Plea Agreement — USA v. Lain (Dkt. 17, D. Colo.)

Summary

A Plea Agreement and Statement of Facts Relevant to Sentencing in United States of America v. Michael Lain in the U.S. District Court for the District of Colorado, between Assistant United States Attorneys Pegeen D. Rhyne and Patricia Davies and the defendant, represented by Sabra Barnett and Joey Hamby. The defendant agrees to waive indictment and plead guilty to a single-count Information charging wire fraud under 18 U.S.C. § 1343, to pay $600,000 toward restitution at or before sentencing and not to contest a money judgment of $4,138,937.59. The stipulated facts state that 70 EIDL applications for LLCs controlled by the defendant were funded, yielding $3,830,400 in EIDL proceeds and $336,000 in grant proceeds. Total agreed restitution is $4,433,837.59, including $294,900 in PPP funds. The government agrees to recommend a low-end sentence at a total offense level of 22.

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