Plea Agreement — USA v. Margaryan et al (Dkt. 301, C.D. Cal.)
Summary
The plea agreement between Sarkis Sarkisyan, aka Samuel Shaw, and the United States Attorney's Office for the Central District of California in United States v. Sarkis Sarkisyan, et al, CR No. 25-458-CV, filed March 17, 2026 as Document 301. The defendant agrees to plead guilty to counts thirty-four and thirty-five, wire fraud under 18 U.S.C. § 1343, and count thirty, transactional money laundering under 18 U.S.C. § 1957, and the parties agree that restitution of at least $786,457 is due to the U.S. Small Business Administration. The parties stipulate to a total offense level of 21 or 23, with the government reserving the right to argue for a higher loss enhancement. In the factual basis the defendant admits false PPP loan and forgiveness certifications for Prime and a $25,000 transfer of proceeds of an SBA-guaranteed loan.
Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“Plea Agreement — USA v. Margaryan et al (Dkt. 301, C.D. Cal.).”
Original at ecf.cacd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/plea-agreement-usa-v-margaryan-et-al-dkt-301-c-d-cal-d426928f18/
, SHA-256 522038a398cab0481394dde74529a3a4717b38d26e553172da7c1392818781dd.Full text
Case 2:25-cr-00458-CV Document 301 Filed 03/17/26 Page 1 of 32 Page ID
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1 TODD BLANCHE
Deputy Attorney General
2 BILAL A. ESSAYLI
First Assistant United States Attorney
3 ALEXANDER B. SCHWAB
Assistant United States Attorney
4 Acting Chief, Criminal Division
MARK AVEIS (Cal. Bar No. 107881)
5 Assistant United States Attorney
Major Frauds Section
6 1100 United States Courthouse
312 North Spring Street
7 Los Angeles, California 90012
Telephone: (213) 894-4477
8 Facsimile: (213) 894-0141
E-mail: mark.aveis@usdoj.gov
9
Attorneys for Plaintiff
10 UNITED STATES OF AMERICA
11 UNITED STATES DISTRICT COURT
12 FOR THE CENTRAL DISTRICT OF CALIFORNIA
13 UNITED STATES OF AMERICA, No. CR 25-458-CV
14 Plaintiff, PLEA AGREEMENT FOR DEFENDANT
SARKIS SARKISYAN
15 v.
16 SARKIS SARKISYAN, aka Samuel
Shaw,
17
Defendant.
18
19
20 1. This constitutes the plea agreement between defendant
21 SARKIS SARKISYAN, aka “Samuel Shaw,” (“defendant”) and the United
22 States Attorney’s Office for the Central District of California (the
23 “USAO”) in the above-captioned case. This agreement is limited to
24 the USAO and cannot bind any other federal, state, local, or foreign
25 prosecuting, enforcement, administrative, or regulatory authorities.
26 DEFENDANT’S OBLIGATIONS
27 2. Defendant agrees to:
28
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1 a. At the earliest opportunity requested by the USAO and
2 provided by the Court, appear and plead guilty to counts thirty,
3 thirty-four, and thirty-five of the indictment in United States v.
4 Sarkis Sarkisyan, et al, CR No. 25-458-CV, which charges defendant
5 with wire fraud in violation of 18 U.S.C. § 1343 (counts thirty-four
6 and thirty-five), and with transactional money laundering in
7 violation of 18 U.S.C. § 1957 (count thirty).
8 b. Not contest facts agreed to in this agreement.
9 c. Abide by all agreements regarding sentencing contained
10 in this agreement.
11 d. Appear for all court appearances, surrender as ordered
12 for service of sentence, obey all conditions of any bond, and obey
13 any other ongoing court order in this matter.
14 e. Not commit any crime; however, offenses that would be
15 excluded for sentencing purposes under United States Sentencing
16 Guidelines (“U.S.S.G.” or “Sentencing Guidelines”) § 4A1.2(c) are not
17 within the scope of this agreement.
18 f. Be truthful at all times with the United States
19 Probation and Pretrial Services Office and the Court.
20 g. Pay the applicable special assessments at or before
21 the time of sentencing unless defendant has demonstrated a lack of
22 ability to pay such assessments.
23 RESTITUTION
24 3. Defendant agrees that any and all criminal debt ordered by
25 the Court will be due in full and immediately. The government is not
26 precluded from pursuing, in excess of any payment schedule set by the
27 Court, any and all available remedies by which to satisfy defendant’s
28
2
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1 payment of the full financial obligation, including referral to the
2 Treasury Offset Program.
3 4. Defendant further agrees to:
4 a. Complete the Financial Disclosure Statement on a form
5 provided by the USAO and, within 30 days of defendant’s entry of a
6 guilty plea, deliver the signed and dated statement, along with all
7 of the documents requested therein, to the USAO by either email at
8 usacac.FinLit@usdoj.gov (preferred) or mail to the USAO Financial
9 Litigation Section at 300 North Los Angeles Street, Suite 7516, Los
10 Angeles, CA 90012. Defendant agrees that defendant’s ability to pay
11 criminal debt shall be assessed based on the completed Financial
12 Disclosure Statement and all required supporting documents, as well
13 as other relevant information relating to ability to pay.
14 b. Authorize the USAO to obtain a credit report upon
15 returning a signed copy of this plea agreement.
16 Consent to the USAO inspecting and copying all of defendant’s
17 financial documents and financial information held by the United
18 States Probation and Pretrial Services Office.
19 THE USAO’S OBLIGATIONS
20 5. The USAO agrees to:
21 a. Not contest facts agreed to in this agreement.
22 b. Abide by all agreements regarding sentencing contained
23 in this agreement.
24 c. At the time of sentencing, move to dismiss the
25 remaining counts of the indictment and all counts against defendant
26 in the complaints in 25-MJ-3132-DUTY and 25-MJ-3138-DUTY as against
27 defendant. Defendant agrees, however, that at the time of sentencing
28 the Court may consider any dismissed charge(s) in determining the
3
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1 applicable Sentencing Guidelines range, the propriety and extent of
2 any departure from that range, and the sentence to be imposed.
3 d. At the time of sentencing, provided that defendant
4 demonstrates an acceptance of responsibility for the offenses up to
5 and including the time of sentencing, recommend a two-level reduction
6 in the applicable Sentencing Guidelines offense level, pursuant to
7 U.S.S.G. § 3E1.1, and recommend and, if necessary, move for an
8 additional one-level reduction if available under that section.
9 NATURE OF THE OFFENSES
10 6. Defendant understands that for defendant to be guilty of
11 the crime charged in counts thirty-four and thirty-five of the
12 indictment, that is, wire fraud, in violation of Title 18, United
13 States Code, Section 1343, the following must be true: (1) defendant
14 knowingly participated in or devised a scheme or plan to defraud, or
15 a scheme or plan for obtaining money or property by means of false or
16 fraudulent pretenses, representations, or promises; (2) the
17 statements made as part of the scheme were material; that is, they
18 had a natural tendency to influence, or were capable of influencing,
19 a person to part with money or property; (3) defendant acted with the
20 intent to defraud, that is, the intent to deceive and cheat; and
21 (4) defendant used, or caused to be used, an interstate wire
22 communication to carry out or attempt to carry out an essential part
23 of the scheme. Defendant understands that for defendant to be guilty
24 of the crime charged in count thirty of the indictment, that is,
25 transactional money laundering, in violation of Title 18, United
26 States Code, Section 1957, the following must be true: (1) defendant
27 knowingly engaged or attempted to engage in a monetary transaction;
28 (2) defendant knew the transaction involved criminally derived
4
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1 property; (3) the property had a value greater than $10,000; (4) the
2 property was, in fact, derived from the wire fraud scheme alleged in
3 the indictment; and (5) the transaction occurred in the United
4 States.
5 PENALTIES AND RESTITUTION
6 7. Defendant understands that the statutory maximum sentence
7 that the Court can impose for a violation of Title 18, United States
8 Code, Section 1343, is: twenty years’ imprisonment; a three-year
9 period of supervised release; a fine of $250,000 or twice the gross
10 gain or gross loss resulting from the offense, whichever is greatest;
11 and a mandatory special assessment of $100. Defendant understands
12 that the statutory maximum sentence that the Court can impose for a
13 violation of Title 18, United States Code, Section 1957, is: ten
14 years’ imprisonment; a three-year period of supervised release; a
15 fine of $250,000 or twice the amount of the criminally derived
16 property involved in the transaction, whichever is greatest; and a
17 mandatory special assessment of $100. Defendant understands that,
18 therefore, the total statutory maximum sentence that the Court can
19 impose in this case is: fifty years’ imprisonment; a three-year
20 period of supervised release; a fine of $750,000 or twice the gross
21 gain or gross loss resulting from the offense, or twice the amount of
22 the criminally derived property involved in the transaction,
23 whichever is greatest; and a mandatory special assessment of $300.
24 8. Defendant understands that defendant will be required to
25 pay full restitution to the victims of the offenses to which
26 defendant is pleading guilty. Defendant agrees that, in return for
27 the United States’ compliance with its obligations under this
28 agreement, the Court may order restitution to persons other than the
5
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1 victims of the offenses to which defendant is pleading guilty and in
2 amounts greater than those alleged in the counts to which defendant
3 is pleading guilty. In particular, defendant agrees that the Court
4 may order restitution to any victim of any of the following for any
5 losses suffered by that victim as a result: (a) any relevant conduct,
6 as defined in U.S.S.G. § 1B1.3, in connection with the offense to
7 which defendant is pleading guilty; and (b) any counts dismissed
8 pursuant to this agreement as well as all relevant conduct, as
9 defined in U.S.S.G. § 1B1.3, in connection with those counts. The
10 parties agree that the total amount of restitution due is at least
11 $786,457, payable to the U.S. Small Business Administration.
12 9. Defendant understands that supervised release is a period
13 of time following imprisonment during which defendant will be subject
14 to various restrictions and requirements. Defendant understands that
15 if defendant violates one or more of the conditions of any supervised
16 release imposed, defendant may be returned to prison for all or part
17 of the term of supervised release authorized by statute for the
18 offense that resulted in the term of supervised release, which could
19 result in defendant serving a total term of imprisonment greater than
20 the statutory maximum stated above.
21 10. Defendant understands that, by pleading guilty, defendant
22 may be giving up valuable government benefits and valuable civic
23 rights, such as the right to vote, the right to possess a firearm,
24 the right to hold office, and the right to serve on a jury.
25 Defendant understands that he is pleading guilty to felonies and that
26 it is a federal crime for a convicted felon to possess a firearm or
27 ammunition. Defendant understands that the convictions in this case
28 may also subject defendant to various other collateral consequences,
6
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1 including but not limited to revocation of probation, parole, or
2 supervised release in another case and suspension or revocation of a
3 professional license. Defendant understands that unanticipated
4 collateral consequences will not serve as grounds to withdraw
5 defendant’s guilty pleas.
6 11. Defendant and his counsel have discussed the fact that,
7 and defendant understands that, if defendant is not a United States
8 citizen, the convictions in this case, or any one of them, make it
9 practically inevitable and a virtual certainty that defendant will be
10 removed or deported from the United States. Defendant may also be
11 denied United States citizenship and admission to the United States
12 in the future. Defendant understands that while there may be
13 arguments that defendant can raise in immigration proceedings to
14 avoid or delay removal, removal is presumptively mandatory and a
15 virtual certainty in this case. Defendant further understands that
16 removal and immigration consequences are the subject of a separate
17 proceeding and that no one, including his attorney or the Court, can
18 predict to an absolute certainty the effect of his convictions on his
19 immigration status. Defendant nevertheless affirms that he wants to
20 plead guilty regardless of any immigration consequences that his
21 pleas may entail, even if the consequence is automatic removal from
22 the United States.
23 FACTUAL BASIS
24 12. Defendant admits that defendant is, in fact, guilty of the
25 offenses to which defendant is agreeing to plead guilty. Defendant
26 and the USAO agree to the statement of facts provided in Exhibit A
27 attached hereto and incorporated herein by this reference, and agree
28 that this statement of facts is sufficient to support pleas of guilty
7
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1 to the charges described in this agreement and to establish the
2 Sentencing Guidelines factors set forth in paragraph 14 below but is
3 not meant to be a complete recitation of all facts relevant to the
4 underlying criminal conduct or all facts known to either party that
5 relate to that conduct.
6 SENTENCING FACTORS
7 13. Defendant understands that in determining defendant’s
8 sentence the Court is required to calculate the applicable Sentencing
9 Guidelines range and to consider that range, possible departures
10 under the Sentencing Guidelines, and the other sentencing factors set
11 forth in 18 U.S.C. § 3553(a). Defendant understands that the
12 Sentencing Guidelines are advisory only, that defendant cannot have
13 any expectation of receiving a sentence within the calculated
14 Sentencing Guidelines range, and that after considering the
15 Sentencing Guidelines and the other § 3553(a) factors, the Court will
16 be free to exercise its discretion to impose any sentence it finds
17 appropriate up to the maximum set by statute for the crimes of
18 conviction.
19 14. Defendant and the USAO agree to the following applicable
20 Sentencing Guidelines factors:
21 Base Offense Level: 7 [U.S.S.G. § 2B1.1(a)]
22 Loss between $550K and $1.5MM [U.S.S.G. § 2B1.1(b)(1)(H),
or between $1.5MM and $3.5MM: 14
23 or (I)]
16
24
Money Laundering: 1 [U.S.S.G. § 2S1.1(b)(2)(A)]
25
Sophisticated Means: 2 [U.S.S.G. § 2B1.1(b)(10)]
26
Acceptance of Responsibility: -3 [U.S.S.G. § 3E1.1]
27
Total Offense Level: 21 or 23
28
8
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1 The USAO will agree to a two-level downward adjustment for acceptance
2 of responsibility (and, if applicable, move for an additional one-
3 level downward adjustment under U.S.S.G. § 3E1.1(b)) only if the
4 conditions set forth in paragraph 2 are met and if defendant has not
5 committed, and refrains from committing, acts constituting
6 obstruction of justice within the meaning of U.S.S.G. § 3C1.1, as
7 discussed below. Nothwithstanding the foregoing, the government
8 reserves the right to argue for, and defendant reserves the right to
9 oppose, an additional two levels for loss under U.S.S.G. §
10 2B1.1(b)(1)(I). Subject to paragraph 29 below and the government’s
11 right to argue for an additional two level for loss under U.S.S.G. §
12 2B1.1(b)(1)(I), defendant and the USAO agree not to seek, argue, or
13 suggest in any way, either orally or in writing, that any other
14 specific offense characteristics, adjustments, or departures relating
15 to the offense level be imposed. Defendant agrees, however, that if,
16 after signing this agreement but prior to sentencing, defendant were
17 to commit an act, or the USAO were to discover a previously
18 undiscovered act committed by defendant prior to signing this
19 agreement, which act, in the judgment of the USAO, constituted
20 obstruction of justice within the meaning of U.S.S.G. § 3C1.1, the
21 USAO would be free to seek the enhancement set forth in that section
22 and to argue that defendant is not entitled to a downward adjustment
23 for acceptance of responsibility under U.S.S.G. § 3E1.1.
24 15. Defendant understands that there is no agreement as to
25 defendant’s criminal history or criminal history category.
26 16. Defendant and the USAO reserve the right to argue for a
27 sentence outside the sentencing range established by the Sentencing
28
9
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1 Guidelines based on the factors set forth in 18 U.S.C. § 3553(a)(1),
2 (a)(2), (a)(3), (a)(6), and (a)(7).
3 WAIVER OF CONSTITUTIONAL RIGHTS
4 17. Defendant understands that by pleading guilty, defendant
5 gives up the following rights:
6 a. The right to persist in a plea of not guilty.
7 b. The right to a speedy and public trial by jury.
8 c. The right to be represented by counsel –- and if
9 necessary have the Court appoint counsel -- at trial. Defendant
10 understands, however, that, defendant retains the right to be
11 represented by counsel –- and if necessary have the Court appoint
12 counsel –- at every other stage of the proceeding.
13 d. The right to be presumed innocent and to have the
14 burden of proof placed on the government to prove defendant guilty
15 beyond a reasonable doubt.
16 e. The right to confront and cross-examine witnesses
17 against defendant.
18 f. The right to testify and to present evidence in
19 opposition to the charges, including the right to compel the
20 attendance of witnesses to testify.
21 g. The right not to be compelled to testify, and, if
22 defendant chose not to testify or present evidence, to have that
23 choice not be used against defendant.
24 h. Any and all rights to pursue any affirmative defenses,
25 Fourth Amendment or Fifth Amendment claims, and other pretrial
26 motions that have been filed or could be filed.
27
28
10
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1 WAIVER OF APPEAL OF CONVICTIONS AND COLLATERAL ATTACK
2 18. Defendant understands that, with the exception of an
3 appeal based on a claim that defendant’s guilty pleas were
4 involuntary, by pleading guilty defendant is waiving and giving up
5 any right to appeal defendant’s convictions on the offenses to which
6 defendant is pleading guilty. Defendant understands that this waiver
7 includes, but is not limited to, arguments that the statutes to which
8 defendant is pleading guilty are unconstitutional, and any and all
9 claims that the statement of facts provided herein is insufficient to
10 support defendant’s pleas of guilty.
11 19. Defendant also gives up any right to bring a post-
12 conviction collateral attack on the convictions or sentence,
13 including any order of restitution, except a post-conviction
14 collateral attack based on a claim of ineffective assistance of
15 counsel, a claim of newly discovered evidence, or an explicitly
16 retroactive change in the applicable Sentencing Guidelines,
17 sentencing statutes, or statutes of conviction. Defendant
18 understands that this waiver includes, but is not limited to,
19 arguments that the statutes to which defendant is pleading guilty
20 are unconstitutional, and any and all claims that the statement of
21 facts provided herein is insufficient to support defendant’s pleas
22 of guilty.
23 LIMITED MUTUAL WAIVER OF APPEAL OF SENTENCE
24 20. Defendant agrees that, provided the Court imposes a total
25 term of imprisonment on all counts of conviction of not more than the
26 statutory maximum, defendant gives up the right to appeal all of the
27 following: (a) the procedures and calculations used to determine and
28 impose any portion of the sentence; (b) the term of imprisonment
11
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1 imposed by the Court; (c) the fine imposed by the Court, provided it
2 is within the statutory maximum; (d) to the extent permitted by law,
3 the constitutionality or legality of defendant’s sentence, provided
4 it is within the statutory maximum; (e) the amount and terms of any
5 restitution order; (f) the term of probation or supervised release
6 imposed by the Court, provided it is within the statutory maximum;
7 and (g) any of the following conditions of probation or supervised
8 release imposed by the Court: the conditions set forth in Second
9 Amended General Order 20-04 of this Court; and the drug testing
10 conditions mandated by 18 U.S.C. §§ 3563(a)(5) and 3583(d).
11 21. The USAO agrees that, provided all portions of the
12 sentence are at or below the statutory maximum specified above, the
13 USAO gives up its right to appeal any portion of the sentence.
14 WAIVER OF RIGHTS CONCERNING PLEA COLLOQUY AND FACTUAL BASIS
15 22. Defendant agrees that: (i) any statements made by
16 defendant, under oath, at the guilty plea hearing; (ii) the agreed to
17 factual basis statement in this agreement; and (iii) any evidence
18 derived from such statements, shall be admissible against defendant
19 in any action against defendant, and defendant waives and gives up
20 any claim under the United States Constitution, any statute, Rule 410
21 of the Federal Rules of Evidence, Rule 11(f) of the Federal Rules of
22 Criminal Procedure, or any other federal rule, that the statements or
23 any evidence derived from the statements should be suppressed or are
24 inadmissible.
25 Defendant further agrees that this paragraph of the agreement is
26 severable. Thus, defendant’s waivers are binding and effective even
27 if, subsequent to defendant’s signing this agreement, defendant
28 declines to plead guilty, the Court declines to accept his guilty
12
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1 plea, or, if this agreement is of the type described in Federal Rule
2 of Criminal Procedure 11(c)(1)(A) or (c)(1)(C), the Court rejects
3 this agreement. Defendant also agrees that his waivers are binding
4 and effective even if some other portion of this agreement is found
5 to be invalid by this Court or the Ninth Circuit.
6 RESULT OF WITHDRAWAL OF GUILTY PLEA
7 23. Defendant agrees that if, after entering a guilty plea or
8 pleas pursuant to this agreement, defendant seeks to withdraw and
9 succeeds in withdrawing defendant’s guilty plea or pleas on any basis
10 other than a claim and finding that entry into this plea agreement
11 was involuntary, then (a) the USAO will be relieved of all of its
12 obligations under this agreement; and (b) should the USAO choose to
13 pursue any charge that was either dismissed or not filed as a result
14 of this agreement, then (i) any applicable statute of limitations
15 will be tolled between the date of defendant’s signing of this
16 agreement and the filing commencing any such action; and
17 (ii) defendant waives and gives up all defenses based on the statute
18 of limitations, any claim of pre-indictment delay, or any speedy
19 trial claim with respect to any such action, except to the extent
20 that such defenses existed as of the date of defendant’s signing this
21 agreement.
22 RESULT OF VACATUR, REVERSAL, OR SET-ASIDE
23 24. Defendant agrees that if any count of conviction is
24 vacated, reversed, or set aside the USAO may: (a) ask the Court to
25 resentence defendant on any remaining counts of conviction, with both
26 the USAO and defendant being released from any stipulations regarding
27 sentencing contained in this agreement, (b) ask the Court to void the
28 entire plea agreement and vacate defendant’s guilty pleas on any
13
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1 remaining counts of conviction, with both the USAO and defendant
2 being released from all their obligations under this agreement, or
3 (c) leave defendant’s remaining convictions, sentence, and plea
4 agreement intact. Defendant agrees that the choice among these three
5 options rests in the exclusive discretion of the USAO.
6 EFFECTIVE DATE OF AGREEMENT
7 25. This agreement is effective upon signature and execution
8 of all required certifications by defendant, defendant’s counsel, and
9 an Assistant United States Attorney.
10 BREACH OF AGREEMENT
11 26. Defendant agrees that if defendant, at any time after the
12 effective date of this agreement, knowingly violates or fails to
13 perform any of defendant’s obligations under this agreement (“a
14 breach”), the USAO may declare this agreement breached. All of
15 defendant’s obligations are material, a single breach of this
16 agreement is sufficient for the USAO to declare a breach, and
17 defendant shall not be deemed to have cured a breach without the
18 express agreement of the USAO in writing. If the USAO declares this
19 agreement breached, and the Court finds such a breach to have
20 occurred, then: (a) if defendant has previously entered guilty pleas
21 pursuant to this agreement, defendant will not be able to withdraw
22 the guilty pleas, and (b) the USAO will be relieved of all its
23 obligations under this agreement.
24 27. Following the Court’s finding of a knowing breach of this
25 agreement by defendant, should the USAO choose to pursue any charge
26 that was either dismissed or not filed as a result of this agreement,
27 then:
28
14
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1 a. Defendant agrees that any applicable statute of
2 limitations is tolled between the date of defendant’s signing of this
3 agreement and the filing commencing any such action; and
4 b. Defendant waives and gives up all defenses based on
5 the statute of limitations, any claim of pre-indictment delay, or any
6 speedy trial claim with respect to any such action, except to the
7 extent that such defenses existed as of the date of defendant’s
8 signing this agreement.
9 COURT AND UNITED STATES PROBATION AND PRETRIAL SERVICES
10 OFFICE NOT PARTIES
11 28. Defendant understands that the Court and the United States
12 Probation and Pretrial Services Office are not parties to this
13 agreement and need not accept any of the USAO’s sentencing
14 recommendations or the parties’ agreements to facts or sentencing
15 factors.
16 29. Defendant understands that both defendant and the USAO are
17 free to: (a) supplement the facts by supplying relevant information
18 to the United States Probation and Pretrial Services Office and the
19 Court, (b) correct any and all factual misstatements relating to the
20 Court’s Sentencing Guidelines calculations and determination of
21 sentence, and (c) argue on appeal and collateral review that the
22 Court’s Sentencing Guidelines calculations and the sentence it
23 chooses to impose are not error, although each party agrees to
24 maintain its view that the calculations in paragraph 14 are
25 consistent with the facts of this case. While this paragraph permits
26 both the USAO and defendant to submit full and complete factual
27 information to the United States Probation and Pretrial Services
28 Office and the Court, even if that factual information may be viewed
15
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1 as inconsistent with the facts agreed to in this agreement, this
2 paragraph does not affect defendant’s and the USAO’s obligations not
3 to contest the facts agreed to in this agreement.
4 30. Defendant understands that even if the Court ignores any
5 sentencing recommendation, finds facts or reaches conclusions
6 different from those agreed to, and/or imposes any sentence up to the
7 maximum established by statute, defendant cannot, for that reason,
8 withdraw defendant’s guilty pleas, and defendant will remain bound to
9 fulfill all defendant’s obligations under this agreement. Defendant
10 understands that no one –- not the prosecutor, defendant’s attorney,
11 or the Court –- can make a binding prediction or promise regarding
12 the sentence defendant will receive, except that it will be within
13 the statutory maximum.
14 NO ADDITIONAL AGREEMENTS
15 31. Defendant understands that, except as set forth herein,
16 there are no promises, understandings, or agreements between the USAO
17 and defendant or defendant’s attorney, and that no additional
18 promise, understanding, or agreement may be entered into unless in a
19 writing signed by all parties or on the record in court.
20 //
21 //
22
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28
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1 PLEA AGREEMENT PART OF THE GUILTY PLEA HEARING
2 32. The parties agree that this agreement will be considered
3 part of the record of defendant’s guilty plea hearing as if the
4 entire agreement had been read into the record of the proceeding.
5 AGREED AND ACCEPTED
6 UNITED STATES ATTORNEY’S OFFICE
FOR THE CENTRAL DISTRICT OF
7 CALIFORNIA
8 TODD BLANCHE
Deputy Attorney General
9 BILAL A. ESSAYLI
First Assistant United States
10 Attorney
11 March 17, 2026
12 MARK AVEIS Date
Assistant United States Attorney
13
(see following pages)
14 SARKIS SARKISYAN, aka Samuel Shaw Date
Defendant
15
(see following pages)
16 MICHAEL H. ARTAN Date
Attorney for Defendant SARKIS
17 SARKISYAN
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1 EXHIBIT A (Stipulated Factual Basis)
2 The parties agree that the following stipulated factual basis
3 meets the requirements of Fed.R.Crim.P. 11(b)(3).
4 At all relevant times:
5 Defendant was a resident of Los Angeles County, California, in
6 the Central District of California, a location in which he performed
7 all of the acts described below.
8 All funds that were transferred for the benefit of defendant
9 involved the deposit, withdrawal, transfer, or exchange by, through,
10 or to a financial institution engaged in interstate commerce and
11 located in the Central District of California.
12 The Paycheck Protection Program
13 The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act
14 was a federal law enacted in or about March 2020 that was designed to
15 provide emergency financial assistance to Americans suffering
16 economic harm as a result of the COVID-19 pandemic. One form of
17 assistance provided by the CARES Act was the authorization of United
18 States taxpayer funds in the form of loans to small businesses for
19 job retention and certain other expenses through a program referred
20 to as the Paycheck Protection Program (“PPP;” loans under that
21 program are sometimes referred to herein as a “PPPL” or “PPPLs”).
22 PPPL proceeds were required to be used by the applicant business to
23 pay certain expenses such as payroll costs, interest on mortgages,
24 rent, and utilities.
25 In order to obtain a PPPL, a qualifying business was required,
26 among other things, to submit a PPPL application that required the
27 applicant business (through its authorized representative) to
28 acknowledge PPP program rules and make certain affirmative
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1 certifications that the applicant business would comply with all such
2 rules to be eligible to obtain a PPPL. Such certifications required,
3 among other things, that the applicant affirm that “[PPP] funds will
4 be used to retain workers and maintain payroll or make mortgage
5 interest payments, lease payments, and utility payments,” and that
6 the “loan proceeds will be used only for business-related purposes as
7 specified in the [PPPL application]” and consistent with PPP rules.
8 The authorized representative of the applicant was required to
9 certify that “the information provided in th[e] PPP application and
10 the information provided in all supporting documents and forms is
11 true and accurate in material respects,” and that “I understand that
12 if the funds are knowingly used for unauthorized purposes, the
13 federal government may hold me legally liable, such as for charges of
14 fraud.”
15 A PPPL applicant’s representative was also required to state,
16 among other things, the applicant’s average monthly payroll expenses
17 and number of its employees. These figures were used to calculate
18 the amount of money that the business was eligible to receive under
19 the PPP. In addition, the applicant’s representative was required to
20 provide documentation showing its payroll expenses and such other
21 documentation as the U.S. Small Business Administration (“SBA”) or
22 the lender requested.
23 A PPPL application and supporting documents were submitted
24 online through a portal and processed by a participating lender. The
25 applicant’s representative confirmed his/her true identity through a
26 variety of means including providing personal identifying
27 information, uploading a copy of that person’s driver’s license
28 and/or Social Security card, and/or executing loan documents via a
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1 document authentication platform such as DocuSign. If a PPPL
2 application was approved, the participating lender would fund the
3 PPPL using its own funds and would wire-transfer those funds to a
4 bank account designated by the applicant. By wire-transferring the
5 loan proceeds to that designated account, the lender, the SBA and,
6 ultimately, law enforcement would have yet another way to ensure that
7 the application was sought by the stated applicant through his/her
8 duly acting representative and that the applicant received and used
9 those funds in accordance with PPP rules.
10 If PPP lending criteria were followed by the lender, the SBA, in
11 turn, guaranteed the borrower’s repayment in the event of that
12 borrower’s default.
13 PPPL Forgiveness
14 Under certain circumstances, PPP borrowers were entitled to
15 forgiveness of their PPP obligations. As a condition of forgiveness,
16 borrowers were required to complete a “PPP Loan Forgiveness
17 Application” on which their authorized representative represented and
18 certified that the borrower had complied with all PPP rules
19 “including the rules related to . . . eligible uses of PPP loan
20 proceeds[]” and that “[t]he information provided in th[e forgiveness
21 application was] true and correct in all material respects.” The
22 forgiveness application warned that ”knowingly making a false
23 statement to obtain forgiveness was a federal crime, punishable by
24 imprisonment and/or a fine.”
25 ///
26 ///
27 ///
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1 PPP Fraud (Counts Thirty-Four and Thirty-Five)
2 In 2018, defendant caused Prime Funding, Inc. (“Prime”) to be
3 incorporated. In January 2021, defendant caused Prime’s business
4 address to be updated to defendant’s personal residence in Van Nuys,
5 CA (“defendant’s residence”). Prime never did any business.
6 On or about April 14, 2021, defendant submitted online to
7 JPMorgan Chase Bank (“JPMC”) a PPPL application on behalf of Prime
8 from within the Central District of California which was processed
9 using a server outside the state of California. With the intent to
10 influence JPMC to approve Prime’s PPPL application, defendant
11 knowingly and fraudulently stated on the application that the purpose
12 of the PPPL was to cover Prime’s payroll costs for 57 employees at an
13 average monthly payroll of $314,583. In fact, as defendant then well
14 knew, Prime did no business, had no employees or employee salaries to
15 pay, and had no monthly payroll, ever.
16 In further support of Prime’s application for a PPPL, defendant:
17 a. caused to be fabricated, and then submitted to JPMC,
18 fraudulent Internal Revenue Service Forms 941 (quarterly payroll tax
19 returns) that purported to show that Prime had incurred and paid
20 substantial employee taxes. Defendant then well knew that such
21 returns were fraudulent because Prime had neither employees nor paid
22 any employee taxes; and
23 b. fabricated and then submitted to JPMC fraudulent
24 payroll reports purportedly prepared by a third-party payroll
25 processor that falsely identified wages of more than $1.5 million
26 paid to 56 Prime employees whose job titles included “customer
27 service,” “sales,” or “admin.” Defendant then well knew that the
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1 reports were fraudulent because, among other things, Prime had no
2 employees. Below is a page from the fictitious payroll report:
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14 Defendant signed the Prime PPPL application, electronically
15 transmitted it to JPMC, and certified that PPPL proceeds would solely
16 be used by Prime to retain employees or for other permissible
17 business expenses. Defendant then well knew and intended that none
18 of the PPPL proceeds would be used for the certified purposes.
19 In reliance on defendant’s material false statements and
20 fictitious documents, JPMC approved the Prime application and funded
21 the loan of $786,457 by wire transferring the proceeds to an account
22 solely controlled by defendant.
23 On or about June 30, 2022, defendant electronically, over
24 interstate wires, submitted an application from the Central District
25 of California for forgiveness of the entire Prime PPPL. Defendant
26 knowingly and falsely certified that Prime’s payroll costs for the
27 period covered by the Prime PPPL were more than $1.5MM, a figure that
28 defendant then well knew was entirely fraudulent because Prime had no
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1 employees, at all. This false certification was capable of
2 influencing JPMC to forgives the Prime PPPL and thus part with money.
3 Transactional Money Laundering (Count Thirty)
4 On or about June 28, 2023, defendant caused co-defendant Vahe
5 Margaryan, aka William McGrayan, to wire-transfer $25,000 to a Prime
6 account at JPMC that defendant solely controlled, the source of which
7 was proceeds of an SBA-guaranteed loan in the amount of $2.83 million
8 for defendant to purchase an entity called Dynamic Delivery Install,
9 Inc. Defendant then well knew that Dynamic Delivery Install, Inc.,
10 was a “shell” entity that did no business, that the $25,000 wire-
11 transfer involved criminally derived property, that such funds were,
12 in fact, derived from a wire fraud scheme, in violation of 18 U.S.C.
13 § 1343, and that the transfer was designed to conceal commission of
14 that wire fraud scheme.
15 Sentencing Guidelines
16 Defendant agrees that, for the purpose of establishing his
17 stipulated Sentencing Guidelines loss in paragraph 14 of this plea
18 agreement, the actual loss that defendant caused by the
19 misrepresentations and misuse of PPP funds described above was at
20 least $786,457. The parties agree that this actual loss figure is
21 legally appropriate under USSG § 2B1.1(b)(1) et seq.
22 As described above, defendant intentionally engaged in
23 sophisticated means through the offense conduct by, among other
24 things, creating and submitting fraudulent IRS Forms 941 and
25 fraudulent payroll reports.
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