United States v. Constantin Bobi Sandu — Plea Agreement, Southern District of California (Document 40)

Summary

The plea agreement in United States v. Constantin Bobi Sandu, aka Bobi Sandu, aka Constantin Sandu, Case 3:23-cr-00386-LAB, in the U.S. District Court for the Southern District of California, filed July 11, 2023 as Document 40. Sandu agrees to plead guilty to Counts 2 and 3 of a 3-Count Superseding Information, conspiracy to commit wire fraud and a transfer of approximately $2,367.15 USD to Romania to promote wire fraud, and consents to forfeiture. In the factual basis Sandu admits that, with an uncharged co-conspirator, Sandu prepared fraudulent identification and supporting documents for hundreds of California EDD unemployment applicants who paid fees of $1,000.00 and $1,500.00. It states the conspiracy with 214 uncharged co-conspirators obtained no less than $5,207,687.00 in benefits, and that Sandu personally received approximately $214,950 in criminal proceeds.

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|) Case 3:23-cr-00386-LAB Document 40 Filed 07/11/23 PagelD.201 Page 1 of 17

RANDY S. GROSSMAN aah é Pb
United States Attorney 8 8 ae Be
Jessica Adeline Schulberg
Assistant United States Attorney J 2023
Wisconsin Bar No. 1105177 UL TI
Federal Office Building Clem US DS Tae? COURT

L y Ww, Sy
880 Front Street, Room 6293 SOUTHERN DISTRIC7 OF CALIFORNIA
San Diego, California 92101-8893 BY, DEPUTY

Telephone: (619) 546-9664
Email: jessica.schulberg@usdo}j.gov

Attorneys for United States of America

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Case No. 23CRO0386-LAB

Plaintiff,
Ve PLEA AGREEMENT

CONSTANTIN BOBI SANDU,

aka Bobi Sandu,

aka Tonut Mihai,

aka Constantin Sandu,
Defendant.

IT IS HEREBY AGREED between the plaintiff, UNITED STATES OF
AMERICA, through its counsel, Randy S. Grossman, United States Attorney,
and Jessica Adeline Schulberg, Assistant United States Attorney, and
Defendant Constantin Bobi Sandu, with the advice and consent of Joseph
Thomas Hitrec, counsel for Defendant, as follows:

I
THE PLEA
Defendant agrees to waive Indictment and plead guilty to Counts 2

and 3 of a 3-Count Superseding Information charging Defendant with:

Count 2
Beginning in or about July 2020, and continuing to in or about
August 2022, in the Southern District of California, and elsewhere,
Defendant CONSTANTIN BOBI SANDU, aka Bobi Sandu, Aka Ionut Mihai,
Aka Constantin Sandu, knowingly and intentionally conspired and
agreed with other persons known and unknown, to commit wire fraud

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in violation of Title 18, United States Code, Section 1343; all in
violation of United States Code Section 1349.

Count 3
On or about August 10, 2021, defendant CONSTANTIN BOBI SANDU, aka
Bobi Sandu, Aka Tonut Mihai, Aka Constantin Sandu, transported,
transmitted, and transferred a monetary instrument and funds from
a place in the United States to a place outside the United States—
approximately $2,367.15 USD from a bank account in the United
States to a bank account controlled, managed, supervised,
directed, and owned by I.T. in Romania—with the intent to promote
the carrying on of specified unlawful activity, to wit, Wire Fraud
in violation of Title 18, United States Code, Section 1343; all in
violation of Title 18, United States Code, Section 1956(a) (2) (A).

In addition, Defendant consents to the forfeiture allegations of
the Superseding Information and consents to the forfeiture of all
properties seized in connection with this case, and agrees the attached
forfeiture addendum shall govern forfeiture in this case.

NATURE OF THE OFFENSE

A. ELEMENTS EXPLAINED

The offenses to which Defendant is pleading guilty have the
following elements:
Count 2:

1. Beginning in or about July 2020, and continuing to in or about
August 2022, there was an agreement between two or more
persons to commit the offense of wire fraud; and

2. Defendant joined the agreement knowing of its unlawful
purpose and intending to help accomplish it.

As to the forfeiture allegations, defendant understands that the

Government would have to prove by a preponderance of the evidence that

the property(ies) subject to forfeiture are all property, real and

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. |{ Case 3:23-cr-00386-LAR Document 40 Filed 07/11/23 —PagelD.203 Page 3of17

personal, involved in such offense or are property(ies) traceable to

such property.

Count 3:
1. Defendant transported money from a place in the United States
to or through a place outside the United States; and
2. Defendant acted with the intent to promote the carrying on of

a specified unlawful activity, to wit: wire fraud.

As to the forfeiture allegations, the defendant understands that
the Government would have to prove by a preponderance of the evidence
that the property(ies) subject to forfeiture are all property, real and
personal, involved in such offense or are property(ies) traceable to
such property.

B. ELEMENTS UNDERSTOOD AND ADMITTED ~ FACTUAL BASIS

Defendant has fully discussed the facts of this case with defense
counsel. Defendant has committed each element of the crime and admits
that there is a factual basis for this guilty plea. The following facts

are true and undisputed:

1. Beginning at least as early as July 2020, there was an
agreement between two or more persons to commit the offense
of wire fraud.

2. In or about July 2020, Defendant CONSTANTIN BOBI SANDU joined
the agreement knowing of its unlawful objective and intending
to help accomplish the objective.

3. For example, in furtherance of the conspiracy:

a. The Unemployment Insurance (“UI”) Program was a joint
federal-state partnership administered on behalf of the U.S.
Department of Labor by agencies in each state. In the State
of California, the UI Program was administered by
California’s Employment Development Department (“California
EDD”).
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On March 13, 2020, President Trump declared a nationwide
emergency due to COVID-19, and in March 2020, the Families
First Coronavirus Response Act (“FFCRA”) and the Coronavirus
Aid, Relief, and Economic Security (“CARES”) Act provided
additional funding for state UI agencies to respond to the
COVID-19 pandemic. The CARES Act allowed states to expand the
scope of workers who were eligible to receive state UI
benefits, to extend the period of time for which workers could
be eligible for UI benefits, and to allow workers who may
have exhausted UI benefits under traditional programs to
receive benefits.

The CARES Act further expanded the ability of states to
provide benefits to unemployed workers by creating three new
unemployment programs, namely: the Pandemic Unemployment
Assistance (“PUA”) program, which permitted states to provide
benefits to individuals who were self-employed, seeking part-
time employment, or otherwise would not qualify for regular
unemployment benefits; the Federal Pandemic Unemployment
Compensation (“FPUC”) Program, which provided an additional
amount in federal benefits to individuals collecting
traditional UI program benefits; and the Pandemic Emergency
Unemployment Compensation (“PEUC”) program, which provided
additional weeks of benefits for individuals who had
otherwise exhausted their entitlement to regular UI benefits
(collectively referred to herein as “expanded pandemic UI
benefits”). PUA and FPUC benefits were 100% federally funded
benefits paid through state UI agencies. To receive UI, PUA,
PEUC, and FPUC benefits from a state UI agency, an applicant
could file a claim, via the internet, with the state UI agency
from which he was eligible to seek benefits.

California EDD provided unemployment insurance benefits for
regular UI and expanded pandemic UI benefits to individuals
whom California EDD determined were entitled to receive such
benefits through debit cards, which were funded by California
EDD and issued by Bank 1.

Sandu and an uncharged co-conspirator, D.C., unlawfully
enriched themselves by filing and causing the filing of
fraudulent claims for UI benefits and expanded UI pandemic
benefits on behalf of hundreds of fraudulent applicants, who
received millions of dollars from California’s Employment
Development Department (EDD) and who paid thousands of
dollars per fraudulent application to Sandu, D.C., and other
co-conspirators.

Sandu and D.C. developed a process to apply for benefits from
EDD by creating fraudulent identifications, falsified utility

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bills, falsified earnings statements, falsified W-2s, and
falsified health insurance cards that Sandu and D.C. provided
to fraudu-lent applicants for use in their EDD applications.
As part of this process, Sandu and/or D.C. would transfer
fraudulent identification documents to other individuals to
aid with submitting the fraudulent applications.

Sandu and D.C. often “backdated” or modified EDD applications
with earlier fictitious unemployment start date to generate
the most possible fraudulent income, and therefore, the
greatest payout of undeserved benefits.

Sandu himself applied for undeserved EDD benefits four
separate times, on September 18, 2020, July 10, 2021, July
13, 2021, and June 5, 2022. On September 18, 2020, Sandu
submitted his first application listing his true social
security number (SSN). Sandu used different, and fraudulent,
SSNs in each subsequent application. Sandu received a total
of $54,450 for himself as a result of these four applications.

Beginning in July 2021, Sandu and OD.C. sent public
announcements via Facebook to a large network of associates,
advertising and offering their services in conducting the
fraud. Specifically, Sandu and D.C. used these announcements
to recruit new conspirators that they could use to submit
additional fraudulent applications to EDD.

Sandu and D.C. communicated with fraudulent applicants via
Facebook messaging or other electronic means, and/or met with
them in person to collect their personal identifiable
information (PIT) for purposes of generating false
identifications and supporting documents, and submitting
fraudulent applications.

Sandu and D.C. used PII provided by fraudulent applicants to
create or have others create false identifications and
supporting documents, which would then be submitted in
connection with the fraudulent applications for UI benefits
from EDD.

Sandu and D.C. used their own electronic devices to create
and/or manipulate many of the ID.me accounts that were by
hundreds of fraudulent applicants to apply for EDD benefits.

An applicant paid Sandu a $1,000.00 down payment for his
assistance at the time of the application and $1,500.00 after
an applicant received undeserved benefits from EDD; Sandu
then paid D.C. $400.00-$500.00 and up to $1,000.00 of this
fee received for D.C.’s unlawful assistance.

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The

Rach time a fraudulent benefits application was approved, the
scheme caused the resulting benefits to be loaded on a debit
card via interstate wire transmission, using Bank 1’s servers
located outside the State of California.

In total, between July 2020 and August 2022, Sandu conspired
with 214 uncharged co-conspirators, including D.C., to
fraudulently obtain no less than $5,207,687.00 in California
Unemployment Insurance benefits.

Over the course of the conspiracy, Sandu communicated with
his contractor, I.T., in Romania over Facebook messenger with
messages containing numerous photos of Sandu’s house in
Romania (located at Capu Piscului 675a, Dobresti, Arges
County, Romania) and construction materials, invoices, and
receipts from a Romanian home supply store. In response to
the receipts, and invoices, Sandu responded with screenshots
of Remitly transfer confirmations showing transfer of funds
from Sandu in the United States to I.T. in Romania.

Between May 19, 2021 and August 14, 2022, Sandu sent 20
transactions via the money transfer service Remitly from the
United States to his contractor, I.T., in Romania totaling
more than $16,000.00, used to pay for the renovation of
Sandu’s house in Romania located at Capu Piscului 673a,
Dobresti, Arges County, Romdnia. The funds were proceeds from
Sandu’s wire fraud conspiracy. On October 25, 2022 and
December 6, 2022, Sandu posted photos on Facebook of himself
and his family members in the vicinity of his newly renovated
house in Romania.

Defendant agrees that from his offenses of conviction he
personally received and obtained the total sum. of
approximately $214,950 in criminal proceeds which are subject
to forfeiture as provided in the attached forfeiture
addendum.

PENALTIES

crimes to which Defendant is pleading guilty carry the

following penalties:

Count 2:

A.

B.

a maximum 30 years in prison;

a maximum $1,000,000 fine;

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. |j-Case 3:23-cr-00386-LAB Document 40 Filed 07/11/23 _PagelD.207 Page 7 of 17

Cc. a mandatory special assessment of $100 per count;

D. a term of supervised release of up to 5 years. Failure to
comply with any condition of supervised release may result in
revocation of supervised release, requiring Defendant to
serve in prison, upon revocation, all or part of the statutory
maximum term of supervised release,

BE. Forfeiture of all property, real or personal, involved in such

offense, or any property traceable to such property.

Count 3:
A. a maximum 20 years in prison;
B. a maximum $500,000 fine, or twice the value of the monetary

instrument or funds involved in the transportation,
transmission, or transfer, whichever is greater;

Cc. a mandatory special assessment of $100 per count; and

D. a term of supervised release of up to 3 years. Failure to
comply with any condition of supervised release may result in
revocation of supervised release, requiring Defendant to
serve in prison, upon revocation, all or part of the statutory
maximum term of supervised release.

EB. Forfeiture of all property, real or personal, involved in
such offense, or any property traceable to such property.

IV

DEFENDANT'S WAIVER OF TRIAL RIGHTS AND
UNDERSTANDING OF CONSEQUENCES

This guilty plea waives Defendant’s right at trial to:
A. Continue to plead not guilty and require the Government to
prove the elements of the crime beyond a reasonable doubt;

B. A speedy and public trial by jury;

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. || -Case 3:23-cr-00386-LABR Document 40 Filed 07/11/23 _PagelD.208 Page 8 of 17

on The assistance of counsel at all stages;
D. Confront and cross-examine adverse witnesses;
E. Testify and present evidence and to have witnesses testify on

behalf of Defendant; and,
F. Not testify or have any adverse inferences drawn from the
Failure to testify.

Defendant has been advised by counsel and understands that because
defendant is not a citizen of the United States, defendant’s conviction
in this case makes it practically inevitable and a virtual certainty
that defendant will be removed or deported from the United States.
Defendant may also be denied United States citizenship and admission to

the United States in the future.
V

DEFENDANT ACKNOWLEDGES NO PRETRIAL RIGHT TO BE
PROVIDED WITH IMPEACHMENT AND AFFIRMATIVE DEFENSE INFORMATION

Any information establishing the factual innocence of Defendant
known to the undersigned prosecutor in this case has been turned over
to Defendant. The Government will continue to provide such information
establishing the factual innocence of Defendant.

If this case proceeded to trial, the Government would ‘be required
to provide impeachment information for its witnesses. In addition, if
Defendant raised an affirmative defense, the Government would be
required to provide information in its possession that supports such a
defense. By pleading guilty Defendant will not be provided this
information, if any, and Defendant waives any right to this information.

Defendant will not attempt to withdraw the guilty plea or to file a

collateral attack based on the existence of this information.

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.Case 3:23-cr-00386-LAB Document 40 Filed 07/11/23 ~RagelD.209 Page 9 of 17

VI

DEFENDANT'S REPRESENTATION THAT GUILTY
PLEA IS KNOWING AND VOLUNTARY

Defendant represents that:

A. Defendant has had a full opportunity to discuss all the facts
and circumstances of this case with defense counsel and has
a clear understanding of the charges and the consequences of
this plea. By pleading guilty, Defendant may be giving up,
and rendered ineligible to receive, valuable government
benefits and civic rights, such as the right to vote, the
right to possess a firearm, the right to hold office, and the
right to serve on a jury. The conviction in this case may
subject Defendant to various collateral consequences,
including but not limited to revocation of probation, parole,
or supervised release in another case; debarment from
government contracting; and suspension or revocation of a
professional license, none of which can serve as grounds to
withdraw Defendant’s guilty plea.

B. No one has made any promises or offered any rewards in return
for this guilty plea, other than those contained in this
agreement or otherwise disclosed to the Court.

on No one has threatened Defendant or Defendant's family to
induce this guilty plea.

D. Defendant is pleading guilty because Defendant is guilty and
for no other reason.

AGREEMENT LIMITED TO U.S. ATTORNEY’S OFFICE
SOUTHERN DISTRICT OF CALIFORNIA

This plea agreement is limited to the United States Attorney’s
Office for the Southern District of California, and cannot bind any
other authorities in any type of matter, although the Government will
bring this plea agreement to the attention of other authorities if
requested by Defendant.

VIII

APPLICABILITY OF SENTENCING GUIDELINES

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Case 3:23-cr-00386-LAR, Document 40 Filed 07/11/23 _PagelD.210 Page 10 of 17

The sentence imposed will be based on the factors set forth in 18
U.S.C. $ 3553(a). In imposing the sentence, the sentencing judge must
consult the United States Sentencing Guidelines (Guidelines) and take
them into account. Defendant has discussed the Guidelines with defense
counsel and understands that the Guidelines are only advisory, not
mandatory. The Court may impose a sentence more severe or less severe
than otherwise applicable under the Guidelines, up to the maximum in
the statute of conviction. The sentence cannot be determined until a
presentence report is prepared by the U.S. Probation Office and defense
counsel and the Government have an opportunity to review and challenge
the presentence report. Nothing in this plea agreement limits the
Government’s duty to provide complete and accurate facts to the district
court and the U.S. Probation Office.

IX

SENTENCE IS WITHIN SOLE DISCRETION OF JUDGE

This plea agreement is made pursuant to Federal Rule of Criminal
Procedure ii(c) (1) (B). The sentence is within the sole discretion of
the sentencing judge who may impose the maximum sentence provided by
statute. It is uncertain at this time what Defendant’s sentence will
be. The Government has not made and will not make any representation
about what sentence Defendant will receive. Any estimate of the probable
sentence by defense counsel is not a promise and is not binding on the
Court. Any recommendation by the Government at sentencing also is not
binding on the Court. If the sentencing judge does not follow any of
the parties’ sentencing recommendations, Defendant will not withdraw

the plea.

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PARTIES’ SENTENCING RECOMMENDATIONS

A. SENTENCING GUIDELINE CALCULATIONS

Although the Guidelines are only advisory and just one factor the
Court will consider under 18 U.S.C. § 3553(a) in imposing a sentence,
the parties will jointly recommend the following Base Offense Level,

Specific Offense Characteristics, Adjustments, and Departures:
Count 2 ~- Conspiracy to Commit Wire Fraud 18 USC §§ 1343 and 1349:

1. Base Offense Level [$2Bl1.1(a) (1) ] 7

2. Loss exceeds more than $3,500,000 +18

3. Sophisticated Means [$2Bl1.1(b) (10) (C) ] +2

4. Unauthorized Use/Transfer of Means of +2
Identification [$2Bl.1(b) (11) (C) (i)]

5. 18 U.S.C. § 1040 National Emergency +2

[$2Bl.1(b) (12)]

Count 3 ~- International Money Laundering 18 USC 1956 (a) (2) (A)

1. Base Offense Level [§ 251.1 (a) (1) ] 313
2. Convicted Under 18 U.S.C. § 1956 +2
[$ 2S1.1(b) (2) (B)]

Grouping Calculation

1. Offense Level [§§$ 3D1.2, 3D1.3] 332
2. Acceptance of Responsibility [S$ 3E1.1] -3
3. Combination of Circumstances [§ 5K2.0]} -4

B. ACCEPTANCE OF RESPONSIBILITY

Despite paragraph A above, the Government need not recommend an

adjustment for Acceptance of Responsibility if Defendant engages in

- This is the offense level for the underlying offense of conspiracy
to commit wire fraud under USSG § 2Bi.1.

2 The United States believes the two counts should be grouped
together and the Guidelines should be calculated based on the count
with the highest offense level pursuant to USSG § 3D1.3(a).

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conduct inconsistent with acceptance of responsibility including, but
not limited to, the following:

1. Fails to truthfully admit a complete factual basis as
stated in the plea at the time the plea is entered, or
falsely denies, or makes a statement inconsistent with,
the factual basis set forth in this agreement;

2. Falsely denies prior criminal conduct or convictions;

3. Is untruthful with the Government, the Court or
probation officer; or

4. Breaches this plea agreement in any way.

Cc. FURTHER ADJUSTMENTS AND SENTENCE REDUCTIONS INCLUDING THOSE
UNDER 18 U.S.C. § 3553

Defendant may request or recommend additional downward
adjustments, departures, or variances from the Sentencing Guidelines
under 18 U.S.C. § 3553. The Government will oppose any downward
adjustments, departures, or variances not set forth in Section xX,
paragraph A above.

DB, NO AGREEMENT AS TO CRIMINAL HISTORY CATEGORY

The parties have no agreement as to Defendant’s Criminal History
Category.

E. “FACTUAL BASIS” AND “RELEVANT CONDUCT” INFORMATION

The facts in the “factual basis” paragraph of this agreement are
true and may be considered as “relevant conduct” under USSG § 1B1.3 and
as the nature and circumstances of the offense under 18 U.S.C.

§ 3553(a) (1).

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PARTIES’ RECOMMENDATIONS REGARDING CUSTODY

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The Government will recommend that Defendant be sentenced to within
the advisory guideline range recommended by the Government at

sentencing.

G. SPECIAL ASSESSMENT/FINE/RESTITUTION/FORFEITURE

1. Special Assessment

The parties will jointly recommend that Defendant pay a special
assessment in the amount of $100.00 per felony count of conviction to
be paid forthwith at time of sentencing. Special assessments shall be
paid through the office of the Clerk of the District Court by bank or
cashier’s check or money order made payable to the “Clerk, United States
District Court.”
¢. Fine

The parties will not recommend imposition of a fine due to
Defendant’s limited financial prospects and because the cost of
collection, even taking into account the Inmate Responsibility Program,
likely would exceed the amounts that could reasonably be expected to be

collected.

3. Forfeiture

The attached forfeiture addendum shall govern in this case.

H. SUPERVISED RELEASE

If the Court imposes a term of supervised release, Defendant will
not seek to reduce or terminate early the term of supervised release
until Defendant has served at least 2/3 of the term of supervised
release and has fully paid and satisfied any special assessments, fine,
criminal forfeiture judgment, and restitution judgment.

XI

DEFENDANT WAIVES APPEAL AND COLLATERAL ATTACK

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Defendant waives (gives up) ali rights to appeal and to
collaterally attack every aspect of the conviction and sentence,
including any restitution and forfeiture ordered. This waiver includes,
but is not limited to, any argument that the statute of conviction or
Defendant’s prosecution is unconstitutional and any argument that the
facts of this case do not constitute the crime charged. The only
exceptions are 1) defendant may appeal a custodial sentence above the
high end of the guideline range recommended by the Government at
sentencing (if USSG § 5G1.1(b) applies, the high end of the range will
be the statutorily required mandatory minimum sentence), and 2)
defendant may collaterally attack the conviction or sentence on the
basis that defendant received ineffective assistance of counsel. If
Defendant appeals, the Government may support on appeal the sentence,
forfeiture, or restitution order actually imposed.

XII

BREACH OF THE PLEA AGREEMENT

Defendant and Defendant’s attorney know the terms of this agreement
and shall raise, before the sentencing hearing is complete, any claim
that the Government has not complied with this agreement. Otherwise,
such claims shall be deemed waived (that is, deliberately not raised
despite awareness that the claim could be raised), cannot later be made
to any court, and if later made to a court, shall constitute a breach
of this agreement.

Defendant breaches this agreement if Defendant violates or fails
to perform any obligation under this agreement. The following are non-
exhaustive examples of acts constituting a breach:

1. Failing to plead guilty pursuant to this agreement;

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2. Failing to fully accept responsibility as established in

Section X, paragraph B, above;

3. Failing to appear in court;

4. Attempting to withdraw the plea;

5. Failing to abide by any court order related to this case;
6. Appealing (which occurs if a notice of appeal is filed)

or collaterally attacking the conviction or sentence in
violation of Section XI of this plea agreement; or

7. Engaging in additional criminal conduct from the time of
arrest until the time of sentencing.

If Defendant breaches this plea agreement, Defendant will not be
able to enforce any provisions, and the Government will be relieved of
all its obligations under this plea agreement. For example, the
Government may proceed to sentencing but recommend a different sentence
than what it agreed to recommend above. Or the Government may pursue
any charges including those that were dismissed, promised to be
dismissed, or not filed as a result of this agreement (Defendant agrees
that any statute of limitations relating to such charges is tolled
indefinitely as of the date all parties have signed this agreement;
Defendant also waives any double jeopardy defense to such charges). In
addition, the Government may move to set aside Defendant’s guilty plea.
Defendant may not withdraw the guilty plea based on the Government's
pursuit of remedies for Defendant’s breach.

Additionally, if Defendant breaches this plea agreement: (i) any
statements made by Defendant, under oath, at the guilty plea hearing
{before either a Magistrate Judge or a District Judge); (ii) the factual

basis statement in Section II.B in this agreement; and (iii) any

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evidence derived from such statements, are admissible against Defendant
in any prosecution of, or any action against, Defendant. This includes
the prosecution of the charge(s) that is the subject of this plea
agreement or any charge(s) that the prosecution agreed to dismiss or
not file as part of this agreement, but later pursues because of a
breach by the Defendant. Additionally, Defendant knowingly,
voluntarily, and intelligently waives any argument that the statements
and any evidence derived from the statements should be suppressed,
cannot be used by the Government, or are inadmissible under the United
States Constitution, any statute, Rule 410 of the Federal Rules of
Evidence, Rule 11(f) of the Federal Rules of Criminal Procedure, and
any other federal rule.

CONTENTS AND MODIFICATION OF AGREEMENT

This plea agreement embodies the entire agreement between the
parties and supersedes any other agreement, written or oral. No
modification of this plea agreement shall be effective unless in writing
Signed by all parties.

XIV

DEFENDANT AND COUNSEL FULLY UNDERSTAND AGREEMENT

By signing this agreement, Defendant certifies that Defendant has
read it {or that it has been read to Defendant in Defendant’s native
language). Defendant has discussed the terms of this agreement with
defense counsel and fully understands its meaning and effect.

//

8a Ag beerie nt Def. Initials ¢ BS
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xV

DEFENDANT SATISFIED WITH COUNSEL

Defendant has consulted with counsel and is satisfied with
counsel’s representation. This is Defendant’s independent opinion, and
Defendant’s counsel did not advise Defendant about what to say in this

regard.
RANDY S. GROSSMAN
United States Attorney

DATED 7/10/2023 JESSICA ADELINE SCHULBERG
Assistant U.S. Attorney

DATED 08 Duty Ze J@SEPH THOMAS HITREC
Defense Counsel

IN ADDITION TO THE FOREGOING PROVISIONS TO WHICH I AGREE, I SWEAR UNDER
PENALTY OF PERJURY THAT THE FACTS IN THE “FACTUAL BASIS” SECTION ABOVE

ARE TRUE.
DATED OF CONSTANTIN BOBI SANDU,
CO aka Bobi Sandu,
aka Ionut Mihai,

aka Constantin Sandu,

Defendant
Approved By:
s/Michael A. Deshong
MICHAEL A. DESHONG
Assistant U.S. Attorney
17

TR Bey. agtye Def. Initials


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