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United States v. Rita Shaba — Plea Agreement, Eastern District of Michigan (ECF No. 65)

Summary

A plea agreement between the United States and Rita Shaba, Case No. 23-CR-20296, filed August 26, 2025 as ECF No. 65 in the U.S. District Court for the Eastern District of Michigan before Hon. Jonathan J.C. Grey. Rita Shaba agrees to plead guilty to Count 1 of the Indictment, conspiracy to commit wire fraud and bank fraud under 18 U.S.C. § 1349, which carries up to 30 years' imprisonment, and the government will move to dismiss any remaining charges. In the factual basis the defendant admits conspiring with others, including Samer Kammo, from about April 2020 through December 2020 to obtain Paycheck Protection Program loans with false applications and fictitious records, and obtaining additional PPP loans in her own name. The parties recommend guideline provisions including an actual loss of $1.5 Million-$3.5 Million, and there is no agreement on restitution.

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

“United States v. Rita Shaba — Plea Agreement, Eastern District of Michigan (ECF No. 65).” Original at ecf.mied.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/plea-agreement-usa-v-shaba-et-al-dkt-65-e-d-mich-e13ed20a14/, SHA-256 8291fd9bb67f6cb3b13eeb4784d97ca6572eade415d89486e3f2856a6c867730.

Full text

Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.394 Filed 08/26/25 Page 1 of 25




                           United States District Court
                           Eastern District of Michigan
                                Southern Division

   United States of America,

              Plaintiff,
                                           Case No. 23-CR-20296
   V.
                                           Hon. Jonathan J.C. Grey
   D-1 Rita Shaba,

              Defendant.
                                       I

                               Plea Agreement
        The United States of America and the defendant, Rita Shaba, have

  reached a plea agreement under Federal Rule of Criminal Procedure 11.

  The plea agreement's terms are:

  1.    Count of Conviction

        The defendant will plead guilty to Count 1 of the Indictment. Count

  1 charges the defendant with Conspiracy to Commit Wire Fraud and

  Bank Fraud under 18 U.S .C § 1349.

  2.    Statutory Maximum Penalties

        The defendant understands that the count to which she is pleading

  guilty carries the following maximum statutory penalties:



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   Count 1       Term of imprisonment:           Up to 30 Years '
                                                 Imprisonment
                 Fine:                           Up to $1,000,000 or twice
                                                 the pecuniary gain or loss;
                                                 18 U.S.C. § 3571(d)
                 Term of supervised release:     Up to 5 years


  3.      Agreement to Dismiss Remaining Charges

          If the Court accepts this agreement and imposes sentence

  consistent with its terms, the United States Attorney's Office for the

  Eastern District of Michigan will move to dismiss any remaining charges

  in the indictment (ECF No. 1) against the defendant, Rita Shaba, in this

  case.

  4.      Elements of Count of Conviction

          The elements of Count 1 (Conspiracy to Commit Wire Fraud and

  Bank Fraud) are:

               (l)First, that or more persons conspired, or agreed, to commit
                  the crime of wire fraud, in violation of 18 U.S.C. § 1343,
                  and the crime of bank fraud, in violation of 18 U.S.C.
                  § 1344(2); and

               (2)Second, that the defendant knowingly and voluntarily
                  joined the conspiracy.

          The elements of the crime of wire fraud, in violation of 18 U.S.C.

  § 1343, are:


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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.396 Filed 08/26/25 Page 3 of 25




             (l)First, that the defendant knowingly participated in,
                devised, or intended to devise, a scheme to defraud in order
                to deprive another of money or property;

             (2)Second, that the scheme included a material
                misrepresentation or concealment of a material fact;

             (3)Third, that the defendant had the intent to defraud; and

             (4)Fourth, that the defendant used wire , radio or television
                communications or caused another to use wire , radio or
                television communications in interstate commerce in
                furtherance of the scheme.

        The elements of the crime of bank fraud, in violation of 18 U.S.C.

  § 1344(2), are:

             (l)First, that the defendant knowingly executed or attempted
                to execute a scheme to obtain any of the money, funds, or
                property owned by, or under the control of, a bank or
                financial institution by means of false or fraudulent
                pretenses, representations or promises;

              (2) Second, that the scheme included a material
                  misrepresentation or concealment of a material fact;

              (3)Third, that the defendant had the intent to deceive or cheat
                 someone for the purpose of either causing a financial loss
                 to another or bringing about a financial gain to herself or
                 to another person; and

              (4)Fourth, that the bank or financial institution was federally
                 insured.




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  5.    Factual Basis

        The parties agree that the following facts are true , accurately

  describe the defendant's role in the offense, and provide a sufficient

  factual basis for the defendant's guilty plea:

        From at least in or around April 2020, through at least in or around

  December 2020, in the Eastern District of Michigan and elsewhere, RITA

  SHABA conspired and agreed with others, including SAMER KAMMO

  and CHRISTINA ANASI, to commit the crime of wire fraud , in violation

  of 18 U.S.C. § 1343, and the crime of bank fraud, in violation of 18 U.S.C.

  § 1344(2). SHABA knowingly and voluntarily joined the conspiracy.

        The object of the conspiracy was for SHABA and her co-conspirators

  to obtain money and enrich themselves by, among other things, inducing

  federally insured financial institutions and other third-party lenders,

  through materially false and fraudulent representations and pretenses,

  to issue improper Paycheck Protection Program ("PPP") loans and then

  divert those loan proceeds to impermissible uses.

        As part of the conspiracy, the co-conspirators caused materially

  false and fraudulent representations to be made to federally insured

  financial institutions and other third-party lenders, including materially


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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.398 Filed 08/26/25 Page 5 of 25




  false    and fraudulent     representations     relating to the   purported

  entitlement of various business entities to PPP loan assistance. PPP loan

  assistance funds issued because of the materially false and fraudulent

  representations were then received by the conspirators and used for

  impermissible purposes.

          As part of the conspiracy, the co-conspirators caused:

            a. Misrepresentations to be made regarding purported payroll

               expenditures by various business entities;

            b. Misrepresentations to be made regarding the purported

               number of employees of various business entities;

            c. Misrepresentations to be made regarding the purported

               nature of business activity for various business entities;

             d. Misrepresentations to be made regarding the purported

               purpose of PPP loan requests for various business entities;

             e. False certifications to be made indicating that PPP loan

               proceeds would only be used for permissible business-related

               purposes;




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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.399 Filed 08/26/25 Page 6 of 25




          f. False certifications to be made indicating that various non-

               operational business entities were operational and that those

               entities paid employee salaries;

          g. Fictitious payroll records to be created and submitted to

               financial institutions and other third-party lenders;

          h. Fictitious health insurance records to be created and

               submitted to federally insured financial institutions and other

               third-party lenders;

          1.   Fictious bank records to be created and submitted to financial

               institutions and other third-party lenders; and

          J. Fictitious tax records to be created and submitted to financial

               institutions and other third-party lenders.

        SHABA acknowledges that as part of the conspiracy, she personally

  submitted PPP loan applications knowing the applications were

  fraudulent and also generated fictious records for submission in

  connection with fraudulent PPP loan applications. SHABA also

  acknowledges      that   she   worked   with    co-conspirators,     including

  CHRISTINA ANASI , to generate fictious records for submission as part

  of fraudulent PPP loan applications.


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        SHABA acknowledges causing the transfer of fraudulent PPP loan

  proceeds into bank accounts controlled by the co-conspirators knowing

  both that those proceeds were fraudulently obtained and that the

  proceeds would not be used for permissible purposes.

        In furtherance of the conspiracy, the co-conspirators caused

  interstate wire transfers to be made, including interstate wire transfers

  of PPP assistance funds.

  6.    Relevant Conduct

        SHABA acknowledges that in addition to participating in the

  conspiracy detailed above, she also fraudulently obtained additional PPP

  loans in her own name. SHABA acknowledges that this conduct is

  relevant to her offense of conviction under U.S.S.G. § lBl.3.

  7.    Advice of Rights

        The defendant has read the Indictment, has discussed the charges

  and possible defenses with her attorney, and understands the crime(s)

  charged. The defendant understands that, by pleading guilty, she is

  waiving many important rights, including the following:

        A.   The right to plead not guilty and to persist in that plea;

        B.   The right to a speedy and public trial by jury;



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        C.       The right to be represented by counsel-and, if necessary,

        have the court appoint counsel-at trial;

        D.       The right to be presumed innocent and to require the

        government to prove the defendant guilty beyond a reasonable

        doubt at trial;

        E.       The right to confront and cross-examine adverse witnesses at

        trial;

        F.       The right to testify or not to testify at trial, whichever the

        defendant chooses;

        G.       If the defendant chooses not to testify at trial, the right to

        have the jury informed that it may not treat that choice as evidence

        of guilt;

        H.       The right to present evidence or not to present evidence at

        trial, whichever the defendant chooses; and

        I.       The right to compel the attendance of witnesses at trial.

  8.    Collateral Consequences of Conviction

        The defendant understands that her conviction here may carry

  additional consequences under federal or state law. The defendant

  understands that, if she is not a United States citizen, her conviction here


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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.402 Filed 08/26/25 Page 9 of 25




  may require him to be removed from the United States, denied

  citizenship, and denied admission to the United States in the future. The

  defendant further understands that the additional consequences of her

  conviction here may include, but are not limited to, adverse effects on the

  defendant's immigration status, naturalized citizenship, right to vote ,

  right to carry a firearm , right to serve on a jury, and ability to hold certain

  licenses or to be employed in certain fields. The defendant understands

  that no one, including the defendant's attorney or the Court, can predict

  to a certainty what the additional consequences of the defendant's

  conviction might be. The defendant nevertheless affirms that the

  defendant chooses to plead guilty regardless of any immigration or other

  consequences from her conviction.

  9.    Defendant's Guideline Range

        A.      Court's Determination

        The Court will determine the defendant's guideline range at

  sentencing.

        B.    Acceptance of Responsibility

        The government recommends under Federal Rule of Criminal

  Procedure l l(c)(l)(B) that the defendant receive a two-level reduction for


                                   Page 9 of 25
Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.403 Filed 08/26/25 Page 10 of 25




   acceptance of responsibility under USSG § 3El. l(a) Further, if the

   defendant's offense level is 16 or greater and the defendant is awarded

   the two-level reduction under USSG § 3El.l(a), the government

   recommends that the defendant receive an additional one-level reduction

   for acceptance of responsibility under USSG § 3El.l(b). If, however, the

   government learns that the defendant has engaged in any conduct

   inconsistent with acceptance of responsibility-including, but not limited

   to, making any false statement to, or withholding information from , her

   probation officer; obstructing justice in any way; denying her guilt on the

   offense(s) to which she is pleading guilty; committing additional crimes

   after pleading guilty; or otherwise demonstrating a lack of acceptance of

   responsibility as defined in USSG § 3E 1.1-the government will be

   released from its obligations under this paragraph, will be free to argue

   that the defendant not receive any reduction for acceptance of

   responsibility under USSG § 3El.1 , and will be free to argue that the

   defendant receive an enhancement for obstruction of justice under USSG

   § 3Cl.1.




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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.404 Filed 08/26/25 Page 11 of 25




        C.     Other Guideline Recommendations

        The parties also recommend under Federal Rule of Criminal

   Procedure 1 l(c)(l)(B) that the following guideline provisions apply:

             Guideline Section                     Offense Level

    Base Offense Level: § 2Bl.l(a)(l)                     7

             Actual Loss of                              +16
        $1.5 Million-$3.5 Million:
             & 2B 1.1 (b )(l)(I)
          Sophisticated Means:                           +2
            § 2B 1.1 (b )(1 0)(C)
     Zero-Point Offender:§ 4Cl.l(a)                       -2


        The parties have no other joint recommendations as to the

   defendant's guideline calculation.

        E.     Parties' Obligations

        Both the defendant and the government agree not to take any

   position or make any statement that is inconsistent with any of the

   guideline recommendations or factual stipulations in paragraphs 9.B or

   9.C. Neither party is otherwise restricted in what it may argue or present

   to the Court as to the defendant's guideline calculation.




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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.405 Filed 08/26/25 Page 12 of 25




         F.   Not a Basis to Withdraw

         The defendant understands that she will have no right to withdraw

  from this agreement or withdraw her guilty plea if she disagrees, in any

  way, with the guideline range determined by the Court, even if that

  guideline range does not incorporate the parties' recommendations or

  factual stipulations in paragraphs 9.B or 9.C. The government likewise

  has no right to withdraw from this agreement if it disagrees with the

  guideline range determined by the Court.

   10.   Imposition of Sentence

         A.   Court's Obligation

         The defendant understands that in determining her sentence, the

   Court must calculate the applicable guideline range at sentencing and

  must consider that range, any possible departures under the sentencing

  guidelines, and the sentencing factors listed in 18 U.S.C. § 3553(a), and

  apply any applicable mandatory minimums.

         B.   Imprisonment

              1.   Recommendation

         Under Federal Rule of Criminal Procedure 1 l(c)(l)(B), the

  government recommends that the defendant's sentence of imprisonment



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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.406 Filed 08/26/25 Page 13 of 25




  not exceed the top of the defendant's guideline range as determined by

  the Court.

               2.   No Right to Withdraw

        The government's recommendation 1n paragraph 10.B. l is not

  binding on the Court. The defendant understands that she will have no

   right to withdraw from this agreement or withdraw her guilty plea if the

   Court decides not to follow the government's recommendation. The

   government likewise has no right to withdraw from this agreement if the

   Court decides not to follow the government's recommendation. If,

   however, the Court rejects or purports to reject any other term or terms

   of this plea agreement, the government will be permitted to withdraw

   from the agreement.

        C.     Supervised Release

               1.   Recommendation

        The parties have no agreement as to supervised release.

               2.   No Right to Withdraw

        Any recommendation regarding the imposition of a term of

   supervised release made by either party is not binding on the Court. The

   defendant understands that she will have no right to withdraw from this


                                 Page 13 of 25
Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.407 Filed 08/26/25 Page 14 of 25




   agreement or withdraw her guilty plea if the Court decides not to follow

   the recommendation of either party.

        D.    Fines

        The parties have no recommendation or agreement as to a fine.

        E.    Restitution

        Notwithstanding     the   offense   of conviction,   the   defendant

   understands the Court must order restitution to every identifiable victim

   of the defendant's scheme. There is no recommendation or agreement on

   restitution. The Court will determine at sentencing who the victims are

   and the amounts of restitution they are owed.

        The defendant agrees that restitution 1s due and payable

   immediately after the judgment is entered and is subject to immediate

   enforcement, in full , by the United States. 18 U.S.C. §§ 3612(c) and 3613.

   If the Court imposes a schedule of payments, the defendant agrees that

   the schedule of payments is a schedule of the minimum payment due,

   and that the payment schedule does not prohibit or limit the methods by

   which the United States may immediately enforce the judgment in full.

        The defendant agrees to make a full presentence disclosure of her

   financial status to the United States Attorney's Office by completing a


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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.408 Filed 08/26/25 Page 15 of 25




   Financial Disclosure Form and the accompanying releases for the

   purpose of determining her ability to pay restitution. The defendant

   agrees to complete and return the Financial Disclosure Form within

   three weeks of receiving it from government counsel. The defendant

   agrees to participate in a presentencing debtor's examination if requested

   to do so by government counsel.

        F.    Forfeiture

        The defendant agrees, pursuant to Fed. R. Crim. P. 32.2., 18 U.S.C.

   § 981(a)(l)(C) with 28 U.S.C. § 2461(c), to forfeit to the United States any

   and all property, real or personal, which constitutes or is derived from

   proceeds traceable to the defendant's violation of 18 U.S.C. § 1349, as

   charged in the Indictment, including but not limited to the following:

                Descriotion                              CATS

         1.     $8,900.00 U.S. Currency          21-CBP-
                                                 000095
         2.     $761,414.32 ln funds from Bank 21-FBI-
                Account Number 761261221 held in 001467
                the name of Rita A. Shaba at
                JPMorgan Chase Bank, Clinton
                Township, MI

         3.     $74,367.15 ln funds from Bank 21-FBI-
                Account Number 517597115 held in 001547
                the name of Forever Beauty, LLC at


                                 Page 15 of 25
Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.409 Filed 08/26/25 Page 16 of 25




                Description                             CATS

                JPMorgan Chase       Bank,    Clinton
                Township, MI

         4.     $50,247.23 In funds from Bank           21-FBI-
                Account Number 0080543967 in the        001548
                name of Rita A. Shaba at Michigan
                Schools and Government Credit
                Union, Clinton Township, MI
         5.     $9,835.58 In funds from Bank            21-FBI-
                Account Number 517597115 held in        004468
                the name of Forever Beauty, LLC at
                JPMorgan Chase Bank, Clinton
                Township, MI

         6.     $498,027.99 In funds from Bank 21-FBI-
                Account Number 1852899267 in the 001039
                name of C&S Detroit Property LLC
                and/or   Samer     Kammo     and/or
                Christina Anasi at Comerica Bank in
                Macomb, MI

         7.     $205,898.76 In funds from Bank 21-FBI-
                Account Number 1852899259 held in 001040
                the name of C & S Liquor and/or
                Samer Kammo and/or Christina
                Anasi at Comerica Bank, Macomb,
                MI

         8.     $55,000.00 In funds from Bank 21-FBI-
                Account Number 6826004936 held in 002551
                the name of Christina Anasi, in trust
                for Samer Kammo at Comerica Bank,
                Macomb, MI




                                 Page 16 of 25
Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.410 Filed 08/26/25 Page 17 of 25




               Description                              CATS

         9.    $125,500.00 1n funds from Bank 21-FBI-
               Account No. 9417715175 in the name 002566
               of Christina Anasi, in trust for Samer
               Kammo at Comerica Bank 1n
               Macomb, MI



         10.    $53,083.08 in funds from Account No. 21-FBI-
                200999370 in the name of Anasi 002677
                Detroit Property, LLC at JPMorgan
                Chase in Clinton Township, MI

         11.    $67,029.74 1n funds from Bank 20-FBI-
                Account Number 842340622 in the 006526
                name of Slewai S. Allos at JP Morgan
                Chase, Troy, MI; and

         12.    $201,656.48 1n funds from Bank 21-FBI-
                Account Number 1853452405 held in 002284
                the name of W Shallal LLC DBA
                Mound Express at Comerica Bank,
                Macomb, MI

   (the "Subject Property").

        In entering into this agreement, defendant hereby withdraws any

   and all prior claims filed with the FBI, the United States Attorney's

   Office, or the Court, concerning the forfeiture of the Subject Property, or

   any other property filed on or about January 28, 2025, and agrees not to




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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.411 Filed 08/26/25 Page 18 of 25




  contest the forfeiture of any of the Subject Property in any proceeding,

  whether administrative or judicial.

        The defendant agrees to the entry of one or more orders of

  forfeiture , including a Preliminary Order of Forfeiture, containing the

   above referenced forfeiture , upon application by the United States at, or

   any time before, her sentencing in this case . The defendant agrees to sign

   such an order, indicating she consents to its entry if requested to do so by

   the government. The defendant agrees that the forfeiture order will be

  final and effective as to her upon entry by the Court.

        The defendant will cooperate with in the government as requested

  by the government in connection with the government's efforts to

  identify, locate , seize, and forfeit property that is subject to forfeiture

   under this agreement. The defendant agrees that she will cooperate with

   the United States by taking whatever steps are necessary to deliver

   possession of, and clear title to, property that is forfeitable to the United

   States under this agreement and will execute such legal documents as

   may be required to transfer title to the United States and by taking

  whatever steps are necessary to ensure that the property is not sold,

   disbursed, hidden, wasted or otherwise made unavailable for forfeiture.


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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.412 Filed 08/26/25 Page 19 of 25




   If any other person or entity has any interest in such property, the

   defendant will provide the government with the name and address of the

   person or entity that has an interest in, and/or possession of, the asset,

   and assist the government in obtaining a release of interest from any

   such other person or entity.

        The defendant waives her right to have a jury determine the

   forfeitability of her interest in the Subject Property as provided by Fed.

   R. Crim. P. 32.2(b)(5).

        The defendant waives the requirements of Fed. R. Crim. P. 32.2 and

   43(a) regarding notice of the forfeiture in the charging instrument,

   pronouncement of the forfeiture at sentencing, and incorporation of the

   forfeiture in the judgment. The defendant acknowledges that she

   understands that the forfeiture of property is part of the sentence that

   may be imposed in this case and waives any failure by the Court to advise

   her of this, pursuant to Fed. R. Crim. P. ll(b)(l)(J), at the time her guilty

   plea is accepted.

        The defendant agrees to hold the United States, its agents and

   employees harmless from any claims whatsoever in connection with the

   seizure and/or forfeiture of property covered by this Plea Agreement.


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         The defendant knowingly, voluntarily, and intelligently waives any

   statutory and constitutional challenge to the above-described forfeiture

   including any challenge based upon the Excessive Fines Clause of the

   Eighth Amendment to the United States Constitution.

         G.     Special Assessment

         The defendant understands that she will be required to pay a

   special assessment of $100, due immediately upon sentencing.

   11.   Appeal Waiver

         The defendant waives any right she may have to appeal her

   conviction on any grounds. The defendant also waives any right she may

   have to appeal her sentence on any grounds, unless her sentence of

   imprisonment exceeds the top of the guideline range as determined by

   the Court.

   12.   Collateral Review Waiver

         The defendant retains the right to raise claims alleging ineffective

   assistance of counsel or prosecutorial misconduct, as long as the

   defendant properly raises those claims by collateral review under 28

   U.S.C. § 2255. The defendant also retains the right to pursue any relief

   permitted under 18 U.S.C. § 3582(c), as long as the defendant properly


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   files a motion under that section. The defendant, however, waives any

   other right she may have to challenge her conviction or sentence by

   collateral review, including, but not limited to, any right she may have to

   challenge her conviction or sentence on any grounds under 28 U .S .C.

   § 2255 (except for properly raised ineffective assistance of counsel or

   prosecutorial misconduct claims, as described above), 28 U.S.C . § 2241 ,

   or Federal Rule of Civil Procedure 59 or 60.

   13.   Remedies for Withdrawal, Breach, Rejection, or Vacatur

         If the defendant is allowed to withdraw her guilty plea or breaches

   this agreement, or if the Court rejects this agreement, or if the

   defendant's conviction or sentence under this agreement is vacated, the

   government may reinstate any charges against the defendant that were

   dismissed as part of this agreement and may file additional charges

   against the defendant relating, directly or indirectly, to any of the

   conduct underlying the defendant's guilty plea or any relevant conduct.

   If the defendant has been permitted to plead guilty to a lesser-included

   offense, the government may also reinstate any charges or file any

   additional charges against the defendant for the greater offense, and the

   defendant waives her double-jeopardy rights with respect to the greater


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   offense. If the government reinstates any charges or files any additional

   charges as permitted by this paragraph, the defendant waives her right

   to challenge those charges on the ground that they were not filed in a

   timely manner, including any claim that they were filed after the

   limitations period expired.

   14.   Use ofWithdrawn Guilty Plea

         The defendant agrees that if she is permitted to withdraw her guilty

   plea for any reason, she waives all of her rights under Federal Rule of

   Evidence 410, and the government may use her guilty plea, any

   statement that the defendant made at her guilty plea hearing, and the

   factual basis set forth in this agreement, against the defendant in any

   proceeding.

   15.   Parties to Plea Agreement

         This agreement does not bind any government agency except the

   United States Attorney's Office for the Eastern District of Michigan.

   16.   Scope of Plea Agreement

         This plea agreement is the complete agreement between the parties

   and supersedes any other promises, representations, understandings, or

   agreements between the parties concerning the subject matter of this


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   agreement that were made at any time before the guilty plea is entered

   in court. Thus, no oral or written promises made by the government to

   the defendant or to the attorney for the defendant at any time before the

   defendant pleads guilty are binding except to the extent they have been

   explicitly incorporated into this plea agreement. If the parties have

   entered, or subsequently enter, into a written proffer or cooperation

   agreement, though, this plea agreement does not supersede or abrogate

   the terms of that agreement. This plea agreement also does not prevent

   any civil or administrative actions against the defendant, or any

   forfeiture claim against any property, by the United States or any other

   party.




                                 Page 23 of 25
Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.417 Filed 08/26/25 Page 24 of 25




  17.   Acceptance of Agreement by Defendant

        This plea offer expires unless it has been received, fully signed, in

  the United States Attorney's Office by 5:00pm on August 18, 2025. The

  government may withdraw from this agreement at any time before the

  defendant pleads guilty.



                                          JEROME F . GORGON JR.
                                          United States Attorney




   John K. Neal                           Andrew J. Y ahkind
   Chief, Anti-Corruption Unit            Assistant United States
   Assistant United States                Attorney
   Attorney


  Dated: 8/1/25




                                 Page 24 of 25
Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.418 Filed 08/26/25 Page 25 of 25


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