Plea — No. 1:22-cr-00335 (Dkt. 6, D. Md.)

Summary

The plea agreement letter of July 22, 2022 from the United States Attorney's Office for the District of Maryland to Richard B. Bardos, counsel for Medard Ulysse, in United States v. Medard Ulysse, Criminal No. RDB-21-54, filed September 23, 2022 as Document 6 in No. 1:22-cr-00335. Ulysse agrees to plead guilty to Count One of the Indictment, conspiracy to commit mail fraud under 18 U.S.C. § 1349, and to a separate information charging wire fraud under 18 U.S.C § 1343, each carrying a maximum of 20 years. The parties stipulate a loss between $1,500,000 and $3,500,000 for the conspiracy and an anticipated total adjusted offense level of 27, 28, or 29. The attached statement of facts describes unemployment claims in the names of identity theft victims and states that the scheme resulted in at least $618,767 in fraudulent unemployment benefits.

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