Statement of Facts — No. 3:24-cr-00017 (Dkt. 13, E.D. Va.)

Summary

A Statement of Facts in United States v. Wendy Lawrence, Case No. 3:24-cr-17, in the U.S. District Court for the Eastern District of Virginia, Richmond Division, supporting a guilty plea to Count One of a Criminal Information, signed for United States Attorney Jessica D. Aber by Assistant United States Attorney Avi Panth. Lawrence, a United States Postal Service employee in Richmond, stole envelopes from the mail stream and took them to her residence in Chesterfield County; on October 18, 2022 law enforcement recovered stolen mail belonging to over 180 victims. Using stolen account details she paid personal bills, including a $10,542 electronic debit on September 27, 2022 for her rent, and forged checks of $902.04, $5,000 and $1,000. The parties stipulate reasonably foreseeable losses of between $15,000 and $40,000 for guideline purposes.

Summary drafted by a model from the document's text below 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

Full text

                       IN THE UNITED STATES DISTRICT COURT
                       FOR THE EASTERN DISTRICT OF VIRGINIA
                                  Richmond Division


 UNITED STATES OF AMERICA


 V.                                                   CaseNo.3:24-cr-17


 WENDY LAWRENCE,

                Defendant.


                                   STATEMENT OF FACTS


        The United States and the defendant, WENDY LAWRENCE (hereinafter,"the

defendant"), stipulate that the allegations contained in Count 1 ofthe Criminal Information and

the following facts are true and correct, and that had this matter gone to trial, the United States

would have proven each ofthem beyond a reasonable doubt.

        1.     At all times relevant to the Criminal Information, the defendant resided in

Richmond, Virginia, within the Eastern District of Virginia, and was an employee of the United

States Postal Service(USES).

        2.     On numerous occasions, during the course of her employment, the defendant stole

envelopes that were entrusted to her care as a USES employee while such envelopes were in the

mail stream. The defendant took such envelopes to her residence in Chesterfield County, Virginia,

within the Eastern District of Virginia.

        3.     The defendant removed various items from such envelopes, including gift cards,

checks, and other items of value, and took such items for her own use. On or about October 18,

2022,law enforcement recovered stolen mail matter in LAWRENCE'S possession at her residence,

belonging to over 180 distinct victims.


                                                  1
       4.      LAWRENCE removed certain checks from the mail matter that she stole. Using

the bank account and routing information on the checks, LAWRENCE obtained funds from the

bank accounts associated with the checks that she stole.

       5.      As an illustrative example, LAWRENCE used stolen bank account information to

initiate electronic payments for various personal expenses {e.g., paying down her own tax bill, pest

control bill, Comcast bill, and rent). For instance,on or about September 27,2022, using the means

of identification of C.W.(namely, C.W.'s name and Navy Federal Credit Union bank account

number ending in -0121) LAWRENCE initiated a $10,542 electronic debit transaction from that

bank account to pay for LAWRENCE'S rent. To do this, LAWRENCE duplicated C.W.'s name

and bank account number into another medium - the electronic payment portal for the rent

payment processor - and initiated a payment. Moreover, to make her fraud scheme more long

lasting and harder to detect, LAWRENCE further initiated a fraudulent address change request at

USPS to redirect C.W.'s mail to LAWRENCE'S own address.

       6.      As an illustrative example, on or about October 18, 2022, law enforcement

recovered various checks that LAWRENCE forged for her own benefit. At no time did

LAWRENCE have the permission to possess such checks.

                   a. LAWRENCE forged her name in the "Pay To The Order Of section of a

                      check addressed to L.A. from B&L Floorcovering, Inc. in the amount of

                      $902.04. The check was dated May 4,2022. L.A. confirmed that the check

                       was intended for L.A.'s father, and only the "Pay To The Order Of section

                      of the check had been doctored.

                   b. LAWRENCE forged her name in the "Pay to the Order of section of a

                      check from R.L. and J.L. in the amount of $5,000. The check was dated

                                                 2
                       August 8, 2022. Various other blank checks in the name of R.L. and J.L.

                       were also found in LAWRENCE'S possession with the same bank account

                       and bank routing numbers,

                   c. LAWRENCE forged her name in the "Pay to the Order Of section of a

                       check from R.D. and G.D. in the amount of $1,000. The check was dated

                       October 8,2022.

       7.      On or about October 18, 2022,enforcement recovered checks belonging to at least

thirty other individuals in LAWRENCE'S possession.

                                               4: iic iji




       8.      For the purpose of calculating the defendant's advisory range under the United

States Sentencing Guidelines, the parties stipulate that the losses to victims reasonably

foreseeable to the defendant were between $15,000 and $40,000. The defendant

acknowledges that this stipulation is not binding on the Court or the probation office, and that

she will not be permitted to withdraw her plea ifthe loss calculations ultimately adopted by the

Court at sentencing differ from this stipulation.

       9.      This statement of facts includes those facts necessary to support the defendant's

guilty plea to Count One of the Criminal Information. It does not include each and every fact

known to the defendant or to the United States, and it is not intended to be a full enumeration of

all ofthe facts surrounding the defendant's case.
       10.    The actions of the defendant, as recounted above, were in all respects knowing and

deliberate, and were not committed by mistake, accident, or other innocent reason.


                                                Respectfully submitted,

                                                Jessica D. Aber
                                                United States Attorney


                                        By;
                                                Avi Panth
                                                Assistant United States Attorney
       I have consulted with my attorney regarding this Statement of Facts. I knowingly and

voluntarily agree that each of the above-recited facts is true and correct and that had this matter

gone to trial the United States could have proven each one beyond a reasonable doubt.


 s- r'' aH
Date                                             WENDY LAWRENCE
                                                 Defendant




       I am counsel for defendant, WENDY LAWRENCE, I have carefully reviewed this

Statement of Facts with him and, to my knowledge, his decision to agree to this Statement of Facts

is an informed and voluntary decision.



Date                                               «eph Camden
                                                 Counsel


File and source

File

13.pdf

Size

384,366 bytes

SHA-256

b8e43e35f1ffe8b08f53384ab5c4ce79695b45911c8af6b15ac73f204863bcb7

Our copy

13.pdf

Original

No public link identified.