Case 8:22-cr-00034-SDM-AEP Document 32 Filed 04/21/22 Page 1 of 19 PageID 88

AFApprovdl&LtJ CWetesprovat[f
I,'NITED STATES DIS'I'R]CT C'OURT
MIDDLE DISTRICT OF FLORIDA
TA.IUPADIVISION

T]NTTED STATtsS OF AMERICA

v. CASENO. S:22<-3,&SDM-AEp

ROT"dNDAWINGEIELI)

.P-[IAAGn-EX[[EI{'r
Pursuant to Fod. R. Cim. P. 1l(c), thc Unid Starcs of Amcrica, by Roggr B.

Handbeu, UaiEd Stat6 Amrnq' br thc Middle District of Florida, and thc

dcftndart, Rotanda Wingfcld, aod ttc amomey fDrthc dcfurdant, Iirhrk J. O,Brbn,

muutdly rgrce rs fullows:

A- PrrticnlrircdTm
l. Coqnts Pleading To
The defradant shall rrrta a plea of guilty to Cours Ooe and Four of
thc Indicanem. Count Oac chatges the de&ndant with access device ftaud.trafic in

and use, in violation of lt U.S.C. $ 1029(aX2), aad Count Four chargies tbc

&ftodant rvirt aggravated identity Oreft, in violation of 18 U.S.C. $ 1028A.

2. Maximum Peoaltieg

Counrt Oac caries a maximum scntcace of l0 yeErs' imprisoament, a

fmc of t250,000, a term of supervised release of not molr ttun 3 pars, aod a special

assessrnem of$100.

l)efttrdant's lnitials tu
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Couat Four is punishable by a rnen{216ry minimrrm term of

imprisonment of 2 yeats that must run consecutive to Coutrt One, a fine of $250,000,

not morE rhrn a teirm of supervised release of I year, aod a special assessmeat of

$100. V/ith respect to cerain offetrses, the Court shall order the defendatrt b make

restitution to auy victim of the ofens{s), aad with respect to other oftnses, the

Court may order the defendant to maLe restitution to any victim of the otrense(s), or

to the community, as set fortt below.

3. Elements of the Offeose(s)

The deftndaot achowledges understauding tbe nature and elemeas of

the oftase(s) with which defeadant has beeu charged and to which deftodaot is

pleadiag guilty. The elemens of Count One and Four are:

Count One Elements:

EtsI the dcfendant howiagly used or tramc&ed in one or more

unauthorized access devies;

Second: the deftndang during a l}month period, obtained a thing

6l things of value totaling $1,000 or more as a result of
such use ofor ftafEcking in unauthorized accrss devices;

Third: the deftodant acted with the intent o de&aud or dcoeive;

and

Fourth: the deftodant's conduct aftcted ht€rstate or foreign

commeroe.

Count Four Elemeats:

Deftodant's lD.itials &L 2

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First: the defendant knowingly transferred, possessed, or used

another person's meaDs of identification or idetrtification
document;

Second: the defendant did so without lawfirl authority; and

Third: &e deftodaot did so during and in relation to access

dcvie fraud a aulifyingpedicae oftnse.

4. Counts Dismissed

At the time of seumcing; the reinaining couats a8ainst thg deftndatrt,

Count T\wo, Three and Five, will be dismissed pnusuant to Fed. R Crim. P.
ll(cXlXA).
5. No Further Chargrxr

If the Court aqts this plea agreemeng the Udted StaB Attorads
Office for the Middle District of Florida agr€cs trot to charge d€fE datrt with

committing aay othcr ftderal criminal oftnses Lnown to the Unitcd States

Anorne/s Offie at the time of the executiol 9f thir atrteoeot, related to the

conduct givitrg rise to this plea agre€metrt.

6. Mandatory Restitutioa to Victim of Oftnse of Convictioa

Pursuatrt to tt U.S.C. g 3663A(a) aad @), deftadaut agrees to Eate tull

restitution of $67,178.00to the Arizoua Deparmeot of Economic Securitr;

$55,800.00 to the Califoraia Employment Developm.entD€partueaq $10,(86.00 to

the Nevada Deparmeat of Employment Training and Rehahilitation; and $2,502.00

to the [,ouisiana Worldoroe Commission.

Deftndant's Initials Irf 3

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7. Guidclines Sentence

Pursuatrt to Fed. R. Qim. P. ll(cXlXB), the Unied Stares wil

rccommend to the Court that the deftndant be seoteoed within the deftndaat's

applicable guidclines range as dcterahedby tte Courtpuruant to the UdEd StaEs

Sea5cing Guidelings, as adjusted by any departure the UEiEd States has agreed to

recommend ia this plea agreement. The panies -nderstaud that such a

recommeodation is not biading on the Court aud thag if it is not acoepted by tLis

Court, neitter tte Utrited Stat6 nor the de&ndant will be allowed to withdraw from

the plea aSteemeot, and the de&odant will not be allowed to withdraw from the plea

of Sdlty.

E. Acceptanoe of Rcsponsibilig - Three Levels

At the time of seoternciug, aad in the event that no adverse information

is reoeirad suggestint such a recommendatiotr to bc utrwarraate4 the United States

will aot oppose the defendant's rcquest to the Court that the deftndant rreceive a two-

level downward adjustmeot for aoqtance of responsibitty, pursuaut to USSG

$ 3El.l(a). The de&ndant undsstands that \is tEcormmcndation or request is trot

biading on the Court, and if not accepted by fte Court, the defendant will not be

allowed to withdraw from the plea.

Furtter, at the time of setrtenong, if the dcftudaafs oftnse level prior

to operation ofsubsedion (a) is level 16 or greater, and ifthe defeudant complies

with the provisions of USSG g 3El.t(b) and all terms of this plea Agrcemeo!
including but aot limited to, the timely submission of the financial afrdavit

Deftudrnt's Initiats lrl 4

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refereoccd in Paragraph B,5., the United States agrees to file a motioo pursuant to

USSG $ 38I.1@) for a downunard adjw eot of one additional leyel, The deftadaat

understands ttat the determiaatiotr as to whcther the deftrdrnt has quatified for a

downward adjusment of a third lwel for accepauce of responsihility rests solely

with the Unircd States Afiomry for tte Middle District of Florida, and tte deftadant

agrees that the deftodaot caonol ilr! qdtl asl chrllenge that dEErminatiou, whether

by appal, colateral attadq or otherrdse.

9. Cooperation - Substantial Assistance to be Considered

hdant agrces to cooperate fully with ttre United Sates in the

investigatioa aud prrosecution ofother persoas, aEd to testiry, subject to a proseantion

for perjury onnaLi'rg a false staement, fully and truttfully before any ftderal court

proceediag or federal gratrd jury h connertion with tte darges in this case aad other

matten, such cooperation to furtter include a ftrll and comptete disdosure of alt

releyant information, iududing production of any and all bools, tnpefs, docunretrB,

and other objectr in defeodanfs posseslrion or coatrol, end to be reasoaably available

for iuerviews which the unircd states Eay require. If the cooperation is completed

prior to senteacing, the govemmeut agrer to consider whefrer such cooperation

qualiEes as nsubstantial assistane" in acordaoe with the policy of the unircd states
Attomey for the Middle District of Florida, warraating the firing orf a motion at tte
time of searcnciag reommendiag (l) a downward departure from the applicable

guidelirc range punruaat to ussc gsKl.l, or (2) the imposition of a sentence below

a stitutory minimum, if any, pursuant to lg U.S.C. $ 3553(e), or (3) both. If the

Defendant,s Initiats &I 5

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cooperatiotr is completed subsequent to seatench& the goverameot agr€es to

oonsider whether such ooperation qualifies as 'substantid assistarce" in acordaace

with the policy of the United Stat€s Attomcy for the Middlc District of Florida,

warraating the filing of a motion for a reduction of seateoce within one year of the

iapositioa of senteae pursrrant to Fed. R. Crim. P. 35(b). In any case, 6e

d€fead,nt undcrstaJds &at the deEmination as to wbether "substaatial assistane"

has been providcd or what tlpe of motion relaEd frereb will be filed, if any, resB

solely with the Unied Stat6 Attomry for the Middlc District of Florida, aod the

dcftodaat agrees that defendant cannot arld will trot ctralleage that detetrminatiotr,

whether by appeat ollaud attadg or otherwise .

10. Cooperation - Responsibilities of Parties

a. The goveimmeat will make known to the Court and other

relerrant authorities the nature aud exteot ofdcftndanfs cooperatioa and any other

mitigating circnmstances indicative of the deftodaafs rehabiliative iatent by

s5suming the fundamentel siyis duty of rcporting crime. However, the dcftadant

understands that the govemoent can make uo represeatation that the Court wil
impose a lesser setrteoce solely oa account o[, or ia coasideration of, zuch

coop€ratiotr.

b. It is understood ttat should the deftadaut ktrowingty provide

incomplete or utrtruthful tstimoay, statemeots, or infrrmation pursrt,?tt to rhis

agneement' or should the deftudant falsely implicate or incrimiaate any penroD, or

shouldthe deftndant fail to voluntarily and unresenredly disclose and provide full,

Defeu.lant's Initials 6
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clmplet€, tnrtbful, atrd hooest loowledge, information, and cooperation regnrdiqg

any of the matters noted herein, the following conditioas shall apply:

(l) The deftod.nt may be posecuted for aay perjury or false

declarations, if aay, comrnittcd wbile testirying punuant to this agreemen! or for

obstnrction of justice.

(2) The Udtrd States may prcsecutc the deftndant for the

charges which arr to be dismisscd pursuant to this ageement, if any, and may either

scek rcinstatement of or redle sucl charges aad gosecute the defeodaat thercon in

the event such cbarges have been dismissed Frrcuant to this agreement. With regard

to such ctaryts, if aay, which have beea dismissed" the deftodant, being firlly aware

of the nature of all suctr charges now peading in the insant case, and beiag further

aware of defendalt's righB, as to all ftlouy charges peading in such cases (those

oftnscs prnichabls by imprrisonmcnt for a term of over oae year), to not be held to

atrswer to said ftlony charges unless on a p'reseatuent or indicUent of a graad jury,

and further being aware that all such ftlony charges in the instant case have

heretofore properly been returncd by the indicrment ofa grandjury, does hereby

agr€e to rcinstatement of such charges by recision of any oder dismiscing them or,

altematively, does hereby waive, in opeo court, pros€cution by indicrmeot and

consenB that the united states may proceed by information instead of by indicmeat

with rcgard to any felony charges which may be dismissed in the instaat case,

pursuant to this plea agreement, and the deftudatrt further agrces to waive the statute

of limitations and any speedy gi2t claims s1 sgch charges.

P.6"1a"nys Initials
fur 7
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(3) The United States may prosecute the dcftadant for any

oftnses set forth herein, if any, the prosecution of which ia accordance with this

agr€em€nt, the United States agrees to forego, and the deftndaat agrecs to waive tte
statuE of limitations aod aay speedy trial daims as to any su& ofeoses.

(4) The govemment may use a8ain*t the dc&ndant the

dcfudanfs su,a rdmissiens atrd statcments aad the information and bools, papers,

documents, and object that tte dcfeodart has firtoished ia the coursc of the

dcftndanfs cooperation with the govenrmeat.

(5) The dcftudantwill notbe permitted to withdraw the guilty

pleas to those counts to which deftadaat hereby agrees to plead in the iastant case

but, in tlat ev€ot, drfeodaot wil bc entitled to the sentencing limiations, if any, set

forth iu this plea age€metrt, with regard to ftose @utrts o which the deftndant has

pled; or in the dteroative, at the option of the Uaited Sates, the United SraB may

move the Court to decliue this eatire plea agreement null aad void.

II . Forftitue of Assets

The deftodant agrees to forfeit to the United States immediarcly and

voluatarily any aDd all assca aod property, or portions thereof, subject to forfeiture,

pu$uant to lE USC 0g 982(aX2)@) aud 1029(cXl)(C), whether ia the possession or

control of the Unitrd StaEs, the deAndaat or defeodanfs nominees.

The deftndant agrees aud consents to the forftitur€ of &ese assets

punuatrt to any fedetal criminal, civil judicial s1 4rtminir64iys forftiture action.

The deftodant also agrees to waive all constitutionar, statutory aod procedural

hdatrt's Initials lu 8
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challenges (induding dfuect aprpeal, habeas orpus, or any other means) to any

fu[ftihrrc caried out in aeordaae with this Plea fuleement on any grounds,

indudhg that the forfeiore described hercin oonstitutcs au cxessive fine, was not

properly notiad iu the chargiag instnrmeng addressedby tte Court at the time of
the guilty plea, announced at seotencing or incorporated into the juagtnent.

If the United Statrs seels the forfeiture of specific assets pursuant b

Rule 32.2@[4), the deftodant agrees that the p,rcliminary ordcr of forftiture will

satisfy the notice requiremeot and will be find as to the defedatrt at the time it is

etrtcred. In the eveot the forfritu€ is omitted from the judgmeng the dcftodaot

agrees that the forftiEue order may be iacorporated iaO the wdtteo judgnetrt at atry

time pursuant to Rule 36.

The defeodant agrcexr to ta&e all steps neessary to idmtiry aod locare

all propcrty subject to forftiture atrd b transftr custody ofsuch property to the

United Sates beforc the deftndant's seoteacing. To that e!4 the deEndant agrecs to

make a fuII and omplete disclosure of all asseB over which defendant exercises

control directly or indirectly, induding all asseB held by asminec*, to execute atry

documens requested by the United Sates to obtain ftom any other parties by lavfirl

means aay records ofassets owned by the defendang aDd to cDns€nt to tte release of
the deftndant's tax retums for the previous five years, The defeodam further agrees

to be intewiewed by the government, prior to aad after sentencing regardiug such

assets ad their connection to criminal conduct. The defendant further agrees to be

polygraphed on the issue of asseB, if it is dc€med necessary by the unit€d states.

Defendaut's Initials
{u 9
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The deftodaat agr€es that Fed€ral Rule of Crimiual Procedure I I and USSG g lBt.E

will not protect from forfeiture asset disdosed by the deftadant as part of the

deft odant's coopcration.

The dcfendaat aglBes to teLe all steps aeoBsary to assist the

govemment in obaining dcar title to the forfriable assctr before the deftudaut's

serEtrcirg. In addition to providing full and compleE iaformation about forftitabte

aEscts, these steps include, but are not limited to, the surrcndcr of title, the signing of
a conseat decree of forftiture, 6a4 signing of any other documens D€esary to

etrectuate sucft tramftrs.

Forftiture of the deftodant's assets shall nort be teated as satisfrction of

any fine, restitution, cost of imprisoDtnent, or :rtry othcr peoalty the Court may

impose upon the defeodaat in additiou to forfeitur€.

The dcfeodant agrees tba! io the ercut the Court dctermines that the

dcftodatrt has brcachd this section of the Plea Ageemeot, the deftodant may be

found indigible for a reduction in the Guidelioes calculation for aoorymnce of

responsibility aad substantial a$istare, aad may be eligible for an obEtructiotr of
justice enhanmeat.

The deftndaat 4grees tbat the forfeiture provisioas of this plea

agreement are intendcd to, and wi4 survive the defendant, notwithstending the

abatenent of any underlying oiminal convictioa after the gxecuti6a 6f this

agrEemeut. The forfeiability of aJty particular Foperty pursuart to this agreement

shell be dctermircd as if the deftodant had suwived and that de@minatior

shalt be

pelfeadanl's Iniriels
_(lu l0
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binding upon deftodaat's heirs, su@essors and assigns until the agreed forftiture,

i4[sding any agreed forftiture amount, is collected in full.

B. Standrrd Tcrmr md Conditiorr

1. Restitutio!" Special Assessment atrd Fine

The deftndant understands and agrees tbat the Court, in additioa to or

in lieu of any other penalty, lhall order the deftodatrt to make restitution to any

victim of the oftos(s), pursuant to lE U.S.C. S 3663A, br all oftases described in

It U.S.C. S 3663A(cXl); and the Court may ordcr the deftndaot to mrlre rcstitutioa

to any victim of thc oflrns{s), pun ant to lt U.S.C. g 3663, induding restitution as

to dl counB charp4 whettrer or not the defrndant eoters a plea of guilty to such

counB, and rvhether or aot suctr couDB are digmi$sd pu$uatrt to rhiq agrcemeat.

The defendaat further uadcntands that compliance with a:ry restinrtion paym.eat

plaa imposed by fte Court ia ao way prrecludes the United Stat6 from

simulAneously pursring other statutory rcmedies for collecting restitution (28 U.S.C.

S 3003(bX2)), induding but not linited to, garnishment and execution, puruant to

the Mandatory Victims Restinrtion Acg in order to ensure that ft6 defradant's

restitution obligation is satisfied.

On each cpunt to which a plea of guilty is etrterc4 the Court shall impose a special

assessmetrt punruant to 18 u.s.c. $ 3013. The special assessmeat is due on the datc

of senEncing. The defeadant understands thxl this 1gpp66st imposes no limitatioa

as to fine.

(JlJ
De&ndant,s
-o* 11
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2, Suoervised Release

The deftndant undcrstaads that the oftos{s) to which the deftndaut is

pleading providc(s) for impoaition ofa term of supervised release upoa release from

imprisonment, and that if the deftndant should violare the conditions of release, the

deftodantwouldbe subject to a fiutter tem of imprisonment.

3. ImmiEation Consequences of Pleading Guilty

The dcfeodant has been advised and understands thag upon conviction,

a deftndant who is uot a United StatEs citizen may be rcmoved from the Uaited

Starcs, denied citizeaship, and denied admission to the United States in &e fuuue.

4. Sentencinglnformation

The Unied States rcs€fies its rigbt and obligation b rrport to the Court
and the United Stat€s Probatioa Office all information conoerning the background,

character, aad ooaduct ofrfie deftodaot, b provide relevaat factual iaformation,

induding the totality of the defeadant's crimiaal activities, if any, trot limited to the

coua(s) to which deftodant pleads, to respond to commenB madc by the deftndant

or deftndands conasel, and to cort€ct any rnisstateme[ts or inaccuracies. The

United States further reseryes its right to make any recommerdations it deems

ap,propriate regarding the disposition sf thir g6s6, subject to aay limiations set forth

herein, if aoy.

5. FinancialDisclosures

Punuatrt to 18 U.S.C. S 3664(dX3) aud Fed. R. Crim. p. 32(dX2XAXii),

the deftndaat agrees to complete and submit to the United States Attom{s Offie

Deftndant's Ininals t2
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within 30 days of execution s1 \is ageemeEt aD affidayit rcflecting the defrndant's

financial condition. The deftndant promises that her finaucial statemetrt atrd

disdosure will be complerc, aeurat€ and truthftl aud will indude all asse6 in

whictr she has any interest or over which the defeodaat exercises mntrol, dircctly or

indirectly, iaduding those held by a stx)use, dep€od€ot, nominee or other third party.

The dcftndant further agrees to exec-ute any documen$ requested by tte United

Starcs needed to obtain ftom aay third parties any records of asseB owned by the

defendang directly or ttrough a nominee, and by the execution of this Plea

comcnB to the release of the deftndaat's tar tetums for the prerrious five

years. The defeod6ai similarly agrees and authorizes the United States Attorneys

Office to provide to, and obtain from, tte Udted States Probatioa Office, the

financial affidavit any of the dcftodant's federal, state, and local tax retums, banlr

records and any 6ftsr'financial fuformation coueaing the defeodant, for the
puryose 6f mzking any recommeodations b the Court and for collecting any

ass€ssmcnts, fines, restitution, or forfeiture ordcred by the Court. The defmdant

expressly auttrorizes the United States Attome/s Office to obtein current credit

Eports itr ordcr to evaluate the dcftodant's ability to satisfy any financial obligation

imposedby the Court.

6. SentencineRecommendatiom

It is understood by the parties that the Court is neither a party to nor

bound by this ageement. The court may accept or rcject the agreemeat, or dcfrr a

decision until it has had an opporouity to coasider tte presetrtence report prepared

Defendant's Irtdrlr{D 13
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by the United States Probation Office. The defudant uaderstads and

acluowledges that, althougb the parties ale permitted to make recommendatioas and

prcseDt argumcnts to the Court, the sentence will be dctcrmined solely by the Court,

with the assistane of tte Unied StaEs Probation Ofre. Defudant further

undssaads and acloowledges that aay disorssions between d€f€ndant or

defeodanfs attoraey aod the attorney or other agcnts for thc govemment regarding

any recommeodations by the government .r. oo1!fuding oa tbe Coufi and that,

should any recommeodations be rejecE4 deftodaut will aot be permitted to

withdraw dcftodant's plea pursu2sl 1s this plea apcm@t. The govermment

expressly resewes the right to suppoil and defeod any decision that the Court may

make with regard to fte dcftndant's s@tctrce , whether or not such decisioa is

coosisteot with the governneot's recommendations conained herein.

7. Deftndant's Waiver of Right to Appeal the Senrcnce

The defeodart agl€es that fiiq Court has jurisdiction and authority to

impose aay sentence up to the statutory maximum and orpressly waives the rigtt to

appeal defendant's sentein@ on any grouo4 iaduding the ground that the Court

ered ia detemining the applicable guidelines range puruart to the United States

Sentcncing Guidclines, except (a) the ground that the scuEoce exceeds tte
deftndaat's applicable guidelines range as deteinined by the Court pursuant to the

uaited stat€s Sentcncing Guidelines; @) the goutrd that the senteuoe exceeds the

statutory maximum penalty; or (c) the ground that the sentence violates the Eighth

Amendment to the coostitution; provided, however, that if the governmeot exercises

Defendant's Irtd.r, fjtr)- t4

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its right to appeal the sertence inposed as authorized by 18 U.S.C. g 37112@), then

the defeadant is rreleascd from his waiver and may appeal the setrEnoe as authorized

by 18 U.s.c. S 3742(a).

E. Middle District of Florida Agreement

It is furttrer understood that rhis agrecment is linited to the Ofrce of the

Uoited States Atrorncy for the Mddle District of Florida and caonot bind other

fed€ml, state, or local prosecuting authorities, although this offie wiII bring

defendanfs cooperatioa, if any, to the attention of otter prosecuting officers or

others, if rcquested-

9. Filing ofASreement

This agreement shall be prreseoted to the Courg in opeu court or il

CaEgfa, in whole or ia parg upon a showing of good cause, aud fiIed ia this sagse, 41

the time of deftndant's entry of a plea of guilty pursuant hereto.

I 0. Voluntariness

The deftodaot acloowledges that defendatrt is entering into this

agreement aad is pleading guilty freely and volunarily without relianee upon any

disanssions between the attomey for the govemment and the d€ftodatrt atrd

deftndant's attorney and without promise of beoefit of any tind (otha than the

coaessions coat ined hercin), and without tbreats, force, iutimidation, or coerciou

of any kind. The deftodant frrrther aclnowleages defmdant's uademranding of the

nature of the oftase or offeoses to vfuich defedant is pleading Euilty and the

elements thereof, induding the penalties provided by law, and defeadant's complete

Defudant's Initials {t^t 15

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satisfaction with the reprreseotation and advioe reaived from deftodant's

undersigped counsel (if any). The deftndant also undentands that d€fendaflt has the

right to plead not Builty or to pcrsist in that plea if it has already beeo madc, aad ftat
deftadatrt bas the rig[t to be tied by a jury with the assistane of ouosel, the right

to confront aad cr$s-examine the wihesses a8einst &ftndant, fre right eginst

compulsory self-incrimination, and the right to compulsory p,roctss hr tte

attcodance of witncss€s to testify h defmdant's dcftose; but, by pleadiagguilty,

deftndant waives or gives up tbose rigbts aad there will be oo rrial. The dcftadant

fiuther understands that ifdeftndaot pleads guilty, the Court may ask defttrdatrt

questioDs about the oftose or oftoses to ufiich deftndant pleede4 and if defendant

answers those questioas uader oath, on the recond, and in the prcseoce of ounsel (if
any), dcftodant's arrswen may lato be used against defendant ia a poosecution for

perjury or hlse stametrt. The deftodatrt also uuderst"nds that deftodant will be

adjudicated guilty of6e offeoses to which deftadant has pleaded and, if aay of such

ofenses are &looies, may therebybe deprived of cerain righs, such as the right o
vote, to hold public office, to serve on a jury, or to have possession offirearms.

11. Factual Basis

Defendant is pleading guiltybecause d€ftodant is iD fact guilty. The

defendaot ceftifies ttat deftad,nt does hereby admit that the facts sa forth in the

attached "Factual Basis,' which is incorporated herein by reference, are true, aod

were \is case to go to trial, the unied sates would be able to prove those specific

facts a[d othcrs bcyond a reasonable doub,t.

Defendant's Initials
0r l6
Case 8:22-cr-00034-SDM-AEP Document 32 Filed 04/21/22 Page 17 of 19 PageID 104

FACTS

From as early as in or around May 202.0, and continuing tbrougfi in or

ahut Sepmbcr 2020, in the Middle District of Florida and elsewhere, the

deftodant, f,olandr 'piagfidd, eogaged in acss device firaud in relation to filing

false unernployment insuraooe (UD fraud clains. Witrgfidd obtaiacd penonal

idcntirying information (PID of other persons, specifically Social Secudty numbes,

aames, and dates ofblth, without their lnowledge or conseot (the Ptr Victim).
Wingfield would submit frbe and fraudulcnt III claims to various state wortforce

agencies for III beoetrB usmg the Ptr Victims' names, g6cial Security numbex, and

othcr information knowing that such meaJ$ of ideatification beloryed to othe$.

These III beaefia wo"ld be trarsffi to benk acrouots or loadcd onb d€bit cards

issued itr the uancs of persons-tlryically Ptr Victims---other than the de&odant.

Wingfield obtained the frauduleor fuads from accounts orATM (automated tellet

machiaes) d€bit cads usued or held at ftdcmlly insured financial iastinrtious.

\ilingEeld would then use, aad atrempt to use, the frauduleatly obained debit cards

loaded with tII beoefits to withdraw money from bant ATMS.

Specifically, oa or about Juae 12,2020, Wingfield used the Sooa]

Secarity aumber aad oame of Ptr Victim J.F. to falsely and fraudulently certifi a

daim for UI benefis aod thereby cause the Arizona Department of Economic

Security to issue a Financial tnstinrtion #I debit crrd ending h.1533. On or about

Defendant's Initials t7
Case 8:22-cr-00034-SDM-AEP Document 32 Filed 04/21/22 Page 18 of 19 PageID 105

Scptember 14,2020, Winsfield with&ew approximately $1,000 h eash from

Fharcid ltrstitudon # I account endiag in 4533.

On or about July 1,2020, Wingfield used the Social Security number

and name of Ptr Victim P.G. to falsely andfrauduleotly certi& a claim for III
bercfits and thereby cause the Arizona Department of Ecoaomic Security to issue a

Fiurcial I$titution # I debit card. The Deparment of t abor calculated the actual

loss from Vy'ingfield's ft:audulent UI claims scheme and determined it amounEd to

$135,576.00.

12. Entire AgEeement

This plea agreement constitut€s the entire agreemeot between the

governmeat and the de&ndant with r€sp6t to the aforemeutioned guilty plea and no

other promises, agreemenb, or representations exist or have beeo made to fte

ddeodant or defendant's auorney with regard to such guilty plea,

Deftodant'slnitiats@- l8
Case 8:22-cr-00034-SDM-AEP Document 32 Filed 04/21/22 Page 19 of 19 PageID 106

13. Certification

The deftodant and defudant's cornsel certi& that this plea agreement

has beea read in its entirety by (or has be€n rcad to) the deftodant and &at d€ftodalt

fully undertands its tcxms.

,l
DATED t* 13 a^v or 2022

ROGER B. IIANDBERG
Udted States Aftomey

ingfield D.Pizzo
psfendent Assistatrt Udted States Auomey

.l-/-
J Rachdle D. Bedke
AsEistatrt UtriEd Stat6 Afiomey
Chid, Eoooomic Crimes Section

l9