Lorraine Brown, Former Head of DOCX (LPS), Pleads GUILTY to CRIMINAL Conspiracy to Commit Mail and Wire Fraud
Pursuant to Fed. R. Grim. P. 11 (c), the United States of America by and through United States Attorney for the Middle District of Florida Robert E. O’Neill and United States Department of Justice Criminal Division – Fraud Section Chief Denis Mcinerney (hereinafter also referred to as “the Government” or the “United States”), and the defendant Lorraine Brown with defendant’s attorney l\,llark Rosenblum, Esq., agree as follows:
A. Particularized Terms
1. Count Pleading To
The defendant shall enter a plea of guilty to Count One of the Information. Count One charges the defendant with Conspiracy to Commit Mail and Wire Fraud, in violation of 18 U.S.C. § 371.
2. Maximum Penalties
Count One carries a maximum sentence of up to five (5) years imprisonment, a fine of up to a fine of up to $250,000 or twice the gross pecuniary gain or twice the gross pecuniary loss occasioned by the offense, a term of supervised release of not more than three (3) years, and a special assessment of $100, said special assessment to be due on the date of sentencing. With respect to certain offenses, the Court shall order the defendant to make restitution to any victim of the offense, and with respect to other offenses, the Court may order the defendant to make restitution to any victim of the offense, or to the community, as set forth below.
3. Elements of the Offense
The defendant acknowledges understanding the nature and elements of the offense with which defendant has been charged and to which defendant is pleading guilty.
The elements of Count One are:
First: That two or more persons, in some way or manner,agreed to try to accomplish a common and unlawful plan to commit mail fraud or wire fraud, as charged in the information;
Second: The Defendant knew the unlawful purpose of the plan and willfully joined in it; and
Third: One of the conspirators committed an overt act in furtherance of the conspiracy.
Full plea agreement below…
(starts on page 8 of the doc)