Factual Basis. Defendant will plead guilty because he is in fact guilty of the charge contained in the information. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt:
Factual Basis. Defendant will plead guilty because he is in fact guilty of the charges contained in Counts One and Two of the information. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt and constitute relevant conduct pursuant to Guideline § 1B1.3:
Factual Basis. Defendant will plead guilty because he is in fact guilty of the charges contained in Counts One and Count Two of the indictment. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt: On or about September 19, 2010, XXXX XXXXX XXXXXXX, attempted, without lawful authority, to use a weapon of mass destruction against people and property in a manner that would have affected interstate and foreign commerce in violation of Title 18, United States Code, Section 2332a(a)(2)(D), and attempted to damage and destroy, by means of an explosive, real property affecting interstate and foreign commerce in violation of Title 18, United States Code, Section 844(i). In early June 2010, XXXXXXX told a law enforcement cooperating source (hereinafter, the “CS”) that he wanted to commit acts of violence in Chicago for monetary gain and to cause political instability. The CS asked XXXXXXX about his ideas for a terrorist attack. XXXXXXX suggested bombing the commercial area surrounding Wrigley Field as one option. XXXXXXX explained that an attack against an entertainment center like the one near Wrigley Field could “paralyze” Chicago commerce. In response, the CS told XXXXXXX that he/she had “friends” who might be willing to pay XXXXXXX to perpetrate such an attack. Over the following weeks, the CS and XXXXXXX continued to discuss XXXXXXX’x ideas for perpetrating a terrorist act. XXXXXXX indicated that he wanted to meet with the CS’s contacts and was anxious to act against Chicago. The CS arranged a meeting between XXXXXXX and an individual the CS represented to be one of his/her purported contacts on July 8, 2010. Then unbeknownst to XXXXXXX, the contact was an undercover FBI task force officer (hereinafter “UC-1”). During their initial meeting, XXXXXXX told UC-1 that he had been contemplating how to perpetrate terrorist attacks in Chicago. XXXXXXX stated that he believed that a series of escalating violent acts could be used to undermine the city’s political establishment. When asked by UC-1 what XXXXXXX was personally willing to do, XXXXXXX indicated that he would be willing to facilitate a car bombing or the assassination of Chicago police officers. XXXXXXX assured UC-1 that he wanted to participate in some violent act. When asked if he was concerned about those who would be hurt by such violence, XXXXXXX stated that casualties were the inevitable result of what he termed “revolution.” XXXXXXX met with UC-1...
Factual Basis. Defendant will plead guilty because he is in fact guilty of the charge contained in the superseding information. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt and constitute relevant conduct pursuant to Guideline § lBl.3, and establish a basis for forfeiture of the property described elsewhere in this Plea Agreement: Beginning in or around April 2013, and continuing until in or around March 2019, at Rosemont, in the Northern District of Illinois, Eastern Division, and elsewhere, defendant, XXXXXXX XXXXXXXX, knowingly devised, intended to devise, and participated in a scheme to defraud Company A, and to obtain money and property by means of materially false and fraudulent pretenses, representations, and promises, as further described below. More specifically, beginning in or around December 2012, XXXXXXXX was the Chief Financial Officer and Manager at Company A, as well as one of the five partners of Company A. As the CFO and Manager, XXXXXXXX was responsible for Company A's financial management, prepared Company A's financial statements, made journal entries in Company A's accounting system, and was a signatory and had access to Company A's bank accounts. XXXXXXXX also was responsible for reporting information regarding Company A's finances to Company A's banks and communicating with Company A's customers with respect to outstanding accounts receivable. Under the terms of Company A's operating agreement, FREMAREK could not take certain actions-including lending any money or extending credit to any person, other than in the ordinary course of business; making any distribution of Company A funds; withdrawing or reducing capital contributions to Company A; and modifying the compensation of any employee-without the approval of a majority or supermajority of the partners. At various times during the period of FREMAREK's scheme, Company A maintained business banking accounts with Bank A, a financial institution headquartered m Schaumburg, Illinois; Bank B, a financial institution headquartered m Rosemont, Illinois; and Bank C, a financial institution headquartered in Bridgeview, Illinois. More specifically, Company A maintained a business banking account: with Bank A, beginning in or about December 2012 until in or about November 2015; with Bank B, beginning in or about November 2015 until in or about October 2018; and with Bank C, beginning in or about October 2018. During the period ...
Factual Basis. Defendant will plead guilty because she is in fact guilty of the charge contained in Count Xxxxxxx of the superseding indictment. In pleading guilty, defendant admits the following facts and that those facts establish her guilt beyond a reasonable doubt: On or about November 3, 2009, at Chicago, in the Northern District of Illinois, Eastern Division, and elsewhere, defendant XXXXXXXX XXXXXXX knowingly made a false statement to Xxxx Xxxxxx Bank, the deposits of which were then insured by the Federal Deposit Insurance Corporation, for the purpose of influencing Xxxx Xxxxxx to delay enforcement and protection of its rights to the TIF project note for the Uptown Goldblatts project issued by the City of Chicago, in that XXXXXXX told Xxxx Xxxxxx that they were working with Bank of America to resolve the double pledge issue with the Uptown Goldblatts TIF note as part of continued negotiations with Bank of America regarding a loan modification, in violation of Title 18, United States Code, Section 1014. Specifically, in September 2006, XXXXXXX became Treasurer of Xxxxxx Xxxxx & Associates (“JFA”), a real estate development company based in Chicago, Illinois. In late 2008, XXXXXXX became Vice President of JFA. In or about 2002, JFA formed a limited liability company called Uptown Goldblatts Venture LLC (“Uptown Goldblatts”) to develop a building formerly owned by Goldblatt’s Department Store, located in the Uptown neighborhood of Chicago. On or about November 20, 2002, the City of Chicago entered into a Redevelopment Agreement with Uptown Goldblatts, in which the City of Chicago agreed to issue two Tax Increment Financing (“TIF”) notes for the financing of the Uptown Goldblatts project. TIF notes were conditional grants of taxpayer funds to a specific project development that the Chicago City Council had approved. For the Uptown Goldblatts project, one TIF note was a redevelopment area note with a principal of approximately $4,300,000, and one TIF note was a project note with a principal of approximately $2,400,000. The Redevelopment Agreement provided that if an event of default occurred, the City of Chicago would no longer be obligated to make TIF payments. Uptown Goldblatts entered into a Security Agreement and Collateral Assignment of Redevelopment Documents with Xxxx Xxxxxx Bank on or about November 20, 2002. Xxxx Xxxxxx agreed to loan approximately $15,000,000 to Uptown Goldblatts in exchange for Uptown Goldblatts’ assignment to Xxxx Xxxxxx of its rights in a...
Factual Basis. Defendant will plead guilty because it is in fact guilty of the charge contained in Count One of the indictment. In pleading guilty, defendant admits the following facts and that those facts establish its guilt beyond a reasonable doubt: SYNESI ASSOCIATES, LLC was an Illinois corporation that offered education-related services to the public education industry. Xxxx Xxxxxxx was the Chief Executive Officer, and Xxxxxx Xxxxxx was the president of The SUPES Academy, LLC and SYNESI ASSOCIATES, LLC (collectively, the “SUPES Entities”). The SUPES Academy, LLC offered professional development training for school administrators. SYNESI ASSOCIATES, LLC offered education consulting services and school diagnostic review and turnaround programs. Generally, Xxxxxxx was responsible for sales and marketing of the SUPES Entities, which included traveling to conferences and school districts, while Vranas was responsible for the day-to-day operations of the SUPES Entities. The Chicago Public Schools (CPS), District Number 299, was an independent school district and unit of local government governed by the Board of Education of the City of Chicago, also known as the CBOE. The CBOE established the policies, standards, goals and initiatives for CPS. From approximately the summer of 2011 until approximately April 30, 2012, Xxxxxxx Xxxx-Xxxxxxx was a paid consultant for the SUPES Entities. In this capacity, among other duties, Xxxx-Xxxxxxx served as a master teacher for The SUPES Academy, LLC, including for its then existing client CPS. Xxxx-Xxxxxxx also assisted developing school diagnostic review and turnaround materials, called the Synesi School Turnaround Toolkit, for SYNESI ASSOCIATES, LLC. In or about December 2011, The SUPES Academy, LLC entered into a contract with Organization A to provide a leadership development program for CPS network chiefs, which program became known as the Chicago Executive Leadership Academy, or CELA. From approximately December 2011 until approximately July 2012, CELA was funded by a grant of approximately $380,000 from Organization A and approximately $25,000 from CPS. While a paid consultant for The SUPES Academy, LLC, Xxxx-Xxxxxxx served as Master Teacher and coach for the CPS CELA developmental program. From approximately May 1, 2012 until October 12, 2012, CPS employed Xxxx- Xxxxxxx as a consultant. Starting on or about October 12, 2012, Xxxx-Xxxxxxx became the Chief Executive Officer and General Superintendent of CPS. She was an agent of CP...
Factual Basis. Defendant will plead guilty because he is in fact guilty of the charges contained in Counts 1, 2, and 3 of the superseding indictment. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt: With respect to Counts 1 through 3 of the superseding indictment: From on or about September 17, 2015, to on or about September 18, 2015, at Lansing, in the Northern District of Illinois, and elsewhere, defendant XXXXXXXX XXXX did unlawfully and willfully seize, confine, kidnap, abduct, carry away, and transport Victim A in interstate commerce from the State of Illinois to the State of Indiana, and did hold Victim A for purposes of robbery, sexual assault, and otherwise, in violation of Title 18, United States Code, Section 1201(a)(1). On or about September 18, 2015, at Lansing, in the Northern District of Illinois, and elsewhere, defendant XXXXXXXX XXXX did knowingly and intentionally attempt to kill Victim A, by strangulation and by setting her on fire, with the intent to prevent the communication by Victim A to a law enforcement officer of the United States of information relating to the commission and possible commission of a Federal offense, namely, the Federal offenses charged in Counts 1, 3, 4, 5, 6, 7, 8, and 9 of the Superseding Indictment, in violation of Title 18, United States Code, Section 1512(a)(1)(C). On or about September 18, 2015, at Lansing, in the Northern District of Illinois, and elsewhere, defendant XXXXXXXX XXXX did knowingly use fire to commit any felony which may be prosecuted in a court of the United States, namely, the felony kidnapping charged in Count 1 and the felony attempted murder charged in Count 2 of the Superseding Indictment, in violation of Title 18, United States Code, Section 844(h)(1). A’s bank account. After not being able to withdraw money from BMO Xxxxxx Bank, defendant drove across state lines again, back into Illinois, and back to Victim A’s home. Once back at Victim A’s home, defendant demanded more money from her. Victim A had no more money to give. Defendant forced Victim A into the trunk of her car with her groceries, and he drove back across state lines into Indiana. After making a stop at a store, defendant drove to the parking lot of a vacant commercial business located at 000 Xxxxxx Xxxx in Xxxxx Harbor, Indiana. While in the parking lot, defendant took Victim A out of the trunk and told her to get into the back seat of the car, where he forced he...
Factual Basis. Defendant will plead guilty because he is in fact guilty of the charge contained in Count Three of the indictment. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt and constitute relevant conduct pursuant to Guideline § 1B1.3: On or about November 25, 2013, at Elgin, in the Northern District of Illinois, Eastern Division, XXXXX XXXXXXX, knowingly transported and caused to be transported child pornography, as defined in Title 18, United States Code, Section 2256(8)(A), namely, a computer file titled (1) “SSPX0060.3g2” and (2) “2010_2Bpthc_Bbabyshivid_2Bfrifam_2BPussyPlay03_2528 withsound_2529.avi,” using a means and facility of interstate and foreign commerce and in and affecting interstate and foreign commerce by any means, including by computer, in violation of Title 18, United States Code, Section 2252A(a)(1). Specifically, defendant used the Yahoo! email addresses “kimdavid5582” and “george_mason57” to receive, trade, and distribute child pornography while at his office and residence in Elgin, Illinois, among other locations. For example, on November 25, 2013, at approximately 10:43 a.m., defendant, using the Yahoo! email address “kimdavid5582,” sent an email while in his Elgin office with the following message: “do you trade. This is what I lik.” The defendant attached two files that defendant knew contained child pornography. The first attachment was a video clip titled “SSPX0060.3g2,” which depicted a naked female, approximately 6 to 7 years old, lying on her back and holding her legs behind her head while an adult male rubbed his penis against her labia and anus. The second attachment was a video clip titled “2010_2Bpthc_Bbabyshivid_2Bfrifam_2BPussyPlay03_2528withsound_2529.avi,” which depicted a naked female, approximately 2 to 3 years old, being vaginally penetrated by an adult male penis. In addition, defendant possessed images and videos depicting child pornography on computers and electronic storage devices in his residence, car and offices, including on his (1) Seagate, 320 GB hard drive, model Momentus 5400.6, bearing serial number 6VDHZZSG, stamped “Product of China”; (2) Dell Dimension 9200 computer, which contained a Seagate, 160 GB hard drive, model Barracuda 7200.9, bearing serial number 5LS8KGSX, stamped “Made in China”; (3) HP Compaq Pro 6305 computer, which contained a Seagate, 500 GB hard drive, model Barracuda, bearing serial number Z3TJJZMG, stamped “Product...
Factual Basis. Defendant will plead guilty because she is in fact guilty of the charge contained in the information. In pleading guilty, defendant admits the following facts and that those facts establish her guilt beyond a reasonable doubt: From at least as early as 2012, and continuing to at least October 2, 2020, in Rockford and Loves Park, in the Northern District of Illinois, Western Division, and elsewhere, defendant knowingly devised, intended to devise, and participated in a scheme to defraud, and to obtain money and property from Company A by means of materially false and fraudulent pretenses, representations, and promises. On or about October 1, 2020, at Rockford and Loves Park, in the Northern District of Illinois, Western Division, for the purpose of executing the scheme to defraud and to obtain money and property by means of materially false and fraudulent pretenses, representations, and promises, defendant knowingly caused to be transmitted in interstate commerce by means of wire communication, certain writings, signs, and signals, namely, a $2,800 online transfer from defendant’s husband’s business account at Bank A in Rockford, Illinois, to Corporation A in Dubuque, Iowa, and then to defendant’s personal bank account at Bank A in Rockford, Illinois, in violation of Title 18, United States Code, Section 1343. Specifically, Company A was a computer numerical control shop located in Loves Park, Illinois, that made custom components for a variety of industries. Defendant was the office manager for Company X. As the office manager, defendant’s responsibilities included, among other things, handling the accounts payable and accounts receivable. Defendant and the owner of Company A were the only two Company A employees who had access to Company A’s bank accounts. Bank A was a bank located in Rockford, Illinois. Defendant’s husband had a business account at Bank A to which defendant had access. Defendant and her husband also had a personal checking account at Bank A to which defendant had access. Corporation A was a financial services company based in Dubuque, Iowa, and was the parent for Bank A. All transfers between accounts at Bank A in Rockford, Illinois went through Corporation A in Dubuque, Iowa. In 2012, defendant started issuing checks to herself from Company A’s bank account without permission from Company A’s owner. Defendant forged the signature of Company A’s owner on the checks. Defendant then deposited the checks into her personal bank account. At s...
Factual Basis. Defendant will plead guilty because she is in fact guilty of the charge contained in Count One of the indictment. In pleading guilty, defendant admits the following facts and that those facts establish her guilt beyond a reasonable doubt, and establish a basis for forfeiture of the property described elsewhere in this Plea Agreement: Beginning no later than in or about December 2008, and continuing until at least on or about March 11, 2020, at Chicago, in the Northern District of Illinois, Eastern Division, and elsewhere, defendant XXXXXXXX XXXXX did conspire with Xxxxxxx Xxxxxx, Xxxxx Xxxxx, Xxxxxx Xxxxxxxx, and others, to commit an offense in violation of Title 18, United States Code, Sections 1956 and 1957, that is, (1) to knowingly conduct and attempt to conduct a financial transaction affecting interstate commerce, which involved the proceeds of a specified unlawful activity, that is the felonious buying and selling and otherwise dealing in a controlled substance, knowing that the transaction was designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of said specified unlawful activity and that while conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction represented the proceeds of some form of unlawful activity, in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i), and (2) to knowingly engage in a monetary transaction in and affecting interstate commerce in criminally derived property of a value greater than $10,000, such property having been derived from a specified unlawful activity, namely, the felonious buying and selling and otherwise dealing in a controlled substance, in violation of Title 18, United States Code, Section 1957, all in violation of Title 18, United States Code, Section 1956(h). More specifically, in or about 2008, XXXXX was living in Mexico with other family members, including her husband (Xxxxx Xxxxxx), her brother-in-law (Xxxxxxxxx Xxxxxx), Xxxxxxxxx’s wife (Xxxxxxx Xxxxxx), and her other brother-in-law (Xxxxxxx Xxxxxx). Between at least May 2005 and December 2008, Xxxxxxxxx Xxxxxx and Xxxxx Xxxxxx operated a Chicago-based distribution cell for the Sinaloa Cartel and the Xxxxxxx Xxxxx Organization, which involved the transportation and distribution of hundreds of kilograms of cocaine and kilogram quantities of heroin per month to customers in Chicago, Columbus, Cincinnati, P...
