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 ▇▇▇▇▇▇▇▇ ▇▇▇▇▇ did conspire with ▇▇▇▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇, ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇, 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, ▇▇▇▇▇ was living in Mexico with other family members, including her husband (▇▇▇▇▇ ▇▇▇▇▇▇), her brother-in-law (▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇), ▇▇▇▇▇▇▇▇▇’s wife (▇▇▇▇▇▇▇ ▇▇▇▇▇▇), and her other brother-in-law (▇▇▇▇▇▇▇ ▇▇▇▇▇▇). Between at least May 2005 and December 2008, ▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇ and ▇▇▇▇▇ ▇▇▇▇▇▇ operated a Chicago-based distribution cell for the Sinaloa Cartel and the ▇▇▇▇▇▇▇ ▇▇▇▇▇ 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, Philadelphia, New York, Washington, D.C., Detroit, Los Angeles, and Vancouver. This drug trafficking activity generated hundreds of millions of dollars of proceeds from the sale of narcotics. In or about November 2008, ▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇▇, and ▇▇▇▇▇▇▇ ▇▇▇▇▇▇ began cooperating with the United States government, which ultimately caused them and their families to leave Mexico and return to the United States in or about December 2008. In the United States, ▇▇▇▇▇ stored proceeds from her husband’s drug trafficking, and ▇▇▇▇▇ accessed and spent those proceeds between 2008 and 2020. Some of the drug proceeds that remained available to ▇▇▇▇▇ were stored in Chicago. However, ▇▇▇▇▇ lived outside of Chicago. Accordingly, ▇▇▇▇▇’▇ sister (▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇) and aunt (▇▇▇▇▇ ▇▇▇▇▇)—both of whom lived in the Chicago area— helped ▇▇▇▇▇ spend the cash drug proceeds in ways that ▇▇▇▇▇ knew were designed to conceal the fact that the funds involved were drug proceeds. ▇▇▇▇▇, ▇▇▇▇▇▇▇▇, and ▇▇▇▇▇ ▇▇▇▇▇ did this through several different methods, described below. In addition, ▇▇▇▇▇ understood that ▇▇▇▇▇ ▇▇▇▇▇ stored cash drug proceeds for ▇▇▇▇▇ at ▇▇▇▇▇ ▇▇▇▇▇’▇ residence in Chicago. First, at the direction of ▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇ sent quantities of ▇▇▇▇▇’▇ cash drug proceeds via U.S. Priority Express mail to ▇▇▇▇▇ and other individuals that ▇▇▇▇▇ specified. Second, at the direction of ▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇ purchased money orders and gift cards using ▇▇▇▇▇’▇ cash drug proceeds. ▇▇▇▇▇ acknowledges that ▇▇▇▇▇ ▇▇▇▇▇ then delivered or mailed the money orders to individuals and entities that ▇▇▇▇▇ specified, including a travel agency, ▇▇▇▇▇’▇ residential and commercial landlords, ▇▇▇▇▇’▇ student loan provider, child support payments for ▇▇▇▇▇’▇ step-daughter, business-related expenses, credit card payments, Bureau of Prison inmates including ▇▇▇▇▇’▇ husband, and ▇▇▇▇▇’▇ children’s private school. Third, ▇▇▇▇▇ acknowledges that ▇▇▇▇▇ ▇▇▇▇▇ deposited cash drug proceeds, which belonged to ▇▇▇▇▇, into ▇▇▇▇▇ ▇▇▇▇▇’▇ personal bank account. ▇▇▇▇▇ ▇▇▇▇▇ then used those deposited drug proceeds to make payments on a credit card used by ▇▇▇▇▇. Similarly, ▇▇▇▇▇▇▇▇ gave ▇▇▇▇▇ access to a credit card that was under the name of ▇▇▇▇▇▇▇▇ and her spouse, and ▇▇▇▇▇ used this credit card to make purchases. ▇▇▇▇▇▇▇▇ then took cash drug proceeds belonging to ▇▇▇▇▇, deposited the proceeds into Finnigan’s bank account, and used those deposits to make payments against the credit card balances that ▇▇▇▇▇ accrued. Fourth, ▇▇▇▇▇ acknowledges that ▇▇▇▇▇ ▇▇▇▇▇ and ▇▇▇▇▇▇▇▇ deposited cash drug proceeds, which belonged to ▇▇▇▇▇, into their respective bank accounts and then used the funds to pay for products and services requested by ▇▇▇▇▇, such as vehicle loans, ▇▇▇▇▇’▇ student loan provider, airfare, private school tuition, rent, and utilities. Fifth, ▇▇▇▇▇▇▇▇ deposited cash drug proceeds, which belonged to ▇▇▇▇▇, into Finnigan’s savings account. ▇▇▇▇▇▇▇▇ then transferred funds to the bank account of ▇▇▇▇▇. Sixth, between on or about March 4, 2020, and March 6, 2020, ▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇, and ▇▇▇▇▇▇▇▇ worked in concert to purchase an exercise bike system for ▇▇▇▇▇ using cash drug proceeds that ▇▇▇▇▇ ▇▇▇▇▇ had stored at the behest of ▇▇▇▇▇. ▇▇▇▇▇ identified the bicycle and accessories that she wanted purchased and she provided the information to ▇▇▇▇▇ ▇▇▇▇▇, who in turn passed the information on to ▇▇▇▇▇▇▇▇. ▇▇▇▇▇ acknowledges that ▇▇▇▇▇▇▇▇ then used a credit card to purchase the products for $3,140.87, arranging for the items to be shipped directly to ▇▇▇▇▇. ▇▇▇▇▇ further acknowledges that after ▇▇▇▇▇▇▇▇ made the purchase, ▇▇▇▇▇ ▇▇▇▇▇ reimbursed ▇▇▇▇▇▇▇▇ by giving her $3,141 in cash drug proceeds.
Appears in 1 contract
Sources: Plea Agreement
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 2008March 2013, and continuing until at least on or about March 11, 2020, at Chicago, in the Northern District of Illinois, Eastern Division, and elsewhere, defendant ▇▇▇▇▇▇▇▇ ▇▇▇▇▇ did conspire with ▇▇▇▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇, ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇, and othersothers known and unknown to the Grand Jury, 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 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, beginning no later that in or about 2008March 2013, ▇▇▇▇▇ was living in Mexico with other family membersagreed to help her niece, including her husband (▇▇▇▇▇ ▇▇▇▇▇▇), her brother-in-law (▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇), ▇▇▇▇▇▇▇▇▇’s wife (▇▇▇▇▇▇▇ ▇▇▇▇▇▇), spend cash located in Chicago and her other brother-in-law (▇▇▇▇▇▇▇ ▇▇▇▇▇▇). Between at least May 2005 and December 2008, ▇belonging to ▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇ and , which ▇▇▇▇▇ ▇knew to be drug proceeds. ▇▇▇▇▇ operated a Chicago-based distribution cell for the Sinaloa Cartel and the ▇▇▇▇▇▇▇ ▇▇▇▇▇ 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, Philadelphia, New York, Washington, D.C., Detroit, Los Angeles, and Vancouver. This drug trafficking activity generated hundreds of millions of dollars of proceeds from the sale of narcotics. In or about November 2008, ▇helped ▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇▇, and ▇▇▇▇▇▇▇ ▇▇▇▇▇▇ began cooperating with the United States government, which ultimately caused them and their families to leave Mexico and return to the United States in or about December 2008. In the United States, ▇▇▇▇▇ stored proceeds from her husband’s drug trafficking, and ▇▇▇▇▇ accessed and spent those proceeds between 2008 and 2020. Some of the drug proceeds that remained available to ▇▇▇▇▇ were stored in Chicago. However, ▇▇▇▇▇ lived outside of Chicago. Accordingly, ▇▇▇▇▇’▇ sister (▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇) and aunt (▇▇▇▇▇ ▇▇▇▇▇)—both of whom lived in the Chicago area— helped ▇▇▇▇▇ spend the cash drug proceeds in ways that ▇▇▇▇▇ knew were designed to conceal the fact that the funds involved were drug proceeds. ▇▇▇▇▇, ▇ and ▇▇▇▇▇▇▇▇, and ▇▇▇▇▇ ▇▇▇▇▇ did this through several different methods, described below. In addition, ▇▇▇▇▇ understood that stored cash drug proceeds for ▇▇▇▇▇▇▇▇ ▇▇▇▇▇ stored cash drug proceeds for ▇▇▇▇▇ at ▇▇▇▇▇ ▇▇▇▇▇’▇ residence in Chicago. First, at the direction of ▇▇▇▇▇, ▇▇▇ ▇▇▇▇▇ ▇, ▇▇▇▇▇ sent quantities of ▇▇▇▇▇▇▇▇ ▇▇▇▇▇’▇ cash drug proceeds via U.S. Priority Express mail to ▇▇▇▇▇▇▇▇ ▇▇▇▇▇ and other individuals that ▇▇▇▇▇▇▇▇ ▇▇▇▇▇ specified. Second, at the direction of ▇▇▇▇▇, ▇▇▇ ▇▇▇▇▇ ▇, ▇▇▇▇▇ purchased money orders and gift cards using ▇▇▇▇▇▇▇▇ ▇▇▇▇▇’▇ cash drug proceeds. ▇▇▇▇▇ acknowledges that ▇▇▇▇▇ ▇▇▇▇▇ then delivered or mailed the money orders to individuals and entities that ▇▇▇▇▇▇▇▇ ▇▇▇▇▇ specified, including a travel agency, ▇▇▇▇▇▇▇▇ ▇▇▇▇▇’▇ residential and commercial landlords, ▇▇▇▇▇▇▇▇ ▇▇▇▇▇’▇ student loan provider, child support payments for ▇▇▇▇▇▇▇▇ ▇▇▇▇▇’▇ step-daughter, business-related expenses, credit card payments, Bureau of Prison inmates including ▇▇▇▇▇▇▇▇ ▇▇▇▇▇’▇ husband, and ▇▇▇▇▇▇▇▇ ▇▇▇▇▇’▇ children’s private school. Third, ▇▇▇▇▇ acknowledges that ▇▇▇▇▇ ▇▇▇▇▇ deposited cash drug proceeds, which belonged to ▇▇▇▇▇, into ▇▇▇ ▇▇▇▇▇ ▇, into ▇▇▇▇▇’▇ personal bank account. ▇▇▇▇▇ ▇▇▇▇▇ then used those deposited drug proceeds to make payments on a credit card used by ▇▇▇▇▇. Similarly, ▇▇▇▇▇▇▇▇ gave ▇▇▇▇▇ access to a credit card that was under the name of ▇▇▇▇▇▇▇▇ and her spouse, and ▇▇▇▇▇ used this credit card to make purchases. ▇▇▇▇▇▇▇▇ then took cash drug proceeds belonging to ▇▇▇▇▇, deposited the proceeds into Finnigan’s bank account, and used those deposits to make payments against the credit card balances that ▇▇▇▇▇ accrued. Fourth, ▇▇▇▇▇ acknowledges that ▇▇▇▇▇ ▇▇▇▇▇ and ▇▇▇. Fourth, ▇▇▇▇▇ deposited cash drug proceeds, which belonged to ▇▇▇▇▇▇▇▇ ▇▇▇▇▇, into their respective ▇▇▇▇▇’▇ bank accounts account and then used the funds to pay for products and services requested by ▇▇▇▇▇▇▇▇ ▇▇▇▇▇, such as vehicle loans, loans and ▇▇▇▇▇▇▇▇ ▇▇▇▇▇’▇ student loan load provider, airfare, private school tuition, rent, and utilities. Fifth, ▇▇▇▇▇▇▇▇ deposited cash drug proceeds, which belonged to ▇▇▇▇▇, into Finnigan’s savings account. ▇▇▇▇▇▇▇▇ then transferred funds to the bank account of ▇▇▇▇▇. Sixth, between on or about March 4, 2020, and March 6, 2020, ▇▇▇▇▇, her other niece (▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇), and ▇▇▇▇▇▇▇▇ ▇▇▇▇▇ worked in concert to purchase an exercise bike system for ▇▇▇▇▇▇▇▇ ▇▇▇▇▇ using cash drug proceeds that ▇▇▇▇▇ ▇▇▇▇▇ had stored at the behest of ▇▇▇▇▇▇▇▇ ▇▇▇▇▇. ▇▇▇▇▇▇▇▇ ▇▇▇▇▇ identified the bicycle and accessories that she wanted purchased and she provided the information to ▇▇▇▇▇ ▇▇▇▇▇, who in turn passed the information on to ▇▇▇▇▇▇▇▇. ▇▇▇▇▇ acknowledges that ▇▇▇▇▇▇▇▇ then used a credit card to purchase the products for $3,140.87, arranging for the items to be shipped directly to ▇▇▇▇▇. ▇▇▇▇▇ further acknowledges that after ▇▇▇▇▇▇▇▇ made the purchase, ▇▇▇▇▇ ▇▇▇▇▇ reimbursed ▇▇▇. ▇▇▇▇▇ by giving her acknowledges that the total amount of money involved in the offense for which she is accountable is at least $3,141 in cash drug proceeds374,762.
Appears in 1 contract
Sources: Plea Agreement
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 ▇▇▇▇▇▇▇ ▇▇ ▇▇▇▇▇ did conspire with ▇▇▇▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇, ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇, 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, ▇▇▇▇▇▇ was living in Mexico with other family members, including her husband (▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇, or “▇▇▇▇▇▇▇▇▇”), her brother-in-law (▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇), or “▇▇▇▇▇”), ▇▇▇▇▇’s wife (▇▇▇▇▇▇▇▇ ▇▇▇▇▇, or “▇▇▇▇▇▇▇▇”), and her other brother-in-law (▇▇▇▇▇▇▇ ▇▇▇▇▇▇, or “▇▇▇▇▇▇▇”). Between at least May 2005 and December 2008, ▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇ and ▇▇▇▇▇ ▇▇▇▇▇▇ operated a Chicago-Chicago- based distribution cell for the Sinaloa Cartel and the ▇▇▇▇▇▇▇ ▇▇▇▇▇ 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, Philadelphia, New York, Washington, D.C., Detroit, Los Angeles, and Vancouver. This drug trafficking activity generated hundreds of millions of dollars of proceeds from the sale of narcotics. In or about November 2008, ▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇▇, and ▇▇▇▇▇▇▇ ▇▇▇▇▇▇ began cooperating with the United States government, which ultimately caused them and their families to leave Mexico and return to the United States in or about December 2008. In the United States, ▇▇▇▇▇ stored proceeds from her husband’s drug trafficking, and ▇▇▇▇▇ accessed and spent those proceeds between 2008 and 2020. Some of the drug proceeds that remained available to ▇▇▇▇▇ were stored in Chicago. However, ▇▇▇▇▇ lived outside of Chicago. Accordinglyor about August 2010, ▇▇▇▇▇’▇ sister (and ▇▇▇▇▇▇▇▇ turned in approximately $4.2 million in cash drug proceeds to counsel for ▇▇▇▇▇▇▇▇) and aunt (▇, for the purpose of forfeiting the proceeds to the government. At the time ▇▇▇▇▇▇ and others turned in these funds, ▇▇▇▇▇)—both ▇ and others represented that the $4.2 million to constitute all of whom lived in the Chicago area— helped available drug proceeds remaining from the drug operations of ▇▇▇▇▇▇▇▇▇ spend and ▇▇▇▇▇. However, in reality, additional drug proceeds remained available to ▇▇▇▇▇▇. In or about 2010 or 2011, ▇▇▇▇▇▇ arrived at ▇▇▇▇▇▇▇’s home in the Austin, Texas, area around the same time that a U-Haul truck filled with secondhand furniture arrived. ▇▇▇▇▇▇ was aware that the truck contained bulk cash, which ▇▇▇▇▇▇ understood to be drug proceeds, hidden inside the furniture. ▇▇▇▇▇▇ asked ▇▇▇▇▇▇▇ if he could store the cash for her. ▇▇▇▇▇▇▇ agreed and proceeded to bury the money underneath his back porch. ▇▇▇▇▇▇ acknowledges that the cash drug proceeds totaled at least approximately $2.3 million. ▇▇▇▇▇▇▇ stored the cash drug proceeds for ▇▇▇▇▇▇ for a number of years without accessing it. Beginning in ways that or about 2015, ▇▇▇▇▇▇▇ agreed to start disbursing the cash as directed by ▇▇▇▇▇▇ in exchange for a fee. At ▇▇▇▇▇▇’▇ request, ▇▇▇▇▇▇▇ disbursed the money in different ways, all of which ▇▇▇▇▇▇ knew were designed to conceal the fact illegal nature and source of the money. For example, between approximately one and four times per month (from approximately 2015 to 2020), ▇▇▇▇▇▇▇ sent quantities of the cash drug proceeds via U.S. Mail Priority Express to ▇▇▇▇▇▇ at her home or at a UPS store mailbox held under the name of ▇▇▇▇▇▇’▇ family member. The amount of drug proceeds ▇▇▇▇▇▇▇ sent in these parcels varied, but on average the parcels contained at least $9,000 per mailing. ▇▇▇▇▇▇ acknowledges that in approximately 2016 or 2017, ▇▇▇▇▇▇▇ started to sometimes exchange older, dirty currency that was often in small denominations, for newer $100 dollar bills at a nearby gas station/currency exchange where ▇▇▇▇▇▇▇ knew an employee, before then sending the funds involved were money to ▇▇▇▇▇▇ by mail. ▇▇▇▇▇▇▇ also distributed the cash drug proceeds for ▇▇▇▇▇▇ by delivering the proceeds to a travel agency near ▇▇▇▇▇▇▇’s home in order to pay for travel that ▇▇▇▇▇▇ booked for herself and others. ▇▇▇▇▇▇ told ▇▇▇▇▇▇▇ the approximate amount of cash to bring to the travel agency and then, when ▇▇▇▇▇▇▇ was inside the agency, he we would call ▇▇▇▇▇▇ via a prepaid cell phone, which ▇▇▇▇▇▇▇ used to communicate with ▇▇▇▇▇▇ regarding the drug proceeds, and let GAYTAN speak with the travel agency employee for purposes of booking the travel and also determining the final amount of money that was due. ▇▇▇▇▇▇ would then have ▇▇▇▇▇▇▇ pay the employee that final amount using the cash drug proceeds. In addition, ▇▇▇▇▇▇▇ used the cash drug proceeds to buy and mail out money orders and gift cards at ▇▇▇▇▇▇’▇ direction. ▇▇▇▇▇▇▇ at times also used his own credit or debit cards to pay for ▇▇▇▇▇▇’▇ expenses and then reimbursed himself, plus a fee, with the cash drug proceeds he stored for ▇▇▇▇▇▇. This arrangement between ▇▇▇▇▇▇▇ and ▇▇▇▇▇▇ continued until on or about March 9, 2020. Finally, ▇▇▇▇▇▇ acknowledges that on or about June 11, 2019, ▇▇▇▇▇▇ and ▇▇▇▇▇▇▇▇ knowingly caused approximately $10,307.43 in drug proceeds possessed by ▇▇▇▇▇▇▇▇ to be used to purchase airfare for ▇▇▇▇▇▇, ▇▇▇▇▇▇▇▇, and ▇▇▇▇▇ ▇▇▇▇▇ did this through several different methodstheir relatives, described below. In addition, ▇▇▇▇▇ understood that ▇▇▇▇▇ ▇▇▇▇▇ stored cash drug proceeds for ▇▇▇▇▇ at ▇▇▇▇▇ ▇▇▇▇▇’▇ residence a travel agency in Chicago. First, at the direction of ▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇ sent quantities of ▇▇▇▇▇’▇ cash drug proceeds via U.S. Priority Express mail to ▇▇▇▇▇ and other individuals that ▇▇▇▇▇ specified. Second, at the direction of ▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇ purchased money orders and gift cards using ▇▇▇▇▇’▇ cash drug proceeds. ▇▇▇▇▇ acknowledges that ▇▇▇▇▇ ▇▇▇▇▇ then delivered or mailed the money orders to individuals and entities that ▇▇▇▇▇ specified, including a travel agency, ▇▇▇▇▇’▇ residential and commercial landlords, ▇▇▇▇▇’▇ student loan provider, child support payments for ▇▇▇▇▇’▇ step-daughter, business-related expenses, credit card payments, Bureau of Prison inmates including ▇▇▇▇▇’▇ husband, and ▇▇▇▇▇’▇ children’s private school. Third, ▇▇▇▇▇ acknowledges that ▇▇▇▇▇ ▇▇▇▇▇ deposited cash drug proceeds, which belonged to ▇▇▇▇▇, into ▇▇▇▇▇ ▇▇▇▇▇’▇ personal bank account. ▇▇▇▇▇ ▇▇▇▇▇ then used those deposited drug proceeds to make payments on a credit card used by ▇▇▇▇▇. Similarly, ▇▇▇▇▇▇▇▇ gave ▇▇▇▇▇ access to a credit card that was under the name of ▇▇▇▇▇▇▇▇ and her spouse, and ▇▇▇▇▇ used this credit card to make purchases. ▇▇▇▇▇▇▇▇ then took cash drug proceeds belonging to ▇▇▇▇▇, deposited the proceeds into Finnigan’s bank account, and used those deposits to make payments against the credit card balances that ▇▇▇▇▇ accrued. Fourth, ▇▇▇▇▇ acknowledges that ▇▇▇▇▇ ▇▇▇▇▇ and ▇▇▇▇▇▇▇▇ deposited cash drug proceeds, which belonged to ▇▇▇▇▇, into their respective bank accounts and then used the funds to pay for products and services requested by ▇▇▇▇▇, such as vehicle loans, ▇▇▇▇▇’▇ student loan provider, airfare, private school tuition, rent, and utilities. Fifth, ▇▇▇▇▇▇▇▇ deposited cash drug proceeds, which belonged to ▇▇▇▇▇, into Finnigan’s savings account. ▇▇▇▇▇▇▇▇ then transferred funds to the bank account of ▇▇▇▇▇. Sixth, between on or about March 4, 2020, and March 6, 2020, ▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇, and ▇▇▇▇▇▇▇▇ worked in concert to purchase an exercise bike system for ▇▇▇▇▇ using cash drug proceeds that ▇▇▇▇▇ ▇▇▇▇▇ had stored at the behest of ▇▇▇▇▇. ▇▇▇▇▇ identified the bicycle and accessories that she wanted purchased and she provided the information to ▇▇▇▇▇ ▇▇▇▇▇, who in turn passed the information on to ▇▇▇▇▇▇▇▇. ▇▇▇▇▇ acknowledges that ▇▇▇▇▇▇▇▇ then used a credit card to purchase the products for $3,140.87, arranging for the items to be shipped directly to ▇▇▇▇▇. ▇▇▇▇▇ further acknowledges that after ▇▇▇▇▇▇▇▇ made the purchase, ▇▇▇▇▇ ▇▇▇▇▇ reimbursed ▇▇▇▇▇▇▇▇ by giving her $3,141 in cash drug proceeds.
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Sources: Plea Agreement