UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. ____________ _ 

UNITED STATES OF AMERICA 

18 u.s.c. § 1349 

18 U.S.C. § 1956(h) 

18 U.S.C. § 1425(a) 

18 U.S.C. § 982(a) 

vs. 

JOFF STENN WROY PHILOSSAINT, 

MARIEL TOLLINCHI, 

FILED BY jp 

SEP O 8 2022 

REGINE MARIE RENE, and 

BRIANNA MONIQUE GAYLE, 

Defendants. 

I ---------------

INDICTMENT 

The Grand Jury charges that: 

GENERAL ALLEGATIONS 

At all times material to this Indictment: 

The Paycheck Protection Program 

ANGELA E. NOBLE 

CLERK U.S. DIST. CT. 

S.D. OF FLA. - W.P.B. 

D.C. 

1. The Coronav irus Aid, Relief, and Economic Security ("CARES") Act was a federal 

law enacted in or aro und March 2020 and designed to provide emergency financia l assistance to 

the millions of Americans who were suffering the economi c effects caused by the COVID-19 

pandemic. One source of relief provided by the CARES Act was the authorization of forgivable 

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loans to small businesses for job retenti on and certain other expenses, through a program referred 

to as the Paycheck Protection Program ("PPP"). 

2. The types of businesses e ligibl e for a loan included so le proprietorships. In order to 

obtain a PPP loan, a qua lify ing business (through its authori zed representati ve or the sole 

proprietor) signed and submitted a PPP loan application (Small Business Administration ("SBA") 

Fo rm 2483) online through the lender's application platform. ln order to be e lig ible to obtai n the 

PPP loan, the PPP loan application required the business (through its authorized representative or 

the sole propri etor) to acknowledge the program ru les and make certa in affirm ati ve certifications. 

The certifications inc luded an attestati on that th e business was in operation on February 15, 2020, 

and had employees fo r whom it pa id sa laries and payro ll taxes, or pa id independent contractors, 

or was a so le proprietorship with no emp loyees. In the PPP loan application, the small business 

(through its authorized representati ve or the so le proprietor) was required to p rov ide, among other 

th ings, its average monthly payroll expenses and number of employees. ln addition, businesses 

app lying fo r the PPP loan were required to provide documentati on confirming the ir payro ll 

expenses. Typically, businesses supplied documents showing the amount of payroll taxes reported 

to the Internal Revenue Service ("IRS"). The sole proprietorship had to report and document the 

business' income and expenses, as typi cally reported to the IRS on Form I 040, Schedul e C. These 

figures and documentati on were used to ca lculate the amount of money the smal l business was 

eli gibl e to receive under the PPP. Sole proprietorships were e li gible to rece ive a maximum PPP 

loan of up to $20,833 to cover lost income. 

3. A PPP loan applicati on was processed by a partic ipating lender. The SBA delegated 

authority to th ird-party lenders to underwrite and approve the loans. If a PPP loan appli cation was 

approved, the partic ipating lender funded the PPP loan using its own monies, which were I 00% 

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guaranteed by the SBA. Data from the appli cation, inc luding information about the borrower, the 

total amount of the loan, and the listed number of employees, was transmitted electronically by 

the lender to the SBA in the course of processing the loan. 

4. PPP loan proceeds were required to be used by the business on certain permissible 

expenses - payroll costs, interest on mortgages, rent, and uti li ties. The PPP allowed the interest 

and principal on the PPP loan to be entire ly forgiven if the business spent the loan proceeds on 

these expense items within a designated period of time and used a defined portion of the PPP loan 

proceeds on payro ll expenses. 

The Economic Injury Disaster Loan Program 

5. Before the COVID-1 9 pandemic, SBA's Economi c Injury Disaster Loan ("EIDL") 

program provided low-interest financing to small businesses, renters, and homeowners in regions 

affected by declared disasters. 

6. The CARES Act also authorized the SBA to prov ide EIDL assistance to eligible 

small businesses experienc ing "substantia l economi c injury" (substanti al financial disruptions) 

due to the COVID- 19 pandemic. In order to obta in a COVID-19 EIDL, a qualifying business was 

required to submit e lectronica lly an ETDL appli cation to the SBA and provide information about 

its operations, such as the number of employees, gross revenues, and the cost of goods so ld for the 

12-month period preceding January 31, 2020. The applica nt was a lso required to certify under 

penalty of perjury that al l of the informati on in the EIDL appli cation was true and correct to the 

best of the applicant's knowledge. 

7. EIDL appli cations were submitted directly to, and processed by, the SBA, with 

support from a government contractor. ETDL fund s were issued directly from the United States 

Treasury . 

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8. In addition, the CARES Act authori zed the SBA to issue advances of up to $10,000 

to small businesses within three days of applying for an EIDL. The amount of the advance was 

determined by the number of employees the applicant certified hav ing at the small business. The 

advances did not have to be repaid . 

9. SBA's email and loan application servers were located outside the State of F lorida, 

so wire communications between banks and the SBA and between EIDL appli cants located within 

Florida and the SBA necessarily trave led in interstate commerce. 

The Defendants, Businesses, Lenders, and Banks 

10. Defendant JOFF STENN WROY PHILOSSAINT was a resident of Broward and 

Miami-Dade Counties, in th e Southern Distri ct of Florida. 

11 . Defendant MARIEL TOLLINCHI was a resident of Broward County, in the 

Southern District of Florida. 

12. Defendant REGINE MARIE RENE was a resident of Palm Beach County, in the 

Southern Distri ct of Florida. 

13. Defendant BRIANNA MONIQUE GAYLE was a resident of Palm Beach and 

Miami-Dade Counti es, in the Southern District of Florida. 

14. Co-conspirator Maurice Shazier was a resident of St. Lucie County, in the Southern 

Distri ct of Florida. 

15. Co-conspirator David Andre Johnson was a resident of Broward County, in the 

Southern District of Florida. 

16. Defendant JOFF ST~ ROY PHILOSSAINT was the principal and registered 

agent of Royal Elite Trans, LLC ("ROY AL ELITE"), Elite Internati onal Financial Group, a/k/a 

Elite International Venture Capital ("EJVC"), and One Solution Gro up LLC ("ONE 

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SOLUTION"), purported businesses located in Broward County, in the Southern District of 

Florida. 

17. Defendant MARJ EL TOLLINCHI was the Treasurer of the Cinda Foundation Inc. 

("CINDA"), and her family members were the principals and registered agents of CINDA, Ferro's 

Entertainment and Production LLC ("FERRO'S"), and D.F. d/b/a "Perfect Landscaping" 

("PERFECT LANDSCAPING"), purported businesses located in Broward County, in the 

Southern District of Florida. TOLLINCHI was a lso the principal of Tollinchi Law P.A. 

("TOLLINCHI LAW"), a law firm located in Broward County, in the Southern District of Florida. 

18. Defendant JOFF STENN WROY PHILOSSAINT was the president and 

TOLLINCHI LAW was the registered agent of Dad Money Investment Group, LLC ("DAD 

MONEY"), a purported business located in Broward County, in the Southern District of Florida. 

19. Defendant REGINE MARIE RENE was the principal and registered agent of Unfold 

Perception, LLC ("UNFOLD"), a purported business located in Palm Beach County, in the 

Southern District of Florida. 

20. Defendant BRIANNA MONIQUE GAYLE was an employee of EIVC and 

purportedly owned a sole proprietorship in her name located in Palm Beach County, in the 

Southern District of Florida. 

21. Co-conspirator Maurice Shazier was the principal and registered agent of Sunrise 

City Construction Development LLC ("SUNRJSE CITY") and JREAM Vision T.V. LLC 

("JREAM"), purpotied businesses located in St. Lucie County, in the Southern District of Florida. 

22. Co-conspirator David Andre Johnson was the principal and registered agent of 

D.D.Z. Fam ily Enterprises L.L.C. ("DDZ"), a purpo1ied business located in Broward County, in 

the Southern District of Florida. 

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23. Lender # 1 was headquartered in New Jersey and was an approved SBA lender for 

PPP loans. 

24. Lender #2 was headquartered in Delaware and was an approved SBA lender fo r PPP 

loans. 

25 . Lender #3 was headquartered in Utah and was an approved SBA lender for PPP 

loans. 

COUNT 1 

(Conspiracy to Commit Wire Fraud: 18 U.S.C. § 1349) 

Paragraphs 1 through 25 of the General Allegati ons Secti on of this Ind ictment are realleged and incorporated by reference as though fu lly set forth herein . 

From in or around Apri l 2020, continuing through on or about August 7, 2022, the exact 

dates being unknown to the Grand Jury, in Palm Beach, St. Lucie, Broward, and Miami-Dade 

Counties, in the Southern District of Florida, and elsewhere, the defendants, 

JOFF STENN WROY PHILOSSAINT, 

MARIEL TOLLINCHI, 

REGINE MARIE RENE, and 

BRIANNA MONIQUE GAYLE, 

did willfully, that is, with the intent to furth er the obj ect of the conspiracy, and knowingly combine, 

conspire, confederate, and agree w ith each other and with persons known and unknown to the 

Grand Jury, to knowingly, and with the intent to defraud, dev ise, and intend to devise, a scheme 

and artifice to defraud, and to obtain money and property by means of materi ally fa lse and 

fraudulent pretenses, representations, and promises, knowing that the pretenses, representations, 

and promises were fa lse and fraudul ent when made, and, fo r the pu rpose of executing such scheme 

and artifice, did transmit and cause to be transmitted, by means of wire communications in 

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interstate and fore ign commerce, certain writings, signs, signals, pictures, and sounds, in violation 

of Title 18, United States Code, Section 1343. 

PURPOSE OF THE CONSPIRACY AND THE SCHEME AND ARTIFICE 

It was the purpose of the conspiracy and of the scheme and artifice for the Defendants and 

their co-conspirators to un lawfu ll y enri ch themse lves by, among other th ings: (1) creating false 

and fraudulent documents, including payroll records and tax documents; (2) submitting and 

causing the submission of fa lse and fraudulent app li cations for loans made avai lable through the 

SBA to provide relief for the economic effects caused by the COV lD- 19 pandemic, including 

EJDL and PPP loans; (3) offering, paying, and receiving kickbacks in return for causing the 

submission of fa lse and fraudulent loan applications; (4) diverting fraud proceeds for the 

Defendants' and co-conspirators' personal use and benefit, the use and benefit of others, and to 

further the conspiracy; and (5) submitting and causing the submission of false and fraudulent 

applications for forgiveness of the received loans. 

MANNER AND MEANS 

The manner and means by which the defendants and their co-conspirators sought to 

accomplish the purpose of the conspiracy and the scheme and artifi ce incl uded, among others, the 

fol lowing: 

(a) JOFF STENN WROY PHTLOSSATNT and BRIANNA MONlQUE 

GAYLE created and caused the creation of fa lse and fra udulent tax documents for business entities 

owned and contro lled by themselves, MARIEL TOLLINCHI, REGINE MARIE RENE, Maurice 

Shazier, David Andre Johnson, and others known and unknown to the Grand Jury, for the purpose 

of app lying for PPP and EIDL loans. 

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(b) JOFF STENN WROY PHlLOSSA lNT, MARIEL TOLLINCHI, REGINE 

MARIE RENE, BRIANNA MONIQUE GAYLE, Mauri ce Shazier, David Andre Johnson, and 

others known and unknown to the Grand Jury submitted and caused the submission of fa lse and 

fraudulent PPP and ElDL loan applications fo r these business entities. 

(c) The PPP and EIDL loan applicati ons submitted, or caused to be submitted, 

by JOFF STENN WROY PHlLOSSAINT, MARIEL TOLLINCHI, REGJNE MARIE RE E, 

BRlANNA MONIQUE GAYLE, Mauri ce Shazier, Dav id Andre Johnson, and others known and 

unknown to the Grand Jury included false and fraudul ent tax documents and falsely and 

fra udulently represented the borrowing entities' number of employees, amount of monthly payroll, 

gross income, and cost of goods so ld. 

(d) JOFF STENN WROY PHlLOSSAlNT and BRIANNA MONIQUE 

GAYLE created and caused the creation of false and fraudulent payroll accounts with a payroll 

processing service for business entiti es owned and controlled by themselves, MARIEL 

TOLLINCHI, REGINE MARIE RENE, Maurice Shazier, David Andre Johnson, and others 

known and unknown to the Grand Jury, for the purpose of applying for PPP and EIDL loans and 

PPP loan fo rgiveness. 

(e) Having obtained PPP and EJDL loans fo r those entities, JOFF STENN 

WROY PHTLOSSATNT, MARIEL TOLLINCHI, REGINE MARIE RENE, BRJANNA 

MONIQUE GAYLE, Maurice Shazier, Dav id Andre Johnson, and others known and unknown to 

the Grand Jury caused the electroni c wire transfer of a portion of the loan proceeds to a payroll 

processing service to make it appear that the proceeds were being used fo r legitimate payro ll 

expenses. 

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(f) Having obtained PPP and EIDL loans for their business entities, JOFF 

STENN WROY PHILOSSAINT caused MARIEL TOLLINCHI, REGINE MARIE RENE, 

BRIANNA MONIQUE GAYLE, Maurice Shazier, David Andre Johnson, and others known and 

unknown to the Grand Jury to pay kickbacks of approximately 10% of the loans' values to JOFF 

STENN WROY PHILOSSAINT via checks and wire transfers that were often disguised as 

legitimate business expenses. 

(g) JOFF STENN WROY PHILOSSAINT, MARIEL TOLLINCHI, REGINE 

MARIE RENE, BRIANNA MONIQUE GAYLE, Maurice Shazier, David Andre Johnson, and 

others known and unknown to the Grand Jury submitted and caused the submission of false and 

fraudulent applications for PPP loan forgiveness for these business entities. 

(h) As a result of the false and fraudulent representations that JOFF STENN 

WROY PHJLOSSAINT, MARIEL TOLLINCHI, REGINE MARJE RENE, BRIANNA 

MONIQUE GAYLE, Maurice Shazier, David Andre Johnson, and others known and unknown to 

the Grand Jury made in the PPP and EIDL loan applications submitted as part of this scheme, 

financial institutions and the SBA disbursed loan proceeds to the Defendants and their coconspirators in the amount of approximately $8.1 million. 

All in violation of Title 18, United States Code, Section 1349. 

COUNT2 

(Conspiracy to Commit Money Laundering: 18 U.S.C. § 1956(h)) 

From in or around April 2020, continuing through on or about August 7, 2022, the exact 

dates being unknown to the Grand Jury, in Palm Beach, St. Lucie, Broward, and Miami-Dade 

Counties, in the Southern District of Florida, and elsewhere, the defendants, 

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JOFF STENN WROY PHILOSSAINT, 

MARIEL TOLLINCHI, 

REGINE MARIE RENE, and 

BRIANNA MONIQUE GAYLE, 

did knowingly and vo luntarily combine, conspire, confederate, and agree w ith each other and w ith 

persons known and unknown to the Grand Jury, to knowingly conduct, and attempt to conduct, a 

financ ia l transaction affecting interstate and fo re ign commerce involving the proceeds of spec ified 

unl awful activity, knowing that the property invo lved in the transaction represented the proceeds 

of some form of unl awful activity, and knowing that the transacti on was designed, in whole and 

in part, to concea l and disguise the nature, locati on, source, ownership, and control of the proceeds 

of said spec ified unlawful acti vity, in violati on of 18 U.S.C. § 1956(a)( l )(B)(i). 

It is furth er alleged that the specified unl awful activity is w ire fraud, in violation of 18 

U.S.C. § 1343. 

A ll in violation of Title 18, United States Code, Section l 956(h). 

COUNT3 

(Conspiracy to Commit Money Laundering: 18 U.S.C. § 1956(h)) 

From in or around April 2020, continuing through on or about August 7, 2022, the exact 

dates be ing unknown to the Grand Jury, in Pa lm Beach, St. Lucie, Broward, and Mi ami-Dade 

Counti es, in the South ern Distri ct of Florida, and e lsewhere, the defendants, 

JOFF STENN WROY PHILOSSAINT, 

and 

MARIEL TOLLINCHI, 

did knowingly and vo luntarily combine, conspire, confederate, and agree with each other and w ith 

persons known and unknown to the Grand Jury, to: 

(a) knowingly transmit and transfer monetary instruments and fund s, from a 

place inside the United States to and th ro ugh a pl ace outside the United States, knowing that the 

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monetary instruments and funds involved in such transmission and transfer represented the 

proceeds of some form of unlawfu l activ ity, and knowing that such transmission and transfer was 

designed in whole and in part to concea l and disguise the nature, location, source, ownership, and 

control of the proceeds of spec ified unlawfu l activity, in violation of 18 U.S.C. § l 956(a)(2)(B)(i); 

and 

(b) knowingly engage in a monetary transaction by, through, and to a financial 

institution, affecting interstate and fore ign commerce, in crimina lly derived property of a va lue 

greater than $ 10,000 that is derived from spec ified unlawful activity, in violation of 18 U.S.C. § 

1957. 

It is further a lleged that the spec ified unlawfu l activity is wire fraud , in violation of 18 

U.S.C. § 1343. 

All in vio lation of Title 18, Uni ted States Code, Section l 956(h). 

COUNT4 

(Obtaining Citizenship by Fraud: 18 U.S.C. § 1425(a)) 

Paragraphs 1 through 9 of the General Allegations Section of this Indictment are re-a ll eged 

and incorporated by reference as though fully set forth here in . 

Beg inning at least as early as December 15, 2020, and continuing through on or about 

February 9, 202 1, in Broward and Miami-Dade Counti es, in the Southern District of Florida, and 

elsewhere, the defendant, 

JOFF STENN WROY PIDLOSSAINT, 

did knowingly procure and attempt to procure, contrary to law, naturalization as a United States 

citizen for himself, to wit, the defendant obta ined and attempted to obtain natura lization by fa lsely 

swearing to a statement in his written Form N-400 (Appli cation fo r Natura lization), his 

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naturalization interview, and his written Form N-455 (Notice of Naturalization Oath Ceremony), 

that: 

(a) he had not knowingly commi tted, assisted in committing, or attempted to 

commit, a crime or offense fo r which he had not been arrested, when in truth and in fact, as the 

defendant then and there well knew, he had committed the offenses of wire fraud conspiracy, and 

money launderi ng conspiracy, as charged in Counts I through 3 of this Indictment; and 

(b) he had not made any misrepresentation to obta in any public benefit in the 

United States, when in truth and in fact, as the defendant then and there well knew, he had 

misrepresented businesses, their earnings, and their employee workforces in an effort to obtai n 

multiple loans and advances, and fo rgiveness of those loans and advances pursuant to the Un ited 

States' Paycheck Protection Program and the Economic Injury Disaster Loan Program. 

A ll in vio lation of Title 18, United States Code, Section l 425(a). 

FORFEITURE ALLEGATIONS 

1. The allegations of this Indictment are hereby re-alleged and by this reference fully 

incorporated herein for the purpose of alleging forfeiture to the United States of America of certain 

property in which the defendants, JOFF STENN WROY PHILOSSAINT, MARIEL TOLLINCHI, 

REGINE MARIE RENE, and BRIANNA MONIQUE GAYLE, have an interest. 

2. Upon conviction of a vio lation of Titl e 18, United States Code, Section 1349, as 

alleged in this Indictment, the defendant sha ll forfeit to the United States any property constituting, 

or derived from, proceeds obtained, directly or indirectly, as the result of such offense, pursuant to 

Titl e 18, Un ited States Code, Section 982(a)(2)(A). 

3. Upon conviction of a violation of Title 18, United States Code, Section l 956(h), as 

a lleged in this Indi ctment, the defendant shall forfeit to the United States any property, real or 

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personal, involved in such offense, and any property traceable to such property, pursuant to Title 

18, United States Code, Section 982(a)(l). 

All pursuant to Title 18, United States Code, Sections 982(a)(l) and 982(a)(2)(A), and the 

procedures set forth at Title 21, Uni ted States Code, Section 853, as incorporated by Title 18, 

United States Code, Sections 982(6)(1 ). 

A TRUE BILL. 

FOREPERSON 

for- A. MARIE VILLAFANA 

ASSISTANT UNITED STA TES ATTORNEY 

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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

UNITED STATES OF AMERICA CASE NO.: 

v. 

JOFF STENN WROY PHILOSSAJNT, 

MARIEL TOLLINCHI, BRIANNA M. 

CERTIFICATE OF TRIAL ATTORNEY* 

GAYLE, & REGINE MARlE RENE, / 

-------------- Superseding Case Information: 

Defendants. 

Court Division (select one) 

□ Miami □ Key West □ FTP 

New Defendant(s) (Yes or No) 

Number of New Defendants 

□ FTL El WPB Total number of New Counts 

I do hereby certify that: 

I. I have carefully considered the allegations of the indictment, the number of defendants, the number of probable 

witnesses and the legal complexities of the Indictment/Information attached hereto. 

2. I am aware that the information supplied on this statement wi ll be relied upon by the Judges of this Court in setting 

their calendars and sched uling criminal trials under the mandate of the Speedy Trial Act, Title 28 U.S.C. §316 1. 

3. Interpreter: (Yes or No) No 

List language and/or dialect: 

4. This case will take 20 days for the parties to try. 

5. Please check appropriate category and type of offense listed below: 

(Check only one) 

I D Oto 5 days 

II D 6 to 10 days 

III El 11 to 20 days 

IV D 21 to 60 days 

V D 61 days and over 

(Check on ly one) 

□ Petty 

D Minor 

□ Misdemeanor 

El Felony 

6. Has this case been previously filed in this District Court? (Yes or No) No 

If yes, Judge Case No. 

7. Has a complaint been filed in this matter? (Yes or No) Yes 

If yes, Magistrate Case No. 22-8336-BER, 22-8337-BER, 22- 8357-BER 

8. Does this case relate to a previously filed matter in this District Court? (Yes or No) No 

If yes, Judge Case No. 

9. Defendant(s) in federal custody as of 8/7/2022 (Philossaint) 

10. Defendant(s) in state custody as of 

11. Rule 20 from the District of 

12. Is this a potential death penalty case? (Yes or No) No 

13. Does this case originate from a matter pending in the Northern Region of the U.S. Attorney 's Office 

prior to August 8, 2014 (Mag. Judge Shaniek Maynard? (Yes or No)No 

14. Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office 

prior to October 3, 20 19 (Mag. Judge Jared Strauss? (Yes or No)No 

By: 

A. MARIE VILLAFANA 

Assistant United States Attorney 

FLA Bar No. 0018255 

22-cr-80144-Smith/Maynard

Case 9:22-cr-80144-RS Document 32 Entered on FLSD Docket 09/08/2022 Page 14 of 18
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: JOFF STENN WROY PHILOSSAINT 

Case No: --------------------------------

Count #1: 

Conspiracy to Commit Wire Fraud 

Title 18 United States Code Section 1349 

*Max. Term of Imprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gross gain 

Counts #2-3: 

Money Laundering Conspiracy 

Title 18, United States Code, Section l 956(h) 

*Max.Term of Imprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

Count #4: 

Acquiring Naturalized U.S. Citizenship through Fraud 

Title 18, United States Code, Section 1425(a) 

* Max. Term of Imprisonment: 10 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $250,000 

*Refers only to possible term of incarceration, supervised release and fines. It does not include 

restitution, special assessments, parole terms, or forfeitures that may be applicable. 

22-cr-80144-Smith/Maynard

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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENAL TY SHEET 

Defendant's Name: MARIEL TOLLINCHI 

Case No: --------------------------------

Count #1: 

Conspiracy to Commit Wire Fraud 

Title 18 United States Code Section 1349 

* Max. Term of Imprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gross gain 

Counts #2-3: 

Money Laundering Conspiracy 

Title 18, United States Code, Section 1956(h) 

* Max. Term oflmprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

*Refers only to possible term of incarceration, supervised release and fines. It does not include 

restitution, special assessments, parole terms, or forfeitures that may be applicable. 

22-cr-80144-Smith/Maynard

Case 9:22-cr-80144-RS Document 32 Entered on FLSD Docket 09/08/2022 Page 16 of 18
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: REGINE MARIE RENE 

Case No: --------------------------------

Count #1: 

Conspiracy to Commit Wire Fraud 

Title 18 United States Code Section 1349 

* Max. Term of Imprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gross gain 

Count #2: 

Money Laundering Conspiracy 

Title 18, United States Code, Section 1956(h) 

* Max. Term oflmprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

*Refers only to possible term of incarceration, supervised release and fines. It does not include 

restitution, special assessments, parole terms, or forfeitures that may be applicable. 

22-cr-80144-Smith/Maynard

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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENAL TY SHEET 

Defendant's Name: BRIANNA MONIQUE GAYLE 

Case No: --------------------------------

Count #1: 

Conspiracy to Commit Wire Fraud 

Title 18 United States Code Section 1349 

*Max.Term of Imprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gross gain 

Count #2: 

Money Laundering Conspiracy 

Title 18, United States Code, Section 1956(h) 

*Max.Term oflmprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

*Refers only to possible term of incarceration, supervised release and fines. It does not include 

restitution, special assessments, parole terms, or forfeitures that may be applicable. 

22-cr-80144-Smith/Maynard

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