UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA

v.

ROSALLIE C. CORVITE

No. 19 CR 226-3 

Judge Virginia M. Kendall 

PLEA AGREEMENT 

1. This Plea Agreement between the United States Attorney for the 

Northern District of Illinois, JOHN R. LAUSCH, JR., and defendant ROSALLIE C. 

CORVITE, and her attorney, DOUGLAS WHITNEY, is made pursuant to Rule 11 of 

the Federal Rules of Criminal Procedure and is governed in part by Rule 11(c)(1)(A), 

as more fully set forth below. The parties to this Agreement have agreed upon the 

following:

Charges in This Case

2. The fourth superseding indictment in this case charges defendant with 

conspiracy to commit offenses against the United States, in violation of Title 18, 

United States Code, Section 371 (Counts One and Two), and making false entries in 

the books of a financial institution, in violation of Title 18, United States Code, 

Section 1005 (Counts Five and Six). 

3. Defendant has read the charges against her contained in the fourth

superseding indictment, and those charges have been fully explained to her by her 

attorney. 

FILED 5/23/2022

THOMAS G. BRUTON CLERK, U.S. DISTRICT COURT

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 1 of 23 PageID #:6020
2

4. Defendant fully understands the nature and elements of the crimes with 

which she has been charged.

Charge to Which Defendant Is Pleading Guilty 

5. By this Plea Agreement, defendant agrees to enter a voluntary plea of 

guilty to the following count of the fourth superseding indictment: Count One, which 

charges defendant with conspiracy to commit offenses against the United States, in 

violation of Title 18, United States Code, Section 371.

Factual Basis 

6. Defendant will plead guilty because she is in fact guilty of the charge 

contained in Count One of the fourth superseding indictment. In pleading guilty, 

defendant admits the following facts and that those facts establish her guilt beyond 

a reasonable doubt and constitute relevant conduct pursuant to Guideline § 1B1.3: 

Defendant ROSALLIE C. CORVITE was employed by Washington Federal

Bank for Savings, first, in 2003, as a teller; then, in 2005, as an accounting clerk and 

accounting assistant. In 2011, CORVITE became the Chief Financial Officer (CFO). 

CORVITE’s duties as CFO included maintaining the bank’s general ledger, which 

included managing the income and expenses of the bank on the general ledger; 

preparing financial reports; preparing call reports; and providing information to 

auditors, consultants, and regulators. CORVITE also was involved in approving wire 

transfers and in generating checks from the bank’s operating account. While CFO, 

CORVITE was also part of the Audit, Compliance, and Asset-Liability Committees.

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 2 of 23 PageID #:6021
3

Beginning in at least 1989, the deposits of Washington Federal were insured 

by the Federal Deposit Insurance Corporation (FDIC). Washington Federal was 

required to regularly provide to the FDIC documentation of its financial condition, 

including Call Reports setting out, among other things, the performance of the bank’s 

loan portfolio and the bank’s income. 

Beginning in approximately 2011, Washington Federal was supervised by the 

Office of the Comptroller of the Currency (OCC) which regularly monitored and 

conducted periodic examinations of the operations of Washington Federal. The OCC 

reviewed and relied on loan documentation and other records Washington Federal 

contemporaneously created during the course of its operations. The OCC also 

reviewed and relied on documents that Washington Federal created for the purpose 

of providing them to the OCC and the FDIC, such as Call Reports and trial loan 

balances, which disclosed delinquencies, compliance with lending limitations, and 

loan histories. The OCC also reviewed and relied upon reports and audits generated 

by third-party auditors of and consultants to Washington Federal, including 

Consultant A.

Individual A was President, Chief Executive Officer, and Chairman of the 

Board of Directors of Washington Federal and the direct supervisor of CORVITE. 

James R. Crotty was employed by Washington Federal as Vice President. Jane V. 

Iriondo, fka Jane V. Tran (Iriondo), was employed by Washington Federal, first, in 

1999, as a teller; then, in 2003, as executive secretary for Individual A; and, finally, 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 3 of 23 PageID #:6022
4

in 2006, as Corporate Secretary. Alicia Mandujano was employed by Washington 

Federal first, as a teller; then, as the secretary to the president; and, finally, as a loan 

servicer. Cathy M. Torres was employed by Washington Federal in positions which 

included a loan officer.

Beginning in at least in or around 2011 and continuing until in or around 

December 2017, at Chicago, defendant ROSALLIE C. CORVITE knowingly conspired 

in violation of Title 18, United States Code, Section 371, with Individual A, Crotty,

Torres, Mandujano, Iriondo, Robert M. Kowalski, Boguslaw Kasprowicz, Miroslaw 

Krejza, Marek Matczuk, and others: (a) to knowingly make false entries in the books, 

reports, and statements of Washington Federal, with intent to injure and defraud 

Washington Federal and to deceive the OCC and the FDIC, in violation of Title 18, 

United States Code, Section 1005; and (b) being an officer, director, agent, or 

employee of, or connected in any capacity to Washington Federal, with intent to injure 

and defraud Washington Federal, to embezzle and willfully misapply moneys, funds, 

and credits of Washington Federal and moneys, funds, assets, and securities 

intrusted to the custody and care of Washington Federal, in violation of Title 18, 

United States Code, Section 656.

For approximately seven years, ending in December 2017, CORVITE agreed 

with Individual A, Iriondo, Torres, Mandujano, and Crotty to embezzle and misapply 

money from Washington Federal, which ultimately totaled approximately $66 

million, to distribute the embezzled money to and for the benefit of Robert M. 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 4 of 23 PageID #:6023
5

Kowalski, Kasprowicz, Krejza, Matczuk, William Kowalski, and others, and to 

conceal the embezzlement by falsifying Washington Federal’s records, creating false 

documents, and providing false records and documents to the FDIC, the OCC, 

consultants and others.

Falsifying Internal Bank Records to Conceal Embezzlement

While employed at Washington Federal, CORVITE, on the instructions of 

Individual A, knowingly made and caused to be made false entries in the books, 

reports, and statements of Washington Federal, understanding that the effect of 

which would be to injure and defraud Washington Federal and to deceive the OCC 

and the FDIC as to the actual financial condition of Washington Federal, by 

materially understating the number of delinquent and nonperforming loans, and

inflating Washington Federal’s income.

Providing False Records to Consultants

CORVITE, along with Individual A and others, provided and caused to be 

provided false information to consultants regarding loans, including to Consultant A, 

whose reports were provided to the OCC during examinations, which loan 

information was false in that maturity dates of loans were altered to conceal that the 

purported loans to defendant Robert M. Kowalski and others were not performing.

As an overt act, on or about May 30, 2013, defendant ROSALLIE CORVITE 

sent and caused to be sent to Consultant A an email which falsely represented the 

maturity dates of a number of loans related to defendant Robert M. Kowalski.

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 5 of 23 PageID #:6024
6

Providing False Records to the FDIC

CORVITE, along with Individual A and others, provided and caused to be 

provided false Call Reports to the FDIC, which Call Reports included schedules that 

omitted and concealed delinquent loans, including the purported loans to defendants 

Robert M. Kowalski, Kasprowicz, Krejza, Matczuk, and William A. Kowalski, and 

others, and inflated the bank’s income.

As an overt act, on or about October 30, 2017, CORVITE filed and caused to be 

filed a Call Report with the FDIC which falsely stated on Schedule RC-N that there 

were approximately $218,000 worth of loans that were 30-89 days delinquent and no 

loans that were 90 days or more delinquent, when, as CORVITE knew, the bank had 

millions of dollars in loans that were more than 90 days delinquent.

Providing False Records to the OCC

CORVITE along with Iriondo, Mandujano, and Torres, and others, provided 

and caused to be provided false trial loan balances to the OCC, which trial loan 

balances contained false information about Washington Federal’s loans, including the 

identity of the borrower, fictitious loan balances, and payment histories, and omitted 

purported loans associated with defendants Robert M. Kowalski, Kasprowicz, Krejza, 

and Matczuk, and others.

As an overt act, in or around October 2017, CORVITE, on the instructions of 

Individual A and along with Iriondo, Torres, and Mandujano, created a false 2017 

trial loan balance purporting to be a list of all of Washington Federal’s loans and 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 6 of 23 PageID #:6025
7

provided it to the OCC. This trial loan balance contained false information about 

Washington Federal’s loans, including the identity of the borrower, loan balances, 

and payment histories, and omitted purported loans associated with Robert M. 

Kowalski, Kasprowicz, Krejza, Matczuk, and others.

Failure of Washington Federal

In or around December 2017, the OCC determined that Washington Federal 

was insolvent and that it had at least approximately $66 million in nonperforming 

loans. On or about December 15, 2017, the OCC closed Washington Federal and the 

FDIC, as a receiver, succeeded to all of Washington Federal’s interests. The FDIC 

provided approximately $90 million to make account holders whole to the extent 

allowed by law. CORVITE further acknowledges at least ten account holders who had 

deposits at Washington Federal over the FDIC insurance limit also suffered losses 

when Washington Federal failed.

7. The foregoing facts are set forth solely to assist the Court in determining 

whether a factual basis exists for defendant’s plea of guilty, and are not intended to 

be a complete or comprehensive statement of all the facts within defendant’s personal 

knowledge regarding the charged crimes and related conduct. 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 7 of 23 PageID #:6026
8

Maximum Statutory Penalties

8. Defendant understands that the charge to which she is pleading guilty 

carries the following statutory penalties: 

a. A maximum sentence of 5 years’ imprisonment. This offense also 

carries a maximum fine of $250,000, or twice the gross gain or gross loss resulting 

from that offense, whichever is greater. Defendant further understands that the 

judge also may impose a term of supervised release of not more than three years. 

b. Defendant further understands that the Court must order 

restitution to the victims of the offense in an amount determined by the Court. 

c. Pursuant to Title 18, United States Code, Section 3013, defendant 

will be assessed $100 on the charge to which she has pled guilty, in addition to any 

other penalty or restitution imposed. 

Sentencing Guidelines Calculations 

9. Defendant understands that in determining a sentence, the Court is 

obligated to calculate the applicable Sentencing Guidelines range, and to consider 

that range, possible departures under the Sentencing Guidelines, and other 

sentencing factors under 18 U.S.C. § 3553(a), which include: (i) the nature and 

circumstances of the offense and the history and characteristics of the defendant; (ii) 

the need for the sentence imposed to reflect the seriousness of the offense, promote 

respect for the law, provide just punishment for the offense, afford adequate 

deterrence to criminal conduct, protect the public from further crimes of the 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 8 of 23 PageID #:6027
9

defendant, and provide the defendant with needed educational or vocational training, 

medical care, or other correctional treatment in the most effective manner; (iii) the 

kinds of sentences available; (iv) the need to avoid unwarranted sentence disparities 

among defendants with similar records who have been found guilty of similar 

conduct; and (v) the need to provide restitution to any victim of the offense.

10. For purposes of calculating the Sentencing Guidelines, the parties agree 

on the following points: 

a. Applicable Guidelines. The Sentencing Guidelines to be 

considered in this case are those in effect at the time of sentencing. The following 

statements regarding the calculation of the Sentencing Guidelines are based on the 

November 2021 Guidelines Manual.

b. Offense Level Calculations.

i. The base offense level, pursuant to Guideline §§ 2B1.1(a)(1) 

and 2X1.1, is 7. 

ii. Pursuant to Guideline § 2B1.1(b)(1)(M), the offense level is 

increased by 24 levels because the loss is between $65 million and $150 million. 

iii. Pursuant to Guideline § 2B1.1(b)(2)(A)(i), the offense level 

is increased by 2 levels because the offense involved ten or more victims. 

iv. Pursuant to Guideline § 2B1.1(b)(10)(C), the offense level 

is increased by 2 levels because the offense involved sophisticated means and 

defendant engaged in conduct constituting sophisticated means.

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 9 of 23 PageID #:6028
10

v. Pursuant to Guideline § 2B1.1(b)(17)(B)(i), the offense level 

is increased by 4 levels because the offense substantially jeopardized the safety and 

soundness of a financial institution.

vi. Pursuant to Guideline § 3B1.3, the offense level is 

increased by 2 levels because defendant abused a position of trust with Washington 

Federal.

vii. Defendant has clearly demonstrated a recognition and 

affirmative acceptance of personal responsibility for her criminal conduct. If the

government does not receive additional evidence in conflict with this provision, and 

if defendant continues to accept responsibility for her actions within the meaning of 

Guideline § 3E1.1(a), including by furnishing the United States Attorney’s Office and 

the Probation Office with all requested financial information relevant to her ability 

to satisfy any fine or restitution that may be imposed in this case, a two-level 

reduction in the offense level is appropriate. 

viii. In accord with Guideline § 3E1.1(b), defendant has timely 

notified the government of her intention to enter a plea of guilty, thereby permitting 

the government to avoid preparing for trial and permitting the Court to allocate its 

resources efficiently. Therefore, as provided by Guideline § 3E1.1(b), if the Court 

determines the offense level to be 16 or greater prior to determining that defendant 

is entitled to a two-level reduction for acceptance of responsibility, the government 

will move for an additional one-level reduction in the offense level. 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 10 of 23 PageID #:6029
11

c. Criminal History Category. With regard to determining 

defendant’s criminal history points and criminal history category, based on the facts 

now known to the government, defendant’s criminal history points equal zero and 

defendant’s criminal history category is I.

d. Anticipated Advisory Sentencing Guidelines Range. 

Therefore, based on the facts now known to the government, the government 

anticipates that the total offense level is 38. When combined with the anticipated 

criminal history category of I, the anticipated advisory Sentencing Guidelines range 

is 235-293 months’ imprisonment, in addition to any supervised release, fine, and 

restitution the Court may impose. However, pursuant to Guideline § 5G1.1(a), when 

the statutory maximum sentence is less than the minimum of the applicable 

Guidelines range, the statutory maximum sentence shall be the Guideline sentence. 

Therefore, the advisory Guideline sentence is 60 months’ incarceration.

e. Defendant and her attorney and the government acknowledge 

that the above guidelines calculations are preliminary in nature and based on facts 

known to the parties as of the time of this Agreement. Defendant understands that 

the Probation Office will conduct its own investigation and that the Court ultimately 

determines the facts and law relevant to sentencing, and that the Court’s 

determinations govern the final guidelines calculation. Accordingly, the validity of 

this Agreement is not contingent upon the probation officer’s or the Court’s 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 11 of 23 PageID #:6030
12

concurrence with the above calculations, and defendant shall not have a right to 

withdraw her plea on the basis of the Court’s rejection of these calculations.

f. Both parties expressly acknowledge that this Agreement is not 

governed by Fed. R. Crim. P. 11(c)(1)(B), and that errors in applying or interpreting 

any of the sentencing guidelines may be corrected by either party prior to sentencing. 

The parties may correct these errors either by stipulation or by a statement to the 

Probation Office or the Court, setting forth the disagreement regarding the applicable 

provisions of the guidelines. The validity of this Agreement will not be affected by 

such corrections, and defendant shall not have a right to withdraw her plea, nor the 

government the right to vacate this Agreement, on the basis of such corrections.

Cooperation

11. Defendant agrees she will fully and truthfully cooperate in any matter 

in which she is called upon to cooperate by a representative of the United States 

Attorney’s Office for the Northern District of Illinois. This cooperation shall include 

providing complete and truthful information in any investigation and pre-trial 

preparation and complete and truthful testimony in any criminal, civil, or 

administrative proceeding. Defendant agrees to the postponement of her sentencing 

until after the conclusion of her cooperation. 

Agreements Relating to Sentencing

12. At the time of sentencing, the government shall make known to the 

sentencing judge the extent of defendant’s cooperation. If the government determines 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 12 of 23 PageID #:6031
13

that defendant has continued to provide full and truthful cooperation as required by 

this Agreement, then the government shall move the Court, pursuant to Guideline 

' 5K1.1, to depart downward and impose a sentence below the applicable Guideline 

sentence, in an amount to be determined at sentencing. Defendant shall be free to 

recommend any sentence. Defendant understands that the decision to depart from 

the applicable guideline sentence rests solely with the Court. 

13. If the government does not move the Court, pursuant to Guideline 

§ 5K1.1, to depart from the applicable guideline sentence, as set forth above, the 

preceding paragraph of this Agreement will be inoperative, both parties shall be free 

to recommend any sentence, and the Court shall impose a sentence taking into 

consideration the factors set forth in 18 U.S.C. § 3553(a) as well as the Sentencing 

Guidelines without any downward departure for cooperation pursuant to § 5K1.1. 

Defendant may not withdraw her plea of guilty because the government has failed to 

make a motion pursuant to Guideline § 5K1.1. 

14. It is understood by the parties that the sentencing judge is neither a 

party to nor bound by this Agreement and may impose a sentence up to the maximum 

penalties as set forth above. Defendant further acknowledges that if the Court does 

not accept the sentencing recommendation of the parties, defendant will have no right 

to withdraw her guilty plea. 

15. Regarding restitution, defendant acknowledges that she is obligated to 

pay restitution to victims in an amount to be ordered by the Court, minus any credit 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 13 of 23 PageID #:6032
14

for funds repaid prior to sentencing, and that pursuant to Title 18, United States 

Code, Section 3663A, the Court must order defendant, together with any jointly liable 

co-defendants, to make full restitution in the amount outstanding at the time of 

sentencing. Defendant reserves the right to argue that restitution should be 

apportioned, pursuant to Title 18, United States Code, Section 3664(h).

16. Restitution shall be due immediately, and paid pursuant to a schedule 

to be set by the Court at sentencing. Defendant acknowledges that pursuant to Title 

18, United States Code, Section 3664(k), she is required to notify the Court and the 

United States Attorney=s Office of any material change in economic circumstances 

that might affect her ability to pay restitution. 

17. Defendant agrees to pay the special assessment of $100 at the time of 

sentencing with a cashier’s check or money order payable to the Clerk of the U.S. 

District Court. 

18. Defendant agrees that the United States may enforce collection of any 

fine or restitution imposed in this case pursuant to Title 18, United States Code, 

Sections 3572, 3613, and 3664(m), notwithstanding any payment schedule set by the 

Court. 

19. After sentence has been imposed on the count to which defendant pleads 

guilty as agreed herein, the government will move to dismiss the remaining counts of 

the fourth superseding indictment and its forfeiture allegation, as well as the third 

and second superseding indictment, as to defendant. 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 14 of 23 PageID #:6033
15

Acknowledgments and Waivers Regarding Plea of Guilty

Nature of Agreement

20. This Agreement is entirely voluntary and represents the entire 

agreement between the United States Attorney and defendant regarding defendant’s 

criminal liability in case 19 CR 226-3. 

21. This Agreement concerns criminal liability only. Except as expressly set 

forth in this Agreement, nothing herein shall constitute a limitation, waiver, or 

release by the United States or any of its agencies of any administrative or judicial 

civil claim, demand, or cause of action it may have against defendant or any other 

person or entity. The obligations of this Agreement are limited to the United States 

Attorney’s Office for the Northern District of Illinois and cannot bind any other 

federal, state, or local prosecuting, administrative, or regulatory authorities, except 

as expressly set forth in this Agreement. 

Waiver of Rights 

22. Defendant understands that by pleading guilty she surrenders certain 

rights, including the following:

a. Trial rights. Defendant has the right to persist in a plea of not 

guilty to the charges against her, and if she does, she would have the right to a public 

and speedy trial.

i. The trial could be either a jury trial or a trial by the judge 

sitting without a jury. However, in order that the trial be conducted by the judge 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 15 of 23 PageID #:6034
16

sitting without a jury, defendant, the government, and the judge all must agree that 

the trial be conducted by the judge without a jury.

ii. If the trial is a jury trial, the jury would be composed of 

twelve citizens from the district, selected at random. Defendant and her attorney 

would participate in choosing the jury by requesting that the Court remove 

prospective jurors for cause where actual bias or other disqualification is shown, or 

by removing prospective jurors without cause by exercising peremptory challenges.

iii. If the trial is a jury trial, the jury would be instructed that 

defendant is presumed innocent, that the government has the burden of proving 

defendant guilty beyond a reasonable doubt, and that the jury could not convict her 

unless, after hearing all the evidence, it was persuaded of her guilt beyond a 

reasonable doubt and that it was to consider each count of the fourth superseding 

indictment separately. The jury would have to agree unanimously as to each count 

before it could return a verdict of guilty or not guilty as to that count.

iv. If the trial is held by the judge without a jury, the judge 

would find the facts and determine, after hearing all the evidence, and considering 

each count separately, whether or not the judge was persuaded that the government 

had established defendant’s guilt beyond a reasonable doubt.

v. At a trial, whether by a jury or a judge, the government 

would be required to present its witnesses and other evidence against defendant. 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 16 of 23 PageID #:6035
17

Defendant would be able to confront those government witnesses and her attorney 

would be able to cross-examine them.

vi. At a trial, defendant could present witnesses and other 

evidence in her own behalf. If the witnesses for defendant would not appear 

voluntarily, she could require their attendance through the subpoena power of the 

Court. A defendant is not required to present any evidence.

vii. At a trial, defendant would have a privilege against selfincrimination so that she could decline to testify, and no inference of guilt could be 

drawn from her refusal to testify. If defendant desired to do so, she could testify in 

her own behalf.

b. Waiver of appellate and collateral rights. Defendant further 

understands she is waiving all appellate issues that might have been available if she 

had exercised her right to trial. Defendant is aware that Title 28, United States Code, 

Section 1291, and Title 18, United States Code, Section 3742, afford a defendant the 

right to appeal her conviction and the sentence imposed. Acknowledging this, if the 

government makes a motion at sentencing for a downward departure pursuant to 

Guideline § 5K1.1, defendant knowingly waives the right to appeal her conviction, 

any pre-trial rulings by the Court, and any part of the sentence (or the manner in 

which that sentence was determined), including any term of imprisonment and fine 

within the maximums provided by law, and including any order of restitution, in 

exchange for the concessions made by the United States in this Agreement. In 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 17 of 23 PageID #:6036
18

addition, if the government makes a motion at sentencing for a downward departure 

pursuant to Guideline § 5K1.1, defendant also waives her right to challenge her 

conviction and sentence, and the manner in which the sentence was determined, in 

any collateral attack or future challenge, including but not limited to a motion 

brought under Title 28, United States Code, Section 2255. The waiver in this 

paragraph does not apply to a claim of involuntariness or ineffective assistance of 

counsel, nor does it prohibit defendant from seeking a reduction of sentence based 

directly on a change in the law that is applicable to defendant and that, prior to the 

filing of defendant’s request for relief, has been expressly made retroactive by an Act 

of Congress, the Supreme Court, or the United States Sentencing Commission. 

23. Defendant understands that by pleading guilty she is waiving all the 

rights set forth in the prior paragraphs. Defendant’s attorney has explained those 

rights to her, and the consequences of her waiver of those rights. 

Presentence Investigation Report/Post-Sentence Supervision 

24. Defendant understands that the United States Attorney’s Office in its 

submission to the Probation Office as part of the Pre-Sentence Report and at 

sentencing shall fully apprise the District Court and the Probation Office of the 

nature, scope, and extent of defendant’s conduct regarding the charges against her, 

and related matters. The government will make known all matters in aggravation 

and mitigation relevant to sentencing, including the nature and extent of defendant’s 

cooperation. 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 18 of 23 PageID #:6037
19

25. Defendant agrees to truthfully and completely execute a Financial 

Statement (with supporting documentation) prior to sentencing, to be provided to and 

shared among the Court, the Probation Office, and the United States Attorney’s 

Office regarding all details of her financial circumstances, including her recent 

income tax returns as specified by the probation officer. Defendant understands that 

providing false or incomplete information, or refusing to provide this information, 

may be used as a basis for denial of a reduction for acceptance of responsibility 

pursuant to Guideline § 3E1.1 and enhancement of her sentence for obstruction of 

justice under Guideline § 3C1.1, and may be prosecuted as a violation of Title 18, 

United States Code, Section 1001 or as a contempt of the Court.

26. For the purpose of monitoring defendant’s compliance with her 

obligations to pay a fine and restitution during any term of supervised release or 

probation to which defendant is sentenced, defendant further consents to the 

disclosure by the IRS to the Probation Office and the United States Attorney’s Office 

of defendant’s individual income tax returns (together with extensions, 

correspondence, and other tax information) filed subsequent to defendant’s 

sentencing, to and including the final year of any period of supervised release or 

probation to which defendant is sentenced. Defendant also agrees that a certified copy 

of this Agreement shall be sufficient evidence of defendant=s request to the IRS to 

disclose the returns and return information, as provided for in Title 26, United States 

Code, Section 6103(b). 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 19 of 23 PageID #:6038
20

Other Terms 

27. Defendant agrees to cooperate with the United States Attorney’s Office 

in collecting any unpaid fine and restitution for which defendant is liable, including 

providing financial statements and supporting records as requested by the United 

States Attorney’s Office. 

28. Defendant will not object to a motion brought by the United States 

Attorney’s Office for the entry of an order authorizing disclosure of documents, 

testimony and related investigative materials which may constitute grand jury 

material, preliminary to or in connection with any judicial proceeding, pursuant to 

Fed. R. Crim. P. 6(e)(3)(E)(i). In addition, defendant will not object to the 

government’s solicitation of consent from third parties who provided records or other 

materials to the grand jury pursuant to grand jury subpoenas, to turn those materials 

over to the Civil Division of the United States Attorney’s Office, or an appropriate 

federal or state agency (including but not limited to the Internal Revenue Service), 

for use in civil or administrative proceedings or investigations, rather than returning 

them to the third parties for later summons or subpoena in connection with a civil or 

administrative proceeding involving, or investigation of, defendant. 

29. Defendant understands that pursuant to Title 12, United States Code, 

Sections 1785(d) and 1829, her conviction in this case will prohibit her from directly 

or indirectly participating in the affairs of any financial institution insured by the 

National Credit Union Share Insurance Fund or the Federal Deposit Insurance 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 20 of 23 PageID #:6039
21

Corporation, except with the prior written consent of the National Credit Union 

Administration Board or the FDIC and, during the ten years following her conviction, 

the additional approval of this Court. Defendant further understands that if she 

knowingly violates this prohibition, she may be punished by imprisonment for up to 

five years, and a fine of up to $1,000,000 for each day the prohibition is violated. 

30. Defendant understands that, if convicted, a defendant who is not a 

United States citizen may be removed from the United States, denied citizenship, and 

denied admission to the United States in the future. 

31. Should defendant engage in additional criminal activity after she has 

pled guilty but prior to sentencing, defendant shall be considered to have breached 

this Agreement, and the government at its option may void this Agreement. 

Conclusion 

32. Defendant understands that this Agreement will be filed with the Court, 

will become a matter of public record, and may be disclosed to any person.

33. Defendant understands that her compliance with each part of this 

Agreement extends throughout the period of her sentence, and failure to abide by any 

term of the Agreement is a violation of the Agreement. Defendant further 

understands that in the event she violates this Agreement, the government, at its 

option, may move to vacate the Agreement, rendering it null and void, and thereafter 

prosecute defendant not subject to any of the limits set forth in this Agreement, or 

may move to resentence defendant or require defendant’s specific performance of this 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 21 of 23 PageID #:6040
22

Agreement. Defendant understands and agrees that in the event that the Court 

permits defendant to withdraw from this Agreement, or defendant breaches any of 

its terms and the government elects to void the Agreement and prosecute defendant, 

any prosecutions that are not time-barred by the applicable statute of limitations on 

the date of the signing of this Agreement may be commenced against defendant in 

accordance with this paragraph, notwithstanding the expiration of the statute of 

limitations between the signing of this Agreement and the commencement of such 

prosecutions. 

34. Should the judge refuse to accept defendant’s plea of guilty, this 

Agreement shall become null and void and neither party will be bound to it. 

35. Defendant and her attorney acknowledge that no threats, promises, or 

representations have been made, nor agreements reached, other than those set forth 

in this Agreement, to cause defendant to plead guilty.

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 22 of 23 PageID #:6041
23

36. Defendant acknowledges that she has read this Agreement and carefully 

reviewed each provision with her attorney. Defendant further acknowledges that she 

understands and voluntarily accepts each and every term and condition of this 

Agreement. 

AGREED THIS DATE: _____________________

/s/ John R. Lausch, Jr., by TCM 

JOHN R. LAUSCH, JR.

United States Attorney

ROSALLIE C. CORVITE

Defendant

 

MICHELLE PETERSEN

Assistant U.S. Attorney

 

DOUGLAS WHITNEY

Attorney for Defendant

 

BRIAN P. NETOLS 

Assistant U.S. Attorney 

____________________________________ 

JEREMY DANIEL

Assistant U.S. Attorney

____________________________________ 

JEFFREY SNELL

Special Assistant U.S. Attorney

 

Case: 1:19-cr-00226 Document #: 726 Filed: 05/23/22 Page 23 of 23 PageID #:6042