Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 1 of 42

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
25-CR-20500-GAYLES/SHAW-WILDER
CASE NO.
---------
18 u.s.c. § 641
18 u.s.c. § 371
18 U.S.C. § 1001(a)(2)
18 u.s.c. § 1519
18 U.S.C. § 1956(h)
18 u.s.c. § 1957
26 u.s.c. § 7206(2)
52 U.S.C. § 30109(d)(l)(A)(i)
52 u.s.c. § 30122
18 U.S.C. § 981(a)(l)(C)
18 U.S.C. § 982(a)(l)

UNITED STATES OF AMERICA BM

vs.
Nov 19, 2025
SHEILA CHERFILUS-MCCORMICK,
EDWIN CHERFILUS,
NADEGE LEBLANC, and MIAMI
DAVID KOFI SPENCER,

Defendants.

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

INDICTMENT

The Grand Jury charges that:

GENERAL ALLEGATIONS

At all times relevant to this Indictment:

Relevant Federal Election Campaign Act Provisions

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1. The Federal Election Campaign Act of 1971, as amended, Title 52, United States

Code, Sections 30101 , et seq. ("Election Act"), limited financial influence in the election of

candidates for federal office, including for the United States Congress, and provided for public

disclosure of the financing of federal election can1paigns, as follows :

a. The Election Act limited the amount and source of money that could be

contributed to a federal candidate or that candidate's authorized campaign

committee.

b. A "straw donor" was a person who contributed to a campaign in his or her name

despite receiving an advance payment or subsequent reimbursement of all or a

part of that contribution from another source, thereby acting as an intermediary

between the true source of the contribution and the candidate or campaign that

received the contribution, which was prohibited under federal law. The Election

Act expressly stated that contributions made through an intermediary were treated

as contributions from the original payor.

c. In 2021, the Election Act prohibited both primary and general election campaign

contributions in the name of intermediaries or straw donors to any candidate. The

Election Act also prohibited any candidate, political committee, or other person

from knowingly accepting or receiving a contribution in the name of an

intermediary or straw donor.

d. In 2021, the Election Act limited both primary and general election campaign

contributions by individuals to $2,900 from any individual to any one candidate.

The Election Act also prohibited any candidate, political committee, or other

person from knowingly accepting or receiving a contribution in excess of these

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limitations.

2. The Federal Election Commission ("FEC") was an agency and department of the

United States with jurisdiction to enforce the limits and prohibitions of the Election Act, and to

compile and publicly report accurate information about the source and amounts of contributions.

3. Pursuant to the Election Act, the FEC required campaign committees, including

Sheila Cherfilus McCormick for Congress, Inc., to file periodic reports of receipts and

disbursements identifying, among other things, each person who made a contribution to such

committee during the relevant reporting period whose contribution or contributions had an

aggregate amount or value in excess of $200 within the calendar year, together with the date and

the amount of any such contribution. In preparing these reports, federal candidates and political

committees relied on the information provided by the donor, including the individual's name,

address, and occupation. These periodic reports, which were filed with the FEC and made

publicly available, were intended to provide citizens with a transparent record of contributions

to candidates for federal office.

Relevant Federal Income Tax Provisions

4. The Internal Revenue Code, Title 26, United States Code, Sections 1, et seq. ("the

Code") set forth tax laws of the United States.

5. The Internal Revenue Service ("IRS") was an agency of the United States

Department of Treasury responsible for enforcing and administering the tax laws of the United

States of America and collecting taxes owed to the United States.

6. The IRS Form 1040 was the standard form that individuals used to file their annual

federal income tax returns. This form contained sections that required taxpayers to disclose

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their financial income and losses for the year in order to ascertain whether the taxpayer was due a

tax refund or whether the taxpayer owed additional taxes.

7. The IRS Schedule C was a form for individuals who operated their own business

to complete and report profits or losses. As a general matter, a loss on a Schedule C allowed a

taxpayer to increase the amount of refund owed to the taxpayer or decrease the amount of taxes

owed to the IRS.

8. The Code permitted certain tax deductions that were incurred during the taxable

year, including those associated with ordinary and necessary business expenses and contributions

made to charity.

9. The Code did not permit a deduction for any amount paid or incurred in connection

with any political campaign, either on behalf of or in opposition to any candidate for public office,

or in connection with attempting to influence the general public, or segments thereof, with respect

to elections, legislative matters, or referenda.

10. The Code did not permit a deduction for any amount paid or incurred in connection

with personal expenses, such as jewelry purchases, clothing, and other expenses that were not

related to the functions of a business or with the ordinary and necessary expenditures of a business.

11. The IRS allowed individual taxpayers to file their tax returns electronically ("e-

file") by filing online directly or through a tax preparation business.

The Defendants and Relevant Individuals and Entities

The Defendants

12. Defendant SHEILA CHERFILUS-MCCORMICK was a politician and

businesswoman in the Southern District of Florida. CHERFILUS-MCCORMICK previously

ran two unsuccessful congressional campaigns for the seat in Florida's 20th Congressional District

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during the 2018 and 2020 federal election cycles. In or around May 2021, CHERFILUS-

MCCORMICK announced her candidacy in the 2022 special election for the 20th District after

the death of the incumbent United States Representative. On or about November 2, 2021,

CHERFILUS-MCCORMICK won her party's special primary election for the 20th District seat

and became the nominee for her party in the 2022 general election. On or about January 11 , 2022,

CHERFILUS-MCCORMICK won the special general election, and she was sworn in as the

United States Representative for Florida's 20th Congressional District on or about January 18,

2022.

13. Defendant EDWIN CHERFILUS, a resident of the Southern District of Florida,

was SHEILA CHERFILUS-MCCORMICK's brother. From at least on or about May 20, 2021,

through on or about January 11 , 2022, CHERFILUS assisted in CHERFILUS-MCCORMICK's

campaign for United States Representative in Florida's 20th Congressional District.

14. Defendant NADEGE LEBLANC, a resident of the Southern District of Florida,

was SHEILA CHERFILUS-MCCORMICK's Chief of Staff for the 20th District office.

LEBLANC also assisted CHERFILUS-MCCORMICK with her campaigns.

15. Defendant DAVID KOFI SPENCER, a resident of the Southern District of

Florida, was at all times relevant to this Indictment a resident of the Middle District of Florida, a

certified public accountant, and, from at least in or around 2020, was the owner of and chief

accountant at D.K.S. Tax and Consulting, Inc.

Relevant Individuals

16. Person 1 was a friend of SHEILA CHERFILUS-MCCORMICK, and a resident

of the Middle District of Florida.

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17. Person 2 was a relative of SHEILA CHERFILUS-MCCORMICK and EDWIN

CHERFILUS, and a resident of the District of Maryland.

18. Person 3 was a relative of SHEILA CHERFILUS-MCCORMICK and EDWIN

CHERFILUS, and a resident of the Southern District of Florida.

19. Person 4 was a relative of SHEILA CHERFILUS-MCCORMICK and EDWIN

CHERFILUS, and a resident of the Southern District of Florida.

20. Straw Donor 1 was a relative of NADEGE LEBLANC, and a resident of the

Southern District of New York.

21. Straw Donor 2 was a relative of NADEGE LEBLANC, and a resident of the

Southern District of Florida.

22. Straw Donor 3 was a relative of NADEGE LEBLANC, and a resident of the

Southern District of Florida.

23 . Straw Donor 4 was a friend of NADEGE LEBLANC, and a resident of the

Southern District of Florida.

24. Straw Donor 5 was a friend of NADEGE LEBLANC, and a resident of the

Southern District of Florida.

Relevant Entities

Government Agencies Addressing the COVID-19 Pandemic

25. On or about March 13, 2020, the President of the United States signed a national

emergency declaration pronouncing the COVID-19 pandemic as a national disaster emergency.

26. The Federal Emergency Management Agency ("FEMA") was an agency of the

executive branch of the United States. FEMA coordinated the federal response to disasters that

had received a Presidential disaster declaration through the Robert T. Stafford Disaster Relief and

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Emergency Assistance Act (the "Stafford Act"). FEMA worked closely with officials in states to

coordinate federal funds and other resources sent to states for disaster recovery. The funds

provided by FEMA to the states were funds appropriated by the Congress of the United States for

use in emergency recovery and management and, therefore, were monies of the United States of

America. FEMA was the federal agency tasked with coordinating the federal response to the

COVID-19 pandemic.

27. The Florida Division of Emergency Management ("FDEM") was an agency of the

executive branch of the State of Florida. FDEM was the agency in the State of Florida responsible

for the coordination of the State's response to disasters. FDEM was also the agency in the State

of Florida tasked with being the liaison to federal agencies, such as FEMA, during and after

disasters. FDEM was the state agency tasked with managing the federal response in Florida, in

coordination with FEMA, to the COVID-19 pandemic.

Other Relevant Entities

28. Trinity Healthcare Services, LLC ("Trinity") was a Miramar, Florida-based

healthcare company founded in 1994 and registered with the State of Florida in 2016. Trinity was

wholly owned by Person 3 and Person 4. In or around 2021 , SHEILA CHERFILUS-

MCCORMICK and EDWIN CHERFILUS were employed by Trinity. Starting from at least on

or about March 4, 2021 , CHERFILUS-MCCORMICK and CHERFILUS, through Trinity,

entered into purchase orders with FDEM to provide nurses, clerical staff, and canvassers for the

FDEM/FEMA vaccination sites. Trinity was to be paid by FDEM with federal funds provided by

FEMA for work Trinity did pursuant to these purchase orders. Bank Account 1 was opened in or

around March 2021 and was provided to FDEM as the Trinity corporate bank account to accept

payments for work done on the purchase orders.

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29. SCM Consulting Group, LLC ("SCM Consulting") was a Miramar, Florida-based

consulting company registered with the State of Florida on or about March 11, 2021 by SHEILA

CHERFILUS-MCCORMICK, and dissolved on or about November 1, 2022.

30. The EC Firm, LLC ("EC Firm") was a Miramar, Florida-based consulting company

registered with the State of Florida on or about March 10, 2021 by EDWIN CHERFILUS and

dissolved on or about September 27, 2024.

31. D.K.S. Tax and Consulting, LLC ("DKS Tax") was a Clearwater, Florida-based tax

preparation and accounting company. It was registered on or about November 10, 2020. It was

wholly owned and managed by DAVID KOFI SPENCER.

32. Sheila Cherfilus McCormick for Congress, Inc. ("SCM for Congress") was the

principal federal campaign committee formed to receive campaign contributions for the election

of SHEILA CHERFILUS-MCCORMICK. SCM for Congress was located in Miramar, Florida.

The Statement of Organization ("Statement") for SCM for Congress filed with the FEC reflected

the committee's creation date of April 25 , 2018. This Statement, originally filed April 27, 2018,

listed CHERFILUS-MCCORMICK as the Candidate, Custodian of Records, and Designated

Agent for SCM for Congress. Person 1 was listed as the committee's treasurer. SCM for Congress

continued to list Person 1 as the committee's treasurer through the special general election in 2022.

33. Between on or about April 6, 2021 , and continuing at least through the special

general election on or about January 11 , 2022, SHEILA CHERFILUS-MCCORMICK

conducted a campaign for the Office of United States Representative for Florida' s 20th

Congressional District, which was a congressional district located within the Southern District of

Florida encompassing areas of Broward and Palm Beach Counties. During this campaign,

CHERFILUS-MCCORMICK and others solicited contributions to her campaign. A primary

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election was held on or about November 2, 2021, and CHERFILUS-MCCORMICK was elected

as her party' s nominee by five votes. The special general election was held on or about January

11 , 2022, and CHERFILUS-MCCORMICK was elected as the United States Representative for

the 20th District. On or about February 10, 2022, SCM for Congress reported to the FEC that it

received approximately $134,719.87 from individual contributors and no contributions from

corporations during the special election cycle.

34. Church 1 was an independent Christian church located in Laurel, Maryland.

35. Jewelry Company 1 was a jewelry design house headquartered in New York, New

York.

36. Management Company 1 was a Delaware-based company registered in 2016,

whose managers were Person 3 and Person 4.

37. Consulting Company 1 was an Orlando, Florida-based consulting company

registered with the State of Florida in or around 2021 by Person 1 and dissolved in or around 2024.

Consulting Company 1 was owned by Person 1, who was its registered agent and manager.

38. Platform 1 was a nonprofit organization that provided an online platform to

facilitate and process contributions made through the platform to political committees.

39. Platform 2 was a digital payment network operated by a private financial services

company owned by several large United States banks. Platform 2 enabled the user to electronically

transfer money from their bank account to another registered bank account without incurring fees.

Platform 2 could be used through a mobile device or the website of a participating financial

institution.

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40. Bank 1 was a financial institution headquartered in Charlotte, North Carolina, with

locations throughout the United States, including the State of Florida, whose accounts were

federally insured by the Federal Deposit Insurance Corporation ("FDIC").

41. Bank 2 was a financial institution headquartered in Charlotte, orth Carolina, with

locations throughout the United States, including the State of Florida, whose accounts were

federally insured by the FDIC.

42. Bank 3 was a financial institution headquartered in San Francisco, California, with

locations throughout the United States, including the State of Florida, whose accounts were

federally insured by the FDIC.

43 . Bank Account 1 was a bank account, ending in 3603, opened at Bank 1 in the name

of Trinity, and located in the District of Maryland. SHEILA CHERFILUS-MCORMICK and

EDWIN CHERFILUS were authorized signers for Bank Account 1.

44. Bank Account 2 was a bank account, ending in 3689, opened at Bank 1 in the name

of SCM Consulting, and located in the District of Maryland. SHEILA CHERFILUS-

MCORMICK and EDWIN CHERFILUS were authorized signers for Bank Account 2.

45. Bank Account 3 was a bank account, ending in 3425, opened at Bank 1 in the name

of SCM for Congress, and located in the District of Maryland. SHEILA CHERFILUS-

MCORMICK and EDWIN CHERFILUS were authorized signers for Bank Account 3.

46. Bank Account 4 was a bank account, ending in 4090, opened at Bank 1 in the name

of SCM for Congress Campaign Donations, and located in the District of Maryland. SHEILA

CHERFILUS-MCORMICK and EDWIN CHERFILUS were authorized signers for Bank

Account 4.
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47. Bank Account 5 was a bank account, ending in 3328, opened at Bank 1 in the name

of EC Firm, and located in the District of Maryland. EDWIN CHERFILUS was the authorized

signer for Bank Account 5.

48. Bank Account 6 was a money market account, ending in 5786, opened at Bank 1 in

the name of SHEILA CHERFILUS-MCCORMICK and EDWIN CHERFILUS, and located

in the Southern District of Florida. CHERFILUS-MCCORMICK and CHERFILUS were the

authorized signers for Bank Account 6.

49. Bank Account 7 was a bank account, ending in 5863 , opened at Bank 1 in the name

of Consulting Company 1, and located in the Middle District of Florida. The authorized signer for

Bank Account 7 was Person 1.

50. Bank Account 8 was a bank account, ending in 4499, opened at Bank 3 in the name

of NADEGE LEBLANC, and located in the Southern District of Florida. LEBLANC was the

authorized signer for Bank Account 8.

51. Bank Account 9 was a bank account, ending in 711 7, opened at Bank 2 in the name

of Management Company 1, and located in the Southern District of Florida. Person 3 and Person

4 were the authorized signers for Bank Account 9.

COUNT 1
Conspiracy to Commit the Theft of Government Funds
(18 u.s.c. § 371)

1. Paragraphs 12 to 14, 16, 18 to 19, 25 to 30, 32 to 33 , 36 to 37, 40 to 44, 47, and 49

to 51 of the General Allegations of this Indictment are re-alleged and incorporated by reference as

though fully set forth herein.

2. From on or about July 1, 2021 , through on or about August 18, 2021 , in the

Southern District of Florida, and elsewhere, the defendants,

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SHEILA CHERFILUS-MCCORMICK and

EDWIN CHERFILUS,

did knowingly and willfully combine, conspire, confederate, and agree with each other and with

other persons known and unknown to the Grand Jury to commit an offense against the United

States, that is, to knowingly and willfully embezzle, steal, purloin, and convert to their own use

money and a thing of value of the United States and of any department and agency thereof, that is,

FEMA, the aggregate value of which exceeded $1,000, that is, approximately $5,007,271.50 in

United States currency and coin, to which the defendants were not entitled, in violation of Title

18, United States Code, Section 641.

PURPOSE OF THE CONSPIRACY

3. It was the purpose of the conspiracy for the defendants and their co-conspirators to

unjustly enrich SHEILA CHERFILUS-MCCORMICK, EDWIN CHERFILUS, and others by

keeping and transferring funds that the conspirators knew were not owed to Trinity and that FDEM

had mistakenly transferred to Bank Account 1, to further transfer the stolen and converted funds

into other bank accounts controlled by CHERFILUS-MCCORMICK, CHERFILUS, and

others, and to use the stolen and conve1ied funds for the personal benefit of the conspirators and

to fund CHERFILUS-MCCORMICK's campaign committee, SCM for Congress.

MANNER AND MEANS OF THE CONSPIRACY

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

accomplish the purpose of the conspiracy included, among other things, the following:

4. On or about July 1, 2021 , the State of Florida deposited into Bank Account 1

$5,240,472.06 of Federal funds as payment for four invoices. EDWIN CHERFILUS submitted

one of the four invoices to FDEM on or about May 14, 2021 ("May 14, 2021 invoice") and

requested payment of approximately $50,578.50 for work done in Jacksonville, Florida pursuant

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to Trinity's purchase order with FDEM. The July 1, 2021 payment included a payment of

$5 ,057,850.00 for Trinity' s May 14, 2021 invoice. This payment exceeded the amount requested

on the May 14, 2021 invoice by $5,007,271.50 and was the result of a clerical error by FDEM.

5. Starting upon Trinity's receipt of that overpayment on July 1, 202 1, SHEILA

CHERFILUS-MCCORMICK and EDWIN CHERFILUS retained the $5,007,271.50 that was

mistakenly deposited into Bank Account 1, which they controlled, with the intent to keep the stolen

funds and convert the funds for their own use and for the benefit of CHERFILUS-

MCCORMICK, her election campaign committee, SCM for Congress, and others.

6. SHEILA CHERFILUS-MCCORMICK and EDWIN CHERFILUS falsely and

fraudulently converted the $5,007,271.50 in mistakenly overpaid Federal funds and caused the

$5,007,271.50 to be withdrawn, through wire transfers and personal checks, into accounts

controlled by CHERFILUS-MCCORMICK, CHERFILUS, and others.

7. SHEILA CHERFILUS-MCCORMICK and EDWIN CHERFILUS intended to

use, and did use, the stolen and converted $5,007,271.50 for their own personal use and benefit,

and the use and benefit of others, and to fund CHERFILUS-MCCORMICK's federal campaign

committee, SCM for Congress, when CHERFILUS-MCCORMICK was a candidate for United

States Representative in the special elections in Florida's 20th Congressional District.

OVERT ACTS

In furtherance of the conspiracy, and to accomplish the purpose thereof, at least one of the

co-conspirators committed and caused to be committed, in the Southern District of Florida, and

elsewhere, at least one of the following overt acts, amongst others:

1. On or about July 1, 2021, after the State of Florida mistakenly deposited into Bank

Account 1 $5 ,240,472.06 of Federal funds for the payment of four invoices submitted by Trinity,

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resulting in a $5,007,271.50 overpayment of funds for the May 14, 2021 invoice, SHEILA

CHERFILUS-MCCORMICK sent EDWIN CHERFILUS a text message of a screenshot of

Bank Account 1's account activity, depicting the deposit that included the $5,007,271.50

overpayment of funds.

2. Starting from at least on or about July 1, 2021 , SHEILA CHERFILUS-

MCCORMICK and EDWIN CHERFILUS retained the $5,007,271.50 in mistakenly overpaid

Federal funds and did not return them to the State of Florida.

3. On or about August 11 , 2021 , SHEILA CHERFILUS-MCCORMICK and

EDWIN CHERFILUS caused a deposit of approximately $2,400,936.96 into SCM Consulting's

bank account, Bank Account 2, by a check drawn from Bank Account 1.

4. On or about August 11 , 2021, SHEILA CHERFILUS-MCCORMICK and

EDWIN CHERFILUS caused a deposit of approximately $190,894.91 into EC Firm' s bank

account, Bank Account 5, by a check drawn from Bank Account 1.

5. On or about August 12, 2021, SHEILA CHERFILUS-MCCORMICK and

EDWIN CHERFILUS caused a transfer of approximately $1,249,333 .68 from Bank Account 1

to Management Company 1's bank account, Bank Account 9.

6. On or about August 16, 2021 , SHEILA CHERFILUS-MCCORMICK and

EDWIN CHERFILUS caused a transfer of approximately $830,708 .93 from Bank Account 1 to

Consulting Company 1's bank account, Bank Account 7.

7. On or about August 18, 2021, SHEILA CHERFILUS-MCCORMICK and

EDWIN CHERFILUS caused a deposit of approximately $334,757.78 into NADEGE

LEBLANC's bank account, Bank Account 8, by a check drawn from Bank Account 1.

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

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COUNT2
Theft of Government Funds
(18 u.s.c. § 641)

1. Paragraphs 12 to 14, 16, 18 to 19, 25 to 30, 32 to 33 , 36 to 37, 40 to 44, 47, and 49

to 51 of the General Allegations of this Indictment are re-alleged and incorporated by reference as

though fully set forth herein.

2. From on or about August 11 , 2021 , through on or about August 18, 2021 , in the

Southern District of Florida, and elsewhere, the defendants,

SHEILA CHERFILUS-MCCORMICK and

EDWIN CHERFILUS,

did knowingly and willfully embezzle, steal, purloin, and convert to their own use money and a

thing of value of the United States and of any department and agency thereof, that is, FEMA, the

aggregate value of which exceeded $1 ,000, that is, $5 ,007,271.50, to which the defendants were

not entitled, in violation of Title 18, United States Code, Sections 641 and 2.

COUNT3
Conspiracy to Commit Money Laundering
(18 U.S.C. § 1956(h))

1. Paragraphs 12 to 13, 29, 32 to 33, 35, 40, 44 to 46, and 48 of the General Allegations

of this Indictment are re-alleged and incorporated by reference as though fully set forth herein.

2. From on or about August 19, 2021 , and continuing through on or about October 8,

2021 , in the Southern District of Florida, and elsewhere, the defendants,

SHEILA CHERFILUS-MCCORMICK and

EDWIN CHERFILUS,

did knowingly and voluntarily combine, conspire, confederate, and agree with each other and with

other persons known and unknown to the Grand Jury to commit an offense under Title 18, United

States Code, Section 1957, that is, to knowingly engage in monetary transactions affecting

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interstate commerce, by, through, and to a financial institution, in criminally derived property of a

value greater than $10,000, such property having been derived from a specified unlawful activity,

and knowing that the property involved in the monetary transactions represented the proceeds of

some form of unlawful activity, in violation of Title 18, United States Code, Section 1957.

It is further alleged that the specified unlawful activity was the theft of government funds,

in violation of Title 18, United States Code, Section 641.

All in violation of Title 18, United States Code, Section 1956(h).

COUNTS 4-11
Money Laundering
(18 u.s.c. § 1957)

1. Paragraphs 12 to 13, 29, 32 to 33 , 35, 40, 44 to 46, and 48 of the General Allegations

of this Indictment are re-alleged and incorporated by reference as though fully set forth herein.

2. On or about the dates set forth in each Count below, in the Southern District of

Florida, and elsewhere, the defendants,

SHEILA CHERFILUS-MCCORMICK and

EDWIN CHERFILUS,

did knowingly engage in, and aid and abet, and cause others to engage in, and attempt to engage

in, monetary transactions affecting interstate commerce, by, through, and to a financial institution,

in criminally derived property of a value greater than $10,000, such property having been derived

from a specified unlawful activity, and knowing that the property involved in the monetary

transactions represented the proceeds of some form of unlawful activity, as more particularly

described in each count below:

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Count Description of Transaction

Approximate Date
Transfer of approximately $1 ,000,000
from Bank Account 2 to Bank Account 6
4 in the Southern District of Florida for the
August 31 , 2021
benefit of SHEILA CHERFILUS-
MCCORMICK and EDWIN
CHERFILUS.
Payment of approximately $109,000 by
cashier's check from Bank Account 6 in
the Southern District of Florida to Jewelry
5 September 1, 2021 Company 1, in the Southern District of
New York, for the purchase of a ring for
the benefit of SHEILA CHERFILUS-
MCCORMICK.
Transfer of approximately $800,000 from
Bank Account 2 to Bank Account 6 in the
Southern District of Florida for the benefit
6 September 3, 2021
of SHEILA CHERFILUS-
MCCORMICK and EDWIN
CHERFILUS.
Transfer of approximately $100,000 from
7 Bank Account 6 in the Southern District
September 15, 2021
of Florida to Bank Account 3 for the
benefit of SCM for Congress.
Transfer of approximately $60,000 from
Bank Account 6 in the Southern District
8 September 23 , 2021
of Florida to Bank Account 3 for the
benefit of SCM for Congress.
Transfer of approximately $40,000 from
9 September 27, 2021 Bank Account 6 in the Southern District
of Florida to Bank Account 3 for the
benefit of SCM for Congress.
Transfer of approximately $800,000 from
Bank Account 6 in the Southern District
10 September 29, 2021 of Florida to Bank Account 4 for the
benefit of SCM for Congress Campaign
Donations.
Transfer of approximately $140,000 from
11 October 8, 2021 Bank Account 6 in the Southern District
of Florida to Bank Account 3 for the
benefit of SCM for Congress.

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It is further alleged that the specified unlawful activity was the theft of government funds,

in violation of Title 18, United States Code, Section 641.

In violation of Title 18, United States Code, Sections 1957 and 2.

COUNT 12
Conspiracy to Make and Receive Straw Donor Contributions
(18 u.s.c. § 371)

1. Paragraphs 1 to 3, 12, 14, 17, 20 to 24, 28, 32 to 33, 38 to 39, 40, and 43 of the

General Allegations of this Indictment are re-alleged and incorporated by reference as though fully

set forth herein.

2. Beginning in or around June 2021 , until in or around August 2021 , in the Southern

District of Florida, and elsewhere, the defendants,

SHEILA CHERFILUS-MCCORMICK and

NADEGE LEBLANC,

did knowingly and willfully combine, conspire, confederate, and agree with each other and with

other persons known and unknown to the Grand Jury to commit an offense against the United

States, that is, to knowingly and willfully make contributions in the names of other persons who

were not the true source of the contributions and caused contributions to be made in the names of

other persons who were not the true source of the contributions, and willfully accepted those

contributions, aggregating $25,000 or more during the 2021 calendar year, that is, contributions to

SCM for Congress, in connection with a primary election held to select candidates for a United

States Representative, in violation of Title 52, United States Code, Section 30122.

PURPOSE OF THE CONSPIRACY

3. The purpose of the conspiracy was to facilitate and cause unlawful and unreported

straw donor contributions from Trinity, through straw donors, to the SCM for Congress campaign

in order to disguise the fact that Trinity was the true source of the funds that SHEILA

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Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 19 of 42

CHERFILUS-MCCORMICK and NADEGE LEBLANC caused to be contributed to SCM for

Congress.

MANNER AND MEANS OF THE CONSPIRACY

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

accomplish the purpose of the conspiracy included, among other things, the following:

4. In or around June 2021 , SHEILA CHERFILUS-MCCORMICK began soliciting

friends and family to contribute funds to SCM for Congress before the committee' s report detailing

contributions covering the period of April 1, 2021 , through June 30, 2021 , was due to be filed with

the FEC. To facilitate friends and family contributing money to SCM for Congress,

CHERFILUS-MCCORMICK caused funds from Bank Account 1 to be provided to friends and

family to contribute.

5. On or about June 25, 2021 , SHEILA CHERFILUS-MCCORMICK, through

Bank Account 1, sent Person 2 approximately $50,000 via wire transfer, part of which Person 2

then withdrew in cash and gave to NADEGE LEBLANC.

6. NADEGE LEBLANC then gave two payments of $2,900 to SCM for Congress

via personal check. SCM for Congress then falsely reported to the FEC that LEBLANC was the

source of the contributions sent to SCM for Congress.

7. Between on or about June 28, 2021, and on or about June 30, 2021, NADEGE

LEBLANC contacted her friends and family members- Straw Donor 1, Straw Donor 2, Straw

Donor 3, Straw Donor 4, and Straw Donor 5 (collectively, the "Straw Donors")- and asked them

to make contributions, either online or by check, to SCM for Congress using money she would

send to them. LEBLANC also sent the internet link to SCM for Congress' s donation page on

Platform 1 to facilitate some of the online contributions.

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Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 20 of 42

8. Between on or about June 28, 2021 , and on or about June 30, 2021, NADEGE

LEBLANC sent the Straw Donors money from the funds given to her by Person 2 to cause the

Straw Donors to contribute those funds to SCM for Congress.

9. Between on or about June 28, 2021 , and on or about June 30, 2021 , the Straw

Donors made contributions to SCM for Congress, either online or by check, in amounts that

NADEGE LEBLANC supplied to them using the money sent by SHEILA CHERFILUS-

MCCORMICK through Person 2. SCM for Congress then falsely reported to the FEC that the

Straw Donors were the sources of the contributions sent to SCM for Congress.

10. On or about June 30, 2021 , Person 2 made two contributions to SCM for Congress

in the amounts of approximately $2,800 and $2,500. SCM for Congress then falsely reported to

the FEC that Person 2 was the source of the contributions sent to SCM for Congress.

11. By causing NADEGE LEBLANC, Person 2, and the Straw Donors to fraudulently

contribute money to SCM for Congress in their names, knowing those persons were not the true

sources of the contributions, SHEILA CHERFILUS-MCCORMICK and LEBLANC hid the

true source of the contributions to disguise the fact that Trinity was the true source of the funds

contributed for CHERFILUS-MCCORMICK's benefit in the 2021 special primary election.

OVERT ACTS

In furtherance of the conspiracy, and to accomplish the purpose thereof, at least one of the

co-conspirators committed and caused to be committed, in the Southern District of Florida, and

elsewhere, at least one of the following overt acts, amongst others:

1. On or about June 25, 2021 , SHEILA CHERFILUS-MCCORMICK sent a text

message to Person 2 with a list of people, including Person 2, NADEGE LEBLANC, and Straw

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Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 21 of 42

Donor 1, with amounts listed next to each person's name. During the text message exchange,

Person 2 sent a text message to CHERFILUS-MCCORMICK stating, "At the bank now."

2. On or about June 25 , 2021, SHEILA CHERFILUS-MCCORMICK, through

Bank Account 1, sent approximately $50,000 to Person 2's bank account.

3. On or about June 25, 2021, Person 2 withdrew approximately $30,000 in cash from

her bank account.

4. On or about June 25, 2021, NADEGE LEBLANC made two payments of

approximately $2,900 to SCM for Congress via personal check using money provided by SHEILA

CHERFILUS-MCCORMICK through Person 2. SCM for Congress then falsely reported to the

FEC that LEBLANC was the source of the contributions sent to SCM for Congress.

5. On or about June 28, 2021, Person 2 withdrew an additional approximately $6,000

in cash from her bank account.

6. On or about June 28, 2021, SHEILA CHERFILUS-MCCORMICK requested

Person 1 to contribute money to SCM for Congress via text. When Person 1 asked in the text chat

what the maximum contribution was, CHERFILUS-MCCORMICK responded, "The max is 2

checks of 2900. That is why [Person 2] had to give money to Nadege [NADEGE LEBLANC]

for her to make another donation."

7. On or about June 29, 2021, Person 2 withdrew from her bank account in cash the

remaining approximately $14,000 of the money sent by SHEILA CHERFILUS-MCCORMICK

on or about June 25, 2021.

8. On or about June 30, 2021, Person 2 gave approximately $2,800 and $2,500 via

personal check and Platform 1, respectively, to SCM for Congress using money provided by

21
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 22 of 42

SHEILA CHERFILUS-MCCORMICK. SCM for Congress then falsely reported to the FEC

that Person 2 was the source of the contributions sent to SCM for Congress.

Straw Donor 1

9. On or about June 30, 2021 , a relative of NADEGE LEBLANC sent Straw Donor

1 a wire transfer of approximately $5,775 after Straw Donor 1 gave two personal checks for

approximately for $2,900 to SCM for Congress on or about June 25, 2021 , and on or about June

30, 2021. The wire transfer was originally for approximately $5 ,800 but a $25 bank fee was

deducted from it before its receipt by Straw Donor 1. SCM for Congress then falsely reported to

the FEC that Straw Donor 1 was the source of the contributions sent to SCM for Congress.

Straw Donor 2

10. On or about June 29, 2021 , after Straw Donor 2 gave approximately $500 to SCM

for Congress via personal check, NADEGE LEBLANC sent Straw Donor 2 a transfer of

approximately $500 via Platform 2. SCM for Congress then falsely reported to the FEC that Straw

Donor 2 was the source of the contributions sent to SCM for Congress.

Straw Donor 3

11. On or about June 30, 2021, NADEGE LEBLANC texted Straw Donor 3. In her

text, LEBLANC told Straw Donor 3, "I just sent you $500. Please donate to the campaign."

LEBLANC then sent Straw Donor 3 a link to SCM for Congress's page on Platform 1 via text.

12. On or about June 30, 2021 , NADEGE LEBLANC sent Straw Donor 3 a transfer

of approximately $500 via Platform 2, which caused Straw Donor 3 to give approximately $500

to SCM for Congress via SCM for Congress's page on Platform 1. SCM for Congress then falsely

reported to the FEC that Straw Donor 3 was the source of the contributions sent to SCM for

Congress.

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Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 23 of 42

Straw Donor 4

13. At some time prior to on or about June 29, 2021 , NADEGE LEBLANC had asked

Straw Donor 4 to give money to SCM for Congress.

14. After Straw Donor 4 agreed to give money to SCM for Congress, on or about June

29, 2021 , NADEGE LEBLANC gave Straw Donor 4 approximately $5,800 in cash, which Straw

Donor 4 deposited into her bank account and caused Straw Donor 4 to give two personal checks

for approximately for $2,900 each to SCM for Congress on or about June 29, 2021 , and on or about

June 30, 2021. SCM for Congress then falsely reported to the FEC that Straw Donor 4 was the

source of the contributions sent to SCM for Congress.

Straw Donor 5

15. On or about June 25 , 2021 , NADEGE LEBLANC texted Straw Donor 5, " [Straw

Donor 5], I need a favor. If I give you $5 ,800 in cash, can you write me two checks for $2,900?"

Straw Donor 5 agreed to do so.

16. After Straw Donor 5 gave two personal checks for approximately $2,900 each to

SCM for Congress on or about June 29, 2021 , NADEGE LEBLANC gave Straw Donor 5

approximately $5 ,800 in cash. SCM for Congress then falsely reported to the FEC that Straw

Donor 5 was the source of the contributions sent to SCM for Congress.

The June 29th and June 30th Text Messages

17. On or about June 29, 2021 , NADEGE LEBLANC sent via text message to

SHEILA CHERFILUS-MCCORMICK a photograph of the personal check from Straw Donor

2 for approximately $500 to SCM for Congress made on or about June 29, 2021.

23
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 24 of 42

18. On or about June 29, 2021, NADEGE LEBLANC sent via text message to

SHEILA CHERFILUS-MCCORMICK a photograph of the two personal checks from Straw

Donor 5 for approximately $2,900 each to SCM for Congress made on or about June 29, 2021.

19. On or about June 29, 2021, NADEGE LEBLANC sent two text messages to

SHEILA CHEFILUS-MCCORMICK that stated, "[Straw Donor 4] is dropping hers off tonight"

and "And [Straw Donor 3] will have to pay online cause I have no way to get a check to her."

20. On or about June 30, 2021, NADEGE LEBLANC sent via text message to

SHEILA CHERFILUS-MCCORMICK a photograph of the two personal checks from Straw

Donor 4 for approximately $2,900 each to SCM for Congress made on or about June 29, 202 1,

and on or about June 30, 2021.

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

COUNT 13
Making and Receiving Straw Donor Contributions
(52 U.S.C. §§ 30122 and 30109(d)(l)(A)(i))

1. Paragraphs 1 to 3, 12, 14, 17, 20 to 24, 28, 32 to 33, 38 to 39, 40, and 43 of the

General Allegations of this Indictment are re-alleged and incorporated by reference as though fully

set forth herein.

2. Between in or around June 2021, and in or around August 2021, in the Southern

District of Florida, and elsewhere, the defendants,

SHEILA CHERFILUS-MCCORMICK and

NADEGE LEBLANC,

did knowingly and willfully make contributions in the names of other persons who were not the

true source of the contributions and cause contributions to be made in the names of other persons

who were not the true sources of the contributions, and willfully accepted those contributions,

aggregating $25 ,000 or more during the 202 1 calendar year, that is, contributions to SCM for
24
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 25 of 42

Congress, in connection with a primary and a general election held to select candidates for a United

States Representative, in violation of Title 52, United States Code, Sections 30122 and

30109(d)(l )(A)(i), and Title 18, United States Code, Section 2.

COUNT 14
Conspiracy to Make a False and Fraudulent Statement on a Tax Return
(18 u.s.c. § 371)

1. Paragraphs 4 to 12, 15, 29, 31 , and 34 of the General Allegations of this Indictment

are re-alleged and incorporated by reference as though fully set forth herein.

2. From at least on or about March 9, 2022, through on or about August 21 , 2023 , in

the Southern District of Florida, in the country of Barbados, and elsewhere, the defendants,

SHEILA CHERFILUS-MCCORMICK and

DAVID KOFI SPENCER,

did knowingly and willfully combine, conspire, confederate, and agree with each other and with

other persons known and unknown to the Grand Jury to commit an offense against the United

States, that is, to willfully aid and assist in, and procure, counsel, and advise the preparation and

presentation to the IRS, of a personal tax return, Form 1040, of SHEILA CHERFILUS-

MCCORMICK for the calendar year 2021 , which was false and fraudulent as to a material matter,

in that Line 28 of Schedule C "Total Expenses" included $4,620,055 worth of business expenses

associated with SCM Consulting, and Line 11 of Schedule A included $1,200,000 in charitable

contributions by CHERFILUS-MCCORMICK in 2021 , whereas, as the defendants then and

there knew, in 2021 , SCM Consulting did not have $4,620,055 of total qualifying business

expenses, and CHERFILUS-MCCORMICK did not make $1 ,200,000 in charitable

contributions, in violation of Title 26, United States Code, Section 7206(2).

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Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 26 of 42

PURPOSE OF THE CONSPIRACY

3. It was the purpose of the conspiracy for the defendants and their co-conspirators to

unjustly enrich SHEILA CHERFILUS-MCCORMICK by falsely representing her total taxable

income for calendar 2021 in order to reduce the tax liability owed by CHERFILUS-

MCCORMICK to the IRS for tax year 2021.

MANNER AND MEANS OF THE CONSPIRACY

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

accomplish the purpose of the conspiracy included, amongst other things, the following :

4. In or around March 2022, SHEILA CHERFILUS-MCCORMICK engaged

DAVID KOFI SPENCER to be her tax preparer for her calendar year 2021 Form 1040 tax return.

5. SHEILA CHERFILUS-MCCORMICK and DAVID KOFI SPENCER falsely

reported inflated business expenses of SCM Consulting in 2021 , by falsely characterizing personal

expenses and political contributions as business expenses.

6. SHEILA CHERFILUS-MCCORMICK and DAVID KOFI SPENCER falsely

reported the total profit for SCM Consulting in 2021 by falsely inflating business expenses of SCM

Consulting, thereby falsely and fraudulently reducing the tax liability of SCM Consulting in 2021 .

7. SHEILA CHERFILUS-MCCORMICK and DAVID KOFI SPENCER falsely

reported the total income for CHERFILUS-MCCORMICK in 2021 by using the falsely reported

profit for SCM Consulting to report a lower total income amount for CHERFILUS-

MCCORMICK in 2021.

8. SHEILA CHERFILUS-MCCORMICK and DAVID KOFI SPENCER falsely

reported an inflated amount of charitable contributions by CHERFILUS-MCCORMICK in

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Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 27 of 42

2021 , thereby increasing the amount of deductions and falsely and fraudulently reducing

CHERFILUS-MCCORMICK's total taxable income for 2021.

9. As a result of SHEILA CHERFILUS-MCCORMICK and DAVID KOFI

SPENCER falsely reporting SCM Consulting' s business expenses and profit in 2021 ,

CHERFILUS-MCCORMICK's total income in 2021 , and CHERFILUS-MCCORMICK's

charitable contributions in 2021 , CHERFILUS-MCCORMICK and SPENCER falsely and

fraudulently underreported the amount of taxes due to the United States by CHERFILUS-

MCCORMICK for calendar year 2021 .

OVERT ACTS

In furtherance of the conspiracy, and to accomplish the purpose thereof, at least one of the

co-conspirators committed and caused to be committed, in the Southern District of Florida, and

elsewhere, at least one of the following overt acts, amongst others:

1. From at least on or about March 9, 2022, through on or about August 21 , 2023,

SHEILA CHERFILUS-MCCORMICK and DAVID KOFI SPENCER corresponded regularly

about CHERFILUS-MCCORMICK's 2021 tax return, including at least five occasions when

CHERFILUS-MCCORMICK was in the Southern District of Florida.

2. On or about March 18, 2022, at DAVID KOFI SPENCER's request, DKS Tax

Employee 1 prepared a trial balance for SHEILA CHERFILUS-MCCORMICK's 2021 tax

return (the "March 18th trial balance"). The March 18th trial balance included line items

describing transfers from Bank Account 2 to Bank Account 3, Bank Account 5, and Bank Account

6, totaling more than approximately $4,000,000. The March 18th trial balance identified these

transfers as "Owner's Distributions," "Campaign," "EC Firm," and "Sheila Personal." SPENCER

requested DKS Tax Employee 1 to send him a copy of the March 18th trial balance.

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Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 28 of 42

3. On or about April 11, 2022, at DAVID KOFI SPENCER's direction, DKS Tax

Employee 2 prepared a second trial balance for SHEILA CHERFILUS-MCCORMICK's 2021

tax return. SPENCER directed DKS Tax Employee 2 to include line items describing expenses

for "Consulting" and "Contractors" totaling more than $4,000,000, which did not appear in the

March 18th trial balance.

4. On or about July 7, 2023 , SHEILA CHERFILUS-MCCORMICK electronically

signed IRS Form 8879, acknowledging, under the penalty of perjury, that she had examined a copy

of her income tax return and that everything contained within her 2021 Form 1040 tax return was

true, correct, and complete.

5. On or about August 21 , 2023 , DAVID KOFI SPENCER submitted a tax return on

behalf of SHEILA CHERFILUS-MCCORMICK which falsely claimed SCM Consulting had a

business-related expense of approximately $4,088,574 in consulting fees in 2021.

6. On or about August 21 , 2023 , DAVID KOFI SPENCER submitted a tax return on

behalf of SHEILA CHERFILUS-MCCORMICK which falsely claimed SCM Consulting had a

business-related expense of approximately $295,529 in contract labor in 2021.

7. On or about August 21 , 2023 , DAVID KOFI SPENCER submitted a tax return on

behalf of SHEILA CHERFILUS-MCCORMICK which falsely claimed SCM Consulting had a

business-related expense of approximately $155,000 in depreciation expense in 2021.

8. On or about August 21 , 2023 , DAVID KOFI SPENCER submitted a tax return on

behalf of SHEILA CHERFILUS-MCCORMICK which falsely claimed SCM Consulting had

approximately $4,620,055 in total business-related expenses in 2021.

9. On or about August 21 , 2023 , DAVID KOFI SPENCER submitted a tax return on

28
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 29 of 42

behalf of SHEILA CHERFILUS-MCCORMICK which falsely claimed SCM Consulting had a

total net profit of approximately $1,779,882 in 2021.

10. On or about August 21 , 2023 , DAVID KOFI SPENCER submitted a tax return on

behalf of SHEILA CHERFILUS-MCCORMICK which falsely claimed CHERFILUS-

MCCORMICK had approximately $2,169,607 in "other income" in 2021.

11. On or about August 21 , 2023 , DAVID KOFI SPENCER submitted a tax return on

behalf of SHEILA CHERFILUS-MCCORMICK which falsely claimed CHERFILUS-

MCCORMICK made a total of approximately $1,200,000 in charitable contributions in 2021.

12. On or about August 21 , 2023 , DAVID KOFI SPENCER submitted a tax return on

behalf of SHEILA CHERFILUS-MCCORMICK which falsely claimed CHERFILUS-

MCCORMICK had a total of approximately $1,054,079 in taxable income in 2021.

13. On or about August 21 , 2023 , DAVID KOFI SPENCER submitted a tax return on

behalf of SHEILA CHERFILUS-MCCORMICK which falsely claimed CHERFILUS-

MCCORMICK had a total of approximately $432,495 in tax owing in 2021.

14. On or about August 21 , 2023 , DAVID KOFI SPENCER submitted SHEILA

CHERFILUS-MCCORMICK's Form 1040 tax return electronically with the IRS from the

country of Barbados.

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

COUNT 15
Aiding and Assisting a False and Fraudulent Statement on a Tax Return
(26 u.s.c. § 7206(2))

1. Paragraphs 4 to 12, 15, 29, 31 , and 34 of the General Allegations of this Indictment

are re-alleged and incorporated by reference as though fully set forth herein.

29
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 30 of 42

2. From at least on or about March 9, 2022, through on or about August 21, 2023, in

the Southern District of Florida, in the country of Barbados, and elsewhere, the defendants,

SHEILA CHERFILUS-MCCORMICK and

DAVID KOFI SPENCER,

did willfully aid and assist in, and procure, counsel, and advise the preparation and presentation to

the IRS, of a personal tax return, Form 1040, of SHEILA CHERFILUS-MCCORMICK for the

calendar year 2021, which was false and fraudulent as to a material matter, in that Line 28 of

Schedule C "Total Expenses" included $4,620,055 worth of business expenses associated with

SCM Consulting, and Line 11 of Schedule A included $1,200,000 in charitable contributions by

CHERFILUS-MCCORMICK in 2021 , whereas, as the defendants then and there knew, in 2021,

SCM Consulting did not have $4,620,055 of total qualifying business expenses, and

CHERFILUS-MCCORMICK did not make $1 ,200,000 in charitable contributions, in violation

of Title 26, United States Code, Section 7206(2) and Title 18, United States Code, Section 2.

COUNT 16
Making a False Statement to a Federal Agency
(18 U.S.C. § 1001(a)(2))

1. Paragraphs 4 to 12, 15, 29, 31, and 34 of the General Allegations of this Indictment

are re-alleged and incorporated by reference as though fully set forth herein.

2. On or about January 27, 2024, in the Southern District of Florida, and elsewhere,

in a matter within the jurisdiction of the Internal Revenue Service ("IRS"), which is an agency of

the executive branch of the United States, the defendant,

DAVID KOFI SPENCER,

did knowingly and willfully make materially false, fictitious, and fraudulent statement and

representation during interviews by Special Agents of the IRS about the investigation of the

30
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 31 of 42

conspiracy described in Count 14, specifically pertaining to the accuracy of statements contained

in the 2021 Form 1040 tax return for SHEILA CHERFILUS-MCCORMICK, that is, DAVID

KOFI SPENCER represented to the IRS that the records he provided in response to a federal

grand jury subpoena issued as part of the above-referenced investigation were accurate, when in

truth and in fact, as the defendant then and well knew, the records he provided in response to a

federal grand jury subpoena issued as part of the above-referenced investigation were not accurate,

in violation of Title 18, United States Code, Sections 1001 (a)(2) and 2.

COUNT17
Concealment and Falsification of a Record or Document
(18 u.s.c. § 1519)

1. Paragraphs 4 to 12, 15, 31, and 34 of the General Allegations of this Indictment are

re-alleged and incorporated by reference as though fully set herein.

2. Between on or about January 19, 2024, and on or about January 27, 2024, in the

Middle District of Florida, in the Southern District of Florida, and elsewhere, the defendant,

DAVID KOFI SPENCER,

did knowingly conceal, cover up, falsify , and make false entries in a record and document, and

cause others to do so, with the intent to impede, obstruct, and influence the investigation and proper

administration of a matter within the jurisdiction of the IRS, and in relation to and contemplation

of such matter, that is, after being served with a subpoena issued by a federal grand jury sitting in

the Southern District of Florida, SPENCER copied and altered a tax letter from Church 1 to falsely

inflate the amount of charitable contributions made by SHEILA CHERFILUS-MCCORMICK

in 2021 ; deleted and concealed the original tax letter from Church 1; and provided the altered

Church 1 tax letter to the IRS in response to said federal grand jury subpoena, in violation of Title

18, United States Code, Sections 1519 and 2.

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Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 32 of 42

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, SHEILA CHERFILUS-MCCORMICK and EDWIN

CHERFILUS, have an interest.

2. Upon conviction of a violation of, or conspiracy to violate, Title 18, United States

Code, Section 641 , as alleged in this Indictment, the defendants shall forfeit to the United States

any property, real or personal, which constitutes or is derived from proceeds traceable to such

offense, pursuant to Title 18, United States Code, Section 981(a)(l)(C).

3. Upon conviction of a violation of Title 18, United States Code, Sections 1956(h)

and 1957, as alleged in this Indictment, the defendants shall forfeit to the United States any

property, real or personal, involved in such offense, and any property traceable to such property,

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

4. The property directly subj ect to forfeiture as a result of the alleged offenses

includes, but is not limited to, the following:

(i) a forfeiture money judgment in the sum of $5 ,007,271.50 in United States

currency, which sum represents the value of any property involved in the

defendants' commission of the offenses, or any property traceable to such

property; and

(ii) Approximately 3.14 carat "Fancy Vivid Yell ow Diamond" ring, purchased

from Jewelry Company 1 on or about August 30, 2021.

5. If any of the property subject to forfeiture, as a result of any act or omission of the

defendants:

32
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 33 of 42

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;

c. has been placed beyond the jurisdiction of the court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be divided without

difficulty,

the United States shall be entitled to forfeiture of substitute property under the provisions of Title

21, United States Code, Section 853(p).

All pursuant to Title 18, United States Code, Sections 981(a)(l)(C) and 982(a)(l), and the

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

United States Code, Section 982(b)(l), and Title 28, United States Code, Section 2461(c).

A TRUE BILL

JASON A,,,, ' DING UINONES

UNITEIJS EY
l _,,.

ES ATTORNEY
.
P. TADDEI
T AL ATTORNEY, CRIMINAL DIVISION
DEPARTMEN TICE

33
 Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 34 of 42
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

UNITED STATES OF AMERICA 25-CR-20500-GAYLES/SHAW-WILDER

CASE NO.: - - -- - - - -- - - - - - - - -
v.
CERTIFICATE OF TRIAL ATTORNEY
SHEILA CHERFILUS-MCCORMICK, et al.,
- - - - - - - - - - - - - - - - -I Superseding Case Information:
Defendants . New Defendant(s) (Yes or No) _ _
Court Division (select one) Number of New Defendants
IZ]Miami □ Key West □ FTP Total number of new counts
□ FTL □ WPB

I do hereby certify that:

1. 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/Inform ation attached hereto.
2. I am aware that the information supplied on this statement will be relied upon by the Judges of this Court in setting
their calendars and scheduling criminal trials under the mandate of the Speedy Trial Act, 28 U.S .C. §3161.

3. Interpreter: (Yes or N o ) ~
List language and/or dialect: _ _ _ _ _ _ __

4. This case will take 30 days for the paiiies to try.

5. Please check appropriate category and type of offense listed below:
(Check only one) (Check only one)
I D Oto 5 days □ Petty
II D 6 to 10 days □ Minor
III D 11 to 20 days D Misdemeanor
IV D 21 to 60 days IZ!Felony
V D 61 days and over
6. Has this case been previously filed in this District Court? (Yes or No) - No -
Ifyes, Judge _ _ _ _ _ _ _ _ _ _ _ Case No. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
7. Has a complaint been fil ed in this matter? (Yes or N o ) ~
If yes, Judge _ _ _ _ _ _ _ _ _ _ _ Magistrate Case No. _ _ _ _ _ _ _ _ _ _ _ _ __
8. Does this case relate to a previously filed matter in this District Court? (Yes or No) Yes
If yes, Judge David S. Leibowitz Case No._2_4-_m_i~·-_63_4_6_-_L_e_ib_o_w_i_tz_ _ _ _ _ _ _ _ __
9. Defendant(s) in federal custody as of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
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 N o ) ~
13. Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office _
prior to October 3, 2019 (Mag. Judge Jared M. Strauss)? (Yes or No) - No -
14. Did this matter involve the participation of or consultation with Magistrate Judge Eduardo I. Sanchez
during his tenure at the U.S. Attorney's Office, which concluded on January 22, 2023? ~
15. Did this matter involve the participation of or consultation with Magistrate Judge Marty Fulgueira
Elfenbein during her tenure at the U.S. Attorney's Office, which concluded on March 5, 2024? ~
16. Did this matter involve the participation of or consultation ·th Magistrate Judge Ellen F. D'Angelo
during her tenure at the U.S. Attorney's Office, which co ude ctober 7, 2024?~

By: - - --+-- ------,~~!aaaa.c, - - - - - - - - - -- -----

A lej an a
Assistant Uni Attorney
FL Bar No. 37132
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 35 of 42

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Name: SHEILA CHERFILUS-MCCORMICK

Case No:

Count #:1

Conspiracy to Commit Theft of Government Funds

Title 18, United States Code, Section 371

* Max. Term of Imprisonment: 5 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NI A
*Max.Fine: $250,000 I $100 Special Assessment

Count #:2

Theft of Government Funds

Title 18, United States Code, Section 641

* Max. Term of Imprisonment: 10 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NI A
*Max.Fine: $250,000 I $100 Special Assessment

Count #:3

Conspiracy to Commit Money Laundering

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

* Max. Term of Imprisonment: 10 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NIA
*Max.Fine: $500,000 or Twice the Value of the Property Involved in the Transaction,
whichever is Greater I $100 Special Assessment
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 36 of 42

Count #:4-11

Money Laundering

Title 18, United States Code, Section 1957

* Max. Term of Imprisonment: 10 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NIA
*Max.Fine: $250,000 or Twice the Value of the Property Involved in the Transaction,
whichever is Greater I $ l 00 Special Assessment

Count #:12

Conspiracy to Make and Receive Straw Donor Contributions

Title 18, United States Code, Section 371

* Max. Term of Imprisonment: 5 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NIA
*Max.Fine: $250,000 I $100 Special Assessment

Count #:13

Making and Receiving Straw Donor Contributions

Title 52, United States Code, Sections 30122 & 30109(d)(l)(A)(9)(i)

* Max. Term of Imprisonment: 5 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NIA
*Max.Fine: $50,000 or 1,000 Percent the Amount of Contributions Involved I $100 Special
Assessment

Count #:14

Conspiracy to Make a False and Fraudulent Statement on a Tax Return

Title 18, United States Code, Section 371

*Max.Term of Imprisonment: 5 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years

2
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 37 of 42

* Mandatory Min. Term of Supervised Release: N/A

*Max.Fine: $250,000 / $100 Special Assessment

Count#:15

Aiding and Assisting a False and Fraudulent Statement on a Tax Return

Title 26, United States Code, Section 7206(2)

* Max. Term of Imprisonment: 3 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 1 year
* Mandatory Min. Term of Supervised Release: N/A
*Max.Fine: $250,000 / $100 Special Assessment

3
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 38 of 42

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Name: EDWIN CHERFILUS

Case No:

Count #:1

Conspiracy to Commit Theft of Government Funds

Title 18, United States Code, Section 371

* Max. Term of Imprisonment: 5 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NIA
*Max.Fine: $250,000 I $100 Special Assessment

Count #:2

Theft of Government Funds

Title 18, United States Code, Section 641

* Max. Term of Imprisonment: 10 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NIA
* Max. Fine: $250,000 I $ l 00 Special Assessment

Count #:3

Conspiracy to Commit Money Laundering

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

* Max. Term of Imprisonment: 10 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NI A
*Max.Fine: $500,000 or Twice the Value of the Property Involved in the Transaction,
whichever is Greater I $ l 00 Special Assessment
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 39 of 42

Count #:4-11

Money Laundering

Title 18, United States Code, Section 1957

* Max. Term of Imprisonment: 10 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NIA
*Max.Fine: $250,000 or Twice the Value of the Property Involved in the Transaction,
whichever is Greater I $100 Special Assessment

2
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 40 of 42

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PENAL TY SHEET

Defendant's Name: NADEGE LEBLANC

Case No:

Count #:12

Conspiracy to Make and Receive Straw Donor Contributions

Title 18, United States Code, Section 371

* Max. Term of Imprisonment: 5 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NIA
*Max.Fine: $250,000 I $100 Special Assessment

Count #:13

Making and Receiving Straw Donor Contributions

Title 52, United States Code, Sections 30122 & 30109(d)(l)(A)(9)(i)

*Max.Term of Imprisonment: 5 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NIA
*Max.Fine: $50,000 or 1,000 Percent the Amount of Contributions Involved I $100 Special
Assessment
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 41 of 42

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Name: DAVID KOFI SPENCER

Case No:

Count #:14

Conspiracy to Make a False and Fraudulent Statement on a Tax Return

Title 18, United States Code, Section 371

* Max. Term of Imprisonment: 5 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NIA
*Max.Fine: $250,000 I $100 Special Assessment

Count #:15

Aiding and Assisting a False and Fraudulent Statement on a Tax Return

Title 26, United States Code, Section 7206(2)

* Max. Term of Imprisonment: 3 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 1 year
* Mandatory Min. Term of Supervised Release: NIA
* Max. Fine: $250,000 I $100 Special Assessment
Count #:16

False Statement to a Federal Agency

Title 18, United States Code, Section 1001(a)(2)

* Max. Term of Imprisonment: 5 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NI A
*Max.Fine: $250,000 I $100 Special Assessment
Case 1:25-cr-20500-DPG Document 1 Entered on FLSD Docket 11/20/2025 Page 42 of 42

Count #:17

Falsification of a Record of Document

Title 18, United States Code, Section 1519

* Max. Term of Imprisonment: 20 years
* Mandatory Min. Term of Imprisonment: NIA
* Max. Term of Supervised Release: 3 years
* Mandatory Min. Term of Supervised Release: NIA
*Max.Fine: $250,000 I $100 Special Assessment