U.S.

Department of Justice
United States Attorney
District of Maryland
Southern Division
David I. Salem
Assistant United States Attorney
[email protected]

Mailing Address:
6500 Cherrywood Lane, Suite 200
Greenbelt, MD 20770-1249

Office Location:
6406 Ivy Lane, 8th Floor
Greenbelt, MD 20770-1249

DIRECT: 301-344-4237
MAIN: 301-344-4433
FAX: 301-344-4516

December 5, 2014
Gary E. Proctor, Esq.
Law Offices of Gary E. Proctor LLC
Eight E. Mulberry Street
Baltimore, Md. 21202
Re:

United States v. Paul Dunham, et al.,

Criminal No. PWG-11-0661

Dear Mr. Proctor:

This letter, together with the Sealed Supplement, confirms the plea agreement which has
been offered to the Defendant by the United States Attorneys Office for the District of Maryland
(this Office). If the Defendant accepts this offer, please have him execute it in the spaces
provided below. This plea agreement is expressly conditioned on co-defendant Sandra
Dunham executing the written plea agreement extended to her by this Office no later than
5:00 p.m. on December 5, 2014, and thereafter promptly entering her guilty plea with the
Court. If this offer has not been accepted by 5:00 p.m. on December 5, 2014, it will be deemed
withdrawn. The terms of the agreement are as follows:
Offenses of Conviction
1.
The Defendant agrees to plead guilty to Counts One and Ten of the Indictment
now pending against him, which charge him in Count One with Conspiracy to Commit Wire
Fraud, in violation of 18 U.S.C. 1349, and in Count Ten with Money Laundering, in violation
of 18 U.S.C. 1956(a)(2)(A). The Defendant admits that he is, in fact, guilty of those offenses
and will so advise the Court.
Elements of the Offenses
2.
The elements of the offenses to which the Defendant has agreed to plead guilty,
and which this Office would prove if the case went to trial, are as follows:
a.
Conspiracy to Commit Wire Fraud: (1) two or more persons
entered into the unlawful agreement charged in the Indictment; and (2) the Defendant knowingly
and willfully became a member of the conspiracy.

b.
Money Laundering: (1) the defendant transported (or attempted to
transport) a monetary instrument or funds to a place in the United States from or through a place
outside the United States; and, (2) the Defendant did so with the intent to promote the carrying
on of specified unlawful activity, in this case, wire fraud, in violation of 18 U.S.C.
1343.
Penalties
3.
The maximum sentence provided by statute for the offenses to which the
Defendant is pleading guilty is as follows:
a.
Count One (Conspiracy to Commit Wire Fraud): 20 years
incarceration, followed by a term of supervised release not to exceed three years, and a fine of
$250,000 or twice the gross gain or loss, pursuant to 18 U.S.C. 3571(d).
b.
Count Ten (Money Laundering): 20 years incarceration, followed
by a term of supervised release of not more than three years, and a fine of $500,000, or twice the
value of the monetary instrument or funds, pursuant to 18 U.S.C. 3571(d).
In addition, the Defendant must pay $200 as a special assessment pursuant to 18 U.S.C.
3013, which will be due and should be paid at or before the time of sentencing. If a fine or
restitution is imposed, it shall be payable immediately, unless, pursuant to 18 U.S.C. 3572(d),
the Court orders otherwise. 1 The Defendant understands that if he serves a term of
imprisonment, is released on supervised release, and then violates the conditions of his
supervised release, his supervised release could be revoked - even on the last day of the term and the Defendant could be returned to custody to serve another period of incarceration and a
new term of supervised release.
4.
The Defendant understands that the Bureau of Prisons has sole discretion in
designating the institution at which the Defendant will serve any term of imprisonment imposed.
Waiver of Rights
5.
The Defendant understands that by entering into this agreement, he surrenders
certain rights as outlined below:
a.
If the Defendant had persisted in his plea of not guilty, he would have had
the right to a speedy jury trial with the close assistance of competent counsel. That trial could be
conducted by a judge, without a jury, if the Defendant, this Office, and the Court all agreed.
b.
If the Defendant elected a jury trial, the jury would be composed of twelve
individuals selected from the community. Counsel and the Defendant would have the
opportunity to challenge prospective jurors who demonstrated bias or who were otherwise
unqualified, and would have the opportunity to strike a certain number of jurors peremptorily.
1

Pursuant to 18 U.S.C. 3612, if the Court imposes a fine in excess of $2,500 that remains
unpaid 15 days after it is imposed, the Defendant shall be charged interest on that fine, unless the
Court modifies the interest payment in accordance with 18 U.S.C. 3612(f)(3).
2

All twelve jurors would have to agree unanimously before the Defendant could be found guilty
of any count. The jury would be instructed that the Defendant was presumed to be innocent, and
that presumption could be overcome only by proof beyond a reasonable doubt.
c.
If the Defendant went to trial, the government would have the burden of
proving the Defendant guilty beyond a reasonable doubt. The Defendant would have the right to
confront and cross-examine the governments witnesses. The Defendant would not have to
present any defense witnesses or evidence whatsoever. If the Defendant wanted to call witnesses
in his defense, however, he would have the subpoena power of the Court to compel the witnesses
to attend.
d.
The Defendant would have the right to testify in his own defense if he so
chose, and he would have the right to refuse to testify. If he chose not to testify, the Court could
instruct the jury that they could not draw any adverse inference from his decision not to testify.
e.
If the Defendant were found guilty after a trial, he would have the right to
appeal the verdict and the Courts pretrial and trial decisions on the admissibility of evidence to
see if any errors were committed which would require a new trial or dismissal of the charges
against him. By pleading guilty, the Defendant knowingly gives up the right to appeal the
verdict and the Courts decisions.
f.
By pleading guilty, the Defendant will be giving up all of these rights,
except the right, under the limited circumstances set forth in the Waiver of Appeal paragraph
below, to appeal the sentence. By pleading guilty, the Defendant understands that he may have
to answer the Courts questions both about the rights he is giving up and about the facts of his
case. Any statements the Defendant makes during such a hearing would not be admissible
against him during a trial except in a criminal proceeding for perjury or false statement.
g.
If the Court accepts the Defendants plea of guilty, there will be no further
trial or proceeding of any kind, and the Court will find him guilty.
h.
By pleading guilty, the Defendant will also be giving up certain valuable
civil rights and may be subject to deportation or other loss of immigration status. The Defendant
recognizes that if he is not a citizen of the United States, pleading guilty may have consequences
with respect to his immigration status. Under federal law, conviction for a broad range of crimes
can lead to adverse immigration consequences, including automatic removal from the United
States. Removal and other immigration consequences are the subject of a separate proceeding,
however, and the Defendant understands that no one, including his attorney or the Court, can
predict with certainty the effect of a conviction on immigration status. Defendant nevertheless
affirms that he wants to plead guilty regardless of any potential immigration consequences.

Advisory Sentencing Guidelines Apply

6.
The Defendant understands that the Court will determine a sentencing guidelines
range for this case (henceforth the advisory guidelines range) pursuant to the Sentencing
Reform Act of 1984 at 18 U.S.C. 3551-3742 (excepting 18 U.S.C. 3553(b)(l) and 3742(e))
and 28 U.S.C. 991 through 998.
Factual and Advisory Guidelines Stipulation
7.
This Office and the Defendant understand, agree and stipulate to the Statement of
Facts set forth in Attachment A hereto, which this Office would prove beyond a reasonable
doubt, and to the following applicable sentencing guidelines factors:
Count One: (Conspiracy to Commit Wire Fraud)
a.

The base offense level is 7 pursuant to U.S.S.G. 2B1.1(a)(1).

b.
The parties agree that the base offense level should be increased 14 levels,
pursuant to 2B1.1(b)(1)(G) and 2B1.1(b)(1)(H), because the loss attributable to the Defendant
is at least $400,000, but not greater than $1,000,000.
c.
A 2-level increase applies because a substantial part of the fraudulent
scheme was committed from outside the United States, pursuant to U.S.S.G. 2B1.1(b)(10)(B).
d.
The Government believes that a 2-level increase applies, because the
Defendant was an organizer, leader, manager or supervisor of criminal activity, pursuant to
U.S.S.G. 3B1.1(c).
e.
The Government believes that a 2-level increase applies, because the
Defendant abused a position of trust with his employer in the commission of the scheme,
pursuant to U.S.S.G. 3B1.3.
f.
The Defendant reserves the right to argue that the enhancements for role
and abuse of positon of trust in paragraphs 7(d) and 7(e) are duplicative and that only one of
these enhancements should apply.
g.
The adjusted offense level for Count One thus is 27 (the Governments
position) or 25 (the Defendants position).
Count Ten: (Money Laundering)
h.
The base offense level is 27 (the Governments position) or 25 (the
Defendants position), because the offense level is determined by looking at the offense level for
the underlying offense from which the laundered funds were derived, pursuant to 2S1.1(a)(1).

i.
Pursuant to U.S.S.G. 2S1.1(b)(2)(B), a 2-level enhancement applies,
because the Defendant was convicted under 18 U.S.C. 1956. The adjusted offense level for
Count Ten is 29 (the Governments position) or 27 (the Defendants position).
j.
Grouping: Because the offense levels for Counts One and Ten are
determined largely on the basis of the total amount of harm or loss, these counts group, pursuant
to U.S.S.G. 3D1.1, 3D1.2(d), and 3D1.3. The total offense level thus is 29 (the Governments
position) or 27 (the Defendants position).
k.
This Office does not oppose a two-level reduction in the Defendants
adjusted offense level, based upon the Defendants apparent prompt recognition and affirmative
acceptance of personal responsibility for his criminal conduct. This Office may oppose any
adjustment for acceptance of responsibility if the Defendant (a) fails to admit each and every
item in the factual stipulation; (b) denies involvement in the offense; (c) gives conflicting
statements about his involvement in the offense; (d) is untruthful with the Court, this Office, or
the United States Probation Office; (e) obstructs or attempts to obstruct justice prior to
sentencing; (f) engages in any criminal conduct between the date of this agreement and the date
of sentencing; or (g) attempts to withdraw his plea of guilty. The final adjusted offense level is
27(the Governments position) or 25 (the Defendants position).
8.
The Defendant understands that there is no agreement as to his criminal history or
criminal history category, and that his criminal history could alter his offense level if he is a
career offender or if the instant offense was a part of a pattern of criminal conduct from which he
derived a substantial portion of his income.
9.
This Office and the Defendant agree that with respect to the calculation of the
advisory guidelines range, no other offense characteristics, sentencing guidelines factors,
potential departures or adjustments set forth in the United States Sentencing Guidelines will be
raised or are in dispute.
Obligations of this Office and the Defendant
10.
At the time of sentencing, this Office will recommend a sentence within the
advisory Guidelines range determined by the Court for Counts One and Ten. At the time of
sentencing, this Office will move to dismiss any open counts against the Defendant.
11.
The Defendant may apply to serve a portion of his sentence in the United
Kingdom, pursuant to the International Prisoner Transfer Program, 18 U.S.C. 4100 et seq. If
the Defendant is eligible and applies to transfer his sentence pursuant to the International
Prisoner Transfer Program, this Office agrees to not oppose the Defendants transfer application.
The Defendant acknowledges and understands, however, that the transfer decision rests in the
sole discretion of the Office of Enforcement Operations (OEO) of the Criminal Division of the
United States Department of Justice and that the position of this Office is neither binding nor
determinative of the positions of other federal agencies or on the final transfer decision of OEO.
The Defendant further understands that in addition to OEO, federal law and the underlying
transfer treaties require that the foreign government must also approve the transfer.
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12.
The parties reserve the right to bring to the Courts attention at the time of
sentencing, and the Court will be entitled to consider, all relevant information concerning the
Defendants background, character and conduct.
Restitution
13.
The Defendant agrees to the entry of a Restitution Order in the amount of
$1,000,000, which represents the full amount of the victims losses. The Defendant agrees that,
pursuant to 18 U.S.C. 3663 and 3663A and 3563(b)(2) and 3583(d), the Court may order
restitution of the full amount of the actual, total loss caused by the offense conduct set forth in
Attachment A. The Defendant agrees to waive any challenge to the restitution amount. Any
restitution imposed shall be payable immediately, unless, pursuant to 18 U.S.C. 3572(d), the
Court orders otherwise.
14.
The Defendant further agrees that he will fully disclose to the probation officer
and to the Court, subject to the penalty of perjury, all information, including but not limited to
copies of all relevant bank and financial records, regarding the current location and prior
disposition of funds obtained as a result of the criminal conduct set forth in the factual stipulation
as well as any funds that may be available as substitute assets for the purpose of restitution. The
Defendant further agrees to take all reasonable steps to retrieve or repatriate any such funds and
to make them available for restitution. If the Defendant does not fulfill this provision, it will be
considered a material breach of this plea agreement, and this Office may seek to be relieved of its
obligations under this agreement.
Forfeiture
15.
The Defendant agrees that as part of his acceptance of responsibility and pursuant
to 18 U.S.C. 981(a)(1)(C) and 28 U.S.C. 2461, he will consent to the entry of a forfeiture
money judgment in the amount of $1,000,000 (the Forfeiture Money Judgment). The
Defendant acknowledges that this amount is subject to forfeiture as property, real or personal,
that constitutes or is derived from proceeds traceable to a violation of 18 U.S.C. 1343 and
1349, which constitutes specified unlawful activity within the meaning of 18 U.S.C. 981
(a)(1)(C).
16.
The Defendant agrees to consent to the entry of orders of forfeiture for the
Forfeiture Money Judgment and waives the requirements of Rules 32.2 and 43(a) of the Federal
Rules of Criminal Procedure regarding notice of the forfeiture in the charging instrument,
announcement of the forfeiture at sentencing, and incorporation of the forfeiture in the judgment.
The Defendant understands that the forfeiture of the Forfeiture Money Judgment is part of the
sentence that may be imposed in this case and waives any failure by the court to advise him of
this pursuant to Rule 11 (b)(l)(1) of the Federal Rules of Criminal Procedure at the guilty plea
proceeding.

Assisting the Government with Regard to the Forfeiture

17.
The Defendant agrees to assist fully in the forfeiture of the foregoing assets. The
Defendant agrees to disclose all of his assets and sources of income to the United States, and to
take all steps necessary to pass clear title to the forfeited assets to the United States, including but
not limited to executing any and all documents necessary to transfer such title, assisting in
bringing any assets located outside of the United States within the jurisdiction of the United
States, and taking whatever steps are necessary to ensure that assets subject to forfeiture are not
sold, disbursed, wasted, hidden or otherwise made unavailable for forfeiture. The Defendant
further agrees that he will not assist any third party in asserting a claim to the forfeited assets in
an ancillary proceeding and that he will testify truthfully in any such proceeding.
Waiver of Further Review of Forfeiture
18.
The Defendant agrees to waive all constitutional, legal and equitable challenges
(including direct appeal, habeas corpus, or any other means) to any forfeiture carried out in
accordance with this Plea Agreement on any grounds, including that the forfeiture constitutes an
excessive fine or punishment or otherwise violates the Eighth Amendment. The Defendant also
agrees not to challenge or seek review of any civil or administrative forfeiture of any property
subject to forfeiture under this agreement, and will not assist any third party with regard to such
challenge or review or with regard to the filing of a petition for remission of forfeiture.
Waiver of Appeal
19.
In exchange for the concessions made by this Office and the Defendant in this
plea agreement, this Office and the Defendant waive their rights to appeal as follows:
a.
The Defendant knowingly waives all right, pursuant to 28 U.S.C. 1291
or otherwise, to appeal the Defendant=s conviction;
b.
The Defendant and this Office knowingly waive all right, pursuant to 18
U.S.C. 3742 or otherwise, to appeal whatever sentence is imposed (including the right to
appeal any issues that relate to the establishment of the advisory guidelines range, the
determination of the defendant=s criminal history, the weighing of the sentencing factors, and the
decision whether to impose and the calculation of any term of imprisonment, fine, order of
forfeiture, order of restitution, and term or condition of supervised release), except as follows: (i)
the Defendant reserves the right to appeal any aggregate term of imprisonment to the extent that
it exceeds the guidelines range associated with an offense level of 27 as to Counts One and Ten;
(ii) and this Office reserves the right to appeal any term of imprisonment to the extent that it is
below the guidelines range associated with an offense level of 25 as to Counts One and Ten.
c.
The Defendant and this Office also waive any right to challenge the
restitution amount determined by the Court.
d.
Nothing in this agreement shall be construed to prevent the Defendant or
this Office from invoking the provisions of Federal Rule of Criminal Procedure 35(a), or from
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appealing from any decision thereunder, should a sentence be imposed that resulted from
arithmetical, technical, or other clear error.
e.
The Defendant waives any and all rights under the Freedom of
Information Act relating to the investigation and prosecution of the above-captioned
matter and agrees not to file any request for documents from this Office or any
investigating agency.
Obstruction or Other Violations of Law
20.
The Defendant agrees that he will not commit any offense in violation of federal,
state or local law between the date of this agreement and his sentencing in this case. In the event
that the Defendant (i) engages in conduct after the date of this agreement which would justify a
finding of obstruction of justice under U.S.S.G. 3C1.1, or (ii) fails to accept personal
responsibility for his conduct by failing to acknowledge his guilt to the probation officer who
prepares the Presentence Report, or (iii) commits any offense in violation of federal, state or
local law, then this Office will be relieved of its obligations to the Defendant as reflected in this
agreement. Specifically, this Office will be free to argue sentencing guidelines factors other than
those stipulated in this agreement, and it will also be free to make sentencing recommendations
other than those set out in this agreement. As with any alleged breach of this agreement, this
Office will bear the burden of convincing the Court of the Defendants obstructive or unlawful
behavior and/or failure to acknowledge personal responsibility by a preponderance of the
evidence. The Defendant acknowledges that he may not withdraw his guilty plea because this
Office is relieved of its obligations under the agreement pursuant to this paragraph.
Entire Agreement
21.
This letter supersedes any prior understandings, promises, or conditions between
this Office and the Defendant and, together with the Sealed Supplement, constitutes the complete
plea agreement in this case. The Defendant acknowledges that there are no other agreements,
promises, undertakings or understandings between the Defendant and this Office other than those
set forth in this letter and the Sealed Supplement and none will be entered into unless in writing
and signed by all parties.

If the Defendant fully accepts each and every term and condition of this agreement,
please sign and have the Defendant sign the original and return it to me promptly.

Respectfully submitted,
Rod J. Rosenstein
United States Attorney

By: ____________________________
David I. Salem
Leah J. Bressack
Assistant United States Attorneys
United States Attorneys Office

I have read this agreement and carefully reviewed every part of it with my attorney. I
understand it, and I voluntarily agree to it. Specifically, I have reviewed the Factual and
Advisory Guidelines Stipulation with my attorney, and I do not wish to change any part of it. I
am completely satisfied with the representation of my attorney.

Date

Paul Dunham

I am Paul Dunhams attorney. I have carefully reviewed every part of this agreement
with him. He advises me that he understands and accepts its terms. To my knowledge, his
decision to enter into this agreement is an informed and voluntary one.

Date

Gary Proctor, Esq.

ATTACHMENT A:
STIPULATED FACTS - UNITED STATES v. PAUL DUNHAM
The parties hereby stipulate and agree that if this case proceeded to trial, the government
would have proven the following facts beyond a reasonable doubt. The parties agree that the
following facts do not encompass all of the facts that would have been proven had this matter
proceeded to trial.
PAUL DUNHAM is a citizen of the United Kingdom. On or about August 3, 1987,
PAUL DUNHAM was hired by Pace Europe Ltd. Pace Europe Ltd. was a United Kingdom
subsidiary of its parent company, Pace USA, which was located at various times in Maryland
and North Carolina (collectively Pace). Pace produced for the military and others parts for the
repair and reworking of electronics.
From in or around 1987 through in or around 2009, PAUL DUNHAM held a number of
executive-level positions at Pace, including President and Chief Operating Officer of Pace.
PAUL DUNHAMs wife, Sandra Dunham, was hired on or about December 2, 1987, to work
for Pace Europe Ltd., and eventually became the Director of Sales and Marketing for Pace USA.
Both PAUL DUNHAM and Sandra Dunham relocated from the United Kingdom to the United
States as part of their job responsibilities for Pace.
As part of their routine business arrangements with Pace, PAUL DUNHAM obtained
several corporate credit cards, including Pace Europe HSBC Mastercards xxxx-xxxx-xxxx-1961;
xxxx-xxxx-xxxx-3649; xxxx-xxxx-xxxx-0823; and xxxx-xxxx-xxxx-2673; Pace Europe
American Express card number xxxx-xxxxxx-92000; and Pace USA Visa card number xxxxxxxx-xxxx-1955. Sandra Dunham also obtained several corporate credit cards, including Pace
Europe HSBC Mastercard number xxxx-xxxx-xxxx-9226, and Pace USA Visa card number
xxxx-xxxx-xxxx-7238. At no time did PAUL DUNHAM or Sandra Dunhams employment
contracts or other agreements with Pace permit them to use their business credit cards for purely
personal expenses.
PAUL DUNHAM and Sandra Dunham often submitted reimbursement vouchers to the
Pace Europe Ltd.s offices in the United Kingdom, either in person or by facsimile from the
United States, for expenses they incurred in both the United States and the United Kingdom,
which they represented to their personal secretary were legitimate business expenses. PAUL
DUNHAM and Sandra Dunham caused their secretary to submit formal company
reimbursement forms to Pace requesting that Pace reimburse PAUL DUNHAM and Sandra
Dunham. Pace then reimbursed PAUL DUNHAM and Sandra Dunham for such expenses,
typically by making wire transfers from the Pace account at HSBC Bank in the United Kingdom
to PAUL DUNHAM and Sandra Dunhams personal bank accounts, both in the United
Kingdom and in the United States, including a joint Bank of America account ending in 0840,
which PAUL DUNHAM and Sandra Dunham had opened in Maryland on or about October
12, 2005.
Between in or about 2002 and in or about 2009, in the District of Maryland and

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elsewhere, PAUL DUNHAM did knowingly combine, conspire, confederate and agree with
Sandra Dunham to knowingly devise a scheme and artifice to defraud Pace and to obtain
money and property from Pace by means of materially false and fraudulent pretenses,
representations, and promises, and material omissions (Athe scheme to defraud@), and for the
purpose of executing and attempting to execute the scheme to defraud, to transmit and cause to
be transmitted by means of wire and radio communication in interstate and foreign commerce,
writings, signs, signals, pictures and sounds, in violation of 18 U.S.C. 1343.
Beginning in about 2002, PAUL DUNHAM agreed with Sandra Dunham to charge
personal expenses on their business credit cards. To avoid detection, PAUL DUNHAM and
Sandra Dunham deliberately mischaracterized personal expenses as business expenses. For
example, on August 11, 2005, PAUL DUNHAM faxed a reimbursement request to Pace Europe,
indicating that approximately $3,007 had been spent on miscellaneous USA expenses for
meals at various restaurants during business meetings in North Carolina, when in fact the
expense invoices attached to the request were actually for luxury bedding and linens from an
upscale bedding boutique in North Carolina. These bedding and linen purchases were intended
for delivery to PAUL DUNHAM and Sandra Dunhams upscale North Carolina residence.
Similarly, on or about December 20, 2004, Sandra Dunham submitted for
reimbursement a claim for approximately $8,397.39, which had been charged to a personal
AMEX account ending in 62007 held in the name of Paul Dunham. The reimbursement claim
that Sandra Dunham submitted to Pace consisted of a copy of the AMEX statement for the
period of November 13 through December 4, 2004, on which Sandra Dunham had placed stars
next to specific charges and written claim due to cancelled holiday due to business meeting.
At the time of its submission, Sandra Dunham knew that the charges for which she was seeking
reimbursement from Pace were not related to a cancelled vacation, but were in fact mortgage
payments she and PAUL DUNHAM had made on two separate time share units PAUL
DUNHAM and Sandra Dunham had purchased in Barbados.
In addition, a substantial portion of the scheme was committed from outside the United
States and involved PAUL DUNHAM managing and directing others in the execution of the
scheme. Moreover, as part of the conspiracy, PAUL DUNHAM resorted to forgery. For
example, on or about October 3, 2007, PAUL DUNHAM requested that his secretary in the UK
prepare and submit to the Pace accounting office in the UK a claim for reimbursement of
approximately $3,943 in legal fees. To support this claim, PAUL DUNHAM provided his
secretary in the UK with a fraudulent invoice dated September 19, 2007, which PAUL
DUNHAM had doctored to appear as if the legal charges were Pace-related legal expenses, and
PAUL DUNHAM noted on the invoice: Please pay this amount as I have already paid this
invoice. At the time of its submission, PAUL DUNHAM knew that he was falsely
representing the nature of the legal expenses, because the legal expenses for which he sought
reimbursement were actually fees PAUL DUNHAM had paid to an attorney for personal
litigation unrelated to Pace.
Similarly, PAUL DUNHAM doctored an invoice from a North Carolina business related
to his purchase of home furnishings in order to make the invoice appear as if PAUL DUNHAM
had purchased trade show display tables on behalf of Pace, when in fact the real invoice showed
11

that the items PAUL DUNHAM had purchased consisted of expensive furniture delivered to
PAUL DUNHAM and Sandra Dunhams North Carolina residence.
With the intent to promote the wire fraud scheme, PAUL DUNHAM also caused to be
transported and transmitted funds from or through a place outside the United States to a place in
the United States. For example, on or about February 12, 2007, PAUL DUNHAM caused Pace
to transmit funds in the amount of $3,279.49 from a Pace account at HSBC Bank in the UK to
the joint BOA account in Maryland. That reimbursement amount included $1,270.03, which
PAUL DUNHAM had charged on his personal American Express credit card ending in 41001
for the purchase of Frontgate furniture, including a domed pet residence and dog sofa that had
nothing to do with Pace business. As part of the scheme, PAUL DUNHAM had coded those
Frontgate purchases as shows [sic], representing to Pace that the items were related to
company industrial trade shows when they were not.
In addition, PAUL DUNHAM and Sandra Dunham defrauded Pace by doubledipping, i.e., charging a particular expense business or otherwise to a Pace USA credit card
and then seeking separate reimbursement from Pace Europe Ltd. for the same expense. For
example, on or about January 12, 2009, Sandra Dunham sought and obtained reimbursement
from Pace Europe in the amount of approximately $1,230.31, for the purchase of European air
travel, which was originally charged to PAUL DUNHAMs Pace USA Visa card no. xxxx1955
and paid by Pace USA.
In conducting the scheme as an executive of Pace, PAUL DUNHAM abused a private
position of trust. Based upon the length of the conspiracy, and information provided by other
individuals, $1,000,000 in actual loss was reasonably foreseeable and within the scope of PAUL
DUNHAMs agreement.
I have read this statement of facts and carefully reviewed it with my attorney. I
acknowledge that it is true and correct.

Date

Paul Dunham

I am the attorney for Paul Dunham. I have carefully reviewed the statement of facts with
him.

Date

Gary Proctor, Esq.

12