The mail fraud charge required an act of mailing in connection with a fraudulent scheme. The relevant mailing was her application to the California Victim Compensation Board, filed November 28, 2016. The application, submitted by mail in connection with a scheme to defraud the Board by presenting herself as a kidnapping victim, established the mail fraud predicate. The application resulted in payments totaling approximately $30,694.15 between 2017 and 2021.

The original indictment contained thirty-four mail fraud counts. Each of the thirty-four counts presumably corresponded to a distinct mailing or transaction in the fraudulent scheme with the Victim Compensation Board — individual reimbursement checks, correspondence, or other specific mailings over the four-year period during which she collected funds from the Board. The plea agreement dismissed thirty-three of those counts in exchange for her guilty plea on one mail fraud count and one false-statements count.

The federal charging and plea framework is worth being precise about because it is commonly mischaracterized: she was charged with thirty-four mail fraud counts and one false-statements count (thirty-five counts total), pleaded guilty to one mail fraud count and one false-statements count (two counts), and had thirty-three counts dismissed. She was not convicted of thirty-four crimes. She was convicted of two.

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## What the Plea Admitted

The guilty plea entered on April 18, 2022, required Papini to acknowledge specific facts before the court. Federal guilty pleas involve a factual basis — a recitation of what the defendant admits to having done — that is reviewed and accepted by the judge before the plea is recorded. The factual basis in the Papini plea, though the plea agreement document itself was not accessible to this article’s research from the DOJ directly, is described in sufficient detail in secondary reporting to establish its essential content.

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