OPINION
MESSITTE, District Judge.
I.
Francis Richard Stewart, the spouse of a deceased federal employee, pleaded guilty to a single count of conspiracy to defraud the United States, specifically conspiracy to convert survivor benefits from the Office of Personnel Management (OPM), in violation of 18 U.S.C. § 371. The payments made to or on behalf of Stewart between 1998 and 2002 consisted of:
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