[\JI?ti?a l?1 


 

 

Case Document 6 Filed 02/15/18 Page 1 of 16

ENTERED

I: A :51.
Rams


FEB 15 as

AT SEATTLE

WESTERN DISTRICT OF

BY

UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

UNITED STATES OF AMERICA,
Plaintiff

V.

RAPHAEL A. SANCHEZ

Defendant.

 

 

COURT
s. OISTRIC HINGTON
CLERK WAS DEPUTY

NO. 133,9 LRL,

PLEA AGREEMENT

The United States of America, by and through Luke Cass and Jessica C.

Harvey, Trial Attorneys for the Public Integrity Section, Criminal Division, United States

Department of Justice, and RAPHAEL SANCHEZ

the following Plea Agreement:

(hereinafter ?the defendant?) enter into

us. DEPARTMENT OF JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 YORK AVENUE, NW
WASHINGTON, DC. 20005
(202) 514-1412

I?n




meadow?Loam

 

 

Case Document 6 Filed 02/15/18 Page 2 of 16

Charges and Statutory Penalties

l. The defendant agrees to waive indictment and to plead guilty to a two?count
Information charging him with one count of wire fraud in violation of 18 U.S.C. 1343
and one count of aggravated identity theft in violation of 18 U.S.C. 1028A.

2. The defendant understands that Count One has the following essential
elements, each of which the United States would be required to prove beyond a reasonable
doubt at trial:

a. First, that the defendant knowingly devised a scheme or arti?ce to
defraud;

b. Second, that the defendant did so with the intent to defraud;

0. Third, that the scheme or arti?ce to defraud involved a materially false
or fraudulent pretense, representation, or promise; and

. d. Fourth, that the defendant transmitted or caused to be transmitted by
means of wire communication in interstate or foreign commerce,
writings, signs, signals, pictures, or sounds for the purpose ofeXecuting
such scheme or attempting to do so.

3. The defendant understands Count Two has the following essential elements,
each of which the United States would be required to prove beyond a reasonable doubt at
trial:

a. First, that the defendant committed an enumerated felony offense as
defined in 18 U.S.C. 1028A(c)(5), speci?cally wire fraud as alleged
in Count One of the Information;

b. Second, that during and in relation to that offense, the defendant
knowingly transferred, possessed, or used a means of identification of
a real person;

0. Third, that the defendant did so without lawful authority;

2 us. DEPARTMENT OF JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 New YORK AVENUE, NW
WASHINGTON, DC. 20005
(202) 514?1412






 

 

Case Document 6 Filed 02/15/18 Page 3 of 16

d. Fourth, that the means of identi?cation belonged to another person;
and I

e. Fifth, that the defendant knew that the means of identi?cation belonged
to another person.

4. The defendant understands that pursuant to 18 U.S.C. 1343, Count One
carries a maximum sentence of thirty years of imprisonment, a ?ne of up to $1,000,000,
and a term of supervised release of not more than ?ve years. Defendant must also pay a
Special Monetary Assessment of $100.00 at or before the time of sentencing.

5. The defendant understands that pursuant to 18 U.S.C. 1028A, Count Two
carries a statutory mandatory minimum sentence of two years of imprisonment that must
be imposed consecutive to any other sentence imposed by the Court, a ?ne of up to
$250,000, and a term of supervised release of not more than one year. Defendant must also
pay a Special Monetary Assessment of $100.00 at or before the time of sentencing.

6. The defendant understands that supervised release is a period of time
following imprisonment during which he will be subject to certain restrictive conditions
and requirements. The defendant further understands that if supervised release is imposed
and he violates one or more of the conditions or requirements, the defendant could be
returned to prison for all or part of the term of supervised release that was originally
imposed. This could result in the defendant?s serving a total term of imprisonment greater
than the statutory maximum stated above.

7. The defendant understands that as a part of any sentence, in addition to any
term of imprisonment and/or ?ne that is imposed, the Court may order the defendant to
pay restitution to any victim of the offense, as required by law.

8. As part of this Plea Agreement, the Public Integrity Section agrees not to
prosecute the defendant for any additional offenses known to it as of the time of this
Agreement that are based upon evidence in its possession at this time, and that arise out of

the conduct giving rise to this investigation. In this regard, the defendant recognizes the

3 US. DEPARTMENT OF JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 NEW YORK AVENUE, NW
WASHINGTON, DC. 20005
(202)514?1412





 

 

Case Document 6 Filed 02/15/18 Page 4 of 16

Public Integrity Section has agreed not to prosecute all of the criminal charges the evidence
establishes were committed by the defendant solely because of the promises made by the
defendant in this Agreement. The defendant agrees, however, that for purposes of
preparing the Presentence Report, the Public Integrity Section will provide the United
States Probation Office with evidence of all conduct committed by the defendant. This
agreement is not intended to provide any limitation of liability arising out of any crimes of
violence that may have been committed by the defendant.

Factual Stipulations

9. The defendant agrees that the attached ?Factual Basis for Plea? fairly and
accurately describes the defendant?s actions and involvement in the offenses to which the
defendant is pleading guilty. The defendant knowingly, voluntarily, and truthfully admits
the facts set forth in the Factual Basis for Plea, and that the United States would prove each
of the facts beyond a reasonable doubt if this case proceeded to trial.

Sentencing

10. The defendant acknowledges that no one has promised or guaranteed what
sentence the Court will impose. The defendant is aware that the sentence will be imposed
by the Court after considering the United States Sentencing Guidelines and related Policy
Statements (hereinafter or ?Sentencing Guidelines?). The defendant
acknowledges and understands that the Court will compute an advisory sentence under the
Sentencing Guidelines and that the applicable guidelines will be determined by the Court
relying in part on the results of a Pre-Sentence Investigation conducted by the Court?s
probation of?ce, which will commence after the guilty plea has been entered. The
defendant is also aware that, under certain circumstances, the Court may depart from the
advisory sentencing guideline range that it has computed, and may increase that advisory
guidelines range up to and including the statutory maximum sentence, or lower that
advisory guidelines range. The defendant is further aware and understands that the Court

is required to consider the advisory guideline range determined under the Sentencing

4 US. OF JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 New YORK AVENUE, NW
WASHINGTON, DC. 20005
(202) 514-1412






 

 

Case Document 6 Filed 02/15/18 Page 5 of 16

Guidelines but is not bound to impose that sentence, that the court is permitted to tailor the
ultimate sentence in light of other statutory considerations, and that such ultimate sentence
may either be more severe or less severe than the Sentencing Guidelines? advisory
sentence. Knowing these facts, the defendant understands and acknowledges that the court
has the authority to impose any sentence within and up to the statutory maximum
authorized by law for the offenses identified in Paragraph One and that the defendant may
not withdraw the plea solely as a result of the sentence imposed.

11. The United States reserves the right to inform the Court and the probation
office of all facts pertinent to the sentencing process, including all relevant information
concerning the offenses committed, whether charged or not, as well as concerning the
defendant and the defendant?s background. Subject only to the express terms of any
agreed?upon sentencing recommendations contained in this Plea Agreement, the United
States further reserves the right to make any recommendation as to the quality and quantity
of punishment.

12. The defendant is aware that any estimate of the probable sentence or the
probable sentencing range relating to the defendant pursuant to the advisory Sentencing
Guidelines that the defendant may have received from any source is only a prediction and
not a promise, and is not binding on the United States, the probation office, or the Court,
except as expressly provided in this Plea Agreement.

Sentencing Guidelines Stipulations .

13. The defendant understands that the sentence in this case will be determined
by the Court, pursuant to the factors set forth in 18 U.S.C. 355 including a
consideration of the Sentencing Guidelines as set forth in the Guidelines Manual for 2016.
Pursuant to Federal Rule of Criminal Procedure and to assist the Court in
determining the apprOpriate sentence, the parties stipulate to the following:

a. Offense Level under the Guidelines

5 us. DEPARTMENT OF JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 NEW YORK AVENUE, NW
WASHINGTON, DC. 20005
(202)514-1412






 

 

Case Document 6 Filed 02/15/18 Page 6 of 16

i. Count One: Wire Fraud

The parties agree to a Total Adjusted Offense Level of 20 based for Count

One based on the following stipulated calculation:

 

Base Offense Level 7
Loss Amount of more than $150,000 2B 1 10
Sophisticated Means 2
Vulnerable Victim 3A1 2
Abuse of Position of Trust (8 3Bl.3) 2
Total Offense Level: 23

ii. Count Two: Aggravated Identity Theft

Pursuant to U.S.S.G. for a defendant convicted of
violating 18 U.S.C. 1028A, the Guideline sentence is the term of imprisonment required
by statute. Therefore, the Guideline sentence for Count Two of the Information is 24

months of imprisonment consecutive to Count One of the Information.

b. Acceptance of Responsibility
Provided that the defendant clearly demonstrates acceptance of responsibility, to the
satisfaction of the United States, through the defendant?s allocution and subsequent
conduct prior to the imposition of sentence, the United States ams that a 2?level reduction
would be appromiate, pursuant to .S.S.G The United States, however, may
oppose any adjustment for acceptance of responsibility if the defendant:
i. fails to admit a complete factual basis for the plea at the time the
defendant is sentenced or at any other time;
ii. challenges the adequacy or sufficiency of the United States? offer of
proof at any time after the plea is entered;

- 6 us. DEPARTMENT OF JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 YORK AVENUE, NW
WASHINGTON, DC. 20005
(202)514-1412






 

 

Case Document 6 Filed 02/15/18 Page 7 of 16

denies involvement in the offense;

iv. gives conflicting statements about that involvement or is untruthful
with the Court, the United States or the Probation Of?ce;

v. fails to give complete and accurate information about the defendant?s
?nancial status to the Probation Office;

vi. obstructs or attempts to obstruct justice, prior to sentencing;

vii. has engaged in conduct prior to signing this Plea Agreement which
reasonably could be viewed as obstruction or an attempt to obstruct
justice, and has failed to fully disclose such conduct to the United
States prior to signing this Plea Agreement;

fails to appear in court as required;

ix. after signing this Plea Agreement, engages in additional criminal
conduct; or

x. attempts to Withdraw the plea of guilty.

If the defendant has accepted responsibility as described above, and given that the
defendant?s offense level is sixteen (16) or greater, the United States agrees that an
additional l?level reduction would be appropriate. pursuant to 3E1 . 1(b) ofthe Sentencing
Guidelines, because the defendant has assisted authorities by providing timely notice of the
defendant?s intention to enter a plea of guilty, thereby permitting the United States to avoid
preparing for trial and permitting the Court to allocate its resources efficiently.

In accordance with the above, the Defendant?s applicable Guidelines Offense Level
is_29,

c. Criminal History Category .

Based upon the information now available to the United States, including
representations by the defense, the defendant has no criminal history. In accordance with
the above, therefore, the defendant?s Criminal History Category is I.

d. Applicable Guideline Range

7 us. DEPARTMENT or JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 NEW YORK AVENUE, NW
WASHINGTON, DC. 20005
(202)514?1412






 

 

Case Document 6 Filed 02/15/18 Page 8 of 16

Based upon the calculations set forth above, the defendant?s stipulated Sentencing
Guidelines range is thirty?three to forty-one months (the ?Stipulated Guidelines Range?).
In addition, there is a mandatory consecutive term of imprisonment for conviction under
18 U.S.C. 1028A, adding twenty?four months to this range.

e. I A_.greed Recommendation Regarding Imprisonment

Pursuant to Federal Rule of Criminal Procedure 1 the parties jointly agree
to recommend 24 months of imprisonment for Count One and 24 months of imprisonment
for Count Two to be served consecutively for a total term of forty?eight (48) months of
imprisonment. The defendant understands that this recommendation is not binding on the
Court and that the Court may reject the recommendation of the parties and may impose any
term of imprisonment up to the statutory maximum penalty authorized by law. The
defendant further understands that he cannot withdraw his guilty pleas simply because of
the sentence imposed by the district court. Except as otherwise provided in this Plea
Agreement, the parties are free to present arguments regarding any other aspect of
sentencing.

Court Not Bound by the Plea Agreement

14. The defendant understands that pursuant to Federal Rules of Criminal
Procedure and the Court is not bound by the above stipulations,
either as to questions of fact or as to the parties? determination of the applicable Guidelines
range, or other sentencing issues. In the event that the Court considers any Guidelines
adjustments, departures, or calculations different from any stipulations contained in this
Plea Agreement, or contemplates a sentence outside the Guidelines range based upon the
general sentencing factors listed in 18 U.S.C. 3553(a), the parties reserve the right to
answer any related inquiries from the Court.

Rights Under Rule 11(b), Fed. R. Crim. P.

15. The defendant understands that the Government has the right, in a

prosecution for perjury or false statement, to use against the defendant any statement that

3 us. DEPARTMENT OF JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 NEW YORK AVENUE, NW
WASHINGTON, D.C. 20005
(202)514-1412





 

 

Case Document 6 Filed 02/15/18 Page 9 of 16

the defendant gives under oath during the guilty plea colloquy. The defendant also
understands that the defendant has the right: (A) to plea not guilty, or having already so
pleaded, the right to persist in that plea; (B) to a Speedy and public trial before a jury of his
peers; (C) to the effective assistance of counsel at trial, including, if the defendant could
not afford an attorney, the right to have the Court appoint one for him; (E) to be presumed
innocent until guilt has been established beyond a reasonable doubt at trial; (F) to confront
and cross?examine adverse witnesses; (G) to compel or subpoena witnesses to appear on
his behalf at trial; and (H) to testify or remain silent at trial, at which trial such silence could
not be used against the defendant. The defendant also understands that the Constitution
guarantees the right to be considered for release until trial]; and if found guilty of the
charges, the right to appeal the conviction on such charges to a higher court. The defendant
understands that if the Court accepts this plea of guilty, the defendant waives all of these
rights.

Waiver of Appellate Rights and Rights to Collateral Attack

16. The defendant is aware that the defendant has the right to challenge the
defendant?s sentence and guilty plea on direct appeal. The defendant is also aware that the
defendant may, in some circumstances, be able to argue that the defendant?s guilty plea
should be set aside, or sentence set aside or reduced, in a collateral challenge (such as
pursuant to a motion under 28 U.S.C. 2255). Knowing that, and in exchange for the
promises made by the government in entering this Plea Agreement, the defendant
voluntarily and expressly waives all rights to appeal or collaterally attack the defendant?s
conviction, sentence, or any other matter relating to this prosecution, whether such a right
to appeal or collateral attack arises under 18 U.S.C. 3742, 28 U.S.C. 1291, 28 U.S.C.

2255, or any other provision of law.

 

1 Title 18, U.S.C. 3141?3156, Release and Detention Pending Judicial Proceedings.

9 US. DEPARTMENT OF JUSTICE
CRIMINAL DIVISION
PUBLIC SECTION
1400 NEW YORK Avenue, NW
WASHINGTON, DC. 20005
(202)514-1412






 

 

Case Document 6 Filed 02/15/18 Page 10 of 16

a. Notwithstanding the waiver provision above, if the government appeals from the
sentence, then the defendant may file a direct appeal of the defendant?s sentence.

b. If the government does not appeal, then notwithstanding the waiver provision set
forth in this paragraph, the defendant may file a direct appeal or petition for

collateral relief but may raise only a claim, if otherwise permitted by law in such a

proceeding:

i. that the defendant?s sentence on any count of conviction exceeds the

statutory maximum for that count as set forth above;

ii. challenging a decision by the sentencing judge to impose an ?upward

departure? pursuant to the Sentencing Guidelines;

challenging a decision by the sentencing judge to impose an ?upward

variance,? pursuant to 18 U.S.C. 35 53(a), above the ?nal Sentencing
Guidelines range determined by the Court; and

iv. that an attorney who represented the defendant during the course of this

criminal case provided constitutionally ineffective assistance of counsel.

If the defendant does appeal or seek collateral relief pursuant to this subparagraph,
no issue may be presented by the defendant in such a proceeding other than those described
in this subparagraph.

17. By signing this Plea Agreement, the defendant acknowledges that the
defendant has discussed the appellate and collateral attack waivers set forth in Paragraph
16 of this Plea Agreement with the defendant?s attorney. The defendant further agrees,
together with the United States, to request that the Court enter a specific finding that the
waiver of the defendant?s right to appeal the sentence to be imposed in this case was
knowing and voluntary.

18. The defendant?s waiver of rights in Paragraph 15 shall not apply to appeals
or challenges based on new legal principles in the United States Court of Appeals for the
Ninth Circuit or the United States Supreme Court cases decided after the date of this Plea

10 us. DEPARTMENT OF JUSTICE
CRIMINAL DIVISION
PUBLIC SECTION
1400 New YORK AVENUE, NW
D.C. 20005
(202)514-1412






 

 

Case Document 6 Filed 02/15/18 Page 11 of 16

Agreement that are held by the United States Court of Appeals for the Ninth Circuit or the
United States Supreme Court to have retroactive effect.
Restitution

19. In addition to the other penalties provided by law, the Court must also order
the defendant to make restitution pursuant to 18 U.S.C. 3663A. The defendant
understands that restitution must be ordered by the Court to all victims of the defendant?s
criminal conduct and not merely for those victims included in the counts to which the
defendant agrees to plead guilty. The parties agree that the defendant will make full and
complete restitution, with the final amount to be determined prior to sentencing and
specified in the Presentence Report. The defendant also agrees to repay any and all
amounts owed to the United States of America or the Internal Revenue Service as a result
of defendant?s false filings on his tax returns. The defendant understands that restitution
may be ordered by the Court to all victims of the defendant?s criminal conduct and not
merely for those victims included in the counts to which the defendant agrees to plead
guilty. The defendant further acknowledges that he may be required to pay for credit?
monitoring services for the aforementioned Victim Aliens to ensure that their credit is
properly repaired.

Breach of Agreement

20. The defendant understands and agrees that if, after entering this Plea
Agreement, the defendant fails Specifically to perform or to fulfill completely each and
every one of the defendant?s obligations under this Plea Agreement, or engages in any
criminal activity prior to sentencing, the defendant will have breached this Plea Agreement.
In the event of such a breach:

a. the United States will be free from its obligations under the Plea Agreement;

b. the defendant will not have the right to withdraw the guilty plea;

c. the defendant shall be fully subject to criminal prosecution for any other crimes,

including perjury and obstruction of justice; and

1 1 U.S. DEPARTMENT 
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 New YORK AVENUE, NW
WASHINGTON, DC. 20005
(202) 514-1412






 

 

Case Document 6 Filed 02/15/18 Page 12 of 16

d. the United States will be free to use against the defendant, directly and indirectly,
in any criminal or civil proceeding, all statements made by the defendant and
any of the information or materials provided by the defendant, including such
statements, information, and materials provided pursuant to this Plea Agreement
or during the course of any debriefings conducted in anticipation of, or after
entry of this Plea Agreement, including the defendant?s statements made during
proceedings before the Court pursuant to Rule 11 of the Federal Rules of
Criminal Procedure.

21. The defendant understands that Rule 11(f) of the Federal Rules of Criminal
Procedure and Rule 410 of the Federal Rules of Evidence ordinarily limit the admissibility
of statements made by a defendant in the course of plea discussions or plea proceedings if
a guilty plea is later Withdrawn. The defendant knowingly and voluntarily waives the rights
arising under these rules.

22. The defendant understands and agrees that the United States shall only be
required to prove a breach of this Plea Agreement by a preponderance of the evidence. The
defendant further understands and agrees that the United States need only prove a violation
of federal, state, or local criminal law by probable cause in order to establish a breach of
this Plea Agreement.

23. Nothing in this Plea Agreement shall be construed to permit the defendant to
commit perjury, to make false statements or declarations, to obstruct justice, or to protect
the defendant from prosecution for any crimes not included within this Plea Agreement or
committed by the defendant after the execution of this Plea Agreement. The defendant
understands and agrees that the United States reserves the right to prosecute the defendant
for any such offenses. The defendant further understands that any perjury, false statements
or declarations, or obstruction of justice relating to the defendant?s obligations under this
Plea Agreement shall constitute a breach of this Agreement. In the event of such a breach,

however, the defendant will not be permitted to withdraw this guilty plea.

12 us. DEPARTMENT OF JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 NEW YORK AVENUE, NW
WASHINGTON, DC. 20005
(202) 514?1412






 

 

Case Document 6 Filed 02/15/18 Page 13 of 16

Waiver of Statute of Limitations

24. It is further agreed that should any conviction following the defendant?s plea
of guilty pursuant to this Plea Agreement be vacated for any reason, then any prosecution
that is not time-barred by the applicable statute of limitations on the date of the signing of
this Plea Agreement (including any counts that the United States has agreed not to
prosecute or to dismiss at sentencing pursuant to this Plea Agreement) may be commenced
or reinstated against the defendant, notwithstanding the expiration of the statute of
limitations between the signing of this Plea Agreement and the commencement or
reinstatement of such prosecution. It is the defendant?s intent in entering this Plea
Agreement to waive all defenses based on the statute of limitations with respect to any
prosecution that is not time-barred on the date that this Plea Agreement is signed.

Voluntariness of Plea

25. The defendant agrees that he has entered into this Plea Agreement freely and
voluntarily and that no threats or promises, other than the promises contained in this Plea
Agreement, were made to induce the defendant to enter his pleas of guilty.

Complete Agreement

26. No agreements, promises, understandings, or representations have been

made by the parties or their counsel?either orally, in writing, or by any other means?

. other than those contained in writing herein, nor will any such agreements, promises,

understandings, or representations be made unless committed to writing and signed by the
defendant, defense counsel, and a prosecutor for the Public Integrity Section.

27. The defendant further understands that this Plea Agreement is binding only
upon the Public Integrity Section, Criminal Division, United States Department of Justice.
This Plea Agreement does not bind any other of?ce or component of the United States

Department of Justice, including the United States Attorneys? Of?ces, nor does it bind any

state or local authorities. It also does not bar or compromise any civil, tax, or administrative

claim pending or that may be made against the defendant.

- 13 us. DEPARTMENT OF JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 NEW YORK AVENUE, NW
WASHINGTON, DC. 20005
(202) 514?1412






 

 

Case Document 6 Filed 02/15/18 Page 14 of 16

28. By signing the Plea Agreement in the space indicated belOw and returning

the original once it has also been signed by counsel for the defendant, the defendant

acknowledges that the terms and conditions of this Plea Agreement are satisfactory.

-14

ANNALOU TIROL
Acting Chief
Public Integrit Section

By: 34M 
face Cass
Jessica C. Harvey
Trial Attorneys
Public Integrity Section
1400 New York Ave. NW
Washington, DC 20005 
(202) 514?1412

US. DEPARTMENT OF JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 YORK AVENUE, NW
WASHINGTON, DC. 20005
(202) 514-1412






 

 

Case Document 6 Filed 02/15/18 Page 15 of 16

ACCEPTANCE

I have read this Plea Agreement in its entirety and discussed it with my attorney. I
hereby acknowledge that it fully sets forth my agreement with the United States. I further
state that no additional promises or representations have been made to me by any of?cial
of the United States in connection with this matter. I understand the crimes to which I have
agreed to plead guilty, the maximum penalties for those offenses and Sentencing Guideline
penalties potentially applicable to them. I am satis?ed with the legal representation
provided to me by my attorney. We have had sufficient time to meet and discuss my case.
We have discussed the charges against me, possible defenses I might have, the terms of
this Plea Agreement and whether I should go to trial. I am entering into this Plea
Agreement freely, voluntarily,'and knowingly because I am guilty ofthe offenses to which

I am pleading guilty, and I believe this Plea Agreement is in my best interest.

Date: 1; 

Raphael A. Sanchez
Defendant

15 us. OF JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 NEW YORK AVENUE, NW
WASHINGTON, DC. 20005
(202) 514-1412





 

 

Case Document 6 Filed 02/15/18 Page 16 of 16

. ACKNOWLEDGMENT

I have read each of the pages constituting this Plea Agreement, reviewed them with
my client, and discussed the provisions of the Plea Agreement with my client, fully. These

pages accurately and completely set forth the entire Plea Agreement.

 

 

Date: 1 Orb;
L.
Cassandra R. Stamm
For the Defendant
.. 16 U.S. OF JUSTICE

CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 NEW YORK AVENUE, 
WASHINGTON, DC. 20005
(202) 5 14-1412