Case Document Mil?wage 10f l7 APR 0 5 2018 ERK re steam BY DEPUTY KEVIN M. RAPP (Ariz. Bar No. 14249, kevinrappfa us otgov DOMINIC LANZA (Cal. Bar No. 225989, dorninic.Ianza@usdoi.gov) MARGARET PERLMETER (Ariz. Bar No. 024805, JOHN J. KUCERA (Cal. Bar No. 274184, iohn.kucera@usdoi.gov) Assistant US. Attorneys 40 N. Central Avenue, Suite 1800 Phoenix, Arizona 85004-4408 Telephone (602) 514?7 500 JOHN P. CRONAN Acting Assistant Attorne General 1 Criminal Division, US. . epartment of Justice 1, REGINALD E. JONES (Miss. Bar No. 102806, reginaldiones4?usdoi.go? Senior rial Attorney, US. Department of Justice 1 Child Exploitation and Obscemty Section 1 950 Ave N.W., Room 21. .16 Washington, DC. 20530 Telephone (2021) 616-2807 Attorneys for aintiff ELIZABETH. A. STRANGE First Assistant United States Attorney CL District of Arizona 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States of America, Plaintiff, PLEA AGREEMENT vs. TN: Carl Allen Ferrer I Carl errer, Defendant. Plaintiff, United States of America, and the defendant, Carl errer, hereby agree to dispose of this matter on the following terms and conditions: 1- 2&4. The defendant will plead guilty to an Information charging the defendant with a violation of 18 United States Code (U.S.C.) 371, Conspiracy, a Class felony offense. cc: AUSA, Defense Counsel. USPO Case Document 7-1 Filed 04/05/18 Page 2 of 17 2. MAXIMUM PENALTIES a. A violation of 18 U.S.C. 371 is punishable by a maximum fine of $250,000 (or, if any person derived pecuniary gain from the offense, or if the offense resulted in pecuniary loss to a person other than the defendant, not more than the greater of twice the gross gain or twice the gross loss), a maximum term of imprisonment of 5 years, or both, and a term of supervised release of 3 years. probation is five years. b. According to the Sentencing Guidelines issued pursuant to Reform Act of 1984, the Court shall order the defendant to: (1) ?3663 and/or 3663A, unless the Court determines that restitution appropriate; fine is not appropriate; (3) serve a term of supervised release when required by a sentence of imprisonment of more than one year is imposed (with the that the Court may impose a term of supervised release in all other cases); (4) which the defendant pleads guilty pursuant to 18 U.S.C. 3013. pay upon. conviction a $100 special assessment for A maximum term of the Sentencing make restitution to any victim of the offense pursuapt to 18 U.S.C. lwould not be (2) pay a fine pursuant to 18 U.S.C. 3572, unless the Cburt finds that a statute or when understanding and each count to c. The Court is required to consider the Sentencing Guidelines in determining the defendant?s sentence. However, the Sentencing Guidelines are adyisory, and the Court is free to exercise its discretion to impose any reasonable sentence up to the maximum set by statute for the crime(s) of conviction, unless there are sti contrary that the Court accepts. 3. AGREEMENTS REGARDING SENTENCING pulations to the a. Immediate Shutdown of Backnage Website: The defendant stipulates and agrees that, upon entry of his guilty plea, he will take all steps within his power to immediately shut down the website (?Backpage?) -2- in the United Case Document 7-1 Filed 04/05/18 Page 3 of 1b 1 States and all other countries in which the website operates. Such steps shall include, but not be limited to, surrendering to the United States the registration accbunt, including login and password information, for the domain na 1 necessary to operate the various Backpage websites and providing technical assistanc to the United States to effectuate the shutdown. If the defendant fails to take all steps ithin his power to immediately shut down the website, this plea agreement shall be null and void and the United States shall be free to prosecute the defendant for all crimes of which it then has knowledge. In such event, the defendant waives any and all objections, motions, and defenses based upon the Statute of Limitations, the Speedy Trial Act, or constitutional restrictions in bringing later charges or proceedings. b. Forfeiture Assistance: The defendant stipulates and agrees tihat, upon entry of his guilty plea, he will take all steps within his power to forfeit to the United States all corporate assets and other property owned or controlled by Website Technologies, LLC (?Website Technologies?), which owns and operates the Backpage website, as well as all corporate assets and other property owned or controlled by Backpageconi, LLC, Posting Solutions LLC, Amstel River Holdings, LLC, Ad Tech BV, and UGC Tech Group CV. Such steps shall include, but not be limited to, agreeing to the forfeiture of the domain names, servers, intellectual property, trademarks, trade secrets, bank accounts, and other financial instruments owned or controlled by such entities. If the defendant fails to comply with this agreement, this plea agreement shall be null and void and the United States shall be free to prosecute the defendant for all drimes of which it then has knowledge. In such event, the defendant waives any andall objections, motions, and defenses based upon the Statute of Limitations, the SpeedF/ Trial Act, or constitutional restrictions in bringing later charges or proceedings. 0. California And Texas Proceedings: It is the parties? extpectation that, concurrently, or as close in time as is practicable to the time the defemdant enters his guilty plea in this case, the defendant also will enter guilty pleas to Backpageu-related charges in California and Texas state court. Pursuant to Fed. R. Crim. P. the -3- \1 Case Document 7-1 Filed 04/05/18 Page 4 of 1 United States and the defendant stipulate that the defendant?s guilty plea in this case is contingent upon the state courts? acceptance of his plea agreements in the California and Nueces County, Texas matters. If either of those plea agreements is rejected, the defendant will be afforded an opportunity to withdraw his guilty plea in th ?3 case. (1. Concurrency With State Sentences: Pursuant to Fed. R. Crim. P. the United States and the defendant stipulate that the antic pated terms of imprisonment in the aforementioned California and Texas proceedings ivill arise from ?relevant conduct to the instant offense of conviction.? Accordingly, under U.S.S.G. the United States and the defendant stipulate that any term of imprisonment imposed in this case shall run concurrently with any terms of imprisonment subsequently imposed in the aforementioned California and Texas proceedings. 6. Federal Custody. Pursuant to Fed. R. Crim. P. the United States and the defendant stipulate that, to the extent the defendant is sentenced to concurrent terms of federal and state imprisonment, the defendant will serve all concurrent time in federal custody. f. Ability To Request Downward DepartureNariance: The defendant reserves the right to request a downward departure or a downward variance based on the factors set forth in 18 U.S.C. 3553(a). The defendant understands that the government is free to oppose any such request. g. Restitution. Pursuant to 18 U.S.C. 3663 and/or 3663A, the defendant speci?cally agrees to pay full restitution, regardless of the resulting loss amount but in no event more than $500 million, to all victims directly or proximately harmed by the defendant?s ?relevant conduct,? including conduct pertaining to any dism uncharged conduct, as de?ned by U.S.S.G. 1B1.3, regardless of whethe constitutes an ?offense? under 18 U.S.C. 2259, 3663 or 3663A. understands that such restitution will be included in the Court?s Order of that an unanticipated restitution amount will not serve as grounds to defendant?s guilty plea or to withdraw from this plea agreement. -4- issed counts or such conduct The defendant 'Judgment and withdraw the Case Document 7-1 Filed 04/05/18 Page 5 of 17 h. Assets and Financial Responsibility. The defendant shall make a full accounting of all assets in which the defendant has any legal or equitable interest. The defendant shall not (and shall not aid or abet any other party to) sell, hide, waste, spend, or transfer more than $500 of any such assets or property before lsentencipg, without the prior approval of the United States (provided, however, that no prior approval will be required for routine, day-today expenditures). The defendant also expr ssly authorizes the United States Attorney?s Of?ce to immediately obtain a credit rjport as to the defendant in order to evaluate the defendant?s ability to satisfy any ?nancial obligation imposed by the Court. The defendant also shall make full disclosure ofall current and projected assets to the US. Probation Of?ce immediately and prior to the termination of the defendant?s supervised release or probation, such disclosures to be shared with the US. Attorney?s Of?ce, including the Financial Litigation Unit, for any rpose. Finally, the defendant shall participate in the Inmate Financial Responsibility Pfiygram to ful?ll all. financial obligations due and owing under this agreement and the law. i. Acceptance of Responsibility. If the defendant makes full and complete disclosure to the US. Probation Of?ce of the circumstances surrounding the defendant?s commission of the offense, and if the defendant demonstrates an acceptance of responsibility for this offense up to and including the time of sentencing, the United States will recommend a two-level reduction in the applicable Sentenriing Guidelines offense level pursuant to U.S.S.G. If the defendant has an offense level of 16 or more, the United States will move the Court for an additional one-level reduction in the applicable Sentencing Guidelines offense level pursuant to U.S.S.G. 4. AGREEMENT TO DISMISS OR NOT TO PROSECUTE a. This of?ce shall not prosecute the defendant for any offenses committed by the defendant, and known by the United States, in connection with the} subject matter described in the factual basis of this agreement. b. This agreement does not, in any manner, restrict the actions of the United States in any other district or bind any other United States Attorney?s Of?cie. -5- 1 Case Document 7-1 Filed 04/05/18 Page 6 of 17 5. COURT APPROVAL REINSTITUTION OF a. If the Court, after reviewing this plea agreement, conciudes that any provision contained herein is inappropriate, it may reject the plea agreement and give the defendant the Opportunity to withdraw the guilty plea in accordance with ed. R. Crim. P. b. If the defendant?s guilty plea or plea agreement is rejected, withdrawn, vacated, or reversed at any time, or if the state courts considering related. claims in California and Texas reject the defendant?s plea agreements in thdse states, this agreement shall be null and void, the United States shall be free to? prosecute the defendant for all crimes of which it then has knowledge and any chargesthat have been dismissed because of this plea agreement shall automatically be reinstated. In such event, the defendant waives any and all objections, motions, and defenses tiased upon the Statute of Limitations, the Speedy Trial Act, or constitutional restrictions in bringing later charges or proceedings, and any statements made by the defendant at The time of his change of plea or sentencing in this case may not be used against him in any subsequent hearing, trial, or proceeding. 6. WAIVER OF DEFENSES AND APPEAL RIGHTS - The defendant waives (1) any and all motions, defenses, probable cause determinations, and objections that the defendant could assert to the indictment or information; and (2) any right to ?le an appeal, any collateral attack, and any other writ or motion that challenges the conviction, an order of restitution or forfeiture, the entry of judgment against the defendant, or any aspect of the defendant's sentence, including the manner in which the sentence is determined, including but not limited to any appeals under 18 U.S.C. 3742 (sentencing appeals) and motions under 28 2241 and 2255 (habeas petitions), and any right to ?le a motion for modificatidn of sentence, including under 18 U.S.C. 3582(c). This waiver shall result in the dismissal of any appeal, collateral attack, or other motion the defendant might ?le cihallenging the conviction, order of restitution or forfeiture, or sentence in this case. Tliis waiver shall -6- Case Document 7-1 Filed 04/05/18 Page 7 of 17 not be construed to bar an otherwise?preserved claim of ineffective assistance of counsel or of ?prosecutorial misconduct? (as that term is de?ned by Section ll.Biof Ariz. Ethics Op. 15-01 (2015)). 7. DISCLOSURE OF INFORMATION a. The United States retains the unrestricted right to provide ihformation and, make any and all statements it deems appropriate to the U.S. Probation Of?ce and to the Court in connection with the case. I b. Any information, statements, documents, and evidence that the defendant provides to the United States pursuant to this agreement may be uSed against the defendant at any time. i c. The defendant shall cooperate fully with the U.S. Probatio Of?ce. Such cooperation shall include providing complete and truthful responses to questions posed by the U.S. Probation Of?ce including, but not limited to, questions relating to: criminal convictions, history of drug abuse, and mental illness; and (2) financial information, including present ?nancial assets or liabilities that relate to the ability of the defendant to pay a ?ne or restitution. 8. FORFEITURE, CIVIL, AND ADMINISTRATIVE PROCEEDINGS a. Pursuant to 18 U.S.C. the defendant agreesi to forfeit, and hereby forfeits, all interest in any property, real or personal, which constitutes or is derived from proceeds traceable to the offense. Such property includes, but is not limited to, all right, title, and interest in funds held in the following bank accounts: (1) Republic Bank of Arizona account number x2912 (2) Republic Bank of Arizona account number x2500 (3) Green Bank account number x4832 (4) Plains Capital Bank account number x1098 Such property further includes, but is not limited to, all right, title, and interest in the following domain names: (1) atlantabackpage.com Case Document 7-1 Filed 04/05/18 Page 8 of 17 (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) (21) (22) (23) (24) (25) (26) (27) (28) (29) backpagebe backpage.com backpage.com.br backpage.cz backpagedk backpage.ee backpage.es backpage? backpagefr backpage. gr backpagehu backpage.ie backpage.it backpage.1t backpagemx backpage.net backpageno backpagepl backpagept 3 backpage.ro i backpagesi backpagesk backpageus backpage?insider.com bestoibackpage?om bestofbigcity.com bigcity.com chicagobackpage.com -3- Case Document 7-1 Filed 04/05/18 Page 9 of 17 (30) denverbackpage.corn (3 1) newyorkbackpagecorn (32) phoenixbackpagecom (33) sandiegobackpagecom (34) seattlebackpagecom (35) tampabackpagecom Such property further includes, but is not limited to, all right, title, and interest in any funds remaining in the following IOLTA bank accounts at the conclusion of litigation (with the understanding that the funds currently deposited in those IOLTA bank accounts may only be Withdrawn by counsel based on the provision of legal serviced): (1) First Republic Bank IOLTA Account x6180 (2) First Republic Bank IOLTA Account x6255 (3) First Republic Bank IOLTA Account x5978 1 (4) All funds previously deposited in Wells Fargo Account 1 x7091 to fund the criminal defense of Backpagecom, LLC, Website Technologies, LLC, Posting Solutions LLC, Amstel River Holdings LLC, Ad Tech Bv, and/or UGC Tech Group BV Such property further includes, but is not limited to, all right, title, and interest in any funds previously advanced to a bail bond service (with the understanding that, should the defendant not be required to post a bond in this matter, he will take imnfediate steps to recover any funds previously advanced to a bail bond service and surrender those funds to the United States for forfeiture). b. The United States and. the defendant further agree that the fpllowing assets are not subject to forfeiture, either in this criminal proceeding or in a future administrative or civil forfeiture proceeding, because the assets were obtained solely with non?Backpage related funds (and, therefore, cannot lawfully be forfeited under the relevant statutes): (1) The real property located at 2531 Tumbleweed Way, Frisco, Texas. -9- Case Document 7-1 Filed 04/05/18 Page 10 of 17 (2) The defendant?s pre?2004 contributions to Millennium Trust IRA account number x2890. c. The defendant further agrees that, other than paragraph 8(b) above, nothing in this agreement shall be construed to protect him from administrative or civil forfeiture proceedings or to prohibit the United States from proceeding with and/or initiating an action for civil forfeiture (either with respect to the property identi?ed above or with respect to additional property that is not subject to forfeiture under 18 U.S.C. 981(a)(1)(C) but may be subject to forfeiture under other provisions). d. The defendant further agrees to waive all interest in all property subject to forfeiture under this agreement in any administrative or judicial forfeit ire proceeding, whether criminal or civil, state or federal. The defendant agrees to consenji to the entry of orders of forfeiture for such property and waives the requirements of Federal Rules of Criminal Procedure 32.2 and 43(a) regarding notice of the forfeiture the charging instrument, announcement of the forfeiture at sentencing, and incorporation of the forfeiture in the judgment. The defendant further understands and agrees that forfeiture of the property is appropriate and in accordance with the applicable forfeiture statutes, which may include Title 8 U.S.C. 1324(b), Title 18 U.S.C. 924(d)i 981, 982 and 2253, Title 21 U.S.C. 853 and 881, and Title 28 U.S.C. 2461(c). e. Pursuant to 18 U.S.C. 3613, all monetary penalties, including restitution imposed by the Court, shall be due immediately upon judgment, shall be subject to immediate enforcement by the United States, and shall be submitted ti) the Treasury Offset Program so that any federal payment or transfer of returned propert the defendant receives may be offset and applied to federal debts (which offset will not affect the periodic payment schedule). If the Court imposes a schedule of paymen. s, the schedule of payments shall be merely a schedule of minimum payments and shall not be a limitation on the methods available to the United States to enforce the judgment. f. Forfeiture of the defendant?s assets shall not be treated as satisfaction of any fine, restitution, cost of imprisonment, or any other penalty this court may impose -10- 1 Case Document 7-1 Filed 04/05/18 Page 11 of 17 1 upon the defendant in addition to forfeiture. This agreement does not preciude the United States from instituting any civil or administrative forfeiture proceedirigs as may be appropriate now or in the future. g. The defendant agrees to waive all constitutional and statutory challenges in any manner (including direct appeal, habeas corpus, double jeopardy or arty other means) to any forfeiture imposed as a result of this guilty plea or any pending or completed administrative or civil forfeiture actions, including that the forfeiture constitutes an excessive fine or punishment. The defendant agrees to take all steps as rdquested by the United States to pass clear title to forfeitable assets to the United StatesL and to testify truthfully in any judicial forfeiture proceeding (including any proceeding to adjudicate the claim of any third party to the forfeited assets). The defendant acknowledges that all property covered by this agreement is subject to forfeiture and that no other person or entity has a legitimate claim to these items listed, other than any community property interest that his wife may have in the forfeited assets under state law. h. The defendant agrees not to ?le a claim. to any of the listed property subject to forfeiture under paragraph 8(a) of this agreement in any civil proceeding, administrative or judicial, which may be initiated. The defendant ?irther agrees that he/she will not contest civil, administrative, or judicial forfeiture of that property. The defendant agrees to waive his/her right to notice of any forfeiture proceeding involving this property, and agrees not to file a claim or assist others in ?ling a claim in that forfeiture proceeding. i. The government reserves its right to proceed against any remaining assets .not identi?ed either in this agreement, other than the assets identi?ed in paragraph 8(b) above, or in any civil actions which are being resolved along with this plea of guilty, including any property in which the defendant has any interest or control, if said assets, real or personal, tangible or intangible were involved in the offense(s). j. The defendant hereby waives, and agrees to hold the goveimrnent and its agents and employees harmless from any and all claims whatsoever in cbnnection with "11? Case Document 7-1 Filed 04/05/18 Page 12 of 17 the seizure, forfeiture, and disposal of the property described above. Without limitation, the defendant understands and agrees that by virtue of this plea of guilty 1 the defendant will waive any rights or cause of action that the defendant might otherwise have had to . . . . . claim that he/she 1s a ?substantially prevalling party? for the purpose (of recovery of attorney fees and other litigation costs in any related civil forfeiture proceeding pursuant to 28 U.S.C. 2465(b)(1). 9. the District of Arizona and elsewhere: 10. ELEMENTS Conspiracy Beginning no later than 2004, and continuing through in or around March 2018, in 1. There was an agreement between two or more persons to commit one or more of the crimes of Travel Act?Facilitate Prostitution (18 U.S.C. Concealment Money Laundering (18 U.S.C. International Promotional Money Laundering (I. 8 US .C. Money Laundering (18 U.S.C. 1957(a)), and International Concealment Money Laundering (1.8 U.S.C. l956(aj(2)(B)(i)). 2. The defendant became a member of the conspiracy knowing of at least one of its objects and intending to help accomplish it; and i 3. One of the members of the conspiracy performed at least one overt act for the purpose of carrying out the conspiracy. FACTUAL BASIS a. The defendant admits that the following facts are true and that if this matter were to proceed to trial the United States could prove the following facts beyond a reasonable doubt: In 2004, I co-founded the website (?Backpage?), along with ML. and IL. Backpage eventually became the second?largest classi?ed advertising website in the world and, during its 14 years of existence, has derived -12- Case Document 7-1 Filed 04/05/18 Page 13 of 17 the great majority of its revenue from fees Charged in return for publishing advertisements for ?adult? and ?escort? services. I have long been aware that the great majority of these advertisem ?nts are, in fact, advertisements for prostitution services (which are not protect; by the First Amendment and which. are illegal in 49 states and in much of Ndvada). Acting with this knowledge, I conspired with other Backpage principals (ijcluding but not limited to M.L, J.L, S.S., D.H., AP, and J.V.) to ?nd ways to kno ingly facilitate the state-law prostitution crimes being committed by Backpage?s customers. For example, I worked with my co-conspirators to create ?moderation? processes through which Backpage would remove terms and pictures that were particularly indicative of prostitution and then publish a revised version of the ad. Such editing did not, of course, change the essential nature of the illegal service being offered in the admit was merely intended to create a veneer of deniability for Backpage. These editing practices were only one component of an overall, company?wide culture and policy of concealing and refusing to of?cially acknowledge the true nature of the services being offered in Backpage?s ?escort? and ?adult? ads. In addition to conspiring to knowingly facilitate the state?law prostitution offenses being committed by Backpage?s customers, I also conspired with ther Backpage principals (including but not limited to M.L, J.L, S.S., J.B., and DH.) to engage in various money laundering offenses. Since 2004, Backpage has carried hundreds of millions of dollars in revenue from publishing ?escort? and ?ad 1t? ads. Over time, many banks, credit card companies, and other ?nancial insti utions refused to do business with Backpage due to the illegal nature of its busine In responseworked With my cowconspirators to find ways to fool credit card companies into believing that Backpage-associated charges were being incurred on different -13- \omummemm? Case Document 7-1 Filed 04/05/18 Page 14 of 17 i websites, to route Backpage-related payments and proceeds througli bank accounts held in the name of seemingly unconnected entities (including bu not limited to Posting Solutions, Website Technologies, and Cereus Propertie and to use companies (including but not limited to CoinBase, GoCoin, Paxful, Kraken, and Capital) for similar purposes. b. The defendant shall swear under oath to the accuracy of this statement and, if the defendant should be called upon to testify about this matter in the future, any intentional material inconsistencies in the defendant?s testimony may subject the defendant to additional penalties for perjury or false swearing, which maybe enforced by the United States under this agreement i APPROVAL AND ACCEPTANCE OF THE DEFENDANT I have read the entire plea agreement with the assistance of nty attorney. I understand each of its provisions and I voluntarily agree to it. I have discussed the case and my constitutional. and other rights wiih my attorney. I understand that by entering my plea of guilty I shall waive my rights to plead not guilty, to trial by jury, to confront, cross-examine, and compel the attendance (if witnesses, to present evidence in my defense, to remain silent and refuse to be a witness against myself by asserting my privilege against self-incrimination, all with the assistance of counsel, and to be presumed innocent until proven guilty beyond a reasonable doubt. I agree to enter my guilty plea as indicated above on the terms and conditions set forth in this agreement. I. have been advised by my attorney of the nature of the charges to which I am entering my guilty plea. I have further been advised by my attorney of the nature and range of the possible sentence and that my ultimate sentence shall be determined by the Court after consideration of the advisory Sentencing Guidelines. -14- 1 Case Document 7-1 Filed 04/05/18 Page 15 of 17 My guilty plea is not the result of force, threats, assurances, or lirornises, other than the promises contained in this agreement. I voluntarily agree to the provisions of this agreement and I agree to be bound according to its provisions. I understand that if I am granted. probation or placed on supervised release by the Court, the terms and conditions of such probation/supervised release are subject to modi?cation at any time. I further understand that ifI violate any of the cdnditions of my probation/supervised release, my probation/supervised release may be rexioked and upon such revocation, notwithstanding any other provision of this agreement, I may be required to serve a term of imprisonment or my sentence otherwise may be altered. This written plea agreement, and any written addenda ?led as attachments to this plea agreement, contain all the terms and conditions of the plea. Any additional agreements, if any such agreements exist, shall be recorded in a separate1 document and may be ?led with the Court under seal; accordingly, additional agreemeiits, if any, may not be in the public record. 1 I further agree that promises, including any predictions as to the Sentencing Guideline range or to any Sentencing Guideline factors that will. apply, n1ade by anyone (including my attorney) that are not contained within this written plea agrdement, are null and void and have no force and effect. I am satis?ed that my defense attorney has represented me in a competent manner. I fully understand the terms and conditions of this plea agreement. I am not now using or under the influence of any drug, medication, liquor, or other intoxicant or depressant that would impair my ability to fully understand the terms and conditions of this plea agreement. 4 ?i it?s at (?11 Date CARL FERRER 1 Defendant -15- Case Document 7-1 Filed 04/05/18 Page 16 of i7 1 advised the defendant of all matters within the scope of Fed. R. Cr'm. P. 11, the APPROVAL OF DEFENSE COUNSEL I have discussed this case and the plea agreement with my client in detail and have 1 constitutional and other rights of an accused, the factual basis for and the nature of the offense to which the guilty plea will be entered, possible defenses, and the consequences of the guilty plea including the maximum statutory sentence possible. ll have further discussed the concept of the advisory Sentencing Guidelines with the defendant. No assurances, promises, or representations have been given to me or to the deendant by the United States or any of its representatives that are not contained in this written agreement. I concur in the entry of the plea as indicated above and that the terms and conditions set forth in this agreement are 1n the best interests of my client. I agree to make a bona fide effort to ensure that the guilty plea is entered in accordahce with all the requirements of Fed. R. Crim. P. 11. +906 x. .w 6/ Date NANCI GLARENCE JONATHAN BAUM Attorneys for Defendant -16.. OOQQM-P-WNHOKDOOQONMAWNWO Case Document 7-1 Filed 04/05/18 Page 17 of 17 APPROVAL OF THE UNITED STATES I have reviewed this matter and the plea agreement. I agree on behalf of the United States that the terms and conditions set forth herein are appropriate best interests of justice. at. sacs Date ACCEPTANCE BY THE COURT Date ELIZABETH A. STRANGE First Assistant United States Attorney District of Arizona JOHN P. CRONAN Acting Assistant Attorne General a and are in the Cri?ision, U.S. epartrnent of Justice KEV IN RAPP DOMINIC LANZA MARGARET PERLMETER JOHN J. KUCERA Assistant US. Attorneys REGINALD JONES Senior Trial Attorney United States District Judge