U.S. Department of Justice United States Attorney District of Maryland Southern Division ?lama: P. ll?indont .liail'ittg .vlridress: O?ice Location: 30i-344-0l9? Assistant United States Attorney 6500 herryn'ood' Lane. Suite 200 6406 hy Lane. 8? Floor MAIN: 301-344-4433 Greenbelt. MD 20770-i2-t9 Greenbelt. .1 207 704249 FAX: 301-34445! 6 October 2, 2019 Liz Oyer, Esq. Of?ce of the Federal Public Defender 100 S. Charles St #900 Baltimore, Maryland 21201 Re: United States v. Christopher Paul Hasson, Crim. No. GIH-19-96 Dear Counsel: This letter, together with the Sealed Supplement, con?rms the plea agreement (this ?Ageement?) that has been offered to your client, Christopher Paul Hasson (hereinafter ?Defendant?), by the United States Attorney?s Of?ce for the District of Maryland (?this Office?). If the Defendant accepts this offer, please have the Defendant. execute it in the spaces provided below. If this offer has not been accepted by Thursday, October 3, 2019, at 12:00 it will be deemed withdrawn.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, Two, Three, and Four of the Superseding Indictment, which charge the Defendant as follows: in Count One, with Unlawful Possession of Unregistered Silencers, in violation of 26 U.S.C. 5861(d); in Count Two, with Unlawful Possession of Firearm Silencers Unidenti?ed by Serial Number, in violation of 26 U.S.C. 58616); in Count Three, with Possession of Firearms by Unlawful User of and Addict to a Controlled Substance, in violation of 18 U.S.C. 922(g)(3); and in Count Four, with Possession of a Controlled Substance, in violation of 21 U.S.C. 844(a). The Defendant admits that the Defendant is, in fact, guilty of the 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: That on or about the time alleged in the Superseding Indictment, in the District of Maryland? Count One (Unlawful Possession of Unregistered Silencers): (1) the Defendant had possession of a ?rearm, as de?ned in 26 U.S.C. 5845(a)(7) and 18 U.S.C. 921(a)(24), speci?cally, one assembled ?rearm silencer and one disassembled ?rearm silencer, as Rev. August 2013 charged in Count One of the Superseding Indictment; (2) the Defendant knew he possessed a ?rearm srlencer; and (3) the ?rearm silencer was not registered to the Defendant in the National Firearms Registration and Transfer Record. Count Two nlawful Po ion of Firearm Si en Uniden ed Number the Defendant had possession of a ?rearm, as de?ned in 26 U.S.C. 5845(a)(7) and 18 U.S.C. 921 speci?cally, one assembled ?rearm silencer and one disassembled ?rearm silencer, as charged in Count Two of the Superseding Indictment; (2) the Defendant knew he possessed a ?rearm silencer; (3) the ?rearm silencer did not have a serial number; and (4) the Defendant knew that the ?rearm silencer did not have a serial number. Count Three asses i of Unla ser of diet to a Substancel: the Defendant knowingly possessed a ?rearm, as charged in Count Three of the Superseding Indictment; (2) at the time of the possession, the Defendant was an unlaw?rl user of and addicted to a controlled substance; (3) at the time of the possession, the Defendant knew that the Defendant was an unlawful user of and addicted to a controlled substance; and (4) such possession was in or affecting commerce. Count Four (Mien of a Controlled swam): the Defendant possessed a connolled substance, speci?cally, Tramadol, as charged in Count Four of the Superseding Indictment; and (2) the Defendant knew that the Defendant possessed the controlled substance. Penalties 3. The maxnn? um penalties provided by statute for the offenses to which the Defendant is pleadrng' guilty are as follows: um Maximum Supervised Maxnn' um Specral? Count Statute Prison Prison Release Fine Assessment 26 U.S.C. ,1 5861(d) NIA 10 years 3 years $10,000 00 26 U.S.C. 1 2 58 6] 10 years 3 years $10,000 3 00 18 U.S.C. 3 922%? 10 years 3 years $250,000 $100 At least $1,000 4 21 1 year . 1 year and no . $25 844(3) more than $100,000 a. Prison: Ifthe Court orders a term of imprisonment, the Bureau of Prisons has sole discretion to designate the institution at which it will be served. Rev. August2018 b. Supervised Release: Ifthe Court orders a term of supervised release, and the Defendant violates the conditions of supervisedrelease, the Court may order the Defendant returned to custody to serve a term of imprisonment as permitted by statute, followed by an additional term of supervised release. c. Restitution: The Court may order the Defendant to pay restitution pursuant to 18 U.S.C. 3663, 3663A, and 3664. Payment: If a ?ne or restitution is imposed, it shall be payable immediately, unless the Court orders otherwise under 18 U.S.C. 3572(d). The Defendant may be required to pay interest if the ?ne is not paid when due. e. Forfeiture: The Court may enter an order of forfeiture of assets directly traceable to the offense, substitute assets, and/or a money judgment equal to the value of the property subject to forfeiture. f. Collection of Debts: If the Court imposes a ?ne or restitution, this O??ice?s Financial Litigation .Unit will be responsible for collecting the debt. If the Court establishes a schedule of payments, the Defendant agrees that: the ?rll amount of the ?ne or restitution is nonetheless due and owing immediately; (2) the schedule of payments is merely a minimum schedule of payments and not the only method, nor a limitation on the methods, available to the United States to enforce the judgment; and (3) the United States may fully employ all powers to collect on the total amount of the debt as provided by law. Until the debt is paid, the Defendant agrees to disclose all assets in which the Defendant has any interest or over which the Defendant exercises direct or indirect control. Until the money judgment is satis?ed, the Defendant authorizes this O?ice to obtain a credit report in order to evaluate the Defendant?s ability to pay, and to request and review the Defen ?s federal and state income tax returns. The Defendant agrees to complete and sign a copy of IRS Form 8821 (relating to the voluntary disclosure of federal tax return information) and a ?nancial statement in a form provided by this O?ice. Waiver of Rights 4. The Defendant understands that by entering into this Agreement, the Defendant surrenders certain rights as outlined below: a. If the Defendanthadpled not guilty and persistedinthatplea, the Defendant would have had. the right to a jury trial with the close assistance of competent counsel. That trial could be conducted by a judge, without a jury, if the Defendant, this Of?ce, 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 unquali?ed, and would have the opportunity to strike a certain number of jurors peremptorily. All twelve jurors would have to agree unanimously before the Defendant could be found guilty of any count. The Rev. August 2018 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 con?'ont and cross-examine the Government?s witnesses. The Defendant would not have to present any defense witnesses or evidence whatsoever. If the Defendant wanted to call witnesses in defense, however, the Defendant would have the subpoena power of the Court to compel'the witnesses to attend. d. The Defendant would have the right to testify in the Defendant?s own defense if the Defendant so chose, and the Defendant would have the right to re?rse to testify. If the Defendant chose not to testify, the Court could instruct the jury that they could not draw any adverse inference from the Defendant?s decision not to testify. e. Ifthe Defendant were found guilty after a trial, the Defendant would have the right to appeal the verdict and the Court?s 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. By pleading guilty, with the limited exceptions set forth in the ?Waiver of Appeal? section below, the Defendant knowingly gives up the right to appeal the verdict and the Court?s decisions. f. By pleading guilty, the Defendant will be giving up all of these rights, except the rights under the limited circumstances set forth in the ?Waiver of Appeal? section below. By pleading guilty, the Defendant understands that the Defendant may have to answer the Court?s questions both about the rights being given up and about the facts of the case. Any statements that the Defendant makes during such a hearing would not be admissible against the Defendant during a trial except in a criminal proceeding for perjury or false statement. g. Ifthe Court accepts the Defendant?s plea of guilty, there will be no further trial or proceeding of any kind in the above-referenced criminal case, and the Court will ?nd the Defendant 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, including possible denaturalization. The Defendant recognizes that ifthe Defendant is not a citizen of the United States, or is a naturalized citizen, pleading guilty may have consequences with meet to the Defendant?s immigration status. Under federal law, conviction for abroad 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 the Defendant?s attorney or the Court, can predict with certainty the effect of a conviction on immigration status. . The Defendant is not relying on any promise or belief about the immigration consequences of pleading guilty. The Defendant nevertheless af?rms that the Defendant wants to plead guilty regardless of any potential immigration eonsequences.? Rev. August 2018 i Advisog Sentencing Guidelines Apply 5. . 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(bx1) and 3742(e)) and 28 U.S.C. 991 through 998. The Defendant ?rrther understands that the Court will impose a sentence pursuant to the Sentencing Reform Act, as excised, and must take into account the advisory guidelines range in establishing a reasbnable sentence. Fm Qd Advim Guidelines Stipulation 6. ThisO?ice and the Defendant stipulate andagreetothe Statement of Facts setforth in Attachment A, which is incorporated by reference herein. Count One a. This Of?ce and the Defendant ?irther agree that the applicable base offense level is 20, pursuant to United States Sentencing Guidelines because the o?'ense involved a semiautomatic ?rearm that is capable of accepting a large capacity magazine and a ?rearm that is described in 26 U.S.C. 5845(a), and the Defendant was a prohibited person at the time the Defendant committed the instant off . b. A 4-level increase applies, pursuant to U.S.S.G. because the offense involved at least eight and not more than 24 ?rearms. 9M9 c. The applicable base offense level is 20, pursuant to U.S.S.G. 2K2.l because the offense involved a semiautomatic ?rearm that is capable of accepting a large capacity magazine and a ?rearm that is described in 26 U.S.C. 5845(a and the Defendant was a prohibited person at the time the Defendant committed the instant offense. d. A 4-level increase applies, pursuant to U.S.S.G. because the o?'ense involved at least eight and not more than 24 ?rearms. Count Three e. The applicable base offense level is 20, pursuant to U.S.S.G. because the offense involved a semiautomatic ?rearm that is capable of accepting a large capacity magazine and a ?rearm that is described in 26 U.S.C. 5845(a), and the Defendant was a prohibited person at the time the Defendant committed the instant offense. f. A 4-level increase applies, pursuant to U.S.S.G. because the offense involved at least eight and not more than 24 ?rearms. Rev. August 2018 Count Four g. The applicable base offense level is 4, pursuant to U.S.S.G. because the offense involved Tramadol. 91mg h. Counts One through Four group, pursuant to U.S.S.G. ation of Ri ts Re di Guide ines i. In addition to the agreed-upon Guideline provisions above, this O?ce and the Defendant reserve the right to argue for or against the applicability of any other Guideline, including but not limited to: U.S.S.G. 3A1.4(a) and 381.3, and Acceptance of Responsibilig j. This Of?ce does not oppose a 2-level reduction in the Defendant?s adjusted o??ense level pursuant to U.S.S.G. 3E1 . based upon the Defendant?s apparent prompt recognition and af?rmative acceptance of personal responsibility for the Defendant?s criminal conduct. This Of?ce will 95; make a motion pursuant to U.S.S.G. 3E1 for an additional 1- level decrease because the Defendant did not timely notify this Of?ce of the Defendant?s intention to enter a plea of guilty. This O?ice may oppose any adjustment for acceptance of responsibility under U.S.S.G. and may decline to make a motion pursuant to U.S.S.G. 3E1 if the Defendant: fails to admit each and every item in the factual stipulation; (ii) denies involvement in the o??ense; gives conflicting statements about the Defendant?s involvement in the offense; (iv) is Imu-uth?rl with the Court, this Of?ce, or the United States Probation Of?ce; obstructs or attempts to obstruct justice prior to sentencing; (vi) engages in any criminal conduct between the date of this Agreement and the date of sentencing; (vii) attempts to withdraw the plea of guilty; or violates this Agreement in any way. MW 7. There is no agreement as to the Defendant?s criminal history and the Defendant understands that the Defendant?s criminal history could alter the Defendant?s offense level. Speci?cally, the Defendant understands that the Defendant?s criminal history could alter the ?nal o?'ense level if the Defendant is determined to be a career o??ender or if the instant o?'ense was a part of a pattern of criminal conduct from which the Defendant derived a substantial portion of the Defendant?s income. Rev. Obliggtions of the Parties 8. At the time of sentencing, this Of?ce and the Defendant reserve the right to advocate for a reasonable sentence, period of supervised release, and/or ?ne considering any appropriate factors under 18 U.S.C. 3553(a). eci?call the De dant ma advocate for gay sentence at or above the mate statutog minimm and the Goxernment may gdyocate for any sentence at or helgw the mm :13me gaximnmg, the advise Guideline ran c. This Of?ce and the Defendant reserve the right to bring to the Court?s attention all information with respect to the Defendan ?5 background, character, and conduct that this O?ce or the Defendant deem relevant to sentencing, including the conduct that Waiver of 9. In exchange for the concessions made by this Of?ce and the Defendant in this Agreement, this Of?ce and the Defendant waive their rights to appeal as follows: a. As vid Fed.R rim.P.lla 2 theDefendantreser-vestheri to th Court? rder den the Defendant?s Mo 'on to Dismiss Counts One and Two of me hdiment on Sand Madamt Grounds (ECF Ngs, 62 (motion) and 86 1 (Elem mg of Order!) and Motion to Dismiss Count 1hr_-ee ofme Igg'gment on Gro CF 0.63 motion and 86 2 relevant are hoford . . b. In all other respects, the Defendant knowingly waives all right, pursuant to 28 U.S.C. 1291 or any other statute or constitutional provision, to appeal the Defendant?s conviction on any ground whatsoever. This includes a waiver of all right to appeal the Defendant?s conviction on the ground that the statutes to which the Defendant is pleading guilty is unconstitutional, or on the ground that the admitted conduct does not fall within the scope of the stamtes, to the extent that such challenges legally can be waived. . c. The Defendant knowingly and expressly waives the right to appeal the Court?s order denying the Defendant?s Motion to Suppress Evidence Seized Pursuant to Search Warrants (ECF No. 66 (motion) and 86 3 (relevant paragraph of order?. d. The Defendant and this Of?ce knowingly and expressly waive all rights conferred by 18 U.S.C. 3742 to appeal whatever sentence is imposed (including any term of imprisonment, fine, term of supervised release, or order of restitution) for any reason (including the establishment of the advisory sentencing guidelines range, the determination of the Defendant?s criminal history, the weighing of the sentencing factors, and any constitutional challenges to the calculation and imposition of any term of imprisonment, ?ne, order of forfeiture, order of restitution, and term or condition of supervised release), except as follows: lRev.August20 8 i. The Defendant reserves the right to appeal any term of imprisonment that exceeds the aggregate statutory minimum (zero years) for any reason, including (but not limited to) grounds that the Court misapplied any Guideline enhancement not agreed to by the parties; and ii. This Of?ce reserves the right to appeal any term of imprisonment that is below the aggregate statutory maximum (31 years) for any reason, including (but not limited to) grounds that the Court misapplied any Guideline enhancement not agreed to by the parties. 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 ?le any request for documents from this Of?ce or any investigating agency. Forfeiture 10. The Defendant understands that the Court may enter an Order of Forfeiture as pm of the Defendant?s sentence, and that the Order of Forfeiture may include assets directly traceable to the offenses, substitute assets, andlor a money judgment equal to the value of the property derived from, or otherwise involved in, the o??enses. 1. Speci?cally, but without limitation on the Government?s right to forfeit all property subject to forfeiture as permitted by law, the Defendant agrees to forfeit to the United States all of the Defendant?s right, title, and interest in the following items that the Defendant agrees constitute money, property, and/or assets derived from or obtained by the Defendant as a result of, or used to facilitate the commission of, the Defendant?s illegal activities: (1) a Stag Arms ARIS 5.56m ri?e; (2) a Ruger CQR Model X15 ri?e; (3) a DPMS Panther Arms 308 Model LR-308 ri?e; (4) a Bergara 308 ri?e; (5) a Remington Model 241 .22 caliber ri?e; (6) a Ranger 101-16 .22 caliber ri?e; (7) a Marlin Model 795 ri?e; (8) a Remington 870 shotgun; (9) another Remington 870 shotgun; (10) a Glock handgun; (11) an (12) a Sig Sauer Model 1911 handgun; (13) a Spring?eld .45 caliber handgun; (14) an Guns revolver; (15) an RG 14 revolver; (16) an assembled ?rearm silencer; (17) a disassembled ?rearm silencer; and (18) any and all magazines and ammunition recovered from the Defendant?s residence on or about February 15, 2019. Rev. August 2018 . 12. The Defendant agrees to consent to the entry of orders of forfeiture for the property descnbed herein and waives the requirements of Federal Rules of Criminal Procedure 32.2 and 43(a) regarding notice of the forfeiture in the charging announcement of the forfeiture at sentencing, and incorporation of the forfeiture in the judgment. This Of?ce agrees to seek the Attorney General?s approval to apply forfeited assets to the Defendant?s Restitution Order. 13. The Defendant agrees to assist ?rlly in the forfeiture of the above property. The Defendant agrees to disclose all assets and sources of income, to consent to all requests for access to information related to assets and income, and to take all steps necessary to pass clear title to the forfeited assets to the United States, including executing 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 ensrn-e that assets subject to forfeiture are made available for forfeiture. 14. The Defendant waives all challenges to any forfeiture carried out in accordance with this Agreement on any grounds, including any and all constitutional, legal, equitable, statutory, or administrative grounds brought by any means, including through direct appeal, habeas corpus petition, or civil complaint. The Defendant will not 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 any challenge or review or any petition for remission of forfeiture. donment 15. The Defendant knowingly and voluntarily waives any right, title, and interest in the following property seized from the Defendant?s residence in Silver Spring, Maryland, on or about February 15, 2019: (1) any and all body armor, including but not limited to, plates and plate carriers; and (2) any and all smoke grenades (together, the ?Abandoned Property?). 16. The Defendant agrees not to contest the vesting of title of the Abandoned Property in the United States Government and agrees to unconditionally release and hold harmless the United States Government, its of?cers, employees, and agents, from any and all claims, demands, damages, causes of actions, suits, of whatever kind and description, and wheresoever situated, that might now exist or hereafter exist by reason of or growing out of or affecting, directly or indirectly, the seizure or waiver of ownership interest in the Abandoned Preperty. The Defendant agees to execute any documents as necessary to the waiver of right, title, and interest in the Woned Property, including any forms necessary to effect the Defendant?s waiver of ownership interest. Defendant?s Condugt Prior to Sentencing Ed Breach, 17. Between now and the date of the sentencing, the Defendant will not engage in conduct that constitutes obstruction of justice under U.S.S.G. 301 will not violate any federal, state, or local law; will acknowledge guilt to the probation of?cer and the Court; will be truthful in any statement to the Court, this O?ice, law enforcement agents, and probation o?icers; will cooperate in the preparation of the" presentence report; and will not move to withdraw from the plea of guilty or hour this Agreement. Rev. August 2018 18. if the Defendant engages in conduct prior to sentencing that violates the above paragraph of the Agreement, and the Court ?nds a violation by a preponderance of the evidence, then: this O?ce will be free from its obligations under this Agreement; (ii) this O?ice may makesentencing arguments and recommendations different from those set out in this Agreement, even if the Agreement was reached pursuant to Rule 1 and in any criminal or civil proceeding, this O?ice will be free to use against the Defendant all statements made by the Defendant and any of the information or materials provided by the Defendant, including statements, information, and materials provided pursuant to this Agreement, and statements made during proceedings before the Court pursuant to Rule 11 of the Federal Rules of Criminal Procedure. A determination that this Of?ce is released from its obligations under this Agreement will not permit the Defendant to withdraw the guilty plea. The Defendant acknowledges that the Defendant may not withdraw the Defendant's guilty plea?even if made pursuant to Rule 1 the Court ?nds that theDefendant breached the Agreement. In that event, neither the Court nor the Government will be bound by the speci?c sentence or sentencing range agreed and stipulated to herein pursuant to Rule 1 bicBene 'nDru Cases 19. The Defendant understands and acknowledges that under 21 U.S.C. 862 and 862a, a person who has been convicted of a federal offense involving the distribution or possession of controlled substances may be denied certain federal and state bene?ts such as loans, grants, or food stamps. Comm. ueng of Vacatur, Revergl, gr Set-Aside 20. If a conviction entered pursuant to this Agreement is vacated, reversed, or set aside for any reason, then this Of?ce will be released from its obligations under this Agreement, and any prosecution that is not time-barred as of the date of the signing of this Agreement (including any counts this O?ice has agreed to dismiss) may be commenced or reinstated against the Defendant, notwithstanding the expiration of the statute of limitations between the signing of this Agreement and the commencement or reinstatement of such prosecution. The Defendant agrees to waive all defenses based on the statute of limitations with respect to any prosecution that is not time-barred on the date this Agreement is signed, and any applicable statute of limitations will be tolled ?om the date of this Agreement until 120 days alter the vacatur, reversal, or set aside becomes ?nal. The Defendant waives any defenses based on double jeOpardy, pro-indictment delay, or the Speedy Trial Act. 21. The Court is not a party to this Agreement. The sentence to be imposed is within the sole discretion of the Court. The Court is not bound by the Sentencing Guidelines stipulation in this Agreement. The Court will determine the facts relevant to sentencing. The Court is not required to accept any recommendation or stipulation of the parties. The Court has the power to impose a sentence up to the maximum penalty allowed by law. If the Court makes sentencing ?ndings different ?'om those stipulated in this Agreement, or if the Court imposes any sentence up Rev. August 20 IS 10 to the maximum allowed by statute, the Defendant will remain bound to ?il?ll all of the obligations under this Agreement. Neither the prosecutor, defense counsel. nor the Court can make a binding prediction, promise, or representation as to what guidelines range or sentence the Defendant will receive. The Defendant agrees that no one has made such a binding prediction or promise. Entire Agreement 22. This letter, together with the Sealed Supplement, constitutes the complete plea agreement in this case. This letter, together with the Sealed Supplement, supersedes any prior understandings, promises, or conditions between this Office and the Defendant. There are no other agreements, promises, undertakings, or understandings between the Defendant and this Of?ce other than those set forth in this letter and the Sealed Supplement. No changes to this Agreement will be effective unless in writing, signed by all parties and approved by the Court. [f the Defendant ?illy accepts each and every term and condition of this Agreement, please sign and have the Defendant sign the original and retum it to me Very truly yours, Robert K. Hur Attorney Thomas P. Windom . Assistant United States Attorney I have read this Agreement, including the Sealed Supplement, and carefully reviewed every part of it with my attorney. I understand it and I voluntarily agree to it. Speci?cally, I have reviewed the Factual and Advisory Guidelines Stipulation with my attorney and 1 do not wish to change any part of it. I am completely satisfied with the representation of my attorney. Iolaln Cit? l-a?R Date Christopher Paul Hasson am the Defendant?s attorney. I have carefully reviewed every part of this Agreement, including the Sealed Supplement with the Defendant. The Defendant advises me that the Defendant understands and accepts its terms. To my knowledge, the Defendant?s decision to enter into this Agreement is an informed and voluntary one. mfg/l4 ?414., 5 Date Liz Oyer . Rev. August 2018 ll ATTACHMENT A STIPULATION OF FACTS The undersigned parties and agree that if this case had proceeded to tricd. this Office n'mdd have proven beyond a reosonobie doubt. The undersigned parties also and agree that diejodmringfaers do no! enconniass rd} of'die evidence that n-?mdd have been presented had mutter proceeded to trim?. At all relevant times. the Defendant. CHRISTOPHER PAUL HASSON was a Lieutenant in the United States Coast Guard. Prior to approximately June 2016. HASSON ovmed a residence and lived in Currituck. North Carolina (the "North Carolina residence"). In approximately June 20! 6. HASSON moved to a rented residence in Silver Spring. Maryland (the "Maryland Residence"). and was assigned to 1uvork at Coast Guard I--lcadquarters in Washington. D.C. From at least March 2016 through early February 2019. using various email accounts (including an overseas email account). I-IASSON continually ordered Traniadol, a Schedule IV controlled substance. from various illegal internet?based distributors. HASSON usually would pay for the Tramadoi by using l'vloneyGrant or Western Union to send money to various individuals in Mexico- at the direction of the Mexico-based distributor. The distribumr then would cause the ramadol to be shipped to HASSON by UPS or FedEx. typically from California and typically in 100mg pills. at addresses selected including North Carolina and Maryland residences. HASSON then would conceal the Tramadoi in other packaging at his residence and work. The chart below details some of Tramadol purchases: .. . - .. sea-'20 I szzu Money?rnm 3:32: 332st a 1 Tramatlol $25 Nu?iczigg??m ?create magi?!? i sate $1223: ??5523?? 8:16:20 6 l0t3l'ggngafol $300 a Moncy?rnln C3333 FedEx h-laryiand Residence I 4 Iao'rmmadot SZIS EEK: ups Rev. August 2013 12/21/2016 100 Trained 1 1 Tijuim? Cardin? 3 85 Sharemoney ext co UPS Residence 2/13/2017 1007 Tiium. Noah Carolina ramadol $215 Sharemoney Mexico UPS Residence 200 Tramadoll Tijuana, North Carolina 4/2/2017 300 Tramadol $365 MoneyG ram Mexico UPS Residence 150 Timmd 1 7/10/2017 0me $230 MoneyGram Maryland Residence 7/13/2017 300 Tramadol $520 MoneyGram Maryland Residence 9/13/2011 300 Tramadol $520 MoneyGram ?33: Maryland Residence . Tijuana, . 11/14/2201 7 300 Tramadol $530 MoneyGrarn Mexico FedEx Maryland Resrdence 1/23/2013 300 Tramadol $520 MoneyGram 33c: ups Maryland Residence Tijuana, . 3/25/2018 300 Tramadol 3530 11401113me Mexico UPS Maryland Resrdenoe Tijuana, . 300 Tramadol $530 MoneyGram Mexico UPS Maryland Residence Tijuana, . 612812018 300 Tramadol $530 MoneyGram Mexico UPS Maryland Resldence . Tijuana, 300 Tramadol $520 Western Umon Mexico FedEx Maryland Residence . Tijuana, Hotel in Moss 1019/2018 300 Tramadol $520 Western Unron Mexico FedEx Point, Mississippi 11/30/2018 300 Tramadol 3520 Western Union 13:13:: FedEx Maryland Residence Tijuana, . 11812019 300 Tramadol $520 Western Union Mexico FedEx Maryland Resmnee . . Tijuana. 2/5/2019 300 Tremadol $520 Westem Umon Mexico FedEx Maryland Residence HASSON ordered the Tramadol for personal consumption. From at least March 2016 through early February 2019, HASSON ordered at least 4,650 Tramadol pills and personally consumed the vast majority of them, usually daily, including while at work at Coast Guard Headquarters. At no relevant time did HASSON have a law?rl prescription for Tramadol, and HASSON knew that he did not have any such lawful prescription. Tramadol possession was unlaw?rl, and his consumption of Tramadol was consistent, prolonged, and close in time to February 15, 2019. Rev. August 2018 13 During the timeframe in which HASSON used Tramadol, HASSON conducted certain relevant interact searches and visited certain relevant websites. For example, on July 12, 2017, HASSON visited the following websites: 0- last! 0 0 Im addicted to tramadol Tramadol Brain and nerves Community Also on July 12, 2017, HASSON conducted the following intemet searches: 0 Does anyone have a good tapering schedule for tramadol? 0 easiest taper off tramadol 0 How long does it take to get off tramadol? Similarly, on November 30, 2017, HASSON conducted an intemet search for ?how to come off tramadol? and then visited an article titled ?How To Stop Tramadol Without Withdrawal Pursuant to a federal arrest warrant, agents from the Federal Bureau of Investigation and Coast Guard Investigative Service arrested HASSON on February 15, 2019, at Coast Guard Headquarters. Incident to arrest, agents recovered from backpack approximately 196 Tramadol pills. Pursuant to a search warrant executed the same day, agents also recovered approximately 106 Tramadol pills from desk at Coast Guard Headquarters. Pursuant to a warrant, agents obtained a blood sample drawn from HASSON on the date of his arrest; the blood sample showed that HASSON had Tramadol in his blood stream that day. During the execution of a search warrant on residence in Silver Spring, Maryland, on February 15, 2019, agents recovered approximately 122 Tramadol pills, as well as a plastic container and packaging that tested positive for Tramadol residue. From the residence, agents also recovered the following ?rearms owned or possessed by HASSON: a Stag Arms ARIS 5.56m ri?e (purchased by HASSON on October 1, 2009, in Petaluma, California); (2) a Ruger CQR Model X15 ri?e; (3) a DPMS Panther Arms 308 Model LR-308 ri?e; (4) a Bergara 308 ri?e (purchased by HASSON on December 30, 2017, in Chantilly, Virginia); (5) a Remington Model 241 .22 caliber ri?e; (6) a Ranger 101-16 .22 caliber ri?e; (7) a Marlin Model 795 ri?e; (8) a Remington 870 shotgun (purchased by HASSON on June 21, 2009, in Tamales, California); (9) another Remington 870 shotgun (purchased by HASSON on March 21, 2012, in Glendale, Arizona); (10) a Glock handgun (purchased by HASSON on May 7, 2016, in Chesapeake, Rev. August 201 8 l4 Virginia); (I I) an handgun (purchased by HASSON on January 24, 2015, in Norfolk, Virginia); (12) a Sig Sauer Model 1911 handgun; (13) a Spring?eld .45 caliber handgun (purchased by HASSON on October I, 2017, in Chantilly, Virginia); (l4) an Guns revolver; (15) an R0 14 revolver; (16) an assembled ?rearm silencer; and (17) a disassembled ?rearm silencer. Each gun was manufactured outside the State of Maryland, and therefore traveled in interstate commerce prior to recovery in the State of Maryland on February 15, 2019. Furthermore, during the search of residence. in close proximity to the guns described above, agents found multiple magazines that could accept more than 15 rounds of ammunition, as well as many hundred rounds of ammunition. The components of the assembled and disassembled ?rearm silencers were purchased by and shipped to HASSON from a company in California. Therefore, possession of the firearm silencers was in or affecting interstate commerce. Once HASSON obtained the ?rearm silencer components, HASSON used a drill to complete and assemble one ?rearm silencer. HASSON knew that the assembled and disassembled ?rearm silencers were, in fact, ?rearm silencers. The assembled and disassembled ?rearm silencers were not, and HASSON knew they were not, registered in the National Firearms Registration and Transfer Record. Further, the assembled and disassembled ?rearm silencers did not, and HASSON knew they did not, have serial numbers. ?oss Thomas P. Windom Assistant United States Attorney Christopher Paul Hasson SO Defendant Liz Oyer, . Counsel 1' Defendant Rev. August 20l8 .