Case 5:18-cr-50160-JLV Document 28 Filed 02/24/20 Page 1 of 3 PageID #: 57 UNITED STATES DISTRICT COURT DISTRICT OF SOUTH DAKOTA WESTERN DIVISION UNITED STATES OF AMERICA, Plaintiff, CR 18-CR-50160 FACTUAL BASIS STATEMENT vs. ROBIN LIANNE WALLACH, Defendant. The Defendant states the following facts are true, and the parties agree they establish a factual basis for the offense to which the Defendant is pleading guilty pursuant to Federal Rules of Criminal Procedure 1 l(b)(3): Beginning on or about November 2017, and continuing until on or about November 2018, the defendant, Robin Lianne Wallach, along with at least one other person, reached an agreement or came to an understanding to distribute a mixture or substance containing methamphetamine in the District of South Dakota and elsewhere. The defendant voluntarily and intentionally joined in the agreement or understanding to distribute methamphetamine. Methamphetamine is a Schedule II controlled substance. At the time the defendant joined in the agreement or understanding to distribute methamphetamine, the defendant knew the purpose of the agreement or understanding. Case 5:18-cr-50160-JLV Document 28 Filed 02/24/20 Page 2 of 3 PageID #: 58 During Robin Lianne Wallach's involvement in the conspiracy, she rented vehicles from the Rapid City area for her husband, Michael Carey, so that Carey could travel to California to obtain multiple pounds of methamphetamine. Carey would then travel, on multiple occasions between November 2017 and November 2018, to California to obtain the methamphetamine. On several occasions, Wallach would travel with Carey on the trips to obtain the methamphetamine . The methamphetamine was distributed primarily out of Wallach's and Carey's home, and she knew some of the methamphetamine they sold would be further distributed. It was reasonably foreseeable that at least 15 kilograms would be distributed during the course of the conspiracy. On November 1, 2018, Michael Carey was returning home from California in a rental vehicle, which was rented by Wallach for Carey. Carey was stopped by the South Dakota Highway Patrol and approximately 10 pounds of methamphetamine was found in the vehicle. The parties submit that the foregoing statement of facts is not intended to be a complete description of the offense or the defendant's involvement in it. Instead, the statement is offered for the limited purpose of satisfying the .requirements of Fed. R. Crim. P. 1 l(b)(3). The parties understand that additional information relevant to sentencing may be developed and attributed to the Defendant for sentencing purposes. 2 Case 5:18-cr-50160-JLV Document 28 Filed 02/24/20 Page 3 of 3 PageID #: 59 RONALD A. PARSONS, Jr. United States Attorney 2-24-20 Date A istant United States Attorney 15 9th Street #201 Rapid City, SD 57701 Telephone: (605)342-7822 Facsimile: (605)342-1108 E-Mail: Gina.Nelson@usdoj.gov Date Ro bin Lianne Wallach Defendant Date aul Eisenbraun Attorney for Defendant 3