Case 5:19-cr-50121-JLV Document 39 Filed 02/24/20 Page 1 of 2 PageID #: 88

UNITED STATES DISTRICT COURT
DISTRICT OF SOUTH DAKOTA
WESTERN DIVISION

UNITED STATES OF AMERICA,
Plaintiff,

CR 19-50121-02
FACTUAL BASIS STATEMENT

vs.

AUBREY HANSEN
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 ll(b)(3):
Beginning no later than March 2019 and continuing until on or about
September 2019, the defendant, Aubrey Hansen! along with at least one other
person, reached an agreement or came to an understanding to distribute a
mixture or substance containing heroin in the District of South Dakota and
elsewhere.
The defendant voluntarily and intentionally joined in the agreement or
understanding to distribute heroin, ·a Schedule I controlled substance. At the
time the defendant joined in the agreement or understanding to distribute
heroin, the defendant knew the purpose of the agreement or understanding. It
was reasonably foreseeable to the defendant that at least 100 grams but less
than 400 grams of heroin would be distributed in the course of the conspiracy.

 Case 5:19-cr-50121-JLV Document 39 Filed 02/24/20 Page 2 of 2 PageID #: 89

During her involvement in the conspiracy, heroin was brought to South
Dakota from Colorado by the defendant, or by others through arrangements with
her. Once the defendant arrived in the Rapid City area, the defendant dispersed
heroin to others for use and distribution. Some of the controlled substances the
defendant supplied were on a "front", meaning the defendant would provide the
substances without receiving payment initially and would get paid at a later date .
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.
RONALD A. PARSONS, Jr.
United States Attorney

Date

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Assistant United States Attorney
515 9th Street #201
Rapid City, SD 57701
Telephone: (605)342-7822
Facsimile: (605)342-1108
E-Mail: Kathryn.Rich@usdoj.gov

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Defendant

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Attorney for Defendant