Plea Agreement as to Aleta Necole Thomas — USA v. Thomas (Dkt. 78, N.D. Okla.)

Summary

A plea agreement under Federal Rule of Criminal Procedure 11(c)(1)(C) in United States v. Aleta Necole Thomas, Case No. 21-CR-239-GKF, U.S. District Court for the Northern District of Oklahoma, filed December 7, 2021 as Document 78 (21 pages). Thomas agrees to plead guilty to Count 3 and Count 4 of the Second Superseding Indictment, each a false statement to a financial institution under 18 U.S.C. § 1014, made to Cross River Bank and to First Electronic Bank to influence the bank for the purpose of securing a loan. She agrees to restitution for the full amount of the victims' losses, listed as $87,500.00 for Cross River Bank and $241,169.50 for First Electronic Bank among other lenders, and to a forfeiture money judgment of at least $795,158.50 plus $170,744.05, $20,100.52 and $19,146.54 seized from Tulsa Federal Credit Union accounts.

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Case 4:21-cr-00239-GKF Document 78 Filed in USDC ND/OK on 12/07/21 Page 1 of 21

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OKLAHOMA x

UNITED STATES OF AMERICA, L UL iy
Vv. Case No. 21-CR-239-GKF

ALETA NECOLE THOMAS,

Defendant.

Plea Agreement Pursuant to
Federal Rule of Criminal Procedure 11(c)(1)(C)

The United States of America, by and through Clinton J. Johnson, Acting United
States Attorney for the Northern District of Oklahoma, and Kristin F. Harrington
and Cymetra Williams, Assistant United States Attorneys, and the defendant,
ALETA NECOLE THOMAS, in person and through counsel, Keith Ward,
respectfully inform the Court that they have reached the following plea agreement,
pursuant to Fed. R. Crim. P. 11(c)(1)(C).

1. Plea

The defendant agrees to enter voluntary pleas of guilty to the following:

Count 3: 18 U.S.C. § 1014-— False Statement to a Financial Institution
Count 4: 18 U.S.C. § 1014 - False Statement to a Financial Institution

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as set forth in the Second Superseding Indictment in the instant case, Northern
District of Oklahoma, and admits to being in fact guilty as charged in the counts to
which the defendant is pleading guilty.

Ze Waiver of Constitutional Rights

The defendant understands that, by pleading guilty, the following constitutional
rights will be relinquished:
a. the right to be indicted if proceeding by Information;
b. the right to plead not guilty;

c. the right to be tried by a jury, or, if the defendant wishes and with the
consent of the Government, to be tried by a judge;

d. at trial, the defendant has the right to an attorney, and if defendant could
not afford an attorney, the Court would appoint one to represent the defendant;

e. the defendant has the right to assist in the selection of the jury;

f. during trial, the defendant would be presumed innocent, and a jury would
be instructed that the Government has the burden to prove the defendant guilty
beyond a reasonable doubt and by a unanimous verdict;

g. the defendant has the right to confront and cross-examine witnesses against
the defendant;

h. if desired, the defendant could testify on the defendant’s own behalf and
present witnesses in the defendant’s defense;

i. if the defendant did not wish to testify, that fact could not be used against
the defendant, and a jury would be so instructed;

j. if the defendant were found guilty after a trial, the defendant would have
the right to appeal that verdict to determine if any errors had been committed during
trial that would require either a new trial or a dismissal of the charges;

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k. at trial, the defendant would be entitled to have a jury determine beyond a
reasonable doubt any facts which may have the effect of increasing the defendant's
mandatory minimum or maximum sentence; and

1. any rights and defenses defendant may have under the Excessive Fines
Clause of the Eighth Amendment to the United States Constitution to the forfeiture
of property in this proceeding or any related civil proceeding, special or other
assessment, and any order of restitution.

By pleading guilty, the defendant will be giving up all these rights. By pleading
guilty, the defendant understands that the defendant may have to answer questions
posed to defendant by the Court, both about the rights that the defendant will be
giving up and the factual basis for the defendant's plea.

Me Appellate and Post-Conviction Waiver

In consideration of the promises and concessions made by the United States in
this plea agreement, the defendant knowingly and voluntarily agrees to the following
terms:

a. The defendant waives the right to directly appeal the conviction and
sentence pursuant to 28 U.S.C. § 1291 and/or 18 U.S.C. § 3742(a); except that the

defendant reserves the right to appeal from a sentence that exceeds the statutory
maximum;

b. The defendant expressly acknowledges and agrees that the United States
reserves all rights to appeal the defendant’s sentence as set forth in 18 U.S.C.
§ 3742(b), and U.S. v. Booker, 543 U.S. 220 (2005); and

c. The defendant waives the right to collaterally attack the conviction and
sentence pursuant to 28 U.S.C. § 2255, including any assessment, forfeiture,
restitution order, the length of term of supervised release and any condition of
supervised release, except for claims of ineffective assistance of counsel.

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The defendant expressly acknowledges that counsel has explained her appellate
and post-conviction rights; that the defendant understands her rights; and that the

defendant knowingly and voluntarily waives those rights as set forth above.

ALETA NECOLE THOMAS

4. Freedom of Information Act Waiver

The defendant waives all rights, whether asserted directly or by a representative,
to request or to receive from any department or agency of the United States any
records pertaining to the investigation or prosecution of this case including, without
limitation, any records that may be sought under the Freedom of Information Act, 5
U.S.C. § 552, or the Privacy Act of 1974, 5 U.S.C. § 552a.

a Rule 11 Rights Waiver

The defendant knowingly and expressly waives all the rights afforded defendant
pursuant to the provisions of Rule 11(f) of the Federal Rules of Criminal Procedure.
In other words, after entry of a plea made pursuant to this plea agreement, and in
consideration thereof, the following shall be admissible against the defendant:

a. A plea of guilty which is later withdrawn or which the defendant seeks to
withdraw, unless done pursuant to Fed. R. Crim. P. 11(c)(1)(©);

b. Any statement made in the course of any proceeding under Rule 11
regarding said plea of guilty; and

c. Any statement made in the course of plea discussions with an attorney or
agent for the Government, or which were made pursuant to a proffer letter

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agreement, which result in a plea of guilty later withdrawn, unless done pursuant to
Fed. R. Crim. P. 11(c)(1)(C).

6. Waiver of Right to Jury Trial on Sentencing Factors

The defendant, by entering this plea, also waives the right to have facts that
determine the offense level under the Sentencing Guidelines (including facts that
support any specific offense characteristic or other enhancement or adjustment) (1)
charged in the Second Superseding Indictment, (2) proven to a jury, or (3) proven
beyond a reasonable doubt. The defendant explicitly consents to have the sentence
based on facts to be established by a preponderance of the evidence before the
sentencing judge pursuant to United States v. Crockett, 435 F.3d 1305 (10th Cir. 2006),
and United States v. Magallanez, 408 F.3d 672 (10th Cir. 2005), and to allow the Court
to consider any reliable evidence without regard to its admissibility at trial. The
defendant explicitly acknowledges that her plea to the charged offenses authorizes
the Court to impose any sentence up to and including the maximum sentence set
forth in the United States Code. The defendant also waives all challenges to the
constitutionality of the Sentencing Guidelines.

7. Payment of Monetary Penalties

The defendant understands that the Court may impose a fine pursuant to the
Sentencing Guidelines. The defendant agrees, as a part of this agreement, to submit
to interviews by the United States Attorney’s Financial Litigation Unit regarding the

defendant’s financial status, and to complete and submit a financial statement, under

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oath, not later than two weeks after the date of this plea agreement. The defendant
understands that, by law, interest accrues on any remaining balance of the debt.

That monetary penalties imposed by the Court will be (i) subject to immediate
enforcement as provided for in 18 U.S.C. § 3613, and (ii) submitted to the Treasury
Offset Program so that any federal payment or transfer of returned property the
defendant receives may be offset and applied to federal debts but will not affect the
periodic payment schedule.

8. Restitution for Offense of Conviction

The defendant understands that the Court can order the defendant to pay
restitution for the full loss caused by defendant’s conduct set forth above. The
defendant agrees to the entry of a Restitution Order for the full amount of the
victims’ losses. At this time, the Government is aware that the following victims
have suffered the following losses:

Cross River Bank $87,500.00
Lauren Quandt

2115 Linwood Avenue

Fort Lee, New Jersey 07024

First Electronic Bank $241,169.50
560 Mission Street, 13th Floor

San Francisco, CA 94105

The defendant understands that restitution is mandatory without regard to the

defendant’s ability to pay.

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9, Restitution for Other Offenses

The defendant agrees the Court’s consideration of the amount of restitution shall

NOT be limited to the amounts alleged in the count(s) to which the defendant is

pleading guilty, and may include all relevant conduct as well as any stipulated

amounts as set forth below pursuant to 18 U.S.C. § 3663. Therefore, the defendant

also agrees that restitution is due to the following victim(s) of an offense listed in 18

U.S.C. § 3663A(c)(1)(A) that is not the offense of conviction but nonetheless gave

rise to this plea agreement.

Tulsa Federal Credit Union
c/o Jason Smith

9323 East 21st Street

Tulsa, OK 74129

Arvest Bank

c/o Eva Allen

502 South Main Street
Tulsa, Oklahoma 74103

Fountainhead SBF, LLC

c/o Michael Bland

3216 West Lake Mary Boulevard
Lake Mary, Florida 72346

Harvest Small Business Finance, LLC
24422 Avenida De La Carlota

Suite 232,

Laguna Hills, California 92653

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$75,000.00
$175,817.00
$104,165.00

$91,102.00

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10. Restitution not Dischargeable in Bankruptcy

The defendant further agrees that any amount ordered by the Court to be paid as
restitution may not be discharged, in whole or in part, in any bankruptcy proceeding.

11. Forfeiture Agreement

The defendant agrees to forfeit, pursuant to 18 U.S.C. § 982(a)(2), the property
constituting or derived from proceeds traceable to the offenses, including but not
limited to:

MONEY JUDGMENT

1. A money judgment in an amount of at least $795,158.50, representing

Seow obtained by ALETA NECOLE THOMAS as a result of the

ACCOUNTS

2. $170,744.05 in funds, seized from Tulsa Federal Credit Union account
number xxx5999;

3. $20,100.52 in funds, seized from Tulsa Federal Credit Union account number
xxx6774; and

4. $19,146.54 in funds seized from Tulsa Federal Credit Union account number
xx7049,
Defendant agrees to take all steps as requested by the forfeiting authority to pass
clear title to forfeitable assets, including, but not limited to, the execution of a
consent decree of forfeiture and the completion of any other legal documents

required for the transfer of title.

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Defendant agrees that the forfeited property is subject to seizure and forfeiture by
the United States, and that no defense exists to the seizure and forfeiture of this
property by the United States. As such, defendant hereby relinquishes all claim, title,
and interest in the above-referenced property to the United States and agrees not to
oppose any civil, administrative, or judicial forfeiture of the property.

Defendant waives any and all interest in the above property and consents to their
forfeiture by whatever process the government chooses. Defendant agrees that the
government may use this waiver and consent in any administrative or judicial
forfeiture proceeding, whether criminal or civil, state, local or federal. If defendant
has filed a claim to the above-mentioned assets in any forfeiture process, defendant
hereby agrees to withdraw it. Defendant further agrees not to file a claim to the
above identified assets or properties in any future forfeiture proceeding of whatever
type. In the event that the law enforcement agency having custody of the property
decides not to pursue forfeiture of any of the seized property, defendant hereby
abandons any interest in such property and consents to its destruction by, and/or
abandonment to, the law enforcement agency.

The defendant understands that forfeiture is part of the sentence that will be
imposed in this case and waives any failure by the Court to advise defendant of this,
pursuant to Rule 11(b)(1)(J), at the time defendant’s guilty plea is accepted. The
defendant further understands that, pursuant to Rule 32.2(b)(4)(A), the order of

forfeiture will become final as to the defendant upon entry. The defendant waives

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notice of the forfeiture in the charging instrument, announcement of the forfeiture at
sentencing, and incorporation of the forfeiture in the judgment. The defendant also
waives all constitutional and statutory challenges in any manner (including direct
appeal, habeas corpus, or any other means) to any forfeiture carried out in
accordance with this plea agreement on any grounds, including that the forfeiture
constitutes an excessive fine or punishment.

The defendant agrees to forfeit substitute property, up to the value of the property
described above, if, by any act or omission of the defendant, the property described
above, or any portion thereof, cannot be located upon the exercise of due diligence;
has been transferred or sold to, or deposited with, a third party; has been placed
beyond the jurisdiction of the court; has been substantially diminished in value; or
has been commingled with other property which cannot be divided without
difficulty.

12. Special Assessment

The defendant hereby agrees to pay the total amount required for the Special
Monetary Assessment ($100 per felony count) to the United States District Court

Clerk before the time of the sentencing hearing or as directed by the District Court.

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13. Factual Basis and Elements

The elements that the United States must prove beyond a reasonable doubt in
order to convict under 18 U.S.C. § 1014 are as follows:

Count Three:

First: Cross River Bank was federally insured;

Second: the defendant made a false statement to Cross River Bank;
Third: the defendant knew the statement was false when she made it; and
Fourth: the defendant intended to influence the bank for the purpose of
securing a loan.

Count Four:

First: First Electronic Bank was federally insured;

Second: the defendant made a false statement to First Electronic Bank;
Third: the defendant knew the statement was false when she made it; and
Fourth: the defendant intended to influence the bank for the purpose of
securing a loan.

With regard to the factual basis required by Federal Rule of Criminal Procedure
11(b)(3), the defendant agrees and stipulates that there is a factual basis for the plea
of guilty and relieves the United States of any further obligation to adduce such
evidence.

The defendant, ALETA NECOLE THOMAS, admits knowingly, willfully and

intentionally committing or causing to be committed the acts constituting the crimes

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alleged in Counts Three and Four in the instant case, and confesses to the Court that
the defendant is, in fact, guilty of such crimes.

a. On or about May 27, 2020, in the Northern District of Oklahoma, I
made false statements and reports for the purpose of influencing a financial
institution, Cross River Bank, which was federally insured, on a Paycheck Protection
Program (“PPP”) loan application by knowingly and intentionally submitting a PPP
Borrower Application Form that falsely stated Coming Correct Community Ministry
had an average monthly payroll of $35,000; had 26 employees; had an Employer
Identification Number of 10-9690847; was in operation on February 15, 2020 and
had employees for whom it paid payroll taxes or independent contracts as reports in
IRS Form 1099-MISC. I also knowingly and intentionally denied that I owned and
operated other businesses and certified all information in the application and
supporting documents was true and correct when, in truth and fact, I knew that this
information was incorrect. Finally, I submitted supporting documentation that
included forged bank statements and a false 2019 IRS Schedule C (Form 1040).

b. On or about June 16, 2020, in the Northern District of Oklahoma, I
made false statements and reports for the purpose of influencing a financial
institution, First Electronic Bank, which was federally insured, on a PPP loan
application by knowingly and intentionally submitting a PPP Borrower Application
Form that falsely stated Coming Correct Community Ministry II had an average
monthly payroll of $45,500; had 25 employees; was in operation on February 15,
2020 and had employees for whom it paid payroll taxes or independent contracts as
reports in IRS Form 1099-MISC. I also knowingly and intentionally denied that I
owned and operated other businesses and certified all information was true and
correct when, in truth and fact, I knew that this information was incorrect. Finally, I
submitted supporting documentation that included a fake Gusto payroll report and a
false 2019 IRS Schedule C (Form 1040).

Aleta Necole Thomas Date
Defendant

14. Further Prosecution

The United States shall not initiate additional criminal charges against the

defendant in the Northern District of Oklahoma that, as of the date of the

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defendant’s acceptance of this agreement, arise from its investigation of the
defendant’s actions and conduct giving rise to the instant Second Superseding
Indictment, save and except crimes of violence and criminal acts involving violations
investigated by the United States Internal Revenue Service. The defendant
understands, however, that this obligation is subject to all “Limitations” set forth
below, and that the United States Attorney’s Office for the Northern District of
Oklahoma is free to prosecute the defendant for any illegal conduct (i.e., violation of
federal criminal laws) not discovered by or revealed to the Government during its
investigation or occurring after the date of this agreement.

The United States shall not initiate additional criminal charges against any other
targets in the Northern District of Oklahoma that, as of the date of the defendant’s
acceptance of this agreement, arise from its investigation of the defendant’s actions
and conduct giving rise to the instant Second Superseding Indictment, save and
except crimes of violence and criminal acts involving violations investigated by the
United States Internal Revenue Service. The defendant understands, however, that
this obligation is subject to all “Limitations” set forth below, and that the United
States Attorney’s Office for the Northern District of Oklahoma is free to prosecute
the these other targets for any illegal conduct (i.e., violation of federal criminal laws)
not discovered by or revealed to the Government during its investigation or

occurring after the date of this agreement.

Revised 02-28-20

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15. Dismissal of Remaining Counts

If the Court finds the defendant’s pleas of guilty to be freely and voluntarily made
and accepts the pleas, then the United States will move, at the appropriate time, to
dismiss the remaining counts in the instant case, if any, as to this defendant.

Except as provided in Fed. R. Crim. P. 11(c)(1)(©), if the defendant’s guilty pleas
are rejected, withdrawn, vacated, or reversed at any time, the United States will be
free to prosecute the defendant for all charges of which it then has knowledge, and
any charges that have been dismissed will be automatically reinstated or may be re-
presented to a grand jury with jurisdiction over the matter. In such event, the
defendant hereby waives any objections, motions or defenses based upon the
applicable statute of limitations, the Speedy Trial Act, or constitutional restrictions as
to the time of bringing such charges.

16. Acceptance of Responsibility

Provided the defendant clearly demonstrates acceptance of responsibility, the
United States agrees to recommend a two-level reduction in offense level pursuant to
U.S.S.G. § 3E1.1. The United States agrees to file a motion recommending that the
defendant receive an additional one-level reduction pursuant to U.S.S.G. § 3E1.1(b)
if the defendant is otherwise eligible therefor. The sentencing judge is in a unique
position to evaluate the acceptance of responsibility, and the Court’s determination
will provide the final approval or disapproval of any Section 3E1.1 point level

reduction for timely acceptance of responsibility.

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The obligations of the Government herein, relative to acceptance of responsibility
are contingent upon the defendant's continuing manifestation of acceptance of
responsibility as determined by the United States. If the defendant falsely denies, or
makes conflicting statements as to, her involvement in the crimes to which she is
pleading, falsely denies or frivolously contests relevant conduct that the Court
determines to be true, willfully obstructs, or attempts to obstruct or impede the
administration of justice as defined in U.S.S.G. § 3C1.1, or perpetrates or attempts to
perpetrate crimes while awaiting sentencing, or advances false or frivolous issues in
mitigation, the United States expressly reserves the right to withdraw any
recommendation regarding acceptance of responsibility without breaching the
agreement.

Sentence

a. Imprisonment
The defendant acknowledges that under 18 U.S.C. § 1014 the maximum statutory

sentence is not more than 30 years of imprisonment and a fine of not more than

$1,000,000.

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b. Supervised Release

Additionally, the defendant is aware, if imprisonment is imposed, that the Court
shall include as part of the sentence a requirement that the defendant be placed on a
term of supervised release after imprisonment not to exceed 5 years.

If the term of supervised release for any count of conviction is revoked, the
defendant may be imprisoned for an additional term not to exceed the term of
imprisonment authorized in 18 U.S.C. § 3583(e)(3) for the offense of conviction,
with no credit being given for any time served while on supervised release. Further,
the Court may impose another term of supervised release following any term of
imprisonment imposed for a violation of supervised release conditions, and this term
of supervised release may not exceed the term of supervised release originally
authorized by statute for the offense of conviction less any term of imprisonment that
was imposed upon revocation of supervised release (18 U.S.C. § 3583(e) and (h)). Ifa
second or subsequent term of supervised release is revoked, the Court may impose
another term of imprisonment not to exceed the difference between any
imprisonment imposed for a prior revocation of supervised release for the offense of
conviction and the term of imprisonment authorized pursuant to 18 U.S.C.

§ 3583(e)(3). Accordingly, the original term of imprisonment when combined with

any term of imprisonment arising from revocations of supervised release, may result

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in a total amount of imprisonment greater than the statutory maximum term for the
offense of conviction.
c. Guidelines

The defendant is aware that the Sentencing Guidelines promulgated pursuant to
the Sentencing Reform Act of 1984 at 18 U.S.C. § 3551 through § 3742, and 28
U.S.C. § 991 through § 998, are advisory. The district courts, while not bound to
apply the Sentencing Guidelines, must consult those Guidelines and take them into
account when sentencing. See 18 U.S.C.A. § 3553(a). The sentence imposed in
federal court is without parole.

Nothing in this plea agreement, save and except any stipulations contained
herein, limits the right of the United States to present to the Court or Probation
Office, either orally or in writing, any and all facts and arguments relevant to the
defendant’s sentence that are available to the United States at the time of sentencing.
The defendant acknowledges hereby that relevant conduct, that is, conduct charged
in any dismissed count and all other uncharged related criminal activities, will be
used in the Sentencing Guidelines calculation. The United States reserves its full
opportunity to speak pursuant to Rule 32(i)(4)(A)(iii) of the Federal Rules of
Criminal Procedure. The defendant further understands that the sentence to be
imposed upon the defendant will be determined solely by the sentencing judge.

17. Stipulations

The defendant and the United States stipulate and agree as follows:

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a. Pursuant to Fed. R. Crim. P. 11(c)(1)(C), the appropriate disposition in this
case is a sentence of not greater than 48 months in prison. This stipulated sentence
departs from the anticipated guideline calculation for the violations to which the
defendant is pleading guilty. The parties have considered various factors in
fashioning this sentence, including the defendant’s timely and full acceptance of
responsibility and accountability, which she has demonstrated by agreeing to serve a
potential prison sentence and to pay restitution, the strength of the evidence, judicial
economy, and the interests of justice, which takes into account the defendant’s role
as a caregiver to both an elderly relative and children. For these reasons, a sentence
of not greater than 48 months of imprisonment, meets the sentencing goals for this
type of case and this defendant. The parties agree upon this sentence regardless of
any advisory Sentencing Guidelines calculations.

b. The parties agree that the defendant may withdraw her pleas of guilty in
the event that the Court rejects the plea agreement.

c. Having been fully apprised by defense counsel of defendant’s right to seek
compensation pursuant to Public Law 105-119, the defendant WAIVES any and all
such right, and stipulates that defendant is not a “prevailing party” in connection
with this case.

18. Limitations
This plea agreement shall be binding and enforceable upon the Office of the

United States Attorney for the Northern District of Oklahoma, but in no way limits,

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binds or otherwise affects the rights, powers, duties or obligations of any state or
local law enforcement agency, administrative or regulatory authorities, civil or
administrative enforcement, collection, bankruptcy, adversary proceedings or suits
which have been or may be filed by any governmental entity, including without
limitation, the Internal Revenue Service, the Tax Division of the Department of
Justice and the trustee in bankruptcy.

19. Breach of Agreement

In the event either party believes the other has failed to fulfill any obligations
under this agreement, then the complaining party shall, in its discretion, have the
option of petitioning the Court to be relieved of its obligations herein. Whether or
not a party has completely fulfilled all of its obligations under this agreement shall be
determined by the Court in an appropriate proceeding at which any disclosures and
documents provided by either party shall be admissible and at which the complaining
party shall be required to establish any breach by a preponderance of the evidence.
The defendant hereby WAIVES any right under Rule 11(d) and (e) of the Federal
Rules of Criminal Procedure to withdraw from defendant’s plea and this agreement,
save and except under circumstances where the Court rejects the plea agreement
under Rule 11(c)(5), except for the limited reasons outlined above in this paragraph,
and except as provided in Fed. R. Crim. P. 11(c)(1)(C).

Except as provided in Fed. R. Crim. P. 11(c)(1)(C), in the event that ALETA

NECOLE THOMAS, after entry of a plea of guilty, unsuccessfully attempts to

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&

withdraw the defendant’s plea of guilty, the United States may continue to enforce
the agreement but will no longer be bound by any particular provision in this
agreement. This provision will not have any continued vitality if it is determined by
the Court that the United States acted in bad faith to bring about the attempted
withdrawal of plea.

20. Conclusion

No agreements, representations or understandings have been made between the
parties in this case, other than those which are explicitly set forth in this plea
agreement and the Plea Agreement Supplement that the United States will file in this
case (as is routinely done in every case, even though there may or may not be any
additional terms) and none will be entered into unless executed in writing and signed
by all of the parties.
SO AGREED:

CLINTON J. JOHNSON
Acting United States Attorney

KRISTIN HARRINGTON Dated

CYMETRA WILLIAMS

Assistant United States Attorney

KEITH WARD Dated
Attorney for Defendant

ALETA NECOLE THOMAS ota!

Defendant

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&

I have read this agreement and carefully reviewed every part of it with my
attorney. I understand it, and I voluntarily agree to it. Further, I have consulted with
my attorney and fully understand my rights with respect to sentencing which may
apply to my case. No other promises or inducements have been made to me, other
than those contained in this pleading. In addition, no one has threatened or forced
me in any way to enter into this agreement. Finally, I am satisfied with the

representation of my attorney in this matter.

ALETA NECOLE eas Dated
Defendant

I am counsel for the defendant in this case. I have fully explained to the defendant
the defendant’s rights with respect to the pending Indictment. Further, I have
reviewed the provisions of the Sentencing Guidelines and Policy Statements and I
have fully explained to the defendant the provisions of those Guidelines which may
apply in this case. I have carefully reviewed every part of this plea agreement with
the defendant. To my knowledge, the defendant’s decision to enter into this

Taal Li is an informed and voluntary one.

KEITH WARD Dated
Counsel for the Defendant

Revised 02-28-20
Defendant's Initials


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