Plea Agreement — United States v. Gooden (Dkt. 40, E.D. Ky.)

Summary

A plea agreement in United States v. Amanda Gooden, Criminal Action No. 6:26-CR-0033-KKC, in the U.S. District Court for the Eastern District of Kentucky, filed June 29, 2026 as Doc. 40. Under Federal Rule of Criminal Procedure 11(c), Gooden will plead guilty to Count One of the Indictment, which charges conspiracy to distribute a mixture or substance containing fentanyl in violation of 21 U.S.C. § 846. The United States will move at sentencing to dismiss Counts Two, Three, Four, and Five and will not bring additional charges based on evidence in its possession, unless the agreement is breached. The agreement sets out the elements of Count One and ends with the defendant's acknowledgment that the agreement is voluntary. Signature blocks are for Assistant United States Attorney Andrew H. Trimble, the defendant and attorney Tomas Paul Miceli.

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Case: 6:26-cr-00033-KKC-EBA Doc#:40_ Filed: 06/29/26 Page: 1 of 6 - Page
                                   ID#: 114

                      UNITED STATES DISTRICT COURT
                      EASTERN DISTRICT OF KENTUCKY
                              SOUTHERN DIVISION
                                     LONDON

CRIMINAL ACTION NO. 6:26-CR-0033-KKC

UNITED STATES OF AMERICA                                               PLAINTIFF

V.                             PLEA AGREEMENT

AMANDA GOODEN                                                        DEFENDANT

                                    k ek * *

      1.     Pursuant to Federal Rule of Criminal Procedure 11(c), the Defendant will

enter a guilty plea to Count One of the Indictment, which charges a violation of 21 U.S.C.

§ 846, conspiracy to distribute a mixture or substance containing a detectable amount of

fentanyl, a Schedule II controlled substance. Pursuant to Rule 11(c)(1)(A), the United

States will move at sentencing to dismiss Counts Two, Three, Four, and Five. Pursuant to

Rule 11(c)(1)(A), the United States will not bring additional charges against the Defendant

based upon evidence in its possession at the time of the execution of this Agreement and

arising out of the Defendant’s conduct within the Eastern District of Kentucky, unless the

Defendant breaches this Agreement.

      2.     The essential elements of Count One are:

             (a) | Two or more persons conspired, or agreed, to distribute a mixture or
                    substance containing a detectable amount of fentanyl, a Schedule IZ
                    controlled substance;

             (b)   The Defendant knew of the conspiracy and its objects, aims, and
                    goals; and

Case: 6:26-cr-00033-KKC-EBA Doc#:40_ Filed: 06/29/26 Page: 2 of 6 - Page

(c)

ID#: 115

The Defendant joined the conspiracy with the intent that at least one
of the conspirators engage in conduct that satisfies the elements of
distribution of a mixture or substance containing a detectable amount
of fentanyl, a Schedule II controlled substance.

3. As to Count One, the United States could prove the following facts that

establish the essential elements of the offense beyond a reasonable doubt, and the

Defendant admits these facts:

(a)

(b)

(c)

From on or about a date in 2025 and until February 12, 2026, the
Defendant worked together with an associate to obtain fentanyl from
a supplier and distribute that fentanyl to other dealers and users in the
Harlan County area of the Eastern District of Kentucky.

On or about January 13, 2026, law enforcement used a confidential
informant to make a controlled purchase of 2.165 grams of fentanyl
from the Defendant’s associate. The transaction was arranged with
the Defendant, but the Defendant’s associate distributed the fentany!
to the informant and received the payment. On or about February 7,
2026, law enforcement used a confidential informant to make a
controlled purchase of 3.172 grams of fentanyl from the Defendant.
Though the Defendant distributed the fentanyl, the Defendant’s
associate participated in the transaction by communicating with the
informant about the details of the transaction prior to it occurring. The
Defendant’s associate was also present during the transaction.

On or about February 12, 2026, in Harlan County, law enforcement
conducted searches of two residences connected to the Defendant and
the Defendant’s associate. During those searches, law enforcement
located, among other things, two firearms, a large amount of United
States currency, 12.054 grams of methamphetamine, and 18.384
grams of fentanyl. The Defendant had obtained one of the firearms
earlier on the date of the search when she accepted it as payment for
fentanyl that she distributed to another individual.

4. The statutory punishment for Count One is imprisonment for not more than

30 years, a fine of not more than $2,000,000, and a term of supervised release of at least 6


Case: 6:26-cr-O00033-KKC-EBA Doc#:40_ Filed: 06/29/26 Page: 3 of 6 - Page

ID#: 116

years. The Defendant has a prior felony drug offense as set forth in the notice filed by the

United States pursuant to 21 U.S.C. § 851, and therefore the Defendant is subject to the

above enhanced statutory punishment. A’mandatory special assessment of $100.00 applies,

and the Defendant will pay this assessment to the U.S. District Court Clerk as directed by

the Court.

5. Pursuant to Federal Rule of Criminal Procedure 11(c)(1)(B), the United

States and the Defendant recommend the following sentencing guidelines calculations, and

they may object to or argue in favor of other calculations. This recommendation does not

bind the Court.

(a)

(b)

(c)

(d)

The United States Sentencing Guidelines (U.S.S.G.) manual in effect
at the time of sentencing will determine the Defendant’s guidelines
range.

Pursuant to U.S.S.G. § 1B1.3, the Defendant’s relevant conduct
includes at least 80 kilograms but less than 100 kilograms of
converted drug weight (fentanyl and methamphetamine mixture),
which corresponds to a base offense level of 22.

Pursuant to U.S.S.G. § 2D1.1(b)(1), increase the offense level by 2
levels because a dangerous weapon was possessed.

Pursuant to U.S.S.G. § 3E1.1 and unless the Defendant commits
another crime, obstructs justice, or violates a court order, decrease the
offense level by 2 levels for the Defendant’s acceptance of
responsibility. If the offense level determined prior to this 2-level
decrease is level 16 or greater, the United States will move at
sentencing to decrease the offense level by 1 additional level based on
the Defendant’s timely notice of intent to plead guilty.

6. No agreement exists regarding the Defendant’s criminal history category

pursuant to U.S.S.G. Chapter 4.

7. The Defendant will not file a motion for a decrease in the offense level based

3


Case: 6:26-cr-00033-KKC-EBA Doc#:40_ Filed: 06/29/26 Page: 4 of 6 - Page
ID#: 117

on a mitigating role pursuant to U.S.8.G. §§ 3B1.2 or 2D1.1(e)(2).

8. The Defendant waives the right to appeal the guilty plea and conviction. The
Defendant reserves the right to appeal the sentence, Except for claims of ineffective
assistance of counsel, the Defendant also waives the right to attack collaterally the guilty
plea, conviction, and sentence.

9. If the Defendant violates any part of this Agreement, the United States may
void this Agreement and seek an Indictment for any violations of federal laws, and the
Defendant waives any right to challenge the initiation of additional federal charges.

10. The Defendant consents to the forfeiture to the United States, by
administrative or judicial proceedings, of all right, title, and interest in the property listed
in the forfeiture allegation of the Indictment. The Defendant agrees that this property is
subject to forfeiture because a nexus exists between the property and the offenses to which
she is pleading guilty, as set forth in the forfeiture allegation of the Indictment. The
Defendant consents to the entry of a Preliminary Order of Forfeiture, pursuant to Federal
Rule of Criminal Procedure 32.2, and agrees take any steps necessary to assist the
government in effectuating the surrender and forfeiture of the assets identified herein,
including but not limited to executing any documents necessary for the surrender and
transfer of title to the United States. The Defendant agrees not to file a claim or petition
seeking remission or otherwise contesting the forfeiture of the assets identified herein in
any administrative or judicial proceeding, or to assist any other person or entity with doing

so, and agrees to withdraw, and hereby withdraws, any such claim or petition that may


Case: 6:26-cr-00033-KKC-EBA Doc#:40_ Filed: 06/29/26 Page: 5 of 6 - Page
ID#: 118

have already submitted. The Defendant voluntarily and knowingly waives all provisions
in Rule 32.2 pertaining to notice and/or the timing of forfeiture orders. The Defendant also
waives her right, if any, to a jury trial on forfeiture and all constitutional, legal, or equitable
defenses to the forfeiture. The Defendant agrees that this forfeiture is separate and distinct
from any restitution, fine, or penalty ordered by the Court and shall survive bankruptcy.

11, The Defendant abandons any interest in, and consents to the official use,
destruction, or other disposition of, any item obtained by any law enforcement agency
during the course of the investigation, unless an item is specifically provided for in another
provision of this Agreement. The Defendant also waives any notice of a proceeding to
implement the official use, destruction, or other disposition of any item abandoned under
this paragraph.

12. This document contains the complete and only Plea Agreement between the
United States Attorney for the Eastern District of Kentucky and the Defendant. The United
States has not made any other promises to the Defendant.

13. This Agreement does not bind the United States Attorney’s Offices in other
districts, or any other federal, state, or local prosecuting authorities.

14. The Defendant and the Defendant’s attorney acknowledge that the Defendant
understands this Agreement, that the Defendant’s attorney has fully explained this
Agreement to the Defendant, and that the Defendant’s entry into this Agreement is

voluntary.


Case: 6:26-cr-00033-KKC-EBA

Date: Le/eq [ee

Doc #: 40 Filed: 06/29/26 Page: 6 of 6 - Page
ID#: 119

JASON D. PARMAN
FIRST ASSISTANT U.S. ATTORNEY

Date: (Q- I 1-302

By: A Ju

Andrew H. Trimble
sistant United States Attorney

he ocho

Date: O6-/1- 24

Amanda Gooden _
Defendant

fig xEFL

Tomas Paul Miceli
Attorney for Defendant

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