Plea Agreement Letter — No. 3:23-cr-00067 (Dkt. 85, D. Or.)

Summary

A plea agreement letter between the U.S. Attorney's Office for the District of Oregon and Eric Kurnezis, filed March 20, 2025 in Case No. 3:23-cr-00067-IM-1. Kurnezis agrees to plead guilty to a count of the Superseding Indictment charging a violation of Title 18, United States Code, Section 1349, which carries up to 20 years' imprisonment and a fine of $250,000. The factual statement says Kurnezis agreed with Bennett to fraudulently obtain funds under the Paycheck Protection Program and conspired with recruiters to submit at least 350 fraudulent PPP applications.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

Text recognized from a scanned document; may contain errors.

Case 3:23-cr-00067-IM Document 85 ~~ Filed 03/20/25 Page1of 10

PORTLAND MAIN OFFICE. _ EUGENE BRANCH
WOOSW Third: Avena, Suite 600 405 5 Sth: Avenus; Suite 240)
Portland, Oregon 97204 Eugene, Oregon 97401
4503) 727-1000 (G44) 465-8771
_ wwantesda) govhisaa/or ye
Meredith D.M..Bateman, US, DEPARTMENT OF JUSTICE MEDFORD BRANCH
Robert Trisatio. ‘United States-Attorney'’s Office 310 Wert Sixth Street
‘Assixtant v. 8 eel Districtof Oregon Medford, craton Pigvh
. = tata : oe United States. Attomey
pt Portland Office
101F Street 4309
San. Diego; CA 92101
gvalencialaw@vihise.cony
amy Caneel diny.cont,
Re: United States v. Eric Kurnezis, Case No, 3:23-cr-00067-IM-1
Blea Apreement Letter
1.  — Parties/Senpe: This plea agreenunt is between this United Spates Attomey’s Office

(USAO) and defendant, and this does not bind any other federal, state, or local proseciting;
adininistrative, or regulatory authority. ‘This agreément does not apply to any charges other than.
those specifically mentioned in this: agreeruerit.

Chatges’ ‘The deftudant agrees to plead: guilty: to Count | of te Supeméding Indictment
filed in this matter; Which charges Conspiticy to Cominit Wire Fraud, in vinlation of Tide 18,
United States Code, Section 1349, Defendant also adinits tha first forfeiture allegation in the

Superseding Indictment,

3. Penalties: “The maximum penalties for Conspiracy: to Commit Wire Fraud, as, charged any
‘Count.1 of the: Superseding Tadictment, are 20 years’ imprisonment, fine of $250,000 (or twice. _
the gross pecuniary gainsor losses resulting from the offense if such:aniunt exceeds $250,000),

3 years of supervised releage, and.a $100 fee atweranient. Defendant agrees to pay the-fee
Assessment on the day of sentencing or explaid to tlie satisfaction of the Court: why this. cannot be

“=

i - The USAO will move. at the:time of sentencing to dismiss.
any, remaining chargé in nthe be Shiperseding’ Tndictnient, The USAO also agrees to: forge ay
additional charges against defendant renilting from this investigation, if, first, call of the essential
farts underlying such: charyes are known to the USAQ atthe dine of this apreemient and, second,
: ant ig convicted and sentenced in conformity with this:agreement.


Case 3:23-cr-00067-IM Document 85 ~~ Filed 03/20/25 Page 2 of 10

Guadalupe Valencia
Asay Potter
Pages?

fencing, 9) ‘The parties agree thatthe Court ust first'determine the applicable
aitiiuoly guideline 1 range, then detertiine a reasonable sentence vonsidering that range and the.
factors listed in 18 U.S:C..§ 3953(a). ‘Where the patties agree that senten¢ing factors. apply, «uch
ARTOCUNNE constitiites sufficient prouf to satisly the applicable evidentiary standard,

erg ‘the Offenses: For defendant ta be found. guilty: of Conspiracy to Conimnit
Wire Rend i iaviolation of Tide 18, United States Code; Section 1349, the United States most:
prove the following elements beyond a reaacnable doulit:

A. First there was ani agreement between two or more persons fo Commit the crime

of Wire Fraud; and.
B. —-Segorid, the defendant becaine « member of that conspiricy knowing ofits s object
and intending to help: accomplish it.

‘To prove Wire Fraud, in-violation of Title 18, United States Code, Section 1343, the United:
States .omst prove:the following elements beyond axeasonable doubt:

A. First, the dafendanit knowingly patticipated i in, devised or intended to. devise a
scheme oc plan to. defraud, or a scheme.orplan for obtaining money.or property
by. mearik of, fatse or faudilent pretensts,. representations. or promises;

B Sécond, the tartans made as part of the schenie were material; thit is, they had
amatural tendency to influence, ot were capable. of influencing, & person to part.
with money: or property:

C. Third, defendant acted with the intent to defraud; thatis, the intent to deceive and
cheat; and.

D, Fourth, defendant used, or caused to be used, ‘an interstate wire Communication to
casry ont of altenipt to cairy dut-an essential part of the scheme.

The defeidanr stipulates that tlie evidence of his relevant conduct: summarized in
paragraph 7 establishes each of these elements as to Count-I in thé Superseding Indictment
beyoutd any reasonable dovibt.

7. Factual Basis: Défeadant agvees that the United States:conld prove the following ‘facts at
trial beyoud a reascmable doubt,

a, Begitming on «dave anlorown and eontioning until atleast March 2022, ‘there was
an agreement between defendant.and covongpirators known, and. unknown,
including Fredrico Williams ("Williams”), Lynisha Wells (Wells), and Nikkia


Case 3:23-cr-00067-IM Document 85 ~~ Filed 03/20/25 Page 3 of 10

‘Guadalupe: Valencia

Bennett (‘Bennett '), to fraudulently obtrin fonds under the Paycheck Protection

Program ("PPP"), Deferidant joined in that agreenienit knowing of its 5 puspose and
intending to help accomiplish that purpose.

pedis cally, defendant conspired with reezuitersito gather faloe and fraudulent

siness information fori applicants for defendant-ro submit at least 350
fraudulent PPP applications on bebalfof the applicants through Blusacorn, a:
lender service provider; to Capital Plus Finnncial,.a lender-participating in the
PPP. The false and fraudulent business ittfomnation included misrepresentations:
about the existence of the businesses, Bross revenues, payroll amounts, and. the
number. of eaiployess..

&. Defendant also. copies vvith Nathan Reis aint. Stephanie Hockridge, the co-

founders and:co-ciwners of Blueacom, among others, to submit these fraudulent’
applications.

A Williatns was a. renrviter for defendant who was responsible for providing false

and fraudulent biisineds information to: defendant.

e Wellsand. Bennett were: applicants whos Wiliams cextnited.
£ Based on ihe aiintepresentations in at least 350 fraudulent PPP applications,

Capital Plus Financial funded at least $60,000,000 in joans:

g, Defendant fequited applicants to pay hit fee far his role in-the conspiracy.

Applicants paid defendant: apptonimately $3,000,000 for submitting the
frmdileat- applications.

te Between March 4, 2021 and March 19, 2021, defendant submitted-hwe: fraudulent

PPP applications.on Williams’ belialf Thibse applications were submitted using
setvers in Oregon aud theti routedto servers in Virginia... Based on the
misrepresentations in these applications, Capital Plus Financial approved the:
loans and funded $203,694 to. Williams, Walliams paid defendant approxiniately
$10,000: for his cote di securing the Joans. ‘The SBA paid lender fees. and interest
totaling $17,173,57 for these loans.

i, Between March 13, 2021 and April 4, 2021, defendant submitted tye fraudulent

ppp applications on Wells’ behalf. These applications were suibniiited ising
servers in Oxegon aud thea routed to servers in Virginia. Based othe
saistepresentalions inthese applications, Capital Plus Financial approved the:
loans and'finded $292,190 to. Welle, Wells paid Williams $45, 000:for his sole in
securing the lomie-and approximately $15,000-9F that amount was. paid to
defendant. The SBA. pald lender fees avid interest totaling $15,829.80 for these:


Case 3:23-cr-00067-IM Document85 ~~ Filed 03/20/25 Page 4 of 10

Guadalupe Valencia
Any Potter
Page 4

Between March 30, 2021 and May.3, 2021, defendant submitted three fraudulent
"ppp applications on Bennett's behalf, These ‘applications were subinitted ising
servers in Oregon And then touted to secvers in Virginia. These three applications
atiemptediadditional PPP funding totaling $2,341,172:tnt were denied, Bennett
agreed to pay defendant spprosimaely§ $117,000 but did not jay.

& Beveen February 3, 2021 and October 7,202, defendant aibmitted six
fraudulent PPP applications and five: Frauidytent PPP forgiveness applications on
his own bebalf'te Capital Plus Financial. All of these applications were submitted

‘Using servers in Oregon and then routed td sexvers in Virginia.

b, On February 3, 2021, defendant sibsaitted a faudulent application for Elevated .
‘Resear. on which he misrepresented Elevated Research's business establishment
date, number of employers, and average monthly payroll. To support the
imisrepresentations, defendant submitted « fandulant IRS Form 940 for 2020.
Based on the inisrepreséntations, Capital Plus Financial finded $146,500 to
defendant’s biink account, which defendant spent on personal expenses.

Defendant Jater submitted a fraudilent forgivetiess application on which he
misrepresented he spent the-eniire loan on payroll, andthe SBA paid off the loan

principal and intarest: The SBA paiddendis fees totaling $7,325 and interest paid
on the forgivenes application totiled an additional $1,062.12.

c. OQwor.about February 5; 2021, defendant aibniined a faudolent application for
Kamiezis Consulting on wwitich ‘he niisrepresented Kamezis Consulting’s bisiness
establishment: date, number of employees, an average monthty, payroll. To

‘support t

for 2020. Basedon. the misrepresentations, Capital Plus Financial fatided.
'$103;660'to defendant's bak account! which defendant spent.on personal:
exposé, Defendant later submitted a fraudwent forgiveness application on.
which he saisreptesented he spent the entire ldan-on-payroll, ond the'SBA paid off
the loan principal and interest... The SBA paid lender fees totaling $5,183 and.
interest paid or the forpiveness application totaled:an additional $731,

d, On of about Febraary 14,2021, defendant submitted a fraudulent application for
Eric Kartezis d/b/a Eric. Kacnesis.on which hé misrepresesited “Bric Karneais””
‘business totablisiment daie, number of employees, and average monthly payroll,
To support the misrepreseritations, defendant sibmitted a fraudulent IRS.Fonn
1040 Schedule C for 2020. Based on the misteprestittations, Capital Plus
Finaricial funded $20,832:10 defendant's bank account, which defendant used to.
epena.new bank. account, Defendant later aibmitted # fraudulent forgiveness

application on which he misrepresented he spent the entire:loan on payroll, and


Case 3:23-cr-00067-IM Document 85 ~~ Filed 03/20/25 Page 5of 10

Guadalupe Valencia
Asay Potter

the'SBA paid off the loan principal and interest; The SBA. paid lender fees
totaling $2,500 and interest paidion the forgiveness application totaled an.
additional $132,

&. On May 1,202), defeudant submitted fraudulent second draw PPP applications
for Elevated Researcti, Kamezis Consulting, and Bite Kamezis d/b/a Ene.
Kamezis.: Oneach of these three applications, defindant tiisrepresented the
‘busineases’ establishment dates, number of employees, and average momhly
payroll, Defendant submitted fraudulent IRS-Fonns for each application, Based.
on the misrepreseritations, Capital Plus Financial funded a total:of $260,782 to
defendant's bak accounts.. Defendant spentsnost of these finds-on personal
Expenses.

£ On Oetuber 7,2021, defendant submitted two fraudulent forgivencss applications
for the second deaw loans to Elevated Research and Kumezis Consulting. on
which hie iisrepresénted le spent the entire loans on payroll, and the SBA paid
off the loan principals and interest. The SBA paid lender fees totaling $11,998,
anid interést paid.on the forgiveness applications totaled an additional $1,025.69.
8. Relevant Conducts The parties agree that the {ollowing sentencing guidelines
calculations are.cortect, The parties make no agreement regarding defendant's caminal-history
category biit esnpiate that he isin category I.

J Base Offense Level - USSG §

OD)

Roose of at least $25,000,000 but nat more than
| $65,000,000 USSG.§ 2BLI@NINCL),

G4

Acceptance of Responsilulity ~ USS

Use of Sephisiested Means ~ USSG § 2510510) _ |

SBI ©).

‘The parties cesorve the ripht to.ttgue that additional specific offense characteristica under
‘the Sentencing Guidelines are-appropriate,

Of estonsio

defendant fully admis mod ace

+

bility: The defendant must demonstrate tw the Court that:
opis responsibility unler U.S.8.G. § SELL for defendant's

‘tunlawdul:condiict inthid cals. If defiridant dons 96, the USAQ will reconimend a three-level
reduction in defendant's wifends level. "The USAO reserves the tight to change this
recommendation if defeadatit, between plea and sentencing, commits auy celmtioal offense,
Obstridte Or attempt to obstruct jistics as explained in US'S. § 3C11, or acts.inconsistently

with acceptance of responsibility as explained jn W.S.8.07 § 3ELA.


Case 3:23-cr-00067-IM Document85 ~~ Filed 03/20/25 Page 6 of 10

Guadalupe Valencia
Page &

Vaiver of Full Discovery: Asa material term of this offer and agreement, defendant
‘s offer to make available the evidence gathered in the investigation

expressly. accepts ihe USAQ’

of thig matter for on-site itepection atid the USAQ's production of. limited discovery as of the
date of this agreementin full satisfaction of the United States’ discovery obligations in. this case.
Defendant knowingly, intelligently, and voluntarily waives bis 1 ights to further production of
‘evidence or information from the United Stites; even though he may be entitled teach:
production under the Federal Rules of Criminal Procedure, the discavery orders of the Court, and

aly prior derands for. discovery.

ration of Soda 8 waiver of substantive motions, ae of Papal collateral a attack,
and full discovery, his prompt accéptatice: of responsibility: as, deuctibed in paragraph 9, :
and his-compliance with all other:tenms of this agieement, the USAQ will recomment
downward vadance of: Four: tevels.. i oe ,
“12, entencine Recommendation ‘The USAO will recommend. the fow-enil of the
applicable guideline. range as long:as- defendant demonstrates ab atesptance of responsibility as
explained above. “For purposes of this agréement; the Jow-end of the applicable guideline range

is thardafined by the Sentencing Table in USSG Chapter.5, Pact A, as detemmined by the Court at
sentencing. Defendant muy séek any lawful seatenee;. Thete is no agreement on the length of

any term of siupervis

Defendant reserves ss thecight to seek a downward departiire, adjustment, or variance from
the applicatile sentencing guideline range determined by the-Court and understands that the:

govemmient restr ves its right to oppose: euch: a.cequest.

Defendatit agrees that, should defendant sock x downward depaxtute, adjustment,
vatiance Brom the applicable guidelinevange deterrniied by the Court and Probation: Oftiee,
defendant will provide the govemment with notice of: (1)the factual basis for such request;

@) any evidence defendant intends to introduce of rely upon at thé sentencing tearing: and

(3) any witnesses, including expert witnesses, defendant intends:to call or rely npon.atthe-
sentencing hearwig; Such notice must be provided to the goveriment.no lafer than the
‘Weduesday prior to thi week during which the seatedcing heating is scheduled. Defendant
agrees that if defendant fils to-comply with this notice requirement, defendant will not: oppose a

povernment motion fora postponement of the sentencing hearitig,.

14, z tion Rulief: Defendant knowitigly and voluntarily

waives: ihe right aed frat any, napect of thie ponviction: and gentence on:any. grounds, except
for & clainy that: (1) the sentence imposed exceeds the statutory: maxinaura, (2) the Court anives:

Bt an advisory sentencing guideline rarige: by applying an upward de ‘under the provisions
of Guidelines Chapters: 4-or 5K, or. (3) the Court exercises its discration under WUSL.


Case 3:23-cr-00067-IM Document85 ~~ Filed 03/20/25 Page /7 of 10

Guadalupe Valencia
Page 7

§ 35539) to.inpose-a sentence exceeding the advisory guideline sentencing tange ax determined
by the Court atthe tints of sentencing without required notice to the parties. Should defendant
seek nn appeal: despite thig waiver; te USAO may take any position on any issue om appeal and
many pursue any charges forgone putsuant to. this agreenient, Defendant also waives the right to
file any collateral atfack, including a motion wader 28 U.S.C. § 2255, challenping any aspect of
the conviction of sentence on any grounds, except on grounds of ineffective assistance of
oounsél, and except as provided in Fed, R-Cnimn. P. 33 and 18 U.S.C. § 3582(6)(2).

Defendant expressly agroow that these waivers shill remain effective if the USAO alters
its Seitending recommendation consistent with the terms of this agreement or because defendant
otherwise breaches this agreement. .

15. Fail Disclosure/Reservation of Righis: The USA will filly inform the PSR writer and.
‘the Court of the facts and Jaw related to-defeudant's ease. Except-as set forth in this agreement,
the patties reserve all other sights tp make sentencing renoimendations and to respond fo
Hobons and arguments by the opposition, beat
16. Coixt Not Bound: The Coutt is not bound by the recommendations of the patties or of
the presentende regort (PSR) woler. Because this agreement is minds under Rule 11 (c)(1)G3) of

conducts, defendant may’ vot Withdraw any guilty-plea or rescind,
‘this plea apreentent if the Courtdoss not follow the agreements ot recommendations of the
parties. .

victizns of the offences of conviction. and his relevant conduct pursuant to:18 U.S.C. §§ 3663 and.
3663A. ‘Defendant agress thie Conrtia required and shall impose an order of restitution in an,
amount to be detemmined, burthat ainount will bent less than $25,000,000 and not more than
$65,000,000. Pursuant to 18 U.S.C. § 3664(4)(5), should the patties te nnable to.reach an-
apreed upon cestitoGon amount 10 days priorto sentencing, the Govemmient willinform the
Court and a restitution hearing will be sét tiot to‘exceed 90 days after sentencing:

Defendant-aprees fully to disclose all assets in which defendant has any interest-or over’
which deferidant exercises contol, diréetly or indirectly, including those held by a spouse,
nonuines,-or third party, Defendait apross to tnithfully complete the Financial Disclogire
‘Statement provided herein by the earlier of fourteen days from defendatit’s‘signahite on this plea
‘agresment of the dite of defendant's entry of a.guilty plea, sign it under penalty of perhity, and
provide itto both the: USAO and the United States Probation Office. Defendant agrees to
provide updates with any material changes'in circumstances, as described in 18 U.S.C. §

3664(k), withinixeven days of the overt giving rise 6 the changed circumstances.

., _Deteétislant expressly authorizes the USAO to obtain a eredit report.on defendant,
Defendant agrees i provide waivers, contents, or releasew-requeated by tie USA to access.


Case 3:23-cr-00067-IM Document 85 ~~ Filed 03/20/25 Page 8 of 10

Guadalupe Valencia
Any Potter
Page 8 8

records to verify the financial information. Defendant also authorizes the USAO to inspect-and.
‘copy all financial: documents and ioforination held by the U.S. Probation Office.

“The parties :agree-that defendant's failure to timely: ‘anid accurately complete and sign the.
Financial Disclosure Statement, and any-npdate thereto, thay, in addition to any other penalty ox
‘remedy, -constitutis defendant's failure to accept responsibility mider USSG § E11,

Defendant 9 agrees to nofify the Financial Litigation Unit of the USAO before defendant
‘transfers any interest in property witha value, exceeding $1000 owned directly ot indirectly,
individually or jointly, by defendant, i inchiding any-interest. held or owned under atty natiie,
including trusts, parnerships, and: comporations,

Restitution

The Coiint'shall dtder restitution to each: victim in the full amoiit of each Vietion's losses
as. deteomined by the Court, but thar amount will be not Jess than'$25:000,000 and not more than
$65,000,000. Defendant apraes te pay restitution for all losses canted by defendant's relevant
-ponduct, regardidss of whether: the Indicument alleges such condhtict..

Defendant: understands and aprees that the total amount of any: monetary judgment that.
tho Court ordets defendant to pay will be thie. Defendant finthet understands and agrees that
pursuant to18 U.S.C. § 3614; defendant may beresentenced to any sentence which might have
originally been imposed ifthe court dotenmines that defendant has knowingly and willfully
refused to pay a fine 6 restitution as ordered:or has failed to mike: sufficient bona fide efforts.to
pay a fine or restihition, Additionally, défendant undemtands and agrees that the United States
may enforce collection of. any fine or restilution i imriposed-in:this. case pursuant to 18 WS.C..
§§-3572, 3613, and 3664(cn), notwithstanding any initial or subsequently modified payment
schedule set by the court: Defendant understands that any nionetary debt defendant owes related
to this matter may be included in the Treasury Offaet Program to potentially offeet defendant’ s:
federal retirement benefits, tax refiinds; acd: other federal benefits.

‘Pursuantto 18 .8.C, § 36126) 1)(F), defendant understands and agrees that until.a fine
Or destitition order is paid in full, defendant must notify the USAO of any change in the mailing
address or residence address within. 30 ‘days of the ehange, Further, pureiant to 18 U.S.C:
§ 3664(k), defendant shall notify the Court anid. the USAO of any material change in defendant's
economic circumstances tharmight affect defendant's ability to pay restitution, including; butinot
limited to, new or changed employniditt, | inicieanes in income, iiheritances, monetary gifts, orany
othér acquinition of assets oF Money,

tt]


Case 3:23-cr-00067-IM Document 85 ~~ Filed 03/20/25 Page 9 of 10

Guadalupe Valencia

thority: By signing this agreement, defendant knowin ingly and
volonieely fori all Baht title; and interest in and to all assets which are subject to forfeiture
pursuant t0 18 U.S.C. § 981@)0XC) and 28°U.S.C. §.2461(c),ocluding all: property listed in the
Bill of Particulars fited in this case. (ECF No. 44),, which defendant-admits is propecty. teal at
personal, which constitutes of iy derived from proceeds traceable to the violations:set forth in
Count 1 of the Supérseding Indichnent,

Agreement ty Civil Forfeiture: Defendant agrees not to file a claim ot jpetition

Or bo wvithdcaw'a any claim of potition already filed Yo:any of the listed property in any: civil
proceeding, adnuitistrative-or judicial, which, has been thitiated. Defendant further waives the
right to: noice of any forfeiture proveeding: involving this.property and, agrees nat-torassiét others
in filing a claim in any forfeiture progeeding.

C ‘No Alteration-ar Satisfaction: Defendant knowingly and voluntarily waives the
right to a jury tial on thé forfeiture “of BSHEIS. ‘Defendant knowingly atid voluntarily waives all
constitutional, legal and equitable defenses to thy forfeiture of these assets, including any claim
or defense under the Bighth Amendment to the United States Constitution, and any rights under
Rule 32.2 of the Federal Rules of Criminal Procedure. ‘Defendant further agrees forferture.of
defendant’ s ascets shall not be: treated-as: satisfaction of any fine, testiqation, cost of
ent, oF any other penalty this Court may: siapoRe upon defendant in addition to

‘itle Assistatice: Defendant agrees to fully assist the USAQ# in the forfeirare.of
the ‘ena assets: Sand to:take whatever stepit: ate necessary to pass cleat fille w the United States,
including butnot limited to surrender of titls and exemution-of any doe
transfer defendant's interest in. any of the above property to: the: United States, and: assistin
bringing any asséte located outside the United States within the jurisdiction of the United States,
and taking whatever steps are necessity to cnstire! that aisets subject to, forfeiture are not sold,
disbursed; wasted, hidden, or otherwise made unavailable for forfeiture.

E, dentifiod: ‘The USAQ reserves its tight to proceed against any
remainigg: sasets spot identified. either j in this aprowment ac in the civil actions which are being
resolved along with this plea of guilty, including any property in which defendant has any
interest or control, if said assets, real or petxonal, tangible or intangible, are subject to forfeitute,

nal Order of Forteiting: Dafendaut.agiees not to contést entry ofa Final:
Order of Forfeiture verellecting these forfeiture: tennis at the contlusion of the criminal case.

49, reach of Plea Agreement: If defendant trenches the terms. of this agreamiant.or
commits any new cominal offenses between signing this agreement: and sentencing, the USAQ is


Case 3:23-cr-00067-IM Document 85 ~~ Filed 03/20/25 Page 10of10

Guadalupe Valencia
Page 10

reliewed of its obligatiotis tinder this agtedinent, but defendant may .siot withdraw any guilty plea
ot rescind his waivers of appeal and post-conviction telief, as-desetibed im paragraph 13, supra,

If defenidant believes that thé United States has breached the plea agreement, defendant
Must raise any sucli claim before the district:court, cither prior te or atsentoncuty,. if defendant
fails to-raise a breach claini in districr-couet, defendant has waived any such claim and shall be
prechaled thereby froni raising a breach:claini for the first time on appeal.
20,  Memorialization. of Agreement: No promises, agreemefits. or conditions other than
those set fortly inthis agreement will be effective anless memorialized in writing and signed by
alll parties listed below ox ten firnted on the record before the Const: Tfdefendant accepts this
‘offer, please sign and attach the original of this letter to. the Petition to Enter-Plea.

21. ‘Deadline: This plea offer expires if'not accepted arid signed by defendant and counsel,
and.ceseived by the USAO by 5:00 pan. PST'on February.10, 2025,

Sincerely,

NATALIE WicerT

T have carefully reviewed every pait of this ageeeinent with may attonney. Tunderstand,
aud voluntarily agrée:to its terms, T expressly waive niy sights to appeal as outlined in this
agreement. I wish to plead guilty because, in fact, Cant pnilty. ;

Erie Kamneais, Defendant

. TLrepresent the defendant as legal counsel. 1 have carefidlly reviewed every pact of this
apreement with defendant. ‘Ta my knowledge, deféndarit’s decistons.to niake this agreement and

” ~

to plead guilty are infornied and volmitary ones. é

Date T Guadalupe Valencia
Amy Potter
Atiomoys for Defendant

File and source

File

85.pdf

Size

618,488 bytes

SHA-256

89b042fe12e32a6f50424932f57a4cb8380bcb814aa710160eeb21a8f57cd343

Our copy

85.pdf