Plea Agreement — United States v. Eco Shield, LLC. (Dkt. 8, S.D. Cal.)

Summary

A plea agreement in United States v. Eco Shield, LLC, No. 3:21-cr-01463-JLS, in the U.S. District Court for the Southern District of California, filed May 25, 2021 as Document 8. It is made by Acting U.S. Attorney Randy S. Grossman and Assistant U.S. Attorney Melanie K. Pierson with the company, advised by counsel Ward Clay. Eco Shield agrees to waive indictment and plead guilty to an Information charging it with knowingly effecting the entry of goods upon a false classification as to quality and value and with payment of less than the duty legally due, on or about June 10, 2019, under 18 U.S.C. §§ 541 and 2. The government agrees to defer other non-tax charges based on the same conduct. Samir Haj signs for the company, swearing to the factual basis.

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.10 Page 1 of 16

    RANDY S. GROSSMAN
    Acting United States Attorney
    MELANIE K. PIERSON
    Assistant United States Attorney
    California Bar No. [atty bar no.]
    Federal Office Building
    880 Front Street, Room 6293
    San Diego, California 92101-8893
    Telephone: (619) 546-7976
    Email: Melanie. Pierson@usdoj.gov

    Attorneys for United States of America

                          UNITED STATES DISTRICT COURT

                        SOUTHERN DISTRICT OF CALIFORNIA

10   UNITED STATES OF AMERICA,          Case No. 21crl463-JLS

11             Plaintiff,

          Vv.                           PLEA AGREEMENT
12

     ECO SHIELD, LLC.
13

14             Defendant.

15       IT IS HEREBY AGREED between the plaintiff, UNITED STATES OF

16   AMERICA, through its counsel, Randy S. Grossman, Acting United States

17   Attorney, and Melanie K. Pierson, Assistant United States Attorney, and

18   Defendant ECO SHIELD, LLC, with the advice and consent of Ward Clay,

19   counsel for Defendant, as follows:

20                                      I

21                                  THE PLEA

22       Defendant agrees to waive Indictment and plead guilty to an

23   Information charging Defendant with:

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         Knowingly effecting the entry of goods and merchandise upon
         a false classification as to quality and value and by the
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         payment of less than the amount of duty legally due, on or
         about June 10, 2019, within the Southern District of
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         California, in violation of 18 U.S.C. §§ 541 and 2.

27       The Government agrees to (1) defer any other non-tax charges based

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    on the same conduct, and (2) not prosecute Defendant thereafter on such

     Plea Agreement                                    Def. rniciais SAL

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.11 Page 2 of 16

deferred charges unless Defendant breaches the plea agreement or the
guilty plea entered pursuant to this plea agreement is set aside for
any reason. If Defendant breaches this agreement or the guilty plea is
set aside, section XII below shall apply.
This plea agreement is part of a “package” disposition as set forth
in Section VI.E below
It

NATURE OF THE OFFENSE

A. ELEMENTS EXPLAINED

The offense to which Defendant is pleading guilty has the following
elements:

1. An employee of the defendant, acting within the scope of the
employment for the benefit of the company, knowingly effected the entry
of goods or merchandise into the United States; and

2. The employee, acting within the scope of employment for the
benefit of the company, knew at the time of entry that the goods were
falsely classified as to value and entered by payment of less than the

duty legally owed.

B. ELEMENTS UNDERSTOOD AND ADMITTED -— FACTUAL BASIS

Defendant has fully discussed the facts of this case with defense
counsel. Defendant has committed each element of the crime and admits
that there is a factual basis for this guilty plea. The following facts
are true and undisputed:

1. At all times relevant herein, Samir Haj was an owner and
manager of Eco Shield, LLC, a company located in San

Diego, California.

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.12 Page 3 of 16

Haj, in San Diego, negotiated an agreement with a foreign
exporter that allowed him to import a product called
EcoAirDoctor from Japan at a cost of $6.25 per unit. The
product was a small badge that was represented to emit
a gas that would kill viruses within a certain distance
of the badge.

Products represented to kill viruses in the environment
are regulated by the U.S. Environmental Protection
Agency as pesticides, pursuant to Title 7, United States
Code, Section 136a.

On or about June 10, 2019, Haj, acting within the scope
of his employment for the benefit of Eco Shield, LLC, in
San Diego, caused the importation of 125,040 units of
EcoAirDoctor products, to be delivered to San Diego. On
the invoice Haj submitted to U.S. Customs at the time of
importation, Haj falsely declared the value of the
125,040 units to be $258,833 (approximately $2.07/unit)
knowing the true value was $781,500, and knowing the
false declaration as to value resulted in the entry of
the goods at less than the duty legally owed. In
addition, as Haj was aware, the goods were falsely
declared as to quality, described as air purifiers
rather than pesticides.

The parties agree that the defendant paid $12,971 of
duty upon entry of the EcoAirDoctor products, but should

have actually paid $46,890, leaving an underpayment of

3 CZ
Def. Initials

duty of $33,919.


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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.13 Page 4 of 16

6. The parties further agree that the defendant obtained
$427,689 in proceeds as a result of the offense.
III
PENALTIES
The crime to which Defendant is pleading guilty carries the
following penalties:
A. a maximum five years of probation for an organization;
B. a fine which is the greater of $500,000 or twice the amount
of gross gain or loss;
on a mandatory special assessment of $400 per count; and
D. forfeiture of the property which constitutes or is derived
from proceeds traceable to the violation;
E. In addition, Defendant shall be subject to an order of
restitution to victims of the offense requiring Defendant to repay such
persons at least $86,754.

IV

DEFENDANT’S WAIVER OF TRIAL RIGHTS AND
UNDERSTANDING OF CONSEQUENCES

This guilty plea waives Defendant’s right at trial to:
A. Continue to plead not guilty and require the Government to
prove the elements of the crime beyond a reasonable doubt;

B. A speedy and public trial by jury;

on The assistance of counsel at all stages;
D. Confront and cross-examine adverse witnesses; and
E. Testify and present evidence and to have witnesses testify on

behalf of Defendant.

//
//

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.14 Page 5 of 16

V

DEFENDANT ACKNOWLEDGES NO PRETRIAL RIGHT TO BE
PROVIDED WITH IMPEACHMENT AND AFFIRMATIVE DEFENSE INFORMATION

Any information establishing the factual innocence of Defendant
known to the undersigned prosecutor in this case has been turned over
to Defendant. The Government will continue to provide such information
establishing the factual innocence of Defendant.

If this case proceeded to trial, the Government would be required
to provide impeachment information for its witnesses. In addition, if
Defendant raised an affirmative defense, the Government would be
required to provide information in its possession that supports such a
defense. By pleading guilty Defendant will not be provided this
information, if any, and Defendant waives any right to this information.
Defendant will not attempt to withdraw the guilty plea or to file a

collateral attack based on the existence of this information.
VI

DEFENDANT’S REPRESENTATION THAT GUILTY
PLEA IS KNOWING AND VOLUNTARY

Defendant represents that:

A. Defendant has had a full opportunity to discuss all the facts
and circumstances of this case with defense counsel and has
a clear understanding of the charges and the consequences of
this plea. By pleading guilty, Defendant may be giving up,
and rendered ineligible to receive, valuable government
benefits. The conviction in this case may subject Defendant
to various collateral consequences, including but not limited
to revocation of probation in another case; debarment from
government contracting; and suspension or revocation of a
professional license, none of which can serve as grounds to
withdraw Defendant’s guilty plea.

B. No one has made any promises or offered any rewards in return
for this guilty plea, other than those contained in this
agreement or otherwise disclosed to the Court.

Cc. No one has threatened Defendant or Defendant’s owners,
officers, managers or employees to induce this guilty plea.

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.15 Page 6 of 16

D. Defendant is pleading guilty because Defendant is guilty and
for no other reason.

E. The disposition contemplated by this agreement is part of a
“package” disposition with codefendant(s) Samir Haj. If any
defendant in the package fails to perform or breaches any
part of their agreement, no defendant can withdraw their
guilty plea, but the Government is relieved from and not bound
by any terms in any agreements in the package.

VII

AGREEMENT LIMITED TO U.S. ATTORNEY’S OFFICE
SOUTHERN DISTRICT OF CALIFORNIA

This plea agreement is limited to the United States Attorney’s
Office for the Southern District of California, and cannot bind any
other authorities in any type of matter, although the Government will
bring this plea agreement to the attention of other authorities if
requested by Defendant.

VIII

APPLICABILITY OF SENTENCING GUIDELINES

The sentence imposed will be based on the factors set forth in 18
U.S.C. § 3553(a). In imposing the sentence, the sentencing judge must
consult the United States Sentencing Guidelines (Guidelines) and take
them into account. Defendant has discussed the Guidelines with defense
counsel and understands that the Guidelines are only advisory, not
mandatory. The Court may impose a sentence more severe or less severe
than otherwise applicable under the Guidelines, up to the maximum in
the statute of conviction. The sentence cannot be determined until a
presentence report is prepared by the U.S. Probation Office and defense
counsel and the Government have an opportunity to review and challenge

the presentence report. Nothing in this plea agreement limits the

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.16 Page 7 of 16

Government’s duty to provide complete and accurate facts to the district
court and the U.S. Probation Office.
IX

SENTENCE IS WITHIN SOLE DISCRETION OF JUDGE

This plea agreement is made pursuant to Federal Rule of Criminal
Procedure ill(c) (1) (B). The sentence is within the sole discretion of
the sentencing judge who may impose the maximum sentence provided by
statute. It is uncertain at this time what Defendant’s sentence will
be. The Government has not made and will not make any representation
about what sentence Defendant will receive. Any estimate of the probable
sentence by defense counsel is not a promise and is not binding on the
Court. Any recommendation by the Government at sentencing also is not
binding on the Court. If the sentencing judge does not follow any of
the parties’ sentencing recommendations, Defendant will not withdraw
the plea.

x

PARTIES’ SENTENCING RECOMMENDATIONS

A. SENTENCING GUIDELINE CALCULATIONS

Although the Guidelines are only advisory and just one factor the
Court will consider under 18 U.S.C. § 3553(a) in imposing a sentence,
the parties will jointly recommend the following Base Offense Level,
Specific Offense Characteristics, Adjustments, and Departures:

Base Offense Level [§ 2T13.1] 12
The parties further agree that the defendant has a culpability

score of 3, as the company has less than 10 employees and has fully

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.17 Page 8 of 16

cooperated in the investigation and clearly demonstrated acceptance of
responsibility for the offense.

B. NO FURTHER ADJUSTMENTS AND SENTENCE REDUCTIONS INCLUDING
THOSE UNDER 18 U.S.C. § 3553

Defendant may not request or recommend additional downward
adjustments, departures, or variances from the Sentencing Guidelines
under 18 U.S.C. § 3553.

Cc. “FACTUAL BASIS” AND “RELEVANT CONDUCT” INFORMATION

The facts in the “factual basis” paragraph of this agreement are
true and may be considered as “relevant conduct” under USSG § 1B1.3 and
as the nature and circumstances of the offense under 18 U.S.C.
§ 3553 (a) (1).

Cc. SPECIAL ASSESSMENT/FINE/RESTITUTION/FORFEITURE

1. Special Assessment

The parties will jointly recommend that Defendant pay a special
assessment in the amount of $400.00 per felony count of conviction to
be paid forthwith at time of sentencing. Special assessments shall be
paid through the office of the Clerk of the District Court by bank or
cashier’s check or money order made payable to the “Clerk, United States
District Court.”

2. Fine

The parties will jointly recommend that Defendant pay a fine at
the low end of the applicable guideline range, which the parties agree
is $42,000, which the Court shall order payable forthwith.

3. Restitution

The parties will jointly recommend that the defendant pay
restitution in the sum of $52.835 for the cost of disposal of the

pesticides and $33,919 as repayment of the unpaid duties, for a total

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.18 Page 9 of 16

of $86,754, to be paid forthwith at the time of sentencing, jointly and
severally with co-defendant Samir Haj. Defendant agrees and understands
that any payment schedule imposed by the Court is without prejudice to
the United States to take all actions and take all remedies available
to it to collect the full amount of the restitution. Defendant further
agrees that notwithstanding any court ordered schedule for payment, the
full amount of restitution is due and payable forthwith and delinquent
until paid in full.

Defendant agrees that the restitution, restitution judgment,
payment provisions, and collection actions of this plea agreement are
intended to, and will, survive defendant, notwithstanding the abatement
of any underlying criminal conviction after the execution of this
agreement. Defendant further agrees that any restitution collected
and/or distributed will survive it, notwithstanding the abatement of
any underlying criminal conviction after execution of this agreement.

The restitution described above shall be paid through the Office
of the Clerk of the District Court by bank or cashier’s check or money
order made payable to the “Clerk, United States District Court.”

Further, the restitution described above shall be paid to or on
behalf of the following agency:

Victim Amount
NFC Collections Section $52,835.00
Attn: DOJ Restitution

Re: FP&F 2021250400038901

P.O. Box 68907

Indianapolis, IN 46268

U.S. Customs and Border Protection $33,919
9945 Customhouse Plaza
San Diego, CA 92154

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.19 Page 10 of 16

4.Forfeiture

Defendant’s conviction will include forfeiture. In addition to the
penalties in the plea agreement, federal law states Defendant must
forfeit to the United States all property, real and personal, which
constitutes or is derived from proceeds obtained directly or indirectly
from the offense, jointly and severally with co-defendant Samir Haj.

As part of Defendant’s guilty plea to Count 1 of the Information,
as set forth in section I of the plea agreement, Defendant agrees to
forfeit $427,689 to the United States, which is the proceeds of the
offense. Defendant agrees to pay the United States half the forfeited
property by way of cashier’s check payable to U.S. Customs and Border
Protection, with the remainder to paid in equal monthly installments
over the period of probation. In the event that Defendant fails to
timely pay the $427,689, the United States reserves all remedies
available to it, including but not limited to vacating the Plea
Agreement and entry of an order of forfeiture for the $427,689 in
proceeds and authorization and a finding that the provisions of Title
21, United States Code, Section 853(p) as applicable under Title 18,
United States Code, Section 982(b)for the substitution of property exist
immediately without the need of further hearings or evidence. In
addition, the Government will be authorized to take all collection
actions available to it in addition to the substitution of assets.

Defendant admits that $427,689 represents property constituting
proceeds or derived from proceeds traceable to a violation of 18 U.S.C.
$541 (Entry of Goods Falsely Classified) and is subject to forfeiture
to the United States pursuant to 18 U.S.C. § 981(a) (1) (C) and 28 U.S.C.

$2461. Defendant further warrants and represents as a material fact

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.20 Page 11 of 16

that all money it pays toward the forfeiture belongs to the organization
alone and that no other person or entity has any interest or claim in
them.

Defendant consents and agrees to the immediate entry of an order
of forfeiture upon entry of the guilty plea. Defendant agrees that upon
entry of the order of forfeiture, such order shall be final as to
Defendant’s interests in the proceeds that it pays to the United States
as part of the forfeiture or that are subsequently substituted or
collected by the United States as part of the forfeiture. Defendant
agrees to immediately withdraw any claims in pending administrative or
civil forfeiture proceedings to properties seized in connection with
this case that are directly or indirectly related to the criminal
conduct. Defendant consents to the forfeiture of all properties seized
in connection with this case. Defendant agrees to execute all documents
requested by the Government to facilitate or complete the forfeiture
process including providing a full and complete financial statement for
all assets and liabilities and disclosure of all transfers of property
valued at more than $5,000 that occurred after the date the Defendant
was charged with criminal violations in this case. The Defendant shall
provide the financial statement to the attorney for the United States
on the first date scheduled for sentencing if the forfeiture has not
been paid on or before that date. Defendant further agrees not to
contest, or to assist any other person or entity in contesting, the
forfeiture of property seized in connection with this case. Contesting
Or assisting others in contesting the forfeiture shall constitute a

material breach of the plea agreement, relieving the Government of all

its obligations under the agreement including but not limited to its

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.21 Page 12 of 16

agreement to recommend an adjustment for Acceptance of Responsibility.

Defendant further agrees to waive all constitutional and statutory
challenges (including direct appeal, habeas corpus, or any other means)
to any forfeiture carried out in accordance with this agreement,
including any claim that the forfeiture constitutes an excessive fine
or punishment under the United States Constitution. Defendant agrees to
take all steps as requested by the United States to pass clear title to
forfeitable assets to the United States and to testify truthfully in
any judicial forfeiture proceeding.

Defendant agrees that the forfeiture provisions of this plea
agreement are intended to, and will, survive defendant, notwithstanding
the abatement of any underlying criminal conviction after the execution
of this agreement. The forfeitability of any particular property
pursuant to this agreement shall be determined as if defendant had
survived, and that determination shall be binding upon defendant’s
successors and assigns until the agreed forfeiture, including any agreed
money judgment amount, is collected in full. Defendant understands and
agrees that interest shall accrue on the $427,689 forfeiture if it does
not pay it in full on or before the first date scheduled for sentencing,
which interest shall accrue at the federal judgment rate calculated
from the date of entry of the order of forfeiture.

D. PROBATION

If the Court imposes a term of probation, Defendant will not seek
to reduce or terminate early the term of probation until Defendant has
served at least 2/3 of the term of probation and has fully paid and
satisfied any special assessments, fine, criminal forfeiture judgment,

and restitution judgment.

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.22 Page 13 of 16

XI

DEFENDANT WAIVES APPEAL AND COLLATERAL ATTACK

Defendant waives (gives up) all rights to appeal and to
collaterally attack every aspect of the conviction and sentence,
including any restitution order up to $100,000. This waiver includes,
but is not limited to, any argument that the statute of conviction or
Defendant’s prosecution is unconstitutional and any argument that the
facts of this case do not constitute the crime charged. The only
exceptions are 1) Defendant may appeal a sentence of a fine above the
high end of the guideline range recommended by the Government at
sentencing, and 2) Defendant may collaterally attack the conviction or
sentence on the basis that Defendant received ineffective assistance of
counsel. If Defendant appeals, the Government may support on appeal the
sentence or restitution order actually imposed.

XII

BREACH OF THE PLEA AGREEMENT

Defendant and Defendant’s attorney know the terms of this agreement
and shall raise, before the sentencing hearing is complete, any claim
that the Government has not complied with this agreement. Otherwise,
such claims shall be deemed waived (that is, deliberately not raised
despite awareness that the claim could be raised), cannot later be made
to any court, and if later made to a court, shall constitute a breach
of this agreement.

Defendant breaches this agreement if Defendant violates or fails
to perform any obligation under this agreement. The following are non-
exhaustive examples of acts constituting a breach:

1. Failing to plead guilty pursuant to this agreement;

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.23 Page 14 of 16

2. Failing to fully accept responsibility;

3. Failing to appear in court;

4, Attempting to withdraw the plea;

5. Failing to abide by any court order related to this case;
6. Appealing (which occurs if a notice of appeal is filed)

or collaterally attacking the conviction or sentence in
violation of Section XI of this plea agreement; or

7. Engaging in additional criminal conduct from the time of
arraignment until the time of sentencing.

If Defendant breaches this plea agreement, Defendant will not be
able to enforce any provisions, and the Government will be relieved of
all its obligations under this plea agreement. For example, the
Government may proceed to sentencing but recommend a different sentence
than what it agreed to recommend above. Or the Government may pursue
any charges including those that were dismissed, promised to be
dismissed, or not filed as a result of this agreement (Defendant agrees
that any statute of limitations relating to such charges is tolled
indefinitely as of the date all parties have signed this agreement;
Defendant also waives any double jeopardy defense to such charges). In
addition, the Government may move to set aside Defendant’s guilty plea.
Defendant may not withdraw the guilty plea based on the Government’s
pursuit of remedies for Defendant’s breach.

Additionally, if Defendant breaches this plea agreement: (i) any
statements made by representatives of the Defendant, under oath, at the
guilty plea hearing (before either a Magistrate Judge or a District
Judge); (ii) the factual basis statement in Section II.B in this

agreement; and (iii) any evidence derived from such statements, are

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.24 Page 15 of 16

admissible against Defendant in any prosecution of, or any action
against, Defendant. This includes the prosecution of the charge(s) that
is the subject of this plea agreement or any charge(s) that the
prosecution agreed to dismiss or not file as part of this agreement,
but later pursues because of a breach by the Defendant. Additionally,
Defendant knowingly, voluntarily, and intelligently waives any argument
that the statements and any evidence derived from the statements should
be suppressed, cannot be used by the Government, or are inadmissible
under the United States Constitution, any statute, Rule 410 of the
Federal Rules of Evidence, Rule 11(f£) of the Federal Rules of Criminal
Procedure, and any other federal rule.

XIII

CONTENTS AND MODIFICATION OF AGREEMENT

This plea agreement embodies the entire agreement between the
parties and supersedes any other agreement, written or oral. No
modification of this plea agreement shall be effective unless in writing
signed by all parties.

XIV

DEFENDANT AND COUNSEL FULLY UNDERSTAND AGREEMENT

By signing this agreement, Defendant certifies that all members of
the defendant organization have read it. The members of the defendant
organization have discussed the terms of this agreement with defense
counsel and fully understands its meaning and effect. The members of
the defendant organization have fully discussed with counsel the
possible conflicts of interest that might arise as a result of defense

counsel representing both Eco Shield LLC and Samir Haj and knowingly

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Case 3:21-cr-01463-JLS Document 8 Filed 05/25/21 PagelD.25 Page 16 of 16

and intelligently waive any potential or actual conflicts of interest,
to the full extent permitted by law.
xV

DEFENDANT SATISFIED WITH COUNSEL

The members of the defendant organization have consulted with
counsel and are satisfied with counsel’s representation. This is
Defendant’s independent opinion, and Defendant’s counsel did not advise

Defendant about what to say in this regard.

RANDY S. GROSSMAN
Acting United States Attorney

Ag & Jor

DATED\ MELANIR|K. PIERSON
Assistant U.S. Attorney

U-¥-2| Leu’ Ce
DATED WARD CLAY 7
Defense Counsel

IN ADDITION TO THE FOREGOING PROVISIONS TO WHICH I AGREE, I SWEAR UNDER
PENALTY OF PERJURY THAT THE FACTS IN THE “FACTUAL BASIS” SECTION ABOVE
ARE TRUE.

H-g- QA

eZ,

SAMIR HAJ
For Defendant Eco Shield LLC

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