Plea Agreement — United States v. Jamie McGowen
Summary
A plea agreement letter dated October 9, 2024 from the United States Attorney's Office, District of Oregon, to counsel for Jamie McGowen, filed December 11, 2024 as Document 42 in Case 3:22-cr-00360-AN. McGowen agrees to plead guilty to Count 1 (wire fraud), Count 5 (bank fraud) and Counts 3 and 7 (money laundering) and admits the forfeiture allegations. The factual basis states that McGowen, owner of Salem Outsourcing, Inc., retained $705,613 in federal income withholding and payroll taxes from Al's Trailer Sales of Salem Inc. in 2016 through 2018. It also states that beginning no later than April 3, 2020, McGowen applied for fifteen COVID-relief loans and grants with false applications, causing a total actual loss of $1,367,247. The USAO will recommend the low end of the applicable guideline ranges.
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“Plea Agreement — United States v. Jamie McGowen.”
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Case 3:22-cr-00360-AN Document 42 Filed 12/11/24 Page 1 of 11
PORTLAND MAIN OFFICE EUGENE BRANCH
1000 SW Third A venue, Suite 600 405 E 8th Avenue, Suite 2400
Portland, Oregon 97204 Eugene, Oregon 97401
(503) 727-1000 (541) 465-6771
www.usdoj.gov/usao/or
Meredith D.M. Bateman U.S. DEPARTMENT OF JUSTICE MEDFORD BRANCH
Assistant U.S. Attorney United States Attorney ' s Office 310 West Sixth Street
Meredith.bateman@usdoj.gov District of Oregon Medford, Oregon 97501
(503) 727-1000 Natalie K. Wight (541) 776-3564
Reply to Portland Office United States Attorney
October 9, 2024
VIA EMAIL ONLY
Serguel Mawuko Akiti
Katryna Spearman
sakiti@lowtherwalker.com
kspearman@lowtherwalker.com
LOWTHER I WALKER LLC
101 Marietta Street, NW, Suite 3650, Atlanta, GA 30303
Re: United States V. Ja,nie McGowen, Case No. 3:22-cr-00360-tYo
Plea Agreement Leiter
Dear CounseL
1. Parties/Scope: This plea agreement is between this United States Attorney's Office
(USAO) and defendant, and thus does not bind any other federal, state, or local prosecuting,
administrative, or regulatory authority. This agreement does not apply to any charges other than
those specifically mentioned herein.
2. Charges: Defendant agrees to plead guilty to Count 1 of the Indictment, which charges
wire fraud in violation of Title 18, United States Code, Section 1343, Count 5 of the Indictment,
which charges bank fraud in violation of Title 18, United States Code, Section, 1344, and Counts
3 and 7 of the Indictment, which charge money laundering in violation of Title 18, United States
Code, Section 1957. Defendant also admits the forfeiture allegations.
3. Penalties: The maximum sentence for wire fraud is 20 years' imprisonment, a fine of
$250,000 (or twice the _gross pecuniary gains or losses resulting from the offense if such amount
exceeds $250,000), 3 years of supervised release, and a $100 fee assessment. The maximum
sentence for bank fraud is 30 years' imprisonment, a fine of $1,000,000, 5 years of supervised
release, and a $100 fee assessment. The maximum sentence for money laundering is 10 years'
imprisonment, a fine of $250,000 (or twice the gross pecuniary gains or losses resulting from the
offense if such amount exceeds $250,000), 3 years of supervised release, and a $100 fee
assessment.
• Revised June 2023
Case 3:22-cr-00360-AN Document 42 Filed 12/11/24 Page 2 of 11
S'erguel Akiti •
Katryna Spearman
Re: Jamie McGowen Plea Agreement Letter
Page 2
Defendant agrees to pay the fee assessments by the time of entry of guilty plea or explain
to the Court why this cannot be done.
4. Dismissal/No Prosecution: The USAO will move at the time of sentencing to dismiss
any remaining counts against defendant. The USAO further agrees not to bring additional
charges against defendant in the District of Oregon arising out of this investigation, lmown to the
USAO at the time of this agreement.
5. Elements: In order for defendant to be found guilty of Count' 1 of the Indictment (wire
fraud), the government must prove the following elements beyond a reasonable doubt:
A. First, defendant lmowingly devised or intended to devise a material scheme or
artifice to defraud, or to obtain money by means of false or fraudulent pretenses,
representations or promises, or omissions of fact;
B. Second, the statements made or facts omitted as part of the scheme were material;
that is, they had a natural tendency to influence, or were capable of influencing, a
person to part with money or property;
C. Third, defendant acted with the intent to defraud; that is, the intent to deceive and
cheat; and
D. Fourth, defendant used, or caused the use of interstate wires to can-y out or
attempt to carry out an essential part of the scheme.
In order for defendant to be found guilty of Count 5 of the Indictment (bank fraud) , the
government must prove the following elements ·beyond a reasonable doubt:
A. First, defendant lmowingly carried out a scheme or plan to obtain money or
property from a financial institution by making false statements or promises;
B. Second, defendant lmew that the statements or promises were false;
C. Third, the statements or promises were material; that is, they had a natural
tendency to influence, or were capable of influencing, a financial institution to
pmi with money or property;
D. Fomih, the defendant acted with the intent to defraud; that is, the intent to deceive
or cheat; and
E. Fifth, Bank of America, N.A. , was insured by the Federal Deposit Insurance
Corporation (or otherwise covered by 18 U.S.C. § 20).
Rev ised June 2023
Case 3:22-cr-00360-AN Document 42 Filed 12/11/24 Page 3 of 11
Serguet Akiti
Katryna Spearman
Re: Jamie McGowen Plea Agreement Letter
Page 3
In order for defendant to be found guilty of Counts 3 and 7 of the Indictment (money
laundering), the government must prove the following elements beyond a reasonable doubt:
A. First, defendant knowingly engaged or attempted to engage in a monetary
transaction;
B. Second, defendant knew the transaction involved criminally derived property;
C. Third, the property had a value greater than $10,000;
D. Fourth, the prope11y was, in fact, derived from the wire fraud and bankfraud
alleged in Counts 1 and 5; and
E. Fifth, the transaction occurred in the United States.
Defendant stipulates that uncontested and admissible evidence of her relevant conduct as
summarized in paragraph 6, infra, establishes each of the foregoing elements as to each count of
the Indictment beyond any reasonable doubt.
6. Factual Basis: Defendant has fully discussed the facts of this case and any potential
defenses with defense counsel. Defendant has committed each of the elements of the crime(s) to
which defendant is pleading guilty and admits there is a factual basis for defendant's guilty
plea(s). The following facts are true and undisputed:
A. Defend ant is owner of Salem Outsourcing, Inc. ("SOI"). Defendant is also the
owner of Reality RV and Trailers Inc ("Reality RV"), owner of Valley Investment
Company d/b/a Casey' s Restaurant Inc. ("Valley Investment"), and a owner of
Reality Auto.
B. Between August 2016 and December 2018, defendant, through SOI, was
responsible for the payroll, income withholding, and employment taxes for Al ' s
Trailer Sales of Salem Inc. ("Al's Trailer").
C. Defendant paid Al ' s Trailer' s employees either via checks from SOI bank
accounts in Oregon or via direct deposit transfers from SOI bank accounts in
Oregon through Intuit Payroll ' s bank account in Texas.
D. Defendant admits she lmowingly caused interstate wire transfers from SOI bank
accounts in Oregon to Intuit Payroll' s bank account in Texas.
E. On November 2, 2017, defendant caused an interstate wire transfer of $55,303.34
from SOI' s bank account in Oregon to Intuit Payroll' s account in Texas for direct
Rev ised June 2023
Case 3:22-cr-00360-AN Document 42 Filed 12/11/24 Page 4 of 11
Serguel Akiti
Katryna Spearman
Re: Jamie McGowen Plea Agreement Letter
Page 4
deposit to Al ' s Trailer's employees from which she withheld income and payroll
taxes as part of her scheme.
F. Between August 2016 and December 2018, while defendant withheld income and
payroll taxes from Al ' s Trailer' s employers, she did not pay over any federal
income withholding or payroll taxes to the Internal Revenue Service ("IRS").
Instead, defendant used those funds for personal expenditures, including
purchasing ownership interest Al's Trailers for $200,000 and an RV for $79,000.
G. On August 7, 2018, defendant used $79,000 money derived from her scheme to
purchase an RV.
H. In total, defendant improperly retained the following amounts of federal income
withholding and payroll taxes from Al's Trailer in the following years: 2016
($92,028), 2017 ($328,739), and 2018 ($284,846) for a total of $705,613.
I. Following the enactment of the CARES Act in March 2020 and the American
Rescue Plan Act in March 2021 , defendant recognized an opportunity to procure
COVID-relief funds from the United States Small Business Administration
("SBA") by submitting fraudulent applications for Paycheck Protection Program
("PPP") loans, an Economic Injury Disaster Loan ("EIDL") and advance, and a
Restaurant Revitalization Fund ("RRF") grant.
J. Beginning no later than April 3, 2020, and continuing at least through December
30, 2021, defendant applied for fifteen COVID-relief loans and grants by
submitting false and fraudulent applications to the SBA and participating lenders.
K. Defendant admits she submitted the following false and fraudulent applications:
Date Applicant Entity Program and Amount
Application Number Funded
April 3, 2020 Al ' s Trailer PPP #15988848 $454,532
April 14, 2020 Klamath Falls Paiis and PPP #13500934 $50,100
Service Inc
April 14, 2020 Klamath Falls RV Inc. PPP #13526200 $52,800
April 30, 2020 Reality RV PPP #21723838 $293 ,180
May 6, 2020 Valley Business & Tax PPP #17338786 $45,317
Services Inc.
May 19, 2020 Sutherlin RV Inc. PPP #18135895 $106,983
June 27, 2020 Reality Auto EIDL #3307022210 $3,000
October 2, 2020 Klamath RV Inc. EIDL #3314832770 declined
Revised June 2023
Case 3:22-cr-00360-AN Document 42 Filed 12/11/24 Page 5 of 11
Serguel Akiti
Katryna Spearman
Re: Jamie McGowen Plea Agreement Letter
Page 5
October 2, 2020 Klamath Falls Parts and EIDL #3314832648 declined
Services
January 19, 2021 Klamath Falls Paiis and PPP #24533528 $50,175
Service Inc.
January 19, 2021 Klamath Falls RV Inc. PPP #25078524 $52,885
February 10, 2021 Valley Business & Tax PPP #25292714 $45,317
Services Inc.
May 11 , 2021 Valley Investment RRF #31232251 $143,675
Company /Casey's
December 14, Valley Accounting EIDL #3325694678 declined
2021
December 30, Valley Accounting and Tax EIDL #3326083997 declined
2021
L. On April 3, 2020, defendant submitted PPP application #15988848 on behalf of
Al's Trailer to Bartle of America, a federally insured financial institution. On that
application, defendant lmowingly and willfully misrepresented Al's Trailer's
average monthly payroll and number of employees. To support her
misrepresentations, defendant submitted an IRS Form 1120(U.S. Corporation
Income Tax Return), never filed with the IRS, but created for the purposes of
securing the PPP Loan. Defendant also lmowingly and willfully misrepresented
that defendant was not the owner of any other business when defendant, in fact
had 100% ownership of 5 other businesses and 50% ownership in two other
businesses. Defendant also certified on the application she was not engaged in
illegal activities, when in fact she was engaged in the aforementioned payroll tax
scheme, and attested and certified all the information on the application and all
supporting documentation submitted was true and accurate.
M. Based on defendant's misrepresentations on PPP application #15988848 , Bank of
America funded a PPP loan of $454,5 32 to Al's Trailer' s Bank of America
account that defendant controlled.
N. On May 13, 2020, defendant used $21 ,000 of the PPP funds to write a check to
Lakeside Investment Group for rent.
0. Based on the fraudulent applications noted above, defendant caused a total actual
loss of $1,367,247, including interest and SBA paid lender fees.
II I
Revised June 2023
Case 3:22-cr-00360-AN Document 42 Filed 12/11/24 Page 6 of 11
Serguel Akiti
Katryna Spearman
Re: Jamie McGowen Plea Agreement Letter
Page 6
7. Sentencing Factors: The parties agree that the Court must first determine the applicable
advisory guideline range, then determine a reasonable sentence considering that range and the
factors listed in 18 U. S.C. § 3553 (a). Where the parties agree that sentencing factors apply, such
agreement constitutes sufficient proof to satisfy the applicable evidentiary standard.
8. Relevant Conduct: The parties agree that the sentencing guidelines calculation for
Counts 1 (wire fraud) and 3 (money laundering) are grouped pursuant to USSG §3D1.2(d) and
the following is accurate:
Guideline Section Offense Level
Base Offense Level- §2Bl.l(a)(l), §2S1.l(a)(l) 7
Loss of$705 ,613 -- §2Bl.l(b)(G), §2S1.l(a)(2) +14
Conviction under 18 U.S.C. § 1957 - §2S 1.1 (a)(l ), (b )(2)(A) +1
Offense Level 22
Acceptance of Responsibility - USSG §3El.1 -3
. Adiustment for Zero-Point Offender USSG §_4C 1.1 -2
Total 17 (24-30 months at Criminal
History Category 1)
The parties agree that the following sentencing guidelines calculation for Counts 5 (bank
1
fraud) and (money laundering) are grouped pursuant to USSG §3D1 .2(d) and the following is
accurate:
Guideline Section Offense Level
Base Offense Level- ~2Bl.l(a)(l ), ~2S1.l(a)(l) 7
Loss of $1 ,367,247 - §2Bl.l(b)(H), §2S1.l(a)(2) +14
Over $1 ,000,000 in gross receipts from one or more financial +2
institutions - § 2B 1.1 (b )(17)(A)
Conviction under 18 U.S.C. §1957 - §2S1.l(a)(l), (b)(2)(A) +l
Offense Level 24
Acceptance of Responsibility- USSG §3El.1 -3
Adiustment for Zero-Point Offender USSG §4Cl .1 -2
Total 19 (30-37 months at Criminal
History Category 1))
The government reserves the right to argue that defendant used sophisticated means to
conunit bank fraud in relation to Count 5 and should receive a two-level enhancement pursuant
to USSG 2Bl.l(b)(10)(c). This would result in a total offense level of21 (37-46 months at
Criminal History Category I). Defendant reserves the right to oppose this request.
Revi sed June 2023
Case 3:22-cr-00360-AN Document 42 Filed 12/11/24 Page 7 of 11
Serguel Akiti
Katryna Spearman
Re: Jamie McGowen Plea Agreement Letter
Page 7
The parties reserve the right to argue that additional specific characteristics under the
Sentencing Guidelines are appropriate. They parties make no agreement as to defendant's
criminal history but estimate defendant qualifies for the zero-point offender adjustment.
9. Acceptance of Responsibility: Defendant must demonstrate to the Court that defendant
fully admits and accepts responsibility under USSG § 3El .1 for defendant' s unlawful conduct in
this case. If defendant does so, the USAO will recommend a three-level reduction in defendant's
offense level. The USAO reserves the right to change this recommendation if defendant,
between plea and sentencing, commits any criminal offense, obstructs or attempts to obstruct
justice as explained in USSG § 3C 1.1 , or acts inconsistently with acceptance ofresponsibility as
explained in USSG § 3El.1.
10. Sentencing Recommendation: The USAO will recommend the low end of the
applicable guideline ranges for each count as long as defendant demonstrates an acceptance of
responsibility as explained above.
11. Additional Departures, Adjustments, or Variances:
A. Defendant reserves the right to seek downward departure, adjustment, or variance
from the applicable sentencing guideline range determined by the Court and understands that the
government reserves its right to oppose such a request. The basis for the departure, adjustment,
or variance shall be limited to USSG § 5K2 or 18 U.S.C. § 3553.
B. Defendant agrees that, shouid defendant seek a downward departure, adjustment,
or variance from the applicable guideline range determined by the Court and Probation Office,
defendant will provide the government with notice of: ( 1) the factual basis for such request;
(2) any evidence defendant intends to introduce or rely upon at the sentencing hearing; and
(3) any witnesses, including expert witnesses, defendant intends to call or rely upon at the
sentencing hearing. Such notice must be provided to the government no later than the
Wednesday prior to the week during which the sentencing hearing is scheduled. Defendant
agrees that if defendant fails to comply with this notice requirement, defendant will not oppose a
government motion for a postponement of the sentencing hearing.
12. Waiver of Appeal/Post-Conviction Relief: Defendant knowingly and voluntarily
waives the right to appeal from any aspect of the conviction and sentence on any grounds, except
for a claim that: (1) the sentence imposed exceeds the statutory maximum, or (2) the Court
arrives at an advisory sentencing guideline range by applying an upward departure under the
provisions of Guidelines Chapters 4 or SK, or (3) the Court exercises its discretion under 18
U.S.C. § 3553(a) to impose a sentence which exceeds the advisory guideline sentencing range as
determined by the Court. Should defendant seek an appeal, despite this waiver, the USAO may
take any position on any issue on appeal. Defendant also waives the right to file any collateral
Revised June 2023
Case 3:22-cr-00360-AN Document 42 Filed 12/11/24 Page 8 of 11
Serguel Akiti
Katryna Spearman
Re: Jamie McGowen Plea Agreement Letter
Page 8
attack, including a motion under 28 U.S.C. § 2255, challenging any aspect of the conviction or
sentence on any grounds, except on grounds of ineffective assistance of counsel, and except as
provided in Fed. R. Crim. P. 33 and 18 U.S.C. § 3582(c)(2). In the event that [any of]
defendant's conviction(s) under this agreement are vacated, the government may reinstate and/or
file any other charges, and may take any position at a resentencing hearing, notwithstanding any
other provision in this agreement.
13. Court Not Bound: The Court is not bound by the recommendations of the parties or of
the presentence report (PSR) writer. Because this agreement is made under Rule 11 (c)(1 )(B) of
the Federal Rules of Criminal Procedure, defendant may not withdraw any guilty plea or rescind
this plea agreement if the Court does not follow the agreements or recommendations of the
parties.
14. Full Disclosure/Reservation of Rights: The USAO will fully inform the PSR writer and
the Court of the facts and law related to defendant's case. Except as set forth in this agreement,
the parties reserve all other rights to make sentencing recommendations and to respond to
motions and arguments by the opposition.
15. Breach of Plea Agreement: If defendant breaches the terms of this agreement, or
commits any new criminal offenses between signing this agreement and sentencing, the USAO is
relieved of its obligations under this agreement, but defendant may not withdraw any guilty plea.
If defendant believes that the government has breached the plea agreement, defendant
must raise any such claim before the district court, either prior to or at sentencing. If defendant
fails to raise a breach claim in district court, defendant has waived any such claim and is
precluded from raising a breach claim for the first time on appeal.
16. Restitution: Defendant agrees to an order of full restitution to all victims of the offenses
of conviction and her relevant conduct pursuant to 18 U.S.C. §§ 3663 and 3663A. The parties
agree that the Court shall impose an order of restitution of $2,072,860, ($705 ,613 due to the IRS
and $1 ,367,247 due to the SBA), which will be reduced by any amount defendant has already
repaid by the time of sentencing.
Defendant agrees fully to disclose all assets in which defendant has any interest or over
which defendant exercises control, directly or indirectly, including those held by a spouse,
nominee, or third party. Defendant agrees to truthfully complete the Financial Disclosure
Statement provided herein by the earlier of fomieen days from defendant's signature on this plea
agreement or the date of defendant' s entry of a guilty plea, sign it under penalty of pe1jmy, and
provide it to 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), within seven days of the event giving rise to the changed circumstances.
Revised June 2023
Case 3:22-cr-00360-AN Document 42 Filed 12/11/24 Page 9 of 11
Serguel Akiti
Katryna Spearman
Re: Jamie McGowen Plea Agreement Letter
Page 9
Defendant expressly authorizes the USAO to obtain a credit report on defendant.
Defendant agrees to provide waivers, consents, or releases requested by the USAO to access
records to verify the financial information. Defendant also authorizes the USAO to inspect and
copy all financial documents and information held by the U.S. Probation Office.
The parties agree that defendant's failure to timely and accurately complete and sign the
Financial Disclosure Statement, and any update thereto, may, in addition to any other penalty or
remedy, constitute defendant's failure to accept responsibility under USSG § 3El.1.
Transfer of Assets
Defendant agrees to notify the Financial Litigation Unit of the USAO before defendant
transfers any interest in property with a value exceeding $1000 owned directly or indirectly,
individually or jointly, by defendant, including any interest held or owned under any name,
including trusts, partnerships, and corporations.
Restitution
The Court shall order restitution to each victim in the full amount of each victim' s losses
as determined by the Court. Defendant agrees to pay restitution for all losses caused by
defendant's conduct, regardless of whether counts of the Indictment dealing with such losses will
be dismissed as part of this plea agreement.
Defendant understands and agrees that the total amount of any monetary judgment that
the Court orders defendant to pay will be due. Defendant further understands and agrees that
pursuant to 18 U.S.C. § 3614, defendant may be resentenced to any sentence which might have
originally been imposed if the court determines that defendant has lmowingly and willfully
refused to pay a fine or restitution as ordered or has failed to make sufficient bona fide efforts to
pay a fine or restitution. Additionally, defendant understands and agrees that the government
may enforce collection of any fine or restitution imposed in this case pursuant to 18 U.S.C. §§
3572, 3613, and 3664(m), notwithstanding any initial or subsequently modified payment
schedule set by the court. Defendant understands that any monetary debt defendant owes related
to this matter may be included in the Treasury Offset Program to potentially offset defendant's
federal retirement benefits, tax refunds, and other federal benefits.
Pursuant to 18 U.S.C. § 3612(b)(l)(F), defendant understands and agrees that until a fine
or restitution 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 change. Further, pursuant to 18 U.S.C. §
3664(k), defendant shall notify the Court and the USAO of any material change in defendant' s
economic circumstances that might affect defendant's ability to pay restitution, including, but not
limited to, new or changed employment, increases in income, inheritances, monetary gifts, or any
other acquisition of assets or money.
Revised June 2023
Case 3:22-cr-00360-AN Document 42 Filed 12/11/24 Page 10 of 11
Serguel Akiti
Katryna Spearman
Re: Jamie McGowen Plea Agreement Letter
Page 10
17. Forfeiture Terms :
A. Assets and Authority: By signing this agreement, defendant knowingly and
voluntarily forfeits all right, title, and interest in and to $2,003 ,577 in the form of a money
judgment, pursuant to 18 U.S.C. § 981(a)(l)(C), 18 U.S.C. §§ 982(a)(l), 982(a)(2), and 28
U.S.C. § 2461(c), which defendant admits represents proceeds defendant personally obtained,
directly or indirectly, as a result of defendant's criminal activity set forth in Counts 1, 3, 5 and 7
of the Indictment.
B. No Alteration or Satisfaction : Defendant knowingly and voluntarily waives the
right to a jury trial on the forfeiture of assets. Defendant knowingly and voluntarily waives all
constitutional, legal, and equitable defenses to the forfeiture of this money judgment, including
any claim or defense under the Eighth Amendment to the United States Constitution, and any
rights under Rule 32.2 of the Federal Rules of Criminal Procedure. Defendant further agrees
forfeiture of defendant's assets shall not be treated as satisfaction of any fine, restitution, cost of
imprisonment, or any other penalty this Court may impose upon defendant in addition to
forfeiture. Defendant agrees that forfeiture of substitute assets as authorized pursuant to 21
U.S.C. § 853(p) shall not be deemed an alteration of defendant' s sentence.
18. Memorialization of Agreement: No promises, agreements, or conditions other than
those set forth in this agreement will be effective unless memorialized in writing and signed by
all paiiies listed below or confirmed on the record before the Court. If defendant accepts this
offer, please sign and attach the original of this letter to the Petition to Enter Plea.
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Rev ised June 2023
Case 3:22-cr-00360-AN Document 42 Filed 12/11/24 Page 11 of 11
Serguel Akiti
Katryna Spearman
Re: Jamie McGowen Plea Agreement Letter
Page 11
19. Deadline: This plea offer expires if not accepted by October 18, 2024 at 5:00 p.m.
Sincerely,
NATALIE K. WIGHT
United States Attorney
l a l ~ V .?lt, ~~
MEREDITH D.M. BATEMAN
Assistant United States Attorney
I have carefully reviewed every part of this agreement with my attorney. I understand
and voluntarily agree to its terms. I expressly waive my rights to appeal as outlined in this
agreement. I wish to plead guilty because, in fact, I am guilty.
October 20, 2024
Date Jamie McGowen
Defendant
I represent the defendant as legal counsel. I have carefully reviewed every part of this
agreement with defendant. To my knowledge, defendant's decisions to make this agreement and
to plead guilty are informed and voluntary ones. ~
October 20, 2024
- - - -- -- - - - - - - -- - -
Date Serguel Akiti
Katryna Spearman
Attorneys for Defendant
Revi sed June 2023
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