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DREAM Contract — United States v. Autumn Luna, No. CR21-189 RAJ

Summary

The Drug Reentry Alternative Model (DREAM) Contract in United States of America v. Autumn Luna, NO. CR21-189 RAJ, Document 57 in Case 2:21-cr-00189-RAJ, filed 03/17/23, in the U.S. District Court for the Western District of Washington at Seattle. The contract describes the DREAM program as a post-plea/pre-adjudication program, with a guilty plea under a written plea agreement and successful completion leading to dismissal of the charges. It addresses program basics, monthly appearances before the DREAM Judicial Officer, treatment and counseling programs, a statement of culpability, limited use of statements, and supervision violations and sanctions. The listed sanctions include community service, curfew restriction for up to 30 days, and up to 7 days in jail. The final page is headed Exhibit A.

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“DREAM Contract — United States v. Autumn Luna, No. CR21-189 RAJ.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-2-21-cr-00189-dkt-57-w-d-wash-a79e1d6d01/, SHA-256 d197ffa5bc06295dfd89a9188615fb20cbb926188f67fd5b707fafb21f96a06d.

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                Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 1 of 15




 1                                                                                           Hon. Richard A. Jones
 2
 3
 4
 5
 6
                                   UNITED STATES DISTRICT COURT
 7                                WESTERN DISTRICT OF WASHINGTON
                                            AT SEATTLE
 8
 9
         UNITED STATES OF AMERICA,                                      NO. CR21-189 RAJ
10
                                  Plaintiff
11                                                                      DRUG REENTRY ALTERNATIVE
                                                                        MODEL (DREAM) CONTRACT
12
13                           v.
         AUTUMN LUNA,
14
                                  Defendant.
15
16
17                                                INTRODUCTION

18            You have been invited by the DREAM Executive Review Team to participate in

19 the DREAM program of the Western District of Washington, at Seattle, a post-plea/pre-
20 adjudication program in which you enter a plea pursuant to the terms of a written plea
21 agreement that is held in abeyance while you complete the program. Contingent upon
                                                                       1


22 approval by the Court and your agreement to participate in the program and abide by the
23 governing terms of the program as set forth herein, you may participate in the DREAM
24 program to enable intensive treatment, sanction alternatives and incentives to effectively
25 address the substance abuse issues that appear to be contributing causes for your criminal
26
27   1
      The Executive Review team is presently comprised of the DREAM Judicial Officer, two Assistant United States
     Attorneys, two U.S. Probation Officers, an Assistant Federal Public Defender, and a representative from the
28   Criminal Justice Act panel. See Interagency Agreement, & 3.
      DREAM CONTRACT                                                                         UNITED STATES ATTORNEY
                                                                                              700 STEWART ST., SUITE 5220
      Autumn Luna, CR21-189 RAJ - 1
                                                                                               SEATTLE, WASHINGTON 98101
                                                                                                     (206) 553-7970
             Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 2 of 15




 1 conduct. Successful completion of the DREAM program leads to dismissal of the
 2 charges. If you are terminated from the program, however, a sentence will be imposed by
 3 the Court overseeing the DREAM program based on the guilty plea or pleas previously
 4 entered pursuant to the terms of the written plea agreement.
 5                                   DREAM PROGRAM BASICS
 6         Participation is entirely voluntary but mandates your commitment to at least 12
 7 months with the possibility that your required participation may be extended up to no
 8 more than 24 months. You will be assigned an attorney from the Federal Public
 9 Defenders Office or the Criminal Justice Act panel who is a member of the Executive
10 Review Team for the DREAM program. An Assistant United States Attorney, also a
11 member of the Executive Review Team, will be assigned to your case as well. Both the
12 defense attorney and the Assistant United States Attorneys will work with the DREAM
13 program’s Probation Officers to provide additional support and encouragement for your
14 hoped for success in the DREAM program.
15         The DREAM Executive Review Team, through correspondence from the DREAM
16 Probation Officer, will seek approval for a transfer of your case from the Originating
17 District Judge to the DREAM Judicial Officer. The correspondence will explain the
18 DREAM Executive Review Team’s reasons for recommending participation in the
19 DREAM program, and a brief summary of the anticipated plea agreement. If rejected,
20 the case will proceed in the usual course before the Originating District Court. If
21 approved, the Originating District Court will execute an Order transferring your case for
22 all purposes to the DREAM program Judicial Officer.
23         Thereafter the Probation Office will arrange for you to make an initial appearance
24 before the DREAM Judicial Officer. The initial hearing before the DREAM Judicial
25 Officer will be conducted in open court, in the presence of the DREAM Executive
26 Review Team and your original defense counsel. At that time, to proceed further, you
27 will be required to execute this DREAM contract, and enter a guilty plea to one or more
28 of the criminal charges against you in the case referenced above if you have not already
     DREAM CONTRACT                                                     UNITED STATES ATTORNEY
                                                                         700 STEWART ST., SUITE 5220
     Autumn Luna, CR21-189 RAJ - 2
                                                                         SEATTLE, WASHINGTON 98101
                                                                               (206) 553-7970
                Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 3 of 15




 1 done so, pursuant to the terms of a written plea agreement. 2 The Court will make a final
 2 determination whether to accept your DREAM contract, your guilty plea(s) and the plea
 3 agreement before you can begin participation in the DREAM program. Once each of
 4 these documents are executed before the DREAM Judicial Officer, and approved by the
 5 Court, you are a participant in the DREAM program.
 6            As set forth herein, by entering this agreement and the DREAM program, you
 7 agree to comply with the directives of your assigned Probation Officer consistent with
 8 your Appearance Bond and the terms of this contract including, but not limited to, an
 9 agreement to participate in a drug and alcohol evaluation and in any and all treatment and
10 testing recommended as a result of that evaluation. You also agree to drug and alcohol
11 testing for substance use issues and may also be required to participate in programs
12 designed to address underlying causes of criminal activity. Finally, you must also
13 comply with all conditions of the terms of your post-plea/pre-adjudication written plea
14 agreement.
15            If you successfully complete the DREAM program, then, as specified in the
16 written plea agreement, your guilty plea(s) will be vacated and the criminal charges
17 against you in the case referenced above will be dismissed with prejudice. If you are
18 terminated from the program, you will be sentenced by the Court overseeing the DREAM
19 program based on the guilty plea or pleas previously entered pursuant to the written plea
20 agreement. Although the DREAM Judicial Officer will appreciate and reward genuine
21 attempts to succeed in the DREAM program, the Court may impose a sentence up to and
22 including what would have been imposed if the standard plea was taken, as reflected in
23 the written plea agreement, and permitted by law, and based on all information available,
24 including your conduct in the DREAM program.
25
26
27
     2
      The written plea agreement will be the result of negotiations by your defense counsel with the government and
28   shall contain terms acceptable to the government, you, and your defense counsel.
      DREAM CONTRACT                                                                         UNITED STATES ATTORNEY
                                                                                              700 STEWART ST., SUITE 5220
      Autumn Luna, CR21-189 RAJ - 3
                                                                                               SEATTLE, WASHINGTON 98101
                                                                                                     (206) 553-7970
             Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 4 of 15




 1                            DREAM PROGRAM APPEARANCES
 2         The time spent in DREAM court is divided into stages and varies based on each
 3 participant’s circumstances and progress. However, from the outset, and at a minimum,
 4 you will be required to appear before the DREAM Judicial Officer at least once a month
 5 to evaluate your progress. The other members of the Executive Review Team will be
 6 present and treatment and/or other program providers may be present, as deemed
 7 appropriate by the Executive Review Team.
 8         Every effort will be made to ensure the time of the appearance does not conflict
 9 with your employment or treatment or other programming. Progress reports from the
10 Probation Officer will be provided to the Court and all members of the Executive Review
11 Team at least 24 hours prior to your appearance. These reports will describe both
12 successes and problems you have experienced. A copy of the report will be available to
13 you via the Assistant Federal Public Defender.
14        DREAM PROGRAM TREATMENT AND COUNSELING PROGRAMS
15         An important part of the DREAM program will be your participation in substance
16 abuse treatment and counseling programs and/or other programs addressing underlying
17 causes of criminal activity as determined necessary by the Probation Officer and the other
18 members of the DREAM Executive Review Team. Treatment and other program
19 providers will be expected to share information regarding your participation and progress
20 in any treatment and counseling programs with all the members of the DREAM
21 Executive Review Team. Treatment and other program providers may also be present at
22 DREAM court appearances, at which they will be expected to discuss your participation
23 and progress with the DREAM Judicial Officer, in the presence of all the members of the
24 DREAM Executive Review Team. To enable treatment and other program providers to
25 freely share information regarding your participation and progress in substance abuse
26 treatment and counseling programs and other programs, you will be required to execute a
27 waiver of confidentiality in the form attached as Exhibit A.
28
     DREAM CONTRACT                                                     UNITED STATES ATTORNEY
                                                                         700 STEWART ST., SUITE 5220
     Autumn Luna, CR21-189 RAJ - 4
                                                                         SEATTLE, WASHINGTON 98101
                                                                               (206) 553-7970
              Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 5 of 15




 1                 DREAM PROGRAM STATEMENT OF CULPABILITY
 2         Another important part of the DREAM program is your willingness to provide the
 3 government all information known about the offense or offenses originally charged. The
 4 DREAM program’s Assistant United States Attorney and your defense counsel will
 5 schedule the meeting after you have been approved for participation in DREAM. The
 6 DREAM program’s Assistant Federal Public Defender may also be present at the
 7 meeting. Every effort will be made to ensure the time of the requisite meeting does not
 8 conflict with your employment or treatment or other programming.
 9         The government agrees that this statement is not for law enforcement purposes but
10 rather for the sole purpose of confirming your sincere intent to achieve sobriety and
11 participate in DREAM. The fact that you may not have any relevant or other information
12 to provide or that the government is already aware of, will not preclude a determination
13 by the DREAM Executive Review Team that you have complied with this requirement.
14 Further, as noted below, the government agrees that it will not introduce any statement
15 made by you against you in its case-in-chief in any future prosecution in this case, except
16 in a prosecution for perjury or making a false statement, nor may it be used to file
17 additional charges against you or require further cooperation by you.
18                       LIMITED USE OF STATEMENTS MADE DURING
                              DREAM PROGRAM APPEARANCES
19
20         Your complete candor with the DREAM Executive Review Team and during your
21 DREAM court appearances is expected throughout your participation in the DREAM
22 program. To encourage your candor, the United States Attorney’s Office has agreed as
23 follows:
24         (A)     Except as otherwise provided in subparagraph (B) below statements made
                   and documents and other information provided by you during and/or in
25
                   relation to all DREAM program proceedings, shall not be used
26
                   (i)     against you in the government’s case-in-chief in any future
27
                           proceedings, including but not limited to determine the applicable
28                         guideline range if terminated from the DREAM program;
     DREAM CONTRACT                                                       UNITED STATES ATTORNEY
                                                                           700 STEWART ST., SUITE 5220
     Autumn Luna, CR21-189 RAJ - 5
                                                                           SEATTLE, WASHINGTON 98101
                                                                                 (206) 553-7970
              Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 6 of 15




1
                    (ii)    to file additional criminal charges against you, except as a basis for
2
                            prosecution for perjury or making a false statement;
3
                    (iii)   to compel your cooperation against others previously known or
4
                            unknown,
5                   or
6
                    (iv)    to determine the applicable sentencing guideline range if you are
7                           terminated from the DREAM program.
8
            (B)     Except as set forth in paragraph (A) above, the United States Attorney’s
9
                    Office may use
10
                    (i)     information derived directly or indirectly from DREAM program
11
                            statements for the purpose of obtaining and pursuing leads to other
12                          evidence, which evidence may be used for any purpose;
13
                    (ii)    DREAM program statements and all evidence obtained directly or
14                          indirectly from DREAM program statements to refute or counter at
                            any stage of any DREAM proceeding any evidence, argument,
15
                            statement, or representation(s) offered by you or on your behalf in
16                          connection with that proceeding; or,
17
                    (iii)   for impeachment purposes in any future proceedings including
18                          sentencing.
19
     The government’s agreements above are limited to the United States Attorney’s Office
20
     for the Western District of Washington and do not bind any other federal, state, local, or
21
     foreign prosecuting, enforcement, administrative, or regulatory authorities. Moreover,
22
     the government’s agreement in subparagraph A is limited to DREAM program
23
     statements, including statements obtained during the requisite statement of culpability,
24
     and does not apply to any statements made or documents or other information provided
25
     by you prior to your participation in DREAM or made after your termination from
26
     DREAM, whether oral, written, or recorded.
27
28
      DREAM CONTRACT                                                         UNITED STATES ATTORNEY
                                                                              700 STEWART ST., SUITE 5220
      Autumn Luna, CR21-189 RAJ - 6
                                                                              SEATTLE, WASHINGTON 98101
                                                                                    (206) 553-7970
               Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 7 of 15




 1        DREAM PROGRAM SUPERVISION VIOLATIONS AND SANCTIONS
 2         The DREAM program’s Probation Officer is charged with overseeing your
 3 supervision and monitoring your compliance with treatment. In preparation for DREAM
 4 court appearances, the DREAM Probation Officer will prepare a DREAM Progress
 5 Report for the DREAM Judicial Officer and other members of the Executive Review
 6 Team. The report will inform the Court and the parties of your conduct on supervision.
 7         The DREAM program anticipates that you may struggle during treatment and
 8 noncompliant behavior, including relapse, will result in some level of sanctions.
 9 However, sanctions imposed are intended to help you succeed in the program. Sanctions
10 may include, but are not limited to:
11         •       Additional education or writing assignments (for example, write out an
12                 explanation for noncompliant behavior and describe a plan to correct it);

13         •       Order to participate in community service as part of the DREAM program;
14
           •       Judicial reprimand delivered during DREAM court proceedings in front of
15                 other DREAM program Participants;
16
           •       Order to return to DREAM program proceedings to observe for a half or
17                 full day;
18
           •       Curfew restriction for up to 30 days;
19
20         •       Increase in frequency of progress hearings before the DREAM Judicial
                   Officer;
21
22         •       Order to complete a term of home confinement (with conditions that may
                   include alcohol monitors and standard location monitoring with GPS);
23
24         •       Order to complete a term of up to 30 days at a residential reentry center;
25
           •       Order to complete a term at a residential drug treatment facility;
26
27
28
     DREAM CONTRACT                                                       UNITED STATES ATTORNEY
                                                                           700 STEWART ST., SUITE 5220
     Autumn Luna, CR21-189 RAJ - 7
                                                                           SEATTLE, WASHINGTON 98101
                                                                                 (206) 553-7970
                   Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 8 of 15




 1             •       Order to spend up to 7 days in jail 3; and,
 2
               •       Termination from DREAM program.
 3
 4             Factors that will influence the type of sanction employed include the seriousness
 5 of the violation, the number of violations, and the amount of time you have remained
 6 compliant, either before a first violation, or between violations. In addition, an important
 7 factor will be whether you voluntarily disclose the violation. Dishonesty on your part will
 8 result in enhanced sanctions. Depending on these factors, any of the sanctions listed
 9 above, including termination from the DREAM program, will be available to the
10 DREAM Judicial Officer. Additionally, if appropriate, any or all the available sanctions
11 may be ordered more than once during a participant’s progress through the DREAM
12 program.
13             Sanctions imposed should be completed by your next DREAM court appearance
14 unless the DREAM Judicial Officer allows you more time. You may also be required to
15 report on performance of the sanction at your next DREAM court appearance.
16 Further, the DREAM Probation Officer need not wait until your scheduled court
17 appearance to address problems with supervision. If you fail to abide by directives of
18 your Probation Officer or if the Probation Officer believes that you have committed other
19 violations of your supervision, the DREAM Probation Officer has the discretion to: (1)
20 contact you directly to address the violation; (2) reach a proposed method of addressing
21 the violation through discussions with members of the Executive Review Team,
22 including the DREAM Judicial Officer; or (3) request the issuance of a warrant for your
23 arrest by the DREAM Judicial Officer.
24
25
26   3
       The 7-day limit applies only to orders for jail time and does not limit the DREAM Judicial Officer=s ability to order
     a longer period in home confinement, a residential reentry center, or a residential drug treatment facility. Nor does it
27   limit the DREAM Probation Officer=s ability to place a participant in a residential reentry center for transitional
     purposes.
28
         DREAM CONTRACT                                                                        UNITED STATES ATTORNEY
                                                                                                700 STEWART ST., SUITE 5220
         Autumn Luna, CR21-189 RAJ - 8
                                                                                                SEATTLE, WASHINGTON 98101
                                                                                                      (206) 553-7970
             Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 9 of 15




 1         When expedited action is appropriate and the parties agree on the resolution, the
 2 agreed upon sanction or adjustment in treatment can be imposed through a modification
 3 without an appearance before the DREAM Judicial Officer. The Probation Officer’s
 4 DREAM Progress Report will inform the DREAM Judicial Officer however, whether
 5 you properly completed the sanction or modification imposed. Failure to complete the
 6 ordered modification may result in additional sanctions, including, but not limited to,
 7 termination from the program.
 8         If you wish to contest the violation(s) alleged, you may do so. A request for a
 9 hearing on whether you in fact, committed the alleged conduct will not automatically
10 result in termination from the DREAM program. The only issue at the hearing, however,
11 is whether you in fact committed the alleged conduct; it is not an opportunity for you to
12 explain the conduct. The DREAM Assistant Federal Public Defender will assist you at
13 the adversarial hearing. And the DREAM Judicial Officer will ultimately decide whether
14 the allegation is true.
15         Finally, the DREAM program is a voluntary program. Therefore, when faced with
16 any sanction, you will always have the option of requesting termination from the
17 DREAM program and proceed to sentencing before the DREAM Judicial Officer.
18                    TERMINATION FROM THE DREAM PROGRAM
19         Termination from the DREAM program prior to successful completion of its
20 requirements may be voluntary or involuntary. Cause for involuntary termination from
21 the DREAM program includes, but is not limited to, the commission of new law
22 violations, repeated drug use, chronic pattern of refusal to cooperate with a treatment or
23 other program provider, repeated refusals to cooperate with the DREAM program’s
24 imposed sanctions or to participate in the DREAM program in a meaningful manner.
25 Final decisions regarding involuntary termination from DREAM will be made by the
26 DREAM Judicial Officer.
27         In either case, whether you were involuntarily or voluntarily terminated from
28 further participating in DREAM, the case will be set for sentencing before the DREAM
     DREAM CONTRACT                                                      UNITED STATES ATTORNEY
                                                                          700 STEWART ST., SUITE 5220
     Autumn Luna, CR21-189 RAJ - 9
                                                                          SEATTLE, WASHINGTON 98101
                                                                                (206) 553-7970
             Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 10 of 15




 1 Judicial Officer and you may be detained unless the DREAM Judicial Officer finds that
 2 there a condition or combination of conditions that reasonably assures your appearance
 3 for sentencing or protect the community. The DREAM Judicial Officer will not be
 4 bound to provide the benefit of dismissal with prejudice that your plea agreement would
 5 have required had you successfully completed the DREAM program. Prior to sentencing,
 6 the DREAM Judicial Officer may order the production of a Presentence Report. And at
 7 sentencing, the DREAM Judicial Officer may consider in imposing a sentence otherwise
 8 consistent with the terms of the written plea agreement, all conduct that has taken place
 9 during your participation in the DREAM program, including any failures, sanctions
10 imposed, and successes achieved.
11                                GRADUATION AND BENEFITS
12          Your successful completion of the DREAM program will be determined by the
13 DREAM Judicial Officer and the other members of the Executive Review Team.
14 Successful completion of the program is subject to the minimum requirement that you
15 demonstrated at least six months of continuous sobriety immediately prior to the
16 scheduled graduation. Upon successful completion, you will be permitted to withdraw
17 your previously entered guilty plea(s), and the criminal charges previously pending at the
18 time of your guilty plea(s) will be dismissed with prejudice.
19   //
20 //
21 //
22
   //
23
   //
24
25 //
26 //
27
     //
28
      DREAM CONTRACT                                                    UNITED STATES ATTORNEY
                                                                         700 STEWART ST., SUITE 5220
      Autumn Luna, CR21-189 RAJ - 10
                                                                         SEATTLE, WASHINGTON 98101
                                                                               (206) 553-7970
             Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 11 of 15




 1                               AGREEMENT TO PARTICIPATE
 2
     Participant:
 3
     I, AUTUMN LUNA, have read, or someone has read to me in the language I best
 4
     understand, this Contract and the plea agreement that would be a condition of my
 5   participation in the DREAM program. I have discussed this Contract and the plea
     agreement with my attorney, and I understand its terms. I have also discussed with my
 6
     attorney the DREAM program and I understand that program. I voluntarily agree to
 7   participate in the DREAM program subject to the terms set forth in this Contract and the
     plea agreement. I understand I can revoke my voluntary participation in the DREAM
 8
     program at any time and have my criminal case set for sentencing before the DREAM
 9   Judicial Officer.
10
   /s/ Autumn Luna____________                              March 17, 2023
11 AUTUMN LUNA                                              DATE
12
13
     DREAM Assistant Federal Public Defender:
14
15 I, Sean Gillespie, counsel from the Criminal Justice Act panel, representing the
   Participant in connection with the DREAM program, have discussed the DREAM
16
   program, the plea agreement that would be a condition of participation in the DREAM
17 program, and this Contract with the Participant and the Participant’s attorney in the
   underlying criminal matter. I believe that the Participant understands the DREAM
18
   program, the terms of the plea agreement that would be a condition of participation in the
19 DREAM program, and the terms of this Contract, and that the Participant's agreement to
   participate in the DREAM program subject to the terms of this Contract and the plea
20
   agreement that would be a condition of participation in the DREAM program is
21 knowingly and voluntarily made.
22
   /s/ Sean Gillespie ____________                          March 17, 2023
23 SEAN GILLESPIE                                           DATE
24 Counsel for Autumn Luna
25
26 DREAM Assistant United States Attorney:
27 I, Amy Jaquette, an Assistant United States Attorney representing the United States
28 Attorney's Office for the Western District of Washington in the DREAM program, agree
      DREAM CONTRACT                                                    UNITED STATES ATTORNEY
                                                                         700 STEWART ST., SUITE 5220
      Autumn Luna, CR21-189 RAJ - 11
                                                                         SEATTLE, WASHINGTON 98101
                                                                               (206) 553-7970
            Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 12 of 15




 1 to the terms of this Contract on behalf of the U.S. Attorney’s Office and accept the above
   named Participant into the DREAM program subject to the terms of this Contract and the
 2
   plea agreement that would be a condition of the Participant’s participation in the
 3 DREAM program.
 4
   /s/ Amy Jaquette            _____                       March 17, 2023          _____
 5 AMY JAQUETTE                                            DATE
   Assistant United States Attorney
 6
 7
     DREAM Assistant United States Attorney:
 8
 9 I, Casey S. Conzatti, an Assistant United States Attorney representing the United States
   Attorney's Office for the Western District of Washington in the DREAM program, agree
10
   to the terms of this Contract on behalf of the U.S. Attorney’s Office and accept the above
11 named Participant into the DREAM program subject to the terms of this Contract and the
   plea agreement that would be a condition of the Participant’s participation in the
12
   DREAM program.
13
   /s/ Casey S. Conzatti ___________                        March 17, 2023________
14
   CASEY S. CONZATTI                                        DATE
15 Assistant United States Attorney
16
17
     DREAM Probation Officer:
18
19 I, Jennifer Van Flandern, a Probation Officer assigned to the DREAM program, accept
   the above named Participant into the DREAM program subject to the terms of this
20
   Contract and the plea agreement that would be a condition of the Participant’s
21 participation in the DREAM program.
22
   /s/Jennifer Van Flandern ___________                    March 17, 2023_________
23 JENNIFER VAN FLANDERN                                   DATE
24 U.S. Probation and Pretrial Services Office
25
26
27
28
     DREAM CONTRACT                                                     UNITED STATES ATTORNEY
                                                                         700 STEWART ST., SUITE 5220
     Autumn Luna, CR21-189 RAJ - 12
                                                                         SEATTLE, WASHINGTON 98101
                                                                               (206) 553-7970
            Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 13 of 15




 1 DREAM Probation Officer:
 2
   I, Christina Lacy, a Probation Officer assigned to the DREAM program, accept the above
 3 named Participant into the DREAM program subject to the terms of this Contract and the
   plea agreement that would be a condition of the Participant’s participation in the
 4
   DREAM program.
 5
   /s/ Christina Lacy          ___________                 March 17, 2023__________
 6
   CHRISTINA LACY                                          DATE
 7 U.S. Probation and Pretrial Services Office
 8
 9 DREAM Judicial Officer:
10
   Subject to acceptance of the Participant’s guilty pleas and plea agreement, the Court
11 hereby accepts the above named Participant into the DREAM Program subject to the
   terms of this Contract and the plea agreement that would be a condition of the
12
   Participant’s participation in the DREAM program.
13
14
     A
   ___________________________________
15 The Honorable RICHARD A. JONES
                                                           _____________________
                                                           March 17, 2023
                                                           DATE
   U.S. District Court Judge
16
17
18
19
20
21
22
23
24
25
26
27
28
     DREAM CONTRACT                                                    UNITED STATES ATTORNEY
                                                                        700 STEWART ST., SUITE 5220
     Autumn Luna, CR21-189 RAJ - 13
                                                                        SEATTLE, WASHINGTON 98101
                                                                              (206) 553-7970
              Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 14 of 15




 1                                                 Exhibit A
 2
      AUTHORIZATION TO RELEASE CONFIDENTIAL INFORMATION TO DREAM
 3
     I, AUTUMN LUNA, the undersigned, have voluntarily agreed to participate in the
 4
     Western District of Washington’s Drug Reentry Alternative Model (DREAM) program.
 5   As part of my participation in the DREAM program, I hereby authorize any and all
     substance abuse treatment and counseling and other programs to which I may be referred
 6
     as part of the DREAM program to release confidential information in their records,
 7   possession, or knowledge, of whatever nature may now exist or come to exist, to the
     following participants in the DREAM program: (a) United States District Court for the
 8
     Western District of Washington; (b) United States Pretrial Services and Probation Office
 9   for the Western District of Washington; (c) the Federal Public Defender’s Office for the
     Western District of Washington; and (d) the United States Attorney’s Office for the
10
     Western District of Washington (collectively, the DREAM Executive Review Team).
11
          The confidential information I hereby authorize to be released to the DREAM
12
   Executive Review Team will include, without limitation: date of entrance to program;
13 attendance records; urine testing results; type, frequency, and effectiveness of therapy
   (including psychotherapy notes); general adjustment to program rules; type and dosage of
14
   medication; response to treatment; test results (psychological, vocational, etc.); date of
15 and reason for withdrawal from program; and prognosis.
16
             I understand that, subject to any exceptions to confidentiality that may apply under
17   federal or state law, the DREAM Executive Review Team may use the confidential
     information hereby authorized to be released only in connection with their evaluation of
18
     my participation and progress in the DREAM program and my compliance or non-
19   compliance with the terms of my diversion, and their evaluation of the effectiveness of
     the DREAM program as a whole. I also understand that this authorization will remain
20
     valid until my termination from the DREAM program, whether successfully or
21   unsuccessfully, at which time this authorization for disclosure of confidential information
     will expire. I understand, however, that confidential information disclosed pursuant to
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     this authorization may subsequently be used by the United States District Court for the
23   Western District of Washington and/or the United States Pretrial Services and Probation
     Office for the Western District of Washington, to initiate or support an action alleging a
24
     violation of the terms of my diversion and/or to prepare a Presentence Report, make a
25   recommendation regarding sentencing, and determine the appropriate sentence, as a result
     of which the information may no longer be deemed confidential and may no longer be
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     protected by federal or state law.
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      DREAM CONTRACT EXHIBIT A –                                          UNITED STATES ATTORNEY
                                                                           700 STEWART ST., SUITE 5220
      United States v. Autumn Luna, CR21-189 RAJ
                                                                           SEATTLE, WASHINGTON 98101
                                                                                 (206) 553-7970
              Case 2:21-cr-00189-RAJ Document 57 Filed 03/17/23 Page 15 of 15




 1           Finally, I understand that I have the right to revoke this authorization to release
     confidential information, in writing, at any time by sending written notification to the
 2
     United States Pretrial Services Officer assigned to supervise me while participating in the
 3   DREAM program. I understand that if I revoke this authorization to release confidential
     information, I will thereby revoke my authorization for further disclosure of such
 4
     information. I also understand that if I revoke this authorization to release confidential
 5   information before I complete the DREAM program, it may result in my termination
     from the DREAM program and may be considered a violation of DREAM program rules
 6
     or of a condition of my DREAM contract.
 7
           I have read this authorization to release confidential information, have discussed it
 8
     with my attorney, understand its terms, and by signing below agree to it.
 9
     s/Autumn Luna                                           March 17, 2023
10
     AUTUMN LUNA                                             DATE
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   I am the attorney representing the individual signing this authorization to release
12
   confidential information in connection with the DREAM program and have discussed the
13 terms of this authorization with this individual. I believe this individual understands the
   terms of this authorization and that this individual’s agreement to sign this authorization
14
   is knowingly and voluntarily made.
15
   s/ Sean Gillespie                                         March 17, 2023
16
   SEAN GILLESPIE                                            DATE
17 Counsel for Autumn Luna
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      DREAM CONTRACT EXHIBIT A –                                          UNITED STATES ATTORNEY
                                                                           700 STEWART ST., SUITE 5220
      United States v. Autumn Luna, CR21-189 RAJ
                                                                           SEATTLE, WASHINGTON 98101
                                                                                 (206) 553-7970


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