Plea agreement, Eric Wilhoit II — United States v. Wilhoit, II (Dkt. 91, E.D. Va.)

Summary

A plea agreement between the United States Attorney for the Eastern District of Virginia and Eric Wilhoit, II in No. 1-22-CR-191-AJT, filed 11/17/22 as Document 91. The defendant agrees to waive indictment and plead guilty to a single count criminal information charging conspiracy to commit wire and mail fraud, which carries a maximum of 20 years of imprisonment. The parties stipulate to an actual loss between $550,000 and $3,500,000, a 2-level increase for 10 or more victims and a 2-level increase for 5 or more means of identification, and agree restitution of at least $550,000. The defendant agrees to forfeit property including $195,000 in cash, firearms and jewelry seized on July 27, 2022, and waives appeal and FOIA rights.

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Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 1 of 16 PagelD# 318

IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA

Alexandria Division
UNITED STATES OF AMERICA
v. No. 1-22-CR-191-AJT
ERIC WILHOIT, I,
Defendant.
PLEA AGREEMENT

Jessica D. Aber, United States Attorney for the Eastern District of Virginia; undersigned
counsel for the United States; the defendant, Eric Wilhoit, II; and the defendant’s counsel have
entered into an agreement pursuant to Rule 11 of the Federal Rules of Criminal Procedure. The
terms of this Plea Agreement are as follows:

1. Offense and Maximum Penalties

The defendant agrees to waive indictment and plead guilty to a single count Criminal
Information, charging the defendant with Conspiracy to commit wire and mail fraud, in violation
of 18 U.S.C. 1349. The maximum penalties for this offense are: a maximum term of 20 years of
imprisonment, a fine of the greater of $250,000 or twice the gross gain or loss, full restitution,
forfeiture of assets as outlined below, a special assessment pursuant to 18 U.S.C § 3013, anda
maximum supervised release term of 3 years. The defendant understands that any supervised
release term is in addition to any prison term the defendant may receive, and that a violation of a
term of supervised release could result in the defendant being returned to prison for the full term

of supervised release.
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 2 of 16 PagelD# 319

2. Factual Basis for the Plea
The defendant will plead guilty because the defendant is in fact guilty of the charged
offense. The defendant admits the facts set forth in the Statement of Facts filed with this Plea
Agreement and agrees that those facts establish guilt of the offense charged beyond a reasonable
doubt. The Statement of Facts, which is hereby incorporated into this Plea Agreement,
constitutes a stipulation of facts for purposes of Section 1B1.2(c) of the Sentencing Guidelines.
3. Assistance and Advice of Counsel
The defendant is satisfied that the defendant’s attorney has rendered effective assistance.
The defendant understands that by entering into this Plea Agreement, defendant surrenders
certain rights as provided in this agreement. The defendant understands that the rights of
criminal defendants include the following:
a. the right to plead not guilty and to persist in that plea;
b. the right to a jury trial;

c. the right to be represented by counsel—and, if necessary, have the court
appoint counsel—at trial and at every other stage of the proceedings; and

d. the right at trial to confront and cross-examine adverse witnesses, to be
protected from compelled self-incrimination, to testify and present
evidence, and to compel the attendance of witnesses.

4, Sentencing Guidelines, Recommendations, and Roles

The defendant understands that the Court has jurisdiction and authority to impose any
sentence within the statutory maximum described above, but that the Court will determine the
defendant’s actual sentence in accordance with 18 U.S.C. § 3553(a). The defendant understands
that the Court has not yet determined a sentence and that any estimate of the advisory sentencing
range under the U.S. Sentencing Commission’s Sentencing Guidelines Manual the defendant

may have received from the defendant’s counsel, the United States, or the Probation Office, is a
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 3 of 16 PagelD# 320

prediction, not a promise, and is not binding on the United States, the Probation Office, or the
Court. Additionally, pursuant to the Supreme Court’s decision in United States v. Booker, 543
U.S. 220 (2005), the Court, after considering the factors set forth in 18 U.S.C. § 3553(a), may
impose a sentence above or below the advisory sentencing range, subject only to review by
higher courts for reasonableness. The United States makes no promise or representation
concerning what sentence the defendant will receive, and the defendant cannot withdraw a guilty
plea based upon the actual sentence.

Further, in accordance with Federal Rule of Criminal Procedure 11(c)(1)(B), the United
States and the defendant stipulate and will recommend to the Court that the following provisions
of the Sentencing Guidelines apply:

e The actual loss, to be used for the Guidelines calculation is somewhere
between $550,000 and $3,500,000, thus resulting in an increase of either +14
or +16 pursuant to § 2B1.1(b)(1)(H) or § 2B1.1(6)(1)();

e The offense involved 10 or more victim resulting an increase of 2 levels
pursuant § 2B1.1(b)(2)(A)(i);

e The offense involved the possession of 5 or more means of identification that
unlawfully were produced from, or obtained by the use of, another means of

identification, resulting in an increase of 2 levels pursuant to
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 4 of 16 PagelD# 321

The United States and the defendant agree that the United States will not seek the
application of following Sentencing Guideline section, but the underlying facts may be used as
part of the government’s arguments regarding the sentencing factors under Section 3553(a):

e Possession of a dangerous weapon in connection with offense pursuant to
§2B1.1(16)(B).

The United States and the defendant do not have any agreements as to the application of
the following Sentencing Guideline sections:

e Role in the offense pursuant to §3B1.1 and §3B1.2.

e The defendant recklessly created a substantial risk of death or serious bodily
injury to another person in the course of fleeing from a law enforcement officer,
resulting in an increase of 2 levels pursuant to § 3C1.2.

The United States and the defendant further agree that the defendant has assisted the
government in the investigation and prosecution of the defendant’s own misconduct by timely
notifying authorities of the defendant’s intention to enter a plea of guilty, thereby permitting the
government to avoid preparing for trial and permitting the government and the Court to allocate
their resources efficiently. If the defendant qualifies for a two-level decrease in offense level
pursuant to U.S.S.G. § 3E1.1(a) and the offense level prior to the operation of that section is a
level 16 or greater, the government agrees to file, pursuant to U.S.S.G. § 3E1.1(b), a motion prior
to, or at the time of, sentencing for an additional one-level decrease in the defendant’s offense
level.

The United States and the defendant have not agreed on any further sentencing issues,
whether related to the Sentencing Guidelines or the factors listed in 18 U.S.C. § 3553(a), other

than those set forth above or elsewhere in this Plea Agreement. As such, the government may
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 5 of 16 PagelD# 322

argue for other enhancements pursuant to the Sentencing Guidelines. Any stipulation on a
Guidelines provision does not limit the parties’ arguments as to any other Guidelines provisions
or sentencing factors under Section 3553(a), including arguments for a sentence within or outside
the advisory Guidelines range found by the Court at sentencing.

5. Other Items

At the request of the defendant, after the plea has been entered by the Court, the United
States will contact the Virginia Commonwealth Attorney’s Office who is prosecuting the
defendant for his flight from law enforcement on August 6, 2022. The United States will provide
the publicly filed Plea Agreement and Statement of Facts, noting that the United States is seeking
an enhancement for the flight from law enforcement. The United States will not give an opinion,
apply pressure, or assert any position as to how the Commonwealth Attorney’s Office should
handle their case.

At the request of the defendant, after the plea has been entered by the Court, the United
States will contact the Charles County Maryland State Attorney’s Office who is prosecuting the
defendant for his possession of the Way2Go cards found on or about June 8, 2022. The United
States will provide the publicly filed Plea Agreement and Statement of Facts, noting that the
United States is seeking an enhancement for the possession of the Way2Go cards. The United
States will not give an opinion, apply pressure, or assert any position as to how the Charles
County Maryland State Attorney’s Office should handle their case.

6. Waiver of Appeal, FOIA, and Privacy Act Rights

The defendant also understands that 18 U.S.C. § 3742 affords a defendant the right to
appeal the sentence imposed. Nonetheless, the defendant knowingly waives the right to appeal

the conviction and any sentence within the statutory maximum described above (or the manner in
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 6 of 16 PagelD# 323

which that sentence was determined) on the grounds set forth in 18 U.S.C. § 3742 or on any
ground whatsoever other than an ineffective assistance of counsel claim that is cognizable on
direct appeal, in exchange for the concessions made by the United States in this Plea Agreement.
This agreement does not affect the rights or obligations of the United States as set forth in 18
U.S.C. § 3742(b). The defendant also hereby waives all rights, whether asserted directly or by a
representative, to request or receive from any department or agency of the United States any
records pertaining to the investigation or prosecution of this case, including without limitation
any records that may be sought under the Freedom of Information Act, 5 U.S.C. § 552, or the
Privacy Act, 5 U.S.C. § 552a.

7. Immunity from Further Prosecution in This District

The United States will not further criminally prosecute the defendant in the Eastern
District of Virginia for the specific conduct described in the Information or Statement of Facts.
This Plea Agreement and Statement of Facts does not confer on the defendant any immunity
from prosecution by any state government in the United States.

8. Payment of Monetary Penalties

The defendant understands and agrees that, pursuant to 18 U.S.C. § 3613 and 18 U.S.C.
§ 3572, all monetary penalties imposed by the Court, including restitution, will be due
immediately and subject to immediate enforcement by the United States as provided for in
Section 3613. If the Court imposes a schedule of payments, the defendant understands that the
schedule of payments is merely a minimum schedule of payments and not the only method, nor a
limitation on the methods, available to the United States to enforce the judgment. Until all
monetary penalties are paid in full, the defendant will be referred to the Treasury Offset Program

so that any federal payment or transfer of returned property to the defendant will be offset and
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 7 of 16 PagelD# 324

applied to pay the defendant’s unpaid monetary penalties. If the defendant is incarcerated, the
defendant agrees to participate voluntarily in the Bureau of Prisons’ Inmate Financial
Responsibility Program, regardless of whether the Court specifically directs participation or
imposes a schedule of payments. Defendant agrees to make good-faith efforts toward payment
of all monetary penalties imposed by the Court.

9, Special Assessment

Before sentencing in this case, the defendant agrees to pay a mandatory special
assessment of $100 per felony count of conviction, pursuant to 18 U.S.C. § 3013(a)(2)(A).

The defendant agrees that restitution is mandatory pursuant to 18 U.S.C. § 3663A(c)(1),
and the defendant agrees to the entry of a Restitution Order for the full amount of the victims’
losses as determined by the Court. Pursuant to 18 U.S.C. § 3663A(c)(2), the defendant further
agrees that an offense listed in Section 3663A(c)(1) gave rise to this Plea Agreement and, as
such, victims of the conduct described in the charging instrument, Statement of Facts, or any
related or similar conduct shall be entitled to restitution. Without limiting the amount of
restitution that the Court must impose, the parties agree that, at a minimum, the following

victims have suffered the losses identified below and are entitled to restitution:

Victim Name and Address Restitution Amount

To Be Determined At least $550,000

The defendant understands that forfeiture and restitution are separate and distinct
financial obligations that must be imposed upon a criminal defendant. The defendant further
understands that restitution will be enforced pursuant to 18 U.S.C. § 3572, 18 U.S.C. § 3613, and

18 U.S.C. § 3664(m).
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 8 of 16 PagelD# 325

The parties acknowledge that determination of the identities, addresses, and loss amounts
for all victims in this matter is a complicated and time-consuming process. To that end,
defendant agrees that, pursuant to 18 U.S.C. § 3664(d)(5), the Court may defer the imposition of
restitution until after the sentencing; however, defendant specifically waives the 90-day
provision found at Section 3664(d)(5) and consents to the entry of any orders pertaining to
restitution after sentencing without limitation.

11. ~—‘ Forfeiture Agreement

The defendant understands that the forfeiture of assets is part of the sentence that must be
imposed in this case. The defendant agrees to forfeit all interests in any fraud-related asset that
the defendant owns or over which the defendant exercises control, directly or indirectly. This
includes any property that is traceable to, derived from, fungible with, or a substitute for the
following: property that constitutes the proceeds of the offense and property used in or involved
in the offense. The defendant agrees that the assets subject to forfeiture include, but are not
limited to, the following specific property:

Items seized from Wilderness Lane on July 27, 2022

a. Kay Jewelry Engagement Ring

b. A pendant that says “Rondo” along with the number “6”
c. One CD Defense Honcho shotgun

d. Five shot gun shells in Honsho Shotgun

e. Twenty two 20 gauge shotgun shells and box

f. Glock 43X serial number BUDH059

g. Ammunition and Glock pistol magazine with 21 rounds, 22 rounds in box,
gun lock

h. 8 rounds 9mm and magazine for Glock 43X

i. One 9mm bullet
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 9 of 16 PagelD# 326

m.

11 rounds of 9mm ammo
10 rounds of 40 S&W ammo in box
50 round 9mm drum

36 rounds of .40 caliber ammunition

Seized from Eric Wilhoit on August 17, 2022

Nn.

One silver chain with one NLMB pendant.

Items seized from Olive Court on July 27, 2022

aa.
bb.
ce.

dd.

$195,000 in cash

Windham Weaponry Model WW-15 Multi Cal. S/N YE016142
Fabrica de Armas Oviedo 1922 S/N E9909

30-30 Winchester Repeating S/N 3500933

Winchester Bolt Model 67-22 Short S/N None

One Glock Magazine for .357 with Approximately 9 Rounds
Glock .357 S/N WRY404

One Glock 357 Magazine With Approximately 9 Rounds And | Round
From Chamber

American Tactical Omni Hybrid Multi Cal S/N NS071548
Glock 19 Gen 5 BSKP786
9mm Glock Magazine with Hollow Point Ammunition

Shotgun Sears Model 200 12-GA No. 273.2251 (9/14/2022 - SN -
P124593)

Six 12-GA Shotgun Shells
Glock Magazine with 9mm Ammunition
Hammerli Cal .357 Special Stahl S/N C2226

Revolver Rohm GMBA Southern Br, Cal .32 S&W Long S/N None
(9/14/2022 - SN - 42824)
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 10 of 16 PagelD# 327

ee. 9mm, .40, .380, .273 Ammunition
ff. Springfield Armory SA-XD BA338444
gg. Extended Magazine 9mm (black), Silver .40 XD-9 Magazine

In agreeing to forfeit the above assets, the defendant agrees to forfeit any interest he has
in the above assets to the United States. The defendant understands that any third party interests
in the above assets, such as those at Olive Court, will not be resolved at the time of the entry of
the consent or preliminary order of forfeiture, rather those issues must be deferred to the
ancillary proceeding pursuant to Fed. R. Crim. P. 32.2(b)(2)(A) and (c), as well as 21 U.S.C. §
853(n). As such, others who have an interest in those assets will be able to make any appropriate
claims.

The defendant understands that if the assets subject to forfeiture are not available to the
United States to be forfeited, the Court must enter a forfeiture money judgment in the amount of
the unavailable assets. United States v. Blackman, 746 F.3d 137 (4th Cir. 2014). The defendant
acknowledges that as a result of defendant’s acts or omissions, the actual proceeds the defendant
obtained as a result of the offense are not available and the defendant stipulates that one or more
of the factors listed at 21 U.S.C. § 853(p)(1) are present in this case.

The defendant further agrees to waive all interest in the asset(s) in any administrative or
judicial forfeiture proceeding, whether criminal or civil, state or federal. The defendant agrees to
consent to the entry of orders of forfeiture for such property and waives the requirements of
Federal Rules of Criminal Procedure 32.2 and 43(a) regarding notice of the forfeiture in the
charging instrument, announcement of the forfeiture at sentencing, and incorporation of the
forfeiture in the judgment. Defendant admits and agrees that the conduct described in the
charging instrument and Statement of Facts provides a sufficient factual and statutory basis for

the forfeiture of the property sought by the government.

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Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 11 of 16 PagelD# 328

12. Waiver of Further Review of Forfeiture

The defendant further agrees to waive all constitutional and statutory challenges to
forfeiture in any manner (including direct appeal, habeas corpus, or any other means) to any
forfeiture carried out in accordance with this Plea Agreement on any grounds, including that the
forfeiture constitutes an excessive fine or punishment. The defendant also waives any failure by
the Court to advise the defendant of any applicable forfeiture at the time the guilty plea is
accepted as required by Rule 11(b)(1)(J). The 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. The defendant understands and agrees that all
property covered by this agreement is subject to forfeiture as proceeds of illegal conduct,
property used or involved in the offense, and substitute assets for property otherwise subject to
forfeiture.

13. The Defendant’s Obligations Regarding Assets and Financial Investigation

The defendant agrees to fully participate in the United States’ pre- and post-judgment
financial investigation. Such participation includes the identification of assets in which the
defendant has any legal or equitable interest to determine what assets may be available for
payment to restitution, forfeiture, and/or any fine imposed in this case. The defendant agrees that
the defendant’s financial information is subject to investigation and disclosure pre-judgment to
the same extent as financial information will be subject to discovery after judgment is imposed.
The defendant understands that 31 U.S.C. § 3711(h)(1) permits the United States to obtain the
defendant’s credit report after sentencing and expressly authorizes the United States to obtain the
defendant’s credit report prior to sentencing in this case. The defendant understands that the

United States has sole discretion over whether it will obtain defendant’s credit report pursuant to

11
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22. Page 12 of 16 PagelD# 329

this Plea Agreement. If the United States determines that it will obtain defendant’s credit report
prior to sentencing pursuant to this Plea Agreement, the defendant authorizes the United States,
and the United States agrees, to provide a copy to defense counsel upon request. The defendant
understands that failure to participate in the financial investigation as described in this paragraph
may constitute the defendant’s failure to accept responsibility under U.S.S.G § 3E1.1.

Within 14 days of a request by the United States, or other deadline agreed upon by the
parties, the defendant agrees to provide all information about all of the defendant’s assets and
financial interests to the United States and the Probation Office and, if requested, submit to a
debtor’s examination, complete a financial disclosure statement under penalty of perjury, and/or
undergo any polygraph examination the United States may choose to administer concerning such
assets and financial interests. The defendant also agrees to provide or consent to the release of
the defendant’s tax returns for the previous five years. The defendant understands that assets and
financial interests subject to disclosure include assets owned or held directly or indirectly,
individually or jointly, in which the defendant has any legal interests, regardless of title,
including any interest held or owned under any other name, trusts, and/or business entities
presently and since date of the first offense giving rise to this Plea Agreement, or giving rise to
the charges presently pending against the defendant, whichever is earlier.

The defendant shall identify all assets valued at more than $5,000 that have been
transferred to third parties since the date of the first offense giving rise to this Plea Agreement,
including the location of the assets and the identities of third parties to whom they were
transferred. The defendant agrees not to transfer any assets valued at more than $5,000 without
approval of the Asset Recovery Unit of the U.S. Attorney’s Office until the fine, forfeiture, and

restitution ordered by the Court at sentencing are paid in full or otherwise terminated by

12
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 13 of 16 PagelD# 330

operation of law. The defendant agrees to take all steps requested by the United States to obtain
from any other parties by any lawful means any records of assets contemplated by this paragraph
in which the defendant has or had an interest. Until the fine, forfeiture, and restitution ordered
by the Court are paid in full or otherwise terminated by operation of law, the defendant agrees to
notify the Asset Recovery Unit of the U.S. Attorney’s Office of a change in address within 30
days of such change.

The United States will not use any truthful and complete information provided by the
defendant pursuant to this paragraph for additional criminal offenses against the defendant in the
Eastern District of Virginia, except in any prosecution for a crime of violence or conspiracy to
commit, or aiding and abetting, a crime of violence (as defined in 18 U.S.C. § 16). Pursuant to
U.S.S.G. § 1B1.8, no truthful information that the defendant provides pursuant to defendant’s
obligations under this paragraph will be used in determining the applicable guideline range,
except as provided in Section 1B1.8(b). Nothing in this agreement, however, restricts the
Court’s or Probation Officer’s access to information and records in the possession of the United
States. Furthermore, nothing in this agreement prevents the United States in any way from
prosecuting the defendant should the defendant knowingly provide false, untruthful, or
perjurious information or testimony, or from using information provided by the defendant in
furtherance of any forfeiture action or restitution enforcement action, whether criminal or civil,
administrative or judicial.

14. _ Breach of the Plea Agreement and Remedies

This Plea Agreement is effective when signed by the defendant, the defendant’s attorney,
and an attorney for the United States. The defendant agrees to entry of this Plea Agreement at

the date and time scheduled with the Court by the United States (in consultation with the

13
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 14 of 16 PagelD# 331

defendant’s attorney). If the defendant withdraws from this agreement, or commits or attempts
to commit any additional federal, state, or local crimes, or intentionally gives materially false,
incomplete, or misleading testimony or information, or otherwise violates any provision of this
agreement, then:

a. The United States will be released from its obligations under this
agreement. The defendant, however, may not withdraw the guilty plea
entered pursuant to this agreement.

b. The defendant will be subject to prosecution for any federal criminal
violation, including, but not limited to, perjury and obstruction of justice,
that is not time-barred by the applicable statute of limitations on the date
this agreement is signed. Notwithstanding the subsequent expiration of
the statute of limitations, in any such prosecution, the defendant agrees to
waive any statute-of-limitations defense.

c. Any prosecution, including the prosecution that is the subject of this
agreement, may be premised upon any information provided, or
statements made, by the defendant, and all such information, statements,
and leads derived therefrom may be used against the defendant. The
defendant waives any right to claim that statements made before or after
the date of this agreement, including the Statement of Facts accompanying
this agreement or adopted by the defendant and any other statements made
pursuant to this or any other agreement with the United States, should be
excluded or suppressed under Fed. R. Evid. 410, Fed. R. Crim. P. 11(f),
the Sentencing Guidelines, or any other provision of the Constitution or
federal law.

Any alleged breach of this agreement by either party shall be determined by the Court in
an appropriate proceeding at which the defendant’s disclosures and documentary evidence shall
be admissible and at which the moving party shall be required to establish a breach of this Plea
Agreement by a preponderance of the evidence.

15. Nature of the Agreement and Modifications

This written agreement constitutes the complete plea agreement between the United
States, the defendant, and the defendant’s counsel. The defendant and the defendant’s attorney

acknowledge that no threats, promises, or representations have been made, nor agreements

14
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 15 of 16 PagelD# 332

reached, other than those set forth in writing in this Plea Agreement or any associated documents
filed with the Court, to cause the defendant to plead guilty. Any modification of this Plea

Agreement shall be valid only as set forth in writing in a supplemental or revised plea agreement

signed by all parties.

Jessica D. Aber

United States Attorney

Kimberly M. Shartar
Christopher J. Hood
Assistant United States Attorneys

15
Case 1:22-cr-00191-AJT Document 91 Filed 11/17/22 Page 16 of 16 PagelD# 333

Defendant’s Signature: I hereby agree that I have consulted with my attorney and fully
understand all rights with respect to the pending criminal Information. Further, I fully
understand all rights with respect to 18 U.S.C. § 3553 and the provisions of the Sentencing
Guidelines Manual that may apply in my case. I have read this Plea Agreement and carefully
reviewed every part of it with my attorney. I understand this agreement and voluntarily agree to
it.

Date: 10 Liglae

Eric Wilhoit, II /

Defense Counsel’s Signature: I am counsel for the defendant in this case. I have fully
explained to the defendant the defendant’s rights with respect to the pending Information.
Further, I have reviewed 18 U.S.C. § 3553 and the Sentencing Guidelines Manual, and I have
fully explained to the defendant the provisions that may apply in this case. I have carefully
reviewed every part of this Plea Agreement with the defendant. To my knowledge, the
defendant’s decision to enter into this agreement is an informed and voluntary one.

Bruce J6hnson
Counsel for the Defendant

16


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