United States v. Stephen Glover — Plea Agreement, Central District of California (Document 37)

Summary

The plea agreement between Stephen Glover and the United States Attorney's Office for the Central District of California in United States v. Stephen Glover, No. 2:22-cr-00260-PA, filed June 21, 2022 as Document 37. Glover agrees to plead guilty to a two-count information charging mail fraud under 18 U.S.C. § 1341 and theft of mail matter by an officer or employee under 18 U.S.C. § 1709, and to make a $1,000 prejudgment payment. The agreement sets a total statutory maximum of 25 years' imprisonment and puts restitution at approximately $151,698. In the factual basis Glover admits that, as a USPS mail carrier in Valencia, California, from August 2020 through June 2021, Glover joined a scheme to defraud the California Employment Development Department of COVID-related unemployment funds. The USAO agrees not to prosecute further under 18 U.S.C. § 1028A for that conduct.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

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ase 2:22-cr-00260-PA Document37 _ Filed 06/21/22 Page1of20 Page ID #:133

FILED
CLERK, U.S. DISTRICT COURT

TRACY L. WILKISON 6/21/2022
United States Attorney CENTRAL DISTRICT OF CALIFORNIA
BENJAMIN R. BARRON By: d_—_éDEPUTY
Assistant United States Attorney
Chief, Santa Ana Branch Office
CHARLES E. PELL (Cal. Bar No. 210309)
Assistant United States Attorney
Santa Ana Branch Office
Ronald Reagan Fed. Bldg. and U.S. Courthouse
411 West Fourth Street, Suite 8000
Santa Ana, California 92701
Telephone: (714) 338-3542
Facsimile: (714) 338-3561
E-mail: charles.e.pell2@usdoj.gov
Attorneys for Plaintiff
UNITED STATES OF AMERICA
UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, No. 2:22-cr-00260-PA
Plaintiff, PLEA AGREEMENT FOR DEFENDANT
STEPHEN GLOVER
Vv.
STEPHEN GLOVER,
Defendant.
1. This constitutes the plea agreement between STEPHEN GLOVER

(“defendant”) and the United States Attorney’s Office for the Central
District of California (the “USAO”) in the investigation of stolen
mail and EDD fraud. This agreement is limited to the USAO and cannot
bind any other federal, state, local, or foreign prosecuting,
enforcement, administrative, or regulatory authorities.

Qe Defendant agrees to:
a. Give up the right to indictment by a grand jury and,
at the earliest opportunity requested by the USAO and provided by the

Court, appear and plead guilty to a two-count information in the form
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Case 2:22-cr-00260-PA Document37 Filed 06/21/22 Page2of20 Page ID #:134

attached to this agreement as Exhibit A or a substantially similar
form, which charges defendant with mail fraud in violation of 18
U.S.C. § 1341 (count one) and theft of mail matter by officer or
employee in violation of 18 U.S.C. § 1709 (count two).

b. Not contest facts agreed to in this agreement.

fe Abide by all agreements regarding sentencing contained
in this agreement.

foun Appear for all court appearances, surrender as ordered
for service of sentence, obey all conditions of any bond, and obey
any other ongoing court order in this matter.

e. Not commit any crime; however, offenses that would be
excluded for sentencing purposes under United States Sentencing
Guidelines (“U.S.S.G.” or “Sentencing Guidelines”) § 4A1.2(c) are not
within the scope of this agreement.

f. Be truthful at all times with the United States
Probation and Pretrial Services Office and the Court.

g. Pay the applicable special assessments at or before
the time of sentencing unless defendant has demonstrated a lack of
ability to pay such assessments.

h. At or before the time of sentencing, make a
prejudgment payment by delivering a certified check or money order to
the Fiscal Clerk of the Court in the amount of $1,000 to be applied
to satisfy defendant’s anticipated criminal debt. Payments may be
made to the Clerk, United States District Court, Fiscal Department,
255 East Temple Street, Room 1178, Los Angeles, California 90012.

ill_ Defendant agrees that any and all criminal debt
ordered by the Court will be due in full and immediately. The
government is not precluded from pursuing, in excess of any payment

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Case 2:22-cr-00260-PA Document37 Filed 06/21/22 Page3of20 Page ID #:135

schedule set by the Court, any and all available remedies by which to
satisfy defendant’s payment of the full financial obligation,
including referral to the Treasury Offset Program.

5. Complete the Financial Disclosure Statement on a form
provided by the USAO and, within 30 days of defendant’s entry of a
guilty plea, deliver the signed and dated statement, along with all
of the documents requested therein, to the USAO by either email at

usacac.FinLit@usdoj.gov (preferred) or mail to the USAO Financial

Litigation Section at 300 North Los Angeles Street, Suite 7516, Los
Angeles, CA 90012. Defendant agrees that defendant’s ability to pay
criminal debt shall be assessed based on the completed Financial
Disclosure Statement and all required supporting documents, as well
as other relevant information relating to ability to pay.

k, Authorize the USAO to obtain a credit report upon
returning a signed copy of this plea agreement.

1. Consent to the USAO inspecting and copying all of
defendant’s financial documents and financial information held by the
United States Probation and Pretrial Services Office.

THE USAO’S OBLIGATIONS

3. The USAO agrees to:
a. Not contest facts agreed to in this agreement.
br Abide by all agreements regarding sentencing contained

in this agreement.

om At the time of sentencing, provided that defendant
demonstrates an acceptance of responsibility for the offenses up to
and including the time of sentencing, recommend a two-level reduction
in the applicable Sentencing Guidelines offense level, pursuant to
U.S.S.G. § 3B1.1, and recommend and, if necessary, move for an

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additional one-level reduction if available under that section.
d. Recommend that defendant be sentenced to a term of
imprisonment no higher than the low end of the applicable Sentencing

Guidelines range, provided that the offense level used by the Court

to determine that range is 22 or higher and provided that the Court
does not depart downward in offense level or criminal history
category. For purposes of this agreement, the low end of the
Sentencing Guidelines range is that defined by the Sentencing Table
in U.S.S.G. Chapter 5, Part A, without regard to reductions in the
term of imprisonment that may be permissible through the substitution
of community confinement or home detention as a result of the offense
level falling within Zone B or Zone C of the Sentencing Table.

e. Except for criminal tax violations (including
conspiracy to commit such violations chargeable under 18 U.S.C.
§ 371), not further criminally prosecute defendant for violations of
18 U.S.C. § 1028A (aggravated identity theft) arising out of
defendant’s conduct described in the agreed-to factual basis set
forth in paragraph 13 below. Defendant understands that the USAO is
free to criminally prosecute defendant for any other unlawful past
conduct or any unlawful conduct that occurs after the date of this

agreement. Defendant agrees that at the time of sentencing the Court

may consider the uncharged conduct in determining the applicable
Sentencing Guidelines range, the propriety and extent of any
departure from that range, and the sentence to be imposed after
consideration of the Sentencing Guidelines and all other relevant
factors under 18 U.S.C. § 3553(a).

NATURE OF THE OFFENSES

4, Defendant understands that for defendant to be guilty of

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Case 2:22-cr-00260-PA Document 37 Filed 06/21/22 Page5of20 Page ID #:137

the crime charged in count one of the information, that is, mail
fraud, in violation of Title 18, United States Code, Section 1341,
the following must be true: (1) defendant knowingly participated in a
scheme or plan to defraud, or a scheme or plan for obtaining money or
property by means of false or fraudulent pretenses, representations,
or promises; (2) 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; (3) defendant acted with the intent to defraud;
that is, the intent to deceive and cheat; and (4) defendant used, or
caused to be used, the mails to carry out or attempt to carry out an
essential part of the scheme.

5. Defendant understands that for defendant to be guilty of
the crime charged in count two of the information, that is, theft of
mail matter by officer or employee, in violation of Title 18, United
States Code, Section 1709, the following must be true: (1) while
working as a Postal Service employee, defendant came into possession

of the letter; (2) the letter was intended to be conveyed by mail;

and (3) defendant embezzled the letter.

PENALTIES AND RESTITUTION

6. Defendant understands that the statutory maximum sentence
that the Court can impose for a violation of Title 18, United States
Code, Section 1341, is: 20 years’ imprisonment; a three-year period
of supervised release; a fine of $250,000 or twice the gross gain or
gross loss resulting from the offense, whichever is greatest; and a
mandatory special assessment of $100.

Ve Defendant understands that the statutory maximum sentence
that the Court can impose for a violation of Title 18, United States

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Code, Section 1709, is: 5 years’ imprisonment; a three-year period of
supervised release; a fine of $250,000 or twice the gross gain or
gross loss resulting from the offense, whichever is greatest; and a
mandatory special assessment of $100.

8. Defendant understands, therefore, that the total maximum
sentence for all offenses to which defendant is pleading guilty is:
25 years’ imprisonment; a three-year period of supervised release; a
fine of $500,000 or twice the gross gain or gross loss resulting from
the offenses, whichever is greatest; and a mandatory special
assessment of $200.

9, Defendant understands that defendant will be required to
pay full restitution to the victim(s) of the offenses to which
defendant is pleading guilty. Defendant agrees that, in return for
the USAO’s compliance with its obligations under this agreement, the
Court may order restitution to persons other than the victim(s) of
the offenses to which defendant is pleading guilty and in amounts
greater than those alleged in the counts to which defendant is
pleading guilty. In particular, defendant agrees that the Court may
order restitution to any victim of any of the following for any

losses suffered by that victim as a result: any relevant conduct, as

defined in U.S.S.G. § 1B1.3, in connection with the offenses to which
defendant is pleading guilty. The parties currently believe that the
applicable amount of restitution is approximately $151,698, but

recognize and agree that this amount could change based on facts that

come to the attention of the parties prior to sentencing.

10. Defendant understands that supervised release is a period
of time following imprisonment during which defendant will be subject
to various restrictions and requirements. Defendant understands that

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Case 2:22-cr-00260-PA Document 37 Filed 06/21/22 Page 7of20 Page ID #:139

if defendant violates one or more of the conditions of any supervised
release imposed, defendant may be returned to prison for all or part
of the term of supervised release authorized by statute for the
offense that resulted in the term of supervised release, which could
result in defendant serving a total term of imprisonment greater than
the statutory maximum stated above.

11. Defendant understands that, by pleading guilty, defendant
may be giving up valuable government benefits and valuable civic
rights, such as the right to vote, the right to possess a firearm,
the right to hold office, and the right to serve on a jury. Defendant
understands that he is pleading guilty to a felony and that it is a
federal crime for a convicted felon to possess a firearm or
ammunition. Defendant understands that the convictions in this case
may also subject defendant to various other collateral consequences,
including but not limited to revocation of probation, parole, or
supervised release in another case and suspension or revocation of a
professional license. Defendant understands that unanticipated
collateral consequences will not serve as grounds to withdraw
defendant’s guilty pleas.

12. Defendant and his counsel have discussed the fact that, and
defendant understands that, if defendant is not a United States
citizen, the convictions in this case makes it practically inevitable
and a virtual certainty that defendant will be removed or deported
from the United States. Defendant may also be denied United States
citizenship and admission to the United States in the future.
Defendant understands that while there may be arguments that
defendant can raise in immigration proceedings to avoid or delay
removal, removal is presumptively mandatory and a virtual certainty

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in this case. Defendant further understands that removal and
immigration consequences are the subject of a separate proceeding and
that no one, including his attorney or the Court, can predict to an
absolute certainty the effect of his convictions on his immigration
status. Defendant nevertheless affirms that he wants to plead guilty
regardless of any immigration consequences that his pleas may entail,
even if the consequence is automatic removal from the United States.

FACTUAL BASIS

13. Defendant admits that defendant is, in fact, guilty of the
offenses to which defendant is agreeing to plead guilty. Defendant
and the USAO agree to the statement of facts provided below and agree
that this statement of facts is sufficient to support pleas of guilty
to the charges described in this agreement and to establish the
Sentencing Guidelines factors set forth in paragraph 15 below but is
not meant to be a complete recitation of all facts relevant to the
underlying criminal conduct or all facts known to either party that
relate to that conduct.

At all times relevant to this plea agreement, defendant was
employed as a mail carrier for the United States Postal Service
(USPS) at the U.S. Post Office in Valencia, California. Starting in
August 2020 and continuing through June 2021, within the Central
District of California, defendant knowingly participated in a scheme
to defraud the California Employment Development Department (EDD) of
hundreds of thousands of dollars of COVID-related unemployment funds.
While participating in the scheme, defendant acted with the intent to
defraud; that is, the intent to deceive and cheat.

In the fraudulent scheme, defendant’s co-schemers would apply
for unemployment benefits from California EDD using false statements

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Case 2:22-cr-00260-PA Document 37 Filed 06/21/22 Page9of20 Page ID #:141

to qualify, and sometimes using stolen identities. The U.S. mails
were used to carry out the fraudulent scheme. Specifically, based
upon the fraudulent applications for EDD benefits, California EDD
would mail out debit cards and other correspondence to the addresses
listed on the applications. On or about June 15, 2021, EDD mailed a
debit card in the name of victim R.M. to an address in Valencia,
California. While working as a USPS mail carrier, defendant stole
that EDD mail from his mail route. During the search of defendant’s
residence in June 2021, agents found that EDD mail with debit card in
R.M.’s name, as well as two other debit cards in the names of S.M.
and K.Br. During the search of defendant’s girlfriend’s residence on
that same day, agents found approximately 37 pieces of mail from EDD
addressed to approximately 15 different names.

Defendant abused his position as a USPS mail carrier to further
the mail fraud scheme. Specifically, defendant would provide
addresses on his mail route to co-schemers, which the co-schemers
would then use as the mailing address on the fraudulent applications
for unemployment benefits filed with the California EDD. After
California EDD mailed out debit cards or other correspondence to the
addresses listed on those applications, defendant would then
intercept and steal that mail. Defendant and co-schemers would then
use those EDD debit cards in other people’s names.

When interviewed by law enforcement, defendant admitted to using
EDD debit cards in other people’s names to withdraw thousands of
dollars in cash from ATMs. Defendant also admitted that he would
sometimes activate the EDD debit cards in other people’s names by
calling EDD and using PINs he had discovered from stolen EDD mail.

Defendant also stole mail unrelated to California EDD, including

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more than 10 personal and business checks payable to others, which
totaled to approximately $23,266.15.

The parties agree that for purposes of this plea agreement, the
intended loss applicable to defendant’s participation in the mail
fraud scheme is $270,698, the intended loss from the stolen non-EDD
related checks is approximately $23,266, and the number of pieces of
mail that defendant stole is approximately 40.

SENTENCING FACTORS

14. Defendant understands that in determining defendant’s
sentence the Court is required to calculate the applicable Sentencing
Guidelines range and to consider that range, possible departures
under the Sentencing Guidelines, and the other sentencing factors set
forth in 18 U.S.C. § 3553(a). Defendant understands that the
Sentencing Guidelines are advisory only, that defendant cannot have
any expectation of receiving a sentence within the calculated
Sentencing Guidelines range, and that after considering the
Sentencing Guidelines and the other § 3553(a) factors, the Court will
be free to exercise its discretion to impose any sentence it finds
appropriate up to the maximum set by statute for the crimes of
conviction.

15. Defendant and the USAO agree to the following applicable
Sentencing Guidelines factors:

Count one (mail fraud)

Base Offense Level: 7 U.S.S.G. § 2Bl.1(a) (1)
$250k < loss < $550k: +12 U.S.S.G. § 2B1.1(b) (1) (G)
> 10 victims: +2 U.S.S.G. § 2Bl1.1(b) (2) (A)
Possess >5 means of ID: +2 U.S.S.G. § 2Bl1.1(b) (11) (C)
Abuse of position of trust +2 U.S.S.G. § 3B1.3

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Count two (mail theft)

Base Offense Level: 6 U.S.S.G. § 2Bl.1(a) (2)
$250k < loss < $550k: +12 U.S.S.G. § 2B1.1(b) (1) (G)
> 10 victims: +2 U.S.S.G. § 2Bl.1(b) (2) (A)
Possess >5 means of ID: +2 U.S.S.G. § 2B1.1(b) (11) (C)
Abuse of position of trust +2 U.S.S.G. § 3B1.3

The USAO will agree to a two-level downward adjustment for acceptance
of responsibility (and, if applicable, move for an additional one-
level downward adjustment under U.S.S.G. § 3E1.1(b)) only if the
conditions set forth in paragraph 3(c) are met and if defendant has
not committed, and refrains from committing, acts constituting
obstruction of justice within the meaning of U.S.S.G. § 3Cl.1, as
discussed below. Subject to paragraph 27 below, defendant and the
USAO agree not to seek, argue, or suggest in any way, either orally
or in writing, that any other specific offense characteristics,
adjustments, or departures relating to the offense level be imposed.
Defendant agrees, however, that if, after signing this agreement but
prior to sentencing, defendant were to commit an act, or the USAO
were to discover a previously undiscovered act committed by defendant
prior to signing this agreement, which act, in the judgment of the
USAO, constituted obstruction of justice within the meaning of
U.S.S.G. § 3Cl1l.1, the USAO would be free to seek the enhancement set
forth in that section and to argue that defendant is not entitled to
a downward adjustment for acceptance of responsibility under U.S.5.G.
§ 3E1.1.

16. Defendant understands that there is no agreement as to
defendant’s criminal history or criminal history category.

17. Defendant and the USAO reserve the right to argue for a

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sentence outside the sentencing range established by the Sentencing
Guidelines based on the factors set forth in 18 U.S.C. § 3553(a) (1),
(a) (2), (a) (3), (a) (6), and (a) (7).

WAIVER OF CONSTITUTIONAL RIGHTS

18. Defendant understands that by pleading guilty, defendant

gives up the following rights:

a. The right to persist in a plea of not guilty.

b. The right to a speedy and public trial by jury.

Cc. The right to be represented by counsel -- and if
necessary have the Court appoint counsel -- at trial. Defendant

understands, however, that, defendant retains the right to be

represented by counsel ~- and if necessary have the Court appoint
counsel -- at every other stage of the proceeding.
d. The right to be presumed innocent and to have the

burden of proof placed on the government to prove defendant guilty
beyond a reasonable doubt.

e. The right to confront and cross-examine witnesses
against defendant.

f. The right to testify and to present evidence in
opposition to the charges, including the right to compel the
attendance of witnesses to testify.

g. The right not to be compelled to testify, and, if
defendant chose not to testify or present evidence, to have that
choice not be used against defendant.

h. Any and all rights to pursue any affirmative defenses,
Fourth Amendment or Fifth Amendment claims, and other pretrial

motions that have been filed or could be filed.

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ase 2:22-cr-00260-PA Document37 Filed 06/21/22 Page13o0f20 Page 1ID#:145

WAIVER OF APPEAL OF CONVICTIONS

19. Defendant understands that, with the exception of an appeal
based on a claim that defendant’s guilty pleas were involuntary, by
pleading guilty defendant is waiving and giving up any right to
appeal defendant’s convictions on the offenses to which defendant is
pleading guilty. Defendant understands that this waiver includes,
but is not limited to, arguments that the statutes to which defendant
is pleading guilty are unconstitutional, and any and all claims that
the statement of facts provided herein is insufficient to support
defendant’s pleas of guilty.

WAIVER OF APPEAL AND COLLATERAL ATTACK

20. Defendant agrees that, provided the Court imposes a total
term of imprisonment within or below the range corresponding to an
offense level of 25 and a criminal history category calculated by the
Court, defendant gives up the right to appeal all of the following:

(a) the procedures and calculations used to determine and impose any

portion of the sentence; (b) the term of imprisonment imposed by the
Court, including, to the extent permitted by law, the
constitutionality or legality of defendant’s sentence, provided it is
within the statutory maximum; (c) the fine imposed by the Court,
provided it is within the statutory maximum; (d) the amount and terms
of any restitution order, provided it requires payment of no more
than $250,000; (e) the term of probation or supervised release
imposed by the Court, provided it is within the statutory maximum;
and (f) any of the following conditions of probation or supervised
release imposed by the Court: the conditions set forth in Second
Amended General Order 20-04 of this Court; the drug testing
conditions mandated by 18 U.S.C. §§ 3563(a) (5) and 3583(d); and the

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alcohol and drug use conditions authorized by 18 U.S.C. § 3563(b) (7).

21. Defendant also gives up any right to bring a post-
conviction collateral attack on the convictions or sentence,
including any order of restitution, except a post-conviction
collateral attack based on a claim of ineffective assistance of
counsel, a claim of newly discovered evidence, or an explicitly
retroactive change in the applicable Sentencing Guidelines,
sentencing statutes, or statutes of conviction. Defendant
understands that this waiver includes, but is not limited to,
arguments that the statutes to which defendant is pleading guilty are
unconstitutional, and any and all claims that the statement of facts
provided herein is insufficient to support defendant’s pleas of
guilty.

22. This agreement does not affect in any way the right of the
USAO to appeal the sentence imposed by the Court.

RESULT OF WITHDRAWAL OF GUILTY PLEA

23. Defendant agrees that if, after entering guilty pleas
pursuant to this agreement, defendant seeks to withdraw and succeeds
in withdrawing any of defendant’s guilty pleas on any basis other
than a claim and finding that entry into this plea agreement was
involuntary, then the USAO will be relieved of all of its obligations
under this agreement.

EFFECTIVE DATE OF AGREEMENT

24. This agreement is effective upon signature and execution of
all required certifications by defendant, defendant’s counsel, and an
Assistant United States Attorney.

BREACH OF AGREEMENT

25. Defendant agrees that if defendant, at any time after the

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se 2:22-cr-00260-PA Document 37 _ Filed 06/21/22 Pagei15of20 Page ID #:147

signature of this agreement and execution of all required
certifications by defendant, defendant’s counsel, and an Assistant
United States Attorney, knowingly violates or fails to perform any of
defendant’s obligations under this agreement (“a breach”), the USAO
may declare this agreement breached. All of defendant’s obligations
are material, a single breach of this agreement is sufficient for the
USAO to declare a breach, and defendant shall not be deemed to have
cured a breach without the express agreement of the USAO in writing.
If the USAO declares this agreement breached, and the Court finds
such a breach to have occurred, then: (a) if defendant has previously
entered guilty pleas pursuant to this agreement, defendant will not
be able to withdraw the guilty pleas, and (b) the USAO will be
relieved of all its obligations under this agreement.

COURT AND UNITED STATES PROBATION AND PRETRIAL SERVICES

OFFICE NOT PARTIES

26. Defendant understands that the Court and the United States
Probation and Pretrial Services Office are not parties to this
agreement and need not accept any of the USAO’s sentencing
recommendations or the parties’ agreements to facts or sentencing
factors.

27. Defendant understands that both defendant and the USAO are
free to: (a) supplement the facts by supplying relevant information
to the United States Probation and Pretrial Services Office and the
Court, (b) correct any and all factual misstatements relating to the
Court’s Sentencing Guidelines calculations and determination of
sentence, and (c) argue on appeal and collateral review that the
Court’s Sentencing Guidelines calculations and the sentence it
chooses to impose are not error, although each party agrees to

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Iaintain its view that the calculations in paragraph 15 are
consistent with the facts of this case. While this paragraph permits
both the USAO and defendant to submit full and complete factual
information to the United States Probation and Pretrial Services
Office and the Court, even if that factual information may be viewed
as inconsistent with the facts agreed to in this agreement, this
paragraph does not affect defendant’s and the USAO’s obligations not
to contest the facts agreed to in this agreement.

28. Defendant understands that even if the Court ignores any
sentencing recommendation, finds facts or reaches conclusions
different from those agreed to, and/or imposes any sentence up to the
maximum established by statute, defendant cannot, for that reason,

withdraw defendant’s guilty pleas, and defendant will remain bound to

fulfill all defendant’s obligations under this agreement. Defendant
understands that no one —-- not the prosecutor, defendant’s attorney,
or the Court -- can make a binding prediction or promise regarding

the sentence defendant will receive, except that it will be within

the statutory maximum.

POTENTIAL CASA APPLICATION

29. Defendant intends to submit an application to participate
in the Court’s Conviction and Sentence Alternatives (“CASA”) program.
Defendant understands that any application will be reviewed by the
USAO and the CASA program team using their ordinary procedures for a
determination whether defendant would be accepted for participation
in the CASA program, and there is no certainty that defendant would
be accepted for participation in the CASA program.

30. With this understanding, defendant and the USAO agree as
follows if defendant submits a CASA application:

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a. After entry of defendant’s guilty pleas, defendant and
the USAO will request that preparation of a presentence report be
delayed, that any previously set sentencing date be vacated, and that
a status conference be scheduled for a date approximately 60 days
after entry of defendant’s guilty pleas;

b. If the CASA program team determines that defendant
should be accepted for participation in the CASA program, defendant
and the USAO will execute an addendum to the plea agreement
incorporating the terms of defendant’s participation in the CASA
program, but otherwise leaving all other terms of the instant plea
agreement in effect (“CASA plea agreement addendum”) ;

Cc. If defendant and the USAO file a CASA plea agreement
addendum, they will jointly request that the Court (i) order that
this case be transferred to the CASA judicial officer; (ii) refer
defendant to the CASA program for the CASA program judicial officer
to take defendant’s amended guilty plea pursuant to the CASA plea
agreement; and (iii) permit defendant to begin his participation in

the CASA program;

d. If either: (i) defendant is not accepted for
participation in the CASA program; or (ii) the Court does not agree
to allow defendant’s participation in the CASA program; then the
Court shall be so advised at or prior to the status conference
referenced in subparagraph (a) above, defendant’s guilty pleas
pursuant to this agreement shall remain in place, and the parties
will jointly request that the Court set a date for defendant's
sentencing and order that the United States Probation Office prepare

defendant’s presentence report.

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Case 2:22-cr-00260-PA Document 37 _ Filed 06/21/22 Page18of20 Page ID #:150

1 NO ADDITIONAL AGREEMENTS

2 31. Defendant understands that, except as set forth herein,

3 there are no promises, understandings, or agreements between the USAO
4 land defendant or defendant’s attorney, and that no additional

5 llpromise, understanding, or agreement may be entered into unless ina
6 |writing signed by all parties or on the record in court.

7 PLEA AGREEMENT PART OF THE GUILTY PLEA HEARING

8 32. The parties agree that this agreement will be considered

9 part of the record of defendant’s guilty plea hearing as if the

10 llentire agreement had been read into the record of the proceeding.
11 |} AGREED AND ACCEPTED
12 || UNITED STATES ATTORNEY'S OFFICE
FOR THE CENTRAL DISTRICT OF
13 || CALIFORNIA
14 i TRACY L. WILKISON

United States Attorney

16 a.

CHARLES E. PEL . Date

17 || Assis d States Attorney

18 bb- IS -2022-
STEPHEN GLOYER Date

19 || Defendant

J¢ALEJANDRO BARRIENTOS/IJEOMA Date

21 || UCHECHI EKE
Attorneys for Defendant STEPHEN

22 || GLOVER
23 CERTIFICATION OF DEFENDANT
24 I have read this agreement in its entirety. I have had enough

25 itime to review and consider this agreement, and I have carefully and
26 |i thoroughly discussed every part of it with my attorney. I understand
27 lithe terms of this agreement, and I voluntarily agree to those terms.

28 iI have discussed the evidence with my attorney, and my attorney has

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Case 2:22-cr-00260-PA _ Document 37 _ Filed 06/21/22 Page 19 of 20 Page ID #:151

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advised me of my rights, of possible pretrial motions that might be
filed, of possible defenses that might be asserted either prior to or
at trial, of the sentencing factors set forth in 18 U.S.C. § 3553(a),
of relevant Sentencing Guidelines provisions, and of the consequences
of entering into this agreement. No promises, inducements, or
representations of any kind have been made to me other than those
contained in this agreement. No one has threatened or forced me in
any way to enter into this agreement. I am satisfied with the
representation of my attorney in this matter, and I am pleading
guilty because I am guilty of the charges and wish to take advantage

of the promises set forth in this agreement, and not for any other

reason.

STEPHEN GLOVER Date
Defendant

CERTIFICATION OF DEFENDANT'S ATTORNEY

I am STEPHEN GLOVER’s attorney. I have carefully and thoroughly
discussed every part of this agreement with my client. Further, I
have fully advised my client of his rights, of possible pretrial
motions that might be filed, of possible defenses that might be
asserted either prior to or at trial, of the sentencing factors set
forth in 18 U.S.C. § 3553(a), of relevant Sentencing Guidelines
provisions, and of the consequences of entering into this agreement.
To my knowledge: no promises, inducements, or representations of any
kind have been made to my client other than those contained in this
agreement; no one has threatened or forced my client in any way to
enter into this agreement; my client’s decision to enter into this
agreement is an informed and voluntary one; and the factual basis set

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ase 2:22-cr-00260-PA Document37 Filed 06/21/22 Page 20of20 Page ID #:152

forth in this agreement is sufficient to support my client’s entry of

guilty pleas pursuant to this agreement.

ALEJANDRO BARRIENTOS/IJEOMA Date
UCHECHI EKE
Attorneys for Defendant STEPHEN
GLOVER

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