Plea Agreement — United States v. William Dexter Lucas, Criminal No. 4:20-CR-452-S (Dkt. 270, S.D. Tex.)

Summary

William Dexter Lucas, also known as Bill Lucas, agrees in this plea agreement, filed 12/08/22 in the Southern District of Texas, to plead guilty to Count 1 of the second superseding indictment, conspiracy to commit bank and wire fraud, which carries up to 30 years in prison and a fine of up to $1,000,000. The United States will move to dismiss the other counts. The factual basis says Jesus Survives Ministries (JSM) and a Richmond, Texas, address were used in false car loan, PPP and EIDL applications, and that Lucas stated JSM's gross revenues as $969,843 or $850,000 on EIDL applications. A $50,000 PPP loan was deposited to a JSM account from Allegiance Bank, and on May 19, 2020, seizure warrants took $46,285.22 from a JSM account and $392.24 from an account of Deborah Jean Lucas. Lucas agrees to a forfeiture of $50,000, including a personal money judgment in that amount.

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Case 4:20-cr-00452 Document 270 Filed on 12/08/22 in TXSD Page 1 of 17

4 UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION
UNITED STATES OF AMERICA §
§

Vv. § CRIMINAL NO. 4:20-CR-452-S

§
WILLIAM DEXTER LUCAS §
a.k.a. Bill Lucas, §
Defendant. §

PLEA AGREEMENT

The United States of America, by and through Jennifer B. Lowery, United States Attorney for
the Southern District of Texas, and Zahra Jivani Fenelon, Assistant United States Attorney, and the
defendant, William Dexter Lucas (“Defendant”), and Defendant’s counsel, pursuant to Rule 11(c)(1)(A)
of the Federal Rules of Criminal Procedure, state that they have entered into an agreement, the terms and
conditions of which are as follows:

Defendant’s Agreement

1. Defendant agrees to plead guilty to Count 1 of the Second Superseding Indictment. Count
1 charges Defendant with conspiracy to commit bank and wire fraud, in violation of Title 18, United
States Code, Section 1349. Defendant, by entering this plea, agrees that he is waiving any right to have
the facts that the law makes essential to the punishment either charged in the second superseding
indictment, or proved to a jury or proven beyond a reasonable doubt.

Punishment Range

2. The statutory maximum penalty for each violation of Title 18, United States Code, Section
1349, is imprisonment of not more than 30 years and a fine of not more than $1,000,000 or twice the
loss or gain. Additionally, Defendant may receive a term of supervised release after imprisonment of
up to 5 years, See Title 18, United States Code, sections 3559(a)(2) and 3583(b)(2). Defendant
acknowledges and understands that if he should violate the conditions of any period of supervised release

which may be imposed as part of his sentence, then Defendant may be imprisoned for up to 3 years,
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without ‘credit for time already served on the term of supervised release prior to such violation, See
Title 18, United Stated Code, sections 3559(a)(2) and 3583(e)(3). Defendant understands that he cannot
have the imposition or execution of the sentence suspended, nor is he eligible for parole.
Mandatory Special Assessment

3. Pursuant to Title 18, United States Code, section 3013(a)(2)(A), immediately after
sentencing, Defendant will pay to the Clerk of the United States District Court a special assessment in
the amount of one hundred dollars ($100.00) per count of conviction. The payment will be by cashier’s
check or money order, payable to the Clerk of the United States District Court, c/o District Clerk's Office,
P.O. Box 61010, Houston, Texas 77208, Attention: Finance.

Immigration Consequences

4, Defendant recognizes that pleading guilty may have consequences with respect to his
immigration status. Defendant understands that if he is not a citizen of the United States, by pleading
guilty he may be removed from the United States, denied citizenship, and denied admission to the United
States in the future. Defendant understands that if he is a naturalized United States citizen, pleading
guilty may result in immigration consequences, such as denaturalization and potential deportation or
removal from the United States. Defendant’s attorney has advised Defendant of the potential
immigtation consequences resulting from Defendant’s plea of guilty, and Defendant affirms that he
wants to plead guilty regardless of any immigration consequences that may result from the guilty plea
and conviction.

Waiver of Appeal and Collateral Review

5. Defendant is aware that Title 28, United States Code, section 1291, and Title 18, United
States Code, section 3742, afford a defendant the right to appeal the conviction and sentence imposed.
Defendant is also aware that Title 28, United States Code, section 2255, affords the right to contest or

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“collaterally attack” a conviction or sentence after the judgment of conviction and sentence has become
final. Defendant knowingly and voluntarily waives the right to appeal or “collaterally attack” the
conviction and sentence, except that Defendant does not waive the right to raise a claim of ineffective
assistance of counsel on direct appeal, if otherwise permitted, or on collateral review in a motion under
Title 28, United States Code, section 2255. In the event Defendant files a notice of appeal following the
imposition of the sentence or later collaterally attacks his conviction or sentence, the United States will
assert its rights under this agreement and seek specific performance of these waivers.

6. In agreeing to these waivers, Defendant is aware that a sentence has not yet been determined
by the Court. Defendant is also aware that any estimate of the possible sentencing range under the
sentencing guidelines that he may have received from his counsel, the United States or the Probation
Office, is a prediction and not a promise, did not induce his guilty plea, and is not binding on the United
States, the Probation Office or the Court. The United States does not make any promise or
representation concerning what sentence the defendant will receive. Defendant further understands and
agrees that the United States Sentencing Guidelines are “effectively advisory” to the Court. See United
States v. Booker, 543 U.S. 220 (2005). Accordingly, Defendant understands that, although the Court
must consult the Sentencing Guidelines and must take them into account when sentencing Defendant,
the Court is not bound to follow the Sentencing Guidelines nor sentence Defendant within the calculated
guideline range,

7. Defendant understands and agrees that each and all waivers contained in the Agreement are
made in exchange for the concessions made by the United States in this plea agreement.

The United States’ Agreements

8. The United States agrees to each of the following:
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‘ (a) If Defendant pleads guilty to Count 1 of the second superseding: indictment and
persists in that plea through sentencing, and if the Court accepts this plea agreement, the
United States will move to dismiss any remaining counts of the second superseding
indictment at the time of sentencing; and

(b) The United States will not move for Defendant’s detention at the time of
Defendant’s guilty plea.

Agreement Binding - Southern District of Texas Only

9, The United States Attorney’s Office for the Southern District of Texas agrees that it will not
further criminally prosecute Defendant in the Southern District of Texas for offenses arising from
conduct charged in the second superseding indictment. This plea agreement binds only the United
States Attorney’s Office for the Southern District of Texas and Defendant. It does not bind any other
United States Attorney’s Office. The United States Attorney’s Office for the Southern District of Texas
will bring this plea agreement and the full extent of Defendant’s cooperation to the attention of other
prosecuting offices, if requested.

United States’ Non-Waiver of Appeal

10. The United States reserves the right to carry out its responsibilities under guidelines
sentencing. Specifically, the United States reserves the right:

(a) to bring its version of the facts of this case, including its evidence file and any

investigative files, to the attention of the Probation Office in connection with that office’s

preparation of a presentence report;

(b) to set forth or dispute sentencing factors or facts material to sentencing;

(d) to file a pleading relating to these issues, in accordance with section 6A1.2 of the
United States Sentencing Guidelines and Title 18, United States Code, section 3553{a);

and

(e) to appeal the sentence imposed or the manner in which it was determined,
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Sentence Determination °

11. Defendant is aware that the sentence will be imposed after consideration of the United States
Sentencing Guidelines and Policy Statements, which are only advisory, as well as the provisions of Title
18, United States Code, section 3553(a). Defendant nonetheless acknowledges and agrees that the
Court has authority to impose any sentence up to and including the statutory maximum set for the
offense(s) to which Defendant pleads guilty, and that the sentence to be imposed is within the sole
discretion of the sentencing judge after the Court has consulted the applicable Sentencing Guidelines,
Defendant understands and agrees that the parties’ positions regarding the application of the Sentencing
Guidelines do not bind the Court and that the sentence imposed is within the discretion of the sentencing
judge. Ifthe Court should impose any sentence up to the maximum established by statute, or should
the Court order any or all of the sentences imposed to run consecutively, Defendant cannot, for that
reason alone, withdraw a guilty plea, and will remain bound to fulfill all of the obligations under this
plea agreement.

Rights at Trial

12. Defendant understands that by entering into this agreement, he surrenders certain rights as
provided in this plea agreement. Defendant understands that the rights of a defendant include the
following:

(a) If Defendant persisted in a plea of not guilty to the charges, defendant would have

the right to a speedy jury trial with the assistance of counsel. The trial may be conducted

by a judge sitting without a jury if Defendant, the United States, and the court all agree.

(b) At a trial, the United States would be required to present witnesses and other

evidence against Defendant. Defendant would have the opportunity to confront those

witnesses and his attorney would be allowed to cross-examine them. In turn, Defendant

could, but would not be required to, present witnesses and other evidence on his own

behalf. If the witnesses for Defendant would not appear voluntarily, he could require
their attendance through the subpoena power of the court; and
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(c) At'a trial, Defendant could rely on a privilege against self-incrimination and
decline to testify, and no inference of guilt could be drawn from such refusal to testify.
However, if Defendant desired to do so, he could testify on his own behaif.

Factual Basis for Guilty Plea

13. Defendant is pleading guilty because he is in fact guilty of the charges contained in Count
1 of the second superseding indictment. If this case were to proceed to trial, the United States could
prove each element of the offense beyond a reasonable doubt. The following facts, among others would
be offered to establish Defendant’s guilt:

William Dexter Lucas, a.k.a. Bill Lucas (Lucas) is married to Deborah Jean Lucas (Deborah) and
was previously married to Brian Michael Corpian’s (Corpian) mother, Diane Corpian. Corpian met
Lucas in early 2000 when Lucas was dating and claimed to marry Brian’s mother, Diane Corpian.
After Lucas and Diane Corpian separated, Lucas began a relationship and married Deborah. After
Diane Corpian’s passing in 2014, Lucas claimed to still be married to Diane Corpian and therefore
claimed ownership interest to Diane Corpian’s house at 20134 Larkspur Landing, Richmond, Texas.
Corpian, Lucas, and Deborah all resided at 20134 Larkspur Landing, Richmond, Texas, and it is the
listed address for Jesus Survives Ministries (ISM). JSM and the Larkspur Landing address was utilized
in false car loan applications, Paycheck Protection Program (PPP) loan applications, Economic Injury
Disaster Loan (EIDL) applications, and identity theft reports to the Federal Trade Commission (FTC).

JSM was registered as a Texas corporation, organized for non-profit purposes, whose Articles of
Incorporation were filed on or about March 31, 2020. The Articles stated Lucas was the President of
JSM, and the Vice President and Secretary of JSM was Corpian. Lucas held himself out as the Lead
Pastor of JSM and Deborah represented she was a Pastor at JSM. Deborah was then named as the new

Registered Agent of JSM on or about May 5, 2020. This change was executed by Lucas. The registered
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office was transferred from the residential property located at 7036 Dairy Ashford, Houston, Texas, to
the residential property located at 20134 Larkspur Landing, Richmond, Texas.

From on or about 2014 there were no meetings, or congregational or pastoral services conducted
by Lucas, Deborah, Corpian, or in the name of JSM—either at the Larkspur residence or the College
Station residence all three resided at prior to moving to the Larkspur residence.

Lucas, Deborah, and Corpian made false statements regarding their payrol! from JSM in
submitting car loan applications to banks or financial lenders for the purchase of cars at multiple
dealerships, including Spring Branch Honda, Classic Chevrolet Sugar Land, Sterling McCall Toyota,
Don McGill Toyota, and Big O Dodge. All dealerships, but for Big O Dodge, are in the Southern District
of Texas. Car loan applications were sent to through the internet to banks or financial lenders whose
servers were located outside of Texas. Lucas would complete, and direct Deborah and Corpian on how
to complete car loan applications—including listing JSM as their employer and the amount of payroll
received. Through false statements made on car loan applications, Lucas acquired a 2019 Toyota
Tundra and Deborah acquired a 2020 Toyota Corolla as listed in Counts 2 and 3 of the second
superseding indictment. Corpian accompanied Deborah to the Toyota dealership when Deborah filed
the application and made the purchase of the Toyota Corolla. While filling out the application for the
Toyota Corolla, Deborah called Lucas on the phone to guide her as to what to list as employment and
income. Jn or about May 2020, after the PPP foan to JSM was funded for $50,000, Lucas and Deborah
traveled to South Carolina. While in South Carolina, Deborah called Corpian to complain about Lucas
attempting to purchase a pickup truck in South Carolina,

In or about March-April 2020, Lucas made false certifications regarding JSM in applications for
EIDLs in the name of JSM and his own name submitted to the Smail Business Administration (SBA).
On multiple EIDL applications, Lucas falsely stated that JSM had gross revenues of $969,843 or

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$850,000 for thé twelve months prior to January 31, 2020. EIDL applications were sent through the
internet to the SBA whose server is located outside of Texas, thus traveling via interstate commerce,
Lucas made calls or directed Corpian to make calls to the SBA to inquire about the status of the EIDL
application. During one of the calis made by Lucas to the SBA, Lucas claimed that the SBA was
discriminating against churches.

Lucas told Corpian and Deborah that he had applied for Paycheck Protection Program (PPP)
loans in or about April 2020, Lucas had Corpian and Deborah sign documents as part of the PPP loan
applications, Florine “Sassman” was listed as the accountant and drafter for several of the records
provided as part of the PPP loan applications. Florine “Sassman” is Florine Lucas and Lucas’ ex-wife.
Florine did not have any affiliation with JSM, was not JSM’s accountant, and did not draft or submit any
of the PPP loan applications.

On or about April 6, 2020 a PPP loan application and supporting documents were submitted to
Wallis Bank by Lucas which contained false statements regarding JSM-—including that JSM was and
had been a solvent and thriving religious organization; that JSM was an employer, making payroll and
withholding taxes from its employees’ wages, including the submission of false Employer’s Quarterly
Federal Tax Return forms 941 and alleged payroll records for JSM. The PPP loan application to Wallis
Bank was sent to through the internet and Wallis Bank’s server is located outside of Texas.

The PPP loan applications to Allegiance Bank submitted by Lucas contained false statements
regarding JSM—including that JSM was and had been a solvent and thriving religious organization; that
JSM was an employer, making payroll and withholding taxes from its employees’ wages, including the
submission of false Employer’s Quarterly Federal Tax Return forms 941; alleged payroll records for
JSM; documents to substantiate that the residence located at 20134 Larkspur Landing, Richmond, Texas,
was leased for JSM including a lease agreement, as well as an altered TXU Energy bill for that address

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‘which falsely reflected the account holder was JSM. ‘The April 4, 2020 PPP: loan application and
supporting documents was submitted by Lucas to Allegiance Bank, even though the application listed
Brian Michael Corpian as the applicant. The April 6, 2020 PPP loan application with supplemental
documents was submitted by Lucas to Allegiance Bank. The PPP loan applications to Allegiance Bank
were sent to through the internet and Allegiance Bank’s server is located outside of Texas.

Lucas sent accusatory and intimidating text messages and emails to bankers at Wallis Bank and
Allegiance Bank, who were reviewing his PPP loan submission, regarding the bank’s alleged failure to
review and fund the loan quickly. Lucas boasted about sending these accusatory and intimidating emails
and text messages to bank employees to Corpian.

On or about April 23, 2020, Lucas and Deborah caused bank account xxxxxxxx343 | to be opened
at Bank of America (BOA) in the name JSM. On May 1, 2020, Deborah and Florine went to Bank of
America in order to procure the $50,000 in PPP loan funds deposited to the BOA JSM account from
Allegiance Bank. On May 5, 2020, Lucas made a notarized statement that he would like to add Deborah
on to the business JSM at Woodforest account xxxxxx1596, On May 5, 2020, Deborah and Lucas opened
a checking account in the name JSM at Woodforest National Bank (Woodforest), account xxxxxx1596,
using Tax identification Number xx-xxx4065, On May 5, 2020, Deborah also opened a debit card,
Master Card xxxxxxxxxxxxx7337, at Woodforest National Bank. On May 5, 2020, Deborah also
opened a personal bank account in her own name at Woodforest National Bank, account xxxxxx5860.

On May 5, 2020, Deborah deposited BOA cashier’s check 1301617369 payable to Jesus Survives
Ministries Inc, in the amount of $49,985 (the $50,000 in loan funds less a $15 fee) into Jesus Survives
Ministries account xxxxxx1596 at Woodforest National Bank. On May 11, 2020, two transfers of loan
funds were made from the Jesus Survives Ministries account xxxxxx1596 into Deborah’s personal
account xxxxxx5860, one for $188 and one for $1,200.

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On or ‘about May 19, 2020, seizure warrants were executed for the loan funds proceeds:
$46,285.22 was seized from JSM’s account xxxxxx1596, and $392.24 was seized from Deborah’s
account Xxxxxxx5860.

Lucas filed and caused Corpian to file false reports under the penalty of perjury to the Federal
Trade Commission (FTC) and claim that his debts associated with car loans were due to his being a
victim of identity theft. Lucas filed the February 20, 2020 (reference number ending in 5182) and
March 3, 2020 (reference number ending in 7606) false identity theft reports as alleged in Counts 22 and
23 of the second superseding indictment. Lucas directed and caused Corpian to file the May 15, 2020
false identity theft report, with reference number ending in 6004 as alleged in Count 24 of the second
superseding indictment.

On May 19, 2020, four agents arrived at Larkspur Landing and interviewed Lucas, Deborah, and
Corpian. Corpian was interviewed by two agents, while Deborah was interviewed by the other two
agents. Following the completion of Corpian’s interview, Lucas approached two agents without the use
of any cane, wheelchair, or other device, and spoke to the agents.

After the interviews with agents, Lucas drafted a false affidavit and directed Corpian to sign it,
and have it notarized. Corpian had the affidavit signed and notarized on August 18,2020. The August
18, 2020 affidavit is false, including but not limited to the following false assertions: Corpian applied
for the PPP and EIDL loans alone; altered documents submitted as part of the applications; that Lucas
and Deborah had no knowledge of the alterations of the documents submitted; and used Deborah and
Lucas’ emails without their consent or knowledge. Lucas informed Corpian that it was okay to initial
and sign the affidavit because it was Lucas and Deborah’s “insurance” in case the government put
Corpian on the stand. Lucas informed Corpian that Lucas could not go back to prison and that Corpian
was young, could handle prison, and that the government would not send Corpian to jail. Corpian did

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not want Lucas or Deborah to go to prison and was also worried that he would be kicked out of the
house. Corpian initialed, signed, and had the false August 18, 2020 affidavit notarized. The August
18, 2020 affidavit was filed by Lucas with this Court in United States v. Lucas, et. al, criminal number
4:20-cr-452, on August 6, 2021, as part of an Opposed Motion to Continue with Affidavit (DE 65).

Lucas also drafted a false July 21,2021 affidavit, in which the August 2020 affidavit is referenced
and states that Lucas and Deborah had no knowledge of what Corpian and the “ministries bookkeeper”
had done wrong in obtaining the PPP loan. As instructed by Lucas, Corpian had the affidavit signed
and notarized on July 21,2021. Lucas filed the July 21, 2021 affidavit under Corpian’s name with this
Court in United States v. Lucas, et, al, criminal number 4:20-cr-452, on July 26, 2021, as part of an
advisory and complaint of prosecutorial and defense counsel misconduct with affidavit in support
thereof.

After the filing of the August 18, 2020 affidavit on August 6, 2021, Lucas and Deborah
influenced and assisted Corpian in fleeing to California to avoid being present and/or testifying in the
current case, United States v. Lucas, et. al, criminal number 4:20-cr-452, Lucas stated that it was in
Corpian’s best interest to flee. Lucas had previously advised Corpian to cut off his ankle monitor while
in the hospital to test how quickly the pretrial officer or law enforcement would be notified. Because
the notification was not immediate when Corpian had cut off his ankle monitor at the hospital, Lucas
persuaded Corpian to cut off his ankle monitor once again. Deborah drove Corpian to purchase a
backpack, sleeping bag, and a Greyhound bus ticket for Corpian to flee. Lucas provided Corpian
approximately $2,000 and 10 50mg pills of Tramadol prior to Corpian’s departure. Lucas wanted
Corpian to stay in California for at least five years and Lucas offered to send Corpian money while he

was in California. .

1]
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vt Breach of Plea Agreement 1

14. If Defendant should fail in any way to fulfill completely all of the obligations under this
plea agreement, the United States will be released from its obligations under the plea agreement, and
Defendant’s plea and sentence will stand. If at any time Defendant retains, conceals, or disposes of
assets in violation of this plea agreement, or if Defendant knowingly withholds evidence or is otherwise
not completely truthful with the United States, then the United States may move the Court to set aside
the guilty plea and reinstate prosecution, Any information and documents that have been disclosed by
Defendant, whether prior to or subsequent to this plea agreement, and all leads derived therefrom, will
be used against defendant in any prosecution,

Restitution, Forfeiture, and Fines — Generally

15. This Plea Agreement is being entered into by the United States on the basis of Defendant’s
express representation that he will make a full and complete disclosure of all assets over which he
exercises direct or indirect control, or in which he has any financial interest. Defendant agrees not to
dispose of any assets or take any action that would effect a transfer of property in which he has an
interest, unless Defendant obtains the prior written permission of the United States.

16. Defendant agrees to make complete financial disclosure by truthfully executing a sworn
financial statement (Form OBD-500 or similar form) within 14 days of signing this plea agreement.
Defendant agrees to authorize the release of all financial information requested by the United States,
including, but not limited to, executing authorization forms permitting the United States to obtain tax
information, bank account records, credit histories, and social security information. Defendant agrees
to discuss and answer any questions by the United States relating to Defendant’s complete financial

disclosure.

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17. Defendant agrees to take all steps necessary to pass clear title to forfeitable assets to the
United States and to assist fully in the collection of restitution and fines, including, but not limited to,
surrendering title, executing a warranty deed, signing a consent decree, stipulating to facts regarding the
transfer of title and the basis for the forfeiture, and signing any other documents necessary to effectuate
such transfer, Defendant also agrees to direct any banks which have custody of his assets to deliver all
funds and records of such assets to the United States.

18. Defendant understands that forfeiture, restitution, and fines are separate components of
sentencing and are separate obligations.
Restitution
19. Defendant agrees to pay full restitution to the victim regardless of the count of conviction.
Defendant stipulates and agrees that as a result of his criminal conduct, the victim incurred a monetary
loss of at least $ 50,000. Defendant understands and agrees that the Court will determine the amount
of restitution to fully compensate the victim. Defendant agrees that restitution imposed by the Court
will be due and payable immediately and that Defendant will not attempt to avoid or delay payment.
Subject to the provisions of paragraph 5 above, Defendant waives the right to challenge in any manner,
including by direct appeal or in a collateral proceeding, the restitution order imposed by the Court.
Forfeiture
20. Defendant stipulates and agrees that the property listed in the Second Superseding
Indictment’s Notice of Forfeiture (and in any supplemental Notices) is subject to forfeiture, and
Defendant agrees to the forfeiture of that property. Specifically, Defendant stipulates and agrees that
the factual basis for his guilty plea supports the forfeiture of the $46,285.22 seized from JSM’s account
xxxxxx 1596 and the $392.24 seized from Deborah Jean Lucas’ account xxxxxx5860 as proceeds of the
conspiracy to commit bank and wire fraud.

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21. Defendant stipulates and agrees that Defendant obtained at least $50,000 from the criminal
offenses and that the factual basis for his guilty plea supports the forfeiture of $50,000. Defendant
stipulates and admits that one or more of the conditions set forth in Title 21, United States Code, section
853(p), exists. Defendant agrees to forfeit any of Defendant’s property in substitution, up to a total

forfeiture of $50,000, Defendant agrees to the imposition of a personal money judgment in that amount,

22, Defendant agrees to waive any and all interest in any asset which is the subject of a related
administrative or judicial forfeiture proceeding, whether criminal or civil, federal or state. 23.
Defendant consents to the order of forfeiture becoming final as to Defendant immediately following this
guilty plea, pursuant to Federal Rule of Criminal Procedure 32.2(b)(4)(A).

24, Subject to the provisions of paragraph 5 above, Defendant waives the right to challenge the
forfeiture of property in any manner, including by direct appeal or in a collateral proceeding.

Fines

25. Defendant understands that under the Sentencing Guidelines the Court is permitted to order
Defendant to pay a fine that is sufficient to reimburse the government for the costs of any imprisonment
or term of supervised release, if any. Defendant agrees that any fine imposed by the Court will be due
and payable immediately, and Defendant will not attempt to avoid or delay payment. Subject to the
provisions of paragraph 5 above, Defendant waives the right to challenge the fine in any manner,.
including by direct appeal or in a collateral proceeding.

Complete Agreement

26. This written plea agreement, consisting of 17 pages, including the attached addendum of
Defendant and his attorney, constitutes the complete plea agreement between the United States,
Defendant, and Defendant’s counsel. No promises or representations have been made by the United

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- States except as set forth in writing in this plea agreement. Defendant acknowledges that no threats
have been made against him and that he is pleading guilty freely and voluntarily because he is guilty.

29, Any modification of this plea agreement must be in writing and signed by all parties.

Filed at \ weatd , Texas, on Deeom boxe 5 , 2022.

Subscribed and sworn to before me on Ve cem be % , 2022.

~ NATHAN OCHSNER, Clerk
UNITED STATES DISTRICT CLERK

By: Iv Vy tv]

Depitly United States District Clerk

APPROVED:

Jennifer B. Lowery

United States Attorne
By: / a a

ssistarit United States Attorney Attorney for Defendant

Southern District of Texas

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS

Defendant.

HOUSTON DIVISION
UNITED STATES OF AMERICA §
v. ; CRIMINAL NO. 4:20-CR-452-S
WILLIAM DEXTER LUCAS ;
a.k.a. Bill Lucas, §
§

PLEA AGREEMENT -- ADDENDUM

I have fully explained to Defendant his rights with respect to the pending second superseding
indictment. 1 have reviewed the provisions of the United States Sentencing Commission’s Guidelines
Manual! and Policy Statements and I have fully and carefully explained to Defendant the provisions of
those Guidelines which may apply in this case. I have also explained to Defendant that the Sentencing
Guidelines are only advisory and the court may sentence Defendant up to the maximum allowed by
statute per count of conviction, Further, I have carefully reviewed every part of this plea agreement
with Defendant. To my knowledge, Defendant’s decision to enter into this agreement is an informed

and voluntary one.

GES php
Attorney for ee) Date

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I have consulted with my attorney and fully understand all my rights with respect to the second
superseding indictment pending against me. My attorney has fully explained, and I understand, all my
rights with respect to the provisions of the United States Sentencing Commission’s Guidelines Manual
which may apply in my case. I have read and carefully reviewed every part of this plea agreement

with my attorney. I understand this agreement and I voluntarily agree to its terms.

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