United States v. Leif Gerald Larsen — Plea Agreement, Eastern District of Washington (Dkt. 97)

Summary

A plea agreement in United States v. Leif Gerald Larsen, Case No. 24-CR-06004-SAB-3, in the U.S. District Court for the Eastern District of Washington, filed March 26, 2025 as ECF No. 97. Larsen agrees to plead guilty to Count 6 of the Indictment filed on March 6, 2024, wire fraud under 18 U.S.C. § 1343, a Class C felony carrying not more than 20 years and a fine of no more than $250,000 or twice the gross gain or loss. In the statement of facts, Larsen and co-schemer Kelly Jo Driver falsely represented that Larsen Firearms had ten (10) employees in an EIDL Targeted Advance request seeking $9,000.00, which Larsen canceled after an interview with federal agents on March 25, 2021. They also submitted a PPP application to Bank of America listing average monthly payroll of $59,667. The agreement names Acting United States Attorney Richard R. Barker and defense counsel Gregory Scott.

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Case 4:24-cr-06004-SAB ECF No.

Richard R. Barker

Acting United States Attorney
Eastern District of Washington
Freida K. Zimmerman

Jeremy J. Kelley

Tyler H.L. Tornabene

Assistant United States Attorneys
Post Office Box 1494

Spokane, WA 99210-1494
Telephone: (509) 353-2767

97 filed 03/26/25

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FILED IN THE U.S. DISTRICT COURT
EASTERN DISTRICT OF WASHINGTON

MAR 26 2025

SEAN F. MCAVOY, CLERK
, DEPUTY
YAKIMA, WASHINGTON

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF WASHINGTON

UNITED STATES OF AMERICA,

Plaintiff,
V.
LEIF GERALD LARSEN,
Defendant.

Case No.: 24-CR-06004-SAB-3

Plea Agreement

Plaintiff, United States of America, by and through Richard R. Barker,
Acting United States Attorney the Eastern District of Washington, and Frieda K.

Zimmerman, Jeremy J. Kelley, and Tyler H.L. Tornabene, Assistant United States
Attorneys for the Eastern District of Washington, and Defendant LEIF GERALD
LARSEN (“Defendant”), both individually and by and through Defendant’s

counsel, Gregory Scott, agree to the following Plea Agreement.

1. Guilty Plea and Maximum Statutory Penalties

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Defendant agrees to enter a plea of guilty to Count 6 of the Indictment filed
on March 6, 2024, which charges Defendant with Wire Fraud, in violation of 18
U.S.C. § 1343, a Class C felony.
Defendant understands that the following potential penalties apply:
a. aterm of imprisonment of not more than 20 years;
b. aterm of supervised release of up to 3 years;
c. a fine of no more than $250,000 or not more than twice the
gross gain or gross loss, whichever is greater; |
d. restitution; and
e. a $100 special penalty assessment.

2. Supervised Release

Defendant understands that if Defendant violates any condition of
Defendant’s supervised release, the Court may revoke Defendant’s term of
supervised release, and require Defendant to serve in prison all or part of the term
of supervised release authorized by statute for the offense that resulted in such term
of supervised release without credit for time previously served on postrelease
supervision, up to the following term: 2 years in prions if the offense that resulted
in the term of Supervised Release is a class C felony.

Accordingly, Defendant understands that if Defendant commits one or more
violations of supervised release, Defendant could serve a total term of
incarceration greater than the maximum sentence authorized by statute for
Defendant’s offense or offenses of conviction.

3. The Court is Not a Party to this Plea Agreement

The Court is not a party to this Plea Agreement and may accept or reject it.
Defendant acknowledges that no promises of any type have been made to
Defendant with respect to the sentence the Court will impose in this matter.

Defendant understands the following:

a. sentencing is a matter solely within the discretion of the Court;

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4.

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the Court is under no obligation to accept any recommendations
made by the United States or Defendant;

the Court will obtain an independent report and sentencing
recommendation from the United States Probation Office;

the Court may exercise its discretion to impose any sentence it
deems appropriate, up to the statutory maximum penalties;

the Court is required to consider the applicable range set forth
in the United States Sentencing Guidelines, but may depart
upward or downward under certain circumstances; and

the Court may reject recommendations made by the United
States or Defendant, and that will not be a basis for Defendant
to withdraw from this Plea Agreement or Defendant’s guilty
plea.

Potential Immigration Consequences of Guilty Plea

If Defendant is not a citizen of the United States, Defendant understands the

following:

pleading guilty in this case may have immigration
consequences;

a broad range of federal crimes may result in Defendant’s
removal from the United States, including the offense to which
Defendant is pleading guilty;

removal from the United States and other immigration
consequences are the subject of separate proceedings; and

no one, including Defendant’s attorney or the Court, can predict
with absolute certainty the effect of a federal conviction on

Defendant’s immigration status.

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Defendant affirms that Defendant is knowingly, intelligently, and voluntarily
pleading guilty as set forth in this Plea Agreement, regardless of any immigration
consequences that Defendant’s guilty plea may entail.

5. Waiver of Constitutional Rights

Defendant understands that by entering this guilty plea, Defendant is
knowingly and voluntarily waiving certain constitutional rights, including the
following:

a the right to a jury trial;

b. the right to see, hear and question the witnesses;
c. the right to remain silent at trial;

d. __ the right to testify at trial; and

e. the right to compel witnesses to testify.

While Defendant is waiving certain constitutional rights, Defendant
understands that Defendant retains the right to be assisted by an attorney through
the sentencing proceedings in this case and any direct appeal of Defendant’s
conviction and sentence, and that an attorney will be appointed at no cost if
Defendant cannot afford to hire an attorney.

Defendant understands and agrees that any defense motions currently
pending before the Court are mooted by this Plea Agreement, and Defendant
expressly waives Defendant’s right to bring any additional pretrial motions.

6. Elements of the Offense

The United States and Defendant agree that in order to convict Defendant of
Wire Fraud, in violation of 18 U.S.C. § 1343, the United States would have to
prove the following beyond a reasonable doubt.
a. First, in the Eastern District of Washington and elsewhere, Defendant
knowingly and willingly devised and participated in a scheme or

artifice to defraud or to obtain money from the United States Small

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Business Administration by means of false and fraudulent pretenses,
representations, promises, or omitted facts;

b. Second, the statements made or facts omitted as part of the scheme were
material; that is, they had a natural tendency to influence, or were
capable of influencing, the United States Small Business
Administration to part with money or property; and

c. Third, Defendant acted with intent to defraud, that is, the intent to
deceive and cheat; and

d. Fourth, Defendant used, or caused to be used, an interstate wire
communication to carry out or attempt to carry out an essential part of
the scheme.

7. Factual Basis and Statement of Facts

The United States and Defendant stipulate and agree to the following: the
facts set forth below are accurate; the United States could prove these facts beyond
a reasonable doubt at trial; and these facts constitute an adequate factual basis for
Defendant’s guilty plea.

The United States and Defendant agree that this statement of facts does not
preclude either party from presenting and arguing, for sentencing purposes,
additional facts that are relevant to the Sentencing Guidelines computation or
sentencing.

The Coronavirus Aid, Relief, and Economic Security Act (““CARES” Act)
was a federal law enacted on March 27, 2020, designed to provide emergency
financial assistance to the millions of Americans who were suffering the economic
effects caused by the COVID-19 pandemic. One source of relief provided by the
CARES Act was the authorization of forgivable loans to small businesses for job
retention and other certain expenses, through a program referred to as the Paycheck

Protection Program (“PPP”).

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In order to obtain a PPP, a qualifying business was required to submit a PPP
application signed by an authorized representative of the business. The PPP
application required the business (through its authorized representative) to
acknowledge the program rules and make certain affirmative certifications in order
to be eligible to obtain the PPP funding. In the PPP application, the applicant
(through its authorized representative) was required to state, among other things: (a)
its average monthly payroll expenses; and (b) its number of employees. If the
applicant had no employees other than the owner, the applicant was required to
provide the gross income amount from a 2019 or 2020 IRS Form 1040, Schedule C.
These figures were used to calculate the amount of money the small business was
eligible to receive under the PPP. Additionally, the applicant was required to certify
that they were in operation as of February 15, 2020. The applicant was also required
to certify that the information in the application was true and correct to the best of
the applicant’s knowledge.

A business’s PPP application was received and processed, in the first instance,
by a participating lender. Ifa PPP application was approved, the participating lender
funded the PPP using its own monies. Data from the application, including
information about the borrower, the total amount of the loan, the listed number of
employees, and the gross income amount, was transmitted by the lender to the Small
Business Administration (“SBA”), an agency of the United States, in the course of
processing the loan.

PPPs were forgivable if the borrower met all the requirements of the program.
These requirements included that at least 60% of the PPP funds were used for:
payroll, while the remaining 40% could be used for payroll, mortgage interest, rent,
and utilities. The funds were not to be used for personal expenses. In seeking
forgiveness, the borrower was required to certify that they used the funds as required.
SBA transmitted the forgiveness payments to the PPP lender through the FMS

servers in Sterling, Virginia.

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In addition to the PPP, the CARES act also authorized COVID-19 related
funding for the Economic Injury Disaster Loan (EIDL) program. EIDL is an SBA
program that provides low-interest funding to small businesses, renters, and
homeowners affected by declared disasters. The EIDL program also offered
Targeted EIDL Advance and Supplemental Targeted Advance grants for certain
qualifying businesses that did not have to be repaid.

In order to obtain an EIDL and Advance, a qualifying business was required
to submit an application to the SBA and provide information about its operations,
such as the number of employees, gross revenues for the 12-month period preceding
the disaster, and cost of goods sold in the 12-month period preceding the disaster.
In the case of EIDLs for COVID-19 relief, the 12-month period was the year
preceding January 31, 2020. The applicant was also required to certify that all the
information in the application was true and correct to the best of the applicant’s
knowledge. The amount of an EIDL Targeted Advance, if the application was
approved, was determined based upon the number of employees listed on the
application. Any funds issued under an EIDL or Advance were issued directly by
the SBA.

‘EIDL applications were received in cloud-based platforms. The location of
the server through which the EIDL application was submitted was based on the date
the application was processed by SBA and the application number. EIDL Targeted
Advance and Supplemental Advance applications were submitted through Rapid
Finance systems that utilizes Microsoft cloud-based servers located in Des Moines,
Iowa. EDIL disbursements were initiated by the SBA Denver Finance Center
located in Denver, Colorado, which transmitted the payment information through
the FMS system to the Department of Treasury server located in the State of
Virginia. |

On or about February 22, 2021, Defendant and his co-schemer Kelly Jo Driver

submitted a request for EIDL Targeted Advance funds, via interstate wires to the

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SBA’s Rapid Finance servers in Des Moines, Iowa, related to EIDL application
number 3600597608. In the Targeted Advance request, Defendant and his co-
schemer Kelly Jo Driver falsely and fraudulently represented that Defendant’s sole
proprietorship, Larsen Firearms, had ten (10) employees as of the date of the
Targeted Advance application. In the application, Defendant and his co-schemer
Kelly Jo Driver submitted certified, and caused to be certified, that the information
provided in the application was true and accurate in all material respects. These
representations and certification were materially false and fraudulent and were made
to induce the SBA to disburse $9,000.00 in EIDL funding for which Defendant and
his sole proprietorship, Larsen Firearms, were not eligible. Defendant canceled the
Targeted Advance request after being interviewed by federal agents on March 25,
2021.

On or about March 2, 2021, Defendant and his co-schemer Kelly Jo Driver
submitted a PPP application in the name of Larsen Gunsmithing & Firearms to Bank
of America, a federally insured financial institution. The application was submitted
via interstate wires. In the application, Defendant and his co-schemer Kelly Jo
Driver, falsely and fraudulently represented that the company had ten (10)
employees and average monthly payroll of $59,667. In support of the PPP
application, Defendant and his co-schemer Kelly Jo Driver submitted a false and
fraudulent payroll register and IRS Form 941s. In the application, Defendant and
his co-schemer Kelly Jo Driver, certified that the information in the application and _
supporting documents were true and accurate. However, the certification as well as
representations in the application and supporting documents were materially false
and fraudulent and made to induce Bank of America to disburse PPP funds for which
LARSEN and Larsen Gunsmithing & Firearms were not eligible. Based upon the
false representations, Bank of America approved the application, which was
assigned PPP No. 49674286-06, and disbursed $149,167 to Defendant on or about
March 23, 2021. On or about March 23, 2021, Defendant sent $15,000 via interstate

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wires from his Bank of America account to his co-schemer, Kelly Jo Driver’s,

‘account at Pinnacle Bank in South Carolina ending x4255.

8. The United States’ Agreements
The United States Attorney’s Office for the Eastern District of Washington

agrees that at the time of sentencing, the United States will move to dismiss Counts
1, 11, 23, and 24, of the Indictment filed on March 6, 2024, which charges
Defendant with Conspiracy to Commit Wire Fraud and Bank Fraud, in violation of
18 U.S.C. §§ 1349, 1343, 1344(1) and (2), False, Fictitious, or Fraudulent Claims,
in violation of 18 U.S.C. § 287, 2, and Bank Fraud, in violation of 18 U.S.C.

§ 1343(1) and (2), respectively.

The United States Attorney’s Office for the Eastern District of Washington
agrees not to bring additional charges against Defendant based on information in
its possession at the time of this Plea Agreement that arise from conduct that is
either charged in the Indictment or identified in discovery produced in this case,
unless Defendant breaches this: Plea Agreement before sentencing.

9. United States Sentencing Guidelines Calculations

Defendant understands and acknowledges that the United States Sentencing
Guidelines (“U.S.S.G.” or “Guidelines”) apply and that the Court will determine
Defendant’s advisory range at the time of sentencing, pursuant to the Guidelines.
The United States and Defendant agree to the following Guidelines calculations.

a. Base Offense Level

The United States and the Defendant agree that the base offense level for
Bank Fraud is 7. U.S.S.G. § 2B1.1(a)(1).

b. Special Offense Characteristics

The United States and the Defendant agree that Defendant’s base offense

level is increased by 10 levels because Defendant’s loss amount is more than
$150,000 and less than $250,000. U.S.S.G. § 2B1.1(b)(F).

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Cc. Acceptance of Responsibility

The United States will recommend that Defendant receive a downward

adjustment for acceptance of responsibility, pursuant to U.S.S.G. § 3E1.1(a), (b), if
Defendant does the following:

i. accepts this Plea Agreement;
il. enters a guilty plea on or before March 26, 2025;
dil. demonstrates recognition and affirmative acceptance of

Defendant’s personal responsibility for Defendant’s
criminal conduct;

iv. provides complete and accurate information during the
sentencing process; and

V. does not commit any obstructive conduct.

The United States and Defendant agree that at its option and on written
notice to Defendant, the United States may elect not to recommend a reduction for
acceptance of responsibility if, prior to the imposition of sentence, Defendant is
charged with, or convicted of, any criminal offense, or if Defendant tests positive
for any controlled substance.

d. Agreements Regarding Representations to the Court
The United States has a duty of candor to the tribunal. If the United States

and Defendant do not agree on the appropriate length of incarceration, the
appropriate length or applicable terms of supervised release, and/or the correct
guidelines calculations, variances, departures, and/or enhancements, the United
States reserves the right to respond to any and all arguments made by Defendant,
on any bases the United States deems appropriate, at all stages of this criminal
case.

Defendant may make any arguments it deems appropriate, at all stages of
this criminal case.

With regard to all briefing, submissions, and hearings in this criminal case,

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the United States and Defendant agree to the following provisions:

i.

il.

iil.

Iv.

Vi.

The United States and Defendant may each respond to
any questions from the Court or United States Probation
Office;

The United States and Defendant may each supplement
the facts under consideration by the Court by providing
information the United States or Defendant deems
relevant;

The United States and Defendant may each present and
argue any additional facts that the United States or
Defendant believe are relevant to the Sentencing
Guidelines computation or sentencing;

The United States and Defendant may each present and
argue information that may already be known to the
Court, including information contained in the
Presentence Investigation Report;

The United States and Defendant may each respond to
any arguments presented by the other;

In order to support the United States’ sentencing
recommendation as set forth herein, the United States
may oppose and argue against any defense argument or
any recommendation for any sentence lower than the
sentence recommended by the United States on any basis,
including arguments for a lower offense level, a lower
criminal history calculation, the application or non-
application of any sentencing enhancement or departure,
and/or any variance from the Guidelines range as

calculated by the Court;

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Vil. In order to support the defense sentencing
recommendation as set forth herein, Defendant may
oppose and argue against any argument by the United
States, or any recommendation for any sentence higher
than the sentence recommended by the defense on any
basis, including arguments for a higher offense level, a
higher criminal history calculation, the application or
non-application of any sentencing enhancement or
departure, and/or any variance from the Guidelines range
as calculated by the Court;

Viii. The United States may make any sentencing arguments
the United States deems appropriate so long as they are
consistent with this Plea Agreement, including arguments
arising from Defendant’s uncharged conduct, conduct set
forth in charges that will be dismissed pursuant to this
Plea Agreement, and Defendant’s relevant conduct; and

ix. Defendant may make any sentencing arguments
consistent with this Plea Agreement Defendant deems
appropriate.

e. No Other Agreements

The United States and Defendant have no other agreements regarding the
Guidelines or the application of any Guidelines enhancements, departures, or
variances.

f. Criminal History

The United States and Defendant have no agreement and make no
representations about Defendant’s criminal history category, which will be
determined by the Court after the United States Probation Office prepares and

discloses a Presentence Investigative Report.

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10. Incarceration

At the time of Defendant’s original sentencing in the District Court, the
United States agrees to make a sentencing recommendation to the Court that is
consistent with this Plea Agreement. The United States’ agreement to make such a
recommendation is limited exclusively to the time of Defendant’s original
sentencing in the District Court. The United States’ agreement to make such a
recommendation does not prohibit or limit in any way the United States’ ability to
argue for or against any future sentencing modification that takes place after
Defendant’s original sentencing in the District Court, whether that modification
consists of an amendment to the Guidelines, a change to a statutory minimum or
maximum sentence, any form of compassionate release, any violation of
Supervised Release, or any other modification that is known or unknown to the
parties at the time of Defendant’s original criminal sentencing. In this Plea
Agreement, the United States makes no promises or representations about what
positions the United States will take or recommendations the United States will
make in any proceeding that occurs after Defendant’s original sentencing in the
District Court.

The United States agrees to recommend a sentence no higher than 16
months of incarceration. Defendant may recommend any legal sentence.

11. Supervised Release

The United States and Defendant each agree to recommend 3 years of
supervised release. Defendant agrees that the Court’s decision regarding the
conditions of Defendant’s Supervised Release is final and non-appealable; that is,
even if Defendant is unhappy with the conditions of Supervised Release ordered by
the Court, that will not be a basis for Defendant to withdraw Defendant’s guilty
plea, withdraw from this Plea Agreement, or appeal Defendant’s conviction,

sentence, or any term of Supervised Release.

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The United States and Defendant agree to recommend that in addition to the
standard conditions of supervised release imposed in all cases in this District, the
Court should also impose the following conditions:

a. The United States Probation Officer may conduct, upon
reasonable suspicion, and with or without notice, a search of
Defendant’s person, residences, offices, vehicles, belongings,
and areas under Defendant’s exclusive or joint control.

b. Defendant will provide financial information and copies of
federal income tax returns, and allow credit checks, at the
direction of the United States Probation Office;

c. Defendant shall disclose all assets and liability to the United

| States Probation Office and shall not transfer, sell, give away,
or otherwise convey or secret any asset, without the advance
approval of the United States Probation Office;

d. Defendant is prohibited from incurring any new debt, opening
new lines of credit, or enter any financial contracts or
obligations without the prior approval of the United States
Probation Office; and

e. Defendant shall participate in and complete financial
counseling and life skills programs at the direction of the
United States Probation Office.

12. Criminal Fine

Defendant may make any recommendation concerning the imposition of a
criminal fine. The United States agrees to recommend the imposition of a criminal
fine in an amount no higher than $55,000. Defendant acknowledges that the
Court’s decision regarding a fine is final and non-appealable; that is, even if

Defendant is unhappy with a fine ordered by the Court, that will not be a basis for

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Defendant to withdraw Defendant’s guilty plea, withdraw from this Plea
Agreement, or appeal Defendant’s conviction, sentence, or fine.

13. Mandatory Special Penalty Assessment

Defendant agrees to pay the $100 mandatory special penalty assessment to
the Clerk of Court for the Eastern District of Washington, pursuant to 18 U.S.C.
§ 3013.

14. Payments While Incarcerated

If Defendant lacks the financial resources to pay any monetary obligations
imposed by the Court, Defendant agrees to earn money toward these obligations by
participating in the Bureau of Prisons’ Inmate Financial Responsibility Program.

15. Additional Violations of Law Can Void Plea Agreement

The United States and Defendant agree that the United States may, at its
option and upon written notice to the Defendant, withdraw from this Plea
Agreement or modify its sentencing recommendation if, prior to the imposition of
sentence, Defendant is charged with or convicted of any criminal offense or tests
positive for any controlled substance.

16. Waiver of Appeal Rights

Defendant understands that Defendant has a limited right to appeal or
challenge Defendant’s conviction and the sentence imposed by the Court.

In return for the concessions that the United States has made in this Plea
Agreement, Defendant expressly waives all of Defendant’s rights to appeal any
aspect of Defendant’s conviction and/or the sentence the Court imposes, on any
grounds.

Defendant expressly waives Defendant’s right to appeal any fine, term of
supervised release, or restitution order imposed by the Court.

Defendant expressly waives the right to file any post-conviction motion
attacking Defendant’s conviction and sentence, including a motion pursuant to 28

U.S.C. § 2255, except one based on ineffective assistance of counsel arising from

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information not now known by Defendant and which, in the exercise of due
diligence, Defendant could not know by the time the Court imposes sentence.
Nothing in this Plea Agreement shall preclude the United States from
opposing any post-conviction motion for a reduction of sentence or other attack
upon the conviction or sentence, including, but not limited to, writ of habeas .
corpus proceedings brought pursuant to 28 U.S.C. § 2255.
17. Withdrawal or Vacatur of Defendant’s Plea

Should Defendant successfully move to withdraw from this Plea Agreement
or should Defendant’s conviction be set aside, vacated, reversed, or dismissed
under any circumstance, then:

a. Any obligations, commitments, or representations made by the
United States in this Plea Agreement shall become null and.
void;

b. The United States may prosecute Defendant on all available
charges;

Cc. The United States may reinstate any counts that have been
dismissed, have been superseded by the filing of another
charging instrument, or were not charged because of this Plea
Agreement; and

d. The United States may file any new charges that would
otherwise be barred by this Plea Agreement.

The decision to pursue any or all of these options is solely in the discretion
of the United States Attorney’s Office.

Defendant agrees to waive any objections, motions, and/or defenses
Defendant might have to the United States’ decisions to seek, reinstate, or reinitiate
charges if a count of conviction is withdrawn, set aside, vacated, reversed, or

dismissed, including any claim alleging a violation of Double Jeopardy.

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Defendant agrees not to raise any objections based on the passage of time,
including but not limited to alleged violations of any statutes of limitation or any
objections based on the Speedy Trial Act or the Speedy Trial Clause of the Sixth
Amendment.

18. Waiver of Attorney Fees and Costs

Defendant agrees to waive all rights Defendant may have under the “Hyde
Amendment,” Section 617, P.L. 105- 119 (Nov. 26, 1997), to recover attorneys’
fees or other litigation expenses in connection with the investigation and
prosecution of all charges in the above-captioned matter and of any related
allegations (including, without limitation, any charges to be dismissed pursuant to
this Plea Agreement or any charges previously dismissed or not brought as a result
of this Plea Agreement).

19. Integration Clause

The United States and Defendant acknowledge that this document
constitutes the entire Plea Agreement between the United States and Defendant,
and no other promises, agreements, or conditions exist between the United States
and Defendant concerning the resolution of the case.

This Plea Agreement is binding only on the United States Attorney’s Office
for the Eastern District of Washington, and cannot bind other federal, state, or local
authorities.

The United States and Defendant agree that this Agreement cannot be
modified except in a writing that is signed by the United States and Defendant.

Approvals and Signatures

Agreed and submitted on behalf of the United States Attorney’s Office for
the Eastern District of Washington.

Richard R. Barker
Acting United States Attorney

Lg 3/26/2025

(Ea AGREEM
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Jeremy J. Kelley Date
Assistant United States Attorney

I have read this Plea Agreement and I have carefully reviewed and discussed
every part of this Plea Agreement with my attorney. I understand the terms of this
Plea Agreement. I enter into this Plea Agreement knowingly, intelligently, and
voluntarily. I have consulted with my attorney about my rights, I understand those
rights, and I am satisfied with the representation of my attorney in this case. No
other promises or inducements have been made to me, other than those contained
in this Plea Agreement. No one has threatened or forced me in any way to enter

into this Plea Agreement. I agree to plead guilty because I am guilty.

Defendant

I have read the Plea Agreement and have discussed the contents of the
agreement with my client. The Plea Agreement accurately and completely sets
forth the entirety of the agreement between the parties. I concur in my client’s
decision to plead guilty as set forth in the Plea Agreement. There is no legal

reason why the Court should not accept Defendant’s guilty plea.

Date

Attorney for Defendant

PLEA AGREEMENT - 18


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550ad1e621e5fe745bf45e1d82733d52318f55cbd71757712d5b147db2217a95

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97-plea-agreement-larsen.pdf

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