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United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 273: Plea agreement, Nathan Reis (Aug. 6, 2025)

Summary

Plea Agreement in United States v. Nathan Reis, No. 4:24-CR-287-O in the Northern District of Texas, Fort Worth Division, Document 273, filed 08/06/25 between the defendant, his attorneys, the Fraud Section and Money Laundering and Asset Recovery Section of the Justice Department's Criminal Division, and the United States Attorney's Office. The defendant waives his trial rights and pleads guilty to Count 1 of the Superseding Indictment, conspiracy to commit wire fraud under 18 U.S.C. 1349, agreeing that his signed factual resume is true. The maximum penalties include imprisonment of up to 20 years, a fine of up to $250,000 or twice the gain or loss, up to 3 years of supervised release, a $100 special assessment, restitution, forfeiture and costs. The agreement notes possible immigration consequences and that the Sentencing Guidelines are advisory.

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“United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 273: Plea agreement, Nathan Reis (Aug. 6, 2025).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/united-states-v-reis-and-hockridge-n-d-tex-no-4-24-cr-00287-o-doc-273-5f7565e53b/, SHA-256 4e878b5bd406d7da7f05590f27aa37a072b8ef972fd65bfc84c92751b94fbe2e.

Full text

Case 4:24-cr-00287-O          Document 273      Filed 08/06/25   Page 1 of 10     PageID 5641



                            IN THE LINITED STATES DISTRICT COURT
                            FOR THE NORTHERN DISTRICT OF TEXAS
                                     FORT WORTH DIVISION

  LINITED STATES OF AMERICA

  v                                                     No. 4:24-CR-287-O

  NATr{AN RErS (01)

                                     PLEA AGREEMENT

         Nathan Reis, the defendant; Kevin Chambers, Matthew Salerno, and Michael

  Heiskell, the defendant's attorneys; and the Money Laundering and Asset Recovery

  Section and the Fraud Section of the Criminal Division of the U.S. Depanment of Justice,

  and the United States Attorney's Office for the Northem District of Texas (collectively,

  the "government") agree as follows:

        1.       Rights of the defendant: The defendant understands that the defendant has

  the rights:

                 a. to plead not guilty;

                 b. to have a trial by jury;

                 c. to have the defendant's guilt proven beyond a reasonable doubt;
                 d. to confront and cross-examine witnesses and to call witnesses in the

                     defendant's defense; and

                 e. against compelled self-incrimination.
         2.      Waiver of rights and plea of guilty: The defendant waives these rights

  and pleads guilty to the offense alleged in Count 1 of the Superseding Indictment,

  charging a violation of 18 U.S.C. $ 1349, that is, Conspiracy to Commit Wire Fraud. The

  defendant understands the nature and elements of the crime to which the defendant is
  Plea Agreement - Page 1
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  pleading guilty and agrees that the factual resume the defendant has signed is true and

  will be submitted as evidence.

         3.      Sentence: The maximum penalties the Court can impose include

                 a. imprisonment for a period not to exceed 20 years;
                 b. a fine not to exceed S250,000, or twice any pecuniary gainto the
                     defendant or loss to the victim(s);

                 c. a term of supervised release of not more than 3 years, which may be
                     mandatory under the law and will follow any term of imprisonment. If
                     the defendant violates the conditions of supervised release, the Court
                     may revoke such release term and required that the defendant serve any
                     or all of such term as an additional period of confinement;

                 d. a mandatory special assessment of $100;
                 e. restitution to victims or to the community, which may be mandatory
                     under the law, and which the defendant agrees may include restitution
                     arising from all relevant conduct;

                 f. forfeiture; and
                 g. costs of incarceration and supervision.
         4.      Immigration consequences: The defendant recognizes that pleading guilty

  may have consequences with respect to the defendant's immigration status if the

  defendant is not a citizen of the United States. Under federal law, a broad range of crimes

  are removable offenses. The defendant understands this may include the offense to which

  the defendant is pleading guilty, and for purposes of this plea agreement, the defendant

  assumes the offense is a removable offense. Removal and other immigration

  consequences ire the subject of a separate proceeding, however, and the defendant

  understands that no one, including the defendant's attorney or the district court, can




  Plea Agreement - Page 2
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  predict to a certainty the effect of the defendant's conviction on the defendant's

  immigration status. The defendant nevertheless affirms that the defendant wants to plead

  guilty regardless of any immigration consequences that the defendant's plea of guilty

  may entail, even if the consequence is the defendant's automatic removal from the United

  States.


            5.   Court's sentencing discretion and role of the Guidelines: The defendant

  understands that the sentence in this case will be imposed by the Court after

  consideration of the United States Sentencing Guidelines. The guidelines are not binding

  on the Court, but are advisory only. The defendant has reviewed the guidelines with the

  defendant's attomey, but understands no one can predict with certainty the outcome of

  the Court's consideration of the guidelines in this case. Pursuant to Federal Rule of

  Criminal Procedure 11(c)(1)(B), the govemment will recommend a sentence no higher

  than the bottom of the applicable advisory guideline range as determined by the Court, or

  120 months, whichever is greater. However, the defendant understands that this

  recorlmendation, if made, is not binding on the Court, and the defendant will not be

  allowed to withdraw the defendant's plea if the recommendation is not adopted, if the

  applicable advisory guideline range is higher than expected, or if the Court departs from

  the applicable guideline range. The defendant fully understands that the actual sentence

  imposed (so long as it is within the statutory maximum) is solely in the discretion of the

  Court.

            6.   Defendant's agreement. The defendant shall not knowingly provide false

  information to the U.S. Probation Office ("USPO"), the Court, or the government relating

  to the offense of conviction and all relevant conduct, or any information the defendant
  Plea Agreement - Page 3
Case 4:24-cr-00287-O        Document 273        Filed 08/06/25      Page 4 of 10     PageID 5644



  must provide related to this agreement.

         7.      Mandatory special assessment: The defendant agrees to pay the U.S.

  District Clerk the amount of $100 in satisfaction of the mandatory special assessment

  prior to sentencing.

         8.      Financial Obligations: The defendant understands that any financial

  obligation imposed by the Court for restitution, fines, or special assessments is due and

  payable immediately. In the event the Court imposes a schedule for payment, the

  defendant agrees that such a schedule represents a minimum payment obligation and does

  not preclude the government from pursuing any other means by which to satisfy the

  defendant's full and immediately enforceable financial obligation. The defendant

  understands that the defendant has a continuing obligation to pay in full as soon as

  possible any financial obligation imposed by the Court. The defendant further agrees as

  follows:

                 a. The defendant agrees that the financial statement, with any supporting
                     documents, the defendant provides to the USPO may be shared with the

                     Court and the government.

                 b. The defendant shall submit to interviews by the government and the
                     USPO regarding the defendant's capacity to satisfy any fine, restitution,

                     or special assessment.

                 c. The defendant expressly authorizes the govemment to immediately
                     obtain a credit report on the defendant to evaluate the defendant's ability

                     to satisfy any financial obligation imposed by the Court.


  Plea Agreement - Page 4
Case 4:24-cr-00287-O        Document 273       Filed 08/06/25      Page 5 of 10        PageID 5645



          9.     Restitution: The defendant agrees that the Court is authorized to order, and

 the defendant agrees to pay, restitution for all loss resulting from the offense of

 conviction and all relevant conduct. The defendant agrees that, for purposes of this

 paragraph, restitution for relevant conduct shall include all acts and omissions described

 in USSG $ 1B1.3(a)(1)(A) and (1)(B), as well as all acts and omissions that were part of

 the same course of conduct or common scheme or plan, regardless whether the grouping

 rules in USSG $ 3D1.2 might apply to computation of the advisory imprisonment range.

 The defendant understands that should the Court order that restitution be paid jointly and

  severally with others who are required to pay restitution for the same loss to victims that

  credit may not be received for all payments made by any other person with joint and

  several liability. The defendant agrees that any restitution ordered to be paid jointly and

  severally remains the responsibility of the defendant until the defendant has paid the

  defendant's ordered amount of restitution in full or the respective victim has been paid in

  tuil.

          10. Forfeiture of property: The defendant agrees not to contest, challenge, or
  appeal in any way the administrative or judicial (civil or criminal) forfeiture to the United

  States of any property noted as subject to forfeiture in the Superseding Indictment. The

  defendant agrees that this property is subject to forfeiture under 18 U.S.C. $ 981(a)(1)(C)

  and28 U.S.C. $ 2a61(c). The defendant consents to entry of any orders or declarations of

  forfeiture regarding such property and waives any requirements (including notice of

  forfeiture) set out in 19 U.S.C. $$ 1607-1609; 18 U.S.C. $$ 981, 983, and 985; the Code

  of Federal Regulations; and Rules 11 and 32.2 of the Federal Rules of Criminal

  Procedure. The defendant agrees to provide truthful information and evidence necessary
  Plea Agreement - Page 5
Case 4:24-cr-00287-O        Document 273       Filed 08/06/25      Page 6 of 10      PageID 5646



  for the govemment to forfeit such property. The defendant agrees to hold the

 govemment, its officers, agents, and employees harmless from any claim whatsoever in

  connection with the seizure, forfeiture, storage, or disposal of such property.

         11. Government's agreement: The government will not bring any additional
  charges against the defendant based upon the conduct underlying and related to the

  defendant's plea of guilty. The govemment will file a Supplement in this case, as is

  routinely done in every case, even though there may or may not be any additional terms.

  The government will dismiss, after sentencing, any remaining charges in the pending

  Superseding Indictment as to the defendant. This agreement is limited to the Money

  Laundering and Asset Recovery Section and the Fraud Section of the Criminal Division

  of the U.S. Department of Justice and the United States Attorney's Office for the

  Northern District of Texas and does not bind any other federal, state, or local prosecuting

  authorities, nor does it prohibit any civil or administrative proceeding against the

  defendant or any property.

          12. Violation of agreement: The defendant understands that if the defendant
  violates any provision of this agreement, or if the defendant's guilty plea is vacated or

  withdrawn, the government will be free from any obligations of the agreement and free to

  prosecute the defendant for all offenses of which it has knowledge, including the

  reinstatement of charges dismissed pursuant to this plea agreement. In the event of such a

  violation, vacatur, or withdrawal, the defendant waives all objections based upon delay in

  prosecution. If the plea is vacated or withdrawn for any reason other than a finding that it

  was involuntary, the defendant also waives all objections to the use against the defendant



  Plea Agreement - Page 6
Case 4:24-cr-00287-O        Document 273        Filed 08/06/25      Page 7 of 10      PageID 5647



  of any information or statements the defendant has provided to the government, and any

  resulting leads.

         13. Voluntary plea: This plea of guilty is freely and voluntarily made and is
  not the result of force or threats, or of promises apart from those set forth in this plea

  agreement. There have been no guarantees or promises from anyone as to what sentence

  the Court will impose.

         14. Waiver of right to appeal or otherwise challenge sentence: The
  defendant waives the defendant's rights, conferred by 28 U.S.C. $ 1291 and 18 U.S.C.

  5 3742, to appeal the conviction, sentence, fine and order of restitution or forfeiture in an

  amount to be determined by the Court. The defendant further waives the defendant's right

  to contest the conviction, sentence, fine and order of restitution or forfeiture in any

  collateral proceeding, including proceedings under 28 U.S.C. 5 2241 and 28 U.S.C.

  5 2255. The defendant, however, reserves the rights (a) to bring a direct appeal of (i) a

  sentence exceeding the statutory maximum punishment, (ii) an arithmetic error at

  sentencing, or (iii) the loss amount determined by the Court for purposes of USSG $

  281.1(b)(1) if the Court finds that it exceeds $3,500,000; (b) to challenge the

  voluntariness of the defendant's plea of guilty or this waiver, and (c) to bring a claim of

  ineffective assistance of counsel.

        15.      Representation of counsel: The defendant has thoroughly reviewed all

 legal and factual aspects of this case with the defendant's attorney and is fully satisfied with

that attomey's legal representation. The defendant has received from the defendant's

 attorney explanations satisfactory to the defendant concerning each paragraph of this plea


  Plea Agreement - Page 7
Case 4:24-cr-00287-O            Document 273               Filed 08/06/25               Page 8 of 10                 PageID 5648




       a$recrn{int. e*sh t}l"th* defhndant'r
                                               rig,h{* 1r]Flbi;l*<l by thi:,r agr*cl1cnt. nlrrJ t}re alterr*atives

       ftYei'shle t* tlm r*gfl*r*!$$t oth*r thnn
                                                   mrl*ring int<i rhis eg/cernent" llu,;*u*e rh* *tefmndanl
       con*ed*s thsi t?re de{bmdant is guilty. *ln6 *{1*r, r.onltrring wrlh Nhe dc.;*ndalrt'* afirrrnryy. l&,1,

       delknd*r: Ims a*nclutlett &*r iI is in the rlefs*d*nt's lrcst int*rest t$ *nt*r intri thie pl*a

       a$feemeni and all ils ternls, rather than to proceed t$ lri&l i* this c.ase.

                  iS" Entirety of agreement: Tkis document, incl.uding any Supplrr.':€fir fiisd
        sfilterr4xlra&eously, is a courplete ststement of the parties ' s,gr".ement a*d r*ay n.*t b*

        modified unless tlre modification is in writing and signcd by all parties. Thls agreemen;
                                                                               .



        supersedes any and all other promisesr rcpresentafions, undsrstandings, and agreernents

        t&*t wo ar wEre nade between the parties at arry time before the guilty plea is eoter*d jn

        eoiut No promises or represantatioss have bseri rrade by the United States except as *et

        iilrth i$ uriting in this plea agreemenl

                  AGREED T0 AND SIGNED this              {& duy or                                  2425"

                                                         NANCY E" LARSON
                                                         ACTI}EG                   STATE$ATTORNHY




                                                         Assistant United $tateu Atorney
                                                         State Bar of Texas No. ?4 t 0264;
                                                         Telephona I I ?-252-5200
                                                         Fax 8l?-252-5455
                                                         Email m*tdrew.weybrecirt@us,Joj.gov


        -..r::.
        h/tAl-Tt{filry $iALpfiX#
        MICHAhJ- HEISKFJI,I"
       fr.fton?fiy$ *irr}*&mdmr



       Prt* &gr**ws*t* **g* S




                                                                                                                                   I
Case 4:24-cr-00287-O        Document 273     Filed 08/06/25        Page 9 of 10   PageID 5649



                                           LORINDA LARYEA
                                           ACTING CHIEF, FRAUD SECTION
                                           Criminal Division, U.S. Department of Justice

                                           lsl Philip Trout
                                           PHILIP TROUT
                                           Acting Assistant Chief, Fraud Section
                                           Criminal Division, U.S. Department of Justice
                                           Telephone : 202-61 6-6989
                                           Fax:202-514-0152
                                           Email : Philip. Trout@usdoj gov
                                                                       .




                                           MARGARET A. MOESER
                                           CHIEF, MONEY LALTNDERING & ASSET
                                           RECOVERY SECTION
                                           Criminal Division, U.S. Department of Justice

                                           lsl Elizabeth R. Carr
                                           ELTZABETH R. CARR
                                           RYAN MCLAREN
                                           Trial Attorneys, Money Laundering & Asset
                                           Recovery Section
                                           Criminal Division, U.S. Department of Justice
                                           Telephone : 202-81 5 -l 53 5
                                           Email : Elizabeth. carr@usdoj. gov




  Plea Agreement - Page 9
Case 4:24-cr-00287-O             Document 273   Filed 08/06/25   Page 10 of 10   PageID 5650




                                                _7
                                                     Date



            &e dcf'mds*t's afrorney" I have carefully rwirrryed wery part of this plea
         X nxr

 B*twaslrt wi& tfus de&xdffit" To my knowtedge and betief, my cliort's dceision io snrer
 ir*s&is pXea apren**nt is an ilrformed ard voluntary one"


         frs{er\d&&efi
 eeegrsxsw sALE*No
 MICHAELHEISKELL
 Atrsrr€ys for Defendant




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