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.
Summary drafted by a model from the document's text below 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
Cite this document
“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
Case 4:24-cr-00287-O Document 273 Filed 08/06/25 Page 2 of 10 PageID 5642
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
Case 4:24-cr-00287-O Document 273 Filed 08/06/25 Page 3 of 10 PageID 5643
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
)!^* .
'oa egreeerenr _ pase
lti
File and source
- File
- gov.uscourts.txnd.396981.273.0.pdf
- Size
- 7,301,714 bytes
- SHA-256
- 4e878b5bd406d7da7f05590f27aa37a072b8ef972fd65bfc84c92751b94fbe2e
- Original
- No public link identified.