Case 1:22-cr-00074-PB Document 39 Filed 10/13/22 Page 1 of 16

FILED - USDC -NH

2022 OCT 13 HM8*3b

UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

UNITED STATES OF AMERICA )

)
V. ) No. l:22-cr-74-PB-01
)
PIERRE ROGERS )

PLEA AGREEMENT

Pursuant to Rules 1 1(c)(1)(A) and(C)of the Federal Rules of Criminal Procedure, the

United States of America by its attorney, Jane E. Young, United States Attorney for the District

of New Hampshire, and the defendant, Pierre Rogers, and the defendant’s attorney, Diane Bass,

Esquire, enter into the following Plea Agreement:

1. The Plea and The Offense.

I'he defendant agrees to waive his right to have this matter presented to a grand jury and

plead guilty to a Superseding Information charging him with Conspiracy to Commit Wire Fraud

and Bank Fraud, in violation of 18 U.S.C. § 1349.

In exchange for the defendant’s guilty plea, the United States agrees to the sentencing

stipulations identified in Section 6 of this agreement. The United States also agrees to move to

dismiss all Counts with respect to the defendant in the underlying indictment when the defendant

is sentenced.

2. The Statute and Elements of the Offense.

Title 18, United States Code, Section 1349 provides, in pertinent part:

Any person who . . . conspires to commit any offense under this

chapter shall be subject to the same penalties as those prescribed
for the offense, the commission of which was the object of the
attempt or conspiracy.

18 U.S.C. § 1349.
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The defendant understands that the offense has the following elements, each of which the

United States would be required to prove beyond a reasonable doubt at trial:

First, that the agreement specified in the indictment, and not some other agreement or
agreements, existed between at least two people to commit bank fraud and wire fraud;
and

Second, that the defendant willfully joined in that agreement.

Paltern Criminal Jury Instruclionsfor the District Courts ofthe First Circuit, District ofMaine
Internet Site Edition, 2022 Revisions, Instructions 4.18.1349 and 4.18.371(1).'
https://www.med.uscouits.aov/sites/med/nics/crpi ilinks.pdf.

The underlying substantive offense of bank fraud, Title 18, United States Code, Section

1344 provides, in pertinent part:

Whoever knowingly executes, or attempts to execute, a scheme or artifice-

(1) to defraud a llnancial institution; or

(2) to obtain any of the moneys, funds, credits, assets, securities, or other property
owned by, or under the custody or control of, a financial institution, by means of
false or fraudulent pretenses, representations, or promises;

shall be fined not more than $ 1,000,000 or imprisoned not more than 30 years, or both.

The defendant understands that the offense has the following elements:

First, that there was a scheme as substantially charged in the indictment to defraud a
financial institution;

Second, that the defendant knowingly and willfully participated in this scheme with the
intent to defraud; and

Third, that the financial institution was federally insured or was a federal reserve bank or
a member of the federal reserve system.

Pattern Criminal Jury Instructionsfor the District Courts ofthe First Circuit, District ofMaine
Internet Site Edition, 2022 Revisions, Instruction 4.18.1344, available at
https://ww\v.med.uscouils.iiov/sites/med/nics/crpiilinks.pdf

' Proof of an overt act is not an element of conspiracy under 18 U.S.C. § 1349. See United Slates v.
/uWfl,789 F.3d I, 9-10 (1st Cir. 2015); accord United States v. Roy, 783 F.3d 418, 420-21 (2d Cir. 2015).

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The underlying substantive offense of wire fraud, Title 18, United States Code, Section

1343 provides:

Whoever, having devised or intending to devise any scheme or

artifice to defraud, or for obtaining money or property by means of
false or fraudulent pretenses, representations, or promises,
transmits or causes to be transmitted by means of[interstate] wire .
.. shall be fined under this title or imprisoned not more than 20
years, or both.

The defendant understands that the offense has the following elements:

First, that there was a scheme, substantially as charged in the indictment, to obtain money
or property by means of false or fraudulent pretenses;

Second, that the scheme to obtain money or property by means of false or fraudulent
pretenses involved a false statement, assertion, half-truth or knowing concealment concerning a
material fact or matter:

Third, that the defendant knowingly and willfully participated in this scheme with the
intent to defraud; and

Fourth,that for the purpose of executing the scheme or in furtherance of the scheme, the
defendant caused an interstate wire communication to be used, or it was reasonably foreseeable
that for the purpose of executing the scheme or in furtherance of the scheme, an interstate wire
communication would be used, on or about the date alleged.

Pattern Criminal Jury Instructionsfor the District Courts ofthe First Circuit, District ofMaine
Internet Site Edition, 2021 Revisions, Instruction 4.18.1343,
https://www.med.iiscoiirts.izov/sites/med/l1les/crpiilinks.Ddf.

3. Offense Conduct.

The defendant stipulates and agrees that if this case proceeded to trial, the government

would introduce evidence of the following facts, which would prove the elements of the offense

beyond a reasonable doubt:

TD Bank was a financial institution as defined by 18 U.S.C. § 20, the deposits of which

were insured by the Federal Deposit Insurance Corporation.

The defendant owned or controlled the companies called Monticello Transnational and

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Sunju. The defendant and his co-conspirator, Joshua Leavitt,jointly owned or controlled

multiple companies, including Puro Trader (d/b/a Yahyn), Puro Lounge, and Puro Group.

These companies had business addresses or operations in New Hampshire.

The United States Small Business Administration (“SBA”) is an executive- branch

agency of the United States government that provides support to entrepreneurs and small

businesses.

In or around March 2020, the Coronavirus Aid, Relief, and Economic Security

(“CARES”) Act was enacted to provide emergency financial assistance to the millions of

Americans suffering adverse economic effects caused by the COVID-19 pandemic. The CARES

Act established several new temporary programs and expanded existing programs, including

programs created or administered by the SBA.

One source of relief provided by the CARES Act was the authorization of forgivable

loans to small businesses for job retention and certain other expenses, through a program referred

to as the Paycheck Protection Program (“PPP”).

To obtain a PPP loan, the authorized representative of a business was required to state the

business’s average monthly payroll expenses and number of employees. These figures were used

to calculate the amount of money the small business was eligible to receive under the PPP.

A participating lender would then process the PPP loan application. If the PPP loan

application was approved, the participating lender funded the PPP loan using its own monies,

which were fully guaranteed by the SBA.

TD Bank participated in the PPP as a lender to small businesses.

Between on or about April 6, 2020, and continuing through on or about January 21,2021,

the defendant agreed with Leavitt to provide false information to TD Bank in PPP loan

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applications. Leavitt prepared supporting documents, including purported tax filings, which

provided false information about their companies' payroll and earnings.

For example, on or about May 6, 2020, Leavitt submitted a $175,000 PPP loan

application and provided supporting documents to TD Bank for Puro Group. The application

claimed that Puro Group’s monthly payroll was $70,000 and that the company had six

employees. The defendant initialed, certified, and signed the application. The defendant knew

the application and supporting documents contained false infonnation.

One of the documents was a false IRS Form 941, or quarterly tax return, for Q1 2020.

The document claimed that Puro Group had paid five employees $209,999.99 in Q1 2020 and

paid $27,600 in federal income tax that quarter. However, that document was never filed with

the IRS. The actual tax document filed with the IRS showed that Puro Group paid $48,255.53

to its employees during the entire calendar year of 2020, or approximately $4,000 per month.

Another supporting document was a purported “Payroll Summary” that showed five

employees earning $209,999.99 during Q1 2020. However, this “Payroll Summary” was

identical to another “Payroll Summary” that was submitted in connection with a different PPP

loan application for Sunju.

TD Bank granted the loan application. The defendant used $107,780 of the PPP loan

funds to purchase a 2011 Rolls Royce Ghost with a VIN ending in -0157.

The Economic Injury Disaster Loan (“EIDL”) program was another source of financial

assistance provided by the CARES Act. It provided low-interest financing to small businesses.

renters, and homeowners in regions affected by declared disasters. The EIDL program was

administered by the SBA.

The CARES Act authorized the SBA to provide EIDLs to eligible small businesses

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experiencing substantial financial disruptions due to the COVID-19 pandemic. In addition, the

CARES Act authorized the SBA to issue advances of up to $10,000 to small businesses, known

as Economic Injui'y Disaster Grants (ElDGs). The amount of the advance was determined by

the number of employees the applicant certified having. The advances did not need to be

repaid.

To obtain an EIDL and/or EIDG, a qualifying business was required to apply to the SBA

and provide information about its operations, such as the number of employees and the entity’s

gross business revenues and cost of goods sold in the 12 months prior to January 31, 2020. The

amount of the loan, if approved, was determined based, in part, on the information provided

concerning the number of employees, gross revenue, and cost of goods.

Any funds issued under an EIDL or EIDG were issued directly by the SBA. EIDL funds

could be used for payroll expenses, sick leave, production costs, and business obligations, such

as debts, rent, and mortgage payments.

Between on or about March 30, 2020, and continuing through on or about November 23,

2021, the defendant agreed with Leavitt to provide false information to the SBA in EIDL

applications.

For example, on or about March 31,2020, Leavitt electronically submitted an EIDL

application for Monticello Transnational that was received by an SBA server in the Des Moines,

Iowa, area. The defendant was the sole owner and CEO of the company. The defendant knew

that the application included false information about Monticello Transnational’s payroll and

earnings.

The application falsely claimed that Monticello Transnational’s gross revenues for the 12

months preceding January 31, 2020, was $75,000, that the cost of goods sold in that same time

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period was $3,000, and that the company had seven employees. Bank records show that

Monticello Transnational only had a few thousand dollars’ worth of deposits in 2019 and January

2020 and that there were no payments to employees. IRS records show that no tax filings were

submitted for Monticello Transnational for 2019 or the first quarter of 2020. The SBA relied on

the false representations in awarding a $29,000 EIDL and a $7,000 EIDG to Monticello

Transnational.

Overall, the intended loss in this scheme was at least $3.5 million.

4. Penalties. Special Assessment and Restitution.

The defendant understands that the penalties for the offense are:

A. With respect to conspiracy to commit bank fraud, a maximum prison term of 30

years(18 U.S.C. §§ 1349, 1344), and, with respect to conspiracy to commit wire
fraud, a maximum prison term of20 years(18 U.S.C. §§ 1349, 1343);

B. With respect to conspiracy to commit bank fraud, a maximum fine of $1 million

(18 U.S.C. §§ 1349, 1344), and, with respect to conspiracy to commit wire fraud,
a maximum fine of $250,000 or twice the gross gain or loss, whichever is greater
(18 U.S.C. §§ 1349, 3571(b)(3) or (d));

C. With respect to conspiracy to commit bank fraud, a term ofsupervised

release of not more than five years (18 U.S.C. §§ 1349; 3583(b)(1);
3559(a)(2)), and, with respect to conspiracy to commit wire fraud, a term
of supervised release of not more than 3 years (18 U.S.C. §§
1349; 3559(a)(3); 3583(b)(2)). The defendant understands that the
defendant’s failure to comply with any of the conditions of supervised
release may result in revocation of supervised release, requiring the
defendant to serve in prison all or part of the term of supervised release,
with no credit for time already spent on supervised release; and

D. A mandatory special assessment of$100, $100 for each count of conviction, at or

before the time of sentencing (18 U.S.C. § 3013(a)(2)(A)); and

E. In addition to the other penalties provided by law, the Court may order the
defendant to pay restitution to the victim(s) of the offense (18 U.S.C. § 3663 or §
3663A).

To facilitate the payment and collection of any restitution that may be ordered, the
defendant agrees that, upon request, he will provide the United States with a

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financial disclosure statement and supporting financial documentation.

The defendant further agrees that, if restitution is ordered, it shall be due and
payable immediately after the judgment is entered and is subject to immediate
enforcement, in full, by the United Stales. If the Court imposes a schedule of
payments, the defendant agrees that the schedule of payments is a schedule of the
minimum payment due, and that the payment schedule does not prohibit or limit
the methods by which the United States may immediately enforce thejudgment in
full, including, but not limited to, the Treasury Offset Program.

5. Sentencing and Application of the Sentencing Guidelines.

The defendant understands that the Sentencing Reform Act of 1984 applies in this case

and that the Court is required to consider the United Slates Sentencing Guidelines as advisory

guidelines. The defendant further understands that he has no right to withdraw from this Plea

Agreement if the applicable advisory guideline range or his sentence is other than he anticipated.

The defendant also understands that the United States and the United States Probation

Office shall:

A. Advise the Court of any additional, relevant facts that are presently known
or may subsequently come to their attention;

B. Respond to questions from the Court;

C. Correct any inaccuracies in the pre-sentence report;

D. Respond to any statements made by him or his counsel to a probation

officer or to the Court.

The defendant understands that the United States and the Probation Office may address

the Court with respect to an appropriate sentence to be imposed in this case.

The defendant acknowledges that any estimate of the probable sentence or the probable

sentencing range under the advisory Sentencing Guidelines that he may have received from any

source is only a prediction and not a promise as to the actual sentencing range under the advisory

Sentencing Guidelines that the Court will adopt.

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6. Sentencing Stipulations and Agreements.

Pursuant to Fed. R. Crim. 1 1(c)(1)(C), the United States and the defendant stipulate and

agree to the following:

(a) A sentence to 41 months' imprisonment is an appropriate disposition of

this case; and

(b) The defendant is jointly and severally liable for no less than $803,756.00

in restitution, of which $607,756.00 is payable to TD Bank and

$196,000.00 is payable to the Small Business Administration.

The parties intend the above stipulations to be “binding” under Fed. R. Crim. P.

11(c)(1)(C). By using the word binding the parties mean that if the Court will not accept the plea

agreement under Fed. R. Crim. P. 1 1(c)(3)(A), the plea agreement is null and void and the

defendant will be allowed the opportunity to withdraw his guilty plea.

The parties are free to make recommendations with respect to the terms of imprisonment,

fines, conditions of probation or supervised release, and any other penalties, requirements, and

conditions of sentencing as each party may deem lawful and appropriate, unless such

recommendations are inconsistent with the terms of this Plea Agreement.

7. Acceptance of Responsibility.

The United States agrees that it will not oppose an appropriate reduction in the

defendant's adjusted offense level, under the advisory Sentencing Guidelines, based upon the

defendant’s apparent prompt recognition and affirmative acceptance of personal responsibility

for the offense. The United States, however, may oppose any adjustment for acceptance of

responsibility if the defendant:

A. Fails to admit a complete factual basis for the plea at the time he is
sentenced or at any other time;

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B. Challenges the United States' offer of proof at any time after the plea is
entered;

C. Denies involvement in the offense;

D. Gives conflicting statements about that involvement or is untruthful with

the Court, the United States or the Probation Office;

E. Fails to give complete and accurate information about his financial status
to the Probation Office;

F. Obstructs or attempts to obstruct justice, prior to sentencing;

G. Has engaged in conduct prior to signing this Plea Agreement which

reasonably could be viewed as obstruction or an attempt to obstruct
justice, and has failed to fully disclose such conduct to the United States
prior to signing this Plea Agreement;

H. Fails to appear in court as required;

I. After signing this Plea Agreement, engages in additional criminal conduct;

or

J. Attempts to withdraw his guilty plea.

The defendant understands and agrees that he may not withdraw his guilty plea if, for any

of the reasons listed above, the United States does not recommend that he receive a reduction in

his sentence for acceptance of responsibility.

The defendant also understands and agrees that the Court is not required to reduce the

offense level if it finds that he has not accepted responsibility.

If the defendant’s offense level is sixteen or greater, and he has assisted the United States

in the investigation or prosecution of his own misconduct by timely notifying the United States

of his intention to enter a plea of guilty, thereby permitting the United States to avoid preparing

for trial and permitting the United States and the Court to allocate their resources efficiently, the

United States will move, at or before sentencing, to decrease the defendant’s base offense level

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by an additional one level pursuant to U.S.S.G. § 3E 1.1(b).

8. Waiver of Trial Rights and Consequences of Plea.

I'he defendant understands that he has the right to be represented by an attorney at every

stage of the proceeding and, if necessary, one will be appointed to represent him. The defendant

also understands that he has the right:

A. To plead not guilty or to maintain that plea if it has already been made;

B. To be tried by a jury and, at that trial, to the assistance of counsel;

C. To confront and cross-examine witnesses;

D. Not to be compelled to provide testimony that may incriminate him; and

E. To compulsory process for the attendance of witnesses to testify in his

defense.

The defendant understands and agrees that by pleading guilty he waives and gives up the

foregoing rights and that upon the Court’s acceptance of his guilty plea, he will not be entitled to

a trial.

The defendant understands that if he pleads guilty, the Court may ask him questions

about the offense, and if he answers those questions falsely under oath, on the record, and in the

presence of counsel, his answers will be used against him in a prosecution for perjury or making

false statements.

9. Acknowledgment of Guilt: Voluntariness of Plea.

The defendant understands and acknowledges that he:

A. Is entering into this Plea Agreement and is pleading guilty freely and voluntarily because
he is guilty;

B. Is entering into this Plea Agreement without reliance upon any promise or benefit of any
kind except as set forth in this Plea Agreement or revealed to the Court;

C. Is entering into this Plea Agreement without threats, force, intimidation, or coercion;
 Case 1:22-cr-00074-PB Document 39 Filed 10/13/22 Page 12 of 16

D. Understands the nature of the offense to which he is pleading guilty,

including the penalties provided by law; and

E. Is completely satisfied with the representation and advice received from

his undersigned attorney.

10. Scope of Agreement.

The defendant acknowledges and understands that this Plea Agreement binds only the

undersigned parties and cannot bind any other non-party federal, state or local authority. The

defendant also acknowledges that no representations have been made to him about any civil or

administrative consequences that may result from his guilty plea. The defendant understands

such matters are solely within the discretion of the specific non-party government agency

involved. The defendant further acknowledges that this Plea Agreement has been reached

without regard to any civil tax matters that may be pending or which may arise involving the

defendant.

11. Collateral Consequences.

The defendant understands that as a consequence of his guilty plea he will be adjudicated

guilty and may thereby be deprived of certain federal benefits and certain rights, such as the right

to vote, to hold public office, to serve on a jury, or to possess firearms.

The defendant understands that, if he is not a citizen of the United States, his guilty plea

to the charged offense will likely result in him being subject to immigration proceedings and

removed from the United States by making him deportable, excludable, or inadmissible. 'I'he

defendant also understands that if he is a naturalized citizen, his guilty plea may result in ending

his naturalization, which would likely subject him to immigration proceedings and possible

removal from the United States. The defendant understands that the immigration consequences

of this plea will be imposed in a separate proceeding before the immigration authorities. The

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defendant wants and agrees to plead guilty to the charged offense regardless of any immigration

consequences of this plea, even if this plea will cause his removal from the United States. The

defendant understands that he is bound by his guilty plea regardless of any immigration

consequences of the plea. Accordingly, the defendant waives any and all challenges to his guilty

plea and to his sentence based on any immigration consequences and agrees not to seek to

withdraw his guilty plea, or to file a direct appeal or any kind of collateral attack challenging his

guilty plea, conviction, or sentence, based on any immigration consequences of his guilty plea.

12. Satisfaction of Federal Criminal Liability: Breach.

The defendant’s guilty plea, if accepted by the Court, will satisfy his federal criminal

liability in the District of New Hampshire arising from his participation in the conduct that forms

the basis of the Superseding Information in this case.

The defendant understands and agrees that, if after entering this Agreement, he fails

specifically to perform or fulfill completely each one of his obligations under this Agreement,

fails to appear for sentencing, or engages in any criminal activity prior to sentencing, he will

have breached this Agreement.

If the United States, in its sole discretion, and acting in good faith, determines that the

defendant committed or attempted to commit any further crimes, failed to appear for sentencing.

or has otherwise violated any provision of this Agreement, the United States will be released

from its obligations under this Agreement, including, but not limited to, any agreement it made

to dismiss charges, forbear prosecution of other crimes, or recommend a specific sentence or a

sentence within a specified range. The defendant also understands that he may not use his breach

of this Agreement as a reason to withdraw his guilty plea or as a basis to be released from his

guilty plea.

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13. Waivers.

A. Appeal.

The defendant understands that he has the right to challenge his guilty plea and/or

sentence on direct appeal. By entering into this Plea Agreement the defendant knowingly and

voluntarily waives his right to challenge on direct appeal:

1. His guilty plea and any other aspect of his conviction, including, but not
limited to, adverse rulings on pretrial suppression motion(s) or any other
adverse disposition of pretrial motions or issues; or claims challenging the
constitutionality of the statute of conviction; and

2. The sentence imposed by the Court if it is consistent with or lower than

the stipulated sentence specified in Section 6 of this agreement.

The defendant’s waiver of his rights does not operate to waive an appeal based upon new

legal principles enunciated in Supreme Court or First Circuit case law after the date of this Plea

Agreement that have retroactive effect; or on the ground of ineffective assistance of counsel.

B. Collateral Review

The defendant understands that he may have the right to challenge his guilty plea and/or

sentence on collateral review, e.g., a motion pursuant to 28 U.S.C. §§ 2241 or 2255. By

entering into this Plea Agreement, the defendant knowingly and voluntarily waives his right to

collaterally challenge:

1. His guilty plea, except as provided below, and any other aspect of his
conviction, including, but not limited to, adverse rulings on pretrial
suppression motion(s) or any other adverse disposition of pretrial motions
or issues, or claims challenging the constitutionality of the statute of
conviction; and

2. The sentence imposed by the Court if it is consistent with the stipulated

sentence specified in Section 6 of this agreement.

The defendant’s waiver of his right to collateral review does not operate to waive a

collateral challenge to his guilty plea on the ground that it was involuntary or unknowing, or on

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the ground of ineffective assistance of counsel. The defendant’s waiver of his right to collateral

review also does not operate to waive a collateral challenge based on new legal principles

enunciated by in Supreme Court or First Circuit case law decided after the date of this Plea

Agreement that have retroactive effect.

C. Freedom of Information and Privacy Acts

The defendant hereby waives all rights, whether asserted directly or through a

representative, to request or receive from any department or agency of the United States any

records pertaining to the investigation or prosecution of the case(s) underlying this Plea

Agreement, including without limitation any records that may be sought under the Freedom of

Information Act, 5 U.S.C. §552, or the Privacy Act of 1974, 5 U.S.C. §522a.

D. Appeal by the Government

Nothing in this Plea Agreement shall operate to waive the rights or obligations of the

Government pursuant 18 U.S.C. § 3742(b) to pursue an appeal as authorized by law.

14. No Other Promises.

The defendant acknowledges that no other promises, agreements, or conditions have been

entered into other than those set forth in this Plea Agreement or revealed to the Court, and none

will be entered into unless set forth in writing, signed by all parties, and submitted to the Court.

15. Final Binding Agreement.

None of the terms of this Plea Agreement shall be binding on the United States until this

Plea Agreement is signed by the defendant and the defendant’s attorney and until it is signed by

the United States Attorney for the District of New Hampshire, or an Assistant United States

Attorney.

16. Agreement Provisions Not Severable.

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The United States and the defendant understand and agree that if any provision of this

Plea Agreement is deemed invalid or unenforceable, then the entire Plea Agreement is null and

void and no part of it may be enforced.

JANE E. YOUNG
United States Attorney

10/12/2022
Date: By:.
Alexander S. Chen
Special Assistant United States Attorney
MA Bar Association #698458
53 Pleasant St, 4th Floor
Concord, NH 03301
[email protected]

The defendant, Pierre Rogers, certifies that he has read thi^l 6-page Plea Agreement and
that he fully understands and accepts its terms. \

0.10/10/22 Pj^e Roger^ D^endant

I have read and explained this 16-page Plea Agreemen ;he defendant, and he has
advised me that he understands and accepts its terms.

Date: 10/12/22
Diane Bass, Esquire
Attorney for Pierre Rogers

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