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U.S. v. Todd A. Boulanger

U.S. v. Todd A. Boulanger

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The plea agreement of Todd A. Boulanger, 37, a former associate of disgraced lobbyist Jack Abramoff who pleaded guilty to honest services violations last week. Page 25 of the document refers to "Staffer F" -- a former top staff member to Sen. Judd Gregg (R-N.H.) who allegedly accepted more than $10,000 in tickets, meals and drinks in exchange for official actions favorable to Abramoff's lobbying clients. Gregg is President Obama's choice to be commerce secretary.


The plea agreement of Todd A. Boulanger, 37, a former associate of disgraced lobbyist Jack Abramoff who pleaded guilty to honest services violations last week. Page 25 of the document refers to "Staffer F" -- a former top staff member to Sen. Judd Gregg (R-N.H.) who allegedly accepted more than $10,000 in tickets, meals and drinks in exchange for official actions favorable to Abramoff's lobbying clients. Gregg is President Obama's choice to be commerce secretary.


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Published by: Washington Post Investigations on Feb 05, 2009
Copyright:Attribution Non-commercial

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05/10/2014

 
UNITED STATES DISTRICT COURTDISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
)
Criminal Number:
)
v )
ount One:
)
18 U.S.C.
§
371
TODD A. BOULANGER,
)
(Conspiracy)
)
Defendant.
)
PLEA AGREEMENT
The United States of America, by and through the undersigned attorneys for the Public
Integrity Section. Criminal Division, United States Department of Justice, and Todd A. Boulanger(hereinafter referred to as the 'defendant") enter into the following agreement:
Charges and Statutory Penalties
The defendant agrees to plead guilty to Count One of the Information, conspiracy to commit
honest services wire fraud, in violation of Title 18, United States Code, Section 371.
2. The defendant understands that Count One has the following essential elements, each of
which the United States would be required to prove beyond a reasonable doubt at trial:
a. First, an agreement between two or more persons to commit an offense against theUnited States, that is, devising and intending to devise a scheme and artifice to
defraud another of the intangible right to honest services, and, for the purpose of
executing that scheme and artifice to defraud, transmitting and causing to transmitwritings by means of interstate wire communications;
 
b. Second, that the defendant knowingly participated in the conspiracy described in
paragraph a. above with the intent to commit honest services fraud; and
c. Third, an overt act in furtherance of the conspiracy.
3. The defendant understands that pursuant to Title 18, United States Code, Section 371, Count
One carries a maximum sentence of 5 years of imprisonment, a fine of $250,000 or a fine
of twice the pecuniary gain or loss pursuant to 18 U.S.C. § 3571(d), a $100 special
assessment, and a three-year term of supervised release, an order of restitution, and an
obligation to pay any applicable interest or penalties on fines or restitution not timely made.
4. lfthe Court accepts the defendant's plea of guilty and the defendant fulfills each of the terms
and conditions of this agreement, the United States agrees that it will not further prosecute
the defendant for any crimes described in the attached factual basis or for any conduct of the
defendant now known to the Public Integrity Section and to the law enforcement agents
working with the Public Integrity Section on the present investigation. Nothing in this
agreement is intended to provide any limitation of liability arising out of any acts of
violence.
Factual Stipulations
5.
The defendant agrees that the attached 'Factual Basis for Plea" fairly and accurately
describes the defendant's actions and involvement in the offense to which the defendant is
pleading guilty. The defendant knowingly, voluntarily and truthfully admits the facts set
forth in the Factual Basis for Plea.
2
 
Sentencing
6. The defendant is aware that the sentence will be imposed by the Court after considering the
Federal Sentencing Guidelines and Policy Statements (hereinafter "Sentencing Guidelines"
or "U.S.S.G."). The defendant acknowledges and understands that the Court will compute
an advisory sentence under the Sentencing Guidelines and that the applicable guidelines will
be determined by the Court relying in part on the results of a Pre-Sentence Investigation by
the Court's Probation Office, which investigation will commence after the guilty plea has
been entered. The defendant is also aware that, under certain circumstances, the Court may
depart from the advisory sentencing guideline range that it has computed, and may raise that
advisory sentence up to and including the statutory maximum sentence or lower that
advisory sentence. The defendant is further aware and understands that the Court is required
to consider the advisory guideline range determined under the Sentencing Guidelines, butis not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence
in light of other statutory concerns, and such sentence may be either more severe or less
severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the
defendant understands and acknowledges that the Court has the authority to impose any
sentence within and up to the statutory maximum authorized by law for the offense identified
in paragraph I and that the defendant may not withdraw the plea solely as a result of the
sentence imposed.
7. The United States reserves the right to inform the Court and the Probation Office of all facts
pertinent to the sentencing process, including all relevant information concerning the
offenses committed, whether charged or not, as well as concerning the defendant and the
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