UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANASOUTH BEND DIVISIONUNITED STATES OF AMERICA))v.) CAUSE NUMBER: 3:12-cr-00018-RLM)STEPHEN P. SACHS )
PETITION TO ENTER A GUILTY PLEA
The defendant above named respectfully represents to the Court as follows:1.My full true name is
STEPHEN P. SACHS
and I request that all proceedings against me be had in the name which I here declare to be my true name.2.I was born in the United States of America. I attended school and have theability to read, write, and speak the English language.3.I am represented by counsel. My lawyer's name is ROXANNE M.JOHNSON.4.I have received a copy of the Indictment filed February 12, 2012, and haveread and discussed it with my lawyer, and believe and feel that I understand everyaccusation made against me in this case.5.I have told my lawyer the facts and surrounding circumstances as known tome concerning the matters mentioned in the Indictment and believe and feel that mylawyer is fully informed as to all such matters. My lawyer has since informed me and hascounseled and advised with me as to the nature and cause of every accusation against me1
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and as to any possible defenses I might have in this case.6.I understand that I am entitled to have all of my rights which may beinvolved in this matter explained to me, and that I have the right to have any questions Imay have answered for me.7.I understand that I have a right to plead NOT GUILTY to any offensecharged against me, and that under a plea of NOT GUILTY the Constitution guaranteesme:(a)the right to a speedy and public trial by a twelve-person jury of my peers,selected according to law, in the Northern District of Indiana which mustreturn a unanimous verdict of GUILTY before I can be convicted;(b)the right to be released on reasonable bail until my trial occurs;(c)the right to see, hear and cross-examine all the witnesses against me at mytrial;(d)the right to use the power and process of the Court to compel the productionof any evidence, including the attendance of any witnesses, in my favor atmy trial;(e)the right to the assistance of counsel at every stage of the proceedings,including upon appeal if need be;(f)the right not to testify without prejudice; and,(g)that in the event that I should be found GUILTY of the charge against me, I2
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would have the right to appeal my conviction on such charge to a higher court.8.I understand, also, that if I plead GUILTY, I waive the right to trial by juryand all of the other rights mentioned above.9.Notwithstanding the above, I have, with the assistance of counsel, enteredinto an agreement with the United States Attorney's Office as follows:(a)I agree to plead guilty to Count 1 of the Indictment which alleges aviolation of Title 18, United States Code, Section 2252(a)(2).(b) I admit the following facts:(1.)On July 25, 2010, I lived at 523 Broadmore Estates, Goshen, IN46543. On that date, officers from the Elkhart County Sheriff'sDepartment obtained a search warrant issued by Elkhart CountySuperior Court to seize all of the computers and electronic storagedevices that were at my residence and which belonged to me. Thosedevices are listed in the forfeiture count of the indictment andconsisted of the following:•1 View Sonic Pocket PC PDA and charger (Ser #M2P034105902);•1 Compaq Presario Laptop Computer and Charger (model # 12XL310, Ser # 1V09FP4FT5E1);•1 purple flash drive (64MB);•1 Computer Tower Dark Grey in color, (no manufacturer name displayed);•1 Dell Computer Tower (Service tag 2B4HY51);•1 Maxtor 40 GB hard drive (Ser # 2F040L0710604);•1 Seagate 80 GB hard drive (Ser # 4LR4CTFE);•1 Seagate 6.4 GB hard drive (Ser # 7CN00QP2;•1 Seagate 500 GB hard drive (Ser # 6VM0598X.(2.)I knew that these devices contained digital images and videos thatdepicted child pornography as defined by 18 U.S.C. § 2256, whichdefines child pornography as a depiction which "involves the use of 3
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