ferguson plea petition
TRANSCRIPT
8/3/2019 Ferguson Plea Petition
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Edmund J. Spinney
3 5 Fifth Street
Sp-eId, OR 97477(541) 988-9399
(541) 988-9598 (FAX)
[email protected] # 84094Attorney for Defendant
INTHEUNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
UlWlTD STATE23 OF ARIERICA, 1
1 CaseNo. CR 4-60087-AAPlaintiff, 1
1 PETITION TOENTER PLEAvs. 1 OF GUILTY, CERTWICATE
) OF COUNSEL, AND ORDERJACOB SEREMZAH FERGUSON, ) ENTERING PLEA.
Defendant.1
1
The defendantrepresentsto the court:
1. My name s Jacob JeremiahFerguson. I am %years old. I havegone to school
uptoand includingthe 12* grade and havecompleteda 2year courseofstudiesatacommunity
college.
2. M y ttorney isEdmmd J. Sphey .
3. My attorney and I have discussed mycase
fully. I have received a copy of the
IndictmentorInformation. I havereadh e ndictmentor Information,or it hasbeenread tome,
and I have discussed it with my attorney. My attorney has counseled and advised me
concerningthe nature of each charge,any lesser-includedoffense@),and the possible defenses
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that I might have in this case. I have been advised and understand that the elements of the
charge@)alleged againstme towhich I ampleading "GUILTY" are as follows:
Count 1:Knowingly and maliciously attemptingto damageordestroy,by meansoffire,
anybuildingorvehicle inwhole or inpart ownedby theUntied Statesorany department
or agency thereof
Count2: Knowingly andmaliciously to damagingor destroying,by means of fire,any
building orvehicle in whole or inpart owned by the Untied States or any departmentor
agency thereof.
Ihavehad a f i l l and adequateopportunity to disclosetomy attorneyall factsknown o me that
relate to my case.
4. I know that if I plead "GUILTY," I will have to answerany questions that the
judge as l a me about the offenses towhich I am pleading guilty. I also h o w hat if I answer
falsely,under oath, and in the presence ofmy attorney, my answerscouldbe used against me
in a prosecution for perjury or false statement.
5. I am not under the influence of alcohol or drugs. I am not suffering h m ny
injury, illness or disability affectingmy thinkkg or my abilityto reason. I have not takenany
drugsormedicationswithin the past seven(7) ays except as follows: Methadone.
6. I understand that conviction of a crimecanresult in consequencesin addition to
imprisonment. Suchconsequences include deportation, or removal Eom theUnited States, or
denial of naturalization,if I am not a United Statescitizen; loss ofeligibilityto receive federal
benefits; loss of certain civil rights (which may be temporary or permanent depending on
applicable state or federal law), such as the right tovote, tohold public office, and topossess
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a firearm; and loss of the privilege to engage in certain occupations licensed by the state or
federal government.
7. I know that I may plead"NOT UIL,TY" to any crime charged againstme and
that I may persist in that plea if it has already been made. I know that if 1plead 'WOT
GUILTY" the Constitution guarantees me:
a. The right to a speedy andpublic trial by jury, during which
1will be-presumed to be innocent unless and until I am proven
guilty by the government beyond a reasonable doubt and by the
unanimous vote of twelvejurors;
b. The right to have the assistanceof an attorney at all stages
of the proceedings;
c. The right to use the power and process of the court to
compel the production of evidence, including the attendance of
witnesses inmy favor;
d. The right to see, hear, c d o n t , and cross-examine all
witnesses called to testiQ against me;
e. Theright to decide for myself whether to take the witness
stand and testifjr, and if I decide not to take the witness stand, I
understand that no inference of guilt may be drawn from this
decision; and
f. The rightnot to be compelled to incriminate myself.
8. I know that if I plead "GUILTY"there will beno rial before either ajudge or a
jury, and that I will notbeable to appeal fiom thejudge's denial of anypretrialmotionsI may
have filed concerningmattersor issuesnotrelated to the court's jurisdiction [see instructions].
9. In his case I am pleading"GUILTY" underRule 1 l(e)(l)(C). My attorneyhas
explainedthe effect of my plea under Rule 1 1(e)(l)(C) to be as follows:
My plea of guilty isunderRule 1 l(e)(l)(C); therefore, at the time of sentencing,
thejudgemust eitherimposethe specific sentenceagreedupon by theprosecutor
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and me, or allowme to withdraw my plea.
10. I knowthe maximum sentence which can be imposed uponme or the crime(s)
towhich I am pleadingguilty is 20 imprisonment anda Fineof $25O,OOO. I lsoknow there is
amandatory minimum sentence of 5 years imprisonment.
11. I know that the judge, in addition to any other penalty, will order a special
assessment as providedby law in the amount of $1 00per count of conviction.
12. I know that if : am orderedto pay a fme, and I wilIfulIy r e h e to pay that fme,
1 can be returned to court, where the amount of the unpaid balance owed on the fine can be
substantially increased by the judge and I can be imprisoned for up to one year.
13. My attorneyhas discussedwith me the Federal. Sentencing Guidelines. I know The
Guidelines are advisory, not mandatory. I dso know the sentencing judge, n determining the
particular sentence to be imposed, must consider those factors set forth in Title 18, United States
Code,Section3553(a), including, but not limitedto:thenatureandcircumstancesoftheoffense,my
own history and characteristics, the goals of sentencing (punishment,deterrence, protection, and
rehabilitation),and the sentencingrange establishedby the advisoryGuidelines.If my attorney or
any other personhas calculatedaguidelinerange for me, I know that this is only advisory, and s
onlyoneof the factorsthat thejudge willconsider in making a finaldecisionas towhatsentencewill
be imposed.I alsoknow hatajudge may not imposeasentencegreaterthan the maximum sentence
referred to in paragraph (10) above.
14. I know fiom discussion with my attorney that, under the Federal Sentencing
GuideIines, i f I am sentencedtoprison I am not entitledtoparole. I will have to serve the h l l
sentence imposed except forany credit forgoodbehaviorthat I earn. I can earncredit forgood
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behavior inprison at a rate of up to 54 days for eachyear of imprisonmentsaved. Credit for
good behavior does not apply to a sentence of one year or less.
15. Iknowthat ifI amsentencedtoprison, thejudge will imposea termofsupervised
release to folrow the prison sentence. During my supervised release term I will be supervised
by aprobationofficeraccordingto terms andconditionsset by thejudge. Inmy case,a term of
supervised releasecanbe 3 to 5 years. I f1 violate the conditions of supervisedrelease, I may
be sent back to prison for up to 3 years.
16. I know that in addition to or in lieu of any other penalty, the judge can order
restitution payments to any victim of any offense towhich I plead guilty. I a m also idormed
that, for certaincrimesofviolence andcrimes involvingh u dordeceit,it ismandatory that the
judge imposerestitutionin the full amount of any financial loss orh am causedby an offense.
If imposed, the victim can use the order of restitution to obtain a civil judgment lielz A
restitutionorder can be enforcedby theUnited States forup totwenty 20)years fiomthe date
of myrelease fkom imprisonment, or, if I am not imprisoned, twenty (20)years fkom the date
of the entry of judgment. If I wilIfuIly refuse to pay restitution as ordered, a judge may
resentenceme to any sentencewhich could originally have been imposed.
17. On any fine or restitution in anamount of $2,500 or more, I know that I will be
requiredtopay interest unless that fineor restitution is paid within fifteen (15) days 5om the
date of he entry ofjudgment.
18 . If 1am on probation, parole, or supervisedrelease in any other state,or federal
case, I know that bypleading@ty inthiscourtmyprobation,paroleor supervised releasemay
be revokedand I may be required to servetime in that case,whichmay be consecutive, that is,
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in addition to any sentence imposed onme in thiscourt.
19, I f I have another case pending in any state or federal court, I know that my
Petition and Plea Agreement in this case do not, in the absence of an express and written
agreement, apply to my other case(s), and that I canbe faced with consecutive sentences of
imprisonment.
20. My plea of "GUILTY"is based on a PleaAgreementthat I have madew i ~he
prosecutor. ThatPleaAgreement is attached heretoandincorporatedherein. I have read orhad
read tome the Plea Agreement, and ImderstandthePleaAgreement.
21. The Plea Agreement contains the only agreement between the United States
government andme. No officeror agent of any branch of government (federal, state or local)
or anyone else has promised or suggested that Iwill receive a lesser term of imprisonment,or
probation, or any other form of leniency if I plead "GUILTY" xcept as stated in the Plea
Agreement. I understand that I cannot rely on any promise or suggestion made to me by a
government agent or oficerwhich is notstated inwriting in the PleaAgreement, or wbch is
not presented to the judge inmy presence in open court at the time of the entry of my plea of
guilly.
22. My pIea of "GUILTY" is not the result of force,h a t , or intimidation.
23. I hereby request that thejudge acceptm y pIea of "GUILTY"to Counts 1 and 2
of the Information.
24. 1h o w hatthejudge mustbe satisfiedthat a crime -occurredandthat1committed
that crime before my plea of"GUILTY"can be accepted. With respect to the charge(s) to
whichIam pleadingguilty, 1represent that I did the followingacts and hat the following facts
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are true:
On or about October 28, 1996, in the District of Oregon, I knowing and maliciously
attempted to damage or destroy, by means of fire, a building located at 610 North
SantiamHighway, Detroit, Oregon, nd did maliciouslyand destroy,by meansof we,
a 1992Ford pick-up, bothofwhichwere ownedby the United States Forest service, an
agency of the UnitedStates.
25. I offer myplea of "GULTY"fieeIy andvoluntarily and ofmy own accord and
witha fullunderstandingofthe allegations set forth inthe Indictment or Information,andwith
a full understanding of the statements set forth in t h i s Petition and in the Certificate of my
attorney that is attached to this Petition.
SIGNED by me inthepresence ofmy attorney, after reading (or havinghad readto me)
allof the foregoingpages and paragraphs of this Petition on this 26* day ofOctober,2007.
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CERTIFXCATE OF COUNSEL
Theundersigned,as attorney for defendant JacobJeremiahFerguson, hereby certifies:
1. I have fully explained to the defendant the allegations wntained in the
Information inthis case, any lesser-included offense(s), and the possibledefenseswhich may
apply in this case.
2. I have personally examined the attached Petition To Enter Plea of GuiltyAnd
OrderEnteringPlea, explained a11 itsprovisions to the defendant,and discussed fullywith the
defendant al lmatters described and referred to in the Petition.
3. I have explainedtothe defendantthemaximum penalty and otherconsequences
of entering a plea of guilty described in paragraphs (6)-(20)of the Petition, and I have also
explained tothe defendantthe applicableFederal SentencingGuidelines.
4. I recommend that the Court accept the defendant's plea of "GUILTY."
SIGNEDby mein he presence of the above-nameddefendant,and afterfulldiscussion
with the defendant of the contents of the Petition To Enter Plea of Guilty, and any Plea
Agreement,onthis 26' day of October, 2007.
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ORDER ENTERING PLEA
I findthatthe defendant's pleaofGUILTY has beenmade fieelyandvoluntarilyand not
outof ignorance, fear, inadvertence,orcoercion. I fixrther fm d thedefendanthasadmitted facts
thatproveeachofthenecessary elements ofthe crimes to which the defendanthas pled guilty.
IT IS THEREFORE ORDERJZD that the defendant'spleaofGUILTY be acceptedand
entered as requested in this Petition and as recommended in the Certificate of defendant's
attorney.
DATED this 26h of October,2007, n open court.
ANNAKEN
Judge, U.S. DistrictCourt
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KARTN . IMMERGUT,OSB #96314
United States Attomey
District of Oregon
KIRK A. ENGDALL,OSB# 1215
Assistant United StatesAttorney
701 High StreetEugene,Oregon 97401(5.41)465-6771
kirk.enerdall@usdoi,mv
INTHEUNITED STATES DISTRICT COURT
FOR THEDISTRICTOF OREGON
UNITED STATESOF AMERICA, 1) caseNO. R 04 * 6608FAA
Plaintiff, 11 A G R E E M E N Tv. 1
1JACOB JEREMIAH FERGUSON, 1
1Defendant. 1
Karin J. Immergut, United StatesAttorney for the district of Oregon, and Kirk A.
Engdall, AssistantUnited StatesAttorney, and Jacob Jeremiah Ferguson, by himself and through
his attorney,Edmund J. Spinney,hereby enter into the following agreement, based upon the
understandingsand premises set forth below.
Mr. Fergusonagrees to enter aplea of guilty to both counts of the attached Information
charging him withthe
attempted arson of the Detroit Ranger Station and the arsonof heUnited
States Forest Servicevehicle located at the Detroit Ranger Station, both of which occurred on
October 28,1996, in violation of 18 United States Code, Section 844(f)(1). The maximum
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penalty for each of these offenses is 20years mprisonment, including a five year mandatory
minimum sentence, a fine of $250,000, $200 fee assessment, and a three year period of
supervised release.
2.
The parties stipulate and agree hat the November 5,2003 version of the United States
SentencingGuidelinesmanualwill be used in this case, thatU.S.S.G.2K1.4(a)(l)(B) (Arson)
is the applicable guideline section,and that the base offense level under that sectionwill be level
24,because the event involved the destruction or attempteddestruction of a government facility.
Because ofMr. Ferguson's willhgnessto enter a plea of guilty, and so long ashe commits no
new criminal offenses,doesnot obstruct or attempt to obstructjustice, does not otherwise
commit an act or acts inconsistent with the acceptance of responsibility, and that he pay the fee
assessment prior to sentencing inthis matter, the United States agrees to recommend that he
receive a three-Ievel reduction inhis base offense level for acceptanceof responsibility pursuatlt
toU.S.S.G.3El. l . The United Stateswill also recommend that Mr. Ferguson be sentenced at
the low end of the appropriate guideline range as ultimately determinedby the Cowt and t . o
fine or restitutionwill be imposed. Mr. Ferguson will be required to pay the necessary fee
assessments.
Mr. Fetrguson's guiltyplea will be pursuant to theFederal Rule ofProcedure 1 (c)(l)(C).
Therefore, if the court a p e s o acceptMr. Ferguson'sguilty plea, the courtwill be bound to
impose the sentence mommended by this agreement.
3.
The United States Attorney's Office for theDistrict ofOregonagrees it will bring no
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additional chargesagainst Mr. Ferguson for those criminal offenses committed in the District of
Oregon including but not limited to those offenses Iisted in paragraph 9 below.
4.
Mr. Ferguson freely, voluntarily, knowingly and intelligently waives: (1 ) any rights to
appeal or collaterallyattackhis conviction and sentence in connectionwith this case, with the
exception of ineffective assistance ofcounsel or retroactive amendments to the United States
sentencing guidelines, (2) any rights which he mayhave underBlakly v. Washington, 004W L
1402697 (June 24,2004), and (3) a sentencing jury. He further agrees to have any sentencing
issues determinedby thesentencing udge in this case.
5.
Mr. Ferguson has expressed a desire to continue to cooperate in the investigation and
prosecutionofotherswho are involved in the commission of criminal acts, including but not
limited to arson and related type activities. As part of this agreement, Mr. Ferguson agrees to
meet with any and all members of requesting federal, state and local law enforcementagencies or
offices, or otherpersons hey designate at any reasonable times and places and to fullyapd
compIetely cooperate with said agencies or offices by accurately and truthfullydisdosing all
information he h o w s concemhg the above matters and all other matters related thereto, whether
federal, state or local.
Mr. Fergusonunderstands he will be required to Mly, honestly, truthfullyand completely
disclose all of the knowledge he has concerning all violations of federal and state laws and all
persons nvolved in thoseviolations. He must disclose the existenceofany records, documents
or other evidence that would corroborate his testimonyorwould furtherthe investigation. W e
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must assist the investigationby providingthoserecords,documentsor other evidence thatare
within his control or the controlof a third party, or do anything requested to aid in obtainingsuch
records. He also agrees to testify fully, honestly, truthfullyand completely at any trial, hearings
or proceedings, either state or federal, upon request.
6 .
Mr. Ferguson agrees to neitherprotect nor attempttoprotect anypersonbywithholding
information orby providing false information, nor to faIsely implicateany person.. Mr. Ferguson
may be asked by the government to contactpersons known o him tobe involved in criminal acts,
including arson or related type activity. He agreeshe will not take any actionwithout the prior
express knowledge and approval of the law enforcementofficers with whom he i s working. Mi-.
Ferguson agrees that the United Statesmay confirm the accuracy ofany nformation which he
provides under the terms ofthis agreementby use ofany nvestigativemeans which it deems
appropriate and necessaryandthat hewill fully cooperate with all efforts to verify that any
information he provides under this agrmnent is truthfid md complete. As part ofthisprocess, n
the sole discretion of heUnited States,Mr.Fergusonmay be asked to submit to a polygraph
examination to verify any informationwhichhe may provide to the United States. Neitherparty
shall object to the admissibilityin evidenceof he resultsof such examination in anyproceeding
to enforce or set aside this agreement in which compliancewith the terms of this agreement are
inissue. If Mr. Fergusondisagrees with the results ofthe polygraph, he may submit the results to
an examiner ofhis choice at his own expense.
Should the defendant intentionallyprovide a false material statementto the government
on any matters concerninghis cooperation, he will be deemed to have breached this agreement
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andhe understands the United Stateswill not move for a downward departure fiom his guideline
sentence in exchange forhis cooperationas agreed toin paragraph9 below. Mr. Ferguson also
understands he would not be able to withdraw his guiltyplea should this occur.
Mr. Ferguson understands that theUnited StatesofAmerica will not tolerateany further
violations of law, federal, state or local, and should any violations become h o w n , they will be
made known o the appropriate authorities. Nothing in this'agreement will preclude prosecution
of Mr. Fergusonby hose authorities for suchviolations. Mr. Ferguson understands that nothing
in this agreement will prevent theUnitedStates fiom institutingprosecutionagainsthim for
perjury, subomationofperjury, fahe statements or fake declarationsifhe cornmits or causes the
commission of any such offense in connectionwith his testimony eferred to above given after
the date of this agreement.
8.
In addition to the non-prosecution agreementsas set forthinparagraph 9 of his
agreement, any statementsmade by Mr. Fergusonunder the terms of this agreementwill be
deemed as ifmade under 'bse immunity" as definedunder Title 18, United StatesCode, Section
6001, et seq. Mr. Ferguson understands and agrees that any rights and benefits he may have as a
result of this agreement and any immunity conferred upon him shallnot extend toany crimes
beyond those criminal offenses enumeratedin paragraph 9 below.
9.
IfMr. Ferguson fullyperforms his obligationsmder the terms of this agreement,at the
time of sentencing,and ifappropriate thereafter,under U.S.SG. 5 5Kl.1 and/orRule 35(b)0f the
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FederalRules ofCriminalProcedm, the United State's Attorney's Office for the District of
Oregonagrees t will file a motion for adownward departure for substantialassistance to the
extentnecessary tobring Mr. Ferguson's total offense level to ZoneA of the sentencing
guidelines. The United Stateswill aIso recommend that sentence be mposed at the low endof
the resdting guidelinerange.
As evidenced by the letters attached to this agreement, the United States and the specified
state and local jurisdictions also agree to bxing no additional chargesagainst Mr. Ferguson for
offenses related to the followingcriminal events:
a. An arson hat occurred at J.E. Harl FineFashion and Furs, 1426 S. Main, Walnut
Creek, ContraCostaCounty, California, in the NorthernDistrict of Califomia,on
or about April 14,1998.
b. An rson that occurred at the Redwood Coast TruckingCompany, 210Peninsula
Drive, Arcata, California, in theNorthernDistrict ofCalifornia, on or about
September 20,1998.
c. An arson that occurred at theHouse of Furs, 2727 Capitol Ave., Sacramento,
SacramentoCounty,California, in theEasternDistrict of California,on or about
May 10,1998.
d. An arsonthatoccurred at theAnimalDamage Control (ADC), Field Office, 720
O'Leary Rd. N.W., Olympia, TbustonCounty,Washington, in the Western
DistrictofWashington, on orabout June 21,1998.
e. An arson that occurred at the APHlS W ildlifeResearch Center, 9701 BIomberg
St. S. W., lympia, Thurston County, Washington, in the Westem Districtof
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Washington, on or about June 21,1998.
A horse release and attemptedarson at the U.S.Bureau of Land Management
Wild HorseCorral,Rock Springs,SweetwaterCounty,Wyoming, in theDistrict
ofWyoming, on or aboutOctober 11, 1998.
An arson that occurred at the Vail SkiResort, Vail, Eagle County,Colorado, in
the DistrictofColorado, onor about October 19,1998.
An arson at U. S. Forest Industries, 2611 Whittle Ave., Medford, Jackson County,
Oregon, in the District ofOregon,on or about December 27, 1998.
An m on at the ChildersMeat Company,29476 Airport Road, Eugene,Lane
County,Oregon, in the District of Oregon, on or aboutMay 9,1999.
An arson at the West UniversityEugenePolice Substation, 716 E. 13th Eugene,
Lane County, Oregon,in the District ofOregononor about September6,2000.
An arson at the Joe Romania C hewle t Dealership, 1425 Walnut St., Eugene,
Lane County, Oregon, in the District ofOregon,where approximately37 sports
utiIity vehicles were burned onor about March 30,2001.
An arson at the Boise Cascade Corporate Offices, 450N. Pacific Ave.,
Monmouth, Polk County,Oregon, in the District ofOregon, on or about
December 25,1999.
An arson at the SuperiorLumber Company offkes, 2695 Glendale Valley Rd.,
Glendale, Douglas County,Oregon, n the District ofOregon,onor about January
2,2001.
An arson at the Jefferson Poplar F m s , 79114 Collins Rd., CIatskanie, Columbia
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County, Oregon, in the District af Oregon,onor aboutMay 21,2001.
o. An arson that occurrcdat the U. .Forest Service OakridgeRanger Station, 46375
Hwy. 58, W e s ~ r ,ane County, Oregon, in the District of Oregon,onor about
October 30,1996.
p. An arson that occwred at Cave1 West, 1607 S. E. Railroad, Redmond, Deschutes
County,Oregon, in the District of Oregon,on orabout July 21,1997.
q. An arson and horse release that occurredat theU. . Bureau of Land Management
Wild Horse Corral,Bums,Harney County,Oregon, in the DistrictofOregon, on
or about November 30,1997.
r. An arson that occurred at Wildlife Phamzaceuticals, 1401DufTDr., Fort Collins,
Larimer County, Colorado, in the District of Colorado,on or about August 17,
1997.
s. The removal of47dogs fiomBio Devices,City ofOrange, Californiaon orabout
August 28,1999.
t. The releaseofmink at the Palmer Mink Fann, Preston, Idaho, on or about October
6,1997.
10.
Should Mr. Fergusonbreach this agreementatany ime, itwill be deemednull and void
and both parties may proceed as if it had not existed. In the eventthe agreement isbreached, the
United Statesmayuse any statement made by Mr. Ferguson to any officer, agentor attorney of
the United States or any state or to any federal or state grand wy inany prosecution whichmay
.bebrought against him.
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11.
Mr.Ferguson understands that theUnited States will fully inform the Court andUnited
States ProbationOffice of all known infomation concaningMr.Ferguson and his offenses for
purposes of sentencing.
12.
This agreement sets out the entire agreementbetween the parties. There are no other
promises, either express or implied,than hose set forth above. Mr. Ferguson fi,uther
acknowledgesthat no hreats have been made against him by anyone n order to obtain his
cooperation and signature to this agreement. Mr. Ferguson also understandsthat thebenefits of
this agreement, as more particuIarly described above, are solely dependent uponwhether he uses
hisbest efforts in cooperating with the agenciesand officesreferred to above and are not
dependent, n whole or in part, onwhether the United States is able to obtain any ndictments or
convictions ofpersons involved in arson and/ordomestic terrorism related activities.
KARTN J. IMhlERGUT
United States Attorney
K ~ R K. ENG$ALL 'AssistantUnited States Attorney
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T HAVEREADTIXISAGREE1MENT CAREFULLY AND REVIEWEDEVERYPARTOF ITWITH MY ATTORNEY. I UNDERSTANDTHEAGREEMENTAND
FREELY AND VOLUNTARILY AGREE TO TSTERMS.
I M PR ESE NT DEFENDANTASHIS LEGAL COUNSEL. I HAVECAREFULLY REVIEWED EVERY PART OF THISAGREEMENTWITHHIM. TO
MY KNOWLEDGE, TH E DECISIONBYHIM TOENTER INTO THlSAGREEMENTISAN NFORMED AND VOLUNTARY ONE.
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US.Departmentof JusticeKarin J. lmmegutUnited States AtfomeyDistrict of Oregon701High Street Office: (547) 465-6771
Eugene, OR 97407 Fax: (540 65-6582
September 10,2004
AUSA Brian Stretch
Chief of Violent Crimes
Northern District of California
450 Golden Gate Avenue
San Francisco,CA 94102
Re: Jacob Jeremiah Ferguson
Dear Mr. Stretch:
This letter is in regard to our conversationconcerningthe potential prosecutionbyyour
officeof Jacob Jeremiah Ferguson,for offensesarising outof the arson that occurredat J.E.Harl Fine Fashion and Furs, 1426 S. Main Street, Walnut Creek, Contra Costa County,
California, on or about April 14, 1998; and the arson that occurred at the Redwood Coast
Trucking Company, 2210 Peninsula Drive, Arcata, California on or about September 20,
1998.
In our conversation you advisedme that if Mr. Ferguson enters a plea of guilty to one
count of arson in the District of Oregon in Federal Court pursuant to the terms of the
cooperation agreement, your office might be willing to forego prosecution of him for thesematters. By this letter, Iam requesting confirmation as to whether charges would be filed.
If there isany additional nformation you would likeme to provide, please letme know.Ican be reachedat 541465-6946. Thank you for your considerationof and assistance with
this matter.
Very truly yours,
KARIN J. IMMERGUT
United States Attorney
District of Oregon
ma44Assistant UnitedStates Attorney
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IfJacob Jeremiah Ferguson enters a plea of guilty to a federal felony arson charge
in the district of Oregon in accordance with the terms of the cooperation agreementbetween AUSA Kirk A, Engdall, Jacob Jeremiah Ferguson and his attorney EdmundSpinney, this of ice agrees it will not file charges against Mr. Ferguson for his actions in
connection with the arson that occurred at J.E. Harl Fine Fashion and Furs, 1426 S. MainStreet, Walnut Creek, Contra Costa County,California, on or aboutApril 14,7998;and thearson that occurred at the Redwood Coast Trucking Company, 2210 Peninsula Drive,
Arcata, California on or about September 20, 1998.
- /+ 0 y
Date
Chief of Violent Crimes
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U.S. Department of JusticeKarin J. ImmergufUnited States AttorneyDjstnct of Oregon701 High Street Office: 541) 465-6771Eugene, OR 9740f Fax: (54f) 465-6582
September 90,2004
AUSA Ken MelikianEastern District of California501 [ Street, 19'~ loorSacramento, CA 958 4
Re: Jacob Jeremiah Ferguson
DearMr. Melikian:
This letter is in regard to our conversationconcerning hepotentialprosecution by youroffice of Jacob Jeremiah Ferguson,or offenses arising out of the arson that occurred at theHouse of Furs, 2727 Capitol Avenue, Sacramento, Sacramento County, California on orabout May 10,1998.
In our conversation you advisedme that if Mr. Ferguson enters a plea of guilty to onecount of arson in the District of Oregon in Federal Court pursuant to the terms of thecooperation agreement, your office might be willing to forego prosecution of him for these
matters. By this letter, I am requestingconfirmation as to whether charges would be filed.
I f there is any additional information you would like me to provide,please letmeknow.I can be reached at 541-465-6946. Thank you for your consideration of and assistance with
this matter.
Very truly yours,
KARIN J. IMMERGUTUnited States Attomey
District of Oregon
KIRK A. ENGDALLAssistant United States Attorney
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Page 2 of 2
If Jacob Jeremiah Ferguson enters a plea of guilty to a federal felony arson chargein the district of Oregon in accordance with the terms of the cooperation agreement
between AUSA -Kirk A, Engdall, Jacob Jeremiah Ferguson and his attorney EdmundSpinney, this office agrees it will not file charges against Mr. Ferguson for his actions in
connection with the arson that occurred at the House of Furs, 2727 Capitol Avenue,Sacramento, Sacramento County, California on or about May 10, 1998.
v,, ,,*Date
Assistant U.S.Attorney
Eastern District of California
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US . Department of JusticeKarin J. ImmergutUnited States AttorneyDistricf of Oregon
701 High Street Ofice: (541) 4656771Eugene, OR 97401 Fax: (541)465-6582
AUSA Andrew FriedmanWestern District of Washington601 Union StreetSeattle, WA 98101-3903
September 10,2004
Re: Jacob Jeremiah Ferguson
Dear Mr. Friedman:
This letter is in regard to our conversation concerningthepotential prosecution by youroffice of Jacob Jeremiah Ferguson, for offenses arising out of the arson that occurred at theAnimalDamageControl (ADC), FieldOffice,720O'Leary Rd. NW.,Olympia, Washington, on
or about June 21,1998; and the arson that occurred at the APHIS Wildlife Research Center,9701 Blomberg St S.W., Olympia, Washington, on or about June 21, 1998.
In our conversation you advised me that ifMr. Ferguson enters a plea of guilty to onecount of arson in the District of Oregon in Federal Court pursuant to the terms of thecooperation agreement, your office might be willing to forego prosecution of him for thesematters. By this letter, I am requesting confirmation as to whether charges would be filed.
If there is any additional information youwould like me o provide, please letme know.1 can be reached at 541-465-6946. Thank you for your consideration of and assistance withthis matter.
Very truly yours,
KARIN J. IMMERGUT
United States AttorneyDistrict of Oregon
KIRK A. ENGDALLAssistant United States Attorney
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Page 2 of 2
If Jacob Jeremiah Ferguson enters a plea of guilty to a federal felony arson chargein the district of Oregon in accordance with the terms of the cooperation agreementbetween AUSA Kirk A, Engdall, Jacob Jeremiah Ferguson and his attorney EdmundSpinney, this office agrees it will not file charges against Mr. Ferguson for his actions in
connectionwith the arson that occurred at the Animal Damage Control (ADC), FieldOffice,720 O'Leary Rd. NW., Olympia, Washington, on or about June 21, 799%;and the arson
that occurred at the APHIS Wildlife Research Center, 9701 Blomberg St S.W., Olympia,
Washington, on or about June 21,1998.
Assistant US. AttorneyWestern District of Washington
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U.S.Departmentof Justice
Karin J. lmmergutUnited SfatesAttorneyDistrict of Oregon701 High Streef OtTce: (541) 465-6771
Eugene, OR 97401 Fax: (547) 465-6582
September 10,2004
Deputy County Prosecutor Jack JonesThurston County Prosecutor's Office2000 Lakeridge Drive, S.W.Olympia, WA 98502
Re: Jacob Jeremiah Ferguson_ - . I
Dear Mr. Jones:
This letter s in regard to our conversation concerning the potentialprosecution byyour
o f k e of Jacob Jeremiah Ferguson,for offenses arising out of the arson that occurred at the
Animal Damage Control (ADC), Field Office, 720 O'Leary Rd. N.W., Olympia, Washington,
on or about June 21, 1998; and the arson that occurred at the APHIS Wildlife ResearchCenter, 9701 Blomberg St. S.W. Olympia, Washington, onor about June 21, 998.
Inourconversation you advised me that if Mr. Ferguson enters a plea of guilty to onecount of arson in the District of Oregon in Federal Court pursuant to the terms of the
cooperation agreement, your office might bewilling to forego prosecutionof him for these
matters. By this letter, I am requesting confirmation as to whether charges would be filed.
Ifthere isany additional nformation you would likeme to provide, please let me know.Ican be reached at 541-465-6946. Thank you for your consideration of and assistancewith
this matter.
Very truly yours,
KARIN J. IMMERGUTUnited States Attorney
District of Oregon
Assistant United States Attorney
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Page 2 of 2
If Jacob Jeremiah Fergusonentersa pleaof guilty to a federal felony arson chargein the district of Oregon in accordance with the terms of the cooperation agreementbetween AUSA Kirk A, Engdall, Jacob Jeremiah Ferguson and his attorney EdmundSpinney, this ofice agrees it wilt not file charges against Mr. Ferguson for his actions inconnectionwith the arson that occurred at the Animal Damage Control (ADC), FieldOffice,720 O'Leary Rd. N.W., Olympia, Washington, on or about June 21, 1998; and the arsonthat occurred at the APHIS Wildlife ResearchCenter, 9701 BlombergSt. S.W. Olympia,Washington, on or about June 21, 1998.
Date
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U.S.Department of Justice
Karin J. lmmergutUnited States Attorney
District of Oregon
701 High Street mce: (541) 465-6771Eugene, OR 740f Fax; (541) 465-6582
September 10,2004
AUSA Thomas O'RourkeDistrict of Colorado
1225 17 Street, Suite 700
Denver,CO 80202
Re: Jacob Jeremiah Ferguson
D e a iMr. O'Rourke:
This letter is in regard to our conversation concerning hepotential prosecution byyour
officeofJacobJeremiah Ferguson,foroffensesarisingoutof thearsonatthevailSki Resort,
Vail, Colorado on or about October 79, 1998, and an arson that occurred at WildlifePharmaceuticals,1401 DufFDrive,Fort Collins, LarimerCounty,Colorado,onor aboutAugust
17, 1997.
In ourconversation you advised me that if Mr. Fergusonenters a plea of guilty to one
count of arson in the District of Oregon in Federal Court pursuant to th e terms of the
cooperationagreement, your of ice might bewilling to forego prosecution of him for thesematters. By this letter, 1 am requesting confirmation as to whether charges would be fe d .
If there isany additional information you would like me to provide, please let meknow.
I can be reached at 541465-6946. Thank you for your consideration ofand assistance withthis matter.
Very truly yours,
KARIN J. IMMERGUTUnited States AttorneyDistrictof Oregon
KIRK A. ENGDALLAssistant United States Attorney
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If Jacob Jeremiah Ferguson enters a plea of guilty to a federal felony arson chargein the district of Oregon in accordance with the terms of the cooperation agreement
between AUSA Kirk A, Engdall, Jacob Jeremiah Ferguson and his attorney EdmundSpinney, this office agrees it will not file charges against Mr. Ferguson for his actions inconnectionwith arson at the Vail Ski Resort, Vail, Colorado on or about October 19,1998,and an arson that occurred at Wildlife Pharmaceuticals, 1401 Duff Drive, Fort Collins,
bout August 17,1997.
Assistant U.S. ttorneyDistrict of colorado
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U.S.Departmentof JusticeKarin J. immeyutUnited StatesAttorneyDistrict of Oregon707 High Street CMce: (541) 465-6771Eugene, OR 97407 Fax: (541) 465-6582
September 10,2004
The Honorable Mark D. Huddleston
Jackson County DistrictAttorneyJackson County District Attorney's Office
715 West I th Street
Medford, OR 97501
Re: Jacob Jeremiah Ferguson
Dear Mr. Huddleston:
This letter is in regardto ourconversationconcerning hepotentialprosecution by youroffice of Jacob Jeremiah Ferguson, for offenses arising out of the arson at US Forest
Industries, 2611Whittle Ave., Medford, Oregon, onor about December 27, 1998.
In ourconversation you advised me that if Mr. Fergusonenters a plea of guilty to onecount of arson in the District of Oregon in Federal Court pursuant to the terms of the
cooperation agreement, your office might be willing to forego prosecution of him for these
matters. By this letter, Iam requesting confirmation as to whether charges would be filed.
If there is any additional information you would like me to provide, please le t me know.I can be reached at 541-465-6946. Thank you for your consideration of andassistancewith
this matter.
Very truly yours,
KARIN J. IMMERGUTUnited States Attorney
District of Oregon
KIRK A. ENGDALfAssistant United States Attorney
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Page 2 of 2
If Jacob Jeremiah Ferguson enters a plea of guilty to a federal felony arson chargein the district of Oregon in accordance with the terms of the cooperation agreementbetween AUSA Kirk A, Engdall, Jacob Jeremiah Ferguson and his attorney EdrnundSpinney, this office agrees itwill not file charges against Mr. Ferguson or his actions in
connection with arson at USForest Industries,2611 Whittle Ave., Medford,Oregon, on or
about December 27, 1998.
Jackson County DistrictAttorney
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U.S. Department of JusticeKarin J. lmrnergufUnited StatesAttorneyDistrict of Oregon701 High Sfreet Office: (541) 465-6777
Eugene, OR 97401 Fax: (541) 465-6582
September 10,2004
The HonorableAlexander R. GardnerLane County District Attorney
Lane County District Attorney's Office
125E. 8'h Avenue, Room400Eugene, OR 97401
Re: Jacob Jeremiah Fetguson
Dear Mr. Gardner:
This letter is in regard to our conversation concerning the potential prosecution by
your omce of Jacob Jeremiah Ferguson. for offenses arising out of the arson at ChildersMeat Company,29476 Airport Road, Eugene,Oregon 97402on or about May 9,1999; the
arson at theWest UniversityEugenePoliceSubstation,716 E. 13th,Eugene, Oregon, on or
about September6,2000; and thearson at Joe Romania Chevrolet Dealership,1425Walnut
St., Eugene, Oregon, where approximately 37sportsutilityvehicleswere burned on orabout
March30,2001.
In our conversation you advisedme that if Mr. Ferguson enters a pleaof guilty to onecount of arson in the District of Oregon in Federal Court pursuant to the terms of the
cooperation agreement, your ofice might be willing to forego prosecution of him for these
matters. By this letter, I am requesting confirmation as to whether charges would be filed.
If there is any additional information you would like me to provide, please let meknow. 1 can be reached at 541-465-6946. Thank you for your consideration of andassistancewith this matter.
I I Very truly yours,
KARIN J. IMMERGUTUnited States Attorney
District of Oregon
KIRK A. ENGDALI' Assistant United States Attorney
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Page2 of 2
If Jacob Jeremiah Fergusonenters a plea of guilty to a federal felony arson chargein the district of Oregon in accordance with the terms of the cooperation agreementbetween AUSA Kirk A, Engdall, Jacob Jeremiah Ferguson and his attorney EdmundSpinney, this office agrees it will not file charges against Mr. Ferguson for his actions in
connection with the arson at Childers Meat Company, 29476 Airport Road, Eugene,Oregon 97402on or about May 9,1999; the arson at the West University Eugene PoliceSubstation, 716 E. I th, ugene, Oregon, on or about September 6,2000; and the arson
at Joe Romania Chevrolet Dealership, 1425 Walnut St., Eugene, Oregon, whereapproximately 37 sports utility vehicles were burned on or about March 30, 2001.
ALEXANDER R. GARDNERLane County District Attorney
Date
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U.S. Department of Justice
Karin J. immergufUnifed StatesAttorneyDistrict of Oregon701 High Street ofice: (541) 465-6771Eugene,OR 97401 Fax: (547) 465-6582- -
September 10,2004
The Honorable John W. Fisher
Polk County District Attorney
Polk County District Attorney's Office850 Main Street
Dallas, OR 97338
Re: Jacob Jeremiah Ferguson,
DearMr. Fisher:
This letter s in regardto our conversation concerning the potential prosecutionby your
office of Jacob Jeremiah Ferguson, for offenses arising out of the arson of Boise CascadeCorporate Offces, 450 N. Pacific Ave., Monrnouth, Polk County, Oregon, on or aboutDecember 25, 1999.
In our conversation you advised me that if Mr. Ferguson enters a plea of guilty to onecount of arson in the District of Oregon in Federal Court pursuant to the terms of thecooperation agreement. your office might be willing to forego prosecution of him for thesematters. By this letter, I am requesting confirmation as to whether charges would be filed.
If there isany additional information you would likeme to provide, please letme know.I can be reachedat 541-465-6946. Thank you'foryour considerationof and assistance with
this matter.
Very truly yours,
KARIN J. IMMERGUTUnited States Attorney
District of Oregon
Assistant United States Attorney
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Page 2 of 2
If Jacob Jeremiah Fergusonenters a plea of guilty to a federal felony arson chargein the ,district of Oregon in accordance with the terms of the cooperation agreementbetween AUSA Kirk A, Engdall, Jacob Jeremiah Ferguson and his attorney EdmundSpinney, this office agrees it will not file charges against Mr. Ferguson for his actions inconnection with the arson of Boise Cascade Corporate Offices, 450 N. Pacific Ave.,Monrnouth, Polk County, gregon, on or about December 25,1999.
I3 6EP 0 4
JOHN W. FISHEH Date
Polk County ~is t r ic t~_fJbrnq
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U.S. Department of JusticeKarin J. lmmergutUnited StafesAttorneyDjstnct of Oregon701 High Street Ofice: (541) 4656771
€ugen& OR 7401 Fax: (541) 65-6582
September 10,2004
The HonorableJack L. Banta
Douglas County District Attorney
Douglas County District Attorney's OfficeP.O. ox I006
Roseburg,OR 97470
Re: Jacob Jeremiah FergusonI
Dear Mr. Banta:
This letteris n regardtoour conversation concerningthepotential prosecutionbyyourofice of Jacob Jeremiah Ferguson,for offenses arising outof the arson at Superior LumberCompany offices, 2695 Glendale Valley Rd., Glendale, Oregon,onor about January2,2001.
In our conversationyou advised me that if Mr. Fergusonenters a plea of guilty to one
count of arson in the District of Oregon in Federal Court pursuant to the terms of the
cooperation agreement, your office might be willing to forego prosecution of him for these
matters. By this letter, I am requesting confirmation as to whether charges would be filed.
If there isany additional nformation you would like me to provide, please let me know.
1 can be reachedat 541-465-6946. Thankyou for your consideration of andassistance with
this matter.
Very truly yours,
KARIN J. IMMERGUTUnited States Attorney
District of Oregon
KIRK A. ENGDALLAssistant United StatesAttorney
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Page 2 of 2
If Jacob Jeremiah Ferguson enters a plea of guilty to a federal felony arson chargein th e district of Oregon in accordance with the terms of the cooperation agreementbetween AUSA Kirk A, Engdall, Jacob Jeremiah Ferguson and his attorney EdmundSpinney, this offtce agrees it will not file charges against Mr. Ferguson for his actions in
connectionwjth thearsonatSuperiorLumber Company offices,2695Glendale ValleyRd.,Glendale, Oregon, on or about January 2,2001.
/ Douglas County DistrictAttorney
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US . Department of JusticeKarin J. immergutUnited SatesAttorney
District of Oregon707 High Street Ofice: (54 7) 465-6771
Eugene, OR 7401 Fax: (541) 465-6582
September 10,2004
The Honorable StephenAtchisonColumbia County DistrictAttorneyColumbiaCounty District Attorney's Office230 Strand Street, Room328
St. Helens,OR 97051
Re: Jacob Jeremiah Ferguson
Dear Mr. Atchison:
This letter Ps in regard o our conversation concerning he potential prosecutionbyyourofice of Jacob Jeremiah Ferguson, for offenses arising ou t of the arson at JeffersonPoplarFarms, 9114Collins Rd.,CIatskanie, Oregon,onor about May 21,2001.
Inour conversation you advised me that if Mr. Ferguson enters a pleaof guilty to onecount of arson in the District af Oregon in Federal Court pursuant to the terms of thecooperation agreement, your office might-bewilling to forego prosecution of him for thesematters. By his letter, I am requesting confirmation as to whether charges would be filed.
If there is any additional information you would like me to provide, please let me know.
1 can be reached at 541 465-6946. Thank you for your consideration of and assistance withthis matter.
Very truly yours,
KARIN J. IMMERGUTUnited States Attorney
District of Oregon
KIRK A. ENGDALL
Assistant United StatesAttorney
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Page 2 of 2
If Jacob Jeremiah Ferguson enters a plea of guilty to a federal felony arson chargein the District of Oregon in accordance with the terms of the cooperation agreementbetween AUSA Kirk A, Engdall, Jacob Jeremiah Ferguson and his attorney EdmundSpinney, this office agrees it will not file charges against Mr. Ferguson for his actions in
connection with the arson at Jefferson Poplar Farms, 79114 Collins Rd., Clatskanie,
Oregon, on or about May 21,2001.
Columbia County District Attorney
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September 10,2004
The Honorable Harold V. MoneyhunSweetwater County Attorney
731 C Street
Rock Springs, WY 82901
Re: Jacob Jeremiah Ferguson
Dear Mr. Moneyhun:
This letter is in regard toour conversationconcerning thehorse release and attemptedarson at theBLM Wjld Horse Coral, RackSprings, Sweetwater County, Wyoming, on or about
October I , 998.
In our conversation you advised me hat ifMr. Ferguson enters a plea of guilty to onecount of arson in the District of Oregon in Federal Court pursuant to the terms of the
cooperation agreement, your office might be willing to forego prosecution of him for thesematters. By this letter, I am requesting confirmation as to whether charges would be filed.
If there is any additional information you would like me to provide,please letmeknow.
I can be reached at 541-465-6946. Thank you for your consideration of and assistance with
this matter.
Very truly yours,
KARIN J. IMMERGUT
United States AttorneyDistrict of Oregon
KIRK A. ENGDALL
Assistant United States Attorney
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SEP-18-2BW 09:17
Page 2 of 2
FBI EUGENE
IfJacob Jeremiah Ferguson enters a plea ofguilty to a federal felony arson chargein the district of Oregon in accordance with the terms of the cooperation agreement
between AUSA Kirk A, Engdall, Jacob Jeremiah Ferguson and his attorney EdmundSpinney, this office agrees it wilt not file charges against Mr. Ferguson for his actions inconnectionwith the offenses arising out: of the horse releaseand attempted arson at the
BLMWild HorseCoral,RockSprings, SweetwaterCounty,Wyoming, on orabout October11, 1998.
9/H/ySIGNATURE DATE
SWEETWATER COUNN ATTORNEY
TOTAL P .02
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U.S. Departmentof JusticeKarin J. lmmergutUnited States AttorneyDistrict of Oregon701 High Street Office: (541) 465-6771Eugene, OR 7401 Fax: (54 ) 465-6582
September 10,2004
First Assistant U.S. Attorney John GreenDistrict of Wyoming
2120 Capitol Avenue, Room4002Cheyenne, WY 82001
Re: Jacob Jeremiah Ferguson
Dear Mr. Green:
This letter is in regard to our conversation concerning the potential prosecutionbyyour
ofice of Jacob Jeremiah Ferguson, for offenses arising out of the horse release andattempted arson at BLM Wild Horse Corral, Rock Springs, Sweetwater County, Wyomingonor about October 11, 1998.
In our conversation you advised me that if Mr. Ferguson enters a plea of guilty to onecount of arson in the District of Oregon in Federal Court pursuant to the terms of the
cooperation agreement, your office might be willing to forego prosecution of him for these
matters. By his letter, Iam requesting confirmation as to whether charges would be filed.
Ifthere is any additional nformation youwould likeme to provide, please letmeknow.Ican be reached at 541-465-6946. Thank you for your considerationofand assistancewiththis matter.
Very truly yours,
KARINJ. IMMERGUT
United States AttorneyDistrictof Oregon
KIRK A. ENGDA~L
Assistant United States Attorney
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Page 2 of 2
If Jacob Jeremiah Ferguson enters a plea of guilty to a federal felony arson chargein the district of Oregon in accordance with the terms of the cooperation agreementbetween AUSA Kirk A, Engdall, Jacob Jeremiah Ferguson and his attorney EdmundSpinney, this office agrees it will not file charges against Mr. Ferguson for his actions inconnection with horse release and attempted arson at BLM Wild Horse Corral, RockSprings, Sweetwater County, Wyoming on or about October 11, 1998.
5 S e @yJOHN GREEN Date
First Assistant US.Attorney
Districtof Wyoming