ORIGINAL 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

UNITED STATES OF AMERICA 

V. No. y: z.z-CR- a.olo- 0 

CLOIS GLENN RABORN (01) 

PLEA AGREEMENT WITH W AIYER OF APPEAL 

CLOIS GLENN RABORN ("the Defendant"), the Defendant's attorney, and the 

United States of America ("the government"), agree as follows: 

1. Rights of the Defendant: The Defendant understands that he has the 

right: 

2. 

a. to plead not guilty; 

b. to have a trial by jury; 

c. to have his guilt proven beyond a reasonable doubt; 

d. to confront and cross-examine wih1csscs and to call witnesses in his 

defense; and 

e. against compelled self-incrimination. 

Waiver of rights and plea of guilty: The Defendant waives these 

rights, waives any defenses he may have based on any statute of limitations, and pleads 

guilty to the offense alleged in Count One of the Infom1ation, charging a violation of 18 

U.S.C. §§ 225l(a) and (e), that is sexual exploitation of a minor. The Defendant 

understands the nature and clements of the crime to which he is pleading guilty, and 

agrees that the factual resume he has signed is true and will be submitted as evidence. 

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3. Sentence: 

The minimum and maximum penalties the Court can impose include: 

a. a term of imprisonment for not less than fifteen (15) years and not more 

than thirty (30) years; 

b. a fine up to the amount of $250,000, or twice the pecuniary gain or twice 

the pecuniary loss to the victim; 

c. a term of supervised release of any tem1 of years or life but not less than 

five (5) years, which is mandatory under the law and will follow any tenn 

of imprisomncnt. Revocation of the term of supervised release could 

result in an additional period of confinement. If the defendant violates 

any condition of the term of supervised release, the Court may revoke such 

release term and require that the defendant serve an additional period of 

confinement; 

d. a mandatory special assessment of $100; 

e. unless the Court finds the defendant to be indigent, an additional mandatory 

special assessment of $5,000 must also be imposed pursuant to 18 U.S.C. 

~ 3014 for offenses occurring on or after May 29, 2015; 

f. an assessment ofup to $50,000 pursuant to 18 U.S.C. § 2259A; 

g. restitution to the victim or to the community, which may be mandatory 

under the law; 

h. registration as a sex offender under the Sex Offender Registration and 

Notification Act; 

1. costs of incarceration and supervision; and 

J. forfeiture of property. 

4. 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 his attorney, but understands no one can predict with certainty the outcome of the 

Court's consideration of the guidelines in this case. 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, and he will not be allowed to withdraw his plea if his 

sentence is higher than expected. 

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5. Mandatory special assessment: The defendant agrees to pay to the U.S. 

District Clerk the amount of $100, and pursuant to 18 U.S.C. § 3014(a), an additional 

amount of $5,000, in satisfaction of the mandat01y special assessment in this case. 

6. Restitution. Pursuant to 18 U.S.C. §3663(a), the defendant agrees to 

pay restitution for losses resulting from all the defendant's criminal conduct, including 

relevant conduct and other criminal conduct related or similar to the defendant's offense 

of conviction, and understands that restitution will not be limited to losses stemming from 

the offense of conviction alone. The defendant agrees to cooperate fully in the 

identification of assets to be applied toward restitution. The defendant's cooperation 

obligations include: (A) fully and truthfully completing the Department of Justice's 

Financial Statement of Debtor form, and any addcndums to said f01n1 deemed necessaiy 

by the government, within ten days of the guilty plea hearing; (B) submitting to a 

financial deposition or interview (should the government deem it neccssa1y) prior to 

sentencing regarding the subject matter of said f01n1; (C) providing any documentation 

within the defendant's possession or control requested by the govermncnt regarding the 

defendant's financial condition; and (D) fully and truthfully answering all questions 

regarding the defendant's past and present financial condition in such intcrview(s). 

7. 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 information, or seized or 

restrained in the investigation underlying the infonnation, including the forfeiture of: 

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• a silver HP Laptop computer serial number 5CH1411BW3 with Lite-On LA512M3S-Zl 512GB SSD serial number 002241118539; and 

• a Silver MultiCard 16GB USB serial number 0XECC3800678047. 

The defendant agrees that this property is subject to forfeiture under 18 U.S.C. § 2428. 

The defendant consents to entry of any orders or declar<ltions 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 truthf-ul information and evidence necessary for the government to forfeit such 

property. The defendant agrees to hold the government, its officers, agents, and 

employees hannless from any claim whatsoever in connection with the seizure, 

forfeiture, storage, or disposal of such property. 

8. Destruction of property: The defendant waives and abandons any and 

all right, title, claim or interest, he may have in all property seized during the 

investigation of the defeodant leading to the lnfonnation in this case, which is 

specifically listed below: 

Pica Agreement 

a. Apple iPad 1 - serial number J3039WYWZ38; 

b. Samsung Tablet - serial number R22D300DD0Y; 

c. Sandisk 2GB microSD card; 

d. HP G60 Laptop - serial number 2CE95 l 0G3F with Cmcial 

CT480BX200SSD1 480 GB SSD serial number l 548F0 121 E2A; 

e. WO Passport 2 TB - serial number WXl 1A23H8231; 

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f. SimpleTcch External USB 500 GB Drive - serial number 07CDTU0V; 

g. Dell Latitude C540 Laptop - S/T G7LL33 l with Hitachi DK23EB-20 

IDE 20GB HDD serial number 107201; 

h. PNY 128GB USB Flashdrive; 

1. PNY 64GB USB Flashdrivc; 

J. Superman shaped 8GB USB Flashdrive; 

k. Silver Seagate FreeAgent Desk 1 TB external USB HDD serial number 

2GEV2TK7; 

I. Kingston 8GB SD card; and 

m. Apple iPhone XS 1921 serial number 35726209306396. 

Defendant affirms that no other person has an interest in the listed property and 

agrees that the government may destroy or otherwise dispose of such propc1ty, including 

but not limited to any and all images, files, documents or other information that may be 

eleeh·onically stored on or within the listed property, at its discretion. The defendant 

agrees there was reasonable cause for the seizure of the subject property and releases, 

holds harmless, and forever discharges the government, its officers, agents, servants, and 

employees, its heirs, successors, or assigns, or any state or local authorities, either in their 

official or individual capacities, from any and all claims, causes of action, suits, 

proceedings, debts, dues, contracts, judgments, damages, and/or demands whatsoever in 

law or equity that the defendant and his heirs, successors, or assigns ever had, now have, 

or may have in the future, in relation lo the subject property. The defendant further 

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agrees that he will not seek costs.or attorney fees in connection with the seizure, 

abandonment, or destruction of the subject property. 

9. Defendant's cooperation with financial investigation: In order to 

assist in the collection of fines and restitution, the defendant shall, upon demand, submit 

a personal financial statement under oath and submit to interviews by the government and 

the U.S. Probation Office regarding the defendant's capacity to satisfy any fines or 

restitution. The defendant expressly authorizes the United States Attorney's Office to 

immediately obtain a credit report on the defendant in order to evaluate the defendant's 

ability to satisfy any financial obligation imposed by the Court. The defendant fully 

understands that any financial obligation imposed by the Comt, including a restitution 

order and/or the implementation of a fine, is due and payable immediately. In the event 

the Court imposes a schedule for payment of restitution, the defendant agrees that such a 

schedule represents a minimum payment obligation and does not preclude the U.S. 

Attorney's Office 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. 

10. Defendant's testimony: The defendant is not obligated by this 

agreement to testify in any criminal proceeding related to this case, nor is the defendant 

required to provide testimony concerning any other criminal offenses about which the 

defendant has knowledge. If the defendant chooses to do so, however, the defendant's 

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testimony must be complete and tmthful. Incomplete or dishonest testimony will 

constitute a breach of this agreement. 

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 and will move to dismiss, at sentencing, any remaining 

counts other than those to which the defendant is pleading guilty. 

12. Violation of agreement: The defendant understands that if the 

defendant violates any provision of this agreement, or if the defendant's guilty pica 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. In such 

event, the defendant waives any 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 objection to the use against the defendant of any information or 

statements the defendant has provided to the govcnm1ent, 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. Representation of counsel: The defendant has thoroughly reviewed all 

legal and factual aspects of this case with the defendant's lawyer and is fully satisfied 

with that lawyer's legal representation. The defendant has received from the 

defendant's lawyer explanations satisfactory to the defendant concerning each paragraph 

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of this plea agreement, each of the defendant's rights affected by this agreement, and the 

alternatives available to the defendant other than entering into this agreement. Because 

the defendant concedes that the defendant is guilty, and after confening with the 

defendant's lawyer, the defendant has concluded that it is in the defendant's best interest 

to enter into this pica agreement and all its terms, rather than to proceed to trial in this 

case. 

15. Waivc1· of right to appeal or otherwise challenge sentence: The 

defendant waives the defendant's rights, confen-ed by 28 U.S.C. § 1291 and 18 U.S.C. § 

3742, to appeal the conviction, sentence, fine, order of restitution, and order of forfeiture. 

The defendant further waives the defendant's right to contest the defendant's conviction, 

sentence, fine, order of restitution, and order of forfeiture in any collateral proceeding, 

including proceedings under 28 U.S.C. § 2241 and 28 U.S.C. § 2255. The defendant, 

however, reserves the rights to bring (a) a direct appeal of (i) a sc~ltcncc exceeding the 

statutory maximum punishment, or (ii) fill arithmetic enor at sentencing; (b) to challenge 

the voluntariness of this plea of guilty or this waiver; and ( c) to bring a claim of 

ineffective assistance of counsel. 

16. Limitation of Agreement: This agreement is limited to the United States 

Attorney's Office for the Northern Dish·ict of Texas and docs not bind any other federal, 

state, or local prosecuting authorities, nor docs it prohibit any civil or administrative 

proceeding against the defendant or any property. 

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17. Entirety of agreement: This document is a complete statement of the 

parties' agreement and may not be modified unless the modification is in writing and 

signed by all parties. 

AGREED TO AND SIGNED this J ,tb day of ;(,1 vi vl l , 2022. 

;, /l . CHAD E. MEACHAM /! ~ UNITEDSTATESATTORNEY 

i '------',f~ / __ "11D~ 

CLOIS GLENN RABORN 

Defendant 

ATTICUS GILL 

Attorney for Defendant 

BRANDIE WADE 

Assistant United States Attorney 

Texas State Bar No. 24058350 

Burnett Plaza, Suite 1700 

801 Cheny Street, Unit #4 

Fort Wmth, Texas 76102 

Telephone: 817-252-5200 

Facsi ·1c: 817-252-5455 

I have rea~ _2:ad i-y· to me this plea agreement and have carefully reviewed 

eve1y part of it 1 my tt ·ney. I fully understand it and voluntarily agree to it. 

CLOIS GLENN RABORN 

of 2 /2 Q, Date / / 

Defendant 

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I am the defendant's attorney. I have carefully reviewed every part of this plea 

agreement with the defendant. To my knowledge and belief, my client's decision to 

enter into this plea agreement is an informed and voluntary one. 

Date I I 

Attorney for Defendant 

I have been advised, and understand, that under the Sex Offender Registration and 

Notification Act, a federal law, I must register and keep the registrntion cunent in each of 

the followingjurisdietions: where I reside; where I am an employee; and where I am a 

student. I understand that the requirements for regish·ation include providing my name, 

my residence address, and the names and addresses of any places where I am or will be 

an employee or a student, among other infonnation. I fmiher understand that the 

requirement to keep the registration current includes informing at least one jurisdiction in 

which I reside, am an employee, or am a student not later than three business days after 

any change of my name, residence, employment, or student status. I f1.irther understand 

that I am required to provide information relating to my intended travel outside the 

United States. I have been adviss.q, and understand, that failure to comply with these 

obligations subjects IJ'l11/tO pro~ cG/ic_ln for failure to register under federal law, 18 U .S.C. 

~2250, which is Us/4? fine or impris;7~r r; q 

ORN Date 

Defendant 

Date 

Attorney for Defendant 

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