Robett W. Rainwater 

Rainwater Law Group 

1327 SE Tacoma Street, Suite 239 

Portland, OR 97202 

U.S. Depal'tment of Justice 

Billy J. Williams 

United States Attomey 

District of Oregon 

1000 SW Third Avenue, Suite 600 

Portland, OR 97204-2902 

June 8, 2016 

Re: United States v. Jason Blomgren, Case No. 3:16-CR-00051-BR-21 

Plea Agreement Letter 

Dear Mr. Rainwater: 

(503) 727-1000 

Fax (503) 727-1117 

1. Parties/Scope: This plea agreement is between this United States Attorney's Office 

(USAO) and defendant, and thus does not bind any other federal, state, or local prosecuting, 

administrative, or regulatory authority. This agreement does not apply to any charges other than 

those specifically mentioned herein. 

2. Charges: Defendant agrees to plead guilty to Count 1 of the Superseding Indictment, 

which charges Conspiracy to Impede Officers of the United States, in violation of Title 18, United 

States Code, Section 372. 

3, Penalties: The maximum sentence is 6 years' imprisorunent, a fine of$250,000, 

3 years of supervised release, and a $100 fee assessment. Defendant a1,,>rees to pay the fee 

assessment by the time of entry of guilty plea or explain to the Court why this caru10t be done, 

4. Dismissal/No Prosecution: The USAO will move at the time of sentencing to dismiss 

any remaining counts against defendant. The USAO futther agrees not to bring additional 

charges against defendant in the District of Oregon arising out of this investigation, !mown to the 

USAO at the time of this agreement. 

5. Sentencing Factors: The parties agree that the Court must first determine the applicable 

advisory guideline range, then dete1mine a reasonable sentence considering that range and the 

factors listed in 18 U.S.C. § 3553(a). Where the parties agree that sentencing factors apply, such 

agreement constitutes sufficient proof to satisfy the applicable evidentiary standard. 

Revised 04/12/16 

Case 3:16-cr-00051-BR Document 724 Filed 06/16/16 Page 1 of 5
Robert W. Rainwater 

Re: Jason Blomgren Plea Letter 

June 8, 2016 

Page2 

6. Acceptance of Responsibility: Defendant must demonstrate to the Court that he fully 

admits and accepts responsibility under U.S.S.G. § 3El. l for his unlawful conduct in this case. If 

defendant does so, the USAO will reconunend a three-level reduction in defendant's offense level 

(two levels if defendant's offense level is less than 16). The USAO reserves the right to change 

this recommendation if defendant, between plea and sentencing, commits any criminal offense, 

obstructs or attempts to obstruct justice as explained in U.S.S.G. § 3Cl. l, or acts inconsistently 

with acceptance ofresponsibility as explained in U.S.S.G. § 3El.1. 

7. Guideline Calculation: The parties agree that defendant's advisory guideline calculation 

is as follows: 

• Base Offense Level is 10 under U.S.S.G. § 2Xl. l(a) and U.S.S.G. § 2A2.4(a). 

• Because a dangerous weapon (including a firearm) was possessed and its use was 

threatened, a 3-level upward adjustment applies under U.S.S.G. § 2A2.4(b)(l)(B) and 

U.S.S.G. § 1B l.3(a)(l )(B). 

• Because the offense was calculated to influence or affect the conduct of govenunent by 

intimidation or coercion, or to retaliate against government conduct, a 3-level upward 

departure applies under Application Note 4 to U.S.S.G. § 3Al .4. 

• For defendant's acceptance ofresponsibility, a 3-level downward adjustment applies 

under U.S.S.G. § 3El. l. 

• For defendant's early disposition of this complex case, a 3-level downward variance 

applies under 18 U.S.C. § 3553(a). 

The parties anticipate that defendant's Total Offense Level will be 10, based on the calculation 

above. The parties are making no agreement with respect to defendant's Criminal History 

Category. 

8. Sentencing Recommendation: So long as defendant continues to demonstrate an 

acceptance ofresponsibility and qualifies for the downward variance under 18 U.S.C. § 3553(a), 

the government agrees to recommend a sentence at the low end the resulting Total Offense Level. 

Defendant may recol11111end any sentence he deems appropriate. 

9. Abandonment of Firearm(s)/Pl'Operty: By signing this agreement, defendant hereby 

voluntarily abandons all right, title, and interest to any property, firearms, and ammunition that 

were seized by law enforcement in this investigation. Defendant also agrees not to file a claim, 

and to withdraw any claim already filed, to any such prope1iy in any civil proceeding which has 

been or may be initiated. Defendant further waives the right to notice of any forfeiture 

proceeding involving this prope1iy and agrees not to assist others in filing a claim in any forfeiture 

proceeding. 

Revised 04/12/16 

Case 3:16-cr-00051-BR Document 724 Filed 06/16/16 Page 2 of 5
Robett W. Rainwater 

Re: Jason Blomgren Plea Letter 

June 8, 2016 

Page 3 

10. Restitution: The Court shall order restitution to each victim in the full amount of each 

victim's losses as required by law and determined by the Comt. Defendant agrees to pay 

restitution for all losses caused by defendant's conduct, regardless of whether counts of the 

indictment or information dealing with such losses will be dismissed as pmt of this plea agreement. 

Defendant agrees that, while the district court sets the payment schedule, this schedule may 

be exceeded if and when defendant's financial circumstances change. In that event, and 

consistent with its statutory obligations, the United States may take any and all actions necessary 

to collect the maximum amount of restitution in the most expeditious manner available. 

Defendant agrees fully to disclose all assets in which he has any interest or over which the 

defendant exercises control, directly or indirectly, including those held by a spouse, nominee, or 

third party. Defendant agrees to trnthfully complete the financial statement form provided herein 

by the earlier of 14 days from defendant's signature on this plea agreement or the date of 

defendant's entry of a guilty plea, sign it under penalty of pe1jury and provide it to both the United 

States Attorney's Office and the United States Probation Office. Defendant agrees to provid'e 

updates with any material changes in circumstances, as described in 18 U.S.C. § 3664(k), which 

occur prior to sentencing, within seven days of the event giving rise to the changed circumstances. 

Defendant expressly authorizes the U.S. Attorney's Office to obtain a credit repmt on him. 

Defendant agrees to provide waivers, consents, or releases requested by the U.S. Attorney's Office 

to access records to verify the financial information, such releases to be valid for a period 

extending 90 days from the date of sentencing. Defendant also authorizes the U.S. Attorney's 

Office to inspect and copy all financial documents and information held by the U.S. Probation 

Office. 

Defendant's failure to timely and accurately complete and sign the financial statement, and 

any update thereto, may, in addition to any other penalty or remedy, constitute the defendant's 

failure to accept responsibility under U.S.S.G. § 3El .1. 

11. Waiver of Appeal/Post-Conviction Relief: Defendant knowingly and voluntarily 

waives the right to appeal from any aspect of the conviction and sentence on any grounds, except 

for a claim that: (1) the sentence imposed exceeds the statutory maximum, or (2) the Court arrives 

at an advisory sentencing guideline range by applying an upward departure under the provisions of 

Guidelines Chapters 4 or SK, or (3) the Comt exercises its discretion under 18 U.S.C. § 3553(a) to 

impose a sentence which exceeds the advisory guideline sentencing range as determined by the 

court. Should defendant seek an appeal, despite this waiver, the USAO may take any position on 

any issue on appeal. Defendant also waives the right to file any collateral attack, including a 

motion under 28 U.S.C. § 2255, challenging any aspect of the conviction or sentence on any 

grounds, except on grounds of ineffective assistance of counsel, and except as provided in Fed. R. 

Crim. P. 33 and 18 U.S.C. § 3582(c)(2). 

Revised 04/12/16 

Case 3:16-cr-00051-BR Document 724 Filed 06/16/16 Page 3 of 5
Robert W. Rainwater 

Re: Jason Blomgren Plea Letter 

June 8, 2016 

Page4 

12. Court Not Bound: The Comt is not bound by the reconunendations of the paiiies or of 

the presentence report (PSR) wtiter. Because this agreement is made under Rule 1 l(c)(J)(B) of 

the Federal Rules of Criminal Procedure, defendant may not withdraw any guilty plea or rescind 

this plea agreement if the Court does not follow the agreements or recommendations of the pa1ties. 

13. Full Disclosure/Reservation of Rights: The USAO will fully inform the PSR writer and 

the Court of the facts and Jaw related to defendant's case. Except as set forth in this agreement, 

the parties reserve all other rights to make sentencing recommendations and to respond to motions 

and arguments by the opposition. 

14. Breach of Plea Agreement: If defendant breaches the terms of this agreement, or 

commits any new criminal offenses between signing this agreement and sentencing, the USAO is 

relieved of its obligations under this agreement, but defendant may not withdraw any guilty plea. 

Defendant understands that any breach of this agreement will result in the govermnent not 

recommending a downward variance under 18 U.S.C. § 3553(a) for early disposition, and that a 

breach may result in the govermnent taking the position that the defendant has not accepted 

responsibility under U.S.S.G. § 3EJ. I. 

If defendant believes that the government has breached the plea agreement, he must raise 

any such claim before the district comi, either prior to or at sentencing. If defendant fails to raise 

a breach claim in district court, he has waived any such claim and is precluded from raising a 

breach claim for the first time on appeal. 

15. Memorialization of Agreement: No promises, agreements or conditions other than 

those set forth in this agreement will be effective unless memorialized in writing and signed by all 

paities listed below or confirmed on the record before the Coutt. If defendant accepts this offer, 

please sign and attach the original of this letter to the Petition to Enter Plea. 

Revised 04/12/16 

Case 3:16-cr-00051-BR Document 724 Filed 06/16/16 Page 4 of 5
Robert W. Rainwater 

Re: Jason Blomgren Plea Letter 

June 8, 2016 

Page 5 

16. Deadline: This plea offer expires if not accepted by June 15, 2016, at 5:00 p.m. 

Sincerely, 

BILLY J. WILLIAMS 

United States Attorney 

,-..-c/l 

'/ 

,::;~~-~:J~IGLH-,Trz>l::;;c ___ ,? 

GEOFFREY A. BARROW 

CRAIG J. GABRIEL 

Assistant United States Attorneys 

I hereby freely and voluntarily accept the terms and conditions of this plea offer, after first 

reviewing and discussing every part of it with my attorney. I expressly waive my right to appeal 

as outlined in this agreement. I am satisfied with the legal assistance provided to me by my 

attorney. I wish to plead guilty because, in fact I m uilty. 

&hd>)lb 

Date 

l represent defendant as legal counsel. I have carefully reviewed and discussed every patt 

of this agreement with defendant. To my lmowledge, defendant's decisions to enter into this 

agreement and to plead guilty are informed an5Jd)lG~~~~ 

Revised 04/12/f6 

W. RAINWATER 

Attorney for Defendant 

Case 3:16-cr-00051-BR Document 724 Filed 06/16/16 Page 5 of 5