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IN THE UNITED STATES DiSTR:CT COuRT

FOR THE DiSTR:CT OF COLORADO

cnmina:ActiOn No ll‐ cr‐ 00430‐ CMA

UNITED STATES OF AMERiCA,

Plainlt

V

2. MARIE DALTON,

Defendant.

PLEA AGREEMENT

The United Slates of America (the government), by and through Christine E.

Kenney and Richard L. Hathaway, Special Counsel for the District of Colorado, and the

defendant, Marie Dalton, personally and by counsel, Thomas E. Goodreid, submit the

following Plea Agreement pursuant to D.C.COLO.LCTR 11.'l and Fed. R. Crim. P.

t 1(c)(1)(B). lt is a condition of this Plea Agreement that the Court accept the terms of

the Plea Agreement between co-Defendant Richard Dalton and the government.

Should the Court reject that Plea Agreement, Defendant Marie Dalton shall have the

right to withdraw her guilty plea under this Plea Agreement.

I. AGREEMENT

The defendant agrees to plead guilty to Count One of the lndictment, charging a

violation of 18 U.S.C. g 371 , Conspiracy to Commit Mail Fraud, Wire Fraud, and Money

Laundering. The defendant does so knowingly and volunlarily. ln return, at the time of

GOVERNMENT

EXHIB:T

1

COURT EXH:B!T

1

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sentencing,the goVernment agrees tO diSmiSS COunts TWO thrOugh Nineteen ofthe

lndictment pending againstthe defendant ThiS plea agreementis subnlitted pursuant

to Fed.R.Cnm P ll(c)(1)(Al and(Cl(1)(B)

The government agrees that,proVided the defendant dOes nothing inconsistent

with her acceptance of responSib‖ ity bet′′ een the entry of her plea of gunty and

sentencing,it wi‖ lle a mOtiOn Seeking a three(3)leVel reduCtiOn in the Offense ievel

based On acceptance of reSponSib‖ ity under u S S G§ 3El l(a)and(b).

.ELEMENTS OF THE OFFENSE(Sゝ

Thepartiesagreethattheelementsoftheoffensetowhichthispleaisbeing

tendered are as follows:

The elements of Conspiracy in viotation of 18 U'S'C $ 371 are:

A. the defendant agreed wiih at least one other person to violate the law'

B. one ofthe conspirators engaged in at least one overt act furthering the

consPiracY's objective'

C. the defendant knew the essential obiective of the conspiracy'

D. the defendant knowingly and voluntarily participated'

E.thereWaSinterdependenceamongthemembersoftheconspiracy;thatis'

the members, in some way or manner' intended to act together for their

shared mutual benefit within the scope of the conspiracy charged'

The maXimum statutOry penalty fOr a viO!ation of18 U S C§

371 lsi not more

than 5 yearS(60 months)implSOnment;nOt more than S250,000 1ne,Or bothi not more

than 3 years superViSed re!eaSei$100 Speclal assessmentfeei p!us restitution and

2

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forfeiture as described below.

It probation or supervised release is imposed, a violation of any condition of

probation or supervised release may result in a Separate prison sentence and additional

supervision.

IV. COLLATERAL CONSEQUENCES

The conviction may cause the loss of civil rights, including but not limited to the

rights to possess firearms, vote, hold elected office, and sit on a lury.

V. STIPULATION OF FACTS

The parties agree that there is a factual basis for the guilty plea that the

defendant will tender pursuant to this plea agreement. That basis is set forth below.

Because the Court must, as part of its sentencing methodology, compute the advisory

guideline range for the offense[s] of conviction, consider relevant conduct, and consider

lhe other factors set forth in '18 U.s.c. $ 3553, additional facts may be included below

which are pertinent to those considerations and computations. To the extent the parties

disagree about the facts set forth below, the stipulation of facts identifies which facts

are known to be in dispute at the time of the execution of the plea agreement.

This stipulation of facts does not preclude either party from hereafter presenting

the Court with additional facts which do not contradict facts to which the parties have

stipulated and which are relevant to the Court's guideline computations, to other 18

U.S.C. S 3553 factors, or to the Court's overall sentencing decision.

' The parties agree that the date on which relevant conduct began is on or about

2007.

The parties agree as fgllows:

rr3

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The defendant,Marie Dalton,at a‖ times relevantto the charges in the

:ndictment,Was married to her CO‐ defendantin thiS Case,Richard Dalton Beginning in

2007,and Continuing through 201 0,the Daltons'primary source ofincome was from a

company founded by Richard DaltOn based in Golden,Co:Ora00,Ca‖ ed Universal

Consuling Resources LLC(“ UCR"))a‖mled‖ab‖ ity∞mpany formed in New MexiC。

Richard Da:ton Operated UCR from hiS residence at 927 Coie Streetin Goldenl

Colorado(the“ Cole Street P「Openプ UCR alSO used a UPS bOX,Iocated at 14405 W

cOrax Ave,Suite 292,Go!den,Co10rado

Through UCR,the DaLons SO‖Cited investors to purchase interests in investment

contractS,general!y referred tO as eitherthe``Trading Program,"Or the“ Diamond

Program" The Trading Program began in approXirnately 2007,and the Diamond

Program began in approximately 2009 1nVestorS Signed the UCR“ lnvestment

structure Agreement,"whiCh Stated that investOrs'money WOu!d be piaced into an

escroW account,and transferred as necessary to UCR trading accOunts,and thatthe

escrOW account would be uSed tO receive prttts from inVestments

Fo「 bOth the Trading Program and Diamond Program,inVestors were guaranteed

a specllC rnonthly return. The Daltons told inVeStors that the investment∞

ntracts Were

extremely 10W ISk ln addilOn,the lnVestment Structure Agreement stated,“

UCR,LLC

account rnanagementis re‐ enfOrced by the evaluation oftOp professionai and HCensed

Third Paw SeIViCes in inveStment and trade transaCtiOns."The investment StruCture

Agreement alsO provided,“[aln investO「 Can CanCe!this Agreement at any lme and

request that a‖ rnoney as principalinvestment and a‖ Other proceeds frOm proflts be

returned."The investment Structure Agreementforthe Diamond Program was neany

4

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identical to that of the Trading Program, except that the deflnition of 'Financial

lnstruments," to be traded for profit, was expanded to include "precious stones.

lnvestor funds were deposited into UCR's Bank of America account # xxxx

xxxx 4794, located in New Mexico, and checks for purported profit payments back to

investors were written on this account. Both Richard Dalton and Marie Dalton had

signatory authority over the ucR bank account, and were both "Member/Managers" of

UCR.

lnvestors from thirteen states and five foreign countries invested approximately

$17,OOO,OOO in UCR. The Daltons made false statements to these investors, including:

retums were guaranteed, typically in the range ot 48 1o 120% annually; returns would

be paid monthly from profitable intemational note trading and diamond trading; the ucR

investment programs were extremely low risk; investors'money could be returned at

any time; UCR accounts were evaluated by top professional and licensed Third Party

services; and, the invested funds would be held safely in an escrow account at a bank

in the United Statds, and that a European trader (often referred to simply as'the

Trader,,, but never known or referred to by name), would use lhe value of that account,

but not the actual funds, to obtain leveraged funds to purchase and sell bank notes.

Richard Dalton and Marie Dalton both told some investors that the UCR investment

programs were extremely low risk. These statements were false. UCR was operated

as a classic Ponzi scheme, wherein investor funds were commingled and used to pay

out purported profits to early investors to create the false appearance that the

investments were performing as promised.

At times, Marie Dalton performed bookkeeping duties for UCR, and participated

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in recruiting investors. Along with her husband, Richard Dalton, Marie Dalton engaged

in discussions with potential investors regarding the investments. Marie Dahon

established the email accrunt to which investors were directed to send investment

questions.

The Daltons used investor funds to pay personal expenses. For example,

Richard Dalton caused the wire transfer of $910,000 of UCR investor funds to purchase

the Cole Street Property in Marie Dalton's name. Originally, UCR was the purchaser,

but the contract was transferred from UCR to Marie Dalton. Also, Marie Dalton wrote

checks on the UCR bank account, and drafted a check from ihis account to Burt Toyota

to purchase a 20OB Toyota Highlander registered to UCR. Marie Dalton drafted some

of the checks for payment to UCR investors, and Richard Dalton signed the checks.

Marie Dalton indicated on some of these checks an amount remaining. Marie Dalton

also draffed a $35,000 check to Wheat Ridge Dental for payment of Richard Dalton's

dental work. All the deposits into the UCR bank account came from investor payments.

Marie Dalton purchased the Cole Street property wilh funds Richard Dalton

transfened from the UCR bank account to Arcanum Commodities Group, where the

funds were deposited into an account at a toreign financial institution. On April 22,

2008, Richard Dalton transferred $500,000 from the UCR Bank of America account #

XXXX XXXX 4794 to Deutsche Bank account # XXXX1229, located in Singapore. On

April 23, 2008, Richard Dalton transfened another $500,000 from the UCR Bank of

America account # XXXX XXXX 4794 to the same Deutsche Bank account #

XXXX1229. On July 2,2009, the Dallons caused $910,298.08 of the UCR investor

funds to be transferred from Liechtensteinische Landesbank, located in Zurich,

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t.

switzerland, into the State of Colorado for the purpose of purchasing the Cole street

proPertY'

The Daltons,famlly members received substantialpayments from the ucR bank

account. one of the Datton's daughters received $118'050 and anothar of the Daltons'

daughtersreceived$2S6,660.PaymentsfromfioUCRbankaccounttoDaltonfamily

membere totaled $660,710' compared to $173'000 in paymentsfrom famlly members

toUeR.NeitherRtchardDaltonnorMarleDaltonmadeanypaymentstoUCR.

ynZalo,uponleamingthatRichardDaltonandUCRwereunderlnvestigationby

the securities and Exchange commission, an entlty of the United states whose mission

is to protoct investors, maintaln fair, orderly, and etficient markets' and facllitate capital

formationtheDaltonsdiscontlnuedmakingpurportedprofitpayrnentstoinvestorswhlch were in fact simply eomrninglod funds of new investqrs- and commenced lultirg

activtties, including but not limited to:

A.falselyrepresentingtolnvestorsthattheyshouldexpectfundssoon:

B.falselyrepresentingtoinvestorsthat',theTrade/,UCRwasusinghadto

switch banks causlng delaYs;

C. tatsely representing that investors could request a return of their

investmentandtherequestwouldbehonoredinaccordancewiththeagreement,

ultimatelyrepresentingthatUCRwouldreturninvestorfundsonorbeforeAugust20l0;

and g6orl oe lla \1,?* Ld eltD., 1 fatse;';;;tstrng in septernber 2010, lhar ucR was liquldating a caehe

ofdiamondstopayinvestorfundsback.butthataplanecarryingthediamondshadthe

numberthreeenginegooutandhadtolandlnAmsterdamithatamongs0,000carats

7

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were 18,000 fake diamonds; and other fraudulent lulling statements. On August 20,

2010, Marie Dalton left an outgoing message on the UCR voicr mailbox for investors

represenling that checks were going out soon in the order of an investors' contribution

to the programs, and promised that everyone would be repaid in the next two to three

weeks.

On 81251201Q the SEC attempted to depose Richard Dalton concerning his and

Marie Dalton's activities related to UCR. Richard Dalton mostly refused to answer

questions, asserting his Fifth Amendment right. On October 7, 2010, the SEC deposed

Marie Dalton concerning her and her husband's activities related to UCR. At times,

Marie Dalton declined to answer questions on the basis of spousal communications

privilege and on the basis of a vicarious assertion of her husband's Fifth Amendment

right.

On November 16, 2010, the SEC filed formal action against Richard Dalton and

UCR in the District Court of Colorado and documents were seNed on the Daltons the

same date. On November 20, 2010, the Daltons left together from the United States for

South Africa. Between October 15,2008, and April 1,2O1O, Richard Dalton had

transferred from the UCR bank account $787,525 of investor funds to accounts both

overseas and domestic, controlled by Henry Anthony Montgomery, a friend of lhe

Daltons. The Daltons remained in South Africa until they were detained by South

African authorities on September 28,2011 and forced to relurn to the United States

where they were arrested in Atlanta, Georgia, on September 30,2011, on federal

warrants related to the instant indictment.

The parties agree that the net loss resulting from the defendant,s conduct as set

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forth aboVe iS rnore than S2.5 mi!liOn and less than S7 milliOn.

The parties understand that the imposition of a sentence in this matter is

governed by 18 U.S C' 53553 In determining the particular sentence to be imposed'

the Court is required to consider seven factors' One of those factors is the sentencing

range computed by the Court under advisory guidelines issued by the United States

Sentencing Commission' ln order to aid the Court in this regard' the parties set forth

berow their estimate of the advisory guiderine range calred for by the united states

sentencing Guiderines. To the extent that the parties disagree about the guideline

computations, the recitation below identifies the matters which are in dispute' The

parties have relied upon lhe 2012 U'S'S G' Manual'

2Bl.1(b):

The base guideline is S 281'1(a)(2) with a base offense level of 6'

Thefollowingspecificoffensecharacteristicsapplypursuantto$

1 . An 18-level increase applies under S 281'1(b)(1XJ) because the

loss is more than 2'5 million but less than 7 million'

2. A4-level incleaseappliesunderS 281 I(bX2)(B) becausethe

offense involved 50 or more but less than 250 victims'

3. A 2Jevel increase applies under S 281'1(bxlOXA) and (C)

becausetheoffenseinvolvedsophisticatedmeans,NoTE:The

defendant reseNes the right to contest the application of this twolevel enhancement'

There are no victim-related or multiple count adjustments'

C

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D. The adjusted offense level therefore would be 30'

E.Thedefendantshouldreceivea3.leveldecreaseforacceptanceof

responsibilityunderss3El.l(a)and(b).Theresultingoffenselevelthereforewouldbe

27.

F. The parties understand that the defendants criminal history computation

istentative.ThecriminalhistorycategoryisdeterminedbytheCourtbasedonthe

defendanfs prior convictions. Based on information currently available to the parties, it

isestimatedthatthedefendant,scriminalhistorycategorywouldbel.

G. The career offender/criminal livelihood/armed career criminal adjustments

would not aPPlY.

H,Theadvisoryguide|inerangeresultingfromthesecalculationsisT0-87

months. However, in order to be as accurate as possible, with the criminal history

categoryundeterminedatthistime,theoffenselevelestimatedabovecould

conceivably resuli in a range from 70 months (bottom of category l) to 162 months (top

ofCategoryVl).Theguidelinerangewouldnotexceed,inanycase,theStatutory

maximums applicable to the count of convictlon'

l.PursuanttoguidelineSsEl.2,assumingtheestimatedoffenselevel

above, the fine range for this offense would be $12,500 to up to the maximum

authorized by statute, see u.s.s.G. s 5E1. 2(cX3), plus applicable interest and

penalties.

J. Pursuant lo guideline S 5D1.2, if the Court imposes a term of supervised

release, that term is at least one but not more than 3 years because the count of

conviction is a Class D felonY'

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K Forfeiture of Assets Defendant hnalie Dalton agrees tO fOrfeitto the

United States immediately and VOiuntarily any and a‖ assetS and property,Or portions

thereof,Subiect tO fOrFeture,pursuantto 18 U S C§ 981(a)(1)(C),28 U S.C_§ 2461(c),

and18 U S C §982(a)(1),Whetherin the pOSSession or contro1 0fthe United States or

in the possession or control ofthe defendant or defendanrs nOminees,or elsewhere

The aSSets to be fOrfelted Specttca‖ y include,but are nο t‖mited to:

1.a money,udgmentin the amount Of$5,二 ,__-00,WhiCh Sum

represents the amount of pЮceeds obtained as a resuit ofthe cOnspiracy to

cOmmiVschemeto comml ma‖ and wire fraud:

2 a2008 Toyota Highiander Ltd,VIN」 TEES42A182076495:

3 927 Cole Street,Golden,CO10rado;

4 0ne1/Vebber OM Gutarvvith caSe Sノ N2310,seized frOm Richard and

Marie Dalton on September 30,201li and

5 one 1 05 Caratdiamond,Curren]y partofa 14KT Ye‖oW Gold“ng,

seized from Marie Dalton on September 30,201l The parties understand that,in

Orderto return the 14KT Ye1loW Gold ttng withOutthe 1 05 Carat diamond,Mane Dalton

w‖ lincurthe costs tO haVe a qualtted ieweler extractthe stone

The defendant agrees and cOnsents to the forfeiture ofthese assets pursuant

tO any federal crimina!,CiVit and′Or administrative fOrfeiture actiOn The defendant also

hereby agrees thatthe Forfeiture desCribed herein iS not eXCessive and,in any event,

the defendant Waives any constitutional ciaimS thatthe defendant rnay have

The Unlted States agrees nottO pursue forfeiture of 14706 Columbine Street,

Brighton,Colorado thrOugh any civi1 0r criminalfOrfeiture actiOn related to the conduct

ll

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described in the Factual Basis.

ThedefendantadmitsandagreesthattheconductdescribedintheFactual

Basisaboveprovidesasufficientfactualandstatutorybasistoestablishthatthe

requisitenexusexistsbetweenthespeciflcpropertysubjecttoforfeitureandthe

offenses to which defendant is pleading guilty' Pursuant to the provisions of Rule

32'2(bX1),theUnitedStalesandthedefendantrequestthatatthetimeofaccepting

thispleaagreement,theCourtfindthatthegovernmenthasestablishedtherequisite

nexus and enter a preliminary order of forfeiture'

DefendantfurtheragreestotakeallstepsnecessarytopasstitletotheUnited

States. These steps include, but are not limited to; the surrender of title, the signing of

a consent decree of forfeiture, and signing of any other documents necessary to

effectuate such transfers. To that end, defendant agrees fully to assist the government

intherecoveryandreturntotheUnitedStatesofanyassets,orportionsthereof,as

described above wherever located. The defendant agrees to make a full and complete

disclosure of all assets over which defendant exercises control and those which are

held or controtled bY a nominee.

The defendant agrees that the United states is not limited to forfeiture of the

propertydescribedabove.lftheUnitedStatesdeterminesthatpropertyofthe

defendant identified for forfeiture cannot be located upon the exercise of due diligence;

has been transferred or sold to, or deposited with, a third party; has been placed

beyond the jurisdiction of the court; has been substantially diminished in value; or has

been commingled with other property which cannot be divided without difficulty; then

the United States shall be entitled to forfeiture of any other property (substitute assets)

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of the de{endant up to the value of any property described above pursuant to 21 U'S'C'

S 853(p) and Federal Rutes of Criminal Procedure 32'2(e)' This Court shall retain

jurisdicliontosettleanydisputesarisingfromapplicationofthisclause.Thedefendant

agrees that forfeiture of substitute assets as authorized herein shall not be deemed an

atteration of the defendant's sentence'

Forfeitureofthedefendant'sassetsshallnotbetreatedassatisfactionofany

fine, restitution, cost of imprisonment, or any other penalty this Court may impose upon

thedefendantinadditiontoforfeiture.TheUnitedStatesAttorney,sofficeforthe

District of Kansas, as special counsel, will recommend to the Attorney General that any

netproceedsderivedfromthesaleofthejudiciallyforfeitedassetsberemittedor

restored to eligible victims of the offenses, for which the defendant has pleaded guilty'

pursuant to 1 I U S'C. S 981(e), 28 C'F'R pt 9' and any other applicable laws' The

defendantunderstandsthattheUnitedStatesAttorney,sofficehasauthorityonlyto

recommendsuchreliefandthatthefinaldecisionofwhethertograntreliefrestssolely

withtheDepartmentofJustice,whichwillmakeitsdecisioninaccordancewith

applicable law.

L'TheCourtshal|orderrestitutiontothevictimsoftheoffenseschargednot

onlyincountone,thecountofconviction.butalsointheremainingcountsofthe

lndictment.

The parties understand that although the Court will consider the parties'

estimate,theCourtmustmake.ttsowndeterminationoftheguidelinerange.lndoing

so, the Cou( is not bound bythe position ofany party'

No estimate by the parties regarding the guideline range precludes either party

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from asking the court, within the overall context of the guidelines, to depart from that

range at sentencing if that party believes that a departure is specifically authorized by

the guidelines or that there exists an aggravating or mitigating circumstance of a kind,

or to a degree, not adequately taken into consideration by the United States Sentencing

Commission in formulating the advisory guidelines. Similarly, no estimate by the parties

regarding the guideline range precludes eilher party from asking the court to vary

entirely from the advisory guidelines and to impose a non-guideline sentence based on

other 18 U.S.C. S 3553 factors.

The parties understand that the court is free, upon consideration and proper

application of all 18 U.S.c. s 3553 factors, to impose lhat reasonable sentence which it

deems appropriate in the exercise of its discretion and that such sentence may be less

than that called for by the advisory guidelines (in length or form), within the advisory

guideline range, or above the advisory guideline range up to and including

imprisonment for the statutory maximum term, regardless of any computation or

position of any party on any 18 U.S.C. 53553 factor'

VII. ENTIRE AGREEMENT

This document states the parties' entire agreement. There are no other

promises, agreements (or "side agreements"), terms, conditions, understandings, or

assurances, express or implied. ln entering this agreement, neither the government nor

the defendant has relied, or is relying, on any terms, promises, conditions, or

assurances not expressly stated in this agreement'

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02 ,of . 1.1

Marie Dalton

Defendant

2/f′′

2.2-/' t3 lL

Richard L. Hathaway

Special Counsei

Datel

Thomas E. Goodreid

oag: P-a/.

dhristine E. Kenney

15

Attorney for Defendant

Special Counsel

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