JOINT STIPULATION REGARDING RESTITUTION

JEFFREY T. MILLER, District Judge.

The United States of America, by and through its counsel, Adam L. Braverman, United States Attorney, and Timothy D. Coughlin, Assistant United States Attorney, together with defendant Timothy Arthur Campbell both individually and through his attorney, and counsel Ezekiel E. Cortez, hereby STIPULATE that:

1. The parties will jointly recommend that defendant pay restitution in the amount of $60,000.00 and that the Court shall order that amount payable forthwith.

2. Defendant agrees and understands that any payment schedule imposed by the Court is without prejudice to the United States to take all actions and take all remedies available to it to collect the full amount of the restitution.

3. Defendant agrees that the restitution, restitution judgment, payment provisions, and collection actions of this plea agreement are intended to, and will, survive defendant, notwithstanding the abatement of any underlying criminal conviction after the execution of this agreement.

4. The restitution described above shall be paid through the Office of the Clerk of the District Court by bank or cashier's check or money order made payable to the "Clerk, United States District Court."

5. Further, the restitution described above shall be paid to or on behalf of the following victim(s):

6. Defendant agrees and consents that, upon execution of this Stipulation, the United States is authorized to run credit reports on the defendant and to share the reports with the Court and the U.S. Probation Office. In addition, defendant agrees that, not later than 30 days from the date of this Stipulation, defendant shall provide to the United States, under penalty of perjury, a financial disclosure form listing all defendant's assets and financial interests valued at more than $1,000. Defendant understands that these assets and financial interests include all assets and financial interests in which defendant has an interest, direct or indirect, whether held in defendant's own name or in the name of another, in any property, real or personal. Defendant shall also identify all assets valued at more than $5,000 which have been transferred to third parties since June 13, 2017, the date of arrest or notice of law enforcement investigation including the location of the assets and the identity of the third party(ies).

7. The parties will jointly recommend that as a condition of probation or supervised release, defendant will notify the Financial Litigation Unit, United States Attorney's Office, of any interest in property obtained, directly or indirectly, including any interest obtained under any other name, or entity, including a trust, partnership or corporation after the execution of this stipulation until the fine or restitution is paid in full.

8. The parties will also jointly recommend that as a condition of probation or supervised release, defendant will notify the Financial Litigation Unit, United States Attorney's Office, before defendant transfers any interest in property owned directly or indirectly by defendant, including any interest held or owned under any other name or entity, including trusts, partnerships and/or corporations.

9. In exchange for Defendant's agreeing to this Stipulation, the United States agrees not to seek restitution in an amount greater than $60,000.00.

This stipulation is being entered into freely and voluntarily by all parties.

SO STIPULATED AND AGREED.