Savoie.plea.Agreement.redacted

8/3/2019 Savoie.plea.Agreement.redacted

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Eugene, OR 97401Phonc: (541) 484-1066Attorney forSuzanne Savoie

IN T& UNITED STATE S DISTRICT COURTFOR THE DISTRICT OF OREGON

UNITED STATES OF AMERICA, 1) N o . c R O ~ - ~ D O O ~ O - & &Plaintiff, )1 PETITION TO ENTER PLEA

vs. 1 OF GUILTY, CERTIFICATE1 OF COUNSEL, AND ORDERSUZQNNE SAVOIE, 1 ENTERING PLEA.)Defendant. 1

The defend ant represents to the court:1. My name is Suzanne Savoie. I am 29 years old. I have gone to school up

to and including the 16th grade.2. My attorney is John J. Kolego.3. My attorney and I have discussed my case fully. I'ha ve received a copy of the

Indictmen t or Information . I have read the Indictment or Information, o r it has been read to me,and I have discussed it with my attorney. My attorney has counse led and advised meconcernin g the nature of each charge, any lesser-included o ffense(s), and the possible defensesthat I might have in this case. I have been advised and understand that the elements of th e

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charge(s) alleged against me to w hich I am pleading "GUILTY" e as follows: Count 1 (1 )P~ ~ ~ ~ r8 'c8Beginning in October 1996 and continuing through lB2eember 2001, that I, in the District ofOregon and elsewhere (2 ) did willfully and knowingly conspire (3) to maliciously dama ge ordestroy, or attempt to damage or destroy, by means of fire, buildings, vehicles, and otherpersonal and real property pw ned in wh ole or in part or possessed by, or leased to, the UnitedStates or any departm ent or agency thereof, and o r used in interstate comm erce or in any activityaffecting interstate co mm erce and to knowingly and willfidly da ma ge and attempt to damag ethe property of an energy facility of the United States involved in the transmission of electricity,as set forth in Attachment 1 attached hereto; Count 2 (1) On or about January 2,200 1, at, thatI, at Glendale, Douglas County, in the Distric t of Oregon (2) did unlawfully and willfully (3)caused and aided, abetted, counseled, commanded, induced, and procured the maliciousdamaging and destroying, by means of fire and explosive, of a building and other real andpersonal property used in interstate commerce and used in activities affecting interstatecommerce, namely, a building and its contents located at Superior Lumber Company, 2695Glendale Valley Road, Glendale, Douglas County, Oregon, a s set forth in Attach me nt 1 attachedhereto; C o u n t 3 (1) On or about May 21,2001, at Clatskanie, Colum bia County, that I, in theDistrict of Oregon, (2) unlawfblly and willfully (3)caused and aided, abetted, counseled,commanded, induced, and procured the attempt to damage or destroy, by means of fire and anexplosive, a bu ilding and o ther real and personal property used in interstate commerce and used inactivities affecting interstate commerce, namely, the main o fi c e building and its contents locatedat Jefferson Poplar Farm, 79114 Collins Road, Clatskanie, Columbia County; Count 4 (1 ) On orabout May 2 1,2001, at Clatskanie, Columbia County, that I, in the D istrict of Oregon, (2)unlawfblly

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and willfully (3) caused and aided, abetted, counseled, commanded, induced, and procured themalicious damaging and destroying, by m eans of fire and an explosive, of a building and other realand personal pmperty used in interstate commerce and used in activities affecting interstatecommerce, namely, a vehicle shop and its co ntents located at Jefferson Poplar Farm, 79 114 CollinsRoad, Clatskanie, Colum bia,County, Oregon. -J

4. I know that if I plead "GUILTY," I will have to answer any questions that thejudge asks me abou t the offense(s) to which I am pleading guilty. I also know that if I answerfalsely, under oath, and in the presence of my attorney , my answers could be used against mein a prosecution fo r perjury o r false statement.

5. I am not under the influence of alcohol or drugs. I am not suffering from anyinjury, illness or disability affecting m y thinking or my ability to reason ex cept as follows:

.I have not takenany drugs or medications within the past seven (7) days except as follows: None.

6. I understand that conviction of a crime can result in consequ ences in addition toimprisonment. Such consequences include deportation, or removal from the United S tates, ordenia l of naturalization, if I am no t a United States citizen; loss of eligibility to receive federalbenefits; loss of certain civil rights (which may be temporary or permanent depending onapplicable state or federal law), such as the right to vote, to hold public office, and to possessa firearm; and loss of the privilege to engage in certain o ccupations Iicensed by the state orfederal government.


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7. 1 know that I may plead "NOT GU ILTY " to any crime charged against me andthat I may persist in that plea if it has already been made. I know that if I plead "NOTGUILTY" the Constitution guarantees me:

a. The right to a speedy and public trial by jury, during whichI will be presumed to be innocent unless and until I am provenguilty by the, government beyond a reasonable doubt and by theunanim ous vote o f twelve jurors;b. The right to have the assistance of a n attorney at all stagesof the proceedings;c. The right to use the power and process of the court tocompel the production of evidence, including the attendance ofwitnesses in my favor;d. The right to see, hear, confiont, and cross-examine allwitnesses c alled to testify against me;e. The right to decide for myself whether to take the w itnessstand and testify, and if I decide not to take the witness stand, Iunderstand that no inference of guilt may be drawn from thisdecision; andf. The right not to be com pelled to incriminate myself.

8. I know that if I plead "GUILT Y" there will be no trial before either a judge or ajury, and that I will not be able to appeal from the judge's denial of any pretrial m otions I mayhave filed concerning matters or issues not related to the court's jurisdiction [see instructions].

9. In this case I am pleading "GUILTY" under Rule (c) ( l )(B).10. I know the maximum sentence which can be imposed upon m e for the crime(s)

to which I am pleading guilty is:Count 1:maximum sentence is 5 years imprisonment, a fine of $250,000 and a 2 to 3year period of supervised release and a man datory $1 00 fee assessment.

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Count 2: maximum sentence is 20 years imprisonment, a mandatory minimum of 5years, a fine of $250,000 and a 2 to 3 year period o f supervised release and a mandatory$100 fee assessmentCount 3: maximum sentence is 20 years imprisonment, a mandatory minimum of 5years, a fine of $250,000 and a 2 to 3 year period of supervised release and a mandatory$100 fee assessment,Count4: maximum , sentence is 20 years imprisonment, a mandatory minimum of 5years, a fin e of $250,000 and a 2 to 3 year period of supervised release and a mandatory$100 fee assessment.+,V- 9 +,+ro%c~ f i * y ~ N ~ kE-*LC 11 0 Y-$ /n?h~orrru* ,6s 6% &F,& e ~ . z o , m ~ 9 2-m 3"w"YmyP~3?rL 5P , + /APO a rn 04 US.&-=&W ON~OO-,11. P?%ow A t he judge, 1 addltlo n to any o&r p%ty, wdl orde r a spec ial

assessmen t as provided by law in the amount of $ 100.00 per count o f conviction.12 . I know that if I am ordere d to pay a fine, and I willfully refuse to pay that fine,

I can be returned to court, where the amou nt of the unpaid balance owed on the fine can besubstantially increased by the judge and I can be imprisoned fo r up to one year.

13 . My attorney has discussed with me the Federal Sentencing Guidelines. 1knowThe G uidelines are advisory, not man datory. I also know he sentencing judge, in determiningthe particular sentence to be imposed, mu st consider those fac tors set forth in Title 18, UnitedState s Code, Section 3553(a), including, but not limited to: the nature and circumstance s of theoffense, my o wn history and characteristics, the goals of sentencing (punishment, deterrence,protection, and rehabilitation), and the senten cing range established by the advisory G uidelines.If my attorney o r any other person has calculated a guideline range for me, I know that this isonly advisory, and is only on e of the factors that the judge will consider in making a finaldecision as to what sentence will be imposed. I also know that a judge may not impose asentence greater than the maximum sentence referred to in paragraph (10) above.

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18 . If I am on probation, parole, or supervised release in any other state or federalcase, I know that by pleading guilty in this court my probation, parole or supervised release m aybe revoked and I may be required to serve time in that case, which may be consecutive, that is,in addition to any sentence imposed on me in this court.

19. If I have another case pend ing in any state or federal court, I know that myPetition and Plea Agreement in this case do not, in the absence of an express and writtenagreement, apply to my other case(s), and that I can be faced with consecutive sentences ofimprisonment.

20 . My plea of "GU ILTY" is based on a Plea A greement that I have made with theprosecutor. That Plea Agreem ent is attached hereto and incorporated herein. I have read or hadread to m e the Plea Agreem ent, and I understand the Plea Agreement.

21. The Plea Agreement contains the only agreement between the United Statesgovernment and me. No officer or agent of any branc h of governm ent (federal, state or local)or anyone else has promised or suggested that I will receive a lesser term of imprisonm ent, orprobation, or any other form of leniency if I plead "GUILTY" except as stated in the PleaAgreement. I understand that I cannot rely on any promise or suggestion made to m e by agovernm ent agent or officer which is not stated in writing in the Plea Agreement, or which isnot presented to the judge in my presence in open court at the time of the entry of my plea o fguilty.

22. My plea of "G UILT Y" is not the result of force, threat, or intimidation.23. I hereby request that the judge accept my plea o f "GUIL TY " to the following

count(s): Count 1,2,3 an d 4.

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24 . I know that the judge must be satisfied that a crim e occurred and that I committedthat crime before my plea of "GUILTY" can be accepted. W ith respect to the charge(s) towhich I am pleading guilty, I represent that I did the follow ing ac ts and that the following factsare true:


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a full understanding of the statements set forth in this Petition and in the C ertificate o f myattorney that is attached to this Petition.

SIGNED by me in the presence of my attorney, after reading (orhavinghad read to me)L).

all of the foregoing pages and p aragraphs4

Defendant

Page 9 - PETITION TO ENTER PLEA OFGUILTY Page 9


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ORDER ENTERING PLEAI find that the defendant's plea of GUILTY has been made freely andvoluntarily and not

out of ignorance, fear, inadvertence, o r coercion. I further find the defendant has adm itted factsthat prove each of the necessary elements of th e crime(s) towhich the defendant ha s pled guilty.

/IT IS THEREFORE,ORDERED that the defendant's plea of GUILTY be accepted andentered as requested in this Petition and as recommended in the Certificate of defendant'sattorney.

J-ATED thisa of 2006, in open c o w .Judge, U.S. District Court

Page 11 - ORDER ENTERING PLEA


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U.S. Departmentof JusticeKarin J. lmmergutUnited States Attorney

July 19,2006

John KolegoAttorney at Law804 P earl StreetEugene, Oregon 97401Re: United States v. Suzanne Nichole Savoie Case No. CR 06-60080-1 AAPlea Agreement - REDACTED VERSION

Dear Mr. Kolego:1. PartiesISco~e: his p lea agreement is between this Un ited States Attorney's Office forthe District of Oregon (USAO ) and defenda nt, and thus does not bind any other federal,state, or local prosecu ting, adm inistrative, or regulatory authority excep t as otherwiseidentified in this agreement. This agreemen t does no t apply to any charges other thanthose specifically mentioned herein.2. Charqes and Penalties: Defendant agrees to plead guilty to Coun ts 1 through 15 ofthe Information as follows:

Count 1: Conspiracy to Commit Arson and Destruction of an Energy Facility ofthe United States in violation of Title 18, United States Cod e, Section 371. Themaxim um sentence is 5 years imprisonm ent, a fine of $250,000, a 2 to 3 year period ofsupervised release and a mandatory $100 fee assessment.Count 2: Arson - Superior Lumber Company in violation of Title 18, Un ited StatesCode , Section 844(i). The m aximum sentence is 20 years imprisonm ent, a mandatoryminimum of 5 years, a fine of $250,000, a 2 to 3 year period of supervised release anda mandatory $100 fee assessment.Count 3: Attempted Arson - Jefferson Poplar Farm Main Office in violation of Title18, United States Code, Section 844(i). The m aximum sentence is 20 yearsimprisonment, a mandatory minimum of 5 years, a fine o f $250,000, a 2 to 3 yearperiod of supervised release and a m andatory $100 fee assessment.Counts 4 through 15: Arson -Jefferson Poplar Farm Vehicle Shop, Shop &Office, and 10 vehicles in violation of Title 18, United States Code , Section 844(i). Themaximum sentence is 20 years imprisonment, a mandatory minimum of 5 years, a fineof $250,000, a 2 to 3 year pe riod of supervised release and a m andatory $100 fee


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John KolegoU.S. v. Savoie - Plea AgreementJuly 19, 2006Page 2assessment.Defendant agrees to pay the fee assessment applicable to each of the above counts bythe time o f entry of guilty plea or explain to the court why this canno t be done.Defendant will pay m andatory restitution as ordered by the cou rt.Factual Basis: The factual basis for each count is attached hereto and b y thisreference incorporated herein as Attachment I, hich defendant agrees the USAO canprove beyond a reasonable doubt.DismissallNo Prosecution: The USAO will move to dism iss all remaining counts atthe time of sentencing. The U SAO further agrees not to bring additional chargesagainst defendan t for offenses relating to arson, consp iracy, conspiracy to com mitarson, or destruction of an energy facility in which de fendant may have been involveddirectly or indirectly up to and including Decem ber 11, 2005, which took place in theDistrict of O regon.Resolution of Sentencina Issues: In addition to waiving the right to a jury trial on theissue of guilt, defendant knowingly and voluntarily agrees that se ntencing issues in thiscase need n ot be alleged in a grand jury indictment, proven to a trial jury, o r provenbeyond a reasonable doubt. Defendant also knowing ly and voluntarily consen ts tojudicial fact-finding and resolution of any and all sentencing issues. Defendant andgovernm ent agree that the guidelines calculations should be derived from the UnitedStates Sentencing C omm ission Guidelines Manual with effective date of Novem ber 1,2000 and further that the co mbined offense level for defendant req uires a 2 levelincrease pursuant to S3D1.4 of that manual. The defendan t and governmentunderstand and ag ree that the cou rt will consider 1 8 U.S.C. 3553(a) in determining theappropriate sentence in this case.Guideline Enhancement:The USAO will recomm end the terrorism guidelineenhan cement found in U.S.S.G. s3A1 .4 because the felony offenses either involved orwere intended to prom ote a federal crime of terrorism.Acceptance: The USAO agrees to recommend a 3 level reduction for acceptance ofresponsibility if defendant's offense level is 16 or greater; otherwise a 2 level reductionapplies pursuant to U.S.S.G. 3E1.I. he USAO reserves the right to chang e or omitthis recommendation if defendant, between plea and sentencing, comm its any new oradditional violation o f law, obstructs or attemp ts to obstruct justice or acts inconsistentlywith acceptance of responsibility.Mitiqatinq Role: The USAO w ill recomm end that defendant receive a 2 level decreasefor her role as m inor participant in the offense un der the provisions of U.S.S.G.3B1.2(b).


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John KolegoU.S. v. Savoie - Plea AgreementJuly 19, 2006Page 3USAO Sentence Recommendation: The sentence to b e recomm ended by thegovernment in this case is based on the nature and circumstances of the offense andthe history and characteristics of the defendant; the need for the sentence to reflect theseriousness of the o ffense, to p romote respect for the law and to provide justpunishm ent for the offense; to afford adequa te deterrence to criminal conduct; toprotect the public from further crimes of the defendant; and to provide a just and fairsentence for this defendan t in relation to and in comparison with all of the de fendant'sco-conspirators.Waiver of A~~ealIPost-Convict ionelief Defendant knowingly and voluntarilywaives the right to app eal from an y aspect of the conviction and sentence on anygrounds unless the sentence imposed exceeds the statutory m aximum, the courtimposes an upward departure pursuant to Part 5K of the Sentencing Guidelines, or thecourt exercises its discretion under 18 U.S.C. 3553(a) to impose a sentence whichexceeds the advisory guideline range. Shou ld defendant seek an appeal, despite thiswaiver of that right, the USAO may take any position on any issue on appeal.Defendant also waives the right to file a motion pursuan t to 28 U.S.C. 2255 to setaside the con viction and sentence, except on grounds of ineffective assistance ofcounse l, newly discovered evidence , or a retroactive change in the applicableguidelines or statute.Court Not Bound: The court is not bound by the recommendations of the parties or ofthe Presentence Report (PSR ) writer. Because this agreement is made under RuleI c)(l )(B ) of the Fed eral Rules of Criminal Procedure, defendant may not withdrawany guilty plea or res cind this plea ag reement if the c ourt does not follow theagreements or recommendations herein.Full DisclosureIReservation of Riahts: The USA O will fully inform the PSR writer andthe cou rt of the facts and law related to defendan t's case . Excep t as set forth in thisagreem ent, the parties reserve all other rights to m ake sentencing recomm endationsand to respond to motions and arguments by the opposition.Breach of Plea Aqreement: If defendan t breaches the terms of this agreement, orcomm its any new violations of law b etween signing this agreem ent and sentencing, theUSA O is relieved of its obligations unde r this agreement, but defendant m ay notwithdraw any gu ilty plea.REDACTED

REDACTED

Total Aqreement: This letter states the full extent of the a greement between theparties. There are n o other promises or agreements, express or implied. If defendan t


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John KolegoU.S. v. S avoie - Plea AgreementJuly 19, 2006Page 4

accepts this offer, please sign and attach the original oEnter Plea.

f this letter to the Petition to

Sincerely,KARIN J. IMMER GUTUnited States Attorney

KIRK A. ENGD ALLAssistant U.S. Attorney

I have read this agreement carefully and reviewed every part of it with my attorney. Iunderstand the agreement and voluntarily agree to it. I am satisfied with the legal assistanceprovided to m e by my attorney.

Date SUZANNE N ICHOLE SAVOIEDefendant

I represent defendant as legal counsel. I have carefully reviewed every part of thisagreement with defendant. To m y knowledge defendant's decision to enter into thisagreement is an informed and voluntary one.

Date JOHN KOLEGOAttorney for Defendant


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ATTACHMENT 1United States vs. Suzanne SavoieCount 1: Conspiracy to Commit Arson and Conspiracy to Commit an OffenseAgainst the United States:

Beginning in Octobe r 1996 and continuing through O ctober, 2001, in the Districtof Oregon and elsewhere, Josephine Sunshine Overaker, Kevin Tubbs, StanislasGregory Meyerhoff, Daniel Gerard McGow an, Joseph Dibee, Rebecca Rubin, ChelseaDaw n Gerlach, Kendall Tankersley, Suzann e Savoie, Jonathan Christopher Mark Paul,Darren Todd Thurston, Na than Fraser Block, Joyanna L. Zacher, Jacob JeremiahFerguson, Jennifer Lynn Ko lar, William C. Rodgers and other persons, willfully andknowingly conspired and ag reed to maliciously damage or destroy, or attempt todamage or destroy, by m eans of fire, buildings, vehicles and other personal and rea lproperty owned in whole or in part or possessed by, or leased to, the United States orany department or agency thereof, and or used in interstate commerce or in any activityaffecting interstate comm erce; and to kn owingly and willfully dam age and a ttempt todamage the property of an ene rgy facility of the United States involved in thetransmission o f electricity.

The conspiracy was accomplished by the defendant and the o thers namedabove, when c ertain of the defendants and others joined toge ther in a group they calledthe "Fam ily." This "Fam ily" was w hat is comm only known as a "cell" of groups andmove men ts publicly named and described by certain of the defendants and others asthe Earth Liberation Front (ELF), the Anima l Liberation Front (ALF), and other names.The primary purposes of the conspiracy were to influence and a ffect the conduct

of government, comm erce, private business and others in the civilian population bymeans of force, violence, sabotage, destruction of property, intimidation and coercion,and by similar means to retaliate against the conduct of governm ent, commerce andprivate business. To achieve these purposes , some of the conspirators comm itted andattempted to commit acts potentially dangerous to human life and property thatconstituted violations of the criminal laws of the United States and of individual states.Som e of the de fendants and o thers targeted for arson, buildings, vehicles andother real and personal property owned, possessed, and leased by the Un ited Statesand its departmen ts and agencies while others targeted for arson, buildings, vehiclesand other real and pe rsonal property used in interstate comm erce and in activities

affecting interstate comm erce; and s till others targeted energy facilities o f the UnitedStates for damage and destruction.The defendant and others conducted and participated in mee tings to plan arsonsof the targeted sites. Several of these mee tings were called "Book C lub" mee tings bythe defendants and others and occurred at distant locations. The "Book Club" meetingscovered subjects such as lock-picking, computer security, reconnaissance of targets,


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and manufacture of timing devices to set off improvised incendiary devices.Some of the defendants and others conducted research and surveillance of sitestargeted for arson and discussed their actions among themse lves by using code words,code nam es, and nicknam es. The phrase "direct action" was used to include arsonsand other acts of des truction.In preparation for the actions, some of the conspirators designed andconstructed destructive devices which functioned as incendiary devices to ignite firesand destroy the targets for arson and p rovided transportation to the locations of thearson targets.During the course of the "direct actions" the defendant and others dressed indark clothing, wore masks and gloves and otherwise disguised their appearance.Som e of the conspirators acted as "lookouts" to ensu re secrecy as the crimes werecarried out, and som e p laced destructive devices and accelerants at sites targeted forarson and ignited or attempted to ignite the devices and accelerants.In some of the arsons and a ttempted arsons, certain of the defendants andothers painted m essages on the w alls of the targets, including "Earth Liberation Front,""ELF" and related nam es and statements concerning the purposes of the crimes.After the arsons and attempted arsons, the defenda nts and others destroyed,buried, hid and otherw ise disposed of physical evidence used in the com mission of thecrimes and thereafter publicized and prom oted the results of the fires by m eans ofwritten p ress releases and comm uniques which attributed the arsons to the EarthLiberation Front (ELF), the An imal Liberation Front (ALF) and related groups, andstated the purpose of the arsons.Before, during and after the arsons, attempted arsons, and destruction of anenergy facility, some of the defendants and others agreed among themselves never toreveal to law enforcement authorities or to anyon e else outside "the Fam ily" the iden tityof the conspirators and participants in the arsons and a ttempted arsons and agreedamong themselves to conceal or destroy any evidence connecting them to the arsonsand attempted arsons. Some of the defendants and others possessed andlor usedfalse identification documents in order to concea l their true identities and a fter thearsons and attempted arsons, some of the defendants and others fled and secretedthemselves in foreign countries in order to avoid detection and arrest by lawenforcement authorities in the United States.

Count 3: Arson - Superior Lumber CompanyPrior to Janua ry 2, 2001, Suzanne Savoie participated in planning andpreparation to commit arson at the Superior Lumber Company a t Glendale, Oregon.On or about January 2, 2001, at Glend ale, Douglas Coun ty, District of Oregon,


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defendants Suzanne Savoie, Stanislas Gregory Meyerho ff, Kevin Tubbs and DanielGerard McGow an and other persons unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging anddestroying, by means of fire and an explosive, of a building and other real and personalproperty used in interstate comm erce and used in activities affecting interstatecomm erce, namely, a building and its contents located at Superior Lumber Company,2695 G lendale Valley Road, Glendale, Oregon.Suzanne Savoie and the others m et at a set location in the city of Eugene,Oregon from where they then traveled in two separate vehicles to a predeterminedstaging area at a rest area located just north of the town o f Glendale, Oregon , onlnterstate 5. Upon arrival at the staging area, Suzanne Savoie and the others dressedin dark clothing, gloves, masks, shoes and hats to avoid being detected wh ilecomm itting the arson at the Superior Lumber Comp any.Suzanne Savoie and the others pu t on their radio earpieces, comp leted a radiocheck and traveled in one van to the Supe rior Lumber Company building. Upon their

arrival, Suzanne Savoie was dropped off at a phone booth near the Supe rior LumberCom pany and served as a look out while others, positioned the "pick-up" vehicle andplaced the time-delayed incendiary devices.After the incendiary devices were placed, Suzanne Savoie was p icked up alongwith the other co-conspirators and traveled back to the staging area a t the lnterstate 5Northbound rest stop, just north of Glendale, Oregon.Suzanne Savoie and the others changed their dark clothing and d isposed ofclothing as they traveled back to Eugene, Oregon.The incendiary devices functioned and the Superior Lumber Company facilitywas destroyed by fire. The Superior Lumber Company building and other real andpersonal property were used in interstate comm erce or in activities a ffecting interstatecommerce.On January 2, 2001, Suzanne Savoie and Daniel McGowan traveled to Portland,Oregon and prepared a com mun ique claiming responsibility for the Supe rior LumberCom pany Arson attributing the fire to the Earth Liberation Front (ELF). Thecommunique was publicized by Craig Rosebraugh of the North American ELF PressOffice.

Counts 4 through 16: Attempted Arson and Arson- Jefferson Poplar Farm MainOffice, Vehicle Shop, Shop & Office and 10 vehiclesApproximately 6 to 8 months prior to May 21, 2001, Suzanne Savoie, DanielGerard McGow an and others performed research regarding the James RiverCorporation's involvement in the genetic engineering of trees.


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At a time prior to May 21, 2001, defendants Suzanne Savoie, Stanislas GregoryMeye rhoff, and Chelsea Da wn Gerlach performed a reconna issance for the arson atthe Jefferson Poplar Farm which they believed was associated with the James RiverCorporation.At a time p rior to M ay 21, 2001, Suzanne Savoie traveled from her residence inSouthern Oregon to the residence of co-conspirator Nathan Fraser Block in O lympia,Wash ington. Once there, Suzanne Savoie, Nathan Fraser Block, Joyanna L. Zacher,Daniel Gerard McGow an and Stanislas Gregory Meyerho ff and others discussed p lansfor comm itting the arson at the Jefferson Pop lar Farms at Clatskanie, Oregon.On M ay 20,2 001 , Suzanne Savoie, N athan Fraser Block, Joyanna L. Zacher,Daniel Gerard McG owan and Stanislas Gregory Meyerhoff traveled in vehicles to astaging area just north of the Oregon - Washington border.At the s taging area, the co-conspirators dressed in dark clothing to avoid be ingdetected while com mitting the arson at the Jefferson Poplar Farm. Once they were

ready, they all drove to the Jefferson Poplar Farm. Suzanne Savoie was the driver ofthe vehicle.Once at Jefferson Poplar Farm, Suzanne Savoie dropped off the co-conspiratorsat different locations at the pop lar farm so they could place the incendiary devices innumerous sites in and around the Jefferson Poplar Farm buildings. One of theincendiary devices was placed adjacent to a large propane gas tank.Some of the co-conspirators spray-painted graffiti at the site attributing the actionto the E arth Liberation F ront (ELF).Suzanne Savo ie monitored a radio scanner to ens ure the security of the otherco-conspirators while they were placing the incendiary devices.After being informed by two-way radios that all the incendiary devices had beenproperly placed by her co-conspirators, Suzanne Savoie returned to pick up the others.Suzanne Savoie then drove everyone back to the staging area to undress, dispose oftheir clothing and get the second vehicle. Suzanne Savoie then returned to Olympia,Washington.The time-delayed incendiary devices which were placed at the M ain Officebuilding failed to function. The time-delayed incend iary devices placed at the Veh icle

Shop and the Shop & Office buildings did function and resulted in a fire whichdestroyed those two buildings as well as ten vehicles sheltered inside those buildings.On or about June 1,2001 , the d efendants in the Jefferson Poplar Farm arsonissued a communique attributing the fire to the Earth Liberation Front (ELF). Thecommunique was publicized by Craig Rosebraugh of the North American ELF PressOff ce.


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The Superior Lumb er Comp any building at Glendale, Douglas County, theDistrict of O regon, which destruction by fire occurred on or about January 2, 2001 andthe Jefferson Poplar Farm arson which occurred on or about May 2 1,2 00 1 atClatskanie, Columbia County, the District of O regon, were buildings and other real andpersonal property used in interstate comm erce and we re used in activities affectinginterstate comm erce.

Documents

Savoie.plea.Agreement.redacted