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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF ORANGE

ATTACHMENT #1

PEOPLE VS. ROBERT LAFEE CITRON

CT; CHARGE; SENTENCE RANGE (YRS); ENHANCEMENTS YEARS; YRS;

1; 25401 CC; 2, 3, 5; 12022.6(d); 4 9
2; 25401 CC; 2, 3, 5; 12022.6(d); N/A 1
3; 424.1 PC; 2, 3, 4; 12022.6(d); N/A 1
4; 424.2 PC; 2, 3, 4; ; 1
5; 424.3 PC; 2, 3, 4; ; 1
6; 424.6 PC; 2, 3, 4; ; 1

Maximum total punishment 14

(signed 4-27-95)
ROBERT L. CITRON
DEFENDANT

(signed 4-27-95)
DAVID W. WIECHERT
ATTORNEY FOR DEFENDANT

ATTACHMENT #2

This letter states the full and complete agreement between the People of the State of California, represented by District Attorney Michael R. Capizzi, through Assistant District Attorneys Jan J. Nolan and Wallace J. Wade, and Robert L. Citron, represented by David W. Wiechert:

1. The People have prepared a criminal complaint alleging six felony counts and three special enhancements, as more fully set forth in the attached Exhibit #1.

2. Mr. Citron has indicated his willingness to enter a plea of guilty to the entire complaint, including all counts and special enhancements.

3. Conditions of this agreement are as follows:

a. The People will file the attached felony complaint on Thursday, April 27, 1995.

b. Mr. Citron will appear on Thursday, April 27, 1995 and immediately be arraigned and enter a certified plea of guilty to all charges and admit all enhancements.

c. By operation of law, the matter will then be assigned to the Orange County Superior Court, for acceptance of the plea and sentencing proceedings.

d. Mr. Citron represents that he intends to move the Superior Court of Orange County for an order that a Superior Court judge of a county other than the County of Orange conduct all sentencing proceedings regarding Mr. Citron. The People have represented that they will take no position on such a motion, if made by Mr. Citron.

e. Mr. Citron represents that he will fully and completely cooperate with the Office of the Orange County District Attorney and the Orange County Grand Jury in their continuing investigation of the events relating to the Orange County Treasurer-Tax Collector's investment pool and related to the notes and bonds issued by the Orange County Treasurer on behalf of the County and other governmental agencies. Such cooperation will include, but not be limited to, full, candid and truthful testimony in any future criminal proceeding against other persons.

f. The People represent that they will not seek pre-sentence incarceration of Mr. Citron during such time as Mr. Citron continues his cooperation with the People. The People represent that, if the Court concurs, they will not oppose a continuation of sentencing until Mr. Citron has completed his cooperation with the People. The determination of the time at which Mr. Citron has completed his cooperation with the Office of the District Attorney is a matter within the sole and exclusive discretion of the District Attorney of Orange County, which discretion shall not be arbitrarily exercised. The People represent that they will accurately represent the extent of cooperation of Mr. Citron with any law enforcement or prosecutorial agency in any criminal investigation or prosecution to a sentencing judge at the time of sentencing. The extent of cooperation of Mr. Citron will be measured by his candor, truthfulness and thoroughness and not by the outcome of any investigation or proceeding in which he may give information or testimony.

g. The People agree that the attached complaint encompasses all the charges that will be filed by the People against Mr. Citron based upon his activities as Treasurer-Tax Collector.

h. No other agreement regarding this plea has been expressly or impliedly entered into between the parties. No agreement has been made regarding the maximum or minimum sentence Mr. Citron should receive at the time of his sentencing. The parties agree that the maximum sentence for the crimes charged in this complaint is 14 years in state prison. No offer of leniency has been made by the People. Mr. Citron has not acting under any threats or compulsion in entering his plea and is doing so freely and voluntarily.

(signed 4-27-95)
ROBERT L. CITRON
DEFENDANT

(signed 4-27-95)
DAVID W. WIECHERT
ATTORNEY FOR DEFENDANT

(signed 4-27-95)
WALLACE J. WADE
ASSISTANT DISTRICT ATTORNEY

(signed 4-27-95)
JAN J. NOLAN
ASSISTANT DISTRICT ATTORNEY

ATTACHMENT #3

PEOPLE VS. ROBERT LAFEE CITRON

FACTUAL BASIS FOR GUILTY PLEA

Count 1. Between April of 1993 and December of 1994, as treasurer-Tax Collector for, and in, the County of Orange, I committed a felony by violating Section 25401 of the Corporations Code to wit: with the assistance of Matthew Raabe, Assistant treasurer, I sold securities to the Participants in the Orange County Treasury Investment Pool by means of certain written communications contained in the following documents:
"Statement of Investment Policy", "1992-1993 Annual Financial Summary," and 1993-1994 Annual Financial Summary", which I knew were false and misleading.

Count 2. Between may 24, 1994 and September 28, 1994, as Treasurer- Tax Collector for, and in, the County of Orange, I committed a felony by violating Section 25401 of the Corporations Code, to wit: with the assistance of Matthew Raabe, Assistant Treasurer, I sold and offered the sale of the following securities to investors:

County of Orange 1994-95 (Teeter Plan) Tax Exempt notes;

County of Orange 1994-95 Taxable notes;

County of Orange 1994-95 (Teeter Plan) Taxable notes;

County of Orange 1994-95 Tax and Revenue Anticipation notes, Series A;

County of Orange 1994-95 Tax and revenue Anticipation Notes, Series B; Placentia-Yorba Linda Unified School District, County of Orange 1994-95 Taxable Notes; Newport-Mesa Unified School District 1994-95 Taxable Notes;

County of Orange Taxable Pension Obligation Bonds, series 1994A; and

County of Orange Taxable Pension Obligation Bonds, series 1994B.

I sold the above securities by means of signed written communications in the Preliminary Offering Statements and Official Statements of said notes and bonds, which I knew were false and misleading and included untrue statements of material facts regarding the true condition and historical earnings of the Orange County Treasury and its Investment Pool. I also failed to disclose material facts which were necessary to prevent the statements made from being misleading in light of the circumstances under which they were made.

Count 3. Between April of 1993 and February of 1994, as treasurer-Tax Collector for, and in, the County of Orange, I committed a felony by violating Section 424.1 of the Penal Code to wit: with the assistance of Matthew Raabe, Assistant Treasurer, I misappropriated in excess of $80 million dollars of earned interest belong to participants in Orange County Treasury Pool to and for the benefit of the County of Orange.

Count 4. Between April of 1993 and November of 1994, as treasurer-Tax Collector for, and in, the County of Orange, I committed a felony by violating Section 424.2 of the Penal Code to wit: with the assistance of Matthew Raabe, Assistant Treasurer, I improperly transferred securities from the Orange County General Fund to the Orange County treasury Commingled Pool.

Count 5. Between April of 1993 and November of 1994, as treasurer-Tax Collector for, and in, the County of Orange, I committed a felony by violating Section 424.3 of the Penal Code to wit: with the assistance of Matthew Raabe, Assistant Treasurer, I maintained and caused to be mailed periodic earned interest statements which falsely stated the interest earnings of the Orange County Investment Pool.

Count 6. Between April of 1993 and November of 1994, as treasurer-Tax Collector for, and in, the County of Orange, I committed a felony by violating Section 424.6 of the Penal Code to wit: with the assistance of Matthew Raabe, Assistant Treasurer, I failed to apportion interest derived from the investment funds in the Orange County Treasury Investment Pool in the amount proportionate to the average daily balance of the amounts deposited by the participants as required by Government Code Section 53684(b).

I also admit that in the commission of the offenses set forth in Counts 1, 2, & 3, that I intended to and did take, damage, or destroy property and the value of the loss exceeds Two Million Five Hundred Thousand Dollars.

/s/ ROBERT L. CITRON 4/27/95
DEFENDANT

/s/ DAVID W. WEICHART 4/27/95
ATTORNEY FOR DEFENDANT

/s/ WALLACE J. WADE 4/27/95
ASSISTANT DISTRICT ATTORNEY

/s/ JEN J. NOLAN 4/27/95
ASSISTANT DISTRICT ATTORNEY

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