Free Plea Agreement - District Court of Delaware - Delaware

· Case 1 :07-cr-00016-GIVIS Document 17 Filed 07/30/2007 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff g
v. g Criminal Action No. 07- 16-GMS
BRITTNEY LAUREN WARREN g
iDefendant. g
i MEMORANDUM OF PLEA AGREEMENT
Pursuant to discussions between the United States of America, by and through its
attorney, Colm F. Connolly, United States Attorney for the District of Delaware, and Robert F.
Kravetz, Assistant United States Attorney, and the defendant, Brittney Lauren Warren, by and
through her attorney, Cathy Ann Jenkins, Esquire, the following agreement is hereby entered into
by the respective parties:
1. The defendant, Brittney Lauren Warren, agrees to plead guilty to Count I of the
Indictment charging her with theft of mail in violation of Title 18, United States Code, Section
1709, which carries a maximum penalty of 5 years imprisonment, a $250,000 fine, 3 years
supervised release, a $100 special assessment, and restitution.
2. The defendant understands that if there were a trial, the government would have to
prove the following elements with respect to Count One of the Indictment: (a) the defendant was
an employee of the United States Postal Service; (b) that at the time she was a Postal Service
employee, the mail matter referred to in the Indictment was entrusted to her possession with the
intent to be conveyed by mail; and (c) that the defendant knowingly stole the mail matter.

Case 1:07-cr-00016-GIVIS Document 17 Filed 07/30/2007 Page 2 of 4
3. Defendant agrees that, for purposes of sentencing at Count I, all the stolen checks
alleged in Counts I through XXVII of the Indictment should be considered by the District Court
as relevant conduct at the time of sentencing. g U.S.S.G. § 2Bl.l. In accordance with this
agreement, the defendant knowingly, voluntarily, and intelligently admits the following facts: (a)
she was an employee of the United States Postal Service; (b) between on or about April 25, 2006,
through on or about August 15, 2006, while she was employed by the United States Postal
Service, the checks referred to in the Indictment were entrusted to her for delivery; (c) she
knowingly stole the checks; and (d) the total value of the checks she stole was $7,562.00.
4. Provided that the United States Attomey does not subsequently leam of conduct
by the defendant inconsistent with acceptance of responsibility, at sentencing, the United States
stipulates that the defendant is entitled to a tvvo-level reduction in her guidelines offense level
under USSG §3El.l(a) based on the defendant’s conduct to date.
5. Prior to sentencing, the defendant agrees to make full restitution payments in the
amount of $7,562.00.
6. The defendant understands that the District Court must consider the United States
Sentencing Guidelines and the factors set forth in Title 18, United States Code, Section 3553(a)
in determining an appropriate sentence. At this stage (prior to the preparation of the pre-sentence
report), the defendant should expect that the Government will recommend that the Court impose
a sentence consistent with the sentencing range set forth by the sentencing guidelines. The
defendant understands, however, that the ultimate determination of an appropriate sentence will
be up to the sentencing judge. The Court may impose a sentence which exceeds, falls below, or
is contained within the sentencing range prescribed by the sentencing guidelines. The defendant
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‘ Case 1:07-cr-00016-GIVIS Document 17 Filed 07/30/2007 Page 3 of 4
expressly acknowledges that if the Court imposes a sentence outside the range set forth in the
sentencing guidelines, or otherwise different than the defendant expected, or contrary to the
recommendation of her attomey or the United States, the defendant will not be allowed to
withdraw her guilty plea on that basis. A
7. The defendant agrees to pay the $100 special assessment the day of sentencing.
Should she fail to do so, the Defendant agrees to enter voluntarily into the United States Bureau
of Prisons’ administered program known as the Imnate Financial Responsibility Program,
through which the Bureau of Prisons will collect a portion of defendant’s prison salary and apply
it on defendant’s behalf to the payment ofthe outstanding debt ordered.
8. The United States Attomey reserves the right to defend any ruling of the District
Court should there be an appeal from this case.
9. It is further agreed by the parties that this Memorandum supersedes all prior
promises, representations, and statements of the undersigned parties; that this Memorandum may
be modified only in writing signed by all the parties; and that any and all promises,
representations and statements made prior to or after this Memorandum are null and void and
have no effect whatsoever, unless they comport with the subsequent written modification
requirements of this paragraph.
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- Case 1:07-cr-00016-GIVIS Document 17 Filed 07/30/2007 Page 4 of 4
COLM F. CONNOLLY
United States Attomey
" / /
/ I I .) W
Brittney Lau arren Robert F. Kravetz
Defendant Assistant United States Att A y
- H -I-_l rl y ' A4
Cathy Ann ins _'
Attomey f efendant
Dated: July 30, 2007
·r H
AND NOW, this QQ day of July, 2007, the foregoing Memorandum of
Plea Agreement is hereby (accepted) (mj-acted) by this Court.
Hoi Gregory M. Sleet
Chief United States District Court Judge
F I L E D
JUL 3 0 2007
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