Free Proposed Plea Agreement - District Court of Delaware - Delaware

Case 1 :07-cr-00017-GIVIS Document 8 Filed 04/19/2007 Page 1 of 4
U.S. Department of Justice
United States Attorney ’s Ojice
"—-i;Q;;l»···"`I District of Delaware
Nemours Building (302) 5 73-6277
` 1007 Orange Street, Suite 700 FAX (302) 5 73·6220
P.O. Box 2046
Wilmington, Delaware 1 9899-2 046
April 19, 2007
The Honorable Gregory M. Sleet
United States District Judge
· District of Delaware
. 844 King Street
Wilmington, DE 19801
_ Re: United States v. Albert Seeney
Criminal Action No. 07-17-GMS
Dear Judge Sleet:
. The defendant has agreed to change his plea pursuant to the enclosed Memorandum of Plea
Agreement. The parties respectfully request that the Court schedule a Change of Plea hearing with
. counsel. An original, executed Memorandum will be submitted at the Change of Plea hearing. .
Respectfully submitted,
COLM F. CONNOLLY ·
- United States Attorney ._
` BK i é -2 —u. A
lana H. 1senstein
Assistant United States Attorney p
Enclosure A
cc: Peter J. Scuderi, Esq. -
Clerk, U.S. District Court ‘ Q

e Case 1 :07-cr-00017-GIVIS Document 8 Filed 04/19/2007 Page 2 of 4
- I IN THE UNITED STATES DISTRICT COURT
· FOR TI-IE DISTRICT OF DELAWARE
UNITED STATES OF Al\/[ERICA, )
v. g Criminal Action No. 07-17-GMS
I ALBERT B. SEENEY, )
)
) .
Defendant. )
MEMORANDIJM OF PLEA AGREEMENT I
Pursuant to discussions between the United States of America, by and through its attorney, Ilana
H. Eisenstein, Assistant United States Attorney for the District of Delaware, and the defendant,
Albert B. Seeney, by and through his attorney, Peter J . Scuderi, Esquire, the following agreement
is hereby entered into by the respective parties:
1. The defendant shall plead guilty in the United States District Court for the District of ‘
Delaware to Count One ofthe Indictment, which charges him with passing counterfeited obligations
of the United States, in violation of Title 18, United States Code, Section 472. The maximum
penalties for this offense are not more than twenty years of imprisonment, a $25 0,000 fine, or both, ` I
three years of supervised release, and a $100 special assessment.
‘ 2. The defendant understands that if there were a trial, the Government would have to prove I
I three elements of the offense: (1) on or about November 6, 2006, the defendant passed counterfeit
currency obligations ofthe United States, to wit, six Federal Reserve Notes each in the denomination
of one hundred dollars; (2) which he knew to be counterfeit; and (3) did so willfully and with the ‘
intent to defraud.
3. The defendant understands that the District Court must consider the United States
Sentencing Guidelines and the factors set forth in 18 U.S.C. Section 3553(a) in detennining an _
appropriate sentence. It is likely that the Govemrnent will recommend that the Court impose a

` Case 1 :07-cr-00017-GIVIS Document 8 Filed 04/19/2007 Page 3 of 4
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 is within, or which exceeds or falls
below, the sentencing range prescribed by the sentencing guidelines. The defendant 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 his attorney or the United States, the defendant will not be allowed to withdraw his guilty plea.
4. Provided that the United States does not subsequently learn of conduct by the defendant l
inconsistent with acceptance of responsibility, the United States agrees that in consideration ofthe .
defendant’s timely guilty plea, a two—point reduction in the Offense Level for the defendanfs
affirmative acceptance of responsibility is appropriate, pursuant to Sentencing Guideline Section
3E1.1. U
5. The defendant agrees to pay the $100 special assessment the day of sentencing. Should
he fail to do so, the Defendant agrees to voluntarily enter the United States Bureau of Prisons’ p
administered program known as the Inmate 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 of the outstanding debt ordered. ‘
. 6. The United States Attorney reserves the right to defend any ruling of the District Corut
should there be an appeal from this case. I
7. It is further agreed by the undersigned parties that this Memorandum supersedes all prior
promises, representations, and statements of the 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.
v y r 2 {

Case 1 :07-cr-00017-GIVIS Document 8 Filed 04/19/2007 Page 4 of 4
COLM F. CONNOLLY
United States Attorney
......._ By: l
Peter J. Scuderi, Esquire Ilana H. Eisenstein
Attorney for Defendant Assistant United States Attorney
Albert B. Seeney
Defendant
Dated: I
AND NOW, this __ day of 2007, the foregoing Memorandum of
Plea Agreement is hereby (accepted) (rejected) by this Court.
` ‘ .- Honorable Gregory M. Sleet
United States District Judge