Free Plea Agreement - District Court of Delaware - Delaware

. _ case 1 :07-mj—OOO10-|\@§)Z|'g; ntpfegggnt ta'~Fa@¤»%`#2e/26§’2V@P'é'g€#fL6r¢_>2c—07
fra
n _ - `
_ IN THE UNITED STATES DISTRICT COURT
‘ FOR THE DISTRICT OF DELAWARE .
. UNITED STATES OF AMERICA, ) -
Plaintiff, i _
v. I 3 4 Case No, 07-10M-MPT - I
ROSE A. VASQUEZ, g . I ‘
Defendant. n g U q -
‘ MEMORANDUM OF PLEA-AGREEMENT _
U l Pursuant to discussions between the United States of America, by and through its attorney, E
Edmond Falgowski, Assistant United States Attorney for the District of Delaware, and on behalf of _
‘ and with the consent and knowledge of Colm F. Connolly, United States Attorney for the District U l
` of Delaware, and the defendant, Rose A. Vasquez, by and through the defendant's attorney, Edson
A. Bostic, Esquire, the following agreement is hereby entered into by the respective parties: - _
- 1. The defendant shall plead guilty tola one count Information, charging theft of government
property (misdemeanor), a violation of Title 18, United States Code, Section 641, which carries a
maximum penalty of one year imprisomnent, a $100,000 fine, one year supervised release,
restitution, or any or all of the above, and a $25 special assessment.
2. The defendant agrees topay the special assessment on the day of sentencing.
-3. The United States agrees that in consideration of the defendants timely guilty plea, the .
_ Government will not oppose a two point- reduction in the Offense Level for the defendant's q
affirmative acceptance of responsibility, pursuant to Sentencing Guideline Section 3E1.l. , i

Case 1:07-'mj—OOO10-|\/IPT Document 14 Filed O4/26/2007 Page`2 of 2 I l
4. The defendant acknowledges that as a result of the conduct set forth in the hiformation,
the defendant caused the United States to suffer losses totaling $8,566, for which the Court may i
order restitution. The defendant further agrees that the Court can order restitution for this amount R
despite the fact that the Information charges a theft of less than $1,000.
5. It is further agreed by the parties that this Memorandum supersedes alliprior promises, _ .
i representations, and statements ofthe 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 effectwhatsoever, unless they
comport with the subsequent written modification requirements of this paragraph, - l
- _ COLM F. CONNO _L `
United - tates to _,y',
t r Qur ,_.t i r . i l
By: [Li 7; I .
- Edson A. Bostic, Esquire . · Edmond Falg s 1 l
Attorney for Defendant Assistant United States Attorney i
(@ Q M/*& A A t A A
Rose A. Vasquez ‘
Defendant . {
Dated: _ _ _
AND NOW this dl ll day of -2007, the foregoing l
Memorandum of nar Agreement is hereby (accepted- (rejected) by this Court.
_ _ _ _ , l . , . .... . l r_ I/5 l
- ` H O LE MARY A THYNGE
United States Magistrate Judge ` _
2 .