Free Proposed Plea Agreement - District Court of Delaware - Delaware

Case 1:07-mj-OOO10—lV|PT Document 12 Filed O2/06/2007 Page 1 of 3
V, ,,_,__ _ _ U.S. Department of Justice
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Untted States Attorney s Ojfice
District of Delaware
Nemours Building (302) 573-62 77
/007 Orange Street, Suite 700 FAX (302) 573-6220
P. O. Box 2046
Wilmington, Delaware I 9899-2046
February 1, 2007
Honorable Mary Pat Thynge
United States Magistrate Court
J. Caleb Boggs Federal Building
844 King Street
Wilmington, Delaware 19801
Re: United States v. Rose A. Vasquez
Case No. 07-10M-MPT
Dear Judge Thynge:
The defendant is prepared to enter a guilty plea to the one count misdemeanor information
pursuant to the enclosed Memorandum of Plea Agreement.
Respectfully submitted,
COLM F. ONNOLLY
U ited S tes Attorney
E mond gowski
Assistant nited States Attomey
pe; Edson A. Bostic, Esquire
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Case 1:07-mj-OOO10—IV|PT Document 12 Filed O2/06/2007 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT
F OR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, g
v. g Case N0. 07-l0M—MPT
ROSE A. VASQUEZ, g
Defendant. 3
MEMORANDUM OF PLEA AGREEMENT
Pursuant to discussions between the United States of America, by and through its attorney,
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
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 to a 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 imprisonment, 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 to pay the special assessment on the day of sentencing.
3. The United States agrees that in consideration of the defendant's timely guilty plea, the
Government will not oppose a two point reduction in the Offense Level for the defendant's
affirmative acceptance of responsibility, pursuant to Sentencing Guideline Section 3El . l.

Case 1:07-mj-OOO10—IV|PT Document 12 Filed O2/06/2007 Page 3 of 3
4. The defendant acknowledges that as a result of the conduct set forth in the Information,
the defendant caused the United States to suffer losses totaling $8,566, for which the Court may
order restitution. The defendant further agrees that the Court can order restitution for this amount
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 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.
COLM F. CONNOLLY
United States Attomey
mmm. By¤-_.m.____
Edson A. Bostic, Esquire Edmond Falgowski
Attorney for Defendant Assistant United States Attorney
Rose A. Vasquez
Defendant
Dated:
AND NOW this day of , 2007, the foregoing
Memorandum of Plea Agreement is hereby (accepted) (rejected) by this Court.
HONORABLE MARY PAT THYNGE
United States Magistrate Judge
2