Free Plea Agreement - District Court of Delaware - Delaware

\ Case 1:07-po—O$,O%2lM§T; hD%Cé1m}GHb§ Ul,_}Fi|e:§1/(,2,'C¥?%’J/3007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT I I
FOR THE DISTRICT OP DELAWARE
UNITED STATES OF AMERICA, ) U
Plaintiff i
Q v. ‘ i Criminal Action No. 07-02-MPT
JOSE ANTONIO NINO—CONTRERAS i l p
Defendant. ; I
’ MEMORANDUM OF PLEA AGREEMENT
Pursuant to discussions between the United States of America, by and through its ‘
attomey, Robert F. Kravetz, 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 Attomey for
the District of Delaware, and the defendant, Jose Antonio Nino-Contreras, by and through his
attorney, Eleni Kousoulis, Esquire, the following agreement is hereby entered into by the respec-
. tive parties:
1. The defendant, Jose Antonio Nino—Contreras, agrees to plead guilty to Count One V _
of the Information charging him with a violation of Title 8, United States Code, Sections 1 _
1325(a)(l) and 1320, entering without inspection. This violation carries a maximum penalty of V
‘ - imprisonment for not more than six months, a $5,000 fine, and a $10.00 special assessment.
2. The defendant agrees to pay the $10 special assessment at the time of sentencing.
3. The defendant understands that if he were to proceed to trial on Count One of
the Infonnation, the Govemment would have to prove each of the following elements of that
offense beyond a reasonable doubt: (a) at the time chargedin the Information, thedefendant was
an alien; and (b) the defendant knowingly entered the United States (c) at “<-Elie? L
1
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Case 1 :,07-po-00002-lV|PT_ Document 8 Filed O3/22/2007 Page 2 of 2
4. lhe defendant knowingly, voluntarily, and intelligent y admits that: (a) he is a
citizen of Mexico; and (b) in January 2004, he entered the United States from Mexico at a point
near Nogales, Arizona, (c) without inspection by immigration officials.
5. lt 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 l l
whatsoever, unless they comport with the subsequent written modification requirements of this
paragraph. ‘ ·
_ ‘ COLM F. CONNOLLY
United States Attorney ‘ _ l
K · _
Jag; ggpfm 50 M50- eadgp- Q M S BY: **4 ig;
Jose Antonio Nino—Contreras A · Robert F. Kravetz '
Defendant Assistant United States Attorney
cézax . igtegiqzr QM;.
Eleni Kousoulis _
Attorney for Defendant _
Dated: March 22, 2007
AND NOW, this éday of March 2007, the foregoing Memorandum of g
Plea Agreement is hereby accepted (rejectediby this Court.
Honor ‘lc ryPat _
ni =• States Magistrate Judge