Free Plea Agreement - District Court of Delaware - Delaware


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Date: March 23, 2007
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State: Delaware
Category: District Court of Delaware
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Case 1:07-po—OOg¥)*Fl\{I5E!' 1nDgcégl[\neCrg 53r_r Fé|pdZ%3é22/2007 Page 1 of 2
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff I
v. I Criminal Action No. 07-01-MPT
FERNANDO ROMERO-FONSECA I A
Defendant. I
MEMORANDUM OF PLEA AGREEMENT A
Pursuant to discussions between the United States of America, by and through its
attorney, 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 Attorney for
the District of Delaware, and the defendant, Femando Romero—Fonseca, by and through his
attorney, Christopher Koyste, Esquire, the following agreement is hereby entered into by the
respective parties:
l. The defendant, Fernando Romero—Fonseca, agrees to plead guilty to Count One
of the Information charging him with a violation of Title 8, United States Code, Sections
l325(a)(l) and 1329, entering without inspection. This violation carries a maximum penalty of
imprisonment for not more than six months, a $5,000 fine, and a $10.00 special assessment.
2. The defendant agrees to pay the $10 special assessment at the time of sentencing.
3. The defendant understands that if he were to proceed to trial on Count One of
the Information, the Government would have to prove each of the following elements of that
offense beyond a reasonable doubt: (a) at the time charged in the Information, the defendant was
an alien; and (b) the defendant knowingly entered the United States (c) ftatirn-$r?a<Â¥-o
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Case 1:07-po-OOOO1-IVIPT Document 8 Filed O3/22/2007 Page 2 of 2
than as designated by immigration officers.
4. The defendant knowingly, voluntarily, and intelligently admits that: (a) he is a
citizen of Mexico; and (b) in February 2004, he entered the United States from Mexico at a point
near Nogales, Arizona, without inspection by immigration officials.
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
A 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. A
COLM F. CONNOLLY
United States Attorney
BY: %/ I
Fernando Romero-Fonseca ` V obert F. Kravetz
Defendant , Assistant United States Attorney
Q7 5 Z rg {
If x
'stopher Koyst _
Attorney for Defendant
Dated: Q " ' 7
AND NOW, this Ag]; day of ,/2007, the foregoing Memorandum of
Plea Agreement is hereby (releFctgd b this Court.
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{United S ates Magistrate Jud ·