Free Plea Agreement - District Court of Delaware - Delaware

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, i
v. ) Case No. 07-0lM—MPT
CHRISTINA CAREEN BRN IK, g _ l
Defendant. g F L E il
OCT l S EUG?
MEMORANDUM OF PLEA AGREEMENT
U.S. DTSTRTCT COURT
Pursuant to discussions between the United States of America, by d t ' , E
Edmond Falgowski, Assistant United States Attomey 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, Christina Careen Brnik, by and through the defendant’s attorney,
Eleni Kousoulis, Esquire, the following agreement is hereby entered into by the respective parties:
l. The defendant shall enter a guilty plea to the one count misdemeanor Information,
charging Embezzlement by a Bank Employee, a violation of Title 18, United States Code, Section
656, which carries a maximum penalty of l year imprisonment, a $100,000 fine, one year supervised
release, restitution, and a $25 special assessment.
2. The defendant acknowledges that the elements of embezzlement by a bank employee
are: a) the defendant was an employee of a bank; b) the bank was insured by the Federal Deposit
Insurance Corporation; c) the defendant knowingly and willfully embezzled ftmds ofthe bank; and
d) the defendant acted with intent to injure and defraud the bank.
3. The defendant acknowledges that she caused HSBC to suffer a loss of $990.
4. The defendant agrees to pay the special assessment on the day of sentencing.

r Case 1 :07-mj-00001 -M PT Document 10 Filed 10/18/2007 Page 2 of 2
5. 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 3E1.1. If the
offense level is 16 or higher, the United States will move for an additional one point reduction.
6. The defendant understands that at sentencing the District Court must consult the United
States Sentencing Guidelines (“U.S.S.G.") and take them into account in exercising its discretion
to determine the appropriate sentence and must also consider the other factors bearing on an
appropriate sentence pursuant to 18 U.S.C. § 35 53(a). The defendant further understands that the
Government will ask the Court to calculate the appropriate sentence under the U.S.S.G. and likely
will ask the Court to impose a sentence consistent with the U.S.S.G.
7. It is further agreed by the parties that this Memorandum supersedes all prior promises,
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 effect whatsoever, unless they r
comport with the subsequent written modification requirements of this paragraph.
A c F. 0 /
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Eleni Kousoulis, Esquire Edmond Fal ;• ski
Attorney for Defendant ‘ Assistant United St s Attorney
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Dated: \[) .- lg-O 7
AND NOW this /5 day of - , 2007, the foregoing I
Memorandum of Plea Agreement is hereby (accepted) (rejec · • by this Court.
I nite · tates Magistrate Judge p