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. )
) Criminal Action N0. 07-171-UF
ANGELA I ONES, ) I
Defendant. g
MEMORANDUM OF PLEA AGREEMENT
Pursuant to discussions between the United States of America, by and through its attorneys, l
Colm F. Comiolly, United States Attorney for the District of Delaware and Shawn A. Weede,
Assistant United States Attorney for the District of Delaware, and the defendant, Angela Jones, by
and through her attorney, Eleni Kousoulis, Esquire, the following agreement is hereby entered into
by the respective parties:
l. The defendant shall plead guilty in the United States District Court for the District of
Delaware to Count Three of the Indictment, which charges her with knowingly making a false
statement with respect to infonnation to be kept by a federal fireanns dealer, in violation of
18 U.S.C. § 924(a)(l)(A). Count Three carries a maximum sentence of a term of imprisonment of
five years, a fne of $250,000, or both, three years supervised release, and a $100 special assessment.
A 2. The defendant rmderstands that if there were a trial, the Government would have to prove
the following elements with respect to Count Three of the Indictment: (l) on or about October l6,
2007, she knowingly made a false statement; (2) to a federally licensed firearms dealer, that is,
Miller’s Gun Center; (3) with respect to information that the law requires a federally licensed
firearms dealer to keep. The defendant knowingly, voluntarily and intelligently admits her guilt to
each of the above described elements of Count Three of the Indictment. `

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3. At or about the time of sentencing, the Government agrees to move to dismiss Counts `
One, Two and Four as set forth in the Indictment.
4. The defendant understands that the District Court must consider the United States
. 1
Sentencing Guidelines and the factors set forth in 18 U.S.C. Section 3553(a) in determining an
appropriate sentence. At this stage (prior to the preparation ofthe pre—sentence report), the defendant
should expect that the Government will recommend that the Court impose a sentence within the 1
sentencing range set forth by the sentencing guidelines. The defendant understands, however, that
the ultimate determination of an appropriate sentence will be up to the sentencing judge. The Court
may impose a sentence which exceeds, falls below, or is contained within the sentencing range gn
prescribed by the sentencing guidelines. The defendant expressly acknowledges that if the Court
imposes a sentence outside the range set forth in the sentencing guidelines, or otherwise different
than the defendant expected, or contrary to the recommendation of her attorney or the United States,
the defendant will not be allowed to withdraw her guilty plea on that basis.
6. Provided that the United States does not subsequently learn of conduct by the defendant
inconsistent with acceptance of responsibility, the United States agrees that in consideration of the
defendant’s timely guilty plea, a two-point reduction in the Offense Level for the defendant’s
affirmative acceptance of responsibility is appropriate. Further, if it is detennined that the
defendant’s Offense Level, prior to the application of the aforementioned two—level reduction, is
Level 16 or greater, the Government agrees to move for the reduction ofthe Offense Level by one
additional level, pursuant to Sentencing Guideline Section 3El .l(b), for a total reduction of three
points.
7. The defendant agrees to pay the $100 special assessment the day of sentencing. Should
she fail to do so, the Defendant agrees to voltmtarily enter the United States Bureau of Prisons’
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administered programknovvn as the Inmate Financial Responsibility Program through which the
Bureau of Prisons will collect a portion of defendant’s prison salary and apply it on det`endant’s
behalf to the payment of the outstanding debt ordered.
n 8. The United States Attorney reserves the right to defend any ruling of the District Court
should there be an appeal from this case.
9. It is further agreed by the undersigned parties that this Memorandum supersedes all prior
promises, representations, and statements of the 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 ave no effect whatsoever.
COLM F, ri 0 OLLY _
United St Attomey
Q: ` EQMQ Q`?. l J
By: 4 !
Eleni Kousoulis, Esquire Sh ·. Weede i
Attorney for Defendant As . t United States Attorney
Angeléiones g I
Defendant
Dated: 1 M/of _
A _ 2 r S ,
AND NOW, this [ ] day of "' . 2008, the foregoing Memorandum
of Plea Agreement is hereby ) ( ) by this Court.
\ g · I S OL./L-—/ci A
Ho ble J u sep . Farnan, Jr. _
Uni · a States District Judge
3

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