Memorandum Of Plea Agreement printable pdf download

Memorandum Of Plea Agreement

Case 1:05-cr-00034-GMS

Document 19-2

Filed 09/23/2005

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA,

Plaintiff,

Criminal Action No. 05-34-GMS

ALIPIO RODRIGUEZ,

Defendant.

MEMORANDUM OF PLEA AGREEMENT

Pursuant to discussions between the United States of America, by and through its

attorney, Beth Moskow-Schnoll, 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, Alipio Rodriguez, by and through his

attorney, Christopher D. Tease, Esquire, the following agreement is hereby entered into by the

respective parties:

The defendant, Alipio Rodriguez, agrees to plead guilty to Count One of the

Indictment charging him with re-entry after deportation in violation of Title 8, United States

Code, Section 1326(a) and (b)(1) which carries a maximum penalty of 10 years imprisonment, a

$250,000 fine, 3 years supervised release and a $100 special assessment.

The defendant understands that if there were a trial, the government would have

to prove the following elements with respect to Count One of the Indictment: (a) the defendant

previously had been deported; (b) subsequent to his deportation, the defendant was found in the

United States; and (c) neither the Attorney General nor the Undersecretary for Border and

Memorandum Of Plea Agreement