Memorandum Of Plea Agreement

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Case 1:05-cr-00070-JJF
Document 12
Filed 08/18/2005
Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA,
:
:
Plaintiff,
:
:
v.
:
Criminal Action No. 05-70-JJF
:
FROILAN HERNANDEZ-GOMEZ,
:
a/k/a ANDRES ROMAN, a/k/a CELEDORIO
:
A. PEREZ,
:
:
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, Froilan Hernandez-Gomez, a/k/a
Andres Roman, a/k/a Celedorio Perez, by and through his attorney, Eleni Kousoulis, Esquire, the
following agreement is hereby entered into by the respective parties:
1.
The defendant, Froilan Hernandez-Gomez, a/k/a Andres Roman, a/k/a Celedorio
Perez, 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), which carries a
maximum penalty of imprisonment for 10 years, a $250,000 fine, 3 years supervised release and
a $100 special assessment.
2.
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

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