Memorandum Of Plea Agreement

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Case 1:05-cr-00034-GMS
Document 22
Filed 10/26/2005
Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA,
:
:
Plaintiff,
:
:
v.
:
Criminal Action No. 05-34-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:
1.
The defendant, Alipio Rodriguez, agrees to plead guilty to Count One of the
Superseding Indictment charging him with re-entry after deportation in violation of Title 8,
United States Code, Section 1326(a) and (b)(2) which carries a maximum penalty of 20 years
imprisonment, a $250,000 fine, 3 years supervised release and a $100 special assessment.
2.
At sentencing, the United States agrees to move to dismiss the Indictment that
was returned against the defendant on April 14, 2005.
3.
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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