Memorandum Of Plea Agreement

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Case 1:07-cr-00110-GMS
Document 2
Filed 08/17/2007
Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA,
:
:
Plaintiff,
:
:
v.
: Criminal Action No. 07-110
:
JOSE MANUEL ROA-BELMONTE,
:
:
Defendant.
:
MEMORANDUM OF PLEA AGREEMENT
Pursuant to discussions between the United States of America, by and through Colm F.
Connolly, United States Attorney for the District of Delaware and Douglas E. McCann, Assistant
United States Attorney for the District of Delaware, and the defendant, Jose Manuel Roa-Belmonte,
by and through his attorney, Edson Bostic, Esquire, the following agreement is hereby entered into
by the respective parties:
1.
The defendant shall plead guilty in the United States District Court for the District of
Delaware to Count One of a Felony Information, which charges him with illegal reentry following
an order of removal, in violation of 8 U.S.C. § 1326(a). The maximum penalties for Count One of
the Felony Information are two years imprisonment, a $250,000 fine, not more than one year of
supervised release, and a $100.00 special assessment.
2.
The defendant understands that if there were a trial, the Government would have to
prove beyond a reasonable doubt the following essential elements of the offense: (1) the defendant
is an alien; (2) the defendant was removed from the United States; (3) the defendant thereafter was
found in the United States; (4) without having obtained permission from the Attorney General or
the Secretary of Homeland Security to reapply for admission to the United States.

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