Memorandum Of Plea Agreement printable pdf download

Memorandum Of Plea Agreement

Case 1:05-cr-00098-GMS

Document 36-2

Filed 04/13/2006

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA,

Plaintiff,

Criminal Action No. 05-98-GMS

DEONDRE BOYER,

Defendant.

MEMORANDUM OF PLEA AGREEMENT

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

attorneys, 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 Joe Hurley,

Esquire, attorney for the Defendant, DEONDRE BOYER, the following agreement is hereby

entered into by the respective parties:

The Defendant agrees to plead guilty to Count One of a Superseding Indictment,

which charges the Defendant with possession of a firearm and ammunition by an individual

previously convicted of a crime punishable by a term of imprisonment exceeding one year, in

violation of Title 18, United States Code, Sections 922(g)(1) and 924(a)(2). The essential

elements of the offense, each of which the Government would have to prove beyond a

reasonable doubt at trial, are: (i) the Defendant knowingly possessed a firearm or ammunition;

(ii) before he possessed the firearm or ammunition, the Defendant had been convicted in a court

of a crime punishable by imprisonment for a term in excess of one year; and (iii) the possession

of the firearm or ammunition was in and affecting commerce. The maximum penalties for Count

I are found in 18 U.S.C. § 924(a)(2), and are ten years imprisonment, a $250,000.00 fine, three

Memorandum Of Plea Agreement