Free Plea Agreement - District Court of Delaware - Delaware

Case 1 :05-mj-00084-lVI PT Document 26 Filed 05/25/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA :
v. Criminal Action N0. 05-84M-MPT
RANDALL HILL
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 Leonard
Stark, Assistant United States Attorney, and Christopher Koyste, Esq., attorney for the defendant,
Randall Hill, the following agreement is hereby entered into by the respective parties:
l. The defendant agrees to plead guilty to an Information, charging him with simple
assault, in violation of-*Tit1e 18, U. S. Code, Section 1l1(a)(l).
2. The maximum penalty is one year imprisonment, one year supervised release, a
$100,000 fine, and a $25 mandatory special assessment.
3. The defendant understands that if he were to proceed to trial on the complaint
charging simple assault, in violation of in violation of Title 18, U. S. Code, Section l11(a)(1),
the government would have to prove each of the following elements of the offense beyond a
reasonable doubt: (1) the defendant knowingly, (2) forcibly assaulted, (3) an employee of the
United States, (4) while the employee was engaged in the performance of his official duties.
4. The defendant knowingly, voluntarily, and intelligently admits that on May 12,
2005, he knowingly forcibly assaulted a court security officer in the United States Courthouse,
Wilmington, Delaware, while the court security officer was engage ' '
official duties. E l
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Case 1:05-mj-00084—lV|PT Document 26 Filed 05/25/2006 Page 2 of 2
6. The defendant understands that at sentencing the District Court must consider the
United States Sentencing Guidelines and take them into account in exercising its discretion to
determine the appropriate sentence and must also consider the other factors bearing on an
appropriate sentence pursuant to 18 U.S.C. §3553(a). The defendant further understands that the
Government will likely recommend that the Court impose a sentence consistent with the
sentencing range set forth by the sentencing guidelines.
7. It is further agreed by the undersigned parties that this Memorandum supersedes
all prior promises, representations, and statements of the undersigned parties; that this
memorandum may be modified only in a written agreement executed by all the undersigned
parties; and that any and all promises, representations, and statements made prior to or after this
Memorandum are null and void and have no effect whatsoever.
COLM F. CONNOLLY
ff, United States Attomey
nj" , J ’ r--- -BY_ t;'\/\ · / _i,;`”
Glbzfstopher Koyste, Esq. ` Leonard Stark
Attorney for Defendant Assistant United States Attorney
V !./5
· Sig'?. Dated: 25 May 2006
Randall Hill
Defendant
AND NOW this Q day of [@ , 2006, the foregoing
Memorandum of Plea Agreement is hereby rej cted) by the Court.
__ ..L ’[Z`.
ble Mary Pat [ y !_
· States Magistrate Court
District of Delaware