Free Plea Agreement - District Court of Delaware - Delaware

· Case 1:07-cr-00029-GIVIS Document 14 Filed 09/18/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, g
v. g Criminal Action No. 07-29-GMS
KELIN BRADLEY, )
Defendant. g
MEMORANDUM OF PLEA AGREEMENT
Pursuant to discussions between the United States of America, by and through its attomeys,
Colm F. Connolly, United States Attomey for the District of Delaware, and Robert F. Kravetz,
Assistant United States Attorney, and the defendant, Kelin Bradley, by and through his attorney,
Christopher Koyste, Esquire, the following agreement is hereby entered into by the respective
parties:
I. The defendant agrees to plead guilty in the United States District Court for the District
of Delaware to Count One of the Indictment, which charges him with knowingly passing
counterfeit obligations of the United States, that is, Federal Reserve Notes, in violation of Title
18, United States Code, Section 472. The offense carries a maximum sentence of 20 years
imprisonment, a $250,000 fine, or both; three years supervised release; and a $100 special
assessment.
2. The defendant understands that ifthere were a trial, the Government would have to
prove beyond a reasonable doubt the following elements with respect to Count One of the
Indictment: (l) that on or about the date alleged in the Indictment, the defendant passed
counterfeit United States currency; (2) knowing that the currency was counterfeit; and (3) with the
specihc intent to defraud.

P Case 1:07-cr-00029-GIVIS Document 14 Filed 09/18/2007 Page 2 of 3
3. In accordance with this Agreement, the defendant admits that on or about
February 10, 2007, he passed approximately $1,000 in United States currency, knowing that the
currency was counterfeit, and so doing with the specific intent to defraud.
4. Provided that the United States does not leam after the entry of the defendant’s guilty
plea of conduct by the defendant that is inconsistent with acceptance of responsibility, the United
States agrees to recommend a tvvo—level reduction in the defendant’s sentencing guideline range
pursuant to U.S.S.G. § 3151.1.
5. The defendant understands that the District Court must consider the United States
Sentencing Guidelines and the factors set forth in Title 18, United States Code, Section 3553(a) in
determining an appropriate sentence. At this stage (prior to the preparation of the pre-sentence
report), the defendant should expect that the Government will recommend that the Court impose a
sentence consistent with the sentencing range set forth by the sentencing guidelines. The
defendant understands, however, that the ultimate determination of an appropriate sentence will
be up to the sentencingjudge. The Court may impose a sentence which exceeds, falls below, or is
contained within the sentencing range prescribed by the sentencing guidelines. The defendant
expressly acknowledges that if the Court imposes a sentence outside the range set forth in the
sentencing guidelines, or otherwise different than the defendant expected, or contrary to the
recommendation of his attorney or the United States, the defendant will not be allowed to
withdraw his guilty plea on that basis.
6. The defendant agrees to pay the $100 special assessment the day of sentencing. Should
he fail to do so, the Defendant agrees to enter voluntarily into the United States Bureau ofPrisons’
administered program known as the Inmate Financial Responsibility Program, through which the
Bureau of Prisons will collect a portion of defendant’s prison salary and apply it on defendant’s
behalf to the payment of the outstanding debt ordered.
2

I Case 1:07-cr-00029-GIVIS Document 14 Filed 09/18/2007 Page 3 of 3
7. The United States Attorney reserves the right to defend any ruling of the District Court
should there be an appeal from this case.
8. It is further agreed by the undersigned parties that this Memorandum supersedes all
prior promises, representations, and statements of the parties; that this Memorandum may be
modified only in a written document signed by all the 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
lg { United States Attorney
`s o r oyste, Esqui e Robert F. Kravetz ' I_,.--—-·r
Attomey for the Defendant Assistant United States tto
Kelin Bradley, Defen
Dated: September l8, 2007
AND NOW, this [*1-, day of —-- rl- 2007, the foregoing
Memorandum of Plea Agreement is hereby (accepted) ·(-rejected)-by this Court.
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Honorgble Gregory M. Sleet
Chief United States District Judge
F l L E D
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