Free Plea Agreement - District Court of Delaware - Delaware

Case 1 :07-cr—00009-GIVIS Document 21 Filed 06/21/2007 Page 1 of 3
» IN THE UNITED STATES DISTRICT COURT
I FOR THE DISTRICT OF DELAWARE l
UNITED STATES OF AMERICA, ) i , .
a 1 —
` )
v. I ) Criminal Action No. 07-00009-GMS g
CLAVEN ANDERSON, g
a/k/a/ "Rasta?’ ) _
Defendant.- l g .
MEMORANDUM OF PLEA AGREEMENT
l Pursuant to discussions between the United States of America, by and through its attomey, Seth A
M. Beausang, Assistant United States Attorney for the District of Delaware, with the consent and
knowledge of Colm F. Connolly, United States Attorney for the District of Delaware, and the
defendant, Claven Anderson, by and through his attomey, Eleni Kousoul-is,-Esquire, the following
agreement is hereby entered into by the respective parties: A
1. The defendant shall plead guilty in the United States District Court for the District of . _
Delaware to Count_ One of the one—count indictment returned against him, charging him with
nknowlingly selling counterfeit obligations of the United States, that is, counterfeit $10 and $20
Federal Reserve Notes, in violation of 18 U.S.C. § 472, which statute carries a maximum sentence -
of a term of imprisonment of twenty years, a fine of $250,000, or both; three years of supervised
release; and a $100 mandatory special assessment.
2. The defendant understands that if there were a trial, the Government would have to prove
the elements of the offense charged in the indictment as follows. The Govemment would have to
prove that (1) the defendant knowingly and with the intent to defraud; (2) sold counterfeit obligations
of the United States.

; - Case 1 :07-cr—00009-GIVIS Document 21 - Filed 06/21 /2007 Page 2 of 3
‘ . 3. Provided that the Government does not subsequently learn of conduct by the defendant l
_ inconsistent with acceptance of responsibility, the Govemrnent agrees that in consideration of the
defendant’s timely guilty plea, it will not oppose a twoelevel reduction in the Offense Level for the
p defendant’s affirmative acceptance of responsibility, pursuant to Sentencing Guidelines Section
1 ‘ 3El . l(a). _ s
4._ The defendant understands that the District Court must consider the United States
Sentencing Guidelines and the factors set forth in 18 U.S.C. Section 3553(a) in determining an
U l appropriate sentence. At this stage (prior to the preparation of the pre-sentence report), the ·
defendant should expect that the Govemment will recommend that the Court impose a sentence
consistent with the sentencing range set forth by the sentencing guidelines. The defendant \ _
A understands, however, that the ultimate determination of an appropriate sentence will be up to the
U sentencing judge. 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
. _ - Z 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. V »
5. The defendant agrees to pay the $100 special assessment on the day of sentencing. l
Should he fail to do so, the Defendant agrees to voluntarily enter the United States Bureau of
Prisons’ 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. V
l ` 6. The United States Attomey reserves the right to defend any ruling of the District Court
_ should there be an appeal from this case. ‘
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Case 1 :07-cr—00009-GIVIS Document 21 Filed 06/21/2007 Pages of 3
U 7. 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 writing 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, unless they comport with the subsequent written modifications requirements of this
paragraph. -
. COLM F. CONNOLLY
_ United States Attorney A
Eleni Kousoulis, Esquire Seth M. Beausang ‘ A
Attorney for Defendant . Assistant_ United States Attorney ‘
. _ _ ven Anderson ~ ·
U Defendant _
Dated: [D»2_ [ ~() 7
fr ....
_ 1 AND NOW, this L f day of Q [ gg , 2007, the foregoing Memorandum
of Plea Agreement is hereby (accepted) ( ' y this Court.
I _l
. The H norabl regory . Sleet
Unite States District Judge
_ _ District of Delaware
F I L E D A `
‘ JUN 2 l EUG? A
A us. msrmcr count
A otsrmcr or DELAWARE
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