Free Plea Agreement - District Court of Delaware - Delaware

Case 1 :06-po-00002-IVI PT Document 8 Filed 1 1/30/2006 Page 1 of 2
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF Al\/IERICA, :
Plaintiff,
v. Criminal Action No. 06-02PO-MPT
JOSE CUR1EL~EST RADA,
Defendant.
MEMORANDUM OF PLEA AGREEMENT
Pursuant to discussions between the United States of America, by and through its
attorney, Beth Moskow—Schnoll, Assistant United States Attorney for the District of Delaware,
and on behalf of and with the consent and knowledge of Colm F. Connolly, United States
Attorney for the District of Delaware, and the defendant, Jose Curiel-Estrada, by and through his
attorney, Eleni Kousoulis, Esquire, the following agreement is hereby entered into by the respec-
tive parties:
1. The defendant, Jose Curiel—Estrada, agrees to plead guilty to Count One of the
Information charging him with a violation of Title 8, United States Code, Section 1325(a)(1),
entering without inspection. This violation carries a maximum penalty of imprisonment for not
more than six months, a $5,000 fine, and a $10.00 special assessment.
2. The defendant agrees to pay the $10 special assessment at the time of sentencing.
3. The defendant understands that if he were to proceed to trial on Count One of
the Information, the Government would have to prove each of the following elements of that
offense beyond a reasonable doubt; (a) at the time charged in the Information, the defendant was
an alien; and (b) the defendant knowingly entered the United States (c) at a time or place other