Free Proposed Plea Agreement - District Court of Delaware - Delaware

Case 1:05-cr-00033-JJF

Document 10

Filed 06/16/2005

Page 1 of 1

U.S. Department of Justice United States Attorney's Office District of Delaware
Nemours Building 1007 N. Orange Street, Suite 700 P.O. Box 2046 Wilmington, Delaware 19899-2046 (302) 573-6277 FAX (302) 573-6220

June 16, 2005 The Honorable Joseph J. Farnan, Jr. U.S. District Court 844 King Street Wilmington, DE 19801 Re: United States v. Emilio Zacarias Bamaca Criminal Action No. 05-33-JJF

Dear Judge Farnan: Christopher Koyste, counsel for the defendant, has notified the Government that the defendant wishes to plead guilty, and, therefore, the parties respectfully request that a change of plea hearing be scheduled. A copy of the proposed Memorandum of Plea Agreement has been attached for the Court's review. In addition, because the parties estimate that the defendant is facing 0-6 months incarceration under the Sentencing Guidelines and the defendant is detained, the defendant seeks to be sentenced immediately following entry and acceptance of his guilty plea. The United States does not object to this request. Therefore, we respectfully ask the Court to schedule a time, prior to the guilty plea hearing, when the parties may discuss with the Court the defendant's request for immediate sentencing. Respectfully submitted, COLM F. CONNOLLY United States Attorney

BY:

/s/ Beth Moskow-Schnoll Assistant United States Attorney

cc: Clerk, U.S. District Court Christopher Koyste, Esq.