Free Proposed Plea Agreement - District Court of Delaware - Delaware

Case 1:05-cr-00020-SLR

Document 19

Filed 07/08/2005 Page 1 of 1 U.S. Department of Justice United States Attorney's Office District of Delaware
Nemours Building 1007 Orange Street, Suite 700 P.O. Box 2046 Wilmington, Delaware 19899-2046 (302) 573-6277 FAX (302) 573-6220

July 8, 2005

The Honorable Kent A. Jordan U.S. District Court 844 King Street Wilmington, Delaware 19801 Re: United States v. Joseph B. DeStefano Criminal Action Nos. 05-20-KAJ and 05-66-KAJ

Dear Judge Jordan: The defendant, through his counsel, has accepted the government's plea offer to plead guilty to Counts Seven through Eleven of the Indictment in Criminal Action No. 05-20-KAJ and to waive indictment and plead guilty to Count One of the Information in Criminal Action No. 05-66-KAJ. Enclosed please find a copy of the Memorandum of Plea Agreement setting forth the terms of the agreement between the parties. The parties respectfully request that a date be scheduled for a change of plea hearing in the above-captioned cases. Defense counsel, Sam Talkin, Esquire, has informed the government that he is available on Monday, July 25, 2005. If this date is available to the Court, the parties further respectfully request that the change of plea hearing be scheduled on July 25, 2005.

Respectfully submitted, COLM F. CONNOLLY United States Attorney

BY:

/s/ Anne Y. Park Assistant United States Attorney

cc:

Clerk of Court Sam Talkin, Esquire