Free Plea Agreement - District Court of Delaware - Delaware

Case 1:04-mj-00014-MPT Document 10 Filed O4/07/2005 Page 1 of 2
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, Q
v. g Case N0. O4-l4M—MPT
DAWN MUMMERT, g
Defendant. ;
MEMORANDUM OF PLEA AGREEMENT
Pursuant to discussions between the United States of America, by and through its attorney,
Edmond Falgowski, 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, Dawn Mummert, by and through the defendants attorney,
Christopher Koyste, Esquire, the following agreement is hereby entered into by the respective
parties:
1. The defendant shall plead guilty to a one count Information, charging theft of govemment
property (misdemeanor), a violation of Title 18, United States Code, Section 641, which carries a
maximum penalty of one year imprisonment, a $lO0,000 fine, one year supervised release,
restitution, or any or all ofthe above, and a $25 special assessment.
2. The defendant agrees to pay the special assessment on the day of sentencing.
3. The United States agrees that in consideration ofthe defendant's timely guilty plea, the
Government will not oppose a two point reduction in the Offense Level for the defendant's
affirmative acceptance of responsibility, pursuant to Sentencing Guideline Section 3El.l.

Case 1:04-mj-00014-MPT Document 10 Filed O4/07/2005 Page 2 of 2
4. The defendant acknowledges that as a result ofthe conduct set forth in the Information,
the defendant caused the United States to suffer losses totaling $400, for which the Court may order
restitution.
5. It is further agreed by the parts that this Memorandum supersedes all prior promises,
representations, and statements ofthe undersigned parties; that this Memorandum may be modified
only in writing signed by all the patties; 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 moditication requirements of this paragraph.
. COLM CONNOLL ,2 /
' Unite State tto ey// ,#
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V A y. .,/
@opher Koyste, Esquire Edmond Falgowski
· ttorney for Defendant Assistant United States At! rney
r" r .... ’
Dawn Mummert Y
Defendant
Dated: Ll { 7 #
AND NOW this Q day of {TZ , 2005, the ioregoing
Memorandum of Plea Agreement is hereb ejected) by this Court.
, ',
= MA 'fy T THYNGE
wg,. Magis ate Judge
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