STIPULATION OF FACTS. A. This Agreement pertains to Division II of the River Rim Ranch Planned Unit Development (“River Rim”) which was approved by the County and recognized as a master planned unit development.
STIPULATION OF FACTS. 1. The Superintendent is the official charged with administering and enforcing the insurance laws of the State of Maine.
STIPULATION OF FACTS. The undersigned parties stipulate and agree that if this case had proceeded to trial, this Office would have proven the following facts beyond a reasonable doubt. The undersigned parties also stipulate and agree that the following facts do not encompass all of the evidence that would have been presented had this matter proceeded to trial. The Defendant Xxxxxx Xxxxxxxxx was a full time salaried employee of the Maryland Center for Adult Training, Inc., (hereafter MCAT) from 2009 through 2019. At no time during that period was she an independent contractor. MCAT was located at 0000 Xxxx Xxxxxxx Xxxxxx, Xxxxxxxxx, Xxxxxxxx. MCAT was a non-profit 501(c)(3) entity that provides training and employment certifications for jobs in the healthcare field, including certifications to be a nursing assistant or a geriatric nursing assistant. MCAT represents itself to be a private career school accredited by the Maryland Higher Education Commission and the Maryland Board of Nursing. MCAT was an approved “Eligible Training Provider” (hereafter “ETP”) and its name appeared on the Maryland Department of Labor, Licensing and Regulation’s (DLLR) Eligible Training Provider list. As a recognized ETP, MCAT was eligible to receive, and did receive, federal funds, including U.S. Department of Labor Workforce Innovation and Opportunity Act (WIOA) funds awarded through DLLR and the U.S. Department of Health and Human Services Temporary Assistance for Needy Family (TANF) grant funds awarded by the State of Maryland’s Department of Human Services. MCAT has also received funding from private philanthropic organizations, such as the Xxxxx Foundation and Associated Black Charities. Xxxxxxxxx was initially hired to serve as XXXX’s student coordinator in 2009. In 2012, Xxxxxxxxx became the organization’s executive director. During Xxxxxxxxx’x tenure at MCAT, G.B. uploaded information, supplied by Xxxxxxxxx, to MCAT’s payroll service provider’s electronic platform. In 2015, G.B., who became the chairperson of MCAT’s Board that year, obtained signatory authority on MCAT’s bank account. As executive director, Xxxxxxxxx handled the day-to-day operations of MCAT, including, for example, what grants to pursue and what activities to undertake. She also handled the organization’s day-to-day accounting. In 2011 and 2012, MCAT withheld funds from her bi-weekly pay check for the purposes of paying state and federal taxes and making contributions to the Social Security and Medicare programs. At the end...
STIPULATION OF FACTS. A. Division II of the River Rim Ranch Planned Unit Development (“River Rim”) was approved by the County and recognized as a master planned unit development as recorded on May 11, 2006 (the “2006 Development Agreement”).
STIPULATION OF FACTS. The parties agree that there is a factual basis for the guilty plea that the defendant will tender pursuant to this plea agreement. That basis is set forth below. Because the Court must, as part of its sentencing methodology, compute the advisory guideline range for the offense of conviction, consider relevant conduct, and consider the other factors set forth in 18 U.S.C. § 3553, additional facts may be included below which are pertinent to those considerations and computations. To the extent the parties disagree about the facts set forth below, the stipulation of facts identifies which facts are known to be in dispute at the time of the execution of the plea agreement. This stipulation of facts does not preclude either party from hereafter presenting the Court with additional facts which do not contradict facts to which the parties have stipulated and which are relevant to the Court’s guideline computations, to other 18 U.S.C. § 3553 factors, or to the Court’s overall sentencing decision. The parties agree that the date on which relevant conduct began is no later than February, 2019. The parties agree as follows: From at least February 2019 and continuing until June 10, 2020, the defendant conspired with others to distribute substantial quantities of pills manufactured to have the appearance of legitimate 30 mg Oxycodone tablets, but that actually contained fentanyl. As part of this conspiracy, the defendant distributed counterfeit pills containing fentanyl to a confidential source (“CS”) utilized by the Drug Enforcement Administration (“DEA”). In approximately January 2018, the DEA began investigating the distribution of counterfeit pills containing fentanyl in the Western Slope of Colorado. As part of this investigation, the DEA developed a CS that was able to communicate with a source of supply for these pills located in Mexico. Utilizing the CS, the DEA conducted several controlled purchases of pills provided by the source of supply. In February 2019, the source of supply contacted the CS. The source of supply told the CS that he had a co-conspirator in Denver, CO, that could provide pills to the CS. The CS and the source of supply reached an agreement for $12,000 in exchange for 1,000 counterfeit pills containing fentanyl. Based on phone conversations between the CS and the source of supply, a controlled purchase was set up to take place at a mall in Lakewood, CO. The CS met with agents prior to the controlled purchase. The source of supply called th...
STIPULATION OF FACTS. The parties agree that there is a factual basis for the guilty plea[s] that the defendant will tender pursuant to this plea agreement. That basis is set forth below. Because the Court must, as part of its sentencing methodology, compute the advisory guideline range for the offense[s] of conviction, consider relevant conduct, and consider the other factors set forth in 18 U.S.C. §3553, additional facts may be included below which are pertinent to those considerations and computations. To the extent the parties disagree about the facts set forth below, the stipulation of facts identifies which facts are known to be in dispute at the time of the execution of the plea agreement. This stipulation of facts does not preclude either party from hereafter presenting the Court with additional facts which do not contradict facts to which the parties have stipulated and which are relevant to the Court’s guideline computations, to other 18 U.S.C. §3553 factors, or to the Court’s overall sentencing decision. The parties agree that the date on which relevant conduct began is __________. The parties agree as follows: [Insert facts and qualifications or disagreements, if any]
STIPULATION OF FACTS. The factual basis for this plea is set forth below. Because the Court must, as part of its sentencing methodology, compute the advisory guideline range for the offense of conviction, consider relevant conduct, and consider the other factors set forth in 18 U.S.C. § 3553, additional facts that may be included below which are pertinent to those considerations and computations. To the extent the parties disagree about the facts set forth below, the stipulation of facts identifies which facts are known to be in dispute at the time of the execution of the plea agreement. This stipulation of facts does not preclude either party from presenting non- contradictory additional facts which are relevant to the Court’s guideline computation, to other 18 U.S.C. § 3553 factors, or to the Court’s overall sentencing decision. The parties agree the government would be able to prove the following facts at trial:
STIPULATION OF FACTS. The parties agree that there is a factual basis for the guilty plea that the defendant will tender pursuant to this plea agreement. That basis is set forth below. Because the Court must, as part of its sentencing methodology, compute the advisory guideline range for the offense of conviction, consider relevant conduct, and consider the other factors set forth in 18 U.S.C. § 3553, additional facts may be included below which are pertinent to those considerations and computations. To the extent the parties disagree about the facts set forth below the stipulation of facts identifies which facts are known to be in dispute at the time of the execution of the plea agreement: This stipulation of facts does not preclude either party from hereafter presenting the Court with additional facts which do not contradict facts to which the parties have stipulated and which are relevant to the Court’s guideline computations, to other 18 U.S.C. § 3553 factors, or to the Court’s overall sentencing decision. The parties stipulate that the following facts are true and correct: Background Information The Western Area Power Administration (“WAPA”) was a government agency within the U.S. Department of Energy (“DOE”). Among other things, WAPA was responsible for supplying and marketing electricity generated from federal dams to public entities within the United States. As part of its services, WAPA was responsible for constructing, maintaining, and operating an electrical grid which was used in the course of WAPA’s transmission of hydroelectric power to its various customers. WAPA operated a sizeable warehouse located in Montrose, Colorado, which warehouse stored and distributed supplies, equipment and materials (collectively referred to as “supplies” or “goods”) used in the maintenance, repair, and building of WAPA’s electrical grid. The Defendant XXXXX XXXXXX (“XXXXXX”) resided and worked in Montrose, Colorado, during June of 2014, through November of 2017. During this time period, the Defendant was employed by a contractor for WAPA, for whom he worked as a warehouse clerk. In his position with WAPA, the Defendant’s general responsibilities included ordering supplies, documenting the purchase of supplies, inventorying supplies, distributing supplies to employees, and entering items (received and issued) into WAPA’s electronic inventory system known as “maximo”. The Defendant worked closely within the warehouse with another government contractor “X.X.” in the course of his duties...
