Government’s Agreements. Based upon evidence in its possession at this time, the United States Attorney=s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against defendant for any federal criminal offenses related to the charges defendant has pled to herein for which it has venue and which arose out of the defendant=s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the person of another, or a conspiracy to commit any such acts of violence nor does it foreclose prosecution of any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States= agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement and the limitations set out herein. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives any right to challenge the initiation of the dismissed or additional charges against defendant if defendant breaches this agreement. The defendant expressly waives any right to assert a statute of limitations defense if the dismissed or additional charges are initiated against defendant following a breach of this agreement. The defendant further understands and agrees that if the Government elects to file additional charges against defendant following breach of this plea agreement, defendant will not be allowed to withdraw this guilty plea.
Government’s Agreements. Based upon evidence in its possession at this time, the United States Attorney's Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against defendant for any federal criminal offenses related to conspiracy to distribute controlled substances, and conspiracy to commit promotional and concealment money laundering, for which it has venue and which arose out of the defendant’s conduct described above. Additionally, the United States Attorney for the Western District of Missouri agrees to dismiss Counts Twenty-One through Twenty-Four as to defendant Xxxxxx at sentencing. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives her right to challenge the initiation of the dismissed or additional charges against her if she breaches this agreement. The defendant expressly waives her right to assert a statute of limitations defense if the dismissed or additional charges are initiated against her following a breach of this agreement. The defendant further understands and agrees that if the Government elects to file additional charges against her following her breach of this plea agreement, she will not be allowed to withdraw her guilty plea.
Government’s Agreements. Based upon evidence in its possession at this time, the United States Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against defendant for any federal criminal offenses related to conspiracy to defraud the IRS or the United States, wire fraud, mail fraud, or filing a false tax return, or any other charge related to the conduct set forth in Paragraph 3 of this plea agreement for which it has venue and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this
Government’s Agreements. Based upon evidence in its possession at this time, the United States Attorney=s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against defendant for any federal criminal offenses related distribution of methamphetamine on June 3, 2014 (Count One) and on June 19, 2014 (Count Two), as well as being an alien in possession of a firearm on August 14, 2014 (Count Three), for which it has venue and which arose out of the defendant=s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States= agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that if the Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.
Government’s Agreements. Based upon evidence in its possession at this time, the United States Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees:
Government’s Agreements. Based upon evidence in its possession at this time, the United States Attorney's Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against defendant for any federal criminal offenses related to conspiracy to commit the offenses of (a) transporting stolen vehicles;
Government’s Agreements. Based upon evidence in its possession at this time, the United States Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against The Teleport, Xxxxx Xxxxxxxx, or Xxxx Xxxxxx for any federal criminal offenses related to prohibition of an illegal gambling business for which it has venue and which arose out of the parties’ conduct described above. The parties understand that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The parties recognize that the United States’ agreement to forego prosecution of all of the criminal offenses with which the parties might be charged is based solely on the promises made by the parties in this agreement. If the parties breach this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The parties expressly waive their right to challenge the initiation of the dismissed or additional charges against them if they breach this agreement. The parties expressly waive their right to assert a statute of limitations defense if the dismissed or additional charges are initiated against them following a breach of this agreement. The parties further understand and agree that if the Government elects to file additional charges against them following a breach of this plea agreement, The Teleport will not be allowed to withdraw its guilty plea.
Government’s Agreements. Based upon evidence in its possession at this time, the United States Attorney’s Office for the Western District of Missouri, as part of this Plea Agreement, agrees not to bring any additional charges against any of these three defendants for any federal criminal offenses based on the importation of materials used in the production and manufacture of pet food, for which the Western District of Missouri has venue and which occurred during the years 2006 through 2007. Additionally, the United States Attorney for the Western District of Missouri agrees, at the time of sentencing, to dismiss all remaining counts of the Indictment filed against these three defendants. Assuming the Court accepts the guideline calculations set forth in this plea agreement, the parties agree that the appropriate sentence in this case is a sentence of three years probation. The parties further agree and specifically request that the Court impose a fine of $25,000.00 against defendant Chemnutra, Inc., and said defendant agrees to pay said fine in full on or before the date of sentencing. The parties further agree and specifically request that the Court impose a separate fine of $5,000.00 against each of defendants Xxxxx Xxxxxx and Xxxxxxx X. Xxxxxx, with said fine to be paid over the term of any probation or supervised release which may be imposed by the Court. The parties further agree and specifically request that no order of restitution be imposed by the Court, and further request that this Court specifically find that the restitution-related determinations and orders issued and made in the multi-district civil litigation based on the same facts which gave rise to this criminal prosecution, i.e., the $24 million cash settlement reached in United States District Court for the District of New Jersey, styled as In re: Pet Food Product Liability Litigation, MDL Docket No. 1850, Civil Action No. 07-2867, negates any need for entry of an additional restitution order in this case. The parties further agree and specifically request that any term of probation or supervised release which may be imposed by the Court include a provision that obligates the defendants to provide full cooperation with the United States Food and Drug Administration (FDA) if requested to do so in any matter within the purview of the FDA. Defendants understand and agree that this Plea Agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexua...
Government’s Agreements. Case number 22-04071-CR Based upon evidence in its possession at this time, the United States Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against defendant for any federal criminal offenses related to wire and mail fraud for which it has venue, and which arose out of the defendant’s conduct described above. The United States Attorney’s Office for the Western District of Missouri agrees not to prosecute the defendant for any crimes involving bribery of a prison guard or possession of contraband in a detention facility. The defendant understands if he breeches this plea agreement, the Government can charge him with conspiracy to bribe a prison guard in violation of 18 U.S.C. 371, bribery of a prison guard in 89 violation of 18 U.S. Code § 201, and possession of contraband in a federal detention facility in violation of 18 U.S. Code § 1791. Additionally, the United States Attorney for the Western District of Missouri agrees to dismiss Counts 3-67 and Count 69 at sentencing. Case number 22-CR-04013 Based upon evidence in its possession at this time, the United States Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against defendant for any federal criminal offenses related to wire and mail fraud for which it has venue, and which arose out of the defendant’s conduct described above. The United States Attorney’s Office for the Western District of Missouri agrees not to prosecute the defendant for any crimes involving bribery of a prison guard or possession of contraband in a detention facility. The defendant understands if he breeches this plea agreement, the Government can charge him with conspiracy to bribe a prison guard in violation of 18 U.S.C. 371, bribery of a prison guard in violation of 18 U.S. Code § 201, and possession of contraband in a federal detention facility in violation of 18 U.S. Code § 1791. Additionally, the United States Attorney for the Western District of Missouri agrees to dismiss Counts 2-9 at sentencing. Case numbers 20-04071-CR and 22-04013-CR In exchange for the defendant’s pleas of guilty, the Government will remain silent on the issue of concurrent or consecutive time as to case numbers 20-04071-CR and 22-04013-CR. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, stalking, an act or atte...
Government’s Agreements. In return for the defendant’s plea of guilty as set forth herein, the United States Attorney for the District of Kansas agrees to request, at the time of sentencing, that the Court dismiss the remaining counts of the Indictment, and agrees to not file any additional charges against the defendant arising out of the facts forming the basis for the present Indictment.
