Professional Documents
Culture Documents
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EVAN J. DAVIS (Cal. State Bar #250484)
Assistant United States Attorney
; oy
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Major Frauds Section
5 1100 United States Courthouse
312 North Spring Street
6 Los Angeles, California 90012
Telephone: (213) 894-4850
7 Facsimile: (213) 894-6269
Email: Evan.Davis@usdoj.gov
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Attorneys for Plaintiff
9 UNITED STATES OF AMERICA
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20 1. This constitutes the plea agreement between EDWARD
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2 authorities.
3 DEFENDANT'S OBLIGATIONS
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3 bankruptcy proceeding.
4 i) To fill out and deliver to the USAO a completed
25 made by defendant, under oath, at the guilty plea hearing and the
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12 that section.
13 d) Recommend that defendant be sentenced to a term of
18 and provided that the Court does not depart downward in criminal
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25 Court, and that the Court may use Cooperation Information for the
27 sentence to be imposed.
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18 tax return that was false or fraudulent; (2) the income tax
23 one-count information.
24 PENALTIES AND RESTITUTION
26 sentence that the Court can impose for a violation of Title 26,
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1 $250,000 or twice the gross gain or gross loss resulting from the
3 assessment of $100.
4 10. Defendant agrees to make full restitution to the
7 return for the USAO's compliance with its obligations under this
15 period for taxpayers G.M. and his spouse F.M., B.M. and his
16 spouse K.M., and T.R. and his spouse J.R., but recognize and
17 agree that this amount could change based on facts that come to
18 the attention of the parties prior to sentencing. The government
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2 invalid.
3 FACTUAL BASIS
4 14. Defendant and the USAO agree to the statement of facts
5 provided below. Defendant and the USAO agree that this statement
28 down from year to year and that recent sales were necessary
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7 information.
8 e. On or about March 26, 2003, defendant purchased
27 assist L.L. 's appraising the Reyes paintings that T.R. and
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9 value, defendant did not notify L.L. or his clients that his
17 return.
18 k. On or about October 17, 2005, B.M. and his spouse
25 inflated.
26 1. Defendant also aided in providing the excessive
28 his spouse J.R., and of G.M. and his spouse F.M., for
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1 donations to A.A.V.C., along with B.M and K.M. 's tax return,
3 $370,938.
4 SENTENCING FACTORS
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1 18. Defendant and the USAO reserve the right to argue for a
4 § 3553 (a) (1), (a) (2), (a) (3), (a) (6), and (a) (7) .
5 WAIVER OF CONSTITUTIONAL RIGHTS
21 against defendant.
22 f) The right to testify on defendant's own behalf and
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10 and gives up: (a) any right that defendant might have to be
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1 within the statutory maximum; (d) the amount and terms of any
2 restitution order, provided it requires payment of no more than
7 in General Orders 318, 01-05, and/or 05-02 of this Court; and the
8 drug testing conditions mandated by 18 U.S.C. §§ 3563(a) (5) and
9 3583 (d) .
10 22. The USAO agrees that, provided (a) all portions of the
14 the sentence, with the exception that the USAO reserves the right
18 the 2004 tax accounts of B.M. and K.M., G.M. and F.M., and T.R.
19 and J.R.
20 RESULT OF WITHDRAWAL OF GUILTY PLEA
24 other than a claim and finding that entry into this plea
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4 defendant, and defendant will not assert, and hereby waives and
5 gives up, any claim under the United States Constitution, any
8 suppressed or is inadmissible.
9 EFFECTIVE DATE OF AGREEMENT
13 BREACH OF AGREEMENT
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1 USAO declares this agreement breached, and the Court finds such a
18 defendant.
19 d) In any investigation, criminal prosecution, or
21 not assert, and hereby waives and gives up, any claim that any
28 hereby waives and gives up, any claim under the United States
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6 inadmissible.
7 COURT AND PROBATION OFFICE NOT PARTIES
8 26. Defendant understands that the Court and the United
21 permits both the USAO and defendant to submit full and complete
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11 maximum.
12 NO ADDITIONAL AGREEMENTS
18 in court.
19 II
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4 as if the entire agreement had been read into the record of the
5 proceeding.
7 OFFICE
OF CALIFORNIA
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18 Attorney fo_ Defendant
Edward Stanton
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1 CERTIFICATION OF DEFENDANT
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AMYF Date
19 Attorney for efendant
Edward Stanton
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