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Edward Stanton plea agreement

Edward Stanton plea agreement

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Published by: The Dallas Morning News on Apr 06, 2011
Copyright:Attribution Non-commercial

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08/17/2011

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Case 2:11-cr-00285-UA Document 3 Filed 04/05/11 Page 1 of 25 Page ID #:5
1
ANDRE
BIROTTE
JR.
United
States
Attorney
2
ROBERT
E.
DUGDALE
Assistant
United
States
Attorney
3
Chief,
Criminal
Division
EVAN
J.
DAVIS
(Cal.
State
Bar
#250484)
4
Assistant
United
States
Attorney
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
8
Attorneys
for
Plaintiff
9UNITEDSTATES
OF
AMERICA
10
~ F ' L E D
:201J
APR
-5
AM
II:
23
(:':."'<,:<
~ U . ' · .
DIST;(/Ci'cOUr
r
CL.
,if
L
DIS
T.
OF
CALIF
..
LO
t"
CUES
;
oy
---_._----
111213
14
1516
17
1819
UNITEDSTATES
DISTRICT
COURTFORTHE
CENTRAL
DISTRICT
OF
CALIFORNIAUNITEDSTATES
OF
AMERICA,
)
CR
N
5
)
Plaintiff,
)
PLEA
AGREEMENTFOR
DEFENDANT
)
EDWARD
STANTON
v.
))
EDWARD
STANTON,
))
Defendant.
)))
20
1.This
constitutes
theplea
agreement
between
EDWARD
21
STANTON
("defendant")
and
the
United
States
Attorney's
Office
for
22
the
Central
District
of
California
("the
USAO")
in
the
23
investigation
of
a
charitable-giving
tax
scheme
that
involved
the
24
preparation
and
presentation
of
tax
returns
that
included
25
falsified
deductions
based
on
inflated
appraisals
of
art
work26
donated
to
charity.
This
agreement
is
limited
to
the
USAO
and
27
cannotbind
any
otherfederal,
state,
local,
or
foreign
28
 
Case 2:11-cr-00285-UA Document 3 Filed 04/05/11 Page 2 of 25 Page ID #:6
1
prosecuting,
enforcement,
administrative,
or
regulatory
2
authorities.
3DEFENDANT'SOBLIGATIONS4
2.
Defendant
agrees
to:
5
a)
Give
up
the
right
to
indictment
by
a
grand
jury
and,
6
at
the
earliest
opportunity
requested
by
the
USAO
and
provided
by
7
the
Court,
appear
and
plead
guilty
to
a
one-count
information
in
8
the
form
attachedto
this
agreementas
Exhibit
A
or
a9
substantially
similar
form.
10
b)Not
contest
facts
agreed
toin
this
agreement.
11
c)
Abideby
all
agreements
regardingsentencing
factors
12
contained
in
this
agreement.
13d)
Appear
for
all
court
appearances,
surrender
as
14
ordered
forserviceof
sentence,
obey
all
conditions
of
any
bond,
15
andobeyany
other
ongoing
court
order
in
this
matter.
16
e)Notcommit
any
crime;
however,
offenses
that
would
17
be
excluded
for
sentencing
purposes
under
United
States
18
Sentencing
Guidelines
(nU.S.S.G."
or
nSentencing
Guidelines")
19
§
4A1.2(c)
are
not
within
the
scope
of
this
agreement.
20
f)
Be
truthful
at
all
timeswith
Pretrial
Services,
the
21
United
States
Probation
Office,
and
the
Court.
22
g)
Pay
the
applicablespecial
assessment
at
or
before
23
the
time
of
sentencingunless
defendantlacks
the
ability
to
pay
24
and
submits
a
completed
financial
statement
(form
OBD-500)
to
the
25
USAO
prior
to
sentencing.
26
27282
 
Case 2:11-cr-00285-UA Document 3 Filed 04/05/11 Page 3 of 25 Page ID #:7
1
h)
Not
seek
the
discharge
of
any
restitution
2
obligation,in
whole
or
in
part,
in
any
present
or
future
3
bankruptcy
proceeding.
4
i)
To
fill
out
and
deliver
tothe
USAO
a
completed
5
financial
statement
(form
OBD-500)
listing
defendant's
assets.
6
3.
Defendant
further
agrees
to
cooperate
fully
withthe
7
USAO,
the
Internal
Revenue
Service,
and,
as
directed
by
the
USAO,
8
any
other
federal,
state,
local,
orforeign
prosecuting,
9
enforcement,
administrative,
or
regulatory
authority.
This
10
cooperation
requires
defendant
to:
11a)
Respond
truthfully
and
completely
to
all
questions
12
that
may
be
put
to
defendant,
whether
ininterviews,
before
a
13
grand
jury,
or
at
any
trial
or
othercourt
proceeding.
14b)
Attend
all
meetings,
grand
jurysessions,
trials
15
orother
proceedings
at
which
defendant's
presence
is
requested
16
by
the
USAO
or
compelled
bysubpoena
or
courtorder.
17
c)
Produce
voluntarily
all
documents,
records,
or
18
othertangible
evidence
relating
to
matters
about
which
the
USAO,
19
or
its
designee,
inquires.
20
4.
For
purposes
of
this
agreement:
(1)
"Cooperation
21
Information"
shall
mean
any
statements
made,
or
documents,
22
records,
tangible
evidence,
or
other
informationprovided,
by
23
defendant
pursuant
todefendant's
cooperation
under
this
24
agreement;
and
(2)
"Plea
Information"
shall
mean
any
statements
25made
by
defendant,
under
oath,
at
the
guilty
plea
hearing
and
the
26
agreed
to
factualbasis
statement
in
this
agreement.
2728
3

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