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BENJAMIN B. WAGNERUnited States AttorneyMICHELLE RODRIGUEZAssistant U.S. Attorney501 I Street, Suite 10-100Sacramento, California 95814Telephone: (916) 554-2700IN THE UNITED STATES DISTRICT COURT FOR THEEASTERN DISTRICT OF CALIFORNIAUNITED STATES OF AMERICA,))CR. NO. S-11-439-MCEPlaintiff,) S-11-317-MCEv.)ROBERT TODD BRUCE,)) Plea AgreementDefendant. ) ______________________________)1.The United States, by AUSA Michelle Rodriguez, anddefendant Bruce, joined by his attorney, AFD Matthew Bockmon,stipulate to entry of this plea agreement reached afternegotiations pursuant to Federal Rules of Criminal Procedure(FRCP) 11 and 32.2. The Court is not a party to this plea agreement.Sentencing is a matter solely within the discretion of the Court.The Court is under no obligation to accept any recommendationsmade by the United States, and the Court may in its discretionimpose any sentence it deems appropriate up to and including thestatutory maximum stated in this plea agreement. The defendantunderstands that neither the prosecutor, defense counsel, nor theCourt can make a binding prediction or promise regarding the
PLEA AGREEMENT (Robert Todd Bruce) 1
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sentence he will receive. This plea agreement is not submitted tothe Court pursuant to FRCP 11(c)(1)(C).3.Bruce is charged as follows:
Information
Count Offense Description11-
317
-MCE
1
18 USC § 2113(a) Bank Robbery, 12/30/08
Sacramento
, Calif11-
317
-MCE
2
18 USC § 2113(a) Bank Robbery, 1/5/09
Auburn
, Calif
Information
11-
439
-MCE
1
18 USC § 2113(a) Bank Robbery, 11/22/08
Santa Barbara
, Calif11-
439
-MCE
2
18 USC § 2113(a) Bank Robbery, 12/4/08
Paso Robles
, Calif11-
439
-MCE
3
18 USC § 2113(a) Bank Robbery, 12/23/08
Pismo Beach
, CaifThis document contains the complete plea agreement between theUnited States Attorney's Office for the Eastern District ofCalifornia (EDCA), and Northern District of California (NDCA), andBruce regarding only the above identified charged offenses. Thisplea agreement is limited to the EDCA and NDCA United StatesAttorney's Offices and cannot bind any other federal, state, orlocal prosecuting, administrative, or regulatory authorities.4. Bruce shall waive indictment and he shall plead guilty ascharged in 3 counts:
Information
Count Offense Description11-
317
-MCE
1
18 USC § 2113(a) Bank Robbery, 12/30/08
Sacramento
, Calif11-
317
-MCE
2
18 USC § 2113(a) Bank Robbery, 1/5/09
Auburn
, Calif
Information
11-
439
-MCE
1
18 USC § 2113(a) Bank Robbery, 11/22/08
Santa Barbara
, Calif///
PLEA AGREEMENT (Robert Todd Bruce) 2
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The defendant agrees that he is in fact guilty of these 3 chargesand that the stipulated factual basis set forth within thisagreement is accurate.5. The defendant agrees to pay any criminal fine as orderedby the Court at the sentencing hearing. The defendant also agreesto pay full restitution.6. The defendant agrees to pay a special assessment of$100.00 for each felony offense of conviction as directed by theUnited States Probation Office.7. The defendant understands that: (a) the maximum penaltyfor each felony violation is as follows:Offense Maximum Penalty Description18 U.S.C. § 2113(a)Bank Robbery20 yrs imprisonment, 3 yrs TSR,$250,000 fine, restitution(b) if the term of supervised release (TSR) for his convictions isrevoked, a 2 year additional period of consecutive incarcerationmay be imposed; and (c) a mandatory $100 penalty assessment foreach felony conviction will be imposed in addition to any penaltyimposed by the Court. The defendant fully agrees to forfeiture ofany seized evidence, and all of his rights to seized evidence, ifany. The defendant understands and agrees that any combination orall penalties/components of his sentence may be run additionallyand consecutively by the Court, including, for example, that theterm of supervised release shall follow the imposed period ofincarceration and that the Court will be requested to make anorder of restitution to identifiable victims.8. The defendant understands and agrees that he may notwithdraw his guilty plea as a result of an order of restitution,
PLEA AGREEMENT (Robert Todd Bruce) 3
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