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United States v. Perez-Urena

United States District Court, S.D. New York

January 6, 2020

United States of America
v.
Tanibel Perez-Urena, Defendant.

          GEOFFREY S. BERMAN United States Attorney for the Southern District of New York

          Peter J. Davis Assistant United States Attorney

          Tanibel Perez Urena Defendant

          John L. Russo Attorney for Defendant

          DEFERRED PROSECUTION AGREEMENT

          Jesse M. Furman United States District Judge.

         TO: Tanibel Perez-Urena

         On June 27, 2019, a grand jury sitting in this District returned a three count indictment, in which you are charged with committing offenses against the United States, to wit, conspiracy to commit bank fraud, in violation of Title 18, United States Code, Section 1349, bank fraud, in violation of Title 18, United States Code, Sections 1344 and 2, and aggravated identity theft, in violation of Title 18, United States Code, Sections 1028A(a)(1), 1028A(b), and 2. However, after a thorough investigation it has been determined that the interest of the United States and your own interest will best be served by deferring prosecution in this District. Prosecution will be deferred during the term of your good behavior and satisfactory compliance with the terms of this agreement for the period of six months from the date of this agreement. The terms and conditions constituting your good behavior and satisfactory compliance are as follows:

         (1) You shall refrain from violation of any law (federal, state and local). You shall immediately contact your U.S. Pretrial Services Officer if arrested or questioned by a law-enforcement officer.

         (2) You shall associate only with law-abiding persons.

         (3) You shall work regularly at a lawful occupation, regularly attend school, and/or support or care for your legal dependents, if any, to the best of your ability. When out of work or not attending school you shall notify your supervising U.S. Pretrial Services Officer at once. You shall consult him or her prior to job and school changes.

         (4) You shall not leave the contiguous United States without permission of your supervising U.S. Pretrial Services Officer. In accordance with this condition, the U.S. Pretrial Services Office shall return your travel documents upon the Court's entering this agreement, and shall do so indefinitely unless this agreement is violated.

         (5) You shall notify your supervising U.S. Pretrial Services Officer immediately of any change in your place of residence.

         (6) You shall follow your supervising U.S. Pretrial Services ...


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