United States District Court, S.D. New York
GEOFFREY S. BERMAN United States Attorney for the Southern
District of New York
J. Davis Assistant United States Attorney
Tanibel Perez Urena Defendant
L. Russo Attorney for Defendant
DEFERRED PROSECUTION AGREEMENT
M. Furman United States District Judge.
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:
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
shall associate only with law-abiding persons.
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.
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.
shall notify your supervising U.S. Pretrial Services Officer
immediately of any change in your place of residence.
shall follow your supervising U.S. Pretrial Services