United States District Court, D. Nevada
JACK
BUCHANAN Counsel for Jamie Joe Dulus
DAYLE
ELIESON United States Attorney ELHAM ROOHANI Assistant United
States Attorney
STIPULATION TO MODIFY THE PLEA AGREEMENT (ECF NO. 26)
AS TO JAMIE JOE DULUS AND ORDER
The
United States of America and Jamie Joe Dulus (defendant) and
his counsel, Jack E. Buchanan, agree as follows:
1. The
government and Jamie Joe Dulus seek to modify the Plea
Agreement (ECF No. 26) to add property to be forfeited. The
Plea Agreement will remain in effect as to all other aspects
of the agreement. All waivers and agreements in the Plea
Agreement will be in effect for the property listed below.
2. The
following property is (1) any firearm or ammunition involved
in or used in any knowing violation of Title 18, United
States Code, Section 924(c)(1)(A), or any violation of any
criminal law of the United States, Title 18, United States
Code, Section 113(a)(3) and (2) any firearm or ammunition
intended to be used in any crime of violence, Title 18,
United States Code, Sections 113(a)(3) and 924(c)(1)(A), and
is subject to forfeiture pursuant to Title 18, United States
Code, Section 924(d)(1) with Title 28, United States Code.
Section 2461(c) and Title 18, United States Code, Section
924(d)(1), (2)(C), and (3)(A) with Title 28. United States
Code, Section 2461(c): Raven handgun .25 caliber, serial
number 545568 (property).
3. The
defendant knowingly and voluntarily agrees to the District
Court imposing the civil judicial forfeiture or the criminal
forfeiture of: Raven handgun .25 caliber, serial number
545568 (property).
4. The
defendant knowingly and voluntarily agrees to the
abandonment, the civil administrative forfeiture, the civil
judicial forfeiture, or the criminal forfeiture of the
property.
5. The
defendant knowingly and voluntarily abandons or forfeits the
property to the United States.
6. The
defendant knowingly and voluntarily relinquishes all
possessory rights, ownership rights, and all rights, titles,
and interests in the property.
7. The
defendant knowingly and voluntarily waives his right to any
abandonment proceedings, any civil administrative forfeiture
proceedings, any civil judicial forfeiture proceedings, or
any criminal forfeiture proceedings of the property
(proceedings).
8. The
defendant knowingly and voluntarily waives service of process
of any and all documents filed in this action or any
proceedings concerning the property arising from the facts
and circumstances of this case.
9. The
defendant knowingly and voluntarily waives any further notice
to him, his agents, or his attorney regarding the abandonment
or the forfeiture and disposition of the property.
10. The
defendant knowingly and voluntarily agrees not to file any
claim, answer, petition, or other documents in any
proceedings concerning the property.
11. The
defendant knowingly and voluntarily waives the statute of
limitations, the CAFRA requirements, Fed. R. Crim. P. 7, 11,
and 32.2, all constitutional requirements, including but not
limited to, the constitutional ...