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United States v. Ramirez

United States District Court, D. Nevada

September 25, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
MARCO ANTONIO RAMIREZ, a/k/a Anthony, Defendant.

          NICHOLAS A. TRUTANICH United states Attorney District of Nevada Nevada Bar Number 13644 JAMES E. KELLER Assistant United States Attorney Nevada Bar No. 10636 Attorneys for the United States

          RICH MOLEZZO, ESQ.Counsel for Marco Antonio Ramirez Assistant United States Attorney a/k/a Anthony

          STIPULATION MODIFY THE PLEA AGREEMENT AS TO MARCO ANTONIO RAMIREZ, A/K/A ANTHONY, AND ORDER

         The United States of America and Marco Antonio Ramirez, a/k/a Anthony, and his counsel, Rich Molezzo, Esq., agree as follows:

         1. The government and Marco Antonio Ramirez, a/k/a Anthony, seek to modify the Plea Agreement (ECF No. 400) only as to the property listed for forfeiture. The Plea Agreement will remain in effect as to all other aspects of the agreement.

         2. The defendant knowingly and voluntarily:

a. Agrees to the district court imposing the civil judicial forfeiture or the criminal forfeiture of:
1. $1, 000.00 in U.S. Currency seized from Alberto Acosta-Macias at 3503 Postre Ct.;
2. $213.00 in U.S. Currency seized from Jose Mora at 460 E. Grove St.;
3. $607.00 in U.S. Currency seized from Shawn Curl at 4986 S. Virginia St.;
4. $996.00 in U.S. Currency seized from Shawn Curl at 18119 Cherry Leaf Ct.;
5. $2, 750.00 in U.S. Currency seized from Shawn Curl at 18119 Cherry Leaf Ct.;
6. $16, 021.00 in U.S. Currency seized from Shawn Curl at 18119 Cherry Leaf Ct.; and
7. $3, 785.00 in U.S. Currency seized from Shawn Curl at 18119 ...

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