Common use of Government’s Agreements Clause in Contracts

Government’s Agreements. Based upon evidence in its possession at this time, the United States, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged in the Information for which it has venue and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that, if the United States elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged charge in Count One of the Information Indictment, that is, conspiracy to distribute cocaine and cocaine base, for which it has venue and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged in the Information for which it has venue and which arose arise out of the defendant’s conduct described abovecharged in the Indictment. Further, the United States agrees to dismiss all remaining counts charged in the Indictment at the time of sentencing. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. It is the specific intent of this plea agreement to waive any and all defenses based upon the statute of limitations with respect to any prosecution which is not barred by the statute of limitations on the date this plea agreement is signed by the defendant. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney's Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime mortgage fraud scheme charged in Count One or the Information money laundering charged in Count Two for which it has venue and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney's Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime crimes charged in the Information for which it has venue and which arose out of the defendant’s conduct described above, including the failure to file income tax returns and failure to pay income taxes as referred to in Paragraph 3(k), above. Additionally, the United States Attorney for the Western District of Missouri agrees to dismiss Counts 54, 55, 56, 58, 60, 61 and 62 of Indictment 1, and Counts 48, 49, 51 through 65 and 67 of Indictment 2 at sentencing. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged in the Information for which it has venue and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney=s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged in the Information wire fraud for which it has venue and which arose out of the defendant’s =s conduct described above. The United States also agrees to jointly recommend with the defendant, a sentence of one year and one day imprisonment at sentencing. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ States= agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to conspiracy to defraud the crime charged in Government with respect to the Information 1099-OID fraudulent tax refund scheme for which it has venue and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his her right to challenge the initiation of the dismissed or additional charges against him her if he she breaches this agreement. The defendant expressly waives his her right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him her following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him her following his her breach of this plea agreement, he she will not be allowed to withdraw his her guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United States, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime crimes charged in the Information for which it has venue and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his her right to challenge the initiation of the dismissed or additional charges against him her if he she breaches this agreement. The defendant expressly waives his her right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him her following a breach of this agreement. The defendant further understands and agrees that, if the United States elects to file additional charges against him her following his her breach of this plea agreement, he she will not be allowed to withdraw his her guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri and the Environmental Crimes Section of the United States Department of Justice, as part of this plea agreement, agrees agree not to bring any additional charges against the defendant defendant, TYSON POULTRY, INC., for any federal criminal offenses related to the crime charged in the Information for which it has venue and which arose out of the defendant’s conduct in May of 2014, as described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the additional criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his its right to challenge the initiation of the dismissed or additional charges against him the corporation if he TYSON POULTRY, INC., breaches this agreement. The defendant expressly waives his its right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him the corporation following a breach of this agreement. The defendant further understands and agrees that, if the United States Government elects to file additional charges against him the corporation following his its breach of this plea agreement, he TYSON POULTRY, INC., will not be allowed to withdraw his its guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged in the Information this indictment for conspiracy to distribute and possess with intent to distribute methamphetamine and money laundering for which it has venue and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his the right to challenge the initiation of the dismissed or additional charges against him the defendant if he the defendant breaches this agreement. The defendant expressly waives his the right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him the defendant following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him the defendant following his a breach of this plea agreement, he the defendant will not be allowed to withdraw his the guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime crimes charged in the Information for which it has venue and which arose out of the defendant’s conduct described above. Additionally, the United States Attorney for the Western District of Missouri agrees to dismiss Counts 2 through 6 at sentencing. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to all crimes arising from the crime charged facts set forth in the Information paragraph three for which it has venue and which arose out of the defendant’s conduct described abovevenue. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged in the Information subject matter of this investigation and for which it has venue, or for which this defendant waives any right to a venue challenge, and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney's Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged in the Information interstate transportation of stolen property, for which it has venue and which arose out of the defendant’s conduct described above. The government agrees to dismiss Counts Three and Four of the Indictment at sentencing. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney's Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged in the Information interstate transportation of stolen property, for which it has venue and which arose out of the defendant’s conduct described above. The government agrees to dismiss Counts One, Three, Four, and Five of the Indictment at sentencing. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his her right to challenge the initiation of the dismissed or additional charges against him her if he she breaches this agreement. The defendant expressly waives his her right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him her following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him her following his her breach of this plea agreement, he she will not be allowed to withdraw his her guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged in the Information conspiracy to distribute oxycodone and OxyContin, conspiracy to launder money and health care fraud, for which it has venue and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his her right to challenge the initiation of the dismissed or additional charges against him her if he she breaches this agreement. The defendant expressly waives his her right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him her following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him her following his her breach of this plea agreement, he she will not be allowed to withdraw his her guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged in the Information conspiracy to distribute heroin for which it has venue and which arose out of the defendant’s conduct described above. Additionally, the United States Attorney for the Western District of Missouri agrees to dismiss Count 20 at sentencing. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his her right to challenge the initiation of the dismissed or additional charges against him her if he she breaches this agreement. The defendant expressly waives his her right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him her following a breach of this agreement. The defendant further understands and agrees that, if the United States Government elects to file additional charges against him her following his her breach of this plea agreement, he she will not be allowed to withdraw his her guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged production and possession of sexually explicit imagery as described in the Information Paragraph 3 above and for which it has venue and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney’s Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged in the Information conspiracy to distribute OxyContin and oxycodone, conspiracy to launder money, health care fraud, and Social Security fraud, for which it has venue and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him his following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney's Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime charged charges in the Information for which it has venue and which arose out of the defendant’s conduct described above. The United States agrees to dismiss the Indictment currently pending against her at the time of sentencing. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence violence, or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his her right to challenge the initiation of the dismissed or additional charges against him her if he she breaches this agreement. The defendant expressly waives his her right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him her following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him her following his her breach of this plea agreement, he she will not be allowed to withdraw his her guilty plea.

Government’s Agreements. Based upon evidence in its possession at this time, the United StatesStates Attorney's Office for the Western District of Missouri, as part of this plea agreement, agrees not to bring any additional charges against the defendant for any federal criminal offenses related to the crime mortgage fraud scheme charged in Count One, the Information money laundering charged in Count Two, or the wire fraud charged in Count Three for which it has venue and which arose out of the defendant’s conduct described above. The defendant understands that this plea agreement does not foreclose any prosecution for an act of murder or attempted murder, an act or attempted act of physical or sexual violence against the Person person of another, or a conspiracy to commit any such acts of violence or any criminal activity of which the United States Attorney for the Western District of Missouri has no knowledge. The defendant recognizes that the United States’ agreement to forego prosecution of all of the criminal offenses with which the defendant might be charged is based solely on the promises made by the defendant in this agreement. If the defendant breaches this plea agreement, the United States retains the right to proceed with the original charges and any other criminal violations established by the evidence. The defendant expressly waives his right to challenge the initiation of the dismissed or additional charges against him if he breaches this agreement. The defendant expressly waives his right to assert a statute of limitations defense if the dismissed or additional charges are initiated against him following a breach of this agreement. The defendant further understands and agrees that, that if the United States Government elects to file additional charges against him following his breach of this plea agreement, he will not be allowed to withdraw his guilty plea.