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RULE ll PLEAAGREEMENT
1. Guilty Plea
A. Count of Conviction
The defendant will enter a plea of guilty to Count One of the Information,
B. Elements of Offense
(3) The defendant purposefully structured the transaction with the intent to
The following facts are a sufficient and accurate basis for defendant's guilty
plea:
In 2014, the defendant owned a company that could perform work for
proposal for a job re-paving the parking lot of the Macomb Township Hal1. The
defendant prepared a proposal that quoted a price of $254,500 for the job to be
conducted by his company, and he gave it to the elected official. About two weeks
1ater, the elected official called the defendant and told him to immediately appear at
theparkinglotofthetownhalltostartworkonthejob. Afterthedefendantappeared
at the township hall parking lot that evening, he found that another company, which
was unknown to the defendant, was already tearing up the old parking lot for purposes
.)
of re-paving it. Other than taking some photographs of the work, the defendant and
his company subsequently did none of the work removing the old asphalt parking lot
and replacing it with it a new concrete parking lot. Instead, the other company
After the parking lot job was completed by the other company, the defendant
received a check fiom Macomb Township for $254,500. The elected offlcial
instructed the defendant to send a check for $181,055 to the other company which
had actually performed the work. In addition, the elected ofhcial instructed the
defendant to give the elected offrcial the remaining money, at least $73,000, to the
official in cash. When the defendant objected to not receiving any portion of the
$254,500 because the defendant would be responsible for paying taxes on the money
he was paid by Macomb Township, the elected official told the defendant that he
could keep approximately $7,000 in order to pay a portion ofthe taxes. Finally, the
elected official informed the defendant that the elected official would direct some
future work for the township to the defendant and his company in compensation.
As instructed, the defendant sent a check for $181,055 to the other company.
On November 5,2014, the defendant then wrote the following series of seven checks
each made out to "cash": (l) $9,429, (2) $9,429, (3) $9,429, (4) 59,429, (s) $9,429,
(6) $9,429, and (7) $9,450. The total amount of the checks was for $66,024. On
November 5,2014, the defendant caused all seven checks to be cashed at his bank in
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the Eastem District of Michigan. The defendant wrote the checks for amounts under
$ 10,000 in order to evade the currency transaction reporting requirement at his bank.
The defendant also was seeking to conceal the fact that he was gathering a large
amount of cash to give to the elected official. After the checks were cashed and the
defendant had collected $66,024 in cash, the defendant delivered all ofthe cash to the
elected official in the building housing the Macomb County Department of Public
In20I5, the defendant was "awarded" anotherjob by the elected official to re-
pave a parkinglot at the Macomb Township fire station. Again, the other company
performed all of the work on the job. In November 2015,the defendant's company
was paid $264,703 for this second job by Macomb Township. Again, as instructed
by the elected official, the defendant paid the second compatry for performing all of
the work. tn addition, the defendant gave at least $30,000 in cash to the elected
official. Again, the defendant was allowed to keep a porlion of the money paid by
Macomb Township in order to pay taxes. In the end, the defendant made no money
on the two jobs for Macomb Township, but he instead lost money because of the
taxes that he had to pay on the two jobs "awarded" by the elected official of Macomb
Township.
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2. SentencingGuidelines
A. StandardofProof
parties recommend that the defendant's guideline range is 10-16 months, as set forth
cnme,
and if any such finding rqsults in a guideline range higher than 10-16 months, the
higher guideiine range becomes the agreed range. The Courl is not bound by this
recommendation concerning the guideline range, and the defendant understands that
he will have no right to withdraw his guilty plea if the Court does not follow this
armed career criminal, or a repeat and daagerous sex offender as defined under the
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sentencing guidelines or other federal law, and that finding is not already reflected in
the attached worksheets, this paragraph does not authorize a corresponding increase
Neither party may take a position conceming the applicable guidelines that is
different than any position ofthat party as reflected in the attached worksheets, except
3. Sentence
The Court will impose a sentence pursuant to l8 U.S.C. $ 3553, and in doing
A. Imprisonment
B. Supervised Release
A term of supervised release follows the term of imprisonment. The Court must
impose a term of supervised release, which in this case is up to three years. The
agreement concerning imprisonment described above in Paragraph 3,A. does not apply
to any term of imprisonment that results from any later revocation of supervised
release.
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C. Special Assessment
The defendant will pay a special assessment of $100 at the time of sentencing.
D. Fine
The parties agree that the fine will be no more than the maximum amount of
$250,000.
E. Restitution
The Court shall order restitution to every identifiable victim ofthe defendant's
offense.
If the Court allows the defendant to withdraw his guilty plea for a "fair and just
reason" pursuant to Fed. R. Crim. P. 11(dX2XB), the defendant waives his rights
under Fed. R. Evid. 410, and the govemment may use his guilty plea, any statement
made under oath at the change-of-plea hearing, and the factual basis statement in this
5. Other Charges
If the Court accepts this agreement, the government will not bring any
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6. Each Party's Right to Withdraw from This Agreement
has no right to withdraw his guilty plea and the parties have no right to withdraw
7. Appeal Waiver
The defendant waives any right he may have to appeal his conviction on any
grounds. Ifthe defendant's sentence ofimprisonment does not exceed 16 months, the
defendant also waives any right he may have to appeal his sentence on any grounds.
This waiver does not bar filing a claim of ineffective assistance of counsel in
court.
pursuant to this agreement is vacated, the Court shall, on the government's request,
reinstate any charges that were dismissed as part of this agreement. If additional
charges are filed against defendant within six months after the date the order vacating
defendant's conviction or allowing him to withdraw his guilty plea becomes final,
which charges relate directly or indirectly to the conduct underlying the guilty plea
or to any conduct reflected in the attached worksheets, defendant waives his right to
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challenge the additional charges on the ground that they were not filed in a timely
manner, including any claim that they were filed after the limitations period expired.
Unless otherwise indicated, this agreement does not bind any govemment
agency except the United States Attomey's Office for the Eastem District of
Michigan.
the complete agreement befween the parties. This agreement supersedes all other
conceming the subject matter of this plea agreement that were made at any time
before the guilty plea is entered in court. Thus, no oral or written promises made by
the govemment to defendant or to the attomey for the defendant at aly time before
defendant pleads guilty are binding except to the extent they have been explicitly
plea agreement does not supersede or abrogate the terms of any such prior written
agreement.
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This agreement also does not prevent any civil or administrative actions against
defendant, or any forfeiture claim against any properfy, by the United States or any
other parfy.
This plea offer expires unless it has been received, fully signed, in the Offrce
of the United States Attomey by 5:00 P.M. on June 30, 2017.T\e govemment
reserves the right to modifr or revoke this offer at any time before defendant pleads
guilry.
DANIEL L. LEMISCH
Acting S mey
DAVIDA. G EY R. MICIIAEL
Assistant United States Attomey Assistant United States Attomev
Chief, Public Comrption Unit
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By signing below, defendalt acknowledges that he has read (or been read) this entire
document, understands it, and agrees to its terms. He also acknowledges that he is
satisfied with his attorney's advice and representation. Defendant agrees that he has
had a ful1 and complete opporrunity to confer with his lawyer, and has had all of his
questions answered by his er.
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Dated Dated
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Defendant: Christopher Sorrentino Count: One
DocketNo.: 17-CR- Statute(s): 31 U.S.C. S 5324
Complete one Worksheet A for each count of conviction (taking into account relevant conduct
and treating each stipulated offense as a separate count of conviction) before applying the
multiple-count rules in U.S.S.G. ch. 3, pt. D. However, in any case involving multiple counts
of conviction, if the counts of conviction are all "closely related" to each other within the
meaning of U.S.S.G. $ 3D1.2(d), complete only a single Worksheet A.
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Defendant: Christopher Sorrentino Count: One
DocketNo.: 17-CR- Statute(s): 31 U.S.C. S 5324
3. ADJUSTEDOFFENSELE\,.EL
Enter the sum of the offense levels entered in Items 1 and 2. If this Worksheet A does
not cover every count of conviction (taking into account relevant conduct and treating
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each stipulated offense as a separate count of conviction), complete one or more
additional Worksheets A and a single Worksheet B.
If this is the only Worksheet A, check this box and skip Worlcsheet B.
If the defendant has no criminal history, check this box and skip Worksheet C.
A-2
Defendant: Christopher Sorrentino Count: One
DocketNo.: 17-CR- Statute(s): 31 U.S.C. S 5324
o Group the counts of conviction into distinct Groups of Closely Related Counts. "A1l counts
involving substantially the same harm sl1all be grouped together into a single Group." (See
u.s.s.G. $ 3D1.2.)
a Determine the combined offense level by assigning "units" to each Group as follows (see
u.s.s.G. $ 3D1.4):
1 GnourOxr: Cotxr(s)
Alrusret OTpENSE LEVEL unit
2. GRouPTwo: Courr(s)
ADruSTED OFFENSELEVEL
unit
3. GRoUPTHREr: Couu(s)
ADruSTED OFFENSELEVEL
unit
4. GnoupFoun: Cornr(s)
Aorusrep OTFENSE LE\,1EL
unit
5. TorALUNrrs
tlunits
B-1
Defendant: Christopher Sorrentino Count: One
DocketNo.: 17-CR- Statute(s): 31 U.S.C. S 5324
6. INcRTnSTNiOFFENSELEVEL
1 unit --> no increase2 ll2 -3 units add 3 levels
level ->
1 ll2 :unns --> add 1 3 112 - 5 units ->
add 4 levels
2 units ---> levels
add 2 > 5 levels ---> add 5 levels
B-2
Defendant: Christopher Sorrentino Count: One
Docket No.: 17-CR- Statute(s): 3'r u.s.c. s 5324
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Defendant: Christopher Sorrentino Count: One
DocketNo.: 117-CR- Statute(s): 31 U.S.C. S 5324
* If the defendant committed the offense before turning 18, indicate whether he or she was
sentenced as ajuvenile (J) or as an adult (A).
** A release date is required in only two situations: (1) when a sentence covered under
U.S.S.G. $ 4A1.1(a) was imposed more than 15 years before the defendant's commencement of
the instant offense (taking into account relevant conduct and stipulated offenses) but resulted in
his or her confinement during any part of that 15-year period; or (2) when a sentence counted
under U.S.S.G. $ 4A1.1(b) was imposed for an offense committed before the defendant tumed
18 but resulted in his or her confinement during any part of the 5-year period preceding his or
her commencement of the instant offense (taking into account relevant conduct and stipulated
offenses).
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Defendant: Ch ristopher Sorrentino Count: One
DocketNo.: '17-cR- Statute(s): 31 U.S.C. S 5324
Enter 1 point for each prior sentence resulting from a conviction for a crime of
violence that did not receive any points under U.S.S.G. $ 4A1.1(a), (b), or (c)
because such sentence was considered related to another sentence resulting
from a conviction for a crime of violence. But enter no points where the
sentences are considered related because the offenses occurred on the same
occasion. (See U.S.S.G. $$ aA1.1(e), 4Al.2G,).) Identiff the crimes of
violence and briefly explain why the cases are considered related. NOTE: No
more than 3 points may be added under this item.
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Defendant: Christopher Sorrentino Count: One
DocketNo.: 17-CR- Statute(s): 31 U.S.C. S 5324
Enter "I" if the defendant has no criminal history. Otherwise, enter the
I
criminal history category entered in Item 6 of Worksheet C.
D-1
Defendant: Christopher Sorrentino Count: One
DocketNo.: 117-CR- Statute(s): 31 U.S.C. S 5324
D-2
f)efendant: Christopher Sorrentino Count: One
Docket No.: 117-CR- Statute(s): 31 U.S.C. S 5324
1. PROBATToN
a. Imposition of a Term of Probation (II.S.S.G. $ 581.1)
1. Probation is not authorized by the guidelines (minimum of guideline range > 10
X months or statute of conviction is a Class A or a Class B felony). If this box is
checked, go to Item 2 (Split Sentence).
2. Probation is authorized by the guidelines (minimum of guideline range : zero
months).
3. Probation is authorized by the guidelines, provided the court imposes a condition or
combination of conditions requiring intermittent confltnement, community
confinement, or home detention satisfiing the minimum of the guideline range
(minimum of guideline range > 0 months but < 9 months).
b. Leneth of Term of Probation (rJ.s.s.G. $ 581.2)
1. At least 1 year but not more than 5 years (total offense level > 6)
2. No more than 3 years (total offense level < 6).
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Defendant: Christopher Sorrentino Count: lOne
DocketNo.: 117-CR- Statute(s): 31 U.S.C. S 5324
2. At least 1 year but not more than 3 years, where the count of conviction is a Class
C or a Class D felony, i.e., an offense carrying a maximum term of imprisonment
> 5 years but < 25 years.
The court must impose certain conditions of supervised release and may impose other
conditions of supervised release.
5. Rrsrrrurrox(U.S.S.G. $ 5E1.1)
1. The court must order fuIl restitution to the victim(s) of the offense(s) of conviction.
(See 18 U.S.C. $$ 3556, 3663A, 3664.) The court will determine who the victims
are and their restifution amounts.
2. The court must order full restitution to the victim(s) of the offense(s) of conviction.
(See 18 U.S.C. $$ 3556,3663A,3664) The parties agree that tull restitution is
$
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Defendant: Christopher Sorrentino Count: One
DocketNo.: 17-CR- Statute(s): 31 U.S.C. S 5324
3. The parties agree that the court may ordet restitution to the victim(s) of the
offense(s) of conviction in arry amount up to and including
S_. (See t8 U.S.C. $$ 3663(a)(3),366a.)
4. The parties agree that the court may also order restitution to persons other than the
victim(s) of the offense(s) of conviction in any amount up to and including
$ . (See 18 U.S.C. $$ 3663(a)(l)(A),3663A(a)(3),3664.)
The court must impose a fine unless "the defendant establishes that he [or she] is
unable to pay and is not likely to become able to pay any ftne." (See U.S.S.G' $
5E1.2(a).) Generally, the fine authorized by the guidelines is limited to the range
established in the Fine Table. (See U.S.S.G. $ 5E1.2(b).) However, there are
exceptions to this general rule. (See U.S.S.G. $ SEl.2(b), (cXa)')
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Defendant: Christopher Sorrentino Count: lOne
DocketNo.: 17-CR- Statute(s): 31 U.S.C. S 5324
(Rev Apdl2014)
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