8/9/2019 KatelynCurtisPlea http://slidepdf.com/reader/full/katelyncurtisplea 1/11 Rt:CE/VE:O APR 20 2010 IN THE UNITED STATES DISTRICT COURT CLERKUS FO R THE SOUTHERN DISTRICT OF IOWA SOUTHERN D ? J ~ R T R / C T COURT 1CTOF/OWA UNITED STATES OF AMERICA, Plaintiff, v. KATELYN MARIE CURTIS, alk/a Katalyn Maria Curtis, Defendant. ) ) ) ) ) ) ) ) ) ) Criminal No.3 :09-cr-119 PLEA AGREEMENT IT IS HEREBY AGREED by and between the plaintiff, the United States of America, and the defendant, KATELYN MARIE CURTIS, a/k/a Katalyn Maria Curtis, (hereinafter "Defendant"), and respective counsel, as follows: A. CHARGES 1. Subject Offense. Defendant will plead guilty to Counts 1 and 2 of the Indictment dated December 16,2009. Count 1 charges a violation of Title 18, United States Code, Sections 2113(a), 2113(d) and 2, that is, bank robbery with a dangerous weapon. Count 2 charges a violation of Title 18, United States Code, Section 924(c) and 2, that is, possession of a firearm in furtherance of violent crime. 2. Charges Being Dismissed. Contingent on the defendant abiding by all the terms and conditions of the plea agreement, the government agrees to dismiss Count 3, as to the defendant, at the time of sentencing. 3. No Further Prosecution. The Government agrees that the defendant will not be charged in the Southern District of Iowa with any other federal criminal offense under Title 18, United States Code, arising from or directly relating to this investigation, except for any Case 3:09-cr-00119-JAJ-TJS Document 64 Filed 04/20/10 Page 1 of 11
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20. Factual Stipulations. Attached hereto as Attachment "A", and incorporated by
reference herein, are factual stipulations entered into between the parties, including the factual
stipulations of the defendant's offense conduct relating to each subject offense.
21. Venue. Defendant agrees that the offense conduct relating to the subject offenses
were committed, in whole or in part, in the Southern District of Iowa, and that the U. S. District
Court, Southern District of Iowa, has proper venue of this agreement.
22. Public Interest. The Plaintiff and Defendant state this plea agreement is in the
public interest and it takes into account the benefit to the public of a prompt and certain
disposition of the case and furnishes adequate protection to the public interest and is in keeping
with the gravity of the offense and promotes respect for the law.
23. ExecutionlEffective Date. This Plea Agreement does not become valid and
binding until executed by each of the individuals (or their designated representatives) shown on 2-0 C)1JtJthe following page. If not executed prior to . M a r c l r Z 6 ~ - 2 6 1 0 this agreement shall automatically
expire and all obligations upon either party by virtue of the terms of this agreement shall be
rendered null and void.
The undersigned hereby accept and agree to the
terms and conditions set forth in this Plea
Agreement.
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1. That on or about October 5,2009, in and about Washington County in the
Southern District of Iowa, the defendants, VERKISHA LATRICE BURNS, KATELYN MARIE
CURTIS, a/k/a Katalyn Maria Curtis, and RAYLON DESHON JONES, by force and violence,
and by intimidation, did take and attempt to take from the person and presence of another,
approximately $3,760 in United States currency belonging to and in the care, custody, control
and possession of West Chester Savings Bank, 1060 West Monroe Street, Washington, Iowa, the
deposits ofwhich were then insured by the Federal Deposit Insurance Corporation.
2. In committing the offense described in paragraph 1 above, the defendant,
KATELYN MARIE CURTIS, a/k/a Katalyn Maria Curtis, did assault and put in jeopardy the life
of another person by the use of a dangerous weapon while the defendants were taking and
attempting to take the $3,760 in United States currency belonging to and in the care, custody,control and possession of West Chester Savings Bank, and did aid and abet the same, when co
defendant, VERKISHA LATRICE BURNS, entered the bank and brandished the weapon,
pointing it at tellers and other bank employees while ordering them to give her money. The
defendant was aware that BURNS had a weapon and intended to use it.
3. That on or about October 5, 2009, in and about Washington County in the
Southern District of Iowa, and elsewhere, the defendant, KATELYN MARIE CURTIS, a/k/a
Katalyn Maria Curtis, did knowingly possess a firearm in furtherance of, and carry a firearm
during and in relation to, a crime of violence, that is, a violation ofTitle 18, United States Code,
Sections 2113(a) and 2113(d), as set forth in Count 1 of the Indictment and described in
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