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intoxicant or depressant that would impair my ability to fully understand the terms and
conditions of this plea agreement.
ELEMENTS
Aiding and Abetting an Alien to Elude Examination and Inspection
On or about April 13, 2017, in the District of Arizona:
1. John Doe, a juvenile, was an alien;
2. John Doe, a juvenile, committed the crime of eluding examination and
inspection by immigration officials;
3. The defendant aided, counseled, commanded, induced or procured John Doe,
a juvenile, with respect to at least one element of eluding examination and
inspection by immigration officials;
4. The defendant acted with the intent to facilitate John Doe’s crime of eluding
examination and inspection by immigration officials.
5. The defendant acted before the crime was completed
FACTUAL BASIS
I further admit the following facts are true and if this matter were to proceed to trial
the United States could prove the following facts beyond a reasonable doubt:
Beginning on an unknown date, and continuing through on or about April
13, 2017, in Mesa, Arizona, I received information from my juvenile son,
John Doe, that he had arrived at the U.S. — Mexican border from El Salvador.
John Doe explained to me that he had found a smuggler to assist him with
crossing into the United States illegally. I then had converstations with the
alien smuggler who requested a fee of $4,000, to be transferred via Western
Union, to facilitate John Doe’s entry into the United States. I then made wire
transfers in increments of $800 - $1000 to individuals in Mexico to facilitate
John Doe’s illegal entry. I knew John Doe did not have legal authorization
to enter the United States and I transferred money to an alien smuggler to aid

John Doe elude examination and inspection by Immigration Officials of the
United States.



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6. EFFECT ON OTHER PROCEEDINGS

This agreement does not preclude the United States from instituting any civil or

administrative proceedings as may be appropriate now or in the future.
DEFENDANT'S APPROVAL AND ACCEPTANCE

I have read the entire plea agreement with the assistance of counsel and understand
each of its provisions.

I have discussed the case and my constitutional and other rights with my attorney.
I understand that by entering my plea of guilty I will be giving up my rights to plead not
guilty; to have a trial; to confront, cross-examine, and compel the attendance of witnesses;
to present evidence in my defense; to remain silent and refuse to be a witness against myself
by asserting my privilege against self-incrimination; and to be presumed innocent until
proven guilty beyond a reasonable doubt, all with the assistance of counsel.

I agree to enter my guilty plea as indicated above on the terms and conditions set
forth in this agreement.

I have been advised by my attorney of the nature of the charges to which I am
entering my guilty plea. I have further been advised by my attorney of the nature and range
of the possible sentence.

My guilty plea is not the result of force, threats, assurances or promises other than
the promises contained in this agreement. I agree to the provisions of this agreement as a
voluntary act on my part and I agree to be bound according to its provisions.

I agree that this written plea agreement contains all the terms and conditions of my
plea. I further agree that promises made by anyone (including my attorney) that are not
contained within this written plea agreement are null and void and have no force and effect.

I am satisfied that my defense attorney has represented me in a competent manner.

I am fully capable of understanding the terms and conditions of this plea agreement.

I am not now using or under the influence of any drug, medication, liquor, or other



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I have read this agreement and I have carefully reviewed every part of it with my
attorney. | understand it, and I voluntarily agree to it.

Oblig/wlr Abeba. Spycle 2.

Date Adela Del Carmen Sanchez-Arevalo
Defendant

DEFENSE ATTORNEY'S APPROVAL

I have discussed this case and the plea agreement with my client in detail and have
advised the defendant of all matters within the scope of Fed. R. Crim. P. 11, the
constitutional and other rights of an accused, the factual basis for and the nature of the
offense to which the guilty plea will be entered, possible defenses, and the consequences
of the guilty plea including the maximum statutory sentence possible. I have discussed the
concept of the advisory Sentencing Guidelines with the defendant. No assurances,
promises, or representations that are not contained in this written agreement have been
given to me or to the defendant by the United States or any of its representatives. I have
concluded that the entry of the plea as indicated above on the terms and conditions set forth
in this agreement are in the best interests of my client. I agree to make a bona fide effort
to ensure that the guilty plea is entered in accordance with all the requirements of Fed. R.

Crim. P. 11. —
\

ylialie Da
Date DENISE AGUILAR
Attorney for Defendant



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ELIZABETH A. STRANGE fff . ne
First Assistant United States Attorney ~ APILED LODGED
District of Arizona —
SEAN K. LOKEY

Assistant U.S. Attorney
California State Bar No. 211373
Two Renaissance Square

40 N. Central Ave., Suite 1800
Phoenix, Arizona 85004
Telephone: 602-514-7500
Email: sean.lokey@usdoj.gov

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA

United States of America,
Plaintiff,
v. PLEA AGREEMENT

No. CR-17-01458-PHX-ESW

Adela Del Carmen Sanchez-Arevalo,

Defendant.

The United States of America and the defendant hereby agree to the following

disposition of this matter:
PLEA

The defendant will plead guilty to an Information charging the defendant with a
violation of 8 U.S.C. § 1325(a)(2) and 18 U.S.C. § 2, Aiding and Abetting an Alien to
Elude the Examination and Inspection of Immigration Officers of the United States, a class
B misdemeanor offense.
1, MAXIMUM PENALTIES

A violation of 8 U.S.C. § 1325(a)(2) and 18 U.S. C. § 2 is punishable by a maximum
fine of $5,000.00, a maximum term of imprisonment of 6 months, or both. The maximum

term of probation is five years.



1 UNITED STATES’ APPROVAL

iz I have reviewed this matter and the plea agreement. I agree on behalf of the United

3| States that the terms and conditions set forth are appropriate and are in the best interests of

4] justice.

5 ELIZABETH A. STRANGE

First Assistant United States Attorney
6 District of Arizona
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Date . .

9 Assistant U.S. Attorney
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ul COURT’S ACCEPTANCE

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6-4. 01h Ww det
13] Date HONORABLE EILEEN S. WILLETT
14 United States Magistrate Judge
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Pursuant to 18 U.S.C. § 3013(a)(1)(A)(ii), the Court is required to order the
defendant to pay a $10 special assessment.

2. AGREEMENTS REGARDING SENTENCING

a. Pursuant to Fed. R. Crim. P. 11(c)(1)(C), the United States and the defendant
stipulate and agree that defendant will be sentenced to a two-year term of probation with
no jail time to be imposed.

b. Pursuant to Fed. R. Crim. P. 11(c)(1)(A), the United States will dismiss at
the time of sentencing the Indictment charging a violation of 8 U.S.C. §§ 1324(a)(1)(A)(i),
(a)(1)(A)(v)(), Conspiracy to Bring Illegal Alien to the United States. In addition, this
office will not prosecute the defendant for any additional offenses committed by the defen-
dant, and known by the government, which are detailed in the discovery released to the
defendant and in the factual basis of this agreement which relate to violations of 8 U.S.C.
§ 1324(a)(1)(A)(ii), Illegal Transportation of an Alien, a class D felony offense punishable
by up to five years of imprisonment. This agreement does not, in any manner, restrict the
actions of the United States in any other district nor bind any other United States Attorney's
Office.

c. Waiver of Presentence Investigation Report. The United States and the
defendant waive a presentence investigation report and agree that sentencing may occur on
the day of the change of plea.

3. COURT APPROVAL REQUIRED; REINSTITUTION OF PROSECUTION

If the Court, after reviewing this plea agreement, concludes that any provision is
inappropriate, it may reject the plea agreement and give the defendant the opportunity to
withdraw the guilty plea in accordance with Fed. R. Crim. P. 11(c)(5).

If the defendant's guilty plea or plea agreement is rejected, withdrawn, vacated, or
reversed at any time, this agreement shall be null and void, the United States shall be free
to prosecute the defendant for all crimes of which it then has knowledge, and any charges

that have been dismissed because of this plea agreement shall automatically be reinstated.

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In such event, the defendant waives any and all objections, motions, or defenses based
upon the Statute of Limitations, the Speedy Trial Act or constitutional restrictions in
bringing of the later charges or proceedings. The defendant understands that any
statements made at the time of the defendant's change of plea or sentencing may be used
against the defendant in any subsequent hearing, trial, or proceeding pursuant to the
limitations of Fed. R. Crim. P. 11(f) and Fed. R. Evid. 410.
4. WAIVER OF DEFENSES AND APPEAL RIGHTS

The defendant waives: (1) any and all motions, defenses, probable cause
determinations, and objections that the defendant could assert to the indictment or
information; and (2) any right to file an appeal, any collateral attack, and any other writ or
motion that challenges the conviction, an order of restitution or forfeiture, the entry of
judgment against defendant, or any aspect of the defendant’s sentence, including the
manner in which the sentence is determined, including but not limited to any appeals under
18 U.S.C. § 3742 (sentencing appeals) and motions under 28 U.S.C. §§ 2241 and 2255
(habeas petitions), and any right to file a motion for modification of sentence, including
under 18 U.S.C. § 3582(c). This waiver shall result in the dismissal of any appeal,
collateral attack, or other motion the defendant might file challenging the conviction, order
of restitution or forfeiture, or sentence in this case. This waiver shall not be construed to
bar an otherwise-preserved claim of ineffective assistance of counsel or of “prosecutorial
misconduct” (as that term is defined by Section II.B of Ariz. Ethics Op. 15-01 (2015)).
5. PERJURY AND OTHER OFFENSES

Nothing in this agreement shall be construed to protect the defendant in any way
from prosecution for perjury, false declaration or false statement, obstruction of justice, or
any other offense committed by the defendant after the date of this agreement. Any
information, statements, documents, or evidence the defendant provides to the United
States pursuant to this agreement, or to the Court, may be used against the defendant in all

such prosecutions.