UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION

UNITED STATES OF AMERICA, )

) REDACTED PURSUANT TO
Plaintiff, ) E-GOVERNMENT ACT OF 2002
)
v. ) Criminal No. H-08-597
)
ALBERT JACKSON STANLEY, )
)
Defendant. )
)

PLEA AGREEMENT,

The United States of America, by and through Steven A. Tyrrell, Chief of

the Fraud Section, Criminal Division, United States Department of Justice, and

William J. Stuckwisch and Patrick F. Stokes, Trial Attorneys, and the Defendant,

Albert Jackson Stanley, by and through his counsel, Larry Ve~elka, pursuant to

Rule 11 (c)(1 )(C) of the Federal Rules of Criminal Procedure, state that they have

entered into an agreement, the terms and conditions of which are as follows:

The Defendant's Agreement

1. The Defendant agrees to waive Indictment and to plead guilty to an

Information (a copy of which is attached) charging him with two counts of

conspiracy to commit an offense against the United States, in violation of Title 18,

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United States Code, Section 371. Count 1 of the Information charges the

Defendant with conspiracy to violate the Foreign Corrupt Practices Act, in

violation of Title 15, United States Code, Section 78dd-2. Count 2 of the

Information charges the Defendant with a conspiracy to commit mail and wire

fraud, in violation of Title 18, United States Code, Sections 1341,1343, and 1346.

The Defendant, by entering this plea, agrees that he is waiving any right to have

the facts that the law makes essential to the punishment charged in the

Information, or proven to a jury or proven beyond a reasonable doubt.

2. Defendant agrees that this plea agreement binds only the Criminal

Division of the U.S. Department of Justice and the Defendant; it does not bind any

United States Attorney or any other Division of the Department of Justice.

Punishment Range

3. The statutory maximum penalty for each violation of Title 18, United

States Code, Section 371, is imprisonment for a term of not more than five years

and a fine of not more than $250,000, or twice the gross pecuniary gain to the

Defendant or loss to the victim(s), whichever is greater. The combined statutory

maximum term of imprisonment for the two counts is imprisonment for a term of

not more than ten years. Additionally, the Defendant may receive a term of

supervised release after imprisonnlent of up to three years on each count. Title 18,

Page 20[23
United States Code, Sections 3559(a)(4) and 3583(b)(2). The Defendant

acknowledges and understands that should he violate conditions of supervised

release which may be imposed as part of his sentence, then the Defendant may be

imprisoned for an additional term of up to two years, without credit for time

already served on the term of supervised release prior to such violation. Title 18,

United States Code, Sections 3559(a)(4) and 3583(e)(3). The Defendant

understands that he cannot have the imposition or execution of the sentence

suspended, nor is he eligible for parole.

Mandatory Special Assessment

4. Pursuant to Title 18, United States Code, Section 30 13(a)(2)(A),

immediately after sentencing, the Defendant will pay to the Clerk of the United

States District Court a special assessment in the amount of one hundred dollars

($100.00) per count of conviction, for a total of two hundred dollars ($200.00).

The payment will be by cashier's check or money order payable to the Clerk of

the United States District Court, c/o District Clerk's Office, P.O. Box 61010,

Houston, Texas 77208, Attention: Finance.

Restitution, Forfeiture, and Fines

5. This plea agreement is being entered into by the United States on the

basis of the Defendant's express representation that the Defendant will make a full

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and complete disclosure of all assets over which the Defendant exercises direct or

indirect control, or in which the Defendant has any financial interest.

6. The Defendant agrees to make complete financial disclosure to the

United States by truthfully executing a sworn financial statement by the deadline

set by the United States, or ifno deadline is set, no later than sentencing. The

Defendant agrees to authorize the release of all financial information requested by

the United States, including, but not limited to, executing authorization forms for

the United States to obtain tax information, bank account records, credit history,

and social security information. The Defendant agrees to discuss or answer any

questions by the United States relating to the Defendant's complete financial

disclosure.

7. The Defendant agrees to pay restitution to the victim(s) of Count 2 of the

Information. The Defendant stipulates and agrees that as a result of his criminal

conduct the victim, his former employer, incurred a monetary loss of $1 0.8

million. The Defendant and the United States agree to recommend that the Court

order restitution of $1 0.8 million.

8. The parties contemplate that the United States will seek the transfer to

the United States of certain of the Defendant's assets in the following bank

accounts in Switzerland that have been frozen by the Swiss authorities and will

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seek to apply those assets to satisfy, in whole or in part, the Court's restitution

order: Credit Suisse (ZH) account number ,in the name of Kirton

Investments Inc.; Credit Suisse (ZH) account number ,in the name

of Black Eagle Foundation; and Credit Suisse (ZH) account number

11 in the name of Meritco Investment S.A. Upon entering his guilty plea, the

Defendant agrees to waive all rights in, interest in, and title to the aforementioned

accounts, to take all steps as requested by the United States to facilitate the

transfer of the assets in the aforementioned accounts to the United States and the

application of the assets to restitution, and to testify truthfully in any related

proceeding. The Defendant further agrees that the amount of restitution that can .

be paid using the assets in these accounts will be due and payable as soon as the

assets are transferred to the United States and available for restitution.

9. The Defendant further agrees to liquidate through an arms-length

transaction his interest in the real property located at

, that he holds through

Kirton Investments Inc., within six months of the date of the entry of his guilty

plea, which time period may be extended by the United States, and to pay all or

that portion necessary of the proceeds of the transaction, net of any transaction

costs, to satisfy his obligation to make restitution under this agreement. The

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 United States agrees not to bring further charges based on the transactions required

by this paragraph.

10. The Defendant understands that under the United States Sentencing

Guidelines, the Court may order the Defendant to pay a fine to reimburse the

government for the costs of any imprisonment or term of supervised release. To

the extent that the Court orders restitution consistent with paragraph 7, the United

States u"".",,,,,,, to recommend that the Court not impose a fine.

Cooperation

] 1. The parties understand this agreement carries the potential for a motion

for departure under Section SKI.1 of the United States Sentencing Guidelines. The

Defendant understands and agrees that whether such a motion is filed will be

determined solely by the United States through the Fraud Section of the Criminal

Division of the United States Department of Justice. Should the Defendant's

cooperation, in the sole judgment and discretion of the United States, amount to

"substantial assistance," the United States reserves the sole right to file a motion for

departure pursuant to Section 5Kl.l of the United States Sentencing Guidelines.

The Defendant understands and agrees that the United States will request that

sentencing be deferred until his cooperation is complete. During that time, the

Defendant agrees to persist in his plea of guilty through sentencing and

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to fully cooperate with the United States as described below.

12. The Defendant understands and agrees that "fully cooperate," as used

herein, includes providing all information relating to any criminal activity known

to the Defendant, including providing assistance to foreign authorities at the

direction of the United States. The Defendant understands that this includes

providing information about all state, federal, and foreign law offenses about

which he has knowledge. In that regard:

(a) Defendant agrees to testifY truthfully as a witness before a grand jury

or in any other judicial or administrative proceeding when called
upon to do so by the United States, including in a proceeding in a
foreign jurisdiction. Defendant further agrees to waive his Fifth
Amendment privilege against self-incrimination for the purpose of
this agreement;

(b) Defendant agrees to voluntarily attend any interviews and

conferences as the United States may request on reasonable notice;

(c) Defendant agrees to provide truthful, complete and accurate

information and testimony and understands any false statements made
by the Defendant to the Grand Jury or at any court proceeding
(criminal or civil), or to a government agent or attorney can and will
be prosecuted under the appropriate perjury, false statement or
obstruction statutes;

(d) Defendant agrees to provide to the United States all documents in his
possession or under his control relating to all areas of inquiry and
investigation.

(e) Should the recommended departure, if any:, not meet the Defendant's
expectations, the Defendant understands he remains bound by the

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 terms of this agreement and cannot, for that reason alone, withdraw
his plea.

Waiver of Appeal

13. The Defendant is aware that Title 18, United States Code, Section 3742

affords a Defendant the right to appeal the sentence imposed. Additionally, the

Defendant is aware that Title 28, United States Code, Section 2255, affords the

right to contest or "collaterally attack" a conviction or sentence after the

conviction or sentence has become final. If the Court accepts the plea agreement

pursuant to Rule ll(c)(1)(C) and sentences the Defendant to the agreed-upon

sentence as set forth in paragraph 19, the Defendant agrees to waive the right to

appeal the sentence imposed or the manner in which it was determined, and the

Defendant waives the right to contest his conviction or sentence by means of any

post-conviction proceeding.

14. In agreeing to these waivers, the Defendant is aware that a sentence has

not yet been determined by the Court. The Defendant is also aware that any

promise, representation, or estimate of the possible sentencing range under the

Sentencing Guidelines that he may have received from his counsel, the United

States, or the Probation Office is a prediction, not a promise, and is not binding on

the United States, the Probation Office, or the Court, other than as provided in

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paragraph 19. The Defendant further understands and agrees that the United

States Sentencing Guidelines are "effectively advisory" to the Court. United

States v. Booker, 125 S.Ct. 738 (2005). Accordingly, the Defendant understands

that, although the Court must consult the United States Sentencing Guidelines and

must take them into account when sentencing the Defendant, the Court is not

bound to follow the United States Sentencing Guidelines and is not required to

sentence the Defendant within the calculated guideline range. However, if the

Court accepts this plea agreement, the Court is bound by the sentencing provision

in paragraph 19.

15. The Defendant understands and agrees that all waivers contained in the

agreement are made in exchange for the concessions made by the United States in

this plea agreement. If the Defendant instructs his attorney to file a notice of

appeal of his sentence or of his conviction, or if the Defendant instructs his

attorney to file any other post-conviction proceeding attacking his conviction or

sentence, the Defendant understands that the United States will seek specific

performance of the Defendant's waivers in this plea agreement of the Defendant's

right to appeal his conviction or sentence and of the Defendant's right to file any

post-conviction proceedings attacking his conviction or sentence.

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 The United States' Agreements

16. The United States agrees that, except as provided in this agreement, no

further criminal charges will be brought against the Defendant for any act or

offense in which he participated in his capacity as an officer and/or employee of

EPC Contractor A or EPC Contractor AI, or for any act or offense relating to the

Defendant's transactions with or use of the proceeds of the conspiracies charged,

provided such conduct was disclosed to the United States by the Defendant prior

to the date the Defendant executes this agreement.

United States' Non-Waiver of Appeal

17. The United States reserves the right to carry out its responsibilities

under guidelines sentencing. Specifically, the United States reserves the right:

(a) to bring its version of the facts of this case, including its evidence file
and any investigative files, to the attention of the Probation Office in
connection with that office's preparation of a presentence report;

(b) to set forth or dispute sentencing factors or facts material to

sentencing;

(c) to seek resolution of such factors or facts in conference with the

Defendant's counsel and the Probation Office;

(d) to file a pleading relating to these issues, in accordance with U.S.S.G.

Section 6Al.2 and Title 18, United States Code, Section 3553{a); and

(e) to appeal the sentence imposed or the manner in which it was

determined.

Page 10 of23
 Sentence Determination

18. The Defendant is aware that the sentence will be imposed after

consideration of the United States Sentencing Guidelines and Policy Statements,

which are only advisory, as well as the provisions of Title 18, United States Code,

Section 3553(a). The United States and the Defendant agree that the applicable

Sentencing Guidelines range exceeds 84 months' imprisonment.

19. Pursuant to Rule 11 (c)(1 )(C) of the Federal Rules of Criminal

Procedure, the United States and the Defendant agree that a term of imprisonment

of84 months is the appropriate disposition of the case. The Defendant

understands that, if the Court rejects the plea agreement, the Court must (i) inform

the parties that the Court rejects the plea agreement, (ii) advise the Defendant

personally that the Court isnot required to follow the plea agreement and give the

Defendant the opportunity to withdraw the plea, and (iii) advise the Defendant

personally that if the plea is not withdrawn, the Court may dispose of the case less

favorably toward the defendant than the plea agreement contemplated. The

Defendant agrees that he will not seek a sentence below 84 months' imprisonment,

and the Defendant understands that except under the circumstances described in

paragraph 20 below, the Court will be required to impose a sentence of 84 months'

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imprisonment if the Court accepts the plea agreement.

20. If the Defendant provides truthful, complete, and accurate infonnation

to the United States and fully cooperates with the United States pursuant to the

plea agreement, then the United States in its sole and exclusive discretion may

move the Court, pursuant to Section 5K1.1 of the United States Sentencing

Guidelines and Title 18, United States Code, Section 3553(e), to depart downward

from the 84-month agreed-upon sentence set forth in paragraph 19. The

Defendant agrees that he will not move for a downward departure on any grounds

and that no such grounds are applicable.

Rights at Trial

21. The Defendant represents to the Court that he is satisfied that his

attorneys have rendered effective assistance. The Defendant understands that by

entering into this agreement, he surrenders certain rights as provided in this plea

agreement. The Defendant understands that the rights of a defendant include the

following:

(a) If the Defendant persisted in a plea of not guilty to the charges, the
Defendant would have the right to a speedy jury trial with the
assistance of counsel. The trial may be conducted by a judge sitting
without a jury if the Defendant, the United States, and the court all
agree.

(b) At a trial, the United States would be required to present witnesses

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 and other evidence against the Defendant. The Defendant would
have the opportunity to confront those witnesses and his attorney
would be allowed to cross-examine them. In turn, the Defendant
could, but would not be required to, present witnesses and other
evidence on his own behalf. If the witnesses for the Defendant
would not appear voluntarily, he could require their attendance
through the subpoena power of the court.

(c) At a trial, the Defendant could rely on a privilege against self-

incrimination and decline to testify, and no inference of guilt could be
drawn from such refusal to testify. However, if the Defendant desired
to do so, he could testify on his own behalf.

Factual Basis for Guilty Plea

22. The Defendant is pleading guilty because he is guilty of the charges

contained in Counts 1 and 2 of the Information. If this case were to proceed to

trial, the United States would prove each element of the offenses charged in the

Information beyond a reasonable doubt. The Defendant understands that the

United States would submit testimony and physical and documentary evidence

that would establish the following facts, among others:

The Defendant

a. At all times relevant to the Information, STANLEY was a United

States citizen and a resident of Houston, Texas. STANLEY and his
co-conspirators committed acts in furtherance of the schemes
described below in Houston, Texas. From in or about March 1991,
until in or about June 2004, STANLEY served in various capacities
as an officer and/or director ofEPC Contractor Al and its successor
..---~---_._------
This factual basis refers to persons and entities, such as EPC Contractor A, using the
same terms as are used in the Information to which STANLEY is pleading guilty. STANLEY

Page 13 of23
 company, EPC Contractor AI.

The Bonny Island Bribery. Scheme

b. At all times relevant to the Information, STANLEY was one of the

executives at EPC Contractor A and then EPC Contractor Al with
responsibility for obtaining the EPC contracts to build the Bonny
Island Project, a series of four contracts awarded between 1995 and
2004 (corresponding to Trains 1 and 2; Train 3; Trains 4 and 5; and
Train 6), collectively valued at over $6 billion, to build liquefied
natural gas ("LNG") facilities on Bonny Island, Nigeria. STANLEY
also was EPC Contractor NEPC Contractor AI's senior
representative on the Steering Committee of Joint Venture. The
Steering Committee made major decisions on behalf of Joint Venture,
including authorizing the retention and compensation of agents.

c. STANLEY believed that support of Nigerian government officials,

including top-level executive branch officials, high-level Petroleunl
Ministry officials, NNPC officials, and NLNG officials and
employees, was necessary for the Bonny Island Project EPC
Contracts to be awarded to Joint Venture. STANLEY also knew that
it was unlawful under U.S. law to bribe foreign government officials.

d. In 1994, 1999,2001, and 2002, STANLEY authorized the hiring of

Consultant A and Consulting Company A by Joint Venture, expecting
that Consultant A and Consulting Company A would pay bribes to
high-level Nigerian government officials to assist Joint Venture, EPC
Contractor A, EPC Contractor AI, and others in winning the EPC
contracts to build the Bonny Island Project. In 1996, 1999, and 2001,
STANLEY also authorized the hiring of Consulting Company B by
Joint Venture, expecting that Consulting Company B would pay
bribes to lower level Nigerian government officials to assist Joint
Venture, EPC Contractor A, EPC Contractor AI, and others in
winning the EPC contracts to build the Bonny Island Project.

has reviewed the "Relevant Entities and Individuals" section ofthe Infonnation (paragraphs 2~
12) and admits the facts alleged therein based on his personal knowledge and/or admits that the
government would be able to prove the facts alleged therein at a trial.

Page 14 of23
e. At crucial junctures in the life of the Bonny Island Project,
STANLEY and others met with three successive holders of a top-
level office in the executive branch of the Government of Nigeria to
ask the office holder to designate a representative with whom Joint
Venture should negotiate bribes to Nigerian government officials. On
or about November 30, 1994, STANLEY and others met with the first
such top-level executive branch official in Abuja, Nigeria, to ask the
official to nominate a representative with whom Joint Venture should
negotiate the fees that Joint Venture would pay Consulting Company
A to pass on as bribes to Nigerian government officials. This top-
level executive branch official designated a high-level official of the
Ministry of Petroleum as his representative. Thereafter, as EPC
Contractor A's senior representative on Joint Venture's Steering
Committee, STANLEY authorized Joint Venture to enter into a
consulting agreement with Consulting Company A providing for
Joint Venture to pay it $60 million if the EPC contract for Trains 1
and 2 was awarded to Joint Venture. STANLEY intended that the
$60 million fee would be used, in part, to pay bribes to Nigerian
government officials.

f. On or about May 1, 1997, STANLEY and others again met in Abuja,

Nigeria, with the top-level executive branch official to ask the official
to nominate a representative with whom Joint Venture should
negotiate bribes to Nigerian government officials in exchange for the
award to Joint Venture of an EPC contract to build Train 3. At the
meeting, the top-level executive branch official designated a senior
executive branch official as his representative.

g. On or about February 28, 1999, STANLEY and others met in Abuja,

Nigeria, with a second top-level executive branch official. At the
meeting, STANLEY asked the second top-level executive branch
official to nominate a representative with whom Joint Venture should
negotiate bribes to Nigerian government officials in exchange for the
award to Joint Venture of an EPC contract to build Train 3. At the
meeting, the second top-level executive branch official designated
one of his advisers as his representative.

Page 15 of23
 h. On or about March 5, 1999, STANLEY and other co-conspirators met
at a hotel in London, England, with the adviser designated by the
second top-level executive branch official to negotiate the amount of
bribes to be paid to the second top-level executive branch official and
other Nigerian government officials in exchange for the award to
Joint Venture of an EPC contract to build Train 3. The amount
negotiated with the representative formed the basis for the $32.5
million fee that Joint Venture promised to pay Consulting Company
A. As EPC Contractor AI's senior representative on Joint Venture's
Steering Committee, STANLEY authorized Joint Venture to enter
into the consulting agreement with Consulting Company A, intending
that the $32.5 million fee would be used, in part, to pay bribes to
Nigerian government officials.

L On or about November 11,2001, STANLEY and other co-

conspirators met in Abl~ja, Nigeria, with a third top-level executive
branch official to ask the official to nominate a representative with
whom Joint Venture should negotiate bribes to Nigerian government
officials in exchange for the award to Joint Venture of an EPC
contract to build Trains 4 and 5. At the meeting, the third top-level
executive branch official designated a top-level official ofNNPC as
his representative. As EPC Contractor AI's senior representative on
Joint Venture's Steering Committee, STANLEY authorized Joint
Venture to enter into a consulting agreement with Consulting
Company A providing for Joint Venture to pay it $51 million if the
EPC contract for Trains 4 and 5 was awarded to Joint Venture. At the
time, STANLEY intended that the $51 million fee would be used, in
part, to pay bribes to Nigerian government officials.

J. In or about June 2002, STANLEY authorized Joint Venture to enter

into a consulting agreement with Consulting Company A providing
for Joint Venture to pay it $23 million if the EPC contract for Train 6
was awarded to Joint Venture. At the time, STANLEY intended that
the $23 million fee would be used, in part, to pay bribes to Nigerian
government officials.

Page 16 of23
The LNG Consultant Kickback Scheme

k. LNG Consultant was a salesperson at EPC Contractor A until in or

about 1988, when he resigned as an employee and became a
consultant to EPC Contractor A. In or about 1991 , STANLEY and
LNG Consultant agreed that (I) STANLEY would arrange for LNG
Consultant to receive lucrative consulting agreements with EPC
Contractor A and, later, EPC Contractor AI, and (ii) LNG Consultant
would "kick back" to STANLEY a portion of the consulting fees that
LNG Consultant received from EPC Contractor A and EPC
Contractor AI. STANLEY and LNG Consultant concealed the
kickback scheme from EPC Contractor A, EPC Contractor A's parent
company, EPC Contractor AI, and EPC Contractor AI's parent
company. At the time, STANLEY knew that the codes of conduct of
the parent companies of EPC Contractor A and EPC Contractor Al
prohibited these payments. STANLEY also knew that other officers
and employees of EPC Contractor A, EPC Contractor AI, and their
respective parent companies would not have approved consulting
contracts with companies related to LNG Consultant if they had
known about the kickback scheme.

1. During the ensuing years, as described below, LNG Consultant or

companies he designated and controlled, with the assistance of
STANLEY, obtained a series of lucrative consulting agreements with
EPC Contractor A and EPC Contractor A 1. These agreements
generally provided for the payment ofa fixed $10 million success fee
if the LNG plant project covered by the agreement was awarded to
EPC Contractor AJEPC Contractor A 1.

m. In April 1992, STANLEY caused EPC Contractor A to enter into a

consulting agreement for the Malaysia Dua LNG project with a
Lebanese consulting company designated and controlled by LNG
Consultant ("Lebanese Consulting Company"). Pursuant to the
consulting agreement, EPC Contractor A paid the Lebanese
Consulting Company $15 million. LNG Consultant kicked back to
STANLEY a total of$4.75 million by directing the Lebanese
Consulting Company to wire transfer payments to a Swiss bank

Page 17 of23
 account controlled by STANLEY after receiving each installment
payment from EPC Contractor A.

n. In January 1996, STANLEY caused EPC Contractor A to enter into a

consulting agreement for Trains 1 and 2 of the Bonny Island Project
with a second company designated and controlled by LNG Consultant
("BVI Consulting Company"). Pursuant to the consulting agreement,
EPC Contractor A paid BVI Consulting Company $10 million. LNG
Consultant kicked back to STANLEY a total of $1.95 million by wire
transferring payments to a Swiss bank account controlled by
STANLEY after receiving each installment payment from EPC
Contractor A.

o. . In or about August 1998, STANLEY caused EPC Contractor A to

enter into a consulting agreement for the Malaysia Tiga LNG project
with BVI Consulting Company. Pursuant to the consulting
agreement, EPC Contractor AI, as the successor company to EPC
Contractor A, paid BVI Consulting Company $13.3 million. LNG
Consultant kicked back to STANLEY a total of$4.1 million by
causing wire transfers to the Swiss bank account of Amal
Development Inc., a Panama corporation controlled by STANLEY.

p. In or about June 2001, STANLEY caused EPC Contractor Al to enter

into consulting agreements for the Yemen LNG project and the Egypt
LNG project with BVI Consulting Company. In or about April 2003,
STANLEY caused EPC Contractor Al to enter into a consulting
agreement for the Indonesia LNG project with BVI Consulting
Company. In each of these agreements, EPC Contractor Al promised
to pay BVI Consulting Company a success fee of $10 million.
Pursuant to the agreement for the Egypt LNG project, EPC Contractor
A 1 paid BVI Consulting Company a total of $1 0 million between
February 2002 and July 2003.

q. In or about 2004, STANLEY talked separately with LNG Consultant

and with one of LNG Consultant's colleagues about potential cover
stories that could be used to explain STANLEY's receipt of payments
from the Lebanese consulting company and BVI Consulting

Page 18 of23
 Company.

Breach of Plea Agreement

23. If the Defendant should fail in any way to fulfill completely all of the

obligations under this plea agreement, the United States will be released from its

obligations under the plea agreement, and the Defendant's plea and sentence will

stand. If at any time the Defendant retains, conceals or disposes of assets in

violation of this plea agreement, or if the Defendant knowingly withholds

evidence or is otherwise not completely truthful with the United States, then the

United States may move the Court to set aside the guilty plea and reinstate

prosecution. Any information and documents that have been disclosed by the

Defendant, whether prior or subsequent to this plea agreement, and all leads

derived therefrom, will be used against the Defendant in any prosecution.

24. Whether the Defendant has breached any provision of this plea

agreement shall be determined solely by the United States through the Fraud

Section of the Criminal Division of the United States Department of Justice,

whose judgment in that regard is final.

Complete Agreement

25. This written plea agreement, consisting of23 pages, including the

attached addendum of the Defendant and his attorney, constitutes the complete

Page 19 of23
plea agreement between the United States, the Defendant, and his counsel. No

promises or representations have been made by the United States except as set

forth in writing in this plea agreement. The Defendant acknowledges that no

threats have been made against him and that he is pleading guilty freely and

voluntarily because he is guilty.

26. Any modification of this plea agreement must be in writing and signed

by all parties.

Filed at Houston, Texas, o~, 2008.

~~
AJbeTtJaSOllSta
Defendant

Subscribed and sworn to before me on~W 3 ' . 2008.

MICHAEL N. MILBY
ITED STATES DISTRICT CLERK

APPROVED:

STEVEN A. TYRRELL, CHIEF

FRAUD SECTION
CRIJVIINAL DIVISION
U.S. DEPARTMENT OF JUSTICE

Page 20 of23
-k'~~ .
LarryVG -
Attorney for Defendant Albert Jackson Stanley

Page 21 of23
 UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION

UNITED STATES OF AMERICA, )

)
Plaintiff, )
)
v. ) Criminal No. H-08-597
)
ALBERT JACKSON STANLEY, )
)
Defendant. )
)

PLEA AGREEMENT - ADDENDUM

I have fully explained to the Defendant his rights with respect to the

Information. I have reviewed the provisions of the United States Sentencing

Guidelines and I have fully and carefully explained to the Defendant the

provisions of those Guidelines which may apply in this case. I have also

explained to the Defendant that the Sentencing Guidelines are only advisory.

Further, I have carefully reviewed every part of this plea agreement with the

Defendant. To my knowledge, the Defendant's decision to enter into this

agreement is an informed and voluntary one.

s.",i i ~01IJr
Date

Page 22 of23
 I have consulted with my attorney and fully understand all my rights with

respect to the Information against me. My attorney has fully explained and I

understand all my rights with respect to the provisions of the United States

Sentencing Guidelines which may apply in my case. I have read and carefully

reviewed every part of this plea agreement with my atton1ey. I understand this

agreement and I voluntarily agree to its terms.

~~~
Defendant
08

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