Plea Agreement in Case of Tony Mitchell Case

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Case 6:24-cr-00298-ACA-NAD Document 2 Filed 07/31/24 Page 1 of 18 FILED

2024 Jul-31 PM 04:25


U.S. DISTRICT COURT
N.D. OF ALABAMA

IN THE UNITED STATES DISTRICT COURT


FOR THE NORTHERN DISTRICT OF ALABAMA
JASPER DIVISION

UNITED STATES OF AMERICA )


) Case No.
v. )
)
JOSHUA CONNER JONES )

PLEA AGREEMENT

The Government and the defendant, JOSHUA CONNER JONES, hereby

acknowledge the following plea agreement in this case:

PLEA

The defendant agrees to (i) plead guilty to COUNTS ONE and TWO of the

Information filed in the above-numbered and -captioned matter; (ii) stipulate to

United States Sentencing Guideline §2Al.4(a)(2)(A)(Involuntary Manslaughter

Involving Reckless Conduct)-18 Base Offense Level, and (iii) waive certain rights

to direct appeal and collateral attack as outlined in section IV of this agreement. In

exchange, the United States Attorney, acting on behalf of the Government and

through the undersigned Assistant United States Attorney, agrees to recommend the

disposition specified below, subject to the conditions in section Vll.

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TERMS OF THE AGREEMENT

I. MAXIMUM PUNISHMENT

The defendant understands that the maximum statutory punishment that

may be imposed for the crime of Conspiracy to Deprivation of Rights under Color

of Law, in violation of Title 18, United States Code, Section 241, as charged in

COUNT ONE is:

A. Imprisonment for not more than life imprisonment;

B. A fine of not more than $250,000.00, or;

C. Both (a and b);

D. Supervised release of not more than five years; and

E. Special Assessment Fee of$100 per count.

The defendant understands that the maximum statutory punishment that may

be imposed for the crime of Deprivation of Rights under Color of Law, in violation

of Title 18, United States Code, Section 242, as charged in COUNT TWO is:

A. Imprisonment for not more than ten years;

B. A fine of not more than $250,000.00, or;

C. Both (a and b);

D. Supervised release of not more than three years; and

E. Special Assessment Fee of$100 per count.

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II. FACTUAL BASIS FOR PLEA

The Government is prepared to prove, at a minimum, the following facts at

the trial of this case:

A. Deliberate Indifference to Individual #1 's Medical Needs

On January 12, 2023, the Walker County Jail (Jail) was headed by the elected
Sheriff, the Jail Administrator, the Captain, and officers who served as shift
supervisors over two day shifts and two night shifts. Each shift was staffed by several
officers who performed various duties related to the care, custody, and control of the
pre-trial and post-conviction detainees housed there. In general, officers typically,
worked 12-hour shifts on a rotation of 4 days on, 4 days off, 3 days on, 3 days off
over the course of a two-week period.

While the Jail contained several dorms to house detainees, a limited number
of inmates were held for limited periods in observation cells in the "Booking" area.
Booking consisted of the Booking desk which formed the central hub of detainee
intake, jail movement, communication, and operations. Eight booking cells could be
directly observed by officers at the Booking desk several feet away. Among the eight
Booking cells, BKS was unique in that it was essentially a cement box with a small
grate on the floor that opens into a hole for fluids to drain from the cell. Capable of
being "flushed" only from outside of the cell, BKS was often referred to as the drunk
tank in that it could easily be hosed down when inebriated people held there would
vomit. BKS was unlike all other cells in the Jail, but for observation cell AH3, which
had no hole in the floor and was used only for holding detainees for hours at a time.

BKS did not have a sink, a toilet, access to any running water, or a raised
platform to be used as a bed. Detainees housed in BKS depended on officers to escort
them to a toilet or shower and relied on officers to bring them water. BKS was
notoriously cold during winter months and the temperature on the bare cement floor
was even colder. A small window was located on the top half of the cell door and a
larger window covered the bottom half of the door. Again, this bottom window was
unique among the observation cells, other than AH3, and offered considerably more
opportunity for observation from the Booking desk than any of the other Booking
cells.

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Medical and mental health services were provided by an outside contractor


hired by Walker County. As part of the booking process, all detainees booked into
the jail were supposed to receive a medical and mental health screening to ensure
that emergent and urgent health needs are met and to determine, among other things,
their fitness for confinement. Jailers were trained that some time after the booking
process was completed medical personnel would identify daily each detainee that
needed to be seen by a nurse for an initial intake evaluation ("Initial Intake") or for
ongoing consultation/evaluation, including providing approved medicine. For those
detainees housed in Booking, nurses would rely on officers for assistance to provide
necessary medical and mental health services, including escorts into the Jail's
medical unit which was located just down a short hallway from Booking.

On January 12, 2023, Walker County Sherrifs deputies responded to the


home of Individual # 1 in response to a request that they conduct a mental health
welfare check. Individual # 1 was arrested after he allegedly fired a gun while
deputies were on his property and officers on defendant JONES' Day shift were
informed that Individual # 1 was being brought in because "he shot at deputies."

Individual #1 was transported directly to the Jail in a patrol car that was met
in the Jail's sallyport by correctional officers and supervisors including defendant
JONES, CO-CONSPIRATOR #1, CO-CONSPIRATOR #2, CO-CONSPIRATOR
#3, CO-CONSPIRATOR #4, AND CO-CONSPIRATOR #5. Upon being removed
from the patrol, car, Individual # 1 could not walk or stand on his own. He was
disoriented, non-combative, and could not follow instructions. These observations
were obvious to everyone who removed Individual # 1 from the car and defendant
JONES believed that Individual #1 needed to be taken to a hospital or mental health
facility rather than being incarcerated at the Jail.

Upon entry into the Jail, Individual # 1 was taken to a dress-out room so that
he could change from his street clothes into a jail uniform. He was sufficiently
helpless that he was not capable of undressing or dressing himself. After several
attempts by officers to struggle with putting on a jail uniform on Individual # 1,
officers simply wrapped a suicide smock around him (known as a "turtle" suit)
without an indication that Individual # 1 was suicidal, instructions that he be treated
as if he was suicidal, or instructions that he needed to be naked for security reasons.

Thereafter, Individual #1 was taken by wheelchair to the medical unit which


was attended by the Health Services Administrator, NURSE 1, and NURSE 2. At
that time, NURSE 1 told defendant JONES, CO-CONSPIRATOR #2, CO-

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CONSPIRATOR #3, AND CO-CONSPIRATOR #4 that "she wanted to wait,"


referring to instructions from CO-CONSPIRATOR # 1 to deny the initial fit for
confinement screening to Individual #1. Defendant JONES, CO-CONSPIRATOR
#2, CO-CONSPIRATOR #3, and CO-CONSPIRATOR #4 turned the wheelchair
around, headed out of the medical unit, and placed Individual # 1 into cell BK5.

To the best of defendant JONES' knowledge, Individual #1 never received


any medical evaluation until the morning of his death, two weeks after he was
arrested. Defendant JONES worked seven shifts during Individual # 1's two-week
incarceration and during that time none of the officers, including defendant JONES,
made efforts to provide medical care for Individual #1 nor alter the conditions of his
confinement. To the contrary, defendant JONES, CO-CONSPIRATOR #2, CO-
CONSPIRATOR #3 and CO-CONSPIRATOR #4, actively denied medical access
to Individual # 1 by falsely telling medical staff that Individual # 1 was too combative
to be evaluated, when in truth that was not the case.

Calling Individual # 1 "combative" was an excuse to mistreat him. There was


no conduct that could have been committed by Individual # 1 that would have
justified the denial of medical access since the jail could manage or control any
behavior that Individual #1 might have exhibited. The capabilities of the Jail to
manage inmates were known and obvious to everyone who worked there, including
medical staff who routinely examined or evaluated the needs of inmates who were
in handcuffs or restraints of one kind or another. Moreover, Individual #1 was frailer
than most other inmates whom JONES and his CO-CONSPIRATORS encountered.

The efforts to deny Individual # 1 care persisted despite his obvious need for
mental health and medical services. Individual # 1 was frequently expressing severe
mental health symptoms such as talking incoherently about "demons" and "portals."
He was often covered in feces, which was an indication that he could not care for
himself. Nearly every time defendant JONES saw Individual # 1, he was on the floor
and "looked really bad." Defendant JONES observed Individual# 1 deteriorate over
the course of his incarceration. As the time passed, Individual #1 was almost always
naked, wet, cold, and covered in feces while lying on the cement floor without a mat
or blanket. By the second week of incarceration, Individual # 1 was largely listless
and mostly unresponsive to questions from officers. Nonetheless, neither defendant
JONES, nor any of the CO-CONSPIRATORS took steps to alter the conditions in
which Individual # 1 was housed despite Individual #l's obvious suffering.

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Despite the obviousness of Individual # 1's need to any and all who saw him
at any time during his incarceration, defendant JONES and his co-conspirators
actively chose not to provide care to Individual # 1. At least once during each shift,
either defendant JONES, or CO-CONSPIRATOR #2, CO-CONSPIRATOR #3, or
CO-CONSPIRATOR #4, would comment on Individual # 1's condition and some
member of the conspiracy would dismiss Individual # 1's needs by saying: "Fuck
him, he gets what he gets since he shot at cops," or words to that effect.

Moreover, defendant JONES and these CO-CONSPIRATORS repeatedly


made comments during the first few days of Individual #1 's detention to the effect
of Individual# 1 should have been killed because he shot at deputies rather than being
brought to the Jail, that they would have killed him if they were the ones responding
to the welfare check, and that road deputies should have killed him rather than
making the correctional officers have to deal with incarcerating him. At times,
defendant JONES and these CO-CONSPIRATORS spoke directly to Individual #1,
saying that he was now in their "house," and that he had to deal with them (the
officers). None of the CO-CONSPIRATORS, regardless of rank or seniority,
objected to or discouraged the comments from continuing. To the contrary, these
comments and comments like them continued amongst officers on this and other
shifts and reflected the indifference showed to Individual # 1's serious medical and
other needs throughout his incarceration.

At the beginning of his shift on January 26, 2023, around 6:00 am, CO-
CONSPIRATOR #5, told defendant JONES that a nurse had seen Individual #1 in
the early morning hours and ordered that Individual # 1 be transported to a hospital
and that the transport should take place as soon as possible. The same message was
conveyed by other officers to CO-CONSPIRATOR #2 in the presence of defendant
JONES and others.

Those officers were insistent in telling CO-CONSPIRATOR #2 that the nurse


said Individual # 1 could die if he was not taken to the hospital to the point of
repeating the message a second time to CO-CONSPIRATOR #2 after CO-
CONSPIRATOR #2 dismissed the concerns initially expressed. In response to the
second effort by those officers, CO-CONSPIRATOR #2 replied: "I'll tell you what,
next time you're on the toilet taking a shit, I'll call you to bother you with something
unimportant," or words to that effect.

According to defendant JONES, CO-CONSPIRATOR #1 AND CO-


CONSPIRATOR #2, both with supervisory positions at the Jail, failed to arrange for

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Individual # 1 to be transported to the hospital for more than 3 hours after officers
reported the nurse's instructions and the urgent need to do so. After defendant
JONES transported several detainees to court that morning, he was instructed to join
other officers at Walker Baptist Medical Center Hospital where Individual # 1 had
been transported by fellow officers in the back of a patrol car, rather than by
ambulance. Upon arrival, he learned that Individual #1 'smother had been called to
the emergency room and overheard her giving permission to medical staff to remove
Individual # 1 from life support.

Defendant JONES admitted that "collectively we did it. We killed him."

B. The Assault of Individual #2

On September 26, 2022, Individual #2 was a pre-trial detainee held in A-Dorm


of the Walker County Jail (Jail). Defendant JONES and OFFICER A were working
as correctional officers on one of the day shifts. As part of their duties, defendant
JONES and OFFICER A were moving an inmate from D-Dorm into a cell in A-
Dorm. Despite the availability of other housing, OFFICER A insisted on placing
inmate in a cell with Individual #2 and two other inmates, which would have caused
the cell to be unnecessarily crowded. When Individual #2 complained, OFFICER A
purposely antagonized Individual #2, by yelling at him and placing him against a
wall in the cell and striking him without cause. At the time, Individual #2 was
argumentative, but was posing no threat to either defendant JONES, OFFICER A,
or the other inmates.

In response to Individual #2's arguing, and to support OFFICER A's


antagonism toward Individual #2, defendant JONES struck Individual #2 in the face
three times with a can of O.C. spray that he carried with him. At the time, no force
was necessary to manage Individual #2 or any other inmate and striking Individual
#2 in the face three times with a metal can was unjustified. The lever or trigger on
the can broke with the force of the blows and O.C. spray was dispersed throughout
the cell irritating Individual #2, the other inmates, JONES, and OFFICER A, and
required de-contamination of all involved.

Thereafter, defendant JONES and OFFICER A wrote identical false reports


designed to cover up OFFICER A's unnecessary provocation and defendant
JONES' unnecessary use of force. The reports falsely indicated that Individual #2
advanced on OFFICER A in way that justified using force against him; that
Individual #2 attempted to strike OFFICER A such that force would have been

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justified to subdue Individual #2; and that defendant JONES blocked Individual
#2's intended attack on OFFICER A with his O.C. cannister, thereby damaging the
cannister, and causing the O.C. dispersal. Each of these allegations was untrue and
was written to hide the unjustified use of force against Individual #2.

The defendant hereby stipulates that the facts stated above are

substantially correct and that the Court can use these facts in calculating the

defendant's sentence. The defendant further acknowledges that these facts do

not constitute all the evidence of each and every act that the defendant and/or

any co-conspirators may have committed.

III. RECOMMENDED SENTENCE

Subject to the limitations in section VII regarding subsequent conduct and

pursuant to Fed. R. Crim. P. ll(c)(l)(B), the Government will recommend the

following disposition:

A. That the defendant be awarded a two (2) level reduction in the


defendant's adjusted offense level, based upon the defendant's apparent
prompt recognition and affirmative acceptance of personal
responsibility for the defendant's criminal conduct. The Government
agrees to make a motion pursuant to USSG §3E 1.1 (b) for an additional
one-level decrease in recognition of the defendant's prompt notification
to the Government of the intention to enter a plea of guilty. The
Government may oppose any adjustment for acceptance of
responsibility if the defendant: ( 1) fails to admit each and every item
in the factual stipulation; (2) denies involvement in the offense;
(3) gives conflicting statements about the defendant's involvement in
the offense; (4) is untruthful with the Court, the Government, or the

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United States Probation Officer; (5) obstructs or attempts to obstruct


justice prior to sentencing; (6) engages in any criminal conduct between
the date of this agreement and the date of sentencing; or (7) attempts to
withdraw the defendant's plea of guilty for any reason other than those
expressly enumerated in the "Waiver of Right to Appeal and Post-
Conviction Relief' section of this Plea Agreement;

B. That the defendant be remanded to the custody of the Bureau of Prisons


and incarcerated for a term consistent within the advisory United States
Sentencing Guideline range as calculated by the Court at the time of
sentencing;

C. That following said term of imprisonment, the defendant be placed on


supervised release for a period to be determined by the Court, subject
to the Court's standard conditions of supervised release;

D. That the defendant be required to pay a fine in accordance with the


sentencing guidelines should the Court determine that the defendant has
the ability to pay a fine, said amount due and owing as of the date
sentence is pronounced, with any outstanding balance to be paid in full
by the expiration of the term of supervised release; and,
E. That the defendant pay a special assessment of $200.00, said amount
due and owing as of the date sentence is pronounced.

IV. WAIVERS

A. STATUTE OF LIMITATIONS WAIVER

In consideration of the recommended disposition of this case, I, JOSHUA

CONNER JONES, hereby understand, acknowledge, and agree that if this plea

agreement is set aside for any reason, I will not assert any defense based on any

applicable statute of limitations or the Speedy Trial Act, 18 U.S.C. § 3161, et

seq., that includes the passage of time from and including the date of this plea

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agreement until and including the date of entry of any order setting this plea

agreement aside.

B. RIGHT TO APPEAL AND POST-CONVICTION RELIEF

In consideration of the recommended disposition of this case, I, JOSHUA

CONNER JONES, hereby waive and give up my right to appeal my conviction

and/or sentence in this case, as well as any fines, restitution, and forfeiture

orders, the Court might impose. Further, I waive and give up the right to

challenge my conviction and/or sentence, any fines, restitution, forfeiture

orders imposed or the manner in which my conviction and/or sentence, any

fines, restitution, and forfeiture orders were determined in any post-conviction

proceeding, including, but not limited to, a motion brought under 28 U.S.C. §

2255, and any argument that (1) the statute(s) to which I am pleading guilty is

or are unconstitutional or (2) the admitted conduct does not fall within the

scope of the statute(s).

The defendant reserves the right to contest in an appeal or post-

conviction proceeding(s) the following:

1. Any sentence imposed in excess of the applicable statutory


maximum sentence(s);

2. Any sentence imposed in excess of the Guidelines range


determined by the Court at the time sentence is imposed; and

3. Ineffective assistance of counsel.

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The defendant acknowledges that before giving up these rights, the

defendant discussed the United States Sentencing Guidelines and their

application to the defendant's case with the defendant's attorney, who

explained them to the defendant's satisfaction. The defendant further

acknowledges and understands that the Government retains its right to appeal

where authorized by statute.

C. WAIVER OF RULE 410, RULE 11, AND SECTION 1B1.8(a)

Defendant agrees that if he fails to comply with any of the provisions of

this agreement, including the failure to tender such agreement to the district

court, or attempts to withdraw the plea (prior to or after pleading guilty to the

charges identified in the agreement), the government will have the right to

characterize such conduct as a breach of the agreement. In the event of such a

breach, the defendant waives any protections afforded by Section 1B1.8(a) of

the Sentencing Guidelines, Rule 11 of the Federal Rules of Criminal Procedure,

and Rule 410 of the Federal Rules of Evidence, and the government will be free

to use against the defendant, directly and indirectly, in any criminal or civil

proceeding any of the information, statements, and materials provided by him

pursuant to this agreement, including offering into evidence or otherwise using

the attached Agreed Factual Basis for Guilty Plea.

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I, JOSHUA CONNER JONES, hereby place my signature on the line

directly below to signify that I fully understand the foregoing paragraphs, and

that I am knowingly and voluntarily entering into this wai 'er.

V. UNITED STATES SENTENCING GUIDELINES

The defendant's counsel has explained to the defendant, that in light of the

United States Supreme Court's decision in United States v. Booker, the federal

sentencing guidelines are advisory in nature. Sentencing is in the Court's discretion

and is not required to be within the guideline range. The defendant agrees that,

pursuant to this agreement, the Court may use facts it finds by a preponderance of

the evidence to reach an advisory guideline range, and the defendant explicitly

waives any right to have those facts found by a jury beyond a reasonable doubt.

VI. AGREEMENT NOT BINDING ON COURT

The defendant fully and completely understands and agrees that it is the

Court's duty to impose sentence upon the defendant and that any sentence

recommended by the Government is NOT BINDING UPON THE COURT, and

that the Court is not required to accept the Government's recommendation. Further,

the defendant understands that if the Court does not accept the Government's

recommendation, the defendant does not have the right to withdraw the guilty plea.

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VII. VOIDING OF AGREEMENT

The defendant understands that if the defendant (a) violates any federal, state,

or local law or any condition of pretrial release after entering into this plea.

agreement, (b) moves the Court to accept a plea of guilty in accordance with, or

pursuant to, the provisions of North Carolina v. Alford, 400 U.S. 25 (1970),

(c) tenders a plea of nolo contendere to the charges, (d) violates any other term of

this plea agreement, and/or (e) does or says anything that is inconsistent with the

acceptance of responsibility, the plea agreement will become NULL and VOID at

the election of the United States, and the United States will not be bound by any of

the terms, conditions, or recommendations, express or implied, which are contained

herein. Further, such election will not entitle the defendant to withdraw a previously

entered plea.

VIII. OTHER DISTRICTS AND JURISDICTIONS

The defendant understands and agrees that this agreement DOES NOT BIND

any other United States Attorney in any other district, or any other state or local

authority.

IX. COLLECTION OF FINANCIAL OBLIGATION

To facilitate the collection of financial obligations to be imposed m

connection with this prosecution, the defendant agrees to:

• fully disclose all assets in which the defendant has any interest or over which

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the defendant exercises control, directly or indirectly, including those held by

a spouse, nominee or other third party;

• promptly submit a completed financial statement to the United States

Attorney's Office, in a form that it provides and as it directs;

• identify all assets over which the defendant exercises or exercised control,

directly or indirectly, within the past five years, or in which the defendant has

or had during that time any financial interest;

• take all steps as requested by the Government to obtain from any other parties

by any lawful means any records of assets owned at any time by the defendant;

• undergo any polygraph examination the Government may choose to

administer concerning such assets and to provide and/or consent to the release

of the defendant's tax returns for the previous five years.

The defendant further agrees that the above information, as well as any of the

defendant's financial statements and disclosures, will be complete, accurate, and

truthful. Finally, the defendant expressly authorizes the United States Attorney's

Office to obtain a credit report on the defendant to evaluate the defendant's ability

to satisfy any financial obligation imposed by the Court.

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X. AGREEMENT REGARDING RELEVANT CONDUCT AND


RESTITUTION

As part of the defendant's plea agreement, the defendant admits to the above

facts associated with the charges and relevant conduct for any other acts. The

defendant understands and agrees that the relevant conduct contained in the factual

basis will be used by the Court to determine the defendant's range of punishment

under the advisory sentencing guidelines. The defendant admits that all the crimes

listed in the factual basis are part of the same acts, scheme, and course of conduct.

This agreement is not meant, however, to prohibit the United States Probation Office

or the Court from considering any other acts and factors, which may constitute or

relate to relevant conduct. Additionally, if this agreement contains any provisions

providing for the dismissal of any counts, the defendant agrees to pay any

appropriate restitution to each of the separate and proximate victims related to those

counts should there be any and waives objection to the inclusion of that restitution

in any order issued by the Court.

XI. TAX, FORFEITURE AND OTHER CIVIL/ADMINISTRATIVE


PROCEEDINGS

Unless otherwise specified herein, the defendant understands and

acknowledges that this agreement does not apply to or in any way limit any pending

or prospective proceedings related to the defendant's tax liabilities, if any, or to any

pending or prospective forfeiture or other civil or administrative proceedings.

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XII. IMMIGRATION STATIJS

The defendant recognizes that pleading guilty may have consequences with

respect to the defendant's immigration status if the defendant is not a citizen of the
I
United States. Under federal law, a broad range of crimes are removable offenses,

including the offense(s) to which the defendant is pleading guilty. The defendant's

guilty plea and conviction make it practically inevitable and a virtual certainty that

the defendant will be removed or deported from the United States if the defendant is

not a citizen of the United States. Removal and other immigration consequences are

the subject of a separate proceeding, however; and the defendant understands that

no one, including his attorney or the district court, can predict to a certainty the effect

of his conviction on his immigration status. Understanding all of this, the defendant

nevertheless affirms that the defendant wants to plead guilty regardless of any

immigration consequences that plea may entail, even if the consequence is automatic

removal from the United States.

XIIl. DEFENDANT'S ACKNOWLEDGEMENT

I have read and understand the provisions of this plea agreement consisting of

eighteen (18) pages. I have discussed the case and my constitutional and other rights

with my lawyer. I am satisfied with my lawyer's representation in this case. I

understand that by pleading guilty, I will be waiving and giving up my right to

continue to plead not guilty, to a trial by jury, to the assistance of counsel at that trial,

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to confront, cross-examme, or compel the attendance of witnesses, to present

evidence on my behalf, to maintain my privilege against self-incrimination, and to

the presumption of innocence. I agree to enter my plea as indicated above on the

terms and conditions set forth herein.

NO PROMISES OR REPRESENTATIONS OTHER THAN THOSE IN


THE AGREEMENT HAVE BEEN MADE TO ME BY THE
PROSECUTOR, OR BY ANYONE ELSE, NOR HAVE ANY THREATS
BEEN MADE OR FORCE USED TO INDUCE ME TO PLEAD
GUILTY.
I further state that I have not had any drugs, medication, or alcohol within the

past 48 hours except as stated here:

I understand that this plea agreement will take effect and will be binding as to

the Parties only after all necessary signatures have been affixed hereto.

I have personally and voluntarily placed my initials on every page of this plea

agreement and have signed the signature line below to indicate that I have read,

understand, and approve all the provisions of this plea agreement, both individually

and as a total binding agreement.

7/2-\/2\Jc -0
DATE JOSHUA CONNER JONES
Defendant

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XIV. COUNSEL'S ACKNOWLEDGMENT

I have discussed this case with my client in detail and have advised my client

of all my client's rights and all possible defenses. My client has conveyed to me that

my client understands this plea agreement and consents to all its terms. I believe the

plea and disposition set forth herein are appropriate under the facts of this case and

are in accord with my best judgment. I concur in the entry of the plea agreement on

the terms and conditions set forth herein.

-:JJ(-J~
DATE
Defendant's Counsel

XV. GOVERNMENT'S ACKNOWLEDGMENT

I have reviewed this matter and this plea agreement and concur that the plea

and disposition set forth herein are appropriate and are in the interests of justice.

PRIM F. ESCALONA
United States Attorney

7 IJ9 l~'-1
DATE MICHAEL A. ROYSTER
Assistant United States Attorney

A. ~RTIN, JR.
Assistant United States Attorney

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