U.S. Department of JusticeRonald C. Machen Jr.United States Attorney District of ColumbiaJudmary Center555 Fourth St, N.W.Washington, D.C. 20530February 25, 2014VIA EMAILMs. Judy PipePublic Defender?s Service 633 Indiana Avenue N.W.Washington, D.C. 20004jpipe@pds.orgRe: United States v. Sosefina Amoa, 20l3CF10l8397Dear Ms. Pipe:This letter is to con?rm the plea offer for your client, Sosefina Amoa. This plea offerwill remain open until February 28, 2013. However, the Government reserves the right to revokethis plea offer at any time before your client enters a guilty plea in this case. If your clientaccepts the terms and conditions set forth below, please have your client execute this documentin the space provided below. Upon receipt of the executed document, this letter will become theplea agreement between your client and the Office of the United States Attorney for the Districtof Columbia. The terms of the offer are as follows:1. Your client, Sose?na Amoa, agrees to admit guilt and enter a plea of guilty of theSuperior Court Rules of Criminal Procedure to the following offense: one count ofVoluntary Manslaughter in violation of 22 D.C. Code Section 2105. Your clientunderstands that the offense of Voluntary Manslaughter carries a potentialmaximum penalty of (30 years) imprisonment, court costs, and payment to theVictims of Crime Fund, and a possible ?ve years of supervised release. Yourclient is also subject to deportation.2. Your client understands that the Government agrees not to file enhancementpapers (which are applicable in this case).1mm 3.The government reserves stepback. The defense agrees that they will notoppose the Government?s request that the defendant remain held without bondpending sentencing.The government agrees to limit its allocution at sentencing to a SentencingGuideline range of four to ten years. The government agrees that the defendantmay ask for a departure from the Applicable Guideline Range pursuant to theDistrict of Columbia Voluntary Sentencing Guidelines Manual (2012)Mitigating Factor as described in Rule 5.2.3 The defendant ?s capacity toappreciate the wrongfulness of her conduct or to conform her conduct to therequirements of law was impaired significantly, though not sufficiently to constitutea complete defense.However, notwithstanding the above, the defendant understands that the Court maysentence the defendant in accordance with the District of Columbia Sentencing andCriminal Code Revision Commission, Voluntary Sentencing Guidelines Manual andmay be sentenced anywhere within the guideline range including any departureswhich might be requested.Your client understands that the Government agrees not to prosecute your clientfor First Degree Murder Felony Murder-with Aggravating Circumstances, and FirstDegree Cruelty to Children in the pending case.The parties further agree that on the date of the plea, your client, after taking anoath to tell the truth, the government?s evidence, as reflected in the attached Proffer ofFacts, would be suf?cient to prove beyond a reasonable doubt that he committed theoffense of Voluntary Manslaughter.In entering this plea of guilty, your client understands and agrees to waive certainrights afforded to your client by the Constitution of the United States and/or bystatute. In particular, your client knowingly and voluntarily waives or gives up hisright against self-incrimination with respect to the offense to which your client ispleading guilty before the Court which accepts your client?s plea. Your client alsounderstands that by pleading guilty your client is waiving or giving up your client?sright to be tried by a jury or by a judge sitting without a jury, the right to be assistedIn this case, the defendant may argue, among other things, that she had just arrived from a foreign country(Samoa), and was only in the United States for six days, was residing in a Convent seeking to become a nun, hadno family or long term friends with whom to confide, delivered a baby which she may or may not have known shewas pregnant (parties dispute this point), that when the defendant delivered the baby, she squatted and leanedforward during the delivery which caused major tearing of her uterine, perineal and vaginal lacerations including asplit through the clitoral hood toward the mons, laceration on the le? and right inner labia. Consequently, thedefendant suffered a great deal of blood loss and pain prior to suffocating her child.2by an attorney at trial and the right to confront and cross-examine witnesses. Thedefendant also agrees to waive any DNA testing.8. This letter sets forth the entire understanding between the parties and constitutesthe complete plea agreement between your client and the United States Attomey?sOffice for the District of Columbia. This agreement supersedes all priorunderstandings, promises, agreements, or conditions, if any, between this Of?ce andyour client.Dated: February 25, 2014Respectfully submitted,RONALD C. MACHEN, JR.United States Attorneydam cyijti?a G. Wright 0D.C. Bar No. 431799Assistant United States AttorneyHomicide SectionJudiciary Center Building555 Fourth Street, N.W., Rm. 9834Washington, D.C. 20530202.252.7217g. Counsel for the United States of AmericaDEF ACCEPTANCEI have read this plea agreement and factual proffer and have discussed it with myattorney, Judy Pipe. I fully understand this agreement and agree to it without reservation. I dothis voluntarily and of my own free will, intending to be legally bound. No threats have beenmade to me nor am I under the in?uence of anything that could impede my ability to understandthis agreement fully. I am pleading guilty because I am in fact guilty of the offense set forthherein.I reaffirm that absolutely no promises, agreements, understandings, or conditions havebeen made or entered into in connection with my decision to plead guilty except those set forthin this plea agreement. I am satis?ed with the legal services provided by my attorneys inconnection with this plea agreement and matters related to it.Date: 091?2ghtl? A0 Sose?na AmoaDEFENDANTACKNOWLEDGMENTI have read each of the pages constituting this plea agreement, reviewed them with myclient, Sose?na Amoa, and discussed the provisions of the agreement with him fully. Thesepages accurately and completely set forth the entire plea agreement.Date: ff