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wit, the forcible rescue of seized property. In the plea
agreement, petitioner agreed to the following:
6. The defendant is pleading guilty because she
is in fact guilty of the charge contained in Count One
of Indictment 96-CR-361. In pleading guilty to this
count, the defendant acknowledges that, if she elected
to go to trial, the United States would prove, beyond a
reasonable doubt, all of the facts set forth in
paragraph 7, and further acknowledges that those facts
would support her conviction on the charge contained in
Count One of Indictment 96-CR-361. The defendant also
specifically admits the following facts as true, and
declares these facts to be true under the penalties of
perjury to Title 18, United States Code, Section 1746:
7. Statement of Relevant Facts:
On or about June 27, 1995, in the Northern
District of New York, the defendant Renee V.
Trupin also known as Renee Daunay and Renee
Virginia Cornelius did unlawfully, knowingly and
forcibly rescue and cause to be rescue property
that had been seized by the Internal Revenue
Service. Specifically, the defendant entered
buildings and real property located at One Block
Lane, Claverack, New York, knowing that property
had been seized by the United States.
At all times, the defendant acted knowingly,
intentionally, willfully and not by mistake or
other innocent reason.
* * * * * * *
17. The defendant hereby agrees to pay
restitution to all persons and entities who suffered a
monetary loss as a result of the defendant’s
misconduct, whether or not embraced in the counts of
the defendant’s conviction, and whether or not the
defendant derived any direct financial benefit
therefrom. The defendant specifically agrees to
surrender, assign, and transfer those three paintings
removed from the premises at One Block Lane, Claverack,
New York to the Internal Revenue Service and
acknowledges that the sentencing Court may include an
order of restitution in an amount greater than that set
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