Harlan Mount your Honor, if we may.
The defense counsel believes that there might've been a mistake with the billing process due to the complexity of the signed plea deal.
In section "VII. Additional Forfeiture and Release" we can read the following:
The Defendant relinquishes any and all claims to $207,443 USD seized during the searches of Forum Drive properties.
The Defendant relinquishes any and all claims to real properties:
7 Forum Drive
9 Forum Drive
11 Forum Drive
The forfeited funds shall be treated as proceeds of unlawful activity and applied to satisfy penalties and restitution obligations.
This means that my client owes exactly $142,557 to the State as her financial punishment, since as per the deal writing, $207,443 of the forfeited funds are to be used to satisfy the penalties of the crime — the fine of $350,000.
We understand that the State might've not intended that to be the case, but reality of the situation is they decided to copy and paste a critical and crucial piece of legal writing from a plea deal prepared specifically for miss Owens by (at the time) ADA Aiden Kerr, and should section "The forfeited funds shall be treated as proceeds of unlawful activity and applied to satisfy penalties and restitution obligations." be removed by them, the defendant would be obligated to cover the entire $350,000 amount, yet that's not the document they presented and signed.
We politely ask for this fact to be reflected in the amount charged from Miss Owens' personal account, and urge the State to further review any future plea deals they'd be proposing, especially when it involves copying and pasting random parts from one document to another.
respectfully submitted,
Annabelle Celestine, representing Rory Owens
