Exhibit 1 — USA v. Lattany (Dkt. 68.1)

Summary

Exhibit 1 to Document 68-1, filed 03/14/24, is a PLEA AGREEMENT between the People of the State of Colorado and Dejane Reaniece Lattany. The defendant will enter a plea of GUILTY, and in exchange the People will dismiss COUNTS ONE, TWO, AND FOUR. The stipulated concession is a Two Years Colorado Department of Corrections Sentence and one year mandatory parole concurrent to the sentence in United States District Court, District of Colorado, Criminal case No. 23-CR-00074-NYW. The parties stipulate to Restitution of $372,150.47 to the Colorado Department of Health Care Policy and Financing, and the agreement lists defense counsel Jason Flores-Williams and prosecuting attorney Daniel T. Brechbuhl.

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PLEA AGREEMENT

Below is the complete and accurate agreement between the People of the State of Colorado, as
represented by the prosecutor, and the above-named Defendant, as represented by his attorney. All
concessions and stipulations are fully set forth herein.

1. The Defendant will enter a plea of GUILTY to the charge of:

{53651}

2. In exchange for the above guilty plea, The People will dismiss COUNTS ONE,
TWO, AND FOUR, after the Court accepts the above guilty plea and any agreement(s) of the
parties.

3. The People and the Defendant have agreed and stipulated to the following concession(s)

A. (all concessions are set forth herein): __ Two Years Colorado Department of
Corrections Sentence and one year mandatory parole concurrent to sentence in United
States District Court- District of Colorado, Criminal case No. 23-CR-00074-NYW.
This sentence would be served in the pn em The parties stipulate to
Restitution. of $372,150.47 to Colorado Department of Health Care Policy and
Financing, c/o Colorado Attorney General’s Office, Colorado Medicaid Fraud Control
Unit, Ralph L. Carr Colorado Judicial Center, 1300 N. Broadway, Ninth Floor, Denver,
CO 80203.

I swear or affirm that I have read and understand this entire document, and every representation I
have made is true.

LZ=—> Date: S. f ) 2?

Defendant: Dejane Reaniece Lattany

As defense counsel, I affirm that the above-named Defendant has executed the foregoing “The
Defendant’s Request to Plead Guilty (Crim. P. Rule 11 Guilty Plea Advisement).” As defense
counsel I have thoroughly reviewed this document with the Defendant in regard to the entry of

this guilty flea.

4—_ Date:_9 =) y 2S

‘ounsel: Jason Flores-Williams, Reg. No. 49702

/s/ Paniel T. Brechbuhl Date: __ 5/1/23
Prosecuting Attorney: Daniel T. Brechbuhl, Reg. No. 31047

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gov.uscourts.cod.223008.68.1.pdf

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17f9032099adcc89a28493bed52bbfe2d436429340dae8ca310bff2384eba742

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gov.uscourts.cod.223008.68.1.pdf

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