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Case 2:15-cr-00109-RAJ-RJK Document 42 Filed 10/15/15 Page 1 of 4 PageID# 99

FILED
IN OPEN COURT

OCT 1 5 2015
IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
NORFOLK DIVISION

CLERK, U.S. DISTRICT COURT


NORFOLK. VA

UNITED STATES OF AMERICA


v.

Criminal No. 2:15cr 109

BREANNA L. MCMANUS,
Defendant.
STATEMENT OF FACTS

Bysigning below, the parties and their respective counsel agree that if this case had gone

to trial, the government's evidence would have established the following facts beyond a
reasonable doubt:

1.

The USS GEORGE H. W. BUSH (CVN 77) (hereinafter, USS BUSH) is a United States

Naval warship owned by the United States of America. At the times pertinentto the events

below, the USS BUSH was located within the Eastern District of Virginia and, specifically, at
Naval Station Norfolk, Virginia.

2.

The defendant is at the time of this agreement, and was during the month of February

2015, married to Donald G. McManus. From on or about February 18,2015, and continuing to
on or about February 23,2015, the defendant entered into a conspiracy with herco-defendant
and husband, Donald G. McManus, to possess with intentto distribute and to distribute a

detectable amount of heroin to a female sailor on board the USS BUSH in exchange for U.S.
currency.

3.

At the time of the events described herein, the defendant's husband, Donald G.

McManus, was an active duty member of the United States Navy stationed on board the USS

BUSH. While in a restricted status, in February 2015, Donald G. McManus approached a

Case 2:15-cr-00109-RAJ-RJK Document 42 Filed 10/15/15 Page 2 of 4 PageID# 100

shipmate and offered to sell heroin to her. The shipmate accepted his offer, and then he called

the defendant, Breanna McManus, who brought heroin and syringes on board the USS
BUSH. Thedefendants led the female sailorto a secure space in the air wing on board the USS
BUSH where all three of them proceeded to inject heroin into their bodies. On a second

occasion during the conspiracy, the defendants led the female sailor to a secure space in the air

wing on board the USS BUSH and used heroin again. The female sailor paid approximately
$150 to the defendants in exchange for heroin.

4.

On February 23,2015, a few days after purchasing heroin from the defendants, the

female sailor went into a heroin overdose on board the USS BUSH. An uninvolved sailor

stationed on board the USS BUSH found the female sailor unresponsive on the floor close to her
sleeping quarters. The sailor called the USS BUSH's medical clinic and informed clinic

personnel of the situation. The ship's medical response team provided immediate care until
civilian Emergency Medical Technicians arrived on scene. The female sailor was without a
pulse for approximately 14 minutes until she was revived.

5.

The acts taken bythe defendant in furtherance of theoffense charged in this case,

including the acts described above, were done willfully and knowingly with the specific intent to
violate the law. The defendant acknowledges that the foregoing statement of facts does not

describe all ofthe defendant's conduct relating to the offenses charged in this case, nor does it

identify all ofthe persons with whom the defendant may have engaged in illegal activities. The

defendant further acknowledges that she is obligated under her plea agreement to provide
additional information about this case beyond that which is described in this statement of facts.

Case 2:15-cr-00109-RAJ-RJK Document 42 Filed 10/15/15 Page 3 of 4 PageID# 101

Respectfully submitted,
Dana J. Boente

United States Attorney

John F. Butler

Special Assistant United States Attorney


United States Attorney's Office
101 W. Main Street, Suite 8000

Norfolk, Virginia 23510


(757)441-6331

john.f.butler@usdoj.gov

Case 2:15-cr-00109-RAJ-RJK Document 42 Filed 10/15/15 Page 4 of 4 PageID# 102

After consulting with my attorney and pursuant to the plea agreement entered into this
day between the defendant, BREANNA L. MCMANUS, and the United States, I hereby
stipulate that the above Statement of Facts is true and accurate, and that had the matter proceeded
to trial, the United States would have proved the same beyond a reasonable doubt.

//Breanna L. Mc
Defendant

I am BREANNA MCMANUS' attorney. I have carefully reviewed the above Statement

of Facts with her. To my knowledge, her decision to stipulate to these facts is an informed and
voluntary one.

Eric Leckie, Esq.

5 n j_

Counsel for Defendant

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