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oN DOHA PB WD = Case 1:19-cr-00490-RMB Document14 Filed 07/15/19 Page 5 of 18 SORA HEARING , page 4 year old, he.was an adult obviously, he was a Marine, a 17 year old came up to him and one thing lead to another and he had sex with her and the People would not agree to a downward modification on that. - So I ama little overwhelmed here because I see -- I mean I read everything here, I am just a little overwhelmed that the People are making this application. “I could cite many many, I have done many SORAs much jess troubling than this one where the People would never make a downward argument like this. MS. GAFFNEY: I agree with Your Honor, it is incredibly unusual for us to make a downward argument. But the problem is the one thing that we have from the board is it seems. to be in contradiction to their own guidelines which if something was not indicted, you are not supposed to rely on it. , , 7 | THE COURT: They obviously took that into consideration. MS. GAFFNEY: And I tried to reach -- I reached ihe authorities in Florida to try to see if they had all the interview notes or other things that we can then subsequently rely on that might be considered clear and convincing evidence, if they had interviewed these women on their own, and they never did. No one was cooperative and they did not go forward on any of the cases and none of them Vikki J. Benkel | Senioi Court Reporter DOJ-OGR-00000370