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Case 1:20-cr-00330-PAE Document 300
L4TPDAYS
As the Court is aware,
felony conviction for narcotics of
fFense,
probation office that a guidelines sentenc
appropriate in this cas
TH
ina
Mr. Donaldson,
report?
MR. DONALDSON:
THE COURT:
MR. DONALDSON:
THE COURT:
e.
COURT: Thank you very much.
Filed 06/15/21
Page 10 of 32 6
this is the defendant's
would be
£ OUTER
and we agree with the
have you reviewed the presentenc
wi
Yes,
I have,
Several times,
your
Have you gone over it wi
your Honor.
th Ms. Days
Honor.
ll hear you on sentencing, sir.
MR. DONALDSON:
As the Court is aware,
Thank you very much, your Honor
the Court read the PSR,
all did, and the guideline range that came back from the
?
as we
PSR
was 63 to 78 months, similar to what we agreed to in our plea
agreement. The probation department recommended 63 months of
incarceration.
We are recommending -- requesting that the Court
sentence Ms. Day to 60 months,
approximately three months below
what the probation department is recommending and which would
be the statutory minimu
m.
Court a background of Ms.
why we believe 60 months is appropriate,
In our writing to the Court,
Days and,
we hope,
or rather than a guidelines sentenc
SOUTHERN
D
STR
CT RE
PORT
ERS,
(212)
805-0300
2)
some indication o1%
we tried to provide the
rather than 63 months
DOJ-OGR-00004753