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Case 1:20-cr-00330-PAE Document 300 Filed 06/15/21 Page 11 of 32 7 L4TPDAYS 1 First and foremost, we believe, I think, this case 2 pretty much revolves around deterrence and whether Ms. Days 3 will be a productive member of society when she returns or when 4 she gets released. I think that's probably the central issue 5 for the sentencing proceeding. 6 We do agr there's no way we can disagree -- that 7 Ms. Days does have several prior convictions. That's a given, 8 and we agree that Ms. Days has been convicted of a felony 9 narcotics, that's a given as well. I guess, it's my opinion in 10 doing these sentencing proceedings so many times, I think the 11 focus of this particular case, if we isolate it, would be 12 whether or not -- or what would be deterrence to Ms. Days and 13 what we believe would be sufficient to ensure that when she 14 comes back out, that she's productive. The minimum of that, 15 not the maximum. What the least we can do to make sure she's 16 deterred. 17 In our opinion, we believe the 60 months is 18 appropriate for a number of reasons. One, we believe that, 19 like most defendants when they get arrested in Federal Court, 20 we believe that rehabilitation starts at the time that they are 21 arrested and, generally, if they're detained, at the time when 22 they are detained. 23 In this particular situation, we think that Ms. Days' 24 rehabilitation and her deterrence started at that time, while 25 in MCC and MDC. Start with MCC. Ms. Days made sure that she SOUTHERN DISTR CT REPORTERS, (212) 805-0300 PG ew DOJ-OGR-00004754