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Blakely and Booker/Fanfan: Fourth Circuit Briefs
- Sentencing Memo (arguing for sentence below advisory sentencing guideline range in part because of lack of Fast Track procedure in district in illegal re-entry cases) Date:
June 2005
- Downward departure motion based on crack/powder
cocaine 100/1 ratio, relying on Nov. 2004 Sentencing Commission analysis of 15 years of
Guideline sentencing and opinions post-Booker that discuss this issue.
Date: March 29, 2005
- Petition for Rehearing, 4th Cir. 4/11/05 (requesting
reconsideration of legality of alternate sentence imposed by court along with guideline sentence pre-Booker)
- Post-Booker sentencing memorandum on the crack/powder cocaine
disparity.
- Brief 4th Cir. 2/14/05 (sentence pursuant to
mandatory Guidelines should be vacated despite waiver of appeal)
- Post-Booker
sentencing memorandum requesting statutory sentence lower than advisory
guideline range based on 3553(a) factors.
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