Free Motion to Reduce Sentence re Crack Cocaine Offense - 18:3582 - District Court of Connecticut - Connecticut

Case 3:03-cr-00105-RNC

Document 102 104

Filed 03/27/2008

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA vs. HARVEY RAMSEY : : : CRIMINAL NO. 3:03CR105(RNC) March 27, 2008

MOTION TO REDUCE SENTENCE RE: CRACK COCAINE OFFENSE The defendant, Harvey Ramsey, represents as follows: (1) On June 20, 2003 he entered a plea of guilty to Count One of an Indictment charging him

with possession with intent to distribute 5 grams or more of cocaine base (crack). (2) On October 2, 2003 the Court imposed a prison sentence of 108 months, the low end of

an applicable guideline range of 108 to 135 months. (3) Mr. Ramsey is eligible for a reduction of the term of imprisonment imposed on Count

One pursuant to 18 U.S.C. § 3582(c)(2) and the retroactive application of the new guidelines relating to crack cocaine offenses. See U.S.S.G. § 1B1.10. (4) Pursuant to said amended guidelines, Mr. Ramsey's offense level should be reduced

from 29 to 27. At criminal history category III, his revised guideline range is 87 to 108 months. (5) Mr. Ramsey submits that he should be sentenced at the low end of this range, just as he

was sentenced at the low end of the original range. Wherefore, the defendant, Harvey Ramsey requests the Court to enter an amended judgment imposing a sentence of 87 months, with all other terms and conditions of the original judgment remaining the same. Respectfully submitted, THE DEFENDANT, HARVEY RAMSEY THOMAS G. DENNIS FEDERAL DEFENDER

Case 3:03-cr-00105-RNC

Document 102 104

Filed 03/27/2008

Page 2 of 2

-2Dated: March 27, 2008 /s/ Thomas G. Dennis Federal Defender 10 Columbus Blvd, 6th FL Hartford, CT 06106 Phone: (860) 493-6260 Bar No.: ct05100 Email: [email protected] CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March 27, 2008, a copy of the foregoing Motion To Reduce Sentence Re: Crack Cocaine Offense was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System.

/s/ Thomas G. Dennis