Free Motion for Acceptance of Responsibility - District Court of Connecticut - Connecticut

Case 3:03-cr-00198-RNC

Document 988

Filed 08/24/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. PABLO GARCIA : CRIM. NO: 3:03cr198(RNC) : : : : August 24, 2005

GOVERNMENT'S MOTION PURSUANT TO U.S.S.G. § 3E1.1(b) The United States of America respectfully requests that the Court accord defendant an additional 1-level adjustment for acceptance of responsibility pursuant to U.S.S.G. § 3E1.1(b). In support of this motion the United States states: 1. The defendant, Pablo Garcia, was charged by indictment with a

violation of 21 U.S.C. §§ 841(a)(1), 841(b)(1)(B) and 846 on July 16, 2003. 2. The defendant timely notified the United States of his intention to

plead guilty, and the change of plea proceeding occurred on April 18, 2005. 3. Pursuant to the plea agreement in this matter, the United States

has recommended that defendant receive a downward adjustment for acceptance of responsibility pursuant to § 3E1.1(a) because defendant has demonstrated an acceptance of responsibility for his offense.

ORAL ARGUMENT NOT REQUESTED

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Case 3:03-cr-00198-RNC

Document 988

Filed 08/24/2005

Page 2 of 3

4.

The defendant's adjusted offense level is 16 or greater and the

defendant has assisted authorities in the prosecution of his own misconduct by timely notifying authorities of his intention to enter a plea of guilty, thereby permitting the United States to avoid preparing for trial and permitting the United States and the Court to allocate their resources efficiently.

Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

Robert M. Spector ASSISTANT UNITED STATES ATTORNEY Federal Bar No. ct18082 157 Church Street, 23rd Floor New Haven, CT 06510 tel. 203.821.3700

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Case 3:03-cr-00198-RNC

Document 988

Filed 08/24/2005

Page 3 of 3

CERTIFICATE OF SERVICE This is to certify that on August 24, 2005, the foregoing motion was sent via facsimile to Attorney Herman Woodard, Jr. 750 Main Street, Suite 202 Hartford, CT 06103 United States Probation Officer Christopher Rogers United States Probation Office 157 Church Street 22nd Floor New Haven, CT 06510

ROBERT M. SPECTOR ASSISTANT UNITED STATES ATTORNEY

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