Free Sentencing Memorandum - District Court of Connecticut - Connecticut

, Case 3:03-cr-00078-SRU Document 69 Filed 10/12/2005 Page 1 of 3
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UNITED STATES DISTRICT COURT i
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA :
vs. : CRIMINAL NO. 3:03CR78 (SRU)
KENNETH MOORE : October ll, 2005
— SUPPLEMENTAL MEMORANDUM IN AID OF SENTENCING
Defendant, through counsel, hereby supplements his previously-filed sentencing memorandum.
VVhile defense counsel previously outlined the pertinent sentencing issues, the defendant wishes to make
the court aware of his post-sentencing rehabilitative efforts as well as his current family responsibilities.
I. Post-Sentencing Rehabilitative Efforts. A
The defendant wishes to bring to the Court’s attention all efforts he has made to better himself
during his period of incarceration. Mr. Moore voluntarily surrendered to the custody of the United
States Brneau of Prisons on June 9, 2004. Since that time he has kept himself constantly busy, taking
advantage of every opportunity available to him to rehabilitate himself
Specifically, in the past fifteen months the defendant has completed six college courses through
Burlington County College. He has completed a course in vocational training for Frameshop and r
Woodshop. He has volunteered his time to repair bicycles which are subsequently provided to
underprivileged children. Mr. Moore is particularly hopeful that his experience with the criminal justice
system can be instructive to young people. To that end he has also been involved in a panel discussion A
with imnates and inner—city children to stress the importance of living a crime and drug-free lifestyle.
It is hoped that by sharing his experience, others will be deterred from engaging in a life of crime. He
has also faithfully attended NA and AA meetings to continue to address his substance abuse problems i
which were at the root of his past criminal behavior.
H. The Defendant’s Family Obligations.
The defendant previously briefed the issue of his family obligations and his desire for a
downward departure based on those obligations. Since his incarceration significant events have
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_ ` occurred to various members of Mr. Moore’s family which weigh strongly in favor of a downward (
_ ‘.ly 3 departure based on his family obligations and the needs of those dependent upon him.
I * Since Mr. Moore’s incarceration his grandmother has had to enter hospice care. She is currently
suffering from lung cancer. Mr. Moore’s mother has recently undergone serious heart surgery, while
A his brother has recently had emergency surgery for colon and prostate cancer. Mr. Moore respectfully
submits that he is needed by his family members to provide comfort, care and support during this
difficult time in which they are coping with life threatening health problems.
Mr. Moore would additionally request that the Court consider that Mr. Moore was, prior to his
incarceration, the primary earner for his family. Since his incarceration, his son has had to leave college I
* A because he lacked the funds to pay his tuition. Mr. Moore hopes to be able to return as soon as possible
_ to the workforce in order to earn the money necessary to fulfill his parental obligations, including
S.-; financing his son’s education.
‘i III. Conclusion.
i Mr. Moore respectfully requests that the Court also consider the factors set forth above when
determining if the Court would have imposed a non—trivially different sentence under an advisory
sentencing scheme. As the Court is aware, in addition to Guidelines considerations, the Court must
consider the factors set forth under 18 U.S.C. § 3553 in determining an appropriate sentence. The
defendant respectfully requests that the Court exercise its discretion and depart downward given the
Q L variety of mitigating circumstances outlined in the defendant’s sentencing memoranda.
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Case 3:03-cr-00078-SRU Document 69 Filed 10/12/2005 Page 3 of 3
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Respectfully submitted, 1
THE DEF ENDAN T, I
Kenneth Moore ,
THOMAS G. DENNIS
FEDERAL DEF ENDER
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Dated: October ll, 2005 .
. Deirdre A. Murray 27 '
~ Assistant Federal Defender
‘ ' 2 Whitney Ave., Suite 300
New Haven, CT 06510
Bar No. Ct2298l
(203) 498-4200
Email: [email protected]
CERTIFICATION
I HEREBY CERTIFY that a copy of the foregoing Supplemental Memorandum in Aid of
Sentencing has been mailed to Robert Spector, Assistant United States Attorney, Federal Building, 450
Main Street, Hartford, CT 06103, on this 7 day of October 2005.
, l l%1rdre A. Murray ' {
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