Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 3:01-cr-00179-SRU

Document 226

Filed 07/26/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. TAKIYAH CATO : : : : :

CRIMINAL N0. 3:01CR179 (SRU) JULY 26, 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 one-level adjustment for acceptance of responsibility pursuant to Section 3E1.1(b) of the Sentencing Guidelines. In support of this motion the United States states: 1. On April 20, 2002, Takiyah Cato pleaded guilty to count ten of the superseding information charging her with possession of cocaine base in violation of Title 21, United States Code, Sections 844(a). At the time of that plea, the defendant executed a plea agreement. Sentencing is scheduled for July 26, 2005, at 10:00 a.m. 2. 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 Section 3E1.1(a) because defendant has demonstrated an acceptance of responsibility for his offense. 3. 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.

Case 3:01-cr-00179-SRU

Document 226

Filed 07/26/2005

Page 2 of 3

4.

Accordingly, pursuant to U.S.S.G. § 3E1.1(b), the Government respectfully

requests that the Court reduce defendant's offense level by one additional level. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

/s/ ANTHONY E. KAPLAN ASSISTANT UNITED STATES ATTORNEY 157 CHURCH STREET NEW HAVEN, CT 06510 Tel. (203) 821-3700 Federal Bar No. ct08083

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Case 3:01-cr-00179-SRU

Document 226

Filed 07/26/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was hand-delivered on this 25th day July, 2005, to: Michael L. Moscowitz, Esq. 7 Elm Street New Haven, Ct. 06510 Joseph P. Montesi U.S. Probation Officer U.S. Probation Office 157 Church Street New Haven, CT 06510 /s/_________________________ ANTHONY E. KAPLAN ASSISTANT UNITED STATES ATTORNEY

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