DEFENDANT’S
MEMORANDUM TO THE COURT IN AID OF SENTENCING
Defendant,
Michael Jones, hereby submits this motion and supporting
materials for the court’s review prior to his sentencing
in the instant case.
1.
Mr. Jones has worked steadily over the past two years
as a retail clerk at
Donovan’s Department Store in Oceana. He was
laid off shortly before his arrest on September 4, 2003.
2.
As the letters attached at Appendix A and B demonstrate,
Mr. Jones was a reliable employee of Donovan’s Dept.
Store during his tenure there. The letter from his supervisor
(Appendix A) states that Mr. Jones did an excellent job
while working at the store.
3.
With respect to the Presentence Report filed by U.S. Probation
Officer Mumford, defendant respectfully maintains that
defendant was only a minor participant in the instant
offense, and that consequently his offense level should
be adjusted downward by two points under Guideline 3B1.2,
Mitigating Role. The Commentary to Guideline 3B1.2 clearly
states that "a minor participant means any participant
who is less
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