Motion to Reduce Sentence Third Point Acceptance Reduction by USA as to Chandler Simbeck — USA v. Foreman (Dkt. 120, D. Colo.)

Summary

The government's motion for a third point reduction under U.S.S.G. § 3E1.1(b) as to defendant Chandler Simbeck in United States of America v. Chandler Simbeck, Case No. 1:21-cr-00165-WJM, in the U.S. District Court for the District of Colorado, filed December 14, 2023, as Document 120. The United States asks the Court to decrease the defendant's offense level by 1 level. It states that the offense level before application of U.S.S.G. § 3E1.1(a) is greater than 16 and that the defendant timely notified authorities of the intention to plead guilty, permitting the government to avoid preparing for trial. It is signed by Assistant United States Attorney Robert Brown.

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IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLORADO 
 
Criminal Case No. 1:21cr-00165-RM 
 
UNITED STATES OF AMERICA, 
 
Plaintiff, 
 
 
 
 
 
 
  
v. 
 
2. 
CHANDLER SIMBECK, 
 
Defendant. 
  
 
GOVERNMENT=S MOTION FOR THIRD POINT REDUCTION PURSUANT TO 
U.S.S.G. § 3E1.1(b) 
  
 
The United States of America, by and through undersigned counsel, moves the Court to 
decrease the defendant’s offense level by 1 level pursuant to U.S.S.G. § 3E1.1(b) because 1) the 
offense level determined prior to application of U.S.S.G. § 3E1.1(a) is greater than 16, and 2) the 
defendant has assisted authorities in the investigation and prosecution of his own misconduct by 
timely notifying authorities of his intention to plead guilty thereby permitting the government to 
avoid preparing for trial and permitting the government and Court to allocate their resources 
efficiently.  See U.S.S.G. § 3E1.1(b).   
 
 
 
 
 
 
 
Case No. 1:21-cr-00165-WJM     Document 120     filed 12/14/23     USDC Colorado     pg 1
of 3

 
 
 
 
 
 
 
COLE FINEGAN 
United States Attorney 
 
 
 
 
 
By: 
s/ Robert Brown                 
ROBERT BROWN 
Assistant United States Attorney 
1801 California St., Suite 1600 
Denver, Colorado 80202 
E-mail: Robert.Brown5@usdoj.gov 
Attorney for the United States 
 
 
Case No. 1:21-cr-00165-WJM     Document 120     filed 12/14/23     USDC Colorado     pg 2
of 3

 
 
CERTIFICATE OF SERVICE 
 
 
I hereby certify that on this 14th day of December, 2023, I electronically filed the foregoing 
GOVERNMENT=S MOTION FOR THIRD POINT REDUCTION PURSUANT TO 
U.S.S.G. § 3E1.1(b) with the Clerk of Court using the CM/ECF system which will send 
notification of such filing to all counsel of record in this case. 
 
 
 
 
 
 
 
 
 
s/ Robert Brown___ 
 
 
 
 
 
 
 
U.S. Attorney’s Office 
 
Case No. 1:21-cr-00165-WJM     Document 120     filed 12/14/23     USDC Colorado     pg 3
of 3

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