Letter Response in Support of Motion — USA v. Ilori et al. (Dkt. 162, S.D.N.Y.)

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U.S. District Court for the Southern District of New York · No. 1:21-cr-00746-MKV · Doc. 162 · 2025-05-29 · Docket on CourtListener

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WRITER'S DIRECT DIAL NO. 
(212) 849-7140 
WRITER'S EMAIL ADDRESS 
marcgreenwald@quinnemanuel.com 
 
quinn emanuel urquhart & sullivan, llp 
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May 29, 2025 
Via ECF 
 
Honorable Mary Kay Vyskocil 
United States District Judge 
Southern District of New York 
500 Pearl Street 
New York, New York 10007 
 
Re:  United States v. Chris Recamier, 21 Cr. 746 (MKV) 
 
Dear Judge Vyskocil: 
 
Pursuant to this Court’s April 8, 2025 Order (ECF 157), Chris Recamier respectfully submits this 
reply in support of his motion for resentencing pursuant to Amendment 821 to the U.S. Sentencing 
Guidelines (ECF 160). 
On May 21, 2025, the government submitted its response to Mr. Recamier’s motion.  (ECF 161).  
There, the government stated that it “agrees with the Probation Office and [Mr. Recamier] that 
Amendment 821 reduced the Guidelines range applicable in this case.”  Id. at 1.  The government 
further noted that it “consents to resentencing within the new Guidelines range, which may include 
the imposition of the existing sentence or a reduced sentence.”  Id.   
Mr. Recamier respectfully submits that a sentence of 87 months’ imprisonment, at the bottom of the 
amended Guidelines range, is warranted.  This Court previously sentenced Mr. Recamier to the 
bottom of the original Guidelines range.  In crafting that sentence, in addition to accounting for the 
seriousness of the offense and need for deterrence, this Court considered Mr. Recamier’s life 
circumstances and his acceptance of responsibility.  ECF 104, Sentencing Tr. (“Tr.”) at 30–33.  This 
Court also considered the educational and work programs Mr. Recamier had taken advantage of 
during pretrial detention.  Id. at 31–32.   
Time has shown that this Court was correct to sentence Mr. Recamier at the bottom end of the 
Guideline’s range.  Mr. Recamier has taken control of his addiction and been clean since his 
incarceration.  Mr. Recamier has only further taken advantage of work and education programs.  See 
ECF 151, Supplemental Presentence Report (“Supplemental PSR”) at 4.   
The § 3553(a) factors that guided this Court to a sentence at the bottom of the original Guidelines 
range still counsel a sentence at the bottom of the amended Guidelines range.  Mr. Recamier’s life 
Case 1:21-cr-00746-MKV     Document 162     Filed 05/29/25     Page 1 of 2

 
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has been plagued by addition and he had a difficult upbringing.  See ECF 76, at 3–4 (citing 18 
U.S.C. § 3553(a)(1); Presentence Investigation Report, ECF 71 (“PSR”) ¶¶ 84–86; 99–103).  He is 
62 years old, with a number of health issues complicated by a lifetime of heroin addiction.  See id. at 
4–5 (citing PSR ¶¶ 97, 99–103).  Importantly, Mr. Recamier accepted responsibility for his actions, 
pleading guilty shortly after new counsel was appointed.  See id. at 5–6. 
For these reasons, Mr. Recamier respectfully requests that this Court resentence him to 87 months’ 
imprisonment, at the bottom of the amended Guidelines range. 
Respectfully submitted, 
 
/s/ Marc Greenwald  
 
 
Marc Greenwald 
Michael Linneman 
  
 
Case 1:21-cr-00746-MKV     Document 162     Filed 05/29/25     Page 2 of 2

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