Motion for Decrease for Acceptance of Responsibility — USA v. Lattany (Dkt. 20, D. Colo.)

Summary

Document 20, a three-page United States' Motion to Decrease Offense Level by One Additional Level under U.S.S.G. 3E1.1(b), filed 08/01/23 in the District of Colorado, Criminal Case No. 23-cr-00074-NYW, United States v. Dejane Reaniece Lattany. The government says she has clearly demonstrated acceptance of responsibility and is entitled to a two-level decrease under 3E1.1(a), as the Probation Office also concluded in the Presentence Investigation Report (ECF No. 15 paragraph 52). It adds that she timely notified authorities of her intention to plead guilty, letting the government avoid preparing for trial. The motion is signed by AUSA Nicole C. Cassidy, with Rebecca S. Weber listed, and a certificate of service signed by legal assistant Stephanie Price.

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IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLORADO 
 
Criminal Case No.  23-cr-00074-NYW 
 
UNITED STATES OF AMERICA, 
 
 
Plaintiff, 
v. 
 
1. 
DEJANE REANIECE LATTANY, 
 
 
Defendant. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
UNITED STATES’ MOTION TO DECREASE OFFENSE LEVEL BY ONE 
ADDITIONAL LEVEL PURSUANT TO U.S.S.G § 3E1.1(b) 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The United States of America respectfully moves the Court to decrease the 
offense level by one additional level pursuant to United States Sentencing Guidelines 
§3E1.1(b).  As grounds therefore, the government states: 
(1) The defendant has clearly demonstrated acceptance of responsibility for her 
offense and is entitled to a decrease in the offense level by two levels pursuant to 
U.S.S.G. §3E1.1(a).  The U.S. Probation Office has reached this same conclusion in the 
Presentence Investigation Report.  (ECF No. 15 ¶ 52.) 
 
/ /  
 
 
/ /  
 
 
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Case No. 1:23-cr-00074-NYW     Document 20     filed 08/01/23     USDC Colorado     pg 1
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(2) The defendant has assisted authorities in the investigation or prosecution of 
her own misconduct by timely notifying authorities of her intention to enter a plea of 
guilty, thereby permitting the government to avoid preparing for trial and permitting the 
government and the Court to allocate their resources efficiently. 
 
Respectfully submitted this 1st day of August, 2023. 
 
COLE FINEGAN 
United States Attorney  
 
By: s/ Nicole C. Cassidy 
 
 
 
Nicole C. Cassidy 
 
 
 
 
Rebecca S. Weber  
Assistant U.S. Attorney 
 
 
 
 
 
 
 
United States Attorney’s Office 
 
 
 
 
 
 
 
1801 California Street, Suite 1600 
 
 
 
 
 
 
 
Denver, Colorado 80202 
 
 
 
 
 
 
 
(303) 454-0100 
 
 
 
 
 
 
 
(303) 454-0409 (fax) 
Nicole.Cassidy@usdoj.gov 
 
Rebecca.Weber@usdoj.gov 
Attorneys for Government 
 
 
 
Case No. 1:23-cr-00074-NYW     Document 20     filed 08/01/23     USDC Colorado     pg 2
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CERTIFICATE OF SERVICE 
 
I hereby certify that on August 1, 2023, I electronically filed the foregoing UNITED 
STATES’ MOTION TO DECREASE OFFENSE LEVEL BY ONE ADDITIONAL LEVEL 
PURSUANT TO U.S.S.G § 3E1.1(b) with the Clerk of the Court using the CM/ECF 
system which will send notification of such filing to all counsel of record in this case.  
 
 
s/ Stephanie Price 
Stephanie Price 
Legal Assistant  
United States Attorney’s Office 
 
Case No. 1:23-cr-00074-NYW     Document 20     filed 08/01/23     USDC Colorado     pg 3
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