Exhibit USPO Memorandum — USA v. Stanley et al. (Dkt. 89-1, N.D. Fla.)

Summary

Exhibit, Document 89-1, filed 01/17/24 in United States v. Felicia Jackson Stanley, No. 4:22CR32 (N.D. Fla.): a January 9, 2024 U.S. Probation memorandum by Senior Probation Officer April J. McCommon on a possible sentence reduction under Amendment 821. It recalls her May 2, 2023 sentence of 24 months for conspiracy to commit wire fraud, conspiracy to commit money laundering and false statements, plus restitution of $2,802,690.76. The court had varied below a 37 to 46 month range, citing no criminal history. Probation concludes her 24 months is already below the amended 30 to 37 month range, so no further reduction is permitted.

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STEPHEN R. PRIDGEN 
CHIEF U.S. PROBATION OFFICER 
100 N. PALAFOX STREET 
SUITE 305 
PENSACOLA, FL 32502 
(850) 470-3070 
FAX (850) 470-3073 
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF FLORIDA 
PROBATION OFFICE 
 
TIFFANY N. DUGGER 
DEPUTY CHIEF 
U.S. PROBATION OFFICER 
100 N. PALAFOX STREET 
SUITE 305 
PENSACOLA, FL 32502 
(850) 470-3070 
FAX (850) 470-3073
 
January 9, 2024 
 
Jason R. Coody 
United States Attorney 
 
Joseph F. DeBelder 
Federal Public Defender 
Re: Felicia Jackson Stanley, DKT#4:22CR32-001 
      Amendment 821 Sentence Reduction  
 
 
The above-referenced case has been referred to the Court for a reduction in sentence pursuant to 
18 U.S.C. § 3582(c)(2) and §1B1.10 of the United States Sentencing Guidelines based on 
Amendment 821. On August 31, 2023, the United States Sentencing Commission voted to add 
Parts A and B, subpart 1 of Amendment 821 to the list of amendments in §1B1.10 that may be 
applied retroactively. An order reducing the defendant’s term of imprisonment must have an 
effective date of February 1, 2024, or later.  
 
Part A, herein referred to as “status points,” reappropriated §4A1.1(d) to §4A1.1(e) and amended 
the previous two-point upward adjustment, providing that one point is added if the defendant (1) 
receives seven or more points under §4A1.1(a) through (d), and (2) committed any part of the 
instant offense (i.e., any relevant conduct) while under any criminal justice sentence.  
 
Part B, subpart 1, established a new guideline at §4C1.1, herein referred to as “zero-point 
offender,” that provides for a two-level reduction to the offense level determined under Chapters 
Two and Three for offenders who did not receive criminal history points from Chapter Four, Part 
A and who meet nine additional criteria.  
 
According to the Bureau of Prisons, the defendant’s current anticipated release date is December 
17, 2024.   
 
Original Sentence: 
 
Following an entry of a guilty plea, on May 2, 2023, the defendant was sentenced to 24 months 
imprisonment for Count 1: Conspiracy to Commit Wire Fraud; Count 2: Conspiracy to Commit 
Money Laundering; and Count 3: Knowingly and Willfully Making Materially False Statements, 
all counts to be served concurrently. The Court also imposed a supervised release term of 3 years, 
restitution in the amount of $2,802,690.76, and a $300 special monetary assessment. No 
substantial assistance motions were filed in this matter. According to the Statement of Reasons, 
Eligibility 
☐ Part A (Status Points)  ☐ Part B (Zero Point Offender)  ☒ Not eligible for Part A or Part B 
Case 4:22-cr-00032-MW-MAF     Document 89-1     Filed 01/17/24     Page 1 of 2

Felicia Jackson Stanley - Docket No. 4:22CR32-001 
Amendment 821 Sentence Reduction  
 
the Court varied downward from the advisory guideline imprisonment range of 37 months to 46 
months, and among the factors it considered, the Court explicitly cited “absolutely no criminal 
history.” 
 
Sentencing Reduction Analysis: 
 
Based on the above-noted information and in consideration of Amendment 821, Part B (“zero-
point offender”), the custodial sentence imposed by the Court of 24 months is less than the 
minimum of the amended guideline imprisonment range of 30 to 37 months as determined 
pursuant to Amendment 821. As such, no further reduction is permitted pursuant to USSG 
§1B1.10(b)(2)(A). Further, it appears that the Court previously imposed a sentence that accounted 
for her status as a zero-point offender. 
 
On January 3, 2024, the Court appointed the Federal Public Defender’s Office to assist the 
defendant in determining whether she is entitled to any relief under the 2023 Amendments to the 
Sentencing Guidelines.  
 
Should you have any questions, please do not hesitate to contact me at (850) 521-3564. 
 
 
Sincerely,  
 
s/ April J. McCommon 
 
April J. McCommon 
Senior United States Probation Officer 
 
 
 
 
 
 
 
 
 
 
Case 4:22-cr-00032-MW-MAF     Document 89-1     Filed 01/17/24     Page 2 of 2

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