Court filing
Motion for Downward Variance (Zero-Point Offender) — United States v. Arashio Harris (S.D. Fla.)
Filed October 23, 2023 in U.S. v. Arashio Harris; one of 11 filings from this case.
Record facts
| Court | U.S. District Court, Southern District of Florida |
|---|---|
| Filed | 2023-10-23 |
U.S. District Court, Southern District of Florida · No. 1:23-cr-20295-CMA · Doc. 21 · 2023-10-23 · Docket on CourtListener
Full text
LAW OFFICES OF MARK EIGLARSH
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
DOCKET NO. 23-20295-Cr-ALTONAGA/DAMIAN
UNITED STATES OF AMERICA
)
)
vs.
)
)
)
ARASHIO HARRIS
)
)
Defendant.
)
)
DEFENDANT’S MOTION FOR DOWNWARD VARIANCE FOR
ZERO-POINT OFFENDER
By and through his counsel of record, Arashio Harris (“Arashio”) respectfully
submits the following Motion for Downward Variance for Zero-Point Offender,
pursuant to U.S.C.G §4C1.1.
1. The Defendant requests a downward variance of two levels from the jointly
recommended final offense level based solely on the proposed Guideline
amendment “Part C – Adjustment for Certain Zero-Point Offenders”
(U.S.C.G. §4C1.1)
2. The Defendant qualifies for such an adjustment and meets the criteria set
forth under the proposed amendment.
3. If the Court grants the variance, the defendant expressly agrees that he will
not seek a further sentence reduction under this provision once the proposed
amendment is enacted.
Case 1:23-cr-20295-CMA Document 21 Entered on FLSD Docket 10/23/2023 Page 1 of 2
LAW OFFICES OF MARK EIGLARSH
4. If the Court grants the motion for a two-level downward variance, the jointly
recommended final offense level of 16 and advisory Guideline range of 21
to 27 months will be reduced to an advisory Guideline range of 15 to 21
months.
5. AUSA Edward Stamm has indicated that the Government does not oppose
Defendant’s request for the requested variance.
WHEREFORE, based upon the above and foregoing the Defendant
respectfully requests this Court to grant the instant motion.
I HEREBY CERTIFY that a true and correct copy of the foregoing was
electronically filed this 23rd day of October, 2023.
Respectfully submitted,
LAW OFFICES OF MARK EIGLARSH
3107 Stirling Road
Suite 207
Fort Lauderdale, Florida 33312
Telephone: (954) 500-0003
Facsimile: (305) 674-0102
Email: Mark@EiglarshLaw.com
BY: _/S/_MARK EIGLARSH______________
MARK EIGLARSH
Florida Bar No.: 956414
Case 1:23-cr-20295-CMA Document 21 Entered on FLSD Docket 10/23/2023 Page 2 of 2File and source
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