Government Opposition to Sentence Reduction — U.S. v. Blotnick

Record facts

U.S. District Court, District of New Jersey · No. 2:21-cr-00796-BRM · Doc. 29 · 2025-03-13 · Docket on CourtListener

Full text

U.S. Department of Justice 
 
 
United States Attorney 
 
District of New Jersey 
 
 
 ___________________________________________________________________________________________________________________________ 
 
 
970 Broad Street, 7th floor 
973-645-2700 
 
Newark, New Jersey 07102 
 
March 13, 2025 
 
VIA ECF 
The Honorable Brian R. Martinotti 
United States District Judge    
Frank Lautenberg Post Office & U.S. Courthouse 
2 Federal Square 
Newark, NJ 07102 
 
Re: 
United States v. Gregory Blotnick,  
Crim. No. 21-796-BRM 
 
Dear Judge Martinotti: 
 
 Please accept this letter opposing Defendant Gregory Blotnick’s motion for a 
reduction in sentence pursuant to 18 U.S.C. § 3582(c)(2) on the basis of Amendment 
821 to the United States Federal Sentencing Guidelines (D.E. 28) (the “Motion”).  
The Motion should be denied because Defendant is ineligible for any relief under 
that Amendment. 
 
First, Amendment 821, Part A, which addresses status points, does not apply 
to Defendant because he did not receive any status points at sentencing.  
Specifically, Defendant received one criminal history point derived from a prior 
criminal sentence.  PSR ¶¶ 61-62.  Having received no status points, Defendant is 
not eligible for relief under Part A.  
 
Second, Amendment 821, Part B, Subpart 1, which provides a reduction for 
certain zero-point offenders, also does not apply to Defendant because, having 
received one criminal history point at sentencing, he was not a zero-point offender. 
 
 
 
 
 
 
Case 2:21-cr-00796-BRM     Document 29     Filed 03/13/25     Page 1 of 2 PageID: 178

      
 
- 2 - 
 
 
For these reasons, the Motion should be denied. 
 
 
  
 
 
 
 
 
Respectfully submitted, 
 
  
 
 
 
 
 
JOHN GIORDANO 
 
  
 
 
 
 
 
United States Attorney 
 
 
  
 
 
 
 
 
/s/ Andrew M. Trombly  
 
 
  
 
 
 
 
By:  
Andrew M. Trombly 
 
  
 
 
 
 
 
Assistant U.S. Attorney 
 
Case 2:21-cr-00796-BRM     Document 29     Filed 03/13/25     Page 2 of 2 PageID: 179

File and source

File

gov.uscourts.njd.484966.29.0.pdf

Size

182,600 bytes

SHA-256

378e74a2312e7a7f091f8c94cbedd1ce3fd3a50e2bdead7f787f6cf1cbf86899

Our copy

gov.uscourts.njd.484966.29.0.pdf

Original

PACER (login required)