Pro Se Motion for Sentence Reduction — United States v. Gladys Harun (3:23-cr-3)

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Document 43 Filed 06/04/24... Page 1 of 46-8

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a UNITED STATES DISTRICT COURT cen
SOUTHERN DISTRICT OF GEORGIA REE a
CASE NO: 3:23CRO0003-1 “oes
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UNITED STATES OF AMERICA me el

GLADYS HARUN
PRO SE MOTION FOR MODIFICATION OF SENTENCE

UNDER AUTHORITY 18 U.S.C. 3582(C) (2)
Now comes prose petitioner Gladys Harun to ask this Honorable Court for a modification or reduction of her sentence
under the authority of 18 U.S.C 3582 (C) (2) and 4C1.1. and pursuant to amendment to the sentencing Guidelines by the
United States Sentencing Commission. .
Petitioner was sentenced to 60 months on January 23 2024. Her total offense level was 18 and her criminal category was 1.
Her sentencing guideline range was 27 to 33 Months. Petitioner's release date is 10/08/2026. Petitioner is currently
incarcerated in Alderson Federal Prison Camp; One Glen Ray Road, Box A Alderson, West Virginia, 24910.
A.) ZERO-POINT OFFENDER
Petitioner Submits she is a zero point offender. She qualifies for a retroactive two point reduction.
Petitioner Asserts:
1. She did not Receive any criminal history points from a prior conviction;
2. Petitioner did not receive an adjustment under 3A1.4 (Terrorism); |
3. Petitioner did not use Violence or credible threats of violence in connection with the offense;
4. The offense did not result in death or serious bodily injury;
5. The instant offense of conviction is not a sex offense;
6. Petitioner did not possess, receive, purchase, transport, transfer sell or otherwise dispose of a firearm or other
dangerous weapon (or induce another participant to do so) in connection with the offense;
7. The instant offense of conviction is not covered by 2H1.1(offenses involving individual rights); _

8. Petitioner did not receive an adjustment under 3A1.1 (Hate crime motivation or vulnerable victim) or (Serious Human
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Rights Offenses)

9. Petitioner did not receive an adjustment under 3B1.1(Aggravating Role) and was not engaged in a continuing criminal

enterprise, as defined in U.S.C 848

B.) POST- SENTENCING REHABILITATION PROGRAMMING

Petitioner has a clear conduct and has not had any disciplinary violation since incarceration. Petitioner has received various
certificates during her programming and rehabilitation. Her Recidivism level is at a minimum which is the lowest as per BOP
policy.
Petitioner could be considered for a reduction of sentence ; Pepper vs United States Supreme Court, 131 S Ct. 1229; 179 L
ED 2d 196, 2001 U.S. Lexis 1902, argued December 6, 2010 decided March 2, 2011. The downward variance was based on
Pepper's post-sentencing rehabilitation, as also with Booker Vs. United states Supreme Court 160 L ED 2d 621, 1255 S. Ct.
736 (2005), Gall Vs. United States 552 U.S 38 1285 Ct. 586, 169 L Ed @d 445, 2007
Lexis 13083, argued October 2, 2007, decided December 10, 2007. Judge Robert C. Chambers (4th Circuit) granted Terri L.
Burns on July 16, 2012 under 18 U.S.C. 3742 (e) a 30 Month Sentence reduction for programming; Burns received 30
certificates while housed at Federal Prison Camp Alderson, WV.

A sentence reduction based on post-conviction rehabilitation can hardly be said to be inconsistent with the policies
underlying an award of goodtime credit under 18 U.S.C 3624 (b) because the two serve distinctly different interest. An
award of good time credit by the Bureau of Prisons (BOP) does not affect the length of court imposed sentences, rather it
is an administrative reward to provide an incentive for prisoners to comply with institutional disciplinary regulations and
such credits may be revoked at any time before the date of the prisoner's release 18 U.S.C 3624 (b) (2).

In contrast, a court's imposition of a reduced sentence based on post-sentencing rehabilitation changes the very
terms of imprisonment and recognizes that the petitioner's conduct since her initial sentencing warrants less severe
criminal punishment. Once imposed, a sentence may be modified only in very limited circumstances 18 U.S.C 3582 (c).
Instead, the difference between the two is reflected most obviously in the fact that the BOP has no authority to award good
time credit where the petitioner's good behavior occurs after a sentence has already been served.

Wherefore, the petitioner humbly asks this honorable court to accept her certificates for programming and grant a

a

reduction of sentence.

C.)

Petitioner hereby request a court appointed attorney and permission to proceed in forma pauperis.
Signature of the Petitioner. (24a '

Date: 2) slat { Qo aU

GaSe 3:23-C1-00003-DHB-BKE Document 43 |

Print Name__ G adys Lac uA
Federal Reg No: 0561 04 HOISLO

Current Address Ov Box fr, Midecton
Attached: Wy aug

(a) Programming Certificates -
(b) Recidivism document

Filed 06/04/24

Page 3 of 16 a

Case 3:23-ct-00003-DHB-BKE Document 43 Filed 06/04/24 Page 4of16

FSA Recidivism Risk Assessment (PATTERN 01.03.00)
Register Number:09407-510, Last Name ; HARUN

U.S. DEPARTMENT OF JUSTICE FEDERAL BUREAU OF PRISONS

Register Number: 09407-510 Risk Level Inmate....: R-MIN
Inmate Name General Level......: R-MIN (0)
Last......... : HARUN Violent Level...... > R-MIN (=-2)
First........: GLADYS Security Level Inmate: MINIMUM |
Middle.......: Security Level Facl..: MINIMUM
Suffix.......: Responsible Facility.: ALD |
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Gender.........: FEMALE Start Incarceration..: 01/23/2024

Case 3:23-ct-00003-DHB-BKE Document 43 Filed 06/04/24 Page 5 of 16

DATE REVIEWED: _4/:17°2Y

INSTITUTION: FPC Alderson UNIT: 2 GP

INMATE NAME: Harun, Gladys REG NO: 09407-510

FIRST STEP ACT (Circle One): / INELIGIBLE

RECIDIVISM RISK LEVEL (Circle One): (CMINIMONS LOW MEDIUM HIGH
Case 3:23-cr- pe SE DHB- a= Document oo Filed age Page 6 gt 16

Certificate of Completion

Gladys Harun

has successfully completed the First Step Act
Women’s Basic Financial Literacy Program

This certificate is hereby issued this_ may day of 21st

Vbrtdhon

V. Booher, Special Population Program Coordinator

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Case 3:23-cr-00003-DHB-BKE Document 43 _ Filed 06/04/24 Page 7 of 16
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CLARE EIN LE NTN LOR TN EU AER LENNIE A EE RATIOS CP ERE OME RIERNNG FLAY Ck CCT NY POO et aay Gacy ae) POOLE SOIT

Certificate of Completion

Gladys Harun

has successfully completed the First Step Act

National Parenting Phase One Program
This certificate is hereby issued this_o» day of apr

Det

V. Booher, Special Population Program Coordinator

Certificate of Completion

Gladys Harun

has successfully completed the First Step Act Women’s
Aging Well

This certificate is hereby issued this__is» day of April 2024

VPake

V. Booher, Special Population Program Coordinator

AimCAse 3:23-CEe 04/24 Page 9

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Gladys Harun

has successfully completed the First Step Act
Circle of Strength Program.

This certificate is hereby issued this _ 24 day of *vril

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V. Booher, Special Population Program Coordinator

Case 3:23-cr-00003-DHB-BKE Document 43 Filed 06/04/24 Page 10 of 16

Ohis Certifies That

GLADYS HARUN

has satisfactorily completed

NUTRITION

Consisting of Hours of Craining

Given at Alderson, WY, this 23x day of  arrr 2024

fhe Ea

RECREATION i ame D. \MORGAN

Case 3:23-cr-00003-DHB-BKE Document 43 Filed 06/04/24 Page 11 of 16

‘This Certifies Chat

GLADYS HARUN

has satisfactorily completed

INTRODUCTION TO FITNESS

Consisting of Hours of Training

Given at Alderson, WU, this isr day of MAY , 2024

Rey. ee

D. MORGAN RECREATION srHCHYE IST

Case 3:23-cf-00003-DH B-BKE Document43 Filed 06/04/24 Page 12 of 16

AMERICAN BIBLE ACADEMY

Presents this Certificate to

Gladys Harun

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upon successful completion of
Gospel of John

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Awarded on 02/06/2024.

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GRADE REPORT
AMERICAN BIBLE ACADEMY
P.O. BOX 1627
JOPLIN, MO 64802-1627

NAME: Gladys Harun STUDENT ID#: 609979
COURSE: Gospel ofJohn _ DATE: 02/06/2024
EXAM 1: 92 . EXAM 2: 93 EXAM 3: 94

FINAL GRADE: 93 CREDITS: NON-CREDIT

The grading system used by A.B.A. is as follows:

At ..100-99%  B+...89-87% C+ ...79-77%  D+...69-67%  F...59-0%
Beco 98-95%  B......86-84% C.....76-74%  D.....66-64%
A- ....94-90% _B-....83-80% C-....73-70% —_—D-....63-60%

Please inform us of any changes in your mailing address.

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Case 3:23-cr-00003-DHB-BKE Document 43 Filed 06/04/24 Page 13 of 16

AMERICAN BIBLE ACADEMY

Presents this Certificate to

Gladys Harun

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NAME: Gladys Harun STUDENT ID#: 609979

COURSE: Christian Doctrine - Vol. 1 DATE: 03/12/2024

EXAM 1: 87 EXAM 2: 91 EXAM 3: 89

FINAL GRADE: 89 CREDITS: 1

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Please inform us of any changes in your mailing address.

Websites: www.abarc.org * www.arm.org
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