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Home Court filings United States v. Ernest Bernard Gonder, Jr. Objections to Pre-Sentence Report — United States v. Ernest Bernard Gonder, Jr. (S.D. Fla.)

Court filing

Objections to Pre-Sentence Report — United States v. Ernest Bernard Gonder, Jr. (S.D. Fla.)

Filed April 29, 2024 in U.S. v. Gonder; one of 14 filings from this case.

Record facts

CourtU.S. District Court, Southern District of Florida
Filed2024-04-29

U.S. District Court, Southern District of Florida · No. 0:24-cr-60003-KMW · Doc. 21 · 2024-04-29 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT  
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 24-CR-60003-Williams/Hunt 
 
UNITED STATES OF AMERICA 
 
v.  
 
ERNEST BERNARD GONDER JR., 
 
 
 
 
Defendant.  
__________________________________ /  
 
OBJECTIONS TO PRE-SENTENCE REPORT  
 
Defendant through counsel respectfully responds to the pre-sentence report as follows: 
Defendant, ERNEST BERNARD GONDER JR., (“Defendant”), by and through undersigned 
counsel respectfully responds to the pre-sentence investigation report (“PSR”).  
1. The Defendant has no objections to the factual and legal conclusions set forth in the 
Pre-Sentence Report (hereinafter PSR). 
2. The Defendant's Motion for a downward Variance which will be filed along with 
these objections will point out that the defendant is eligible for house arrest and 
probation (See paragraph 92 and 98 PSR); However, it is the Defendant's request that 
this Court sentence him to a probationary sentence. 
3. In the event the defendant is sentenced to some period of incarceration however, the 
defense requests the court recommend to the FBOP that the defendant be incarcerated 
in a Federal Correctional Institution as close as possible to the Southern District of 
Florida since his entire extended family resides here.  
 
Dated: April 29, 2024. 
Respectfully submitted, 
 
Case 0:24-cr-60003-KMW   Document 21   Entered on FLSD Docket 04/29/2024   Page 1 of 2

s/Michael B. Cohen, Esq. 
_________________________ 
Michael B. Cohen, Esq. 
 
 
 
 
 
 
 
Florida Bar No:  210196 
 
6400 N. Andrews Ave, #505 
Fort Lauderdale, Florida 33309 
Ph (954) 928-0059 
Fax (954) 928-0829 
michael@mcohenlaw.com 
eservice@mcohenlaw.com  
 
Case 0:24-cr-60003-KMW   Document 21   Entered on FLSD Docket 04/29/2024   Page 2 of 2

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