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Objections to Presentence Investigation Report — United States v. Gregory Scott Keough
No. 9:23-cr-80154-DMM · Doc. 51 · Docket on CourtListener
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Case 9:23-cr-80154-DMM Document 51 Entered on FLSD Docket 01/25/2024 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 23CR80154
UNITED STATES OF AMERICA,
Plaintiff,
vs.
GREGORY SCOTT KEOUGH,
Defendant.
______________________________/
OBJECTIONS TO PRESENTENCE INVESTIGATION REPORT
COMES NOW the Defendant, GREGORY SCOTT KEOUGH, (hereinafter
“KEOUGH”), by and through undersigned counsel, David J. Joffe and Patrick R. McKamey,
pursuant to the Local Rules for the Southern District of Florida and the Federal Rules of Criminal
Procedure, and would hereby file these KEOUGH’S Objections to Presentence Investigation
Report, in which it is requested that this District Court impose a sentence “sufficient, but not greater
than necessary” in order to achieve individual accountability and just punishment. See generally,
United States v. Irey, 612 F.3d 1160 (11th Cir. 2010). The objections are a result of detailed
discussions with KEOUGH and as such, KEOUGH has provided relevant input into said objection.
As a threshold matter, KEOUGH continues to fully and completely accept responsibility for his
offense conduct. KEOUGH’S objections are as follows:
1. Undersigned counsel would object to paragraph 34 at page 11, of the Presentence
Investigation Report; more particularly, KEOUGH would argue that said paragraph should be
stricken as it deals with It deals with the NFH bankruptcy and has no relevancy to the charges that
KEOUGH pled to.
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Case 9:23-cr-80154-DMM Document 51 Entered on FLSD Docket 01/25/2024 Page 2 of 3
2. Undersigned counsel would object to paragraph 55 at page 15, of the Presentence
Investigation Report; more particularly, KEOUGH would argue that he has provided a statement
for acceptance of responsibility.
3. Undersigned counsel would object to paragraph 65 at page 16, of the Presentence
Investigation Report; more particularly KEOUGH argues that KEOUGH is entitled to a three level
reduction for acceptance of responsibility pursuant to U.S.S.G. §3E1.1.
4. Undersigned counsel would object to paragraph 66 at page 16, of the Presentence
Investigation Report; more particularly KEOUGH argues that KEOUGH’S Total Offense Level
should be 19.
5. Undersigned counsel would object to paragraph 109 at page 25, of the Presentence
Investigation Report; more particularly KEOUGH argues that KEOUGH’S total offense level
should be 19 and that his guideline imprisonment range is 30 to 37 months.
6. Undersigned counsel would object to paragraph 115 at page 26, of the Presentence
Investigation Report; more particularly KEOUGH argues that KEOUGH does not have the ability
to pay a fine. (PSI:107).
7. Undersigned counsel would object to paragraph 117 at page 26, of the Presentence
Investigation Report; more particularly KEOUGH argues that KEOUGH does not have the ability
to pay a fine. (PSI:107).
8. Undersigned counsel would object to paragraph 121, at page 26, of the Presentence
Investigation Report; more particularly, KEOUGH does have factors that may warrant a variance
or downward departure.
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Case 9:23-cr-80154-DMM Document 51 Entered on FLSD Docket 01/25/2024 Page 3 of 3
CONCLUSION
The Presentence Investigation Report’s advisory guideline range of 41 to 51 months of
imprisonment is both inequitable and unreasonable given the facts in the case sub judice. Taking
into account KEOUGH’S objections. Furthermore, the Court should also consider KEOUGH’S
arguments that support his request for a variance before making a final decision as to KEOUGH’S
sentence. This embodies the sum and substance of undersigned counsel’s Objections to
Presentence Investigation Report.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 25, 2024, I electronically filed the foregoing
document with the Clerk of the Court.
Respectfully submitted,
JOFFE LAW, P.A.
Co-Counsel for KEOUGH
110 E. 6th Street 17th Floor
Suite 1700
Fort Lauderdale, Florida 33301
Telephone: (954) 723-0007
Facsimile: (954) 723-0033
davidjjoffe@aol.com
By David J. Joffe
DAVID J. JOFFE, ESQUIRE
FLORIDA BAR NO. 0814164
Respectfully submitted,
Law Office of Patrick R. McKamey
Co-Attorney for KEOUGH
515 North Flagler Drive, Suite P300
West Palm Beach, Florida
(561) 370-7424
patrick@mckameydefenselaw.com
Patrick R. McKamey
By_________________________________
PATRICK R. MCKAMEY, ESQUIRE
FLORIDA BAR NO. 103624
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