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Letter, Mitchell C. Elman, Sentencing — United States v. Danielle Miller (D. Mass., Dkt. 89, August 31, 2023)

Summary

Letter from attorney Mitchell C. Elman to Judge F. Dennis Saylor IV, dated August 30, 2023 and filed August 31, 2023 as Document 89 in Case 1:21-cr-10228-FDS, concerning the sentencing of Danielle Miller scheduled for September 7, 2023 at 10:00am. The defense asks the Court to sentence Miller in accordance with the plea agreement entered on March 6, 2023, which the letter says provides 36 months on Counts One through Three and 24 months on Counts Four and Five, consecutive to Counts One through Three, for a total of 60 months. It asks that the 60 month sentence run concurrent to a 5-year committed sentence out of Sarasota County, Florida, and says the Government stated it has no objection to that.

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“Letter, Mitchell C. Elman, Sentencing — United States v. Danielle Miller (D. Mass., Dkt. 89, August 31, 2023).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-d-mass-no-1-21-cr-10228-dkt-89-d-mass-91e0466c8b/, SHA-256 638615b05431c6a05b22ddded908fde06c7ff8e764ecbe7cb842aa1c21fc832e.

Full text

          Case 1:21-cr-10228-FDS Document 89 Filed 08/31/23 Page 1 of 2




       LAW OFFICES OF MITCHELL C. ELMAN, P.C.
                                 233 East Shore Road, Suite 210
                                    Great Neck, NY 11023
                                   Telephone (516)586-6666
                                   Facsimile (516)345-2517


                                             August 30, 2023

VIA ECF
The Honorable F. Dennis Saylor IV
United States District Judge, Chief Judge
United States District Court
District of Massachusetts
John Joseph Moakley U.S. Courthouse
1 Courthouse Way
Boston, MA 02210

                                             Re:     USA vs. Danielle Miller
                                                     Criminal No. 21-cr-10228 (FDS)

Dear Judge Saylor:

               Please accept this letter in connection with Ms. Miller’s sentencing which is
scheduled for September 7, 2023 at 10:00am.

                Based upon the particular circumstances in this case including Ms. Miller’s
medical history, family history and characteristics, the defense is asking your Honor to sentence
Ms. Miller in accordance with the plea agreement entered on March 6, 2023. The parties have
agreed to a concurrent sentence of incarceration for 36 months (as to Counts One through Three,
to be imposed concurrently as to each other) and for 24 months (as to Counts Four and Five, to
be imposed concurrently as to each other but consecutively as to Counts One through Three for a
total term of incarceration of 60 months. Ms. Miller entered a plea of guilty on March 6, 2023
before Your Honor. Mr. Miller has a criminal history category III. The defense is respectfully
requesting the court to accept the plea agreement and that tge 60 month sentence run concurrent
to the 5-year committed sentence out of Sarasota County, Florida. The Government has stated
that they have no objection to this sentence being run concurrent to the Florida sentence that Ms.
Miller is currently serving.

                Ms. Miller should receive a sentence of 60 months incarceration with a period of
supervised release. Sentencing Ms. Miller pursuant to the plea agreement would be sufficient to
meet the objectives set out in 18 U.S.C. § 3553 (a). In the period of time since the date of the
offense, Ms. Miller has exhibited a strong sense of post-offense rehabilitation. She has accepted
responsibility for her actions. Ms. Miller at 33 years old, understands the seriousness of her
conduct and how it was inconsistent with her basic morality and behavior. To that end, she has
sought to make amends with her family, the victims in this matter, the court, and most
          Case 1:21-cr-10228-FDS Document 89 Filed 08/31/23 Page 2 of 2




The Honorable F. Dennis Saylor IV
August 30, 2023
Page 2

importantly, with herself. While she is prepared to accept the court’s punishment, she wants you
to understand that she is at the crossroads of her life and will be returning to the righteous path
upon which she previously traveled. She asks you to give her a chance. You will not be
disappointed.

                Ms. Miller has demonstrated an affirmative acceptance of responsibility for the
offense. Ms. Miller is a decent woman who, owing to some poor decisions, was led into making
a terrible choice about how to deal with her life situation.

               Thank you for your consideration.


                                                     Respectfully Submitted,

                                                     /s/ Mitchell C. Elman

                                                     MITCHELL C. ELMAN

Cc:    Assistant United States Attorney William F. Abely II
       Assistant United States Attorney Benjamin Saltzman
       Senior United States Probation Officer Martha C. Victoria

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