Court filing — No. 1:21-cr-00224 (Dkt. 92, D. Md.)
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Case 1:21-cr-00224-DKC Document 92 Filed 05/03/24 Page 1 of 1
May 3, 2024
Honorable Deborah K. Chasanow
United States District Court
for the District of Maryland
6500 Cherrywood Lane
Greenbelt, Maryland 20770
Re: United States v. Kenneth Dodd
DKC-21-224
Dear Judge Chasanow:
On behalf of Mr. Dodd, counsel respectfully requests that the Court consider late notice of
opposition to the Pretrial Sentencing Report (“PSR”) in his case. PSR Paragraph 30 calculates the
appropriate offense level as 27, based on a loss amount of $1.8 million (+16 offense level.)
The parties have agreed in the pretrial agreement that the appropriate loss amount
foreseeable to Mr. Dodd is between $95,000 and $350,000 (+8 or +10 offense level). The parties
have further agreed that the amount directly attributable to his conduct and an appropriate amount
of restitution is approximately $112,000.
The defense objects to the finding in the PSR that the loss amount of $1.8 million, the
amount caused by the entire conspiracy including acts by persons that Mr. Dodd was unaware of.
The defense maintains the appropriate loss amount is approximately $112,000. The defense believes
that government counsel will take the position that the appropriate loss amount is approximately
$160,000. The defense further objects to paragraphs 35, 39, and 83 of the PSR which propagate the
higher offense level from the higher loss amount. The defense also objects to paragraph 84 which
reflects the impact of the guilty plea as only granting acceptance of responsibility points when in fact
it also impacts the appropriate calculation of the loss amount.
Government counsel is aware of this request and does not object to its consideration.
Sincerely,
/Signed
Kwasi Hawks
cf:
Service by CM/ECF filing