Defendant Donna Wasson Sentencing Memorandum — United States v. Wasson (D. Mass., Document 40)

Summary

A Defendant Donna Wasson Sentencing Memorandum, filed March 8, 2022 as Document 40 in United States v. Donna Wasson, Case No. 1:21-CR-10167-FDS, in the U.S. District Court for the District of Massachusetts. The memorandum states that the Presentence Investigation Report recommends an Advisory Guideline Range of 12 to 18 months on counts 1 – 3, and that the Defendant does not object to the recommended findings. It asks the Court to impose 18 months of imprisonment, consistent with the parties' plea agreement, citing the "history and characteristics of the defendant," including upbringing and substance abuse described in the report. It states that 18 months is at the high end of the range and meets the goals of sentencing under 18 U.S.C. § 3553. The signature line shows /s/ Paul J. Garrity.

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                Case 1:21-cr-10167-FDS Document 40 Filed 03/08/22 Page 1 of 3




                               UNITED STATES DISTRICT COURT
                                DISTRICT OF MASSACHUSETTS

                                               *
UNITED STATES OF AMERICA                       *
                                               *
           V.                                  *              Case No. 1:21-CR-10167-FDS
                                               *
DONNA WASSON                                   *
         Defendant.                            *


                 DEFENDANT DONNA WASSON SENTENCING MEMORANDUM


           The Defendant, through counsel, files this sentencing memorandum in support thereof.

           The Probation Offer has completed a Presentence Investigation Report (PSR) in which she

recommends, on counts 1 – 3, an Advisory Guideline Range (AGR) of 12 to 18 months. 1 The

Defendant does not object to the recommended findings. The Defendant contends that there are

good and sufficient grounds for the Court to consider imposition of a sentence, consistent with the

parties plea agreement, to a term of imprisonment of 18 months. The primary basis for the

Defendant’s sentencing request fall under the rubric of the “history and characteristics of the

defendant”. The PSR is replete with information describing the Defendant’s absolutely traumatic

upbringing, which includes years of physical and sexual abuse at the hands of her father, which it

would be fair to say adversely impacted the Defendant during her formative years and well into

young adulthood.

           The Defendant also has a long history of substance abuse, beginning with the consumption

of alcohol at the extremely young age of 6 2. The Defendant’s substance abuse expanded as she

grew older to include the use of marijuana, heroin, crack cocaine, and methamphetamine on a daily



1
    PSR ¶ 81.
2
    PSR ¶ 68.
                Case 1:21-cr-10167-FDS Document 40 Filed 03/08/22 Page 2 of 3




basis, along with the continuing usage of alcohol. The Defendant’s substance abuse continued on

until the date of her arrest for this offense. The Defendant’s substance abuse issues, which the

Defendant herself states “has ruined her life” 3, appear to be intertwined with her traumatic and sad

upbringing. The Defendant submits that her chaotic upbringing along with her substance abuse

history is a significant factor in what brings her before this Court.

           In addition, the Defendant, although having prior convictions for other offenses, has not

previously been incarcerated. The parties joint recommendation of an 18-month period of

incarceration is a significant period of detention for the Defendant and is at the high end of the

AGR. As a result, the Defendant submits that the recommended 18-month period of incarceration

meets the goals of sentencing with respect to specific deterrence for the Defendant and general

deterrence for others who may consider engaging in similar type conduct.

           The Defendant submits that when the Court takes all of these factors fully into

consideration, in light of the statutory purposes of sentencing, it will conclude that the proposed

18-month prison sentence is more than sufficient to address all of the factors, as outlined by 18

U.S.C. § 3553, that this Court should consider in imposing a sentence.



                                                       Respectfully submitted,
                                                       Donna Wasson,
                                                       By her Attorney,

Date: March 8, 2022                                    /s/     Paul J. Garrity
                                                       Paul J. Garrity, Bar No. 555976
                                                       14 Londonderry Road
                                                       Londonderry, NH 03053
                                                       603-434-4106
                                                       garritylaw@myfairpoint.net




3
    PSR ¶ 68.
         Case 1:21-cr-10167-FDS Document 40 Filed 03/08/22 Page 3 of 3




                                    CERTIFICATE OF SERVICE

      I, Paul J. Garrity, herein certify that on this 8th day of March, 2022, a copy of the within
Motion was e-filed for all parties involved and mailed, postage pre-paid, to Donna Wasson.


Date: March 8, 2022                                 /s/     Paul J. Garrity
                                                    Paul J. Garrity


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