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Motion for Reduction of Sentence (Amendment 821) — United States v. Monica Faye Barnes

Summary

Motion for Reduction of Sentence (Amendment 821) in United States v. Monica Faye Barnes, No. 5:23-CR-94-D-2, Eastern District of North Carolina, Western Division, filed 12/07/23. The defendant, through undersigned counsel, moves the Court for a sentence reduction based on the 2023 retroactive amendments to the criminal history guidelines. It states that Ms. Barnes is a zero-point offender and requests that the Court impose a sentence at the low end of the revised guideline range. The motion is dated the 7th day of December, 2023, and signed /s/ Laura S. Wasco, Attorney for Defendant.

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“Motion for Reduction of Sentence (Amendment 821) — United States v. Monica Faye Barnes.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-nced-200166-66-0-c3d8a21950/, SHA-256 a87c360e54182fd24b12914b07dd6511de6c464578406dd342c6f6a75def6a99.

Full text

                           UNITED STATES DISTRICT COURT
                        EASTERN DISTRICT OF NORTH CAROLINA
                                 WESTERN DIVISION

                                      NO. 5:23-CR-94-D-2


    UNITED STATES OF AMERICA
                                                          MOTION FOR REDUCTION OF
        v.                                             SENTENCE UNDER 18 U.S.C. § 3582(c)
                                                               (Amendment 821)
    MONICA FAYE BARNES


       The defendant, Monica Faye Barnes, by and through undersigned counsel, respectfully

moves this Court, pursuant to 18 U.S.C. § 3582(c)(2), U.S.S.G. § 1B1.10(c), and U.S.S.G.

Amendment 821, for a sentence reduction based on the 2023 retroactive amendments to the

criminal history guidelines. Ms. Barnes is a zero-point offender, and she respectfully requests this

motion be granted and the Court impose a sentence at the low end of the revised guideline range.

       Respectfully requested this the 7th day of December, 2023.

                                              G. ALAN DUBOIS
                                              Federal Public Defender
                                              /s/ Laura S. Wasco
                                              LAURA S. WASCO
                                              Attorney for Defendant
                                              Office of the Federal Public Defender
                                              150 Fayetteville Street, Suite 450
                                              Raleigh, North Carolina 27601
                                              Telephone: 919-856-4236
                                              Fax: 919-856-4477
                                              E-mail: Laura_Wasco@fd.org
                                              N.C. State Bar No. 34885
                                              LR 57.1 Counsel
                                              Appointed




         Case 5:23-cr-00094-D         Document 66        Filed 12/07/23      Page 1 of 2
                                 CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that a copy of the foregoing was served upon:

FELICE CORPENING
United States Attorney’s Office - EDNC
150 Fayetteville Street, Suite 2100
Raleigh, North Carolina 27601
usance.ecfcivil2@usdoj.gov

by electronically filing the foregoing with the Clerk of Court on December 7, 2023, using the
CM/ECF system which will send notification of such filing to the above.

       This the 7th day of December, 2023.

                                             /s/ Laura S. Wasco
                                             LAURA S. WASCO
                                             Attorney for Defendant
                                             Office of the Federal Public Defender
                                             150 Fayetteville Street, Suite 450
                                             Raleigh, North Carolina 27601
                                             Telephone: 919-856-4236
                                             Fax: 919-856-4477
                                             E-mail: Laura_Wasco@fd.org
                                             N.C. State Bar No. 34885
                                             LR 57.1 Counsel
                                             Appointed




                                                2

         Case 5:23-cr-00094-D        Document 66       Filed 12/07/23      Page 2 of 2


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