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Motion for Reduction of Sentence pursuant to U.s.s.g. § 5K1.1 — No. 1:21-cr-20157 (Dkt. 23, S.D. Fla.)

Summary

The government's motion for reduction of sentence under U.S.S.G. § 5K1.1, filed June 24, 2021 as Document 23 in United States v. Ioannis Kralievits, Case No. 21-20157-CR-ALTONAGA, in the U.S. District Court for the Southern District of Florida. The motion cites Guideline Section 5K1.1 and Title 18, United States Code, Section 3553(e) and moves for a downward departure from the advisory range to reflect the defendant's substantial assistance in the prosecution of others. It states that on April 14, 2021 she pleaded guilty to an information charging one count of conspiracy under Title 18, United States Code, Section 371, and that the government will give the court further information at the sentencing hearing scheduled for June 30, 2021.

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Cite this document

“Motion for Reduction of Sentence pursuant to U.s.s.g. § 5K1.1 — No. 1:21-cr-20157 (Dkt. 23, S.D. Fla.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/motion-for-reduction-of-sentence-pursuant-to-u-s-s-g-5k1-1-no-1-21-cr-21372798cc/, SHA-256 1c3bacaf07254ca440d14d1512d26db736fc294c7e88212a06008f7c282592c1.

Full text

Case 1:21-cr-20157-CMA Document 23 Entered on FLSD Docket 06/24/2021 Page 1 of 3




                              UNITED STATES DISTRICT COURT
                              SOUTHERN DISTRICT OF FLORIDA
                              CASE NO. 21-20157-CR-ALTONAGA


  UNITED STATES OF AMERICA

  vs.

  IOANNIS KRALIEVITS,

                 Defendant.
                                       /

                         MOTION FOR REDUCTION OF SENTENCE
                             PURSUANT TO U.S.S.G. § 5K1.1

         Pursuant to United States Sentencing Guideline Section 5K1.1 and Title 18, United States

  Code, Section 3553(e), the United States of America, by and through the undersigned Assistant

  United States Attorney, hereby moves for a downward departure from Ioannis Kralievits’ advisory

  sentencing range under the United States Sentencing Guidelines, in order to reflect her substantial

  assistance in the prosecution of others. In support of this motion, the Government states the

  following:

         1.      On April 14, 2021, the defendant pled guilty to an information charging one count

  of conspiracy to commit an offense, in violation of Title 18, United States Code, Section 371.

         2.      The defendant has provided substantial assistance to the government in the

  investigation and prosecution of others who have committed crimes against the United States.

         3.      At the sentencing hearing scheduled for June 30, 2021, the United States will

  provide the Court with further information regarding the nature and quality of the defendant’s

  cooperation and make a specific recommendation regarding an appropriate sentence reduction.
Case 1:21-cr-20157-CMA Document 23 Entered on FLSD Docket 06/24/2021 Page 2 of 3




         WHEREFORE, the United States respectfully requests this Honorable Court to grant this

  motion for reduction of sentence pursuant to United States Sentencing Guideline 5K1.1, following

  a hearing on this matter.



                                              Respectfully submitted,

                                              JUAN ANTONIO GONZALEZ
                                              ACTING UNITED STATES ATTORNEY


                                      By:     s/Michael N. Berger       _______________
                                              MICHAEL N. BERGER
                                              ASSISTANT UNITED STATES ATTORNEY
                                              Court No. A5501557
                                              99 NE 4th Street
                                              Miami, Florida 33132
                                              Tel: 305-961-9445
                                              E-mail: Michael.berger2@usdoj.gov




                                                 2
Case 1:21-cr-20157-CMA Document 23 Entered on FLSD Docket 06/24/2021 Page 3 of 3




                                CERTIFICATE OF SERVICE

          I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically
  filed with the Court's CM/ECF system on June 24, 2021:



                                     By:     /s/ Michael N. Berger
                                            Assistant United States Attorney




                                               3

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