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Objection to Paragraph 67 of the Presentence Report and the Two-Level Adjustment for Obstruction of Justice pursuant to §3c1.1 — No. 2:21-cr-00520 (Dkt. 233, D. Utah)

Summary

Defendant Allison Marie Baver's withdrawal of her objection to paragraph 67 of the Presentence Report and the two-level adjustment for obstruction of justice under §3C1.1, filed October 9, 2024 as Document 233 in United States v. Baver, Case No. 2:21-cr-00520-001 JNP, in the U.S. District Court for the District of Utah. The filing refers to her objections at Sealed Doc. No. 225, pgs. 16-17, and states that after further review the adjustment appears appropriate under §3C1.1, Application Note 8, citing United States v. Roybal, 188 F. Supp. 3d 1163 (D.N.M. 2016). It adds that whether contempt is a misdemeanor or a felony is still an issue and that a $25.00 special assessment would apply if it is a misdemeanor.

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Cite this document

“Objection to Paragraph 67 of the Presentence Report and the Two-Level Adjustment for Obstruction of Justice pursuant to §3c1.1 — No. 2:21-cr-00520 (Dkt. 233, D. Utah).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/objection-to-paragraph-67-of-the-presentence-report-and-the-two-level-54951db74a/, SHA-256 c750e77b53e858b1bedeca9867cc11cb6a9bf65a9af118a97c98bd3aeea99ec1.

Full text

 Case 2:21-cr-00520-JNP Document 233 Filed 10/09/24 PageID.3726 Page 1 of 2




SCOTT KEITH WILSON, Federal Public Defender (#7347)
KRISTEN R. ANGELOS, Assistant Federal Public Defender (#8314)
ROBERT K. HUNT, Assistant Federal Public Defender (#5722)
ROBERT STEELE, First Assistant, Federal Public Defender (#5546)
OFFICE OF THE FEDERAL PUBLIC DEFENDER
DISTRICT OF UTAH
Attorneys for Defendant
46 West Broadway, Suite 110
Salt Lake City, Utah 84101
Telephone: (801) 524-4010
Email: kris_angelos@fd.org, robert_hunt@fd.org, robert_steele@fd.org


                       IN THE UNITED STATES DISTRICT COURT

                                     DISTRICT OF UTAH


  UNITED STATES OF AMERICA,                            DEFENDANT’S WITHDRAWAL OF
                                                      OBJECTION TO PARAGRAPH 67 OF
                  Plaintiff,                          THE PRESENTENCE REPORT AND
                                                     THE TWO-LEVEL ADJUSTMENT FOR
  v.                                                     OBSTRUCTION OF JUSTICE
                                                           PURSUANT TO §3C1.1
  ALLISON MARIE BAVER,

                  Defendant.                              Case No. 2:21-cr-00520-001 JNP




       Defendant, Allison Marie Baver, (“Ms. Baver”), by and through her attorneys of record,

Kristen R. Angelos, Robert K. Hunt, and Robert Steele, hereby withdraws her objection to

paragraph 67 of the Presentence Report which assesses a two-level adjustment pursuant to

§3C1.1. See Defendant’s Objections to Presentence Report and Sentencing Memorandum,

Sealed Doc. No. 225, pgs. 16-17. After further review and research, it appears that the two-level

adjustment is appropriate pursuant to §3C1.1, Application Note 8. See also, United States v.

Roybal, 188 F. Supp. 3d 1163, 1211-1212 (D.N.M. 2016)1211-1212.          However, Ms. Baver

asserts that the issue of whether or not contempt in this instance is a misdemeanor or felony is
                                                 1
 Case 2:21-cr-00520-JNP Document 233 Filed 10/09/24 PageID.3727 Page 2 of 2




still an issue. For example, if it is a misdemeanor, a special assessment of $25.00 will be

imposed.

       RESPECTFULLY SUBMITTED this 9th day of October, 2024.



                                                     /s/ Kristen R. Angelos
                                                     KRISTEN R. ANGELOS
                                                     Assistant Federal Public Defender


                                                     /s/ Robert K. Hunt
                                                     ROBERT K. HUNT
                                                     Assistant Federal Public Defender


                                                     /s/ Robert L. Steele
                                                     ROBERT L. STEELE
                                                     Assistant Federal Public Defender




                                                 2

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