Sentencing Memorandum in Aid of Sentencing — USA v. Sandu (Dkt. 46, S.D. Cal.)

Summary

A memorandum in aid of sentencing on behalf of defendant Constantin Bobi Sandu, filed September 28, 2023 as Document 46 in United States v. Sandu, Case No. 23CR0386-LAB, in the U.S. District Court for the Southern District of California. Defense counsel Joseph T. Hitrec of First Call Legal Services, Inc. takes exception to the Probation recommendation of 72 months and asks that Sandu be sentenced according to the plea agreement, stating the offense level is 26, reducible to level 22, with Criminal History Category 1. The memorandum states that Sandu's gain was about $60.000.00 and that the conviction will result in removal from the United States. It cites the history of persecution of the Romani people and Sentencing Commission recidivism data for offenders with zero criminal history points.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used