Sentencing Memorandum — USA v. CATALA et al (Dkt. 109, N.D. Fla.)

Summary

The defendant's sentencing memorandum for Clonet Junior Charmant in United States v. Charmant, Case No. 4:21 CR 00036, in the U.S. District Court for the Northern District of Florida, filed March 1, 2022 by defense attorney Eric K. Milles ahead of sentencing scheduled for March 3, 2022. Citing United States v. Booker and 18 U.S.C. § 3553(a), it asks the court to impose the mandatory minimum of 2 years imprisonment without an additional period of imprisonment. The memorandum points to Charmant's acceptance of responsibility, lack of any criminal history, and age of 19 when the involvement began, and states that co-defendants Catala and Ramirez were already engaged in the fraud. It also describes Charmant's high school football record and plans to pursue HVAC skills and a commercial driver's license.

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