Federal Sentencing Data Expert

Wire Fraud and Other Financial Crimes

• In compassionate release litigation after the Court requested information on similarly situated defendants, provided historical data on sentencing trends from around when the client was sentenced.

• Studied similar loss amounts in a range of cases to support reductions in sentence below Guideline recommendations

Bank Robbery

Provided data to support argument that clients with matching Guideline applications in bank robbery cases could be sentenced favorably, achieving probation with a 33-month Guideline recommendation in one case and a 31% reduction, from 87 months to 60 months, in another case.

Drugs

• In a case challenging the drastic sentencing disparity between powder and crack cocaine, analyzed data on sentencing disparities to support a 59% reduction from Guidelines recommendations, from 210 months to 86.

• In another crack cocaine case, challenged the sentencing disparity again to support a 47% reduction from 135-month Guideline recommendation to 72 months in case with alleged distribution of both guns and crack.

• Provided data to support argument that because meth is purer nowadays than when the meth Guidelines were adopted, the only difference nowadays between meth and meth actual is whether the government tests the substance for purity. Data analysis supported a 40% reduction from 100-month Guideline recommendation to 60-month sentence.

• Filed reports in two ten-year mandatory minimum drug cases where the Court sentenced client to the mandatory minimum despite 188-month Guideline recommendations.

Child Pornography

Provided data to support argument that clients with matching Guideline applications in child pornography cases could be sentenced favorably, achieving:

• 88% reduction from 97-month Guideline recommendation to a year and a day

• 78% reduction from 78-month Guideline recommendation to 21 months

• 62% reduction from 87-month Guideline recommendation to 33 months

• 50% reduction from 130-month Guideline recommendation to 65 months

Weapons, False Statements on Passport Applications, Terrorism, and Other Crimes

• Provided data to support argument that clients with matching Guideline applications for felon-in-possession of a firearm, achieving a 47% reduction from 70-month Guideline recommendations to 37 months.

• Provided data on probation rates for client with guidelines under 2L2.2 and Criminal History Category II or higher.

• In-depth research on terrorism cases including USSC data analysis on terrorism enhancements and PACER research of cases with similar charges to identify e.g., the one case in 2006 that received a +20 offense level enhancement with confirmation that such an enhancement has only happened once, according to USSC datafiles.

• Identified every single case charging pollution into waters of the United States and compiled a detailed chart summarizing each case to identify cases with more egregious facts with relatively lenient sentences.