IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF VIRGINIAAlexandria Division_______________________________________)UNITED STATES OF AMERICA, ))v.
) Case No: 1:11-CR-00061-GBL)BRIAN W. YOUNG, ) The Hon. Gerald Bruce Lee)Defendant. ) Sentencing Date: July 15, 2011_______________________________________)DEFENDANT’S MEMORANDUM IN AID OF SENTENCING
The defendant, Brian Young, pled guilty to one count of conspiracy to commit moneylaundering on April 26, 2011. He will appear before the Court for sentencing on July 15, 2011.Through undersigned counsel, Mr. Young respectfully submits this memorandum as an aid to theCourt’s sentencing decision. As the Court is aware,
United States v. Booker
, 125 S. Ct. 738(2005), rendered the United States Sentencing Guidelines advisory in order to remedy the SixthAmendment violation that resulted from a mandatory Guidelines system. The applicableadvisory Guidelines range is merely one factor that the Court must consider when imposingsentence. The Court “may not presume that the Guidelines range is reasonable.”
Gall v. United States
, 128 S. Ct. 586, 596-597 (2007). Specifically, the Court’s duty is to consider all of thefactors identified in 18 U.S.C. § 3553(a) and to “impose a sentence sufficient, but not greaterthan necessary” to comply with the purposes of sentencing set forth in the statute.
18 U.S.C.§ 3553(a).As discussed below, the advisory Guidelines range in this case far exceeds a level that is“sufficient, but not greater than necessary” to serve the purposes of federal sentencing was relateto the circumstances of this case and characteristics of Mr. Young. Based on the history and
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