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Joint agreement with government, notable because the sentencing change in this case was the removal of the recency criminal-history point from the guidelines, which had moved defendant up a criminal history category; also includes a section 404/crack retro argument because he was eligible, and argued the GL change there too. He had also served a long time and had good equities, and that guideline hook was enough to get some traction. Second look: not just for statutory changes.”
Motion (Aug. 26, 2021)
Order (Aug. 27, 2021)
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