In light of facts that demonstrate the defendant was an eager and persistent consumer of child pornography who engaged in activity well beyond the possession and observation of images depicting the sexual abuse of children, the United States respectfully requests that this Court sentence the defendant to a sentence between the low end and middle of the Guidelines range as set forth more fully below. He also faces a potential fine, restitution, and forfeiture. Investigation Report, the defendant’s Sentencing Guidelines calculations result in an advisory guidelines imprisonment imprisonment range of 151 to 188 months. ' 3583(k) (for any offense under section 2252A, the authorized term of supervised release is any term of years not less than 5, or life.).Ĭase 3:13-cr-00021-NKM Document 48 Filed 07/10/14 of 34 Pageid#: 312 The Guidelines recommend lifet lifetime ime supervision for sex offense convictions. In total, the defendant fa faces ces a statutory mi minimum nimum of 5 years and a potential maximum sentence of 50 years, to be followed by a period of supervised release between five years and life.
He faces a st statutory atutory mandatory minimum of 5 years of imprisonm imprisonment ent and a maximum of 20 years imprisonment for each of the distribution counts and a maximum of 10 years for the possession possession count. §§ 2252(a)(2) and 2252(b)(1), and one count of possession of child pornography, in violation of 18 U.S.C.
Morris, faces sentencing after pleading guilty before this Court on April 21, 2014, without a written plea agreement, to two counts of distribution of child pornography, in violation of 18 U.S.C. GOVERNMENT'S MEMORANDUM IN SUPPORT OF SENTENCING The United States hereby submits this memorandum in support of its position on sentencing and to respond preliminarily to the defendant’s sentencing memorandum. IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA CHARLOTTESVILLE DIVISION
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