IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEBRASKA

UNITED STATES OF AMERICA, )
)
Plaintiff, ) 8:06CR122
)
vs. ) MOTION FOR REDUCTION
) OF SENTENCE PURSUANT
JOHN MCCAUL, JR., ) TO RULE 35(b)
)
Defendant. )
COMES NOW, the Plaintiff, the United States of America, and pursuant to FRCP 35(b,
respectfully requests this Court to reduce JOHN MCCAUL, JR.s to reflect his subsequent
substantial assistance in the investigation and prosecution of another person in accordance with the
guidelines and policy statements issued by the Sentencing Commission pursuant to 28 U.S.C. 994.
In support of this motion, the Plaintiff states that the defendant provided information to the
government within one year of the time he was sentenced and further testified against another
individual, successfully prosecuted by the United States.
Respectfully submitted this 3 day of July, 2007.
rd
UNITED STATES OF AMERICA,
Plaintiff
JOE W. STECHER
United States Attorney
District of Nebraska
By: s/ Frederick D. Franklin
FREDERICK D. FRANKLIN (#18313)
Assistant United States Attorney
1620 Dodge Street, Suite 1400
Omaha, Nebraska 68102-1506
(402) 661-3700
8:06-cr-00122-LSC-TDT Doc # 64 Filed: 07/03/07 Page 1 of 2 - Page ID # 148
CERTIFICATE OF SERVICE
I hereby certify that on July 3, 2007, I electronically filed the foregoing with the Clerk of the
Court using the CM/ECF system which sent notification of such filing to the following:
Woody Bradford.

s/ Frederick D. Franklin
FREDERICK D. FRANKLIN, (#18313)
Assistant United States Attorney
United States Attorneys Office
1620 Dodge Street, Suite 1400
Omaha, NE 68102-1506
(402) 661-3700
8:06-cr-00122-LSC-TDT Doc # 64 Filed: 07/03/07 Page 2 of 2 - Page ID # 149