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El Chapo Trial Dolly Cifuentes Request Two Level Reduction
El Chapo Trial Dolly Cifuentes Request Two Level Reduction
El Chapo Trial Dolly Cifuentes Request Two Level Reduction
herewith her Motion for Reduction of her Drug Trafficking Sentence based on recently
approved amendments to the Drug Quantity Table and in support would show as follows:
1. Dolly De Jesus Cifuentes-Villa was sentenced on January 22, 2014 for two
would be unlawfully imported into the United States in violation of Title 21, United
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34. However, her Total Offense Level was level 27 after a reduction for minor role; her
criminal history category was I; and, the advisory guideline imprisonment range was 70
to 87 months.
3. At her sentencing hearing, the Court, after taking into consideration her
minor role as well as the Sentencing Factors contained in 18 U.S.C. §3553(a), granted a
recently approved amendments to the Drug Trafficking Guidelines by the United States
Sentencing Commission.
5. If granted, Defendant expressly agrees that she will not later seek a further
reduced sentence under the 2014 amendment revising the drug quantity table.
for federal drug trafficking offenses. The bipartisan Commission’s amendment proposed
to lower by two levels the base offense levels in the Drug Quantity Table across drug
types in guideline § 2D1.1, which governs drug trafficking cases. News Release, U.S.
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approved the proposed two level reduction to the federal drug guidelines. The
Since the original proposal to amend the guidelines in January, 2014, Attorney
General Eric H. Holder Jr. has called for reduced sentences for defendants in most of the
nation’s drug cases as part of his effort to cut the burgeoning U.S. prison population and
reserve stiff penalties for the most violent traffickers. Prior to the approval of the drug
instructing his prosecutors in a memo on Thursday [March 20, 2014] not to press
judges to impose the longer sentences in the current guidelines if attorneys for drug
offenders seek shorter sentences for their clients that would be permissible under
On July 23, 2014 it was reported that the United States Sentencing Commission
voted, again unanimously, to apply these recent amendments to the federal drug
Court Judge for the District of Massachusetts has been quoted as saying “the delay [until
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routinely included by the United States in all current plea agreements where applicable.
Counsel is unaware of any judges in this district who have refused to apply the
amendment prospectively.
this Court, the Defendant’s total offense level would be 22 with a range of 41 to 51
months.
Respectfully submitted,
s/ Irwin G. Lichter
by: IRWIN G. LICHTER, ESQ.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was
s/ Irwin G. Lichter
IRWIN G. LICHTER, ESQ.