Free Objection to Presentence Investigation Report - District Court of Arizona - Arizona

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IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) Plaintiff, ) ) vs. ) ) Loren Lamar Green, ) ) Defendant. ) __________________________ ) Case No. CR 04-1058-PHX-FJM

8 United States of America, 9 10 11 12 13 14

OBJECTIONS TO PRESENTENCE REPORT AND MEMORANDUM

COMES NOW the Defendant, Loren Lamar Green, by and

15 through undersigned counsel, and informs the Court he has no 16 substantive objections to the presentence report.

He does want

17 the Court to know that he believes that there must have been some 18 type of mis-communication with the presentence writer (James W. 19 Cook) because in paragraphs 43 and 46 on page 13, although he did 20 rely on his mother for financial support, he maintains he never 21 relied on his girlfriend for financial support. 22

As an aside, undersigned counsel believes that Loren

23 Lamar Green is a very good person who made a horrible mistake. 24 Unfortunately, he was a incredible athlete in high school and 25 because of certain circumstances, he was not able to finish his 26 career.

He certainly would have gone on to play football in

27 college had he not removed himself from high school for family 28 reasons.

As a matter of fact, the running back at Arizona State 1

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1 University was behind Loren Lamar Green on the depth chart while 2 Loren Lamar Green played at Trevor Brown High School (or Westwood 3 High School). 4

Undersigned counsel has discussed with the Defendant

5 certain opportunities he will have while in the Bureau of Prisons, 6 and Loren Lamar Green is more than anxious to earn a college 7 degree during the time he is incarcerated. 8

Loren Lamar Green has stipulated to a seven year

9 sentence so there is practical reason to ask this Court for a 10 sentence less than to which has stipulated.

However, Loren Lamar

11 Green, if he keeps the positive, upbeat and goal-oriented attitude 12 he has now, he should do very well when he is released from 13 prison. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

RESPECTFULLY SUBMITTED this 23rd day of February, 2006. PHILIP A. SEPLOW, ESQ.

By: s/Philip A. Seplow Philip A. Seplow, Esq. Attorney for Defendant

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CERTIFICATE OF SERVICE

X I hereby certify that on February 23, 2006, I electronically transmitted the attached document to the Clerk's Office using the 3 CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: 4 Kurt Altman, Esq. 5 ASSISTANT UNITED STATES ATTORNEY X I hereby certify that on February 23, 2006, I served the 7 attached document by hand delivery on the following, who are not registered participants of the CM/ECF System: 8 James W. Cook 9 U. S. PROBATION OFFICER Sandra Day O'Connor U.S. Courthouse - SPC 7 10 401 West Washington - Suite 160 Phoenix, AZ 85003 11
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S/Philip A. Seplow

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