crespo defense

1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT -------------------------------------------------------x UNITED STATES OF AMERICA, Plaintiff CR IMINA L MATTER NO. 3:12-CR-00141-EEB Vs. DAVID J. CRESPO, Def enda nt NOVEMBER 26 , 2014 -------------------------------------------------------x DEFENDANT DAVID J. CRESPO’S SUPPLEMENT TO HIS MEMORANDUM IN AID OF SENTENCING Defendant David J. Crespo, in the above captioned criminal matter, through counsel, respectfully provides to the Court this Supplement to his Memorandum in A id of Sent encing, f iled Oct ober 16, 2014 (ECF No. 100). In this Supplement , t he Defendant wishes to address two issues relevant to sentencing: relevant conduct, and the calculation of loss. Specifically, the Defendant intends to argue that certain acts of t he De f endant , alleged by t he Government and mentioned in the Presentence Report, should not be included as relevant conduct in the determination of the Defendant’s sentence, for the reason that such acts are not part of a common scheme or plan, or part of the same course of conduct. A ddit ionally, t he Def endant int ends t o cont est t he Government ’ s c alculat ion and determination of loss for purposes of enhancement under Section 2B1.1(b)(1) of the Sentencing Guidelines. For the reasons that f ollow , t he De f endant assert s that the proper amount of loss is $199,401. Case 3:12-cr-00171-EBB Document 114 Filed 12/24/14 Page 1 of 12

crespo defense

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