Case 1:07-cr-00274-RJL Document 15 Filed 06/11/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
) Cr. No. 07-274 (RJL)
DEFENDANT’S MEMORANDUM IN AID OF SENTENCING
Defendant Renita Franklin-Thrower, through counsel, respectfully submits this memorandum
in aid of sentencing.
On December 21, 2007, defendant Franklin-Thrower pled guilty to the one count indictment
charging her with embezzlement from an organization receiving federal funds, the organization here
being the Red Cross. Sentencing is set for June 18, 2008.
The Probation Office in its revised report has determined that Ms. Franklin-Thrower’s
base offense level, including acceptance, is 8, and that her criminal history is category I; this
calculation results in a guidelines range of 0 to 6 months.
Other 3553 Factors
No one downplays the seriousness of this offense. However, Ms. Franklin-Thrower
entered an early guilty plea and has always held the position that she did not wish to force the
government and the Court to the time and expense of a trial.
Case 1:07-cr-00274-RJL Document 15 Filed 06/11/2008 Page 2 of 3
As the presentence report notes, Ms. Franklin-Thrower never knew her biological father,
and has had no contact with her biological mother since age 12. She appears to have been raised
by foster parents. She is now unemployed and receives food stamps; her unsecured debt is over
Although there is no criminal history resulting in any points, we do acknowledge some
troubling behavior. But we would submit that there are no aggravating factors warranting
anything above the lower end of the guidelines. Indeed we would submit that the ends of justice
may well be served by a probationary sentence with the requirement that she obtain employment
and make reimbursement for the funds taken. Of course, the Court would have the sword of
incarceration should she violate any terms of probation.
For the foregoing reasons, and any others that may appear to the Court, counsel and Ms.
Franklin-Thrower request a sentence of probation in this case and that full credit be given for
acceptance of responsibility.
Federal Public Defender
Assistant Federal Public Defender
Attorney for Renita Franklin-Thrower
DC Bar #214171
625 Indiana Avenue, NW #550
Washington, DC 20004
Case 1:07-cr-00274-RJL Document 15 Filed 06/11/2008 Page 3 of 3