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Case 1:07-cr-00274-RJL Document 16 Filed 06/12/2008 Page 1 of 2

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

v.

RENITA FRANKLIN-THROWER,

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Criminal No. 07-274 (RJL)

GOVERNMENT’S SUPPLEMENTAL MEMORANDUM IN AID OF SENTENCING

The United States, by and through its attorney, the United States Attorney for the District

of Columbia, submits this memorandum in aid of sentencing. For the reasons set forth herein,

the government respectfully amends its prior recommendation that the Court sentence the

defendant to a period of four months of incarceration with no supervised release.

In its previous memorandum, the Government recommended that the Court sentence the

defendant to four months of incarceration. The Government also suggested that no period of

supervised release be imposed because the defendant is such a poor candidate for supervision.

Upon further reflection, the Government recognized that the defendant will be required to pay

some amount of restitution pursuant to 18 U.S.C. § 3663A, if only a nominal amount. It appears

that a term of supervised release is the only way the Court will be able to monitor and ensure that

the defendant pays any required restitution. Accordingly, the Government requests that the

defendant be sentenced to four months of incarceration, followed by a period of supervised

Case 1:07-cr-00274-RJL Document 16 Filed 06/12/2008 Page 2 of 2

release commensurate with any payment schedule set by the Court.

Respectfully,

JEFFREY A. TAYLOR
United States Attorney
D.C. Bar No. 498610

/s/
Emily A. Miller
Assistant United States Attorney
Federal Major Crimes Section
555 4th Street, N.W. #4237
Washington, DC 20530
Phone: 514-7533; Fax: 514-6010
D.C. Bar No. 462077

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