The Federal Defender Office for the Eastern District of Pennsylvania has two new resources available for litigating Booker sentencing issues:
1) Booker Litigation Strategies Manual (April 20, 2005)
2) Model Sentencing Memorandum (post-Booker)
In addition, Fran Pratt, Research and Writing Attorney, Federal Defender Office, Alexandria, VA, has updated her Outline of post-Booker decisions. (April 17, 2005).
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Amendment 801 to § 2G2.2(b)(3)(F) is a substantive change to the Guidelines, and does not apply retroactively under § 2255
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