UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF MICHIGAN

<NORTHERN/SOUTHERN> DIVISION

__________

UNITED STATES OF AMERICA,

Plaintiff,	Case No. <Case number>

v.

Hon. <Judge name>

<DEFENDANT NAME>

Defendant.

________________________________/

JOINT MOTION FOR EXPEDITED SENTENCING

AND BRIEF IN SUPPORT

Defendant <Defendant name>, through counsel, <Deft’s attorney name>, and the United States, by Assistant United States Attorney <AUSA name>, jointly request that this Honorable Court sentence defendant immediately following the guilty plea on <Plea date>. Defendant intends to plead guilty as charged in the <Charging document>, in violation of 8 U.S.C. § 1326(a). The following joint sentencing memorandum is being filed to assist the Court in fashioning an appropriate sentence.

Offense: <Offense>

Date Offense Concluded: <Date offense concluded>

Statutory Maximum: <Statutory maximum>

Base Offense Level: <Base offense level>

Potential Adjustments: <Potential adjustments>

Total Offense Level: <Total offense level>

Criminal History Points and Category: <Criminal history points and category>

Guideline Range: <Guideline range>

Advisory Supervised Release Range: <Advisory supervised release range>

Restitution: <Restitution>

Advisory Fine Range: <Advisory fine range>

Special Assessment: <Special assessment>

Offense Conduct

<Offense conduct>

Criminal History

<Criminal history>

Immigration History

<Immigration history>

Personal Background

<Personal background>

The personal background information is being provided by the defendant and is not joined in by the United States.

Sentencing Guidelines

<Sentencing guidelines>

Conclusion

<Conclusion>

Respectfully submitted,

Dated: <Date>	<Deft’s counsel signature block>

ANDREW BYERLY BIRGE

United States Attorney

Dated: <Date>	/s/ <AUSA name>

Assistant United States Attorney

<AUSA address 1>

<AUSA address 2>

<AUSA phone>