Miles Guo Court Documents · Doc 469

摘要

Defense Sentencing Memorandum · Yvette Wang

This 37-page document, dated October 4, 2024 from Brendan F. Quigley and Sarah Reeves of Baker Botts LLP, is the defense sentencing memorandum on behalf of Yvette Wang in United States v. Yvette Wang, 23 Cr. 118-3 (AT).

Defense's Sentencing Position

The memorandum requests a significantly below-Guidelines sentence.

Structure

• Preliminary Statement;
• Ms. Wang's Background
• I. Ms. Wang's Upbringing in Communist China;
• II. Ms. Wang Comes to America, and Soon Thereafter [further personal history];
• III. The Impact of This Case on Ms. Wang;
• Applicable Law (sentencing framework);
• A Significantly Below Guidelines Sentence Is Appropriate
• I. Ms. Wang Did Not Significantly Financially Benefit from the Offense, and Indeed the Offense Came at a Significant Cost;
• Additional § 3553(a) arguments developed across the remainder of the memorandum.

Defense's Principal Arguments

• Limited financial benefit: Ms. Wang did not significantly financially benefit from the offense conduct, and the offense came at a significant personal cost to her;
• Personal background: Her upbringing in Communist China and personal history are offered as § 3553(a) history-and-characteristics factors;
• Acceptance of responsibility: She pleaded guilty, accepts responsibility, and stands by the plea agreement (consistent with the posture in case-doc-473);
• Comparative sentencing considerations: Reference to the recent sentence of Ms. Dilkinska as a comparator.

Exhibits

The filing includes Exhibit A under seal (case-doc-469-1), containing additional supporting material.