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UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION UNITED STATES OF AMERICA v.
CASE NO. 3:16-cr-34-J-32JRK
CARLA WILEY MOTION BY THE UNITED STATES FOR DOWNWARD DEPARTURE OF DEFENDANT'S SENTENCE BASED UPON SUBSTANTIAL ASSISTANCE Pursuant to the provisions of Section 5K1.1 of the United States Sentencing Guidelines, the United States moves this Court to grant a 6-level reduction in the defendant's offense level, and in support thereof states as follows: 1. On January 5-6, 2016, the investigation into One Door For Education, which involved then Congresswoman Corrine Brown, Chief of Staff Elias R. (Ronnie) Simmons, Carla Wiley (Wiley), and others became public. 2. On March 4, 2016, Wiley waived indictment and pled guilty to a one-count Information charging conspiracy to commit wire fraud with a cooperation plea agreement.
Case 3:16-cr-00034-TJC-JRK Document 30 Filed 11/09/17 Page 2 of 4 PageID 169
3. Wiley cooperated with the government, which assisted in the return of the Indictment and prosecution in the case of United States v. Corrine Brown and Elias Simmons, case no. 3:16-cr-93-J-32JRK. 4. Wiley testified before the grand jury and during the jury trial of Corrine Brown. Wiley’s cooperation rose to the level of substantial assistance. 5. Based upon Wiley’s substantial assistance, the government requests that this Court grant a 6-level reduction to the current applicable advisory sentencing guidelines range. 6. The Probation Officer scored the sentencing guidelines as to Wiley at Criminal History Category (CHC) I, Total Offense Level (TOL) 22. The corresponding advisory guidelines range is a term of imprisonment of 41-51 months. 7. If granted, a 6-level downward departure would result in an advisory guidelines range of CHC I, TOL 16 (21-27 months of imprisonment). MEMORANDUM OF LAW The Court, on motion of the government, may reduce a defendant's sentence to reflect a defendant's substantial assistance. USSG §5K1.1. Here, defendant Carla Wiley provided truthful and timely information to the United
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Case 3:16-cr-00034-TJC-JRK Document 30 Filed 11/09/17 Page 3 of 4 PageID 170
States, which assisted in two additional convictions. The United States believes that, because of her efforts on behalf of the United States, Carla Wiley should receive a 6-level reduction in her offense level for her substantial assistance. CONCLUSION For the foregoing reasons, this Court should grant the government's motion for downward departure of defendant's sentence. Respectfully submitted, W. STEPHEN MULDROW Acting United States Attorney /s/ A. Tysen Duva A. Tysen Duva Assistant United States Attorney Florida Bar No. 0603511 Michael J. Coolican Assistant United States Attorney USA No. 156 300 N. Hogan Street, Suite 700 Jacksonville, Florida 32202 Telephone: (904) 301-6300 Facsimile: (904) 301-6310 [email protected][email protected]
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ANNALOU TIROL Acting Chief /s/ Eric G. Olshan Eric G. Olshan Public Integrity Section Criminal Division United States Department of Justice 1400 New York Ave. NW, Suite 12100 Washington, D.C. 20005 (202) 514-1412 (202) 514-3003 (fax) [email protected] CERTIFICATE OF SERVICE I hereby certify that on November 9, 2017, I electronically filed the foregoing with the Clerk of the Court by using the CM/ECF system which will send a notice of electronic filing to the following: Justin Fairfax, Esquire (Counsel for Carla Wiley) D. Gray Thomas, Esquire (Local Counsel for Carla Wiley) s/ A. Tysen Duva A. Tysen Duva Assistant United States Attorney
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