III. RECOMMENDED DEPARTURE
As noted above, this defendant agreed to cooperate with the UNITED STATES as part of his plea agreement. Pursuant to that agreement, defendant met with government agents and attorneys and provided information regarding his dealings with Casavant, Bagley and others. Defendant also testified before a grand jury of this Court. Defendant provided material information to the government and was ready to testify against Casavant and Bagley at trial in 2:09-cr-132-JAD-GWF and potentially other actions.
Defendant’s cooperation with the UNITED STATES was cut short by the untimely deaths of both Casavant and Bagley. Bagley passed away in late 2013 following a lengthy illness. Casavant reportedly died unexpectedly in Canada earlier this year. Nonetheless, in recognition of defendant’s substantial assistance in the investigation of his co-conspirators, the UNITED STATES respectfully moves that the Court grant defendant a 2 Level downward departure pursuant to § 5K1.1 of the Sentencing Guidelines.
RESPECTFULLY SUBMITTED this 30th day of June 2014.
Daniel G. Bogden
United States Attorney
/s/
Timothy S. Vasquez
Assistant United States Attorney
Marco's in prison on a reduced sentence, 4 years instead of 10 for Marco's "substantial assistance" he provided in the investigation and prosecution of others.
