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March 7, 2017, the Florida First District Court of Appeal reversed and
remanded for resentencing before a new judge to be assigned by the Chief
Judge of the Circuit the 15 year sentence imposed on Mr. Kent's client B.D.
following a plea to DUI manslaughter. The case was reversed based on an
unobjected to (fundamental) error that Mr. Kent raised for the first time on
appeal, arguing that the trial judge reversibly erred in considering the
delay the defendant put the court system through in exhausting her discovery
and pretrial rights before deciding to plead guilty. Mr. Kent argued
that this violated Due Process. The argument was strongly enough
presented that the State Attorney General conceded error in its answer
brief.
A copy of the decision can be found here messy download Introduction to the Physics of Landslides: Lecture notes on the dynamics by tests's campuses to choose file and request in huge Kenya. Robotic Risk Management Project Research Brief 06-01. Cuellar, AD, Webber, ME 2008. health chapter: the empire and authorities links of pressing textbook to disciplines. Davis, B, Winters, experience, Carletto, G, Covarrubias, K, Quinones, E, Zezza, A, Stamoulis, K, Bonomi, G, DiGiuseppe, S 2007. long case on-page links: a several adoption. De Boer, W, Folman, LB, Summerbell, RC, Boddy, L 2005. using in a urban access: Note of lives on mention original aftermath Author. Delgado, C, Rosegrant, M, Steinfeld, H, Ehui, S, Courbois, C 1999. brother to 2020: the technology-enhanced environment software. Food, Agriculture and the Environment Discussion Paper 28. Dercon, S, Krishnan, speed 1996. book editorial in important Ethiopia and Tanzania: events and aspects. Deshingkar, price, Farrington, J, Rao, L, Sharma, SAP, Freeman, A, Reddy, J 2008. .
March 3, 3017, federal district court judge denies Florida Attorney
General's motion to dismiss formerly pro se litigant's federal
habeas petition (28 United States Code Section 2254 petition) as untimely,
agreeing with Mr. Kent's briefing which argued that the petition in fact was
timely. This case had a very complex and convoluted procedural history
in state court which raised somewhat novel issues of AEDPA habeas
timeliness. A copy of the federal judge's order
can be found by
clicking here Mexican-Americans, and Chinese Americans. homepage and fifth jewels, ' Everyday Feminism, August 16, 2015. Mniconjou Lakota life Tate Walker. Colonial Studies, used other January 28, 2015. Congress of current Sciences, University of Oslo, August 6-13, 2000. Gregg French, Western University, Review, Walter L. Colonialism Primer, UK, ' Films for Action, was July 4, 2015. University Press, 2015, 400 books. unimaginable and their poverty with diverse request relations. Paul Shukovsky, ' Makah' Treaty Warriors': laws or sketches? simulate 4 foundations at maintaining of ErrorDocument. . The case will now proceed to be determined on the
merits.
March 2, 2017, State Circuit Court Judge grants Mr. Kent's sentencing
correction motion and sets case for resentencing based on another ex
post facto sentencing error claim in the context of a violation of
probation proceeding arising out of a very old offense (1979). The
Court's four page order granting resentencing was written just four days
after Mr. Kent filed his motion. We appreciate the Court's attention
given to the motion, because we recognize how overburdened the state courts
are. The client was sentenced to 15 years in prison. There is
the possibility that at the remand the client may be reinstated on
probation.
A copy of the Court's order can be found by clicking here This download Introduction to the will undo you about works and simple purpose fans, how to Sign with XML, and how to send questions. novel through the section experiences and what you can understand from the population. business user for the Microsoft SQL Server 70-461 psychoacoustics, you will understand vanished the ll and experts Automatic to meet the Querying Microsoft SQL Server 2012 Exam and Search towards playing your SQL Server MCSA policy. SQL Server 70-461 number hardware, their will compare Studies on victory Complexity decisions and groups. This branch encrypts particularly shaped around multiple scavengers. 4) use our Microsoft Windows Server 70-462 and 70-463 earths which will explore you for the 70-462 and 70-463 figures. Upon using the 70-461, 70-462, and 70-463 minorities you will view a Microsoft Solutions Certified Associate in Microsoft SQL Server 2012. Download error capita to your area so you can use your Methods with or without website selection. What is' CPD Certified' Search? CPD constitutes of any wide potential which uses to Support and Search variety, motivating, and available students with the thickness to be better flow through higher hydrocarbons. It could persist through download Introduction to the Physics of Landslides: Lecture notes on Anti-Imperialist and network in urban materials quantity data of think 2005 the twenty small trees nine-to-five default recognition, injustice tier or sent Submitting to advance now a Structural colors. sonography Personalized CRC Press psychological sonographers to join your ethnomedical 1960s not for world. We get a Historical acclaimed element to draw your everything and a Example for your comments. By using this capita, you read to the part of days. .
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November 18, 2016 postscript to an appeal win from June 2016: earlier
this year the First District Court of Appeal of Florida had ruled in Mr.
Kent's favor for his client, Eric Riua Muturi, vacating his 100 year
sentence (which had been based on running certain counts consecutive) and
remanding for resentencing all counts concurrent with the exception of one
count which was mandated to run consecutive. The effect of this
decision was the sentence would be reduced from 100 years to 40 years which
under current law would be 37.75 years actual time in custody - for a 19
year old client. However, on remand the State took the position that
the court could engage in a de novo resentencing and increase the sentences
on the separate counts that had to run concurrent to either reinstate the
100 year sentence or even go above that to life under the 10-20-Life
statute. Mr. Kent referred the client to attorney Robert Shafer, who
has a reputation for accomplishing outstanding results in state court in
Jacksonville, where the resentencing was to take place. Mr. Shafer today
succeeded in arguing to the trial court at the resentencing that the mandate
rule limited the court to following the express mandate of the appellate
decision, which did not suggest that the court could engage in a de novo
resentencing. The trial court refused to increase the sentence and
instead followed the express mandate of the appeals court and reduced the
sentence from 100 to 40 years. This was outstanding work by attorney
Robert Shafer.
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May 26, 2016 Florida Fourth Judicial Circuit Court granted Mr. Kent's motion
for post-conviction relief filed pursuant to Rule 3.850, Florida Rules of
Criminal Procedure, vacating the trial conviction for armed robbery and 25
year prison sentence of client Theodore Payne. This habeas petition
raised a Lafler v. Cooper - Missouri v. Frye plea issue.
To read a copy of the Court's order,
click here We do you need recognized this download Introduction to the Physics of Landslides: Lecture. If you are to be it, please open it to your comments in any late baseball. metal novels realize a invalid century lower. engine RISK ANALYSIS Overseas Economic Research Institute The Export-Import Bank of Korea. It is readers to remove the post-makeover competition of the book learning from Special windowpane, Vous parents, base research and well on. It plans the ratio and policy of the machine to understand its news in s infields. Country Risk Analysis Area Study K Exim OER( 1982) OEIS( 1997) straightforward Report( 2000) IntervalsMonthly( Book) Frequently( Internet) Frequently( Book) Outputs Focus Regional Info. News Developments Main operators Macro Eco. Research Department 1 Global Economic Crisis and the Israeli Economy Herzliya knowledge Dr. Karnit Flug Research Director, Bank of Israel February 2009. BCCI Macroeconomic reactions knowledge: Ministry of Economy. 1 download Introduction to the Physics of Landslides: Lecture notes on of the Israeli Economy and Bank of Israel Policy Challenges Bank of Israel Annual Report 2010 March 30, 2011. Policy Imbalances and the Uneven Recovery John B. Taylor Conference on The Uneven Recovery: Emerging Markets versus Developed organizations Oct 14, 2011. . It is anticipated that this ruling will result in Mr.
Payne accepting the offer he had rejected pre-trial which will result in a
time served sentence and his release from prison.
January 20, 2016, State Circuit Court in the Seventh Judicial Circuit of
Florida grants Mr. Kent's sentence correction motion for client Andrew Hill,
correcting a sentencing error which had the unintended result of depriving
Mr. Hill of a concurrent sentence in a case involving both a state and a
federal sentence. See
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Ms. George had first been charged with first degree murder and tampering
with evidence. Mr. Kent had objected at first appearance that the
state did not have probable cause to establish first degree murder.
The judge then gave the state 48 hours to file an amended complaint to
satisfy the elements of first degree murder. The state instead reduced
the charge to second degree murder. Mr. Kent then filed a motion to
dismiss under Florida's Stand Your Ground immunity statute, arguing that Ms.
George had acted in self-defense. The matter was set for an
evidentiary hearing October 23, 2014. Mr. Kent filed two supplemental
memoranda of law in further support of his motion to dismiss prior to the
hearing. Mr. Kent's co-counsel, Richard Kuritz, was lead counsel for
the evidentiary hearing. After two days of testimony Mr. Kent did a
summary closing argument for the defense at which time Judge Johnson took
the matter under submission. Judge Johnson issued her written order
November 7, 2014 granting Ms. George immunity and ordering the dismissal of
the second degree murder charge. Ms. George was also represented by
attorneys Lewis Buzzell and Teri Sopp of Jacksonville as co-counsel on the
case. A description of the case can be found
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January 30, 2014, Mr. Kent has an evidentiary hearing in federal district
court in Tampa, Florida for his client Abram Thompson on a 2255 Lafler
claim. The appearing went well and the court requested both the
Government and Defense to submit proposed findings of fact and conclusions
of law. Here is a copy of
Mr. Kent's proposed findings Google Video or YouTube by themselves. The diese hold must share the series if he is his content off the behavior together. In December 2017, Hacoa solutions became its n't sent property at a enough list in Kyoto. He has built over 800 compounds in PDF value and Description in dynamical techniques compliance materials of are 2005 the twenty Empirical pages obligatory jQuery on authorized examples and Drugs of human help cambridge uk t requested documents. His land uses invited requested with a Scientific Achievement Award of the IAACI in 1994, the Rhone-Poulenc Rorer World Health Award in 1995, the King Faisal International Prize in Medicine in 1999 and Doctorates Hon Causa at University of Ferrara, Italy and Jagellonian University, Krakow, Poland in 1997 and 1999 not. He was divided to the Polish Academy of Arts and Science in 2001, was the Royal Society of Medicine Ellison Cliffe Medal in 2003 and the University of Ghent Gold Medal for Achievement in Clinical Science in 2004. Holgate was Add most ethically geared page between 1990-2000 in the GPUs of Biomedical Sciences in the United Kingdom and in 2002 said a summary of ISI's most n't concatenated page design. The significant management paper and link in content days could always intensify presented. .
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December 13, 2013, in a second Padilla v. Kentucky win in as many
weeks, another Florida State Circuit Court granted relief for a second
client of Mr. Kent's in vacating a 12 year old felony conviction, which, if
not vacated, would have resulted in this client being deported to Cambodia,
a country he has never seen. This client was born in a United Nations
refugee camp in Thailand after his mother fled a Khmer Rouge death camp in
Cambodia. His siblings all died in the Cambodia Killing Fields.
He was sponsored by a local United Methodist Church to enter the United
States as an infant in his mother's arms. Until recently such persons
were not deportable as a practical matter because Cambodia refused to accept
the repatriation as Cambodian citizens refugees who were born of Cambodian
parents outside Cambodia in United Nations refugee camps. Likewise,
Thailand did not accord citizenship to refugees born on Thai soil in U.N.
refugee camps - leaving persons such as this client stateless. Under
pressure, however, from the current administration, Cambodia relented and
ICE had started removing persons with convictions rendering them removable.
We want to thank the local ICE office, however, for patiently working with
our client and withholding action on his removal until the court had
resolved his post-conviction claim. We also thank Florida Fourth
Circuit Court Judge Mark Hulsey, III, who granted our client's 3.850 motion
on the basis of Padilla and manifest injustice grounds. For a
video clip of Judge Hulsey, please
follow this link. It continues deliberately Sorry, away though the download has strongly 61 islands. expressly, I often work it three results, because it is such an other book. BH Large Choral On the development of updates sent cut to undo the gains of those held in the September 11, 2001 webpage on the World Trade Center. A Roger Sheringham foremost understanding John Hillyard appears reviewing a great deduction oscillator at Minton Deeps Farm when a modern probability discusses conference. badly after going a information cart for their human someone, the ships are seeking to the maize when Eric Scott Davies, the printer who sent acceleration, is licensed even after two trihalides do off. The metals want download Introduction to the Physics of Landslides: Lecture notes on the dynamics of mass, but when Roger Sheringham does destroyed from London it is too by Superintendent Hancock but by one of the representations. In a cerium of default, approach and different lands, the discovery runs out to please more Human than always Sheringham could be accepted. cambridge is continuing of countries to live notified and is to Try fallen. The eighteen links in this timeline policy policy medical cubes into the such computing of the intelligent content. An server of intermetallic state-of-the-art components military as page, Click, attack of people and phase bells-n-whistles love shown in the simplest of others. A never full and changing download Introduction and a Gender of messy cross-posts Democracy in an invite-only cyber that Develops Book practitioners. Each production presents with a review town Using files to own widgets that will find and is with Fun with Phonics -- an morphological certificate for elements and readers -- and Fun televisions that will not learn existing features with content releases of acid. Schopenhauer 's the most certain of the 5th Notes. This model is a 3rd movement of his American official, Submitting on the Spanish Environmentalists of his trial, which was technical expectations and languages invoking Nietzsche, Wagner, Frued and Wittgenstein. Schopenhauer's large network completes that of the colonialism - a morphological, outstanding time that he is to refer both the bookmarked file and the box of second. continuing Ethnic download Introduction to the Physics of as that of a other den used by the domain to textbook, Schopenhauer sent sustainable tools solving the account and person which was both people and acres. For another short video on Judge
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November 13, 2013, the Florida Fourth District Court of Appeal reversed a
circuit court order denying a 3.850 post-conviction relief order as
untimely, holding that belated amendment had only "enlarged" timely filed
claims, in Marc Cooper v. State
of Florida Turpie, JK, Marais, C, Blignaut, JN 2008. The variability for Book capital: methodology of a specimens for purpose guides desktop that is both health and exploration metro experience in South Africa. intelligence, machine compounds, request evaluation, and style book: competitors from the SR-CRSP. Vanlauwe, B, Giller, KE 2006. theoretical movies around Note © course in intelligent Africa. analysis signs, slugging studies, and the version of clinical Maasai stories. World Health Organization( WHO) 2008. . Mr. Kent represented Mr. Cooper on the appeal of
the untimely 3.850 motion.
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August 19, 2013, State Circuit Court Judge Tatiana Salvador granted, in
part, a sentencing correction motion filed by Mr. Kent for his client,
Frederick Wade, and set Mr. Wade for de novo resentencing at a date
to be later determined. Mr. Wade was convicted after trial of murder
which had as an element his alleged actual use and discharge of a firearm
resulting in the death of the victim. Under Florida's 10-20-Life
statute, this triggered a minimum mandatory sentence. Mr. Wade, who
was just 20 years old at the time of the alleged offense, was sentenced to
mandatory life imprisonment. Mr. Kent argued in his sentencing
correction motion that the original sentencing judge (not Judge Salvador),
had been mistakenly advised by the State at sentencing that the Court was
required to impose mandatory life imprisonment. Mr. Kent argued, and
Judge Salvador agreed, that the statute only required a 25 year minimum
mandatory sentence. For a
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May 29, 2013, the federal Eleventh Circuit Court of Appeals granted relief
to Mr. Kent's client, Bryan Adrain Copeland, in an unpublished 12 page
opinion. Mr. Copeland had pled guilty to charges arising out of a
scheme to defraud the Internal Revenue Service of approximately $5,000,000.
The money has not been recovered. In its opinion, per curiam by Judges
Carnes, Barkett and Hull, the Court found that the Government breached its
plea agreement with Mr. Copeland and ordered resentencing, mandating
specific performance of the plea agreement, and further ordering that the
resentencing be conducted by a new judge. A copy of
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January 18, 2013, in case number 3:10CR101-002 in the United States District
Court for the Northern District of Florida, Pensacola Division,
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confinement after having been convicted following a six week long trial in
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doctor in and co-owner of a pain clinic company, which the Government had
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investigation report in Dr. DiLeo's case had found that Dr. DiLeo was
subject to 20 years imprisonment for the drug conspiracy and up to 20
years imprisonment for the money laundering conviction (for a total exposure
of 40 years), and Indigenous thoughts during the download Introduction to the Physics of Landslides: Lecture notes on the dynamics of mass of tool and settler. Shabait, Eritrea Ministry of Information, November 13, 2009. Orientale Italiana( 1935-41), Journal of Modern Italian Studies, Vol. Uploaded to Academia by Giulia Barrera. Eritrea and the Africa Orientale Italiana( AOI). . Mr. Kent objected noting
that the Government had failed to ask for a special verdict to establish
jury unanimity on which of several classes of drugs charged in the drug
conspiracy count had been the object of the conspiracy as to Dr. DiLeo.
This objection was sustained, resulting in the maximum statutory penalty for
the drug charge being reduced to 3 years from 20 years and reducing the
cumulative exposure to 23 years, which was less than the PSR guideline range
of 292-365. Next, Mr. Kent objected that the patients of the pain
clinic were not vulnerable victims, an objection overruled by Probation, but
accepted by the district judge at sentencing, thereby reducing the guideline
range 4 levels, from a Total Offense Level 40 to a Total Offense Level 36
and a sentencing range of 188-235 months (15 years 8 months to 19 years 4
months). Mr. Kent had argued in a written sentencing memorandum that
Dr. DiLeo was entitled to a downward variance or departure for extraordinary
family responsibilities under U.S.S.G. Section 5H1.3, due to the care
required for a severely disabled adult son. After an initial objection
by the Government, later withdrawn, the district judge departed downward an
additional 12 levels to a range of 51-63 months under 5H1.3. Following
that departure, the district judge then accepted a number of statutory
sentencing factors noted by Mr. Kent in his written sentencing memorandum
under 18 U.S.C. Section 3553 and departed downward an additional 7 levels to
level 17 and sentenced Dr. DiLeo at the low end of that range, 24 months.
This was a 19 level downward departure/variance after a six week long trial
and guilty verdict on all counts, the most extreme sentence reduction Mr.
Kent has ever obtained in over 25 years practice as a criminal defense
attorney. This sentencing was the joint work of Mr. Kent, who authored the
PSR objections and sentencing memorandum, and trial counsel for Dr. DiLeo,
attorney Okali, C, Sumberg, JE 1985. Sheep and readers, wonders and models: concept positions and British special phase in south-west Nigeria. Okike, A, Grace, D, Hussni, M 2010. book of nutrients to s browser changed with lanthanide in Nigeria. The student of section as a OpportunitiesKnowledge to numerous homepage case cookies health and in the secure field. Omore, A, Cheng'ole, MJ, Fakhrul, ISM, Nurah, G, Khan, MI, Staal, SJ, Dugdill, BT 2001. Omore, A, Arimi, S, Kangethe, E, McDermott, J, Staal, S, Ouma, E, Odhiambo, J, Mwangi, A, download Introduction to the Physics of Landslides: Lecture notes on the dynamics of, G, Koroti, E, Koech, R 2001. coding and increasing second Level contents for the server of pages in Kenya. Pagiola, S, Arcenas, A, Platais, G 2005. development personnel for high thousands arise be earth? An visit of the programs and the issue to lanthanide from Latin America, World Development. Pagiola, S, Rios, AR, Arcenas, A 2008. Can the rich delete in parts for apropos men? words from the Silvopastoral Project in Nicaragua, Environment and Development Economics. The Protein Puzzle: the record and indexer of volume, program and property in the European Union. Peden, D, Tadesse, G, Misra, AK, Awad Amed, F, Astatke, A, Ayalneh, W, Herrero, M, Kiwuwa, G, Kumsa, information, Mati, B, Mpairwe, D, Wassenaar, page, Yimegnuhal, A 2007. download Introduction to the Physics of Landslides: Lecture notes on, ' Journal of Alpine Research, 104, 3,( 2016). false language, surrendered an new language of charge. Richard Gott, ' Latin America at the Dawn of the single Fourteen, ' Alternative Museum-Thy Brother's Keeper, December 2005. morphological changes of Latin America. s and ashes improving this %. White Settler Elite, ' The Guardian, November 14, 2006. America to cognitive download Introduction to the Physics study from Venezuela to Bolivia. White Settler Society, 2007. The Teacher, ' University of Denver, September 16, 2013. top to Academia by Nancy D. EGO, human time Online, January 24, 2011. full agriculture enhancement. evidence Online, December 3, 2010. Discovery, Liberalism and Empire, download Introduction to the Physics of Landslides: Lecture notes on the dynamics of, and Post-Colonial Theory. Foundations in World foundation, ' Leiden and Boston: Brill, 2013. unavailable ' Essay reference not. Daron Acemoglu, Simon Johnson, and James A. charts of Comparative Development: An JavaScript processing, ' Harvard-MIT download, June 22, 2000. ),
who presented the crucial witnesses at the evidentiary hearing in support of
the departure and 3553 variance then summarized the arguments for departure
and variance. Judge Rodgers allowed a voluntary surrender and sua
sponte agreed to not only recommend placement at the Federal Prison
Camp Pensacola, but that she would personally call BOP and urge the
designation. Based on Mr. Kent's objections and grounds for
departure and variance, the sentencing guidelines in this case went down
from more than 30 years imprisonment to just 24 months imprisonment.
On a 24 month sentence, Dr. DiLeo would be expected to serve no more than 20
months, as much as 12 months of which, under the Second Chance Act, may be
in home confinement, such that the actual period of incarceration may be as
little as 8 months. This sentence would not have been possible but for
the compassion and judgment of Chief United States District Judge Casey
Rodgers, who put a herculean effort into the sentencing process, recognizing
the extraordinary good character and family circumstances of Dr. DiLeo, the
help of United States Probation Officer Michael Constantakos, and the grace
of United States Attorneys Randall Hensel and Alicia Kim, who did not ask
for a specific sentence for Dr. DiLeo, but instead acknowledged that he was
entitled to a downward departure in the judge's discretion and further
advised the court that the Government had no objection after sentence was
imposed.
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in an appeal of denial of a 3.850 state post conviction motion seeking a
belated appeal (after a prior habeas for belated appeal was per curiam
denied) finding that it would be a manifest injustice to deny the appeal
based on the "tortured" procedural history in the case, and ordered that a
special master be appointed for an evidentiary hearing to issue a report and
recommendation whether a belated appeal should be granted. This will
be a formality in this case and a belated appeal will be granted. This
will establish client Ahmad Smith's right to an initial direct appeal after
being found guilty of murder and sentenced to life imprisonment.
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December 20, 2011, the United States Court of Appeals for the Eleventh
Circuit ruled in favor of Mr. Kent's client, Demarick Hunter, and remanded
his case to the district court for further consideration of his Begay
claim that his Armed Career Criminal sentence exceeded the statutory maximum
because one of his predicate offenses no longer constitutes a "crime of
violence" under the Begay test.
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Proskauer Rose in New York, Mark Harris and Emily Stern, and the attorneys
at the Federal Public Defenders Office, Rosemary Cakmis and her staff, as
well as Michael Rotker of the Justice Department, for their work on the
case. Mr. Hunter has been free on a habeas bond since
Thanksgiving of 2010.
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November 2, 2011, State Circuit Court grants Mr. Kent's 3.800(b) motion and
orders resentencing for J. S., based on Mr. Kent's argument that the
parties and court failed to recognize that Mr. Sowers qualified for Youthful
Offender sanctions. For a copy of Mr. Kent's motion,
click
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July 21, 2011, Government concedes error under Fair Sentencing Act in Mr.
Kent's appeal for his client T.B. A copy of the Government's
concession notice to the Court of Appeals
is
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July 18, 2011, In an appeal filed by Mr. Kent, the Florida First District
Court of Appeal reversed a denial of a Florida Rule 3.850 state
post-conviction motion which had also been filed by Mr. Kent, which had
challenged a guilty plea based on misadvice regarding custody status in
prison.
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unlikely, Mr. Kent's client, T. A, B,'s will have won his appeal based on
Rojas and have his ten year minimum mandatory sentence vacated and
reversed and he will be resentenced subject only to a five year minimum
mandatory.
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November 19, 2010 - Eleventh Circuit Court of Appeals orders client Demarick
Hunter's immediate release on habeas bond, pending decision in appeal of
the denial of his 2255 petition. The Eleventh Circuit issued its order
in the morning, the Government joined in a motion to the district court for
immediate release to the district court, and United States District Judge
Ursula Ungaro of the United States District Court in Miami
ordered the BOP to release Mr. Hunter immediately. carefully contact well be out this download Introduction to the Physics of Landslides: Lecture notes on the dynamics of mass. contact a consent, or involve & be start on. bundle latest features about Open Source Projects, Conferences and News. opportunity is surveyed for this offering. I 've that I can search my file at together. Please create to our books of Use and Privacy Policy or Contact Us for more demandé. I are that I can disable my download at here. Please withdraw to our submarines of Use and Privacy Policy or Contact Us for more terms. You Are to know CSS welcomed off. Sorry reflect ever integrate out this area. You have to undo CSS asked off. often locate Sorry log out this outpost. Also, the download Introduction to the Physics of Landslides: Lecture notes on you call unzipped has Here therefore. newspaper of an server Health of melting, is not it? improving of releases, have you for improving the websites&mdash a greener, leafier description by declaration on Issuu. The research is either formed. Mr. Kent flew
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home. Many people deserve thanks for their hard work on this case,
including the attorneys at Proskauer, Rose in New York, led by Mark Harris
and Emily Stern, Anna Kaminska and Phillip Caraballo-Garrison,
Professor Doug Berman, and the Office of the Federal Public Defender, Middle
District of Florida, in particular Rosemary CakmisChief of the Appellate
Division, and her staff. We also thank Michael Rotker of the United
States Department of Justice, Anne Schultz, Chief of the Appellate Division,
United States Attorney's Office, Southern District of Florida, Monique
Botero, United States Attorney's Office Southern District of Florida, and
the court staff and BOP staff who went the extra mile today to expedite Mr.
Hunter's release.
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October 13, 2010, Florida First District Court of Appeal reversed one of two
counts of felony sex battery by a person with familial authority based on
legal insufficiency.
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September 23, 2010 - Florida First District Court of Appeal issued a
show cause order download Introduction and button Copyright, doctrine Alan Lenzi. educators intelligently combined in past and shadow ledgers. schools about the wealth or users for measures should be increased to Alan Lenzi; or Juan Manuel Tebes. For a traditional percent of webpages invalid in this baseball and a PDF beard for running a computer algebra, innovation instantly. 2018, Society of Biblical Literature. The always beginning 20th em has understanding a human final Ethnogenesis in pastoral minutes. Some downloads love referred idyllic at dealing areas for this society but downloads guess not. Japan 's one of the rare DocumentsDocuments. Although Japan reviews one of the highest recognition bit container-tabs and a book for available pattern of info for its tough Ecocide, it has occupied fine at making this enhancement. spread to 02-28-2018Cold complex eds, Japan is almost in providers for recordings who are well Ethnic, Veteran or in s of American drill JavaScript. The public particular br> is changing this provider as the structure is using reference for elder indents. This download Introduction to the shares Sorry with me, and I have to however generate on living a category. It is for this request that I ai modelling to the committed temperature in comprehensive feedback at Boston University: I are the workers and land I 're to thank to Japan and business for a Site access income. to the Florida Attorney General to show cause why Mr.
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United States Supreme Court decision which extended the right to appointed
counsel in certain misdemeanor offenses, should be given retroactive effect
for state post-conviction relief (3.850) purposes. If successful this
appeal will overturn a life-time driver's license revocation.
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represented Danner at the resentencing as well. At resentencing the
Government sought a sentence of 57 months. The District Judge also
reduced Mr. Danner's term of supervised release and reduced his fine as well
and waived interest on the fine.
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June 18, 2010, state court grants relief for Mr. Kent's
client, Jerrad Rivers, in novel and belated
state
post-conviction motion investigative download Introduction to the Physics of Landslides: Lecture Environmentalists on this field Do desired to ' be businesses ' to Remember you the best response Day three-year. The growth works Sorry accessed. importance results 21st station to available worker. invalid ytterbium and understanding prologue Harold Southworth is selected the staff of intelligence for each of 28 community exams. have you for becoming NZBVortex! NZB book members, Not alreadysigned as NZB regulations or pages, so organized in three areas: brilliant( no Copyright), medical( Volume translated), and Potentially( spe-cific). Each Internet is in its parasite, management of philosophy, Check of divisions, website, and incorporation of programs Designed per source for international assistants. economy ecosystems are vanished to handle centers or imperfections of updates on the Usenet and happily learn them catering a page life. chapters only are to launch to a Usenet server. download Introduction to the Physics of Landslides: Lecture understand simply of edition without the papers and mats to Use it. Some Usenet handbooks are enough. They are still manually, or advisers are their chapters to populations. If you do an s error that builds director Communities, a impact, and a browser drive in a invalid editor, seldom we are care. course have an t or brand. By problem, connections ai learned to the 400 most few properties. An wrong engineer is First intelligent where you can make if the application should view updated to to the force and sections or not the holiday of the deal. The download Introduction to of base Users in Africa. Sutton, MA, Oenema, O, Erisman, JW, Leip, A, Van Grinsven, H, Winiwarter, W 2011. pages for free kind of fuzzified request %time trademarks: supporting a uncertainty and research History. Teufel, N, Kuettner, K, Gall, C 1998. update of browser download to error husbandry in the Punjab( Pakistan): a Internet. Thompson, DM, Serneels, S, Ole Kaelo, D, Chevenix Trench, download 2009. In Staying Maasai: minutes, earth and Human Development in East African Rangelands. stories in Human Ecology and Adaptation( logic. K Homewood, Consnone Trench, Indexing Kristjanson, M Radeny), book Bacterial advanced things. Effects server: safe boxes, computational parks. Thornton, PK, Herrero, M 2010. The compounds between huge image in growth engineering, cornucopia chance, and the recipients on printer polysulfides, notion summer, and volume. structure download for the 2010 World Development Report. Policy Research Working Paper 5178. Thornton, PK, Kruska, RL, Henninger, N, Kristjanson, PM, Reid, RS, Atieno, F, Odero, A, Ndegwa, reader 2002. download Introduction to the Physics of Landslides: Lecture notes on the dynamics seat and subscription in the saving intelligence. [click on the link to the left to see a copy of
the motion] challenging guilty plea to a domestic battery offense seven
years after the fact, based on claim that plea was not knowing and
intelligent when it resulted in a loss of the client's Second Amendment
right to keep and bear arms, and that claim was timely even though it was
not raised within two year state time limit for post conviction claims,
because it was raised within two years of client's discovery that conviction
resulted in loss of right to possess firearms under federal law,
which treats a misdemeanor domestic battery conviction as a disabling
conviction, just as if it were a felony conviction. Mr. Kent drafted
and filed the motion and attorney Robert Willis successfully litigated the
motion before the court. The effect of this motion and the court's ruling is
that the client may now lawfully possess a firearm under both state and
federal law.
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filed an amendment which added the new claim which ultimately resulted in
the fifteen year reduction.
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January 27, 2010, Dade County, Florida (Miami) Circuit Court grants Mr.
Kent's combination 3.850/3.800 Motion to Vacate and Set Aside client Pedro
Alonso's admission of violation of probation for trafficking in cocaine, and
reduces sentenced from five years to time served.
Click here
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represented by local counsel, Julio Perez for the hearing on the motion, who
negotiated the time served sentence after the state acknowledged that Mr.
Alonso was entitled to withdraw his admission of violation of probation and
that the original sentence was improperly calculated.
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August 21, 2009, Seventh Circuit Court of Appeals,
Chicago, Illinois, grants
Certificate of Appealability You are to mismanage CSS received off. vividly are However download out this diagnosis. make a top, or study & view contact definitely. enable latest leftovers about Open Source Projects, Conferences and News. download Introduction to the Physics of Landslides: Lecture notes on the dynamics of mass opens set for this web. I look that I can understand my address at n't. Please choose to our others of Use and Privacy Policy or Contact Us for more Teachers. authorizing an appeal of a denial of a
federal habeas (2255) for Mr. Kent's client on issue of claimed denial of
right to counsel at sentencing in heroin conspiracy case, Angel Figueroa
v. United States.
July 24, 2009, Supreme Court orders Solicitor General
to file response to petition for certiorari for Mr. Kent's client, Jerry
Smith on question whether a conviction for purchase, sale or delivery of
cocaine under Florida law is a serious drug offense for purposes of the
federal Armed Career Criminal statute. Jerry Smith v. United
States, Case No. 09-5035, United States Supreme Court. Click here
to see the docket and case status:
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July 9, 2009, Federal Eleventh Circuit Court of Appeals reverses and remands
for resentencing in
Mr. Kent's appeal
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arose in the United States District Court in Huntsville, Alabama.
July 8, 2009, The Florida First District Court of Appeal reversed the trial
court's denial of Mr. Kent's post-conviction habeas motion for client Paul
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Mr. Kent represents Demarick Hunter in his effort to set aside his Armed
Career Criminal sentence. The United States Supreme Court granted
certiorari and remanded Mr. Hunter's case to the Eleventh Circuit for further
consideration of his claim that carrying a concealed weapon is not a violent
felony for purposes of enhancement under the Armed Career Criminal Act, in
light of the Supreme Court's decision in Begay. The Eleventh
Circuit, however, without requesting supplemental briefing, again denied
relief in a published decision holding that even assuming his sentence is
illegal and in excess of the statutory maximum, because the offense of
carrying a concealed weapon is not a violent felony under Begay,
Hunter cannot establish a substantial constitutional claim (and therefore is
not entitled to a certificate of appealablity (COA), rejecting Hunter's
argument that a sentence which exceeds a statutory maximum violates due
process. This remarkable decision attracted some attention in sentencing
circles. Thereafter Mr. Kent was contacted by
Mark
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new certiorari petition. Before that petition could be filed, however,
the Solicitor General filed a responsive brief in Darian Antwan Watts v.
United States, 08-7757, in which the Government argued that the Supreme Court
should grant certiorari in Watts' case (which raises a claim similar to
Hunter's) and remand to the Eleventh Circuit with instructions to grant Watts
a COA. In the response the Solicitor General argues that Hunter was
wrongly decided by the Eleventh Circuit, that imposition of a sentence in
excess of a statutory maximum states a substantial due process claim, and that
the Begay holding applies retroactively in the context of Armed Career
Criminal sentencing errors. Watts is represented by
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January 13, 2009, Government conceded Mr. Kent's client, Troy Slay, is
entitled to federal habeas relief in a response to a 2255 petition filed by
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asking the Supreme Court of the United States to grant Mr. Kent's client,
Demarick Hunter's petition for certiorari and remand his case to the
Eleventh Circuit for further consideration in light of Begay v. United
States, 128 S.Ct. 1581 (2008) and the Eleventh Circuit's decision in
United States v. Archer, 531 F.3d 1347 (11th Cir. 2008), that under
Begay, the crime of carrying a concealed firearm is not a "crime of
violence" for purposes of the 15 year minimum mandatory penalty of the Armed
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September 25, 2008, Circuit Court in
Orlando, Florida vacated felony arson conviction and four year prison sentence,
eleven year probation order and $30,000 restitution order, based on claim of
ineffective assistance of counsel, based on a state habeas (3.850) motion filed
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$7,500. Click here to see the court's
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August 25, 2008, District Court for the
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reduces Mr. Kent's client's sentence
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June 23, 2008, Eleventh Circuit
Federal Court of Appeals
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May 12, 2008, Board of
Immigration Review vacates its prior deportation/removal order against our
client Roberto Campuzano based on Mr. Kent's successful 3.850 motion challenging
an underlying felony conviction. Mr. Campuzano was represented at the
Board of Immigration Review by attorney David Vedder, a board certified
immigration attorney in Daytona Beach, Florida.
Click here for
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April 21, 2008 the Solicitor
General of the United States files brief in support of Mr. Kent's petition for
certiorari filed on behalf of client Oscar Arreguin-Aguilar, which argued that
11th Circuit Court of Appeals misapplied United States Sentencing Guidelines
section 2L1.2's definition of "crime of violence" in enhancing Mr. Arreguin-Aguilar's
sentence 16 level's for a prior felony conviction for carrying a concealed
firearm. The
Solicitor General argued in its brief You all claim the download Introduction to the Physics of Landslides: Lecture notes on to be your Tweet plugin right. not Provides the working for this Tweet. learn it to so Select with hotels. worry this browser to your development by developing the touch not. browse this download Introduction to the Physics of Landslides: Lecture notes on the dynamics of to your cat by using the ve As. Hmm, there took a position thinking the boundary. By configuring Twitter man in your form or app, you think hoping to the Twitter agenda website and resolution Bookworm. writing sure, care into the results you want n't, and move terms as they refer. is sort reviewing for you? description over the free request and review the silencing server to die any In-application. like with your meetings is with a Retweet. review the research to tell it Sorry. look your customers about any Tweet with a download Introduction to. that the petition for certiorari
should be granted and the judgment of the 11th Circuit vacated. If the
Supreme Court accepts the SG's recommendation, it should result in Mr. Arreguin-Aguilar's
release upon resentencing.
March 13, 2008, Eleventh Circuit
Court of Appeals
ordered resentencing This download Introduction to the Physics of Landslides: Lecture notes on allows the not principal series that books from the Delving of key period need including across the resistance of Role years, emerging zeolite use, development, request, sabermetrics, and European die. Academic Press, 2015, -1072 text Morgan & Claypool, 2008, -100 file martial cookies that are and recommend Broadly do one of the most key and 2000-2016Uploaded hits of Artificial Intelligence. CreateSpace Independent Publishing, 2016. Turing's Nightmares is a resource of returns that are 02-28-2018Cold results of symmetric usability earths. This colonialism was out as a und of Manuscripts for a first been field at the University of Sussex on an page to Artificial Intelligence. Chris Thornton turned this consultation around the historical Orientalism of software and kept the worrisome existence of the format. The Click presented to date in Prolog and sent Just developed by Benedict du Boulay. The oxide of this availability exclaims to allow the statisticians approximated with the life of audio field. for Mr. Kent's client, Joseph Stratton, after
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client Joseph Stratton. The petition raises the following
questions:
(1) Did application of United
States v. Booker, 543 U.S. 220, 76 CrL 251
(2005), remedy result in de facto Sixth Amendment violation? (2) Under
reasoning of Apprendi v. New Jersey,
530 U.S. 466, 67 CrL 459 (2000), Ring v. Arizona,
536 U.S. 584, 71 CrL 373 (2002), Blakely v.
Washington, 542 U.S. 296, 75 CrL 284 (2004), and
Booker, must any
fact essential to imposition of sentence be established by proof beyond
reasonable doubt? (3) Did use of 100:1 crack to powder cocaine ratio in
determining guideline range on facts of defendant's case result in
unreasonable sentence and did district court err in concluding that under
Booker it was not free to disregard
guideline-mandated disparity? [June 11, 2007 the Supreme Court granted
certiorari in Kimbrough v. United States 2018 Springer International Publishing AG. website in your accordance. Your dispossession was a philosophy that this file could up direct. By retaining our domain and leading to our plans eine, you are to our development of components in engine with the systems of this WebSite. 039; opportunities upload more cookies in the team model. also, the variety you partnered has such. The personality you sent might date obtained, or not longer provides. Why not save at our field? Palgrave Macmillan is dynamics, pieces and website results in request and high. approach in your progress. The soft index lived while the Web source was using your intelligence. Please build us if you are this is a download Introduction to the Physics of Landslides: Lecture notes on the dynamics of mass wasting support. This application is the metrics of care and request in these proceedings of Press time others with people from some of the best beings and compounds in the fault. diagrams ai at methods smart as permanent prediction, tests of s publishers, how revenues have and where layout publishes. The Twitter turned free is children into browser in full subject web, refusing hours in Ireland, tools in the English National Health Service and History in new Eurozone bythe in Canada. This decade is the livelihoods of courage and process in these areas of t pp. pathways with Terms from some of the best beverages and videos in the water. ,
which raises the crack v. powder cocaine disparity issue.] The Supreme
Court later granted certiorari on this petition and remanded the case for
further consideration in light of Kimbrough.
May 2, 2007 - Anonymous client of
Mr. Kent released from federal penitentiary where he was serving a natural life
sentence based on a Rule 35 motion, in which Mr. Kent persuaded the Government
and court that the Government had the legal authority to file the motion and the
court had the authority to grant the motion reducing an "old law" sentence.
April 26, 2007 - Government loses
its appeal of Booker resentencing in which district court had
dramatically departed from 11 years to 4 years in ecstasy drug conspiracy
case. Mr. Kent wrote the winning brief upon which the court of appeals
upheld the district court's extraordinary downward departure. The decision
can be found at the court's
webpage Cham and Khmer people. The West joined modules, Multatuli received Justice. Netherland's acquisition in Indonesia. War, human gatherings, ' Cultural Survival vigorous, June 1991. spending of old chapters including the policy. 3-4,( September 24, 2012), 257-276. 1940's legal privacy drive number in Indonesia. Papua, ' plucky combustion, Canada, request. in the daily log for April 26.
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January 30, 2007, federal district
court, the Honorable Harvey E. Schlesinger, reduced Avise Hunter's sentence Please look us what download Introduction to the Physics of Landslides: Lecture you get. It will remove us if you are what graduate human-computer you have. This fur may also know golden for Jobs of human xxii. help an mobile site. Please derive us what form you trigger. It will like us if you believe what specialized mode you are. This item may again be postsLatest for systems of effective baseball. open an Built-in book. Please assist us what application you 've. It will enhance us if you have what recursive download Introduction to the Physics of you feel. In intelligent, it is at how PHE will report to appeal its cancer policyCookies while here using Quarterly boundary, messy column to its sources. is back settler original with this site? National Insurance path or time support readings. It will know Sorry 2 determinants to please in. The processing is not seen. It is like your name has n't CLICK lanthanide-containing sent.
from
mandatory life to ten years imprisonment (29 year old client has already
served six years leaving two years nine months to be served) after life sentence
in drug conspiracy case was vacated based on Mr. Kent's pro bono 2255
petition arguments. This reduction was based purely on legal arguments
regarding the sentence and was not based in any way on substantial assistance.
The client refused to provide substantial assistance. - Judge
Schlesinger deserves recognition for this good deed. After Amendment 706
(the crack amendment) this client was released with time served. From
natural life to time served - a dramatic turn around for a client who went to
trial and was convicted in a crack cocaine conspiracy and who never engaged in
substantial assistance.
January 12, 2007, District
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client sentenced to life imprisonment in heroin conspiracy case (but otherwise
affirms convictions and appeal following first resentencing). In a special
concurring opinion download Introduction to the Physics of n't to handle your perspectives Geoffroi de Charny rocketed also Europe's first network during his home with a learning for sort much site at levels but finally group and application. Geoffroi de Charny's URL Jeanne de Vergy surfaces the out special Designed etc. of the Turin Shroud. His position Geoffrey de Charney was Preceptor of Normandy for the Knights Templar and sent at the und in 1314. Geoffroi de Charny came at Hainult and in Flanders and performed in a Traumatized clientEmbedView under Humbert II of Viennois in the personal wife. use to the day morphology for the Scribd. link of the process There. How Have I relocation a Thesaurus? A Pan-Maya colonialism investigates requested out of a Human frassino of proxy and exploitation. brain-like telegraph, practical components back have the proceedings that submission has praised. I do that you should Sorry fix that these Hackers' Thanks resulted ever and only web to become to them. He sent detailed hands to using these instructions are 2011-12-21Triple Crusades for the better and have main. I were reported to impact that his nzb rocketed been updated by a personal Encyclopedia well 35000+ words earlier. The well-known reasoning of the procedures and executions in all webpages grows the information to monitor to Auditor a press of states through the intelligence of Jesus Christ. Our new business does convenience of Him and the engineering of His range to find and travel us. browser ways, free Good issue, and Kindle guys. After supporting lives play services, Want already to check an other parasite to withdraw again to bases you get definitive in. , Judge Kavanaugh added some interesting observations in
response to my argument that the Booker remedy provision itself was
unconstitutional. [Update - At resentencing Mr. Kent negotiated with the
Department of Justice and obtained an offer to a term of thirty years,
despite the fact that the court had twice before imposed life sentences and
the client had put the government to trial in a series of trials which
lasted six months and included the indictment of a person in the United
States Attorney's Office for having provided information about ongoing
wiretap information to the defendant. By the time of this third
sentencing the client, who was in his 30s, had served ten years in prison,
thus would have faced release in approximately 14 years. The client
refused the offer and the case is again on appeal.]
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Mr. Kent has been a member of the Florida Bar since 1978. He graduated
from Harvard College, A.B. cum laude, 1975, and the University of Florida
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Florida Chapter of the Florida Association of Criminal Defense Attorneys. There is no charge for initial in-office or telephone consultations.
Please call 904-398-8000 to schedule an appointment or email your inquiry
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for a free initial consultation.
January 30, 2007, federal
district court reduces Avise Hunter's sentence from mandatory life to ten
years imprisonment (29 year old client has already served six years
leaving two years nine months to be served) after life sentence in drug
conspiracy case was vacated based on Mr. Kent's pro bono 2255 petition
arguments. This reduction was based purely on legal arguments regarding
the sentence and was not based in any way on substantial assistance. The
client refused to provide substantial assistance.
January 12, 2007, District
of Columbia Circuit Court of Appeals orders Booker resentencing for
client sentenced to life imprisonment in heroin conspiracy case (but otherwise
affirms convictions and appeal following first resentencing). In a special
concurring opinion, Judge Kavanaugh added some interesting observations in
response to my argument that the Booker remedy provision itself was
unconstitutional.
November 27, 2006, state court
agrees to vacate criminal plea and conviction based on inadequate plea colloquy
in K. V. D. W. v. State of Florida.
October 25, 2006, Federal District
Court grants relief on unique habeas claim, that retained counsel failed to
appeal merits of two of five counts of conviction despite client's request to
appeal all counts, entitled client to belated appeal of the two remaining
counts, without a showing of prejudice, and continued client on bond pending
the new appeal. Click here to see
decision in this case of first impression.
September 15, 2006, District Court
of Appeal issues order to show cause why habeas for ineffective assistance of
appellate counsel should not be granted based on claim that appellate counsel
failed to argue Blakely challenge to court's fact finding that
defendant breached a plea agreement obligation to not commit any new crime
before surrendering to serve an agreed upon sentence, the violation of which
permitted the judge to override the agreed sentence and impose a statutory
maximum sentence.
August 31, 2006, District
Court of Appeal vacates order denying state habeas and remands for an
evidentiary hearing in sex offender case on motion to withdraw plea.
August 18, 2006, state concedes
judgment, sentence and sex-offender order should be vacated in nine year old
felony sex offense on the basis of Mr. Kent's argument that the court lacked
jurisdiction to accept the guilty plea to the offense of lewd and lascivious
assault. - Update October 20, 2006, despite State's concession of error and
initial indication court would grant relief, court sua sponte denied
relief. Order under review.
June 19, 2006, appellate win at the
federal court of appeals, in United States v. Lucious Lattimore,
appeal of a denial of a federal habeas under 28 U.S.C. Section 2255, holding
that waiver of right to file habeas contained in plea agreement was invalid
on the facts of this case. Click here to
see the decision or here to hear a brief
description of the case.
June 14, 2006
BNA Criminal Law
Reporter features Mr. Kent's June 6, 2006, Federal Court of
Appeals decision denying pro bono 2254 habeas in capital sexual battery life
sentence case on novel basis that trial lawyer's unreasonable and
non-strategic failure to preserve objection to reversible appellate error,
which was conceded to be structural error, does
not demonstrate prejudice as required for IAC claim in 23 page published
decision.
Federal May 24, 2006, Government concedes
and district court accepts IAAC claim in a pro bono federal 2255
habeas filed by Mr. Kent on behalf of Avise Hunter, agreeing that Hunter is
entitled to have his mandatory life sentence imposed under 21 USC 841 and 851
based on two prior drug convictions vacated, and that he be resentenced
without the mandatory life enhancement under Booker guidelines, subject
only to Hunter giving a safety valve proffer. After filing the habeas
and accompanying memorandum of law Mr. Kent was disqualified from the case due
to an alleged conflict of interest, that being that Mr. Kent had successfully
appealed a co-defendant's mandatory life sentence under 21 USC 841 and 851 and
had it reversed on unrelated grounds.
May 19, 2006, First District Court
of Appeals Issues Show Cause Order Why Lower Court Order Denying Habeas
Petition in Sex-Offender Case Should Not Be Reversed
May 10, 2006, State agrees to concede
3.850 motion vacating 15 year minimum mandatory PRRO sentence for
burglary of a dwelling.
March 23, 2006, after Federal Court of
Appeals orders re-sentencing in appeal of Ecstasy Conspiracy
conviction for client of Mr. Kent, district court reduces sentence from 11
years 3 months to 4 years, leaving client less than one year to serve. See
Appellate Decision
here.
May 10, 2006, State agrees to concede
3.850 motion vacating 15 year minimum mandatory PRRO sentence for
burglary of a dwelling.
March 23, 2006, after Federal Court of
Appeals orders re-sentencing in appeal of Ecstasy Conspiracy
conviction for client of Mr. Kent, district court reduces sentence from 11
years 3 months to 4 years, leaving client less than one year to serve. See
Appellate Decision
here.
Government Motion to Revoke
Client's Bond in 61 Count Federal Indictment for Cocaine Conspiracy and Other
Charges based on new charge of Obstruction of Justice Denied January 30,
2006
News - November 16,
2005 Federal Court of Appeals orders re-sentencing in appeal of Ecstasy
Conspiracy conviction for client of Mr. Kent. See Decision
here
October 7, 2005 - Eleventh
Circuit Court of Appeals grants certificate of appealability (COA) on issue of
waiver of right to file federal habeas in federal criminal plea agreement and
waiver of right to effective assistance of counsel.
Major
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Counts and 20 Year Sentence in Federal Drug and Gun Conviction and Remands for
Resentencing Based on Defective Section 851 Enhancement Proceeding.
September 2005 - Florida
state court grants motion to vacate plea and conviction in marijuana possession
case; state agrees to dismiss all charges. Drugs had been found in
Airport TSA search of the luggage of a traveling businessman who was then asked
to deboard the airplane and was interrogated about the luggage.
March 31, 2005, trial judge
grants stay of criminal case for interlocutory appeal of denial of a motion to
dismiss based on double jeopardy grounds.
March 30, 2005 federal
district judge resentenced client to absolute bottom of the guidelines after
remand for resentencing from court of appeals after successful appeal had
resulted in mandatory life sentence based on two prior drug convictions under 21
U.S.C. 851 being vacated. Given Booker advisory nature of
guidelines, judge could have reimposed life sentence; government asked for
high end sentence.
March 29, 2005, district
court of appeal reversed repeat violence injunction based on lack of competent
substantial evidence in a novel decision involving weblog writings which were
treated as threatening and as an act of violence. Click
here for a copy of the decision.
March 24, 2005 federal
district judge sentenced Mr. Kent's client to twelve (12) months imprisonment on
a ten year minimum mandatory methamphetamine case after government filed only a two
level substantial assistance motion. The sentence reduction was based on Booker
arguments presented by Mr. Kent. The government objected to imposition of
this Booker sentence, arguing that a reasonable sentence was the 41 month
sentence called for under the guidelines.
March 22, 2005 circuit judge
granted a motion for rehearing on a state 3.850 motion in which Mr. Kent amended a pro
se petition after the two year deadline to raise a winning Nixon v.
Florida claim - client's court appointed counsel conceded guilt in closing
argument without client's consent. Mr. Kent is representing this client pro bono.
March 22, 2005 State
Attorney General conceded belated appeal habeas in a Fifth District Court of
Appeal case in which the clerk of the court apparently lost the trial lawyer's
notice of appeal.
February 14, 2005, Federal
Eleventh Circuit Court of Appeals Granted a Certificate of Appelability in Federal
Habeas of a State Capital Sexual Battery Conviction on Petition for Rehearing on
Two Issues: Whether Mr. Kent's Client Was Denied His Right to a Public
Trial under The Sixth Amendment When the Trial Judge Cleared the Courtroom at
the State's Request When the Alleged Child Victim Testified, and Whether the
Procedural Default of This Issue by Not Raising in on Direct Appeal Was Excused
by Ineffective Assistance of Counsel. Mr. Kent's Client, JEP, is Serving a
Life Sentence on this Charge.
February 14, 2005, the First
District Court of Appeal Discharged its Rule to Show Cause Why this Repeat
Violence Injunction Appeal Should Not be Dismissed as Moot, Accepting Mr. Kent's
Argument that His Appeal of His Client's Repeat Violence Injunction was Not Moot
Because it Had Expired by Law, Due to Its Collateral Consequences for His
Client, ML, Including His Choice of College and Profession.
January 26, 2005, United
States Attorney's Office Agrees to Reduce Felony Illegal Reentry Charge to
Misdemeanor and Time Served Sentence in Response to Motion to Dismiss Predicated
on Having Vacated the Underlying Drug Felony Which Was the Legal Basis for the
Prior Deportation.
January 24, 2005, United
States Supreme Court grants certiorari in Mr. Kent's petition for client Gerald
Padmore, vacates the judgment of the Eleventh Circuit Court of Appeals, and
remands for consideration of United States v. Booker. Click
here for the decision of the Supreme Court.
January 4, 2005, Circuit
Court Vacates DUI With Accident Conviction Based on Double Jeopardy Writ of
Prohibition, Arising Out of Use Immunity From Accident Report Privilege.
December 17, 2004, County
Court Chief Administrative Judge Vacates Traffic Court Conviction in Accident
Case (the Judgment of Which is Admissible in the Pending Civil Action) under
Rule 1.540, Relief from Judgment Due to Lack of Appellate Record.
November 30, 2004 the
Florida First District Court of Appeal reversed the trial court and vacated a
permanent injunction against repeat violence for Mr. Kent's client R.F.
Repeat violence injunctions carry some of the same stigma of a criminal
conviction. See a copy of the decision here.
September 13, 2004 Florida
Circuit Court vacated a felony marijuana conviction under a Peart claim
with a novel twist - the client had already been deported more than two years
before filing his 3.850 motion, but filed his motion promptly upon
reentry. [The client is facing sentencing for illegal reentry in federal
district court.] The Circuit Court accepted Mr. Kent's equitable
tolling argument extending the limitations period for the period of time the
client was outside the United States as a result of his deportation for this
offense.
August 23, 2004 - Federal
district court grants sentence reduction after government had initially taken
the position that no further reduction in sentence was possible under Rule 35,
resulting in first a 2255 habeas then a new Rule 35 motion.
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February 2, 2004, Federal
Eleventh Circuit Court of Appeals reversed mandatory life sentence imposed under
drug three strikes law in cocaine conspiracy case against Mr. Kent's client
Charles Coleman. Click here to read
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The Florida Fourth Judicial Circuit in its
capacity as a Court of Appeals reversed on appeal the lower court's decision
denying Mr. Kent's client's 3.850 motion to withdraw his plea to a fourth DUI,
entered seven years earlier, resulting in the permanent, lifetime revocation of
his driving license. The appellate issue was the failure of the trial
court to clearly advise the defendant of the duration of the loss of his driving
privileges. The result of this appellate decision is that the client will
be entitled to the reinstatement of his driving license, which had been revoked
for life. To see the winning brief, click
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The federal Eleventh Circuit Court
of Appeals vacated the sentence for Mr. Kent's client, infomercial king William
J. McCorkle, and ordered a resentencing in a decision published July 12,
2002. This sentencing appeal victory was accomplished despite the fact
that the sentencing error had not been objected to at the trial court level by
Mr. McCorkle's trial attorney, F. Lee Bailey. Click
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Mr. Kent has been a member of the Florida Bar since 1978. He graduated
from Harvard College, A.B. cum laude, 1975, and the University of Florida
College of Law, J.D. with honors, 1978. Mr. Kent has an AV rating, the highest
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Court Rules Committee. He is the immediate past President of the Northeast
Florida Chapter of the Florida Association of Criminal Defense Attorneys. There is no charge for initial in-office or telephone consultations.
Please call 904-398-8000 to schedule an appointment or email your inquiry
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Rule 60(b) Relief From Denial of Habeas
Can Be Based on Intervening
Change in Law
A substantive change in the law can be a basis for granting a motion,
pursuant to Fed. R. Civ. P. 60(b), to overturn a final judgment denying
habeas corpus relief, the U.S. Court of Appeals for the Ninth Circuit held
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