MEMORANDUM
HARRINGTON, Senior District Judge.
The defendant, Nicholas Otey, pled guilty to a three-count indictment charging him with distribution of cocaine base (widely known as "crack"), a violation of 21 U.S.C. § 841. Probation assigned him a criminal history category of III and determined his base offense level under the Guidelines Manual effective November 1, 2007, to be 24 because he had distributed a total of 5 grams of cocaine base....
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