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U.S. v. Kemmish, No. 96-50241 (9th Cir.) (120 F.3d 937) (July 15, 1997) (Judge Edward Leavy)

Case held that defendant's activities as a "trafficker" in child pornography did not constitute a pattern of sexual exploitation that would support a sentence enhancement under § 2G2.2(b)(4).

 

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