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U.S. v. Gartner, No. 4:CR97-3070 (D.Neb.) (5 F.Supp.2d 1060) (May 14, 1998) (Judge Richard G. Kopf)

Case held that the timing of arrests in two prior controlled substance convictions resulted in an artificial increase in the defendant's offense level and criminal history category, justifying a four-level downward departure.

 

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