Fill and Sign the Louisiana Memorandum in Support of Motion to Reconsider Sentence Form

___________________ ________________ ________________ ____________ , LOUISIANA _______ ________________ TELEPHONE ( ___ ) _______ FAX (___ ) _______ _______ ___ , 20 ___ Hon. ________________ District Judge ________________ ________________ ____________ , LA _______ RE: State of Louisiana vs _______________ Docket No. ________ MEMO IN SUPPORT OF MOTION TO RECONSIDER SENTENCE Dear Judge ____________ : STATEMENT OF THE CASE On _______ ___ , 20 ___ , ________________ plead guilty before the Honorable ________________ to one (1) count of ________________ , under Docket Number ___ . At that time, the Court ordered a pre -sentence investigation and set a sentencing date of _______ ___ , 20 ___ . ACTION OF THE COURT On _______ ___ , 20 ___ , ________________ appeared before the Honorable ________________ for sentencing on one (1) count of ________________ . On _______ ___ , 20 ___ , the Defendant, ________________ , was sentenced to serve _______ (___ ) years at hard labor. ARGUMENT The D efendant, ________________ , argues that the trial Court should consider several mitigating factors in reviewing his sentence for excessiveness: 1. Although failing to establish a defense to the crime of ________________ , the D efendant, ________________ , asks that the Court consider in mitigation the fact that , at the time of the commission of the offense, the Defendant was dealing with several c omplex psychological issues includ ing the death of his wife and son and the declining health of his other wheelchair - bound son, ________________ , afflicted with a debilitating spinal cord disease. 2. The Defendant, ________________ has taken responsibility for his actions by both pleading guilty to the charge and by agreeing to pay for child support and health insurance for the child, ________________ . 3. The D efendant, ________________ , has been evaluated for both psychiatric and chemical dependency problems. Although said evaluation stated ________________ did not need treatment, ________________ has successfully completed three (3) separate substance abuse programs while incarcerated. 4. The excessive sentence poses an unusual hardship upon ________________ and his one (1) wheelchair -bound son, in that, he is unable to care for him and maintain a healthy rela tionship with him during his time of need. CONCLUSION The D efendant, ________________ , respectfully requests that this Court reconsider the sentence imposed in light of the above mitigating factors and asks that this Court reduce the sentence of ________________ accordingly. Sincerely, ________________