Fill and Sign the Memorandum in Support of Motion to Reconsider Sentence Louisiana 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 Defendant, ________________ , 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 Defendant, ________________ , 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 complex psychological issues including 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 Defendant, ________________ , 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 relationship with him during his time of need. CONCLUSION The Defendant, ________________ , 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, ________________