in this case in her briefly argued all the possibilities of how the government was making this into a conspiracy essentially from my reading of the government's breach i believe they conceded that the only person that does qualify as a potential going to focus on a meeting under conspiracy has had a very long history of in our opinion being overused and broadly stretched in this case i think it's been stretched too far to include indeed anders as a coconspirator and you know i find that pretty interesting look she drove him to chicago on two to four occasions to pick up her own from his supplier she rented cars for him on other occasions for the same purpose she drove them around madison wisconsin on multiple occasions when he was making sales to his customers she allowed him to store and pack her in her inner home she even package the her own herself for resale in one instance and following its arrest she removed the store to her owing from its hiding place and gave it to a friend for disposal so there's far more here than mere association on her part in a variety of ways she knowingly deliberately and it seems to me pretty willingly chose to give concrete is since to this person and his heroin but whatever her incentive was she agreed with thomas to commit illegal acts and so what about it it's not a conspiracy i think that we're talking about willful agreement and the question is whether she will fully did any of this that trips to chicago she testified willful it understood i knew it she was doing she know that she's driving and she knows that she's got her own in the car right i don't think she knew all the time that she had here in the dark so i don't mean all the time right i think she didn't in various occasions that she was kind of her word for this guy and i think she does the worst possible absence of willfulness i think she was forced into many of the actually did he told her that he would be physically violent to her if she didn't go to be forced into it she could have gone to the police at any point he was in the you didn't have twenty four hour surveillance over i think she could have but when the police did come i think her conduct shows that she was afraid she lied to them first and said you know that she didn't know anything about it and i think she was afraid or just trying to help him out keep him out of trouble i heard testimony at trial does not seem to be of a woman who's willing to help mr thomas out she was angry woman she do not dictate he threat to the maker she absolutely threatened her she he she was not always in his presence when she was driving around with  wishing no and no and i show why didn't she just you know quit i think at some point she did but then going to going to the police and saying i'm living with someone who's dealing factor had it's always difficult because certain actions they were take on really need to be considered part of their personal relationship with the malefactor  are similar but i see a line there and that's where i think the distinction where do you think the line is i think the line is that hunt went on the trip in that hunt case willingly knowing exactly what the purpose of the trip was miss do believe i know you are and i'm getting out of the car to go do something illegal rob a bank robbing a liquor store i'm driving because later on we're going to dinner with somebody he gets back in the car i realize what he has done i may in fact get out of the car and say no i'm done here but if i'm in a city that i don't know well i without consideration you totally so we were just excusing all sorts of criminal behavior i think it does not take into account the relationship between women and men in these high situation i get absolutely the conspiracy has got to be stopped somewhere and someone who doesn't willfully participate in the illegal object cannot because you're all wet i think those pressures you would limit criminal punishment to some kind of pure say that someone someone had no never did under oath under pressures from other people but  just under his own desire for why they are killing people or what you know i permitted to people who actually participate in the agreement to commit a crime and i don't believe she did that in this  of course she did well that certainly our argument based on the facts of this case i'll talk a little bit about maintaining premises start ripple your question before one's to whether as a career offender that does obviously make this a more difficult case but the main didn't premises and hanson was part of the original calculation which the judge didn't want to part from hash i'm sorry i didn't hear the maintaining a premises enhanced version right and so it's part of the original calculation he was then considered to be a the judge essentially rejected the career offender guidelines which are quite high they were three sixty to life and ultimately gave him a much lower sentence i believe to sixteen although i know i'm getting the two cases messed up but it was a lower than guidelines ones it's within the think that's a valid reason to impose an enhancement but when you have something that's really tipping the scales fifty fifty and i don't think this is that case even i think it was more a primary residence than anything else do we know what the right i absolutely cannot see a problem because not only did he refer to milly store her one in the home underneath that t v stand but he was observed by both andrews and her former roommate cutting packaging heroin in the residence and indeed that roommate tina were trina her testimony was that she saw him do and of course after you know following his arrest they found a digital still i mean material twenty two sandwich bags with their corners out i think i mean there was a sound basis here for a judge conley finding that thomas had maintained the premises for the storage and distribution of her own i think if we're going to look at the guideline the guidelines show several factors and what you're saying is absolutely true but that's merely one of the factors that shoe that really go against that is that he did you did not have any possessory interest in the residence he did not even have a key to the resident she had to let him enter now so for him using a premises as well i mean i can't think of a circuit that has been held that it's not necessary for a defendant to have had an ownership or leasehold interest in the property in order for the guideline to apply i don't think because look that would enable a defendant to avoid culpability under the guideline by using someone else's residences a stash house just like he did here and we often see that with with girlfriends being the stash house yes so your position is  well i mean i'm here to represent mr thomas and unfortunately that that comes with the arguments i'm making i'm here to also argue that there's a certain type of relationship that the guidelines i actually now recognize as an enhancement into the one point one b fifteen defendants can get it if they use someone in a romantic relationship to forward their drug activity and it is a recognised difficulty in these cases i'm way beyond my time and i think the court for the col won't go through it judge rove nurse hit on all the things that i need to andrews did for this defendant to further his drug distribution again numerous numerous times he drove him around to me it's got to be more than ted and look it's going to be some indication that they they did willfully jordan conspiracy snack to willie during the conspiracy and that gets difficult when people quasi familial relationships with the principal and can you help me out when we redraw the lines how we are to cure well i think you have to look you have to look at everything and this person in this particular chicago he had i think the testimonies thousands of dollars on him he was making telephone calls to is a heroin source and she was there listening she testified  guess all i can say you have to look at everything the words in the actions of the conspirators in this case and the fact that she packaged here one front was there was driving him around so that that would assist him curry favor with them so they can remain boyfriend girlfriend that's a perfectly you know that's a reason for why she did this in other reasons could be the thrill of just committing crimes so the whole financial or profit  more of really is irrelevant in this case going to the money and clyde correct going to the second issue the enhancement for maintaining a drug house the issue here is it was not objected to t told his mother telling media to check my stash spots and to get rid of it i mean stash house stash box and that's that something very telling in regards to that particular and handsome and he just said yes she tie their reasoning to the fact these are the drug guidelines so i am sentencing him here the court specifically went through the thirty five fifty three eight factors and say look at eighteen years to me that sounds appropriate for this