UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

NORTHERN DIVISION 

UNITED STATES OF AMERICA, Case No. 15-20155 

 Plaintiff, Hon. Linda V. Parker 

-vsDANA COOPER, 

 Defendant. 

___________________________________/ 

DEFENDANT’S SENTENCING MEMORANDUM 

AND REQUEST FOR VARIANCE

 Defendant, Dana Cooper, by his attorney Joan E. Morgan, says in 

support of his Sentencing Memorandum and request for Variance: 

1. Mr. Cooper entered guilty pleas to Felon in Possession of a Firearm, 

18 USC 924(a)(2) and Possession of a Firearm in Furtherance of a Drug 

Trafficking Crime, 18 USC 924( c). Sentencing is scheduled for August 26, 

2015 at 11:00 a.m.

2. Mr. Cooper is 39 years old, an age which has a low recidivism rate. 

He was on state parole from 2012 to 2014 from a 2004 conviction, and he was 

compliant with all of his parole conditions. During his time on parole, he 

maintained employment and rehabilitated two houses in Flint for rental 

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property, but then reverted to selling drugs (see his letter, attached as Exhibit 

A). At the time of his arrest, he was completely cooperative with the agents 

and signed a written statement assuming responsibility for the drugs and guns 

in the home. He has remained steadfast in his acceptance of guilt and in his 

remorse throughout the pendency of this case. 

 3. Mr. Cooper comes from a close, loving family. He has seven sisters, 

most of whom have written letters in support of him (as have some of his 

nieces and nephews); they are attached to this pleading as Exhibits F to M. 

His mother also wrote a letter (attached as Exhibit E), acknowledging her 

shortcomings in raising her children, as she and her husband were drug users. 

Several other relatives have also written letters which are attached to this 

pleading. 

 4. Mr. Cooper has remained close to his two teenage sons; his son 

Diego’s letter is attached hereto as Exhibit B. For twelve years, he has been 

in a steady relationship with Ameishia Calloway. She and her 12 year old 

daughter, Amyrionna Quyinn, have written letters which are attached as 

Exhibits C and D. 

 5. The mandatory sentence for Count One is five years. The guidelines 

for Count Two are 30 to 37 months. Mr. Cooper is seeking a sentence of one 

day, credit for time served, for Count Two. This sentence would be sufficient, 

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but not greater than necessary, to fulfill the goals of 18 USC 3553(a). 

 Respectfully submitted, 

 s/Joan Ellerbusch Morgan 

 Legal Aid and Defender Assn. Inc. 

 Federal Defender Office 

 Attorney for Defendant 

 105 Paterson Building 

653 South Saginaw Street 

 Flint, Michigan 48502 

 (810) 232-3600 

 joan_morgan@fd.org

 (P-34482) 

 

 

Dated: July 28, 2015 

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CERTIFICATE OF SERVICE 

 I hereby certify that on July 28, 2015, I electronically filed the attached 

document using the ECF system which will send notification of such filing to 

the Assistant U.S. Attorney, Christopher Rawsthorne, and I personally served 

the document on Probation Officer Nichole Collins. 

 s/Joan Ellerbusch Morgan 

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