IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA )

)

v. ) 3:17-CR-00065-CRB-1

)

BARRY CLINTON WILLIAMS )

SENTENCING MEMORANDUM

BARRY CLINTON WILLIAMS, pursuant to N.D. CAL. L. R. 32-

5(b), respectfully submits the following for this Court’s consideration, 

regarding imposition of sentence, scheduled for June 7, 2017, at 10:00AM, 

pursuant the factors enumerated in 18 U.S.C. § 3553(a). 

Mr. Williams affirms, and agrees, with the factual assertions contained 

within the Offense Conduct section of the fully resolved Final Presentence 

Investigation Report (PSR) (ECF No. 9), as well as those representations made 

within the Government’s Sentencing Memorandum (ECF No. 10). Further, 

Mr. Williams prays this Court impose the affirmatively recommended

sentence as proffered by both the United States Probation Office (USPO), via 

the PSR (ECF No. 9), and the Government, via its Sentencing Memorandum 

(ECF No. 10), and sentence Mr. Williams to a term of probation of three 

years.

Case 3:17-cr-00065-CRB Document 11 Filed 05/31/17 Page 1 of 5
In support of the aforesaid disposition, Mr. Williams impresses upon 

this Court his woeful recognition of wrongdoing, and his unreserved 

acceptance of responsibility. As is indicative within his personal statement, 

attached to the PSR (PSR 5, ECF No. 9), Mr. Williams has unquestioningly 

learned his lesson, and remains regretful for his actions. 

Without excusing his conduct, or minimizing the same, Mr. Williams 

avers that he is a young man, in his mid-twenties, and is the, quite 

remarkable, byproduct of an extremely challenging childhood. Without the 

benefit of parental guidance—imparting the wrongs and rights of life, and 

exemplifying sound morals and ethics—Mr. Williams has, nevertheless, led a 

drug free, law abiding, life, achieving an Associates Degree, and maintaining 

regular employment throughout. Despite an absent father, and a drug 

addicted mother—both of whom he lost at an early age—he is an unreserved 

family man, dedicating his life to caring for those who subsequently took care 

of him. To this day, his Aunt and Uncle rely on Mr. Williams’ support on a

daily basis, as they are literally completely dependent upon his guardianship;

he is a mature young man, who uninhibitedly, and selflessly, supports his 

loved ones at the obvious expense of a normal social life, in his twenties. 

Case 3:17-cr-00065-CRB Document 11 Filed 05/31/17 Page 2 of 5
However, despite his bittersweet achievements, and his praiseworthy

attributes, Mr. Williams is only human. In an attempt to pursue his business 

aspirations, he took a risk—like so many others have done before him—and, 

like many do, his efforts failed, leaving him in significant financial debt.

Desperate times often precede irrational ideas, and Mr. Williams, admittedly, 

acted upon them, when he should have known better. Nonetheless, what is 

done is done, and he knows that he shall inevitably endure the consequences 

of his actions—albeit, a felony conviction, familial disappointment, 

employment hardship, or the many other collateral corollaries he is quite 

cognizant. Mr. Williams has realized the inherent adverse effects of his poor 

decision-making.

Mr. Williams has no criminal history, and despite his enduring 

immense personal privation and hardship throughout his young life, he 

remains a commendable person; he retains great respect for the law, and has 

wholly learned his lesson; the instant prosecution, and the forthcoming 

sentence, have impressed upon him all the deterrence needed so to avoid 

such mistake again; and, he has never hurt anybody—in fact, he has only 

helped others—and the public is far better off with him in it, as contributing 

member of our society. He is tremendously apologetic for his actions. 

Case 3:17-cr-00065-CRB Document 11 Filed 05/31/17 Page 3 of 5
Based on the foregoing, Mr. Williams respectfully prays this Court 

sentence him to three years of probation, as affirmatively recommended by 

the both the Government and the United States Probation Office.

Date: May 31, 2017

Respectfully submitted,

/s/ Murdoch Walker II, Esq.

Murdoch Walker II, Esq.

Ga. Bar # 163417

National Federal Defense Group

P.O. Box 8281, Savannah, GA 31412

M 843.540.7903 | F 866.819.7859

mwalker@nationalfederaldefense.com

www.nationalfederaldefense.com

Case 3:17-cr-00065-CRB Document 11 Filed 05/31/17 Page 4 of 5
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA )

)

v. ) 3:17-CR-00065-CRB-1

)

BARRY CLINTON WILLIAMS )

CERTIFICATE OF SERVICE

I, as attorney for Barry Clinton Williams, certify that on May 31, 2017, I

electronically filed the foregoing SENTENCING MEMORANDUM with the 

Clerk of the United States District Court for the Northern District of California 

by way of the CM/ECF system, which automatically will serve this document 

on the attorneys of record for the parties in this case by electronic mail.

Date: May 31, 2017

Respectfully submitted,

/s/ Murdoch Walker II, Esq.

Murdoch Walker II, Esq.

Ga. Bar # 163417

National Federal Defense Group

P.O. Box 8281, Savannah, GA 31412

M 843.540.7903 | F 866.819.7859

mwalker@nationalfederaldefense.com

www.nationalfederaldefense.com

Case 3:17-cr-00065-CRB Document 11 Filed 05/31/17 Page 5 of 5