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Wednesday, February 19, 2020

Noon until 2:30 p.m.


Ceremonial Courtroom 3A, United States Courthouse


No food or beverage is allowed in the ceremonial courtroom, please eat prior to this event

3.0 hours of CLE credit is pending from The Florida Bar

Please RSVP to Margaret_Bundy@fd.org if you plan to attend

When RSVP’ing – Please include the date, time, location, and whether you are a member of CFACDL



Noon – 12:45 p.m.  Get Real! Pseudo Counts, The Charges you Never Saw Coming: If the factual basis in a defendant’s plea agreement establishes the commission of additional, uncharged offenses, the guidelines require that the defendant be treated as if the district court convicted him of those offense.  These added offenses are known as “pseudo counts,” and we’ve seen an uptick in Probation’s use of them.  This presentation will help you spot pseudo counts early, allowing you to better advise your client about whether to plead guilty and what his guidelines range may be at sentencing.  Conrad Kahn, Federal Defender Attorney, Appellate Division


12:45 – 1:25 p.m.    Getting Connected with the 4-level “in Connection” Guidelines Enhancement under 2K2.1: In a typical sentencing for a conviction under 18 U.S.C 922(g), for being a felon in possession of a firearm, one of the most onerous guidelines enhancements is the four-level enhancement under 2K2.1(b)(6)(B), when the defendant: (1) “used or possessed any firearm or ammunition in connection with another felony offense”; or (2) “possessed or transferred any firearm or ammunition with knowledge, intent, or reason to believe that it would be used or possessed in connection with another felony offense.” This presentation offers a primer on how and when the “in connection” enhancement applies and the recent 11th circuit case law discussing the enhancement, and also provides litigating practice pointers to defender against application of the “in connection” enhancement. Adeel Bashir, Assistant Federal Defender, Appellate Division


1:25 – 1:55 p.m.       What to Expect when you’re Not Expecting (an Upward Variance): Upward variances are becoming more common place in this District. In this session we will discuss how to prepare for and challenge an upward variance. Jim Skuthan, Acting Federal Defender, MDFL


1:55 – 2:30 p.m.       Federal Practice Issues: An overview of the Orlando Division’s federal practice issues. Nicole Mouakar, Supervising Assistant Federal Defender, Orlando Division