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understand what his family members and friends are going through. i can't. it's not enough for a departure to probation for a second-degree murder. we believe, your norhonor, thes four aggravating factors and findings the court made certainly justify an upward departure because there are four of them standing alone by in a sense not overlapping but coming together to show this is not the typical second-degree murder. this is egregious. this justifies a double upward departure. from the top of the box which is 180 months, we're asking the court to double departure recognizing all four factors to 360 months. as i mention, this is sentencing. this is the time for victims. this is the time for the loved ones of the victim and the

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