The New York Council of Defense Lawyers (the “NYCDL”) would like to thank the Sentencing Commission (the “Commission”) for the opportunity to present our views on the 2013 Proposed Amendments to the Sentencing Guidelines (the “Guidelines”), policy statements, and official commentary. We are a professional association comprised of more than 240 experienced attorneys whose principal area of practice is the defense of criminal cases in federal court. Among our members is a former United States Attorney and former Assistant United States Attorneys, including previous Chiefs of the Criminal Divisions in the Southern and Eastern Districts of New York. Our membership also includes current and former attorneys from the Federal Defender offices in those districts. ...