In a post-Booker world, most powerful sentencing submissions lay out a client’s history and characteristics with a comprehensive sentencing presentation: a detailed memorandum that puts the offense into the context of the client’s life, powerful objections to the presentence report, character letters from an array of individuals who know the

  This is a very common response when I suggest to attorneys that we obtain a psychological evaluation of our client in preparation for sentencing.  Of course there may be reasons a psychological evaluation would not be beneficial.  For example, if your client will be testifying against a co-defendant in