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by: Ryan • July 25, 2001 • no comments

I have previously written two posts: here and here - both subsequently updated - on merging Felon in Possession and UUW, when the former also alleges the gun minimum. The impact, ironically, is to leave your client with only a non-person conviction.

Though I laid out the analysis in those two posts, I did not include a memo. Well, here's a motion entitled Gun minimum, UUW and merger arguing for the merger of Burglary I and UUW, when the burglary count also includes the gun minimum allegation.

Enjoy! Please let me know the outcome if you make the argument.