he plead guilty to specific charges including the specific acts that encompass the racketeering conspiracy, what are you talking about? A sentencing memorandum is what a prosecutor submits to the judge to show why he should be sentenced at the high point of the guidelines and letters from family and friends and "good acts" and denial of charges(when you dont plead guilty, and its hard to deny surveillance and financial records) is what a defendant submits to a judge in hopes of a downward departure from the sentencing guidelines...remember guidelines are just that, the judge has discretion to sentence someone above or below the guidelines as he sees fit.....