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ed States v. Jungers, II Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, othe
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
ed States v. Jungers, II Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, othe
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
ed States v. Jungers, I1 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, othe
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
ed States v. Jungers, 11 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, othe
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
ed States v. Jungers, II Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, othe
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
ed States v. Jungers, 11 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, othe
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
ed States v. Jungers, 11 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, othe
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
ed States v. Jungers, II Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, othe
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
ed States v. Jungers, II Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, othe
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
ed States v. Jungers, II Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, othe
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
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