The following excerpt is from United States v. Torres, No. 10-3029-cr (2nd Cir. 2011):
A defendant seeking a two-point offense-level reduction under 3B1.2(b) bears the burden of demonstrating that he is "substantially less culpable than the average participant" in the crime of conviction. U.S.S.G. 3B1.2 cmt. n.3(A); see United States v. Carpenter,
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