TORRUELLA, Circuit Judge.
Following a two-day trial, a jury convicted defendant-appellant Gilberto Brown ("Brown") of two counts of distribution of cocaine base, in violation of 21 U.S.C. § 841(a)(1). Brown was sentenced to 70 months' imprisonment. The district court based the sentence on a finding that the substance Brown distributed was crack cocaine and that, given the nature of his offense and his criminal history, 70 months was a reasonable sentence to impose...
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