Saying the judge should send a message to other attorneys, New York prosecutors are calling for a “substantial” prison sentence for Michael Avenatti for defrauding Stormy Daniels—but also one below the guideline range.

A 12-page memorandum filed Thursday by the Southern District of New York U.S. Attorney’s Office neither requests a specific sentence nor explains the recommendation for less prison time than the 65 to 75 months for which it says Avenatti qualifies.

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