The need for the client to remain in the United States, productively employed and therefore able to make restitution payments can constitute a powerful argument in favor of obtaining a sentence that does not cause the client to be removed from the United States.

SENTENCE - SENTENCING GUIDELINES - MITIGATING CIRCUMSTANCES
Gall v. United States, __ U.S. __, 128 S.Ct. 586 (2007) (while an appellate court may take degree of variance into account in reviewing reasonableness of a sentence outside advisory Guidelines range, there is no rule that requires "extraordinary" mitigating circumstances to justify sentence outside Guidelines range), abrogating United States v. Claiborne, 439 F.3d 479 (8th Cir. 2006).