YOUNGSTOWN, Ohio (WKBN) — The attorney for an Illinois woman convicted in October in federal court of having four kilos of cocaine said in a sentencing memorandum she should get less than five years in prison because she has no prior criminal record and she was only a courier for someone selling drugs.

Chicago-based lawyer Beau Brindley also wrote that his client, Tashe Goins, 32, is a mother of two children who has at times worked two jobs to make ends meet.

Goins is set to be sentenced Wednesday before U.S. Judge Sara Lioi in the U.S. Northern District Court of Ohio after a jury convicted her of one count of possession with intent to distribute cocaine.

The charge stems from a June 16, 2020, traffic stop on Interstate 80 in Braceville when troopers with the Ohio State Highway Patrol pulled over a car Goins was driving for a lane violation.

Goins told the trooper she was on her way to Pittsburgh from Chicago, according to an affidavit in the case.

A police dog was brought in and detected an odor of narcotics, the affidavit said. Troopers searched the car and found the cocaine in a suitcase in the back seat, according to the affidavit.

Judge Lioi earler in the case had denied a suppression motion by Brindley and also denied a motion by Brindley in December to overturn Goins’ conviction.

Brindley pointed out to Judge Lioi that Goins was convicted because prosecutors were able to convince the judge to instruct jurors that they could find Goins guilty based on “deliberate knowledge,” which meant the government did not have to prove Goins had actual knowledge the cocaine was in the car to convict her.

Brindley wrote that Goins was truthful and cooperated with investigators after she was taken into custody with the limited information that she had by the people who asked her to transport the luggage in which the cocaine was found.

Even though Goins chose to go trial and contested the fact she was guilty, Brindley contends that because prosecutors had to use a deliberate ignorance strategy to convict her she did accept responsibility because she cooperated as much as she could and because of that she should receive a lenient sentence.