warranting a downward departure provided that the efforts are so exceptional as to remove the particular case from the heartland in which the acceptance of responsibility guideline was intended to apply.”); United States v. Lieberman, 971 F.2d 989, 996 (3d Cir.1992) (“[A] sentencing court may depart downward when the circumstances of a case demonstrate a degree of acceptance of responsibility that is substantially in excess of that ordinarily present.”). But see United States v. Severino, 454 F.3d 206, 210 n. 2 (3d Cir.2006) (questioning validity of Lieberman in light of recent amendments to the Guidelines). 5 . Perhaps tellingly, Samuelsen does not argue that the District Court failed to give full consideration to the factors under 18 U.S.C. § 3553(a), cf. Severino, 454 F.3d at 211 (<HOLDING>), or that his final sentence is "unreasonable,”
holding that trial court must consider both statutory and nonstatutory mitigating factors holding that district courts may consider extraordinary acceptance of responsibility in weighing statutory factors holding that a district courts failure to consider the 18 usc  3553a factors was plain error relying on gall holding that a court may rely on factors listed in ussg  5h116 to justify a departure in extraordinary circumstances holding that in exercise of its discretion district court may consider factors such as number of requests made and number of documents withheld