Supplemental Exhibit to re 91 Motion Injunction Pending Appeal/ Motion — USA v. Lattany (Dkt. 94, D. Colo.)

Summary

Dejane Reaniece Lattany filed this supplement on 11/05/24 (Document 94, Case No. 1:23-cr-00074-NYW) with exhibits marked for a 2255 motion, an injunction and an emergency compassionate release request. The exhibits include an ECG printout from the Carswell Clinic dated 30-Aug-2024, a BOP inmate locator printout and pages of a plea statement carrying a Case No. 1:23-cv-03027-SBP header, and a January 31, 2024 letter from the Denver Sheriff Department to FCC Victorville lodging a detainer for Denver District Court Case No. 22CR6134. An amended Denver District Court judgment shows a plea on 5/22/2023 to Count 3, MEDICAID-ALTER/FALSE/CONCEAL RECORD, and a 2.00 YEARS Department of Corrections sentence to run concurrently with federal case 23-CR-74-NYW. It also includes a book excerpt on Carswell Federal Medical Center and messages to medical staff, one dated 10/6/2024.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

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Case No. 1:23-cr-00074-NYW Document 94 filed 11/05/24 USDC Colorado pg 5 of 27
[handwritten, rotated 90 degrees] Exhibit 1
[handwritten notes, rotated 90 degrees] 8/26/2024 [illegible] HR 56 she told them h/o 1st degree AV block, echo, holter, CXR, Vitals [illegible] [initials]
[image: electrocardiogram (ECG) printout, rotated 90 degrees]
PMC: Carswell Clinic
30-Aug-2024 10:45:34
Lattany, Dejane 34years Black Female
ID: 51090-510 [handwritten beside it: 51090-510]
Vent. rate 49 bpm
PR interval 194 ms
QRS duration [illegible]2 ms
QT/QTc 474/428 ms
P-R-T axes 49 38 42
Marked sinus bradycardia
Abnormal ECG
Technician: Tmasters Rn
Test ind:
Referred by:
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FMC Carswell
| J Street, Building 3000, Fort Worth, TX 79127
| Tel: 817.782.4719 Fax: [illegible]
| Report prepared by DigiCardio, Inc. Tel: 866.344.4227
HOLTER MONITOR REPORT
| | Patient Name: 90510091224 Black Disk 1 Interp. Physician: Janet Shackleford, M.D.
Date of Birth: 6/30/1990 Scan Number: [illegible]
ID: 90510091224 Date Recorded: 9/12/2024 @ 6:53
Age: 34 Years Date Processed: 9/26/2024
Sex: M Recorder Num: 041707
Analyst: CE HookupTech: AAB
Physician: Janet Shackleford, M.D.
Indications: Medications: [illegible]
f
| The patient was monitored for a total of 47:59 hours. The total time analyzed was 45:04 hours. Start time was 6:53am1.
[illegible] [There was a total of 172297 beats. Less than 1% were Ventricular beats, less than 1% were Supraventricular beats, and
patient is not paced.
Mean Heart Rate: 64 Total Beats: 172297
Maximum Heart Rate:147 @ 6:22am2 Tachycardia beats: 11159 (>=100 BPM) 6%
Minimum Heart Rate: 38 @ 10:49pm1 Bradycardia beats: 31833 (<= 50 BPM) 18%
Pauses: 0 (> 2.5 sec.) Longest RR at: 1.65 seconds at 10:51pm2
Ventricular Ectopy Supraventricular Ectopy
Total: 163 Total: 19
Early/Late: 126/37 Single: 16
Pairs: 0 Pairs: 0
Total Runs: 0 Total Runs: 0
Beats in Runs: 0 Beats in Runs: 0
Longest Run: 0 @6:53am1(0BPM) Longest Run: 0 @ 6:53am1(0 BPM)
Fastest Run: 0 @ [illegible] ( 0 BPM) Fastest Run; 0 @ 6:53am1(0 BPM)
RontT: 0 Aberrant: 3
RR Varlability ST Absolute
SDNN: 247.57 ms Depression: *** mm
PNN50: 30.095 % Elevation: *** mm
RMSSD: 61.565 ms
SDSD: 61.565 ms
Underlying sinus rhythm. Periods of slight sinus arrhythmia. [illegible] 4 [illegible] ane
Periods of sinus bradycardia totaled just over 11 hours. Ko) [04 0-510
Periods of sinus tachycardia totaled 1.75 hours.
| [illegible] (0/30 ||440
Non-specific ST-T wave changes.
Occasional primarily unifocal PVCs.
Rare PACs.
[illegible] patient event correlated with sinus tachycardia.
al} within normal limits.
Physician's Signature:
Janet Shackleford. M.D. mar
Case Nm. [illegible] Dohonsmeatt-94 [illegible] ofg 8
of 27 [illegible] Z
DISTRICT COURT,
CITY AND COUNTY OF DENVER, COLORADO
520 West Colfax Ave.
Denver, Colorado 80204 DATE FILED: May 18, 2023 10:54 AM
THE PEOPLE OF THE STATE OF COLORADO, FILING ID: 37640A5C5757A
Plaintiffs, CASE NUMBER: 2022CR6134
Vv.
DEJANE REANIECE LATTANY
(DOB 06/30/1990)
fy [illegible] i, [illegible]
Defendant. 4 COURT [illegible] “ ”
PHILIP J. WEISER, Attorney General Case No.: 22CR6134
Daniel T. Brechbuhl*
Assistant Attorney General I]
Ralph L. Carr Colorado Judicial Center Courtroom: 5G
1300 Broadway, 9th Floor
Denver, CO 80203
(720) 508-6482
E-Mail: Daniel.Brechbuhl@coag.gov
Registration Number: 31047
*Counsel of Record
DEFENDANT’S REQUEST TO PLEAD GUILTY
This document represents my desire to plead guilty. I know that I have the right to remain
silent, that I do not have to make this request, and anything I write or say may be used against
me. Knowing that, I swear or affirm that I have read and understand everything in this and all
of the documents I have submitted in this case. I understand all of the rights that I am giving
up by pleading guilty.
Defendant’s Initials; lea [illegible]
p [illegible] years old. I have completed CA yéars of school. At this time my
mental and physical health is satisfactory. I am thinking clearly. My decision to plead guilty is
not being affected in any way by alcohol, drugs, or medication.
[illegible] I understand what is happening in this Courtroom today. I read, speak, and
understand the English language, or all of the documents and proceedings in this matter have
been fully explained to me in a language that I understand.
ij C3, I understand that if I am not a citizen of the United States, this guilty plea can cause
deportation, exclusion from admission to the United States, or denial of naturalization, or other
immigration consequences.
p [illegible] I understand the nature of the charge(s) against me and the elements of the
charge(s), which the prosecution would have to prove beyond a reasonable doubt to a
unanimous jury before I could be found guilty at trial. The essential elements of the crime to
which J am pleading guilty are attached to this document. With my lawyer, I have reviewed the
Case No. 1:23-cr-00074-NYW Document 94 _ filed 11/05/24 USDC Colorado pg9
Case No. 1:23-cv-03027-SBP Document 2-27 filed 04/02/24 USDC Colorado pgiofi
412/24, 8:33 AM Inmate Locator
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Find an inmate.
Locate the whereabouts of a federal inmate incarcerated from 1982 to the present. Due to the First Step Act, sentences are
being reviewed and recalculated to address pending Federal Time Credit changes. As a result, an inmate's release date
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DEJANE REANIECE
LATTANY Related Links
Register Number: 51090-510 Facility Information
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[illegible] 1H
Case No. 1:23-cv-08074-SBRV [illegible] 2 [illegible] 10
of 27
[illegible]
attached document(s) explaining the elements of the charge I am pleading guilty to. I have
signed the attached document(s) because I thoroughly understand them.
5. [illegible] understand that I have each of the following rights:
[illegible] (a) I know that I have the right to plead “not guilty” to all charges against me and to
have a speedy and public trial to a jury of 12 persons or to a judge on all charges against me.
L (b) I know that I have the right to be represented by a lawyer at all stages of these
proceedings, and if I cannot afford a lawyer, the Court will appoint a lawyer for me, free of
charge.
) [illegible] [know that I have the right to be presumed innocent at trial and to require the
prosecution to prove at trial each element of each charge beyond a reasonable doubt before |
could be found guilty.
| [illegible] (d) I know that at that trial I have the right to see and cross-examine all witnesses
who might testify against me.
(e) I know that I have the right to present any defense I might have, and to call any
Witnesses in my own defense. If those witnesses were unwilling to appear, I understand that
the Court would issue subpoenas at my request and would order those witnesses to appear and
testify. I understand that I would have no burden to present any evidence or witnesses at trial.
I would not have to prove myself not guilty. I would be presumed innocent at trial and the
burden to prove my guilt would rest solely with the prosecution.
L- (f) I know that I have the right to remain silent, and not say anything or make any
statement whatsoever about this case. I know that [illegible] do choose to make any statement, that
statement could be used against me in Court.
| [illegible] know that I have the right to either testify at trial or to remain silent, and
tHat if I chose not to testify, I could have the Judge instruct the jury that they could not consider
my decision to not testify for any purpose. I understand that whether I testified or not at trial
would be purely my decision.
[illegible] (h) I know that if I were convicted of any charge at trial I would have the right to
appeal that conviction to a higher Court.
(i) I know that I may have a right to a Preliminary Hearing, and I understand that
right.
[illegible] (j) Iam aware that I may have the right to bail, and I am aware of the amount of
that bail.
[illegible] (k) I know that when I plead guilty, except for the right to counsel, I give up all
of these rights and all possible defense(s) to the charge(s).
Case No. 1:23-cr-00074-NYW Document 94 filed 11/05/24 Colorado 11
Case No. 1:23-cv-03027-SBP Document 94 04/02/24 USDC Colorado pg 3 [illegible] 9
[illegible] L 6. The decision to plead guilty is my decision and it has been made freely and
voluntarily. There has been no threat, coercion, undue influence, or force used to make me
plead guilty. I know that I do not have to follow my lawyer’s advice and that I do not have to
plead guilty. This is my decision to plead guilty.
L 7. know that a plea of guilty admits the charge, and a plea of not guilty denies the
charge. 1 admit the charge(s) to which I am pleading guilty and each of the elements, which are
attached to this document. I also admit that there are sufficient facts in this case which could
be presented at trial by the prosecution, which would result in a strong likelihood of my
conviction.
[illegible] To the charge(s) of COUNT THREE: MEDICAID FRAUD AND WASTE 24-
[illegible] (4), C.R.S. (Class 5 Felony) [illegible] I plead GUILTY.
[illegible] 9. The elements of the charge(s) to which I am pleading guilty, which are attached to
this document, have been explained to me. I understand fully everything the prosecutor would
have had to prove beyond a reasonable doubt to each and every member of a 12-person jury
before I could have been convicted.
[illegible] 1[illegible]. I understand that one of the elements, which the prosecutor would have had to
prove, is my mental state at the time of commission of the crime. In addition to understanding
the elements, I understand the applicable definition(s) below, and I understand what the
prosecutor would have had to prove in that regard:
DL INTENTIONALLY: A person acts “intentionally” or “with intent” when his/her
[illegible] objective is to cause the specific result proscribed by the statute defining the offense.
It igjmmaterial whether or not the result actually occurred.
KNOWINGLY or WILLFULLY: A person acts “knowingly” or “willfully” with
respect to conduct or to a circumstance described by a statute defining an offense when he/she
is aware that his/her conduct is of such nature or that such circumstance exists. A person acts
“knowingly” or “willfully” with respect to a result of his/her conduct when he/she is aware that
[illegible] conduct is practically certain to cause the result.
[illegible] RECKLESSLY: A person acts “recklessly” when he/she consciously disregards a
[illegible] and unjustifiable risk that a result will occur or that a circumstance exists.
[illegible] NEGLIGENTLY: A person acts with “criminal negligence” when, through a gross
deviation from the standard of care that a reasonable person would exercise, he/she fails to
perceive a substantial and unjustifiable risk that a result will occur or that a circumstance exists.
[illegible] 11. [illegible] understand that the Court is not bound by and does not have to follow anyone’s
recommendations concerning the entry of a guilty plea, the penalty to be imposed, and the
granting or denial of probation. Any proposed plea agreement and any concession(s) are fully
and accurately set forth in this written document.
Cy. L have had a full opportunity to discuss with my lawyer everything I know about
this case and all defenses that may be available to me. My lawyer has also discussed the
elements of the charges, which the prosecutor would have to prove, all lesser included charges,
and all possible defenses. I understand my lawyer, and ] am satisfied with the advice and
Case No. [illegible] 4 [illegible]
of 27 |
[illegible] A
representation I have received from my lawyer.
[illegible] I understand that if the Court accepts my guilty plea to a felony I will stand
convisted of a felony. I understand that this felony conviction may be used against me in any
future proceeding under the habitual criminal laws. I also understand that my felony conviction
may be used against me in any future proceeding concerning my credibility. [illegible] have entered
into a Stipulation of a Deferred Judgment and Sentence, and I have not yet completed the terms
of that agreement, my guilty plea may be used against me in any future proceeding. I
understand if I have entered into a Stipulation of a Deferred Judgment and Sentence and I
violate the terms of that agreement, I may stand convicted of a felony and then I will be re-
sentenced by the Court.
14. [illegible] understand the full range of potential penalties for my offense(s) as set forth
below and in the chart of applicable sentencing ranges on page 6.
\ | [illegible] (a) I know that if I plead guilty to a felony, I may be sentenced to the custody of the
Department of Corrections (prison), as shown in the below chart on page 6 for my applicable
sentencing range. I understand that the Department of Corrections will determine my place of
incarceration.
A [illegible] (b) [illegible] applicable, I understand and agree that there exist facts or circumstances
urrounding the offense(s) I committed which are extraordinarily aggravating and will call for
the Judge to impose a sentence above the maximum in the presumptive range, and as high as
the maximum shown in the “extraordinary circumstances” portion of the box marked in the
chart below. I agree to such a sentence. I understand that I have the right to require the
prosecution to prove to a unanimous jury beyond a reasonable doubt any facts that bear upon
whether extraordinary aggravating circumstances are present and upon whether any sentence
will be above the top of the presumptive range. I understand and agree that by pleading guilty,
I give up that right, including the right to have those facts proved beyond a reasonable doubt
and the right to have them determined by a jury. I understand that my guilty plea is a waiver of
my right to a jury trial on all issues including the determination of the penalty to be imposed
and of all facts relating to, or supporting, a sentence above the top of the presumptive range.
[illegible] If applicable, I know that if the Judge were to conclude that extraordinary
[illegible] or aggravating circumstances are present in my case, I could be sentenced to any
ter of imprisonment from the minimum to the maximum sentence allowed by law as set out in
the “extraordinary circumstances” portion of the box marked in the chart below on page 6. I
understand that I have the right to require the prosecution to prove to a unanimous jury beyond
a reasonable doubt any facts that bear upon whether extraordinary aggravating circumstances
are present and upon whether any sentence will be above the top of the presumptive range. I
understand and agree that by pleading guilty, I give up that right, including the right to have
those facts proved beyond a reasonable doubt and the right to have them determined by a jury.
I agree to let the Judge, in the Judge’s discretion, decide all such facts and decide whether or
not extraordinary aggravating circumstances are present in my case and whether or not to
impose a sentence above the top of the presumptive range. I understand that my guilty plea isa
waiver of my right to a jury trial on all issues including the determination of the penalty to be
Case No. 1:23-cr-00074-NYW Document 94 [illegible] filed 11/05/24 USDC Colorado pgi3
Case No. 1:23-cv-03027-SBP Document 94 filed 04/02/24 USDC Colorado pg 5 of 9
imposed and of all facts relating to, or supporting, a sentence above the top of the presumptive
range.
AA A (d) [illegible] applicable, I understand and agree that my criminal record will allow the
Judge to impose a sentence above the maximum in the presumptive range, and as high as the
maximum shown in the “extraordinary circumstances” portion of the box marked in the chart
below on page 6. I understand that I have the right to require the prosecution to prove to a
unanimous jury beyond a reasonable doubt facts about my criminal record that bear upon
whether extraordinary aggravating circumstances are present and upon whether any sentence
will be above the top of the presumptive range. I understand and agree that by pleading guilty,
I give up that right, including the right to have any such facts proved beyond a reasonable doubt
and the right to have them determined by a jury. ] understand that my guilty plea is a waiver of
my right to a jury trial on all issues including the determination of the penalty to be imposed
and of all facts about my criminal record relating to, or supporting, a sentence above the top of
the presumptive range.
_A [illegible] (e) [illegible] applicable, I understand and agree that I am pleading guilty to a “crime of
[illegible] A “crime of violence” sentencing requires the Court to sentence me to prison for at
least the midpoint in the presumptive range and no more than twice the maximum of the
presumptive range, as shown on the chart below on page 6. I understand and agree that the
minimum mandatory sentence shall be years in prison with a maximum potential
sentence of years in prison.
VA (f) If applicable, I know that if the Court sentences me to incarceration for a felony,
that gentence must be to at least the midpoint, but not more than twice the maximum in the
presumptive range, if, at the time of committing the crime(s) in this case, I was:
On probation or parole for another felony, or
Confined or had escaped while completing a felony sentence, or
On bond after revocation of probation for another felony or for an
act that would have been a felony if committed by an adult, or
On a felony appeal bond.
I understand and agree that by pleading guilty, I give up any right I might have to have a jury
determine whether any of these circumstances are present in my case, and I agree to allow the
Judge to make that determination and decide whether my sentence will be above the top of the
presumptive range. Further, I admit that circumstances that I have initialed above are present
[illegible] case.
[illegible] (g) Ifapplicable, I know that if the Court sentences me to incarceration for a felony,
the Court must sentence me to at least the minimum, but not more than twice the maximum in
the presumptive range, if, at the time of committing the crime(s) in this case, ] was:
Charged with or on bond for another felony in another case for
which I have now been convicted, or
Charged with or on bond for an act that would be a felony if
committed by an adult, or
Under a Deferred Judgment and Sentence for a felony or for an act
that would be a felony if committed by an adult, or
On a juvenile parole for an offense that would be considered a
Ease No. [illegible] Filed [illegible] 6 oPg 14
[illegible] tt 2.
felony if committed by an adult, or
On bond after pleading guilty to a lesser offense when the original
offense charged was a felony or would be a felony if committed by an adult.
I understand and agree that by pleading guilty, I give up any right I might have to have a jury
determine whether any of these circumstances are present in my case, and I agree to allow the
Judge to make that determination and decide whether my sentence will be above the top of the
presumptive range. Further, I admit that circumstances that I have initialed above are present
in my case.
(h) I know that if I receive a sentence to the Department of Corrections, I must
serve a mandatory period of parole as indicted below. Parole is after, in addition to and distinct
from any other sentence imposed. Additionally, if my parole is revoked I may be required to
serve the time remaining on parole in the Department of Corrections. The period of parole I
must serve is as indicated in the box marked in the following sentencing range chart:
MARKED FELONIES COMMITTED ON OR AFTER
BOX BELOW JULY 1, 1993
INDICATES PRESUMPTIVE EXTRAORDINARY MANDATORY
APPLICABLE RANGE CIRCUMSTANCES PERIOD of
SENTENCING PAROLE
RANGE
CLASS | MINIMUM | MAXIMUM | MINIMUM | MAXIMUM | MANDATORY
PAROLE
1 Life Life
Imprisonment Death Imprisonment Death
2 8 years 24 years 4 years 48 years 5 years
$5,000 fine | $1,000,000
fine
3 4 years 12 years 2 years 24 years 5 years
$3000 fine $750,000
[illegible]
ordinary 4 years 16 years 2 years 32 years 5 years
Risk $3000 fine $750,000
Crime fine
4 2 years 6 years 1 year 12 years 3 years
$2000 fine $500,000
[illegible]
ordinary 2 years 8 years 1 year 16 years 3 years
Risk $2000 fine | $500,000
Crime fine
XXX 5 1 year 3 years 6 months 6 years 2 years
$1000 fine $100,000
[illegible]
ordinary 1 year 4 years 6 months 8 years 2 years
Risk $1000 fine $100,000
Crime fine
Case No. 1:23-cr-00074-NYW Document 94 filed 11/05/24 USDC Colorado pgi15
Case No. 1:23-cv-03027-SBP Document 94 filed 04/02/24 USDC Colorado pg 7 of 9
6 1 year 18 months 6 months 3 years 1 year
$1000 fine $100,000
[illegible]
ordinary 1 year 2 years 6 months 4 years 1 year
Risk $1000 fine | $100,000
Crime fine
[illegible] Based on the above, I understand the sentencing range applicable for my crime.
[illegible] (i) I know that the sentence is imposed by the Court. The Court is not bound by
any promises made by anyone concerning sentencing. Any promises or agreements made to
me with respect to the sentence, that are not set forth in this document, are invalid.
) [illegible] (j) I know that by pleading guilty to a felony offense, from this point forward I may
not and it will be illegal for me to own, possess, or use any firearms.
[illegible] I understand and agree that by pleading guilty to any criminal offense in this
J
[illegible] I have a history of any sex offenses or if I have been previously convicted on or after
nuary 1, 1994, of any type of sex-related criminal offense, including attempt, solicitation, and
conspiracy to commit a sex-related criminal offense, or if I have been previously convicted on
or after July 1, 2000, of any criminal offense, the underlying factual basis of which involved a
sex-related criminal offense, I will be required, as part of the pre-sentence investigation by the
Probation Department, to submit to a mental health sex-offense specific evaluation, and that I
may be required to undergo sex offender treatment to the extent appropriate. I further
undergtand that such sex offender treatment may include therapy, monitoring, and supervision.
[illegible] (1) applicable, I am aware that ] am pleading guilty toa SEXUAL OFFENSE.
[illegible] lawyer, I have reviewed the attached documents explaining the elements of the
charge I am pleading guilty to and the potential penalties for that sex offense. I have initialed
and signed the attached documents because I thoroughly understand them.
[illegible] (m) I know that if [illegible] am pleading guilty to a misdemeanor offense, I may be
[illegible] to the Denver County Jail for as little as the minimum lawful term or as much as the
maximum lawful term. I know the applicable sentencing range for my misdemeanor offense
as indicated in the box below is:
MARKED BOX MISDEMEANORS COMMITTED
INDICATES ON OR AFTER JULY 1, 1993
APPLICABLE
SENTENCING CLASS MISDEMEANORS
RANGE
MINIMUM MAXIMUM
1 6 MONTHS 18 MONTHS
[illegible] ‘NOT [illegible] TEN [illegible] 9pg 16
of 27 [illegible] 2
PLEA AGREEMENT
Below is the complete and accurate agreement between the People of the State of Colorado, as
represented by the prosecutor, and the above-named Defendant, as represented by his attorney. All
concessions and stipulations are fully set forth herein.
1. The Defendant will enter a plea of GUILTY to the charge of:
COUNT THREE: MEDICAID FRAUD AND WASTE, 24-31-808(1)(G), (4). C.R.S. [illegible]
{53651}
2. In exchange for the above guilty plea, The People will dismiss COUNTS ONE,
TWO, AND FOUR, after the Court accepts the above guilty plea and any agreement(s) of the
parties.
3. The People and the Defendant have agreed and stipulated to the following concession(s)
A. (all concessions are set forth herein): __ Two Years Colorado Department of
Corrections Sentence and one year mandatory parole concurrent to sentence in United
States District Court- District of Colorado, Criminal case No. 23-CR-00074-NYW.
This sentence would be served in the federal prison system. The parties stipulate to
Restitution. of $372,150.47 to [illegible] Department of Health Care Policy and
Financing, c/o Colorado Attorney General’s Office, Colorado Medicaid Fraud Control
Unit, Ralph L. Carr Colorado Judicial Center, 1300 N. Broadway, Ninth Floor, Denver,
CO 80203.
I swear or affirm that I have read and understand this entire document, and every representation I
have made is true,
<=> Date: [illegible] ) [illegible] ?
Defeiidant: Dejane Reaniece Lattany
As defense counsel, I affirm that the above-named Defendant has executed the foregoing “The
Defendant’s Request to Plead Guilty (Crim. P. Rule 11 Guilty Plea Advisement).” As defense
counsel I have thoroughly reviewed this document with the Defendant in regard to the entry of
this guilty [illegible]
[illegible] Date: S [illegible] y [illegible]
[illegible] Jason Flores-Williams, Reg. No. 49702
/s/ Daniel T. Brechbuhl Date: __ 5/1/23
Prosecuting Attorney: Daniel T. Brechbuhl, Reg. No. 31047
of 27
FSA Time Credit Assessment
Register Number:51090-510, Last Name: LATTANY
U.S. DEPARTMENT OF JUSTICE FEDERAL BUREAU OF PRISONS
Conditional Transition To Community Date: N/A
[illegible] SCA Ineligible [illegible]
[illegible] 1:23-cr-00074-NYW Document 94 [illegible] filed 11/05/24 USDC Colorado pg17
[illegible] Best Case Scenario - Conditional Pre-release Planning & Preparation Only
All conditional days and conditional dates below are the individual's best case scenario
given the individual's FSA/FTC status and best case SCA days as of 10-15-2024. These dates
ean change if there are changes to one or more of the following: the individuals FSA risk,
FSA opt-in/opt-out status, or best case SCA days.
SCA DAYS ARE NOT GUARANTEED AND REQUIRE AN INDIVIDUALIZED ASSESSMENT! THEREFORE, IF A DEFAULT
OF 365 DAYS IS REFLECTED, THIS DATE IS SUBJECT TO CHANGE BASED ON THE REQUIRED FIVE-FACTOR
REVIEW UNDER 18 USC SEC. 3621(B). AN INDIVIDUAL WHO HAS PENDING CHARGES/DETAINERS ARE NOT
ELIGIBLE FOR SCA TIME. THE FIVE-FACTOR REVIEW INVOLVES THE FOLLOWING: (1)THE RESOURCES OF THE
“PACILITY CONTEMPLATED; (2) THE NATURE AND CIRCUMSTANCES OF THE OFFENSE; (3) THE HISTORY AND
CHARACTERISTICS OF THE PRISONER; (4) ANY STATEMENT BY THE COURT THAT IMPOSED THE SENTENCE:
(a) CONCERNING THE PURPOSES FOR WHICH THE SENTENCE TO IMPRISONMENT WAS DETERMINED TO BE
WARRANTED; OR (b) RECOMMENDING A TYPE OF PENAL OR CORRECTIONAL FACILITY AS APPROPRIATE; AND
(5) ANY PERTINENT POLICY STATEMENT ISSUED BY THE U.S. SENTENCING COMMISSION.
Projected Release Date: 04-25-2027
Projected Release Method: GCT REL
FSA Projected Release Date: 01-15-2027
FSA Projected Release Method: FSA REL
FSA Conditional Release Date: 04-25-2026
SCA Conditional Placement Days: N/A
SCA Conditional Placement Date: N/A of [illegible]
FSA Conditional Placement Days: N/A
FSA Conditional Placement Date: N/A
--- Detainers
Id Lodged Org Authority
001 01-31-2024 SCO COLORADO DOC/ DENVER COUNTY SHEIRFF DEPT [ke
10-15~2024 (4) Assessment# ~2144217899
e No. 1:23-cr-00074-NYW D [illegible] filed 11/05/24 USDC [illegible]
[illegible] ocumen £27 ile olora RA [illegible] ave]
[illegible] OCUMENTATION OF INFORMAL RESOLUTION ATTEMPT MC. Bishop
Bureau of Prisons Program State ini
‘ [illegible] ment No. 13360.16, Administrative [illegible] f [illegible] |
attempt informal resolution of grievances prior to fling a formal [illegible] (December 31, 2007), requires, in most cases, that [illegible] TAS.
[illegible] informal resolute form shall be used to document your efforts towards informally
[inmate Name [illegible]
[illegible] Dt TaN€ [illegible] Register Numb =
[illegible] Briefly state your complaint. fnel ude all details add facts which [illegible] and [illegible] wove [illegible] basis
[illegible] one [illegible] Provided Aw. mn itess with the aperwork And [illegible]
[illegible] paperwork [illegible] Tp [illegible] me Bard SIE Cr [illegible]
[illegible] the [illegible] There is WO [illegible]
Detain [illegible] BE [illegible] MY Zyear [illegible] Are [illegible]
Me [illegible] he Legal sentenee [illegible] ABE. £0
[illegible] Briefly state the action You request fo resolve your complaint. an Order or Paperwork [illegible]
= AMO [illegible] You Rever to the Legal [illegible]
[illegible] SING cae, [illegible] 3 [illegible] ary [illegible]
[illegible] in [illegible] Lee [illegible] Z year
M the Stale OF (olomtdo [illegible] You ding [illegible] Paperwork
3. ape Briefly state the action(s) you have taken and with whom you have [illegible] Detain [illegible] Par my Legal a. [illegible]
[illegible] Spore with Pegicnel [illegible] Ms Hes [illegible] tig [illegible] Doe [illegible] Selene
[illegible] in [illegible] those fo MS. Mallard, [illegible] Het dine clale [illegible] Boe [illegible]
Ug [illegible] UH 2024 [illegible] Ram a Verbet plore Call [illegible] Yer
10 [illegible] TAM Now [illegible] 4 idl [illegible] Sen
[illegible] 10 [illegible] You legally Prespons } [illegible] so,
[illegible] GIVE THIS COMPLETED FORM TO YOUR [illegible] COUNSELOR [illegible] heh. [illegible]
TO BE COMPLETED BY STAFF Date Received by Counselor for Response [illegible]
Summary of investigation (pia [illegible]
VM. Latthany 51090-510 [illegible] here to EMC [illegible] Department of Corrections/Denver County Sheriff Department sentence in case number
22CR6134 that was placed on her by FCC Victorville. Colorado sent Victorville paperwork on January 31, 2024, placing the detainer. The paperwork contained a letter and her
judgment order instructing the Bureau to place a Detainer on her. The Detainer judgment order stated that she was sentenced to 2 years starting on May 22, 2023, followed by 24 <
months of mandatory parole required by statute. Verification was made on March 13, 2024, by the Deputy Case Management Coordinator at FCC Victorville with Colorado
DOC/Extraditions Operations Coordinator. They stated via email that I/M Latthany 51090-510 must be extradited back to Colorado to be processed for parole. Colorado states
that the projected parole termination date is 05-22-2027. Legally the ISM Department cannot remove this Detainer unless instructed to do so in writing(verified) by the agency
that place the Detainer, which in this case is Colorado DOC/Denver County Sheriff Department. Therefore, the Detainer will stay in place until Colorado DOC/Denver County
Sheriff Department decides to remove it.
[illegible] actions were faken fo resolve this matter informally (place response on this form):
Contacted R&D
Explain reasons for no resolution (place response on this form):
[illegible] Time lamate Refurned BP 85 / / / [illegible] : Unit Team Member: [illegible]
Time Investigation on BP 8.5 Completed and BP-9 (BP228(13) issued:
[illegible] Administrator Signature:
(date), this issue [illegible] informally resolved,
‘ignature
Date
on: (1) lf co Play tisi al 4
yf resol ed, fo
[illegible] nform [illegible] the or tginal, signed and dated by the Ic imate to the Unit Counselor for filing. (2) (f
{attached to [illegible] form) to the [illegible] box in the Warden's Office
Case No. 1:23-cr-00074-NYW Document 94 filed 11/05/24 USDC Colorado pg19
of 27
[illegible] Sheriff Department
Downtown [illegible] Civil Unit
Cs SHERIFF 201 W, Colfax Avenue
2.2 DEPARTMENT [illegible] Co 90202
: DENVER PUBLIC SAFETY [illegible] 29
[illegible]
January 31, 2024
FCC Victorville
Attn: A Hatt
P.O. Box 5400
Adelanto, CA 92301
RE: LATTANY,DEJANER. DOB: 6/30/1990
Denver District Case No.: 22CR6134
BOP # 51090-510
To Whom It May Concern:
We have been informed that Dejane Latteny is in your custody. This letter will serve as our lodging of a
detainer against her for charges in Denver District Court.
Enclosed please find a copy of the court mittimus, to be lodged as a detainer for Dejane Lattany. Court
“'mittimus issued by the Honorable Judge Christine Antoun, Denver District Court, Denver Colorado.
Dejane Lattany is a Black female, [illegible] 199 [illegible] brown hair, brown eyes,
DOB: 6/30/1990 SSN: unknown
We are requesting that you lodge our court mittimus as a detainer for this department and advise the
subject of same.
Should you have any questions with regards to this request, please contact Disa Gibbens of the Denver
Sheriff's Office Fugitive Warrants & Extradition Unit at (720) 865-8701.
Disa.Gibbens@denvergov.org.
Thank you for your cooperation in this matter.
[illegible]
Sheriff Elias Diggins.
co: Jessica Negrete, District Attorney’s Office
Enclosure
[illegible] |3f [illegible]
[illegible] 7 [illegible]
[illegible] i ’
' [illegible]
Case No. 1:23-cr-00074-NYW Document 94 filed 11/05/24 USDC Colorado pg 20
[illegible] of 27
Mis [illegible]
Dastrict Court, Denver County, State of Colorado
Case#:D0162022CR006134 Div/Room: 5G
JUDGMENT OF CONVICTION, SENTENCE Amended
The People of the State of Colorado vs. LATTANY, DEJANE REANIECE
DOB 6/30/1990
om
RID:B. 62022CR006134-000044
‘The Defendant was sentenced on: §/22/2023
People represented by...: BRECHBUHL, DANIEL
Defendant represented by: FLORES-WILLIAMS, JASON
UPON DEFENDANT'S CONVICTION this date of: 5/22/2023
The defendant pled guilty to:
Count # 3 Charge: MEDICAID-ALTER/FALSE/CONCEAL RECORD
C.R.S # 24-31-808(1) (g), (4) Class: FS
Date of offense(s): 11/09/2019 to 2/17/2021 Date of plea(s): 5/22/2023
IT IS THE JUDGMENT/SENTENCE OF THIS COURT that the defendant be sentenced to
THE CUSTODY OF THE EXECUTIVE DIRECTOR OF THE DEPARTMENT OF CORRECTIONS
Department of Corrections 2.00 YEARS COUNT 3
5/22/23: 2 YEARS PAROLE. DEF'S SEXTENCE IS TO BE SERVED CONCURRENTLY TO DEF'S
SENTENCE IN FEDERAL CASE 23-CR-74-NYW. DEF'S SENTENCE IS TO BE SERVED IN THE
BUREAU OF PRISONS. [illegible]
STAY OF EXECUTION IS GRANTED UNTIL 8/29/23 AT 1 P.M. /MSA
09/06/2023 - STAY OF EXECUTION IS EXTENDED UNTIL 09/28/2023 AT 12:00 PM. /AKB
STAY OF EXECUTION GRANTED TO: 9/28/2023 @ 12:00 P
Plus a mandatory period of parole as required by statute.
Months on parole 0024
Assessed Balance
$ [illegible] $ 377,172.47
THEREFORE, IT IS ORDERED the Sheriff of Denver County Shall convey the
DEFENDANT to the following department TO BE RECEIVED AND KEPT ACCORDING TO LAW
COLORADO STATE DEPARTMENT OF CORRECTIONS DIAGNOSTIC CENTER
ADDITIONAL REQUIREMENTS
JUDGMENT OF CONVICTION IS NOW ENTERED, IT IS FURTHER ORDERED OR RECOMMENDED:
[illegible] | [illegible]
DATE [illegible] NPT S bales JUDGE/MAGISTRATE
[illegible] CHRISTINE [illegible] ANTOUN
Sheriff's Certificate of Completion
The court orders the sheriff to complete this certificate and return to the
clerk of court upon the release of the defendant from their custody.
I certify that I executed this order as directed and released the defendant
on {Date}.
Date Sheriff
By Deputy
Exnibit 4° 1:23-cr-00074-NYW Document 94 [illegible] filed 11/05/24 USDC [illegible]
of 27
DISTRICT COURT, DENVER COUNTY, COLORADO
Court Address:
1437 BANNOCK STREET, RM 256, DENVER, CO, 80202
THE PEOPLE OF THE STATE OF COLORADO DATE FILED
Vv. October 11, 2024
Defendant(s) DEJANE REANIECE LATTANY
[illegible] COURT USE ONLY /A\
Case Number: 2022CR6134
Division: 5G Courtroom:
Order Denying EMERGENCY MOTION FOR REQUEST FOR A MEETING VIA VIDEO OR TELEPHONE
The motion/proposed order attached hereto: DENIED.
The Court does not schedule meetings on criminal matters. As noted in a prior order, this Court does not have authority over
the Bureau of Prisons and cannot issue any orders regarding the location of incarceration. As there are no pending matters
in this case, the Court declines to schedule any hearing dates.
issue Date: 10/11/2024 [illegible]
[illegible]
DEMETRIA ELIZABETH TRUJILLO
District Court Judge
[illegible]
[illegible]
PAS [illegible] Document 94 filed 11/05/24 USDC Colorado pg 22
CXNibt of 27
DISTRICT COURT, DENVER COUNTY, COLORADO
Court Address:
1437 BANNOCK STREET, RM 256, DENVER, CO, 80202
THE PEOPLE OF THE STATE OF COLORADO DATE FILED
Vv. September 26, 2024
Defendant(s) DEJANE REANIECE LATTANY
[illegible] COURT USE ONLY A
Case Number: 2022CR6134
Division: 5G Courtroom:
Order Re: Letter dtd 9/14/24 RE: Defendant's Health w/attach
The motion/proposed order attached hereto: NO ACTION TAKEN.
The Court has reviewed the foregoing letter.
To the extent Ms. Lattany is seeking relief from circumstances involving the Bureau of Prisons relative to her health issues,
this Court does not have jurisdiction to grant any relief.
Issue Date: 9/26/2024
DEMETRIA ELIZABETH TRUJILLO
District Court Judge
Page of1
[illegible] 1:23-cr-00074-NYW Document 94 filed 11/05/24 USDC Colorado pg 23
of 27
TRULINCS 51090510 - LATTANY, DEJANE REANIECE - Unit: LOS-G-S
FROM: Lattany, Anezshe
TO: 51090510
SUBJECT: Hey
DATE: 03/11/2024 05:06:06 PM
Hello Ms. Lattany,
I am more than happy to speak with the public defender and/or the case manager to advise that CDOC does not show a
detainer in our system for Dejane Lattany. Please feel free to give them my information if necessary.
This is what head of doc wrote her email is jacqueline.sherbo@state.co.us
Case No. 1:23-cr-00074-NYW Document 94 filed 11/05/24 USDC Colorado pg 24 of 27
[handwritten margin note, rotated] Exhibit 5 - [illegible] Supplement 2255, Injunction and Emergency Compassionate release
A Knock aT MIDNIGHT — 155
Chapter 10
GIRLS EMBRACING MOTHERS
The ACLU calls Carswell Federal Medical Center a “hospital
of horrors”—and for good reason. Women are sent there
with diagnoses requiring urgent medical care and then are rou-
tinely denied treatment. Prescriptions are thrown out upon arrival
until new tests can be ordered—tests that are often put off for
months, at which point the woman’s health has declined to the
point of no return. Carswell is the only medical facility for women
in federal prison, but from the beginning it was obvious the prison
hospital was ill-equipped to handle a situation as severe as Genice
Stribling’s.
Within days of her arrival, the untrained prison aides assigned
to help Genice rolled her out of bed incorrectly and broke her
ankle. A day later, her toe. They put her in a full-body lift-sling and
hoisted her high in the air onto a cot, but didn’t fasten the sling
correctly; Genice fell out and broke her tailbone. Prison doctors
deemed treatment unnecessary, as Genice “couldn’t feel it any-
way.” Her body swelled so severely they kept her in a compression
brace for twenty-four hours a day, rushing her to an outside hospi-
tal only when the swelling compromised her internal organs.
When she was released back to Carswell, medical staff refused to
use Genice’s method to move her bowels despite their method not
working. Utterly dependent on her caregivers, Genice went for
weeks without a bowel movement.
“Ms. Stribling,” the prison doctor who oversaw her first trau-
matic months at Carswell leaned over and whispered in her ear,
“we cannot care for you here. File the compassionate release pa-
perwork and I'll recommend you for home confinement.” But
when Genice’s attorney reached out to him for the recommenda-
tion, something had changed. The doctor just shook his head. “I’m
sorry, I can’t do it,” he said, and refused to comment further. An-
other doctor quit after three weeks on Genice’s unit after unsuc-
cessfully arguing that they couldn’t possibly meet her needs.
“Nothing they’re doing at that prison is ethical,” she told a family
member later.
Carswell’s reputation extended well beyond its walls. “I took an [illegible]
oath. Just being in that place betrayed it,” Kathleen Rumpf of the
Catholic Workers Association lamented. “I have never seen any-
thing like the corruption and cruelty at Carswell Women’s Prison
Hospital.” A former medical officer at Carswell, Dr. Roger Guth-
rie, even filed a formal complaint with the U.S. Office of Special
Counsel in which he detailed substandard care, medical mistakes,
and delays in treatment leading to numerous cases of prisoner
death and endangerment. He documented repeated incidences of
falsified medical records and documents, the rape and sexual abuse
of women prisoners, and misappropriation of funds intended to
provide medical care for incarcerated women.
Even the media had found their way to the story. “If I have to
stay in here,” Genice told one reporter investigating prison hospi- J
tal conditions, “I'll probably end up dead.”
None of this made it any easier for Sharanda, who was halfway
across the country from her family, serving her sentence 850 miles
away in Tallahassee, Florida. Weasel, housed at Carswell’s low-
security camp across the street from the medical center, heard of
Case No. [illegible]
[illegible] me [illegible] oe
/24 USDCColorado [illegible]
[illegible] me [illegible]
FROM: 51090510
TO: Psychology Services
SUBJECT: ***Request to Staff*** LATTANY, DEJANE.
DATE: 10/07/2024 07:15:17 AM
To: Dr. Young/Dr. Reynolds
inmate Work Assignment: Medical idle
goodmorning,
I am also unsure of how i am medically cleared when i never s bleeding since coming back from the hospital. According
to P.A Smith, i was supposed to have an ultrasound and address e pain in my pelvic area. She also ordered labs showing that
i was depleted of nutrients due to no being able to go to the chow hall to eat real meals. My labs probably improved as of friday _
because some times the inpatients will share their tray if they dont eat it. I am trying to do whati can.
-----LATTANY, DEJANE REANIECE on 10/6/2024 5:53 PM wrote:
[illegible] Hello Dr. Young.
anted to let you know that over this weekend, I had a nervous breakdown. I understand that I need to be moved at [illegible] >
int. I have been trying to see if the Medication that Dr. Allison precscribed is working but it is not working. When | leave
time [illegible] ¢ chest pains increase, everything gets blury and | feel blacked out and | dont know what is going on. lan
raid of this. be ause [illegible] I am telling the staff about my chest pains.. its the same way AIC yolanda did who i whitnessed
not all the time that another AIC will help me. and [illegible] has been done. lve been [illegible]
I was told to eat with the medicine as you know it is hurting my stomach but I am despirately trying to get out of this stuff with
my anxiety, depression, fears, chest pains. I have never been this way in my life.
ase No. 1:23-cr-O00/4-NYW = Document 94 lea 4 USD olorado pg 26
vase No. 1:23-cr-000/4-NYW [illegible] Document 94 led [illegible] USDC Colorado pg
~ [illegible] = [illegible]
[illegible]


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