Objection by Denis Casseus as to Denis Casseus — USA v. Casseus (Dkt. 56, M.D. Fla.)

Summary

Defendant Denis Casseus' additional objection to his presentence investigation report in United States v. Denis Casseus, CASE NO.: 23-cr-00009-TPB, U.S. District Court for the Middle District of Florida, filed October 13, 2023 as Document 56. He objects to paragraph 85, which recommends restitution of $298,875. His counsel says Fifth Third Bank confirmed that a total of $182,279.55 from his accounts was applied to repay the PPP loans. Counsel adds that a property he bought with a $120,000 transfer has been forfeited to the government and has more than $120,000 in equity, so the remaining balance of $116,595.45 will be satisfied when the government sells it. Advocacy document; claims are Casseus'.

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UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA  
 
CASE NO.: 23-cr-00009-TPB 
 
UNITED STATES OF AMERICA            
                      Plaintiff, 
vs. 
 
DENIS CASSEUS, 
 
           Defendant. 
                                                                      / 
 
DEFENDANT’S OBJECTIONS TO PRESENTENCE INVESTIGATION REPORT 
 
Defendant, DENIS CASSEUS, by and through undersigned counsel, pursuant to Rule 
32(f) of the Federal Rule of Criminal Procedure, and the Due Process Clause of the Fifth 
Amendment to the United States Constitution, respectfully files the Defendant’s objections to the 
Pre-Sentence Investigation Report (PSR) and states: 
In addition to the Presentence Investigation Report objections filed on July 31, 2023, the 
Defendant files the following objection: 
Paragraph 85 states that restitution in the amount of $298,875 shall be ordered. The 
undersigned has discussed this issue with Mr. Tyler Boyle from Fifth Third Bank, who advised 
that the money in the accounts held by Denis Casseus was used to repay the loans. 
Specifically, Mr. Casseus controlled three accounts with Fifth Third Bank: $92,125 in 
account ending in 9725, $81,775.66 in account ending in 6816, and $8,378.89 in account ending 
in 9515, for a total of $182,279.55. The bank statements for all three accounts show a debit entry 
on May 2023 “PPP loan proceed offset” for $92,125, $81,775.66, and $ 8,378.89 respectively.  
On October 10, 2023, Mr. Boyle from Fifth Third Bank confirmed to the undersigned 
that a total of $182,279.55 from Mr. Casseus’ accounts was used to pay back the loans. 
Mr. Casseus transferred $120,000 on March 4, 2021, to Breeze Escrow and Title to be 

 
 
used towards the purchase of property located at 132 SW 10th Place, Cape Coral, FL. This 
property has since been forfeited by the United States Government and is now the Government’s 
property. The property now has more than $120,000 in equity.  
Therefore, it appears that out of $298,875 loans taken out by Mr. Casseus, $182,279.55 
was paid back, leaving a balance of $116,595.45, which will be satisfied once the Government 
sells the property they now own. 
 
CERTIFICATE OF SERVICE 
I HEREBY certify that on October 13, 2023, undersigned counsel electronically filed 
foregoing document with the Clerk of Courts using CM/ECF which will send notification of such 
filing to all counsel of record. 
Respectfully submitted, 
BOZANIC LAW, P.A. 
17100 Royal Palm Blvd. 
Suite 1 
Weston, FL 33326 
Telephone: 
954.920.9750 
Facsimile: 
954.400.0335 
E-Mail: Zeljka@bozaniclaw.com 
 
 
By:_____/s/Zeljka Bozanic___________ 
 
 
 
 
 
 
 
Zeljka Bozanic 
 
 
 
 
 
 
 
Florida Bar No.  23707

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