Attachment — USA v. Casseus (Dkt. 62.1)

Summary

Filed 01/24/24 as Document 62-1, this attachment to a motion for compassionate release is a proposed release plan form in support of a motion for sentence reduction under 18 U.S.C. § 3582(c)(1)(A), with housing, employment and medical-care answers. Medical records and letters addressed to Judge Thomas P. Barber follow.

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

Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 1 of 26 PageID
ATTACHMENT TO MOTION FOR COMPASSIONATE RELEASE

UNITED STATES DISTRICT COURT
FOR THE

Mrpoie._ Districror Floktp a»

UNITED STATES OF AMERICA

Case No. 2 -2.3-CR-9-Tps -KCD
Vv. (write the number of your criminal
case)

“Dems Cosseus

Write your full name here.

PROPOSED RELEASE PLAN
In Support of Motion for Sentence Reduction Under 18 U.S.C. § 3582(c)(1)(A)

NOTICE

The public can access electronic court files. Federal Rule of Criminal Procedure 49.1 addresses
the privacy and security concerns resulting from public access to electronic court files. Under
this rule, papers filed with the court should not contain: an individual's full social security
number or full birth date; the full name of a person known to be a minor; or a complete
financial account number. A filing may include only: the last four digits of a social security
number; the year of an individual’s birth; a minor’s initials; and the last four digits of a

financial account number.

If you provide information in this document that you believe should not be publicly
available, you may request permission from the court to file the document under seal. If
the request is granted, the document will be placed in the electronic court files but will
not be available to the public.

Do you request that this document be filed under seal?

C] Yes

Mo
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 2 of 26 PageID
ATTACHMENT TO MOTION FOR COMPASSIONATE RELEASE

B. Medical needs

Will you require ongoing medical carg if you are released from prison?
ou Menta’ Hoth Treatment

O No

Will you have access to health insurance if released?

O Yes

No

If yes, provide the name of your insurance company and the last four digits of the
policy number. If no, how do you plan to pay for your medical care?

O c_mechica)
e@ \ \ mm ASS Ghance7

If no, are you willing to apply for government medical services (Medicaid/Medicare)?
Yes

O No

Do you have copies of your medical records documenting the condition(s) for which
you are seeking release?

O Yes

ono

If yes, please include them with your motion. If no, where are the records located?
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 3 of 26 PageID
ATTACHMENT TO MOTION FOR COMPASSIONATE RELEASE

Are you currently prescribed medication in the facility where you are incarcerated?

O) Yes

of No

If yes, list all prescribed medication, dosage, and frequency:

Do you require durable medical equipment (e.g., wheelchair, walker, oxygen, prosthetic
limbs, hospital bed)?

O Yes

w No

If yes, list equipment:

Do you require assistance with self-care such as bathing, walking, toileting?

O Yes

of No

If yes, please list the required assistance and how it will be provided:

Do you require assisted living?

Ol Yes

ot No
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 4 of 26 PageID
ATTACHMENT TO MOTION FOR COMPASSIONATE RELEASE

PROPOSED RELEASE PLAN

To the extent the following information is available to you, please include the information
requested below. This information will assist the U.S. Probation and Pretrial Services Office to
prepare for your release if your motion is granted.

A. Housing and Employment

Provide the full address where you intend to reside if you are released from prison:

321% Sw Barbara Pl
Cape Coral, F\ B32aid

Provide the name and phone number of the property owner or renter of the address

where you will reside if you are released from prison:

“Lemaelle Manuel] [ Renter \
O54 - Fo - 1259

Provide the names (if under the age of 18, please use their initials only), ages, and

relationship to you of any other residents living at the above listed address:

Tile | | DR-AcG 4 | Dic month | R podenaicke
( Our dnildren)

COLES EMS | \G_,

If you have employment ses, provide the name and address of your employer and
describe your job duties:

C\eve land Well ness | 2500_Fowler s+: fore Myers,
FL 33401 | Managua “Divectoc

List any additional housing or employment resources available to you:

Tamploument ~ Addon Mutt - Service, Tne
Du ner
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 5 of 26 PageID
ATTACHMENT TO MOTION FOR COMPASSIONATE RELEASE

If yes, please provide address of the anticipated home or facility and the source of
funding to pay for it.

Are the people you are proposing to reside with aware of your medical needs?
Yes

O No

Do you have other community support that can assist with your medical needs?

O Yes

we

Provide their names, ages, and relationship to you. If the person is under the age of 18,
please use their initials only:

Will you have transportation to and from your medical appointments?

ves

O No

Describe method of transportation:

NIN WACe 3 \O Year aid claudnier Wi assist we
Wien jwarspor toon +O appaintmentS F Worle
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 6 of 26 PageID
ATTACHMENT TO MOTION FOR COMPASSIONATE RELEASE

SIGNATURE

I declare under penalty of perjury that the facts stated in this attachment are true and
correct.

Dat Signatu
“DENS CaAssEUS
Name

WA Old -5i0

Bureau of Prisons Register #

Vo Raby Ave, pensacola , FL - 32569

Bureau of Prisons Facility

FRC Pensa cola

Institution’s Address
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 7 of 26 PageID
ATTACHMENT TO MOTION FOR COMPASSIONATE RELEASE

UNITED STATES DISTRICT COURT
FOR THE

MibpL& DISTRICTOF_Floerpa

UNITED STATES OF AMERICA

Case No. 2 2>°6 -9- TP? - KCIld
v. (write the number of your criminal
case)

DEnis CAasseus

Write your full name here.

MEDICAL RECORDS AND ADDITIONAL MEDICAL INFORMATION
In Support of Motion for Sentence Reduction Under 18 U.S.C. § 3582(c)(1)(A)

NOTICE

The public can access electronic court files. Federal Rule of Criminal Procedure 49.1 addresses
the privacy and security concerns resulting from public access to electronic court files. Under
this rule, papers filed with the court should not contain: an individual’s full social security
number or full birth date; the full name of a person known to be a minor; or a complete
financial account number. A filing may include only: the last four digits of a social security
number; the year of an individual’s birth; a minor’s initials; and the last four digits of a

financial account number.

If you attach documents to this form that you believe should not be publicly available,
you may request permission from the court to file those documents under seal. If the
request is granted, the documents will be placed in the electronic court files but will not
be available to the public.

Do you request that the attachments to this document be filed under seal?
C) Yes

No
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 8 of 26 PageID
ATTACHMENT TO MOTION FOR COMPASSIONATE RELEASE

MEDICAL RECORDS AND ADDITIONAL MEDICAL INFORMATION

To the extent you have medical records or additional medical information that support your
motion for compassionate release, please attach those records or that information to this
document.

SIGNATURE

I declare under penalty of perjury that the facts stated in this attachment are true and
correct.

(922| dea Dir W pul)

Date Signature / — / /

DEWss CASSEUS

Name

U201%- Slo

Bureau of Prisons Register #

PPG DenSacola

Bureau of Prisons Facility

[lo Raby Bye. pensacola Fl 3ageg

institution’s Address
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 9 of 26 PageID
Name: Ismaelle Manuel | DOB: 4/7/1991 | MRN: 40326891 | PCP: Lee D Coghill, M.D. | Legal Name: Ismaelle Manuel

Appointment Details

Your Provider's Notes

Progress Notes

Lee D Coghill at 1/17/2024 4:00 PM
Florida State University Coliege of Medicine
Family Medicine Residency Program at Lee Health
Family Medicine Center

Subjective
Patient ID: Ismaelle Manuel is a 32 y.o. female.

The patient's past medical, surgical, family and social history has been updated in the
EHR during today's encounter by clinical staff. | have reviewed and updated as
appropriate in the EHR during the patient's visit today, and all information is available in
the encounter report.

Chief Complaint: Back Pain (Going on for about a year but gets worse at night)

History of Presenting Illness:
ismaelle Manuel is a 32 y.o. female presenting for back pain follow up

Back pain

e History of chronic back pain previously has done PT, tylenol, lidocaine, avoids
NSAIDS due to history of bariatric surgery. Back pain now is higher than it was
previously in thoracic region. Feels right over the bone and has been worsening over
the past few months

e Hasn't been seen in over a year here due to pregnancy, not currently breastfeeding

e Denies any fevers, progressive motor/sensory loss, saddle anesthesias, urinary
retention, urinary/fecal incontinence or weight loss. Patient has no history of
malignancy, osteoporosis, immunocompromising condition, IV drug use, recent
invasive spinal procedure, or significant trauma relative to age.

e Takes calcium and vitamin D supplement.

Review of Systems
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 10 of 26 PageID
BP 105/65 (BP Site: Left Arm, Patient Postion: Sitting, Cuff Size: Regular) | Pulse 60 |
Temp 98.3 °F (36.8 °C) (Tympanic) | Ht 5' 6" (1.676 m) | Wt 133 Ib (60.3 kg) | LMP
01/08/2024 (Exact Date) | SpoO2 100% | BMI 21.47 kg/m?

Wt Readings from Last 3 Encounters:

01/17/24 133 Ib (60.3 kg)
07/19/23 140 Ib 11.2 oz (63.8 kg)
06/07/23 145 Ib 4.8 oz (65.9 kg)

Pain Score: 9-Severe pain, Pain Loc: Middle back
Physical Exam
Vitals and nursing note reviewed.
Constitutional:

General: She is not in acute distress.
Cardiovascular:

Rate and Rhythm: Normal rate and regular rhythm.

Effort: Pulmonary effort is normal.

Breath sounds: Normal breath sounds. No wheezing.
Musculoskeletal:

Right lower leg: No edema.

Left lower leg: No edema.

Comments: Bony tenderness over thoracic spine, no paraspinal
tenderness, ROM within normal limits.
Psychiatric:

Mood and Affect: Mood normal.

Lab Review:
- no new lab studies available for review at time of visit

Assessment and Plan:
Ismaelle was seen today for back pain.

Diagnoses and all orders for this visit:

Chronic midline thoracic back pain (Primary)

Assessment & Plan:
Can use tylenol, flexeril, lidocaine patches, cannot use NSAIDS due to

bariatric surgery

Will obtain XR due to pain > 30 days, bony tenderness, risk of
osteoporosis with bariatric surgery.

If xr within normal limits recommend PT.

Orders:
- XR SPINE THORACIC 3 VIEWS; Future

Nausea and vomiting, unspecified vomiting type
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 11 of 26 PageID
Case 2:23-gh GREG OENZOFRANHOET OPMG ofSlReGHMRHY*Ablel AaRel+ bist BPE!

mouth every 8 hours as needed for Nausea.

Other orders

- cyclobenzaprine (FLEXERIL) 5 MG tablet; Take 1 tablet by mouth every 8 hours
as needed for Muscle Spasms.

All questions/concerns regarding today's visit have been addressed and patient/family
has verbalized understanding.

Return for Physical with Dr. Coghill in 2-3 months.

Lee D Coghill, M.D.

The Florida State University

COM Family Medicine Residency Program
At Lee Health

MA Brittani G at 1/17/2024 4:00 PM
Ismaelie Manuel is a 32 y.o. female who presents and complains of
Chief Complaint
Patient presents with
* Back Pain
Going on for about a year but gets worse at night

Ismaelle does need her medication(s) refilled.

Brittani G., MA

LPN Shawn V at 1/17/2024 4:00 PM
Pre-Visit Planning

Confirm Visit Type: Office Visit
Review last office visit: 8/24/2022 Wong, Hailon T, M.D.

Outstanding Orders Reviewed:
No orders placed

Overdue Health Maintenance Topics:
Health Maintenance Due

Topic Date Due
¢« COVID-19 Vaccine (1) Never done
* YEARLY PHYSICAL ADULT 18+ 04/05/2023
* INFLUENZA (1) 08/01/2023

Is the patient on the diabetes registry? No
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 12 of 26 PageID
Casa re4herd anypouestaiding PBESROE Messages thidt Heéd to Be addtessbage!D
No

Reconciliation Completion:

Medication: No

Records: No

Immunizations: No

Maintenance medications reviewed for necessary refills: No

Have all the Pre-Visit Planning tasks been completed? Yes

MyChart® licensed from Epic Systems Corporation © 1999 - 2024
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 13 of 26 PageID
Name: Ismaelle Manuel | DOB: 4/7/1991 | MRN: 40326891 | PCP: Lee D Coghill, M.D. | Legal Name: Ismaelle Manuel

Appointment Details

After Visit Summary®

AFTER VISIT SUMMARY

Iismaelle Manuel mRN: 40326891

fs) 1/17/2024 4:00 PM © Family Medicine at Lee Memorial 239-343-3831

INStruCctiOns trom Lee D Coghil M.D.

Today's medication changes

START taking:
cyclobenzaprine (FLEXERIL)

Accurate as of January 17, 2024 11:59 PM.
Review your updated medication list below.

Pick up these medications at CVS/pharmac y A 4 - CAPE CORAL, FL -
1003 SANTA BARBARA BL\ VD AT CORN EF a4 NIC HOLAS PARKWAY

* cyclobenzaprine
Your estimated payment per fill: $0

* ondansetron ODT
Your estimated payment per fill: $0

Address: 1003 SANTA BARBARA BLVD, CAPE CORAL FL 33991
Phone: 239-772-4000

Return for Physical with Dr. Coghill in 2-3 months.

Today's Visit

M You saw Lee D Coghill, M.D. on Wednesday January 17, 2024. The following issues were

addressed: Chronic midline thoracic back pain and Nausea and vomiting, unspecified
vomiting type.

Blood Pressure pon BMI .| Weight | Height
105/65 ‘ur 21.47 ~ 133 Ib |5'6"
Temperature Wry, Pulse ©) Oxygen Satura-

(Tympanic) \/ 60 (GY tion

98.3 °F 100%
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 14 of 26 PageID
What's Next

You currently have no upcoming appointments scheduled.

Immunization History Administered as of 1/17/2024

Never Reviewed

Name Date
HPV 8/26/2011
HepA 10/1/2009
HepB 8/26/2011 , 10/1/2009 , 3/19/2009
IPV 3/19/2009
Influenza (Flu Shot) 12/14/2020 , 11/16/2016
MCV4 (Menactra) 3/19/2009
MMR 7/8/2022 , 10/1/2009 , 3/19/2009
Tdap 5/10/2023 , 3/19/2009

Varicella 10/1/2009 , 3/19/2009
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 15 of 26 PageID
PSU MEU Cation List ssstanuayeay, 2024 isa bm Page 19 of 20 Pagelb

@ If you have any questions, ask your nurse or doctor.

cyclobenzaprine 5 MG tablet Take 1 tablet by mouth every 8 hours as
Commonly known as: FLEXERIL needed for Muscle Spasms.
Started by: Lee D Coghill, M.D.

ketoconazole 2 % shampoo Apply topically daily. APPLY TOPICALLY TO
Commonly known as: NIZORAL AFFECTED AREA EVERY DAY

ondansetron ODT 4 MG disintegrating Take 1 tablet by mouth every 8 hours as
tablet needed for Nausea.
Commonly known as: ZOFRAN-ODT

MyChart® licensed from Epic Systems Corporation © 1999 - 2024
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 16 of 26 PageID
Name: Ismaelle Manuel | DOB: 4/7/1991 | MRN: 40326891 | PCP: Lee D Coghill, M.D. | Legal Name: Ismaelle Manuel

Note From Your Admission on 12/16/21

Progress Notes by Irene A Greivell at 12/18/2021 10:53 AM

Attestation signed by Peter M. Denk at 12/18/2021 11:27 AM

The patient was seen and examined, plan formulated in conjunction with my PA.

Doing reasonably well today. The patient seems somewhat timid with liquids and
pills. She is having a slight bit of regurgitation but does not seem to actually have
nausea or true vomiting of gastric contents.

| encouraged her that if she can keep down 30 mL of fluid per hour she should be
fine in terms of hydration and nutrition. She seems stable for discharge home
today. We will give her some Reglan for nausea and a promotility agent that will
likely help with her symptoms temporarily. She can wean off this if it is not needed.

Discharge home today. Full liquid diet with a goal of 70 g of protein per day at
home. She should follow-up with me in the office in the next 1 to 2 weeks.

LMHS Surgery Daily Progress Note
Ismaelle Manuel Admit Date: 12/16/2021 [Hospital day: 2

Problem Assessment/Plan:

* Morbid obesity (HCC)

Assessment & Plan

Postop day 2 laparoscopic sleeve gastrectomy, hiatal hernia repair, cholecystectomy with
indocyanine green.

Labs look fine today. She is tolerating bariatric clear liquids without nausea or emesis. She did
note some dysphagia with pills and had some regurgitation.

Stable for discharge home today. She may shower and bathe. No heavy lifting more than 25
pounds for 1 month. Liquid diet including protein shakes at home. Prescription for Percocet and
Reglan sent into her pharmacy. She should call our office to schedule an appointment for follow-
up in 1 to 2 weeks.
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 17 of 26 PageID
SS

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Progress Note
IProblem Assessment/Plan: |

Patient Active Problem List

Diagnosis

¢ Chronic cholecystitis

¢ Frequency of micturition

* Dyspareunia, female

* Cystitis

* Pelvic pain

* Preop cardiovascular exam

* High blood pressure

¢ Burning chest pain

* Chronic bilateral low back pain without sciatica

* Hiatal hernia

* Mild depression (HCC)
* Intermittent headache
¢ Nexplanon in place

¢ Morbid obesity (HCC)

Chief complaint: No chief complaint on file.

No chief complaint on file.

History:

L2: EPF (HPI 1-3 element, ROS 1 system) L3: D (HPI >=4 element, ROS>=2 system)

(loc,severity,duration,modifier,assoc symptom)

Ismaelle Manuel is a 30 y.o. Black female who was initially admitted to the hospital with the chief

complaint of No chief complaint on file.

PHYSICAL EXAM:

(L2 : EPF >6 element; L3 : ( 2 bullet x 6 system )

Date Noted
12/16/2021
12/15/2021
12/15/2021
12/15/2021
12/15/2021
10/26/2021
10/26/2021
10/26/2021
08/24/2021
06/21/2021
05/03/2021
05/03/2021
02/10/2021
07/22/2019
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 18 of 26 PageID
VETade SIGRS-BPONRKGD-PliSe sPoTeMpYSS-4F | Rew 99/4424 7oBadeH Fol PAVPHAEDKg
(242 Ib 15.2 oz) | LMP (LMP Unknown) | Sp 0% | Breastfeeding No | BMI 38.05 kg/m?

GENERAL APPEARANCE: In no acute distress

HEAD: Normocephalic. No masses, lesions, tenderness or abnormalities

NOSE: Nares normal. Septum midline. Mucosa normal. No drainage or sinus tenderness.
THROAT: Lips, mucosa, and tongue normal. Oropharynx moist

NECK: Neck supple. No adenopathy. Thyroid symmetric, normal size, and without nodularity
LUNGS: Clear bilaterally

CARDIOVASCULAR: $1, S2 normal

ABDOMEN: Incisions clean, dry, intact with Dermabond present. Appropriate incisional tenderness
to palpation.

EXTREMITIES: Extremities normal, no deformities, edema, or skin discoloration

SKIN: Skin color, texture, turgor normal. No rashes or lesions.

intake / Output

Intake/Output Summary (Last 24 hours) at 12/18/2021 1052
Last data filed at 12/18/2021 0402
Gross per 24 hour

Intake Omi

Output 0 ml

Net 0 mi

LABS:

CBC

Lab Results

Component Value Date/Time
WBC 14.5 (H) 12/18/2021 0312
RBC 3.63 (L) 12/18/2021 0312
Hemoglobin 10.8 (L) 12/18/2021 0312
Hematocrit 32.7 (L) 12/18/2021 0312
MCV 90.1 12/18/2021 0312
MCH . 29.8 12/18/2021 0312
RDW 13.0 12/18/2021 0312
Platelet Count 215 12/18/2021 0312
MPV 12.3 12/18/2021 0312

, CMP

Lab Results

Component Value Date/Time
Glucose 105 (H) 12/18/2021 0312
BUN 12 12/18/2021 0312
Creatinine 0.66 12/18/2021 0312
BUN/Crea Ratio 18.2 12/18/2021 0312
Sodium 138 12/18/2021 0312
Potassium 4.4 12/18/2021 0312
Chloride 104 12/18/2021 0312
COQ2 27 12/18/2021 0312

Anion Gap 7 12/18/2021 0312
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 19 of 26 PageID
C&sachuhB-cr-00009-KCD-DNF Docume@t®2-1 Filed 01/24/24 2/187@024%@1126 PagelD

Protein, Total
Albumin

A/G Ratio

Alkaline Phosphatase
AST (SGOT)
Bilirubin, Total

6,794 12/18/2021 0312
3.9 12/18/2021 0312
1.4 12/18/2021 0312
71 12/18/2021 0312
60 (H) 12/18/2021 0312
0.6 12/18/2021 0312

, Magnesium No results found for: MAGNESIUMLVL

WEIGHTS:
Most Recent 5 Weights
12/14/2021 12/16/2021
Weight: 106.1 kg (234 Ib) 110.2 kg (242 Ib
15.2 oz)
Drug Calc — 110.2 kg (242 Ib
(Dosing) Weight: 15.2 oz)
Continuous Medications
* enoxaparin 40 mg Subcutaneous Q24H SCH 1800
(LOVENOX)
SUBCUTANEOUS-
PROPHYLAXIS
* pantoprazole 40 mg Intravenous Q24H SCH
Current Code status: Full Code
DVT Prophylaxis: Currently on
Hematological Agents
Sig

enoxaparin (LOVENOX) injection
40 mg

40 mg, Subcutaneous, EVERY 24 HOURS
SCHEDULED 1800, Administer while patient is LYING
down. Give SubQ ONLY. DO NOT administer in the
midline (navel/belly button) area. Midline administration
can cause hematomas.Administer laterally: Left or Right
abdominal wall ("love handles").Do NOT rub injection
site.Alternate injection sites between the left and right
anterolateral and left and right posterolateral abdominal
wall.

Anti-Embolism Devices: Bilateral; Sequential compression devices, below knee (12/18/21 0823)

12/18/2021
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 20 of 26 PageID
TétabFime 25 MDSOWaCSpephwith Heqatient $2/18/20ale with examining abe satiehE Teveaeihg
relevant EMR labs, orders, consultant plans wherrpertinent, creating the record (20 mins on the
average). Additional time was spent on counseling and coordination of care with other physicians,
radiologist, case managers and pharmacists as deemed pertinent (10 mins on the average).

Medical Decision Making:
This case supports HIGH complexity medical decision making as evidenced by the number and
potential severity of the differential diagnoses given above. Although these diagnoses were
considered, the most likely diagnoses are included under the assessment. Some diagnoses were
excluded from the assessment category by review of the history, physical, labs, radiology and
review of other providers documentation within the EPIC medical record.

- Patient presented with more than 2 chronic problems

- New acute problem identified on admission and required significant work up

- Extensive number of diagnosis or management options are considered above.

- Extensive amount of complex data reviewed.

- High risk of complication and/or morbidity or mortality are associated with differential diagnostic
considerations above.

- There may be Uncertain outcome and increased probability of prolonged functional impairment or
high probability of severe prolonged functional impairment associated with some of these
differential diagnosis.

Medical Data Reviewed:

1.Data reviewed on 12/18/2021 include relevant clinical labs listed above, Medications listed
above, radiology, Medical Tests;

2.Tests results discussed w/performing or interpreting physician;

3.Obtaining/reviewing relevant old medical records;

4.Obtaining case history from another source;

5.Independent review of image, tracing or specimen.

Patient education was provided including the following: review of diagnostics including any
radiologic diagnostics, electrodiagnostic, or laboratory evaluation; and review of possible working
diagnosis and differential diagnosis, and review of possible therapeutic options. The patient was
ready to learn and there were no barriers to learning identified.

Patient education was provided including the following: review of diagnostics including any
radiologic diagnostics, electrodiagnostic, or laboratory evaluation; and review of possible working
diagnosis and differential diagnosis, and review of possible therapeutic options.

All questions were answered
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 21 of 26 PageID
—_ yee

Irene A Julian, P.A.

MyChart® licensed from Epic Systems Corporation © 1999 - 2024
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 22 of 26 PageID
Dear,

Honorable Judge Thomas P. Barber,

| hope this letter finds you in the compassion and understanding that you have for the people and
the court of this great nation. My name is Ismaelle Manuel, Denis Casseus’s wife. | am writing with a
heavy heart to request an early release for my husband and great-father to our kids, Denis Casseus,
Docket No. 2:23-cr-9-TPB-KCD. Who was given permission on December 21*, 2023, to escort
himself to PEN with registration no. 42013-510 Or if possible, give him house arrest, that way he will
at least have a chance to work short hours and help me with assisting our children's needs since |
am not able to work long hours due to medical issues.

| recently visited the doctor because of the severe back pain | have been having due to having 3
major surgeries done at once, gastric sleeve, hiatal hernia repair, and cholecystitis. | was sent to do
an x-ray and | will have to attend therapy during the week too. | will attach my medical record with
this letter for review. | will also attach my mental health paper with this letter.

Honorable please tempered justice with mercy. | know what we did was wrong, but we have
received a lot of punishment for it. | am pleading on behalf of my husband to please allow him to
come to his family because we desperately need his help at home. | will not be able to take care of 5
children alone plus my sick mother due to my health issues. It pains me to see my 19-year-old
intelligent and smart daughter pose her college classes to assist me with her young siblings on top
of that working a night shift job at Health Park Hospital to assist with the family's financial situation.

Your Honor, we have learned from our mistake, and we are remorseful. My husband is a hard-
working father and husband who cares for the wellbeing of his family and without him, we have
been feeling a huge void upon us. | am worried that my 16-year-old daughter who has been having a
hard time each time she thinks about her dad not going to be here to see her walking on the stage of
her high graduation with all her accomplishments over the years. He made a lot of mistakes in his
life, but | watch him grow from them day by day. | believe he learned from his mistake and that he
will not trust people which will lead him to bad behavior.

Your honor, as | mentioned before in my previous motion after the eviction, which has put a lot of
pressure on our family. | appreciate the opportunity you gave me to be able to be home with my
kids. | have used this opportunity to accomplish some good things for my children. After my
sentencing hearing, | enrolled at Florida Academy to become a professional esthetician because |
was having difficulty finding a job as a CAN due to my background check. | finally secured a job at
the Winsor of Cape Coral as a Med Tech/CAN from 10 pm to 6 am so that | can drop my son at
school and get myself ready to go to class. | am also enrolled back at Rasmussen University for
Business Administration. | will be starting classes in March 2024.

Your Honor, we are not bad people, we came to this country as immigrants from Haiti. We earned
our citizenship in the United of America and since we have resided in this country all we did was go

_to school to learn English and go to trade schools and college. We participate in the American
economy by starting businesses and providing jobs to other individuals. But we let all that go to
waste by following a friend's footsteps. | will not say that | nor my dear husband are perfect
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 23 of 26 PageID
individuals, we all make mistakes at some points in life, but some mistakes are hard to repair and
all we can do is accept our fault, take responsibility, be remorseful, and ask for mercy as well as
redemption.

Your Honor, | am submitting the Motion for Sentence Reduction Under 18 U.S.C18 U.S. § 3553
(c)(1)(A) (Compassionate Release) form with the attachment of Proposed Release Plan and the
attachment of my Medical Records and additional Medical Information on behalf of my husband as
he helps me with the completion of the form but since he is absent | will be the one sign it on his
behalf. Please take this case into consideration if it is not for him or me his wife lsmaelle Manuel but
for the future of our 5 beautiful, intelligent, and smart kids (Roodenaicka, 19 yrs. old, college
student at FSW in Biology major) (Junie, 16 yrs. old, will be high school graduate this year) (Josiah, 6
yrs. old, doing amazing in kindergarten), ( Jonah, 4 yrs. old, who is about to go to pre-school this
year) and (Jaelle, our precious 7 months old baby girl who used to her father loves a lot). | know this
motion is for inmates who are not a threat to society and for inmates who have never committed an
offense before and have never committed any crime before. Today, | am using this form to plead for
mercy on behalf of my husband. Please, your honor, grant him with early release or house arrest so
that he can help me with the children with this economy | will not be able to do it alone with 5
children.

| am hopeful that you will temper justice with mercy as a well-known father, husband, and a great
judge of this country who understands people and always works for the best of your nation.

Sincerely,
———"F

Ismaelle Mantel
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 24 of 26 PageID
Dear Honorable Judge Thomas P. Barber,

My name is Ismaelle Manuel, Denis Casseus’s wife. Please | would like to submit this email that
was sent to me by Denis Casseus, Docket No.2:23-cr-9-TPB-KCD, on his behalf.

From: Denis Casseus,

How are you doing today, How are the kids doing? | know you're not feeling good same here, | still
cannot eat, and | cannot sleep well | keep thinking about our kid's life | am thinking how you guys
will be homeless without me because | know how you are sick you cannot really work my life going
through a lot of stress depress, I'm a not feeling well at all bb.

My love please send this later to Honorable Judge THOMAS BARBER for me and please correct any
mistakes before you send it thank you.

Honorable Judge Thomas Barber,

As a responsible Father of five beautiful intelligent kids and a beautiful courageous sick wife,
my family problems have been extremely complicated since | have been in prison my wife Ismaelle
Manuel has been involved in three surgeries she cannot work a full-time job to take this big size
family | would like to get your special attentions on my case a mistake | made by a friend influence
that | paid 10% to do the loan and the calculation shows that | don't own more $ 5000 to the SBA,
therefore, please my Honorable Judge Thomas P. Barber, don't let my daughter Roodenaicka losing
her College opportunity, please my Honorable don't let my family become homeless because of my
mistake | believe | learned enough now I never try to heat no body please thank my Honorable be
understand and compassion thank you. Your honor, | am remorseful, and | am pleading for
forgiveness as well as redemption for my children’s sake. | am willing to work hard to pay the money
back, all | am asking is to grant me early release or house arrest even with an anklet monitor under
supervision will be enough for me to assist my wife and children. | am a hard-working person | can
work to assist her financially as the economy is so high right now.

| know Ismaelle will never find anyone to help her with five children and | already know she cannot
afford that by herself. Please Honorable you have a great Father with a great heart please save my
children's lives and education by compassion to back doing business and work to support my
family thank my Honorable God bless you.

Sincerely,

Denis Casseus
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 25 of 26 PageID
Dear Honorable Judge Thomas P. Barber,

| hope this letter finds you in good health. | am writing to you with a heavy heart to
request the release of my father, Denis Casseus, Docket No. 2:23-cr-9-TPB-KCD, who has been
incarcerated for his involvement in the COVID-19 relief situation.

First and foremost, | want to emphasize the impact my father's absence has had on our family. He is
not only a loving and devoted father but also the backbone of our household. Without him, our
family feels incomplete, like a puzzle missing its essential piece. His presence brings us comfort,
stability, and a sense of unity that we sorely miss.

Moreover, as | approach my senior year, | cannot fathom the thought of spending such a significant
milestone without my father by my side. His unwavering support and motivation have been
instrumental in shaping the person | am today. His guidance and encouragement have pushed me
to strive for excellence, and | fear that his absence will leave a void in my educational journey.

| want to highlight the selflessness my father has displayed throughout this challenging situation.
He willingly shouldered the burden and hardships, protecting our family from the stress and
financial strain that could have engulfed us. His sacrifice speaks volumes about his character and
his commitment to our well-being.

| understand the gravity of the situation and the need for accountability. However, | firmly believe
that my father has learned from his mistakes and is genuinely remorseful for his actions. He is
determined to make amends, not only to our family but also to society as a whole.

| kindly request your compassionate consideration in granting my father early release. His presence
at home is crucial for our emotional and financial stability. We are ready to support him in his
journey towards redemption and reintegration into society.

Thank you for taking the time to read this letter and for your understanding. | trust in your wisdom
and compassion to make a just decision.

Sincerely,

eb)

Junie Casseus
Case 2:23-cr-00009-KCD-DNF     Document 62-1     Filed 01/24/24     Page 26 of 26 PageID
Dear Honorable Judge Barber,

| hope this letter finds you well, my name is Roodenaicka Casseus, | am the daughter of
Denis Casseus. | am writing to you today to discuss my fathers case and to be the most
humbling and request you mercy on the remaining time he serves in prison. My father Denis
Casseus means the world to me and our family. As the head of our household His absence
these last few weeks has tremendously affected our family. It is taking a huge toll on me as the
eldest to sacrifice most of my day to help out with my siblings, weather is picking up my brother
from school, running constant errands and having to work a night shift position at the Healthpark
emergency room, whilst still trying to attend college to obtain my Bachelors in biology. Although
at this time ! have decided to pause my learning after this spring semester due to the inability to
attend my classes regularly and not having my dads financial and physical help to continue on
in school. | also acknowledge and understand the gravity of his actions and respect the court's
efforts to uphold justice, However, | believe that the consequences that my family has and is
facing such as being evicted from the house the state is taking back, trying to find a place to
stay in this economy with four other siblings, our financial hardships, stress, and the ability to
confidently say how we are going to live whilst both of my parents are repaying for the money
they stole, have been a significant punishment in themselves.
Even before my father was sent to prison he was making many efforts to work more and give
us some guidance prior to leaving us, although our time was cut short together he showed us
that he came to an acceptance with your decision despite his effort to show that he is actually a
good citizen who just got mixed up in the wrong ordeal. He believes in therapy and has
amended from his mistakes. We as a family have committed to support my dad through a path
of reformation and are certain that he will make positive changes. Your compassion at this
juncture would not only impact my fathers life but will also provide our family the opportunity to
heal and rebuild. Thank you very much for considering my plea to possibly lessening his
sentence. We trust in your wisdom and outstanding kindness thus far and hope you see beyond

this case and acknowledge the profound effects your decision will have on our lives.

Sincerely, .. .

Roodenaicka Casseus


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