Objections to Presentence Investigation Report by Emmanuel Bully, Jr — USA v. Bully (Jr) (Dkt. 23, S.D. Fla. No. 9:23-mj-08415, docketed in No. 9:23-cr-80141)

Record facts

U.S. District Court for the Southern District of Florida · No. 9:23-cr-80141-DMM · Doc. 23 · 2023-11-15 · Docket on CourtListener

Full text

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IN THE UNITED STATES DISTRICT COURT  
SOUTHERN DISTRICT OF FLORIDA 
 
UNITED STATES OF AMERICA, 
) 
) 
Plaintiff, 
) 
) 
v. 
) No. 23-cr-80141-DMM 
) 
EMMAUEL BULLY, JR. 
) 
) 
Defendant. 
) 
 
DEFENDANT’S OBJECTIONS TO PRESENTENCE INVESTIGATION REPORT 
Comes now Defendant, by his undersigned attorney, and for his Objections to 
Presentence Investigation Report states: 
Introduction 
Probation Officer Garcia is to be commended for the thoroughness of the 
Presentence Investigation Report. Her thoroughness is impressive in light of the limited time 
she had to prepare the PSR. 
The PSR was received by the undersigned on November 1, 2023, and it was sent to 
Mr. Bully for his review shortly after. On Sunday November 12, 2023, the undersigned 
met with Mr. Bully and went through the PSR. He advised the undersigned which 
objections he desired to make to the PSR. 
Thereafter, the undersigned spoke with Mr. Bully to ensure that Mr. Bully desired to 
make the following objections to the PSR. As such, the objections are made with 
Defendant’s knowledge and at his behest. 
Case 9:23-cr-80141-DMM   Document 23   Entered on FLSD Docket 11/15/2023   Page 1 of 3

 
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Since a final PSR has not been prepared and since objections are due this date, the 
undersigned is filing these objections and, if need be, will file amended objections 
depending on the ultimate conclusions reached by Officer Garcia. 
Objections 
 
1. Defendant objects to paragraph 17 and states that to the best of his knowledge 
that MB Tax Consultants was reinstated with the Florida Division of Corporations on 
February 24, 2020.  
2. Defendant objects to paragraph 25 and states that to the best of his knowledge 
he did not intend, and could not have had such intention, to attempt to obtain “$1,394.27” 
because the applications did not specify any amount sought or requested, and the 
Defendant did not know what if any funds were going to be provided in connection with 
any application submitted by the Defendant. 
3. Defendant objects to paragraph 42 and states that although he was arrested on 
May 18, 2011, for driving under the influence (the “DUI”), that conduct is wholly 
unrelated to the current and isolated conduct the Defendant is being sentenced for now; 
which was heavily influenced by the COVID pandemic. Moreover, the DUI is almost 10 
years from the conduct that forms the subject of this action. 
4. Defendant objects to paragraph 57 and states that his back injury requires 
physical therapy due to the surgeries to repair it and resulting chronic condition.  
5. Defendant objects to paragraph 68 and states that to the best of his knowledge 
he completed approximately 45 credits. He earned 30 credits in his first year alone and 
attended during the summer sessions as well.   
6. Defendant objects to paragraph 70 and states that to the best of his knowledge 
that he did graduate and participated in the graduation ceremony. 
7. Defendant objects to paragraph 81 and states that to the best of his knowledge 
he sold the Maserati (the “Vehicle”) in 2019 to a car dealership in Delray Beach, off 
Case 9:23-cr-80141-DMM   Document 23   Entered on FLSD Docket 11/15/2023   Page 2 of 3

 
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Linton Blvd. just I-95 East (across from the McDonald’s and next to the Mercedes Benz 
dealer), which is no longer in business. Notwithstanding the forgoing, under no 
circumstances did the Defendant knowingly misrepresent his ownership of the Vehicle 
to Officer Garcia. 
8. Defendant files these objections to merely clarify the record and hopes to 
resolve these objections prior to the current sentencing hearing on December 7, 2023, 
and is not desirous of delaying or postponing said hearing. 
WHEREFORE, Defendant hereby files his objections to the Presentence 
Investigation Report and respectfully asks that the Government be required to carry its 
burden to prove the conclusions contained in the PSR in connection with any unresolved 
objections herein. 
The Bravo Law Firm, PLLC  
 
/s/ Jason Bravo 
Jason Bravo, Esq. 
FL Bar. # 85743 
368 Minorca Avenue 
Coral Gables, FL 33134 
 
 
 
 
 
 
 
jbravo@thebravolawfirm.com  
 
 
 
 
 
 
 
admin@thebravolawfirm.com 
T: 786.732.0065 
 
Certificate of Service  
I certify that on November 15, 2023, this document was filed with the 
Clerk’s CM/ ECF System, which will provide notice to all parties.  
 
                                            
 
/s/ Jason Bravo 
 
 
 
 
 
 
 
Jason Bravo, Esq. 
 
 
 
 
 
 
 
FL Bar. # 85743 
 
The Bravo Law Firm, PLLC 
Jason Bravo 
368 Minorca Avenue 
 
 
 
 
 
 
 
Coral Gables, FL 33134 
 
 
 
 
 
 
 
T: 786.732.0065  
Case 9:23-cr-80141-DMM   Document 23   Entered on FLSD Docket 11/15/2023   Page 3 of 3

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