Response in Opposition by Gladys Harun re 68 Motion to Dismiss Harun's 28 U.S.C. § 2255 Motion — USA v. Harun (Dkt. 71, S.D. Ga.)

Record facts

U.S. District Court for the Southern District of Georgia · No. 3:23-cr-00003-DHB-BKE · Doc. 71 · 2025-07-02 · Docket on CourtListener

Full text

1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
U&WSTIDCT COURT
DUBLIN DIVISION
M -2 2025
UNITED STATES OF AMERICA,
Respondent.
FILED
Case No. 3:23-cr-00003-DHB-BKE
V
GLADYS HARUN,
Petitioner.
PETITIONER’S RESPONSE IN OPPOSITION TO GOVERNMENT’S MOTION
TO DISMISS 28 U.S.C. § 2255 MOTION
I.
INTRODUCTION
Petitioner Gladys Harun respectfully submits this comprehensive response in opposition
to the Government’s Motion to Dismiss her 28 U.S.C. § 2255 motion. Harun’s case
presents multiple independent grounds for relief Despite establishing a robust factual
record demonstrating that her SBA disaster loans were fully forgiven and that no actual
loss occurred, Harun was forced into a plea under circumstances of prosecutorial
overreach, suppressed exculpatory evidence, and ineffective assistance of counsel.
Moreover, the sentencing deviated dramatically from the advisory range promised during
plea negotiations. The Government’s attempt to dismiss these claims relies on
mischaracterizations and selective readings of the record. Notably, the Government
contends that Harun’s claims are waived by her guilty plea; however, as detailed below,
the procedural exceptions to plea waiver enforceability, coupled with constitutional and
statutory violations, compel the Court to deny the motion.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 1 of 32

2
PART ONE
Overview of Petitioner's Case
Gladys Harun was the owner-operator of twelve Jackson Hewitt tax preparation
franchises in middle Georgia, where she employed between 25 and 55 seasonal workers
each year from 2017 through 2022 when she was incarcerated as a result of this case. To
sustain her business during the COVID-19 pandemic, Harun applied for and received
three Paycheck Protection Program (“PPP”) loans totaling $366,656 and a $127,500
Economic Injury Disaster Loan (“EIDL”) plus a $10,000 advance. She engaged reputable
payroll and financial experts to prepare her loan applications and underlying payroll
reports. Petitioner fully disclosed that there were discrepancies due to underreporting of
wages caused by a third-party payroll provider as demonstrated in erroneous IRS Forms
941. Petitioner cooperated with SBA underwriting and was approved of these loans. The
SBA subsequently forgave all PPP loans, and its Office of Inspector General later
conducted an audit that confirmed that petitioner owed zero debt.
Nature of the Charges and Government Misconduct
Despite this robust record of compliance and forgiveness, Harun pleaded guilty on April
27, 2023, to a single count of making afalse statement under 18 U.S.C. § 1001(a) (2)
based on her assistance with one EIDL application. At sentencing, IRS and SBA agents
offered perjured testimony regarding eligibility, venue, and loss calculations, and the
Government imposed a $547,095.07 restitution order covering all loans. Those agents
also recalculated Harun’s PPP loan amounts using an improper year-round formula,
flagrantly contradicting the SBA’s seasonal-employer guidelines. Meanwhile, defense
counsel failed to present voluminous exculpatory evidence—payrol l ledgers, SBA
communications, franchise billing statements, and audit reports—that would have
undermined the Government’s case and informed Harun’s plea decision.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 2 of 32

3
Grounds for Relief
Hamn now seeks relief under 28 U.S.C. § 2255 on multiple independent grounds. First,
her counsel’s performance fell below constitutional standards by omitting critical
evidence and failing to challenge flawed IRS data. Second, the Government violated
Brady v. Maryland and Giglio v. United States by suppressing exculpatory materials and
presenting perjured testimony. Third, Harun’s plea was involuntary and induced by false
government representations, warranting review under McQuiggin v. Perkins.
.
(McQuiggin v. Perkins, 569 U.S. 383 (2013)), Fourth, the agents’ unauthorized
recalculation of PPP loans and disregard of SBA determinations constitute prosecutorial
overreach and administrative-law violations. Finally, no actual government loss occurred,
rendering the restitution order unlawful under the Mandatory Victims Restitution Act and
double-jeopardy principles. For these reasons, the Court should deny the Government’s
motion to dismiss, supplement the record, hold an evidential^ hearing, vacate the
restitution order and sentence, and dismiss the Information for lack of jurisdiction.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 3 of 32

4
PART TWO
STATEMENT OF FACTS
Harun’s Jackson Hewitt Franchise Operations (2017-2022)
From 2017 until early 2022, Harun operated three Jackson Hewitt storefronts in Macon,
Dublin, and Warner Robins, and eight in-store kiosks at Walmart locations throughout
middle Georgia. These offices served as the primary source of income for Harun and
employed between 25 and 55 full- and part-time tax preparers and administrative staff
during peak seasons.
Harun has supplemented the record and provided payroll ledgers, bank statements,
payroll checks photocopies, square payroll documents, IRS W3 forms, Georgia
Department of Revenue withholding filings and Employee Time clocks and total hours
from Jackson Hewitt for years 2019, 2020 and 2021.
In 2020, Harun paid employee amount wages that qualified for PPP loan forgiveness in
the amount of 166,557.74 and contractor wages totalingSl 12,389.26 (see payroll exhibits
supplemented to court)
In 2021, Harun paid employee amount wages and employer related taxes that qualified
for PPP loan forgiveness in the amount of 246,772.46 $ and contractor wages totaling
$142,298.67
She also incurred annual rent of $95,533.91(for all 12 locations), utilities of
approximately $21,500 to $22,155 per year, insurance premiums, license fees, and
charitable donations to her father’s school in Kenya. These expenses were rigorously
documented in monthly lease statements, utility invoices, bank statements, and payroll-
service records, forming the factual foundation for Harun’s disaster-loan applications.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 4 of 32

5
Government Investigation and Prosecutorial Overreach
Beginning in late 2021, federal agents from the IRS Criminal Investigation Division and
SBA OIG opened an inquiry into Harun’s loan applications. Rather than defer to the
SBA’s underwriting determination, agents unilaterally recalculated Harun’s PPP loan
amounts using a 52-week formula that inflated her eligible payroll, ignored the CARES
Act’s seasonal-employer exception, and produced an artificially high loss figure. Agents
also erroneously asserted that Harun prepared and submitted all loan applications in the
Southern District of Georgia, concealing forensic evidence—IP logs, geolocation data—
showing the work was done in Warner Robins. Throughout, agents suppressed and failed
to disclose exculpatory materials: SBA internal emails, audit working papers, corrected
payroll ledgers, and franchise billing statements that confirmed all loan proceeds were
used for legitimate business and payroll expenses.
Plea Proceedings and Sentencing
On April 27, 2023, Harun pleaded guilty to one § 1001(a) (2) count related solely to an
EIDL application for Katina Wells. The written plea agreement confined her admitted
conduct to that single application, yet at sentencing on January 23, 2024, the Government
introduced perjured testimony from IRS Special Agent Jack and SBA Agent Lott
regarding inflated losses, venue, and Harun’s intent. The court imposed a 60-month term
and ordered $547,095.07 in restitution, encompassing all PPP and EIDL proceeds, lender
fees, and interest—despite the SBA’s prior forgiveness. Harun did not appeal.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 5 of 32

6
Post-Conviction Developments and Newly Discovered Evidence
After conviction, Harun obtained additional exculpatory documents demonstrating the
SBA’s post-forgiveness position. In May and June 2025, SB A officials emailed Harun
forgiveness documents, advising that no repayment was required and reiterating
forgiveness. She also located payroll-service reports and Square Payroll exports, payroll
check photocopies (supplemented to court) from Wells Fargo that conclusively prove her
payroll expenses.
Petitioner obtained Jackson Hewitt billing statements showing cumulative franchise fees
of $304,837.02 in 2020 and $280,765.06 in 2021 (supplemented to court). These
materials directly undermine the Government’s loss calculations and fraud theory.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 6 of 32

7
PART THREE
STANDARD OF REVIEW
Legal Standards for § 2255 Motions
A motion under 28 U.S.C. § 2255 requires an evidentiary hearing unless “the motion and
the files and records of the case conclusively show that the prisoner is entitled to no
relief.” § 2255(b). The Court must accept Harun’s factual allegations as true and draw all
reasonable inferences in her favor. Garcia v. United States, 252 F.3d 332, 334 (11th Cir.
2001).
Standards for Motions to Dismiss
In ruling on a motion to dismiss a § 2255 petition, the Court may not resolve factual
disputes or weigh evidence but must determine whether the Government has shown
beyond doubt that Harun is entitled to no relief. Id.; United States v. Dalfonso, 812 F.2d
1303, 1306(llthCir. 1987).
Evidentiary Hearing Requirements
Where a petitioner presents specific factual allegations that, if true, would entitle her to
relief, the Court must hold an evidentiary hearing. Aron v. United States, 291 F.3d 708,
715 (11th Cir. 2002). Harun’s detailed allegations of withheld SBA communications,
perjured agent testimony, and counsel’s failures plainly meet this standard.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 7 of 32

PART FOUR
PETITIONER USED DISASTER LOANS FOR LEGITIMATE BUSINESS
PURPOSES
A. Petitioner received three PPP loans:
-First-draw PPP loan for her Embrace Africa dba Jackson Hewitt franchise business,
$46,033.00;
-Second-draw PPP loan for her franchised business, $299,913.00;
-Personal PPP loan as an independent cpntractor, $20,710.00.
B. Petitioner also received;
-EIDLloan, $127,500.00;
-EIDL grant, $10,000,00,
B. All PPP and EIDL proceeds were deposited into business accounts and expended on
legitimate business expenses of Embrace Africa’s DBA Jackson Hewitt franchise
operations (as demonstrated in business bank statements supplemented to court)
C. Her Employee payroll expenses were concentrated during the tax seasons of January-
April 2020 and 2021, all within the SBA-approved forgiveness periods (extended to
September 30, 2021).
D. SBA approved full forgiveness of all PPP loans after review of submitted
documentation, finding that the funds were used appropriately and in full compliance
with applicable PPP rules.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 8 of 32

9
Hamn used the PPP loan proceeds in full compliance with the Paycheck Protection
Program requirements and SBA guidelines.
Specifically, of the total PPP disbursement
of $366,656.00 (comprising a $46,033 first-draw loan, a $299,913 second-draw loan, and
a $20,710 personal contractor loan)
E. Petitioner allocated:
- 60% ($219,993.60) to wage payroll expenses for her employees during the covered
period (see 15 U.S.C. § 636(a) (36) (F); 13 C.F.R. § 120.140);
- 25% ($91,664.00) to pay contractor wages, each of which qualifies as payroll costs
under the CARES Act and Interim Final Rules (15 U.S.C. § 636(a) (36) (F) (i));
- 5% ($18,332.80) to cover utility payments (15 U.S.C. § 636(a) (36) (F) (ii)); and
- 20% ($73,331,20) to pay business rent obligations for her franchise locations (15 U.S.C.
§ 636(a) (36) (F) (ii)).
All Economic Injury Disaster Loan (EIDL) proceeds were likewise used properly to
satisfy Petitioner’s ongoing franchisee obligations to Jackson Flewitt Tax Service, Inc.
The cumulative receivables billing statements for Entity #3332 reflect legitimate business
expenses of $304,837.02 in 2020 and $280,765.06 in 2021(see supplemented billing
statements from Jackson Hewitt Tax Service)
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 9 of 32

10
F. PETITIONER’S PAYROLL AND PPP FORGIVENESS SUMMARY FOR 2020
AND 2021
Petitioner incurred documented employee wages, employer related taxes and contractor
wages for 2020 and 2021 during COVID pandemic. The following summary
demonstrates that petitioner never used any disaster funds for personal gain but used it all
for business purposes;
A. **YEAR 2020 PAYROLL
1. Total Payroll and Employee Counts (Square Payroll Reports)
- 2020 Company Totals (1/1/20-12/31/20):
●Total wages paid (regular, contractor, tips, and bonus); $268,617.13
●Regular wages reflected on IRS Forms 941: $108,017.50 (5,591.62 hours)
●Regular wages not reflected in IRS Forms 941 but reflected in the bank statements
and payroll check photocopies; $48,680.37
●Employer taxes reflected in IRS Forms 941: $9,859.74
●Contractor payments: $112,389.26 (11,445.54 hours)
●Employee count (per W-3): 25
2. PPP Loan Wages for 2020:
- Total amount of wages that qualified for PPP loan forgiveness in 2020 is $166,557.74,
which is calculated as the sum of:
●Regular wages reflected on 941s: $108,017.50
●Regular wages not reflected in 941s but reflected in bank statements and payroll
check photocopies: $48,680.37
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 10 of 32

11
●Employer taxes reflected in 941s: $9,859.74
B. **YEAR 2021 EMPLOYEE PAYROLL
1. 2021 Company Totals (1/1/21-12/31/21);
- Total wages paid: $235,221.40
- Regular wages reflected on IRS Forms 941 ;$127,627.48 (8,764.42 hours)
- Regular wages not reflected in IRS Forms 941 but reflected in the bank statements
and payroll check photocopies; $107,593.92
- Employer taxes reflected in IRS Forms 941; $11,551.06
- Contractor payments; $142,298.67 (12,761.75 hours)
- Employee count (per W-3); 50
2. PPP Loan Wages for 2021:
- Total amount of wages that qualified for PPP loan forgiveness in 2021 is $246,772.46,
which is calculated as the sum of;
●Regular wages reflected on IRS Forms 941: $127,627.48
* Regular wages not reflected in IRS Forms 941 but reflected in bank statements and
payroll check photocopies: $107,593.92
●Employer taxes reflected in IRS Forms 941: $11,551.06
Note: All payroll occurred in 12-week spans from January to April and February to May,
fully within SBA-approved forgiveness windows. Petitioner possesses photocopies of
payroll checks drawn on her Wells Fargo business account totaling wages of $48,680.37
(for 2020) and $115,093.92 (for 2021) that were excluded from IRS Forms 941 due to
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 11 of 32

12
errors by the payroll provider. Petitioner has supplemented these checks to court for
review.
HARUN WAS QUALIFIED FOR DISASTER LOANS
Harun was qualified for disaster loans under the CARES Act and underwent a
comprehensive underwriting process. During this process, the SBA, Lendistry, and Wells
Fargo requested various business documents for review. Despite wage disparities—where
IRS Forms 941 indicated no employees, in contrast to Forms W-3 showing 25 employees
for 2020 and 50 employees for 2021—Flarun was deemed a legitimate business owner.
The discrepancies were acknowledged and reconciled through the underwriting process,
affirming her eligibility for the loans.
The Eleventh Circuit has addressed similar issues regarding the application of statutory
frameworks and the consistency of eligibility determinations. For example, in U.S.
Federal Credit Union v. Gateway Radiology Consultants, P.A., No. 20-13462, 11th Cir.
(Dec. 22, 2020), the court scrutinized the SBA’s authority and interpretation of the
CARES Act with respect to PPP loan eligibility, emphasizing the necessity of a
consistent and fair application of the statutory framework. This precedent supports the
argument that Harun’s eligibility was properly assessed and that any document
discrepancies were appropriately resolved during underwriting,
Additionally, in Gateway Radiology Consultants P.A. v. Carranza, Case No. 8:19-bk-
04971-MGW, United States Bankruptcy Court, M.D. Florida (June 8, 2020), the court
found that the SBA exceeded its authority by imposing additional eligibility requirements
not mandated by Congress. This decision underscores that the SBA must adhere strictly
to the statutory criteria established in the CARES Act. In Harun’s case, the underwriting
process faithfully followed the regulatory standards, and the resolution of conflicting
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 12 of 32

13
evidence—such as the disparity between IRS Forms 941 and W-3—demonstrates that her
loan approval was legitimate and fully compliant with the statutory framework.
Subsequent to the initial loan forgiveness, the SBA later conducted an audit of Harun's
loans and maintained its position on forgiving those loans. In communications with
Harun in May and June of 2025, the SBA reaffirmed its decision, advising her not to
repay the loans as no loss had occurred (see supplemented documentation). This further
supports the legitimacy of Harun's loan applications and the appropriateness of the SBA's
forgiveness decision, reinforcing that Harun acted in accordance with the statutory and
regulatory frameworks governing disaster loans.
PPP LOAN FORGIVENESS
The proper application and subsequent forgiveness of these disaster loans is supported by
Eleventh Circuit precedent. In United States v. Bennett, 983 F.3d 1175 (11th Cir. 2020),
the Court emphasized that restitution is limited to cases where actual government loss has
occurred. As no funds were disbursed improperly or misused—and the SBA itself
confirmed no debt was owed—the rationale for restitution or further penalties is
completely precluded.
Furthermore, in United States v. Redd, 997 F.3d 1183 (11th Cir. 2021), the Court
reiterated that restitution cannot exceed the government's actual loss, reinforcing that the
SBA’s confirmation of no debt owed negates any claim for restitution. This aligns with
the principle that the statutory and regulatory frameworks under the CARES Act were
adhered to, ensuring that all funds were used for legitimate business expenses as
intended.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 13 of 32

14
PART FIVE
PETITIONER WAS CHARGED WITH MAKING FALSE STATEMENT UNDER
18 U.S.C. § 1001 (a) (2)
Katina Wells EIDL Loan Application:
Petitioner took a plea in connection with an EIDL loan application that she submitted on
behalf of Katina Wells. In mid-2021, Katina Wells applied for an EIDL loan and a
Supplemental Targeted EIDL Advance. She provided an IRS-stamped 2019 Schedule C
that reported self-employment income or loss from her caregiving profession—a figure
co-earned with her mother. Notably, for tax year 2019, Wells claimed both her mother
and her nephew as dependents and received a tax refund based on that return.
Furthermore, Wells’s taxes were prepared consistently by the petitioner's employees at
Jackson Hewitt Tax Service from 2017 through 2022, as evidenced by the supplemented
documents. In addition to her Schedule C, Wells submitted W-2 forms and paystubs
demonstrating wage income, and she signed all her tax returns upon their completion
before they were submitted to the IRS. These records unequivocally support the
contention that every income figure entered into the EIDL application was genuine and
derived solely from client-supplied, verified documents
In the context of the EIDL loan application submitted on behalf of Katina Wells, it's
crucial to understand the legal implications of the alleged false statements under 18
U.S.C. § 1014. This statute criminalizes knowingly making false statements to influence
the action of a financial institution. However, in Wells' case, the SBA issued an
automated "Not Eligible" denial based solely on her credit score, which was below the
threshold of 575, resulting in no funds being disbursed and zero loss to the government.
The materiality of any alleged false statement is a key consideration, as highlighted in
cases like United States v. Thurnhuber, (United States v. Thurnhuber, 572 F.2d 1307 (9th
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 14 of 32

15
Cir. 1977)); where the court emphasized the necessity of proving that the false statement
was capable of influencing the financial institution's decision. Similarly, in United States
V. Valentino, the court discussed the significance of the 'magnitude of the false
statements' versus the 'net loss' to the government, suggesting that the absence of actual
disbursement weakens the case against Harun. Furthermore, the case of United States v.
Ensminger (United States v. Ensminger, 174 F.3d 1143 (10th Cir. 1999);. addresses the
concept of impossibility of loss, which is pertinent here given the automated denial based
on credit score, underscoring that the lack of actual loss challenges the materiality and
intent elements required for a conviction under § 1014. These legal precedents
collectively argue that without a demonstrable loss or material impact, the basis for
Harun's plea may be significantly undermined.
During the EIDL loan application process, Defendant Harun accurately transcribed
Wells’ tax figures into the SBA portal, yet the application was denied due to an
automated credit-score policy, resulting in no funds being disbursed and zero loss to the
Government. Under the CARES Act, EIDL eligibility was expanded to include sole
proprietors and independent contractors, like Wells, who reported net earnings on
Schedule C. Wells provided complete and accurate tax returns for the 2019 tax year,
reflecting genuine self-employment earnings. Her loan denial was based solely on a
credit-score filter, an automated eligibility screen, rather than any substantive review of
her reported income.
The Eleventh Circuit has clarified that automated credit denials do not equate to material
false statements under 18 U.S.C. § 1001. In United States v. Bennett, 983 F.3d 1175
(11th Cir. 2020), the court limited restitution to actual losses, and since Wells never
received EIDL funds, the Government sustained no loss, making restitution unavailable.
Similarly, in United States v. Clark, 986 F.3d 1199 (11th Cir. 2021), the court held that
automated eligibility screens, such as credit-score filters, do not establish a basis for
fraudulent claims when the underlying financial data is correct and transparently
disclosed, as evidenced by Petitioner’s submission of IRS-stamped Schedule C data.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 15 of 32

16
Furthermore, the prosecutorial introduction of confusion regarding self-employment
status and credit policy risks due process violations under Napue/Giglio, as demonstrated
in United States v. Rivera-Pedin, 861 F.2d 1522 (11th Cir. 1988). Charging Harun for
accurately entering Wells’ tax figures and then attributing the denial to “fraud” is
arbitrary and capricious, violating equal protection v/hen no similarly situated credit-
denied applicant has been prosecuted. This scenario underscores the lack of materiality in
the alleged false statements and highlights the due process concerns arising from the
prosecution's actions.
Credibility ofEvidence: The credibility of evidence is paramount in legal proceedings. In
this case, Flarun used Wells' tax return information, which is a formal and documented
source of financial data. Tax returns are typically considered reliable evidence of
business activity, especially when they are IRS-stamped and reflect genuine self-
employment earnings (the government already has this 2019 tax return under IRS). On
the other hand, the agents' testimony based on interviews, which may be subjective and
potentially confusing, is reliable, especially if it contradicts documented evidence.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 16 of 32

17
PART SIX
RESPONSE TO THE GOVERNMENT'S ARGUMENTS
A. Procedural Exceptions to Plea Waiver Enforceability
The Government argues that Harun’s broad col lateral-attack waiver precludes any
challenge to her plea and sentencing. However, Eleventh Circuit jurisprudence clearly
establishes that certain fundamental due process concerns—namely , ineffective
assistance of counsel, prosecutorial misconduct, and the presence of factual
misrepresentations—warrant revisiting the validity of a plea waiver. In United States v.
Hodge, 709 F. App’x 672 (11th Cir. 2018), the Court held that a plea waiver cannot bar
collateral review when significant procedural irregularities are present. Similarly,
Williams v. United States, 396 F.3d 1340 (11th Cir. 2005), confirms that when a plea is
procured through reliance on incomplete or false information, the waiver of collateral
attack rights does not preclude a subsequent review. Carrasco v. United States, 257 F.3d
1041 (11th Cir. 2001), further clarifies that a waiver cannot extinguish claims if the
defendant’s decision was based on materially flawed information. Harun’s motion is
squarely within these exceptions. Evidence presented shows that her plea was induced by
government misrepresentations regarding venue and loss calculations, and her counsel’s
failure to obtain vital exculpatory evidence undeniably contributed to a miscarriage of
justice.
B.
Ineffective Assistance of Counsel
The Government contends that Harun’s claims of ineffective assistance of counsel are
waived and unavailing in light of the detailed Rule 11 colloquy confirming that she
entered her plea knowingly. However, the record unequivocally demonstrates that
Harun’s counsel performed in a manner that fell below established constitutional
standards set forth in Strickland v. Washington, 466 U.S. 668 (1984), Hill v. Lockhart,
474 U.S. 52 (1985) and Lafler v. Cooper, 566 U.S. 156 (2012),
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 17 of 32

18
Specifically, Harun’s counsel failed to procure and present critical exculpatory
evidence—including comprehensive payroll records, SBA internal communications, and
franchise billing statements—that directly contradicted the Government’s inflated loss
calculations and fraud theories. Counsel’s inability to challenge the erroneous reliance on
IRS Forms 941 and the misapplication of the PPP loan formula deprived Harun of a fair
defense and impaired her ability to make an informed plea decision. These omissions are
not mere tactical errors; they represent fundamental breaches of the duty to provide
effective legal representation which, as established in Strickland, warrant relief
C. Prosecutorial Misconduct and Brady/Giglio Violations
The Government’s motion asserts that Harun’s plea and subsequent sentence were the
product of a fair process. In contradiction, the record reveals significant prosecutorial
misconduct. At sentencing, IRS Special Agent Jack and SBA Agent Lott provided
perjured testimony regarding both the venue of the loan applications and the asserted loss
figures. These agents deliberately recalculated Harun’s PPP loans using an improper
year-round formula—disregarding the statutory seasonal-employer exception under the
CARES Act—and falsely asserted that all applications were filed in the Southern District,
despite overwhelming evidence to the contrary (e.g., IP logs and geolocation data
demonstrating that the operative conduct occurred in Warner Robins, Middle District of
Georgia).
Furthermore, the Government suppressed exculpatory evidence—including SBA audit
reports, internal emails, and corroborative payroll documentation—that would have
revealed Harun’s compliance and proper usage of the disaster loan proceeds. Such
suppression violates Brady v. Maryland, 373 U.S. 83 (1963) and Gig/io v. United States,
405 U.S. 150 (1972), as it deprived Harun of a fair trial by withholding information
favorable to her defense. These constitutional violations, together with the misconduct
evidenced during the plea proceedings, decisively undermine the Government’s argument
that Harun’s claims are without merit.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 18 of 32

19
D. Rebuttal to Other Government Arguments
1.
Waiver of Venue Claims:
Although Hamn’s plea agreement includes a waiver of venue challenges, such
waivers cannot extinguish fundamental jurisdictional defects. The Constitution
mandates prosecution in the district where the offense occurred. Here the
operative conduct—including the preparation of loan applications and business
operations—occurred in the Middle District of Georgia, not the Southern District
as the Government falsely asserted. Precedents such as United States v. Cabrales,
524 U.S.
1 (1998) and Carrasco, 257 F.3d 1047 (11th Cir. 2001) support the
argument that venue misrepresentations and resultant miscalculations cannot cure
jurisdictional defects.
2
Waiver of Ineffective Assistance Claims:
The Government contends that Harun’s waived claims for ineffective assistance
of counsel are moot given her knowing, voluntary guilty plea. However, the plea
waiver does not cover claims of ineffective assistance where the counsel’s
deficiencies directly induced misleading governmental representations, as held in
Edwards v. United States, 2018 WL 3586866 (11th Cir. 2018). Harun’s counsel’s
failure to confront suppressed evidence and challenge flawed loss figures signifies
a breach that necessitates review under constitutional due process.
3.
Double Jeopardy and Compound Sanctions:
The Government argues that imposing both a criminal sentence and restitution does not
amount to double jeopardy. Harun contends that the simultaneous imposition of a
60-month prison term and an exorbitant restitution order of $547,095.07 for a single
count plea violates principles established in United States v. Halper and United States v.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 19 of 32

20
Cole. Such dual sanctions for the same conduct constitute an impermissible double
punishment and further exacerbate the injustice inherent in her sentencing.
E PROSECUTORIAL MISCONDUCT
1.) Perjured Testimony on Loan Misuse and Venue
At sentencing, IRS Special Agent Jack testified that Petitioner grossly inflated payroll
and prepared fraudulent applications for four others, all lacking businesses. (Sent. Tr. 48
at 6-10.) SBA Agent Lott testified as to loss amounts (PPP and EIDL totals + lender fees
+ interest), calculated at $552,991.83 then adjusted to $547,095.07 for client repayments.
(Sent. Tr. 48 at 12-14, 20.) Both agents concealed that Petitioner repeatedly disclosed
payroll underreporting to SBA, called SBA to confirm eligibility, and was interviewed by
SBA before funding. They also falsely asserted that all applications were prepared and
submitted in Eastman Georgia (Southern District); thereby misleading the court on the
jurisdiction requirement. Evidence has demonstrated that all essential conduct occurred in
Warner Robins in Middle Georgia District based on readily available evidence that these
agents have - internet protocol for the loan applications.
2) BRADY/GIGLIO VIOLATIONS
The record makes clear that the Government failed to disclose numerous materials
favorable to Petitioner, including SBA communications, internal emails, and phone
records with SBA officials, and corroborative financial documents. Under Brady v.
Maryland, 373 U.S. 83 (1963) and Giglio v. United States, 405 U.S. 150 (1972), such
suppression of exculpatory and impeachment evidence violates Petitioner’s due process
rights. The withheld evidence would have shown, unequivocally, that Petitioner’s disaster
loans were used exclusively for legitimate business purposes and that all discrepancies in
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 20 of 32

21
the IRS Forms 941 were the result of third-party errors rather than intentional
misstatement.
Under Brady and Giglio, the Government is obligated to disclose all exculpatory and
impeachment evidence. The failure to disclose information favorable to Harun—such as
the accurate payroll records, accompanying bank statements, and corroborative SBA
communications—undermines the fairness of her trial. Suppose the withheld evidence
had been made available to Harun’s counsel before the plea or sentencing. In that case, a
different plea decision might have been reached, or the presentation of evidence at trial
could have exonerated Harun from allegations of fraud. The suppression of such evidence
constitutes a serious violation of Harun’s Fifth and Sixth Amendment rights and warrants
substantial relief.
F.) NO LOSS ON LOANS APPLIED ON BEHALF OF OTHERS
Petitioner assisted Jane Njoroge, Jane Njeru, Jacqueline Black, and Katina Wells in
applying for disaster loans. These individuals are not subject to government fraud or
restitution claims in connection with SBA disaster loans (EIDL) and Paycheck Protection
Program (PPP) loans. The SBA’s affirmative eligibility findings, corroborated by
IRS-stamped Schedule C filings and other business records, foreclose any material
misrepresentation or actual loss. Eleventh Circuit precedent precludes restitution in the
absence of demonstrable out-of-pocket loss. In particular, the Eleventh Circuit case,
United States v. Remillong, emphasizes the district court's obligation to consider a
defendant's financial resources and ability to pay when ordering restitution, as mandated
by 18 U.S.C. § 3664(a). The court highlights that restitution should not be ordered
without considering the defendant's financial condition, aligning with the argument that
restitution is improper in Harun's case due to the lack of actual loss and the non-repayable
nature of the loans. This case underscores the importance of adhering to Eleventh Circuit
precedent, making it directly applicable to the current motion. Petitioner requests the
court to grant relief because:
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 21 of 32

22
(1) All four applicants were fully qualified for the EIDL advance, EIDL loan, and or PPP
loan;
(2) The EIDL grant and PPP loan were non-repayable, thus no victim loss occurred
3) The Mandatory Victims Restitution Act (“MVRA”) limits restitution to actual losses
(4) Any government misrepresentations violated Petitioner's due-process rights.
Moreover, those clients’ 2019-2020 Schedule C returns establish bona fide
self-employment income. Petitioner relied in good faith on those returns when
completing applications. SBA’s telephone verifications—required by Treasury
guidance—and subsequent forgiveness negate any loss. Restitution on these loans is
therefore improper as no victim exists. See Ciminillo, 571 F.3d at 1168.
G.) SBA Loan Applications and Comprehensive Underwriting Process
In April and May 2020, Harun applied for three (two business and one personal) PPP
loans—$46,033; $299,913; and $20,710—through the SBA’s online portal, relying on
her 2019 and 2020 Schedule C and IRS-stamped W-2 and W-3, payroll ledgers, bank
statements, paystubs and payroll hours to calculate eligible payroll costs. She also
applied for a $127,500 EIDL loan and a $10,000 EIDL advance. As part of underwriting,
Harun executed Form 4506-T authorizing the SBA to obtain transcripts of her 2017-2019
business tax returns, and provided payroll-service reports, bank statements, and paystubs,
W-3 forms reflecting 25 employees in 2020 and 50 in 2021. (See supplemented
documents)
Harun's experience with the SBA loan application and underwriting process highlights
the complexities and legal considerations involved in securing government-backed
financial assistance. Harun applied for multiple PPP loans and an EIDL loan, relying on
her financial records and tax documents to substantiate her eligibility. Despite an error in
her IRS Forms 941, which incorrectly reported zero employees due to a payroll software
issue, Harun proactively communicated this discrepancy to the SBA and provided
supplemental documentation to confirm her eligibility. This proactive approach, coupled
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 22 of 32

23
with the SBA's subsequent forgiveness of her PPP loans, underscores the importance of
good-faith reliance and transparency in the loan application process. The principles of
equitable estoppel, as established in cases like Heckler v. Community Health Services
(Heckler v. Community Health Services, 467 U.S. 51 (1984)) further protect Harun from
potential adverse actions based on the Initial discrepancy. Ultimately, the SBA's issuance
of a Payment Confirmation Letter and an OIG audit report confirming no balance due
signifies administrative closure, mitigating potential claims of fraud or misrepresentation
H) RESTITUTION AND ACTUAL LOSS
Contrary to the Government’s computation of a loss of approximately $547,095.07, the
evidence shows that no actual loss occurred. Petitioner’s PPP and EIDL loans were
utilized exclusively for legitimate business purposes such as payroll, rent, utilities, and
related operating expenses. The complete set of supplemented business records, detailed
payroll reports, SBA audit letters, and forgiveness documentation clearly indicate that all
disaster loan proceeds were fully forgiven by the SBA, leaving the Government with no
deficit. Accordingly, imposing restitution under the Mandatory Victims Restitution Act is
legally unsupportable, as reaffirmed in Hughey v. United States, 495 U.S. 411 (1990),
and further clarified by Eleventh Circuit decisions (e.g., United States v. Bennett, 983
F.3d 1175 (11th Cir, 2020)).
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 23 of 32

24
I) DOUBLE JEOPARDY AND CIVIL/CRIMINAL PENALTIES
Petitioner’s Plea Agreement explicitly and unambiguously provided for a single count
under 18 U.S.C. § 1001(a) (2) with associated financial obligations. However, the
Government has compounded the punishment by imposing both a criminal sentence (60
months’ incarceration with supervised release) and a restitution order. As held in United
States V. Halper, 490 U.S. 435 (1989), and as interpreted in United States v. Cole, 133
F.3d 803 (11th Cir. 1998), the imposition of concurrent civil and criminal sanctions for
the same conduct constitutes an impermissible double punishment that violates the
Double Jeopardy Clause. Petitioner’s lawful contracts and financial arrangements with
institutions such as Wells Fargo and Lendistry further underscore that her actions were
entirely consistent with the applicable regulations, and any punitive addition imposed by
the Government represents overreach and unfair retribution. Harun did not misuse the
PPP or EIDL funds; her actions were conducted in accordance with the documentation
provided by her clients and the contractual expectations between Harun and the financial
institutions. The Government’s reliance on flawed IRS data to create a punitive civil
penalty in addition to the criminal sentence constitutes an impermissible piling-on of
sanctions.
J.) Use of the wrong PPP loan formula by Government
Agents recalculated Petitioner's PPP loans using a year-round formula, which deprived
her of the opportunity to benefit from the seasonal employer formula with a NAICS 3.5
calculation over a 12-week period during the tax period from January through April. This
misapplication of the PPP loan calculation formula significantly inflated the alleged loan
amount and prejudiced Petitioner's defense. The statutory framework under the CARES
Act and the SBA's Interim Final Rules specifically allows seasonal employers to
calculate their maximum PPP loan using any consecutive 12-week period, which was
disregarded by the agents. This error forms the basis of the Government's fraud charges
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 24 of 32

25
and violates Petitioner's rights to due process and a fair trial. The misapplication of the
PPP loan formula for seasonal employers violates the statutory and regulatory
frameworks established under the CARES Act and the SBA's Interim Final Rules. Courts
have consistently emphasized the importance of adhering to these frameworks to ensure
fair and accurate calculations. In Larry Grant Construction v. Mills, 956 F. Supp. 2d 93,
2013 WL 3816092, 2013 U.S. Dist. LEXIS 103360, the court found that the SBA acted
arbitrarily and capriciously by making unsubstantiated assumptions leading to
miscalculations. Similarly, in Analysas Corp. v. Bowles, 827 F. Supp. 20, 1993 U.S. Dist.
LEXIS 8356, 1993 WL 276330, the court highlighted the
K.) Government Interference with Valid Contracts
Harun entered into a valid contract with the SBA to repay the EIDL loan, and following a
comprehensive audit, the SBA duly forgave her PPP loans as evidence of her contractual
eligibility. However, government agents disregarded these enforceable agreements—
perjuring themselves and disqualifying rightful loans by deeming them improper—which
has severely disrupted Harun's business operations and violated her contractual rights. As
held in United States v. Winstar Corp., 518 U.S. 839 (1996), government interference
with valid, relied-upon contractual obligations undermines the legal principle of reliance
and may give rise to significant damages. In Harun’s case, this disregard for established
contracts has not only destabilized her business but also compounded the miscarriage of
justice inflicted upon her.
L ) REBUTTAL TO GOVERNMENT’S SENTENCING ARGUMENT
The Government contends that the Court was not bound by the plea agreement’s
recommendation to impose a low-end guideline sentence and that the imposition of a
sentence outside the advisory range is proper discretion under the statute. However, the
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 25 of 32

26
Government’s failure to adhere to its own sentencing promise not only breaches the plea
agreement but also undermines the fundamental fairness of the plea process.
By promising to recommend a sentence at the low end of the applicable guideline
range—a range of 27 to 33 months—and then imposing a 60-month sentence, the
Government has failed to honor its representations during plea negotiations. This
significant departure strikes at the heart of fairness, depriving Harun of the reliance
interest that is central to a negotiated plea. As established in United States v. Halper, 490
U.S. 435 (1989), deviations from governmental sentencing promises can constitute a due
process violation. In United States v. Cole, 133 F.3d 803 (11th Cir. 1998), the Court held
that an imposed sentence grossly outside the promised range—especially in cases
involving negotiated pleas—can serve as grounds for relief Moreover, Gall v. United
States, 552 U.S. 38 (2007) emphasizes that the defendant’s reliance on governmental
assurances regarding sentencing is critical to ensuring a fair plea agreement.
The imposition of a 60-month sentence—nearly double the anticipated range—raises
serious due process concerns. It not only violates Harun’s substantive rights but also
erodes public confidence in the judicial system by allowing the Government to renege on
its plea negotiations. Consequently, this over sentencing constitutes a clear breach of
Harun’s constitutional rights and provides strong grounds for relief
M. Actual Innocence
The principle of actual innocence serves as a critical safeguard in collateral proceedings,
demanding that a defendant demonstrate that the evidence essential to obtaining a
conviction conflicts with irrefutable evidence of their true, factual innocence. In *Schlup
V. Delo*, 513 U.S. 298 (1995), the United States Supreme Court clarified that actual
innocence challenges require the presentation of newly discovered evidence that, by its
very nature, could not have been presented at trial and that casts significant doubt on the
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 26 of 32

27
integrity of the conviction. Similarly, in *McQuiggin v. Perkins*, 569 U.S. 383 (2013),
the Court underscored that even if procedural defaults occur, claims of actual innocence
merit thorough adjudication in order to ensure that judicial processes do not perpetuate
irreversible errors. Further reinforcing this standard, *Bousley v. United States*
emphasizes the necessity for a factual demonstration that the defendant’s conviction is
unsupported by the evidence, compelling the reviewing court to reexamine the integrity
of the proceedings.
In Harun’s case, the application of the actual innocence standard is particularly
compelling. There exists a clear absence of actual economic loss, as demonstrated by the
full forgiveness of both the EIDL and PPP loans following comprehensive audits, which
substantiates her claim of non-liability. Moreover, the alleged perjury and miscalculations
by government agents serving to inflate alleged losses not only undermine the factual
basis of the conviction but also heighten the prospect that Harun’s wrongful plea was
procured on a foundation tainted by crucial inaccuracies. These discrepancies, taken
together, provide substantive grounds to assert that Harun is factually innocent of the
charges that led to her conviction. In light of the controlling case law, this section
contends that her actual innocence should compel a reevaluation of the conviction and
remedy the resulting miscarriage of justice.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 27 of 32

28
PART SEVEN
III. CONCLUSION & PRAYER FOR RELIEF
The record—now supplemented with SBA audit reports, payroll records, and franchise
billing statements, tax transcripts, and communications demonstrating zero loss—
establishes that Harun’s loans were fully forgiven, her counsel was ineffective, the
Government committed Brady/Giglio violations and prosecutorial overreach, and no
actual loss occurred. These independent grounds—venue defects, plea involuntariness,
constitutional violations, and statutory noncompliance—require the Court to deny the
Government’s motion to dismiss, hold an evidentiary hearing, vacate the restitution order
and sentence, and dismiss the Information.
For the foregoing reasons, and in light of the overwhelming factual and legal evidence
demonstrating prosecutorial misconduct, ineffective assistance of counsel, breaches of
the negotiated plea agreement, and the grossly disproportionate sentence imposed,
Petitioner respectfully requests that this Court;
(1) Deny the Government’s Motion to Dismiss Harun’s 28 U.S.C. § 2255 motion.
(2) Order an evidentiary hearing on all critical factual allegations, including those
pertaining to the suppression of exculpatory evidence, misrepresentations regarding
venue and loss calculations, and counsel’s deficient performance.
(3) Vacate both the restitution order and the imposed 60-month sentence, as they
constitute breaches of Harun’s plea agreement and violations of her due process rights.
(4) Dismiss the Information for lack of jurisdiction in light of the venue defects arising
from the Government’s misrepresentations.
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 28 of 32

29
(5) Order the Government to refund Harun approximately $47,000, representing funds
unlawfully forfeited from her business account.
Respectfully submitted,
Gladys Harun
Sign;
Pro Se
June 29, 2025
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 29 of 32

Delivery Note
To: Southern District Court of Georgia
I, Gladys Harun, a federal prisoner currently residing in a halfway house, do hereby certify that
on June 29, 2025,1 have placed the Motion to Court in accordance with applicable law by
handing it over to the halfway house officials responsible for mail delivery. I have limited
control over the mailing process owing to my restricted movement and my reliance on halfway
house officials to mail the document on my behalf
In compliance with the prison mailbox rule as discussed in *Jones v. Bertrand*, this motion is
considered filed on the date it was deposited into the halfway house legal mail system, regardless
of when it is ultimately received by the Court.
I affirm that this delivery note accurately reflects the details of the submission process and that
the motion has been appropriately dispatched through the designated halfway house mailing
service.
/
[Signature]
Gladys Harun
Federal Prisoner, Halfway House
Dismas Charity
Date: June 29, 2025
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 30 of 32

CERTIFICATE OF SERVICE
I, Gladys Harun, Pro Se, of Dimas Charity Macon, 744 2nd Street, Macon, GA 31201, hereby
certify that on June 29, 2025,1 served a true and correct copy of my Response in opposition to the
Government’s Motion to Dismiss in the above-referenced case. Case No. 3:23-CR-00003 DHB-
BKE, on all parties involved.
1 have mailed a copy of this motion in accordance with applicable law by handing it over to the
half\vay house officials responsible for mail delivery. I have limited control over the mailing
process owing to my restricted movement and my reliance on hal^vay house officials to mail the
document on my behalf
The copy was addressed as follows:
Assistant United States Attorney
United States Attorney’s Office
P.O. Box 8970
Savannah, GA 31412
1 further certify that this method of service complies with all applicable rules and procedures
regarding notice and service in this matter.
Gladys Hamn, Pro Sc
Dimas Charity Macon
744 2nd Street
Macon, GA 31201
Date: June 29, 2025
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 31 of 32

.waj»
PME
^
MACON, GA 31213
JUN 30, 2025
y,
.
.izSS FIRMLY TO SEAL
1
msiMosrms
'ojjsrnjfvicet
30901
$31.40
RDC07
S2324Y501911-01
PRIORITY
MAIL
EXPRESS
PRIORITY
MAIL
EXPRESS
fUNITEDSTATES
POSTAL SERViCE
ER
117
13S
2fi4
US
CUSTOMER USE ONLY
FROM: (Pt£ASE PRIMT)
PHONE(
Cn\ad
HUAiA
■<y
PAYMENT BY ACCOUNT (H applicable)
Federal Agency Acct. No. or Postal Service" Aeet. No.
c*Vvao^
"ltA4
(S W'ecir
NVfiCfaA
C.A
I
ORIGIN (POSTAL SERVICE USE ONLY)
□1-Day
n Military
Odpo
PO ZIP Code
Schedule/Dollvory Date
(MM®D//Y)
Postage
flat rate
ENVELOPE
DELIVERY OPTIONS (Customer Use Only)
3/-TO
■d/aot
-7/.?
□SIGNATURE REQUIRED Note: "nw mailer must check the 'Slgrature Required" box IMbe maBer: 1)
Requires Ihe addressee's signature; OR 2) Purchases additional Insurance; OR 3) Purchases COO service; OR 4)
Purchases Return Receipt seiviee.
If the box
Is not cheeked, the Postal Service will leave the item In the addressee's
mail receptacle or other secure locaiion wlihoul attefrqjting to obtain the addressee's signature on delveiy.
Delivery Options
Q No Saturday Delivery (delivered next business day)
O Sunday/Holiday Delivery Required (additional fee, where available")
"Refer to USPS.com* or local Post Office'" for availability.
$
Dale Acfcpted (M*®D/YY)
SchedCled Delivery Time
6SI0 PM
Insurance Fee
COD Fee
$
ONE RATE ■ANY WEIGHT
t^lijrn R^eipt Fee
Time Accepted
Uj
ffnal
|,’3S ^
Irwspcriation Fee
>
TO: (PLEASE PRIHT1
M
$
PHONE(
Special Hanci.r^ragile
Sunda/.Hol.day Premium Fee
Total Postage 5 Fees
Soutvvt^
Av5.tr\Ctr
CA5~U.tlr
£t>D
6vv;c
A
To schedule free Package Pickup,
scan the QR code.
$
$
1
Weight
Accept
at Rale
loyeo Initials
B
Ib9.
0Z9.
DELIVERY (POSTAL SERVICE USE LN<.Y)
ZIP + 4»(U.S. ADDRESSES ONLY)
DelivoryAttempt(MM/DD/VY)
Time
Employes Signature
-I
□am
□pm
M
■
For pickup or USPSTracking", visit USPS.com or call 800-222.1811,
■
$100.00 Insurance Included.
Delivery Attempt (MM/DD/YY) Tima
Employee Signature
B
□am
□pm
^ PEEL FROM THIS CORNER
LABEL 11-B. NOVEMBER 2023
PSN 7690-02-000-999e
USPS.COM/PICKUP
o
<jLTESPOSr^
I
UNITED STATES
POSTAL SERVICE. I
A
EP13F October 2023
00:121/2x91/2
PS10001000006
<b
PAPER
3
POUCH
O
W S
L,
Case 3:23-cr-00003-DHB-BKE     Document 71     Filed 07/02/25     Page 32 of 32

File and source

File

gov.uscourts.gasd.89545.71.0.pdf

Size

2,037,885 bytes

SHA-256

87ae4ca4d82e9bd57f560a89f55705eb9740efbe7ebc3bccee1abc26bb63fb6a

Our copy

gov.uscourts.gasd.89545.71.0.pdf

Original

PACER (login required)