Sentencing Memorandum — No. 2:22-cr-20355 (Dkt. 26, E.D. Mich.)

Summary

Defendant Semaje Reffigee's sentencing memorandum requesting a variance under 18 U.S.C. § 3553 in USA v. Semaje Reffigee, Case No. 22-20355, in the U.S. District Court for the Eastern District of Michigan before the Hon. Matthew F. Leitman, filed July 11, 2023 as ECF No. 26. It states that she pled guilty to a one count information charging conspiracy to commit wire fraud under 18 U.S.C. § 1349, with a guideline range of 27 months to 33 months and a loss amount of $313,497.00. It cites her acceptance of responsibility, lack of a prior record and family circumstances, and attaches character references as Exhibit A.

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Case 2:22-cr-20355-MFL-EAS ECF No. 26, PageID.131 Filed 07/11/23 Page 1 of 4




                           UNITED STATES DISTRICT COURT
                           EASTERN DISTRICT OF MICHIGAN
                                SOUTHERN DIVISION


USA

       Plaintiff,
                                                      Case No. 22-20355
-vs-
                                                      Hon. Matthew F. Leitman
SEMAJE REFFIGEE,

     Defendant.
_______________________/

                            SENTENCING MEMORANDUM
                            VARIANCE (18 U.S.C. § 3553)

       Defendant Semaje Reffigee pled guilty to a one count information charging her

with Conspiracy to Commit Wire Fraud in violation of 18 U.S.C. § 1349.

       The presumptive guideline range is 27 months to 33 months. The amount of loss

was $313,497.00.

       Defendant Semaje Reffigee has no prior criminal record, approximately 26 years

of age and is the devoted mother of a seven-year-old. She currently resides with her

grandmother and disabled uncle, and was residing at this premise during the course of

the criminal violations.

       The following were extracted from the Presentence Investigation Report, ECF 22,

in support of request for variance:

       20.    Adjustment for Acceptance of Responsibility

              The defendant clearly demonstrated acceptance of responsibility for
              her offense and has assisted authorities in the investigation or
              prosecution of her own misconduct by timely notifying authorities of
              her intention to enter a plea of guilty, thereby permitting the

Case 2:22-cr-20355-MFL-EAS ECF No. 26, PageID.132 Filed 07/11/23 Page 2 of 4




              government to avoid preparing for trial and permitting the
              government and the court to allocate their resources efficiently.

       40.    Personal and Family Data

              Reffigee reported that her family is aware of instant case and provide
              her with moral support. Reffigee reports spending most of her time
              with her grandmother, Alfreda Baldrige, who resides next door, and
              with her daughter. When asked to describe how she felt about the
              offense, Reffigee replied, “I feel really ashamed about this offense. I
              feel like this was very unnecessary of me and out of character. This
              offense has impacted my friends and family in a negative way. They
              are really disappointed. Peers and people around me began to
              influence my decisions. I could have abided by the work policy and
              not told anyone what my job was. In the future, I will always do the
              right thing. I will know how to say no and think for myself.”

       43.    If sentenced to a term of imprisonment, Reffigee states “I will focus
              on a degree in Business and also learn how to manage my finances
              better by reading financial books. I will also focus on doing
              everything I can to get back home to be the best mom to my
              daughter. I would like the judge to know that I am a great mom. I
              am a good citizen in society. I do my very best to take accountability
              and correct my mistakes. I am young and still learning but this
              offense has taught me a lot.”


       The above are strongly evident of the basis for request for variance indicating

immediate acceptance of responsibility, as well as expressions of remorse and intention

to learn from this mistake, to be a better citizen, person and “best mom.”

       Defendant further indicated that after the first positive testing for marijuana, she

was tested three times thereafter with negative results which should be considered in

support of her expression of remorse, as well as intension to comply with the law to be a

better overall person.

       It should be further considered by this Honorable Court that the money pocketed

by Defendant Semaje Reffigee was used solely for maintenance and support regarding

her responsibilities as mother and tenant in her grandmother’s house, and to provide care

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Case 2:22-cr-20355-MFL-EAS ECF No. 26, PageID.133 Filed 07/11/23 Page 3 of 4




and attention to her disabled uncle who is paralyzed on his left side due to a stroke and

ambulates with a cane. None of the monies were used for “bling” or other extravagant

indulgences or unnecessaries.

       Defendant Semaje Reffigee further participated in a proffer and implicated others

involved and offered to be a cooperating witness, but as of this date, there is no indication

that prosecution has been initiated against others involved in the fraud.

       Enclosed herewith are character references in support of Sentencing

Memorandum with request for variance (18 U.S.C. § 3553) (Exhibit A).

       This Honorable Court should consider with regard to request for Variance are

those set forth in the PSR as previously outlined.          Most specifically, Defendant’s

adjustment for Acceptance of Responsibility, as well as Personal and Family Data.

       Defendant Semaje Reffigee respectfully asks this Honorable Court to impose a

sentence of one year and one day with corresponding supervised release which will

reflect the seriousness of the offense, as well as to promote justice for the law and provide

appropriate punishment, and further that the place of incarceration should be in close

proximity to her residence.

                                                  THOMAS LEGAL CENTERS, P.C.

                                                  BY: s/Thomas W. Jakuc______
                                                      22811 Greater Mack, Ste. 204
                                                      St. Clair Shores, MI 48080
                                                      586-573-2694
                                                      Thomasjakuc@sbcglobal.net
                                                      P15426



Dated: July 11, 2023




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Case 2:22-cr-20355-MFL-EAS ECF No. 26, PageID.134 Filed 07/11/23 Page 4 of 4




************************************************************************************************

                                 CERTIFICATE OF MAILING

        I certified that a copy of Sentencing Memorandum Variance (18 U.S.C. § 3553)
and this Certificate of Mailing was mailed to all attorneys of record on this date of July
11, 2023 by electronic and/or ordinary mail.


                                                     s/Joyce J. Crechiolo________
                                                     Secretary to Thomas W. Jakuc
                                                     (586) 573-2694

Dated: July 11, 2023




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