Court filing
POSITION WITH RESPECT TO SENTENCING FACTORS filed by Plaintiff USA as to Defendant… — United States v. Quadri (Dkt. 38)
No. 2:24-cr-00617-GW · Doc. 38 · Docket on CourtListener
Full text
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 1 of 28 Page ID #:167
1 BILAL A. ESSAYLI
United States Attorney
2 CHRISTINA T. SHAY
Assistant United States Attorney
3 Chief, Criminal Division
ANDREW BROWN (Cal. Bar No. 172009)
4 Assistant United States Attorney
Major Frauds Section
5 1100 United States Courthouse
312 North Spring Street
6 Los Angeles, California 90012
Telephone: (213) 894-0102
7 Facsimile: (213) 894-6269
E-mail: andrew.brown@usdoj.gov
8
9 Attorneys for Plaintiff
UNITED STATES OF AMERICA
10
11 UNITED STATES DISTRICT COURT
12 FOR THE CENTRAL DISTRICT OF CALIFORNIA
13 UNITED STATES OF AMERICA, No. 2:24-CR-617-GW
14 Plaintiff, GOVERNMENT’S SENTENCING POSITION
15 v. Sentencing: July 10, 2025
8:00am
16 ABIOLA FEMI QUADRI,
17 Defendant.
18
19 I. DEFENDANT’S OBJECTIONS ARE LATE AND SHOULD BE DISREGARDED
20 The Presentence Report (PSR) was disclosed on March 20, 2025.
21 (ECF 30.) Under Rule 32, defendant’s objections were due within
22 fourteen days. Defendant failed to file his objections, however,
23 until April 23 (ECF 34), 20 days late. Cf., Local Criminal Rule 32-
24 3.2 (“Counsel are required to observe strictly the requirements of
25 F.R.Crim.P. 32(f) regarding objections to presentence reports”)
26 (emphasis added). Although the court "may, for good cause shown,
27 allow a party to make a new objection at any time before sentence is
28 imposed," Rule 32(i)(1)(D), defendant has not even alleged good
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 2 of 28 Page ID #:168
1 cause for his delay, let alone shown it. Accordingly, the court
2 should disregard as untimely defendant’s objections which, as
3 described below, are ineffective as bare denials in any event.
4 II. DEFENDANT’S OBJECTIONS FAIL LEGALLY AND ARE UNSUPPORTED BY
FACTS
5
Defendant offers a series of vague objections without
6
addressing either the facts or the law. None of them is effective.
7
Loss: While defendant does not dispute that that “fraudulent
8
funds contemplated by the conspiracy were in the amount of
9
$7,996,182.54, the Defense will contend Mr. Quadri is not
10
responsible for this total amount.” (ECF 30, page 1.) Defendant
11
offers no facts to support his contention, nor does he indicate what
12
portion of the loss he is “not responsible for,” so it is impossible
13
for Probation or the government even to understand defendant’s
14
position, let alone respond to it. (Cf., ECF 35, Addendum to the
15
PSR, rejecting defendant’s objection because he did not offer any
16
“new facts or previously unconsidered authority”.)
17
Sophisticated Means: Defendant similarly “objects” to the
18
Probation Office’s finding that he employed sophisticated means in
19
carrying out his fraud. Again, defendant offers no facts or legal
20
support for his position, unhelpfully stating: “Mr. Quadri did not
21
employ sophisticated means.” (ECF 30, page 2.) While defendant
22
does concede that he withdrew stolen funds from ATMs, he asserts
23
that is the “only” action he performed in the conspiracy, which is
24
so at odds with the facts that it can only be seen as rhetorical.
25
Again, defendant’s decision not even to identify the facts that he
26
disputes prevents Probation or the government from responding,
27
discussed in more detail in the next section. (Cf., ECF 35, Addendum
28
2
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 3 of 28 Page ID #:169
1 to the PSR, rejecting defendant’s objection because, “Conduct such
2 as hiding assets or transactions, or both, using fictitious entities
3 also ordinarily indicates sophisticated means [and] This is exactly
4 the conduct in which Quadri engaged”.)
5 Section USSG § 2B1.1(b)(11) Enhancement: Defendant concedes
6 that he did, in fact, use the stolen means of identification of his
7 victims, such as their social security numbers and names, to obtain
8 another means of identification, such as EDD debit cards in their
9 identities and so qualifies for that enhancement under section
10 2B1.1(b)(11), but contends that the Court cannot apply the
11 enhancement because it is “duplicative” or double counting of the
12 enhancement in paragraph 48(c) of the Presentence Report for
13 defendant victimizing more than 10 persons pursuant to section
14 2B1.1(b)(2)(A). (ECF 34, page 2.) The Probation Office properly
15 rejected defendant’s position, which is unsupported by law or facts.
16 (Cf., ECF 35, Addendum to the PSR: “application of one section does
17 not preclude application of the other and is not duplicative.”)
18 “Impermissible double counting occurs only when one part of the
19 Guidelines is applied to increase a defendant's punishment on
20 account of a kind of harm that has already been fully accounted for
21 by application of another part of the Guidelines.” United States v.
22 Alexander, 48 F.3d 1477, 1492 (9th Cir. 1995) (citations and
23 quotations omitted). Plainly, that did not happen here. Defendant
24 would have qualified for the 2B1.1(b)(11) enhancement for having
25 using a single victim’s means of identification to apply for a new
26 means of identification, such as an EDD debit card. It is clearly
27 worse that he did so for 107 victims. (PSR ¶ 48(c).) Indeed,
28 because the enhancement for number of victims only requires 10 of
3
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 4 of 28 Page ID #:170
1 his victims, there is a good argument that the combined enhancements
2 fail to take into account all of defendant’s misconduct. Further,
3 the Section 2B1.11(b)(11) enhancement was independently justified
4 because the offense involved “the possession or use of any
5 . . . authentication feature,” such as those found on the
6 counterfeit passport in a victim’s name but bearing defendant’s
7 photograph. (USSG § 2B1.1(b)(11)(A); PSR ¶ 30.)
8 Role: Defendant objects that his role was not of “medium
9 culpability.” (ECN 34, page 2.) Again, defendant neither disputes
10 any facts in the Presentence Report, nor offers any new ones. As
11 described in more detail in the section below, such empty objections
12 fail to trigger the disputed fact-finding obligation of Rule 32.
13 (Cf., ECF 35, Addendum to the PSR, rejecting defendant’s role
14 objection because he did not offer any “new facts or previously
15 unconsidered authority”.)
16 Abusing Defendant’s Position of Trust: Defendant concedes that
17 he “used his position as the owner of a daycare facility to obtain
18 the information of his minor patient to commit fraud,” but contends
19 that the Court cannot apply the abuse of position of trust
20 enhancement because it is “duplicative” of paragraph 51 of
21 Presentence Report, which applied a vulnerable victim enhancement
22 for defendant’s have victimized developmentally disabled children.
23 (ECN 34, page 2.) (Cf., ECF 35, Addendum to the PSR: “application
24 of one section does not preclude application of the other and is not
25 duplicative”).
26 Again, defendant ignores Ninth Circuit law which holds that,
27 “Impermissible double counting occurs only when one part of the
28 Guidelines is applied to increase a defendant's punishment on
4
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 5 of 28 Page ID #:171
1 account of a kind of harm that has already been fully accounted for
2 by application of another part of the Guidelines.” Alexander, 48
3 F.3d at 1492. Clearly that did not happen here. Defendant could
4 have used his position as the owner of a daycare facility to steal
5 the identities of his own employees, or those of adults, in which
6 case he would have avoided the vulnerable victim enhancement.
7 Similarly, he could have stolen the identities of disabled children
8 from the dark web—or any other source other than his daycare
9 business—and he would have avoided the abuse of position of trust
10 enhancement. But it is truly egregious that defendant, in the guise
11 of someone caring for disabled children, used his access to their
12 personal identifying information to commit frauds in their names,
13 knowing that their age and disabilities would prevent them for
14 detecting his crime.
15 A. DEFENDANT’S OBJECTIONS, WHICH NEITHER DISPUTE FACTS
CONTAINED IN THE PSR NOR OFFER ADDITIONAL FACTS, DO NOT
16 TRIGGER THE DISPUTED FACT-FINDING OBLIGATION OF RULE 32
17 Defendant apparently thinks that his bare denial of certain
18 enhancements, such as the loss found by the Probation Office, is
19 sufficient to dispute them. Defendant is mistaken. The PSR has
20 already established the propriety of those enhancements. Once the
21 Probation Office has made such findings, it becomes the defendant’s
22 obligation to introduce evidence to the contrary, or at least to
23 identify the facts that he contends contradict that finding:
24 Rule 32[] imposes certain requirements upon the defendant
. . . . [including] that where factual inaccuracy [in the
25 PSR] is alleged, the defendant has the burden of
introducing, or at least proffering, evidence to show the
26 inaccuracy.
27 United States v. Roberson, 896 F.2d 388, 391 (9th Cir. 1990)
28 (rejecting defendant’s claim that the district court failed to
5
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1 resolve disputed facts when defendant “failed to proffer or to
2 present . . . a factual scenario at odds with that set forth in the
3 pre-sentence report”).
4 Every circuit to consider the issue has held that non-specific
5 objections to the PSR, like defendant’s, are ineffective, and fail
6 to trigger the fact-finding obligation in Rule 32 regarding disputed
7 facts. E.g., United States v. Brown, 314 F.3d 1216, 1221 (10th Cir.
8 2003) (explaining that unless “objections involve non-perfunctory
9 specific allegations of factual inaccuracy, no controverted matter
10 exists, and the district court's fact-finding obligation under Rule
11 32[] is not implicated”) (internal quotation marks and citation
12 omitted), cert. denied, 537 U.S. 1223, 123 S.Ct. 1338, 154 L.Ed.2d
13 1083 (2003); United States v. Davis, 583 F.3d 1081, 1095-96 (8th Cir.
14 2009) (“We require that objections to the PSR be made with
15 specificity and clarity before a district court is precluded from
16 relying on the factual statements contained in the PSR. The reason
17 we require specific objections is to put the Government on notice of
18 the challenged facts which the government will need to prove at the
19 sentencing hearing.”) (quotations and citations omitted) (rejecting
20 the claim that the district court failed to resolved disputed facts
21 when defendant made only a “vague, blanket objection”); United
22 States v. Waseta, 647 F.3d 980, 989 n.6 (10th Cir. 2011) (“Though
23 Mr. Waseta made a general, unspecified objection to ‘allegations in
24 the [PSR] that have been suggested as [grounds for] a possible
25 upward variance’ . . . this sort of general objection is inadequate
26 to trigger a district court's factfinding obligation under Rule 32.”
27 (alterations in original)); United States v. Sumner, 325 F.3d 884,
28 890 (7th Cir. 2003) (“A defendant has the burden of producing at
6
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 7 of 28 Page ID #:173
1 least some evidence that the PSR is unreliable or inaccurate beyond
2 a bare denial, if the facts set forth in a PSR bear sufficient
3 indicia of reliability to support [their] probable accuracy.”)
4 (citations and quotations omitted); United States v. Hughey, 147
5 F.3d 423, 437-38 (5th Cir. 1998) (“Although Hughey lodged general
6 objections that the PSR overestimated the loss, Hughey did not file
7 evidence capable of rebutting the detailed evidence presented in
8 support of the PSR calculations.”); United States v. Cheal, 389 F.3d
9 35, 37 n.1 (1st Cir. 2004) (“Cheal objected generally to the PSR's
10 description of the facts, but she offered no specifics to counter
11 that description. If the defendant's objections are merely
12 rhetorical and unsupported by countervailing proof, the district
13 court is entitled to rely on the facts in the PSR.”) (citations and
14 quotations omitted).
15 Presumably, defendant has chosen not to challenge any of the
16 factual findings of the PSR specifically because he knows that a
17 “defendant who falsely denies, or frivolously contests, relevant
18 conduct that the court determines to be true has acted in a manner
19 inconsistent with acceptance of responsibility,” and he does not
20 wish to jeopardize that reduction. USSG 3E1.1, app. n. 1(A).
21 Defendant’s attempt to have it both ways – “objecting” to the
22 enhancements while failing to even identify a claimed factual error
23 – fails:
24 When a defendant has within his capacity the means to
dispute the information presented by the government to the
25 probation officer conducting a presentence investigation
and chooses to remain silent, he cannot demand that the
26 trial court disregard the government’s version of the
facts.
27
28
7
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 8 of 28 Page ID #:174
1 United States v. Miller, 588 F.2d 1256, 1266-7 (9th Cir. 1978)
2 (affirming the district court’s adoption of the presentence report
3 when defendant’s objections consisted only of “his counsel’s bare
4 assertion . . . that the information [in the presentence report] is
5 incorrect.”).
6 “Only specific factual objections trigger Rule 32(i)(3)(B).”
7 United States v. Stoterau, 524 F.3d 988, 1011 (9th Cir. 2008). In
8 that case, the Ninth Circuit affirmed the district court’s decision
9 to rely on the PSR despite defendant’s objection to it, and without
10 further fact-finding:
11 In his sentencing position memorandum, Stoterau challenged
several paragraphs of his PSR on the ground that the
12 information gathered from police reports contained
multiple levels of unreliable hearsay. Stoterau did not
13 deny that the police reports contained the information
alleged in the PSR or that the information was factually
14 inaccurate. Instead, he argued that law enforcement
reports are not generally a reliable source of accurate
15 information.
16 Because Stoterau failed to dispute particular facts in the PSR, the
17 district court was entitled to rely on the PSR without more. Here,
18 too, defendant has failed to make specific factual objections.
19 III. BECAUSE DEFENDANT WILL LIVE IN LUXURY ON THE PROCEEDS FROM HIS
CRIME AFTER HE IS RELEASED, HIS SENTENCE MUST BE LONG ENOUGH TO
20 OUTWEIGH HIS STOLEN RICHES
21 Not only did defendant steal millions from programs designed to
22 help the needy, but he sent it abroad where it is beyond the reach
23 of U.S. authorities, and declined to provide an accounting for that
24 money. (PSR ¶ 114.) Worse, he attempted to deceive the Court and
25 the Probation Office by failing to disclose the great wealth he
26 returned to Nigeria—and which he will be able to enjoy once he is
27 released from prison.
28
8
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 9 of 28 Page ID #:175
1 As described in the Government’s Objections to the Presentence
2 Report (dkt. 31), defendant’s efforts at deception are both an
3 attempted obstruction of justice, and a demonstration that defendant
4 has emphatically not accepted responsibility for his crimes; he
5 wants to keep his fraudulent profits.
6 While the Probation Office acknowledged in its Addendum that
7 “Quadri’s lack of disclosure of a Nigerian hotel and other
8 properties he may own” is “concerning” as evidenced by his many
9 “text messages” regarding its construction, financing, and
10 operation, it failed to recommend either an attempted obstruction of
11 justice enhancement, or the elimination of an acceptance of
12 responsibility reduction because “the Probation Officer could not
13 locate sufficient evidence.” (Dkt. 35, page 1.) The Court need
14 only find guideline enhancements by a preponderance of the evidence,
15 USSG § 6A1.3 commentary, and here there is far more than that.
16 First defendant’s wife stated that “Quadri owns numerous
17 properties in Nigeria, including malls,” that “his father was a
18 king,” and that he was “raised in royalty” and “lived in a palace
19 with numerous servants.” (PSR ¶ 116.) This is corroborated by
20 evidence found on defendant’s digital devices, including a
21 photograph of a giant poster celebrating Quadri’s coronation as
22 prince (exh. 14), as well as innumerable photographs and messages
23 regarding Quadri’s directing the construction and operation of a
24 luxury 120-room hotel which includes a mall, lounge, club, pool, and
25 more, as discussed in more detail below. (PSR ¶¶ 70, 115.)
26 Second, Nigerian corporate records show that defendant is the
27 primary shareholder of Oyins International Limited, the company that
28 owns the hotel and mall, Oyins Resorts, as well as its director.
9
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 10 of 28 Page ID #:176
1 The other listed shareholders have the same last name as defendant,
2 and so are presumably his family members. (Exh. 1-2.)
3 Third, defendant had on his digital devices incontrovertible
4 evidence that he controlled Oyins International Limited, ranging
5 from the architectural drawings for the construction of the resort
6 (e.g., exh. 3), progress reports from the construction site
7 supervisor during the period of defendant’s fraud (e.g., exh. 4-5),
8 commands from defendant to the construction engineer (e.g., exh. 6:
9 “move the gym to the back and the 3 bed to the front”; exh. 8:
10 “Send me the video of the lift let me see what they do and the
11 remaining place to work on the correction”), defendant’s
12 exhortations to speed construction (exh. 8: “I just need them to be
13 fast so we can cast [concrete] tomorrow[;] we have stay[ed] on this
14 floor to[o] long”), defendant’s admission that he was paying for the
15 construction of the hotel (exh. 7: “50K I will be paying every stage
16 [of the construction] Engineer”), and periodic photographs of the
17 construction of the hotel (exh. 9). Defendant also directed the
18 accountant for Oyins International to provide him with the revenues
19 for the resort. (PSR ¶ 70.)
20 Fourth, Oyins International is a going concern with a
21 substantial web presence. You can book its rooms through Expedia,
22 Booking.com, hotwire.com, and other well-known websites. More
23 detail can be found on its own website: oyinsinternational.com.
24 In combination, this is far more than a preponderance of the
25 evidence to show that defendant personally financed the construction
26 of the hotel during his fraud, is the largest shareholder and
27 director of the corporation, oversaw the hotel’s construction
28 including directing the engineer to make changes to the plans, and
10
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 11 of 28 Page ID #:177
1 tracked its profits until he was arrested in this case—but failed to
2 disclose to the Probation Office that he had any stake in the
3 business at all, even though he was punctilious about disclosing
4 even $200 of cryptocurrency. (PSR ¶ 111.) Defendant believed he
5 could hide from the Court his assets abroad and wanted to keep his
6 fraud proceeds—now in the form of a luxury resort—to enjoy when he
7 got out of prison. In essence, defendant wanted to defraud his
8 victims a second time by preventing them from recovering their
9 losses from defendant.
10 Conclusion
11 If the Court applies the obstruction of justice enhancement and
12 eliminates the acceptance of responsibility reduction as described
13 in the Government’s Objections to the Presentence Report (dkt. 35),
14 defendant’s final offense level would be 39, which with defendant’s
15 criminal history category of I yields a guideline sentencing range
16 of 262 to 327 months in prison. While defendant has done nothing to
17 warrant leniency, the government nevertheless recommends a low-end
18 sentence of 262 months in prison only because defendant’s guideline
19 range is exceptionally high.
20 Dated: July 3, 2025 Respectfully submitted,
21 BILAL A. ESSAYLI
United States Attorney
22
CHRISTINA T. SHAY
23 Assistant United States Attorney
Chief, Criminal Division
24
Andrew Brown
25 ANDREW BROWN
Assistant United States Attorney
26
Attorneys for Plaintiff
27 UNITED STATES OF AMERICA
28
11
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 12 of 28 Page ID #:178
Exhibit page 001
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 13 of 28 Page ID #:179
Exhibit page 002
225 225
8100 6050
2400 2400 2400
6300 1800 150 1800
4575
225
5700
2175
CORRIDOR
8700 225
ROOM
1800
EXECUTIVE EXECUTIVE
525 4125 1800 ROOM ROOM
Case 2:24-cr-00617-GW
1800
ROOM 1200
2000 2000 1100 1200 1200 675
M/ F/
LIFT LIFT TOI
1800 TOI TOI
P A S S A G E
2225 1500
PHC ROOM
3800 TOI. 2700
P A S S A G E 1000 REST ROOM 1575
P A S S A G E 1500 1500
ROOM
ROOM LOBBY
1950 P A S S A G E
1800
Document 38
LANDING/
WAITING AREA
ROOM ROOM 4875
3825 ROOM
ROOM ROOM
5475 ROOM
P A S S A G E
Exhibit page 003
Filed 07/03/25
P A S S A G E
ROOM OURTH & IFTH LOOR LAN
ROOM
ROOM ROOM
NOTES: CLIENT: PROJECT & LOCATION: CONSULTANT: BN 2808543 DESIGNED BY EMERALD SEAL SHEET NO:
1. ALL DRAWING ARE NOT TO BE SCALED, USE FIGURE DIENSION ONLY
EMERALD BUILDING CONSULTING VENTURES
Page 14 of 28 Page ID #:180
2. ALL DIMENSIONS ARE TO THE NEAREST MM. AND MUST BE READ
PROPOSED COMMERCIAL DEVELOPMENT DRAWN BY ABDULFATTAH
WITH THE ACTUAL DIMENSION ON THE SITE ALONG OLD ONDO-BENIN ROAD/OWAKURUDU ROAD, *ARCHITECTURAL DESIGNS
3. ALL DETAILS ARE TO BE READ ALONG WITH RELEVANT ENGINEERING IJEBU-ODE *STRUCTURAL DRAWINGS
DRAWINGS
CHECKED BY EMERALD
OYINS *BUILDING CONSTRUCTION Address:
IJEBU-ODE LOCAL GOVERNMENT AREA 52, SANGO-IJOKO ROAD
4. NO ALTERATION SHALL BE MADE ON THE DRAWING WITUOUT THE *SURVEYORS E-06
APPROVAL OF THE ARCHITECT
INTERNATIONAL LIMITED OGUN STATE. PLAZA B/STOP, SANGO-OTA SCALE 1 : 100
*REAL ESTATE AGENT OGUN STATE.
JOB TITLE:
DATE DESCRIPTION NOTE FOURTH & FIRST FLOOR PLAN DATE AUG. 2021
TEL: 08169223260 , 07015889114
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 15 of 28 Page ID #:181
site report dated 7th febuary 2022
Week expectations
complete the casting
starting the deck work on the resturant section
parking of [block on the club section
completion of all block work on the club section
Note only the lift shaft was not done this week as expected.
details of work done are as follows between monday 31stjan to 6th feb.
31st- completion of casting on the club section
1st- getting the materials for the capenters such as the bamboo
parking of blocks to the club section
2nd capenter started work on the deck over the resturant section
block work started
3rd- capentery work contiuned
iron works on lintel was completed
block work contiuned
4th - casting of the lintel and secting of block work on the resturant was done
capentery work rolled on
block work contiuned
5th block work contiuned
capentary work continued
6th - capentery work was done
Exhibit page 004
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 16 of 28 Page ID #:182
observation and corrections
pick of the level for the capenter was done
and checking the block level as corrected on the club section deck
percentage of worked achievement in the week
93percent of expected job the week was done
Reasons
capenter did not finish his work to time due to delay in starting the work
iron work did not commeces as schedule
job expected to be done in 2nd week includes
complete the deck work
start the casting on the resturant section
deck work on the club section wood work and iron work will be completed and ready for casting
thanks
ARC. Balogun O. ademola
site supervisor
lugz projects ent.
Exhibit page 005
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 17 of 28 Page ID #:183
Exhibit page 006
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 18 of 28 Page ID #:184
Exhibit page 007
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 19 of 28 Page ID #:185
Exhibit page 008
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 20 of 28 Page ID #:186
Exhibit page 009
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 21 of 28 Page ID #:187
Exhibit page 010
Case 2:24-cr-00617-GW
7/2/25, 4:56 PM Document
oyins nternational - Discover 38 Reserve
Comfort, FiledLuxury -
07/03/25 Page
Your Gateway to 22 of 28
Memorable Page ID
Stays at #:188
OyinsInternational
y , y , y q ,
set the stage for unforgettable celebrations.
From intimate gatherings to grand affairs, experience impeccable service, stunning landscapes, and exquisite
settings. Let us transform your special moments into timeless memories, making every occasion extraordinary.
BOOK SPACE
Exhibit page 011
https://oyinsinternational.com 11/16
Case 2:24-cr-00617-GW
7/2/25, 4:56 PM Document
oyins nternational - Discover 38 Reserve
Comfort, FiledLuxury -
07/03/25 Page
Your Gateway to 23 of 28
Memorable Page ID
Stays at #:189
OyinsInternational
Super Standard Suite
From ₦65,000 Night Elevate your stay with our Super Standard Suites, where luxury is in every d
enhanced space and premium furniture, setting the stage for a truly opulen
those who appreciate finer comforts, each suite merges contemporary elega
ensuring a seamless blend of style and convenience. Ideal for discerning gues
ordinary, our Super Standard Suites offer a sanctuary of sophisticat
Book Now!
Exhibit page 012
https://oyinsinternational.com 9/16
Case 2:24-cr-00617-GW
7/2/25, 4:56 PM Document
oyins nternational - Discover 38 Reserve
Comfort, FiledLuxury -
07/03/25 Page
Your Gateway to 24 of 28
Memorable Page ID
Stays at #:190
OyinsInternational
King Suite
From ₦100,000 Night
A realm of unmatched luxury and grandeur awaits in our King Suites. Tailored for royalty, these expansive
suites feature sumptuous furnishings and bespoke amenities, promising an unparalleled stay. Experience
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Event's Place
Occasions to remember
Exhibit
At Oyins Resort, every event becomes an occasion page 013
to remember. Our luxurious venues, tailored to your unique needs,
https://oyinsinternational.com 10/16
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 25 of 28 Page ID #:191
Exhibit page 014
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 26 of 28 Page ID #:192
VICTIM IMPACT STATEMENT OF ROBERT M FOX AND ISABELLE FOX
This is our victim impact statement to be sent to the Court regarding the theft of the $24,000+
refund check mailed by the IRS. I (Robert M Fox) am 100 and my wife (Isabelle Fox) is 98. We
are the victims. We were very stressed by this theft and it took about 10 months for us to
convince the IRS that our refund was stolen and to issue a new refund. I am a lawyer
(retired/inactive) in Calif. and despite my legal background it was very difficult and time
consuming to find and compose the many IRS forms and requests. letters of explanation. etc
and send all that material with complete copies, to at least 5 or 6 IRS offices in different cities
throughout the country . I had to consume many hours puzzling out telephone numbers to call,
speaking to many-many IRS personnel. And, I did it all myself (as I am typing this out on my
computer)-without any help from anyone.
I have trouble estimating the number of hours-or days- that were consumed to finally get our
refund. At least 50 to 100 pages of forms, requests, etc were required doing the immense
amount of work required in addition to the many miserable hours of waiting on the telephone,
typing, explaining to IRS personnel, and keeping it all in order, In short, not what a hundred
year old should have to do.
Hopefully, our impact statement will help the Court to decide a proper sentence.
ROBERT M FOX (AND ISABELLE FOX -who has reviewed and approves this statement). It
was composed March 21, 2025. RMF
Exhibit page 015
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 27 of 28 Page ID #:193
Exhibit page 016
Case 2:24-cr-00617-GW Document 38 Filed 07/03/25 Page 28 of 28 Page ID #:194
To whom it may concern,
My husband and I were victims of a crime when a government check, we were relying on to help
us with medical care for my husband, was stolen. We spend precious time trying to track it down
as well as finding another way to take care of paying our caregivers.
Sincerely,
Elizabeth and Michael Vittes
Exhibit page 017
File and source
- File
- gov.uscourts.cacd.944947.38.0.pdf
- Size
- 6,502,176 bytes
- SHA-256
- 0b5140517409414b7942334ca8cd95083e8e5e3b7b85849427c17aeb6e23bbbb
- Original
- PACER (login required)