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Home Court filings U.S. v. Adiana Pierre Sentencing Hearing Transcript — Gardy Alexandre

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Sentencing Hearing Transcript — Gardy Alexandre

Record facts

CourtU.S. District Court, District of Massachusetts
Filed2024-05-28

U.S. District Court, District of Massachusetts · No. 1:24-cr-10007-MJJ · Doc. 88 · 2024-05-28 · Docket on CourtListener

Summary

A transcript of a sentencing hearing in United States of America v. Gardy Alexandre, Criminal Action No. 24-CR-10007-MJJ-3, before Judge Myong J. Joun in the U.S. District Court for the District of Massachusetts, held May 28, 2024 and filed September 5, 2024 as Document 88. The court states it reviewed the presentence report and both sentencing memoranda and adopts probation's base offense level of 6 over the government's objection. It adds 14 levels for the loss amount and one level for a conspiracy under 18 U.S.C. 1957, then subtracts three levels, reaching a total offense level of 18. With Criminal History Category II the court gives a guideline range of 30 months to 37 months, supervised release of 1 to 3 years and a fine range of $10,000 to $100,000, and declines to depart. The government recommends 27 months of incarceration and 36 months of supervised release.

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UNITED STATES DISTRICT COURT
 DISTRICT OF MASSACHUSETTS
______________________________
UNITED STATES OF AMERICA, 
               Plaintiff,        Criminal Action             
     No. 24-CR-10007-MJJ-3
V.
             
     May 28, 2024 
GARDY ALEXANDRE, 
         2:30  p.m. 
                    Defendant.
_______________________________
BEFORE THE HONORABLE MYONG J. JOUN  
UNITED STATES DISTRICT COURT
JOHN J. MOAKLEY U.S. COURTHOUSE
1 COURTHOUSE WAY
BOSTON, MA  02210
 
JAMIE K. HALPIN, RPR, RMR
Official Court Reporter
John J. Moakley U.S. Courthouse
1 Courthouse Way, Room 5205
Boston, MA  02210
jkhhalpin@gmail.com
Case 1:24-cr-10007-MJJ     Document 88     Filed 09/05/24     Page 1 of 29

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APPEARANCES:
FOR THE GOVERNMENT:  
David M. Holcomb
United States Attorney's Office MA
1 Courthouse Way
Suite 9200
Boston, MA 02210
(617) 756-9043
Email: David.Holcomb@usdoj.gov 
  
FOR THE DEFENDANT: 
James L. Sultan
Rankin & Sultan
1666 Massachusetts Avenue
Suite P-16
Lexington, MA 02420
617-720-0011
Fax: 617-742-0701
Email: Jsultan@rankin-sultan.com
Case 1:24-cr-10007-MJJ     Document 88     Filed 09/05/24     Page 2 of 29

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P-R-O-C-E-E-D-I-N-G-S
THE CLERK:  All rise.
(The Honorable Court Entered)
(INTERPRETER SWORN) 
THE CLERK:  Please state your name for the record. 
THE INTERPRETER:  Simon A Chen, C-H-E-N, Mandarin. 
MR. SULTAN:  James Sultan for Gardy Alexandre.
THE CLERK:  Today is May 28, 2024.  We're on the 
record in the matter of United States v. Gardy Alexandre, Case 
Number 24-CR-10007.  Counsel, please identify themselves for 
the record.
MR. HOLCOMB:  Good afternoon, your Honor.  David 
Holcomb for the United States.
THE COURT:  Mr. Holcomb.
MR. SULTAN:  Good afternoon, your Honor.  Jamie Sultan 
for Gardy Alexandre.
THE COURT:  Mr. Sultan.  Good to see both of you.  Mr. 
Alexandre, good afternoon, sir. 
THE DEFENDANT:  Good afternoon, sir.
THE COURT:  So we're here for sentencing.  I received 
and reviewed the presentence report as revised on May 20 and 
the Government's sentencing memo dated May 21 and the 
defendant's sentencing memo also filed on May 21.  There is a 
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motion for order of forfeiture.  Did you want to be heard on 
that?  
MR. SULTAN:  Well, your Honor, I think that that 
relates to the defendant's ability to pay so I would -- I mean, 
I can do it now or we can do it later, but I understand the 
restitution is mandatory, but given his lack of ability to pay, 
I don't really -- I think the Court has a discretion not to 
order forfeiture as well as restitution.  So I guess that's the 
position I would take with the Court. 
MR. HOLCOMB:  Yeah, I would oppose that request, your 
Honor.  I don't see a reason to deviate from imposing both 
restitution and forfeiture.  I think the payment plan or the 
payment plan issue, the ability to pay issue, is a separate 
consideration to be ironed out on the back end with the U.S. 
Attorney's Office Financial Litigation Unit.
THE COURT:  I'm pretty sure probation takes that into 
consideration at the time -- I mean, the order is in place, the 
forfeiture.  
MS. SOUSA:  The forfeiture and the restitution are two 
separate issues.  If the Department of Justice chose, the  
forfeiture amount should go toward restitution.  That would be 
dealt with later.
THE COURT:  Okay, all right.  So other than the PSR 
and the sentencing memos, I don't believe anything else has 
been submitted. 
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MR. HOLCOMB:  No, your Honor.
MR. SULTAN:  Nothing else submitted.  Your Honor, I'm 
sorry, I have one small correction.  In my sentencing memo on 
Page 2, I stated incorrectly that Mr. Alexandre has never been 
married.  He was married once about 30 years ago.  So I just 
wanted to make that correction for the record.
THE COURT:  Yeah, I read someplace else that he's been 
divorced, all right.  And Attorney Sultan, have you reviewed 
the PSR with your client?  
MR. SULTAN:  I'm sorry, your Honor?  
THE COURT:  Have you discussed the PSR with your 
client?  
MR. SULTAN:  Yes, your Honor.
THE COURT:  And you've discussed the objection that I 
noted in there?  
MR. SULTAN:  Yes, your Honor.
THE COURT:  And Mr. Alexandre, let me ask you, you've 
had a chance to review the presentence report and discuss it 
with your attorney?  
THE DEFENDANT:  Yes, your Honor.
THE COURT:  All right.  Thank you so much.  So I know 
the Government had an objection to the base offense level in 
the PSR as calculated.  I looked at it, and I'm going to adopt 
the analysis made by probation.  I found the video and the 
training material from the sentencing commission to be very 
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helpful, particularly the handout from the commission, and on 
Page 2 of the handout, in the Hypothetical Number 3, I think it 
addresses the concern that we had here or how we should go 
about calculating the base offense level.  It was a bit 
confusing, I admit, but given that clarification from the 
training material from the commission, I'm satisfied with the 
analysis made by probation.  So I'm going to start the base 
offense level at 6 instead of the 7 that you're suggesting.  
MR. HOLCOMB:  Yes, your Honor.
THE COURT:  Say that again.  
MR. HOLCOMB:  I just said yes, your Honor.
THE COURT:  Okay.  So following the most recent 
guideline with the offense level beginning at 6, because the 
loss was between $550,000 and $1.5, 14 levels are added.  That 
brings us to 20.  
Because Mr. Alexandre pled guilty to a conspiracy 
under 18 U.S.C. 1957, one level is added.  That brings us to 
21.  
With his clear demonstration of acceptance of 
responsibility, the offense level is decreased by 2.  So that 
brings us to 19.  
With his timely notification of intention to enter 
into a plea of guilty, that brings us down one additional 
level.  So a total offense level is 18.  Any disagreement?  
MR. SULTAN:  I agree, your Honor. 
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MR. HOLCOMB:  I agree with that calculation, your 
Honor.  I would just note again for the record the Government's 
objection.
THE COURT:  The objection is noted.  So based upon the 
total offense level of 18 and Criminal History Category of II, 
as I understand it, the guideline range is 30 months to 37 
months, a supervised release range from 1 to 3 years, a fine 
range of $10,000 to $100,000 and a mandatory special assessment 
of $100 in each count for a total of $200.  
And Mr. Sultan, I know you in your memo suggested that 
I depart based on the criminal history category.  I don't know 
if you want to be heard any further on that.
MR. SULTAN:  Just very briefly, your Honor.  I think 
that obviously a II is higher than a I.  All of his convictions 
are for driving under the influence.  He's had a longstanding 
problem with alcoholism, and I just think II overstates his 
record.  I understand that driving under the influence is a 
serious offense and people can get killed by drunk drivers, but 
in light of the relationship between his record and his 
longstanding alcohol problem, that's the basis for my request.
THE COURT:  And I get it.  My intention is not to 
depart.  I think departure is authorized in this case given 
that Mr. Alexandre's criminal history score of II comes from 
the two recent convictions of driving under the influence, and 
without, again like you, without minimizing those crimes, they 
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are different from the crimes for which Mr. Alexandre has 
pleaded guilty to here and those DUI or OUI convictions stemmed 
from, at least based on my reading of the material, his 
well-documented and longstanding battle with alcohol going back 
at least twenty-five years, but the reason I'm not going to 
depart is because, number one, even if the Criminal History 
Category under I, the range is 27 to 33 months, and I will be 
taking those factors into consideration in my sentencing.  
So I will hear from the Government, Mr. Holcomb, as to 
the Government's recommendation.  
MR. HOLCOMB:  Thank you, your Honor.  The Government 
is recommending a sentence of 27 months incarceration, with 36 
months of supervised release and the restitution that's 
specified in the parties' plea agreement which represents the 
losses that are attributable to this defendant's conduct.  A 
27-month sentence is below the guidelines as calculated even 
with the lower 18 being the total offense level, and the 
Government has agreed to make a below-guidelines recommendation 
based primarily on the defendant's pre-indictment acceptance of 
responsibility as well as the fact that his own profits from 
this scheme were just a portion of the overall loss amount that 
he is responsible for which is what is really driving the 
guidelines range here.  
So the primary reason for the sentence and the 
importance of the sentence is deterrence.  Generally, 
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deterrence, this district, like so many others, has seen a 
variety of cases by now involving pandemic relief fraud and 
especially involving this program, the Paycheck Protection 
Program.  
What makes Mr. Alexandre's case unique is that while 
most of the other cases involving PPP fraud involved defendants 
lying on applications to get bigger amounts for themselves, Mr. 
Alexandre did not only that but he and his co-defendants 
essentially created a business of their own out of committing 
PPP fraud for other borrowers.
He worked on his own, he didn't have any employees, and at 
most as a tax return preparer, working on his own he may have 
been eligible for a PPP loan of around $20,000 and that's only 
-- as a sole proprietor, he had made the maximum cap for the 
program which was $100,000 a year, which there is no indication 
he made close to that, and so any truthful application by Mr. 
Alexandre would have resulted in a PPP loan of less than 
$20,000; but instead, what he did was he gave information to 
his co-defendant, Adiana Pierre, about his business.  She 
passed it along to the third co-defendant, Wallace Ford, and he 
applied for a loan of $300,000 for Mr. Alexandre.  Mr. Ford 
listed false numbers of employees in payroll to back into that 
$300,000 amount because the calculation was based on two and a 
half times the average monthly payroll of the borrower, and Mr. 
Ford gave Mr. Alexandre the login information for that online 
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application to review and sign the application.  
Once that loan was dispersed to Mr. Alexandre, he then 
paid Mr. Ford a commission or a kickback of 10 percent of that 
loan which was $30,000.  
The PPP application was a simple two-page, two-to-three 
page form that millions of businessowners completed and just on 
their own to get a loan to help prop up their struggling 
businesses.  There is no legitimate reason to be charging or 
paying a fee of 10 percent or more of the resulting PPP loan 
just to submit one of these applications for somebody else.  
What Mr. Alexandre was actually doing was paying for 
someone else to get him a much larger loan than what he was 
actually eligible for through false representations.  
And after he got his own loan, he then joined Mr. Ford and 
Ms. Pierre in helping others get loans that were larger than 
they were eligible for.  
His referrals led to several substantial loans based on 
egregious claims about borrowers' payroll expenses, including 
the two loans to Massachusetts borrowers that are highlighted 
in both the PSR and the Government's memo, and these in turn 
led to large portions of these PPP loans getting kicked back to 
Mr. Ford, Ms. Pierre and Mr. Alexandre for doing nothing -- in 
Mr. Alexandre's case, for doing nothing more than making the 
connection between the borrower and the application preparer.  
Regarding the other 3553(a) factors, your Honor, the 
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defendant's memo and presentence report describes a number of 
hardships that the Government acknowledges shouldn't be 
minimized.  
And the criminal history, in the Government's view, 
appropriately reflects the seriousness of those offenses and 
the fact that this is not mere substance abuse.  This is 
life-endangering conduct on a repeated basis by this defendant.  
But the most striking thing to the Government is that Mr. 
Alexandre held himself out as a tax return preparer, and so he 
is somebody who in that capacity presumably represented 
financial information of other people to the Government and so 
he knew and understood how significant it was to lie on forms 
related to Government funding; but this wasn't, again, this 
wasn't a complicated application process.  This was a 
straightforward form and a straightforward calculation.  There 
wasn't a whole lot of room for confusion here.  
Putting the offense in the larger context of the time and 
the rush to get the funds out, there certainly was plenty of 
temptation and opportunity for fraud.  The lenders made money 
by getting PPP money out quickly, and in fact, the system was 
designed to do that, but it was a finite pool made available 
for a limited, specific purpose, and Mr. Alexandre and his 
co-defendants not only stole from that pool but then they got 
paid to help other people steal from that pool.  
So his sentence should reflect the need to promote respect 
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for the rules for obtaining funds from those types of public 
programs and to deter others from stealing from public funds.  
A 27-month sentence is proportionate to Mr. Alexandre's 
offense and his criminal history when placed alongside many of 
the other defendants in this district who have been sentenced 
for pandemic fraud, especially if the Court accounts for the 
ripple effects or Mr. Alexandre's activity in that this was not 
just a loan for himself, but he induced others to commit the 
same type of fraud.  
So for those reasons, your Honor, the Government 
respectfully submits that 27 months, below guidelines, is 
sufficient but no greater than necessary to meet the goals of 
sentencing in Mr. Alexandre's case.
THE COURT:  Thank you.  Mr. Sultan.
MR. SULTAN:  Thank you, your Honor.  So I certainly 
don't want to repeat everything that's in my sentencing memo or 
the PSR, but I do want to highlight, if I may, a few aspects of 
Mr. Alexandre's background, a few aspects of the offense 
conduct, the particular circumstance that applies to him and 
then my recommendation.  
So Mr. Alexandre really is a self-made man.  He was sent 
from his native Haiti to New York City when he was 14 to live 
with a mother who he didn't know and had only barely met.  
He didn't know any English.  
He got himself through high school.  
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He got himself into college and walked on to the soccer 
team at Stoney Brook University where he became a star, still 
holding records that stood for many years there.  
He graduated from college.  
He enlisted in United States Army where he served our 
country for two years.  
He then went and moved to Florida where he became trained 
as a tax preparer and went into business for himself in that 
area.  
Unfortunately, this comes back later on, Mr. Alexandre, 
even though he's been here for almost four decades and came 
here as a legal resident alien, never took the time to apply 
for U.S. citizenship.  Therefore, he comes before the Court as 
a non-citizen who is likely to be deported back to his native 
Haiti, which is now obviously a violent country, even though he 
hasn't had any connection with that country for four decades 
and the United States of America is his home.  
Mr. Alexandre has suffered from mental illnesses including 
depression, anxiety, alcoholism and gambling addiction, and 
those became worse when his -- during the pandemic and they 
became worse a few years ago when his mother passed away.  
When the pandemic happened in 2020, his business stopped.  
His treatment at the VA was put in suspense and his support 
system basically was unavailable to him, and none of that is an 
excuse for his offense conduct which he takes responsibility 
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for but it provides some of the context in which he did make 
the terrible decision to participate in this fraudulent 
conduct.
Now, with respect to the offense conduct, your Honor, 
I think the Government's description in their sentencing memo, 
if I can just read two paragraphs of it, I think really 
captures Mr. Alexandre's role, how he got into it, and what he 
did.  So if the Court will indulge me, I'm going to just read 
from the Government's sentence memo at Page 2.  
"After his first attempt at obtaining a PPP loan for his 
business, Palm Beach Community House, failed, the defendant 
accepted assistance from a woman that he met through his work 
as a tax return preparer, co-defendant Adiana Pierre.  Pierre 
and her friend from church, co-defendant Wallace Ford, agreed 
to work together to make money by securing PPP loans for 
individuals and businesses.  Pierre recruited the borrowers, 
including Mr. Alexandre, and Ford electronically prepared the 
applications.  Rather that soliciting and reporting accurate 
information about potentially borrowers' employees and payroll 
costs, they, they being Pierre and Ford, fabricated the numbers 
on the applications that Ford prepared.  Ford also prepared 
fake tax forms for borrowers to match the payroll costs he 
stated on applications.  For securing loans through false 
applications, Ford and Pierre charged borrowers a commission, 
typically around 10 percent.  
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In early June, Ford prepared two PPP applications for Mr. 
Alexandre's business, which falsely claimed employees that the 
business never had.  He also and -- Ford also prepared a fake 
2019 Form W-3 for Alexandre's business.  As a result of one of 
all those applications, the defendant, Mr. Alexandre, received 
a $300,000 loan.  In return, he paid Ford a 10 percent 
kickback.  
Thereafter, the defendant, Alexandre, agreed to recruit 
additional borrowers to submit applications through Pierre and 
Ford and he shared in the kickbacks for securing loans for 
other borrowers."  
So that was his role, and again, I'm not minimizing it.  
I'm not saying he -- he was a knowing participant, but he was 
recruited initially, and he is simply, as a factual matter, 
your Honor, less culpable than his two co-defendants.  Each of 
them, according to the Government and the presentence report, 
are responsible for more than -- between four and five times 
the amount of loans that Mr. Alexandre is responsible for, and 
they're the ones who brought him in and he willingly accepted a 
PPP loan that he knew he wasn't entitled to and he willingly 
went out and recruited several other people for those loans.  
That's his crime.  He did that.  He takes responsibility for it 
there are no excuses for that, and I'm saying this in part 
because I know your Honor has not yet sentenced the other two 
defendants and he is the least culpable of the three.  It often 
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goes the other way, the most culpable person goes first, but 
here we have the least culpable person coming before the Court 
first and I just want to highlight that because obviously the 
Court is going to consider proportionality in deciding what a 
fair and appropriate sentence is.  
So the special circumstance I just want to highlight is 
the fact that Mr. Alexandre is facing almost certain 
deportation back to Haiti and I understand that is not strictly 
speaking a factor under 3553, but in real life, it's a pretty 
big factor, your Honor.  His life that he's built over the last 
four decades in the United States, including voluntary military 
service, graduating from college, building a business, being a 
professional, contributing to his community, all of that is 
going to go by the board.  He's going to lose all of that, and 
he may not see his four children again.  That's a serious 
consequence of his misconduct.  He did it.  He's responsible 
for putting himself in that position, but surely that is a 
special factor that the Court can consider in looking at the 
whole picture here and deciding what kind of a sentence, how 
long this man has to go to prison.  So I ask the Court to 
consider the whole picture and that's part of the picture.  It 
just is.
With respect to recommendation, your Honor, I ask the 
Court to sentence Mr. Alexandre to a year and a day in the 
custody of the Bureau of Prisons.  This is a jail case.  There 
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is no question about it.  As far as I know, every PPP loan, 
fraudulent loan person who has been convicted in this district 
has gone to jail, and I'm not standing before your Honor 
saying, give him probation.  He should go to jail for this 
fraudulent conduct for deterrence and for all the other 
purposes for sentencing, but he doesn't need to go to jail or 
27 months, your Honor, before he gets shipped back to Haiti.  A 
year and a day is sufficient but not more than necessary, and I 
ask the Court to craft a sentence of that duration.  
I ask the Court to recommend that he receive treatment for 
his alcoholism and mental illness while he is in the custody of 
the bureau of prisons, and that if he is released back to the 
community in the United States for supervised release, that all 
of the conditions recommended by probation including abstinence 
from alcohol and treatment be imposed as special conditions.  
I ask that there not be a forfeiture or a fine because he 
doesn't have the ability to pay a forfeiture or fine.  I ask 
that Mr. Alexandre be allowed to -- that the Court make a 
recommendation that he serve his time at an institution in or 
as close to Florida as possible so he can -- so his family can 
come see him and that he be permitted to self-report to that 
institution at the date designated by the Bureau of Prisons.  
He's been out for well over a year and there haven't been any 
issues with that and he's been here every time he's supposed to 
be here.  
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So that's my recommendation and I appreciate the Court's 
patience in listening to me.
THE COURT:  Thank you.  Does Mr. Alexandre wish to 
address the Court?  
MR. SULTAN:  You want to speak?  
THE DEFENDANT:  Yes.  Good afternoon, your Honor.  
Well, first I want to apologize to my community, my children 
and everything else -- and everybody else that I let down with 
my engagement with this PPP loan fraud.  I take full 
responsibility for my involvement in the scheme.  
COVID-19 was a very stressful time.  It was a difficult 
time.  I saw everything I had built just crumbling down and did 
my attempt to apply for a PPP Loan.  Unfortunately, I didn't 
have the necessary paperwork to get the loan myself.  This is 
when Adiana was a friend of mine and she gave me the advise 
that she has some people that can help me, and I should have 
known better because obviously when I tried on my own I wasn't 
eligible for the type of loan that she was getting me, but like 
I said, COVID -- I had COVID three times, and I was under a lot 
of stress to keep my business and to keep my financials and 
that's no excuse but I ended up in this situation.  
You know, I have always been somebody who regards myself 
as somebody who has morals and standards.  This is the reason 
why after I graduated college I joined the military.  After the 
military, I was a member of Americorps which is kind of like a 
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Peace Corps.  When I got to Florida, I worked at a community 
college where I helped people in the Haitian community get into 
college.  
So my history is not just the crime that I committed but 
there is also some good things, and I hope the court can show 
some leniency based on the overall circumstances and everything 
else.  Thank you.
THE COURT:  Thank you.  So I want to thank counsel.  I 
appreciate your arguments and your recommendations.  
So I have to determine what a reasonable sentence will be 
given all of the factors that I must consider under Title 18, 
under U.S. Code Section 3553(a).  Those factors, Mr. Alexandre, 
include the Advisory Guidelines sentencing range, the nature 
and circumstances of this case, the crime that you committed, 
your personal history and background and the need for any 
sentence that I impose to do a number of things including not 
just to reflect the seriousness of your crime but also to 
promote the respect for the law, provide just punishment and 
deterrence and avoid any unwarranted sentencing disparities.  
So Mr. Alexandre, I have considered all of those 
sentencing factors, and I want to note just a few things.  
Given the breadth and scope of the conspiracy to defraud here, 
I think both sides acknowledge that some amount of 
incarceration is necessary to serve the goals of the sentencing 
factors that I mentioned.  The Government is recommending a 
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sentence of 27 months which is not unreasonable.  Your 
attorney, on the other hand, is recommending a sentence of a 
year and a day.  
I am mindful of your role in the conspiracy and relative 
culpability with your co-conspirators and the fact that you 
were more -- I don't know what's the word -- susceptible to 
being lured into the conspiracy given your state of mind, your 
struggles with alcohol.  
I'm also aware of the possibility that you will be 
deported after serving your sentence.  
I read in the Government's sentencing memo that the 
Government will be recommending 30 months for Ms. Pierre, who 
appears to be the most culpable, the brains or the orchestrator 
behind the conspiracy.  
Using that as a goalpost, I think a sentence of 15 months 
incarceration is the appropriate sentence here given all of the 
facts and circumstances of this case followed by 3 years of 
supervised release and restitution in amount of $1,455,652.  
I am not going to impose a fine, but I have to impose a 
mandatory special assessment of $100 on each count for a total 
of $200.  
So I believe this is an appropriate and reasonable 
sentence but not greater than necessary to effectuate all of 
the goals of sentencing that I mentioned.  
Before I formally impose sentence, does either side need 
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to be heard any further? 
MR. SULTAN:  As long as the Court -- sorry.  
MR. HOLCOMB:  No, your Honor.
MR. SULTAN:  Just that I would ask the Court to 
incorporate in the judgment the other recommendations I made.
THE COURT:  Yes, yes.  And on the forfeiture issue, 
the amount was 450 some thousand dollars.  I will have the 
exact figure in a minute.  I think that is separate from 
restitution and I think Mr. Alexandre's ability to pay will be 
factored in.  So I am going to allow the Government's motion.
Mr. Alexandre, will you please stand.  
Pursuant to the Sentencing Reform Act of 1984 and 
having considered the sentencing factors enumerated at Title 
18, United States Code Section 3553(a), it is the judgment of 
the Court that the defendant, Gardy Alexandre, is hereby 
committed to the custody of the Bureau of Prisons to be 
imprisoned for a term of 15 months as to each count, to be 
served concurrently.  
The Court makes a judicial recommendation that the 
defendant participate in substance treatment as well as 
gambling treatment while in the custody of the Bureau of 
Prisons.  Although, I can't guarantee it because with 15 months 
I'm not sure that that's enough time for the RDAP program, I'm 
not sure, but I'm sure the Bureau of Prisons will figure it 
out.  
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Upon the release from imprisonment, the defendant 
shall be placed on supervised release for a term of 3 years as 
to each count to run concurrently.  
Within 72 hours of release from the custody of the 
Bureau of Prisons, Mr. Alexandre, you shall report in person to 
the district to which you are released.  
It is further ordered that the defendant shall make 
restitution in the amount of $1,455,652.  $1,150,652 will go to 
the Cross River Bank and $305,000 to the U.S. Small Business 
Administration.  
Given this amount, your current financial statement 
that I saw attached to the sentencing memo, I will waive your 
-- well, I will waive the interest.  
Any payment made that is not payment in full shall be 
divided proportionately among the parties named.  
The restitution to Cross River Bank in the amount of 
$1,150,652 shall be paid by the defendant jointly and severally 
with Ford and Pierre.  
The Small Business Administration restitution in the 
amount of $300,000 shall be paid by the defendant jointly and 
severally with Ford and Pierre.  
The defendant's remaining Small Business 
Administration restitution obligation in the amount of $5,000 
shall not be affected by any restitution payments that may be 
made by any other defendants.  
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Payment of the restitution balance shall begin 
immediately and shall be made according to the requirements of 
the Federal Bureau of Prisons Inmate Financial Responsibility 
Program while the defendant is incarcerated and according to 
the court order of the payment schedule during the term of the 
supervised release.  
All restitution payments shall be made to the Clerk of 
the U.S. District Court for transfer to the identified victims.  
And Mr. Alexandre, you will notify the United States 
Attorney for this district within 30 days of any change of 
mailing or residence address that occurs while any portion of 
the restitution remains unpaid.  
I'm not imposing a fine, as I mentioned.  Based on the 
information before me, I find that you do not have the 
financial ability to pay a fine in addition to the restitution.  
And as I indicated, the Court will grant the United 
States' motion for an entry of an order of forfeiture in the 
form of a personal money judgment and order the defendant to 
forfeit the sum of $443,760.  
I further order that you pay the mandatory special 
assessment of $100 on each count for a total of $200 which 
shall be due immediately.  
So while you're on supervised release, you will be 
subject to certain mandatory and standard conditions.  
You must not commit another federal, state or local 
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crime.  
You must not unlawfully possess a controlled 
substance.  
You must submit to 1 drug test within 15 days of your 
release from imprisonment and at least 2 periodic drug tests 
thereafter, not to exceed 104 tests per year.  
You must cooperate in the collection of DNA as 
directed by the probation officer.  
You shall comply with the standard conditions that 
have been adopted by the court which are described at United 
States Sentencing Guidelines Section 5D1.3(c), and these will 
be set forth in detail in the judgment that I will enter either 
later today or tomorrow.  
And you must make the restitution as ordered.
Those mandatory and standard conditions will be 
reflected in the written judgment, but you will also be subject 
to certain special conditions during your period of supervised 
release and I will read those to you now even though they will 
also be included in the written judgment that I will issue.  
You must participate in a substance abuse treatment 
program and follow the rules of that program and the probation 
office will supervise your participation in the program.  
As I mentioned, you have to submit to substance abuse 
testing, not to exceed 104 drug tests per year in order to 
determine whether you've used any prohibitive substances, and 
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you are ordered not to obstruct or tamper with any testing 
methods.  
You're prohibited from consuming alcoholic beverages.  
You must participate in any mental health treatment 
program as directed by the probation office.  
You are prohibited from frequenting establishments 
whose primary purpose is gambling.  
You're prohibited from participating in any gambling 
activities and that includes things like casino gambling, 
online gambling, scratch tickets, lotteries, Keno, anything of 
that nature.  
You must attend a gambling-specific treatment program 
and/or meetings as directed by the probation department.  
You must pay the balance of the restitution imposed 
according to a court ordered repayment schedule.  
You're prohibited from incurring any new credit 
charges or opening any additional lines of credit without the 
approval of the probation department while any financial 
obligations remain outstanding.  
You must provide the probation office access to any 
requested financial information which may be shared with the 
Asset Recovery Unit at the U.S. Attorney's office.  
You shall be required to contribute to the costs of 
the evaluation treatment program and/or monitoring based on 
your ability to pay or availability of any third-party payment.  
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And it's further ordered the defendant shall pay to 
the United States a special assessment of $200 which shall be 
due immediately.  
This sentence is hereby imposed as stated.  
You may be seated, sir.  
THE DEFENDANT:  Thank you.
THE COURT:  I will include in the judgment, as you 
requested, that the Bureau of Prisons designate you to a 
facility in or near Florida where your family resides.  As you 
may already know from your attorney, this is only a 
recommendation.  The Bureau of Prisons makes the final 
decision, but I will make sure that the recommendation that I'm 
making now is in the judgment.  
No objection to Mr. Alexandre self-reporting?  
MR. HOLCOMB:  No objection, your Honor.
THE COURT:  Why don't we give Mr. Alexandre a date 
maybe six, seven, eight weeks out.  
THE CLERK:  Yes, your Honor.  Your Honor, that would 
be Tuesday, July 23rd, before 2 p.m.
THE COURT:  So, Mr. Alexandre, you're further ordered 
to self-surrender at the institution designated by the Bureau 
of Prisons on July 23 -- before July 23 at 2 p.m., okay?  
THE DEFENDANT:  Okay.
THE COURT:  So I have to advise you of your appellate 
rights, and if you recall from our plea colloquy back in 
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February, I had discussed with you there was a provision in the 
plea agreement where there was a provision about appeal waiver.  
Assuming any appellate rights survive any appeal waiver, I need 
to advise you that you also have a right to appeal your 
sentence, particularly if you think the sentence was contrary 
to law.  
If you're unable to pay the costs of appeal, you may ask 
permission to have those costs waived and appeal without 
paying.  
You must file any notice of appeal within 14 days after 
the entry of judgment; and if you request, the clerk will 
immediately prepare and file a notice of appeal on your behalf, 
all right, sir?  
THE DEFENDANT:  Yes, your Honor.
THE COURT:  All right.  I wish you the best, and I 
know you have family.  I don't know what's going to happen 
after you serve your sentence, but I hope that you're able to 
take care of your family and put this behind you.  
THE DEFENDANT:  Thank you.
THE COURT:  I wish you luck.  
THE DEFENDANT:  Thank you, sir.
MR. SULTAN:  Does he need to report to the marshals or 
not today?  
THE COURT:  Not to the marshals today.  
MR. SULTAN:  They don't need to process or anything?  
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MS. SOUSA:  He should have already been processed 
initially.
MR. SULTAN:  Thank you very much.  
(A-D-J-O-U-R-N-E-D)
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- - - - - - - - - - - -
CERTIFICATION
I certify that the foregoing is a correct transcript 
of the record of proceedings in the above-entitled matter to 
the best of my skill and ability.
/s/Jamie K. Halpin
       September 4, 2024     
Jamie K. Halpin, RPR, RMR 
      Date
Official Court Reporter 
Case 1:24-cr-10007-MJJ     Document 88     Filed 09/05/24     Page 29 of 29

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