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Home Court filings U.S. v. Amber Rewis Bruey Transcript of Sentencing — United States v. Amber Bruey

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Transcript of Sentencing — United States v. Amber Bruey

No. 2:21-cr-00074 · Doc. 134 · Docket on CourtListener

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Case 2:21-cr-00074-TPB-K_D   Document 134   Filed 08/23/22   Page 1 of 23 PageID 882




                             UNITED STATES DISTRICT COURT
                              MIDDLE DISTRICT OF FLORIDA
                                 FORT MYERS DIVISION


        UNITED STATES OF AMERICA,      ) Fort Myers, Florida
                                       )
                                       ) Case 2:21-CR-74-JLB-MRM
        Plaintiff                      )
                                       ) Wednesday, July 13, 2022
        vs.                            )
                                       ) 11:59 a.m. to
        ANTHONY JAMES BRUEY, and       )
        AMBER REWIS BRUEY,             )
                                       )
        Defendants.                    )
        _______________________________)



                         TRANSCRIPT OF SENTENCING, PART TWO

                              DAY 2 OF 2, VOLUME 2 OF 2

                    HELD BEFORE THE HONORABLE THOMAS P. BARBER,

                         United States District Court Judge




                                        Official Court Reporter:
                                        Jeffrey G. Thomas, RPR, CRR
                                        2110 First Street, Suite 2-194
                                        Fort Myers, FL 33901
                                        Telephone: (239) 461-2033


        (Proceedings reported by Stenotype; Transcript produced by
        computer-aided transcription.)
Case 2:21-cr-00074-TPB-K_D   Document 134    Filed 08/23/22   Page 2 of 23 PageID 883

                                                                                    2


   1                            A P P E A R A N C E S

   2
        COUNSEL FOR GOVERNMENT:
   3
                             United States Attorney's Office
   4                         Middle District of Florida
                             United States Courthouse
   5                         2110 First Street
                             Room 3-137
   6                         Fort Myers, FL 33901
                             (239)461-2200
   7                         BY: TRENT REICHLING, ESQ.

   8
        COUNSEL FOR DEFENDANT JAMES BRUEY:
   9
                             Mangone & Miller Law Offices
 10                          Suite 502
                             2335 Stanford Court
 11                          Naples,Florida 34112
                             (239)774-4100
 12                          BY: LANDON P. MILLER, ESQ.

 13
        COUNSEL FOR DEFENDANT AMBER REWIS BRUEY:
 14
                             Federal Public Defender's Office
 15                          2075 West First Street, Suite 300
                             Fort Myers, FL 33901
 16                          (239) 334-0397
                             BY: JAMES LAPPAN, ESQ.
 17

 18     ALSO PRESENT:

 19                          JODI PETERSEN, Pretrial Services Officer

 20
                                            * * *
 21

 22

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 25
Case 2:21-cr-00074-TPB-K_D   Document 134    Filed 08/23/22   Page 3 of 23 PageID 884

                                                                                    3


   1                                   I N D E X

   2    July 13, 2022                                                  Vol.      Page

   3    Preliminary Discussions                                          2          4

   4    Argument by Mr. Miller                                           2          4

   5    Imposition of Sentence                                           2          5

   6    Objections by Mr. Lappan                                         2         19

   7    Certificate of Court Reporter                                    2         23

   8
                                            * * *
   9

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Case 2:21-cr-00074-TPB-K_D   Document 134    Filed 08/23/22   Page 4 of 23 PageID 885

                                 ARGUMENT BY MR. MILLER                             4


   1                     * * * P R O C E E D I N G S * * *

   2                                        - - -

   3                THE COURT:    All right.     Next is the Brueys.        Let's

   4    take up that case.

   5                Do you want to do Anthony first, I guess?            Let's do

   6    Anthony first.

   7                This is Case Number 21-CR-74, United States versus

   8    Anthony Bruey.

   9                MR. REICHLING:    Good morning, Judge.         Trent Reichling

 10     on behalf of the United States.

 11                 MR. MILLER:    Good morning, Your Honor.          Landon Miller

 12     on behalf of Anthony Bruey, who is present, seated to my left.

 13                 THE COURT:    All right.     So this is a case that we

 14     spent some time on.      I think this might be the third time I've

 15     seen Mr. Bruey, second time I've seen Ms. Bruey.              I've spent a

 16     lot of time thinking about it, analyzing it.

 17                 We had a sentencing hearing previously where I took

 18     in a bunch of information.      Today is the day where I told you

 19     we would come back where I would impose the sentence.               So,

 20     unless there's something else somebody wants to say that's new

 21     information, or anything like that, I'm just going to do most

 22     of the talking this time.

 23                 Is there anything else I need to know about here?

 24                 MR. REICHLING:    No, Your Honor.

 25                 MR. MILLER:    Judge, on behalf of Mr. Bruey, there was
Case 2:21-cr-00074-TPB-K_D   Document 134    Filed 08/23/22   Page 5 of 23 PageID 886

                                 IMPOSITION OF SENTENCE                              5


   1    one thing that I forgot to mention at our last sentencing, that

   2    I discussed with Mr. Reichling this morning, and that is that

   3    there's been a fair amount of cash received, and I believe it

   4    to the tune of 60,000.      It was in a different account.           Once

   5    they got arrested, the Brueys disclosed where that money was,

   6    and turned it over to the government without the forfeiture

   7    proceedings.

   8                THE COURT:    That's good.      That's a good fact.

   9                MR. MILLER:    And then I believe a lot of vehicles

 10     have been recovered; and, of course, the house is now up for

 11     sale.

 12                 THE COURT:    Okay.     All right.    Where are we now?

 13     Last time, I got a new piece of information that Mrs. Bruey was

 14     pregnant.    What's the due date?

 15                 MR. LAPPAN:    That would be February 25th, Your Honor.

 16                 THE COURT:    February.     What's the math on that?         I

 17     guess we're already in July; right?          February 25th, the end of

 18     February?

 19                 MR. LAPPAN:    Yes, Your Honor.

 20                 THE COURT:    All right.

 21                 So, in Anthony Bruey's case, looks like on March 4th,

 22     2022, he entered a plea of guilty to Count 1, 12, 13, 14, 15,

 23     16, of an indictment charging him, in Count 1, with conspiracy

 24     to commit wire fraud, in violation of Title 18 U.S. Code

 25     Section 1349; and Counts 12 through 13, with wire fraud, in
Case 2:21-cr-00074-TPB-K_D   Document 134   Filed 08/23/22   Page 6 of 23 PageID 887

                                IMPOSITION OF SENTENCE                             6


   1    violation of Title 18 U.S. Code Section 1343; Count 14,

   2    conspiracy to commit money laundering, in violation of Title 18

   3    U.S. Code Section 1956(h); and, in Counts 15 through 16, with

   4    illegal monetary transactions, in violation of Title 18 U.S.

   5    Code Section 1957.

   6                I previously accepted his guilty plea and adjudicated

   7    him guilty.    And we previously discussed where he fell in the

   8    sentencing guidelines, and that's all been covered before.

   9    It's now time to impose the sentence.

 10                 Pursuant to Title 18 U.S. Code Section 3551 and 3553,

 11     it is my judgment that the defendant, Anthony James Bruey, will

 12     be committed to the custody of the Bureau of Prisons for a term

 13     which I will announce momentarily.

 14                 Upon release from imprisonment, he shall serve

 15     three years of supervised release on each count to run

 16     concurrent.    While on supervised release, he shall comply with

 17     the mandatory and standard conditions adopted in the Middle

 18     District of Florida, and comply with the following special

 19     conditions:

 20                 Number 1, participate in a mental health treatment

 21     program, outpatient or inpatient, follow the probation

 22     officer's instructions regarding that directive.             He'll also

 23     have to contribute to the cost of those services not to exceed

 24     an amount determined reasonable by the probation office.

 25                 He is prohibited from incurring new credit charges,
Case 2:21-cr-00074-TPB-K_D   Document 134    Filed 08/23/22    Page 7 of 23 PageID 888

                                 IMPOSITION OF SENTENCE                              7


   1    opening additional lines of credit, or obligating himself for

   2    any major purchases without the approval of the probation

   3    office.

   4                He has to provide the probation officer access to any

   5    requested financial information.

   6                Having been convicted of a qualifying felony, he must

   7    cooperate in the collection of DNA as directed by the probation

   8    office.

   9                He has to refrain from any unlawful use of controlled

 10     substances and submit to one drug test within 15 days of

 11     placement on supervision, and two periodic drug tests

 12     thereafter, as directed bring the probation officer.               He has to

 13     submit to random drug testing not to exceed 104 tests per year.

 14                 Restitution.    These amounts are all staying the same,

 15     irrespective of what they have tried to pay back.               They just

 16     get credit for that; right?

 17                 MR. MILLER:    That's my understanding, Judge.

 18                 THE COURT:    All right.

 19                 MR. LAPPAN:    That's correct.

 20                 THE COURT:    Okay.     So restitution in the amount of

 21     $881,659.35, as set forth below:         To the Celtic Bank,

 22     $35,959.35; Customer's Bank, $20,000; TransPecos Bank, $62,400,

 23     Small Business Administration, $763,300.              This obligation is

 24     payable to the U.S. District Court for distribution to victims,

 25     it's joint and several with the co-defendant, Amber Bruey.
Case 2:21-cr-00074-TPB-K_D   Document 134    Filed 08/23/22    Page 8 of 23 PageID 889

                                 IMPOSITION OF SENTENCE                              8


   1                While in the Bureau of Prisons custody, they will

   2    have to either pay at least $25 quarterly if you have a

   3    non-UNICOR job, or at least 50 percent of the monthly earnings

   4    if you have a UNICOR job.      Upon release, you have to pay

   5    restitution at the rate of $300 a month.              At any time during

   6    the course of post release supervision, the victim, the

   7    government, or the defendant may notify me of a material change

   8    in the defendant's ability to pay, and I will adjust the

   9    payment schedule accordingly.

 10                 I find the defendant does not have the ability to pay

 11     interest, so that's waived.         And a fine is waived also.         He

 12     doesn't have the ability to pay that.

 13                 I already signed the forfeiture order on April 27th,

 14     so that covers the forfeiture.

 15                 There is a $600 special assessment, which is due

 16     immediately, which I don't have any control over.

 17                 Is there a plea agreement?

 18                 MR. REICHLING:    No, Judge.      This as straight-up plea.

 19                 THE COURT:    So then you have a right to appeal within

 20     14 days of entry of the judgment.         Failure to appeal within

 21     14 days is a waiver of your right to appeal.              The government

 22     may file an appeal from the sentence.

 23                 You are also advised you are entitled to the

 24     assistance of counsel in taking an appeal.              If you're unable to

 25     afford a lawyer, one will be provided for you.              If you can't
Case 2:21-cr-00074-TPB-K_D   Document 134    Filed 08/23/22   Page 9 of 23 PageID 890

                                 IMPOSITION OF SENTENCE                             9


   1    afford the filing fee, the clerk will be directed to accept the

   2    notice of appeal without a fee.

   3                You are going to be allowed voluntary surrender at an

   4    institution designated by the Bureau of Prisons.

   5                Where is it he'd like to go?

   6                MR. MILLER:    The North Carolina area, Judge.

   7                THE COURT:    I'm not familiar with the places up

   8    there.    Okay.   Whatever prisons there are in the information

   9    area.    And he's going to be ordered to report, we'll

 10     say . . . .    What is this, this is the middle of July.             What's

 11     is it, August 15th, is that good?

 12                 MS. PETERSEN:    I believe.

 13                 THE COURT:    What's August 15th?

 14                 COURTROOM DEPUTY:       It's a Monday.

 15                 THE COURT:    A Monday?     Good.    Fine.    August 15th is

 16     his report date at the institution that they will designate

 17     for.

 18                 Now, after considering the advisory sentencing

 19     guidelines, and all the factors identified in Title U.S. Code

 20     Section 3553(a)(1) through (7), I find the sentence I'm about

 21     to impose is sufficient but not greater than necessary to

 22     comply with the statutory purposes of sentencing.

 23                 I've considered the various points that have been

 24     made here, including the idea that Mr. Bruey was volunteering

 25     to basically do some of the time that maybe his wife deserved
Case 2:21-cr-00074-TPB-K_D    Document 134 Filed 08/23/22   Page 10 of 23 PageID
                                      891
                                IMPOSITION OF SENTENCE                         10


 1     so that she wouldn't have to spend time behind bars, and I

 2     considered that, and we talked about that.           That's a tricky

 3     proposition, and I'm not sure it's appropriate in any event.

 4                The guideline calculation, where we left this off was

 5     51 to 63 months; right?       That's where we left it?

 6                MR. MILLER:     Yes, Your Honor.

 7                MR. REICHLING:      That's correct, Judge.

 8                THE COURT:     In this particular case, the reasons for

 9     the sentencing, on the positive side of things, he accepted

10     responsibility.       I think he's expressed genuine remorse, and I

11     think you can see some of that in some of those text messages

12     we talked about last time.       He knew what he was doing was

13     wrong, he did it anyway, but at least he knew it was wrong, and

14     apparently at the time felt bad about it.

15                He wasn't the mastermind of this thing.          I don't

16     think anyone is saying that he is.        His wife is certainly more

17     culpable in terms of filling out the paperwork and things like

18     that, and filing the documents and whatnot.           And I just heard

19     today that he has, or they both have, cooperated in trying to

20     get some of this money back, which is a good and important

21     fact.   That's on the positive.

22                On the negative, he's got a very bad record.            He just

23     has a bad record.       I mean, it is what it is.      He was on

24     probation when this went down for threatening his wife with an

25     AR.   It was an AR-15, not an AK-47.       I just heard testimony
Case 2:21-cr-00074-TPB-K_D   Document 134 Filed 08/23/22   Page 11 of 23 PageID
                                     892
                               IMPOSITION OF SENTENCE                         11


 1     from the FBI firearms expert on the two different weapons.

 2     Whatever it was, it was a serious firearm.

 3                And, you know, on the negative side of things, we're

 4     talking about a lot of money here.       The number, you know,

 5     881,000, and that's just a lot of money to steal.          And it's

 6     used for things like a $50,000 Yukon, which, you know, is an

 7     unnecessary luxury item, and various other luxury items here.

 8     He had 30 different fraud applications, all lies.

 9                You know, he was on probation when this went down.

10     And I guess, during all of this time, there were still people

11     collecting unemployment, and . . . I don't know if they both

12     were, but somebody was collecting unemployment from the State

13     of Florida, and income tax refunds, all this stuff is going

14     down are while stealing from the Federal Government.

15                And I don't know how they did this in a way that they

16     didn't think they were going to get caught.         Seems like there

17     was just a total disregard for the law and, at the end of

18     the day, the amount of money is so great that I don't see any

19     other explanation besides just greed.

20                So I understand the arguments that have been made,

21     but at the end of the day the appropriate sentence for

22     Mr. Bruey is a guideline sentence of 51 months for him, bureau

23     of Prisons.

24                Anyone have any objections?       Anything else they'd

25     like to say?    Is that concurrent on anything?
Case 2:21-cr-00074-TPB-K_D   Document 134 Filed 08/23/22   Page 12 of 23 PageID
                                     893
                               IMPOSITION OF SENTENCE                         12


 1                MR. REICHLING:     That would be fine, Judge.

 2     Concurrent on everything would be appropriate, and there's no

 3     objection from the government.

 4                MR. MILLER:    No objection, Judge.

 5                THE COURT:    All right.

 6                So you have a turn in date.       Don't do anything dumb,

 7     Mr. Bruey.    If you do anything dumb prior to your turn-in date,

 8     I'll bring you in and max you out.

 9                Let's jump no to Mrs. Bruey.

10                MR. MILLER:    Judge, may he be seated in the gallery?

11                THE COURT:    Yes.

12                MR. MILLER:    May we be excused?

13                THE COURT:    Yes.   We should have some -- oh, he's

14     back there.    All right.    Okay.

15                Turning now to Case Number 21-CR-74, Amber Bruey.           On

16     March 16th, 2022, pled guilty to Count 1 through 11, and

17     Counts 14 through 18 of an indictment charging her, in Count 1,

18     with conspiracy to commit wire fraud, in violation of Title 18

19     U.S. Code Section 1349; Counts 2 through 11 charging her with

20     wire fraud, in violation of Title 18 U.S. Code Section 1343,

21     Count 14, charging her with conspiracy to commit money

22     laundering, in violation of Title 18 U.S. Code Section 1956;

23     and Counts 15 through 18 charging her with illegal monetary

24     transactions, in violation of Title 18 U.S. Code Section 1957.

25                I previously accepted her guilty plea and adjudicated
Case 2:21-cr-00074-TPB-K_D   Document 134 Filed 08/23/22   Page 13 of 23 PageID
                                     894
                               IMPOSITION OF SENTENCE                         13


 1     her guilty, and previously had a lengthy sentencing hearing

 2     that I've reviewed everything that's been submitted, including

 3     her sentencing memo and the report from the doctor which was a

 4     confidential thing but was discussed.

 5                So we're now at the point for sentence here.

 6                So, pursuant to Title 18 U.S. Code Section 3551 and

 7     3553, it's my judgment that the defendant, Amber Bruey, be

 8     committed to the custody of the Bureau of Prisons for a term

 9     which I will announce momentarily.

10                Upon release, she has to serve three years of

11     supervised release in each count, to be served concurrently.

12     While on supervised release, she must comply with the mandatory

13     and standard conditions adopted by the Middle District of

14     Florida, including the following special conditions:

15                Number 1, participate in a mental health treatment

16     program, outpatient or inpatient, follow the probation

17     officer's instructions regarding implementation of the

18     directive, and contribute to the cost of the services in an

19     amount determined to be reasonable by the probation office.

20                You're prohibited from incurring new credit charges,

21     opening additional lines of credit, or obligating yourself for

22     any major purchases without the approval of the probation

23     officer.

24                You have to provide the probation officer access to

25     any requested financial information.
Case 2:21-cr-00074-TPB-K_D   Document 134 Filed 08/23/22   Page 14 of 23 PageID
                                     895
                               IMPOSITION OF SENTENCE                         14


 1                 Having been convicted of a qualifying felony, you

 2     must cooperate in the collection of DNA as directed by the

 3     probation officer.

 4                 The mandatory drug testing requirements of the

 5     Violent Crime Control Act are suspended, but you must submit to

 6     random drug tests, not to exceed 104 tests per year.

 7                 You have to pay restitution in the amount of $881,659

 8     as set forth below:

 9                 To Celtic Bank, $35,959.35; Customer's Bank, 20,000

10     TransPecos Bank, 62,400, Small Business Administration,

11     $763,300.    The restitution obligation is payable to the Clerk

12     of the U.S. District Court for distribution to victims.            It's

13     joint and several with Anthony Bruey, who I just sentenced.

14                 While in the Bureau of Prisons custody, you shall

15     either pay at least with $25 quarterly if you have a non-UNICOR

16     job, or pay at least 50 percent of your monthly earnings if you

17     have a UNICOR job.

18                 Upon release from custody, you shall pay restitution

19     in the amount of $300 per month.       At any time during the course

20     of post-release supervision, the victim, the government, or the

21     defendant may notify me of a material change her ability to

22     pay, and I may adjust the payment schedule accordingly.

23                 I find that the defendant does not have the ability

24     to pay interest, and I'll waive that requirement.

25                 Based on her financial status, there is no fine.
Case 2:21-cr-00074-TPB-K_D   Document 134 Filed 08/23/22   Page 15 of 23 PageID
                                     896
                               IMPOSITION OF SENTENCE                         15


 1                Forfeiture order was already signed May 27th, 2022,

 2     on this.

 3                It's further ordered the defendant shall pay the

 4     United States a special assessment of $1,600, which is due

 5     immediately.

 6                You have the right to appeal within 14 days of entry

 7     of the judgment.      Failure to appeal within 14 days is a waiver

 8     of your right to appeal.      The government may file an appeal

 9     from the sentence.

10                You're advised you're entitled to the assistance of

11     counsel in taking the appeal.       If you can't afford a lawyer,

12     one will be provided for you.       If you can't afford the filing

13     fee, the clerk will be directed to accept the notice of appeal

14     without a fee.

15                After considering the advisory sentencing guidelines

16     and all the factors identified in Title 18 U.S. Code

17     Section 3553(a)(1) through (7), I find the sentence I'm about

18     to impose is sufficient but not greater than necessary to

19     comply with the statutory purposes of sentencing.

20                So, in Miss Bruey's situation, on the positive side

21     of the equation there's every reason to believe she's a good

22     parent, a good mom, except for committing crimes like this,

23     stealing large amounts of money from the State of Florida and

24     the United States.      She's a good parent.    I'll say that.

25                She does not have a bad criminal record, and I agree
Case 2:21-cr-00074-TPB-K_D   Document 134 Filed 08/23/22   Page 16 of 23 PageID
                                     897
                               IMPOSITION OF SENTENCE                         16


 1     somewhat with the point that was made by the defense in the

 2     sentencing memorandum about the guidelines overstating her

 3     criminal record.      I understand that.   She does have a

 4     shoplifting case from Wal-Mart, and then she has this theft of

 5     state funds.

 6                As to kind of the elephant in the room, the point

 7     that was made in this confidential report, in terms of, you

 8     know, abusive relationship and whatnot, I understand that

 9     point, but I just don't think it explains all of this and

10     justifies all this, especially when I then learn that the

11     relationship, whatever it may have been, didn't stop her from

12     getting pregnant while they both are under federal indictment

13     and looking at going to federal prison.

14                So that relationship wasn't ideal, but it wasn't

15     nearly as bad that could explain all of this criminal and

16     justify all of this criminal behavior.        So I have taken that

17     into account, though, and I will factor that into my sentence.

18                On the bad side, as I already mentioned with

19     Mr. Bruey, this is just a lot of money here, $881,000 used for

20     $50,000 Yukons and some of these other, you know, ATVs, and

21     high-end ATVs.    I understand maybe she wasn't driving them, but

22     I think I saw a picture -- one of these pictures of her riding

23     anything like that; right?

24                I'm showing Government's Exhibit 6, which I'm being

25     told, well, you know, the ATVs were all kind of male items for
Case 2:21-cr-00074-TPB-K_D   Document 134 Filed 08/23/22   Page 17 of 23 PageID
                                     898
                               IMPOSITION OF SENTENCE                         17


 1     Mr. Bruey to use, but I see her picture with one of their

 2     children, Government's Exhibit 6, I think that maybe is a

 3     Talon, I'm not that familiar with these vehicles.          But, in any

 4     event, that's what they used the money for, not to pay medical

 5     bills and keep people from dying.       They used them for luxury

 6     items and things of that nature.

 7                 Thirty different fraud applications is just a whole

 8     series of lies and fraud.      And she's the one that completed

 9     that paperwork, not Mr. Bruey.       That's for sure, for the most

10     part.    She was on probation at the time for stealing government

11     money from the State of Florida, and she used the money that

12     she stole from the United States to pay the money she stole

13     from the State of Florida while she was on probation for that.

14     That's not good.

15                 Again, at the same time, we have information that

16     they're continuing to collect unemployment and bogus tax

17     refunds.    More stealing government money.

18                 And then I guess the part about this that bothers me

19     the most, this is all done, you know, without . . . without

20     really thinking about what does this mean for the family?

21     Right?    Now we have to worry about it.      I, as the Judge, am

22     supposed to salvage four children here, and five on the way.

23                 Well, she was engaging in this stealing and criminal

24     behavior knowing she had four little kids that could end up

25     basically without parents when she and her husband went to jail
Case 2:21-cr-00074-TPB-K_D   Document 134 Filed 08/23/22    Page 18 of 23 PageID
                                     899
                               IMPOSITION OF SENTENCE                          18


 1     if they got caught.     That's just irresponsible and disregarding

 2     important family responsibilities.

 3                At the end of the day, I'm about done talking about

 4     this, there's no need for any of this to be stolen for this

 5     level.   Maybe a couple thousand, maybe 10,000, maybe 20,000,

 6     but 800,000?    That is called greed.     This should be an episode

 7     out of that show American Greed, because that, at the end of

 8     the day, is what it is, is greed.       So, in light of that, I

 9     cannot go along with the defense request that she should not do

10     any time behind bars.     So the question is for how long.

11                I am going to take into account the stuff in the

12     confidential report, and her lack of criminal record, and

13     sentence her under the guidelines.

14                The guideline sentence in her case was what?

15                MR. REICHLING:     63 to 78 months, Your Honor.

16                THE COURT:    Yeah, 63 to 78 months.       I think 48 months

17     is enough time, all right?      So her sentence is 48 months, which

18     is a below guideline sentence that takes into account some of

19     the points that have been made.       I'm going to work with her on

20     the turn-in date and go out to, we'll say -- the baby is

21     coming, what did we say, mid February?        Let's say April 1st,

22     all right?    That's her turn-in date, April 1st.

23                You guys are going to have to figure out what you do

24     with your family.     That's on you, not me.        All right?   But her

25     turn-in date is April 1st.      If it turns out something goes
Case 2:21-cr-00074-TPB-K_D   Document 134 Filed 08/23/22 Page 19 of 23 PageID
                                     900
                              OBJECTIONS BY MR. LAPPAN                       19


 1     wrong with that pregnancy, which God forbid, I'm not hoping for

 2     that, but if something does, we'll need to know about that, and

 3     her turn-in date needs to be reevaluated.        But for now that's

 4     the turn-in date, and I hope everything goes down well.

 5                 MS. PETERSEN:    April 1st is a Saturday.

 6                 THE COURT:    So the 2nd would be Sunday, and the 3rd

 7     would be Monday.

 8                 MS. PETERSEN:    Correct.

 9                 THE COURT:    April 3rd.

10                 And you want to go someplace in North Carolina also?

11                 MR. LAPPAN:    Yes, Your Honor.

12                 THE COURT:    Okay.   Any objections, or anything else

13     anybody wants to say?

14                 MR. REICHLING:    No objections from the government,

15     Judge.

16                 MR. LAPPAN:    Just could be clear, instead of saying

17     North Carolina, some facility close to where they reside, which

18     is Farmville, North Carolina.       So it may be a place in

19     Virginia, it may be a place in South Carolina.         Someplace close

20     to there.

21                 THE COURT:    That's fine.

22                 MR. LAPPAN:    Judge, if I may, with regard to

23     objections, two things.      I think you may have already decided

24     this, but I want to make sure I understand it.         You're not

25     considering staggering these sentences?
Case 2:21-cr-00074-TPB-K_D   Document 134 Filed 08/23/22 Page 20 of 23 PageID
                                     901
                              OBJECTIONS BY MR. LAPPAN                       20


 1                 THE COURT:    No.   This is the best I can do with this.

 2     I can't have somebody out, you know, four years into the

 3     future.    I thought about it a lot.      I also, frankly, thought

 4     about his requesting of him doing more time so your client

 5     wouldn't have to go at all, and it's not workable to me.          I

 6     think I've given them enough time to figure something out.            And

 7     you do the math on a 48-month sentence and stuff like that, you

 8     know, they can get it figured out.

 9                 MR. LAPPAN:   Judge, if I could, I have to object to

10     the sentence enhancement for sophisticated means.         Can I

11     proceed?

12                 THE COURT:    Yeah.

13                 MR. LAPPAN:   We object to the two-level enhancement

14     for sophisticated means.        As we have premised in our objection

15     letter and the case law contained therein, which was our May 31

16     objection letter which was attached to the addendum to the PSR

17     at Pages 75 through 85 of the PSR, and also as we argued in

18     oral argument before this Court at the previous sentencing

19     hearing.    The Court overruled our objection and imposed the

20     additional two levels for sophisticated means.

21                 We respectfully, Your Honor, object to Your Honor's

22     ruling.    Also, Judge, while I'm on it, we object to the

23     procedural and substantive reasonableness of the sentence

24     imposed on the basis that the sentence imposed is more

25     sufficient than necessary to satisfy the goals of sentencing.
Case 2:21-cr-00074-TPB-K_D   Document 134 Filed 08/23/22 Page 21 of 23 PageID
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                              OBJECTIONS BY MR. LAPPAN                       21


 1                Judge, one more thing.      In an abundance of caution, I

 2     have been made aware that, sometimes, when the PSR addendum

 3     contains the defendant's letter, that does not get included in

 4     the record.    If it please the Court, if the government has no

 5     objection, I'd like to, before we close this proceeding, submit

 6     to the Judge -- submit to the Court our objection letter, which

 7     appears at Pages 75 through 85 in the addendum, and have it

 8     marked or made part of the record for appellate purposes.

 9                THE COURT:    Okay.   I'll just say this, and I don't

10     know what the significance of this is or isn't, but all this

11     back and forth over the sentencing guideline things, I guess I

12     could have -- another way I could have proceeded would have

13     been to agree to your request for a minor role, which would

14     then have changed the sentence.       I don't know what it would

15     have been, but I bet it would have come out in roughly this

16     same place.

17                MR. LAPPAN:    Judge, I never sought minor role.

18                THE COURT:    What was it you just said?

19                MR. LAPPAN:    Sophisticated means two-level

20     enhancement.

21                THE COURT:    My point is, had I agreed with that, and

22     then just given her a straight guideline sentence we probably

23     would have come out in the same place.        And I haven't myself

24     figured out what the most judicious way to handle this is.          I

25     guess I'm just saying I think I could have agreed with you and
Case 2:21-cr-00074-TPB-K_D   Document 134   Filed 08/23/22   Page 22 of 23 PageID
                                     903
                                                                                22


 1     came out where I came out.       I disagreed with that point and

 2     came out where I came out, but at the end of the day I think

 3     we're in basically the same place.        So be that as it may.

 4                 MR. LAPPAN:   Judge, may I present a copy of the

 5     objection letter?

 6                 THE COURT:    Yes.

 7                 MR. LAPPAN:   I'll give Mr. Reichling a copy, as well.

 8     May I have it marked and made part of the record?

 9                 THE COURT:    I'm giving Juan back the government's

10     exhibits that I had that I wanted to look at, so they're part

11     of the record.    And then yours will be?

12                 MR. LAPPAN:    Defendant's 1, I believe.        I had no

13     exhibits.

14                 THE COURT:    Yes.   That will go in the same packet as

15     those.

16                 MR. LAPPAN:    May I approach, Judge?

17                 THE COURT:    Yes.   Okay.   Good luck.

18                            -- -- -- -- -- -- -- --

19          (Thereupon, at 12:27 p.m., the above-entitled matter

20          was concluded.)

21                            -- -- -- -- -- -- -- --

22

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 1

 2                                   CERTIFICATE

 3          I CERTIFY THAT THE FOREGOING TRANSCRIPT IS A TRUE AND

 4     ACCURATE TRANSCRIPT FROM THE ORIGINAL STENOGRAPHIC RECORD IN

 5     THE ABOVE-ENTITLED MATTER.

 6

 7          Dated this 23rd day of August, 2022.

 8

 9

10                                               _
                                             JEFFREY G. THOMAS, RPR, CRR
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