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Home Court filings U.S. v. Carlos Vazquez Transcript of Sentencing Proceedings (Nov. 16, 2021) — United States v. Carlos Vazquez

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Transcript of Sentencing Proceedings (Nov. 16, 2021) — United States v. Carlos Vazquez

No. 1:21-cr-20231-DMM · Doc. 97 · Docket on CourtListener

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Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 1 of 75


                                                 Pages 1 - 74

                        UNITED STATES DISTRICT COURT

                        SOUTHERN DISTRICT OF FLORIDA

    Before The Honorable Donald M. Middlebrooks, Judge

    UNITED STATES OF AMERICA,      )
                                   )
               Plaintiff,          )
                                   )
      VS.                          )             NO. 21-CR-20231-DMM
                                   )
    CARLOS VAZQUEZ,                )
                                   )
               Defendant.          )
    _______________________________)

                                   Miami, Florida
                                   Tuesday, November 16, 2021

                          TRANSCRIPT OF PROCEEDINGS


    APPEARANCES:

    For Plaintiff:
                                JUAN ANTONIO GONZALEZ
                                UNITED STATES ATTORNEY
                                99 Northeast Fourth Street
                                Miami, Florida 33132-2111
                          BY:   HAYDEN PATRICK O'BYRNE, ESQ.
                                ANNIKA MARIE MIRANDA, ESQ.
                                ASSISTANT UNITED STATES ATTORNEYS

    For Defendant:
                                LAW OFFICE OF ALBERT Z. LEVIN, P.A.
                                Courthouse Tower
                                40 Northwest Third Street, Suite 200
                                Miami, Florida 33128
                          BY:   ALBERT ZACHARY LEVIN, ESQ.
                                ATTORNEY AT LAW




    Reported By:        James C. Pence-Aviles, RMR, CRR, CSR No. 13059
                        Official Court Reporter
 Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 2 of 752


1                                   I N D E X

2    Tuesday, November 16, 2021 - Volume 1

3    GOVERNMENT'S WITNESSES                                         PAGE VOL.

4    ESTEVEZ, OSCAR
     (SWORN)                                                         16    1
5    Direct Examination by Mr. O'Byrne                               17    1
     Cross-Examination by Mr. Levin                                  21    1
6    Redirect Examination by Mr. O'Byrne                             24    1

7    BOADA, BARBARA
     (SWORN)                                                         30    1
8    Direct Examination by Mr. O'Byrne                               30    1
     Cross-Examination by Mr. Levin                                  31    1
9    Redirect Examination by Mr. O'Byrne                             33    1

10                               E X H I B I T S

11   GOVERNMENT'S EXHIBITS                                   IDEN   EVID VOL.

12    A                                                       18     25    1

13    B                                                       27     27    1

14

15

16

17

18

19

20

21

22

23

24

25
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1    Tuesday - November 16, 2021                                  1:02 p.m.

2                            P R O C E E D I N G S

3                                    ---000---

4              THE COURT:    Good afternoon.

5          Please be seated.

6              MR. O'BYRNE:     Good afternoon.

7              THE DEFENDANT:     Good afternoon.

8              THE COURT:    This is a sentencing in the case of United

9    States versus Carlos Vazquez, Case Number 21-20231.

10         Can we please have appearances.       And if you'd like to

11   remove your mask while you speak, you may.

12             MR. O'BYRNE:     Good afternoon, Your Honor.      AUSA Hayden

13   O'Byrne on behalf of the United States.         I'm here with my

14   colleague, Annika Miranda, from the asset forfeiture group.            I

15   also have a case agent --

16             THE COURT:    Hold on just a second, please.

17         Can we try to figure out what that is?

18             THE CLERK:    Somebody's drilling somewhere.

19             THE COURT:    Okay.   Well, hopefully that doesn't happen

20   again.

21         Okay.   Mr. O'Byrne, you -- and --

22             MR. O'BYRNE:     Your Honor, I also have my case agent.

23   Giovanni Donies is here from the IRS.        And I have a couple of

24   witnesses outside in case we need them.

25             THE COURT:    All right.    Thank you.
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1              MS. MIRANDA:     Good afternoon, Your Honor.

2              MR. LEVIN:    Your Honor, good afternoon.       Albert Levin

3    on behalf of Carlos Vazquez, who's present before the Court.

4              THE COURT:    Good afternoon, Mr. Levin.

5          I just got a moment ago a motion to withdraw a guilty plea

6    from Mr. Levin, which I've reviewed.        I also reviewed -- I also

7    reviewed the transcript of the change of plea hearing before

8    Judge McAliley.

9          Does the Government want to respond to this?

10             MR. O'BYRNE:     Briefly, Your Honor.

11         Just to bring to the Court's attention -- I'm not sure if

12   you're aware of it, but the Eleventh Circuit issued a case, I

13   believe, yesterday called United States v. Whitehead.           I can

14   pass up a copy of that decision for you, which deals with the

15   consequences of --

16             THE CLERK:    Thank you.

17             MR. O'BYRNE:     The Whitehead opinion, on Page 8, sets

18   forth the standard in the Eleventh Circuit.         It's a four-factor

19   test that went along with the Eleventh Circuit's (Inaudible).

20        (Court reporter requests clarification for the record.)

21             THE CLERK:    Counsel, we cannot hear you.

22             THE COURT:    What's going on?     Do we have --

23             COURT SECURITY OFFICER:      I already called.     They're

24   going to come up and see where that's coming from.

25             THE COURT:    Sounds like it's upstairs.
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1              THE CLERK:    Yeah.    That's what it sounds like.

2              COURT SECURITY OFFICER:      They're working on it, too.

3              THE COURT:    Okay.    Thank you.

4              MR. O'BYRNE:     Thank you, Your Honor.

5          Page 8 of this Whitehead opinion from the Eleventh Circuit

6    explains that there's a four-factor test, but if the defendant

7    does not satisfy the first two of those factors, it is not

8    necessary to thoroughly analyze the remaining two factors.

9    Those factors are whether close assistance of counsel was

10   available and whether the plea was knowing and voluntary.

11         I think that if you look at the end of the plea colloquy

12   transcript -- I think it's Pages 37 to 39 -- all of those

13   factors were clearly addressed by Judge McAliley, and this is

14   not a situation where the change of plea was inappropriate.

15             THE COURT:    All right.    I'm -- I'm going to deny the

16   motion to withdraw the guilty plea.

17         I've reviewed the motion.      The motion deals for the most

18   part with sentencing issues.       It also contains statements that

19   conflict with the statements made by the defendant during the

20   plea colloquy with Judge McAliley.        I've reviewed that entire

21   transcript, and it appears to me under these factors whether

22   close assistance of counsel was available.

23         Mr. Levin was there.      Defendant expressed total confidence

24   and satisfaction with Mr. Levin, said he thought he was doing a

25   great job for him.     The plea was knowing and voluntary.        The
 Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 6 of 756


1    magistrate went through all of the factors, including whether

2    any representations or promises had been made to him by the

3    Government.    And he agreed they had not, which conflicts with

4    what he is now saying in the motion.

5          And the motion deals with some issues that we would take

6    up at sentencing such as whether or not he gets acceptance of

7    responsibility.     I'm frankly inclined to grant him an

8    acceptance, although he's doing everything he can to take

9    himself out of that category, it looks like, Mr. Levin, as he

10   goes through, including not even signing medical releases so

11   Probation can find out something about his medical

12   circumstance, which you've raised as well.

13         So I see absolutely no basis to allow withdrawal of this

14   plea, and the Eleventh Circuit in this opinion talks about the

15   delay between entry of plea and the motion to withdraw it.

16   This is done on the -- either -- I think the morning of

17   sentencing.

18         So let's -- let's proceed.      I've -- and I have adopted the

19   report and recommendation of the magistrate, and I adjudge

20   Mr. Vazquez guilty of the crime charged.         There is no written

21   plea agreement.     There was a factual proffer that he agreed to

22   in the plea colloquy.

23         I've read the defendant's memorandum and request for a

24   variance, the Government's response, the Government's

25   objections, which went to acceptance and obstruction, the
 Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 7 of 757


1    addendum to the PSI.      The PSI, as it presently stands, does not

2    grant acceptance.     It does enhance for obstruction.       Mr. Levin,

3    you also disagree with sophisticated means.

4          I will tell you -- I'm going to not cut off lawyers in

5    terms of argument.     I'm inclined to agree with Mr. Levin on

6    that one.    I'm not sure how sophisticated this was.        It was

7    basically a defunct corporation that he revitalized.           It's, I

8    guess, surprising to me the loan went through.          But -- but I

9    don't find that tactic and then later on, I guess, the issuance

10   of the multiple checks to be all that sophisticated.

11         But if you want to -- I guess I'll first turn to the

12   Government.    Do you want to argue on this sophisticated means?

13             MR. O'BYRNE:     Your Honor, I agree with you.       I think

14   it's a close case.     The comments to the sentencing manual talk

15   about use of shell companies, and here that was the basis of

16   the fraud, using that defunct company to rehabilitate -- to

17   rehabilitate the company and then use that formerly defunct

18   company to get the loan.

19         But I agree with you, Your Honor.       This is not the most

20   sophisticated case I've ever seen.

21             THE COURT:    All right.    I'm going to grant that --

22   that objection.

23         I'm also inclined -- although, as I say, it's a close

24   question because he's done everything he can other than -- he

25   did take the important step -- and I think it took three times,
 Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 8 of 758


1    but he did take the important step of -- he pled guilty.           The

2    Government avoided the necessity of trial, although I think you

3    had to do some preparation.

4          I'm inclined to grant the two levels.        The Government

5    controls the third.     He also missed my deadline in terms of the

6    deadline for timely acceptance, but I am inclined to grant a

7    two-level adjustment for acceptance.

8          But, again, if you want to try to convince me otherwise,

9    go ahead.

10             MR. O'BYRNE:     Your Honor, I think in this case -- I

11   think you pointed out this defendant is --

12             THE COURT:    Have you heard anything yet?

13             COURT SECURITY OFFICER:      They're sending -- they're

14   working on trying to locate it.

15             THE COURT:    All right.    When I was in private

16   practice, one of my lawyers, this happened to.          And then he

17   kept trying to get them to stop, and they didn't.          So he went

18   and he yanked the cord out of the drill --

19                                 (Laughter.)

20             THE COURT:    -- which I think might be the best way to

21   handle this.

22         Go ahead.

23             MR. O'BYRNE:     Yes, Your Honor.

24         My -- in this case, Your Honor, the defendant did plead

25   guilty.   He had also tendered the check, which I think is of
 Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 9 of 759


1    importance --

2               THE COURT:   Just rest a second.

3               THE CLERK:   Maybe if you go to the podium and you're

4    closer to the microphone, we'll be able to hear you better.

5               MR. O'BYRNE:    Is this better?

6               THE COURT:   It is better, yeah, and -- but that drill

7    is awfully annoying, if that's what it is.

8          Go ahead.

9               MR. O'BYRNE:    Certainly.

10         Your Honor, in this case, I think he -- he did plead

11   guilty.    It took a little while to come around to do it.         We

12   had to prepare for trial multiple times, and he did tender the

13   check.    But after he pled guilty -- and I think you pointed out

14   he's sort of done everything he can to, you know, walk back on

15   that, including this morning filing the motion to withdraw his

16   guilty plea.

17         You know, we found out with the PSI that he had filed this

18   backdated deed.     Right now, he's in violation of the conditions

19   of his bond that he not sell or encumber assets, which he did.

20         We also -- and then also at the change of plea hearing, he

21   insisted that he was a U.S. citizen during the part of the plea

22   colloquy when Judge McAliley asked if he was an American

23   citizen.    And he said he was, and that was something that we

24   had to correct.

25         And now he's been adamant that he is an American citizen
                                                                                10
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1    throughout these proceedings, Your Honor, and we followed up on

2    that thoroughly because it's not something that we take for

3    granted.   We actually got the entire A-file to review and found

4    that, you know, he was ordered deported.

5         He went through a Board of Immigration Appeals proceedings

6    on the exact issue he's raising, that he became a naturalized

7    citizen through his father -- through derived citizenship from

8    his father.   That argument was before the Board of Immigration

9    Appeals, and it was rejected.      This defendant was personally

10   served with that.

11        I mean, these are things that he knew, but he continued to

12   assert them at the change of plea hearing and then going

13   forward.   And I do think they're relevant, and they made their

14   way into the PSI.    So I think they're material.

15              THE COURT:   All right.    I'm going to -- you've made

16   good points on the acceptance issue, but he did plead guilty.

17   So I'm going to give him the two levels.

18        Mr. Levin, I'm inclined to agree with the Government on

19   the obstruction.    Do you still object to the obstruction?

20              MR. LEVIN:   Yeah, I do, Your Honor.     I really object,

21   and I just want to say a couple things before I argue on that

22   particular issue.

23        As far as his motion for a new trial two hours before

24   sentencing, his concern -- just know that it was borne of fear

25   and frustration of Mr. Vazquez because this is obviously a very
                                                                                11
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1    important day in his life.      So that's what -- that was what the

2    product of that was.     He stands by his guilty plea.       He

3    admitted after he got arrested that he did this.

4         Okay.    As far as the previous two pleas that you couldn't

5    get through, I wasn't there.      I don't know what happened.      I

6    know this.    He needs a lot of attention.

7         Okay.    I don't know anything about Mr. Fleites.        I don't

8    know anything about Mr. Cohen or whatever the other lawyer's

9    name was, but he didn't understand certain legal concepts

10   frankly, in my opinion, until I started representing him.          And

11   then he understood the concept of deliberate ignorance, and

12   then he understood the concept of willful blindness.

13        And his whole position on this has been that he got

14   involved with this guy, who was paid $170,000, who has yet to

15   be indicted.    The Government doesn't want to hear from

16   Mr. Vazquez with regard to any substantial assistance he wanted

17   to provide with regard to the person that we believe was the

18   driving force of this fraud, not to take away from his

19   involvement.

20        But that as a backdrop leads me to the obstruction with

21   regard to where he was born, which, to me, is somewhat of an

22   absurdity only because it has nothing to do with the PPP.

23   Okay?   This is not an immigration case.       This is not an

24   immigration proceeding.     This is a case involving a fraud on a

25   PPP loan.    Now --
                                                                                12
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1              THE COURT:    Doesn't it affect, though -- and I'll give

2    you a chance -- I think --

3              MR. LEVIN:    Right.

4              THE COURT:    -- the Government is going to have to put

5    some evidence on if you've objected, and you have.         So I think

6    they're going to need to do that.

7         But -- I mean, the lines on citizenship -- and apparently

8    he told the probation officer something different still.           He

9    told her he was born in Chicago, not any of this naturalized --

10             MR. LEVIN:    Well, he made --

11             THE COURT:    -- business.

12             MR. LEVIN:    Yeah.

13             THE COURT:    So -- but it -- doesn't it affect first

14   bond and then it affects the plea colloquy in terms of the

15   magistrate giving the advice or my -- my giving him of the

16   advice on the occasions where I had to deal with it?          It

17   affects the Bureau of Prisons.

18             MR. LEVIN:    Okay.

19             THE COURT:    And so it seems to me that it is

20   important.   I hear it raised a lot of times by both sides at

21   sentencing, usually defense counsel arguing that since he's

22   someone who's going to get removed, they shouldn't have to

23   serve a lengthy sentence.       It seems like that is an important

24   and material problem.

25             MR. LEVIN:    Well --
                                                                                13
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1              THE COURT:    And -- but frankly, to me, the more

2    significant problem is this whole backdating of the -- of the

3    deed after a pretrial determination that he couldn't encumber

4    assets.   And not only does he encumber them, he backdates the

5    deed to allow him to do it, according -- assuming the

6    Government can prove that.

7         And your objection, I think, to the PSI makes him have to

8    prove it.

9              MR. LEVIN:    Okay.   With regard -- if I may just

10   address the Court's comments on those particular issues, the

11   deed was dated 2019.     That's not disputed.     It was filed a

12   couple of weeks ago with the Clerk's Office.

13             THE DEFENDANT:    No.   No.   July 12th.

14             MR. LEVIN:    Okay.   Excuse me.    July 12th, it was filed

15   with the Clerk's Office.

16             THE DEFENDANT:    Before I even hired you.

17             MR. LEVIN:    Before I was even in the case.       So --

18             THE COURT:    Well, apparently these witnesses say it

19   was signed in 2021, don't they?       Isn't that what the issue is?

20             MR. LEVIN:    I think --

21             THE COURT:    The notary and the person to whom he tried

22   to transfer the property both say this didn't happen in 2019.

23   It happened after --

24             MR. LEVIN:    You're right.

25             THE COURT:    -- he was arrested.
                                                                                14
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1               MR. LEVIN:   You're right.     That's what they're

2    alleging in their pleadings, correct, my mistake.

3         Regardless, as far as that is concerned, the deed has been

4    transferred back to him.     It's -- the property is in

5    Mr. Vazquez's name.     When he told me that this occurred, I

6    immediately instructed him that that needed to be undone, and

7    he did.    So he tried to correct his wrong, if you will.

8               THE DEFENDANT:   Yeah.    I was told by Mr. Fleites --

9               MR. LEVIN:   Okay.    Okay.   With regard to the

10   citizenship issue, it is our belief and his belief that he said

11   that he -- he was born in Havana but not -- not born in Chicago

12   but grew up in Chicago, where he did spend the first ten years

13   of his life.

14        I also provided to Probation a card which reflects that he

15   is a naturalized citizen.       And it was his belief, his thought

16   that, in fact, he was a citizen based on derivative -- the

17   derivative citizenship from his parents.        And that happened

18   20 -- I don't know.

19        You have the -- Madam Probation Officer, you have that

20   document; right?

21              THE PROBATION OFFICER:     Yes.

22              MR. LEVIN:   Okay.    Whatever the date is on that

23   document, that reflects that he's a naturalized United States

24   citizen.    Again, it is a material point.      There's no question

25   about it.
                                                                                15
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1         But given what I believe the facts are going to show in

2    this case -- and I'll stipulate to most of this stuff so we

3    don't have to take up too much of the Court's time.          I think

4    that you're -- as far as the deed is concerned, I mean, it's

5    something that he drafted up.      He wasn't trying to transfer

6    assets.

7         The prosecutor -- and I don't really want to violate Rule

8    11, but one of the things that was a driving force was he

9    returned the 175,000-dollar check, which was made payable to

10   the IRS, which really makes no sense if you think about it.

11   There's an argument for that -- or a reason for that.          I'm not

12   going to get into that because I don't want to waste any more

13   time with that because it's not really the issue.

14        But he gave him the check back.       That showed his good

15   faith, his acceptance.     Before I got involved is when he

16   transferred the property because he thought he was going to be

17   going to jail.    He told me about it.     He reversed that.     He put

18   it back in his name.

19             THE DEFENDANT:    It was more because of my health.

20             MR. LEVIN:    And -- and he's got -- obviously, he has

21   health issues.    He was in the hospital.      He got out, like, two

22   days ago, and that's where we're at.

23        I don't know if you want to hear testimony or not.          I

24   mean, I would stipulate that the document was dated then.            I

25   will stipulate that these witnesses will say that it
                                                                                16
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1    happened -- what, a couple months ago?

2              MR. O'BYRNE:    Yeah, I believe so, this summer.

3              MR. LEVIN:    I mean, if the Court wants to hear

4    evidence on that, if the Court is still inclined to rule with

5    the Government, then yes, I have to so I don't have a --

6              THE COURT:    Well, it takes two to stipulate.

7              MR. LEVIN:    -- 2255 -- right.

8              THE COURT:    So if you don't know if you're going to

9    accept a stipulation --

10             MR. LEVIN:    I can't accept -- I can't accept it.       I'm

11   going to have to let him put on some witnesses, Judge.

12             THE COURT:    You do need to?

13             MR. LEVIN:    I would have to.     Otherwise, I would be --

14             THE COURT:    Okay.   Well, let's go ahead and do that,

15   then.

16             MR. LEVIN:    Yeah.   All right.

17             MR. O'BYRNE:    At this point, the United States calls

18   Oscar Jose Estevez.

19             THE CLERK:    Raise your right hand.

20                              OSCAR ESTEVEZ,

21   called as a witness for the Government, having been duly sworn,

22   testified as follows:

23             THE WITNESS:    I do.

24             THE CLERK:    Yes.

25        When you have a seat, if you're comfortable removing your
                                                                                17
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                         ESTEVEZ - DIRECT / O'BYRNE

1    mask, please do so.     And please state your full name and spell

2    your name for the record for the court reporter.

3         Thank you.

4                             DIRECT EXAMINATION

5    BY MR. O'BYRNE:

6    Q.   Good afternoon, sir.

7    A.   Good afternoon.

8    Q.   Could you please state your name for the record.

9    A.   Oscar Estevez, E-s-t-e-v-e-z.

10   Q.   Thank you.

11        And, Mr. Estevez, could you briefly tell us where are you

12   employed?

13   A.   I'm basically a full-time caretaker for my dad, but I

14   work, like, maybe six hours a week doing filing work for a

15   friend of mine.

16   Q.   Do you know the defendant, Mr. Carlos Vazquez?

17   A.   I've known him for about 46 years -- 45, 46 years.

18   Q.   And was there a time that Mr. Vazquez came to you to ask

19   you if he could transfer a piece of property to you?

20   A.   Yes, there was.

21   Q.   Could you please tell me about that.

22   A.   He was in a situation, a legal situation, and he thought

23   that he might go to jail.      And his health has been really,

24   really bad over the years.      And he asked me if he could

25   transfer the property to me because he didn't think that he
                                                                                18
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                         ESTEVEZ - DIRECT / O'BYRNE

1    would make it while he was in jail.       He wouldn't survive jail.

2    That's what he told me.

3    Q.     Did he give you any further explanation as to why he

4    wanted to transfer the property to you?

5    A.     I think his main concern was "I'm not going to survive

6    jail," and I don't think he has a good relationship with his

7    son.    So I think -- I've been a friend to him over the years,

8    and he -- he asked me if he could transfer the property to me.

9    Q.     At what time did Mr. Vazquez ask to transfer this piece of

10   property to you?

11   A.     I don't recall the exact date, but it was a few months

12   ago.

13   Q.     Was it during the year 2021?

14   A.     Yes.

15   Q.     Was it in the summer of 2021?

16   A.     Around the summer, yes.

17   Q.     Now, I've put in front of you a document -- and I

18   apologize.    I forgot to label it, but we'll exhibit -- we'll

19   mark it as Exhibit A, which is styled "Quitclaim Deed."

20           (Government's Exhibit A marked for identification.)

21              THE WITNESS:   Yes.

22   BY MR. O'BYRNE:

23   Q.     Are you familiar with this document?

24   A.     I received a copy from the Recorder's Office at my house.

25   Q.     Prior to receiving that from the Recorder's Office, had
                                                                                19
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                         ESTEVEZ - DIRECT / O'BYRNE

1    you seen it before?

2    A.   I don't remember seeing this before, no.

3    Q.   When did you receive this from the Recorder's Office?

4    A.   I have -- I have the copy that I received from -- from the

5    Recorder's Office.     So I've got to say sometime in late July.

6    I don't remember the exact date, but it's got to be late July.

7    Q.   Did you pay Mr. Vazquez anything in consideration for this

8    property?

9    A.   No.

10   Q.   Did you have any discussions with Mr. Vazquez about the --

11   about the transaction that would result in you getting his

12   property?

13   A.   A few times.    He asked me initially -- well, he said he

14   wanted to transfer the property to me.        I didn't want it.    I --

15   you know, I learned later on that the property came with a

16   foreclosure, too many problems for me.        I take care of my

17   96-year-old dad.    So I said, "No."

18        Then he asked me again maybe one or two more times, and he

19   kept insisting -- or telling me that he knew he wasn't going to

20   survive jail, that he knew that if he went in, because of his

21   health condition, that he would not survive.        And he doesn't

22   have a good relationship with his son.

23        He says, "You're the only person that I can transfer the

24   property to."

25        So eventually, I conceded.       I said, "Yes."
                                                                                20
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 20 of 75
                         ESTEVEZ - DIRECT / O'BYRNE

1    Q.     Did you and Mr. Vazquez have any discussions about your

2    return of the property to Mr. Vazquez?

3    A.     I don't think there was any -- I don't remember having any

4    discussions.    I never considered that property mine.        I always

5    considered it his.      If he went to jail and he came out, it was

6    his property.    I -- you know, I never considered that my

7    property.

8           So -- you know, if he went in and something happened,

9    then -- to him, then I would have to deal with the property.

10   But if he came out, it's always his property.         That's how I saw

11   it.

12   Q.     And did you intend to return it to him?

13   A.     I did return it to him.

14   Q.     But at the time you received this property, did you intend

15   to return it to Mr. Vazquez if he asked you for it back?

16   A.     Initially, no.    I -- I told him that I didn't want the

17   property, that I wanted him to take it back.        And then a few

18   weeks passed, and I remember I got a -- after I spoke to the

19   IRS agent, I realized he can't do anything at that point.          The

20   property is in my name.     Legally, it's in my name.

21          So I'm the one who's got to return the property back to

22   him.   So I actually prepared a deed and transferred it back to

23   him.

24   Q.     Well, let me clarify that for a second.

25          So at the time this deed was transferred to you, you
                                                                                21
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 21 of 75
                           ESTEVEZ - CROSS / LEVIN

1    didn't know about it until you got a notice from the --

2    A.   No.   He did tell me before that he was going to transfer

3    the property, and then I got the deed in the mail.         But then

4    after that, then we had discussions.       I told him, "I don't want

5    the property.    Please take it back."     Then we had a -- maybe a

6    few times -- we did speak about that.

7         And then at some point, I realized, "Well, he can't take

8    it back anymore.    The property is in my name.       I've got to

9    transfer it back to him."      That's what I did.     I prepared the

10   deed and transferred it back to him.

11   Q.   Did Mr. Vazquez ask you to transfer it back to him, or did

12   you do that on your own volition?

13   A.   I think I did speak to him, and I told him I was going to

14   transfer it back.    And he said yes, that he wanted the property

15   back.

16   Q.   Thank you.

17        No further questions.

18   A.   Sure.

19                             CROSS-EXAMINATION

20   BY MR. LEVIN:

21   Q.   Mr. Estevez, good afternoon.

22   A.   Good afternoon.

23   Q.   You've known Mr. Vazquez pretty much your entire life;

24   correct?

25   A.   About 46 years, yes.
                                                                                22
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 22 of 75
                           ESTEVEZ - CROSS / LEVIN

1    Q.   Okay.    And so this particular unit -- you know that this

2    unit belonged to his mother one time; right?

3    A.   Yes, I did.    Yes.

4    Q.   She passed away; correct?

5    A.   Yes.    Yes, I knew that.

6    Q.   Okay.    And he's been asking you to take title to this

7    property for a number of years; correct?

8    A.   I don't remember that.

9    Q.   You don't remember him asking you a couple of years ago to

10   take the property?

11   A.   I remember him mentioning -- talking to me about his

12   property, but that specific conversation, I don't remember.           I

13   know he's -- he's had a lot of health issues over the years --

14   Q.   Right.

15   A.   -- and he's mentioned the property.        But that specific

16   conversation, I do not remember.

17   Q.   Okay.    So he has discussed with you the property over the

18   years because he's had a lot of health problems, and he's been

19   concerned about his mortality; right?

20   A.   Yes.

21   Q.   Okay.    And you don't know if you spoke to him in 2019

22   about it; right?

23   A.   I don't remember.     It's been a while.

24   Q.   You don't remember?

25   A.   Yeah.
                                                                                23
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 23 of 75
                           ESTEVEZ - CROSS / LEVIN

1    Q.    Now, this exhibit that you -- that bears your signature --

2    did you look at it when you signed it?

3    A.    Which one?

4    Q.    The one that you're looking at now.       It says "Quitclaim

5    Deed" at the top.

6    A.    The one that I prepared?     The one that I prepared?      The

7    one that I prepared?

8    Q.    No, the one that Mr. Vazquez prepared.

9    A.    I'm not -- I'm not seeing my signature on this one.

10               MR. LEVIN:   May I approach the witness, Your Honor?

11               THE COURT:   Yes.

12               MR. LEVIN:   Thanks.

13   BY MR. LEVIN:

14   Q.    Are you Oscar Jose Estevez?

15   A.    Yes.

16   Q.    Let me show you.

17         Is this your signature?

18   A.    No.

19   Q.    Not your signature?

20   A.    No.

21               MR. LEVIN:   Okay.   I don't have any further questions,

22   Your Honor.

23               THE COURT:   Is there redirect?

24               MR. O'BYRNE:   Let me just clarify that point.

25   ///
                                                                                24
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 24 of 75
                        ESTEVEZ - REDIRECT / O'BYRNE

1                             REDIRECT EXAMINATION

2    BY MR. O'BYRNE:

3    Q.   Mr. Estevez, just to clarify that point, the first

4    document that we've been talking about, the one that's styled

5    "Quitclaim Deed" and bears Court File Number 2021R0493913 --

6    A.   I think Mr. Levin took the document back.         I don't have

7    that document with me.

8              MR. LEVIN:    My mistake.    Sorry, sir.

9              THE WITNESS:    Thank you.    Okay.

10   BY MR. O'BYRNE:

11   Q.   So the document that we've been talking about styled

12   "Quitclaim Deed" bearing Miami-Dade Court File

13   Number 2021R0493913 -- it's styled "Quitclaim Deed."          That's

14   the deed purporting to transfer the property to you; correct?

15   A.   That's correct, yes.

16   Q.   And you learned from the property -- from the Recorder's

17   Office that this property had been transferred to you?

18   A.   Well, he did tell me he was going to transfer it before,

19   but I learned that it was -- that it had been -- that it had

20   been filed when I received it at home.

21   Q.   Okay.   And you -- you looked at something.        I believe you

22   have the original copy you got from the Recorder's Office with

23   you; is that correct?

24   A.   For this -- for this particular document?

25   Q.   Yes.
                                                                                25
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 25 of 75
                        ESTEVEZ - REDIRECT / O'BYRNE

1    A.   Yes, I do.    Yes.   This is -- well, I'm not sure if this is

2    the original document, but this is the certified document that

3    the Recorder's Office sends out.

4    Q.   Okay.

5    A.   Yes.    It's the same document that Mr. Levin was just

6    showing me now.

7              MR. O'BYRNE:    Okay.   I'd move that in as Exhibit 1 --

8    or Exhibit A.

9              MR. LEVIN:    No objection.

10             THE COURT:    You had an Exhibit A.     What is this?

11             MR. O'BYRNE:    This is Exhibit A.     Let's call this

12   Exhibit A, Your Honor, the quitclaim deed with --

13             THE COURT:    All right.

14             MR. O'BYRNE:    -- Court File Number 2021R- --

15             THE COURT:    Right.

16             MR. O'BYRNE:    -- -0493913.

17             THE COURT:    "A" is admitted without objection.

18         (Government's Exhibit A received in evidence.)

19   BY MR. O'BYRNE:

20   Q.   All right.    Let's now talk about the other deed I just

21   handed you with Court File Number 2021R0813381.

22        Do you have that document in front of you?

23   A.   I do, yes.

24   Q.   Now, is this -- are you the Oscar J. Estevez identified in

25   this document?
                                                                                26
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 26 of 75
                        ESTEVEZ - REDIRECT / O'BYRNE

1    A.   Yes, I am.

2    Q.   And is that your signature at the bottom?

3    A.   Yes, it is.

4    Q.   And was this document -- did you record this document in

5    the Miami-Dade public records?

6    A.   I personally did, yes.

7    Q.   Okay.   And what was your purpose in doing that?

8    A.   I wanted to give Mr. Vazquez back the property.          We had

9    spoken maybe -- I don't remember how many times, but I told him

10   that I didn't want the property.       And at some point, he said

11   that he wanted the property transferred back.

12        We had some conversations, and I told him, "Please take it

13   back" because I didn't want the property.        Then I realized that

14   he wasn't able to take it back because it was legally in my

15   name.   So I went and transferred the property myself.

16   Q.   And when did Mr. Vazquez ask you to transfer the property

17   back?

18   A.   I don't recall exactly.      It was sometime before the

19   transfer, but I don't recall exactly.       We -- we -- I mean, we

20   spoke often.    I haven't spoken to him or seen him since I got

21   served with the subpoena to come to court, but I've known him

22   46 years, and we did speak often.

23        And I couldn't tell you exactly when he asked me that, but

24   sometimes we spoke maybe two, three times a day.         So I really

25   can't pinpoint the exact time and date that you're asking me
                                                                                27
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 27 of 75
                        ESTEVEZ - REDIRECT / O'BYRNE

1    of.

2    Q.    Was it between July and October of 2021?

3    A.    As soon as the property was transferred to me, I wanted

4    the property transferred back.       So we had many conversations

5    between July and October.      In terms of specifically when that

6    occurred, the conversation that you're asking me about, I

7    couldn't tell you.     But it was within that time frame, yes.

8    Q.    All right.   Thank you.

9              MR. O'BYRNE:    At this point, the Government would move

10   Exhibit B into evidence.

11          (Government's Exhibit B marked for identification.)

12             MR. LEVIN:    No objection, Your Honor.

13             THE COURT:    B is admitted.

14          (Government's Exhibit B received in evidence.)

15             MR. O'BYRNE:    And I realize I have a third page, which

16   I didn't mean to include, on the back of my sheet.         This should

17   just be a two-page document, which is the deed.

18         Thank you.   No further questions.

19             THE WITNESS:    You're welcome.

20             THE COURT:    All right.    Thank you, sir.

21             THE WITNESS:    Thank you.

22             COURT SECURITY OFFICER:      Watch your step there.

23             THE DEFENDANT:    God bless you.

24             MR. O'BYRNE:    Your Honor, at this time, the United

25   States would call Estevan Valderrama, who I believe is in the
                                                                                28
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 28 of 75


1    other room.

2               COURT SECURITY OFFICER:     Face the clerk.    She'll swear

3    you in.

4               THE CLERK:   Please raise your right hand.

5          Do you speak English?

6          Do you swear or affirm the testimony you're about to give

7    will be the truth, the whole truth, and nothing but the truth?

8          Judge, it doesn't appear that he speaks English.

9          Counsel, your witness doesn't appear to understand

10   English.

11              MR. O'BYRNE:   Your Honor, I think we can resolve -- I

12   think we can resolve this.

13              THE DEFENDANT:   Where is he?    Does he have any

14   warrants?    Is he deported?    Is he a criminal?     Is he in federal

15   custody?    No.   I don't want to be the only bad guy here in the

16   courtroom.    I want the honorable judge to understand --

17              THE CLERK:   Un momento, por favor.

18              THE WITNESS:   Okay.

19              THE CLERK:   He doesn't understand -- I can't swear him

20   in.   He doesn't understand what I'm saying.

21              MR. O'BYRNE:   In that case --

22              THE CLERK:   You would need an interpreter.

23              MR. O'BYRNE:   Yeah.   I apologize for that.

24         At this point, the United States will call Elvia

25   Gomez-Vega.
                                                                                29
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 29 of 75


1         All right.    Your Honor, we have a stipulation.        The

2    stipulation is that Estevan Valderrama would stipulate -- let

3    me rephrase that, Your Honor.

4         The United States and the defense stipulate that Estevan

5    Valderrama would testify that he signed the quitclaim deed,

6    Exhibit A, in 2021.

7              THE COURT:    Was he the notary?     Is that who this

8    person is?

9              MR. O'BYRNE:    Estevan Valderrama is the witness on

10   Page 3 of Exhibit A.

11             THE COURT:    Okay.   So the witness signed in 2021.

12   That's the stipulation?

13             MR. O'BYRNE:    Yes, Your Honor.

14        You're stipulating to all the witnesses signing it?

15             MR. LEVIN:    No, just that witness.

16             MR. O'BYRNE:    Okay.

17             MR. LEVIN:    That witness.

18             THE COURT:    All right.    And, Mr. Levin, that's -- you

19   agree with that stipulation that --

20             MR. LEVIN:    Yes, Your Honor.

21             THE COURT:    -- the witness signed the -- as the

22   witness in 2021?

23             MR. LEVIN:    Correct.

24             THE COURT:    All right.

25             THE CLERK:    Please raise your right hand.
                                                                                30
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 30 of 75
                          BOADA - DIRECT / O'BYRNE

1                               BARBARA BOADA,

2    called as a witness for the Government, having been duly sworn,

3    testified as follows:

4              THE WITNESS:    Yes, ma'am.

5              THE CLERK:    Okay.   When you have a seat, into the

6    microphone, please state your full name and spell your name for

7    the record.

8              MR. O'BYRNE:    May I approach to hand the witness a

9    copy of Exhibit A?

10             THE WITNESS:    Barbara Boada.

11             THE CLERK:    I'm sorry.    Can you repeat your name and

12   spell it for me?

13             THE WITNESS:    Barbara, B-a-r-b-a-r-a, Boada,

14   B-o-a-d-a.

15             THE CLERK:    Thank you.

16                            DIRECT EXAMINATION

17   BY MR. O'BYRNE:

18   Q.   Ms. Boada, thank you for coming in today.

19        Could you just briefly tell us where you're employed?

20   A.   First Capital Property and Casualty.

21   Q.   Okay.    And are -- you're a notary public; correct?

22   A.   Yes, I am.

23   Q.   All right.    I'd like to ask you a few questions about the

24   exhibit I just handed you, Exhibit A.

25   A.   Yes, sir.
                                                                                31
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 31 of 75
                            BOADA - CROSS / LEVIN

1    Q.   Is that your signature that appears on the last page?

2    A.   Yes, it is.

3    Q.   Do you recall signing this document?

4    A.   Yes, I do.

5    Q.   And when you signed this document, was it the same

6    four-page document?

7    A.   Yes, it was.

8    Q.   Now, do you recall when this document was signed?

9    A.   Sometime in, like, June, I believe, June -- first week of

10   June of this year.

11   Q.   Of this year?

12   A.   Correct.

13   Q.   Now, it says here that the instrument was acknowledged

14   before you in March of 2019.      I just want to confirm.      That's

15   incorrect.   This was -- this document was acknowledged and

16   signed in 2021; is that correct?

17   A.   Correct.

18   Q.   Thank you.

19             MR. O'BYRNE:    No further questions.

20             MR. LEVIN:    Can I have the exhibit?

21                             CROSS-EXAMINATION

22   BY MR. LEVIN:

23   Q.   So, Ms. Boada -- so you -- you signed this document, which

24   reflected a date of March 17th, 2019, even though it was 2- --

25   2021?
                                                                                32
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 32 of 75
                            BOADA - CROSS / LEVIN

1    A.     The last page doesn't say a date, sir.

2    Q.     Are you looking at Page 4 of 4?

3    A.     4 of 4?   Yes, it does.

4    Q.     "The foregoing instrument was acknowledged before me, by

5    means of physical presence, this 17th day of March, 2019, by

6    Carlos Vazquez, who is personally known to me or who has

7    produced Florida ID as identification.        Barbara Boada"?

8    A.     Yes, sir, that's me.

9    Q.     Okay.   But it's -- how come it says March 17th, 2019, if

10   he signed it in '21?

11   A.     I signed it in '21.    I didn't say that he signed it in

12   '21.

13   Q.     You signed it in 2021, but you're -- you're signing a

14   document which says the 17th of March, 2019, and that's when he

15   signed it.     And it wasn't in your presence apparently, or was

16   it?

17   A.     The document that I signed was the last page, and I didn't

18   read the date.    I'm sorry I didn't read the date.

19   Q.     Well, isn't it important to have the right dates on

20   documents that you notarize and you're swearing that it was

21   signed --

22   A.     Well --

23   Q.     Let me finish my question.     Let me finish my question.

24              MR. LEVIN:   Sorry, sir.

25   ///
                                                                                33
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 33 of 75
                         BOADA - REDIRECT / O'BYRNE

1    BY MR. LEVIN:

2    Q.   The date's important where you notarize somebody

3    signature's; right?

4    A.   Correct.

5    Q.   All right.    But you didn't look -- you didn't look at that

6    date?

7    A.   No, I didn't.

8    Q.   Even though it says right above your signature March 19th?

9    A.   I didn't read it.

10   Q.   March 17th, 2019?

11   A.   I didn't read it.

12   Q.   Now, you work in a realty company?

13   A.   No.    Insurance agent.

14   Q.   Oh.    An insurance agency.

15              MR. LEVIN:   Okay.   All right.    I have no further

16   questions.    Thanks.

17              THE COURT:   Is there any redirect?

18              MR. O'BYRNE:    Just one question, Your Honor.

19                             REDIRECT EXAMINATION

20   BY MR. O'BYRNE:

21   Q.   Ms. Boada, did you prepare this document?

22   A.   Did I prepare it?

23   Q.   Yes.

24   A.   No, I did not.     I signed it.

25   Q.   Do you know who prepared it?
                                                                                34
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 34 of 75
                         BOADA - REDIRECT / O'BYRNE

1    A.   No, I do not.

2    Q.   Thank you.

3              MR. O'BYRNE:    No further questions.

4              THE COURT:    All right.    Thank you.

5              COURT SECURITY OFFICER:      Watch your step.

6              THE WITNESS:    No problem.

7              THE COURT:    Is that it?

8              MR. O'BYRNE:    That's it for the deed, Your Honor.

9              THE COURT:    All right.    Were you going to call anybody

10   on the other issue or -- or not?

11             MR. O'BYRNE:    Yes.   Yes, Your Honor.     I have ICE

12   Special Agent Giorgio Garcia here to speak as to the

13   defendant's immigration status, if that's necessary.

14             MR. LEVIN:    Judge, we're stipulating that -- at least

15   from our perspective, that he -- you're talking about whether

16   or not he's the subject of removal?

17             MR. O'BYRNE:    Well --

18             MR. LEVIN:    What's the issue?

19             MR. O'BYRNE:    -- Agent Giorgio Garcia is going to

20   testify that this -- the defendant is not a U.S. citizen and

21   that he's gone through removal proceedings, including the Board

22   of Immigration Appeals.

23             MR. LEVIN:    That -- we'll stipulate that that's what

24   this witness would say.

25             THE COURT:    That he's not a citizen?
                                                                                35
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 35 of 75


1              MR. LEVIN:    That he's not a citizen.      That's what the

2    witness would say.

3              THE COURT:    Subject to removal?

4              MR. LEVIN:    Correct.

5              MR. O'BYRNE:    That's fine, Your Honor.

6              THE COURT:    All right.    And so that concludes your

7    witnesses?

8              MR. O'BYRNE:    Yes, Your Honor.

9              THE COURT:    All right.    Do you want to make argument

10   on this point, Mr. Levin?

11             MR. LEVIN:    Yes, Your Honor.

12        Your Honor, with regard to this issue about whether he's a

13   citizen or not, the Government is asking this Court to enhance

14   his sentence by two levels for obstruction of justice.

15        Now, in Mr. Vazquez's mind, in his mind, he felt that he

16   was a citizen based on the fact that he had derived citizenship

17   from his parents.    I provided to Probation a card which

18   reflects that he is a naturalized United States citizen.            That

19   is what he believed.

20        And he did not tell the probation officer that he was born

21   in Chicago.   He told her he was raised in Chicago.        He's told

22   everybody other than her that he's been born -- that he was

23   born in Havana.    He told that to Magistrate McAliley.        He

24   told -- he told that probably to Your Honor when he started

25   plea colloquies with you.      He told Pretrial Services that.
                                                                                36
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 36 of 75


1         So now to make this an issue because he said to the

2    probation officer that he was raised in Chicago or born in

3    Chicago -- I mean, he knows that he was born in Havana.          But he

4    believed, based on the naturalization, based on derivative

5    citizenship from his parents, which I believe was the law back

6    in the day, that he, in his mind, was a United States citizen.

7         And that's really what I believe should control the

8    Court's determination, not this sideshow and these smoke and

9    mirrors that the Government is really throwing up on this

10   issue, which frankly I don't believe is even relevant to these

11   proceedings.

12        I mean, he came in.     He pled guilty after three tries.        He

13   returned a check for $175,000.       He's accepted responsibility.

14   They want to enhance him for this little -- what I consider to

15   be trivial.    Maybe it's not.    Maybe I'm wrong.     But where he's

16   born -- and, you know, he's -- he's saying to the Court he's

17   from Havana.    He said to this young lady that he's from Havana,

18   even though she heard "Chicago."

19        And it's really much, if you will, to do about nothing.

20   It shouldn't be considered in terms of calculating his

21   guideline.

22             THE DEFENDANT:    I gave Mr. O'Byrne my word that I

23   would come in.    I came in myself.     They didn't arrest me.

24             THE COURT:    All right.    What's the -- what's the

25   Government's view of this?
                                                                                37
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 37 of 75


1              MR. O'BYRNE:    Your Honor --

2              THE COURT:    Now, what -- is there -- I mean, the

3    probation officer thinks he said "Chicago."        It's possible that

4    was a mistake between "raised" or "born."        I could accept how

5    that could happen.

6         He says here he was born in Cuba before McAliley.          I don't

7    remember what he told me frankly.       I guess we can go back and

8    look at the transcript, but I don't remember that.         Is there a

9    Pretrial Services report?      What did he tell them?

10             MR. O'BYRNE:    Yes, Your Honor.     I think Probation can

11   speak to this if they have a copy.

12        But when he was initially interviewed, I believe he said

13   that he was an American citizen in March at his Pretrial

14   Services interview prior to his initial appearance.          But that

15   Pretrial Services report also noted that he had -- I can't

16   remember the specifics, but I think it was an order of removal

17   for a warrant of deportation or something along those lines in

18   the initial Pretrial Services report at the detention hearing.

19             THE COURT:    All right.    Why does it make a difference

20   for the -- in terms of the obstruction here?        I can -- assuming

21   we credit his statement, he's just confused about what his

22   status is.

23        He was born in Cuba, thinks he might have had some sort of

24   perceived -- some sort of citizenship from his parents.          I

25   guess you would think someone would remember an order of
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1    removal if that was -- if he attended these immigration

2    consequences -- immigration hearings.

3         But why -- tell me why it makes a difference, why he

4    should be enhanced for obstruction on this issue.

5               MR. O'BYRNE:   Well, Your Honor, it comes back to

6    what's material for the Court, and I think there were a couple

7    situations here where it was material.

8         The first was with respect to the bond he got.          When he

9    said he was an American citizen, you know, that is a factor the

10   magistrate would consider favorable in terms of not being a

11   risk of flight.

12        And then when we go forward with the sentencing, there's a

13   lot of differences as to whether or not somebody is an American

14   citizen or not.    You know, if somebody is not an American

15   citizen, they'll usually be deported and removed from the

16   country.   If they're not an American citizen, they're not

17   eligible for RDAP and other programs like that.

18              THE COURT:   I'm not going to enhance for that reason.

19   Particularly in South Florida, I see a lot of cases where

20   people are uncertain or think they have some sort of derived

21   citizenship.    Then they probably don't.      Sometimes they do.

22   Sometimes they don't.

23        I've had cases getting to the very end where the lawyers

24   for the defendant are still trying to, I guess, show that

25   someone has some type of legal status.        Here, you have the
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1    additional issue that apparently he went through these

2    proceedings, and there was an order of removal.

3         And so it's hard for me to understand confusion of that

4    type, and I have -- I'm having a hard time often following the

5    statements Mr. Vazquez makes, but I don't think this is a basis

6    for obstruction.

7         But -- but, Mr. Levin, what about the other one?          I mean,

8    that seems likely -- you may have tried to fix it after the

9    fact, but it looks to me like he's pretty flat-out trying to

10   transfer property to avoid the restriction against encumbrance,

11   and one of the reasons for that is to make sure the asset is

12   there for the Government to get payment for this money he

13   stole.

14        And so apparently he also signed the fellow's name that

15   was -- it was being transferred to.       The notary was --

16   "careless" would be a kind word for it, but he basically

17   manufactured a document to -- and backdated it to try to

18   transfer property in direct defiance of the pretrial order.

19        Why is that not --

20             MR. LEVIN:    I see -- I see the Court's point on this.

21        I will only say that Mr. Estevez, who told you that he was

22   a lifelong friend, that he had had these types of conversations

23   with Mr. Vazquez over the years, might have had a conversation

24   with him in 2019 about him transferring his property.          These

25   documents were obviously not drafted by Greenberg Traurig, if
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1    you will, or any of our other fine law firms in the world.

2    Mr. Vazquez drafted this document.

3           Why he didn't change the date on it is a mystery, but the

4    bottom line is it doesn't matter what the date on the document

5    is.    It's the date it's filed.     So there was no way he was

6    going to get around that.      I mean, he filed it in July of 2021,

7    and the document says '19.      Well, that's fine, but legally it

8    doesn't come into effect until the date it's filed, 2021.

9           So what I believe happened here is that this is something

10   he had been planning on doing or thinking about doing for

11   years.    And, you know, Estevez finally said, "Okay.        Fine.

12   Yeah.    All right.   I'll do it."     And then they had a

13   conversation about transferring it back, and he said, "Yes, you

14   know, I want to take it back."

15          Now, yes, did he absolutely violate a bond condition?         He

16   did.    All right.    Does it rise to the level of obstruction?       I

17   don't know because I don't think it's material to these

18   proceedings, and I think that's what the commentary says with

19   regard to the guidelines.      It's got to be material to these

20   proceedings.

21              THE COURT:    Well --

22              MR. LEVIN:    I understand.

23              THE COURT:    -- I'm going to overrule against you on

24   that.

25              MR. LEVIN:    No problem.    Okay.
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1               THE COURT:   I think that this is obstruction.       He --

2               MR. LEVIN:   Yes.

3               THE COURT:   -- basically backdated a deed to try to

4    avoid a restriction against encumbering assets that was part of

5    his bond.

6           And so -- and I think the reason he did it was to -- as he

7    said, he was -- thought he was -- he had legal problems and was

8    going to jail, and he wanted to get the property out of his

9    name and didn't -- apparently, he didn't want it to go to his

10   son.    It doesn't look like he wanted it to go to the Government

11   to pay back the $900,000.      So I think obstruction does apply.

12          I think those are the rulings on the objections, which

13   leaves us with a Level 21, criminal history category of I.           The

14   guidelines are 37 to 46 months.

15          So let me hear your recommendations, starting with the

16   Government.

17              MR. O'BYRNE:   Just a second, Your Honor.

18          You said Level 21?

19              THE COURT:   Yes.   I gave him two levels for

20   acceptance, took away the enhancement for sophisticated means,

21   applied the enhancement for obstruction.

22              MR. O'BYRNE:   Your Honor, I think you hit the nail on

23   the head from the beginning.      This is a -- this is a tough one.

24   This defendant has done everything he can to unaccept

25   responsibility after he pled guilty, but ultimately he did
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1    accept responsibility and did plead guilty to it.

2         But he has, you know, backdated this deed.         He has been

3    very loose with the -- regarding his immigration status in

4    multiple proceedings.     He's -- you know, even today, he filed

5    two motions to withdraw his guilty plea.

6         So with all of that, I thought -- you know, I think that,

7    you know, the real thing that he has going for him is the fact

8    that he gave up the check and he pled guilty, which is the

9    acceptance.

10        In this case, since he's already gotten credit for that, I

11   think I would recommend a sentence at the high end of the

12   guidelines, which you said -- because the acceptance has

13   already been factored into your calculation by going down to a

14   Level 21 and not remaining at the Level 25, which I believe was

15   the original calculation.

16        So with that, I think I'd recommend a high-end sentence.

17   I don't have the calculation in front of me but the high end of

18   a Level 21 with a criminal history category of I.

19        And the other thing I'll throw in there, Your Honor, is if

20   this defendant -- you know, he didn't have a lot of scorable

21   criminal history, but he has a lengthy criminal history from

22   years ago, and it's for a lot of different things, a lot of

23   credit card fraud.     He had a huge narcotics-trafficking case.

24        This is somebody who, every couple years, comes back in

25   front of the criminal justice system and has other issues.           And
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1    this time, it was PPP fraud.      And this time, he was caught with

2    it in nearly a million dollars that he defrauded the Government

3    of because he was trying for a program that was designed to

4    help people in a financial crisis.

5         So for all those reasons, I think that a high-end sentence

6    is appropriate.

7              THE COURT:    All right.    Thank you.

8         Mr. Levin?

9              MR. LEVIN:    Your Honor, would you hear from my client

10   before I address the Court?

11             THE COURT:    I usually give him last word.      If you want

12   to -- if you'd prefer that, I'll hear from him first.

13             MR. LEVIN:    Okay.

14             THE COURT:    Usually, I hear from the defendant last.

15        You can keep your seat.

16             THE CLERK:    Keep --

17             THE COURT:    Just use the microphone.

18             THE DEFENDANT:    First of all, Your Honor, I want to

19   thank you for the opportunity to come before you again.          I

20   promised you that I'd be here, and I promised the --

21   Agent Donies that I would walk in and face the

22   responsibilities, as I did to Mr. O'Byrne.

23        I'd like to clear up a few things.        That so-called

24   document -- I've been in terrible health since my mother died.

25   I lost my mother.    I'm an only child.     I lost my family.     She's
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1    here with me in court right now today because I don't know

2    what's going to happen to me.      You know, I don't want to

3    abandon my mother.     She's here with me right now.

4           I never did anything with bad intentions.       Oscar

5    Estevez -- if anything would be -- to happen to him, I'll take

6    responsibility for that time and do that time, too.          He's my

7    best friend since I'm ten years old.       He lost his business.       He

8    lost his license.    He was duped by a best friend, lost his

9    relationship with his mother, and he's still caring for a

10   96-year-old father.

11          He's got my utmost respect.     Not only would I give him my

12   property, I would give him my life and my freedom.         So that's

13   why I put it in his name.      I tried to give it to my son back in

14   2019.    I -- he was going through marital situations.         And quite

15   frankly, the divorce with my -- with my ex-wife wasn't a good

16   one.    I was about to lose my life.

17          I ended up -- in fact, I'll show this to you.       I'm cut up

18   and down here with four operations.       He needs to see this.      I

19   believe in -- I believe in making mistakes, and I -- people

20   have to believe in God.     I don't care what anybody says,

21   Your Honor.    I believe in the judge.     I know he's a fair man.

22   I know people that have come before him before, and he's going

23   to do us right.

24          The only reason I did that -- Number 1, my private

25   attorney stated a bunch of times that the only condition that I
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1    signed to was the property that was encumbered or -- on the

2    bond, which is not my property.       It was a property -- if you

3    know the bond, it was not my -- that -- that property was not

4    on the bond.    I didn't -- it was not a condition.

5         Maybe -- Fleites, my previous attorney, told me there's no

6    problem.    He says, "As a matter of fact, you can even sell it,"

7    which I didn't.    I gave it to my best friend because he's got

8    nothing, and he's still taking care of his father penniless and

9    living with little scraps that he gets here and there.          And

10   I've gone through -- to want to help him however I can, and he

11   wouldn't even accept my help.

12        Okay.    And I think it's fair to leave -- that property has

13   been ours since 1985.     Nothing that had to do with this loan

14   has to do with that property, absolutely nothing.         Nothing, not

15   one light bulb in that apartment, was done with that property.

16        As far as the deed is concerned, the paperwork, the

17   Government -- and Mr. Donies there, who will attest to -- who's

18   a decent human being as well -- went into the apartment, which

19   he knows is unlivable.     It basically was -- was used as a -- as

20   a -- as a storage unit.     He knows it was full of dust, dirt,

21   mildew.    I didn't even live there.

22        Decent human being, went in there, got what the Government

23   authorized him to get, left a bunch of my mother's stuff,

24   jewelry, lifelong, as Mr. O'Byrne calls it, trinkets, which --

25   which -- on a phone call, I had to listen to him say, "No.
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1    Don't worry.    There's no problem with the property.        I'm not

2    going to go after Vazquez's mother's trinkets."         And I had to

3    listen to a humiliation and making fun of a dead person who's

4    never in her life had a speeding ticket in this country.

5         I was raised in Chicago until I was ten years old.          I

6    provided my attorney with addresses, schools.         I went to Saint

7    Theresa.   I went to Trumbull.     I showed him our property.        I

8    Googled where I grew up.     I came here when I was ten years old.

9    My father became a citizen of this country in 1976.

10        When I was 12 years old, he was provided, as was

11   Mr. O'Byrne, with the law -- the statute of the United States

12   Code stating that a son of a U.S. citizen derives citizenship

13   if he's under the age of 18.      I lived with my father.      I went

14   to Kinloch, where -- Mr. Estevez can attest to -- we went to

15   Kinloch Park Junior High together in 1976.

16        I provided my attorney -- I believe I might have provided

17   Mr. O'Byrne -- I'm not going to lie.       I don't know whether he

18   has it or not -- with my school ID, with documentation that I

19   lived with my father.     We lived in the same neighborhood.         My

20   father was a citizen.

21        Mr. O'Byrne -- I mean Mr. Levin tried to contact him to

22   get a copy of the certificate to provide this honorable court

23   and yourself and Mr. O'Byrne -- I don't know.         He said he spoke

24   to my dad, but he's an old-school 80-something-year-old, you

25   know, Cuban that's been here all his life, and he's sort of a
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1    little bit intimidated by these court situations.

2         I did not exchange one cent with Mr. Estevez for that

3    property, nor did I do it to hide anything from the Government

4    at all, at all.    I was told -- and I heard a conversation, like

5    I said, from -- with Mr. O'Byrne and Mr. Levin stating that the

6    property had nothing to do with anything.        It's encumbered, and

7    this was not derived from anything having to do with this PPP

8    loan.

9         I've had this property in my name since my mother passed

10   away in 2014, late '15.     Okay?   It was done without any type

11   whatsoever of malice.     I've complied with everything,

12   Your Honor, and this honorable court as long [sic] as

13   Mr. O'Byrne, who I'm very appreciative to because I remember

14   the last time I came to court, something was brought up of

15   being remanded or not.

16        And he acted as my defense attorney and said, "No, Your

17   Honor.   This gentleman is not vaccinated.       He's in bad health.

18   He turned himself in.     He complied."    So he, in essence, has

19   been my defense attorney on occasions in this courtroom, too,

20   as have you.

21        And you believed in me because that day you let me go back

22   home.    You let me try to better my health.      I haven't violated

23   any laws.    I have not done any crimes.      I have not hidden

24   anything whatsoever.     I haven't lied to anybody.

25        Does it make sense to tell 12 people, my probation
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1    officer, Your Honor, Ms. McAliley, the other judge that did the

2    hearing one day -- my probation officer now acted -- not the

3    one from Pretrial, the one that handles my case, Charisse.

4    Everybody, I've told the same story to.

5         I've provided Mr. Levin with the statute that was given to

6    me by three different prominent, high-line immigration

7    attorneys who told me, "Well, we're not going to steal your

8    money because all you need to do is bring this up into a court

9    and" -- you know, "and prove that you derive citizenship.          All

10   you've got to do is come in with your father and show, you

11   know, that he became a citizen before the age of 18."

12        My mother obviously is dead.       I didn't hide anything from

13   Pretrial.   I've been sick.     My computers -- Mr. Donies, on a --

14   on a couple of occasions, has said they're clean, they've been

15   checked from top to bottom, nothing bad, to return them.

16        Due to my health and my situation with transportation and

17   what I'm going through -- I'm on 17 different medicines -- 17,

18   sir -- including Oxycontin, Percocet.       I -- it's a miracle that

19   I'm here.   I'm here today.     You know why?    Because I have

20   self-respect and dignity, and I respect you and the United

21   States and Mr. O'Byrne and everybody in this court because I

22   should be in the hospital.

23        I checked out of a hospital purposely and expedited my

24   release to be here today because they didn't even want to

25   release me because they couldn't provide me with a -- with a
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1    nurse that I needed at home.      They couldn't provide me with

2    oxygen.   They couldn't provide me with anything.        So they

3    wanted me to stay.

4         And to not further, you know, make myself look bad and

5    make you mad and -- which is what my other attorney -- "Oh, you

6    don't want to piss" -- I don't -- sir, I'm here with the utmost

7    respect to you because I know how you are, that you're a good

8    human being.

9         And regardless of what Mr. O'Byrne has said here today,

10   he's a good human being because on one occasion he helped me

11   when he needed to.     And if it wouldn't have been for him, I

12   wouldn't -- I wouldn't have been able to walk in here today and

13   face this Honorable Court.

14        As far as the offense is concerned, it hurts me in my

15   heart to see unindicted co-conspirator -- okay -- Armando Del

16   Portillo -- God knows where -- with $171,000 of the Government,

17   and nothing happened to him.      Nobody wants to hear from me.

18   I've offered my cooperation many times.        I've offered my

19   cooperation.

20        And the Government has said, "Where are the emails?           Where

21   are the text messages?     Where's the" -- "where's your phone?"

22   Yet there's -- they didn't present this Honorable Court with

23   any emails, any -- anything that they're asking me to

24   corroborate and say the truth when they arrested me.

25        Where are the emails and where's the correspondence and
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1    where's all the proof from del Portillo, who they know -- they

2    know that it was him that did the papers, that falsified my

3    signature, that sent them from his house or wherever he sent

4    them from, activated my defunct corporation with his credit

5    card.   They know all of this.

6         And don't please take this as disrespect.         I accept full

7    responsibility for whatever happens.       I'm a man.    And

8    obviously, if I die now when they take me in handcuffs --

9    because I'm not going to be able to make that walk.          I'll die,

10   and I'll take responsibility for everything, for -- and for

11   Mr. Estevez, for whatever this Court wants me to take

12   responsibility for.

13        But I'm not going to sit here and lie like my other

14   attorney wanted me to do, lie and say you did -- I'm not the

15   type to commit anything even remotely close to this, sir.          Yes,

16   I've had problems.     I've had instability.     I had a bad divorce.

17   I haven't been the most intelligent person, but I'm not a bad

18   human being.

19        And I'm not trying to sneak anything under anybody's

20   vision.   I'm not trying to disrespect you.       I'm here today.     I

21   can very easily be in a hospital.       Whether or not I get an

22   arrest warrant or whatever it is, I can very easily be in a

23   hospital.    My blood pressure was 220-something with 150 when I

24   got here walking with my mother down the street, and here I am.

25   Here I am.
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1         Okay.    Regardless of what happens to me, I'm here to face

2    this situation, to face the Government, and to face everything

3    with the utmost respect and dignity.       I understand that what I

4    did is wrong.    I'm deeply shameful, deeply, but I'm not trying

5    to sneak anything here under anybody's eyes or -- or play games

6    with the Government.

7         Mr. -- Mr. Donies knows where my -- where my apartment

8    was, full of nice things.      Not one thing, sir, not one thing,

9    since my mother died in 2015, have I had the heart or the nerve

10   to sell, not one thing.     That's -- everything that she had when

11   she died is still there, and she's got a ton of things, like he

12   says, trinkets.    They're not trinkets.

13        My mother was a law-abiding citizen, worked for Sony and

14   for Universal Music for many years, worked with Julio Iglesias,

15   worked with the biggest stars on the planet.        A lot of

16   memorabilia, a lot of stuff that I could easily sell and turn

17   into money.   And there's not one thing that I've sold since my

18   mother died, and he's a witness right there.

19        So with the utmost respect, I want you to understand that

20   I'm here to accept full responsibility.        I'm in a terrible

21   state of health.    I have hundreds, if not thousands, of papers

22   with all my issues.     My heart is bad.    My heart is supposed to

23   be working at 60 percent, and sometimes it's working from

24   15 percent to up to 45 at the best.       I have hypertension.     I

25   have -- I have problems with my vision.        I have problems with
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1    my head.    I have problems with my digestive system.

2         I won't last a day in a situation like this.         I was there

3    for two days and almost had a heart attack.        I've tried every

4    way to cooperate with what happened.       I wanted to sit down with

5    them since Day 1.

6         Jacob Cohen was the first one that called -- something --

7    queens for a day.    I don't know what the legal term is -- then

8    repeatedly over and over and over and over with Mr. Levin, with

9    Mr. Fleites.    They don't want to have anything to do with the

10   guy who really perpetrated this situation.

11        And I accept responsibility.       Don't think that I'm trying

12   to get away from my responsibility, but why won't they go after

13   Armando del Portillo?     That's why, with the utmost respect to

14   you, sir, I came on a couple occasions to try to plead guilty.

15        And when they read, you know, the statement, I'm not going

16   to sit here and perjure myself under -- under -- under God

17   Almighty and Your Honor and His Honorable Court and say, "Oh,

18   yes, this, this, this, and this" to get this out of the way.

19   I'm here to take my responsibility but with the truth, the

20   truth.

21        The truth is -- what don't they tell you the truth?          Well,

22   the papers -- yeah.     Okay.   From this guy, but yeah, he signed

23   them.    Yeah, it's not this guy's signature, blah, blah, blah,

24   blah, blah, the exact truth, which is what I'm sure you're here

25   to see.    You told me the last time I was here, "Sir, I can't
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1    take your plea."    And you asked them, "What's going on with

2    this guy del Portillo?"

3          Well, guess what?    This guy del Portillo is still in

4    Coconut Grove with his strippers, which I provided proof,

5    shuffling hundred-dollar bills off the back.        Mr. Levin has the

6    videos.    I mean, I don't know.    Did you forward them to him?

7    No?   See what I'm saying?

8          Total proof on the Internet of a guy who did fraud all

9    over the place, yet I'm -- you know, I'm the one here, and I'm

10   here because I gave you my word when you let me go home that I

11   would be here.    I gave Mr. Donies my word.      I gave Mr. O'Byrne

12   my word.

13         And this -- this gentleman has done for me what nobody has

14   done for me in my life, and my best friend is sitting here in

15   court with his 96-year-old father at home -- god knows who's

16   taking care of him -- because of this situation, which -- in

17   reality, you know, it breaks my heart.

18         Again, I can come here and take responsibility for

19   everything except for lying to you and saying, "Oh, you know,

20   blah."    I'm not going to say I'm the smartest person in the

21   room, nor am I going to say that I'm the dumbest.         But I have

22   as big a heart as anybody in this room, and there's a lot of

23   people in this room with great big hearts:        Mr. Levin, O'Byrne,

24   Mr. Donies, who spoke to me with the utmost respect.

25         You, without knowing me, have given me the benefit of the
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1    doubt of going home, of taking care of my health, accepting a

2    plea, walking in here today.

3         You know, I feel bad because what's being said here -- the

4    fact that a paper -- because of a tape, because of this -- that

5    paper was intended to -- because of my health.         It goes to show

6    that what I'm saying is the truth because why would, in 2019, I

7    want to pass that property to my son or anybody if I wanted to

8    be concerned with my health when this situation didn't take

9    part until 2020-something?

10        I have excellent credit aside from all the trivial stuff

11   that, oh, I'm a bad guy, whatever.       I have excellent credit.      I

12   don't owe anybody anything.      I'm a decent human being.      I've

13   worked, served for many, many years with the most prominent,

14   upstanding, decent professional athletes.        I don't know if you

15   provided -- did you provide anybody, you know, my background?

16        Nobody knows my background.       With the most -- I've

17   represented Yasiel Puig.     I've represented Yoenis Céspedes.

18   I've represented every professional Cuban boxer.         I've never in

19   my life had one problem having to do with fraud or theft or

20   anything with all the people that I've worked with.

21        So, you know, I feel terrible about what's happened, and I

22   respectfully request that Your Honor take into consideration

23   everything that is going on here and what I'm going through and

24   please take into consideration my health because I won't last a

25   week incarcerated.
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1           I'll be willing to work with the Government in every

2    possible way.    I'm willing to do whatever to pay this back.         If

3    I'm given an opportunity to work or be -- or take double the

4    time that I would be given if I was to be arrested in my house,

5    where I could have my proper attention and not be a burden on

6    the Government, to have all these doctors and all these -- and

7    have to send me to some prison with a hospital and a bunch of

8    medicines and be even a bigger expenditure.

9           Because I'm not going anywhere, sir.      If I was going to

10   leave, I wouldn't have gone there and violently -- voluntarily

11   turned myself in.    I wouldn't be here today.      I'm not going

12   anywhere because, like I said, three prominent attorneys told

13   me, "We don't want to steal your money because all you need to

14   do is file an affidavit from your father, get the school

15   records.   And with this law, you're an American citizen."

16          Why would I come in here and lie about something that's so

17   black and white?    It's not even a gray area.      You're either

18   here or you're not.     Your father is either a citizen or he's

19   not.   You either became a derived citizen before such age or

20   you didn't.

21          I don't want to -- I don't want to further bury myself by

22   saying, well, one or the other.       I'm explaining what I've been

23   told because I was going to hire an attorney to come in here

24   today, and I've been really sick to the point where my heart

25   almost blew up the other day.      I had to spend eight days in the
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1    hospital.    They didn't want to release me.      They released me

2    with a home nurse.

3           And they told me, "We're not going to steal your money.

4    Just bring up the law.     Have your attorney bring it to the

5    attention, and, you know, your father" -- Mr. Levin spoke to

6    him.    I don't know exactly where that -- where -- but in

7    reality, I was going to pass the property to my son.          He was

8    going through divorces.

9           And Mr. Donies has my computers.     I didn't have -- it was

10   done with no bad intentions, sir.       And regardless of the

11   ruling, which I respect totally and bow my head to this Court

12   with respect to you, whatever the ruling is, I'll accept

13   responsibility.    But I want you to know deep down inside that I

14   didn't do that with any malice.

15          Why would I do a paper from X amount of days or whatever,

16   you know, year where you go and a clock stamps it, you know,

17   3:30, whatever the time, January, whatever the case may be?

18   Nothing here has been done with bad intentions by my part

19   except, you know, being a little off the wall with all the

20   medications I'm taking, the situation I face.

21          My mother was beat up at Doctors Hospital, dying of

22   cancer, blew up her face.      If I was a money guy and if I was

23   worried about money or -- or millions or stealing money, I

24   would have sued Doctors Hospital, where my mother, Isel Ferro,

25   was beat up.    I didn't even need to put a lawsuit.       I was
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1    asleep next to my mother's side on the floor for a year until

2    she passed away and didn't even do a lawsuit.

3         So I want this Court and Your Honor to know me well

4    because I should have been better prepared.        I should have gone

5    outside the realms of legality and prepared a huge background

6    of myself so you can judge me accordingly.

7         And through my sickness, my desperation, everything that

8    I've been through, what I've been through back and forth, I

9    always expected from Mr. O'Byrne to say, "Yeah, come on in.           We

10   want to hear what's going on."

11        If this deed happened, why is Mr. del Portillo sitting in

12   Coconut Grove as an unindicted co-conspirator and I'm here

13   today before this Honorable Court?       It's all I'm saying.     I

14   would please request that you do whatever is right by you, and

15   I'll accept responsibility and give you an opportunity to

16   redeem myself.

17        If -- if possible, send me to -- you know, to house arrest

18   or something or give me an opportunity to face my appointments.

19   I have a list here of seven appointments that I need to go to

20   that are real.    This is not concocted.      I didn't fake these

21   documents.   I didn't pay Doctors Hospital about this.         I'm in

22   serious health -- bad.     I don't know if you want to show the

23   honorable judge.

24        You know, I need some time to get my life together, to

25   bury my mother, take her to some place where -- where I can
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1    give her a place with dignity, to rest in peace, for whatever

2    happens to me.    I don't know nothing.

3         And now, on top of this, my best friend in life is in this

4    situation, too.    I can't even talk to him because I didn't even

5    know.   I thought something had happened to him because we

6    talked many times a day, and all of a sudden, I called him and

7    called him and called him, and we never had a chance to talk.

8         Regardless of what happened, I request that you give me at

9    least the opportunity.     I give you my word if I'm not back here

10   to turn myself in to wherever you send me, if you decide to

11   send me to a prison, you can give me ten times, ten times --

12   I'll sign a paper right now -- ten times whatever you're going

13   to give me.

14        If you're going to give me whatever months, I'll sign a

15   paper right now.    You can give me ten times, and I'll approve

16   it, but give me an opportunity to get my life in order and my

17   health.   I'm not vaccinated.     I've been told by some people

18   that I -- that I run big risks, because of all my health

19   issues, to a reaction that may kill me.        Even if I -- the

20   vaccine may kill me, or -- or the virus may kill me.

21        I haven't even left my house, sir, since you put me --

22   since you put me and Mr. O'Byrne and Mr. Donies -- since they

23   put me in my house, sir, I haven't even left.         I've been in

24   there trying to do what I can, trying -- trying to fix my

25   situation, trying to get this process to, you know, gently
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1    pass.    I haven't been out.    I haven't been doing anything.

2           I've been just laying low, doing my classes that you sent

3    me to.    I did them.   I did all the classes.     I graduated

4    successfully from -- from the substance abuse classes.          I've

5    done all the urine tests asked for me.        All of them have

6    passed.

7           I've moved within an hour and a half from when they told

8    me to move back to my residence, which was full of dust,

9    mildew, dirt.    You can ask Mr. Donies.      It was unlivable, yet I

10   respected the court order, and I respect you and the Court and

11   the United States and everybody here to the utmost.

12          I just plead with you to do the right thing and let me --

13   if it means that I'm going to have to go to jail, give me at

14   least 90 days or something to get my situation in order, take

15   my mother somewhere and put her in a big dignified place, not

16   leave her alone in an apartment that -- when I -- you know, God

17   knows what's going to happen -- and get my health in order.

18          I'm not asking for anything aside from my health and my

19   mom.    I don't care about monetary things.      I don't care about

20   nothing.    I was told many times that my apartment had nothing

21   to do with it because it wasn't on the bond.

22          It might have been a misunderstanding, whatever the case

23   may be, including the conversations on the speakerphone with

24   Mr. O'Byrne, who said, "No.      We're not going to take his

25   mother's trinkets."     It's encumbered or whatever that means,
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1    that it's got a mortgage, no harm.

2         The minute I found out that this was a situation, it was

3    corrected.   It was corrected because that gentleman sitting in

4    the court back there wouldn't take a grain of sand from the

5    beach from anybody due to his self-respect and his dignity and

6    his heart, and that's my best friend.       And it's only fair.      I'd

7    die in a situation like this.

8         I didn't do it to hide anything from the Government.          He's

9    lost everything he had.     It wasn't derived from anything.       I

10   didn't know the technicalities.       I was told that the only house

11   that couldn't be touched was the house that was used at my

12   bond, which had nothing to do with this.

13        And I'm sorry for going on and on and on and on, but this

14   is the biggest and most scariest and most important day of my

15   life.   And from the recommendations and everybody I've heard

16   speak about you that, for some reason or another, have been in

17   front of you -- whether it's a legal attorney or a defendant,

18   everybody said the same.     "He's a great man, and he's going to

19   do what's right, and he doesn't play games."        And I haven't

20   played not even one game with you, sir.

21        Now, the fact -- the fact that he's against me, getting

22   ready -- or prepared myself for what's coming, talking about

23   remanding, talking about -- come on.       I've been here all my

24   life, sir.   All my life, sir.     I've been in this country since

25   1969, since I was five years old.       I've been here for 52 years.
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1    If anything derived -- you know, if anything, I'll be here 52

2    years without doing any crime against the Government, without

3    being a spy, without doing anything.

4           Where am I going to go?    To Communist Cuba?     I have never

5    even left the country in my life.       In my whole entire life,

6    I've never left this country.      For someone to oppose me getting

7    an opportunity to get my life in order and having a little bit

8    of respect for a person that's going through what I'm going

9    through by myself -- I have nobody.

10          My best friend is sitting there today in a suit.        Do you

11   see anybody else here for me?      I had to walk in here today with

12   my legal papers and my mother and my grandmother because I

13   didn't know what was going to happen.       I mean, I don't know how

14   else to put it.    I trust you blindly to be -- I wouldn't be in

15   front of another -- a better judge because I know that you're

16   going to do the right thing.

17          I respectfully request that opportunity to get my life in

18   order, to get my health in order, to at least -- if I go and

19   got to do whatever, I promise you that I will go.         I can't even

20   go to the bathroom and take care of my own situation.          I can't

21   put on a pair of socks by myself.       This is real.    This is not a

22   lie.   These socks were put on me by someone in my building

23   today because I couldn't even put on a pair of socks or shoes.

24          When I got remanded -- remanded -- or when I turned myself

25   in -- and they said there was a rule at the federal facility
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1    that you have to wear socks.      There was a guard that was nice

2    enough that -- I told him, "Listen, I'm going to have to get in

3    trouble because I can't" -- "I can't bend my leg or bend myself

4    down enough to put on socks."

5         And that guy was nice enough to put on socks for me, which

6    I didn't even take off.     I didn't even take a shower waiting

7    for a bond because I didn't want to break the rules or get on

8    anybody's bad side and try to get out of this situation as best

9    as possible.

10        If there's anything you want to know from me that you feel

11   I haven't told you or anything that needs to be heard or

12   whatever, please ask me because I'm transparent.         I'll be

13   willing to tell you.     I may be a little off the pattern that

14   you're used to hearing people talk because I'm distraught with

15   what's going on.

16             THE COURT:    All right.    Thank you.

17        Mr. Levin, did you have something?

18             MR. LEVIN:    Very briefly, Your Honor.

19        The guidelines are 37 to 46 months.        The Court has to

20   consider all the 3553(a) factors, including the history and

21   characteristics of the defendant.       There's not much more I need

22   to add.

23        I mean, you've seen Mr. Vazquez.       He's definitely a unique

24   individual.    He's definitely not the norm, but he is who he is.

25   He's had a very -- frankly, he's had a very sad life.          I mean,
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1    that's the only way to put it.      He's had a very, very sad life.

2         The closest person in his life was his mom.         She passed

3    away in 2015.    He went off the rails then basically.        And, you

4    know, it's not often you see somebody bringing their loved

5    one's remains to court, but that's also a part of his

6    personality.    But it also shows how deeply he was -- he was

7    hurt by her demise.

8         He definitely needs to pay the penalty for stealing almost

9    a million dollars from the United States Government.          In his

10   heart, it really wasn't his intention initially, which it

11   wasn't.   He got approached by a guy who basically said, "Oh,

12   the Government's giving away money now.        If you have a

13   business, you can apply.     Here's what we'll do.      This is how

14   you do it."

15        And he basically led him down the path until Vazquez

16   realized he was in deep and realized that, you know, "Wait a

17   second.   I think this is really designed for people that

18   actually have real businesses, that are paying salaries."          And

19   then he kind of, like, turned a blind eye to that reality, to

20   that notion.

21        But, you know, he's not -- not well educated.         He's not

22   very bright frankly.     He's obviously got a big personality.

23             THE DEFENDANT:    Big heart.

24             MR. LEVIN:    He's got a big heart.     He doesn't know

25   when to stop talking.
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1          You know, this is a decision that the Court has to make in

2    balancing all the -- all the factors.       Of course, one of them

3    is the 37-to-46-month guideline range.        The other -- the

4    others, of course, are the history and characteristics of this

5    defendant, who suffers from severe mental illness.

6          The Court ordered him for counseling during the pendency

7    of his -- that he's been out on bond.       He's on medication, he's

8    morbidly obese, he's not vaccinated, all of his own doing, mind

9    you, which -- I constantly remind him of that.         Okay?   I've

10   tried to help him as best I can not only as a lawyer but as a

11   person.

12         He means well.    He really does have good intentions, but

13   he just frankly didn't know when to stop here.         He got -- third

14   time was a charm.    He pled guilty.     He's accepted

15   responsibility.

16         He returned a 175,000-dollar check to the Government that

17   was made out to the IRS, which is the first time I'd ever heard

18   of anything like that in any of these types of cases, which I

19   think also might have showed his state of mind with regard to

20   "Well, if I'm getting this money, don't I have to pay tax on

21   it?   IRS?   $175,000?"

22         Your Honor, he's -- he's a very sick person physically,

23   and frankly he's got psychiatric issues.        I don't think jail --

24   I mean, the Court does have to send a message to the community

25   to deter this type of conduct.      I understand that.     But I think
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1    the Court can fashion a sentence that might take into

2    consideration all these issues:       His issues, satisfying the

3    Government, and dispensing justice.

4         And I'm not here to tell the Court what I feel is an

5    appropriate sentence.     I know the Court can decide that

6    himself.

7         Thank you, Your Honor.

8               THE COURT:   All right.    Thank you.

9         All right.    I've considered the statements of all parties,

10   the presentence report, which contains the advisory guidelines,

11   and the statutory factors.      It's the finding of the Court the

12   defendant is not able to pay a fine in addition to the

13   mandatory restitution.

14        I adopt the findings of the presentence investigation

15   report.    However, I did grant a two-level decrease for

16   acceptance and remove the enhancement for sophisticated means,

17   which left an Offense Level 21, Criminal History Category I.

18   The advisory guideline is 37 to 46 months.

19        This was a serious crime.       The loss was $949,531, which is

20   the restitution amount.     This program was meant for -- to --

21   for people with ongoing businesses that needed to pay employees

22   and to keep people employed during the pandemic, and this was a

23   brazen theft.

24        I've also reviewed the criminal history of the defendant.

25   He has a history of not being truthful.        There are a number of
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1    cases going back to when he was a young man for forgery, using

2    false credit cards, using false driver's licenses, theft.

3    There's a case where he claimed to be a police officer, and

4    when the police tried to stop him, he apparently ran over

5    the -- or hit the officer with his car.

6         There are a number of cases that were not scored, which

7    include in -- when he was 20, taking a gun and pointing it at a

8    victim.   There was a case of battery on an elderly person where

9    there was no action.     The history of the defendant belies the

10   fact that -- that he has led a law-abiding life.

11        And for those reasons, it's the judgment of the Court the

12   defendant, Carlos Vazquez, is committed to the Bureau of

13   Prisons for 42 months as to each of Counts 1 and 2, to be

14   served concurrently.     It's ordered the defendant shall pay

15   restitution in the amount of $949,531.25.

16        Upon release --

17             MR. LEVIN:    Your Honor, can I stop you right there?

18   I'm sorry.

19             THE COURT:    Yes.

20             MR. LEVIN:    I think in fairness, the $175,000 that he

21   returned should be --

22             THE COURT:    He'll get a credit for that.

23             MR. LEVIN:    Oh.    He will get a credit for that?

24             THE COURT:    Yeah, but I -- he will -- in fact, the

25   Government's filing says he gets a credit for the -- does it
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1    not?

2               MS. MIRANDA:   Your Honor, I just want to be very clear

3    between -- the sanction between forfeiture and restitution.

4           Shortly before the sentencing, if I may at this point

5    elaborate on forfeiture, the Government filed a motion seeking

6    a forfeiture money judgment in the amount of $921,875.           In

7    addition, the Government seeks the forfeiture of the cashier's

8    check in the amount of $175,957.40.

9           However, the Government is seeking forfeiture of those

10   funds.   In order for those funds to be applied to restitution,

11   the Government must apply for restoration through the Money

12   Laundering and Asset Recovery Section in Washington, DC.          The

13   Attorney General has delegated the authority to restore

14   forfeited funds to the chief of what's commonly --

15              THE COURT:   Well, what's this about?      You want

16   forfeiture rather than the restitution to have priority?          Is

17   that what you're doing?

18              MS. MIRANDA:   So the funds will be forfeited, and

19   then -- although I can't make any promises, the Government is

20   reviewing this to submit a restoration request to MLARS.          So

21   yes, we seek to have the cashier's check forwarded --

22   forfeited -- excuse me -- and --

23              THE COURT:   Well, you said he'd get credit for it.

24              MS. MIRANDA:   He'd get credit against the forfeiture

25   money judgment, as I relayed in my motion.        And then once the
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1    forfeiture process is completed, at that juncture, if the

2    defendant does not have the wherewithal to pay both --

3               THE COURT:   Well, probably either.     So --

4               MS. MIRANDA:   So I --

5               THE COURT:   Other than the check you're getting, I

6    suspect.

7               MS. MIRANDA:   That's most likely.

8         Now, the Government --

9               THE COURT:   What -- apparently, this was some sort of

10   private loan company.

11        So is the -- is the idea that the Government takes the

12   forfeiture first and then the loan company is in line?          Is that

13   what you're doing?

14              MS. MIRANDA:   Yeah.   One of the victims has filed a

15   petition for admission to identify themselves as a victim in

16   the case.   So what happens is the Government forfeits its funds

17   in any substitute assets that it can find.

18        Again, if the defendant does not have the wherewithal to

19   pay both, the line AUSA can then put together a restoration

20   package that is submitted to Washington, DC, and reviewed by

21   the Money Laundering and Asset Recovery Section.         The Attorney

22   General has delegated his authority to the chief of that

23   section to review that.

24        If the restoration is approved, those forfeited funds and

25   assets are then restored for the purpose of the restitution and
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1    paying victims.    However, I cannot bypass the forfeiture

2    process and --

3              THE COURT:    Well, he tried to give you a check.       Was

4    the problem that it was made to the IRS?        Is that the problem

5    with the check?

6              MS. MIRANDA:    That is not the problem, Your Honor.

7    The Government -- to be more specific, the Department of

8    Justice is working with the Internal Revenue Service regarding

9    the forfeiture of those funds.

10        Those funds are not being paid to the IRS for taxes or

11   anything of the sort.     They represent proceeds of the crime,

12   and I am working with IRS to have the funds forfeited,

13   assuming, Your Honor, this Court enters the forfeiture money

14   judgment and also the forfeiture of those funds.

15        We will also review potential substitute assets that the

16   defendant may or may not have, including but not limited to the

17   apartment that's been discussed today.

18        I just want to make clear for the record that just because

19   PPP fraud proceeds did not go into an asset does not mean that

20   the Government does not have the right to pursue that asset as

21   a substitute asset in partial satisfaction of the forfeiture

22   money judgment.

23             THE COURT:    Well, I've done this before where the

24   Government seeks to go forward with restitution often against

25   people who can pay neither.
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1         There was a case where some woman got Social Security

2    proceeds she wasn't entitled to and was trying to give it back,

3    and the Government was trying to get forfeiture and

4    restitution, which seems wrong.

5              MS. MIRANDA:    Well, both forfeiture and restitution

6    are mandatory pursuant to case law and statute, which is set

7    forth in the filing that, admittedly, we filed a few minutes

8    before sentencing.

9              THE COURT:    Well, that's fine, but there ought to be a

10   credit for the money that people pay back.

11             MS. MIRANDA:    And that's why the restoration process

12   exists, but unfortunately -- or perhaps "unfortunately" is the

13   wrong word -- the Attorney General is the one who has the

14   authority to decide on that, and that he has delegated to the

15   Money Laundering and Asset Recovery Section.

16        So in this case, Your Honor, as the line AUSA, I can say

17   that I have begun to review it for a restoration request.          But

18   until the forfeiture process is completed, I cannot submit that

19   package to the Money Laundering and Asset Recovery Section.

20             THE COURT:    All right.    Well, I am going to direct

21   that he get credit for the check he's trying to return back,

22   regardless of what -- I guess the posture of the various

23   agencies.

24        So where should he get the credit, the forfeiture or the

25   restitution?
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1              MS. MIRANDA:    The credit will be on the forfeiture,

2    Your Honor.    And then at the end of the forfeiture process, I

3    am reviewing this file for a restoration request, which means

4    after we are done forfeiting everything and he will receive the

5    credit towards the forfeiture money judgment, I will put

6    together a package that will be sent to the Money Laundering

7    and Asset Recovery Section in Washington, DC.

8         And if they approve that these forfeited funds be applied

9    to the victims in this case for the purpose of restitution,

10   vis-a-vis through that process, Mr. Vazquez will essentially

11   receive a credit because those funds will go back for

12   restitution.

13             THE COURT:    All right.    Well, I'm going to order that

14   restitution be payable in the amount of $949,531.25.

15        However, I also direct that the check for -- how much

16   money, Mr. Levin?

17             MR. LEVIN:    I believe it was about -- it was

18   approximately 175-.

19        Do you know?

20             MS. MIRANDA:    It was $175,957.40.

21             THE COURT:    And 40 cents.

22        I direct that that be applied as a credit to restitution.

23   Upon release from incarceration, the defendant shall pay

24   restitution at the rate of ten percent of monthly gross

25   earnings until such time as that schedule may be altered in the
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1    interest of justice.

2         The Probation Office and U.S. Attorney's Office shall

3    monitor payment of restitution and report any material change

4    in ability to pay.     These payments don't preclude the

5    Government from using any unexpected financial gains, assets,

6    or income of the defendant to satisfy restitution.         Restitution

7    is payable to the Clerk, who will forward it to the victim.

8         Upon release from imprisonment, the defendant shall be

9    placed on supervised release for a term of three years as to

10   Counts 1 and 2, all such terms to run concurrently.          Within 72

11   hours of release, the defendant shall report in person to the

12   Probation Office in the district to which he's released.

13        While on supervised release, the defendant shall comply

14   with mandatory and standard conditions of supervised release,

15   which include not committing any crime, being prohibited from

16   possessing a firearm or other dangerous device.         He shall not

17   unlawfully possess a controlled substance and cooperate in the

18   collection of DNA.

19        The defendant shall also comply with the following special

20   conditions:   Cooperation with Immigration during any removal

21   proceedings, the financial disclosure requirement, no-new-debt

22   restriction, credit card restriction, mental health treatment,

23   substance abuse treatment, and permissible search, as noted in

24   Part F of the presentence report.       The defendant shall also pay

25   a special assessment of $200.
                                                                                73
Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 73 of 75


1         So the total sentence is 42 months' imprisonment, three

2    years' supervised release, $949,531.25 in restitution, and a

3    200-dollar special assessment.       I will enter the order of

4    forfeiture, but I also direct that that credit of $175,957.40

5    be provided with respect to any forfeiture judgment entered

6    with respect to this defendant.

7         When he's trying to turn the money back over, it is -- it

8    would be unfortunate to end up with two obligations of this

9    kind.   The crime was serious, but that behavior is unbecoming

10   of the Government.

11        Mr. Vazquez, you have a right to appeal the sentence

12   imposed -- well, first, now that sentence has been -- been

13   imposed, does the defendant or his counsel object to the

14   Court's findings of fact or the manner in which sentence was

15   pronounced?

16              MR. LEVIN:   None other than those previously

17   articulated.

18              THE COURT:   All right.    Thank you.

19        Mr. Vazquez, you have a right to appeal the sentence

20   imposed.   Any Notice of Appeal must be filed within 14 days.

21   Failure to file a notice within that period would constitute a

22   waiver of your right to appeal.

23        I believe remand is appropriate at this time.         I'm mindful

24   of the health issues of the defendant, but I think there are --

25   continued release is problematic.       I do recommend that the
                                                                                74
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1    Bureau of Prisons take steps to deal with Mr. Vazquez's medical

2    condition.

3           And I wish you well, sir, but I think remand is necessary

4    at this point.      I was tempted and almost did that before.

5    You're right.    The prosecutor stepped forward and argued that I

6    shouldn't do it, and I didn't at that time.        But I'm concerned

7    about aspects of this case and -- and the ability to follow the

8    law.

9           All right.    Thank you all.   Have a good day.

10              THE CLERK:    All rise.

11              COURT SECURITY OFFICER:     All rise.

12                   (Proceedings adjourned at 2:42 p.m.)

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Case 1:21-cr-20231-DMM Document 97 Entered on FLSD Docket 12/22/2021 Page 75 of 75


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3                           CERTIFICATE OF REPORTER

4              I certify that the foregoing is a correct transcript

5    from the record of proceedings in the above-entitled matter.

6

7    DATE:    Monday, December 20, 2021

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11                        /S/ James C. Pence-Aviles

12            James C. Pence-Aviles, RMR, CRR, CSR No. 13059
                            U.S. Court Reporter
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