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Home Court filings U.S. v. Denis Casseus Transcript of Sentencing Hearing (September 15, 2023) — United States v. Denis Casseus

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Transcript of Sentencing Hearing (September 15, 2023) — United States v. Denis Casseus

No. 2:23-cr-00009-KCD-DNF · Doc. 69 · Docket on CourtListener

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    1                  IN THE UNITED STATES DISTRICT COURT
                       FOR THE MIDDLE DISTRICT OF FLORIDA
    2                          FORT MYERS DIVISION

    3              TRANSCRIPT OF SENTENCING HEARING
        __________________________________________________________
    4
        UNITED STATES OF AMERICA,            )
    5                                        )
                       Plaintiff,            )
    6                                        )
                 vs.                         )   2:23-cr-9 and
    7                                        )   2:23-cr-3
                                     )
    8   DENIS CASSEUS AND ISMAELLE   )
        MANUEL,                      )
    9                                )
                  Defendants.        )
   10   __________________________________________________________

   11

   12
                   BEFORE THE HONORABLE THOMAS P. BARBER
   13               UNITED STATES DISTRICT COURT JUDGE
                    FOR THE MIDDLE DISTRICT OF FLORIDA
   14

   15                        2110 First Street North
                            Fort Myers, Florida 33901
   16                   1:31, Friday, September 15, 2023

   17

   18                        Vonni R. Bray, RDR, CRR
                         Federal Official Court Reporter
   19                        2110 First Street North
                            Fort Myers, Florida 33901
   20                     vonni_bray@flmd.uscourts.gov
                                  (239) 461-2033
   21

   22

   23          Proceedings recorded by machine shorthand
         Transcript produced by computer-assisted transcription
   24

   25
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    1                               APPEARANCES

    2   FOR PLAINTIFF:

    3                Ms. Yolande G. Viacava
                     Assistant U.S. Attorney
    4                2110 First Street
                     Room 3-137
    5                Ft. Myers, FL 33901

    6

    7   FOR DEFENDANTS:

    8                Ms. Zeljka Bozanic
                     Bozanic Law
    9                2847 Hollywood Blvd.
                     Hollywood, FL 33020
   10

   11

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   13

   14

   15

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   25
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    1                        (Court called to order at 1:31 PM)

    2                THE COURT:      Good afternoon, everybody.

    3   Welcome to court.

    4                First case up, United States versus -- I

    5   might do them both together.            We'll talk about that in

    6   a second.

    7                We've got Ismaelle Manuel and Denis Casseus,

    8   Case No. 23-cr-3 and 23-cr-9.             Go ahead and introduce

    9   yourselves, starting with the prosecutor, please.

   10                MS. VIACAVA:      Good afternoon.          Yolande

   11   Viacava for the Government.            With me at counsel table

   12   is United States Secret Service Special Agent Brian

   13   Kirby.

   14                THE COURT:      Yeah.     It's better to sit down

   15   and just talk into the mic.

   16                Come on down.      I recognize him.          That's him;

   17   right?

   18                MS. BOZANIC:      Yes.

   19                THE COURT:      We're going to do both your cases

   20   at the same time.        Sort of.

   21                For the record, in the courtroom, we've got

   22   both defendants on these cases.              Ms. Manuel and Mr. --

   23   is it Casseus?

   24                DEFENDANT CASSEUS:         Casseus.

   25                MS. BOZANIC:      Casseus.
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    1                THE COURT:     Okay.     Go ahead and introduce

    2   yourself.

    3                MS. BOZANIC:     I'm so used to standing up,

    4   Your Honor.     Zeljka Bozanic on behalf of Ismaelle

    5   Manuel and Denis Casseus.

    6                THE COURT:     Both of you raise your right hand

    7   for me.

    8                (Defendants sworn).

    9                THE COURT:     Good.     They have been both been

   10   sworn.     Some of this we'll do together.             Some of it

   11   we'll spread out.       They have the same lawyer.             They're

   12   charged with the same type of crime, and they are

   13   together how many years?           Have kids together?         I mean,

   14   they function like a married couple, although they've

   15   never been married.       So we'll try to do this together.

   16                So we got PPP fraud going on here.              They pled

   17   guilty; we're at the sentencing.             Looks like both

   18   pled -- they had the same charges or different charges?

   19                MS. VIACAVA:     Your Honor, they are different

   20   charges.     They are both -- submitted separate PPP --

   21   sorry.     They both submitted separate PPP applications.

   22   In addition, when they entered their plea, Defendant

   23   Mr. Casseus, he also entered a plea involving illegal

   24   money -- a monetary transaction.

   25                THE COURT:     All right.       So Ms. Manuel pled
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    1   guilty on May 23rd to Counts 1 through 3 of an

    2   indictment charging her with bank fraud, in violation

    3   of Title 18, United States Code, Section 1344 and 2.                  I

    4   accepted a guilty plea and adjudicated her guilty.

    5                And Mr. Casseus -- I'm going to mess it up;

    6   I'm sorry -- he pled guilty to Counts 1 and 2 of an

    7   indictment charging him with bank fraud, in violation

    8   of Title 18, United States Code, Section 1344 and 2,

    9   and Count 5 of an indictment charging him with illegal

   10   monetary transactions, in violation of Title 18, United

   11   States Code, Sections 1957 and 2.

   12                First thing we need to do in a sentencing

   13   case in federal court is address the sentencing

   14   guidelines, and that's done with the presentence

   15   report.

   16                So we'll start with the prosecutor.              Have you

   17   had the opportunity to read and discuss the presentence

   18   reports -- plural -- and do you have any objections to

   19   the factual accuracy or guideline calculations?

   20                MS. VIACAVA:     The Government has reviewed

   21   both presentence reports, and the Government has no

   22   objections to guideline calculation.

   23                THE COURT:     All right.      Defense, one question

   24   at a time for one defendant at a time.

   25                Start with Ms. Manuel; have you had the
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    1   opportunity to read and discuss her presentence report

    2   with her?

    3                MS. BOZANIC:     Yes, Your Honor.

    4                THE COURT:     And how about Mr. Casseus?

    5                MS. BOZANIC:     Yes, Your Honor.

    6                THE COURT:     Okay.     With regard to

    7   Ms. Manuel -- Ms. Manuel, you speak English okay;

    8   right?

    9                DEFENDANT MANUEL:        Yes, Your Honor.

   10                THE COURT:     So this presentence report is a

   11   long document.       It tells me everything about you you

   12   could even imagine.       Tells me, you know, you've got

   13   kids.     It tells me you were depressed during pregnancy.

   14   You name it, it tells me all this stuff.

   15                Have you had a chance to read that yourself?

   16                DEFENDANT MANUEL:        Yes, Your Honor.

   17                THE COURT:     And you went over it with your

   18   lawyer?

   19                DEFENDANT MANUEL:        Yes, Your Honor.

   20                THE COURT:     Questions for her or me about

   21   anything in that document?

   22                DEFENDANT MANUEL:        No, Your Honor.

   23                THE COURT:     Mr. Casseus, same thing.            This

   24   presentence report -- you can read English okay; right?

   25                DEFENDANT CASSEUS:        Yes, Your Honor.
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    1                THE COURT:     Did you read it?

    2                DEFENDANT CASSEUS:       Yes, Your Honor.

    3                THE COURT:     Any questions for your lawyer or

    4   me about anything in the presentence report?

    5                DEFENDANT CASSEUS:       No, Your Honor.

    6                THE COURT:     All right.      So now, Defense

    7   Counsel, do you have any objections to the guideline

    8   calculations on either client?

    9                MS. BOZANIC:     Yes, Your Honor.         I did file

   10   written objections; there are two different objections.

   11                THE COURT:     Yeah, I know.       But I'm saying --

   12   go ahead and talk to me about those.

   13                MS. BOZANIC:     Okay.     So, Judge, one, it's an

   14   objection, but I understand that the new guidelines

   15   haven't been passed, and it's going to be effective in

   16   November.     And I did not file a motion to continue;

   17   thought about it, but I didn't.

   18                I can say that in the Southern District of

   19   Florida, the judges are normally giving variances.                  But

   20   the judges are granting variances with the

   21   understanding, and letting the defendants know on the

   22   record, that they are not to come back to file a

   23   motion.

   24                So while this poses an objection, I guess, it

   25   could be treated as a variance request in each one of
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    1   their cases, for both Ms. Manuel and Mr. Casseus.

    2                THE COURT:     I'm going to ask you what

    3   sentence you think they deserve here at some point.

    4   You can build that in to what you're saying.                I kind of

    5   do the same thing.        But -- sort of informally and

    6   generally.     Just give people the sentence.

    7                To me, the sentencing guidelines are

    8   advisory, because that's what the law tells us.                 So if

    9   they are going to change it next month, that just means

   10   the advisory piece is different.            Might not affect my

   11   sentence.     So I can hear all of that.

   12                Do you have other objections besides that?

   13                MS. BOZANIC:     Yes, Your Honor.         The other

   14   objection was two-level upward adjustment pursuant to a

   15   Robert T. Stafford Major Disaster Reparation.                 Pursuant

   16   to United States Sentencing Guidelines 2B1.1(b)(12),

   17   the provision added two additional levels in both

   18   cases.    And they are arguing that this fraud, or the

   19   offense involved conduct, is described in 18 U.S.C.

   20   1040.

   21                My argument -- I mean, I did try to look up

   22   case law.     Obviously, there is nothing on this point.

   23   I can tell you that I probably had between 5 and 10 of

   24   these cases in the Southern District, where I practice

   25   mostly.     I've never seen it before, and I was a little
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    1   surprised to see this.        I spoke to the Government.

    2   They have seen it before; I haven't.

    3                So my argument is, Judge, that under the

    4   Robert T. Stafford Disaster Relief -- the PPP loan

    5   wasn't passed as a result of Robert T. Stafford

    6   Disaster Relief and Emergency Assistance.                It was

    7   passed -- there are two different acts that were

    8   passed.

    9                A PPP loan was passed under the CARES Act.

   10   The statute 18 U.S.C. 1040 states that anybody who

   11   makes any material false, fictitious, or fraudulent

   12   statement or representation with Robert T. Stafford

   13   Disaster Relief and Emergency Assistance, and it talks

   14   about receiving a benefit.          I've looked at other cases

   15   in the past, what this benefit meant.                I found that

   16   benefit usually represented, for example, if you have a

   17   major flood and there's a benefit where the Government

   18   gives money to the states to give people to fix their

   19   house.    It's something as a benefit.              Something that's

   20   not to be repaid.       It's pretty much a gift.

   21                I don't think that's what's meant -- I don't

   22   think it's similar to a PPP loan.             First of all, PPP

   23   loan is not a gift.       I would argue it's not a benefit.

   24                THE COURT:     It's a loan -- quote, loan you

   25   don't have to pay back.        We'd all like to get those;
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    1    right?

    2                 MS. BOZANIC:     Well, Judge, first of all, when

    3    PPP loans first came out, nobody knew that you were not

    4    going to have to pay them back.           Sometime later, the

    5    Government came out with the guideline that if your

    6    loan is under $150,000, you don't have to pay it back.

    7                 But at the time people were taking these

    8    loans out, I don't think there was something set in

    9    stone that you don't have to pay it back.               As a matter

   10    of fact, many businesses didn't know there was going to

   11    be any threshold of 150,000.          There were business that

   12    took out loans for 160- and couldn't ask for

   13    forgiveness.

   14                 So I don't think this was a benefit.              I think

   15    that this application was -- I don't think it applies

   16    in this case.       President Biden -- well, the president;

   17    I'm not sure which president.          Anyway, the president at

   18    the time passed the CARES Act; I think that was in

   19    March.     They invoked the emergency in February, the

   20    Robert T. Stafford Disaster Relief Emergency, in

   21    February.     And the actual loans, the PPP and EIDL

   22    loans, were authorized in March by the CARES Act.

   23                 THE COURT:     Okay.    Interesting conversation

   24    on this.     They do things differently.           Just driving

   25    across the Alligator Alley, it's a very different
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    1    world.    I have many friends down there, grew up in

    2    Fort Lauderdale.      So it's sort of home to me in some

    3    ways, although I haven't lived there in a long time.

    4                But in any event, what do you think about

    5    this, Madam Probation Officer?

    6                PROBATION OFFICER:        Your Honor, we've looked

    7    into -- we've all had this discussion.              And at this

    8    point, we believe because -- that the loan -- that it

    9    was, like you said, a gift at some point.               They made it

   10    where you wouldn't have to pay it back.               And we feel

   11    like it qualifies under the Stafford Act.

   12                THE COURT:     Yeah.     This hadn't made it to the

   13    Court of Appeals yet to have any kind of answer on

   14    this.

   15                PROBATION OFFICER:        No, sir.

   16                THE COURT:     All right.       I'll overrule the

   17    objection on that, but I'll take it into consideration,

   18    of course, on the idea that these guidelines are

   19    advisory.    And so that's that.

   20                Anything else on the guidelines?

   21                MS. BOZANIC:      No, Your Honor.

   22                THE COURT:     All right.       So before we move

   23    forward, we'll -- on Ms. Manuel, she's at level 18,

   24    Criminal History Category I, advisory range of 27 to 33

   25    months, two to five years supervised release,
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    1    restitution $411,417, possible fine of 10 grand to

    2    3 million, $300 special assessment.

    3                Mr. Casseus is in a situation of -- he's a

    4    level 19, 'cause his charges were a little different --

    5    Criminal History Category I, advisory guideline range

    6    of 30 to 37 months.       Counts 1 and 2, 2 to 5 years.

    7    Supervised release:       Count 1, only three years

    8    supervised release.       Restitution, 298,875.           Possible

    9    fine of 10 grand to 2 million, $300 special assessment.

   10    That's where we are on the sentencing guidelines.

   11                There's no victims here?

   12                MS. VIACAVA:      No, Your Honor.

   13                THE COURT:     So what sentence does the

   14    Government recommend, starting with Ms. Manuel?                 Then

   15    we'll talk about Mr. Casseus.          Then we'll go to defense

   16    and maybe back to the Government briefly at the end.

   17                MS. VIACAVA:      Your Honor, in terms of

   18    Ms. Manuel, the Government would be recommending a

   19    sentence to the low end of the advisory guideline

   20    range, as we agreed to in the plea agreement.                 So that

   21    would be 27 months.       We'd be recommending 3 years

   22    supervised release.       We would ask that the forfeiture

   23    that has been ordered in Docket 53 be included as part

   24    of the judgment in this case.

   25                THE COURT:     Is that the house?
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    1                MS. VIACAVA:      Yes, Your Honor.         The house --

    2    well, there was a money judgment that's included in

    3    there as well.

    4                In addition, we're asking for restitution in

    5    the amount of $411,417 that should be payable to the

    6    Small Business Association, or the SBA, as they were

    7    free PPP loans that Ms. Manuel had fraudulently applied

    8    for that have been forgiven.

    9                We'd also recommend mental health treatment

   10    as being appropriate in this case.             It's the

   11    information contained within the pretrial services

   12    report.    That would be the Government's recommendation

   13    in this case based on the fact that she purported to be

   14    in charge of owning two businesses.

   15                And then between July 24, 2020, through

   16    March 4, 2021, she submitted three fraudulent PPP loan

   17    applications for the total of $411,417.               And she used

   18    money from those proceeds towards the purchase of a

   19    home in Cape Coral, Florida.

   20                THE COURT:     Do you have any information about

   21    what they did with the money besides buy this house?

   22    The house is worth roughly 4- or 500-.              The math

   23    doesn't work.       Let's see, the loss amount.

   24                MS. VIACAVA:      Your Honor, talking with the

   25    case agent who looked over the bank records, it
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    1    appeared that the rest of the money went towards living

    2    expenses, things of that nature.

    3                THE COURT:     Just a second.          Let me set this

    4    question up, because it matters a lot to me in this

    5    case what they did with the money.             Because according

    6    to what -- Ms. Manuel stole, roughly, $411,417; and

    7    Mr. Casseus, 298,875.       My math is not great, but I have

    8    that at $710,292.       I hope somebody here can crunch the

    9    numbers and make sure I'm doing that right.                But that's

   10    around 700,000.

   11                The house -- what's the number value of the

   12    house?    4- or 500-, as I recall?

   13                MS. VIACAVA:      I have it close to 500,000.

   14                THE COURT:     So there's another 310 grand

   15    sitting on the table.       It matters to me -- when people

   16    steal money in white-collar scenario, it matters to me

   17    what they do with it.       And I don't know that I could

   18    spend it in the two or three years before they got

   19    caught -- $300,000 -- if I tried.            That's the

   20    difference between a house and the total amount stolen.

   21                So what were they doing with this money?

   22    Does anybody know?

   23                MS. VIACAVA:      Your Honor, just to be clear --

   24                THE COURT:     Just a second.          I'm going to ask

   25    them what they say, and then you can tell me what you
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    1    think.    I mean, the investigator is here.             Somebody

    2    should have looked at this.          What do you think they

    3    were doing with the money?

    4                MS. VIACAVA:      Your Honor, also just to be

    5    clear, the purchase of the house -- the house is now

    6    worth almost 500,000.       But at the time they purchased

    7    it, it was under 300,000.

    8                THE COURT:     So let's just take 3- off 7-,

    9    that's 500,000.      That makes my question even more

   10    pressing.    What did they do with the rest of the money?

   11                MS. VIACAVA:      Your Honor, from looking at the

   12    bank records that the agent reviewed, it appeared as

   13    though they were using it for living expenses.                 There

   14    were purchases made, things of that nature.                But the

   15    house was the biggest purchase with the money going

   16    directly to that.

   17                THE COURT:     That's not that much money,

   18    frankly, to spend on a house in the current Florida

   19    real estate market.       $500,000 house is not that super

   20    fancy in the current price structure we're living in.

   21    But still -- or 300,000, you said; right?               That was the

   22    purchase price?      That's probably not even a very nice

   23    house for the current prices.

   24                MS. VIACAVA:      If you give me one moment, Your

   25    Honor, I'll be able to answer that question.
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    1                THE COURT:     Related to my question -- on the

    2    defense side of things, related to my question is going

    3    to be, I have historically sentenced people to lower

    4    sentences who pay the money back.

    5                MS. BOZANIC:      Yes, Your Honor, and I have an

    6    answer for you.

    7                THE COURT:     Yeah.     Now if it's going to be

    8    that they spend it all and they can't pay it back,

    9    well, then they don't have that option.               But I've

   10    always, when people have stolen money, that they can

   11    get, you know, a decent amount of that paid back right

   12    up front, they get a more favorable sentence from me

   13    than people saying, well, I spent it.

   14                I treat those cases a little differently.                So

   15    if your clients have the ability to pay that back, I'd

   16    like to know that because it will benefit them in their

   17    sentence.

   18                Let me just finish up over here.

   19                MS. VIACAVA:      Your Honor, speaking to the

   20    agent, he indicated that there were a lot of purchases

   21    that were being made.       In addition to travel to Haiti,

   22    there was money being sent down to Haiti presumably to

   23    other family members.       There is a bank account that the

   24    Government located; still had the money sitting in it,

   25    otherwise, we'd have seizure warrants and have the
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    1    money in hand.

    2                 We do know that money went toward the

    3    purchase of a house; the final purchase price of the

    4    house was $275,000.       They each used a portion of the

    5    PPP funds that they received towards the purchase of

    6    the house.

    7                 THE COURT:     So if the total stolen is 710-;

    8    they spent 275- on a house, that's 425- left over,

    9    roughly.     And we think that was spent just in general

   10    and sending money to Haiti?

   11                 MS. VIACAVA:     I'm being told the purchases

   12    were -- personal purchases were made, just lifestyle

   13    living, everyday living.          In addition, money was being

   14    sent down to Haiti.       There was also travel to Haiti.

   15                 THE COURT:     Haiti is not that expensive to go

   16    to.   Maybe it is to get there.          But you couldn't spend

   17    money in Haiti, because it's the poorest country in the

   18    Western Hemisphere.       I don't know if you could spend

   19    425,000.

   20                 All right.     What -- what do you guys got?

   21                 MS. BOZANIC:     Judge, I know that the bank

   22    froze assets.       And at some point, they had no access to

   23    their accounts.       I know there was one account --

   24                 THE COURT:     Remember what we said about

   25    speaking slowly?
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    1                MS. BOZANIC:      Ms. Manuel -- one of

    2    Ms. Manuel's accounts had $60,000.

    3                THE COURT:     60-?

    4                MS. BOZANIC:      60,000.

    5                For Mr. Casseus, it was about $198,000.

    6                THE COURT:     So there's 260 grand sitting out

    7    there plus a house?

    8                MS. BOZANIC:      Yes, Judge.          And I can tell you

    9    that the house, obviously, had closing costs.                  So even

   10    though the purchase would maybe be this, we should put

   11    another 5 percent or more.         I don't know how much

   12    closing costs are.

   13                THE COURT:     Let's forget about the house.              By

   14    my math, after they -- the 710- that they stole, 275-

   15    to the house is roughly 425-.           What's the total amount

   16    that's in those accounts?

   17                MS. BOZANIC:      198- plus 60- would be 258-.

   18                THE COURT:     Okay.     Subtract that off the

   19    425-.   We're now down -- okay.          That's under 200-,

   20    then, that's left over that they went through over two

   21    and a half years.       That's a lot more reasonable.

   22                Now, do you have that money?              Do you have

   23    those accounts froze for that amount?

   24                MS. VIACAVA:      The Government did not seize

   25    any accounts in this case.
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    1                THE COURT:      So where are we?

    2                MS. BOZANIC:       The bank froze it.           They have

    3    no access to it.        I know that banks, especially the

    4    Fifth Third Bank, I've seen them -- they will freeze it

    5    and close the accounts.            I am not sure why the

    6    Government -- I don't know how the Government actually

    7    gets their hands on that money.             And I'm not sure -- I

    8    think that Fifth Third Bank returned some of the money

    9    to the SBA possibly, but I cannot guarantee on the

   10    process of what happens when the banks freeze money.

   11                They just basically close an account where

   12    they believe there's fraud or they believe -- this case

   13    even started with the Fifth Third Bank, and it was odd

   14    they were buying a house --

   15                THE COURT:      Yeah, the Fifth Third Bank or the

   16    Sixth Fourth Bank -- who cares what bank it is -- it's

   17    not allowed to just freeze somebody's accounts and keep

   18    250 grand of stolen money and nobody ever sees it

   19    again.

   20                PROBATION OFFICER:          Your Honor, for the

   21    record, when -- the defendant reported to us that her

   22    personal checking account had $25 in it and a vehicle

   23    worth 9,000.        So that's all we had for her report

   24    financially.

   25                THE COURT:      Well, I don't know what I'm
Case 2:23-cr-00009-KCD-DNF   Document 69   Filed 02/21/24   Page 20 of 24 PageID20
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    1    supposed to do with this information.              'Cause I'm

    2    hearing that they told the authorities they had $25 and

    3    no money.    They are here now in court telling me that

    4    there's frozen accounts worth about what, 258-?

    5                MS. BOZANIC:      Yes, Your Honor.

    6                THE COURT:     Let's get to the bottom of this,

    7    because it matters to me.         I think my sentence would be

    8    very different if they can pay back, roughly, you

    9    know -- I don't know.       What's the house going to sell

   10    for with closing costs and stuff like that?                If they

   11    can pay back a big chunk of this, then that's a

   12    different sentence for me than if we just hear, oh,

   13    gone to Haiti and spent it.

   14                MS. BOZANIC:      Judge, I would suggest if you

   15    would continue the sentencing hearing, I will work with

   16    the Government.      We'll figure out where this money

   17    went.

   18                THE COURT:     I'd be happy to do that.            I mean,

   19    show me the money; right?         If they can come up with

   20    this money and pay it back, that's going to benefit

   21    them.

   22                I'll tell you the last time I had this

   23    conversation was a case in Tampa.            The defendant was

   24    represented by Alec Hall, the public defender -- not

   25    assistant public defender.         This defendant was
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    1    represented by the public defender.                And everybody in

    2    the room understood what I was saying.                And she had a

    3    house that she bought with stolen money.                And she put

    4    it into her husband's name, and she refused to sell it.

    5    She just wouldn't do it, because she didn't think it

    6    was fair she was going to prison and her husband didn't

    7    have a house.

    8                I know her attorney definitely told her to

    9    sell it.    She wouldn't listen to her attorney.                She

   10    didn't want to give up the money, and she's doing a

   11    longer sentence than she needed to, 'cause she didn't

   12    come up with the money.

   13                So if they can come up with the money without

   14    stealing it, don't do another crime or used -- you

   15    know, do it legally, and maybe we can talk about

   16    something a little different.

   17                MS. BOZANIC:      They have agreed to the

   18    forfeiture.     They're just basically waiting -- they are

   19    going to go rent something.

   20                THE COURT:     So they are out of the house; the

   21    house has gone to forfeiture.          But you're telling us

   22    there's another 250- out there; right?

   23                SPECIAL AGENT KIRBY:         Yeah.

   24                THE COURT:     Let's see what we can do here.

   25    One thing I'm not going to trade is a real short jail
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    1    sentence for 250 grand.           Because a lot of people would

    2    do that; right?      I can find hundred people on the

    3    street that would go to jail for six months if they can

    4    keep 250 grand.      So I got to balance all of that, you

    5    know.

    6                MS. BOZANIC:      Yes, Your Honor.          I would --

    7                THE COURT:     What do you think?

    8                MS. VIACAVA:      Your Honor, I will say, in

    9    talking with the agent, they did trace the accounts

   10    that the PPP loan money went into.              They conceded those

   11    accounts are empty.       So if there's additional funds out

   12    there, we're not sure where that came from.

   13                THE COURT:     I don't think we need to get

   14    wrapped up into accounts.           My point is paying back the

   15    amount of money that was stolen.             However they can come

   16    up with it, as long as it's legal, that, I think, is a

   17    good idea if we can.       But go ahead.

   18                MS. VIACAVA:      I was going to say if there's

   19    any money that's been frozen, it certainly has not been

   20    done with a seizure warrant.           It's not something the

   21    Government has been involved with, because we did not

   22    find any accounts that had money sitting in it.                  So,

   23    therefore, we're not aware of which accounts --

   24                THE COURT:     Sounds like it was the Sixth

   25    Fourth Bank; not the Fifth Third Bank.               They are going
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    1    to get into -- Juan, what's my next day?

    2                THE DEPUTY CLERK:        October 20.

    3                THE COURT:       October 20.     Your cases will be

    4    reset to October 20.         Go find some money.        See where we

    5    are; all right?

    6                MS. BOZANIC:       Yes, Your Honor.

    7                THE COURT:       Thank you.

    8                You guys out of jail; right?

    9                MS. BOZANIC:       Yes, Your Honor.        They're out

   10    on bond.

   11                THE COURT:       Don't do anything illegal while

   12    you're out on bond.         If you do, you go to jail.          Good

   13    luck.

   14                THE DEFENDANT:        Thank you, Your Honor.

   15                        (Recess taken 1:27 PM, September 15,

   16                        2023)

   17

   18

   19

   20

   21

   22

   23

   24

   25
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    1                         REPORTER'S CERTIFICATE

    2                I, Vonni R. Bray, a Certified Dipolmate and

    3    Realtime Reporter, certify that the foregoing transcript,

    4    consisting of 23 pages, is a true and correct record of

    5    the proceedings given at the time and place hereinbefore

    6    mentioned; that the proceedings were reported by me in

    7    machine shorthand and thereafter reduced to typewriting

    8    using computer-assisted transcription; that after being

    9    reduced to typewriting, a certified copy of this

   10    transcript will be filed electronically with the Court.

   11                I further certify that I am not attorney for,

   12    nor employed by, nor related to any of the parties or

   13    attorneys to this action, nor financially interested in

   14    this action.

   15                IN WITNESS WHEREOF, I have set my hand at Fort

   16    Myers, Florida, this 21st day of February, 2024.

   17

   18

   19                                       s/ Vonni R. Bray, RDR, CRR
                                           Vonni R. Bray, RDR, CRR
   20                                      United States Court Reporter

   21

   22

   23

   24

   25


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