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Home Court filings U.S. v. Francesco Distefano Government's Sentencing Memorandum — United States v. Francesco Distefano

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Government's Sentencing Memorandum — United States v. Francesco Distefano

Summary

The government's sentencing memorandum in United States of America v. Francesco Distefano, No. 1:24-cr-00424, in the U.S. District Court for the Northern District of Illinois, filed February 24, 2026 as Document 111. It asks the court to impose 108 months' incarceration followed by three years of supervised release, and notes a sentencing hearing set for March 10, 2026. It recounts that a second superseding indictment returned December 10, 2024 charged wire fraud under Title 18, United States Code, Section 1343, a false statement to a financial institution under Section 1014 and money laundering under Section 1957(a), and that the defendant pleaded guilty to Count One on June 25, 2025. It describes Paycheck Protection Program and Economic Injury Disaster Loan applications filed with a co-defendant for two companies, including a $149,900 disbursement and a $1,090,890 loan. It is 34 pages.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

No. 1:24-cr-00424 · Doc. 111 · Docket on CourtListener

Full text

     Case: 1:24-cr-00424 Document #: 111 Filed: 02/24/26 Page 1 of 34 PageID #:787




                        UNITED STATES DISTRICT COURT
                        NORTHERN DISTRICT OF ILLINOIS
                             EASTERN DIVISION

 UNITED STATES OF AMERICA                   )
                                            ) No. 24 CR 424-1
         v.                                 )
                                            ) Judge Jeremy C. Daniel
 FRANCESCO DISTEFANO                        )

                     GOVERNMENT’S SENTENCING MEMORANDUM

        The United States of America, by its attorney, ANDREW S. BOUTROS, United

States Attorney for the Northern District of Illinois, respectfully submits this

memorandum in advance of the sentencing of defendant FRANCESCO DISTEFANO.

The government respectfully requests that this Court impose a sentence of 108

months’ incarceration followed by three years of supervised release.

I.      PROCEDURAL BACKGROUND

        On December 10, 2024, a grand jury returned its second superseding

indictment charging defendant FRANCESCO DISTEFANO with wire fraud, in

violation of Title 18, United States Code, Section 1343 (Counts 1-11); making a false

statement to a financial institution in violation of Title 18, United States Code,

Section 1014 (Count 12); and money laundering, in violation of Title 18, United States

Code, Section 1957(a) (Counts 13-17).

        On June 25, 2025, pursuant to a written plea agreement with the government,

DISTEFANO pled guilty to Count One of the second superseding indictment.

        A sentencing hearing has been scheduled for March 10, 2026, at 11:00 a.m.
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II.      OFFENSE CONDUCT

         The Paycheck Protection Program (PPP) and the Economic Injury Disaster

Loan (EIDL) program provided economic relief to businesses experiencing a loss of

revenue as a result of the COVID-19 pandemic. Plea Agreement, ¶ 5. 1 DISTEFANO

was familiar with these programs and knew that, in order to obtain a PPP loan, a

business was required to provide information about, among other things, the number

of individuals it employed and its average monthly payroll and, in order to obtain a

loan as part of the EIDL program, a business applicant was required to provide

truthful information about the number of employees as well as the business’ gross

revenues and cost of goods sold, among other things. DISTEFANO also knew that the

information in the PPP and EIDL applications about the business’ employees, payroll,

and revenues was material to the approval and funding of these loans. Id.

         Beginning in March 2020, and continuing through February 2021, in the

Northern District of Illinois, Eastern Division, and elsewhere, DISTEFANO, together

with co-defendant Sargis Urumieh, knowingly devised, intended to devise, and

participated in a scheme to defraud and to obtain money and property, in connection

with applications for loans and advances under the PPP and the EIDL program on

behalf of businesses which Urumieh owned and controlled, namely, West Cost POS,

Inc. (West Coast) and National POS Inc. (National). Plea Agreement, ¶ 5. These

applications     contained   materially   false   statements   and   misrepresentations



1 Dkt. 82.


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concerning, among other things, the purported entities’ number of employees, gross

revenues, and payroll. And, on or about March 31, 2020, DISTEFANO, for the

purpose of executing the scheme, knowingly caused to be transmitted by means of

wire communication in interstate commerce certain writings, signs, and signals,

namely, an internet transmission of an EIDL application on behalf of West Coast to

the U.S. Small Business Administration (SBA). Id.

      The West Coast EIDL and EIDL Advance

      Following the onset of the pandemic, DISTEFANO and Urumieh discussed

obtaining an EIDL on behalf of Urumieh’s company, West Coast. Plea Agreement, ¶

5. Following that discussion, on or about March 31, 2020, DISTEFANO prepared and

filed an EIDL application on behalf of West Coast through the SBA online portal with

Urumieh’s knowledge and consent. DISTEFANO acknowledges that the transmission

of this application over the Internet involved an interstate wire communication. Id.

      In completing this application, DISTEFANO falsely represented that West

Coast had 12 employees as of January 31, 2020, gross revenues of $5,000,000, and

cost of goods sold of $4,500,000, even though DISTEFANO knew that West Coast did

not have that many employees or that amount of cost of goods sold. Id. As a result of

these false representations, on May 22, 2020, the SBA disbursed EIDL funds of

$149,900 into an account J.P. Morgan Chase Bank, in the name of West Coast, for

which Urumieh was the sole signatory (“Account 6250”). Id. The SBA also disbursed

a $10,000 advance grant into Account 6250 on or about April 20, 2020, based upon

DISTEFANO’s request. Id.
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      The West Coast PPP Loan and Second Round Application

      On approximately July 17, 2020, DISTEFANO prepared and provided to

Urumieh, and Urumieh thereafter signed and submitted to Arkansas Capital

Corporation (Arkansas Capital), an application for a PPP loan for West Coast in the

amount of $1,090,890. Plea Agreement, ¶ 5. Arkansas Capital was a community

development finance company that originated PPP loans in partnership Encore Bank.

Id. In connection with the loan application, DISTEFANO and Urumieh falsely

represented that West Coast had 67 employees (after reporting 14 employees on the

initial application form) and an average monthly payroll of $436,356, even though

West Coast did not have that number of employees or an average payroll in that

amount. Id.

      In support of the application, DISTEFANO also created and provided to

Urumieh, and Urumieh electronically submitted to Arkansas Capital, a fictitious

ADP “Payroll Run Summary Report” and a fictitious IRS Form 940. Id. Based upon

the false statements, on July 22, 2020, Arkansas Capital and Encore Bank funded a

PPP loan in the amount of $1,090,890, into an account at Encore Bank in the name

of West Coast, that was opened to receive the PPP proceeds. Id.

      On approximately July 23, 2020, DISTEFANO opened a payroll account in the

name of West Coast at ADP, with himself as the account administrator, for the

purpose of removing PPP proceeds from West Coast’s account at Encore Bank and

making it appear that these proceeds were being used for payroll. Id. Between July

of 2020 and December of 2020, approximately $783,012 of the West Coast PPP
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proceeds were transferred from the West Coast account at Encore Bank to the payroll

account at ADP held for the benefit of West Coast. Id. Between July of 2020 and

December of 2020, DISTEFANO told ADP to transfer funds it held for West Coast to

approximately eight “employee” payees including himself, Urumieh, and three of

Urumieh’s family members. Id. Specifically, ADP paid $84,600 as “wages” to Urumieh

and approximately $169,769 as “wages” to three of Urumieh’s family members. Id.

ADP also paid DISTEFANO $389,539, which Distefano identified to ADP as non-

wage payments. Id.

      On February 5, 2021, DISTEFANO electronically submitted a second round

PPP application to Arkansas Capital on behalf of West Coast in which he fraudulently

sought to obtain an additional $1,380,655. Id. In support of this application,

DISTEFANO falsely represented that West Coast had 14 employees and monthly

payroll of approximately $552,262, knowing that West Coast neither had that many

employees or amount of payroll. Id. The loan was not funded. Id.

      The National PPP Loan and Second Round Application

      Between approximately July 25, 2020, and July 28, 2020, DISTEFANO

prepared and provided to Urumieh, and Urumieh then submitted to Arkansas

Capital, an application for a PPP loan in the amount of $1,722,645.50 on behalf of

National. Plea Agreement, ¶ 5. In the loan application, DISTEFANO and Urumieh

falsely represented that that National had 123 employees and an average monthly

payroll of $689,058.20, even though, in reality, National was not an operating

business and had no employees. Id.
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         In support of the application, DISTEFANO assisted Urumieh in creating and

sending fabricated documents to the lender in support of the loan. Id. These

documents included a fictitious ADP “Payroll Run Summary Report” and a fictitious

IRS Form 940, both falsely reporting that National paid $8,272,696.45 in wages in

2019 that DISTEFANO created and provided to Urumieh to submit to Arkansas

Capital. Id.

         On July 28, 2020, DISTEFANO created a fictitious payroll spreadsheet that

listed 122 fictitious employees, each with a reported salary of between $98,121 and

$98,952. Id. Urumieh sent these false documents to Arkansas Capital in support of

the National PPP loan application. Id. Based upon the false statements, on July 29,

2020, Encore Bank disbursed a PPP loan in the amount of $1,722,654 into an account

at Encore Bank in the name of National that was opened to receive the PPP proceeds.

Id.

         On approximately July 28, 2020, DISTEFANO opened a payroll account in the

name of National at ADP, with himself as the account administrator, in order to make

it appear that National had employes and payroll. Id. Nevertheless, the ADP account

set up by DISTEFANO identified only six employees rather than the 123 listed in the

loan application. Id. Of these six employees, DISTEFANO identified four as W-2 wage

earners, with the remaining two – DISTEFANO and his acquaintance – listed as non-

employees receiving 1099 compensation. Id.

         On February 5, 2021, DISTEFANO electronically submitted a second round

PPP application to Arkansas Capital on behalf of National in which he and Urumieh
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fraudulently sought to obtain an additional $1,994,717. Id. In support of this

application, DISTEFANO falsely represented that National had 53 employees and

monthly payroll of approximately $797,887, knowing that National did have that

number of employees or amount of monthly payroll. Id. This loan was not funded. Id.

      Proceeds from the West Coast and National Loans

      On July 31, 2020, DISTEFANO caused $388,821 of the National PPP loan

proceeds to be transferred into his account at U.S. Bank (“Account 9624”) via the

National payroll account at ADP. Plea Agreement, ¶ 5. That same day, DISTEFANO

caused funds to be drawn from Account 9624 to make payments to American Express

totaling $188,368.73 and to purchase three cashier’s checks totaling $183,205.33 to

purchase or complete the purchase of a 2016 Lamborghini Huracan; 2020 Land Rover

Range Rover Evoque; and 2017 Maserati Ghibli. Id. On or about August 6, 2020,

DISTEFANO used a further approximately $95,000 in National PPP loan proceeds

that Urumieh caused to be transferred directly from National’s account at Encore

Bank to DISTEFANO’s Account 9624 to purchase a 2017 Porsche 911 Carrera. Id.

      The total amount of funds DISTEFANO received for his personal benefit from

the National PPP loan was approximately $814,780. Id. This amount is comprised of

transfers into Account 9624 totaling approximately $719,780 from the payroll account

at ADP held for the benefit of National between July 2020 and January 2021, and the

$95,000 transferred directly from National’s account at Encore Bank to Account 9624

on August 6, 2020. Id.



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      From July 2020 through January 2021, approximately $329,815 of the West

Coast PPP loan proceeds were transferred to Account 9624 for DISTEFANO’s

personal benefit. Id.

      Defendant acknowledged in his plea agreement that the actual loss

attributable to the scheme is approximately $2,973,444 and that the total of actual

loss and intended loss for that scheme is approximately $6,348,816. Id.

      Urumieh’s Purchase of Property in Glendale California

      After obtaining funds from the EIDL and PPP first-round loan applications

filed for West Coast and National, Urumieh entered into a contract to purchase a

home located at 29XX E. Chevy Chase Dr. in Glendale, California (the “Glendale

Property”). Plea Agreement, ¶ 5. DISTEFANO’s understanding was that Urumieh

used funds obtained from the West Coast and National PPP loans for the down

payment to purchase the Glendale Property. Id. Thereafter, DISTEFANO and

Urumieh caused fraudulent mortgage loan applications to be filed to enable Urumieh

to complete the purchase. Id.

      Between approximately September 9, 2020, and October 19, 2020,

DISTEFANO assisted Urumieh in submitting to Better Mortgage an application for

a residential real estate loan in the amount of approximately $746,555 to purchase

the Glendale Property, knowing that such application contained false and fraudulent

representations regarding: (a) monthly income; and (b) the truthfulness and accuracy

of the application and supporting documents. Id.



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      The Uniform Residential Loan Application that DISTEFANO submitted online

to Better Mortgage on behalf of Urumieh represented that Urumieh had monthly

income of $233,333. Id. In support of the application, DISTEFANO created two

fraudulent individual income tax returns (IRS Forms 1040-X) falsely representing

that Urumieh had adjusted gross income of $8,908,233.43 in 2019 and adjusted gross

income of $7,659,188.50 in 2018, and a fraudulent letter from “ER TAX SERVICES”

explaining the IRS Forms 1040-X, and caused the documents to be submitted to

Better Mortgage. Id. Additionally, DISTEFANO and Urumieh submitted to Better

Mortgage a fraudulent “Large Deposit Explanation” that falsely attributed a

$450,000 deposit of proceeds from the National first draw PPP loan into an account

that Urumieh controlled at Chase Bank ending in 6250, as proceeds of a liquidation

of Urumieh’s “stock options on TastyTrade.” Id.

      On or about October 19, 2020, Urumieh, after he was informed by Better

Mortgage that his loan application had been rejected by underwriting because of

“discrepancies in income in the amount of millions of dollars from what was reported

to the IRS when your taxes were filed as opposed to the tax returns that [Better

Mortgage] received,” sent an email to DISTEFANO and Individual A stating “[t]hats

what I was concerned about” and asking “[w]hat now?” Id. DISTEFANO responded

to this email with a false narrative for Urumieh to provide to Better Mortgage. Id.

      After Urumieh’s mortgage loan application was rejected by Better Mortgage,

between approximately October 30, 2020 and December 4, 2020, DISTEFANO,

Urumieh, and Individual A caused to be submitted to Planet Home an application on
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behalf of Urumieh for a residential real estate loan in the amount of approximately

$765,600 to purchase the Glendale Property, knowing that the application contained

false and fraudulent representations regarding: (a) monthly income; and (b) the

truthfulness and accuracy of the application and supporting documents. Id.

      The Uniform Residential Loan Application to Planet Home falsely represented

that Urumieh was employed by National and West Coast, both of Addison, Illinois,

with a total monthly income of $30,833. Id. To corroborate false representations made

in the application, DISTEFANO, Urumieh, and Individual A, created and submitted

to Planet Home, a fraudulent Sales Purchase Agreement that was backdated to

August 1, 2020. Id. More specifically, the document was built from a template

Individual A and DISTEFANO received from a then-relative of DISTEFANO. Id.

After the document was modified to reflect a fictional business sale transaction, the

document was docusigned by DISTEFANO from his house in Addison, Illinois, and

by Urumieh from his house in Glendale, California, on November 27, 2020. Id. The

docusign receipt page was then altered so that it appeared that the document had

been docusigned on August 1, 2020. Id. The document was then submitted to Planet

Home and falsely recounted that West Coast was sold by Urumieh to DISTEFANO’s

company, Distefano Enterprises LLC, for $2,000,000 payable in installments, and

that Urumieh was to enter into a 10-year employment agreement with Distefano

Enterprises at an annual salary of $365,000. Id.




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      Defendant acknowledged in his plea agreement that for the purpose of

computing his sentence under the Sentencing Guidelines, the following conduct

constitutes relevant conduct under Guideline § 1B1.3:

      EIDL and EIDL Advance Obtained by Distefano Enterprises

      Simultaneous to his scheme with Urumieh, DISTEFANO was engaged in his

own scheme to obtain EIDL and PPP funds through fraudulent applications filed for

his own company, Distefano Enterprises LLC. Plea Agreement, ¶ 6. On March 31,

2020, DISTEFANO applied for an EIDL on behalf of Distefano Enterprises through

the SBA online portal. In this application, he falsely represented that Distefano

Enterprises had 12 employees as of January 31, 2020, gross revenues of $2,500,000,

and cost of goods sold of $2,120,000. At the time of the application, DISTEFANO knew

that these representations were false. Id. As a result of these representations, on

June 10, 2020, the SBA disbursed EIDL funds totaling $149,900 into DISTEFANO’s

Account 9624. Id. On June 18, 2020, the SBA disbursed a $10,000 EIDL advance

grant into Account 9624. Id.

      Distefano Enterprises PPP Loan and Second Round Application

      On or around April 27, 2020, DISTEFANO submitted to U.S. Bank an

application requesting a PPP loan in the amount of $237,500, on behalf of Distefano

Enterprises. Plea Agreement, ¶ 6. In the initial loan application, DISTEFANO falsely

stated that Distefano Enterprises had 14 employees and an average monthly payroll

of $95,000. Id. DISTEFANO supported this loan application with a fraudulent ADP

“Payroll Run Report” that he created. Id.
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      On or about May 13, 2020, DISTEFANO submitted a revised fraudulent PPP

loan application to U.S. Bank, in which he falsely represented that Distefano

Enterprises had 14 employees with an average monthly payroll of $79,166, once again

knowing these presentations were false. Id. Based upon the false statements, on May

13, 2020, U.S. Bank disbursed a PPP loan in the amount of $197,915 into Account

9624. Id.

      On October 29, 2020, DISTEFANO electronically submitted to U.S. Bank a

PPP Loan Forgiveness Application Form 3508EZ on behalf of Distefano Enterprises.

Id. In the application, he falsely reported that during the period of May 13, 2020 to

October 27, 2020, the business had payroll costs of $255,478.54. Id. Additionally,

DISTEFANO submitted, as supporting documentation, a fictitious ADP report listing

7 employees and a fictitious IRS Form 941 for the 3rd quarter of 2020. Id. This loan

forgiveness application was not granted. Id.

      On approximately February 5, 2021, DISTEFANO electronically submitted a

second round PPP application to Arkansas Capital Corporation on behalf of Distefano

Enterprises in which he fraudulently sought to obtain an additional loan in the

amount of $83,921. Id. In support of this application, DISTEFANO falsely

represented that Distefano Enterprises had 14 employees and a monthly payroll of

approximately $33,568. Id. This loan was not funded. Id.

      Defendant acknowledged in his plea that the actual loss attributable to the

Distefano Scheme is approximately $357,815 and that the total of actual loss and

intended loss for that scheme is approximately $441,736. Id.
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      Unemployment Benefits

      Beginning in March 2020 and continuing into February 2021, DISTEFANO

applied for and received unemployment benefits by falsely claiming that he was

unemployed due to COVID-19 since March 29, 2020. Plea Agreement, ¶ 6. In fact,

DISTEFANO was not unemployed and his business continued to operate. Id. Based

upon his false statements, the Illinois Department of Employment Security

electronically deposited approximately $29,581.50 in unemployment benefits into

Account 9624. Id.

      Beginning in approximately August of 2020 and continuing into September of

2021, DISTEFANO applied for and received unemployment benefits in the name of

his father, claiming that his father was a self-employed driver/sales worker who

became unemployed due to COVID-19. Id. In reality, DISTEFANO’s father was

retired. Id. Based upon DISTEFANO’s false statements, the Illinois Department of

Employment Security disbursed $8,059.50 in unemployment benefits on account of

the claim, and DISTEFANO received the funds. Id.

      Defendant’s Fraudulent Petition Filed with FBI

      On February 17, 2021, four motor vehicles and $677,932.25 on deposit in

Account 9624 were seized pursuant to seizure warrants. Plea Agreement, ¶ 6. On

April 28, 2021, a Notice of Seizure of Property and Initiation of Administrative

Forfeiture Proceedings was issued and served on defendant. Id.

      On May 3, 2022, defendant filed his Petition for Remission/Mitigation seeking

the return of the $677,932.25 seized from Account 9624. Id. In this application,
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defendant represented that the funds transferred to him by West Coast and National

were “for actual work done.” Id. Defendant falsely represented in the application that

he “was a bona fide purchaser or seller of the forfeited property for value, AND [he]

did not know and was without cause to believe that the property was subject to

forfeiture at the time [he] acquired [his] interest in the property.” Id. In support of

his petition, defendant submitted four counterfeit invoices, purporting to bill four

different customers a total of $1,010,000 care of Urumieh and West Coast. Id. These

invoices did not evidence real obligations, and were submitted to deceive the

government as to why defendant had received funds from the West Coast and

National loans. Id. The Petition for Remission/Mitigation was electronically signed

by defendant under penalty of perjury. Id.

III.   CORRECTIONS/OBJECTIONS TO THE PRESENTENCE REPORT

       The government has the following correction and objections to the Presentence

Report.

          •   The total loss amount for Guidelines’ purposes should be approximately
              $6,828,184. The government and Probation Office have reviewed the
              inputs, and it appears that one input was slightly off in arriving at the
              $6,828,193 referenced in Paragraph 38 of the PSR.

          •   The government respectfully disagrees with the Probation Office about
              the applicability of a leader/organizer enhancement, for the reasons
              explained below.

          •   The government agrees the proposed Special Condition 14 is warranted,
              but believes it should be more narrowly drawn, for reasons explained
              below.




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IV.    GUIDELINES CALCULATIONS

       The Sentencing Guidelines to be considered in this case are those in effect at

the time of sentencing, the November 2025 Guidelines Manual.

       A.      Criminal History Category

       The government and the Probation Office agree that defendant is a criminal

history category I. PSR at ¶ 53.

       B.      Offense Level Calculation

               i.        The government and the Probation Office agree that that the base

offense level is 7, pursuant to Guideline § 2B1.1(a)(1). PSR ¶ 37.

               ii.       The government and the Probation Office agree that the offense

level is increased by 18 levels because the loss of approximately $6,828,184 2


2 The inputs for this total are as follows:


                     Distefano Enterprises EIDL                  $159,900
                     Distefano Enterprises PPP                   $197,915
                     Distefano Enterprises 2nd Round PPP          $83,920

                     West Coast EIDL                             $159,900
                     West Coast PPP                            $1,090,890
                     West Coast 2nd Round PPP                  $1,380,655

                     National PPP                              $1,722,646
                     National 2nd Round PPP                    $1,994,717

                     IDES benefits payable to defendant        $29,581.50
                     IDES benefits payable to defendant's
                     father                                     $8,059.50

                                                     TOTAL     $6,828,184


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attributable to the offense of conviction and relevant conduct is between $3,500,000

and $9,500,000, pursuant to Guideline § 2B1.1(b)(1)(J) and Application Note 3(D)(ii).

PSR ¶ 38.

              iii.   The government and the Probation Office agree that the offense

level is increased by 2 levels because the offense involved obtaining more than

$1,000,000 in gross receipts from one or more financial institutions, pursuant to

Guideline § 2B1.1(b)(17)(A). PSR ¶ 39.

        iv.   The government respectfully disagrees with the Probation Office that

the offense is increased by 2 levels because defendant was an organizer of the offense,

pursuant to Guideline § 3B1.1(c). Application Note 4 to Guideline § 3B1.1(c) instructs

that factors to consider include: “the exercise of decision-making authority, the nature

of participation in the commission of the offense, the recruitment of accomplices, the

claimed right to a larger share of the fruits of the crime, the degree of participation

in planning or organizing the offense, the nature and scope of the illegal activity, and

the degree of control and authority exercised over others.”

        Among the participants of this scheme (defendant, codefendant Sargis

Urumieh, and Individual A 3), defendant did not per se exercise control over others.

He made many tactical decisions in executing the scheme, but he did not alone

(openly) make larger decisions such as what loans would be applied for or what his

share of the proceeds would be. Defendant was supposed to be working for Urumieh


3Individual A’s direct involvement in the scheme primarily involved the second home
mortgage application for co-defendant Sargis Urumieh.
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to fraudulently obtain the loans for Urumieh. Their agreed arrangement was that

defendant would be compensated with a particular high end motor vehicle for his

efforts. PSR ¶ 23. Defendant took a portion of the loan proceeds, but he achieved this

by deceiving Urumieh into believing that the funds were needed for taxes. Id.

Urumieh (directly and through his designees) received the majority of the funds

obtained through the scheme. Considering the totality of the circumstances, the

government does not believe that an enhancement under Guideline § 3B1.1(c) is

warranted.

             v.    The government and the Probation Office agree that the offense

level is increased by 2 levels because the defendant willfully attempted to impede and

obstruct the investigation by filing his fraudulent Petition for Remission/Mitigation

with the FBI, pursuant to Guideline § 3C1.1. PSR ¶ 42.

      ii.    Acceptance of Responsibility

      The government agrees with the Probation Office that that a two-level offense

reduction is not applicable under Guideline § 3E1.1(a). PSR ¶ 45. The government’s

position is based exclusively on defendant’s continued criminal conduct while on

pretrial release, however, and not on defendant’s pre-indictment obstruction.

Defendant obstructed brazenly during the investigation. However, after he was

indicted, defendant requested to meet with the government and truthfully admitted

his conduct in this case. The contrast with his pre-indictment behavior was

exceptional. A plea agreement was reached between the government and defendant

that provided that defendant would be available to cooperate and testify in the case
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against his codefendant, Sargis Urumieh. However, after defendant was granted

pretrial release, he brazenly violated the conditions of release and engaged in further

fraudulent conduct by creating All in 1 Swipe LLC with a nominee owner, and he

used the business to sign up an as-of-yet undetermined number of business clients

for payment processing services without their knowledge or consent. PSR ¶ 57; Supp

GV at 1; GX 4 (reports of interview with four “customers” who are unaware of All In

One Swype). 4 Additionally, defendant tendered a fraudulent check to Molly Maids

cleaning service. 5 See GV at 18-20; GX 2-A; GX 2-B.

       The Guidelines advise that appropriate considerations in determining the

applicability of § 3E1.1(a) include, but are not limited to, “voluntary termination or

withdrawal from criminal conduct. . . .” Application Note 1(B). Consistent with the

Application Note, courts have denied defendants the reduction under § 3E1.1(a) for

continuing criminality. See United States v. McDonald, 22 F.3d 139, 141 (7th Cir.

1994) (collecting cases). Here, defendant continued engaging in fraudulent conduct




4 Citations to the Government’s Version of the Offense are “GV,” Government’s Supplemental

Version of the Offense are “Supp. GV,” and Defendant’s Version of the Offense are “DV,” each
followed by a page number. Citations to exhibits to the Government’s Versions of the Offense
are “GX” followed by the exhibit number and page, if applicable.
5 The government was alerted to the existence of a potential issue with Molly Maids through

a violation report prior to defendant’s change of plea. The government initially understood
that the check involved an acquaintance of defendant who had been living in his house, and
that defendant was more or less in the wrong place at the wrong time. The reality of what in
fact occurred – a fraudulent check was created using account information of Victim PB, whose
identity was previously fraudulently used to sign her business up for service with defendant’s
Big Star Payments company – was not known to the government until after defendant’s
pretrial release was revoked and further witnesses were interviewed and records obtained.
See GV 18-20.
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within a few weeks of obtaining pretrial release. Defendant’s actions were entirely

inconsistent with acceptance, and the reduction should not apply.

         D.    Advisory Guidelines Range

         The government calculates defendant’s total offense level to be 29. With a

criminal history category I, defendant’s guideline range is 87 to 108 months’

imprisonment.

V.       APPLICATION OF STATUTORY SENTENCING FACTORS

         The Court must impose a sentence that is “sufficient, but not greater than

necessary” to achieve the purposes of sentencing. 18 U.S.C. § 3553(a). In doing so,

the Court must consider the statutory factors outlined in 18 U.S.C. § 3553(a)(1)-

(7), including:

         (1) the nature and circumstances of the offense and the history and
         characteristics of the defendant; (2) the need for the sentence imposed—(A) to
         reflect the seriousness of the offense, to promote respect for the law, and to
         provide just punishment for the offense; (B) to afford adequate deterrence to
         criminal conduct; (C) to protect the public from further crimes of the defendant;
         and (D) to provide the defendant with needed educational or vocational
         training, medical care, or other correctional treatment in the most effective
         manner; [and] (3) the kinds of sentences available.

Id. § 3553(a)(1)-(3). The Court must also respect “the need to avoid unwarranted

sentence disparities among defendants with similar records who have been found

guilty of similar conduct,” as well as “the need to provide restitution to any victim of

the offense.” Id. § 3553(a)(6)-(7). Finally, the Court must consider the Guideline range

and any pertinent policy statements issued by the United States Sentencing

Commission. Id. § 3553(a)(4)-(5). Although the Sentencing Guidelines are only

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advisory, “[a]s a matter of administration and to secure nationwide consistency,

[they] should be the starting point and the initial benchmark.” Gall v. United States,

552 U.S. 38, 49 (2007).

      This Court should give serious consideration to the advisory Guidelines range,

for several reasons. First, the Guidelines minimize unwarranted sentencing

disparities and “remain an essential tool in creating a fair and uniform sentencing

regime across the country.” United States v. Mykytiuk, 415 F.3d 606, 608 (7th Cir.

2005); see also Booker v. United States, 543 U.S. 220, 250, 253 (2005) (noting that

“Congress’ basic goal in passing the Sentencing Act was to move the sentencing

system in the direction of increased uniformity” and “diminish[ing] sentencing

disparity”). Second, the Guidelines are “the product of careful study based on

extensive empirical evidence derived from the review of thousands of individual

sentencing decisions,” Gall, 552 U.S. at 42, and the U.S. Sentencing Commission is

“a respected public body with access to the best knowledge and practices of penology.”

United States v. Wachowiak, 496 F.3d 744, 753 (7th Cir. 2007) (quoting United States

v. Goldberg, 491 F.3d 668, 673 (7th Cir. 2007)). Therefore, “its judgments should not

lightly be disregarded.” Id. Finally, the U.S. Sentencing Commission is charged by

statute to review and revise the Guidelines as it collects sentencing data from

throughout the federal court system, see 28 U.S.C. § 994(o), making the Guidelines

the product of continuous evolution and improvement. See Rita v. United States, 551

U.S. 338, 358 (2007).



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      In this case, a sentence of 108 months’ incarceration, which falls at the high end

of the advisory Guidelines’ range, is sufficient but not greater than necessary to satisfy

the goals of Section 3553(a). Even if the Court were to determine a lower Guidelines

range, the government believes that a sentence of 108 months’ incarceration is

appropriate under the Section 3553(a) factors.


      A.     The Nature and Circumstances of the Offense

      The offense was serious. As the nation was struggling with the COVID

pandemic the defendant was scheming to defraud the PPP, EIDL, and unemployment

programs. Defendant successfully obtained $3,368,892 and nearly obtained a further

$3,459,292. The offense occurred over an 11-month period. It was not the result of a

momentary lack in judgment, but a continuing series of decisions, motivated by greed,

that defendant made to fraudulently obtain ever more money.


      B.     History and Characteristics of the Defendant

      Defendant is 29 years-old and a lifetime resident of the Chicagoland area. PSR

¶¶ 62, 73. Defendant grew up in a household with both parents and enjoys a good

relationship with them. Id. ¶¶ 62-63. Defendant reports that he was bullied as a child

due to his placement in advanced classes at school. Id. ¶ 64. Defendant graduated

high school in 2014, and went on to complete one year of college. Id. ¶ 105. While in

high-school, defendant started Distefano Enterprises LLC, a company that provided

payment processing services to merchants. Id. ¶ 65.



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      Defendant is generally healthy. PSR ¶¶ 77-79. Defendant has several mental

health diagnoses for which he has been provided medication. Id. ¶¶ 81-84, 86.

Defendant is presently on the waitlist at MCC to participate in cognitive skills, anger

management, and criminal thinking programs. Id. ¶ 86.

      Defendant was 24 years-old when he committed the criminal conduct in this

case. The known fraudulent conduct that defendant has engaged in since the offense

conduct began includes:

          •   committing mortgage fraud in the purchase of defendant’s own home

              (see PSR ¶ 55; GV at 17-18);

          •   continued receipt of fraudulently obtained unemployment benefits in

              defendant’s father’s name after defendant was interviewed by the FBI

              concerning PPP fraud (see PSR ¶ 28);

          •   submission of false records to the FBI in an attempt to recover

              $677,932.25 in scheme proceeds that had been seized from defendant’s

              bank account (see PSR ¶ 32);

          •   filing four fraudulent lien releases with the DuPage County Recorder to

              release liens places on defendant’s home after he failed to pay for

              windows, HVAC, floor refinishing, and roofing services performed by

              contractors on his home (see PSR ¶ 55; GV at 17-18; GX 1-A; GX 1-B);

              and




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          •   operating Big Star Payments through a nominee owner and signing

              “customers” up for services without their knowledge or consent (see PSR

              ¶ 57; GV at 20; GX 2-B).

Defendant was initially detained in this case on September 11, 2024. After

approximately 225 days of detention, defendant was granted pretrial release on April

24, 2025. Upon posting bond, defendant engaged in further fraudulent conduct:

          •   on May 12, 2025, defendant opened All in 1 Swipe LLC through a

              nominee, and proceeded to use “customer’s” identities to sign them up

              for service without their knowledge or consent (see GV at 20-21); and

          •   on or about May 13, 2025, defendant provided a fraudulent check to

              Molly Maids cleaning service and later lied to the Glendale Heights

              Police Department about the fraudulent nature of the check, insisting

              that it was not honored because he had stopped payment, when, in fact,

              it was not honored because it was a fraudulent check. 6 See GV at 18-20;

              GX 2-A; GX 2-B.

      Defendant has one prior conviction. In December 2023, defendant was

convicted of Nonconsensual Dissemination of Sexual Images, commonly referred to

as “revenge porn,” in Cook County Circuit Court. The conduct underlying that



6 On September 10, 2025, defendant was charged in DuPage County Circuit Court with a

misdemeanor forgery offense in People of the State of Illinois v. Francesco Distefano, No.
2025CM001892. The case was nolle pross’d on October 22, 2025. The government
understands from the ASA assigned to the case that the disposition was due to the pending
federal case, and not the merits.
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conviction occurred on or about January 12, 2022, and involved defendant

disseminating private sexual images of the victim to her father, as well as the posting

of such images to Facebook, Instagram, and various pornographic websites. PSR ¶

52. One disseminated image was a video of a sexual encounter filmed in Las Vegas,

Nevada, wherein the victim appeared to not be alert during the filmed encounter. Id.

Defendant contends that the victim was trying to “extort” him, and that it was

“stupid” of him to distribute the images. Id. It is noted that defendant has been

accused of similar conduct by other women, including his former wife (PSR ¶¶ 68,

97), and Victim KM, who filed a series of police reports against defendant in April

2020, alleging that, following their breakup and her rejection of his sexual advances,

defendant disseminated nude images of her (that she had never consented to the

creation of) without consent, slashed the tires on her vehicle, called her incessantly

including from spoofed numbers that appeared to be known contacts to her, and

circled her apartment in his vehicle repeatedly after the police told defendant to stop

contacting her. Supp. GV at 2-3; GX 7 (compilation of police and interview reports).

Defendant accused Victim KM of using his credit card for unauthorized charges, see

Exhibit 7 at 8, however, defendant has fabricated evidence to falsely accuse Victim

KM of being under grand jury investigation (compare GX 3-D with GX 3-E), so his

accusations against her are suspect.

      Defendant has a history of perpetrating outrageous deceptions. In a recent

example, while defendant was on pretrial release, he falsely portrayed himself to

Victim NN as an informant and special agent working with the FBI with access to
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criminal investigatory files. Defendant provided Victim NN with fabricated and

fraudulent investigatory files to convince Victim NN that her former partner (with

whom she shares a child) was about to be indicted. See Supp. GV at 3; GX 3-C at 1;

GX 3-D; GX 3-E. This was apparently motivated by defendant’s desire to date Victim

NN, and his desire that she stay away from her former partner with whom she shares

a child. In another example, in August 2023, defendant distributed to former business

acquaintances a fraudulent letter purported to be from the United States Attorney

for the District of Columbia. See GX 8. The fraudulent letter falsely represented that

the investigation into defendant’s PPP fraud (which was publicly known due to news

articles covering the seizure of defendant’s cars and bank accounts) had been closed

and that the United States was paying $15,000,000 to defendant for its “wrongdoing.”

Id.

      Defendant has not been cited for misconduct while housed at the Metropolitan

Correctional Center. However, on December 6, 2025, defendant utilized another

inmate’s calling account and called Victim NN approximately 19 times on December

6, 2025. See Supp. GV at 2; GX 5; GX 6. This behavior constitutes phone abuse in

violation of MCC rules. And it is the continuation of a pattern of defendant

incessantly calling women who do not wish to communicate with him. See GX 5; GX

7 at 29.




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      C.       The Seriousness of the Offense, and the Need to Promote
               Respect for the Law, Provide Just Punishment, Afford Adequate
               Deterrence, and Protect the Public

      Defrauding federal relief programs for millions of dollars during a global

pandemic is a serious offense. The sentence to be imposed must deter defendant

and others from committing fraud, protect the public, and promote respect for the

rule of law.

      Defendant’s offense was serious because of the large sums involved and the

fact that the offense was committed while the nation was experiencing a national

emergency. Defendant took millions from programs designed for struggling

businesses to avoid layoffs and used the funds for ostentatious purchases

including a Lamborghini and a Porsche. His conduct undermines the public’s

confidence in the administration of federal relief programs.

      Defendant has shown by his actions that there is a strong need for specific

deterrence in this case. Defendant knew that he was under investigation for PPP

fraud since February 2021, and, instead of being chastened and changing his

conduct, he plowed forward and committed further frauds. Even after defendant

spent 225 days in pretrial detention, he quickly returned to fraud upon being

granted pretrial release. Defendant has demonstrated a lack of respect for this

Court’s order setting conditions of release and a continuing lack of respect for the

law. Defendant has shown that a substantial custodial sentence is necessary to

deter him from committing further crimes.

       A substantial sentence is also necessary to protect the public. While
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defendant may not have the opportunity to defraud the PPP and EIDL programs

again, he has shown that he will continue to engage in other frauds if he is not

incapacitated. An example is the case of Victim PB. On September 4, 2024, one

week before defendant was arrested in connection with this case, defendant’s Big

Star Payments (which he had opened using the name of his then-girlfriend)

fraudulently impersonated Victim PB and signed her up for payment processing

services. See GV at 19-20. After defendant was granted pretrial release and was

on home incarceration, defendant returned to victimizing Victim PB by using a

fraudulent check that contained her business’s account information and

presenting it to Molly Maids. Id. Defendant’s behavior demonstrates that he is not

presently willing to refrain from engaging in fraud, and custodial incapacitation

is the only measure that will reasonably assure the safety of the public from

defendant’s unceasing fraud schemes.

      A substantial custodial sentence is also necessary to generally deter others

who may be inclined to defraud government programs. The need for general

deterrence is particularly strong for economic crimes, which are often

premeditated, lucrative, and difficult for law enforcement to detect. See United

States v. Heffernan, 43 F.3d 1144, 1149 (7th Cir. 1994) (“Considerations of

(general) deterrence argue for punishing more heavily those offenses that either

are lucrative or are difficult to detect and punish, since both attributes go to

increase the expected benefits of a crime and hence the punishment required to

deter it.”) “Because economic and fraud-based crimes are more rational, cool, and
                                         27
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calculated than sudden crimes of passion or opportunity, these crimes are prime

candidates for general deterrence.” United States v. Brown, 880 F.3d 399, 405 (7th

Cir. 2019) (quotation omitted).

      Defendant was young when he committed the offense conduct. However,

the mitigative inference of this fact is substantially tempered by defendant’s

behavior in the five years since the offense conduct. Specific deterrence, promotion

of respect for the law, and protection of the public are considerations that require

a substantial custodial sentence in defendant’s case. The government submits that

a sentence of 108 months’ incarceration is sufficient but not greater than

necessary to achieve the purposes of sentencing set forth in 18 U.S.C. § 3553(a).

VI.   FINE AND RESTITUTION

      In light of defendant’s present circumstances and the Guidelines’ range, the

government’s position is that a fine is not appropriate in this case.

      Pursuant to 18 U.S.C. § 3663A, the Court must order defendant, together

with any jointly liable co-defendants, to make full restitution to the victims in an

amount to be determined by the Court at sentencing. The government has

submitted its Victim Import Spreadsheet requesting defendant be ordered to pay

$2,973,436.42 in restitution for the offense conduct.

      Additionally, as part of his plea agreement with the government, the

defendant agreed to pay further restitution of $395,456 pursuant to 18 U.S.C. §§

3663(a)(3) and 3664, for losses caused by defendant’s relevant conduct. Plea

Agreement, ¶ 15. These amounts are also included in the Victim Import
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Spreadsheet.

VI.    SUPERVISED RELEASE

       The government requests that defendant’s sentence include a period of three

years’ supervised release. With the exception of Special Condition 14, which the

government supports in a modified form, the government supports the Probation

Office’s recommended conditions for the reasons set forth below.

       The PSR recommends the following mandatory conditions, as numbered in the

PSR:

       (1) not commit another Federal, State, or local crime;

       (2) make restitution in accordance with 18 U.S.C. §§ 3663 and 3663A, or any
           other statute authorizing a sentence of restitution

       (3) not unlawfully possess a controlled substance;

       (6) cooperate in the collection of a DNA sample if required by law; and

       (7) refrain from any unlawful use of a controlled substance AND submit to one
       drug test within 15 days of release on supervised release and at least two
       periodic tests thereafter, up to 104 periodic tests for use of a controlled
       substance during each year of supervised release.

The government agrees with the imposition of these mandatory conditions, and given

that these conditions are mandated by statute, the Court need not give any reason or

explanation for the imposition of these mandatory conditions. United States v.

Bryant, 754 F.3d 443, 445 (7th Cir. 2014).

       In addition to the mandatory conditions, the Court has discretion to impose

additional conditions of supervised release or probation (1) that are “reasonably

related” to the factors set forth in 18 U.S.C. §§ 3553(a)(1), (a)(2)(B), (a)(2)(C), and
                                          29
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(a)(2)(D); (2) that “involve[] no greater deprivation of liberty than is reasonably

necessary” to meet the goals of 18 U.S.C. §§ 3553(a)(2)(B), (a)(2)(C), and (a)(2)(D); and

(3) that are “consistent with any pertinent policy statements issued by the Sentencing

Commission.” 18 U.S.C. § 3583(d); United States v. Shannon, 743 F.3d 496, 500 (7th

Cir. 2014). Section 3583(d) points to the discretionary conditions set forth in § 3563(b).

      Discretionary Conditions 4, 6, 7, 8, 9 and 24, as numbered in the PSR, support

defendant’s rehabilitation and reintegration into the community and would ensure

that he is engaged in lawful pursuits instead of criminal activity. Specifically,

Discretionary Condition 4, requiring defendant to work conscientiously at obtaining

employment will discourage him from returning to a life of crime and provide him

necessary financial resources. Discretionary Condition 6 prohibits defendant from

knowingly meeting or communicating with any person that he knows to be planning

or engaging in criminal activity, and also prohibits defendant from contacting the

individuals that participated in the offense conduct. Discretionary Condition 7, which

prohibits defendant from excessive use of alcohol (defined as a BAC above .08%) and

from any use of narcotics or controlled substances without a prescription, will assist

with defendant’s efforts to address anger and other mental health issues.

Discretionary Condition 9 provides support for defendant’s mental health diagnosis

by providing for mental health treatment.

      Discretionary Conditions 14 through 18, as numbered in the PSR, facilitate

effective and efficient supervision of defendant by the Probation Office, and without

these conditions, the Probation Office would be severely hampered in assisting
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defendant to succeed. For example, requiring defendant to remain within the district

(Discretionary Condition 14) and report to his probation officer within 72 hours of

release from imprisonment (Discretionary Condition 15) will assist the probation

officer in supervising defendant effectively and efficiently. Discretionary Condition 16

allows the probation officer to visit defendant’s home, work, school, a community

service location or other reasonable location at any reasonable time to ensure

defendant’s compliance with his release conditions. Moreover, requiring defendant

notify a probation officer within 72 hours of any change in residence, employer, or

workplace (Discretionary Condition 17) or any arrest, criminal charge, or law

enforcement questioning (Discretionary Condition 18) allow for necessary probation

officer supervision and support of defendant.

      Pursuant to 18 U.S.C. § 3563(b)(22), which allows for “other conditions as the

court may impose,” the Probation Office recommended nine additional special

conditions, all of which the government agrees are appropriate here. First, the

Probation Office recommends that defendant, if unemployed after the first 60 days of

supervision or if unemployed for 60 days after employment ends, must perform at

least 20 community service hours each week at the direction of Probation until

gainfully employed, with the total community service hours not to exceed 300 hours

(Special Condition 3). This condition supports defendant’s reintegration to lawful

society should he be unable to obtain employment despite the training and support

provided through supervised release. Second, the Probation Office recommends that

defendant be prohibited from incurring new credit charges or opening new lines of
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credit without approval of a probation officer unless defendant is in compliance with

the financial obligations of his sentence (Special Condition 5). Given that defendant

will owe substantial restitution, Special Condition 5 as well as Special Condition 6

(requiring defendant to provide financial information to probation officer to monito

compliance with conditions of supervised release), Special Condition 7 (requiring

defendant to notify probation officer of significant change in economic circumstance),

Special Condition 8 (requiring defendant to file accurate income tax returns and pay

all taxes, interest, and penalties required by law), and        Special Condition 10

(requiring defendant to repay any financial condition that remains owing at the

commencement of supervised release at a rate of not less than 10% of after-tax

income) are all warranted.

      The Probation Office recommends in Special Condition 15 that all of

defendant’s current and future employment be subject to Court approval to mitigate

third party risk. This condition is reasonably necessary to protect the public from

further crimes of defendant in light of defendant’s activities with Big Star Payments

and All in One Swipe.

      The Probation Office recommends that defendant “not enter into any

agreement to act as an informer or special agent of a law enforcement agency without

the permission of the court.” (Special Condition 11). As the Seventh Circuit has noted,

a defendant acting as a confidential informant on supervised release is “generally

inconsistent” with the rehabilitative and reintegration efforts of the Sentencing

Guidelines because it keeps a defendant in the underground world of criminality at a
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time when that person is trying to change his/her life. See United States v. Kappes,

782 F.3d 828, 851 (7th Cir. 2015) (finding that the district court’s lack of findings to

support this condition was harmless because “acting as a confidential informant is

generally inconsistent with the rehabilitative and re-integrative goals of

supervision”).

      The Probation Office’s proposed Special Condition 14 provides that defendant:

      shall participate in a sex offender evaluation/assessment, which may include
      psychological and physiological testing. The specific program and provider will
      be determined by a probation officer. If treatment is deemed necessary by the
      provider, the offender shall comply with all recommended treatment, which
      may include psychological and physiological testing.

The government agrees that a sex offender evaluation/assessment is warranted.

Defendant did not complete such an evaluation/assessment in connection with his

Cook County case. Given that defendant’s Cook County case involved images of a

victim who does not appear to have been fully alert during the filmed sexual act, and

given that defendant has been accused of nonconsensual dissemination of sexual

images by two other women, an assessment to evaluate whether defendant might

benefit from treatment would promote the policy goals of protecting the public and

defendant’s rehabilitation. See United States v. Russell, 81 F.4th 726, 730 (7th Cir.

2023) (finding sex offender assessment warranted in sentencing for fentanyl

distribution based on conduct underlying a previous domestic battery/physical

contact conviction). The government submits that the Special Condition should be

narrowly tailored to include only the evaluation/assessment. In the event the

assessment determines that defendant would benefit from treatment, the matter
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should then be brought back before the Court so defendant has the opportunity to be

heard and a decision can be made as to whether any treatment is necessary.

VIII. CONCLUSION

      For the reasons set forth above, the government respectfully submits that a

sentence of 108 months’ incarceration followed by three years of supervised release is

warranted in this case.

                                       RESPECTFULLY SUBMITTED,

                                       ANDREW S. BOUTROS
                                       UNITED STATES ATTORNEY

Dated: February 24, 2026         By:   /s/ Jeffrey S. Snell
                                       JEFFREY S. SNELL
                                       United States Attorney=s Office
                                       219 S. Dearborn, Suite 500
                                       Chicago, Illinois 60604
                                       Telephone: 312-469-6308
                                       Email: Jeffrey.Snell2@usdoj.gov




                                         34


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