Sentencing Memorandum - United States v. Crystal Denean Harvell

Record facts

U.S. District Court, Middle District of Florida · No. 3:24-cr-00179-WWB-LLL · Doc. 34 · 2025-03-03 · Docket on CourtListener

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UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
JACKSONVILLE DIVISION
UNITED STATES OF AMERICA
v.

Case No. 3:24-cr-179-WWB-LLL

CRYSTAL DENEAN HARVELL
__________________________________/
SENTENCING MEMORANDUM
I.

A sentence below the guidelines is appropriate sentence in this
case.

Undersigned counsel respectively requests this Court to sentence Ms. Harvell
to a sentence below the guidelines, with a requirement that Ms. Harvell serve time
on home confinement. A sentence that allows for a portion of the term to be served
on home confinement is appropriate in this case and promotes the sentencing
factors set forth in 18 U.S.C. § 3553(a). The requested sentence is sufficient, but
not greater than necessary, when considering the history and characteristics of
Ms. Harvell, the nature of the offense, the need to reflect the seriousness of the
offense and to promote just punishment, to provide adequate deterrence to Ms.
Harvell, to provide Ms. Harvell with the needed resources contemplated under the
statute, and the need to avoid unwarranted sentence disparities.
II.

1

The history and characteristics of Ms. Harvell support a below
guideline sentence. 1

Ex. 1, Letters for the Court, Video of Mr. Harvell.

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While many people come before this Court with difficult childhoods, it would
be fair to say that Ms. Harvell has struggled throughout her life. Despite these
struggles, Ms. Harvell is the first person her family calls when they need help. She
is the confidant for all of the children and teenagers in her family. She is the most
reliable neighbor, friend, and family member in her circle. Ms. Harvell has a big
heart. It is no wonder that while she is the joy of so many people’s lives, she also
suffers greatly.
A. Ms. Harvell was the victim of a heinous crime at the age of 15.
Ms. Harvell’s mother was 16 when she had Ms. Harvell. Despite this early
pregnancy, Ms. Harvell’s mother worked hard to raise Ms. Harvell, ultimately
becoming a nurse. Ms. Harvell’s mother married Carlton Rogers when Ms. Harvell
was young, and they remain together today. Ms. Harvell’s stepfather worked for
the railroad when Ms. Harvell was younger and now is a truck driver for Centurion
Auto Logistics.
Although Ms. Harvell’s parents worked hard to provide her with a good
childhood, Ms. Harvell was gang raped at a friend’s house when she was 15 years
old. Ms. Harvell’s parents tried to intervene after the tragic incident and help Ms.
Harvell. They reported the rape to law enforcement and supported Ms. Harvell in
getting therapy after this extensive trauma occurred. Unfortunately, the incident
facilitated a breakdown for Ms. Harvell that resulted in Ms. Harvell being committed
to a psychiatric hospital because Ms. Harvell’s family was concerned that she was
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going to harm herself.
Once Ms. Harvell was released from the hospital, Ms. Harvell tried to act as if
nothing had happened. She started dating a much older man, which was
concerning to her parents but not surprising as it was obvious that Ms. Harvell was
trying to find worthiness from a man after having been stripped of all dignity during
the crime committed against her. Ms. Harvell quickly became pregnant and gave
birth to a little girl at the age of 16.
Ms. Harvell raised her daughter with the help of her parents. Ms. Harvell tried
to stay in school after the birth of her daughter Cimone but was unable to handle
trying to take care of her baby, who had some health issues. Due to her own mental
health issues and the baby’s health issues, it became impossible to stay in school.
In order to make ends meet, Ms. Harvell worked multiple jobs, often coupling a
daytime office job with bartending at night.
B. Ms. Harvell was the victim of a senseless violent act at 20 years old.
After struggling the first few years of her daughter’s life, Ms. Harvell was able
to get her own apartment at age 20 and was trying to raise Cimone on her own.
She was still dependent on her mother’s help but was so proud that she was finally
able to provide enough stability for Cimone that they could live on their own in a
small little apartment in downtown Jacksonville. One night, Ms. Harvell was coming
back to her apartment after work. She parked in front of the building and was shot

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in the back of her head and neck by a drive-by shooter while trying to exit her car. 2
Ms. Harvell suffered significantly from this shooting. She was in the hospital for
several weeks. The anxiety that she had been able to keep at bay since the birth
of her daughter, came back even stronger. Ms. Harvell was treated for anxiety, for
which she continues to be treated today. Due to having severe anxiety, in
combination with her arrhythmia in her heart, there are moments that Ms. Harvell
has panic attacks so strong that she is unsure whether she is going to live.
C. The loss of Ms. Harvell’s brother has been difficult for the family.
Ms. Harvell had two siblings, with whom she was extremely close. Her sister
Carnisha Rogers is unfortunately an unnamed co-conspirator in Ms. Harvell’s case
and has been prosecuted separately. The sisters were extremely close with their
brother, Carlton Rogers, who died of an accidental drug overdose in July of 2020.
Ms. Harvell was not aware that her brother had a substance abuse issue until right
before he died. Ms. Harvell knew who was supplying the drugs to her brother and
tried to get him to stop dealing drugs to her brother. But in the end, Ms. Harvell
was unable to save her brother. He went missing and was found in an empty house
close to where their family was living at the time. 3 He was only 24 at the time of
his death.

Ex. 2, Medical Records from Emory Hospital. (showing that Ms. Harvell still has the bullet in
her body from the shooting and also suffers from supraventricular tachycardia, an irregular
heartbeat or arrhythmia that causes episodes of fast or erratic heartbeat leading to chest pain,
dizziness, weakness, and occasional falling.). Medical Records filed under seal and provided to
all parties.
3
Ex. 3, The last message that Carlton Rogers sent Ms. Harvell and his obituary.
2

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Since the death of Ms. Harvell’s brother, Ms. Harvell and her family have tried
to identify the person that dealt the deadly dose to her brother and have him
prosecuted. Ms. Harvell and her family have given law enforcement access to her
brother’s phone, have made reports, and done everything they can to bring the
person that harmed her brother to justice. The death of her brother still haunts Ms.
Harvell and the family. It also has had serious consequences on the children that
he has left behind.

Crystal and her sister with their mother. Carlton Rogers, Jr. with their mother.

D. Ms. Harvell has done an excellent job raising her daughter and others.
Ms. Harvell always wanted a better life for her daughter and the children in
her family than the life she had. Ms. Harvell has worked tirelessly to provide her
daughter, her nieces and nephews, and children of her extended family and to give
them opportunities to ensure that they have a good life. Cimone is now 20 years
old. She is a junior at Albany State University. She is smart and excited about her
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future. She wants to be a federal prosecutor, because she believes that she can
make a difference by compassionately prosecuting those accused of crime. Ms.
Harvell is so proud of Cimone and is devastated that her participation in this
offense will take her away from Cimone as Cimone enters her senior year of
college and thinks about her next steps.

Cimone’s high school graduation.
After discovering that her brother and the mother of his children were
struggling with substance abuse issues, Ms. Harvell took temporary custody of
their children, providing for all of their needs. Although two of the three children
now reside with Ms. Harvell’s mom, Ms. Harvell is the person called upon to help
take care of the children, currently ages 2 and 5, when Ms. Harvell’s mom needs
assistance. Recently one of Ms. Harvell’s cousin’s daughters, age 14, moved in
with Ms. Harvell because her mother was struggling with personal issues and
she needed someone she could trust to help care for her daughter. Ms. Harvell
also has helped her sister raise her children, who are currently ages 11, 8, and 3.
During the Covid-19 pandemic, Ms. Harvell moved her sister and her children
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into her home in Atlanta. She knew that Carnisha needed help with her children
and was ready and willing to help.
It is very likely that Carnisha will ultimately be sentenced for her
participation in the offense for which Ms. Harvell is now being sentenced. If
Carnisha is incarcerated, Ms. Harvell’s mother will be solely responsible for
raising all three of her children in addition to the two children left behind by her
son. Although only 53 years old, Ms. Harvell’s mother has Lupus and has a hard
time getting around some days. She also recently learned that there has been a
mass discovered near her kidney. Ms. Harvell is needed at home to help with
these children and this need is primarily why she has requested a below
guideline sentence with a requirement that she serve a portion of that sentence
in home confinement. By sentencing Ms. Harvell below the guidelines, Ms.
Harvell will be able to continue to assist her mother in helping raise the children
left behind by the tragedy of their brother’s overdose and help with her sister’s
three children.

Ms. Harvell’s nieces and nephews.
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E. Ms. Harvell is a caretaker.
Ms. Harvell is a caretaker for anyone in need. Ms. Harvell had a good life in
Atlanta. She was selling hair extensions, living close to her daughter, and able to
take the children in her family’s life to Atlanta for exposure to a different life than
the one they were living in Jacksonville. Everyone loved visiting Ms. Harvell in
Atlanta and she loved living in a bigger city where everyone did not know her name.
In August 2024, Ms. Harvell’s family suffered another huge loss after the death
of her brother in 2020. Ms. Harvell’s grandmother, the matriarch of the family,
passed away.

Ms. Harvell’s grandfather is 82 years old and a veteran. He was exposed to Agent
Orange while overseas and has had his leg amputated due to his various medical
conditions. Ms. Harvell’s grandmother had not only taken care of Ms. Harvell and
her siblings and children but was also taking care of Ms. Harvell’s grandfather at
the time of her death. Ms. Harvell immediately left her life in Atlanta to return to
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Jacksonville to take care of her grandfather. Ms. Harvell’s mother is still working
and raising her son’s children. Carnisha has her own children and struggles that
do not allow her to be a caretaker to their grandfather. Therefore, the privilege of
being their grandfather’s caretaker was bestowed upon Ms. Harvell. Ms. Harvell
willingly packed up her life in Atlanta and moved back to Jacksonville to take care
of her grandfather. Today, Ms. Harvell cooks for her grandfather, helps him with
his medications, takes him to all of his doctor’s appointments, and bathes him.
While they have a nurse that helps, most of the responsibilities are entrusted to
Ms. Harvell.
At the time of this writing, the family has made the decision not to ask Ms.
Harvell’s grandfather to attend the sentencing. His mental health is unstable. He
has been extremely depressed since his wife died and now is having to come to
terms with the fact that his caretaker may be taken away from him. However, Mr.
Harvell spoke to this Court from his home through a video message that we have
attached to Exhibit 1 of this Memorandum. Mr. Harvell’s message to this Court is
powerful. He explained that Ms. Harvell is his sole caretaker and that he relies on
Ms. Harvell for all of his needs. The family is very concerned about his well-being
and what will happen if Ms. Harvell is no longer able to provide the necessary care
that he needs.
F. Ms. Harvell has always helped law enforcement, which is why she is
so embarrassed by her actions.
When Ms. Harvell was young, she bar tended to try to make ends meet.
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During that time, she got to know a lot of people in Jacksonville and was privy to
information about gangs and crime. Due to her connections and her concern about
what was happening in her community, Ms. Harvell became a confidential
informant for the Jacksonville Sheriff’s Office in approximately 2015. When Ms.
Harvell heard information that she believed would be helpful to law enforcement
about criminal activity, she would make law enforcement aware of what she heard.
She was in consistent communication with one of the detectives about the
information that she learned.
When people in her community found out that Ms. Harvell was a “snitch”
they started making veiled threats through mutual acquaintances. Ms. Harvell
continued to provide information to law enforcement but ultimately moved to
Atlanta because she was concerned for her safety. While in Atlanta, Ms. Harvell
was introduced to the hair extension business and became the “go to” for all things
hair extensions in her community. Ms. Harvell continued to provide information to
law enforcement about things she was hearing “through the grapevine” and tried
to help any way she could.
Ms. Harvell would have never imagined that just a few short years later, she
would be the subject of a law enforcement investigation. She has expressed
remorse but also complete embarrassment for what she has done and how ended
up committing crimes when she spent most of her life trying to prevent crime. Ms.
Harvell still wants to help law enforcement when she is able and believes that she
still has a lot to offer this world, despite this conviction.
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III.

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The nature and circumstances of the offense warrant a below
guideline sentence.

A. Ms. Harvell’s participation in the scheme – Count 1.
i.

What is a CPN and a Tradeline?
a. CPNs

Although not as prevalent as it was during the years of the scheme—2016 to
2019—you can find a way to “increase your credit score” through obtaining Credit
Privacy Numbers and Tradelines online. Websites such as cpnprograms.com and
cpngenerator.com advertise that persons can purchase “Credit Profile Numbers”
or “Credit Privacy Numbers” to utilize for loans and purchases in place of one’s
social security number when applying for credit. 4 The websites advertise that these
“CPNs” provide second chance credit and are a way to increase a person’s credit
score by attaching their name to this “second identification number.” In addition to
websites advertising CPN Numbers, you can also go to ssn-verify.com/generate
and have the website generate the first 5 numbers of a new social security number
to which one can just add the last 4 digits to create what they believe to be a new
identification number. 5
Today, there are more websites cautioning about the illegality of CPNs than
CPN generator websites as it has become determined over the course of the past

Ex. 4, printouts from websites cpnprograms.com and cpngenerator.com. See
https://cpnprograms.com/; https://cpnprograms.com/.
5
See ssn-verify.com.
4

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several years that while CPNs were advertised as second identifications, most
companies were providing social security numbers belonging to others. 6 As such,
most CPN generators have gone underground with their scams. However, during
the course of 2018 and 2019 when Ms. Harvell was involved (although the
conspiracy ran from 2016 through 2019, there is no indication that Ms. Harvell was
involved prior to 2018 and Ms. Harvell believes that it was not until 2018 that she
agreed to help an unnamed co-conspirator with providing CPNs to others), CPN
generating businesses were pervasive in her community. What is interesting about
these CPNs, is that even though many of the CPN numbers were actual social
security numbers, either because the person generating the number had access
to social security numbers or, like Ms. Harvell, they used the SSN-verify generator
to create new identification numbers not knowing that these numbers could be
associated with actual persons, people that used these CPNs to purchase credit
or merchandise on credit used their real names and addresses. In other words,
when they obtained a CPN, they registered that CPN with the credit companies as
their own number.
During this time, Ms. Harvell believed, that these “new” identification numbers
were to be used for the purpose of immediately resuscitating a bad credit score.
Therefore, if someone wanted to immediately improve their credit score, they
needed to use their newly issued CPN with their actual name and address to

Ex. 5, Capitol One Article, published in August 2024. https://www.capitalone.com/learngrow/money-management/cpn/.
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ensure that the new, better credit, was being credited to them. As such, the use of
the CPNs, were committed out in the open because almost every business that
provided a loan or credit to the person using the CPN knew where to find that
person, if they were not paid. And in Ms. Harvell’s case, she was not aware that
these numbers were tied to actual people.
b. Tradelines
While Ms. Harvell helped generate CPNs for some persons, her main role
in the conspiracy involved the second step in “increasing a person’s credit score,”
which was providing people with “tradelines.” Experian provides a good
explanation for a tradeline describing it as: “another name for an account listed on
your credit reports . . . for each credit card, loan and other type of credit account
you have, you’ll have a separate tradeline that includes key information about the
creditor and the debt.” 7 Experian warns, “there is no law against buying tradelines
to increase your credit. However, buying tradelines may be viewed as deceptive
by lenders and credit reporting agencies and could even put you in danger of
committing bank fraud . . . If you pay to improve your credit scores without doing
any of the work or even getting a card to use, you could be falsely representing
your creditworthiness to potential lenders.” 8
Despite Experian’s warnings over the last couple of years, there are thousands

Ex. 6, Experian, “Why you should avoid buying tradelines,” June 30, 2023.
https://www.experian.com/blogs/ask-experian/are-buying-tradelines-legal/.
8
Id.
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of accounts advertised online that purport to be persons willing to sell a position as
an “authorized user” on their accounts and persons eager to buy these “tradelines”
to “boost their credit score.” There are a number of “tradeline” websites still
available for easy access and utilization on the internet. If you just google
“purchase tradeline,” there are multiple businesses advertising “tradelines” for
sale. 9
In the scheme for which Ms. Harvell participated, persons would open up credit
accounts using their CPNs. Then, others, would be added to those accounts, or
tradelines, as a way to boost credit as well as purchase items on credit that most
likely the person could not afford at the time of the purchase.
ii.

Ms. Harvell’s participation in the scheme.

During the years of the scheme, CPNs and tradelines were being advertised
throughout Ms. Harvell’s community as a way to boost credit scores and purchase
items on credit. Sometimes this activity was to help a person purchase an item for
themselves such as a car. Sometimes it was to help a person obtain an apartment
when they could not pass a credit score. And sometimes it was to purchase
merchandise that the co-conspirators could resell at a higher value because they
purchased the original merchandise on credit.
Ms. Harvell sometimes sold CPNs to others, but mostly the other coconspirators would call her after they had generated a CPN for someone and ask

Ex. 7, printouts from multiple websites selling “tradelines.” See, e.g., tradelineworks.com;
boostcredit101.com; tradelinesupply.com.

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Ms. Harvell to add their “customers” to the tradelines. Ms. Harvell also boosted her
own credit, and on a few occasions sold merchandise purchased by herself and
others through these CPNs and credit accounts.
Ms. Harvell does not provide this information to the Court to minimize in any
way her participation in this scheme. Ms. Harvell takes full responsibility for her
actions. Ms. Harvell provides this information to the Court because it is important
for this Court to know that it was never Ms. Harvell’s intention to steal someone
else’s identification or make fraudulent purchases in someone else’s name or as
someone else. The utilization of other person’s social security numbers is illegal,
and Ms. Harvell takes full responsibility for her actions. However, it is important to
note that Ms. Harvell did not have access to a database with social security
numbers nor was she purchasing advertised social security numbers anywhere.
Ms. Harvell was generating numbers that mimicked social security numbers in
order to help people mask their bad credit and then using those numbers to take
out loans, aka Tradelines, to help them boost their credit. This is fraud.
Unfortunately, in addition to the fraud committed by Ms. Harvell and others, some
of the numbers that were generated belonged to actual people who suffered as a
result. Ms. Harvell is deeply remorseful for the harm that she caused and is
embarrassed that she participated in this scheme.
B. Ms. Harvell’s PPP loan during COVID.
In 2021, Ms. Harvell applied for a PPP loan. At that point, she was supporting
her daughter, had lost her brother and was trying to support his children, and had
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moved her sister and her sister’s children in with her. Ms. Harvell had been working
in the beauty industry selling extensions to people in her community. She did not
have a registered business, but she was trying to make a living by selling hair to
other women. Because she was overextended by family commitments, Ms. Harvell
was struggling to provide for her family.
Ms. Harvell learned about the PPP program and knew a lot of people that took
advantage of the money being offered by the government. Ms. Harvell saw the
PPP loan as a way to help during this time and took advantage of the program by
applying for a loan in order to help with her personal bills. Ms. Harvell is extremely
embarrassed by her actions. She is ashamed to look at the people that counted
on her during this time and admit that she committed this crime in order to try to
help them. She knows that if they had known she was struggling, they would not
have demanded her help. But, true to her character, Ms. Harvell wanted to do
whatever she could to help others struggle less and so she made this bad decision
to lie on the loan application by requesting a business loan when she did not have
the actual losses required to be eligible for the loan.
C. The over exaggeration of Ms. Harvell’s criminal history.
In 2006, Ms. Harvell was 18 years old and dating a much older man. During a
traffic stop, law enforcement found Ecstasy in the vehicle in which Ms. Harvell was
the passenger and the older man was the driver. The man told Ms. Harvell that
she needed to claim that the drugs were hers because he was already in trouble
with the police. When Ms. Harvell tells story, which she does not do to minimize
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her culpability but as a story about her past, she shakes her head and says, “the
police officer kept telling me ‘are you sure you want to claim these drugs? We know
that they are his. You really do not need to be doing this.’” Ms. Harvell recounts
that she told the officer several times that the drugs were hers and the officer,
several times, begged her not to claim ownership of drugs that were not hers, but
also warned that if she continued to insist that they were hers, she was going to
be charged with them. Although this charge was adjudicated in 2006, it still gives
2 points to Ms. Harvell because it was a felony within 15 years of the conspiracy—
the dates of which span from 2016 to 2019. Even given that Ms. Harvell did not
join the conspiracy until 2018, the 2 points would still count because this crime was
within 15 years of the conspiracy.
Ms. Harvell also has an additional criminal history point for a misdemeanor that
occurred in 2016. While this point should technically not be scored because Ms.
Harvell did not join the conspiracy until 2018, she concedes that the 2 points for
the 2006 felony conviction are scored appropriately and that she admitted that the
conspiracy occurred from 2016-2019 and as such has not formally objected to the
additional 1 point. Ms. Harvell takes responsibility for these convictions and does
not ask the Court to ignore them. However, she does ask the Court to consider the
age of the criminal history when fashioning a sentence below the calculated
guideline range.

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D. The motivation to commit these offenses was motivated more to help
others than her own personal gain.
From reviewing the small amount of criminal history and the circumstances
surrounding the criminal history, one can certainly see how Ms. Harvell got herself
in trouble when she was young and once again got herself in trouble in her 30s.
Unfortunately, Ms. Harvell’s efforts and the consequences of her efforts to help
others once again got her into trouble in her 30s when she saw an opportunity to
help others by getting into the “boost your credit score” industry and take out an
unauthorized loan to help with her bills. While she profited some from generating
CPNs and adding tradelines to people’s accounts and her own, the persons
obtaining the loans profited the most. The loss amount for her activities related to
the CPN and Tradeline fraud is approximately $108,000 for which Ms. Harvell will
be jointly responsible with at least one other individual. However, it should be noted
while the loss amount is $108,000, Ms. Harvell did not profit from this full amount.
The loss amount includes all the people involved, which included more than Ms.
Harvell and Ms. Rogers.
Ms. Harvell also did not use the PPP loan to make large purchases or buy
designer items. While she used some of the money to purchase hair for resell, she
used most of the money to pay her bills, for which she was overextended on
because she had taken in so many family members during the pandemic. It is Ms.
Harvell’s big heart that has gotten her into trouble over the years. But thankfully,
because she has a big heart and tries to do the right thing, it is her heart that will
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save her from future crimes because her heart is breaking knowing that she has
let her family down and will be unavailable to them while she serves her time for
this crime.

E. Ms. Harvell tried to cooperate.
Ms. Harvell took responsibility for her actions by agreeing to waive her right to
be Indicted and plea to an Information. In her plea agreement, Ms. Harvell was
given the opportunity to provide substantial assistance to the government. Ms.
Harvell met with agents to discuss certain crimes that she knew about. While Ms.
Harvell certainly would have liked to received credit for her cooperation in the form
of a §5K motion by the government, Ms. Harvell’s main purpose to meeting with
law enforcement was because Ms. Harvell is aware of some people committing
crime that she believed she should tell law enforcement about.
Ms. Harvell’s cooperation did not give rise to the government filing a §5K
motion. Ms. Harvell understands that this was the government’s choice and
because Ms. Harvell chose not to discuss her sister’s involvement, it was likely that
she would probably not receive any type of downward departure for her
cooperation. However, it should be noted that Ms. Harvell tried to tell the
government everything else she knew about crimes being committed—not
because she primarily wanted a downward departure, but because she believed
she had important information to provide to law enforcement. Even after being
charged with this crime, Ms. Harvell’s duty still lies with law enforcement and the
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efforts that they make to keep her community safe.
IV.

The deterrent and rehabilitative purposes of § 3553(a) warrant a
below guideline sentence, with respect to the seriousness of the
offense and the need for punishment.

A. The requested sentence is appropriate when reviewing the § 3553(a)
factors.
Ms. Harvell is extremely remorseful for her actions. The conspiracy in which
Ms. Harvell participated has now been over for almost 6 years and the PPP loan
was taken out in 2021. Since that time, Ms. Harvell has tried to live a law-abiding
life before she was formally charged with these crimes and since she has been on
Supervised Release. Her only goal is to try to do the right thing for herself and her
loved ones.

She understands that what she did is wrong. The charges, the

embarrassment of what she has done, and the possibility of time away from those
that she loves and cares for, serves as deterrence for Ms. Harvell. A lengthy jail
term is not necessary to accomplish this goal. Rather, a sentence below the
guideline range, which may include probation and home detention, or a sentence
to incarceration with a portion of that sentence to be served in home confinement,
will serve as a “substantial restriction” of Ms. Harvell’s liberty and would not be a
sentence of leniency but one that accomplishes the § 3553(a) factors. 10
In addition to serving as a deterrence, a sentence in accordance with § 3553(a)
requires this Court to look at punishments that will provide the defendant with

10

Gall v. U.S., 552 U.S. 38, 44 (2007).

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needed education and vocational training or needed rehabilitation. In this case,
Ms. Harvell is not in need of education or vocational training. She is a hard worker
who needs to be at home to help care for her grandfather and the children in their
family that need help. In addition, a sentence that allows her to serve home
detention rather than be incarcerated will provide her with the much needed mental
health and medical care that she needs in the most efficient and effective way
possible. Ms. Harvell’s crippling anxiety and other health issues are best
addressed in a community setting and not the Bureau of Prisons. In fact,
incarceration will likely trigger Ms. Harvell’s anxiety due to the inevitable shackles
of prison that one experiences while incarcerated and because she will be away
from those that she loves and to whom she provides support. A sentence to
probation or a Zone C sentence that provides for a portion of her sentence to be
served in home confinement, followed Supervised Release will provide Ms. Harvell
with the needed care in the most effective way possible by allowing her to continue
seeing the doctors and being around those that she worries about when she is not
with them.
The offense is serious. While those that commit similar crimes may sometimes
require a more lengthy sentence to reflect the seriousness of the offense and
provide just punishment, a below guideline sentence is appropriate in this case
when considering the other § 3553(a) factors such as the history and
characteristics of Ms. Harvell, the nature of the offense—especially considering
the time period of the offense and Ms. Harvell’s participation in the offense, and
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the impact that the arrest, conviction, and potential incarceration has had on Ms.
Harvell. Ms. Harvell has been deterred from any future crime. If Ms. Harvell were
to be placed on home detention, the community will be safe and Ms. Harvell’s
family would benefit greatly from her being home. Ms. Harvell is a good human.
The world is better off with Ms. Harvell in it, not behind a prison wall.
B. The requested sentence is sufficient, but not greater than necessary.
In addition to the § 3553(a) factors that support a below guidelines sentence, the
guidelines also support this type of sentence. A person sentenced to probation or a
guideline sentence in Zone C of the Sentencing Table may be sentenced to a term
of home detention. In this case, the Court may look to several policy statements to
support a below guideline sentence.
If the Court were to determine that Ms. Harvell’s criminal history score is
overexaggerated, it could find that a more appropriate guideline range would fall
within criminal history category I, making Ms. Harvell’s guideline range 21-27
months. In addition, the Court may consider that even though Ms. Harvell’s
cooperation did not support a §5K Motion, Ms. Harvell did try to cooperate and has
tried to cooperate most of her adult life, making this offense even more devastating
to Ms. Harvell as she never thought that she would be in a position where she was
the target of law enforcement.
§ 5H1.3 allows for departures or variances in cases where a person’s mental
health is present and distinguishes that person from the typical case. For Ms.
Harvell, her mental health struggles stem from being the victim of serious violence
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at a young age and for which she has sought help all of her life. Ms. Harvell’s mental
health struggles, combined with her physical health, are present to an unusual
degree and for reasons beyond her control. While many defendants come before
this Court struggling with mental health and physical health issues, many of those
defendants are not facing a potential guideline sentence that would allow for those
struggles to be addressed outside the Bureau of Prisons. In Ms. Harvell’s case, the
Court could reasonably find that a sentence below the calculated guideline is
appropriate and would more effectively address the struggles that Ms. Harvell has
by allowing her to continue mental health treatment with her providers and to be
around her family who act as a support system to her when she has a serious
depressive episode.
§ 5H1.6 allows for Court to consider family ties and responsibilities as a reason
to sentence someone below the applicable guideline range. In this case, Ms.
Harvell’s assistance to her family is addressed in the Application Note: in light of her
mother’s physical health and her sister’s challenges, the family will struggle
tremendously if Ms. Harvell is sentenced to a lengthy period of time—there will be
a substantial, direct, and specific loss of essential caretaking for both Ms. Harvell’s
grandfather and her brother’s and sister’s children. Ms. Harvell’s mother cannot bear
this caretaking on her own for a lengthy period of time. A sentence probation with
home confinement or a Zone C sentence with a period to be served in home
confinement, will allow Ms. Harvell to limit the substantial hardship on her mother
who will soon be responsible for five children and her father.
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In reviewing the §3553(a) factors, especially the history and characteristics of
Ms. Harvell, the nature of the offense, and the need for deterrence and punishment,
along with the policy statements contained in the guidelines, it would be appropriate
to vary in this case. A sentence that allows Ms. Harvell to serve her sentence in
home confinement is sufficient but not greater than necessary when considering the
§3553(a) factors and would be appropriate when considering the policy statements
outlined by the Guidelines.
V.

Conclusion.

For the reasons outlined in this Sentencing Memorandum, a sentence below
the guideline range, is sufficient, but not greater than necessary. Ms. Harvell has
shown this Court that she is remorseful for her actions. She has the character and
the will to never again make the misguided and senseless decisions that led to this
crime.
Respectfully submitted,
A. FITZGERALD HALL, ESQ.
FEDERAL DEFENDER, MDFL
s/ Sabra M. Barnett
Sabra M. Barnett, Esq.
Florida Bar No. 1058792
Assistant Federal Defender
200 West Forsyth Street, Suite 1240
Jacksonville, FL 32202
Telephone: (904) 232-3039
Fax: (904) 232-1937
Email: sabra barnett@fd.org

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 3rd day of March 2025, a true copy of the
foregoing was served by electronic notification to Kevin Frein, Office of the United
States Attorney.
s/ Sabra M. Barnett
Sabra M. Barnett, Esq.

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EXHIBIT 1- Letters of Support
and Video of Grandfather

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The Honorable Judge Wendy W. Berger
U.S. District Court, Middle District of Florida
300 North Hogan Street
Jacksonville, FL

Dear Judge Berger,
My name is Nichol Rogers, and I am the mother of Crystal Denean Harvell. I am writing this
letter to respectfully ask for your compassion and leniency regarding my daughter’s case.
I gave birth to Crystal on July 18, 1987, when I was just 16 years old. With the support of my
parents, I was able to provide her with a safe and loving home. When Crystal was around two years old,
I met the man she has called “Daddy” for most of her life. Crystal was never a major problem growing
up—she faced the usual teenage challenges but remained bright and dedicated to her education. At the
age of 16, she gave birth to her daughter, Cimone Harvell. My husband and I supported her as she
navigated the responsibilities of young motherhood, and Crystal always prioritized providing a loving
and stable home for her child.
Despite the pressures she faced as a young mother, Crystal remained focused on raising Cimone.
I am incredibly proud to say that Cimone broke the cycle of teenage pregnancy in our family—she
graduated high school and is now in her second year at Albany State University. This achievement is a
testament to Crystal’s dedication and unwavering support as a mother.
Our family has endured tremendous loss. On July 13, 2020, we lost my only son—Crystal’s
younger brother, Carlton. Their bond was incredibly close; she was like a second mother to him. His
passing devastated her, yet she stepped up to ensure his children, their mother, and our family were
supported during that difficult time. Crystal even took custody of his children before and after his death,
regularly traveling between Atlanta and Jacksonville to care for them.

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More recently, on July 7, 2024, I lost my mother. Crystal and my mother shared a special
relationship, and her passing placed another heavy burden on Crystal’s heart. Without hesitation,
Crystal moved permanently to Jacksonville to care for my 82-year-old father—a veteran and an
amputee—who had relied on my mother’s care for 48 years. With my own health challenges, including
lupus, and the responsibility of raising my two young grandchildren, Crystal’s presence and assistance
have been a blessing beyond words. She made the selfless decision to put her personal life aside to care
for her grandfather and support our family.
In addition to my existing health struggles, my doctors have recently discovered a mass located
between my kidney and spine. This diagnosis has added to the physical and emotional challenges I am
facing. Crystal’s presence is vital—not only as a caregiver for my father and grandchildren but also as a
source of emotional and physical support for me as I navigate these medical uncertainties. I truly do not
know how I would manage without her help.
Beyond her role as a caregiver, Crystal is also the spiritual anchor of our family. Her faith in God
is unwavering, and she continuously shares that faith with all of us. She regularly organizes fasts for our
family, sends Bible scriptures in our group texts, and encourages us to lean on God during difficult times.
Despite being younger than me, Crystal teaches me about God and has strengthened my own
relationship with Him. Her spiritual leadership brings comfort and hope to our household, especially as
we face the many challenges life has presented.
Our family is small but tightly bonded, and Crystal is an essential part of that foundation.
Despite the mistakes that have led her to this point, I believe with all my heart that she deserves a
second chance. I understand that her actions carry consequences, but I respectfully ask the court to
consider an alternative to incarceration. Crystal’s absence would leave a profound void, not only in my
life but in the lives of the loved ones who depend on her daily care and support.

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I am willing to do whatever it takes to ensure Crystal complies with any guidelines set by the
court. I am humbly asking for your mercy and leniency on behalf of my daughter.
Thank you for taking the time to read my letter. I deeply appreciate your consideration.

Respectfully,

Nichol L. Rogers

Jacksonville, Florida 32221-5622

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Briana Palmer

The Honorable Judge Wendy W. Berger
U.S. District Court, Middle District of Florida
300 North Hogan Street
Jacksonville, FL 32202
Dear Judge Berger,
My name is Briana Palmer, and I am the mother of Cameron and Camilla, who are the niece and
nephew of Crystal Harvell. I had these children with her brother, Carlton Rogers. I am 27 years old
and currently work as a Customer Service Representative in a call center.
I am writing this letter on behalf of Crystal because, despite everything our families have gone
through, she has always remained neutral, understanding, and fair. I have known Crystal for over a
decade, and I will never forget the time when I had to live with her. At that time, it was me, Carlton,
our two kids, Carnisha with her two kids, and Crystal with her daughter, all living together in a twobedroom apartment. Crystal worked tirelessly—during the day at Ovation Credit Services and at
night bartending at Ice Lounge. She worked seven days a week while none of us worked, but she
never complained. Even after working at the club until 5 a.m., she would still get up and attend
church on Sundays.
Crystal has always made sure everyone was okay. Even when her brother and I were not getting
along, she remained a supportive and caring big sister to me. When I lost custody of my children,
Crystal stepped in and took custody of all three of them without hesitation. The only times I have
seen her get upset were when we were not trying to do the right thing.
All of the kids love Crystal deeply. She consistently demonstrates that it is better to be part of the
solution rather than part of the problem. After her brother passed away—a loss that devastated her
—she still put herself last to ensure that everyone else was taken care of.
I wanted to share this with you to express the type of person Crystal is: selfless, hardworking, and
deeply committed to the well-being of those around her.
Thank you for your time and consideration.
Sincerely,
Briana Palmer

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Christal Scott

February 23, 2025

The Honorable Judge Wendy W. Berger
U.S. District Court, Middle District of Florida
300 North Hogan Street
Jacksonville, FL 32202

Dear Judge Berger,
I am writing this letter in support of my good friend Ms. Crystal Harvell as you consider her sentencing. I
hope to provide you with additional information about her character and background, which may assist
you in making an informed decision.
My name is Christal Scott. I am a 43-year-old makeup artist, and I have been in my profession for 15
years. I have known Ms. Harvell for 12 years and have had regular contact with her throughout this time.
She is a very close friend of mine whom I consider to be family.
I am aware that Crystal pleaded guilty to a federal charge. I do not wish to reduce or excuse her actions.
I was extremely shocked and disappointed when I learned of her charges because this does not align
with the person I know and have grown to love. From our numerous conversations, I believe she takes
full responsibility for her actions, is extremely remorseful, and deeply regrets them. She feels as though
she has tarnished her name and worries that it may affect her daughter, Cimone, who is currently in
school for law and aspires to become a federal prosecutor.
Throughout the time I have known Crystal, she has consistently demonstrated kindness, selflessness,
and genuine concern for others. When my father passed away, she was there for me and my family,

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offering us all the support and love she could muster. I have seen her help her family and friends even
while struggling with her own challenges, including depression and exhaustion from working multiple
jobs. Despite her own burdens, she has taken on the responsibility of caring for her child, her siblings'
children, and her siblings themselves, all while maintaining her generosity toward others.
One of the qualities I admire most about Crystal is her unwavering faith in God. She incorporates her
faith into her daily life and shares it with those around her in a gentle, supportive manner. Even in the
face of hardship, she keeps a smile on her face, continues to joke, and remains steadfast in her belief
that "God will work everything out."
A recent example of her selflessness is how she ended her relationship, packed up her belongings, and
moved back to Jacksonville to assist her grandfather after her grandmother passed away in July. She
takes him to all his VA and medical appointments and is his primary source of support. Her dedication to
her family is a testament to her caring and responsible nature.
I respectfully ask that you consider Ms. Harvell's character, her acceptance of responsibility, and her
genuine remorse when determining her sentencing. I am confident that she is ready to rebuild her life,
continue to be a positive influence in the community, and remain a steadfast support for her
grandfather and daughter.
Thank you for your time and consideration.
Sincerely,
Christal Scott

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Damonte Paige

February 23, 2025
The Honorable Judge Wendy W. Berger
U.S. District Court, Middle District of Florida
300 North Hogan Street
Jacksonville, FL 32202
Dear Judge Berger,
I am writing this letter in support of Crystal Harvell regarding her upcoming sentencing. I want to
share my perspective on the type of person Crystal is and provide insight into her character beyond the
charges she has pleaded guilty to.
My name is Damonte Paige. I am 29 years old and from Los Angeles, California. I have owned a
dropshipping company for the past five years. I have known Crystal for the same amount of time, having
met her while she was starting a hair company and boutique for herself and her daughter.
I am aware that Crystal has pleaded guilty to a federal charge. From the conversations I have
had with her, it is clear that she is extremely remorseful for her actions and takes full accountability for
them.
I want to highlight the person Crystal is outside of her legal situation. I met her on the day her
brother went missing and was on the phone with her when he was found. I vividly remember how she
immediately gathered his children—for whom she had custody—and found a way to Florida to be with
her family. Throughout that time, her main concern was for her parents and sister. She blamed herself
for not being there and felt she could have saved him, vowing to take care of his children. This
selflessness stood out to me because, despite her own pain, she prioritized the well-being of those
around her.

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Crystal has also shared with me how difficult her experiences in Jacksonville have been. She has
endured significant hardships, including being sexually assaulted, surviving a drive-by shooting, and
becoming a teenage mother. Despite these challenges, she chose to return to Jacksonville without
complaint to care for her grandfather. Her resilience and dedication to her family are qualities I deeply
admire. Additionally, Crystal has a strong relationship with God and consistently emphasizes the
importance of faith in our lives.
In conclusion, I wanted to offer my support for Crystal Harvell and provide you with a fuller
picture of the compassionate, selfless, and accountable person she is. Thank you for taking the time to
read this letter and for considering my perspective.
Sincerely,
Damonte Paige

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Fredericka Milner

Jacksonville, FL 32210
02/19/2025

The Honorable Judge Berger

U.S. District Court, Middle District of Florida
300 North Hogan Street
Jacksonville, FL 32202

Dear Judge Berger,

I am writing to respectfully provide the court with additional insights regarding Ms.
Harvell in relation to her upcoming sentencing hearing. It is my sincere hope that
this letter will contribute to a more comprehensive understanding of her character
and the significant steps she has taken to acknowledge her actions and accept
responsibility.

My name is Fredericka Milner, and I reside in Jacksonville, Florida. I am 45 years old
and live with a disability. I have had the privilege of knowing Ms. Harvell for the past
10 years, during which time I have observed her character and the depth of her
compassion and support.
When I learned of Ms. Harvell's guilty plea to a federal charge, I was genuinely taken
aback. Knowing her as I do, I felt a deep disappointment upon hearing of her actions,
which I fully recognize to be both criminal and wrong. It is of utmost importance to
me to emphasize that I do not wish to minimize her conduct or shift blame. We all
make mistakes in life, and Ms. Harvell has openly acknowledged hers,
demonstrating a sincere commitment to personal growth and change.
Our relationship has flourished over the years, particularly through her bond with
my daughter. Ms. Harvell has truly become part of our family. There is nothing I
wouldn’t feel comfortable asking of her. She has consistently gone above and
beyond to support me during challenging times, especially when I faced financial
and health-related difficulties. For instance, during a particularly trying period, she
graciously provided meals and financial assistance for my medications and bills,
helping me navigate unforeseen circumstances.

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A specific instance that exemplifies her character occurred when my daughter was
away, and I experienced a medical emergency that required hospitalization. Ms.
Harvell took it upon herself to visit me, ensuring I had everything I needed for my
recovery. This act of kindness highlighted her empathy, loyalty, and selflessness—
qualities that define who she is as a person. She consistently puts the needs of
others before her own, which is a rare and admirable trait.

In my personal opinion, despite her recent actions, Ms. Harvell is fundamentally a
good person. I have witnessed her compassion extend beyond our family; she has
devoted herself to caring for her nieces and nephews, providing them with a loving
home and stability. Following the passing of her grandmother, she selflessly moved
to Florida to care for her grandfather, prioritizing his well-being over her own
personal circumstances. She has also taken in her niece and nephew, offering them
support without expecting anything in return.
While we all experience lapses in judgment, I firmly believe that these moments do
not define Ms. Harvell as an individual. Her actions throughout our relationship
have led me to see her potential to be a productive member of society moving
forward.

Moreover, I would like to highlight that Ms. Harvell has expressed profound remorse
for her actions and is dedicated to making amends. She is acutely aware of the
consequences of her choices and is determined to learn and grow from this
experience.
Thank you for considering this letter as part of your deliberation process. I trust it
provides you with valuable insight into Ms. Harvell's character and the person I
know her to be.
Sincerely,

Fredericka Milner

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Princess Bunch
February 22, 2024
The Honorable Judge Wendy W. Berger
U.S. District Court, Middle District of Florida
300 North Hogan Street
Jacksonville, FL 32202
Dear Judge Berger,
My name is Princess Bunch, and I am writing this letter on behalf of my friend Crystal Harvell in
hopes that it may assist in the decision process for her sentencing.
I currently reside in Atlanta, Georgia, where I work as a certified nursing assistant and also own a
clothing boutique. I am a 29-year-old single mother of three children. I have known Crystal for
approximately seven years, and when I learned about the charges she pled guilty to, I was extremely
shocked. Despite the circumstances, I made sure not to judge her for her mistakes. Crystal is a very
giving and helpful person—the kind of person who would give you the clothes off her back—which
made it difficult for me to understand how this situation occurred.
I first met Crystal in 2018 under challenging circumstances. I had recently moved to Atlanta.
The person I was staying with was mistreating me and my son. Upon learning of my situation, Crystal
immediately offered us a place to stay. Even though we were strangers, she welcomed me and my child
into her home without asking for anything in return. At the time, she was working at Xfinity and a
bar called Lacura. Despite her busy schedule and having her own daughter to care for, she made
room for us in her two-bedroom apartment. In return, I would help by taking her daughter, Cimone,
to and from school. Her generosity during such a vulnerable time in my life is something I will never
forget.
Throughout the years, I have continued to witness Crystal's selflessness. During the COVID-19
pandemic, she traveled to Florida to assume custody of her brother's two children, as well as his
partner's other child. She also took in her sister's children because she believed they would be safer with
us. Despite the fear and uncertainty we all faced during that time, Crystal always put others before
herself—volunteering to go out for groceries and ensuring we had everything we needed to stay safe
and healthy.
Crystal is also a deeply spiritual person who has consistently shared her faith in God and the
importance of giving back to the community. I know she is ashamed and regrets the decisions that led to
her current situation. She often expresses how none of it was worth it, especially given her role as the
full-time caregiver for her grandfather. The thought of leaving him, particularly after he lost his leg and
his wife, weighs heavily on her. She frequently speaks about how she feels she has let her family down.
Despite the hardships she has faced—including being a survivor of gun violence and sexual
assault, raising a child on her own, and losing her brother—Crystal remains compassionate and
generous. She battles anxiety and depression, yet she continues to lift herself up to help others.

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Your Honor, Crystal is genuinely a good person who made some bad decisions. I could share
countless stories about her kindness and the positive impact she has had on those around her. I
respectfully ask that you consider her character and the good she has done in this world when making
your decision regarding her sentencing.
Thank you for taking the time to read this letter.
Sincerely,
Princess Bunch

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Feb.20 ,2025

The Honorable Judge Wendy W. Berger
U.S. District Court, Middle District of Florida
300 North Hogan Street
Jacksonville, FL

Dear Judge Berger
I am writing this letter in support of my cousin Crystal Harvell and the sentencing that you are
imposing on her for the federal charges she pled guilty to. I would like to tell you more about her
character and the things she has done and more about where she comes from.
My name is Santisha Meeks and i am 38 years old, a single mother of 3 daughters from
Jacksonville Florida. I have been a cosmetologist for the last 20 years. I have known Crystal all of my life,
our mothers are sisters and we are cousins, but we were raised as sisters.
I'm very shocked about the charges that Crystal pled guilty to and I’m disappointed in her
because this is not who she is. I've had alot of talks with her about this situation and I know how
disappointed in herself she is. I've seen Crystal face alot in life but she always seems to bounce back. I
witnessed the things she went through after she was sexually assaulted and it was a turning point in her
life and she was so ashamed and embarrassed she started running away to run from that because she
blamed herself and she dealt with alot of judgement from our family as well. We were kids so i didn't
know how to help.
I can remember her being in the hospital by herself at 16 when she had her daughter and
wishing i was there. I also remember when she was 18 and she let her ex-boyfriend convince her to take

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a drug charge for him. I remember being in the court room with her and the Judge telling her not to
mess her life up behind this man because they knew what she was doing but it was just me and her
there, two 18 year olds.
I remember when she was 20 a week before she turned 21 her being shot in a driveby in front of
her apartment, then i can remember NOBODY going to see her, give her flowers or staying the night
with her and her crying about it.
I said all these things to let you see the things she's dealt with in life alone by herself with no
support. None of it made her cold or heartless because after this I still have seen Crystal take care of her
brother and sister and their kids. I’ve watched her always work multiple jobs at a time because she was
taking care of so many people. I've watched my cousin riding down the street, stop at Popeyes, buy a
family meal, go back down the street and give it to a homeless person and say God put that on my heart.
When she came back from Atlanta to take care of our Grandpa she also took in my 14 year old
and said i know you dont need her to be here but i know her being here could possibly help you. I had
my daughter come back and she started to run away, and out of my family Crystal is the only one who is
truly concerned and was ready to pass out fliers, call the police with me and be by my side. No matter
what one does to her she forgives and still offers a helping hand. I tell her i couldn't forgive them for
that and she lives by God always forgives us for our sins so who are we to not forgive others. She is a
single mother who has been through so much in her life and she still gives all she can. She is a person
that will help you carry your cross and still carry hers by herself. My Grandfather depends solely on
Crystal. We have family but to be honest nobody is willing to sacrifice themselves the way she is. I’m
begging you please consider her Character and background when you consider her sentencing.

Thanks for your time,
Santisha Meeks

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February 22, 2025

The Honorable Judge Wendy W. Berger:

I am writing to show support and good character in regards to Crystal Harvell. As we know
she has made some choices that weren’t of the best, and although this has happened she still
remains a good person as a whole. As human beings, everyone makes mistakes but it is most
important that we learn from them.

My name is Shaniece Ross. I am a 32 year old single mother of 2, one boy (10) and one
girl (13). My children and I live in Dacula , GA. I also have my mother living with me to help
support me in raising my children. I have my own catering company of 8 years by the name of
Delicious Bliss where i specialize in pharmaceutical catering and events of all sorts. Crystal
Harvell has been a good reliable friend of mine for about 7 years now and her daughter Cimone
Harvell I consider nothing less than my niece. I even assisted in helping Crystal get Cimone her
first car!

Crystal has pleaded guilty to her federal charge, which I know means that she is accepting
full responsibility for her actions. Hearing that she has to deal with this has weighed so heavy on
my heart. I try to be there the best way I can for her mentally, emotionally, and spiritually as I
know this can be hard on her and everyone around her. Crystal plays such a big role in my life
and the lives of many others. So many of her family and friends rely on her for support. She is a
full time caregiver for her grandfather, who she gave up her life in Atlanta to move to Florida to
take care of him when her grandmother passed. I’ve also seen her take care of her sister and
her sister’s children. Crystal has had custody of her deceased brother’s children and was a full

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time care giver for them as well. There is not a time that I can recall that I needed something
and Crystal was there for me however she could be.

There is never any excuse good nor bad for committing a crime of any sort, and I know
that Crystal has an understanding of that. She has taken full responsibility for her actions and is
ready to accept her consequences however they may be given to her. I do hope that you will
consider her personal character when deciding on what that consequence shall be. She is a
kind hearted, god fearing woman and plays a big role in supporting so many people. Her
daughter Cimone is a student in college and she needs her mother as college can be so
challenging in any young woman’s life.

Judge Berger I hope that my letter has helped shed some light on the good characteristics
of my close friend Crystal Harvell. Like I’ve already stated there is never any excuse for
committing a crime and I’ve spoken with Crystal many times and she knows and understands
that. First steps to recovery are knowing and accepting you did wrong. Second is accepting the
consequences, and lastly is moving forward being a better person. I stand behind my friend fully
and completely as she continues through this journey of dealing with the consequences of her
actions. I appreciate you taking the time to hear me out.
Best Regards

Shaniece Ross

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Twymiria Walker
Feb. 20, 2025
The Honorable Judge Wendy W. Berger
U.S. District Court, Middle District of Florida
300 North Hogan Street
Jacksonville, FL
Dear Judge Berger,
My name is Twymiria Walker, and I am a 33-year-old single mother residing in Atlanta, Georgia. I work as
a lash technician. I am aware that Crystal has pled guilty to a federal charge, and I am not wri�ng to
dismiss or minimize the seriousness of those charges. Instead, I am wri�ng to share with you the person I
have come to know over the past seven years.
During the �me I have known Crystal, I have witnessed her do amazing and selfless things. She is a
loving, caring, and deeply family-oriented person. As a single mother herself, she has always priori�zed
the well-being of her family. A�er the passing of her brother, she stepped up without hesita�on to care
for his children, demonstra�ng her unwavering commitment to family. Crystal is the kind of person you
can turn to when life becomes overwhelming. In my own difficult �mes, she has shared scriptures with
me, offering comfort and hope. Her faith in God is the founda�on of her life, and she relies on that faith
in all that she does.
I have personally experienced Crystal's kindness and generosity. During a challenging period in my life,
she opened her home to me without expec�ng anything in return. She even helped me prepare for job
interviews and paid for my business license when I was unable to afford it. I will never forget how she
introduced me to a church live stream (wo�atl.com) when I was feeling lost and depressed. She became
a member of that church and consistently encouraged me to watch the service every Sunday, always
checking in to see if I had received the message.
I also accompanied Crystal to Florida when her grandmother passed away. When she saw that her
grandfather was struggling and needed her support, she made the decision to move back to Florida from
Atlanta without hesita�on. This is just one example of how deeply she cares for those she loves and how
willing she is to sacrifice her own comfort to be there for others.
I know that Crystal is genuinely remorseful for her ac�ons. I respec�ully ask that you consider the person
she truly is beyond the mistakes she has made. Crystal has posi�vely impacted my life and the lives of
many others. I believe she has so much more to offer her family and community if given the opportunity
to con�nue building others up, as she has done for me.
Thank you for taking the �me to read this leter and for considering my words.
Sincerely,
Twymiria Walker

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Video provided on removable
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EXHIBIT 2- Emory Medical Records
(filed under seal and provided to Court and
parties)

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EXHIBIT 3- Message from Brother and
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