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Home Source documents Court filing — No. 1:22-cr-20360 (Dkt. 84, S.D. Fla.)

Court filing — No. 1:22-cr-20360 (Dkt. 84, S.D. Fla.)

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Case 1:22-cr-20360-RNS Document 84 Entered on FLSD Docket 02/15/2024 Page 1 of 2




                              UNITED STATES DISTRICT COURT
                              SOUTHERN DISTRICT OF FLORIDA


                                 CASE NO. 22-20360-CR-SCOLA



  UNITED STATES OF AMERICA,
            Plaintiff,
  v.

  JAVIER LAZO-CABRERA,
              Defendant.
  _____________________________/


               OBJECTION TO PRE-SENTENCE INVESTIGATION REPORT

         The Defendant, JAVIER LAZO-CABRERA (“Lazo-Cabrera”) by and through the

  undersigned counsel, files these Objection to the Pre-Sentence Investigation Report (“PSI”) and

  hereby states his objection to the Department of Probation’s Pre-Sentence Investigation Report as

  follows:

         Lazo-Cabrera objects to paragraph 57, which states that “he is responsible for a loss
  totaling $5,634,026. Because the loss amount is more than $3,500,000 but not more than
  $9,500,000, the offense level is increased by 18 levels.” However, the loss amount should
  be consistent with his plea agreement entered on December 21, 2023, which reflects the
  loss amount to be more than $1,500,00.00 but no more than $3,500,00.00, resulting in a
  16-level increase, not 18 levels as indicated in the PSI.

         WHEREFORE, the Defendant, JAVIER LAZO-CABRERA, respectfully requests that

  this Honorable Court grant his Objection to Pre-Sentence Investigation Report and impose a

  sentence in accordance herewith.
Case 1:22-cr-20360-RNS Document 84 Entered on FLSD Docket 02/15/2024 Page 2 of 2




                                    CERTIFICATE OF SERVICE

         I HEREBY CERTIFY that a true and correct copy of the above and foregoing was
  furnished electronically to Joseph Egozi, Esq., AUSA, Office of the United States Attorney
  this 15th day of February 2024.

                                            By: s/ Michael Mirer
                                               MICHAEL MIRER, ESQ.


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