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.