Government's Sentencing Memorandum — United States v. Dean Tran, No. 24-CR-10178

Summary

The Government's Sentencing Memorandum, Document 155 in Criminal No. 24-CR-10178-FDS, United States v. Dean Tran, filed January 28, 2026, in the U.S. District Court for the District of Massachusetts. The United States requests a sentence of 18 months in prison, 3 years of supervised release and a fine of $25,000. It agrees with the Probation Office's offense level of 12 and states an advisory guideline range of 12-18 months. The memorandum alleges that Tran obstructed justice by lying to federal agents about a job offer letter tied to his sister and co-defendant, Tuyet Martin, and describes a January 10, 2026 letter to the First Circuit as Exhibit A. It is signed by John T. Mulcahy for United States Attorney Leah B. Foley.

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       Case 1:24-cr-10178-FDS          Document 155        Filed 01/28/26     Page 1 of 6




                             UNITED STATES DISTRICT COURT
                              DISTRICT OF MASSACHUSETTS


 UNITED STATES OF AMERICA

                                                  CRIMINAL No. 24-CR-10178-FDS
        v.

 DEAN TRAN

        Defendant


                    GOVERNMENT'S SENTENCING MEMORANDUM

       Now comes the United States and requests a sentence of 18 months in prison; 3 years of

supervised release; and a fine of $25,000. Such a sentence is consistent with the sentencing

factors enumerated under 18 U.S.C. § 3553(a).

                               GUIDELINES CALCULATION

       The government agrees with the United States Probation Office’s calculation of

defendant Dean Tran’s offense level as 12. (PSR, ¶ 53). Tran’s advisory guideline range is 12-

18 months. The base offense level is 14. (PSR, ¶ 45). The offense level is reduced by 2 levels

for acceptance of responsibility. (PSR, ¶ 52).

                                             FACTS

       The government agrees with the factual recitation in the PSR. (PSR, ¶¶ 8-35). As

described therein, Tran obstructed justice by lying to federal agents about a phony job offer and

job offer letter from his sister and co-defendant, Tuyet Martin, at her New Hampshire-based food

production company. Before Tran lied to agents about the letter and job offer, he had used the

letter/job offer to defraud unemployment authorities and obtain benefits that he was not entitled

to receive. In addition, Tran was so intent on making sure he unlawfully received unemployment
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benefits that he instructed Martin on at least two occasions to provide misleading information to

authorities if she were questioned about the letter and job offer.

       In April 2021, Tran’s pandemic unemployment benefits were suspended. (PSR, ¶¶ 14-

15). Within a few days, Tran contacted his sister to create the sham job offer to get his benefits

reinstated. (PSR, ¶ 17). Martin agreed to the scheme and drafted a job offer letter that she

emailed to Tran. (PSR, ¶ 17). Tran significantly edited the letter and then finalized it, signing

Martin’s name to the letter and submitting it to unemployment officials. (PSR, ¶ 20). Tran even

instructed his sister on what to say if she were questioned about the letter by unemployment

officials, “[a]lso, I’m not sure if they will call you to substantiate, but if they do, say my resume

came to you from an acquaintance, interviewed in December and offer made in January. I

couldn’t accept the offer due to child care issues.” (PSR, ¶ 20).

       Unemployment department official D.L. then conducted an appeals hearing with Tran

under oath. (PSR, ¶ 23). During the hearing, Tran misled D.L. by falsely claiming that he had

submitted his resume to an “acquaintance” for the job at the sister’s company. (PSR, ¶ 23).

There is no evidence Tran submitted any resume to Martin or anyone else at her company. Tran

also said he had a “discussion with HR,” but Martin’s business did not have a Human Resources

Department as Martin handled all personnel issues herself. After the hearing, just as he had done

in the email to Martin before the hearing, Tran again gave specific instructions by text to his

sister about what story to give if she were asked about the letter. (PSR, ¶ 25).

       When Tran was confronted about the job offer letter during his interview by federal

agents, instead of coming clean about the true nature of the letter and job offer, Tran double

downed. He claimed that Martin was the author of the letter (when he had substantially revised




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it) and also falsely stated that she had signed the letter, when he had signed her name to the

letter. (PSR, ¶¶ 29-30).

                                         3553(a) FACTORS

          The Court should sentence Tran to a substantial period of incarceration because lying to

federal agents and obstructing justice are serious offenses. Just as Tran thought he could get

away with lying to unemployment officials to keep getting unemployment benefits (even while

he was actually working), Tran thought he could derail the federal investigation into his fraud

schemes. The government’s sentencing recommendation is justified based on the series of

events stemming from Tran’s lies to federal agents, including getting his sister and co-defendant

involved in his criminal activity and causing agents to seek to verify the accuracy of the job offer

letter.

             A. Tran Continues His False Narrative In Letter to Appeals Court

          And Tran still has not learned his lesson as is obvious from a letter he recently wrote.

See Exhibit A (the “Appeals Letter”). On January 10, 2026, Tran wrote a letter to the United

States Court of Appeals for the First Circuit in support of his pending appeal regarding his

convictions for unemployment and tax fraud schemes. Tran’s letter follows the same false

narrative from his trial on the tax and unemployment fraud. Instead of showing any contrition or

self-reflection on Tran’s part, Tran essentially denies committing unemployment and tax fraud,

and instead blames others and baselessly accuses government agents of wrongdoing. It is

astounding that even after receiving a sentence of 18 months and spending approximately 10

months in prison, Tran has still not learned his lesson and continues to deny his crimes even in

the face of convictions by a jury of his peers and a significant sentence by this Court.




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       The theme underlying Tran’s letter is that everyone was out to get him and all of his legal

problems were someone else’s fault and not his. At trial, Tran completely denied responsibility

and even perjured himself to avoid accountability. The Appeals Letter is full of the same vitriol

that characterized Tran’s response during his first trial. Tran blames individuals like D.L. and

J.M. for his unemployment fraud even though Tran is who orchestrated a fake job offer from his

sister to fraudulently earn unemployment benefits. Tran even goes so far in the Appeals Letter

as to claim that D.L. perjured herself at trial. In fact, Tran, not D.L., is who committed perjury at

trial by littering his testimony with false statements. D.L. flatly rejected Tran’s assertion that she

gave him the green light to commit fraud in an off-the-record conversation. Tran received an

obstruction of justice enhancement at sentencing and the jury clearly rejected his testimony in

convicting him.

       Tran also cast aspersions on agents from the FBI and Department of Labor, but it was

Tran, not them, who lied and told falsehoods even as he knew he was under investigation and

agents had just executed a search warrant at his house. It is telling that Tran apparently still has

not learned his lesson and accepted the truth of his crimes. That is why the government is

requesting a significant period of incarceration to demonstrate the severity of his crimes and

punish him for his utter lack of self-accountability.

           B. Tran Feels Entitled To Break The Law

       Tran’s background and history provide no justification for his crimes. Tran overcame

significant odds to graduate from Brandeis University and attain several white-collar positions in

private industry. Tran also had a promising political future until his numerous ethical breaches

as a State Senator ended his political career. Tran is under indictment in Suffolk Superior Court

for abusing his official position as a State Senator to gain unwarranted privileges arising from



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using his staff for his reelection campaign. Tran’s crimes were not motivated by desperation.

The PSR describes Tran’s substantial assets totaling approximately $2.2 million, and include two

residences, a Fidelity 401K valued at approximately $943,000 and stocks held by his wife valued

at approximately $192,000. (PSR, ¶ 100). Nor were Tran’s crimes an accident or a mistake.

Instead, they were motivated by a sense of entitlement. Tran lied to agents and attempted to

obstruct their investigation because he felt entitled to do so -- just as Tran felt entitled to use his

Senate Staff to conduct campaign work for him on government time, and then lied and misled his

Senate colleagues when he was called to task about it.

        Finally, deterrence is an important factor here. It is essential for government agents to be

able to conduct investigations without any obstacles to getting to the facts. A substantial period

of incarceration deters others from interfering in investigations and helps to assure that agents

can do their jobs and enforce our laws. If people are not deterred from lying and obstructing

justice, our criminal justice system would be in peril. Such a penalty also promotes respect for

the law. Specific deterrence is also important because a low-end guideline sentence for Tran’s

last case was apparently not enough to put him in line. A severe penalty is called for to avoid

him again using fraud schemes and interfering in investigations for his own selfish motives.

                                 [CONTINUED ON NEXT PAGE]




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                                         CONCLUSION

       For those reasons stated above, the government requests a sentence of 18 months in

prison; 3 years of supervised release; and a fine of $25,000.

                                              Respectfully submitted,

                                              LEAH B. FOLEY
                                              United States Attorney


                                      By:     /s/ John T. Mulcahy
                                              John T. Mulcahy
                                              Lauren Maynard
                                              Assistant United States Attorneys
                                              617/748-3641



                                CERTIFICATE OF SERVICE

I hereby certify that this document filed through the ECF system will be sent electronically to the
registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies
will be sent to those indicated as non-registered participants .

                                              /s/ John T. Mulcahy
                                              John T. Mulcahy
                                              Assistant United States Attorney


Date: January 28, 2026




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