Government's Consolidated Sentencing Memorandum — United States v. Lawrence Nathanial Harris (Document 146)

Summary

The Government's Consolidated Sentencing Memorandum in United States v. Lawrence Nathanial Harris, Criminal Nos. DLB-23-cr-183 and DLB-23-cr-376, in the U.S. District Court for the District of Maryland, Document 146, filed October 23, 2025. The government asks the Court to sentence Harris to a total of 228 months' incarceration, supervised release of three years, restitution of $952,225 to the Maryland Department of Labor and a $500 special assessment. It describes two matters: possession of a machine gun, additional firearms and marijuana in DLB-23-cr-183, and an unemployment insurance conspiracy in DLB-23-cr-376 that it says began in or about January 2021. The memorandum states that Harris pleaded guilty on August 7, 2025, to Count One and Count Seventeen in DLB-23-cr-376.

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“Government's Consolidated Sentencing Memorandum — United States v. Lawrence Nathanial Harris (Document 146).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-8-23-cr-00376-dkt-146-d-md-5225f43ed8/, SHA-256 60baa2e38c137db962299f5e196942d3abfa50269e7176b9bb23de139bb7d6d1.

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Case 8:23-cr-00376-DLB Document 146 Filed 10/23/25 Page 1 of 27

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA *
*
v. * CRIMINAL NO. DLB-23-cr-183
* CRIMINAL NO. DLB-23-cr-376
LAWRENCE NATHANIAL HARRIS, *
*
Defendant. *
*
*******

GOVERNMENT’S CONSOLIDATED SENTENCING MEMORANDUM

The United States of America, by and through Kelly O. Hayes, United States Attorney for

the District of Maryland, and Harry M. Gruber, Christopher Sarma, and Joseph L. Wenner,

Assistant United States Attorneys, moves this Court to sentence Defendant Lawrence Nathanial

Harris (“Harris”) to the following:

• A total period of 228 months’ incarceration in the Bureau of Prisons (“BOP”), consisting
of:
o 144 months as to Count One of the Indictment in DLB-23-cr-376 (Conspiracy to
Commit Wire Fraud) and Count Two of the Superseding Information in DLB-23-
cr-183 (Possession with Intent to Distribute a Controlled Substance);
o the 120-month statutory maximum, concurrent, as to Count One of the Superseding
Information in DLB-23-cr-183 (Possession of a Machinegun);
o 24 months on Count Seventeen of DLB-23-cr-376 (Aggravated Identity Theft),
consecutive to all other terms; and
o 60 months on Count Three of the Superseding Information in DLB-23-cr-183
(Possession of a Firearm in Furtherance of the Drug Trafficking Crime),
consecutive to all other terms;

• Supervised release of three years on all counts, except Count Seventeen in DLB-23-cr-
376, which has a maximum period of supervised release of one year; and

• Restitution of $952,225 to the Maryland Department of Labor and a $500 special
assessment. 1

1
The government’s restitution calculation is set forth infra at 25. The government
further asks the Court to impose forfeiture consistent with the government’s preliminary orders of
forfeiture, which are being separately submitted.
Case 8:23-cr-00376-DLB Document 146 Filed 10/23/25 Page 2 of 27

TABLE OF CONTENTS
BACKGROUND ............................................................................................................................ 3
I. Procedural History .......................................................................................................... 3
II. Harris’s Criminal Conduct ............................................................................................. 4
A. Harris’s Possession of a Machine Gun, Additional Firearms, and Intended Distribution
of a Controlled Substance (DLB-23-cr-183) .................................................................. 5
B. The Unemployment Insurance Conspiracy (DLB-23-cr-376) ...................................... 10
III. Sentencing Guidelines .................................................................................................. 12
IV. Section 3553(a) and the Appropriate Sentence ............................................................ 14
A. The Nature and Circumstances of the Offenses ............................................................ 15
B. Harris’s History and Characteristics ............................................................................. 21
C. Adequate Deterrence and Protection of the Public ....................................................... 22
D. The Need to Avoid Unwarranted Sentencing Disparities ............................................. 24
V. Restitution .................................................................................................................... 25
CONCLUSION ............................................................................................................................. 26

2
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BACKGROUND
I. Procedural History

On May 18, 2023, a federal grand jury in the District of Maryland indicted Harris on one

count of Felon in Possession of a Firearm and Ammunition, in violation of 18 U.S.C. § 922(g)(1).

Indictment, United States v. Harris, ECF No. 1, DLB-23-cr-183 (D. Md. May 18, 2023). Following

his arrest in September 2023, Harris pleaded not guilty and consented to pre-trial detention. Id.

ECF Nos. 31 & 33.

In October 2023, a grand jury in the District of Maryland returned an indictment against

Harris, Ahmed Hussain (“Ahmed”), Zakria Hussain (“Zakria”), Terry Chen (“Chen”), Bryan

Ruffin (“Ruffin”), and Kiara Smith (“Smith”), charging them with multiple criminal offenses,

including conspiracy to commit wire fraud, in violation of 18 U.S.C. § 1349 (Count One).

Indictment, United States v. Harris et al., ECF No. 1, DLB-23-cr-376 (D. Md. Oct. 24, 2023). The

Indictment also charged Harris with aggravated identity theft, in violation of 18 U.S.C. § 1028A

(Count Seventeen). Id. Harris remained detained.

In December 2023, the grand jury returned a superseding indictment in DLB-23-cr-183,

charging Harris with three additional counts, including one count of Possession with Intent to

Distribute a Controlled Substance, in violation of 21 U.S.C. § 841(a)(1) (Count Three); one count

of Conspiracy to Distribute a Controlled Substance, in violation of 21 U.S.C. § 846 (Count Four);

and one count of Possession of a Firearm in Furtherance of a Drug Trafficking Crime, in violation

of 21 U.S.C. § 924(c) (Count Five). DLB-23-cr-183, Superseding Indictment, ECF No. 57. On

November 26, 2023, Harris moved for pre-trial release. Id. ECF No. 54. The Court held a bond

review hearing on January 5, 2024 and ordered Harris detained pre-trial. Id. ECF No. 64.

On July 24, 2025, the grand jury returned a second superseding indictment against Harris

in DLB-23-cr-183, charging him with a total of five counts: Felon in Possession of a Firearm and
3
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Ammunition, in violation of 18 U.S.C. § 922(g)(1) (Count One); Possession with Intent to

Distribute a Controlled Substance, in violation of 21 U.S.C. § 841(a)(1) (Count Two); Conspiracy

to Distribute a Controlled Substance, in violation of 21 U.S.C. § 846 (Count Three); Possession of

a Firearm in Furtherance of a Drug Trafficking Crime, in violation of 18 U.S.C. §924 (c)(1)(B)(ii)

(Count Four); and Opening, Using, and Maintaining a Drug-Involved Premises, in violation of 21

U.S.C. § 856(a)(1) (Count Five). Id. ECF No. 124.

In August 2025, the government filed a three-count superseding information in DLB-23-

cr-183, charging Harris with Possession of a Machinegun, in violation 18 U.S.C. § 922(o) (Count

One); Possession with Intent to Distribute a Controlled Substance, in violation of 21 U.S.C. §

841(a)(1) (Count Two); and Possession of a Firearm in Furtherance of a Drug Trafficking Crime,

in violation of 21 U.S.C. § 924(c). Superseding Information, Id. ECF No. 127.

On August 7, 2025, Harris pleaded guilty before this Court to Count One and Count

Seventeen in DLB-23-cr-376. ECF Nos. 118-120. At the same hearing, Harris also pleaded guilty

in DLB-23-cr-183 to Counts One, Two, and Three of the Superseding Information. Crim. No.

DLB-23-cr-183, ECF Nos. 131-33.

II. Harris’s Criminal Conduct

As detailed in the Plea Agreement and stipulated facts, Harris engaged in significant

criminal conduct with respect to two distinct criminal operations. The first was a marijuana

distribution effort, in which Harris possessed a machine gun, multiple additional firearms, and

hundreds of rounds of ammunition. The second was a sprawling conspiracy to steal real

individuals’ identities, exploit Maryland Department of Labor’s response to the COVID-19

pandemic, and defraud the Maryland unemployment insurance program of millions of dollars.

Harris’s intimate involvement in important aspects of both schemes, as well as the amount of loss

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he caused and sought to cause in the COVID-19 fraud, set him apart from his co-conspirators,

especially when considering his extensive criminal history.

A. Harris’s Possession of a Machine Gun, Additional Firearms, and Intended
Distribution of a Controlled Substance (DLB-23-cr-183)

i. October 26, 2022 Traffic Stop 2

On October 26, 2022, in broad daylight, law enforcement saw a dark Gray Porsche Macan

SUV (the “Porsche”) with heavily tinted windows and windshield. After confirming that the car

had fake temporary registration plates, law enforcement pulled over the Porsche.

Law enforcement approached the Porsche where Harris was the driver and sole occupant.

While speaking with Harris, law enforcement smelled burnt marijuana and ordered Harris out of

the Porsche. During a search of the Porsche, Harris told law enforcement, there “wasn’t nothing

illegal.” Nevertheless, law enforcement found several grams of suspected marijuana in the

Porsche. Law enforcement attempted to check the glovebox in the Porsche, but it was locked.

Upon request, Harris provided law enforcement the key fob to the Porsche so that law enforcement

could open the glovebox. Law enforcement found a Glock 27 Handgun loaded with a 30-round

magazine. A Glock Auto Switch was attached to the Glock 27 Handgun.

For the contraband found in the car, Harris pleaded guilty in the Circuit Court for Prince

George’s County and received a sentence of 5 years all but 18 months suspended. He was released

on October 6, 2023. DLB-23-cr-376, ECF No. 145 (“PSR”) at 23.

ii. November 16, 2022 Search Warrant at 4325 Delmar Avenue

2
The facts of the traffic stop come from a search warrant affidavit, which the Government
attached at DLB-23-cr-183, ECF No. 123-1. Harris has not contested the veracity of these
statements during the litigation.
5
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On November 16, 2022, law enforcement executed a residential search warrant at 4325

Delmar Avenue, Temple Hills, Maryland, which was a residence where Harris lived along with

co-defendant Ahmed Hussain and several other individuals. That residence is shown below.

Before entering the residence, police officers announced their presence. After they did so,

Harris threw a .380 caliber semi-automatic pistol model 42, manufactured by Glock Inc. as well

as a duffle bag full of marijuana from his bedroom window. Harris possessed the Glock in

furtherance of his drug-trafficking activities and possessed the marijuana with the intent to sell it.

A picture of the Glock lying outside Harris’s bedroom window is included below.

During the search of the Delmar Residence, law enforcement searched the attic to which

Harris had access. Harris knowingly had joint possession of the items recovered in the attic.

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Specifically, within the attic, law enforcement found a large black duffle bag containing 23 large,

heat-sealed bags. Each heat-sealed bag contained approximately one pound of marijuana. In total,

the black duffle bag had approximately 26 pounds of marijuana.

Law enforcement also found in the attic a large red duffle bag that contained seven large

bags of marijuana that weighed approximately one pound each. In total, the red duffle bag had

approximately 11 pounds of marijuana.

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Along with the 11 pounds of marijuana in the red duffle bag, law enforcement also found

the following weapons and accessories in the attic:

• Black Ruger AR-15 .556 Caliber, bearing serial number #855-95377.

• Black Chiappa PAK 9mm Rifle, #RON2025342.

• (1) Magazine for the Chiappa.

• (2) Fifty-Round AR Drum Mags (loaded).

• (2) Thirty-Round AR Magazines (loaded).

• (1) Masterpiece Arms 9mm “Mac 9”, Serial Number #Fl 5430, loaded with an extended
magazine containing approximately 38 rounds of ammunition.

• (1) .45 semi-automatic pistol, Model 21, bearing serial number BLEY949, which was
equipped with a full-auto sear switch, containing 24 rounds of ammunition.

Several photos of the firearms in the attic are below. The last two photos show the machinegun.

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Law enforcement later recovered a video from Harris’s phone that Harris took of himself

holding the Glock switch with a stack of cash. Exhibit 1 (Harris with Glock Switch) (Native

Exhibit). 3

B. The Unemployment Insurance Conspiracy (DLB-23-cr-376)

Beginning in or about January 2021, Harris worked with his co-conspirators to defraud the

Maryland Department of Labor (“MD-DOL”), multiple financial institutions, and identity theft

victims to obtain fraudulent unemployment insurance (“UI”) benefits. Harris’s fraud began at the

height of the pandemic, when Maryland and the United States had expanded access to

unemployment benefits and employed contractors through Company #1 to review an influx of UI

applications and administer benefits. Harris interacted to a significant degree with the co-

3
Law enforcement can identify Harris in this video, and other videos discussed below, through
Harris’s distinctive arm and hand tattoos.
10
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conspirators (Kiara Smith and Bryan Ruffin) who had insider access to the MD-DOL’s internal

databases through their employment with Company #1. Many of the communications occurred

between Smith, and later Ruffin, and Harris. Harris exploited the insider access to redirect

unemployment benefits meant for real people to their own bank accounts and to file fraudulent

benefit claims with the use of stolen identities. Harris has admitted that he personally participated

in claims resulting in over $550,000 in loss, but the government’s restitution calculation sets his

loss amount at almost twice that amount. Based on the claims tied to the various email addresses,

phone numbers, and identities that Harris admitted to using in his Statement of Facts, Harris was

personally involved in causing $952,225 in actual loss. See infra at 25.

In order to redirect and file fraudulent UI claims, Harris and his co-conspirators took

several coordinated and intricate steps. These included using their surreptitious access to MD-DOL

databases: (1) to change information on existing UI claims; (2) to make numerous false statements

regarding purported applicant’s identity, employment status, wages, and eligibility to fraudulently

inflate the amount of benefits received; (3) to both upload and approve certain documents in

support of UI claims; and (4) to remove MD-DOL’s internal fraud holds on certain UI claims and

certify weeks of unemployment for payment in the MD-DOL system, among other actions, all to

facilitate the payment of fraudulent UI benefits. Moreover, Harris and his co-conspirators ensured

that the fraudulent benefits flowed into bank accounts they controlled.

In this loose confederacy, Harris repeatedly took control of the Company #1 laptop and

ardently worked to file claims or submit false information to cause existing claims to fraudulently

pay out the most amount of benefit money. On multiple occasions, co-conspirators accused Harris

of: monopolizing the use of co-conspirator Smith’s Company #1 laptop for his own fraud, using

the wrong credentials to take off fraud holds, and generally interfering in his co-conspirators’ illicit

11
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use of the Company #1 laptop. Harris did this with the intent of maximizing his personal benefit.

As time wore on, Harris’s relationship with Smith obviously frayed, as reflected in his

messages in furtherance of the conspiracy. In 2022, Harris wrote: “Y’all be catering to her

(referencing Smith) like she sum god.” Harris’s residence became a haven not only for the firearms

and drugs involved in DLB-23-cr-183, but also the fraudulent use of the laptop. For example, in

April 2022, Ahmed wrote about using the Company #1 laptop for fraud at Harris’s residence,

writing: “Get us out the way every night when we at ur house on laptop.” By April 2022, Harris

was writing about how he should be entitled to use the laptop for fraud, writing: “I got da laptop

wit me till tomar nite,” “How many people in dis chat knew dat [relative of Zakria] and zak was

wit da laptop ina lab yesterday,” and “I let it be know I was gettin laptop.” Harris then focused on

working with Ruffin (whom he referred to as “[a]notha plug” to his co-conspirators) to gain illicit

access to MD-DOL’s internal system and direct fraudulent UI claims into bank accounts under his

and his co-conspirators’ control.

Messages show that Harris prepared and submitted a significant volume of fraudulent UI

claims. Typically, once Harris received false MD-DOL credentials, Harris would use his access to

personally alter the particular claims that real individuals had already made. Harris would then

alter the claimant’s contact information to his own, upload false documents (to help remove any

existing fraud flags) and back date to increase the amount of UI that claim would receive, then

alter the bank account where the UI funds would be deposited. The stipulation of facts illustrates

how Harris repeated this pattern over and over to hijack dozens of UI claims.

III. Sentencing Guidelines

The government agrees with the PSR calculations that the final offense level for the counts

without mandatory minimum sentences—Count One of DLB-23-cr-376 (Conspiracy to Commit

12
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Wire Fraud, 18 U.S.C. § 1349), Count One of DLB-23-cr-183 (Possession of a Machinegun, 18

U.S.C. § 922(o)), and Count Two of DLB-23-cr-183 (Possession with Intent to Distribute a

Controlled Substance)—following the applicable enhancements, grouping, the multiple count

adjustment, and acceptance of responsibility is 27. See DLB-23-cr-376, ECF No. 119 (“Plea

Agreement”) at 6-8; PSR at 16-19.

The underlying calculation for Count One in the Superseding Information in DLB-23-cr-

183, which groups with Count Two of the Superseding Information, represents a base offense level

of twenty (20), which is increased by (i) two (2) levels because the firearm was stolen; (ii) two (2)

levels because the offense involved three or more firearms; and (iii) four (4) levels because Harris

used or possessed the firearm in connection with another felony offense, resulting in an adjusted

offense level of twenty-eight (28). PSR at 17-18.

The underlying calculation for DLB-23-cr-376 represents a base offense level of seven (7),

with a fourteen (14) level increase due to losses that were more than $550,000, but less than

$1,500,000. In the plea agreement, the parties stipulated that the offense level should be increased

(i) by two (2) levels because the offense involved 10 or more victims; (ii) by two (2) levels because

the scheme involved sophisticated means, and Harris intentionally engaged in or caused the

conduct constituting sophisticated means; and (iii) by two (2) levels because the scheme involved

the use of an authentication feature, resulting in an adjusted offense level of twenty-seven (27). Id.

at 17.

Under the multiple count adjustment rules, two (2) levels are added to the adjusted offense

level of DLB-23-cr-183—the higher offense level of the two cases. Id. at 18. The government

agrees with the PSR that Harris should then receive a three-level reduction for timely acceptance

of responsibility. Id. at 18-19. This results in a total offense level of Harris’s Criminal History

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Category VI, the advisory Guidelines range for these counts is 130-162 months. This is consistent

with the government’s requested sentences of 144 months’ incarceration as to Count One of DLB-

23-cr-376 (Conspiracy to Commit Wire Fraud) and Count Two of DLB-23-183 (Possession with

Intent to Distribute a Controlled Substance), and 120-months’ incarceration, concurrent, as to

Count One of DLB-23-cr-183.

Harris has also pleaded guilty to two offenses with mandatory minimums that must be

imposed consecutive to all other sentences imposed by this Court. Count Three of DLB-23-cr-

183—Possession of a Firearm in Furtherance of a Drug Trafficking Crime—is a five-year

mandatory minimum sentence, consecutive to any other sentence. See PSR at 18 ; Plea Agreement

at 7. Count Seventeen of DLB-23-cr-376—Aggravated Identity Theft, in violation of 18 U.S.C.

§ 1028A—carries a mandatory two year minimum sentence, consecutive to any other sentence. 4

See PSR at 17; Plea Agreement at 7.

IV. Section 3553(a) and the Appropriate Sentence

As this Court is well aware, it must impose a reasonable sentence that is sufficient but not

greater than necessary to achieve the goals of sentencing, based on multiple factors, including “the

nature and circumstances of the offense,” “the history and characteristics of the defendant,” the

need “to promote respect for the law,” the need for just punishment without unwarranted

sentencing disparities and the need for both specific and general deterrence. 18 U.S.C. § 3553(a).

4
Moreover, the Court cannot alter its sentence on the grouped counts to take into account
the mandatory minimum on Count Two in DLB-23-cr-376. See 18 U.S.C. § 1028A(b)(3) (“in
determining any term of imprisonment to be imposed for the felony during which” the defendant
used a means of identification, “a court shall not in any way reduce the term to be imposed for
such crime so as to compensate for, or otherwise take into account, any separate term of
imprisonment imposed or to be imposed for a violation of this section”).
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The government will address all of these factors at the sentencing hearing, but addresses some of

them below. Based on these factors, a total overall sentence of 228 months’ imprisonment is

appropriate. 5

A. The Nature and Circumstances of the Offenses

Harris has committed two sets of serious and disturbing unlawful conduct. First, he

possessed multiple firearms and copious ammunition in connection with dealing illicit substances,

exposing his community to potential violence. Second, Harris committed a major financial fraud

with multiple co-conspirators, including those with insider access to trusted government databases,

that exploited individual victims, financial institutions, and public institutions at a time when

society was navigating an unprecedented economic and public health crisis. The combined harm

caused by Harris’s extensive criminal conduct in these two matters, combined with his noteworthy

criminal history, merit a significant sentence at the top end of the agreed upon C-plea range.

i. The Firearm and Drug Offenses

In 2022, while the UI fraud scheme was up and running, Harris was also found illegally

possessing a machine gun, other firearms, and distribution-level quantities of marijuana. The

Guidelines for the counts of conviction understate the nature and circumstances of Harris’s

criminal conduct related to the guns and drugs offenses.

5
Under the Plea Agreement, the parties have agreed that a total term of imprisonment
between 132 months and 228 months is the appropriate disposition of this case pursuant to the
§ 3553(a) factors. Plea Agreement at 8-9.

15
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Gun Possession. As described above, Harris possessed an arsenal of guns. The Mac9 and

the machine gun found in the attic were both loaded with more than two dozen rounds each. For

the AR-15, law enforcement received (2) fifty-round drums and (2) thirty-round drums, all of

which were loaded. Harris did not have a legitimate job. He made his money committing fraud

and dealing drugs. The Court should infer that he possessed these guns to protect his drug-

trafficking and fraud money.

The evidence also suggests that Harris possessed guns other than those obtained during the

search warrant execution at the Delmar Avenue Residence. That evidence is summarized below.

Guns at Tucker Road. Before being arrested on November 16, 2022, Harris was subject to

location monitoring for a Washington, D.C. case. He had told his Washington, D.C. probation

officer that he was living at the 4325 Delmar Avenue residence. On October 11, 2022, Harris wrote

the following message to co-defendant Ahmed Harris. 6

6
This message was obtained from a phone search warrant for one of Harris’s phones. He
is the 202-713-2813 number. Co-defendant Ahmed Harris went by the nickname “Osama” and has
been linked to the 240-315-3367 number.
16
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As evidenced in the message exchange, Harris and his co-defendant, Ahmed, were also storing

guns (“irons”) at a residence on Tucker Road in Oxon Hill (“da tucker rd spot”). They were only

keeping some of these guns at the Delmar Avenue residence. Law enforcement never executed a

search warrant at the Tucker Road residence in relation to this investigation.

Glock Switch in Porsche. On October 26, 2022—a little more than two weeks before the

search warrant execution—law enforcement recovered a Glock 27 with an auto switch from inside

of Harris’s Porsche. See supra at 5. He pleaded guilty to possessing that gun in state court.

Pictures with Other Guns. While reviewing Harris’s cell phones pursuant to search

warrants, law enforcement found photos of Harris posing with guns that were never recovered. A

few examples are below.

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Not only did Harris possess numerous guns, but he also carried them outside of his house,

which suggests he was willing to use them offensively. See Exhibit 2 (Harris with AK) (Native

Exhibit); Exhibit 3 (Harris with Gun in Vehicle) (Native Exhibit); Exhibit 4 (Harris & Others with

Guns in Vehicle) (Native Exhibit). Harris captioned this last video “Can’t hang round me if u ain’t

stepping shyt ain’t safe.”

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The government interprets that message to be a warning to members of the community: do

not threaten Harris unless you want a gun battle.

Drug Trafficking. The Guidelines captures the amount of marijuana that law enforcement

seized during the search warrant at the Delmar Avenue Residence. At the time of recovery, law

enforcement estimated that marijuana to have a street value of $897,878. See DLB-23-cr-183, ECF

No. 110-1 at 32, USA_000146. That amount—though large—does not consider the prior drug

sales that Harris conducted with different individuals. Evidence from his phones indicates that

Harris had engaged in prior drug sales and used online platforms to market drugs. For example, in

one video, he displayed a series of marijuana bags and captioned the video “Bagz N.” A screenshot

from that video is below.

****

Harris will likely point out that he did not use his guns violently. The Court should

nevertheless impose a long sentence for these offenses, because Harris was arming himself because
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he was engaging in drug trafficking. See Orrego Goez v. United States, 2023 WL 2045970, at *4

(S.D. Fla. Feb. 16, 2023) (“Guns and drugs ‘are a dangerous combination’ – as courts across the

country have consistently found.”) (citation omitted).

ii. The Unemployment Insurance Fraud

Beginning in or about January 2021, Harris worked closely with Smith and Ruffin, who

worked for Company #1 to use insider access to the MD-DOL systems, as well as multiple co-

conspirators such as Ahmed Hussain, Zakria Hussain, and Terry Chen, to defraud the government

and multiple individuals during an ongoing pandemic. While businesses were still reeling from

COVID-19-related closures and loss of business, and Marylanders had lost their jobs or were

working reduced hours, Harris and his co-conspirators were taking advantage of a vital lifeline to

Marylanders who were suffering financially and seeking to keep their families safe, housed, and

fed. Recognizing this, Congress expanded UI benefits and eligibility throughout the pandemic.

And the MD-DOL enlisted remote contractors through Company #1 to screen claims and handle

increased volume.

Through Smith and Ruffin, Harris used and obtained Company #1 credentials to

fraudulently alter the UI claims of real people using MD-DOL’s internal databases, removing fraud

flags on existing claims, inflating claims and directing hundreds of thousands of dollars into

Harris’s and co-conspirators’ bank accounts. This caused profound harm. Real Marylanders lost

access to their UI funds in the middle of the pandemic. The MD-DOL and the federal government

lost UI funds to a criminal conspiracy. Banks and financial institutions unknowingly transferred

fraudulent UI funds under their care.

Harris himself advanced this scheme in multiple essential ways. The text messages seized

from his and other co-conspirators’ phones show that he arranged the fraudulent use of Company

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#1’s laptops among his co-conspirators, frequently commandeering these laptops from his own co-

conspirators to submit more fraudulent claims. He used multiple email addresses to change the

contact information and misdirect UI claims away from real claimants. And he directly benefitted

from the fruits of his scheme to the tune of over half a million dollars. When one co-conspirator

(Smith) grew frustrated with his behavior, he moved on to working with another MD-DOL insider

(Ruffin) so that he could continue to exploit illicit access to Maryland’s unemployment system.

Harris’s initiative fueled the conspiracy’s success and longevity.

Moreover, the adjustments to the guidelines for the fraud conspiracy demonstrate in a real

sense the serious nature of Harris’s criminal conduct. This was a conspiracy not just driven by loss

amounts, but also by the sophisticated and complex nature of the scheme, the insider access, the

use of genuine driver’s licenses and other documents with authentication features, and many

individual victims.

B. Harris’s History and Characteristics

These cases only add to Harris’s already astounding criminal record. Not only is it lengthy,

but it also illustrates the breadth, variety, and increasing severity of Harris’s offenses. He has

multiple Simple Assault convictions in Washington D.C., two years apart. PSR at 21-22. Harris

also has a disturbing series of six sexual misconduct offenses between 2014 and 2022. See PSR at

19-20 (Lewd, Indecent, or Obscene Acts (2014), Harris sat next to a Metro passenger and “turned

around with his penis exposed in full view of the public”); id. (Indecent Exposure (2015), Harris

approached a Metro passenger and “was holding a $20 bill in one hand and his shirt up with his

other hand and the victim observed his fully exposed penis”); id. 20-21 (Sex Abuse (Misdemeanor)

(2016), Harris “touched the buttocks of the victim”); id. at 21 (Indecent Exposure (2016), while

Harris was standing over the victim on a Metro train, she “felt a substance hit her hair and on her

21
Case 8:23-cr-00376-DLB Document 146 Filed 10/23/25 Page 22 of 27

left shoulder . . . she recognized the look and smell of the substance to be semen”) 7; id. at 21-22

(Sex Abuse (Misdemeanor) (2017), Harris “plac[ed] his hands on the victim’s buttocks”); id. at 22

(Sex Abuse (Misdemeanor) (2022), Harris “penetrated the victim’s vulva with his penis where he

knew or had reason to know the victim was . . . incapable of declining participation in the sexual

act”).

Particularly relevant to this case is Harris’s 2022 firearms offense. Id. at 23. As discussed

above, law enforcement discovered a loaded handgun with a 30-round magazine in Harris’s

glovebox during a vehicle search. Harris committed this offense less than a month before the search

of his house that led to the charges in DLB-23-cr-183.

Being caught with one firearm did nothing to deter Harris from continuing to stockpile

weapons and ammunition to further his drug trade. Nor did his prior criminal sentences discourage

him from joining a multifaceted fraud conspiracy and stealing dozens of identities for his own

monetary gain. As difficult and as tragic as Harris’s upbringing was, the severity of Harris’s

compounding criminal conduct, the harm he has caused to victims, and the continuous disregard

he has demonstrated to his neighbors and community warrant a significant sentence.

C. Adequate Deterrence and Protection of the Public

These twin cases—and Harris’s prior record—demonstrate that Harris is both an economic

and physical danger to those around him. As to the latter, Harris’s penchant to mix firearms and

drugs continues to place the public in danger. Having one firearm seized by law enforcement did

7
A recording of the plea and sentencing hearing for this case is attached as a native exhibit.
See Exhibit 5, Plea and Sentencing Hearing Recording, State v. Harris, Case No. 0D00352842
(Dist. Ct. Mont. Cnty. Aug. 18, 2016). At the hearing, the victim stated that she “ha[s] post-
traumatic stress disorder because of this incident” and “it’s something that I think about every
single day”).
22
Case 8:23-cr-00376-DLB Document 146 Filed 10/23/25 Page 23 of 27

little to discourage Harris from continuing to possess the other firearms at his Delmar Avenue

residence. Nor did it discourage him from encouraging others to hide his additional firearms at

Tucker Road while he was on supervised release. See supra at 16. His sentence should

appropriately reflect the requisite protection of the public and the need to deter his future criminal

conduct.

Sophisticated fraud schemes like Harris’s also require deterrence. “Because economic and

fraud-based crimes are more rational, cool, and calculated than sudden crimes of passion or

opportunity, these crimes are prime candidates for general deterrence.” United States v. Martin,

455 F.3d 1227, 1240 (11th Cir. 2006) (internal quotations omitted). As evidenced by the scope of

Harris’s criminal conduct, cases such as this involving individual benefits fraud, insider access to

computers and government databases, and the use of false documents as well as the improper use

of real documents with authentication features are difficult to detect. The Fourth Circuit has

recognized the importance of incarceration for defendants convicted of similarly elusive white-

collar crimes such as tax evasion, theft, fraud, and embezzlement. See, e.g., United States v. Engle,

592 F.3d 495, 501 (4th Cir. 2010).

The UI fraud scheme also carries a particular need for general deterrence. Harris’s

exploitation of a high-profile relief program during an unprecedented pandemic also heightens the

importance of general deterrence. Congress expanded UI benefits and eligibility to get money to

people in need as quickly as possible. The United States must be able to aid its citizens

expeditiously and with streamlined bureaucratic scrutiny in an emergency. And yet it is precisely

the lack of scrutiny that Harris wrongfully exploited. The imposition of criminal penalties severe

enough to deter others who may seek to take similar advantage of public largesse in future disasters

is critical. Undeterred fraud of this sort will also undermine public support for similar relief efforts

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Case 8:23-cr-00376-DLB Document 146 Filed 10/23/25 Page 24 of 27

even when they are unquestionably needed. A lengthy sentence is necessary to deter others who

might think to use another national emergency for personal financial gain.

D. The Need to Avoid Unwarranted Sentencing Disparities

Harris is the second co-defendant in both the DLB-23-cr-376 and DLB-23-cr-183 cases to

be sentenced. (Four defendants in DLB-23-cr-376 remain to be sentenced.) The government

anticipates that Harris will argue that a sentence at the high end of the C plea range would result

in an unwarranted sentencing disparity between Harris and co-defendant Ahmed Hussain. Not so.

First, such an argument “focuses on the wrong kind of disparity.” United States v. Lawson,

128 F.4th 243, 257 (4th Cir. 2025). The Fourth Circuit has made clear that “§ 3553(a)(6)’s primary

purpose is to fulfill the ‘Guidelines’ goal’ ‘to eliminate unwarranted sentencing disparities

nationwide.’” Id. (quoting United States v. Withers, 100 F.3d 1142, 1149 (4th Cir. 1996))

(emphasis in original). A “sentence is not ‘unreasonable under § 3553(a)(6) merely because it

creates a disparity with a co-defendant’s sentence.’ ” United States v. Gillespie, 27 F.4th 934, 945

(4th Cir. 2022) (quoting United States v. Pyles, 482 F.3d 282, 290 (4th Cir. 2007)).

There is no unwarranted disparity in this case, just as there was no unwarranted disparity

in Lawson, where the appellant claimed there was an unwarranted disparity between him and his

co-conspirator. That co-conspirator had initially received the same 78-month sentence as the

appellant but was later resentenced to 46 months. Lawson, 128 F.4th at 257. The panel rejected

Lawson’s argument, holding that “the district court evaluated Lawson’s conduct under all of the §

3553(a) factors and based its sentence on that individualized assessment,” and finding that Lawson

failed to offer evidence “that his sentence was out of line with nationwide sentences.” Id. Given

that the government’s sentencing recommendation here is in the middle of the applicable

guidelines, Harris cannot show such a disparity either.

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Case 8:23-cr-00376-DLB Document 146 Filed 10/23/25 Page 25 of 27

Moreover, a sentencing disparity between Ahmed Hussain and Harris is warranted under

the § 3553(a) factors. While both committed similar sets of conduct, important distinctions merit

a significantly higher sentence for Harris. Harris, not Ahmed, was caught possessing a machinegun

as part of his marijuana distribution operation. Harris, not Ahmed, is captured in numerous

photographs carrying firearms which have not been recovered by law enforcement. Harris is

responsible for nearly twice the loss amount that Ahmed was in the UI case. Harris further pleaded

guilty to 18 U.S.C. § 922(c), a five-year mandatory minimum; Ahmed did not. Harris’s record

earned him the highest Criminal History level under the U.S.S.G.; Ahmed’s did not. A

meaningfully higher sentence for Harris is justified on multiple grounds.

V. Restitution

The government asks that this Court impose restitution of $952,225. The government

gathered the UI claims that could be tied to facts that Harris admitted to regarding his involvement,

namely the specific email addresses that Harris admitted to using “in furtherance of UI fraud,

including by having the contact email address for multiple purported claimants in the MD-DOL

system changed to” these email addresses. See Stipulation of Facts, ECF No. 119-1 at 9. The

government then added up the confirmed amounts paid on these UI claims from the point Harris’s

information was added to each claim in MD-DOL’s system through either the end of the

conspiracy or the point the claim was changed to a different email address. This conservative

approach results in a loss amount of $952,225. Additional information for a restitution order to

MD-DOL is included in the table below:

Victim Total Actual Loss Amount
Maryland Department of Labor
Benefit Payment Control Unit,
Room 206 $952,225.00
1100 N. Eutaw St.
Baltimore, MD 21201
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Case 8:23-cr-00376-DLB Document 146 Filed 10/23/25 Page 26 of 27

CONCLUSION

For the reasons set forth herein and further discussed at the sentencing hearing, the

Government respectfully requests that the Court sentence Harris as follows:

• Impose a total period of 228 months’ incarceration in the Bureau of Prisons (“BOP”),
consisting of 144 months as to Count One of DLB-23-cr-376 (Conspiracy to Commit Wire
Fraud) and Count Two of DLB-23-cr-183 (Possession with Intent to Distribute a
Controlled Substance); 120 months’ incarceration, concurrent, as to Count One of DLB-
23-cr-183; 24 months’ incarceration on Count Seventeen of DLB-23-cr-376 (Aggravated
Identity Theft), consecutive to all other terms; and 60 months’ incarceration on Count
Three of DLB-23-cr-183 (Possession of a Firearm in Furtherance of the Drug Trafficking
Crime), consecutive to all other terms;

• Place the Harris on supervised release of three years;

• Order Harris to make restitution of $952,225 and to pay a $500 special assessment.

• Impose forfeiture consistent with the government’s preliminary orders of forfeiture in
each respective matter.

Respectfully submitted,

Kelly O. Hayes
United States Attorney

/s/
Harry M. Gruber
Christopher Sarma
Joseph L. Wenner
Assistant United States Attorneys

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Case 8:23-cr-00376-DLB Document 146 Filed 10/23/25 Page 27 of 27

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Government’s filing was served via CM/

ECF on the defendant’s counsel.

________/s/_______________
Joseph L. Wenner
Assistant United States Attorney

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