Defendant Muge Ma's Submission in Aid of Sentencing — United States v. Muge Ma (Document 61)

Summary

Defendant Muge Ma's Submission in Aid of Sentencing, filed April 4, 2022, in United States v. Muge Ma, Crim. No. 20 CR 407 (RMB) (Document 61). It is a letter to Judge Berman on behalf of Muge Ma, written ahead of the sentencing scheduled for April 21, 2022, requesting a sentence of 24 months on the Aggravated Identity Theft count, consecutive to time served on the Bank Fraud count. The letter says he is non-violent, withdrew his applications before any investigation, obtained no PPP funding, and owes no restitution. It cites almost 50 letters in support and quotes several of them.

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     Case 1:20-cr-00407-RMB Document 61 Filed 04/04/22 Page 1 of 232




UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,

           Plaintiff,

     vs.                                CRIM. NO. 20 CR 407 (RMB)

MUGE MA,

           Defendant.




                            DEFENDANT MUGE MA’S
                        SUBMISSION IN AID OF SENTENCING




                                          Peter Katz, Esq.
                                          LAW OFFICES OF PETER KATZ, LLC
                                          116 Village Blvd., 2nd Floor
                                          Princeton, NJ 08540
                                          Attorneys for Defendant Muge Ma




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Dear Judge Berman:

       I write on behalf of my client, Muge Ma (who has adopted an Americanized name of

“Hummer Mars”), in advance of his sentencing currently scheduled for April 21, 2022, to

respectfully request a sentence of 24 months.

       The Muge Ma known to everyone who has come in contact with him is a different person

than the one who committed this crime. Muge is a loving, caring, giving person. Moreover, he

suffered through the pandemic in federal custody in squalid conditions and frequent, extended

lockdowns, quarantines and isolations, being victimized by fellow inmates, and contracting

COVID-19.      As is apparent from his letter to Your Honor, Muge has not only accepted

responsibility and expressed remorse for his actions (which began when he voluntarily withdrew

and cancelled his loan applications), but also put his future life in proper perspective such that

when he is released from prison, he is poised to return to the productive entrepreneur he was before.

Muge is extremely remorseful; however, this conviction by no means defines him.

       As Your Honor reviews the presentence report and the 3553(a) factors, I ask that you

consider the following:

   •   Muge readily admitted his guilt, including to a count of Aggravated Identity Theft –
       apparently, he is the only defendant in the Country required to enter such a plea for a PPP
       Loan Fraud case
   •   He is non-violent
   •   He is extremely remorseful
   •   He withdrew his applications before being aware of any bank or governmental
       investigations – (such withdrawal appears to be unique among the hundreds of PPP cases
       throughout the Country)
   •   He obtained no PPP funding because of the withdrawals, resulting in no restitution being
       owed
   •   Muge had a difficult childhood, having endured mental, physical, and sexual abuse because
       of his obesity
   •   He suffered through two grueling years in squalid conditions, repeated lock-downs,
       quarantines and isolations at the MCC and MDC, contracting COVID-19 and suffering
       through physical threats, significant racial and ethnic harassment, and hate crimes – all the
       while displaying an exemplary prison record



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   •   He has an immensely strong and supportive family and support structure in place
   •   This conduct was clearly an aberration in an otherwise law-abiding and productive life

       In considering the factors enumerated in 18 U.S.C. §3553(a), the Court should

bear in mind that as a 38-year-old lawful, permanent resident of the United States, this is Muge’s

first (and is certain to be his only) contact with the criminal justice system. He is a well loved and

respected person in his community who has been humbled by this process and has learned his

lesson. In fact, Muge’s own words from his letter to Your Honor demonstrate the depths of his

acceptance of responsibility and remorse: “An astronomical guilt intensifying every minute on me

for submitting those horribly false applications was like a blackhole sucking me and soaking me

up into the hell of dishonor.”

       Muge poses absolutely no threat to the community. In fact, as demonstrated by the almost

50 letters in support of Muge, he has been, and will continue to be, a great asset to society. Thus,

as we detail below, the §3553(a) factors counsel that a sentence of 24 months is the one sufficient,

but not greater than necessary to achieve the goals of 18 U.S.C. §3553(a).

       For these reasons as well as those that follow, it is respectfully submitted that the Court

sentence Muge Ma to 24 months in prison on the Aggravated Identity Theft count consecutive to

time served on the Bank Fraud count.




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Background

       Muge had been an incredibly successful member of society, who overcame a difficult

childhood and adolescence as detailed in the attached report of Leslie Lockwood, MSW

(“Lockwood Report”). Muge is an exceptionally hard-working man who puts his family and

friends above himself. To begin, it is essential to know that Muge fully accepts responsibility for

his actions, as he has with his guilty plea and in his attached letter. By all accounts, before this

conduct, he was an upstanding and law-abiding individual for the entirety of his life. Indeed, Muge

has dedicated his life to his family. As Your Honor can see from the attached letters, Muge’s love

of and for his family pervades his entire being. He is dedicated to them and supports them

financially, physically, emotionally, and spiritually. Unfortunately, since his incarceration, his

parents (who live in China and speak no English, have resided in New York since Muge’s arrest)

have suffered immense physical, emotional and financial trauma. As detailed in the Lockwood

Report and attached letters from his parents, his mother and father have succumbed to numerous

physical ailments, including his father recently breaking his hip on his way to visit Muge at the

MDC. As a result of COVID, their previously thriving businesses in China have virtually

collapsed. And of course, culturally, they have suffered great societal ignominy because of Muge’s

conduct.

       To be sure, Muge is a giving person, a man of integrity, a man committed to his family and

friends. This is evident from the many letters in support of Muge. As his friend since primary

school, Gening Dong, noted, “I have always been growing up under Muge’s positive influence.

He was always the best one among his peers, and he had set a good example for me with his hard

work and many achievements…. Muge is the kind of person who is always cheerful and full of




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energy…. He takes his career and life seriously, works hard and loves his family from the bottom

of his heart.”

         Ting Yu, a Doctor and Professor at Jilin University and cousin of Muge, commented that

Muge “has been a man of noble character and excellent learning since he was a child. He is smart,

enthusiastic and helpful. He contacts everyone with his kindness and sense of responsibility….

He [is] a man of great excellence and integrity, a role model for our peers and our children to learn

from.”

         Indeed, Ting’s expression of Muge’s care for others and integrity are echoed by everyone

who knows Muge. Hong Bao, also a doctor and wife of one of Muge’s cousins, added that “what

I like most about him is that he is sincere, enthusiastic, optimistic and enthusiastic about everything

he does.” Bruce Quilliam, Jr., a business associate, noted that “Muge always presented himself in

a gracious, professional manner and did not in any way appear to be anything other than a true

gentleman with good intentions.”

         Muge also was eternally dedicated to his work. A former co-worker of Muge, Zhang Shu,

reflected that “Hummer is one of the hardest-working people I have ever worked with, and his

dedication to his work is unforgettable.” Amy Mao, a Citibank Branch manager and former co-

worker and friend of Muge, echoed these sentiments: “Hummer was always to be supportive and

willing to share his experience and professionalism with my team. They all [were] impressed with

his kindness and selfless[ness]…. As many of his friends, associates, and employees can attest to

it, he is a good man who serves his friends, families and his community with selfless acts and

kindness. He loves to learn, works very hard, stays away from bad habits…. He has always been

kind, warm, and humble.”




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       Muge’s former boss at Citibank Shanghai, Joo Howe, reflected that Muge was a “kind-

hearted man.” He added that “Muge has always been one of my most trusted staff when I was the

branch manager. Muge has always displayed great compassion and trust to everyone around him.”

Others have made similar comments: Muge’s friend, Zhe Yang: “wherever he goes, he will always

bring his kindness with him.” Muge’s business associate, Yongwei Chen: “As a friend for many

years, I have always admired Hummer’s hard-working and enterprising spirit.” Friends, Vici

Shaweddy and Robin Chou, simply: “Hummer was the glue of our community.” Family friend,

Lianwei Dong: “Hummer is a warm and cheerful man…. He has always been a leader among his

peers.” Friend, Joseph Bent: “I know that Hummer is a decent man with a kind and loving heart….

Everyone who has met or knows Hummer would say nothing but good things about him. He is

selfless in nature and would give a stranger a shirt [off] his back.”

       Muge’s second cousin, Mingxin Li commented on Muge’s best qualities and all that has

been lost: “I think Muge’s most distinguishing trait is his self-discipline…. Wherever he goes, he

brings energy and joy to the people around him…. [Muge’s crimes have] destroyed the most

important things that Muge has worked for in his life, due to his own fault. His businesses are

effectively gone. His finances are ruined. He cannot support his family anymore. His name is all

over the newspapers, and his former friends and colleagues who used to look up to him now all

know that his reputation is ruined.”

       Muge’s college classmate, Daniel Zhao, an auditor, likewise commented on Muge’s stature

in his community: “I can say for sure that he’s the one people looking for help when they were in

need and of course I was one of them. He treats everyone with patien[ce] and compassion.

Through years, I never see him complaining, helping others, neither hear from anyone speaking




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any bad of him, which I see it an accomplishment. He is a man of high morality that makes some

of us feel like we are ‘bad guys.’ His morality makes people want to follow his lead.”

       Hongmei Meng, Muge’s colleague for five years, recounted an example of Muge’s

leadership. Meng wrote, “In my impression, one thing that is deep in my memory is that in his

second year of work, the company contacted poor students in remote primary schools and asked

the entire company to support them. Not very long time afterwards, only after the company sent

an email, we learned that he silently funded one of the poor students, but he never made any

announcements.”

       Radhu Ihuas, a friend and MBA classmate of Muge, relayed another example of his

leadership: “During the MBA, he was one of the most active community connectors. He was

always organizing team buildings, dinners, and activities for our community to enjoy and to build

connections beyond. He organized a large dinner celebrating Chinese New Year and introduced

his classmates to traditional Chinese food. He was also active in helping other students to

showcase their culture. Muge was open to everyone and eager to build friendships across cultures.

His desire to meet everyone and build friendships was always a defining characteristic of him. I

could give endless anecdotes about our friendship and why I love Muge deeply and believe him to

be a fundamentally decent person…. Even as he was struggling to build his own business, he was

happy to help others. I know Muge as a thoughtful, considerate, and compassionate man…. I

write this letter to share with you this fundamental conviction of mine: that Muge is at his core a

good person who will strive to do better, if given the chance. He is not the sum of these charges,

and the life he has lived until now has been meaningful and positive to so many people.”

       Another MBA classmate and close friend, Jennifer Austin, gave specific examples of

Muge’s goodness and love: “What I loved most about him was that he approached everything with




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sincerity, enthusiasm, optimism, and passion…. There are those [people] who fundamentally

change you – people whose friendship and influence make you a better, stronger, and more

complete person, enriching your character and perspectives. Muge…is such a [person]…. I could

see how proud Muge was to show his parents that he had made deep friends in America and that

this was a place where people from all backgrounds could make friends with each other… Muge

beamed with pride to show them America…. Unfortunately, 2020 brought many personal

difficulties for me. Covid-19 disrupted my business… my brother developed pancreatic cancer.

Muge was there for me through all of this. He was one of the few people I could bring myself to

talk to because he was so kind and supportive. People tend to offer vapid pleasantries in such dire

situations. Muge didn’t bother with such pretenses. Each time we spoke, he offered all the support

he could: emotional, tangible, financial – he was willing to help in any way.”

       Muge is also a man of much faith. His mother, Xianmei Yu commented that “under the

influence of his wife, Elisabeth, Muge has taken to Christianity in recent years, trying hard to study

the Bible and understand its essence. He regularly attends church services and makes donations.

Every Year he takes part in large Christmas celebrations and events. He is a devout believer.”

       Crystal Tian, an accountant and friend of Muge summed it up well, “He is a good man,

good friend and good son.” This is the Muge Your Honor should know before you sentence him.

       Muge, originally from China, taught himself English, attended and graduated from UCLA

Business School, received numerous business-related accolades, and used his entrepreneurial spirit

to start a business of his own. Unfortunately, Muge made a horrific, life-altering decision in a

cataclysmically stupid and monumental, yet temporary, lapse in judgment. That said, it is critical

to note that Muge realized his mistake before he was aware of any investigation and withdrew and

canceled his various PPP Loan applications – attempting to minimize any damage. His corrective




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actions worked – as he obtained no funds, and no bank lost any funds. Indeed, Muge continues to

fully accept responsibility for his actions, as he indicated at his guilty plea and as he has

demonstrated in his attached letter. It should be noted that it appears Muge is the only defendant

charged in the United States who voluntarily withdrew and cancelled his loan applications 1 and

the only defendant charged with PPP loan fraud who was required to plead guilty to Aggravated

Identity Theft. These two facts may not be coincidental, as the government may have sought to

maintain some control over his sentence, mandating a plea with a 24-month mandatory minimum,

knowing that a probationary sentence might otherwise be imposed.

         To be sure, Muge fully accepts and acknowledges his conduct. We respectfully suggest

that keeping Muge in prison for the remainder of his young adulthood and into his 40s would not

serve any meaningful purpose and would be detrimental to society in a myriad of ways.

         Muge has suffered immensely since his arrest. For almost two years, Muge has lived in

brutal and traumatic prison conditions due to the COVID-19 pandemic. The conditions are

detailed in the Lockwood Report, including his contracting COVID-19 while incarcerated. In fact,

Muge continues to suffer from “long-term COVID.”                     We ask that Your Honor take this into

account in fashioning a fair and just sentence. As Your Honor is likely aware, virtually every

Southern District of New York Judge has lowered defendants’ sentences because of MCC and

MDC conditions during the COVID-19 pandemic. Yes, Muge deserves some punishment for his



1
  While Mr. Ma withdrew and cancelled his applications, we had to concede that under United States Sentencing
Guideline Section 2B1.1, Application Note 3(E)(i), the loss calculation was not subject to a credit against loss even
though (1) “the fair market value of the property was returned by the defendant” and (2) Mr. Ma did so voluntarily
before becoming aware of any investigation. We were compelled to do so solely because one of the banks did, in
fact, “detect” (but not notify Mr. Ma about) the offense by beginning an internal investigation. This technicality
prevents a guideline credit against loss. If such credit would have been applied, the resulting guidelines would have
been an adjusted offense level of 7 with a range of 0-6 months. While we concede the guideline analysis, we
believe, under 3553(a), this “technicality” is of no moment, and Mr. Ma should be sentenced to time served on the
Bank Fraud offense because of his voluntary withdrawal of all applications along with the other reasons
demonstrated in this memo and submission.


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conduct. However, his experience with month-long lockdowns, no visits, frequent quarantines

and isolations, contracting COVID-19, anti-Asian prejudice and hate crimes, and abuse by fellow

inmates and prison guards, caused significant mental strain and physical trauma far exceed the

appropriate and usual reach of punishment.

Sentencing Factors

       As Your Honor is well aware, pursuant to Title 18, United States Code, Section 3553(a),

the Court shall impose a sentence sufficient, but not greater than necessary, to comply with the

need for the sentence imposed. In this case, Your Honor must consider the following:

   •   The nature and circumstances of the offense
   •   The history and characteristics of the defendant
   •   The need for the sentence imposed
          o To reflect the seriousness of the offense, to promote respect for the law and to
              provide just punishment for the offense
          o To afford adequate deterrence to criminal conduct
          o To protect the public from further crimes of the defendant
   •   The kinds of sentences available
   •   The kinds of sentence and the sentencing range established by the guidelines
   •   The need to avoid unwarranted disparities

Nature and Circumstances of the Offense

       There is no sugar-coating Muge’s conduct. However, as Muge noted in his letter and will

orally state at his sentencing, this is certain to be his last interaction with the criminal justice

system. Muge is extremely apologetic to the banks, family, friends, and the Court for his conduct.

       While this is a significant offense, as noted below, the seriousness of the offense does not

require or demand a lengthy custodial sentence because of the other factors detailed above,

including Muge’s voluntary withdrawal of the loan applications.




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History and Characteristics of Muge Ma

       The background noted above (including the Lockwood Report and letters of support)

demonstrates the challenges Muge faced as a child, and some insight into the caring, loving, giving,

and sharing person that Muge has also shown to be. It is apparent from these circumstances, that

the conduct which brings Muge before Your Honor does not represent Muge’s true character and

worth. It does not define who Muge is, or who he will become.

       As is likely to be requested by the government, a lengthy prison sentence for Muge is

wholly unnecessary.

       In addition, as a remorseful, 38-year-old, Muge is not likely to recidivate. A review of

Muge’s life and his demonstrated awareness of his situation reveals that the likelihood of him

committing another crime is exceptionally low. As long as he lives, Muge will not be a criminal

defendant again. Therefore, a lengthy sentence of imprisonment is unnecessary as a means of

deterrence or to protect the community from Muge. As previously noted, Muge is wholly

remorseful for his conduct. He is ready, willing, and able to move on with his law-abiding life.

       Indeed, there has been a groundswell throughout the country to reduce the over-

incarceration of those convicted of crimes, particularly non-violent offenses. Even the splintered

federal government’s executive and legislative branches have come together to acknowledge that

low-risk offenders, should spend considerably less time in prison through the First Step Act. See

First Step Act of 2018. There is a general understanding that extensive stays in federal prison for

these populations are expensive, deleterious to their long-term health,        and ineffective and

unnecessary punishment.

       Moreover, as a lawful, permanent resident of the United States, Muge will not be allowed

to participate in many prison programs. For example, he will not be eligible for work release,




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placement in a half-way house, First Step Act credit, community service, home detention, or

intermittent custody.

       Accordingly, we respectfully submit that these sentencing factors mitigate in favor of a 24-

month sentence.



       The Need for the Sentence Imposed to Reflect the Seriousness of the Offense, to Promote
Respect for the Law, to Provide Just Punishment for the Offense, to Deter Future Criminal Conduct
and the Need to Avoid Unwarranted Disparities

       Without question, Muge stands convicted of serious offenses. That said, he is remorseful.

He will suffer dozens, if not hundreds or thousands of collateral consequences from this

conviction, including potential immigration effects. Placing him in prison for several more years

will not benefit society in any way and would be a punishment greater than necessary to achieve

these purposes of sentencing.



To Protect the Public From Further Crimes of Muge Ma

       A review of Muge’s current life status and insight reveals that the likelihood of Muge

committing another crime is exceptionally low. As long as he lives, Muge will not be a criminal

defendant again. This factor militates in favor of a truncated prison sentence.



The Need to Avoid Unwarranted Disparities

       The Court should consider one final, yet immensely significant factor, specifically, the

sentences imposed on others who have committed similar offenses. As the Guidelines instruct and

fundamental fairness dictates, it would be improper for similarly situated and charged individuals,

such as Muge, to be imprisoned disparately. A survey of similar PPP and related cases from around




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the country over the last year reveals a plethora of similarly situated defendants all receiving

sentences well below the advisory guidelines, receiving sentences of 24 months or less. Indeed,

that survey of over 150 PPP Loan fraud defendants was unable to find any other case where (1)

the defendant was required to plead guilty to Aggravated Identity Theft (with a mandatory 2-year

sentence) or (2) where the defendant voluntarily withdrew and cancelled the applications. In

addition, while Mr. Ma is technically guilty of Aggravated Identity Theft based upon current

Second Circuit precedent, his use of an already existing corporate email in the name of his former

girlfriend for purposes of communications regarding applications is far afield from the intended

purpose of the statute. As noted above, we believe the government demanded a plea to Aggravated

Identity Theft, with a mandatory 24-month sentence, precisely because Mr. Ma’s withdrawal

conduct would otherwise be consistent with a probationary sentence. Below are 20 examples of

cases where defendants actually received PPP funds; often spending millions on personal luxury

purchases, and received a sentence of 24 months or less. Every one of these defendants are more

culpable than Mr. Ma:

           •   U.S. v. Shashank Rai, 21 CR 9, EDTX ($13 million loan sought) (24-month
               sentence)

           •   U.S. v. Tarik Jaafar, 20 CR 185, EDVA (18 applications, $6.6 million sought, $1.4
               million received) (attempted to flee to Poland) (12-month sentence)

           •   U.S. v. David Butziger, 20 CR 72, DRI ($543,000) (Sentence of Time Served-
               equivalent of 1 day in jail)

           •   U.S. v. Benjamin Hayford, 20 CR 88, NDOK (more than $8 million) (24-month
               sentence)

           •   U.S. v. Leonel Rivero, 21 CR 20160, SDFL (118 loan applications, $2.3 million
               sought, approximately $900,000 received) (24-month sentence)

           •   U.S. v. Baoke Zhang, 20 CR 169, WDWash ($1.5 million) (60-day sentence)




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  •   U.S. v. Bridgett Dorsey, 21 CR 624, DSC (more than $1.25 million received) (24-
      month sentence)

  •   U.S. v. Cindi Denton, 21 CR 60171, SDFL (approximately $500,000 received) (6-
      months jail/12 months, home confinement)

  •   U.S. v. Miranda Devlin, 21 CR 226, NDCA ($369,000 received) (18-month
      sentence)

  •   U.S. v. Diamond Blue Smith, 21 CR 20001, SDFL (over 80 applications, $24
      million sought, $1.13 million received) (20-month sentence)

  •   U.S. v. Tonye Johson, 21 CR 60017, SDFL (over 80 applications, $24 million
      sought, $389,627 received) (18-month sentence)

  •   U.S. v. Nadine Jackson, 20 CR 112, SDOH ($2.5 million received) (24-month
      sentence)

  •   U.S. v. Andrew Tezna, 21 CR 77, EDVA (Senior Executive Service employee of
      NASA) (18-months sentence)

  •   U.S. v. Tristan Bishop Pan, 21 CR 436, EDNC ($6.1 million sought, $1.7 million
      received) (20-month sentence)

  •   U.S. v. Scott Suber, 20 CR 110, EDVA ($350,000 received) (24-month sentence)

  •   U.S. v. Darrell Baker, 20 CR 355, EDMich ($590,000 received) (24-month
      sentence)

  •   U.S. v. Mukund Mohan, 21 CR 41, WDWash ($5.5 million sought, $1.8 million
      received (24-month sentence)

  •   U.S. v. Luke Pierre, Jr., 21 CR 60288, SDFL ($415,000 received) (24-month
      sentence)

  •   U.S. v. Jeremy Clawson, 21 CR 39, Dist. of Oregon (24-month sentence)

  •   U.S. v. Dennes Garcia, 21 CR 60146, SDFL ($285,000 received) (18-month
      sentence)




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       Based upon all of these factors, we respectfully submit the sentence which is

sufficient but not greater than necessary to achieve the goals of sentencing is a sentence of 24

months on the Aggravated Identity Theft count to run consecutive to a sentence of time served on

the Bank Fraud count.

                                                           Respectfully Submitted,




                                                           Peter Katz, Esq.




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                     LESLIE S. LOCKWOOD, MSW
                     Sentencing Consultant and Mitigation Expert




                              April 2, 2022
(347) 219-9760
Leslie.S.Lockwood@gmail.com
                              The Hon. Richard M. Berman
3597 Milburn Avenue
                              Senior U.S. District Judge
Baldwin, NY. 11510            U.S. District Court Southern District of New York
                              500 Pearl Street
                              New York, NY 10007

                                                                       Re: US v. Muge Ma, 20-CR-407 (RMB)




                              Your Honor,

                              The following social history assessment and mitigation report is provided on behalf of Muge
                              Ma (also known as Hummer Mars), who awaits sentence before Your Honor. The undersigned
                              has been appointed by the Court as a Mitigation Specialist. It is respectfully requested that
                              this report be filed under seal due to Mr. Ma’s reasonable fear that




                              This report is based upon in-person, telephonic and video interviews conducted with Mr. Ma,
                              as well as written communication with his mother. In connection with the preparation of this
                              report, the charging instruments, plea agreement and Presentence Report have been
                              reviewed.




                              Introduction

                              Muge Ma pleaded guilty to counts charging him with bank fraud and aggravated identity theft;
                              he faces up to 30 years imprisonment on Count 2, and a mandatory consecutive 2 years
                              imprisonment on Count 8. He has been in custody since May 21, 2020, and will have served
                              23 months at the time of his sentencing on April 21, 2022.




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                        Mr. Ma’s Struggles with Obesity and Gynecomastia

                        Muge Ma was born on March 21, 1984, in Changchun in the Jilin Province of China, to his
                        parents, Feng Xiang Ma and Xian Mei Yu. Mr. Ma is an only child, pursuant to the “one child”
                        rule that existed in Communist China at that time.1 During Mr. Ma’s formative years, his
                        parents owned multiple businesses in China and were considered wealthy, but they were
                        never home during his childhood due to their work responsibilities. As such, Mr. Ma ate a lot
                        of unhealthy food, particularly “luxury foods” from American restaurants such as McDonald’s,
                        KFC, Pizza Hut and Burger King, ultimately gaining so much weight that he was clinically
                        obese.

                        While he was in grade school, Mr. Ma earned excellent grades and was advanced to the next
                        grade, despite the principal’s warning to his parents that it could be a difficult road for him to
                        be among older students. By the age of 8, Mr. Ma’s weight gain was beginning to accelerate,
                        which led to his victimization by other children. On one occasion, he was beaten up by
                        neighborhood children who robbed him of his toys. When his parents observed wounds on
                        his face, he downplayed the incident to his parents because he felt humiliated. By the time he
                        was in middle school, his grades began to suffer significantly. From ages 12 through 14,
                        during breaks between classes, his classmates tried to “squeeze the fat out of” him, while
                        teachers and other students watched and laughed; this happened every day, throughout the
                        day. At the age of 13, he was beaten up by another student because he was obese and an
                        easy target; Mr. Ma couldn’t sleep for two weeks because his jaw was swollen.

                        At age 14/15, in the midst of puberty, Mr. Ma’s weight was at its peak; he was 5 feet tall and
                        about 270 pounds, and his clothing had to be custom made to fit his body. The skin was
                        infected and actually breaking down in the folds of his fat, and he had developed
                        gynecomastia (overdeveloped breasts).2 Due to his excessive weight and overdeveloped
                        breasts, Mr. Ma was mercilessly bullied by his classmates, at times amounting to sexual
                        assault. Students would sometimes grab his breasts from behind, or remove his shirt entirely


1 In addition to the restrictive measures implemented by the communist party, in 1980, China initiated its “one-child” policy in response to a

significant increase in the country’s population. Violators of this policy would be fined or could be subject to forced abortions, and risked losing
their jobs if found to have had more than one child. In some parts of China, the penalties were far more violent, and could involve doctors injecting
poison directly into a baby’s skull. Officials may kidnap or imprison the parents, and if they could not be found, officials would kidnap elder
members of their families. The policy led to sex-selective abortions or infanticide targeting girls due to a longstanding social preference for boys.
This policy was amended in 2016 in favor of a two-child policy, and again in 2021 to a three-child policy. https://www.scmp.com/economy/china-
economy/article/3135510/chinas-one-child-policy-what-was-it-and-what-impact-did-it, https://www.npr.org/2021/06/21/1008656293/the-legacy-
of-the-lasting-effects-of-chinas-1-child-policy

2 https://www.mayoclinic.org/diseases-conditions/gynecomastia/symptoms-causes/syc-20351793




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   to expose his breasts. The physical, sexual and emotional abuse endured by Mr. Ma was
   exacerbated by the fact that he was younger than his classmates. He struggled to focus on
   his classwork, because he was constantly in fear of being tormented by other students.
   People told him “you’re going to be a waste,” and no one held back their thoughts about his
   medical issues. Mr. Ma was often truant from school, and would stay home for weeks at a time
   to avoid the daily trauma of attending school. Since his parents were always working, they
   were unaware that he was home playing video games all day. The abuse started to wane
   when he was in high school, but the psychological damage had been done, and he continued
   to suffer from extremely low self esteem.

   Mr. Ma feels that he was neglected by his parents throughout his childhood, through their lack
   of supervision and protection, although he doesn’t blame them for the torment he endured.
   Nevertheless, their neglect contributed to his obesity, and they turned a blind eye when he
   was ridiculed by his extended family. Due to the incessant bullying he was subject to in
   middle school, he had trouble focusing on his schoolwork and his grades suffered; when his
   teachers used corporal punishment-which included public beatings-and verbally abused him
   for not meeting their expectations, his parents did not come to his defense. Other students
   witnessed this treatment, and they would join in the torment by humiliating, beating and
   robbing Mr. Ma of his possessions. As noted in the PSR, he has several scars from this
   abuse. Although their inaction created a toxic environment during his youth, his parents only
   became aware of the extent of his victimization in October 2021, during the pendency of this
   case.

         The first time my parents got to know all of my childhood and juvenile traumas was as
         late as last October (2021) right after the probation officer interviewed me. My mother, a
         very tough business entrepreneur and calm investor for decades whom I barely have
         seen crying, bitterly cried at the phone call to me, witnessed by my Dad…….she was
         falling apart merely asking me "Why didn't you tell Mom? Why didn't you tell Mom?". My
         parents are very loving [toward] me. [I] see fulfilling filial piety as the highest priority of
         my life. It's a trauma for me. It's an incurable trauma for my parents as well.

         To their neglect, my parents essentially failed their duty of supervision or guardianship
         on me throughout my childhood. But never even the very least have I blamed on them
         even as slightly as a piece of hair, because they are the most loving parents in the
         world for me - and now for my wife - that's why my wife misses my parents so much
         whenever she's not around with my parents, as she indicated in her love letter to me.
         My parents were just a couple of young parents who were so absorbed by their three
         fast growing businesses back then and mountains of responsibilities on their


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                                  employees and on their companies……Me, a monstrous humiliation of my successful
                                  parents - that's how I believed throughout my childhood before 18 years old.

                         When Mr. Ma was age 16, his maternal uncle was robbed and bloodily murdered by a gang at
                         his home. The event was traumatizing, and certainly life changing for him and his entire
                         extended family. Mr. Ma’s mother, who was his uncle's younger sister, was particularly
                         heartbroken having been raised with him.

                         Mr. Ma reached a turning point when, at age 17, he decided to take charge of his life and lose
                         weight. He limited his diet to eating apples with salt water for the first seven months, and he
                         continued the practice only intermittently after that; he ultimately lost 80 to 90 pounds. After
                         graduating from high school, he attended Northeastern University in China, and his grades
                         were excellent. He was now physically fit, and became involved in the student government,
                         and he was no longer being victimized by his peers. Mr. Ma was obsessed with his weight,
                         and suffered at various times from anorexia3 and bulimia,4 both of which are potentially life-
                         threatening eating disorders. He began to purge (induce vomiting) when he was in college;
                         anytime he perceived that he had consumed too much food, he would force himself to expel
                         it.

                         Mr. Ma came to learn that his testosterone levels were very low, which caused his enlarged
                         breasts. He was taking testosterone supplements from 2013 until his arrest to minimize the
                         gynecomastia, but he has not been provided with testosterone at either the MCC or MDC, and
                         he fears that his breasts will become enlarged while incarcerated. As such, he works out
                         every day and eats an exclusively vegetarian diet to keep his weight down. Since his
                         incarceration, he has consumed an exclusively vegetarian diet to keep his weight down, and
                         to avoid the unhealthy food served to the general population. He also believes that it would
                         reduce the odor in his cell, and he didn’t want any conflict with his cellmate in the next bunk.


3 Anorexia nervosa — often simply called anorexia — is an eating disorder characterized by an abnormally low body weight, an intense fear of

gaining weight and a distorted perception of weight. People with anorexia place a high value on controlling their weight and shape, using extreme
efforts that tend to significantly interfere with their lives. To prevent weight gain or to continue losing weight, people with anorexia usually severely
restrict the amount of food they eat. They may control calorie intake by vomiting after eating or by misusing laxatives, diet aids, diuretics or
enemas. They may also try to lose weight by exercising excessively. No matter how much weight is lost, the person continues to fear weight gain.
Anorexia isn't really about food. It's an extremely unhealthy and sometimes life-threatening way to try to cope with emotional problems. When you
have anorexia, you often equate thinness with self-worth. https://www.mayoclinic.org/diseases-conditions/anorexia-nervosa/symptoms-causes/
syc-20353591

4 Bulimia nervosa, commonly called bulimia, is a serious, potentially life-threatening eating disorder. People with bulimia may secretly binge —

eating large amounts of food with a loss of control over the eating — and then purge, trying to get rid of the extra calories in an unhealthy way.
https://www.mayoclinic.org/diseases-conditions/bulimia/symptoms-causes/syc-20353615



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Case 1:20-cr-00407-RMB Document 61 Filed 04/04/22 Page 20 of 232




   He has been working out obsessively in an effort to keep his weight down and hold the
   gynecomastia at bay, but the constant lockdowns at the MDC have made it challenging for
   him. As a result of his poor diet at the MDC, in March 2022, he was deemed malnourished by
   the medical staff. According to the Mayo Clinic, malnutrition can actually exacerbate
   gynecomastia.

   Mr. Ma has also endured ongoing dental issues since he was a child. Most of his baby teeth
   fell out between the ages of 10 and 17. His baby teeth took many years to fall out since the
   space wasn’t needed for the new teeth to grow in; his last baby teeth fell out in approximately
   2010, when he was in his twenties. When his baby teeth eventually fell out, only half of his
   adult teeth came in to replace them, necessitating the installation of prosthetic teeth. As a
   teenager, he had large gaps between his teeth until the artificial teeth could be installed. His
   mother had the same condition when she was young, so he believes it is an inherited
   condition.
Case 1:20-cr-00407-RMB Document 61 Filed 04/04/22 Page 21 of 232
                 Case 1:20-cr-00407-RMB Document 61 Filed 04/04/22 Page 22 of 232




                        Mr. Ma has worked hard for everything he has attained

                        Mr. Ma longed to leave China and its communist regime, because the environment there was
                        unpredictable and he felt unsafe. He worked hard toward his goal of relocating to the United
                        States, because corporations in this country attract the best people from around the world.

                        Despite the trauma he endured throughout middle school and high school, Mr. Ma earned his
                        high school diploma from the Jilin Provence Experiment High School in 2002. He then
                        attended Northeastern University, where he earned a bachelor’s degree in 2006. While still a
                        student at Northeastern University in China, Mr. Ma worked as an intern at Citigroup/Shanghai
                        Bank. In 2006, after joining Citigroup, he was asked for his “American name,” and he started
                        referring to himself as Hummer Mars. At that time, “Hummer” was a popular car in China and
                        translates to “tough horse,” and “Ma” means “horse” in Chinese. Once in the United States,


6 Starting on the night of April 17, three thousand Peking University students marched from the campus towards Tiananmen Square, and soon

nearly a thousand students from Tsinghua joined. Upon arrival, they soon joined forces with those already gathered at the Square. As its size grew,
the gathering gradually evolved into a protest, as students began to draft a list of pleas and suggestions (the Seven Demands) for the government.
The students drafted the Seven Demands, in an effort to affect change in the ruling government: Affirm Hu Yaobang's views on democracy and
freedom as correct; Admit that the campaigns against spiritual pollution and bourgeois liberalization had been wrong; Publish information on the
income of state leaders and their family members; Allow privately run newspapers and stop press censorship; Increase funding for education and
raise intellectuals' pay; End restrictions on demonstrations in Beijing; and Provide objective coverage of students in official media. https://
en.wikipedia.org/wiki/1989 Tiananmen Square protests and massacre

7 https://www.bbc.com/news/world-asia-48445934




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   he unofficially changed his last name to “Mars,” to solidify his loyalty to this country. He plans
   to legally change his name to Hummer Mars upon his release from custody. After graduating
   from Northeastern, he went on to work at HSBC, then at Citigroup as an investment banker
   until moving to the United States in 2011.

   While working at Citigroup in China/Hong Kong, Mr. Ma took the GMAT (Graduate
   Management Admission Test) and applied to approximately 30 Masters in Business
   Administration programs in the United States. He was ultimately accepted to University of
   California-Los Angeles (UCLA), and entered the United States with a student visa in July 2011.
   He initially had difficulty understanding his professors due to the language barrier, but
   attending UCLA ultimately strengthened his language skills. Although he had a rudimentary
   command of the English language, he had studied the language on his own, beginning in
   2009, in order to achieve fluency. He is now fluent in the Mandarin and English languages.
   While at UCLA, he worked through the weekends and most holidays. He graduated from their
   MBA program in June 2013, and moved to New York City. There, he participated in an
   internship with Graviton Fund, a trading fund, from June 2013 to April 2014. He went on to
   work for HT Capital, an investment bank, until June 2015.

   Although he was working full-time, in 2014, Mr. Ma was awarded a merit-based scholarship
   and commuted from his home in New York City to Goldey-Beacom College, located in
   Delaware. It should be noted that the round-trip commute to Goldey-Beacom was nearly 5
   hours. There, he earned a second Masters Degree in August 2016. Before his student visa
   was set to expire, Mr. Ma applied for temporary permanent residency in the United States, and
   he received his work authorization card in the summer of 2016. He finalized his permanent
   residency in 2019, and hopes to become a US citizen. Although he retains his China
   citizenship, he has not returned to his home country since relocating to the United States. His
   parents may be applying for asylum in the United States due to the harsh conditions they left
   behind in China.

   Mr. Ma has been continuously employed since graduating from UCLA in 2013. He has been
   the Executive Director of New York International Capital LLC (NYIC) since June 20, 2016, the
   Vice President of Investment Banking at China Merchant’s Bank (US Office) and the Executive
   Director of Hurley Resources (Hurley) since January 18, 2019; these businesses provided
   investment banking advisory and management consulting services to United States-based
   small and medium-sized enterprises and technology start-ups. In July 2018, Mr. Ma canceled
   the lease for his office space, and thereafter worked from his apartment, using the conference
   room in his building if necessary. He hopes to get these businesses up and running upon his
   release, but he has been approached by other companies because of his reputation in the


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Case 1:20-cr-00407-RMB Document 61 Filed 04/04/22 Page 24 of 232




   business community. As noted in the PSR, Mr. Ma presently has a net worth of negative
   $356,000, and he is unable to pay a fine. Mr. Ma never worried about money until his parents’
   businesses collapsed in 2019, due to the COVID-19 pandemic.

   As noted in the PSR, despite the restrictions at the Bureau of Prisons due to the ongoing
   pandemic, Mr. Ma was able to take 16 weeks of the First Step Act classes and training to
   become a tutor. He was waitlisted for anger management and drug programs, but
   programming has been on hold throughout the pandemic. He has taken several
   correspondence courses in Christianity and has read numerous books during the BOP
   lockdown, including books on morality and ethics, addiction, anger management, and
   emotional control. Mr. Ma has been taking courses every Thursday through Columbia
   University at the MDC. These classes have been very important to Mr. Ma, and he has
   scheduled all legal visits around his classes.




   Mr. Ma’s new life in the United States

   After graduating from UCLA, Mr. Ma relocated to New York City. Shortly after moving here, he
   met Elizabeth Turner-Ma (now age 28) through an online dating service, and they married on
   December 24, 2015.

   Mrs. Turner-Ma graduated from New York University, the Galetin School of Individualized
   Study, in 2020. Mrs. Turner-Ma had majored in journalism at NYU, but came to realize that the
   meager salary offered by a journalism career could not support a life in New York City. After
   graduating, she decided to pursue her dream of becoming an actor, and was temporarily
   residing in Los Angeles from May 2020 to July/August 2020. She was in Los Angeles when
   Mr. Ma was arrested on this matter. When Ms. Turner-Ma returned from Los Angeles, she was
   struggling to pay the mortgage on her own. To save money, she moved in with Mr. Ma’s
   parents, and their West End apartment has been rented to tenants. She has had a difficult time
   coping since his incarceration, concerned that the government would believe she was
   involved in the offense, and has found refuge in her religion and reading books. She has been
   earning income by selling essential oils and paleo baked goods, which she makes herself.

   Mr. Ma describes his wife as having a pure heart, and being of high moral character. She was
   raised with Puritan Christian values, experiencing a very strict religious upbringing. Mrs.
   Turner-Ma grew up in a suburb of Harrisburg, Pennsylvania, and against the wishes of her
   family, she moved to New York City to attend New York University, where she majored in



                                   9
                Case 1:20-cr-00407-RMB Document 61 Filed 04/04/22 Page 25 of 232




                      journalism. Her family refused to finance her education, because they wanted her to return
                      home to become a teacher. In an apparent attempt to convince Mrs. Turner-Ma to come
                      home, her mother contacted NYU officials to advise that her daughter had a serious mental
                      health condition; as a result, the school required her to participate in mental health counseling
                      as a condition of her continued enrollment. She struggled financially, and was homeless for
                      about a year during 2014, sometimes sleeping in her car. Mrs. Turner-Ma moved in with Mr.
                      Ma in August 2015, shortly before their marriage, in order to save money.

                      Mr. Ma believes that his wife suffers from Post Traumatic Stress Disorder due to something that
                      happened in her family, and she meets with a psychologist on a regular basis. He recalls that
                      she would often awake during the night, crying and yelling her mother’s name, but she would
                      tell him it was too painful to discuss. According to an online memory page in honor of Mrs.
                      Turner-Ma’s grandmother, Mary Alice Butkofsky, her mother wrote:

                              In the late 1980’s I went through a major trauma at Grace Chapel. Things began to shut
                              down in the church due to some unusual events. I met Nelson Turner during that time
                              and attended his Bible Group. He and his friends prayed diligently for me due to the
                              “attack” that I had received at Grace Chapel and they successfully delivered me of the
                              situation that had come against me. I married Nelson for these reasons, but this was not
                              as God had planned. I did give birth to my daughter, Elisabeth Deborah Turner during
                              this marriage. When she was one year old we left due to serious circumstances.
                              Elisabeth and I lived happily at Lakewood Hills Apartments in Harrisburg for 8 years.8

                      Mrs. Taylor-Ma’s mother spoke about her daughter’s life; that mother and daughter left their
                      home due to “serious circumstances”; that her daughter studied communications at Hofstra
                      University; that she transferred to New York University (NYU) in her third year against the
                      wishes of her family (for financial reasons); that she “worked for Hammer Mage” in New York
                      City, where she was residing; and that she visited her grandmother three times between 2017
                      and 2018. There is no mention of her marriage to Mr. Ma in 2015. Mr. Ma describes his wife
                      as having “carrie[d] a bevy of hefty trauma and pains throughout her life.” According to Mr.
                      Ma, his parents treat her as their own daughter. His parents recently informed him that his
                      wife suffered a heart attack during the government's investigation. “This makes me
                      heartbroken.”

                      In May 2018, Mr. Ma’s parents purchased the one-bedroom condominium on West End
                      Avenue (the address of record), and put the deed in the name of Mr. Ma and his father. Mr.


8 https://maryalicememoirs.wordpress.com/




                                                      10
Case 1:20-cr-00407-RMB Document 61 Filed 04/04/22 Page 26 of 232




   Ma was residing there at the time of his arrest, and as of July 2018, was running his business
   from the apartment. In April 2020, approximately one month into the COVID pandemic, his
   wife traveled to Los Angeles for three weeks to seek work as a screenplay writer or actor,
   professions she had been preparing for throughout her life. She had taken acting and dance
   classes, and had even written two screenplays before meeting Mr. Ma, and seeking work in
   Hollywood was the obvious next step for her. Although Mr. Ma was unable to leave his
   businesses to travel with her, they planned to travel back and forth to see each other. Mr. Ma
   and his parents were supportive of her, but Mr. Ma did not want her to leave. His parents love
   her as if she were their own daughter, but Mr. Ma has never met anyone in his wife’s family.
   They have maintained contact by writing letters to each other while Mr. Ma has been
   incarcerated.

   Mr. Ma was arrested on May 21, 2020, before his wife’s return from Los Angeles. At the time of
   his arrest, case agents also contacted his wife for questioning, which was very intimidating for
   her. Although she had done some work for his businesses, she had no involvement in the loan
   applications involved in the instant offense. Mr. Ma had used her NYIC corporate email
   address in connection with the offense, resulting in his conviction for aggravated identity theft.
   His wife returned from Los Angeles in August 2021, after exhausting all of her work prospects,
   which were already limited due to the pandemic. She moved in with Mr. Ma’s parents because
   she could not afford to pay the expenses on the apartment by herself. His parents gave her
   their bedroom, and they slept in the living room. On March 31, 2022, the parents relocated
   with Mrs. Turner-Ma to another one-bedroom apartment in the Coney Island section of
   Brooklyn, in order save money on rent.




   Mr. Ma’s family needs him

   Mr. Ma has always had a loving relationship with his parents; he also respects them and
   heeds their advice. He speaks to them every day when there isn’t a lockdown at the MDC.
   His parents were residing in China when the COVID pandemic hit their country, during
   November 2019. The pandemic had already ravaged their businesses by the time they
   traveled to Manhattan in January 2020; unfortunately, the Chinese government would not
   permit them to return home due to pandemic restrictions, and their businesses-two retail
   stores and a daycare-are barely operational. They have been struggling financially due to the
   pandemic, especially since they are also supporting their son’s wife; Mr. Ma was the primary
   means of financial support for his parents and his wife before his arrest. His parents’ only
   other income was a meager monthly pension from China in the combined amount of $1,000,



                                   11
Case 1:20-cr-00407-RMB Document 61 Filed 04/04/22 Page 27 of 232




   and his wife has only recently begun to sell essential oils and baked goods. As noted
   previously, they had to rent out Mr. Ma’s apartment to tenants for $4,750 in monthly rental
   income because they needed the income. Since his incarceration, they have been relying on
   assistance from family and friends, and have been taking out loans.

   Prior to his arrest, Mr. Ma’s parents were dependent on him for physical assistance as well as
   financial assistance. His parents are 66 years of age, and have numerous health problems.
   His mother has knee problems, and she has trouble walking; she has had several heart
   attacks; and she has vision problems. In addition, on March 29, 2022, his mother was seen at
   the New York Eye Hospital, where she was advised that she has cataracts in both eyes and
   will require surgery. Mr. Ma’s father has hypertension and has had multiple heart attacks; low
   blood sugar; and knee degeneration-the father often requires a wheelchair. According to the
   mother, his father also suffers from cholecystitis and cerebral infarction. Mr. Ma would take
   them to all of their medical appointments, because his parents do not speak the English
   language, and were reliant on him to serve as their translator. They currently rely on the
   Google Translate app in order to communicate.

   Mr. Ma’s parents need his help more than ever. In late March 2022, family visits at the MDC
   commenced after the long lockdown. Mr. Ma’s parents were scheduled to visit with him on
   March 25, but even this happy occasion was marred by tragedy. His parents had traveled to
   the MDC, but as they maneuvered around the fencing at MDC’s entrance, his father took a
   serious fall. MDC staff quickly came to his rescue, and called for an ambulance. His father
   underwent major hip surgery, in which the hip joint and thigh bone were replaced with artificial
   bones, and it will take many months for him to recover. His father’s debilitating injury and
   anticipated lengthy rehabilitation makes it even more important for Mr. Ma to reunite with his
   family. Notably, although the parents have relocated to a new apartment, they continue to
   sleep in the living room, while Mr. Ma’s wife sleeps in the bedroom. Mr. Ma’s parents have
   serious health problems, and limited financial resources, and are desperate to have their son
   home again. Mr. Ma was the primary source of financial support for his parents and his wife
   prior to his arrest, and they are struggling financially in his absence. Mr. Ma’s mother is deeply
   saddened by her son’s legal situation, and wants him to come home:

         But, in 2020, yet another greater doom befell our family. What was originally a good
         wish turned into a crime in an instant. I know my son, he has always been a law-
         abiding man. He has always been a sunny, kind-hearted and idealistic person. A
         capable young man. The occurrence of this incident is just a stupid mistake made by
         him on the basis of a wrong understanding of the policy. I guarantee with my life that he
         never intended to commit a crime. Moreover, after his reflection, he took the initiative to


                                   12
                Case 1:20-cr-00407-RMB Document 61 Filed 04/04/22 Page 28 of 232




                              cancel the loans as soon as possible, without spending a penny, without causing any
                              loss to any institution. And he has been severely punished.




                      Mr. Ma has endured extraordinarily harsh conditions while awaiting sentence

                      COVID-19 Pandemic

                      Mr. Ma has remained incarcerated during the entirety of the unrelenting COVID-19 pandemic,
                      which commenced in early 2020. He received the Johnson & Johnson vaccine in April 2021,
                      and the Pfizer booster in November/December 2021. On January 7, 2022, Mr. Ma tested
                      positive for COVID-19, and was moved to an isolation unit where he was confined 24 hours
                      per day. He initially suffered from acute symptoms, including fever, chills, coughing and
                      weakness, progressing to loss of taste, breathing problems, brain fog and loss of memory.
                      MDC officials provided no medical treatment to Mr. Ma, but advised him to purchase over the
                      counter pain medication through his commissary account. In an effort to stave off
                      gynecomastia, he continued to work out although he was symptomatic, but his reduced lung
                      capacity limited him to low intensity exercise. As of March 21, 2022, Mr. Ma has continued to
                      experience “long COVID” symptoms, including brain fog. As evidenced during multiple
                      interviews with Mr. Ma, he tires easily, and has difficulty engaging with this writer as the
                      interviews have progressed.

                      Although the pandemic has become less deadly over time due to the development of effective
                      vaccines, the number of infections spiked dramatically due to the more infectious Omicron
                      variant. The World Health Organization (WHO) is presently monitoring a variant of concern,
                      Omicron’s sublineages BA.1 and BA.2, which could potentially produce future virus spikes.
                      The COVID-19 pandemic continues to jeopardize inmates at the Bureau of Prisons. According
                      to the BOP’s own website, as of February 24, 2022, there are 1,257 federal inmates and 1,397
                      BOP staff who presently have confirmed positive test results for COVID-19 nationwide. As of
                      the same date, 54,315 inmates have tested positive for COVID-19 infections since the
                      beginning of the pandemic; there have been 285 inmate deaths.9 The BOP has been
                      reviewing all inmates whom they deem as having COVID-19 risk factors, and moving the
                      suitable candidates to home confinement in lieu of continued incarceration. Between March
                      26, 2020, and February 24, 2022, they moved 38,452 inmates to home confinement settings.
                      The MDC in Brooklyn, NY, remained under lockdown due to the current COVID threat until only


9 https://www.bop.gov/coronavirus/




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                          recently, and during that time, inmates were permitted to leave their cells for only 30 minutes
                          every other day to shower and use the computer email system. While this restrictive practice
                          was for the health benefit of staff and inmates, it significantly limited Mr. Ma’s contact with his
                          family and his ability to participate in programming.

                          Inhumane conditions at the MCC

                          Mr. Ma was housed at the Metropolitan Correctional Center (MCC) in New York from 2020 to
                          2021. The MCC was already under scrutiny for the recent suicide of Jeffrey Epstein, an
                          inmate’s death, and repeated complaints from inmates about the squalid conditions. When
                          the COVID pandemic hit, MCC staff were unable to obtain masks; when the staff restrooms ran
                          out of soap, the workers in charge of filling the dispensers were suddenly thrust into duty as
                          correctional officers due to staffing shortages. In May 2020, a court-authorized inspection
                          found that inmates with coronavirus symptoms were neglected, and social distancing was
                          almost nonexistent, with some inmates sleeping on bunks within arm’s reach of each other.10
                          Mr. Ma was transferred to the Metropolitan Detention Center in Brooklyn shortly before the
                          MCC was shuttered in August 2021.

                          During Mr. Ma’s time at the MCC, there were numerous quality of life issues. Several lights
                          were broken in his unit and cell, and with the lack of sunlight, he struggled to read and
                          prepare for his case in the darkness. Toilets overflowed on a regular basis, and the stench
                          permeated the entire unit. With no protective gear, inmates used their bare hands to clean the
                          raw sewage that had overflowed. Ventilation fans were either working poorly or not working at
                          all, actually resulting in the closure of two units in May and June 2021. Bedding was tattered,
                          and their bunks were rusted. Mold covered surfaces in the common shower area. Mice and
                          cockroaches were regular visitors.

                                   Mice and cockroaches were running around all day. One day a mouse jumped on my
                                   hand when I was working out; the other day another mouse jumped on my leg when I
                                   was about to sleep. Many friends had the experience that mice jumped on their face
                                   when sleeping. It so often that we saw mice and roaches jumped out of our lockers,
                                   which could not be locked for they were broken, leaving ravages on our properties. It
                                   was easy for them to jump on our tables if food was kept there just for a while, because
                                   tables were broken too.




10 https://pix11.com/news/local-news/controversial-manhattan-jail-mcc-set-to-close-u-s-dept-of-justice-says/




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                         COVID-19 was rampant in the MCC, and inmates would sometimes wait for months to be seen
                         by the medical department. The units were very cold, and thermal wear was hard to come by
                         in the commissary. Milk and fruit were at times spoiled, and some food items were being
                         served beyond their expiration date. Due to the pandemic, inmates did not have access to
                         the law library, and there were no church services, laundry or on-site programming. Inmates
                         were also unable to access the roof, where they would be able to experience some sunlight
                         and fresh air.

                                   Washed clothes, towels and beddings were hung on the pipes of the ceiling and bunks,
                                   like a horrible third world shanty or a refuge in a war zone.

                         Dangerous conditions at the MDC Brooklyn

                         Due to the impending closure of the MCC, Mr. Ma was transferred to the MDC in Spring of
                         2021. In October 2021, David Patton, Chief of the Federal Defenders Manhattan Office,
                         announced that inmates at the facility were subsisting in deteriorating living conditions, and
                         called for an outside regulatory authority to intervene.11 He cited reports that inmates had no
                         access to water, lacked hot food, and had spotty electricity. Approximately 100 inmates from
                         the shuttered MCC were moved to the MDC during the summer of 2021, and combined with
                         staff shortages, MDC staff have reported “overwhelming and dangerous conditions.” Civil
                         rights attorney Andrew Laufer reported that the MDC and MCC have “very similar habitability
                         problems. Heating and cooling are very poor, sanitary conditions, infestation of insects,
                         sewage-you name it. It’s just a mess.”12 He went on to say, “There’s a lack of supervision,
                         which allows prisoners to attack other prisoners regularly, [and allows] rampant drug use and
                         contraband that’s smuggled in.” “There’s also abuse by corrections officers against prisoners
                         themselves. These officers are just undisciplined.”

                         US District Court Judge Colleen McMahon criticized the conditions at the MDC in April 2021,
                         describing the conditions as “disgusting.” “The single thing in the five years that I was chief
                         judge of this court that made me the craziest was my complete and utter inability to do
                         anything meaningful about the conditions…at the MCC and the MDC, [which] are run by
                         morons.” “There is no continuity, there is no leadership, there is no ability to get anything
                         done. They lurch from crisis to crisis….”


11 https://www.ny1.com/nyc/all-boroughs/inside-city-hall/2021/10/14/metropolitan-detention-center-in-brooklyn-nyc-reports-dangerous-

conditions-david-patton-discussion

12 https://www.ny1.com/nyc/all-boroughs/inside-city-hall/2021/10/14/metropol tan-detention-center-in-brooklyn-nyc-reports-dangerous-cond tions-david-patton-

discussion




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                       Mr. Ma had hoped the conditions at the MDC would be an improvement; however, he
                       experienced similar quality of life issues to those he experienced at the MCC. Although the
                       MDC has been on lockdown for most of his time there, when he has been free to leave his cell,
                       he experienced gang activity; gangs would monopolize essentials such as food and phones,
                       and would control showers, yard space and other life essentials. Gang violence would lead to
                       frequent lockdowns, on top of the COVID restrictions inmates were already enduring. In
                       addition, Mr. Ma was personally subject to threats from other inmates simply because he is an
                       Asian male. While Mr. Ma was in Unit 83, he received threats from Ibrahim Aksakal, another
                       inmate in his unit. Mr. Aksakal has a known history of violence, and threatened Mr. Ma with
                       bodily injury. As a result, Mr. Ma was moved to Unit 82; however, the threats continued.

                       Inmate unrest in Mr. Ma’s new unit

                       Mr. Ma was transferred from MDC Unit 83 to Unit 82 on January 21, 2022. Due to the
                       COVID-19 restrictions, inmates were not permitted to attend their job assignments in the
                       kitchen, and due to the limited kitchen staff, inmates were only being provided with cold food,
                       such as sandwiches. On February 12, the day before Super Bowl Sunday, inmates in his unit
                       decided to protest; they were banging on their cell doors, and some were refusing the food
                       that was being delivered to them, while threatening other inmates to not accept the food. Mr.
                       Ma was the only inmate willing to take the food. Officers from all parts of the MDC came to the
                       unit to remove the agitators from their cells. Mr. Ma reports that the prison staff protected him,
                       and he has written letters to the Warden commending them for their actions.

                       Lockdown due to staff assault in USP Beaufort

                       On January 31, 2022, every BOP facility in the United States was locked down due to a gang
                       assault at USP Beaumont, a federal prison in Beaufort, Texas, by members of the violent
                       MS-13 gang.13 Two inmates were killed and others were injured in the melee. In addition to
                       the COVID restrictions that were already in place, legal calls and videoconferences were also
                       denied to inmates. Mr. Ma was not permitted to shower, or use the phone or computer (he
                       was denied contact of any kind with family and legal counsel). On February 16, 2022, multiple
                       staff members were assaulted by inmates at the MDC Brooklyn, resulting in a continuation of
                       the lockdown, which lifted on February 22, 2022. Mr. Ma continued to receive cold meals14,
                       and was permitted to leave his cell to shower every two days for 10 minutes. Mr. Ma reported
                       that they had no access to commissary during the ensuing lockdown, and because he is a

13 https://apnews.com/article/texas-prison-fight-federal-lockdown-a0e7b61c5bdc5bbc25a691cc0a6920ba


14 Since the MDC was on lockdown, the inmates assigned to work in the kitchen could not prepare hot meals.




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   vegetarian, he was given only cold peanut butter sandwiches and apple slices-for every
   single meal. After the lockdown was lifted, he once again began to receive his regular
   vegetarian meals; however, due to the length of time that his food intake was restricted, he
   was diagnosed with malnutrition.

   Mr. Ma’s pretrial experience has been physically and emotionally brutal. He has been denied
   visitation with his family for the past two years due to the COVID pandemic, and as noted
   above, all communication with his family was on hold for an extended period of time due to
   prison unrest that he played no part in.




   Looking toward the future

   Despite the traumatizing experiences Muge Ma has endured while incarcerated, he remains
   optimistic about the future and has been working toward a reunion with his family. He has a
   strong work ethic, and has worked hard to achieve everything he has attained. To increase
   his marketability upon his release, he is enrolled in a12-week college course in finance and
   management at the MDC, sponsored by Columbia University. As noted previously, Mr. Ma has
   participated in as many programs as he could given the pandemic restrictions.

   Mr. Ma will be 38 years old on the date of his sentence, and this is his first and only encounter
   with the criminal justice system. In all of these years, in spite of the traumas he experienced
   during his youth, he has never experimented with controlled substances, and has never used
   social drugs such as marijuana. He does not even consume alcohol. In the Probation
   Department’s recommendation, it is noted that “Although the defendant does not have any
   illegal substance abuse concerns, he does take several supplements, some of which may
   have unknown illegal controlled substances in them. As such, it is recommended that the
   drug testing condition remain.” There is no suggestion, never mind any evidence, that Mr. Ma
   has been taking supplements which contain controlled substances. Therefore, the condition
   specifying ongoing drug testing is unwarranted and should be removed. As mentioned
   previously, Mr. Ma was taking testosterone before his arrest in order to mitigate his
   gynecomastia; notably, the Bureau of Prisons has not provided testosterone to Mr. Ma, and he
   is at risk of developing enlarged breasts. The Probation Department’s recommendation also
   suggests that Mr. Ma should “continue treatment” for his mental health concerns; however, it
   should be noted that other than a handful of counseling sessions while at the MCC last year,
   he has not received any mental health treatment. In view of his history of torment and sexual
   abuse as a child, mental health treatment would certainly be beneficial for Mr. Ma.



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   Many letters have been sent to the Court by Mr. Ma’s parents, extended family, classmates,
   friends, customers and a former employer. Letters submitted by his parents describe their son
   as intelligent, generous and kind, and attest to their anguish and feelings of loss. Mr. Ma is the
   primary source of financial support to his parents and wife, Elisabeth, and he faces possible
   deportation. If he is deported, it would be financially devastating to his family, yet it is a real
   possibility despite the fact that he is a lawful permanent resident.

   Although the Probation Department has recommended a sentence of 75 months
   imprisonment, the multitude of mitigating factors outline herein have not been fully considered
   in the formulation of their recommended sentence. Based on the mitigating information
   provided herein, and in consideration of sentences previously imposed on similarly-situated
   defendants, it is respectfully requested that the Court sentence Mr. Ma to Time Served on
   Count 2, to run consecutively to the mandatory 2 years required by Count 8. Mr. Ma has been
   in custody since May 21, 2020, and will have served 23 months at the time of his sentencing
   on April 21, 2022. If the Court should impose the recommended sentence, in consideration of
   the Good Conduct Time Mr. Ma has likely accrued to date, his release date would have been
   in January 2022.

   It is respectfully requested that the Court free Mr. Ma from the unsafe and mentally anguishing
   conditions at the Bureau of Prisons, and allow him to be reunited with his family.




   Sincerely yours,



   Leslie S. Lockwood, MSW




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