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Home Source documents Court filing — United States v. Farah (Dkt. 855, D. Minn.)

Court filing — United States v. Farah (Dkt. 855, D. Minn.)

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UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF MINNESOTA
Criminal No. 22-cr-00124 NEB-DTS
————————————————————-X
UNITED STATES OF AMERICA,            )
                                     )                       HAYAT MOHAMED NUR
              Plaintiff,             )                       POSITION REGARDING
                                     )                       SENTENCING
                                     )
      -against-                      )
                                     )
HAYAT MOHAMED NUR                    )
                                     )
              Defendant.             )
————————————————————X

                                              Introduction

     Defendant Hayat Mohamed Nur (“Hayat”), by and through her counsel, Barry S. Zone,

Esq., respectfully moves the Court for a downward departure by way of downward adjustments

in the United States Sentencing Guidelines (the “Guidelines”), and a downward variance from

the applicable Guidelines.



     We make these motions upon:

     (1) all the files and proceedings in this case;

     (2) Hayat’s position regarding sentencing, which is a sentence of 18 months custody.

followed by three years of supervised release, six months of home confinement, 300 hours of

community service, mental health treatment, and orders of restitution in an amount to be

determined by the Court and forfeiture in the amount of $30,000.00; and




                                           Page 1 of 20
     (3) the further points and authorities that we will present to the Court, including the

anticipated arguments of counsel and the personal statement of Hayat at her sentencing hearing

on August 26, 2025.



     As the Court knows, Hayat was one of the seven defendants at the first Feeding Our Future

trial last year. She was convicted of three substantive and conspiratorial wire fraud counts of the

indictment (counts one, 10 and 11) and acquitted of two counts (four and 34), one substantive

wire fraud count and one money laundering count.



     Hayat is deeply remorseful for her many significant errors in judgment. If she could take

back time, she would change so many of the actions she took.



                       United States Sentencing Guidelines Calculation

     We begin with a suggestion that the Court calculate Hayat’s Sentencing Guidelines as

follows:

     • Base Offense Level: 7

     Because the statutory maximum term of incarceration is 20 years, the base offense level is

7. See U.S.S.G. §2B1.1(a)(1).

     • Loss Enhancement: +20

     We ask the Court to find that the loss that is reasonably foreseeable to Hayat as to the

counts of conviction and the supporting evidence is more than $9,500,000.00 but not more than




                                          Page 2 of 20
$25,000,000.00. Therefore, a 20-level Guidelines enhancement should apply. See U.S.S.G.

§2B1.1(b)(1)(L).



      Here is our rationale:

      In one of the counts of conviction, Count 10, Hayat is charged with sending an invoice on

January 5, 2022, which was at the very end of the conspiracy. With no connection to these

entities, financial or otherwise, and in a purely clerical capacity, Hayat sent the invoice to

Partners In Nutrition, and it reflected that ThinkTechAct was entitled to more than $2 million in

Federal Child Nutrition Program (“FCNP”) funds for meals purportedly served to children

during the prior month of December 2021. See PSR, par. 52.



      In addition, Hayat was convicted of Count 11. The jury received evidence that a week

later, on January 12, 2022, at the direction of her brother and co-defendant Abdimajid Nur, Hayat

sent to her brother and his boss and co-defendant Abdiaziz Farah an invoice purporting to show

that ThinkTechAct owed more than $2 million to Mr. Farah’s company, Empire Enterprises, for

serving meals at ThinkTechAct sites in April 2021. See PSR, par. 52.



      As to Count 10, even though Hayat had no involvement with any federal program or food

distribution, the jury also received evidence demonstrating that Hayat sent, again in a purely

clerical capacity, invoices purporting to document the purchase of more than $10 million in food

and expenses related to the FCNP. See PSR, par 56.




                                           Page 3 of 20
      Therefore, because according to the trial evidence it appears that a loss amount of $14

million was reasonably foreseeable to Hayat, we ask the Court to increase her Guidelines by 20

levels.



      • Role Adjustment:      -4

      The Court should find that Hayat is entitled to a four-level minimal role adjustment. Her

involvement appears to have been largely limited to administrative tasks at the request of her

brother at the very end of the conspiracy and just before the defendants were arrested. Hayat had

absolutely no decision-making authority or financial control within the conspiracy; nor did she

recruit or direct anyone else. The evidence presented at trial indicates that her activities were

confined to submitting meal count forms, invoices, and rosters, often based on templates that

were provided to her. Her lack of knowledge regarding the scope of the scheme supports the

conclusion that she acted with limited awareness and without any significant role in its

orchestration or execution.



      While the Presentence Investigation Report (“PSR”) includes Hayat in the overall loss

assessment of $50 million; the evidence appears to show that she received $30,000.00, less than

one tenth of one percent, which further underscores her lack of financial benefit and extremely

limited involvement in the scheme.



      While the government introduced meal rosters, invoices, and other documents used to

advance fraud, Hayat had no connection to the broader scope of the claimed loss. Her actions


                                           Page 4 of 20
appear to have been limited to clerical duties and did not involve financial transactions,

management, or direct control over funds.



      • Zero Point Offender:              -2

      Hayat is a zero-point offender as she meets the criteria of U.S.S.G. §§4C1.1(a)(1)-(10).

Therefore, she asks the Court to find that she is entitled to a two-level Guidelines reduction

pursuant to U.S.S.G. §4C1.1(a) and (b). See PSR, par. 110.



      • No Sophisticated Means: 0

      The Court should not find the two-level enhancement for sophisticated means under

U.S.S.G. §2B1.1(b)(10). While the government’s case portrays as complex the overall scheme,

the role apparently attributable to Hayat did not involve any sophistication. While the conspiracy

involved a network of co-defendants, shell entities, and fraudulent documents, which may

collectively reflect sophistication, none of this was reasonably foreseeable to Hayat, and her

apparent minimal role looks as if it was limited to administrative tasks, and she lacked both the

authority and ability to influence the scheme's complexity. Her contributions appear to have

consisted largely of completing templates and forms provided by others, and did not require any

specialized knowledge, decision-making, or the strategic creation of shell companies. She

apparently followed instructions to input information into documents without involvement in any

intricate or deceptive planning that would characterize sophisticated means.




                                          Page 5 of 20
      • Emergency Benefits:                +2

      Because the offense involved fraud in connection with emergency benefits, which is

conduct described in 18 U.S.C. §1040, a two-level Guidelines increase should apply. See

U.S.S.G. §2B1.1(b)(12); see also PSR, par. 105.

      Adjusted Offense Level:        23 (Criminal History Category I)

      = Advisory Range of 46 - 57 Months of Incarceration



                                             Argument

      I did not have the honor of being Hayat’s lawyer at that time of her trial, but I carefully

read the trial transcripts, and I conferred extensively with Edward Sapone, trial counsel to

Hayat’s brother, Abdimajid Nur. What is obvious to me is the stark difference between Hayat

and her co-defendants. Whether Your Honor finds that Hayat is a minimal participant, as I ask

you to find, or a minor participant, as the PSR at paragraph 97 suggests, mindful of the need to

avoid unwarranted sentence disparities among similar defendants, I respectfully urge the Court to

find that the evidence against Hayat was, by far, the least of all of the trial defendants.



      As mentioned above, I submit this sentencing memorandum with the hope that I will

succeed in convincing the Court to find that a sentence of 18 month’s custody with regular

conditions and special conditions of supervised release including home confinement, community

service and mental health treatment is sufficient but not greater than necessary to achieve the

goals of sentencing under 18 U.S.C. §3553(a)(2).




                                            Page 6 of 20
      As we consider the nature and circumstances of the offense, I am confident that Your

Honor discerned during the trial that Hayat’s involvement was at the request of her brother, was

11th hour, and was extremely limited. In no way is this offered as an excuse, as we are all

responsible for our actions. Hayat, nonetheless, is different from the lion’s share of fraud

defendants who end up in a prison jump suit because they are greedy. While it is impossible to

totally divorce greed from a fraud case, Hayat’s actions were not fueled by greed. In a male-

dominated environment, Hayat’s brother approached her with desperation. Of course, she should

have exercised the wisdom and courage to decline his desperate plea; that she didn’t, underscores

the reality that Hayat needs additional mental health treatment to further strengthen her resolve.1

She misunderstood how love acts, especially during times of adversity. And, at age 25, she made

the worst mistake of her young life.



      But, thankfully, we sentence the whole person. And while Hayat’s actions in failing to turn

her brother away deserve condemnation, she deserves praise for having taken positive steps to

self-rehabilitate and for having lived her life consistently extending a helping hand to others.



                              Positive Steps Towards Self-Rehabilitation

      Since Hayat’s detention at the Sherburne County Jail 16 months ago, once of the positive

steps she has taken to change her life has been to participate consistently in group mental health

therapy. She completed a lengthy voluntary program, which contained multiple consecutive



1 As will be explained later in the memorandum, Hayat has engaged in voluntary mental health treatment while
detained.

                                                Page 7 of 20
group sessions from which participants can withdraw at any time. See Exhibit A . The sessions

that Hayat completed include:

      • Grief and Loss Group (Nine Weeks);

      • Trauma-Informed (TI) Group (Eight Weeks);

      • Life Skills Group (Six Weeks);

      • CBT Group (Eight Weeks); and

      • Mini DBT Group (10 Weeks).

      Each of the groups met once weekly for one to one-and-a-half hours. The purpose of the

groups is to increase awareness of stressors, triggers and emotions, and to teach coping skills for

clients to utilize when faced with difficult situations.



      And Hayat continues to do all she can do to self-rehabilitate. To that end she has

participated in all available additional groups that are offered at the jail. For example, she

currently participates in the Psychoeducation Group, which is the final open therapeutic group.

As of August 8th, she has completed three weeks of the six-week program.



      Based on her excellent behavior Hayat was also selected as an inmate worker, and in

connection with this designation she works extensively in the commissary sorting packages and

inmate orders, as a podworker in the housing unit, where she cleans and organizes and with meal

service 3 times daily. Captain J.D. Coolidge describes Hayat as an asset to the facility. See

Exhibit B




                                            Page 8 of 20
      The extraordinary effort that Hayat has made since her detention 16 months ago is

consistent with her effort throughout her life to support her friends, neighbors, and family.

      Fowziya Ahmed, a friend of Hayat’s who almost died in a car accident, shares:

                 Hayat’s role in my recovery was beyond that of a neighbor; she
                 was my caregiver, translator, and advocate. My mother reached
                 out to Hayat for help, and she immediately responded, coming to
                 the hospital every single day—after work and classes, despite the
                 demands of her own life as a graduate student. For the entire four
                 months I was hospitalized, Hayat was there by my side, ensuring
                 that I received the proper care and helping to communicate with
                 medical staff. Even after my discharge, Hayat continued to assist
                 me, driving me to every physical therapy session and making sure
                 my family had the support they needed.

See Exhibit C.

      Amino Nur, Hayat’s mother, writes:

                 Hayat has always been mature beyond her years. While other
                 teenagers were focused on having fun, she was helping me care
                 for her younger siblings. At just 14 years old, she started
                 working to help support our family while still excelling in school.
                 Despite her busy schedule, she managed to be at the top of her
                 class. She would stay up late into the night studying to achieve
                 her goals, which led her to graduate high school with honors,
                 followed by completing both her undergraduate and master’s
                 degrees with the same distinction.

See Exhibit D.

      Imam Q. Mursal, the Imam of the Dar-Us-Salam Mosque, explains:

                 Hayat is a dynamic and driven individual who has consistently
                 demonstrated her potential as a leader and a role model. Despite
                 her young age, she has made significant contributions to our
                 mosque, particularly within the women’s section, where she has
                 taken on responsibilities that foster growth, connection, and
                 support among members. Her efforts, especially during the holy
                 month of Ramadan, have been instrumental in creating meaningful
                 programs and fostering a welcoming and nurturing environment.

                                           Page 9 of 20
See Exhibit E.

     Hayat’s husband, Hussein Abdulaziz, tells us:

                 Throughout her life, Hayat has consistently placed others' needs
                 before her own. In addition to her support for her brother, she has
                 also demonstrated an unwavering passion for working with
                 children with special needs. Her empathy and ability to connect
                 with these children are truly extraordinary, and she has made a
                 lasting difference in their lives.    Her dedication to serving
                 others, whether it’s through her family or her work with special-
                 needs children, has been an integral part of who she is.

See Exhibit F.

     Idil Hassan, a family friend, adds:

                 In her personal and professional life, Hayat is known for her
                 integrity and work ethic. Her honesty and dedication are evident in
                 how she fulfills her obligations, no matter the circumstance. Hayat
                 is respected for her ability to handle challenges with calmness,
                 insight, and resilience, often guiding others through difficult
                 situations with grace and understanding.

See Exhibit G.

     Hayat’s best friend, Marian Mohamed, writes:

                 As the eldest daughter in an immigrant household, she understood
                 the weight of setting a positive example for her younger siblings. I
                 vividly remember late-night study sessions, where Hayat, despite
                 being a full-time student, also worked two jobs. She juggled so
                 much with such determination and strength, and I often found
                 myself thinking, ‘She’s a Superwoman’.

See Exhibit H.

      Mohamed Nur, Hayat’s father, talks about Hayat’s selflessness when she was barely 20
years of age:

                 When I finally joined my family in the United States, Hayat’s
                 support continued to be invaluable. She helped me navigate the

                                           Page 10 of 20
                 difficult transition of settling into a new country. Hayat assisted me
                 in applying for jobs, understanding the systems in place, and
                 adjusting to a completely new life. Her resilience, intelligence, and
                 determination to help others have always been part of her
                 character.

See Exhibit I.

     Hayat’s friend, Nasib Jama, adds:

                 Hayat is a remarkable individual, known to all who have had the
                 privilege of knowing her for her intelligence, diligence, and
                 unwavering commitment to personal growth. She earned her
                 master's degree, a testament to her dedication and perseverance in
                 the pursuit of knowledge and career. Throughout our friendship, I
                 have observed her deep compassion for others and her constant
                 efforts to make a positive impact in her Community.

See Exhibit J.

      Sadia Mohamed, Hayat’s sister-in-law, explains:

                 When I became pregnant and faced severe sickness throughout all
                 my pregnancies, Hayat went out of her way to help me, often
                 visiting and making sure I had what I needed. She truly cared for
                 my well-being, and her support made such a difficult time much
                 easier to endure.

See Exhibit K.

      Hayat’s friend, Sagal Mohamud, writes of Hayat’s responsibility, helpfulness, support, and

work ethic:

                 Hayat always had a sense of responsibility towards her family and
                 anything she was assigned to do. I have witnessed her dedication to
                 support her family and the community at large. For example,
                 during the holy month of Ramadan, I would often see her at the
                 mosque providing for and helping others in breaking their fasts. I
                 would frequently see her support for her younger sister by taking
                 part in her high-school events and meetings. Most importantly,
                 Hayat had the most admirable work ethic.


                                           Page 11 of 20
See Exhibit L.

         Sheymaa Nur, Hayat’s younger sister, gives us a window into Hayat’s character since

Hayat was a young girl:

                 Hayat was always by my side growing up, particularly during my
                 school years. Her support has been a guiding force, especially
                 when I felt uncertain about myself or my future. I can’t count the
                 number of times she would sit down with me before an important
                 test, presentation, or school event, offering words of
                 encouragement that helped me stay calm and confident.

See Exhibit M.

         Notwithstanding Hayat’s errors in judgement, Yasmin Jama, a mental health professional,
notes:

                 Hayat is deeply committed to her family, always prioritizing their
                 needs and providing emotional support during times of hardship.
                 She is known to be the one family members turn to for guidance,
                 and her ability to nurture and care for those around her speaks
                 volumes about her character. Her honesty, dependability, and
                 strong sense of duty have earned her the respect and admiration of
                 all who know her.

See Exhibit N.

            Hayat’s Career Demonstrates That She Is Driven To Help Those In Need

      All of the good works that Hayat has done for countless neighbors and members of our

community is consistent with the kind of person she has always been. She is a very smart

woman who could have chosen just about any career. Hayat chose to work in human services to

serve the most vulnerable members of the community. She has served those most in need of

help, the neglected members of society, those abused and traumatized, and those who suffer with

disabilities.

      In a letter to the Court, Hayat explains:

                                          Page 12 of 20
                 I really do want the Court to understand that the conduct that I was
                 convicted of doesn’t define who I am, and what I have been
                 through in my life up to my involvement in this case. I spent years
                 working in the human services field serving my community,
                 particularly those most vulnerable: the disabled, the abused, the
                 neglected, and the traumatized. Since my graduation from high
                 school in 2015, throughout my college years and post-graduation, I
                 have always held jobs and roles that involved assisting and
                 providing support, advocacy, treatment, and resources for those
                 who need it most in our community, so that              they can live a
                 life with dignity and joy, regardless of their disability or deficits.

See Exhibit O.


                                Hayat Nur’s History and Characteristics

      It doesn’t take much to figure out why Hayat has been attracted to a life of helping those

most in need. Her birthday illuminates the darkness of her history. Hayat, now age 28, was born

in Somalia during a murderous civil war. I am confident that the Court recalls the testimony of

the defense expert during the first FOF trial who described in interesting yet tragic detail the

history of so many folks from Somalia. Millions of people were killed, maimed, kidnapped, and

driven from their homes. Everyone was harmed in one way or another. Children were separated

from their parents. There is no Somali national from that time period who doesn’t know

someone who was displaced. This is why Hayat’s birthday and the birthday of just about

everyone else is January 1st.



      The PSR at paragraphs 124-127 explains with some specificity Hayat’s history while living

in Somalia and once she relocated to Minnesota:




                                            Page 13 of 20
      “[Hayat] has few memories of Somalia, but she recalled a lack of housing stability as they

moved to different areas to escape the impact of the civil war. She has no memories of her

father during this time, hearing from her mother that he had to flee the country. Her mother

did not work outside the home, given her seven young children, and they relied on other

family members for financial support. [Hayat] was age 8 when her family immigrated to Egypt

in 2005. They received some support from a government refugee program. Although they

did not live in a refugee camp, they were often in small apartments and had to move at

times to save money. [Hayat] attended school, but it took some time for her to learn Arabic,

and she did not always eat three meals a day due to their limited financial means. As she

and her siblings aged, it became clear that they would not be able to pursue higher

education in Egypt, where they were not citizens. Her mother hoped that moving to the

United States would allow more opportunities for her children.



      Immigration records confirm [Hayat] entered the United States on September 8, 2010.

After briefly residing in the Twin Cities area, the family relocated to Marshall, Minnesota. While

the community had few Somali or Muslim people, the smaller population made it less

intimidating to seek social support services. [Hayat] recalls that her father was located in Saudi

Arabia and moved to join the family in approximately 2014. She does not know all the

details about why his whereabouts remained unknown for so long, believing her mother

wanted to shield her children from that knowledge. [Hayat] stated she was excited to have her

father present again, but it was not an easy transition for their family. She also held some

resentment that her father, although fleeing the country himself, did not show greater


                                          Page 14 of 20
concern for her mother, who raised seven young children alone for several years.

[Hayat] indicated that she and her siblings experienced racism and bullying in the community,

and there was little awareness of Somali culture and Islamic beliefs. She attended English

as a second language (ESL) classes throughout high school, although most of the other

students in the classes spoke Spanish or Hmong. She also was relied on heavily by her

parents to navigate paperwork and other administrative functions, as they have never

achieved the same degree of proficiency in the English language. Following her

graduation, she moved away from the family home to live with a roommate and attend

college in St. Cloud, Minnesota. [Hayat] advised that this is highly unusual in Somali culture

and caused some friction with her parents, although they eventually agreed to her plan.

While she was residing in St. Cloud, her family moved back to the Twin Cities area to

provide a wider variety of college choices to her younger siblings.”



     So when the Court considers the factors of §3553(a), I hope that you will consider that a

person such as Hayat Nur does not need to remain incarcerated any longer for the goals of

sentencing and the parsimony clause to be met.




                   No Need To Deter Hayat From Committing Future Offenses

     There is no need to impose upon Hayat a further custodial sentence to deter her from

engaging in future offenses. Hayat was arrested in this case in September 2022. She was

immediately released on a PRB, and remained at liberty for almost 21 months. During that



                                         Page 15 of 20
almost-two-year time period, Hayat adhered to all conditions of pretrial release as ordered by the

Court. Then during the multi-week trial, Hayat arrived to your courtroom early every morning

and was as respectful as a person could be during the duration of the trial. During the almost

three years since her arrest, throughout the 21 months while at pretrial liberty, and during the last

16 months while detained, Hyatt has proven to the Court that she will follow all rules and not

commit future offenses.




                                The Remaining §3553(a) Factors

      As the Court reflects upon the whole person being sentenced, I urge Your Honor to

consider that the requested sentence will reflect the seriousness of the offense, promote respect

for the law and provide just punishment. Hayat deeply regrets what she did. Her mistakes, as

terrible as they were, however, do not define the person being sentenced. The above letters

demonstrate that she is a hard-working, kind and caring person, and a family woman.



      For its part, the U.S. Sentencing Commission has noted that “dwindling prison space

should be reserved for the most serious and dangerous offenders, necessitating a reconsideration

of alternative sanctions for first-time and nonviolent offenders.” Alternative Sentencing in the

Federal Criminal Justice System, United States Sentencing Commission, January 2009, pg. 1.

Hayat is such a first-time, nonviolent offender. She has lived almost her entire life as a positive

and productive member of society who does not need to be imprisoned to be punished. The

requested sentence will mean that Hayat, at the end of the day, will have spent years reporting to


                                          Page 16 of 20
either a pretrial services officer or a probation officer, being subjected to strict supervision. See

United States v. Gall, 552 U.S. 38, 48-9 (2007) (describing probation as a punishment that

“severely restricts an individual’s liberty”); quoting United States v. Knights, 534 U.S. 112, 119

(2001). Lastly, as a first time felony offender, Hayat will continue to face myriad collateral

consequences well into the future.



      According to Professor Michelle Alexander, “[m]yriad laws, rules, and regulations operate

to discriminate against ex-offenders and effectively prevent their reintegration into the

mainstream society and economy. These restrictions amount to a form of 'civi[l] death' and send

the unequivocal message that 'they' are no longer part of ‘us.’” Michelle Alexander, The New Jim

Crow 142 (2010).



      The requested sentence can provide adequate general and specific deterrence. The available

empirical evidence does not support a finding that a prison sentence necessarily leads to

increased deterrent effects, regardless of the type of crime. See Andrew von Hirsch et al.,

Criminal Deterrence and Sentence Severity: An Analysis of Recent Research (1999) (concluding

that “correlations between sentence severity and crime rates … were not sufficient to achieve

statistical significance,” and that “the studies reviewed do not provide a basis for inferring that

increasing the severity of sentences generally is capable of enhancing deterrent effects”);

Michael Tonry, Purposes and Functions of Sentencing, 34 Crime and Justice: A Review of

Research 28-29 (2006)(“[I]ncreases in severity of punishments do not yield significant (if any)




                                           Page 17 of 20
marginal deterrent effects. . . . Three National Academy of Science panels, all appointed by

Republican presidents, reached that conclusion, as has every major survey of the evidence.”).



      Studies have also demonstrated that, except for the incapacitation effect of incarceration,

there is little apparent correlation between recidivism and imprisonment. See David Weisburd et

al., Specific Deterrence in a Sample of Offenders Convicted of White-Collar Crimes, 33

Criminology 587 (1995) (finding no difference in deterrence for white collar offenders between

probation and imprisonment); Donald P. Green & Daniel Winik, Using Random Judge

Assignments to Estimate the Effects of Incarceration and Probation on Recidivism among Drug

Offenders, 48 Criminology 357 (2010) (study of over a thousand offenders whose sentences

varied substantially in prison time and probation found that such variations “have no detectable

effect on rates of re-arrest,” and that “[t]hose assigned by chance to receive prison time and their

counterparts who received no prison time were re-arrested at similar rates over a four-year time

frame”).



      The Commission has similarly found that “[t]here is no correlation between recidivism and

guidelines’ offense level. … While surprising at first glance, this finding should be expected. The

guidelines’ offense level is not intended or designed to predict recidivism.” U.S. Sent’g

Comm’n, Measuring Recidivism: The Criminal History Computation of the Federal Sentencing

Guidelines, at 15 (2004).




                                          Page 18 of 20
      A more relevant predictor of recidivism is a defendant’s criminal history, of which Hayat

has none. Social science research indicates low recidivism rates for offenders with no prior

criminal history. The Commission found that offenders with zero criminal history points have a

recidivism rate of only 11.7% (compared with a recidivism rate of 22.6% for offenders with one

criminal history point, and 36.5% for offenders with two or more criminal history points). See

id., p. 13-14, 26.



      Therefore, while every case presents different facts and circumstances, given Hayat’s

unique history and characteristics, and the likely collateral consequences of her conviction, the

requested sentence will provide just punishment for the offense and promote respect for the law.

      !




                                         Page 19 of 20
                                            Conclusion

      For all of the above reasons, and mindful of the kinds of sentences available, I most

respectfully suggest that a sentence of time-served; three years of supervised release; six months

of home confinement; 300 hours of community service, mental health treatment, and orders of

restitution and forfeiture is sufficient but not greater than necessary to achieve the objectives of

sentencing.



      On behalf of Hayat Nur and her family, I thank Your Honor for considering this

memorandum.



Dated: August 12, 2025                                         Respectfully submitted,




                                                               By:__________________
                                                                   Barry S. Zone, Esq
                                                                   Attorney for Defendant
                                                                   40 Fulton Street / 17th Fl.
                                                                  New York, NY 10038


cc: All Government counsel (By ECF)




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