United States' Sentencing Memorandum — United States v. Jackson (W.D. Wash., Document 171)

Summary

The United States' Sentencing Memorandum in United States v. D'Arius Akim Jackson, No. CR-23-090-02 JHC, in the U.S. District Court for the Western District of Washington at Seattle, Document 171, filed January 29, 2024. It recommends that the Court sentence Jackson to 63 months of imprisonment followed by five years of supervised release and order restitution of $436,667, as agreed in the Plea Agreement. The memorandum states that a Grand Jury returned a 26-count indictment on May 31, 2023, and that Jackson pled guilty to wire fraud as charged in Count 19 on October 26, 2023. It gives a Guidelines range of 70 to 87 months and describes its recommendation as below-Guideline. The signature block reads /s/ Cindy Chang, Assistant United States Attorney.

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“United States' Sentencing Memorandum — United States v. Jackson (W.D. Wash., Document 171).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-w-d-wash-no-2-23-cr-00090-dkt-171-w-d-wash-4858ce281e/, SHA-256 88b472c4b0bbd9ade5becf09386c54d2790df665ac9b2a45fade74e6a4ff59af.

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Case 2:23-cr-00090-JHC Document 171 Filed 01/29/24 Page 1 of 12

1 The Honorable John H. Chun

2
3
4
5
6
7 UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF WASHINGTON
8 AT SEATTLE
9
10
UNITED STATES OF AMERICA, NO. CR-23-090-02 JHC
11
Plaintiff,
12 UNITED STATES' SENTENCING
v. MEMORANDUM
13
14
D’ARIUS AKIM JACKSON,
15
Defendant.
16
17
D’Arius Jackson participated in a scheme to defraud nearly every major federal
18
pandemic assistance program of more than $6.8 million through the submission of more
19
than 125 fraudulent applications and claims. Jackson personally defrauded the U.S.
20
Department of Treasury’s Emergency Rental Assistance program administered through
21
the King County Eviction Protection and Rental Assistance Program; the Paycheck
22
Protection Program administered by the U.S. Small Business Administration (SBA); and
23
the Economic Injury Disaster Loan Program administered by the SBA. In total, Jackson
24
sought at least $457,637 and obtained at least $436,667 in pandemic assistance that
25
should have gone to King County tenants on the verge of eviction and small businesses
26
suffering from the economic impact of the COVID-19 pandemic. He systematically
27
United States’ Sentencing Memorandum UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
United States v. Jackson, CR23-090-JHC 02 - 1
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document 171 Filed 01/29/24 Page 2 of 12

1 laundered and used funds intended to support those in need for expenses such as a
2 Porsche Panamera, diamond jewelry, gambling, and kickback payments to his sister and
3 co-defendant Paradise Williams.
4 The United States recommends that the Court sentence Jackson to 63 months of
5 imprisonment, followed by five years of supervised release. Jackson exploited multiple
6 assistance programs during a national emergency and committed this offense while he
7 was on state probation. This sentence is necessary to reflect the serious nature of the
8 offense and to deter Jackson and others from engaging in similar conduct. The Court
9 should further order Jackson to pay restitution in the amount of $436,667, as agreed upon
10 in the Plea Agreement.
11 The government is recommending a below-Guideline sentence in this case because
12 while Jackson’s criminal history is extraordinary, his Criminal History Category (CHC)
13 of VI may slightly overstate the severity of his crimes. The recommended 63 months is a
14 low-end Guideline sentence for CHC V. The government also weighed that Jackson was
15 among the first defendants to accept responsibility and enter a guilty plea in this matter.
16 I. BACKGROUND
17 A. Jackson Stole Funds Intended for Vulnerable King County Residents and
Small Businesses.
18 As the COVID-19 pandemic economically devasted Americans across the country,
19 the federal government enacted measures to assist small businesses, legitimate workers
20 who lost their jobs because of the pandemic, and tenants who were vulnerable to eviction.
21 Among the earliest measures was federal funding for Economic Injury Disaster Loans
22 (EIDL) of up to $2 million and the Paycheck Protection Program (PPP) for eligible small
23 businesses. PSR at ¶ 15. Jackson, who does not appear to have any form of legitimate
24 income prior to 2020, saw each of these assistance programs as opportunities for self-
25 enrichment.
Approximately three months after presidential declarations of a nationwide
26
emergency and major disasters in every state, on July 12, 2020, Williams submitted a
27
United States’ Sentencing Memorandum UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
United States v. Jackson, CR23-090-JHC 02 - 2
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document 171 Filed 01/29/24 Page 3 of 12

1 fraudulent EIDL application using Jackson’s identity with his permission. PSR at ¶ 23.
Jackson falsely claimed he was a sole proprietor of a hair and nail salon with seven
2
employees as of January 31, 2020 and gross revenue of $6,800 for the year prior to
3
January 31, 2020. Id. The application directed the loan proceeds to be deposited into
4
Jackson’s bank account. Dkt. 122, Plea Agreement at ¶ 8.z. Jackson’s application was
5
denied because he did not meet the program’s credit score requirement. PSR at ¶ 23.
6
Less than a year later, on about May 14, 2021, Williams submitted a fraudulent
7
PPP application using Jackson’s identity with his permission. Id. at ¶ 24. The
8 application claimed Jackson was a sole proprietor of a food delivery business that began
9 on January 1, 2020, with a gross income of $100,000. Id. All of these representations
10 were false, and Williams created a fake bank statement in support of the application.
11 Dkt. 122 at ¶ 8.u. On June 14, 2021, the application was funded for $20,832 (the
12 maximum allowed for a sole proprietorship with no employees), and the proceeds were
13 deposited into Jackson’s bank account. Id.; PSR at ¶ 24.
14 In the fall of 2021, Williams began defrauding the King County Eviction

15 Protection and Rental Assistance Program (EPRAP), which had received over $300
million in federal Emergency Rental Assistance funds and state grants to help King
16
County residents facing the loss of basic housing security as a result of the COVID-19
17
pandemic. A few months later, Jackson joined the scheme, and text messages between
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Jackson and Williams indicate that Jackson played a proactive role in executing the
19
fraud:
20
Timestamp: Time From To Text
21 1/13/2022 10:16:43 AM(UTC‐8) JACKSON WILLIAMS You're moving at a very slow Pace
speedy
22
1/13/2022 10:38:18 AM(UTC‐8) JACKSON WILLIAMS Send me another address rent
23 amount utilities bedrooms
1/13/2022 10:38:36 AM(UTC‐8) JACKSON WILLIAMS Please
24
25 1/13/2022 10:44:18 AM(UTC‐8) WILLIAMS JACKSON She's sending doc sign for the other
one
26 1/13/2022 10:45:02 AM(UTC‐8) JACKSON WILLIAMS Ok
27
United States’ Sentencing Memorandum UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
United States v. Jackson, CR23-090-JHC 02 - 3
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document 171 Filed 01/29/24 Page 4 of 12

Timestamp: Time From To Text
1
1/13/2022 10:45:53 AM(UTC‐8) JACKSON WILLIAMS We have like 5 waiting in my name
2
3 1/13/2022 10:47:40 AM(UTC‐8) WILLIAMS JACKSON What's Alex last name

4
5 1/13/2022 10:48:44 AM(UTC‐8) JACKSON WILLIAMS Spilbury

6 1/13/2022 11:02:00 AM(UTC‐8) WILLIAMS JACKSON Alex is 30 what did we say his rent was
?
7
1/13/2022 11:05:27 AM(UTC‐8) WILLIAMS JACKSON I don't think she did his math right but
8 I'm not bout to go back and forth just
send the money 🤣
9
10
1/13/2022 11:10:16 AM(UTC‐8) JACKSON WILLIAMS It'll just send it
11
1/13/2022 11:10:32 AM(UTC‐8) JACKSON WILLIAMS It should be there tomorrow too
12
right?
13 1/13/2022 11:10:48 AM(UTC‐8) WILLIAMS JACKSON No way
14
1/13/2022 11:10:52 AM(UTC‐8) WILLIAMS JACKSON Next week
15
1/13/2022 11:12:33 AM(UTC‐8) JACKSON WILLIAMS OK but the other one we did should
16 be depositing tomorrow right
17 1/13/2022 11:12:43 AM(UTC‐8) JACKSON WILLIAMS Lol

18 1/13/2022 11:14:19 AM(UTC‐8) WILLIAMS JACKSON Yeah I'm sending to your bank like I
did last time so be aware lol
19
Over the course of several weeks in January 2022, the pair filed at least 11
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fraudulent applications using Jackson’s alias “Akim Jackson” and co-defendant David
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Martinez’s names as landlords. PSR at ¶ 25. Williams generated fake documents,
22
including ledgers and landlord attestations, that were submitted to support the
23 applications. Id. Jackson and Martinez impersonated landlords and tenants associated
24 with the fraudulent applications. Id. The applications sought at least $$433,395 and
25 caused King County to pay at least $415,845 in Emergency Rental Assistance funds to
26 Jackson’s and Martinez’s bank accounts. Dkt. 122 at ¶ 8.m.
27
United States’ Sentencing Memorandum UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
United States v. Jackson, CR23-090-JHC 02 - 4
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document 171 Filed 01/29/24 Page 5 of 12

1 In summary, over the course of approximately 18 months, Jackson repeatedly
defrauded federal pandemic assistance programs, seeking a total of $457,637, and
2
causing at least $436,667 in emergency rental and small business assistance to be
3
fraudulently disbursed. PSR at ¶ 22. In each instance, Jackson acted in concert with
4
Williams, to whom he paid kickback payments. Upon receipt of the criminal proceeds,
5
Jackson methodically laundered the funds through cash withdrawals, wire transfers, and
6
expensive purchases. Dkt. 122 at ¶ 8.f.
7
B. Jackson Stole Pandemic Assistance to for Luxury Items and Gambling.
8 In addition to the kickback payments Jackson paid Williams, Jackson used stolen
9 pandemic aid to gamble and purchase luxury items such as diamond jewelry, designer
10 clothing, and a Porsche Panamera:
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12
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21 Particularly egregious is the fact that Jackson attempted to obfuscate his ownership of the
22 Porsche by registering it in the identity of a female associate. PSR at ¶ 27. Jackson used
23 the same identity to in fraudulent applications for pandemic aid. Id.
24 C. Jackson’s Continuous Criminal Activity is Extraordinary.
25 Although the government concedes that a CHC of VI may overstate the severity of
26 Jackson’s crimes, the continuous nature of Jackson’s criminal activity is exceptional. As
27 detailed in the PSR, Jackson’s 24 adult convictions generally consist of unlawful
United States’ Sentencing Memorandum UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
United States v. Jackson, CR23-090-JHC 02 - 5
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document 171 Filed 01/29/24 Page 6 of 12

1 possession of firearms, assault, obstruction of justice, and driving offenses, many of
which are felonies. See id. at ¶ 54-77. It appears that the longest sentence he has
2
received was 12.75 months of custody in 2017 for unlawful possession of a firearm, and
3
his most recent sentence in 2018 was 214 days of custody for driving under the influence
4
and making a false statement to law enforcement. Id. at ¶¶ 75-77. These terms of
5
incarceration and opportunities to reform under Drug Offender Sentencing Alternative
6
(DOSA) sentences have not deterred Jackson from criminality. See also Probation
7
Sentencing Recommendation at 6. Moreover, during Pretrial Service’s investigation
8 concerning Jackson’s detention pending trial, the Department of Corrections reported that
9 Jackson violated all six terms of supervision he has had since 2007. In fact, Jackson was
10 under state supervision at the time of his offenses in this case.
11
II. PROCEDURAL HISTORY
12
On May 31, 2023, the Grand Jury returned a 26-count indictment, charging
13
Paradise Williams, D’Arius Jackson, Jahri Cunningham, Tia Robinson, Rayvon Peterson,
14
and David Martinez with various counts of wire fraud in connection with a presidentially
15
declared emergency or major disaster, in violation of 18 U.S.C. § 1343; and money
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laundering. Dkt. 1. Williams was charged with all 19 counts of wire fraud (Counts 1-19)
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and two counts of money laundering (Counts 25-26) for the purchase of two luxury
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vehicles. Jackson was charged with five counts of wire fraud (Counts 3, 7, 15, 18, 19)
19
and one count of concealment money laundering, in violation of 18 U.S.C.
20
1956(a)(1)(B)(i) (Count 23).
21
On June 5, 2023, Jackson was arrested in Tacoma. Following his arrest, Jackson
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initially agreed to speak with federal agents but declined to answer questions after being
23
advised of the charges he faced. He only stated, “You know what you know.”
24
On October 26, 2023, Jackson pled guilty to wire fraud as charged in Count 19,
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becoming the second defendant in this case to plead guilty. Dkt. 120-23.
26
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United States’ Sentencing Memorandum UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
United States v. Jackson, CR23-090-JHC 02 - 6
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document 171 Filed 01/29/24 Page 7 of 12

1 III. SENTENCING GUIDELINES CALCULATIONS
2 The United States agrees with the Probation Office on the Sentencing Guidelines
3 calculations and has no objections to the facts contained in the PSR.
4 The following calculation applies to wire fraud as charged in Count 10:
5 Item Guideline Adjustment
6 Base 2B1.1(a)(1) +7
Intended Loss in Excess 2B1.1(b)(1)(G) +12
7 of $250,000
8 Sophisticated Means 2B1.1(b)(10) +2
Theft of Major Disaster 2B1.1(b)(12) +2
9 or National Emergency
Benefits
10
Acceptance 3E1.1 -3
11 Total 20
12 See PSR at ¶¶ 36-47.
13 The defendant’s total criminal history score is 14, which correlates with a criminal
14 history category of VI. Id. at ¶ 80. The resulting Guidelines range is 70 to 87 months of
15 imprisonment. Id. at ¶ 148.
16 IV. SENTENCING RECOMMENDATION
17 The United States recommends that the Court impose a term of imprisonment of
18 63 months, followed by five years of supervised release.
19 For the reasons set forth below, this recommendation is appropriate given “the
20 nature and circumstances of the offense,” and the need for the sentence “to reflect the
21 seriousness of the offense, to promote respect for the law, and to provide just punishment
22 for the offense,” to ensure adequate general deterrence, and “to protect the public from
23 further crimes of the defendant.” 18 U.S.C. §§ 3553(a)(1), (a)(2)(A), and (a)(2)(C).
24
25
26
27
United States’ Sentencing Memorandum UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
United States v. Jackson, CR23-090-JHC 02 - 7
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document 171 Filed 01/29/24 Page 8 of 12

1 A. The Nature and Circumstances of the Offense—Jackson’s Exploitation of
Multiple Pandemic Assistance Programs During an Unprecedented National
2 Emergency is an Aggravating Factor.
3 Because nearly four years have lapsed since the onset of the COVID-19 pandemic,

4 it is easy to forget the chaotic, desperate, and dire circumstances facing our nation and
5 our government’s attempts to stem the catastrophic economic impact of the COVID-19
6 pandemic. Schools, businesses, and restaurants shuttered, while hospitals were
1
7 overwhelmed with patients dying of COVID-19. In 2020, a safe and effective COVID-
8 19 vaccine was unfathomable to most. Yet, Jackson saw the pandemic and its
9 consequences not as a public health catastrophe but as an opportunity to continue
10 perpetrating crimes even while he was on probation.
11 Emergency Rental Assistance. To mitigate the spread of COVID-19, federal,

12 state, and local governments—including Washington and cities in King County—enacted
13 eviction moratoriums that ensured residents remained housed during the global
14 pandemic. The moratoriums were intended to assist the millions of Americans facing
15 financial hardship. The last federal moratorium ended on October 3, 2021; Washington’s
16 statewide moratorium ended on October 31, 2021; and Seattle’s moratorium ended on
17 January 15, 2022.
18 In anticipation of exacerbating existing housing crises amidst the ongoing

19 pandemic when the moratoriums ceased, the U.S. Department of Treasury began
20 disbursing Emergency Rental Assistance Program funds to state, local, and tribal
21 governments in early 2021. From March 2021 through 2022, Washington State and local
22 governments, including King County, received over $900 million in federal emergency
23 rental assistance. Nevertheless, the administrating agencies acknowledged that there was
24 insufficient funding to help every household who qualified, thus, the screening criteria
25
26 1
See, e.g., Cha, Ariana, “Faced with a crush of patients, besieged NYC hospitals struggle with life-or-death
decisions,” The Washington Post (Mar. 31, 2020), available at
27 https://www.washingtonpost.com/health/2020/03/31/new-york-city-hospitals-coronavirus/.

United States’ Sentencing Memorandum UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
United States v. Jackson, CR23-090-JHC 02 - 8
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document 171 Filed 01/29/24 Page 9 of 12

1 was intended to target those most likely to become homeless but for the assistance. Even
2 so, during the first two years of the pandemic, between 2020 and 2022, the homeless
3 population in Washington State increased by approximately 10%.2
4 Jackson looted scarce resources available to assist those on the brink of eviction
5 during a national emergency. Every dollar Jackson diverted from the Emergency Rental
6 Assistance Program for his luxury purchases should have been used to keep a King
7 County resident housed through the winter of 2021 and 2022.
8 Small Business Assistance. In July 2020, when Jackson authorized Williams to
9 file his fraudulent EIDL application for funds intended to assist small businesses,
10 American business owners had seen their livelihoods vanish overnight, an unprecedented
11 occurrence in our nation’s history and a far more severe economic impact than the 1918
12 influenza.3 In fact, in July 2020, only approximately half of small businesses were fully
13 open and most worried about having to permanently close due to prolonged closures.4
14 Although Jackson did not succeed in obtaining EIDL funds, he contributed to the
15 onslaught of fraudulent claims that clogged the infrastructure in place to distribute aid
16 and delayed or denied genuine small business owners assistance.5
17 In March 2021, approximately two months before Jackson authorized Williams to
18 submit a fraudulent PPP application in his identity, SBA expanded eligibility and
19 increased minimum award amounts for self-employed individuals seeking forgivable PPP
20 loans. These changes were intended to assist gig workers and independent contractors
21
22 2
U.S. Dep’t of Housing and Urban Development, “The 2022 Annual Homelessness Assessment Report to
Congress,” (Dec. 2022) at 109, available at https://www.huduser.gov/portal/sites/default/files/pdf/2022-AHAR-
23 Part-1.pdf.
3
Bartik, Alexander, et al., “How Are Small Businesses Adjusting to COVID-19? Early Evidence From a Survey,”
24 Nat’l Bureau of Economic Research (Apr. 2020), at 3, 8, available at
https://www.nber.org/system/files/working_papers/w26989/w26989.pdf.
25 4
U.S. Chamber of Commerce, “July 2020 Small Business Coronavirus Impact Poll” (July 29, 2020), available at
https://www.uschamber.com/small-business/july-2020-small-business-coronavirus-impact-poll.
26 5
See, e.g., Trish Turner, “‘Double the number of users’ in PPP system as it reopens with more technical issues,”
ABC News (April 27, 2020), available at https://abcnews.go.com/Politics/double-number-users-ppp-system-
27 reopens-technical-issues/story?id=70370289.

United States’ Sentencing Memorandum UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
United States v. Jackson, CR23-090-JHC 02 - 9
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document 171 Filed 01/29/24 Page 10 of 12

1 who were among the workers hardest hit by the pandemic.6 Jackson’s application for
2 PPP funds and his award of $20,832 particularly exploited the vulnerability of gig
3 workers because he claimed to be a food delivery driver when he was either unemployed
4 or working construction. See PSR at ¶ 139.
5 Sentencing Enhancements. Notably, both Congress and the Sentencing
6 Commission have endorsed sentencing enhancements during national emergencies and
7 major disasters. See 18 U.S.C 1343 (increases maximum penalties to 30 years
8 imprisonment and $1 million fine); USSG § 2B1.1(b)(2)(12) (two-level increase applied
9 for offenses involving disaster fraud). Congress enacted the enhanced statutory penalty
10 for wire (and mail) fraud in response to reports of widespread fraud and abuse in
11 connection to disaster funds disbursed for Hurricanes Katrina and Rita. The Senate
12 Judiciary Committee report noted:
13 We want to help ensure that federal money goes to the right people and
14 does not get stolen by criminals posing as victims. Congress wants to
provide appropriate recovery and relief resources to affected States, and
15 also ensure that these resources are protected and distributed only to the
real victims–not to individuals seeking to take advantage of the disaster.
16
17 Senate Report No. 110-69, 110th Cong., 1st Session (May 22, 2007).
18 In this case, Jackson was a seasoned criminal and under state probation during the

19 COVID-19 pandemic. While the government sought to prioritize the well-being of a
20 suffering nation, Jackson took advantage of the vulnerable period for self-enrichment.
21 B. Defendant’s History and Characteristics

22 1. Jackson’s Exceptional Criminal History is an Aggravating Factor.
As discussed above and detailed in the PSR, Jackson’s criminal history is
23
extraordinary. Unfortunately, opportunities for reform under DOSA sentences and
24
25
26 6
Mark Klee et al., “Combining Census Bureau Pulse Surveys Reveals Which Workers Are Hardest Hit by COVID-
19,” United States Census Bureau (June 30, 2020), available at https://www.census.gov/library/stories/2020/06/self-
27 employed-adults-hit-harder-by-pandemic-related-business-downturns-in-hardest-hit-states.html.

United States’ Sentencing Memorandum UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
United States v. Jackson, CR23-090-JHC 02 - 10
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document 171 Filed 01/29/24 Page 11 of 12

1 increasingly longer periods of custody have not deterred Jackson. Jackson’s crimes,
including the offenses in this case, have continuously victimized our community.
2
Accordingly, a substantial term of prison is necessary.
3
2. Jackson’s Luxury Expenditures Are an Aggravating Factor.
4
As detailed above, Jackson used his criminal proceeds for a Porsche, luxury
5
goods, and gambling. His use of emergency pandemic assistance for these purposes
6
while King County residents on the brink of eviction suffered is egregious.
7
C. A Substantial Term of Imprisonment is Necessary to Deter and is Just
8 Punishment for the Offense.
9 The government’s recommendation of 63 months of imprisonment is just
10 punishment for Jackson’s conduct, given the facts and circumstances discussed above.
11 The proposed sentence is also necessary to deter Jackson from further criminal behavior
12 and promote rule of law, given his exceptional criminal history despite opportunities to
13 reform. Because this matter is one of the first and largest Emergency Rental Assistance
14 fraud cases in the nation, a substantial term of imprisonment is particularly important for
15 general deterrence.
16 //
17 //
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United States’ Sentencing Memorandum UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
United States v. Jackson, CR23-090-JHC 02 - 11
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document 171 Filed 01/29/24 Page 12 of 12

1 D. Conclusion
The Court should sentence Jackson to 63 months of imprisonment, followed by
2
five years of supervised release. The Court should further order Jackson to pay $436,667
3
in restitution, as agreed upon in the Plea Agreement.
4
Dated: January 29, 2024
5
Respectfully submitted,
6
TESSA M. GORMAN
7 United States Attorney
8
/s/ Cindy Chang
9 CINDY CHANG
10 Assistant United States Attorney
United States Attorney’s Office
11 700 Stewart Street, Suite 5220
Seattle, Washington 98101-1271
12 Phone: 206-553-7970
13 Fax: 206-553-0582
Email: Cindy.Chang@usdoj.gov
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United States’ Sentencing Memorandum UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
United States v. Jackson, CR23-090-JHC 02 - 12
SEATTLE, WASHINGTON 98101
(206) 553-7970

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