Memorandum Supplement to Sentencing Memorandum — USA v. Padilla-Reyna (Dkt. 44, E.D. Wash.)

Summary

A supplement to the defendant's sentencing memorandum, filed May 15, 2023 as ECF No. 44 in United States v. Karla L. Padilla-Reyna, Case No. 22-cr-2059-MKD-1, in the U.S. District Court for the Eastern District of Washington, by Robin C. Emmans and Ulvar W. Klein of 2nd Street Law PLLC. It corrects account balances reported in the presentence interview and states counsel keeps $300,000 in a dedicated trust account, half of which, $150,000, will be paid to the court at sentencing while, with the court's approval, the other half will be held by counsel pending the sale of a Yakima property subject to civil forfeiture. The supplement surveys other COVID-19 fraud cases in the Eastern District of Washington, several resolved with probation or a deferred prosecution, to argue that probation would be proportional.

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