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Home Source documents Notice of Filing — No. 1:22-cr-00032 (Dkt. 49, N.D. Fla.)

Notice of Filing — No. 1:22-cr-00032 (Dkt. 49, N.D. Fla.)

Summary

A Notice of Filing, Document 49 filed October 6, 2023 in the Northern District of Florida, Gainesville Division (Case 1:22-cr-00032-AW-MAL), United States v. Joseph Harding. Through counsel from Lauro & Singer and Turner O'Connor Kozlowski, the defendant submits two character letters for his Sentencing Hearing on October 19, 2023: one from his current employer, Del Zotto Products, and one from his brother, Samuel Harding. The employer's letter to Judge Allen C. Winsor, dated August 31, 2023, describes the precast concrete and steel supply company, says he works as an account manager at its Ocala location, and calls him an important part of its future growth.

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“Notice of Filing — No. 1:22-cr-00032 (Dkt. 49, N.D. Fla.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/notice-of-filing-no-1-22-cr-00032-dkt-49-n-d-fla-434815f90b/, SHA-256 48639d93d3f9c117a0e1f56ac4b6c3608fd7eb89e617c32eafe55aa1652bdeeb.

Full text

     Case 1:22-cr-00032-AW-MAL Document 49 Filed 10/06/23 Page 1 of 10




                 UNITED STATES DISTRICT COURT
             FOR THE NORTHERN DISTRICT OF FLORIDA
                      GAINESVILLE DIVISION

UNITED STATES OF AMERICA

v.                                         CASE NO.: 1:22CR32-AW/MAL

JOSEPH HARDING
_____________________________/

                            NOTICE OF FILING

      Defendant Joseph Harding, through counsel, respectfully submits the

following in connection with his Sentencing Hearing on October 19, 2023:

      1.    Letter from Mr. Harding’s current employer, Del Zotto Products; and

      2.    Letter from Mr. Harding’s brother, Samuel Harding.



Dated: October 6, 2023                     Respectfully submitted,

                                           /s/ John F. Lauro
                                           John F. Lauro, Esq.
                                           Florida Bar No. 794074
                                           jlauro@laurosinger.com
                                           Filzah I. Pavalon, Esq.
                                           Florida Bar No. 1033403
                                           fpavalon@laurosinger.com
                                           LAURO & SINGER
                                           400 N. Tampa St., 15th Floor
                                           Tampa, FL 33602
                                           813.222.8990




                                       1
      Case 1:22-cr-00032-AW-MAL Document 49 Filed 10/06/23 Page 2 of 10




                                                        - and -

                                                Ron Kozlowski
                                                Florida Bar No. 69432
                                                ron@toklegal.com
                                                Peg O’Connor
                                                peg@toklegal.com
                                                Florida Bar No. 170471
                                                TURNER O’CONNOR KOZLOWSKI, P.L.
                                                102 NW 2nd Ave.
                                                Gainesville, Fl 32601
                                                352.372.4263

                                                Counsel for Defendant
                                                Joseph Harding

                          CERTIFICATE OF SERVICE

      I HEREBY CERTIFY on October 6, 2023, I electronically filed the foregoing

document with the Clerk of the Court using CM/ECF system, which will serve a

notice of electronic filing to all counsel of record.

                                         /s/ Filzah I. Pavalon
                                         Filzah I. Pavalon, Esq.




                                           2
      Case 1:22-cr-00032-AW-MAL Document 49 Filed 10/06/23 Page 3 of 10




August 31, 2023

Hon. Allen C. Winsor
United States District Judge
United States District Court
Northern District of Florida
111 N. Adams Street
Tallahassee, FL 32301-7730

RE: U.S. v. Joseph Harding / Case No.: 1:22-cr-00032-AW-MAL

Dear Judge Winsor,

The purpose of our letter is to provide a reference of character for our employee and friend, Joe
Harding. Our company has a history of over 50 years in our business and we are proud of what
we have built. Del Zotto is a precast concrete structure manufacture, concrete plant and steel
supplier. Joe works in our Ocala location where we have nearly 200 employees, but he reports
directly to us. In a word, Joe is an important part of our company and future growth.

Joe is our account manager and point of contact for our company in the divisions of Ready-Mix
Plant, Block Plant and Foundation Supplies. He is deeply familiar with the construction industry,
and even though the distribution and manufacturing side is new to him, he understands people
and quickly grasps their needs. He knows our community and people respect him, and he works
very hard.

Joe is someone we have known personally for nearly 5 years dating back to when he was first
exploring running for office. Joe quickly became a friend to our family, and we supported him in
his endeavors to be our state representative. Our values aligned then, and they still do today.
When we knew Joe was having to restart his career after the challenges he has faced this year,
we knew that Joe was someone that we wanted on our team as we continue to expand and grow
our family owned and operated business.

We have watched Joe as a friend and employee navigate the challenges that he has faced this
year. Every person at some point in their life makes mistakes, and unfortunately for him, he has
had to face his mistakes in an extremely public and brutal way. He is genuinely remorseful for
the mistakes he has made, and he is very focused on the future.
      Case 1:22-cr-00032-AW-MAL Document 49 Filed 10/06/23 Page 4 of 10




We as an employer have been successful in working with people who have made bad decisions
in their past, and as a company we believe in giving people second chances. We feel confident
that Joe will continue to be a good member of our team and we are proud to have him on board.


Regards,

Del Zotto Family:

Philip Del Zotto
Mary Del Zotto
Mario Del Zotto
Abigal Del Zotto
Elizabeth Del Zotto
Miella Del Zotto
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