Notice of Sentencing Materials — United States of America v. Deon Levy, Case No: 1:22:CR:227 (Dkt. 65, N.D. Ohio)

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A Notice of Sentencing Materials filed January 6, 2023 as Doc #: 65 in United States of America v. Deon Levy, Case No. 1:22-cr-00227-PAB, in the U.S. District Court for the Northern District of Ohio, before Judge Pamela Barker. Defense counsel William B. Norman submits the materials in support of the defendant's sentencing hearing and states they will be referenced in the sentencing argument the next day. The notice lists two items: a letter from the defendant's twin sons Azeem and Ameer, and a medical diagnosis sheet. A certificate of service dated 5 January 2023 lists Assistant US attorney Elliot Morrison, and the attached letter from Ameer Levy speaks to his father's character and their relationship.

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Case: 1:22-cr-00227-PAB Doc #: 65 Filed: 01/06/23 1o0f9. PagelD #: 419

IN THE FEDERAL DISTRICT COURT FOR THE
NORTHERN DISTRICT OF OHIO

UNITED STATES OF AMERICA, ) CASE NO: 1:22:CR:227
)
Plaintiff, ) JUDGE: PAMELA BARKER
)
Vv. )
NOTICE OF SENTENCING MATERIALS
DEON LEVY,
Defendant.

Now comes Defendant, DEON LEVY, and hereby submits the following materials in
support of his sentencing hearing. 1. Letter from his twin sons Azeem and Ameer; and 2. Medical
diagnosis sheet. See attached.

These materials will be referenced in Defendant’s sentencing argument tomorrow.

Respectfully Submitted,

/s/ William B. Norman
William Norman (0088113)
WEB NORMAN LAW, INC.
22255 Center Ridge Road, Ste 311
Rocky River, OH 44116
Phone: (216) 487-7055
Fax: (216) 815-1788
Email: WillNorman@DefendingCleveland.com
Counsel for Defendant
Case: 1:22-cr-00227-PAB Doc #: 65 Filed: 01/06/23 2 of 9. PagelD #: 420

CERTIFICATE OF SERVICE

The foregoing notice of sentencing material was delivered via the ECF to the following
counsel of record on this 5 January 2023:

Elliot Morrison

Assistant US attorney
Northern District of Ohio

Respectfully Submitted,

/s/ William B. Norman
William Norman (0088113)
Case: 1:22-cr-00227-PAB Doc #: 65 Filed: 01/06/23 3 of 9. PagelD #: 421

To Whom It May Concern:

My name is Ameer Levy and I am writing to speak to the character of my father, Deon
Levy, and to share with you the depths of his love and dedication to his family. As his child, I
have been fortunate to experience firsthand the love and care that he has always shown to us.

My father has made a serious mistake a few years ago that cost him his reputation and many of
his public relationships. It was a difficult time for our family, and it would have been easy for my
father to become discouraged and lose sight of what was truly important. But through it all, my
father remained strong and resilient, and he never let his mistakes define him. If anything, this
difficult experience brought us closer as a family. We leaned on each other for support and love,
and we realized that we are all we have. My father's love for his children knows no bounds, and
he would do anything to protect and care for us. He has always been there for us, and I know that
he would do anything to make things right.

Seeing my brother firsthand go through this experience was traumatic for me because
with us just graduating college together and for this to come out it was a nuclear blast to our
morale and relationship with him. We’ve could’ve easily made amends and went our separate
ways but deep down I know he didn’t make this decision with ill intentions to do his son harm.
My father is a great teacher, and I have learned so much from him both in the trade of
construction and in life. I am proud to call my father my role model, and I genuinely see him as a
person of good character. His love and dedication to his family, combined with his business
acumen and integrity, make him an outstanding individual.

Sincerely,

Ameer Levy
Case: 1:22-cr-00227-PAB Doc #: 65 Filed: 01/06/23 4 of 9. PagelD #: 422
1/5/23,5:12PM Case: 1:22-cr-00227-PAB Doc #: 65 FiledibwOgieaGre3 5 of 9. PagelD #: 423

Name: DEON D LEVY
Date of Birth: <x KX]
Birth Sex: Male
Diagnoses

e HYPERTENSION NOS

CONGESTVE HRT FAILUR NOS

CARDIOMYOPATH IN OTH DIS

PRIM CARDIOMYOPATHY NEC

HYPERTENSION NOS

Hypertensive emergency

CHF (congestive heart failure)

Noncompliance with treatment plan

Troponin level elevated

Hypertension

CHF (congestive heart failure)

NYHA class 2 and ACC/AHA stage C acute on chronic systolic congestive heart failure
Congestive heart failure, hypertensive

CHF (congestive heart failure)

HTN (hypertension)

CHF (congestive heart failure)

Influenza

Influenza A

Accelerated hypertension

Hypertensive urgency

Chronic combined systolic and diastolic CHF, NYHA class 2 and ACA/AHA stage C
Chronic combined systolic and diastolic CHF, NYHA class 2 and ACA/AHA stage C
Cardiomyopathy

Viral pharyngitis

Ingrown toenail

Acute dyspnea

Epistaxis

e Anemia
1/5/23,5:12PM Case: 1:22-cr-00227-PAB Doc #: 65 Filediow0yieara3 6 of 9. PagelD #: 424

Gastric mass

GIST (gastrointestinal stromal tumor), non-malignant
DM (diabetes mellitus)

Gastrointestinal stromal tumor (GIST)

Malignant gastrointestinal stromal tumor

Daytime somnolence

Cardiomyopathy

Hypertension

DOE (dyspnea on exertion)

Chronic combined systolic and diastolic congestive heart failure
Astigmatism of both eyes

Abnormal fasting glucose

Body mass index (BMI) of 38.0 to 38.9 in adult

LVH (left ventricular hypertrophy)

Screening for colon cancer

GIST (gastrointestinal stromal tumor), non-malignant
Diastolic congestive heart failure

Hyperopia with presbyopia of both eyes

Obesity

Cardiomyopathy

Diabetes mellitus

LDL-c greater than or equal to 100 mg/dl

Vitamin D deficiency

Finger laceration

Class 2 severe obesity with serious comorbidity and body mass index (BMI) of 38.0 to 38.9 in adult,
unspecified obesity type

Thyroid disorder screen

Nephropathy screen

Prostate cancer screening

GERD (gastroesophageal reflux disease)

Elevated PSA

Knee pain

Colonoscopy planned

Diastolic CHF

Other dyspnea and respiratory abnormality
Hyperplastic colon polyp

Allergies

lisinopril - Unknown

ACE inhibitors - Unknown
ACE Inhibitors

lisinopril

https://uhhospitals.followmyhealth.com/PatientAccess/HealthRecordPrinting?token=XDDt6R5znuUZs_EPLCr-l-vPVkgDV39kdDtRP97wGqSIHSLj9hlk... 2/3
1/5/23,5:12PM Case: 1:22-cr-00227-PAB Doc #: 65 FilediwOgieara@3 7 of 9. PagelD #: 425

Medications

spironolactone 25 mg oral tablet - 1 tab(s) oral once a day

Carvedilol 25 Mg Tab Glen - TAKE 1 & 1/2 TABLETS BY MOUTH TWICE A DAY

Furosemide 20 Mg Tab Solc - TAKE ONE TABLET BY MOUTH DAILY

Spironolactone 25 MG Oral Tablet - Take 1 Tablet Daily.

Losartan Potassium 100 MG Oral Tablet - Take One Tablet By Mouth Every Day.

Carvedilol 25 MG Oral Tablet - Take 1 And 1/2 Tablets Twice Daily.

Furosemide 20 MG Oral Tablet - Take 1 Tablet Daily.

Pantoprazole Sodium 20 MG Oral Tablet Delayed Release

Pantoprazole Sodium 40 MG Oral Tablet Delayed Release - Take One Tablet By Mouth Every Day.
Ketorolac Tromethamine 0.5 % Ophthalmic Solution - Instill 1 Drop Into Affected Eye(s) 3 Times A Day.
Enoxaparin Sodium 40 MG/0.4ML Subcutaneous Solution - Inject 40 Mg Under The Skin Once A Day.
Tobramycin-Dexamethasone 0.3-0.1 % Ophthalmic Suspension - Instill 2 Drops Into Affected Eye(s) 4
Times A Day.

traMADol HCI - 50 MG Oral Tablet - Take One Tablet By Mouth Every 4 To 6 Hours For 7 Days As
Needed For Pain.

Vitamin D3 Ultra Potency 1.25 MG (50000 UT) Oral Tablet - Take 1 Tablet Weekly For 12 Weeks.
Losartan Pot 100 Mg Tab Camb

metFORMIN - orally once a day

pantoprazole - orally once a day

hydrALAZINE 25 mg oral tablet - orally 2 times a day

PEG 3350-KCI-Na Bicarb-NaCl 420 GM Oral Solution Reconstituted - Mix And Drink 4000 MI As Per
Split Dose Uh Endoscopy Instructions.

metFORMIN HCI - 500 MG Oral Tablet - Take 1 Tablet Twice Daily, With Morning And Evening Meal.
Atorvastatin Calcium 40 MG Oral Tablet - Take One Tablet By Mouth Daily.

hydrALAZINE HCl - 50 MG Oral Tablet - Take 1 Tablet Twice Daily.

Trulicity 0.75 MG/0.5ML Subcutaneous Solution Pen-injector - 0.75 Mg Once A Week.

DISCLAIMER: This information is supplied from the patient’s medical record via a patient portal. The medical
provider is listed as the source. Items with a source of 'Patient-Entered' were added by the patient. This
record may not be complete or up to date, and should not be used for providing medical advice. For an
official copy of the individual’s medical record, the patient (or custodian) must contact their medical
provider.

Generated on 01/05/2023 5:12:11 PM by FollowMyHealth® (http://www.followmyhealth.com).

https://uhhospitals.followmyhealth.com/PatientAccess/HealthRecordPrinting?token=XDDt6R5znuUZs_EPLCr-l-vPVkgDV39kdDtRP97wGqSIHSLj9hlk... 3/3
Case: 1:22-cr-00227-PAB Doc #: 65 Filed: 01/06/23 8 of 9. PagelD #: 426

I recently had a discussion with my siblings, but especially my twin brother (my sister
really did not have too much to say other than ask me if I was going to go to court and
speak up about our father).

My twin brother and I were having a heated discussion about the ordeal that I have been
going through these past months (or couple of years, whichever is appropriate). And my
brother asked me: How do you really feel now about how dad got you involved in his
business?

Well, at first, I was mad as all get out and didn’t even want to talk to my father. I mean I just
couldn't believe that he messed up like that and involved me in his business. Please, don’t
get me wrong. I know my father and I know that he doesn’t always do things like most
other fathers would do things. I mean, I know that my father is (was) definitely prone to
cutting corners, but whatever my father did or does, he always kept that side of him away
from us.

My father always made sure that his children had what they needed to be successful in life
including attending college for a better life. It was always my dream to work with my father
in his construction business and I thought I was learning the ropes of how to be success in
all aspects of construction even in the aspect of dealing with banks.

As I said, my father has (had) two sides, the one that he shared with his colleagues and
associates and the one that he shared with me and my siblings.

As | think back on it now, I was just in total shock when I came out of that bank and was
arrested. Even after dealing with that drama, I remember trusting and relying on my father
to deal with the situation. I can honestly say though, that because of my ordeal, I have
learned that I must grow-up. I still love and need my father’s guidance, but I must now put
all of the lessons that my father has taught me and my sibling into action so that I wlil
never, ever, ever find myself in such a situation again.

For the first few months, although I believed that my father was going to fix things and
make everything OK. But after a few weeks or months when things did not go away, I really
didn’t trust my father, I was really mad, and I didn’t even want to talk with him any more.
After I got over the anger, I began to understand that bad things happen even to good
people and that my father never intended to involvement in any unsavory business. Even
though I was angry. My siblings and I. (especially my twin brother) all realized how much
we truly are dependent upon our father for guidance and wisdom.

I still want to have a career in the construction industry and I often find that I need my
father’s guidance or I feel that I will never be successful. If you make one slight avoidable
error, it could mean the difference between paying the bills and facing bankruptcy. I hope
to one day be wise enough to not need my father’s close coaching, but that time is not
today. Today he is very much needed by me.

I know that I am rambling, but I would like to say that I asked my father what really
happened and he shared with me that although he did not know that what he was doing
was not Kosher, he should have known and he should have pulled the plug and he should
never have involved me. But that is all hindsight.

I still love my father and I do trust him, but this ordeal has taught us both a really valuable
lesson. You really, really have to scrutinize everything. If something even remotely seems
fishy, you must investigate. Trust, but verify that everything is on the up and up.

We lost our father for a long period of time in 2014-2017 and we didn’t exactly fall all the
way aper, but we were darn near close to it. I don’t believe that we are going to fall all the
Case: 1:22-cr-00227-PAB Doc #: 65 Filed: 01/06/23 9 of 9. PagelD #: 427

way apart, but we definitely still need our father’s presence and his present guidance to
really make a go of life successes.

My father is a really good man who has made some not so smart choices, but I’m certain
that he, just like me, will go forward to be really productive citizens.

It can be difficult to bridge the gap between yourself and your father when trying to rebuild
a healthy relationship. It helps to start small and be open to changes and compromises. My
father showed me he was genuinely sorry, and willing to take responsibility for his past
mistakes and that’s most important towards having a better relationship. Ultimately, the
two of us were open to forgiveness and were willing to take the time to invest in each other

and rebuild from the ground up.


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