Sentencing Memorandum and Motion for Departure — USA v. Zolezzi (Dkt. 32, S.D. Cal.)

Summary

Defendant Thomas Zolezzi's Sentencing Memorandum and Motion for Downward Departures in United States of America v. Thomas Zolezzi, Case No. 23-CR-2352-AJB, in the U.S. District Court for the Southern District of California, filed January 13, 2025 as Document 32 by defense counsel Domenic J. Lombardo and Emerson Wheat for a January 21, 2025 hearing. It addresses the 18 U.S.C. § 3553(a) factors and states that the PPP and EIDL loans totaled $2,939,749.99, with funds used partly for personal expenses and partly for the Casamar business. The memorandum states a Guidelines range of 24 to 30-months at adjusted offense level 17 and seeks departures under U.S.S.G. § 4C1.1 and §§ 5H1.3, 5H1.4. It asks for an 18-month sentence, three-years supervised release, restitution without interest, and a self-surrender date of 90-days.

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