Sentencing Memorandum — United States of America v. Boylett (Dkt. 38)

Summary

This is the Defendant's Sentencing Memorandum for Jeffery Boylett, document 38 in case 2:21-cr-00154-JD-JPK, United States District Court for the Northern District of Indiana, Hammond Division. It requests a sentence below the applicable guideline range, to twelve (12) months and one (1) day of imprisonment, and notes a total offense level of thirteen (13), criminal history category III, and a recommended range of 18 to 24 months. It states that on April 10, 2020, Mr. Boylett submitted a fraudulent application for a business that never existed and received $109,900 from the Small Business Administration. The conclusion also asks for one (1) year of supervised release, a recommendation that the sentence be served close to Northwest Indiana, and thirty (30) days to self-surrender.

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Cite this document

“Sentencing Memorandum — United States of America v. Boylett (Dkt. 38).” Original at ecf.innd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/sentencing-memorandum-united-states-of-america-v-boylett-dkt-38-d2cacd3843/, SHA-256 14782d5b44e0e3b5dd0e778d342f1ea2f471dfde7fe5bf450222fe66008b5a69.

Full text

USDC IN/ND case 2:21-cr-00154-JD-JPK document 38 filed 10/14/22 page 1 of 4

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF INDIANA
HAMMOND DIVISION

UNITED STATES OF AMERICA, )
Plaintiff, )
v. )
) Cause No.: 2:21 CR 154
)
JEFFERY BOYLETT )
)
Defendant )

DEFENDANT’S SENTENCING MEMORANDUM
Comes now the Defendant, Jeffery Boylett, by his Attorney Adam Tavitas and files the

following Sentencing Memorandum.

SENTENCING REQUEST

Jeffery Boylett requests that this Honorable Court sentence him below the applicable

guideline range as determined by the Final Presentence Report to twelve (12) months and one (1)

day of imprisonment.

SENTENCE RECOMMENDED BY THE SENTENCING GUIDELINES
Jeffery Boylett pled guilty count 1 of the indictment to Wire Fraud in violation of Title 18

U.S.C. 1343 He faces a maximum term of twenty (20) years incarceration, a maximum term of

supervised release of three (3) years, and a $250,000 fine. Pursuant to the Pre-Sentence

Investigation Report, Jeffrery Boylett’s total offense level is thirteen (13) and his criminal history

category is III for a recommended guidelines range of 18 to 24 months.

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USDC IN/ND case 2:21-cr-00154-JD-JPK document 38 filed 10/14/22 page 2 of 4

NATURE OF THE OFFENSE

On April 10, 2020 Mr. Boylett submitted a fraudulent application indicating he had a

business called “Bills”, was involved in health services, had five (5) employees, and had been

operating for over twenty (20) years. When he submitted this application, he in fact did not have

this business and it never existed. As a result of filling out this application, he received $109,900

from the Small Business Administration.

JEFFERY BOYLETT’S HISTORY AND CHARACTERISTICS

At the time of sentencing Mr. Boylett will be forty (40) years old. When he completes
his sentence, he wants to live a law abiding life. He is sorry for his actions and truly did not mean
to harm anyone. It was something he did that he truly regrets. He understands that because of his
actions he will be away from his family and friends and has no one to blame but himself.

Mr. Boylett wants to provide for his family with gainful employment after he is released
from the Bureau of Prisons. He also wants to be employed to start paying back the money he
unlawfully received. He currently is a barber and has been for many years.
He has lived in Northwest Indiana for almost his entire life. He does not have much of a
criminal history. Sixteen (16) years ago he received his only other felony conviction for
Possession of a Controlled Substance in which he served a sentence of four (4) years
imprisonment. This case was filed eleven (11) months ago. Since that time he has not received
any new charges and has been compliant with pretrial release.

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USDC IN/ND case 2:21-cr-00154-JD-JPK document 38 filed 10/14/22 page 3 of 4

CONCLUSION
The Defendant respectfully asks that he be sentenced to no more than twelve (12) months and
one (1) day of imprisonment and one (1) year of supervised release. He also requests credit for
the time he has already spent incarcerated in this case. He also would like the Court make a
recommendation to the Bureau of Prisons that he serve his remaining sentence as close as
possible to Northwest Indiana. In addition since he has been compliant on pretrial release he
requests thirty (30) days to self -surrender after his sentencing hearing.

Respectfully Submitted,

/s/ Adam Tavitas
Adam Tavitas, #18451-53
Attorney for Defendant
751 E. Porter Avenue, Suite 3
Chesterton, IN 46304

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USDC IN/ND case 2:21-cr-00154-JD-JPK document 38 filed 10/14/22 page 4 of 4

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF INDIANA
HAMMOND DIVISION
UNITED STATES OF AMERICA, )
Plaintiff, )
v. )
) Cause No.: 2:21 CR 154
)
JEFFERY BOYLETT )
)
Defendant )
______________________________________________________________________________

CERTIFICATE OF SERVICE
_____________________________________________________________________________________

I hereby certify that, on the 14th day of October, 2022 I electronically filed a complete
copy of Defendant’s Sentencing Memorandum and this Certificate of Service with the Clerk of
the Court using the CM/ECF system which sent notification of such filing to the following:
Thomas McGrath
Thomas.McGrath@usdoj.gov

File and source

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