Sentencing Memorandum — USA v. Barrera Almaguer et al (Dkt. 183, S.D. Fla.)

Summary

A defense sentencing memorandum for Yandre Garcia Hernandez in United States of America v. Yandre Garcia Hernandez, Case No. 22-CR-80118, in the United States District Court for the Southern District of Florida, entered on the docket January 23, 2023 as Document 183. It requests a variance below the bottom of the guidelines range under 18 U.S.C. § 3553(a) and cites Booker and Kimbrough. The memorandum states that the defendant allowed co-defendant Barrera Almaguer to use the Garcia & Sons Remodeling Service Corp. Bank of America account to move funds from false PPP loans, signed documents and checks as instructed, and benefited by approximately $40,000. It proposes a reduced incarceration period with a longer supervision term so the defendant can work toward restitution. It is signed /S/ by defense counsel Khurrum B. Wahid.

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