Defendant Horne’s Sentencing Memorandum, Request for Variance (M.D. Fla., September 3, 2026)

Summary

Defendant Horne's Sentencing Memorandum Request for Variance in United States v. Verlynn Jamelah Horne, Case No. 6:25-cr-161, in the U.S. District Court for the Middle District of Florida, Orlando Division, filed September 3, 2026 as Document 93. It states the defendant pled guilty to wire fraud under 18 U.S.C. 1343 and willful failure to file tax returns under 26 U.S.C. 7203, and that the Presentence Report sets a total offense level of 22 and a range of 41 to 51 months. The memorandum states the defendant and unindicted participants obtained fraudulent loans totaling $5,581,089.20, and cites a pre-indictment proffer on February 6, 2023. Counsel asks for a 7 level downward variance and an 18 month term of imprisonment, citing age, lack of criminal history, health and cooperation; medical exhibits are attached. It is signed by Roger L. Weeden, Esquire.

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Case 6:25-cr-00161-JSS-NWH Document 93 _ Filed 09/03/26 Page 1 of 16 PagelD 261

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION

UNITED STATES,
Plaintiff,
Vv.
Case No: 6:25-cr-161

VERLYNN JAMELAH HORNE,
Defendant.

DEFENDANT HORNE’S SENTENCING MEMORANDUM
REQUEST FOR at VARIANCE

As stated in the Pre-Sentence Report, Verlynn Horne has pled guilty in this
cause to Wire Fraud in violation of 18 U.S.C. 1343 and Willful Failure to File Tax
Returns in violation of 26 U.S.C. 7203. The maximum penalty for the offense of
Wire Fraud is 30 years and for Willful Failure to File Tax Returns, 1 year impris-
onment. The United States Probation Office has calculated and stated in the Pre-
sentence report (PSR) that the total offense level for the defendant is 22, which is
driven primarily by the amount of loss and Ms. Horne’s under stated acceptance of
responsibility. Having no prior offenses, Ms. Horne has zero criminal history

points, placing her in the criminal history category of 1. Her offense level and

criminal history category provide a sentencing range of 41 to 51 months. It is well
Case 6:25-cr-00161-JSS-NWH Document 93 _ Filed 09/03/26 Page 2 of 16 PagelD 262

settled that the Court must give respectful consideration to the guidelines. How-
ever, the Court may not presume that the guideline sentence is the correct one, Rita
v. United States, 127 S. Ct. 2456 (2007), nor place “any thumb on the scale favor-
ing a guideline sentence.” United States v. Sachsenmaier, 491 F. 3d 680 (7th Cir.
2007). As the Court knows, the guidelines are but one factor among several listed
in 18 U.S.C. Section 3553 (a). The initial factors listed under section 3553 (a) are
the nature and circumstances of the offense and the personal history and character-
istics of the Defendant. The PSR details the offense conduct and computes the ad-
visory guideline range based on that conduct. The personal history and characteris-
tics of the Defendant address the issues relevant to an individualized sentence. As
stated in Paragraph 103 of the PSR, the personal characteristics of the Defendant
provide recognizable factors, which warrant the Court’s consideration for a variant
sentence below the statutory guidelines. Counsel will also note as stated below,
there are significant factors within the nature and circumstances of the offense,
which provide a recognizable basis for a downward variance.
NATURE AND CIRCUMSTANCES OF THE OFFENSE

As noted in the PSR, Ms. Horne obtained a significant amount of government
money through false representations and provided assistance for other identified, but
uncharged offenders, to fraudulently obtain PPP loans. As noted in the PSR, Ms.

Horne and the unindicted co-defendants obtained fraudulent loans in the total
Case 6:25-cr-00161-JSS-NWH Document 93 Filed 09/03/26 Page 3 of 16 PagelD 263

amount of $5,581,089.20. The application for these loans were facilitated with the
knowing assistance of an uncharged accountant.
PERSONAL HISTORY AND CHARACTERISTICS
Ms. Horne is 49 years old with no prior criminal history. She is the loving
mother of a 24 year old daughter and 15 year old son, but unfortunately suffers from
an array of major health issues. Her poor health would not only make incarceration
substantially more difficult, it would be a constant and imminent threat to her well
being and life. Ms. Horne’s age, lack of prior criminal history suggests that she is
unlikely to reoffend. Her cooperation with law enforcement and her supportive fam-
ily and friends are also strong indicators of amenability for rehabilitation.
FACTORS WARRANTING A SENTENCING VARIENCE
1. Post Offense Behavior
Ms. Horne’s last activity related to this Fraud Offense occurred on September
9, 2020. Verlynn Horne has not committed any additional offenses in the six years
since. Other than this offense and two dismissed misdemeanors from her teenage
years, she has had no other encounters with law enforcement. At Ms. Horne’s ar-
raignment, the Government noted that she was not a flight risk and agreed to release
her on her own recognizance with Pretrial Services Supervision. Noting her lack of
criminal history, her cooperation with the investigation and her exemplary post of-

fense behavior, Ms. Horne is very unlikely to recidivate.
Case 6:25-cr-00161-JSS-NWH Document 93 _ Filed 09/03/26 Page 4 of 16 PagelD 264

2. Verlynn Horne’s Health and Need for Medical Care

Ms. Horne’s poor health and substantial need for medical care further warrant
a downward variance. As stated in Paragraphs 74 and 75 of the PSR, Ms. Horne
suffers from atrial fibrillation (rapid, irregular and often chaotic heart rhythms,
which can lead to blood clots), sinus tachycardia (increased electrical discharges,
which raises blood pressure), stage three kidney failure, venous insufficiency (blood
pooling in leg veins) complex migraines, epileptic seizures and obstructive sleep
apnea. She receives medical care through Advent Health, Dr. Karen G Reddy, MD
and West Orange Nephrology, all of whom have provided documentation of their
treatment. These multiple ailments require regular medical care from Ms. Horne's
medical doctors, especially her cardiologist. (See attached Exhibits)
Ms. Horne requires regular medical care that would not likely be available or ade-
quate in the Bureau of Prisons. Ms. Horne’s body is in a constant state of inflam-
mation. Additionally, Ms. Horne has been diagnosed with anxiety by her therapist.
Ms. Horne has returned to regular contact with her therapist, working on coping
mechanisms to assist her in day-to-day life. According to Anxiety Disorders by the
World Health Organization, for an individual with multiple health issues, anxiety
attacks can be much more severe as they can mimic or trigger cardiac episodes. Ms.
Horne’s physical and mental health will be negatively and severely impacted by her

incarceration and thus be far more punitive than normally contemplated Please find
Case 6:25-cr-00161-JSS-NWH Document 93 _ Filed 09/03/26 Page 5 of 16 PagelD 265

attached as Exhibits, current medical reports documenting the above cited medical
issues and the continued need for care.

3. Bureau of Prisons Unwillingness or Inability
to Provide Appropriate Medical Care

In recent compassionate release litigation in the Middle District of Florida,
the Court made the factual finding that the Bureau of Prisons had ignored for over
three months a medical provider’s referral of an inmate for emergency surgical
care. United States v Justina Maria Holland, 6:20-cr-86-RBD-NWH. (Doc. 207
March 31, 2026). In granting compassionate release the Court noted that in another
earlier 2026 case in the Middle District, the Office of the Inspector General had
found , that the delay of medical care by the Bureau of Prisons had resulted in the
death of inmate. (Doc 207, p.2) See United States v Bardell, 6:11-cr-401.

The District Court in Holland concluded that “The BOP is simply unwilling
or unable to provide appropriate medical care” (Doc 207, p.8). The recent Bardell
and Holland cases not only show how incarceration is more difficult for those suf-
fering medical and health issues, but how incarceration may be life threatening as
well.

4. Verlynn Horne Heightened Acceptance of Responsibility and
Cooperation

On February 6, 2023, more than two years prior to the filing of the Indictment,

Verlynn Horne, voluntarily participated in a two hour proffer with two Special IRS
Case 6:25-cr-00161-JSS-NWH Document 93 _ Filed 09/03/26 Page 6 of 16 PagelD 266

Agents and an Assistant U.S. Attorney. As part of the pre-indictment proffer, she
willingly admitted to fraudulently applying for PPP and EIDL loans and assisting
others in obtaining fraudulent loans. Ms. Horne’s proffer was detailed and specific
as to the bank officers who directed her to include potential employee slots in the
application, the accountant who for cash, knowingly assisted in preparing the
fraudulent applications for the numerous other individuals referred by Ms. Horne
and the individuals who through those referrals also obtained their own fraudulent
loans.

In addition to her oral proffer, Ms. Horne provided the agents full access to
her cell phone, which allowed the agents to download inculpatory text messages
and emails with the unindicted co-conspirators and complicit accountants. Further,
Counsel and Ms. Home confirmed their availability for future cooperation, includ-
ing her willingness to conduct controlled phone calls. Although, the assigned As-
sistant U.S. Attorney transferred to another District, Ms. Horne and Counsel in-
quired and remained available for further cooperation, none of which was sought
by the Government. As a result, according to Paragraph 35 of the PSR almost three
dozen criminally liable participants remained uncharged and their two-million-dol-

lar theft non-recoverable.
Case 6:25-cr-00161-JSS-NWH Document 93 _ Filed 09/03/26 Page 7 of 16 PagelD 267

In the absence of a Rule 5K Motion acknowledging Ms. Horne’s cooperation
and moving for a downward departure, Ms. Horne would request a downward vari-
ance under 3553(a) for her cooperation, disparate treatment and the Government’s

failure to mitigate their loss.

CONCLUSION AND PRAYER

In accord with all the foregoing facts, law and arguments, Counsel respect-
fully prays that this Honorable Court calculate and find support under 3553(a) fac-
tors for a 7 level downward variance from the PSR stated level of 22 to a guideline
level of 15 and impose an 18 month term of imprisonment followed by the required
term of conditional supervision. Under 3553(a) factors a reasonable sentence may
take into account Ms. Horne’s advancing age of 49 with the lack of any prior crimi-
nal history for a one level variance and her major health issues for a three level var-
iance. Further, Ms. Horne’s heighten level of acceptance of responsibility and co-
operation without 5K recognition, her disparate treatment and the Government’s
failure to mitigate their loss, should allow for an additional 3 level variance.

Respectfully Submitted this 3rd day of September 2026,

/s/ Roger L. Weeden, Esquire
Roger L Weeden, Esquire
Case 6:25-cr-00161-JSS-NWH Document 93 Filed 09/03/26 Page 8 of 16 PagelD 268

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoing was filed with the Clerk of Court
(CM/ECF) by using the CM/ECF system which will send a notice of electronic fil-
ing to the Office of United States Attorney, this 3rd day of September, 2026.

/s/Roger L Weeden, Esquire
ROGER L. WEEDEN, ESQUIRE
321 East Colonial Drive

Orlando, Florida 32801

(407) 894-9004
Florida Bar No. 290106
Case 6:25-cr-00161-JSS-NWH Document 93 Filed 09/03/26 Page 10 of 16 PagelD 270

FLORIDA
CARDIOLOGY, P.A.
Dedicated » Compassionate » Convenient oe

Antoinette Lorelike, APRN
Carlie Smith, APRN
Vanessa Tumbell. APRN

Raviprasad Subraya. MD. FACC.FSCAi Ashish Guptu, MD, PhD
Prashanta Ladd. MD Kunal J Teli, MD
Usman Siddiqui. MD Vined Makhija, MD

Sandeep Bajaj. MD. FACC, FCCP
Karan G Reddy, MO. FACC. FACP
Claudio Manubens, MD, FACP

Steven Davis, MD

Roberto Torres-Aguiar, MD. FACC

Jorge O.Diaz, MD. FACC, FHRS

Bridgette Michell, APRN

Milan Kothari, MD. FACC Sayed T. Hussain, MD. FACC Sara Bashyam, APRN Rona Thompson. APRN
Sameer Chadha. MD Harish Patil, MD. FACC, FSCAIL Kathy Ewing. APRN Jonathan Jaremilio, APRN
Edwin Martinez, MD. FACC Ariel Delucruz. APRN Brenda Joseph, APRN

RE: Verlynn J. Horne
DOB: 05/30/1977
Patient ID: 243065 — Verlynn J. Reed-Taylor

To: The Honorable Judge Sneed

RE: Medical Necessity and Severity of Medical Conditions
Dear Judge Sneed:

| am the treating cardiologist for Ms. Verlynn J. Horne and have evaluated and treated her for multiple complex
cardiovascular and related medical conditions. Based upon my ongoing treatment relationship with Ms. Horne, my
review of her medical records, objective diagnostic studies, cardiac monitoring, laboratory findings, physical —
examinations, and her ongoing clinical presentation, it is my medical opinion that her medical conditions are

severe, chronic, complex, and associated with significant functional limitations.

Ms. Horne's medical conditions include resistant and poorly controlled hypertension, recurrent
supraventricular tachycardia (AVNRT) status post ablation with recurrent tachycardia, chronic venous
insufficiency, May-Thurner syndrome, chronic bilateral lower-extremity edema, renal insufficiency,
obstructive sleep apnea, palpitations, chronic fatigue, dizziness, neuropathic pain, migraine headaches,
epilepsy, and other associated medical conditions.

Severity of Cardiovascular Disease and Ongoing Medical Crisis

Ms. Horne's cardiovascular condition is complex and requires continuous medical management, monitoring, and
treatment. Of particular concern is her severely resistant and poorly controlled hypertension despite
extensive medical therapy.

Her reported average blood-pressure readings range from approximately 179/100 mmHg with a heart rate of 96
beats per minute to 208/116 mmHg with a heart rate of 100 beats per minute. These persistently elevated
readings are concerning given her extensive cardiovascular history and multiple associated medical conditions.

Because of the severity, persistence, and complexity of her medical conditions, Ms. Horne is in a constant state
of medical crisis and remains at significant risk of acute medical deterioration. Her condition is medically
unstable and requires continued supervision, close monitoring, medication management, and prompt medical
evaluation whenever her symptoms or cardiovascular status worsen.

ALOMA CLERMONT DAVENPORT HUNTERS CREEK METROWEST

483 N. Semoran Blvd., Suite 102 255 Citrus Tower Bivd, Suite 107 2239 North Boulevard West 14561 Gatorland Cr, 6208 Metrowest Blvd., Suite 102,
Winter Park, FL32792 Clenmont, FL34711 Davenport, FL 33837 Orlando, FL 32837 Orlando, FL 32835

Ph# (407) 645-1847 Phit (352) 394-0893 Phi (863) 419-1418 Ph# (407) 931-0070 Ph# {467} 294-5551

Fax (322) 274-0245 Fax (352) 243-1188
OVIEDO LAKE MARY

7440 Red Bug Lake Road
Oviedo, FL 32765

Ph# (407} 971-0600
Fax# {407} 971-Coe8

lake Mary, FL 32746
Ph (407) 638-9000
Faxi# (407} 878-7609

1307 S. international Pkwy Suite 2072

Fax (863) 419-1809

LAKE BALDWIN

964 Lake Saidwin Lane, Suite 100
Odando, FL 32874

Ph# (407) 601-0888

Fax# (407) 601-0931

Fax# (407) 816-4174

LONGWOOD

515 West SR 434 Suite 301
Longwood, FL3275¢6

Ph# {407} 638-9000

Fax# (407) 878-7009

Fax# (407) 254-5572

DEBARY

110 Pond Court Suite 204

Phi (386) 245-5020

Fax# (386) 259-9539
Case 6:25-cr-00161-JSS-NWH Document 93 _ Filed 09/03/26 Page 11 of 16 PagelD 271

\FLORIDA
CARDIOLOGY, P.A.

Dedicated « Compassionate * Convenient

Sandeep Bajaj. MD. FACC, FCCP Raviprasad Subraya, MD, FACC, FSCAI Ashish Gupta, MD, PhD Antoinetie Lorelike, APRN

Karan G Reddy, 31D, FACC. FACP Prashaata Laddu. MD Kunal J Teli, MD Carlie Smith, APRN
Claudio Manubens. MD, FACP Usman Siddiqui. MD Vined Makhiya, MD Vanessa Turnbull. APRN
Steven Davis, MD Roberto Torres-Aguiar, MD. FACC Jorge O. Diaz. MD, FACC, FHRS Bridgette Mitchell, APRN
Milan Kothari, MD. FACC Sayed T. Hussain, MD. FACC Sara Bashyam. APRN Roaa Thompson, APRN
Sameer Chadha. MD Harish Patil, MD. FACC, FSCAI Kathy Ewing. APRN Jonathan Jaramillo, APRN
Edwin Martinez, MD. FACC Adel Deiacruz. APRN Brenda Joseph, APRN

Her condition is not simply a matter of subjective symptoms or discomfort. She has significant documented
cardiovascular disease accompanied by objective abnormalities and recurrent symptoms requiring ongoing
medical care.

Cardiac Arrhythmia and Procedures

Ms. Horne has a documented history of typical AV nodal re-entry tachycardia (AVNRT) and underwent AVNRT
ablation on April 3, 2013. Despite the prior ablation, she has continued to experience recurrent supraventricular
tachycardia, sinus tachycardia, and symptomatic palpitations.

Because of her recurrent and debilitating palpitations and tachyarrhythmias, an implantable loop recorder was
placed for continued cardiac rhythm monitoring.

Her cardiac monitoring has demonstrated significant recurrent tachycardia. The May 1, 2026 loop-recording
evaluation documented 1,809 episodes of tachycardia, with ventricular rates reaching approximately 180
beats per minute and the longest episode lasting approximately 41 minutes.

These findings demonstrate that her tachyarrhythmia remains an active and clinically significant cardiovascular
problem despite prior intervention and ongoing treatment.

Resistant Hypertension

Ms. Horne’s hypertension has been particularly difficult to control and has required treatment with multiple
medications, including carvedilol, clonidine, Entresto, hydralazine, labetalol, minoxidil, and
triamterene-HCTZ.

Despite this extensive medical therapy, she continues to experience severely elevated blood-pressure readings.
The possibility of renal artery denervation has also been discussed because of the resistant nature of her
hypertension.

The persistence of markedly elevated blood pressure despite multiple medications significantly increases the
medical complexity of her condition and requires continued cardiovascular and medical supervision.

Venous Disease, Edema, and Lower-Extremity Symptoms

Ms. Horne also has significant chronic venous disease and May-Thurner syndrome. Her medical history
includes chronic bilateral lower-extremity edema, venous insufficiency, and significant lower-extremity symptoms.

She has reported moderate to severe swelling of both legs, numbness and burning involving the toes, feet,
and legs, leg cramps, restless-leg symptoms, aching, heaviness, and neuropathic pain.

ALOMA CLERMONT DAVENPORT HUNTERS CREEK METROWEST

483 N. Semaran Blvd., Suite 102 255 Citrus Tower Bivd, Suite 101 2239 North Beulevard West 14561 Gatorland 6r., 6260 Metrowest Blvd, Suite 102,
Winter Park, FL 32792 Clermont, FL 34711 Davenport, FL 33837 Orlando, FL 32837 Orlando, FL 32835

Phit (407) 645-1847 Ph# (352) 394-0893 PhH (863) 419-1413 Ph# (407} 931-0070 Phe (407} 294-5551

Faxd (321) 274-0246 Faxit {352} 243-1188 Fax# (853) 419-2809 FaxH (467) 816-4174 Fax# (407) 294-5572

GVIEDO LAKE MARY LAKE BALDWIN LONGWOOD DEBARY

7449 Red Bug Lake Read 1307 5. International Pkwy Suite 2071 964 Lake Baldwin Lane, Suite 100 515 West 58 434 Suite 301 140 Pond Court Suite 204
Oviedo, FL 32765 Lake Mary, FL 32746 Orlando, FL 32314 Longwood, FL 32750 Debary. Fl 32713

Ph# (407) 971-0000 Phit (407} 538-9600 Ph# {407} 601-0888 Pil (497) 638-9000 Ph# (386) 845-S020

Fax# (407} 972-0008 Faxi# {407} 878-7663 Fax (407) 601-0931 Fax# (407) 878-7669 Fax# (385) 259-9539
Case 6:25-cr-00161-JSS-NWH Document 93 _ Filed 09/03/26 Page 12 of 16 PagelD 272

FLORIDA oN
CARDIOLOGY, P.A.
Dedicated * Compassionate « Convenient —
Sandeep Bajuj. MD. FACC, FCCP Raviprasad Subraya. MD. FACC_FSCAL Ashish Gupta, MD, PhD Antoinette Lorelike, APRN
Karas G Reddy, MD. FACC, FACP Prashanta Laddu. MD Kunal J. Teli, MD Carlie Smith, APRN
Claudio Manubens, MD. FACP Usimsa Siddiqui, MD Vined Makhija, MD Vanessa Tumbuli, APRN
Steven Davis, MD Roberto Torres-Aguiar, 41D. FACC Surge O_Diaz. MD, FACC. FHRS Bridgette Mitchell, APRN
Milan Kothari, MD. FACC Suyed T. Hussain, MD. FACC Sara Bashyam. APRN Rona Thompson. APRN
Sameer Chadha. MD Harish Patil, MD. FACC, FSCAI Kathy Ewing. APRN Jonathan Jaramillo, APRN
Edwin Martinez, MD. FACC Ariel Delucruz, APRN Brenda Joseph, APRN

These symptoms have persisted despite conservative measures including compression stockings, leg elevation,
and leg exercises.

The combination of chronic venous insufficiency, May-Thurner syndrome, bilateral edema, and neuropathic pain
further contributes to the severity of her overall medical condition.

Renal and Other Associated Medical Conditions

Ms. Horne also has documented renal insufficiency, which is clinically significant in the management of her
resistant hypertension and cardiovascular disease and requires continued monitoring.

Her additional medical conditions include obstructive sleep apnea treated with CPAP, fatigue, dizziness,
complex migraine headaches, epilepsy, neuropathic pain, and other associated neurological and medical
conditions.

The cumulative effect of these conditions adds substantially to the complexity of her medical care and overall
clinical presentation.

Medical Necessity and Functional Limitations

Ms. Horne's multiple cardiovascular and systemic medical conditions significantly affect her ability to carry out
normal daily activities consistently.

Her recurrent tachycardia and palpitations, severe hypertension, fatigue, dizziness, bilateral lower-extremity
edema, neuropathic pain, and other associated symptoms may become severe without warning and can require
her to stop activity, rest, change positions, elevate her legs, and allow her symptoms to stabilize.

Her symptoms fluctuate in severity and can worsen unexpectedly. Because of the seriousness of her
cardiovascular disease, it is medically necessary for her to be able to respond promptly when her symptoms
escalate and to obtain appropriate medical evaluation and treatment when medically necessary.

Ms. Horne requires continued access to medical care, appropriate periods of rest, the ability to change
positions as necessary, and the ability to address acute changes in her cardiovascular symptoms without
delay.

Physician's Medical Opinion
Based upon my ongoing treatment of Ms. Horne, review of her medical records, objective diagnostic testing,

cardiac monitoring, laboratory findings, physical examinations, and her continued clinical presentation, it is my
medical opinion that her impairments are severe, chronic, and significantly limiting.

ALOMA CLERMONT DAVENPORT HUNTERS CREEX METROWEST

483 N, Semoran Blvd., Suite 102 255 Citrus Tower Bivd., Suite 101 2239 North Soulevard West 14501 Gatorland Or., 6200 Metrowest Bivd., Suite 102,
Winter Park, FL32792 Clermont, FL34711 Davenport, FL 33337 Orlando, FL 32837 Oriando, FL 32835

Phi {407} 645-1847 Pha (352) 394-0893 Ph# (863) 419-1418 Phit (407} 931-0070 Ph# (407) 294-5551

Fax# (321) 274-0246 Fax# (352) 243-1183 Fax {863} 419-1809 Faxd (407) 816-4174 Faxit {407} 294-5572

OVIEDO LAKE MARY LAKE BALDWIN LONGWOOD DEBARY

7440 Red Sug Lake Road 1307 S. Internationa! Pkvy Suite 2071 $64 Lake @aldwin Lane, Suite 160 515 West SR 434 Suite 301 110 Pond Court Suite 264
Oviedo, FL 32765 isake Mary, FL 32746 Orlando, FL 32314 Longweed, FL 32756 Debary, FL32713

Phi (407) 971-0000 Ph#t (407) 638-9600 Phi (407) 601-0888 Ph# (467) 638-8000 Pha (386) 845-5020

Faxt (407) 971-0608 Fax# (407} 878-7009 Faxd# (407) 601-0932 Fax# (407) 878-7008 Fax# {386} 259-9539
Case 6:25-cr-00161-JSS-NWH Document 93 _ Filed 09/03/26 Page 13 of 16 PagelD 273

A
FLORIDA a
CARDIOLOGY, P.A.
Dedicated » Compassionate * Convenient Seeamctioker”
Sandeep Bajaj. MD. FACC. FCCP Ras iprasad Subraya. MD. FACC. FSCAL = Ashish Gupta, MD, PhD Antoinette Lorclike, APRN
Karan G Reddy, MD. FACC, FAC? Prashanta Laddu. MD Kunal J. Teli, MD Carlie Saiith, APRN
Claudio Manubens, MD. FACP Usman Siddiqui. MB Vined Makhija, MD anessa Turnbull, APRN
Steven Davis, MD Roberto Teres-Aguiar, MD. FACC Jorge O Diaz. MD, FACC, FERS Bridgette Mitchell. APRN
Milan Kothari, MD. FACC Sayed T. Hussain, MD. FACC Sare Bashyem, APRN: Rona Thompson. APRN
Sameer Chadha, MD Harish Patil, MD, FACC. FSCAI Kathy Ewing, APRN Jonathan Jaramillo, APRN
Edwin Martinez, MD, FACC Ariel Delacruz. APRN Brenda Joseph, APRN

Her resistant hypertension remains extremely difficult to control despite extensive medical therapy, with reported
blood-pressure readings ranging from approximately 179/100 to 208/116 mmHg, accompanied by heart rates
ranging from approximately 96 to 100 beats per minute.

She also has recurrent tachyarrhythmias despite prior AVNRT ablation and continued medical treatment. Her
implanted cardiac monitor has documented substantial recurrent tachycardia, including episodes reaching
approximately 180 beats per minute and a prolonged episode lasting approximately 41 minutes.

In addition, her chronic venous insufficiency, May-Thurner syndrome, bilateral lower-extremity edema,
neuropathic pain, renal insufficiency, fatigue, dizziness, obstructive sleep apnea, migraines, epilepsy, and other
medical conditions further compound the severity of her overall medical condition.

Due to the acute and chronic nature of these conditions, Ms. Horne is in a constant state of medical crisis
and remains at significant risk of acute medical deterioration. Her condition requires ongoing medical
supervision, cardiac monitoring, medication management, and prompt medical intervention when her
cardiovascular symptoms become exacerbated.

Her medical condition is complex and unpredictabie, and her symptoms and cardiovascular status may change
rapidly. She may require immediate rest, medical attention, diagnostic evaluation, medication adjustment, or other
treatment when her condition deteriorates.

lt is my medical opinion that continued comprehensive medical care and close cardiovascular monitoring
are medically necessary for Ms. Horne. Her condition requires ongoing evaluation and management because of

the persistent severity of her hypertension, recurrent tachyarrhythmias, cardiovascular symptoms, venous
disease, edema, renal insufficiency, and multiple associated medical conditions.

| respectfully request that the Court give full consideration to the severity, complexity, chronic nature, and
ongoing medical instability of Ms. Horne’s condition.

This opinion is based upon my treatment relationship with Ms. Horne, her medical records, objective diagnostic
findings, cardiac monitoring, laboratory results, physical examinations, and her ongoing clinical course.

Please feel free to contact my office if additional medical information or clarification is required.
Sincerely,

Karan G. Reddy, MD

Florida Cardiology, PA

ALOMA CLERMONT DAVENPORT HUNTERS CREEK METROWEST

483 N. Semoran Blvd., Suite 102 + 255 Citrus Tower Bivd., Suite 101 2238 North Boulevard West 14501 Gatorland Or, 6200 Metrowest Blivd., Suite 102,
Winter Park, FL 32792 Clermont, FL 34711 Davenport, FL 33837 Osfando, FL 32837 Orlando, FL32835

Phe (407) 645-1847 Ph# (352} 394-0893 Phit (863) 419-1413 Ph# (407} 931-C0790 Phe {407} 294-5551

Fax# (321) 274-0246 Fax# (352) 243-1188 Fax# (863) 419-1809 Fax# {407} 816-4174 Faxi (407) 294-5572

OVIEDO LAKE MARY LAKE BALDWIN LONGWOOD DEBARY

7446 Red 8ug Lake Road 1307 S. international Pkwy Suite 2071 964 take Baldwin Lane, Suite 160 515 West SR 434 Suite 301 219 Pond Court Suite 204
Oviedo, FL 32765 Lake Mary, FL 32746 Orlando, FL 32814 Longwood, Fl 32750 Debary, Fl 32713

Ph# (407) 971-00¢0 Pha (407) 638-9000 Phi (407) 661-0883 Ph# (407) 638-8060 Phi (326) 845-5020

Fax#t {407} 971-CO08 Fax (407) 878-7609 Fax# (407) 601-0931 Faxé# {407} 878-7003 FaxH (386) 259-3589
Document 93 Filed 09/03/26 Page 15 of 16 PagelD 275

WEST ORANGE
NEPHROLOGY

S$ ® 3 3 ®

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cs

07/22/2026

To whom it may concern,

Tam the treating nephrologist for Ms. Verlynn Horne and have been actively involved in her care for Stage 3
chronic kidney disease (CKD) and multiple serious, chronic medical conditions. I have personally evaluated
her, reviewed her medical records, monitored her clinical progress, and overseen her treatment.

Ms. Horne's diagnoses include, but are not limited to:
e Stage 3 chronic kidney disease (CKD)
Hypertension
Secondary hyperparathyroidism
Congestive heart failure
Bilateral lower extremity edema
Migraine headaches
Iron deficiency
Chronic fatigue
Other associated medical conditions related to her chronic disease processes

Despite appropriate medical management, including multiple prescription medications, specialist
consultations, diagnostic testing, laboratory monitoring, and conservative treatment measures such as leg
elevation, Ms. Horne continues to experience persistent and significant symptoms. These include chronic
fatigue, weakness, dizziness, headaches, lower extremity swelling, pain, and episodes of uncontrolled
hypertension, all of which substantially limit her functional capacity.

Based on my ongoing treatment relationship with Ms. Horne and my review of her medical history, it is my
medical opinion, to a reasonable degree of medical certainty, that her combined medical impairments
significantly interfere with her ability to perform basic work-related activities on a regular and continuing
basis (defined as eight hours per day, five days per week, or an equivalent schedule).

Due to her medical conditions and associated symptoms, Ms. Horne has marked limitations in her ability to:

e Sustain attention and concentration throughout a normal workday.

e Maintain regular attendance and complete a full workday without excessive interruptions from her
symptoms.

e Stand or walk for prolonged periods because of lower extremity edema, weakness, fatigue, and
cardiovascular limitations.

e Perform work activities at a consistent pace due to chronic fatigue, dizziness, and migraine
headaches.
Lift, carry, push, or pull on a sustained basis.

¢ Tolerate the physical and mental demands of even simple, routine work on a predictable and reliable
basis.
Case 6:25-cr-0016RJSS-NWH Document 93 _ Filed 09/03/26 Page 16 of 16 PagelD 276

Newest ORANGE
~ NEPHROLOG

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In addition, it is my opinion that Ms. Horne would require frequent periods of rest during the day, would
likely experience excessive absenteeism due to exacerbations of her medical conditions and ongoing medical
appointments, and would be unable to sustain competitive employment on a regular and continuing basis.

These limitations are the result of objective medical findings, clinical examinations, laboratory testing,
diagnostic studies, and my ongoing treatment of Ms. Horne. Despite compliance with prescribed treatment,
her symptoms remain persistent and continue to significantly impair her daily functioning.

Based on the chronic nature of her medical conditions and her current clinical course, I expect these
limitations to persist for at least 12 continuous months and likely longer.Therefore, in my professional
medical opinion, Ms. Horne is unable to maintain substantial gainful activity and is not capable of sustaining
full-time competitive employment due to the combined effects of her medically determinable impairments.
Should you require any additional information, please do not hesitate to contact my office at (407) 297-8408.

Sincerely,

Marjan Vandevar, DO
NPI 1861759862


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