Sentencing Memorandum — USA v. Memon (Dkt. 69, S.D. Fla.)

Summary

The United States' sentencing memorandum and response in opposition to Kareem Memon's request for a downward variance, filed May 13, 2024 as Document 69 in Case Nos. 23-CR-80068-AHS(s) and 24-CR-60004-AHS in the U.S. District Court for the Southern District of Florida and signed by Assistant United States Attorney Robin W. Waugh. It states Memon pled guilty on September 21, 2023 to wire fraud, two money transaction counts and felon in possession, and on February 8, 2024 to healthcare fraud and anti-kickback conspiracy charges. The memorandum cites an actual Medicare loss of approximately $11,384,001, a PPP and EIDL loss of approximately $451,154.00, and kickbacks of at least $1,486,261.78. It describes a $386,954 PPP loan from Kabbage and a $64,200 EIDL paid to KSM Enterprise Inc. and asks the court to deny the variance from the guideline range of 121-151 months.

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