Sentencing Memorandum — USA v. Padilla-Reyna (Dkt. 42, E.D. Wash.)

Summary

The defendant's sentencing memorandum, filed May 8, 2023 as ECF No. 42 in United States v. Karla L. Padilla-Reyna, Case No. 22-cr-2059-MKD-1, in the U.S. District Court for the Eastern District of Washington, submitted by Robin C. Emmans and Ulvar W. Klein of 2nd Street Law PLLC. It raises no objections to the presentence report and states restitution is stipulated at $302,145.40, that $300,000 has been deposited in trust with counsel, and that a civil forfeiture of real estate tied to PPP loan funds has been negotiated. The memorandum requests a sentence of probation for 36 months with full restitution, acknowledging a guideline range of 21-27 months. It argues that publicity of such prosecutions already deters others and that the defendant faces lasting career consequences.

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