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Sentencing Memorandum — USA v. Philossaint et al (Dkt. 306, S.D. Fla.)

Summary

Defendant Philossaint's sentencing memorandum and motion for variance, entered June 21, 2023 as Document 306 in United States v. Philossaint, Case No. 22-CR-80144-RS, in the U.S. District Court for the Southern District of Florida. It argues that the loss table in Section 2B1.1 of the economic crime guideline recommends a disproportionate sentence, and it states that the government urges a sentence of over 10 years. The memorandum asks for a two-level reduction under the new Guidelines amendment § 4C1.1 for zero-point offenders, effective November 1, 2023, and cites potential future deportation as a collateral consequence. It asks for a sentence well below the government's recommended guideline range of 121-151 months, and the signature block names Scott W. Sakin as counsel.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Sentencing Memorandum — USA v. Philossaint et al (Dkt. 306, S.D. Fla.).” Original at ecf.flsd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/sentencing-memorandum-usa-v-philossaint-et-al-dkt-306-s-d-fla-e0f8c6e311/, SHA-256 499859bcffb33ec206577f13ae3d82dac57116cdeaa1c6fe988bc190d3601896.

Full text

Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 1 of 16




                           UNITED STATES DISTRICT COURT
                           SOUTHERN DISTRICT OF FLORIDA

                              CASE NO. 22-CR-80144-RS

  UNITED STATES OF AMERICA,

        Plaintiff,
  vs.

  JOFF STENN WROY PHILOSSAINT,

        Defendant.
   __________________________________/


    DEFENDANT PHILOSSAINT’S SENTENCING MEMORANDUM AND
                   MOTION FOR VARIANCE

        Defendant, JOFF STEN WROY PHILOSSAINT, through counsel, files this

  Motion for a Sentence Variance and sets forth other sentencing factors, pursuant to

  18 U.S.C. § 3553(a) as follows:

        Pursuant to Title 18, United States Code, § 3533(a), the court shall impose a

  sentence sufficient, but not greater than necessary, to comply with the purpose set

  forth in § 3553(a)(2).




                                           1
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 2 of 16




      I.      The Economic Crime Guideline, Section 2B1.11 Recommends a
              Disproportionate and Draconian Sentence for Joff Philossaint,
                          a Non-Violent, First-Time Offender

           The economic crime guideline is driven primarily by Section 2B1.1’s current

  loss table, which has an outsized role in determining the length of Joff’s sentence.

  The sentencing calculation for federal economic crimes includes an enhancement

  under Section 2B1.1’s economic loss table based upon a very broad vision of loss.

  The calculations in this loss table are extraordinarily important because the

  magnitude of the enhancement will drive the severity of the sentence in Joff’s case.

           The Sentencing Commission has substantially increased penalties for

  economic crimes to often extreme levels.2 With respect to fraud type crimes, the

  Sentencing Commission has deviated from its standard practice of anchoring

  recommended sentencing ranges in empirical data.3 Additionally, the series of

  sentencing guideline amendments has resulted in a loss table today that recommends

  sentences for economic crimes that are orders of magnitude greater than the same



  1
    Although Defendant’s sentence is determined pursuant to USSG § 2S1.1, that
  guideline refers to the underlying fraud guideline, USSG § 2B1.1.
  2
    Mark W. Bennett et al., Judging Federal White-Collar Fraud Sentencing: An
  Empirical Study Revealing the Need for Further Reform, 102 IOWA L. Rev. 939, 950
  n.48 (2017)
  3
    James E. Felman, The Need to Reform the Federal Sentencing Guidelines for High-
  Loss Economic Crimes, 23 FED. SENT’G REP. 138, 138 (2010); U.S. SENT’G
  GUIDELINES MANUAL ch. 1, pt. A (U.S. SENT’G COMM’N 2009) (recognizing
  that while the Commission generally anchored its Guidelines in empirical data, it
  departed from the empirical data in crafting guidelines for economic crimes).
                                            2
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 3 of 16




  sentence for the same crime back in the mid-1980s.4 For example, as Judge Rakoff

  explains, while a typical fraud in 1987 would have produced a guideline range of

  30–37 months, by 2003, that same case would result in a recommended sentence of

  151–188 months, an increase of more than 500 percent.5 Because of the

  Commission’s      “preoccupation     and   reliance    with   ‘quantifiable    offense

  characteristics’ the guidelines short shrift both mitigating and aggravating factors

  relative to culpability and harm.”6 The current loss table is likewise a poor indicator

  for relative culpability in Joff’s case. The loss calculation fails to account for the

  extent to which Joff personally profited from the offense.

        The Government suggests Joff is responsible for the total reasonably

  foreseeable loss attributable to all co-conspirators/co-defendants, regardless of how

  much each conspirator personally profited from that amount. The Government urges

  the Court to sentence Joff to over 10 years’ imprisonment, a draconian sentence.

  (DE: 304). Accordingly, the current loss table, which is often the determining factor

  in an economic crime offender’s sentence, has an outsized role in influencing such

  sentences.




  4
    See Bennett et al., supra at 951-53; Felman supra at 138.
  5
    United States v. Gupta, 904 F. Supp. 2d 349, 351 (S.D.N.Y. 2012), aff'd, 747 F.3d
  111 (2d Cir. 2014).
  6
    Bennett et al., supra at 957.
                                             3
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 4 of 16




        Section 2B1.1 is routinely not followed. The U.S. Sentencing Commission

  Interactive Data Analyzer shows that judges are more likely to vary below the

  Guideline range in Section 2B1.1 cases compared to the average federal criminal

  case. For example, Federal judges, on average, tend to grant non-government

  sponsored downward variances to first time (Category I) offenders in approximately

  24 percent of all cases. In contrast, in sentencing first-time (Category I) offenders

  under Section 2B1.1, federal judges, on average, grant non-government sponsored

  downward variances in approximately 31 percent of cases.7

        Indeed, sentencing courts depart or vary below the Guidelines in the majority

  of cases to which Section 2B1.1’s loss enhancement applies. In 2022, utilizing the

  Interactive Data Analyzer, more than 60 percent of sentences issued to Category I

  fraud offenders were below the Guideline Range. Moreover, during the 2018-2022

  fiscal years, out of 51 defendants whose primary guideline was USSG § 2B1.1, with

  a Final Offense Level of 35, a Criminal History Category of I, a guideline range of

  168 to 210 months,8 and excluding anyone who received a reduction for substantial

  assistance pursuant to USSG §5K1.1, the median length of imprisonment imposed




  7
    Interactive Data Analyzer, U.S. SENT’G COMM’N, https://ida.ussc.gov. This data
  is from 2015 through 2022.
  8
    Defendant disputes the offense level of 35 and resulting guideline range that
  probation calculated in Defendant’s Presentence Investigation Report. (DE: 281).
                                           4
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 5 of 16




  was 96 months. See U.S. Sentencing Commission’s Judiciary Sentencing

  Information (“JSIN”).

        Courts have resisted a rigid application of the sentencing guidelines, including

  application of the “amount of loss” enhancement. One district court for example,

  stated:

        What drove the Government’s calculation in this case, more than any
        other single factor, was the inordinate emphasis that the Sentencing
        Guidelines place in fraud cases on the amount of actual or intended
        financial loss. As many have noted, the Sentencing Guidelines, because
        of their arithmetic approach and also in an effort to appear “objective,”
        tend to place great weight on putatively measurable quantities, such as
        weight of drugs in narcotic cases or the amount of financial loss in fraud
        cases, without, however, explaining why it is appropriate to accord such
        huge weight to such factors.

  United States v. Adelson, 441 F. Supp. 2d 506, 509 (S.D.N.Y 2006), aff’d 301 F.

  App’x 93 (2d Cir. 2008).

        The loss enhancement under USSG § 2B1.1 results in a draconian sentence

  for Joff Philossaint, a non-violent, first-time offender.

                              II.    Request for Variance

                      History and Characteristics of the Defendant

        The evidence in this case reveals a man who has engaged in behavior that was

  totally uncharacteristic. Before his involvement in this offense, Mr. Philossaint’s life

  was defined by hard work and dedication to his family and community.




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Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 6 of 16




        Joff Philossaint was born on March 15, 1990, in Port-de-Paix, Haiti. (PSI ¶

  118). He received his bachelor’s in public administration from the University of

  Port-au-Prince. (PSI ¶ 138). In 2016, at age 26, Joff immigrated to the United States.

  (PSI ¶ 125). Joff first worked at a Dania Beach Casino in security and engineering.

  He later became a driver for Uber. Joff then began working for various companies

  and became involved in the instant charges. In 2021, Joff became a naturalized U.S.

  citizen. (PSI ¶ 21).

        Joff’s cousin, Louineze Mertil, attests to the hard-working nature of Joff:

        Upon his arrival to this [sic] United States his work ethic was evident.
        He did not waste any time working to build a life for himself and for
        his family. He immediately learned how to drive. He immediately
        started looking for a job, His drive was rooted in his desire to not only
        make a living for his children but for his family back in Haiti, mother,
        siblings and other family members.

  See Exhibit “1” – Letter from Louineze Mertil, (attached hereto).

        Joff has always supported his two sons, Jay, age 5, and Jeremiah, age 3. (PSI

  ¶ 121). Defendant has another son, Giovany, who resides in Haiti with the son’s

  mother. (PSI ¶ 122). Prior to his incarceration for the instant case, Joff provided

  voluntary child support for his three children in varying amounts. (PSI ¶ ¶ 121, 122).

  Joff is especially helpful to his ex-wife, Ferlinda, who unfortunately is very sick. In

  a letter to the Court, Ferlinda describes the significant role Joff has played in

  providing care to their two young children, as well as his assistance to her while

  battling a fatal prognosis:
                                            6
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 7 of 16




        Presently, I'm faced with a debilitating disease called Lupus. My lungs
        are slowly deteriorating. In the coming weeks, my doctor plans to add
        my name to the organ donation waiting list. I have no other aid to
        support myself or my children in his absence. I'm overwhelmed and my
        abilities are limited.

        Mr. Joff Philossaint is the primary provider and caretaker of our two
        sons. Throughout our relationship, he’s been a responsible father and
        caregiver. Mr. Philossaint is a warm-hearted, nurturing, and loving
        father. In my children's eyes, he's their hero, mentor, and role model.

  See Exhibit “2” – Letter from Ferlinda Mertil Philossaint, (attached hereto). Morgan

  Carbajal, Ferlinda’s doctor, emphasizes the uncertain term of assistance necessary

  for Ferlinda:

        Ms. Philossaint is a patient under my care due to an advanced, life
        threatening chronic lung condition that renders her disabled and
        oxygen-dependent….As her condition is progressive and likely
        terminal without an extreme intervention such as [a] lung transplant, I
        believe her need for assistance will be indefinite.

  See Exhibit “3” – Letter from Morgan Paloma Carbajal, M.D., (attached hereto).

  Joff’s inherent nature as a provider is further illuminated with regard to his mother,

  Lamerice Philossaint:

        I am a person who suffer with an underline [sic] condition of High
        Blood Pressure/diabetes…Joff is my main support system. He makes
        sure my doctor visits is taking [sic] care of and my medicine are getting
        paid. Without Joff being around its becoming a little difficult. I’m not
        able to go to the doctor like I should to maintain my illness.

  See Exhibit “4” – Letter from Lamerice Philossaint, (attached hereto).




                                            7
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 8 of 16




        Gerta Telfort-Morency, a friend of Joff’s, recounts Joff’s valuable

  contributions not just towards her children, but also the Haitian-American

  community:

        We met over 6 years ago. I can attest to his respectfulness, kindness,
        and incredible work ethic. He…has made exceptional contributions to
        his community in the United States.

        He volunteered his time to tutor my children in math and French and
        was always ready to help a fellow Haitian to adjust in the USA with
        jobs, translating English/Creole and work skills.

  See Exhibit “5” – Letter from Gerta Telfort-Morency, (attached hereto).

        Joff’s character, life history and circumstances support a downward variance

  well below the current guideline range set forth in the PSI.



     Request for Two-Level Variance Based on New Guideline Amendment, § 4C1.1

        Joff Philossaint is a first-time, non-violent offender. Defendant urges the

  Court to consider his lack of a criminal history, and to reduce his sentencing

  guidelines by two levels pursuant to an amendment to the Guidelines set to become

  effective November 1, 2023.

        On April 5, 2023 the Sentencing Commission met and voted to promulgate

  the Proposed Amendments to the United States Sentencing Guidelines. Many of the

  Proposed Amendments are in response to the Congressional Directive to the

  Sentencing Commission which seeks to limit long periods of incarceration only to


                                            8
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 9 of 16




  violent offenders and offenders of very serious crimes. United States Sentencing

  Commission Chairman, Carlton W. Reeves in his opening remarks explained that

  many of the Amendments promulgated by the Sentencing Commission were being

  proposed in order to “give judges more discretion to expand non-carceral options to

  more people.”9

        Chairman Reeve’s remarks are in keeping with the trajectory that began with

  the Supreme Court’s decision in United States v. Booker, 543 U.S. 220 (2005), and

  followed by Kimbrough v. United States, 128 S. Ct. 558 (2007), Rita v. United States,

  127 S. Ct. 2546 (2207), and Gall v. United States, 128 S. Ct. 586 (2007). A trajectory

  which for the past eighteen years has resulted in imposing lower sentences for non-

  violent, first-time offenders with a particular emphasis on individualized sentencing.

  Thus, while the Guidelines remain “the starting point and the initial benchmark” in

  determining a sentence, this Court “may not presume that the Guidelines range is

  reasonable,” but must “make an individualized assessment based on the facts

  presented.” Gall, supra at 596-598.

        One of the most recent examples of the Sentencing Commission’s

  commitment to the trajectory that began post-Booker, has come in the form of the

  proposed amendment to the Advisory Guidelines. Of particular note is the proposed



  9
   https://www.ussc.gov/sites/default/files/pdf /amendment-process/public-hearings-
  and-meetings/ 20230405/20230405_remarks.pdf (page 18-19).
                                            9
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 10 of 16




   Amendment which creates a new section under “Chapter Four - Criminal History

   and Criminal Livelihood” entitled: § 4C1.1 Adjustment for Certain Zero-Point

   Offenders. This new provision calls for a two-point decrease from the total base

   offense level of the applicable Guidelines.

         Mr. Philossaint meets all ten criteria set out in USSG § 4C1.1:

         a) Joff has not received any criminal history points (PSI ¶ 112);

         b) Joff has not received an adjustment under § 3A1.4 (Terrorism);

         c) Joff did not use any violence or credible threats of violence in connection

            with the offense;

         d) The offense did not result in death or serious bodily injury;

         e) The instant offense is not a sex offense;

         f) Joff did not personally cause financial hardship;

         g) Joff did not possess, receive, purchase, transport, transfer, sell, or

            otherwise dispose of a firearm or other dangerous weapon (or induce

            another participant to do so) in connection with the offense;

         h) The instant offense of conviction is not covered under § 2H1.1 (Offenses

            involving individual rights);

         i) Joff did not receive an adjustment under § 3A1.1 (Hate Crime Motivation

            or Vulnerable Victim) or § 3A1.5 (Serious Human Rights Offense); and




                                            10
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 11 of 16




         j) Joff did not receive an adjustment under § 3B1.110 (Aggravating Role) and

            was not engaged in a continuing criminal enterprise, as defined in 21

            U.S.C. § 848.1.

         Several judges in the Southern District of Florida have already applied the

   two-level reduction for “zero point” offenders, notwithstanding the effective date of

   the amendment is not for another few months. See United States v. Christian

   Encarnacion, 22-20422-DMM; United States v Robles, 22-20494- RNS; United

   States v. Saomi Tatiana Mera-Palomino, 22-20501-BB; and United States v. Yohan

   del Pozo Hernandez, 22-cr-20429-RNS. Accordingly, Joff should likewise receive

   a two-level reduction at his upcoming sentencing.



                      Collateral Consequences Support a Variance

         Joff’s potential future deportation is a collateral consequence that a sentencing

   court may consider under 18 U.S.C. § 3553(a). United States v. Hercules, 947 F.3d

   3, 5 (1st Cir. 2020). The Government chose to prosecute Joff on Count 4 – acquiring

   naturalized U.S. citizenship by fraud – with the goal of Joff facing deportation upon

   completing his sentence. The consequences of very likely deportation are

   insurmountable. Joff’s two children, Jay and Jeremiah, will have no choice but to be



   10
     Defendant objects to any aggravating role adjustment applied in Defendant’s PSI
   report. (DE: 281).
                                             11
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 12 of 16




   raised without their father, who has been a critical, stable figure in their young lives.

   There will also be detrimental consequences for the health of Joff’s ex-wife,

   Ferlinda, and mother, Lamerice, for whom Joff has been a primary caregiver. See

   United States v. Leon, 341 F.3d 928 (9th Cir. 2003) (Defendant’s indispensable role

   in caring for wife who recently had her kidney removed due to renal cancer

   constituted sufficient extraordinary family circumstances to warrant downward

   departure of six levels). Further, Joff’s livelihood will be in danger if sent back to

   Haiti.

            Haiti remains at a Level 4, Do Not Travel, travel advisory with the U.S.

   Department of State. Haiti Travel Advisory, U.S. Dep’t of State, available at

   https://travel.state.gov/content/travel/en/traveladvisories/traveladvisories/haiti-

   travel-advisory.html (last visited June 12, 2023). This is “due to kidnapping, crime,

   civil unrest, and poor health infrastructure.” Id. The State Department warns:

            Kidnapping is widespread, and victims regularly include U.S. citizens.
            Kidnappers may use sophisticated planning or take advantage of
            unplanned opportunities, and even convoys have been attacked.
            Kidnapping cases often involve ransom negotiations and U.S. citizen
            victims have been physically harmed during kidnappings. Victim’s
            families have paid thousands of dollars to rescue their family members.

            Violent crime, such as armed robbery, carjackings, and kidnappings for
            ransom that include American citizens are common. Mob killings
            against presumed criminals have been on the rise since late April.
            Travelers are sometimes followed and violently attacked and robbed
            shortly after leaving the Port-au-Prince international airport. Robbers
            and carjackers also attack private vehicles stuck in heavy traffic
            congestion and often target lone drivers, particularly women. As a
                                              12
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 13 of 16




         result, the U.S. Embassy requires its personnel to use official
         transportation to and from the airport.

         Protests, demonstrations, tire burning, and roadblocks are frequent,
         unpredictable, and can turn violent. The U.S. government is extremely
         limited in its ability to provide emergency services to U.S. citizens in
         Haiti – assistance on site is available only from local authorities
         (Haitian National Police and ambulance services). Local police
         generally lack the resources to respond effectively to serious criminal
         incidents. Shortages of gasoline, electricity, medicine, and medical
         supplies continue throughout much of Haiti. Public and private medical
         clinics and hospitals often lack qualified medical staff and even basic
         medical equipment and resources.

   Id. The government is plagued with corruption and police have not been able to

   control gang violence. The U.S. State Department has explained:

         The government rarely took steps to identify, prosecute, and punish
         government and law enforcement officials who committed abuses or
         engaged in corruption, and civil society groups alleged widespread
         impunity regarding these acts.

         Gang violence continued at high rates in the Port-au-Prince
         metropolitan area. Some gangs allegedly received support from
         political and economic elites. Kidnappings for ransom by armed gangs
         increased and affected all parts of society. Armed gangs were also
         responsible for armed conflicts resulting in killings, brutal attacks on
         citizens, targeted instances of sexual violence, mutilation of human
         remains, widespread displacement, and the destruction of homes and
         property.

   2022 Country Report on Human Rights Practices: Haiti, U.S. Dep’t of State,

   available at https://www.ecoi.net/en/document/2089114.html (last visited June 12,

   2023).




                                           13
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 14 of 16




         Because Joff will likely face deportation, he will be ineligible to serve the last

   part of his prison term in the community confinement reentry program, or to benefit

   from the First Step Act, which would enable Joff to earn additional time credits. The

   unavailability of these options has the effect of making the affected prison term more

   severe for foreign nationals, and, in Joff’s case, revoked citizenship. See United

   States v. Thomas, 999 F.3d 723, 736 (D.C. Cir. 2021).



     The Need for the Sentence to Reflect the Seriousness of the Offense, Promote
                  Respect for the Law and Provide Just Punishment

         The Probation Officer calculates a total offense level of 35 and a guideline

   imprisonment range of 168-210 months for Defendant. (DE: 295-1). The

   Government, on the other hand, recommends Joff be sentenced to a term of

   incarceration in the range of 121-151 months, with a total offense level of 32. (DE:

   304). The recommended sentencing ranges proposed by both Probation and the

   Government result in a sentence that is far greater than necessary to reflect the

   seriousness of the offense, promote respect for the law, and deter future criminal

   conduct.

         The sentences already rendered to two of Joff’s co-conspirators support a

   variance well below the above guideline ranges. David Andre Johnson, a co-

   conspirator of Joff, was involved in completing fraudulent applications for EIDL

   and PPP loans for his business, DDZ Enterprises, LLC. (PSI ¶ 79). Mr. Johnson pled
                                             14
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 15 of 16




   guilty to five counts of wire fraud, amounting to $730,734.00. See United States v.

   Johnson, 22-cr-60201-RS (DE: 29). Despite a Criminal History category of II, Mr.

   Johnson was sentenced to 24 months imprisonment followed by three years’

   supervised release. See Johnson (DE: 48,50).

         Brianna Monique Gayle, one of Joff’s co-defendants, worked with Joff for

   over a year. (PSI ¶ 78). Prior to her involvement with Joff in the instant case, Ms.

   Gayle worked for ADP. (DE: 94). While working for Joff, Ms. Gayle contacted ADP

   on multiple occasions to manage payroll accounts, to add or remove accounts, and

   to retrieve payroll documents and W-2 forms for the payroll accounts. (PSI ¶ 78);

   (DE: 94). Additionally, Ms. Gayle obtained for herself, as an independent contractor,

   a fraudulent PPP loan for approximately 20 thousand dollars. (PSI ¶ 78). Despite

   pervasive involvement in the conspiracy, Ms. Gayle was sentenced to a non-

   incarceration term of three years’ probation followed by six months’ home detention.

   (DE: 215).

         Many of Joff’s co-defendants have not been sentenced, as their cases remain

   pending. Considering the sentences already rendered to those involved in the

   conspiracy, fairness dictates a sentence for Mr. Philossaint well below his guideline

   range as outlined in his PSI, and well below the Government’s recommended

   guideline range of 121-151 months.




                                            15
Case 9:22-cr-80144-RS Document 306 Entered on FLSD Docket 06/21/2023 Page 16 of 16




         WHEREFORE, Defendant respectfully moves this Court to grant Defendant

   a sentence variance as requested herein, pursuant to 18 U.S.C. § 3553(a).



                                                 Respectfully Submitted,

                                                 SCOTT W. SAKIN, P.A.
                                                 CJA Counsel for Defendant:
                                                 JOFF PHILOSSAINT
                                                 2883 Executive Park Drive, Suite 200
                                                 Weston, Florida 33331-3662
                                                 Tel. (954) 779-7879
                                                 scott@sakinlaw.com

                                                 By: ___/s Scott W. Sakin___________
                                                       SCOTT W. SAKIN, ESQ.
                                                       Fla. Bar No. 349089



                            CERTIFICATE OF SERVICE

         I HEREBY CERTIFY that a true and correct copy of the foregoing

   DEFENDANT        PHILOSSAINT’S        SENTENCING         MEMORANDUM          AND

   MOTION FOR VARIANCE was filed electronically with the Clerk of the Court

   through the CM/ECF system and copies of same distributed to all counsel of record

   and known interested parties on this 21st day of June, 2023.

                                                 By: ___/s Scott W. Sakin___________
                                                       SCOTT W. SAKIN, ESQ.
                                                       Fla. Bar No. 349089




                                            16


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