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Sentencing Memorandum — USA v. Guillermo Lopez Carrazana (Dkt. 112, S.D. Fla.)

Summary

A Sentencing Memorandum for Guillermo Lopez Carrazana in United States of America v. Guillermo Lopez Carrazana, Case No. 1:25-cr-20178-ELA-1, in the U.S. District Court for the Southern District of Florida, Miami Division, entered on the docket December 10, 2025 as Document 112 and signed by defense counsel Bijan S. Parwaresch. It states that Lopez Carrazana pled guilty to Count One of a 10 Count Indictment, conspiracy to commit wire fraud under 18 U.S.C. § 1349, and asks the Court for a variance under 18 USC 3553 (a). It argues that the codefendants had their own clients, supplied the false information, sent completed applications to Lopez Carrazana and made far more money. It cites the defendant's education and work as a nurse, clean criminal record, early guilty plea and family support, and attaches character letters addressed to U.S. District Judge Ed Artau.

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Cite this document

“Sentencing Memorandum — USA v. Guillermo Lopez Carrazana (Dkt. 112, S.D. Fla.).” Original at ecf.flsd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/sentencing-memorandum-usa-v-ulloa-et-al-dkt-112-s-d-fla-180c05e1e6/, SHA-256 8cacfc147632c8082f971bbc50df8cf0579d5245effd02c3b07ab62c2b49381b.

Full text

Case 1:25-cr-20178-EA Document 112 Entered on FLSD Docket 12/10/2025 Page 1 of 10




                              UNITED STATES DISTRICT COURT
                              SOUTHERN DISTRICT OF FLORIDA
                                      (Miami Division)

                                CASE NO.: 1:25-cr-20178-ELA-1

  UNITED STATES OF AMERICA,
  Plaintiff,

  v.

  GUILLERMO LOPEZ CARRAZANA,
  Defendant.
                 ____________                  /

                                SENTENCING MEMORANDUM

                                    MEMORANDUM OF LAW

         The Sentencing Reform Act of 1984 created the U. S. Sentencing Guidelines

  (“Guidelines”) in which a Federal District Court Judge must consider each of the factors set forth

  in 18 USC § 3553 (a) when crafting a sentence. However, judges cannot increase sentences beyond

  the statutory maximum based on their own factual findings. See Blakely vs. Washington, 524 US

  296, 303-04 (2004); Later the Court more thoroughly remedied the constitutional problem by

  holding that sentencing courts must consider the guidelines as only “advisory” and that may “tailor

  their sentence in light of other statuary concerns”. See United States cs. Booker 543 US 220, 245-

  246 (2005). Pursuant to Booker, guidelines are no longer mandatory, and the final sentence has to

  withstand "Reasonableness" review. Id 543 US 220, 221; See also Rita vs. United States, 551 US

  338 (2007); See also Kimbrough vs. United States, 552 US 85 (2007); Gall vs. United States, 525

  US 38 (2007).

         The factors the Court must consider in crafting a sentence are:

  (1) The nature and circumstances of the offense and the Defendant's history and characteristics

  (18 USC § 3553(a)(1)).


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Case 1:25-cr-20178-EA Document 112 Entered on FLSD Docket 12/10/2025 Page 2 of 10




  (2) The general purpose of the Sentencing Reform Act: The need for the sentence imposed to:

  (A) Reflect the seriousness of the offense, to promote respect for the law, and to provide just

  punishment for the offense;

  (B) To afford adequate deterrence to criminal conduct;

  (C) To protect the public from further crimes of the defendant;

  (D) To protect the defendant with needs for educational or vocational training,

  medical care, or other correctional treatment in the most effective manner (18 USC § 3553(a) (2)).

  (3) The kinds of sentences available (18 USC § 3553(a)(3)).

  (4) The pertinent policy statements issued by the "U.S Sentencing Commission" (18 USC §

  3553(a) (5)).

  (5) The need to avoid unwarranted sentences disparities between defendants convicted of similar

  conduct: (18 USC § 3553 (a)(6)).

  (6) The need to provide restitution to any victims (18 USC § 3553(a)(7)).

  (7) The applicable sentence range recommended by the “Guidelines” (18 USC § 3553(a) (4)).

  Sentencing courts are required to consider the § 3553(a) factors and may not presume that a

  sentence within the guidelines range is automatically reasonable. Gall 128 S.CT 586,596. But

  sentencing courts have a great deal of discretion in deciding how the factors apply to the case and

  in setting a sentence accordingly. See Gall 127 S.CT at 597. Sentencing courts are not required to

  impose a sentence within the range provided by the “Guidelines. See Kimbrough 128 S.CT at 574-

  75. United States vs. Diaz - Arguera, 447 F.3d 1167 (9th Cir,2006). Everything boils down to

  the sentencing court imposing a sentence that is both procedurally reasonable and substantive

  reasonable and according to the § 3553(a) factors, Mr. Lopez Carrazana is asking this Honorable




                                              Page 2 of 5
Case 1:25-cr-20178-EA Document 112 Entered on FLSD Docket 12/10/2025 Page 3 of 10




  Court to apply a variance from the federal sentencing guidelines in this case and states as grounds

  thereof the following:

                      REQUEST FOR VARIANCE UNDER 18 USC 3553 (a)

                              Nature and Circumstances of the Offense

     The Defendant pled guilty to Count One of a 10 Count Indictment. Count One alleges

  conspiracy to commit wire fraud in violation of 18 U.S.C. § 1349. The defendant accepted full

  responsibility for his actions and plead guilty in a speedy fashion.

         Both codefendants had their own clients and conducted all contact with those clients. The

  two codefendants sent out most of the applications already filled out to the Defendant and

  provided all the false information to the Defendant. These codefendants ultimately paid a portion

  of their gain to the Defendant. These two codefendants made far more money than the

  Defendant did. The Defendant almost never interacted with the clients of the codefendants and

  had no way of knowing how much and if the codefendants got paid. In sum, the codefendants

  advertised to get clients, controlled all the clients, provided file information, and controlled the

  payments. They then sent a portion of their profits to the Defendant.

                           The History and Characteristics of the Defendant

     The Defendant is a 33-year-old United States citizen. He first migrated with his family to the

  United States in 1998 on a lottery visa. Both the Defendant’s mother and father, who remain

  married to-date, reside in Miami, FL. The Defendant also has one full sister, and two half

  siblings on his father’s side, who all reside in Miami, FL as well. The Defendant had a delayed

  learning disability as a child, which required him to attend speech therapy to learn English as his

  first language, then Spanish as his second language.




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Case 1:25-cr-20178-EA Document 112 Entered on FLSD Docket 12/10/2025 Page 4 of 10




     In 2023, the Defendant married his longtime girlfriend, Ariane Lopez, a nurse practitioner,

  and they had one son. The Defendant holds a Master of Science Degree in Nursing and is

  currently enrolled in a Doctor of Nursing Practice program online at Western University. He has

  been employed as a legal nurse consultant for Florida Injury Solutions for over a year. Prior to

  his employment at Florida Injury Solutions, the Defendant was employed as a nurse since 2021.

     The Defendant has a clean criminal record and he was ready to cooperate with the

  Government right away and was available as a witness against the codefendants. The Defendant

  is now employed in an unrelated industry and will continue to be a productive member of

  society.

                                    The Defendant’s Family Support

     The Defendant remains close to all his family members. His wife is aware of the criminal

  situation he is currently in, and she remains supportive of him as evidenced by the attached

  Character Letters. Under all accounts, the defendant is an excellent father.

          The Need to Avoid Unwarranted Sentencing Disparities Among Defendants with
              Similar Records Who Have Been Found Guilty of Similar Conduct

     USA v. Heidi Cid, 1:23-cr-20421-AMC-1, the defendant pled guilty to over $14,500,000 in

  PPP fraud and was sentenced to two months followed by three years supervised release. She was

  also charged simultaneously in Case Number 1:23-cr-20422-RNS-1.

                                                Conclusion

       Mr. Lopez Carrazana cooperated with the process as best he could, accepted responsibility

  early on in this case, and pled guilty in a speedy fashion.

     WHEREFORE the Defendant, Guillermo Lopez Carrazana, through undersigned counsel

  respectfully petitions this Honorable Court to apply a variance in this case.




                                               Page 4 of 5
Case 1:25-cr-20178-EA Document 112 Entered on FLSD Docket 12/10/2025 Page 5 of 10




                                 CERTIFICATE OF SERVICE

         I HEREBY CERTIFY that a true and correct copy of the foregoing instrument was e-filed

  via   CM/ECF     and   furnished   to     Assistant   United   States     Attorney   Roger   Cruz

  at roger.cruz@usdoj.gov on this 10th day of December, 2025.



                                                  Respectfully submitted,

                                      By:           /s/ Bijan S. Parwaresch
                                                   Law Offices of Bijan Parwaresch & Associates
                                                   FL Bar No. 127700
                                                   407 Lincoln Road, Suite 12-E
                                                   Miami Beach, FL. 33139
                                                   Tel. 305-505-8858
                                                    bijanlaw@aol.com
                                                   Attorney for Defendant




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Case 1:25-cr-20178-EA Document 112 Entered on FLSD Docket 12/10/2025 Page 6 of 10




   CHARACTER REFERENCE LETTER FOR COURT


   Miami, December 4th, 2025


   Honorable Mr. Ed Artau

   U.S. District Judge


   To whom it may concern,


   My name is Manuel Alvarez, and I am writing on behalf of Mr. Guillermo Lopez, someone I have known
   for many years and deeply respect. Guillermo is a person of genuine kindness, humility, and strong
   character. He is always willing to help others and consistently treats people with compassion and
   respect.


   The incident before the Court does not reflect the man I know. Guillermo feels true remorse and
   understands the seriousness of the situation. I sincerely believe he will learn from this experience and
   continue striving to be the responsible, caring individual he has always been.


   Your Honor, I respectfully ask that you consider the sincerity of his character and the positive impact he
   has on those around him.


   Sincerely,

   Manuel Alvarez

   1424 NE Miami Pl

   Miami, FL 33132

   Apt. 3414

   manubass901204@gmail.com
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