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UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA CASE NO. 2:17-CR-164(15)

Plaintiff,
JUDGE EDMUND A. SARGUS, JR.
  v.
JOSE BONILLA-MEJIA
a/k/a Emedalio Mejia-Bonilla
a/k/a Espia

Defendant.

GOVERNMENT’S SENTENCING MEMORANDUM

The United States, by and through undersigned counsel, hereby submits the following

sentencing memorandum to aid the Court in its consideration of sentencing issues in this case.

BACKGROUND

On February 15, 2018, the grand jury in the Southern District of Ohio returned the

Second Superseding Indictment, which charges the defendant, Jose Bonilla-Mejia (a/k/a Espia),

with one count of conspiracy to commit racketeering, in violation of 18 U.S.C. § 1962(d) [Count

One]; three counts of murder in aid of racketeering, in violation of 18 U.S.C. § 1959(a)(1)

[Counts Two through Four]; and one count of murder through the use of a firearm during and in

relation to a crime of violence, in violation of 18 U.S.C. §§ 924(c)(1)(A) and 924(j)(1) and 18

U.S.C. § 2 [Count Five]. The Second Superseding Indictment also includes a forfeiture

allegation and a substitute assets clause requiring the defendant to relinquish his interest in any

property associated with this offense.

On August 7, 2019, Mr. Bonilla-Mejia entered a plea of guilty to Counts One, Two, and

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Three of the Second Superseding Indictment, consistent with the terms of the plea agreement

into which the United States and the defendant entered pursuant to Rule 11(c)(1)(A) of the

Federal Rules of Criminal Procedure. The defendant also agreed to forfeit any right, title, and

interest in any and all property that he acquired or maintained in connection with the charged

criminal activity. In pleading guilty, the defendant admitted that he unlawfully conspired to

participate in the affairs of La Mara Salvatrucha, commonly known as MS-13, a racketeering

enterprise that operated in the Southern District of Ohio and elsewhere. Specifically, the

defendant admitted that as a member of MS-13, he committed, and conspired with others to

commit, multiple homicides on behalf of the enterprise.

The Probation Officer released the final Presentence Investigation Report (“PSR”) on

November 26, 2019. Sentencing in this matter is scheduled for February 27, 2020.

PRESENTENCE INVESTIGATION REPORT AND RECOMMENDATION

The Probation Officer calculated the defendant’s advisory sentencing range under the

United States Sentencing Guidelines (“Guidelines”) as life imprisonment, based on a Total

Offense Level of 43 and a Criminal History Category of I. The Probation Officer identified three

factors that could support an upward departure in this case, and also noted that the nature and

circumstances of the offense and the defendant’s history and characteristics could warrant a

deviation. The Probation Officer’s recommended sentence is a term of incarceration of life on

each count (to be served concurrently), a term of supervised release of five years on each count

(to be served concurrently), and the payment of $1,653.03 in restitution.

The United States agrees with the Probation Officer’s factual findings and computation of

the Guidelines range, and thus has no objections to the PSR. As set forth below, the United

States concurs with the Probation Officer’s sentencing recommendation and requests that the

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Court impose a sentence of life imprisonment without the possibility of release, which is the

mandatory sentence in this case. The Court should also impose a term of supervised release of

five years and order the defendant to pay restitution in the amount of $1,653.03.

ANALYSIS AND RECOMMENDATION OF THE UNITED STATES

After United States v. Booker, 543 U.S. 220 (2005), district courts should engage in a

three-step sentencing procedure. See U.S.S.G. § 1B1.1(a)-(c) (outlining the sentencing process).

First, the Court should calculate the applicable Guidelines range. Gall v. United States, 552 U.S.

38, 49 (2007) (“As a matter of administration and to secure nationwide consistency, the

Guidelines should be the starting point and the initial benchmark.”). Second, the Court should

consider whether a departure from the Guidelines range is appropriate. Rita v. United States, 551

U.S. 338, 351 (2007). Third, the Court should consider “all of the [18 U.S.C.] § 3553(a) factors”

in deciding what sentence to impose. Gall, 552 U.S. at 49–50. Under 18 U.S.C. § 3553, the

Court is directed to “impose a sentence sufficient, but not greater than necessary, to comply with

the purposes” of sentencing set forth in 18 U.S.C. § 3553(a)(2). 18 U.S.C. § 3553(a). Booker

requires that the sentence a district court imposes be reasonable. United States v. Jackson, 408

F.3d 301, 304 (6th Cir. 2005). A sentence within the applicable Guidelines range is deemed

presumptively reasonable. Rita, 551 U.S. at 347; United States v. Graham-Wright, 715 F.3d 598,

604 (6th Cir. 2013); United States v. Williams, 436 F.3d 706, 708 (6th Cir. 2006) (“We now join

several sister circuits in crediting sentences properly calculated under the Guidelines with a

rebuttable presumption of reasonableness.”).

I. Sentencing Guidelines Range

The Probation Officer calculated Mr. Bonilla-Mejia’s Total Offense Level as 45, which

was adjusted to 43 based on the operation of the Guidelines. See U.S.S.G., Ch. 5, Part A, App.

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Note 2. In light of the absence of prior criminal convictions, the defendant was assigned to

Criminal History Category I. This results in a sentencing range of life imprisonment.

II. Possible Departures

The Probation Officer identified three possible bases for an upward departure from the

applicable Guidelines range: U.S.S.G. §§ 5K2.1 (death(s) resulted from the offense), 5K2.3

(victim(s) suffered extreme psychological injury), and 5K2.8 (defendant’s conduct was unusually

heinous, cruel, brutal, or degrading to the victim(s)). The United States will defer to the Court

regarding whether and how to apply these provisions of the Guidelines. The government notes

that, because the Guidelines call for a sentence of life imprisonment, it would be impossible to

increase the defendant’s sentence above the advisory range.

III. Sentencing Factors in 18 U.S.C. § 3553(a)

In addition to the Guidelines, the Court must consider seven factors in determining a

sentence: (1) the nature and circumstances of the offense and the history and characteristics of

the defendant; (2) the statutory purposes of sentencing; (3) the kinds of sentences available;

(4) the kinds of sentences and the sentencing range as set forth in the Guidelines; (5) the

Guidelines policy statements; (6) the need to avoid unwarranted sentencing disparities; and

(7) the need to provide restitution to any victims of the offense. 18 U.S.C. § 3553(a). The

United States submits that careful consideration of these factors supports a sentence of life

imprisonment without the possibility of release, which is the mandatory sentence in this case.

See 18 U.S.C. § 1959(a)(1). Such a sentence would also be consistent with the applicable

Guidelines range and the parties’ plea agreement.

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A. The Nature and Circumstances of the Offense

Mr. Bonilla-Mejia has admitted to his involvement with MS-13, a transnational

racketeering enterprise comprised primarily of immigrants and descendants of immigrants from

El Salvador, Guatemala, and Honduras. MS-13 has become one of the largest criminal

organizations in the United States, with more than 10,000 members and associates estimated to

be operating in at least 40 states. In Ohio and other states, MS-13 is organized into “cliques,”

which are smaller groups of MS-13 members and associates who act on behalf of the enterprise

in a specific region, city, or part of a city. This organizational structure facilitates the

transmission of orders from MS-13 leadership in El Salvador to cliques in the United States and

the transmission of money from cliques in the United States to gang leadership in El Salvador.

Mr. Bonilla-Mejia had a leadership position in the organization, a fact made clear by his

participation in a meeting of high-ranking MS-13 members in Richmond, Virginia, in December

2015 – a meeting that included the attendees receiving direction (via telephone) from a gang

leader in El Salvador who wielded authority over a number of MS-13 cliques in the eastern half

of the United States.

As set forth in the Second Superseding Indictment, Mr. Bonilla-Mejia and his co-

defendants knowingly and unlawfully conspired to participate in the affairs of the MS-13

enterprise in Ohio and elsewhere over the course of more than a decade. MS-13 members and

associates in the Southern District of Ohio engaged in a wide range of criminal activity,

including murder, drug trafficking, extortion, money laundering, assault, obstruction of justice,

witness intimidation, weapons offenses, and immigration-related violations. Specifically,

Mr. Bonilla-Mejia adopted the goals of the enterprise by conspiring with other MS-13 members

and associates to commit three violent, premeditated homicides in the Columbus area.

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1. Murder of Carlos Serrano-Ramos (a/k/a Migra)

The victim of Mr. Bonilla-Mejia’s first homicide in the Southern District of Ohio was

Carlos Serrano-Ramos (a/k/a Migra), a man who claimed to be an MS-13 member from Virginia.

The defendant and his co-conspirators suspected that Mr. Serrano-Ramos was in fact a member

of the rival 18th Street gang, due in no small part to the presence of suspicious tattoos on his

body. After conducting an investigation, the MS-13 members decided that Mr. Serrano-Ramos

had to be killed. Martin Neftali Aguilar-Rivera (a/k/a Momia), the leader of the Columbus

clique, ordered this homicide.

In the summer of 2015, MS-13 lured Mr. Serrano-Ramos to the home of co-defendant

Juan Jose Jimenez-Montufar (a/k/a Chele Trece) at 3350 Anita Street, Columbus, Ohio, under

the guise of gathering for a barbeque. Later that night, eight MS-13 members, including

Mr. Bonilla-Mejia, offered to drive Mr. Serrano-Ramos home. This was also a ruse. Instead of

taking the victim to his residence, they drove to Innis Park and walked into a wooded area.

Mr. Bonilla-Mejia and five of his associates then attacked Mr. Serrano-Ramos. What began as a

beating ended with the MS-13 members stabbing the victim to death with a knife and burying his

body in a shallow grave. According to the forensic anthropologists who examined Mr. Serrano-

Ramos’s skeletonized remains, the victim suffered at least 29 cut wounds consistent with sharp

force trauma.

After the homicide, the MS-13 members burned the clothes they had worn during the

murder. A co-defendant destroyed the victim’s cellular telephone and the knife and gloves that

the gang members used during the murder.

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2. Murder of Wilson Villeda

Less than six months later, Mr. Bonilla-Mejia committed another homicide. This time,

the victim was Wilson Villeda, a 17 year-old high school student. Mr. Villeda spent time with

members of the Columbus clique and may have been interested in joining the gang. However,

the co-conspirators had other ideas. They questioned Mr. Villeda’s allegiance to MS-13 because

of his tattoos, which they believed signaled an affiliation with a rival gang. Ultimately, they

sought and received authorization from MS-13 leadership in El Salvador to kill the victim.

The co-conspirators put their plan into action on the evening of November 14, 2015.

That night, Mr. Bonilla-Mejia and more than a dozen other MS-13 members and associates –

several of whom traveled to Ohio from other states specifically to participate in this homicide –

waited at and around 3350 Anita Street. Mr. Aguilar-Rivera brought Mr. Villeda to this

residence and, like Mr. Serrano-Ramos before him, the victim was taken into the woods of Innis

Park and slaughtered. During the horrific attack, the gang members took turns stabbing,

slashing, and cutting Mr. Villeda with a machete and other bladed weapons. Mr. Bonilla-Mejia

took photographs of the victim’s mutilated body on his cell phone and sent those pictures to

other MS-13 members in California with a message that said, “I got a little crazy with the

homies.” The co-conspirators buried the victim’s body in a shallow grave near where

Mr. Serrano-Ramos was buried. Medical reports describe between 70 and 92 chop-like injuries

to Mr. Villeda’s head, torso, and extremities.

The day after this homicide, the MS-13 members gathered to burn Mr. Villeda’s clothing.

The weapons that the group used during the murder were grounded down, and the remaining

pieces were disposed of in another state.

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3. Murder of Salvador Martinez-Diaz (a/k/a Rabanito)

MS-13 members began planning the murder of Salvador Martinez-Diaz (a/k/a Rabanito)

in 2015. Mr. Martinez-Diaz demonstrated his allegiance to the 18th Street gang, MS-13’s chief

rival, with a large tattoo of the numerals “X,” “V,” and “3” on his back. That tattoo sealed his

fate. For over a year, Mr. Bonilla-Mejia and his co-conspirators prepared to kill their victim.

They conducted surveillance of Mr. Martinez at his home, his place of employment, and the field

on which he played soccer. Mr. Bonilla-Mejia used a female associate to communicate with

Mr. Martinez-Diaz on Facebook and pretend to have a romantic interest in him, all in furtherance

of the scheme to murder him. In one instance, the gang attempted to lure Mr. Martinez-Diaz to

3350 Anita Street, where Mr. Bonilla-Mejia and several other MS-13 members and associates

were waiting to kill him. The co-conspirators put large sheets of plastic on the walls and floors

of the trailer to catch the victim’s blood and had their bladed weapons at the ready, but their

target was spared because he failed to show up at the ambush.

Before the MS-13 members could finally execute their plot to kill Mr. Martinez-Diaz,

law enforcement officers arrested Mr. Bonilla-Mejia in Akron, Ohio, in connection with an

outstanding warrant issued in California. Shortly thereafter, the defendant was transported to

California and detained in the Santa Barbara County Jail.

Mr. Bonilla-Mejia’s co-conspirators were undeterred. On the evening of December 3,

2016, Mr. Aguilar-Rivera explained the clique’s plan to kill Mr. Martinez-Diaz after the victim

finished playing soccer at the Resolute Athletic Complex in Columbus, Ohio. Eight MS-13

members took part in the operation, with Isaias Alvarado (a/k/a Cabo) and Jose Mendez-Peraza

(a/k/a Shadow) firing the hail of bullets that killed Mr. Martinez-Diaz. The coroner’s report

describes gunshot wounds to the victim’s face, chest, abdomen, back, both arms, and both

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shoulders. The fatal bullet entered the victim’s chest and struck his left lung, pulmonary artery,

and heart.

B. The History and Characteristics of the Defendant

1. Other Gang-Related Conduct

The nature of Mr. Bonilla-Mejia’s connection to MS-13 and the length of time he spent in

the Southern District of Ohio distinguish him from the other defendants in this case. Unlike his

co-defendants, Mr. Bonilla-Mejia has no obvious ties to Ohio, and he is not a formal member of

the Columbus clique of MS-13. Instead, Mr. Bonilla-Mejia is a member of the Santa Maria Lil

Salvi (SMLS) clique of MS-13, which is based in Santa Maria, California, the city in which he

has spent much of his adult life. The defendant came to Ohio in June 2015 and immediately

associated with the Columbus clique of MS-13. In fact, he participated in the murder of Carlos

Serrano-Ramos less than a month after arriving in this district.

Mr. Bonilla-Mejia’s criminal conduct in California is much more than a footnote to this

case. He is one of 12 defendants charged in People of the State of California v. Orellana, et al.,

Case No. 1501755, Santa Barbara County Superior Court (Santa Maria Division), an indictment

that focuses on the criminal activities of the Santa Maria clique of MS-13. In that prosecution,

the State of California has charged Mr. Bonilla-Mejia with ten counts of first-degree murder and

ten counts of conspiracy to commit murder for conduct that occurred between January 2013 and

February 2016. The California case provides a fuller picture of Mr. Bonilla-Mejia’s gang-related

activities in the United States. Both the government and the defense carefully considered the

nature and strength of the evidence supporting the state murder and conspiracy charges in

negotiating a plea agreement in the instant case. The agreement that the parties reached is

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intended to be a global resolution of the charges in this case and the Orellana case, respectively.1

2. Personal Background

As is true of every other defendant in this case, Mr. Bonilla-Mejia’s personal background

is a mitigating factor. The defendant was born and raised in El Salvador. Like his co-

conspirators, his childhood was marred by extreme poverty, malnutrition, lack of formal

educational opportunities, and inadequate access to health care. As a young child, Mr. Bonilla-

Mejia was abused by his alcoholic father. Outside of his home, the defendant was confronted

with the harsh realities of a county besieged by violence and gang activity. At the age of 13, he

joined MS-13.

In 2007, immigration officials arrested and promptly removed Mr. Bonilla-Mejia after he

entered the United States illegally. A year later, he reentered the United States illegally and

settled in Santa Maria, California. After returning to El Salvador in 2011, the defendant came

back to the United States in 2014 and moved to Columbus in 2015. Mr. Bonilla-Mejia’s partner

and their three children, one of whom is severely disabled, live in El Salvador. During his time

in the United States, the defendant has worked in agricultural and construction jobs. He has also

regularly used marijuana. The defendant experiences some lingering effects of a gunshot wound

he sustained in 2010. A report submitted by Dr. Antolin Llorente, the defense’s retained

neuropsychologist, indicates that Mr. Bonilla-Mejia suffers from cognitive and intellectual

impairments that were likely caused by various environmental factors in El Salvador. The

instant offense is the defendant’s first criminal conviction of any kind.

Like all criminal prosecutions, this case requires the Court to balance the nature and

1
Pursuant to the plea agreement, the parties anticipate that the Santa Barbara County District Attorney’s Office will
seek to dismiss the charges pending against Mr. Bonilla-Mejia in the Orellana case after the Court enters final
judgment in this case.

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circumstances of Mr. Bonilla-Mejia’s offense with his history and characteristics to determine an

appropriate sentence. In this matter, weighing the defendant’s conduct – being an active member

of MS-13, having a leadership position in the organization, and committing multiple homicides

on behalf of the enterprise – against his personal background demonstrates that a sentence of life

imprisonment is warranted.

C. The Statutory Purposes of Sentencing

A sentence of life without the possibility of release would serve the statutory purposes of

sentencing. Congress has determined that the mandatory penalty for this type of crime is life

imprisonment (or death). Such a sentence would reflect the nature and seriousness of

Mr. Bonilla’s offense and would be just punishment for his role in the charged racketeering

conspiracy – a role that includes him being legally responsible for three homicides.

Requiring the defendant to spend the rest of his life in federal prison could also be a

powerful deterrent. Dismantling MS-13 is one of the Department of Justice’s highest priorities,

and the resolution of this case should send a message that anyone who commits violent crimes on

behalf of this dangerous organization will be arrested, prosecuted, and held accountable.

Protection of the public from future harm is of paramount importance in this case.

During his roughly eight months in the Southern District of Ohio, Mr. Bonilla-Mejia committed

two gruesome murders and conspired to kill a third victim. The State of California alleges that

the defendant is responsible for ten additional murders in Santa Barbara County. In the absence

of law enforcement intervention and lengthy confinement, it is reasonable to believe that

Mr. Bonilla-Mejia’s fierce loyalty to MS-13 and its mission would lead him to continue to

eliminate anyone perceived to be an enemy of the enterprise. Simply stated, anything short of a

life sentence would put the public at an unacceptable risk.

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Finally, in the unlikely event that the defendant is ever released from prison, a five-year

term of supervised release would allow the Court to monitor his future compliance with the law,

including his obligation not to reenter the United States illegally

D. The Kinds of Sentences Available and the Sentencing Range

In light of the charges to which Mr. Bonilla-Mejia pled guilty, there can be only one

sentence in this case. For Count One, the maximum penalty is life imprisonment. See 18 U.S.C.

§ 1963(a). But for Counts Two and Three, the mandatory statutory penalty is life imprisonment.

See 18 U.S.C. § 1959(a)(1). Though it is largely academic, the PSR accurately sets forth an

advisory Guidelines range of life imprisonment, which is within Zone D of the Sentencing Table.

Under U.S.S.G. § 5C1.1(f), a term of incarceration is required. The government and the

Probation Officer agree that a sentence of life imprisonment is required in this case.

The United States concurs with the Probation Officer that a five-year term of supervised

release should be imposed. Such a sentence would be consistent with both the statute of

conviction and the Guidelines. See 18 U.S.C. § 3583(b)(1) and U.S.S.G. § 5D1.2(a)(1). The

government concedes that a term of supervised release ordinarily should not be imposed in a

case in which “supervised release is not required by statute and the defendant is a deportable

alien who likely will be deported after imprisonment.” U.S.S.G. § 5D1.1(c). However, the

Guidelines further counsel that a district court should consider imposing a term of supervised

release in such a case “if the court determines it would provide an added measure of deterrence

and protection based on the facts and circumstances of a particular case.” U.S.S.G. § 5D1.1,

App. Note 5; see United States v. Solano-Rosales, 781 F.3d 345, 353-354 (6th Cir. 2015) (“[T]he

district court’s explanation should directly address [U.S.S.G. § 5D1.1(c)’s] recommendation

against supervised release and provide the court’s reasoning for taking a different course of

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action in the case before it.”); United States v. Saucedo, 2018 U.S. App. LEXIS 1875, at *7 (6th

Cir. Jan. 24, 2018) (requiring district court to “acknowledge § 5D1.1’s recommendation against

supervised release” and “explain why deviating from the recommendation is appropriate in the

defendant’s case”).

In this case, a number of factors – including Mr. Bonilla-Mejia’s membership in a violent

criminal enterprise, his eagerness to assist and promote MS-13 by committing homicides, and his

unlawful presence in the United States – indicate that a term of supervised release of five years

would promote the goals of deterrence and protection of the public and would help the Court

monitor the defendant’s compliance with the law. It is telling that all of the criminal activity

with which Mr. Bonilla-Mejia is charged in the Second Superseding Indictment (as well as in the

Orellana indictment) occurred after the defendant illegally reentered the United States following

his removal in 2007. Should Mr. Bonilla-Mejia ever be released from prison and deported, and

then return to this county, every effort should be made to ensure that he is arrested and punished

accordingly.

The Probation Officer recommends that no fine be imposed in light of the defendant’s

financial situation and immigration status. See U.S.S.G. § 5E1.2(e). The United States does not

object to this recommendation.

E. The Sentencing Guidelines Policy Statements

The Probation Officer identified three policy statements that could support an upward

departure in this case: U.S.S.G. §§ 5K2.1 (death(s) resulted from the offense), 5K2.3 (victim(s)

suffered extreme psychological injury), and 5K2.8 (defendant’s conduct was unusually heinous,

cruel, brutal, or degrading to the victim(s)). The government agrees that, in light of the nature of

the homicides that Mr. Bonilla-Mejia committed, all three policy statements are applicable.

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There are no additional policy statements that the government wishes to highlight in this case.

F. The Need to Avoid Unwarranted Sentencing Disparities

A sentence of life imprisonment without the possibility of release is mandatory in this

case. See 18 U.S.C. § 1959(a)(1). The imposition of anything less than a term of life would

result in unwarranted sentencing disparities with other defendants who are convicted of murder

in aid of racketeering. A life sentence would also be consistent with the advisory Guidelines

range and appropriate given the facts and circumstances of this offense.

Of the co-defendants who have been sentenced thus far in this case, Mr. Bonilla-Mejia is

most similarly situated to Mr. Aguilar-Rivera. The latter, the unquestioned leader of MS-13 in

Columbus, admitted to his role in five homicides and was sentenced to life imprisonment.

Mr. Bonilla-Mejia is a violent, committed MS-13 member who held a leadership position in the

organization and participated in three homicides during his relatively short time in this district.

The defendant’s egregious conduct in this case, coupled with the murder charges in California

that will be dismissed as part of this global resolution, place him on par with Mr. Aguilar-Rivera

and support a life sentence.2

G. The Need to Provide Restitution

In light of the nature of Mr. Bonilla-Mejia’s offense, an order of restitution is mandatory.

See 18 U.S.C. § 3663A. As detailed in the PSR, the Court should order the defendant to pay

$1,653.03 jointly and severally with his co-defendants.

The United States has consulted with some of the relatives of Mr. Bonilla-Mejia’s

2
Two other defendants who pled guilty to murder have been sentenced in this case. Jose Manuel Romero-Parada
(a/k/a Russo), a young but criminally prolific MS-13 member, admitted to his role in three gruesome homicides and
was sentenced to 480 months of imprisonment. Juan Jose Jimenez-Montufar (a/k/a Chele Trece), a long-serving
member of MS-13 who committed multiple homicides in this district, including the execution of an informant, was
sentenced to 420 months of imprisonment.

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victims. At the time of sentencing, representatives of one or more of the families may wish to

address the Court and further discuss the impact of the defendant’s crimes. If so, the government

will endeavor to inform the Court prior to the hearing.3

CONCLUSION

For the foregoing reasons, the United States submits that the mandatory sentence of life

imprisonment, along with five years of supervised release and the payment of $1,653.03, is

sufficient, but not greater than necessary, to satisfy the goals of sentencing. Accordingly, the

United States respectfully requests that the Court adopt the recommendation set forth in this

memorandum and the PSR as reasonable and appropriate in this case.

Respectfully submitted,

DAVID M. DEVILLERS
United States Attorney

s/ Brian J. Martinez
BRIAN J. MARTINEZ (CA 224587)
NOAH R. LITTON (0090479)
Assistant United States Attorneys
303 Marconi Boulevard, Suite 200
Columbus, Ohio 43215
Office: (614) 469-5715
E-mail: Brian.Martinez2@usdoj.gov

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Sentencing Memorandum was served this

18th day of February 2020, electronically upon all counsel of record in this case.

s/ Brian J. Martinez
BRIAN J. MARTINEZ (CA 224587)
Assistant United States Attorney

3
The government intends to submit two victim impact letters in advance of the sentencing hearing.

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