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Case 1:19-cr-20148-TLL-PTM ECF No. 10 filed 03/26/19 PageID.

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United States of America, No. l9-CR-20148

Judge Thomas L. Ludington
Plaintiff, Magistrate Judge Patricia T. Morris

Offenses: Count 1, wire fraud, 18 USC

Robert i. Reznick, $ 1343; Count 2, false tax retum, 26
u.s.c. $7206(1)
Defendant Penalties: Count 1: 20 years custody.
Count 2: 3 years custody, costs of
prosecution, restitution. $250,000 fine
per count, supervised release, special
assessment, forfeiture.

Rule 1l Plea Agreement

Pursuant to Rule l1 of the Federal Rules of Criminal Procedure, defendant

Robert J. Reznick and the govemment agree as follows:

1. Guilty Pleas

A. Counts of Conviction

Defendant will waive indictment and plea guilty to counts I and 2 of an

information charging him with wire fraud in violation of l8 U.S.C. $ 1343 and

filing a false federal income tax return in violation of 26 U.S.C. 97206(1)

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B. Elements of Offenses

The elements ofthe offense charged in count 1 are that defendant (1)

knowingly developed a fraudulent scheme to obtain money; (2) in furtherance of

that scheme, he intentionally made materially false representations to suppliers of

firearms and ammunition; and (3) he made the false representations through

interstate wire communicatlons.

The elements ofthe offense charged in count 2 are that (1) having caused

another to prepare his federal income tax return, defendant willfully signed that

income tax retum subject to the penalties for perjury; (2) the tax retum contahed

materially false information regarding defendant's incomc; and (3) the defendant

did not believe that the reported income on his tax retum was true and correct.

C. Factual Basis lbr Guilty Pleas

The following stipulated facts are a sulficient and accurate basis for

defendant's guilty pleas:

During all times relevant to the charges in this case, Robert J. Reznick was

employed as a police chief, private security services provider, and process server

through his solely-owned business known as Due Process of Michigan. Reznick

became the Chief ol Police for the Viltage of Oakley, located in Saginaw County,

Michigan, in 2009, and was paid between 51,200 to $6,000 per year.

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Though the population of the Village of Oakley was around 300 people,

Reznick recruited and maintained a roster of approximately 120 reserve officers for

the Oakley Police Department, most of whom were affluent professionals or

otherwise prominent individuals who lived and worked in locations somewhat

distant from Oakley. Members of the Oakley reserye officer group were required

to pay at least $ 1 ,000 to the Village of Oakley to join the reserves, and buy their

own firearms, uniforms and other equipment. Reznick told, but did not require,

members to attend formal training or perform any duties to stay in good standing

as reserve off1cers. However, Reznick provided badges and police identity cards,

and instructions on how to obtain an enhanced CPL (a law enforcement

endorsement on licenses to carry concealed firearms), to all reserve officers.

The Oakley reserve officers became Reznick's ready and primary customers

for firearms, ammunition, police badges, uniforms, and tactical gear. Reznick

purchased hrearms, ammunition, and other equipment from suppliers located both

in and outside of Michigan, fraudulently using his position as police chief to obtai
,l'l' ; l"-ls".ly se7rcso.,*i n., tf.o-F he wi,: v,, c.lo-,- 1 iAc p.,rr.r^7,g*; h.r pcr
reduced prices'[rom the suRRliertf,vhile intending to selfprimaiily the firearms, 'sr
ammunition and flirearm-related items for his personal profit. He placed orders
with his out-of-state suppliers by using interstate wire communications, including

telephonic, faxed and emailed communications. Reznick made most of his profit

from the sale of ammunition, but was also able to make a significant profit on

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frrearm sales that involved high-end firearms such as assault weapons and firearms

customized with an Oakley Police Department badge. Reznick also used his

position as police chiefto facilitate the sale ofassault shotguns with the capacity to

hold 16 rounds from an out-of-state vendor for some of his customers and thereby

enabled the purchasers ofthose shotguns to evade the federal and state taxes on the

transactions. As a result ofhis fiaudulent activities, Reznick obtained more than

$10,000 per year in unreported, criminally derived income and an aggregate gain

from fraud ofmore than $40,000 but less than 595,000

Though he had filed timely personal federal income tax retums previously,

Robert Reznick did not file personal income tax retums for 20 t 0 through 20 I 3

when the returns were due, despite having income from his sales of ammunition,

firearms and other items, and from his lawful employment in various capacities.

Similarly, though Reznick had filed Form I 120 retums fbr Due Process of

Michigan through 201 1 , he stopped filing for that entity thereafter, even though he

should have filed Forms 1120 for2012,2013 and2014.

By 2015, Reznick was aware of the I'ederal investigation that gave rise to his

cunent charges. Also in 2015, Reznick arranged to have late personal tax returns

prepared for 2010 through 2013, and a timely personal return lor 2014' Reznick

deliberately did not disclose all of his income to the preparer ofthose personal tax

returns. Consequently, Reznick's personal tax rotums for 201 0 to 2014 contained

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materially false information regarding Reznick's total income from all sources lor

each of those years. Reznick willfully signed his Form 1040 tax retums lor 2010,

2011,2012,2013 and 2014 subject to the penalties for perjury, even rhough he was

fully aware of the fact that his income for each of those years was under-reported.

and filed the retums with the IRS. The criminal tax loss that resulted from Reznick

failing to report all ofhis personal income for 2010 to 2014 totals $87,702.86.

2. SentencingGuidelines

A. Standard ofProof

The court will hnd sentencing factors by a preponderance ofthe evidence

B. Agreed Guidelines Range

There are no sentencing guidelines disputes. Except as provided below, the

parties stipulate that the defendant's guidelines range is 12 to 18 months, as stated

in the attached guidelines worksheets. However, ifthe court finds that defendant's

criminal history category is higher than reflected on the attaohed worksheets, or

that the offense level should be higher because, after pleading guilty, defendant

made any false statement to or withheld information from his probation officer,

otherwise demonstrated a lack of acceptance of responsibility for his offense, or

obstructed justice or committed any new crime, and if any such finding results in a

guidelines range higher than the stipulated range of 12 to I 8 months, the higher

guidelines range will become the agreed guidelines range of the parties.

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Neither party may take a position concerning the applicable guidelines that

is different from the attached stipulated worksheets, except as necessary to the

court's determination regarding the guidelines factors specified above. A violation

of this provision of this plea agreement by either party will constitute a breach of
this plea agreement and will enable the other party to withdraw from this


3. Sentence

The court will impose a sentence pursuant to 18 U.S.C. $3553, and in doing

so must consider the sentencing guidelines range.

A. Imprisonment

Pursuant to Federal Rule of Criminal Procedure 11(c)(1)(C), the sentence of

imprisonment in this case may not be higher than the guidelines range as

determined by the court pursuant to this agreement.

B. Supervised Release

A term of supervised release ofup to 5 years may be imposed, to follow the

term of imprisonment. There is no agreement on the length of the supervised

release term. The custodial sentence agreement above does not limit any term of

imprisonment that results from revocation ofdefendant's supervised release.

C. Special Assessment

Defendant will pay a special assessment of$200.

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D. Fine

There is no agreement as to fines.

E. Restitution

Pursuant to the stipulation of the parties, the court shall order restitution to

the Intemal Revenue Service in the amount of $124,078.88. That is the total of the

criminal tax loss of $87,702.86 from Reznick's unreported personal income for

201 1 through 2014, and the criminal tax loss attributable to Due Process of
Michigan, totaling $36,37 6.02, for 2012 ttuough 20 I 4.

F. Costs of Prosecution

Defendant shall pay $4,553.77 to the United States as the costs of

prosecution pursuant to 26 U.S.C. $7206(1).

G. l'orfeiture

Defendant agrees to forfeit to the United States all interests he may have in

all fircarms, ammunition and explosives seized by United States.

4. Cooperation with the Internal Revenue Service

The delendant agrees to cooperate with the Internal Revenue Service in the

determination of the defendant's civil income tax liability for the tax years 2010 to

present. Cooperation is defined to include the following:

A. Defendant will file all income tax retums currently due or overdue

within 120 days of pleading guilty

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B. Defendant will sign and submit to the IRS a Form 870 at or before


C. Upon request of the IRS, defendant will participare truthfully and

completely in a face-to-face interview with a representative of the Intemal

Revenue Service Examination Division within 60 days after sentencing or at a later

time if set by the examining agent.

D. At the request of the IRS, defendant will provide source

documentation relevant to the retums at issue. Source documentation includes, but

is not limited to, hnancial account records including checks, books and records of
related businesses, substantiation for deductions and expenses claimed, and

investment records.

E. At sentencing, defendant will agree to a condition of supervised

release ordering him to pay all unpaid restitution and the costs ofprosecution

stated above.

5. Use of Withdrawn Guilty Plea(s)

lf the court allows defendant to withdraw either of his guilry pleas under

Rule 11(d)(2)(B), defendant waives his rights under Rule 410 of the Federal Rules

of Evidence and the govemment may use defendant's guilty plea, any statement

made under oath at the change-of-plea hearing, and the factual basis statement in

this plea agreement, against the defendant in any later proceeding.

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6. Other Charges

If the court accepts this ageement, the government will not bring additional

charges against defendant based on any of the conduct reflected in the attached

worksheets or the factual basis provided above. However, ifthe defendant

provides any false, misleading or incomplete information while complying with the

requirements ofparagraph 4, above, that conduct will be the basis for one or more

separate prosecutions for that conduct, at the discretion of the government.

7. Each Party's Right to Withdraw from This Agreement

The government may withdraw from this agreement if the court imposes a

sentence below the agreed guidelines range. Defendant may withdraw ffom this

agreement, and may withdraw his guilty pleas, if the court decides to impose a

sentence higher than the guidelines range determined by the court pursuant to this

plea agreement. That is the only reason for which defendant may withdraw from

this agreement. The court shall advise defendant that ifhe does not withdraw his

gurlty pleas under this circumstance, the court may impose a sentence that is higher

than the maximum allowed by this agreement.

8. Appeal Waiver

The government retains the right to appeal if the court imposes a sentence of
less than l2 months.

-9 -
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Defendant waives any right to appeal his convictions. If the sentences

imposed by the court do not exceed the guidelines range determined pursuant to

this plea agreement, defendant waives his right to appeal his sentences on any

ground. This appeal waiver does not bar defendant from filing a claim of
ineffective assistance of counsel in court except as stated below.

9. Collateral Consequences of Convictions

Defendant understands that his convictions in this case may carry additional

consequences under federal and state 1aw, including the potential loss ofthe right

to vote, right to serve on a jury, and ability to hold certain licenses or work in

certain fields. Ifany collateral consequences result from either ofthe defendant's

convictions in this case, that circumstance will not be a ground on which the

defendant may seek to invalidate his convictions or to claim ineffective assistance

of counsel in this matter.

Defendant further understands that, if he is not a native-born citizen of the

United States, there may be adverse immigration consequences resulting from his

convictions. These consequences include possible removal from the United States,

denial of citizenship, denaturalization, denied admission to the United States in the

future, and other possible consequences.

Defendant understands that no one, including the defendant's attorney or the

court, can predict with certainty the effect of defendant's convictions on any of

Case 1:19-cr-20148-TLL-PTM ECF No. 10 filed 03/26/19 PageID.27 Page 11 of 18

these matters. Defendant nevertheless affrrms that he chooses to plead guilty

regardless ofany immigration consequences or other collateral consequences of his


10. Consequences of Withdrawal of Guilty Pleas or Vacation of Convictions

If defendant is allowed to withdraw his either of his guilty pleas, or if either

of the convictions entered pursuant to this agreement are vacated or set-aside for

any reason, the court shall, on the govemment's request, al'low the government to

reinstate the charges in the information and/or seek and obtain an indictment

containing felony charges arising under Tile 26 and Title 18, including the charges

in the information and./or other offenses that were not filed because of the

defendant's agreement to plead guilty to the current information. If any such

charges are filed against defendant within six months after the date of the order

vacating or setting aside defendant's conviction(s) or allowing him to withdraw his

guilty plea(s) becomes final, defendant waives his right to challenge the charges on

the ground that they were not filed in a timely manner, including any claim that

they were filed after the limitations period expired.

I l. Acknowledgment

Defendant understands that, upon entry ofhis guilty pleas, it will be illegal

for him to possess or receive a firearm or ammunition in or effecting interstate


- 11-
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12. Parties to Plea Agreement

Unless otherwise indicated, this agreement does not bind any govemment

agency except the U. S. Attorney's Office for the Eastem District of Michigan.

I 3. Scope of Plea Agreement

This agreement is the complete agreement between the parties. This

agreement supersedes al1 other promises, representations, understandings and

agreements between the parties concerning the subject matter of this plea

agreement that were made at any time before the guilty plea is entered in court. No

oral or written promises made by the government to defendant or to the attorney

for the defendant at any time before defendant pleads guilty are binding except to

the extent they have been explicitly incorporated into this agreement.

Notwithstanding the previous paragraph, ifdefendant has entered into a

written proffer agreement or a written cooperation agreement with the government,

this plea agreement does not supersede or abrogate the prior written agreement.

This agreement does not prevent any civil or administrative actions against

defendant, or any forfeiture claim against any property, by the United States or any

third party.

14- Acceptance ofAgreement by Defendant

This plea offer expires unless it has been received, fully signed, in the Bay

City Office of the United States Attorney by 5:00 p.M. on March 15, 2019. The

Case 1:19-cr-20148-TLL-PTM ECF No. 10 filed 03/26/19 PageID.29 Page 13 of 18

govcnrnlcnl r!-srrvcs thc riEht to [xxlily or rcvokc lhis ofl'cr al ony timc before

dr'lctrrlrtnl plulds prriltv

i\ l: rlt h Schttcitlcr
, .,\lkr r
J\ n( JI J Parker
Assisrnnl U.S. istanl U.S. Attomey
Chicf. R f iccs
G rz.-
Chrislopher Rawsthorne I

Assistanr U.S. Atrom€y I

By ing below, defcndant acknow ledges that he has rcad (or bccn read)

this entirc document, he understands it, and he agrees to irs lerms. He abo

acknowledges that he is salislied with his anorncy's advicc, assisrance ud

rcpFcsentalion. Defen&nt agrccs that he has had a full and completc opportunity

to confcr with his lawyer, and has had all of his qucstioos answcred to his

satisfaclion by his lawyer.

J Robert J.
r Defendanl Defendant

o^t",t|ev4 ll .zots

- t3 -

Case 1:19-cr-20148-TLL-PTM ECF No. 10 filed 03/26/19 PageID.30 Page 14 of 18

Delenda nt
Robert Reznick
District/Offrce IJastern District of N{ichisan
Docket Number 1$CR-20148

Count Nurnber(s) 1 2 U.S. Code Title & Secrion 18 . 1343 26 .72m(1)

Guidelines Manunl Eilition Llsed: 20lq (Note;The worksheeh ore keyed to the Novembe. 1.2o16 Guidelines Monuot)

Complete a separate Worksheet A for each count of conyiction or as !€quir€d in a situation listed at the bottom of Worksheet B-1
Etception-s: Use only a single Worksheet A where the ofrense lerrl for a group of closely rclated counts is based primarily on
aBgregate value or quantity (see S3D1.2(d)) or where a count of conE iracy, solicitstion, or attaEpt is gouped wirh a substantive
court that was the sole object of the conspiracy, solicitation, or atrpmpt (8ee $3D1.2(a) & (b)).

l. Otfense level r
Enter the applicable base offense level and any specific offense characteristics from Chapter Tw-o and explain the
bases for these determinations. Enter the sum in the box provided-

Guideline Desc plion Level

2r1 1t2I41lE) filing false tax return. >$40,000 to $100,000 tax toss
2r1.1(b)(1) unreported income >$10,000 from criminal actlvity
'2 .._
[281.1(a)] wire fraud I7l .,_
t2B1 1(bX1XD)l

>$40,000 to 995,000 gain/toss
misrepresentation that detund-ant was acting on behalf of a government agency
J-21 - _
If the Chapter Two guideline requires applicatiou of a cross reference or other at
reference, an additional Worksheet A may be needed for that analysis. See $181.5. Surr) |

tr. Vlctim-Reloled Adjuslmenls {See Chopier Three, Port A}

Enter the applicable section and adjustment. If more than ore section is applicable,
list each section and enter the combined adjustment. If no adjustment is applicable, 281 1 n 8lEXr)
enter "0". $
3, {See Chqpler Three, Port B)
Enter the applicable section and adjustment. If more than one section is applicable,
list each sec'tion and enter the combined adjustment. If the adjustment reduces the
offense level, enter a minus (-) sign in front of the adjustment. If no adjustment is 3_ 0
applicable, enter "0".

Enter the applicable section and adjustment- If mqre than one sectio[ is applicable,
list each section and enter the combi-oed adjustment. If no adjustment is applicable, s U
enter "0".

Enter the sum of Items 1-4. If this Worksheet A iloes not cover all counts of conviction or situations
listed at the bottom of Worksheet B, complete Worksheet B- Otherwise, enter this result on to
Worksheet D, Item 1.

V Check here ifall counts (incluclizg situations listed at the bottom of Worksheet B)* are addressed on this one
Worksheet A. If so, no Worksheet B is used.

a Ifthe defendant has no criminal history, enter "I" here and

on Worksheet D, Item 4. No Worksheet C is used,

Se.ienclng Commission Wo*sheets (November l, 2016l

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[Poge 1 of 4]
Defendant Robert Reznick Docket Number 19CR-20148

l. Adjusled Offense tevel Bl

If \\-orkshect B rs r-e,]uir-r,rl. errte: the lcsult fi'r,rn Wo[kshtet l]. Itenl 9. Other'\vis,,. (r11tet ( he r'(,sult
frorn Wolksheel A. ltcm i. _16_
2. Acceptonce ol Responsibillly (See Chopter Three, Port E)
Enter t hr' ,r1tplrtrrrblc lrrluction of 2 or 3 ler.els. If no a(ljustulenL rs aplrliclble. r,nter' '0 .

3, Otfeme Level Iolol (llem I less ltem 2)


Eoter the rcsult flnm Worksheet C, Ircm 8, unlc,ss t,he tlrfendant has no criminal history, antl as
dilccrerl at rhe Dottonr of \\'ork"-het't -{, no \Yorksheet (l is uscd and "l'' is t'ntcled here. I

5. Terrorism; Coreer Offender; Criminol [ivelihood; Armed Coreer Criminol; Repeot ond Dongerou:
Sex Oflender (See Chopter Three, Port A, ond Chopter Four, Porl B)
o. Ofrense levellolol
If the provision for Career Ofrender (S4B1.1), Criminal Livelihood ($481.3), Armed Career
Criminal (S4Bf.4), or Repeat and Dangerous Sex Offender ($481.5) results in an offense level toLal rla
higher than Item 3, enter the offense level total- Otherwise, enter "i\'/A'. -
b. crlminol Hi3lory Cotegory
Ifthe provision for Terrorism ($3AI.4), Career Offender (S481- l), Armed Career Criminal ($481.4),
or Repeat and Dangerous Sex Offender ($481.5) results in a criminal history category higher than
Item 4, enter the applicable criminal history category. Otherwise, enter "N/A".

!lntel the applitrblc guidolinr, rangc from Chaptel Five. Prlt -\. in rnonths-
12 to 18

Ii the statutolily authorizecl maximum sentcnce or the statutorily lcquircrl

minimum s(,ntence !cstricts the gurdeline range (Irem 6) (see $55G1,1 and 5(]1.2), nla lo
enler cither thc restlicted gurrlelinc range or any stal,utory- maximurn or' ruinimr-tnr
penaltl- that rvould modifr lhe guklelinc !'aogc. OlheINise. enter' "N/-\".

tr Check here if $5C1.2 (Limitation on Applicability ofStatutory IMinimum Penalties in Certain Cases) and
18 U.S-C. S 3553(e) - "The Safety Valve" - are applicable.

Undis€horged Term of Imprisonmenl; Anticlpoted Slote Term of lmprisonment (see S5Gl .3)

f If thedefendant is subject io ar undischarged term of imprisonment, or an aniicipated state term of

imprisonment, check this box. Below list the undischargerVanticipated term(s), the applicable section of
$5Gl-3 and its direction or guidance as to whether the instant federal sentence is to be imposed to run
concurrently or consecutively to the undiechar6ed/anticipated term(s), and any sentence adjustment.

U,S. Senlencing Commission Worksheels (Novembe( l, 2016)

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Worksheet D Delermining the Sentence [poge 2 of

Defendant Robert Reznick
- Docket Numbor 19CR-20148

9. Senlenclng oplions (See Chopter Five, Sentencing Tobte ond SSSB t.t (o) ondSCt.l)
Check the applicable box that corre.-ponds to thc Cuidt'line Range entered in Item 6 or Item 7, if applicable

Zone A {See 5S58l,l {o )ir) & 5cr.r (o) & {b))

tr Ifchecked, the following options are available:

. Fine (See gg50l.10) & 5EI.2(a))
. "Straisht" Probation (See ggEB1.l(a)(r) & sct.r(b)
. Imprisonment (See 95C1.1(a) & (c)(1))

Zone B (See gg58l.l (o)12) & 5cl.l (o) & (c))

tr Ifchecked, the nininrum ternl ma! be satisfied. by:

. Imprisonment (See gECr.r(a) & (c)(2))

' Imprisonment' of at leaat one month plus eupentised release with a condition that
substituteo co!]Eunity confinement or home detention for imprisonment
(See 55Cr.1(cXz))

' Probation with a condition that substitutes intermittent confinement, community

confinement,or home detention for imprisonment (See ggEB l. I (aXZ) and SC 1.1(cXB))

Zone C lsee 05C | .l (o) & {d})

/ If checked, the minimu terrn rnay be sotisfied. by

Imprisonment (See 95C1.1(a) & (d)(1))

Imprisonment of ot least one-hclf of the minimum term plus supervised. releo;se

with a condition that substitutes community confinement or home detention for
imprisonment (See g5C 1. t(d)(2))

r Zone D (See g5C 1.1 {o) & (f))

Ifchecked, the mininum tenn is to be satislied by a sentence ofimprisonment

tength of Term ot Probolion (See SSB I .2)

tr At least one year, but not mor€ than 6ve years ifthe offense level total is 6 or greater

No more than three years ifthe offense level total is b or less

U.S. Senrencing Commission Worksheets (November t, 20l6i

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Worksheet D Determining lhe Sentence [Poge 3 of a]

Defenrlant Robert Reznick
- Docket Number 19-CR-20148

I I. Supervlsed Releose (See g05Dl.i ond SDLA

o. lmposllion ot o Term of Superyised Releose:

tr Ordered because required by statute (See 55D 1.1(a)(1))

m Qrdered because a sentence of imprisonment of more than one year is imposed (.See $5Df.l(aX2))-

T Is zot ordered although a sentence of more than one year is imposed, because it is not required by
statute ond the defendant Iikety will be deported after imprisonment (See $ 5D1.1(c)).

Ordered because it may be ordered in any other case (See $5D 1,1(b)).

b. Lenglh of Term ol Supervised Releose

Check the Class ofthe Offense.

V Class A or B Felony: TVo to Fiye Year Term (&e gsD t.2(ax1))

tr Class C or D Felony: One to Three Year Term (See g5Dl.2(a)(2))

T Class E Felony or Class A Misdemeanor: One Year Term (See 95D1.2(aXS))

Ifa statutorily required mandatory minimum term ofsupervised release for the offense impacts the
guideline range for the applicable Class of Offense above, also check this box, and list the statutory
minimum teror (See $5D 1.2(c)):
years mandatory minimum term of supervised release

- ollenee in
Ifan 18 U.S.C. $ 2332b(gX5)(B) that resulted in, or created a foreseeable risk of, death or
serious bodily injury to another person; or if a sex offense, the term of supervised release will not be
less than the minimum term established above, and may be up to life (See $EDI,Z(b)).
Policy Statement: Ifa sex offense, the statutor! moxirnu lerm ofsupervised release is recommended-

I l. Eeslilution
a, If restitution is applicable, enter the amount. Otherwise enter,.N/A,' and the reason:
$124,078.88 restitution based on tax loss + costs of costs of prosecution of $4,553,77

b. Enter whether restitution is statutorily mandatory or diseretionary

by stipulation of the parties

c- Enter whether restitution is ty

an order of restitutio n, or solellt as a condition of supervision. Enter the
authorizing statute:
by order as to restitution; costs of prosecution per statute for tax charge

U.5. Sentencing Co.nmission Worksheeis (November t. 20I5l

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Worksheet D Determining the Senlence [Poge 4 of 4]

Defendant Robert Reznlck
- Docket Number 19CR-20148

1 3. f ines (The Guideline Ronge lor Flnes for lndividuol Defendonts) (See SSE I .2)
q. Speciql Fine Provisions Minimum Moximum
Check box if any ofthe counLs ofconviction is for a statute with
a special frne provision. (This do"s rot include the general fine
provisions of 18 USC $ 35?1(b)(2) & (d).
Enter the sum of statutory maximum fines for all such counts. $

b. rine Toble (S5El.2(cX3))


Enter the minrmum and maximum fines $ s5,ooo

c Fine Guidellne Ronge

(Determined by the minimum of the Fine Table (Item 15O)) and the
greater maximum above (Item fs(a) or 15(t))). ls,@l $ 55,000

d. Ability to Poy

T Check this box ifthe defendant does not have an ability to pay.

14. Speciol Assessments for lndividuol Delendonls {See S5El .3)

llntcr i hc tolal arnort nt oi l Le statu tory SpeCial assessments rt:quired for a I ccunts ol convrct ion
. S100 for iach fi.lo l count ofcolrviction.
. Sl5 for- each ('lass -{ rnrsderneanol counL olconvicl.ion.
. \\hi tr' not su bli:ct to guideline sc n1 encing, the sp r:r ia I a ssc:ssrne nts lbr a []lass I ] misde rnci:r ror.
anrl l Class (' rnisdern,:tinor ol intraction at.c S10 ancl S5 per.couDt, r'cslle.ttv,i.l\.
IOIAI,: $200
15. Foclors Thot Moy Woront o Depr:rlwe (See S lB l.l (b))
Consider Chaptel Five, 1)art H (Spccific Otfc,ndel Characte.-isLrcs) ancl Part I{ (l)eparLurc's), and other.policy
statements and commentary tn lhc Guilcl.ines Llonual thaL might warrant consider.ation rn sentencing-
(See also the "l,ist. of lJepa l r u ro Provisions" inr:lu ded in the G u Lcle tites !.tal rr(l aile r the Inclox) -

16. foclors Thot Moy Worront o Varionce (See g lBt_l ic)) '
(lonsider l.he applir:able fadors in lil t,'.S.C- {i :Jb53(a) l.;il(en as;t $,hole

Compleled by Rawsthorn€ & Parker , go1" Zt14t2O19

ll.S. Sentencing Comm6sion Workrhegts {November l, 20t6)