Contract analysis

I. Introduction and Purpose of Letter I am Conrad Ashby, a Partner in the White Collar & Investigations practice of Calderwood & Harkness LLP. I write on behalf of our client, Marguerite D. Fonseca, the defendant in the above-referenced matter. This firm was retained on November 12, 2025, to represent Ms. Fonseca in connection with her sentencing proceedings following her conviction at trial. We succeeded prior trial

II. Enclosed Materials Together with this letter, we are transmitting several categories of materials for the Probation Office's review and consideration. Each category is summarized below. A. Defendant's Objections to the Presentence Investigation Report The Defendant's formal written Objections to the Presentence Investigation Report were filed with the Court on January 10, 2026. A courtesy copy of the filed object

III. Defense Position on the Guidelines Calculation The PSR calculates Ms. Fonseca's Total Offense Level at 31, with a Criminal History Category of I, yielding an advisory Guidelines range of 108 to 135 months of imprisonment. The PSR's Guidelines calculation is set forth as follows: Base Offense Level (U.S.S.G. § 2B1.1): 7 Specific Offense Characteristic — Loss Enhancement (§ 2B1.1(b)(1)(J), based on a loss amount o

IV. Request for PSR Addendum Pursuant to the standard practice in the Central District of California, we respectfully request that the Probation Office prepare an addendum to the PSR addressing the defense's objections and the supplemental information submitted herewith. Specifically, we request that the addendum address the following matters: (1) The Probation Office's response to the defense's position on the loss

V. Request for Meeting We respectfully request a meeting at the Probation Office's earliest convenience to discuss the following matters: (1) Specific factual corrections to the PSR narrative identified in the Defendant's Objections and in the enclosed materials; (2) The defense's position on the Guidelines calculation, including the factual and legal basis for each of the defense's objections to the PSR's applicatio

VI. Forthcoming Submissions We wish to advise the Probation Office that the following additional materials will be submitted to both the Probation Office and the Court in advance of the March 6, 2026 sentencing hearing:

1. Expert report of Dr. Priya Chandrasekaran, Department of Economics, Westbridge University, regarding the correct calculation of actual and intended financial loss;

2. Expert report of Dr. Kenneth Whitmore, board-certified forensic psychiatrist, containing the results of his comprehensive forensic psychiatric evaluation of Ms. Fonseca;

3. Comprehensive mitigation report of Dr. Sandra Oleander, Ph.D., Lead Mitigation Specialist, Thornfield Mitigation Consulting LLC, containing the results of her social history investigation;

4. Character reference letters from industry colleagues, community members, and family members (more than 40 letters are anticipated);

5. Defendant's Sentencing Memorandum;

6. Defendant's Motion for Downward Variance pursuant to 18 U.S.C. § 3553(a); and

7. Proposed Judgment and Restitution Order. The defense anticipates filing the Defendant's Sentencing Memorandum and Motion for Downward Variance with the Court, and submitting copies to the Probation Office, on or about February 14, 2026. Expert reports, character reference letters, and the other materials listed above will be submitted as they are completed, and in all events sufficiently in advance of the sentenci

VII. Closing We sincerely appreciate your attention to these materials and the thoroughness and professionalism reflected in your preparation of the PSR in this complex matter. The defense looks forward to a productive dialogue with the Probation Office in the weeks ahead and to working cooperatively to ensure that the Court has a complete and accurate record upon which to base its sentencing determination. For sched

1. Defendant's Objections to the Presentence Investigation Report (filed January 10, 2026)

2. Summary Memorandum on Defense Loss Calculation Analysis

3. Preliminary Mitigation Materials (biographical overview, mental health summary, caregiving summary, community contributions summary) cc: Brenda K. Tillotson, Assistant United States Attorney, Major Frauds Section, United States Attorney's Office, Central District of California Derek R. Huang, Assistant United States Attorney, Major Frauds Section, United States Attorney's Office, Central District of California The