Fine Amount Calculations. i. Base fine. Pursuant to Guidelines §§ 8C2.3(a) and 8C2.4(b) and § 2C1.1(d)(1)(B), the base fine is the value of the benefit received in return for the payment. It is the government’s position that the value of the benefit received was at least approximately $2 million. Defendant reserves the right to argue that the value of the benefit received was less than $1,500,000.
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Sources: Plea Agreement, Plea Agreement