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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-80185-CR-MIDDLEBROOKS

UNITED STATES OF AMERICA )

)

v. )

)

ELIZABETH GENNA SUAREZ, )

f/k/a “Elizabeth Mirson Suit,” )

)

Defendant. )

______________________________ )

RESPONSE TO DEFENDANT’S SENTENCING MEMORANDUM,

REQUEST FOR DEPARTURE AND REPLY TO GOVERNMENT’S 

RESPONSE TO DEFENDANT’S OBJECTIONS

The United States files this limited response to the defendant’s filing at Docket Entry 57. 

The position of the United States has been largely established elsewhere, in its Notice of Objection 

to Presentence Investigation Report (DE 51), its Response in Opposition to Defendant’s Objections 

to Presentence Investigation Report (DE 52), and its Supplement to Notice of Objection to 

Presentence Investigation Report (DE 56). 

The United States files this limited response to refute the defendant’s claim that “the 

substance of the letters was not changed” (DE 57 at 2.) The Court has been presented with copies 

of the original letters by Greg Tabeek and Raymond Cameron, and a comparison to the versions

submitted by the defendant shows their substantive alteration. 

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Greg Tabeek’s original letter

(DE 51-1 at 10.)

Letter submitted by defendant

(DE 46-1 at 13.)

These letters differ materially. The defendant made several significant additions beyond 

changing her name and date:

• “thus being recognized so often for those leadership qualities”

• “Her kindness, selflessness, and priority to put her patient’s [sic] first was obvious to 

anyone who worked with her.”

• “I hope that any judgment placed on Mrs. Suarez takes this letter into serious consideration 

when doing so.” 

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Raymond Cameron’s original letter (2016) 

(DE 56-1 at 6.)

Letter submitted by defendant

The concluding paragraph of the letter submitted by the defendant differs in its entirety 

from the original letter written by Raymond Cameron. Of course, had the defendant not altered 

this paragraph, it would have laid bare her falsification of the date and her name, as the concluding 

paragraph in the original 2016 letter spoke of things that had long since come to fruition by 

February 2023. 

The United States maintains that the two-level enhancement under U.S.S.G. § 3C1.1 was 

properly applied by the U.S. Probation Office in its amended Presentence Investigation Report. 

The United States also submits that these letters demonstrate the need for a significant sentence to 

promote respect for the law and provide just punishment for the defendant. The United States is 

also concerned about protecting the public from further crimes of the defendant, as her continued 

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deception to the Court after the commission of the crimes, and the similar nature of her previous 

conviction, speak to her likelihood to recidivate. 

Respectfully submitted,

 

MARKENZY LAPOINTE

UNITED STATES ATTORNEY

By: /s/ Alexandra Chase

ALEXANDRA CHASE

ASSISTANT UNITED STATES ATTORNEY

District Court No. A5501746

500 South Australian Avenue, Suite 400

West Palm Beach, Florida 33401

Tel: (561) 209-1011

Fax: (561) 659-4526

alexandra.chase@usdoj.gov

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on April 5, 2023, I electronically filed the foregoing document 

with the Clerk of the Court using CM/ECF.

/s/ Alexandra Chase

ALEXANDRA CHASE

Assistant United States Attorney

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