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UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION

UNITED STATES OF AMERICA

v. CASE NO. 8:22-cr-155-MSS-SPF

ALEXANDER LESZCZYNSKI

UNITED STATES’ SENTENCING MEMORANDUM

The United States of America, by Roger B. Handberg, United States Attorney

for the Middle District of Florida, hereby files this Sentencing Memorandum, stating

as follows:

I. PRELIMINARY STATEMENT

Defendant Alexander Leszczynski is scheduled to be sentenced on

Wednesday, October 4, 2023, at 9:30 a.m. The government respectfully submits this

memorandum in connection with that sentencing hearing.

The government submitted a small number of minor corrections and proposed

additions to the facts of the Presentence Investigation Report (“PSR”) prepared by

the United States Probation Office. Aside from those submissions, the government

has no objections to the factual accuracy of the PSR. See Doc. 96. Further, the

government concurs with Probation’s calculation of the applicable United States

Sentencing Guidelines (“USSG”), which yielded a Total Offense Level of 35, a

Criminal History Category of I and, thus, a recommended range of 168–210 months

of imprisonment, followed by a term of supervised release of one to three years, a

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fine of $50,000 to $250,000, in addition to a special assessment of $100 per count of

conviction and mandatory restitution. See id. at ¶¶ at ¶¶ 65, 73, 113, 115, 121, & 122.

The government recommends that the Court impose a sentence at the high

end of the applicable USSG range. Such a sentence would comport with the

statutory sentencing factors in that it would account for the nature and circumstances

of defendant Leszczynski’s offenses of conviction and his history and characteristics

as well as reflect the seriousness of the offenses, promote respect for the law, provide

just punishment for the offenses, afford adequate deterrence to criminal conduct and,

most importantly, protect the public from further crimes of the defendant. See 18

U.S.C. § 3553(a)(1) and (2)(A)–(C).

II. STATUTORY SENTENCING FACTORS

The late Dr. Maya Angelou is credited for the sage advice that “when

someone tells you who they are, you should believe them the first time.” Over the

last several years, Alex Leszczynski has shown nothing but contempt for this Court,

for the Department of Justice, and the rule of law. From forging a pardon letter

(purportedly signed by former President Trump), to soliciting individuals to “cop” to

his crimes, defendant Leszczynski has told us—again and again—precisely who he

is. See Exhibit A; see also PSR ¶¶ 47, 49, 60 & pp. 89–93, 96, 98, 102, 106, 108, 113–

115, & 117. Defendant Leszczynski consummate fraudster, completely lacking in

remorse, whose only goal appears to be to make the lives of those he crosses paths

with as difficult as possible.

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It is difficult to know where to begin when describing Defendant

Leszczynski’s crimes, of which there are many. The investigation began when a local

law enforcement agency made a referral to the Federal Bureau of Investigation

(“FBI”) that a purported religious entity headquartered in the Middle District of

Florida had fraudulently applied for and received two Payroll Protection Plan

(“PPP”) loans for totaling approximately $195,910 and it appeared that the entity,

Love & Bliss Inc., was not entitled to receive the subject loan.

Open-source reporting identified that Leszczynski and Love & Bliss had been

connected with a deed fraud scheme in which Leszczynski deeded to Love & Bliss

three properties (collectively valued at $90 million) belonging to the Estate of

convicted sex offender Jeffrey Epstein (for the benefit of Epstein’s victims). See

William Bredderman& Kate Briquelet, Meet the Accused Stalker Behind the Christian

Nonprofit Gunning for Epstein’s Houses, June 2, 2021 (available at

https://www.thedailybeast.com/meet-the-accused-stalker-behind-the-christian-

nonprofit-gunning-for-jeffrey-epsteins-houses). Further investigation revealed that the

Epstein properties were not the only properties that defendant Leszczynski had his

eye on. The investigation eventually connected defendant Leszczynski to the

transfers of ten properties (primarily located in Florida, save for the Epstein

properties) to seven distinct “religious entities” 1 owned or controlled by Leszczynski.

While the many of the properties were owned by trusts or corporate entities and were

1
Those entities were Love & Bliss, Aura, Inc., King Neptune, Inuyasha, Inc., Rhone, Inc.,
King Cobra, Inc., Tinnitus Institute of Love & Bliss, Inc., and King Country Road, Inc.

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valued at tens of millions of dollars, one property, owned by husband-and-wife

victims M.S. and M.S., captured his special attention.

The M.S. property was located in Redington Shores, Florida, approximately a

mile from defendant Leszczynski’s home in North Redington Beach. And when

M.S. and M.S.—like the other deed fraud victims—engaged in civil litigation to

attempt to correct the deed to their newly-purchased home, defendant Leszczynski

engaged in a campaign of harassment and intimidation. For example, on October 3,

2021, an email was sent from an email Leszczynski controlled—

michaeloliver@consultant.com—to attorney B.C. (a civil attorney for M.S. and

M.S.) and others. The email begins, “Hello I’m a Business Consultant representing

clients overseas In Asia, Japan, South Korea…” The email continues, “[M.S.] did in

fact donate the property to a Non-Profit Corporation and from what I’ve gathered is

[M.S.], have either lost or have never received the Charitable Tax deduction Receipt,

to then be able to deduct the amount from their gross annual taxes paid.” The email

names [M.S.]’s company and job title and states, “It would be such a shame for One

of our Extremely Wealthy Clients to indirectly talk down about [M.S.] in meeting at

global summits…” See Exhibit B; see also Exhibits C & D (filed under seal).

At this point in October 2021, federal investigators were laser-focused on

gathering the evidence necessary to indict Leszczynski for the PPP and deed fraud

schemes, but they had also discovered a third scheme in which Leszczynski

fabricated checks and attempted to deposit them into the same account that

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ultimately held his PPP funds. Over several months, Leszczynski attempted to

deposit $2.7 million in fraudulent checks, $110,000 of which were funded.

All the while Leszczynski was moving the PPP and check fraud funds from

account to account (as detailed in the indictment), with the United States attempting

to identify locate and seize the funds. And then in November 2021, M.S. reported to

law enforcement that he had received another letter from Leszczynski at his Texas

residence. The typed letter stated in part, “I don’t want to see your career go down

the drain, I’ve been hearing lots of things about you, an ex-girlfriend who can’t keep

her mouth shut claims that your raped her, of course you will say its false but don’t

worry about her because we can take care of her for you :).” The letter concludes

with handwriting, “THIS UR LAST CHANCE.” See Exhibit E (filed under seal).

The government knew at this point it did not have all of the records necessary to

indict Leszczynski, but they wanted to take whatever action they could to stop the

harassment of M.S. and M.S. So on December 3, 2021, FBI agents conducted a

search warrant at Leszczynski’s, seized multiple devices, and spoke to Leszczynski.

As detailed in Leszczynski’s initial appearance and bond hearing, FBI agents

gave Leszczynski a stern warning to cease all contact with M.S. and M.S.

Leszczynski was also advised that the PPP loan he obtained was fraudulent. But

Leszczynski did not stop. After the search warrant was conducted:

• M.S. and M.S. received another harassing letter on December 15, 2021;

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• Leszczynski moved the check and PPP fraud proceeds two times, first

on December 6, 2021, and again on January 11, 2022 (the subject of

Counts Seven and Eight of the Indictment;

• Leszczynski listed the property owned by M.S. and M.S. on multiple

websites, including Zillow.com; and

• Leszczynski continued to respond to various quiet title lawsuits filed by

the rightful owners of the properties he deeded to himself.

In April 2022, Leszczynski was indicted, and he was arrested and detained in May

2022.

Even arrest and detention did not stop Leszczynski from his campaign of

harassing M.S. and M.S. or from his flagrant disregard for our system of justice. In

August 2022, the government received a letter from the Pinellas County Jail

concerned that Leszczynski was attempting to hire a “hit man” to kill two

individuals who were witnesses in his case, that is, M.S. and M.S. This event, and

events that occurred in the weeks that followed, became the subject of Leszczynski’s

second federal indictment in Case No. 8:22-cr-371-JSM-AAS.

Still the evidence against Leszczynski was overwhelming. He used his credit

card to pay for many of the corporate entities to which he deeded properties, he

controlled all of the bank accounts into which fraud proceeds were deposited, he

appeared on camera depositing worthless checks, and many of the acts and

communications in furtherance of his scheme were traced by to his home IP address.

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On his various devices seized during the December 2021 search warrant, agents

discovered draft deed documents, forged signatures, google search history showing

searches for M.S. and relatives, and much more. Ultimately the defendant expressed

an intention to plead guilty in both of his pending cases. But the saga does not end

there.

Despite two prior competency evaluations (April 2022–found to be

malingering, and October 2022–found to be competent), Leszczynski requested to be

evaluated again. (Doc. 64). He then moved to withdraw his plea (Doc. 65), and then

later requested not to withdraw his plea (Doc. 66). He persisted in his requests for

additional competency evaluations in his parallel case, and ultimately Judge Moody

ordered Leszczynski into the custody of the Attorney General to be evaluated. (Case

No. 8:22-cr-371-JSM-AAS, Doc. 59). Once again, Leszczynski was found to be

competent.

Since his return to the Middle District of Florida, Leszczynski has made

multiple attempts to have friends and other inmates claim that they committed both

his fraud offenses and the murder-for-hire offense. PSR ¶¶ 47, 49, 60 & pp. 89–93,

96, 98, 102, 106, 108, 113–115, & 117. The correspondence obtained by the

government was provided to defense counsel and probation, and is attached to the

PSR. FBI agents interviewed multiple individuals at the Pinellas County Jail

regarding Leszczynski’s claims and discovered them to be unfounded. Those reports,

too, were provided to defense counsel. Still, despite knowing that we could intercept

his letters, and that we would continue to interview subjects, Leszczynski persisted in

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this obstruction.

In determining an appropriate sentence, this Court must consider the factors

in 18 U.S. Code § 3553. In particular, the Court must consider the nature and

circumstances of the offense and the history and characteristics of the defendant, and

the need for the sentence imposed to reflect the seriousness of the offense, to promote

respect for the law, and to provide just punishment for the offense; to afford adequate

deterrence to criminal conduct; and to protect the public from further crimes of the

defendant. Leszczynski has told us who he is. He is a criminal with no remorse or

limit to what he will do or say to get his way. All of these factors point to a sentence

at the high end of Leszczynski’s guideline range.

For all of the foregoing reasons, the Court should impose a prison sentence at

the high end of the applicable Sentencing Guidelines range.

Respectfully submitted,

ROGER B. HANDBERG
United States Attorney

By:

Rachel K. Jones
Assistant United States Attorney
Florida Bar. No. 91492
400 N. Tampa Street, Suite 3200
Tampa, FL 33602
Phone: (813) 274-6000
Fax: (813) 274-6178
Email: Rachel.Jones@usdoj.gov

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U.S. v. ALEXANDER LESZCZYNSKI Case No. 8:22-cr-155-MSS-SPF

CERTIFICATE OF SERVICE

I hereby certify that on September 25, 2023, I electronically filed the foregoing

with the Clerk of the Court by using the CM/ECF system which will send a notice of

electronic filing to the following:

Ronald Kurpiers

s/ Rachel K. Jones
Rachel K. Jones
Assistant United States Attorney

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Exhibit A

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