Convictions of defendants for defrauding the Farm Service Agency (FSA) of emergency loans and incentives to qualified farmers following the damage inflicted on the Commonwealth of Puerto Rico by a hurricane is affirmed where: 1) evidence is sufficient to support defendants' convictions; 2) district court did not abuse its discretion by instructing the jury on sentencing enhancements; 3) district court did not abuse its discretion in its pre-trial disqualification of a defendant's attorney; 4) district court's imposition of a 27-month sentence defendant is not unreasonable; and 5) district court did not err in awarding a four-point leadership role enhancement on the other defendant.
Appeal from the United States District Court for the District of Puerto Rico
Decided January 25, 2010
Opinion by Circuit Judge Gajarsa
For Appellant: Raymond L. Sanchez Maciera, Rachel Brill
For Appellee: Rosa Emilia Rodríguez-Velez, Nelson Perez-Sosa