USA v. Curry

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IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NORTH CAROLINA
CHARLOTTE DIVISION
CIVIL ACTION NO. 3:25-CR-00148-KDB-DCK
UNITED STATES OF AMERICA,
v. MEMORANDUM AND ORDER
CAMERON CURRY,
Defendant.
THIS MATTER is before the Court on consideration of additional restitution, requested
in the Government’s Memorandum in Aid of Sentencing (Doc. No. 79). The Court has carefully
considered this memorandum, the Defendant’s opposition (Doc. No. 92), exhibits and oral
argument on the motion from the parties at the sentencing hearing on August 13, 2026. For the
reasons discussed below, the Court will GRANT in part and DENY in part the Government’s
request for additional restitution.
On March 18, 2026, Defendant Cameron Curry (“Curry”) was found guilty by a jury on
six counts interstate communications with intent to extort and aiding and abetting, in violation of
18 U.S.C. §§ 875(d) and 2. (Doc. No. 67). On August 14, 2026, this Court entered judgment and
ordered Curry to pay restitution to Brightly Software, Inc. in the amount of $7,540.80. (Doc. No.
84). The Court left open for twenty-one days the Government’s motion for an additional
$81,260.01 in restitution to Brightly Software, Inc., allowing Defendant an opportunity to respond
to the Government’s belated request.1
1 The Government did not provide documentation supporting additional restitution to the Court until during
the sentencing hearing, unnecessarily delaying consideration of the request.
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On September 3, 2026, Defendant filed his opposition to additional restitution and argued
that the invoices provided by the victim did not support such restitution. (Doc. No. 92; Ex. 2
“Certification of Authenticity of Business Records”). The Court partially agrees with Curry.
The Mandatory Victim Restitution Act (“MVRA”) requires defendants who have been
convicted of certain offenses, including fraudulent extortion, to “reimburse the victim for lost
income and necessary child care, transportation, and other expenses incurred during participation
in the investigation or prosecution of the offense or attendance at proceedings related to the
offense.” Lagos v. United States, 584 U.S. 577, 579 (2018) (quoting 18 U.S.C. § 3663A(b)(4)
(emphasis in opinion)). But because the words “investigation” and “proceedings” are limited to
“government investigations and criminal proceedings,” Lagos, 584 U.S. at 585, restitution must
be limited to such participation only.
While some of the line items listed on the invoices make clear the activity for which the
expense was incurred, others lack the specificity required for the Court to discern how they relate
to “governmental investigations and criminal proceedings.” Lagos, 584 U.S. at 585. For example,
Invoice No. 553 dated January 29, 2026, from FTI Consulting, demonstrates that the expenses for
professional services were incurred while participating in federal proceedings. The specific line
items contain written descriptions that on their face show the required participation:
• 11/26/2025: Eric Humbert – attend meetings with client and colleagues regarding
federal trial.
• 11/21/2025: Patrick Bolger – prepare for and attend meeting with client and federal
prosecution.
However, the Court will not order additional restitution without a supporting rationale as depicted
above. For example, the FTI Consulting invoice dated March 13, 2026, only states “Sidley Austin
LLP Brightly Software” and claims total expenses of $32,558.99. The Court cannot determine
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whether these legal services were related to the government’s investigation and/or criminal
proceedings from this and other similarly bare invoices, so they will not be included in additional
restitution.
Accordingly, the Court finds that the following invoices support additional restitution:
No. Services
Date
Services
Description Amount2
FTI Consulting January 29, 2026 (No. 553)
1. 11/26/2025 Eric Humbert: Attend meeting with client and colleagues
regarding federal trial.
$392
2. 12/10/2025 Eric Humbert: Review artifacts and emails with client and
colleagues regarding potential trial.
$2,548
3.
12/19/2025 Eric Humbert: Prepare for meetings with DOJ/FBI and
counsel; Attend meetings with DOJ/FBI and internal
counsel
$1,862
4.
11/21/2025 Patrick Bolger: Prepare for and attend meeting with client
and federal prosecution team to prepare for pending
testimony
$1,960
5. 12/10/2025 Patrick Bolger: Facilitate meeting with counsel to prepare
for pending trial testimony
$980
FTI Consulting April 2026, 2026 (No. 7086)
6. 3/6/2026 Eric Humbert: Review and prepare for trial testimony;
attend meeting with counsel
$1,568
7. 3/9/2026 Eric Humbert: Review evidence for trial; Attend meeting
with counsel regarding trial testimony
$1,764
8. 3/12/2026 Eric Humbert: Review and prepare for trial testimony;
Attend trial prep meeting with counsel and DOJ
$2,254
9. 3/6/2026 Patrick Bolger: Conduct case review and testimony
preparation w/ outside counsel
$2,744
10. 3/9/2026 Patrick Bolger: Case files review $490
11. 3/10/2026 Patrick Bolger: Meeting with federal prosecutors to
prepare for testimony
$2,352
12.
3/16/2026 Patrick Bolger: Reviewed case facts and facilitated
working meetings with outside counsel to prepare for
testimony
$6,958
13. 3/17/2026 Patrick Bolger: Prepared for and provided testimony at
federal criminal court proceeding
$5,292
Total Additional Restitution: $31,164
2 Each invoice depicts multiple line items that comprise the total of the invoice. For
professional services, the rate provided on all invoices is $980/hour. For each line item, the invoice
depicts the number of hours billed to the decimal point and a description of that line item. However,
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NOW THEREFORE IT IS ORDERED THAT:
1. The Government’s Request for Additional Restitution (Doc. No. 79) is GRANTED
in part and DENIED in part; and
2. The Clerk is directed to amend the Judgment (Doc. No. 84) to reflect the
restitution amounts listed in this Order.
SO ORDERED ADJUDGED AND DECREED.
the invoices only provide a dollar amount for groups of line items, not each individually.
Accordingly, to determine the dollar figures listed in the table above, the Court multiplied the
hourly rate by the time billed for each line item. For example, January 29, 2026, Invoice No. 553
(No. 4 above) has a line item for 11/26/2025 billed for 0.40 hours, so the amount the Court
attributed to that is $392 (or $980 x 0.40 = $392). The Court repeated this for each line item on the
invoices.
Signed: October 6, 2026
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