By Joe Beck
Yulissa Eusebio thought she was taking a short, innocent Christmas vacation with her boyfriend when they set out for Houston in early December 2011.
But the trip ended abruptly on the way back with a drug bust on Interstate 81 near Edinburg. Now Eusebio's attorney, Sherwin Jacobs, is trying to spare her from a harsh prison sentence.
The story Eusebio tells in a sentencing memorandum filed Thursday in U.S. District Court begins with a boyfriend identified only as Lenny.
She agreed to go on the trip with Lenny and the man who ended up being her co-defendant in the case, Jose Augusto Ferreira-Flores, according to the memorandum.
She didn't realize until she got to Houston that the others were making the trip to obtain drugs.
"Yulissa had no knowledge of the overall conspiracy, nor did she know that the purpose of the trip to Texas was to obtain drugs," Jacobs wrote.
He described her later in the memorandum as having no criminal record and no involvement in drugs "of any type."
"The closest that she has ever come to being involved with drugs were the individuals with whom she associated and in particular the individual with whom she chose to have a romantic relationship," Jacobs said.
By the time she and the men left Houston, she knew they had placed drugs in the trunk of the car during their stay there, according to a statement of facts she signed.
She agreed to drive the car back to New York only to be pulled over for speeding while headed northbound on I-81 near Edinburg, the court document states.
She and Ferreira-Flores have both pleaded guilty to possessing heroin with intent to distribute.
In a sentencing memorandum also filed Thursday, Assistant U.S. Attorney Grayson Hoffman asked that Judge Michael F. Urbanski give Ferreira-Flores a lighter sentence than the 70 to 87 months called for in federal sentencing guidelines.
Hoffman cited "substantial assistance" that Ferreira-Flores had given prosecutors during the investigation as his reason for seeking a lesser sentence.
In another sentencing memorandum filed Thursday, Ferreira-Flores's attorney, Joel Hoppe, described him and Eusebio as "drug mules whose task was to transport from Texas back to New York drugs that the other members of the group had obtained."
Hoppe called on Urbanski to limit Ferreira-Flores's sentence to 35 months.
Contact staff writer Joe Beck at 540-465-5137 ext. 142, or firstname.lastname@example.org