Santos

I. Background

In August 2004, co-defendant Kevin Eisert delivered to Santos a batch of mail he had recently stolen, which included bank statements and checks from a number of businesses. Santos brought the stolen checks to an individual known as “Cowboy,” who at various times made counterfeit checks from them. Santos and Cowboy would then recruit other indi- viduals to cash the counterfeit checks, offering the recruits 50% of the amount cashed and keeping 50% for themselves to be split evenly between them.

A month later, Santos and Cowboy recruited a woman named Laurane Ivey to cash a counterfeit check. The three 1 Santos also challenges the district court’s application of a two-level aggravating role enhancement under U.S.S.G. § 3B1.1(c). We dispose of that issue in a separate memorandum disposition, filed concurrently with this opinion. UNITED STATES v. SANTOS 6407 drove to an apartment complex, where Cowboy created a check in Ivey’s name. Ivey then drove both men to a check cashing store, where she was arrested attempting to cash the check. Cowboy and Santos fled the scene. In a search of Ivey’s trunk, the police discovered stolen mail, counterfeit…