Date Mar6,20151251 PM
Subjecl Michael Johnson

Here IS the letter I am proposlng sendan to the prosecutor early next week Please note that It does not
Include a no contest plea Betore send II. I would llke your opInIon on It you thInk It IS MIchael
would take (as there IS not point In maklng a counter offer MIchael would not take)

Heather Donovan
Forwarded by Heather Donovan/Areafl'l mseo on name/201511 49 AM

 

 

March 4. 2015

Phil Groenweghe
Assistant Prosecuting Attorney
St. Charles County

Re: Michael Johnsonr 13117CR05915
Dear Phil:

The last time we spoke you mentioned the possibility oi entertaining a counter offer from
Michael.

We have two counter proposals lor you to consider:

Proposal Amend counts 1 and 5 to class felonies. On count 1, 5 DOC. On
count 5. 5 DOC. Counts to run concurrent with each other.

Proposal Amend counts 1 and 5 to class felonies. On count 1, 7 DOC. On
count 5. 3 DOC. Counts to run consecutive to each other. Suspend execution of sentence.
Place delendant on 5 probation with the agreement oi no earned compliance credit as well
as other special conditions requested,

Given Dr. Hardy's testimony regarding the low risk ol transmission through oral sex and anal
sex where there was no ejaculation in the anus, we would be asking that you nolle counts 2, 3,
and 4.

We would also ask that you agree no charges be filed with regard to allegations made by
Charles Ploutz.

I know you will have to run these proposals past several people. Please get back to me after
you have had a chance to do so.

Sincerely,

Heather E. Donovan