Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 1 of 175 81,7(' 67$7(6 ',675,&7 &2857 ',675,&7 2) 0$66$&+86(776 81,7(' 67$7(6 2) $0(5,&$ Y &5 ,7 *25'21 &$3/$1 (;+,%,7 $ /(77(56 ,1 6833257 2) *25'21 &$3/$1¶6 6(17(1&,1* 0(025$1'80 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 2 of 175 Letters in Support of Gordon Caplan?s Sentencing Memorandum Tab Family 1 aplan, Amy (wife) 2 (daughter) 3 ? 4 aplan, Ronald (father) 5 Avital-Caplan, Aliza (father?s wife) 6 (half-sister) 7 Perskin, Randy (sister) 8 Perskirr, Thomas (nephew) 9 Perskin, Zachary (nephew) 10 Treibick, Ian (brother-in?law) 11 Eckhardt, Bronwyn (cousin-in-law) 12 Margulies, Michael (cousin) Medical Professionals 13 Greenfeld, David 14 Kass, Frederick 15 Bolger, Mary Others in Support of Gordon Caplan 16 Anonymous (former client) 17 Benedek, Michael (friend) 18 Bernstein, Andrew (friend) 19 Bonney, James (police of?cer and friend) 20 Brentani, William (friend) 21 Briggs, Joanne (friend) 22 Bruch, Gregory (former colleague) 23 Casanova, Pedro (friend) 24 Dave, Kruti (former colleague) 25 Davis, Jessica (professional acquaintance) 26 Davis. Wilbert (former colleague) 27 de Franciscis, Maurizio (professional acquaintance) Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 3 of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ase 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 4 of 175 6KXIULQ +DUU\ DFFRXQWDQW 6RQRGD ŝĨĞzŝĞůĚ͕ Ă ĨŝŶĂŶĐŝĂů ƚĞĐŚŶŽůŽŐLJ ĐŽŵƉĂŶLJ ďĂƐĞĚ ŝŶ ŽƐƚŽŶ͘ / ĂƚƚĞŶĚĞĚ ŽƐƚŽŶ ŽůůĞŐĞ >Ăǁ ^ĐŚŽŽů ĂŶĚ Ăŵ Ă ŵĞŵďĞƌ ŽĨ ƚŚĞ DĂƐƐĂĐŚƵƐĞƚƚƐ ĂŶĚ EĞǁ zŽƌŬ ^ƚĂƚĞ ďĂƌƐ͘ / ŵĞƚ 'ŽƌĚŽŶ ŝŶ ϭϵϴϮ ǁŚĞŶ / ũŽŝŶĞĚ ŽƵƌ ŚŝŐŚ ƐĐŚŽŽů͛Ɛ Ɛǁŝŵ ƚĞĂŵ͖ / ǁĂƐ Ă ĨƌĞƐŚŵĂŶ ĂŶĚ 'ŽƌĚŽŶ ǁĂƐ Ă ũƵŶŝŽƌ ĂŶĚ ŽŶĞ ŽĨ ƚŚĞ ƚĞĂŵ͛Ɛ ůĞĂĚĞƌƐ͘ / ǁĂƐ Ă ƐŽŵĞǁŚĂƚ ŶĞƌǀŽƵƐ LJŽƵŶŐ ƚĞĞŶĂŐĞƌ͕ ĂŶĚ ŶŽƚ Ă ƉĂƌƚŝĐƵůĂƌůLJ ŐŽŽĚ ƐǁŝŵŵĞƌ͕ ďƵƚ ƚŚĞ ůĞĂĚĞƌƐŚŝƉ ŽĨ ƚŚĞ ƚĞĂŵ͕ ĂŶĚ ĞƐƉĞĐŝĂůůLJ 'ŽƌĚŽŶ͕ ŵĂĚĞ ŝƚ ĐůĞĂƌ ƚŚĂƚ Ăůů ǁĞƌĞ ǁĞůĐŽŵĞ ŝĨ LJŽƵ ǁĞƌĞ ǁŝůůŝŶŐ ƚŽ ƚĂŬĞ ƐĞƌŝŽƵƐůLJ LJŽƵƌ ƌĞƐƉŽŶƐŝďŝůŝƚŝĞƐ ďŽƚŚ ĂƐ ƐǁŝŵŵĞƌ ĂŶĚ ĂƐ Ă ƐƵƉƉŽƌƚŝǀĞ ƚĞĂŵŵĂƚĞ͘ dŚĞ ůĂƚƚĞƌ ǁĂƐ ƉĞƌŚĂƉƐ ƚŚĞ ŵŽƌĞ ŝŵƉŽƌƚĂŶƚ ƌĞƋƵŝƌĞŵĞŶƚ ĂŶĚ ŝƚ ŝŶĐůƵĚĞĚ Ă ƌĞƐƉĞĐƚ ĨŽƌ ŽƚŚĞƌƐ ŶŽ ŵĂƚƚĞƌ ŚŝƐ Žƌ ŚĞƌ ĂďŝůŝƚLJ Žƌ ƐŽĐŝĂů ƐƚĂŶĚŝŶŐ͘ 'ŽƌĚŽŶ ǁĂƐ Ă ůĂƌŐĞ ƉĂƌƚ ŽĨ ƉƌŽŵŽƚŝŶŐ ƚŚŝƐ ĂƚŵŽƐƉŚĞƌĞ͕ ĂŶĚ͕ ĂƐ Ă ƌĞƐƵůƚ͕ ŝŶ ŚŝƐ ƐĞŶŝŽƌ LJĞĂƌ ŚŝƐ ƉĞĞƌƐ ĞůĞĐƚĞĚ Śŝŵ ďŽƚŚ ƚĞĂŵ ĂƉƚĂŝŶ ĂŶĚ ǁŝŶŶĞƌ ŽĨ ƚŚĞ ůƵŵŶŝ ǁĂƌĚ͕ ǁŚŝĐŚ ŝƐ ŐŝǀĞŶ ƚŽ ƚŚĞ ƉĞƌƐŽŶ ǁŚŽ ŵŽƐƚ ĞdžĞŵƉůŝĨŝĞƐ ƐƚƌŽŶŐ ĂŶĚ ĐŽŵƉĂƐƐŝŽŶĂƚĞ ůĞĂĚĞƌƐŚŝƉ͘ &Žƌ ŵĞ͕ 'ŽƌĚŽŶ ŶŽƚ ŽŶůLJ ĚĞƐĞƌǀĞĚ ƚŚĞƐĞ ŚŽŶŽƌƐ ďĞĐĂƵƐĞ ŽĨ ǁŚĂƚ ŚĞ ĚŝĚ͕ ďƵƚ ĂůƐŽ ďĞĐĂƵƐĞ ŽĨ ǁŚĂƚ ŚĞ ŝŶƐƉŝƌĞĚ͖ ŚĞ ǁĂƐ Ă ƌŽůĞ ŵŽĚĞů ĨŽƌ ŵĞ ĂŶĚ ƐŽ / ƐŽƵŐŚƚ ƚŽ ůĞĂĚ ĂƐ ŚĞ ŚĂĚ͘ DƵĐŚ ŽǁŝŶŐ ƚŽ ƚŚŝƐ ŝƐ ǁŚLJ /͕ ƚŽŽ͕ ǁĂƐ ĞůĞĐƚĞĚ ĂƉƚĂŝŶ ŝŶ ŵLJ ƐĞŶŝŽƌ LJĞĂƌ ĂŶĚ ƌĞĐĞŝǀĞĚ ƚŚĞ ůƵŵŶŝ ǁĂƌĚ͘ KǀĞƌ ƚŚĞ ĚĞĐĂĚĞƐ ƐŝŶĐĞ͕ 'ŽƌĚŽŶ ŚĂƐ ĐŽŶƚŝŶƵĞĚ ƚŽ ƉƌŽǀŝĚĞ ŵĞ ƉƌŝŶĐŝƉůĞĚ ĂĚǀŝĐĞ ƚŚĂƚ ŚĂƐ ĐŽŶƐŝƐƚĞŶƚůLJ ĚĞŵŽŶƐƚƌĂƚĞĚ ƚŚĞ ƵƚŵŽƐƚ ŝŶƚĞŐƌŝƚLJ͘ KŶĞ ŝŶƐƚĂŶĐĞ ŝŶ ƉĂƌƚŝĐƵůĂƌ ĐŽŵĞƐ ƚŽ ŵŝŶĚ͘ / ŚĂĚ ũƵƐƚ ůĂƵŶĐŚĞĚ Ă ƚĞĐŚŶŽůŽŐLJ ĐŽŵƉĂŶLJ ĂŶĚ ŵĞƚ ǁŝƚŚ 'ŽƌĚŽŶ ƚŽ ĚŝƐĐƵƐƐ ĂǀĞŶƵĞƐ ĨŽƌ ƉŽƚĞŶƚŝĂů ĨŝŶĂŶĐŝŶŐ͘ EŽƚ ƐƵƌƉƌŝƐŝŶŐůLJ͕ 'ŽƌĚŽŶ ŐĞŶĞƌŽƵƐůLJ ŽĨĨĞƌĞĚ ƚŽ ŵĂŬĞ ŝŶƚƌŽĚƵĐƚŝŽŶƐ ƚŽ ƉŽƚĞŶƚŝĂů ŝŶǀĞƐƚŽƌƐ͘ tŚĞŶ / ƐĂŝĚ ƚŚĂƚ / ǁŽƵůĚ ĐŽŵƉĞŶƐĂƚĞ Śŝŵ ĨŽƌ ƚŚĞƐĞ ŝŶƚƌŽĚƵĐƚŝŽŶƐ͕ 'ŽƌĚŽŶ ĨůĂƚůLJ ĂŶĚ ƐƚĞĂĚĨĂƐƚůLJ ƌĞĨƵƐĞĚ ;ĂŶĚ ĂĚǀŝƐĞĚ ƚŚĂƚ / ĂǀŽŝĚ ĂŶLJ ƐƵĐŚ ĂƌƌĂŶŐĞŵĞŶƚƐ ǁŝƚŚ ŽƚŚĞƌƐͿ͘ ǀĞŶ ƚŚŽƵŐŚ ŝƚ ǁŽƵůĚ ŚĂǀĞ ďƌŽƵŐŚƚ Śŝŵ Ă ƉĞĐƵŶŝĂƌLJ ďĞŶĞĨŝƚ͕ ŚĞ ĚŝĚ ŶŽƚ ƚŚŝŶŬ ƚŚĞƌĞ ƐŚŽƵůĚ ĞǀĞƌ ďĞ ĂŶLJ ĐŽŶĨƵƐŝŽŶ Ͳ ĞŝƚŚĞƌ ďLJ ŵĞ Žƌ Ă ƉŽƚĞŶƚŝĂů ŝŶǀĞƐƚŽƌ Ͳ ĂƐ ƚŽ ǁŚLJ ŚĞ ǁŽƵůĚ ďĞ ŵĂŬŝŶŐ ƐƵĐŚ ĂŶ ŝŶƚƌŽĚƵĐƚŝŽŶ͘ dŚŝƐ ďĞŚĂǀŝŽƌ ŝƐ ƌĞƉƌĞƐĞŶƚĂƚŝǀĞ ŽĨ ŚŽǁ 'ŽƌĚŽŶ ŚĂƐ ĐŽŶƐŝƐƚĞŶƚůLJ ƐŽƵŐŚƚ ƚŽ ŚĞůƉ ŽƚŚĞƌƐ ĨƌĞĞ ĨƌŽŵ ĐŽŶĨůŝĐƚ ĂŶĚ ǁŝƚŚŽƵƚ ŐĂŝŶ ƚŽ ŚŝŵƐĞůĨ͘ Ɛ ƚŽ ƚŚĞ ŵĂƚƚĞƌ Ăƚ ŚĂŶĚ͕ ǁŚŝůĞ / ĐĞƌƚĂŝŶůLJ ŬŶŽǁ ŚŽǁ ǁƌŽŶŐ 'ŽƌĚŽŶ͛Ɛ ĂĐƚŝŽŶƐ ǁĞƌĞ͕ / ĂůƐŽ ŬŶŽǁ ƚŚĂƚ ǁĞ ĂƌĞ Ăůů ĨĂůůŝďůĞ͘ / ĚŽ ŶŽƚ ďĞůŝĞǀĞ ƚŚŝƐ ƐŝŶŐůĞ ĞǀĞŶƚ ĂĐĐƵƌĂƚĞůLJ ƌĞƉƌĞƐĞŶƚƐ ƚŚĞ ƉĞƌƐŽŶ ŽĨ ŝŶƚĞŐƌŝƚLJ ʹ ďŽƚŚ ƉĞƌƐŽŶĂůůLJ ĂŶĚ ƉƌŽĨĞƐƐŝŽŶĂůůLJ ʹ / ŚĂǀĞ ŬŶŽǁŶ ĨŽƌ ĂůŵŽƐƚ ϰϬ LJĞĂƌƐ͖ Ă ƉĞƌƐŽŶ ĨŽƌ ǁŚŽŵ ƚŚĞ ƉƌŽďŝƚLJ ŽĨ ŚŝƐ ůĂǁ ƉƌĂĐƚŝĐĞ ŚĂƐ ĂůǁĂLJƐ ďĞĞŶ ŝŶƚĞŐƌĂů ƚŽ ŚŝƐ ĐŽƌĞ ďĞŝŶŐ͘ ůů / ĐĂŶ ƚŚŝŶŬ ŝƐ ƚŚĂƚ ŚĞ ŚĂĚ Ă ŵŽŵĞŶƚĂƌLJ ůĂƉƐĞ ŽĨ ũƵĚŐŵĞŶƚ ĚƌŝǀĞŶ ŶŽƚ ďLJ ĂŶLJ ŵĂůŝĐĞ ǁŚĂƚƐŽĞǀĞƌ ƚŽǁĂƌĚƐ ĂŶŽƚŚĞƌ ŚƵŵĂŶ ďĞŝŶŐ͕ ďƵƚ ďLJ Ă ;ŵŝƐŐƵŝĚĞĚ ƉĞƌŚĂƉƐͿ ůŽǀĞ ĨŽƌ Ă ĐŚŝůĚ͘ Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 46 of 175 dŚƌŽƵŐŚŽƵƚ ƚŚĞ ƉĂƐƚ ĨĞǁ ŵŽŶƚŚƐ ŝƚ ŚĂƐ ďĞĐŽŵĞ ĐůĞĂƌ ŚŽǁ ƐŝŶĐĞƌĞůLJ ĐŽŶƚƌŝƚĞ 'ŽƌĚŽŶ ŝƐ͘ zĞƐ͕ ƚŚĞ ŐůĂƌŝŶŐ ŚŝƚƐ ƚŽ 'ŽƌĚŽŶ͛Ɛ ĐĂƌĞĞƌ ĂŶĚ ƌĞƉƵƚĂƚŝŽŶ ŚĂǀĞ ďĞĞŶ ƐĞǀĞƌĞ ĂŶĚ ŚĞ ŝƐ ƐƵĨĨĞƌŝŶŐ ĨƌŽŵ ƚŚŝƐ ĂŶĚ ǁŝůů ĐŽŶƚŝŶƵĞ ƚŽ ĚŽ ƐŽ͕ ďƵƚ ǁŚĂƚ ŚĂƐ ƐƚŽŽĚ ŽƵƚ ŵŽƐƚ ƚŽ ŵĞ ŝƐ ƚŚĂƚ ŚŝƐ ĐŽŶƚƌŝƚŝŽŶ ĐŽŵĞƐ ŶŽƚ ĨƌŽŵ ďĞŝŶŐ ĐĂƵŐŚƚ͕ ďƵƚ ƌĂƚŚĞƌ ĨƌŽŵ ƌĞĂůŝnjŝŶŐ ŚŽǁ ǁƌŽŶŐ ŚŝƐ ĂĐƚŝŽŶƐ ǁĞƌĞ ŝŶ ƚŚĞ ĨŝƌƐƚ ƉůĂĐĞ͘ /ƚ ŝƐ ƚŚŝƐ ƌĞĐŽŐŶŝƚŝŽŶ ƚŚĂƚ / ŬŶŽǁ ŝƐ ĂůƌĞĂĚLJ ĂĨĨĞĐƚŝŶŐ ŚŝƐ ƉĂƚŚ ĨŽƌǁĂƌĚ͘ ZĞƐƉĞĐƚĨƵůůLJ LJŽƵƌƐ͕ DŝĐŚĂĞů ĞŶĞĚĞŬ Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 47 of 175 Tab 18 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 48 of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ase 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 49 of 175 Tab 19 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 50 of 175 Your Honor. My name is James Bonney; I am 3 Lieutenant at the Greenwich Connecticut Police Department. I am writing to you on behalf of my friend Gordon Caplan. I have known Gordon Caplan for approximately eight years. I met Gordon when he coached my daughter in flag football. Gordon was an excellent coach and struck me as a very kind and caring man. His son was on the team with my daughter was fortunate enough to become Gordons tenant and neighbor in 2014. I live directly next door to Gordon and his family and see him often. I have been a sworn member of the Greenwich Police Department since 1990. During my time here I have supenised every diyision of the department, including the Detective. Patrol. and Operations Division. I haye supervised the arrest of countless people for an array of crimes. 1 was proud to take dangerous people who victimized residents of Greenwich off the street. I realize that Gordon broke the law. 1 also know that this was a non-Violent offense and his intent was not to harm anyone and was just to help out his daughter who was struggling with school. I feel that Gordon is an honorable man. In this instance. he let his devotion to his family override his common sense. He did it for his child, not himself. This arrest and the corresponding media frenzy have taken a tremendous toll on Gordon and his family. I understand that the prosecutor is demanding jail time in this case, in addition to re? ocatton of his law license. It's a national story and the prosecutors want to come out looking strong. Please consider the following; If Gordon goes to jail. his children will be scarred for life and his son- will be devastated. Without his Law License he will lose his ability to support his family. Gordon is a good man who deserves a second chance. I hope you see it in your heart to spare Gordon and his family. Please feel free to contact me at any timeJames Bonney #05 I Greenwich Police Department Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 51 of 175 Tab 20 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 52 of 175 April 28. 2019 Your Honor. I am writing this letter on behalf of Gordon Caplan in connection with his sentencing. I do not have any knowledge about the conduct leading up to his guilty plea and am not able to understand it. but I hope that the following information about my personal experience with Gordon will be helpful to the Court. I have known Gordon since 1990. when he was still in law school. Since then, I have known him as a good friend and have spent signi?cant time with him and other friends. particularly when I lived in New York City until early 2001. We have remained close. I attended his wedding and have spent time with him and his wife when visiting New York. When I re?ect on the Gordon 1 have known, I think about a very driven, hardworking. relentless and dedicated professional. family man, and reliable friend. While no one is perfect. 1 have had the good fortune of being the bene?ciary ofa caring. empathetic side ofGordon. including in particular during some difficult periods in my own life when he was incredibly supportive. insightful and optimistic when events seemed to dictate otherwise. I have seen him lend this type ofsupport in much the same way to other friends of his. I know that even before his guilty plea. he has been trying to ?x the mess that he created for his family and himself. He is incredibly remorseful and is ready to face the consequences. While I do not know all of the factors that are considered in determining an appropriate sentence. the loss of his job and reputation has been absolutely devastating to him. and it seems that a sentence might be able to draw on his skills and energy in ways to help the community and those in need. I believe him when he says he wants to ?nd ways to become a better person while rebuilding the trust with his family. friends and community that he knows he badly damaged. Thank you for your consideration. Respectfully, 6 William Brentani Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 53 of 175 Tab 21 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 54 of 175 Joanne Briggs Re: united?tateu?atdgn?aplan Your Honor 1 have known Gordon Caplan in a personal and professional capacity for 20 years. He was my mentor when I was an associate at Mintz Levin ohn Ferris Glovsky and. more recently. I worked on a consulting project for him at Willkie Farr Gallagher. He has also been a friend and advisor throughout the time I?ve known him. After talking with Gordon about his criminal offense. he immediately expressed great remorse. He said he was ashamed of his behavior and the legal. moral and ethical boundaries he had transgressed. From my years of knowing Gordon. I sincerely believe that this offense does not speak to his general character. Throughout our personal and professional relationship. 1 have developed tremendous respect for Gordon. not only as an employer and mentor. but as a human being. He always demonstrated honesty. integrity and faimess. He was unfailing in his professional guidance and mentoring - taking time many would not spare to help me learn the practice of law and client relations. Gordon?s standards were rigorous and he led by example. In the many years we worked together. he always held true to all legal. moral and ethical boundaries and expected nothing less from those around him. He created an equal opportunity work environment. where the criteria for success was hard work and giving your best etTort. Gordon also expected me to prioritize my domestic violence pro bono cases as if they were billable matters and fully encouraged my participation in this area. Speaking to Gordon?s integrity. he is one of the few people I've met who follows through on his word. Whether in a professional or personal context, if Gordon offers his guidance, support or help. you can be assured he will be there for you. Clients would frequently speak about his trustworthiness and dependability. On a personal note, two occasions stand out where Gordon has gone above and beyond to honor his word: Several years ago. I was feeling at a loss for how to re-enter the workforce after a hiatus while raising small children. Gordon stepped in to help me navigate that process. sel?essly giving his time and efforts to help me figure out a new path. His support, advice and guidance were invaluable. Then again in 2018, I was faced with the diagnosis and subsequent death of my children?s father. Throughout this difficult time, Gordon reached out to offer his support and assistance. He made it clear he would help in any way possible. even if the request was something simple like picking my kids up from school. Gordon?s sincerity. kindness and thoughtfulness during this time are yet further examples of his good character. Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 55 of 175 ?l?ltank you, Your Honor. for taking these thoughts into consideration. Respectfully @1138 \x Joanne Briggs Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 56 of 175 Tab 22 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 57 of 175 BRUCH HANNA LLP $0226.33; NW 80115500 WASHINGTON DC 20001 NA.COM September 20, 2019 The Honorable Indira Talwani US. District Judge John Joseph Moakley US. Courthouse 1 Courthouse Way Boston, MA 02210 RE: United States v. Gordon Caplan Dear Judge Talwani: I?m writing in connection with the upcoming sentencing of Gordon Caplan. I have been a securities enforcement lawyer for more than 30 years, at the SEC and in private practice, and I was Gordon?s partner at Willkie Farr Gallagher LLP during 2008-13. Gordon was a business lawyer, who represented a number of clients regulated by the Securities and Exchange Commission and other ?nancial regulators. I was a partner specializing in ?nancial-related government investigations, corporate governance, and compliance work. Our work overlapped frequently on compliance issues for his clients. During my time at Willkie, I found Gordon to be an excellent lawyer, a great partner, and a committed advocate for compliance by his clients. Gordon was a successful business lawyer, but he never pandered to his clients. I saw ?rst-hand Gordon?s ability to deliver challenging compliance advice to clients, even when that advice was not welcomed or well-received. Legal compliance advice is often costly and intrusive, but Gordon never blinked when his enforcement and compliance lawyers give him their best advice, and he in turn was fully supportive of that advice when it was delivered by other lawyers to his clients. I have great respect for Gordon as a lawyer and as a person. He was smart, generous, thoughtful, helpful, and full of energy. His success as a lawyer was not the result of luck, salesmanship, or comer?cutting. He was a great adviser and a prodigious worker, and his clients recognized the value he added. I respectfully urge the Court to consider all the good work Mr. Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 58 of 175 The Honorable Indira Talwani September 20, 2019 Page 2 of 2 Caplan has done, and is capable of doing in the ?lture, and to err on the side of leniency at the time of sentencing. Sincerely 6:3 . Bruch Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 59 of 175 Tab 23 Case 1:19-or-10117-IT Document 490-1 Filed 09/26/19 Page 60 of 175 Your Honor: The purpose of this letter is to brie?y describe the character and dedication of Gordon Caplan and ask for leniency on his case. I have known Gordon since 1986 when we where students at Cornell University. We joined the same fraternity and he was my "Big Brother?. Back then he showed traits of leadership, friendship, loyalty and an all around a great human being. Through the years our paths diverged onto different journeys, our carriers and family lives grew and developed. I became a Civil Engineer and received my masters at MIT. I work and live in Puerto Rico. Gordon became a successful layer in New York City after receiving his law degree from Fordham University. The distance, however, did not stop us from remaining in contact with each other: a quick visit, a text, a phone call, or a common friend, and so on. No matter how many years have passed, he has and always will be my ?Big Bro?. Gordon's success in his professional life is pretty well known, but his philanthropic works, which has been very important to him, have remained out of the public eye, and are not as known. I can vouch that his charitable works have been executed with the compassion and with the most sincere of intentions. Not too long ago, I experienced one such example showing his true character. When Hurricane Maria devastated Puerto Rico, Gordon organized a relief effort that brought necessary essentials such as food, water and medical supplies to the Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 61 of 175 suffering people of Puerto Rico. He organized to charter a plane that not only brought the supplies that were very much needed, but rescued people and brought them back to the US, my family and myself included. Families were finally reunited with their loved ones, while others received desperate medical attention. I strongly believe in his good nature as a human being and hope this letter will express a small part of his person. Human beings are not perfect and we have to be responsible for our mistakes, but I believe one should be able to show leniency, knowing that he truly repents his actions. There is so much good Gordon can do for others, and given the chance, the opportunity, I know he can do much good in the world. With my sincere respects, Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 62 of 175 Tab 24 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 63 of 175 May 14, 2019 T0 WHOM IT MAY CONCERN RE: GORDON CAPLAN Dear Sir/Madam, My name is Kruti Dave and I am a Senior Billing Coordinator at Willkie Farr Gallagher LLP. 1 have worked with Gordon for approximately 12 years. Of those 12 years, I worked very closeiy with him for the past year. I was offered a step up by Gordon by being moved outside of the Accounting Dept and to join his Private Equity practice as their Senior Billing Coordinator, as this close proximity made the work flow smoother and faster and gave me a hands?on, in-depth look at the Private Equity practice. initially I was nervous as I had always been part of the Accounting Dept which was very different than working so ciosely with a Partner. I have to say Gordon sensed that nervousness and made me feel very comfortable- He was very patient and very understanding. Today, a year later, I can only be very thankful to him for giving me this opportunity within the ?rm. Working so closely with him, I came to understand him and the work of the firm as a whole. He was awarded with the Des! Maker of the year award last year, and I was truly very happy for him, because I got to see him in action and to see how hard he really works. He is very thorough and very professional. He also has a very good sense of humor and is very compassionate towards others. There were times in the past year when I would have emergencies at home due to my kids being sick or just weather related hassles, and Gordon always would approve my working from home. He insisted that my family came ?rst and that I should not worry about coming in to work. I was never allowed to work from home before at our ?rm, but Gordon made things possible and easier for me- He gave me an additional bonus at the end of year on top of the bonus we received from the firm. He acknowledged my hard work and I am very appreciative and grateful to him for that. I have no hesitation in giving this recommendation. Sincerely, if; .1. Kruti Dave Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 64 of 175 Tab 25 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 65 of 175 Your Honor, I am writing to you on behalf of Gordon Caplan. I made Gordon’s acquaintance in approximately 2009 and interacted with him intermittently throughout the years of 2009-2016 in a work capacity as well as several times in 2019 in a non-work capacity. I wanted to share my perspective on Gordon because I believe it is a particularly unique one; Gordon and I worked together on less than half a dozen occasions, and we did not have a strong direct personal relationship. However, I did have strong direct friendships with people during the period of 2009-2016 who interacted with Gordon significantly. Gordon has done me no personal favors. Nor do I anticipate receiving any material help or favors from him in the future. I have no personal motive to speak well of him but for the fact that I saw how much good he brought to the lives of others at no benefit to himself, and I believe that these accounts of his character ought to be brought to light. From the vantage point of someone who has not benefited from him directly but who has seen his interactions with others, I believe I have seen his true character. Here is what I have observed of Gordon Caplan. I had a friend and co-worker named Joshua Roberts. He was from a middle-class background and was a volunteer fireman at his local firehouse in Suffern, NY. We began our post-college careers in 2009 at the same time in an entry-level analyst program at an investment firm, and it was through that avenue that he and I were both introduced to Gordon Caplan. When Josh expressed his interest and enthusiasm for pursuing a career in law, Gordon made time in his busy schedule to mentor him. When Josh was deciding on which law school program to pursue, Gordon was generous in providing advice to him. And when Josh was graduating and looking for a new role, Gordon offered him a position at Willkie Farr and Gallagher under his wing. Gordon had no reason to help a middle-class kid from Suffern, NY try and make it in the world, but he did it anyway. My current co-founder, Elodie Dupuy, is also another individual whose life was improved by Gordon at no benefit to himself. Elodie began as a part-time receptionist and eventually negotiated her way to a role on the investment team on which Joshua Roberts and I worked. She, too, met Gordon through our previous employer. She had originally begun her work as a part-time receptionist as she was waiting to hear back from law schools, and when she expressed her interest in perhaps one day pursuing a career in the field of law, Gordon made time for her as well. Elodie was one of many people in an entry-level analyst program at a client firm. Helping her could net him no discernible profit. He mentored and advised her as she thought about her career at various junctures, most notably in 2017. Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 66 of 175 When Elodie had left our former employer and approached Gordon for advice, he was a fount of resources and suggestions. In a sector which is often ruled by pedigree – coming from the right school, with the right GPA, with the right look and way of dress – Gordon was focused on raw ability and talent. He offered her a position helping to grow Willkie Farr. More importantly, he shared his observations of her strengths and saw beyond the superficial pedigree and exterior. In the course of their ensuing discussions, he gave her the confidence that she could start a venture capital fund of her own. Elodie credits her mentorship and guidance by Gordon as the tipping point for being willing to set off on the path of starting our own fund. Gordon has been one of the most active people in a position of privilege and power to champion for others who may not have come from wealth, or the right college, or have the right pedigree. I have interacted with many others of similar influence who have done little to nothing at all that did not provide a direct path to further personal riches or the respect of others of equal power and position. Having found himself at the top of his industry, Gordon reached out to bring others up along with him, at no direct benefit for himself and in a manner which made it clear it was not for show or admiration from others. I have had a chance to meet with Gordon in the last few weeks. He has expressed immediate remorse for his actions related to the charges for which he pled guilty. He has taken unequivocal responsibility for them. He blames nobody but himself and expressed to me that it was right that he plead guilty immediately and take responsibility for his actions, and that his one and only goal now would be spending his entire life trying to win back the respect of his community. Professionally, the ramifications of his actions have been grave. I do not know the full details, but Willkie Farr – the firm which he spent nearly his entire career building – has effectively severed its relationship with him. He may be disbarred and never again be allowed to practice law, the field which he loves and in which he has built his proudest achievements. The public shame and humiliation both in the media and in his community have been immediate, harsh, and exacting. I believe Gordon has displayed true goodness in his actions towards others in the past 10 years which I’ve known him. I respect his decision to own up to his actions and plead guilty immediately to the charges upon which he was brought to court. And I believe the punishments Gordon has suffered have been severe enough – professionally, socially, and personally. In light of these three things, I would respectfully urge you to consider leniency in his sentencing. Sincerely, Jessica Davis Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 67 of 175 Tab 26 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 68 of 175 April 23, 20l9 To Whom This May Concern Re: Mr. Gordon Caplan Dear Madam or Sir: My name is Wilbert Davis and I am honored to offer my recommendation for Gordon Caplan who I have known and worked with for over ?fteen years. During this time know Gordon to be a diligent, conscientious and kind person. Gordon is a dedicated family man but he is always willing to help others. Not only does he contribute to more than one community charitable program but from my experience, he always follows up to check on the status of some of them. Gordon is a great person to be around and he encourages others to be the best they can be. His wit is exhilarating, Gordon will find a way to put a smile on your face out ofthe simplest thing. This makes him a unique and invaluable co-worker. it is without any reservation that 1 am providing this recommendation for Gordon. Wilbert Davis Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 69 of 175 Tab 27 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 70 of 175 The Honourable Judge Indira Talwani U.S. District Judge Joseph Moakley U.S. Courthouse 1 Courthouse Way Boston, MA 02210 August 21, 2019 Re: Mr. Gordon Caplan Your Honour: I serve on the board of directors of a publicly listed company1 and have previously served three times as CEO. My line of business is helping with distressed operations. I write about one of your defendants, Mr. Gordon Caplan. I have known Mr. Caplan for 7 years in a professional capacity, and I believe I have had the opportunity to observe him under especially testing circumstances, due to the nature of my work. I have never had any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ase 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 92 of 175 few. However, certain of my experiences with Gordon stick out in my memory, all involving crucial times in my life. First, Gordon was an omnipresent source of support during my divorce and his concern for me and my son was both touching and extremely important. Second, my father, who is very important to me and many others (he currently serves as the President of The Legal Aid Society of New York after a long and distinguished career at Skadden Arps) has been very ill since February 2018. Gordon has been a constant for me during this time and even given his dif?culties he has consistently checked in with me about my father and how we are doing. Finally, Gordon played a similar role following my mother-in-law?s stroke, constantly checking in with me and my wife and offering his help and support. I am a lawyer and I take the rule of law seriously. However, I ask that when you are considering Gordon?s sentence that you take into consideration his outstanding character. Also, Gordon has already been severely punished. I have not spoken to him about his case but he has talked to me about the overwhelming shame and guilt he feels. He has been publicly humiliated and vili?ed, particularly in the legal media and the New York legal community. He apologized to me for his actions because he knows that many people in the New York legal community know we are friends and he worried that my association with him would somehow damage me. (I don?t share his concern). Finally, from what I understand (admittedly not an in depth knowledge) Gordon will no longer be able to practice law in New York (or at least not for a very long time). I have met very few people who have enjoyed our profession as much as Gordon, and not being to do something he both loves and is good at is devastating to him. Finally, I would ask that you to take into consideration that Gordon?s family needs him, particularly his daughter -and his (adopted) son - Please consider the full circumstances of Gordon?s life when deciding on a sentence in this case. He is loved by his family and community and has already paid a very dear price for his actions. Thank you. Very truly yours, William V. Fogg Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 93 of 175 Tab 35 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 94 of 175 WILLKIE FARR 8: GALLAGHER l.l.l? .. June 4, 2019 The Honorable Indira Talwani John Joseph Moakley United States Courthouse 1 Courthouse Way, Suite 2300 Boston, MA 02210 Dear Judge 'l?alwani: I am a partner of Willkie Farr Gallagher, which has been my professional home for more than 35 years. My partner. Tom Cerabino, and I have managed the Firm for ten years. I write this unsolicited letter on behalf of my friend and former partner, Gordon Caplan. While Gordon?s conduct was reprehensible, both to his family and as a member of our Firm and the NY bar, I hope this letter sheds some light on other, more favorable, aspects of Gordon Caplan. I?ve known Gordon for more than 17 years, having recruited him from another major ?rm tojoin our Firm given his reputation and expertise. I consider Gordon to be a friend, and professionally Gordon fully supported and assisted me throughout my 10-year tenure leading the Firm. In addition to managing a busy practice, Gordon was an active member of our Executive Committee and led many of our Firm?s initiatives over the last few years. Over the course ofhis career at Willkie, Gordon managed relationships with a number of our important private equity and corporate clients, guiding many of them through challenging economic times and extremely sensitive issues. His success was in no small part due to his exceptional commitment and dedication to his clients. Along with his success working on behalf of clients, Gordon became a leader at Willkie, and a mentor to many young partners and associates. They learned from Gordon what it means to be truly dedicated to your clients and to be a zealous advocate for their interests. He cared passionately about the Firm and its success and worked with all of our partners to assist them in developing their practices. To say he was a force of nature would be an understatement. His passion for excellence and client service goes along way to explaining why so many of his clients stuck by him throughout the years and continue to express to me their support and concern for Gordon, notwithstanding recent events. Niwi'uux Hut-sum l?uus Loxnox litu'ssr'ts n\llEA.\' Rostr- Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 95 of 175 The Honorable Indira Talwani John Joseph Moakley United States Courthouse une 4, 2019 Page 2 You should be aware of the enormous outpouring of support I and other Firm leaders received from Gordon?s clients after the announcement relating to his misconduct, including his guilty plea. We received dozens of calls from clients and others with whom Gordon had a professional relationship. While no one defended his conduct, his clients were, without exception, extremely appreciative of Gordon?s commitment to them, and genuinely concerned about his personal and family?s well-being. This support came from people at public companies, regulated institutions, private companies and individuals. It reflected the high regard with which they held Gordon as a friend, a zealous advocate and a smart and thoughtful legal adviser. Your honor, I am a corporate lawyer by training and practice; I?ve never been involved in sentencing or related issues involving criminal conduct. As I noted earlier, I do not excuse Gordon?s actions they were stupid, albeit motivated solely for the bene?t of his daughter whom he loves more than anything in this world. I would ask you to consider in your sentencing deliberations the fact that Gordon has suffered massively as a result of his misconduct. He will lose his license to practice law as a result of this matter. And although one can certainly expect more of an of?cer of the court, I would respectively request that you consider that Gordon has lost the ability to continue working at a Firm he loves, and has severely affected his relationship with his daughter and other family members. His public apology was heartfelt, sincere and anguished, and he sought to blame no one but himself. He has in the past and continues to engage in public service for those less fortunate. As one of our ?rm?s strongest supporters of pro bono work, Gordon worked on pro bono matters himself and acted as a mentor throughout his career, encouraging our younger attorneys to get involved in public service. Knowing Gordon as I do, he will likely make it his life?s work to redeem himself in the eyes of his former partners and clients, and his family. I hope the foregoing is helpful. Sine ely, Steven J. Gartner Chairman 297512223 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 96 of 175 Tab 36 Case 1:19-cr-10ll7-IT Document 490-1 Filed 09/26/19 Page 97 of 175 .- May 14, 2019 Re: Character Reference for Gordon R. Caplan Dear Your Honor: It is with sadness that I am writing this letter to you, but at the same time, I believe it is important for Your Honor to get a sense of Gordon Caplan?s character other than through the lens of what has transpired over the past few months. I have known Gordon for approximately 12 years, since I was a junior associate at Willkie Farr Gallagher LLP. Early on in my legal career, Gordon was looking for an associate to work on an interesting matter with one of his clients and I jumped at it. That one assignment and the chance to work with Gordon made my legal career what it is today and had a profound effect on it. From that time forward, I got to know Gordon well, both professionally and personally. Working on Gordon?s team did not mean he was a senior ?gure who didn?t bother with junior associates. Quite the contrary - I worked closely with him on many matters and learned how to be a lawyer from him. It did not make a difference whether it was 9 A.M. or 1 A.M., he was there for support and guidance. We all knew Gordon was a fabulous lawyer and advocate for his clients and the level of dedication he gave to them, but what I did not know was the level of personal interest he took in my growth. After I left Willkie Farr, I joined one of Gordon?s clients as Chief Compliance Of?cer and Deputy General Counsel. I knew the challenge that was forthcoming with that new role and that the decisions and recommendations, both legal and ethical, I would need to make and give would not be easy, but I knew Gordon would be there for me. And he was. Always. Knowing I could lean on him was comforting and I never second guessed any advice he would give. There were times when decisions required more than legal analysis - whether something was the ?right thing to do? and Gordon always thought of that. In light of the relationship I built with Gordon over the years, he and his wife Amy were invited to my son?s bar mitzvah, an important time of my life which I wanted Gordon to share with me and my family. I treasure relationships and this one was one I wanted to keep. 1 was saddened by the news in the media about Gordon and the case before Your Honor. Given the interest he took in me, I can only imagine the love and devotion he has for his family. Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 98 of 175 GOODWIN May 14, 2019 Page 2 Thank you Your Honor for taking my and others? thoughts into consideration in connection with Gordon?s case. I would be more than glad to provide any additional insight about Gordon should you need it. $an Eric C. Goldstein, Esq. Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 99 of 175 Tab 37 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 100 of 175 September 21, 2019 The Honorable Judge Indira Talwani U.S. District Judge Joseph Moakiey U.S. Courthouse 1 Courthouse Way Boston, MA 02210 Your Honor, My name is Robert Greebel and have known Gordon Caplan for over 13 years as a skilled advisor and supportive friend. The acts to which he pied guilty are disappointing, to say the least, but his willingness to be held accountable for his mistake is commendable. Please do not think this is the man I know. He has always demonstrated a high degree of ethics and morality; I believe he lost his way during an unfortunate series of events. My relationship with Gordon developed while he served as outside counsel to a team 1 used to work with. regularly sought his advice and candid assessments on various complex situations. Gordon was very attentive while demonstrating sound and conservative guidance. Over time, we developed a friendship. Unlike many professional relationships that have a friendship component, Gordon?s actions over many years showed it was a genuine friendship. When my family experienced a very complex and unfortunate development, Gordon was one of the first to express his support. He checked on me regularly and offered his assistance for many years. Separately and to my pleasant surprise, when was exploring career opportunities, Gordon opened his rolodex and made important introductions. He went out of his way to recommend me on numerous occasions without my knowledge. It is clear to me that Gordon likes to help people and this is a core component of his personality. Gordon often spoke of his family and especially his children. They are the most important people in his life. Unfortunately, he took his desire to help too far. He crossed a line that did not need to be crossed. Gordon and have spoken regularly since his arrest and had dinner recently. He is a humbled man who clearly understands the impropriety of his actions and thoroughly regrets the decisions he made. He has suffered an incredible loss aiready. He has lost his livelihood and professional career that took over 25 years to build. There is no going back for Gordon and only ask your Honor to show him as much leniency as possible. A sentence of community service will allow him to help those less fortunate and turn this negative into a positive. Thank you for your consideration and time. Sincerely, Robert Greebel, Esq. Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 101 of 175 Tab 38 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 102 of 175 Cliff Griffin Dia Barman-Griffin July 29, 2019 Re: Gordon Caplan The Honorable Judge Indira Talwani, We first met the Caplan family when our kids started nursery school together, 14 years ago. The Caplan's were the first family we met when we moved to Connecticut and in a very short time became one of our closest and dearest friends. We will never forget how kind Gordon was when we lost electricity during Hurricane Sandy. He lnsisted we stay at their home until our electricity was restored. However busy he was he always took time out of his busy schedule to spend time with his friends and family. Be it a call from us to Gordon to let our baby-sitter back into the house when she locked herself out, he is always there to lend a helping hand. We have traveled extensively with the Caplan?s and celebrated many holidays, family birthdays and Wedding Anniversaries. Through good times and dif?cult times, Gordon remains a true and genuine friend, someone we can always count on. We have attended several Charity events with Gordon and have noticed his financial and time commitment to these organizations. He is someone who cares about the less fortunate. Gordon was a volunteer Flag football coach for his son's team and has been actively involved in his daughter's tennis training and competition. Always encouraging and motivating not only to his children but all of our kids to reach their fullest potential. Gordon is our good friend and confidant a doting father and family man, with a wry sense of humor and wry wit. He is adored by our kids and well respected by all of us. ?w . ri?e-Qi- Cliff Grif?n Dia Barman-Grif?n Sincerely, Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 103 of 175 Tab 39 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 104 of 175 Nicholas M. Grumbach, MD. April 21, 2019 Your Honor, I work as a physician-educator caring for children and adults, including refugees and transgender patients, in an outpatient clinic in Providence, RI as a member ofthe Brown University Medical School faculty. I see my own panel of patients and also teach medical residents and students. i am writing this letter with the hope that you will be lenient in sentencing my friend, Gordon Caplan. I have known Gordon since he entered elementary school in ?fth grade, becoming good friends as we attended school through 12th grade together. Over the years since graduation, despite having busy family and work lives, we have remained close and keep in touch regularly. I characterize Gordon as a devoted husband and father of two children, a loyal friend, and a hard-working and trusted lawyer. Over the years, due to my expertise as a pediatrician some of our interactions have related to questions and worries that Gordon and his wife, Amy, have had regarding their children- This may have been hard for Gordon to broach as he is a proud father and is protective of his family, but he did so nevertheless out of his parental concern. Gordon has demonstrated his willingness to help others who have made mistakes or who have been in dif?cult situations. In addition, I called Gordon not so long ago when my own son? My wife and our family will never forget the help that Gordon has provided. Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 105 of 175 I know that Gordon feels terrible about the mistake and lapse of judgment he has made. He realizes how wrong and unfair it was, and how damaging this has been to his family and to his own self-respect and reputation. Gordon is devoted to his family and I know that any time in prison will be devastating to them. I hope that you can appreciate how remorseful he feels and that you will be lenient and thoughtful of the Caplan family with your sentencing decision. I am happy to provide further information should you require it. Sincerely, Nicholas M. Grumbach, MD. Clinical Assistant Professor of Medicine and Pediatrics The Warren Alpert School of Medicine of Brown University Providence, RI Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 106 of 175 Tab 40 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 107 of 175 WILLKIE FARR GALLAGHER up 787 Seventh Avenue New York NY 10019?6099 May 20. 2019 The Honorable Judge Indira Talwani United States District Court of Massachusetts John J. Moakley US. Courthouse 1 Courthouse Way. Suite 2300 Boston. MA 02210 Re: Gordon R. aplan Dear Judge Talwani: I have worked with Gordon aplan since 2003 when I joined Willkie Farr Gallagher LLP. and I write this character reference letter to express my for him. Over 16 years I worked with Gordon almost daily, ?rst as an associate and for nearly seven years as his partner. I have not only developed a great respect for Gordon as an attomey. but as a skilled business and strategic advisor for his clients, as well as his family. ?'iends and colleagues. I consider Gordon a mentor. partner and a close personal friend. Gordon taught me to be a lawyer. and showed me what it meant to be devoted to serving oru' clients. He truly exempli?ed client service. When the news of Gordon?s troubles broke. I spoke to many of these clients in the days that followed. Unsure of what to expect. given our profession is one based on trust and accountability. I found rmwavering support from each person with whomI spoke. Their surprise at the news did not lead them to question the advice he had given. or the service he had provided. because they all know that Gordon?s actions were based in love for his family, not contempt for the law. Those that know him. know that man that he is. The skills that have made him successful in his practice. also made him the person that people ttun to when in need, whether it be personaL business or otherwise. His generosity with his time and advice is boundless. He is not only intelligent. but has a huge heart. When my wife and I had our ?rst children. Gordon not only made it possible NEW YORK WASHINGTON HOUSTON PALO ALTO PARIS LONDON FRANKFURT BRUSSELS LIILAN ROME Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 108 of 175 29544567.l for me to take as much time as I needed, he made it clear to me that family comes ?rst, even above the demands of our dif?cult job. I learned early on that Gordon was more than just a successful lawyer, at the top of his profession. When I was a y01mg associate and did not yet know him well on a personal level, he asked me if I would be interested in volunteering to help paint a school as part of a charitable organization with which he has been involved helping youth in New York City?s schools. My wife and I jumped at the chance to spend some time outside of the office with the co-Chair of my ?rm. It was then that I was introduced to the generous family man that he is, as I watched him help his yormg son help others who were less fortunate. Over the years he opened 11p to me on the challenges of parenting, and balancing the demands of a job that can be overwhehning at times. In the past couple of months, Gordon has expressed to me great remorse and genuine regret for his actions. In our conversations he never once tried to minimize what occurred, and it has been clear to me that his decision was an emotional one, driven by a desire to help his daughter. In each of our discussions, he has been focused on how others may have been effected, not on his own fate. As a father, I understand that when it comes to our children, sometimes decisions get made with our emotions instead of the head, as they are matters of the heart. Thank you, Your Honor, for taking these thoughts into consideration as you deliberate on the outcome of Gordon?s case. I stand ready to provide whatever additional assistance or support that may be helpful. Respectfully, Matthew J. Guercio Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 109 of 175 Tab 41 Case 1:19-cr-101l7-IT Document 490-1 Filed 09/26/19 Page 110 of 175 iliilw i. Hiidid May I6, 2019 RE: Mr. gorggn R. Qaplan To Whom It May Concern: I am writing on behalf of Gordon Caplan. Mr. Caplan and have been close work colleagues for over ten years. In this time, I have seen many aspects of Mr. Caplan?s personality, and I ?rmly believe that he is a principled man of outstanding moral character. My experience with Mr. Caplan spans more than a decade of grueling hours and intense pressure working ?rst, for him, and then, alongside him, at a large corporate law ?rm. Mr. Caplan took me under his wing as a law clerk in my ?rst months on the job, and he ultimately made me his partner nearly 10 years later. During this time, I knew Mr. Caplan as a man of admirable character and integrity who cared deeply for those around him. Whether it was his family, his clients, his colleagues or his friends, Mr. Caplan?s generosity and loyalty knew no bounds. More importantly, in giving 100% to his work and to those around him, I never once saw Mr. Caplan act immorally, unethically or untoward. Indeed, in the rare instance a client would suggest taking an action that Mr. Caplan considered disingenuous or worse, Mr. Caplan immediately and unequivocally would steer. the client back onto a path of truthfulness and candor. Mr. Caplan is known for being an aggressive attorney that relies on his ?gut? instinct; in my over ten years of experience with Mr. Caplan, that instinct has been entirely honorable. I can also tell you without a doubt that Mr. Caplan is incredibly remorseful for what he has done. In both his public and his private statements, he has made this very clear. As a father myself, I understand how blinded by love one can be when it comes to matters of family. Surely, any parent understands this. What was certainly a temporary lapse in judgment borne entirely out of his undying love for his daughter has cost Mr. Caplan his relationship with that daughter, his career, and his reputation - truly a heavy price to pay. i understand that Mr. Caplan now faces the possibility of incarceration for this lapse in judgement. While I do not envy the decision the court must make in regards to such a serious matter, it is my hope that this letter and my testament to Mr. Caplan?s character will help the court when it considers an appropriate sentence. 1 remain proud to call Mr. Caplan my partner and friend. Sincerely, Matthew J. 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Lesser April 11, 2019 Your Honor: I have known Gordon aplan for nearly 35 years. We attended both college and law school together. Gordon and I have stayed in periodic contact over the years. I will always remember Gordon as a supportive and kind person on whom I knew I could always depend. After law school, we remained in contact although oru' busy careers and young families took us in separate directions. Gordon is devoted to his family; his children are the light of his life. We came together when a very close friend of ours was diagnosed with Acute Myelogenous Leukemia. She passed away in 2011 but Gordon?s kindness and support of our friend during her illness and his outreach to me a?er her death were a reminder of his thoughtfulness, compassion and humanity. In addition to his devotion to his family and friends, Gordon has worked very hard to become a very capable lawyer. I hope the 01111 would consider leniency in Gordon?s sentencing for the sake of his children and so that he may direct his considerable talent toward making a positive difference. Thank?you. 7% Danielle C. Lesser Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 131 of 175 Tab 51 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 132 of 175 Douglas A. Lindgren July 3, 2019 The Presiding Judge Boston Federal Court YourHonon I am providing this character reference on behalf of Gordon Caplan. I have known Gordon since the mid 19905 when I met him in a professional capacity. During the years that followed, he provided me with outstanding legal and business advice and became one of my closest advisers. Over time, I got to know Gordon on a more personal level, and we forged a personal friendship that complemented our professional ties. I have known Gordon to be a man of admirable character who always looked out for the best interests of his clients, his colleagues, his friends, and his family. I have a great deal of respect for him on a personal and professional level and am proud to call him my friend today notwithstanding the well?publicized, life-changing mistakes that he made in relation to the ?Varsity Blues? case. In advance of a recent trip to New York recently, I reached out to Gordon to see if he wanted to have dinner. I wanted to see how he was holding up after seeing his world crash down on him. I didn?t know if he would want to see me or anyone else for that matter under the current circumstances, but I hoped I would be able to see him and remind him that aside from his highly regrettable entanglements with Rick Singer, he has lived an exemplary life. He responded quickly and af?rmatively to my dinner invitation. When we met, I reminded him that he is one of the "good guys" in this world. He has always tried to do his best for the people in his life and has always been extremely generous. Sadly, it must have been his admirable desire to help his daughter realize her dreams that led him to Mr. Singer and the mistakes that followed. He had trouble accepting my compliments as he can't stop beating himself up over what he did. He is deeply remorseiul and embarrassed, but he knows that he cannot change the past and must somehow move forward. Gordon?s actions in relation to the case before you are inexcusable and Gordon has paid a heavy price for them by seeing his highly successful career and stellar reputation ruined. However. I am hopeful that he will be able to get past all of this and put his many talents and admirable qualities to good use in a way that may create something positive out of this terrible situation. Speaking honestly and publicly about what he did and apologizing to his daughter and all the students and parents currently in the admission process on national television was a great step forward. Over time, I am con?dent that he will ?nd ways to make it up to his daughter and to society at large. I hope the court will consider Gordon?s pristine record and this character reference at the time of sentencing. If you would like me to elaborate on any of the above or if I can assist in this matter in any other way, please do not hesitate to contact me. Douglas A. Lindgren Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 133 of 175 Tab 52 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 134 of 175 April 25, 2019 To Whom It May Concern: I was introduced to Gordon through a contact in my professional network, as I was seeking a paralegal position before applying to law school. I told him about my background as a first-generation college graduate, how I was interested in becoming a lawyer and how I wanted an opportunity to work hard and prove myself in the real world. He was very receptive and understanding and fully supported me throughout my interview. During and since my time at Willkie, Gordon has been an important mentor in my life, offering his guidance on everything from law school to professional development. I began working at Willkie right after my graduation from Princeton in 2016. While at Willkie, I worked on various projects, including corporate deals as well as pro-bono matters. Although we were both very busy, I made sure to update him about how things were going and how much I was enjoying my time at Willkie. I was occasionally staffed on a few of his projects alongside other associates, and I always made sure to put my best work. I would volunteer to do additional research for him and made sure to follow through with my responsibilities. As I was gearing up to begin applying to law school, I spoke to him about where I was applying as well as my future career plans. One thing that stood out to me was his encouragement that I consider applying to Fordham Law School and how he enjoyed his time there. He highlighted the “practice-ready” nature of the school and the strong alumni network in New York City. Whenever I ran into Gordon, he would always urge me to consider Fordham Law and to visit the school. I took his advice and visited the school, and he was right. After I applied to law school and thought about my career pathway, Gordon continued to provide career guidance and advice on law school, emphasizing the importance of client relationship and hard work. In the Spring of 2018, as decisions came in, I gleefully shared my acceptance to Fordham Law with him and immediately committed. I was excited for a new opportunity at Fordham and aspired to return and work for Gordon. During my two years at Willkie, I looked up to Gordan Caplan and he was an important mentor who constantly provided me with law school and career advice. He gave an opportunity to work hard and learn more about becoming a lawyer. No matter how busy he was, he was willing to speak with me and ask me about how I was coming along. He gave me an inside look into the world of lawyering as well as the business world. Although we both come from very different worlds, he listened to my story and helped achieve my American Dream of one day helping my family and serving my community as an attorney for change. Respectfully yours, Kevin Lopez Fordham Law ’21 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 135 of 175 Tab 53 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 136 of 175 Gerard Mattie July 27, 2019 Regarding: Mr. Gordon Caplan The Honorable Judge Indira Talwani US District Judge Joseph Moakley US Courthouse 1 Courthouse Way Boston, MA 02210 lam writing on the behalf of Gordon Caplan, to share my appreciation of Gordon?s character and to seek consideration of leniency in his sentencing. I ?rst met Gordon and his family when our children attended preschool together over 15 years ago. Our children quickly became friends and over the years we have become best friends, sharing countless family holidays and life experiences. In this time, he has proven to be of ?ne and responsible character- Gordon is known for being a dedicated husband, father and son; and a truly good friend who so many of us rely on for insights and personal counsel. Someone I trust. As an upstanding member ofthe community this serious incident of poorjudgment was quite surprising to those of us that know Gordon well. Over these 15 plus years, i have seen firsthand Gordon's true character. I can point to numerous examples of his generosity and kindness. Gordon is a wonderfully caring father, husband and friend. Someone who routinely puts his self-interests aside in favor of helping a friend, colleague or even brief acquaintance. The person that has always been someone I can count on, even without asking. to be there in a moment ofneed. The person that immediately reach out across his network of friends to find us the best doctor to treat our son when he was Struck by a car while riding his bike. The one that got mejob interviews when I was considering a career change. Known for his unparalleled work ethic yet making time for those special father moments ?whether it?s attending his daughter tennis events orjust dropping everything to take a bike ride with his young son. Beginning with his sincere public apology, and since his steadfast and resolute demeanor in moving past this clearly demonstrate his taking responsibility. As a friend I know how much he cares for his family and how concerned he is for their wellbeing. I believe he was stressed and somewhat overwhelmed with concern for his daughter?s future. This is the only explanation I can find to reconcile this slip in judgement with the Gordon Caplan I know. Gordon called me shortly after pleading guilty, i could hear the discomfort in his voice, he was embarrassed and sincerely disappointed in himself. He apologized for letting us down. He explained how disappointed his father is, the challenges he has brought to his relationship with his family. He Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 137 of 175 The Honorable Judge Indira Talwani July 27, 2019 Page 2 talked about his immediate focus on building back their trust, our trust in him. Through this discussion, and further conversations since, I can see the sincere remOrse and regret that he will now carry with him forever. I hope you take this into consideration as you consider his fate. Sincerely, Gerard Mattie Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 138 of 175 Tab 54 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 139 of 175 April 25, 2019 Your Honor, I am writing in regard to my very dear friend, Gordon Caplan. Gordon is my husband?s oldest friend and they have been friends since the 2nd grade. I was introduced to Gordon more than 25 years ago and he has since become one of my closest friends, closer to me than my own brother. I have spent so much time with Gordon and his family and have relied on him in every way. During my happiest and darkest moments, Gordon was there for me every step of the way. A visit, call and ?owers durin- as a groomsman in my wedding, at the birth and bris of my son, an ear and help when my own parents became very ill, work advice, home advice, andloouldgoonandon. All of this is to say that my life and my family?s life will change for the worse without Gordon in it. Moreover, Gordon brings such happiness and enthusiasm to his family that I am devastated in thinking about the chance of his not being there and having such an incredible positive impact. He has always been an active member and giving back to the communities he has been a part of. He has been incredibly active with Publicolor, an organization dedicated to making high school children's lives better. I therefore ask you for leniency with regards to Gordon, and I would be happy to provide more insights at any point Thank you. Allison Musrna Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 140 of 175 Tab 55 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 141 of 175 Your Honor, I am writing on behalf of Gordon Caplan. Gordon Caplan and I have been friends for almost 50 years. He is my oldest friend. We met in second grade. He has been a generous and dedicated friend, in childhood and adulthood. He has been available to discuss both trivial and important matters - and to help me/my family in any way. When my mother was ill and dying after a long (rare) illness he was a constant - a constant shoulder to lean on and a constant avenue for help, be it asking about nothing important or critical health matters, what could he do to help, was a constant question? Call me if you need anything at all? And he did help in words and actions and knowing I could count on him was a tremendous help in terms of peace of mind. I have seen him offer this type of generosity many times over the years. So many times unknown to anyone because he never wanted any reward beyond helping. More overtly, he has volunteered countless hours to Publicolor which helps high risk students. He is a giving presence - to others and his family. I cannot imagine being without him or, most importantly, his family being without him even for a short period of time. infra Fraser Mu ma Case Document 490-1 Filed 09/26/19 Page 142 of 175 Tab 56 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 143 of 175 134.33 8: tau: 3?5 Motors: May 24, 2019 Your Honor, I write this letter with the hope of providing you with some useful insights into Gordon Caplan?s character and state of mind. Let me introduce myself. Until this recent resignation from the Firm. 1 was a Partner ofGordon?s at Willkie Farr Gallagher LLP, and was Firm Chaimtan for 23 years, from 1987 through 2010. I was instrumental in hiring Gordon. and since the day he joined us, he has been a great colleague but most ofall. a trusted friend. Gordon is an exceptional lawyer. As such, he built the largest practice in the inn, and all of his clients to this day are supportive of Gordon and mysti?ed by the actions for which he has been prosecuted. Gordon has been everything that a lawyer should be. Devoted to his clients; a consummate professional; a champion of gender and racial diversity and a leader by example of ?giving back? through his many pro bono activities. Gordon brings the same zeal and drive for success to his family life. He is exceptionally devoted to his wife and children, all of whom I know well, and all oi?whom are devastated by his present circumstances. While there is absolutely no excuse for what Gordon did, I know that he is acutely aware ofthe unethical and illegal conduct he engaged in on behall?of his daughter. As I am sure you know, he made a very public apology and expression of contrition to those he harmed (and there were many), but in private conversations. it is even more clear that if ever one learns from his mistakes and does whatever it takes to rectify those mistakes, Gordon has learned and will do anything possible to atone for his misdeeds. Gordon is not only publicly humiliated as a result of his actions and his guilty plea, but he is also suffering the ultimate penalty for a lawyer, which is loss of his license to practice. Not only has that license been the basis for his sole source ofincome over the years, but with its loss comes the loss o?l?a stellar reputation built brick by brick over many years of practice. limiting llt'ittst'm. Putts Faisal-tut Roast. ?i i'imrst'or: 359.1115 Lamaze;- lirttr-tict'trm Bitumen mater; Rome Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 144 of 175 May 24, 2019 Page 2 Your Honor, as a fellow member of the Bar, I recognize the seriousness of Gordon?s actions and hope and expect that they will act as a reminder to all lawyers that as of?cers of the Court, integrity and compliance with the law are fundamental values that must be adhered to. Given the loss of his law license: the loss of earning power associated with it, and the public and private humiliation which Gordon has suffered and will continue to live with for the rest of his life, hope you will weigh all the good that is Gordon against his one overzealous and inexcusable and misguided effort to help his daughter, and reach the conclusion that he has suffered suf?cient punishment. Sincerely4m,? Jack H. Nusbau Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 145 of 175 Tab 57 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 146 of 175 Your Honor, My name is Stanley Ouimette. I am a retired GreenWich Connecticut Police Detective. After sewing almost 30 years, I retired and began working for the Caplan family I have been with the family more than 8 years During this time. I have Witnessed Gordon?s devotion to his family and he made me feel like a family member rather than a worker I a55ist the family with their daily actiVities as well as manage and maintain the families property, I have had numerous conversations over the years With Gordon regarding his family. I have found that Gordon IS a very devoted father to his two children and demonstrates that on a daily His Son? looks up to his father for guidance and support and relies heaviy on him This admiration is a direct re?ection of his fathers involvement in establishing good moral and values. When-was interested in playing ?ag football Gordon did not heSitate to become involved. Even with Gordon's busy work schedule and responsibilities, he was able to find the time to coach the football team. Gordon daughter - now 17 IS a typical well grounded teenager I have raised ?ve daughters and understand the stresses of raismg teenage daughters I have witnessed Gordon raising - over the past years and like_ is a very compaSSionate and caring person Gordon?s children are always respectful and well mannered This, I believe is a result of good parenting Because of the children's ages it is even more important to have Gordon remain a constant influence on them As a Detective I worked in the SpeCial Victims Unit with cases involving many troubled youths. I met With many of the parents and learned over the years that most of the problems could be traced back to lack of parenting. I understand that Gordon has broken the law. I also know that it was not a violent offense and Gordon?s intent was never to harm anyone. Gordon was only trying to aSSist his daughter who was over stressed With the testing process. In a bnel moment in his honorable life he made bad choices With his heart and devotion to his daughter instead of using his head Since his arrest. I have Witnessed Gordon's life crumble around him. He has been unable to work and with this media attention unable to maintain a normal life outside the house in the community I know this letter Will be one of many asking your honor to look past the charge and at the man before you. I feel I am in a uniQUe position. as I am close to the private and public Gordon. have found this man is a good honorable man and someone I respect. He has taken responsibility for his action and I have Witnessed his heart felt feelings of remorse. Not that he was arrested but rather for harm he caused to others in his life such as co-workers. friends. family, and most importantly his daughter- At no time. have I Witnessed Gordon say he feels sorry for himself and his main concern is that of his children. When making the de0ision please consider that his son and daughter will be devastated and without his law license he will Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 147 of 175 lose his ability to provide for his family. This is a man who has lead a honorable life up to this brief moment of weakness. I hope that a man is not judged heavin on one bad decision but rather the totality of his life's works. Please feel free to contact me at anytime, as I have so . many other things that I could say in this letter. l. Yours Truly, Stanley Ouim - 1?7? .- Retired Greenwich Police Detective Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 148 of 175 Tab 58 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 149 of 175 April 25, 2019 TO WHOM IT MAY CONCERN RE: GORDON CAPLAN Dear SirfMadam, My name is Fred Reid and I work in the Mailroom Department of Willkie Farr Gallagher. I have known Gordon for approximately 16 years. During this time Gordon has been extremely kind and courteous to me. I felt that I could approach Gordon at any time without issue. He has always had a great sense of burner and made me feel included. I give this recommendation without hesitation. WKJ Sincerely, Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 150 of 175 Tab 59 m/N?o? 8 9m @e 151 of 175 Certi?ed Public Accountants July 31,2019 The Honorable Judge Indira Talwani US District Judge Joseph Moakley US Courthouse 1 Courthouse Way Boston. MA 02210 Your Honor; have known Gordon Caplan both personally and as his accountant for almost 20 years. During this period I have watched him grow as an individual and develop a deep caring for others as well as a drive to exceed at what he puts his mind to. On a professional level he has always been diligent and conservative in my dealings with him especially in the preparation and ?ling of his tax returns. Unlike many others, he will take the time to carefully review his return. make sure all income is properly reported and no deduction taken that is not appropriate. I have known him to be charitable not only with money but also with his time. He generously donates to public charities as well as he helps others privately. This is a man of both substance and good character. His actions before you are inconsistent with the man who I know him to be. I can only account for his actions as a temporary lapse in judgement, due to the deep love he has for his children. Everyone deserves a second chance. In my conversations with him he has expressed deep remorse. I strongly believe that he truly is regretful as to his actions and has learned from his mistake. He has already been punished and lost much due to this matter and to punish him further would be unfair, unnecessary and disproportionate. Please allow him to continue to exceed as an example to others and for all the good he has done and can continue to do. I pray for the Court to be as lenient as possible in determining its sentencing and further punishment of him. Respectfully submitted; Shufrin, CPA 155 EAST 55m STREET, SUITE 204. NEW YORK. NY. 10018 - Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 152 of 175 Tab 60 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 153 of 175 April 29, 2019 YourHonon I am a gynecologic oncologist and have spent the last two decades caring for unfortunate women diagnosed with cancer. Early in my medical career, I was at a point where I needed guidance. A mutual friend put me in touch with Gordon Caplan who then introduced me to his father, a prominent gynecologist in New York. This ultimately led me to pursue my current career path. I was a stranger to Gordon, but he went out of his way to make this connection and help me. Certain acts of kindness are always remembered. Thus, I am writing this letter with the hope that you take such acts into account when judging him. As an academic gynecologic oncologist, have the responsibility of overseeing the education of residents and fellows. During floor rounds, tumor board conferences, and in the operating room, I discuss patient management with the junior members ofthe team. As physicians, our goal is to help patients, but occasionally, junior physicians can make decisions in haste. During my own training, I experienced how such decisions could anger my superiors. ?Malignant? attendings were those who berated their juniors. However, I tend to take a different approach when educating my fellows and residents. I have found they learn best when they are forced to reflect on how their decisions can impact a patient?s life whether it be in a positive and negative manner. I truly believe this will leave a more memorable mark and make them a better physician in the future. Since our initial meeting over twenty-five years ago, I have gotten to know Gordon. When Hurricane Irma devastated Puerto Rico, he was there to support friends and their families in need. I know he wishes he could turn back the clock. Certainly, we have all made poor decisions in haste, and we must live with the ramifications of such. Gordon?s lapse in judgement will forever haunt him and his family. He is a good hearted human being, and I ask that you be lenient when deciding on his sentence. Sincerely, I Yukio Sonoda, MD Attending Surgeon, Memorial Sloan Kettering Cancer Center Professor, Weill Cornell Medical College Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 154 of 175 Tab 61 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 155 of 175 William Stellmach August 22, 2019 Hon. Indira Talwani United States District Court Judge John Joseph Moakley United States Courthouse 1 Courthouse Way, Suite 2300 Boston, MA 02210 Re: Gordan Caplan Your Honor: I am writing on behalf of my friend and former law partner, Gordon Caplan. As a former federal prosecutor, I recognize that there are likely few decisions more challenging than the ones a sentencing court faces, particularly in attempting to place someone?s criminal conduct in the greater context of their life and character. Here, I think that must be especially dif?cult given the widespread and justifiable outrage? which I fully share?which the criminal charges have prompted. But I also know that Gordon is much more than the person who, out of what I believe was misplaced guilt and love, acted in the way described in the public allegations. I first met Gordon when I joined our ?rm in September 2015, fresh from the Justice Department, and seeking to build my own practice after spending virtually my entire career in public service. I was new, I had no clients and I was operating in a satellite of?ce. Gordon made a point to befriend me and integrate me into the ?rm, which included joining me on a business trip to help develop my marketing and calling me from time to time on matters for his own clients. While I never worked extensively or even regularly with Gordon?my practice and his did not intersect very much?he was assiduous in soliciting my views on the firm and ensuring that I felt like I belonged. That is a rare quality, particularly in the hectic and fast-paced world in which law ?rm partners operate. There was absolutely no upside to him in investing any time in me, other than he took my success and integration seriously. Demanding and driven, Gordon always struck me as hardest on himself, and I found him a generous colleague and friend, quick to offer constructive criticism and praise. Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 156 of 175 I can also attest that there is no one who was more driven or committed to our ?rm, and, knowing him as I do, I can imagine the anguish which he has experienced at effectively having to abandon that world forever. After spending much of my professional life reading and responding to letters like this, I recognize that there are a number of factors which weigh in the calculus which Your Honor is undertaking. I do not envy that decision. But I would ask you to consider that, from my experience, Gordon is a person who gave without asking or expecting anything in return, and showed many kindnesses, big and small, which speak to an underlying strength of character and spirit which this case should not obscure. Sincerely, William I. millmach Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 157 of 175 Tab 62 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 158 of 175 DĂLJ ϮϭƐƚ͕ ϮϬϭϵ zŽƵƌ ,ŽŶŽƌ͗ DLJ ŶĂŵĞ ŝƐ DŝŬĞ dƌŝƉůĞƚƚ ĂŶĚ / Ăŵ ŽŶĞ ŽĨ ƚŚĞ DĂŶĂŐŝŶŐ ŝƌĞĐƚŽƌƐ ŽĨ /ŶƐŝŐŚƚ WĂƌƚŶĞƌƐ͕ ĂŶ ŝŶǀĞƐƚŵĞŶƚ Ĩŝƌŵ ƚŚĂƚ ĨŽĐƵƐĞƐ ŽŶ ŝŶǀĞƐƚŝŶŐ ŝŶ ƐŽĨƚǁĂƌĞ ďƵƐŝŶĞƐƐĞƐ͘ / ŚĂǀĞ ŬŶŽǁŶ 'ŽƌĚŽŶ ĂƉůĂŶ ƐŝŶĐĞ ϮϬϬϮ͕ ǁŚĞŶ ŚĞ ǁĂƐ Ă LJŽƵŶŐ ůĂǁLJĞƌ Ăƚ tŝůůŬŝĞ &Ăƌƌ Θ 'ĂůůĂŐŚĞƌ͕ Ă ůĂǁ Ĩŝƌŵ ƚŚĂƚ ĚŽĞƐ ŵƵĐŚ ŽĨ ƚŚĞ ůĞŐĂů ǁŽƌŬ ĨŽƌ ŵLJ Ĩŝƌŵ͘ &Žƌ ƚŚĞ ƉĂƐƚ ϭϳ LJĞĂƌƐ͕ / ĚŽŶ͛ƚ ƌĞĐĂůů ĨŝǀĞ ĚĂLJƐ ƉĂƐƐŝŶŐ ŝŶ ǁŚŝĐŚ 'ŽƌĚŽŶ ĂŶĚ / ĚŝĚ ŶŽƚ ƐƉĞĂŬ͘ KŶ Ă ƉƌŽĨĞƐƐŝŽŶĂů ůĞǀĞů͕ 'ŽƌĚŽŶ ŝƐ ŽŶĞ ŽĨ ƚŚĞ ŵŽƐƚ ƚĂůĞŶƚĞĚ ůĂǁLJĞƌƐ / ŚĂǀĞ ǁŽƌŬĞĚ ǁŝƚŚ͘ /Ŷ ŵĂƚƚĞƌƐ ƌĂŶŐŝŶŐ ĨƌŽŵ ĚĞĂů ƐƚƌĂƚĞŐLJ ƚŽ ĞƚŚŝĐƐ͕ 'ŽƌĚŽŶ ǁŽƵůĚ ďĞ ƚŚĞ ĨŝƌƐƚ ƉĞƌƐŽŶ / ƐŽƵŐŚƚ ĐŽƵŶƐĞů͘ DŽƐƚ ŽĨ ƚŚĞ ŵĂƚƚĞƌƐ ǁĞ ĚŝƐĐƵƐƐĞĚ ǁŽƵůĚ ƵůƚŝŵĂƚĞůLJ ďŽŝů ĚŽǁŶ ƚŚĞ ƋƵĞƐƚŝŽŶ ͞ǁŚĂƚ ŝƐ ƚŚĞ ƌŝŐŚƚ ƚŚŝŶŐ ƚŽ ĚŽ ŝŶ ƚŚŝƐ ĐŝƌĐƵŵƐƚĂŶĐĞ͍͟ /Ŷ ƚŚĞ ĐŽŶƚĞdžƚ ŽĨ ƌĞĂĐŚŝŶŐ ĨĂŝƌ ĂŶĚ ƐƵĐĐĞƐƐĨƵů ŽƵƚĐŽŵĞƐ͕ / ĐĂŶ ƐĂLJ ǁŝƚŚŽƵƚ ĨĂŝů͕ ƚŚĂƚ 'ŽƌĚŽŶ ĐŽŶƐŝƐƚĞŶƚůLJ ŬĞƉƚ ŵĞ ŽŶ ƚŚĞ ƌŝŐŚƚ ƉĂƚŚ ĂŶĚ ƵŶŝĨŽƌŵůLJ ĐŽŶĚƵĐƚĞĚ ŚŝŵƐĞůĨ͕ ĂŶĚ ĂĚǀŝƐĞĚ ŵĞ ƚŽ ĐŽŶĚƵĐƚ ŵLJƐĞůĨ͕ ŝŶ Ă ĨĂŝƌ ĂŶĚ ĞƚŚŝĐĂů ŵĂŶŶĞƌ͘ KŶ Ă ƉĞƌƐŽŶĂů ůĞǀĞů͕ 'ŽƌĚŽŶ ŝƐ ƚŚĞ ƚLJƉĞ ŽĨ ƉĞƌƐŽŶ ǁŚŽ ŐŽĞƐ ĐŽŵƉůĞƚĞůLJ ŽƵƚ ŽĨ ŚŝƐ ǁĂLJ ƚŽ ŚĞůƉ ĂŶLJŽŶĞ ŝŶ ŶĞĞĚ ŝƌƌĞƐƉĞĐƚŝǀĞ ŽĨ ƚŚĞŝƌ ĐŝƌĐƵŵƐƚĂŶĐĞ͘ dŚĞ ďĞƐƚ ǁĂLJ / ĐĂŶ ĚĞƐĐƌŝďĞ ƚŚŝƐ ŝƐ ƚŚƌŽƵŐŚ ĂŶ ĞdžĂŵƉůĞ͘ ďŽƵƚ ƚǁŽ LJĞĂƌƐ ĂŐŽ͕ ĂŶ /ƌĂŶŝĂŶ ǁŽŵĂŶ͕ ŶĂŵĞĚ &ĂŚŝŵĞŚ <ĂƐŚŬŽŽůŝ͕ ŶĞĞĚĞĚ ƚŽ ŐĞƚ ŚĞƌ ĚĂƵŐŚƚĞƌ ŝŶƚŽ ƚŚĞ hŶŝƚĞĚ ^ƚĂƚĞƐ͘ ,Ğƌ ĚĂƵŐŚƚĞƌ͕ <ĂƐŚŬŽŽůŝ͕ ŚĂĚ Ă ĚĞďŝůŝƚĂƚŝŶŐ ĞLJĞ ƉƌŽďůĞŵ ĂŶĚ ǁĂƐ ĞƐƐĞŶƚŝĂůůLJ ŐŽŝŶŐ ďůŝŶĚ͘ ŶĞĞĚĞĚ ĂĐĐĞƐƐ ƚŽ h^ ĚŽĐƚŽƌƐ ĂŶĚ ŵĞĚŝĐŝŶĞ͘ tŝƚŚŽƵƚ ĂŶLJ ŽďůŝŐĂƚŝŽŶ ƚŽ ĚŽ ƐŽ ĂŶĚ ǁŝƚŚŽƵƚ ĂŶLJ ĨŽƌŵ ŽĨ ƉƵďůŝĐ ƌĞĐŽŐŶŝƚŝŽŶ͕ 'ŽƌĚŽŶ ŵĂŶĂŐĞĚ ƚŽ ŐĞƚ ŝŶ ƚŽ ƚŚĞ hŶŝƚĞĚ ^ƚĂƚĞƐ ĂŶĚ ĂĐĐĞƐƐ ƚŽ Ă ƚŽƉͲƌĂƚĞĚ ĞLJĞ ƐƵƌŐĞŽŶ ǁŚŽ ǁĂƐ ĂďůĞ ƚŽ ĐŽƌƌĞĐƚ ŚĞƌ ĚŝƐĞĂƐĞ͘ dŚŝƐ ǁĂƐ Ă ĐŽŵƉůŝĐĂƚĞĚ ƉƌŽĐĞƐƐ ƚŚĂƚ ŶĞĞĚĞĚ ƐŽŵĞŽŶĞ ĐĂƉĂďůĞ ŽĨ ŚĂŶĚůŝŶŐ ĂŶĚ ƐŽůǀŝŶŐ ĐŽŵƉůĞdž ƉƌŽďůĞŵƐ͘ dŚĞƌĞ ǁĞƌĞ ƐĞǀĞƌĂů ƉŽŝŶƚƐ ĂůŽŶŐ ƚŚĞ ƚŝŵĞůŝŶĞ ǁŚĞŶ ŝƚ ůŽŽŬĞĚ ůŝŬĞ ǁŽƵůĚ ŶŽƚ ďĞ ĂůůŽǁĞĚ ŝŶƚŽ ƚŚĞ ĐŽƵŶƚƌLJ͘ /Ĩ ƐŚĞ ĚŝĚ ŶŽƚ ŚĂǀĞ 'ŽƌĚŽŶ ŽŶ ŚĞƌ ƐŝĚĞ͕ ƐŚĞ ƵŶĚŽƵďƚĞĚůLJ ǁŽƵůĚ ďĞ ďůŝŶĚ ƚŽĚĂLJ͘ ŶĚ ĨŝŶĂůůLJ͕ ŶŽƚŚŝŶŐ ŝƐ ŵŽƌĞ ŝŵƉŽƌƚĂŶƚ ƚŽ 'ŽƌĚŽŶ ƚŚĂŶ ŚŝƐ ĨĂŵŝůLJ͘ ,Ğ ŝƐ Ă ĚĞǀŽƚĞĚ ĨĂƚŚĞƌ ĂŶĚ ŚƵƐďĂŶĚ͘ / ŽŶĐĞ ƌĞĂĚ ƐŽŵĞƚŚŝŶŐ / ďĞůŝĞǀĞ ƚŽ ďĞ ƚƌƵĞ͗ ϵϱй ŽĨ ďĞŝŶŐ Ă ŐŽŽĚ ƉĂƌĞŶƚ ŝƐ ƚŚĞ ƐŝŶĐĞƌĞ ĂĐƚ ŽĨ ďĞŝŶŐ ƚŚĞƌĞ ĂŶĚ ƚƌLJŝŶŐ͘ zŽƵ ǁŽŶ͛ƚ ĂůǁĂLJƐ ŐĞƚ ŝƚ ƌŝŐŚƚ ďƵƚ ŝƚ ŝƐ ŝŵƉŽƌƚĂŶƚ ƚŚĂƚ ŬŝĚƐ ŬŶŽǁ ƚŚĞŝƌ ƉĂƌĞŶƚƐ ĐĂƌĞ͘ / ŚĂǀĞ ǁĂƚĐŚĞĚ ďŽƚŚ ŽĨ 'ŽƌĚŽŶ͛Ɛ ĐŚŝůĚƌĞŶ͕ ĂŶĚ ͕ ŐƌŽǁ ƵƉ͘ / ďĞůŝĞǀĞ ƚŚĂƚ ďŽƚŚ ŽĨ ƚŚĞŵ ĂƌĞ ŐƌĞĂƚ ŬŝĚƐ͗ dŚĞLJ ĂƌĞ ǁĞůů ďĂůĂŶĐĞĚ͕ ƚŚŽƵŐŚƚĨƵů͕ ĂŶĚ ĐŽŵƉĂƐƐŝŽŶĂƚĞ͘ dŚŝƐ ŝƐ ƚŚĞ ƵůƚŝŵĂƚĞ ƚĞƐƚĂŵĞŶƚ ƚŽ 'ŽƌĚŽŶ ĂŶĚ ŚŝƐ ǁŝĨĞ͘ /Ŷ ŵĂŶLJ ǁĂLJƐ͕ 'ŽƌĚŽŶ͛Ɛ ĐŚŝůĚƌĞŶ ĂƌĞ Ă ĚŝƌĞĐƚ ƌĞĨůĞĐƚŝŽŶ ŽĨ Śŝŵ͘ KǀĞƌ ƚŚĞ ĐŽƵƌƐĞ ŽĨ ŵLJ ůŝĨĞƚŝŵĞ͕ ǁŚĞƚŚĞƌ ŝŶ ŵLJ ƉƌŽĨĞƐƐŝŽŶĂů ĐĂƌĞĞƌ ŽĨ Ϯϯ LJĞĂƌƐ Žƌ ŽƚŚĞƌǁŝƐĞ͕ / ŚĂǀĞ ŬŶŽǁŶ ĂŶĚ ǁŽƌŬĞĚ ǁŝƚŚ ŵĂŶLJ ĚŝĨĨĞƌĞŶƚ ƉĞŽƉůĞ͘ / ĐĂŶ ƐĂLJ ǁŝƚŚ ĐŽŶĨŝĚĞŶĐĞ ƚŚĂƚ 'ŽƌĚŽŶ ĂƉůĂŶ ƌĂŶŬƐ ĂŵŽŶŐ ƚŚĞ ƚŽƉ ŽĨ ƚŚĞ ƉĞŽƉůĞ ƚŚĂƚ / ŚĂǀĞ ŬŶŽǁŶ ǁŝƚŚ ƌĞŐĂƌĚ ƚŽ ŝŶƚĞŐƌŝƚLJ͕ ĐŚĂƌĂĐƚĞƌ͕ ĂŶĚ ƉŽƐŝƚŝǀĞ͕ ůĂƐƚŝŶŐ ŝŵƉĂĐƚ ŽŶ ƚŚĞ ĐŽŵŵƵŶŝƚLJ͘ / Ăŵ ŚĂƉƉLJ ƚŽ ƉƌŽǀŝĚĞ ĂŶLJ ĨƵƌƚŚĞƌ ĚĞƚĂŝů ƚŚĂƚ LJŽƵ ƌĞƋƵŝƌĞ͘ dŚĂŶŬƐ͕ DŝŬĞ dƌŝƉůĞƚƚ Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 159 of 175 Tab 63 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 160 of 175 ANNA WHITE May 9, 2019 TO WHOM IT MAY CONCERN Re: Gordon Caplan Dear Sir/ Madam, I am the Private Equity Practice Coordinator at Willkie Farr dc Gallagher LLP and prior to that I was Gordon Caplan?s personal assistant. I have known Gordon for over 20 years. During this time we have worked closely together and I consider Gordon to be family. The friendship and support Gordon has shown to my family and I over the last two decades has been unwavering. Gordon is truly the most loyal, hard-working, dedicated and generous person that I have the privilege of knowing. We have come so far both professionally and personally since 1998 when we first met at O?Sullivan Graev 6r. Karabell. Throughout the years, Gordon has guided and helped me more times than I can count. When I started my family he made sure that I had the best care possible. When my youngest daughter needed to see a pediatric neurosurgeon Gordon immediately found the right doctor for us. He has contributed to my daughters? 5295 throughout the years. Most recently in November 2018 when I required back surgery, Gordon got me an appointment with two top Doctors, one of whom performed the successful surgery. A year prior to my back Surgery Gordon bought me a standing desk in an effort to help alleviate my pain. In November 2017 Gordon paid for my daughters and I to fly to England to visit my brother. Whatever I or my family have needed throughout the years, Gordon has always been there for us, he is always offering to do things for us. His generosity and support know no bounds. I know this to be true also for any friend, colleague or even an acquaintance of someone who knew Gordon, if they requested help, unthout hesitation Gordon is always there to offer support and guidance. Professionally Gordon pushed me to be where I am today and I am forever in his debt. As his business grew, he guided me to be an active part of the process and as a result I grew professionally to a position I never thought attainable. I-lis leadership, guidance and encouragement motivated me to realize that I could do more and he opened the door to make that possible. I am honored to call Gordon my friend. Please do not hesitate to contact me should you wish to discuss further. Shicerely, MAP Anna lWhite Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 161 of 175 Tab 64 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 162 of 175 Anthony A. Yoseloff September 5, 2019 The Honorable Indira Talwani U.S. District Judge John Joseph Moakley U.S. Courthouse 1 Courthouse Way Boston, MA 02210 RE: United States v. Gordon Caplan Dear Judge Talwani: My name is Tony Yoseloff, and I am the co-head of Davidson Kempner Capital Management LP. I am writing to you in support of Gordon Caplan who I have known extremely well for over 20 years, as a boss, client, mentor and good friend. Davidson Kempner is one of the largest alternative investment managers in the United States. We manage about $31 billion, with the majority of our clients being pension funds, endowments or foundations, and employ over 355 people globally. I initially got to know Gordon when I was a summer associate and then law clerk at O?Sullivan Graev and Karabell, a boutique law ?rm with about 60 lawyers specializing in private equity law. I worked for Gordon for about a year in 1997-1998 while pursuing a and served as his primary junior resource during my year at the ?rm. Even though it was 20 years ago, the early time I spent working for Gordon was incredibly in?uential in my career. Gordon taught me to be very thorough and to always make sure to read all the documents, with the belief that many people took shortcuts in that regard. He also taught me to be extremely careful in checking my work and avoiding spelling and grammar mistakes, as readers would assume greater errors in the work product if they noticed small mistakes. These may seem like small things, but this extremely practical advice stuck with me throughout my career and helped me value the integrity of the process and work product. Gordon invested a tremendous amount of time in teaching me the profession, even though he knew I was unlikely to become a full time law associate. I decided not to pursue a career in law and instead went into money management, and Gordon has represented me as an attorney (both at DKCM and in my personal capacity) for almost 20 years. Throughout this period, both personally and professionally, Gordon has been a trusted advisor, mentor and friend. Whenever I had tough personal or professional questions of many types to ponder, Gordon has always been one of the ?rst people I have spoken with. This has run the gamut from ?nding good doctors (including helping my wife get urgently needed medical care at 4 pm on a Friday afternoon) to navigating parenthood to being a trusted advisor in the creation of our ?rm?s succession planning, which is considered a model in the alternative asset industry. Gordon Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 163 of 175 has always been available to his clients and friends whenever they needed him. for matters big and small. With this long history and ongoing relationship, I was completely shocked by the conduct to which Gordon has pleaded guilty. In fact. I can attest to the fact that Gordon has generally been conservative in his advice, both personally and professionally. (And by conservative. I mean firmly on the correct side of the line between right and wrong.) Part of what made Gordon successful as an attomey is that he always provided practical and conservative advice. In no way do I condone Gordon's conduct, but I can de?nitively say that it does not represent the Gordon aplan that have gotten to know so well over the past 20 years. About four years ago. I joined the board of a non-for?profit named Leadership Enterprise for a Diverse America. a program which was designed to help educate talented rising high school seniors from diverse (and always low income) backgrounds and help prepare them for college (and support them for four years of college and beyond). While an organization like LEDA may normally be on the smaller side for a ?rm like Willkie Farr and Gallagher to take on. Gordon enthusiastically brought in LEDA as a pro bono client of the firm. Under Gordon?s guidance. Willkie spent a lot of pro bono time supporting LEDA each year. and Gordon himself was invested in and spent real time with the organization. Gordon and Willkie took the engagement extremely seriously and LEDA is better off for Gordon's hard work. As part of my involvement with LEDA. in 2016 I introduced Gordon to Kevin Lopez, who was a graduating senior from Princeton University looking to pursue a career in law. Kevin was a LEDA Scholar in 201 and I had gotten to know him through LEDA events. Gordon took Kevin on as a paralegal and spent considerable time and effort in Kevin's learning process. Kevin ultimately followed in Gordon?s footsteps and is attending Fordham Law School. Gordon took great pride in his work with Kevin. and in having made a real difference for him. In sum. Gordon is one of the most talented and caring people I have ever had the chance to know? in his professional capacity as an advisor and personally as a friend and mentor to me and countless others. There are many things about what has happened here which make me sad, but one of them is that Gordon will not have the chance to positively impact so many lives in his chosen profession going forward. While I did attend law school and take the importance of sentencing and deterrence very seriously. Gordon has been punished tremendously already both from the public nature of this case and the fact that it seems unlikely he will be able to continue with his chosen profession. Please consider all of the good Gordon has done for so many people when making your decision. Thank you for your time and for reading this letter. Best regards. 1? Anthony A. Yoseloff Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 164 of 175 Tab 65 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 165 of 175 /HWWHU 6XEPLWWHG 8QGHU 6HDO Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 166 of 175 Tab 66 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 167 of 175 /HWWHU 6XEPLWWHG 8QGHU 6HDO Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 168 of 175 Tab 67 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 169 of 175 /HWWHU 6XEPLWWHG 8QGHU 6HDO Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 170 of 175 Tab 68 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 171 of 175 /HWWHU 6XEPLWWHG 8QGHU 6HDO Case Document 490-1 Filed 09/26/19 Page 172 of 175 Tab 69 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 173 of 175 /HWWHU 6XEPLWWHG 8QGHU 6HDO Case Document 490-1 Filed 09/26/19 Page 174 of 175 Tab 70 Case 1:19-cr-10117-IT Document 490-1 Filed 09/26/19 Page 175 of 175 /HWWHU 6XEPLWWHG 8QGHU 6HDO