DISTRICT ATTORNEY
COUNTY OF NEW YORK
ONE HOGAN PLACE
New York, N. Y. 10013

(212) 335-9000

 

CYRUS R. VANCE, JR.

DESTRICT ATTORNEY

The Honorable Justice James Burke March 6, 2020

New York County Supreme Court People a. Wez'mz?ez'a

100 Centre Street, Part 99 - Ind. Nos. 2335/2018
New York, NY 10013 2673/2019
Dearjudge Burke:

Please accept this letter for your consideration along with the oral statement the People
will make pursuant to CPL 380.50(1) regarding the sentence to be imposed upon the
defendant on March 11, 2020. The Court presided at defendant?s trial and is fully familiar with
the facts and circumstances of defendant?s commission of the crimes for which he stands
convicted. The victims of those crimes, Miriam Haley andJessica Mann, will provide the Court
with their statements, pursuant to CPL 

As this Court is well aware, in imposing what it deems to be fair and just punishment,
a sentencing court is not limited to the evidence at trial. To the contrary, ?[hjighly relevant?
if not essential?to a [sentencing judge?s] selection of an appropriate sentence is the possession
of the fullest information possible concerning the defendant?s life and characteristics.?
[Vi/lame v. New York, 337 US. 241, 247 (1949), a?fg, Peep/e a. William, 298 N.Y. 803 (1949).
Accordingly, ?the modern probation report draws on information concerning every aspect of
a defendant?s life,? id. at 250, and sentencing courts have ?wide discretion to consider all
circumstances that shed light on a convicted person?s background, history and behavior? in
fixing a sentence. United Slater a. Pug/zen, 805 F.2d 1117, 1122 (2d Cir. 1986). Accord William: 0.
New York, 337 US. at 250; People a. Dry, 73 208, 212 (1989) (?Sentencing courts, in
the exercise of their unique judicial function in criminal proceedings, are wisely allocated wide
latitude as they are recognized to be in a superior position to dispense proportionate and fair
punishment?) (citing People Farmr, 52 302605?06 (1981) (holding that determination
of appropriate sentence requires exercise of discretion after due consideration of several
factors, including ?the crime charged, the particular circumstances of the individual before the
court and the purpose of a penal sanction, societal protection, rehabilitation and
deterrence?)).

Particularly apt here is the Farmr Court?s reliance on Penal Law 1.05, which sets forth,
among the purposes of a penal sanction: ?To provide for an appropriate public response to
particular offenses, including consideration of the consequences of the offense for the victim,

including the victim?s family, and the community.? 105(5). See alto PL 105(6) (providing
as additional purpose of a penal sanction, insure the public safety by preventing the
commission of offenses through the deterrent in?uence of the sentences authorized?). The
need for deterrence, of this defendant speci?cally and other offenders generally, is of particular
importance here. See, 18 U.S.C. 3553(a)(2)(B) (In imposing sentence, the court ?shall
consider the need for the sentence imposed . . . to afford adequate deterrence to criminal
conduct?); People o. Bmadz'e, 37 100, 115 (1975) (recognizing deterrence as an ?obvious
purpose? of penal sanctions, which is achieved by putting would?be offenders on notice of
severe penalties); United State; a. Cat/em, 550 F.3d 180, 195 (2d Cir. 2008) (en banc) (affirming
sentence above guidelines range for gun trafficker based on need for deterrence where strict
local gun laws increase pro?ts for distributing firearms in New York City); United Stoter o. Tare,
450 F.3d 352, 359 (8th Cir. 2006) (finding abuse of discretion in lenient sentence imposed on
willful tax evader, noting that he goal of deterrence rings hollow if a prison sentence is not
imposed in this case?). It is therefore totally appropriate in this case to communicate to a
wider audience that sexual assault, even if perpetrated upon an acquaintance or in a
professional setting, is a serious offense worthy of a prison sentence.

Chief among the information considered at sentencing is the defendant?s history of
?misconduct, whether or not it resulted in convictions.? United State; o. Mateo/7n, 432 F.2d 809,
816 (2d Cir. 1970). See CPL 390.30(1) (presentence investigation includes information about
?the defendant?s history of delinquency or criminality?); Peep/e 7). Powell, 157 524, 525
(1 st Dept. 1990) (holding ?no legal impediment to the court?s consideration of prior uncharged
crimes?); People 188 839, 842 (3d Dept. 1992) (proper for court to consider

9 (C

at sentencing defendant 3 propensity for antisocial and violent aggressive behavior?).

Moreover, the need for courts to have information about all aspects of a defendant?s
life and characteristics has made it imperative that they be free to consider a broad spectrum
of information from a wide variety of sources without strict adherence to a rigid set of rules.
Consequently, presentence reports and presentations by the parties at sentencing are not
limited to information that would satisfy evidentiary rules governing admissibility at trial, tee
People 72. Perry, 36 114, 120 (1975), but may include hearsay. Wit/toner o. New York, 337
US at 249?50; United 5tater o. C/nmner Inc, 711 F.2d 1164, 1170?71 (2d Cir. 1983).

The information regarding defendant that the People ask the Court to consider is listed
below, divided into three categories: (1) sexual assault and harassment; (2) bad acts and
behavior in the work environment; and (3) other bad acts. These acts, viewed in the totality,
establish that throughout his entire adult professional life, defendant has displayed a staggering
lack of empathy, treating others with disdain and inhumanity. He has consistently advanced
his own sordid desires and fixations over the well-being of others. He has destroyed people?s
lives and livelihoods or threatened to do so on whim. He has exhibited an attitude of
superiority and complete lack of compassion for his fellow man. What is obvious from this
list of misdeeds is that many of them are frighteningly similar to the events testified to at trial.

Sexual assaults and sexual harassment:

Our investigation over approximately two years has revealed that the defendant has

sexually violated many women. Starting in the 19705, he has trapped women into his exclusive
control and assaulted or attempted to assault them.

In 1978, a woman was an employee of defendant?s music company based in Buffalo,
New York. While in New York City with defendant for a business meeting, she was
told by defendant that there was ?only one room left? at the hotel. While in a room
she shared with defendant, she woke up in the middle of the night to ?nd him lying on
top of her and forcing himself sexually on her.

In approximately the summer of 1981, a woman responded to an open call for
auditions at a hotel on Central Park South in Manhattan. After waiting with various
other female actresses, a young man appeared and announced that the producer would
not be doing any more auditions that day and the actresses should return at a later date.
On the next audition date when the woman showed up, her name was called and she
was told to go to a particular hotel room. She was totally surprised when, in response
to her knock at the door, an unattractive and overweight man, who she later learned
was defendant, appeared wearing nothing but a white robe. He said,
?everyone calls me Teddy Bear because I?m so big and cuddly and harmless.? He said
he had just taken a shower and told her to sit down in a chair by a table. He tossed a
script onto the table and said he was going to produce a movie starring Faye Dunaway
and needed someone to play her younger sister. He said that the woman would be
perfect for the part and that, think you are willing to do anything to get ahead,? and
that there were always parts for women like her if they were ?willing to do what it
takes.? He did not ask her anything about herselfaudition for
the part. He said that she could get any part she wanted if she would have sex with him.
The woman was ?scared for her life,? and wondered if she would be able to escape
from defendant?s room. She tried to sit calmly and not show her fear. Defendant said
that when a man is obese, normal sexual positions would not work and other options
would have to be used to ?get him off.? He said that if she did not want to have sex
with him, he could arrange for her to have sex with other directors or producers. When
she said she was not interested, he let her leave unharmed but not without asking if she
could give him names of other girls who might be interested. The woman never spoke
about this because she knew that the young man who must have been defendant?s
assistant had her contact information and she was afraid of retaliation. She never
auditioned for an acting role again and over 20 years later, she saw defendant on
television and realized who he was.

In a reported incident in the late 1980s, defendant came to the home of a young actress
and as soon as she opened her door, he pushed her up against a coat rackand had
forcible intercourse with her.

In the late 19805 and early 19905, a male employee worked as the head of marketing at
defendant?s company in New York. He described the office as an ?incredibly abusive
place? with a lot of yelling. Defendant threw objects at him and he observed defendant
throw objects at his coworkers. The employee also said that the more senior female
employees would use him as a ?shield? when defendant wanted to be alone with them.
For example, when defendant would ask one of his female employees to ride home
with him, she would pretend she had dinner plans with the employee. This happened
on a ?semi?regular? basis and, to accommodate these coworkers, this employee would
stop working, get in defendant?s car, and be dropped off with his colleague at a random
uptown restaurant. He would then have to get a cab to travel to his home downtown.
Also, as part of the employee?s of?cial duties, he was in charge of all of the promotional
photoshoots. Defendant always wanted naked or scantily clad women on the movie
posters. During one of these photoshoots, defendant called the employee repeatedly,
asking if the female celebrity was ?naked yet.? Defendant would also insist that
unwilling women appear naked or scantily clad in these photoshoots. In one instance,
when an actress refused to be photographed nude, defendant insisted that they
photoshop the actress?s head onto another woman?s body.

In the 19905 in the UK, a 19?year?old employee of defendant was instructed by
another employee that she must visit defendant in his hotel room that evening. The
meeting was described as a script meeting. She did not want to go but was told that
she had to if she wanted to keep her job. At the start of the meeting, there were
several other people in the room but the employee was asked to stay after others left.
Defendant then sexually assaulted the employee, who was left in extreme shock and
had difficulty comprehending what had happened. The employee later left her job,
but felt forever stigmatized by the events and experienced difficulty gaining any
momentum in her career.

In 1991, after an introduction by a mutual friend, a woman went to New York to
interview for an internship at defendant?s company. While giving her a tour of the
office, defendant took the woman into a conference room where he grabbed her hand
and placed it on his genital area. When she tried to leave, defendant followed her into
an elevator where he forcibly kissed her.

In 1991, a 19?year?old woman worked for one day as an intern for defendant in the
UK. She was told by her supervisor that she must visit defendant in his hotel suite.
She was called to the bathroom by defendant where the door was open.
Through a gap in the door she could see that defendant was naked in the bathtub.
She was called into the bathroom but did not enter and went to sit at a desk in the

room. Defendant continued to call her and she felt nervous and intimidated. A few

moments later, she was called by defendant into the bedroom. He was lying on his

back with his dressing gown open. Defendant called her over to the bed and
beckoned her to sit down. She sat facing away from him at an angle. Defendant
requested that she take her top off, which she felt she had no choice but to do, but
then abruptly got up and left the suite, shaking and anxious. She wished to report the
matter to the police and was introduced by a superior to a police of?cer who was the
boyfriend of her superior and to whom she reported the matter. She was then called
by the same superior who told her that defendant wanted to speak to her and that she
should consider dropping her case. The woman was fearful and did not pursue the
matter further.

In 1996, an actress met defendant at the film festival in Cannes, France. He invited her
to have breakfast with him and a French film executive to talk about Miramax?s
potential distribution of a film they had just purchased and in which the actress had a
starring role. When they ?nished breakfast, the French film executive suddenly had to
leave and defendant invited the actress to his hotel room to ?see the view? from his
terrace. When they got to the terrace and she saw a bottle of champagne, she said she
had to leave. Defendant told her he was going to give her a massage. When she
declined, he ?jumped on her? and tried to remove her shirt. She physically fought him
off, screamed, and ran away.

Defendant met with an actress at his Miramax of?ce, where he invited her to a movie
screening. As they were allegedly being driven to the screening, defendant said he
needed to stop at his apartment to get something. The actress went inside the
apartment with defendant where they discussed movies, after which defendant went
into the bathroom and emerged shortly thereafter, dressed only in a bathrobe. He asked
the actress for a massage. She said no several times. He went back inside the bathroom
and came out naked. He asked her to show him her breasts but she declined. He told
her he would let her go if she would give him a minute to get dressed, after which he
took her in a taxi to a bar where he dropped her off. She saw defendant outside the
bar, waiting in the car for about 15 minutes before the taxi drove away. Defendant
called the actress several times over the next few days, but she did not answer his calls.

In 2005, a woman who was approximately 22 years old attended a party at Cipriani
(?Upstairs?) in downtown Manhattan. Defendant, who was also at the party, grabbed
the woman and sat her on his lap. She got off his lap, and she later accepted a ride
home from him, during which she asked him for professional advice. After defendant
told her that he would connect her with people who would help her to become an
actress, the woman gave him her contact information. Shortly thereafter, defendant?s
assistant called and invited her to a movie screening at defendant?s office. She
accepted the invitation and during the screening, defendant abruptly stopped the
movie and said that they had to go out and eat, even though he had ordered sushi to
his office. The woman said no, but he insisted and led her to a car outside. The car
stopped at a building in Soho, which was not a restaurant; it had a lobby and an

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elevator. Defendant and the woman rode the elevator, which opened into an
apartment. The woman was upset and afraid, but tried to remain calm and respectful.
Defendant poured her a drink, despite her indicating that she didn?t want one, and
told her that if she wanted to act in movies, she had to be comfortable being naked
and told her to take off her clothes. She undressed, but kept her underwear on.
Defendant said, ?no, all the way.? She complied and defendant grabbed her clothes
and left the room. She went down the hallway looking for her clothes and walked
into the one room that had a light on. Defendant was standing in that room
completely naked. She was petri?ed, afraid he was going to rape and murder her, and
she realized that no one knew where she was. When she asked defendant for her
clothes, he said, ?you?re never going to find them.? He patted the bed and motioned
for her to get on it. When she refused, he chased her around the room, as she
repeatedly said, He then asked if she would ?at least jerk him of He
promised to give her back her clothes if she came into the bed and held him. She
agreed, and when she got into the bed and touched defendant?s back, she was
I repulsed at how ?gross? it was. She was in shock and sternly demanded her clothes.
Defendant refused, demanded that she put her hand on his penis to get her clothes
back, and proceeded to masturbate and ejaculate onto her body. He then ordered her
to take a shower and wash everything off, after which he dried her very roughly with
a towel. She grabbed her clothes, got dressed quickly, and left defendant?s apartment.

In 2007, defendant told a woman that he wanted to show her the kitchen ?in a new
restaurant he owned.? Once inside the kitchen, defendant dismissed an employee who
was cleaning up. Defendant then blocked the woman in a hallway, trapping her so that
she was unable to escape, and tried to kiss her. He took his penis out, masturbated, and
ejaculated into a nearby potted plant.

In 2010, a woman who is a professional masseuse met defendant through a mutual
friend. Defendant?s assistant arranged for the woman to give defendant a massage at
the Montage Hotel in Beverly Hills. When she arrived at the hotel, she was met in the
lobby by defendant?s assistant who escorted her to defendant?s hotel room. As the
woman was setting up the massage table, defendant instructed his assistant to leave the
room. The woman excused herself to let defendant undress and get onto the massage
table. She told him to let her know when he was ?under the sheets,? which he did a
few minutes later. But when the masseuse returned to the room, defendant was
standing there naked. During the course of the massage, defendant got up and asked
the witness ?how big his penis was.? She excused herself and went to the bathroom.
Defendant followed her into the bathroom, closed the door behind him, blocked her
from leaving, pushed her up against the wall, and began masturbating. While
masturbating, defendant groped the woman?s breasts. The woman noticed a marked
change in defendant?s demeanor immediately after he ejaculated, from very abusive and
aggressive behavior before he assaulted her, to an apparent state of calm after the
assault, almost as if nothing had happened. Defendant also made efforts to silence the

woman, by telling her he could harm her professionally, but also offering her a book
publishing opportunity.

In 2011, a waitress at Cipriani served defendant a diet soda. He asked the witness about
her career. She said she wanted to be a model. A short time later the owner of the
restaurant told the witness that defendant wanted to see her in private, and arranged
for another waitress to cover her tables. He told the waitress to go to the rooftop where
defendant was waiting. When she arrived, she saw defendant exposing his penis. He
grabbed her dress, pulled it up, and masturbated as his penis touched her. (This was
very similar to the incident involving witness Tarale Wulff.)

In January of 2011, following the Golden Globe Awards, defendant asked an actress
to meet him in the lobby of the Peninsula Hotel in Beverly Hills to discuss ?lm
opportunities. She arrived but defendant was not in the lobby. He called her and told
her to come up to his room because he was a celebrity and wanted to have privacy. She
went to the room. Once she was there defendant initially discussed potential career
opportunities with the actress, but then asked her to give him a naked massage. When
she refused, he berated her, telling her that this is how people get ahead in the film

business.

In 2011, an actress met defendant at a party at the Rose Bar in the Gramercy Park
Hotel in New York. He asked for her email address so that he could invite her to lunch
to talk about her career. On his way out of the party, defendant grabbed the actress
between her legs and touched her buttocks and genital area through her clothing.

In February 2014, a woman met defendant at a party in London and he asked to see
her film reel. In May of that year, when she saw him again at the Cannes Film Festival,
he asked her to come to his hotel room to review her reel. While she was in the room,
he led her into the bathroom and stood her in front of the mirror. She told him to stop
but he kept her in front of the mirror, put his leg in between her legs, and began
touching her shoulder and pulling down her straps while she tried to get away.
Defendant then turned her around, unbuckled his pants, and masturbated while still
gripping her. He took her hand and put it onto his penis and moved her hand up and
down his penis.

Abusive behavior in the workplace:

At the Cannes Film Festival in the 1990s, an employee observed defendant throw a
table of food on an employee who disagreed with him. The employee who was
assaulted continued to return to work every day for months because he feared that
defendant would smear his name and ruin his reputation (similar to the women who
testi?ed under oath in this case that after defendant raped them they continued to
have a relationship out of fear).

An executive at defendant?s companies from the 19903 through 2017 reported that
defendant threatened him on multiple occasions and he observed defendant threaten
others physically and professionally. Defendant asked the executive to lie for him when
Ronan Farrow?s article about defendant?s sexual abuse of women was published in the
New Yorker in 2017. In addition, defendant threatened to expose the executive for a
minor dispute with another employee if the witness would not lie for him.

In the mid?1990s, defendant asked a business executive to lie for him in both personal

and professional matters. This witness described defendant as ?despicable, aggressive,

demeaning, coercive, threatening,? and as someone who would ?make you do things
you don?t want to do.?

An employee of defendant from 1987 to 1991 who worked with defendant on a daily
basis and traveled with him, described his ?bullying, screaming, and abusive behavior?
directed at her and at other employees and executives in the company.

A man was a business executive in defendant?s company during the 2000s. He
describes defendant as ?brutal and vicious? as well as ?volcanic.? The man experienced
this behavior himself and saw others who were victimized by it.

Another former business executive in defendant?s company observed a pattern of
conduct by defendant including lying, being verbally abusive to many people, and
vindictive. This executive also observed defendant during a business meeting in front
of multiple witnesses stand up and physically attack his brother, Bob Weinstein,
punching him so hard that he bled a great deal and was brie?y unconscious.

Another long?term executive at Miramax observed speci?c malicious and vindictive
acts of defendant, including threats to multiple people, both personally and
professionally, lies, false accusations, and the use of enormous amounts of resources
to impose gratuitous damage to other people?s lives. Speci?cally, this executive said
that defendant had ?zero compassion, empathy, civility.? The executive left the
company because of defendant?s ?abhorrent behavior.?

Another employee worked closely with defendant for over 25 years, from 1991 to 2017.
He described defendant as abusive mentally, temperamental, demanding, and
threatening. This employee ?lived in this state of fear most of the time,? and continued
to feel fearful after his employment was terminated. He also experienced physical
effects from working for defendant, including frequent nightmares, that adversely
affected his personal life and his relationship with his family.

In 2007, a male employee was traveling with defendant. One day in the back seat of a
car, defendant got angry and physically assaulted the man. When the employee
indicated that he would report him, defendant told him that he could never tell anyone

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and that no one would ever believe him. When the employee quit his job over this
incident, defendant had another employee follow the man in an attempt to convince
him not to report defendant?s actions.

From 2010 to 2014, a woman worked in the Los Angeles office of defendant?s
company. She observed that defendant was ?always behaving strangely??erratic, always
snapping at people, seemed sociopathic.? He ?got a lot of joy by demeaning people.?
As an example, she said, ?if you opened a door for him, he would turn and say ?what
the fuck are you looking at? Don?t fucking look at me.? She further described
defendant as a ?monster.?

In 2012, a 32?year?old woman began working in production for defendant's company
in the UK. She was subject to relentless insulting and abusive behavior by defendant
throughout her employment. She also suffered verbal abuse and was threatened
physically by defendant. During a trip with defendant to the Cannes Film festival,
they boarded a boat and when she indicated she had not sent an email yet, he started
to threaten her and ran towards her as if to throw her off the boat. Another colleague
stepped in to protect the woman. She was required to pick up erectile dysfunction
drugs for him, not knowing initially what these drugs were. On one occasion when
she was asked to lead an actress to his room at a hotel she challenged him regarding
what was happening in the room and he verbally abused her, telling her, "your
opinion doesn't matter, fuck off," and pushed her against a wall.

In 2013, defendant was repeatedly verbally abusive to a male assistant. He threatened
to physically hurt the assistant, made him get out of a car on the side of the road, and
abandoned him while on a business trip outside of the United States.

A woman who worked for defendant?s company in New York from 2015 to 2016
observed and experienced his outbursts. Defendant ?constantly berated [her] in front of
other people,? he once kicked her out of a car while on a work-related trip in upstate New
York, and he threatened to have her followed by a private detective after he accused her
of lying about an invoice.

A woman who recently worked as a Weinstein family personal assistant was bullied,
overworked, and verbally abused by defendant. She described defendant as explosive,
observed him throwing staplers and other objects at people, and witnessed him
threatening female assistants ?all the time.? She also observed defendant threaten to
have his private investigator ?look into? people?s personal finances. Defendant
repeatedly screamed and cursed at this employee, on one occasion calling her a ?cunt?
in front of a celebrity while she was trying to navigate defendant?s schedule.

In 2015, defendant threatened to punch a board member and said he would kill him.
On another occasion, defendant told the board member that he would send someone
to his of?ce to cut off his genitals with gardening shears.

Three men were drivers for defendant, on a contractual basis, ?lling in for the person
who held a permanent position as a driver. They uniformly described defendant as a
bully, who would lose his temper with them and others in their presence. One recalled
being threatened by defendant and another said that defendant yelled at him and
demanded that he drive in an illegal manner.

In addition to the above incidents, almost every employee interviewed by the People
has described being ordered by defendant to work long hours without any extra
compensation. They similarly recount defendant calling them at all hours of the night
and day, demanding their time, attention, and performance of personal tasks.
Defendant would also berate, insult, and demean employees loudly and in front of
many people. He would scream at them at the top of his lungs, close to their faces.
This type of behavior was constant and unwavering.

Other bad acts:

In November 2000, a female reporter worked at the New York Observer and was
assigned to write a story about a movie that defendant?s company was producing. As
part of that assignment, she attended a party with her boyfriend, another reporter, that
defendant was hosting on the evening of Election Day, November 7, 2000, at the
Tribeca Grand Hotel in Manhattan. The reporter approached defendant with her tape
recorder and attempted to get a comment from him for her story. Defendant declined
to comment and said that his brother was producing the movie. When the reporter
continued to ask defendant about the movie, he became incensed and yelled at her,
repeating variations of: ?\Who let this cunt into the party?? and ?Get this bitch out of
here.? The second reporter, her boyfriend, intervened and said that he had been invited
to the party and that the female reporter was his guest. Later, after defendant appeared
to calm down, the second reporter approached defendant and said that he should
apologize to the female reporter for calling her a ?cunt? and a ?bitch,? but defendant
refused and said, ?I?m glad I?m the fucking sheriff of this shit ass fucking town.?
Defendant then grabbed the second reporter by the neck, pulled him outside into the
street, told him he was going to kick his ass, then put him in a headlock and struck him
in the head. The assault was subsequently stopped by others.

From 2015 through 2017, defendant had direct communication with Black Cube, an
organization that generated content designed to publicly discredit and shame
defendant?s sexual assault victims. One of the techniques it employed on behalf of
defendant was to send operatives, who lied about who they were, to manipulate what
the victims said about defendant. After the publication of articles in 2017 alleging
defendant?s sexual abuse of various women, and after defendant was fired by the

10

Weinstein Company, he called an employee and asked him to let people in who
defendant told to ?ransack? the office. This witness also observed defendant meeting
personally with representatives of Black Cube.

0 Multiple people have reported to the People that defendant bragged about his ability
to get people killed. Similarly, defendant toldjessica Mann that he could send men with
baseball bats to assault her father if she wanted, bragging that he had done that with
other people in the past.

Based upon the totality of the information before this Court, namely: (1) the evidence
adduced at trial regarding defendant?s sexual assaults of Miriam Haley and jessica Mann; (2)
his sexual assaults of the Molimzzx witnesses, Tarale Wulff, Dawn Dunning, and Lauren Young,
all committed under strikingly similar circumstances; and (3) his additional acts set forth in
this letter that show a lifetime of abuse towards others, sexual and otherwise, the People will
ask the Court to impose a sentence that re?ects the seriousness of defendant?s offenses, his
total lack of remorse for the harm he has caused, and the need to deter him and others from
engaging in further criminal conduct.

Sincerely,

szi?Orbon
As stant District Attorney

  
   

Cc: Donna A. Rotunno, Esq.

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