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#11
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Quote:
Because a defendant’s record of charity and good works may justify a lenient sentence— indeed, a probationary sentence—it is common enough for white-collar defendants to seek mercy based on their purported generosity and character. As a result, sentencing courts may be skeptical, understandably, of white-collar defendants who pursue leniency through “checkbook philanthropy.” Although that skepticism is warranted in some cases, it simply is not merited here. The 223 character letters presented to the Court attest to Bill’s uncommon humanity and commitment to helping others—what the Senior Probation Officer describes as a “genuine sense of altruism” long predating the “instant criminal investigation.” (S.R. at 2). These letters are written by men and women who have witnessed and been enriched by Bill’s generosity and selflessness first-hand—family members and friends, business associates and religious clergy, fellow addicts in recovery and fellow volunteers. Taken together, the letters demonstrate that Bill’s extraordinary, decades-long dedication to service exists at the core of who he is. The letters attest to the quiet way in which Bill serves others—never seeking credit or acclaim—and to his meaningful and selfless good works. We respectfully submit that the character revealed by Bill’s charitable acts, as well as the genuine remorse evidenced by his acceptance of responsibility and substantial cooperation, merit leniency.
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