Professional Documents
Culture Documents
The Defendant, ELLIOT WILSON, pursuant to Rule 32 of the Federal Rules of Criminal
On January 6, 2010, Elliot Wilson waived Indictment and entered a guilty plea to a one-
count Information charging him with Making False Declaration Before a Federal Grand Jury, in
Elliot Wilson was interviewed by the United States Probation Department who issued a
report dated February 7, 2010 (PSR). Said PSR is accurate and thorough but for two spelling
changes. At paragraph 23 of the PSR, Jill Nedowstek should be changed to Jill Nedorostek;
and at Paragraph 28 of the PSR, Valerie Stringowski should be changed to Valerie Stengowski.
Elliot Wilson is grateful for the time and effort of United States Probation Officer Bouffard.
Case 3:10-cr-00007-CSH Document 25 Filed 02/18/11 Page 2 of 6
ARGUMENT
In U.S. v. Booker, 125 S.C. 738 (2005), the Supreme Court severed and excised the
mandatory provision of the Sentencing Guidelines, “making the Guidelines effectively advisory.”
Id. at 757. Thus, instead of being bound by the Sentencing Guidelines, the Sentencing Reform
Booker, 125 S. Ct. at 757. Under Booker, sentencing courts must treat the guidelines as just
The primary directive in Section 3553(a) is for sentencing courts to “impose a sentence
sufficient, but not greater than necessary, to comply with the purposes set forth in paragraph
(A) to reflect the seriousness of the offense, to promote respect for the
law, and to provide just punishment for the offense;
(B) to afford adequate deterrence to criminal conduct;
(C) to protect the public from further crimes of the defendant; and
1) the nature and circumstances of the offense and the history and
characteristics of the defendant;
2) the kinds of sentences available;
Here, Elliot Wilson requests that the Court impose a sentence of probation, less than
the 10 to 16 months established by the Sentencing Guidelines and/or for the following
reasons:
1.) Elliot Wilson after obtaining Counsel, met with the Government and admitted to
his offense early on;
2.) Elliot Wilson has lived a productive law abiding life, until said offense, for over
65 years;
3.) Elliot Wilson, with Counsel, met with the Government on several occasions and
provided the Government with information and evidence without reservation;
5.) Elliot Wilson, as evidenced by his letters of recommendation, has served the
Case 3:10-cr-00007-CSH Document 25 Filed 02/18/11 Page 4 of 6
public well and has treated people with kindness and dignity;
6.) Elliot Wilson has suffered financial loss from being suspended from his
employment which has severly impacted his wife’s life as well;
7.) Elliot Wilson is remorseful and has tremendous regret for his actions which
have caused embarrassment and shame for his family and aged father;
8.) Elliot Wilson adopts the Conclusion from Paragraph 58 of the PSR, that “the
defendant is an unlikely candidate for recidivism and will likely not appear
before this or any other Court in the future.
Defendant, Elliot Wilson. Two letters, in particular, stand out. The first from Frank and Linda
Giordano, testifies to Elliot Wilson’s characteristics as a person and neighbor. The second
letter from Francis Skoronski describes Elliot Wilson as “someone I know I could go to if I
CONCLUSION
Elliot Wilson has lived a good and decent life. He is a great husband and neighbor.
Elliot Wilsom comes before this Court and respectfully requests this Court sentence him to a
term of probation. Hopefully, justice and mercy recognizes the Defendant’s age, personal
THE DEFENDANT
ELLIOT WILSON
BY: /s/
MICHAEL S. HILLIS
Dombroski, Knapsack & Hillis, LLC
129 Whitney Avenue
New Haven, CT 06511
(203) 624-9096
ct11867
Case 3:10-cr-00007-CSH Document 25 Filed 02/18/11 Page 6 of 6
CERTIFICATION
I hereby certify that on February 18, 2011 a copy of the foregoing was filed
electronically and served by mail on anyone unable to accept electronic filing. Notice of this
filing will be sent by e-mail to all parties by operation of the Court’s electronic filing system or
by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic
Filing. Parties may access this filing through the Court’s CM/ECF System.
/s/
MICHAEL S. HILLIS