Michael Brown Defense Sentencing Memo

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

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UNITED STATES )
)
v. ) Criminal No. 13-164 (RLW)
)
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MICHAEL A. BROWN, )
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Defendant. )
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SENTENCING MEMORANDUM OF MICHAEL A. BROWN

Reid H. Weingarten (D.C. Bar #365893)
Brian M. Heberlig (D.C. Bar #455381)
Scott P. Armstrong (D.C. Bar #993851)
Steptoe & Johnson LLP
1330 Connecticut Avenue, N.W.
Washington, D.C. 20036-1795
(202) 429-3000
rweingarten@steptoe.com
bheberlig@steptoe.com
sarmstrong@steptoe.com

Counsel for Defendant Michael A. Brown

Dated: April 24, 2014

Case 1:13-cr-00164-RWR Document 34 Filed 04/24/14 Page 1 of 45
ii
TABLE OF CONTENTS

I. INTRODUCTION .............................................................................................................. 1
II. PERSONAL HISTORY ...................................................................................................... 5
A. Upbringing And Family .......................................................................................... 5
B. Education And Early Professional Life .................................................................. 7
C. Helping Others ........................................................................................................ 8
1. Individual Acts of Kindness ........................................................................ 8
a. Helping Others during Times of Need ............................................ 9
b. Making Others Feel Like Part of the Family and
Mentoring Young African-American Men ................................... 10
2. Expanding the Safety Net for District Residents as a D.C.
Councilmember ......................................................................................... 12
a. Food Stamp Expansion Act of 2009 ............................................. 13
b. Temporary Assistance for Needy Families (TANF)
Educational Opportunities and Accountability Act of 2010 ......... 14
III. SENTENCING ISSUES ................................................................................................... 14
A. The Federal Sentencing Guidelines Are Advisory And Only One Of
Several Factors To Be Considered In Sentencing ................................................. 14
B. The Stipulated Guidelines Analysis ...................................................................... 17
1. The Amended Plea Agreement ................................................................. 17
2. The Probation Offices Pre-Sentence Investigation Report
(PSIR) .................................................................................................... 18
C. The Court Should Impose A Below-Guidelines Sentence In Recognition
Of Mr. Browns Substantial Cooperation ............................................................ 19
1. Mr. Browns Substantial Assistance in the Governments Long-
Running Investigation of Jeffrey Thompson ............................................ 19
2. Mr. Browns Substantial Assistance in Resolving the Allegations
Against Him .............................................................................................. 22
iii
3. Mr. Browns Substantial Assistance as to the Governments
Investigation of Hakim Sutton for the Alleged Theft of Campaign
Funds ......................................................................................................... 24
4. Mr. Browns Assistance with the Governments Other
Investigations ............................................................................................ 25
D. Mr. Browns History And Characteristics, As Well As The Nature Of His
Offense, Warrant A Lower Non-Guidelines Sentence ......................................... 26
1. History and Characteristics ....................................................................... 26
a. Community Service ...................................................................... 26
b. Family Ties ................................................................................... 29
(1) Mr. Brown became the rock of the family with
the death of his father in 1996 ........................................... 30
(2) Mr. Brown has shouldered the responsibility of
primary caregiver to his elderly, ailing mother ................. 30
(3) Mr. Brown has continued to be a loving and
protective older brother to his sister .................................. 33
(4) Mr. Brown has been a loving and supportive father
to his two sons ................................................................... 33
2. Nature and Circumstances of the Offense ................................................ 34
3. Substantial Leniency Would Avoid Unwarranted Sentence
Disparities among Defendants Sentenced to Similar Conduct ................. 37
E. There Is No Need To Protect The Public Through A Prison Sentence
Because There Is No Chance of Recidivism ......................................................... 40
IV. CONCLUSION ................................................................................................................. 41

I. INTRODUCTION
Michael A. Brown respectfully urges the Court to sentence him to a term of incarceration
well below the advisory Guidelines range. A below-Guidelines sentence is appropriate based on
Mr. Browns substantial cooperation in the prosecution of others, history and characteristics
involving a lifetime of service to his community and support for his family, and complete
acceptance of responsibility for the conduct that has brought him before the Court.
Mr. Brown has dedicated his life to serving the community of the District of Columbia
and supporting his family. As a D.C. Councilmember, he fought to end poverty in the District
and expand the safety net for vulnerable residents. As a son, brother, and father, Mr. Brown is a
pillar of strength and support to his family. To those closest to him and many others, his
generosity and selflessness is a source of inspiration. These characteristics, not the conduct now
before the Court, define Mr. Brown.
Mr. Brown recognizes he fell far short of the high standard he held for himself. On June
10, 2013, Michael Brown pleaded guilty to a one-count information charging bribery in violation
of 18 U.S.C. 201(b)(2)(A).
1
In the Amended Statement Of Offense And Other Conduct filed
with the Court (Dkt. No. 25, Ex. B), Mr. Brown acknowledged that he received $35,000 from
undercover agents with the Federal Bureau of Investigation (FBI) who posed as representatives
of a government contracting company (Company M). Mr. Brown also acknowledged his
official acts to expedite approval of Company Ms application as a Certified Business Enterprise
from the District of Columbias Department of Small and Local Business Development.

1
The parties have since amended that Plea Agreement and the accompanying Statement
Of Offense And Other Conduct (Dkt. No. 25, Exs. A, B). Mr. Brown intends to plead guilty to
the Amended Plea Agreement and accept the Amended Statement Of Offense And Other
Conduct before the Court on May 8, 2014.
2
Mr. Brown has accepted complete responsibility for his actions and acknowledged his
wrongdoing both in Court and before his family and friends. He is remorseful and regrets the
pain and disappointment his actions have caused his family, friends, and former constituents.
Mr. Brown in no way seeks to minimize either his conduct or his culpability. Through this
memorandum, Mr. Brown will provide the Court with the necessary information about his
background and characteristics to permit the Court to sentence him in accordance with the law.
Several factors warrant leniency and support a below-Guidelines sentence for Mr. Brown.
First, the government recognizes Mr. Browns substantial assistance in the prosecution of other
individuals. The Court should credit that cooperation and extend Mr. Brown substantial leniency
for his efforts.
Mr. Brown specifically provided substantial cooperation in the governments long-
running investigation of Jeffrey Thompson, a Washington businessman who recently pled guilty
to a years-long scheme to funnel roughly $2,000,000 to candidates for election in the District of
Columbia. Mr. Brown corroborated the governments evidence against Mr. Thompson and
provided significant new evidence of one-on-one meetings with Mr. Thompson that only
Mr. Brown was in a position to provide. This evidence revealed conclusively Mr. Thompsons
intent to orchestrate a scheme to violate campaign finance laws in Mr. Browns 2007 and 2008
election campaigns. Even more, Mr. Brown admitted that Mr. Thompson secretly funded these
election campaigns in public charging documents.
2
Weeks after the filing of the Amended
Statement Of Offense And Other Conduct that detailed Mr. Thompsons role in Mr. Browns
2008 campaign, Mr. Thompson pleaded guilty to conduct involving that campaign and others.

2
Mr. Brown remains the only public figure who has publicly acknowledged knowingly
receiving shadow contributions from Mr. Thompson.
3
Mr. Brown also provided substantial assistance to the government through the manner in
which he resolved its investigation of him. The government specifically asked Mr. Brown not to
reveal certain sources and methods of its undercover investigation. Mr. Brown agreed to
terminate his campaign for re-election and keep confidential those important details. He did so
even though, as a candidate in the midst of a re-election campaign, he had a bully pulpit to do
just the opposite. Mr. Browns substantial cooperation on this issue is described in further detail
in the governments April 24, 2014 sealed filing.
The government also recognizes Mr. Browns substantial cooperation in its investigation
of the theft of funds from Mr. Browns 2012 re-election campaign account. After Mr. Brown
discovered the theft and reported it to authorities, he made himself available to answer all of the
governments questions about the matter. He also facilitated the governments interview of an
important witness, his legislative counsel at the time. Through these efforts and others,
Mr. Brown enabled the government to investigate fully the theft. Mr. Browns substantial
cooperation has paid dividends: the government recently indicted Mr. Browns former campaign
treasurer, Hakim Sutton, for the alleged theft of these funds and related offenses.
Second, Mr. Browns history and characteristics, including his good acts and family ties,
weigh in favor of a lenient below-Guidelines sentence. Mr. Brown learned at a young age from
his parents the importance of helping others and giving back to the disadvantaged and at-risk
residents in the District. The letters of support submitted to this Court evidence how Mr. Brown
followed through on his parents teachings. Indeed, this commitment to helping the less
fortunate became the hallmark of Mr. Browns tenure on the D.C. Council where he took
concrete actions to expand the safety net for District residents in the height of the recent
economic recession.
4
Beyond his good deeds for others, Mr. Browns family ties run deep. He is the primary
caregiver to his elderly, ailing mother, Ms. Alma Brown; loving and protective brother to his
younger sister, Tracey Brown James; and devoted and supportive father to his two sons, Morgan
and Ryan. These good works and family ties define Mr. Brown. His admitted, grave mistakes
before the Court do not.
Third, the nature of the offense and its circumstances support substantial leniency.
Mr. Browns dire financial condition leading up to, and throughout, the charged conduct led him
to engage in acts inconsistent with his character. Mr. Brown recognizes that nothing excuses his
conduct and that many in the District make ends meet on far less. He offers his deteriorating
financial condition as a mitigating circumstance to explain how his judgment became clouded,
his decision-making compromised, and his character undermined.
Fourth, a below-Guidelines sentence for Mr. Brown would be consistent with post-
Booker sentences of other similarly-situated public officials. In this way, substantial leniency for
Mr. Brown would avoid unwarranted sentence disparities among defendants with similar
records who have been found guilty of similar conduct[.] 18 U.S.C. 3553(a)(6).
Fifth, Mr. Brown poses no threat to the public given his age and criminal history. Nor
does Mr. Brown run the risk of recidivism. Mr. Browns public fall from grace has made an
example of him and warned other elected officials about the dangers of crossing, and even
approaching, the line between constituent advocacy and impropriety. Even a below-Guidelines
sentence would reflect the seriousness of his conduct, promote respect for the law, and deter
other criminal conduct.
5
II. PERSONAL HISTORY
A. Upbringing And Family
Mr. Brown was born on March 4, 1965 in Kassel, West Germany on a U.S. Army base
where his father Ronald H. Brown was stationed with his mother, Alma A. Brown. Throughout
his childhood and early years as an adult, Mr. Browns father was a committed public servant
who served as the Secretary of Commerce under President Clinton until his death in a plane
crash in Croatia on April 3, 1996. Mr. Browns life has been dominated by the virtues his
parents taught him at a young age: loyalty to family, service to others, and unwavering advocacy
for the less fortunate.
3
Heberlig Decl. 3 (Ex. 1 letter from Richard E. Greenfield); see also id.
at 4 (Ex. 2 letter from Charlynn Goins).
Adopting the teachings of his parents came naturally to Mr. Brown. A childhood friend
remembers Mr. Browns leadership and protective instincts at the earliest of ages and writes,
When we would play in large groups of kids, Michael always made sure everyone felt included,
and he looked out for the underdog and would NEVER allow one child to be picked on or
bullied. Heberlig Decl. 5 (Ex. 3 letter from Wren M. Lester); see also id. at 6 (Ex. 4
letter from Linda Wharton Boyd) (describing how Mr. Brown as a young man had integrity and
character well beyond his years and recalling his good deeds for those in the neighborhood).
A lifelong friend recalls that Mr. Brown continued to better those around him as he grew up. She
writes:
Michael was seen as a peacemaker, always encouraging his
neighborhood friends and fellow students to get along and respect
themselves and others. He would always help his friends complete

3
Mr. Browns friends, family members, and supporters have written letters to the Court
on his behalf. Those letters not cited in this Sentencing Memorandum are attached to the
Declaration of Brian M. Heberlig (Heberlig Decl.) at Exhibit 41.
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their homework assignments and lead them in participating in
school and community service projects.
Id.
Mr. Brown married Tamara Smith-Barnes on October 5, 1991 in Washington, D.C. In
1993, Mr. and Ms. Brown had twin boys, Ryan and Morgan. Together, they raised their boys in
Washington, D.C. Numerous letters to the Court speak to Mr. Browns devotion to his sons and
his efforts to be a positive role model in their lives. Mr. Browns close friends describe him as a
wonderful father who relishes his sons and always makes their needs top priority.
Heberlig Decl. 7-8 (Exs. 5-6 letters from Tonya L. Albert and Lisa Bonner). Indeed,
Michael Woods writes, I have yet seen any father and son relationship that is any stronger.
Heberlig Decl. 9 (Ex. 7 letter from Michael Woods). Beyond his utmost dedication to his
family, Mr. Brown taught his sons the importance of serving the community and helping the less
fortunate, just as Mr. Browns father did with him. Heberlig Decl. 10 (Ex. 8 letter from
Rhonda Lampkin). Mr. Browns ex-wife writes:
As the boys were growing up, Michael always stressed the
importance of giving back to their community. Our sons went with
him to hand out Thanksgiving dinners to those who found
themselves in less than fortunate circumstances, to hand out
Christmas presents and they even played Santa Claus to young
children. By instilling that value in our sons, Michael influenced
them to continue performing community service. The boys now
know how important it is to those who need it.
Heberlig Decl. 11 (Ex. 9 letter from Tamera Brown); see also id. at 12 (Ex. 10 letter from
Laurayne Farrar-James) (describing how Mr. Brown and his sons handed out presents on
Christmas to the needy from the back of a rented truck).
Over the past months, Mr. Brown has redoubled his energies to strengthen his family ties,
especially with his sons. He knows that his conduct and its consequences have taken a toll on
those closest to him and will continue to negatively impact them in the future. Mr. Brown
7
recognizes that the consequences of the plea will be unfairly felt by those he loves most: his
mother and sons. Mr. Brown is the primary caregiver to his ailing, elderly mother. See infra
Sec. III.D.1.b.(2) (describing in greater detail Mr. Browns care for his mother). Mr. Browns
incarceration would dramatically reduce her quality of life in the years when she most needs his
care and support. The consequences of his conviction also spread to his two sons, who have
learning differences and have leaned on Mr. Brown for support in every aspect of their lives.
Heberlig Decl. 6, 11 (Exs. 4, 9 letters from Linda Wharton Boyd and Tamara Brown). For
placing this burden on his mother and sons, Mr. Brown has great remorse.
Mr. Brown also recognizes that the pain of his conviction extends beyond his mother and
sons. That pain and embarrassment extends to his younger sister and closest friends. It is a
testament to Mr. Browns true character that so many still stand behind him. The letters of
support to the Court from Mr. Browns family and lifelong friends confirm that the facts
underlying the plea are inconsistent with Mr. Browns true character. A lapse in judgment and
grievous mistakes cannot overshadow his lifetime of dedication to family, friends, and the
District.
B. Education And Early Professional Life
Mr. Brown graduated from Mackin Catholic High School, now Archbishop Carroll High
School, in Washington, D.C. In 1987, Mr. Brown received his Bachelor of Science Degree from
Clark University. Mr. Brown continued his education at the Widner University School of Law
where he earned his Juris Doctor in 1991. Mr. Brown used his education as a springboard to
pursue his familys strong values and a legacy of public service. Heberlig Decl. 6 (Ex. 4
letter from Linda Wharton Boyd).
Long-time friends admire how Mr. Brown, even as a young man, was driven to give back
to the District. Heberlig Decl. 13-14 (Exs. 11-12 letters from Karyn Greenfield and Kim
8
Greenfield Alfonso). A friend of twenty years recalls vivid examples of how Mr. Brown
dedicated his life to living out his familys civic tradition as a budding professional and
public servant. Heberlig Decl. 6 (Ex. 4 letter from Linda Wharton Boyd). She writes:
After finishing his college education, Michael returned to his
hometown and became active throughout the community. Perhaps,
his biggest contribution was with his work with youth. He
mentored young people and worked with them in developing and
participating in productive neighborhood activities. He also served
on the Board of the Whitman Walker Clinic and was among the
first in the city to speak out against prejudice behavior towards
those with HIV-AIDS.
Id.
Mr. Browns desire to give back to his community only grew over time. Mr. Browns
early professional life was defined by how he strove hard to build a reputation and to live up to
the integrity and credibility of both of his parents, as well as his grandparents. Heberlig Decl.
15 (Ex. 13 letter from Dale Cochran) (emphasis in original). Indeed, Mr. Brown dedicated
his life to public service in order to ensure that the less fortunate have greater opportunities.
Heberlig Decl. 16 (Ex. 14 letter from Maxine Mauricio).
C. Helping Others
1. Individual Acts of Kindness
Mr. Browns acts for others as a private citizen, away from the spotlight of the D.C.
Council and the media glare, speak to his huge heart. Heberlig Decl. 16-18 (Exs. 14-16
letters from Maxine Mauricio, Tracey Brown James and Nickie M. Lum Shapira Davis). The
letters of support highlight Mr. Browns selfless acts that might not make the 6 pm news.
Heberlig Decl. 19 (Ex. 17 letter from Danielle Weston). Mr. Browns acts of kindness and
selfless efforts to better the lives of those around him speak to his true character. So too do his
9
efforts to mentor and serve as a father-figure to many of his sons friends and young men in the
District.
a. Helping Others during Times of Need
Mr. Brown, regardless of either the events in his life or his schedule, always took the time
to make [others] feel like [they] matter[ed]. Heberlig Decl. 7 (Ex. 5 letter from Tonya L.
Albert) (describing how Mr. Brown reached out to her after major surgery). Andrea
Carrington, a friend of Mr. Brown for six years, writes, I have two young children, one who is
autistic. Michael has always exposed my children to various activities, and we are most
appreciative for his kindness and generosity. Heberlig Decl. 20 (Ex. 18 letter from Andrea
Carrington). Faith Danford also writes how, after meeting Mr. Brown six years ago through a
family friend, Mr. Brown became a big brother to her. Heberlig Decl. 21 (Ex. 19 letter
from Faith Danford). She writes:
When I was going through a rough time in my personal life, he
always offered words of encouragement and lifted my spirits with
his smile and genuine hugs. He was truly a great support system to
me when I needed him most without being judgmental he offered
his unconditional support and for that I am truly grateful.
Id. Lashun Kenney also speaks of Mr. Browns unsolicited efforts to help her during a moment
of need:
I was going through an extremely difficult time in my life. He
took me under his wing and provided amazing counseling. I was
involved in a volatile abusive marriage. He and our mutual friend
helped me through that grave ordeal. They stayed on the phone
with me during the night and very early hours of the morning to
ensure my safety. There were times when I slept in my vehicle to
escape my husband and get a good nights rest. [Mr. Brown] and
our mutual friend offered me shelter. They reminded me of my
worth as I suffered from self-esteem issues (a trait that many
victims of domestic violence have). There were times we would
go to dinner with a host of friends and Michael would pay for my
dinner knowing that I was financially dependent on my ex-husband
leaving my marriage was financially difficult.
10
I am healthier and mentally stronger today because of Michaels
help. . . . Michael has been a true friend and a supportive big
brother to me. He has never been too busy to help, lend an ear, or
offer sound advice.
Heberlig Decl. 22 (Ex. 20 letter from Lashun C. Kenney) (ellipsis added).
These individual acts of kindness and generosity by Mr. Brown are but a few of those
cited in the letters of support. Those same letters reveal how helping others is in Mr. Browns
fabric and lies at the core of who he is. See, e.g., Heberlig Decl. 5, 7 (Exs. 3, 5 letters from
Wren M. Lester and Tonya L. Albert). In short, Mr. Brown is nothing less than a man who I
consider to be one of the most generous with his time, advice and love. He has one of the
biggest hearts of anyone I know. Heberlig Decl. 18 (Ex. 16 letter from Nickie M. Lum
Shapira Davis).
b. Making Others Feel Like Part of the Family and Mentoring
Young African-American Men
Mr. Browns efforts to share his family ties with others speak just as loudly about his big
heart as his kindness and generosity for others. Family ties lie at the center of Mr. Browns
character, as discussed below. The letters of support are filled with examples of how Mr. Brown
served as the big brother to many. Heberlig Decl. 5, 18, 21-23 (Exs. 3, 16, 19-21 letters
from Wren M. Lester, Nickie M. Lum Shapira Davis, Faith Danford, Lashun C. Kenney and
Hilary Goins Van Kleeck). Beyond making his friends feel like they were part of the family,
Mr. Brown mentored and served as a father-figure to many of his sons friends. Heberlig Decl.
24-25 (Exs. 22-23 letters from Morgan Brown and Ryan Brown).
Mr. Browns mother and sister recall how Mr. Brown would organize dinners on Friday
nights with his sons and their friends to share laughs and a good meal. Mr. Browns sister,
Tracey, fondly recalls:
11
Michael always includes his sons friends, especially those in
unstable family situations to share meals and conversations. Our
family dinners are filled with laughter and loud conversation about
politics, dating, celebrity gossip and the classic Michael Brown
Would you rather questions. . . . As I write this I can see
everyones faces around the dinner table, lit up with joy,
thankfulness, love and good times.
Heberlig Decl. 17 (Ex. 15 letter from Tracey Brown James) (ellipsis added). Mr. Browns
mother, Alma, also recalls:
Michael has provided food and shelter to many of his sons friends
who have had difficult family lives. We have family dinner every
Friday night and the table always has at least one of the boys
friends, who all refer to Michael as their godfather.
Heberlig Decl. 26 (Ex. 24 letter from Alma Arrington Brown). It is through these dinners
and other efforts that Mr. Brown mentored and served as a father-figure to many of his sons
friends and young men in the District.
Gregory Thompson II, an elementary school friend of Mr. Browns sons, is one of those
young men who Mr. Brown mentored. He writes:
[Mr. Brown] has always been there for me when I needed help the
most. Basically, he treated me like his own flesh and blood. He
introduced a new world to me in DC. Instead of me being stuck
and trapped in a world of violence, he gave me a place to stay
when I needed [it] the most. He also fed and clothed me. He
taught me to become a leader and to fight for what I want to
accomplish most in life.
Heberlig Decl. 27 (Ex. 25 letter from Gregory Thompson II); see also id. at 4 (Ex. 2 letter
from Charlynn Goins) (noting how Mr. Brown also took into his family a young boy who needed
support and guidance and treated him as a third son); id. at 28 (Ex. 26 letter from Shantrel
Brown) (recalling how Mr. Brown served as a surrogate father to a few of his kids friends).
It is examples like Mr. Browns mentorship of Mr. Thompson that lead Colonel Brian
Albert (Ret.) both to admire Mr. Brown for his work with young African-American men and to
12
credit Mr. Brown with a critical role in their success. Heberlig Decl. 29 (Ex. 27 letter from
Brian Albert); id. at 26 (Ex. 24 letter from Alma Arrington Brown).
2. Expanding the Safety Net for District Residents as a D.C. Councilmember
The passing of Mr. Browns father in 1996 was a turning point in Mr. Browns
professional career. A family friend of the Browns who attended the funeral of Ronald Brown
recalls how Mr. Brown eulogized his father by describing his fathers guiding principles and
announcing his duty to preserve his fathers legacy and follow in his footsteps to public office.
Heberlig Decl. 30 (Ex. 28 letter from George S. Kopp). Attaining public office was more
than just a personal goal of Mr. Brown, or a means to pay tribute to his father. Public office fit
with Mr. Browns character and was a natural next step given his track record of service to the
community. Heberlig Decl. 31 (Ex. 29 letter from Tamela R. Cash-Curry). Attaining public
office in the District of Columbia was more than geographical convenience. Public office in the
District of Columbia allowed Mr. Brown to give back to his people and the city he loves.
Heberlig Decl. 32 (Ex. 30 letter from Larkin Arnold).
When Mr. Brown finally reached public office in the District of Columbia and won a
four-year term on the D.C. Council in 2008, he arrived in the midst of the countrys severe
financial crisis. Mr. Brown recognized that the economic downturn hit all of his constituents, but
hit hardest those with the least. With unemployment at record levels in the District, Mr. Brown
worked tirelessly and went above and beyond to provide much-needed services and benefits
to all of his constituents, especially those in vulnerable communities. Heberlig Decl. 14, 30,
33-34 (Exs. 12, 28, 31-32 letters from Kim Greenfield Alfonso, George S. Kopp, Norman M.
Glasgow, Jr., and Carol A. Sadler). His efforts became a catalyst for positive change;
transforming lives from poverty and despair to hope and promise. Heberlig Decl. 10 (Ex. 8
letter from Rhonda Lampkin). Linwood Rayford aptly writes, Even [Mr. Browns] harshest
13
critics must admit that he has accomplished good for the District of Columbia, especially for
some of its most disenfranchised citizens. Heberlig Decl. 35 (Ex. 33 letter from Linwood L.
Rayford, III).
Mr. Browns efforts on the D.C. Council to expand the safety net for low-income
residents in the height of the recent recession speaks to his true character, commitment to District
residents, and efforts to live by the teachings of his parents and leave the ladder down for the
less fortunate. Heberlig Decl. 10, 16, 26 (Exs. 8, 14, 24 letters from Rhonda Lampkin,
Maxine Mauricio, and Alma Arrington Brown).
a. Food Stamp Expansion Act of 2009
In 2009, Mr. Brown authored, introduced, and spearheaded through the D.C. Council the
Food Stamp Expansion Act of 2009 (Act) to fight hunger in the District. The Act significantly
expanded the eligibility for, and amount of, food-stamp assistance to District residents at or near
the poverty level. Under the Districts prior food-stamp regime, residents who had recently lost
their job would be denied food stamps if they had assets above the statutory threshold. The Act
stripped this harsh eligibility cut-off from the books. No longer did laid-off District residents
have to face an impossible choice: spending down savings in the height of a recession or
providing food for a family. By introducing and pushing the Act through the D.C. Council,
Mr. Brown strengthened the safety net for those already receiving food stamps. And his efforts
expanded that safety net to catch those who may have never thought they would need public
assistance but faced an unexpected crisis that left their families vulnerable.
14
b. Temporary Assistance for Needy Families (TANF)
Educational Opportunities and Accountability Act of 2010
In 2010, Mr. Brown co-introduced the Temporary Assistance for Needy Families
4

(TANF) Educational Opportunities and Accountability Act of 2010 (TANF Act), legislation
that helped the heads of needy families build job skills and become self-sufficient. The TANF
Act ended the harsh, unintended consequence of the Districts prior TANF framework. Under
the old law, receipt of TANF benefits was tied to certain employment benchmarks, among other
factors. This work-requirement funneled many TANF recipients with low skills into unstable,
low-wage jobs. The TANF Act co-introduced by Mr. Brown paved the way for heads-of-
households receiving TANF to become self-sufficient. The TANF Act expanded the programs
work-requirement so that participants could participate in educational or job-training courses and
build skills to be competitive in the job market. In this way, the TANF Act allowed District
residents supporting families to continue to receive financial assistance while learning skills to
secure higher paying, more stable jobs.
III. SENTENCING ISSUES
A. The Federal Sentencing Guidelines Are Advisory And Only One Of Several
Factors To Be Considered In Sentencing
The Supreme Court in United States v. Booker, 543 U.S. 220, 226-27 (2005) held that the
mandatory Sentencing Guidelines system violated the Sixth Amendment. Booker freed
sentencing courts from the rigid, formalistic framework that existed under the Guidelines.
Judges now have discretion to consider any relevant characteristic of either an offense or the
particular defendant.

4
TANF provides temporary financial assistance to unemployed residents who are
supporting a family and trying to re-enter the work force.
15
Under the Guidelines before Booker, courts were discouraged from considering factors
such as the defendants age, education and vocational skills, mental and emotional conditions,
physical condition, ties to family and the community, or civic, charitable and public service.
U.S.S.G. 5H1.1-4, 6, 11. After Booker, however, these factors are precisely the types of
considerations that sentencing courts must evaluate when determining the history and
characteristics of the defendant as required by 18 U.S.C. 3553(a)(1). See, e.g., Gall v. United
States, 552 U.S. 38, 59 (2007) (upholding district courts consideration of a defendants age).
Indeed, Booker has breathed new life into 18 U.S.C. 3661, which requires that [n]o limitation
shall be placed on the information concerning the background, character, and conduct of a person
convicted of an offense which a court of the United States may receive and consider for the
purpose of imposing an appropriate sentence. United States v. Jones, 531 F.3d 163, 173 n.6 (2d
Cir. 2008) (quoting 3661). Thus, factors disfavored by the Sentencing Commission may
[now] be relied on by the district court in fashioning an appropriate sentence. United States v.
Munoz-Nava, 524 F.3d 1137, 1148 (10th Cir. 2008) (citing Gall).
Although the Guidelines are no longer mandatory, sentencing courts are obliged to take
account of [the Sentencing Guidelines] range along with the sentencing goals Congress
enumerated in the [Sentencing Reform Act] at 18 U.S.C. 3553(a). Cunningham v. California,
549 U.S. 270, 286 (2007) (quoting Booker, 543 U.S. at 259, 264); see also Gall, 552 U.S. at 59
(the Guidelines are only one of [seven] factors to consider when imposing a sentence, and
3553(a)(3) directs the judge to consider sentences other than imprisonment); United States v.
Pickett, 475 F.3d 1347, 1351 (D.C. Cir. 2007) (The Courts remedial opinion [in Booker]
required the district court to treat the Guidelines as advisory only and as simply one factor to be
considered in sentencing.). In the post-Booker world, the court must calculate and consider the
16
applicable Guidelines range, but is not bound by it. United States v. Dorcely, 454 F.3d 366, 375
(D.C. Cir. 2006). Booker now requires district courts to consider both the Guidelines range and
other 3553(a) factors.
In particular, 18 U.S.C. 3553(a) requires that a court, in determining the sentence to be
imposed, shall consider:
(1) the nature and circumstances of the offense and the history
and characteristics of the defendant;
(2) the need for the sentence imposed --
(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
(D) to provide the defendant with needed educational or
vocational training, medical care, or other correctional
treatment in the most effective manner;
(3) the kinds of sentences available;
(4) the kinds of sentence and the sentencing range established
for --
(A) [in the Sentencing Guidelines] . . .
(5) any pertinent policy statement --
(A) issued by the Sentencing Commission . . .
(6) the need to avoid unwarranted sentence disparities among
defendants with similar records who have been found guilty
of similar conduct; and
(7) the need to provide restitution to any victims of the offense.
18 U.S.C. 3553(a) (2010) (Section 3553(a)).
The Guidelines are entitled to no greater weight than any of the other Section 3553(a)
factors. See United States v. Terrell, 696 F.3d 1257, 1261-62 (D.C. Cir. 2012) (reversing a
sentence because the sentencing court excessively weighed the Guidelines sentence in favor of
17
the Section 3553(a) factors) (citations omitted); accord Pickett, 475 F.3d at 1353-54 (explaining
that a sentencing court must evaluate how well the applicable Guideline effectuates the purpose
of [the Section 3553(a) factors] and cannot simply presume that a Guidelines sentence is the
correct sentence[,] because doing so would represent a large step in the direction of returning
to the pre-Booker regime); see also United States v. Biheiri, 356 F. Supp. 2d 589, 594 n.6 (E.D.
Va. 2005) (No individual factor is singled out as having greater weight; instead, the richness of
factual diversity in cases calls on sentencing judges to consider all of the factors and to accord
each factor the weight it deserves under the circumstances.).
B. The Stipulated Guidelines Analysis
1. The Amended Plea Agreement
Mr. Brown and the government agreed on a Sentencing Guidelines calculation as part of
his Amended Plea Agreement. (Dkt. No. 25, Ex. A). The base offense level under U.S.S.G
2C1.1(a)(1) is 14. A 6-level increase is applied under 2C1.1(b)(2) for received payments
greater than $30,000. A 4-level increase is applied under 2C1.1(b)(3) for an offense involving
a public official. Those calculations bring Mr. Browns initial offense level to 24. The parties
have agreed that a 2-level decrease is appropriate under 3E1.1 based on Mr. Browns
acceptance of responsibility. The parties have also agreed that an additional 1-level decrease is
appropriate under 3E1.1(b) because Mr. Brown assisted the government by providing timely
notice of his intention to plead guilty. The resulting Guidelines Offense Level is 21. The parties
agree that Mr. Browns Criminal History Category is I. Based on the above calculation, the
stipulated Sentencing Guidelines range is 37 months to 46 months, and, should the Court impose
a fine, the applicable Sentencing Guidelines fine range is $7,500 to $75,000.
18
Should the Court accept Mr. Browns guilty plea under Fed. R. Crim. P. 11(c)(1)(C), any
sentence of incarceration imposed by the Court may not exceed 43 months of incarceration,
followed by up to three years of supervised release.
2. The Probation Offices Pre-Sentence Investigation Report (PSIR)
The Probation Office, over both parties objection, counts under its Guidelines analysis
certain of the undisclosed campaign contributions that Mr. Brown received from Mr. Thompson
in 2008. The Court should not include these payments under the Guidelines analysis because the
uncharged campaign finance other conduct is wholly unrelated to the charged bribery offense.
The Probation Office rejects the parties agreed-upon Guidelines calculation in favor of
its own. It contends that Mr. Browns charged and uncharged conduct combined warrant an
eight-point enhancement under the Guidelines. See PSIR at 110 (Dkt. No. 31) (citing an eight-
point enhancement under U.S.S.G. 2C1.1(b)(2), 2B1.1(b)(1)(E)). The Probation Office bases
this enhancement on Mr. Browns receipt of the charged $35,000, plus his receipt of two
undisclosed campaign contributions from Mr. Thompson during his 2008 campaign. With eight
points, the Probation Office increases Mr. Browns Guidelines Offense Level to 23 and increases
his potential term of imprisonment to 46 months to 57 months. See PSIR at 119, 171 (Dkt.
No. 31).
Uncharged conduct may only be included in the Guidelines analysis if it is relevant
conduct, defined for the present purposes as conduct that was part of the same course of
conduct or common scheme or plan as the offense of conviction. U.S.S.G. 1B1.3(a)(2).
Uncharged conduct and a charged offense is only part of the same scheme or plan if the two
offenses are substantially connected by at least one common factor, such as common victims,
common accomplices, common purpose, or similar modus operandi. U.S.S.G. 1B1.3 cmt.
n.9(A). Uncharged conduct and a charged offense is only part of the same course of conduct if
19
the two offenses are sufficiently connected or related to each other as to warrant the conclusion
that they are part of a single episode, spree, or ongoing series of offenses. U.S.S.G. 1B1.3
cmt. n.9(B). Relevant factors to assess whether two offenses are sufficiently connected
include the degree of similarity of the offenses, the regularity (repetitions) of the offense, and
the time interval between the offenses. Id. A weak or absent showing in one factor requires a
stronger showing in another. Id.
In counting the uncharged 2008 campaign contributions together with the charged 2013
bribery payments, the Probation Office makes no effort to engage in this necessary, fact-
intensive analysis. See United States v. Jackson, 161 F.3d 24, 28 (D.C. Cir. 1998). The
Probation Office instead ties together these two unrelated offenses because [t]he government
provided no indication or support as to the reason these funds are not attributable to the
defendant. PSIR at 45 (Dkt. No. 31). Such conclusory statements cannot support the Probation
Offices analysis. See, e.g., United States v. Sumner, 265 F.3d 532, 540 (7th Cir. 2001) (finding
error under well established law in the sentencing courts reliance on a PSIR that failed to
explain the connection between the uncharged conduct and the offense of conviction). The
Court should reject the Guidelines analysis in the PSIR in favor of the agreed-upon Guidelines
analysis in the Amended Plea Agreement.
C. The Court Should Impose A Below-Guidelines Sentence In Recognition Of
Mr. Browns Substantial Cooperation
1. Mr. Browns Substantial Assistance in the Governments Long-Running
Investigation of Jeffrey Thompson
The government recognizes the substantial assistance Mr. Brown provided in its case
against Jeffrey Thompson. A Washingtonian businessman, Mr. Thompson recently pleaded
guilty to a roughly five-year scheme to violate campaign finance laws by secretly funneling
20
roughly $2,000,000 to candidates running for public office in the District of Columbia.
5
In
interviews with the government, Mr. Brown corroborated and confirmed the governments
evidence of Mr. Thompsons illicit role in two of his campaigns. He also provided the
government with information that tied together its evidence and strengthened a central pillar of
its case: Mr. Thompsons wrongful intent to circumvent campaign finance laws. The Court
should extend Mr. Brown substantial leniency for the substantial assistance he provided to the
government in the prosecution of Mr. Thompson.
Mr. Brown provided the government with key evidence of Mr. Thompsons unlawful
intent to make shadow campaign contributions to Mr. Brown during his 2007 campaign for a seat
on the D.C. Council. Mr. Brown told the government of a face-to-face meeting with
Mr. Thompson in Mr. Thompsons office in the spring of 2007.
6
Mr. Brown disclosed how
Mr. Thompson agreed in that meeting to provide non-public support to Mr. Browns campaign.
7

Mr. Brown corroborated the governments evidence of how Mr. Thompson concealed the
scheme by transferring this money through Eugenia C. Harris, to Mr. Brown, and ultimately to
Mr. Browns campaign.
8
Mr. Browns substantial assistance, however, extended beyond
corroboration.
9
His disclosure of this initial meeting with Mr. Thompson provided strong
evidence, unavailable from any other source, implicating Mr. Thompson.

5
Information, United States v. Thompson, 1:14-cr-00049 (D.D.C. Mar. 10, 2014) (ECF
No. 1); see also Stmt. of Off. at 17, Thompson (Mar. 10, 2014) (ECF No. 6).
6
Amended Stmt. Of Off. And Other Conduct at 72 (Dkt. No. 25, Ex. B).
7
Id.
8
Id. at 72-74, 76.
9
Mr. Brown also told the government that Mr. Thompson went by the alias Uncle Earl.
Mayoral Candidate A allegedly also referred to Mr. Thompson as Uncle Earl to mask
Mr. Thompsons identity and keep secret his unlawful contributions to the campaign of Mayoral
Candidate A. Stmt. of Off. at 27, Thompson (ECF No. 6).
21
Mr. Brown also provided substantial assistance to the governments case against
Mr. Thompson by providing similar evidence relating to Mr. Browns 2008 campaign for a seat
on the D.C. Council. Mr. Brown confirmed for the government that he received over $100,000
from Mr. Thompson to pay for get-out-the vote efforts during this campaign.
10
Beyond that
corroboration, Mr. Brown disclosed another one-on-one meeting with Mr. Thompson in October
2008.
11
Mr. Brown explained how Mr. Thompson expressly agreed at that meeting to provide
secret funding to Mr. Browns campaign, how Mr. Thompson agreed to provide Mr. Brown with
funding above the applicable campaign finance limits, and how Mr. Thompson planned to use
Ms. Harris again to provide in secret this money to Mr. Browns campaign.
12
Mr. Browns
disclosure of this one-on-one meeting tied together the governments evidence and made clear a
crucial tenet of its case: Mr. Thompsons intent to violate the campaign finance laws and
guiding hand in direct[ing] the core means to carry out that scheme.
13

Less than a month after Mr. Browns public acknowledgment that Mr. Thompson secretly
financed his 2008 campaign, and after years of denying the allegations and contentious litigation
with the government even through an appeal to the United States Supreme Court, Mr. Thompson
pleaded guilty to a two-count information charging years-long conspiracies to violate campaign
finance laws.
14
The Statement of Offense accompanying Mr. Thompsons plea agreement
describes Mr. Thompsons role in secretly funding election campaigns in the District of

10
Amended Stmt. Of Off. And Other Conduct at 81 (Dkt. No. 25, Ex. B).
11
Id. at 79.
12
Id.
13
Id. at 80.
14
See Information, Thompson (ECF No. 1).
22
Columbia, including Mr. Browns 2007 and 2008 campaigns.
15
By providing the government
with key evidence of Mr. Thompsons role in two of his elections, Mr. Brown substantially
assisted the government in its lengthy investigation of Mr. Thompson.
The Court should recognize Mr. Browns substantial cooperation in the case against
Mr. Thompson and grant him substantial leniency for his efforts.
2. Mr. Browns Substantial Assistance in Resolving the Allegations Against
Him
The government also credits the manner in which Mr. Brown resolved this case.
Mr. Brown cooperated with the government to resolve quickly its undercover investigation of
him and swiftly accepted responsibility for that conduct. He did so without publicly disclosing
the governments sources and methods of its undercover investigation of him. These efforts also
warrant substantial leniency and a substantially below-Guidelines sentence.
Mr. Brown worked with the government to resolve quickly this matter. When the FBI
confronted Mr. Brown on March 14, 2013, he was campaigning towards an April 23, 2013
special election for an at large seat on the D.C. Council. The government informed Mr. Brown
that he faced potential indictment if he did not drop out of the race. On April 2, 2013,
Mr. Brown withdrew from the race.
During these initial discussions, the government also requested that Mr. Brown keep
confidential the sources and methods of its undercover investigation of him. The government
explained that publicizing those sources and methods could jeopardize its other active
investigations. Mr. Brown again agreed not to contest publicly the governments case against
him. He also agreed not to reveal publicly the identity of Person A who, among other acts,

15
Stmt. of Off. at 52-54, 57-60, Thompson (ECF No. 6).
23
arranged the initial meeting between Mr. Brown and undercover FBI agents.
16
By maintaining a
public silence about the governments sources and methods, Mr. Brown has done nothing to
jeopardize any future government investigations.
Mr. Brown swiftly accepted responsibility for his conduct, admitted the allegations in the
Statement Of Offense And Other Conduct, and plead guilty to the one-count information on
June 10, 2013. In the same vein, the $35,000 was paid back without any need for forfeiture
proceedings.
Mr. Browns efforts to publicly accept responsibility for his actions sit in stark contrast to
other public officials in the District of Columbia implicated in wrongdoing. The Statement of
Offense of Mr. Thompson is littered with references to candidates for public office in the District
of Columbia who allegedly had direct knowledge of Mr. Thompsons illicit contributions to their
respective campaigns. Mayoral Candidate A, publicly identified by prosecutors as Mayor
Vincent Gray, allegedly knowingly received over $400,000 in unlawful support from
Mr. Thompson during a 2010 mayoral campaign.
17
Many other candidates running for seats on
the D.C. Council also allegedly knowingly received unlawful support from Mr. Thompson. D.C.
Council Candidate As campaign received over $100,000 in hidden support from Mr. Thompson
during the 2008 election cycle;
18
D.C. Council Candidate Bs campaign received over $26,000 in
secret financing from Mr. Thompson during a 2010 election cycle;
19
D.C. Council Candidate Cs
campaign received over $140,000 in secret contributions from Mr. Thompson during a 2010
election cycle; and D.C. Council Candidate Ds campaign received over $148,000 in unlawful

16
Dkt. No. 25, Ex. B at 5, 7-8.
17
Stmt. of Off. at 19, 33-34, Thompson (ECF No. 6).
18
Id. at 55-56.
19
Id. at 61-63.
24
contributions from Mr. Thompson during a 2011 election cycle.
20
According to the government,
these candidates were not unwitting participants in Mr. Thompsons schemes. Mr. Thompsons
Statement of Offense alleges each candidate knowingly received unlawful, non-public support
from Mr. Thompson.
Mr. Brown is the only individual referenced in Mr. Thompsons Statement of Offense
who has publicly admitted to knowingly accepting shadow contributions from Mr. Thompson.
Far from hiding behind a public wall of silence, Mr. Brown has publicly recognized his errors
and publicly accepted responsibility for his conduct. Mr. Brown was, and remains, the only
public figure to do so. Through his efforts, Mr. Brown has worked to clear the cloud of
uncertainty that still hangs over recent elections in the District of Columbia.
Mr. Brown has taken significant steps to own his mistakes and cooperate with the
governments investigations. The Court should extend significant leniency to Mr. Brown in
recognition of this substantial cooperation.
3. Mr. Browns Substantial Assistance as to the Governments Investigation
of Hakim Sutton for the Alleged Theft of Campaign Funds
The government also credits Mr. Browns substantial cooperation to resolve Hakim
Suttons alleged theft of funds from Mr. Browns 2012 re-election campaign account.
21
The
Court should recognize this substantial cooperation and grant Mr. Brown a lenient below-
Guidelines sentence.
Hakim Sutton, the treasurer and custodian of records for Mr. Browns 2012 re-election
campaign, allegedly stole and misappropriated over $115,000 from that campaign account.
From around May 2011 through June 2012, Mr. Sutton unlawfully diverted the campaigns funds

20
Id. at 67-71.
21
Indictment at 3, 12, United States v. Sutton, 1:14-cr-00032-RJL-1 (D.D.C. Feb. 21,
2014) (ECF No. 1).
25
to his personal use.
22
With those funds, Mr. Sutton allegedly paid for his personal expenses and
various trips around the country and even to Greece.
23
Over the course of this theft, Mr. Sutton
allegedly filed false campaign reports to cover his tracks.
24

When Mr. Brown discovered Mr. Suttons alleged theft in the summer of 2012, he
reported it to the authorities. Mr. Brown thereafter cooperated with the governments
investigation. He freely volunteered to interviews with the government, disavowed knowledge
of the alleged theft, and provided information about the surrounding circumstances. Mr. Brown
also made his campaign staff available to the government. Mr. Brown specifically facilitated the
governments interview of his legislative counsel at the time. A key source of information
regarding Mr. Browns re-election campaign, the legislative counsel provided the government
with information that advanced its investigation into the misappropriated funds.
Through Mr. Browns substantial cooperation, the government was able to investigate
fully the loss of Mr. Browns campaign funds and indict Mr. Sutton. The Court should again
recognize these efforts and grant Mr. Brown a below-Guidelines sentence.
4. Mr. Browns Assistance with the Governments Other Investigations
Over the course of his cooperation, Mr. Brown also provided the government with other
information to aid its other investigations. Mr. Brown specifically provided the government with
information to assist its investigation into the D.C. Councils vote to award a contract to run the
Districts lottery games. Mr. Brown provided the government with detailed information about
his knowledge of that contract, involvement in crafting related legislation, the contracts bidding
process, contacts with the relevant players, and considerations as to his vote on the D.C. Council.

22
Id. at 8.
23
Id. at 15, 16.
24
Id. at 14.
26
Mr. Brown was unaware of any illegalities associated with this matter. But by providing the
government with the necessary context, Mr. Brown assisted the governments investigation into
the lottery contract.
In sum, the Court should recognize Mr. Browns substantial cooperation to the
governments investigations and grant Mr. Brown substantial leniency for his efforts.
D. Mr. Browns History And Characteristics, As Well As The Nature Of His
Offense, Warrant A Lower Non-Guidelines Sentence
After evaluating the Sentencing Guidelines and calculating a potentially applicable
Guidelines range, a sentencing court must consider the remaining Section 3553(a) factors to
impose a sentence sufficient, but not greater than necessary, to comply with the purposes set
forth by Congress. Kimbrough v. United States, 552 U.S. 85, 89 (2007) (quoting
Section 3553(a)). Sentencing courts now have the obligation to consider factors that were
discouraged under the pre-Booker mandatory Guidelines regime, such as the history and
characteristics of a defendant, the nature of the offense, the need for deterrence, the likelihood of
recidivism, and the publics need for protection, because they are relevant in determining the
history and characteristics of the defendant under Section 3553(a)(1). See, e.g., Kimbrough,
552 U.S. at 93 (citation omitted); accord Jones, 531 F.3d at 172 n.6. In this case, Mr. Browns
history and characteristics, as well as the nature of his offense, strongly favor a below-Guidelines
sentence.
1. History and Characteristics
a. Community Service
Courts commonly cite service to both the community and others as when evaluating a
defendants history and characteristics as a grounds for a below-Guidelines sentence. See, e.g.,
United States v. Tomko, 562 F.3d 558, 571 (3d Cir. 2009) (en banc) (affirming a probationary
27
sentence where the sentencing court properly considered the defendants negligible criminal
history, employment record, community ties, and good works); United States v. Arthur, Case No.
04-CR-122, 2006 U.S. Dist. Lexis 93819, at *27-32 (E.D. Wis. Dec. 22, 2006) ([T]he
Guidelines do not account for the defendants significantly positive personal characteristics, as
reflected in her good works and the many letters [the court] received which depicted someone
who is caring, responsible and eager to help others); see also United States v. Mansuetto,
Criminal Action No. 5:06CR36, 2006 U.S. Dist. Lexis 72518, at *15 (N.D.W.V. Oct. 3, 2006)
(finding that the substantial amount and degree of the defendants community service, coupled
with the apparent consistency and length of time over which the defendant has served merits
some consideration as a positive sentencing factor in arriving at a variance sentence below the
Guidelines range).
Mr. Brown, both as a D.C. Councilmember and a private citizen, has consistently
advanced the principles that he learned from his parents at a young age: service to the
community and advocating for the less fortunate. Indeed, the letters of support submitted with
this memorandum contain numerous testaments to Mr. Browns service to the community. A
friend of Mr. Brown for over twenty years writes that Mr. Browns service to his community and
the less fortunate has been unparalleled. Heberlig Decl. 36 (Ex. 34 letter from Alphonso E.
Tindall, Jr.). Another life-long friend echoes that sentiment and applauds Mr. Browns tireless
work as an advocate for the poor and minorities . . . [and] accomplishments on the D.C. City
Council. Heberlig Decl. 16 (Ex. 14 letter from Maxine Maurico). This outpouring of
support reveals that Mr. Brown takes seriously advocating on behalf of the disadvantaged and
bettering the lives of those around him. See, e.g., Heberlig Decl. 35 (Ex. 33 letter from
Linwood L. Rayford, III).
28
The Court should grant Mr. Brown leniency in light of his substantial commitment to
serving others and his community. The words of the Adelson court, crediting another
defendants good works, ring true here:
[S]urely, if ever a man is to receive credit for the good he has done,
and his immediate misconduct assessed in the context of his
overall life hitherto, it should be at the moment of his sentencing,
when his very future hangs in the balance. This elementary
principle of weighing the good with the bad, which is basic to all
the great religions, moral philosophies, and systems of justice, was
plainly part of what Congress had in mind when it directed courts
to consider, as a necessary sentencing factor, the history and
characteristics of the defendant.
United States v. Adelson, 441 F. Supp. 2d 506, 513-14 (S.D.N.Y. 2006).
Mr. Brown will continue to give back to his community if given the chance. Many of the
letters of support cite to Mr. Browns much-needed leadership in the community and request that
any sentence be as short as possible so that he may continue to give back to the disadvantaged
and underrepresented groups in his hometown. Heberlig Decl. 21, 37-38 (Exs. 19, 35-36
letters from Faith Danford, Carmen R. Adams and Dwight Ferrell). Indeed, Mr. Brown has
volunteered at Youth in Media and Education (Y.I.M.A.E.) to serve at-risk youth in the
District. Cornell Stone, the CEO and founder of Y.I.M.A.E., recognizes Mr. Browns very
valuable contributions to our organization and the community and requests substantial leniency
so that Mr. Brown may build on these efforts. Heberlig Decl. 39 (Ex. 37 letter from Cornell
Stone).
We urge the Court to exercise its discretion and show Mr. Brown leniency in recognition
of both his good works for others throughout his life and ability to continue to improve the lives
of District residents.
29
b. Family Ties
Another common factor relied upon by sentencing courts to justify a sentence below the
Guidelines is the strength of the defendants family ties. See, e.g., United States v. Whitehead,
532 F.3d 991, 992-93 (9th Cir. 2008) (en banc) (affirming a sentence of probation, 1,000 hours
of community service, and restitution in lieu of 41 months to 51 months of prison in part because
the defendants eight-year-old daughter depended on him); Simon v. United States, 361 F. Supp.
2d 35, 42 (E.D.N.Y. 2005) (sentencing the defendant to a lower non-Guidelines sentence in part
because the defendant had been a caring father); see also United States v. Nellum, No. 2:04-
CR-30-PS, 2005 WL 300073, at *4 (N.D. Ill. Feb. 3, 2005) (sentencing the defendant to a lower
non-Guidelines sentence in part because of his good relationship with his children).
Mr. Browns loyalty and selflessness towards his family are as central to his character as
his commitment to helping others. From his young age, Mr. Browns family emphasized the
importance of family and looking out for each other. Heberlig Decl. 4 (Ex. 2 letter from
Charlynn Goins). This fierce loyalty grew out of the small size of Mr. Browns family. The core
of Mr. Browns family was his father, Ronald, his mother, Alma, and his sister, Tracey.
Heberlig Decl. 17 (Ex. 15 letter from Tracey Brown James).
Following his fathers death, Mr. Brown assumed the role of patriarch within his family.
He assumed that role on top of his responsibilities as caregiver to his mother, loving and
protective brother to his sister, and devoted and supporting father to his sons. Even through
trying times, such as now when his mothers health has deteriorated such that she requires
Mr. Browns constant care, Mr. Brown never complains about his family obligations.
Heberlig Decl. 13, 36 (Exs. 11, 34 letter from Karyn Greenfield and Alphonso E. Tindall,
Jr.). He instead maintains the utmost dedication to his family and continues to put family
first. Heberlig Decl. 20 (Ex. 18 letter from Andrea Carrington).
30
(1) Mr. Brown became the rock of the family with the death
of his father in 1996
After Mr. Browns father tragically passed in 1996, Mr. Brown was thrust into the role of
family patriarch. Heberlig Decl. 26 (Ex. 24 letter from Alma Arrington Brown). Leading by
example, Mr. Brown gave his family strength, support and direction. Id. Mr. Brown stepped up
for his family immediately after the accident and guided his family through the painful funeral
and memorial services of his father. Mr. Browns sister, Tracey, recalls that Mr. Brown was the
pillar of strength when he stood in front of thousands at the Washington Cathedral and eulogized
my father, privately assuring me that we would survive the overwhelming loss as I sat hopeless
and mute. Heberlig Decl. 17 (Ex. 15 letter from Tracey Brown James). After the funeral,
Mr. Brown became the rock of [his] family and gave his family strength to stop wallowing
in the loss and continue their lives. Id. It was Mr. Browns strength and leadership that kept his
family together and strong in the aftermath of his fathers death. Heberlig Decl. 30-31 (Exs.
28-29 letters from George S. Kopp and Tamela R. Cash-Curry).
(2) Mr. Brown has shouldered the responsibility of primary
caregiver to his elderly, ailing mother
Mr. Brown is the primary caregiver to his elderly, ailing mother.
25
Mr. Brown has taken
on this responsibility because his mother has no other family in the District who can take care of
her. Heberlig Decl. 14 (Ex. 12 letter from Kim Greenfield Alfonso) (noting that Mr. Browns
support has allowed Ms. Brown to live independently outside of a nursing home); id. at 26
(Ex. 24 letter from Alma Arrington Brown). Yet Mr. Brown would have accepted this
responsibility even if someone else could have. Mr. Brown shuttles his mother between her
doctors appointments, keeps her company, and looks out for her because he adores her.

25
PSIR at 131 (Dkt. No. 31); Heberlig Decl. 14, 22 (Exs. 12, 20 letters from Kim
Greenfield Alfonso and Lashun C. Kenny).
31
Heberlig Decl. 13-14 (Exs. 11-12 letters from Karyn Greenfield and Kim Greenfield
Alfonso). He firmly believes it is his responsibility to care for her, just as she cared for and
supported him when he needed it.
Mr. Brown recognizes that imprisonment often harms family members of the accused
who had nothing to do with the charged crimes. Mr. Brown has great remorse both about the
pain his actions caused his family members and how his mistakes now jeopardize his mothers
quality of life in her late years. He offers his role as caretaker for his mother as another example
that speaks to his true character and as a mitigating circumstance to his lapse in judgment and
admitted mistakes.
Ms. Browns health has deteriorated over the years. She has a number of health issues,
takes sixteen daily medications, and sees regularly six doctors for care. Heberlig Decl. 26
(Ex. 24 letter from Alma Arrington Brown); id. at 17 (Ex. 15 letter from Tracey Brown
James). Chief among Ms. Browns ailments is end-stage renal disease. PSIR at 131 (Dkt.
No. 31). This disease requires three-hour dialysis treatments, three times a week. Id.; Heberlig
Decl. 17, 26 (Exs. 15, 24 letters from Tracey Brown James and Alma Arrington Brown).
Ms. Browns eyesight is also failing. She is completely blind in her right eye; the vision in her
left eye has reduced to a snowy haziness.
26
Her partial blindness leaves her unable to travel by
herself: she is unable to drive
27
and struggles with walking. She has fallen several times,
causing head trauma and broken bones. Heberlig Decl. 17, 26 (Exs. 15, 24 letters from
Tracey Brown James and Alma Arrington Brown). This constant risk of falling requires that she
travel everywhere with a companion. Heberlig Decl. 26 (Ex. 24 letter from Alma Arrington

26
PSIR at 131 (Dkt No. 31); Heberlig Decl. 26, 40 (Ex. 24, 38 letters from Alma
Arrington Brown and Frank A. Spellman, MD).
27
PSIR at 131 (Dkt No. 31).
32
Brown). Her physical condition has so deteriorated that Mr. Brown moved in with her to care
for her. Id. Though her physical disabilities are severe and require constant attention, her mind
remains sharp and her spirit strong. Id.
Mr. Brown has become his mothers lifeline as her health has declined. Id. Numerous
letters of support speak to Mr. Browns dedication to his mother and efforts to provide her with
the care and support she needs. Heberlig Decl. 6-8, 13 (Exs. 4-6, 11 letters from Linda
Wharton Boyd, Tonya L. Albert, Lisa Bonner and Karyn Greenfield). Michaels sister, Tracey,
summarizes Mr. Browns care of his mother:
Michael is the dream child that organizes the 16 different
medication dosages that mom takes every day; that drives her to
and from dialysis treatment 3 days a week; and her myriad of
doctors appointments; he provides her with nearly every meal she
eats; he carries her to the toilet and helps her use it when she had
gone through periods where she isnt ambulatory; he chats with her
for hours while they analyze Meet the Press, or The Young and
the Restless (which they watch together when it replays at
midnight); and most importantly, he is simply there for her always.
Heberlig Decl. 17 (Ex. 15 letter from Tracey Brown James). Mr. Browns mother clarifies
the issue: Simply put, Michael is critical to my survival. Heberlig Decl. 26 (Ex. 24 letter
from Alma Arrington Brown); see also id. at 14 (Ex. 12 letter from Kim Greenfield Alfonso)
(writing that Mr. Browns care of Ms. Brown is the reason she is still with us today). A
longtime family friend of the Browns also writes, I hope that if and when I am as handicapped
as Alma, my children will care for me in such a loving way. Heberlig Decl. 4 (Ex. 2 letter
from Charlynn Goins).
Mr. Browns imprisonment would negatively impact Ms. Browns quality of life in a real
and substantial way. The imprisonment of Mr. Brown will take from Ms. Brown the solid
rock on which she depends for support, medical assistance, and the basic tasks most of us take
for granted. Heberlig Decl. 3, 6, 13, 34 (Exs. 1, 4, 11, 32 letters from Richard E. Greenfield,
33
Linda Wharton Boyd, Karyn Greenfield and Carol A. Sadler). Mr. Brown asks the Court for
substantial leniency and to make any term of imprisonment as short as possible so that the cost of
his errors are not shouldered most by those least responsible and most vulnerable.
(3) Mr. Brown has continued to be a loving and protective
older brother to his sister
Mr. Brown has always had unabashed love for his younger sister, Tracey, and was
protective of her from a young age. Heberlig Decl. 41 (Ex. 39 letter from Barbara J.
Schmitz). The letter of support from Tracey Brown James speaks to Mr. Browns generous,
caring and loving character through anecdotes that only a sister can provide. Heberlig Decl. 17
(Ex. 15 letter from Tracey Brown James). Those anecdotes reveal how Mr. Brown taught
Tracey to respect her parents when she wanted to rebel against them at a young age; cope with
her emotions in dealing with the death of their father; care for their ailing, elderly mother;
understand the struggles of friends and become more compassionate for their circumstances; and
love and support her own children without condition. Id. The acts of Mr. Brown as described in
that letter speak to his true character and support substantial leniency.
(4) Mr. Brown has been a loving and supportive father to his
two sons
Mr. Browns relationship with his sons is a true example of what a son and father should
be. Heberlig Decl. 19 (Ex. 17 letter from Danielle Weston). Mr. Brown has been both a
loving and supportive father and a role model to his two sons throughout their lives. Indeed,
when Mr. Brown told his sons of his plea, he could not have received a greater punishment than
the disappointment shown by his sons . . . . Heberlig Decl. 42 (Ex. 40 letter from Danielle
McBeth) (ellipsis added).
Mr. Brown has been an exceptional father to his twin boys and involved in their lives at
every step. Heberlig Decl. 32 (Ex. 30 letter from Larkin Arnold). From doling out parental
34
advice, driving his sons to school every day, shooting hoops with them or simply having fun,
Mr. Brown has been a supportive and engaged father. Heberlig Decl. 8, 24-25 (Exs. 6, 22-23
letters from Lisa Bonner, Morgan Brown and Ryan Brown). When his boys struggled in
school from their learning differences, Mr. Brown made sure they got all of the resources and
services they needed, but more importantly, he made sure that their self-esteem stayed intact and
they didnt get discouraged by the challenges that they face. Heberlig Decl. 17 (Ex. 15
letter from Tracey Brown James).
Beyond providing essential support to his sons, Mr. Brown also served as their role
model. His boys looked up to him. Morgan writes how he always wanted to be just like my
dad. I planned on going to law school and becoming a city council member in DC, just like
him. Heberlig Decl. 24 (Ex. 22 letter from Morgan Brown).
Mr. Brown recognizes that he let down his sons and failed to live up to the high standard
he held out for them throughout their lives. He has great remorse that his conduct has both
distracted his sons as they have transitioned into young adults and served as source of pain and
embarrassment. Heberlig Decl. 34 (Ex. 32 letter from Carol A. Sadler) (noting how this
[plea] has been extremely difficult to [Mr. Browns] sons to cope with); id. at 24-25 (Exs.
22-23 letters from Morgan Brown and Ryan Brown).
Mr. Brown respectfully requests that the Court balance the grave mistakes now before it
against Mr. Browns lifetime of being a loving and supportive son, brother, and father. Those
strong family ties reveal that Mr. Brown is far more than the person represented by the conduct
now before the Court. Mr. Browns true character cuts in favor of substantial leniency.
2. Nature and Circumstances of the Offense
Mr. Browns financial circumstances leading up to, and throughout, the charged conduct
led him to take otherwise inconceivable acts given his true character. He took actions on behalf
35
of Company M to secure money that he desperately needed to stay afloat financially and not
drown under his financial undoing.
28

Mr. Brown seeks leniency from the Court, not pity. He acknowledges that his income
exceeded that of many District residents, including many of his former constituents. So too does
Mr. Brown recognize that those same District residents make ends meet on far less. He also
admits that his deteriorating financial condition was partly of his own undoing. Mr. Brown
overextended himself to cover his expenses. Some of those expenses supported a lifestyle that
he could no longer maintain as his income dropped each year after 2009 and fell roughly 38% in
2012 from its 2009 peak.
29
Other expenses were unexpected, such as improvements and
maintenance needed to sell his marital home and substantial legal bills for a now-finalized
divorce. He sank deeper into a financial hole once he realized in the summer of 2012 that his
war chest for his 2012 re-election campaign had been emptied, allegedly by Hakim Sutton. He
collapsed under the weight of his unsustainable expenses, personal and family commitments, and
the re-financing of his re-election campaign.
None of Mr. Browns circumstances excuse his conduct. He recognizes that he failed to
meet not only his own moral code but also the higher standard expected of public officials. He
never should have put himself in the position he now finds himself and accepts full responsibility
for his actions. He offers his deteriorating financial condition not to explain away his grave
errors but as mitigating evidence in a request for leniency.
Prior to the first meeting with undercover FBI agents posing as representatives of
Company M, Mr. Brown found traditional lending options closed off to him. He was a credit
risk to banks: underwater on his mortgage and without further room to tap a line of credit

28
Mr. Brown remains deeply in debt. See PSIR at 159 (Dkt. No. 30).
29
PSIR at 167 (Dkt. No. 30).
36
against his marital home. Nor did he feel he could ask his friends and family for money. He
considered, but ruled out, asking his mother for a loan. She had helped him out so many times
before, and at that time her health was deteriorating rapidly. Mr. Brown considered asking his
sister for a loan but did not. She too had helped out before and had her hands full raising her
own family in New York City. Mr. Brown considered asking a family friend, but embarrassment
and pride stopped him from disclosing his financial situation.
Believing he had no good options to secure financial assistance, Mr. Brown had the poor
judgment to turn to the worst option: discussing with Person A the possibility of securing a
loan from government contractors known to Person A.
Again, Mr. Brown reiterates that nothing excuses his conduct. He takes full
responsibility for his actions and admits wrongdoing. He offers his financial undoing only as a
mitigating circumstance to explain why he took actions so inconsistent with his true character.
The conduct that now brings him before the Court is inconsistent with his life of good deeds for
others, service to his community, and devotion to family. See, e.g., Heberlig Decl. 31, 41-42
(Exs. 29, 39-40 letters from Tamela R. Cash-Curry, Barbara J. Schmitz and Danielle McBeth).
Mr. Brown respectfully requests leniency and a sentence that weighs his grave mistake against
the whole of his life and recognizes:
The Michael who rocks my mother back and forth and soothes her
when she is in the middle of a grand mal seizure as they wait for
the ambulance. The Michael whose favorite activity is grocery
shopping with his family because it means he is getting things for
family gatherings. The Michael who regularly takes his kids with
him to soup kitchens, community centers, and homeless shelters so
that they can understand the tough plight that many face and lend a
hand to help lift them up. The Michael who held my hand and
cracked jokes as my son made strides in the NICU after being born
prematurely. . . . The Michael who brings light, strength, love, and

37
laughter to our lives. This is the Michael who should be shared
with the world, not incarcerated.
Heberlig Decl. 17 (Ex. 15 letter from Tracey Brown James) (ellipsis added).
3. Substantial Leniency Would Avoid Unwarranted Sentence Disparities
among Defendants Sentenced to Similar Conduct
Section 3553 also requires sentencing courts to impose a sentence that will avoid
unwarranted sentence disparities among defendants with similar records who have been found
guilty of similar conduct[.] 18 U.S.C. 3553(a)(6). Substantial leniency for Mr. Brown would
be consistent with post-Booker sentences for public officials who violated 18 U.S.C. 201(b)(2)
through similar conduct. A below-Guidelines sentence would also avoid disparities among
Mr. Browns sentence and other sentences imposed recently on public officials who were
convicted of greater misconduct than that before the Court.
Substantial leniency for Mr. Brown would be consistent with post-Booker sentences for
public officials who violated 18 U.S.C. 201(b). The court in United States v. Fisher, for
example, rejected the governments recommendation for a Guidelines sentence of 24-30 months
and sentenced the defendant to 18 months for accepting $40,000 in bribes over a four-year period
in violation of 18 U.S.C. 201(b).
30
The court in United States v. Minor similarly declined the
governments request for a Guidelines sentence of 37 months and handed down a 30-month
sentence to a defendant who flagrantly abused his position . . . to enrich himself by awarding
jobs to government contractors who, in return, paid the defendant kickbacks totaling $118,000
over a period of several years.
31

30
Judgment at 2, United States v. Fisher, 1:08-cr-00012-RMU (D.D.C. June 12, 2008)
(ECF No. 33); see also USA Sent. Mem. at 17, Fisher (May 9, 2008) (ECF No. 25).
31
Judgment at 2, United States v. Minor, 1:11-cr-00131-RMU (D.D.C. Nov. 11, 2011)
(ECF No. 38); see also USA Sent. Mem. at 1, Minor (Sept. 1, 2011) (ECF No. 32).
38
Both Minor and Fisher argue strongly in favor of substantial leniency for Mr. Brown.
First, substantial leniency for Mr. Brown would recognize that his conduct does not approach
either the breadth or scope of the misconduct of the Minor defendant. The Minor defendant
received three times more money than Mr. Brown and engaged in pervasive misconduct over
several years. Yet the Minor defendant still received a below-Guidelines sentence of 30 months.
Mr. Brown respectfully submits that his sentence should fall below that of the Minor defendant
to account for the nature and circumstances of Mr. Browns offense.
Second, Mr. Browns substantial cooperation with the government cuts in favor of
substantial leniency and a sentence well below that of the Minor and Fisher defendants. Both
the Minor and Fisher defendants received leniency and a below-Guidelines sentence even though
neither defendant provided substantial cooperation to the government.
32
Mr. Brown, by contrast,
has provided such cooperation. The Court should recognize the value of Mr. Browns
cooperation and grant him further leniency in keeping with the sentences of both Minor and
Fisher and the other sentencing factors discussed in this memorandum.
The sentences handed down recently to other elected officials for misconduct more
pervasive than that of Mr. Brown also weighs in favor of substantial leniency. Former
Congressman Robert Ney, for example, pleaded guilty to selling legislative favors and official
acts in exchange for all-expense-paid trips to golfing and gambling locales, substantial campaign

32
Defendant Minors sentencing memorandum noted that [d]espite numerous meetings
with the government, the Defendant has not been able to produce results sufficient to cause the
government to make a substantial cooperation motion pursuant to U.S.S.G 5K1.1. Def. Sent.
Mem. at 1, Minor (Oct. 19, 2011) (ECF No. 34). Defendant Fishers sentencing memorandum
also referenced his cooperation but noted that he could not provide substantial assistance to the
government. Def. Sent. Mem. at 26, Fisher (May 5, 2008) (ECF No. 24).
39
contributions, meals, tickets to sporting events, and other illegal benefits.
33
Judge Huvelle
sentenced Rep. Ney to 30 months.
34
Former D.C. Councilman Harry Thomas similarly abused
his office to steal more than $350,000 of public funds earmarked for youth programs.
35
The
government argued that the scope and gravity of Councilman Thomass theft warranted a jail
term at the top of the Guidelines range of 37 months to 46 months.
36
Judge Bates sentenced
Councilman Thomas to 38 months.
37

Substantial leniency is appropriate for Mr. Brown because his conduct, while serious and
improper, does not approach either Rep. Neys pervasive misconduct of selling legislative acts
for handouts or Councilman Thomass theft of public funds ten times the amount at issue here.
Yet Rep. Ney received a sentence of 30 months, and Councilman Thomas received a sentence 38
months.
Undersigned counsel also recently represented two former public officials who received
below-Guidelines sentences. Former-Congressman Jesse Jackson Jr. pled guilty to the personal
use of approximately $750,000 in campaign funds.
38
Although the government sought a
sentence of 48 months
39
and former-Congressman Jackson did not provide substantial assistance
to the governments investigations, Judge Berman Jackson sentenced former-Congressman

33
Factual Basis for the Plea of Robert W. Ney, United States v. Ney, 1:06-cr-00272-ESH
(D.D.C. Oct. 13, 2006) (ECF No. 5) (describing the pervasive bribery of Rep. Ney).
34
Judgment at 2, Ney (Jan. 23, 3007) (ECF No. 20).
35
USA Sent. Mem. at 1, United States v. Thomas, 1:12-cr-00003-JDB (D.D.C. Apr. 27,
2012) (ECF No. 16).
36
Id. at 1, 8.
37
Judgment at 2, Thomas (May 21, 2012) (ECF No. 24).
38
Stmt. of Off. at 2, United States v. Jackson, 1:13-cr-00058-ABJ-1 (Feb. 20, 2013)
(ECF No. 9).
39
USA Sent. Mem. at 1, Jackson (June 7, 2013) (ECF No. 26).
40
Jackson to 30 months, well below the applicable Guidelines range.
40
Former-Congressman
Richard Renzi was also convicted at trial on public corruption and other offenses.
41
Although
former-Congressman Renzi did not provide substantial cooperation to the governments
investigations and the government argued for a sentence of between nine years and twelve
years,
42
the court sentenced him to 36 months of imprisonment.
43

Mr. Brown should receive a sentence far below these former officials to account for the
nature and circumstances of his offense, substantial cooperation, track record of good acts, and
strong family ties.
E. There Is No Need To Protect The Public Through A Prison Sentence Because
There Is No Chance of Recidivism
In determining an appropriate sentence, courts must also consider the need for the
sentence to protect the public from further crimes of the defendant. 18 U.S.C. 3553(a)(2)(C).
Two key indicators are tied to the likelihood of recidivism: the defendants age at the time of
sentencing and criminal history. A non-Guidelines sentence is appropriate in the case of an
elderly offender because the Sentencing Guidelines do not take into account how defendants who
are over the age of forty exhibit markedly lower rates of recidivism in comparison to younger
defendants. United States v. Carmona-Rodriguez, No. 04 CR 67 (RWS), 2005 WL 8400464, at
*4 (S.D.N.Y. Apr. 11, 2005) (citations omitted); see also Simon v. United States, 361 F. Supp. 2d
35, 48 (E.D.N.Y. 2005) (sentencing forty-three-years-old defendant to a lower non-Guidelines
sentence because, [t]he Guidelines failure to account [for the correlation between increased age

40
Judgment at 2, Jackson (Aug. 19, 2013) (ECF No. 56).
41
Judgment at 1, United States v. Renzi, 4-08-cr-00212-DCB-BPV (D. Az. Oct. 28, 2013)
(ECF No. 1318).
42
USA Sent. Mem. at 2, Renzi (Oct. 21, 2013) (ECF No. 1307).
43
Judgment at 1, Renzi (ECF No. 1318). Former-Congressman Renzi is appealing his
convictions.
41
and decreased recidivism rates] renders it an imperfect measure of how well a sentence protects
the public from further crimes of the defendant.); United States v. Hernandez, No. 03 CR 1257
(RWS), 2005 WL 1242344, at *5 (S.D.N.Y. May 24, 2005) (imposing a lower non-Guidelines
sentence on a forty-nine-years-old defendant for a similar reason).
At forty-nine years old, Mr. Browns likelihood of recidivism is zero. His criminal
history is also minimal, save a fifteen-year-old misdemeanor plea to making contributions to a
federal political campaign above the statutory limit. See United States v. Brown, 1:97-cr-00336-
RMU-1 (D.D.C. 1997); see also PSIR at 121-29 (Dkt. No. 31). This misdemeanor has little
relevance, if any, in assessing Mr. Browns threat to the public in light of his other good deeds
and acts. See, e.g., United States v. Edwards, 595 F.3d 1004, 1009, 1115, 1117 (9th Cir. 2010)
(affirming the district courts sentence and findings that the defendant convicted of two fraud
offenses was no threat to the public, despite another felony fraud conviction nine years earlier,
and ordering a sentence of probation where the Guidelines range was 27 months to 33 months).
Put simply, Mr. Brown is not an individual who poses any threat to society. Quite the
opposite, Mr. Brown would continue to advocate for the disadvantaged and better the lives of
District residents if allowed the opportunity. See, e.g., Heberlig Decl. 21, 33, 38 (Exs. 19, 31,
36 letters from Faith Danford, Norman M. Glasgow, Jr. and Dwight Ferrell). Substantial
leniency is therefore appropriate.
IV. CONCLUSION
Mr. Brown has always been defined by his strong family ties, good works for others, and
service to District residents. The charged conduct is inconsistent with his true character and a
grave misstep brought about by financial desperation and clouded judgment. His plea has
tarnished the legacy of his father and torn apart his family. Even more, his conduct has
jeopardized the health and wellbeing of his elderly, ailing mother at a time she most needs his
42
care. Mr. Brown has done everything in his power to correct his mistakes. He has
acknowledged his errors before the Court and those closest to him, strengthened his family ties,
and provided substantial assistance to the government in its investigations. If given the chance,
Mr. Brown will continue to make amends and better the lives of those in his hometown.
In sum, Mr. Brown respectfully requests a substantially below-Guidelines sentence.
Respectfully submitted,

/s/ Brian M. Heberlig
Reid H. Weingarten (D.C. Bar #365893)
Brian M. Heberlig (D.C. Bar #455381)
Scott P. Armstrong (D.C. Bar #993851)
Steptoe & Johnson LLP
1330 Connecticut Avenue, N.W.
Washington, D.C. 20036-1795
(202) 429-3000
rweingarten@steptoe.com
bheberlig@steptoe.com
sarmstrong@steptoe.com

Counsel for Defendant Michael A. Brown

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

)
UNITED STATES, )
)
v. ) Case No. 1:13-cr-00164-RLW
)
MICHAEL A. BROWN, )
)
Defendant. )
)

DECLARATION OF BRIAN M. HEBERLIG IN SUPPORT OF
DEFENDANT MICHAEL A. BROWNS SENTENCING MEMORANDUM

Pursuant to 28 U.S.C. 1746, I, Brian M. Heberlig, hereby declare:
1. I am an attorney representing Defendant Michael A. Brown in this case.
2. I am submitting this declaration in support of Defendant Michael A. Browns
Sentencing Memorandum.
3. Attached as Exhibit 1 is a copy of a letter from Richard E. Greenfield, dated
August 15, 2013.
4. Attached as Exhibit 2 is a copy of a letter from Charlynn Goins, dated August 12,
2013.
5. Attached as Exhibit 3 is a copy of a letter from Wren M. Lester, dated July 28,
2013.
6. Attached as Exhibit 4 is a copy of a letter from Linda Wharton Boyd, dated
August 13, 2013.
7. Attached as Exhibit 5 is a copy of a letter from Tonya L. Albert, dated August 12,
2013.
8. Attached as Exhibit 6 is a copy of a letter from Lisa Bonner, dated August 15,
2013.
9. Attached as Exhibit 7 is a copy of a letter from Michael Woods, dated August 7,
2013.
10. Attached as Exhibit 8 is a copy of a letter from Rhonda Lampkin, dated
August 10, 2013.
Case 1:13-cr-00164-RWR Document 34-1 Filed 04/24/14 Page 1 of 4
- 2 -

11. Attached as Exhibit 9 is a copy of a letter from Tamera Brown, dated August 11,
2013.
12. Attached as Exhibit 10 is a copy of a letter from Laurayne Farrar-James, dated
August 28, 2013.
13. Attached as Exhibit 11 is a copy of a letter from Karyn Greenfield, dated
August 15, 2013.
14. Attached as Exhibit 12 is a copy of a letter from Kim Greenfield Alfonso, dated
August 11, 2013
15. Attached as Exhibit 13 is a copy of a letter from Dale Cochran, dated July 10,
2013.
16. Attached as Exhibit 14 is a copy of a letter from Maxine Mauricio, dated July 18,
2013.
17. Attached as Exhibit 15 is a copy of a letter from Tracey Brown James, dated
August 21, 2013.
18. Attached as Exhibit 16 is a copy of a letter from Nickie M. Lum Shapira Davis,
dated July 20, 2013.
19. Attached as Exhibit 17 is a copy of a letter from Danielle Weston, dated
August 14, 2013.
20. Attached as Exhibit 18 is a copy of a letter from Andrea Carrington, dated
August 15, 2013.
21. Attached as Exhibit 19 is a copy of a letter from Faith Danford, dated August 13,
2013.
22. Attached as Exhibit 20 is a copy of a letter from Lashun C. Kenney, dated
August 11, 2013.
23. Attached as Exhibit 21 is a copy of a letter from Hilary Goins Van Kleeck, dated
August 13, 2013.
24. Attached as Exhibit 22 is a copy of a letter from Morgan Brown, dated April 7,
2014.
25. Attached as Exhibit 23 is a copy of a letter from Ryan Brown, dated September 8,
2013.
26. Attached as Exhibit 24 is a copy of a letter from Alma Arrington Brown, dated
April 20, 2014.
- 3 -

27. Attached as Exhibit 25 is a copy of a letter from Gregory Thompson, II, dated
August 22, 2013.
28. Attached as Exhibit 26 is a copy of a letter from Shantrel A. Brown, dated
August 28, 2013.
29. Attached as Exhibit 27 is a copy of a letter from Brian Albert, dated August 23,
2013.
30. Attached as Exhibit 28 is a copy of a letter from George S. Kopp, dated
August 12, 2013.
31. Attached as Exhibit 29 is a copy of a letter from Tamela R. Cash-Curry, dated
August 20, 2013.
32. Attached as Exhibit 30 is a copy of a letter from Larkin Arnold, dated August 12,
2013.
33. Attached as Exhibit 31 is a copy of a letter from Norman M. Glasgow, Jr., dated
July 30, 2013.
34. Attached as Exhibit 32 is a copy of a letter from Carol A. Sadler, dated August 1,
2013.
35. Attached as Exhibit 33 is a copy of a letter from Linwood L. Rayford, III, dated
August 5, 2013.
36. Attached as Exhibit 34 is a copy of a letter from Alphonso E. Tindall, Jr., dated
August 2, 2013.
37. Attached as Exhibit 35 is a copy of a letter from Carmen R. Adams, dated
August 11, 2013.
38. Attached as Exhibit 36 is a copy of a letter from Dwight Ferrell, dated August 15,
2013.
39. Attached as Exhibit 37 is a copy of a letter from Cornell Stone, dated April 16,
2014.
40. Attached as Exhibit 38 is a copy of a letter from Frank A. Spellman, dated
August 1, 2013.
41. Attached as Exhibit 39 is a copy of a letter from Barbara J. Schmitz, dated July 1,
2013.
42. Attached as Exhibit 40 is a copy of a letter from Danielle McBeth, dated
August 14, 2013.
- 4 -

43. Additional letters in support of Mr. Browns Sentencing Memorandum are
attached as Exhibit 41.

Brian M. Heberlig

EXHIBIT 1
EXHIBIT 2
EXHIBIT 3
EXHIBIT 4
_________Linda Wharton Boyd, Ph.D___________

August 13, 2013

The Honorable Robert L. Wilkins
United States District Court for the District of Columbia
333 Constitution Avenue, NW
Washington, DC 20001

Dear Judge Wilkins:

I am writing in strong support of Michael A. Brown (Criminal Case No. 13-cr-00264-RLW-1). I am aware
that Michael has entered into a plea agreement with the government and I fully believe he is deserving
of leniency in his sentencing.

I have known Michael for more than twenty eight years as a young lad, a budding professional and a
public servant. Having been raised in a family with strong values and a legacy of public service, Michael
dedicated his life to living out his familys civic tradition.

As a young man, Michael demonstrated leadership skills well beyond his years. He was always willing to
lead his peers in helping others. Respectful of the elderly, Michael would often find ways to make their
life a little easier. At any time, you could find him helping seniors with groceries, crossing the street, or
just spending a little talk time to make them feel valued.

As a young leader, Michael was seen as a peacemaker, always encouraging his neighborhood friends and
fellow students to get along and respect themselves and others. He would help his friends complete
their homework assignments and lead them in participating in school and community service projects.

After finishing his college education, Michael returned to his hometown and became active throughout
the community. Perhaps, his biggest contribution was his work with youth. He mentored young people
and worked with them in developing and participating in productive neighborhood activities. He also
served on the Board of the Whitman Walker Clinic and was among the first in this city to speak out
against prejudice behavior toward those with HIV-AIDS.

Years later when I had the opportunity to serve with Michael as his Chief of Staff and Communications
Director at the Council of the District of Columbia, I saw in him the same character and servant qualities
he exhibited as a young man. While serving on the Council, I witnessed in him a dedication to duty and
commitment to the residents of the city. He introduced bills that expanded the number of residents
eligible to receive food stamps during the height of this countrys recent financial downturn. He also
introduced a bill revising the First Source Act, which increased the hiring of District residents on city
funded project. In addition, he held business summits and roundtables for minority contractors and
vendors and reached to the creative economy community to include them in the discussion of business
opportunities.

With a great sensitivity to the concerns for others, Michael would often extent himself personally to
support the needs of others. Using his personal resources, he would assist constituents with utility
payments, and with the purchase of food, clothing and medical expenses.

Although he was busy with his community and professional obligations, Michael was also dedicated to
his family. As a devoted father, he is active in the life of his sons and is an essential part of ensuring that
their learning differences are addressed. He is there for them all the time and they need the constant
and consistent support of their father. As a son, Michael is the solid rock on which his mother stands
and depends on for support, medical assistance and basic daily living, especially during at this time of
her fragile medical condition.

Michael has always been committed to his family and I believe that he is very remorseful for his actions.
While his missteps and lapse in judgment are uncharacteristic, I believe his core principles and character
remain strong.

I do not believe Michael A. Brown is a danger to society. He deserves a second chance. Moreover, with
the costs and stigma associated with incarceration, I believe his proven leadership would be put to much
better use in serving his local community in Washington, DC.

Thank you in advance for your consideration. Please feel free to contact me should you have any
questions.

Sincerely,

Linda Wharton Boyd, Ph.D.

EXHIBIT 5
August 12, 2013


Dear Judge Wilkins:

I am writing in strong support of Michael A. Brown (Criminal Case
No. 13-cr-00264-RLW-1). I am aware that Michael has entered
into a plea agreement with the government, and I fully believe he
is deserving of leniency in his sentencing.

I have known Michael for over eight years and was introduced to
him by a mutual friend at an event. I was immediately impressed
by his demeanor, gentleman approach, posture and
professionalism. In that instant I could tell that he was a man of
purpose. During the course of our friendship, I have had the
opportunity to be in his company on numerous occasions
including celebrating birthdays; hosting/attending fundraisers on
his behalf; attending Congressional Black Caucus events; and
enjoying dinner parties at my home. I am a strong supporter
because I know that his heart is in the right place. He cares about
the community, his family, and is always willing to help where
there is a need. He has offered his assistance when I was seeking
to resolve an issue or in need of guidance, information or
direction. He would gladly help not because of his position or job
title, but because that is the person he is. It is part of his fabric
and character. Michael relishes his mother and sons. He always
makes their needs top priority. I always hear him lovingly
reference that he had to take his mom to her doctors
appointment or be her travel companion to ensure her safety. He
is a dedicated son, father, friend and community leader.
Regardless of his hectic schedule, he always makes you feel as if
you matter. A few years ago, I had major surgery and Michael
personally reached out to me to extend well wishes. He even
asked for prayers on my behalf from his constituents without
calling me by name -- he only mentioned that he had a friend who
needed prayer.

I understand that Michael is very remorseful for his actions. I do
not believe he is a danger to society and deserves a second
chance. Moreover, with the costs and stigma associated with
incarceration, I believe his proven leadership would be put to
much better use serving his local community in Washington, DC. I
ask that you have mercy and not sentence Michael to any jail
time.

Thank you in advance for your consideration. Please contact me if
you have any questions at

Sincerely,

Tonya L. Albert

Tonya L. Albert

EXHIBIT 6
EXHIBIT 7
micjhai:l woods, mu face?
August 7,2013
'I'he Honorable Robert L. Wilkins
United Slates district C^ourt for ihe District of Columbia
333 Constitution Avenue, XVV
Washington. DC 20001
Dearjudge Wilkins,
I am writing this letter with the understanding that Michael A. Brown has
entered into a plea agreement. Thank you for taking time to read m\ let
ter in support of Michael A. Brown who I have known for 35 years. We
grew up together in Northwest Washington, DC and though I now reside
in Indiana since 1998, we have been able to maintained a close friendship.
I moved to Indiana after completing my residency in Emergency Medicine
at Howard University Hospital. As an Emergency Medicine Physician, I
interact daily with an array of personality types.
One thing that is for certain is that Michael is a good and decent man. He
has always shown the upmost respect to me and my family to his family
and friends and to society. He is upbeat, gregarious and emotionally
grounded. I have never heard him talk in a negative way about anyone
nor seen him mad about anything. If there is something anyone needed
he has always been generous in giving kindness as well as emotional and
financial support.
One highlight that deserves mentioning is his love and support of twin
sons. I have yet seen any father and son relationship that is any stronger.
He loves his boys and would do anything for them. The stories he tells mc.
about them shows me how much they love him back. His sons truly get
their guidance from Michael and not from their peers, a rarity now a days.
Michael has told me that he has fully disclosed his current situation to
them and have talked about it e.xtensivelv.
EXHIBIT 8
August 10, 2013


Dear Judge Wilkins:

My name is Rhonda Lampkin, and I am writing in support of Michael A. Brown (Criminal Case
No. 13-cr-00264-RLW-1). I am aware that Michael has entered into a plea agreement with the
government, and I prayerfully and sincerely believe he is deserving of leniency in his sentencing.

I have known Michael for over ten years. Prior to our official introduction, I admired Michael
from afar merely from observing his public works and community engagement. As a resident
of the state of Mississippi, Ive not had an opportunity to interface with community leaders in
our nations capital until I met Michael. He was very approachable and willingly shared his
insight and vision for enhancing the quality of life for individuals in underserved communities
and beyond. His compassion for people and their plight was an attribute that served as a
catalyst for positive change; transforming lives from poverty and despair to hope and promise.

Since Ive known Michael, not only has he shown a remarkable commitment to his community,
hes demonstrated the utmost dedication to his family. Hes a doting father of two outstanding
and respectful young men, loving brother and caring son. His parents taught him the difference
between right and wrong and instilled strong Christian values in him. Michael instilled those
same Christian values in his children by teaching and living an upright life before them.

My experience with Michael Brown has been very positive and inspirational. He has always
been a respectful hard working individual with great leadership qualities and sound moral
values. I was always able to see the respect that he had for his parents, siblings and others. That
respect served as his guiding principle to do the right things throughout life.

I understand that Michael is contrite and remorseful for his actions. I do not believe he is a
threat to society and deserves a second chance. Moreover, with the expense and stigma
associated with incarceration, I believe his successful track record as a proven leader would be
better utilized serving his local community in Washington, DC.

Thanks for considering this letter. If you need any additional information I can be reached at

Sincerely,

Rhonda Lampkin
EXHIBIT 9
EXHIBIT 10
Ms. Laurayne Farrar-James

August 28, 2013

U.S. District Court, D.C.
333 Constitution Avenue N.W.
Washington, D.C. 20001

Dear Honorable Robert L. Wilkins:
Thank you for this moment in time to convey to you a matter that is written on my heart.

I am an octogenarian residing in my hometown of Bridgeport, CT, where I continue to do
public service work and give back to the community. I am a frontline educator, and
advocate for children and parents. In 1985 I entered a political race and was elected to
the Bridgeport City Council and served as one of the rst females ever elected from my
councilmanic district.

In 1962, I launched a career in the civil rights movement. Dr. Martin Luther King, Jr.,
hired me to be his local coordinator in Richmond, VA. It was during this period that I
developed a deeper knowledge of and commitment to social and economic justice.

I was named by Gov. Jodi Rell (CT) in 2003 as recipient of the 100 Outstanding
Women of Connecticut Award. I felt very honored, however in my lifetime; the
accomplishment that brings me the greatest joy is the nurturing and the care for my
three sons who today are grown men of purpose and distinction. They serve the
population with excellence in their chosen professions.

I have known Michael Brown and his family for a few decades and at least one of his
family members for more than 30 years. Michaels sister is married to my youngest son.
I count it a blessing that God has put people like the Brown family in my life, and I know
that the feeling is mutual. We care deeply about each other. Such is the genesis of
Michaels core; the quality of his heart. He cares about people and has compassion for
those who seem unable to defend or care for themselves.

I remember; for a few Christmases Michael and his immediate family (wife and twin
boys) missed the traditional Christmas Eve festivities at the Amoss home. His concern
and focus was for those who lacked the resources to participate in and enjoy the spirit
of the holiday. Michael rented a truck, lled it to capacity with toys, winter clothing for
children, all ages, nonperishable food items for whole families, and bath towels,
toiletries and other related items. They spent the night and the early dawn delivering
and bringing the spirit of Christmas to those who would perhaps have nothing to bring
them some semblance of joy and gladness.
Today.... I pray that a truck lled to capacity with pardon and forgiveness will pull up to
Michaels doorstep and unload, to redeem him out of this dark place he is currently in.
He confesses his iniquity and repents for having made such a thoughtless, reckless
decision to disregard the law and his self-respect.

It is my fervent prayer that this breach will not determine a bleak fractured future for him
and his family, but rather be used somehow to lift others out of despair; perhaps urban
youth, through mentoring and other learning techniques . . . thus becoming a beckon
light for transformation.

Prayerfully Submitted,

Laurayne Farrar-James
EXHIBIT 11
August 15, 2013

United States District Court of the District of Columbia

Your Honor:

I am sending this letter requesting your leniency when sentencing Michael Arrington Brown on October
3, 2013.

Michael has been a long family friend. I have known Michael for over 30 years, since his family first
moved to Washington, D.C. Michael and my younger brother have been best friends almost since that
time, and Michael spent a lot of time in our home over the years. Michael was and still is considered a
part of our family. He was always welcomed in our home, and grew up into a well respected young man
with a drive towards public service and giving back to the community. That is one of the things I admired
about Michael.

I have watched Michael over the past few years, as he has raised two respectful, nice young sons, as well
as watching over any of their young friends he felt needed additional guidance or support. I have also
watched him take care of his ill mother with the dedication and compassion that is Michael. He never
complains and has made decisions that always put his mother and his family in the forefront. I am
particularly concerned that an extended prison term for Michael would be detrimental to his mother's
health and well being, as he functions as her primary caregiver. In addition, as Michael's twin sons are
now in college, a lengthy prison term would also have a significant impact on his twin sons' financial
obligations at college, as well as their general well-being in being without a much-needed father figure in
this important phase of their lives.

I am aware of the events regarding Michael's guilty plea, and that he is accepting full responsibility, and I
expect nothing less of Michael. I know Michael and his family are very upset over what they are
experiencing at this most critical time in their lives. I know Michael regrets the decisions and actions that
led up to this event, and cannot imagine that he will ever repeat any illegal offenses. I feel Michael's time
would be better served providing community service and educating young people on the dangers of
committing crime, rather than serving jail time. I strongly believe that any sentence for wrongdoing
should not just be for punishment, but also rehabilitation and repayment to the community impacted.

Because of the significant difficulties that will be faced by this very small, and close knit loving family, I
plead that you grant Michael Brown leniency upon sentencing.

Respectfully,

Karyn Greenfield, Esq.

EXHIBIT 12
August 11, 20013


Your Honor:

I am writing to request your compassion and leniency when sentencing Michael
Arrington Brown on October 3rd.

I have known Michael since 1973, when the Brown family moved from New York to our
neighborhood in Washington, D.C. Michael and my younger brother, Richard
Greenfield were best friends and Michael spent a lot of time in our home over the years.
I am five years older than Michael so I considered him my younger "brother". He was
always a very considerate, respectable and nice child and grew into a very well
respected, nice young man who was focused on giving back to underserved
communities. I have watched him work tirelessly on behalf of the underserved
communities. I now work in the nonprofit arena with people with disabilities (Columbia
Lighthouse for the Blind) and Michael has been very supportive of our efforts.

I have watched Michael over the past few years, take care of his ill mother with such
dedication and compassion that I feel it is the reason she is still with us today. He never
complains and has made decisions that always put his Mother in the forefront of
everything. Michael adores his Mother, and has always put her first and keep a close
watch on her daily activities. I often see him taking her out to dinner or driving her to a
doctor's appointment. I feel strongly that an extended prison term for Michael would be
detrimental to her health and well being. I also feel that it could impact his twin son's
financial obligations at college as they are entering their second year of college in
Florida.

I am aware of the events regarding Michael's guilty plea, and that he is accepting full
responsibility, and I believe that he is truly remorseful for his actions. Michael is the
primary caregiver for his Mother as his sister lives in New York with her family and kids.
Serving anytime in jail, will cause significant emotional and transportation issues for his
Mother, who has serious health issues and depends on him for access to medical care
so she can live at home instead of moving to a nursing home.

I know Michael and his family are very upset over what they are experiencing at this
most critical time in their lives, and I cannot imagine that he will ever repeat any illegal
offenses. I feel his time will be better spent providing community service and educating
young men on the dangers in committing this type of crime than serving jail time.

Because of the significant difficulties that will be faced by this very small, and close knit
loving family, I plead that you, Your Honor would grant Michael Arrington Brown
leniency upon sentencing.

Thank you for your consideration and time.

Respectfully,

Kim Greenfield Alfonso
EXHIBIT 13
EXHIBIT 14
EXHIBIT 15
Tracey L. Brown James

August 21, 2013


Dear Judge Wilkins,

I am Michaels little sister and it is with a heart filled with love, anger, fear, frustration,
worry, and disappointment that I write this letter requesting leniency in his sentencing. I
am hoping that I can describe Michael and his incredibly generous heart in a way that
assists you in understanding his true character so that you can seriously consider it when
deciding on his sentence. He is a good man who used terrible judgment, and made a
mistake that has devastated and disappointed his family, friends and community.

I have obviously known Michael my entire life. He is just 2 years older than me and he
has always been my best friend. Our family is small. Both of our parents were only
children so we didnt grow up with aunts, uncles or close cousins. It was always just
Michael, our mom, our dad, and me. We are the type of family that loves spending time
together, playing sports - mostly basketball (including nerf), tennis, golf, and skiing,
vacationing together, cooking together, watching movies together, including as we have
grown older and have independent lives in different cities. Even when Michael and I
fought, which we did constantly as kids, like when I was 6 and he cut off my ponytail, or
when he was 11 and I laughed hysterically when he fell off his bike and broke his arm,
we always made up quickly and all slights were forgotten.

Michael has taught me so much about so many things. He has taught me how to be a
good daughter. Even when I was teenager testing our parents rules, it was always
Michael who reined me in and made me see that our parents were foremost concerned
about our safety, and if I simply checked in with them when I was out with friends and
kept the lines of communication open they would trust me, and I would respect their
concern. In our twenties, when we lost our father so tragically, Michael became the rock
of our family and helped me to stop wallowing so that I could be more of a support to our
mom and continue to live my life. Now with our mom in poor health (she has been on
dialysis for several years, she has had bad falls, including head trauma that led to a
seizure disorder, and broken bones, and she is now legally blind), Michael is the dream
child that organizes the 16 different medication dosages that mom takes every day; that
drives her to and from dialysis treatment 3 days a week, and her myriad of doctors
appointments; he provides nearly every meal she eats; he carries her to the toilet and
helps her use it when she has gone through periods where she isnt ambulatory; he chats
with her for hours while they analyze Meet the Press, or The Young and the Restless
(which they watch together when it replays at midnight); and most importantly, he is
simply there for her always. On the occasions when I come down from New York to
relieve him, or he brings her to New York to stay with me for a bit, I marvel at the
herculean task Michael accomplishes with her, and try my best to temporarily fill his
shoes.

Michael has taught me how to be a good parent. He showers his sons, Morgan and Ryan,
with love and affection, always making sure that they know they can talk to him about
anything. As they struggled in school and their learning differences were diagnosed, he
made sure they got all of the resources and services they needed, but more importantly,
he made sure that their self-esteem stayed intact and they didnt get discouraged by the
challenges that they face. I have learned from him that the best conversations with your
kids happen at the dinner table. Michael always includes his sons friends, especially
those in unstable family situations to share meals and conversations. Our family dinners
are filled with laughter and loud conversations about politics, dating, celebrity gossip,
and the classic Michael Brown Would you rather questions. (As in, Would you rather
eat a slug, chewing it slowly, or a large bowl of mayonnaise? - which I detest). As I
write this I can see everyones faces around the dinner table, lit up with joy, thankfulness,
love and good times.

He has taught me how to be a good friend. When a close friend began behaving strangely,
doing embarrassing things, including acting inappropriately at professional functions I
had invited her to, Michael urged me to be more understanding. He realized, before I ever
did that my friend was hurting and was going through a difficult and painful time in her
life and was simply lashing out.

Michaels generosity knows no bounds, which unfortunately is what caused him to
stretch himself too thin and compromise himself in the case before Your Honor. When
friends are in a difficult financial bind, he helps them. Short on rent, he will help you.
Cant pay your childs school tuition, he wont want to leave you suffering. Once,
Michael even co-signed a loan for a friend who then defaulted on it. His heart is kind and
good.

This is the Michael that I know. The Michael who amazed our father when he was in
college and somehow managed to get himself onstage at a presidential campaign event
and was warming up the crowd of over 10,000 people at UCLAs Pauley Pavilion just as
dad was walking into the venue with Governor Dukakis. The Michael who was a pillar of
strength when he stood in front of thousands at the Washington Cathedral and eulogized
my father, privately assuring me that we would survive the overwhelming loss as I sat
hopeless and mute. The Michael who held my hand tightly and told me how happy he
was for me and how much he loved me as he walked me down the aisle at my wedding.
The Michael who rocks my mother back and forth and soothes her when she is in the
middle of a grand mal seizure as they await the ambulance. The Michael whose favorite
activity is grocery shopping with his family because it means he is getting things for
family gatherings. The Michael who regularly takes his kids with him to soup kitchens,
community centers, and homeless shelters so that they can understand the tough plight
that many face and lend a hand to help lift them up. The Michael who held my hand and
cracked jokes as my son made strides in the NICU after being born prematurely. The
Michael who brings his brother-in-law his favorite pistachios every single time he visits.
The Michael who when we are together with my kids, pulls them into his bed on
Saturday mornings so they can watch cartoons together, and then takes them to breakfast
so my husband and I can sleep in for once. The Michael who brings light, strength, love,
and laughter to our lives. This is the Michael who should be shared with the world, not
incarcerated.

My father often said that the test of persons character is how they handle adversity.
I have never been more proud of my brother than on June 10, 2013 when he stood before
you in your courtroom and pled guilty. He has firmly accepted responsibility for his
actions and stood tall before you knowing the devastating potential consequences. Thats
my brother. He doesnt hide from his mistakes. He faces them. I have talked to many
friends who have said that if they were facing what Michael is facing, they would curl up
in a ball and never want to see anyone. That is not my brother. He has met the
humiliation, shock, embarrassment, consequences, and fear head on. Whether he is
walking his dog, or in the community with his sons, whomever he encounters that asks
how he is doing, he readily tells them how sorry he is for his actions and for
disappointing them. He is a person who deserves mercy.

Your Honor, I understand that you have a serious task before you in sentencing my
brother. Michael has held my hand through many important milestones, disappointments,
and tragedies in my life. I have now reached for his hand in prayer as we seek Gods
guidance and strength through this terrifying process. Please consider his whole person
and be guided by the goodness that is in his heart and the potential he has to continue to
serve his community. He is shining example of someone who when he falls, he gets up,
faces the challenges and stands strong.

Thank you for your consideration.

Tracey Brown James

EXHIBIT 16
}uly 2u, 2u1S

The Bonoiable Robeit L. Wilkins
0niteu States Bistiict Couit foi the Bistiict of Columbia
SSS Constitution Avenue, NW
Washington, B.C. 2uuu1

RE: Nichael A. Biown

Beai }uuge Wilkins:

I am wiiting this lettei as a longtime fiienu of Nichael Biown.

I have known Nichael since 1992, when I was just a senioi in high school uoing
volunteei woik on the Clintonuoie 92 Piesiuential campaign. 0ui ielationship can
best be uesciibeu as one that began with him as a piotective oluei biothei anu
fiienu who maue suie none of his fiienus tiieu to uate me as a teenagei, that ovei
the yeais, giew into one of mutual iespect anu aumiiation that now has spanneu
ovei 2u yeais.

We have always foiemost been fiienus, but beginning in 2uu4, my tiust in Nichael
leu me to iecommenu him to be a membei of the boaiu that husbanu anu I helu a
numbei of shaies in calleu SPARK NETW0RKS (paient company of Chiistian Ningle,
}Bate etc). Nichael seiveu foi a numbei of yeais as a membei of the Boaiu anu was
iespecteu foi his uiligence anu honesty anu iemaineu a membei of the boaiu even
beyonu my ex-husbanu's tenuie as Chaiiman of that company.

Latei, Nichael also was veiy instiumental in helping to auvise me in my chaiitable
anu investment activities in the Bemociatic Republic of Congo anu the Republic of
Congo. While Nichael nevei piofiteu monetaiily fiom the time that he spent in the
two Congos with me, he nevei hesitateu to give me auvice oi lenu a hanu in teims of
guiuing my effoits in Afiica - whethei it was ueveloping a piogiam to help cultivate
young unuiscoveieu musical talents in the Congo, oi iuentifying watei puiifying
machines foi the most uesolate anu isolateu of communities theie; I tiusteu
Nichael's auvice because of his yeais of expeiience tiaveling anu woiking in the
continent of Afiica - anu ieally, he was the only peison close to me who hau spent a
substantial amount of time on the continent.

Nichael was also extiemely suppoitive of my effoits in the pio-Isiael community.
When I became piesiuent of WAIPAC (Woilu Alliance foi Isiael) - the laigest pio-
Isiael PAC in the nation, Nichael was essential in my effoits to show cioss-
community suppoit anu outieach foi oui effoits. Nichael has a veiy unique quality
of making people of any iace, coloi, ieligion, class oi ethnicity feel comfoitable with
his easy anu genuine smile anu willingness to always listen.

In shoit, Nichael is nothing less than a man who I consiuei to be one of the most
geneious with his time, auvice anu love. Be has one of the biggest heaits of anyone I
know. 0ui fiienuship has spanneu 2u yeais now anu I was veiy sauueneu to heai of
his iecent tioubles anu the plea agieement-- especially since I know his sons aie
going to be away in Floiiua foi school next yeai anu the one job that peihaps he is
bettei at than being a fiienu, is that of a fathei to his chiluien anu ueuicateu son to
his mothei. Thiough the yeais, I have seen that Nichael's gieatest motivation in all
that he uoes (especially aftei the untimely ueath of his fathei) is foi his family -
whethei it is foi his sons, oi foi his sistei, uianuma, 0ncle Chip oi Nom. Any
uecision on his sentencing I hope will take into consiueiation pioximity to his family
so that he can be easily visiteu.

Thank you foi youi time anu consiueiation. Please feel fiee to contact me if you
shoulu iequiie moie infoimation at (S1u) 41S.141S.

Best Regaius,

Nickie N. Lum Shapiia Bavis

EXHIBIT 17

August 14, 2013
Dear Judge Wilkins:
I am writing in support of Michael A. Brown (Criminal Case No. 13-cr-00264-RLW-1). I understand that
Michael has entered into a plea agreement with the government, and I truly believe he is deserving of
leniency in his sentencing.
I met Michael through a mutual friend and have known him for over 6 years. Before meeting him I was
a resident of the district and knew of his work in the city. I admired him for the little things he did in the
community, not things that would make the 6pm news, but the things that touched the lives of the
people, such as his work with the elderly and the undeserved.

Michael has impressed me with his dedication to his family, and is a true example of what a son and
Father should be. The tender way that he treats his Mother and the pride he his for his sons is
remarkable.

I understand that Michael is very remorseful for his actions, but I know that he is not a danger to
society. Our community would be better served with him in it, instead of him being incarcerated.

Thank you in advance for your consideration.

Please contact me if you have any questions at
Sincerely,

Danielle Weston

EXHIBIT 18

August 15, 2013


Dear Judge Wilkins:

I am writing in strong support of Michael A. Brown (Criminal Case No. 13-cr-00264-RLW-
1). I am aware that Michael has entered into a plea agreement with the government. I
sincerely believe he is deserving of leniency in his sentencing.

I have known Michael for approximately six years and was introduced to him by a
mutual friend. I was immediately impressed by his professionalism. I have two young
children, one who is autistic. Michael has always exposed my children to various
activities, and we are most appreciative for his kindness and generosity. Since I have
known Michael, not only has he shown a remarkable commitment to his community, he
has demonstrated the utmost dedication to his family and friends.

I know that Michael is very remorseful for his actions. I am proud that he has taken full
responsibility for his actions. I believe he deserves a second chance, and I know that he
is not a danger to society. I am prayerful and hopeful that you will be lenient in your
sentencing and forego jail time.

Thank you in advance for your consideration. If you have any questions, please contact
me at .

Sincerely,

Andrea Carrington

Andrea Carrington
EXHIBIT 19

August 13, 2013


Dear Judge Wilkins:

I would like to offer my strong support for Michael A. Brown. I have known Michael for
approximately six years and I have only experienced great things with him. We met
through a family friend and since then he has always been like a big brother to me.
When I was going through a rough time in my personal life, he always offered words of
encouragement and lifted my spirits with his smile and genuine hugs. He was truly a
great support system to me when I needed him the most without being judgmental -- he
offered his unconditional support and for that I am truly grateful.

I am aware that Michael has entered into a plea deal with the government. This situation
is very unfortunate but I know with his unwavering faith he will get through it. Michael
has lived a selfless, humbled and grounded life. I know he is very remorseful for his
actions because it is not within his character. I am prayerful and hopeful that you will be
lenient and not send him to jail. He is truly a great guy with a great heart who puts others
before himself.

me at .

Sincerely,

Faith Danford

Faith Danford
EXHIBIT 20
Lashun C. Kenney

August 11, 2013


Dear Judge Wilkins:

I am writing in strong support of Michael A. Brown (Criminal Case No. 13-cr-00264-RLW-1). I am
aware that Michael has entered into a plea agreement with the government, and I truly believe
he is deserving of leniency in his sentencing.

Michael and I have been friends for approximately five years. I met him through a mutual
friend. I was going through an extremely difficult time in my life. He took me under his wing and
provided amazing counseling. I was involved in a volatile abusive marriage. He and our mutual
friend helped me through that grave ordeal. They stayed on the phone with me during the
night and very early hours of the morning to ensure my safety. There were times I slept in my
vehicle to escape my husband and get a good nights rest. He and our mutual friend offered me
shelter. They reminded me of my worth as I suffered from self-esteem issues (a trait that many
victims of domestic violence have). There were times we would go to dinner with a host of
friends and Michael would pay for my dinner knowing that I was financially dependent on my
ex-husband -- leaving my marriage was difficult financially.

I am healthier and mentally stronger today because of Michaels help. I am currently in a very
healthy and happy relationship with a great man that he introduced me to! Michael has been a
true friend and supportive big brother to me. He has never been too busy to help, lend an
ear, or offer sound advice. He has never missed a birthday celebration in the five years of
knowing me. He even attended my divorce party. He also attended my mothers birthday
luncheon despite his busy schedule while serving on the Council of the District of Columbia --
my parents adore Michael!!!

I have witnessed what an amazing son he has been to his mom. Michael is her full-time
caregiver -- I know he takes her to numerous appointments including dialysis three times a
week. I have also witnessed how involved he is in his twin sons lives. I know that taking them
to school was a big deal for him, and even though they are entering into their second year of
college, his presence is still needed in their lives.

I know that Michael is wholeheartedly regretful and sorry for his actions. He has taken full
responsibility for his poor judgment. I know that Michael is an asset to our community and that
his leadership skills will go to waste if he is incarcerated. Moreover, Michael is not a threat to
society. I am hopeful that you will be lenient in your sentencing and forego jail time.

Thank you in advance for your consideration. Please contact me should you have any questions.

Sincerely,

Lashun C. Kenney

Lashun C. Kenney

EXHIBIT 21
EXHIBIT 22
1
From: Morgan Brown
Sent: Monday, April 07, 2014 2:53 PM
To: Tracey Brown
Subject: Re: Letter for my dad

Dear Judge Roberts,

My name is Morgan Brown and Michael Brown is my father. I am in college with my twin brother, Ryan, at Florida A&M. While
our family has tried to keep our lives steady since the news of my dads plea, Ryan and I are both having a really tough time. I
always wanted to be just like my dad. I planned on going to law school and becoming a city council member in DC, just like him.
Now I am sad, disappointed and worried. It is hard to focus on school and the future. My dad has always been there for me.
Throughout middle school and high school, he drove my brother and I to school every day. It was our special time to talk and
catch up. We are now in college in a program that addresses our learning difference and even now my dad takes the time to talk
with and meet with our academic advisers to make sure we stay on the right track. He has always given me good advice and is
easy to talk to about anything. He has even helped out a lot my friends who were facing tough times and hard decisions. When
we are together we laugh so much. Ryan is really funny too and I love watching Ryan and my dad talking, they always get me
laughing no matter what. Now that light my dad always had in his eyes is dimmer. Hes worried, we are all worried about what
happens next. He is so sorry for his actions. Please dont take him away from us. Hes a good man and a great dad.

Sincerely,
Morgan Brown

EXHIBIT 23
EXHIBIT 24
Alma Arrington Brown

April 20, 2014

The Honorable Richard Roberts

Dear Judge Roberts,

My son, Michael Arrington Brown, will appear before you for sentencing on May
8, 2014. I am writing to beg you not to send him away.

After my husbands tragic death in a plane crash in 1996, Michael stepped into
the role of family patriarch by providing strength, support and direction. He longed to
carry on my husbands example of leaving the ladder down for others to follow. As a
result, he has mentored countless young people and has been generous with both his time
and money. Michael has provided food and shelter to many of his sons friends who have
had difficult family lives. We have family dinner every Friday night and the table always
has at least one of the boys friends, who all refer to Michael as their godfather. He once
co-signed a loan for a friend in need, who defaulted on it, which left Michael to pay it off.
Michael would literally give a friend his last dollar if they needed it, even at a cost of not
having it for his own family.

Michael is literally my lifeline and life source. I do not mean to sound
melodramatic, but it is the truth. I have a number of severe health issues that only
Michael helps me with. I see 6 doctors regularly. Recently, after another health scare, my
2 children, Michael and Tracey, were forced to discuss with whom I would live, as I am
now unable to live alone. Not wanting to move me from my excellent medical doctors
who have been treating me for a number of years, it was determined that I would stay in
Washington, and Michael and I would live together, with him being my primary
caregiver. Just in the last 3 weeks, I have fallen 4 times. Luckily these falls didnt result
in the broken neck, knee, toe, or brain injury that have occurred in the past. Fortunately,
Michael was available to handle the consequences of these injuries.

Even when Michael held two jobs, as a government affairs consultant and as a
city council member, Michael always arranged his schedule so that he could take me and
pick me up from my 3 times a week dialysis treatments. He would leave his offices
downtown, drive to my previous residence in Chevy Chase to pick me up, then take me to
Bethesda for my dialysis treatment, then go back to work, and then return four hours later
to tak
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EXHIBIT 25
From: Greg Thompson
Date: August 22, 2013, 1:51:04 PM EDT
To:
Reply-To: Greg Thompson

Dear Judge,
My name is Gregory Thompson II. I have known my Godfather, Michael A. Brown, ever since I
was in elementary school with his sons. I really cant comprehend what he has done but, I know in my
heart he is a good man. He has always been there for me when I needed help the most. Basically, he
treated me like his own fresh and blood. He introduced a new world to me in DC. Instead of me being
stuck and trapped in the world of violence, he gave me a place to stay when I needed the most. He also
feed and clothe me. He taught me to become a leader and to fight for what I want to accomplish the
most in life. Please look in your heart to see all of his accomplishments and just not his faults.
Greg Thompson II
EXHIBIT 26
EXHIBIT 27

August 23, 2013


Dear Judge Wilkins:

I am writing in strong support of Michael A. Brown (Criminal Case No. 13-cr-
00264-RLW-1). I am aware that Michael has entered into a plea agreement with
the government, and I fully believe he is deserving of leniency in his sentencing
and should serve no jail time.

Michael is a close friend that I have known for over eight years. He is considered
by me as well as his former constituents to be a long-standing, hardworking
servant of the people of the District of Columbia. I have often engaged in
conversation with Michael regarding education, parenting and life issues. I know
that he has a strong foundation and strives to be the best son and father to his
family. I also admire Michael for serving as a mentor to friends of his sons who
were lacking strong family support. Michael was a father figure to these young
African-American men and he played a critical role in their success.

I understand that Michael is very remorseful for his actions. Moreover, I believe
he has already suffered punishment by his admission of wrongdoing. Sentencing
Michael to prison will not yield any additional deterrent effects.

Thank you in advance for your consideration. Please contact me if you have any
questions at

Sincerely,

Brian Albert

Col Brian Albert (Ret)

EXHIBIT 28
EXHIBIT 29
August 20, 2013

333 Constitution Avenue, N.W.,

Honorable Sir,

My name is Tamela R. Cash-Curry. I am a Public Defender for Los Angeles County and
have been such for 19 years. I am writing this letter in hopes that it will provide
additional insight into the character of Michael A. Brown and be of some assistance as
you prepare to sentence him in a few months.

I was introduced to Michael by his sister, Tracey Brown, about 17 years ago. Michael
and his wife were parenting 2 young boys and doing an amazing job at the time we met.
Given the notoriety of his father, I marveled at how grounded Michael and his wife were.
In fact, the entire family shared the same core valuesfamily first. As a man in his early
thirties, Michael was a pillar of support for his mother, grandmother, sister and his young
family. This became even more apparent after the untimely death of his father. I believe
it was Michaels fortitude that kept the family in tact during this tragedy and its
aftermath.

Michaels choice to become a political figure came as no surprise. The surprise would
have been had he not chosen this path. Michael has been around politics his whole life
and possesses a genuine desire to help others. The Browns have spearheaded and been
major contributors to a myriad of charitable organizations. Michael felt that his role as a
public servant would better facilitate his ability to reach more and do more. Clich, as it
may sound, Michael wants to help make the world a better place to live.

Unfortunately Michael, like all of us, possesses human frailties. Poor judgment has
plagued us all at one time or another, as was Michaels situation. However, an error in
judgment should not obliterate the core qualities that make a man who he is. Michael
remains humble when his lifes circumstances would have justified him being arrogant.
Hes exuded strength when others would have crumbled under the social microscope.
Even now, Michael, by entering an early guilty plea, shows the integrity of a man who is
willing to admit wrong doing. At the core of Michael Brown is a man possessed with
love for family, God and fellow man. I am proud to call him my friend and pray that you
will have mercy and exercise leniency in his sentence.

Very truly yours,

Tamela R. Cash-Curry
EXHIBIT 30
EXHIBIT 31
EXHIBIT 32

August 1,

The Hono
United Sta
For the D
333 Const
Washingto

Dear Judg

This letter
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Sincerely,

Carol Sadl

2015
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EXHIBIT 33
August 5,2013
The Honorable Robert L' Wilkins
United States District Court for the
District of Columbia
Re: United States v. Michael A. Brown
Dear Judge Wilkins,
My name is Linwood L. Rayford, III. I am a member of the District of Columbia
Bar and I am admitted to practice before this Court. I have known Michael Brown for
many yeals. We are famiiy friends and members of the same golf club' My sister,
Claudia Rayford Rodgers had the privilege of working closely with Michael's father at
the U.S. Department of Commerce.
I have personally witnessed Michael's love for his family and friends' During the
time that I have had aplrsonal relationship with Michael, he has always been a dedicated
friend, he is blesseo wittr an incredible sense of humor, and he has unquestioned loyalty
to the organizations
I have had the pleasure of being apart of with him. These are but
some of the reasons why I am writing to you today'
As a life-long Washingtonian
I love this city. I contributed to Michael's
campaigns for pubhl office because I believed that he would serve the citizens of the
listriciorColumbia
with a combination of hard work, compassion and intelligence'
Even his harshest critics must admit that he has accomplished
good for the District of
Columbia, especially for some of its most disenfranchised
citizens'
I am aware of the circumstances
sulrounding Michael's
plea agreement' As a
member of this court I cannot say that I am not disappointed
in the actions that form the
basis for the plea. And yes those actions appear to run contrary to some of the attributes
that I cite above. However, I am writing in support of Michael as I have had the pleasure
of seeing the positive side of his characGr and I believe that he has done many good
things fJr tne-listrict of Columbia and its citizens. It is for these reasons, and many
otheis, that I am asking you to take these comments into consideration
as you sentence
Michael in this case'
Cc: Scott Armstrong, Esq.
EXHIBIT 34
EXHIBIT 35
CARMEN R. ADAMS, ESQ

August 11, 2013


Dear Judge Wilkins:

I am writing you in strong support of Michael A. Brown (Criminal Case No. 13-cr-00264-
RLW-1). I am aware that Michael has entered into a plea agreement with the
government, and I wholeheartedly believe he is deserving of leniency in his sentencing.

I have known Michael for almost 5 years. I met him while volunteering at a golf
tournament named in honor of his father during the 2008 Democratic National
Convention in Denver, Colorado. I was impressed by his commitment to carrying on his
fathers legacy of providing financial assistance to extraordinary students who exhibit
dedication to community service, demonstrated leadership, proven academic
achievement, and financial need. I was also very moved by his close relationship with his
children.

I truly believe Michael deserves a second chance. He is very remorseful for his actions
and is certainly not a danger to society. Moreover, with the costs and stigma associated
with incarceration, I believe his proven leadership would be put to much better use
serving his local community in Washington, DC.

Thank you in advance for your consideration. Please do not hesitate to contact me if
you have any questions.

Sincerely,

Carmen R. Adams

EXHIBIT 36
August 15, 2013
Dear Judge Wilkins:
I am writing in strong support of Michael A. Brown (Criminal Case No. 13-cr-00264-RLW-
1). I am awarethat Michael has entered into a plea agreement with the government. I
sincerely believe he is deserving of leniency in his sentencing.
I have always had a great deal of respect for Michael and his father, the late Secretary of
Commerce Ron Brown, because of their humanitarian efforts. I was introduced to
Michael this year by a mutual friend -- I was immediately impressed by his
professionalism and sincerity. In that instant I could tell that he was a man of purpose.
I knowthat Michael is very remorseful for his actions. I am proud that he has taken full
responsibility for his actions. I believe he deserves a second chance, and I know that he
is not a danger to society. I am hopeful that you will be lenient in your sentencing and
forego jail time. I truly believe his proven leadership would be put to much better use
assisting his community by continuing to fight for the elderly, disabled and young
African-American menin his hometown of Washington, DC.

me at

Sincerely,
Dwight Ferrell
EXHIBIT 37

April 16, 2014

Dear Chief Judge Roberts:

Youth in Media and Education (Y.I.M.A.E.), a nonprofit organization aimed at positively impacting the behavior and future
outlook of youths by merging media and education, is providing this letter of support to inform you of Mr. Michael A. Browns
contributions to our organization as a volunteer staff member.

The Y.I.M.A.E. program is a multifaceted media and education curriculum that incorporates incentives and measurable
outcome-based components as a non-traditional means for rehabilitation. The program has been designed to validate the
premise that exposing troubled community youth to a program model that merges entertainment media with education can
indeed positively change the behavior and future outlook of these youth. Y.I.M.A.E. uses the entertainment media component as
an incentive by presenting youth with opportunities that many of today's youth only dream of (e.g., the chance to record their
own albums, collaborate with well-established and well-known artists, create their own movies, run their own radio programs,
etc.). The degree of these incentives serves as a catalyst to help them excel in the educational component of the program and
other areas of their lives. Within the educational component of the program, the youth will refine technical competencies and
grasp lifelong principles that inspire educational advancement and preparation for the workforce. The overall goal is to help
youth develop the knowledge and skills they need to thrive in the modern worldskills such as global awareness, civic
engagement, technology literacy, critical thinking, problem-solving and life skills.

Y.I.M.A.E. is currently operating in the Edgewood community in Northeast Washington, D.C., where Mr. Brown has been
working with our organization as a volunteer staff member since September 10, 2013. With tasks including, but not limited to,
helping with the implementation of our programs for young people, outreach, seminars, etc., Mr. Brown has gone above and
beyond to make very valuable contributions to our organization and the community. In October 2013, Mr. Brown was very
generous in his provision of food and beverages for our Evening Social event, where we did outreach within the community and
provided treats for a fun and uplifting event. He was instrumental in producing and distributing promotional materials for the
Costume Party event that followed. In December 2013, Mr. Brown was able to round up a host of donations for Y.I.M.A.E.s
Holiday Gift Drive, where we were able to brighten up the Christmas holiday for several youths. We found out during this event
that the gifts that some youths picked out would be the only toys they would receive for Christmas, and we thank Mr. Brown for
his ability to help us fill the table with quality gifts. Since December, Mr. Brown has been assisting us with workshops to help
educate and entertain the youths in the communityone of which was to teach business etiquette that can be used on job
interviews and in business settings.

Y.I.M.A.E. is profoundly appreciative of Mr. Browns contributions and feels that his absence would have an adverse impact on
the youths and parents with whom hes connected and on our efforts to service the at-risk youth of Edgewood and the
community at-large. That being said, we are hopeful that you will be lenient in your sentencing and forgo jail time. If you have
any questions or concerns, please feel free to contact me at

Sincerely,

Cornell Stone
CEO and Founder
EXHIBIT 38
EXHIBIT 39
EXHIBIT 40
Danielle McBeth

August 14, 2013

U.S. District Court for the District of Columbia

Re: Michael A. Brown (Criminal Case No. 13-cr-00264-RLW-1)

Dear Judge Wilkins:

I deeply regret having to contact you regarding my longtime friend and colleague Michael A.
Brown. Michaels plea is totally inconsistent with the character of the man I have come to know
well over the years and I believe whole heartedly that he deserves leniency in his sentencing on
October 3, 2013.

I have known Michael for over a decade and have hosted him at my house during his tenure as
Councilman. I worked with Michael at Alcalde & Fay and have always held him in very high
regard. He is devoted to his family and could not have received a greater punishment than the
disappointment shown by his twin sons who are attending Florida A&M University, my alma
mater. Sometimes when faced with dire circumstances, we have a lapse in judgment that does
not reflect our true nature and our true character.

Michael truly is repentant and by no means is a danger to his community. With the expense and
humiliation associated with incarceration, we would be better served by putting his proven
leadership to good use within his local community in our nations capital.

I appreciate your consideration of leniency and please do not hesitate to contact me if I may
answer any questions or provide additional information.

Sincerely,

Danielle McBeth
EXHIBIT 41
Honorable Robert L. Wilkins
Washington DC 20001

Dear Honorable Robert L. Wilkins,

I am writing on behalf of Michael A. Brown who has pled guilty on charges of bribery in the
case proceeding captioned United States of America v. Michael Brown. It is with a heavy heart
that I submit this letter asking for the esteemed court's leniency when sentencing my friend.

The Brown family and mine have a long history of friendship. Both our grandparents and our
parents were friends. Michael, his sister Tracey and I grew up together and have remained close
for over 36 years. Throughout these many years Michael has been a loyal and supportive friend.

Fifteen years ago I ran a marathon to raise money for diabetes research and Michael didn't
hesitate to send a check in the amount of $500 to the American Diabetes Association. Ten years
ago I decided to relocate from LA back to my hometown of DC. Michael sprung into action
helping me to connect with potential employers in search of job leads. Within a few short
months, I was offered a job and was able to move back home to be near family again. More
recently, this past July, I lost my precious nephew and despite Michael's own troubles and
embarrassing news headlines he attended the funeral determined to be a source of support for my
grief stricken family.

It is with this same spirit of loyalty that I reach out to you Your Honor asking for leniency. I
fully understand the seriousness of this situation. Michael has pled guilty to a criminal offense
and as such he should be punished for his crime but I ask that you take into consideration that
absent from this offense he is a decent and compassionate human being. He is a doting father, a
loving son, a protective brother and a very dear friend.

Thank you for your time and consideration.

Sincerely,

Nikki Webber Allen

April 16, 2014

The Honorable Richard W. Roberts

Dear Chief Judge Roberts:

I am writing in strong support of former Councilmember Michael A. Brown (Criminal Case No.
13-cr-00264-RLW-1). I am aware that Michael has entered into a plea agreement with the
government. I fully believe he is deserving of leniency in his sentencing and should serve no jail
time. I along with his devoted family and friends are asking on his behalf forgiveness.

I was introduced to Michael by a mutual friend approximately seven years ago and was
immediately impressed by his genuine demeanor. Over the years, I have interacted with him
on many occasions in Los Angeles, California, and Washington, DC. I know that neither his
integrity nor his character is in question.

The humiliation from him making a poor decision has been very difficult for such a humble,
honest and truly good man. I know it pains him tremendously when he sees the
disappointment in his twin sons eyes. However, he knows that they will always love and
support him -- they know that anyone can make a mistake.

Michael has been unemployed for almost a year. Since September 2013, he has worked
numerous hours as a volunteer mentoring troubled youth at a reputable nonprofit
organization. I am sure he has made a positive impact on these youth and their families.

He has taken full responsibility for his actions. He is not a danger to society. He is very
remorseful for placing himself in a compromising position. Michaels proven leadership is
needed in his community. I am hopeful and prayerful that you will be lenient in your
sentencing and forego jail time.

Thank you in advance for your consideration. If you have any questions, please do not hesitate
to contact me at .

Graciously,

Tonia D. Bell

Tonia D. Bell

August 14, 2013


Dear Judge Wilkins:

I am writing today in support of Michael A. Brown (Criminal Case No. 13-cr-00264-RLW-1). I am aware
that Michael has entered into a plea agreement with the government, and I believe he is deserving of
leniency in his sentencing.

I met Michael about a year ago when I worked a fundraiser event for him, since that time I have gotten to
know him and consider him a friend. I knew of him before we met and admired him for his work in the city,
community and different charities. As I started to know him on a more personal level, I saw that not only is
he committed to the community, but more importantly to his family and friends.

Michael is very sorry for his actions and knows that he should be held responsible, but I know that he is
not a danger to his community and is in fact an asset that would be better used serving the city of
Washington, DC

Thank you

Sincerely,

Oscar Braithwaite

Joyce Morgan Danford
Media and Image Consultant

August 15, 2013

Dear Judge Wilkins:
This letter is in reference to the case of Michael A. Brown - Criminal Case No. 13-CR-00264-
RLW-1. I am writing in support of him being granted leniency in his sentencing as I have been
made aware that Michael has entered into a plea agreement with the government.
Michael has been a friend for more than three years. I have found him to be a very
supportive friend who has achieved a high level of success due to his hard work and
commitment to his family, friends, and the greater Washington D.C. community.
I believe Michael fully understands the implications of his actions and I further believe he is
truly sorry. Due to Michaels reputation and achievements, I do not believe he poses any
danger to society and I in fact beseech you to grant him a second chance. Considering the
financial burden associated with incarceration, I believe the local community would be better
served by allowing him to use his charismatic leadership skills and abilities to improve the lives
of those less fortunate.
I appreciate this opportunity to appeal for your consideration. I can be reached at
if you have any questions.
Sincerely,

Joyce Morgan Danford


April 14, 2014

333 Constitution Avenue, N.W.
Re: Michael A. Brown
Your Honor,
My husband and I met Ron and Alma Brown through mutual friends in 1969. We became
immediate friends because we had two children around the same age. Our children played
together and were in the same Jack and Jill chapter where they got together frequently for
activities planned by the mothers who exposed them to the Arts, to volunteerism, religion, and
becoming loving and caring people. It was during those times that I had an opportunity to
observe Michael. Our small community of young parents, who wanted a better life for our
children, taught and nurtured them to be good people. As a little boy, he was the epitome of
what every mother wanted her child to be. He was the one who always greeted you with a smile
and a hug, was willing to help and was concerned about how you were and what he could do for
you. He was an intelligent leader at a young age and his peers seemed perfectly happy to follow
him. I now think he was preparing to be a leader in the community, to help those who needed
him and to make policies that protected the people of the District of Columbia.
Your Honor, I have a child who made poor decisions and paid the price for it. She is now a
successful member of society. I am grateful everyday to have her as my daughter. My heart
breaks for his mother, my friend Alma, who is not well and depends on Michael for so much. My
heart also feels sadness for his sister Tracey, who has always looked up to her older brother
and continues to do so despite his poor decisions. I am so concerned about what his sons,
Morgan and Ryan, are going through and will continue to go through because of Michael's
situation. I trust their college classmates are kind. Michael has been a loving and doting father,
however, he seemed for a time to have lost sight of the critical role he plays in their lives.
In my quiet moment, I wonder how this could have happen to an intelligent gifted young man
of whom we all love and were so proud and supportive. I think about my own situation with my
daughter and know that there are times when unfortunate things happen and poor decision are
made. Your Honor, Michael's poor judgment is not indicative of the man he is, the loving son,
the doting father, the amazing brother and the loyal friend. Despite Michael's circumstances, I
will never deny that he has always been a wonderful, caring human being and humanitarian. His
love and loyalty to the District, for his family and friends are undeniable. It would be my hope,
Your Honor that you take into consideration the positive impact of Michael's entire life and the
impact he has had on those around him. I would ask that you not judge him too harshly based
on an irresponsible yet serious action but on his life as a whole.
Respectfully submitted,
Lorethea F. Davis

Yvonne Missy Doggett

August 7, 2013


Judge Wilkins,

I am aware that Michael A. Brown has entered into a plea agreement with the government in the
United States District Court for the District of Columbia, Criminal Case No. 13-cr-00264-RLW-
1. I am writing this letter of support to you so that you may fully appreciate Michaels character
and accomplishments prior to his sentencing on October 3, 2013.

I have known Michael since the summer of 1985 (for 28 years) when I lived at Michaels family
home while attending summer school at George Washington University in Washington, DC.
Michaels warm hospitality made me feel right at home. I remember many nights watching
television in the family room with Michael and his sister, Tracey, laughing and joking about the
days events. Michael was and still is a funny and kind person whose smile can light up a room!

Michael and I have remained close friends over the years. He was very supportive of me during
a difficult time in my life just several years ago and was always available to me when I needed
advice and assistance. No matter what the ask, Michael was there.

Further, Michael is an outstanding son, brother and father. I have had the pleasure to see him in
all of the aforementioned roles, i.e. at family get-togethers in Sag Harbor, NY, at his sister's
wedding, at numerous dinners in New York City or Washington, DC, etc. I can truly say he is
not your random guy but so much more. Michael has given and has so much more to give to his
family, friends, and his community.

With Michaels quiet nature, his guilty plea is an anomaly and out of character for my friend.
Judge Wilkins, I do hope you take this letter seriously when considering Michaels sentence on
October 3.

Respectfully,

Yvonne Missy Doggett

"Forgive others not because they deserve forgiveness but because you deserve peace!"

Yvonne "Missy" Doggett

November 24, 2013


Dear Judge Wilkins:

I am writing in strong support of former Councilmember Michael A. Brown (Criminal Case No. 13-
cr-00264-RLW-1). I understand that he has entered into a plea agreement with the government. I
truly believe he is deserving of leniency in his sentencing and should serve no jail time.

I was introduced to Michael approximately three years ago by a mutual friend. During the course
of our friendship, we have had lengthy conversations about various topics including our families,
giving back to the community, education, life, politics and sports. I have always found him to be
an upstanding individual.

While on the Council of the District of Columbia, Michael fought endlessly for the youth and poor.
He was a dedicated public servant. He is currently working numerous hours as a volunteer serving
as the Youth in Media and Educations (Y.I.M.A.E.) Community Outreach Director. I am aware that
this entity is a reputable organization, which promotes artistic expression and self-empowerment
to troubled youth through education, the entertainment/media industry and vocational training. I
am sure he has been an invaluable asset. As an educator, I am impressed with his tireless efforts
serving as a mentor to youth.

Michael is not a danger to society. He has taken full responsibility for his actions. I know that he is
very remorseful for placing himself in a compromising position. He has already suffered
punishment by his admission of wrongdoing, and I believe sentencing him to prison will not yield
any additional deterrent effects. I am hopeful that you will be lenient in your sentencing and
forego jail time.

Thank you in advance for your consideration. If you have any questions, please contact me.

Sincerely,

Dr. Herman J. Felton, Jr
Senior Vice President
Vice President Institutional Advancement
Karla Fitzgerald

April 15, 2014
Re: Michael A. Brown
Dear: Honorable Richard W. Roberts:
This letter is to express my sincere support of Michael A. Brown with regard to your leniency. I am a
native Washingtonian and have known Michael most of my life; starting with our childhood. Michael
and I first met as members of Jack & Jill, Inc. His sister and I were in the same age-group; therefore I
have very fond memories of spending weekends at the Brown household. My fondest memories of
Michael center around playing music, laughing, and dining with many of Tracey and Michaels friends.
The Brown household was very loving, growing up and this love remained evident throughout Michaels
life; with his family and kids. He was a super fun kid, and I am thankful that I witnessed him gowning up
into a loving great man. It was evident that Michael would be destined for success. I remember that
Michael gave an expensive sweater; (Ralph Lauren) to a mutual friend in high school, because he could
not afford one himself. Michael did not want our friend to feel ostracized from the groups style trends,
and thats the true measure of a friend.
In some cases, being the son of a successful father may have placed a lot of pressure on Michael to be
great. After graduating elementary school, then high school I would see Michael periodically during
college breaks. He was always with his kids, or in a position doing something with his family. To me, that
is a sign of a great man and father. There were times that I wished I were as close to my family as
Michael and his sister were to their family. After Michael lost his father in 1996, it was clear that he
stepped up to be the head of the Brown household, as his sister Tracey really needed the support of her
brother.
As a native Washingtonian, I was really proud to see Michael go into politics because I knew that he was
the right person to help change the city. Im sure at times; the pressure he was under was as a result of
the pressure that he placed upon himself. It was apparent that Michael put a lot of pressure on himself,
but for a good reason. He wanted to make a difference within the community. I will always believe that
Michaels ultimate goal was to help others so that they could have the opportunities that he had as a
young man growing up in Washington, DC.
Your Honor, I am respectfully requesting that you support Michaels speedy return to his family so that
he can continue to help make a difference. I look forward to seeing Michael so that I can give him a
big hug, as I will always support the kind-hearted man that I know him to be.
Respectfully,
Karla Fitzgerald
Annie Jackson

April 16, 2014

U.S. District Court for the District of Columbia

Re: Michael A. Brown (Criminal Case No. 13-cr-00264-RLW-1)

Dear Judge Roberts:

I am writing in strong support of former Councilmember Michael A. Brown. I
understand that he has entered into a plea agreement with the government. I am
praying that you will be lenient in your sentencing and forego jail time.

My family has known Michael for over a decade. We have supported him personally
and professionally and even hosted events for him. We have always found him to be a
humble, honest and trustworthy friend. I have known Michael since 2008. From the
time I met him, I was impressed by his compassion and the way he cared about the
community and the respect he had for seniors like me as we voiced our concerns
about the community and life in general.

I understand that Michael has been unemployed for nearly a year but during this time
he has continued to give back to his community by volunteering numerous hours as
the Community Outreach Director at Youth in Media and Education (Y.I.M.A.E), a well-
respected charitable organization that empowers troubled youth. I am sure these
youth and their families are appreciative of his efforts.

Michael has taken full responsibility for his actions. I believe he is deeply sorry for the
dire circumstances he brought upon himself, his family, especially his twins and would
rewrite the script in a heartbeat. He certainly is not a danger to society and deserves
a second chance. I hope you will see beyond this lapse in judgment and let the lessons
hes learned through this journey work in his favor so that jail time is not an option
during sentencing.

Sincerely,

Annie Jackson

Annie Jackson

November 6, 2013


Dear Judge Wilkins:

I am writing in strong support of former Councilmember
Michael A. Brown (Criminal Case No. 13-cr-00264-RLW-1). I have known
Michael and his family for almost 50 years. I have always found him to be
trustworthy and selfless. I understand that he has entered into a plea
agreement with the government. He is very remorseful for placing himself
in a compromising position and has taken full responsibility for his actions.
I am hopeful that you will be lenient in your sentencing and forego jail time.

I have worked with Michael and his father, the late Secretary of
Commerce Ron Brown, on numerous human rights and civil rights issues.
The Brown family has a long history of public service and is well-respected
throughout the world for their dedication to human rights and equality. During
his time as a member of the Council for the District of Columbia,
Michael fought endlessly for public policies that addressed the needs of the
poor. I am aware that he is currently dedicating numerous hours as a
volunteer at the Youth in Media and Education Program (Y.I.M.A.E.), a very
worthy entity, which merges entertainment media with education to positively
change the behavior and future outlook of troubled youth. I am very
impressed with his tireless efforts of giving back to the community.

Michael is not a danger to society in any way. He deserves a second
chance. He is a dedicated family man and I know that his ailing mom and
children would suffer from being separated from him. I truly believe he is
deserving of leniency and should serve no jail time. His legal education, proven
leadership and legislative experience would be put to much better use by
sentencing him in a manner that allows him to serve his community in
Washington, DC.

Thank you in advance for your consideration. If you have any
questions, please contact me through my, Senior Advisor, Rev. Janette Wilson on
773-383-7277

Sincerely,

Reverend Jesse L. Jackson Sr.
Founder and President


April 4, 2014


Dear Judge Roberts:

I am writing in strong support of former Councilmember Michael A. Brown (Criminal Case No.
13-cr-00264-RLW-1). I understand that he has entered into a plea agreement with the
government. I truly believe he is deserving of leniency in his sentencing and should serve no jail
time.

I met Michael approximately six years ago when I was visiting family and friends in Florida. I
attended a fundraiser for him -- he was a candidate for the DC City Council At-Large. Even
though I was a Georgia resident, I decided to contribute to his campaign because he impressed
me with his compassion and sincerity. Over the years, I have had the opportunity to be in his
company on numerous occasions including the 2008 and 2012 Democratic National
Conventions. I have always found him to be humble, honest and trustworthy.

I am aware that Michael has been unemployed for almost a year. However, I understand that
over the last several months he has been working numerous hours as a volunteer serving as the
Community Outreach Director for Youth in Media and Education (Y.I.M.A.E), a reputable
organization that promotes artistic expression and self-empowerment to troubled youth. I am
pleased that he has decided to continue to give back to his community. I am sure that he has
been an invaluable asset.

Michael has taken full responsibility for his actions. I know that he is very remorseful for
placing himself in a compromising position. I am hopeful and prayerful that you will be lenient
in your sentencing and forego jail time.

Thank you in advance for your consideration. If you have any questions, please contact me.

Sincerely,

Edna Boyd Jones

Edna Boyd Jones, RN, BSN, MN
US ARMY COL(Retired)

Honorable Richard W. Roberts

Dear Honorable Richard W. Roberts,
I am writing in reference to Michael Brown, who is appearing before your court
after entering into a plea agreement in his case proceeding captioned United States
of America v. Michael Brown.
Michael is my cousin and I have had a close relationship with him for most of my
adult life. I submit this letter because I feel strongly that Michael is a person of good
moral character. Michael has always been a dedicated father and loving son, and
never exhibited the kind of behavior that has lead to his current circumstances
before the Court. I often spend weekends with Michael, at his mothers home,
playing basketball or watching movies with his sons Morgan and Ryan. Michaels
love and devotion to his family are the truest examples of his values. Most times
when the house in full of family members, Michael is the one that volunteers to drive
his mother an hour away to her dialysis treatment. He never thinks of asking
someone else to do it so that he can have some free time for himself. Instead he
gives of himself for the benefit of others. That to me is the Michael Brown that I
know and love.
Michael has made a horrible mistake in judgment, and he is incredibly remorseful,
and is willing to do whatever it takes to make reparations to the community and the
people that he has disappointed, if possible. But to do that, he needs to get this
matter resolved and behind him so that he can be at home with his family and those
that continue to stand in his corner. That is why I sincerely hope that you will allow
Michael to be with us as much as possible. So that we can help him to repair the
damage that has been done and, so that Michael can be with Morgan and Ryan and
continue to serve the community as an outstanding contributor.
Thank you,
Brian Keys
917-386-4760


Your Honor,

By way of introduction, I am William H. McGlockton, II, and am writing to the Court on behalf
of my friend, Michael Brown. Michael and I have been friends for almost 20 years and have
spent many weekends together golfing and attending social events. Michael is a member of a
social golf club that was formed by myself and several other Washingtonians called the Half
Dollar Club of America in 1992. Michael has been a member of the Club for approximately ten
(10) years and has been Club Champion golfer several times at our annual U-Dah-Man tourney.

Michael has always been an exemplary club member and an exemplary friend. In all my time
knowing Michael, I have known him to be a person of excellent character and integrity. He has
been a reliable and trustworthy comrade who has always put the best interests of the club ahead
of his own. Additionally and certainly more importantly, Michael is a proud, patient and loving
father and an adoring son who has always made his obligation to his family his number one
priority in his many private conversations with me.

At this time, I would beg that the Court show all available leniency to a man I know humbly
acknowledges his mistaken steps and looks to a future where he can care for his mother (who is
ill) and watch and support his sons as they mature into manhood.

Most Sincerely Provided By,

William H. McGlockton, II
Founding Member and Grand Poobah (President)
The Half Dollar of America

July 28, 2013

US District Court For the District of Columbia
333 Constitution Ave. N.W.

Re: United States of America v. Michael Brown

Dear Judge Wilkins:

Without reservation I wish to offer this letter in reference to the above matter in which
Mr. Brown has entered a plea. I have known Michael for a number of years as neighbor,
friend and as DC residents concerned for the well being of our beloved city. Michael is
given his time, talents and resources to help others.

As a neighbor Michael is always cordial, encouraging and supportive. He stays on top of
things and expresses interest in the lives of those he engages daily. All would want to be
a friend of Michael. His upbeat personality and empathy is comforting and encouraging.

While I believe the above is important, I am writing this letter of support to share a story
that may provide insight on his heart. Following a failed attempt to be elected to political
position, I met a family touched by Michael during that campaign. I was speaking to
parents about college preparation (my favorite topic) and a mother and I engaged after
my presentation. I discovered that she had shared her challenges to Michael at a
campaign event thinking that his pledge to connect her to help was solely connected with
his desire to win an election. She further informed me that following the close of the
campaign Michael connected her with services and persons who were able to help her. I
was impressed but not surprised.

As you consider what is best, I ask that you consider this and other good works of
Michael.

Thank you.

Leroy Nesbitt, Jr.
H. Cody Press III

August 12, 2013


Dear Judge Wilkins:

I have known Michael Brown for 40 years since our days in Washington DC. He is the same age as my
younger sister as they were rug rats in the backyard of barbeques of friends which I now call family.
We really became friends after he graduated law school when our age difference meant very little.

I had graduated from Dartmouth College, received my MBA from Wharton and started my 28 year
career in investment banking at Merrill Lynch, when Michael and I reconnected. We saw each other at
political events, had dinners and played golf together. We just plain had fun. We became members in
the same fraternity, Sigma Pi Phi, the oldest African American fraternity in the country. I nominated
Michael for membership into our eclectic golf club, The Half Dollar Club of America, African American
friends and golfers from all over the Country.

Michael is a very generous person. He has supported my charities in Los Angeles from afar. Anything I
would ask Michael to do, he was there to support me and my family. When my Dad died, Michael was
at the funeral at Trinity Episcopal Church to give my family a proclamation from the District of
Columbia. The proclamation was for my Dads efforts in supporting the police and firemen of the
District as a physician.

I know Michael knows he has erred in his ways. Living above his means has made him do things that
are incomprehensible to the both of us. I know he has deep regrets and will not error in the future.
Reality has hit him.

I am writing this letter to request reasonable leniency in his sentencing. It is going to hurt Michael
tremendously not to see his sons progress through college. He is not a menace to society. His time in
jail will give him time to reflect the error of his ways. When in jail and missing his family and friends, he
will realize even more, his wrong doing. The length of his stay will not increase the level of his resolve.
He will get it within the first week.

Please give my very close friend, Michael Brown, all due consideration.

Respectfully,


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April 19, 2014
Mark S. Thomas
Judge Richard Roberts
Dear Judge Roberts,
Its painfully obvious my lifelong friend Michael Brown has put himself in an unfortunate
position. This outlier action is one he deeply regrets.
Nonetheless, I know an infinite number of reasons this will not be his legacy in my eyes.
Michaels kindness and grace is most evident with his family. Ive watched the anchor he has
become with his young sons. Constantly preparing them to be responsible young men by first
being good human beings. Not surprisingly, his duty to Mrs. Browns healthcare is standard
operating procedure for Michael. Yes, this should be the right thing for any son. But, Michael
has the capacity and the willingness to do this for me and my Mother if asked. Thats the
qualitative difference with him. Michael defines friendship.
Im hopeful you might consider the positive influence Michael can provide to the larger
community without incarceration. His altruistic nature will be uplifting to the participants in
Youth in Media. Not to mention the numerous non-profits that will benefit from his personal and
professional achievements if given the chance.
Now, make no mistake about it, Michael made a mistake. But his approach to life, his friends
and family is endearing, rewarding and frankly inspiring. He is a success in the most humble way.
Your honor, thank you for the time and consideration.
Sincerely,
Mark S. Thomas

RE: Conviction and Sentencing of Michael A. Brown

July 11, 2013

Dear Mr. Wilkins,

I am writing you this letter today with out prompting or solicitation from Michael
A. Brown with regards to his conviction and future sentencing. I have known Michael for
thirty years.

Michael and I graduated from the same University in 1983 thru 1987 (Clark
UniversityWorcester, Massachusetts). The Michael I knew then was a soft spoken,
kind friend who would come to my house to relax, play basketball and discuss politics.

As I am sure you are aware, Michaels father was killed in 1996 in a tragic plane
accident in Crotia while serving our country as the Commerce Secretary under President
Bill Clinton. After his fathers passing I noticed a sea change in Michaels personality
and behavior. I fully believe that due to this tragedy, the mooring that his father provided
was lost, and I personally witnessed a great change in Michaels behavior. He became un-
approachable, aloof, and despondent. I would invite him to play basketball, but the calls
were never returned.

I have been running a construction and development company called Washington
Landmark based in the District since 1992, and during this time I have run into my share
of District officials who have attempted to solicit bribes for favors. In one of my most
recent (September) dealings with corrupt officials, the FBI stepped in with the prodding
of the owner at Channel Square (325 P Street, SW, Washington, DC). Two employees of
the District were arrested and convicted. In this particular shakedown, we (the owner and
my company) were told that $360,000 of fines and violations and possible jail time
awaited us, unless we compensated the officials for their efforts. These officials were
trading their responsibility to the public for cash payments of $20,000 (it would have
been a lot more if the FBI had not stepped in to arrest them!). These two former
environmental inspectors for the District of Columbia were sentenced to a year behind
bars.

The above bribery episode was mentally tortuous, and made me feel vulnerable
for my personal safety as the threats mounted and while the attempted shakedown took
place (over a month period). Again these two criminals received a one-year sentence,
while Michael is looking at serving a lot more than one year.

I am writing you to implore you to confer some leniency in the sentencing of
Michael Brown for the crime he has committed, especially in comparison to the crimes
perpetuated against me by other district officials. The man was changed dramatically
after the tragic and untimely death of his father. He became unmoored, and his actions (in
this bribery case) speak for themselves. I only ask, that the sentencing be reduced to
reflect what former officials received while trying to solicit a bribe from me, and that
some weight is given to what Michael lost when his father died.

Sincerely,

J. Karl A. Voglmayr

September 8, 2013

The Honorable Robert Wilkins
United States District Court for District of Columbia

Your Honor,

I have known Michael Brown for my entire life. Our families have know each other for four
generations. In fact, it was my father who introduced Michael's parents to each other initially
(many years ago). I can personally attest that he is a kind, generous and loving person. Even as
children, Michael was always popular and had a reputation of standing up for those who were
shy and deemed less popular for whatever reason. He had time for everyone and made people
feel special. Without a doubt, this selfless quality of making people feel important continues to
this day in every aspect of his life - as a father, a brother, a son, a friend, a colleague, a civil
servant.

This genuine concern for others is why he has committed himself to public service his entire life
when he could have easily gone exclusively into the private sector and achieved greater financial
success and notoriety. While he has reached significant heights professionally based on merit,
charisma and integrity, he still remains one of the most genuine and widely cherished friends and
mentors a person could have. Always ready to lend a helping hand whenever needed without
hesitation. I realize he has entered into a plea but needed to convey the fact that he has
consistently displayed principled characteristics throughout the 44 years that I have had the
pleasure of knowing him.

I am truly honored to have him as a close family friend for so many years.

Sincerely,

Eden Williams

CERTIFICATE OF SERVICE

I hereby certify that on April 24, 2014, a copy of the foregoing Sentencing Memorandum
of Michael A. Brown and Declaration of Brian M. Heberlig in Support Of thereof, with exhibits,
was served on the government and to Probation Officer Kathie J. McGill via electronic mail.

Brian M. Heberlig


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