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Good Afternoon your honour, my name is Talebiani initial N and I am here to represent the

defendant, my client, Mr. Brad Pitt.


If it pleases the court, your honour, may full case citations be dispensed with for oral
submissions?
If it pleases the court, I would also like to tender the letter written by one Mr Ray ONeill,
master Painter and a previous employer of the defendant.
The defence has Three submissions:
o first submission is with regards to the circumstances preceding and following the
event of 5 February 2013
o the second submission is with regards to the history of the defendant
o The third submission is with regards to mitigating factors

For the First submission, I would like to bring to your attention your honour that:
o On 4 February 2013 my client had a verbal argument with the two victims. There
were no reported witnesses to the incident. Also, the specificity of the situation is
unclear. However, it is clear that all parties agreed that there was a confrontation
between the defendant and the victims. Also, that the defendant potentially lost
his job due to the incident.
o During the following confrontation 5 February 2013, there was an added party,
that of Ms. Ange Jolie who, by the statements of all parties involved as well as the
two witnesses, was present and potentially a participant in the incident.
o As already provided to you, your honour, my clients previous probation officer
Ian Frank of the Ipswich Probation and Parole provided a letter stating that the
defendant and the victim, Ms. Jennifer Aniston, were known to each other and
had had a previous relationship. It was also stated in the letter that the victim, Ms.
Jennifer Aniston, was known to the probation office, where various tension and
confrontations had taken place between the her and the defendant. The probation
officer has stated that although the defendant took part in commencing
confrontations at times, in some cases, Ms. Aniston was the initiator as well.
Clearly, your honour, this confrontation was not random and my client cannot be
said to be a risk to the community because of this incident.
o I would also like to draw your attention, your honour, to the letter written by the
defendant after the incident, received by the Queensland Police Service by 3 May
2013. I admit, your honour, which the defendant did not appear to give the extent
of the damage that occurred in the letter. However, I would like to draw your
attention to the fact that my client did admit to the confrontation and to the
striking of the victims car. Also, I would ask that it be taken into account as
under s13 of the Penalties and Sentencing Act, 1992 that my client did hand
himself in to the custody of the police following the letter, cooperated with the
police and provide an early guilty plea, demonstrating his degree of remorse as
well as saving this court the financial burden following trials.

For the Second Submission, I would like to bring to your attention your honour the
history of the defendant
o Your honour, my client has had a tough life. He grew up in an abusive household,
as indicated by his ex-employer Mr. Ray ONeil in his letter that I previously
provided to you.
His anger management problems could be an outcome of the abuse he
suffered at the hands of his father
There is no doubt, your honour, that my client struggles with anger
management. Nevertheless, he appears to be accepted into the community,
as provided by both letters by the probation officer and Mr. Ray ONeil
o My client also has a 12 year old daughter that is fully dependent on him alone. As
a single parent, my client is known to put much of his time and effort in the
raising of his daughter. This was commented on, through the letters by both the
probation officer and Mr. Ray ONeil
o Your honour, I admit that my client does have a criminal history. However, I
would draw your attention to the fact that for none of the previous charges has he
been sentenced to imprisonment. Also, the charges, outside of the last one, have
been over a stretch of twenty five years.
o Moreover, although he was charged for 12 months probation, his complied with
all terms of the sentence and completed them prior to his latest offence. Also, the
probation officers letter clearly indicates that my client cooperated fully with the
instructions provided to him, seeking employment as best he could while still
taking care of his 12 year old daughter.

For my third submission, your honour, I would draw your attention to mitigating factors similar
to previous common law sentencing judgements to be considered.
The case of Crown against Christopher Brian Hilton was similar in the sense that the
victim and accused had a previous tense history, the accused had a similar criminal
history of a previous AOBH as well as other irrelevant charges, the age of the accused to
the age of my client is close and both had young dependents under their support
However, I would bring your honours attention to the divergence between Crown
against Christopher Brian Hilton case and my clients. The accused there committed one
AOBH but it was a very violent act in that the accused continued the assault upon the
victim after the victim fell unconscious. My client, although done with an instrument,
cannot be considered to hold the same degree of malicious intent. Also, the accused, Mr.
Hilton, sought out the victim whereas there is no reason why my client would have
known that Ms. Jennifer Aniston or Ms. Gwynth Paltrow would have been at that
location at that point in time. Also, the accused in crown against Christopher Brian Hilton
provided a very late guilty plea, suggesting that he held little sense of guilt or realization
for the fault and extent of the crime he committed.
I understand your honour by s9 of the SPA as well as the judgement of this case that
avoiding imprisonment is unlikely, however, I would like to bring to your attention that
even for a clear lack of remorse as well as committing such a violent crime, the accused
in Crown against Christopher Brian Hilton only received 18months imprisonment
suspended after 6 moths for operative period of 2 years.
I understand your honour that my clients actions led to two assaults occasioning bodily
harm with an instrument, however, through his letter and his early plea, it is clear that my
client came to realize the extent of his crime and feel remorse for his actions. His
probation officer also wrote that my client is willing to take anger management
counselling, once against showing that my client understands the crime he committed and
wishes to prevent himself from acting in such a way again. Thus, my client would like to
follow the R v Christopher Brian Hilton to an extent with a sentence of 12 months
imprisonment with a sentence of 6 months operative period of 18 months with an
addition of committing to anger management counselling after the 6 month imprisonment
under the supervision of the Probation Office

In the case of Crown against Richard Jayde Cunningham, as previously indicated by my
learned friend, there are some similarities in the accused issue with anger management as
well as his early guilty plea, however I do not think that the similarities equal or override
the distinguishing factor that the accused was 17 at time crime and 19 at trial as well as
he was a first offender.

In the case of Crown against Jeffrey Francis Leach, the history with the victim was
similar. However, on the whole the case was distinguishable to my clients situation both
to the extent of crime and the type of crime committed. Nevertheless, the fact that the
sentencing should include counselling under corrective officer supervision for the period
of probation after imprisonment can be consider in the case of my client, as he has clear
anger management problems.