Sentencing - USA V Thompson, Et Al

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UNITED STATES DISTRICT COURT
1
CENTRAL DISTRICT OF CALIFORNIA
HONORABLE PERCY ANDERSON, JUDGE PRESIDING
UNITED STATES OF AMERICA,
Plaintiff,
Vs.
GREGORY THOMPSON, STEPHEN
LEAVINS, GERARD SMITH, MICKEY
MANZO, SCOTT CRAIG, and
MARICELLA LONG,
Defendants.
___________________________________
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No. CR 13-819 PA
REPORTER'S TRANSCRIPT OF SENTENCINGS
LOS ANGELES, CALIFORNIA
TUESDAY, SEPTEMBER 23, 2014; 9:15 A.M.
LEANDRA AMBER, CSR 12070, RPR
OFFICIAL U.S. DISTRICT COURT REPORTER
312 NORTH SPRING STREET, # 408
LOS ANGELES, CALIFORNIA 90012
www.leandraamber.com
(213) 894-6603

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A P P E A R A N C E S
IN BEHALF OF THE PLAINTIFF,
UNITED STATES OF AMERICA: UNITED STATES ATTORNEY
BY: BRANDON D. FOX, AUSA
LIZABETH RHODES, AUSA
MAGGIE CARTER, AUSA
312 NORTH SPRING STREET
12TH FLOOR
LOS ANGELES, CA 90017
(213) 894-0284
brandon.fox@usdoj.gov
(213) 894-3541
lizabeth.rhodes@usdoj.gov
(213) 894-7413
maggie.carter@usdoj.gov
IN BEHALF OF THE DEFENDANT,
GREGORY THOMPSON: LAW OFFICE OF DAVID E. STOTHERS
BY: DAVID E. STOTHERS, ESQ.
850 EAST CHAPMAN AVENUE
SUITE C
ORANGE, CA 92866
(714) 288-9688
dave@yourdefense.us
GODES AND PREIS LLP
BY: KEVIN B. McDERMOTT, ESQ.
8001 IRVINE CENTER DRIVE
SUITE 1420
IRVINE, CA 92618
(949) 596-0102
warlawyer@aol.com
IN BEHALF OF DEFENDANT,
GERARD SMITH: LAW OFFICES OF WILLIAM GENEGO
BY: WILLIAM GENEGO, ESQ.
2115 MAIN STREET
SANTA MONICA, CA 90405
(310) 399-3259
bill@genegolaw.com

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A P P E A R A N C E S
(CONTINUED)
MICKEY MANZO:
LAW OFFICE OF MATTHEW J. LOMBARD
BY: MATTHEW J. LOMBARD, ESQ.
316 WEST SECOND STREET
SUITE 1202
(213) 625-1806
mlombard@lombardlaw.net
STEPHEN LEAVINS: LAW OFFICE OF PETER JOHNSON
BY: PETER JOHNSON, ESQ.
409 NORTH PACIFIC COAST HIGHWAY
SUITE 651
REDONDO BEACH, CA 90277
(310) 295-1785
pete@pjohnsonlaw.com
LAW OFFICES OF RICHARD W. RAYNOR
BY: RICHARD W. RAYNOR, ESQ.
800 SOUTH PACIFIC COAST HIGHWAY
SUITE 8-284
REDONDO BEACH, CA 90277
(424) 257-0284
richard@richardraynor.com
SCOTT CRAIG : STONE BUSAILAH LLP
BY: RICHARD RABE, ESQ.
MUNA BUSAILAH, ESQ.
200 EAST DEL MAR BOULEVARD
SUITE 350
PASADENA, CA 91105
(626) 683-5600
MARICELLA LONG: LAW OFFICE OF ANGEL NAVARRO
BY: ANGEL NAVARRO, ESQ.
714 WEST OLYMPIC BOULEVARD
SUITE 450
(213) 744-0216
angel_navarro@me.com

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I N D E X
PAGE
SENTENCING OF DEFENDANT THOMPSON 79
SENTENCING OF DEFENDANT LEAVINS 83
SENTENCING OF DEFENDANT SMITH 89
SENTENCING OF DEFENDANT MANZO 93
SENTENCING OF DEFENDANT CRAIG 98
SENTENCING OF DEFENDANT LONG 103

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LOS ANGELES, CALIFORNIA; TUESDAY, SEPTEMBER 23, 2014
9:15 A.M.
-o0o-
THE CLERK: Calling Item One, United States of
America versus Greg Thompson, Stephen Leavins, Gerard Smith,
Mickey Manzo, Scott Craig, and Maricella Long.
Counsel, please state your appearance for the
record.
MR. FOX: Good morning, your Honor.
Brandon Fox, Lizabeth Rhodes, and Maggie Carter on
behalf of the United States. With your permission, also
sitting at counsel table is David Dahle, Special Agent with
the FBI.
THE COURT: Good morning.
MR. STOTHERS: Good morning, your Honor.
David Stothers and Kevin McDermott on behalf of
Greg Thompson, who is present.
MR. JOHNSON: Good morning, your Honor.
Peter Johnson and Richard Raynor on behalf of
Stephen Leavins, who is present.
MR. GENEGO: Good morning, your Honor.
William Genego on behalf of Gerard Smith, who is
present.
MR. LOMBARD: Good morning, your Honor.

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Matthew Lombard on behalf of Mr. Manzo, who is
present.
MR. RABE: Good morning, your Honor.
Richard Rabe and Muna Busailah on behalf of Scott
Craig, who is present.
MR. NAVARRO: Good morning, your Honor.
Angel Navarro with Maricella Long. She is present
this morning.
THE COURT: Good morning.
This matter is before the Court for the
pronouncement of judgment and the imposition of sentence. Is
there any reason why judgment and sentence should not be
imposed at this time?
MR. FOX: Not from the Government, your Honor.
MR. McDERMOTT: Not by defense, your Honor.
MR. JOHNSON: No, your Honor.
MR. LOMBARD: No, your Honor, on behalf of
Mr. Manzo.
MR. NAVARRO: No, your Honor.
MR. RABE: No, your Honor.
THE COURT: I provided notice of the conditions of
supervised release that the Court is contemplating imposing
in this case. Does any of the parties have any objections to
the contemplated positions of supervised release?
MR. FOX: Not from the Government, your Honor.

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MR. McDERMOTT: No, sir, not from defendant
Thompson.
MR. LOMBARD: No, your Honor on behalf of
Mr. Manzo.
MR. GENEGO: No, your Honor.
MR. RABE: No, for Craig.
MR. NAVARRO: No, your Honor, not for Miss Long.
THE COURT: What I intend to do at least in terms
of calculating the advisory guidelines in this case is to
address the various arguments for enhancements, the
objections -- to do that jointly, addressing each counsel.
And then once the advisory guidelines are
calculated, I'll have some general comments about the nature
of the offense, and then we'll address each of the defendants
individually with respect to the appropriate sentence in this
case.
Does anybody have any objections to proceeding in
that manner? If you do, I'll do them individually.
MR. FOX: Not from Government, your Honor.
MR. STOTHERS: Not from Thompson, your Honor.
MR. LOMBARD: No, your Honor.
MR. RABE: No.

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THE COURT: Was the Presentence Report timely
disclosed to all parties?
MR. FOX: Yes, your Honor.
MR. McDERMOTT: Yes, as to Thompson.
MR. LOMBARD: Yes, your Honor, for Mr. Manzo.
MR. JOHNSON: Yes, your Honor.
MR. GENEGO: Yes as to Smith.
MR. RABE: Yes as to Craig.
MR. NAVARRO: Yes, your Honor.
THE COURT: The Court has received, read, and
considered the Presentence Report, addendum to the
Presentence Report, the parties' objections, the sentencing
memoranda, and letters received on behalf of the defendants.
Apart from any issues raised in your sentencing
memoranda, which we'll address shortly, is the Presentence
Report factually accurate? Do you have any objections,
corrections, or additions?
MR. FOX: None from the Government besides the
additional obstruction enhancement, which we've addressed in
our motions.
MR. McDERMOTT: Sir, as to Thompson, nothing that
hasn't been addressed in the pleadings so far.
MR. LOMBARD: Same for Mr. Manzo, your Honor.
MR. JOHNSON: Same for Mr. Leavins, your Honor.

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MR. GENEGO: Same for Mr. Smith.
MR. RABE: And Craig.
MR. NAVARRO: And Ms. Long, as well.
THE COURT: All right. What I'm going to do is I'm
going to first object -- or address the factual objections
and corrections that the defendants have stated; and after
that I'll address the potential enhancements that have been
proposed by the Probation Office; and then I'll address the
proposed minor role adjustments that I believe Defendant
Smith and Manzo have asked for; and finally I'll address the
Government's argument for an obstruction of justice
enhancement.
Why don't I turn first to the factual objections
raised by Mr. Thompson. I've reviewed your papers. I'm
ready to rule on those, but I'll hear you if you want to be
heard on any of those.
MR. McDERMOTT: Sir, on behalf of Defendant
Thompson, everything that we wanted to address with this
Court was put in the pleadings, and there wouldn't be
anything further we would like to say as to those issues.
THE COURT: All right. Does the Government wish to
be heard on any of the factual objections raised by
Mr. Thompson?
MS. CARTER: Your Honor, I just want to address one
point.

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The Government recently submitted some exhibits in
support of paragraphs 80 through 84 in the PSR to which
Defendant Thompson objected, but I just want to clarify for
the Court that the Government is not asking the Court to
adopt or rely at sentencing on paragraphs 83 and 84.
THE COURT: All right. All right. As to the
objection to Paragraph 70, I don't believe it's necessary to
rule on whether Mr. Thompson's superiors in this case,
Mr. Tanaka or his assistant, were participants in this scheme
because that issue will not affect Mr. Thompson's sentence
regardless of the role played by Mr. Tanaka.
Mr. Thompson's sentence and the calculation of the
advisory guidelines will be determined based on his conduct
in this case.
And as to Paragraph 18, the Court finds that
Paragraph 18 is supported by a preponderance of the evidence
that was adduced in this case including several of the trial
exhibits.
As to Paragraph 25, the Court finds that
Paragraph 25 is supported with a preponderance of the
evidence as it essentially recites the defendant's own
statements and one of the trial exhibits I believe
Exhibit 33.
As to paragraphs 26 and 32, these paragraphs
essentially summarize trial exhibits 35 and 36. Moreover,

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there's additional evidence in the record to support the
statements in paragraphs 35 and 36. And, therefore, the
Court believes that they are supported by a preponderance of
the evidence.
As to Paragraph 29, the Court believes that
Paragraph 29 is supported by a preponderance of the evidence
including several of the trial exhibits, the testimony of
Yolanda Baines, as well as testimony from Jason Pearson and
Ryan Ortiz in addition to the testimony of Mr. Tanaka that he
was sure at some point that he had seen the writ. And I
believe those exhibits also support that, and moreover those
statements are consistent with the verdict in this case.
As to Paragraph 30, the Court also believes that
that statement is supported by the trial exhibits in this
case. And, in fact, I believe the defendant doesn't dispute
that he ordered deputies to go to the Records Center with
another lieutenant. And there's evidence to support an
inference that that records jacket was slipped under
Lieutenant Thompson's door.
Paragraph 33 I think what we probably ought to do
in that case is have the full portion of the sentence. I
think the Probation Department basically cut off a portion of
the sentence from Exhibit 60. And so I'm going to order the
Probation Department to pull -- put the full sentence from
Paragraph -- from Trial Exhibit 60 into the PSR.

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And as to paragraphs 80 and 82, I understand the
Government's withdrawing their reliance or -- on 83 or
paragraphs 83 and 84.
And as to paragraphs 80 through 82 the
Government -- the Court finds that they are supported by
trial exhibits, and the Court by statute is authorized to
consider information that may be relevant to the background
character and conduct of any person that has been convicted
of an offense for the purposes of imposing a sentence.
Any additional objections that you had on behalf of
Mr. Thompson to any of the factual allegations?
MR. McDERMOTT: No, sir, not on behalf of Thompson.
THE COURT: Okay. All right. I'll turn to the
factual objections raised by Mr. Leavins.
Do you wish to be heard on any of those?
MR. JOHNSON: Yes, just briefly, your Honor.
Your Honor, I've addressed all of the objections
that we have factually. I -- the paragraph numbers were
different in Mr. Thompson's PSR as to Mr. Leavins; so I
wanted to highlight just one thing that I think is important
for the Court, and that's the leadership or organizational
role.
THE COURT: Sir, I'm only dealing with the factual
objections as to any enhancements. We'll get to those next.
MR. JOHNSON: I apologize, your Honor. That was my

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mistake, and there were no -- everything was written.
THE COURT: All right. Thank you.
All right. I believe there was an objection to
Footnote 1 in Paragraph 18. Okay. The Court is -- I don't
think a ruling is necessary because the Court didn't rely on
Footnote 1 in determining the sentence for Mr. Leavins in
this case.
There's also an objection to Footnote 6 in
Paragraph 32. The Court believes that that footnote is
supported by a preponderance of the evidence in this case.
There was also an objection to Paragraph 36, and
the Court believes that that paragraph is amply supported by
a preponderance of the evidence as I believe that at some
point Mr. Craig actually specifically names the FBI as an
entity in which Mr. Michel shouldn't talk to.
Now, there was also an objection to paragraphs 83
through 87. Is the Government still -- does the Government
have a position with respect to paragraphs 83 through 87 as
to Mr. Leavins?
MR. FOX: Your Honor, we do not ask the Court --
we're not asking the Court to rely on those paragraphs in the
sentencing.
THE COURT: The Court will not rely on paragraphs
83 through 87 in determining a sentence in this case for
Mr. Leavins.

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Any additional objections on behalf of Mr. Leavins?
THE COURT: All right. I'll turn to the factual
objections raised by Mr. Smith.
Do you wish to be heard on any of those?
MR. GENEGO: No, your Honor, we'll submit on the
papers.
THE COURT: All right. I believe Mr. Smith
objected to Footnote 1 in Paragraph 18. That Paragraph or
that issue will not affect Mr. Smith's sentence. There was
also an objection to Paragraph 18.
The Court finds that that statement is supported by
a preponderance of the evidence. I believe there is evidence
in the record that Mr. Smith made clear his knowledge of the
subpoenas and, moreover, to the extent that there is an
objection that he didn't have any knowledge of the federal
grand jury investigation.
The jury's determination proves that -- well,
supports his knowledge of the grand jury investigation in
this case.
There is also an objection to Paragraph 22. The
Court finds that that statement is supported by a
preponderance of the evidence as -- including Trial Exhibits
37, Trial Exhibit 48; and thus the statements are accurate as
shown by those exhibits.

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There was also an objection to Paragraph 26. The
preponderance of the evidence including the testimony from
Ryan Ortiz as well as additional trial exhibits that were
offered during the trial.
There is also an objection to Paragraph 33. The
Court finds it's unnecessary to determine whether Mr. Smith
actually transported Mr. Brown to different jails or whether
he caused it to happen, and that will not affect his sentence
in this case.
There's also an objection to Paragraph 34. I'm
going to strike -- or order the Probation Department to
strike that Smith told one of those deputies that the federal
government was coming to get Brown, and they should, at all
costs, stop the federal government from seeing him.
Any additional objections raised by -- factual
objections raised by Mr. Smith?
MR. GENEGO: No.
THE COURT: Mr. Manzo had an objection to
Paragraph 25 as well as paragraphs 62 and 66. Any additional
objections you wish to raise?
MR. LOMBARD: No, your Honor, we would submit.
THE COURT: All right. As to Paragraph 25, the
preponderance of the evidence, and the Court believes

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supported by Trial Exhibit 177. And therefore that objection
is overruled.
As to Paragraph 62 and 66, to the extent those
paragraphs attribute conduct to Mr. Manzo instead of others,
I'm not going to consider it, but I will consider it in
determining Section 2(j)(1).2 as to whether or not this
scheme was extensive in scope and in the planning or
preparation as they relate to Mr. Manzo's actions or those of
others as long as -- as far as those actions were reasonably
foreseeable to him. Accordingly the Court finds that it's
unnecessary to rule on a specific objection to those
paragraphs.
Also the Court to the extent that Paragraph 66 is
something more than summarizing facts regarding Manzo's role
as to why he was not an organizer or manager. It seems to me
I really don't need to rule on that objection because I don't
find it necessary to consider in imposing his sentence in
this case.
I don't believe Mr. Craig had any factual
objections to the Presentence Report.
MR. RABE: That's correct.
THE COURT: And I believe Miss Long had no specific
factual objections to the Presentence Report.
MR. NAVARRO: Correct, your Honor.
THE COURT: All right. I'm going to turn to the

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enhancements. There was a two-level enhancement pursuant to
Section 2(j)1.2(b)(3). I believe Defendant Smith, Manzo,
Craig and Long argued that they shouldn't be held accountable
for that enhancement involving the destruction, alteration,
or fabrication of records or scheme otherwise being extensive
in scope or planning or preparation.
All right. Why don't I take up -- does Mr. Smith
wish to be heard on that enhancement?
MR. GENEGO: No, your Honor, we'll submit on the
papers.
THE COURT: Does Mr. Manzo wish to be heard?
MR. LOMBARD: No, your Honor, we'll submit.
THE COURT: And does Mr. Craig wish to be heard?
MR. RABE: Your Honor, we'll submit on what's been
already --
THE COURT: All right. And does Miss Long wish to
be heard?
MR. NAVARRO: No, your Honor, nothing further.
THE COURT: Does the Government wish to be heard on
that enhancement?
MR. FOX: No, your Honor.
THE COURT: All right. The Court believes that
that enhancement is appropriate because this offense involved
the alteration or fabrication of the substantial number of
records and documents in hiding Inmate Brown from the federal

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government.
It applies either under Section 2(j)1.2(b)(3)(a) or
2(j)(1).2(b)(3)(c), and it also applies under
Section 2(j)1.2(b)(3)(a), also applies under
2(j)(1).2(b)(3)(c) because this offense was extensive in
scope as it involved numerous participants, occurred over a
substantial period of time -- namely six weeks -- and
involved witness tampering and the threatened arrest of an
FBI agent.
Where a conspiracy is charged, a defendant can be
held accountable for the actions of another, and the
application note provides that a defendant is not just
accountable for his own conduct but also for the action of
others committed in furtherance of the jointly undertaken
criminal activity with the exception of the conduct of others
shouldn't be applied if it wasn't reasonably foreseeable.
And in this case the Court finds that the conduct
engaged in by others was reasonably foreseeable.
Specifically there was witness tampering involved
when Inmate Brown was interviewed on at least two occasions.
And while these defendants may not have initiated that
scheme, they were aware of the scheme in order to find him
and interview him.
Furthermore, none of these defendants did anything
to remove them from the conspiracy or to prevent the

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codefendants from engaging in conduct while it was ongoing.
And as such the Court finds that this conduct was
reasonably foreseeable as to each of the defendants and the
application of the enhancement was appropriate.
Okay. There was also a two-level enhancement
applied by the Probation Department for an abuse of position
of trust under Section 3(b)(1).3. Does Mr. Leavins care to
be heard on that enhancement?
MR. JOHNSON: No, your Honor. We'll submit on the
papers.
THE COURT: Does Mr. Smith care to be heard on that
enhancement?
MR. GENEGO: No, your Honor. We'll rest on the
arguments that were made in the papers.
THE COURT: All right. And does Mr. Craig wish to
be heard on that enhancement?
MR. RABE: Submit on the papers, your Honor.
THE COURT: And does Miss Long wish to be heard?
MR. NAVARRO: No, your Honor. We'll submit on our
brief.
THE COURT: Does the Government wish to be heard?
MR. FOX: No, your Honor. Thank you.
THE COURT: The defendants essentially argue that
the abuse of trust enhancement does not apply to them because
of their positions as law enforcement officers are

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insufficient to create a position of public-to-private trust
and because they had no special duty or relationship with the
federal government.
The defendants' actions as law enforcement officers
significantly contributed to the obstruction of justice in
this case. Among other things and in their capacity as law
enforcement officers, they repeatedly interviewed Inmate
Brown. They hid him. They changed his name. Moved him in
order to keep him from testifying before the grand jury and
ordered other deputies not to cooperate with the FBI. They
conducted surveillance on FBI Special Agent Marx, threatened
Marx with an arrest.
In addition, the defendants ordered Michel not to
cooperate with the FBI, and therefore the deputies abused
their position of public trust with Michel as well as with
Deputy Courson.
The Ninth Circuit has held that police officers are
accorded public trust to enforce the law. The public,
including fellow law enforcement agents, expect the police
officers will not violate the laws that they are charged with
enforcing. And each of the defendants took advantage of that
trust and adversely influenced the grand jury's
investigation.
This is precisely the type of situation that is
contemplated by Section 1(b) or 3(b)(1).3 as an abuse of a

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position of trust.
And, therefore, the defendant's objections are
overruled, and the Court finds that the Probation Office
correctly applied that enhancement.
All right. There was also a four-level enhancement
that was applied for an aggravated role pursuant to Section
3(b)(1)(1).A for defendants Thompson and Leavins. Do you
wish to be heard on that enhancement?
MR. McDERMOTT: No, sir, on behalf of Thompson.
THE COURT: All right. As I understand it,
Defendant Thompson raised one objection. He urged that the
role offense warranted only a two-level enhancement rather
than the four-level enhancement. And let me ask, does the
Government wish to be heard as to that enhancement?
MS. CARTER: Not beyond what's in the papers, your
Honor.
First of all, the two-level enhancement cannot
apply to this defendant because the conviction of at least
six defendants of conspiracy that was charged in Count One of
the indictment and the jury necessarily found beyond a
reasonable doubt that the criminal activity involved five or
more participants.
Here, the evidence established that Mr. Thompson
exercised control over other OSJ co-conspirators and was

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responsible within that conspiracy for making sure that the
informant was hidden from the FBI. He exercised
decision-making authority regarding how to hide Mr. Brown,
recruited accomplices, had conspirators reporting back to
him. The record is clear that Mr. Thompson did considerably
more than pass along directives. He was organizing,
directing the actions of the OSJ deputies who worked for him.
The Court finds that the defendant acted as an
organizer or leader, and the application of the four-level
adjustment was proper. And therefore the objection is
overruled.
All right. Does Mr. Leavins wish to be heard on
the enhancement?
MR. JOHNSON: Yes, your Honor, just briefly.
Your Honor, did -- this is the enhancement that I
think is troubling because of the context in which the
offense occurred. And I just -- the Presentence Report
didn't mention or gave little mention of the power and
responsibility of Sheriff Baca, Undersheriff Tanaka and
Captain Carey in orchestrating and guiding and giving orders
in the leadership. Just because those individuals were not
charged in this offense doesn't mean that the -- Mr. Leavins
is then -- now the leader or organizer in the offense.
The directions in this case based upon -- I know
that the jury didn't hear it, but the Court has -- has heard

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the media reports from Sheriff Baca and the letter from
Sheriff Baca on September 26, 2011 -- give an indication that
Sheriff Baca believed that the actions of the -- of the
Los Angeles Sheriff's Department were, in fact, legal.
And more importantly in this context gives an
indication that he orchestrated and directed these
individuals to investigate the presence of the cell phone and
the person or persons responsible.
And I think that under these circumstances, the
leadership role is inappropriately applied in the PSR.
be heard?
MR. FOX: Very briefly, your Honor. I just want to
point out that Mr. Leavins himself on the witness stand
testified that he was the one that ordered that Mr. Brown
would be moved despite knowing that a writ was probably
coming and that, with respect to the approach and threatened
arrest of Special Agent Marx, that Mr. Leavins said that
Mr. Tanaka and Mr. Baca did not order that to occur. Did not
order them to threaten the arrest of Special Agent Marx.
Mr. Leavins was involved in every phase of this at
a high level. He is one of the two highest-ranking people.
He and Mr. Thompson are the two highest ranking people
charged, and it's clear that they had their fingers all over
everything that was happening with this obstruction.

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MR. JOHNSON: Your Honor, as to the order from
Lieutenant Leavins, Lieutenant Leavins communicated -- he was
the conduit of information. And I think the testimony of
Undersheriff Tanaka and Captain Carey were clear on that,
that he communicated information to them. And the orders
came from the -- higher than him. It's impossible for him to
have ordered his superiors to do anything or to act in a
certain way. Once he informs him, the orders come down,
that's what I believe the testimony was.
As far as a threat of arrest, I believe that
Mr. Craig stated that Mr. Leavins never said -- threatened,
"Go arrest her." And, in fact Lieutenant, Leavins testified
that he didn't say "Go out there and arrest her."
So I think that is an error on the Government's
part in stating the evidence. The -- and basically, you
know, the general comment that his leadership was all over
this is just -- it's highlighting his role as Lieutenant, and
the role as a Lieutenant or the -- the named Lieutenant is
not an appropriate factor to consider in this application of
the guideline. It's more of his role in the offense.
THE COURT: All right. The Court finds that
regardless of the roles played by other higher-ranking
officials, that Defendant Leavins exercised discretion,
control, and leadership within the conspiracy. It makes him
an organizer or leader.

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The guideline application also notes that more than
one person can be an organizer or a leader for purposes of
the enhancement. Specifically I believe Application Note 4
states that there can, of course, be more than one person who
qualifies as a leader or organizer of a criminal organization
or conspiracy.
Here Mr. Leavins either exercised control over, had
leadership responsibility for several aspects of the
conspiracy including hiding Anthony Brown and tampering with
witnesses. He exercised decision-making authority over the
decision to move Brown, held himself out and was held out by
co-defendant Craig as the superior officer during the witness
tampering interviews of Gilbert Michel and William Courson
and supervised and directed Craig and Long in investigating
the FBI case agent.
Co-conspirators including Craig, Long, Smith and
Manzo were also reporting back to him on their activities
through much of this conspiracy. And the record is,
therefore, clear that he did not let -- the discretion was
not just simply following orders of his superiors. Instead
he was organizing, directing the actions of the OSJ deputies
as well as the ICIB deputies involved in this conspiracy.
The Court, therefore, finds that he acted as an
organizer or leader and the application of that enhancement
was proper; and, therefore, the objection is overruled.

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All right. I believe that there was also an
objection to the three-level enhancement for an aggravating
role for Defendant Craig. Does Defendant Craig wish to be
heard on that issue?
MR. RABE: Your Honor, no. We submitted
substantial argument in the papers already.
be heard?
MS. RHODES: No. Similarly the Government would
rest on its papers, your Honor.
THE COURT: This defendant was a senior
investigator with ICIB and co-defendant Long's training
agent. He was in charge of the investigation as to how that
cell phone that was possessed by Inmate Brown got into the
jail, directed the conduct of Long and other L.A.S.D.
personnel in interviewing Brown and other witnesses, and
directed the team that was involved in the surveillance of
Agent Marx and other FBI agents.
The defendant continued to exercise his leadership
role in the criminal conspiracy by directing aspects of the
scheme to obstruct justice, namely interviewing Brown and
other witnesses and attempts to intimidate Marx. In
particular at one point in the scheme the defendant used his
positions as a Sergeant to order Michel, a subordinate
officer, not to cooperate with the FBI.

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Accordingly the Court finds that the three-level
enhancement for being a manager or supervisor was
appropriately applied by the Probation Officer in this case,
and the objection is overruled.
All right. I believe that Defendant Smith and
Manzo asked for a two-level decrease for a minor role. Does
Mr. Smith first wish to be heard on that issue?
MR. GENEGO: No, your Honor. We'll submit on the
papers.
THE COURT: Mr. Smith argues that he was only
following orders and that he did not repeatedly interview
Brown or move him from one location to another. It's the
defendant who bears the burden of proving by a preponderance
of the evidence that he's entitled to a mitigating role
adjustment.
The Court finds that Mr. Smith has not sustained
his burden of proving that he was substantially less culpable
than the average participant in this case. There were any
number of witnesses that the Hero's Park meeting was called
by and led by Mr. Smith among others. There was testimony in
the record that several other participants in the conspiracy
looked to Mr. Smith or Mr. Manzo.
There's evidence in the record that Smith or Manzo

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were the people that should be called if anyone wanted to
visit Anthony Brown or challenge them while they were
guarding Anthony Brown, that it was Smith or Manzo who told
them about their overtime.
And even if they were following orders, it's clear
from the evidence in this case that Mr. Smith was one of the
participants that was giving orders or overseeing the actions
of others. There were e-mails that he sent out indicating
that he was in charge and there would be no movement of
Anthony Brown without the approval of one of six people. And
Mr. Smith listed himself as one of those six.
And furthermore, Mr. Smith urged other participants
to call him if they needed anything.
He also -- there was other evidence in the record
that showed that Mr. Smith was more than culpable than the
average participant and consequently the Court finds that a
downward adjustment for a mitigating role was not appropriate
in this case for Mr. Smith.
Does Mr. Manzo wish to be heard on the mitigating
role adjustment?
MR. LOMBARD: We'll submit on the papers, your
Honor.
that issue?
MS. RHODES: No, nothing further than the papers,

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your Honor.
THE COURT: Again, the defendant bears the burden
of proving by a preponderance of the evidence that he was
entitled to a mitigating role. The Court finds, for many of
the same reasons stated for Mr. Smith, that he hasn't
sustained his burden; and therefore the Court finds that the
mitigating role or the nonapplication of the mitigating role
was proper in this case.
All right. I believe Mr. Craig asks for a
two-level decrease for an acceptance of responsibility. Do
you wish to be heard on that?
MR. RABE: Your Honor, submitted on the papers.
MS. RHODES: No thank you, your Honor.
THE COURT: Here the defendant admitted to
committing much of the conduct charged by the Government.
However, he never admitted he was engaged in any type of
criminal conduct.
Furthermore, the Court finds that the defendant did
not go to trial solely on the issues unrelated to factual
guilt. Rather he contested his intent which was the element
of both the offenses of obstruction of justice and making
false statements. And for the defendant to be found guilty
of obstruction, the Government had to prove, among other
things, that he acted corruptly with the purpose of

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obstructing a grand jury investigation, similarly the false
statements required that the defendant willfully made a false
statement.
Therefore, the Court finds that the defendant did
not meet the requirements for an acceptance of responsibility
because he forced the Government to prove the elements of the
offense at trial which related to factual guilt.
All right. I'll hear from the Government as to
their proposed two-level enhancement for obstruction as to
Defendant Leavins.
MR. FOX: Your Honor, we will submit on the papers
as well, unless you have additional questions.
THE COURT: All right. Does the defendant wish to
be heard?
MR. JOHNSON: We submit on the papers at docket
531. Just to be clear, we addressed this separately in a
filing on August 25th.
THE COURT: All right. The Court finds that the
Government hasn't sustained its burden and thus the objection
is sustained as to the obstruction of justice enhancement for
Defendant Leavins.
All right. I believe Mr. Craig also objected to
the two level increase for obstruction of justice. Do you
wish to be heard?
MR. RABE: Your Honor, yes.

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In the Government's reply, that was recently filed
on Page 7, it states that defendant also argues that his
testimony regarding his general practice of admonishing
witnesses to refuse to talk to the FBI was not perjured
testimony.
That's in difference to their original argument and
against the actual testimony of my client. On Page 17 of
their original papers, line 15, 16, the question was:
"Okay. Other than that, it is generally our
practice to order people not to talk."
So they've morphed the -- what they're calling
perjury from a general practice to order people not to talk,
which the answer was yes to a specific statement saying it
was his practice not to order people to talk to the FBI,
which does not accurately reflect the evidence.
The general practice is a general practice over
years. It can't be a snapshot on the -- this particular case
that just has a few people being interviewed, some of which
were admonished, some of which were not, a general practice,
it wasn't my general practice in this case. It's my general
practice.
So there's insufficient evidence for any court to
decide what would have been Sergeant Craig's general practice
in this area for witnesses in general. That would have to
necessarily include going back to review a substantial number

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of cases historically and that's -- we don't have that kind
of evidence to determine a general practice.
As to the other two, I'm going to submit them on
the papers.
be heard?
MS. RHODES: Well, yes, your Honor, briefly.
In the Government's reply, it was summarizing what
it believed defendant's argument was regarding the general
practice at Page 7. The Government has submitted the five
interviews that Defendant Craig did on August 30 -- Bravo,
Michel, Her (phonetic), Lyons and Courson. The defendant
testified that his general practice was to say not to talk to
anyone. And yet here, three out of the five, he did not do
so. And specifically with regard to Deputy Bravo, he
indicated he did not do so because he had no reason to
believe that Deputy Bravo was talking to the FBI.
And for that reason the Government believes that is
perjured testimony.
THE COURT: All right. The Court finds that the
Government has not sustained its burden and the objection to
that enhancement is sustained.
All right. Has Mr. Thompson and his counsel read
the Presentence Report and the addendum to the Presentence
Report?

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MR. McDERMOTT: We, have sir.
THE COURT: And although the guidelines are not
mandatory but advisory, has the Probation Office correctly
analyzed and applied the advisory guidelines in this case?
MR. McDERMOTT: Yes, sir, it has.
THE COURT: Thank you.
All right. Has Mr. Leavins and his counsel both
read the Presentence Report and the addendum to the
Presentence Report?
THE COURT: And has the Probation Office correctly
MR. JOHNSON: Outside of the objection, yes, your
Honor.
And has Mr. Smith and his counsel both read the
Presentence Report and the addendum to the Presentence Report
some?
MR. GENEGO: Yes, your Honor. We have both.
MR. GENEGO: Other than the previously stated
objections.
And has Mr. Manzo and his counsel read the

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Presentence Report and the addendum to the Presentence
Report?
MR. LOMBARD: Yes, your Honor.
MR. LOMBARD: Yes, your Honor, notwithstanding the
objections.
Sorry. Did I skip Mr. Leavins?
THE COURT: All right. And has Mr. Craig read the
Report?
And has Ms. Long and his counsel read the
Report?
MR. NAVARRO: Your Honor, Ms. Long and I have read
them. And the aside from our two objections, no other
objections.

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MR. NAVARRO: Aside from our objections, yes, your
Honor.
THE COURT: And has the Government read the
Presentence Report and the addendum to the Presentence Report
for each of the defendants?
Just to be clear, did -- did you admonish or ask
Mr. Smith? Because at counsel table we're a little confused
over that too.
THE COURT: All right. Let me just make sure.
On behalf of -- I believe I did.
MR. FOX: I believe you did too, but we're unsure
over here.
MR. GENEGO: I believe you did as well.
MR. FOX: All right. Then we're fine, your Honor.
Yes, we read all the PSR's, and we agree with all
the calculations from the PSR's.
THE COURT: All right. Does counsel for
Mr. Thompson wish to be heard on appropriate sentence in this
case?
MR. McDERMOTT: Could we have a couple of words
with the Court if you're so inclined, sir?
THE COURT: Yes.
MR. McDERMOTT: Thank you. From here or the

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podium, which do you prefer?
THE COURT: Why don't we do it from the lectern.
MR. McDERMOTT: Sir, this is probably one of the
few times in the course of this trial that you might find me
a little short of words to express the kind of opinions that
I might have on behalf of my client at this particular point
in time.
We have before the Court a request to consider some
variances. I would ask the Court to consider in the totality
of the circumstances the e-mail of 18 August where my client
had requested to send Mr. Brown to state prison to remove him
from the jail completely and to extricate Brown from the
machinations that were going on that they were just coming to
understand.
If my client had the kind of supervisory power that
he now wishes he certainly did have, Mr. Brown would have
been in state prison and maybe this entire circumstance would
have never occurred. There would have been no opportunity
for the mechanics that took place, whoever may have ordered
or dictated or directed those.
But I believe on the 18th of August, Mr. Thompson
was trying to do the right thing and was trying to make this
situation smooth out, even out, go into a direction where
they could figure out what was going on. And I don't believe
the Government would ever argue that if Mr. Brown was in some

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state prison on the 19th of August, that there would have
been any type of argument that there might have been
obstruction or impeding or anything of that nature.
And from the very start of this trial, we heard
that there was no actual obstruction, that it was an
endeavoring to obstruct.
And what this was an attempt on my client's part
was to make this endeavor go away, to make it absolutely end
at that particular point in time.
And if there was any assistance, that Mr. Brown
could have offered the Government that could have occurred at
Calipatria, any other number of places in which he was
assigned to.
My client served the county of Los Angeles
faithfully for over 30 years. He was a good officer. He was
a good Lieutenant. Maybe too good of a Lieutenant.
We all recognize how much the structure of the
Sheriff's Department might have needed to change, but I'm
asking this Court not to have my client bear the burden of
all the change that should have come forward long before this
situation ever arose.
My client has the right to be viewed as an
individual who has endeavored and perhaps crossed a line.
The variances that we requested in our moving papers, sir,
seem to be established by the Supreme Court in the Koon case

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addressing the fact that if the -- when the Court sentences
police officers to jail, that there should be some
dispensation or consideration given to that fact.
And also in light of the argument that was
addressed also in Koon, the fact that that particular event
didn't start out to be a crime, evolved into one, we would
venture to say to this Court on the 8th of August, when they
located that cell phone -- that was the start of the
evolution into what occurred and evolved from a legitimate
investigation into something that the jury has found and this
Court has found that they had no permissible right to
conduct.
We can argue the parameters of what a Sheriff's
Department may or may not be able to do inside of its jail.
I've often thought about what the circumstances might be or
what -- how it could be different if that had been a Glock, a
Smith & Wesson -- some kind of item inserted into the jail on
the theory that it would be sufficiently beneficial for an
investigation.
Now, we've heard some testimony -- and we can
discount it all we want -- as to the nature of the
dangerousness of a cell phone in a lockup facility; but I
implore this Court to consider the service that my client has
given to this county, to consider the type of individual that
he's been prior to August 18, 2011, and the fact that where

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he will be sent upon this Court's sentencing will have some
significant impact on him far more than myself or anybody
else in the courtroom.
We need to take into consideration that he is an
officer that will be confined. We're not arguing that that's
not an impermissible sentence in this case, but we ask the
Court to consider the crime and not the circumstances.
By that I mean this was an endeavor. This was an
argument from the very beginning by the Government. There
was no actual -- they didn't really impede, they just got in
our way a little bit, and we stepped the rest of the way
through it. There was nothing actual.
But however we want to view it now and however the
facts came out, I ask this Court to use its judgment and
leniency to consider the fact that this officer has now
sacrificed everything he's now worked for the past 30 years
and will now have to face those in confinement that would
love nothing more than have that opportunity to meet an
officer face-to-face beyond bars. That's what Koon stands
for.
We'd ask that the appropriate range on that
variance, as it was found in Koon, eventually was about half.
And that was dovetailed with the consideration as to whether
or not this was an evolving offense that didn't start out
that way but became criminal as it bore on.

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Whatever the Court's considerations are in this
case, we'd ask sincerely that you consider their status and
the circumstance under which this event unfolded. On that,
sir, I would submit.
be heard?
MS. CARTER: Yes, your Honor.
Your Honor, the Government maintains that its
requested sentence of 48 months at the high end of the
applicable guidelines range in this case or towards the high
end is the appropriate sentence here because what we have
here is a massive abuse of trust, people doing essentially
the opposite of the job that they were entrusted to do.
And also you have a very serious offense.
Obstruction, not just of a narrow issue in a particular case
but obstruction of an FBI and grand jury investigation to
entire categories of civil rights and public corruption
abuses in the Los Angeles County jails.
The arguments that the defendant has raised about
his initial impulse to go -- to -- was to send the informant
to state prison is not sufficiently mitigating because even
looking at the evidence from August 18th, it's clear that his
goal was to take this informant out of play, separate him
from his FBI handlers.
Yes, the initial impulse was to move him to 1750

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and then to send him out to state prison, but it was not to
do the right thing. And the -- over time, yes, the planning
all evolved and got more serious, and the conspirators took
more and more drastic actions to first isolate this informant
from the handlers and then to do other things to obstruct the
investigation.
But that initial impulse to send Anthony Brown to
state prison, which lasted only a few hours, is not
sufficiently mitigating and is certainly very different from
the diminished intent situation in the Nachamie case that the
defendant cites in his papers.
In that situation the doctors that were the
supposed -- the defendants were lied to. They didn't get
into the conspiracy until they were lied to, and they relied
on those lies. It was only after -- and then later this
concept of diminished intent was when they should have known,
but they still relied on the lies.
There's nothing like that here, your Honor. This
defendant went into the conspiracy knowing of the facts as
the facts evolved, the efforts of the conspirators to
obstruct the investigation just became that much more severe.
The Government also submits that in this case the
defendant put by choice his record of service at risk and
that this was not the only situation in which he may have
done so. And the Government has put before your Honor two

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other situations in which it believes that this defendant was
not doing the right thing.
First it submitted what was marked at trial as
Government's Exhibits 89 and -- 189 and 190 that relate to an
incident where he was receiving information about an
investigation into his -- a family member.
And then also the information that the Government
submitted in its declaration regarding paragraphs 80 and 81
in the PSR where this defendant tipped off another
Los Angeles sheriff's deputy about information that his own
deputies have brought to him for investigation. And that
deputy was alleged to have committed some wrongdoing himself
admitted that he had been shown a report by Defendant
Thompson.
With regard to the Koon decision, the Government
submits that that decision does not stand for the proposition
that police officers who commit crimes should receive lesser
sentences. That case was related to a very specific set of
facts in its decision. It talks about a unique combination
of factors present in that case which the trial court was
relying on, not just the defendant's status as police
officers.
And the Government would submit that under the
guidelines as it should be, police officers' status is not
generally mitigating. It's generally aggravating because it

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demonstrates an abuse of the public trust.
For all of those reasons, your Honor, the
Government submits that its 48-month sentence is in fact the
appropriate one. A probationary sentence would not account
for the serious abuse of public trust in this case nor the
grave danger that was presented by this broad-based
obstruction until entire categories of abuses within the Los
Angeles County jails.
THE COURT: Is the Government aware of whether
there are any victims who wish to address the Court?
MS. CARTER: There are not, your Honor.
THE COURT: Does the defendant wish to be heard?
MR. McDERMOTT: No, sir, not at this time.
THE COURT: Does counsel for Mr. Leavins wish to be
heard?
Your Honor, I would show the Government the photos
that I'll be displaying.
Your Honor, Mr. Leavins is a lifelong resident of
Los Angeles, a loyal father, a recently married person who
dedicated almost 30 years of service to the Los Angeles
Sheriff's Department.
I know the Court has read the papers that I filed,
so I won't detail everything. But I would ask the Court to
focus on the individual that gave a lifetime of service, the

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individual that the Court has heard from and has gone through
various levels of the Sheriff's Department receiving what is
outlined in our position paper, awards, accommodations, of
excellent service throughout that time.
I would ask the Court to look at this in its
entirety and not to just examine the two months that this
offense is focused on.
I would also ask the Court to focus on the letters
that were received or submitted that described Mr. Leavins as
a consummate professional, the epitome of what anybody would
want out of a law enforcement officer, a person with a strong
morale compass -- fine, morale and ethical character.
These are the individuals that know Mr. Leavins. I
would also ask the Court to -- and I -- and I say this with
respect to the jury's decision, but I would ask the Court to
really look at the decision making of Mr. Leavins in context
in determining what is a fair sentence.
And in the context of this situation,
Lieutenant Leavins was receiving orders from his superiors.
And I know the Court has read the -- the letters from
Sheriff Baca that I've -- that I've mentioned, but I think
these are important considerations that need to be
considered:
The fact that Lieutenant Leavins would be
considered -- or the behavior of disobeying these orders

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would be considered insubordination.
And during this time, while the jury did not hear
from people like Mr. Yoshinaga, I think the Court should also
consider that Lieutenant Leavins was acting in good faith to
protect Mr. Brown, to let others know what he was doing and
to conduct his affairs legally.
Your Honor, a term of imprisonment in this case is,
as outlined in the papers, I believe is inappropriate. For
the Court has the power to decide, and I'd ask the Court to
consider all of the factors including Mr. Leavins' medical
history, his service to the Los Angeles Sheriff's Department
and the fact that this case, while the jury did find
obstruction, there were no -- there was no benefit to
Mr. Leavins. He was on his way to retire.
This was a new situation for the Los Angeles
Sheriff's Department, a situation that they had not
encountered in the past where the FBI had introduced a cell
phone into the jail.
There was imperfect knowledge that the FBI or the
U.S. Attorney's Office -- Lieutenant Leavins didn't know
about the full investigation that was going on and didn't
know the -- the -- fully what others may have been thinking
or the others' motives during the time.
That there was a legal confusion, meaning that
there was a confusion over the law in that this idea of the

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supremacy clause and what was -- what others could do or what
he could do and couldn't do was a difficult circumstance.
In the end, your Honor, I'd ask the Court to, as
well consider as not an excuse but as an explanation of
Mr. Leavins' goals in the situation to keep Mr. Brown safe is
that Mr. Brown actually was safe under what appeared to be a
dangerous situation to Mr. Brown.
THE COURT: Counsel, what did keeping Mr. Brown
safe have to do with approaching an FBI agent at their home?
MR. JOHNSON: Your Honor --
THE COURT: I can answer that for you. Absolutely
nothing.
MR. JOHNSON: -- I'm not simply -- I'm not making
excuses, your Honor. It's just by way of explanation. And
while the jury has found that this is obstruction to have
approached the FBI agent at her home, Mr. Leavins did not say
anything about arresting this agent. As -- by way of
mitigation, and again not to down play the approach,
Miss Marx was not arrested, and she was not harmed. And I
don't think there was ever any intent to harm or arrest her
on behalf of Mr. Leavins.
And I'm simply asking not as an argument of finding
guilt or not guilty but in terms of mitigation, in looking at
this in context, the setting, the circumstances, in
evaluating everything, in determining the sentence, as the

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Court knows, that these are important factors.
In the end, your Honor, I believe that, again,
well, the Court is going to make the decision but the Court's
role is to impose a sentence that is no greater than
necessary to fulfill the objectives of 18 U.S.C. 3553. And
we believe that a noncustodial sentence with community
service of substantial hours of community service, will meet
the goals of sentencing and provide for just punishment in
this case. Thank you.
Does the Government wish to be heard?
MR. FOX: Yes, your Honor. Thank you.
Mr. Johnson just asked you to look at the context
of what was happening, and obviously we agree that you
should.
Mr. Leavins was the one who came up with the idea
to move Mr. Brown after he suspected that a writ would be
issued. Mr. Leavins also tampered with witnesses.
Mr. Courson and Mr. Michel he tampered with. He was there
when that tampering occurred.
And your Honor just asked Mr. Johnson what did the
approach of Special Agent Marx have to do with the safety of
Brown. Of course the -- the tampering of those two witnesses
had nothing to do with the safety of Brown. There's no
excuse for his decision to tamper with witnesses and -- and

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cause his supervisor or Sergeant -- excuse me -- to also
tamper with witnesses.
With respect to Mr. Johnson's argument that there
was any confusion over the law, take away the supremacy
clause. As I know your Honor believes as well, this is Law
Enforcement 101 that an undercover agent or a super --
actually, she's supervising an undercover operation. She
doesn't commit a crime just because there's an undercover
operation into criminal activity.
All the defendants prior to trial, during trial,
and after trial have tried to excuse their conduct because
they were following orders, and I want to point out a couple
of things there: These are law enforcement officers who we
demand and expect to exercise their own judgment. They're
expected to follow the law, enforce the law. And if they are
just saying, "Well, I did it because somebody told me to do
it," they're not doing their duty. It is not an excuse to
say, "I was just following orders."
And as your Honor is aware, based on all the
testimony that we've heard throughout the three different
trials at this point, it's not very clear what orders they're
referring to at this point.
With respect to his -- Mr. Johnson's statement that
there was no benefit to Leavins, I think that's one of the
sad parts of this case. He was bound to investigate the

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crimes that the FBI was investigating, and instead he decided
to protect his own department instead of enforcing the law as
he was supposed to do.
There was no personal benefit to him, but he
thought there was an organizable benefit, and that he was
sadly mistaken about because it had brought a lot of shame to
the department, and I'm sure the department at this point
would rather that the defendant and others had not taken the
actions that they took.
And finally with respect to whether home detention
or a period of probation is appropriate, I think the context
here is that the defendant's going to be receiving, based on
his retirement, $7,000 a month in pension based on his
retirement. He's going to be able to sit at home, collect
that money, if that's -- if that's the decision of the Court,
while he performs volunteer work on the side -- again, if
Mr. Johnson's recommendation is accepted by the Court.
That will not provide the deterrent effect to other
law enforcement officers that should know that they should
not violate the law, even if they think that their superiors
would like that to happen.
This is a case that calls for incarceration, your
Honor, and we suggest that your Honor goes with the
recommendation that we have submitted in our papers.
Thank you.

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Does Defendant Leavins wish to be heard?
THE COURT: Does Defendant Smith?
MR. GENEGO: Yes, your Honor.
Your Honor, more powerful than anything I could say
are the letters that were written on behalf of Mr. Smith, but
I do want to mention a few points.
As the Court knows, the overriding principle behind
the guidelines is one of parsimony, and that is that the
Court is to impose a sentence that is sufficient but not
greater than necessary to achieve the objectives of
sentencing.
And I think that in this case that has special
significance because of the position of Mr. Smith in the
offense.
I don't think anyone can question that there's a
need to deter him further. And I also think that given the
consequences of the trial, the publicity it had, and the
attention it's gotten within the Los Angeles County Sheriff's
Department, there is not a need for imprisonment to deter
others in a deputy position.
Anybody who is in a deputy position in the Los
Angeles County Sheriff's Department has gotten the message,
and I think the Court heard that through the trial and from

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all the attention that the case got.
As far as sufficient punishment for Mr. Smith, he's
not going to sit at home getting retirement. He lost his
career. As the letters show, what he always wanted to be a
law enforcement officer.
Now, I know the Government is going to say, "Well,
he should have then not committed the offense," but we're
accepting as given that there was a verdict in this case and
he did commit the offense. And as a consequences of that,
he's going to lose the career that he always wanted to
pursue, and he's going to be a felon.
And I think that in terms of punishment that is a
substantial punishment here for somebody who is in a deputy
position and someone like Mr. Smith.
Rehabilitation -- that's not something that plays
into a need for imprisonment here.
And then we come to his personal circumstances.
And, again, the letters are -- I think as the Court probably
can see from written -- from reading them are extraordinary.
I -- Mr. Smith is someone who his fellow officers would make
fun of because he cared about the inmates that he was
supposed to take care of.
And again I understand that we're not talking about
a situation where there's not a verdict. There is.
But the fact of the matter is that when you look at

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those letters, he was someone who cared about the people that
he was charged with taking care of, and that's in the letters
from other deputies.
And his personal circumstances -- there's a lot of
people, when they get convicted of a crime, they'll go out
and start doing good things so they can come back to the
Court and say, "Look, what a good person I am." That's not
what Mr. Smith did. For years he's been involved in
charitable projects. He has his kids serve meals at a
homeless shelter, not because he was convicted in this case,
but because that's how he wants his kids to be raised.
He spends time with his church, not because he
wants to impress the Court, because it's important to him.
Same thing with the Boy Scouts, and the same thing with his
son.
And when you take all of those things into account,
and you figure out what is sufficient but not greater than
necessary for someone in a deputy position like Mr. Smith and
the context of this case, I think that a sentence of
probation with a term of home confinement is sufficient but
not greater than necessary.
Thank you.

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And we think that it's important for your Honor to
send a message that no matter how low you are in the
department or how high you are in the department, again, you
need to be exercising judgment and your own judgment and do
the right thing, and that's not something that Mr. Smith did
from the beginning.
Mr. Smith was aware that Mr. Brown was an FBI
informant, a federal informant, before anybody else realized
that. And he went and -- you heard the statements on tape
from August 19th about how he wanted to clean his own house,
how he didn't like the fact that the FBI was over -- all over
the place. Mr. -- Mr. Smith showed a disdain for the
investigation from the very beginning.
Mr. Genego's right that there are a lot of
mitigating circumstances with regard to Mr. Smith and the
fact that Mr. Smith is one of the lowest ranking people that
we charged. We agree that your Honor should consider that,
and that's why we believe that a sentence of 28 is
appropriate.
THE COURT: Does Mr. Smith wish to be heard?
MR. GENEGO: No.
THE COURT: Does counsel for Mr. Manzo wish to be
heard?
MR. LOMBARD: Briefly, your Honor.
Your Honor, like Mr. Smith, Mr. Manzo is a deputy,

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and I join a lot of the arguments Mr. Genego made on behalf
of Mr. Smith. I think some of them apply to Mr. Manzo
regarding his role in the offense. Even though the Court has
denied the request for a mitigating role, I think the
Court -- I asked the Court to consider that under 3553(a).
The biggest difference for Mr. Manzo, amongst all
of the defendants, is his experience with the Los Angeles
County Sheriff's Department. He has been -- he was employed,
I think it was five years, I think it was, your Honor, since
the time.
And since this indictment was issued, he was
terminated with or put on leave without pay. And he won't
enjoy the years of pensions that have been earned like the
other defendants, and he's had to start over.
As the Court has read, he sold his home, moved into
his parents' garage with his wife and young child and ever
since then has been looking for jobs. And that's very
difficult, your Honor, for a man who has got to provide for
his family. His wife works as an administrative assistant
for the -- I think it's the police department of Whittier.
But, your Honor, this has huge consequences. And
if the Court will indulge me, I just recently spoke at my
son's fifth grade class on prisons and the effect of prisons,
and one of the things that we miss is the inability to
establish wealth and to grow your family and give your family

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a better chance.
And prisons have really affected that, and the
primary reason is because of the felony convictions. And the
fifth graders are saying, "We're not going to hire a felony
conviction for my job." And Mr. Manzo is in that position
where he's applied and applied and applied for positions and
been denied because he tells them about his situation.
And here he is living in a garage of his parents'
garage, and he has to start over. And it's never going to be
the same track that he had. He'll never have that
opportunity that he squandered. And certainly, your Honor,
there's -- there's reasons and the Government's going to get
up and talk about that.
And -- and I will tell you his loyalty was
misplaced. Absolutely. He was an eager -- the letters will
show you he wanted to be a cop. He was a baseball player,
then wanted to be a teacher or a coach, and then found law
enforcement and was happy, very happy for five years. And
that's gone. And he can't even take the jobs being a teacher
now because of his record.
His loyalty was misplaced, and he recognizes that,
and he'll pay the price for the rest of his life for that,
your Honor.
And so I do think that Mr. Manzo -- he is a very
good person. As you can tell by the letters, and the family

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that -- how he was raised. And the question of loyalty will
also resonate with him in the decisions he made, the people
he decided to follow, and he was an eager deputy to please
and to work hard and be accepted.
So, your Honor, I do think that a sentence of home
confinement or halfway house that will allow him to help
provide for his family to get back on his feet is appropriate
and not greater than necessary in this case.
With that I would submit.
be heard?
MS. RHODES: Briefly, your Honor.
The defendant in this case, Mickey Manzo, was the
closest to the line and the thing that the FBI was
investigating, which was abuse in the jails.
So it was certainly within his view that he could
have seen and probably did see what was going on in the jails
on the line, and that was exactly what the FBI was
investigating and exactly the investigation that he was a
part of obstructing.
Moreover, the Government in its papers has
indicated that his conduct, not just charged conduct but
other conduct, far extended or extended far after the
approach of Special Agent Marx. And that is into December
when he was warning his then Lieutenant Thompson about

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actions that could be taken or investigations about
Lieutenant Thompson's son.
It is true his loyalty was misplaced, but he placed
that loyalty over duty, and he placed friendship and/or a
misguided sense of what should be done over justice.
And for those reasons the Government believes that
his conduct, which extended over many months, and his role in
this offense should be taken into account. And he should
receive the 30 months that the Government is requesting.
THE COURT: Does Mr. Manzo wish to be heard?
THE COURT: Does counsel for Mr. Craig wish to be
heard?
First of all, I want to mention briefly the Koon
variance factors. It is more than peace officer status. It
includes publicity, which we have had in this case. This
will be on all the TV channels, the news, the front page of
the Times. It has been for months.
But also it's connected to the abuse of prisoners.
Whenever you read about this case, if you don't really
understand what's happening, you and those readers and those
watchers connect these defendants with the abuses that do
occur in jails and prisons.
And so like the Koon case where there was an abuse

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of a prisoner, these defendants are also tainted by that
publicity and by their status.
One thing that has always come to my mind in this
occasion is at least for most of these defendants and for
Mr. Craig in particular, is the randomness of how he got
involved. At his unit they're all Sergeants. It's a large
unit. He happened to be the one chosen that day to, 16 days
after the phone was found, to investigate how the phone got
into the jail. It could have been somebody else, but the
randomness of that choice fell upon him.
Now, it wasn't, "I hope I get a case today where I
can obstruct a federal investigation." This case is
unprecedented. There are no cases like it -- nothing in the
literature across the nation, state, federal, anywhere. And
because it's unprecedented, it's going to be written about.
It's going to be discussed. It's going to be analyzed.
The template of how the Los Angeles Sheriff's
Department responded to an FBI investigation into their
agency will not be followed. It will be just the opposite.
When a federal investigation is conducted by an
agency into another law enforcement agency, state, or local,
the management and officers in question because of this case
will know how to respond appropriately.
The deterrence is already there because, if you
respond as the Los Angeles Sheriff's Department did in this

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case, you're going to be charged and you're going to be
convicted of a felony. You're going to lose your job. That
is the deterrence. That's sufficient because of this case.
And publicity -- that won't be sent out to the
general media, but there is going to be publicity and
discussions and articles written for law enforcement managers
because of this case.
The -- I mention deterrence because that's one of
the four factors this Court has to decide. The deterrence
does not necessarily have to be a prison sentence. Nobody --
another factor, protect the public from further crimes. No
defendant -- my client, Craig Smith -- is going to commit
another crime.
These people were all of good character. All of
exceptional character. And the other factor whether they
need care or treatment, education, medical assistance, that
doesn't apply in this case. It's -- it's what is the just
punishment, and it's our submission that a just punishment in
this case, punishment that's not greater than necessary for
these four factors is home confinement, community service, a
probation or mixed sentence. That is sufficient for this
case.
Can I be of any further assistance to this Court?
THE COURT: No, thank you.

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MS. RHODES: Yes, your Honor.
The Government's position is that while it could
have been anyone who got assigned to this case, it was Scott
Craig. And it was Scott Craig, therefore, who tampered with
Anthony Brown as a witness, who tampered with Gilbert Michel
and Deputy Courson who actually approached Special Agent Leah
Marx and who was there -- then thereafter on the phone with
his partner and the officer he was training Sergeant Long,
when Supervisory Special Agent Narro called. And he was
certainly there supporting and supervising Sergeant Long.
So the Government requests that the Court look at
the facts not of what could have been but what actually was
and what this defendant did and therefore what is just
punishment for what he did.
Additionally Mr. Rabe talked about the fact that
this case is unprecedented. It may well be that it is
unprecedented because the behavior of this defendant as well
as the others was so egregious that it has never been even
considered by others before.
And so notwithstanding your Honor's decision with
regard to whether his testimony fits the Dunnigan factors,
the Government believes that his character both on and off
the stand both during the commission of the crime and in the
courtroom merits the sentence recommended by the Government
which is 51 months.

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THE COURT: Does Mr. Craig wish to be heard?
MR. RABE: Your Honor, no.
THE COURT: Does counsel for Ms. Long wish to be
heard?
MR. NAVARRO: Yes, your Honor. Thank you.
Good morning, your Honor.
Your Honor, I've been before you and many other
judges on many, many federal cases over my years here, and I
know what happens at sentencing. People come before you
convicted of numbers of crimes. Sometimes there's
limitations on what you can do in terms of a sentence because
of narcotics offenses most of the time, but many times we
have first time offenders who come before you.
It could be a postal worker, a bank teller. It
could be a judge. It could be a lawyer. It could be a
doctor. It could be a police officer.
And in our system of justice, at least I believe in
giving people an opportunity to rehabilitate themselves if
it's available.
And in this case, your Honor, it is available. You
don't have to send my client to jail. We know that. There
is no mandatory minimum. She's not engaged in any RICO
conduct, any of those kind of cases we see in these courts on
a regular basis.
We have someone who has devoted her entire adult

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life to work and do the right thing, and her work took her to
law enforcement. She became with the DEA in 1996. She
joined the Sheriff's Department in 1990 first as a clerk,
became a deputy in '95, I believe.
During her 23 years in law enforcement, she's done
work for federal Task Forces in this case. Probably been in
this building. May have talked to AUSA's along the way.
And one thing that are clear to me, your Honor, and
is clear from the 20 letters we submitted, there was some
from law enforcement and some from regular folks as well. My
client has always been a person with integrity, and she's
been committed to doing the right thing. She's been
convicted in this case, and I understand I have to respect
the judge -- the jury's decision in this case. But that
should not take away, your Honor, from the fact that you have
someone who is truly a first-time offender, under our
guidelines for sentencing.
And I believe person of that -- of that nature,
someone who is really the first time before a judge deserves
an opportunity. That's -- that's the way we are raised.
When the child makes a mistake in school, they might go to
the principal's office, and you give them an opportunity to
rehabilitate themselves. It happens all the time.
I'm not asking you to reinvent the wheel. I'm not
asking you to do something that is so crazy or out of the

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ordinary. I'm asking you to take a look at my client and
look at the work she's done in her life, not just the month
or two months that she's been involved in this case. But
look at her entire life.
And my mom -- my mom always used to tell me, your
Honor, that I can tell a lot about you by where you've been.
And I think that's applicable to my client. We can tell a
lot about her by what she's been doing over her many years in
law enforcement.
She's worked in the community. She's painted a --
she's cleaned up graffiti. She's worked with teenage girls.
She's done everything she can to do the right thing, and she
stands convicted before you, which if we could go back in
time and if she were to have come to me when this happens,
who knows.
But we don't have that, your Honor. We have a
person who deserves an opportunity. In this Court here we
have finally some programs which are available for first-time
offenders, such as CASA 1 and CASA 2, which the Court is very
familiar with.
My client doesn't qualify for those problems
because she doesn't have a drug problem. She's not a single
mother. And those are -- those are good things. She has
grown up locally here, went to school here, and has
exceptional work over her lifetime not because she wanted to

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at some point get you know letters of recommendation, because
it was the right thing to do.
Your Honor, she always -- she always felt it was
her duty as a police officer to go above and beyond just
being a police officer.
As a woman of color, as a Latina, she took that
very seriously. She -- and I think it was reflected in a
number of letters that she was a role model to many other
Latina's. And now she's convicted felon. She'll never be
able to work in law enforcement. Her future is
financially -- it's going to be very difficult, but I don't
think you have to send her to jail for one day.
You don't have to -- you don't have to deter her in
any way. You'll never see her again. If you gave her -- if
you gave her the opportunity, as you've done in the past with
other clients of mine, to do the right thing. And I think
she'll do that.
And she'll -- she'll -- she's gotten the message,
and I think the message has been loud and clear.
Now, a lot has been said about my client
obstructing, you know, Government witnesses. I received a
letter 10 days ago or so from Anthony Brown. He's at M.D.C.
He wanted to see me. He felt abandoned by the FBI, and it
was shocking to me that after all this Mr. Brown wrote to me
and wanted me -- he -- and I'll see him. I'm going to see

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him because he asked me to see him.
Again, that is what it is, your Honor, but we take
our cases as they come. We know that.
But you have someone before you who has spent a
lifetime of doing good things, and I don't want you to ignore
that.
We submitted every one of those letters. And if I
submitted just one of them, it would have been enough to be
honest. And in every letter that I received, I never told
any of those people what to say. I never do that. I want to
hear from them. I want to hear what they have to say.
And it was clear to me that we have some -- that we
have an individual here -- we have a person who over her
entire life will do the right thing. And I don't think you
have to send a message to other deputies, Sergeants, or her.
She doesn't have to be an example to be put into custody. I
don't think it's really warranted under the 3553 factors,
your Honor. And I will submit, your Honor.
Does the Government wish to be heard.
MS. CARTER: Yes, your Honor.
The Government maintains that its recommended
sentence of 30 months at the midpoint of the guideline range
is the appropriate sentence here and that a probationary
sentence is willfully insufficient to account for the goals

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of sentencing.
Here today you heard the same theme echoed
throughout the defendant's papers that she is a person who
does the right thing, who is not a criminal.
But in this case, she did exactly the opposite of
what she was entrusted to do. She is not a child who in
front of her mother made a mistake. She's a 23-year law
enforcement veteran who at the time of this offense was
entrusted with the very serious public trust of investigating
crimes and being in a position to be involved in the
deprivation of someone else's liberty. She knew exactly what
would happen, and she committed a crime.
But instead of fulfilling her public trust, she did
the opposite, and there's no excuse for that. There's no
misapprehension in which she could have been under that would
have justified a person entrusted with investigating crimes
by deputy obstruction -- obstructing an investigation into
crimes by deputies.
And, your Honor, in the Government's view one thing
in this case really exemplifies the problem, really
exemplifies the gravity of her conduct and also the gravity
of the suggestions in her papers now that there was nothing
wrong, the lack of appreciation for the seriousness of her
crimes, and that was her comment to the FBI soon after the
FBI supervisors hung up the phone. "They're scared" and then

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laughing.
There's no world in which that was something that
she thought she should have been doing, that that was in
furtherance of any kind of legitimate investigation. She
knew exactly what she was doing. She knew that it was
exactly the opposite of what she was entrusted to be doing.
And the custodial sentence that the Government
recommends in this case is the appropriate one. The
Government further submits that it does account for the
mitigating circumstances here including her lack of prior
criminal history.
THE COURT: Okay. Thank you.
Does the defendant wish to be heard?
MR. NAVARRO: No, your Honor. Thank you.
THE COURT: All right. I'll turn to the
calculation of the advisory guidelines.
As to Mr. Thompson, the Court adopts the factual
findings, the guideline application set forth in the
Presentence Report, finds that the advisory guidelines
establish a total offense level of 22, a criminal history
category of one, which results some in an advisory sentencing
guideline range of 41 to 51 months of incarceration.
The Court recognizes its discretion to depart in
this case based on the various factors cited by the defendant
either individually or in combination. However, the Court

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elects not to exercise its discretion and depart in this
case.
As to Defendant Leavins, the Court adopts the
factual findings in the guideline application set forth in
the Presentence Report, finds that the advisory guidelines
category of one, which results in an advisory sentencing
this case based on the various factors cited by Mr. Leavins
elects not to exercise its discretion and depart.
As to Defendant Smith, the Court adopts the factual
findings in the guideline application set forth in the
As to Mr. Smith, the Court recognizes its
discretion to depart based on various factors cited by the
defendant either individually or in combination. However,
the Court elects not to exercise its discretion and depart.
As to Defendant Manzo, the Court adopts the factual

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this case based on various factors cited by Defendant Manzo
As to Defendant Craig, the Court adopts the factual
findings and the guideline application set forth in the
this case based on various factors cited by the defendant
As to Defendant Long, the Court adopts the factual
this case based on various factors cited by the defendant

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Does either counsel on behalf of Mr. Thompson wish
to be heard on the mathematical calculation of the
guidelines?
MR. McDERMOTT: No, sir.
the mathematical calculation of the guidelines as to
Mr. Thompson?
MS. CARTER: No, your Honor.
THE COURT: As to Defendant Leavins, does
counsel -- does either counsel wish to be heard on the
mathematical calculation of the guidelines?
THE COURT: As to Mr. Smith, does either counsel
wish to be heard on the mathematical calculation of the
guidelines?
MR. GENEGO: No.
THE COURT: And as to Mr. Manzo, does either
counsel wish to be heard on the mathematical calculation of
the guidelines?
MR. LOMBARD: No.
MS. RHODES: No, your Honor.

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THE COURT: And as to Mr. Craig, does either
the guidelines?
MR. RABE: No.
THE COURT: And as to Mrs. Long, does either
the guidelines?
THE COURT: All right. We're going do take a short
recess. Let's take 10 minutes, and then I'll be back out,
and we'll pronounce sentence as to each.
THE CLERK: All rise.
(Whereupon, from 11:05 a.m. to 11:15 a.m., a break
was taken.)
This Court is again in session.
You may be seated.
THE COURT: All right. I have some comments about
the nature and circumstances of this offense that I think
will apply to all the defendants. And after making these
comments, then we'll sentence -- we'll have each of the
defendants and their counsel go to the lectern, and we'll
complete the sentencing.

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Standing before me today are six sworn peace
officers who took an oath to uphold the law and to support
and defend the Constitution, to serve the public. Like
thousands of other sworn and civilian employees of the Los
Angeles County Sheriff's Department, these six defendants
have devoted their careers to the department.
Mr. Thompson spent more than 30 years with the
Sheriff's Department.
Defendant Leavins, nearly 30 years.
Defendant Smith, almost 20 years.
Mr. Manzo, almost eight years.
Mr. Craig, over 25 years.
And Mrs. Long, over 23 years.
The Court has no doubt that the vast majority of
those that devoted their lives to the defendant are dedicated
public servants. They've sworn an oath to protect our
community, and they take their enormous responsibilities very
seriously.
They face danger every day. They keep us safe.
They serve with honor.
At trial, however, we heard testimony about
significant problems within the Sheriff's Department. We
heard about corrupt deputies. We heard about the abuse of
inmates. We heard testimony that from their first days at
the academy, deputies were instructed about an "us" versus

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"them" mentality and unwritten codes that taught deputies
that, when an inmate in the county jails dared to even
attempt to harm a deputy, the deputies were told to respond
with enough violence to send that inmate to the hospital.
Deputies were taught how to cover up the abuses
committed by their fellow deputies, how to look the other
way, how to shield the department from embarrassment.
Although none of these six defendants are accused
of beating inmates or taking bribes to provide inmates with
contraband, they all took actions calculated to shield those
dirty deputies from the consequences of their crimes. These
defendants fostered the corrupt culture within the Sheriff's
Department.
They conspired with each other to hide an inmate
who was cooperating with the FBI. They interviewed this
witness not with any desire to pursue a case against the
corrupt deputy who had accepted a bribe but to find out what
the FBI knew and to get the informant to stop cooperating
with the federal investigation.
They interviewed the deputy who had accepted the
bribe. Again, their goal was not to build a case against the
deputy but to convince him not to cooperate with the FBI, not
to turn on the department and provide evidence against other
deputies.
These defendants conducted surveillance on an FBI

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agent that they knew was part of an authorized and legitimate
federal investigation into abuses committed by their fellow
deputies. They confronted her outside her home and
threatened to arrest her despite not having probable cause.
They did this to scare and intimidate the FBI.
They did all those things to derail the federal
investigation. They intended to obstruct justice.
Each of these defendants had a choice between right
and wrong, and they chose to join the side of wrong, not
everybody in the department joined them.
The Court heard testimony about a deputy who worked
in the IRC who refused to go along with the defendants'
scheme. When asked to violate the department policies, she
said no. When told that the Undersheriff had authorized it,
she still said no. She knew right from wrong and chose
right.
None of you showed that sort of courage. Instead
you all endeavored to obstruct justice in a misguided attempt
to protect the Los Angeles County Sheriff's Department.
Despite being law enforcement officers sworn to
uphold the law, each of you broke the law. In doing so, you
broke the vow you made to protect the public, to serve the
community.
You don't serve the public by using your position
to conceal wrongdoing in the jails. You don't serve the

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public by hiding witnesses. You don't serve the public by
tampering with witnesses, and you don't serve the public by
threatening to arrest a FBI agent in some misguided effort to
get her to reveal the details of her investigation.
Perhaps it's a symptom of corrupt culture within
the Sheriff's Department, but one of the most striking things
aside from the brazenness of threatening to arrest an FBI
agent for a crime of simply doing her job and videotaping
yourselves doing it, is that none of you have shown even the
slightest remorse. You've all defended your actions by
claiming that you were merely following orders, but this does
not absolve you of responsibility.
At trial the only evidence of orders you received
from those above you in the chain of command were to keep
Anthony Brown safe and to investigate the smuggling of the
cell phone into the jail.
There was no evidence of the trial that any of you
were ordered to keep Brown safe in a way that hid him from
the FBI and the federal grand jury. There was no evidence at
trial that any of you were ordered to tamper with Brown or
Deputy Michel.
Instead the only evidence is that you chose to
encourage both of them to stop cooperating with the federal
investigation, not to further your -- your investigation, but
to stop the federal investigation.

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And there was no evidence at trial that you were
ordered to confront an FBI agent at her home and threaten to
arrest her. You did that.
Your unquestioning loyalty to the Sheriff's
Department is not something to be proud of when that loyalty
is perverted to protect corrupt deputies and the inflated
reputations of those in command.
Your actions have not only embarrassed the
Sheriff's Department but every man and woman that puts on
that badge every day and puts their lives on the line. Your
actions have violated the trust put on you by the community.
None of you showed the courage to do what was right, to risk
the scorn of your fellow deputies by exposing their crimes.
In sentencing you today, the Court is mindful that
among the factors that the Court must consider are to promote
respect for the law and to afford adequate deterrence to
criminal conduct.
The Court hopes that if and when other deputies are
faced with decisions similar to those you face, they will
remember what happened here today. They will not look the
other way or obstruct an investigation; that they will
recognize that blind obedience to a corrupt culture has
serious consequences, that they will enforce the law rather
than conspire to commit crimes, that they will do what is
right rather than what is easy.

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The guidelines have taken into account the nature
of this offense, the defendants' lack of criminal history,
their breach of the public trust, the alteration and
fabrication of records, of documents, and some of the
defendants' aggravating roles as a organizer or leader of
criminal activity.
What the guidelines have not captured is the
irreparable harm to the public. The public expects that
police officers will not violate the laws that they are
charged with enforcing.
It destroys the very fabric of our system of
justice and erodes a cornerstone that the rule of law applies
to everyone equally, that no person, whether he wears a badge
or not, is above the law.
And while I have very little doubt that any of you
will re-offend, probably more disturbing is the fact that you
refuse to accept responsibility for any of your conduct.
Your refusal to accept responsibility stands in sharp
contrast to the professed tenets expressed in many of the
letters that were received by the Court.
All right. I'll turn to each individual defendant
as I assess additional factors under 3553.
If Mr. Thompson and his counsel will approach the
lectern, please.
I've considered the kinds of sentences available

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for this defendant. The Government seeks a sentence of
48 months while the defense seeks a probationary sentence.
In aggravation this defendant assumed a leadership role in
hiding an inmate that was cooperating with the grand jury,
looking into abuses within the jails. He was involved in
instituting new policies that would make it more difficult
for the federal government to investigate abusive deputies.
He used Sheriff's Department's personnel and to carry out
that obstruction. The defendant abused the substantial
authority that he was given.
In mitigation, I've considered the history and
characteristics of the defendant, those factors weigh in his
favor. Until these events this defendant was a decorated law
enforcement officer who had served the people of the county
of Los Angeles faithfully.
He has a loving and devoted family and the support
of many in the community. The Court has received numerous
letters from his family and friends attesting to his good
character, his dedication to his family to his community, and
his many acts of public service.
Having considered the advisory guidelines, which is
only one of many factors the Court has considered, the Court
also recognizes that it has discretion to vary from the
guidelines so long as it acts reasonably in exercising that
discretion.

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The Court finds that the defense arguments for a
variance are persuasive and incorporates those into the
sentence that I'm going to impose, which is outside the
guidelines.
Under the circumstances, the Court finds that a
sentence of 37 months of imprisonment followed by a one-year
term of supervised release, a fine of $7,500, and a $200
special assessment reflects the seriousness of the offense,
provides for a just punishment, will deter others from
engaging in similar conduct, and is sufficient but not
greater than necessary to comply with the statutory goals of
sentencing.
Does either party have any objections that were not
previously addressed?
MR. McDERMOTT: Not by defense, sir.
THE COURT: Is there any legal reason why sentence
should not now be imposed?
MR. McDERMOTT: No, sir.
THE COURT: It is ordered that the defendant shall
pay the United States a special assessment of $200, which is
due immediately. Any unpaid balance shall be due during the
period of imprisonment at a rate of not less than $25 per
quarter and pursuant to the Bureau of Prisons' inmate
financial responsibility program.

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It is ordered that the defendant shall pay to the
United States a total fine of $7,500 consisting of the
following: On Count On, a fine of $3,750; and Count Two a
fine of $3,750. The total fine shall bear interest as
provided for by law. The fine shall be paid in full
immediately. The defendant shall comply with General Order
01-05.
Pursuant to the Sentencing Reform Act, it is the
judgment of the Court that the defendant is hereby committed
on Counts One and Two of the indictment to the custody of the
Bureau of Prisons for a term of 37 months. This term
consists of 37 months on each of Count One and Two of the
indictment to be served concurrently.
Upon release of imprisonment, the defendant shall
be placed on supervised release for a term of one year. This
term consists of one year on each of Count One and Two of the
indictment, all such terms to run concurrently under the
following terms and conditions:
The defendant shall comply with the rules and
regulations of the United States Probation Office, General
Order 05-02 and General Order 01-05 including the three
special conditions delineated in General Order 01-05.
During the period of community supervision, the
defendant shall pay the special assessment and fine in
accordance with the judgments orders pertaining to such

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payment.
The defendant shall cooperate in the collection of
a DNA sample.
The defendant shall apply monies received from
income tax refunds, lottery winnings, inheritances, judgments
and any anticipated or unexpected financial gains to any
outstanding court ordered financial obligation.
The drug-testing condition mandated by statute is
suspended based upon the Court's determination that the
defendant poses a low risk of future substance abuse.
Sir, you have the right of appeal from the judgment
and sentence within 14 days from today's date. The failure
to appeal within that 14-day period will constitute a waiver
of your right to appeal.
You are also advised that you are entitled to the
assistance of counsel in taking an appeal. And if you're
unable to afford a lawyer, one will be provided to you.
If you're unable to afford filing time fee, the
clerk of the Court will be directed to accept the notice of
appeal without such a fee.
Does the defendant wish to have a self-surrender
date?
MR. McDERMOTT: Yes, sir, please.
THE COURT: Any objection to the defendant
self-surrendering?

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THE COURT: What date would the defendant like?
MR. McDERMOTT: Sir, with the -- we would like to
make it consistent with designation by the Bureau of Prisons.
If at all possible, we would like to have him turn into where
the Bureau of Prisons dictates that he should be housed as
opposed to perhaps turning himself here at the Marshal's
Office. I would ask the Court for 65 days.
THE COURT: Any objection?
THE COURT: How is December 5th?
MR. McDERMOTT: Could I indulge the Court and the
Government. Can I ask for 20 more days and make it until the
2nd of January and have the holidays? Could we ask for 2
January, sir?
MS. CARTER: The Government does not object.
MR. McDERMOTT: Thank you.
THE COURT: Sorry, January 2nd?
MR. McDERMOTT: January 2nd.
THE COURT: All right. The Court finds by clear
and convincing evidence that the defendant is not likely to
flee or pose a danger to any person or community.
It is ordered that the defendant shall surrender
himself to the institution designated by the Bureau of
Prisons on or before noon on January 2nd, 2015.

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In the absence of such a designation, the defendant
shall report on or before that date and time to the United
States Marshal's Office located in the Roybal federal
building.
What's the bond in this case?
MR. McDERMOTT: It was a $10,000 signature.
THE COURT: All right. Your bond will remain in
effect. If you violate any of the conditions of your bond,
that could result in your immediate incarceration. And the
defendant's bond will be exonerated upon his self-surrender.
Is that clear.
DEFENDANT THOMPSON: Yes, it is. Thank you very
much.
THE COURT: All right. Thank you very much.
DEFENDANT THOMPSON: Thank you, your Honor.
MR. McDERMOTT: Thank you, your Honor.
THE COURT: All right. If Defendant Leavins would
approach the lectern with counsel.
MR. JOHNSON: (Complied.)
THE COURT: The Court has considered the kinds of
sentences available. The Government is seeking a 60-month
term of imprisonment while the defendant seeks a probationary
sentence.
In aggravation the evidence showed that this
defendant was involved in all aspects of the obstruction. He

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was involved in hiding witnesses, tampering with witnesses,
and ordering Craig and Long to confront Agent Marx.
The defendant abused the substantial authority he
was given, and while the Court didn't find that the defendant
perjured himself at trial, the Court finds that his testimony
was highly suspect. The defendant's conduct showed that he
believed that he was above the law.
I have considered the history and characteristics
of the defendant, and again those factors weigh in his favor.
Until these events, this defendant too was a
decorated law enforcement officer who served the people of
the county of Los Angeles with distinction. He has a devoted
family and support of many in his community.
The Court has received numerous letters from the
defendant's family and friends attesting to his character and
integrity, his complete dedication to his family and his
community, and his many acts of public service.
This defendant was charged with the responsibility
of uncovering abuse and corruptions in the jail, and instead
he used his position to obstruct the investigation into the
wrongdoing by deputies.
Having considered the -- the Court has considered
the advisory guidelines as well as the statutory sentencing
factors, the Court recognizes that it has discretion to vary
from those guidelines so long as the Court acts reasonably in

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exercising that discretion.
variance are persuasive, and accordingly those arguments are
incorporated into the Court's sentence in this case.
term of supervised release, no fine, and a $200 special
assessment reflects the seriousness of the offense, provides
for a just punishment, will promote deterrence, and is
sufficient but not greater than necessary to comply with the
statutory goals of sentencing.
Does either counsel have any objections that were
not previously addressed?
MR. RAYNOR: No, your Honor.
THE COURT: Any reason why sentence should not now
be imposed?

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Pursuant to Section 5(a)1.2, all fines are waived
as the Court finds that the defendant has established that
he's unable to pay and is not likely to become able to pay
any fine.
judgment of the Court that the defendant is committed to the
custody of the Bureau of Prisons for a term of 41 months.
This term consists of 41 months on each of Counts One and
Three to be served concurrently.
term consists of one year on each of Counts One and Three,
all such terms to run concurrently under the following terms
and conditions:
regulations of the United States Probation Office and General
Order 05-02.
During the period of community supervision the
defendant shall pay the special assessment in accordance with
the judgment's orders pertaining to such payment.
a DNA sample.
suspended based on the Court's determination that the

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to appeal within that 14-day period will constitute waiver of
your right to appeal.
You are also advised that you're entitled to the
unable to afford a lawyer, one will be provided to you. If
you're unable to afford the filing fee, the clerk of the
Court will be directed to accept the notice of appeal without
such a fee.
date?
MR. JOHNSON: Yes, your Honor. January 2nd would
be fine.
MR. FOX: That's fine, your Honor.
May I ask you though, you mentioned that you found
the defendant's arguments for a variance persuasive, and it
appears that you incorporated the reasoning to have -- to
sentence him to a low-end sentence of the guidelines.
I just want to make sure that that was your intent
because I had the guidelines, as you calculated them, at 41
to 51.
THE COURT: No. What I did was I provided the
defendant with a variance, and ordinarily I would have
sentenced him. Without that variance he would have received

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a sentence in excess of 41 months.
MR. FOX: Thank you, your Honor.
flee or pose a danger to any person or the community.
Prisons on or before noon on January 2nd, 2015. In the
absence of such a designation, the defendant shall report on
or before that date and time to the United States Marshal's
Office located in the Roybal federal building.
Your conditions of bond will remain in effect prior
to yourself surrender. If you violate any of those
conditions, that could result in your immediate
incarceration.
Is that clear?
DEFENDANT LEAVINS: Yes.
THE COURT: And the defendant's bond will be
exonerated upon his self-surrender.
Is there anything else?
MR. RAYNOR: Your Honor, Mr. Leavins would ask the
Court to make a recommendation for a designation in the
Central District to serve the sentence.
THE COURT: I'll make that recommendation.
MR. RAYNOR: Thank you.

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THE COURT: Anything else?
All right. I've considered the history and
characteristics of Defendant Smith. These factors weigh in
his favor.
He was a deputy sheriff for nearly 20 years. He
has a loving and devoted family and the support of many in
his community. The Court has received numerous letters from
his family and friends attesting to his character. He has
complete dedication to his family and to his community and
his many acts of public service.
I've considered the kinds of sentences available.
The Government seeks a 28-month term of imprisonment while
the defendant seeks a probationary sentence. To impose a
probationary sentence as urged by the defendant in this
occasion under the circumstances would trivialize the
seriousness of the offense, the need for a just punishment,
the need to promote respect for the law, to promote
deterrence, and to avoid sentencing disparities.
However, the Court recognizes that it has
discretion to vary from the guidelines in this case provided
it does so reasonably.

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variance are persuasive and accordingly incorporates those
arguments into its sentence in this case.
And I'll just say in this case -- in this case the
defendant, probably more than anyone else, knew of the
implications because he had worked in the jails for so long.
He knew the implications of obstructing this investigation
into the abuses within the jail.
So under the circumstances the Court finds that a
assessment reflects the seriousness of the offense provides
for a just punishment, promotes deterrence and is sufficient
but not greater than necessary to comply with the statutory
goals of sentencing.
THE COURT: Any legal reason why sentence should
not be imposed at this time?
MR. GENEGO: No.

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All fines are waived as it is found that such a
sanction would place an undue burden on the defendant's
dependents.
on Count One and Two of the indictment to the custody of the
Bureau of Prisons for a term of 21 months. This term
consists of 21 months on each of Count One and Two to be
served concurrently.
term consists of one year on each of Counts One and Two, all
such terms to run concurrently under the following terms and
conditions:
Order 05-02.
a DNA sample.

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And the drug-testing condition mandated by statute
is suspended based on the Court's determination that the
and sentence within 14 days from today's date. Failure to
appeal within that 14-day period will constitute a waiver of
such a fee.
date?
MR. GENEGO: Yes, your Honor. We would request
January 2nd and would also request that the Court recommend a
facility in Southern California.
THE COURT: All right. I will make that
recommendation.
The Court finds by clear and convincing evidence
that the defendant is not likely to flee or pose a danger to
any person or the community.

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The defendant will remain free on his current bond.
If you violate the conditions of your bond, that could result
in your immediate incarceration.
Is that clear?
DEFENDANT SMITH: Yes, sir.
THE COURT: The defendant's bond will be exonerated
upon his self-surrender, and the Court will make a
recommendation that he be housed in Southern California.
MR. GENEGO: Thank you, your Honor. May we be
excused?
THE COURT: Yes. Thank you very much.
I've considered the kinds of sentences available
for Mr. Manzo. The Government seeks a 30-month term of
imprisonment while the defendant seeks a probationary
sentence.
In aggravation, this defendant was involved in
hiding an inmate who was a federal informant. He helped
draft a policy that was designed to keep the FBI out of the
jails. He was involved in tampering with witnesses and, when

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he was transferred to the ICIB, continued with certain
activities.
I've considered the history and characteristics of
the defendant. This defendant too has a devoted family and
the support of many in the community. The Court has received
letters from his family, colleagues and friends attesting to
his good character, his dedication to his family, to his
community, and his acts of public service.
The Court has considered the advisory guidelines
along with the statutory sentencing factors. To impose a
probationary sentence urged by the defendant under the
circumstances would trivialize the seriousness of the
offense, the need for a just punishment, the need to promote
respect for the law, to promote deterrence, and to avoid
sentencing disparities.
The Court recognizes its discretion to vary from
the guidelines provided it does so reasonably.
The Court finds that -- the defendant's arguments
to vary from the guidelines aren't persuasive, and the
defendant's arguments have been incorporated into the
sentence that will be imposed by the Court.
sentence of 24 months of incarceration followed by a one-year
term of supervised release, no fine and a $200 special
assessment reflection the seriousness of the offense,

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provides for a just punishment, promotes deterrence, and is
THE COURT: Any legal reason why sentence should
not now be imposed?
Pursuant to Section 5E1.2, all fines are waived as
the Court finds that the defendant has established that he's
unable to pay and is not likely to become able to pay any
fine.
on Count One and Two to the custody of the Bureau of Prisons
for a term of 24 months. This term consists of 24 months on
each of Count One and Two to be served concurrently.

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term consists of one year on each of Count One and Two, all
such terms to run concurrently under the following terms and
conditions:
Order 05-02.
a DNA sample.
suspended based on the Court's determination that the
to appeal within that 14-day period will constitute a waiver
of your right to appeal.
You are advised that you are entitled to the
unable to afford a lawyer one will be provided to you.
If you're unable to afford the filing fee, the

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date?
MR. LOMBARD: Yes, your Honor. January 2nd as
well.
flee or pose a danger to any person or the community.
Prisons on or before noon on January 2nd, 2015.
In the absence of such a designation, the defendant
shall report on or before that date and time to the United
States Marshal's Office located in the Roybal federal
building.
The defendant is to remain free on his current
bond; but, sir, if you violate any of the conditions of your
bond, that could result in your immediate incarceration.
Is that clear?
DEFENDANT MANZO: Yes, sir.
upon his self-surrender.

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MR. LOMBARD: Yes, your Honor.
If the Court would recommend placement in the
Southern California Bureau of Prisons facility.
THE COURT: I'll make that recommendation as well.
MR. LOMBARD: And may we be excused, your Honor?
THE COURT: Yes, you may.
MR. LOMBARD: Thank you.
THE COURT: All right. If we could have Defendant
Craig and his counsel approach the lectern, please.
This defendant is before the Court for sentencing
after a jury trial in which he was convicted of conspiracy,
obstruction of justice, and making a false statement.
The Government seeks a 51-month term of imprisonment while
the defendant seeks a probationary sentence.
In aggravation, this defendant was involved in
tampering with witnesses, in confronting an FBI agent at her
home even though it was clear that she was conducting a
legitimate investigation into abuse of deputies and
corruption at the county jails.
The Court has considered the kind of sentences
available.
This is a defendant, who has dedicated a majority
of his adult life to public service. In addition he and his
wife have turned a personal tragedy into a viable nonprofit

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organization that provides for mental health support for many
in the community.
The defendant has requested a variance based upon
his personal history and characteristics.
the guidelines. The Court finds that the arguments for a
variance are persuasive, and the Court has incorporated the
arguments for a variance into its sentence in this case.
for a just punishment, promotes deterrence, and is sufficient
but not greater than necessary to comply with the statutory
goals of sentencing.
Does either party have any objections that were not
previously addressed?
MS. RHODES: Your Honor, I believe because he was
convicted on three counts, the special assessment should be
$300.
THE COURT: You are correct. The special
assessment is $300.
Any legal reason why sentence should not now be
imposed?

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quarter pursuant to the Bureau of Prisons' inmate financial
responsibility program.
the Court finds that the defendant has established that he's
fine.
on Counts One, Four, and Five to the custody of the Bureau of
Prisons for a term of 33 months. This term consists of
33 months on each of Counts One, Four, and Five to be served
concurrently.
Upon release from imprisonment, the defendant shall
term consists of one year on each of Counts One, Four, and
Five, all such terms to run concurrently under the following
terms and conditions:
Order 05-02.

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101
The defendant shall participate in mental health
treatment which may include evaluation and counselling until
discharged from treatment by the treatment provider with the
approval of the Probation Officer.
As directed by the Probation Officer, the defendant
shall pay all or a part of the costs of treating his mental
health treatment to the after-care contractor during the
period of supervision. The defendant shall provide payment
and proof of payment as directed by the Probation Officer.
a DNA sample.
suspended based upon the Court's determination that the
defendant poses a low risk of future substance abuse, and the
Court authorizes the Probation Office to disclose the
Presentence Report and/or any previous mental health
evaluations or reports to the treatment provider.
The treatment provider may provide information to
state or local service agencies for the purpose of the
defendant's rehabilitation. Further redisclosure of the
Presentence Report is prohibited without the consent of the
Court.

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and sentence within 14 days from today's date the failure to
assistance in counsel in taking an appeal. And if you're
such a fee.
date?
MR. RABE: Your Honor, yes, January 2nd, 2015.
THE COURT: The Court find by clear and convincing
evidence that the defendant is not likely to flee or pose a
danger to any person or the community.
The defendant will remain free on his present bond.

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If you violate any of the conditions of your present bond,
that could result in your immediate incarceration.
Is that clear?
DEFENDANT CRAIG: Yes, sir.
upon his self-surrender.
MR. RABE: Your Honor, as with the others, could
you recommend incarceration within Southern California?
THE COURT: Yes, I'll make that recommendation.
All right. Thank you very much.
Defendant Long appears before the Court for
sentencing after having been found guilty by jury on one
count of conspiracy, one count of obstruction of justice, and
one count of making false statements.
The Government seeks a 30-month term of
imprisonment while the defendant seeks a probationary
sentence.
In aggravation this defendant was involved in
tampering with witnesses, confronting an FBI agent at her
home.
I've also considered the history and
characteristics of the defendant. She too has received
letters from many in the community including many of her
colleagues. She has a loving and devoted family. Friends

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104
have attested to her good character, her dedication to her
family, to her community, and her many acts of public
service.
Having considered the advisory guidelines as well
as the statutory sentencing factors, the Court finds that a
probationary sentence urged by this defendant under the
circumstances would trivialize the seriousness of the
offense, the need for a just punishment, the need to promote
respect for the law, to promote deterrence, and to avoid
sentencing disparities.
the guidelines provided it does so reasonably. The Court
has -- finds the arguments for a variance persuasive and has
incorporated those arguments into the fashioning of the
sentence.
term of supervised release, no fine, a $300 special
for a just punishment, will promote deterrence, and is

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105
MR. NAVARRO: Your Honor, not with respect to
sentence, no.
THE COURT: Is there any legal reason why the
sentence should not now be imposed?
responsibility program.
the Court finds that the defendant has established that she's
fine.
on Counts One, Four, and Six to the custody of the Bureau of
Prisons for a term of 24 months. This term consists of 24
months on each of Counts One, Four, and Six, all to be served
concurrently.
term consists of one year on each of Counts One, Four, and
Six, all such terms to run concurrently under the following

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106
terms and conditions:
regulations United States Probation Office and General Order
05-02.
a DNA sample.
And the drug-testing condition mandated by statute
is suspended based on the Court's determination that the
You have the right of appeal from the judgment and
sentence within 14 days from today's date. The failure to
your right to appeal. You are also advised that you are
entitled to the assistance of counsel in taking an appeal.
And if you're unable to afford a lawyer, one will be provided
to you.
If you're unable to afford the filing fee, the
date?
MR. NAVARRO: Yes, your Honor, if we could have

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107
January 2nd by 12 noon.
and convincing evidence that the defendant poses no danger to
the community or any person.
The defendant is ordered to surrender herself to
the institution designated by the Bureau of Prisons on or
before noon on January 2nd, 2015. In the absence of such a
designation, the defendant shall report on or before that
date and time to the United States Marshal's Office located
in the Roybal federal building.
The defendant shall remain free on her current bond
until her self-surrender.
If you violate any of the conditions of your bond,
that could result in your immediate incarceration.
Is that clear?
DEFENDANT LONG: Yes.
upon her self-surrender. Is there anything else?
MR. NAVARRO: Your Honor, we would ask for a
recommendation for a Southern California facility.
THE COURT: I'll make that recommendation.

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108
Anything else?
MR. McDERMOTT: Sir, one additional request.
I neglected to ask as far as a recommendation from
the Court for designation of incarceration. Would you also
make it for Lieutenant Thompson as to the Central District as
well?
THE COURT: I will make that recommendation.
MR. McDERMOTT: Thank you, sir.
I'll just say there really are no winners today.
All right. Thank you.
Thank you.
(Whereupon, at 12:13 p.m. , the proceeding
concluded.)

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109
CERTIFICATE OF REPORTER
COUNTY OF LOS ANGELES )
) ss.
STATE OF CALIFORNIA )
I, LEANDRA AMBER, OFFICIAL FEDERAL COURT REPORTER, REGISTERED
PROFESSIONAL REPORTER, IN AND FOR THE UNITED STATES DISTRICT
COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, DO HEREBY
CERTIFY THAT PURSUANT TO SECTION 753, TITLE 28, UNITED STATES
CODE, THE FOREGOING IS A TRUE AND CORRECT TRANSCRIPT OF THE
STENOGRAPHICALLY REPORTED PROCEEDINGS HELD IN THE
ABOVE-ENTITLED MATTER AND THAT THE TRANSCRIPT PAGE FORMAT IS
IN CONFORMANCE WITH THE REGULATIONS OF THE JUDICIAL
CONFERENCE OF THE UNITED STATES.
DATE: __________________________
_____/s/_________________________
LEANDRA AMBER, CSR 12070, RPR
FEDERAL OFFICIAL COURT REPORTER

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