Case 5: Sample Defendant

Client Name


Memphis, Tennessee  38120 

December 3, 20xx

The Honorable Christina A. Samuel

United States District Court Judge

First Street Courthouse

350 West First Street, Courtroom 8D

Los Angeles, CA 90012

Regarding: U.S. v. Client Name

Dear Judge Samuel:

I deeply regret the many bad decisions I made. Despite being blessed with countless opportunities, I struggled with some personal failings. Those failings led me into a cycle of substance abuse that has plagued my life for more than 35 years. I’ve learned a great deal from this experience. I’m going to make things right with law enforcement, with my victims, and with my family. 

My struggles with drugs began during my teens. In a foolish effort to feed my addiction, I am ashamed to acknowledge that I broke laws and contributed to our nation’s crisis with drug abuse. I will do anything to make amends. As a first step to make things right, I pleaded guilty quickly. Further, I agreed to cooperate fully with the government. But I know that I must do much more. 

Although I broke the law by engaging in this crime over many years, this act does not reflect my true character.  I never would have associated with people who break the law if I were not an addict. I am deeply sorry for my crimes. 

Certainly, I understand that my criminal behavior will result in severe sanctions. Yet I pray that this Honorable Court will take my entire life into consideration. Please judge me for more than the decisions I made during my weakest moments. By the time I am sentenced, I will be a 58-year-old man. Other than the actions that led to my criminal charge, I have lived as a law-abiding, contributing citizen. It is my hope that this Honorable Court will see some good in what I have done. 

Through this letter, I would like to reveal more about my background and the influences that led me into this problem. I would like this Honorable Court to understand how I empathize with the many victims of my crime. And I would like the Court to know what I have learned. Mostly, I would like this Court to know why I will never engage in criminal misconduct again. 


My father graduated from Vanderbilt and joined my grandfather in building a family business. The business grew, eventually employing more than 400 people. I am ashamed that despite being born into privilege, I did not live up to my potential. 

My dad married my mother, Mickey, when he was 18. They grew up as childhood sweethearts. I was their first-born child, born on January 3, 1960. Two years later, my mother gave birth to my younger sister, Daneel. In 1965, my younger brother Danny was born. We are a very close family. 

I graduated from Christian Brothers High School in 1978 as a mediocre student. My parents encouraged me to pay attention in school, but the academic life never appealed to me. As an entitled young man, I assumed that I would go into the family business. From my perspective, it didn’t make any sense to study concepts like literature or history because they wouldn’t have any bearing on my future. Rather than studying, I was more into social activities like going to games, concerts, or parties. 

Following my graduation from high school, I began studies at the University of Alabama. I didn’t take too well to the studies there. The family scrutiny during my freshman year stifled me. Wanting a change, I transferred to the University of Arizona. In retrospect, I can see that I wasn’t ready or sufficiently mature for independence. 

During my sophomore year, my father called me in Arizona to tell me that he sold our family business to a larger company. Rather than celebrating my father’s successful exit, I felt as if my legacy had been ripped away. 

Starting With Drugs:

When my dad told me that he sold our family’s company, I went off the deep end, taking heavier doses of drugs and partying. I descended into a cycle, ignoring my classes completely. My father told me to pack my bags and return home. The day after I got home, my parents sent me to a drug rehabilitation center in Dallas. I’d never been in treatment before, but once my parents heard about my abuse of drugs, they wanted to get me help. That treatment program took about 30 days. I got through the program, but didn’t learn much. 

When I returned home, I tried to build a career with the new company that purchased our family business. Yet management in the new company brought tighter controls. Sensing that it wasn’t “our” company any longer, I quit. By then I was using cocaine, taking pills, and getting high by shooting drugs intravenously. I was a mess as a young man. 

Marriage and Career:

As a young boy, I met Jill and we became childhood sweethearts. I returned to Tennessee from Arizona as a college dropout, in shame. Yet Jill didn’t give up on me. She was making progress toward her college degree. Against her family’s wishes, Jill and I dated. Her family didn’t want her around me because they knew that I was a problem child. Yet Jill and I continued our relationship and she had a positive influence on me. We fell in love and I began to build my life around her. With Jill’s help, I cleaned up my act with substance abuse. My father used his connections to open a few job opportunities. For the first time in my life, I started acting responsibly. With Jill, I could see a future that looked bright. 

I took a position with Delta Foremost, a company that manufactured and sold cleaning chemicals. Delta hired me to work as a salesman. Then the company’s leadership promoted me to work as a district manager. I applied myself and gave all I could to contribute. 

With more stability, Jill and I decided to marry and start a family. We got married on September 19, 1986, when I was 26. Our first daughter, Paige, was born on December 27, 1987. And our second daughter, Sydney, was born on December 10, 1992. 

After about five years with Delta Foremost, I had more confidence and experience. I was ready to go into business on my own. Jill and I spoke with her father and he agreed to extend us a $25,000 loan. We used those resources to launch River Products. Through River Products, I became a supply company that fulfilled orders for local businesses. We sold everything our customers wanted, from chemical supplies to paper products. I negotiated credit terms with vendors and I created an efficient distribution system with subcontractors. Jill did our bookkeeping, and together we built a small business that would allow me to earn a living and repay my father in law as agreed. Our business grew rapidly, opening new opportunities along the way for me to create additional revenue streams for our family.

Through our work with River Products, I learned about the billboard business. I acquired billboards by signing long-term leases with landowners. Then I could monetize those leases by contracting with advertising companies and small businesses. The venture helped our family become more financially secure. We still operate River Products, though we focus most of our attention on our growing billboard business. Since starting our businesses, I’ve supported our community by creating jobs and contributing to the economy in positive ways. 

Substance Abuse and My Crime:

My wife influenced me to abstain from drugs when we began dating. Unfortunately, as I was recuperating from knee surgery. To help me recuperate, my physician prescribed Lortab. The opioid pain reliever worked fine for people who did not have a history of substance abuse. Once I started taking Lortab, my addictions resumed. 

I took much higher doses of Lortab than my prescription allowed. When my physician refused to refill the prescriptions, I found street vendors. They sold Lortab and other drugs, including Quaaludes. 

I became a functioning addict. My businesses were well established and almost operating on autopilot. As a result, it didn’t hurt me too much to indulge in drugs. I would wake at 4:00 am, take a few Lortabs or Quaaludes and enjoy the high in solitude before my wife woke. They were fast-acting drugs, but not long-lasting drugs. As the day moved on I could focus on business, even if I was slurring my words a bit. At night, I would take a few more pills to relax. 

This pattern went on for several years. My weight dropped from a normal weight of 155 to about 120 pounds, more than 35 pounds too light for my frame. I looked sickly. Jill could see that I had reverted to substance abuse. I lied to her and she became disgusted. We slept in different rooms of the house, with my living in denial that I had a problem. 

In 2009, a friend introduced me to Rachel Berkowitz. Rachel heard that one of my companies sold business supplies, including industrial cleaning solvents. She asked if I could provide her with Anthranilic acid and o-Toludine. Rachel provided me with the name of a supplier. 

At the time, I didn’t consider the legal implications of what I was doing. Rachel offered to supply me with Quaaludes if I could provide her with the chemicals. The supplier agreed to send the chemicals to my company. I was delusional, willfully ignorant, refusing to acknowledge that my actions were breaking the law. I simply put a new mailing label on the package. Then I used a standard delivery service to send the packages to Rachel’s address. Rachel and I completed this transaction about every eight months. She paid for the cost of the chemicals. To compensate for my troubles, she sent 250 Quaaludes—absolving me of having to go out and purchase the drugs from street dealers. I used those drugs for my own supply. When I ran out, I’d order more. 

I knew that Rachel wanted the chemicals to manufacture Quaaludes. It embarrasses me to admit that I was so consumed with feeding my own addictions that I violated federal laws. I am guilty of participating in this scheme. 

In 2010, I voluntarily sought treatment for my addictions at the Cumberland Heights treatment center in Nashville. I did my best to get through the program. For a full week, I went through the counseling sessions and tried to learn. But six months later, I received another order from Rachel. That triggered another relapse. 

In 2013, trying to get the addiction under control again, I returned to Cumberland Heights. Once again I went through the program. My sobriety lasted fine while I was there. But then once I returned home, the pressures mounted again. Within months, I was getting high again. 

By February of 2015, I knew that I needed to get things under control. Addictions were tearing apart our family. A therapist recommended that I check into the Canyon in Malibu for a one-month treatment program. I made good progress. My wife and daughters met me out there for the family-group session. I was determined to do better. 

Yet by early 2017, I relapsed once again. It was always the trigger of receiving that order from Rachel. When I received the order, the cycle of addiction pulled me down again. 

In April of 2017, Rachel told me that she had been working with a manufacturer who got arrested. She said that she wanted to start manufacturing Quaaludes on her own and asked me to send the chemicals. At the time, I was in a period of sobriety. Instead of accepting 250 Quaaludes for the trouble of sending her chemicals, I asked her to send me the equivalent value in cash—about $3,000. 

In June of 2017, DEA agents raided my office and my home. Suddenly, my world came to a crashing halt. Unresolved problems with drug addiction brought the full force of law enforcement upon me. That was when I realized the magnitude of the problems my drug abuse created. As a result of providing Rachel with restricted chemicals, I subverted law enforcement. I contributed to the problem of substance abuse that plagued others as it plagued me. 

Immediately after the arrest, I hired counsel and let them know of my commitment to cooperate fully. Then I returned to the Canyons in Malibu, resuming treatment for my addictions in earnest. I made a commitment to my family that I would never use drugs again. 


Your Honor, I empathize with the victims of my crime because I am one of them. Since learning that I was the target of a criminal investigation, I’ve been tormented with grief. It’s led to introspection, to think about the damages that my actions have caused. 

Since I was 20 years old, I have struggled with drug abuse. My early sense of entitlement led to a lack of discipline as a young man. Drug abuse became my escape. When life got too tough, I could self-medicate my way through challenges. It wasn’t until Jill and our daughters came into my life that I got back on track. Yet as I became more successful with the small businesses I built, I lost my way again. I believed that I had everything under control. When a physician prescribed an opioid to ease my pain and maximize my recovery, I didn’t act responsibly. I welcomed that sensation of getting high again and I didn’t want to let it go. I abused the drug. I didn’t have the strength to resist the addiction. It pulled me under. 

As an addict, I lost my sense of reason. I deeply regret that I have hurt our community, my family, and that I violated the law. 

Request for Mercy:

As you consider the appropriate sanction in my case, your honor, I ask that you take my entire life into consideration. I broke the law in this instance, and I regret to admit that I participated in this scheme over a sustained period of time. Please understand that I was feeding my addiction. My sickness precluded me from appreciating the severity of the crime that I was committing. 

On the other hand, please review my tax and business records. I have been a faithful husband for 31 years. Together we’ve raised two amazing daughters, and they’re the joy of our lives. Besides our daughters, I have an 18-month old grandson who is the center of my world. I would like to be with him and see him every month as he grows. With help from my family, I will stay in treatment for my addictions and maintain my commitment to sobriety. 

Over the course of my life, my wife and I have taken pride in contributing to our community. We donate regularly to Jewish causes. And through my business, I am active in contributing to worthy nonprofits. Two campaigns that I feel strongly about include The Unknown Child. This foundation shows the work of grade school children that worked together to collect 1.5 million pennies that they use to represent the lives of children killed during the Holocaust.  We also contribute extensively to the Courage Thru Cancer Foundation and the Jewish Federation. 

Ironically, despite my guilty plea in this offense, I have been a vocal and enthusiastic supporter of law enforcement for many decades. Our family lives in a city with lots of violence and murders. For that reason, on my own initiative, I tried to help. I reached out to an advertising agency and offered to fund a campaign. We worked together and came up with a campaign that would show the important role that law enforcement plays in our community. 

Our work led to the Blue Lives Matter slogan. I created a billboard, featuring a police badge with 901—profiling the Memphis area code. I donated two billboards to bring awareness to the campaign and I attach a photograph of our creation. 

After the Blue Lives Matter campaign succeeded in Memphis, I approached a business associate at Lamar Billboards. Lamar is the largest billboard company in the United States and we do a lot of business together. I showed my colleague how we were using our Billboards in Memphis to show our support for law enforcement with the Blue Lives Matter campaign. I asked Lamar to join us in spreading this message across the United States. Lamar agreed and we grew our campaign to more than 300 markets across the country. The Los Angeles Police Department even wrote a letter to express support. 

My point in bringing the message to your attention, your honor, is not to pat myself on the back. Rather, I am hoping that when you deliberate over the appropriate sentence, you will recognize that I identify with law-abiding citizens. I am not beyond redemption. If it were not for my addictions, I would not be in this predicament. I am doing everything within my power to make things right, including maintaining my commitment to sobriety and cooperating with law enforcement. When judging me, please consider me a law-abiding citizen with an addiction, and not a criminal. Please have mercy on me. 


Client Name