Case 6: Sample Defendant

Client Name


San Diego, CA 92101

December 1, 20xx 

The Honorable Anthony Rizzo

United States District Court Judge

Southern District of California

221 West Broadway

Courtroom 4A, Suite 4135

San Diego, CA 92101

Regarding: U.S. v. Client Name-Sentencing

Dear Judge Rizzo:

I am deeply sorry for my bad decisions. As a young man I aspired to live as a hard-working, good citizen. I was born into a life of struggle and challenge, in an abusive environment. It was always my goal to overcome those struggles and to live as an honorable person. With my actions that placed me before this Honorable Court, it is quite clear that I have failed. I regret what I have done. I am pleading guilty to serious crimes and I am ashamed of my poor decisions, my selfish decisions. 

As a result of my criminal actions, I contributed to our nation’s problems with substance abuse. I fell into a bad way of life—all because of a foolish middle-age crisis. I lacked the good character to take an honest assessment of my life. In this letter, I will provide details of what happened. To get through that story, I must start from the beginning. A family member offered what I perceived to be an easy solution to my problems. I regret that I used poor judgment, moving into criminal behavior that I knew in my heart was wrong. 

With my error in thinking, I did not consider the victims that I would harm. I only thought of digging myself out of a hole that I had created. 

I am ashamed to admit that I was in a bad place in my life. I was weak. I failed to make the type of decision that characterized the man I aspired to be. It was my weakest moment. 

I implore this Honorable Court to have mercy. And in my request for mercy, I ask this Honorable Court—and all who judge me—to know that I am not beyond redemption.  Despite my deplorable behavior in this offense, I do not have a criminal mindset. I have the will, the desire, and the discipline within to work toward redemption. I will make things right to the best of my ability. I pray this story will show my commitment to living as a law-abiding, contributing citizen. I hope that you will see me as a good person—and not judge me only for the bad decisions I made during the weakest time of my life.


My father is Jesus Reyes Niebla. He was born in Los Angeles, but his parents took him to Tijuana when he was only an infant. My father was raised in poverty in Mexico. When he turned 18, he returned to California so that he could join the military. He aspired to build a life of stability and to contribute to his family. 

When he was still a young man, my father married my mother, Mary Carmen Reyes. My mother was born in California. As with my father, her parents brought my mother to Mexico where she spent her childhood and youth. My parents married in 1959 or 1960 and they began to build our family. 

I have four siblings. My oldest sister is Marla Denise, who was born in 1961. I have an older brother, Jesus, Jr., who was born in 1962. I was born in 1968, making me 49 years old. I have two younger sisters, Maire Anjenette, born in 1972, and Mirelle, born in 1974. As a young boy, I felt closest to my younger sisters because of our proximity in age.

We were a middle-class family. For many years, our father worked as a paper salesman in San Diego. Our mother reared my siblings and me in Tijuana. On Sundays, we attended Catholic mass together as a family. 

While I grew up in Tijuana, drug traffickers ravished our community. We heard about their exploits every day. Our parents tried to teach us about the bad ways that drugs influenced our community. From a young age, I understood the dangers of drugs. Despite my behavior that led to this instant offense, I knew that I should not become involved with anything illegal. 

Our parents had all of the struggles that accompany an impoverished life. As a child, I felt abused, both verbally and physically. Our parents did their best to provide us with stability, but we always lived in struggle. My father worked hard on his job. My mother protected us as she saw fit from the bad influences around our community. 

Our parents were strict disciplinarians. In retrospect, I know that they wanted us to grow up to be good people. Yet as a young boy, violence in our home left an indelible impression upon me. I have many memories of our parents beating me, abusing me emotionally and physically. 

I was a child performer, enjoying singing and dancing and acting. My parents did not approve of the arts, certainly not as a career aspiration. When I told them that I wanted to grow up to be an actor, my dad would try to influence my choices with verbal or physical abuse—or both. My mother ridiculed the idea of living as an artist, saying that I would always be a failure. Their anger, violence, and discouragement had the opposite influence. Instead of turning away from the arts, I looked for more opportunities to develop my skills as an actor. 

As a child, I performed okay in school. Academics were not my strong suit. I started playing American-style football when I was 13. At that point, I lost all interest in studying. It didn’t matter whether I was on a stage or on an athletic field. I enjoyed interacting with others and performing. I continued with sports until I was 18. Sports and the arts attracted me more than academia. 

Once I graduated from high school, in 1986, I wanted to train for a career as a performing artist. Since childhood, I enjoyed singing and I had some experience acting in school plays. As stated earlier, my parents discouraged all hopes of working as a performing artist. They insisted that I continue my education. Trying to please them, I enrolled in a program to study architecture at Grossmont College in San Diego. 

As with my high school studies, I did not take well to college. The structure felt too restrictive and I didn’t apply myself. With the maturity of being a 49-year old father of two, I reflect on the past decisions of my life. With more clarity, I can see the many bad decisions I made along the way, and I learn. My inability to follow through with structure was a character flaw I should have worked on. After a semester, I left college life so I could experience a bit more liberty. I began working in retail sales at Miller’s Outpost clothing store. 

My father wanted me to stay in school. Even though I needed to earn a living, he didn’t like that I was working in retail sales. He said that I needed to mature. He built his life by enlisting in the military. Wanting to please him, I began making inquiries to enlist in the Marines. I went through the preliminary process of enlisting in the military. My father supported the decision, but my mother did not. When my mother learned that I might enlist in the military, she vetoed the plan, fearing for my safety. 

Although my parents differed on whether the military would be a good pathway for my future, they were in total agreement that I should not be working in retail sales. I needed to apply myself, they insisted. Again, I tried to please them by returning to school. I enrolled in Southwestern College, studying music and composition. After a year at Southwestern, an opportunity opened for me to transfer to the Academia de Arte y Cultura Sonia Amelio, in Mexico City. I wanted to become an actor. 

My parents continued to resist my decision to pursue this career. But I was trying to follow my dreams. I moved into a one-room, cockroach-infested apartment with 14 other aspiring actors. We slept on the floor. We shared a single bathroom. Life was about studying, looking for work, and doing anything necessary to survive. I also studied with El Centro de Educacion Artistica de Televisa en Monterray. I wanted to learn everything I could about art history, dancing, acting, and literature in the conservatory-style school. The conservatory-style placed a higher emphasis on practical performance training and experience, and a lower emphasis on academics—which felt like a better fit for me. 


Over the next ten years, I found work as an actor. I did not have the highest level of success. Yet I was away from my parents and pursuing my dream. When I was about 25, I married Martha Elena. 

Martha and I met during high school and we did our best to build a life together. While I struggled to build a career as a performing artist, Martha became a schoolteacher. The Lord blessed us with two beautiful children. Our daughter, Maria Sofia, was born on September 4, 1997. Our son, Dario Antonio, was born on September 5, 2003. 

My career as an actor provided sporadic income. I found work on a cable television show as an extra and then doing parts in skits and ensembles. I started working in theater, doing musicals. My studies in ballet, ballroom dancing, fencing, gymnastics, and jazz made me well suited for the stage. In Monterray I had roles in the Phantom of the OperaJesus Christ Superstar. New opportunities opened in Mexico City with Ocesa Teatro, with swing parts in Jesus Christ Superstar and Man of La Mancha

After the tragedy of 9/11, theater productions in Mexico came to an abrupt halt. As a married father of two, I began searching for stability. We struggled financially, but I was not willing to give up on my dream of becoming an actor. By then I invested many years in my craft. Although we did not have financial stability, I kept trying and we seemed to be getting by. 

Martha and I returned to Tijuana where we could have more support from family. I traveled several times each week from Tijuana to Los Angeles so that I could visit with production companies and audition. An opportunity opened for me to join the cast for Ms. Saigon, and I began touring across the USA. 

I considered the opportunity to work with Ms. Saigon as a huge break in my career. It brought some level of financial stability to our family, but the cost proved too high. My constant travel made our marriage difficult. I was on the road for nine months out of the year. 

As I think back, I see that my aspirations to work as a performing artist had a huge toll on Martha and our family. Since I was 29, I spent long periods of time away from home. By the time I was 35 or 36, I realized that I had to make a change.  It wasn’t fair that I was away for so long, leaving Martha with the burden of rearing our two children. Besides the burden I put on my wife, I missed our children. 

The rocky relationship with my parents had a bad influence on me. They tried to control me and I felt abused. Pursuing my career as a performing artist brought my escape from them. I wanted a different relationship with my children. Although I was away while I was acting, we spoke every day. To the extent possible, I doted on them and we became very close. We’re still very close. Our daughter now studies at NYU and we speak daily. I am also very close with my son, a student at Saint Augustine High School. 

To give a more full commitment to our family, I suspended my acting career in 2006, when I was 38. I invested more than 15 years trying to build my career as an actor. But to comply with the advice of my parents and Martha, I gave up on my dream. I took a job as a car salesman in San Diego. Things were really bad at home, and I wanted to make things better. I crossed the border every day to work. Then I returned home to our family in Tijuana. I kept up this life as a salesman for about 10 years. I received a SENTRI pass so that I could pass through the border with less complication. 

To get the SENTRI card, I voluntarily went through an extensive background check. Our entire family went through the process. Once I had the pass, it was easier for me to drive back and forth to work. 

Disruptions and Mid-Life Crisis:

In theory, the plan to work as a salesman seemed like a good fit. Yet to paraphrase the famous Shakespeare, we all weave our tangled webs. With my efforts to build a career as a performing artist, I spun a web that was impossible to unwind. 

The constant traveling led Martha and I to grow apart. I can look back and say that my acting career played a big role in our separation. She worked as a mother and schoolteacher while I was away. We drifted. 

While I tried to work as a car salesman and improve our relationship, Martha had her own life. I suppose she had to adjust because we had been apart for so long. Even though I tried to recalibrate and make it at home, the magic we shared during our youth was gone. From my perspective, Martha was angry and bitter all the time. She preferred to spend time with her friends and doing things outside of the family. I was too clingy, she said, she didn’t like that I wanted so much of her time. We were miserable together. Our life and marriage were failing. 


As a consequence of the struggles at home, my performance on the job began to suffer. I started drinking heavily. When I drove home from my job, I would take the long way—just so I could avoid time with Martha. Stopping off at cantinas led to my abuse of alcohol. I tried to resolve my interpersonal problems with tequila and other alcohol. By the time I reached my late 40s, my life was completely derailed. 

As a father, I was very close to my children. But as an actor, I failed, and as a husband, I failed. I wanted to divorce Martha but I didn’t know how. I created a complicated mess. 

My mother and father were 100% on Martha’s side. As Catholics, they did not believe in divorce. They continuously pointed accusatory fingers at me, insisting that I stay in an unhappy marriage because it was the right thing to do. They kept saying how they had advised against my foolish dreams about pursuing an acting career. I made my own misery, they said, and I would need to see it through. In our family, divorce was not an option. 

Complicating matters further, I began to second-guess the choices I made. By abandoning my dream of being an actor, I left my identity behind. Colleagues with whom I had acted on Ms. Saigon had gone on to great careers on Broadway. When we worked together, we were on the same level. I convinced myself that if I had not given up, I too could have reached a higher potential as an actor. But I gave up on my dream. As a result, I lived in misery and I didn’t know how to escape. It was my mid-life crisis. 

I was deeply in debt, depressed, and struggling with alcoholism. Despite my parents’ anger and disappointment, I divorced Martha in 2015. 

My Deal With the Devil:

My youngest sister, Mirelle, was married to Oscar Leon. Outward appearances suggested that Oscar was financially successful. He represented to our family that he earned a living as an automobile wholesaler. That struck me as being odd because I tried to offer him opportunities. As a car salesman, I frequently came across trade-in opportunities that should have appealed to him. When I told Oscar about good deals he could seize, he refused. I did not think too much about it, but I always thought it was strange. 

When Oscar saw me as being depressed, he pulled me aside to talk. He told me that he understood I was going through a tough time. It wasn’t right, he said, that my parents were judging me so harshly. If I wanted to become an actor, they should have supported me, he said. Oscar was telling me exactly what I wanted to hear. He plied me with alcohol, assuring me that every man had a right to pursue his dream. Then he said that he wanted to help me break free from my problems. 

I didn’t know what he was talking about. But he said that since I had a SENTRI card, I would be a perfect fit to work with him. If I worked with him, he said, he could pay me enough money that would allow me to get out of debt. The money I earned would allow me to resume stability after my divorce from Martha. I could start a new life. I would have enough time, he said, to resume my career as an actor. The job he was offering would not take too much time. I would only need to work for a few hours. 

When I asked what I would need to do, Oscar told me that I would only need to do some driving for him. He told me it would be best if I didn’t ask questions. I would simply need to give him the keys to my car. He would then load the car with the goods that he wanted me to carry, and give me the keys. Although he didn’t say what I would be driving, Oscar insinuated that I would be driving marijuana. But it would be best if I didn’t ask questions, he said. Foolishly, I agreed. 

Oscar offered to pay a few thousand dollars if I drove the vehicle to his colleagues in Los Angeles. I wanted to believe in him, as if he could offer some type of magical cure for the problems that my earlier life decisions had created. 

As agreed, I drove for him. He would give me a phone number when I was on my way. I would call the number and the people who answered would tell me where to meet. We always met in a public place. They would drive around in their car, and I would follow in my car. When they stopped, I stopped behind them. They would take the boxes from the trunk. 

When I returned, Oscar paid me in cash. I did this job when he asked. 

In October of 2017, that “work” for Oscar came to an end. While I was driving through San Clemente on my way to Los Angeles, authorities caught me. The Border Patrol pulled me over on what I assumed was a random stop. Upon their search, they discovered that the car was packed with drugs. I learned that the car I was driving carried 162 pounds of cocaine. Although I thought I was driving a car with marijuana—not cocaine—my life, as I knew it, was over. 

The authorities arrested me and I spent the next nine days in custody. While in the detention center, I had time to reflect. Those were the first nine days of sobriety I had in more than three years. Without alcohol, my body and mind began to cleanse. Without the numbing of my mind from alcohol, I could see how much trouble I had caused. 

In order to resolve the mid-life crisis I was going through, I made a deal with the devil. I deluded myself with thoughts that I was only driving a car across the border. But as I was locked inside of that detention center, I could not deny that I had been participating in a drug-trafficking scheme. And I’m ashamed. 

What I’ve Learned and What I’m Doing to Make Things Right:

I have learned a lot about myself through this process. During the time that passed since my arrest, I’ve had an opportunity to recalibrate. I know that I was weak. I know that I made bad decisions. I know that I must do better. 

I am making a commitment to sobriety and I am making a commitment to cleansing myself of all unhealthy relationships. Through my attorney, I have agreed to plead guilty and to cooperate fully with the government. I instructed my attorney to let prosecutors know that I will do anything and everything to right the wrongs that I have done. 

Further, I am being completely honest with my family. I have had lengthy conversations with my children, my ex-wife, and my parents about the way that I have fallen. I am ashamed for what I have done, and I determined to make things right. 

I have enrolled in a program to help me lead a more values-based, goal-oriented way of life. I made a commitment to sobriety, and I have stayed true to that path since my release from the detention center. 

Your Honor, I understand that a sanction follows the bad decisions I made. I committed crimes and punishments will follow. Still, I implore you to have mercy on me. I learned a great deal from this experience. I know that I violated the trust that our government gave me when issuing the SENTRI card, and I know that through my actions, I contributed to the spreading of substance abuse. Yet in my heart, I am capable of redemption and I will do everything within my power to prove worthy. 

With hopes that you will consider me a good candidate for reconciliation, I ask you to be merciful at sentencing. 

Respectfully submitted, 

Client Name