VERY LONG BUT VERY NECESSARY READING

AFFIDAVIT OF RAYMOND BAKER

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN  DISTRICT  OF NEW YORK

UNITED STATES OF AMERICA

v

CHRISTOPHER MICHAEL·COKE

IRaymond Baker being duly sworn make oath and say as follows:

1.  That I reside and have my true place of abode at 51 Chestnut Lane, Denham

Town Kingston 14 from 1996 with my mother.

2.  I am a Fisherman and work with B & D Trawling Company Limited at 1 Port

Royal Street, Kingston.

3.  That before my father died in 2001 he was a close friend of Mr. Michael

Coke (commonly known as Dudus) and I became acquainted with Mr. Coke as a result of the association he had with my father.

4.  That in 2001 Iheard that two men came to my house and took away my

little brother Kemar Baker. The next day his body was found dead with gunshot wounds to both his feet at King Street and Water Lane corner in Kingston.

5. My father because of his close association with Mr. Coke was assisted by

Mr. Coke in trying to find my bother’s kidnappers and killers.

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6.  Persons who were present at the kidnapping confirmed that the people

were not associated with Mr. Coke and that it was some people from another area. In fact they tried to kill me too and I have a scar in the middle of my chest to show their violence.

7.  I have a clean record and do not need to give this statement  but the lies

that have been told about Mr. Coke are troubling and I have decided to come forward.

8.  I know Jermaine  Coward  also known as Cowboy and he has always been somebody who will pt the blame on somebody else to get out of trouble.

9.  The above statement was made voluntarily of my own free will and it is true

to the best of my knowledge and belief.

SWORN to by the said

RAYMOND BAKER

At  1‘}7  ?owe ,r         5h

On the parish of:   /,’Sf D”

On the  {.#..day of      -::;– Before me:

2012

K ?.n.ll?  <sr

RAYMOND BAKER

B FTHE1’EiiCE FOR THE Pii.RtSH ..

7

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

– – – – – X

UNITED STATES OF AMERICA

– v. –                              Sl7 07 Cr. 971 (RPP) CHRISTOPHER MICHAEL COKE,

Defendant.

X

GOVERNMENT’S POST-HEARING MEMORANDUM

PREET BHARARA

United States Attorney for the

Southern District of New York

Attorney for the United States of America

Jocelyn E. Strauber

John T. Zach

Assistant United States Attorneys

– Of Counsel –

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

– – – – – X

UNITED STATES OF AMERICA

– v. –                                                                                        S17 07 Cr. 971 (RPP) CHRISTOPHER MICHAEL COKE,

Defendant.

– – – – – – – – – – – – – – – – – – – – X

GOVERNMENT’S  POST-HEARING MEMORANDUM

On May 22 and May 23, 2012, a hearing was held pursuant to United States v. Fatico, 579 F.2d 707 (2d Cir. 1978), in the above-referenced matter. The Government respectfully submits that the evidence adduced at the Fatico hearing easily establishes that the appropriate sentence for the defendant Christopher Michael Coke (“Coken) is a term of twenty-three years’ imprisonment – the statutory maximum sentence, the

sentence recommended by the United States Department of Probation and a sentence at uppermost end of the agreed-upon Guidelines range.      The testimony of the two witnesses, corroborated by two sworn Declarations, and unsolicited letters submitted by, among others, members of the Tivoli Gardens community, make clear that the defendant’s history and circumstances and the nature and characteristics of his offense call for a sentence of twenty- three years’ imprisonment.

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I.    BACKGROUND

There is of course no dispute that the defendant has pled guilty to extremely serious crimes.          The defendant has acknowledged, under oath, that he served as the leader of a criminal organization that engaged in narcotics trafficking, firearms trafficking and assault. The defendant has also acknowledged, under oath, that he and other members of that criminal organization conspired to commit an assault with a dangerous weapon.     The particular nature and circumstances of these crimes, and this defendant’s history and characteristics, warrant a sentence of twenty-three years’ imprisonment.

The defendant was a violent and ruthless leader, and the criminal organization (the “Organization” that he ran consisted of a large private militia that the defendant used to control the Tivoli Gardens community in Kingston, Jamaica.                                The defendant used that control to commit and to direct barbaric murders, often in response to relatively minor transgressions such as thefts.

The defendant used that control to monopolize the cocaine trade

within Tivoli Gardens and to supply crack to the addicts who resided there.                 The defendant used that control to force young women in the community to transport his cocaine, vaginally, to the United States.     The defendant’s conduct spanned an almost

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twenty-year period and is simply startling in its cruelty and brutality.

As set forth in the Government’s sentencing submissions of February 22 and March 15, 2012, and its pre-hearing memorandum of May 21, 2012, the parties have agreed and stipulated to a Sentencing Guidelines Range of 262-276 months’ imprisonment.                                                  The parties’ dispute centers on whether the characteristics of this defendant and the nature of his offense call for a sentence at

the top of that range. In particular, the defendant disputes

that he engaged in violence as part of his and his Organization’s efforts to control Tivoli Gardens, (Sentencing Hearing Transcript (“Tr.” at 3), and he contends that his charitable and community activities contradict these allegations regarding his “personal character” (Defendant’s March 12, 2012 Sentencing Memorandum at

2).

In light of the evidence adduced at the Fatico hearing – and indeed in light of the very offenses to which Coke pled guilty – the defendant’s contentions are utterly unpersuasive.                  As

detailed below, the sworn testimony and declarations presented at

the hearing provide eyewitness accounts of Coke’s personal participation in violence on behalf of the Organization.                   There was testimony about Coke’s use of violence to control the Organization and its members – for example, by killing a man who lost a firearm and by butchering a narcotics dealer who failed to

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remit drug proceeds Coke believed he was owed. There was testimony about a mother who pleaded with Coke to spare her son, who had stolen a motorcycle; Coke ignored her pleas and killed her son with a hatchet.      In light of such evidence, it is simply absurd to deny that Coke engaged in violence as part of his and his Organization’s effort to intimidate and control the surrounding community.               Coke’s use of violence was sadistic, deliberate, and effective.

II.  THE FATICO HEARING

First, the Government’s evidence established that Coke maintained control over the Tivoli Gardens community through intimidation and violence – in particular through arming a group of “soldiers” – young men in the Tivoli Gardens community whom Coke and members of his Organization recruited, often as teenagers.   These young men were paid by the Organization. (Tr.

31-33,  42-43).             Jermaine Cohen, a cooperating witness who served as one of Coke’s soldiers from the mid-1990s until about 2006, and who rose to be a high-ranking member of the Organization, described this “System” in his testimony.       (See id.)                   The

soldiers’ responsibilities included protecting the community from

attacks by rival communities (often driven by political conflicts), and preventing law enforcement or military personnel, who were viewed as “enemies,” from entering Tivoli Gardens.                                 (Tr.

34 ,  42,  48).           The Declaration of Cooperating Witness 1, who

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resided in Tivoli Gardens and served as a senior counselor to the

Organization  in the early 1990s, provided a consistent description of Coke’s recruitment of soldiers and the soldiers’ responsibilities,  which corroborated Cohen’s testimony. (Declaration of Cooperating Witness-1  (“CW-1 Decl.”   3, 13-

14) .

Both Cohen and Cooperating Witness 1 explained that these soldiers, up to two hundred in total, (CW-1 Decl.      13; Tr. 72), were armed with firearms that Coke imported illegally into Jamaica from the United States.             (CW-1 Decl. 27-28; Tr. 69-70) Indeed, Coke has acknowledged,  in his guilty plea, that he directed the purchase of firearms in the United States and the unlawful importation of those firearms into Jamaica to further the goals of the Organization.     (Transcript of August 31, 2011

Plea Proceeding  (“Plea Tr.” 23)      Cooperating Witness 1

described Coke’s statements that firepower was critical to maintaining  control over the Organization  and within Jamaica. (CW-1 Decl.    27).   Cooperating Witness 1 recalled that

approximately  every two to three months, Coke received a shipment

containing approximately  five firearms, usually a mix of rifles and handguns, and that Coke would “test fire” the guns after they arrived.     (CW-1 Decl. 28, 30).

Indeed, firearms were so critical to Coke’s control over his

Soldiers and his control over the Tivoli Gardens community that

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the penalty for losing a firearm was death. Cohen testified that when he first became a soldier, Coke gave him (Cohen) a firearm and told him that “if I [Cohen] lose this gun, I [Cohen] lose my life.”     (Tr. 46).   Similarly, Cooperating Witness l’s sworn Declaration described a incident in which a well-respected soldier, (whose accomplishments included “freeing” another

soldier from police custody), lost a firearm. Coke directed the

soldier to replace the firearm, and stated that the soldier would have been shot and killed immediately, were it not for the above- referenced accomplishment.  When the soldier failed to replace

the gun within the period of time allotted, he was killed. (CW-1

Dec1. ‘ll  15…: 17).

Second, contrary to Coke’s claim that his goal was to serve and improve the Tivoli Gardens community, the evidence shows that Coke made the community a hub of his own criminal activity.                                As

an initial matter, Coke used the community’s youth as his personal soldiers, thereby rendering the community inaccessible to local law enforcement, which, in turn, allowed Coke to commit crimes with impunity, virtually assured – until his arrest in this case – that he was beyond the reach of the law.

Furthermore, the evidence at the hearing established that Coke

maintained a crack “monopoly” in Tivoli Gardens.   Indeed, Coke has acknowledged that he directed the distribution of crack cocaine in Jamaica. (Plea Tr. 23).                      Cohen’s testimony and the

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Declaration of Cooperating Witness 1 established that Coke directed other members of the community to sell his crack cocaine to the community’s drug-addicted residents, at spots located within the community, while banning the sale of crack or cocaine by others. (CW-1 Decl. <JI    31; Tr. 68-69).

As further evidence of his control, Coke required vulnerable women in Tivoli Gardens community to transport cocaine,

vaginally, to the United States. Both Cohen and Cooperating

Witness 1 personally observed women who were required to transport cocaine to the United States for Coke in this manner, saw the packaged cocaine that the women transported and were nearby at the time that these women inserted the cocaine in their bodies.                                Indeed, Cohen and Cooperating Witness 1 independently interacted with a woman they knew as “Petal” who transported cocaine for Coke to the United States in this manner.          (CW-1

Decl. <JI<JI   36-37; Tr.    81-83).   Cohen discussed with Petal her cocaine trafficking activities.       Petal told him (Cohen) that she wanted to stop transporting cocaine for the defendant but that she was afraid to. (Tr. 83-85).                      Cooperating Witness 1 also observed a number of other women, ln addition to Petal, who were required to transport cocaine to the United States by inserting

it into their bodies, vaginally, and then traveling to the United

States.   (CW-1 Decl. <J[<J[       33-35).   Cooperating Witness 1 stated that Coke was present when the women received and inserted the

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cocaine, and that Coke gave the women instructions about who to contact upon arrival in the United States.                (CW-1 Decl.    35).

Anthony Brown, a cooperating witness and former Kingston track coach whom Coke tasked with obtaining fraudulent U.S. visas for his (Coke’s) drug couriers, similarly testified about Coke’s use of women to transport narcotics to the United States.

Brown’s testimony corroborates that of Cohen and the Declaration

of Cooperating Witness 1. When Coke met with Brown to discuss the visas that he needed, Coke specifically told Brown that the individuals for whom Coke wanted visas were “not coming to America for any joy ride, they [would] be carrying up drugs.” (Tr. 315). Brown testified that among the individuals for whom he (Brown) was asked to obtain a visa was a young, pre-pubescent girl.        Brown recalled that when he met with her to prepare her for her U.S. Embassy interview (then necessary to obtain a U.S.

visa) the young girl, who was “crying,” said she “never wanted to do it but because her brother messed up some money from Duddus [Coke] in the United States and so she had to and that her father got a beat from them.” (Tr. 320).

Brown’s testimony concerning Coke’s use of a young and unwilling girl to transport cocaine is consistent with the allegations that Coke mistreated women, made in some of the unsolicited letters written to this Court in connection with the sentencing of this defendant.   For example, in an undated letter

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received by this Court on September 22, 2011, a woman requesting a life sentence for Coke wrote of the vicious rape and murder of her daughter, who refused to carry cocaine to the United States for the defendant.    The author stated that her daughter was “gang rape[d) and shot in her vagina by Christopher Coke and his shower posse coconspirators.”

Brown’s testimony lS also corroborated by the sworn declaration of Witness 2, a citizen of Jamaica and student and researcher at a local university, who conducted surveys of various populations within Kingston during the period of time that Coke was in control of Tivoli Gardens. (Declaration of

Witness 2 (“W-2 Decl.”     1-5).   Witness 2 described a woman she met in the course of a survey of the area around Tivoli Gardens. The woman reported to Witness 2 that after she was deported from the United States, she was taken to “Tivoli” where “they” asked her to carry cocaine to the United States.   When she refused to

do so she was raped repeatedly.   (W-2 Decl.    8).  Because the

woman stated that she had been taken to “Tivoli” where “they” had asked her to transport narcotics, Witness 2 concluded that “they” was a reference to Coke and his Organization. (Id.).

Third, Coke used – and increased – his control over the residents of Tivoli Gardens, including those who sold his cocaine, through truly gruesome acts of violence, including murder. Coke maintained a structure in Tivoli Gardens referred

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to as the “jail,” which both Cohen and Cooperating Witness 1 described, in similar terms – an enclosed structure made of cement slabs that was used for beatings, shootings and murders. (Tr. 100-101; CW-1 Decl.      23).1  Cohen testified about six

murders in which Coke directly participated, ln Cohen’s presence, that took place in that jail.

In one instance, Coke murdered a crack seller known as “Tall Man,” to punish Tall Man for repeatedly failing to pay Coke the full amount of drug proceeds Coke believed he was owed. (Tr. 103-

104).   In an act of startling brutality, Coke had his men “tie

up” Tall Man in the jail, and Coke murdered Tall Man with a

“power saw”, dismembering Tall Man so that when Cohen entered the jail shortly thereafter, Cohen saw “human remains .                . lots of blood, lots of feces, human feces, and hands and foots cut off

and a head cut off.”   (Tr. 104-105).

Coke murdered other individuals for “crimes” ranging from stealing his (Coke’s) motorcycle (Tr. 119), to “stealing” extortion payments collected from local businesses at Coke’s request (Tr. 110), to shooting a child in the leg (Tr. 113) Indeed, Cohen testified that Coke once tried to kill Cohen

1 Attached to CW-1’s Declaration are two photographs, Exhibits E and F, that CW-1 believed resembled the jail.                     (CW-1

Decl.    23 n.3).   In an unsolicited letter dated January 23,

2012, the author similarly refers to Coke’s “informal jail”

where, among other things “Coke is known to use an electric chain

saw and a hot iron as implements of torture on women.”

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himself in the jail, after Cohen fought with and disrespected

Coke’s Aunt. (Cohen escaped).2     (Tr. 132-135).   Coke used a

hatchet to commit two of these murders, (Tr. 108, 122); in others he used a firearm (Tr. 111, 117).             In one instance, involving the theft of Coke’s motorcycle, the victim’s Mother and Aunt begged Coke to spare the victim’s life, offered to pay for any damage to the motorcycle, and explained to Coke that the victim had mental problems.         (Tr. 121). Coke simply told them to go away, and murdered the individual who had stolen his motorcycle with a hatchet. ( Id.). After committing these murders, Coke left the bodies behind to be disposed of by his soldiers, who stuffed them in “a keg,” in “a food barrel,” or just “dumped [them) down in

the street”.   (Tr. 106, 109, 112, 117, 124).3

Cooperating Witness 1’s sworn Declaration described, among other things, a murder committed in a similar manner by Coke. Cooperating Witness 1 related that Coke murdered Cutter, one of Coke’s own soldiers, after Cutter repeatedly stole money to

2 Cohen’s account of this incident is corroborated by an intercepted telephone call on September 9, 2006, in which Coke explained to a U.S.-based co-conspirator that “when the man ran out, you how much man was strapped [armed).                                      And the man went straight up the gully and no man ran after.”                   (Tr. 169-170, Government Exhibit 1TR at page 10).

3     The unsolicited letter dated January 23, 2012 that is referred to in footnote 1, above, also makes reference to this method of disposing of bodies, stating, in seeking a sentence

that will keep Coke away from Jamaica “forever” that “[s)ince Mr. Coke left   . no young girls have been found dismembered in barrels.”

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support a crack habit.   (CW-1 Decl.    24-25).   Coke directed other soldiers to bring Cutter to Coke’s Office in Tivoli Gardens, where Coke confronted Cutter with reports that Cutter was stealing and noted that Cutter was a repeat offender.                (CW-1

Decl.    24).   Other soldiers then escorted Cutter into the jail, and Coke followed, with a chrome handgun in his front pants pocket.      (Id.).     Cooperating Witness 1 could not see inside the jail, but Cooperating Witness 1 heard Cutter shouting and pleading “no Bossy!” and then heard an explosion that sounded like a gunshot.                  When Cooperating Witness 1 later entered the jail, he saw Cutter bleeding from his groin area, and later learned that Cutter had died that same day. (CW-1 Decl.    25).

A number of unsolicited letters describe other murders

committed by Coke.   In a letter dated September 2, 2011, addressed to this Court, a resident of Western Kingston asserts that Coke is “personally responsible for the deaths of hundreds of Jamaicans, including my son.   .[who] was sixteen years old when he was killed by Shower Posse gunman.” In a letter dated September 26, 2011, addressed to this Court, a United States

Citizen, born in Jamaica in 1947, writes that “Coke has dedicated his life to killing and exploiting poor black youngsters from Jones Town, Tivoli, Rema and Denham Town.”                      Cohen testified about all of these locations, and the wars that occurred between the various communities in Kingston. (Tr. 48).                                         Another writer, in a

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September 2, 2011 letter to this Court, describes Coke as the “embodiment of evil” who has “killed people in America, Europe and the Caribbean.”      The Government has not requested these letters and indeed has had no contact with the authors.     The Government is not able to fully investigate, now, the many murders, committed in Jamaica, that the letters describe. But

the letters are vivid and specific, and their descriptions of the

violence that Coke visited upon the letter-writers and their families are closely consistent with the sworn testimony and statements received at the hearing.                              The testimony and statements were principally from members of Coke’s Organization- these letters give voice to just a few of Coke’s victims and reflect

the dreadful impact of his violence on their lives.

Fourth, because Coke’s soldiers effectively eliminated law enforcement’s access to and control over Tivoli Gardens, Coke (like his father before him) assumed responsibility for fielding complaints within the community – ranging from claims of theft to domestic disputes.     (CW-1 Decl.      21). In adjudicating these matters and imposing “punishments” consisting of beatings and shootings, Coke abused and terrorized the residents of Tivoli Gardens.           For example, Cohen testified that at Coke’s direction

he (Cohen) beat with baseball bats individuals accused of

stealing.   These individuals were so badly beaten that they could not walk out of the jail after the beatings – including a man

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later determined to be innocent.   (Tr. 101-102).   Similarly, Cooperating Witness 1 recalled an array of punishments imposed on men and women for relatively minor offenses such as domestic disputes, including beatings with bats or the butt of a firearm

so severe that they required hospitalization. (CW-1 Decl.    22)

Theft was punished by a shooting – usually in the hand or the foot.     (CW-1 Decl.               23).

Fifth, Coke controlled the community financially by

extorting local businesses. As a result of Coke’s control over the community, and his well-founded reputation for brutal acts of violence, Coke easily extracted “taxes” from local businesses – payments that were collected by members of his Organization.

Cohen testified that people working in the markets in the area

paid a “tax” – a “certain percentage” – to Coke. (Tr. 66). Consistent with Cohen’s testimony, Cooperating Witness 1’s sworn declaration explains that vendors working in Coronation Market were required to pay a fee to Coke, in addition to the fees imposed by the Jamaican Government.      Coke tasked a senior member of the Organization with tax collection, and anyone who failed to pay the fee would be prohibited from selling in the market area, and potentially subject to physical harm. (CW-1 Decl. 38). Witness 2’s sworn Declaration provides additional corroboration that Coke engaged in extortion.                                  Witness 2 came to know a taxi driver who operated in the vicinity of Tivoli Gardens and the

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Coronation Market area. The driver told Witness 2 that he had to pay a tax of $500 (Jamaican) two times per week to “Shortman’s boys.” (W-2 Decl. 11).        (Shortman is one of Coke’s aliases). Witness 2 explained that in 2008 or 2009, she learned from a friend of the taxi driver that the driver had been killed.

Witness 2 was told that when “they” came to collect the $500 tax, the driver said he did not have the money and was shot by “them” immediately. (W-2 Decl.               12).

Finally, as the hearing testimony and other evidence

established, Coke’s control over the Tivoli Gardens community­ and his well-deserved reputation for ruthless violence – facilitated his control over members of the Organization who relocated to the United States.     Those individuals were required to contribute to the “System” from the United States – to send money, firearms or goods to Coke in Jamaica.      (CW-1 Decl.    5). Cooperating Witness 1 explained that he personally discussed this “System” with Coke and was aware of it by virtue of living in Tivoli Gardens.     (Id.).      As Coke acknowledged at his guilty plea, from his base in Jamaica he directed the purchase of firearms and the sale of narcotics in the United States, and people in the United States took direction from him and they sent drug proceeds to him. (Plea Tr. 24-25).

If Coke’s U.S.-based associates failed to deliver what he

asked, their Kingston-based relatives were at risk of harm from

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Coke and his Organization. Cohen testified that Coke held meetings of senior members of the Organization, where Coke said that those individuals from the community in the United States needed to send back “clothes, food, guns, bikes” to the community.”        (Tr. 90).   Cohen explained that “if the soldier come to the States, don’t comply with the system, like send back stuff for the system, then family got to leave” or their families could be harmed.   (Tr. 91-92).             Consistent with Cohen’s understanding

of the System, Cooperating Witness 1 witnessed Coke order his

soldiers to shoot an elderly couple whose grown children trafficked narcotics in the United States and refused to send money to Coke in Jamaica. Cooperating Witness 1 was present when Coke gave the order, and when the soldiers returned shortly thereafter to confirm they had shot the couple. Cooperating Witness 1 learned that the husband had died, but that the wife

had lived. (CW-1 Decl. <JI      26) . 4

III.     CONCLUSION

As the evidence adduced at the hearing makes clear, Coke used his financial resources and a steady supply of firearms to arm and direct a private army that controlled – through violence and intimidation – the population of Tivoli Gardens and the

4 As to these circumstances, and throughout, it is apparent that the testifying witnesses and sworn declarants are credible because their recollections are detailed and specific and the events that they describe are consistent, and inter-locking.

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surrounding area.   Because Coke’s soldiers rendered the community essentially off-limits to law enforcement, Coke assumed the role of judge, jury and at times, executioner.                         Coke authorized those crimes from which he profited, such as armed robbery and

narcotics trafficking, and punished with truly brutal and barbaric violence transgressions such as theft, the loss of a firearm or disrespect. As a result, Coke tightly controlled the Tivoli Gardens community – a control that allowed him to extend his authority to Organization members who relocated to the United States and left their families behind. Those U.S.-based Organization members, often themselves armed and violent

narcotics traffickers, contributed drug proceeds, goods and most importantly firearms, to Coke in Jamaica, lest their families in Kingston be victimized by his Organization.                             With those contributions, Coke further strengthened his hold on the local community, in a cycle of violence and control that spanned two countries and almost two decades and left numerous victims in its wake.                          Coke’s criminal conduct- its length, extent, and

brutality – clearly calls for the statutory maximum sentence of

twenty-three years’ imprisonment. The Government respectfully

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submits that a twenty-three year sentence is sufficient but not greater than necessary to serve the goals of Title 18, United States Code, Section 3553(a), and should be imposed in this case.

Dated:     New York, New York

June 7, 2012

Respectfully submitted, PREET BHARARA

United States Attorney for the

Southern District of New York

By:              i2L

JOCELYN E.

——————-

STRAUBER

JOHN T. ZACH

Assistant United States Attorneys

Tel: (212) 637-1034/2410

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CERTIFICATE OF SERVICE

JOCELYN STRAUBER deposes and says that she is employed in the Office of the United States Attorney for the Southern District of New York, and that, on the 7th day of June, 2012 she caused to be served a copy of the within Government’s Post- Hearing Memorandum on Stephen Rosen, Esq., and Frank Doddato, Esq., bye-mailing the document to [email protected] and [email protected].

I declare under penalty of perjury that the foregoing

is true and correct.   28 U.S.C. § 1746.

———-LH ———————

JOCELYN E. STRAUBER

Dated:    June 7, 2012

New York, New York

St Jago High School · Statements in Response to Coke Evidentiary Hearing

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• Any actiVIties  that  ma’l  ha-,e bf?en conduc t ed ours Cle or these gu!del.nes  nc:l thest hcwe t>een reprene: d DS being condu·t:ed  by,or n behalf  of, the school ‘s administratiOn are m•>rl!llr  sentatio.,s.

• The students.,   a, Jtdmlnistration 6ftd  ost  studentof St. J.11g o High Schooll ook forward to the cartinuation of

mt ny  m:>re d ecades cf  ewr JJpnc:e .

·End-ofTerm

• Mr .a:td M:; St J.:icr o 2012

• founders Day

• Head StudtDts’  Splrll Qay

• eovs‘ ,nd G!r\s’

cnamoJoosb!p

• Ptan Bdcvs 2012

statement re:  Anthony Brown

• Our  records  indicate thAnthonBrcwn  Wl!S o s.tJc.ent at S.t. Jaga High School bt!tween  \.985 and 1989.                 He Y- OIS  a rnem er or the winning 1987 Boys C amploi\Shlp te,m.

• Ourir19 the 1 90’s Hr.  Drown acted vrc:>h..antar nv e& JJS:S!st ant c ottch to the  sd’lool’S tll!ck end Reid prO(Iramme.   Hr.

6r-O’ovn w”s r t\!er  app:;,int fd nor employed  to the ;choolif”l  clny ::aoaci .

•  At no  time was  Mr. Btvwn i!Skd  to  ssist ¥ tth the pocess of opply ing for  visitor-.safor our itudent:s  t rave.Jing  ro

Ihe USA  on  SChO<llbv siness.

•  An offici! poslt J on was for malty taken  to bri19 cessativn  to r. Brown’s  I nvolvement .at tht chool.

Office  of the Prl elp•l

‘4al’ 1, lOll

Please keep St Jagc always in yvvr thooghts 3MI in your pray ers.

WebSite: ht tp•llwy.tw stlago  core .

Case 1:07-cr-00971-RPP    Document 386     Filed 06/08/12   Page 2 of 2

The Honorable  Robert  P. Patterson

June 7, 2012

Page 2

$1,500,000.  Accordingly, the Government respectfully  requests  that the Court enter an order of forfeiture in the amount  of $1 ,500,000 against Coke.

Respectfully submitted, PREET  BHARARA

United Stas  Attorney

/

Assistant  United States  Attorneys (212) 637-1034/2410 (phone) (212) 637-0128 (fax)

cc:        Defense Counsel

(By Electronic  Mail)

ORIGINAL PDF

http://www.olintja.com/docs/coke/CHRISTOPHER_MICHAEL_COKE_Sentencing_Documents_381-387.pdf