Hector Sabu Monsegur Sentencing Order and Background

Federal Defenders
S u t h ern Di s~ ~ t
52 Du ane S t reet -10t h Floor, New York, NY 10007
O F NEW YORK , 1 N C .
Tel: (212) 417-8700 Fax: (212) 571-0392
Davi d E. Pat t on
Execu t i ve Di rect or
VIA HAND DELIVERY
Honorable Loret t a A. Preska
Ch i ef Uni t ed S t at es Di st ri ct Ju dge
S ou t h ern Di st ri ct of New York
Uni t ed S t at es Di st ri ct Cou rt
500 Pearl S t reet
New York, New York 10007
S ou t h ern Di st ri ct of New York
Jenni fer L. Brown
At t orney-i n-Ch arge
May 23, 2014
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Re: Uni t ed S t at es v. Hect or Xavi er Monsegu r
11 Cr. 666 (LAP)
Dear Ch i ef Ju dge Preska:
We wri t e on beh alf of ou r cli ent , Hect or Monsegu r, t h e
defendant i n t h e above-referenced case, wh o i s sch edu led t o be
sent enced by t h e Cou rt on May 27, 2014. We joi n i n t h e government 's
ant i ci pat ed requ est t h at t h e Cou rt sent ence Mr. Monsegu r pu rsu ant
t o t h e fact ors set fort h i n U. S . S . G. 5K1 . 1 (a) (1) - (5) i n li gh t of
h i s "ext raordi nary" assi st ance. For t h e reasons set ou t more fu lly
below, we respect fu lly requ est t h at t h e Cou rt i mpose a sent ence of
t i me served.
On Au gu st 15, 2011, before You r Honor, Mr. Monsegu r pled
gu i lt y, pu rsu ant t o a cooperat i on agreement , t o a t welve-cou nt
i nformat i on wh i ch ch arged h i m wi t h vari ou s offenses relat ed t o
compu t er h acki ng. He was det ai ned at t h e MCC from May 25, 2012, u nt i l
December 17, 2012, at wh i ch poi nt h e was re-released on bai l. S i nce
t h at t i me, h e h as compli ed wi t h all of t h e condi t i ons of h i s release.
Asa resu lt of Mr. Monsegu r's `ext raordi nary cooperat i on, "
t h e government h as i nformed t h e Cou rt t h at i t wi ll move at sent enci ng
for t h e Cou rt t o sent ence Mr. Monsegu r i n li gh t of t h e fact ors
cont ai ned i n U.S .S .G. 5K1.1(1)-(5), and, pu rsu ant t o 18 U.S .C.
3553(e), wi t h ou t regard t o any mandat ory mi ni mu m sent ence. S ee Exh .
A at 18 (Gov't Mot i on, fi led May 23, 2014) . In ant i ci pat i on of t h i s
mot i on, t h e Probat i on Depart ment recommends a sent ence of t i me
Case 1:11-cr-00666-LAP Document 32 Filed 05/27/14 Page 1 of 13
Hon. Loretta A. Preska
May 23, 2014.
Chief United States District Judge
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Re: United States v. Hector Xavier Monsegur
11 Cr. 66.6 {LAP)
served.l
This is an extraordinary case in several respects,
including the round-the-clock, all-consuming nature.ofMr.
Monsegur' s cooperation, the danger it has posed to him and his family,
and the enormous benefits - in terms of national security,
infrastructure protection, and losses averted - that stemmed from
his cooperation.
Given the nature, extent, and results of Mr. Monsegur's
cooperation, as well as the repercussions he and his family have
suffered as a result, the defense submits that a sentence of time
served is the just and appropriate sentence in this case. Any
additional period of incarceration or supervision would be more than
necessary to affect the statutory sentencing goals.
Background
Mr. Monsegur was born in in
and was
raised in the Jacob Riis housing project on Manhattan's Lower East
Side. He was raised primarily by his grandmother. His mother had
left him with his father when Mr. Monsegur was a young boy a.nd, when
he was
his father was sentenced to state prison. Mr.
Monsegur's aunt also was sentenced to prison as part of the same case.
She later returned to prison, leaving her two young daughters in the
care of her mother, Mr. Monsegur's grandmother, as well.
In .. ~
Mr. Monsegur's grandmother died from
complications related to _
Watching his
grandmother struggle as her health declined was extremely difficult
for Mr. Monsegur. As she got sicker, he withdrew into their
apartment, and became more isolated. When she died, it fell to Mr.
Monsegur to care for his two young cousins, then
and
dears
old. That he would care for the girls wasn't even a question. As
his father tells the Court, Mr. Monsegur "has always helped the
1 The Probation Department also recommends that the Court impose a three-year term of supervised release. For the reasons discussed more fully below, the defense Submits that a term of supervised release is not necessary to affect the statutory sentencing objectives and, in this case, would expose Mr. Monsegur to additional danger. In light of all of the facts and circumstances of this case, the defense submits that a sentence of time served is the just and appropriate sentence.
May 23, 2014 Chief United States District Judge
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Re: United States v. Hector Xavier Monsegur ~.
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family." See Exh. B (Letter from H
M
). His brother M
explains to the Court that Mr. Monsegur is "the backbone
to our family." See Exh. C {Letter from M
).
The girls were the most important thing in his life. He
took their care and well being very seriously. He was involved in
their education, walking them to and from school and helping with
their homework. The agency that oversaw the girls' foster care
placement with Mr. Monsegur regularly evaluated their situation and
confirmed that Mr. Monsegur was doing an admirable job as a surrogate
parent. He looked out not only for his girls, but for other kids
in the neighborhood. As
tells the Court, Mr. Monsegur
"always looked out for" her kids and made sure they got to school,
too. See Exh. D (Letter from
~) . He struggled, though.
His grandmother's death had come close on the heels of him losing
his job. He struggled to pay the rent and to feed and clothe the
girls, and caring for them made it hard for him to look for a job.
Tf Mr. Monsegur had lived somewhere else, if he had attended a well-funded suburban school with a computer science program or had had the money to attend college, things might have
been much different. With his self-taught computer skills and a
college degree, he might have maintained a lucrative jQb that would
have enabled him to have child care assistance so he could work and
care for the girls.
But Mr. Monsegur was on the Lower East Side, spending his
days in a run-down apartment while waiting to pick his young cousins
up from schcol . He was angry and frustrated and desperate . He was
also politicized and extremely talented, and, over time, he got more
deeply involved in online activism. For example, during the Arab
Spring, when he learned that governments were cutting off citizens'
Internet access, he did what he could to enable access . He was also
committed to exposing hypocrisy by uncovering security weaknesses.
It frustrated him to see private industries raking in millions of
government dollars while not actually providing the security services they boasted about. As he has candidly admitted, scme of
his online activity was illegal. In his desperation, for example,
he paid for household expenses with stolen account information and
broke into websites to purchase items for his family. In an attempt
to draw attention to their skills, and an immature attempt to get
May 23, 2014.
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some laughs, for example, Mr. Monsegur and his group posted a fake
news article on PBS.org asserting that.the rapper Tupac was alive
and well.
On June 7, 2011, almost
to the day after his
grandmother's death, late at night, FBI agents knocked on the door
of his grandmother's apartment on the Lower East Side. As the
government has explained to the Court, "Mr. Monsegur admitted his
criminal conduct and immediately agreed to cooperate with law enforcement." Exh. A at 6. It was not a difficult choice for him.
However strong his political beliefs, his family came first. He
would do whatever he had to do to protect the girls and avoid their
placement in the foster care system. After this night, his life,
and the lives of his .family members., would never be the same.
Mr. Monsegur began working around the clock for the FBI.
Sometimes, he would sit in computer rooms with agents for eight, ten,
twelve hours at a time, reviewing logs and explaining his methods
of researching vulnerabilities. Other days, he would sit for hours
with prosecutors and agents from around the country, giving information he had on past online activity and helping them understand what had occurred in various computer intrusions they were
investigating. This work not only allowed law enforcement to
"resolve open investigations into several computer intrusions," see
Exh. A at 9-10, but also taught law enforcement information that would
assist in future investigations. These full day meetings would end
only when he had to leave to pick the girls up from school.
Ir. addition to providing information about past online
activities, Mr. Monsegur worked proactively for the FBI. Because
the targets of the FBI's investigations often were in other countries, this proactive work required him to work overnight and
then spend the next .day reviewing the work with agents.
The work
kept him up at night and bled into every waking hour. He was truly
on the clock 24 hours-a-day. The government installed key-logging
software on his computer so it could monitor every letter he typed
and even installed a camera at his apartmen~ to record his activities.
For months, he maintained this virtually non-stop activity on behalf
of the government, while still trying to maintain some semblance of
order for the girls.
May 23, 2014 Chief United States District Judge
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Re: United States v.. Hector Xavier Monse r
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In August, 2011, Mr. Monsegur consented to the filing of an information that included charges from five districts around the country. He waived venue on the out-of-district charges and pled .guilty pursuant to a cooperation agreement. At the time, he waived indictment, the government informed the Court that Mr. Monsegur had "already incurred a significant amount of personal risk by deciding to cooperate." See Exh. E at 8 (Excerpt from August 5, 2011, Transcript).
Far six months following his plea, Mr. Monsegur kept up his round-the-clock proactive cooperation. Over the course of his cooperation, his helped secure evidence that led to the
identification of his co-conspirators. He also helped avert national and international crises. For example, information he obtained permitted law enforcement officials to avoid a take-over of the water supply, system in a major U . S . city and of a major foreign energy supply company. He helped law enforcement prevent attacks on organizations such as ~ and the
as well as the- United States Courts anc~ the United States Congress. He also enabled law enforcement to determine that an alleged take-over of the United States energy grid was a hoax. His work not only enhanced national security, but it prevented millions, if not billions, of dollars in loss.
Then, on March 6, 2012, Mr. Mons~egur's world came crashing down again. In a multi-national law enforcement effort, based on information he had provided, agents affected the arrests of his LulzSec co-conspirators and others. In part because of the "important deterrent effect" law enforcement hoped to gain through news of Mr. Monsegur's arrest and cooperation, the government requested that documents related to Mr. Monsegur's plea be unsealed and "his work as a cooperating witness was made public shortly after the arrest of the core LulzSec members." See Exh. A at 17. The government's press release announcing the arrests also announced Mr. Monsegur's arrest and plea. See Exh. F (USAO Press Release, March 6, 2012) . Although the press release did not confirm Mr. Monsegur's status as a cooperator, government officials did so i~ off-the-record interviews with the press. Early on the morning of March 6, news
pieces that had been prepared in advance,, chronicling Mr. Monsegur's life and the details from the night of his arrest known only to those who were present, appeared online. By the end of the day, news outlets
May 23, 201. 4
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around the caorld had his picture and his story on the front page'.
The next day, things got even worse. Mr. Monsegur's
cooperation was all over the morning papers . As the government we~ _1
knows, the scrutiny Mr. Monse~ ur and his family were subj ected to
was something that few cooperating witnesses must cope with until
shortly before trial, if at all. But the scrutiny was not merely
unpleasant. It threatened to have serious consequences for the
family. Early on the morning of March 7, Mr. Monsegur was- contacted
b~ the agency that oversaw the girls' foster care placement. This
was his worst nightmare, the very thing he had sought to avoid through
his cooperation. The agency told him that it was coming to get the
g,;_rls and was possibly going tc remove them from his custody and place
them with strangers. The family converged at the Federal Defenders
office and tc;gether we traveled to the agency to explain the. situation
and plead for the girls ~ o remain with family. For several frantic hours, officials held closed-door and telephone meetings and the
girls were subj ected to examinations and evaluations. Finally, that
evening, arrangements were approved that accelerated the return of
the girls to the custody of their mother, who had recently been
released from prison.
'
Following the barrage of publicity'; Mr. Monsegur could not even return home. His face was plastered all over the Internet. The personal information of his family members, including their home
addresses and social security numbers, were distributed online.
While the te^ hnical details of his hacking .activities may have passed under ti~ ~ e radar on the Lower East Side, the concept of "snitching"
did not. Shortly after news of his cooperation was made public, the
NYPD conducted a drug raid near Mr. Monsegur's home. This NYPD
activity had nothing whatever to do with Mr. Monsegur. But he was accused of snitching in relation to.that raid and he and his family
were threatened. Mr. Monsegur's younger brother; who stood by his
side every day throughout the whole ordeal, was threatened and
actually physically attacked because of Mr. Monsegur's cooperation. As the government explains to the Court, "the threat to [Mr. ] Monsegur
and his family became severe enough that the FBI relocated [Mr.]
Monsegur and certain of his family members." Exh. A at 17.
His months of round-the-clock work and the crushing
publicity took its toll on Mr. Monsegur. In the spring of 2012, Mr.
May 23, 20.14
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11 Cr. 66~ (LAP)
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Monsegur made some unauthorized online posts and the government moved for his remand. He was detained at the MCC from May 25, 2012, until December 17, 2012, at which point he was re- released on bail. While at the MCC, _he tried to make the most of his time. He read
voraciously: He. created and taught afive- week Computing Essentials course designed to teach other incarcerated persons the digital tools needed to analyze, synthesize and evaluate information. Attached as Exhibit G is a copy of the syllabus he created.
Since his release in December 2012, Mr. Monsegur has been fully compliant with the terms of his release . He has spent eighteen months waiting in limbo for his sentencing, attending occasional meetings with counsel and with law enforcement. He has looked for work but repeatedly has been rejected, due to lack of job openings and this open case. When applying for jobs, he has been questioned about fiis co~~peration. He currently is prohibited by his conditions of release from using a computer, and this restriction has greatly hampered hip job search ability.
Mr. Monsegur has incredible computer skills that he can put to good use. He would like to use his skills as both a systems administrator and as a teacher. As his friend
puts it, Mr. Monsegur is "truly a great asset to the human race as a whole. " See Exh. H (Letter from
).
But he will forever be marred by this case. Even this week, while he was at a gas station with a friend, Mr. Monsegur was identified by drivers in the next car who called out to him while looking at information about him on their smartphones. - The
extraordinary publicity that came along with his cooperation will follow him forever.
A Sentence of Time Served is Appropriate
In Light of Mr.~Monsegur's "Substantial Assistance"
As the government notes in its May 23, 2014 letter, in arriving at the appropriate sentence fora defendant who has provided substantial assistance, Section 5K1.1 of the Sentencing Guidelines encourages Courts to consider, inter alias the significance and usefulness of a defendant's assistance; the truthfulness,
May 23, 2014
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11 Cr . .6.66 {I~Ap)
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completeness and reliability of the information provided; the nature and extent of th:e assistance; any injury or risk of injury suffered by the defendant or his family; and the timeliness of a defendant's assistance. The defense submits that an individualized assessment of these factors counsels in favor of a sentence of time served.
Mr. Monsegur's assistance was significant and useful. Indeed, the government describes it as `extraordinarily valuable and productive." Exh. A at 13. He provided "unprecedented" access to the targets of law enforcement investigations through both
"historical information and substantial proactive cooperation." Id. His efforts led directly to the identification, prosecution and convictions of seven individuals as well as the identification and prosecution of an eighth who awaits trial. Id. at 14-15. While these arrests and convictions were "extremely important to the Government;" they "..only partially convey[) the significance and utility of [Mr. Monsegur's) cooperation." Id. at 15. By providing infc~rmation~to laic"enforcement regarding on-.going or threatened computer hacks as well as existing vulnerabilities in computer systems, "the FBI was able to thwart or mitigate at least 300 separate hacks." Id. As the government explains to the Court, "[t)he amount of loss prevented by [Mr. ] Monsegur' s actions is difficult to fully quantify, but even a conservative estimate would yield a loss prevention Figure in the millions of dollars.." Id. Perhaps more important than the dollar value of Mr. Monsegur's cooperation, information he provided allowed law enforcement to proactively
secure vulnerabilities in "critical infrastructure," including the water supply of a major U.S. city and the supply chain of a foreign energy supply company. Finally, the significance and utility of his cooperation will last far into the future. For example, the last piece of his cooperation involved repeated real-time efforts to secure evidence that firmly links a subject (whom multiple countries have expressed interest in prosecuting) to the solicitation of cyber attacks on foreign government computer systems. Although these efforts -have not yet led to prosecution of the subject, they yielded `significant and valuable" evidence. Id: at 16.
NIz. Monsegur provided the government with truthful,
reliable, and complete information. As the government explains in its letter, ~Mr. Monsegur was "fully candid" with law enforcement and provided information that was "consistently reliable and complete,
May 23, - 201, Chief United States District Judge
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Re: United States v. Hector Xavier Monse ur
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corroborated by documents and electronic files, as well as by statements from other witnesses." Exh. A at 16. T he candid
information he provided regarding his own criminal conduct went beyond ' information that had been available to the government and included information about offenses the government likely would have remained unable to prove, and may not even have discovered, absent his candor.
T ie nature of Mr. Monsegur' s assistance was varied and extensive, both in time - it lasted three years - and in subject matter - he worked with agents and prosecutor from various districts to close pending investigations, prevent future attacks, and gather
information that lead to several arrests and convictions. As the government tells the Court, Mr. Monsegur' s "cooperation entailed many multi- hour meetings with FBI agents that :extended. into the late evening and early morning hours." Exh. A at 16. As discussed above, he not only sat with law enforcement to review historical
information, he engaged in round- the- clock online activity at the direr_tion of laic enforcement. His activity had to be precisely coordinated with law enforcement officials in different cities and, at times, different countries. He sat through lengthy proffer sessions with law enforcement officials from around the country, often being asked to spend hours and hours reviewing information rye had previously discussed with officials from other jurisdictions.
T he defense submits that the publicity surrounding Mr. Monsegur' s cooperation makes the nature and extent of his cooperation unique. Most cooperators in this district have their plea
agreements sealed and their cooperation is not revealed until either the eve of a trial at which their testimony is required or their own sentencing proceedings. Mr. Monsegur' s cooperation was very different. ' More than two years ago, Mr. Monsegur' s cooperation was publicly revealed, not because his testimony was needed or for sentencing purposes, but for law enforcement purposes. As mentioned above, Exhik~it F is a copy of the press release issued by the United States Attorney' s Office for the Southern District of New York on the morning of the arrest of several of Mr. Monsegur' s
co- conspirators. Although the press release did not name him as a cooperator, it did single him out as having pled guilty months earlier and informed the press that the documents related to Mr. Monsegur' s plea had been unsealed. T hese documents, of course, revealed his
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cooperation: This public outing of Mr. Monsegur's cooperation was unprecedented in our experience. Where generally the government does all it can to protect the identities of cooperators, here, the government sought a deterrent effect by allowing Mr. Monsegur's cooperation to be publicized. While all cooperators understand that there may come a time when their cooperation is no longer secret, this case was unique in that the government itself participated in his unveiling.
AJ_1 of Mr. Monsegur's cooperation was undertaken at great risk to him and his family.2 All of his family gave up a certain amount of privacy as a result of the camera that was installed at Mr. Monsegur` s home. Attached as Exhibit J is an example of the type of iizformation about Mr. Monsegur's family ..t hat has been published online. Although the information released online has not always been accurate, it often has been... Mr. Monsegur's own residence, as well as the home addresses of
was released online. His __ .._
..
One of
was cornered by a reporter and questioned until
caved and gave the reporter what the reporter came for:. information related to Mr. Monsegur and his arrest. Of course,
chid not fully understand the details of Mr. Monsegur's case, but still caas subjected to questioning. As the government mentions in its letter to the Court, the girls Mr. Monsegur cared for also iaere approached by the press. A reporter actually entered their school and attempted to question them about Mr. Monsegur, in clear violation of the school security policy. These events were traumatic for the whole family, not only for the invasion of privacy they represented, but also for the fear it placed in everyone: i.f the kids in the family were being hounded in their elementary schools and iri apartment hallways, no one felt safe. Sadly, it is this fear that deters Mr. Monsegur's family from being by his side in Court. They don't want to subject the children to further publicity.
0f course, the risk to Mr. Monsegur and his family was far
2 In light of the continuing risk of retaliation against Mr. Monsegur
and his family, including the young children, the defense requests that this letter
and the documents associated with Mr. Monsegur's sentencing be filed under seal.
~ ~ ~ ~ ~ ~ 3r ~ ~ ' ~ ~ ~ ~ Chief Unitea States District Judge
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Re: United States v. Hector Xavier Monsegiar
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more dangerous than that posed by certain members of the press . One of Mr. Monsegur' s brothers was physically assaulted at a bar in New York in retaliation for Mr. Monsegur' s cooperation. This
retaliation was not on behalf of any particular person against whom Mr. Monsegur cooperated, but was retaliation for his role as a cooperator in general. And as recently as this spring, front-page news coverage has contained erroneous reports regarding Mr. Monsegur and attacks on foreign governments. This type of publicity, even when it is incorrect., exposes Mr. Monsegur to real danger and, sadly, shows no sign of abating. This all underscores the fact that the publicity surrounding his cooperation placed Mr. Monsegur at unusual risk.
Finally, Mr. Monsegur' s cooperation was timely. 1t began immediately after agents approached him, .even before he had a chance to consult c~ ~ ith an attorney. As the government explains in its motion, Mr. Monsegur' s timely decision to cooperate prevented the destruc4ion of evidence, allowed the government to develop the evidence necessary for several successful prosecutions, helped prevent and mitigate hundreds of hacks, and established proof that a significant subject of global law enforcement efforts had been soliciting cyber attacks against a foreign government. Exh. A at 18. Had he not made the decision to cooperate and resumed his online activities immediately, none of this may have happened. His
"immed~ .ate decision to cooperate was thus particularly important." Id.
Mr. Monsegur has been punished tremendously for his offenses. Next week will mark three years that he has been under law enforcement supervision. He served seven months at the MCC. 3 He lived under constant law enforcement surveillance for months. His conduct since his release from custody in December 2012 makes clear that no further period of supervision is necessary. Given the threatened retaliation he has faced, as well as the relentless pursuit by the press, requiring Mr. Monsegur to report to probation
3 As the government details in its motion, Mr. Monsegur' s LulzSec
co-conspiratoxs received sentences ranging from probation to 30 months'
incarceration. The individual the government describes as "the FBI' s most wanted
cybercriminal in the world," who had a similar, prior conviction, received a
sentence of 120 months' incarceration following a plea to a charge that covered
conduct that cccurred after Mr. Monsegur' s arrest.
Hon. Loretta A. Pxeska
May~23, 2014
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for supervision would only continue. to place him at risk. It would
also be greater punishment than is necessary. He has worked
tirelessly to right his wrongs; to repay his debt to society. No
further punishment is necessary to, affect the statutory sentencing
objectives..
Given the particular circumstances of this case, and in
light of the factors contained in U.S.S.G. 5K1.1, the defense
submits that a sentence of tune served is the appropriate sentence
to affect these statutory directives.
Conclusion
Mr. Monsegur has provided tremendously valuable assistance to the government. Governments around the world will
benefit from his work for years to come.. He helped avert at least
millions of dollars worth of damage to computer systems around the
world.' He cave everything he had had - all of his time, all of his
energy, all of his skills - to righting his wrongs, all while
subjecting himself and his family to retaliation and public
humiliation that will follow them forever.
He _remains a- very dedicated and loyal man, one who believes
that the Internet can be used to enhance freedoms and share knowledge.
He has the skills to help any company or government secure their
systems and prevent intrusions. His own Life has been on hold for
the three years since his arrest. A sentence of time served will
acknowledge the extraordinary substantial assistance Mr. Monsegur
provided and wi1.1 allow him and his family to move on to safer,
productive lives.
Hon. Larettu A. Preska
May 23, 2014. Chief United States District Judge.
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In light of all of the facts and circumstances of this case, the defense respectfully requests that the Court sentence Mr. Monsegur to time served.
Respectfully submitted,
G~
_ _ _ _
PEGGY CROSS.-GOLDENBERG
PHILIP WEINSTEIN
Assistant Federal Defenders
(212.) 417-$732/8744
cc: AUSA James J. Pastore, Jr.
Exhibit A
Case 1:11-cr-00666-LAP Document 32-1 Filed 05/27/14 Page 1 of 21
UNITED. STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .X
~~.p A
UNITED STATES OF AMERICA
- v -
11 Cr. 666 (LAP)
HECTOR X AVIER MONSEGUR,
a/k/a "Sabo,"
Defendant.
---------------------------- -----x
PREET BHARARA.
United States Attorney for the
Southern District of New York
Attorney far the United States
of,America
JAMES J. PASTORS, JR.
Assistant United States Attorney
_ _ Of Counsel _
_ _ ._ _ ._ _ _ _ _ _ _ _ _ ._ . _ _ _ _ _ _ ... _ . _ _ _ _ . _ _ . _ _ _ _ .. _
UNITED STATES DISTRICT COURT
SQUTHERN DISTRICT OF NEW YORK
---------------------------------- x
UNITED STATES OF AMERICA
-v - 11 Cr. 66b (LAP)
HECTOR XAVIER MONSEGUR.,
alkla "Sabu,"
Defendant.
-------------------- ---- - ---x
Preliminary Statement
The Government respectfully submits this memorandum in connection with the
sentencing of defendant Hector Xavier Monsegur, alk/a "Sabu" (the `defendant", or
"Monsegur"), which. is currently scheduled for May 2'l, 2014 at 11:00 a.m. In.its Presentez~ce
Report ("PSR"), the United States Probation Office {"Probation") correctly calculates that the
defendant's United States Sentencing Guidelines ("U.S.S.G." or "Guidelines") range is 259 to
317 months' imprisonment. Probation recommends a sentence of time served.. As set forth. in
more detail below, Monsegur was an extremely valuable and productive cooperator. Assuming
that the defendant continues to comply with the terms of his cooperation agreement, and
commits no additional crimes before sentencing, the Government intends to move at sentencing,
pursuant to Section SK1.1 of the United States Sentencing Guidelines ("Guidelines" or
"U.S.S.G.") and Section 3553(e) of Title 18, United States Code, that the Court sentence the
defendant in light of the factors set forth in Section SK1.1{a)(1)-(5) of the Guidelines, and
without regard to the otherwise applicable mandatory nr~inirnum sentence in #his case.
Statement of Facts
I. Monsegur's Involvement with Anonymous, LulzSec, and Major Cvber Intrusions
Throughout 2011, hackers affiliated with the "Anonymous" movement targeted hundreds
of computer systems around the world, hacking, disabling and at times ex~iltrating data from
those systems. Victims included news media outlets, government agencies and contractors, and
private entities. In approximately May 2011, Monsegur and five other members of Anonymous
formed Lulz Security, an elite hacking collective or "crew" commonly referred to as "LuizSec:''
Monsegur and the other core members of LulzSec typically worked as a team and had
complementary, specialized skills that enabled them to gain unauthorized access to computer
systems, damage,and exploit those systems, and publicize heir hacking activiries, This core
group, among whom, only Monsegur was.identified prior to the time Monsegur bean.
cooperating in the investigation, included:
Monsegur, a/k/a "Sabu," who served primarily as a "rooter," analyzing
code for vulnerabilities which could then be exploited;
"Kayla," who specialized, among other things, in "social engineering"
that is, manipulating others .into divulging personal information such as login.credentials;
"T-Flow," who served as an organizer, analyzing information provided by
members of the group in order to direct other members what to do next;
"Topiary," who served from time to time as the public face of
Anonymous and LulzSec, giving interviews to media outlets and writing public communications
on LulzSec's behalf;
' "Lulz" is shorthand for a common abbreviation used in Internet communications LOL
or "laughing out loud." As explained on LulzSec's website, LulzSec.com, the group's unofficial
motto was "Laughing at your security since 20i 1."
2
servers; and
Kayla.
"AVUnit," who provided computer infrastructure for the group such as
"Pwnsauce," who performed some of the same work as Mansegur and
Monsegur and many of these core LulzSec members were also part of another
Anonymous-affiliated group called. Internet Feds which, like LulzSec, engaged in major criminal
computer hacking activity.
Throughout 2011, Monsegur, through Lu1~Sec and Inter.~et Feds, engaged in several
major hacks into and thefts_ fr~ran tie computer servers. of United States and foreign corporations
and other entities including the fol]owing:
HB Gary.., Monsegur directly participated in the. hack of the computer
system of this Internet security firm in response to the .firm's claim, through one of its
investigators, that it had identified the members of Anonymous. This hack involved the theft of
emails and other company information.
Fox Television.. This hack resulted in the compromise of a database of
contestants of a reality TV show called "X-Factor." Monsegur downloaded data from Fnx that
he was able to obtain through his co-conspirators' unauthorized access to Fox's computer
systems.
Tribune Company. A journalist provided his credentials to Internet Feds
in the hopes he would be invited into private chats. Monsegur used the credentials to login to the
Tribune's systems and confirmed that the credentials could be used to gain.access to Tribune
Company's entire system.
3
~ PBS.org. Monsegur was a direct participant in this hack, which resulted in
the compromise of PBS's servers. and the defacement of its website. Monsegur helped identify a
vulnerability and then installed multiple "back doors" on PBS's system that is, he installed
programs that allowed others to later access the computer system.
Sonypictures.com. Monsegur was a direct participant in this hack, in
which the personal identification infoi~ nation of customers was stolen from Sony.
Sony BMG sites in Belgium, Russia, and the Netherlands. Monsegur
accessed and downloaded data from the Belgium and Netherlands sites, including the release
dates of records. Monsegur passed iufarmation about a vulnerability for the Russian. website to
other members ofLulzSec for exploitation..
Nintendo. Mo~ segur participated in a hack into Nintendo's cornputex
systems, pursuant to which files regarding the structure of Nintendo's computer systems wexe
downloaded.
Senate.gay. Monsegur had knowledge of, and conducted research for, this
hack of the Senate's website.3
Bethesda(Brink video game. Monsegur helped hack into Bethesda's
system, and downloaded information including a database containing personal identification
information.
In.fragardlCJnveillance. Monsegur was a participant in a hack of an FBI
affiliate in Atlanta, which resulted in the theft of confidential information.
z Following his arrest, Monsegur provided information that helped repair and remediate
this hack.
3 Monsegur provided the FBI with information about the vulnerability, which allowed it to
be repaired or "patched."
4
In addition to Monsegur's direct participation in the criminal hacking acrivity set forth
above, Monsegur had contemporaneous knowledge of other major cxiniinal hacking activity by
his co-conspirators, including hacks :into the computer servers of the Irish political party Fine
Gael; a U.S. online media outlet, a foreign law firm, _; and the Sony.
Playstation Network..
In addition to the six "core" members. identified above, several individuals were loosely.
affiliated with Monsegur and LulzSec, including, significantly, Donncha O'Cearrbha 1 , a/k/a
"palladium," and Jeremy Hammond, a/k/a "Anarchaos:' Hammond,_the FBI's number one
cybercriminal target at the time of his arrest in 201 2, was a prolific and technically skilled hacker
who launched cyber attacks against scores of governmental institutions, law enforcement.
organizations, and businesses, during a nearly year-fang rampage in which lie broke:intg these
victiu~s' computer systems, stole. data, defaced. websites, destroyed files and published. online the
sensitive personal and financial information of thousands of individuals all with the object of
creating, in Hammond's words, maximum "mayhem."
The hacks identified above constitute only a portion of the significant criminal computer
intrusions conunitted by Internet Fads, LulzSec, and their members, including Monsegur. As the
examples make clear, Monsegur and his co-conspirators indiscriminately targeted government
agencies, private companies, and news media outlets. In many instances, the harms inflicted on
these entities were significant, ranging from defacements of their websites to the exfiltration of
personal identification information of customers or employees of the entities; the costs associated
with repairing these attacks ran into the tens of millions of dollars. Monsegur was a key
participant in these Anonymous hacking crews, providing Y us technical expertise to aid in many
of the hacking operations.
5
II. The Complaint, Monsegur's Guilty Plea. and Subseguent Remandiand the
Guidelines Calculation
On or about June 7, 2011, the FBI. approached Monsegur in his home and questioned him
about his online activities. Monsegur admitted his criminal conduct and .immediately agreed to
cooperate with Iaw enforcement. That night, Monsegur reviewed his computer files with FBI
agents and provided actionable infornnaton to law enforcement. The next morning, Monsegur
appeared in court on a criminal complaint charging him with credit card fraud and identity theft,
and was released on bail, whereupon he inunediately continued his cooperation with the
Government, as described fuz-t1~ er below. Ott or about August 15, 2011, Monsegur appeared
before Your Honor and entered a guilty plea pursuant to a cooperation agreement with the
Government, Pursuant to.the tens of that agreement, Monsegur pled.,guilty to a 12- count
Supersed~ .ng Information, S 1 11 Cr. X66, charging him with nine counts related to computex
hacking; one count related to credit caxd fraud; one count of conspiring to commit bank fraud;
and one count of aggravated identity theft. In addition. to resolving the charges brought against
him in the Southern District of New York, Mansegur's guilty plea also resolved four cases filed
against him in other distaicts (including the Eastern and Central Districts of California, the
Northern District of Georgia, and the Eastern District of Virginia) which were transferred to the
Court under docket numbers 11 Cr. 693- 696, respectively.
On ox about May 24, 2012, the. Government. moved to revoke Monsegur's bail because he
made unauthorized online postings. Monsegur was arrested and remanded to custody the
following day. He was released on a revised bail package on or about December 18, 2012, and
has remained at liberty since that date. Accordingly, Monsegur has served approximately 7
months in prison in connection with this case.
6
In the PSR, Probation correctly calculates that the defendant's base offense 1 ev e1 is 7
pursuant to U.S.S.G. 2B1 .1 (a)(1 ) and correctly applies a 22-lev el enhancement in light of a loss
amount between $Zfl million and $50 million; a 6-lev el enhancement giv en that the offense
inv olv ed more than 250 v ictims; a 2-lev el enhancement for sophisticated means; and a 4-lev el
enhancement giv en that the defendant was conv icted of v iolating Title 1 8, United States Code,
Section 1 030(a)(5)(A). The defendant receiv es athree-lev el reduction far his acceptance of
resppnsibility, resulting in a total adjusted offense lev el of 38. (PSR ~ 43-59.) The defendant
has zero criminal _history points, and is therefore in Criminal History Category I. (PSR 60-
66.)
Based on an offense lev el of 38 and a Cri~unal Hisiory Category of I, the defendant's
adv isory Guidelines Range is235 to 293 months' imprisonment. (PSR ~ 96.) In addition, absent
the Court granting the,Gov ernment's motion pursuant to Title 1 8, United States Code, Section
3553(e}, the defendant would face a mandatory consecutiv e term of two years' imprisonment,
resulting in a total adv isory Guidelines range of 259 to 31 7 months' imprisonment.
III. Monse~ur's Cooperation
Monsegur
acknowledged his criminal conduct from the time he was first approached by
agents, before die was charged in this case. Monsegur admitted both to prior ci7minal conduct
about which the Gov ernment had not dev eloped ev idence, as well as his role in both Internet
Feds and LulzSec. Monsegur subsequently and timely prov ided crucial, detailed information
regarding computer intrusions con~xnitted by these groups, including how the attacks occurred,
This loss.. figure includes damages caused not only by hacks in which Monsegur
personally and directly participated, but also damages from hacks perpetrated by Monsegur's ca-
conspirators in which he did not directly participate. Monsegur's actions personally and directly
caused between $1 ,000,000 and $2,500,000 in damages. Had Monsegur not candidly
aclrnowledged his affiliarion with the groups that committed the other hacks, his adv isory
Guidelines range likely would hav e been substantially lower.
which members were involved, and how the computer systems were exploited once breached.
As set forth below, Monsegur's consistent and corroborated historical information, coupled with
his substantial proactive cooperation and other evidence developed. in the case, contributed
directly to the identification, prosecution and conviction of eight of 1us major ca-conspirators,
including Hammond, who at the time of his arrest was the FBI's number one cybercriminal
target in the world. On top of that, Monsegur engaged in additional, substantial proactive
cooperation that enabled,tlie FBi to prevent a substantial number ofplanned cyber attacks, as set,
forth below.
A. Monse~ur's Acceptance of Res~onsibility
To begin, with, Mansegux in:unediately admitted, his role in Internet Feds and LulzSec,
including his role in the majox cyber intrusions. setforth in th,e first section of this memorandum.
In addition, Monsegur admitted to playing a role in cyber.attacks and intrusions with these
groups that the Government had not previously known that he,played. For example, Monsegur
admitted to participating in DDoS (Distributed Denial of Services attacks against the computer
systems of PayPal, MasterCard, and Visa, among other targets. Monsegur also admitted to
hacking certain government websites and taking government servers online, to providing
"security research" (that is, publicizing vulnerabilities in computer systems that others could
exploit), and to using his "celebrity" hacker name "Sabu" in the hopes that it would inspire
others to join certain ci~imival activities of these groups.
In addition to his .admission to these crimes, Monsegur admitted to engaging in hacking
activities about which the Government had. not previously developed evidence. According to
Monsegur, between 1999, when he first began hacking computers, and late 2003/early 2004,
$ DDoS attacks involve the use of several computers to bombard a victim's computer
system with connection requests, thereby overwhelming the victim's system, often resulting in
the temporary shutdown of the victim's website.
Monsegur hacked into thousands of computers. For the next approximately two years, Monsegur
identif ed vulnerabilities in perhaps 200 computer systems in an effort to grow a legitimate
computer security fum. Then, starting around 2006, Monsegur hacked into computer . systems
for personal financial gain, or as part of hacker groups that. broke, into systems for a variety of
reasons, including so-called "hacktivism: ' Monsegur admitted that, before joining Anonymous
hacking crews, he hacked into a variety of websites and computer systems including the websites
of several businesses. Through these hacks, Monsegur was able to steal credit card information,
and then sold the credit caxd numbers, gave them away to family members and friends, anc~ used
them to pay his own bills. On at least one occasion, Monsegur was hired to hack into a
business's computer system. He also ,successfully hacked,into a business's website and had
merchandise delivered to hum free of charge.. .
Finally, Monsegur acknowledged a variety of other criminal conduct including sales and
attempted sales of small .quantities ~ ofmarijuana; personal marijuana use; illegally possessing an
unlicensed firearm; and purchasing stolen, goods including electronics and jewelry.
B. Monse~ ur Assists Law Enforcement in Identifvinu and Lacatin~ LulzSec
Monsegur's primary substantial, assistance came in the fozm of his cooperation against
significant cybercruiunals affiliated with Anonymous, Internet beds, and LulzSec. He provided
detailed historical information about the activities of Ananymaus, contributing greatly to law
enforcement's understanding of how Anonymous operates. Monsegur also provided crucial and
detailed information about the formation, organization, hierarchy and membership of thase
hacking groups, as well as specific information about their planning and execution of many
major cyber attacks, including the specific roles of his co-conspirators in committix~ g those
crimes. He also provided historical information that helped resolve open investigations into
D
several computer intrusions committed by members of Internet Feds and LulzSec, including the
hacks identified.above.
In addition to this crucial historical information, Monsegur proacrively cooperated with
ongoing Government investigatipns. Woxking sometimes literally around tie clock, at the
direction of law enforcerz~ent, Monsegur engaged lus co-conspirators in online chats that were
critical to confirming thee identities and whereabouts. During some of the online chats, at the
direction of law enforcement, Monsegur convinced LulzSec members to proeide him digital
evidence of the hacking activities .they claimed to have pxeviously engaged in, such as logs
regarding particular criminal.hacks. When law. enforcement later searched the computers of
particular LulzSec members, they discovered copies of the same electronic evidence on the
individuals' computers. In this way, the. online nicknames of Lu~zSec members were.definitxvely
linked. to their true identities, providing powerful proof of their guilt. Other times, at the,
direction of law enforcement, Monsegur asked seemingly innocuous questions designed to elicit
information from his co-conspirators that, when coupled with other u~.fonnatian obtained during
the investigation, could be used to pinpoint their exact locations and identities. Moiisegur's
substantial proactive cooperation, as set forth more particularly below, contributed,directly to .the
identification, prosecution, and conviction. of eight of his co-conspu-ators, including Hammond.
As disclosed in their communications, Hammond. and. certain other co-conspirators had
learned how to exploit a particular software application vulnerability that enabled him to hack
into many cornpufier servers. At Iaw enforcement direction, Monsegux attempted to learn how
these targets were able to exploit this vulnerability, but was unsuccessful. At the same rime,
Monsegur was able to learn of many hacks, including hacks of foreign government computer
servers, committed by these targets and other hackers, enabling the Government to notify the
1 0
victims, wherever feasible, so the victims could engage in remediation efforts and prevent further
damage or intrusions.
Monsegur's cooperation was complex and .sophisticated, and the investigations in which
he participated required close and precise coordination with law enforcement officexs in several
locations. For instance, during tha investigation of Hammond, Monsegur (who was then in New
Yark) engaged in online chats with Hanunond (who was then in Chicago), while coordinating
with FBI agents in New York, physical surveillance teams deployed in Chicago, and an
electronic suveillance unit in Washington, D.C.
Monsegur also engaged in a significant undercover operation in an existing investigation
through which, acting at the du~ection of law enforcement, Monsegur fathered evidence that,
exposed a particular subject's role_ in soliciting cyber attacks on a foreign government. T ,he ' .
evidence he enabled the Government to obtain was. extremely valuable, and the Government
could not otherwise have obtained it without his assistance. Although this cooperation has not
resulted in any prosecutions to date, the Gaveriunent believes his inforniation, and the evidence
he helped to obtain in this matter, is extremely significant.
C. Monse~ur Assists Law Enforcement in Preventing Hacks
Notably, during the period of his. cooperation, Monsegur received communications from
hackers about vulnerabilities in computer systems, as well as computer hacks that wexe being
planned ar carried out by them. T he FBI used this information, wherever feasible, to prevent or
mitigate harm that otherwise would have occurred. T he FBI estimates that it was able to disrupt
ox prevent at least 300 separate computer hacks in this fashion. T he vicrims included divisions
of the United States.Governrnent such as the United States Aimed Forces (specifically
~~, the United States Congress, the United States Courts (specifically,
l~
,...
_ ), and NASA; international intexgovernmental organizations
{specifically,
); end sevexal private companies including a
television netw o~ ~ k ~ ), a security firm ~ _), a video game manufacturer
~ ), and an electronics conglomerate ~ ). Although difficult to quantify, it is lik ely
that Monsegur's actions prevented at least millions of dollars in loss to these victims.
Monsegur also. provided information about vulnerabilities in critical nfrastruciure,
including at a w ater utility for an American city, and a foreign energy company. Law
enforcement used the information Monsegur provided to secuxe the w ater utility, and the
information about the energy company w as shaxed w itlz appropriate goverment personnel. In
addition, w hen. Anonymous.claimed to have hack ed the electrical grid in the United States,
Monsegur commutucated w ith certain Anonymous members :w ho revealed that the. claims. w ere a
hoax. This saved the Government the substantial tune and resources that otherw ise. w ould have
been deployed in responding to.these bogus claims.
Discussion
I. Applicable Law
The United States Sentencing Guidelines still provide strong guidance to the Court
follow ing United States v. Book er, S43 U.S. 220 (20Q5), and United States v. Crosbv, 397 F.3d
103 (2d Cir. 2005). As the Supreme Court stated, "a district court should begin all sentencing
proceedings by correctly calculating the applicable Guidelines range" that "should. be the
starting point and the initial benchmark ." Gall v. United States, 128 S. Ct. 5$6, 596 (20x7).
After that calculation, how ever, a sentencing judge must consider seven. factors outlined
in Title 18, United States Code, Section 3553(a): "the nature and circumstances of the offense
and the history and cha~ acteristics of the defendant," 18 U.S.C. 3553(a)(1); the four legitimate
12
purposes of sentencing, see id. 3553(a)(2); "the kinds of sentences available," id. 3553(a)(3);
the Guidelines xange itself, see id. 3553(a)(4); any relevant policy statement by the Sentencing
Commission, see id. 3553(a)(5); "tlie need to avoid unwarranted sentence disparities among
defendants," id. 3553(a)(6); and "the need to provide restitution to any victims," id.
3553(a)(7). See Gall, 128 S. Ct. at 596 & n.6.
II. Evaluation of Defendant's Cooperation
Section SKl.l of the Guidelines sets forth five non-exclusive factors that sentencing
courts are encouraged to consider in detei7iuning the appropriate sentencing reduction for a
defendant who has rendered substantial assistance, including the significance and usefulness of
the assistance; the truthfulness, completeness and reliability of the defendant's information and
testimony; the nature and extent. of the assistance; any. injury suffered, or any danger or risk of
injury to the defendant or his family resulring from his. assistance; and the timeliness of the
assistance.
As to the significance and usefulness of the defendant's assistance, Monsegur's
cooperation was extraordinarily valuable and productive. Monsegur provided unprecedented
access to LulzSec a tightly knit group of hackers who targeted and successfully breached a
variety of caznputer systems operated by governments, businesses, and news media outlets.
Through Monsegur's historical information and substantial proactive cooperation, the FBI and
international law enforcement were able to pierce the secrecy surrounding the group, identify and
locate its core members, and successfiilly prosecute them. In particular, when Monsegur first
was arrested, he provided the FBI with information about the identities and whereabouts of core
LulzSec members. This information helped focus the investigations being conducted by the FBI
and international law enforcement, allowing them to develop additional evidence against
13
LulzSec members. At the direction of law enforcement, Monsegur then engaged in online chats
with various LulzSec members, .convincing them to disclose details that confin~ied their
identities and whereabouts including, as noted above, digital evidence that later was matched to
files stored on the LulzSec members' connputers. Monsegur also provided in-depth information
regarding many of the computer hacks that LulzSec had perpetrated.
Monsegur's efforts contributed. directly in the identification, prosecution, and convictions
of core members of LulzSec, including:
Ryan Ackroyd, a/l~/a "Kayla," Ackroyd was arrested. by authorities in the
United Kingdom.. He pled_ g~ulty and was sentenced to 30 months' imprisonment.
Jake Davis, a/k/a "Topi~r~~." Davis was arrested by authorities in the
United Kingdom. He filed. guilty and was sentenced to 24 months' cust9dy in a young offender
institution.
~ Mustafa A1-Bassam, aJ~c/a "T-Flow: ' A1-Bassam was arrested by
.authorities in the United Kingdom. He pled guilty and was sentenced to a 20 month term, which
was suspended for two years, as well as 300 hours' community service.
~ Darren Marlyn, a/kla "pwnsauce," was arrested by authorities in Ireland.
He subsequently pled. guilty and received a sentence of probation and a fine.
In addition to these core members of LulzSec, Monsegur's cooperation led to the arrest
and prosecution of others who contributed to LulzSec's hacking efforts, including:
Jeremy Hammond, aJk/a "Anarchaos: ' As the Court is aware, Hammond,
the FBI's most wanted cybercriminal in the world at the tune of his arrest, was prosecuted in the
Southern District of New York, pled guilty, and was sentenced by the Court principally to a term
of imprisonment of 120 months.
14
Ryan Clea~ty. GIeary was arrested by authorities in the United Kingdom..
He pled guilty and was sentenced to 32 months' imprisonment.
Donncha O'Cearrbhail, a/k/a "palladium:' O'Cearrbhail was arrested by
authorities in Ireland, pled guilty, and was sentenced to probation and a fine.
Matthew Keys. Keys is currently charged in the Eastern District of
California in connection with his role in permitting unauthorized access to the Tribune
Company's computer systems.
All of these prosecutions wexe extremely important to the Government. As set forth
above, these hackers engaged insignificant cyber attacks against computer systems .that
belonged to government.. agencies.and contractors, nevys media outlets, non-profit . insritutions,
and private .entities., Some of the attaclzs defaced, news media webs~tes, ot~exs rendered ,
government websites inaccessible, and still othexs resulted in the exfiltration of the personal
identification information of victims.
Yet the number of prosecutions to which Monsegur coniribu~ed only partially conveys
the significance and utility of lus cooperation. On a daily basis throughout the suuuner of 2011,
Monsegur provided, inxeal time, information about then-ongoing computer hacks_ and
vulnerabilities in significant computer systems. Through Monsegur's cooperation, the FBI was
able to thwart or mitigate at least 300 separate. hacks. The amount of lass prevented by
Monsegur's actions is difficult to fu11y quantify, but even a conservative estunate would yield a
loss prevention figure in the millions of dollaxs. Moreover, Monsegur provided information
about actual and purported vulnerabilities in critical infrastructure, allowing law enforcement to
respond appropriately.
15
Finally, as set forth above, Monsegur engaged in a significant undercover operation in
which, acting at the direction of law enforcement, he helped to obtain evidence that exposed a
subject's role in soliciting cyber attacks on the computer systems of a foreign government.
While it has not resulted in prosecutions ; to :date, this evidence is significant and va~ uab~ e to the
Governnrient.
As to Monsegur's truthfulness, completeness and reliability, he presented as fully candid,
and admitted not only to crimes about which the Government had gathered evidence, but also
crimes about which the Government had not previously gathered :evidence. Monsegur's
information was also consistently reliable and complete, corroborated by documents and.
electronic flex, as well as by statements from other witnesses. As noted above, while Monsegur
made certain_ unauthorized online postings that xesulted in the revocation of his. bail. and his
incarceration fox several months, following his release from custody in December 2012,
Monsegur made no fiarther unauthorized postings.
As to the nature and extent of Monsegur's cooperation, as noted above, Monsegur has
been cooperating with law enforcement for approximately three years. His cooperation entailed
many multi-hour meetings with FBI agents that extended. into the late evening and early morning
hours. Monsegur provided substantial historical cooperation, as well as substantial proactive
cooperation, and he was prepared to testify if needed. Hovcrever, to date, every defendant against
whom Mansegur has cooperated has pled guilty with the exception of Keys, Who rs awaiting
trial. Monsegur's cooperation no doubt played a significant role in securing several of these
guilty pleas in that, among other things, acting at the direction of law enforcement, Monsegur
obtained incriminating online chats with most of the defendants that constituted strong proof of
each defendant's guilt.
16
The na#ure of Monsegur's cooperation was also somewhat atypical in that his work as a
cooperating witness was made pulilic shortly after the arrest of the. core LulzSec members. This
revelation in itself served an important deterrent effect throughout the hacking community. At
the same time, it resulted. in significant scrutiny of Mansegur and his family membexs.
As to the danger or risk associated with Monsegur's cooperation, Monsegur faced
hardships because of his cooperation. During the course of lus cooperation, the threat to
Monsegur and his family became .severe enough that t} ~ e FBI relocated Mansegur and .certain of
his family members, Monsegur repeatedly was, approached on the street and threatened.or
menaced about his cooperation once it became publicly known, Monsegur was also harassed by
individuals who ncor~ ectly concluded that he participated iii tl~ e Government's prosecution of
the operators.ofrhe Silk Road website.
`
Moreover, Monsegur has been vilified ozaline by various groups affiliated with the
Anonymous movement, which pai~ icularly affected. him given the central role that his online
activity played in his life prior to his cooperation with the Government. Among other things,
certain groups have sought to release. Moiisegur's personal identification information (such as his
exact address) as well as the.personal identification information of certain of his family
members.
Members of Monsegur's family have been threatened because of his cooperation, and one
of those relatives was involved in a physical altercation regarding Monsegur's cooperation.
Monsegur's family members have also repeatedly been approached by members of the media. In
one instance, a reporter was removed from the school of the children fox whom Monsegur served
as guardian after the reporter entered the school and attempted to interview the children.
17
As to the timeliness of Monsegur's assistance, as noted above, he iznniediately
cooperated with law enforcement. Just hours after being approached by law enforcement, he was
back online cooperating proactively.. His timely decision to cooperate helped prevent or mitigate
hundreds. of hacks; allowed the Government to develop sufficient evidence to charge multiple
individuals with serious computer crimes; and revealed a significant subject's role in soliciting
cyber attacks against a foreign government. Had Monsegur delayed his decision to cooperate,
his efforts would have been far less fruitful. In fact, LulzSec had developed an action plan to
destroy evidence and disband if the group determined that any of its members had been arrested,
or were out of touch with the other group members for an extended period of time. Accordingly,
had Monsegur delayed his decision to cooperate and remained offli~e for azi extended period of
time, it is likely that much of the evidence regarding LulzSec's activities would have been.
destroyed, .and members of the group would have become much moxe difficult to locate.
Monsegur's immediate decision to cooperate was thus particularly important to the ultunate
successes that stemmed from his cooperation.
Conclusion
In light of the foregoing facts, the. Goven~unent respectfully requests that, pursuant to
Section 5K1.1 of the Guidelines, the Court grant the defendant a substantial downward departure
at sentencing. In addition, the Government respectfully moves, pursuant to Title 1$, Section
3553(e), for relief from the otherwise applicable mandatory minimum sentence in this case.
Such a sentence will appropriately account for the defendant's extraordinary cooperation, and be
sufficient, but not greater than necessary, to serve the legitimate goals of sentencing.
18
R e ~ c ue st to Se al
The Gove rnme nt re spe c tfully re que sts that it be pe rmitte d to file limite d portions of this
submission unde r se al to prote c t the ide ntitie s of c e rtain vic tims.
Date d: Ne w York, Ne w York
May 23, 2014
`R e spe c tfully submitte d,
PR EET BHAR AR A
'Unite d State s. Attorne y
By: /S/
Jame s J. Pastore , Jr.
Assistant Unite d .State s Attorne y
Te l.:. {212) 637-2418
19
March 15, 2014,
H M_
~'
NY . ,
To Whom It May Concern:,
I H ` M-
i ~. Father of Hector X Monsegur Jr. am wri ti ng an behalf of
my son. He i s a wonderful son. He has always helped the fami ly and always
been there forme. 1 am si ckly. I have 3 pace makers and ~n asthma#i G, t need
my son to take care of me, I gladly appreci ate i f you can :take my health i nto
consi ders#i on and phase let ;by son stay free to help. me cope wi th my health.
gladly appreci ate your help and consi derati on to gi ve my son hi s freedom.
r
Si ncerely yours,
H ~ M~
{Si gnature}
exhibit ~
March 10, 201
M D,
-
~r
T
_
~~
,,
: ; ,
` ` N Y
To Whom It May Concern:
am writing to you on behalf of my brother to please give him a second chance at
life because he is e~cfremely intellgen# and I look up to him.. If he was, to go back
to prison it would re~~ly hurfi me and. mike my fami y depressed and ~o through
changes. N e is the back bane of our family. He has (aught me to be patient and
take #kings one, day at.a time.. He explain to me hpw precious life is and tells me
to appreciate R ~. Please find it in your heart to give my brother a chance end J et
him be free.
Sincerely,
M 'D
March 15, 2014
To whom it may concern,
t ~ ~ ~ ;ow
three children
r H. Monsegur for many years. He has been a good friend to me and my
~ ~ ind
~ . He is such a good person that I even
He has always been kind and understanding and a friend that you can count
on. He is also a very intelligent human being who has given me good advice and help during my college
year in
.. Living here in Jacob Riis Affordable Housing has not been easy. He always looked
out for my kids and make sure they go to school too. if you have any question or would like me to testify
in his behalf please feel free to call me at
Sincerer,
~ -
_ _ ~
" - ~ ~
STATE
~ F- N~ 1N
YORK.
'
C411tV~ 'Y E? F NE3 IV
MURK
/ J SYVC? ~ tN T4
BEFt~ RE ME
THlS
~ .
. ~ ~ ~
~ ~
,,.
.
a
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3 lfota , rua+ + T ,* ~ ~ K~
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Qualified In ~
_ : ; ,', .'~ y
Certificate file ~ ~ . ,- - -
i~ 'tmission
Expires
Exhibit E
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
I7
18
19
20
21
22
23
24
25
X185rdoe
SEALED
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
------------------------------x
UNITED STATES OF AMERICA.
v.
Defendant.
------------------------------x
Before :
HGN . L~i~E'11A 1-~ . ~RESKA
APPEARANCES
PREET BF.~
United States Attorney for the
Southern District of New York
JAMES PASTORS
Assistant United States Attorney
FEDERAL DEFENDANTS OF NEW YORK, INC.
Attorneys for Defendant
BY: PHILIP L. WEINSTEIN
PEGGY CROSS
11 Cr. 666 (LAP)
Arraignment
New York, N.Y.
August 5, 2011
11:35 a.m.
District Judge
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
X185rdoe SEALED
1
2
3
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7
8
9
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~~
18
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interests of justice.
MR. PASTORE:
for a moment .
Your Honor, Idid want to address bail
THE COURT: Yes, sir.
MR. PASTORE: This is a defendant v,~ho has been charged
with serious crimes. He is facing a significant amount of jail
time. Iwanted to brieflyaddress whythe government continues
to believe that the bail conditions set byMagistrate Judge
Colt on June 8th continue to be appropriate.
Since literallythe dayhe was arrested, the defendant
has been cooperating with the government proactively. Those
efforts have involved cooperation against targets of national
and international interests. Some of the groups against whom
the defendant, is cooperating are known to retaliate against
people who cooperate with the goveznment in ways ranging from
the mundane, for example, ordering hundreds of pizzas to
someone's house, to much more serious: Calling in hostage
situations in part byusing familyinformation and having a
SV ~~AT team show up at that person's home. It's actuallycalled
"swatting." It's fair to saythat this defendant has already
incurred a significant amount of personal risk bydeciding to
cooperate.
As to the cooperation itself, because it involves
efforts against targets both here and abroad, the defendant has
literallyworked around the clock with federal agents. He has
{212) 805-0300
X185rdoe
SEALED
1
2
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5
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9
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l5
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25
been staying up sometimes all night engaging in conversations
with co-conspirators that are helping the government to build
cases against those co-conspirators.
During this time the defendant has been closely
monitored by the government. We have installed software on a
computer that tracks his online activity. There is also video
surveillance in the defendant's residence. So, all of his
activities have been closely monitored, which has obviously
been an imposition not only on him but he also has two
daughters that he takes care of, is the foster parent for them.
The results of this carefully monitored cooperation
have already been quite positive. To give the Court some sense
of it, the defendant receives information about security
vulnerabilities from a network, literally a worldwide netv,~ork
of criminals, cybercriminals. On a day-to-day basis the
defendant can sometimes receive upwards of two dozen
vulnerabilities. Working with the FBI, that information has
been used to patch more than 150 vulnerabilities to date.
tn~hen I say "patch," I mean the FBI has been able to
reach out to victims sometimes before the hack has actually
occurred, other times after the hack has occurred but in an
effort to mitigate the harm from that hack. That is, f rankly,
something that we would probably not have been in a position to
do without the defendant's cooperation.
The defendant's information is also helping the
(212) 805-0300
X1~5raoe
SEALED
10
1 government close in on several prominent cybercriminals.
2 So, there is every reason to believe that by
3 continuing the defendant's bail, by allowing him to continue to
4 mitigate harm from cyberattacks, to continue to develop
5 evidence against other targets, that will able to mitigate
6 cybercrime and also apprehend some pretty serious
7 cybercriminals.
8 The defendant has been compliant with his bail
9 conditions for more than two months. Ithink he has shown that
10 at this point he is not a risk of flight, nor is he presently a
11 danger to the community.
12 For those reasons, the government respectfully submits
13 that bail be continued as set by Magistrate Judge Cott.
14 THE COURT: So ordered.
15 Anything else today, counsel?
16 MR. PASTORS: Nothing further from the government.
17 MS. CROSS: No. Thank you, your Honor.
18 THE COURT: The record remains sealed as we have
19 discussed.
2 0 (Adjourned}
21
22
23
24
25
SOUTHERNDISTRICT REPORTERS, P.C.
(212) 805-0300
Exhibit F
~`
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~;.
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~, ~~C~
`~
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,~ r
~: ,~r
~ iir'i~
FOR IMMEDIATE RELEASE
CONTACT: U.S. ATTORNEY'S OFFICE
Tuesday, March b, 2012.
Press Office
http: //www justice.gov/usao/nys
(21.2) 637-2600.
~'B T
Press Office
(212) 384-2100
Four Principal Mert~bers of `'Anonymous''.'. and "~uZzSec"Are .Charged with Computer Hacking,
.,
and a Fifth Member Pleads Guilty
"AntiSec "Member is Also Arrested and Charged with Stealing Confidential Information From
.r~ppr~ximately $6Q QDD Clients and
Subscribers of Stratfor
Five computer hackers in the United States and abroad were charged,today, and a sixth
pled,guilty~ for computer hacking and other craznes. The six hackers identified themselves as
aligned with the group Anonymous, which is a loose confederation.of cnmputerhackers and
others, andlor of~shoc~t groups related to. Anonymous, including "Internet
Feds," "LulzSec," and
t~AntiSec."
RYAN ACKROYD, alk/a "kayla," ~/k/a "lol," a/kia "lolspoon,": JAKE DAMS, alk/a
~~
`topiary, alkta atopiary, DARKEN MA.RTYN, afkfa `pwnsauce, alkia `raepsauce, a/k/a
"networkkittet~," .and DONNCHA O'CEARI2B HATL, a/k/a "palladium," who identified
themselves as members of Anonymous, Internet Fels, andlor LulzSec, were charged in an
Indictment unsealed today in Manhat-tazi federal court with computer hacking conspiracy
involving the hacks of Fox B roadcasting Company, Sony Pictures Entertainment, and the Public
B roadcasting Service..{"PB S"). O'CE~.RRB HAIL is also charged in a separate crimuial
Complaint with. intentionally disclosing a~a unlawfulty intercepted wire com~unicatzon.
HECTOR XAVIER MONSEGUR, alkla "Sabo,' ~Ik/a "Xavier DeLeon," allcla "Leon,"
i
who also identified himself as a member of Anonymous, Internet Feds and LulzSec, pled guilty
on August 1S, 2011 in U.S. District Count to a 12-count. information charging him with computer
x
hacking conspiracies and other crimes. MONSEGUR'S Information and guilty plea were
unsealed today. The crimes to which MONSEGUR pled, guilty include computer hacking
conspiracy. charges uutially filed in the Southern District of New York. He Also pled guilty to
the following charges: a substanrive hacking charge initially filed by the U.S. Attorney's Office
in the Eastern District of California related to the hacks of HB ~iary, Inc. and HB Gary Federal
LLC; a substantive hacking charge. initially filed by the U.S. Attorney's Office in the Central
District of California related to the hack of Sony Pictures Entertai~unent and. Fox B roadcasting
Company; a substantive hacking charge initially filed by the U.S. Attorney's O#fice in the
Northern Disirict of Georgia x~lateci to the. hack of Infragard. Members Alliance; a substantive
hacking charge uutially .filed by the U.S. Attorney's Office in the Eastern District of Virginia
related .ta the.~hack of PBS, all of which were tr~ns~~rred to the Southern District of New York,
pursuant. to Rule 2 U. of the Federal Rules of Criminal Procedure, in coordination with the
Computer Crime and Intelleci~~l Property Section, ("CLIPS") _ in the. Justice Department's.
Criminal Division. .
Late yesterday,lEREMY H[~~NIMOND., a/kla "Anarchaos," alk/a "sup_ g," a/k!a "burn," s
~
~~ a/kla `yohoho, a/k/a .POW, alkla
`tylerknowsthis, a/kla crediblethre~t, who identified
himself as a member of AntiSec, was azrested in Chicago, Illinois and charged in a, crunnal
Complaint with crimes relating to the .December 2 01,1 hack of Strategic Forecasting, Ina
("Stratfor"), a global intelligence firm in Austin, Texas, which may. have affected approximately
86U,000 .victims. In publicizing the ;Strai~f'or hack, members of AntiSec reaffirmed :their
connection to Anonymous and other related groups, including LulzSec. For example, AntiSec
members published a document with ] .inlccs to the. stolen Stra#fir data entitled: "Anoz~ymaus
Lulzxmas rooting youproud" on a file sharing website.
The following .allegations are based on the Indictment, the Information, the Complaints
and statements made. at MONSEGUR,'s guilty plea:
Hacks by Anonyrr~ous, l'nternet Feds, and .Lulz$ec.
,.
.Since. at least 2 00$, Ananympus has been a loose confederation of computer ~iackexs and
others. MONSEGUR.,and other members;af Anonymous took responsibility,for a nwnber of
cyber attacks between _ December 2 01 ~ and June 2 011: , including denial of service {"DoS")
attacks against the websites of Visa, MasterCard, and PayPa~, as retaliation_ for the refusal of
these companies to pra~ess donations ~o Wikileaks, as well as hacks. or DoS attacks on foreign
government computer systems.
$etween December 2 010 and May 2 Q l 1, members of Internet Feds sim lazly waged a
deliberate;campaign of oziline. destruction, intimidation, .and cririunality. Members of Internet
Feds, engaged in a series of cyber attacks :that included breaking into computer systems, stealing
confidential information, publicly disclosing stolen confidential information,,laijacking vict% ~ns'
email .and Twitter accounts, and defacing victims' Internet websites. Specif cally, .ACKROYD,
DAVIS, ~VIARTYN, O'CEARRBHAIL, and MQ NSEGUR., as me~bexs of InternetFeds,
,.
conspired to. commit computer hacks. including: the hack of 1tl~e w~bsit~ of Fine Gael, a pok~ical
party in Ireland; the hack of compu#ex systems used, by
security firms. HBGary, Inc..anc~ its
_ .
affiliate HBGary Federal, LLC, from which Internet Feds stole. confidential data pertaining to
80,000 user accounts; and the hack of computer systems used by Fox. Broadcasting Company,
from which Internet Fed.s stole confidential data. relating to more than 70,000 potential
contestants on "X-Factor," a ~'ox television. show.
In May 2 011, following the publicity that they had generated. as a result of their hacks,
including those of Fine Gael and HBGary, ACKROYD, DAVIS, MARTYN, and MONSEGUR
formed and became tl~e principal members of a new hacking group called "Linz Security" or
"LulzSec.' Like Internet Feds, LulzSec undertook a campaign of malicious cyber assaults on the
websites and computer systems of various business and :governmental entities in the United
States and throughout the world.- Specifically, ACKROYD, DAVIS, MARTYN, and
MI
MONSEGIJR, as members of LulzSec, conspired to commit computer hacks i~cludang the hacks
of:computer systems used by the PBS, in retaliation for what LulzSec perceived ta.be
unfavorable news coverage in an episode o~the news program, "Frantli~~'.'; Sony Pictures.
Entertauunent, in which LulzSec stole confidential data concerning apprpte~y 100,000 users
of Sony's website; and Bethesda Softworks, a video g~,mme company based. in Maryland, in which
LulzSec stole co~dent~al information for approximately 200,OOQ users of B~thesda's webs te. ,
.The Stratfor Hack.
In December 2011, HAMMOND conspired to hack into computer systems. used by
Stratfor, a private firm that provides_goyernments:and others with independent geopolitic~i
analysis. HAMMOND and his coco~spirators, as members of AntiSec, stole, confidential
.;
information from those cor~puter systems, including Str~tfor employees' emailsas well as '.
account. information. for approximately 860,000 Stratfor subscribers ~r clients. HAMMOND .and
lus co-conspirators stole credit card information for approxi.m~ately b0,000 credit cazd users and
used some of the stolen data..to make unauthorized charges exceeding $700,000. HAMMOND
and his co-conspiratory also publicly disclosed sgrne of the confidential. information they bad
stolen.
_ .
The Hack of International Law Enforcement
In January 2012., O'CEARRBHATL hacked into .the personal email account ~f an officer
with Ireland's nattonal .police service, the An Garda. Siochana (the "Garda'.'). because the .Garda .,
officer hall forwarded Work emails to a personal account, O'C~ARRB.HAIL learned information
about how: to access a conference call
that the Garda, the. FBI, and, other law enforcement
agencies :were planning to hold on January 17, 2012, regarding international investigatigns of
Anonymous and other hacking groups,. O'.CEARRBHAIL then accessed and secretly recorded
the January 17 international law enforcement conference ca11, and then disseminated the
illegally-.obtained recording toothers.
~ ~ ~
IvIONSEGUR, 28, of New York, New York, pled .guilty to three counts of computer
hacking conspiracy, five counts of computer hacking,,ane count of computer hacking in
furtherance of fraud, one count of co~asp racy to commit access device fraud, one .count of
conspiracy. to commit bank fraud, and one count of aggravated identity theft. He. faces, a
maximum sentence of 124 years and six months in prison.
ACKR.OYD, 23, ofDoncaster, United Kingdom, DAVIS, 29, of Lerwick, Shetland
Islands, United Kingdom, MARTYN, 25 of Galway, Ireland, each are charged with two counts
of computer hacki~,~ conspiracy, Each conspiracy. count carries a maximum sentence of 1 Q years
in prison.
O'CEA.RRI3HATL, 19, of Birr, Ireland is charged in the Indicirnent with orie count of
computer hacking conspiracy, for which he faces 10 years in prison. He is also charged in the
Complaint with one count of intentionally disclosing an unlawfially intercepted wire
communication, for which he faces a ma~mum sentence of five years in prison.
v
~'
HA~MMOND, 27, of Chicago, Illinois, is charged with one count of computer hacking
conspiracy, one count of computer hacking, and Qne count. of conspiracy to commit access
device fiaud.. Each count carries a ma um sentence, of 1 Q years in prispn.
DAMS is separately facing criminal chaxges in the United Kingdom, which remain
pending, .and. ACKROYD, s being interviewed #oday by the Police ~en~ra,~, e-crime. Unit in the
United Kingdom.. O'CEAItRBHA~L was ,arrested today by the G aarda
'The case is being prosecuxed by the. U.S. Attorney',s :Office. for the Southern District of
New York. The investigation was initiated and led by the FBI, and its New York, Cyber Crime
',
Task Force, vvh cl~ is a federal, state. and local law enforcement task farce combating cybercrime,
with assistance from the PCeU; a unit of New Scotland.Yard's Specialist Crime.D rectorate,
SCD6; the G arda; the Cruninal Division's CCiPS; and the U.S. Attorneys' Officesfor the...
Eastern District of California, the Central District o California, the Northern Dzsirict of G eorgia,
and.the Easters District of Virginia; ~s well as the Criminal Division's Office of International
Affairs.
_
The charges contained in the Indictment and Complaints are merely accusations, and the
defend~.nts are presumed innocent unless and until proven guilty.
12-068
###,
Computing Essintials
This is a 5 HOUR CL A S S
Overview
in a wprld where information increases exponentially, individuais are expected to develop and use
critical-thinking and decision-making skills. Digital taois enhance society's emerging abilities. to analyze,
synthesize, and evaluate information. The integration of technology systems expands and optimizes
their ability to use information and to communicate and collaborate with diverse individuals to expand.
the knowledge and skills necessary for solving both hypotheti~ai and authentic problems.
In a global world community, individuals are expected to be responsible digital citizens who practice
safe, legal, a.nd responsible use of technology systems and digital media, Individuals must comprehend
the impact of technology on the culture, social, economic, environmental, and political aspects of
society., Positive attitudes toward technology use are essential to support collaboration, learning, and
productivity fQr success in the twenty-first century.
Intro to Computers: 5 weeks
Week 1:
1. Identify basic parts of various technology systems, naming input and output devices, lE input-
keyboard, stylus, output: printer
2. Identify applications and operations of various technology systems IE: A ppi~cations-word
processing; operations-opening, closing, and, saving files
3. Discuss various operating systems of #echnology devices.
Week 2:
4. Determine basic troubleshooting strategies to correct common hardware and software
problems IE: Checking connections, restarting equipment, creating a backup copy of digital data
5. Explain basic features of word processing, spreadsheets, databases, and presentation
software. IE word processing: reports, letters; spreadsheets: discovering patterns, trackig data;
presentation software: slideshow
Week 3:
6. Identify safe use of technology systems and applications IE: protecting personal info online,
avoiding inappropriate sites, exiting inappropriate sites
7. Practice, responsible use of technology systems !E: maintaining proper settings
Week 3:
,~ S. Explain responsible and legal use of fiechnolagy systems and digital content IE: avoiding
plagiarism, complying with acceptable-use policies, recognizing secure web sites
Week 4:
9. Describe advances in fiechnology and effects of each on the workplace and spciety IE
agriculture, manufacturing, medicine, warfare, transportatis~ n
Week 5:
10. Explain the different uses of digital tools and strategies to locate, collect, organize, evaluate,
and synthesize information,
IE:locating-Boolean searches, collecting probeware, oCganizin~ spreadsheets, evaluating-determining ,.._
facts synthesizing-word.processing software
COMPLE710N R EQ U IR EMENT S:
Attend at least 7090 of class
Sign the sign-in sheet
Complete apre-test
Participate in class discussions
Complete any homework assignments
Pass a final exam with a grade of 7096 or better
INTRO TO COMPUTERS PRE/POST TEST
NAME:
NUMBER:
DATE:
1) A
is usually a powerful#~ersonal computer that functions as the primary computer in a
network.
A) Laptop B) Router CJ Server
D}
Node
2) A(n) ,_ is software that you can use to navigate the world wide web.
A) Browser B) Explorer C) Anti-virus Dj surfer
3J A(n}
is an example of a magnetic storage device.
A) Flash memory drive BJ CD-Rom C) Hard disk drive D) Optical drive
4j This lets you. fit more daa onto a magnetic disk..
Aj :Extraction .~) Defragmentation C) Compassion Dj Reboot
5) To remove data,fr~m pne document and place it in another, you. can use the and
commands.
Aj Cut and paste B) Copy and paste C) File and open D) Delete and paste
6) In a spreadsheet program, a ,,,_, is a set of worksheets in the same file.
A) Workbench B) Desktop C) Workbook DJ Workout
7) A,_,,,, is an, agreed-upon format for transmitting data. between two devices
A) Protopology B) Protoservice C) Prototype D) Protocol
8) When you set up an account with an online merchant, the web site may place one of these on your
computer's disk.
A) Catalog Bj Shopping cart C) Cookie D) Encryption
9) This technology secures data by converting it into code that is unusable by anyone who does not
possess a key #o the code.
A} Shopping cork Bj P2P C) User name D) Encryption
10j How many USB (Universal Serial Bus devices can you daisy chain to a PC?
A) 16 B)127 C) 256 D} 1020
Exhibit H
March 15, 2014
R ~ ar
,, .
~ .
. . . . . . . . . .
yY ,
To whom it may concern,
R _ , D have known N. Monsegur since High School. He has been a good friend to me. He
is ~ great person and a Brilliant mind. He has a)ways been kind and understanding friend that you can
count on. On many occasions he has helped me with schoai work. He and his family have. always helped
guide me towards. a
good life. . Always. . giving me advice on whit would ,be best not only fQr tne,but my
family as well, He truly motivated me to not. ar~ ly finish high, school b~ rt to. foliow my drams be a good
parent and is like. family to rr~ e, and my kids. He is more #han ]ust a friend to me he is family. He has
never had. a negative thing to say has never done me any harm and has always kept a watchful eye out
to help keep me safe. !t's not every day you find someone that truly knows the meaning of the ward
Loyalty. Yes he has made mistakes but I truly feet he has paid he debt to society and is a different
person now, He is truly a greafi asset to the human race es a whale. Ne is loyal, smart, honest, caring xhe
list goes on and on. i know in these circumstances these things may seem as a farce. Yet I don't know a
single human being that's made it through #heir entire life without committing a mistake. ln this great
country C _ was barn and bred to believe in t also believe in its ideals. People can change, People do
commit mistakes but does not necessarily make them bad people. l feel That my friend my brother my
kin should. be absolved of this. He has done time, come home, stayed out of trouble and is looking to
turn his life around. This is oat possible from Inside a cell. On the mercy of the court I beg of you,
please give him another chance. in khis great country that was once 13 small little colonies we h ue
come a long way so far that people come from far and wide to wave our flag and be a part of this great
nation. Show the mercy and compassion and the forgiveness that embodies this great nation we cal! the
United StaC es Of America and show the world once again why we are the best country in the world.
Sincerely,
- ~ . ,,
S' ~ 1 ~ ~ ' E O~ ' .t~ lE lN
YORK., - ;
C ~ 3iJNTY AF NE ~ 1 t
1 ' URIC
..
. .~
StiNQAN TO
BE FC )A~ .ME ~ THi~ A
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3 /5/2012

Hector Sabu Monsegur Sentencing Order and Background

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