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Case 1:08-cr-00341-RCL Document 25 Filed 07/13/15 Page 1 of 55

UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA
_____________________________________
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-v:
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JEREMY P. RIDGEWAY
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Defendant.
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_____________________________________
UNITED STATES OF AMERICA

Criminal No. 08-00341 (RCL)

JEREMY P. RIDGEWAYS
MEMORANDUM IN AID OF SENTENCING

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TABLE OF CONTENTS
Page
I.

INTRODUCTION ...................................................................................................................1

II. NATURE AND CIRCUMSTANCES OF THE OFFENSE ....................................................4


III. PERSONAL HISTORY AND CHARACTERISTICS OF MR. RIDGEWAY ......................5
IV. PROBATION WITH CONTINUED AND SUBSTANTIAL COMMUNITY
SERVICE IS AN APPROPRIATE SENTENCE UNDER 18 U.S.C. 3553 AND IN
VIEW OF THE UNIQUE CIRCUMSTANCES OF THIS CASE ..........................................6
A. Departure from Sentencing Guidelines is Permitted and Appropriate Here ....................6
B. Factors Under 18 U.S.C. 3553(a) Support a Sentence of Probation .............................8
C. A Sentence of Probation is Appropriate in View of Mr. Ridgeways History
and Characteristics ...........................................................................................................9
1.

Background and Education ..................................................................................... 9

2.

Honorable Military Service ................................................................................... 10

3.

Acceptance of Responsibility, Acknowledgement of Guilt, and Cooperation with


the Government, Including Public Testimony About the Truth of What Occurred
at Nisur Square ...................................................................................................... 20

4.

Community Service ............................................................................................... 22

5.

Importance of Family ............................................................................................ 41

D. A Sentence of Probation is Appropriate in View of the Nature and


Circumstances of the Offense ........................................................................................45
E. A Sentence of Probation Would Not Result in Unwarranted Sentence
Disparities Among Defendants with Similar Records Who Have Been
Found Guilty of Similar Conduct...................................................................................49
F. A Sentence of Probation Would Allow Mr. Ridgeway to Be Present for His
Children and Family.......................................................................................................49
G. A Sentence of Probation Would Comply with the Purposes of Sentencing
Listed in 18 U.S.C. 3553(a)(2) ....................................................................................51
V. CONCLUSION ......................................................................................................................52

ii

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I.

INTRODUCTION
Jeremy P. Ridgeway, by his attorneys, submits this Memorandum for the Courts

consideration in advance of sentencing in this matter scheduled for July 16, 2015. For the
reasons set forth more fully below, Mr. Ridgeway respectfully requests that the Court sentence
him to a five-year term of probation, with a condition that Mr. Ridgeway perform 2,500 hours of
additional community service. Such a proposed sentence comports with the statutory 18 U.S.C.
3553(a) factors, specifically the nature and circumstances of the offense, which occurred in the
foreign and hostile war zone of Baghdad, Iraq, where sudden and fatal violence was frequent and
Mr. Ridgeway was often forced to make instantaneous life or death decisions, as he mistakenly
did here, as well as his personal and compelling life history and characteristics, such as his
military service, his demonstrated and tireless commitment to his community, and his selfless
devotion to his family.
Nearly seven years ago, in November 2008, Mr. Ridgeway courageously pled guilty and
unreservedly accepted responsibility for his actions during the Blackwater guard civilian
shooting at Nisur Square in Baghdad, Iraq, on September 16, 2007.

Since doing so, Mr.

Ridgeway has cooperated actively and fully with the government providing a level of
cooperation that the government recognizes as exceptional1 for nearly seven years, despite
legitimate fears for his safety, including regularly meeting with two trial teams in this case, two
Kastigar taint teams, as well as other government investigators in additional proceedings
concerning allegations against Blackwater and other former Blackwater employees and
independent contractors. He did so consistently (and will continue to do so, as needed) without
fail, while understanding that his decision to cooperate would lead some to label him a rat, a

Governments Sentencing Memorandum, Dkt. No. 24 (July 13, 2015), at 11.

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turncoat, and a person who betrayed his teammates. As even the government recognizes in
its Sentencing Memorandum, in describing the fortitude it took for Mr. Ridgeway to come
forward by cooperating, Mr. Ridgeway would effectively be a pariah in many circles.2 After
the Defendants short-lived Kastigar victory at the end of 2009,3 it appeared that Mr. Ridgeway
the one shooter who honorably acknowledged his actions, accepted responsibility for them, and
committed himself to the truth could have been left as the only person to be held responsible
for the incident. And yet he cooperated further still. Ultimately, Mr. Ridgeway and counsel
acting at his direction met with prosecutors on countless occasions over nearly seven years of
vital cooperation. Mr. Ridgeway provided complete and truthful testimony to the grand jury,
during the Kastigar hearing, 4 and for three days at a public trial against his former fellow
Blackwater guards testimony that this Court previously found credible.
There can be little doubt that Mr. Ridgeways testimony throughout this matter before
the grand jury, during the Kastigar hearing, and at trial played a critical role if not the critical
2

See Governments Sentencing Memorandum, Dkt. No. 24 (July 13, 2015), at 12 (It is difficult to
overestimate how difficult cooperating has been for [Mr.] Ridgeway. It took courage for him to
abandon the party line, reject his friends and former colleagues, and tell the truth about what
happened in Nisur Square. The security contractor community is close knit, and [Mr.] Ridgeways
decision to cooperate has rendered him a pariah in his former community. He endured hectoring at
trial, where all of his prior mistakes, missteps, and foibles were exposed for all to see. Nevertheless,
[Mr.] Ridgeway maintained his composure, admitted his mistakes, and told the jury the truth about
what happened in Nisur Square. At bottom, [Mr.] Ridgeway has demonstrated great integrity by
admitting his wrongdoing and trying to right the grave wrong in which he participated.) (emphasis
added).
United States v. Slough, et al., Crim. No. 1:08-CR-00360, Order and Mem. Op. Granting the
Defendants Motion to Dismiss the Indictment; Denying as Moot the Governments Motion to
Dismiss the Indictment Against Defendant Slatten Without Prejudice, Dkt. Nos. 217-218 (Dec. 31,
2009).
See United States v. Slough, et al., Crim. No. 1:08-CR-00360, Mem. Op., Dkt. No. 416 (redacted)
(April 8, 2014), at 20 (Ultimately, the Courts determination rests on its assessment of Ridgeways
credibility as a witness. Ridgeway testified before this Courts Kastigar hearing for over a day. See
Kastigar Hrg Tr. Dec. 9, 2013 (PM); Kastigar Hrg Tr. Dec. 11, 2013 (AM); Kastigar Hrg Tr.
Dec. 11, 2013 (PM). The defendants had ample opportunity to question Ridgeway about his exposure
to their immunized statements and about how and why he repudiated his earlier statements
[redacted]. In observing Ridgeway during the Kastigar hearing, this Court found Ridgeway
credible. On that basis, the Court also credits Ridgeways testimony before the grand jury.) .

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role in securing justice for many of the innocent Iraqis who were killed and maimed on
September 16, 2007. The government, in its sentencing memorandum, recognizes that Mr.
Ridgeways actions significantly contributed to the achievement of justice and the beginning of
healing.5 Specifically, the government states:
[Mr.] Ridgeways Kastigar hearing testimony was an important
part of the governments proof that tainted evidence had not been
presented to the grand jury. And his trial testimony provided
valuable pieces of evidence. As a shooter (an insider), [Mr.]
Ridgeway was the only witness, who could explain to the jury that,
although he had shot, the shooting was unjustified. He also
explained that the claims about incoming fire were fabricated and
how those fabricated claims were developed by his confederates.
Accordingly, [Mr.] Ridgeways testimony was important to
achieving justice in this matter.6
Accordingly, the government is properly recommending a significant downward
departure from the Sentencing Guidelines, although Mr. Ridgeway believes a more substantial
departure is in fact warranted.
Mr. Ridgeways decision to assist the government was motivated both by his desire for
atonement as well as his intent in divulging the truth of what happened in Nisur Square. As Mr.
Ridgeway himself explained at trial, I needed to tell what happened that day. . . . . I wanted [my
wife and children] to know that I did something right in the end after doing something bad,
horrible. J. Ridgeway Trial Tr. (July 30, 2014 AM, 12:21, 13:5-6).
Mr. Ridgeway is a kind, gentle, and decent man, whose life outside of the events of
September 16, 2007, has been defined by love for others, compassion, generosity, sacrifice, and
courage. He has served his country, cared for his family, aided disabled veterans, and become a
community leader through his charity work with his Catholic Parish and the Knights of
5
6

Governments Sentencing Memorandum, Dkt. No. 24 (July 13, 2015), at 1.


Governments Sentencing Memorandum, Dkt. No. 24 (July 13, 2015), at 12.

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Columbus. He has spent the past eight years in steadfast and deliberate atonement, as a devoted
husband and father, a parish and community caregiver, and a courageous witness to the events
which occurred on that September day in Nisur Square, so that the truth would be known and
justice served. The life Mr. Ridgeway led before, and how Mr. Ridgeway has chosen to conduct
himself since September 16, 2007, is worthy of this Courts careful and most earnest
consideration.
Accordingly, Mr. Ridgeway respectfully requests that the Court recognize his
extraordinary cooperation and critical role in bringing this matter to a just conclusion, and credit
the governments acknowledgment of his exceptional assistance and recommendation of a
significant downward departure from the Sentencing Guidelines range, and sentence him to a
five-year probationary period, including requiring him to continue the significant community
service that he has already begun on his own initiative. As detailed more fully below, given the
nature and circumstances of the offense, Mr. Ridgeways acceptance of responsibility, his
extensive and long-standing cooperation with the government, the unusually long seven-year
period since his guilty plea, the personal history and characteristics of Mr. Ridgeway, and the
other factors identified under 18 U.S.C. 3553(a), the imposition of a sentence of probation
would be sufficient, but not greater than necessary, to comply with the purposes [of
sentencing]. 18 U.S.C. 3553(a).
II.

NATURE AND CIRCUMSTANCES OF THE OFFENSE


Mr. Ridgeway pled guilty on November 18, 2008, to one count of Voluntary

Manslaughter, in violation of 18 U.S.C. 1112, and one count of Attempt to Commit


Manslaughter, in violation of 18 U.S.C. 1113. A factual proffer and criminal information,
detailing the events of September 16, 2007, and identifying the victims, was filed with the

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Court.7 As set forth in the factual proffer, Mr. Ridgeway opened fire after other Blackwater
guards did, and he shot and killed Dr. Mahassin Mohssen Kadhum Al-Khazali, who was a
passenger in a white Kia sedan located south of the Nisur Square traffic circle, and shot and
injured Mr. Abdul Wabah Abdul Qadar Al-Qalamchi, who was driving a white Chevrolet
Celebrity, as the Raven 23 convoy proceeded against the flow of traffic to the north of the circle.
By agreeing to plead guilty to these two charges, Mr. Ridgeway acknowledged his
wrongdoing and demonstrated his acceptance of responsibility. Indeed, and as discussed in
greater detail below, Mr. Ridgeways decision to plead guilty was driven by his own profound
sense of remorse and personal culpability.
III.

PERSONAL HISTORY AND CHARACTERISTICS OF MR. RIDGEWAY


As referenced, Mr. Ridgeway is a good man, who has lived an honorable life both

before September 16, 2007, in his service to his country and his family, and after, in his sincere
acceptance of responsibility, acknowledgement of guilt, dedication to community service, and
cooperation with the government.

What occurred on September 16, 2007, was a tragic

aberration to a life led honorably before and since.


As evidence of his strong moral character, the Court need only look to the 89 letters
submitted in support of Mr. Ridgeway in connection with his sentencing.8 In letter after letter,
Mr. Ridgeway is described as a leader, a provider, a mentor, the first volunteer to step forward,
and someone who is proactive and identifies and addresses needs as they arise, without first
being asked to assist. He is also described as humble, loving, as someone with a big heart, and,
in the eyes of his daughter, Haley, a hero.

A superseding criminal information, containing the same two counts, was filed on December 4, 2008.
See Dkt. No. 11.
The collection of letters submitted in support of Mr. Ridgeway is attached hereto as Exhibit A.

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IV.

PROBATION WITH CONTINUED AND SUBSTANTIAL COMMUNITY


SERVICE IS AN APPROPRIATE SENTENCE UNDER 18 U.S.C. 3553 AND IN
VIEW OF THE UNIQUE CIRCUMSTANCES OF THIS CASE
A.

Departure from Sentencing Guidelines is Permitted and Appropriate Here

As set forth in the Presentence Investigation Report (the PSI Report), the Probation
Office has calculated Mr. Ridgeways Sentencing Guideline imprisonment range at 70 to 87
months. The government has recommended a significant downward departure from this range.
As the Court is well aware, however, the Sentencing Guidelines are not binding; rather,
they are only advisory in nature, and this Courts exceptionally broad experience amply
supplements their usefulness. See United States v. Booker, 543 U.S. 220, 245 (2005). Indeed,
the Sentencing Guidelines range is just one of several factors that the Court may consider under
18 U.S.C. 3553(a). Accordingly, while the Court must consider the applicable Guideline
range, it must also tailor Mr. Ridgeways sentence in light of other statutory concerns in
18 U.S.C. 3553(a), which are addressed in greater detail below. Id. The Court must make an
individualized assessment based on the facts presented and may not presume that the Guidelines
range is reasonable. United States v. Rita, 551 U.S. 338, 351 (2007). The Court may hear
arguments by either side that the Guidelines sentence should not apply perhaps because (as the
Guidelines themselves foresee) the case at hand falls outside the heartland to which the
Commission intends individual Guidelines to apply, . . . perhaps because the Guidelines sentence
itself fails properly to reflect 3553(a) considerations, or perhaps because the case warrants a
different sentence regardless. Id. Extraordinary circumstances need not be present to justify
deviating from the sentencing Guidelines, United States v. Gall, 552 U.S. 38, 48 (2007)
(upholding a sentence of probation because, inter alia, any term of imprisonment . . . would be
counter effective by depriving society of the contributions of the Defendant who . . . understands
the consequences of his criminal conduct and is doing everything in his power to forge a new
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life. Gall at 44), nor does the Court have to find a compelling reason to do so. United States
v. Terrell, 696 F.3d 1257, 1262 (D.C. Cir. 2012).
Mr. Ridgeway is eligible to be sentenced to probation. See 18 U.S.C. 3561(a) (A
defendant who has been found guilty of an offense may be sentenced to a term of probation
unless - (1) the offense is a Class A or Class B felony and the defendant is an individual; (2) the
offense is an offense for which probation has been expressly precluded; or (3) the defendant is
sentenced at the same time to a term of imprisonment for the same or a different offense that is
not a petty offense.). Neither of the charges to which Mr. Ridgeway has pled guilty is a Class A
or Class B felony.
In enacting 18 U.S.C. 3561(a), Congress clearly reiterated its intention to authorize a
probationary sentence in cases such as this one. Indeed, it would be difficult to imagine any case
Congress would believe to be more deserving of the benefits of probation. The offense at issue
clearly represents an aberrant act undertaken in very stressful circumstances by a man who has
otherwise led an exemplary life, has demonstrated his sincere remorse, and who formally
accepted responsibility at an early stage. Almost eight years have passed since the Nisur Square
tragedy, seven of which have seen Mr. Ridgeway cooperate extensively with the government,
leading to the convictions of four defendants who never accepted responsibility for their actions
that day. Congress must have had these very unique circumstances in mind when it passed
legislation authorizing probationary sentences for convictions under the statutes for which Mr.
Ridgeway is being sentenced.
18 U.S.C. 3553 instructs the Court to impose a sentence sufficient, but not greater than
necessary, to accomplish the goals of sentencing. 18 U.S.C. 3553(a) (2000). Thus, in the
unique circumstances present here wherein the tragic acts that bring Mr. Ridgeway before the

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Court are clearly an extreme exception to an otherwise honorable and productive life; wherein
Mr. Ridgeway has demonstrated his very sincere and heartfelt remorse for those acts and has
demonstrated earnest efforts to atone; wherein Mr. Ridgeway has admitted guilt and accepted
responsibility many years ago and, for the last nearly seven years, has provided exceptional
assistance to the government, and has promised to continue to assist in the event of appeals or for
any other reason the Court should depart from the Sentencing Guidelines. The Court should
instead issue a sentence of probation for Mr. Ridgeway.
B.

Factors Under 18 U.S.C. 3553(a) Support a Sentence of Probation

In sentencing Mr. Ridgeway, under 18 U.S.C. 3553(a), the Court must consider, inter
alia:
(1)

the nature and circumstances of the offense and the history and characteristics of
the defendant;

(2)

the need for the sentence imposed-(A)

to reflect the seriousness of the offense, to promote respect for the law,
and to provide just punishment for the offense;

(B)

to afford adequate deterrence to criminal conduct;

(C)

to protect the public from further crimes of the defendant; and

(D)

to provide the defendant with needed educational or vocational training,


medical care, or other correctional treatment in the most effective manner;

(3)

the kinds of sentences available;

(4)

. . . the sentencing range established [in the Sentencing Guidelines] . . .

(6)

the need to avoid unwarranted sentence disparities among defendants with similar
records who have been found guilty of similar conduct . . .

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In essence, the Court must make an individualized assessment based on the facts
presented. Gall, 552 U.S. at 50. In this case, such a personalized evaluation favors probation
enabling Mr. Ridgeway to remain with both the community and family who plead for his
continued presence and participation.
C.

A Sentence of Probation is Appropriate in View of Mr. Ridgeways History


and Characteristics

Mr. Ridgeway is a good man, who has lived an honorable life through his service to his
country, his caring for his family, his acceptance of responsibility for his actions on
September 16, 2007, and his dedication to serving his community in an effort to atone for his
wrongdoing.
1.

Background and Education

Mr. Ridgeway is 44 years old and was born in Huntington, New York, into a family of
military and public service. His father is a former New York City firefighter and Marine; his
grandfather was also a firefighter and served in World War II, retiring from the Army at the rank
of Colonel; and his great-grandfather was a policeman in New York. Mr. Ridgeway continued
his familys tradition of public service by joining the Army in 1989, and then later, in 2000,
joining the California Army National Guard.
Mr. Ridgeway completed several years of post-high school education, including
participating in the California Commission on Peace Officer Standards and Training (P.O.S.T.)
Certification at Miramar College in San Diego, and enrolling in courses in criminal justice and
military science at institutions in southern California. In addition to his time spent in the military
and with Blackwater, Mr. Ridgeway was employed for many years in the security industry.
From 1994 through 2002, he worked for what is now Securitas, where he rose through the ranks
of the company to eventually become business development manager. Beginning in 2002, Mr.

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Ridgeway worked for Allied-Barton, where he was also business development manager, before
leaving to join Blackwater in 2006.
Mr. Ridgeway is the loving husband of Marinette and proud father of Haley and Michael.
Later this summer, he and Marinette will celebrate their twentieth wedding anniversary, Haley
will begin her senior year in high school, and Michael will start fourth grade. Mr. Ridgeways
family is truly his pride and joy, and is the most important part of his life.
2.

Honorable Military Service

Mr. Ridgeway served his country with honor and distinction in the U.S. Army, from
1989-1990, and in the California Army National Guard, from 2000-2007.

Mr. Ridgeway, U.S. Army, 1989-90.

Mr. Ridgeway, U.S. Army National Guard, while depoloyed


in Iraq in 2004-2005.

While serving in the National Guard, Mr. Ridgeway fought bravely for his country in Iraq and
later volunteered for dangerous emergency response missions at home.

As Mr. Ridgeway

described in his letter to the Court, he has dedicated much of [his] life before September 16,
2007, trying to better the lives of others as a civilian, and through [his] military service in combat
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and in great disaster . . . Jeremy Ridgeway Letter at 2. Mr. Ridgeways military service
continued a family tradition of such service. See Diette Ridgeway Letter at 1 (The Ridgeway
family has an extensive generational line of continuous patriotic service dating back to the first
World War. Service to country has always been and continues to be an integral part of the
Ridgeway family . . . My cousin Jeremy embodies this deep sense of duty and service that is at
the core of the Ridgeway family.).
Operation Iraqi Freedom.

From March 2004 through March 2005, Mr. Ridgeway

served his country in one of the most dangerous neighborhoods of the most dangerous country
on the planet An-Nasiriyah, Iraq, a few hundred miles southeast of Baghdad, and the site of
fierce sectarian fighting as the violence in Iraq exploded in 2004 and 2005.

There, Mr.

Ridgeway was responsible for protecting his American and Iraqi brothers and sisters in arms,
showing restraint and good judgment when dealing with Iraqi residents, and, whenever possible,
helping the local Iraqi community rebuild their devastated nation.
himself to achieving all three objectives.

11

Mr. Ridgeway devoted

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Mr. Ridgeway (second from left) and Mr. Roger K. Williams, Jr. (third from left) train Iraqi soldiers to
guard polling stations in the first democratic election in Iraqs history.

Mr. Ridgeway (right) and Mr. Roger K. Williams, Jr. (left) pose with an Iraqi police official,
with whom they had regular contact and a good relationship.

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Mr. Ridgeway (far left) with Iraqi school teachers at a school, where he helped provide the villagers
with clean drinking water. See Roger K. Williams, Jr. Letter at 1.

As a squad leader responsible for managing security details in a high-risk environment,


Mr. Ridgeway never lost a comrade on his watch, including his Iraqi counterparts on-mission.
According to a brother-in-arms who served with him in Iraq, Mr. Ridgeway was a great leader,
who always took care of his soldiers. Roger K. Williams, Jr. Letter at 1.
Moreover, as a soldier tasked with the need to defend himself and his colleagues but to
also show restraint, he never killed an Iraqi, even though he was regularly confronted with
dangerous, threatening situations requiring split-second decisions. In fact, there were several
occasions when Mr. Ridgeway showed resolute courage in declining to engage a vehicle or a
potential target out of his commitment to do everything he could to protect his teammates and the
innocent Iraqis near him. Mr. Ridgeway always maintained his soldiers safety and the safety

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of civilians. Jeremy would take the extra time to make sure the right command was given. At no
time during our deployment was the wrong decision made. Eric C. Brady Letter at 1.
Mr. Ridgeways restraint frequently went beyond what was required by the rules of
engagement. On one such occasion, Mr. Ridgeway was acting as a squad leader at a checkpoint
in Iraq.

As squad leader, it was Mr. Ridgeways decision whether to use deadly force.

Mr. Ridgeway saw a box truck speed past and ignore soldiers down the road who were warning
motorists to slow down for the checkpoint. The truck continued to barrel down the road toward
his team without any sign its driver intended to slow down. It eventually reached a point where a
decision had to be made: either use force and risk harming a possibly innocent, albeit dangerous,
driver, or wait and risk a deadly insurgent attack. Mr. Ridgeway made the brave and responsible
decision to use restraint. Thankfully, the truck skidded to a halt a mere twenty feet away. Inside,
Mr. Ridgeway saw a startled male driver with his wife and son as passengers. Mr. Ridgeways
courageous and prudent caution during this incident plainly saved the lives of several Iraqis.
Throughout his time in Iraq from March 2004 through March 2005, Mr. Ridgeways
squad regularly encountered hostile fire by enemies who engaged and then took refuge within
communities and among innocent women and small children. This forced Mr. Ridgeway to
simply duck from the incoming fire, without response, to avoid the potential loss of innocent life.
Despite the constant danger, he was simply a soldier doing his job, protecting his teammates, and
following the rules of engagement even at personal risk to himself.
And as a man wearing the uniform of the United States, Mr. Ridgeway worked on a neardaily basis to strengthen the relationships between his unit, Coalition forces, local Iraqi
counterparts, and the indigenous Iraqi populations in which he was often embedded, bravely
doing so even though he served under constant risk of attack. He accepted such risk and

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developed great rapport with Iraqi citizens, truly embrac[ing] the winning of hearts and
minds doctrine. Jeremy Ridgeway Letter at 2. Those who served beside him recalled that Mr.
Ridgeway always displayed kindness to the local Iraqi people and treated everyone with dignity
and respect. Roger K. Williams, Jr. Letter at 1. They also recognized that Mr. Ridgeway
looked for ways to go beyond what was required of him to help the Iraqi citizens that he met:
Prior to departing the base to patrol, Jeremy would command his team to stop at MRE (Meals
Ready to Eat) points to load up as many MREs as possible.

Countless times over the

deployment, Jeremy would seek out families living in the areas wed patrol to distribute meals.
Jeremy would sit on the hood of the Humvee and pass out MREs, stuffed animals, crayons,
books, and markers to parents and children. Jeremy would also seek medics from other platoons
to patrol with us and help treat sick or injured civilians. Eric C. Brady Letter at 1. Mr.
Ridgeway also worked on projects benefitting local Iraqis, including, repairing an old water
station adjacent to our base so that running water was accessible to the base and local
community, and clean[ing] up unexploded ordinance[s] (UXO) in the area so that it would be
safe for the local community and troops. Roger K. Williams, Jr. Letter at 1.
Mr. Ridgeway especially bonded with the Iraqi children he met; his wife recalls that
Mr. Ridgeway had fond memories especially when it came to spending time with the Iraqi
children. He would always show pictures of him with the children and the smiles on their faces
said it all. Marinette Ridgeway Letter at 2. His fellow soldier recalls that Mr. Ridgeway
spearheaded the UXO clean-up, referenced above, because he was always worried about the
children getting hurt. Roger K. Williams, Jr. Letter at 1. Just a few illustrative photographs are
included here:

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Mr. Ridgeway poses with young Iraqi children while on patrol.

Mr. Ridgeway and his teammates pose with young Iraqi children while on patrol.

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Mr. Ridgeway hands out water to an Iraqi family while on patrol.

Mr. Ridgeway and his teammates pose with Iraqi children while on patrol.

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Mr. Ridgeway also received numerous commendations recognizing his military service in
Iraq and elsewhere, including the Iraq Campaign Medal, the National Defense Ribbon, the
Armed Forces Reserves Medal, the Army Commendation Medal, two Army Achievement
Medals, the Combat Infantryman Badge, and the Army Good Conduct Medal.
Hurricane Katrina.

Mr. Ridgeways bravery and compassion during his service in

Operation Iraqi Freedom continued through his National Guard service at home. In fact, less
than six months after returning from Iraq, Mr. Ridgeway served his country yet again: this time,
helping to respond to the devastation wrought by Hurricane Katrina in August 2005. Just as
Katrina made landfall, Mr. Ridgeway immediately volunteered to be the first to respond [for
Operation Gulf Coast Relief] and last to leave amongst [his] task force. Jeremy Ridgeway
Letter at 2. While in New Orleans with the National Guard, he put his own personal safety aside
to save the life of an elderly man, Edgar Hollingsworth, who had been stranded for sixteen days
due to the storm, and whom others had given up for dead. As his squad mate, Roger Williams,
recalled, [w]ithout regard to his own safety and without the proper protective equipment,
Jeremy entered a home that had been ravaged by flood waters and carried an elderly gentleman
to safety. Roger K. Williams, Jr. Letter at 2. Indeed, Mr. Ridgeways courage was noted by the
national media,9 and was even captured in one of the iconic photos that emerged in the aftermath
of Hurricane Katrina:

See Orange County Register, Survivor rescued 16 days after the hurricane, Sept. 14, 2005
(available at: http://www.ocregister.com/articles/force-192709-hollingsworth-task.html); see also
Jill Lawrence, USA Today, Behind an iconic photo, one familys tale of grief, Nov. 11, 2005
(available at: http://usatoday30.usatoday.com/news/nation/2005-11-10-hollingsworth-katrina_x.htm).

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Mr. Ridgeway (far right) holds an IV as he and his teammates rescue Mr. Edgar Hollingsworth,
who had been stranded for sixteen days due to Hurricane Katrina.

For this heroic conduct in the rescue of Mr. Hollingsworth, Mr. Ridgeway was nominated
for the U.S. Army Soldiers Medal, and was awarded the Humanitarian Service Medal. See
Roger K. Williams, Jr. Letter at 2. When Mr. Hollingsworth sadly succumbed to his injuries at
the hospital a few days after the rescue, his family asked Mr. Ridgeway to serve as a pallbearer,
and he was honored to do so. Mr. Ridgeways daughter recounts this rescue with pride and
admiration, describing it as the most beautiful story [she] heard on the news, and stating that
she is so grateful to know that [her] dad has such a huge heart. Haley Ridgeway Letter at 2.
Mr. Ridgeway was a good soldier, and always has been a good man. A friend from his
church community shared the following:

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As a recruiter in the U.S. Coast Guard, I interviewed thousands of


candidates. Many were looking to avoid the Viet Nam War. I had
to judge quality applicants. My theory was, would I want this man
in my lifeboat. With Jeremy Ridgeway, the answer is yes, without
hesitation.
Joseph Bator Letter at 2.
Similarly, another friend from his church community stated:
In my 32 years in the fire service, personnel evaluation was a
regular duty that I had to perform. Jeremy Ridgeway is as
dedicated, hard-working and outstanding individual as the
personnel that I classified as top fire fighters.
Ross Bergantine Letter at 1.
And a third:
When I was chief on the Los Angeles City fire department, I
learned that good officers are very important to the organization.
A volunteer organization has the same need. Jeremy has shown
that he is very capable in leadership positions.
Scott Lenz Letter at 1.
3.

Acceptance of Responsibility, Acknowledgement of Guilt, and


Cooperation with the Government, Including Public Testimony About
the Truth of What Occurred at Nisur Square

When Mr. Ridgeway returned from Iraq following the Nisur Square incident, it was clear
to those around him that his heart [was] severely broken, and [h]e went through a very dark
period. Marinette Ridgeway Letter at 2.
According to Mr. Ridgeway:

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I deeply regret my participation on that horrendous day and


desperately wish I could change the past with the same conviction
that I would not change the birth of my own children. As a man of
faith, I knew that in order to get right with God and seek
forgiveness, I had to repent, confess my sins, accept responsibility
for my participation on September 16, 2007, and begin to make
atonement for my actions.
Jeremy Ridgeway Letter at 1.
Accordingly, in 2008, with the purposeful courage expressed in his letter, Mr. Ridgeway
formally accepted responsibility for his actions and pleaded guilty to the two counts referenced
above.
Following his acceptance of responsibility and guilty plea, Mr. Ridgeway extensively
cooperated with and provided not only substantial, but exceptional assistance to the government.
He did so while under fear for his life and, for a time, while under the protection of U.S.
Marshalls. Over the past nearly seven years, Mr. Ridgeway has remained readily available to
assist the government, meeting with prosecutors on numerous occasions for countless hours,
answering questions, truthfully explaining what occurred on September 16, 2007, and testifying
before a grand jury in May 2013, at a Kastigar hearing in December 2013, and at the criminal
trial of his co-defendants last year. Mr. Ridgeway continued to cooperate, even after the original
indictment against his co-defendants was improperly dismissed in December 2009. He never
wavered in his commitment to provide the truthful rendition of the events of that day. In
addition to his past cooperation, Mr. Ridgeway has vowed to continue to cooperate with the
government, as requested. See Jeremy Ridgeway Letter at 1.
Mr. Ridgeways public testimony about the events of September 16, 2007, also provided
the Iraqi victims and their families with a truthful rendition of what happened on that fateful day.
One should not minimize the importance to those victims to have Mr. Ridgeway accept
responsibility for what occurred and tell them and the world what happened. Hopefully, it has
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brought some measure of peace and comfort to those Iraqis to know that one of the Americans
was willing to tell the truth and accept legal and moral responsibility.
Mr. Ridgeways significant, extensive, and very public cooperation with the government
also provides an additional basis for the Court to issue a non-custodial sentence. As a result of
the substantial and well-publicized assistance that he provided to the government, Mr. Ridgeway
would very likely be at risk among an incarcerated population. His cooperation and brave
testimony against his co-defendants leading to their convictions was extensively publicized in the
media and by word of mouth. Within a prison population, he will undoubtedly be immediately
known as a cooperator and snitch with all of the attendant risks to his personal safety. Indeed,
Mr. Ridgeway feared for his personal safety and that of his family when he first began to
cooperate with the government, but such fears never dissuaded him from his commitment to the
truth.
4.

Community Service

As is thematic in the nearly 90 letters submitted in support of Mr. Ridgeway, he has


dedicated his life in recent years to community service and helping those in need, and has done
so lovingly, enthusiastically, and tirelessly. His community has embraced him for his dedicated
commitment to its wellbeing. For example:
[Mr. Ridgeway] is also a faithful member of the parish as he
volunteers in many of our parishs ministries and activities.
Reverend Ramon Marrufo Letter at 1.
I could write for pages and pages about the good that Jeremy is
doing in our parish and community. In short, Jeremy is the first
volunteer to arrive and last one to leave.
Matthew Downey Letter at 1.

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[Mr. Ridgeway] is the first person to be counted on in times of


need by lending a helping hand or offering words of support. He is
warm and welcoming at every gathering, whether it is a potluck
dinner or large parish event and makes everyone he encounters feel
important.
Sergio Almada Letter at 1.
Jeremy is always willing to sacrifice his time, effort and put his
gifts on the table to help the community. Anytime there was a
need he was always there to help with great enthusiasm and
commitment to excellence . . . .
Daniel Andrus Letter at 1.
Jeremy is first on [site] and last to leave at every fundraiser. He
has thrown himself into these activities to overcome his sorrow.
Joseph Bator Letter at 1.
Jeremy is one that I can call on to help serve in whatever event we
are planning, hosting, or trying to get off the ground, and Jeremy
will be at every meeting, in the heat of the kitchen, and there with a
huge smile on his face.
Frances Jones Letter at 1.
[Mr. Ridgeway has] always lent a helping hand even when others
seem to be bothered by additional requests to serve.
Robert Kahle Letter at 1.
I know [Mr. Ridgeway] has worked hard to turn his life into
something that will bring peace and love to this world . . . I do
know that he is always ready to lift a helping hand and go the extra
mile.
Valerie Kahle Letter at 2.
[N]o matter what the need might be, school, church, or community,
Jeremy, the sweet and kind guy that he is, is always there to help
others. He is constantly volunteering his services, whether to grill
for the Knights of Columbus numerous events, serve hot lunches
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for school kids, or pick up 3 dozen helium balloons for graduation.


Whatever the need, he is always ready to give a helping hand.
Debra Shedd Letter at 1.
When thinking about Jeremy and his place in our community, no
better term comes to mind to define him as the word team player.
I have witnessed his strong sense of loyalty and duty. He has been
there to help me and the community on many projects and events.
He generously offers his assistance in any capacity needed,
whether it is his tireless effort on behalf of the Knights of
Columbus or a helping hand to the school or parish. Jeremy
always offers his services with great humility.
Robert Shedd Letter at 2.
Regardless of the activity within our parish and/or [Knights of
Columbus] organization, when volunteers are requested, Jeremy is
the first that will jump at the chance to serve others. In addition,
he is the first to rally others into volunteering their time to assist
others.
John Snyder Letter at 1.
Members of his community have characterized Mr. Ridgeway as a shining light . . .
always ready to lend his assistance (Frederick Bernier, Maj. USMC Letter at 1), and a strong
pillar of his community, standing out because of his integrity and sincere character (Jerome
Toliver Letter at 1). Put simply, [t]he amount of good that [Mr. Ridgeway] has done for [his]
community is enormous. Evans E. Formica Letter at 1.
Mr. Ridgeway gave and gave and gave and continues to give. Marinette Ridgeway
Letter at 2. And Mr. Ridgeways plea is that he want[s] to do more, by continu[ing] to serve
[his] community and better the lives of others. Jeremy Ridgeway Letter at 2.
Mr. Ridgeways dedication to community service stemmed from his desire to atone for
his past conduct; [k]nowing that [he] could not change the past, [he] began to attempt to change
the future for those who need it the most. Jeremy Ridgeway Letter at 1. He has certainly
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learned from his mistake and will never stop making up for his role on September 16, 2007,
because that is the type of man he is. He has gone outside of his comfort zone and volunteered
for things that neither he nor I couldve even imagined him doing in the past. Marinette
Ridgeway Letter at 4.
Indeed, Mr. Ridgeway has volunteered for more than half a dozen substantial forms of
community service, including the noble endeavors below:
Parish Soup Kitchen. Mr. Ridgeway has served in the parish soup kitchen and assisted
with food drives for the less fortunate. Marinette Ridgeway Letter at 2.
Parish School. Mr. Ridgeway is active in the Catholic school that his children have
attended, where he volunteer[ed] in every area he possibly could, including doing everything
from assisting with cooking and serving school lunch, to coordinating and assisting with major
fundraising events. Marinette Ridgeway Letter at 2. The principal of the parish school described
Mr. Ridgeways eagerness to assist: Since 2011, I have come to know Jeremy as the father who
is always the first one to step up when something needs to be done; whether it is fixing
something in a classroom, making a donation, barbequing for an event, or helping to unload
Christmas trees for our fundraiser. Linda McCotter Letter at 1.
Mr. Ridgeway has also shared with the children in the parish school regarding Veterans
Day. See William G. Byrne, Jr. (Lt. Col. USMC (Ret.)) Letter at 1 (When asked to interact with
children concerning Veterans on Veterans Day, he quickly said yes. He is proud to have
served his country and is eager to help wherever he can.). He also volunteers regularly as a
childrens leader at the parishs Vacation Bible School. See, e.g., Denell Corda-Robles Letter at
1 (Year after year he would make himself available to mentor the children [at the churchs
Vacation Bible School program]. I remember one time, watching him kneel down with the

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children in his group patiently teaching them how to carve out wooden animals with hand tools.
His soft voice gently guiding them each step of the way. I remember admiring him and his
ability to show the children so much kindness and goodness with such a caring heart.); Susie
Urrutia Letter at 1 (I remember [Mr. Ridgeway] working with such love and passion with our
children [during Vacation Bible School]. He had a group of teenage students helping him. One
of them was my son. Jeremy and my son connected immediately and Jeremy became a role
model for him.).
Knights of Columbus. Mr. Ridgeway has taken on a leadership role in the Knights of
Columbus, a Catholic mens charity organization, as Deputy Grand Knight, and has worked hard
to make the Knights of Columbus volunteer events and fundraisers successful. The individual
who served as the Grand Knight in the past year credits Mr. Ridgeway with his success: [t]he
position [of Grant Knight] is nothing without men like Jeremy Ridgeway. His dedication and
willingness to serve make the organization work. Robert J. Huber Letter at 2. Members of the
organization also give Mr. Ridgeway great credit for his tireless work on behalf of the Knights of
Columbus. See, e.g., Joseph L. Cusimano Letter at 1 (Organizations like ours could not exist
without the dedicated work of members like Jeremy.); D. Christopher Nolte Letter at 1
([Mr. Ridgeway] has become one of the most active Knights in our council and is relied upon
for his volunteerism, leadership, and friendship to all.); Kenneth W. Quigley (Lt. Col. USMC
(Ret.)) Letter at 1 ([Mr. Ridgeway] is a very hard working person and everyone in our
organization has immense respect for him and his commitment to helping the community and
others.).

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Mr. Ridgeway at a Knights of Columbus ceremony, giving an honorary lifetime


membership award to fellow Knight Lt. Col. William Byrne, Jr. (Ret.).

For example, Mr. Ridgeway has led efforts related to the Knights of Columbus Fish
Fries that occur for several weeks each year during Lent, and which are a major fundraiser for
the organization. His dedication to making the events successful is obvious to those around him.
To be responsible for the Fish Fry means long days. He helps open the kitchen in the morning,
buys any last minute items, and arrives back at 3:00 to start cooking. The night ends at 9:00 PM.
The event goes for six weeks. Jeremy keeps track of who will be there each week. He keeps the
guys spirits up, and he makes sure that he thanks every man personally. Robert J. Huber Letter
at 2. See also Wayne J. Gallagher Letter at 1 ([Regarding Fish Fry and other Knights of

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Columbus fundraising dinners:] Long, tiresome days, not a lot of thanks, other than what is in his
heart seeing the enjoyment the dinners bring to the fellowship of our community, and funds
raised helping many needy charities.).

Mr. Ridgeway leading efforts in the kitchen at a Knights of Columbus Fish Fry.

In addition to coordinating the Lenten fish fries, through the Knights of Columbus
organization, Mr. Ridgeway has coordinated many additional events/ fundraisers through the
organization. For example, Mr. Ridgeway is co-chairing (and serving as co-pit master for) the
annual Knights of Columbus BBQ Feast, at his church, which raises money for charitable
causes. See Matthew J. Downey Letter at 1-2.

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Assisting Catholic Teens with Confirmation Preparation. Mr. Ridgeway stated that
assisting young men and women, for example, through preparing for their confirmation in the
Catholic Church, became a passion.

Jeremy Ridgeway Letter at 2.

Others observed

Mr. Ridgeways demonstration of great love and attentiveness to the teens, and his efforts at
encouraging and mentoring [the teens] in their faith walk. Daniel Andrus Letter at 1.
4Paws4Patriots. After Mr. Ridgeway realized the positive impact a service dog had on
his own life, and the companionship that he was able to enjoy with fellow veterans while training
his service dog, he began volunteering with the organization 4Paws4Patriots. Jeremy Ridgeway
Letter at 2. 4Paws4Patriots is a non-profit organization that specializes in training dogs to
become service dogs for veterans.10

10

The website for this admirable organization can be found online at http://www.4paws4patriots.org/.

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Mr. Ridgeway with his service dog, Roscoe.

Mr. Ridgeway presenting a service dog vest to a


former student during a graduation ceremony.

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Mr. Ridgeway with his most recent service dog class at their graduation ceremony.

Mr. Ridgeway became a certified volunteer instructor at the organization, and is currently
fostering and training a Labrador puppy named Piesko to become a service dog for a wheelchairbound veteran, Michael Lee Fluharty. This is a commitment that, although ultimately Mr.
Ridgeways responsibility, his entire family enjoys working on together.

See Marinette

Ridgeway Letter at 3 (regarding the training of Piesko, [o]ur entire family helps out daily and it
brings us joy knowing we are helping a veteran in need.).
Mr. Fluharty is grateful for Mr. Ridgeways efforts to [seek] out and personally train[] a
prospective service animal, for him including by helping [Mr. Fluharty] tailor the service
animal to meet [his] specific needs . . . and be more safely independent. Michael Lee Fluharty

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Letter at 1. Mr. Fluharty credits his time spent with Mr. Ridgeway so far as enabling him to
gain[] confidence in dealing with large crowds of people in everyday situations. Id.

Mr. Ridgeway (standing, center) with 4Paws4Patriots students and service dogs in training, including
Michael Lee Fluharty (seated, center) and his Labrador retriever service puppy, Piesko,
who Mr. Ridgeway is fostering and training for Mr. Fluharty.

A brief June 2015 local media report from FOX 11 in Southern California profiled
4Paws4Patriots and demonstrates Mr. Ridgeways support of the organization. The video shows
a number of dogs trained by Mr. Ridgeway, and from the approximate 1:20-1:30 mark of the
video, the video actually depicts Mr. Ridgeway training a specific service dog on behalf of a
wounded veteran.11

11

The video is available online at https://www.youtube.com/watch?v=WtMFwQgqKl8&sns=em.

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Those who have gotten to know Mr. Ridgeway through 4Paws4Patriots have praised his
work for the organization. For example:
Over this past year I have come to know Jeremy as selfless and
exceedingly generous, giving both his time and monetary assets to
a noble cause he believes in. Jeremy spends hours not only
brilliantly training service dogs, but even helps to personally
deliver them to new homes with their veteran owners. These
service dogs bring unequivocal companionship and quality of life
to those who receive them. Always upbeat and positive, his
presence at 4 Paws for Patriots is a credit to not only himself but a
quality non-profit organization that gives so much back to our
service men and women.
Jesse Wolff Letter at 1.
Jeremy . . . now takes on more responsibilities at 4Paws4Patriots.
He trains more veterans and their dogs and even became a certified
Canine Good Citizen evaluator with the American Kennel Club
(AKC). This has helped the organization out a great deal.
Recently, Jeremy has even added an extra day of training so the
program can help even more disabled vets. This also relieved the
stress on the rest of the trainers that are working with other dogs. . .
. Without Jeremys service there would be a lot more disabled
veterans out there without the companionship and assistance they
so greatly need.
Richard J. Lyden, Jr. Letter at 1.
The CEO of 4Paws4Patriots best summarized the impact Mr. Ridgeway has had on the
organization and the veterans it serves:
Since [first coming to 4Paws4Patriots], Jeremy has become one of
our most dedicated volunteer trainers, working with not only the
service dogs, but dozens of disabled veterans every week (several
of which are on our suicide watch list). Regardless of what Jeremy
has going on in his life he is always there day or night for these
disabled veterans. They know that in their darkest hour they can
call Jeremy and he will help them through it. Being able to
communicate with these young disabled men and women, at this
level and train these highly skilled animals are not skills that are
easily acquired or even possible for most people. It takes a very
special person to be able to do this job well.
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I cannot state strongly enough how important Jeremy Ridgeway is


to our program, not only the changes hes made in himself since
entering the program but his dedication and the way he can
instantly make the connection with the disabled veterans we serve.
If our program [were] to lose Jeremy, it would greatly affect not
just us as an organization but literally hundreds of disabled
veterans every year.
Timothy LeBlanc Letter at 1.
Mr. Ridgeways work with veterans is particularly significant because, even though he
himself suffers from the effects of war, he recognizes that he has the ability and duty to help
those less fortunate than himself. Diette Ridgeway Letter at 2.
Mr. Ridgeways extensive community service efforts and his willingness to help those in
need appear to be a natural extension of his servants heart when it comes to helping family,
friends, and even strangers. For example:
. . . Ill begin when he was very young. Jeremy always liked to
help with things, especially those big projects around the house. I
was building a retaining wall out of stone, and he wanted to help
by carrying the stones over to me from a large pile. I thought that
this might be a bad idea because each stone was around 10 pounds,
and he was only three years old. I tried talking him out of it, but he
insisted. The work went on for a half an hour or so when he finally
had enough and went inside to get some water for himself, and for
me. This little boy showed more determination and love that day
[than] I could have imagined he was capable of.
Francis W. Ridgeway Letter at 1.
[W]henever we have had car problems, we knew we could call on
Jeremy to help us. He would drop everything and come to our aid.
He has helped us with so many things, including renewing a VISA
or passport, making an appointment with the DMV or Social
Security Administration, helping out with our business, and
assisting me to compose a resume and with the job application
process, and with just about any emergency you can think of.
Gil & Corazon Diza Letter at 1.
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Jeremy has always been there for me whether its fixing my car,
rescuing me when my car broke down, replacing a lock on a door,
or helping me with everyday situations.
Catherine Diza Letter at 1.
It doesnt matter who needs help or what the circumstances are,
Jeremy never hesitates to help a family member or a friend in need.
Jake Diza Letter at 1.
[Mr. Ridgeway] is the type of person we could depend on, if ever
we needed help.
Roland Mangaoang, Jr. Letter at 1.
Jeremy readily offers a helping hand to friends and family. He can
be counted on to be there for you when you need him. He is truly
an unselfish person who puts others before himself.
Janice Lassu Letter at 1.
As a neighbor, [Mr. Ridgeway] always helped with tasks that I was
finding difficult to do. On many occasions, he would help
unsolicited. For example, he would just show up with his pole saw
in hand and start sawing high branches too high for me to reach.
Anne Russo Letter at 1.
Jeremy was a great leader and always took care of his soldiers. He
would give you the shirt off his back if you needed it.
Roger K. Williams, Jr. Letter at 1.
Jeremy was a mentor to me, who would go out of his way to make
sure I was full prepared for anything. For example, Jeremy
generously gave me several important items I needed for a
promotion school I was sent to. Not only was I short on
equipment, I was short on cash. Unsolicited, Jeremy game me 100
dollars to help with any expenses.
Eric C. Brady Letter at 1.

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[Mr. Ridgeway] is always available to serve and is the example of


[a] servant leader. The most relevant event I can recall was when
my wife and I were new [to] the Parish and met Jeremy at the
annual Knights Barbecue cook-off in June of 2014. Jeremy was
quick to welcome us and our children, serve us, and was a real
example to my kids.
John Del-Zio Letter at 1.
I honestly believe that without Jeremy becoming a friend and
spiritual guide, I dont think that I would still be in the church
today. This caused me to find personal salvation and betterment in
my life. He allowed me to see that assisting others is always better
than serving yourself and Jeremy is the leader in that department.
John Snyder Letter at 1.
And, as the letters submitted in support of Mr. Ridgeway demonstrate, his service and
care for those in his community extends beyond formal kinds of community service. For
example, Mr. Ridgeway takes initiative to help others whenever he perceives a need:
I am a homeless Vietnam Veteran who sought help and found the
Knights of Columbus and Jeremy Ridgeway. In one of our first
meetings, he committed the entire post to help me overcome my
homeless issues. He also dropped what he was going and took me
to the emergency VA hospital for a fractured spine I developed on
one occasion and was the noblest form of kind and concerned
throughout. Then, as I live an hour from the VA, he took me down
for my quad by-pass surgery and retrieved me when it was done
four times! This guy is squared away and will be a huge loss to the
community should he be required to serve time.
Clay Ferguson Letter at 1.
Through another veteran, Jeremy became aware of Edmund.
Edmund is a veteran. When Jeremy met him, Edmund was in poor
health. He had closed himself off from others. Jeremy, among
others, visited Edmund. They took him to doctor appointments,
and encouraged him to come to our Knights of Columbus pot luck
dinners. Slowly, Edmund came out of his self-imposed exile. His
health improved. At one of our pot lucks, Edmund stood up to
thank Jeremy, and acknowledge how much he owed to Jeremy.
Robert J. Huber Letter at 1.
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Jeremy [does] not need to be asked to help; he [is] there to assist


anyone who was in need. For example, Jeremy found out about a
veteran in our community who was in bad health and almost
homeless. Jeremy saw to it that the individual received the care at
the VA hospital an hours drive away. This was not a one-time
affair. Jeremy was there to get him to the hospital for surgery, pick
him up when he was released, and made sure he made all of his
checkups. He made sure his residence was livable and he was
provided with food.
Maurice F. Bernier (Lt. Col. USMC (Ret.)) Letter at 1.
Mr. Ridgeways church community has recognized this devotion to those in need,
including Mr. Ridgeways special gift for caring for veterans:
Jeremy Ridgeway has been able to turn his experiences of war,
pains, and suffering into help for his community and other
Veterans with disabilities. . . . Jeremy has also reached out to
fellow veterans to help guide them through the VA system. One
particular Veteran Jeremy even assisted with getting to doctors to
assure he received the treatment he needed, and also actively
followed up with the Veteran to ensure he was following his
treatment. Jeremy helped him get his finances in order as well.
There are other men Jeremy served with whom Jeremy keeps a
close eye on to ensure they are physically and mentally ok, are
working, and are returning to a more active role in society. Please
be lenient in Jeremys sentencing so that he can continue his work
with our Veterans.
D. Christopher Nolte Letter at 2.
I have a son in the Marines. He served four and a half years, two
tours in Iraq and Afghanistan. He has Post Combat Stress
Disorder. Jeremy has also been helpful in giving advice on how to
reach out to Adam and has referred resources for Adam to use in
getting over his condition. Jeremy is a person who really cares
about people.
David Schutte Letter at 1.
Mr. Ridgeway also strives to create an environment of inclusion and acceptance wherever
he is:
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I actually got to know [Mr. Ridgeway] a little better when he


became a member of the Knights of Columbus in our parish and
befriended one of my sons who became a new and very young
member of the Knights. My son has some minimal learning
disabilities so I was a bit concerned about how he would do with
this somewhat older group of men. Jeremy was one of those men
who took special interest in him and made sure he was always
welcome and encouraged to really become a part of the group and
feel like a valued member.
Valerie Kahle Letter at 1.
As is plain from his significant and expansive social and charitable service and
willingness to help those in need, Mr. Ridgeways community would be best served by
sentencing him to probation, so that he can continue his good works for those who have come to
rely on him:
I truly believe that our community is a better place with him and
all that he does, than if he were incarcerated. I hope you take into
account all the great he has done and will continue to do.
Marinette Ridgeway Letter at 4.
I hope you will take into consideration all the great deeds my dad
has done and continues to do on a daily basis; and know that our
community is a better place because of him.
Haley Ridgeway Letter at 3.
I beg for mercy for a community who would suffer from losing
someone who has helped the unfortunate to such a degree; the
military veterans, the elderly, the unwed mothers, the mentally
challenged, and the disabled.
Janet Ridgeway Letter at 2.

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Im certain that Jeremy will continue helping the less fortunate and
being a positive influence because of his penitence. He wants to
move forward, uplift his community and set a good example for his
family and friends. The only way he can continue to do so is if
Jeremy Ridgeway remains a free man.
Janette Baxa Letter at 3.
If you sentence Jeremy to prison, it will only cause more harm.
We need Jeremy in Fallbrook. His family needs him. His parish
needs him. His community needs him.
Matthew J. Downey Letter at 2.
He lives his life in service to others and we would feel his absence
deeply. Jeremy could do more good if he was able to remain
outside of prison.
Meg Long-Eastman Letter at 1.
He does far more good in the life he has created here in Fallbrook
than if he is in prison. . . . Jeremy shows great remorse for the
action resulting in the charges against him and I believe he lives a
life that might somehow make up for the wrongdoing.
Harriet Beres Letter at 1.
I believe removing this gentleman from his family and church
serves little to no purpose and actually degrades our community.
Frederick Bernier, Maj. USMC Letter at 1.
I am hoping that you will see that Jeremy can do more for his
family, his community, and his parish by being allowed to remain
free on probation rather than being sentenced to time in prison.
Maurice Bernier (Lt. Col. USMC (Ret.)) Letter at 1.

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[Mr. Ridgeways] contribution to the small community of


Fallbrook is substantial. If he were confined to prison, our
community would feel a great loss and it would be devastating to
his young family.
William R. Dyckman Letter at 1-2.
[Mr. Ridgeway is a] man his family needs, our Church needs, out
Community in Fallbrook needs. It would be such a tragedy and
waste to lose this valuable member.
Wayne J. Gallagher Letter at 1.
I sincerely believe incarcerating Jeremy will not best serve his
family, community, or our country. He and his loved ones have
already suffered greatly and he will continue to shoulder the
burden and consequences of the events of that day for the rest of
his life. I believe his family, community, and our country will best
be served by allowing Jeremy to return to his family and our
community to be that nurturing, loving father and husband that I
know. I believe the benefits of his continuing service to our
community will greatly outweigh any perceived benefits of
incarcerating him. I also believe that if Jeremy is given probation
in lieu of incarceration, that he will return to our community and
be a very productive citizen because I have witnessed that he has
the skill sets to be very successful in whatever he chooses to do.
Robert Shedd Letter at 2.
I believe that in Jeremys case the interests of society and Jeremy
would be better served by permitting him to remain in society
where he would remain a productive member and fulfill his most
important role as father and husband . . . I know that Jeremy will
carry the weight of the consequences of his action for the rest of
his life and would welcome the opportunity to demonstrate to
society his true worth as an individual and pay back to society for
the single act, the consequences of which have been most
devastating to himself and his family, as well as, the Iraqis
involved.
Edmund and Priscilla White Letter at 1-2.
As a person who drafted a letter in support of Mr. Ridgeway simply but powerfully
stated, I believe that we shouldnt be defined by our mistakes, only by how we react to them.
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Sergio Almada Letter at 1.12 Here, Mr. Ridgeway has responded to his mistakes by dedicating
his life to lovingly serving those around him, particularly those in need. The only thing that he
asks from those benefitting from his good works is that they pay it forward, if they are able to,
creating a rippling effect of altruism. See Evans Formica Letter at 2 ([Jeremy] has done and
plans to continue being a great asset to our community. He has shown that he cares about and
will work towards aiding the disenfranchised in our community. The only thing he asks for in
return is that they help another person.).
Accordingly, Mr. Ridgeway respectfully urges this Court to impose a probationary
condition of an additional 2,500 hours of community service.
5.

Importance of Family

Mr. Ridgeway has always served his family and worked hard to provide them with the
best life possible. Mr. Ridgeway has been married to his wife, Marinette, for 19 years (20 in
September), and they have two children, Haley, age 16, and Michael, age 9. Mr. Ridgeways
closeness to and special bond with his family was one of the first things his wife, Marinette
Ridgeway, noticed about him when she first met him. Marinette Ridgeway Letter at 1. This
characteristic continues to define Mr. Ridgeway. Mr. Ridgeway is a great provider for his
family, and is supportive in everything the children and [his wife] do. Marinette Ridgeway
Letter at 3. Mr. Ridgeways daughter calls him an amazing family man, and most of all, a
hero. Haley Ridgeway Letter at 1. She said that even though Mr. Ridgeway spends a lot of
time helping others, he still manages to give the family his presence and provides for us as well;

12

In considering Mr. Ridgeways mistake, in an otherwise good and honorable life, one individual who
wrote a letter in support of Mr. Ridgeway noted the following: Who among us can imagine a life
lived with no mistakes? The scale of our mistakes is more modest because the risk we assume is
incalculably small compared to the risk assumed by Jeremy. He is not a risk to us now; he is an asset.
To isolate him from his family and his community will not serve justice. A terrible mistake was made
under impossible conditions. Cameron and Teresa Schutt Letter at 1.

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she said Mr. Ridgeway provides their family with clothes on our backs, food on the table, a roof
over our heads, and lots of unconditional love. Id.
Mr. Ridgeways love for and devotion to his family is powerfully evident to those around
him. See, e.g., Barry Pavlovich Letter at 1 (But the thing I like most about Jeremy is his
devotion to his wife and family. There is a rare conversation where he doesnt bring them up in
some way. Each month, at the Knights of Columbus Family Pot Luck, you will always find
Jeremy and Marinette and their children.); Denell Corda-Robles Letter at 2 (Every Sunday, I
see Jeremy, his wife Mary, and their children Haley and Michael at church. I see Jeremys
faithfulness to wife and children displayed in the gentle mannerisms and kindness he expresses
to them. I see a man very well respected and admired by me and this community for his
goodness and faithfulness to God and his family.); Edward S. Rotunda Letter at 1 (Jeremy is a
strongly committed family man to his wife Mari, and his two children Haley and Michael. I see
them weekly at mass, and it is clear to everyone the excellent role model he is.); John Snyder
Letter at 1 (Jeremy is a dedicated father and husband. He has dedicated his life to raising his
children and supporting his wife in her teaching career. Jeremy is a pillar in his childrens
education and constantly there to support them in all extracurricular activities.).
To sentence Mr. Ridgeway to a period of incarceration would remove him from his
family, who has already had to suffer immensely from his absence, primarily due to past
deployments. See, e.g., Haley Ridgeway Letter at 2 ([Describing how she suffered as a result of
her fathers deployment to Iraq, National Guard service related to Hurricane Katrina, security
contractor work in Iraq via Blackwater, etc.] Please, please, please dont make him go away and
make me suffer again.). It would take Marinettes husband and life-companion away from

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her, Haley Ridgeways hero away from her, and Michael Ridgeways Scout leader and
camping buddy away from him.
Removing Mr. Ridgeway from his childrens lives at this time would be particularly
damaging:
[Mr. Ridgeway] doesnt just tell [his children] how they should
live their lives; he actually shows them by living his life as a
loving and responsible father and husband.
Francis Ridgeway Letter at 2.
I beg for mercy for his children, whose lives would suffer from the
loss of a father; a man who teaches love, honesty, and a fruitful
way of life by his example. A son, who would lose the affection,
the watchful eye and safety net provided by his father; and a friend
to spend time with in Cub Scouts, and to enjoy movies with. A
beautiful daughter, already suffering from her fathers past
absences on deployment, and the threat of a new impending loss.
A young, impressionable child who requires a loving father to
show her how a man is supposed to behave; as well as a teacher, a
friend, and a comforting soul in trying times.
Janet Ridgeway Letter at 1.
[Mr. Ridgeway] taught me to accept the consequences of my
actions, to learn from my mistakes, and to feel joy not jealousy
when others succeed. . . . [Mr. Ridgeway] is a phenomenal role
model. The idea of Jeremy not being around to give his children
the same love, guidance, and inspiration that he gave me,
particularly at such critical ages in their lives, is unconscionable.
Christopher M. Ridgeway Letter at 1.
[Jeremy] has taken care of our daughter and grandchildren so well
and we know that they would suffer without him.
Gil & Corazon Diza Letter at 2.

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If Jeremy is incarcerated, it will devastate us, especially Jeremys


wife and kids. . . . His children and wife need him in every way . . .
They would be lost without him.
Catherine Diza Letter at 1.
My nephew and niece desperately need him to be part of their
lives.
Gil Diza, Jr., Letter at 1.
My cousins adore their father. You can see it in the way they
interact. I cant imagine the pain they would have to go through if
they lost their father.
Jake Diza Letter at 1.
Without Jeremy, as the foundation of this beautiful family, I worry
that they will fall apart.
Roland Mangaoang, Jr. Letter at 1.
Jeremy will be sorely missed by his family and friends if he has to
serve time in prison. He is needed by his wife for moral support in
the day to day struggles, as well as psychologically, physically and
financially. His daughter, who is college-bound, will need him for
help in making decisions at this important time in her life. He has
a son who needs his father around to guide him through the steps
of boyhood.
Janice Lassu Letter at 1.
[I ask the Court to] give special regard to [Mr. Ridgeways] young
son who would be devastated to live without his father present to
love and guide him to adulthood.
Kenneth Gahner Letter at 1.

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As a father of two children in the important years of their lives, it


is crucial for Jeremy to be present. It is even more important when
one considers that during much of their younger years, Jeremy was
overseas serving his country.
Frances Jones Letter at 1.
Please have leniency during Jeremys sentencing so that his wife
Mari does not have to endure more time alone raising their family
and worrying about Jeremys safety. She has sacrificed enough as
an Army wife. She is tough and could endure, but it would be a
very difficult journey for her. . . . I think it will be the children that
suffer the most if Jeremy is sentenced and misses this important
time in the childrens lives. . . . Children need a mother and father
present in their lives to develop properly so please have leniency in
the sentencing of Jeremy Ridgeway for the sake of his children and
their future.
D. Christopher Nolte Letter at 1.
Jeremys continued presence as a father within his immediate
family as well as with parish children is critically important. It is
my hope that the court will enable Jeremy to continue to [be]
physically present and continue his instrumental role of being a
loving father and active participant in our parish and community.
Jerome Toliver Letter at 2.
D.

A Sentence of Probation is Appropriate in View of the Nature and


Circumstances of the Offense

As referenced above, Mr. Ridgeway has pled guilty to one count of Voluntary
Manslaughter, in violation of 18 U.S.C. 1112, and one count of Attempt to Commit
Manslaughter, in violation of 18 U.S.C. 1113. By agreeing to plead guilty to these two
charges, Mr. Ridgeway acknowledged his wrongdoing and demonstrated his acceptance of
responsibility. Indeed, Mr. Ridgeways decision to plead guilty was driven by his own profound
sense of remorse and personal culpability, as well as his sincere desire for atonement by serving
the truth.

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Both counts reflect an act done without malice and in the heat of passion. In
particular, 18 U.S.C. 1112(a) defines Voluntary Manslaughter as the unlawful killing of a
human being without malice . . . [u]pon sudden quarrel or heat of passion. Neither of the two
counts, to which Mr. Ridgeway has pled guilty, therefore, involves a finding of willful intent or
malicious conduct.

Rather, they reflect culpability for Mr. Ridgeways unquestioned

overreaction under very unique circumstances: a tragic and criminal mistake that resulted in
the death of an innocent mother, Dr. Mahassin Mohssen Kadhum Al-Khazali, and the severe
injury to a young Iraqi male, Mr. Abdul Wahab Abdul Qadar Al-Qalamchi, who was in the
wrong place at the wrong time.
From the beginning, Mr. Ridgeway has recognized the serious nature of the offense, and
has felt great remorse for the loss of life and injuries that occurred on September 16, 2007. J.
Ridgeway Trial Tr. (July 30, 2014 AM, 12:18). As he stated in his letter to the Court, Mr.
Ridgeway deeply regret[s his] participation on that horrendous day and desperately wish[es he]
could change the past. Jeremy Ridgeway Letter at 1.
Mr. Ridgeways immediate family has written powerfully regarding his remorse and
contrition. His wife, Marinette, confirms Mr. Ridgeways remorse, writing that, [a]lthough our
Pastor tells Jeremy over and over again, that his sins have been forgiven and absolved, he still
feels great remorse and carries it heavy in his heart. Marinette Ridgeway Letter at 3-4. His
father, Francis, writes that, I know that Jeremy carries this terrible weight every day, and will
for the rest of his life. We, as a family, will try to continue to help Jeremy in every way possible,
but ultimately, I suspect it will continue to etch his mind with guilt and sorrow for the rest of his
life. Francis Ridgeway Letter at 2. And his brother, Christopher, writes that, [t]he tragic
events in Iraq hang over Jeremys head every day. Christopher Ridgeway Letter at 2.

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Others who are very close to Mr. Ridgeway family and friends both share similar
observations regarding the depth of Mr. Ridgeways remorse and his commitment to doing
everything possible to make things better. Examples include:
[Mr. Ridgeway] often told us how bad he felt about what happened
in Iraq and we could tell he was truly remorseful and we could see
that he really wanted to make amends.
Gil & Corazon Diza Letter at 2.
I could see the remorse in his eyes and in his heart. He was, no
doubt, a broken man.
Catherine Diza Letter at 1.
Shortly after my arrival to the parish [in July 2009] Jeremy made
me aware of his involvement in the events that took place in
Baghdad, Iraq, in September 2007, while he was working for the
security firm Blackwater. At that time he expressed to me his
regrets and remorse for his actions.
Reverend Ramn Marrufo Letter at 1.
I have personally witnessed Jeremys anxiety, fears and stress. I
have seen Jeremy cry with remorse and regret. Yet even in his
darkest hours, Jeremy has never attempted to deny responsibility
for his actions on September 16, 2007, in Iraq.
Matthew Downey Letter at 2.
Jeremy has expressed to me his remorse resulting in PostTraumatic Stress which drives him to leading life to the fullest in
the hope when he is judged by God that he has done enough to
make up for his actions. Jeremy has shared the crosses he bears
and with a heavy heart and remorse of his role and actions in
service of his country.
Erik Benitez Letter at 1.

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Jeremy has shown so much remorse and pain from the incident that
I have to ask you to have mercy on him. He is a good man that has
suffered and continues to suffer for what he did.
Juan Gomez Letter at 1.
I am aware of the events that led to Jeremys guilty plea. We have
talked about it many times and I know that he is truly sorry for
what happened.
Scott A. Lenz Letter at 1.
This is a man who lives his faith. This is a man who cares deeply
for others. This is a man who, in my personal conversations with
him about the events of September 16, 2007, is deeply remorseful.
Edward Rotunda Letter at 1.
On several occasions Jeremy has shared with me his deep remorse
for what transpired in Iraq in 2007. His sorrow for all the victims
involved in that event is genuine. In my opinion, he has accepted
full responsibility for his actions on that day in Iraq. I have
experienced first hand that he and his family suffered the
consequences of what took place over and over again and he is
truly despondent about that. I have felt his heart ache and have
seen how his depression has affected him and his family.
Robert Shedd Letter at 2.
. . . Jeremy and I have had many conversations regarding this case.
However, the focus of those conversations were centered around
the level of remorse he has for what occurred during the incident in
Iraq. As a father he is distraught that childrens lives were taken.
As a husband, he is sad that the wife of another has been taken. As
a Catholic man, the basic tenant of [thou] shall not kill has been
broken and he has asked for forgiveness and has been blessed with
that forgiveness. As a patriot, he is saddened by the scar that has
[been] left upon his country due to the incident. As a man, he is
extremely remorseful for the actions that occurred in Iraq.
John Snyder Letter at 2.

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I feel that Jeremy has express[ed] true remorse and regret for his
actions. I have personally seen Jeremys sorrow, stress, anxiety
and heartache over these events.
Lisa Waddington Letter at 1.
E.

A Sentence of Probation Would Not Result in Unwarranted Sentence


Disparities Among Defendants with Similar Records Who Have Been Found
Guilty of Similar Conduct

Mr. Ridgeway is not similarly situated to the other defendants who have already been
tried and sentenced in this matter i.e., Messrs. Slatten, Slough, Heard, and Liberty. Unlike
Mr. Ridgeway, none of the four other defendants have accepted responsibility for their actions,
for which a jury found them guilty. To the contrary, they continue to profess their innocence and
lack of responsibility or remorse, even going as far as to wrongfully blame Mr. Ridgeway for
every consequential shooting during the incident in Nisur Square. The government has correctly
observed that, [i]n light of [Mr.] Ridgeways cooperation, any disparity between his sentence
and those of his confederates would not be unwarranted.13 In addition, unlike Mr. Ridgeway,
the other defendants appeared before this Court under circumstances in which the Court had little
to no discretion in fashioning their sentences, due to the 18 U.S.C. 924(c) convictions for
Messrs. Slough, Heard, and Liberty and the first-degree murder conviction for Mr. Slatten.
Accordingly, the Court should not consider the sentences imposed upon Messrs. Slatten, Slough,
Heard, and Liberty in fashioning Mr. Ridgeways sentence.
F.

A Sentence of Probation Would Allow Mr. Ridgeway to Be Present for His


Children and Family

As discussed above, a sentence of probation would allow Mr. Ridgeway to be present for
his family. This upcoming year is an especially important one for his daughter, Haley. She
graduates from high school in 2016, and if sentenced to probation Mr. Ridgeway will be able
13

Governments Sentencing Memorandum, Dkt. No. 24 (July 13, 2015), at 10.

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to walk her down the aisle at her Senior Presents with the National Charity League, a
philanthropic mother-daughter organization that she and Mrs. Ridgeway belong to, and that she
joined based on the philanthropic example that Mr. Ridgeway set. See Haley Ridgeway Letter at
2. A term of probation for Mr. Ridgeway would also mean that a young woman would not have
to suffer from her fathers absence again, as she begins her post-high school adult life. See id. at
3 (In closing, Id like to say that when I was 5, my dad served in the Army. Because he was sent
to Iraq, I had to suffer. When he returned, he distanced himself and was not the same father that
left 15 months prior and for that, I had to suffer. Then he left again to go to New Orleans as well
as guard the airport during a liquid bomb scare, I had to suffer some more. Then he left again for
Iraq and Ive had to suffer even more. When he came back this time, he kept to himself so much
that I felt like he wasnt even back. It took years but I finally have my dad back. Its been
wonderful seeing him and watching him be the great example that he is for me and my brother.
Please, please, please dont make him go away and make me suffer again.).
A probationary sentence for Mr. Ridgeway would also benefit his young son, Michael,
whom he leads in Cub Scouts as an assistant den leader. This year, Michael advanced to Webelo,
and if sentenced to probation Mr. Ridgeway will be able to continue to directly participate in
Michaels life, as assistant den leader, just as an example.
Finally, a probationary sentence for Mr. Ridgeway would allow him to be there to
celebrate his twentieth anniversary with his wife, Marinette, in person. And it would enable him
to help her parent Haley and Michael, and guide them during these next few years ahead.

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G.

A Sentence of Probation Would Comply with the Purposes of Sentencing


Listed in 18 U.S.C. 3553(a)(2)

Mr. Ridgeway agrees with the government that most of the purposes of sentencing under
18 U.S.C. 3553(a)(2) do not apply to his situation.14 However, Mr. Ridgeway respectfully
disagrees with the governments position that the retributive purpose of sentencing15 requires that
he be incarcerated.
In United States v. Cole, 622 F. Supp. 2d 632, 637 (N. D. Ohio 2008), the Court
distinguished the purposes of sentencing in the following way:
We have long understood that sentencing serves the purposes of
retribution, deterrence, incapacitation, and rehabilitation.
Deterrence, incapacitation, and rehabilitation are prospective and
societal each looks forward and asks: What amount and kind of
punishment will help make society safe? In contrast, retribution
imposes punishment based upon moral culpability and asks: What
penalty is needed to restore the offender to moral standing within
the community?
Id. at 637 (emphasis added).

14

15

Regarding 18 U.S.C. 3553(a)(2)(B), the need for the sentence imposed to afford adequate
deterrence to criminal conduct, the unique circumstances that lead to the Nisur Square incident will
likely not occur again, so there is little to no need to consider issues of general deterrence. In
addition, Mr. Ridgeway will certainly never be in a similar situation again, so there is no need to
consider specific deterrence.
Regarding 18 U.S.C. 3553(a)(2)(C), the need for the sentence imposed to protect the public from
further crimes of the defendant, other than the charges presently before the Court, Mr. Ridgeway has
never been accused or convicted of any crime, and he has vowed that he will never commit another
crime again, but instead has devoted his life to community service. Accordingly, there is no need to
protect the public from further criminal behavior.
Regarding 18 U.S.C. 3553(a)(2)(D), the need for the sentence imposed to provide the defendant
with needed educational or vocational training, medical care, or other correctional treatment in the
most effective manner, Mr. Ridgeway has completed educational courses and worked for many years
before the Nisur Square incident, both in the military, as detailed above, and for private employers.
Indeed, Mr. Ridgeway does suffer from Post-Traumatic Stress Disorder (PTSD) and has been
receiving counseling and treatment. It is actually critical that this treatment not be interrupted, as
would occur if he were incarcerated.
See 18 U.S.C. 3553(a)(2)(A) (The court, in determining the particular sentence to be imposed, shall
consider-- the need for the sentence imposed-- to reflect the seriousness of the offense, to promote
respect for the law, and to provide just punishment for the offense.).

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The United States Supreme Court recognized that a sentence of probation is punishment
because it substantially restricts the liberty of offenders. See United States v. Gall, 552 U.S. 38,
48 (2007). The Supreme Court also concluded that courts can consider offenders self-motivated
rehabilitation as support for the conclusion that imprisonment was not necessary to deter an
offender from committing future criminal conduct or to protect the public from his potential
future criminal conduct. See id. at 59.
As detailed above, after September 16, 2007, Mr. Ridgeway worked tirelessly to attempt
to restore himself to moral standing within his community. And he has succeeded in doing so, as
is reflected in the dozens of letters submitted in his support, written by those who have both
served alongside Mr. Ridgeway and those who have been served by him over the past eight
years. And his community has answered the critical question asked by the Court in Cole: Mr.
Ridgeway already has obtained moral standing within a community that simply cannot bear to let
him go.
V.

CONCLUSION
Mr. Jeremy Ridgeway presents a unique opportunity for this Court to acknowledge the

power of remorse, expiation, atonement, and redemption. It has been almost eight years since
Jeremys tragic mistake, and almost seven since he has formally accepted responsibility, and
pursued truth to achieve justice. He needed to tell what happened that day, so his family will
know that he did something right in the end after doing something bad, horrible. And Jeremy
has continued to do something right every day since, for many people. This Court has the
power, the authority and, most notably, the insight to let his good works continue,
uninterrupted.16

16

Mr. Ridgeway anticipates that a significant proportion of his community service hours will be
dedicated to assisting veterans in need.

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Respectfully submitted,
/s/ William M. Sullivan, Jr.
William M. Sullivan, Jr. (D.C. Bar No. 467269)
Thomas C. Hill (D.C. Bar No. 242974)
Kristen E. Baker (D.C. Bar No. 995333)
Pillsbury Winthrop Shaw Pittman LLP
1200 Seventeenth Street, NW
Washington, DC 20036-3006
(202) 663-8027
wsullivan@pillsburylaw.com
thomas.hill@pillsburylaw.com
kristen.baker@pillsburylaw.com
Ryan R. Sparacino (D.C. Bar No. 493700)
Krum Ryan LLP
1050 Connecticut Avenue, NW
10th Floor
Washington, D.C. 20036
(202) 772-3100
ryan@krumryan.com
Counsel for Jeremy P. Ridgeway
Dated: July 13, 2015

In addition, Mr. Ridgeway understands the importance of providing restitution to the family of Dr.
Mahassin Mohssen Kadhum Al-Khazali and to Mr. Abdul Wabah Abdul Qadar Al-Qalamchi and his
family, and to any other victims that the Court directs, and is willing to do so, in an amount
commensurate with his ability to pay, and pursuant to a payment plan.

53