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Case 3:16-cr-00089-AWT Document 38 Filed 07/18/16 Page 1 of 14

UNITED STATES DISTRICT COURT


DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA


vs.
BRADLEY COMMERFORD

:
: CRIMINAL NO. 3:16-CR-00089 (AWT)
: July 18, 2016

MEMORANDUM IN AID OF SENTENCING


Bradley Commerford has been blaming himself for the heroin overdose of his best friend for
the past ten years. It does not matter that Bradley was only ten years old when it happened, or that it
was Bradleys 23-year-old sister who had actually provided the heroin both to Bradley and to his
friend. For Bradley, like many others who suffer from Post-Traumatic Stress Disorder, the drive
towards self-recrimination arises not from logic, but rather from logic-defying trauma. Bradley, at
age 20, now faces sentencing because he distributed heroin, the very drug that killed his friend ten
years ago. The parallel between these events invites a question: how could a person who watched
his friend die of a heroin overdose at age ten ever use, let alone sell, heroin? The following
memorandum both addresses that historical question and explains why, looking forward, a sentence
of one year and a day, coupled with strict conditions of supervised release including mental health
and addiction treatment, is the most appropriate sentence both to punish Mr. Commerford for his
actions and to direct Mr. Commerford towards an adult life that moves beyond the trauma and
disorder of his childhood and adolescence.

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Birth to Age Ten: Never a Cry Baby


Bradley Commerford was born on October 6, 1995, in Derby, Connecticut, to Helen
Overton and Sean Commerford. Bradley recalls his childhood as a basically happy one in which his
needs were well taken care of. Occasional family trips to go camping or to Six Flags are the things
that stand out in his memory.
Bradleys cheerful recollections of early childhood accord with his mother Helens
recollection of Bradley as a positive-spirited child, a good kid who was never a cry baby. PSR
64. Bradleys godfather, Michael Haas, a social worker who works for the State of Connecticut,
similarly recalls in the letter attached as Exhibit A, that Brad was always an incredibly respectful
and likeable young man. A young man with a bright future. My earliest memories of Brad are of his
infectious smile, his positive disposition and his genuine kindness. He was a staple of all our family
camping trips. Always showing a quick wit and strong sense of humor.

[Bradley, left, and Bradley with his sister Angela, right]


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In Bradleys case, however, not being a cry baby and maintaining an infectious smile
was no mean feat, and his positive attitude reveals genuine resilience in the face of a childhood of
chronic instability and stress. As Helen Overton writes in the letter attached as Exhibit B, Bradley
was impacted by my own and his fathers struggles with alcohol at a young age and was raised in
poverty which was also very hard on him. Through it all he had a sweetness and kindness to him
that defied the struggles he endured. His half-sister Angela Krasowski describes the essence of this
struggle succinctly in her letter attached as Exhibit C: we all grew up in a home with two addicted
parents who also suffer from mental illness.
As a result of his parents substance use, legal problems, and shifting romantic
relationships, Bradley lived such a chaotic life that the chronology is difficult to piece together.
When Bradley was an infant, his mother was arrested for driving under the influence and
subsequently served a month in prison. Shortly thereafter, his parents separated for a period and
Bradley lived principally with his mother. The two reconciled and again lived together until Bradley
was approximately five years old, at which time Helen Overton was again convicted of driving
under the influence and spent several months incarcerated. As a result, Sean Commerford, who
suffers from paranoid schizophrenia severe enough that he receives disability benefits, obtained full
legal custody of both Bradley and his older brother, Sean Jr. Connecticut Department of Children
and Families (DCF) records from this period offer a window into Bradleys life during this time.
Excerpted records are submitted separately under seal as Exhibit D.
In November of 2003, when Bradley was eight years old, DCF investigated Sean
Commerford based upon a police officers complaints that Mr. Commerford was regularly
intoxicated and on one occasion struck Bradleys older brother with a belt, an incident that led
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Bradley to run from the home to the residence of an older sister. In the ensuing DCF investigation,
Bradley denied knowing why he ran to his half-sisters house and denied that his father regularly
drank. Nothing further came of the investigation; several months later Sean Commerford was
arrested and subsequently convicted for driving under the influence.
This investigation came on the heels of a series of prior DCF inquiries. In April of 2003,
when Bradley was seven, DCF had previously investigated Sean Commerford as a result of a report
that he has a problem with addiction to alcohol and crack cocaine, in addition to marijuana use,
drives people around to buy drugs, telling the children that he has gone to the store, and that at
times [Bradley and Sean Jr.] cannot rouse their father and have to put themselves to bed. The
children are afraid of the father and intimidated by him. These reports were deemed
unsubstantiated for lack of sufficient evidence, as were a series of earlier reports, including one in
2001 in which Bradley came to school this morning told his teacher, Miss Schmidt that yesterday
his father was drinking a lot. He said that he father also takes pills a lot. He said that the pills make
him fall asleep. Bradley told father he was worried that father was drinking taking pills. Bradley
said that father got angry with him and slapped him across the face.
In each of these instances, when questioned by DCF, Bradley denied that his father drank
excessively and minimized any other problems. DCF investigators consistently noted Bradleys
positive demeanor. In her letter, Bradleys older half-sister Angela, a teenager at the time of these
earlier DCF investigations, offers this very different recollection of Bradleys home life as a child:
Sean was mad at my mom a lot and didnt know to care for us all on his own. His anger would get
the best of him especially when he was drinking. He took his frustrations out on us and Bradley
being the youngest would cry a lot during these times. Exhibit C.
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Bradleys parents reunited when he was approximately eight years old, and DCF did not get
involved in his life again until 2006, when he was ten. Then, on the night of May 6, 2006, Angela
Krasowski picked Bradley and his friend Frank up from his parents house. What happened that
night is detailed in the video statement by Ms. Krasowski, who is presently serving a 17-year
sentence for manslaughter arising from the heroin overdose death of Bradleys best friend, Frank.
That statement is submitted via disk as Exhibit E.
Ages Ten to Twenty: The Aftermath of Trauma
Bradleys struggles in the years that followed his friends death are documented in the
Presentence Report and include problems in school and ultimately expulsion, escalating drug abuse,
and ultimately trouble with the law. In anticipation of sentencing, Dr. Laurie Edwards, PsyD, a
clinician in psychiatry affiliated with the Yale School of Medicine, conducted a forensic mental
health examination of Bradley. Her report, based upon a review of records and interview with
Bradley, is submitted under seal as Exhibit F.
The principal findings of the report are that, under the criteria set forth in the Diagnostic and
Statistical Manual of Mental Disorders (DSM), Bradley suffers from severe opiod and cannabis
dependence, both of which have entered early remission since his detention. Bradley also suffers
from Post-Traumatic Stress Disorder. The report explains:
During the present evaluation, this writer asked Mr. Commerford to describe the incident in
which he witnessed his best friend die of a heroin overdose and asked how, if at all, the
incident continues to impact him. Based on his narrative, he was found to meet criteria for
PTSD, based on DSM criteria.
A. Mr. Commerford witnessed his best friends death. His friend died of an overdose
when Mr. Commerfords adult sister provided both boys with heroin;

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B. Mr. Commerford experiences intrusive thoughts about his friends death and his
sisters subsequent incarceration. He stated, When it comes to mind, I get stuck, tossing
and turning ... Now that Ive been in jail, Im thinking, I hate this place and I put my
sister there for 10 years;
C. Mr. Commerford avoids stimuli associated with the event. He stated, I block it out;
D. Mr. Commerford experiences negative alterations in thinking and mood associated
with the event. Despite the fact that he was only 10 years old at the time of his friends
death, he believes that he is guilty for what happened and that he can never be forgiven.
Although his adult sister gave Mr. Commerford and his friends the heroin, he believes
that he is at fault for his friends death because he suggested that he and his friend go to
visit his sister. He also believes that he is responsible for his sisters incarceration,
stating I didnt know what to say and not. I was the only witness. I basically ratted on
my own sister. I wouldve done things differently. I wouldve said it was my fault
because I suggested that we go to her house. I was just stupid ... This is me getting
punished for what I did when I was 10;
E. Mr. Commerford experiences alterations in arousal and reactivity associated with the
event. Since the event, he has exhibited irritable behavior and angry outbursts as well as
reckless and self-destructive behavior;
F. The disturbances have lasted for more than one month following the traumatic event;
G. The distress has contributed to impairment in social functioning; and
H. The disturbance is not attributable to the physiological effects of a substance or
another medical condition. Although Mr. Commerfords presentation is complicated by
his history of co-occurring substance dependence, he continues to experience symptoms
even though he has not had access to drugs for the past four and a half months.
Exhibit F at 10-11.
As the above list suggests, PTSD presents a complex constellation of symptoms. The
following definition, from a 2015 article in the journal Neurobiology of Stress, offers this succinct
synthesis:
Post-Traumatic Stress Disorder (PTSD) is a debilitating condition affecting soldiers,
veterans and civilians alike, often leading to substance abuse, loss of work and erosion of
family life. Trauma during childhood can be particularly devastating, and can have life-long
debilitating consequences. Over the last 25 years, studies in animals have begun to reveal
how stress alters brain physiology, providing new strategies for treatment. Exposure to stress
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markedly impairs the executive functions of the highly evolved prefrontal association cortex
(PFC), while simultaneously strengthening the primitive emotional responses of the
amygdala and the tonic firing of the noradrenergic (NE) locus coeruleus (LC), three brain
regions that are intimately interconnected.
Arnsten, Amy FT, et al. The effects of stress exposure on prefrontal cortex: translating basic
research into successful treatments for post-traumatic stress disorder. Neurobiology of Stress 1
(2015): 89-99. As this definition suggests, through PTSD traumatic past experience persists as
something more real and present than just a bad memory, and it drives self-destructive behaviors
like drug use into adulthood. Indeed, there is a robust literature demonstrating the negative mental
health consequences of childhood trauma, as well as a growing literature demonstrating that PTSD
mediates the relationship between trauma and addiction. Cross, Dorthie, et al. Childhood trauma,
PTSD, and problematic alcohol and substance use in low-income, African-American men and
women. Child abuse & neglect 44 (2015): 26-35.
Whats more, the effects of childhood trauma on subsequent addiction and depression is
cumulative. A study examining adverse childhood experiences on subsequent problems in early
adulthood found that there is a connection between levels of adversity in childhood and
comorbidity in early adulthood. Put another way, cumulative disadvantage appears to predict
cumulative dysfunction. Mersky, J. P., J. Topitzes, and A. J. Reynolds. Impacts of adverse
childhood experiences on health, mental health, and substance use in early adulthood: A cohort
study of an urban, minority sample in the US. Child abuse & neglect 37.11 (2013): 917-925. 1

See also Agorastos, Agorastos, et al. The cumulative effect of different childhood trauma types
on self-reported symptoms of adult male depression and PTSD, substance abuse and health-related
quality of life in a large active-duty military cohort. Journal of psychiatric research 58 (2014): 467

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The Mersky study included the following categories that qualify as adverse childhood
experiences that may trigger subsequent mental and physical health and addiction issues:
(1) household Child Protective Service (CPS) record for reported abuse or neglect, (2)
personal victim or witness of violent crime, (3) parent substance abuse, (4) prolonged
absence of parent, (5) divorce of parents, (6) death of close friend or relative, (7) frequent
family conflict, and (8) family financial problems.
Id. Strikingly, every single one of these featured prominently in Bradley Commerfords childhood.
That Bradley managed to cope admirably with these stressors through his early childhood is
remarkable. What is neither remarkable nor surprising is that eventually the accumulated stresses,
particularly the PTSD he suffers in connection with his friends overdose death, led him as a
teenager on a path of escalating drug abuse and disciplinary problems.
Prior to Dr. Edwards evaluation, it appears that Bradley had never been formally diagnosed
with PTSD, though he received some counseling and treatment in the aftermath of his friends
death. More recently, treatment has focused on Bradleys significant addiction issues. As Dr.
Edwards report notes, Bradleys co-occurring addictions complicate recognition of PTSD, but his
time in remission from drug use clarifies the diagnosis. So too, for that matter, does Bradleys
growing self-awareness and willingness to talk about what has happened in his past. These
developments have made it possible, for perhaps the first time, to begin developing a treatment
regimen tailored to addressing Bradleys PTSD alongside his addiction.

54. (The major finding of our study is the cumulative adverse effect of different CT [childhood
trauma] types on adult PTSD and depression symptoms, as well as mental and physical HRQoL
showing a dose-dependent relationship with increasing number of CT types experienced. While
history of a single CT type had at most a weak association with these adult outcomes, the
independent association of several experienced CT types showed a definitive effect on adult risk.)
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A Base Offense Level of 26 Does Not Meaningfully Reflect Mr. Commerfords Culpability.
Bradley Commerford, suffering from severe opiod dependenceheroin addictionsold
heroin in order to buy heroin to support his addiction. A 20-year-old, he bought heroin with people
approximately his age. He used heroin with people approximately his own age. He also provided
heroin to people of approximately his age, including an eighteen year old and his sixteen-year-old
girlfriend.
As a result of the age of one of the people who bought heroin from Bradley, the Sentencing
Guidelines assign a base offense level of 26, an offense level typically reserved for defendants
responsible for half a kilogram of heroin. The offense level of 26 is not based upon the Sentencing
Commissions studied empirical analysis; rather, as the provisions commentary states, [t]his
section implements the direction to the Commission in Section 6454 of the Anti-Drug Abuse Act of
1988. The statutory language referenced in the commentary states, specifically, that:
Pursuant to its authority under section 994(p) of title 28, United States Code, and section 21
of the Sentencing Act of 1987, the United States Sentencing Commission shall promulgate
guidelines, or shall amend existing guidelines, to provide that a defendant convicted of
violating sections 405, 405A, or 405B of the Controlled Substances Act (21 U.S.C. 845,
845a or 845b) involving a person under 18 years of age shall be assigned an offense level
under chapter 2 of the sentencing guidelines that is
(1) two levels greater than the level that would have been assigned for the underlying
controlled substance offense; and
(2) in no event less than level 26.
PL 100690 (HR 5210), PL 100690, November 18, 1988, 102 Stat 4181. In setting the base
offense level in all cases involving a person under the age of 18, the Sentencing Commission did
what Congress ordered.

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As the United States Supreme Court has recognized, where a particular guideline provision
does not reflect the Commissions characteristic institutional role and [does] not take account of
empirical data and national experience, Kimbrough v. United States, 552 U.S. 85, 109 (2007)
(internal quotation marks omitted), but rather mechanically follows the political dictates of
Congress, the ordinary assumption that the Guidelines will form the starting point of a Courts
analysis does not necessarily apply. Indeed, addressing the crack cocaine guidelines, the Supreme
Court has explained that under the logic of Kimbrough, district courts are entitled to reject and
vary categorically from the crack-cocaine Guidelines based on a policy disagreement with those
Guidelines. Spears v. United States, 555 U.S. 261, 265-66 (2009).
More generally, District judges are not permitted to treat the Sentencing Guidelines as
reasonable. The corollary of that proposition is that district judges have an obligation to consider
whether a sentence other than a Guidelines sentence would be sufficient, but not greater than
necessary, to serve the purposes of sentencing. 18 U.S.C. 3553(a). United States v. Corsey, 723
F.3d 366, 382 (2d Cir. 2013), as corrected (July 24, 2013) (Underhill, J., concurring) (citation
omitted). The potential disconnect between the politically-generated offense level of 26 assigned by
2D1.2(a)(3) and the appropriate sentence under 3553(a) is particularly dramatic. As a judge in
the Eastern District of Wisconsin explains in one of the very few written decisions addressing this
section: 2
Section 2D1.2(a)(3) treats all offenders who deal drugs to minors the same, but under
3553(a) the court can make a more refined assessment. A cocaine or methamphetamine

A Westlaw search for 2D1.2(a)(3) across all federal jurisdictions returns only 11 cases, one of
which refers to the provision only due to a typographical error.
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dealer who targets grade school children should obviously be treated more harshly than
someone . . . who sells a small amount of marijuana to a person on the cusp of adulthood.
United States v. Kerner, No. 10-CR-146, 2011 WL 832254, at *5 (E.D. Wis. Mar. 3, 2011). The
provision likewise draws no distinction between a 40-year-old who targets children and a teenager
selling to friends. Nor, for that matter, does it differentiate between a drug dealer who strategically
uses a 10-year-old as a drug courier to avoid getting caught by police and a drug user who sells to
whoever will buy in order to have enough money to keep withdrawal at bay.
Bradley Commerford, addicted to heroin and battling the psychic demons of past trauma in
ways he himself could not have recognized, regularly bought heroin. He bought more than he
needed for himself and he resold some of the heroin so that he would have enough money to buy
more heroin. He sold heroin to two teenagersan eighteen year old and his sixteen-year-old
girlfriendand as a result Congress has specified that he is to spend at least one year in prison.
Congressional dictate, however, does not explain why, in this case, Bradley Commerford should be
sentenced to a period of incarceration roughly five times longer than a person convicted of selling a
small quantity of heroin.
A Criminal History Category of III Overstates Bradley Commerfords Criminal History.
Bradley Commerford has stood before a criminal sentencing judge exactly once before in his
life. He has never served any prison sentence. Nevertheless, at age 20 he has five criminal history
points and falls into Criminal History Category III. Mr. Commerford was arrested three times in a
four-month period beginning in May of 2014, by which time he was already battling a severe
addiction. In connection with each of the arrests he ultimately received a non-prison sentence. The
present case occurred while Bradley was on probation in connection with these convictions.

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The Second Circuit has recognized that the fact that a [criminal history category] may
overrepresent a defendants likelihood of recidivism permits a sentencing court, in appropriate
cases, to include in its individualized consideration of a section 4A1.3 departure the relationship
between the punishment prescribed by a . . . CHC and the degree of punishment imposed for prior
offenses. United States v. Mishoe, 241 F.3d 214, 220 (2d Cir. 2001) (addressing specifically
departure from Career Offender criminal history category). As the Mishoe court further noted, a
significant part of the logic behind lengthy sentences is that prior sentences have failed to deter the
defendant from crime and so further punishment is in order. See id.
This is far from a case in which a defendant has time and again failed to respond positively
to prison sentences in such a way as to suggest that a lengthy sentence is necessary to deter future
misconduct. Quite the opposite: Bradley Commerford has never previously served a prison
sentence. He accumulated all of his prior convictions over a brief period during which he was, to
put it plainly, a drug-addicted, traumatized teenager.
While treatment and rehabilitation are not legitimate reasons to impose a prison sentence,
Mr. Commerfords time in pretrial detentionalready the longest period he has ever spent in
custodyhas brought about early remission of his addictions, as noted in the forensic mental health
report. He is no longer a teenager, and while he is far from being a fully developed adult, he has
noticeably matured over the course of this case. As Dr. Edwards notes, he has a budding internal
motivation to remain abstinent from all drugs. He has positive goals for the future, including
completing school and obtaining employment as a welder, having a family, and protecting any
children that he has from exposure to drugs. He has also now been diagnosed with PTSD, a
disorder that is often debilitating and intimately associated with addictionbut also one that is
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treatable, particularly with the appropriately focused therapies. Bradleys criminal history does not
reflect a pattern of conduct that can fairly be said to predict his future behavior. Rather, it speaks to
the mess of addiction and trauma that has exacerbated a period of late adolescence that is at best
chaotic for most teenagers asked to navigate the world of adulthood equipped with a brain that has
yet to reach real maturity.
A Sentence of One Year Followed by Intensive Treatment and Supervision Is Properly
Tailored to Accomplish the Goals of Sentencing under 3553(a).

Bradley will celebrate his 21st birthdaya traditional milestone of adulthoodin prison. As
a twenty year old who has never served a prison sentence, a yearlong prison sentence will be a
shock and will send a clear message that the path he has been on cannot continue. Beyond that oneyear mandatory sentence, what is called for in this case is not further incarceration, which will not
solve the problems underlying Bradleys drug use and consequent distribution. What is needed,
rather, is treatment and structured supervision, something that the United States Probation Office is
well equipped to provide, particularly with an order from the Court requiring Bradley to participate
in treatment. More, while Bradley has had a difficult childhood, upon his release he will have the
support of his parents as well as people like his godparents. His godfather Michael Haas writes in
Exhibit A that I hope to have a strong relationship with Brad as he gets older and serve as a
mentor in his life. Bradleys godmother, similarly, writes in the letter attached as Exhibit G, that
[w]hen [Bradley] comes home, I will support him with his recovery.
Mr. Commerfords adult life is just now beginning, and this Court has an opportunity to set
Mr. Commerfords life on a trajectory that, through treatment of his addiction and underlying
PTSD, points him in a direction away from further drug use and crimean outcome that leaves Mr.
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Commerford a productive member of society and not a threat to it. A substantial prison sentence in
this matter would be a missed opportunity that would substitute prison time for real treatment
during a critical period in Mr. Commerfords development towards adulthood. With respect to
PTSD, time does not heal all wounds. It merely lets them fester.
CONCLUSION
For the reasons above, Defendant respectfully requests that the Court sentence Bradley
Commerford to a prison sentence of one year and one day, followed by a period of Supervised
Release to include mental health and drug addiction treatment.
Respectfully submitted,
THE DEFENDANT,
Bradley Commerford
OFFICE OF THE FEDERAL DEFENDER

Dated: July 18, 2016

/s/ James P. Maguire


James P. Maguire
Assistant Federal Defender
265 Church Street, Suite 702
New Haven, CT 06510
Phone: (203) 498-4200
Bar No.: ct29355
Email: James_Maguire@fd.org

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 18, 2016, a copy of the foregoing Memorandum in Aid of
Sentencing was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of
this filing will be sent to all parties by operation of the Courts electronic filing system or by mail to anyone
unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing
through the Courts CM/ECF System.

/s/ James Maguire


James Maguire

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Case 3:16-cr-00089-AWT Document 38-1 Filed 07/18/16 Page 2 of 3

Re:

United States v. Bradley Commerford


Docket No.: 3:16-CR-00089 (AWT)
Honorable Alvin W. Thompson
United States Courthouse
450 Main Street #240
Hartford, Connecticut 06103

My name is Michael Haas. I am the maternal uncle and godfather of Bradley


Commerford. I am a lifelong resident of Connecticut and currently reside in Stratford with my
wife and children.
I am employed as a social worker with the State of Connecticut. My wife is a certified
psychiatric nurse. We both work with families on a daily basis who struggle with cycle and
tragedy of addiction. I have also experienced the tragedy of addiction within my own family.
I have known Bradley Commerford his entire life.
Brad was always an incredibly
respectful and likeable young man. A young man with a bright future. My earliest memories
of Brad are of his infectious smile, his positive disposition and his genuine kindness. He was a
staple of all out family camping trips. Always showing a quick wit and strong sense of humor.
A vivid memory of Brad is of him and all his cousins burying and digging up a time capsule on
one of our annual trips.
Brad was always first to try something, such as a rope-swing or water skiing to model for
his younger cousins, to make them feel comfortable, and show them they had nothing to fear.
As a young man Brad showed an intelligence that made the family believe that he had the
qualities to make a true positive impression on the world. I have always known Brad to be a
good son, grandson, brother and cousin.
In 2006, Brads life did take a horrible turn when a good friend of his died unfortunately
from a heroin overdose. Brad was so young at the time that we were all concerned with how this
might impact his life. We all hoped that he would turn away from the dangers of addiction.
We did not realize how wrong we would be.
I understand that Brad has succumbed to his addiction and it has impacted him and many
of the people around him. I am aware that Brad has pled guilty to distribution of heroin to a
person who is under 21 years old. I know Brad has expressed remorse for these actions.
I could only hope and pray that Brad will get the help he needs to truly overcome his
addiction and once again become a productive member of society. Brad is a young man with so
much to offer. I hope to have a strong relationship with Brad as he gets older and serve as a
mentor in his life.

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EXHIBIT B

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June 22, 2016


Honorable Alvin W. Thompson
United States Courthouse
450 Main Street #240
Hartford, CT 06103
Dear Judge Thompson,
My name is Helen Overton and I am writing to you on behalf of my son Bradley Commerford who is to
be sentenced in your court and has pleaded guilty to distributing heroin to a person who is under 21
years old.

Bradley has not had an easy life; he was impacted by my own and his fathers struggles with alcohol at a
young age and was raised in poverty which was also very hard on him. Through it all he had a sweetness
and kindness to him that defied the struggles he endured. He was always such a happy and curious boy
who took it upon himself to help out around the house without being asked thinking that by working
hard it would help to make our situation better. He is an exceptional uncle to his nieces and truly
enjoyed spending time playing with and guiding them. He was a hard working student and all his
teachers always raved about him. In fact, that was the theme throughout Bradley's life in work and
school; he was always a favorite because of his great work ethic and cheerful disposition.
He really was such a good boy, but started having troubles in junior high school hanging around with the
wrong crowd and experimenting with marijuana, which at the time I was ill equipped to get him the help
I knew he needed. Most recently (about six months before the incident at hand with him and all his
friends), all the kids started using heroin and that is when the son I knew changed.
Bradley and Louis Ahern loved each other and were very close since they were young. I was quite fond
of Louis myself as he spent many days and evenings at my home throughout the years. Louiss loss is a
tragedy that shouldnt have happened, but unfortunately he made a choice to use heroin and my heart
truly goes out to his family and I understand completely that they want justice for their son but in my
heart I know that addiction is a tough battle. The truth of the matter is that they both went down the
wrong road together . Regardless, Bradley will have to live with the loss of his friend for the rest of his
life, and the what ifs that go along with it. No sentence you give him will ever be a greater punishment
than that.
In speaking to my son about this case I can only say that he understands the gravity of what happened
and is extremely guilt ridden and remorseful over his actions. I find my son, in his grief for his friend,
much wiser and more reflective of his past actions and deeds that led to this ultimate tragedy. My hope
is that what happened will spur my son into getting the help he needs. I know how hardworking and

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industrious he is, and given the chance, can and will contribute positively to society. I feel that the
addiction he suffers with heroin is new enough that it need not be lifelong, and with the proper help
along with the lessons learned he will become the man that God intended him to be. I know in my
heart that this is what Louis would have wanted for him.
While Bradley needs some time away to work on his problems, a long prison sentence will in essence
throw another promising very young life away. I pray that God grants you the wisdom that will allow
you to pass a sentence that gives some measure of justice and peace for Louiss family, but also one that
gives Bradley the opportunity to redeem his life as I know for sure in my heart that he is not past the
point of no return.
I sincerely thank you for taking the time to read this letter and I have faith that your judgment will be
fair and just.
Sincerely,
Helen Overton

Case 3:16-cr-00089-AWT Document 38-3 Filed 07/18/16 Page 1 of 5

EXHIBIT C

Case 3:16-cr-00089-AWT Document 38-3 Filed 07/18/16 Page 2 of 5

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Case 3:16-cr-00089-AWT Document 38-3 Filed 07/18/16 Page 3 of 5

Case 3:16-cr-00089-AWT Document 38-3 Filed 07/18/16 Page 4 of 5

Case 3:16-cr-00089-AWT Document 38-3 Filed 07/18/16 Page 5 of 5

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Case 3:16-cr-00089-AWT Document 38-4 Filed 07/18/16 Page 1 of 2

Case 3:16-cr-00089-AWT Document 38-4 Filed 07/18/16 Page 2 of 2