Case 3:16-cr-00089-AWT Document 45 Filed 07/22/16 Page 1 of 16

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA

Crim. No. 3:16cr89(AWT)

v.
BRADLEY COMMERFORD

July 22, 2016

GOVERNMENT=S SENTENCING MEMORANDUM

The government respectfully submits this sentencing memorandum in connection with the
defendant Bradley Commerfords (Commerford) sentencing hearing on July 28, 2016. For the
reasons set forth below, the government asks that the Court adopt the findings of fact in the PreSentence Report (PSR) and conclude that the guideline range for the offense is 57-71 months
incarceration. The government respectfully requests a sentence at the top of that range and, for
the reasons set forth below, argues that such a sentence is sufficient, but not greater than necessary,
to reflect the purposes of a criminal sanction set forth in 18 U.S.C. 3553(a).
I.

BACKGROUND
On May 6, 2016, Commerford waived his right to be indicted and pleaded guilty to a one-

count Information charging him with distribution of heroin to an individual who is under 21 years
of age, in violation of 21 U.S.C. 841(a)(1) and 859. The offense carries a statutory mandatory
minimum incarceration term of 12 months and a maximum term of 40 years. In the plea agreement,
the parties stipulated that the base offense level was 26 because Commerford distributed heroin to
an individual who was under 18 years of age. With a three-level reduction for acceptance of
responsibility, the parties agreed that the total offense level was 23.
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In addition, the parties calculated that Commerford fell into Criminal History Category III
with five criminal history points. They reserved their respective rights to re-calculate the criminal
history category should this initiate estimate prove to be inaccurate.
A total offense level of 23 with a Criminal History Category III, resulted in a guideline
incarceration range of 57-71 months. Both sides reserved their rights to seek a sentence above or
below that range. Commerford waived his right to appeal or collaterally attack his sentence
provided that it did not exceed 57 months in jail, a life term of supervised release and a $1 million
fine. The government agreed not to appeal any sentence of 24 months incarceration or greater.
Had this case proceeded to trial, the government would have proven the following: on
February 16, 2016, members of the Shelton Police Department responded to a reported heroin
overdose of an 18-year-old male, Nick Boland, at a residence located on Center Street in Shelton,
CT. Medical assistance was rendered to Boland, who was subsequently transported to the Griffin
Hospital in Derby, Connecticut for evaluation and treatment. Boland was treated and released from
the hospital. While at the residence, a 16-year-old female who was Bolands girlfriend and who
will be referred to herein as Minor 1, stated to law enforcement that Boland does in fact snort
heroin. While at the hospital, law enforcement attempted to speak with Boland, however, he
initially refused to answer questions of law enforcement.
On the evening of Bolands overdose, members of the Shelton Police Department spoke
with another friend of Minor 1s, who provided a telephone number of 203-892-8592 as the
telephone number belonging to the heroin source of supply for Boland. He said that Brad sold
heroin to Boland.
On February 17, 2016, DEA TFO Brian McPadden and Shelton Police Detective Nugent
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attempted to speak again with Boland and Minor 1. They both discussed the overdose that occurred
on the previous day and stated that Brad was the heroin source of supply for the supplied heroin.
They observed social media photographs and law enforcement photographs of Commerford and
identified the photographs as Brad, the source of supply for Boland. Boland said that he
purchased five bags of heroin, sniffed one bag of heroin and that, within seconds, he knew
that he was overdosing.
While speaking with law enforcement, Minor 1 stated that, on February 16, 2016, there
was a second heroin overdose, 22-year-old Shane Lagasse, and that Commerford was also the
heroin source of supply for Lagasse. Minor 1 provided the identity of Lagasse, and the DEA
confirmed his identity. According to Minor 1, on February 16, 2016, Lagasse had also been
transported to Griffin Hospital by one of Minor 1s friends who also happened to be Commerfords
ex-girlfriend. Law enforcement had not been aware of Lagasses heroin overdose at the time.
After receiving the information, they tried to speak with Lagasse. He acknowledged the heroin
overdose, but would not identify his source or answer any questions of law enforcement.
On February 18, 2016, the DEA provided an administrative subpoena to Griffin Hospital
for patient records of Lagasse. The records showed an admission for him for a heroin overdose on
February 16, 2016. Members of the DEA and Shelton Police Department continued to try to speak
with Lagasse at that time, but he refused to speak to them.
On February 17, 2016, at approximately 5:43 a.m., members of the Derby Police
Department responded to a medical emergency, which was determined to be a heroin overdose of
twenty-three-year-old Louis Ahearn at a residence in Derby. Medical assistance was rendered to
Ahearn, but he died after being transported to Griffin Hospital. The Medical Examiners report
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would later confirm that he died from acute fentanyl intoxication.

DEA TFO McPadden was able to speak briefly with Ahearns mother, Gina Mattei, who
reported that, approximately one week earlier, he had told her that he was using heroin and that
his heroin source of supply was an individual with the first name of Brad. Following this
interview, Ms. Mattei provided his cellular telephone to law enforcement. The telephone number
used by Ahearn was in frequent contact with telephone number 203-892-8592. Ms. Mattei and her
20-year-old son (Louiss younger brother) subsequently confirmed that Ahearn had gotten heroin
from Commerford the night before his death. They described Commerford as someone who would
manipulate and use Ahearn for car rides and other favors. And they described Louis as someone
who had never before used heroin, who was trusting and somewhat gullible and who had struggled
throughout his school years as a result of a diagnosed learning disability.
On February 17, 2016, the DEA issued an administrative subpoena to Verizon requesting
subscriber information and toll records related to telephone number 203-892-8592. According to
Verizon, this telephone number was subscribed to Sean Commerford, who is Commerfords father.
Also, according to Verizon, the telephone was in the account name of Bradley Commerford,
effective January 18, 2016 through February 16, 2016 and was in the account name of Sean
Commerford from December 16, 2015 through January 18, 2016.
On February 17, 2016, the DEA conducted a search of telephone number 203-892-8592
within a query function available on the social media website Facebook. The result of the query
showed that telephone number 203-892-8592 was associated with a Facebook profile of Brad
Commerford.
On February 17, 2016, members of the Monroe Police Department conducted an electronic
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analysis of Ahearns cell phone. Members of the DEA conducted an analysis of the telephone
text messages recovered as a result of the electronic analysis. A search of the telephone contact
list for Ahearn revealed that telephone number 203-892-8592 was associated with Brad.
Ahearns telephone number was in frequent contact with 203-892-8592.
Ahearns telephone had numerous saved, stored text messages with Commerfords
number. For example, on July 30, 2015, from approximately 3:24 p.m. through 3:30 p.m., the
following text message conversation took place between Ahearn and Commerford: Commerford
stated, Yo nigger, Im back home. Ahearn stated, Whos this. Commerford stated, Its
brad u dont got my num saved lol. Ahearn responded, Nah got a new phone dude. Commerford
stated, Ok call me when u can.
There were also several saved text messages during the time frame relevant to the overdose.
On February 14, 2016, from approximately 10:29 p.m. through 11:49 p.m., the following text
message conversation took place between Ahearn and Commerford: Ahearn stated, Address??
Commerford replied, 19 dusty lane, Newtown cr. Ahearn stated, lght, Outside nigga,
Yoo, Yo go near ur phone nigga. Commerford replied, Can u check the car and see if I
dropped money dude, Please dude I'll throw u a bag if u find it in looking everywhere.
On February 16, 2016, at approximately 11:02 p.m., the following text message
conversation took place between Ahearn and Commerford: Ahearn stated, At the door.
Commerford stated, Comin. Ahearn states ight.
A search warrant executed on Verizon on February 18, 2016 resulted in the seizure of
approximately ten days worth of text messages sent and received by Commerfords cell phone
(from February 7, 2016 through February 17, 2016). These text messages established that
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Commerford regularly distributed both heroin and marijuana during this time period.
On April 5, 2016, the DEA conducted a more in-depth interview of Minor 1, with her
parents present. Minor 1 is only 16 years old. She said that she met Commerford in May 2015,
that she regularly purchased marijuana from him, and that she started purchasing heroin from him
in January 2016. She said that several of her friends who used heroin vouched for Commerford as
a good source of supply. She described Commerford as her normal dealer. She explained that,
on the night of Bolands overdose, she had purchased six bags of heroin from Commerford for
$40. Though she had been warned by one of her friends that this batch was strong and not to do
more than one bag of it at a time, she was not thinking anything of it at that point. She and
Boland had poured out the contents of three bags and shared it. A little later that evening, they
shared the contents of the other three bags. Boland began to overdose at this point. His lips
turned blue. He nodded out and was making strange noises. She immediately called 911 and a
friend whom she knew to have Narcan. Boland received two doses of Narcan that night (one from
Minor 1s friend and one from the EMS personnel).
Minor 1 said that she saw Commerford every day to purchase heroin from him. She said
that the most heroin she ever bought from him at one time was thirty bags. She also said that she
often bought heroin from Commerford for her friends.
On February 18, 2016, the DEA, working with local law enforcement, made plans to locate
and arrest Commerford on three outstanding state arrest warrants for violation of probation. They
received information that Commerford was residing with his girlfriend in Newtown, Connecticut
and set up surveillance on a suspect residence. They watched a male and a female leave the
residence, get into a vehicle and drive away. They followed the vehicle and conducted a traffic
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stop. They identified Brooke Bizewski as the operator and Commerford as the lone passenger.
Bizewski reported that they were going to Waterbury to purchase heroin from her source of supply
named Duke. Commerford had $765 on his person and a cell phone. Officers placed a call from
a DEA telephone to the number previously noted for Commerford and watched Commerfords
phone alert an incoming call.
The DEA and the Shelton Police interviewed Commerford after his state arrest. He was not
forthcoming during the interview with respect to distributing heroin to others. He did state that he
used heroin and knew about significant heroin distributors. He also said that he had been notified
of two heroin overdoses, including that of Ahearn. He became visibly upset when speaking about
Ahearn because he said he had known him for his entire life.
The PSR found that the base offense level, under Chapter Two of the November 1, 2015
version of the Sentencing Guidelines, was 26 because Commerford sold heroin to an individual
who was under 18 years of age. See PSR 32. After a three-level reduction for acceptance of
responsibility, the total offense level is 23. See PSR 39-41.
As to his criminal history, though Commerford is only 20-years-old, he has already been
convicted of three offenses in state court. Specifically, on January 5, 2016, he was convicted of
second degree threatening in connection with a June 19, 2014 arrest, possession with intent to
distribute in connection with an August 16, 2014 arrest and sale of a controlled substance in
connection with an October 23, 2014 arrest. See PSR 45-47. In all three of those cases, he
received concurrent sentences of probation. For the two drug cases, he received concurrent terms
of three years incarceration, execution suspended, and three years probation. See PSR 4647. He resumed his heroin dealing almost immediately after sustaining these convictions and was
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eventually arrested in this case on February 18, 2016. While incarcerated in state custody in this
case, he received one disciplinary ticket for fighting on May 26, 2016. See PSR 5.
Commerford has made an extensive sentencing submission in support of his argument for
a significant variance and a sentence of one year and one day in prison. He raises some important
points about his own addiction and upbringing and about the tragic death of his childhood friend
after his sister gave them both heroin at a young age. There is no doubt that this prosecution
exposes some deeply troubling issues for Commerfords family and shows his extreme need for
intensive mental health and drug treatment.
On the other hand, there are some deeply troubling aspects of Commerfords offense
conduct. He regularly distributed heroin to teenagers. He sold heroin on the immediate heels of
being convicted in state court of several serious felony offenses. Indeed, despite his numerous
arrests and court appearances, he has continued to distribute heroin without pause and without
regard to the damage it wreaks on those who use it. Even after the overdoses in this case, he
continued to sell heroin, as he was arrested while on the way to purchase heroin from his source
in Waterbury. And, of course, his conduct directly led to the untimely and tragic death of Louis
Ahearn, whose family submitted extensive impact statements to describe the loss of their loved
one. Louis Ahearn was not a heroin addict. He had never before used the drug until Commerford
introduced him to it a mere two weeks before his death. Ahearn was a trusting soul, and his family
has repeatedly insisted that the guideline range in this case is too low and does not account for the
damage done by the heroin that Commerford distributed.
Balancing all of these factors, the government has decided to seek a sentence of 71 months
incarceration, which is the top of the guideline range. There are certainly grounds for an upward
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variance based on the fact that Commerford distributed heroin which caused two non-fatal
overdoses and one fatal overdose and that he did so less than two months after being placed on
state probation for selling drugs, and, after hearing from both parties, the Court may decide that
such a variance is appropriate. But, in the governments view, a 71-month prison term
appropriately balances all of the factors under 3553(a) and is sufficient, but not greater than
necessary, to reflect these factors.
II.

DISCUSSION
After the Supreme Courts holding in United States v. Booker, 543 U.S. 220, 243-245

(2005) rendered the Sentencing Guidelines advisory rather than mandatory, a sentencing judge is
required to: (1) calculate[] the relevant Guidelines range, including any applicable departure
under the Guidelines system; (2) consider[] the Guidelines range, along with the other 3553(a)
factors; and (3) impose[] a reasonable sentence. See United States v. Fernandez, 443 F.3d 19,
26 (2d Cir. 2006); United States v. Crosby, 397 F.3d 103, 113 (2d Cir. 2005). The 3553(a)
factors include: (1) the nature and circumstances of the offense and history and characteristics of
the defendant; (2) the need for the sentence to serve various goals of the criminal justice system,
including (a) to reflect the seriousness of the offense, to promote respect for the law, and to
provide just punishment, (b) to accomplish specific and general deterrence, (c) to protect the
public from 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 set forth in the guidelines; (5) policy statements
issued by the Sentencing Commission; (6) the need to avoid unwarranted sentencing disparities;
and (7) the need to provide restitution to victims. See 18 U.S.C. 3553(a).
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The Second Circuit reviews a sentence for reasonableness. See Rita v. United States, 127
S. Ct. 2456, 2459 (2007). The reasonableness standard is deferential and focuses primarily on
the sentencing courts compliance with its statutory obligation to consider the factors detailed in
18 U.S.C. 3553(a). United States v. Canova, 412 F.3d 331, 350 (2d Cir. 2005).
In this case, the most significant 3553(a) factors are the seriousness of the offense
conduct, the personal characteristics of the defendant and the need for both specific and general
deterrence.
As set forth above, this case involves perhaps the most serious offense conduct in any drug
case. Commerford sold heroin that had devastating consequences. Two young men overdosed,
were transported to the hospital and survived, and a third young man overdosed and died. The
autopsy report for Ahearn confirms that the heroin Commerford was selling was either mixed with
fentanyl or was pure fentanyl. The evidence in this case would certainly have supported a charge
under 21 U.S.C. 841(b)(1)(C) because Commerford sold heroin that caused death. Such a
charge would have subjected him to a sentence of no less than 20 years in jail.
Another aggravating factor here is that Commerford is the reason Ahearn used heroin in
the first place. Louis was not a heroin user; he had never tried it or expressed any interest in it.
His mistake was that he was too trusting. Commerford, who grew up being friends with Louiss
younger brother, had recently befriended Louis and started asking him for rides. Louis obliged.
As the letters from his family and friends make clear, Louis was always there to help, always kind
and, in some ways, too willing to believe in others. His mother described him as follows: Louis
always went out on a limb to help others and he was eager to make friends. . . . He was a strong,
courageous, funny and loving man. He would help strangers and ask for nothing in return. He
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was innocent. Two weeks before his death, Louis, in pain from a recent dental procedure, asked
Commerford if he had access to pain medication. Commerford introduced him to heroin and told
him it was a cheaper alternative to prescription pills. Two weeks later, a bag of fentanyl provided
by Commerford would kill him.
Ms. Matteis powerful and heartbreaking letter, which is attached to this memorandum,
portrays the tragedy that caused her sons death and makes clear that Louiss overdose was, by no
means, typical. He was not a heroin addict. He was not a heroin user. He had only tried heroin
for the first time two weeks before his death, and it was Commerford who introduced it to him.
Ahearns family firmly believes that, if it had not been for Commerford, Ahearn would never have
used heroin and would still be alive. The undisputed facts here certainly support their view, and
this troubling fact only highlights the very serious nature of Commerfords conduct.
Moreover, this offense was serious because it involved the distribution of heroin to
teenagers. Though the defense suggests that Commerford was merely selling to his peers, that
argument is more difficult for Minor 1, who is just 16 years old and who easily could have
succumbed after ingesting one of Commerfords bags of heroin. Indeed, Minor 1s 18-year-old
boyfriend did overdose and was transported to the hospital after having been revived with narcan.
Another important 3553(a) factor is Commerfords personal characteristics. As the
defense points out, he had an extremely difficult childhood. He was raised by parents who had
serious substance abuse problems, and his sister went to jail for manslaughter after giving
Commerfords childhood friend a fatal dose of heroin. But Commerfords more recent interaction
with the criminal justice system cannot be ignored. This is not his first or second offense. He has
already been given several chances in state court. He was arrested three different times in 2014,
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two of which were for selling drugs. When he was sentenced on these three cases in January
2016, he received a fully suspended three-year sentence. According to Minor 1, Commerford was
selling her heroin in January 2016. So, there was really no break in his criminal conduct despite
these three arrests, and the fact of his state probation did nothing to deter him from selling heroin.
Also, even after he sold the heroin which caused the death of Louis, whom he described as a friend,
and the non-fatal overdose of two other customers, Commerfords drug dealing continued without
pause. On the day of his arrest, which was the day after Louiss death, Commerford was heading
to Waterbury to purchase several hundred dollars worth of heroin. Had he not been arrested, he
would have continued to distribute the same deadly heroin that he had provided to his customers
on February 16 and 17, 2016.
A third key factor in this case is general deterrence. According to statistics provided by the
Connecticut Medical Examiners Office, in 2012, there were 174 overdose deaths resulting from
the use of heroin. Of those deaths, only one involved a combination of heroin and fentanyl. By
2015, the number of heroin-related overdose deaths in Connecticut had increased to 415.
Fentanyl contributed to 107 of those deaths and played a role in 79 additional deaths. In January
and February 2016 alone, there were approximately 93 heroin overdose deaths, putting
Connecticut on track for the total number of such fatalities to equal or exceed 540 in 2016. This is
truly an epidemic. Despite numerous summits and forums attended by concerned educators and
parents, government officials, doctors, drug experts and law enforcement officers, the number of
overdose deaths continues to rise. The problem has impacted almost every town, every income
bracket and even children as young as thirteen years old. Though the arrest and prosecution of
heroin dealers will most certainly not have an immediate impact that stems the tide of these tragic
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overdose deaths, the federal incarceration of those who distribute fentanyl-laced heroin can send
a powerful message. A significant sentence here will have an impact. Commerford sold heroin
that had devastating results. In fact, law enforcement officers scrambled to arrest him to prevent
him from selling any more heroin since he had caused three overdoses in two days.
Specific deterrence is the fourth key factor here. Commerford presents a very high risk of
recidivism. He had been under state pretrial and post-conviction supervision for about an 18month period prior to his arrest here, and his conduct did not change at all. He was arrested three
separate times in 2014. Then, when he was finally convicted in all three of these cases and given
the benefit of a fully suspended sentence, he immediately, with virtually no break, returned to
selling heroin. The defense has argued and will argue that Commerfords recidivism is due to his
heroin addiction, his mental health problems, his lack of maturity and his difficult childhood. And
the government agrees that his risk of re-offending can be mitigated through specific conditions of
supervised release which provide him with intensive mental health counseling and drug treatment.
But the fact remains that his actions speak volumes and that he has an extremely poor track record.
Finally, it certainly bears mention that, though the government is not seeking an upward
departure, the guidelines certainly provide for one in this circumstance. U.S.S.G. 5K2.1 states
that [i]f death resulted, the court may increase the sentence above the authorized guideline range
. . . the extent of the increase should depend on the dangerousness of the defendants conduct, the
extent to which death or serious injury was intended or knowingly risked, and the extent to which
the offense level for the offense of conviction . . . already reflects the risk of personal injury.
Courts have applied 5K2.1 in drug distribution cases where a victim died of the drugs
supplied by the defendant. For example, in United States v. Nossan, 647 F.3d 822 (8th Cir. 2011),
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the Eighth Circuit affirmed an upward departure imposed by the district court where the defendant
had distributed heroin and cocaine on two occasions to a victim who died of a drug overdose. The
Eighth Circuit explained that the departure was warranted because the defendant engaged in
dangerous acts, disregarding the grave risks accompanying the issue of the drugs. Id. at 826; see
also United States v. Howard, 454 F.3d 700, 704 (7th Cir. 2006) (concluding that a relatively
modest increase in the guidelines range pursuant to 5K2.1 was appropriate to take into account
the death of a heroin customer); United States v. Grover, 486 FSupp.2d 868, 887 (N.D. Iowa 2007)
(granting an upward departure and concluding that while the guideline for drug offenses takes
into account some of the pernicious effects of heroin, it does not take into account death.).
Similarly, in United States v. Bradford, 499 F.3d 910 (8th Cir. 2007), the Eighth Circuit
concluded that the district court properly granted an upward departure on the basis that a customer
of the defendant had died from heroin sold by the defendant. The Eighth Circuit held that while
2D1.1(a)(2) was not applicable because the indictment did not charge the defendant with the
death, the courts determination that [the defendants] base offense level did not take death into
account was not erroneous, and the uncharged, relevant conduct (distribution resulting in death)
was a proper ground for departure. Id. at 919; see also United States v. Russow, 3:14cr84(JBA)
(departing upward under 5K2.1 from a range of 41-51 months to an incarceration term of 65
months because defendant sold heroin that caused a death).
There is no question that, under the guidelines, an upward departure is supported by the
facts here. Commerford knowingly distributed a dangerous and deadly drug to an individual he
knew had little experience with it. In fact, it was Commerford himself who introduced Ahearn to
the drug. Though Commerford expressed remorse when he talked to the police about Louis and
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referred to him as a friend, Louiss family vehemently disagrees with that characterization and
believes Commerford used and manipulated Louis, first introducing him to heroin and then
offering him free bags in exchange for favors and car rides. This conduct is reprehensible, even
when considered in the context of the many mitigating factors offered to explain Commerfords
heroin dealing.
III.

CONCLUSION
For the reasons stated above, the government respectfully asks the Court to adopt the

factual findings in the PSR, find that the guideline incarceration range in this case is 57-71 months,
and impose a guideline sentence of 71 months incarceration.
Respectfully submitted,
DEIRDRE M. DALY
UNITED STATES ATTORNEY
/s/ Robert M. Spector
ROBERT M. SPECTOR
ASSISTANT UNITED STATES ATTORNEY
FEDERAL BAR NO. CT18082
157 CHURCH STREET; 23rd FLOOR
NEW HAVEN, CT 06510
203-821-3700

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CERTIFICATION
I hereby certify that on July 22, 2016, the foregoing Sentencing Memorandum was filed
electronically. Notice of this filing will be sent by e-mail to all parties by operation of the Court=s
electronic filing system or by mail to anyone unable to accept electronic filing. Parties may access
this filing through the Court=s system.

/s/ Robert M. Spector

ROBERT M. SPECTOR
ASSISTANT UNITED STATES ATTORNEY

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July 6, 2016
You're Honor,
My life is forever changed. There are no words to describe the pain of losing a child.
Four days before my 23 year old son died, he .told me the following;
"Mom, I have been thinking about suicide. I have been doing a bad drug. I have been snorting
heroin." I asked him how long he has been doing this. He said "Two weeks". I asked him where
he got it? He replied "Brad."
I didn't call the police. I should have. I should have taken him to a hospital. I didn't. I will live
with the guilt for the rest of my life.
It will be your decision to determine how long Bradley Commerford will stay in prison for
giving my son a "free bag" of fentanyl which took his life on February 17, 2016.
'

'

'

Louis was not a drug addict. He was an innocent victim. His death was not accidental. Brad
Commerford is responsible. He is going to jail for selling heroin to a sixteen year old girl who
used drugs for months, maybe years and is alive today. My son, just seven years older then she,
who did not regularly use drugs is gone forever. Brad is responsible for the spreading a deadly
epidemic that is tearing lives apart.
I would like for you to know a little bit about my son. Louis David Ahearn was born 11 weeks
early on September 17, 1992. He was miraculously healthy other than the normal developmental
delays that are common with premature birth. Growing up he was joy. He was always happy
and easygoing. He rarely cried. He loved to be outside riding his bike and playing with his
younger brother David and his cousins with which he was very close.

From an early age when Louis started school he began receiving resources for learning
challenges. He struggled with memory and retention but he always strived towards his academic
goals and I was always told he was doing such a great job by his resource educators. He
embraced the tools he was given to battle his learning challenges. During his middle school and
high school years there were times that Louis was bullied by his peers. He would often avoid
confrontation and let other kids push him aside. I often called the school to address the problems.
Eventually Louis learned to deal with it as best he could. He never acted out because of it. He
was always friendly and pleasant to everyone. When he graduated from high school, the family
was so proud of him because he received several awards for merit and improvement in his
studies. His high school guidance counselor Mrs. Farley was beaming with pride after his hard
work got him accepted into Mitchell College. Mitchell College was a choice we made based on
, their ability to provie "world renowned" \earning resources for J:.,ouis.
He picked Hospitality and Tourism as his major. No wonder because Louis was probably the
most considerate and hospitable person you could ever know.

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He also had an amazing sense of humor. He was eager to learn and he had a sharp visual
memory. He never forgot a face. He was always looking out for everyone else. He was so
cautious and he was the person who I depended on to remind me to change the oil in the car or
the brakes, to make sure the furnace was working properly and that I had enough gas in the car.

He loved Mitchell College and strove to do well. He did great for two years, making friends and
utilizing the resource center. Louis always went out on a limb to help others and he was eager to
make friends. He had a great ability to do impressions of movie characters, singers and
comedians. Louis made me and his brother laugh till we cried and our stomachs hurt.
He was affectionate. He was generous with hugs and pats on the back." Family meant everything
to Louis. Although his own father was absent most of his life, Louis had a close connection with
his grandfathers and his uncles. Even though I was a single mom, all of my family, especially my
three sisters helped raise my boys and give them ongoing support and encouragement and love. I
struggled with alcoholism, went in and out of rehabs and hospitals for the better of ten years
before I was able to get completely sober in 2012. I have been ever since. My boys suffered
because of my illness. Fortunately, my family was there to carry them through the rough times.
'

'

During Louis's second year of college, my father passed away. This was devastating for Louis.
The following year, his other grandfather died suddenly. When he went back to school in the
spring of2014 he struggled with his academics. He started exhibiting signs of depression and
sometimes he would come home on the weekends and tell me he could not concentrate on his
studies. But we pushed through, and he never gave up. He sought help from the college and they
seemed to give it to him. -In the fall of 2014, Louis took an off campus apartment at school. He wanted to save money and
be with his friends who found the apartment. I wasn't happy about it because I felt Louis would
do better in a structured environment because he got distracted easily by things happening
around him. I knew there would be less guidance from the college with him being off campus.
However, Louis was 21 years old and he wanted me to honor his decisions, so I did.
He met a girl and he was so excited to finally have a relationship. The relationship lasted only
four months. When she ended it, he was very sad. Soon after, a situation occurred that fall and
Louis and four other students were suspended for an incident on campus. Suddenly my Louis
who never once got into trouble, who was always cautious, was facing criminal charges for
going into a female's dorm room and taking some of her things along with four other kids.
Fortunately, because it was a first time offense, the charges were reduced to misdemeanors.
Unfortunately, he was suspended from Mitchell College for two years. Louis came home and
was completely devastated. He had just begun his internship at a hotel and was prepared to
graduate with his degree that spring. Still he marched on, working, trying and smiling. He went
to the gym and tried reading self-help books and praying. My son MADE ONE MISTAKE and
he ~as suspended from sshool for two years. Lqst his internship, his graduation plans
everything. No one was hurt and he made amends. How many times was Brad Commerford
arrested and never served anytime in jail?

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With everything I had, I tried to protect and reassure my son. We had an incredible bond. He
tried so hard to do the right thing. He always worked hard. He worked for seven years at a local
pizza restaurant. He was reliable and loved by the restaurant owners.
Even though Louis put on a happy front, He confided in me and his brother that he was
depressed that his college plans were shattered. He tried to get help for his depression by going
to therapy at the Birmingham Group in Ansonia, but it seems to me the mental health system
didn't really help at all. He was mandated by court to take an IOP for mental health. He went in a
looking for something positive to learn and he came out with a new knowledge of drugs and an
introduction to low life's and sick predators in the community. He could not say no to people
who asked him for rides, money or whatever they could use him for. It caused me anxiety and
worry on a daily basis.
Within eighteen months, my son was dead.
What happened to my son could have happened to anyone. He was a strong, courageous, funny
and loving man. He would help strangers and ask nothing in return. He was innocent.
'

'

'

Louis was the greatest gift I could ever imagine receiving. He had a sweet innocence yet a
mature soul. He was unique. Louis fell victim to this long time drug dealer Brad Commerford.
Louis met him when they were in middle school. They were not close friends. Louis avoided him
because he knew he was trouble even then. When Louis came back from living at Mitchell, he
came into contact with Commerford because he lived close by to us.
I ask that you consider that Commerford is a dangerous person who is responsible for the death
of my son. He is a dangerous predator. He has shown no remorse in my opinion. If he was
remorseful, he would have cooperated with detectives to eliminate the drug dealers he worked
for. He was arrested so many times and always was given a free pass. I believe in my heart that
several others died as a result of being sold drugs from Commerford, although it can never be
proven.
My son was not a low life to society. He deserved to be here and live out his life. He deserved to
walk down the aisle with the woman of his dreams. He deserved the chance to raise a child and
he would have been an amazing father. His life ended after only 23 years. Individuals like Louis
are dying every day because of the poison that is being distributed freely in our communities. It
was a death th~t should have never happened. It is not fair that Commerford should walk away
from this after months in jail. It should be several years! My son lost 50 years or more because of
this callous drug pusher. I believe Commerford knew he was risking people dying and he just
didn't care. He is a dangerous individual who should be shown as an example to other drug
pushers that the murdering of innocent people has to stop. He called my son the night of his
death. He solicited free drugs to my son who was an innocent soul, struggling with this new
addictiqn that was introduced ,to him only two week~ prior. My son had hi~ uncashed paycheck ,
in his wallet and $57.00 cash. He told me only 4 days prior to his death that Commerford gave
him heroin for only $3.00. It was cheap and helped him with his pain.

Case 3:16-cr-00089-AWT Document 45-1 Filed 07/22/16 Page 4 of 5

Commerford is the worst kind of predator. I am asking that you make an example of him and
give him the maximum sentence possible. Others like him need to stop passing out this poison
and knowing they will only get a slap on the hand for doing it. Maybe if someone like
Commerford goes to prison for 20 years or more, others will think twice before handing out
cheap poison to anyone, anywhere so easily.
I feel sorry for addicts. I know they need help. I know firsthand how difficult it is to battle
substances. I know that an addict wears a veil that blocks their ability to value anything other
than getting more drugs. I can perhaps someday forgive Commerford. I hope I can. But this is
not about me or my feelings at all. This is about a vicious epidemic that needs to be addressed
fiercely!
Please impose the maximum sentence on Commerford. Please allow some peace that something
good can come out of this tragedy. I have inherited my sons unlived years. I can maybe have
some peace knowing that others can live because evil such as Commerford is not tolerated
anymore. I am now on a journey to honor my son and perhaps fight against a broken system that
killed us both. To perhaps prevent another mother's heartbreak.

Sincerely,
Louis ' s mom

(Jina :Mattei

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