Case 3:10-cr-00221-VLB Document 15 Filed 01/15/11 Page 1 of 18

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA : Criminal No. 3:10cr221 (VLB)

:
: January 15, 2011
v. :
:
:
CARLOS GARCIA :

UNITED STATES’ RESPONSE TO DEFENDANT’S SENTENCING MEMORANDUM

I. Introduction

The defendant details the good deeds he has purportedly done helping his

family members, volunteering for his children’s sports teams and serving as a

deacon at church. He characterizes himself as a “caring and loving husband, a

devoted son, and a person who has given much to his community.” He then

argues that because of those good deeds, because he adopted two children, and

tragically, because one of his children died unexpectedly, that he should receive

a departure for extraordinary family circumstances or a non-Guidelines sentence.

But the defendant fails to offer facts required under Second Circuit law to justify

such a departure, namely, that he is the sole careprovider for his family or that he

plays an irreplaceably vital role in the care of his family.

Further, this case does not warrant a non-Guidelines sentence or a

departure based on a combination of factors either. Many of the very good deeds

defendant now uses to justify a lenient sentence proved to have an insidious

purpose--they allowed the defendant to cultivate victims for his fraud scheme.
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Indeed, the defendant repeatedly stole money from members of his own family;

he stole from his church friends; and he even stole from the youth soccer club

where he served as treasurer. The defendant proclaims that a lengthy sentence

might be appropriate “for a lesser man, a man more comfortable with the dark

side of the law.” However, stealing from family and friends and leaving retirees

with nothing is sufficiently “dark” to warrant 51 to 63 months in prison. His

request for a downward departure or non-Guidelines sentence should be denied.

II. GARCIA’S FAMILY CIRCUMSTANCES DO NOT JUSTIFY A DOWNWARD

DEPARTURE OR NON-GUIDELINES SENTENCE

A. Relevant Law

The Sentencing Guidelines provide that “[f]amily ties and responsibilities

are not ordinarily relevant in determining whether a departure may be warranted.”

U.S.S.G. § 5H1.6 (Policy Statement). “Because the Guidelines disfavor departure

based on family responsibilities, such a departure is not permitted except in

extraordinary circumstances.” United States v. Smith, 331 F.3d 292, 294 (2d Cir.

2003). A downward departure for family circumstances “must be reserved for

situations that are truly extraordinary.” United States v. Walker, 191 F.3d 326, 338

(2d Cir. 1999).

The Second Circuit has concluded that departures based on family

circumstances are not abuse of discretion where the defendant has a unique and

irreplaceably vital role in the caretaking of other minor or disabled family

members. See United States v. Johnson, 964 F.2d 124, 128-30 (2d Cir. 1992) (no

abuse of discretion to depart where defendant had sole responsibility for raising

four young children); United States v. Alba, 933 F.2d 1117, 1122 (2d Cir. 1991) (no
 Case 3:10-cr-00221-VLB Document 15 Filed 01/15/11 Page 3 of 18

abuse of discretion to depart where defendant solely financially responsible for

wife, two children, ages 4 and 11, and for disabled, dependant father and

grandmother, all of whom lived in the same house).

Beyond such cases where the defendant has a unique and irreplaceable

role in caring for minors or disabled family members, the Second Circuit has

reversed downward departures, even under a deferential, abuse-of-discretion

standard of review. In United States v. Smith, 331 F.3d 292 (2d Cir. 2003), the

court reversed a family-circumstances departure for a defendant who had a

close relationship with his two-year-old son and played a major role in caring for

him, including dropping him off at day care, feeding him dinner, bathing him, and

putting him to bed,” and where the defendant’s incarceration would result in his

wife having to discontinue her college studies. Id. at 293. The court observed

that the defendant was “not the sole caregiver or financial supporter of his [2-

year-old] son” and that the concerns for the son “may be alleviated by the

availability of Smith’s mother and half-sister for child care.” Id. at 294. To the

extent that the defendant’s college studies would be disrupted, the court noted

that “[i]t is not unusual, however, for a convicted defendant's incarceration to

cause some hardship in the family.” Id.

Similarly, in United States v. Madrigal, 331 F.3d 258, 260 (2d Cir. 2003), the

court reversed a family-circumstances departure that was premised on a female

defendant’s relationship with her six children. Focusing again on the availability

of alternative caregivers, the Court observed the absence of evidence that the

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defendant was “the only person capable of providing adequate care for the

youngest children” and that “[t]here was also evidence that the family as a whole

remained cohesive, that [the defendant’s] three older children were doing well

and were available to care for their younger siblings, and that [the defendant’s]

extended family was also available for caregiving.” Id. at 260. Accordingly, the

court concluded that “[u]nfortunate as the circumstances described by the court

are, they are not ‘extraordinary,’” and that “[t]hey are the common collateral

damage of imprisonment and are far enough removed from those circumstances

that existing case law has found exceptional that we must conclude that the

district court acted outside of permissible limits in granting the downward

departure for family circumstances.” Id.

In multiple other cases, the Second Circuit has reversed downward

departures where the facts were far from exceptional. See United States v.

Carrasco, 313 F.3d 750, 756-57 (2d Cir. 2002) (reversing family-circumstance

departure for defendant who had three children and an ill father for whom he

should provide financial support; “being the father of three children is in no

sense an exceptional circumstance” and financial support for the father was not

unique because “in view of the ‘considerable personal success’ achieved by

Carrasco’s siblings”); United States v. Faria, 161 F.3d 761, 762-63 (2d Cir. 1998)

(reversing family-circumstance departure for defendant who provided financial

support to wife and three minor children; “although Faria pays child support, he

no longer lives with his children, and his ex-wife earns approximately $40,000 per

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year,” such that “we cannot conclude that Faria's family is uniquely dependent on

the support it currently receives from him”); United States v. Tejeda, 146 F.3d at

87-88 (reversing family-circumstances departure for defendant with wife and two

children; “the existence of a stable family (a wife and two children) – something

that is by no means extraordinary – does not satisfy the ‘exceptional hardship’

criterion established by our precedents”).

B. The Defendant Does Not Provide The Type Of Care That Justifies A
Departure Based on Family Circumstances

Here, defendant’s circumstances do not merit a departure. As an initial

matter, while it is admirable that Garcia adopted two children, the fact that he is

an “adoptive father” does not justify a family circumstances departure as he now

argues. [Doc. #14 at 9]. The fact that one of Garcia’s daughters died of

myocarditis1 in November 2009 is tragic and nothing the Government argues

should be construed as demeaning the magnitude of that loss in any way. But

Garcia himself acknowledges, the death of his daughter is “factually unrelated”

to this offense.

As for his role as caregiver, based on the facts of the PSR, defendant does

not have the type of unique and irreplaceably vital role in caring for his son or his

father that would justify a departure. The defendant argues that “the surviving

adoptee is emotionally vulnerable and in need of his father’s caretaking.” [Doc.

#14 at 9]. The Government does not dispute that the defendant’s son (the

1
Garcia’s sentencing memo at one point refers to the death as a “suicide”
[Doc. 14 at 10] but the PSR states that the death was due to myocarditis, an
inflammation of the heart muscle. PSR, ¶ 40.

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“surviving adoptee”) is no doubt suffering as a result of his sister’s death, as any

sibling certainly would. Moreover, it seems obvious that the child would prefer to

have his father present as a caregiver than not. But there is no assertion that the

defendant is the sole caretaker for his children or that he provides a type of care

that no one else can. In fact, the defendant’s wife lives in the family home and

provides care for the children. PSR, ¶¶ 40-42. Further, as discussed below, the

family is awaiting a treatment placement to address the son’s needs. PSR, ¶ 40.

The defendant also argues that he is in a “unique and irreplaceable

position as caretaker for his elderly father,” and that he plays a “pivotal role” in

his care. [Doc. # 14 at 7, 9]. However, the nature of the care the defendant

provides to his father is not specified anywhere in the PSR. Defendant cites PSR

¶ 34, but that paragraph merely states that his father is 73, a resident of

Bridgeport, and “reported” to be in poor health. If defendant were his father’s

sole caregiver or gave him a unique kind of care that no one else could, this

would be a relevant fact to consider, but it is simply not borne out by the PSR. In

any event, it is clear that the defendant is not his father’s sole or primary

caretaker as the defendant’s father lives in Bridgeport while the defendant lives

well over 30 miles away in Guilford.

At its core, defendant’s argument is that being separated from his family

due to incarceration will be extremely difficult on them. However, that is a

difficulty that is inherent in the punishment of incarceration and one that all

defendants sentenced to federal prison face, including those who face far more

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substantial economic hardship than defendant’s family. The adverse effect on a

defendant’s family from a defendant’s imprisonment does not ordinarily warrant a

downward departure, because “[d]isruption of the defendant’s life, and the

concomitant difficulties for those who depend on the defendant, are inherent in

the punishment of incarceration.” United States v. Tejeda, 146 F.3d 84, 87 (2d Cir.

1998) (per curium) (quoting United States v. Johnson, 964 F.2d 124, 128 (2d Cir.

1992)). Accordingly, the defendant’s request for a family circumstances

departure should be denied.

III. THE DEFENDANT IS NOT ENTITLED TO A DEPARTURE UNDER 5K2.0

BASED ON A COMBINATION OF FACTORS

The defendant also relies upon a “combination of factors” to support a

downward departure under U.S.S.G. § 5K2.0. [Doc. #14 at 9-14]. The Second

Circuit has made clear that a departure based on a combination of factors should

be reserved for truly “extraordinary” cases. See, e.g., United States v. Cornielle,

171 F.3d 748, 754 (2d Cir. 1999) (upholding “limited” departure in light of the four-

year delay in prosecuting the defendant and the defendant’s extraordinary

rehabilitation after his crime, including significant volunteer work, stable

employment and residence, glowing work evaluations, and attendance at

college).

The combination of factors here are not extraordinary. Carlos Garcia is an

investment advisor who lived an extravagant lifestyle beyond his means. He

made friends at church and through his children’s sporting activities and later

defrauded them. His conduct was not aberrant, and his tax evasion offense, far

from being outside the heartland, was a classic case of failure to file. The sum
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total of his arguments should not add up to a departure on “combination of

factors” grounds.

A. Mental Health Needs of the Defendant’s Family

The defendant argues for a departure based on a combination of factors

including “the mental health needs of his wife, adopted child and natural child.”

[Doc. #14 at 10]. The defendant’s son is reportedly facing “two significant mental

health issues relating to the death of his sister” (PSR ¶ 40), obviously a challenge

to any family. The PSR indicates that the family is “awaiting a treatment

placement to address this issue”–an occurrence that would assist the family in

providing care. Such a placement would presumably reduce the need for any

mental health care the defendant is providing to his son–care that is not specified

in the PSR in any event.

As for the defendant’s wife, the PSR does not mention any “mental health

needs” on her part at all. The PSR affirmatively states that the defendant’s other

daughter is not receiving treatment and would only receive treatment “in the

event [such services] become necessary.’ PSR ¶ 40. For the defendant to argue

that he deserves a departure because of the “mental health needs” of his entire

family is overstated based on the facts presented in the PSR.

B. Number of Victims

The defendant also argues that the number of victims overstates the harm

in this case. [Doc. #14 at 11]. Defendant stipulated to the number of victims in

this case and that a two-point increase in his guidelines level should apply, so

arguing now that the enhancement is overstated is disingenuous. Further, the

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Guidelines plainly define “victim” as “any person who sustained any part of the

actual loss . . .“ (U.S.S.G. § 2B1.1, Application Note 1), and makes no mention of

married couples somehow counting as only one person.

C. Defendant’s Charitable Activities and Volunteer Work

Defendant detailed with painstaking care to Probation all of his charitable

work in the community and other volunteer activities. PSR, § 39. However,

particularly in the case of affluent businesspeople convicted of white-collar

crimes, civic and charitable works are the expectation, not the exception, and

accordingly will rarely merit a downward departure. For example, the First Circuit

reversed a downward departure based on charitable works where the white-collar

defendant was “a member of a church, tithe[d] ten percent of his income, and

devote[d] hours every week to unpaid service with the church in a variety of

positions,” and had taken family members and others into his home. United

States v. Thurston, 358 F.3d 51, 79 (1st Cir. 2004), judgment vacated and

remanded for reconsideration in light of Booker, 543 U.S. 1097 (2005).2 The First

Circuit held that the businessman’s charitable works were “hardly surprising” in

2
See also Thurston, 358 F.3d at 79 (“Letters from his fellow congregants
characterize him as a man of principle and impeccable character –
characterizations undermined, of course, by the jury’s finding of guilt.”); id. (“In
addition to his church activities, Thurston has taken family members and others
into his home and has been helpful to his neighbors. For example, the parents of
a woman undergoing rehabilitation at a local medical center stayed at Thurston’s
home for several weeks. On another occasion, Thurston and his family laid sod
for an infirm neighbor. Save for his crime, Thurston appears to have lived a
creditworthy life.”).

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light of his position as a prominent corporate executive, and hence difficult to

categorize as “exceptional” for purposes of a downward departure. Id. at 80.

Other circuits have reached similar conclusions. See, e.g., United States v.

Morken, 133 F.3d 628, 629-30 (8th Cir.1998) (reversing downward departure for

white-collar defendant stating, “[I]t is usual and ordinary, in the prosecution of

similar white-collar crimes involving high- ranking corporate executives . . ., to

find that a defendant was involved as a leader in community charities, civic

organizations, and church efforts.” ); United States v. Haversat, 22 F.3d 790, 796

(8th Cir. 1994) (reversing downward departure: “It would appear that high-level

business executives, those who are in a position to commit Sherman Act

violations, also enjoy sufficient income and community status so that they have

the opportunities to engage in charitable and benevolent activities.”). “Likewise,

excellent character references are not out of the ordinary for an executive who

commits white-collar crime; one would be surprised to see a person rise to an

elevated position in business if people did not think highly of him or her.”

United States v. McClatchey, 316 F.3d 1122, 1135 (10th Cir. 2003).

What defendant leaves out of all of this is that his charitable activities and

volunteer work actually served to facilitate his fraud scheme. For example,

defendant cites that he was the chairman of the Board of Deacons for the First

Congregational Church of Guilford from 2004 through 2010, PSR ¶ 39, but leaves

out the fact that he used his church to find additional victims. Indeed, the Victim

Impact Statement submitted by A.B. and B.B. expresses their disbelief as to how

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the defendant could, as a deacon and chairman of the Board of Deacons, “prey

on fellow church members.”

The defendant also specifically pointed out to Probation that he served as a

coach for his children’s sports teams. Again however, what the defendant leaves

out is that while he was acting as the treasurer for the Guilford Soccer Club, he

stole $80,000 from the club coffers. PSR, ¶ 12. Once the club reported him to the

police, the defendant returned the money with an additional $10,000, reporting

that the extra money was “interest.” Id. Now that the local police are no longer

pursuing the matter and the soccer club is not a loss victim in this case,

defendant has demanded that the soccer club pay him back the money,

characterizing the money as merely a “loan,” and threatening to use “any and all

legal means available “ and that he is “more than willing to file multiple claims

against the club and against all officers individually, past and present.”3 This

sort of charitable activity and volunteer work is something the community could

well do without.

IV. CONSIDERATION OF THE 3553 FACTORS DOES NOT JUSTIFY A NON-

GUIDELINES SENTENCE

Garcia argues for a non-Guidelines sentence because he is a “caring and

loving husband, a devoted son, and a person who has given much to his

community.” [Doc. # 14 at 12]. Defendant’s submission demonstrates, at most,

that he is considered by some to be a good parent, son, friend, and neighbor. It

3
A redacted copy of a letter dated November 17, 2010 (about two weeks
after defendant entered his plea in this case on November 4, 2010) from the
defendant to the Guilford Soccer Club is filed herewith. The attached copy is the
best copy available to the Government.
 Case 3:10-cr-00221-VLB Document 15 Filed 01/15/11 Page 12 of 18

does not, however, show an exceptional case. Defendant’s arguments here are

nearly identical to those made in United States v. Regensberg, 635 F. Supp. 2d

306, 307 (S.D.N.Y. 2009), by a securities and wire fraud defendant at sentencing.

There, the district court recognized, in sentencing the defendant to 100 months

imprisonment:

[Defendant’s] argument falls into a pattern advanced by

a subset of the white collar criminal. This category
encompasses a select class: distinguished, reputable,
highly esteemed model citizens such as this defendant.
This list of their achievements and virtues is long and
impressive. Let us count the ways. At home, they are
good family men and women, caring spouses, loving
parents, loyal and reliable to friends. At work, they are
looked up to as outstanding professionals and business
partners. To their community’s charities and public
causes they are generous patrons and sponsors. And
as worshipers they are devout, often rising as leaders of
the congregation.

Yet, for all of their outward rectitude, these otherwise

good people suffer a fatal flaw: they lead a double life.
Somewhere at the core, in a distorted dimension of the
soul, the public image they present is as false as the lies
they tell to sustain the appearances of an exemplary life.
And somehow, for reasons that always defy reason, they
fall into crime, doing wrongful deeds that seem
aberrational, selfish and greedy acts that, when caught,
they claim are entirely out of character with their
otherwise law-abiding lives.
...
As it ends, the presentation comes to several
conclusions it urges the Court to adopt: that the
defendant has already shown full rehabilitation and
earned redemption; that there is absolutely no likelihood
of recidivism from this defendant and thus no threat of
future harm to society; that no further need exists to
punish the defendant because he has been wracked
long enough by shame, by ruin of his family and
personal life, by loss of his primary means to earn a

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livelihood. The purposes of sentencing thus having

been satisfied, ergo: a sentence of any lengthy
incarceration would serve little or no useful purpose. Id.
at 308.

As the Regensberg court concludes, defendant’s argument is critically

flawed in what it omits, namely, several other circumstances the Court is required

to consider under § 3553. For example, “with regard to the severity of the crime,

the common white collar appeal for leniency tends to understate the gravity of the

underlying offenses by compressing the defendant’s entire record of misconduct

as if it were a single, isolate episode of crime, a one-time or sometime thing that

occurred over a lifetime of otherwise immaculate behavior.” Id.

The defendant makes that claim here, emphasizing that this is his “first and

only offense” and that “there is no evidence to suggest that he is a hardened and

habitual criminal.” While it is true that this is defendant’s first criminal

conviction, it is not as if the offense here was his first taste of fraud. The

defendant was fired from Paine Webber in or around 2001 after defrauding his

clients and his employer by engaging in unauthorized trading that caused

significant customer losses and by settling customer complaints without Paine

Webber’s knowledge or consent. PSR, ¶¶ 38, 55. Although defendant tries to

spin this as him having “left to begin his own business as an investment

manager,” he did not share with any of his new clients (or with Probation) the

circumstances surrounding his firing in 2001. Id.

In this case, the defendant was defrauding his victims for years, during

which time he took money from more than 10 victims, and committed hundreds of

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acts of deception. This fraud wasn’t simply a detour of sorts in an otherwise

straight, law-abiding life--the fraud was his way of life, and nothing could be more

habitual than that. United States v. Altman, 48 F.3d 96, 105 (2d Cir. 1995) (where

attorney embezzled $500,000 over four year period, court held that “the repeated

and long-lasting criminal conduct involved here cannot under any circumstances

be considered a ‘single aberrant act.’”). Such a history weighs heavily against a

below Guidelines sentence.

Further, similar to the defendant in Regensberg, casting the defendant as

an upright citizen who simply went astray minimizes a deeply disturbing aspect

of his conduct. Specifically, the defendant used the mantle of respectability that

came with being a hedge fund manager, a church deacon, a member of

philanthropic boards, a solid member of the community, and a family man with a

nice wife and kids, to earn his victims’ trust. Indeed, Victims A.B. and B.B. detail

the defendant having invited A.B. over to his house more than once in order to

impress A.B. with his nice home and expensive business equipment. Those very

qualities that the defendant presents as weighing in favor of leniency were the

essential tools he used to facilitate his fraud. That fact makes defendant’s

conduct here more, not less, blameworthy and demonstrates a characteristic that

justifies a sentence within the guidelines range. See Regensberg, 635 F. Supp. at

309 (defendant’s use of his clean outward appearance, “all make his conduct that

much more sinister and reprehensible.”).

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Further, although defendant tries mightily to characterize himself as having

been somewhat passive in this fraud scheme, stating that he “permitted himself

to be caught up in a web of bad investments,” [Doc. # 14 at 13]; and that he is “a

product of an environment in which easy gain was regarded as a matter of right

by investors,” defendant alone charted his course. He engaged in repeated and

express misrepresentations over a period of several years, and went to great

lengths to cover up his fraud by ginning up fake paperwork to backup his false

claims and string his victims along. This was not a matter of investments

somehow having gone “bad”--this was outright stealing. Moreover, it is not as if

the defendant was trying hard to right course, living modestly so that he could

pay people back. He spent the money he stole to sustain a lifestyle he could not

afford, including a nice car, a 5,000 square foot home, and a $1,100,000 mortgage.

Indeed, Victims A.B. and B.B. put it best, saying “Carlos and his family always

appeared to live an affluent life style with no obvious concern to spend

conservatively.”

The defendant insists that his “fall from grace” and the fact that he has

“lost his standing in the community” has left him a “shattered man” and that

therefore, “[t]here is no need for specific deterrence in this case.” [Doc. # 14 at

12-13]. However, the value of specific deterrence should not be dismissed that

easily. Defendant had what was in all respects what appeared to be a good life–a

nice family, beautiful home, social status, and a professional career. Despite

these advantages, defendant chose to steal from those who trusted him most,

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and to do so repeatedly. The defendant still appears to believe that the fraud

somehow just happened to him and resulted from no more than an unfortunate

set of circumstances beyond his control. Indeed, he appears to suggest that this

investigation (rather than his own fraud) caused the collapse of his business.

[Doc. # 14 at 10] (stating that “After law enforcement began to investigate the

defendant, his business folded.”). Although the government does not quarrel

with the defendant having accepted responsibility for purposes of § 3E1.1, he

does not seem to fully grasp that this scheme was entirely his own making. That

too weighs in favor of a sentence within the guidelines range.

The defendant also argues in favor of a non-Guidelines sentence based on

the fact that he is required to pay significant restitution in this case and

“incarceration makes it difficult to generate any meaningful restitution for his

victims.” [Doc. # 14 at 13]. Defendant goes so far as to state that “[P]rison for

Mr. Garcia deprives both his son and his victims of the support they need.” [Doc.

#14 at 14]. As the Second Circuit has well recognized however, restitution

obligations do not justify a more lenient sentence because it would “subvert the

principle that the court should ‘avoid unwarranted sentence disparities among

defendants with similar records who have been found guilty of similar conduct.’”

See Untied States v. Cutler, 520 F.3d 136, 167 (2d Cir. 2008) (quoting 18 U.S.C. §

3553(a)(6)), receded from on other grounds, United States v. Cavera, 550 F.3d 180,

188 (2d Cir. 2008). Indeed, imposing a shorter sentence because defendant

would otherwise be unable to pay restitution “would imply that virtually all

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defendants who are required to pay restitution in amounts exceeding their net

worth should receive short prison terms, a proposition that is patently

untenable.” Cutler, 520 F.3d at 167.

Finally, this Court may well take issue with the defendant’s insistence that

he is not a “hardened” criminal. [Doc. # 14 at 13]. It takes a significant degree of

“hardness” to take the life savings from a woman (Victim H.C.) who was 72 years

old at the time she started investing and gave the defendant money she earned

the hard way--by working and saving for 41 years. PSR, ¶ 6. It is also quite

hardened to steal from those you worship with and from members of your own

family. Defendant’s stipulated guidelines range of 51 to 63 months is sufficient,

but not more than necessary, to address the sentencing considerations under §

3553.

V. CONCLUSION

For the reasons set forth above, the Government respectfully requests that

the defendant be sentenced within the guidelines range of 51 to 63 months’

imprisonment.

Respectfully submitted,

DAVID B. FEIN
UNITED STATES ATTORNEY

/s/ Susan L. Wines

SUSAN L. WINES (phv2379)
ASSISTANT U.S. ATTORNEY
157 Church Street, 23rd Floor
New Haven, CT 06510
Phone: (203) 821-3700
Fax: (203) 821-3829
E-mail: susan.wines@usdoj.gov
 Case 3:10-cr-00221-VLB Document 15 Filed 01/15/11 Page 18 of 18

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on January 15, 2011, a copy of the foregoing was
filed electronically and served by mail on anyone unable to accept electronic
filing. 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 as indicated on the Notice of Electronic Filing. Parties may access this
filing through the Court’s CM/ECF System.

/s/ Susan L. Wines

SUSAN L. WINES (phv2379)
ASSISTANT U.S. ATTORNEY
Connecticut Financial Center
157 Church Street, 23rd Floor
New Haven, CT 06510
Phone: (203) 821-3700
Fax: (203) 821-3829
E-mail: susan.wines@usdoj.gov
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