Exhibits to Sentencing Memorandum — USA v. Chancy et al. (Dkt. 97-1, S.D.N.Y.)

Record facts

U.S. District Court for the Southern District of New York · No. 1:20-cr-00378-LJL · Doc. 97-1 · 2021-09-29 · Docket on CourtListener

Full text

Index of Exhibits 
United States v. Adedayo Ilori 
No. 20-cr-0378 (CM) (S.D.N.Y.) 
Letters and Exhibits Submitted on Behalf of Adedayo Ilori 
Exhibit 
Description 
1 
Letter from Adedayo Ilori 
2 
Letter from Aminat Bakare (Adedayo’s mother) 
3 
Letter from Benjamin Ejelonu (Adedayo’s uncle) 
4 
Letter from Muslim Adesoye Bakare (Adedayo’s step-
father) 
5 
Letter from Wunmi Fadipe-Ilori (Adedayo’s wife) 
6 
Letter from T.I. (Adedayo’s daughter) 
7 
Pictures of Adedayo and His Family 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 1 of 24

EXHIBITS
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 2 of 24

EXHIBIT 1 
Letter from Adedayo Ilori 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 3 of 24

Dear Judge Liman: 
I am writing you with the hopes that you will be lenient with regards to my case. The time that I 
have spent on home confinement have especially added a weighted prospective to my life as a 
whole. I cannot gamble or feel pressured to do anything illegal in my life going forward because 
I will always get the brunt end of the outcome and the shame associated with it.  
My family have been supportive but I know deep down that everybody (including my kids) are 
ashamed of me and the situation that I have put myself in. They have been supportive, loving and 
great to me during this very challenging time and I humbly ask to be given a chance to make 
them proud as I had been doing before this.  
For more than 10 years I have tried to overcome the temptation and peer pressure of getting 
involved in illegal activities and have built a successful Wellness business that I, my family and 
friends are proud of. I have a desire to help people transform themselves into their better version 
through fitness, and I love doing it because of the joy I get in assisting people change their 
mental well-being through their physical. I’ve built a stable relationship of business staff with 
some of the best wellness professionals in a few cities around the world that work with my 
provided clientele. But the peer pressure I suppressed came around in another form of a trusted 
person. I do not blame anyone but myself for relenting to what I teach my kids to stand up to. I 
am truly disappointed in myself; disappointed in the actions that led me to be arrested in front of 
my family at 6am in the morning. My 11 year old still asks me what the commotion that morning 
was about but I am too ashamed to fully explain what led to that morning. I’ve been learning 
through therapy and readings on how to tell him so he can learn from my mistakes, which I have 
plenty of. I hope to get a chance to be able to stand upright again in front of my children, family 
and friends.   
Having had the time to reassess my life especially throughout the Covid-19 lockout and my 
contracting the virus which made me deadly sick, I realized I wasn’t as strong mentally nor 
physically as I thought. Repeating old mistakes in different forms, looking for validation from 
friends, peer pressure which is internally not healthy. When I was in jail between July 2019 and 
October 2019, my friend was the only one that came to visit me and tried to help with my bail, 
and I sort of felt indebted to him even though I shouldn’t have. Afterwards I thought I was strong 
enough to walk away from him and the scheme, I now know he colluded with the CI to 
manipulate and pressure me to continue with the scheme. I would not be writing this letter if not 
for this manipulation and pressure directed from the CI that I was told was a high ranking 
Russian gangster. I also tried to sabotage the scheme by providing bad documents that I thought 
would be a way out.  Unfortunately they kept the scheme going even with the bad documents I 
had provided for the first scheme after which I refused to provide any further documents for the 
second.  I contest that my co-defendant continued with the scheme by himself (without my full 
knowledge or assistance) and the government knows this to be true. I felt tired and trapped, and 
my unfortunate reaction was to just sit back and be a pedestrian observer with the second scheme 
because of the threat of what may happen to me if I didn’t. But I must take responsibility for my 
weakness, for the highest regards for others instead of myself and my future.  
I have 3 great children I hope to see every day, to see them grow to be a much better version of 
me. I have a wife that loves me and believes that I can and will do better, so she supports me 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 4 of 24

2 
knowing there are better days ahead. This colossal action has laid bare my life as not been for 
myself alone as I selfishly thought before,  but it touches my retired mother in Nigeria that 
depends on me for her well-being financially and mentally, my uncle that’s a university vice-
Chancellor but depends on my generosity every so often because he hasn’t been paid in months, 
my biological father that’s recovering from 3 strokes that needs 24 hours house help to function 
in a country that barely has a functioning health care system, my extended family that looks up to 
me for whatever little I can provide in a failed state. I am extremely fortunate to be in this 
country and position to do the little I can for the few I can, and I hope you will give me the 
opportunity to improve on my life and the lives of my family by showing leniency.  
I am trying to make amends any little way I can 
 
 
 I want to move forward out of this wretchedness that I have gotten 
myself and family into. 
Thank you for taking the time to read this letter. 
Adedayo Ilori 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 5 of 24

EXHIBIT 2 
Letter from Aminat Bakare 
(Adedayo’s mother) 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 6 of 24

09/07/2021. 
Dear Judge, 
REQUEST FOR LENIENCY. 
I write to you on the behalf of my son Adebayo Adewale Ilori. Am his biological Mother. 
To Start with, I want passionately Implore you not to feel bored or angry with my long 
writing. 
Though I can see you, but I humbly plea that you listen to a sad and miserable Mother. 
Thanks so much for this favour. 
I raise my son solely as a single mother and I tried my best to give him good life. I am 
educated and a working class mother. His upbringing was fine and he attended the best 
school in my city, Ibadan Nigeria for is nursery primary and high school education. At the 
age of 11 I left him with my husband and the step grandmother to work in Saudi Arabia for a 
better and quality life for him. Prior we are very happy together despite the fact he didn't 
know his biological father because he was showered with love by my husband, He was in the 
boarding school but I widrew in from the boarding house because the seniors were bulling 
him and he was going to the same school — Government College Ibadan as a day student. 
His stay with the Step — grandmother was very rough coupled with wickedness but he 
endured the situation because I always come home on vacation yearly but unfortunately the 
worst happened to him, he was abducted by unknown men to the family who posed to him as 
is father relation. 
They convinced him that they were taking him to the father, but unfortunately he was taking 
to New York in united State of American where he had NO RELATIONS nor PARENT, so 
he was redeemed for some time until he managed to escape from them. From this point the 
problem of is life started, he had no parent nor relation to turn to for his livelihood Nor to go 
back to school. He therefore started struggling for his survival along the line many things 
could have gone wrong 
Meeting wrong people e.tc. but eventually he got himself a 
job, marry and started living a good life. 
All this while I have no communication with him even I didn't attend his wedding because I 
was denied visa to experience this honourable day. IN 2012 he came to Nigeria briefly to 
visit me and fortunately this same year I was granted Green Card Visa and I started visiting 
him and the family regularly doing my vacation till 2017. I n 2017 I left him in New York to 
come to Nigeria briefly to come my siblings and to go back to US but unfortunately I meet 
very bad catasphronic situation three of my Junior Siblings where suffering from Malignant 
Cancer with no body to take care of them and I had no choice than to stay behind and take 
care of them. 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 7 of 24

The health issue of my siblings coupled with the outbreak of covid — 19 and my Own Health 
Issue kept me in Nigeria I lost two of my siblings to Cancer, One in February 14 2018 and the 
second one January 12 2020 and on my Own part I have GLAUCOMA AND 
RHEUMATOID ARTHRITIS'S. Unfortunately, by the time is could manage to go back to 
US he was not there, So I could not go to US because know body to support me health wise 
and other needs. 
Overall Point is Dayo Adewale Ilori at always been my back bone my friend because he cares 
and loves me and my family. Doing Turbulent periods, he was there for us. Dayo has always 
been very gentle, calm, Kind, Quite, Hate Violence and Violence Atmosphere and is very 
well Principle. 
I humble urge you Sir to temper justice with mercy for the sake of his family, his dad who 
eager to see him to apologize to him for not being there for him till now. It will do him and 
family good if you can magnanimously give him another chance, having realized his 
misdeeds and the need to get focused and discipline to embrace the glorious future. I want to 
come to U S before my Green Card Visa expires next year, 2022 and to be close to him 
because is all that I have. I am very lonely in Nigeria, because i am all alone by myself. 
I will draw your Attention that since from age 11 years we have not really stay together ask a 
mother and Son should be, so please temper Justice with Mercy, so that I we can have time 
together before I die. Am getting Older and I have GLAUCOMA, heart problem and 
Rheumatic ARTHRITIS'S. 
Sadly, too, his biological father has STROKE. He wants to see him and Apologize to him for 
the deserting him before he dies. 
Sir, I want to humbly urge the court to release him on compassionate ground and /or mitigate 
the punishment. His absence from us has put his immediate family in serious s jeopardy. My 
son is a good and well — behaved young man who unfortunately has made poor decisions 
leading to the situation he now find himself. I have a strong belief that he would turn a new 
leaf if my plea for leniency is given positive consideration and approval 
Do not hesitate to contact me on any information you may require from me concerning this 
issue 
Yours respectfully, 
Mrs Aminat I. Bakare. 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 8 of 24

EXHIBIT 3 
Letter from Benjamin Ejelonu  
(Adedayo’s uncle) 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 9 of 24

ADEKUNLE AJASIN UNIVERSITY 
.., building a 21st Century University, properly called! 
Department of Chemical Sciences 
1.)epalithent of Cheocal Seer 
acuity of Scienco 
P M B. 001.
Akungba-Akok
Oridu State 
chernicalscience@aaua.edu ng 
woiw.aaria.edu.liq 
Dear Judge, 
REQUEST FOR LENIENCY 
I write to you on behalf of my nephew; Adedayo Adewale llori. Dayo was raised by her mother as a single mother, 
who tried hard to give him the best life could afford him. She has to travel to Saudi Arabia so as to enhance the family's 
financial status. While the mother travelled I have stay with Dayo in his step father's apartment with my sister's 
mother in —law. Dayo would chose to lie down on his stomach waiting for when food would come than going about 
begging for food. He was so humble and quiet, growing up as a young boy; also very respectful. 
i have to leave home to the University hotel to write my Master's Examination, only to find out that he had been 
abducted by some unknown people to us on arriving from the University. After several months of search to no avail 
we have to give up trusting that one day we would gladly find him. 
It was a year of turbulence searching for him in Nigeria not knowing he was far away in the USA. We got relieved 
when he called telling us his ordeal. Since then he had struggled to survive along the way all alone. He eventually got 
himself a job as a trainer and got married. A marriage and family he had strived to keep and maintain all this while. 
I believe bad influence must have led him into some of these unfriendly, uncivil tendencies and behaviours as I could 
vouch for him having helped to nurture him while his mother was away in Saudi Arabia. 
I humbly urge you Sir to temper justice with mercy to give him the reason to live again having experience much from 
his past. As his Uncle I have always been proud of him, but for the bad influences and communications, which i 
believed by now he had learned in a hard way the difference between Good and Bad. 
I strong believe that if given a second chance he would not err again knowing the damning consequences of such 
breach of trust and confidence that he can be a good boy, a good man, a good son, a good brother, and a good husband 
and father again. 
Dayo also has been of immense assistance to me in several ways both in the past and in recent times. 
Sir, 1 want to humbly urge the court to release him on compassionate ground and/or mitigate the punishment. His 
absence from us has put his whole family in serious jeopardy. My nephew, i strongly believe is a good and well-
behaved young man who inadvertently has made poor decisions leading to the situation he now found himself. I have 
a strong belief that he would bounce back to good life, becoming a good and dependable citizen of the great America 
again if my plea for leniency is given positive consideration and approval. 
Dayo remains my good nephew beyond Tomorrow! 
Your espectfully, 
kyo'D--1)
Ejelonu, B. C., PhD 
Professor and Head , Department of Chemical Sciences. 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 10 of 24

EXHIBIT 4 
Letter from Muslim Adesoye Bakare 
(Adedayo’s step-father) 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 11 of 24

= 
  
 
9/28/21 1:36 PM 
Your Honor,  
 
My name is Muslim Adesoye Bakare, my address is 
 
 England. 
Sir, I am writing for leniency in sentencing of my stepson Adedayo Adewale ILORI  
I have known Adedayo for more than 40years, I married his mother when he was just one year 
and eleven months, so I can comfortably tell you that Dayo as always called is my son and he 
grew up under my tutelage before coming back to the United States of American. 
Your Honour am aware of the gravity of his offence, but I still find it very hard to wrap my head 
around it, this is not the boy I brought up. 
Dayo has been there for me and his family,( his wife Wunmi and their kids Teniola and 
Timilehin ) helping in providing and taking care of the kids. 
Your Honour not too long ago he lost his uncle to cancer and his Aunt also died leaving him with 
two nephews and one niece, mother and the 86years old grandmother, all this people depended 
on his support. 
Your Honour Dayo has been working tirelessly to improve himself and to make himself a better 
person and he has also moved closer to God. 
I plead with you to please temper Mercy with Justice while delivering your verdict sir, as I have 
no doubt that he has learnt his lessons. 
 
 
Sincere yours, 
Muslim Adesoye Bakare 
  
 
 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 12 of 24

EXHIBIT 5 
Letter from Wunmi Fadipe-Ilor 
(Adedayo’s wife) 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 13 of 24

'
' 
Wunmi Fadipe-Ilori 
 
July 12th, 2021 
Judge 
United States Courthouse 
500 Pearl Street 
New York, NY 10007 
Dear Judge,  
I am writing this letter to ask for leniency on behalf of my husband and father to my children, 
Adedayo Ilori.   I hope that this can help you see what kind of person Adedayo is despite the 
transgressions that have led us all to this point.  I feel strongly about Adedayo’s future and i 
want to try and make you feel the same way. 
I met Adedayo in June of 1999 and i’ve known him for over 22 years and he is truly a good 
person of strong moral character. i realize that may seem hard to believe, given the current cir-
cumstances, but it is true nonetheless.  I have seen Adedayo go through many trials and tribu-
lations during these years which we have been together and somehow he still manages to look 
at life from a positive perspective. 
Adedayo and I have 2 kids together ages 11 and 15 and he has been nothing short of a great 
father in their lives.  He is an amazing father and although that may be something you hear fre-
quently, but i wish you could witness their relationship.  Both with his 11 year old Son and 15 
year old daughter.  He helps to take them to school and picks them up.  He assists them with 
their homework and as a Personal Trainer makes physical activity his way of bonding with the 
kids outside of their academic studies.   
He’s a good husband and friend to me and he extends himself in any capacity that i may re-
quire of him.  I currently work as an Executive Assistant at an Investment banking Firm and 
have a 9 to 5 schedule that does not allow me to drop and pick up the kids without being late 
for work or having to leave early since the schooldays is over at 2:30pm.  He steps up by mov-
ing his schedule around to make the children his priority while i’m at work.  He pushes me to 
do more and this summer through his encouragement, i was able to finish my Bachelors with a 
degree in Economic from CUNY @ Queens College and currently studying for my investment 
licenses (Series 7 and 63) in becoming a Financial Advisor. He truly is beyond committed as a 
father and husband.  Adedayo is truly my biggest support system and i truly rely on him.   
I believe as a child your parents are the most important and influential people we can ever en-
counter.  Ever since i could remember, i’ve looked up to my Mom and Dad.  Whether for guid-
ance, support, advice, or just a big hug.  They have been my true friends and have always been 
there for me throughout my life.  I want to provide the same for my kids.  I do not want the void 
of their other to have a negative impact on their upbringing or for them to feel any less loved as 
a child because their father is unable to help raise them.  
Adedayo is one of two siblings with his brother and Step Father residing in London, England. 
His Mother is a retired Nurse who currently resides in Nigeria along with his biological Father 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 14 of 24

who suffered 3 strokes and currently Immobile due to the illness.  Adedayo does his best to 
help them in any capacity that he can.  He has always been a helpful and thoughtful person.  
He’s always willing to put others before himself.  For the past 12 years, he has told clear of 
trouble and has focused on his Personal Training Business and his family. 
Throughout the lockdown, he himself has had medical challenges that i’m afraid might be hard 
to manage if sent to prison. On top of contracting covid, we also had to deal with medical di-
agnosis that is still inconclusive along with his shoulder and knee surgeries that he is still wait-
ing on for a date.  My biggest fear is him falling ill while in prison and not being able to receive 
the care of his loved ones.   
It is unfortunate that Adedayo has made some poor decisions which led us here and i am very 
disappointed with his choices.  However, that does not overlook the good characteristics he 
has as a Son, Husband, father, friend, a person.  I believe that as we move forward he will be a 
better person and this will serve a lesson that he can look back on and use as a teaching mo-
ment to younger ones.  I also believe that everyone makes mistakes but we must learn from 
them.  I recognize that Adedayo has made mistakes in the past and i sincerely ask that you 
please find it in your heart to show leniency while sentencing him and temper justice with mer-
cy.  Thank you for your consideration and thank you for taking the time to read this letter. 
If you have any inquiries please contact me at anytime. 
Sincerely,  
 Wunmi Fadipe-Ilori 
 
  
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 15 of 24

EXHIBIT 6 
Letter from T.I. 
(Adedayo’s daughter) 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 16 of 24

I. 
August 11th, 2021
Judge
United States Courthouse 500 Pearl Street
New York, NY 11412
Dear Judge,
I am writing this letter to ask for leniency on behalf of my father, Adedayo Ilori. Additionally, I
hope that this letter shows you what kind of person he is despite the offenses that have been
charged against him. I feel strongly about my relationship with my dad and want him to be there
for me in the future. I’ve seen my dad go through many obstacles during my lifetime and he still
manages to be positive, joke around, and have fun.
My dad helps me with my homework, extracurricular activities, and personal issues that I may
have. I also have a brother who is 11 years old and their relationship with each other is great.
They go to the park, take walks and confide in each other. My dad has been nothing but a good
father to me and my brother, so I hope you see the good in his heart.
My father, Adedayo Ilori is not only a dad but a son in law, a husband, an uncle, and a son. And
still with all the people who rely on him, he still is able to nurture and love everyone. I also will
be entering my second year of high school at Excelsior Preparatory High School which I plan on
running track and field. Since my dad works as a trainer he will help and push me to be a great
runner. And although my dad works in the field of fitness I know that he and my mom will push
me to do my best academically too.
Therefore judge, I urge you to take into consideration how many people who know and love my
dad want him to stay with us and keep his freedom. I can’t imagine Christmas, a birthday,
Easter, or any day without him. I’ll miss him calling me to get up before 12:00 pm on the
weekends or being at my track and field games. I hope this letter shows you how much my dad
means to me and my family and how you should take into consideration who Adedayo is before
charging him with any crimes.
Sincerely,
T
 
 I
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 17 of 24

EXHIBIT 7 
Pictures of Adedayo and His Family 
Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 18 of 24

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Case 1:20-cr-00378-LJL     Document 97-1     Filed 09/29/21     Page 20 of 24

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