Affidavit Defendant Bern Benoit's Character Witnesses - Ronnie L. Breaux — USA v. Thomas et al. (Dkt. 378-1, N.D. Ga.)

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U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 378-1 · 2021-09-01 · Docket on CourtListener

Full text

1 
 
IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA, 
) 
) 
Plaintiff, 
) 
) 
vs. 
) 
CASE NO.: 1:20-CR-00296-JPB-AJB 
) 
BERN BENOIT, 
) 
) 
Defendant. 
) 
  
) 
 
 
DEFENDANT BERN BENOIT’S CHARACTER WITNESSES – RONNIE L. 
BREAUX, JR.; JAMES SMITH; RON LYLES; MAURINE LOPES; 
LAWANDA C JACKSON; REBECCA KHAMMAR AND MAURICE 
STEWART 
 
 
 
Dated this 1ST day of September, 2021. 
 
Respectfully submitted, 
 
s/ Anthony O. Egbase 
 
ANTHONY O. EGBASE 
California Bar No. 181721 
Attorney for Defendant Bern Benoit 
 
 
 
A.O.E LAW & ASSOCIATES, INC 
350 S. Figueroa Street 
Suite 189 
Los Angeles, California 90071 
(213) 620-7070 (Telephone) 
(213) 620-1200 (Facsimile) 
info@aoelaw.om 
Case 1:20-cr-00296-JPB-CMS     Document 378-1     Filed 09/01/21     Page 1 of 10

Charactcr l.ettcr lirr Bcrn llcnoit
Dittc: 6.4.21
To Whom tt lv{l.y (.oncc'rn:
My nanre rs Ronnic 1,. Ilrciru x, Jr. I anr rvrrtirrg this lctter to s;;e ai< r;rr thI
relationship that I have with Bern Benoit. I rnet Eern atrout 5 years frgo while
working on a job. I was new to the field and he took rne undEr his wing and madc
sure that I undcrstand cv0ryth ing about thal job to thc ber.st of rny altility. [;or that I
rn extrcnrcly gratclul. llc lrrad c slire ldidn't f;ril. From th.rt poilrt on l3crn:rnd lhaye
beconre grcat friends,
Bern is one of the nrost clcpendable peoplc I knolv, his lrryalfy is scconrl to none and
I anr tnrly [r]e.ssed to consider"[rir.n a fl'icnd. 'l-herc's nothilrg that Ile rrr rvouldn't clo
pco ple, he g,ets extrcrnc jo,v ,when pcople around him succc.ed. llc will pu.str you
the linrsh line by;tny rneilns ncccssary, that's his character.
Istrongly stand behind this st;]tcrncrlto[character firr Bcrn l]enoit. please fcel free
contact nre if there are ;tny additional qucstions.
nnie L.
r.
310,531.0741
Case 1:20-cr-00296-JPB-CMS     Document 378-1     Filed 09/01/21     Page 2 of 10

YOUR HONOR:
I want to start off by saying I thank you for your time to take a minute to
read this letter. My good friend BERN BENOIT has always been a man of
class an integrity. l've always been able to count on BERNS for my kids b-
day parties and any other events that l've invited him to. We've been close
buddies for over 10 yrs and as you can see from his background, he's not
a criminal by any means. I do understand YOUR HONOR that we all make
mistakes in life and lwould appreciate you taking BERN'S character and
background in account prior to sentencing.
Thank you again for time and consideration,
JANIES SNIITH
Q1A4 Hoffman st. Unit 202
STUDIO CITY. CA 91604
3i3 8=1">aa\
Case 1:20-cr-00296-JPB-CMS     Document 378-1     Filed 09/01/21     Page 3 of 10

Your Honor,
l'm writing on behalf of Mr. Bern Benoit who lhave come to knowto be a
man of Christian faith, conviction, consistency, and character.
lr/y name s Ron Lyles and I'm a licensed Lay tMinister and member of the
Faithful Central Bible Church in lnglewood California.
I am a leader of a prayer group and was introduced to Bern from a friend
who l've known and has been a solid member of the community for over
30 years.
Bern has been a faithful and consistent member of our Znd Chronicles
7:14 Prayer group. He is contributed to our group greatly by his presence
and contribution. We recently celebrated his physical baptism confirming
his Christian faith.
I would ask, your honor, that you would have mercy in your sentencing for
a man, who in my observation, has taken responsibility for his actions and
his made efforts to cooperate with the investigation and exhibited a desire,
going forward, to continue to be a positive contributor to his cCImmunity
and society at large.
I am prepared to continue to provide moral support, accountability, prayer,
and spiritual advice as needed to walk along side Bern.
Thank you for your consideration in this matter.
Sincerely,
Ron Lyles
{G>6 317-ii 00
Case 1:20-cr-00296-JPB-CMS     Document 378-1     Filed 09/01/21     Page 4 of 10

Lopes
t395
Sherman Way, Unit 402
uys, California9l40S
Charucter Refereneefor Beru Benoit
Van
Re:
To
My
and
them like they are his family. I recently have had to deal with some health and family
This May Concern:
is Maurine Lopes and have personally known Bern Benoit for ovu 10 years. I met
Bern
a mutual friend and we quickly became close friends.
Bem
to Califomia with nothing to start a business and make it on his own, and I have
him build that business and successfully run it on his own. This is all because he is an
hard worker and will do whatever it takes to succeed. That carries over into his
relationships as well. He is an extremely generous person when it comes to his friends
lssues
he has been there to help any way he could.
It is
sincere hope that the court will take all of this into consideration when making its
and I would be happy to speak to all of these examples if called upon to do so.
you for your time.
Lopes
Case 1:20-cr-00296-JPB-CMS     Document 378-1     Filed 09/01/21     Page 5 of 10

LaWanda
To Whom
I have kn
associate
f riends"
Bern is ve
over the
our Churc
Since I
mother.
that I ba
Over the I
Lord. Just
Overall Be
LaWanda
os An
. Jackson
hlay Concern:
n Bern Benoit for more than 1g years. I first met him as a work
my husband Thomas. Over the years they have remained
kind and respectful. I have had many interactions with him
rs. He is a real cool guy. He has even supported a couple of
's fundraisers for the hoys mentoring Brogram, Sword Warriors.
known Bern, I've known him to make regular travels to visit his
n he goes to visit he always takes fresh baked goods to her
st few years, Bern has had an intense desire to get closer to the
cently he was even baptized.
is an upstanding individual.
. Jackson
Case 1:20-cr-00296-JPB-CMS     Document 378-1     Filed 09/01/21     Page 6 of 10

Khammar
1231 South Bundy Drive #6
Los
cA,90025
June
,2021
Re:
Benoit
Dear
orMadam,
Iam
this letter to you to provide a character reference for Bem Benoit, who I have
2005-
slooe
last 16 years I have witnessed Bern overcome trials and tribulations, support his family
on him a great deal and give from his heart to his friends and Ioved ones, Bern and
I
has
and
Goddaughter
It is his faith that makes it difiicult for him to do
more than anyone should have to sinoe he was a child, yet he is
and it is been my honor to witness his faith in action over the
anything bad without feeling intense
always full of hope
years. He
a
Over
who
would
not
I
Overwhelming remorse and sadness is what he's feeling right now. I know that he
anything to make amends without having to be taken away from his family. The idea of
able to support and help his mother is what is affecting him the most.
that he has learned his lesson. This transgression has shaken him to the core. Given the
he would make better deoisions. It is my sincere hope that the court gives Bem
and a chance to rectiff his mistakes without having to sacrifice precious time with his
niece and nephew.
be happy to speak to the court and elaborate on why I feel that Bem Benoit, a man of
faith,
atnazing son, brother, uncle, Godfather, friend and a pillar of the community, deserves a
chance at living an upstanding lifb with his family.
Thank
for your time.
Khammar
I
3t
Case 1:20-cr-00296-JPB-CMS     Document 378-1     Filed 09/01/21     Page 7 of 10

323-481-749A
m..:lw r€, eqrc 0) V."r llo(l r {.) I r }
to whom it may concern
my name is Maurice stewart,l know Bern from work,we met in 2OO1 while we were both chauffers
at a limousine conrPanY.
I am writing this letter to vouch for Bern's character and to let you know what type of person he is.Bern
is a hard worker and a very motivated person.We started out as drivers but he went on to start his own
Limo company and I eventually started working for him.He always went above and beyond to help
everyone around him and would give even if he didn't have it.There wer times when friends of ours
didn't have a place to stay and Bern would let them live with him until they got on their feet,without
asking to be paid back.
I hope this has given you a better picture of Bern as a overall person and thank you for taking the time
to read this.Feel free to contact me if you need more information
Sincerely,MAU RICE STEWART
Case 1:20-cr-00296-JPB-CMS     Document 378-1     Filed 09/01/21     Page 8 of 10

 
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C:\AOE\Client\B\Benoit\MotionForAdditionalTime 
CERTIFICATE OF COMPLIANCE 
 
This is to certify that to the best of my knowledge this document has been prepared 
with one of the font and point selections approved by the Court in LR 5.1B, pursuant to LR 
7. Specifically, the above-mentioned document has been prepared using Times New 
Roman font, 14 point. 
Dated this 1ST day of September, 2021. 
 
s/ Anthony O. Egbase 
 
ANTHONY O. EGBASE 
California Bar No. 181721 
Attorney for Defendant Bern Benoit 
 
A.O.E LAW & ASSOCIATES, INC 
350 S. Figueroa Street 
Suite 189 
Los Angeles, California 90071 
(213) 620-7070 (Telephone) 
(213) 620-1200 (Facsimile) 
info@aoelaw.om 
C:\AOE\Client\B\Benoit\MotionForAdditionalTime 
 
Case 1:20-cr-00296-JPB-CMS     Document 378-1     Filed 09/01/21     Page 9 of 10

- 5 - 
 
 
IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA, 
) 
) 
Plaintiff, 
) 
) 
vs. 
) 
CASE NO.: 1:20-CR-00296-JPB-AJB 
) 
BERN BENOIT, 
) 
) 
Defendant. 
) 
  
) 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on the above date, I electronically filed this document 
using the CM/ECF system which will automatically send email notification of such filing 
to all attorneys of record. 
Respectfully submitted, 
 
s/ Anthony O. Egbase 
 
ANTHONY O. EGBASE 
California Bar No. 181721 
Attorney for Defendant Bern Benoit 
 
A.O.E LAW & ASSOCIATES, INC 
350 S. Figueroa Street 
Suite 189 
Los Angeles, California 90071 
(213) 620-7070 (Telephone) 
(213) 620-1200 (Facsimile) 
info@aoelaw.om 
C:\AOE\Client\B\Benoit\MotionForAdditionalTime 
 
 
 
Case 1:20-cr-00296-JPB-CMS     Document 378-1     Filed 09/01/21     Page 10 of 10

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