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Case 2:24-cr-00383-HCN-CMR Document 75 Filed 12/06/25 PageID.364 Page 1
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CRAIG R. JOHNSON #10151
CRAIG JOHNSON LAW, PLLC
Attorney for Defendant
2500 N. University Ave.
Provo, Utah 84604
Telephone: (801) 458-2285
Fax: (801) 704-7070
Craig@CraigJohnsonLaw.com
UNITED STATES DISTRICT COURT
DISTRICT OF UTAH, CENTRAL DIVISION
UNITED STATES OF AMERICA,
Plaintiff, POSITION OF DEFENDANT WITH
RESPECT TO SENTENCING FACTORS
vs.
Cases: 2:24-cr-00383
BRENT RICHARD JOHNSON,
Defendant.
Magistrate Judge: Howard C. Nielson Jr.
Craig R. Johnson, Federal Defense Attorney, hereby submits this “Position of Defendant
with Respect to Sentencing Factors” to the Court on behalf of BRENT RICHARD JOHNSON, the
Defendant. The Defendant has no objections to any material information, sentencing classification,
sentencing guideline ranges, and policy statements contained in or omitted from the presentence
report. Defense counsel has conferred in good faith with the United States prosecutors and with
probation officer Conrad Kaufman in an attempt to resolve any disputed matters, which do not
exist.
The Defendant would respectfully ask the Court to take into account that:
1. On December 2, 2025, Utah Fourth District Court Judge Roger Griffin sentenced
the Defendant to three consecutive “15-to-life” prison sentences in case 241100537,
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which represents the “hands-on” offense underlying the videotaped evidence in this
case. Based on the Utah State Adult Sentencing, Release, & Supervision
Guidelines, the Defendant is anticipated to serve at least 345.6 months in the Utah
State Prison before his first chance at State parole.
2. Other than this criminal episode, he has no felony criminal history,
3. His psychosexual evaluation notes some important findings:
a. “Mr. Johnson was scored in the Moderate density range of criminogenic
needs on the STABLE-2007 and was preliminarily placed in Level II on the
Static-99R. When these measures were combined, his composite assessment
places him in the Level II category of risk for sexually reoffending.”
b. “Individuals placed in Level II are considered Below Average Risk using
the standardized risk level framework. Most individuals have few
identifiable criminogenic needs and have clearly identifiable prosocial
resources and strengths. When moderate levels of criminogenic needs are
observed, these needs are expected to be transitory, rather than ingrained,
problems. The risk of new criminal behavior for individuals in Level II is
lower than the average individual convicted of sexually motivated
offenses…”
c. “The combined Static-99R and STABLE-2007 risk assessments placed Mr.
Johnson in the Below Average category of risk to reoffend sexually.
Individuals at this risk level are typically placed in community settings…”
4. His character letters show he has been a contributing member of society (see
EXHIBIT A).
Dated this 4th day of December, 2025.
Respectfully Submitted:
BRENT RICHARD JOHNSON
By: /s/ Craig R. Johnson
Craig R. Johnson
Federal Defense Attorney
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EXHIBIT A
3
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jameswadsworth@me.com
to me, krista
To Whom It May Concern
I have known Brent Johnson for the past five or six years, and I have been asked by his wife, Julie Smith Johnson, to write a letter of
recommendation on behalf of Brent.
Brent has been a neighbor and friend ever since we met. I also have met and had some interaction with his four biological children, but mostly
with his two daughters, both of whom attended the same church as me during their high school years.
I maintain an extremely busy schedule, and so I have not taken the time to look up the charges and/or court proceedings related to Brent. In
fact, I would prefer to remain neutral about such things. Consequently, I have communicated as a friend with Brent on a fairly regular basis
(once or twice a month) until late summer when the demands in my own life have left me little or no time to continue our communication.
I have found Brent to be a good friend. Most importantly, I have found him eager to learn. He has commented to me since his incarceration
that he is amazed at my own family relationships, as I have reported to him on several occasions that I have gathered my family together for
meals and reunions. I know that Brent has not had many of the advantages that I have had in life. He has had a strained relationship with his
father and brother. He tragically lost his first wife, leaving him with four little children to raise. Along the way, it is understandable that Brent
may have succumbed to the pressures of life. If so, he is like so many of us.
This I do know. There is a range of punishments that the State can assign to Brent. On the one hand, the State can be heavy-handed and doom
the rest of his life for misdeeds that he might have done. On the other hand, as we all know, there are times when the State can be lenient --
sometimes too lenient for those who wish to quarterback from the sidelines.
In this case, I hope the State can find a pathway for Brent that will allow him to make any necessary changes in his life. I hope such a path will
enable him to patch up relationships that might have been damaged. In my written communications with him, I see a Brent who is humble and
willing to face the terrible conditions of his incarceration with a strange sense of appreciation, despite the unimaginable living conditions of
jail.
So it is my sincere recommendation that the State map out a pathway to a new Brent who can, not only mend fences that need mending, but
who is willing to learn how to bless others through his experience and be a net positive contributor to his family and society.
James Wadsworth
801-368-9630
jameswadsworth@me.com
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Your Honor,
I have known Brent Johnson since July 1993. Since that time, Brent has been loyal, supportive, and compassionate towards me, and my
family. I pray you will consider this in your decisions regarding his future.
My first meeting Brent is a great first example of this. I first met Brent when we were both young men at age 19. We had both recently
moved to England, trying to figure out our new life in a foreign land amongst strangers. He had arrived in England just one month prior to
me. We were playing basketball one Monday, and he saw me, brand new to the area, and clearly unsure of myself and my surroundings,
and my outward display of discomfort in my new situation. Brent immediately came over, extended a sold and warm handshake, and
befriended me. He had compassion on me. He immediately sought to reassure me, and to give me my very first ‘friend’ with a friendly
face, a friendly smile, and friendly conversation. He encourage me to hang tough and that things would get better. And he was right. He
was truly a ‘light’ to me at that time, when I needed it a lot. I will never that first meeting, and what became a lifetime of friendship.
We have remained friends since that day, some 32 years later. His love and friendship, support, and compassion towards me has remained
constant. We all have our challenges, we all have our faults. But, Brent’s willingness to serve and give to others, and show love to others,
has shown itself to me several times. I have always known Brent to be a man that I rely on to help me if I needed help. He is that kind of a
person.
Let me give another example to illustrate. When I was in law school, I took a job in Las Vegas, Nevada at a law firm to be a “summer
clerk” during my 2nd year of law school. I had no place to live, and my wife and son were living in California at an apartment there,
because that is where I was going to school. We couldn’t afford to have two different apartments, and we were locked into the California
apartment. I was unsure as to what we were going to do. At that time of my life, Brent happened to be living in Las Vegas with his wife
and children (prior to his wife’s sudden and tragic passing away due to a surgery complication). Brent learned of my need, and willingly
and graciously offered up his home as a place I could stay and live while working at that law firm. He opened up his home, and he and his
wife and family treated me so well. They didn’t have an abundance, they were striving to make every day count, just like the rest of us.
But during that time, he made me feel like family. We ate together, played games together, and shared spiritual experiences together. He
was kind, loving, compassionate and supportive of me, and was there for me in my time of need at that point in my life.
Brent has continued to be that in the years that followed. I recognize that each person has their mistakes, and sins, none of us escape that.
And we all must account for that. But, I pray and ask for mercy to be extended upon Brent, my dear friend who has extended his hand of
mercy to me many times, and was a friend throughout.
Jason McNeill
Office: 801-823-6464
Direct: 801-823-6465
236 South 300 East
Salt Lake City, Utah 84111
mcneill@mvmlegal.com
www.mvmlegal.com
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Craig Johnson <craig@craigjohnsonlaw.com>
Brent Johnson
p.scottpierson@gmail.com <p.scottpierson@gmail.com> Mon, Nov 17, 2025 at 5:38 PM
To: craig@craigjohnsonlaw.com, krista@craigjohnsonlaw.com
To the honorable Judge Griffin
My name is Patrick Pierson, and I have known Brent Johnson for approximately fifteen years. During
that time, I have seen Brent through both difficult and successful seasons of life, and he has
consistently been a positive and grounding influence in mine.
There were times when I struggled to find employment, and Brent stepped in without hesitation.
Most notably, in August of 2021, I went through a divorce and lost my job as an adult probation
officer after being unable to complete the police academy. I was facing serious depression and
financial hardship. When I reached out to Brent for help, he didn’t make me wait or wonder—he
told me, “Give me thirty minutes and I’ll get you a job.” Less than thirty minutes later, he did exactly
that.
Brent has always been a man of character, compassion, and integrity. His willingness to serve and
support the people around him is not something he does for recognition—it is simply who he is.
One example that stands out is when my niece, Payton, was attacked by her grandmother’s dog
and nearly lost her eye. Payton required major facial surgeries, and my sister and brother-in-law
were overwhelmed by medical bills. Brent, without even knowing my sister personally, offered to
help pay some of the expenses. That is the kind of heart he has.
I have also watched Brent interact with my son, and he has always treated him with kindness,
encouragement, and genuine care.
From my fifteen years of knowing him, I can confidently say Brent is a good man, a loyal friend,
and someone who has consistently lifted others when they were at their lowest. His character has
never wavered.
In closing, I respectfully ask the Court to take into consideration the man Brent has consistently proven
himself to be—someone who lifts others, takes responsibility, and genuinely cares for the people in his life.
Based on my own experiences and the many times Brent has shown up for me , his friends, acquaintances
and my family, I can say with confidence that he is a good man at heart. I truly believe he is capable of
learning, growing, and continuing to be a positive influence in our community. I respectfully ask the Court to
take his character, compassion, and lifelong pattern of helping others into account.
Respectfully,
Patrick Pierson
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To whom it may concern,
I am writing this letter on behalf of Brent Johnson. My name is Julie
Johnson and I am the wife of Brent. We have been married for five
years. We met in the spring of 2017 and dated until 2020 when we
were married.
Brent is a good man. A man that cares deeply about those in his life.
He raised his four children on his own for 14 years after his first wife
passed away unexpectedly. He raised them to know what’s right.
He raised them to be hard workers. He raised them to be kind to
others.
When I came into his life and he was introduced to my two children,
he encircled them with love and tried to teach them the things he
had taught his own children. When my children’s father stepped
away and didn’t speak to my children for years, Brent was there to fill
that gap. He helped shape my son into the man he has become.
He helped me in getting my son on his mission by teaching him
gospel principles and guiding him.
I have never been in danger with Brent. My children have never
been in danger. His children have never been in danger.
There will be many that write hateful words about Brent, but I know
Brent is a loving, caring husband, father and friend. He loves God
and he loves his family.
I ask that you consider all of these facts.
Sincerely,
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Julie Johnson