Sentencing Memorandum on Behalf of Michael Dimassa — No. 3:22-cr-00033 (Dkt. 306, D. Conn.)

Summary

A sentencing memorandum, Document 306, dated April 13, 2023, by John R. Gulash for Michael DiMassa in United States v. DiMassa, Case No. 3:22-cr-00033-OAW, in the U.S. District Court for the District of Connecticut. DiMassa, 32 and a first offender, pleaded guilty on November 1, 2022 to three counts of conspiracy to commit wire fraud under 18 U.S.C. §§ 1343 and 1349. Counsel does not dispute the facts in the PSR: as an administrative assistant for the City of West Haven, DiMassa signed off on invoices for services never provided by Compass Investment Group, LLC, L&H Company and JIL Sanitation Solutions, drawing largely on the approximately $1.15 million in Covid Relief Funds the city had received. It cites the Sentencing Commission's May 2004 first-offender recidivism study and asks for a non-Guideline sentence with appropriate conditions.

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“Sentencing Memorandum on Behalf of Michael Dimassa — No. 3:22-cr-00033 (Dkt. 306, D. Conn.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/sentencing-memorandum-on-behalf-of-michael-dimassa-no-3-22-cr-00033-dk-77ae4e4634/, SHA-256 79e33303d1ea6ff1b3a5360f4d46301111d93be79337ed1521919ff2b712f4a6.

Full text

UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA,
Plaintiff Case No. 3:22-cr-00033-OAW

MICHAEL DIMASSA, APRIL 13, 2023
Defendant

SENTENCING MEMORANDUM ON BEHALF OF
MICHAEL DIMASSA

Michael DiMassa, by and through counsel, respectfully submits this memorandum of

law and accompanying documents to assist the Court in determining the appropriate sentence

to impose at Mr. DiMassa’s upcoming sentencing hearing. These remarks are addressed to

what are anticipated to be the main issues and arguments presented to the court at sentencing.

For the most part, this Memorandum will be a discussion of individual factors and

circumstances that support the sentence that will be requested by the Defendant. We intend to

rely upon the collective record in this case, which consists of the very thorough PSR prepared

by Senior U.S. Probation Officer Michelle Murphy and the evidence and information

presented or available to the Court during the pendency of the case.

The undersigned anticipates receiving, prior to the sentencing hearing, support letters

from friends and family members who have known Mr. DiMassa both before and after the

conduct at issue. Said letters of support will be provided to the Court as a supplemental

filing upon receipt.

I. PRELIMIARY STATEMENT

Michael DiMassa, who is presently 32 years old (aged 31 at the time of the offense),

is to be sentenced by this Court following his plea of guilty on November 1, 2022, to three
counts of Conspiracy to Commit Wire Fraud, in violation of 18 U.S.C. § 1343 and 18 U.S.C.

§ 1349. This plea of guilty represents a first conviction in any court, and therefore a first

sentence for Mr. DiMassa.

It is worth noting at the outset that defense counsel does not dispute the facts relating

to the Mr. DiMassa’s criminal conduct and involvement in the charged offenses as outlined

in the PSR. The Court has been provided with an exceptionally thorough report prepared by

Probation and a high level of detail regarding the Government’s factual allegations, having

not only presided over the full trial of Mr. Trasacco, but also having heard nearly three days’

worth of testimony by Mr. DiMassa.

During the period of the offense conduct, Mr. DiMassa was employed as an

administrative assistant to the City Counsel and was responsible for signing off on invoices

requesting payment from the City of West Haven for services rendered to the city. The City

of West Haven Financial Director, an unwitting participant, was responsible for authorizing

the final approval of the disbursements for payment of invoices for services rendered for the

city. The City of West Haven received approximately $1.15 million in Covid Relief Funds,

which were deposited into a city account.

The charges, for which Mr. DiMassa has entered a plea of guilty, stem primarily from

Mr. DiMassa’s role in a fraudulent scheme involving the submission of requests for payment

from the City of West Haven for services purportedly provided by Compass Investment

Group, LLC; L&H Company; and JIL Sanitation Solutions when no services were actually

provided by these entities. The funds disbursed primarily involved Covid-19 relief funds and

the services, which were fraudulently claimed to have been provided, related to Covid-19,

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such as legal research, lobbying, site work for a Covid-19 clinic, HVAC maintenance at

multiple municipal locations, the purchase of personal protective equipment, cleaning

services for various municipal and school buildings, etc.

In January 2021, Mr. DiMassa and colleague, John Bernardo, Housing Specialist in

the Office of Community Development Administration of West Haven, formed Compass

Investment Group, LLC. Both Mr. DiMassa and Mr. Bernardo were listed as principals of

the company. The services fraudulently claimed to have been provided by this entity related

to services concerning the West Haven Public Health Department. As a result of the

fraudulent invoices created by Mr. DiMassa, the City of West Haven issued thirteen checks

totaling $636,783.70 to Compass Investment Group, LLC. The lions share of the money

obtained through this particular entity ($587,856.45) went to Mr. DiMassa, of which nearly

all was used to support Mr. DiMassa’s gambling addiction.

Mr. Bernardo introduced Mr. DiMassa to Mr. Trassaco in late 2020, just before

Compass Investment Group, LLC was formed. Shortly thereafter, Mr. Trassaco approached

Mr. DiMassa with a proposal to have Mr. Trassaco, through his company, L&H Company,

and later JIL Sanitation Services, provide fraudulent invoices relating to the purported

provision of Covid-19 supplies to West Haven schools. The understanding reached between

the parties was that Mr. Trassaco would submit fraudulent invoices and Mr. DiMassa would

assist in getting the City of West Haven’s approval to disburse payment on the invoices. Mr.

Trassaco, after involving himself in the scheme, took advantage of the situation, and of Mr.

DiMassa and Mr. Bernardo, by seeking much more money from the City of West Haven, via

the fraudulent invoices, than Mr. DiMassa had originally anticipated. Following the initial

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success of the early disbursements, Mr. Trassaco wanted more, and continued to submit high-

priced invoices for services never rendered relating to the City of West Haven, which Mr.

DiMassa questioned. Mr. DiMassa recognized that it would be difficult to justify payment of

certain invoices submitted by the entities controlled by Mr. Trassaco. Based on a

combination of fear of and deception by Mr. Trassaco, Mr. DiMassa, with significant

misgivings, assisted Mr. Trassaco in facilitating payment of the fraudulent invoices

submitted by the entites controlled by Mr. Trassaco.

Defense counsel is not in any way suggesting that Mr. DiMassa was an unwitting

participant in the offense conduct, or that he had not expected compensation for his role in

assisting Mr. Trassaco. However, it is important to note that the extent and scope of the

fraud was greatly enhanced by Mr. Trassaco and his influence over Mr. DiMassa. After

using Mr. DiMassa in order to get the necessary approval for the disbursement of the funds

for services that Mr. Trassaco never provided, Mr. Trassaco bilked both Mr. DiMassa and

Mr. Bernardo and, of the total $431,982.00 paid to the various entities controlled by Mr.

Trassaco, Mr. Trassaco kept all but approximately $20,000.00, which he disbursed to Mr.

DiMassa and Mr. Bernardo over time in incremental cash payments.

In addition to the above-described scheme, Mr. DiMassa, with the assistance of his

now-wife, Lauren Knox, defrauded the City through a Youth Violence Initiative, which

immediately preceded the conduct relating to the Covid relief fund. The funds at issue were

not federal funds, but rather regular, City of West Haven or ‘state’ funds. With regard to the

Youth Violence funds, Mr. DiMassa created false invoices for services that, on paper,

appeared relevant under the framework of youth violence, but were never actually delivered.

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Mr. DiMassa paired the invoices with vouchers for payment. The City of West Haven

would then issue checks payable to Ms. Knox, which she would cash and transfer to Mr.

DiMassa,

In total, while approximately half of the disbursed funds inured to the benefit of third

parties, Mr. DiMassa assisted in facilitating a loss to the City of West Haven in the amount of

approximately $1.2 million.

Regardless of any determinations made under guidelines factors, there are, even

taking into account the agreed upon downward departures, substantial grounds to conclude

that the appropriate sentence for Mr. DiMassa is a non-Guideline sentence. There are

factually and legally cognizable reasons for a finding that the charged conduct does not

represent Mr. DiMassa in a balanced light. The conduct does not accurately reflect his

character, personal circumstances or adequately account for his blameless prior record.

By law, a court is obligated to structure a sentence that is “sufficient, but not greater

than necessary” to accomplish the goals of sentencing under 18 U.S.C. ¶ 3553(a). Such a

sentence is the lowest possible sentence that accounts for all of the relevant factors. Where a

district court concludes that a lower sentence will be as effective as a higher sentence, it must

impose the lower sentence United States v. Ministro-Tapia, 470 F.3d 137, 142 (2d Cir. 2006)

(“if a district court were to explicitly conclude that two sentences equally served the statutory

purpose of § 3553, it could not, consistent with the parsimony clause, impose the higher.”).

In considering the nature and circumstances of an offense, and a defendant’s prior criminal

history, a sentencing judge, must determine a sentence that represents a just punishment,

general and specific deterrence, balanced with the goal of rehabilitation, subject to the

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precept of parsimony.1 The emphasis on and importance of these purposes may shift or a

particular purpose may apply differently, or even not at all, depending on the kind of

sentence under consideration.” Tapia v. United States, 564 U.S. 319, 326 (2011). In an early

post-Booker case, the United States Supreme Court observed that where a sentence is unduly

punitive, it is at odds with those goals, and may operate “to promote not respect, but derision,

of the law.” United States v. Gall, 552 U.S. 38, 54 (2007).

In this post-Booker era the sentencing court has greater latitude. United States v.

Booker, 543 U.S. 220 (2005).2 The Court may now engage in what has been described as the

art of sentencing rather than the science of sentencing. Id. at 226. See, e.g., United States v.

Bruno, 789 F.3d 1249, 1254 (11th Cir. 2015) ("The decision about how much weight to

assign a particular sentencing factor is 'committed to the sound discretion of the district

court.' [Citation omitted]." 1B1.4. In determining the sentence to impose within the

guideline range, or whether a departure from the guidelines is warranted, the court may

consider, without limitation, any information concerning the background, character and

1 The district court must give respectful consideration to the guidelines in determining a
sufficient sentence, Gall, 552 U.S. at 47, but it may not presume that the guideline sentence
is the correct one, Rita v. United States, 551 U.S. 338 (2007). Rather, it is the statute's
parsimony provision, quoted above, which serves as the “overarching” command of§
3553(a). Kimbrough v. United States, 552 U.S. 85, 101 (2007).

2 Booker made the Sentencing Reform Act of 1984 [SRA] “effectively advisory” by excising
the SRA provisions that required judges to sentence withing guideline ranges, directing
judges to impose sentences that are “sufficient, but not greater than necessary” to comply
with the purposes of sentencing under 18 U.S.C. § 3553(a), and directing judges to
“consider” the guidelines and underlying policy statements removing the previously
mandated strict formulaic adherence in favor of individualized sentences. 543 U.S. 220, 264
(2005). 2

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conduct of the defendant, unless otherwise prohibited by law. A sentencing court is permitted

to more freely consider mitigating factors and this Court will be asked to do so in this matter.

II. GUIDELINES CALCULATION

There is a written plea agreement signed by Mr. DiMassa dated November 1, 2022.

Undersigned counsel, Probation, and the Government agree with the advisory guideline

calculation and Criminal History Category as determined in the plea agreement, which is

reflected in the PSR.

The PSR guidelines analysis begins with a base level of 7. (PSR ¶ 48). A 14-level

increase to the base offense level is recommended because the total loss attributable to Mr.

DiMassa due to his alleged conduct is more than $550,000.00 but less than 1,500,00.00.

(PSR ¶ 48). Because Mr. DiMassa abused a position of public trust in a manner that

significantly facilitated the commission of the offense, the PSR recommends a 2-level

enhancement. (PSR ¶ 51). Due to Mr. DiMassa having allegedly recruited Mr. Knox and Mr.

Bernardo to participate in the offense of Wire Fraud, having received greater financial gain

than Mr. Knox and Mr. Bernardo, and Mr. DiMassa’s alleged decision-making authority, two

levels have been added. (PSR ¶ 52). The PSR recommends a two-level reduction for Mr.

DiMassa’s acceptance of responsibility; and another agreed one-level decrease based on Mr.

DiMassa’s acceptance indicated by his plea and having assisted authorities in the

investigation or prosecution of Mr. DiMassa’s own involvement in the alleged conduct. (PSR

¶¶ 56 & 57). The PSR computation results in a total Offense Level of 22. (PSR ¶ 58). A total

Offense Level of 22, and Category I Criminal History, with his score of zero, results in a

guideline imprisonment range of forty-one (41) to fifty-one (51) months. According to the

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JSIN, using Guideline §2B1.1, and taking into consideration Mr. DiMassa’s total offense

level of 22 and his criminal history category I, the average length of imprisonment imposed

was thirty-three (33) months. It is worth noting that the JSIN platform excludes defendants

who have received a §5K.1 substantial assistance departure. (PSR ¶ 107).

As noted in the PSR, “Mr. DiMassa has never served a term of imprisonment. The

Court may consider the principle of incremental punishment as a basis for a downward

variance.” (PSR ¶ 125). “Mr. DiMassa has no prior criminal history...While on bond, he has

received mental health treatment…Mr. DiMassa presented as friendly, cooperative,

respectful and forthcoming with information. He repeatedly provided statements of remorse

and he appears genuine. While on pretrial release, Mr. DiMassa has maintained compliance

and is cooperative with the Pretrial Services officer.” (PSR ¶¶ 133 & 134). The Court may

wish to consider whether imposition of a sentence within the advisory guideline range is

more than necessary to accomplish the purposes of sentencing. We respectfully urge the

Court to consider this lack of a prior criminal history as a basis for a variance from the

applicable guidelines range.

Defendant respectfully maintains that the relatively young man Mr. DiMassa was,

and is, both before and since his participation in the charged offense, as well as his otherwise

unblemished record prior to the instant offense, warrants a departure and variance from the

advisory guideline range. Defendant further maintains that this requested exercise of the

Court’s authority is consonant with the purposes and goals of post-Booker discretionary

sentencing.

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III. PERSONAL BACKGROUND

Mr. DiMassa is a thirty-two-year-old man (aged thirty-one when he became involved

in the conduct at issue), born in New Haven, Connecticut, to the (former) marital union of

Manuel Rodrigues and Denise DiMassa-Donofrio. Mr. DiMassa was the only child born to

his parents’ union.

Mr. DiMassa’s parents divorced when he was one year old, and he does not recall his

parents maintaining a relationship or living together at all during his lifetime. Mr. DiMassa

was raised by his mother, later with the assistance of his stepfather, Patrick Donofrio, and did

not have a meaningful relationship with his biological father. Mr. DiMassa’s last name at

birth was ‘Rodrigues’; however, due to Mr. DiMassa’s biological father’s total lack of

interest in maintaining a meaningful relationship with Mr. DiMassa, despite Mr. DiMassa’s

efforts to do so, Mr. DiMassa legally changed his last name to ‘DiMassa’ at 18 years old,

which led to further deterioration of their virtually non-existent relationship. In 2022, Mr.

DiMassa’s father, Mr. Rodrigues, died in a motor vehicle accident.

When Mr. DiMassa was two years old, Mr. Donofrio, who would later become Mr.

DiMassa’s stepfather, moved into the home. Mr. Donofrio, who had several children from a

prior relationship, raised Mr. DiMassa as his own. Mr. DiMassa views Mr. Donofrio as his

father and calls him ‘dad’. The two have a very close relationship and Mr. DiMassa

considers his stepfather to be his best friend. Mr. Donofrio, who is now eighty-nine years

old, is approximately twenty years older than Mr. DiMassa’s mother; and, consequently, Mr.

DiMassa’s stepsiblings are significantly older than Mr. DiMassa. Mr. DiMassa’s stepsiblings

never resided in the family home. Mr. DiMassa did not have a relationship with them

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growing up, nor does he have a strong relationship with them currently.

Mr. DiMassa has faced adversity and fought diligently to succeed all of his life.

Throughout childhood, and up to the present day, Mr. DiMassa’s parents struggled, and

continue to struggle, financially. When Mr. DiMassa was young, his mother worked as a

receptionist for a short time but was mostly a homemaker. His stepfather, Mr. Donofrio,

worked in food service for Aramark and worked hard to support the family. While Mr.

DiMassa was a child, his mother and stepfather tried their best to shield him from their

financial difficulties, but they were unable to do so for very long, as they declared

bankruptcy when Mr. DiMassa was in elementary school due to significant credit card debt.

Both Mr. DiMassa’s mother and stepfather were poor money managers.

Mr. DiMassa’s mother, who did not work, spent beyond the family’s means, often

spending the little money the family had on shopping excursions for herself rather than

saving or using the money for practical expenditures, such as paying off debt. Mr. DiMassa

suspects that she suffered, and continues to suffer from, undiagnosed mental health issues

and never fully matured or “grew up” when it came to decision making as an adult,

especially regarding money. His stepfather was the breadwinner of the family and his ability

to provide for the family on his limited salary was made even more difficult by his gambling

habits. Despite the fact that Mr. DiMassa’s biological father, Mr. Rodrigues, provided child

support for Mr. DiMassa’s care, Mr. DiMassa’s living circumstances were destitute and the

family was constantly burdened with debt.

Mr. DiMassa recalls times when the electricity would be shut off due to unpaid

electric bills; going to bed and waking up hungry because the family did not have enough

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money for food; taking cold showers because there was no hot water; and regular threats of

eviction. Fortunately, because his stepfather worked in the food industry, he was sometimes

able to bring food home from work for the family. To this day, Mr. DiMassa’s mother and

stepfather continue to struggle financially, and they are on a payment plan for overdue rent.

Mr. DiMassa grew up keenly aware of the family’s financial problems. He often worried

that they might lose their housing. He vividly recalls his mother and stepfather arguing about

money in his presence; and he will never forget the feeling of embarrassment, shame, and

sadness of watching his mother and stepfather beg for money from friends and family so that

they could make ends meet.

Even though Mr. DiMassa was young and could not have reasonably been expected

to assist with bills, he remembers feeling a sense of guilt over not being able to help more,

and feeling like a burden to his mother, stepfather, and biological father. His father never

wanted anything to do with him and the only thing he ever did for Mr. DiMassa was pay a

marginal amount of child support, which Mr. DiMassa suspects was purely out of obligation

rather than love; Mr. Donofrio, his stepfather, had older kids of his own from another

marriage, who were more or less financially independent and did not rely on him for support;

and his mother had no other children or dependents apart from Mr. DiMassa. Mr. DiMassa

often wondered whether his family would have struggled less if they did not have to worry

about providing for him.

Despite the significant financial struggles, Mr. DiMassa’s mother tried her best to

remain upbeat and ensure that Mr. DiMassa felt loved and appreciated. He spent all holidays

and special events with his mother and stepfather and recalls that his mother attended all of

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his school functions. Whenever he would return from school, she would always be home

waiting for him ready to actively engage and spend time with him.

Mr. DiMassa has lived in Connecticut for his whole life but moved several times in

his formative years. He spent a short time in New Haven before moving to Milford with his

mother and stepfather. The family then moved to East Haven, where he attended both

elementary and middle school. The family ultimately relocated to West Haven and Mr.

DiMassa attended and graduated high school there.

While Mr. DiMassa experienced less than ideal living conditions at home, he excelled

academically. School was a welcome distraction from the family’s troubles. When his

grandmother passed away, she left a modest sum of money to Mr. DiMassa and Mr.

DiMassa’s mother. The money left for Mr. DiMassa was utilized pay for Mr. DiMassa’s

education at Notre Dame of West Haven. At Notre Dame, he participated in both track and

cross country, graduated with honors, and was named “Notre Dame Man of the Year.” He

did not take any time off between high school and college, despite the fact that just after Mr.

DiMassa graduated high school, his stepfather, who raised him since he was two years old,

suffered his first stroke and became extremely ill, rendering him unable to work or support

the family.

Mr. DiMassa felt guilty attending college and spending money on his education while

his mother and stepfather struggled, simultaneously, with finances and his stepfather’s health

issues. In spite of his difficult personal circumstances, Mr. DiMassa enrolled in Albertus

Magnus College in New Haven in August 2009 where he attended as a day student and lived

with his parents. He performed exceptionally well in college and graduated magna cum

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laude with a 3.8 cumulative GPA. He obtained a bachelor’s degree in Business Management

and graduated (on time) in May 2013.

After graduating college, Mr. DiMassa continued to feel responsible for helping his

mother and stepfather stay afloat financially, which he feels his mother exacerbated. It was

not enough that he supported his parents financially; in addition, his mother expected him to

take her out to dinner and take her shopping. He felt that, despite giving his parents

everything he could, it was never enough for his mother. Mr. DiMassa resented the fact that

his mother would not contribute any of the modest income that she earned through social

security towards paying off her own bills. By 2016, just three years out of college, Mr.

DiMassa filed for bankruptcy due primarily to credit card debt in connection with financially

supporting his parents, as well as gambling.

By 2016, at the age of 26, Mr. DiMassa had already been gambling for half of his life.

Mr. DiMassa’s stepfather, Mr. Donofrio, was a habitual gambler and introduced Mr.

DiMassa to gambling when he was in middle school. He and his stepfather regularly

purchased scratch off lottery tickets together and played the nightly lottery numbers. This

soft introduction to gambling, as Mr. DiMassa understood it, was his stepfather’s way of

showing him that, despite having very little money, you could make ends meet if you were

lucky. Mr. DiMassa believed, whether it was true or not, that the family’s bills were often

paid with their lottery winnings, which Mr. DiMassa felt that he was a part of, and it made

him feel like the universe was shining down on him and his family.

Apart from the lottery, his stepfather played online poker and had accounts set up,

with the assistance of Mr. DiMassa, across various websites, which he eventually allowed

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Mr. DiMassa to use, despite the fact that he was under the age of twenty-one. When Mr.

DiMassa reached high school, he became involved in online poker. He used his stepfather’s

accounts to gamble online throughout high school and while in college. When he reached the

age of twenty-one, he was legally able to create his own online poker accounts, which he did,

as well as accounts on illegal gambling sites.

Mr. DiMassa was able to compartmentalize his growing gambling addiction well and

keep it more or less under control for a significant period of time. He consistently worked,

earned an income, and was able to support himself and his parents while suffering from a

budding gambling addiction. Prior to his involvement in the charged conduct, Mr. DiMassa

was employed by the City of West Haven in various capacities starting in 2009 when he was

a college student. He worked as an intern for the Mayor’s Office from 2009 to 2013;

administrative assistant to the Registrars from 2013 to 2014; revenue clerk in the Tax office

from 2014 to 2016; and ultimately as City Council clerk from 2016 to 2021. While

employed as City Council clerk, in 2021, he became involved in the conduct at issue.

Prior to Mr. DiMassa’s involvement in the charged conduct, which began in 2020, he

was a model employee and had an unblemished record in public service. Prior to the conduct

at issue, he never wrongfully conveyed City of West Haven funds to himself or others, nor

has he been accused of doing so. Due to a combination of factors, which include a lifetime

of hardship and financial struggles; prior bankruptcy; the need to support himself and his

parents; an increasingly unmanageable gambling addiction; the recent success of the

acquisition of funds from the Youth Violence initiative; and newly gained, easy access to

approximately $1.15 million of federal Covid-19 relief funds, Mr. DiMassa engaged in the

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conduct at issue.

V. APPLICATION OF SECTION USC 3553(a) FACTORS MILITATES IN
FAVOR OF DOWNWARD DEPARTURE FROM GUIDELINES AND IN
FAVOR OF A NON-CUSTODIAL SENTENCE

The statute directs the sentencing judge to consider the following: (1) the offense and

offender characteristics; (2) the need for a sentence to reflect the basic aims of sentencing,

namely (a) ‘just punishment’ (retribution) (b) deterrence, (c) incapacitation, (d)

rehabilitation; (3) the sentences legally available; (4) the Sentencing Guidelines; (5)

Sentencing Commission policy statements; (6) the need to avoid unwarranted disparities; and

(7) the need for restitution. Rita v. U.S., 551 U.S. 338 (2007). Based on these statutory

factors, Mr. DiMassa respectfully urges the Court to depart from the guidelines. Permitting

sentencing courts to consider the widest possible breadth of information about a defendant

ensures that the punishment will suit not merely the offense, but the individual defendant.

Pepper v. United States, 562 U.S. 476, 494 (2011).

Prior to his participation in the offense, Mr. DiMassa had a pristine criminal record.

Subsequent to his guilty plea, Mr. DiMassa has complied with all release restrictions, has

worked very hard to secure employment, submitting weekly progress reports to Probation

and information regarding jobs for which he has applied. As noted in the PSR, Mr. DiMassa

has provided Probation with documentation of numerous employment positions for which he

has applied both online and in-person. (PSR ¶ 92). Apart from the brief seasonal position of

warehouse worker at FedEx in North Haven from November through December 2021, where

Mr. DiMassa earned $250 per week, he has been unable to secure employment. He has used

this time where he has been unable to work to provide for his family as a homemaker and

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cares for his infant son while being financially supported by his wife (prior to her post-

sentencing termination from employment) and mother-in-law, with whom, among other

family members, he resides. (PSR ¶¶ 92 & 93).

In addition to his dedication to finding steady employment and caring for his family,

Mr. DiMassa is about to become a father for the second time, as his wife is pregnant with

their second child. Mr. DiMassa, throughout his life, has been diligent, and determined to

persevere through separation and adversity, and is admirably resilient and resolved to

continue to be there, and provide for his family. He looks forward to continue to parent and

provide for his family and his newborn son and to provide them with the security of the

stable home life for which he had longed as a child.

As mentioned infra, and as has been brought to the Court’s attention in discovery and

through multiple days of testimony in the related matter of Mr. Trassaco, Mr. DiMassa

suffered from a debilitating gambling addiction at the time of the offense, and his essentially

unfettered access to a deep pool of federal funds and total lack of impulse control facilitated

his precipitous downward spiral. The amount of money a gambler can waste is only limited

by the amount of money that he has or has access to. The concept of, and treacherousness of,

gambling addiction can be difficult for people unfamiliar with this affliction to understand.

The impact of gambling addiction on those suffering from it, and on the lives of those around

them, may be less widely known than that of individuals suffering from drug addiction;

although, gambling, for addicts, triggers the same dopamine response as habitual drug users

experience.

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The latest edition of the American Psychiatric Association's Diagnostic and

Statistical Manual lists "gambling disorder" in the same category as heroin and opioid

addictions. “The criteria for the diagnosis include the need ‘to gamble with increasing

amounts of money to achieve the desired excitement,’ ‘repeated unsuccessful attempts to

control, cut back or stop gambling,’ jeopardizing or losing a ‘significant relationship, job or

educational or career opportunity due to gambling’ and relying on others ‘to provide money

to relieve desperate financial conditions caused by gambling.’ Some studies have found that

as many as 19 percent of problem gamblers attempt suicide, the highest rate of any

addiction.” See Gunn, Meghan. These Are the Real Dangers of the Sports Betting Boom for

Young Men. Newsweek. (March 22, 2023). Available at: http://www.newsweek.com.

(Accessed: April 13, 2023).

As the Court has consistently recognized, addiction can mitigate a defendant’s

culpability. The matter of United States v. Dikiara, 50 F. Supp. 3d 1029 (E.D. Wis. 2014) is

a prime example of a federal district court finding mitigation and imposing a non-Guideline

sentence where a defendant, suffering from a similarly debilitating gambling addiction as Mr.

DiMassa, stole over a million dollars from her employer over time, which she squandered

almost entirely gambling. Ms. Dikiara, without cooperation, and having paid minimal

restitution upfront, was sentenced to a 15-month term of imprisonment where the Guidelines

range was 41-51 months, based primarily on the severity of her gambling addiction and

treatment. The information considered by the Court, quoted below, in determination of the

sentence in Dikiara is equally applicable in the present case:

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In the present case, I first considered the impact of defendant's gambling addiction on
her conduct. Defendant did not act out of a desire to harm her employer, nor did she
steal in order to finance a lavish lifestyle. Virtually all of the money went to the
casino. The records from the casino demonstrated substantial losses, which ate up not
just the proceeds of the crime but also defendant and her husband's savings.

As Judge Mark Bennett recently explained, addiction can mitigate a defendant's
culpability. “By physically hijacking the brain, addiction diminishes the addict's
capacity to evaluate and control his or her behaviors. Rather than rationally assessing
the costs of their actions, addicts are prone to act impulsively, without accurately
weighing future consequences.” United States v. Hendrickson, No. CR 13–4110,
2014 WL 2600090, at *5 (N.D.Iowa June 11, 2014). Judge Bennett was talking about
drug addiction, but as the evidence defendant presented showed, gambling addiction
is similar. The American Psychiatric Association recently reclassified pathological
gambling from an impulse control disorder to an addiction-related
disorder. See American Psychiatric Association, Diagnostic and Statistical Manual of
Mental Disorders (“DSM–V”) 585 (5th ed.2003); see also Ferris Jabr, How the Brain
Gets Addicted to Gambling, Scientific American, Nov. 5, 2013.

Defendant also cited research that slot machines, her preferred mode of gambling,
were more addictive than other forms of gambling. See Natasha Dow Schull, Slot
Machines are Designed to Addict, N.Y. Times, Oct. 10, 2013 (“Studies by a Brown
University psychiatrist, Robert Breen, have found that individuals who regularly play
slots become addicted three to four times faster (in one year, versus three and a half
years) than those who play cards or bet on sports.”). The report from counselor Zangl
described addictive type behaviors and reactions on defendant's part, including a
description of how she was drawn to the machines—the colors and the themes. The
report also indicated that she kept thinking she would eventually win enough to pay
back the money she had taken. This too was consistent with the literature, including
the notion of “chasing one's losses” referenced in the DSM–V. Defendant further
presented literature discussing how this kind of addiction can lead from hoping for a
big score to cover past losses on to illegal activity. S.H. Dakai, Compulsive
Gambling: An Examination of Compulsive Gambling, Including Pathology,
Chemistry Exchange, Similarities to and Differences from Substance Abuse,
Gambling Phases, and Assessment Questionnaires, Journal of Addictive Disorders,
8–9 (2004). Given the impact of her gambling addiction, which was well-supported
by the defense materials, a below range term sufficed to provide just punishment.

Second, I took into account defendant's efforts to obtain treatment and rebuild her life
after this crime came to light. A defendant suffering from an addiction or compulsion
may be less culpable but, without treatment, may present a greater risk of recidivism
if the condition is not addressed. In the present case, both the Zangl report and the
PSR confirmed that defendant's addiction had been addressed. She regularly attended

18
GA meetings, participated in individual counseling, and voluntarily banned herself
from the casino. The counselor was positive about her prospects, indicating that she
had been totally compliant with their treatment plan. Her GA sponsor and the leader
of her meeting group also provided positive letters…

Third, I took into account defendant's lack of any prior record, which bore to some
extent on culpability but more on the need to protect the public. I saw little such need
here, given her age, lack of record, progress in treatment, poor health, and strong
family support. Her husband attended GA meetings with her so he could help her
avoid problems in the future. I also considered the fact that she had never served any
time before. Generally speaking, a lesser sentence will suffice to deter a defendant not
previously subject to lengthy incarceration than is necessary to deter a defendant who
has already served serious time yet continues to re-offend. See United States v.
Qualls, 373 F.Supp.2d 873, 877 (E.D.Wis.2005)…

Finally, I took into account defendant's acceptance of responsibility, admitting the
crime to her employer and then the FBI when confronted. She pleaded guilty to an
information and seemed genuinely remorseful. Prior to sentencing she made a
restitution payment of $5400, modest compared to what she owed, but nevertheless a
positive development. This also demonstrated remorse and a desire to make amends,
and suggested that I should take restitution payment into account in determining the
sentence. See 18 U.S.C. § 3553(a)(7). The term should not be so long that it would
destroy her ability to pay back more of what she owed.

These mitigating circumstances did not eliminate the need for punishment—I still
found a prison sentence necessary—but they did temper it. Under all the
circumstances, I found a sentence of 15 months sufficient but not greater than
necessary to satisfy the purposes of sentencing. This provided a significant
punishment for a 56 year old first-time offender, while acknowledging the other
mitigating factors discussed above.

United States v. Dikiara, 50 F. Supp. 3d 1029, 1032–34 (E.D. Wis. 2014).

Mr. DiMassa did not act out of a desire to harm his employer, and he did not steal in

order to finance a lavish lifestyle. Mr. DiMassa admittedly did use some of the money to

purchase some clothing, meals, drinks and cigars at the Owl Shop (New Haven), but it could

not be seriously argued that these indulgences were his primary motivation for engaging in

the conduct at issue, or that nearly all of the money was spent for this purpose. Throughout

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the relevant time period, he continued to drive the same, modest vehicle that he had owned

for years, a 2013 Buick Verano, which is worth approximately $4,200.00 and is still his only

vehicle. Almost all of the funds wrongfully taken were squandered gambling. Mr. DiMassa,

while he knows that his actions hurt his employer, the City of West Haven, the community,

and the city’s reputation, was never indifferent to the damage he knew that he was causing

and had no desire to harm his community or his employer. He truly loved his community

and greatly respected the office by which he had been employed in different capacities for his

entire adult life starting at the age of eighteen.

For Mr. DiMassa, gambling was not about winning or losing. It was about the

adrenaline rush of taking a risk for a potentially great reward, and chasing the short-lived

thrill of the unknown, potential to hit big and the accompanying dopamine high – a high that

became harder and harder to achieve, and was ultimately cut short when the money “won”

was lost, sometimes within seconds. Even just placing a bet in and of itself was a thrill. Mr.

DiMassa would not study odds or probabilities or pick games or place bets where he had a

mathematically higher probability of winning, but rather he bet on the long shots and placed

“hard” bets. Mr. DiMassa described these bets as bets most people would avoid, or only

place occasionally. He would make these bets almost every round. If he was “lucky” he

would continue to buy in and “ride” the win. He would lose track of time, how much money

he had on the table, and even where he had placed his chips due to the adrenaline buzz. He

never left on-top, and lost several thousand dollars every time he gambled. It would not be

unusual for Mr. DiMassa to lose $10,000 in a single day, which would have taken him

months to earn through his employment.

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In addition to casino betting, Mr. DiMassa engaged in illegal sports betting, some of

which Mr. Trassaco helped facilitate. When it came to sports betting, Mr. DiMassa first

started betting on sports that he felt he knew something about, like baseball and football.

However, he would often place those bets a week or so before the actual games, so he was

left unfulfilled, and had the compulsion to bet on other sports while waiting for the initial

bets to play-out. Due to the empty feeling of waiting on those bets to play-out, he started

betting on sports, often obscure ones, that he knew nothing about. He recalls one time

betting on a sport, which to this day he is not sure what it was, but believes that it might have

been Cricket, in the Middle East. He bet on that particular game because he (incorrectly)

believed that the game would start and end quickly and he’d get a fast result. He did not

learn until after he had placed the bet that the game of whatever sport it was, likely Cricket,

went on for several days. As his gambling addiction worsened, the bets he placed and the

types of things that he would gamble on became more absurd, as did the amount of the

wagers. For example, he found himself betting on things like what color Gatorade would be

poured on the winning coach or how long the national anthem at the super bowl would take

for the performer to complete. He would even go as far as searching YouTube for videos of

the performer singing the national anthem at a different event and believed that this gave him

some sort of edge.

Mr. DiMassa did not just bet on somewhat absurd things or sports that he did not

understand, but also engaged in parlay betting on sporting events, which involves making

multiple, individual wagers (at least two), or in Mr. DiMassa’s case, many more than two,

which are all tied together in one bet. The single bet links all of the individual wagers

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together and is dependent on all of those wagers winning together. If one of the wagers

loses, all of them are lost. For example, one could bet that the New York Giants will win by

4 and the Dallas Cowboys will lose by 8, but both things would need to happen in order to

win. Parlay betting is typically frowned upon by professional gamblers, as the more

outcomes added increase one’s chances of one, and subsequently all, of the wagers being

lost, and, relatedly, more money being lost. This manner of betting was particularly thrilling

for Mr. DiMassa.

Subsequent to his arrest his arrest, after he stopped gambling, Mr. DiMassa had the

opportunity to watch Uncut Gems, a movie starring Adam Sandler. Uncut Gems is a story

about a fictional character, Howard Ratner (played by Sandler), a Jewish-American jeweler

and gambling addict in New York City's Diamond District. Without spoiling the movie,

there is a particularly climactic scene where Sandler’s character, in the hole for over

$100,000, and at great risk to himself and his family, makes a risky three-outcome parlay bet

on a Boston Celtics game. The movie and the particular scene described, in Mr. DiMassa’s

view, accurately portrayed, to a surreal extent, the ill-advised behavior of a gambling addict

and the real-life consequences of such behavior. Watching this film as a spectator deeply

resonated with Mr. DiMassa. He very much related to the character getting involved in

ridiculous parlay bets and throwing caution to the wind in so doing. The character of

Howard Ratner was an uncannily relatable character for Mr. DiMassa. There were both

responsible and irresponsible sides to Howard Ratner, as well as Mr. DiMassa. Mr,

DiMassa, like Howard Ratner, led an average, regular life, worked a day job, and had family

to support; but outside of work and the mundane aspects of life, Mr. DiMassa, like Howard

22
Ratner, was a high risk, out of control gambler. Witnessing someone that Mr. DiMassa could

(unfortunately) relate to so well hit home and assisted him in assessing his conduct and

working towards change.

Since terminating his illegal conduct, Mr. DiMassa has confronted his gambling

problem head-on and has participated in extensive mental health treatment, for over a year

and a half, which includes one-on-one therapy. Simply accepting, genuinely and truly, that

he has a gambling addiction took a lot of work and was something that he had never done

prior to treatment. Before treatment, he had always been able to rationalize what he was

doing as a means to provide for his family, or as only using money “after his obligations

were taken care of” – money that he didn’t “need” for other things. He has a wonderful

relationship with his therapist and will continue to seek help for this problem. He feels, and

hopes that, down the road, he will be able to use his experience to help others undergoing

similar issues with addiction.

Counsel urges that additional grounds for a non-Guideline sentence are Mr.

DiMassa’s family’s needs and his personal health concerns. The impact on Mr. DiMassa and

his immediate family members from the prospect of incarceration, as well as Mr. DiMassa’s

health concerns, are proper considerations as part of the “history and characteristics” of the

defendant. 18 U.S.C. § 3553(a)(1). The additional penalties and hardships for Mr. DiMassa

as a result of conviction under these circumstances are relevant to whether the sentence is

“just”. 18 U.S.C. § 3553(2)(A).

In December 2022, Mr. DiMassa was diagnosed with testicular cancer. He was

advised that the best course was to undergo surgery and have the tumor and testicle removed.

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Pathology reports indicate that he has a seminoma, which is a slow-growing form of

testicular cancer generally found in men in their forties and fifties. While the cancer is in the

testes, it may spread to the lymph nodes. Lymph node involvement is either treated with

radiotherapy or chemotherapy. Fortunately, seminomas are sensitive to radiation treatment.

After a great deal of consideration, Mr. DiMassa opted to undergo chemotherapy in March

2023. Mr. DiMassa will need continued monitoring due to the possibility that the cancerous

tumor detected was more than a seminoma. He will need continued monitoring post-

chemotherapy, and will need to undergo additional testing six months post-treatment.

Regarding family, Mr. DiMassa has an approximately eleven-month-old son for

whom, with the assistance of his wife and mother-in-law, he is the sole caretaker. His wife,

Lauren Knox, will soon be serving a six-month prison term (in relation to the charged

offense) and is pregnant with their second child. Mr. DiMassa has two stepdaughters, Ms.

Knox’s children, ages sixteen and seventeen, who reside with Mr. DiMassa, his wife, and

mother-in-law. Mr. DiMassa, with the assistance of his wife and mother-in-law, is the sole

caretaker for his stepdaughters. His stepdaughters, like Mr. DiMassa, have grown up without

their biological father in their lives and, like Mr. DiMassa, have grown to love, and become

dependent, on their stepfather (Mr. DiMassa). Mr. DiMassa’s eleven-month-old son is cared

for mainly by Mr. DiMassa, his wife, and his mother-in-law. As Mr. DiMassa’s wife is

about to begin to serve her six-month prison sentence, Mr. DiMassa fears, should he be

sentenced to a term of imprisonment, that neither parent will be available to care for the

children for at least some, yet-to-be-determined amount of time. Mr. DiMassa feels fear and

uncertainty regarding the care of his children and stepchildren in his and his wife’s absence.

24
Prior to his arrest, and public humiliation, Mr. DiMassa enjoyed a an extremely

positive reputation throughout the greater West Haven area. His personal successes were

founded upon public service and improving the quality of life for the City of West Haven.

As noted in the attached articles and documents, Mr. DiMassa’s public fall from grace was

highly publicized. Mr. DiMassa rapidly went, in the public opinion, from an unblemished,

well-regarded public servant to a deplorable scoundrel.

Akin to the resident alien who suffers identifiably more severe penalty for a

seemingly identical offense (deportation, denial of certain institutional placement benefits),

U.S. v. Cruz-Ochoa, 85 F.3d 325 (8th Cir.1996), U.S. v. Smith, 27 F.3d 649 (D.C. Cir.1994),

the public figure faces penalties well beyond the penalty meted out by the Court and

normally experienced in the community by the average defendant. Akin to the lawyer losing

his license, Mr. DiMassa faces de facto “debarment” from public service at the state and

federal level. In other words, Mr. DiMassa has and will continue to suffer harms and

consequences atypical and beyond the norm.

West Haven is a relatively small, tight-knit community where everyone who grew up

there knows each other. Many people working and living there as adults grew up together,

went to school together and often work together in West Haven. Mr. DiMassa continues to

reside in West Haven despite his very public humiliation and vilification.

Since Mr. DiMassa’s arrest, he has been the subject of countless news stories and

articles excoriating him publicly. Simply searching “Michael Dimassa West Haven CT” on

Google yields infinite results regarding Mr. DiMassa’s criminal conduct. He even has a

Wikipedia page, which discloses that he was charged with stealing COVID-19 relief funds.

25
The following excerpt, from an article entitled Michael DiMassa’s affairs, gambling habits in

spotlight during trial is representative of the many news articles regarding Mr. DiMassa and

the offenses for which he pleaded guilty:

The personal and professional life of Michael DiMassa, a former Connecticut
lawmaker and West Haven city employee, was on full display in federal court on
Tuesday as lawyers scrutinized his finances, his gambling habits and his “sexual
escapades.”

The focus of the trial shifted quickly away from Trasacco’s alleged wrongdoing and,
instead, delved into the past actions of DiMassa, who pleaded guilty earlier this month
to three related conspiracy charges.

Trasacco’s defense team’s strategy was apparently to impeach DiMassa’s character so
jurors would have reason to question his motives and credibility while he is on the
witness stand.

The defense team avoided asking DiMassa about how he allegedly processed bogus
invoices that were submitted by two companies — JIL Sanitation Solutions and L&H
Company — which were formed and controlled by Trasacco.

The defense attorneys…spent hours Tuesday afternoon seeking to paint DiMassa, who
was elected three times to the state legislature, as a sexual philanderer and gambling
addict who was desperate for money.

The lawyers went through the three women one by one, and DiMassa acknowledged
having sexual relationships with all three of them.

CTMirror.org, A.B.// (2022) Michael DiMassa's affairs, gambling habits in spotlight during
trial, Connecticut Public. WNPR. Available at: https://www.ctpublic.org/news/2022-11-
30/michael-dimassas-affairs-gambling-habits-in-spotlight-during-trial (Accessed: April 12,
2023).
On chat forums, such as Reddit, Mr. DiMassa has been insulted and further

embarrassed publicly. Users have posted things such as, “How much of a scumbag do you

need to be to take $600k+ Covid relief funds and lose it gambling? Fuck this guy”; “What a

giant piece of shit”; “Hope this scumbag rots in prison”; “Went to high school with the guy,

26
he was man of the year in his class.” See R/Connecticut - democratic state rep Michael

Dimassa charged with stealing 600K+ in Covid relief funds. (no date) reddit. Available at:

https://www.reddit.com/r/Connecticut/comments/qdewcs/democratic_state_rep_michael_dim

assa_charged_with/ (Accessed: April 13, 2023).

Mr. DiMassa is reminded every day of his regretful actions and his status as an

outcast with whom no one wants to associate. Since his arrest nearly two years ago, the only

employment that he has been able to obtain, despite applying for jobs on a weekly basis and

providing proof to Probation of having done so, was a seasonal job, which lasted a month,

working for FedEx for $250.00 a week.

Despite his lamentable, and inexcusable actions, Mr. DiMassa is not a hardened

criminal who would, in the future, engage in criminal conduct. He is an intelligent and

hardworking individual who has a passion for his community and his family. Mr. DiMassa

has the potential, and desire to turn his regretful actions and experiences into positive ones

and would be a tremendous asset to the community capable of effectively helping and

speaking to individuals regarding the pitfalls of gambling and addiction. He has relevant life

experience, not just relating to gambling and addiction, but also in public speaking. Such a

service is more relevant than ever now that Connecticut has legalized Online sports betting –

something that Mr. DiMassa fears will lead to significant problems for many people,

especially twenty-something year-old males, in the not-too-distant future. This fear is also

shared by others. The attendant dangers of newly legalized sports betting, particularly for

young men, were recently reported on in a Newsweek article titled These Are the Real

Dangers of the Sports Betting Boom for Young Men (March 22, 2023), cited infra. Last year,

27
the American Gaming Association (AGA) estimated that 45 million Americans would bet

$3.1 billion on the NCAA Division 1 Men’s Basketball Tournament. This year, in 2023, the

AGA estimated that the tournament will attract $15.5 billion in bets from 68 million

Americans, which is over 20 million more people and five times more money than last year.

Since a Supreme Court ruling opened the door in 2018, legal sports betting has
exploded in the U.S., fueled by easy access through online apps and expensive, star-
studded ad campaigns for online sportsbooks. Some 36 states have passed laws to
allow gambling on sports, another eight are considering it and more than half of
American adults—146 million people—now live in a live, legal sports-betting
market. The result: record-breaking revenue for the betting companies, a tax windfall
for states and, many experts believe, a sharp and troubling rise in the risk of serious
gambling problems and addiction. It's a trend the experts believe may rapidly worsen,
given what is known about the trajectory of compulsive gambling and the experience
of countries that have had legal sports betting in place far longer than the U.S.

Calls to gambling helplines reflect the growing problem. In 2021 (the most recent
year for which data is available), calls to the helpline run by the National Council on
Problem Gambling, a gaming industry supported group, rose 43 percent, while texts
increased 59 percent and chats jumped 84 percent. That's troubling, but a Newsweek
analysis of the available data in every state that has legalized sports gambling since
the Supreme Court ruling shows an even more dramatic spike in pleas for help. In
Connecticut, for example, helpline calls jumped 91 percent in the first year after
legalization.

Gunn, Meghan. These Are the Real Dangers of the Sports Betting Boom for Young Men.
Newsweek. (March 22, 2023). Available at: http://www.newsweek.com. (Accessed: April 13,
2023) (emphasis added).

In 2019, in England, a country in which sports betting has been legal for some time,

the National Health Service (NHS) opened its first gambling addiction clinic for children,

which services children as young as 13 years old. See Moss, Rachel. NHS Opens First

Gambling Addiction Clinic for Children. HuffPost. (June 24, 2019). Available at:

https://www.huffingtonpost.co.uk/entry/nhs-opens-first-gambling-addiction-clinic-for-

28
children_uk_5d0ce87be4b07ae90d9c1af2. (Accessed: April 13, 2023). Mr. DiMassa would

be uniquely qualified to assist children, as well as adults, struggling with gambling issues.

Based on Mr. DiMassa’s individual characteristics, and personal growth since the

commission of the offenses, his status as a true first-time offender with a predictably low risk

of recidivism, a guideline sentence is not required to address the goals of sentencing. Mr.

DiMassa, while under pre-trial supervision and monitoring, has been able to demonstrate to

the Court the depth and breadth of his ability to move forward and thrive with community

supervision. As a defendant with a Criminal History of 0, there is a strong argument that a

non-Guidelines sentence would be a just sentence. 3

Finally, as an additional factor to consider, based upon circumstances not fully

contemplated or addressed in the Guidelines, the Court should also consider whether the

continuing effects of the Covid – 19 pandemic warrant and support further non-guideline

sentences. Mr. DiMassa, fortunately, has yet to contract the virus. Although, his mother-in-

law, with whom the family resides, is a Covid-19 survivor who suffers permanent effects of

long Covid and has an augmented risk in the event of re-infection. Many have argued before

this Court and others that one day in jail in these times is some, yet to be determined,

multiple of a day from years past. The incalculable effect of limitations of family visits,

limitations of movement within facilities, the petri dish spread of the virus within facilities

can appropriately be considered in deciding upon an appropriate sentence.

3 The May 2004 United States Sentencing Commission study found defendants who were
first offenders have lower recidivism rates. See U.S. Sentencing Comm'n, RECIDIVISM AND
THE “FIRST OFFENDER” (May 2004) at 13.

29
CONCLUSION Defendant Michael DiMassa respectfully requests a non-Guideline

sentence with appropriate conditions.

Respectfully submitted,

THE DEFENDANT
Dated: 4/13/2023 MICHAEL DIMASSA

By_/s/ John R. Gulash
John R. Gulash #05093
Gulash & Associates
P.O. Box 999
265 Golden Hill Street
Bridgeport, CT 06604
email: JRGulash@Gulashlaw.com

CERTIFICATE OF SERVICE

I hereby certify that on this date above 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/ John R. Gulash____________
John R. Gulash ct #0509

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