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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

UNITED STATES OF AMERICA, 

Plaintiff

HON. DAVID M. LAWSON

CASE NO.: 2:08-CR-20520 DML-MKM-2

vs.

DAVID LEE WILLIAMS

Defendant.

____________________________________/

MARK BILKOVIC

Office of the U.S. Attorney

211 W. Fort Street, Suite 2001

Detroit, MI 48226

(313) 226-9623

Fax: (313) 226-3265

Email: Mark.bilkovic@usdoj.gov

SANFORD A. SCHULMAN

Attorney for Defendant

DAVID WILLIAMS

500 Griswold Street, Ste. 2340

Detroit, MI 48226

(313) 963-4740

saschulman@comcast.net

STEFANIE LAMBERT JUNTTILA

Attorney for Defendant

DAVID WILLIAMS

500 Griswold Street, Ste. 2340

Detroit, MI 48226

(313) 963-4740

attorneystefanielambert@gmail.com

_______________________________/

Case 2:08-cr-20520-DML-MKM ECF No. 567, PageID.2004 Filed 12/07/20 Page 1 of 14
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DEFENDANT DAVID WILLIAM’S SUPPLEMENTAL MOTION FOR 

RESENTENCING AND REQUEST FOR EARLY RELEASE

Defendant, DAVID WILLIAMS (“Defendant”), by and through his

attorneys, SANFORD A. SCHULMAN and STEFANIE LAMBERT, states in 

support of his Motion for Resentencing and Request for Early Release as follows:

1. On October 1, 2008, Defendant, DAVID WILLIAMS was charged by

way of Indictment with Count One: Conspiracy to Possess with Intent to Distribute 

and to Distribute Cocaine, in violation of 21 U.S.C. §§ 846 and 841(a)(1), Count 

Two: Conspiracy to Possess with Intent to Distribute and to Distribute and to 

Distribute Cocaine Base, a.k.a. “Crack” in violation of 21 U.S.C. §§846 and 

841(a)(1), Count Six: Possession with Intent to Distribute Cocaine Base “Crack” in 

violation of 21 U.S.C. §841(a)(1), Count Seven: Possession with Intent to Distribute 

Cocaine, in violation of 21 U.S.C. §841(a)(1), Count Eight: Possession with Intent to 

Distribute Marijuana, in violation of 21 U.S.C. § 841(a)(1), Count Nine, Felon in 

Poessession of a Firearm, 18 U.S.C. § 922(g)(1), Count Twenty-Four: Conspiracy to 

Unlawfully Use a Communication Facility Commit A Drug Trafficking Offense, in 

violation of 21 U.S.C. § U.S.C. §843(b) and 846, and Count Twenty-Five, Criminal 

Forfeiture, 21 U.S.C. §853(a). (R.4, PGID -51).

Case 2:08-cr-20520-DML-MKM ECF No. 567, PageID.2005 Filed 12/07/20 Page 2 of 14
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2. On January 28, 2009, a Superseding Information was filed by the 

Government Charging Defendant with Count Twenty-Six: Conspiracy to 

Unlawfully Use of a Communication Facility to Commit A Drug Trafficking 

Offense, in violation of 21 U.S.C. §843(b) and 846, and Count Twenty-Seven: 

Criminal Forfeiture, 21 U.S.C. §853(a)(R. 141, PgID 488-510).

3. Mr. Williams pled guilty on March 11, 2009. 

4. Mr. Williams is currently house at FCI Milan with a release date of 

August 17, 2026. 

5. Mr. Williams was sentenced on June 22, 2009 by this Honorable 

Court to 240 months imprisonment on counts 1, 2, and 6; 48 months imprisonment 

on count 26, all concurrent. The court further recommended placement in a facility 

with a Comprehensive Drug Treatment Program. (R. 276, PgID 872-877).

6. If released, Mr. Williams is supported by family, plans to live with his 

mother and stepfather, and will work for Benjamin Bryan Concrete, which is 

owned by his family. 

7. Mr. Williams has numerous health conditions that make him high risk 

according to the CDC guidelines, and COVID-19. Mr. Williams has an extremely 

high Body Mass Index weighing over 400 pounds. Additionally, Mr. Williams has 

diabetes, and hypertension. 

Case 2:08-cr-20520-DML-MKM ECF No. 567, PageID.2006 Filed 12/07/20 Page 3 of 14
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10. Mr. Williams exhausted his administrative remedies by making a 

request for home confinement, and the warden denied his request on July 20, 2020. 

(Exhibit 1). 

11. As the parties are aware the COVID-19 virus has become a pandemic 

in the United States and throughout the world. 

12. Although death and serious illness can strike anybody, it appears 

from new reports that COVID-19 is much more lethal. 

14. Mr. Williams makes this application knowing that the crime he 

committed was serious. He understands that a substantial term of incarceration was 

appropriate. In light of this unprecedented change in circumstances, we 

respectfully request that the Court exercise its power to modify Mr. Williams’ 

sentence and direct that he be released to home confinement to serve the remainder 

of his sentence, and allow him to work and seek medical treatment as needed. 

15. Pursuant to local rule 7.1, Mr. Williams, through counsel, sought 

concurrence from Assistant United States Attorney, Mark Bilkovic, and the 

Government intends to oppose the relief sought by Mr. Williams. Attorney 

Bilkovic stated that he would have communicated the Government’s intent to 

oppose Mr. Williams Motion for Resentencing had Mr. Williams sought 

concurrence prior to filing his motion. 

Case 2:08-cr-20520-DML-MKM ECF No. 567, PageID.2007 Filed 12/07/20 Page 4 of 14
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WHEREFORE, Defendant respectfully requests that this Court to enter an 

order resentencing Defendant Williams to early release from Federal Prison for the 

reason so stated herein. 

Respectfully submitted,

/s/ Sanford A. Schulman

SANFORD A. SCHULMAN P-43230

Attorney for Defendant 

DAVID WILLIAMS

500 Griswold Street, Suite 2340

Detroit, Michigan 48226

(313) 963-4740

saschulman@comcast.net

/s/ Stefanie Lambert Junttila

Stefanie Lambert Junttila P-71303

Attorney for Defendant 

DAVID WILLIAMS

500 Griswold Street, Ste 2340

Detroit, MI 48226

(313) 963-4740

attorneystefanielambert@gmail.com

Date: December 7, 2020

Case 2:08-cr-20520-DML-MKM ECF No. 567, PageID.2008 Filed 12/07/20 Page 5 of 14
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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

UNITED STATES OF AMERICA, 

Plaintiff

HON. DAVID M. LAWSON

CASE NO.: 2:08-CR-20520-DML-MKM-2

vs.

DAVID LEE WILLIAMS

Defendant.

____________________________________/

MARK BILKOVIC

Office of the U.S. Attorney

211 W. Fort Street, Suite 2001

Detroit, MI 48226

(313) 226-9623

Fax: (313) 226-3265

Email: Mark.bilkovic@usdoj.gov

SANFORD A. SCHULMAN

Attorney for Defendant

DAVID WILLIAMS

500 Griswold Street, Ste. 2340

Detroit, MI 48226

(313) 963-4740

saschulman@comcast.net

STEFANIE LAMBERT JUNTTILA

Attorney for Defendant

DAVID WILLIAMS

500 Griswold Street, Ste. 2340

Detroit, MI 48226

(313) 963-4740

attorneystefanielambert@gmail.com

_______________________________/

Case 2:08-cr-20520-DML-MKM ECF No. 567, PageID.2009 Filed 12/07/20 Page 6 of 14
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BRIEF IN SUPPORT OF DEFENDANT, DAVID WILLIAMS’ 

SUPPLEMENTAL MOTION FOR RESENTENCING AND REQUEST FOR 

EARLY RELEASE

NOW COMES the Defendant DAVID WILLIAMS, by and through his

attorneys, SANFORD A. SCHULMAN, and STEFANIE L. LAMBERT, and state 

in support of his Brief in Support of his Renewed Motion to Resentence Defendant 

and Request for Early Release as follows:

I. Should this Honorable Court resentence DAVID WILLIAMS and release

him early from his prison sentence because he has serious health 

conditions in light of the current pandemic?

Defendant answers. “Yes.”

Plaintiff answers. “No.”

STATEMENT OF FACTS 

Mr. Williams was charged with Count One: Conspiracy to Possess with Intent 

to Distribute and to Distribute Cocaine, in violation of 21 U.S.C. §§ 846 and 

841(a)(1), Count Two: Conspiracy to Possess with Intent to Distribute and to 

Distribute and to Distribute Cocaine Base, a.k.a. “Crack”) in violation of 21 U.S.C. 

§§846 and 841(a)(1), Count Six: Possession with Intent to Distribute Cocaine Base 

“Crack” in violation of 21 U.S.C. §841(a)(1), Count Seven: Possession with Intent to 

Case 2:08-cr-20520-DML-MKM ECF No. 567, PageID.2010 Filed 12/07/20 Page 7 of 14
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Distribute Cocaine, in violation of 21 U.S.C. §841(a)(1), Count Eight: Possession 

with Intent to Distribute Marijuana, in violation of 21 U.S.C. § 841(a)(1), Count 

Nine, Felon in Possession of a Firearm, 18 U.S.C. § 922(g)(1), Count Twenty-Four: 

Conspiracy to Unlawfully Use a Communication Facility Commit A Drug 

Trafficking Offense, in violation of 21 U.S.C. § U.S.C. §843(b) and 846, and Count 

Twenty-Five, Criminal Forfeiture, 21 U.S.C. §853(a). (R.4, PGID -51). On January 

28, 2009, a Superseding Information was filed by the Government Charging 

Defendant with Count Twenty-Six: Conspiracy to Unlawfully Use of a 

Communication Facility to Commit A Drug Trafficking Offense, in violation of 21 

U.S.C. §843(b) and 846, and Count Twenty-Seven: Criminal Forfeiture, 21 U.S.C. 

§853(a)(R. 141, PgID 488-510). Mr. Williams pled guilty on March 11, 2009, and 

Mr. Williams was sentenced on June 22, 2009 by this Honorable Court to 240 

months imprisonment on counts 1, 2, and 6; 48 months imprisonment on count 26, 

all concurrent. The court further recommended placement in a facility with a 

Comprehensive Drug Treatment Program. (R. 276, PgID 872-877).

Mr. Williams is currently housed at FCI Milan with a release date of August 

17, 2026. 

Ms. Williams current conditions of confinement are putting his health at 

risk, and he seeks immediate release from confinement as a result of here being no 

conditions of confinement sufficient to prevent irreparable injury. Mr. Williams 

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has numerous health concerns including a high body mass index and he weighs 

over 400 pounds, prediabetes or diabetes, and hypertension. 

ARGUMENT

Under the First Step Act, Mr. Williams is eligible for reduced sentence and 

this Court can act sua sponte to adjust downwards Mr. Williams imposed sentence 

so that he is eligible for supervised release.

In addition, the public health recommendation is to release high-risk people 

from detention, given the heightened risks to their health and safety (ECF No. 6-1, 

PgID 87 (Declaration of Infectious Disease Epidemiologist Joseph Amon)). The 

only way to prevent serious illness including death is to release all people with low 

risk factors. 

The Center for Disease Control provided an update on November 2, 2020. 

Mr. Williams a high body mass index. Mr. Williams weighs over 400 pounds. The 

Center for Disease Control has identified a high body mass index to be an 

underlying medical condition that is at an increased risk for severe illness from the 

virus that causes COVID-19. Additionally, Mr. Williams has diabetes or 

prediabetes, with hypertension. The CDC identifies these medical conditions as 

conditions that might be at an increased risk from the virus that causes COVID-19. 

Certain Medical Conditions and Risk for Severe COVID-19 Illness |CDC, 

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November 2, 2020, https://www.cdc.gov/coronavirus/2019-ncov/need-extraprecautions/people-with-medical-conditions.html.

Mr. Williams is housed at Milan Correctional Facility in Milan, Michigan. 

The number of COVID-19 cases in the federal prisons are extremely high as of 

October 14, 2020. There are currently 1,652 federal inmates and over 700 BOP 

staff members positive with COVID-19. COVID-19 Cases, October 14, 2020, 

https://www.bop.gov/coronavirus/. This demonstrates that the Bureau of Prisons 

policies and procedures to address COVID-19 simply are not working.

A well-known medical professional, Dr. Greifingert stated that the only way 

to “prevent serious illness including death” in ICE facilities is to “release all people 

with risk factors.” (ECF NO. 20-3, PageID.374 (Declaration of Dr. Robert B. 

Greifingert). Same can be said about Milan. 

On March 23, 2020, the Center for Disease Control and Prevention (CDC) 

acknowledged that correctional and detention facilities “present unique challenges 

for control of COVID-19 transmission among incarcerated/detained persons, staff 

and visitors.” Interim Guidance on Management of Coronavirus Disease 2019

(COVID-19) in Correctional and Detention Facilities, Centers for Disease Control 

(Mar. 23, 2020), https://www.cdc.gov/coronavirus/2019-

ncov/community/correctiondetention/guidance-correctionaldetention.html.[Hereinafter”CDC Guidance 3/23/2020”].

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Specifically, the CDC has noted that many detention conditions create a 

heightened risk of danger to its inmates. Risks include low capacity for patient 

volume, insufficient quarantine space, insufficient on-site medical staff, highly 

congretional environments, inability of most patients to leave the facility, and 

limited ability of incarcerated/detained persons to exercise effective disease 

prevention measures (e.g., social distancing and frequent handwashing). Id. 

The only adequate relief for Mr. Williams is to release him from 

confinement at FCI Milan. Social distancing, hygiene measures and proper diet are 

Mr. Williams only defense against COVID-19. These protective measures are 

exceedingly difficult at, if FCI Milan if not impossible. Mr. Williams shares toilets, 

sinks, phones, showers, and eats in communal spaces. He is in frequent, close 

contact with other inmates, and officers. 

No matter what steps are taken at FCI Milan, Mr. Williams is constantly at 

risk of contracting COVID-19 during this pandemic. Absent an early release by 

this Court, Mr. Williams has a high likelihood of irreparable harm in the form of 

loss of health or life should he contract COVID-19, if he has not already. 

New data has confirmed that it is possible to contract COVID-19 multiple 

times, and that people reinfected with the disease had more severe symptoms the 

second time. Two different medical journals noted cases of reinfection where low 

oxygen levels and patients requiring oxygen were symptoms of a second 

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reinfection of COVID-19, Researchers Confident it was Reinfection, Not a 

Relapse, October 13, 2020, https://www.clickondetroit.com/health/goodhealth/2020/10/13/reports-2-people-reinfected-with-covid-19-had-more-severesymptoms-the-second-time/. 

The United States Attorney General has issued a directive to consider early 

release for detainees who do not pose a public safety risk, as minimizing crowded 

populations is the only known way to mitigate spread of this pandemic. 

Prioritization of Home Confinement as Appropriate in Response to COVID-19 

Pandemic, Atty Gen. (Mar. 26, 2020); Executive Order, No. 2020-29 (COVID-19) 

(Mar.26, 2020). We respectfully request that Mr. Williams is released to home 

confinement to live with his family, work, and seek medical treatment as needed 

from his doctors, and local hospitals. 

CONCLUSION

Ms. Williams current living conditions are putting his health at risk, and 

home confinement is a safer setting for him with his health conditions. Mr. 

Williams continued confinement at FCI Milan exposes him to greater symptoms of 

COVID-19 and possible death due to his underlying conditions. 

WHEREFORE, Mr. Williams, by and through his attorneys, SANFORD A.

SCHULMAN and STEFANIE LAMBERT, respectfully requests this Honorable 

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Court to enter an order resentencing DAVID WILLIAMS to early release from 

federal prisons for the reasons so stated herein. 

Respectfully submitted,

/s/ Sanford A. Schulman

SANFORD A. SCHULMAN P-43230

Attorney for Defendant 

500 Griswold Street, Suite 2340

Detroit, Michigan 48226

(313) 963-4740

saschulman@comcast.net

/s/ Stefanie Lambert Junttila

Federal Criminal Attorneys of Michigan

Stefanie Lambert Junttila P71303

Attorneys for Defendant

500 Griswold Street, Suite 2340

Detroit, MI 48226

December 7, 2020

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Certificate of Service

I, Stefanie Lambert Junttila, attorney at law, certify that on December 7, 

2020, I caused a copy of this pleading to be served upon the Clerk of the Court and 

Government via E-file. 

/s/ Stefanie Lambert Junttila

Stefanie Lambert Junttila (P71303)

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