1 

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA ) 

 ) No. 20 CR 299

 ) 

 vs. ) Judge Andrea Wood 

 ) 

HARDY BROWNER ) 

 

GOVERNMENT’S SENTENCING MEMORANDUM 

Defendant Hardy Lee Browner attempted to sexually traffick a minor female 

with whom the defendant had been having sex. Separately, the defendant lied to the 

FBI when the FBI interviewed the defendant regarding communications they1 had 

with members of ISIS, a designated Foreign Terrorist Organization. For both 

offenses, the government recommends a sentence of 292 months, at the low end of the 

advisory sentencing guidelines range of 292 to 365 months’ imprisonment. 

I. Procedural History

The defendant was originally charged in two separate indictments in the 

Northern District of Illinois. In Case No. 20 CR 299, the defendant was charged with 

knowingly and willfully making a materially false statement involving international 

terrorism in a matter within the jurisdiction of the Federal Bureau of Investigation 

(“FBI”), in violation of Title 18, United States Code, Section 1001(a)(2).

In Case No. 21 CR 302, before Judge Virginia Kendall, the defendant was 

charged with sex trafficking of a minor in violation of Title 18, United States Code, 

1 It is the government’s understanding that defendant uses the pronouns “they” and “their.”

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Section 1591(a), (b)(1), (b)(2), and (c); knowingly obstructing or interfering with the 

enforcement of the sex trafficking statute, in violation of Title 18, United States Code, 

Section 1591(d); and using a facility and means of interstate commerce to persuade 

or induce a minor under the age of 18 to engage in unlawful sexual activity, in 

violation of Title 18, United States Code, Section 2422(b).

On January 11, 2023, the defendant pleaded guilty to a two-count superseding 

information in Case No. 20 CR 299, which covered the offense conduct in both cases. 

In his plea agreement, the defendant admitted to (i) knowingly and willfully making 

a materially false statement involving international terrorism to the FBI, in violation 

of Title 18, United States Code, Section 1001(a)(2) (Count 1); and (ii) sex trafficking 

of a minor, in violation of Title 18, United States Code, Sections 18 U.S.C. 1591(a)(1), 

(b)(2) and (c) (Count 2).

The defendant’s sentencing is scheduled for October 11, 2024. The government 

will move to dismiss Case No. 21 CR 302 before Judge Kendall after sentencing in 

this case.

II. Offense Conduct and Relevant Conduct

The background facts are taken from the defendant’s plea agreement, as well 

as the exhibits submitted with the government’s version.

a. False Statements

From between on or about May 17 and July 13, 2014, the defendant used their 

Twitter account (@AhkTheBlackArab) to communicate via public tweets with Twitter 

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account @AbuFarriss. The @AbuFarriss account was used by an Islamic State 

recruiter referred to as Individual A in the indictment.2 

For example, on or about June 28, 2014, defendant wrote to @AbuFarriss: 

“someone said martyrdom attacks are forced on dawlah members saying you can’t 

say no to it is that true?” (“Dawlah” is another phrase for the Islamic State.) 

@AbuFarriss responded, “not true at all. You sign up if uu wnt to . . . Dawlah has soo 

many brothers for martyrdom ops they draw lots instead of a que or list.” That same 

day, defendant responded, “enter the truth has given a lot of people a different point 

of view.” 

On or about July 13, 2014, defendant tweeted to @AbuFarriss: “are Americans 

obliged to pledge bayyah to IS [the Islamic State or ISIS] and if so how do they do 

that when there [sic] so far from IS.” (“Bayyah” is a reference to an oath of allegiance, 

and “IS” is a reference to the Islamic State.) 

Defendant also communicated by Twitter with @Dawla_Newsmedia, which is 

a Twitter account for ISIS’s media arm and which listed, “Join the Islamic State” on 

its public account. For example, on or about May 11, 2014, defendant wrote to 

@Dawla_Newsmedia: “isn’t it hard for an american Muslim to make hijrah 

[immigrate] there?” On May 17, 2014, defendant tweeted to @Dawla_Newsmedia and 

2 According to @AbuFarriss’s profile, the user of @AbuFarriss posted his location as “Islamic 

State – Khilafa” and displayed a profile photo and background image that depicted images of 

the ISIS flag. 

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to another account that appears to be held by an ISIS sympathizer, “death will find 

you regardless better to choose a path of righteousness rather than a path of comfort.” 

The defendant created and controlled other Twitter accounts, including 

@RightlyGuidedTA, @Ahkishaykh, and @ChocalateShaykh. Defendant used those 

three Twitter accounts to make public posts and ask questions regarding, among 

other subjects, “jihad,” martyrdom, and ISIS. For example, on March 31, 2013, 

defendant tweeted using the “@RightlyguidedTA” account: “I didn’t kno self deffense 

[sic] was Terrorism! #Jihad.” On April 1, 2013, defendant tweeted: “Muslims are not 

violent people we just firmly believe in self defense! #jihad #mujahideen #khilafah.” 

Id. On April 2, 2013, defendant tweeted: “One mans Terrorist is the next mans 

Patriots #Mujahideen #Crusaders #ShariaLaw.”

The defendant’s Twitter account with moniker @ChocalateShaykh listed its 

location as “Ansar Al Islam,” which at the time was designated as a Foreign Terrorist 

Organization by the State Department. On October 26, 2014, @ChocalateShaykh 

tweeted a photograph of an ISIS fighter holding a gun, based on the flag in the 

photograph. On November 5, 2014, the defendant tweeted: “difference between 1 who 

loves life and the 1 who seeks death is the one who loves life won’t have the heart in 

battle to do the necessary.”

On July 15, 2015, FBI agents interviewed the defendant regarding their 

Twitter accounts, their communications with an ISIS recruiter, and their pro-ISIS 

Twitter postings. The defendant told FBI agents that (a) defendant did not use the 

following Twitter accounts: @AhkTheBlackArab, @RightlyGuidedTA, @Ahkishaykh, 

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and @ChocalateShaykh; and (b) defendant did not communicate with the user of the 

@AbuFarriss Twitter account and @Dawla_NewsMedia. Those were knowing lies 

about material matters relating to international terrorism.

b. Trafficking Conduct

In around January 2020, the FBI began investigating the defendant’s conduct 

related to a girl referred to as Minor A, after Minor A’s foster mother reported 

discovering Instagram messages regarding Minor A having sex with older men for 

money. 

Minor A was born in December 2005. During the summer of 2019, the 

defendant began communicating with Minor A, who was 13 at the time. The 

defendant and Minor A met in person on multiple occasions, and began having sexual 

intercourse sometime that summer. 

During some of those meetings, including in December 2019, after Minor A 

turned 14 years old and while the defendant was 32 years old, the defendant and 

Minor A continued to have vaginal and oral sex. When they saw each other, the 

defendant sometimes gave Minor A cash or other items of value. The defendant also 

asked Minor A to send the defendant videos and pictures of her naked, which she did 

on about two occasions. 

Between approximately December 16, 2019, and December 20, 2019, the 

defendant used Instagram to solicit Minor A to engage in commercial sex acts. In 

their Instagram communications, the defendant and Minor A discussed past and 

future payments from the defendant to Minor A. In those communications, the 

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defendant also discussed setting up commercial sex acts between Minor A and other 

individuals, although no such acts with other individuals ultimately took place. 

Specifically, the defendant told Minor A that “if you wanna make money I can really 

show you but u gotta be Fa real.” Minor A asked how much and the defendant replied 

“depends on what u wanna do...I’m saying I can put u on wit saling [selling] pussy.” 

The defendant stated that they could be Minor A’s “pimp” and that they could make 

money. The remainder of the conversations are included in the government’s version. 

Luckily, the defendant never succeeded in their efforts to traffick Minor A, 

although not for lack of trying. Minor A’s foster mother discovered the Instagram 

messages with the defendant, and immediately took action to contact law 

enforcement. 

III. Statutory Penalties

Count One carries a maximum sentence of 8 years’ imprisonment, because the 

investigation that gave rise to the FBI’s interview of the defendant involved a matter 

of international terrorism. Count One also carries a maximum fine of $250,000. The 

Court also may impose a term of supervised release of not more than three years. 

Count Two carries a maximum sentence of life imprisonment, and a statutory 

mandatory minimum sentence of 10 years’ imprisonment under Title 18, United 

States Code, Section 1591(b)(2). Pursuant to Title 18, United States Code, Section 

3561, defendant may not be sentenced to a term of probation on this count. Count

Two also carries a maximum fine of $250,000. With respect to Count Two, the Court 

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must impose a term of supervised release of at least five years, and up to any number 

of years, including life. 

Pursuant to Title 18, United States Code, Section 3014, the defendant will be 

assessed an additional $5,000 if the Court determines that the defendant is a nonindigent person. 

IV. Sentencing Guidelines Calculations

a. Offense Level for Count One

The base offense level for Count One is 14, pursuant to Guideline § 2J1.2(a).

Pursuant to Guideline § 2J1.2(b)(1)(C), the offense level is increased by 12 

levels because the statutory maximum term of eight years’ imprisonment applies 

since the matter relates to international terrorism.

The adjusted offense level for Count One is therefore 26. 

b. Offense Level for Count Two

The base offense level for Count Two is 30 pursuant to Guideline § 2G1.3(a)(2),

because Minor A had attained the age of 14 years but had not yet attained the age of 

18 years at the time of the offense.

Pursuant to Guideline § 2G1.3(b)(2)(B) and Application Note 3(B), the offense 

level is increased by 2 levels because the defendant unduly influenced Minor A to 

engage in prohibited sexual conduct. “Prohibited sexual conduct” includes “any sexual 

activity for which a person can be charged with a criminal offense.” Guideline § 2A3.1 

app. note 1. Where, as here, the defendant is at least ten years older than Minor A, 

there is a rebuttable presumption that defendant “unduly influenced” a minor. The 

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fact that defendant was about 18 years older than Minor A is strong indication of how 

much influence they had over Minor A. United States v. Watkins, 667 F.3d 254, 265 

(2d Cir. 2012) (noting that “given the substantial age difference between [defendant] 

and [his victim], the District Court did not err in finding that the rebuttable 

presumption was not overcome by alleged evidence of [the victim’s] ‘eagerness’ to 

participate in [defendant’s] offense”).

Pursuant to Guideline § 2G1.3(b)(3)(A), the offense level is increased by 2 levels 

because the defendant used an interactive computer service (Instagram) to patronize 

and solicit Minor A to engage in prohibited sexual conduct.

Pursuant to Guideline § 2G1.3(b)(4)(A), the offense level is increased by 2 levels 

because the offense involved the commission of a sex act or sexual conduct. “Sex act” 

and “sexual contact” are defined in 18 U.S.C § 2246(2) and (3) to include sexual 

intercourse and also the intentional touching of certain body parts. This enhancement 

is easily satisfied by the sexual encounters between the defendant and the victim.

The adjusted offense level for Count Two is therefore 36.

c. Grouping

Pursuant to Guideline §§ 3D1.3 and 3D1.4, the offenses are not grouped, but 

there is no increase to the total offense level because the offense level for Count One

is 9 or more levels lower than the offense level for Count Two. The total adjusted 

offense level is therefore 36, before the adjustments described below are applied.

d. Acceptance of Responsibility

If the government does not receive evidence in conflict with this provision, and 

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if the defendant continues to accept responsibility, a 2-level reduction in the offense 

level is appropriate under Guideline § 3E1.1(a).

An additional 1-level reduction is appropriate under Guideline § 3E1.1(b), 

provided the Court determines the offense level to be 16 or greater prior to 

determining that the defendant is entitled to a 2-level reduction for acceptance of 

responsibility, because the defendant timely notified the government of their 

intention to plead guilty. 

e. Repeat and Dangerous Sex Offender Against Minors

Pursuant to Guideline § 4B1.5(b)(1), the offense level is increased by 5 levels 

because the sex trafficking offense in Count Two is a covered sex crime, neither 

§ 4B1.1 nor subsection (a) of the Guidelines applies, and the defendant engaged in a 

pattern of activity involving prohibited sexual conduct. 

f. Criminal History Category

Based on the facts now known to the government, the defendant’s criminal 

history points equal 6 and their criminal history category is III.3 

The defendant was sentenced on or about June 23, 2006, to 40 months’ 

imprisonment as a result of the defendant’s conviction for possessing a firearm as a 

convicted person in the Superior Court of Los Angeles County, California. Pursuant 

to Guideline § 4A1.1(a), the defendant receives three criminal history points for this 

sentence. 

3 As addressed in the Pre-Sentence Report, the defendant had been convicted of multiple 

offenses when they were a juvenile. None of those offenses result in criminal history points. 

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The defendant was sentenced on or about April 28, 2010, to 16 months’ 

imprisonment as a result of the defendant’s conviction for robbery and violation of 

parole in the Superior Court of Los Angeles County, California. Pursuant to Guideline 

§ 4A1.1(a), the defendant receives three criminal history points for this sentence.

g. Anticipated Advisory Sentencing Guidelines Range

Based on the facts now known to the government, the anticipated adjusted 

total offense level is 38 which, when combined with the anticipated criminal history 

category of III, results in an anticipated advisory sentencing guidelines range of 292 

to 365 months’ imprisonment, in addition to any supervised release, fine, and 

restitution the Court may impose.

V. THE 3553(A) FACTORS

Following a calculation of the applicable Guidelines range, the Court must 

consider the application of the factors set forth in 18 U.S.C. § 3553(a). See United 

States v. Damato, 672 F.3d 832, 838 (10th Cir. 2012) (discussing review of sentences 

for “procedural reasonableness” and “substantive reasonableness”). The Court should 

consider each of the § 3553(a) factors, explain the chosen sentence, and explain any 

deviation from the Guidelines range. United States v. Shuck, 713 F.3d 563, 570 (10th 

Cir. 2013). Those factors include:

(1) the nature and circumstances of the offense and the history and 

characteristics of each defendant;

(2) the need for the sentence imposed

(A) to reflect the seriousness of the offense, to promote respect for the 

law, and to provide just punishment for the offense;

(B) the need to afford adequate deterrence to criminal conduct;

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(C) to protect the public from further crimes of the defendant; and

(D) to provide the defendant with educational or vocational training, 

medical care, or other correctional treatment in the most effective 

manner.

18 U.S.C. § 3553(a). 

Additionally, the Court must consider the kinds of sentences available, the 

range set forth by the Guidelines, any pertinent policy statements by the Sentencing 

Commission and the need to avoid unwarranted sentencing disparities. Id.

A. The Need for the Sentence Imposed to Reflect the Seriousness of the 

Offense, Promote Respect for the Law, Provide Just Punishment, 

Promote Deterrence, and Protect the Public from Further Crimes of 

the Defendant

Sex trafficking of minors is an extremely serious offense because of its

“devastating and long-term effects” on the victim and “greater society.” United States 

v. Whitley, 354 F. Supp. 3d 930, 934 (N.D. Ill. 2019) (collecting cases). Unfortunately, 

minor victims are prevalent in the sex trafficking industry. 

The defendant’s actions, which caused a 13- (and later 14-) year old girl to 

engage in sex acts with them and enticed her to engage in sex acts with strangers for 

money, have created a trauma for Minor A that is nearly impossible to imagine, 

quantify, or truly understand. It was only Minor A’s foster mother’s discovery of 

defendant’s Instagram messages, followed by the defendant’s arrest on the false 

statement charge, that stopped the defendant from fulfilling their goal. Although 

Minor A has not provided a victim impact statement, she did say that she was glad 

the defendant was arrested and her toxic relationship was able to end. She described 

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her experience with the defendant as “weird,” “cruel,” and “sad,” and feels the 

defendant manipulated her. See GVO Exh. G. 

However, the arrest of the defendant does not end Minor A’s troubles. In order 

to estimate the projected psychiatric and psychological care that Minor A will need 

in the future, the government consulted with Dr. Diana S. Goldstein, Ph.D., ABPP, 

who is the owner and Director of Neuropsychology of Isaac Ray Forensic Group, LLC. 

According to Dr. Goldstein, “Minor A struggled with mood and behavioral issues prior 

to becoming a trafficking victim, which, along with placement in multiple foster home 

environments (and feeling “lost in the system” since a young age, with unreliable 

parental involvement over many years, according to Minor A), most certainly 

increased her vulnerability to victimization.” The defendant took advantage of Minor 

A’s vulnerability. 

Minor A has been diagnosed with Post Traumatic Stress Disorder, a diagnosis 

she received in the summer of 2019, around the time she started have sex with the 

defendant. GVO Exh. I. According to Dr. Goldstein, Minor A has a complex case of 

PTSD, which “shares symptoms with PTSD but includes additional symptoms, 

including emotional difficulties (problems controlling emotions, feeling rage, 

depression, panic, or shame, and difficulty identifying and expressing emotions); 

behavioral difficulties (impulsivity, aggressiveness, sexual acting out, alcohol or drug 

abuse, self-destructive behavior, and sleep disturbance); cognitive difficulties 

(dissociation, amnesia, depersonalization, and impaired memory for state-based 

events); interpersonal difficulties (difficulty maintaining relationships, avoiding 

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friendships, or feeling connected with others); and somatization (increased medical 

problems or many visits to medical practitioners).” GVO Exh. H.

Dr. Goldstein’s brief interaction with Minor A demonstrates that these 

symptoms are not theoretical but are actualized with Minor A. Dr. Goldstein found 

Minor A’s “experience [with the defendant] was distressing and her emotional 

intensity throughout the conversation reflected anger and physiologic reactivity to 

the entire topic.” Minor A expressed anger toward the defendant and found discussing 

the situation to be extremely stressful. Minor A is now 18, and is realizing what the 

defendant did to her – something her 14 year old self could not understand. Minor A 

has had a difficult life and, although the defendant is not the cause of all her 

difficulties, they took advantage of her situation and exacerbated Minor A’s issues. A 

guideline sentence will adequately reflect the trauma they caused her that she will 

have to deal with the rest of her life. 

Deterrence and Protect the Public

Because the defendant is receiving mental health treatment which addresses 

what appears to be an underlying issue that may have caused some of the defendant’s 

conduct, the government does not anticipate the defendant being a recidivist. The 

need for specific deterrence or to protect the public, therefore, is not a compelling 

factor, however, a guideline sentence is still needed to act as a deterrence to other sex 

traffickers from targeting other minors. Because minors (and vulnerable minors in 

particular) are attracted to quick money without appreciating the consequences, a 

strong sentence is necessary to deter criminals like them. 

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The culture of impunity surrounding sex trafficking must end. If there is hope 

of deterring sex trafficking, the sentences in sex trafficking cases must be significant.

Congress has recognized this by creating stiff mandatory minimum penalties and 

significant Guideline ranges. Traffickers operating today should receive the message 

that if you traffic children in the Chicagoland area, the sentence will be severe.

Promote Respect for the Law

The sentence should also promote respect for the law. Count One—false 

statements to the FBI in a matter of international terrorism—is not the driving factor 

in the sentencing guidelines nor in the 3553 factors but that offense should not be 

ignored by the Court in determining a just sentence. That offense figures prominently 

in promoting respect for the law and is a very serious offense. 

The FBI questioned the defendant about their communications with known 

ISIS social media accounts. The FBI was looking to the defendant to assist the 

government in gathering information on ISIS for intelligence purposes, including: 

Who in ISIS did the defendant speak to? What information did they provide the 

defendant regarding routes to Syria or Iraq to join ISIS? What other Americans might 

have taken these routes? And who would assist travelers along the routes? This 

information could have proven usual to the FBI in stopping other Americans from 

providing support to ISIS. Instead of assisting the agents, the defendant

demonstrated a complete lack of respect for the law by lying to them. They denied 

ever communicating with anyone from ISIS, and they denied the social media 

accounts were theirs. The defendant disrespected law enforcement agents and sought 

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to thwart the FBI’s mission in defending against terrorist organizations. A guideline 

sentence is necessary to promote respect for the law and ensure the defendant 

complies with law enforcement in the future. 

The defendant’s public posts are also deeply troubling and violent. In those 

posts, the defendant glorified violent extremism, by describing “jihad” as a form of 

“self defense” and proclaiming “One mans Terrorist is the next mans Patriots 

#Mujahideen #Crusaders #ShariaLaw.” Although defendant was not criminally 

charged due to the substance of their postings, these deeply troubling messages—

which defendant spread publicly in an effort to publicize their support for ISIS—

cannot be ignored. 

History and Characteristics of the Defendant

The government recognizes that the defendant, like Minor A, has had family 

issues in their youth and that the defendant has had mental health issues, as 

addressed in the defendant’s expert witness report. On the other hand, the defendant, 

with their awareness and sensitivity to a poor home life, should have recognized the 

same with Minor A and the damage they could cause her through their actions. 

VI. SUPERVISED RELEASE

The government concurs with the conditions of Supervised Release 

recommended by the Probation Officer. 

VII. RESTITUTION

Pursuant to 18 U.S.C. § 3663, the Court shall order the defendant to make 

restitution to the victim of the offense. Specifically, the following provisions of 18 

U.S.C. § 3663(b)(2) require the defendant to:

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(A) pay an amount equal to the cost of necessary medical and related 

professional services and devices relating to physical, psychiatric, and 

psychological care, including nonmedical care and treatment rendered 

in accordance with a method of healing recognized by the law of the place 

of treatment;

(B) pay an amount equal to the cost of necessary physical and

occupational therapy and rehabilitation; and

(C) reimburse the victim for income lost by such victim as a result of 

such offense . . . 

As these provisions make clear, “a restitution order can include payments to 

victims of the offense for the projected cost of future mental health treatment.” United 

States v. Dickey, 52 F.4th 680, 687 (7th Cir. 2022); see also See United States v. 

Protho, 41 F.4th 812, 832 (7th Cir. 2022) (“A district court’s restitution order may 

require the defendant to pay any victim harmed by the defendant's offense the cost 

of necessary medical and related professional services for psychiatric and 

psychological care.”); United States v. Danser, 270 F.3d 451, 455 (7th Cir. 2001) (“In 

light of Congress’s intent to make whole those victims of sexual exploitation, we find 

that section 2259 allows for restitutionary damages for the future costs of therapy.”).

Restitution Request

The government is seeking restitution in the amount of $85,250 for Minor A’s 

future psychiatry and psychotherapy costs related to the defendant’s sexual assault 

and attempted trafficking.4 

4 Minor A’s previous medical expenses were paid for by the State of Illinois and are thus not 

included in this restitution request. In the event the State submits a detailed restitution 

request, the government will revise its restitution submission.

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In order to estimate the cost of projected psychiatric and psychological care 

that Minor A will need in the future, the government consulted with Dr. Goldstein, a 

licensed clinical neuropsychologist, whose report is attached to the July 25, 2024, 

Supplement to the Government’s Version of the Offense as Exhibit H. The Seventh 

Circuit has affirmed restitution awards based on Dr. Goldstein’s estimates of 

projected therapy costs for victims suffering from trauma disorders. See, e.g., Protho, 

41 F.4th at 832 (affirming restitution award of $87,770 to a kidnapping victim, based 

on future therapy cost, finding the district court properly concluded that Dr. 

Goldstein was “very well qualified in her field” and gave her testimony a “significant 

amount of weight”); Dickey, 52 F.4th at 687-88.

Dr. Goldstein provided approximate anticipated costs of future psychiatry and 

psychotherapy that Minor A will likely need as a result of this offense. This was based 

on Dr. Goldstein’s experience and training, her interview with Minor A and her 

review of Minor A’s medical records, grand jury testimony, and other materials in 

this case. 

Minor A’s medical records show that in the summer of 2019, around the time 

Minor A first met and began having a sex with the defendant, she sought medical 

treatment for various physical and psychological issues. She was admitted to a 

psychiatric hospital in June 2019, and she continued to receive psychiatric therapy 

in July and August 2019 due to a “reaction to severe stress, unspecified.” She was 

also treated for a urinary tract infection on August 16, 2019. Minor A’s psychological 

and physical condition also suffered in the year following her relationship with 

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Browner, including a stillbirth at 25 weeks’ gestation in October 2020, although 

Browner is not believed to be the biological parent. 

Dr. Goldstein opined that Minor A can be considered a sex trafficking victim, 

because “defendant Browner paid Minor A for sexual encounters and made known 

his (now her) intentions to prostitute Minor A to male friends and other male 

strangers.” Based on her conversation with Minor A, the evidence in this case, and 

the empirical literature about sex trafficking victims, Dr. Goldstein opined that 

“research robustly supports the conclusion that the mental health consequences of 

being a sex trafficking victim can include numerous disorders impacting mental 

health and behavior, including post-traumatic stress disorder (PTSD), dissociative 

symptoms, mood and anxiety disorders, substance misuse or disorders . . . and 

attention deficit/hyperactivity (ADHD) and adjustment disorders among youth.” Id. 

Dr. Goldstein added that sex trafficking victims’ “psychosocial outcomes depend on 

access to appropriate services that address their emotional, behavioral, 

interpersonal, cognitive and environmental needs.” In addition, Dr. Goldstein noted 

the “wide range of negative short- and long-term consequences, including low selfesteem, depression, suicidal ideation and suicide attempts, eating disorder, substance 

use and antisocial personality,” that are associated with girls who have sexual 

intercourse before the age of 15. 

Dr. Goldstein opined that “[t]reating CPTSD can be a life-long endeavor, 

especially for those whose traumatic experiences occur early in life.” Dr. Goldstein 

therefore anticipates that Minor A will need both psychiatry and psychotherapy 

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treatment potentially for the rest of her life based on her post-traumatic stress 

disorder. 

Dr. Goldstein detailed therapy and psychiatry costs in 2024 as follows: (1) 

Individual therapy sessions typically cost between $90 and $130 for Master’s level 

therapists and between $120 and $165 for doctoral level therapists for a 50-minutes 

session. (2) Psychiatry sessions typically cost between $75 and $150 for a 15-minute 

session.

If Minor A were to attend one therapy session per week (absent holidays) and 

one psychiatry session per month for 25 years at the average of the 2024 costs for 

those services, this would amount to a total of $170,500, based on (1) $137,500 for 

therapy ($110 x 50 x 25); and (2) $33,000 for psychiatry ($110 x 12 x 25). This is a 

conservative estimate, given that costs will rise over time and given that, at 18 years 

old, Minor A is expected to live more than 25 years. The government recognizes that 

the defendant’s conduct is likely not the sole cause of Minor A’s psychological 

challenges. Accordingly, the government requests that the defendant be ordered to 

pay half of Minor A’s anticipated psychotherapy and psychiatry costs, which is 

$85,250. 

If necessary, and if Dr. Goldstein’s conclusions are challenged, the government 

can present her testimony at a hearing. 

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VIII. CONCLUSION

The government recommends that this Court sentence the defendant to a 

guideline sentence of 292 months’ imprisonment followed by five years’ supervised 

release. 

The sentence would be sufficient, but not greater than necessary, to comply 

with the purposes set forth in 18 U.S.C. § 3553(a).

Respectfully submitted,

 MORRIS PASQUAL

Acting United States Attorney

 By: s/Barry Jonas

 BARRY JONAS

 JULIA SCHWARTZ 

 Assistant United States Attorneys

 

Dated: September 26, 2024

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