WHEN HE WAS ARRESTED FOR THIS CRIME ON JANUARY 9, 2013, DAVID RENZ PRESENTED AS WHAT SOME WOULD REFER

TO AS A TYPICAL RUN-OF-THE MILL CHILD PORNOGRAPHY OFFENDER.

HE HAD COLLECTED AND MAINTAINED AN ENORMOUS COLLECTION OF CHILD PORNOGRAPHY, BUT APPEARED WITH A GOOD JOB, A STABLE RESIDENCE, NO CRIMINAL RECORD, AND NO DISCERNABLE REASON OTHER THAN THE NATURE OF HIS CRIME ITSELF- FOR THE COURT, PROBATION, AND THE ATTORNEYS, TO PROVE OR FIND THAT HE WAS A RISK OF FLIGHT OR DANGER TO THE COMMUNITY. SO HE WAS RELEASED. ON STANDARD CONDITIONS.

AND THEN HE PROVED, WHAT 10 YEARS OF EXPERIENCE IN THIS PARTICULAR FIELD HAS TAUGHT ME THERE IS NO TYPICAL, NO RUN OF THE MILL CHILD PORNOGRAPHY CASE.

WITH PREMEDITATION, PLANNING, AND PRACTICE, THE DEFENDANT THWARTED THE GPS SYSTEM HE WAS ORDERED TO WEAR, AND ON THE NIGHT OF MARCH 14, 2013, DAVID RENZ CARRIED OUT A PLAN HE HAD CLEARLY SPENT TIME THINKING ABOUT, PREPARING, AND

PLANNING. AND HE COMMITTED THE MOST HORRIFIC CRIMES THIS COMMUNITY HAS SEEN IN RECENT MEMORY.

WHEN

PEOPLE

DENY

THE

CONNECTION

BETWEEN

CHILD

PORNOGRAPHY AND HANDS-ON OFFENSES, THEY SHOULD BE REMINDED THAT THE RAPE COMMITTED BY DAVID RENZ THAT NIGHT MIMICKED, TO A LARGE DEGREE, THE RAPE OF A CHILD DEPICTED IN HIS COLLECTION OF CHILD PORNOGRAPHY.

BUT WHILE THE RAPE WAS CERTAINLY A DRIVING FORCE BEHIND THE CRIMES DAVID RENZ SET OUT TO COMMIT THAT NIGHT, IT IS EQUALLY AS CERTAIN THAT HIS END GAME, HIS EXIT STRATEGY, WAS TO LEAVE NO WITNESSESS. DESPITE AMPLE MEANS AND

OPPORTUNITES TO FLEE INTO THE NIGHT ONCE HE ACCOMPLISHED THE RAPE, DAVID RENZ INSTEAD TOOK HIS VICTIMS TO A REMOTE LOCATION, WHERE, WHILE HE KILLED LORI BRESNAHAN, THE CHILD MANAGED, MIRACULOUSLY, AND WITH AN UNIMAGINABLE

AMOUNT OF INNER STRENGTH, TO ESCAPE TO THE RESCUE OF STRANGERS.

WHILE WE ARE CERTAINLY NOT HERE TO SENTENCE DAVID RENZ FOR THE CRIMES HE COMITTED ON MARCH 14TH OF LAST YEAR, THOSE CRIMES INFORM THIS SENTENCE.

WHILE THE DEFENSE POINTS TO THE DEFENDANTS APPEARANCE, CHILDHOOD DIFFICULTIES, AND ADULT ACCOMPLISHMENTS AS FACTORS THAT SET RENZ APART FROM OTHER OFFENDERS THEY DONT.

WHAT SETS DAVID RENZ APART ARE HIS ACTIONS. HE HAS PROVEN TO THIS COURT- AND TO THE COMMUNITY WHO HE REALLY IS, AND WHAT HE IS REALLY CAPABLE OF.

AND IT WAS ONLY AFTER HE COMMITTED THESE HORRIBLE CRIMES THAT WE LEARNED THAT THE MAN WHO PRESENTED AT HIS INITIAL APPEARANCE WITHOUT A CRIMINAL RECORD HAD IN FACT SEXUALLY ABUSED A CHILD BEFORE. THE ELUSIVE FAMILY COURT RECORDS, WHICH REMAIN SEALED TO THIS DAY, WOULD HAVE SHOWN AN ADJUDICATION FOR ANOTHER SEX OFFENSE.

BUT WHILE THOSE RECORDS REMAIN SEALED, THE MEMORY OF HIS VICTIM, NOW AN ADULT, REMAINS VIVID. SHE HAS COME FORWARD AND DESCRIBED A YEAR-LONG NIGHTMARE OF REPEATED SEXUAL ABUSE AT THE HANDS OF DAVID RENZ, WHO, ALONE, AND TOGETHER WITH A FRIEND, ABUSED THIS CHILD WHEN SHE WAS 8 9 YEARS OLD AND RENZ WAS 15.

IT IS ALSO SIGNIFICANT TO NOTE THAT A SEARCH OF THE DEFENDANTS RESIDENCE AFTER THE MARCH 14TH CARJACKING, MURDER AND RAPE REVEALED YET ANOTHER COLLECTION OF CHILD PORNOGRAPHY. POSSESSED WHILE ON FEDERAL

SUPERVISION.

AS NOTED IN OUR SENTENCING MEMORANDUM, ALL OF THESE FACTORS PROVIDE THE EVIDENCE NEEDED TO SUPPORT A FINDING THAT CRIMINAL HISTORY THE CATEGORY OF I SUBSTANTIALLY DEFENDANTS

UNDERREPRESENTS

SERIOUSNESS

THE

CRIMINAL HISTORY AND THE LIKELIHOOD THAT HE WILL REOFFEND. AND THE COURT SHOULD DEPART UPWARD FROM CHC I TO CHC V.

MOREOVER, THE REPEATED SEXUAL ABUSE COMMITTED BY THE DEFENDANT AT AGE 15, COUPLED WITH THE HORRIFIC AND SPECIFIC ACTS OF RAPE COMMITTED ON MARCH 14, 2013, SUPPORT AN UPWARD DEPARTURE UNDER 2G2.2, AS THE PATTERN OF ABUSE ENHANCEMENT OF 2G2.2(b)(5) DOES NOT ADEQUATELY REFLECT THE SERIOUSNESS OF THE SEXUAL ABUSE OR EXPLOITATION INVOLVED.

AND LET THE DEFENDANTS OTHER VICTIMS NOT BE FORGOTTEN. EACH AND EVERY CHILD IN EACH AND EVERY ONE OF THE DEFENDANTS 11,000 IMAGES AND 1,100 VIDEOS FOR WHICH HE STANDS CONVICTED. EVERY SINGLE ONE OF THOSE CHILDREN WAS USED BY DAVID RENZ TO FUEL HIS TWISTED INTEREST IN THE EXPLOITATION OF CHILDREN. EVERY ONE OF THEM IS ALSO HIS VICTIM.

WHILE THE DEFENSE ARGUES FOR A GUIDELINES SENTENCE AR RARE EVENT IN CHILD PORNOGRAPHY CASES THE GOVERNMENT SUBMITS THAT WHETHER ACHIEVED BY THE UPWARD DEPARTURS

REQUESTED,

OR

NON-GUIDELINES

SENTENCE

ABOVE

THE

CALCULATED RANGE, THIS DEFENDANT, FOR THIS CRIME, UNDER THESE CIRCUMSTANCES, MUST BE SENTENCED TO THE MOST TIME POSSIBLE. HERE, THAT IS A COMBINED SENTENCE THAT EQUALS A SENTNCE WITHIN THE RANGE OF 30 70 YEARS.

ADDITIONALLY, THE GOVERNMENT REQUESTS THAT THE COURT EXERCISE ITS DISCRETION AND ORDER THAT THE SENTENCE IMPOSED HERE TODAY SHALL RUN CONSECUTIVELY TO THE ANTICIPATED SENTENCE FOR THE PREDATORY SEXUAL ASSAULT AND MURDER CHARGES PENDING SENTENCE IN ONONDAGA COUNTY COURT.