SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK: PART 31 = ———— x THE PEOPLE OF THE STATE OF NEW YORK =: SCI. NO.: 4632/2010 ~Against- ALAN HEVESI, Defendant ALAN Hi SIMON & PARTNERS LLP 551 Fifth Avenue New York, New York 10176 Tel: (212) 332-8900 Fax: (212) 332-8909 Attorneys for Defendant Alan HevesiPage(s) INTRODUCTION 1 I. ALAN HEVESI’S PERSONAL LIFE HISTORY 1 A. Family Background and Personal History 2 B. Alan’s Political Career 4 1. New York State Assembly 5 2. New York City Comptroller 7 3. New York State Comptroller uw 4, Alan Was a Dedicated Politician Committed to Social Justice and Reform 13 I. THE INSTANT OFFE! 1s A. Hevesi’s Relationship with Hank Morris 19 B. The CRF Prospered During Alan’s Tenure as State Comptroller 20 C. Alan Has Taken Full Responsibility For His Actions and Has Expressed Genuine Remorse 2 Ill. ALAN’S COOPERATION WITH THE ATTORNEY G IV. CAROL HEVESI HEALTH AND ALAN’S PRIOR CONVICTION 24 V. ALAN HEVESI’S MEDICAL CONDITION 27 VI. ALAN HAS ALREADY BEEN PUNISHED SEVERELY 29 FOR HIS CRIME CONCLUSION 33INTRODUCTION ‘The objective of this memorandum is to provide information that will enable the Court to more fully understand Mr. Hevesi’s life in its totality; his career, his family, his triumphs, tragedies and mistakes, Our objective is not to minimize Mr. Hevesi’s offense, but to place the context of his entire life and to assist the court in determining a just sentence. As the esteemed United States District Judge, Jed S, Rakoff, has eloquently explained: {Slurely, if ever a man is to receive credit for the good he has done, and his immediate misconduct assessed in the context of his overall life hitherto, it should be at the moment of his sentencing, when his very future hangs in the balance. This clementary principle of weighing the good with the bad ... is basic to all the great religions, moral philosophies, and systems of justice USS. v. Adelson, 441 F Supp.2d 506, 513-514 (S.D.N.Y 2006)(emphasis added). Based on the totality of his life, we believe that Alan deserves considerable credit for the enormous good he has done for society, which should weigh heavily in favor of a lenient sentence, despite his misdeeds. 1. ALAN HEVESI’S PERSONAL LIFE HISTORY Family members, friends, colleagues and constituents have submitted letters to the court on Mr. Hevesi’s behalf. These letters are evidence of Mr, Hevesi’s good character and demonstrate all he has done for individuals and organizations within the community over his lifetime. Some also detail the considerable medical and health issues of both Mr. Hevesi and his wife, Some of these letters are excerpted herein, while others are not. We respectfully urge the Court to read and consider each one of these letters, which uniformly portray Alan Hevesi as an extraordinary family man, friend, teacher, activist and politician who has selflessly done astonishing things for his community. The following letters are attached hereto: