Telugu serial groper and convicted felon Srinivasa Erramilli has made several interesting arguments in his bid to escape jail time and obtain probation (albeit with special conditions).
Erramilli’s novel arguments were made in his Sentencing Memorandum submitted to the U.S. District Court for the Northern District of Illinois on August 22, 2013.
(Note: We have converted the language in Erramilli’s Sentencing Memorandum filing from the third person to first person.)
Why I Should Not be Sent to Prison
1. I am a devout Hindu.
2. I have strong ethical and moral values.
3. I gave my old car to an ex-employee.
4. I am a vegetarian.
5. I am a remarkable man.
6. I have intellectual curiosity to fulfill my goals.
7. I am not afraid to roll up my sleeve.
8. I have lived a giving, caring and devout existence.
9. I am a successful businessman and my product engineering company has won contracts from large U.S. corporations.
10. I gave a laptop to my employee’s son for Christmas.
11. I gave money from my scholarship to poor friends.
12. I have made positive and lasting contributions to society.
13. I am a respected member of the Chicago Indian-American community.
14. I have selflessly dedicated myself to others throughout my life.
15. I have lot of energy and self motivation.
16. I am a community leader and regularly attend Hindu services.
17. I am deeply compassionate and earnestly believe in my obligation to helping those less fortunate than myself.
18. I am always available to help a stranger, close friend or employee in need.
19. I have already spent four month in Kenoshka County Jail (without justification on immigration-related issues).
20. I lost a lot of weight in jail because I am a vegetarian.
21. I am a good person.
22. I am a beloved employer.
23. I am a beloved community member.
24. I have done good deeds and shown selflessness all my life.
25. I am a man of integrity and humility.
26. I have built a thriving technology company in Chicago.
27. I have taken a hit to my business, losing employees and customers.
28. I am irreplaceable and my business will fail if I am sent to prison.
29. I am a man of my word.
31. I am generous and my selflessness is rare.
32. I have created goodwill through my honorable life.
33. I am undergoing religious counseling and traditional therapy.
34. I am already a sex offender and my conviction will extend the sex offender registration period by 10 years.
35. I ‘wrangled’ my friends to run marathons for charity.
36. I will likely be deported.
37. I am willing to accept intermittent or weekend imprisonment
38. I am a passionately hardworking man.
39. I am willing to accept psychiatric treatment and ongoing monitoring and counseling.
40. I have shown unusual generosity of friendship, mentorship and charity.
41. I have already suffered enough.
42. I have received bad publicity from SearchIndia.com blog over my conviction (see P.18 of Erramilli’s Sentencing Memorandum).
Srinivasa Erramilli was convicted by a Chicago jury in December 2012 for groping a fellow passenger on board a Southwest Airlines flight.
Erramilli was involved in two other in-flight groping incidents in the past.
In its Government Sentencing Memorandum response to the court on August 29, 2013, the prosecution pooh-poohed Erramilli’s arguments and asked for prison term at the top of the advisory guideline of 15-months to 21-months.
Here’s what the U.S. attorney Gary Shapiro wrote in the prosecution’s response to Erramilli’s sentencing memorandum filing:
Throughout his sentencing memorandum, defendant minimizes his criminal conduct in the present case, fails to address his repeated acts of sexual abuse committed against women, and attempts to limit his sentence by repeatedly asking the Court to consider the impact of a term of imprisonment on those around him – without noting that he apparently did not bother to consider the effect of his actions on his friends, family, and employees when he groped the victim while seated next to her on the Southwest Airlines flight to Chicago (P.6 of Government Sentencing Memorandum).
The prosecution also said Erramilli’s conduct was contrary to Hindu’s [sic] teachings (P.9 of Government Sentencing Memorandum).
An important argument the prosecution made was that an adequate sentence would act as deterrence on the general population:
By imposing a sentence of imprisonment at or near the top of the guideline range, the Court can clearly state that conduct such as the defendant’s is serious and will not be tolerated (P.13 of Government Sentencing Memorandum).
The prosecution also indirectly sided with SearchIndia.com blog on the issue of bad publicity by noting that in the light of Erramilli’s previous abusive sexual contact “additional similar conduct could result in public scrutiny” (see P.11 of Government Sentencing Memorandum).