MASSIE et al v. GOVERNMENT OF THE DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA

Filing 260

MASSIE et al v. GOVERNMENT OF THE DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA

Doc. 260

UN ITE D STATES DISTRICT COURT FO R THE DISTRICT OF COLUMBIA

UN ITE D STATES OF AMERICA, P la intiff , v. P A TR IC IA BUCCELLO, D e fe nd a nt. _________________________________

) ) ) ) ) Docket No: CR-07-517M-01 ) ) Hon. Deborah A. Robinson ) United States Magistrate Judge )

D E FE N D A N T'S SENTENCING MEMORANDUM D e fe nd a nt, by and through undersigned counsel of record, hereby files electronically th e letter that was hand delivered to the Court on January 18, 2008, without the a c c o m p a nying attachments:

J a nua ry 18, 2008

H o no ra ble Deborah A. Robinson M a g is tra te Judge U.S . District Court for the District of Columbia 3 0 0 Constitution Avenue, NW W a s h ing to n, DC 20001

R e : United States v. Patricia Buccello Docket No. 07-517M-01 D e a r Judge Robinson: This letter is being written in anticipation of the sentencing of my client, Patricia B uc c e llo , which is set on your calendar for next Wednesday, January 23, 2008 and
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Dockets.Justia.com

s up p le m e nts the Defendant's position as set forth in the pre-sentence report. Ms. Buccello has pled guilty to a one count information charging her with Theft of P ublic Money (Misdemeanor) in violation of 18 USC §641. As set forth in the pre-sentence re p o rt, the total offense level is 8, and since the defendant has no prior convictions, an a d vis o ry guideline imprisonment range is from 0 to 6 months. This letter, together with the accompanying attachments, is being written in the hope th a t you will determine, based on Ms. Buccello's lack of prior criminal record and lifetime o f commitment to serving the community, that imprisonment would not be appropriate in th is matter and that therefore the lower range of the sentencing guideline, 0 months im p ris o nm e nt, is appropriate in this case. 1. The Plea Agreement Initia lly, Ms. Buccello would note that she has complied with all the conditions of the plea agreement. She has resigned from her position as SAC with the National Park S ervice , and has retired from the Federal Government after a long and distinguished career. In fact, she was forced to take an early retirement, which has had a significant financial im p a c t not only on herself, but also on her family, both now and in the future. She has also p a id the special assessment of $25 owed in the case prior to her sentencing. She has further m ad e full restitution payment totaling $10,864.95 to the Department of the Interior, of w h ic h only a portion is related to the charge in the information, pursuant to the terms of the a g re e me nt. Additionally, she has agreed never to apply for or accept a law enforcement job in the future, and can never apply for retired law enforcement credentials. Moreover, she has taken other steps not specifically set forth in the plea agreement but agreed to by the parties. Specifically, she has relinquished all of the Marriott Points th a t were credited to her personal account and which were associated with some of her p e rs o na l credit card activity, and has agreed to donate them to charity. She has taken full responsibility for her criminal actions, and has even agreed to go abo ve and beyond that admission and repay to the federal government amounts that are c le a rly not related criminal conduct, but would ordinarily have been handled a d m inis tra tive ly by an adverse personnel action. 2. The Offense Th e offense, a misdemeanor, to which the defendant has pled guilty, is set forth in th e government's proffer and is reiterated in the pre sentence investigation report. It is
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d ivid e d up in to two segments, "Failure to Perform Duties", and "Fraudulently Billed Tra ve l." Ms. Buccello would assert that if the fraudulently billed travel segment of the c h a rg e s had not occurred, that this matter would not have been handled by a criminal p ro s e c utio n, and therefore, the court should not consider the "failure to perform duties" as c rim ina l conduct. There is no actual intentional theft implicit in those allegations. In fact the a lleg a tio ns contained in that section seek to cast Ms. Buccello as a negligent employee is co ntrary to the weight of the evidence regarding her federal career. In support of Ms. Buccello we have provided numerous letters from co-workers and fo rm e r supervisors demonstrating that Ms. Buccello is a diligent, innovative, and extremely h a rd working federal employee who was simply overwhelmed by the hardship of being s e p a ra te d from her husband while simultaneously working in Washington, living in Maine, a nd traveling extensively throughout the country for the National Park Service. Importantly, regarding the allegations contained in the "Failure to Perform Duties" s e c tio n of the charge, as noted at the time of the actual plea soliloquy, Ms. Buccello never o bta ine d a "free airplane ticket" for her own use. If she were awarded a free travel ticket by the airline, she turned it over to the government and never, as implied, attempted to convert it to her own use. The government agreed with this statement at the time of the plea. Additionally, the failure to perform duties charge specifically denotes Ms. B uc c ello 's failure to attend a particular non-governmental ceremony in Jacksonville, Flo rid a on March 23, 2007 and her failure to provide a fatality report to a widow in St. L o uis on July 10, 2006. Both of these incidents centered on the same deceased National P a rk Service employee, and in regard to this particular officer's death, the government has a tte mp te d to paint Ms. Buccello as a callous and uncaring individual. This is not supported by the record of her entire law enforcement career, as the attached letters from numerous s urviving families and co workers attest. The letters and show of support demonstrate that M s . Buccello was a leader, not only among the National Park Service, but among all D e p a rtm e nt of Interior Agencies, in establishing programs to care for employees and g r ie ving surviving families and co-workers. Th e defendant would point out that the death of this particular agent was unique and p re se nte d a very specific situation, which we will explain orally at sentencing, and although s h e does not seek to excuse her conduct, we would stress that it is not criminal and should no t be considered as criminal conduct by the court in support of sentencing. Second, addressing the "Fraudulently Billed Personal Travel," Ms. Buccello has re a d ily admitted to this personal lapse of judgment and mistake, and although she does not s e e k to excuse this conduct before the court, she can try to explain this aberration in
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be h a vio r from years of dedicated and stellar government and community service. During the time frame relevant to this case, Ms. Buccello was stationed in Maine a nd was authorized to conduct the duties of National SAC and Medical Standards Program M a na g e r from her home base in Bar Harbor Maine, where her husband David, also a fe d e ra l employee, is the Chief Park Ranger of Acadia National Park. For a number of years she had been authorized to travel between Bar Harbor and W a s h ing to n, D.C. as agreed to by the NPS when she accepted the dual positions, both of w h ich had significant responsibilities. She admits that she knew this changed in February 2005. Ms. Buccello would note that the first time that the personal travel was billed to her g o ve rnm e nt issued credit card was an absolute mistake, she processed the wrong credit c a rd when buying her ticket. Additionally, the majority of the 9 trips mentioned in this s p e c ific a tio n, which occurred from April 2005 through February 2007 consist of travel c h a ng e s charged to her government issued card, not original purchases. The underlying tic k e t had been bought with her personal credit card and never charged to the government. Th e changes to the already purchased tickets were almost uniformly made when she had to c h a ng e her travel plans over a weekend due to duties that had unexpectedly come up at w o rk and kept her from keeping already made reservations. Therefore, she admits that she m is ta k e nly and improperly considered these changes to be work related at the time she m a d e them, thereby charging them to the government. She admits that this was wrong, and h a s made full restitution to the Department of the Interior, not only for the fraudulently bille d travel, but also for the other matters unrelated to the fraudulently billed travel. Moreover, the trips should also be considered in context. During this time period s h e traveled to Bar Harbor at a minimum of twice per month-- often more frequently than th a t. In all that time over a two year period, this amounted to dozens of trips, yet only nine trip s include possible changes to travel and in a much smaller number of instances tickets th a t were charged to the government. However, this doesn't excuse this conduct. Ms. Buccello is truly remorseful for th is indiscretion, has made full restitution and realizes and has owned up to her mistake, she is not claiming innocence, and has not forced the government to prove all the elements of th e offense against her.

3. Support from the Law Enforcement and Paramedic Community and M s . B uc c ello 's Record as a Federal Employee
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M s . Buccello is providing the court with numerous letters from law enforcement p r o f e ss io na ls , supervisors and co-workers who have known Ms. Buccello both as a p a ra m e d ic and throughout her federal service career and who support her in this difficult tim e . Following are portions and representative highlights of the attached letters of support for Ms. Buccello: Judith Stolfo. Administrative Law Judge. Social Security Administration. Former Senior Attorney for Dept. Interior. "Pat helped create a program to set up Medical Standards Program for Law Enforcement Pe r s o n n e l and firefighters in the Dept. Interior... Her service to the National Park S e rv ic e spared the Department of the Interior millions of dollars in legal liability...Her s e rv ic e , but for this incident, has been superlative." She knows of the travel strains on Pat a n d indicates that the move to DC was unjustified but that Pat did not complain. Vicki Minor, Executive Director, Wildland Firefighter Foundation, a non-profit that takes c a re of fallen or injured wildland firefighters and their families. She has worked well Pat for several years, stating "Her (Pat's) abilities in helping the fa m ily heal have been the best in the business. She showed sincere compassion and c o n c e rn ... If I could appeal to the court for justice for Pat, it would be to go lightly on this wo m a n who has given so much to so many in their darkest hours." Jack Harris M.Ed. Licensed professional counselor, advisor to numerous state and Federal la w enforcement Critical Incident Stress Management Programs. "I have worked with Pat during some very traumatic times, where employees, coworkers, fa m ilie s and visitors were exposed to significant trauma and stress. She worked tirelessly with Park employees and their families...after Hurricane Marilyn, in New York City after 9 1 1 , with families of deceased employees...(including) an NPS ranger who was m u r d e r e d ... A g a in and again I watched Pat go above and beyond to help other people. Her unselfish compassion, dedication and commitment to people in their time of need m a d e a difference to and had a significantly positive impact on many peoples' lives." Glen R. Anderson. Law Enforcement Specialist, Lake Mead, NV. Longtime friend and c o lle a g ue .
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" E ith e r Pat or I have coordinated and directed all of the line of duty death services since 1 9 9 0 ... e n s u r in g that the final remembrances of employees lost in the line of duty were c o n d u c ted in a dignified manner that honored their services. Pat worked diligently with th e National Park Service... and the Department of Justice ensuring that anyone who was e n title d to benefits would receive them...Pat made certain (that fallen employees were) p r o p e r ly memorialized...Were it not for her diligent work in this matter, those who made th e ultimate sacrifice would remain forgotten." Tamm y Keller. Law Enforcement Park Ranger, Federal Law Enforcement Training Center. " S h e was known to even go beyond what good Rangers do at personal expense. Extra h o u r s , taking leadership roles, mentoring Rangers, CISM (Critical Incident Stress M a n a g e m e n t) development and training, EMS training, and participating in her c o m m u n ity as a Paramedic as well as a Paramedic for the National Park Service. I could fill an entire letter with the extra work Pat has done for the National Park Service...Pat a ss iste d me and other Rangers in tragedies ranging from being involved in extremely d a n g e ro u s rescues or recoveries to losing a co-worker to a murderous sniper...personal lo s s e s in natural disasters to losing a co-worker to suicide...I believe the CISM program h a s been instrumental in saving many valuable employees from career ending stress re la ted problems...Pat is personally responsible for much of the success of this p r o g r a m ... I watched Pat cry with, laugh with, and hold the hands of Mothers and Fa th e rs , Sisters and Brothers of fallen Rangers. Pat gave pieces of herself to everyone s h e touched and everyone was a better person for it." Ke n Phillips. Chief of Emergency Services, Grand Canyon National Park, Law E nfo rc e m e nt Park Ranger. "Pat's record as a public employee entrusted with law enforcement duties...over three d e c a d e s has been stellar...(Pat) was working in a high volume law enforcement patrol o p e ra tio n ... a n d was also directly involved in many complex rescues and large-scale e m e rg e n c y incidents...There are countless numbers of park visitors who were aided by Pa t's direct actions and effective decisions at Grand Canyon. Pat's positive impact on the p u b lic and her fellow rangers did not stop when she left Grand Canyon...(she became) d ire c tly involved in the development of the (CISM)program...I have personally known r a n g e rs who quit working law enforcement, prior to the CISM program, due to the impact o f the work stress on their personal lives...I can only assure you that this program has s p a r e d many rangers personal suffering...I request that you review Pat's personal p e rfo r m a n c e and commitment toward law enforcement. The way in which the National
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Pa r k Service has chosen to terminate her for this improper act, without any effort made to wa rd rehabilitation, causes one to wonder about the motives of the agency. I believe in b e in g able to forgive someone." Te rr ie Fajardo, Chief, Human Resource Operations (retired), NPS Washington, DC. " M s . Buccello's dedication to her position and to her fellow law enforcement staff proved to be the difference in meeting both the needs of the Agency and the needs of the in d iv id u a l... It took a leader with the humanity to know how difficult the ultimate decision wa s to accept and the strength to help each person find a way to accept this drastic c h a n g e ... s h e (Pat) met my every expectation as a leader and as a person."

C urt Sauer, Superintendent, Joshua Tree National Park, CA. " ... I relied on her...during and after high stress/traumatic rescues involving fatalities a n d serious injuries...our park experienced the tragic death of five rescuers due to a helije t crash...(Pat) arranged for full support of my personnel during the following week of in c id e n t debriefing...I do know that for over twenty five years, (Pat) is a person who I c o u ld count on, and have counted on in stressful and emotional times. I know of many r a n g e r s and other NPS employees who have benefited from her support and tireless, b e h in d the scenes actions. I know (Pat) to be of the highest caliber as a person and e m p lo y e e of the National Park Service." R alp h Moore, Superintendent, Katmai National Park, AK. Former law enforcement ranger. " I have known Pat for 25 years...She has always been an excellent example of p r o f e ss io n a l is m , dedication, commitment, conscientiousness, and compassion." Mr. M o o r e joined the CISM program at Pat's encouragement responding to an employee m u r d e r in Yosemite, the Space Shuttle Columbia tragedy, and Hurricane Katrina among o t h e r s... "In all these incidents, we succeeded because Pat had trained us well, because s h e was committed to doing whatever it took to get the job done, and she sincerely cared a b o u t the survivors and those assisting them...Her legacy is a good one, and many NPS e m p lo y e e s who would have burnt out or would have succumbed to too much stress in th e ir jobs and left the agency are still with it today because of the outstanding work she h a s done for us." J o s e p h Evans, Chief Park Ranger (retired), Rocky Mountain National Park, CO.
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" W h ile the current circumstances are not desirable for her, they do not detract from what I know of Ms. Buccello and what she has meant to the National Park Service....I p e rs o n a lly witnessed the value of (the CISM program) on the well being of emotionally str e ss e d staff. Ms. Buccello was a driving force behind this program. Ms. Buccello b e c a m e ... r e sp o n s ib le for implementing (the medical standards program) across the a g e n c y . She brought compassion and common sense... (she) deserves considerable credit fo r developing...procedures to manage and improve the health of hundreds of Law E n fo r c e m e n t Park Rangers." R o be rt Stinson, Law Enforcement Park Ranger, Saguaro National Park, AZ. " Pa t has proven to be a hardworking and dedicated employee to the National Park S e rv ic e who made significant contributions to the emergency medical services, critical in c id e n t stress program, medical program, and law enforcement fields over the course of h e r extensive career...One instance of her outstanding work include(s) her leadership ro le in the aftermath of the murder of U.S. Park Ranger Kris Eggle in the line of duty...in wh i c h Pat was involved in all aspects...including critical incident stress debriefings, p la n n in g of memorial services as well as the criminal investigation...another instance of Pa t's exceptional efforts was in the ...medical standards program in which Pat's le a d e rs h ip and management of the program has led it to (be) an important and vital p r o g r a m for (employees) performing public safety functions." L a nny Wagner, Bureau of Land Management Law Enforcement Ranger, New Mexico. " ( Pa t) was one of the safest officers I worked with and I credit my survival in this career o f 25+ years as a federal law enforcement officer...to the skills I learned from Pat. Pat c a re d so much for her employees that she would often take the lead on many dangerous d u tie s so that if anything did happen, others would have the chance to escape. As an e m e rg e n c y medial professional I learned from Pat that no matter who the patient is they d e se rv e the same level of care. Everyone no matter of economic background, country of o rig in , or even if they were a suspect got the same quality of treatment...(I) have seen in p e rs o n Pat's ability as a paramedic to save peoples lives...I would gladly go through any d o o r on any mission with Pat. She is a leader with integrity and honesty and someone wh o I believe is one of the good people in this world!" Ka re n Frauson, Law Enforcement District Ranger, Grand Teton National Park, WY. " Pa t is a true advocate for victims and survivors...(having) worked closely with Pat on a
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fu ll ranger of incidents from many death notifications, extended searches, employee s u ic id e s and line of duty deaths...Pat has a wonderful ability...to empathize with victims o f crime...natural disasters, families of suicide victims...and personnel killed in the line o f duty...(she) has helped hundreds and hundreds of people...right after the terrorist acts o f 911..She coordinated a huge effort that involved CISM personnel throughout the c o u n tr y ... Pa t was a `rock' for many of us there..She truly cares about those in need and h a s a huge heart...she will continue to make a positive difference in other people's liv e s ... " . R ic h a rd Powell, Chief, Risk Management, National Park Service, Washington, DC. " I am a 41 year career employee of the National Park Service...I have worked with and s u p e rv is e d many NPS personnel...Pat Buccello is among the finest...Pat is foremost an h o n e st and caring person and has represented the NPS and the law enforcement p r o f e ss io n with distinction throughout her career...Two outstanding examples of her care a n d her sensitivity to our employees are the work she has done for the (CISM) and M e d ic a l Standards programs...Pat became the model for how the (medical stan d a rd s)p r o g ra m should be managed to protect the employees as well as the NPS...In m y opinion, she stands tall among her peers and is one of the kindest, most honest and d e d ic a te d NPS employees I have ever had the privilege of working with." Ka ryl Yeston, Supervisory Park Ranger, Grand Canyon National Park, AZ. " In all the years that I have worked with her, I have observed that Ms. Buccello always c o n d u c te d herself with a high level of professionalism...Ms. Buccello was also a leading fo r c e in implementing major improvements in the NPS Medical Standards Program, wh ic h impacts all employees who perform law enforcement and fire fighting. Her im p r o v e m e n ts to the program have benefited all of us."

J o h n Patmore, District Law Enforcement Park Ranger, Curecanti, CO. " ( Pa t's ) compassion is also evident in her professional life...I have worked with Pat on m a n y tragic incidents in the National Park Service, and she never fails to professionally a tte n d to...duties...she then will go farther, and purposefully attend to the emotional n e e d s of those affected, whether it is employees or families...My wife and I view the r e c e n t events which bring Pat before the court as an anomaly...Her actions certainly do n o t fit in with her long and well defined history of professional service and concern for
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o th e r s ." S usan Schwarz, Park Ranger, Sequoia National Park, CA. " ... (a fte r joining the CISM team)I saw just how dedicated Pat could be towards s o m e th in g she believed in...(Pat) was the one person most instrumental in the National Pa r k Service having the CISM program...today...at Sequioia...we had one of our fir e fig h te rs die in the line of duty...Pat... was assisting the fire fighters family through th is ordeal. Her compassion and concern for this family was very evident...I don't know th e details of what happened with Pat. I do know that a 30 year stellar career should not b e wiped out due to some bad choices." P a tric ia Wands, Park Service firefighter (retired), AZ. S h e first met Pat when she was a backcountry ranger at Grand Canyon National Park... " B e in g a backcountry ranger required strength, courage, knowledge and care for th o u sa n d s of park visitors and employees. (Pat's) skills were graceful and powerful, a lwa y s ensuring that the visitor had a positive National Park experience. Pat developed the line-of-duty death response program and supported survivors across the country...It is difficult for some to speak from the heart, but for Pat, her words no doubt come n a tu r a l ly . Pat has always proven to be there for the families and the National Park S e rv ic e . I witnessed her professionalism...after the violent death of (a park ranger)...and with the family. She was extremely kind and compassionate with the family and the Park e m p lo y e es ... T h e NPS family is losing a fine employee over an offense that is totally out of c h a ra c te r for her. Because of Rangers like Patricia Buccello, the National Park Service is a well-loved and cherished organization." P a m ela McMillan, Coordinator, CISM Program, National Park Service. " Pa t's hard work, dedication, and great compassion for NPS employees are the fo u n d a tio n for why the NPS currently has an active CISM Program...I worked for Pat...in m a n y CISM responses that were Line of Duty Death related...Pat always showed great c o n c e r n for the family and friends of the deceased ­ going that extra mile to make sure th e y were well provided for...she created and formalized the NPS Line of Duty Death r e s p o n s e handbook...(which) came from Pat's desire to provide the very best for NPS e m p lo y e e s and their families." D a n Bahr, Operations Chief/Paramedic, County Ambulance Services, ME.

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" ( In working with Pat)...there has never been a single occasion that was anything but p r o fe ss io n a l, above board, honest and straightforward. She represents the epitome of the k in d of person you would want to walk through your door if you were unconscious at 2 :0 0 a m . She would guide her crew on how to treat you, she would make sure your pet wa s safe, and she would make sure your door was locked before they left for the hospital. S h e has been a strong leader (for the ambulance service)...and the towns...have been v e ry fortunate, indeed, to have her as the service chief...the EMT's and paramedics of th a t service have great respect for her leadership and trust her judgement...(she) is a v e ry valuable asset to the EMS community here in Maine...I certainly hope the judge will c o n s id e r her character and service to the community when deciding her sentence." Tim o th y Clough, Police Officer (retired), Southwest Harbor, ME. " ... In my law enforcement capacity, I have witnessed several times her dedication, p r o fe ss io n a lis m and compassion when treating victims of automobile accidents...drug o v e rd o s e s, domestic assaults, etc...I hope the court will take into consideration ...the to ta lity of her past work history and her many years of extraordinary dedication to c o m m u n ity service which she has demonstrated over and over again." C o m me nts from Management and Crew of the Southwest Harbor-Tremont, Maine, V o lunte e r Ambulance Service of which Pat has been a paramedic and crew chief for many ye a r s : S o nia Field, vice-president of the service: "The communities...have benefited greatly from (Pa t's ) presence as crew chief and paramedic...It would be an immense loss for all if this we re to change...I have found her to be an honorable person...I believe Pat is ir r e p la c e a b le ." Jerry Walls, volunteer, retired US State Dept: "I have observed her professionalism as a p a r a m e d ic under many levels of stress...I have full confidence in her professional and p e r s o n a l qualities." D w a yne Pinette, Paramedic/Firefighter: "(Pat) is a wonderful person, proficient crew c h ie f, great Paramedic, and a person whom I respect." J im Keene, President of the service, volunteer: "We all hold Pat in highest respect and a ffe c tio n ... I... a m glad to vouch for her good character." S us a n Clarke, EMT: "I have had many crew chiefs...none as good as Pat
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B u c c e l lo ... th r o u g h her caring, professional determination she has increased the stature o f the service. I know Pat to be a loyal, highly intelligent, straightforward, respectable a n d thoughtful friend and co-worker." E llio tt Spiker, volunteer, retired Department of Interior: " Pat has always acted in a totally p ro fes sio n a l, disciplined manner, exercising her fair-minded leadership with impeccable in te g r ity ."

M a uric e Marshall, EMT and past service President: "...she has provided mentoring...and h a s been very supportive and caring in the aftermath of multiple trauma or DOA calls. O u r crewmembers look upon Pat as not only a reliable EMS colleague, but also as a tr u s te d friend in tough times." D a vid & Heather Dostie, Paramedics: "(Pat) has always been a person of unquestioned c h a ra c te r, always completely honest, loyal and supportive on both a personal and p ro fes sio n a l level...always leading by example and setting a high bar of excellence rarely s e e n in other EMS services...she is a great mentor and an outstanding role model for new Pa r a m e d ic s... W e trust her implicitly, which in this field is the ultimate complement...Her s e rv ic e is vital for the continued health of the communities...Please let her continue her g r e a t work." D a vid Robertson, EMT-Intermediate, training officer: Pat Buccello has continually p r o v i d e d compassionate care for all her patients...providing our small towns with a very h ig h level of care...she has done all this for us in her spare time and on weekends...the Pa t Buccello that I know and work with is a very dedicated, caring person." D a le n Mills, volunteer, US Coast Guard retired: " I support Pat Buccello as our crew c h ief... we are blessed to have the abilities that she brings to our service...I certainly re a lize that she has had some glitches recently, but I also believe that the service is g e ttin g a better person to be the crew chief because of her travails...I look forward to her le a d e r s h ip ... " Ad d itio na lly, we are providing the Court with select examples, which are in no way e x h a us tive , of Ms. Buccello's commendations throughout the years and which more than a nyth ing , serve to prove her dedication as a federal employee and proud member of the N atio nal Park Service. Some of the actual representative awards are attached to this letter.
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O uts ta nd ing Federal Law Enforcement Employee Award, April 27, 2007 (no m ina tio n by Lane Baker, Deputy Chief, Law Enforcement, Security, and Emergency S e rvic e s) "...Pat's portfolio of completed cases is vast and literally spans the United S ta te s ... H e r nearly 30 year history is remarkable...Her support, performance, and le a d e rs h ip will be missed." W o m e n in Federal Law Enforcement, Julie Cross Memorial Award Nomination, April, 1 9 9 5 (nomination by Richard Gale, Deputy Chief Ranger, Washington, DC) "...Special A g e nt Buccello has clearly sustained a superior level of performance...she was the first fe m a le to be hired to a regular patrol position...Supervisors have recognized her skills in la w enforcement leadership and she has been the first female hired in every position she has h e ld ... Th ro ug h o ut her career, Ms. Buccello has provided a mentoring role to other w o m e n... Th e diversity of (Pat's) law enforcement ...include(s) her role, since 1993 as a k e y member of a multi-agency task force involved in the investigation of radical right-wing g ro up s ... H e r willingness to pursue investigation of perpetrators of hate crime is to be c o m m e nd e d ."

O uts ta nd ing EMS Performance, September, 2007 "...She has dedicated years to giving h e r best and inspiring and mentoring others to do the same for EMS in her community." E M T of the Year, September, 2001 "...Simply put, patients trust her, the medical staff trus ts her. We can count on her to do what needs to be done, to do it well, and to know her lim ita tio ns in doing so...many times under less than ideal conditions, for her patients. I d o n't think you could ask for anything better." S ta r Award, January, 2007 Quality Step Increase, October, 2006 Star Award, October, 2004 Outstanding Performance Recognition, Yellowstone Fires, September, 1998 Star Award, November, 1997 Q ua lity Performance Award, January, 1994 Q ua lity Performance Award, November, 1994
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Q ua lity Performance Award, September, 1993 S up e rio r Performance Incident Rating, Hurricane Andrew, September, 1992 S p e c ia l Achievement Award, April, 1991 E a g le Award, December, 1989 P e rfo rm anc e Award, August 1989 S p e c ia l Achievement Award, September, 1984 C o m m e nd a tio n for Bravery, May, 1984 (Regional Director, Howard Chapman) "Th e platform (at the edge of the Grand Canyon) was approximately five feet square, with a near vertical drop of approximately 150 feet on three sides. You were able to restrain the visito r and stop her suicide attempt...your prompt response to this emergency are in k e e p ing with the highest ideals of the National Park Service."

We are also providing representative select letters which demonstrate a history of c o m p a s s io na te care for co-workers and families of fatality (including homicides & e m p lo ye e suicides) victims documented in numerous letters. W e are also attaching some representative commendations and thanks for teaching a t academies, parks and other agencies. Finally, we are attaching a number of "thank you" letters from patients Pat has re sc ue d or treated in the national parks. As with the other attachments, these are not e x h a ustive and literally dozens of pages of other documents will be brought to court to d e m o ns tra te the support that Ms. Buccello has in the community at large. It is sincerely hoped that the Court will take all of this information into consideration a t the time of sentencing, and compassionately understand that the defendant's criminal
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c o nd uc t in this case is truly an aberration. We hope that after considering all of the good th a t she has done for the community, and after reviewing the pre-sentence report that Ms. B uc c e llo will be sentenced to a period of probation. Respectfully,

Michael L. Spekter M L S :s t

C E R TIFIC ATE OF SERVICE I hereby Certify that I have caused a copy of the foregoing Defendant's sentencing m e m o ra nd um to be served by hand with attachments on January 18, 2008 , and e le c tro nic a lly, without attachments, on the following individuals this date.

Ronald Sharpe, Esq. As s is ta nt United States Attorney D istric t of Columbia 5 5 5 4 th Street, NW W a s h ing to n, DC 20001

M ic h a el L. Spekter

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