Free Sentencing Memorandum - District Court of Delaware - Delaware


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Date: April 4, 2008
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I I Case 1 :O7—cr—OOO98-SLR Document 27 Filed O4/O4/2008 Page 1 of 2
1N THE UNITED STATES DISTRICT COURT
- FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, i g l
v. . ) Criminal Action No. 07-98-SLR
an ‘ CARL W. WILSON, JR., g
Defendant. g .
-— ` I GOVERNMENT’S SENTENCING MEMORANDUM i
The United States opposes the request of the defendant, Carl W. Wilson, Ir. (Wilson), for a
I —- downward variance nom the applicable Guidelines range. `
I In ten online chats with Paul Thielemann, spread over a nine month period, Wilson condoned
and encouraged the sexual molestation of young children. When Thielemann variously spoke of
_ having sexual access to young children, Wilson responded "kool"l and "awesome."2 Wilson agreed
that he “would luv to rape”3 a young girl. When Thielemann said that he was babysitting a two year i
. old girl in his bedroom with his penis exposed, Wilson responded "turn on ur cam and let me
watch."" On a different occasion when Thielemann said he was babysitting an eight year old girl,
if Wilson asked that she be brought to him, writing -"u going ot help me rape her too[?]" and #‘I wanna
make u force her to [perform fellatio on you.]" -
I Online chat, May 14, 2006, at 00:45:39 hours. I ‘
_ 2 Online chat, December 9, 2006, at 15:35:02 hours and 15:55:12 hours.
. 3 Online chat, February 1, 2007, at 20:10:31 hours. _,
4 Online chat, February 16, 2007, at 14:38:16 hours. ·

Case 1 :O7—cr—OOO98-SLR Document 27 Filed O4/O4/2008 Page 2 of 2
_ Wilson asserts that his receipt ofthe child pornography video and the nature of his online chats
are the result of motives other than a sexual interest in children. The Government submits that any
_ such distinction does not warrant a variance Hom the Guidelines. The prepubescent girl in the video
is victimized, regardless of the motives of the people who possess her image. Being a pedophile is
_ neither an element of the relevant offense nor a specific offense characteristic of the applicable
Guidelines section.
In conclusion, Wilson is not deserving of a variance because he not only possessed a video of
a prepubescent girl engaged in multiple sex acts with an adult male, Wilson condoned and
· encouraged such conduct in ntunerous online chats with Thielemann over a prolonged period.
_ COLM F. CONNOLLY ff?
. United St s Attorne ‘
‘ By: my A j
Edmon Falgows j
_ U Assistant United S ate : ttorney
-Dated:([·.((.-Og _ t