Opinion
1:21-CR-98
05-26-2022
UNITED STATES OF AMERICA v. BLAKE FOREST WATSON
DENA J. KING UNITED STATES ATTORNEY ALEXIS SOLHEIM ASSISTANT UNITED STATES ATTORNEY NC State Bar number 46417
DENA J. KING UNITED STATES ATTORNEY
ALEXIS SOLHEIM ASSISTANT UNITED STATES ATTORNEY NC State Bar number 46417
GOVERNMENT'S REDACTED SENTENCING MEMORANDUM CONCERNING RESTITUTION
NOW COMES the United States of America, by and through Dena J. King, United States Attorney for the Western District of North Carolina, with an agreement between the parties concerning restitution.
1. Request from the “XXXXX ” Series
The United States received a restitution request from attorney Kelly Locher who represents the victim using the pseudonym “XXXXX ” from a series of child pornography called “XXXXX .” Defendant possessed child pornography images of this victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Locher informs the undersigned that payments should be made to:
Jones Day
Attn: Kelly Locher
500 Grant Street, Suite 4500
Pittsburgh, PA 15219-2514Attorney Locher requests that checks include the case name and court docket number and be made payable to “Jones Day in trust for XXXXX .” Defense counsel has agreed to this request.
2. Request from the “XXXXX ” Series
The United States received a restitution request in the amount of $10,000 from attorney Carol Hepburn who represents the victim using the pseudonym “XXXXX ” from a series of child pornography called “XXXXX .” Defendant possessed child pornography images of this victim. The parties to this case have been unable to reach an agreement with counsel for the victim. However, having considered the facts of the case and having analyzed the harm proximately caused by Defendant to the victim under Paroline v. United States, 134 S.Ct. 1710 (2014), the United States is not seeking the full amount of restitution requested by the victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Hepburn informs the undersigned that payments should be made to:
Carol L. Hepburn
P.O. Box 17718
Seattle, Washington 98127Attorney Hepburn requests that checks include the case name and court docket number and be made payable to “Carol L. Hepburn in trust for XXXXX of the XXXXX series.” Defense counsel has agreed to this request.
3. Request from the “XXXXX ” Series
The United States received a restitution request from Attorney Amy Mathieu who represents the victim using the pseudonym “XXXXX ” from a series of child pornography called “ XXXXX” Defendant possessed child pornography images of this victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Mathieu informs the undersigned that payments should be made to:
MarshLaw Firm PLLC
Attn:XXXXX
P.O. Box 4668 #65135
New York, New York 10163-4668Attorney Mathieu requests that checks include the case name and court docket number and be made payable to “Marsh Law Firm PLLC in trust for XXXXX ” and to also include the defendant's name in the memo line of the check. Defense counsel has agreed to this request.
4. Request from the “ XXXXX” Series
The United States received a restitution request from Attorney Amy Mathieu who represents the victim using the pseudonym “XXXXX ” from a series of child pornography called “ XXXXX” Defendant possessed child pornography images of this victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Mathieu informs the undersigned that payments should be made to:
Marsh Law Firm PLLC
Attn:XXXXX
P.O. Box 4668 #65135
New York, New York 10163-4668Attorney Mathieu requests that checks include the case name and court docket number and be made payable to “Marsh Law Firm PLLC in trust for XXXXX ” and to also include the defendant's name in the memo line of the check. Defense counsel has agreed to this request.
5. Request from the “XXXXX ” Series
The United States received a restitution request from Attorney Amy Mathieu who represents the victim using the pseudonym “XXXXX ” from a series of child pornography called “ XXXXX.” Defendant possessed child pornography images of this victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Mathieu informs the undersigned that payments should be made to:
Marsh Law Firm PLLC
Attn: XXXXX
P.O. Box 4668 #65135
New York, New York 10163-4668Attorney Mathieu requests that checks include the case name and court docket number and be made payable to “Marsh Law Firm PLLC in trust for XXXXX ” and to also include the defendant's name in the memo line of the check. Defense counsel has agreed to this request.
6. Request from the “ XXXXX” Series
The United States received a restitution request in the amount of $10,000 from attorney Carol Hepburn who represents the victim using the pseudonym “ XXXXX ” from a series of child pornography called “ XXXXX.” Defendant possessed child pornography images of this victim. The parties to this case have been unable to reach an agreement with counsel for the victim. However, having considered the facts of the case and having analyzed the harm proximately caused by Defendant to the victim under Paroline v. United States, 134 S.Ct. 1710 (2014), the United States is not seeking the full amount of restitution requested by the victim. Defendant has agreed to a restitution order of $6,000 for this victim. Attorney Hepburn informs the undersigned that payments should be made to:
Carol L. Hepburn
P.O. Box 17718
Seattle, Washington 98127
Attorney Hepburn requests that checks include the case name and court docket number and be made payable to “Carol L. Hepburn in trust for XXXXX of the XXXXX series.” Defense counsel has agreed to this request.
7. Request from the “ XXXXX” Series
The United States received a restitution request in the amount of $5,000 from attorney Carol Hepburn who represents the victim using the pseudonym “ XXXXX” from a series of child pornography called “ XXXXX.” Defendant possessed child pornography images of this victim. The parties to this case have been unable to reach an agreement with counsel for the victim. However, having considered the facts of the case and having analyzed the harm proximately caused by Defendant to the victim under Paroline v. United States, 134 S.Ct. 1710 (2014), the United States is not seeking the full amount of restitution requested by the victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Hepburn informs the undersigned that payments should be made to:
Carol L. Hepburn
P.O. Box 17718
Seattle, Washington 98127
Attorney Hepburn requests that checks include the case name and court docket number and be made payable to “Carol L. Hepburn in trust for XXXXX of the XXXXX series.” Defense counsel has agreed to this request.
8. Request from the “ XXXXX ” Series
The United States received a restitution request in the amount of $10,000 from attorney Carol Hepburn who represents the victim using the pseudonym “ XXXXX” from a series of child pornography called “ XXXXX .” Defendant possessed child pornography images of this victim. The parties to this case have been unable to reach an agreement with counsel for the victim. However, having considered the facts of the case and having analyzed the harm proximately caused by Defendant to the victim under Paroline v. United States, 134 S.Ct. 1710 (2014), the United States is not seeking the full amount of restitution requested by the victim. Defendant has agreed to a restitution order of $4,000 for this victim. Attorney Hepburn informs the undersigned that payments should be made to:
Carol L. Hepburn
P.O. Box 17718
Seattle, Washington 98127Attorney Hepburn requests that checks include the case name and court docket number and be made payable to “Carol L. Hepburn in trust for XXXXX of the XXXXX series.” Defense counsel has agreed to this request.
9. Request from the “ XXXXX ” Series
The United States received a restitution request in the amount of $7,500 from attorney Carol Hepburn who represents the victim using the pseudonym “XXXXX ” from a series of child pornography called “XXXXX .” Defendant possessed child pornography images of this victim. The parties to this case have been unable to reach an agreement with counsel for the victim. However, having considered the facts of the case and having analyzed the harm proximately caused by Defendant to the victim under Paroline v. United States, 134 S.Ct. 1710 (2014), the United States is not seeking the full amount of restitution requested by the victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Hepburn informs the undersigned that payments should be made to:
Carol L. Hepburn
P.O. Box 17718
Seattle, Washington 98127Attorney Hepburn requests that checks include the case name and court docket number and be made payable to “Carol L. Hepburn in trust for XXXXX of the XXXXX series.” Defense counsel has agreed to this request.
10. Request from the “ XXXXX ” Series
The United States received a restitution request in the amount of $7,500 from attorney Carol Hepburn who represents the victim using the pseudonym “ XXXXX” from a series of child pornography called “ XXXXX .” Defendant possessed child pornography images of this victim. The parties to this case have been unable to reach an agreement with counsel for the victim. However, having considered the facts of the case and having analyzed the harm proximately caused by Defendant to the victim under Paroline v. United States, 134 S.Ct. 1710 (2014), the United States is not seeking the full amount of restitution requested by the victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Hepburn informs the undersigned that payments should be made to:
Carol L. Hepburn
P.O. Box 17718
Seattle, Washington 98127Attorney Hepburn requests that checks include the case name and court docket number and be made payable to “Carol L. Hepburn in trust for XXXXX of the XXXXX series.” Defense counsel has agreed to this request.
11. Request from the “ XXXXX ” Series
The United States received a restitution request in the amount of $10,000 from attorney Carol Hepburn who represents the victim using the pseudonym “ XXXXX” from a series of child pornography called “ XXXXX.” Defendant possessed child pornography images of this victim. The parties to this case have been unable to reach an agreement with counsel for the victim. However, having considered the facts of the case and having analyzed the harm proximately caused by Defendant to the victim under Paroline v. United States, 134 S.Ct. 1710 (2014), the United States is not seeking the full amount of restitution requested by the victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Hepburn informs the undersigned that payments should be made to:
Carol L. Hepburn
P.O. Box 17718
Seattle, Washington 98127Attorney Hepburn requests that checks include the case name and court docket number and be made payable to “Carol L. Hepburn in trust for XXXXX of the XXXXX series.” Defense counsel has agreed to this request.
12. Request from the “ XXXXX” Series
The United States received a restitution request from attorneys Tanya Hankins and Susanna Southworth who represent the victim using the pseudonym “ XXXXX” from a series of child pornography called “ XXXXX.” Defendant possessed child pornography images of this victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorneys Hankins and Southworth inform the undersigned that payments should be made to:
Restore the Child, PLLC
2522 N Proctor St., Suite 85
Tacoma, Washington 98406-5338Attorneys Hankins and Southworth request that checks be made payable to “Restore the Child in Trust for XXXXX .” Defense counsel has agreed to this request.
13. Request from the “ XXXXX” Series
The United States received a restitution request from attorneys Tanya Hankins and Susanna Southworth who represent the victim using the pseudonym “ XXXXX ” from a series of child pornography called “ XXXXX.” Defendant possessed child pornography images of this victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorneys Hankins and Southworth inform the undersigned that payments should be made to:
Restore the Child, PLLC
2522 N Proctor St., Suite 85
Tacoma, Washington 98406-5338Attorneys Hankins and Southworth request that checks be made payable to “Restore the Child in Trust for XXXXX .” Defense counsel has agreed to this request.
14. Request from the “ XXXXX” Series
The United States received a restitution request from attorney Deborah Bianco who represents the victim using the pseudonym “ XXXXX ” from a series of child pornography called “ XXXXX .” Defendant possessed child pornography images of this victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Bianco informs the undersigned that payments should be made to:
Deborah A. Bianco, P.S.
P.O. Box 6503
Bellevue, Washington 98008Attorney Bianco requests that checks include the case name and docket number and be made payable to “Deborah A. Bianco, in trust for XXXXX .” Defense counsel has agreed to this request.
15. Request from the “ XXXXX” Series
The United States received a restitution request from attorney Deborah Bianco who represents the victim using the pseudonym “ XXXXX ” from a series of child pornography called “ .XXXXX ” Defendant possessed child pornography images of this victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Bianco informs the undersigned that payments should be made to:
Deborah A. Bianco, P.S.
P.O. Box 6503
Bellevue, Washington 98008Attorney Bianco requests that checks include the case name and docket number and be made payable to “Deborah A. Bianco, in trust for XXXXX ” Defense counsel has agreed to this request.
16. Request from the “ XXXXX ” Series
The United States received a restitution request from attorney Deborah Bianco who represents the victim using the pseudonym “ XXXXX” from a series of child pornography called “ XXXXX.” Defendant possessed child pornography images of this victim. Defendant has agreed to a restitution order of $4,000 for this victim. Attorney Bianco informs the undersigned that payments should be made to:
Deborah A. Bianco, P.S.
P.O. Box 6503
Bellevue, Washington 98008Attorney Bianco requests that checks include the case name and docket number and be made payable to “Deborah A. Bianco, in trust for XXXXX.” Defense counsel has agreed to this request.
17. Request from the “ XXXXX” Series
The United States received a restitution request from attorney Tanya Hankins who represents the victim using the pseudonym “ XXXXX” from a series of child pornography called “ .XXXXX ” Defendant possessed child pornography images of this victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Hankins informs the undersigned that payments should be made to:
The Law Office of Erik L. Bauer
P.O. Box 1091
Tacoma, Washington 98401Attorney Hankins requests that checks be made payable to “Tanya Hankins in trust for XXXXX .” Defense counsel has agreed to this request.
18. Request from the “ XXXXX ” Series
The United States received a restitution request from attorney Thomas Watson who represents the victim using the pseudonym “ XXXXX ” from a series of child pornography called “ XXXXX.” Defendant possessed child pornography images of this victim. Defendant has agreed to a restitution order of $3,000 for this victim. Attorney Watson informs the undersigned that payments should be made to:
Cusack & Gilfillan, LLC
411 Hamilton Boulevard, Suite 1510
Peoria, Illinois 61602Attorney Watson requests that check be made payable to “Cusack & Gilfillan, LLC for XXXXX Defense counsel agrees to this request.
19. Conclusion
For these reasons, the parties respectfully request that the Coin! enter the above restitution orders for each victim. The following table summarizes the amounts:
Series - Victim Pseudonym
Settlement Amount
XXXXX - “XXXXX”
$3, ooo.oo
XXXXX - “XXXXX”
$3.000.00
XXXXX - “XXXXX”
$3,000.00
XXXXX - “XXXXX”
$3, ooo.oo
XXXXX - “XXXXX”
$3.000.00
XXXXX - “XXXXX”
$6,000.00
XXXXX - “XXXXX”
$3.000.00
XXXXX - “XXXXX”
$4,000.00
XXXXX - “XXXXX”
$3,000.00
XXXXX - “XXXXX”
$3.000.00
XXXXX - “XXXXX”
$3,000.00
XXXXX - “XXXXX”
$3,000.00
XXXXX - “XXXXX”
$3,000.00
XXXXX - “XXXXX”
$3,000.00
XXXXX - “XXXXX”
$3.000.00
XXXXX - “XXXXX”
$3,000.00
XXXXX - “XXXXX”
$3,000.00
XXXXX - “XXXXX”
$3,000.00
Total
$58,000.00