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Case 2:18-cr-00003-CB Document 97 Filed 03/05/19 Page 1 of 4




v. ) Criminal No. 18-003


AND NOW, comes the United States of America, by its attorneys, Scott W. Brady, United

States Attorney for the Western District of Pennsylvania, and Timothy M. Lanni Assistant United

States Attorney for said district, submits its following sentencing memorandum in the above

captioned matter:



Title 18, United States Code, Section 3553(a) requires this Court to consider the following

sentencing factors: (1) the nature and circumstances of the offense and the history and

characteristics of the defendant; (2) the need for the sentence imposed to reflect the seriousness of

the offense, to promote respect for the law, and to provide just punishment for the offense; (3) the

need to afford adequate deterrence to criminal conduct, and to protect the public from further

crimes of the defendant; (4) the need to provide the defendant with educational or vocational

training, medical care, or other correctional treatment in the most effective manner; (5) the

guidelines and policy statements issued by the Sentencing Commission; (6) the need to avoid

unwarranted sentence disparities among defendants with similar records who have been found

guilty of similar conduct; and (7) the need to provide restitution to any victims of the offense.

In this case, greed and a misguided need for revenge caused Brad Lanese to travel to the

ends of the country and stand on the edge of the Pacific Palisades and instead of ruminating on the
Case 2:18-cr-00003-CB Document 97 Filed 03/05/19 Page 2 of 4

natural beauty of the area, hypothesize on how he could turn this scenic place into an ideal crime

scene, the final chapter in his murder for hire plot 1:

CS 1: When we go through here, show me the cliffs that you are talking about
LANESE: It will look like an accident, that's the long term deal.
CS 1: I like your idea, like inject her with heroin and throw her over the hill, make
it look like a DUI accident.
LANESE: Yes, dude it happens fucking ten times, all day up in this fucking place.
They don't even investigate half of these fucking things dude.
CS 1: So what do you do? Stun gun her and inject her with heroin?
LANESE: Exactly
CS 1: Push her truck off the mountain?
LANESE: Exactly
LANESE: I'll do it. I will fucking gladly fucking be that fucking guy that does
that. I've rehearsed this in my mind a thousand times.
LANESE: Honest to god. I know the exact spot.
CS 1: Right
LANESE: Wait until I show you this, youre going to be like oh my god perfect,
its one little fucking accidental not turn of the wheel.
CS 1: Right

Before Lanese had even made it to California, he had already had multiple meetings with

CS 1 and had planned to fly to California in order to plan to execute a home invasion, kidnapping,

and robbery of those running the profitable marijuana farm he was cut out of. While Lanese’s plans

had not yet turned to murder, his intentions were no less depraved:

LANESE: So right now, they are harvesting ok, it's the big outdoor
CS 1: Right
LANESE: ok so, that there, okay
CS 1: About how many pounds
LANESE: Last time it was 360 lbs, they grow 300, every time they plant 1000
CS 1: Right
LANESE: It all outdoor, that I know for a fact
CS 1: Right
LANESE: okay, it's the cold hard cash, I know, I know they got a safe, ok I know
they always got at least 30 or 40 g's because they have to pay their clippers
everyday when they are done, and that's where they do it all um...
CS 1: Where are they keeping the bulk of the cash?

1 These are transcribed portions of statements made by Lanese recorded by DEA

investigators. They are reproduced from the criminal complaint filed against
Lanese on December 4, 2017 at Magistrate No. 17-1520.
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LANESE: That one, they rented a storage facility which is right next to their
CS 1: Right
LANESE: Cause I'm gonna break, I'm gonna break their fuckin fingers even after
it's all done, I'm gonna break his fingers and his knees.

However, en route to California, Lanese’s plans took a deadly turn. Instead of simply

asking “Deeds”, undercover DEA TFO and City of Pittsburgh Bureau of Police Det. Eric Harpster,

to help acquire firearms and aid in the home invasion, kidnapping, and robbery, Lanese asked

Deeds if he had any problem “building a woman’s room” or in the lingo Lanese, CS 1 and Deeds

had developed: murdering a woman. Deeds stated that he had no problem “building a woman’s

room”, but would not do any “children’s rooms” and would do what Lanese requested for $20,000.

Back in Pittsburgh, Lanese confirmed that he would pay an extra $10,000, $30,000 in total, because

would not have the funds to pay Deeds until the murder had taken place and could move back to

marijuana farm and share in its profits.

Luckily, due to the extraordinary efforts of Det. Harpster, Det. William Churilla from

Pittsburgh Bureau of Narcotics and Vice, and the DEA and ATF both in Pittsburgh and California,

Lanese was taken into custody before any harm could come to the intended victim. However,

Lanese’s lack of success in this plot does not in any way diminish the serious and disturbing nature

of his conduct in this case. His conduct alone and the facts and circumstances of this case preclude

any basis for a departure or variance in this case. See United States v. Kilkeary, 410 F. App'x 554,

556 (3d Cir. 2011) (In which court held that defendant’s conduct in terrorizing Atlantic City casino

patrons with a bomb threat and hostage situation alone justified an upward variance of 65 months).

Defendant’s lack of a serious prior record has already been factored into an agreement of 96

months which is near but not at the top of the end of the statutory maximum on the count of

conviction. While the facts in this case are unique circumstances unlikely to reoccur, this sentence

will also adequately deter Lanese from any similar future conduct.

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The Government respectfully requests that the Court sentence defendant to 96 months.

Respectfully Submitted,

United States Attorney

s/ Timothy M. Lanni
Assistant U.S. Attorney
NJ ID No. 011242012