CONLEY Devell Govt Sentencing Memo

Case 3:17-cr-00214-JCH Document 152 Filed 05/21/19 Page 1 of 15
UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA CRIMINAL NO. 3:17CR214 (JCH)
v.
DEVELL CONLEY, a.k.a. “DL”

May 21, 2019
GOVERNMENT’S SENTENCING MEMORANDUM
I. Introduction
The defendant, Devell Conley, is 32 years old. He is not a “career offender,” as this legal
term of art is now construed in the Guidelines context. But he is, to be sure, a career criminal and
an inveterate drug trafficker who has spent much of his adult life in prison.
Conley has 14 prior convictions dating back to 2003. Nine of these were for selling drugs.
He committed the instant offense while on probation for selling drugs. He’s violated probation
three other times in the past, and all three previous probation violations involved the sale of drugs.
Conley’s other prior convictions include convictions for assault, threatening, criminal possession
of a gun, and resisting arrest.
The defendant’s prior sentences have not deterred him from criminal conduct. They have
not engendered a respect for the law. And, as discussed more fully below, they most certainly
have not adequately protected the public from Conley’s persistent--and the instant case, deadly--
drug trafficking.
On October 17, 2018, the defendant pleaded guilty to distributing heroin and fentanyl to
Christina Pace on May 5, 2017. Ms. Pace ingested the drugs, overdosed, and died. The
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defendant also pleaded guilty to distributing heroin and cocaine base from July of 2016 through
May of 2017. Under the terms of his plea agreement, Conley faces a statutory maximum term of
20 years in prison; a recommended Guidelines range of 70 to 87 months of imprisonment; a term
of supervised release of at least three years and up to life; and, a fine range of $15,000 to $1 million.
He is scheduled to be sentenced on May 28, 2019. The Government submits this memorandum
as an aid to the Court in fashioning an appropriate sentence, and recommends, respectfully, that
the Court sentence the defendant to no less than 80 months of imprisonment.
II. Pertinent Background
This case arises out of an investigation into the overdose death of Christina Pace, the victim
in this matter. The underlying investigation was conducted by the Drug Enforcement
Administration (“DEA”) and the East Haven Police Department (“EHPD”), with assistance from
the New Haven Police Department (“NHPD”).
On May 5, 2017, members of the EHPD responded to a suspected overdose at a residence
in East Haven, Connecticut. There they located Ms. Pace, who was deceased.
Officers seized from the residence Ms. Pace’s cellular telephone and three small bags
stamped with the words “griselda blanco.” The bags contained a powdery substance that field
tested positive for the presence of fentanyl. Subsequent laboratory testing conducted by the DEA
confirmed that the substance contained fentanyl and heroin (as well as tramadol, quinine, and
caffeine). The ensuing investigation revealed that Conley had supplied the drugs to Ms. Pace.
The investigation included the examination of call detail records, the extraction of text messages
from Ms. Pace’s cellular telephone, physical surveillance of Conley, and interviews of several of
Conley’s drug customers.
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A. Text Messages
Investigators analyzed Ms. Pace’s cellular telephone and discovered numerous text-
message exchanges between her cellular telephone and a telephone assigned telephone number
203-390-9948, which was later determined to be Conley’s telephone number. The text-message
exchanges occurred between April 20, 2017, and May 5, 2017, the date of Ms. Pace’s death, and
pertained to Ms. Pace’s purchase of drugs from Conley.
The following exchanges were among those discovered on Ms. Pace’s cellular telephone.
April 20, 2017
Pace: “Hey this Jaimes home girl she was Wit in the silver SUV can I
come see you?”
Conley: “I’m going to get it now. Give me a hour”
Pace: “K”
Pace: “Same shit? And how much for 2 whole”
Conley: “Yea 140”
Investigators concluded that, in the April 20, 2017, text-message exchange, Ms. Pace and
Conley were arranging to meet for the purpose of completing an illegal drug transaction.
Investigators further concluded that this exchange indicated the victim had ordered two bundles of
heroin, i.e. “2 whole,” for “140,” i.e. $140, which was consistent with the price for two bundles
(20 single-dosage-unit bags) of heroin, and that Ms. Pace’s reference to the “same shit” indicated
that she had previously, either directly or indirectly, obtained heroin and/or fentanyl or a mixture
thereof from Conley.
April 25, 2017
Pace: “Where do you want me to go.”

Conley: “Elliot St”
Pace: “Ok I’ll be there in 20 mins I need a whole one”
Conley: “Ok”
Investigators concluded that, in the April 25, 2017, text-message exchange, Ms. Pace and
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Conley were, once again, arranging to meet for the purpose of completing an illegal drug
transaction. Investigators further concluded that when she texted “Where do you want me to go,”
she was inquiring where Conley wanted to meet with her to consummate the anticipated drug
transaction. Investigators further concluded that when Conley texted “Elliot St,” he was directing
Ms. Pace to meet with him on Elliot St. in New Haven, Connecticut, to consummate the anticipated
drug transaction. Finally, investigators concluded that when Ms. Pace texted “Ok I’ll be there in
20 mins I need a whole one,” she was indicating that she would be arriving on Elliot Street in New
Haven, Connecticut, in 20 minutes and wanted to purchase one “whole” bundle of heroin from
Conley.
May 5, 2017
Pace: “Passing Walgreens”

Conley: “Ok”
Pace: “Here”
Conley: “Coming out”
Investigators concluded that, in the May 5, 2017, text-message exchange, Ms. Pace and
Conley were, once again, arranging to meet for the purpose of completing an illegal drug
transaction. Investigators also concluded that when Ms. Pace texted the words “Passing
Walgreens,” she was indicating she was traveling to a location where she anticipated meeting with
Conley. Investigators further concluded that when Ms. Pace texted the word “Here,” she was
indicating that she had arrived at the designated meet location. Finally, investigators concluded
that when Conley texted the words “Coming out,” he was indicating that he was coming out of his
location to distribute drugs to Ms. Pace. Ms. Pace, as indicated, was found dead later that day.
B. Information from Individuals in Frequent Contact with (203) 390-9948
As part of their investigation into Ms. Pace’s suspected overdose death, investigators, in
addition to analyzing the foregoing text messages found on her cellular telephone, also obtained
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call detail records for Conley’s cellular telephone, i.e. telephone number 203-390-9948.
Analysis of the call detail records identified several telephone numbers that were in
frequent contact with Conley on telephone number 203-390-9948. Investigators ran a search in
Facebook for these telephone numbers, which enabled investigators to identify the names of some
of the users.
1. Frequent Caller 1
One of these individuals (hereafter “Frequent Caller 1”), was known to members of the
East Haven Police Department. Investigators interviewed Frequent Caller 1 on May 17, 2017.
Frequent Caller 1 indicated that he/she had been in contact with telephone number 203-390-9948
for the purpose of purchasing heroin from the user of telephone number 203-390-9948. Frequent
Caller 1 further indicated that the user of telephone number 203-390-9948 was a black male,
approximately 35 years old, who used the name “DL.” Frequent Caller 1 also stated that he/she
believed that “DL” resided on Sylvan Avenue in New Haven, Connecticut, near the intersection
of Elliott Street.
Frequent Caller 1 also stated that he/she had purchased heroin that day from “DL,”
approximately one hour before meeting with investigators, and that “DL” operates a white colored
Infiniti sport utility vehicle. Finally, Frequent Caller 1 traveled with investigators to Sylvan
Avenue in New Haven and identified the location at the end of Elliot Street, where it intersects
with Sylvan Avenue, as the location where the black male known to Frequent Caller 1 as “DL”
regularly parks his white, Infiniti SUV.
2. Frequent Caller 2
In addition, on May 17, 2017, members of the East Haven Police Department observed a
parked vehicle, with an operator who appeared to be either asleep or unconscious in the driver side
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of the vehicle. Law enforcement spoke with the operator (hereafter “Frequent Caller 2”), who,
based upon previous investigation, had also been identified as the user of a telephone number that
had been in frequent contact with telephone number 203-390-9948.
Frequent Caller 2 informed officers that he/she frequently purchased heroin from the user
of telephone number 203-390-9948, that the user of the phone was a black male, that the black
male utilized the name “DL,” and that “DL” had supplied Frequent Caller 2 with heroin stamped
with the words “griselda blanco.”
Neither Frequent Caller 1 nor Frequent Caller 2 were cooperating witnesses. They were
sources who provided information to law enforcement as described above.
C. Events Pertaining to Conley’s Arrest
In the early morning hours of May 18, 2017, members of the DEA and the New Haven
Police Department established surveillance in the area of the intersection of Sylvan Avenue and
Elliot Street in New Haven, Connecticut. A white, Infiniti sport utility vehicle, bearing State of
Connecticut registration plates, was parked at the end of Elliott Street, at the intersection of Sylvan
Avenue, in the location that Frequent Caller 1 had identified for investigators on May 17, 2017.
The vehicle was registered to a male (hereafter “RS”) of Wallingford, Connecticut.
During the course of the surveillance, investigators observed Conley depart from the front
door of a residence located on Sylvan Street and engage in what appeared to be a hand-to-hand
exchange. The interaction was brief, and immediately following it, Conley walked to and entered
the aforementioned white SUV.
Surveillance was maintained on the Infiniti sport utility vehicle. The vehicle made
several turns, which were believed to be counter surveillance measures aimed at detecting and
evading law enforcement. Surveillance officers directed a marked patrol officer to stop the
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Infiniti sport utility vehicle.
Patrol officers stopped the vehicle without incident. The operator was positively
identified as Devell Conley. Investigators approached the driver side of the vehicle and called
telephone number 203-390-9948. Immediately after calling telephone number 203-930-9948,
investigators heard a ringing of a telephone in the driver’s side door compartment and retrieved
Conley’s cellular telephone, i.e. the cellular telephone that Ms. Pace, Frequent Caller 1, and
Frequent Caller 2, had contacted for the purpose of purchase heroin from Conley.
Thereafter, Conley was Mirandized and placed under arrest. The Infiniti sport utility
vehicle was transported to the DEA. Two additional cellular telephones were also recovered
from the same location in the vehicle, i.e. the drivers’ side door compartment, and $643.00 in cash
was located in Conley’s pants pocket.
D. Information from RS
On May 22, 2017, agents interviewed RS, the registered owner of the white, Infiniti sport
utility vehicle Conley was operating at the time of his arrest. RS indicated that he had purchased
heroin from Conley, that Conley utilized telephone number (203) 930-9948, and that he had
allowed Conley to use the white, Infinity SUV in exchange for heroin and with the understanding
that Conley would repair some damage to the bumper of the vehicle during the period of time that
Conley was using the vehicle. RS also indicated that Conley worked with another individual
known to RS by the alias “C” who was involved in narcotics trafficking. Investigators did not
believe RS had been completely truthful during the interview and had minimized his involvement
with Conley.
III. Anonymous Tip
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Following his arrest, agents learned that the NHPD had recently received a detailed, written,
anonymous tip regarding Conley. The tip indicated that Conley “sells heroin and crack out of his
apartment,” that he “goes by the name ‘DL,’” and that he utilizes “203-390-9948” (the telephone
number assigned to the cellular telephone Conley used to communicate with the victim in this case,
which was seized from him at the time of his arrest) as his “Drug Phone.” The anonymous tip
also indicated that Conley was supplied with drugs by a “young, Hispanic” male who operated a
“black truck.” Finally, the tip identified Conley’s “Personal [telephone] Number” and indicated
that the personal telephone number was not “registered” in Conley’s name.
Investigators eventually determined that the anonymous tip had been provided by DH. DH
was not a drug customer, but, rather, was one of Conley’s former girlfriends. DH was interviewed
and confirmed that she had, in fact, written the detailed, anonymous tip. Investigators do not
believe DH was completely candid when interviewed, and that she minimized her knowledge of
Conley’s drug trafficking, as well as its nature and scope.
IV. Interviews with Conley’s Drug Customers
In addition to interviewing Frequent Caller 1, Frequent Caller 2, and RS, investigators,
following Conley’s arrest, also located and interviewed several of Conley’s other drug customers.
Information from their statements is summarized below.
A. Customer 1
Customer 1 stated that he/she purchased crack cocaine and heroin from Conley, and had
begun purchasing drugs from Conley for several months before Conley’s arrest. Customer 1
identified two other customers who purchased heroin and/or crack cocaine from Conley.
Customer 1 also provided information about Conley’s retail pricing and packaging practices.
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More specifically, Customer 1 indicated that Conley sold $20 bags of crack, but would offer a
$10 discount if customers purchased three, $20 bags at a time. The discount would increase if
the quantity purchased was larger--10 $20 bags for $150--for example. Conley sold heroin in
bundles (10 single-dosage-unit bags tied, or “bundled” together). The bundles of heroin were
always stamped with some sort of branding. Customer 1 purchased drugs from Conley several
times after May 5, 2018, the date on which Ms. Pace overdosed and died.
B. Customer 2
Customer 2 stated the he/she had been purchasing heroin from Conley for approximately
eight years. During this time period, Customer 2 estimated that he/she had purchased thousands
of dollars’ worth of heroin from Conley. Customer 2 knew of several other individuals who were
regularly supplied with heroin by Conley.
C. Customer 3
Customer 3 purchased heroin frequently from Conley for more than a year before Conley’s
arrest. Conley charged between $70 and $80 per bundle of heroin, according to Customer 3.
Customer 3 remembered the “Griselda Blanco” stamp as a stamp utilized by Conley. Customer
3 recalled discussing with Conley the quality of the heroin Conley was distributing, and also
recalled Conley stating that he (Conley) did not use drugs, with the exception of marijuana.
Customer 3 also knew Conley to sell crack cocaine and drive nice cars.
D. Customer 4
Customer 4 purchased crack cocaine and heroin from Conley for years, and did so
frequently. In fact, for several periods of time, Customer 4 purchased drugs from Conley on a
daily basis. Customer 4 recalled Conley operating a nice Saab automobile. On one occasion,
Conley offered to provide drugs on consignment to Customer 4 in exchange for sex.
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E. Customer 5
Customer 5 purchased heroin from Conley. Customer 5 paid between $70 and $80 per
bundle of heroin, and recalled two of the stamps utilized by Conley on his bundles heroin: “Tom
and Jerry” and “Griselda Blanco.” Customer 5 recalled that Conley operated nice cars, including
an Infinity SUV.
F. Customer 6
Customer 6 purchased heroin and crack cocaine frequently from Conley for several months
prior to his/her arrest. Customer 6 recalled that, on occasion, Conley’s heroin was of poor quality.
Customer 6 knew of at least one other person to whom Conley sold drugs.
V. Criminal History
Conley, as noted above, has 14 prior convictions. His record dates back to 2003. The
United States Probation Office was able to obtain police reports corresponding to some of Conley’s
prior convictions. The reports document a troubling pattern, which has been compelling
chronicled in the PSR. Conley has also violated probation on multiple occasions and, in fact,
committed the instant offense while on probation. The sentences corresponding to Conley’s prior
convictions include sentences of 90 days in prison, one year in prison, three years in prison, five
years in prison, and nine years in prison. None of these sentences deterred Conley.
VI. Discussion of Sentencing Considerations
The Federal Sentencing Guidelines are no longer mandatory. United States v. Booker, 543
U.S. 220, 258 (2005). The Booker decision does not, however, reduce the Guidelines to “a body
of casual advice, to be consulted or overlooked at the whim of the sentencing judge.” United
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States v. Crosby, 397 F.3d 103, 113 (2d Cir. 2005); see also United States v. Johnson, 445 F.3d
339, 342 (4th Cir. 2006) (“By now, the Guidelines represent approximately two decades of close
attention to federal sentencing policy.”); United States v. Claiborne, 439 F.3d 479, 481 (8th Cir.
2006) (“The Guidelines were fashioned taking the other § 3553(a) factors into account and are the
product of years of careful study.”); United States v. Cooper, 437 F.3d 324, 331 n.10 (3d Cir. 2006)
(“The federal sentencing guidelines represent the collective determination of three governmental
bodies...as to the appropriate punishments for a wide range of criminal conduct.”); United States
v. Mykytiuk, 415 F.3d 606, 607 (7th Cir. 2005) (“The Sentencing Guidelines represent at this point
eighteen years’ worth of careful consideration of the proper sentence for federal offenses.”).
To the contrary, in the wake of Booker, the Guidelines remain an integral part of the two-step
sentencing process that district courts must now employ. See Crosby, 397 F.3d at 110-118.
Sentencing courts must first determine a defendant’s applicable Guidelines range, including
whether a departure is appropriate pursuant to the policy statements referenced in § 3553(a)(5).
Id. at 111-112. Second, sentencing courts must consider the applicable Guidelines range “along
with all of the factors listed in section 3553(a).” Id. at 112-113.
District courts may impose non-Guidelines sentences, but they may do so only after
determining a defendant’s applicable Guidelines range in conjunction with the other factors set out
in section 3553(a). See Crosby, 397 F.3d at 115 (“[A] judge would commit a statutory error...if
the judge failed to ‘consider’ the applicable Guidelines range as well as the other factors listed in
section 3553(a), and instead simply selected what the judge deemed an appropriate sentence
without such required consideration.”). Courts electing to impose non-Guidelines sentences must
articulate the basis for such sentences; and appellate courts review non-Guidelines sentences using
a reasonableness standard. Booker, 543 U.S. at 260-261; Crosby, 397 F.3d at 114; see also 18
11
U.S.C. § 3553(c) (requiring a district court to state the reasons for the imposition of a particular
sentence).
A. Statutory Maximums and Guidelines Ranges
A conviction for a violation of 18 U.S.C. §§ 841(a)(1) and 841(b)(1)(C) carries a maximum
penalty of 20 years of imprisonment, a period of supervised release of at least three years and up
to life, a fine of up to $1 million, and a special assessment of $100.
1. Offense Level
Under the terms of the plea agreement, the parties agreed that the defendant’s base offense
level is 22. See U.S.S.G. § 2D1.1(c)(8). Two levels are subtracted, because the defendant
accepted responsibility for his offense, see U.S.S.G. § 3E1.1, resulting in a total offense level of
20.
2. Criminal History Category
Under the terms of the plea agreement, the parties agreed that the defendant falls within
criminal history category VI. The PSR confirms this.
3. Guidelines Range
A total offense level of 20, and a criminal history category of VI, results in an applicable
Guidelines range of 71 to 87 months of incarceration. The Guidelines range for a term of
supervised release is three years to life. The Guidelines range for a fine is $1,500 to $1,000,000.
B. 18 U.S.C. § 3553(a) Factors
1. Nature and Circumstances of the Offense
The defendant’s offense conduct, and his relevant conduct, are serious. He has been a
narcotics trafficker his entire life, and his criminal conduct has impacted countless lives and
countless families, none more seriously, perhaps, than the family of Christina Pace, the victim in
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this case. The Court need not speculate about the extent of the harm and hurt Conley has
occasioned on the victim’s loved ones. Ms. Pace’s family members have submitted victim impact
statements, which are attached hereto, and which speak for themselves. See Exhibits A (Letter
from Laina Piscitelli), B (Letter from Nicole Watras), C (Letter from Noreen Piscitelli), and D
(Letter from Leslie Covert). The sentence imposed, therefore, should reflect the seriousness of
the defendant’s conduct.
2. Sentencing Goals
Generally, a sentence should be significant enough to promote respect for the law, protect the
public, and carry with it an appropriate general and specific deterrent effect. See United States v.
Tapia-Vitinio, 463 F. App’x 11, 13 (2d Cir. 2011) (The Court should consider the need to promote
both general and specific deterrence.). As stated above, the defendant committed the instant
offense while still serving a conditional discharge. And he did so against the backdrop of a
criminal history that includes 14 prior convictions and three prior probation violations. He is 32
years old and has served much of his adult life in prison in prison. His multiple, previous drug
trafficking convictions and probation violations demonstrate a plain, if not brazen, lack of respect
for the law. He has not been deterred, despite progressively lengthy prison sentences, including
a prior sentence of nine years for selling drugs.
Accordingly, the Government respectfully requests that the Court give appropriate weight to
several sentencing goals, including the protection of the public, promoting respect for the law, and
deterrence, when endeavoring to fashion an appropriate sentence in this case.
3. Need To Avoid Unwarranted Disparities Among Defendants With Similar

Records Who Have Been Found Guilty Of Similar Conduct.
The Guidelines exist for the precise purpose of reducing unwarranted disparities. See United
13
States v. Arjoon, 964 F.2d 167, 170 (2d Cir. 1992) (“One of the principal purposes of the
Sentencing Commission was to establish policies and practices that avoided unwarranted
sentencing disparities....”); United States v. Joyner, 924 F.2d 454, 460 (2d Cir. 1991) (“[A]n
applicable guideline range may seem harsh..., but it is the same range applicable throughout the
country for all offenders with the same combination of offense conduct and prior record.”). This
factor, therefore, supports giving greater weight to the applicable Guidelines range; it is not a
reason to depart from them.
VII. Conclusion
For the reasons set forth above, the government respectfully requests that the Court sentence
the defendant to no less than 80 months of imprisonment.
Respectfully submitted,
JOHN H. DURHAM
UNITED STATES ATTORNEY
/s/ Patrick F. Caruso

PATRICK F. CARUSO
ASSISTANT U.S. ATTORNEY
Federal Bar No. CT17984
157 Church Street, 23rd Floor
New Haven, CT 06510
14
CERTIFICATE OF SERVICE
This is to certify that on May 21, 2019, a copy of the foregoing Memorandum was filed
electronically and served by mail on anyone unable to accept electronic filing. Notice of this
filing will be sent by email to all parties by operation of the Court’s electronic filing system or by
mail on anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing.
Parties may access this filing through the Court’s CM/ECF System.
/s/ Patrick F. Caruso
PATRICK F. CARUSO
ASSISTANT U.S. ATTORNEY
Case 3:17-cr-00214-JCH Document 152-1 Filed 05/21/19 Page 1 of 8
Exhibit A
To you sir, Christina wasjust a drug addict. Someone you can get afewbucks fiom, close the window
and move on throughout your day to sell to the next "Junkie". What you and many others have failed to
see was that Christina was a mother, a daughter. a sister, a niece and a cousin to many. The love our
family has for each other is both a curse and a godsend. A godsend because without each other I am not
sure ifany of us alone could pull ourselves out ofthe darkness. A curse because I sit at night sometimes
wishing I was a cold hearted person who was incapable offeelings. Why do I think this? Because the
pain in my heart after going through that most tragic and traumatizing day of my life is sometimes too
muchtobear. However they are always there to pull meup. It is not that I haven't dealt with death
before. I lost my Mom and Dad when I was pretty young and it hurt. I lost a sister when she was 42 and
I thought it was the worse grief I would feel. May 5'l' and every day after that has been the worse grief.
Christina was a beautiful person inside and out. Because ofgetting in with the wrong crowd she is no
longer with us. She struggled to fit in; she fought to be loved but time and time again her heart was
broken.
Yes, Christina was an addict. Did she have a death wish? No, she loved her son with all the love she had
in her. She cherished her family and struggled to get sober.
Because ofyou, Mr. Drug Dealer, Christina is dead. You carelessly and recklessly sold her drugs that she
had no chance of surviving after she used it. She died with the needle in her hand. That's how much time
she had to think about what was abor.rt to happen. I hope every day you picture Christina being brought
out ofher house in a body bag with her lamily and friends devastated in the driveway and her Mom and
Step Dad 7 hours away and cannot be there to comfort their Son, Christina's brother who found her
lifeless body and her 6 year old son standing over her. The helplessness is beyond the irraginable.
Christina was an addict. Christina was loved and Christina willalways be loved and remembered. It is
low life's' like yourselfwho have so very little care about human beings, about the struggles. All in the
name to make a few bucks. Maybe this will turn your life around and become a productive member of
the human race, get a real job and ask God for tbrgiveness every day for what you sold to Christina. It is
very unlikely looking at your past history but one can always pray.
We take comfort in knowing that Christina is surrounded by light. free from the struggles that haunted her.
We rvould have given anyhing for her to experience that freedom in this lifetime. Our griefover losing her
is infinite. And now so is she. Rest in Pease our dear Christina, a mother, a daughter, a sister, a niece and a
cousin.
Exhibit B
RE: Christina Pace
March 5, 2019
Your honor,
My name is Nicole Watras, I am the first cousin to Christina Pace. Recently, in October of last year which
was just a few months ago, her brother Anthony Pace which is also my first cousin had the most
important day of his life. He married his high school sweet heart without his sister at his wedding. All he
had were pictures of her scrolling across a video monitor instead of her being here with him to
celebrate, laugh, dance, cry and just be together. She was so excited for that day and she missed it
because of someone's decision to take her life. We all missed Christina dearly on that day.
We have always been a very close ltalian family. We had Sunday dinner every single Sunday and those
were some of the best memories I have of Christina and my family. lt was always me, Christina, my sister
Alyssa, my cousin Anthony and my brother Rocco. There was not a week that went by that we were not
all together. Growing up and even in my adult years, Christina and I were BEST friends. My father Robert
and Christina and Anthonys father Anthony were also very close, it was always good times when we
were all together. We grew up being neighbors! Unfortunately, when Christina and Anthony were
smaller, my Uncle Anthony passed away from brain cancer.
My aunt Licia has been through way too much in her life, losing her husband and now losing her
daughter lcant begin to imagine how she feels on a day to day basis. She is also raising Christinas son,
Christopher who has to bare the pain of finding his mother deceased in his own home after arriving
home from school that very sad day of May 5th, 2017. Little Christophers life will never be the same. My
aunts life will never be the same. My cousin Anthonys life will never be the same. My life will never be
the same.
Your honor, please find it in our heart for my family and for Christina to give Devell Conley the
MAXIMUM Sentence. He has ruined so many peoples lives. Most of all he has ruined Christinas son,
Christophers life who is only 9 years old. I thank you for taking the time to read this letter and I hope you
will take this into consideration when making your decision.
Sincerely,
N icole M. Watras
Exhibit C
3/6/2o1.e
RE: Devell Connolly
My name is Noreen Piscitelli. Christina Pace was my niece. Devell Connolly allegedly sold Christina the
drug that led to her death with the knowledge that it contained Fentanyl.
Christina was a loving daughter, sister, niece and mostly mother to her son. Her son was only seven
years old when he lost his mother who he loved as his best friend. They had fun together every day,
whether it was the summer in their pool or just playing games in the house. He misses that immensely.
He will not grow up with a mother who will be in attendance at the best times in his life. He has been
cheated by her untimely passing.
Iwould just like it to be known how people are affected by our loss of Christina besides her mother,
brother and son. We are a very large, close family. We see each other at birthdays and holidays often.
Christina was present at every gathering, always willing to help. She had a personality that when you
saw her you immediately smiled. Not a day goes by that she is not thought of and missed. Her loss is felt
by many.
I would hope that your decision will prevent Devellfrom devastating another family.
Sincerely,
Noreen Piscitelli
Exhibit D
My name is Leslie Covert and l'm the aunt of the late Christina Pace. l'm not writing to tell you how or
what to do with this man, what lwould like to tellyou is about Christina.
She was a warm, loving,caring person. A daughter, sister,and most of all a mother. She had a heart of
gold and would help anyone and everyone she could have possibly helped. She cared for the elderly at
her job and loved doing it. Our families lives have been changed for ever especially her sons. She is
missed everyday that goes by. Her brother Anthony has the memory of what he found that day forever
etched in his soul. He got married without that one person that was truly excited and will start a family
without them ever knowing christina.
Christina's son Christopher will never have her there to cheer him on or watch milestones he will make
in life. My heart breaks for my entire family, we have an emptiness that will never be filled. At our last
family gathering I will never forget all the lau8hter we had and that is what I hold dear to my heart. Your
decision is yours but I truly believe that this man will never be a productlve member of society, his arrest
record has proven that and the fact he was caught still selling drugs. That alone speaks volume.
Just know that Christina is missed,was loved,and had a huge family supporting her.
Thank you for this opportunity to address the courts.

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Case 3:17-cr-00214-JCH Document 152 Filed 05/21/19 Page 1 of 15

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA CRIMINAL NO. 3:17CR214 (JCH)

DEVELL CONLEY, a.k.a. “DL”

GOVERNMENT’S SENTENCING MEMORANDUM

of a gun, and resisting arrest.

20 years in prison; a recommended Guidelines range of 70 to 87 months of imprisonment; a term

the Court sentence the defendant to no less than 80 months of imprisonment.

II. Pertinent Background

the New Haven Police Department (“NHPD”).

On May 5, 2017, members of the EHPD responded to a suspected overdose at a residence

Conley’s drug customers.

pertained to Ms. Pace’s purchase of drugs from Conley.

April 20, 2017

thereof from Conley.

April 25, 2017

Pace: “Where do you want me to go.”

Pace: “Passing Walgreens”

B. Information from Individuals in Frequent Contact with (203) 390-9948

regularly parks his white, Infiniti SUV.

had been in frequent contact with telephone number 203-390-9948.

with the words “griselda blanco.”

sources who provided information to law enforcement as described above.

C. Events Pertaining to Conley’s Arrest

The vehicle was registered to a male (hereafter “RS”) of Wallingford, Connecticut.

the aforementioned white SUV.

Infiniti sport utility vehicle.

telephone number 203-390-9948. Immediately after calling telephone number 203-930-9948,

was located in Conley’s pants pocket.

III. Anonymous Tip

Conley’s drug trafficking, as well as its nature and scope.

IV. Interviews with Conley’s Drug Customers

In addition to interviewing Frequent Caller 1, Frequent Caller 2, and RS, investigators,

Information from their statements is summarized below.

regularly supplied with heroin by Conley.

Conley offered to provide drugs on consignment to Customer 4 in exchange for sex.

VI. Discussion of Sentencing Considerations

whether a departure is appropriate pursuant to the policy statements referenced in § 3553(a)(5).

with all of the factors listed in section 3553(a).” Id. at 112-113.

A. Statutory Maximums and Guidelines Ranges

A conviction for a violation of 18 U.S.C. §§ 841(a)(1) and 841(b)(1)(C) carries a maximum

to life, a fine of up to $1 million, and a special assessment of $100.

2. Criminal History Category

criminal history category VI. The PSR confirms this.

Guidelines range of 71 to 87 months of incarceration. The Guidelines range for a term of

B. 18 U.S.C. § 3553(a) Factors

1. Nature and Circumstances of the Offense

the defendant’s conduct.

a prior sentence of nine years for selling drugs.

deterrence, when endeavoring to fashion an appropriate sentence in this case.

3. Need To Avoid Unwarranted Disparities Among Defendants With Similar

reason to depart from them.

the defendant to no less than 80 months of imprisonment.

/s/ Patrick F. Caruso

/s/ Patrick F. Caruso

RE: Christina Pace

RE: Devell Connolly

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