Thursday

exhibit 10

OFFICE OF DISTRICT ATTORNEY
EXHIBIT
10 Milwaukee County
November 21, 1995
Mr. Andrew Highlove
Attorney at Law
900.1 North 76th Street, Suite #204
Milwaukee, WI 53223

Ms. Jean Kies
Attorney At law
516 North Milwaukee Street, Suite #304
Milwaukee 53202

RE:State of Wisconsin v. Jonathan Gils and Cory Gilmore
case No.K-954770

Dear Attorney Hashlove and Attorney Kies:
Now that each of your clients has had a separate preliminary hearing, I want to make sure that each of you has received the 105 pages of police reports pertaining to this case. If either of you wants to view or inspect any of the evidence described in the police reports, please contact Detective Louis Johnson, who works second shift in the Bureau at the Milwaukee Police Department, to arrange a mutually convenient time.
With each of your clients, in the hustle and bustle of filing an Information at the end your prelim, I forgot to file the correct information justified by the testimony. When 1 reviewed the case,
I did not know whether your clients got a way with any money from the robbery pertaining to the father, so I charged them with attempted armed robbery. As you can see from the police reports, and as you each heard from the testimony, a subsequent audit revealed that approximately $1150.00 was missing after that robbery. Accordingly, I am enclosing an Amended Information that 1 will file with the court on l1/21/95, which will reflect two counts of Armed Robbery ( PTAC ), plus the other two counts named in the Criminal Complaint. Each of your clients can enter the formal not guilty pleas at the pre-trial date, 1/30/96.
If however, either of your clients wants to dispose of this case short of trial,1 have spoken with the two respective victims and am prepared to make the following offer; if either or both of your clients pleads guilty to the two counts of armed robbery as party to a crime, I will move to dismiss and read in for sentencing purposes the other two count. After preparation of a pre-sentence investigation, 1 will recommend two consecutive 20 year sentences, but I will recommend that I the second 20 year sentence be stayed, and that the defendant be placed on six years probation' consecutive to his sentence in count 1. As conditions of probation, I will recommend that each client have no contact with either of the victims, that each client recieve drug and alcohol abuse treatment, that each client own or possess no firearms, that each client be jointly or severally responsible for the restitution for both robberies, that each client be jointly and severally responsible for any out-of-pocket medical expenses suffered by the victims, and that each client pay the required costs, fees, and surcharges of the action.
As for defendant Gils, I know this offer is somewhat different from the other made in a letter to Attorney Kies on 11/13/95. 1 am hereby rescinding that offer, having had no indication of it being accepted. I am making this new offer based upon conversations with each of the victims, each of whom have now had to testify twice at preliminary hearings.
As you know, a 20 year sentence imposed means that a prisoner is eligible for parole after five years, and will be mandatorily released after after 13 years and 8 months, if not paroled earlier. Given the strength of the State's ,case, the seriousness of the injuries, the viciousness of the attacks, the fact that weapons were used, and the repetitive nature of these crimes, 1 believe the above disposition is a fair one. Of course, each of you is free to argue for a different disposition.
Please review these matters with your clients and let me know as soon as possible what your intentions are. Thank you for your attention and consideration.
Assistant District Attorney

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