SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CRIMINAL DIVISION – FELONY BRANCH

UNITED STATES OF AMERICA ) Criminal No. 2008 CF1 29610

)
v. ) Judge Herbert B. Dixon, Jr.
)
CHARLES ELEGALAM ) Sentencing Date: February 1, 2011

GOVERNMENT’S SUPPLEMENTAL
MEMORANDUM IN AID OF SENTENCING

The United States, by and through its attorney, the United States Attorney for the District

of Columbia, respectfully submits this supplemental memorandum in aid of sentencing. Since

the United States filed its original memorandum in aid of sentencing – and just six days before

the original sentencing date in this case – the defendant stabbed another inmate at the D.C. Jail.

Indeed, a judge has now found probable cause with respect to a charge of Assault with a

Dangerous Weapon and issued an arrest warrant for the defendant. A copy of this arrest warrant

is attached as Exhibit A.

As discussed in that arrest warrant, on January 7, 2011, the victim allegedly saw the

defendant and others enagaged in a discussion that the victim thought would lead to violence.

The victim addressed some of those involved in the discussions and told them that violence was

not worth the consequences. The defendant responded by stabbing the victim nine times.

Importantly, the victim later reported that he swung his hands to prevent the defendant’s knife

from his head and neck. Even more distrubingly, the defendant only stopped stabbing the victim

because a D.C. Jail Corrections Officer interrupted the assault.

The government spent considerable time in its original sentencing memorandum

discussing the defendant’s prior criminal history. This latest offense is very troubling. The

defendant was pending sentencing at the time he stabbed another inmate nine times. He was well
aware that this atrocious conduct may be considered by this Court in imposing sentence, but he

nonetheless acted. While this defendant – like virtually all defendants – is sure to claim he is

remorseful at the sentencing hearing, such brazen conduct certainly undercuts any such claim.

To the contrary, it is further evidence that the defendant poses a very real danger to the public.

For the reasons discussed in the original memorandum of sentencing, coupled with this latest

alleged offense, the government stands by its previous recommendation that the Court sentence

the defendant to a period of incarceration of not less than 59 years.

CONCLUSION

For the reasons discussed above, the government respectfully requests a sentence of

incarceration of not less than 59 years.

Respectfully submitted,

RONALD C. MACHEN JR.

UNITED STATES ATTORNEY

SHARAD S. KHANDELWAL
ASSISTANT UNITED STATES ATTORNEY
U.S. Attorney’s Office, District of Columbia
Homicide Section
555 4th Street, N.W., Suite 9417
Washington, D.C. 20530
(202) 252-7091 (Tel)
(202) 353-9415 (Fax)

CERTIFICATE OF SERVICE

I hereby certify that I caused a copy of the foregoing to be served by e-mail this 26th day
of January, 2011:

Lisbeth Sapirstein, Esq.

________________________________
SHARAD S. KHANDELWAL
Assistant United States Attorney

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