SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CRIMINAL DIVISON UNITED STATES OF AMERICA 2013CFr18397 V. JUDGE ROBERT MORIN SOSEFINA AMOA CSH: MAY 23,,2014 PDID: 676469 GOVERNMENT'S MEMORANDUM IN AID OF SENTENCING The United States of America, by and through its attorney, the United States Attorney for the District of Columbia, hereby submits this memorandum in aid of sentencing. Based on the facts of this case and the defendant's conduct and criminal history, the United States respectfully requests that this Court impose a sentence of five years, impose the maximum supervised release, order the defendant to make payments to the Victims of Crime Fund, impose court costs, obtain mental health treatment, and advise her that she is subject to deportation. I. Background On October 5,2013, the defendant, who is 26 years old and from the island of Samoa, arrived in the United States and began her "Religious Formation" program at the "Little Sisters of the Poor" facility, located at 4200 Harewood Road, N.E, Washington, D.C. The "Little Sisters of the poor" is an international congregation of Roman Catholic Women who provide worldwide period, service to the elderly poor. The defendant was to reside in the convent for a five month In receiving religious classes, doctrine, prayer life, community life, and caring for the residents. into a other words, she was considered a "Postulant," a person who wanted to be admitted religious order. During the first few days after the defendant arrived at the Convent, members of the Order noticed that the defendant was having difficulty kneeling. On Thursday, October 10,2013, the defendant asked to be excused from her duties and stated that she was having menstrual cramps. The defendant stated that she began to experience bleeding around 8:30 a.m. or 9:00 a.m. and had significant abdominal pain. She went to her room. On several occasions, one of the Sisters went to her room and offered her assistance or food. The defendant refused. The Sister observed that the defendant looked sweaty and in pain. At around 1 1:00 a.m., the defendant reported that after l5 or 20 minutes, she felt the baby started "coming." She stood on the floor while leaning on her bed and the baby "came out" and fell straight down, striking the floor. She described experiencing severe stomach pain. The baby cried for two to three minutes. She laid on the floor next to the child and could see that he was not breathing. The defendant cleaned the room with rags and left them in the trash pail in the room. The defendant woke up on Friday, October ll,20l3 at around 8:30 a.m. or 9:00 a.m. and contacted a Religious Sister who resided in the Convent. Initially, the defendant told the Sister that she had to show her something. The defendant took the witness to her room and showed her the baby. The Sister looked at the baby and knew that it was dead. Initially, the defendant told the Religious Sister that she found the body outside, but then, later, she recanted her story, admitting that she gave birth to the child. The Religious sister picked up the child, and the child was cold and stiff. The Sister made ilrangements to transport the defendant and the baby to Providence Hospital. clothing, When the police executed a search of the defendant's room, they found bloody cord which had bloody rags, and pads. They also found part of the placenta and the umbilical 2 been placed in the trash. It was obvious that the defendant had made attempts to clean the room to hide the birth of her child. On October 16,2013, Detectives from the D.C. Metropolitan Police Department interviewed the defendant. She admitted that she was not truthful during her first interview at the hospital on October 1lth. She admitted that she had not told the "Little Sisters of the Poor" about her prior sexual encounters. She said that after she gave birth to the child, the child fell to the floor. She then laid next to the child. She said that she did she was afraid that someone would hear the not know what to do and that child crying and learn of her pregnancy. She said that she placed a black wool garment over the child's nose and mouth and applied pressure with her hand for two to three minutes until he stopped breathing. The defendant admitted that prior to placing the wool garment over the child's nose and mouth the child was breathing and had cried. She admitted that initially she had lied when she told a Religious Sister that she had found the baby outside. On Wednesday, October 16, 2013, D.C. Deputy Medical Examiner Nikki Mourtzinos conducted the autopsy and found the decedent's Cause of Death to be Asphp