WHEN HE WAS ARRESTED FOR THIS CRIME ON JANUARY 9, 2013,

DAVID RENZ PRESENTED AS WHAT SOME WOULD REFER TO AS A

TYPICAL RUN-OF-THE MILL CHILD PORNOGRAPHY OFFENDER.

HE HAD COLLECTED AND MAINTAINED AN ENORMOUS COLLECTION

OF CHILD PORNOGRAPHY, BUT APPEARED WITH A GOOD JOB, A

STABLE RESIDENCE, NO CRIMINAL RECORD, AND NO DISCERNABLE

REASON OTHER THAN THE NATURE OF HIS CRIME ITSELF- FOR THE

COURT, PROBATION, AND THE ATTORNEYS, TO PROVE OR FIND THAT

HE WAS A RISK OF FLIGHT OR DANGER TO THE COMMUNITY. SO HE

WAS RELEASED. ON STANDARD CONDITIONS.

AND THEN HE PROVED, WHAT 10 YEARS OF EXPERIENCE IN THIS

PARTICULAR FIELD HAS TAUGHT ME THERE IS NO TYPICAL, NO

RUN OF THE MILL CHILD PORNOGRAPHY CASE.

WITH PREMEDITATION, PLANNING, AND PRACTICE, THE DEFENDANT

THWARTED THE GPS SYSTEM HE WAS ORDERED TO WEAR, AND ON

THE NIGHT OF MARCH 14, 2013, DAVID RENZ CARRIED OUT A PLAN

HE HAD CLEARLY SPENT TIME THINKING ABOUT, PREPARING, AND

PLANNING. AND HE COMMITTED THE MOST HORRIFIC CRIMES THIS

COMMUNITY HAS SEEN IN RECENT MEMORY.

WHEN PEOPLE DENY THE CONNECTION BETWEEN CHILD

PORNOGRAPHY AND HANDS-ON OFFENSES, THEY SHOULD BE

REMINDED THAT THE RAPE COMMITTED BY DAVID RENZ THAT

NIGHT MIMICKED, TO A LARGE DEGREE, THE RAPE OF A CHILD

DEPICTED IN HIS COLLECTION OF CHILD PORNOGRAPHY.

BUT WHILE THE RAPE WAS CERTAINLY A DRIVING FORCE BEHIND

THE CRIMES DAVID RENZ SET OUT TO COMMIT THAT NIGHT, IT IS

EQUALLY AS CERTAIN THAT HIS END GAME, HIS EXIT STRATEGY,

WAS TO LEAVE NO WITNESSESS. DESPITE AMPLE MEANS AND

OPPORTUNITES TO FLEE INTO THE NIGHT ONCE HE ACCOMPLISHED

THE RAPE, DAVID RENZ INSTEAD TOOK HIS VICTIMS TO A REMOTE

LOCATION, WHERE, WHILE HE KILLED LORI BRESNAHAN, THE CHILD

MANAGED, MIRACULOUSLY, AND WITH AN UNIMAGINABLE

AMOUNT OF INNER STRENGTH, TO ESCAPE TO THE RESCUE OF

STRANGERS.

WHILE WE ARE CERTAINLY NOT HERE TO SENTENCE DAVID RENZ

FOR THE CRIMES HE COMITTED ON MARCH 14TH OF LAST YEAR,

THOSE CRIMES INFORM THIS SENTENCE.

WHILE THE DEFENSE POINTS TO THE DEFENDANTS APPEARANCE,

CHILDHOOD DIFFICULTIES, AND ADULT ACCOMPLISHMENTS AS

FACTORS THAT SET RENZ APART FROM OTHER OFFENDERS THEY

DONT.

WHAT SETS DAVID RENZ APART ARE HIS ACTIONS. HE HAS PROVEN

TO THIS COURT- AND TO THE COMMUNITY WHO HE REALLY IS,

AND WHAT HE IS REALLY CAPABLE OF.

AND IT WAS ONLY AFTER HE COMMITTED THESE HORRIBLE CRIMES

THAT WE LEARNED THAT THE MAN WHO PRESENTED AT HIS INITIAL

APPEARANCE WITHOUT A CRIMINAL RECORD HAD IN FACT

SEXUALLY ABUSED A CHILD BEFORE. THE ELUSIVE FAMILY COURT

RECORDS, WHICH REMAIN SEALED TO THIS DAY, WOULD HAVE

SHOWN AN ADJUDICATION FOR ANOTHER SEX OFFENSE.

BUT WHILE THOSE RECORDS REMAIN SEALED, THE MEMORY OF HIS

VICTIM, NOW AN ADULT, REMAINS VIVID. SHE HAS COME FORWARD

AND DESCRIBED A YEAR-LONG NIGHTMARE OF REPEATED SEXUAL

ABUSE AT THE HANDS OF DAVID RENZ, WHO, ALONE, AND

TOGETHER WITH A FRIEND, ABUSED THIS CHILD WHEN SHE WAS 8 9

YEARS OLD AND RENZ WAS 15.

IT IS ALSO SIGNIFICANT TO NOTE THAT A SEARCH OF THE

DEFENDANTS RESIDENCE AFTER THE MARCH 14TH CARJACKING,

MURDER AND RAPE REVEALED YET ANOTHER COLLECTION OF

CHILD PORNOGRAPHY. POSSESSED WHILE ON FEDERAL

SUPERVISION.

AS NOTED IN OUR SENTENCING MEMORANDUM, ALL OF THESE

FACTORS PROVIDE THE EVIDENCE NEEDED TO SUPPORT A FINDING

THAT CRIMINAL HISTORY CATEGORY I SUBSTANTIALLY

UNDERREPRESENTS THE SERIOUSNESS OF THE DEFENDANTS

CRIMINAL HISTORY AND THE LIKELIHOOD THAT HE WILL RE-

OFFEND. AND THE COURT SHOULD DEPART UPWARD FROM CHC I

TO CHC V.

MOREOVER, THE REPEATED SEXUAL ABUSE COMMITTED BY THE

DEFENDANT AT AGE 15, COUPLED WITH THE HORRIFIC AND SPECIFIC

ACTS OF RAPE COMMITTED ON MARCH 14, 2013, SUPPORT AN

UPWARD DEPARTURE UNDER 2G2.2, AS THE PATTERN OF ABUSE

ENHANCEMENT OF 2G2.2(b)(5) DOES NOT ADEQUATELY REFLECT

THE SERIOUSNESS OF THE SEXUAL ABUSE OR EXPLOITATION

INVOLVED.

AND LET THE DEFENDANTS OTHER VICTIMS NOT BE FORGOTTEN.

EACH AND EVERY CHILD IN EACH AND EVERY ONE OF THE

DEFENDANTS 11,000 IMAGES AND 1,100 VIDEOS FOR WHICH HE

STANDS CONVICTED. EVERY SINGLE ONE OF THOSE CHILDREN WAS

USED BY DAVID RENZ TO FUEL HIS TWISTED INTEREST IN THE

EXPLOITATION OF CHILDREN. EVERY ONE OF THEM IS ALSO HIS

VICTIM.

WHILE THE DEFENSE ARGUES FOR A GUIDELINES SENTENCE AR

RARE EVENT IN CHILD PORNOGRAPHY CASES THE GOVERNMENT

SUBMITS THAT WHETHER ACHIEVED BY THE UPWARD DEPARTURS

REQUESTED, OR A NON-GUIDELINES SENTENCE ABOVE THE

CALCULATED RANGE, THIS DEFENDANT, FOR THIS CRIME, UNDER

THESE CIRCUMSTANCES, MUST BE SENTENCED TO THE MOST TIME

POSSIBLE. HERE, THAT IS A COMBINED SENTENCE THAT EQUALS A

SENTNCE WITHIN THE RANGE OF 30 70 YEARS.

ADDITIONALLY, THE GOVERNMENT REQUESTS THAT THE COURT

EXERCISE ITS DISCRETION AND ORDER THAT THE SENTENCE

IMPOSED HERE TODAY SHALL RUN CONSECUTIVELY TO THE

ANTICIPATED SENTENCE FOR THE PREDATORY SEXUAL ASSAULT

AND MURDER CHARGES PENDING SENTENCE IN ONONDAGA COUNTY

COURT.