CLEVELAND, Ohio - An attorney for former Warren assistant prosecutor Nicholas Graham has submitted a sentencing memorandum to a federal judge that includes information about Graham's life and letters of support from community members, including a former Ohio Republican Party Treasurer. The request aims to persuade the court to impose a less severe sentence ahead of Graham’s sentencing hearing on Nov. 19.

Graham, 52, pleaded guilty in August to one count of conspiracy. The city of Warren previously fired him in September 2022 following the investigation into the matter.

The case centers on an agreement between Graham and Niles car dealer Brian Votino, 52. Court documents show that in October 2019, Graham agreed to use his position as a prosecutor in Warren Municipal Court to help Votino with two pending criminal cases. In return, Votino would provide free repairs to Graham's truck.

Votino was facing a drug possession charge and a charge for driving under the influence. The indictment alleged that in January 2020, Graham reduced the felony drug charge to a first-degree misdemeanor and lowered the DUI charge to a third-degree misdemeanor for reckless operation of a vehicle.

Graham asked the court for probation and a suspended sentence for Votino. To hide the agreement, Graham allegedly told Votino through a third person to falsify a bill for the truck repair and to keep the deal secret from Votino's own criminal defense lawyer.

Graham’s sentencing memorandum asks the judge to consider his personal circumstances and history, typically suggesting that these factors warrant a sentence at the lower end of the federal guidelines. These requests often include an expression of remorse and highlight the defendant's acceptance of responsibility by pleading guilty.

The memorandum includes several letters of support, which are written by people in the defendant's life to provide the court with a fuller picture of the person beyond the crime. Among the most notable people offering support is Tracy Winbush, the former Ohio Republican Party Treasurer and a previous Youngstown mayoral candidate. The letters describe Graham’s positive qualities, contributions to the community, and provide a character reference.

Graham's co-defendant, Votino, has a sentencing hearing scheduled for Nov. 14. Votino’s attorney submitted a similar request, citing his good conduct while on bond, strong family ties, as well as physical and mental health issues as reasons for leniency.

The judge will review Graham's full sentencing memorandum, the letters of support, and other legal factors before determining the sentence.