UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF INDIANA

HAMMOND DIVISION


UNITED STATES OF AMERICA

Plaintiff,

v. CASE NUMBER: 2:13-CR-36

CHRISTOPHER M. BOUR

Defendant.
__________________________________/

DEFENDANTS SENTENCING MEMORANDUM

The Defendant, Christopher Bour, by counsel submits the following for the
Courts consideration in imposing a sentence upon him.
HISTORY AND CHARACTERISTICS OF THE DEFENDANT

Christopher Bour is 40 years old and has never been arrested in his life until
the present case. Christopher grew up with only his mother and brother, as he did
not know who his father was. He has had no contact with his mother since age 19 up
until recently after his arrest. Growing up, Christopher participated in the Juvenile
Workshop in Plainfield, Indiana as well as the United States Air Force Office of
Security Police in Boston, Massachusetts. (See Exhibit A attached).
Christopher has been a jack of all trades beginning with a paper route at the
age of 11. When he was 16, he got a job as a bus boy. At the age of 17, he started
working at Arbys and, after a short period of time, was promoted to manager. When
Christopher was 20 years old, he was a firefighter for Dolton, Illinois. After the age of
case 2:13-cr-00036-RL-APR document 63 filed 05/08/14 page 1 of 6
2

20, Christopher never worked for anyone, but was a self-employed entrepreneur. His
first business was Steaks n Stuff which sold frozen steaks and seafood door to door.
Next was a lawn care business, and finally Concrete Solutions. (See Exhibit B
attached). While in custody for this case, Christopher has developed a business plan
for when he is released from prison. (See Exhibit C attached)
Although Christopher has never been married, he has had four significant
long-term relationships with adult females. One of his long term relationships
included living together for one and half years. (See Exhibit D attached). Some of the
pictures in the attached exhibits show him as an extra in the film Public Enemy
from 2009.
At some point in his life, Christopher began viewing adult pornography. He
then began to view more youthful images, which progressed into child pornography.
Viewing pornography, both adult and child, seemed to become an addiction for him.
In spite of the above, there is a good and redeemable side of Christopher Bour
as evidenced by the character letters attached hereto as Exhibit E.
NATURE AND CIRCUMSTANCES OF THE OFFENSE
Christopher Bour now realizes that what he did in these crimes was very
wrong. He did help the authorities after he was arrested to locate the mother of the
victim. Christopher provided the following information to the government: 1) The
mother has a 219 telephone number; 2) he met her through a dating service; 3) he
texted back and forth with the mother regarding a time to meet using his telephone;
4) the mother is a heavy-set black female; 5) she lived in a single story apartment
case 2:13-cr-00036-RL-APR document 63 filed 05/08/14 page 2 of 6
3

complex surrounded by a wrought-iron fence off of Burr Street, 1 mile north of the
expressway on the left hand side, just past the dump; 6) the mothers apartment was
in the middle of the complex; and 7) the pictures were taken in her apartment. (See
United States v. Natasha Hillard, Case No. 2:13-CR-36, Criminal Complaint [DE 1]
filed February 22, 2013, paragraph 28). After his first questioning by the police in the
present case, Christopher did cooperate with the authorities. Christopher did admit
receiving and downloading child pornography.
As far as the text messages with TJ, Christopher was only sending those
messages as role playing. Christopher never told Natasha Hillard that he had been
with a prior child. Also, Christopher never threatened Natasha Hillard to coerce or
manipulate her to allow him to do this to her children. In fact, as evidenced by
Natasha Hillards own statements, it was approximately 50/50 on contacting
between herself and Christopher.
At one point, Christopher wanted to stop seeing Hillards child and sent her a
text message to that effect. This is collaborated by the fact contained in Hillards Rule
11 Proffer of March 13, 2013 where Bour told Hillard that had had moved to South
Bend and was not living in Gary. Christopher told her this so she would leave him
alone.
Hopefully the victims in this case, Jane Doe 1 and Jane Doe 2, will not
remember any of the actions of either Defendant. Among adults, the average age of
earliest memory is typically 3-4 years. Patricia J. Baur & Marina Larkina (2013):
The onset of childhood amnesia in childhood: a prospective investigation of the course
case 2:13-cr-00036-RL-APR document 63 filed 05/08/14 page 3 of 6
4

and determinants of forgetting early life events, found at Tandfonline. Department of
Psychology, Emory University, Atlanta, GA (2013). Studies in which children are
asked to report their earliest memories provide evidence of amnesia for early-life
events by the end of the first decade of life. (Id at 2).
Another factor for this Court to consider is that even though there may have
been some emotional or psychological damage, Jane Doe 1 or Jane Doe 2 did not
experience any physical damage. It is with great hope that they do not remember any
of the events as evidenced in the Bauer & Larkina, Memory (2013) article cited
above.
THE NEED FOR THE SENTENCE IMPOSED
The guideline calculation is well past Offense Level 43, which just goes to show
how illogical the calculation is for child sex offense cases. A sentence of life as
recommended by the guideline would be a greater than necessary sentence to comply
with the purposes set forth in 18 U.S.C. 3553(a). Christopher is currently 40 years
of age and if the Court were to impose the mandatory minimum sentence of 30 years,
he would serve 25.5 years in prison.
Recidivism rates for child molesters decreases over their lifespan. Laws, R. &
ODonohue, W., Sexual Deviance, Theory, Assessment and Treatment (2008) (See
Exhibit C attached). The recidivism rate for child molesters age 65 or older is less
than 5% after their release from custody. (See graph attached as Exhibit F). If the
Court were to sentence Christopher to 30 years imprisonment, he would be released
from custody at approximately 65 years old.
case 2:13-cr-00036-RL-APR document 63 filed 05/08/14 page 4 of 6
5

FORFEITURE AND RESTITUTION
While Christopher agrees to forfeit any computer or video equipment that was
used with the crimes, he does not agree to forfeit the real estate or proceeds derived
from the sale therefrom. Additionally, there is no agreement as to restitution. The
defense does not know what a reasonable figure would be for restitution for Jane Doe
1 and Jane Doe 2 as well as for the non-homemade child pornography. However,
Christopher is not opposed to paying reasonable restitution from the sale proceeds of
his real estate.
CONCLUSION

WHEREFORE, based upon the foregoing facts and circumstances, the
Defendant respectfully requests this Court to sentence him to 30 years
imprisonment, followed by a term of supervised release.

Dated: May 8, 2014

Northern District of Indiana
Federal Community Defenders, Inc.


By: /s/ Matthew D. Soliday
Matthew D. Soliday
31 East Sibley Street
Hammond, IN 46320
Phone: (219) 937-8020
Fax: (219) 937-8021
eMail: matthew_d_soliday@fd.org

case 2:13-cr-00036-RL-APR document 63 filed 05/08/14 page 5 of 6

6
CERTIFICATE OF SERVICE

I hereby certify that on May 8, 2014 I electronically filed the foregoing with
the Clerk of the Court using the CM/ECF system which sent notification of such
filing to the following: Jill Rochelle Koster, Assistant United States Attorney.


/s/ Matthew D. Soliday
Matthew D. Soliday,
Northern District of Indiana
Federal Community Defenders, Inc.

case 2:13-cr-00036-RL-APR document 63 filed 05/08/14 page 6 of 6