Felix Robert LaSaracina "carefully and methodically defrauded his victims over many years, knowing all the while that what he was doing was wrong," according to a government sentencing memorandum that paints the former Norwich accountant as a dishonest schemer.

Assistant U.S. Attorney Michael McGarry, who signed the 33-page document, rejects the notion that LaSaracina's "alleged gambling addiction" should be a mitigating factor in his sentencing and suggests that because LaSaracina was a successful businessman and respected community figure his crimes are all the more heinous.

McGarry, in his conclusion, calls on the court to impose a sentence of imprisonment "near the top" of a recommended range of 63 to 78 months and an order that he make full restitution to his victims and to the Internal Revenue Service.

U.S. District Judge Christopher F. Droney will sentence LaSaracina on Nov. 3 in Hartford.

The government's memorandum, dated Tuesday, contrasts sharply with a pre-sentencing memorandum LaSaracina's attorneys filed Monday. The earlier document blames LaSaracina's admitted misdeeds on an "all-consuming" gambling addiction.

McGarry disputes the characterization.

"In this case, the defendant's alleged gambling addiction was clearly not (as he alleges) 'all consuming,' nor did it have a causal connection to the charged offenses," McGarry writes. "His purported gambling problem may have led him to gamble, and create a motive or a motivation to steal his clients' money, but it did not cause him to grossly abuse his position of trust and commit this massive fraud over years and years."

LaSaracina, 60, agreed to plead guilty in July to wire fraud and willful failure to "pay over" taxes withheld from employees of his accounting firm, felony counts that carry a maximum combined prison term of 25 years. As part of the agreement, the government recommended a prison term of 63 to 78 months.

LaSaracina and the government stipulated that from about November 2001 to September 2010 he defrauded more than 20 "victim-investors" of at least $2.5 million. LaSaracina admitted diverting $1.2 million from a Norwich estate known as the Kauppinen Trust, for which he served as trustee from 1997 to 2010.

In his memorandum, McGarry states that LaSaracina defrauded his victims of more than $5 million, $2.2 million of which came from the trust.

In fleecing the trust, McGarry writes, LaSaracina mortgaged trust-owned property in Stonington that is leased by a restaurant and a motel. Beneficiaries of the trust, some of whom have "various difficult medical and developmental conditions," rely on the income the leases provide.

McGarry, citing a pre-sentencing report prepared by the U.S. Probation Office, writes:

"Mr. LaSaracina's activities have left the three beneficiaries of these trusts in dire straits, one of them owing well in excess of $100,000 in medical and care expenses, and the Trusts bereft of working capital, with a monthly mortgage payment of approximately $12,143.59 and a claimed obligation of an original $1,300,000 to the Groton Chelsea Savings Bank - with future projected losses of $1,963,617.26."

The Probation Office, McGarry writes, estimates that LaSaracina has victimized 32 people, not including the beneficiaries of the Kauppinen Trust.

While LaSaracina's attorneys argue in their memorandum that their client's history of business success and positive contributions to family and community warrant a prison sentence below the recommended range, McGarry writes, "these same facts can also be viewed in a very different light."

"Despite his success," McGarry writes, "the defendant still turned to criminal conduct in order to line his pockets and increase his own personal wealth. … When someone like the defendant does so, it is neither excusable nor explainable and merits a stiff and significant punishment for the purposes of both specific and general deterrence."

b.hallenbeck@theday.com