When crypto fraudster Sam Bankman-Fried went on trial in 2023, the prosecution’s star witness was on-and-off-again girlfriend Caroline Ellison, who was CEO of his trading firm and whose testimony helped put him in prison for 25 years. Now, Ellison will face the court again—this time to plead for leniency as a judge prepares to sentence her for her own role in the collapse of FTX.

On Tuesday night, Ellison’s attorneys filed a 67-page memorandum detailing her cooperation with prosecutors and FTX’s bankruptcy estate, and asking that she avoid any jail time for her involvement in FTX’s collapse. They also filed nearly 40 letters in support from her friends and family, along with representatives of the FTX bankruptcy estate, including CEO John Ray.

The memo delves into Ellison’s personal life and history with Bankman-Fried, blaming many of her decisions on his manipulative approach to their relationship. In one instance, her attorneys allege that Bankman-Fried convinced her to get a prescription for the amphetamine Adderal, which Ellison became dependent on.

“Reflecting now, Caroline believes that this amphetamine use made her more risk-seeking, more focused on the task at hand but less thoughtful and reflective,” the attorneys write. “It narrowed her focus to completing whatever task Mr. Bankman-Fried had assigned her and left her less inclined to step back and think about whether the situation made sense.”

From crush to collapse

Once valued at over $30 billion, the rapid failure of FTX in November 2022 captured public attention thanks to its larger-than-life characters and eye-popping dollar figures. Much of the fascination focused on the relationship between the close cadre of friends in their late 20s and early 30s who ran the crypto empire, including Bankman-Fried and Ellison, many of whom dated each other. By the time of the trial, all had turned on Bankman-Fried, whose response included leaking Ellison’s private diary to the New York Times.

As the CEO of Alameda Research, Ellison played a critical role in FTX and admitted to prosecutors that she was aware—and facilitated—Bankman-Fried’s ploy to funnel billions of dollars of customer funds to his own investments, including in startups, political donations, and luxury real estate. Still, in her sentencing memo, her lawyers argue that much of her bad judgments stemmed from her long-term relationship with Bankman-Fried, which began while they were both working at the trading firm Jane Street.

They intermittently dated, including while working together at FTX—a fact that Bankman-Fried tried to conceal from his employees. In one instance, according to Ellison’s attorneys, he proposed having sex with her while dating someone else, which Ellison refused. Later, her attorneys note that Bankman-Fried denied her the same celebrity lifestyle that he enjoyed, telling her that he did not want to be seen publicly with her, including at high-profile events like the Met Gala and Super Bowl.

A spokesperson for Bankman-Fried declined to comment.

While the memo is filled with sordid details about their relationship, the attorneys also criticized the media’s fascination with her personal life, which they argue led to invasions of her privacy and led to people “hounding” Ellison’s parents and sisters, including revealing their residences on the internet. Some of the letters in the memo were filed under seal to protect the identities of people writing in her support.

In the memo, Ellison’s attorneys note that the Probation Department recommends a sentence of time served with three years of supervised release, and request a non-custodial sentence, meaning one that does not involve jail time. Her hearing is scheduled for September 24, with prosecutors expected to file their response this week.

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