Rajaratnam, 54, was the most prominent defendant among 21 people charged in the government crackdown on insider trading on Wall Street, which involved companies such as as IBP Corp and McKinsey & Co. The government sting involved a 9-month wiretap of his phone conversations, which they say showed Rajaratnam cooly and blatently trading on insider information.
"Violating the law was of no moment to him. What mattered was not getting caught," the filing reads.
Lawyers for Rajaratnam asked for a sentencing "substantially below" the government guidlines, saying it would constitute a death sentence in light of "his failing health and the unique constellation of ailments ravaging his body."
The memo filed on his behalf Tuesday night cited letters from family, business colleagues and a childhood friend from his native Sri Lanka, all attesting to his philanthropic character. One letter describes Rajaratnam as a boy, helping families with chores in exchange for their donations to charitable causes.
"He has been not only a law-abiding, tax-paying, productive member of society, but an extraordinary force for good, donating over $45 million of his personal wealth to charitable causes here and abroad. Whereas the crimes of his conviction had not a single identifiable victim, his charitable acts enriched countless lives - and surely saved more than a few."
While his lawyers acknowledged the seriousness of the convictions, they claimed government and media "unfairly and inaccurately portray" Rajaratnam, making him into the "poster child for every wrongful act that has ever been associated with Wall Street."
U.S. District Judge Richard Holwell will sentence Rajaratnam on Sept. 27 and is not obligated to follow the federal recommendation.