WARREN - A prosecutor invited a judge to view a trucker's dash camera that shows him ''rocking to the heavy-metal song 'Burn' by Rob Zombie as he plowed into the victims, traveling an astonishing 581 feet before applying his brakes.''
The invitation to Judge Andrew Logan is contained in a sentencing memorandum from assistant county prosecutor Michael Burnett, who suggests that Donald Williams Jr. serve 18 years behind bars and undergo a lifetime driver's license suspension for the triple fatal crash that claimed the lives of three Marine recruits.
Williams' attorney J. Gerald Ingram also filed his own memorandum that suggests his client serve six and a half years in prison.
Logan has scheduled Williams' sentencing for 1:30 p.m. June 27 .
The chain-reaction crash March 31, 2010, killed Michael T. Theodore Jr., 19, of Howland; Joshua A. Sherbourne, 21, of Southington; and Zachary Nolen, 19, of Newton Falls.
The three, along with another recruit and a recruiter, were headed to Cleveland to finalize their enlistment papers when they were rear-ended by the semi driven by Williams at the intersection of state Route 5 and Burnett Road in Leavittsburg.
Set for 1:30 p.m., June 27
31 years: How long he could have faced
18 years: Sentencing recommendation from prosecution
6 1/2 years: Sentencing recommendation from defense
Williams, 46, of Austintown, faces a maximum of 31 years behind bars after pleading guilty Feb. 17 to three counts of aggravated vehicular homicide, three counts of aggravated vehicular assault, three other counts of vehicular assault and possession of drugs. He remains free on bond in the meantime.
Williams, who was driving for Strimbu Trucking at the time, also has been named along with the company in a consolidated civil suit in connection to the crash. Logan has combined the wrongful death and personal injury claims in several suits.
Besides up to five years each on the aggravated vehicular homicides and aggravated vehicular assaults, Williams faces another year on the drug charge since he was found to have diazepam and nordiazepam in his system. The impairment of the drug along with recklessness were spelled out in the formal charges against the defendant.
Burnett pointed out in court that Williams did not have a prescription for the drugs and had been convicted in Mahoning County in 1989 of aggravated drug trafficking and drug abuse.
''Williams has a criminal record involving drug trafficking, drug abuse, falsification and impaired driving. He obviously has not learned from his past mistakes,'' Burnett wrote. He also pointed out that Williams lied about his criminal and driving record when he was hired at Strimbu. He had three prior convictions for operating a vehicle impaired, Burnett said.
Ingram, meanwhile, says Williams has been gainfully employed his whole life, and the prior convictions are all from when he was relatively young and related to the drugs and alcohol.
He said Williams suffered a traumatizing childhood that included a mother who was addicted to drugs and who went to prison for robbery when he was very young. His father, according to Ingram, served in the Air Force during the war in Vietnam and was shot down. He suffered from post traumatic stress disorder and unable to care for his son.
Williams grew up in foster care and was raised in a military-based facility until he was 18 years old.
Ingram said his client will never drive a truck again and hopes to gain a new vocational skill while serving prison time.