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A picture of the beneficent Lord Black

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The document is replete with examples of Lord Black's kindness to others and it said that while Lord Black spoke in an educated and "somewhat elaborate manner" he had a common touch. He sent "care packages" to sick friends, restored faith to a woman who had turned from God and worked diligently on behalf of refugees.

At Hollinger, he made employees feel like family and offered untold support to his servants, including helping one housekeeper learn English and paying therapy costs for another one suffering depression.

"Even to people [Lord Black] did not know but who reached out to him for assistance, Mr. Black was uniformly gracious," the filing says. That included musicians, aspiring journalists, students and bankers.

The lawyers go on at length about Lord Black's devotion to Catholicism, noting that his house in Toronto has a "spare and elegant" chapel with an anteroom containing tomes on Judaism for his wife, Barbara Amiel, who is Jewish. They said Lord Black attended mass every Saturday during the four-month trial "before taking long, contemplative walks along the Chicago lake front."

There are also extensive quotes from Lord Black's autobiography, A Life in Progress, including sections about his close relationship with his father and the last conversation he had with his mother, who died in 1973 of liver cancer.

In his letter of support, journalist William Johnson credits "Conrad's vision and advocacy on [Quebec separation] with saving Canada from sinking into the devastating political and economic crisis that would have resulted from the separatists and their position emerging victorious in the 1995 period," the filing says.

But the document is devoted largely to comments from Lord Black's family.

Lady Black said her husband "always sees the best in events and people" and added that she could not have gotten through "a week of the sort of assault we have now taken for the past four years without the strength and love [Conrad] has given me."

His daughter wrote about a childhood "filled with reading, games, biking, badminton and diversions which helped an eight-year old tolerate 75 minute Latin masses."

Even his ex-wife, Joanna, "remains a staunch supporter," the filing says. His son, Jonathan, discussed the "realities he has had to endure because of the trial" and his sister-in-law, June, wrote about how Lord Black immersed himself in the "joyous problems of young people - choices of schools and jobs as well as bourgeoning relationships" always offering assistance and advice.

"He is a husband, father, friend, patron, benefactor and mentor," the filing says. "A just sentence will take account of all of those aspects of Conrad Black's character as well as the fact that for such a man, to face the loss of all he has worked for and the prospect of imprisonment has already been enormous punishment."

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IN THEIR OWN WORDS

Conrad Black's supporters

According to the filing, 'it is in the dozens upon dozens of letters submitted for Mr. Black from individuals inhabiting an astonishing breadth of stations in life, however, that the most valuable insights into his personality can be located.' Some of those comments:

"He has always been courteous and helpful - not just to friends and acquaintances of high rank but to everyone I have seen him come in contact with in the course of daily life." - Gerald Schwartz, CEO of Onyx Corp.

Conrad "always sees the best in events and people. For Conrad, the glass is always half full no matter what life dishes out for him." - Barbara Amiel Black, Lord Black's wife

Conrad Black "is gender blind in creating relationships and essentially motivated to be with and around people who he finds intellectually stimulating ... "

- Heather Reisman, CEO of the Indigo Books chain, who is described in the filing as a bookstore proprietor

Conrad's everyday life was marked by "many acts of unheralded charity, altruism and kindness." - George Jonas, journalist and author and one of Lady Black's ex-husbands

"My father sees the world through rose colored glasses and fresh eyes - no matter what problems or issues arise, he finds something positive to focus on. He sees and believes in the good in everything and everyone."

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