NEW YORK (WIVB) – The attorneys representing Chris Collins in his insider trading case have asked the judge to sentence the former congressman to probation.

Collins will be sentenced on January 17th in New York City. He pleaded guilty to charges of conspiracy to commit securities fraud and lying to the FBI in October, and resigned from Congress on the same day. He admitted to tipping off his son, Cameron, about a drug that had failed its trial. Cameron and Stephen Zarsky, his future father-in-law, are scheduled to be sentenced in January as well.

Federal sentencing guidelines call for Chris Collins to serve between 46 and 57 months in federal prison. However in a sentencing memo filed Tuesday, Collins’ attorneys note probation officers recommended much less time than that in their pre-sentencing investigation report.

“(The U.S.) Probation (Department) recommends a substantial downward variance… with a custodial sentence of a year and a day, a term of supervised release, and a $200,000 fine,” Collins’ attorneys wrote.

They went on to request probation, citing “Chris’ advanced age, prior good and charitable acts, non-existent risk of recidivism, and acceptance of responsibility”.

Collins is 69 years old.

Under the terms of the requested probation, Collins attorneys suggested a significant term of home confinement, extensive community service, and a substantial fine.

More than 100 friends, family members, and Collins supporters wrote Judge Vernon Broderick letters on his behalf, including more than a dozen current and former members of Congress. One of his advocates is former Speaker of the House John Boehner.

“I know this experience has been mortifying for him,” wrote Boehner, who also said that he is now neighbors with Collins on Marco Island, Fla. “I continue to believe he is a good man who loves his family and his country.”