"A sentence of time served, probation, work release, or house arrest would ensure that Msgr. Lynn can still use his priestly gifts to improve the lives of those around him," lawyers Thomas Bergstrom and Jeffrey Lindy said in their filing.
Lynn, a longtime aide to the late Cardinal Anthony J. Bevilacqua, faces up to seven years in state prison when he is sentenced Tuesday by Common Pleas Court Judge M. Teresa Sarmina.
Prosecutors from the office of District Attorney Seth Williams have pledged to argue for the maximum term.
They are expected to outline their reasons in a memo to the judge Friday, but have previously portrayed Lynn as a critical church administrator who helped conceal and protect priests who sexually abused children. Nearly 20 victims of clergy sex abuse testified at Lynn's landmark trial, and prosecutors have asked to include statements from some at his sentencing.
Lynn's lawyers said they had submitted "several hundred" letters from his supporters, including parishioners at St. Joseph, the Downingtown parish where Lynn served as pastor from 2004 until his arrest last year.
Lynn has been jailed without bail since his June 22 conviction. His lawyers said a lengthy state prison term would serve no purpose and would instead "be merely cruel and unusual."
His three-month trial marked the first for a Catholic Church official charged with covering up or enabling sex abuse by priests. As secretary for clergy between 1992 and 2004, Lynn recommended assignments for archdiocesan priests and investigated complaints of misconduct against them, including child sex-abuse.
The jury found him guilty of child endangerment for not removing Edward Avery, a onetime parish priest, from active ministry in the mid-1990s after learning Avery had once molested a teen.
Avery sexually assaulted a 10-year-old altar boy at a Northeast Philadelphia parish in 1999. He pleaded guilty to the attack this year and is serving 2½ to five years in state prison.
The jury acquitted Lynn of conspiracy and another endangerment count, and deadlocked on charges against his codefendant, former parish priest James J. Brennan.
In their memo, Bergstrom and Lindy renewed their contention that Lynn was following recommendations of psychologists who evaluated and treated Avery after he was accused of abusing a teen in the 1970s.
Lynn then allowed Avery to live at St. Jerome parish, restricted his work to a hospital chaplaincy, and set up an "aftercare" team to monitor him.
"The extent to which Msgr. Lynn worked to neutralize any danger that Avery posed cannot be overlooked in determining the severity of his sentence," the motion states. "Msgr. Lynn did not suspect, and had many valid reasons not to suspect, that Avery was anything but rehabilitated."
Bergstrom and Lindy, whose fees were paid by the archdiocese because the allegations involved Lynn's job, have vowed appeals on several fronts.
Among other things, they contend that prosecutors misapplied state child-endangerment laws and that the judge erred by allowing jurors to hear evidence about area priests who molested children years or decades before Lynn was clergy secretary.
The lawyers noted that the case put an unprecedented spotlight on the 61-year-old priest. But they said the scrutiny began a decade ago and intensified after a 2005 grand jury report into clergy-sex abuse in Philadelphia.
"To say that Msgr. Lynn has not adopted and internalized the lessons of the grand jury and his subsequent trial would be absurd," Bergstrom and Lindy wrote. "The last 10 years of his life were a time of reflection, penance, and rehabilitation."
Advocates for abuse victims, meanwhile, called for a long prison term.
"Lynn does pose a threat to public safety," said a statement released by the Survivors Network of Those Abused by Priests (SNAP). "Behind bars, he can't shred evidence, intimidate victims, discredit whistle-blowers, threaten witnesses, deceive parishioners, fabricate alibis, or take any of the other steps Catholic officials take to keep clergy sex crimes hidden."
Contact John P. Martin at 215-854-4774 at email@example.com, or @JPMartinInky on Twitter.
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