NEW YORK (AP) — An ex-U.S. congressman is humbled and remorseful after pleading guilty to conspiracy in an insider trading scheme and should face no time behind bars, his lawyers argued in court papers Tuesday.

The presentence submission on behalf of 69-year-old Christopher Collins was filed in Manhattan federal court, where the Republican is scheduled to be sentenced on Jan. 17.

Collins pleaded guilty in October to conspiracy to commit securities fraud and lying to law enforcement officials. According to a plea agreement he signed, Collins agreed that federal sentencing guidelines call for a sentence of nearly four to five years in prison, but the actual sentence is up to a judge.

“Chris comes before the Court humbled, penitent, and remorseful,” the lawyers wrote. “The public humiliation will follow Chris and mar him for the rest of his life.”

The lawyers said Collins, a Republican who was one of the earliest supporters of President Donald Trump, should not go to prison because of his contrition, advanced age, good charitable works and because there’s no chance he’ll commit more crimes.

Collins had represented western New York since his election to the 27th Congressional District of New York in 2012.

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His lawyers cited over 100 letters written to the judge on his behalf including from over a dozen current and former members of Congress, including former House Speaker John Boehner.

The lawyers said an appropriate sentence would be probation with significant home confinement, extensive community service and a substantial fine.

The guilty plea by Collins came after he was charged with leaking information about a biopharmaceutical company so his son and friends could avoid $800,000 in stock losses before announcement that a drug trial failure caused the stock price to plunge 92%.

An indictment said Collins was attending the Congressional Picnic at the White House on June 22, 2017, when he received an email from the chief executive of Innate Immunotherapeutics Ltd., a biotechnology company headquartered in Sydney, Australia, with offices in Auckland, New Zealand.

At the time, Collins sat on the company board and was its largest shareholder, with nearly 17% of its shares.

Collins responded to the email saying: “Wow. Makes no sense. How are these results even possible???” the indictment said.

It said he then called his son, Cameron Collins, and, after several missed calls, they spoke for more than six minutes.

Cameron Collins has also pleaded guilty and faces sentencing later this month.