Prosecutors have asked a federal judge to sentence local real estate speculator Steven A. Madeoy to 15 years in prison, describing him as a "morally and ethically bankrupt individual, a predator of the most vicious sort."

Madeoy's attorney, Kenneth M. Robinson, said in court papers filed yesterday that the government's sentencing memorandum "reflects the viperous bite of advocates who seek more than a pound of flesh." Madeoy, 34, his father Jakey Madeoy, 70, and his brother-in-law Michael J. Friedman, 46, are to be sentenced tomorrow by U.S. District Judge Harold H. Greene for illegally obtaining more than $1.8 million in federally insured mortgages, half of which are in default.

The three men were convicted in April of racketeering, conspiracy and bribery after a seven-week trial that stemmed from a massive two-year investigation of loan fraud schemes that have cost the U.S. Department of Housing and Urban Development millions of dollars because of loan defaults.

In a 20-page sentencing memorandum filed last week, Assistant U.S. Attorneys Steven C. Tabackman and Donald J. Allison accused Steven Madeoy of "loansharking," alleging for the first time that he lent more than $800,000 to area homeowners, levying settlement charges of as much as 40 percent of the total loan.

The loans were made to "desperate homeowners" who needed a short-term solution to save their homes, but who ultimately faced foreclosure because of the loans made by Madeoy, according to the memorandum.

Steven Madeoy, prosecutors said, "wreaked havoc not only on the government, but also the numerous poor people of this city on whom he preyed."

They also asked for prison terms for Jakey Madeoy and Friedman.. Five persons who pleaded guilty in connection with the scheme have been sentenced to prison terms, one at long as 40 months, and fined as much as $100,000.

Robinson attacked the government for filing its memorandum six days before sentencing and for including allegations of criminal acts with which Madeoy was not charged.

"We cannot tread water in an ocean of allegations such as the government makes," Robinson said.

According to testimony at the trial, the loan fraud scheme centered on obtaining federally guaranteed home mortgages based on inflated real estate appraisals, which allowed Steven Madeoy and other purchasers to buy properties without putting down any money and obtain cash kickbacks from the loan proceeds.

Many of the properties were put in the names of "straw buyers" to circumvent D.C. rent control laws, according to the testimony.

Jakey Madeoy, a Veterans Administration appraiser, did many of the real estate appraisals for his son and Friedman acted as the settlement lawyer.

Sentencing, which usually occurs about six weeks after a conviction, has been delayed for the three men while Greene considered several defense motions.

One of the defense motions sought dismissal of the case because of alleged racial prejudice by the grand jury.

According to the grand jury transcript, one juror commented during the proceedings that some of the white defendants in the case had used blacks to bring in prospective purchases of the real estate in question, but that the money "as always" ended up in "white peoples' pockets."

Greene ruled that the defendants were unable to show actual prejudice, noting that the trial jury was questioned about racial prejudice and none was found.