515 results for "2013"
Page 9 of 21
DOJ-OGR-00009527.jpg
...AMENDED SENTENCING MEMORANDUM OF THE
UNITED STATES REGARDING DEFENDANT DAVID PARSE
The United States respectfully submits this memorandum for the Court’s consideration in
connection with the sentencing of defendant David Parse (““Parse” or “the defendant’), which is
scheduled for March 22, 2013 at 2:30 p.m.
Preliminary Statement...
DOJ-OGR-00000280.jpg
Case 1:19-cr-00490-RMB Document6 Filed 07/11/19 Page 7 of 16
that was unsealed and became public in July 2013, specifically noted that “a number of districts
outside the Southern District of Florida (e.g., the Southern District of New York and the District
of New...
DOJ-OGR-00021909.jpg
...Beginning in approximately 2013, THOMAS was assigned to work as a
DOJ-OGR-00021909
DOJ-OGR-00005663.jpg
...Representatives David Cicilline and James Langevin (Rhode Island)
Rhode Island Legislative Advocacy
09/2013 — 02/ 2014
2004 - present
Special Jomt Commission to Study the Integration of Primary Care and Behavioral
Health, Co-Chaired by Senator Joshua Miller and Representative David Bennett,
Commission Member.
Advocacy regarding legislation:
The increased oversight of...
DOJ-OGR-00006625.jpg
...Representatives David Cicilline and James Langevin (Rhode Island)
Rhode Island Legislative Advocacy
09/2013 — 02/ 2014
2004 - present
Special Jomt Commission to Study the Integration of Primary Care and Behavioral
Health, Co-Chaired by Senator Joshua Miller and Representative David Bennett,
Commission Member.
Advocacy regarding legislation:
The increased oversight of...
DOJ-OGR-00021055.jpg
...United States,
724 F.3d 150 (1st Cir, 2013)... ceeccccnccesceeeeteeeeeeceneeeeeeceeneeenaeeneeeeeeatens 67, 72
Samra v. Shaheen Bus. & Inv. Grp., Inc.,
355 F. Supp. 2d 483 (D.D.C. 2005)... eccceeneeeeteeeeeeeceteeeeaeeceeneeeaeeeneeeenaeees 27
Santobello v. New York,
92S. Ct. 495 (1971)... eeccececcecesceeeeeeeeseeeeeeeceeeseaeeceaeeeeaaeceeneeeeaeeeeeeeenaeees 13,19
Smith v. City of Jackson, Miss.,
S44 U.S...
DOJ-OGR-00005913.jpg
...In a survey of Swiss child services,
Maier, Mohler-Kuo, Landholt, Schnyder, and Jud (2013) fur-
ther found 2.68 cases per 1,000 of CSA disclosures, while in a
recent comprehensive review McElvaney (2015) details the
high prevalence of delayed, partial, and nondisclosures in
childhood indicating a persistent trend...
DOJ-OGR-00006838.jpg
...In a survey of Swiss child services,
Maier, Mohler-Kuo, Landholt, Schnyder, and Jud (2013) fur-
ther found 2.68 cases per 1,000 of CSA disclosures, while in a
recent comprehensive review McElvaney (2015) details the
high prevalence of delayed, partial, and nondisclosures in
childhood indicating a persistent trend...
DOJ-OGR-00011993.jpg
...2007 through 2013.
Q. For today's purposes, I'm going to refer to that man as
Matt. Will you do that?
A. Yes.
Q. While you were together, did you ever tell Matt that you'd
been sexually abused by Maxwell and Epstein?
A. Yes.
Q. Why did you...
DOJ-OGR-00017583.jpg
...2007 through 2013.
Q. For today's purposes, I'm going to refer to that man as
Matt. Will you do that?
A. Yes.
Q. While you were together, did you ever tell Matt that you'd
been sexually abused by Maxwell and Epstein?
A. Yes.
Q. Why did you...
DOJ-OGR-00007842.jpg
...JDL Services Inc. — Enrolled Agent
June 2013 - Present
Conducted confidential investigations in conjunction with Kostelanetz & Fink LLP.
Conducted confidential investigations in conjunction with Baker Tilly Virchow
Krause, LLP.
Conducted confidential investigations in conjunction with B2B Investigations Inc.
Represented clients at IRS Audits with Revenue Agents involving complex
income tax issues...
DOJ-OGR-00000335.jpg
...645, 2013 WL 12131300, at *7 (D. Utah
Aug. 27, 2013); United States v. Cohen, No. C 10-00547, 2010 WL 5387757, at *9 n.11 (N.D.
Cal. Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United
States v. Stroh...
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...government need not prove ... that the unlawful sexual activity
actually took place.” U.S. v. Vargas-Cordon, 733 F.3d 366, 375 (2d Cir. 2013).
Thus, Counts Three and Four should have been dismissed.
However, to save Counts Three and Four from dismissal, the court rejected
this categorical approach altogether...
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...the
juror’s dishonesty, and (3) the juror’s motives for lying. See, Sampson v. United
States, 724 F.3d 150, 166 (1* Cir. 2013).
Here, Juror 50’s undisclosed experience was strikingly similar to the
experiences described by the witnesses at trial. Juror 50 was a victim of childhood...
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...S.,
865 F.3d 48 (2d Cir. 2017) oc eccceccceccnceeeceeceeeeeececeeeeeecaeeeeeeeesaeeneaneseeeeeeas 49, 50
Young v. U.S.,
953 F. Supp. 2d 1049 (D.S.D. 2013) oo. ceecceesseceeneeceteeeeeeceeeeeeaeeeeeeeenaeees 21
Ziglar v. Abbasi,
137 S. Ct. 1843 (2017)... ceeccccenceesnceceseeeesaeceeeeesaeeeeaeeceeeseaeeseeneeeaeeeeaeeesaeens 24
Statutes & Other Authorities:
ULS. Const. amend. VI cee ceccceecseceseeeesseeeseeeceseeseaeeceneeesaeceeneeccaeeseaeeceeeeeaaeseeneeeaaes 63
8 USC...
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...Pauley, III
March 7, 2013
Page 11
Our lower Guidelines calculation begins from the premise that Mr. Parse was
convicted only of the three “backdating” transactions. If that is so, then the proper loss
calculation is this:
Coleman $2.738,630
Blair $ 470,035
Aronofft $ 536,770
Toporek h _ '62...
DOJ-OGR-00021591.jpg
...Smith, a Ninth Circuit case from 2013, 719 F.3d 1120. That
3 case explains 2G1.3(a) base offense level and the undue
4 influence enhancement "serve unique purposes under th
5 Guidelines."
6 The defense argues that because th nhancement
7 applies only if undue influence was exerted...
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...Pauley, Ill
March 7, 2013
Page 3
enjoyed his college years immensely, and many of his closest friends are Michigan classmates.
To this day, he “tailgates” with friends before Michigan football games and donates generously
to the school. See letter of Kenneth Norwick (our “tailgate [group] ... has become like an...
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...any records[1] documents, files,
communications, memoranda, orders, agreements and/or instructions
relating to or referring to Epstein that were created from November 1,
2013 to November 6, 2014, and were prepared received, transmitted,
collected, and/or maintained by the U.S. Customs and Border Protection,
Department of Homeland Security...
DOJ-OGR-00005930.jpg
...Interviews were the main data collection method with a
few exceptions using survey designs (1.e., Easton, 2013; Kogan,
2004; Smith et al., 2000) and case file reviews (i.¢., Collings
et al., 2005; Goodman-Brown et al., 2003). Results show a clear
trend toward increased likelihood of disclosure in older...
DOJ-OGR-00006855.jpg
...Interviews were the main data collection method with a
few exceptions using survey designs (1.e., Easton, 2013; Kogan,
2004; Smith et al., 2000) and case file reviews (i.¢., Collings
et al., 2005; Goodman-Brown et al., 2003). Results show a clear
trend toward increased likelihood of disclosure in older...
DOJ-OGR-00021037.jpg
...530
22 (2013). In that case, a sentencing court must -- in the case
23 of a higher range at the time of sentencing than in place at
24 the time of the offense, in that case the sentencing court must
25 apply the guidelines in effect when the offense was...
DOJ-OGR-00010195.jpg
...Pauley, III
March 7, 2013
Page 11
Our lower Guidelines calculation begins from the premise that Mr. Parse was
convicted only of the three “backdating” transactions. If that is so, then the proper loss
calculation is this:
Coleman $2.738,630
Blair $ 470,035
Aronofft $ 536,770
Toporek h _ '62...
DOJ-OGR-00000138.tif
...need not appear there unless their omission
would seriously prejudice the defendant. See United
States v. Stringer, 730 F.3d 120, 127 (2d Cir. 2013);
United States v. Kidd, 386 F. Supp. 3d 364, 369
(S.D.N.Y. 2019). Maxwell likely knows the identity of
the alleged victims described...
DOJ-OGR-00010187.jpg
...Pauley, Ill
March 7, 2013
Page 3
enjoyed his college years immensely, and many of his closest friends are Michigan classmates.
To this day, he “tailgates” with friends before Michigan football games and donates generously
to the school. See letter of Kenneth Norwick (our “tailgate [group] ... has become like an...
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