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596 KB
Extraction Summary
6
People
2
Organizations
1
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
596 KB
Summary
This document is a legal filing from the law firm Zuckerman Spaeder LLP to Judge William H. Pauley, III, dated March 7, 2013. It serves as a sentencing memorandum for their client, David Parse, arguing for a non-incarcerative sentence following his conviction for involvement in backdating transactions. The letter emphasizes the significant personal, professional, and familial suffering Parse has endured since the investigation began in 2004 and cites legal precedents to support a lenient, individualized sentence.
People (6)
| Name | Role | Context |
|---|---|---|
| William H. Pauley, III | The Honorable |
The document is addressed to him, indicating he is likely the judge in the case.
|
| David Parse | Defendant |
The subject of the document, convicted for involvement in backdating transactions. The letter argues for a lenient se...
|
| Theresa Parse | Wife of David Parse |
Mentioned as the author of a letter describing the family's hardship. Referred to as David's wife whose health has su...
|
| Jenkins |
Mentioned in the context of the "Jenkins scheme," suggesting involvement in the underlying criminal conduct.
|
|
| Adelson | Party in a legal case |
Mentioned in the legal citation "United States v. Adelson".
|
| Koon | Party in a legal case |
Mentioned in the legal citation "Koon v. United States".
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| ZUCKERMAN SPAEDER LLP | Law firm |
The law firm that authored and sent this document on behalf of their client, David Parse.
|
| United States Supreme Court | Government agency |
Cited as a legal authority regarding sentencing traditions.
|
Timeline (2 events)
A jury convicted David Parse for his involvement in three backdating transactions.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in a legal citation (Southern District of New York), indicating the jurisdiction of a cited case.
|
Relationships (1)
The document refers to Theresa Parse as David's wife ("His wife’s health has suffered") and quotes from her letter about their three sons.
Key Quotes (3)
"our lives [have] essentially [been] placed on hold, as we try to raise our three sons in a safe and secure environment"Source
— Theresa Parse
(Quoted from a letter by Theresa Parse to describe the family's hardship.)
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Quote #1
"uniform and constant . . . tradition for the sentencing judge [is] to consider every convicted person as an individual and every case as a unique study in the human failings that sometimes mitigate, sometimes magnify, the crime and the punishment to ensue."Source
— United States Supreme Court
(A quote from the Supreme Court's decision in Koon v. United States, used to argue for individualized sentencing.)
DOJ-OGR-00009518.jpg
Quote #2
"if ever a man is to receive credit for the good he"Source
DOJ-OGR-00009518.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,909 characters)
Case 1:20-cr-00330-PAE Document 16166320 Filed 02/24/22 Page 99 of 117
A-5942
Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 13 of 14
A-5942
Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 13 of 14
ZUCKERMAN SPAEDER LLP
The Honorable William H. Pauley, III
March 7, 2013
Page 13
March 7, 2013
Page 13
As noted above, we believe that the jury convicted David for his involvement in three backdating transactions from which he barely profited. He has already suffered greatly for that conduct. Since 2004, when the criminal investigation commenced, this matter has hung over him. His once-thriving brokerage business has collapsed. His wife’s health has suffered. See supra n.3. His children have felt the sting of comments from others who have learned of David’s conviction. And the stigma of the conviction haunts David, especially because it is antithetical to the values with which he was raised. See letter of Theresa Parse (“our lives [have] essentially [been] placed on hold, as we try to raise our three sons in a safe and secure environment”).
More than 15 years ago, the United States Supreme Court reminded that the “uniform and constant . . . tradition for the sentencing judge [is] to consider every convicted person as an individual and every case as a unique study in the human failings that sometimes mitigate, sometimes magnify, the crime and the punishment to ensue.” Koon v. United States, 518 U.S. 81, 113 (1996). In this submission, we have tried to show that David Parse is a fundamentally decent man. He believes in family, hard work, helping others, and being actively involved in community. The conduct for which he was convicted, we believe, was at the periphery of the Jenkins scheme. On this record, we respectfully submit that a non-incarcerative sentence would be just. It would not diminish respect for the law. See United States v. Adelson, 441 F.Supp.2d 506, 513-14 (S.D.N.Y. 2006)(“if ever a man is to receive credit for the good he
DOJ-OGR-00009518
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