DOJ-OGR-00009515.jpg
526 KB
Extraction Summary
6
People
2
Organizations
0
Locations
2
Events
2
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
526 KB
Summary
This legal document, dated March 7, 2013, from the law firm Zuckerman Spaeder LLP to Judge William H. Pauley, III, argues for a lower sentencing guideline for a client. It contests the Probation Office's preliminary calculation, which suggests a 292-365 month sentence based on a $1.5 billion tax loss. To support its argument, the document cites a letter from a juror detailing the conviction of David Parse, suggesting his conviction was limited to "backdating" transactions and not a broader conspiracy.
People (6)
| Name | Role | Context |
|---|---|---|
| William H. Pauley, III | The Honorable |
The document is addressed to The Honorable William H. Pauley, III.
|
| Juror No. 1 | Juror |
Mentioned in a footnote regarding a letter written to AUSA Okula about David Parse's conviction.
|
| Okula | AUSA (Assistant United States Attorney) |
Recipient of a letter from Juror No. 1.
|
| David |
Mentioned in the context of "David's conviction" for "backdating" transactions. The context implies this is David Parse.
|
|
| David Parse | Mr. |
Subject of a juror's letter, who was part of a conspiracy charge and convicted on other charges related to backdating.
|
| Catherine Conrad |
Author of a letter dated 5/25/11, which is quoted in a footnote.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| ZUCKERMAN SPAEDER LLP | company |
The law firm that authored and sent the document, as indicated by the letterhead.
|
| Probation Office | government agency |
Mentioned as having calculated a preliminary offense level and Guidelines range in a report.
|
Timeline (2 events)
2011-05-24
A jury asked for a judge's clarification on legal terms ("willfully" and "knowingly") during deliberations regarding David Parse.
Juror No. 1
Judge
2011-05-24
David Parse was convicted on charges related to backdating, though the jury did not convict on the conspiracy charge.
Relationships (2)
The juror describes their internal conflict during deliberations, wanting to convict David Parse on a conspiracy charge but ultimately conceding, while still believing he was a key element in the scheme and that his conviction on backdating charges was sufficient.
Juror No. 1 wrote a letter to AUSA Okula following the trial to explain the jury's deliberations.
Key Quotes (1)
"[W]e did have qualms with Mr. David Parse. I solely held out for two days on the conspiracy charge for him -- I wanted to convict 100% (not only on that charge) -- but on Tuesday, May 24, 2011, we had asked for the Judge’s clarification of “willfully” and “knowingly,” I believe, and I had to throw in the towel. I did fight the good fight, however, and I felt that Mr. Parse played his integral part and was a key element in the elaborate scheme/scam. The backdating was enough for the other charges."Source
— Juror No. 1
(Quoted from a letter by Catherine Conrad dated 5/25/11, explaining the juror's perspective on the deliberations and conviction of David Parse.)
DOJ-OGR-00009515.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (1,618 characters)
Case 1:20-cr-00330-PAE Document 16166320 Filed 02/24/22 Page 96 of 117
A-5939
Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 10 of 14
A-5939
Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 10 of 14
ZUCKERMAN SPAEDER LLP
The Honorable William H. Pauley, III
March 7, 2013
Page 10
March 7, 2013
Page 10
losses in the prior year (e.g., 2001). The prosecution focused on those transactions in its summations, as did the jury in its deliberations.⁶
E. Guidelines Calculation
In its preliminary Report, the Probation Office calculates an offense level of 40 and a Guidelines range of 292 to 365 months. It assumes a tax loss amount of $1.5 billion and adds “points” for sophisticated means (§ 2T1.1(b)(2)) and special skill (§ 3B1.3). We have written to Probation and asked it to reconsider that calculation. Under the Court’s rules, its final Report is due after ours, and so we summarize here our argument that the Guidelines range should be far lower than where Probation has preliminarily put it.
⁶ Juror No. 1’s letter to AUSA Okula goes far to show that David’s conviction was only for the “backdating” transactions:
[W]e did have qualms with Mr. David Parse. I solely held out for two days on the conspiracy charge for him -- I wanted to convict 100% (not only on that charge) -- but on Tuesday, May 24, 2011, we had asked for the Judge’s clarification of “willfully” and “knowingly,” I believe, and I had to throw in the towel. I did fight the good fight, however, and I felt that Mr. Parse played his integral part and was a key element in the elaborate scheme/scam. The backdating was enough for the other charges.
Letter of Catherine Conrad 5/25/11 (emphasis added).
[W]e did have qualms with Mr. David Parse. I solely held out for two days on the conspiracy charge for him -- I wanted to convict 100% (not only on that charge) -- but on Tuesday, May 24, 2011, we had asked for the Judge’s clarification of “willfully” and “knowingly,” I believe, and I had to throw in the towel. I did fight the good fight, however, and I felt that Mr. Parse played his integral part and was a key element in the elaborate scheme/scam. The backdating was enough for the other charges.
Letter of Catherine Conrad 5/25/11 (emphasis added).
DOJ-OGR-00009515
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