DOJ-OGR-00010192.jpg
609 KB
Extraction Summary
8
People
3
Organizations
2
Locations
6
Events
6
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
609 KB
Summary
This document is page 8 of a legal filing, likely a sentencing memorandum, dated March 7, 2013, from the law firm Zuckerman Spaeder LLP to Judge William H. Pauley, III. It presents character evidence for a defendant named 'David' (or 'Dave'), citing letters from friends (James Yetter, Andrew Miller, Thomas Carnaghi, Kenneth Norwick) who describe his selfless and extensive support during their personal family crises. The document contrasts this positive character with the 'Instant Offense,' which involved a relationship David had with Paul Daugerdas starting in 1998, and mentions related activities by broker Jason Shih in the early 1990s.
People (8)
| Name | Role | Context |
|---|---|---|
| William H. Pauley, III | The Honorable |
The document is addressed to The Honorable William H. Pauley, III.
|
| Dave | Subject of the document |
Referred to as 'Dave' and 'David', the document describes his supportive actions towards friends in crisis.
|
| James Yetter | Friend of Dave |
Wrote a letter describing how Dave flew from Chicago to support him when his friend's daughter was on her death bed.
|
| Andrew Miller | Friend of David |
Wrote a letter stating David was there to counsel and encourage him when his son was diagnosed with a mental illness.
|
| Thomas Carnaghi | Friend of David |
Wrote a letter describing how David drove from Chicago to support him and his family for over three weeks after his d...
|
| Kenneth Norwick | Friend of Dave |
Author of a letter quoted as saying, “Dave is a giver, not a taker; if you need some help, he is the friend you can c...
|
| Paul Daugerdas |
Mentioned as someone David met in 1998 and who had a relationship with Deutsche Bank.
|
|
| Jason Shih | Broker |
A broker in Alex. Brown’s San Francisco office in the early 1990's who executed bond shorts for Daugerdas' clients an...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| ZUCKERMAN SPAEDER LLP | law firm |
Appears in the letterhead of the document.
|
| Deutsche Bank | company |
Mentioned as having a relationship with Paul Daugerdas that began before 1998.
|
| Alex. Brown | company |
The company where Jason Shih worked as a broker in its San Francisco office.
|
Timeline (6 events)
Dave flew from Chicago to provide support to James Yetter when a friend's daughter was on her death bed.
Chicago
David provided counsel and encouragement to Andrew Miller when his son was diagnosed and hospitalized with a mental illness.
David
Andrew Miller
David drove from Chicago to spend time with Thomas Carnaghi and his family for over three weeks after Carnaghi's 12-year-old daughter had a brain aneurysm burst.
Chicago
David
Thomas Carnaghi
early 1990's
Jason Shih, a broker at Alex. Brown's San Francisco office, began executing bond shorts for Paul Daugerdas' clients.
San Francisco
Locations (2)
| Location | Context |
|---|---|
|
Dave/David flew from or drove from Chicago on two separate occasions to support friends. Jason Shih was transferred t...
|
|
|
Location of the Alex. Brown office where Jason Shih worked.
|
Relationships (6)
James Yetter wrote a letter in support of Dave, describing him as a supportive friend during a difficult time.
Andrew Miller wrote a letter describing how David provided counsel and encouragement during a family crisis.
Thomas Carnaghi wrote a letter detailing David's extensive, daily support for over three weeks during a family medical emergency.
Kenneth Norwick wrote a letter describing Dave as a reliable and giving friend.
The document states that David met Paul Daugerdas in 1998 and mentions their relationship in the context of the 'Instant Offense'.
Jason Shih was a broker who 'began executing bond shorts for Daugerdas’ clients'.
Key Quotes (5)
"[w]hen our friend’s daughter was on her death bed, Dave . . . flew in from Chicago . . . to provide support"Source
— James Yetter
(From a letter written by James Yetter describing Dave's supportive actions.)
DOJ-OGR-00010192.jpg
Quote #1
"when my son was diagnosed and hospitalized with a mental illness . . . , David was there to . . . counsel and encourage me"Source
— Andrew Miller
(From a letter written by Andrew Miller about David's support during a family crisis.)
DOJ-OGR-00010192.jpg
Quote #2
"my then 12 year old daughter had a brain aneurysm burst . . . [David] drove in from Chicago to spend time with me and my family; he spoke with me every day during the three plus weeks of this ordeal"Source
— Thomas Carnaghi
(From a letter by Thomas Carnaghi detailing David's extensive support after a family medical emergency.)
DOJ-OGR-00010192.jpg
Quote #3
"Dave is a giver, not a taker; if you need some help, he is the friend you can call."Source
— Kenneth Norwick
(A quote from a letter by Kenneth Norwick summarizing Dave's character.)
DOJ-OGR-00010192.jpg
Quote #4
"detached acts of charity . . . [but were] in a very real way, hands-on personal sacrifices, which have had a . . . positive impact on the lives of others"Source
— United States v. Cooper, 394 F.3d 172, 177 (3d Cir. 2005)
(A legal citation used to argue that the defendant's actions were meaningful personal sacrifices, not just simple charity.)
DOJ-OGR-00010192.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (1,876 characters)
Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 8 of 14
A-5937
A-5937
ZUCKERMAN SPAEDER LLP
The Honorable William H. Pauley, III
March 7, 2013
Page 8
March 7, 2013
Page 8
horrific birth defects, Dave cried openly with us” and discussed the “moral, ethical and emotional dilemmas this raised”); letter of James Yetter (“[w]hen our friend’s daughter was on her death bed, Dave . . . flew in from Chicago . . . to provide support”); letter of Andrew Miller (“when my son was diagnosed and hospitalized with a mental illness . . . , David was there to . . . counsel and encourage me”); letter of Thomas Carnaghi (when “my then 12 year old daughter had a brain aneurysm burst . . . [David] drove in from Chicago to spend time with me and my family; he spoke with me every day during the three plus weeks of this ordeal”). As one friend puts it, “Dave is a giver, not a taker; if you need some help, he is the friend you can call.” Letter of Kenneth Norwick.
Notably, David’s good deeds have involved his time and effort and not his money. Nor has he sought recognition for what he has done. Just the opposite is true: he has been reluctant to ask others to write on his behalf because asking for something in return has never been his way. See United States v. Cooper, 394 F.3d 172, 177 (3d Cir. 2005)(noting that defendant’s actions were not “detached acts of charity . . . [but were] in a very real way, hands-on personal sacrifices, which have had a . . . positive impact on the lives of others”).
D. The Instant Offense
As noted above, David met Paul Daugerdas in 1998, but the relationship between Deutsche Bank and Daugerdas began earlier. In the early 1990’s, Jason Shih was one of a group of brokers in Alex. Brown’s San Francisco office, who began executing bond shorts for Daugerdas’ clients. When Shih was transferred to Chicago to supervise the office, he continued
DOJ-OGR-00010192
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