DOJ-OGR-00010194.jpg
530 KB
Extraction Summary
4
People
3
Organizations
0
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing / letter to judge (sentencing memorandum excerpt)
File Size:
530 KB
Summary
This document is a page from a legal filing by Zuckerman Spaeder LLP addressed to Judge William H. Pauley, III, regarding the sentencing of David Parse. It disputes the Probation Office's sentencing guidelines which calculated a tax loss of $1.5 billion and a prison range of 292-365 months. The document includes a significant footnote quoting a letter from Juror No. 1 (Catherine Conrad) to AUSA Okula, detailing her hesitation in convicting Parse on conspiracy charges.
People (4)
| Name | Role | Context |
|---|---|---|
| William H. Pauley, III | Judge |
Addressee of the legal letter/filing.
|
| David Parse | Defendant |
Subject of the sentencing guidelines calculation and the jury conviction discussed in the footnote.
|
| AUSA Okula | Assistant United States Attorney |
Recipient of the letter from Juror No. 1.
|
| Catherine Conrad | Juror (Juror No. 1) |
Author of the letter quoted in footnote 6 regarding jury deliberations.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Zuckerman Spaeder LLP |
Law firm submitting the document (Letterhead).
|
|
| Probation Office |
Government entity that calculated the offense level and sentencing guidelines.
|
|
| DOJ |
Department of Justice (implied by footer DOJ-OGR).
|
Timeline (1 events)
May 24, 2011
Jury deliberations where Juror No. 1 asked for clarification on 'willfully' and 'knowingly'.
Court
Catherine Conrad
David Parse (Defendant)
Relationships (2)
Conrad writes about deliberating Parse's conviction in a letter.
Juror No. 1's letter to AUSA Okula.
Key Quotes (3)
"[W]e did have qualms with Mr. David Parse. I solely held out for two days on the conspiracy charge for him..."Source
DOJ-OGR-00010194.jpg
Quote #1
"The backdating was enough for the other charges."Source
DOJ-OGR-00010194.jpg
Quote #2
"In its preliminary Report, the Probation Office calculates an offense level of 40 and a Guidelines range of 292 to 365 months."Source
DOJ-OGR-00010194.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,622 characters)
Case 1:20-cv-08138-PAE Document 1646-3 Filed 08/04/22 Page 696 of 1717
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).
DOJ-OGR-00010194
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