DOJ-OGR-00009507.jpg
598 KB
Extraction Summary
4
People
3
Organizations
3
Locations
2
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal memorandum / sentencing submission
File Size:
598 KB
Summary
This document is a page from a 2013 legal memorandum filed by Zuckerman Spaeder LLP to Judge William H. Pauley, III, describing the background of a defendant named 'David' (associated with case 1:09-cr-00581). It details his blue-collar upbringing, Catholic education, history of manual labor starting at age 11, and graduation from the University of Michigan in 1984. The document appears as an exhibit (A-5931) within the later Ghislaine Maxwell case filings (1:20-cr-00330).
People (4)
| Name | Role | Context |
|---|---|---|
| David | Defendant/Subject |
Subject of the character reference; described as having a blue-collar background, attending University of Michigan.
|
| William H. Pauley, III | Judge |
Addressee of the letter; Honorable Judge.
|
| Bridget Rodgers | Supporter/Reference |
Quoted in the text regarding David's background.
|
| Scott Mordell | Supporter/Reference |
Former high school classmate quoted regarding David's leadership.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Zuckerman Spaeder LLP |
Firm submitting the document (Letterhead).
|
|
| University of Michigan |
Where David attended college and graduated in 1984.
|
|
| Detroit News |
Employer where David had a paper route at age 11.
|
Relationships (2)
Provided a character reference letter quoted in the document.
Provided a character reference letter; refers to 'our class'.
Full Extracted Text
Complete text extracted from the document (1,910 characters)
Case 1:20-cr-00330-PAE Document 166-3 Filed 02/24/22 Page 88 of 117
A-5931
Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 2 of 14
A-5931
Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 2 of 14
ZUCKERMAN SPAEDER LLP
The Honorable William H. Pauley, III
March 7, 2013
Page 2
March 7, 2013
Page 2
in their children the importance of work, education, family and respect for others. See letter of
Bridget Rodgers (“Dave comes from a blue-collar background; his dad was a mailman and his
mom was a saint”).1
Bridget Rodgers (“Dave comes from a blue-collar background; his dad was a mailman and his
mom was a saint”).1
David attended local Catholic schools, where he excelled in academics and sports.
See letter of Scott Mordell (“David was an academic, sports and social leader among our [high
school] class”). He started on the varsity basketball team as a freshman and was among the top
players in the state his senior year. Although recruited by several colleges, he chose to attend the
University of Michigan, a state school, and gave up playing organized sports.
See letter of Scott Mordell (“David was an academic, sports and social leader among our [high
school] class”). He started on the varsity basketball team as a freshman and was among the top
players in the state his senior year. Although recruited by several colleges, he chose to attend the
University of Michigan, a state school, and gave up playing organized sports.
What he did not give up was his work ethic. David got his first job at age 11,
delivering the Detroit News to his neighbors. Every day after school and on weekends, he rode
his bicycle on his route. In eighth grade, he began working part-time in a local restaurant as a
busboy (the same restaurant where his mother cleaned linens). He worked there on weekends
during the school year and 30 to 40 hours a week in the summer. The job enabled him to
purchase a used car for $600. With a car, he could drive across town to work at a famous
seafood restaurant; beginning his senior year in high school, it became his regular employer.
delivering the Detroit News to his neighbors. Every day after school and on weekends, he rode
his bicycle on his route. In eighth grade, he began working part-time in a local restaurant as a
busboy (the same restaurant where his mother cleaned linens). He worked there on weekends
during the school year and 30 to 40 hours a week in the summer. The job enabled him to
purchase a used car for $600. With a car, he could drive across town to work at a famous
seafood restaurant; beginning his senior year in high school, it became his regular employer.
David graduated from Michigan in 1984 with a bachelor’s degree in Business
Administration. He put himself through college, commuting from Ann Arbor to Detroit to work
as a waiter in the seafood restaurant. Although most of his time went to studies and work, David
Administration. He put himself through college, commuting from Ann Arbor to Detroit to work
as a waiter in the seafood restaurant. Although most of his time went to studies and work, David
_____________________
1 Letters from David’s family and supporters are attached as an appendix to this
submission.
1 Letters from David’s family and supporters are attached as an appendix to this
submission.
DOJ-OGR-00009507
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