William H. Pauley, III

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person PAUL SHECHTMAN
Legal representative
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Date Event Type Description Location Actions
N/A Legal proceeding Sentencing of David Parse for his role in tax shelter-related transactions. N/A View

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This document is the final page (page 14) of a legal letter dated March 7, 2013, from attorney Paul Shechtman of Zuckerman Spaeder LLP to Judge William H. Pauley, III. The text concludes an argument regarding sentencing, specifically referencing *Gall v. United States* to argue that non-incarcerative sentences (probation) are still severe and restrictive. The letter is copied to Assistant US Attorneys Stanley J. Okula, Jr. and Nanette Davis.

Legal correspondence / court filing (page 14 of 14)
2025-11-20

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This document is a legal brief or letter to The Honorable William H. Pauley, III, discussing the case of a man named David, who was convicted of backdating transactions. It references the impact of the conviction on David's family and cites legal precedent from the United States Supreme Court and United States v. Adelson.

Legal document
2025-11-20

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This document is a page from a legal filing submitted by Zuckerman Spaeder LLP to Judge William H. Pauley, III on March 7, 2013, regarding the sentencing of David Parse. It argues for leniency, distinguishing Parse's role as a broker executing trades from those who designed the illegal tax shelters (referencing Donna Guerin and the Jenkins law firm). The document appears to be an exhibit (A-5941) filed in the later Ghislaine Maxwell case (1:20-cr-00330-AJN) in 2022.

Legal correspondence / sentencing memorandum (exhibit)
2025-11-20

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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.

Legal filing / letter to judge (sentencing memorandum excerpt)
2025-11-20

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This legal document, a letter from Zuckerman Spaeder LLP to Judge William H. Pauley, III, argues on behalf of a client named David. It contends that while David was convicted for 'backdating' transactions, the jury's acquittal on more serious tax evasion and conspiracy charges suggests they believed he was unaware of the illegality of the Jenkins tax shelter scheme itself. The letter posits that David was given comfort by the participation of major entities like Deutsche Bank and believed he was exploiting a legal 'loophole'.

Legal document
2025-11-20

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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.

Legal document
2025-11-20

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This document is page 7 of a legal filing, specifically a letter dated March 7, 2013, from the law firm Zuckerman Spaeder LLP to Judge William H. Pauley, III. The letter argues for the good character of an individual named David by citing several character reference letters from people like Charles Austerberry, Theresa Parse, and Bridget Rodgers. These letters praise David's compassionate and effective coaching style, his focus on teaching life lessons over winning, and his commitment to supporting friends in times of need.

Legal document
2025-11-20

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This document is page 6 of a legal filing (Case 1:09-cr-00581-WHP) from the law firm Zuckerman Spaeder LLP to Judge William H. Pauley, III, dated March 7, 2013. It primarily serves as a character reference for a defendant named 'David,' detailing his 15 years of volunteer work as a youth sports coach in Hinsdale and his role as a father. A footnote discusses the serious health issues of an individual named Theresa (referenced via a letter from Theresa Parse) dating back to 2008.

Legal correspondence / sentencing memorandum (excerpt)
2025-11-20

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This document is page 4 of a letter dated March 7, 2013, from the law firm Zuckerman Spaeder LLP to The Honorable William H. Pauley, III. The letter provides several character references for a broker named David, quoting former colleagues and associates who describe him as honest, diligent, and always prioritizing his clients' interests. A footnote indicates that David has been sued by taxpayers over disallowed tax shelters.

Legal document
2025-11-20

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This document is page 3 of a legal filing, likely a sentencing memorandum, addressed to Judge William H. Pauley, III. It outlines the personal and professional history of a man named David, detailing his education at the University of Michigan, his strong friendships from college, and his successful career progression through several prominent financial firms, including Touche Ross, Goldman Sachs, Kidder Peabody, and Alex Brown & Sons, from his graduation until his indictment in 2009. The document uses letters from friends to portray him as a loyal friend and generous person.

Legal document
2025-11-20

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This document is page 2 of a letter dated March 7, 2013, from the law firm Zuckerman Spaeder LLP to Judge William H. Pauley, III. It describes the strong work ethic and positive character of an individual named David, detailing his humble, blue-collar upbringing, early jobs starting at age 11, and achievements in academics and sports. The letter cites supportive statements from Bridget Rodgers and Scott Mordell to portray David in a favorable light, likely as part of a legal proceeding.

Legal document
2025-11-20

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This document is the first page of a declaration by Stephen Gillers, a legal ethics professor at NYU, filed on April 6, 2012, in the case United States v. Paul M. Daugerdas. Gillers outlines his qualifications and states he was asked to address whether attorneys for the firm Brune & Richard met their ethical obligations regarding the disclosure of a 'July 21 letter' and an investigation into 'Juror No. 1.' The document appears to be part of a larger Department of Justice release (DOJ-OGR stamp), though the specific text on this page relates to the Daugerdas tax fraud case rather than explicitly mentioning Epstein.

Legal declaration (court filing)
2025-11-20

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This document is the final page (page 14) of a legal letter dated March 7, 2013, sent by attorney Paul Shechtman of Zuckerman Spaeder LLP to Judge William H. Pauley, III. The text concludes an argument regarding sentencing, specifically utilizing a footnote citing 'Gall v. United States' to argue that non-incarcerative (probationary) sentences still constitute a significant restriction of liberty. The document was originally filed in 2013 but was later submitted as Exhibit A-5943 in the 2022 Ghislaine Maxwell case (Case 1:20-cr-00330-AJN).

Legal correspondence / court filing exhibit
2025-11-20

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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.

Legal document
2025-11-20

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This legal document, a letter from the law firm Zuckerman Spaeder LLP to Judge William H. Pauley, III dated March 7, 2013, argues for a lenient sentence for their client, David Parse. The letter contends that Parse's role was limited to that of a broker executing trades, not designing or marketing illegal tax shelters, and that the sentencing guidelines are too harsh for his level of culpability. It further notes that of all the brokers performing similar functions for the law firm Jenkins, only Parse and Craig Brubaker were prosecuted, with Parse being the only one convicted.

Legal document
2025-11-20

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This legal document, a letter from the law firm Zuckerman Spaeder LLP to Judge William H. Pauley, III, dated March 7, 2013, argues for a lower sentencing guideline for their client, Mr. Parse. The firm contends that since Mr. Parse was only convicted of three "backdating" transactions, sentencing enhancements for "sophisticated means" and "special skills" are unwarranted, as he did not design the underlying complex tax shelters. The letter provides a total loss calculation of $3,807,988 based on IRS assessments related to the transactions.

Legal document
2025-11-20

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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.

Legal document
2025-11-20

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This legal document, a page from a letter to Judge William H. Pauley, III, argues that a defendant named David was not a culpable participant in the illegal aspects of the Jenkins tax shelter scheme. The author contends that David's acquittal on conspiracy and tax evasion charges, along with his co-defendant's full acquittal, shows the jury believed David did not know the shelters were illegal. The document attributes David's belief in the shelters' legality to high-level approval from Deutsche Bank and the belief that a legal "loophole" had been found, suggesting his convictions for mail fraud and tax obstruction were solely for separate "backdating" transactions.

Legal document
2025-11-20

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This document is page 7 of a legal filing from the law firm Zuckerman Spaeder LLP to Judge William H. Pauley, III, dated March 7, 2013. It compiles excerpts from several character reference letters written in support of a man named David. The letters portray David as a compassionate and effective youth sports coach who prioritizes children's personal development and life lessons over winning, contrasting his calm approach with that of other coaches.

Legal document
2025-11-20

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This document is page 6 of a legal letter dated March 7, 2013, from the law firm Zuckerman Spaeder LLP to Judge William H. Pauley, III. The letter provides character references for a man named David, highlighting his 15 years of dedicated volunteer coaching for youth sports in his community. It includes quotes from letters by community members Phil Allen, Thomas E. Carnaghi, and John and Kathryne Maguire, all of whom praise David's commitment and positive impact. A footnote also details the serious health issues of a woman named Theresa Parse since 2008.

Legal document
2025-11-20

DOJ-OGR-00009510.jpg

This document is a page from a legal filing (dated March 7, 2013) submitted by Zuckerman Spaeder LLP to Judge William H. Pauley, III. It appears to be part of a sentencing memorandum or character reference for a defendant named 'David' (likely David Parse, based on the case number 1:09-cr-00581-WHP associated with Paul Daugerdas). The text focuses on David's family life, his marriage to Theresa Austerberry, and includes character reference quotes from his brother-in-law James Yetter and others regarding his parenting skills. The document was later filed as an exhibit in the Ghislaine Maxwell case (1:20-cr-00330-PAE) on Feb 24, 2022.

Legal correspondence / sentencing memorandum excerpt
2025-11-20

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This document is page 3 of a legal letter dated March 7, 2013, addressed to The Honorable William H. Pauley, III. It outlines the educational and professional history of an individual named David, detailing his degrees from the University of Michigan and his successful career at financial firms including Touche Ross, Goldman Sachs, and Deutsche Bank between his graduation and his 2009 indictment. The letter also includes character references from friends, Kenneth Norwick and Bridget Rodgers, highlighting his friendships and generosity.

Legal document
2025-11-20

DOJ-OGR-00009507.jpg

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).

Legal memorandum / sentencing submission
2025-11-20

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This document is the first page of a legal declaration by Stephen Gillers, a law professor and expert in legal ethics, filed on April 6, 2012, in the U.S. District Court for the Southern District of New York. Gillers outlines his extensive qualifications and states that he has been asked by the court to provide an opinion on whether the attorneys for clients named Bruce and Richard fulfilled their ethical obligations regarding the potential failure to disclose a letter and an investigation concerning 'Juror No. 1' during March, May, and July of 2011.

Legal document
2025-11-20
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