Download - Curran Sentencing Hearing
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
Case No. 12-80206-CR-RYSKAMP
UNITED STATES OF AMERICA,) )
Plaintiff, ) ) -v- ) ) MARY ESTELLE CURRAN, ) )
Defendant. ) West Palm Beach, Florida ) April 25, 2013 _________________________) 1:24 p.m.
TRANSCRIPT OF SENTENCING PROCEEDINGS
BEFORE THE HONORABLE KENNETH L. RYSKAMP
U.S. SENIOR DISTRICT JUDGE
Appearances:
For the Government: MARK F. DALY
US DEPARTMENT OF JUSTICE TAX DIVISION 601 D Street NW, Room 7334 Washington, DC 20579
For the Defendant: BLACK SREBNICK KORNSPAN & STUMPF
BY: ROY BLACK, ESQ. 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131
Reporter: Karl Shires, RPR, FCRR (561) 514-3728 Official Court Reporter
701 Clematis Street, Suite 258 West Palm Beach, Florida 33401
STENOGRAPHICALLY RECORDED COMPUTER-AIDED TRANSCRIPT
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(Call to Order of the Court.)
THE COURT: You may be seated.
Good afternoon. First case will be United States
versus Curran.
Counsel state their appearance, please.
MR DALY: Your Honor, Mark Daly, Senior Litigation
Counsel, Tax Division of the US Department of Justice. With me
is Assistant United States Thomas Lanigan and Special Agent
Scott Johnson of the IRS.
THE COURT: All right.
MR. BLACK: Good afternoon, Your Honor. Roy Black,
Nathan Hoffman, and Jackie Perczek on behalf of Mrs. Curran,
who is here as well.
THE COURT: Okay. You've received a copy of the
presentence report and reviewed it with your client?
MR. BLACK: Yes, sir.
THE COURT: And there are no errors, omissions, or
corrections?
MR. BLACK: No, sir.
THE COURT: All right. You may proceed.
MR. BLACK: Your Honor, we have no witnesses to
present. We've sent you our sentencing memorandum.
THE COURT: I have read it.
MR. BLACK: And we have attached all of the letters.
All that I intended to do was make some short remarks and
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proceed to the sentencing.
THE COURT: All right. I'll hear from you at this
time.
MR. BLACK: Thank you, Your Honor.
Mrs. Curran accepts full responsibility for these
offenses that she's pled guilty to. She blames nobody but
herself for being in this position, about being charged and
being subjected to sentencing before the Court today.
However, we believe that there are mitigating
circumstances that make her case different than virtually all
of the others who were prosecuted or not prosecuted under
similar circumstances as her with these offshore accounts, and
we believe that she has shown an extraordinary acceptance of
responsibility.
And, Your Honor, to go through just -- I'm not going
to go through the same things we wrote in our sentencing
memorandum, but I do want to highlight a couple of issues.
First is that this is a woman who was unsophisticated
in financial matters, had no training in finance or taxes or
handling even her own personal accounts. For the first 30
years of her marriage she did not even see the monthly bank
statements. Everything was handled by her husband Mortimer,
Senior, who was a financial analyst, an investment banker, a
man who was very well versed in finances, and he's the one who
handled all of their accounts.
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She did not work outside the house at all except she
spent her life in volunteer work. I mean, she worked at
hospitals, at thrift stores, at soup kitchens, at
rehabilitation centers working with children, working with the
disabled. That was her entire life until her husband got sick
and died in the year 2000. And that's when she then learned
about the extent of their finances and learned about these
accounts.
The accounts that are in question were established
with funds that her husband inherited from his aunt who lived
in Monte Carlo and died and left part of her estate to him. It
was not funds that were ever in the United States. She was not
a US taxpayer. She was a citizen and I think she was English
living in Monte Carlo, and there were no tax consequences of
this money.
However, her husband left the money in Europe and it
grew from what was not a large amount into a very significant
amount of money. However, there was never any deposits put
into this account by her husband or after his death by
Mrs. Curran. Whatever money was there was left there, and
that's how the funds grew. And she had nothing to do with the
creation of the accounts, of depositing money into it and
growing these accounts. But she did inherit these accounts.
At his death in the year 2000 she inherited the accounts along
with other funds from her late husband.
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And this is where she made the mistakes. You know, we
all make mistakes in our lives and we hope that we're not
judged but just on our mistakes but we're judged on how we
handle those mistakes. And her mistake was that when she
inherited these accounts and got possession of them, or at
least a beneficial interest in them, she did not handle it
correctly, did not advise her US lawyers or US accountants, and
had the European bankers, accountants and lawyers handle it.
So there's no question that's where her mistakes were in not
reporting the accounts when she inherited them.
However, she tried to rectify that mistake. In the
year 2000 she wanted to make a voluntary disclosure of all the
funds in any of these accounts. On her own she contacted the
bankers in Europe and asked how she could disclose this. They
recommended that she obtain a tax lawyer in the United States
to do this.
She then retained a tax lawyer, gave him all of the
information, more than sufficient, to make the voluntary
disclosure according to the Internal Revenue Service programs
that were available at the time. This is before the offshore
voluntary disclosure programs were created. So she was going
to make a regular voluntary disclosure to the IRS.
Unfortunately, he waited too long, over a month, and
during that period of time UBS, the bank in question, gave the
names of 250 people to the Internal Revenue Service. And by
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the time her voluntary disclosure came in, they had already had
her name for some three to four weeks. And under the rules of
the Internal Revenue Service if they have your name before you
make the voluntary disclosure, you are not eligible for their
program.
So even though she tried to do a voluntary disclosure
and her voluntary disclosure was filed seven days before the
first amnesty program was put into effect by the Internal
Revenue Service, her application was denied. And she was not
able to because of that obtain any benefit for attempting to
disclose it or any benefit from the three voluntary offshore
disclosure funds that were thereafter created by the Internal
Revenue Service.
UBS for some reason reported 285 people out of the
some 50,000 that had accounts with them, and she was one of
those 250. And, of course, this caused her to be treated far
differently than the overwhelming majority of people. And her
report was seven days before the first offshore voluntary
program went into effect.
So 38,000 people went through the three offshore
voluntary disclosure programs after her and received immunity
from prosecution. They were also treated and penalized far
different than her. They were penalized mainly at the rate of
20 percent for the FBAR violation of the largest amount of
money in the account. She was penalized by 50 percent. She
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has been prosecuted criminally, indicted and arrested, and the
38,000 were not. And she has now been adjudicated a felon, and
all those 38,000 people did not suffer that designation.
The IRS created these amnesty programs called the
Offshore Voluntary Disclosure Fund in 2009, 2011, and 2012.
The one that's been created in 2012 has no time limit. So
anybody from now on into the future can make a voluntary
disclosure and receive immunity from prosecution. And as I
said, some 38,000 people have taken advantage of this.
Every one of those people got advanced warning from
the Internal Revenue Service to do this, but not Mrs. Curran.
The IRS warned United States taxpayers the consequences of not
entering the program, but not Mrs. Curran. Every one of these
38,000 people were given a second chance three times, yet
Mrs. Curran never received a second chance at all. She never
received the benefit of any of these programs.
Now, Your Honor, I know that one of the important
concepts of sentencing in a tax case is deterrence, and we all
know that we have a voluntary tax program and deterrence is
important so people pay their taxes. However, I believe that
granting her probation in this case is not inconsistent with
the aims of the Internal Revenue Service and the idea or
concept of deterrence.
The government through the Internal Revenue Service
created these amnesty programs not as a matter of deterrence.
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That was not the aim of creating the program. But as the
Internal Revenue Service commissioner Doug Shulman said, "as I
said all along, the goal is to get people into the United
States tax system." And so deterrence was not really the aim
of any of these programs. It was really to reintegrate these
people back into the United States tax system. And that's why
I think what's important here in terms of thinking about a
sentence that deterrence is not really the same as it would be
in the ordinary tax case.
In addition to her attempts to disclose her accounts,
she also has another matter she did that I think shows her
cooperation. Soon after being denied entrance into the
program, on June 4, 2009, she agreed to meet with an Assistant
US Attorney and agents of the Internal Revenue Service. At
that time she made a full disclosure to them. Long before they
entered into any kind of investigation or prosecution of her
she gave a sworn statement -- I think it was sworn. I'm not a
hundred percent sure -- and gave them full cooperation and
described everything that she did, described every person who
worked with her, gave the names of all of the bankers, the
lawyers, the managers of all of the accounts, gave the dates
and times and information about everything that occurred with
them. And this was back, as I said, in June of 2009. And she
did all that she could to cooperate with the United States
Government.
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Your Honor, some 50 plus taxpayers have been
criminally prosecuted out of those 50,000, and her situation
also is far different than theirs. She did not use this
account to skim money off of a business that she was running in
the United States. She did not create false business documents
in a United States business in order to hide her income. She
did not funnel money back to the United States from these
accounts claiming they were sham loans or some other method of
doing it. She did none of these things. She did not make any
extravagant purchases. And so her situation is really far
different than most of the others. And yet, most of them were
sentenced to probation. Some with house arrest or with
community service, but almost all were sentenced to a period of
probation. And I think that's why the probation officer in
this case has recommended probation and why the government is
not objecting to it.
Just two other personal matters, and then I will
conclude. In our memorandum we listed out many charitable
works that Mrs. Curran has done. As I said, she spent her
entire working life doing volunteer work. But she is not a
person who only donated money. This is a woman who spent her
time and effort from feeding people in soup kitchens to
visiting them in the hospitals and working with the disabled.
And the one that I particularly believe is worthy of
note is she worked with the Rehabilitation Center for Children
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and Adults that's located here in Palm Beach. She worked there
for 32 years. For 32 years she worked with the children in the
preschool. And these are children who suffer from mainly
neurological disorders, from Down's syndrome to other
neurological disorders, which are incurable. And she worked
with children trying to assist them in doing such things as we
take for granted, like climbing the stairs, being able to go to
the playground, trying to work with them so they could go to a
normal kindergarten class. And this is very hard work. Most
people don't want to do this. People do not want to see
severely disabled children for which there is no cure and some
of whom the families are desperate. But she spent 32 years not
just making donations but 32 years of herself. And I think
that's probably one of the most noteworthy things that I have
seen that people do.
One last matter which I think sort of sums up how
seriously Mrs. Curran treats this case that's before Your Honor
this afternoon. Before we first came to this courthouse she
called us and asked us the address of the courthouse. And then
the next time we saw her we asked her, well, why did you want
to know where the courthouse was? And she said that she was so
anxious and worried that she wanted to practice driving to this
courthouse because she did not want to keep the prosecutors and
the Court waiting for her and she was so afraid that she might
be late. And I think that sort of sums up what her attitude
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is, what her attitude to this case is, and tells you who she
is.
And I would echo what the Probation Department has
said. I would humbly ask the Court to sentence her to a period
of probation.
THE COURT: I had a couple of questions.
MR. BLACK: Yes, sir.
THE COURT: The account that was in Switzerland, it
had a foundation named in it?
MR. BLACK: Yes. The husband set up what was called
a -- some type of a foundation, and at their death the money
was to go to three different universities.
THE COURT: The foundation wasn't giving regularly, it
was just being held, accumulated, and then to be distributed
upon their death?
MR. BLACK: Yes.
THE COURT: So her name wasn't on the account nor was
her husband's name?
MR. BLACK: No.
THE COURT: I guess they would have a record of them
as being the principals in the foundation, right?
MR. BLACK: Right. They were the beneficial owners of
the case. Their name was not on the case. It was in the name
of the foundation.
THE COURT: But it was a revocable thing, I image.
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MR. BLACK: Yes, it was revocable.
THE COURT: And apparently they traveled in Europe and
sometimes they used some of this money, did they?
MR. BLACK: Yes, Your Honor. Somewhere, depending on
the trip, 10, 15, or $20,000. And what Mrs. Curran thought,
which whether it is accurate or not, as long as the funds were
spent in Europe it did not violate US law. That's what she
thought at one time.
THE COURT: I think maybe a lot of people think that,
and maybe reasonably so.
MR. BLACK: Yes, sir. But unfortunately that's not
the law.
THE COURT: At what point did she make this payment?
Was it after the indictment -- or is it an information? Before
the information?
MR. BLACK: Well, she made a deposit -- she had paid
taxes before she was charged, and then we had to wait for the
Service to create what's called a closing statement to get all
of the figures together. But she made deposits and made
payments before she was charged. In fact, when we were
undergoing this process. And now she has fully paid everything
prior to today.
THE COURT: All right. Let me hear from the
government at this time.
MR. BLACK: Thank you, Your Honor.
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THE COURT: Let me ask you at the outset, do you
basically disagree with anything Mr. Black said?
MR DALY: We don't disagree with anything that
Mr. Black says. Based on many of the factors that he
highlighted as well as within the presentence investigation
report, the government doesn't oppose the variance downward.
Factually, Mr. Black has made a correct presentation.
THE COURT: Based upon those facts, did it ever occur
to the government this case ought to be dismissed and let this
thing go?
MR DALY: No, Your Honor.
THE COURT: It's totally consistent with all of the
amnesty programs the government has been running.
MR DALY: Your Honor, there is a certain level of
randomness to the level of government prosecution, but the
government drew a bright line in February 2009 in which it said
if at this point you haven't told the government about your
foreign bank account, you cannot, you cannot seek amnesty with
the IRS to the DOJ.
THE COURT: What Mr. Black said was she had already
turned it over to a lawyer to handle it. Apparently the lawyer
delayed it, and she would have qualified under it.
MR DALY: Had she come in prior to the production of
her name she would have qualified. But at that point she
hadn't. And the government has to draw bright lines as to
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where --
THE COURT: I don't know if the government has to do
anything. It seems to me the government has a lot of
discretion and the government decided they wanted to make a
felon out of this woman.
MR DALY: Well, Your Honor, I think that's -- I think
while the fact of when the information was handed over, it
ignores the fact of when the US investigation of UBS AG came to
light. Starting in June 2008 there were numerous articles in
the Wall Street Journal, in the New York Times about the
government's investigation of foreign bankers. Bradley
Birkenfeld was prosecuted here.
THE COURT: This case is totally out of the scope of
all of your others case where people are skimming, were trying
to hide funds. I mean, this was an inheritance over there, and
I think a lot of reasonable people would think you don't have
to report this.
MR DALY: Your Honor, Mr. Curran, the late Mr. Curran
was a very wealthy man. They had attorneys and they had
accountants at the time of his death in 2000. Mrs. Curran at
that time had every opportunity to tell those accountants I
have tens of millions dollars in Switzerland.
THE COURT: Didn't she have advisers in Switzerland
also who --
MR DALY: Right, but no reasonable person would ignore
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the US tax lawyers and accountants that they have. You don't
turn to a foreign national to ask you for an interpretation of
US law.
THE COURT: All right. Anything else you want to say?
MR DALY: No, Your Honor.
THE COURT: Mr. Black, does your client wish to
address the court? It's not necessary. She may not care to.
(Defendant and counsel conferring sotto voce.)
MR. BLACK: Your Honor, I think she is a little too
nervous to say anything.
THE COURT: I understand. I have to always give them
the opportunity if they would like to.
MR. BLACK: Yes, sir.
THE COURT: Well, this is really a tragic situation.
It's unfortunate and it seems to me the government should have
used a little more discretion in handling this.
Did you ever suggest to the government, Mr. Black,
that they should dismiss this case and settle for the -- what,
21 million did she pay?
MR. BLACK: Your Honor, I think -- we did have long
discussions with them. However, I cannot criticize the
government because I think they were within their discretion
and in their rules.
THE COURT: Within their discretion, but they could
exercise some discretion.
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MR. BLACK: Yes, Your Honor. But I find it hard to
criticize them for what they did. And we had many
conversations, but I think that they have their rules and they
proceeded ahead. And I don't want to criticize them for that.
THE COURT: Okay. The Court has considered the
statements of all parties, the presentence report which
contains the advisory guidelines and the statutory factors as
set forth in Title 18 United States Code § 3353(a).
Pursuant to the Title 18 United States Code §
3553(a)(1) and (2), a variance from the advisory guideline
range of 30 to 37 months is warranted in this case.
Based upon the history and characteristics of the
defendant, a sentence of probation will provide for just
punishment for this offense. A term of imprisonment would be
unnecessarily harsh.
It is the finding of the Court that the defendant is
not able to pay a fine.
It is the judgment of the Court that the defendant,
Mary Estelle Curran, is placed on probation for a period of one
year. This term consists of a term of one year as to Counts 1
and 2, all such terms to run concurrently.
Now, you understand you're under probation, don't you,
Mrs. Curran?
THE DEFENDANT: Yes, sir.
THE COURT: I'm now revoking probation. Probation is
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terminated. You were on probation for about five seconds
there.
THE DEFENDANT: Thank you.
THE COURT: The law requires me to put you on -- if I
don't put you in jail, I've got to put you on probation. It
doesn't say how long you have to stay there. So you are
officially off probation now.
The defendant shall immediately pay to the United
States a special assessment of $100 as to each of Counts 1 and
2 for a total of $200.
Now that sentence has been imposed, does the defendant
or her counsel object to the Court's finding of fact or to the
manner in which the sentence was pronounced?
MR. BLACK: No, Your Honor.
THE COURT: You have a right to appeal the sentence
imposed. Any notice of appeal must be filed within 14 days
after the entry of judgment. If you are unable to pay the
costs of an appeal, you may apply for leave to appeal without
payment of cost.
Do you understand that?
THE DEFENDANT: Yes, sir.
THE COURT: Mr. Black, I would urge you to file a
petition for a pardon with the executive branch. You can tell
them the Court thinks that this woman's felony should be
removed. And if the government doesn't join it, then it's just
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spiteful I think.
MR. BLACK: Thank you, Your Honor. We certainly
appreciate Your Honor's comments today and that as well.
THE COURT: All right. Anything further?
MR DALY: No, Your Honor.
THE COURT: Thank you.
(Proceedings concluded at 1:49 p.m.)
C E R T I F I C A T E
I, Karl Shires, Registered Professional Reporter and
Federal Certified Realtime Reporter, certify that the foregoing
is a correct transcript from the record of proceedings in the
above-entitled matter.
Dated this 25th day of April, 2013.
____________________________ Karl Shires, RPR FCRR
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$$100 [1] 17/9$20,000 [1] 12/5$200 [1] 17/10
--v [1] 1/6
110 [1] 12/512-80206-CR-RYSKAMP [1] 1/21300 [1] 1/2114 [1] 17/1615 [1] 12/518 [2] 16/8 16/91:24 [1] 1/91:49 [1] 18/7
220 percent [1] 6/242000 [4] 4/6 4/24 5/12 14/202008 [1] 14/92009 [4] 7/5 8/13 8/23 13/16201 [1] 1/202011 [1] 7/52012 [2] 7/5 7/62013 [2] 1/8 18/1520579 [1] 1/1821 million [1] 15/1925 [1] 1/8250 [2] 5/25 6/16258 [1] 1/2425th [1] 18/15285 [1] 6/14
330 [2] 3/20 16/1132 [4] 10/2 10/2 10/12 10/1333131 [1] 1/2133401 [1] 1/253353 [1] 16/83553 [1] 16/1037 [1] 16/113728 [1] 1/2438,000 [5] 6/20 7/2 7/3 7/9 7/14
550 [1] 9/150 percent [1] 6/2550,000 [2] 6/15 9/2514-3728 [1] 1/24561 [1] 1/24
6601 [1] 1/18
7701 [1] 1/247334 [1] 1/18
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account [6] 4/19 6/25 9/4 11/8 11/17 13/18accountants [5] 5/7 5/8 14/20 14/21 15/1accounts [16] 3/12 3/20 3/25 4/8 4/9 4/22 4/23 4/23 4/24 5/5 5/10 5/13 6/15 8/10 8/21 9/8accumulated [1] 11/14accurate [1] 12/6addition [1] 8/10address [2] 10/19 15/7adjudicated [1] 7/2Adults [1] 10/1advanced [1] 7/10advantage [1] 7/9advise [1] 5/7advisers [1] 14/23advisory [2] 16/7 16/10afraid [1] 10/24afternoon [3] 2/3 2/11 10/18AG [1] 14/8Agent [1] 2/8agents [1] 8/14agreed [1] 8/13ahead [1] 16/4aim [2] 8/1 8/4aims [1] 7/22AMERICA [1] 1/4amnesty [5] 6/8 7/4 7/25 13/13 13/18amount [3] 4/17 4/18 6/24analyst [1] 3/23anxious [1] 10/22anybody [1] 7/7apparently [2] 12/2 13/21appeal [4] 17/15 17/16 17/18 17/18appearance [1] 2/5Appearances [1] 1/15application [1] 6/9apply [1] 17/18appreciate [1] 18/3April [2] 1/8 18/15arrest [1] 9/12arrested [1] 7/1articles [1] 14/9asked [3] 5/14 10/19 10/20assessment [1] 17/9assist [1] 10/6Assistant [2] 2/8 8/13attached [1] 2/24attempting [1] 6/10attempts [1] 8/10attitude [2] 10/25 11/1Attorney [1] 8/14attorneys [1] 14/19aunt [1] 4/10available [1] 5/20
Bback [3] 8/6 8/23 9/7bank [3] 3/21 5/24 13/18banker [1] 3/23
bankers [4] 5/8 5/14 8/20 14/11Based [3] 13/4 13/8 16/12basically [1] 13/2Beach [3] 1/8 1/25 10/1behalf [1] 2/12believe [4] 3/9 3/13 7/20 9/24beneficial [2] 5/6 11/22benefit [3] 6/10 6/11 7/16Birkenfeld [1] 14/12Biscayne [1] 1/20BLACK [10] 1/19 1/20 2/11 13/2 13/4 13/7 13/20 15/6 15/17 17/22blames [1] 3/6Boulevard [1] 1/20Bradley [1] 14/11branch [1] 17/23bright [2] 13/16 13/25business [3] 9/4 9/5 9/6
CCall [1] 2/1called [4] 7/4 10/19 11/10 12/18care [1] 15/7Carlo [2] 4/11 4/14case [16] 1/2 2/3 3/10 7/18 7/21 8/9 9/15 10/17 11/1 11/23 11/23 13/9 14/13 14/14 15/18 16/11caused [1] 6/16Center [1] 9/25centers [1] 4/4certain [1] 13/14certainly [1] 18/2Certified [1] 18/12certify [1] 18/12chance [2] 7/14 7/15characteristics [1] 16/12charged [3] 3/7 12/17 12/20charitable [1] 9/18children [6] 4/4 9/25 10/2 10/3 10/6 10/11circumstances [2] 3/10 3/12citizen [1] 4/13claiming [1] 9/8class [1] 10/9Clematis [1] 1/24client [2] 2/15 15/6climbing [1] 10/7closing [1] 12/18Code [2] 16/8 16/9come [1] 13/23comments [1] 18/3commissioner [1] 8/2community [1] 9/13concept [1] 7/23concepts [1] 7/18conclude [1] 9/18concluded [1] 18/7concurrently [1] 16/21
conferring [1] 15/8consequences [2] 4/14 7/12considered [1] 16/5consistent [1] 13/12consists [1] 16/20contacted [1] 5/13contains [1] 16/7conversations [1] 16/3cooperate [1] 8/24cooperation [2] 8/12 8/18copy [1] 2/14correct [2] 13/7 18/13corrections [1] 2/18correctly [1] 5/7cost [1] 17/19costs [1] 17/18counsel [4] 2/5 2/7 15/8 17/12Counts [2] 16/20 17/9couple [2] 3/17 11/6course [1] 6/16court [11] 1/1 1/24 2/1 3/8 10/24 11/4 15/7 16/5 16/16 16/18 17/24Court's [1] 17/12courthouse [4] 10/18 10/19 10/21 10/23CR [1] 1/2create [2] 9/5 12/18created [5] 5/21 6/12 7/4 7/6 7/25creating [1] 8/1creation [1] 4/22criminally [2] 7/1 9/2criticize [3] 15/21 16/2 16/4cure [1] 10/11CURRAN [16] 1/7 2/4 2/12 3/5 4/20 7/11 7/13 7/15 9/19 10/17 12/5 14/18 14/18 14/20 16/19 16/23
DDALY [2] 1/16 2/6Dated [1] 18/15dates [1] 8/21day [1] 18/15days [3] 6/7 6/18 17/16DC [1] 1/18death [5] 4/19 4/24 11/11 11/15 14/20decided [1] 14/4defendant [8] 1/8 1/19 15/8 16/13 16/16 16/18 17/8 17/11delayed [1] 13/22denied [2] 6/9 8/12DEPARTMENT [3] 1/17 2/7 11/3depending [1] 12/4deposit [1] 12/16depositing [1] 4/22deposits [2] 4/18 12/19described [2] 8/19 8/19designation [1] 7/3
19
Ddesperate [1] 10/12deterrence [6] 7/18 7/19 7/23 7/25 8/4 8/8Didn't [1] 14/23died [2] 4/6 4/11different [5] 3/10 6/23 9/3 9/11 11/12differently [1] 6/17disabled [3] 4/5 9/23 10/11disagree [2] 13/2 13/3disclose [3] 5/14 6/11 8/10disclosure [13] 5/12 5/19 5/21 5/22 6/1 6/4 6/6 6/7 6/12 6/21 7/5 7/8 8/15discretion [5] 14/4 15/16 15/22 15/24 15/25discussions [1] 15/21dismiss [1] 15/18dismissed [1] 13/9disorders [2] 10/4 10/5distributed [1] 11/14DISTRICT [3] 1/1 1/1 1/13DIVISION [2] 1/17 2/7documents [1] 9/5doing [3] 9/9 9/20 10/6DOJ [1] 13/19dollars [1] 14/22donated [1] 9/21donations [1] 10/13Doug [1] 8/2Down's [1] 10/4downward [1] 13/6draw [1] 13/25drew [1] 13/16driving [1] 10/22
Eecho [1] 11/3effect [2] 6/8 6/19effort [1] 9/22eligible [1] 6/4English [1] 4/13entered [1] 8/16entering [1] 7/13entire [2] 4/5 9/20entitled [1] 18/14entrance [1] 8/12entry [1] 17/17errors [1] 2/17ESQ [1] 1/20established [1] 4/9estate [1] 4/11ESTELLE [2] 1/7 16/19Europe [4] 4/16 5/14 12/2 12/7European [1] 5/8executive [1] 17/23exercise [1] 15/25extent [1] 4/7extraordinary [1] 3/13extravagant [1] 9/10
Ffact [4] 12/20 14/7
14/8 17/12factors [2] 13/4 16/7facts [1] 13/8Factually [1] 13/7false [1] 9/5families [1] 10/12far [4] 6/16 6/22 9/3 9/10FBAR [1] 6/24FCRR [2] 1/23 18/17February [1] 13/16February 2009 [1] 13/16Federal [1] 18/12feeding [1] 9/22felon [2] 7/2 14/5felony [1] 17/24figures [1] 12/19file [1] 17/22filed [2] 6/7 17/16finance [1] 3/19finances [2] 3/24 4/7financial [2] 3/19 3/23find [1] 16/1finding [2] 16/16 17/12fine [1] 16/17first [6] 2/3 3/18 3/20 6/8 6/18 10/18five [1] 17/1FLORIDA [4] 1/1 1/8 1/21 1/25foregoing [1] 18/12foreign [3] 13/18 14/11 15/2forth [1] 16/8foundation [5] 11/9 11/11 11/13 11/21 11/24four [1] 6/2full [3] 3/5 8/15 8/18fully [1] 12/21Fund [1] 7/5funds [8] 4/10 4/12 4/21 4/25 5/13 6/12 12/6 14/15funnel [1] 9/7further [1] 18/4future [1] 7/7
Ggive [1] 15/11given [1] 7/14giving [1] 11/13go [6] 3/15 3/16 10/7 10/8 11/12 13/10goal [1] 8/3going [2] 3/15 5/21Good [2] 2/3 2/11government [19] 1/16 7/24 8/25 9/15 12/24 13/6 13/9 13/13 13/15 13/16 13/17 13/25 14/2 14/3 14/4 15/15 15/17 15/22 17/25government's [1] 14/11granted [1] 10/7granting [1] 7/21grew [2] 4/17 4/21growing [1] 4/23guess [1] 11/20
guideline [1] 16/10guidelines [1] 16/7guilty [1] 3/6
Hhanded [1] 14/7handle [4] 5/4 5/6 5/8 13/21handled [2] 3/22 3/25handling [2] 3/20 15/16hard [2] 10/9 16/1harsh [1] 16/15hear [2] 3/2 12/23held [1] 11/14hide [2] 9/6 14/15highlight [1] 3/17highlighted [1] 13/5history [1] 16/12Hoffman [1] 2/12Honor [21] 2/6 2/11 2/21 3/4 3/15 7/17 9/1 10/17 12/4 12/25 13/11 13/14 14/6 14/18 15/5 15/9 15/20 16/1 17/14 18/2 18/5Honor's [1] 18/3HONORABLE [1] 1/12hope [1] 5/2hospitals [2] 4/3 9/23house [2] 4/1 9/12humbly [1] 11/4hundred [1] 8/18husband [7] 3/22 4/5 4/10 4/16 4/19 4/25 11/10husband's [1] 11/18
II'll [1] 3/2I'm [3] 3/15 8/17 16/25I've [1] 17/5idea [1] 7/22ignore [1] 14/25ignores [1] 14/8image [1] 11/25immediately [1] 17/8immunity [2] 6/21 7/8important [3] 7/17 7/20 8/7imposed [2] 17/11 17/16imprisonment [1] 16/14income [1] 9/6inconsistent [1] 7/21incurable [1] 10/5indicted [1] 7/1indictment [1] 12/14information [5] 5/18 8/22 12/14 12/15 14/7inherit [1] 4/23inheritance [1] 14/15inherited [4] 4/10 4/24 5/5 5/10intended [1] 2/25interest [1] 5/6Internal [10] 5/19 5/25 6/3 6/8 6/12 7/11 7/22 7/24 8/2 8/14interpretation [1] 15/2
investigation [4] 8/16 13/5 14/8 14/11investment [1] 3/23IRS [5] 2/9 5/22 7/4 7/12 13/19issues [1] 3/17it's [4] 13/12 15/7 15/15 17/25
JJackie [1] 2/12jail [1] 17/5Johnson [1] 2/9join [1] 17/25Journal [1] 14/10JUDGE [1] 1/13judged [2] 5/3 5/3judgment [2] 16/18 17/17June [3] 8/13 8/23 14/9June 2008 [1] 14/9June 4 [1] 8/13JUSTICE [2] 1/17 2/7
Kkeep [1] 10/23KENNETH [1] 1/12kind [1] 8/16kindergarten [1] 10/9kitchens [2] 4/3 9/22know [5] 5/1 7/17 7/19 10/21 14/2KORNSPAN [1] 1/19
LLanigan [1] 2/8large [1] 4/17largest [1] 6/24late [3] 4/25 10/25 14/18law [4] 12/7 12/12 15/3 17/4lawyer [4] 5/15 5/17 13/21 13/21lawyers [4] 5/7 5/8 8/21 15/1learned [2] 4/6 4/7leave [1] 17/18left [3] 4/11 4/16 4/20letters [1] 2/24level [2] 13/14 13/15life [3] 4/2 4/5 9/20light [1] 14/9limit [1] 7/6line [1] 13/16lines [1] 13/25listed [1] 9/18Litigation [1] 2/6little [2] 15/9 15/16lived [1] 4/10lives [1] 5/2living [1] 4/14loans [1] 9/8located [1] 10/1long [5] 5/23 8/15 12/6 15/20 17/6lot [3] 12/9 14/3 14/16
Mmajority [1] 6/17
20
Mmaking [1] 10/13man [2] 3/24 14/19managers [1] 8/21manner [1] 17/13MARK [2] 1/16 2/6marriage [1] 3/21MARY [2] 1/7 16/19matter [4] 7/25 8/11 10/16 18/14matters [2] 3/19 9/17mean [2] 4/2 14/15meet [1] 8/13memorandum [3] 2/22 3/17 9/18method [1] 9/8Miami [1] 1/21million [1] 15/19millions [1] 14/22mistake [2] 5/4 5/11mistakes [5] 5/1 5/2 5/3 5/4 5/9mitigating [1] 3/9money [11] 4/15 4/16 4/18 4/20 4/22 6/25 9/4 9/7 9/21 11/11 12/3Monte [2] 4/11 4/14month [1] 5/23monthly [1] 3/21months [1] 16/11Mortimer [1] 3/22Mr [1] 14/18Mr. [8] 13/2 13/4 13/7 13/20 14/18 15/6 15/17 17/22Mr. Black [7] 13/2 13/4 13/7 13/20 15/6 15/17 17/22Mr. Curran [1] 14/18Mrs [1] 2/12Mrs. [10] 3/5 4/20 7/11 7/13 7/15 9/19 10/17 12/5 14/20 16/23Mrs. Curran [10] 3/5 4/20 7/11 7/13 7/15 9/19 10/17 12/5 14/20 16/23
Nname [7] 6/2 6/3 11/17 11/18 11/23 11/23 13/24named [1] 11/9names [2] 5/25 8/20Nathan [1] 2/12national [1] 15/2necessary [1] 15/7nervous [1] 15/10neurological [2] 10/4 10/5never [3] 4/18 7/15 7/15New [1] 14/10normal [1] 10/9note [1] 9/25noteworthy [1] 10/14notice [1] 17/16numerous [1] 14/9NW [1] 1/18
Oobject [1] 17/12objecting [1] 9/16obtain [2] 5/15 6/10occur [1] 13/8occurred [1] 8/22offense [1] 16/14offenses [1] 3/6officer [1] 9/14Official [1] 1/24officially [1] 17/7offshore [6] 3/12 5/20 6/11 6/18 6/20 7/5Okay [2] 2/14 16/5omissions [1] 2/17opportunity [2] 14/21 15/12oppose [1] 13/6order [2] 2/1 9/6ordinary [1] 8/9ought [1] 13/9outset [1] 13/1outside [1] 4/1overwhelming [1] 6/17owners [1] 11/22
Pp.m [2] 1/9 18/7paid [2] 12/16 12/21Palm [3] 1/8 1/25 10/1pardon [1] 17/23part [1] 4/11particularly [1] 9/24parties [1] 16/6pay [5] 7/20 15/19 16/17 17/8 17/17payment [2] 12/13 17/19payments [1] 12/20penalized [3] 6/22 6/23 6/25people [18] 5/25 6/14 6/17 6/20 7/3 7/9 7/10 7/14 7/20 8/3 8/6 9/22 10/10 10/10 10/15 12/9 14/14 14/16percent [3] 6/24 6/25 8/18Perczek [1] 2/12period [4] 5/24 9/13 11/4 16/19person [3] 8/19 9/21 14/25personal [2] 3/20 9/17petition [1] 17/23placed [1] 16/19Plaintiff [1] 1/5playground [1] 10/8please [1] 2/5pled [1] 3/6plus [1] 9/1point [3] 12/13 13/17 13/24position [1] 3/7possession [1] 5/5practice [1] 10/22preschool [1] 10/3present [1] 2/22presentation [1] 13/7presentence [3] 2/15 13/5 16/6
principals [1] 11/21prior [2] 12/22 13/23probably [1] 10/14probation [15] 7/21 9/12 9/14 9/14 9/15 11/3 11/5 16/13 16/19 16/22 16/25 16/25 17/1 17/5 17/7proceed [2] 2/20 3/1proceeded [1] 16/4proceedings [3] 1/11 18/7 18/13process [1] 12/21production [1] 13/23Professional [1] 18/11program [7] 6/5 6/8 6/19 7/13 7/19 8/1 8/13programs [8] 5/19 5/21 6/21 7/4 7/16 7/25 8/5 13/13pronounced [1] 17/13prosecuted [5] 3/11 3/11 7/1 9/2 14/12prosecution [4] 6/22 7/8 8/16 13/15prosecutors [1] 10/23provide [1] 16/13punishment [1] 16/14purchases [1] 9/10Pursuant [1] 16/9put [5] 4/18 6/8 17/4 17/5 17/5
Qqualified [2] 13/22 13/24question [3] 4/9 5/9 5/24questions [1] 11/6
Rrandomness [1] 13/15range [1] 16/11rate [1] 6/23read [1] 2/23really [5] 8/4 8/5 8/8 9/10 15/14Realtime [1] 18/12reason [1] 6/14reasonable [2] 14/16 14/25reasonably [1] 12/10receive [1] 7/8received [4] 2/14 6/21 7/15 7/16recommended [2] 5/15 9/15record [2] 11/20 18/13rectify [1] 5/11Registered [1] 18/11regular [1] 5/22regularly [1] 11/13rehabilitation [2] 4/4 9/25reintegrate [1] 8/5remarks [1] 2/25removed [1] 17/25report [5] 2/15 6/18 13/6 14/17 16/6reported [1] 6/14Reporter [4] 1/23 1/24
18/11 18/12reporting [1] 5/10requires [1] 17/4responsibility [2] 3/5 3/14retained [1] 5/17Revenue [10] 5/19 5/25 6/3 6/9 6/13 7/11 7/22 7/24 8/2 8/14reviewed [1] 2/15revocable [2] 11/25 12/1revoking [1] 16/25right [10] 2/10 2/20 3/2 11/21 11/22 12/23 14/25 15/4 17/15 18/4Room [1] 1/18ROY [2] 1/20 2/11RPR [2] 1/23 18/17rules [3] 6/2 15/23 16/3run [1] 16/21running [2] 9/4 13/13RYSKAMP [2] 1/2 1/12
Ssaw [1] 10/20says [1] 13/4scope [1] 14/13Scott [1] 2/9seated [1] 2/2second [2] 7/14 7/15seconds [1] 17/1see [2] 3/21 10/10seek [1] 13/18seen [1] 10/15SENIOR [3] 1/13 2/6 3/23sent [1] 2/22sentence [6] 8/8 11/4 16/13 17/11 17/13 17/15sentenced [2] 9/12 9/13sentencing [6] 1/11 2/22 3/1 3/8 3/16 7/18seriously [1] 10/17service [12] 5/19 5/25 6/3 6/9 6/13 7/11 7/22 7/24 8/2 8/14 9/13 12/18set [2] 11/10 16/8settle [1] 15/18seven [2] 6/7 6/18severely [1] 10/11sham [1] 9/8short [1] 2/25shown [1] 3/13shows [1] 8/11Shulman [1] 8/2sick [1] 4/5significant [1] 4/17similar [1] 3/12sir [7] 2/16 2/19 11/7 12/11 15/13 16/24 17/21situation [3] 9/2 9/10 15/14skim [1] 9/4skimming [1] 14/14Soon [1] 8/12sort [2] 10/16 10/25
21
Ssotto [1] 15/8soup [2] 4/3 9/22South [1] 1/20SOUTHERN [1] 1/1special [2] 2/8 17/9spent [5] 4/2 9/19 9/21 10/12 12/7spiteful [1] 18/1SREBNICK [1] 1/19stairs [1] 10/7Starting [1] 14/9state [1] 2/5statement [2] 8/17 12/18statements [2] 3/22 16/6STATES [16] 1/1 1/4 2/3 2/8 4/12 5/15 7/12 8/4 8/6 8/24 9/5 9/6 9/7 16/8 16/9 17/9statutory [1] 16/7stay [1] 17/6stores [1] 4/3Street [3] 1/18 1/24 14/10STUMPF [1] 1/19subjected [1] 3/8suffer [2] 7/3 10/3sufficient [1] 5/18suggest [1] 15/17Suite [2] 1/21 1/24sums [2] 10/16 10/25sure [1] 8/18Switzerland [3] 11/8 14/22 14/23sworn [2] 8/17 8/17syndrome [1] 10/4system [2] 8/4 8/6
Ttake [1] 10/7taken [1] 7/9tax [11] 1/17 2/7 4/14 5/15 5/17 7/18 7/19 8/4 8/6 8/9 15/1taxes [3] 3/19 7/20 12/17taxpayer [1] 4/13taxpayers [2] 7/12 9/1tell [2] 14/21 17/23tells [1] 11/1tens [1] 14/22term [3] 16/14 16/20 16/20terminated [1] 17/1terms [2] 8/7 16/21Thank [5] 3/4 12/25 17/3 18/2 18/6theirs [1] 9/3thing [2] 11/25 13/10things [4] 3/16 9/9 10/6 10/14think [19] 4/13 8/7 8/11 8/17 9/14 10/13 10/16 10/25 12/9 12/9 14/6 14/6 14/16 14/16 15/9 15/20 15/22 16/3 18/1thinking [1] 8/7thinks [1] 17/24
Thomas [1] 2/8thought [2] 12/5 12/8three [5] 6/2 6/11 6/20 7/14 11/12thrift [1] 4/3time [12] 3/3 5/20 5/24 6/1 7/6 8/15 9/22 10/20 12/8 12/24 14/20 14/21times [3] 7/14 8/22 14/10Title [2] 16/8 16/9today [3] 3/8 12/22 18/3told [1] 13/17total [1] 17/10totally [2] 13/12 14/13tragic [1] 15/14training [1] 3/19transcript [2] 1/11 18/13traveled [1] 12/2treated [2] 6/16 6/22treats [1] 10/17tried [2] 5/11 6/6trip [1] 12/5trying [3] 10/6 10/8 14/14turn [1] 15/2turned [1] 13/21two [1] 9/17type [1] 11/11
UU.S [1] 1/13UBS [3] 5/24 6/14 14/8unable [1] 17/17undergoing [1] 12/21understand [3] 15/11 16/22 17/20unfortunate [1] 15/15unfortunately [2] 5/23 12/11UNITED [16] 1/1 1/4 2/3 2/8 4/12 5/15 7/12 8/3 8/6 8/24 9/5 9/6 9/7 16/8 16/9 17/8universities [1] 11/12unnecessarily [1] 16/15unsophisticated [1] 3/18urge [1] 17/22use [1] 9/3
Vvariance [2] 13/6 16/10versed [1] 3/24versus [1] 2/4violate [1] 12/7violation [1] 6/24virtually [1] 3/10visiting [1] 9/23voce [1] 15/8voluntary [14] 5/12 5/18 5/21 5/22 6/1 6/4 6/6 6/7 6/11 6/18 6/21 7/5 7/7 7/19volunteer [2] 4/2 9/20
Wwait [1] 12/17waited [1] 5/23waiting [1] 10/24Wall [1] 14/10want [7] 3/17 10/10 10/10 10/20 10/23 15/4 16/4wanted [3] 5/12 10/22 14/4warned [1] 7/12warning [1] 7/10warranted [1] 16/11Washington [1] 1/18We've [1] 2/22wealthy [1] 14/19weeks [1] 6/2well [8] 2/13 3/24 10/20 12/16 13/5 14/6 15/14 18/3went [2] 6/19 6/20were [22] 3/11 4/9 4/12 4/14 5/9 5/20 5/21 6/12 6/22 6/23 7/2 7/14 9/8 9/11 9/13 11/22 12/6 12/20 14/9 14/14 15/22 17/1West [2] 1/8 1/25wish [1] 15/6witnesses [1] 2/21woman [3] 3/18 9/21 14/5woman's [1] 17/24work [5] 4/1 4/2 9/20 10/8 10/9worked [6] 4/2 8/20 9/25 10/1 10/2 10/5working [4] 4/4 4/4 9/20 9/23works [1] 9/19worried [1] 10/22worthy [1] 9/24wrote [1] 3/16
Yyear [5] 4/6 4/24 5/12 16/20 16/20years [5] 3/21 10/2 10/2 10/12 10/13York [1] 14/10
22