{
  "document_metadata": {
    "page_number": "8",
    "document_number": "604",
    "date": "03/16/13",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 8 of 14\n\nZUCKERMAN SPAEDER LLP\n\nThe Honorable William H. Pauley, III\nMarch 7, 2013\nPage 8\nhorrific 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.\n\nNotably, 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\").\n\nD. The Instant Offense\n\nAs 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",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 8 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "ZUCKERMAN SPAEDER LLP",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable William H. Pauley, III\nMarch 7, 2013\nPage 8",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "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.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "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\").",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "D. The Instant Offense",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "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",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010192",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "William H. Pauley, III",
      "Dave",
      "James Yetter",
      "Andrew Miller",
      "Thomas Carnaghi",
      "Kenneth Norwick",
      "David",
      "Paul Daugerdas",
      "Jason Shih",
      "Alex Brown"
    ],
    "organizations": [
      "ZUCKERMAN SPAEDER LLP",
      "Deutsche Bank",
      "Alex Brown"
    ],
    "locations": [
      "Chicago",
      "San Francisco"
    ],
    "dates": [
      "March 7, 2013",
      "03/16/13",
      "1998",
      "early 1990's"
    ],
    "reference_numbers": [
      "1:09-cr-00581-WHP",
      "Document 604",
      "394 F.3d 172",
      "DOJ-OGR-00010192"
    ]
  },
  "additional_notes": "The document appears to be a court filing, likely a sentencing memorandum, discussing the character and actions of an individual named David. The text includes references to various individuals who have written letters on David's behalf, highlighting his charitable actions and personal sacrifices. The document also mentions a case number and a court filing date."
}