{
  "document_metadata": {
    "page_number": "13",
    "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 13 of 14\n\nZUCKERMAN SPAEDER LLP\n\nThe Honorable William H. Pauley, III\nMarch 7, 2013\nPage 13\n\nAs noted above, we believe that the jury convicted David for his involvement in three backdating transactions from which he barely profited. He has already suffered greatly for that conduct. Since 2004, when the criminal investigation commenced, this matter has hung over him. His once-thriving brokerage business has collapsed. His wife's health has suffered. See supra n.3. His children have felt the sting of comments from others who have learned of David's conviction. And the stigma of the conviction haunts David, especially because it is antithetical to the values with which he was raised. See letter of Theresa Parse (\"our lives [have] essentially [been] placed on hold, as we try to raise our three sons in a safe and secure environment\").\n\nMore than 15 years ago, the United States Supreme Court reminded that the \"uniform and constant . . . tradition for the sentencing judge [is] to consider every convicted person as an individual and every case as a unique study in the human failings that sometimes mitigate, sometimes magnify, the crime and the punishment to ensue.\" Koon v. United States, 518 U.S. 81, 113 (1996). In this submission, we have tried to show that David Parse is a fundamentally decent man. He believes in family, hard work, helping others, and being actively involved in community. The conduct for which he was convicted, we believe, was at the periphery of the Jenkins scheme. On this record, we respectfully submit that a non-incarcerative sentence would be just. It would not diminish respect for the law. See United States v. Adelson, 441 F.Supp.2d 506, 513-14 (S.D.N.Y. 2006)(\"if ever a man is to receive credit for the good he\ndo\n\nDOJ-OGR-00010197",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 13 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 13",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "As noted above, we believe that the jury convicted David for his involvement in three backdating transactions from which he barely profited. He has already suffered greatly for that conduct. Since 2004, when the criminal investigation commenced, this matter has hung over him. His once-thriving brokerage business has collapsed. His wife's health has suffered. See supra n.3. His children have felt the sting of comments from others who have learned of David's conviction. And the stigma of the conviction haunts David, especially because it is antithetical to the values with which he was raised. See letter of Theresa Parse (\"our lives [have] essentially [been] placed on hold, as we try to raise our three sons in a safe and secure environment\").\n\nMore than 15 years ago, the United States Supreme Court reminded that the \"uniform and constant . . . tradition for the sentencing judge [is] to consider every convicted person as an individual and every case as a unique study in the human failings that sometimes mitigate, sometimes magnify, the crime and the punishment to ensue.\" Koon v. United States, 518 U.S. 81, 113 (1996). In this submission, we have tried to show that David Parse is a fundamentally decent man. He believes in family, hard work, helping others, and being actively involved in community. The conduct for which he was convicted, we believe, was at the periphery of the Jenkins scheme. On this record, we respectfully submit that a non-incarcerative sentence would be just. It would not diminish respect for the law. See United States v. Adelson, 441 F.Supp.2d 506, 513-14 (S.D.N.Y. 2006)(\"if ever a man is to receive credit for the good he",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010197",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "William H. Pauley, III",
      "David Parse",
      "Theresa Parse"
    ],
    "organizations": [
      "ZUCKERMAN SPAEDER LLP",
      "United States Supreme Court"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "March 7, 2013",
      "03/16/13",
      "2004",
      "1996",
      "2006"
    ],
    "reference_numbers": [
      "1:09-cr-00581-WHP",
      "Document 604",
      "518 U.S. 81",
      "441 F.Supp.2d 506",
      "DOJ-OGR-00010197"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the sentencing of David Parse. It includes a letter from Theresa Parse and references several legal cases."
}