{
  "document_metadata": {
    "page_number": "1",
    "document_number": "604",
    "date": "03/16/13",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 1 of 14\n\nZUCKERMAN SPAEDER LLP\n1185 AVENUE OF THE AMERICAS 31ST FLOOR\nNEW YORK, NY 10036-2603\n212.704.9600 212.704.4256 fax www.zuckerman.com\n\nPAUL SHECHTMAN\nPartner\n212-704-9600\nPshechtman@zuckerman.com\n\nBY HAND\n\nMarch 7, 2013\n\nThe Honorable William H. Pauley, III\nUnited States District Judge\nSouthern District of New York\n500 Pearl Street, Room 2210\nNew York, NY 10007\n\nRe: United States v. David Parse, et al., 09 Cr. 581 (WHP)\n\nDear Judge Pauley:\n\nThis letter is respectfully submitted on behalf of David Parse, who is scheduled to be sentenced for tax-related crimes on March 22, 2013. For the reasons discussed below, we believe that a non-incarcerative sentence would be a fair and parsimonious one. See United States v. Dorvee, 616 F.3d 174, 182 (2d Cir. 2010)(\"it is the sentencing court's duty to impose a sentence sufficient, but not greater than necessary to comply with the specific purposes set forth at 18 U.S.C. § 3553(a)(2)\").\n\nA. Background\n\nDavid Parse was born in Detroit, Michigan, on December 7, 1961. He was the youngest of five children of Sylvia and Henry Parse. A World War II veteran, David's father worked two jobs for most of his life. He was a mailman by day, and a factory worker at night. David's mother worked part-time as a laundress in a local restaurant. The two parents instilled\n\nWASHINGTON, DC          NEW YORK          TAMPA          BALTIMORE\n\nDOJ-OGR-00009506",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 1 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "ZUCKERMAN SPAEDER LLP\n1185 AVENUE OF THE AMERICAS 31ST FLOOR\nNEW YORK, NY 10036-2603\n212.704.9600 212.704.4256 fax www.zuckerman.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "PAUL SHECHTMAN\nPartner\n212-704-9600\nPshechtman@zuckerman.com",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "BY HAND\n\nMarch 7, 2013",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable William H. Pauley, III\nUnited States District Judge\nSouthern District of New York\n500 Pearl Street, Room 2210\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. David Parse, et al., 09 Cr. 581 (WHP)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Pauley:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "This letter is respectfully submitted on behalf of David Parse, who is scheduled to be sentenced for tax-related crimes on March 22, 2013. For the reasons discussed below, we believe that a non-incarcerative sentence would be a fair and parsimonious one. See United States v. Dorvee, 616 F.3d 174, 182 (2d Cir. 2010)(\"it is the sentencing court's duty to impose a sentence sufficient, but not greater than necessary to comply with the specific purposes set forth at 18 U.S.C. § 3553(a)(2)\").",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "A. Background",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "David Parse was born in Detroit, Michigan, on December 7, 1961. He was the youngest of five children of Sylvia and Henry Parse. A World War II veteran, David's father worked two jobs for most of his life. He was a mailman by day, and a factory worker at night. David's mother worked part-time as a laundress in a local restaurant. The two parents instilled",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "WASHINGTON, DC          NEW YORK          TAMPA          BALTIMORE",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009506",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "William H. Pauley, III",
      "David Parse",
      "Sylvia Parse",
      "Henry Parse",
      "Paul Shechtman"
    ],
    "organizations": [
      "ZUCKERMAN SPAEDER LLP",
      "United States District Court"
    ],
    "locations": [
      "New York",
      "Detroit",
      "Michigan",
      "Washington, DC",
      "Tampa",
      "Baltimore"
    ],
    "dates": [
      "March 7, 2013",
      "March 22, 2013",
      "December 7, 1961"
    ],
    "reference_numbers": [
      "09 Cr. 581 (WHP)",
      "DOJ-OGR-00009506"
    ]
  },
  "additional_notes": "The document appears to be a letter from Paul Shechtman of Zuckerman Spaeder LLP to Judge William H. Pauley, III, regarding the sentencing of David Parse. The letter is dated March 7, 2013, and is related to the case United States v. David Parse, et al., 09 Cr. 581 (WHP)."
}