{
  "document_metadata": {
    "page_number": "1",
    "document_number": "604",
    "date": "03/16/13",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Casas: 2020-10-03 08:37:34 A-5930\nCase 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 1 of 14\nZUCKERMAN SPAEDER LLP\n1185 AVENUE OF THE AMERICAS 31ST FLOOR NEW YORK, NY 10036-2603\n212.704.9600 212.704.4256 fax www.zuckerman.com\nPAUL SHECHTMAN Partner 212-704-9600 Pshechtman@zuckerman.com\nBY HAND\nMarch 7, 2013\nThe Honorable William H. Pauley, III United States District Judge Southern District of New York 500 Pearl Street, Room 2210 New York, NY 10007\nRe: United States v. David Parse, et al., 09 Cr. 581 (WHP)\nDear Judge Pauley:\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)\").\nA. Background\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\nWASHINGTON, DC NEW YORK TAMPA BALTIMORE\nDOJ-OGR-00010185",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Casas: 2020-10-03 08:37:34 A-5930",
      "position": "header"
    },
    {
      "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 NEW YORK, NY 10036-2603\n212.704.9600 212.704.4256 fax www.zuckerman.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "PAUL SHECHTMAN Partner 212-704-9600 Pshechtman@zuckerman.com",
      "position": "left margin"
    },
    {
      "type": "printed",
      "content": "BY HAND\nMarch 7, 2013",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Honorable William H. Pauley, III United States District Judge Southern District of New York 500 Pearl Street, Room 2210 New York, NY 10007",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Re: United States v. David Parse, et al., 09 Cr. 581 (WHP)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dear Judge Pauley:",
      "position": "body"
    },
    {
      "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-00010185",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "David Parse",
      "William H. Pauley, III",
      "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",
      "03/16/13"
    ],
    "reference_numbers": [
      "09 Cr. 581 (WHP)",
      "1:09-cr-00581-WHP",
      "Document 604",
      "DOJ-OGR-00010185"
    ]
  },
  "additional_notes": "The document appears to be a letter from a law firm to a judge regarding a sentencing case. The letterhead and footer contain the law firm's information and locations. The document is well-formatted and legible."
}