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U.S. v. Achiekwelu, No. 95-0376-A (E.D.Va.) (900 F.Supp. 812) (October 16, 1995) (Judge Thomas Selby III Ellis)

Based upon the "exceptional complexity of the defendant's scheme to defraud", Judge Ellis enhanced the defendant's sentence both under § 2F1.1(b)(2)(A) for more than minimal planning, and under § 5K2.0 as an upward departure based on his conclusion that the case departed from the "heartland" of typical fraud cases.

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