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U.S. v. Lewis, No. 95 CR 300 (SAS) (S.D.N.Y.) (907 F.Supp. 683) (October 16, 1995) (Judge Shira A. Scheindlin)

In this case Judge Scheindlin refused to impose a two-level "sophisticated means" enhancement to a sentence under ยง 2T1.1(b)(2), as recommended by the Government. In one of her typically detailed and well-reasoned analyses, she started by noting that "it is not easy to define the term 'sophisticated means'." Her decision, ...

 

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