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U.S. v. Hairston, No. 95-5771 (4th Cir.) (96 F.3d 102) (September 16, 1996) (Judge Diana Gribbon Motz)

Case held that while departures based on the extraordinary complexity of defendant's fraud are rare, they are proper if "present to such an exceptional degree that it cannot be characterized as typical or usual." (Id., at 108).

 

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