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U.S. v. Achiekwelu, No. 95-5765 (4th Cir.) (112 F.3d 747) (May 1, 1997) (Judge Francis D. Jr. Murnaghan)

Court agreed with the district court's assessment that "the intricacy and sophistication of [the defendant's] scheme were substantially in excess of the typcial fraud case that involves 'more than minimal planning'.".

Case held that the extraordinary complexity of a defendant's fraud can constitute a basis for an upward departure if ...

 

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