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U.S. v. Footman, No. Crim. 98-CR-10067-NG (D.Mass.) (66 F.Supp.2d 83) (June 1, 1999) (Judge Nancy Gertner)

In this case Judge Gertner held that the victims of a prostitution ring, none of whom were included in the indictment, were not "participants" with the leader of the prostitution ring for purposes of justifying a ยง 3B1.1(a) enhancement.

 

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