U.S. v. Trask, No. CRIM. 00CR10111-NG (D.Mass.) (143 F.Supp.2d 88) (April 20, 2001) (Judge Nancy Gertner)
Here the court held it would be improper to impose a sentence enhancement for abuse of position of trust under U.S.S.G. § 3B1.3 in a stock churning case involving a 90-year old client because that factor was already included in the definition of the crime.
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