Brief filed: 10/19/2009
United States v. Turk
S.D.N.Y.; Case No. 07-CR-1062 (NRB)
Defendants should be sentenced based only upon those losses that their conduct proximately caused. The government’s efforts to limit proximate cause analysis to securities fraud cases are unconvincing and unsupported; application of proximate cause principles will avoid unjust results that conflict with the purposes of the guidelines.
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