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Vern Edwards

Contracting Scandals

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It is not uncommon for defense lawyers to file a motion to set aside a verdict.  The usual ground is insufficient evidence upon which to base a conviction.

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Grasping at straws -  my contract file had his signature on a non-disclosure agreement and on a conflict of interest statement and there was the altered insurance paperwork that was found in multiple contract files during the investigation. 

 

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I just read today (in the LA Times) about a (now former) Deputy City Treasurer in the City of Compton who managed to swipe $3.7 million over six years by "skimming" cash receipts sent to City Hall. He reported the correct value of cash received, but deposited slightly less. Sometimes he took only $1,400 per month, other times much more. Over six years. Allegedly.

The data was there all along. All anybody had to do was compare cash receipts reported as revenue to cash receipts deposited in the bank. Apparently, nobody did.

 

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 I wonder on what grounds the set aside was based? 

The jury verdict was not set aside. The judge accepted the jury's verdict. He was found guilty and went to jail.

I have not found any explanation for why the judge did not go with the DOJ's sentencing recommendation.

I hate to tell you this, guys, but this case was penny ante. Small potatoes. It doesn't really register on the scale of government contracting scandals. I'm surprised it has prompted so many posts.

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Hi Vern

The topic took a turn after GWGerard1102's initial post in this thread.   We all know that this case does not rate anywhere alongside of "Fat Leonard" for the dollars, reach or impact. 

In my prior post I was wondering what basis the defense had to request the verdict to be set aside.  I know it was not set aside. 

I thought we were talking about Contracting Scandals.  "Thrower" may not be a "Fat Leonard", but it was a scandal to DWGerard1102 and those of us involved. 

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1 hour ago, leo1102 said:

Hi Vern

The topic took a turn after GWGerard1102's initial post in this thread.   We all know that this case does not rate anywhere alongside of "Fat Leonard" for the dollars, reach or impact. 

In my prior post I was wondering what basis the defense had to request the verdict to be set aside.  I know it was not set aside. 

I thought we were talking about Contracting Scandals.  "Thrower" may not be a "Fat Leonard", but it was a scandal to DWGerard1102 and those of us involved. 

I agree, Leo.  While not a MAJOR scandal, it affected several peoples' lives and careers. And the title of this thread is "Contracting Scandals", not "Major Contracting Scandals" or "Major Contracting Scandal".

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13 hours ago, leo1102 said:

Hi Vern

The topic took a turn after GWGerard1102's initial post in this thread.   We all know that this case does not rate anywhere alongside of "Fat Leonard" for the dollars, reach or impact. 

In my prior post I was wondering what basis the defense had to request the verdict to be set aside.  I know it was not set aside. 

I thought we were talking about Contracting Scandals.  "Thrower" may not be a "Fat Leonard", but it was a scandal to DWGerard1102 and those of us involved. 

Yes, it was a scandal. And since you love this one so much I've posted the culprit's lawyer's (long) motion for a reduced sentence for his client. It appears that the culprit was a great guy, so much so that the lawyer even invokes the Reverend Martin Luther King, Jr., on his behalf. I mean, if you're going dwell on this one I might as well throw fuel on the fire. I've deleted the lawyer's phone numbers and email address, just in case you guys get too exercised by what you're about to read. 

Remember that the DOJ recommended 60 months in jail and that he got 27 months.

Enjoy. Chat it up. Then please think about finding a new horse to kill. B)

 

Quote

 

UNITED STATES OF AMERICA,

v.

Allen THROWER, Defendant.

No. 08-10292-NMG.

October 18, 2010.

Allen Thrower's Sentencing Memorandum

Respectfully submitted, For the defendant, Allen Thrower, By his attorney, Scott P. Lopez, Bbo # 549556, Lawson & Weitzen, LLP, 88 Black Falcon Avenue, Suite 345, Boston, MA 02210.

Defendant Allen Thrower submits this sentencing memorandum to assist the Court in fashioning a reasonable and appropriate sentence in this case. For the reasons set forth in this memorandum and based on the information and materials provided to the Court and expected arguments at the sentencing hearing, undersigned counsel respectfully suggests that a sentence of (1) probation for a period of five years, with a special condition of home detention for the first 8 months, (2) restitution in the amount of $13,707.00 in lieu of a fine, (3) the required special assessments ($1,000.00); and (4) any additional conditions the Court deems necessary to satisfy the sentencing purposes set forth in 18 U.S.C. § 3553(a) is a reasonable and just sentence under the totality of the circumstances in this case.

Post Booker, this Court can choose a reasonable sentence based on the factors set forth in 18 U.S.C. § 3553(a). The sentence must be “sufficient, but not greater than necessary, to comply with the purposes of sentencing set forth in paragraph 2”, namely: just punishment, adequate deterrence, protection of the public from further crimes by the defendant, the need to avoid unwarranted sentence disparities, and the need to provide restitution. The sentence proposed herein takes these factors into account and accomplishes the purposes of sentencing.

I. HISTORY AND CHARACTERISTICS OF DEFENDANT.

Allen Thrower was born in Somerville, Massachusetts on XX/XX/1952. Seventeen days after his sentencing in this case, he will be fifty-eight (58) years old. According to his wife of twenty-four (24) years, Allen “grew up in an abused home.” His father was an alcoholic who beat him regularly. Allen grew up in abject poverty and went to bed hungry many nights. He worked in the school lunch room so he could receive his daily lunch free at school.

He quit school at the age of 13 to earn money to feed his family. He left home after a serious altercation with his father at the age of 14. When he first left home, he lived in a car until he eventually moved into his half-brother's home. He married his first wife at the age of 16.

In 1971, at the age of 18, Allen enlisted in the United States Army as an Infantryman during the Vietnam War. After more than 25 years of active duty, he earned the rank of Sergeant Major, the highest rank for a noncommissioned officer. He retired from active service on September 1, 1997.

During his years of honorable service, Allen was awarded many medals and awards. According to his Certificate of Release or Discharge from Active Duty (DD Form 214) he received the Legion of Merit, two Meritorious Service Medals, three Army Commendation Medals, the Army Achievement Medal, eight Army Good Conduct Medals, two National Defense Service Medals, four Noncommissioned Officer's Professional Development Ribbons, an Army Service Ribbon and four Overseas Service Ribbons.

In December 2002, Allen returned to government service, taking a civil service position as Supervisory Human Resources Specialist in the Directorate of Military Personnel/Adjutant General. During his civil service career, his many accomplishments included being a key participant and leader in the human resources category for Fort Benning's selection as the Presidential Quality Award Winner, a four-time winner of the Best Installation in the Army Award, the winner of the Georgia Oglethorpe Quality Award, and the Military Human Resources organization's selection as Best in the Army three times.

Most notably, in January 2006, Allen was awarded an Achievement Medal for Civilian Service for exceptional achievement in Military Human Resources Services. Allen was selected for this award by the Garrison Commander at Fort Benning for “outstanding performance results that exceeded excellence goals.” Specifically, Allen ensured that 451 quality assurance reviews were completed with a 96% pass rate, assisted in developing and implementing 48 business process improvements which saved 4-man years and a savings of over $800,000, achieved a 99% pass rate on 2,100 A76 performance standards reviews, achieved a 98% customer satisfaction from AG customers, and supported over 100 MOB/DEMOB operations and 16,722 soldiers. Also, Allen was selected by the Garrison Commander as Quality Expert for his installation transformation/change team and customer service measurement implementation initiative. These achievements reflected great credit for the G1/Adjutant General, the Fort Benning Garrison and the U.S. Army.

Before retiring in 1997, Allen had a long and distinguished record of military service. Before the Indictment was filed in September 2008, Allen was a valuable civil service employee for the Human Resources Directorate. On August 17, 2010, he was terminated from his civil service position as a result of his conviction in this case.

Martin Luther King, Jr. once said: “The true measure of a man is not how he behaves in moments of comfort and convenience, but how he stands at time of controversy and challenges.” Attached to this Memorandum are a letter from Allen Thrower accepting responsibility for his criminal behavior in this case, and fourteen (14) letters from Allen Thrower's wife, daughter, family, friends, professional colleagues, and community leaders which capture the true essence of this man. What is remarkable, indeed, striking about these letters is that they talk about a man who has met many challenges in his life with honor and dignity. They talk about a hard-working, dedicated, law-abiding, religious man who is revered and cherished by the people he has touched during his life. They talk about a man who throughout his life has helped others even when it meant making personal sacrifices. They talk about a man who is loved and respected. They talk about a man who is remorseful and ashamed of his behavior in this case. They talk about a man whose behavior in this matter is an aberration when viewed in the context of his entire life.

For example, his wife relates in her letter that Allen Thrower gives freely at the same time that it is very hard for him to receive something. She notes that Allen is a giving person when someone needs help. He helps without being asked. Mrs. Thrower notes that her mother and stepfather are very ill and they have been a financial hardship for the past 12 years. Nevertheless, Allen has does whatever needs to be done to assist without expecting anything in return.

His daughter relates that her father is a selfless man who repaired homes for those in need without accepting payment in return. She relates how he helped build a habitat for humanity house and supports charitable events and gives back to the community. But, most importantly, she notes how her two children idolize and depend on him and how he participates in their activities including sporting events and reading stories to their class at school.

And, his long time supervisor, James Brinson, who admires Allen as a Patriot and a Soldier, notes that he selflessly served his country for over 25 years as an Infantryman and Human Resources Soldier both in the United States and in forward deployed overseas commands. Mr. Brinson relates that Allen was “an exceptional enlisted Soldier whose accomplishments led to continuous promotion up to the highest non-commissioned officer leadership positions - First Sergeant and Sergeant Major (SGM).” Finally, he relates that SGM Thrower's reputation was that he treated all Soldiers with respect, always placed the mission and needs of others before his own interests, and did what's right in balancing the Army's mission and the individual's problems and needs. And, as a result, SGM Thrower “always handled the most difficult individual Soldier problems.”

Since the Indictment was filed in this case, Allen has also experienced some serious medical issues. In October 2009, Allen required emergency surgery for a herniated disc which resulted from injuring his lower back while lifting a copier that weigh approximately 50 pounds. In March 2010, he had to have a second surgery to fuse his spine at the L4-L5 level. See Redacted discharge summaries attached hereto as Exhibit “A”. Notwithstanding these two surgeries, he is still in a significant amount of pain and continues to treat with his primary care doctor and a pain doctor. He is taking numerous pain medications to cope with the chronic pain he is experiencing.

On September 14, 2010, Allen's primary care doctor indicated that Allen has “little functional capacity for range of motion (ROM) at the lumbar spine.” “He cannot tolerate sitting or standing for more than 10-15 minutes at a time and must use a cane to maintain balance.” Allen is also on “significant pain medication that makes it unsafe for him to drive and interferes with his memory and ability to reason.” See Redacted letter dated September 14, 2010 from Kim J. Zagorski, D.O. attached hereto as Exhibit “B”. Currently, he is not at a medical end and will likely need to have spinal cord stimulator implanted into his spinal cord to manage the chronic pain he is experiencing. See Redacted letter dated October 7, 2010 from Sung Chang, M.C. attached hereto as Exhibit “C”.

II. NATURE AND CIRCUMSTANCES OF THE OFFENSE.

While employed as a civil service employee by the U.S. Army, Allen Thrower used his position as Chief of Quality Assurance to steer government contracts to Military Service Support, Inc. (“MSS”), a company owned by his sister, Marie Cimino. Although MSS and Marie Cimino profited from these contracts in an approximate amount of $1.5 million before taxes, the government did not sustain any losses from awarding the contracts to MSS. Indeed, the evidence at trial was that the government actually saved money on the contracts awarded to MSS. Also, it was undisputed that the services MSS provided to the government were excellent and saved the Army a substantial sum of money.

In addition, the administrative expenses incurred by the government for rebidding the contracts once the scheme was uncovered was less than $14,000. Finally, although Marie Cimino's company made a profit of $1.5 million dollars, Allen received less than $20,000 from his criminal activity.

Given Allen's history and personal characteristics, his behavior in this case is inexplicable because it is so out of character from the man that he is. Indeed, unlike many fraud cases, it does not appear as though Allen was motivated by greed for himself. While it is true that he received some money from his sister during the criminal activity, his “profit” from the offenses was less than $20,000, which is slightly more than 1% of the profit made by his sister. So why did this man of honesty and integrity commit the crimes in this case? The explanation is simple. He was trying to help his sister. However, what he did not fully realize at the time was that he was helping his sister by doing something that was, in fact, morally and legally wrong. He was helping his sister by undermining the government procurement process. He now fully understands the wrongfulness of his conduct and accepts full responsibility as set forth in his letter to the Court. He will not be a repeat offender. Indeed, as a result of his conviction in this case, he will never be in a position to cheat the government again.

III. A SENTENCE OF PROBATION WITH A CONDITION OF HOME CONFINEMENT IS SUFFICIENT, BUT NOT GREATER THAN NECESSARY, TO ACHIEVE THE SENTENCING PURPOSES OF 18 U.S.C. § 3553(a).

18 U.S.C. § 3582 instructs the Court to “consider the factors set forth in section 3553(a) to the extent they are applicable, recognizing that imprisonment is not an appropriate means of promoting correction and rehabilitation.” (Emphasis added). In determining the proper sentence in this case, it is also important to note that “the starting point for every sentence should be probation or some other sentence not involving commitment or confinement.” American Bar Association Project on Minimum Standard for Criminal Justice, Sentencing Alternatives and Procedures, (Approved Draft, 1968), Section 2.3(e), pp. 72-73.

The “first offender” philosophy in sentencing policy generally encourages lower sentences for offenders who have little or no prior criminal record. This philosophy, which can be derived directly from the guidelines Chapter Four introductory commentary, postulates that first offenders are less culpable and less likely to reoffend. As such, they are deserving of reduced punishment.

Through 28 U.S.C. § 994(j), Congress incorporated the “first offender” philosophy into statutory law and the sentencing guidelines when it directed the Sentencing Commission to “insure that the guidelines reflect the general appropriateness of imposing a sentence other than imprisonment in cases in which the defendant is a first offender who has not been convicted of a crime of violence or an otherwise serious offense....”

In this case, there are a number of factors which weigh in favor of a sentence of probation. Specifically, Mr. Thrower's age, first offender status, employment, education, family circumstances, abstinence from drug use, non-violent offense and distinguished military service make his risk of recidivism almost non-existent.

A. Allen Thrower's History and Characteristics Justify a Sentence of Probation.

Age is a powerful component of recidivism prediction, which the Guidelines do not take into account. Indeed, U.S.S.G. § 5H1.1 states: “Age (including youth) is not ordinarily relevant in determining whether a departure is warranted. However, age may be a reason to depart downward in a case in which the defendant is elderly and infirm or where a form of punishment such as home confinement might be equally efficient as and less costly than incarceration....” Elderly offenders, whether or not seriously infirm, suffer greater punishment in prison because they are at risk of being preyed upon by younger inmates and lack social support. See Correctional Health Care, Addressing the Needs of Elderly, Chronically Ill, and Terminally Ill Inmates, U.S. Department of Justice, National Institutes of Corrections, p. 9 (2004 ed.), available at http://www.nicic.org/Library/018735.

Moreover, it is well established that the risk of recidivism drops dramatically in defendants who are forty and older, which lessens the need to protect the public from further crimes of the defendant pursuant to 18 U.S.C. § 3553(a)(2)(C). See United States Sentencing Commission, Measuring Recidivism: The Criminal History Computation of the Federal Sentencing Guidelines at 12 (“Recidivism rates declines relatively consistently as age increases,” from 35.5 % under age 21, to 9.5% over age 50) available at http:// www.ussc.gov/publicat/Recidivism General.pdf. Indeed, for first-time offenders over the age of 50, the recidivism rate is even lower at 6.2%. Id. at p. 28; see also, United States v. Thomas, No. 03- CR-30033-MAP, slip op. at *13 (D.Mass. March 14, 2005)(Ponsor, J.)(defendant, at the time of his release in his late 50's or early 60's, will offer no danger to the community); Simon v. United States, 361 F. Supp. 2d, 35, 48 (E.D.N.Y. March 17, 2005)(noting guidelines' failure to account for a defendant's recidivism rate renders them an imperfect measure of how well a sentence protects the public from further crimes of the defendant).

In 2004, the Commission reported that in fiscal year 1992, more than 49% of federal offenders were first offenders; in fiscal year 2001, the more than 40% (42.2%) of federal offenders were first offenders. See Recidivism and the First Offender at 4 (May 2004) (hereinafter “First Offender ”) available at http:// www.ussc.gov/publicat/Recidivism_FirstOffender.pdf.

As a group, first offenders are more likely to be involved in less dangerous offenses and their offenses involve fewer indicia of culpability, such as the use of violence or weapon, no bodily injury and acceptance of responsibility. Id. 9-10. They are also more likely than offenders with criminal histories to have a high school diploma and to be employed. Id. at 6-11. Most importantly, research has found that offenders are most likely to recidivate when their sentence is straight prison time, as opposed to probation or split sentences. See Measuring Recidivism at 13 & Exhibit 12 (May 2004).

However “first offender” status is defined1, the rate of recidivism (including reconviction, rearrest or revocation) for first offenders is 11.7%, which is significantly lower that the rate of 22.6% for offenders with one criminal history point, or that of 36.5% for offenders with two or more criminal history points. First Offender, supra at 13-14. Even more interesting, the rate of reconviction also is much lower. Indeed, offenders with zero criminal history points have a reconviction rate of 3.5%, those with one point have a reconviction rate of 5.5% and offenders with two or more points have a reconviction rate of 10.3. Id. at 13-14, n. 25, 26 & 27. Thus, Allen Thrower's first offender status makes it likely that he will never reoffend.

Moreover, other factors further demonstrate that a prison sentence is unnecessary to serve the purposes of sentencing in this case. Stable employment in the year prior to arrest is also associated with a lower risk of recidivism (19.6 %) than for those who are unemployed (32.4%). Recidivism rates also decrease with increasing educational levels - no high school (31.4%), high school (19.3%), some college (18%), college degree (8.8%). College graduates who are married have a lower rate of recidivism than those who are not. Similarly, for offenders with no history of illicit drug use, the recidivism rate is half that of those who do have a drug history. Also, non-violent offenders sentenced under the fraud guidelines are also least likely to recidivate. Thus, for offenders like Allen Thrower whose combined age, first offender status, stable employment and family life, education, non-violent offense and abstinence from drug use, his rate of recidivism is essentially non-existent. Indeed, the Commission's own research has found that the lengthy sentence will only increase the likelihood of his recidivism which clearly is counterproductive. See Measuring Recidivism, supra at 13 & Exhibit 12.

Finally, our nation has a long tradition of according leniency to veterans in recognition of their service. See Porter v. McCollum, 130 S.Ct. 447, 455 (2009). Allen Thrower's distinguished military career is another reason why a sentence of probation is appropriate in this case. Indeed, the Amendment to the Guidelines § 5H1.11 that will go into effect next week distinguishes between military service and other circumstances covered by § 5H1.11. As amended, the policy statement provides that military service “may be relevant in determining whether a departure is warranted, if the military service, individually or in combination with other offender characteristics, is present to an unusual degree and distinguishes the case from the typical cases covered by the guidelines.” It is clear that Allen's long and distinguished military career in combination with his other offender characteristics distinguishes this case from the typical cases covered by the guidelines and provides an additional justification for a sentence of probation.

B. The Collateral Consequences Of Allen Thrower's Conviction And The Collateral Consequences Of A Sentence Of Imprisonment Justify A Sentence Of Probation.

As noted above, Allen Thrower has already been terminated from his civil service position at Fort Benning as a result of his conviction in this case. The Army is also in the process of terminating his workers' compensation payments which he is appealing with the assistance of a lawyer that he had to privately retain before attorney's fees are not recoverable under the Federal Employees Compensation Act. Moreover, if Allen receives a sentence of imprisonment, his workers' compensation benefits will be suspended during any period of incarceration even if he wins his appeal. If he is incarcerated, he will also not receive the medical treatments that his doctors are now recommending. In addition, a prison sentence will also result in the loss of some or all of his veteran's disability payments. See Incarcerated Veteran's Program Frequently Asked Questions at http:// www.vba.va.gov/bln/21/Benefits/Incarcerated/incarcfaq.htm

C. A Sentence of Probation Is Sufficient To Satisfy the Sentencing Purposes Set Forth In 18 U.S.C. § 3553(A)(2), (A)(6) AND (A)(7).

1. The Purposes of Sentencing

18 U.S.C. § 3553(a) provides that “[t]he court shall impose a sentence sufficient, but not greater than necessary, to comply with the purposes set forth in paragraph (2) of this subsection.”

Paragraph (2) in turn directs the court to consider the need for the sentence imposed -

(A) to reflect the seriousness of the offense, to promote respect for the law, and to provide just punishment for the offense;

(B) to afford adequate deterrence to criminal conduct;

(C) to protect the public from further crimes of the defendant; and

(D) to provide the defendant with needed educational or vocational training, medical care, or other correctional treatment in the most effective manner.

Paragraph (6) also requires the Court to avoid unwarranted disparities and paragraph (7) also directs the Court to consider “the need to provide restitution to any victims of the offense.” 18 U.S.C. § 3553(a)(7).

In this case, a sentence of probation for a period of five years, with a special condition of home detention for the first 8 months and restitution in the amount of $13,707.00 in lieu of a fine is sufficient to achieve the purposes of sentencing set forth in § 3553(a)(2) and (a)(7).

Congress has authorized probation for a broad range of offenses and offenders, i.e., for any offense with a statutory maximum below 25 years so long as probation is not expressly precluded and a defendant is not sentenced to prison for a non-petty offense at the same time. See 18 U.S.C. § 3561(a); 18 U.S.C. § 3559(a). The Sentencing Commission recently reported that:

“Effective alternative sanctions are important options for federal, state and local criminal justice systems. For the appropriate offenders, alternatives to incarceration can provide a substitute for costly incarceration.” See United States Sentencing Commission, Alternative Sentencing in the Federal Criminal Justice System, at 2-3 (2009) at http://www.ussc.gov/general/20090206_ Alternatives.pdf. This report also confirms that non-prison alternatives are under-used in federal court. Id. at 5.

Under past practice, the threshold question in most cases was whether to impose a sentence of imprisonment. The relevant considerations were whether public safety required incarceration, what the defendant's risk of recidivism was, what his treatment and medical needs were, and what collateral effects imprisonment would have on family and employment.

Congress expected that the threshold question in most cases would continue to be whether probation was sufficient or whether prison was necessary. In 18 U.S.C. § 3582(a), Congress instructed:

The court, in determining whether to impose a term of imprisonment, and if a term of imprisonment is to be imposed, in determining the length of the term, shall consider the factors set forth in section 3553(a) to the extent they are applicable, recognizing that imprisonment is not an appropriate means of promoting correction and rehabilitation.

Thus, Congress intended that probation would be used with at least the same frequency as before the guidelines. Indeed, Congress even identified when probation should be the presumptive sentence. 28 U.S.C. § 994(j) instructed the Commission to ensure that the guidelines reflect the “general appropriateness of imposing a sentence other than imprisonment in cases in which the defendant is a first offender who has not been convicted of a crime of violence or an otherwise serious offense.” Moreover, among the various factors to consider when determining the appropriateness of a sentence of probation is an offender's health problems.

2. Seriousness of the Offense, Promoting Respect for the Law and Just Punishment.

Probation is not an easy sentence. It is restrictive and punitive. Allen will be reminded every day that he is on probation that his freedoms are restricted and he is being punished. He will also be required to make weekly or monthly payments of restitution, which will serve as an additional reminder that he is being punished and is being required to pay his debt to society.

Most importantly, Allen has been punished by losing what is most precious to him - his reputation. Indeed, Allen has already endured the humiliation and embarrassment of his crimes each time saw his name in the newspaper or on local television and each time he has told friends and family what he did wrong in this case.

In addition, a sentence that is excessive in light of the seriousness of the offense promotes disrespect for the law and provides unjust punishment. Seriousness of an offense may be lessened, for example, when the crime was victimless or was non-violent offense. Moreover, an offense can be considered less serious if restitution can be made in whole or in part, if a defendant's motives were not entirely egregious, if no actual loss occurred, or if a defendant's gain from the offense was comparatively minor. In this case, Allen has the capacity to make restitution to the government. Moreover, his motives, while wrong, also included the good motive of helping his sister. Also, no loss to the government occurred and Allen's gain from the offense was comparatively minor. Thus, a long prison sentence in light of the actual seriousness of the offense in this case would promote disrespect for the law and provide unjust punishment.

Accordingly, a sentence of probation and restitution in full is sufficient to reflect the seriousness of the offense, to promote respect for the law, and to provide just punishment for the offense.

3. Adequate Deterrence

Incarceration or incapacitation of Allen is not necessary to deter him in the future. Incarcerating Allen is not necessary to deter others in the future. Given Allen's distinguished military and civilian service to his county, the public will understand that a sentence of probation and restitution is sufficiently punitive when the crime is non-violent and purely financial. Indeed, requiring Allen to pay back all the money he cost the government because of his conduct is the most effective deterrence to him and others in the future.

Moreover, while many believe that the higher the sentence, the greater effect in deterring others, the empirical evidence shows no relationship between sentence length and deterrence. Indeed, in one of the best studies of specific deterrence, which involved federal white collar offenders in the pre-guideline era, no difference in deterrence was found even between probation and imprisonment. See David Weisburd, et al., Specific Deterrence in a Sample of Offenders Convicted of White-Collar Crimes, 33 Criminology 587 (1995). That is to say, offenders given terms of probation were no more or less likely to reoffend than those given prison sentences. As such, a sentence of probation will provide adequate deterrence in this case.

4. Protection of the Public

Without repeating what is stated above, the chance of Allen recidivating is as close to non-existent as possible. In addition to the factors present that indicate that his risk of recidivism is very low, the most glaring reason to believe that Allen will never commit another crime in the future is because he has never committed a crime in the past. Indeed, his conduct in this case is completely out of character for this man.

5. Avoiding An Unwarranted Disparity.

Another reason why a sentence of probation is justified in this case is to avoid unwarranted sentence disparities among defendants with similar records who have been found guilty of similar conduct. See 18 U.S.C. § 3553(a)(6). As the Court knows, Allen's named co-conspirator in this case, Marie Cimino, was sentence to 24 months of probation on Count 10 of the original Indictment. Subsequently, the government filed a Superseding Indictment against Allen charging him with a conspiracy to defraud the United States, which is also the offense that increased the low end of the Advisory Guideline Range (“AGR”) from a level 8 under U.S.S.G. § 2B1.1 to a level 97 under U.S.S.G. § 2C1.1. Fortunately, even the Guidelines permit a “sentencing court [to] control any inappropriate manipulation of the indictment through use of its departure power.” See U.S.S.G. Ch. 1, Part A, subpart 4. Not doing so in this case will result in the person who profited to the tune of $1.5 million dollars receiving a sentence of probation at the same time that Allen receives a lengthy and unjust prison sentence. Also, a sentence of probation will avoid an unwarranted disparity among defendants with similar records besides Marie Cimino who have been found guilty of similar conduct as required by 18 U.S.C. § 3553(a)(6).

6. The Need To Provide Restitution.

Finally, a sentence of probation will permit Allen Thrower to pay restitution to the government which is another factor that is to be considered under § 3553. See 18 U.S.C. § 3553(a)(7).

IV. THE ADVISORY GUIDELINE RANGE IS FAR GREATER THAN NECESSARY TO ACCOMPLISH THE GOALS OF SENTENCING.

The Advisory Guideline Range (“AGR”) in this case is far greater than necessary to satisfy the goals of sentencing. The draconian sentencing recommendation contained in U.S.S.C. § 2C1.1 is not based on past practice, empirical data or national experience. When a guideline is not based on past practice, empirical data or national experience, it “does not exemplify the Commission's exercise of its characteristic institutional role,” and it is not an abuse of discretion to categorically reject it even in a “mine-run case.” See Kimbrough v. United States, 128 S.Ct. 558, 57 (2007).

A. The Low End Of The Advisory Guideline Range Under U.S.S.C. § 2C1.1 (Conspiracy to Defraud Guideline) Is Twelve Times Longer Than The Low End Of the Advisory Guideline Range Under U.S.S.C. § 2B1.1 (Wire Fraud Guideline).

In this case, the low end of the AGR under § 2C1.1 is 97 months while the low end of the AGR under § 2B1.1 is 8 months. As such, the low end of the AGR under § 2C1.1 is 12 times longer than the low end of the guideline under § 2B1.1. One of the principal reasons for this wide discrepancy is that the “loss” under § 2B1.1 is defined as the “reasonably foreseeable administrative costs to the government ... of repeating or correcting the procurement action affected”, which in this case was estimated to be less than $14,000.00. See § 2B1.1, Application Note 3(A)(v)(II). Because the $14,000 “loss” only results in a 4-level adjustment under § 2B1.1, the resulting AGR is an 11 or an advisory sentence of 8-14 months. See § 2B1.1(b)(C).

Under § 2C1.1(b)(2), “loss” is determined in accordance with Application Note 3 of the Commentary to § 2B1.1. However, when there is no loss, then the enhancement is determined by the value of “the benefit received or to be received” which means the net value of such benefit. Thus, under this definition, the “benefit received” includes the profits earned by MSS or $1.5 million dollars. See 2C1.1, Application Note 3, Example B; United States v. Harvey, 532 F.3d 326 (4th Cir. 2008)(profit margin in the contract is the benefit received). Thus, in a case like the present one, where there was no loss, the guidelines nevertheless enhance the ABR by applying the Loss Table contained in § 2B1.1(b). In other words, the guidelines, as written, produce the absurd result of applying the Loss Table to a fact scenario where no loss occurred.

B. The High End Of The Advisory Guideline Range Under U.S.S.C. § 2C1.1 (121 Months) Is Two Times Longer Than The Statutory Maximum In 18 U.S.C. § 371 (60 Months).

A second absurdity in the AGR is that the high end of the AGR is two times longer than the statutory maximum contained in 18 U.S.C. § 371. The statutory maximum in § 371 is five years or 60 months. This statutory maximum is evidence of Congress' intent that a person convicted of conspiracy to defraud the United States should serve no more than five years in prison regardless of his criminal history. Nevertheless, the high end of the AGR is 121 months. Of course, this high end is a permissible sentence under the Guidelines because Allen has also been convicted of multiple counts of wire fraud which carry a statutory maximum of 20 years. See U.S.S.C. § 5G1.2(d)(allowing consecutive sentences until the combined sentence equals the total punishment).

As a result, the wire fraud counts result in a 8-14 month sentence in Zone B, whereas the conspiracy to defraud count results in a 97-121 month sentence in Zone D, which is a sentence that is 37 months longer than the statutory maximum on the low end and 61 months longer than the statutory maximum on the high end, which is nonetheless permissible because the guidelines allow the Court to consecutive sentences to reach the guideline range. In short, the guidelines make no sense in this case.

C. The Advisory Guideline Range Under U.S.S.C. § 2C1.1 Does Not Reflect Sound Policy And Is Not Based On Empirical Data, National Experience Or Any Rational Policy Basis.

When the Sentencing Commission fails to fulfill “its characteristic institutional role” of developing a particular guideline, or its later amendments, based upon empirical data, national experience or some rational policy basis, the Court has the discretion to conclude that the resulting advisory range “yields a sentence ‘greater than necessary’ to achieve § 3553(a)'s purposes.” Kimbrough, supra at 575. Over the years, the Sentencing Commission has dramatically increased sentences for fraud without empirical support, without adequate consideration of the cumulative effect of overlapping enhancements, and despite research showing that shorter sentences provide adequate deterrence for white collar offenders. Accordingly, the Court should give minimal weight to the AGR in this case. See Spears v. United States, 129 S.Ct. 840, 843 (2009)(explaining that when the Commission fails to fulfill its institutional role, a district court can vary from the guidelines “based on policy disagreement with them, and not simply based on an individualized determination that they yield an excessive sentence in a particular case”).

When the Sentencing Commission adopted the original guidelines in 1987, it sought to ensure that white collar offenders faced “short but definite period of confinement.” U.S. Sentencing Commission, Fifteen Years of Guidelines Sentencing: An Assessment of How Well the Federal Criminal Justice System is Achieving the Goals of Sentencing Reform, at 56 (Nov. 2004)(hereinafter “15-Year Report”). The Commission thus reduced the availability of probation and adopted a fraud guideline that subjected more defendants to prison. To justify this increase, the Commission explained that “the definite prospect of prison, though the term is short, will act as a significant deterrent to many of these crimes, particularly when compared with the status quo where probation, not prison, is the norm.” USSG, ch. 1, intro., part 4(d)(1987). Thus, in the pre-guideline era, probation and not prison was the “norm” for white collar offenders.

Unfortunately, over the years, the Commission has abandoned its original goal of ensuring “short but definite” sentences and has instead steadily increased the prison sentences for fraud offense including conspiracy with intent to defraud the United States. The offense of conspiracy to defraud the United States, which is currently covered by U.S.S.G. § 2C1.1, was originally covered by U.S.S.G. § 2C1.7. U.S.S.G. §2C1.7 was initially adopted in November 1, 1991. See Appendix C, Amendment 368. At the time of its adoption, the only reason given by the Commission was to provide “an additional guideline to cover certain offenses that involve public corruption” that did not fall within the other guidelines contained in Chapter Two. Originally, the Base Offense Level was a Level 10. However, the Commission did not explain how or why it reached this result. Originally, the Specific Offense Characteristics were tied to the Fraud and Deceit Table set forth in § 2F1.1. However, the Commission also did not explain how or why it arrived at this conclusion either. Finally, the Original guideline did not include language that permitted the value of the “benefit received” to be the profit from a government contract as the current § 2C1.1 provides.

In the years after its adoption, § 2C1.7 remained for the most part the same. However, as the loss amounts continued to increase under § 2F1.1, so did the resulting guideline range under and § 2C1.7. The biggest change, however, occurred in 2004, when § 2C1.7 was deleted and the offense of conspiracy to defraud was consolidated into § 2C1.1 by virtue of Amendment 667, which was adopted on November 1, 2004.

The new §2C1.1 raised the Base Offense Level from a 10 to a 14, if the defendant was a public official. Also, by consolidating §2C1.7 into § 2C1.1, the “benefit received” language, which was not in § 2C1.7 now became applicable to a conspiracy to defraud the United States offense. The Commission's reason for the Amendment 667 reflected the “Commission's conclusion that, in general, public offenses previously did not receive punishment commensurate with the gravity of the offense.” Moreover, with respect to the increased offense levels for public officials, the Commission noted that the increased levels reflected its “view that offenders who abuse their positions of public trust are inherently more culpable than those who seek to corrupt them, and their offenses present a somewhat greater threat to the integrity of governmental processes.”

However, what the Commission did not say was that these changes were based on past practice, or empirical data or national experience. Rather, the changes reflected their “view” or opinion that longer sentences were necessary to satisfy the goals of sentencing. Because § 2C 1.1 is not based on past practice, empirical data or national experience, it “does not exemplify the Commission's exercise of its characteristic institutional role,” and, this Court is, therefore, free to categorically reject it.” Kimbrough supra at 57. Undersigned counsel respectfully requests that the Court do so in this case.

V. A SUBSTANTIAL VARIANCE IS NECESSARY TO ACHIEVE THE GOALS OF SENTENCING IN THIS CASE.

If the Court is not inclined to categorically reject the application of § 2C1.1 in this case, then Allen Thrower respectfully submits that a substantial variance is necessary to achieve the goals of sentencing. Specifically, as substantial variance is necessary to avoid an unwarranted disparity between his sentence and his sister's sentence. A variance is also necessary to avoid unwarranted sentencing disparities between Allen Thrower and similarly situated defendants who have received substantial variances from other courts. Indeed, substituting the Offense Level for the wire fraud convictions under $2B1.1, or a AGR of 11, seems the most appropriate Offense Level in this case, resulting in a 8-14 month sentence.

In addition, several aspects of Allen Thrower's offense conduct and his individual characteristics support a variance. Without repeating all of his arguments for a sentence of probation here, these factors include, that his motivation was to help his sister, he has an exceptionally low risk of recidivism, his criminal conduct in this case was aberrant when viewed in the context of his entire life, he has already lost his job which will prevent him from committing any government procurement fraud crimes in the future, his current medical condition will make a sentence of imprisonment extremely difficult for him to serve, and his long and distinguished military career warrants a more lenient sentence.

Finally, if the Court is nevertheless inclined to impose a sentence of imprisonment, undersigned counsel respectfully requests the Court to impose a short but definite sentence of confinement that does not exceed 12 months and one day and includes a recommendation that he serve his sentence at Federal Prison Camp Montgomery, located at the Maxwell Air Force Base in Montgomery, Alabama, so he can be close to his family during his imprisonment.

VI. CONCLUSION.

In conclusion, undersigned counsel respectfully suggests that a sentence of (1) probation for a period of five years, with a special condition of home detention for the first 8 months, (2) restitution in the amount of $13,707.00 in lieu of a fine, (3) the required special assessments; and (4) any additional conditions the Court deems necessary to satisfy the sentencing purposes set forth in 18 U.S.C. § 3553(a) is a reasonable and just sentence under the totality of the circumstances in this case. Alternatively, if the Court decides that it must impose a sentence of imprisonment, undersigned counsel respectfully requests the Court to impose a short but definite sentence of confinement that does not exceed 12 months and one day and includes a recommendation that he serve his sentence at Federal Prison Camp Montgomery, located at the Maxwell Air Force Base in Montgomery, Alabama, so he can be close to his family during his imprisonment.

Respectfully submitted,

For the defendant,

ALLEN THROWER,

By his attorney,

/s/ Scott P. Lopez

Lawson & Weitzen, LLP

88 Black Falcon Avenue, Suite 345

Boston, MA 02210

Dated: October 18, 2010

Footnotes

1. Whether the status “first offender” is defined as individuals with a zero criminal history points, individuals with a Criminal History Category I, or individuals with no prior convictions, Thrower qualifies as a first offender.


 

 

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Ignore the strikeout in the last few paragraphs of the last post. It's from some kind of coding glitch in Wifcon's software.

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When anyone has a court case to place on a board, please notify me and I will upload it.  It takes a few moments and I can be contacted by PM.

The software has a text editor called BBB or something like it.  It automatically edits text when it sees fit.  It is especially hard on a legal site--such as Wifcon.com.  It will get kicked off when there is an [ ] indent.  To remove the editor's choice of editing, I must search the raw text and hope I can identify the offending punctuation.

In the above case, I removed all the strike-out text but could not find the offending text.  As a result, all the time I spent editing the raw code was for naught.  

I contacted the software writer--Invision Power Services--over a year ago and they said that they would delete the text editor in the future.

It is my guess, that the offending text is here.

“short but definite period of confinement.”   If you notice, period looks as if it should be plural.  That apparently pissed off the bbb editor.

 

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Contracting scandals are as American as apple pie. Here is a partial list from DOJ of indictments in Fat Leonard and Afghanistan cases, with links to judgments and sentences when available. Even I was shocked by the number.

https://www.justice.gov/criminal-fraud/procurement-fraud

And try Googling "contracting officer convicted"

Check this out:

https://www.publicintegrity.org/2015/05/05/17268/us-military-personnel-have-been-convicted-50-million-worth-crimes-iraq-and

Here's an Army Corps of Engineers program manager who got 88 months:

https://www.washingtonpost.com/local/ex--army-corps-official-sentenced-in-contracting-scheme-of-historic-proportions/2013/07/11/7d8ba21e-ea21-11e2-a301-ea5a8116d211_story.html?utm_term=.c460b9e42f2f

Reading some of this stuff has to make you wonder about the whole enterprise of government contracting.

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35 minutes ago, Vern Edwards said:

Reading some of this stuff has to make you wonder about the whole enterprise of government contracting.

Government contracting is not an enterprise separate from the people who practice it, and from the supervisors and managers who review and approve the practitioners' decisions.

As always, it's about people. People are the first line of defense against fraud, waste, and abuse.

In any large group you find a Bell curve distribution. If we assume the mean is "ethical" then in any large group you will find some people a couple of deviations away from the mean. Same thing if we assume the mean is "knowledgeable" or "well trained" or even "intelligent". In every organization, you need robust internal controls and a top-notch internal review function. Not because of the folks who are at the mean of the distribution, but because of those who are a couple of deviations away from it. Unfortunately, you need the other stuff (including business systems) because of the small fraction of people who are way over on the distribution tail--lacking in integrity and knowledge and expertise.

When you get a confluence of people in the same organization, from the bottom to the top of the decision cycle, all of whom are way over on the distribution tail--and you couple that weak with or non-existent internal controls--then you get Fat Leonard.

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help:

39 minutes ago, here_2_help said:

In any large group you find a Bell curve distribution. If we assume the mean is "ethical" then in any large group you will find some people a couple of deviations away from the mean. Same thing if we assume the mean is "knowledgeable" or "well trained" or even "intelligent". In every organization, you need robust internal controls and a top-notch internal review function. Not because of the folks who are at the mean of the distribution, but because of those who are a couple of deviations away from it. Unfortunately, you need the other stuff (including business systems) because of the small fraction of people who are way over on the distribution tail--lacking in integrity and knowledge and expertise.

Assuming that the scoundrels are outliers and that there will always be outliers, do you think instances of unethical and criminal behavior can be reduced through better

  1. screening,
  2. selection,
  3. education, and
  4. training?

Or do you think the workforce is as good as it can get and we simply need better oversight--i.e., more investigators?

Do you think the cases that have been discovered are merely the tip of the iceberg, or do you think the problem is not as great as it seems? 

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24 minutes ago, Vern Edwards said:

help:

Assuming that there will always be outliers, do you think instances of unethical and criminal behavior can be reduced through better

  1. screening,
  2. selection,
  3. education, and
  4. training?

Or do you think the workforce is as good as it can get and we simply need better oversight--i.e., more investigators?

Do you think the cases that have been discovered are merely the tip of the iceberg, or do you think the problem is not as great as it seems? 

Vern,

1. Yes, you need to screen and select better. You need to educate better. You need to develop your high potentials earlier and better, and fast track them. You need to identify your weak performers and move them out of critical positions more quickly.

2. You need to incentivize correct behavior better, and punish incorrect behavior more strongly and publicly. For example, if a CO chops off on a DCAA audit report without using independent business judgment (TM) to evaluate it, or if a CO abdicates approval of a business system to DCAA (both recent cases) then should that CO continue to hold a certificate of appointment? If the CO's supervisor and managers all blessed those decisions, should they continue to hold their positions?

3. The workforce is absolutely not as good as it can get. The leadership is absolutely not as good as it can get. We need more and better. PLUS we need more and better internal controls and knowledgeable investigators. I am not impressed with the DODOIG either; I would advocate a complete revamp of that function as well. (Since we're dreaming ....)

4. Yes, tip of the iceberg. Ask any compliance person. It starts with "tone at the top". Or as somebody once told me: "As above, so below."

 

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9 minutes ago, here_2_help said:

You need to incentivize correct behavior better....

help:

Aside from a paycheck and appropriate, timely promotions, what kinds of incentives?

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Compensation and promotion are obviously two time-honored approaches. For a government workforce, I would make public acknowledgement another vector of incentivization. In the military, people are written up for medals. Why not a similar approach for the civil service that supports the military? Do the same for civilian agencies. Write people up, submit nominations for medals or whatever, have the nominations scrutinized and confirmed. Then publicize what the winners did well, hold a public ceremony and give them a medal or a certificate or something similar. Make sure their peers know why the award was awarded. Make sure as many people as possible know why it was earned. Spread the word.

Annually, hold a conference for all winners of the acquisition medal of excellence (or whatever you want to call it). Give them a tough problem to solve and tell them to solve it. If they do, publicize that as well. If they don't then maybe the problem cannot be solved short of legislative means.

None of this is rocket science. It's how organizations have achieved excellence for a hundred years or more.

P.S. I'm not talking about one or two Hammer Awards. I'm talking about commendations and ribbons and medals and certificates, awarded to a lot of people who are doing the right thing for the right reasons. Have different grades of award depending on what the nomination says. If a leader of a certain department can't find anybody to nominate, or if the nominations are consistently rejected for lack of substance, then that points to a different problem that needs to be solved.

P.P.S. Don't discount compensation and promotions, neither of which the Federal government does well in my opinion.

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On ‎4‎/‎3‎/‎2017 at 11:26 AM, Vern Edwards said:

help:

Aside from a paycheck and appropriate, timely promotions, what kinds of incentives?

In my case it would have been simply to act on the information that was provided, do the right thing and inspire confidence that when malfeasance is discovered, leadership will do something about it rather than punish the one who found the evidence.  I was not looking for a promotion, I simply respected the concept of integrity, honesty and ethical work, and when I found something that did not match those ideals to the point of criminal behavior, I reported it.  The real failure was how my leadership handled it, I was ridiculed, told to shut up and go back to work and that my evidence was "weak" despite it being well documented with photos of non-existent lay down area, no work being conducted despite more than 50% of invoices approved by the PM, and evidence of earlier fraudulent work being signed off on.

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DW, when something goes wrong in an organization, management frequently considers it to be a negative reflection on its management ability.  Therefore, while disappointing to receive the  reaction you did,  it should not be all that surprising.

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3 hours ago, Retreadfed said:

DW, when something goes wrong in an organization, management frequently considers it to be a negative reflection on its management ability.  Therefore, while disappointing to receive the  reaction you did,  it should not be all that surprising.

Are you kidding? Surprising? Yes! Shocking? Yes! Disgusting? YES!

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No, I am not kidding.  You and I must have traveled different roads if this is all that surprising to you.  I agree it is shocking and disgusting that government personnel would not be ticked off that fraud had happened on their watch and want to do whatever is necessary to get it eradicated.  However, DW's experience is not uncommon for whistleblowers.

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These things run in cycles, sort of like the Wall Street scandals.  The general presumption is that 10-15 years is about the time it takes a major scandal to be washed from the collective memory.

When I came in, it was Ill Wind.  I remember the NCIS guys coming into the ballroom in Crystal City to basically scare the crap out of the workforce with their presentation (the surveillance photos of the evaluation report in the back window of a contractor's car still sticks.)

Then came Darleen Druyun and her tankers.

Then came Fat Leonard and his ship husbanding.

What will it be in 2025?  Something to do with our Robot Overlords perhaps?

 

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On 4/3/2017 at 1:30 PM, here_2_help said:

Write people up, submit nominations for medals or whatever, have the nominations scrutinized and confirmed.

So the Darleen Druyun fiasco was because she wasn't promoted, compensated, or recognized enough?  I beg to differ: the Darleen Druyun fiasco was precisely a result of someone who was promoted, recognized, and compensated to the point where she had little to no oversight because she was such a recognized expert.  She wasn't sent to prison for misapplying the FAR.

What you describe would be effective (maybe) at the GS-9/11  level, but you will note one commonality in all these corruption scandals: not one of them was attributable to the disgruntlement of an uncompensated, unrecognized, minion.  They were all deliberate actions taken by high-level people who knew exactly what they were doing.

As I've see it, it's simple abdication of responsibility. It's people ceding their power and responsibility to others who want that power and responsibility, simply because it was easier to do so. It's wanting the job, but not the responsibility that comes with it (the Holy Grail of the non-supervisory GS-15 comes to mind).  It's not speaking out when you know something is wrong, even when you have more job protections than practically anyone else on the planet. It's about the strong bullying the weak.   It's about character, or lack thereof.

A little more than a laser-printed Attaboy and a catered lunch is required to fix that, I'm afraid.

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43 minutes ago, REA'n Maker said:

So the Darleen Druyun fiasco was because she wasn't promoted, compensated, or recognized enough?  I beg to differ: the Darleen Druyun fiasco was precisely a result of someone who was promoted, recognized, and compensated to the point where she had little to no oversight because she was such a recognized expert.  She wasn't sent to prison for misapplying the FAR.

What you describe would be effective (maybe) at the GS-9/11  level, but you will note one commonality in all these corruption scandals: not one of them was attributable to the disgruntlement of an uncompensated, unrecognized, minion.  They were all deliberate actions taken by high-level people who knew exactly what they were doing.

As I've see it, it's simple abdication of responsibility. It's people ceding their power and responsibility to others who want that power and responsibility, simply because it was easier to do so. It's wanting the job, but not the responsibility that comes with it (the Holy Grail of the non-supervisory GS-15 comes to mind).  It's not speaking out when you know something is wrong, even when you have more job protections than practically anyone else on the planet. It's about the strong bullying the weak.   It's about character, or lack thereof.

A little more than a laser-printed Attaboy and a catered lunch is required to fix that, I'm afraid.

Excellent use of a strawman argument! I congratulate you for successfully arguing against something I did not post.

Please, proceed.

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