EIGHTY-EIGHT EASY DEPARTURES

Downward Adjustment For Role In The Offense Is Inadequate To Show Defendant’s Peripheral Involvement. 13 ... (in bad check and bankruptcy scam, remanded for district court to consider whether to depart downward under 2B1.1 where intended loss of over $1 million “substantially overstated” actual loss of $800); U.S. v. Oligmueller, 198 F.3d ... ................
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