United States v. Philip Andre Rennert, United States of America v. George Raymond Jensen, United States of America v. Michael Lewis Miller (2004)

In United States v. Rennert, building on Collado, we clarified that “[although we required individualized inquiry [in Collado ], we did not impose an immutable requirement that the district court hold extensive hearings to make explicit, particularized findings as to the exact date on which each defendant committed to the conspiracy or the precise contours of each conspirator’s agreement.” 374 F.3d 206, 214 (3d Cir.2004), vacated in part on other grounds, Miller v. United St…

See, e.g., United States v. Thomas, 377 F.3d 232, 241-42 (2d Cir.2004); United States v. Rennert, 374 F.3d 206, 213 (3d Cir.2004); United States v. Serfling, 504 F.3d 672, 679 (7th Cir.2007).

The language of this instruction paraphrased our statement of the law: in United States v. Rennert, we stated that a 56 “fraud victim’s negligence or lack of diligence in uncovering the fraud is not a defense.” 374 F.3d 206, 213 (3d Cir. 2004) (citing United States v. Coyle, 63 F.3d 1239, 1244 (3d Cir. 1995)), vacated on other grounds, Miller v. United States, 544 U.S. 958 , 125 S.Ct. 1744 (2005).

The language of this instruction paraphrased our statement of the law: in United States v. Rennert, we stated that a “fraud victim’s negligence or lack of diligence in uncovering the fraud is not a defense.” 374 F.3d 206, 213 (3d Cir.2004) (citing United States v. Coyle, 63 F.3d 1239, 1244 (3d Cir.1995)), vacated on other grounds, Miller v. United States, 544 U.S. 958 , 125 S.Ct. 1744 , 161 L.Ed.2d 598 (2005).

Although a district court’s inquiry must be individualized to the defendant, Collado “did not impose an immutable requirement that the district court hold extensive hearings to make explicit, particularized findings as to the exact date on which each defendant committed to the conspiracy or the precise contours of each conspirator’s agreement.” United States v. Rennert, 374 F.3d 206, 214 (3d Cir.2004).

United States v. Rennert, 374 F.3d 206, 213 (3d Cir.2004) ("[T]he fraud victim's negligence or lack of diligence in uncovering the *459 fraud is not a defense.”); Coyle, 63 F.3d at 1244 . 50 .

See generally United States v. Rennert, 374 F.3d 206 (3d Cir.2004); United States v. Yeaman, 194 F.3d 442 (3d Cir.1999). 1 Teale, a net *360 work of fraudulent offshore and domestic companies, represented these leased stocks as assets available to pay claims pursuant to reinsurance contracts entered into with a Pennsylvania-based insurance company, the World Life and Health Insurance Company (“World Life”).

See United States v. Duliga, 204 F.3d 97 , 101 n. 2 (3d Cir.2000); see also United States v. Rennert, 374 F.3d 206, 215 (3d Cir.2004) (“[W]e [do] not impose an immutable requirement that the district court hold extensive hearings to make explicit, particularized findings as to the exact date on which each defendant committed to the conspiracy or the precise contours of each conspirator’s agreement.”) (vacated in part on other grounds).

See United States v. Hoffecker, 530 F.3d 137, 177 (3d Cir.2008) (quoting United States v. Rennert, 374 F.3d 206, 213 (3d Cir.2004)).

See United States v. Rennert, 374 F.3d 206, 215 (3d Cir.2004) (affirming attribution of entire conspiracy loss to individual defendant), vacated in part on other grounds and remanded by 544 U.S. 958 , 125 S.Ct. 1744 , 161 L.Ed.2d 598 (2005); United States v. Duliga, 204 F.3d 97, 100-01 (3d Cir.) (same), cert. denied, 530 U.S. 1222 , 120 S.Ct. 2236 , 147 L.Ed.2d 264 (2000); see also Neadle, 72 F.3d at 1110 (“[I]t is not appropriate to reduce the amount of the loss, as compute…

See United States v. Rennert, 374 F.3d 206, 215 (3d Cir. 2004) (affirming attribution of entire conspiracy loss to individual defendant), vacated in part on other grounds and remanded by 544 U.S. 958 (2005); United States v. Duliga, 204 F.3d 97, 100-01 (3d Cir.) (same), cert. denied, 530 U.S. 1222 (2000); see also Neadle, 72 F.3d at 1110 ("[I]t is not appropriate to reduce 50 the amount of the loss, as computed under the Guidelines, in order to reflect other causes of the lo…