U.S. v. Diekemper

Dist. Ct. did not err in sentencing defendant to 120-month term of incarceration on conspiracy to commit bankruptcy fraud and mail fraud charges based, in part on four-level enhancement for his leadership role in directing others, including his wife, to hide $2.5 million in assets from defendant's creditors. Dist. Ct. could properly find that defendant's involvement in scheme was otherwise extensive, without making specific finding as to number of individuals that defendant brought into scheme, where instant scheme concerned approximately nine individuals and large amounts of money over several year period. Moreover, defendant lacked standing to contest condition of term of wife's two-year probation for her role in instant conspiracies where Dist. Ct. prohibited wife from having any contact with defendant for duration of her probation period.