Sixth Circuit -- USA v. Lance Poulsen

Securities search, conviction & sentencing upheld 

No error of denial of entrapment instruction where there was no direct inducement.

Existence of phone calls among conspirators were sufficient grounds for the wiretap.

No clear error in denial of Franks hearing.

Not unreasonable for sentencing court to accept government's estimates of loss, as the trigger is not actual losses of that amount, but rather that deft had knowledge of potential losses of that level.

No error in denial of venue change, as neither presumptive nor actual prejudice existed at venue.

Introduction of evidence from obstruction prosecution in securities prosecution is not prejudicial for showing consciousness of guilt, but probative (because showing consciousness of guilt).

No error in introduction of testimony as to losses.

No error in calculation of losses for sentencing purposes.

USA v. Lance Poulsen