Fourth Circuit -- US v. Gary Gillion

Proffer agreement that by its terms contemplates trial binds post-indictment, requiring deft to take polygraph.

Statements were hamless anyway.

Interposing a similarly-named shell corporation between customer and employer for purposes of siphoning profits is fraud on the employer; the employer has a property interest.

Misstatements (forged signatures, use of certain kinds of checks) were sufficiently material.

Mailings from the shell corporation sufficient for mail fraud trigger.

US v. Gary Gillion