United States v. Milton Zucker Mende

FLOYD R. GIBSON, Senior Circuit Judge:

Milton Mende appeals his conviction and sentence for conspiracy, multiple counts of mail fraud, wire fraud, and money laundering. Mende alleges that the district court erred in three ways: failing to grant his motion for mistrial based on improper prose-cutorial comments on his exercise of his Fifth Amendment privilege against self-incrimination; admitting evidence of his prior fraudulent conduct; and calculating his base offense level. We AFFIRM.

I. BACKGROUND

From 1984 until 1990, Mende and his co-conspirators, Robert Turman and Samuel Longo, organized…