United States v. Richard S. Holiusa
Court of Appeals for the Seventh Circuit
1Opinion of the Court
ILANA DIAMOND ROVNER, Circuit Judge.
This appeal raises the question of how “loss” should be calculated under Sentencing Guidelines section 2F1.1 in cases involving a “Ponzi” or pyramid scheme, when defendants have partially repaid fraudulently-obtained funds before detection of the scheme.
I
Between January 1982 and April 1988, Richard Holiusa and his co-conspirators solicited investments in various companies, representing that they would reinvest the money in silver futures and high-yield government securities. They promised investors that their principal would not be at risk and that they…
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