United States v. James B.A. Niven

James B.A. Niven appeals his sentence for mail and wire fraud. Niven contends that the district court erred in calculating his adjusted offense level. Niven asserts eight errors: (1) an erroneous loss calculation; (2) incorrect adjustment for role as supervisor or manager; (3) refusing to give a downward adjustment for acceptance of responsibility; (4) inclusion of prior convictions when he was not represented by counsel; (5) considering that he was on unsupervised release at the time of his present offense; (6) separately sentencing him for offenses initiated before November 1, 1987 rather…