Author Archives: David S. Zapp

Dimitrios Skaftouros (“Skaftouros”) was wanted in Greece on murder charges. A Magistrate Judge of the United States District Court for the Southern District of New York certified him as extraditable, but the decision was overturned by a District Court judge who denied the extradition.

The Government appealed and the Court of Appeals for the Second Circuit […]

The guidelines are a sentencing scheme by which levels are accorded to different factors such as the nature of the crime, the amount of drugs or money involved in the crime, the role played by the defendant in the crime, and whether he “accepted responsibility” which is looked upon favorably. Each factor determines levels and […]

Taking a case to trial after the client has “proffered” (spoken to the prosecutor) is difficult. Most proffer agreements have a clause permitting the government to introduce the defendant’s proffer statements to rebut evidence offered or elicited, or factual assertions made by, the defense. In United States v. Barrow, 400 F.3d 109 (2d Cir. 2005), […]