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United States v. Collins

United States District Court, S.D. New York

January 15, 2020

UNITED STATES OF AMERICA,
v.
CHRISTOPHER COLLINS, et al., Defendants.

          ORDER

          VERNON S. BRODERICK, UNITED STATES DISTRICT JUDGE.

         As the parties are aware, sentencing of Defendant Christopher Collins (“Collins” or Defendant Collins”) is scheduled in this matter for Friday, January 17, 2020, at 2:30 p.m. I have completed my initial review of the Presentence Report (“PSR”), the defense sentencing submission, and the Government's sentencing submission. Based upon that review, it is hereby:

         ORDERED that the parties shall provide the following requested documents prior to sentencing and shall be prepared to discuss/answer the following topics and questions either at sentencing or prior to sentencing:

         1. Please provide copies of the reports documenting the statements made to law enforcement by Christopher Collins, Cameron Collins, Lauren Zarsky, and Stephen Zarsky. In addition, to the extent there are reports documenting statements made to law enforcement by Mary Collins and Dorothy Zarsky, please provide copies.

         2. In paragraph 19 of the PSR, it states that Cameron Collins owned approximately 2.3% of the shares in Innate.

a. How much did these shares cost at the time purchased?
b. Where did the money come from that was used to purchase the approximately 2.3% of the shares of Innate?

         3. Other than Christopher Collins's guilty plea allocution, what is the basis for the assertion in paragraph 27 of the PSR that “During the call, CHRISTOPHER COLLINS told CAMERON COLLINS that MIS416 had failed and they agreed that, if possible, CAMERON COLLINS would sell his shares in Innate.”?

         4. What is the basis for the assertions in paragraph 28 of the PSR that Cameron Collins and Lauren Zarsky informed “Dorothy and STEPHEN ZARSKY that MIS416 had failed” and they “agreed that they would sell their shares in Innate, but CAMERON would avoid selling all of his shares at once, so as not to depress the price of the stock before Dorothy, Lauren, and STEPHEN ZARSKY sold their shares.”?

         5. How were the avoided losses contained in the chart in paragraph 35 of the PSR calculated?

         6. What did each of the Defendants originally pay for the shares of Innate in their possession on or before June 22, 2017? If another individual purchased the shares for a Defendant, how much did that individual pay?

         7. If possible, please provide the closing prices of Innate stock for each day between June 22, 2017 and June 26, 2017, prior to the issuance of the Innate press release.

         8. What was the total value of each Defendant's shares at the time they sold their shares on or after June 22, 2017?

         9. Besides the calls to Cameron Collins listed in paragraph 22 of the Superseding Indictment, what calls did Christopher Collins make and receive on June 22, 2017 after Christopher Collins received the email from Innate's Chief Executive Officer ...


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