United States District Court, S.D. New York
S. BRODERICK, UNITED STATES DISTRICT JUDGE.
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:
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:
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.
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?
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
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
were the avoided losses contained in the chart in paragraph
35 of the PSR calculated?
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?
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.
was the total value of each Defendant's shares at the
time they sold their shares on or after June 22, 2017?
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