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Gov.uscourts.nysd.390337.19.0

Gov.uscourts.nysd.390337.19.0

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Published by D B Karron, PhD

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Published by: D B Karron, PhD on Oct 07, 2012
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10/07/2012

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USOCSDNY
DOCUMENT
ELECTRONICALLY FILEDDOC
#:
- - - - ; : : : - ; f ' " ' - ' " : ~ : : -
DATE FILED:
71
J
3/
J
,;t
D. B. Karron, Ph.
D.
348 East Fulton Street
U
~~~~~;~a~~!:::=:!)
Long Beach,
New
York 11561E-Mailtodrdbkarron@gmail.com Facsimile + 1 (516) 308 -1982Voice
+1
(516)515
-1474
Wednesday July
11,2012
at 14:40:24 HoursHon. Robert P. PattersonUnited States District JudgeDaniel Patrick Moynihan United States CourthouseCourtroom: 24A500 Pearl
S1.
JUDGEROBERT
P.
PATTERSON
New York, NY 10007-1312
RE:
Karron, v United States
of
AmericaCASE
#:
I:
I
2-cv-001 l8-RPP,OPINION
AND
ORDER
#
I
01897
of
61G/20
1
modil1ed
61l
112012
Dear Judge Patterson:This letter
is
with respect
to
the
above
order for additional and full supporting backup forour claim. We are preparing requested documentation as ordered for property seized; to backupour claim for credit against criminal restitution. Because
of
the volume
of
detail, and the poorstate
of
my records from that period.
\eve
respectfully require an additional
60
days to preparethese reports such that they are c0l11preheflsible and clear with CPA support. Preliminaryschedules are provided as exhibits here
(net in
the fax copy), but they are unchecked and containbugs. Copies
of
checks
and
statements behind each purchase showing payment account arebeing cornpiled.We would propose
L
negotiate
Tes;;
schedules with the Government
if
you so order.We also respectfully
;'cql:t:st
SLt).li~sion
on a
DvD
to the Court and to the Governmentinstead
of
printing out more
p ' ~ p e ; · . 
PROPOSED
CLASSIFICAT!Ot<
S(,HE
v1E
We
also propose, and
f3ql:est
consent
of
the Government, the following classificationscheme to simplify quanti
f
ic.tio'1
c,fth:
.
to Karron and the recovery
to
the Government by
Case 1:12-cv-00118-RPP Document 19 Filed 07/13/12 Page 1 of 58
 
its seizure
in
June 2007. Estimates
of
the tellal value reported by the OIG
(See Exhibit
1)
$300,000 and estimated
by
reconstructed CAS! records
(Exhibit
6) are about $341,8991) Equipment and property seized (over seized) purchased and paid for prior to theproject start on October
I,
2001. This is approximately worth $70,858 in inventory,
(See Exhibit
2) that \vas eligible for match co-funding
in
kind
(See Exhibit
5). Theactual cost
of
seized equipment
(all
of
eASY's computer inventory at the time) was
$123,516 (See Exhibit
3)
2) Equipment and property seized (over seized) purchased and paid for after the projectwas suspended, ailer June 2003, and before the
Government's
seizure
in
June2007. We currently estimate
it is
worth $50,241.
(See Exhibit
4)
3) Items were purch:lsed during:he-period
of
the project, and where
the
source
of
fundswas
either
NIST A TP
or
Kart'on
's
tax paid salary. This consists
of
approximately
$182,099 (See Exhibit
5)
worth
of
computer inventory not paid by the Burgundy
NIST
ATP program checks. subject to being verified by a CPA. We have engagednew accountant to try to help sort this and the
tax
issues.To make matters simple. we propose
to
further segment the items purchased during theproject period (Item 3,
above)
by source
of
fund ing.
PERSONAL FUNDS
A. Paid by Karron's "j;astec:mJ
.
B. Paid by Karron' s Visa,C. Paid by Karron' s checking account
or
cash,
or
D. Equipment Ordered prior to suspension, but Paid by any means for after the grant
was
suspended on June 27, 2003 are to be considered property
ofCASVKarronGOVERNMENT FUNDED
PLRCHASr-:SEquipment purchased and paid
\\ith
Burgundy NIST
ATP
Program checks, with a fairmarket value less than 5.000 dollars [hat would be otherwise abandoned to
CASI
at fullvalue. We should agree on a date for evaluation.
Case 1:12-cv-00118-RPP Document 19 Filed 07/13/12 Page 2 of 58
 
Equipment purchased and paid
by
Burgundy NIST ATP Program checks, with an itemvalue greater than $5,000 , where the government recovered that equipment
in
theseizure, should also offset the loss to the government by the governments recovery
of
said equipment at invoice cost or some agreed on basis. Please note that the OIG verypublically notified Congress and issued press releases that it recovered some $400,000worth
of
equipment.
bchibii
j
I
STATUTORY AUTHORITY
We
bring to the Courts attention to the following NIST ATP Statute, citing title to equipmentpurchased with grant funds
v~sts
\\ith
the
grantee, namely CAS!.
15 CFR Subtitle A
(1-1-01
Edition)
§
24.32 Equipment.(httpJ/csrc.nist.gov/grants/15CFR24J2ill orhttp://www.gpo.gov/fdsys/pkg/CFR-2001-title15voI1/pdf/CFR-2001-titleI5-voI1-sec24..:32 pdf)(a) Title. Subject to the obligations and conditions set forth
in
this section, title to equipmentacquired under a grant
or
sl!bgrant wi!' vest upon acquisition
in
the grantee or subgranteerespectively.(e) Disposition. When original or replacement equipment acquired under a grant or subgrant isno longer needed for the original project or program or for other activities currently
or
previouslysupported by a Federa: agency,(1) Items
of
equipmer:t with a current per-unit fair market value
of
less than $5,000 may be
retained,
sold
or
otherwise
disposed
of
with
no
further
obligation
to
the
awarding agency.
Respectfully Submitted,
prose
Cc:Enc:
See
attached typewritten 
Memo
Endorsement
."
4!0
II'UJI'It
J
pa..S
c-
Case 1:12-cv-00118-RPP Document 19 Filed 07/13/12 Page 3 of 58

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