that the Sister City account records show that defendant deposited checkspayable to the City of Dixon into the Sister City account. After defendantdeposited the checks into the account, defendant converted some of the funds toher own use by writing checks to pay for personal expenses and for the purchaseof money orders that defendant used to pay personal expenses. Special AgentGarry will testify that defendant took at least $25,000 in City of Dixon fundsfrom the Sister City account between August 1988 and May 1990 and convertedthose funds to her own use. In addition, as set forth in its Motion for Upward Variance and Response to Defendant’s Sentencing Memorandum, Special AgentGarry will testify regarding the circumstances of defendant’s arrest and herstatement to the FBI on April 17, 2012 and will testify regarding the foundationfor Government Exhibits 1-6 and 8. The United States also intends to call fiveCity of Dixon officials and employees who will testify regarding the non-monetary loss and disruption of governmental function caused by defendant’sconduct in this case.2 Title 18, United States Code, Section 3771(a)(4) provides that crimevictims have “[t]he right to be reasonably heard at any public proceeding in thedistrict court involving release, plea, sentencing, or any parole processing.” Thissection has been interpreted as giving victims a right to allocution at sentencinghearings.
United States v. Vampire Nation
, 451 F.2d 189, 197, n.4 (3d Cir.
Case: 3:12-cr-50027 Document #: 62 Filed: 02/12/13 Page 2 of 4 PageID #:500