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Non-Tech : Spongetech

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To: scion who wrote (145)3/21/2013 11:11:59 AM
From: scion   of 259
 
Dear Judge Irizarry:

This letter is written in response to the Presentence Investigation Report ("PSR"), to point out a few inaccuracies. None of these items are substantive but are being provided because the client was asked to review the report and identify any errors.

In paragraph 51, I am advised by Mr. Metter that his unemployment is actually $573.00 per week.

In paragraph 52, the PRS states that Mr. Metter was able to increase Business Talk Radio's ("BTR") net worth to $6,200,000.00. In fact, he was able to increase its revenues to that level.

In paragraph 53, the PSR states that Mr. Metter was President of RM Enterprises and, later, the President of Spongetech, and that he held those positions until 2007. In fact, he held the position at RM Enterprises until2007, but continued as President of Spongetech until 2010. The PSR also notes that Mr. Metter worked full time at BTR and Steven Moskowitz handled the day to day operations of "the company;" that could be clarified to reflect that it was not BTR that Mr. Moskowitz was handling but rather Spongetech.

In paragraph 60, the PSR states that Mr. Metter underwent a management training program with Federated Department Store "in Cincinnati, Ohio." In fact, Federated was based in Ohio but the training program was in Brooklyn. The PSR also states that he was a buyer of sportswear at Macy's. He was actually a buyer in the Bamberger's division of Macy's.

With respect to paragraph 62 regarding financial condition, obviously those numbers fluctuate to some extent. At this point, Mr. Metter has approximately $500.00 in the bank. His wife's IRA is now valued at approximately $9,000.00. Similarly, in paragraph 64, the PSR states that Mr. Metter is $114,000 in arrears on his mortgage; the arrears have increased to approximately $170,000.

Thank you for your consideration in this matter.

Respectfully submitted,

Is/ Maranda Fritz Maranda E. Fritz

OCR extract -

03/18/2013 295 Letter In Response to Presentence Investigation Report as to Michael Metter (Fritz, Maranda) (Entered: 03/18/2013)

Doc 295 PDF file
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