U.S. Department of Justice  United States Attorney Eastern District of New York
DRA:BMR:JL		One Pierrepont Plaza
F.#2002R00892		Brooklyn, New York 11201
	Mailing Address:	147 Pierrepont Street
		Brooklyn, New York 11201
		March 30, 2005

U.S. Probation Officer Amy B. Preston

U.S. Probation Department
Eastern District of New York
75 Clinton Street, Room 405
Brooklyn, New York 11201-4201

Re: United States v. Thomas P. McGuire, et al.
Criminal Docket No. 03-191 (S-5) (SJ)
 

Dear Ms. Preston:
 

The government submits this letter in response to the Addendum to the Presentence Report for the defendant Thomas P. McGuire in the above-captioned case.
 

In response to the defendant’s objections to paragraphs7, 10, 11 and 12, the Addendum indicates that it defers to the government for clarification. The government does not object to the cosmetic changes to paragraphs 7, 10 and 12, but stands by the substance of the facts reflected in paragraph 11. At trial, the government would have presented evidence establishing that in practice a hiring list was, in fact, maintained, but often not utilized. The government notes that the contested facts do not effect the defendant’s Guidelines calculation.

Very truly yours,
 

ROSLYNN R. MAUSKOPF
UNITED STATES ATTORNEY
 

By: Bridget M. Rohde/Joey Lipton
Assistant United States Attorneys
(718) 254-6348/6125
 

cc: Clerk of the Court (SJ)
Michael G. Considine, Esq.