COFFEY, Circuit Judge.
Michael Paul De Angelo pleaded guilty to one count of mail fraud, 18 U.S.C. § 1341, and was sentenced to 46 months' imprisonment. On appeal, De Angelo argues that because there was no showing that he engaged in an amount of planning that was unusual for this type of offense, the district court erred in increasing his offense level by two for "more than minimal planning" under U.S.S.G. § 2F1.1(b)(2)(A). De Angelo also argues that the...
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