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Joseph Bruno was convicted of two counts of mail and wire fraud in December 2009 and filed an appeal with the Second Circuit in January 2010. He was sentenced in May 2010 and was released on bail until the U.S. Supreme Court released its honest services fraud decisions. On July 2, 2010, Bruno submitted a letter to District Court Judge Gary L. Sharpe articulating arguments to remain on bail pending release. Within this letter are substantive arguments concerning the status of his honest services fraud conviction in light of Skilling.
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