Federal Judiciary

United States v. Adams, No. 06-1714-cr (L), et al., (2d Cir. March 23, 2009) (found here)

No surprise that the Second Circuit affirmed a 4 level leader/organizer enhancement here.  Nevertheless, it's always instructive to learn what constitutes a leader/organizer.  Here, the defendant "recruited people into the scheme, paid people for their participation in the scheme, developed the frozen fish pallet shipping method, and discussed going to Guyana to arrange a new shipment method after the September 23, 2003 seizure." 

Does the conduct of your client fall short of this description?  If so, perhaps a leader/organizer enhancement is inappropriate.