Deceptive Conduct After Receipt of Money May Still Violate Mail Fraud Statute

Mailings occurring after receipt of the goods obtained by fraud are within
the mail-fraud statute if they `were designed to  lull the victims into a false sense of security, postpone their ultimate complaint to the authorities, and therefore
make the apprehension of the defendant less likely than if no mailings had taken place.’ (quoting Maze, 414 U.S. at 403 ); United States v. Pacheco- Ortiz, 889 F.2d 301, 305 (1st Cir. 1989) (post- Schmuck).  For the mailings to be considered in furtherance
of the scheme, the scheme’s completion or the prevention of its detection must have depended in some way on the mailings.”



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