The following excerpt is from U.S. v. Srulowitz, 785 F.2d 382 (2nd Cir. 1986):
"When the government charges a defendant with mail fraud, it must at a minimum clearly and explicitly prove that the mailing occurred." United States v. Hart, 693 F.2d 286, 289 (3d Cir.1982). As every element of the government's case
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