Case 1:22-cr-00024-AW-GRJ Document 35 Filed 01/30/23 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF FLORIDA
GAINESVILLE DIVISION
UNITED STATES OF AMERICA )
)
v. )
) Criminal No. 1:22-cr-00024-AW-GRJ
)
PATRICK PARKER WALSH )
)
Defendant. )
DEFENDANT’S RESPONSE TO GOVERNMENT’S SECOND
SENTENCING MEMORANDUM
Patrick Parker Walsh, through his counsel, submits this memorandum in response to the
allegations in the Government’s Second Sentencing Memorandum. Mr. Walsh submits this
information to clarify the record in anticipation of sentencing tomorrow.
The Government claims that Mr. Walsh was hiding assets, including 8 airships owned by
the defendant and his companies [D.E. at 11]. This information is wrong. Mr. Walsh never hid
these assets from the government. He disclosed the airships to Probation in his Financial
Disclosure Form (pg. 6. of 7) as follows:
The value of the AirSign Airship Group changes based on current contracts. We
did have a buyer for the company at $10M but then when the news articles came
out about my crime that deal fell through. But we are working with lots of potential
buyers for the individual airships and related airship assets.
Moreover, an Asset Purchase Agreement was emailed to AUSA Justin Keen on September
22, 2022, detailing 15 airships as well as other business assets. This Agreement is attached and
incorporated as Exhibit 1.
The Government also states that Mr. Walsh has not been actively working to sell his
properties. This is inaccurate. Mr. Walsh has been actively pursuing the sale of various properties
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and has been completely transparent with the government in his real estate dealings. On October
14, 2022, Mr. Walsh’s legal counsel sent the government notice that he would be pursuing Path B
pursuant to the Plea Agreement Rider, including documentation of all the listing agreements with
the realtors for the following properties:
Sweetheart Island Documents
Commercial Property – US HWY 19, Dixie County, FL
12 NW 5th PL Documents
8657 NE 150th Ave Documents
0412300500 Documents
041230050A Documents
541 SE 1 Ave Documents
This satisfied both the spirit and the letter of the Plea Agreement Rider. This letter is attached and
incorporated as Exhibit 2. Mr. Walsh, through his legal counsel, has been in constant
communication with the government regarding the sale of his various assets. An example of the
significant level of communication is attached and incorporated as Exhibit 3.
The government argues that Mr. Walsh has not been transparent, due largely to the
existence of an international trust. Not so. The trust is a legitimate and irrevocable
instrument. Mr. Walsh lacks the direct power to recover the trust property and holds no direct
control over any trust assets. Upon termination, the trust property passes to Mr. Walsh’s
descendants, not to Mr. or Mrs. Walsh. It is a legitimate arrangement, not a sham. The Trustee is
not required to make any payments to Mr. or Mrs. Walsh. Per its terms, if the Trustee distributes
funds in a way that causes them to be vulnerable to any beneficiary’s creditors, the Trustee could
face liability. In addition, Mr. Walsh cannot force the Trustee to distribute any assets to any
beneficiary or to any creditor. The trust contains a spendthrift provision protecting trust assets
from any beneficiaries’ creditors. There is nothing illegal, unusual, or improper about a person
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using an offshore trust, such as this one and, to be clear – this trust was disclosed to the government
multiple times.
Mr. Walsh disclosed to probation the existence of the trust and its current financial
state. The information Mr. Walsh disclosed to probation is corroborated by the attached exhibit,
an account statement dated September 30, 2022, demonstrating the value of the trust bank
account. See Exhibit 4.
Mr. Walsh has disclosed all relevant information to both the government and the U.S.
Probation Office.
Respectfully Submitted,
/s/ Nicole Hughes Waid /s/ David G. Lazarus___________
Nicole Hughes Waid David G. Lazarus (pro hac vice)
FisherBroyles LLP Verrill Dana LLP
Florida Bar #0121720 One Federal Street
625 Tamiami Trail North, Suite 203 20th Floor
Naples, FL 34103 Boston, MA 02110
P: (202) 906-9572 P: (617) 292-2859
E: Nicole.waid@fisherboyles.com E: dlazarus@verrill-law.com
CERTIFICATE OF SERVICE
I, David G. Lazarus, attorney for Patrick Parker Walsh, do hereby certify that I have, this
day, filed the foregoing with the Clerk of Court via the CM/ECF system, which has caused a true
and correct copy to be served on all counsel of record.
/s/ David G. Lazarus
David G. Lazarus, Esq.
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