The following question presents a purely hypothetical case. Neither Mr. Wirth nor Ms. Wary are real persons. Damian Williams is, however, the current U.S.
Attorney for the Southern District of New York. The events described herein are purely fictitious.
Jason Wirth is a sixty-six-year-old single man. He has been divorced three times and has one adult daughter. He lives on the lower East Side of Manhattan, in
a one-bedroom apartment on First Avenue and 12th street. On or about December 31, 2020, Mr. Wirth posted a profile on the site “Our Time,” which is a
dating site catering to people over fifty who are, in the words of the site, “looking for long-term, stable relationships (and hopefully marriage) that are focused
on mutual respect and the sharing of one-another’s lives.” In his profile, Mr. Wirth falsely claimed that he had attended Oxford University—a very prestigious
university in England. He also falsely claimed that he had received the Congressional Medal of Honor.
Ms. Mable Wary is a seventy-three-year-old widow who lives in a penthouse apartment on Central Park West, just north of the Museum of Natural History.
Ms. Wary is a member of the renowned Wary family of New York. She is the daughter of the late Maximillian Wary, the wealthy investment banker, and the
niece of the late Conrad Wary, the former Senator from New York.
On or about January 5, 2021, Ms. Wary saw Mr. Wirth’s profile on “Our Time” and decided to contact him through the website. Subsequent to that contact, she
spoke over the phone to Mr. Wirth three times. Then, on or about January 23, 2021, Ms. Wary invited Mr. Wirth to have afternoon tea with her in the sitting…
