Because of these differing standards of review, the Illinois cases cited by the parties must serve primarily as statements of the law. Their factual conclusions are only exemplary, not binding. Ill. Rev. Stat. While Levine admits that the government met its burden on the fourth element of the crime, he challenges its evidence on the other four elements. Levine made deceptive statements.
Illinois law defines five types of conduct as deception.
Ill. Rev. Stat. Under this definition, Levine deceived Berry about his qualifications and about the disposition of her money. Levine earned Berry's trust by lying about his personal achievements. Levine further maintained that he worked at Diversified only because he loved his job. In reality, Levine was deeply in debt.