DOJ-OGR-00010179.pdf

22 CAC3PARC 1 transactions that had to be done by the end of the year, that 2 had been done by the end of the year, pursuant to instructions 3 that had been given by Jenkins & Gilchrist to Deutsche Bank, 4 had been implemented properly by Mr. Parse in the first 5 instance, and now were being requested to redo them to achieve 6 a different result. 7 This I think is a distinction that makes 8 Mr. Shechtman's example of the broker's mistake an apple to our 9 orange or an orange to our apple, which is that this is not an 10 instance where Mr. Parse takes an instruction from a client and 11 screws it up. Implements it wrong. Rather, they did 12 everything that they were supposed to do the way it was 13 supposed to be done, and there are results to show for that. 14 It's only because the tax loss that they wanted to get from 15 these results was not correct that it required anything to be 16 done after the end of the year. 17 We suggest that the evidence was overwhelming to 18 support Mr. Parse's knowing and criminal involvement in both 19 the corrupt endeavor to obstruct and impede the IRS and in mail 20 fraud. 21 THE COURT: Anything further? 22 MS. DAVIS: Your Honor, there are other pieces of 23 evidence which we've detailed in our briefing but which I will 24 not go through again here. 25 I did want to just note though that the Second Circuit SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300