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Document A-5918

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CAC3PARC 16 1 MS. DAVIS: Yes, please, your Honor. 2 Good afternoon, your Honor. I'm glad to see that 3 Mr. Shechtman has conceded that other than this particular 4 area, Mr. Parse did in fact receive what can only be described 5 as a platinum plated defense with a defense team that most 6 defendants can only dream of. 7 MR. SHECHTMAN: I don't think I quite went that far, 8 your Honor. 9 MS. DAVIS: I do think, though, that had Mr. Shechtman 10 been here at trial and seen the forces that were mustered in 11 Mr. Parse's favor, he would have to admit that it is a rare 12 scene in such a courtroom for an individual defendant. 13 Your Honor, the crux of it is that defendant Parse is 14 seeking to be rewarded now for the strategic choices of his 15 attorney regarding Catherine Conrad and their knowledge of her. 16 Choices for which he has already benefited in the form of 17 acquittals on the conspiracy and the tax evasion counts. We 18 submit, as we said in our papers, that we believe that 19 Mr. Shechtman has met neither prong of the Strickland standard 20 in that he cannot show ineffective assistance of counsel and he 21 cannot show prejudice. 22 This Court in its ruling on the motion for new trial 23 regarding Catherine Conrad has already found that the Brune & 24 Richard law firm knew that Catherine Conrad and Juror No. 1 25 were the same person and chose to gamble with the jury that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010173