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Document A-5921

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CAC3PARC 19 1 of this after the receipt of the jury -- of Ms. Conrad's letter 2 to the government in May after the verdict. And worse, even in 3 the conference calls with the Court, they continued to make it 4 appear and resist the Court and the government learning that 5 knowledge. 6 Mr. Shechtman seems to want to characterize this as 7 them wanting to hide their mistakes. But it's quite clear, and 8 Susan Brune and Laurie Edelstein testified, we would not have 9 told this Court but for the Court pressing. That to me speaks 10 of a decision made early on and continuing through the briefing 11 that they wanted the juror on the panel, but they wanted the 12 Court not to know exactly what they knew because they 13 understood, and, as was acknowledged at the hearing, that that 14 was damaging to their client. 15 THE COURT: Would you address the prejudice prong. 16 MS. DAVIS: Yes, your Honor. Your Honor, we believe 17 that there is more than adequate evidence, indeed overwhelming 18 evidence, of defendant Parse's criminal involvement in the 19 corrupt endeavor to obstruct the IRS and in the mail fraud 20 count. The defense conceded in its papers that Mr. Parse was 21 involved in the backdated transactions. We think backdated 22 transactions is a perfectly adequate description of them. 23 We also submit, your Honor, that Mr. Parse's 24 background as a CPA, even a non-practicing CPA, is under case 25 law relevant to his intent and circumstantial evidence of his SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010176