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1 incident. We know he was instrumental and indeed Carrie Yackee
2 cited to more than a dozen instances during her testimony where
3 she made clear that she was acting at the instructions of and
4 with the knowledge of David Parse in implementing all of these
5 complex and varied transactions that had to be effectuated in
6 order to change the results of the three sets of transactions.
7 It's actually four because Coleman and Blair were two separate
8 taxpayers. She understood that this was being done for tax
9 purposes. This is Carrie Yackee the sales assistant. Nice
10 woman, but not nearly as sophisticated as Mr. Parse. To
11 suggest that the jury could not find or infer that he knew
12 exactly why these transactions were being effectuated, not for
13 any real investment reason, not because they had figured out
14 that in February and March, the year after the transactions had
15 been done, that somehow it would have been a better investment
16 to have not invested in Cisco stock, but instead to have
17 invested in foreign currency. To suggest that the jury could
18 not have found that Mr. Parse knew that the reason that these
19 were being done was to effectuate tax losses for the prior year
20 is simply ludicrous.
21 Your Honor, the defendant was faxed information
22 relating to the tax returns themselves. This wasn't just a
23 one-way street between David Parse's office and Jenkins &
24 Gilchrist, but it was at least a two-way street between
25 Deutsche Bank and Jenkins & Gilchrist and also the accountants.
Deutsche Bank SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010177