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Case ee £9) ee aR Macrae 49 of 117 = OoOwoOdtnmbewhNe Lee ee lll cool eel cel lll ee el UBWNrPOWOHAHRA oO Bw Ne 20 CAC3PARC incident. We know he was instrumental and indeed Carrie Yackee cited to more than a dozen instances during her testimony where she made clear that she was acting at the instructions of and with the knowledge of David Parse in implementing all of these complex and varied transactions that had to be effectuated in order to change the results of the three sets of transactions. It's actually four because Coleman and Blair were two separate taxpayers. She understood that this was being done for tax purposes. This is Carrie Yackee the sales assistant. Nice woman, but not nearly as sophisticated as Mr. Parse. To suggest that the jury could not find or infer that he knew exactly why these transactions were being effectuated, not for any real investment reason, not because they had figured out that in February and March, the year after the transactions had been done, that somehow it would have been a better investment to have not invested in Cisco stock, but instead to have invested in foreign currency. To suggest that the jury could not have found that Mr. Parse knew that the reason that these were being done was to effectuate tax losses for the prior year is simply ludicrous. Your Honor, the defendant was faxed information relating to the tax returns themselves, This wasn't just a one-way street between David Parse's office and Jenkins & Gilchrist, but it was at least a two-way street between Deutsche Bank and Jenkins & Gilchrist and also the accountants. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR- 00009498