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Case eae atiatlieeiaiiy ar, eamaemeaeenameniaeidia 117 Case 1:09-cr-00581-WHP Document 604 _ Filed 03/16/13 Page 1 of 14 7185 AVENUE OF THE AMERICAS 31ST FLOOR 4 NEW YORK, NY 10036-2603 vy. ZUCKERMAN SPAE'DER ue 212.704.9600 = 212.704.4256 fax = www.zuckerman.com PAUL SHECHTMAN Partner 712-704-9600 Pshechtman@zuckerman.com BY HAND March 7, 2013 The Honorable William H. Pauley, III United States District Judge Southern District of New York 500 Pear! Street, Room 2210 New York, NY 10007 Re: United States v. David Parse, et al., 09 Cr. 581 (WHP) Dear Judge Pauley: This letter is respectfully submitted on behalf of David Parse, who is scheduled to be sentenced for tax-related crimes on March 22, 2013. For the reasons discussed below, we believe that a non-incarcerative sentence would be a fair and parsimonious one, See United States v. Dorvee, 616 F.3d 174, 182 (2d Cir. 2010)(“it is the sentencing court’s duty to impose a sentence sufficient, but not greater than necessary to comply with the specific purposes set forth at 18 U.S.C. § 3553(a)(2)”). A. Background David Parse was born in Detroit, Michigan, on December 7, 1961. He was the youngest of five children of Sylvia and Henry Parse. A World War II veteran, David's father worked two jobs for most of his life. He was a mailman by day, and a factory worker at night. David’s mother worked part-time as a laundress in a local restaurant. The two parents instilled WASHINGTON, OC NEW YORK TAMPA BALTIMORE DOJ-OGR-00009506