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Case peneeeieees ememenees COTE each agenes of 117 Case 1:09-cr-00581-WHP Document 605 Filed 03/18/13 Page 3 of 41 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, -v.- : S3 09 Cr. 581 (WHP) PAUL DAUGERDAS, DONNA GUERIN, DENIS FIELD, and DAVID PARSE, Defendants. AMENDED SENTENCING MEMORANDUM OF THE UNITED STATES REGARDING DEFENDANT DAVID PARSE The United States respectfully submits this memorandum for the Court’s consideration in connection with the sentencing of defendant David Parse (““Parse” or “the defendant’), which is scheduled for March 22, 2013 at 2:30 p.m. Preliminary Statement Following an eleven-week trial that included over 1300 exhibits, 41 witnesses, eight days of jury deliberations, and 46 jury notes, the jury on May 24, 2011 convicted David Parse on one count of corruptly obstructing and impeding the due administration of the Internal Revenue Laws in violation of 26 U.S.C. § 7212(a) (Count Twenty of the Redacted S3 Indictment), and one count of mail fraud in violation of 18 U.S.C. §§ 1341 and 2 (Count Twenty-Five of the Redacted S3 Indictment). The jury acquitted Parse of the conspiracy count and three counts of tax evasion. Those convictions stemmed from David Parse’s integral role in one of the largest tax fraud schemes ever charged, the details of which are spelled out in the indictment against him, $3 09 Cr. 581 (WHP), and the trial record. Incorporating the factual allegations in the conspiracy count, Count Twenty DOJ-OGR-00009527