{
  "document_metadata": {
    "page_number": "81",
    "document_number": "616320",
    "date": "08/24/22",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00336-PAE Document 616 Filed 08/24/22 Page 81 of 117\nA-5924\n\n22\nCAC3PARC\n1 transactions that had to be done by the end of the year, that\n2 had been done by the end of the year, pursuant to instructions\n3 that had been given by Jenkins & Gilchrist to Deutsche Bank,\n4 had been implemented properly by Mr. Parse in the first\n5 instance, and now were being requested to redo them to achieve\n6 a different result.\n7 This I think is a distinction that makes\n8 Mr. Shechtman's example of the broker's mistake an apple to our\n9 orange or an orange to our apple, which is that this is not an\n10 instance where Mr. Parse takes an instruction from a client and\n11 screws it up. Implements it wrong. Rather, they did\n12 everything that they were supposed to do the way it was\n13 supposed to be done, and there are results to show for that.\n14 It's only because the tax loss that they wanted to get from\n15 these results was not correct that it required anything to be\n16 done after the end of the year.\n17 We suggest that the evidence was overwhelming to\n18 support Mr. Parse's knowing and criminal involvement in both\n19 the corrupt endeavor to obstruct and impede the IRS and in mail\n20 fraud.\n21 THE COURT: Anything further?\n22 MS. DAVIS: Your Honor, there are other pieces of\n23 evidence which we've detailed in our briefing but which I will\n24 not go through again here.\n25 I did want to just note though that the Second Circuit\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00009500",
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      "content": "Case 1:20-cr-00336-PAE Document 616 Filed 08/24/22 Page 81 of 117",
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    {
      "type": "printed",
      "content": "A-5924",
      "position": "header"
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    {
      "type": "printed",
      "content": "22\nCAC3PARC\n1 transactions that had to be done by the end of the year, that\n2 had been done by the end of the year, pursuant to instructions\n3 that had been given by Jenkins & Gilchrist to Deutsche Bank,\n4 had been implemented properly by Mr. Parse in the first\n5 instance, and now were being requested to redo them to achieve\n6 a different result.\n7 This I think is a distinction that makes\n8 Mr. Shechtman's example of the broker's mistake an apple to our\n9 orange or an orange to our apple, which is that this is not an\n10 instance where Mr. Parse takes an instruction from a client and\n11 screws it up. Implements it wrong. Rather, they did\n12 everything that they were supposed to do the way it was\n13 supposed to be done, and there are results to show for that.\n14 It's only because the tax loss that they wanted to get from\n15 these results was not correct that it required anything to be\n16 done after the end of the year.\n17 We suggest that the evidence was overwhelming to\n18 support Mr. Parse's knowing and criminal involvement in both\n19 the corrupt endeavor to obstruct and impede the IRS and in mail\n20 fraud.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "21 THE COURT: Anything further?\n22 MS. DAVIS: Your Honor, there are other pieces of\n23 evidence which we've detailed in our briefing but which I will\n24 not go through again here.\n25 I did want to just note though that the Second Circuit",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009500",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Parse",
      "Mr. Shechtman",
      "MS. DAVIS"
    ],
    "organizations": [
      "Jenkins & Gilchrist",
      "Deutsche Bank",
      "IRS",
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "Second Circuit"
    ],
    "locations": [],
    "dates": [
      "08/24/22"
    ],
    "reference_numbers": [
      "1:20-cr-00336-PAE",
      "616",
      "A-5924",
      "DOJ-OGR-00009500"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. The text is clear and legible, with no visible redactions or damage."
}