DOJ-OGR-00010212.jpg
660 KB
Extraction Summary
3
People
2
Organizations
0
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (court document/sentencing memorandum)
File Size:
660 KB
Summary
This document appears to be a page from a sentencing memorandum in the case United States v. Parse (Case 1:09-cr-00581), filed in 2013 and later referenced in a 2022 filing. It discusses the fraudulent backdating of transactions at Deutsche Bank to achieve tax shelters, specifically refuting David Parse's attempt to blame his subordinate, Carrie Yackee, for the misconduct. The text includes transcript excerpts where Yackee testifies she simply followed her boss's orders, assuming they complied with bank policy.
People (3)
| Name | Role | Context |
|---|---|---|
| David Parse | Defendant/Employee |
Accused of criminal conduct regarding fraudulent backdating of transactions; attempted to blame subordinate Carrie Ya...
|
| Carrie Yackee | Witness/Subordinate |
Testified she acted under Parse's instructions; presumed her boss followed policy.
|
| Branch Manager | Bank Employee |
Signature appeared on some trade tickets; document argues they likely did not know the fraudulent purpose.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Deutsche Bank |
Employer of Parse and Yackee; organization whose policies were discussed regarding trade approvals.
|
|
| DOJ |
Department of Justice (indicated by Bates stamp DOJ-OGR).
|
Timeline (1 events)
2013-03-18
Relationships (2)
Yackee testified she acted at the instruction of David Parse; refers to him as 'my boss'.
Discussion of Deutsche Bank approvals and Parse's role.
Key Quotes (4)
"Parse’s attempt to blame her for his criminal conduct is inconsistent with the facts; it is also, in a larger sense, inexcusable."Source
DOJ-OGR-00010212.jpg
Quote #1
"the fraudulent backdating was nothing more than garden-variety fraud committed to achieve impermissible tax results."Source
DOJ-OGR-00010212.jpg
Quote #2
"To the extent that a branch manager actually knew what was occurring, that fact would only render the branch manager a co-conspirator, and not excuse Parse’s criminal conduct."Source
DOJ-OGR-00010212.jpg
Quote #3
"I was directed what to do by my boss."Source
DOJ-OGR-00010212.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,074 characters)
Case 1:20-cv-01388-AJN Document 614-3 Filed 02/11/22 Page 11 of 17
A-6082
Case 1:09-cr-00581-WHP Document 605 Filed 03/18/13 Page 9 of 41
A-6082
Case 1:09-cr-00581-WHP Document 605 Filed 03/18/13 Page 9 of 41
Sentencing Mem. at 12), the evidence showed and Yackee testified persistently, consistently, and
credibly that she acted at all times at the instruction of David Parse. Given the foregoing, Parse’s
attempt to blame her for his criminal conduct is inconsistent with the facts; it is also, in a larger
sense, inexcusable.
credibly that she acted at all times at the instruction of David Parse. Given the foregoing, Parse’s
attempt to blame her for his criminal conduct is inconsistent with the facts; it is also, in a larger
sense, inexcusable.
To the extent that Parse trial and current counsel have suggested and continue to suggest that
the backdating transactions were approved by Deutsche Bank, the only approvals were from Parse
himself, and on some of the trade tickets, the signature of the branch manager appears.⁴ Moreover,
there is no evidence that the branch manager knew of the purpose and animus for the backdated
transactions. To the extent that a branch manager actually knew what was occurring, that fact would
only render the branch manager a co-conspirator, and not excuse Parse’s criminal conduct.
the backdating transactions were approved by Deutsche Bank, the only approvals were from Parse
himself, and on some of the trade tickets, the signature of the branch manager appears.⁴ Moreover,
there is no evidence that the branch manager knew of the purpose and animus for the backdated
transactions. To the extent that a branch manager actually knew what was occurring, that fact would
only render the branch manager a co-conspirator, and not excuse Parse’s criminal conduct.
However complex the tax shelters, the fraudulent backdating was nothing more than garden-
variety fraud committed to achieve impermissible tax results. Basic principles of tax reporting —
such as the annual accounting rule — prohibit the changing of tax results through transactions
carried out after the close of the tax year. Carrie Yackee testified that she understood, based on her
variety fraud committed to achieve impermissible tax results. Basic principles of tax reporting —
such as the annual accounting rule — prohibit the changing of tax results through transactions
carried out after the close of the tax year. Carrie Yackee testified that she understood, based on her
__________
⁴ Yackee made clear that the “Deutsche Bank approvals” on the backdated transaction were
actually instructions from David Parse:
actually instructions from David Parse:
Q. You also testified about acting in accordance with Deutsche Bank policy, correct?
A. Correct.
Q. Are you aware what Deutsche Bank's policy is for the use of as of dates on trades?
A. I don’t know of the specific policy.
Q. How do you know you acted in accordance with the policy?
A. I was directed what to do by my boss.
Q. So when you say you acted in accordance with policy, you mean you followed your
boss’s orders?
A. And I presumed that he would follow policy. So . . .
A. Correct.
Q. Are you aware what Deutsche Bank's policy is for the use of as of dates on trades?
A. I don’t know of the specific policy.
Q. How do you know you acted in accordance with the policy?
A. I was directed what to do by my boss.
Q. So when you say you acted in accordance with policy, you mean you followed your
boss’s orders?
A. And I presumed that he would follow policy. So . . .
(Tr. 5699).
7
DOJ-OGR-00010212
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