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This legal document, a letter from Zuckerman Spaeder LLP to Judge William H. Pauley, III, argues on behalf of a client named David. It contends that while David was convicted for 'backdating' transactions, the jury's acquittal on more serious tax evasion and conspiracy charges suggests they believed he was unaware of the illegality of the Jenkins tax shelter scheme itself. The letter posits that David was given comfort by the participation of major entities like Deutsche Bank and believed he was exploiting a legal 'loophole'.

This legal document, a page from a letter to Judge William H. Pauley, III, argues that a defendant named David was not a culpable participant in the illegal aspects of the Jenkins tax shelter scheme. The author contends that David's acquittal on conspiracy and tax evasion charges, along with his co-defendant's full acquittal, shows the jury believed David did not know the shelters were illegal. The document attributes David's belief in the shelters' legality to high-level approval from Deutsche Bank and the belief that a legal "loophole" had been found, suggesting his convictions for mail fraud and tax obstruction were solely for separate "backdating" transactions.