Shannon Kerr director of SEFE Inc is also the Trustee of The Buffs & Bruins Irrevocable Trust that purchased a golf course in Colorado with funds her father Stephen Kerr repatriated from undeclared Swiss bank accounts.
GOVERNMENT’S MOTION FOR DETERMINATION OF CRIME FRAUD EXCEPTION
Oh, isn’t this a shame, no protection for the fraudsters?……..Stephen Kerr and/or Michael Quiel are not protected by the attorney-client privilege because of the applicability of the crime-fraud exception. I wonder if Monica or Timothy from the tax department knows about Stephen Kerr's shares in SEFE?
Plaintiff, United States of America, through its undersigned counsel of record, the United States Attorney for the District of Arizona, and the Tax Division of the Department of Justice, hereby files its Motion For Determination of the Crime-Fraud Exception to the attorney-client privilege (“Motion”) and respectfully moves the Court for a determination that confidential oral communications between Christopher Rusch and Stephen Kerr and/or Michael Quiel are not protected by the attorney-client privilege because of the applicability of the crime-fraud exception. The motion is supported by the below memorandum of points and authorities.
Monica B. Edelstein Timothy J. Stockwell Trial Attorneys Department of Justice, Tax Division Two Renaissance Square 40 North Central Ave. Suite 1200 Phoenix, AZ 85004-4408 Monica.Edelstein@usdoj.gov Timothy.J.Stockwell@usdoj.gov
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