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Tuesday, 05/08/2012 12:56:22 AM

Tuesday, May 08, 2012 12:56:22 AM

Post# of 221834
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.

Shannon Kerr is mentioned on page 9 lines 19 & 20
Case 2:11-cr-02385-JAT Document 67 Filed 04/27/12 Page 1 of 15
http://www.scribd.com/doc/92592662/GOVERNMENT%E2%80%99S-MOTION-FOR-DETERMINATION-OF-CRIMEFRAUD-EXCEPTION

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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