court filing or transcript: 1:20-cr-00338-PAE Document 1616-2 Filed 02/24/22 Page 78 of 117

The document contains a statement made by the defense, arguing that the defendant's actions were mistakes made in the chaos of a law firm, and that the government has not provided sufficient evidence to prove the defendant's intent (mens rea). The defense challenges the 'must have known' argument made by the government, citing the defendant's limited accounting experience.