OPINION & ORDER
MARSH, District Judge.
In 1991, defendant Martin J. Cote was convicted of conspiring to defraud the government in violation of 18 U.S.C. § 371. The government's theory at trial was that the defendant and others set up an alternative warehouse banking system known as "NCE" for the purpose of providing members with a means by which they could conduct untraceable financial transactions and thereby impair and impede the IRS' ability...
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