1. MAKING THE COMPLEX CASE SIMPLE PAUL E. PELLETIER ASSISTANT U. S. ATTORNEY SOUTHERN DISTRICT OF FLORIDA/ SPECIAL COUNSEL FOR LITIGATION FRAUD SECTION/DEPARTMENT OF JUSTICE

2. PRINCIPLES OF COMPLEX PROSECUTION 1. MAKE IT SIMPLE 2.MAKE IT MORE SIMPLE 3MAKE IT EVEN SIMPLER YET

3. FUNDAMENTALS 1. There is no substitute for hard work 2. Cases can be won or lost in the charging process 3. Do not lose sight of your objective

4. AS YOU BUILD YOUR CASE Nothing is Too Basic Continuously Frame the Issues Explain Your Case to Peers

5. Choosing Your Litigation Strategy Is the Crime Segmented? What Gives You the Biggest Bang for the Buck? Is Anything Simply Egregious?

6. Parmalat Investigation Multi-faceted/Multi- billion Dollar Accounting Fraud Accounting Fraud Morass Total Crime is Severely Complicated Is There a Way Out?

7. SHOW ME THE MONEY!

8. OPENING STATEMENT Uncomplicate Your Case Use Charts if Possible Make Them Understand the Harm/Victim

9. USE SUMMARY CHARTS Helps Jury/Judge Visualize Crime Allows Use of Faux “Expert” May Be Admitted As Evidence

11. Expert Witnesses Less is More Choose Experts Carefully Preparation is Key Avoid: “Battle of the Experts”

12. Expert Testimony Back to Basics Not Condescending Not Boring Not Biased Not Complicated