NATHAN J HOCHMAN. PARTNER

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NATHAN J HOCHMAN PARTNER nathan.hochman@morganlewis.com Century City Phone +1.310.255.9025 Fax +1.310.907.2000 2049 Century Park East \ Suite 700 \ Los Angeles, CA 90067-3109 \ United States Washington, DC Phone +1.202.373.6774 Fax +1.202.739.3001 1111 Pennsylvania Ave. NW \ Washington, DC 20004-2541 \ United States Nathan J. Hochman, the former head and Assistant Attorney General of the US Department of Justice s Tax Division, practices complex civil and criminal litigation, with a focus on white collar criminal defense, tax controversy, securities, and environmental matters. As the deputy chair of the firm s white collar litigation and government investigations practice, he represents individuals and organizations involved as targets, subjects, witnesses and victims in state and federal criminal and civil investigations, grand jury, pre-trial proceedings and trials, conducts internal investigations, and handles complex civil litigation, arbitrations, trials, and appeals. Nathan has achieved notable successes throughout the United States and the world representing clients in the US government s ongoing efforts to investigate and prosecute US taxpayers, and intermediaries (e.g., bankers, lawyers, accountants) for unreported offshore income and accounts. He has acted as counsel and an independent examiner for Swiss banks under the USDepartment of Justice s Swiss Bank Program. Through his efforts, over 100 of his clients have successfully entered the IRS Offshore Voluntary Disclosure Program since 2009, avoiding criminal prosecution and steep penalties and fines. In cases that have proceeded to court, Nathan has obtained sentences well below that recommended by the government; for example, one client was sentenced to five seconds of probation after the government argued for 2-3 years in prison in a case involving over $40 million in unreported foreign bank accounts. Nathan s practice has spanned from representing the former Sheriff of Los Angeles County in two hotly contested federal criminal obstruction of justice trials to obtaining an acquittal in less than an hour in a federal criminal tax trial involving millions in contested charitable contributions to representing corporations involved in large-scale environmental prosecutions, individuals and companies accused of multi-million dollar Bank Secrecy Act offenses, and the former CEO of a technology company charged with a $98 million conspiracy and wire fraud violations. Nathan is one of the country s leading experts in white collar criminal defense and tax matters and regularly speaks around the country and world on a wide variety of subjects in these fields. Recently, Nathan has spoken and written in the area of US and global enforcement in the cryptocurrency and blockchain arenas. Prior to joining Morgan Lewis, Nathan was a partner at another international law firm, where he was chair of the white collar investigations and enforcement practice. Prior to joining the Justice Department, Nathan was in private practice for 11 years in a boutique litigation firm, where he concentrated on representing individuals and organizations in tax controversy litigation, federal and state white collar criminal investigations and litigation, and complex civil litigation. Before joining the ranks of private practitioners, Nathan served for seven years as an Assistant US Attorney for the Criminal Division of the Central District of California. In that role, Nathan prosecuted over 180 cases in the public corruption and government fraud section, ranging from tax violations, bank fraud, loan fraud, money laundering, and bribery to government program fraud, customs fraud, environmental crimes, arson, narcotics trafficking, bank robbery, alien smuggling, and perjury. He spearheaded the Los Angeles Disaster Fraud Task Force, was the Environmental Crimes Coordinator, tried over 20 jury trials, argued over 20 appeals before the US Court of Appeals for the Ninth Circuit, and ran over 30 complex grand jury investigations. Nathan clerked for United States District Judge Stephen V. Wilson in Los Angeles. He has previously been appointed as federal receiver in several cases. Nathan served as a Commissioner on the Los Angeles City Ethics Commission for five years, including as its president.

SANDRA R. BROWN PROFESSIONAL BIOGRAPHICAL INFORMATION Hochman, Salkin, Rettig, Toscher & Perez, P.C. 9150 Wilshire Boulevard, Suite 300 Beverly Hills, CA 90212 Phone: 310/281-3200 Fax: 310/859-5108 Email: brown@taxlitigator.com Web Site: www.taxlitigator.com Sandra R. Brown is a tax attorney and principal of the law firm of Hochman, Salkin, Rettig, Toscher & Perez, P.C., Beverly Hills, California, where she specializes in civil and criminal tax litigation. Prior to entering into private practice, Ms. Brown spent more than 26 years as a federal trial lawyer, including serving as the Acting United States Attorney, First Assistant United States Attorney, Chief of the Tax Division, and an Assistant U.S. Attorney in the Tax Division all in the Office of the U.S. Attorney, Central District of California. Ms. Brown s broad range of experience in complex civil tax controversies and criminal tax investigations and litigation, includes having personally handled over 2,000 cases on behalf of the United States before the United States District Court, the Ninth Circuit Court of Appeals, the United States Bankruptcy Court, the United States Bankruptcy Appellate Panel and the California Superior Court. These cases included nationally significant civil tax cases such as two Supreme Court decisions and a multitude of published 9th Circuit decisions, as well as equally noteworthy criminal tax cases including the first FBAR prosecution in California, one of the largest individual tax restitution judgments fully recovered in a criminal tax case prosecuted in this nation, and the direct oversight of an unprecedented deferred prosecution agreement, resolving a criminal probe into an international bank s worldwide U.S. cross-border business, requiring the bank to pay $270 million in restitution and fines. In addition to other honors, commendations and awards, Ms. Brown has received the Internal Revenue Service Criminal Investigation Chief s Award and the IRS s Mitchell Rogovin National Outstanding Support of the Office of Chief Counsel Award, respectively, the two most prestigious criminal and civil awards available for presentation by the IRS to Department of Justice employees. Ms. Brown has written, lectured and taught federal prosecutors, agents and private practitioners throughout the country on topics involving trial strategies, taxation, bankruptcy and money laundering. Based upon the breadth of her expertise and experience in litigation and management, Ms. Brown is a highly sought-after speaker before national and regional professional organizations. Ms. Brown is a graduate of the University of Denver College of Law, where she obtained her LL.M. in Taxation, as well as a graduate of Western Michigan University Cooley Law School.

R. Damon Rowe Special Agent in Charge IRS Criminal Investigation Los AngelesField Office Damon Rowe is the Special Agent in Charge, IRS Criminal Investigation (CI), for the Los Angeles Field Office. Mr. Rowe was named to this position in April 2017. Mr. Rowe is responsible for planning, directing, and evaluating activities of 15 groups of special agents in the Southern California area, which includes the oversight of three Assistant Special Agents in Charge, 15 supervisory special agents, and administrative and paraprofessional support employees. Criminal Investigation's law enforcement priorities are the investigation of income tax evasion and other related financial crimes. This encompasses fraud in legal industries, illegal industries, and narcotics related financial crimes as well as terrorism financing. Investigations include tax, money laundering and Bank Secrecy Act violations, which involves the proper reporting of currency transactions. Mr. Rowe began his IRS CI career in 1998 as a Special Agent in Los Angeles, California. Since then he has held increasingly responsible positions. Mr. Rowe served as Senior Analyst in the Narcotics and Counterterrorism section; and Supervisory Special Agent in the Dallas Field Office from 2007 2011. In late 2011, Mr. Rowe was promoted to Assistant Special Agent in Charge for the New Orleans Field Office. In January 2014, Mr. Rowe was promoted to Special Agent in Charge of the Dallas Field Office. Damon Rowe has a B.S. in Accounting from the University of Houston, J.D. from Texas Southern University, and a Masters of Legal Letters in Taxation from Southern Methodist University School of Law. Damon Rowe is a member of the Texas Bar. 1

Gary L. Howard, CPA Bio for UCLA tax controversy conference: Gary Howard has focused on tax controversy, white collar crime and litigation support matters since the founding of his firm, GL Howard and Company CPAs, LLP, in 1986. With over 30 years experience, Gary is recognized as one of the top CPAs nationwide in these matters. Gary is currently assisting other CPA firms nationwide to form forensic accounting and tax controversy practices. He has authored published articles and is a frequent speaker to local and national groups of business owners and professionals. Gary is a member of the California Society of CPA (CalCPA) and American Institute of CPAs (AICPA). He received his B.A. in Economics and Accounting from California State University, Fullerton and his M.S. in Taxation from Golden Gate University, San Francisco. His firm, GL Howard and Company CPAs, LLP, based in Los Alamitos, CA assists attorneys on complicated tax controversy cases and in litigation support for civil and criminal matters. The firm's professionals work closely with attorneys to analyze, verify and quantify the financial issues in their cases. The firm serves clients nationwide as well as internationally with these matters. Gary is also an expert witness and experienced court appointed referee. See www.glhowardcpa.com for more information.

UCLA Bio Richard Speier, Jr.-Richard Speier & Associates Telephone (909) 912-2864 Email: r.speier@verizon.net. Rick is the former Deputy Chief for IRS Criminal Investigation (CI). He spent 29 years as a special agent, manager and executive with CI. During his management career with CI, he served as the Special Agent in Charge for both the San Jose and Los Angeles Field Offices. He finished his IRS career in 2006 after serving as the Deputy Chief, CI, CI s second in command. In this position, he supervised CI s 4,600 employees and was responsible for guiding CI s entire investigative program. He also served as the Acting Chief, CI immediately prior to his retirement. As an IRS executive, he frequently represented IRS as a media spokesman and in sessions on Capitol Hill. During his government career, he frequently testified as a trial expert witness. Since his retirement from government service, he has served as consultant to attorneys and corporate clients who seek his advice in matters dealing with all financial crimes and primarily tax controversy issues. Rick is also an enrolled agent and has been an invaluable member of the Planning Committee, friend and advisor to the UCLA Extension Tax Controversy Institute.

Martin A. Schainbaum Martin A. Schainbaum, P.C. San Francisco, California schainbm@taxwarrior.com Martin A. Schainbaum, founder of Martin A. Schainbaum, P.C., received his law degree and his masters in tax law from New York University. He is a former Assistant United States Attorney in the Northern District of California, Tax division, and former IRS Regional Counsel trial attorney. Marty is recognized in California as a Certified Taxation Specialist, is an active member of the Section of Taxation of the American Bar Association, and is a frequent speaker on tax controversy and litigation matters. He also serves as an adjunct professor of Federal Tax Procedure and Tax Litigation at Golden Gate University in San Francisco, California. His team of professionals is dedicated to the defense of civil and criminal tax matters, including all aspects of litigation, and white-collar crime, involving individual, business and corporate tax and white-collar crime matters. In 2010, Marty had the honor of receiving the Bruce Hochman Tax Controversy Litigation Award at the UCLA Tax Controversy Conference. In 2012, Marty was presented with the prestigious Jules Ritholz Memorial Merit Award in recognition of outstanding dedication, achievements and integrity in the field of civil and criminal tax controversies by the American Bar Association Tax Section s Committee on Civil and Criminal Tax Penalties. In 2015, the Tax Section of the State Bar of California awarded the distinguished JoAnne Garvey Award for lifetime outstanding contribution in the field of tax law. He is admitted to practice in California, New York and the District of Columbia.