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In their separately submitted brief, defendants Arden and Sparks argue that they should not be liable under Sec. 2(a) because they are employees of an alleged kingpin and such employees have not been subjected to liability as accomplices.

They rest their argument on the following language from the Seventh Circuit's opinion in United States v. Pino-Perez: "As the government has rightly conceded in these cases, the persons supervised by the kingpin cannot be punished as aiders abettors." See Brief of Defendants-Appellees Arden and Sparks at p. The CCE is a different criminal statute with a different purpose and scope than Sec. The CCE is only directed at kingpins, not employees.


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