Brown

MEMORANDUM *

Judy Scharnhorst Brown (“Brown”) appeals convictions for mail fraud, bankruptcy fraud, abetting perjury and conspiracy. The convictions are based on a scheme to defraud homeowners, lenders, and the courts by listing false deeds of trust in bankruptcy petitions in order to frustrate foreclosure proceedings. As the parties are familiar with the facts, we do not recite them here.

*422 DISCUSSION

I. Sufficiency of the Evidence

Brown argues that none of the convictions is supported by sufficient evidence. “Sufficient evidence exists to support a conviction when, viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” United States v. Coleman, 208 F.3d 786, 792-93 (9th Cir.2000) (quotation marks omitted).

A. Mail Fraud (Counts 2-6, 8, 10, and ID

Counts Two through Eleven charge Brown with mail fraud in violation of 18 U.S.C. § 1341 and aiding and abetting mail fraud in violation of 18 U.S.C. § 2 . The jury convicted Brown of all mail fraud counts except Seven and Nine.

Brown contends that her mail fraud convictions cannot stand because she did not…