Karl

MEMORANDUM *

Gregory Paul Karl and Willie Watts appeal their convictions of conspiracy to defraud the United States, 18 U.S.C. § 371 , and various counts of mail fraud, 18 U.S.C. § 1341 , arising from their participation in a scheme to sell “pure trusts” purporting to shield income from federal taxation. 1 We have jurisdiction over this appeal pursuant to 28 U.S.C. § 1291 , and for the reasons set forth below, affirm their convictions.

I.

The district court correctly rejected Karl and Watts’ claim of a denial of equal protection due to Batson error. Batson v. Kentucky, 476 U.S. 79, 93-94 , 106 S.Ct. 1712 , 90 L.Ed.2d 69 (1986). Although the government struck two of five African-American potential jurors, the district court did not clearly err, United States v. Esparza-Gonzalez, 422 F.3d 897, 901 (9th Cir.2005), in finding that the government’s race-neutral explanation—that Juror No. 13 lacked the capacity to understand the complicated tax prosecution, and that Juror No. 45 had never filed her own taxes—were legitimate. Thus Karl and Watts failed to demonstrate that the government acted with the requisite “discriminatory intent or purpose.” See Hernandez v. New York, 500 U.S.…