Exhibit 21 — Casey David Crowther (Dkt. 162.4)

Summary

This exhibit, filed 06/29/21 as Document 162-4 in Case 2:20-cr-00114 against Casey David Crowther in the Middle District of Florida, is the transcript of the testimony of Kristen Diiorio before United States District Judge John E. Steele, with an index dated March 24, 2021. Kristen Diiorio testified as office manager of the downtown Fort Myers location of Sanibel Captiva Community Bank, examined by Assistant U.S. Attorney Trent Reichling. The testimony states that a separate PPP account was opened at Casey Crowther's direction and that Casey Crowther was the only person with access to it. It covers an emailed request from Casey Crowther to transfer $3,300 into a personal account and a July 17th, 2020 wire request of $150,000 to Steve Adkins, and Government's Exhibits 24 through 28 were among those admitted.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

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Case 2:20-cr-00114-JES-M_M Document 162-4 Filed 06/29/21| Page 1l0$Adittagetburt
3735 Middle District of Florida
Fort Myers Division-

GOVERNMENT EXHIBIT

Exhibit No.: 21

UNITED STATES DISTRICT COUR
MIDDLE DISTRICT OF FLORIDA

FORT MYERS DIVISION Case No.: 2:S20-cr-114-JES-MRM

UNITED STATES OF AMERICA

UNITED STATES OF AMERICA, Fort Myers, Vys.

Case 2:20-CH¥ CASEY DAVID CROWTHER
Plaintiff

Wednesday, N Date Identified:

vs.
1:07 p.m. tqDate Admitted: __

CASEY DAVID CROWTHER,
Courtroom 5D
Defendant

TRANSCRIPT OF DIRECT EXAMINATIONS OF KRISTEN DiIORIO
VOLUME 1 OF 1
HELD BEFORE THE HONORABLE JOHN E. STEELE,

United States District Court Judge

Official Court Reporter:
Jeffrey G. Thomas, RPR, CRR
2110 First Street, Suite 2-194
Fort Myers, FL 33901
Telephone: (239) 461-2033

(Proceedings reported by Stenotype; Transcript produced by
computer-aided transcription.)
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APPEARANCES

COUNSEL FOR GOVERNMENT :

United States Attorney's Office

Middle District of Florida

United States Courthouse

2110 First Street

Room 3-137

Fort Myers, FL 33901

(239) 461-2200

BY: TRENT REICHLING, ESO.
MICHAEL V. LEEMAN, ESQ.

COUNSEL FOR DEFENDANT:

FisherBroyles LLP

2390 Tamiami Trail North

Suite 100

Naples, FL 34103

BY: NICOLE HUGHES WAID, ESQ
BRIAN E. DICKERSON, ESQ.
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INDEX
March 24, 2021 Vol. Page
Preliminary Discussions 1 4
WITNESSES FOR GOVERNMENT
WITNESS DIRECT CROSS REDIRECT RECROSS VOIR DIRE
NAME Vol. Pg. Vol. Pg. Vol. Pg. Vol. Pg. Vol. Pg.
| Kristen Diiorio 1 5 1 42
GOVERNMENT EXHIBITS ADMITTED
Vol. Page
Government's Exhibit 166 Admitted 1 10
Government's Exhibit 167 Admitted 1 12
Government's Exhibits 24, 25, 26 Admitted 1 15
Government's Exhibit 27 Admitted 1 21
Government's Exhibit 28 Admitted 1 27
Government's Exhibit 36 Admitted 1 30
Government's Exhibit 37 Admitted 1 32
Government's Exhibit 38 Admitted 1 33
Government's Exhibit 30 Admitted 1 36
Government's Exhibit 173 Admitted 1 40
Vol. Page
Certificate of Court Reporter 1 44
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** * PROCEEDINGS ***

(At 1:07 p..m., the jury was escorted into the
courtroom. )

THE COURT: And the government may call its next
witness.

MR. REICHLING: At this time, Your Honor, the
| government calls Kristen Dilorio.

THE COURT: Right up here, please.

COURTROOM DEPUTY: Good afternoon.

THE WITNESS: Good afternoon.

COURTROOM DEPUTY: Please raise your right hand.

Do you solemnly swear or affirm the testimony you are
about to give in the case now before the Court will be the
truth, the whole truth, and nothing but the truth?

THE WITNESS: I do.

COURTROOM DEPUTY: Thank you very much.

If you would please walk over to the witness box and
have a seat.

Once seated, would you please put your name on the
record and spell it for us?

THE WITNESS: Okay.

COURTROOM DEPUTY: Thank you.

THE WITNESS: Where on the record is that?

MR. REICHLING: No; could you state and spell your
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KRISTEN DIIORIO -— DIRECT/REICHLING S)

name for the record, please?
THE WITNESS: Oh, absolutely. Kristen,
KRISTEN, Dilorio, DI IORI O.
MR. REICHLING: And you can remove your mask if you
feel comfortable.
Your Honor, may I approach just to drop one exhibit
off? I've left exhibits on the stand.
THE COURT: You may.
(Counsel provides evidence to the witness.)
KRISTEN DIIORIO,
called as a witness by the Government, and having been first
duly sworn, was examined and testified as follows:
DIRECT EXAMINATION

BY MR. REICHLING:

Q Miss Dilorio, where do you currently work?

A Sanibel Captiva Community Bank.

Q And how long have you worked with Sanibel Captiva --

A About four years.

Q And what do you do for Sanibel Captiva Community Bank?
A I work as there office manager, the downtown Fort Myers
location.

Q And would that also somewhat be considered a branch
manager?

A It would, yeah. Same thing.

Q And are you in charge of, you said, downtown branch?
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KRISTEN DIIORIO -— DIRECT/REICHLING 6

Correct.
And where is that located? Here in downtown Fort Myers?

Yeah. Right in the Edison Theatre Building.

oO FP YO Pp

And have you served in that role for the four years
you've been with Sanibel Captiva?

| A I have.

HW Q And did you work at any other previous banks before you
worked at Sanibel Captiva Community Bank?

A I have. I have been in banking 17 plus years. Prior to
| Sanibel Captiva, I worked with Florida Gulf Bank, and then went
through the merge and became Iberian Bank.

Q What are your job duties, typically, as an office

| manager at the downtown Sanibel Captiva Bank branch?

| A Sure. As a community banker, kind of first and foremost
position is just to make sure we're there for our customers.
We'll go to the customer's office when needed. Just be there,
you know, open accounts, I do manage a staff, make sure
operational bank foundations are in place.

Do you also handle wire requests for customers?

I do, yes.

And account opening requests?

I'm sorry?

Account opening requests?

Yes.

And what about transferring funds between customers'
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KRISTEN DIIORIO — DIRECT/REICHLING 7
accounts?
A Yes, I do.
Q Now, you said you manage a staff of individuals?
A I do, um-hum.
| Q Who is Jennifer Briggs?
A She's my assistant branch manager.
Q And you supervise her?
A I do, um-hum.
Q Okay. Was Target Roofing a customer of Sanibel Captiva
Bank?
Wy A Yes.
Q And was Casey Crowther a customer of Sanibel Captiva
Bank?
A Yes.
Q And, roughly, do you know how many accounts Target

Roofing has With?

A

Q

I believe, currently, one.

Okay. Does Mr. Crowther have accounts with the bank as

Yes.
Now, who's the owner of Target Roofing?
Casey Crowther.

And were you also involved with the Paycheck Protection

Program on behalf of Sanibel Captiva Bank?

A

I was.
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KRISTEN DIIORIO — DIRECT/REICHLING 8
| Q And what was your involvement?
A All the branch managers, when that rolled out, we were
designated to be the . . . we were called the relationship
managers, kind of to address -- because we worked with these

customers day in and day out, it was just an easy transition

for us to be the contact person throughout the process.

Q Did you select documents that were submitted for the PPP
program?
A I did.
Q And were you assigned to Target Roofing's PPP
application?

A I was, um—-hum.
Q And I'd like you to take a look at Government's

Exhibits 166 and 167 before you.
A Okay.
Q Do you recognize government's -- I'll let you finish

taking a look at them. I'm sorry.

A Okay.
Q What's Government's Exhibit 166?
A 166. It looks like just the folks with Target Roofing

that I was in contact with to collect the information, just
e-mails, some information off the checklist items that were
needed to apply, where I was just requesting information and
they provided them to me.

Q Are those a fair and accurate copies of e-mail -- what
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KRISTEN DIIORIO -— DIRECT/REICHLING 9

was the date of those e-mails? I'm sorry.

A April 6th, 20.

Q April 6th, 2020?

A Um-hum.

Q Is that a fair and accurate copy of e-mail

correspondence that you received from individuals at Target
Roofing on that date?
A Yes.

MR. REICHLING: Judge, at this time the government
would move what's been previously marked as Government's
Exhibit Number 166 in evidence.

THE COURT: Okay.

Any objections?

MS. WAID: Your Honor, it appears there are
attachments to this e-mail that I'm not seeing. I would just
inquire as to the -- we can see the attachments to the e-mail
so it's a complete document.

MR. REICHLING: I can attach one of the attachments,
but the exhibit does not have the attachments included with the
e-mail correspondence, Your Honor.

THE COURT: I guess I'm confused as to whether the
e-mail correspondence originally had attachments.

MR. REICHLING: There was an e-mail transmission that
was transmitted that did have attachments. I'm going to talk

about one of those attachments with Miss DilIorio, but those
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KRISTEN DIIORIO -— DIRECT/REICHLING 10

attachments aren't currently attached to Government's
Exhibit 166.

THE COURT: And the defense wants them attached? Or
wants them produced?

MS. WAID: I would like to see them, but I'm going to
withdraw the objection. Let the e-mail in. That's fine.

THE COURT: 166 will be admitted then.

(Government's Exhibit 166 admitted.)
BY MR. REICHLING:
Q Miss DilIorio, you have already talked about attachments.
I'm going to show you Government's Exhibit 166. If you'd take
a look at that?
A You said six?
Q Maybe it's not there. I'm showing you what's already in
evidence as Government's Exhibit 6. Was that attached to that
e-mail that you received on April 6th, 2020?
Yes.
And what is that?
It's the application for that payment protection loan.

And who originally sent you that document from your

Oo FP O PY

e-mail chain in Government's Exhibit 166?

A I'm reading it. It looks like from their HR department.
Q Now, did you also receive additional e-mails from Target
Roofing that included additional PPP applications or documents?

A I know there was discussion. I don't have them in front
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KRISTEN DIIORIO — DIRECT/REICHLING 11

of me. I would assume there was further e-mails with
information.
Q I'd like you to take a look at Government's Exhibit 167.
I believe that's before you. Take a look at it and let me know
if you recognize it.

(Witness examines evidence.)
A I was listed on the e-mail. I don't recall getting it,
because Kyle DeCicco kind of ran with it, but I was on the
e-mail.
Q Is that a fair and accurate copy of an e-mail that you

received on that date?

A I would say so, yes.
Q And is there an attachment? Multiple attachments?
A It looks like just the application?

MR. REICHLING: Your Honor, at this time the
government would move what's previously been marked as
Government's Exhibit 167 into evidence.

THE COURT: Any objection to 167?

MS. WAID: Sorry, Your Honor. We're just trying
to -- there's a lot of attachments to this e-mail, and they're
only showing one; so I'm trying to figure out what else there
might be that I can

We're going to object to incomplete on that,

Your Honor.

THE COURT: The objection is the exhibit as currently
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KRISTEN DIIORIO — DIRECT/REICHLING 12

formatted is incomplete?

MR. REICHLING: Yes, that's correct, Your Honor. It
does include one attachment.

We can have a brief sidebar if Your Honor would like.

THE COURT: Are there other attachments?

MR. REICHLING: I can produce them, and they're
voluminous, but the defense has copies of them. We're only
seeking to introduce one of the attachments because it's
relevant to the witness's testimony at this time.

THE COURT: All right. The Court will admit the
exhibit as is; and then, if the defense wants to introduce the
rest of it, of course, they may.

MS. WAID: Thank you, Your Honor.

THE COURT: So 167 will be admitted.

(Government's Exhibit 167 admitted.)

BY MR. REICHLING:

Q And what's that attachment, Miss Dilorio?

A The second application for the increase for PPP funds.
Q And what was the date of that application on the bottom
of it?

A April 13th, 2020.

MR. REICHLING: Permission to publish, Your Honor?

THE COURT: You may.

MR. REICHLING: Thank you, Your Honor.
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KRISTEN DIIORIO — DIRECT/REICHLING 13
BY MR. REICHLING:
Q I'd like you to take a look at Government's Exhibit 167.

It's also on that screen in front of you, if you'd like. And,

of course, you have the actual physical exhibit in front of

you.
This e-mail was sent to you and Mr. DeCicco, you stated.
A Correct.
Q And where was it send from?
A Brad North.
Q And what's the date of that?
A April 13th.
Q Who is cc'd in that e-mail?
A Casey Crowther and their HR department.
Q I'm going to go back to Government's Exhibit 166,

because I didn't publish it, and I'd like to talk about it just
briefly.
(Evidence was published via the projector.)
BY MR. REICHLING:
Was the e-mail we discussed earlier on April?
It was, yes.
And who's it from again?
It's from Evelyn Portinari with the HR department.
And who is cc'd on this e-mail?

Brad North and Casey Crowther.

And we talked about the attachment that was on this
Case 2:20-cr-00114-JES-M_M Document 162-4 Filed 06/29/21 Page 14 of 44 PagelD
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KRISTEN DIIORIO — DIRECT/REICHLING 14

e-mail. Was that the original PPP application that I think had

2 a date of April lst on it?

3 | A Correct.
4 Q Okay. Now, other than collecting some of the documents
5 we talked about here, I'd imagine you collected other documents

6 for Target Roofing for the PPP program?

7 A Correct, um-hum.
8 Q Now, I'd like the talk you to about your involvement in
9 opening up any accounts related to the PPP program. Do you

10 recall that?

11 A I do.

12 Q And do you recall having correspondence with the

13 defendant about what account he'd like his PPP funds to be
14 deposited into?

15 A I do.

16 Q I'd like you to take a look the a Government's

17 Exhibits 24, 25, and 26. And if I mistakenly didn't put them

18 up there, please let me know.

19 | A No; I've got them. Okay.

20 Q Could you briefly explain, without telling me the

21 | contents of those exhibits, what those -- what those exhibits
22 reference?

23 l A Sure. It's just letting me know to put the PPP funds,
24 once closed, into the main operating account.

25 Q Don't read from the documents. I'm just asking you,
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KRISTEN DIIORIO — DIRECT/REICHLING 15

were these correspondence you had with Mr. Crowther about where
he wanted funds to be deposited into?

A Correct.

Q And are Government's Exhibits 24, 25, and 26 fair and
accurate copies of those correspondence that you had with the
defendant back on that date?

A They are.

MR. REICHLING: Your Honor, at this time the
government would move what's been previously marked as
Government's Exhibits 24, 25, and 26 into evidence.

THE COURT: Any objections?

MS. WAID: No objection, Your Honor.

THE COURT: Exhibits 24, 25, and 26 will be admitted
and may be published.

(Government's Exhibits 24, 25, 26 admitted.)

MR. REICHLING: Thank you, Your Honor. I'm going to
publish Government's Exhibit 24.

(Evidence was published via the projector.)

BY MR. REICHLING:

Q And could you read out -- what's your original
correspondence on this date? Is it contained toward the lower
half of the e-mail on Government's Exhibit 24 or towards the
top? And I'll zoom in on it, and you can tell me.

A It looks like toward the top. I apologize. In my

e-mail it looks like -- same day, but mine was the lower mid
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KRISTEN DIIORIO — DIRECT/REICHLING 16

form, and then the response was at the top.

Q And what's the date of this e-mail?

A April 10th, 2020.

Q And could you read what you sent to Mr. Crowther?
A Sure. "Good morning Casey. We received updated

information on how the closings and fundings will be processed.
Please read below and provide me with the funding account
number at your earliest convenience. Once closed, you will
receive immediate credit." And then, just, “Important. These
loan funds will be electronically deposited into your SCCB
account. Please provide me the account number you would like
these funds deposited into. Each morning, I will get a list,
and we'll notify you to expect an e-mail DocuSigned loan
package within 48 hours or less so you can be on the lookout
for the closing documents. The entire process is done
electronically."

Q Is this e-mail referencing the first PPP application and
approval by Sanibel Captiva Bank, do you recall?

A I don't recall, no.

Q Okay. What was Mr. Crowther's response to your e-mail?
And I'm going to zoom in on it.

A He says to deposit it in the main operating account.

Let me know what else you need and when to expect to close.

Q Now, Government's Exhibits 25 and 26, does Mr. Crowther

then respond to you again after he sends that e-mail?
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3/751
KRISTEN DIIORIO — DIRECT/REICHLING 17
A Yes.
Q Is that located on Page 3 of the document before you?

And the lower right-hand corner of each of these exhibits has a
Bates number on it.

A It is, um-hum.

Q Is that the e-mail that I have -- the portion that I
have zoomed in on?

It is.

And what did he e-mail you back again?

"Can you call me please?"

And did you call him?

I did. Um-hum.

And do you recall what you all discussed?

Pr O PF O YFP YO P

Yes. It was just about if there was an option, if we
could open a separate account to put the PPP funds into.

Q And could you continue to explain that conversation with
me? Did he tell you that he wanted the money to remain in the
operating account, or did he want it to go somewhere else?

A He just asked if a separate account could be opened to
put the funds into, which we were allowed to open a separate
account to put the funds into. So he said he would just like
to keep it from, you know, other staff viewing the funds. So
we went ahead -- you know, it was a quick conversation about if

it's something we can do. We did it for a couple of customers

25 | that requested it, so it wasn't anything out of the ordinary -—-
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KRISTEN DIIORIO - DIRECT/REICHLING 18
Q I'm going to have you stop there. You said something

about not having others view the account?

A Um-hum.
Q Why did he want it in another account?
A Just to keep it separate from the employees that had

access to either on-line or other accounts.

Q And you're familiar with Target Roofing's other bank
accounts that they have at Sanibel Captiva Bank?

A I am.

Q And do members of Target Roofing's work force have

access to other accounts that Mr. Crowther has via Target

Roofing?

A Yeah. I believe, at the time, there was one other
person.

Q Now, this particular PPP account, however, was only

going to be accessible to Mr. Crowther.
A Correct.
Q Now, Government's Exhibit 26, following this
conversation with Mr. Crowther over the phone, did you send him
documents that could be used to open the account?
A I did, um-hum.
MR. REICHLING: And I'll publish that.
(Evidence was published via the projector.)
BY MR. REICHLING:

Q Is this the e-mail you sent?
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KRISTEN DIIORIO — DIRECT/REICHLING 19
A It is, um-hum.
Q And can you read what you wrote, and also tell the jury

| the date and time that you sent that?
A Sure. The e-mail was September on Friday, April 10th,

2020, at 3:49. It says: "Hi Casey. Please sign where

highlighted on the new account. I have updated your SBA file

| to indicate for the funds to go into this account. Let me know
if you need anything else. Thank you."

Q Now I'd like you to turn to Pages 2 and 3 of
Government's Exhibit 26. Are these the account opening

documents that you sent to Mr. Crowther?

A They are.
Q What is the account agreement? What's its significant?
A It just lists who has ownership of the account and who

can sign on the account.

Q Okay. And, according to your review of this document,
who has authority on the account?

A Casey Crowther.

Q To the next page, Page 3, could you explain what the
corporate authorization resolution is?

A That just designates who has what powers and authorities
on the account. So, if there was more than one signer, you can
designate them specifically to be able to do only one thing.

Q Is there more than one signer, at least according to

l your review, of this document?
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KRISTEN DIIORIO — DIRECT/REICHLING 20
A No, there's not.
Q And could you read this by part, by who?
A Sure. By Target Roofing and Sheet Metal, Inc., PPP

loan, and then 1841 Ortiz Avenue, Fort Myers, Florida, 33905.
Q You don't need to read anything else.

Now I'd like you to take a look at Government's
Exhibits 27, 31, and 32. Do you not see 31 and 32 in front of
you? Let me just make sure.

A Yeah, I don't think I have it.
(Counsel provides evidence to the witness.)
THE WITNESS: Okay.
BY MR. REICHLING:
Q Could you tell me what Exhibit 27 is? Government's
Exhibit 27?
A It's an e-mail request to transfer funds to another
individual.
Q Okay. Is that an e-mail that was sent to you?
A It was, um—-hum.
Q And who was it sent by?
A Casey Crowther.
Q And is that a fair and accurate copy of the e-mail you
received from Mr. Crowther?
A It is.
MR. REICHLING: Okay.

At this time, Your Honor, the government would admit
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KRISTEN DIIORIO — DIRECT/REICHLING 21

what's been previously marked as Government's Exhibit 27 in
evidence?

MS. WAID: No objection.

THE COURT: Exhibit 27 will be admitted and may be
published.

(Government's Exhibit 27 admitted.)

MR. REICHLING: Thank you, Judge.

(Evidence was published via the projector.)
BY MR. REICHLING:
Q Could you read this e-mail for me, please?
A "Can you transfer a hundred thousand to Steve Adkins?
SanCap account __2271."
Q I'd like you to sort of walk me through a scenario in
which a customer submits a wire request via e-mail. What is
your typical standard of practice if you receive a wire request
via e-mail from a customer?
A Um-hum. We have a couple different methods to set
customers up, depending on how many wires they do. This
request is pretty typical for a lot of our businesses. It
would initiate us either receiving a signed request from them,
or, based on what we have on file, which is called a wire
agreement, kind of sets the tone whether we can just send wires
based on an e-mail and then with a callback verification, or
they might have to sign a request and e-mail it to us in order

to send it; but, by receiving this, this would prompt me to
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KRISTEN DIIORIO - DIRECT/REICHLING 22

check and see if we have a wire agreement on file, which we do,
and then to call the folks back listed as authorized
confirmers, and confirm the dollar amount and their codeword.

Q What did you do in response to receiving this e-mail
from Mr. Crowther?

A I called Casey to confirm the dollar amount and the Code
word. And that was for a reason.

Q Let me just stop you there. Codeword. Did this
particular account that Mr. Crowther was requesting the funds

to be wired from have its own unique wire pass code?

A It did.

Q And was it different from his other pass codes for other
accounts?

A It was.

Q Okay. And can you explain Government's Exhibit 32 and

what it is? It's already in evidence, I believe.

A So this is the wire form that generates from our wire
software, so this is where we plug it into the system. It
prints out this sheet, and then we have a second employee

within the bank verify what we've entered in to ensure that it

gets processed properly.

Q Referring -- is that Government's Exhibit 32 before you?
A It is, um-hum.

Q And there's handwriting on that exhibit?

A There is.
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KRISTEN DIIORIO — DIRECT/REICHLING 23
Q And whose handwriting is that?
A It's mine.
Q And did you make this handwriting at or near the time
that you received this phone call -- or the time that you

called Mr. Crowther to confirm the wire?

A Yeah. It would have been within an hour, I would say.

Q Now, during this discussion, did you ask Mr. Crowther
what the purpose of the wire transfer was?

A Yes.

Q And is that standard practice when you confirm a wire
request?

A If it's not listed on the e-mail or in the other form of
wire request, then yeah, we are -- we do ask that.

MR. REICHLING: Okay. Your Honor, I'm going to
publish Government's Exhibit 32. I believe it is in evidence.
I believe it was admitted yesterday.

THE COURT: It is.

MR. REICHLING: Any objection?

MS. WAID: It's in evidence.

MR. REICHLING: That went in yesterday.

(Evidence was published via the projector.)

BY MR. REICHLING:
Q Now, could you go to the stop of the zoomed in portion?
It says: "Signature, see attached wire agreement on file."

What does that mean?
Case 2:20-cr-00114-JES-M_M Document 162-4 Filed 06/29/21 Page 24 of 44 PagelD

3758
KRISTEN DIIORIO — DIRECT/REICHLING 24
1 | A That just tells my wire department that we don't have a
2 Signature because we do have a wire agreement on file, and then
3 they'll look to the file to make sure we do.
4 fe) And the date included there, is that the date that you
5 entered the wire request into Sanibel Captiva's system?
6 | A Correct, it is.
7 Q And if you look below that, it says wire purpose. Could
8 you read what you wrote there?
9 A "Payroll transfer to partner."
10 Q And it's entered by whom?
11 A Me.
12 Q And I see: "If fax, call back info." Do you see that?
13 A This is just where we provide how we verified it. Sol
14 put: "Verified codeword with Casey Crowther." And listed his
15 phone number.
16 | Q Are you familiar with Mr. Crowther's voice?
17 A I am.
18 Q And did he identify himself in that phone call, and you
19 were familiar with his voice?
20 A I don't know that he said his name, but I've called him
21 enough to know his voice and to know that that's his number.
22 Q Okay. Now, Government's Exhibit 31. Could you just
23 briefly explain what that is?
24 A This is what would generate if you asked for a wire
25 confirmation. It's just a confirmation e-mail.
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KRISTEN DIIORIO — DIRECT/REICHLING 25
Q Okay. And is this a record that is accessible and kept

by Sanibel Captiva Bank?
A Correct, it is.
MR. REICHLING: I'm going to publish Government's
Exhibit 31.
(Evidence was published via the projector.)
BY MR. REICHLING:
Q Does this document also contain what the purpose of the
wire was?
A I believe it does. Yeah. This is more what we just

plug in internally. But yes, it does notate payroll transfer.

Q To whom?

A It doesn't list it on our form.

Q But it says payroll transfer to, could you read the rest
of that?

A I don't see it listed on this form.

QO If you look at the zoomed in portion of Government's

Exhibit 31 that's on the screen to your left, or up on the

screen behind you, you should take a look at it.

A Oh. Sorry.

Q Verify, next to that section?

A Yeah. Payroll transfer to partner.

Q And what's this verified thing about?

A That is the second employee verification; so that is one

of the employees in my office, Cassie Spara, who just did the
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KRISTEN DIIORIO -— DIRECT/REICHLING 26

double-checking with the internal stuff to make sure that the
funds were available, that we, you know, checked all the boxes
on our end that we needed to before sending it.

Q If a customer has more than one bank account with
Sanibel Captiva Bank, is it possible for them to transfer funds
amongst their accounts?

A Absolutely, um-hum.

Q ‘And do you have the capability of doing that as -- this
might sound like a dumb question, but do you have the
capability of doing that, yourself, since you're branch manager
or office manager?

A I do.

Q And do customers request that you sometimes transfer

funds amongst accounts that they have with Sanibel Captiva

Bank?

A Yes.

Q I'd like you to take a look at Government's

Exhibit .. . I think it's going to be... 28.

A Okay.

Q Do you recognize that e-mail?

A I do.

Q And is it a fair and accurate copy of an e-mail that you

received from Mr. Crowther on April 26th, 2020? I mean
April 22nd, 2020, sorry.

A Yes, um-hum.
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KRISTEN DIIORIO — DIRECT/REICHLING 27

MR. REICHLING: At this time, Your Honor, the
government would move what's been previously marked as been
government's 28 into evidence.

MS. WAID: No objection.

THE COURT: Twenty-eight will be admitted and may be
published.

(Government's Exhibit 28 admitted.)

BY MR. REICHLING:

Q What was this e-mail about?

A It was a request to transfer funds from the PPP account
into the personal checking account.

(Evidence was published via the projector.)

BY MR. REICHLING:

Q Could you just briefly read the e-mail that you received
from Mr. Crowther?

A Yes. It says can you transfer $3,300 into my personal
account ending in 3439. I want it for my PPP account. Let me

know when it's done, please.

Q And what was the date of that e-mail?
A Wednesday, April 22nd, 2020.
Q Did Mr. Crowther, in the month of April, 2020, request

additional wire transfers from the PPP account, if you recall?
A I'm not sure if it was the month of April.
Q Okay. Well, do you recall a wire request in the month

of April to a marina?
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KRISTEN DIIORIO -— DIRECT/REICHLING 28
A I do.
Q And could you explain why you didn't handle that
I particular wire request?
A Yes. I was working from home at the time, and just

didn't have the devices needed to process a wire from, so I

forwarded it to my assistant branch manager to take care of.

Q And who was that?
A Jennifer Briggs.
Q And did she handle that request?
A She did.
Q I'll have you take a look at Exhibits 35, 36, 37, and
38.
A I might not have 35 and 36.
MS. WAID: Sorry, I didn't hear. What exhibits were
they?

MR. REICHLING: 35, 36, 38, and 30 -- sorry.

MS. WAID: 35, 36, 38, and 30?

(Mr. Reichling and Ms. Waid confer privately.)

MS. WAID: Your Honor, we are going to object to 35,
36, 37, for lack of a proper foundation.

THE COURT: 35 and 36 are already in. 37 I don't
know anything about, so I don't think 37 has been offered yet.

MR. REICHLING: My apologies, Judge. It's 34,
35... it's going to be 35, 36, and 37. And 35 and 36 appear

to be in evidence at this time.
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KRISTEN DIIORIO — DIRECT/REICHLING 29

COURTROOM DEPUTY: Yes.

MS. WAID: Just for the record, Your Honor, they were
admitted as business records, so our objection is for
relevancy.

(Counsel provides evidence to the witness.)

BY MR. REICHLING:

Q Do you recognize Government's Exhibits 35 and 36?

A I do.

Q And what are they?

A It's our wire form that's generated from our software

after we input it and the wire confirmation.

Q And what's Government's Exhibit 36?

A Thirty-six?

Q Yes, ma'am.

A It's the wire form that prints out once it's on our
system.

Q And what do these particular documents reference?

A It references the bank it's going to, the beneficiary,

the account we're taking it from, who authorized.

And does this document state the purpose of the wire?
It does.

And what is the amount?

This one is for 55,000.

And Government's Exhibit 36, what did you state it was?

Fr Oo FP O YF O

I'm sorry, for the dollar amount, or —--
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KRISTEN DIIORIO — DIRECT/REICHLING 30
Q No, no. What's the document?
A The document is our wire form that prints up once we put
it in our system.
Q Is that your handwriting that's on Government's
Exhibit 36?
A It is.
6) And this is already in evidence, but I just want to

confirm that you did fill out that form.

A I did.
MR. REICHLING: Permission to publish, Your Honor?
THE COURT: You may.
MS. WAID: We object to relevance, Your Honor.
THE COURT: Same ruling as before, I'm admitting it.
(Government's Exhibit 36 admitted.)
(Evidence was published via the projector.)

BY MR. REICHLING:

Q Could you state what the purpose of this wire was for?
A Materials.

Q And is that your signature there, next to, "Entered by"?
A It is.

fe) And could you refer to: "If faxed, call back info?"

Could you read what you wrote there?
A Sure. I put: "Verified with Casey," at his phone
number, with a dollar amount and codeword.

@) And what is the date of this wire transfer?
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KRISTEN DIIORIO -— DIRECT/REICHLING 31
A June lst, 2020.
Q Now, Government's Exhibits, I believe it was 37 and 38,

could you take a look at those?

A Okay.
Q What is Government's Exhibit 37?
iN This was the initial e-mail request for Casey requesting
the wire.
Q And is that the wire we just referenced in that wire

form you filled out?
A It is.
Q And is this a fair and accurate copy of an e-mail that

you received from the defendant on June lst regarding that wire

request?

A It is.

Q And is there an attachment to that e-mail?

A Yes, there is.

Q And just can you just briefly not state what's on that

attachment but what it is?

A It's a copy of the bottom of a check.

Q And there's handwriting contained on Government's
Exhibit 37. Could you explain whose handwriting there is, and
why there's handwriting on it?

A It's mine and Jennifer Briggs, my assistant branch
manager, who was the second verifier. We just initial it so,

when our wire department receives it, they know it's an
Case 2:20-cr-00114-JES-M_M Document 162-4 Filed 06/29/21 Page 32 of 44 PagelD

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3766

KRISTEN DIIORIO — DIRECT/REICHLING 32

authentic e-mail attachment from what we received.

Q And is this a fair and accurate copy of an e-mail you
received from Mr. Crowther and wrote on on June lst, 2020?

A It is.

MR. REICHLING: At this time, Your Honor, the
government would move what's previously been marked as
Government's Exhibit 37 in evidence.

THE COURT: Any objection?

MS. WAID: Same objection, relevance, Your Honor.

THE COURT: All right. Thirty-seven will be
admitted.

(Government's Exhibit 37 admitted.)

(Evidence was published via the projector.)

BY MR. REICHLING:

Q Could you read the body of that e-mail?

A Yes. "Can you wire 55,000 out of my operating account
to the attachment. It's for materials." Do you need me

to

Q That's it. Sorry. And is this the attachment, is
that -- what is that?

A It's a picture of a bottom of a check, and contains a

routeing number and account number.
Q And were these documents -- or was this e-mail and
document used in your processing of that request?

A It was.
Case 2:20-cr-00114-JES-M_M Document 162-4 Filed 06/29/21 Page 33 of 44 PagelD

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KRISTEN DIIORIO — DIRECT/REICHLING 33
Q Now, Government's Exhibit 38, could you take a look at
that?
| A Okay.
Q And what is that?
A It's an e-mail from Casey just asking for wire

confirmation. Something that shows that we sent the wire.

Q And does that wire confirmation for that wire transfer
we just talked about?

A Are you -- I'm sorry, do you mind repeating that?

Q I'm asking the context of the e-mail. Is that e-mail
referencing the wire transfer that you just testified about,
the June lst one?

A Yes.

Q And is it a fair and accurate copy of an e-mail exchange
that you had with the defendant on that date?

A Yes.

MR. REICHLING: At this time, Your Honor, the
government would move what's been previously marked as
Government's Exhibit 38 into evidence.

MS. WAID: Same objection, relevance, Your Honor.

THE COURT: All right. That objection is overruled,
Exhibit 38 will be admitted.

(Government's Exhibit 38 admitted.)

MR. REICHLING: I'm going to publish Government's

Exhibit 38, Miss Dilorio. I'd like you to go to the second
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KRISTEN DIIORIO — DIRECT/REICHLING 34

page of that exhibit.
(Evidence was published via the projector.)
BY MR. REICHLING:
Q What is the date and time of that wire transfer? I

mean, excuse me, e-mail.

A It was received on Monday, June lst, 2020, at 9:55 a.m.
Q And can you read the body of that e-mail?
A It says: "Can you send me something that shows we made

the wire? I want to show them something so the guys can pick

material up now."

Q And is the first page of Government's Exhibit 38 your
response?

A Yes.

Q Ts that what I published here before the jury?

A Correct.

Q And who was the recipient of that wire, if you could
say?

A Heather Mangus at J.P. Morgan Chase.

Q Now, I believe it's going to be Government's Exhibit 39.

Actually, it's Government's Exhibit 30. My apologies.

A Thirty?

Q Yes, ma'am.

A Okay.

Q Could you take a look at Government's Exhibit 30,

Pages 1 and 2, and just not read from the document, but state
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KRISTEN DIIORIO — DIRECT/REICHLING 35

what it is?

A Sure. It's an e-mail sent from the comptroller just
asking about wiring funds.

Q And could you look at the second page of that e-mail? —
Is that the attachment that was included with that e-mail?
I would say yes. Yes.

And what is this for?

It was a wire request to -- do you want me to --
Yeah, who is it to?

Going to Steve Adkins for $150,000.

And what was the date of this wire transfer request?
Looks like July 17th, 2020.

And is the defendant cc'd on this e-mail?

Yes.

And is that a fair and accurate copy of an e-mail that

you received on that date from the comptroller of Target

Roofing?
A Yes.
Q And is the attachment a fair and accurate copy of the

attachment that was included with that e-mail?

A Yes.
MR. REICHLING: Okay.
At this time, Your Honor, the government would move

what is been previously marked as Government's Exhibit 30 into

evidence.
Case 2:20-cr-00114-JES-M_M Document 162-4 Filed 06/29/21 Page 36 of 44 PagelD

3770
KRISTEN DIIORIO -— DIRECT/REICHLING 36

1 MS. WAID: Objection, relevance, Your Honor.

2 THE COURT: That objection is overruled. Thirty will
3 be admitted.

4 (Government's Exhibit 30 admitted.)

5 | BY MR. REICHLING:

6 Q Miss Dilorio, could you explain this particular wire

7 request and what it was for?

8 A I mean, the... . The purpose says note payment.

9 Q Okay. But, just generally, what was this -- who was
10 this -- who are these funds to be sent to?
11 A Steve Adkins.
12 Q And what is the date of this request again?
13 A July 17th, 2020.
14 MR. REICHLING: Okay. I'm going to publish
15 Government's Exhibit 30.
16 (Evidence was published via the projector.)
17 BY MR. REICHLING:
18 Q And I'm zooming in there on the body. Who is Larry

19 Caudill?
20 ] A He's a comptroller for Target Roofing.
21 Q And have you. . . I guess, worked with Mr. Caudill in
22 dealing with account issues regarding any of Target Roofing's
23 bank accounts that they have with Sanibel Captiva Bank?

24 A Yes.
25 Q Did there come a time that Mr. Caudill had inquired
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KRISTEN DIIORIO — DIRECT/REICHLING 37

about accessing the PPP account?

A Yes.

Q And did he have access to the PPP account?

A Not at that time, no.

Q Now I'm going to go to the second page of this exhibit.
What account number -- or what account was this wire coming
from?

A Their operating account.

Q Their operating account. Who is "their"?

A Target Roofing's.

Q And is that the account ending in 1791?

A Correct.

Q And what is the amount of the wire?

A 150,000.

Q And who was it being sent to?

A Steve Adkins.

Q And what is the purpose of this wire?

A Note payment.

Q Is there anything in there that indicates it was for a

payroll transfer?

A I don't see anything, no. And I don't recall.

Q Is that the section that references the purpose of the
wire?

A Correct, it is.

Q Do you have Government's Exhibit 107 before you? I know
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KRISTEN DIIORIO — DIRECT/REICHLING 38

it's already in evidence, but.

A I do, yes.

Q And can you take a look at that?

A Okay.

Q And what is that?

A It's our monthly account statement. Looks like this

one's for the month of April, 2020.
Q And I'm going to publish it, because it's already in
evidence.

(Evidence was published via the projector.)

BY MR. REICHLING:

Q And what account statement is that for?
A The one with the one title "PPP Loan".
Q Now I'm going to focus in on the bottom of that bank

statement, and specifically I want to refer to the transaction

dated 4/16/2020. It says: "Loan from Casey, $126,000." Did

you enter in: "Loan from Casey"?
A I don't believe that was done in the bank. I think that
was done in -- through their log-ins. But I couldn't say with

a hundred percent certainty. I don't recall doing that.

Q Does Mr. Crowther have online account access to his bank
accounts, if you know?

A He does, um-hum.

Q And are clients like Mr. Crowther able to transfer funds

amongst accounts using their online access?
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KRISTEN DIIORIO — DIRECT/REICHLING 39
A They are.
Q And is there any cap on how much money could be

| transferred back and forth between accounts, do you know?

A No. As long as their ownership is -- as long as they're
owners on all accounts, they can do whatever amount as long as
the funds are available.

QO Now, is the transaction dated April 21st, 2020, is that
regarding the wire transfer you discussed earlier to Steven

Adkins on 4/21/2020?

A Not the one we just discussed, but earlier.

Q Early early?

A Correct.

Q The one you discussed in the beginning of your
testimony.

A Yes.

Q And what about the 4/22/20 transaction, is that the

transfer of funds that you assisted Mr. Crowther with that he

indicated he wanted to come from his PPP account?

A Yes.

Q And Exhibit 424 we haven't talked about, but what is
that?

A That's a wire that was performed on that date going to

Sara Bay Marina.

Q Now, do you recall having a conversation with

Mr. Crowther in the month of July concerning his desire to
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KRISTEN DIIORIO — DIRECT/REICHLING 40

inquire, excuse me, about depositing cash?

A I do.

Q Okay. I believe you should have Government's

Exhibit 173 in front of you? What is Government's Exhibit 173?
A It was my e-mail back to Casey Crowther in response to

an inquiry he had over the phone about depositing cash into the

bank.

Q And what's date of that e-mail?

A July 30th -- I'm sorry, July 3lst, 20.

Q And is that a fair and accurate copy of an e-mail that

you sent to Mr. Crowther on that date?
A It is.

MR. REICHLING: At this time, Your Honor, the
government would move what's been previously marked as
Government's Exhibit 173 into evidence.

MS. WAID: No objection.

THE COURT: 173 will be admitted and may be
published.

(Government's Exhibit 173 admitted.)

BY MR. REICHLING:

Q Could you read what you wrote the defendant in that
e-mail?
A "Hi Casey. I have spoken with our internal auditors,

and what we need for you to provide on the cash deposit is

noted below: Name, occupation, and address of the purchaser of
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KRISTEN DIIORIO — DIRECT/REICHLING 41

the boat, person who gave you the cash, explanation of the
source of the cash, where did the cash originate from,
information on the boat, make, model, VIN. If you can produce
a bill of sale, that would take care of this part. If/when you
get this information, we can coordinate a day for you to bring
in the deposit. Please let me know if you have any other
questions. Hope all went well with the closing."

Q Let me ask you, Miss Dilorio, would it have been your
practice to wait days or weeks to send that to Mr. Crowther
after he asked you for information about depositing cash?

A No.

Q Do you recall if you sent that the same day he asked you

about depositing cash?

A I can't say. I think maybe next day.
Q And you're referring to a closing. What's that about?
A I think we might have done a wire for a closing on

the day before. I don't recall the dates, but I'm assuming we
did something that I knew about it, so.
Q Was it a wire for a closing on a house?
A I believe so.

MR. REICHLING: One moment, Your Honor. If I could
just confer with co-counsel real quick.

(Mr. Reichling and Mr. Leeman confer privately.)
BY MR. REICHLING:

Q Following receipt of this e-mail, or sending this e-mail
Case 2:20-cr-00114-JES-M_M Document 162-4 Filed 06/29/21 Page 42 of 44 PagelD

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KYLE DECICCO - REDIRECT/REICHLING 42

on July 31st, 2020, do you recall if you handled the deposit of

the cash that Mr. Crowther was referring to?

A No. No, nothing more was .. . done with it after that
with me.
| Q Okay. And do you recall if any large cash ~- you were

] involved with depositing a large quantity of cash following the
date of that e-mail?

A No, huh-uh.

1 MR. REICHLING: No further questions at this time,

Your Honor.

THE COURT: All right. Thank you.
Ms. Waid, you may proceed.
MS. WAID: Thank you, Your Honor.

(At 2:05 p.m., direct examination of Kristen Dilorio

concluded. )

k ok *
At 2:20 p.m., redirect examination of Kristen Dilorio
commenced. )
THE COURT: Any redirect?
| MR. REICHLING: Just briefly, Your Honor. Thank you.
REDIRECT EXAMINATION
BY MR. REICHLING:
| Q I just have a couple brief follow-up questions.

Brad North, he didn't have access to that PPP account,

did he?
Case 2:20-cr-00114-JES-M_M Document 162-4 Filed 06/29/21 Page 43 of 44 PagelD

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KYLE DECICCO ~ REDIRECT/REICHLING 43
A No.
Q And Evelyn Portinari, she also didn't have access to

that PPP account; correct?

A Correct.

| Q And Mr. Pavelo that we talked about, he didn't have

access to that PPP account either.

A Correct.

Q Who was the only person that had access to it?

A Casey.

Q And was it at Casey's direction that you opened that up

separately from his main operating account?

A Correct.

Q It wasn't your choice to open up a separate PPP account?
A Was it mine? No.

Q Now, the wire that was sent to Steven Adkins that we

talked about at the beginning, that was sent from the PPP

account; correct? ,
A Correct.
Q And you stated the purpose of the wire when it was sent

from the PPP account was for a payroll transfer to a partner;

correct?
A Correct.
Q And then we talked about a later wire transfer that was

sent in July from the main operating account of Target Roofing?

A Correct.
Case 2:20-cr-00114-JES-M_M Document 162-4 Filed 06/29/21 Page 44 of 44 PagelD
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44

1 Q And what was it called then? What was the purpose then?

NO

I think it was a note payment; correct?

3 A CoOrrece.

4 MR. REICHLING: No further questions, Judge.
5 THE COURT: Any recross?

6 MS. WAID: No thank you, Your Honor.

oh THE COURT: You may stand down. Thank you.
8 You may call your next witness.

9 (The witness left the witness stand.)

11 (Thereupon, at 2:22 p.m., the direct-examination
LZ testimony of Kristen Dilorio was concluded.)

14 CERTIFICATE

15 I CERTIFY THAT THE FOREGOING TRANSCRIPT IS A TRUE AND ACCURATE
16 TRANSCRIPT FROM THE ORIGINAL STENOGRAPHIC RECORD IN THE

LF ABOVE-ENTITLED MATTER.

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Dated this 11th day of March, 21.
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