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Home Court filings USA v. Ilori et al — U.S. District Court, Southern District of New York Exhibit Exhibit B — USA v. Ilori et al (Dkt. 33.1)

Court filing

Exhibit Exhibit B — USA v. Ilori et al (Dkt. 33.1)

Record facts

CourtU.S. District Court for the Southern District of New York
Filed2022-05-26

U.S. District Court for the Southern District of New York · No. 1:21-cr-00746-MKV · Doc. 33-1 · 2022-05-26 · Docket on CourtListener

Summary

Doc. 33-1 in USA v. Ilori et al, No. 1:21-cr-00746-MKV, in the U.S. District Court for the Southern District of New York, filed May 26, 2022, is Exhibit B: the transcript of a digitally recorded sworn statement taken by the Department of Justice Office of the Inspector General on October 8, 2021, OIG case 2021-009252. Harry Lidsky, an agent with the Office of the Inspector General, questions the interviewee with Kerwin John after the execution of a search warrant at the interviewee's apartment. Lidsky reads Miranda warnings, asks for a signed rights form, and explains that cooperation could lead to a recommendation for a substantial-assistance reduction but that no promises can be made. The questioning covers items found in the apartment and the interviewee's associate, Mr. Ilori. The 78-page transcript closes at approximately 2:21 a.m. with a transcriber's certificate.

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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DIGITALLY RECORDED 
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SWORN STATEMENT 
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OF 
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CHRIS RECAMIER 
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OIG CASE #: 
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2021-009252 
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DEPARTMENT OF JUSTICE 
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OFFICE OF THE INSPECTOR GENERAL 
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OCTOBER 8, 2021 
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RESOLUTE DOCUMENTATION SERVICES 
28632 Roadside Drive, Suite 285 
Agoura Hills, CA 91301 
Phone:  (818) 431-5800 
USAO_00000287
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APPEARANCES: 
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OFFICE OF THE INSPECTOR GENERAL 
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BY: KERWIN JOHN 
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BY: HARRY LIDSKY 
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WITNESS: 
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CHRIS RECAMIER 
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OTHER APPEARANCES: 
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NONE 
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USAO_00000288
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MR. LIDSKY:  Did you want that?  
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MR. JOHN: No.  
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MR. LIDSKY:  Is this for you?   
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MR. JOHN: Do you want it?  
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MR. LIDSKY:  Yeah.  (Indiscernible 
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*00:00:08).  Otherwise, I’ll drink it.  We have 
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plenty more.  
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MR. JOHN: Yeah.   
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MR. LIDSKY:  Are we good?  
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MR. JOHN: Yeah.  
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MR. LIDSKY:  Oh, I'm sorry.  Okay.  Chris, 
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thank you for your patience.  
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MR. RECAMIER:  Sure.  
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MR. LIDSKY:  As I said in the car, we are 
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just, you know, kind of re-doing what we have 
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talked about.  Both at the apartment and in the 
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car ride.  So, let me introduce myself.  My 
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name is Harry Lidsky.  I know it was quick when 
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we first met.  But my name is Harry LIdsky.  
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I'm an agent with the Department of Justice, 
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Office of the Inspector General.  We talked 
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about why we knocked on your door.  We executed 
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a search warrant at your apartment, as you 
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know, you saw a copy of that warrant.  You will 
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be provided with a copy.   
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We left one at the apartment, as well.  We 
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discussed a number of procedural things 
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(Indiscernible *00:01:41).  And I also provided 
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you with your Miranda warnings, just verbally, 
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and as I said when we got back to the office, I 
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wanted to do it in writing, as well.  So, we 
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will go ahead and do that now.  Before, when we 
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were at the apartment - and I realize this is 
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redundant - but I know you speak with a French 
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accent.  I asked you your nationality, you did 
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say you were a citizen of France.  
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MR. RECAMIER:  Mm-hmm.  
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MR. LIDSKY:  And we will notify the 
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consulate, as required.  But, you know, it is 
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clear that you understand English.  I asked you 
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if you understand English.  You acknowledged 
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that you were proficient enough, and we have 
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conversed accordingly.  So, I'm just going to -
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.  I’ll give one copy.  These are identical.   
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MR. RECAMIER:  Okay.  
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MR. LIDSKY:  I’ll just read along.  I’ll 
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read it to you, you can read along with me.  We 
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found glasses.  We let you bring those.  And 
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I’ll just ask you when we are done.  And 
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certainly, if you have any questions, and 
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require any clarity on any of these, feel free 
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to ask, and I’ll just ask if you understand 
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each.  So, before we ask you any questions, or 
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you make any statement, you must understand 
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your rights.   
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“You have the right to remain silent and 
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refuse to answer any questions at any time.  
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Anything you say can be used against you in a 
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court of law or other proceedings.  You have 
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the right to talk to a lawyer for advice, 
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before answering any questions, and to have a 
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lawyer with you during any questioning, now or 
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in the future.  If you cannot afford a lawyer, 
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one will be provided for you without cost.  If 
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you decide to answer questions now, you have 
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the right to stop answering questions at any 
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time you desire.”   
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And then, what I'm going to ask is, for 
18 
you to ensure that you understand the following 
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statement.  I will read it out loud.  “I have 
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read the statement of my rights, and I 
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understand what my rights are.  I am willing to 
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make a statement and answer questions.  I 
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understand I know what I am doing.  No promises 
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or threats have been made to me, and no 
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pressure or coercion of any kind has been used 
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against me.”  If you have any questions about 
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that, I am happy to answer, do you understand 
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all of the rights and warnings that are on this 
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form?  
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MR. RECAMIER:  Yeah, I do.  
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MR. LIDSKY:  Now, I’ve read you these 
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rights.  I read you Miranda back at the 
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apartment.  We spoke fairly informally.  I 
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mean, we were seated at the corner and you 
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were, we were executing a search warrant.  So, 
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it wasn’t as formal as sitting here in the 
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office.  But I would like to go over just the 
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questions we covered at the apartment, and some 
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in the car.  There were some you did not want 
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to answer, and that is perfectly fine.  That is 
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your right.  It still is.  And as the, you 
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know, it’s not one of the rights on here, but 
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you can choose which questions you would like 
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to answer, and which ones you prefer not to 
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answer.  And that is fine.  So, if you are 
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willing, I would like to just cover some of the 
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ground we have already covered.  But in order 
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to do that, I would --  
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MR. RECAMIER:  Right. 
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MR. LIDSKY:  -- ask for us all to sign and 
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date this form, indicating that we are willing 
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to go forward and do that.   
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MR. RECAMIER:  Yeah.  Okay.  
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MR. JOHN:  Okay.  
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MR. LIDSKY:  Thank you.  You can just sign 
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your copy.  So, you would be there.  And then, 
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the next line down, if you could just print 
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your name.  And then --  
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MR. RECAMIER:  What day is today?  
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MR. LIDSKY:  -- it is already Friday, 
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October 8th.   
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MR. RECAMIER:  Gotcha.  
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MR. LIDSKY:  And we are in New York, New 
14 
York.  Oh, and the time is 1:15 a.m.   
15 
MR. RECAMIER:  There you go.  
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MR. LIDSKY:  Thank you.  And I will sign 
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here.  And Kerwin, you sign there.  This is 
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Kerwin John.  I know we all kind of --  
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MR. RECAMIER:  Yes.  
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MR. LIDSKY:  -- met informally out there.  
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I don't know.  So, one of the things we talked 
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about, obviously, when we came in, I, you know, 
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I wanted to ensure that you knew why we were 
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there, and what this was about.   
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MR. RECAMIER:  Mm-hmm.  
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MR. LIDSKY:  In doing so, I mentioned a 
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few of the names that I know you as, through 
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the course of this investigation.  Just, you 
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know, I wanted to make sure you know who, you 
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know, I want you to know, you know, this is 
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serious, and know that this is, you know, a 
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pretty thorough investigation.  And we know 
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what we are talking about.  And so, you 
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acknowledged that.  You know, I did ask you to 
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own any of those, but I did ask for your actual 
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name, date of birth, and social security 
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number, which you provided.  Thank you.  You 
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know, we were going to, obviously, we are going 
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to print you.  I informed you that if you 
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wanted to be booked in as John Doe, you know, 
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you can't get bail until the court finds out 
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who you really are.  So, you, you know, you 
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accepted that.   
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MR. RECAMIER:  Mm-hmm.  
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MR. LIDSKY:  You understood that.  You 
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provided your name.  Your true name and date of 
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birth.  Your social security number.  I’ve 
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checked that.  It’s real.  So, thank you for 
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that.  I asked you if understood English.  I 
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USAO_00000294
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think we covered this.  You said you did and 
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you are willing to keep talking English, and I 
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appreciate that because we don’t speak French.  
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We are aware, I asked you your nationality.  
4 
You are a French citizen.  And so, we will 
5 
notify the consulate, of course, tomorrow, or 
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we will follow whatever the requirements are.   
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Admittedly, I haven't arrested a foreign 
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national in a while.  So, I am not -.  I will 
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have to refresh the process, with regard to 
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that.  We also, I asked you if you were under 
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the influence of any alcohol or drugs.  You 
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acknowledged that you do have an addiction, a 
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substance abuse problem.  So, we appreciate 
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that, and you are lucid, you understand what is 
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going on.  You haven't used in a while.   
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MR. RECAMIER:  Yeah.  
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MR. LIDSKY:  And I mentioned to you, too, 
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it is important when the court, you know, asks 
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you these questions, please be honest.  They 
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are more for your health.  We are not -.  This 
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is not a drug investigation.  You are not being 
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charged with any drug offenses.  Through our 
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conversation, I have learned that you have a 
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current case in the city of New York, regarding 
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USAO_00000295
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drug offenses.  You are represented there.  We 
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are not asking any questions about that. 
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MR. RECAMIER:  Okay.  
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MR. LIDSKY:  Aside from your history.  
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Please don’t offer up any information about 
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that case, without your attorney at least being 
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present for that.  We are not interested, and 
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any questions that we ask you are not designed 
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to elicit a response regarding that 
9 
investigation.   
10 
MR. RECAMIER:  Okay.  
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MR. LIDSKY:  And if they seem to, then 
12 
please, you know, tell us, because we are going 
13 
down the wrong path.  Other than that, we asked 
14 
you a couple of questions about things in the 
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apartment that, you know, do they belong to 
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you, or do they belong to your associate, Mr. 
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Ilori.  So, I informed you that, you know, we 
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knew about him.  We know about him.  We know 
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about his role.  We are certainly curious to 
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learn more about the roles.  
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MR. RECAMIER:  Mm-hmm.  
22 
MR. LIDSKY:  Admittedly, there is some 
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gaps in what we know, or we would certainly 
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like affirmation of some of the things that we 
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believe to be true, and I think you are able to 
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fill in those gaps, if you desire to do so.  I 
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also informed you of how the federal system 
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works.  You have admittedly been arrested at 
4 
the state level, but not at the federal level, 
5 
and you asked me if this was federal or NYPD.  
6 
And I told you that it was federal.   
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In the federal system, anybody who is 
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deemed to have cooperated and provided 
9 
substantial assistance to the government with 
10 
regard to an investigation, can be entitled to 
11 
a reduction in their sentence.  That reduction 
12 
is made by the judge, at his or her discretion.  
13 
We cannot promise any reduction in exchange for 
14 
cooperation.  The way it works in the federal 
15 
system is, if you cooperate with us, with our 
16 
investigation, we will make a recommendation 
17 
through the U.S. Attorney’s Office, to the 
18 
court, that you are eligible, that you should 
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be eligible and considered for substantial 
20 
assistance reduction.   
21 
But the judge can disagree unilaterally, 
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and not afford it.  So, the takeaway there is 
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we can't make any promises.  I informed you 
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that we would certainly like your cooperation.  
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We are interested in it.  I told you, honestly, 
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that we know you are not alone in this.  
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MR. RECAMIER:  Mm-hmm.  
3 
MR. LIDSKY:  And you have an opportunity 
4 
to help us out.  And, you know, that choice is 
5 
yours.  I also told you that, you know, there 
6 
would come a time where, you know, you have to 
7 
decide whether or not you want to help, and to 
8 
the degree you want to help.  And you are, you 
9 
know, that is a choice you have to make 
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voluntarily.  And of your own volition.   
11 
MR. RECAMIER:  Mm-hmm.  
12 
MR. LIDSKY:  So, and that stands.  And we 
13 
talked about that.  We asked you - we found 
14 
your cell phone - we did ask you for the 
15 
passcode and you declined to give it, and that 
16 
is perfectly within your rights.  And you can 
17 
answer this question and not that question.  
18 
And that is fine.  It’s no hard feelings.  And 
19 
that, you can continue along that line.   
20 
MR. RECAMIER:  Mm-hmm.  
21 
MR. LIDSKY:  We asked you what in the 
22 
apartment was yours versus Mr. Ilori’s.  You 
23 
know Mr. Ilori as - in his true name - as Mr. 
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Ilori.  Do you know his first name?  
25 
USAO_00000298
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MR. RECAMIER:  Yeah.   
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MR. LIDSKY:  Do you mind telling me his 
2 
first name?   
3 
MR. RECAMIER:  Adedayo.   
4 
MR. LIDSKY:  Adedayo.  Okay.  So, we are 
5 
pronouncing it the same.  I imagine you 
6 
recognize a picture of Mr. Ilori if I showed 
7 
you one?   
8 
MR. RECAMIER:  Yeah. 
9 
MR. LIDSKY:  Okay.  Do you mind if I show 
10 
you one?  It’s just to --  
11 
MR. RECAMIER:  Mm-hmm.  
12 
MR. LIDSKY:  -- make sure we are talking 
13 
about the same person.   
14 
MR. JOHN:  You have one handy?   
15 
MR. LIDSKY:  I got one.   
16 
MR. JOHN:  If you could send me one, I 
17 
could print it.  
18 
MR. LIDSKY:  Oh, I’ll pull it up.  Let me 
19 
just say I'm sorry.  And I do appreciate your 
20 
patience.  I know it is late.  
21 
MR. RECAMIER:  Yeah.  
22 
MR. LIDSKY:  I know this was --  
23 
MR. RECAMIER:  Yeah.  
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MR. LIDSKY:  -- I wish we could have done 
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this a bit earlier, as well.  I am sure you 
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feel likewise.  
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MR. RECAMIER:  That’s fine.  
3 
MR. LIDSKY:  Thank you for your 
4 
understanding and patience with us.  Okay.  Is 
5 
that -?  Are we talking about the same person?  
6 
MR. RECAMIER:  Yeah.  
7 
MR. LIDSKY:  Okay.  Were you with Mr. 
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Ilori today?  
9 
MR. RECAMIER:  Yeah.  
10 
MR. LIDSKY:  You were with Mr. Ilori in 
11 
Chipotle --  
12 
MR. RECAMIER:  Mm-hmm.  
13 
MR. LIDSKY:  -- late this afternoon.  
14 
Okay.  So, we are talking about the same 
15 
person.  What did we cover?  Oh, I did, in the 
16 
car, I asked you, I noticed, you know, this 
17 
investigation, of course, you know, as I have 
18 
mentioned, I rattled off a number of the 
19 
aliases, or the identities that we were aware 
20 
of, a number of them.  I did notice that there 
21 
were no IDs.  I have a number - and I am happy 
22 
to show you, if you want - I have a number of 
23 
IDs with your picture on them.   
24 
MR. RECAMIER:  Mm-hmm.  
25 
USAO_00000300
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MR. LIDSKY:  But I didn’t find any of 
1 
those in the apartment, nor did I find any of 
2 
the credit cards, or debit cards --  
3 
MR. RECAMIER:  Mm-hmm.  
4 
MR. LIDSKY:  -- that go along with the 
5 
bank accounts associated with those IDS.  So, I 
6 
asked you, you know, does he have all of those?  
7 
MR. RECAMIER:  Mm-hmm.  
8 
MR. LIDSKY:  And you said that he did.  
9 
MR. RECAMIER:  Mm-hmm.  
10 
MR. LIDSKY:  Does he just not trust you 
11 
with them, or I mean, why does he -?  
12 
MR. RECAMIER:  No.  I mean, like, we 
13 
usually have -.  We would, I mean, you know 
14 
that kind of thing got around.  So, we use the 
15 
credit card when we go outside.  I mean, like, 
16 
and we are not using them that much, anyway.   
17 
MR. LIDSKY:  Mm-hmm.  Gotcha.  I mean, the 
18 
accounts are kind of depleted.  
19 
MR. RECAMIER:  Yeah.  
20 
MR. LIDSKY:  Right?  A lot of them are.  I 
21 
mean, have you ever had one?  Does he let you -
22 
-  
23 
MR. RECAMIER:  Yeah.  
24 
MR. LIDSKY:  -- okay.  
25 
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MR. RECAMIER:  Yeah.  He does.  
1 
MR. LIDSKY:  Like, do you each have one?  
2 
Just on the same account, or he -?  
3 
MR. RECAMIER:  No.  It is very, like, I 
4 
mean, like, he give me one, like, sometimes, 
5 
you know, like --  
6 
MR. LIDSKY:  Just to go out, buy --  
7 
MR. RECAMIER:  Yeah. 
8 
MR. LIDSKY:  -- buy whatever.  Okay.  So, 
9 
sometimes him, sometimes --  
10 
MR. RECAMIER:  Uh-huh.  
11 
MR. LIDSKY:  -- it’s you, but he holds all 
12 
the IDs?  
13 
MR. RECAMIER:  Yeah.  
14 
MR. LIDSKY:  Does he just give them to you 
15 
when it’s time for you to go in --  
16 
MR. RECAMIER:  Yeah.  
17 
MR. LIDSKY:  -- so, we --  
18 
MR. RECAMIER:  Mm-hmm.  
19 
MR. LIDSKY:  -- so, one of the other 
20 
things we brought up was the car.  You know, 
21 
obviously --  
22 
MR. RECAMIER:  Mm-hmm.  
23 
MR. LIDSKY:  -- we are aware of the car.  
24 
MR. RECAMIER:  Okay. 
25 
USAO_00000302
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MR. LIDSKY:  And when - just so we are 
1 
talking about the same car -- 
2 
MR. RECAMIER:  Mm-hmm.  
3 
MR. LIDSKY:  -- is it September, late 
4 
September?  
5 
MR. RECAMIER:  Uh-huh.  Yeah.  
6 
MR. LIDSKY:  At the Mercedes dealership?  
7 
MR. RECAMIER:  Mm-hmm.  
8 
MR. LIDSKY:  Right up the street?  
9 
MR. RECAMIER:  Yeah.   
10 
MR. LIDSKY:  Right?  And you all leased --  
11 
MR. RECAMIER:  Mm-hmm.  
12 
MR. LIDSKY:  -- a -.  Well, I’ll let you 
13 
(Indiscernible *00:16:36).  I know the answer, 
14 
but --  
15 
MR. RECAMIER:  580.  
16 
MR. LIDSKY:  -- the 580.  S-580 --  
17 
MR. RECAMIER:  Mm-hmm.  
18 
MR. LIDSKY:  -- that’s a beautiful car.  
19 
MR. RECAMIER:  Yeah.   
20 
MR. LIDSKY:  It’s a beautiful car.  So, 
21 
for that ID, I think that was --  
22 
MR. RECAMIER:  Mm-hmm.  
23 
MR. LIDSKY:  -- Thomas Hockinberry 
24 
(Phonetic Sp. *00:16:51).   
25 
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MR. RECAMIER:  Yeah.  
1 
MR. LIDSKY:  So, did he just give you it 
2 
and said, go in, I want that one?  
3 
MR. RECAMIER:  Well, I mean, he is the one 
4 
who paid for the ID and everything.  So. 
5 
MR. LIDSKY:  So, that is interesting.  So, 
6 
where did the IDs come from?  So, he buys them?  
7 
He doesn't make them?  
8 
MR. RECAMIER:  No.   
9 
MR. LIDSKY:  No?  
10 
MR. RECAMIER:  He doesn't --  
11 
MR. LIDSKY:  He doesn't make it. 
12 
MR. RECAMIER:  -- make it.  
13 
MR. LIDSKY:  Do you know who he gets them 
14 
from?   
15 
MR. RECAMIER:  No.  I mean, like, on the 
16 
dark web, but -.  
17 
MR. LIDSKY:  Oh.  There are that many out 
18 
there?  
19 
MR. RECAMIER:  Yeah.  
20 
MR. LIDSKY:  Jesus.  So, but so, he had 
21 
that ID?  
22 
MR. RECAMIER:  Mm-hmm.  
23 
MR. LIDSKY:  And did he just pick you up 
24 
and say, here, this is you today, go in and buy 
25 
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the white Mercedes?  
1 
MR. RECAMIER:  I mean, yeah.  You could, 
2 
the way you put it, it sounds funny, but that’s 
3 
(Indiscernible *00:17:43).   
4 
MR. LIDSKY:  I mean, is that -?  And so, 
5 
you just say, okay, you know -- 
6 
MR. RECAMIER:  Yeah. 
7 
MR. LIDSKY:  -- be right back?  
8 
MR. RECAMIER:  Be right back.   
9 
MR. LIDSKY:  And you come back, and just 
10 
flip him the keys?  
11 
MR. RECAMIER:  Yeah.  
12 
MR. LIDSKY:  Does he go in with you?  
13 
MR. RECAMIER:  Yeah.  He came with me 
14 
inside the --  
15 
MR. LIDSKY:  To the dealership?  
16 
MR. RECAMIER:  -- to get the car.  Yeah.   
17 
MR. LIDSKY:  And a couple times to the, 
18 
just so, for the car?  Like, a couple of the 
19 
banks, as well?  
20 
MR. RECAMIER:  No.  To the car.  Not to 
21 
the bank.  
22 
MR. LIDSKY:  Why doesn't he go into the 
23 
banks?  Does he not want to be on camera?  
24 
MR. RECAMIER:  I mean, that he went to, to 
25 
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get money at the bank, yeah, but, like, when 
1 
they opened a new account, he didn't always 
2 
have to be there.  
3 
MR. LIDSKY:  He doesn't.  Yeah.  So, that 
4 
was your role.   
5 
MR. RECAMIER:  Mm-hmm.  
6 
MR. LIDSKY:  And that was his role.  Now, 
7 
in the car, I asked you, you know, what do you 
8 
get out of it, and you didn't answer, and 
9 
that’s fine if you don’t want to.  I am 
10 
curious.  I mean, he seems to -.   
11 
MR. RECAMIER:  I mean, that’s how I met 
12 
him, living, like --  
13 
MR. LIDSKY:  So --  
14 
MR. RECAMIER:  -- for quite a few months.  
15 
MR. LIDSKY:  -- okay.  So, it is just some 
16 
living expenses, cash --  
17 
MR. RECAMIER:  Yeah.  
18 
MR. LIDSKY:  -- the cards, to buy --  
19 
MR. RECAMIER:  Mm-hmm.  
20 
MR. LIDSKY:  -- things from time to time.  
21 
Okay.  That makes sense.  I also asked you - 
22 
see, and I apologize, because I know I'm all 
23 
over the map, but it is late for me, too - 
24 
where you were living.  You said most recently, 
25 
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you don’t have a home, and you have been 
1 
staying at the apartment.  
2 
MR. RECAMIER:  Yeah.  I rent his 
3 
apartment.  Yeah.  
4 
MR. LIDSKY:  And so --  
5 
MR. RECAMIER:  Yeah.  
6 
MR. LIDSKY:  -- that was another one.  
7 
That was -.  And when you answered the door, of 
8 
course, I greeted you by the name Mark Hefron 
9 
(Phonetic Sp. *00:19:14).  
10 
MR. RECAMIER:  Mm-hmm.  
11 
MR. LIDSKY:  I think is the name the 
12 
apartment is leased in.  And that is, you know, 
13 
that is another alias we know.  We think we 
14 
have the real Mark Hefron --  
15 
MR. RECAMIER:  Mm-hmm.  
16 
MR. LIDSKY:  -- ID.  We know it is not 
17 
you.  It is your picture.  So, did he just say, 
18 
today, you are mark Hefron, go rent, you know, 
19 
a one-bedroom?  
20 
MR. RECAMIER:  Well, actually, I was 
21 
looking for an apartment, and -- 
22 
MR. LIDSKY:  Oh, okay.  
23 
MR. RECAMIER:  -- so.  
24 
MR. LIDSKY:  So, it made sense.   
25 
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MR. RECAMIER:  Yeah.  
1 
MR. LIDSKY:  So, does he pay and say, 
2 
listen, I will pay, you can stay there when you 
3 
want --  
4 
MR. RECAMIER:  Mm-hmm.  
5 
MR. LIDSKY:  -- and we will use this -- 
6 
MR. RECAMIER:  Yeah.  
7 
MR. LIDSKY:  -- for our office?  Okay.  
8 
Yeah.  You know, we have seen a lot of the 
9 
documents, you know, the registration for some 
10 
of the companies and the companies.  I mean, 
11 
there is Safe Air, East Coast Air.  
12 
MR. JOHN:  Moola Apps (Phonetic Sp. 
13 
*00:20:06). 
14 
MR. LIDSKY:  Moola Apps.  JetAway 
15 
(Phonetic Sp. *00:20:07) jets.  
16 
MR. RECAMIER:  Mm-hmm.   
17 
MR. JOHN:  Appsensible (Phonetic Sp. 
18 
*00:20:09).  
19 
MR. LIDSKY:  Appsensible.  Twinway 
20 
(Phonetic Sp. *00:20:12)?  
21 
MR. RECAMIER:  Yeah.  
22 
MR. LIDSKY:  And then, there was some in 
23 
individuals.  Hockinberry.  I think you guys 
24 
got declined for a PPP loan on Hockinberry.  Do 
25 
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you even -?  
1 
MR. RECAMIER:  Yeah.  Some of them got 
2 
declined, I know.  
3 
MR. LIDSKY:  So, are you involved in that 
4 
part of it, or is that all him?  
5 
MR. RECAMIER:  What?  
6 
MR. LIDSKY:  Like, for the submitting the, 
7 
like, the PPP loans online.   
8 
MR. RECAMIER:  I mean, I worked on the 
9 
tax.  
10 
MR. LIDSKY:  I'm sorry?  
11 
MR. RECAMIER:  I was making the tax.  
12 
MR. LIDSKY:  Oh, the documents?  
13 
MR. RECAMIER:  Yeah.  
14 
MR. LIDSKY:  So, like, the state 
15 
registration record?  
16 
MR. RECAMIER:  No.  Just the tax.  
17 
MR. LIDSKY:  Or -?  Oh, the tax documents?  
18 
MR. RECAMIER:  Uh-huh. 
19 
MR. LIDSKY:  Gotcha.  So, that was kind of 
20 
your role.  And then, he --  
21 
MR. RECAMIER:  Mm-hmm.  
22 
MR. LIDSKY:  -- he would take care of 
23 
everything else.  Okay.  Did he -.  I mean, 
24 
whose idea was it to, you know, let’s do 
25 
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another one in this name?  I mean, how, just 
1 
how, or did it work?  Break down, you know, how 
2 
it -.  
3 
MR. RECAMIER:  I mean, you know, I can't, 
4 
I don’t know initially want to, I want to talk 
5 
-. 
6 
MR. LIDSKY:  Okay.  No.  That’s fine if -.  
7 
That’s fine.  We, you know, we took a bunch of 
8 
documents out.  We saw all of the, you know, a 
9 
lot of the bank statements, so, a lot of tax 
10 
forms.  There was a Chase bank statement.  
11 
MR. RECAMIER:  Okay.  
12 
MR. LIDSKY:  That has, like, Facebook wire 
13 
transfers and stuff.  I think it was used for 
14 
just kind of to show solvency from some of the 
15 
companies.   
16 
MR. RECAMIER:  Okay.  
17 
MR. LIDSKY:  Is that a document you are 
18 
familiar with?  
19 
MR. RECAMIER:  I am not sure which you are 
20 
looking at.   
21 
MR. LIDSKY:  If I showed it to you?  
22 
MR. RECAMIER:  Yeah.  
23 
MR. LIDSKY:  Might it jog a memory?  I 
24 
mean, if, would you be willing to, if I can 
25 
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find it, would you be willing to talk about 
1 
that one?  
2 
MR. RECAMIER:  Yeah.  I mean, like, if I 
3 
know what it is.  Yeah.   
4 
MR. LIDSKY:  Okay.   
5 
MR. RECAMIER:  Yeah.  
6 
MR. LIDSKY:  Let me see.  I think I’ve got 
7 
a copy of it.  Do you know - while I'm looking 
8 
for that - do you know some of his associates?  
9 
MR. RECAMIER:  No.  
10 
MR. LIDSKY:  Oh, where do I have that?  Do 
11 
you have that Chase -?  
12 
MR. JOHN:  Which one?  
13 
MR. LIDSKY:  That recycled Chase doc.  
14 
MR. JOHN:  I got it buried somewhere.  I 
15 
think it was in the zip package.  
16 
MR. LIDSKY:  That’s right.  That’s where 
17 
it was.   
18 
MR. JOHN:  Mm-hmm.   
19 
MR. LIDSKY:  Yeah.  Bear with me.  I'm 
20 
sorry, Chris.  
21 
MR. RECAMIER:  That’s fine.  
22 
MR. LIDSKY:  And Recamier.   
23 
MR. RECAMIER:  Mm-hmm.  
24 
MR. LIDSKY:  Okay.  I got it.   
25 
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MR. RECAMIER:  What?  
1 
MR. LIDSKY:  I butchered it enough times.  
2 
You asked me to just call you Chris.  I 
3 
appreciate it.  
4 
MR. RECAMIER:  Mm-hmm.   
5 
MR. LIDSKY:  I’ve got a copy right here.  
6 
Yeah.  A safe error.  John Croaks (Phonetic Sp. 
7 
*00:23:18).  John Litbow (Phonetic Sp. 
8 
*00:23:21).   
9 
MR. RECAMIER:  Mm-hmm.  
10 
MR. LIDSKY:  That’s another one.   
11 
MR. RECAMIER:  Yeah.  
12 
MR. LIDSKY:  How many were there?  
13 
MR. RECAMIER:  Hmm.  
14 
MR. LIDSKY:  And while you are thinking, 
15 
this is another area where we discussed --  
16 
MR. RECAMIER:  Mm-hmm.  
17 
MR. LIDSKY:  -- you know, it is not always 
18 
talking about other, you know, helping, 
19 
substantial assistance can come in many forms.  
20 
In this case, we have a number of victims, 
21 
obviously, whose identity has been stolen, and 
22 
making them whole again, you know, helping them 
23 
as victims, helping us identify them, and --  
24 
MR. RECAMIER:  Mm-hmm.  
25 
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MR. LIDSKY:  -- and getting them back to 
1 
normal might also be a way where you could sort 
2 
of give back.   
3 
MR. RECAMIER:  Mm-hmm.  
4 
MR. LIDSKY:  And so, that is another 
5 
opportunity that we discussed.  There was also 
6 
some documents that looked a bit confusing on 
7 
their face, and helping put context to some of 
8 
those, and what they mean, that might be 
9 
another way, as well.  Hmm.  Oh, so, while I am 
10 
looking, do you know how many there were?  Or 
11 
did you even keep track?  
12 
MR. RECAMIER:  I can't -.  I mean, like, 
13 
maybe 15, 20.  
14 
MR. LIDSKY:  Okay.  So, we got most of 
15 
them, I guess.  Is there, like, a master list 
16 
of them somewhere?  Does he keep a list of kind 
17 
of who’s who?  
18 
MR. RECAMIER:  I mean, like, if you check 
19 
all the files, and all the computer, like --  
20 
MR. LIDSKY:  Is there --  
21 
MR. RECAMIER:  -- it is a gray computer.  
22 
It handles the phone and you have everybody on 
23 
it.   
24 
MR. LIDSKY:  Like, in, like, on the 
25 
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computer, or, like, in a file?  
1 
MR. RECAMIER:  Well, you know, like, on 
2 
the email on the computer.  Uh-huh.  
3 
MR. LIDSKY:  On the email?  
4 
MR. RECAMIER:  You have some of the 
5 
people, and on the phones, and you have the 
6 
rest of the people.   
7 
MR. LIDSKY:  Okay.  Okay.  Understood.  
8 
Thank you.  That is helpful, too.  Just helping 
9 
us kind of get through all this is also helpful 
10 
and much appreciated.  I'm sorry.  I'm some 
11 
other place here.  So, were you kind of the tax 
12 
documents specialist, and he took care of 
13 
everything else?  
14 
MR. RECAMIER:  No.  I mean, like, it was 
15 
just, like, he transacts like he wants to do, 
16 
you know?   
17 
MR. LIDSKY:  Okay.  It’s just -.  I'm 
18 
sorry.  
19 
MR. RECAMIER:  Doesn't understand exit 
20 
tax.  
21 
MR. LIDSKY:  Oh.   
22 
MR. RECAMIER:  So.  
23 
MR. LIDSKY:  Gotcha.  So, there was one 
24 
bank.  I think it was M&T (Phonetic Sp. 
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*00:25:54).  
1 
MR. RECAMIER:  Mm-hmm.   
2 
MR. LIDSKY:  Where you all, I mean, are 
3 
you, I mean, I believe you went in.  I think he 
4 
got -.  It was, you all - I say you and Mr. 
5 
Ilori - I assume it’s all of this is you and 
6 
Mr. Ilori.  Were any of these just you, or just 
7 
him?   
8 
MR. RECAMIER:  Yeah.  Like, I went just by 
9 
myself at M&T.  
10 
MR. LIDSKY:  But he knew --  
11 
MR. RECAMIER:  Yeah.  
12 
MR. LIDSKY:  -- that you were going, 
13 
right?   
14 
MR. RECAMIER:  Mm-hmm.  
15 
MR. LIDSKY:  I mean, he asked you to go, I 
16 
assume?   
17 
MR. RECAMIER:  Yeah.  
18 
MR. LIDSKY:  So, there was one, I think it 
19 
was M&T for, was it four million, or two 
20 
million?  There was a couple that were pretty 
21 
big.  That got denied.   
22 
MR. RECAMIER:  I mean, that, I don't know.   
23 
MR. LIDSKY:  So, one of them, like, one of 
24 
the tax forms had, like, Wite-Out and 
25 
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corrections.  
1 
MR. RECAMIER:  Mm-hmm.  
2 
MR. LIDSKY:  Was that things that -?  
3 
MR. RECAMIER:  That’s not me. 
4 
MR. LIDSKY:  That doesn't sound like your 
5 
work?  
6 
MR. RECAMIER:  No.   
7 
MR. LIDSKY:  So, when you say he didn't 
8 
know what he was doing, like, is that kind of 
9 
an example?  I don’t have those, and for the 
10 
life of me, I can't find this Chase statement.  
11 
Let me see here.  Ah, I got it.  Okay.  So, can 
12 
you see that?   
13 
MR. RECAMIER:  Okay.   
14 
MR. LIDSKY:  So, this statement, we have 
15 
seen this a couple of different times.  The 
16 
name changes and the address changes.   
17 
MR. RECAMIER:  Okay. 
18 
MR. LIDSKY:  The account number can 
19 
change.  
20 
MR. RECAMIER:  Mm-hmm.  
21 
MR. LIDSKY:  But a lot of these 
22 
transactions, I know it is small.   
23 
MR. RECAMIER:  Can I -?  
24 
MR. LIDSKY:  Yes.  Okay.  But, like, like, 
25 
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these dollar amounts --  
1 
MR. RECAMIER:  Uh-huh.  
2 
MR. LIDSKY:  -- like, those are the same.  
3 
It’s, like, you can - when you hold them side 
4 
by side by side - you can tell it’s kind of the 
5 
same statement, just customized --  
6 
MR. RECAMIER:  Mm-hmm.  
7 
MR. LIDSKY:  -- for a company name.  Was 
8 
this something you were doing, or he was doing?  
9 
MR. RECAMIER:  No.  That, he was doing.   
10 
MR. LIDSKY:  This is his work?  
11 
MR. RECAMIER:  Yeah.  
12 
MR. LIDSKY:  Is this a real statement?  
13 
Because, like, some of these, there is a, like, 
14 
there is an app company in here, out in Great 
15 
Neck.  Like, is he buying these statements?  
16 
Like, on a dark web, as well?  
17 
MR. RECAMIER:  I think so.  
18 
MR. LIDSKY:  So, this was, like, a real 
19 
statement, it’s just kind of changed to make it 
20 
look like, you know, he is doing a million 
21 
dollars a month?  
22 
MR. RECAMIER:  Mm-hmm.  
23 
MR. LIDSKY:  Okay.  So, we were 
24 
understanding that correctly.  And you know 
25 
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that because you saw him do it, or you showed 
1 
him to do it, or -?  
2 
MR. RECAMIER:  No, because then you --  
3 
MR. LIDSKY:  It’s not that I don’t believe 
4 
you --  
5 
MR. RECAMIER:  -- we talked about it.   
6 
MR. LIDSKY:  -- but --  
7 
MR. RECAMIER:  No.  We just talked about 
8 
it.       
9 
MR. LIDSKY:  -- okay.  So, does he have 
10 
the actual, the real Chase statement, the one 
11 
that started this, and he just scans it in, and 
12 
-?  
13 
MR. RECAMIER:  I don’t think he has the 
14 
first one.  But --  
15 
MR. LIDSKY:  It’s gone?  
16 
MR. RECAMIER:  -- mm-hmm. 
17 
MR. LIDSKY:  Do you know what software he 
18 
uses?  He uses, like, Photoshop, or -?  
19 
MR. RECAMIER:  Yeah.   
20 
MR. LIDSKY:  Is that exactly what he uses?  
21 
MR. RECAMIER:  Mm-hmm.  
22 
MR. LIDSKY:  Does he do it on a Mac?  
23 
MR. RECAMIER:  I mean, you would have to 
24 
ask him.   
25 
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MR. LIDSKY:  Okay.  But you said the Mac 
1 
is a computer that he uses.  Do you ever use 
2 
it?  Do you have the logins for it?  
3 
MR. RECAMIER:  Yeah.   
4 
MR. LIDSKY:  Okay.   So, you, it’s shared, 
5 
but do you each have a folder, or is it just 
6 
one account name?          
7 
MR. RECAMIER:  Just one account.  
8 
MR. LIDSKY:  Okay.  So - okay - so, we 
9 
need some help, you know, knowing whose files 
10 
are whose.  Is there one computer that is more 
11 
--  
12 
MR. RECAMIER:  I know that five --  
13 
MR. LIDSKY:  -- (Indiscernible *00:29:39).  
14 
MR. RECAMIER:  -- I mean, like, I mean, 
15 
like, I access the computer to use Photoshop.  
16 
That’s it.   
17 
MR. LIDSKY:  You use for?  
18 
MR. RECAMIER:  I use Photoshop on it a 
19 
couple times.  
20 
MR. LIDSKY:  Oh, to shop.   
21 
MR. RECAMIER:  Mm-hmm.  
22 
MR. LIDSKY:  Oh, gotcha.  So --  
23 
MR. RECAMIER:  Yeah.  
24 
MR. LIDSKY:  -- you are just using it for 
25 
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--  
1 
MR. RECAMIER:  Photoshop.  
2 
MR. LIDSKY:  -- oh, Photoshop.  Photoshop.   
3 
MR. RECAMIER:  Yeah.  
4 
MR. LIDSKY:  Gotcha.  
5 
MR. RECAMIER:  A couple times.  
6 
MR. LIDSKY:  And that’s for the --  
7 
MR. RECAMIER:  Yes.  
8 
MR. LIDSKY:  -- for the tax forms?  
9 
MR. RECAMIER:  Yeah.   
10 
MR. LIDSKY:  Gotcha.  That makes sense. 
11 
MR. RECAMIER:  Yeah.    
12 
MR. LIDSKY:  It’s so easy these days.   
13 
MR. RECAMIER:  I mean, the tax form, you 
14 
download them on the, online.   
15 
MR. LIDSKY:  Yeah.  
16 
MR. RECAMIER:  But the IRS that causing it 
17 
--  
18 
MR. LIDSKY:  Right.  
19 
MR. RECAMIER:  -- I mean, the text for him 
20 
don’t say no there online.    
21 
MR. LIDSKY:  And you fill them in.   
22 
MR. RECAMIER:  Yeah.   
23 
MR. LIDSKY:  The tax ID numbers?  Were 
24 
those just made up?   
25 
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MR. RECAMIER:  Hmm.  Like the EIN?  
1 
MR. LIDSKY:  The EINs.  Yeah.   
2 
MR. RECAMIER:  Those are actually, I mean, 
3 
I mean, no, the EIN are good.   
4 
MR. LIDSKY:  Really?   
5 
MR. RECAMIER:  Yeah.  
6 
MR. LIDSKY:  Like, but from somebody 
7 
else’s -?  I mean, you guys, you didn't get 
8 
them, or, you, he, or you?  They’re not real 
9 
for you.  
10 
MR. RECAMIER:  Yeah.  
11 
MR. LIDSKY:  Or are they?  
12 
MR. RECAMIER:  No.  They are the real EIN.  
13 
MR. LIDSKY:  Huh.  So, some of the, some 
14 
of the companies, like, maybe Appsensible.  
15 
MR. RECAMIER:  Mm-hmm.  
16 
MR. LIDSKY:  They show up in the state 
17 
registry, going back to 2014 or 2015.  
18 
MR. RECAMIER:  Okay.  
19 
MR. LIDSKY:  2016.  
20 
MR. RECAMIER:  Uh-huh.  
21 
MR. LIDSKY:  How does that happen?  Are 
22 
they real?  Were they real LLCs filed with the 
23 
state?  
24 
MR. RECAMIER:  Yeah.   
25 
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MR. LIDSKY:  So, but seven years ago?  
1 
MR. RECAMIER:  That has nothing to do with 
2 
this.   
3 
MR. LIDSKY:  Oh, so, somebody else did it?  
4 
MR. RECAMIER:  Uh-huh.   
5 
MR. LIDSKY:  Oh.  Okay.  Because that’s 
6 
why I couldn’t square.  I don't not understand 
7 
what --  
8 
MR. RECAMIER:  Uh-huh. 
9 
MR. LIDSKY:  -- you guys planned this 
10 
seven years back.  
11 
MR. RECAMIER:  No.  
12 
MR. LIDSKY:  You didn't even know each 
13 
other.   
14 
MR. RECAMIER:  We didn't know each other.  
15 
MR. LIDSKY:  This was another thing that 
16 
came up in our conversations.  So, you spent 
17 
some time in Rikers.   
18 
MR. RECAMIER:  Yeah.  
19 
MR. LIDSKY:  On the other case that you 
20 
have in the city, and that’s where you met -- 
21 
MR. RECAMIER:  Mm-hmm. 
22 
MR. LIDSKY:  -- Mr. Ilori? 
23 
MR. RECAMIER:  Yeah.   
24 
MR. LIDSKY:  And I imagine you guys just 
25 
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became friends, and --  
1 
MR. RECAMIER:  Yeah.  
2 
MR. LIDSKY:  -- did he just want to keep 
3 
in touch after you got out, or did you have 
4 
common interests?  
5 
MR. RECAMIER:  Well, we talked about a few 
6 
things.  Yeah.  
7 
MR. LIDSKY:  Okay.  Yeah.  No.  I’ve seen 
8 
that before.  I saw that in common.  So, how do 
9 
you find existing companies?   
10 
MR. RECAMIER:  I have no idea.  
11 
MR. LIDSKY:  Is that what he -?  
12 
MR. RECAMIER:  Yeah.  
13 
MR. LIDSKY:  That’s his role.  Gotcha.  I 
14 
asked you, there was -.  We noticed, you 
15 
mentioned, do we have a red car?  I forget how 
16 
you put it.  But you didn't seem too surprised 
17 
to see us.   
18 
MR. RECAMIER:  Mm-hmm.  
19 
MR. LIDSKY:  And you asked about, do we 
20 
have a red car?  So, we, you know, we know each 
21 
other.  You know we were out there.  We know 
22 
you know we were there.  We know you saw us 
23 
from time to time.  I did ask you - and again, 
24 
this is just for the record - you know, we saw, 
25 
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and you, and Mr. Ilori come out of the 
1 
apartment, and sprint up Perv Street (Phonetic 
2 
Sp. *00:32:52).  
3 
MR. RECAMIER:  Mm-hmm.  
4 
MR. LIDSKY:  The other day.  And so, I 
5 
just asked you what was that about, and you 
6 
said, you said you guys were, you were late.  
7 
He was late.   
8 
MR. RECAMIER:  Mm-hmm.  
9 
MR. LIDSKY:  And you had something in his 
10 
car.   
11 
MR. RECAMIER:  Yeah.  
12 
MR. LIDSKY:  So, you were running after 
13 
him to get what you need out of his car, and he 
14 
was running to his car.  So that, that makes 
15 
sense.  We were just, you know, curious about 
16 
that.  How long have you been doing this with 
17 
him?  I mean, when did it start?  You both got 
18 
out.   
19 
MR. RECAMIER:  I think some time last 
20 
year.   
21 
MR. LIDSKY:  Now, he was arrested and 
22 
charged last --  
23 
MR. RECAMIER:  Yeah.  
24 
MR. LIDSKY:  -- January, or March.   
25 
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MR. RECAMIER:  Yeah.  He was charged.   
1 
MR. LIDSKY:  He was charged.  You weren’t.  
2 
MR. RECAMIER:  No.  
3 
MR. LIDSKY:  You, I mean, for, I mean, he 
4 
seems to be, you know, if - not to belittle 
5 
your position in the organization - but he is 
6 
the president and the CEO, and --  
7 
MR. RECAMIER:  Mm-hmm.  
8 
MR. LIDSKY:  -- you are the subordinate 
9 
employee.  Is that a fair characterization?  
10 
MR. RECAMIER:  Yeah.  That is fine.  
11 
MR. LIDSKY:  Is that how you see it?  
12 
MR. RECAMIER:  Yeah.  Yeah.  
13 
MR. LIDSKY:  I mean, do we have that 
14 
assessed correctly, or --  
15 
MR. RECAMIER:  Yes. 
16 
MR. LIDSKY:  -- did you -?  Okay.  So, how 
17 
is it that he keeps - everything is leading 
18 
back to him?  
19 
MR. RECAMIER:  What do you mean? 
20 
MR. LIDSKY:  Well, I mean, he was 
21 
identified in the prior case, and charged.  And 
22 
you weren’t.  But you, you know, one of the 
23 
names I mentioned to you when we met was 
24 
Christopher Millot (Phonetic Sp. *00:34:48).  
25 
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Or Donald Millot.  
1 
MR. JOHN:  Donald.  
2 
MR. LIDSKY:  Donald Millot.  
3 
(Indiscernible *00:34:52).  
4 
MR. RECAMIER:  I mean, he had mentioned 
5 
that name, actually.   
6 
MR. LIDSKY:  He did?  
7 
MR. RECAMIER:  You didn't.  
8 
MR. LIDSKY:  When we - I think I did, when 
9 
we were --  
10 
MR. RECAMIER:  Nope.  
11 
MR. LIDSKY:  -- (Indiscernible *00:34:59).  
12 
Donald Millot?  
13 
MR. RECAMIER:  Nope.  
14 
MR. LIDSKY:  I thought I did.  
15 
MR. RECAMIER:  No, you didn't.  
16 
MR. LIDSKY:  Christopher Potash (Phonetic 
17 
Sp. *00:35:03).   
18 
MR. RECAMIER:  No, you didn't.   
19 
MR. LIDSKY:  Not that one, either?  
20 
MR. RECAMIER:  Nope.  
21 
MR. LIDSKY:  Josh Hatura (Phonetic Sp. 
22 
*00:35:09)?  
23 
MR. RECAMIER:  You did.   
24 
MR. JOHN:  You recognize all those names, 
25 
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though, right?  
1 
MR. RECAMIER:  Yeah.  
2 
MR. LIDSKY:  David Dilly?  (Phonetic Sp. 
3 
*00:35:16).   
4 
MR. RECAMIER:  Mm-hmm.   
5 
MR. LIDSKY:  Thomas Hackinberry.  So, will 
6 
Donald Millot.  So, if I didn't --  
7 
MR. RECAMIER:  Mm-hmm.  
8 
MR. LIDSKY:  -- mention it, it was an 
9 
oversight on my part but I will mention it now.  
10 
So, that was one from the previous iteration.   
11 
MR. RECAMIER:  Yeah.  
12 
MR. LIDSKY:  I mean, was it just all the 
13 
same?  But how do you keep kind of avoiding 
14 
scrutiny, up until now of course, where he 
15 
keeps getting identified?  I mean -.  
16 
MR. RECAMIER:  I mean, like, if you 
17 
(Indiscernible *00:35:49), like, you know how 
18 
it happened, and it’s not exactly fair. I mean, 
19 
like, he was not doing anything wrong.  
20 
MR. LIDSKY:  Mm-hmm.  
21 
MR. RECAMIER:  And you guys came at him.  
22 
And offered him to commit crime.  And then 
23 
arrest him.  I mean, when I say you, like, it’s 
24 
not --  
25 
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MR. LIDSKY:  Yeah.  
1 
MR. RECAMIER:  -- you.   
2 
MR. LIDSKY:  Yeah, yeah.  
3 
MR. RECAMIER:  Like, it’s --  
4 
MR. LIDSKY:  The same thing.  And when I 
5 
say --  
6 
MR. RECAMIER:  -- that.  
7 
MR. LIDSKY:  -- you guys, you know -.  
8 
MR. RECAMIER:  And frankly, it’s not -.  
9 
That’s really nasty.    
10 
MR. LIDSKY:  Yeah.  That wasn’t our --  
11 
MR. RECAMIER:  That’s a (Indiscernible 
12 
*00:36:22).  And actually, there are tapes.  
13 
And I heard the tapes.  (Indiscernible 
14 
*00:36:27), like, if this guy doesn't want to 
15 
do it, and like, the guys that work with the 
16 
FBI, it’s, like, we’ll push it on him, like, 
17 
we’re going to hurt him or something, and yeah, 
18 
yeah, I mean, like --  
19 
MR. LIDSKY:  Oh. 
20 
MR. RECAMIER:  -- it’s -.  
21 
MR. LIDSKY:  I'm not - admittedly, I’ve 
22 
read the criminal complaint on that - but I am 
23 
not that intimately familiar with the details.   
24 
MR. RECAMIER:  It’s not fair.  
25 
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MR. LIDSKY:  I see what you are saying.  
1 
MR. RECAMIER:  Yeah.   
2 
MR. LIDSKY:  But anyway, you know, his --  
3 
MR. RECAMIER:  (Indiscernible *00:37:00).  
4 
MR. LIDSKY:  -- I know, you know, we 
5 
knocked on your door, and we, you know, you are 
6 
here with us, we are talking to you.  His role 
7 
in this is not lost on us.  It seems to be, you 
8 
know, basically the same type of activity.  
9 
Just redirected at the PPP loans.  I realize --  
10 
MR. RECAMIER:  Mm-hmm.  
11 
MR. LIDSKY:  -- last year, when he was 
12 
arrested and charged, PPP loans didn't exist.  
13 
MR. RECAMIER:  Yeah.  
14 
MR. LIDSKY:  That was prior to the 
15 
pandemic, or just the beginning.  I mean, the 
16 
PPP loans are admittedly pretty easy target.  I 
17 
guess.  Low hanging fruit.  I mean, you know, 
18 
they were throwing money in the air.  Can I ask 
19 
whose idea was it to target the PPP loans?  Did 
20 
they just -?  Was it just easy, appealing?   
21 
MR. RECAMIER:  I am not sure, actually.   
22 
MR. LIDSKY:  I'm just curious, like, if 
23 
somebody researched the program, got an 
24 
understanding --  
25 
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MR. RECAMIER:  Nope.  
1 
MR. LIDSKY:  -- of how it works.  A number 
2 
of loans that I believe you guys, you and Mr. 
3 
Ilori, submitted, the applications that you 
4 
submitted were denied.  
5 
MR. RECAMIER:  Mm-hmm.  
6 
MR. LIDSKY:  Did you all learn --  
7 
MR. RECAMIER:  Mm-hmm.  
8 
MR. LIDSKY:  -- like, when it was denied?  
9 
Did you kind of learn from it, and try to do it 
10 
better on the next one, or was it just, let’s 
11 
just try this, let’s just try this, and -?  
12 
MR. RECAMIER:  Well, we, I mean -.  Yeah.  
13 
I think, like, I don’t want to answer it.  
14 
MR. LIDSKY:  Fair enough.  Kerwin, do you 
15 
have any points of curiosity?  If I could come 
16 
back to one more.  In the car - I'm sorry - in 
17 
the car, circling back to the IDs and credit 
18 
cards.  Yeah.  There were no IDs.  No credit  
19 
cards in the place --  
20 
MR. RECAMIER:  Mm-hmm.  
21 
MR. LIDSKY:  -- in any of the names that 
22 
we know of.  I asked you, you know, do you know 
23 
if he keeps some, like, we have covered that.  
24 
I asked you if you know where he keeps them, 
25 
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and you thought he kept them in his car?  
1 
MR. RECAMIER:  Yeah.   
2 
MR. LIDSKY:  So, he always has them all 
3 
with him?  Does he -.  He doesn't leave them at 
4 
home.  He doesn't want either, does he -?  
5 
MR. RECAMIER:  I mean, I don’t go to his 
6 
house.  So --  
7 
MR. LIDSKY:  You never --  
8 
MR. RECAMIER:  -- I don't know.  
9 
MR. LIDSKY:  -- do you know where he 
10 
lives?  
11 
MR. RECAMIER:  Yeah.  But have I been 
12 
inside, I mean, like --  
13 
MR. LIDSKY:  Gotcha.  Specifically.  
14 
MR. RECAMIER:  -- met his wife, his kids.  
15 
So.  
16 
MR. LIDSKY:  Oh.  Okay.  Yeah.  So, like, 
17 
he took you there, just said, I’ll be right 
18 
out, then he ran inside, or did he just, you 
19 
know where he lives, just generally? 
20 
MR. RECAMIER:  I mean, I know the 
21 
(Indiscernible *00:39:54), like, but nothing.  
22 
MR. LIDSKY:  Gotcha.  So, he keeps all the 
23 
IDs and credit cards with him, all the time?  
24 
Just, he never knows when he might need one, or 
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-?  
1 
MR. RECAMIER:  I have -.  You know, you 
2 
would have to ask him. 
3 
MR. LIDSKY:  Ask him.   
4 
MR. RECAMIER:  Yeah.  
5 
MR. LIDSKY:  Okay.   
6 
MR. RECAMIER:  Yeah. 
7 
MR. LIDSKY:  Understood.  I'm sorry.  
8 
That’s all I wanted to --  
9 
MR. JOHN:  That’s fine. 
10 
MR. LIDSKY:  -- circle back with. 
11 
MR. JOHN:  How do you and him communicate?   
12 
MR. RECAMIER:  What do you mean?  
13 
MR. JOHN:  You and him talk.  When you are 
14 
not together.   
15 
MR. LIDSKY:  Did you want this one?  
16 
MR. RECAMIER:  No.   
17 
MR. LIDSKY:  Thank you.   
18 
MR. RECAMIER:  Phone.  
19 
MR. JOHN:  By phone?  
20 
MR. RECAMIER:  Yeah.  
21 
MR. JOHN:  And does he call you or do you 
22 
call him?  Does he call you?  
23 
MR. RECAMIER:  Well, we call each other.  
24 
MR. JOHN:  You call each other.  Okay.  
25 
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And do you call from your own phone, or phones 
1 
under he --  
2 
MR. RECAMIER:  Yeah.  From an app. 
3 
MR. JOHN:  -- through an app? 
4 
MR. RECAMIER:  Yeah.  
5 
MR. JOHN:  Which app is that?  
6 
MR. RECAMIER:  Telegram.  
7 
MR. JOHN:  Telegram?  
8 
MR. RECAMIER:  Uh-huh.  
9 
MR. JOHN:  Okay.   
10 
MR. LIDSKY:  So, what phone in particular?  
11 
We’ll just start, the Jonathan Hertua (Phonetic 
12 
Sp. *00:41:02) -- 
13 
MR. RECAMIER:  Uh-huh.  
14 
MR. LIDSKY:  -- ID seemed to kind of be 
15 
the main one.  
16 
MR. RECAMIER:  Okay.  
17 
MR. LIDSKY:  That you guys use.  I don't 
18 
know.   
19 
MR. RECAMIER:  Yeah.  
20 
MR. LIDSKY:  I think that’s just 
21 
subjective.   
22 
MR. RECAMIER:  Yeah.  
23 
MR. LIDSKY:  But so, there was a phone 
24 
assigned to that.  Who has that phone?  Is it 
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in the pile that we found in the apartment?  Or 
1 
does he carry that one around with him?  
2 
MR. RECAMIER:  I don’t know.  
3 
MR. LIDSKY:  Oh, you don’t know?  Does he 
4 
--  
5 
MR. RECAMIER:  (Indiscernible *00:41:27) I 
6 
think.  
7 
MR. LIDSKY:  -- are all those phones his, 
8 
or -?  
9 
MR. RECAMIER:  Yeah.  
10 
MR. LIDSKY:  Do you, but you have access 
11 
to them?  
12 
MR. RECAMIER:  Yeah.  
13 
MR. LIDSKY:  So, shared?  
14 
MR. RECAMIER:  Mm-hmm.  
15 
MR. LIDSKY:  And they are just used for, I 
16 
would imagine, to answer questions like the 
17 
bank calls.  
18 
MR. RECAMIER:  Yeah.  (Indiscernible 
19 
*00:41:46).  
20 
MR. LIDSKY:  So, for their - associated 
21 
with an application.  Who decided on Telegram?  
22 
MR. RECAMIER:  I have no idea.  
23 
MR. LIDSKY:  So, the apartment was rented, 
24 
the 44 - when I say the apartment - 4441 Perv 
25 
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Street (Phonetic Sp. *00:42:14), Apartment 
1 
1805, where we met this evening.  
2 
MR. RECAMIER:  Mm-hmm.  
3 
MR. LIDSKY:  When was that rented?  
4 
MR. RECAMIER:  I'm not sure.  I think, 
5 
like, in May.  
6 
MR. LIDSKY:  Yeah.  He has a key.   
7 
MR. RECAMIER:  Mm-hmm. 
8 
MR. LIDSKY:  To the apartment.  He has 
9 
some clothes stored in a closet in that 
10 
apartment?  
11 
MR. RECAMIER:  Mm-hmm.  
12 
MR. LIDSKY:  He has been in that apartment 
13 
before?  
14 
MR. RECAMIER:  Mm-hmm.  
15 
MR. LIDSKY:  Yeah.  I realize it’s, some 
16 
of these questions are fairly straightforward.  
17 
He was in that apartment today?  
18 
MR. RECAMIER:  Yeah. 
19 
MR. LIDSKY:  About how many times have you 
20 
seen him in that apartment?  
21 
MR. RECAMIER:  I don’t know.   
22 
MR. LIDSKY:  A dozen?  Hundreds?  
23 
MR. RECAMIER:  I don't know.  
24 
MR. LIDSKY:  You don’t know.  Okay.  He 
25 
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uses all of the electronic devices in that 
1 
apartment?  
2 
MR. RECAMIER:  I mean, you would have to 
3 
ask him. 
4 
MR. LIDSKY:  Okay.    
5 
MR. RECAMIER:  I don't know that.   
6 
MR. LIDSKY:  Fair enough.   
7 
MR. RECAMIER:  I mean, frankly, if you 
8 
have a question about, like, the night that 
9 
(Indiscernible *00:43:32) victim, that’s fine.   
10 
MR. LIDSKY:  Okay.  
11 
MR. RECAMIER:  But I mean, I don’t want to 
12 
talk about (Indiscernible *00:43:36).  
13 
MR. LIDSKY:  Okay.  
14 
MR. RECAMIER:  I mean, that’s -.  
15 
MR. LIDSKY:  Gotcha.   
16 
MR. JOHN:  About - I'm sorry - about what?  
17 
MR. LIDSKY:  Ilori.   
18 
MR. JOHN:  Oh, okay.  
19 
MR. LIDSKY:  Okay.  Understood.  That’s 
20 
helpful.  Yeah.  Well, I mean, if -.  I mean, 
21 
you mentioned the devices have the names of all 
22 
of the victims.   
23 
MR. RECAMIER:  Yeah.  
24 
MR. LIDSKY:  You know, there was some 
25 
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paperwork with a couple of names on them.  
1 
MR. RECAMIER:  Mm-hmm.  
2 
MR. LIDSKY:  That I admittedly said we 
3 
were unfamiliar with these.  Yeah.  If you are 
4 
able to help us, if there is a master list, or 
5 
a key, you said, on the devices, if you are 
6 
able to help us identify them, so we can notify 
7 
them, and, you know, help them with their 
8 
credit repair, that would certainly be, you 
9 
know, welcome news for us.  Getting into the 
10 
devices, it would be an issue, potentially.  
11 
Are there passwords on the computers?  
12 
MR. RECAMIER:  Yeah.    
13 
MR. LIDSKY:  Do you know the passwords to 
14 
the computers?  
15 
MR. RECAMIER:  Yes.  
16 
MR. LIDSKY:  Are they encrypted?  
17 
MR. RECAMIER:  Nope.  
18 
MR. LIDSKY:  Okay.  Are there passwords to 
19 
the phones?  
20 
MR. RECAMIER:  Yes.  
21 
MR. LIDSKY:  Do you know the passwords to 
22 
the phones?  
23 
MR. RECAMIER:  Yes.   
24 
MR. LIDSKY:  Would you be willing to share 
25 
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with us the passwords to the phones, for the 
1 
purpose of getting the victim information off, 
2 
so that we could start helping the victims?  
3 
MR. RECAMIER:  I would want to think of 
4 
it, but yeah.  I mean, why not?  
5 
MR. LIDSKY:  Okay.  Would you be willing 
6 
to write it down for us this evening?   
7 
MR. RECAMIER:  Not this evening.  No.  
8 
MR. LIDSKY:  Okay.   
9 
MR. RECAMIER:  I think, like, at this 
10 
point, like, I would want to think of it.   
11 
MR. LIDSKY:  Okay.  
12 
MR. RECAMIER:  A little bit more.  
13 
MR. LIDSKY:  Okay.  Not a problem.  We 
14 
would certainly welcome the help in identifying 
15 
the victims.  Without asking you a question, 
16 
you know, about Mr. Ilori, but one that kind of 
17 
involves you both.  So, are you aware of all of 
18 
the identities that your likeness, your face, 
19 
was used on, or did he have your picture and 
20 
just make IDs that you were unaware of?  
21 
MR. RECAMIER:  No.  I don't think so.  
22 
MR. LIDSKY:  Okay.  So, you are aware of 
23 
all of the ones where your --  
24 
MR. RECAMIER:  Yeah.  
25 
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MR. LIDSKY:  -- okay.  There is some where 
1 
your face looks a little different.   
2 
MR. RECAMIER:  Okay.  
3 
MR. LIDSKY:  Was it, like, stretched?  Or 
4 
was that just -?  
5 
MR. RECAMIER:  Like, which one?  
6 
MR. LIDSKY:  Let me pull up -.  This looks 
7 
like it.  I want to say -.  So, do you 
8 
recognize the name Christopher Potash?  
9 
MR. RECAMIER:  Mm-hmm.  
10 
MR. LIDSKY:  Potash.  I thought that 
11 
picture was a bit different, but that was you?  
12 
I have to find that one.  Forgive me for the 
13 
delay.  While I'm looking for that, a separate 
14 
question.  Do you know where all the money 
15 
went?  So, this is another area, if you are 
16 
able to help us recover --  
17 
MR. RECAMIER:  Mm-hmm.  
18 
MR. LIDSKY:  -- some of the stolen money.  
19 
MR. RECAMIER:  No.  I don’t.   
20 
MR. LIDSKY:  He doesn't share that with 
21 
you?  
22 
MR. RECAMIER:  Hmm-mm.  
23 
MR. LIDSKY:  Does he control all of that?  
24 
MR. RECAMIER:  Mm-hmm.   
25 
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MR. LIDSKY:  Okay.  And so - all right - 
1 
so, you don’t have access to it, then.  You 
2 
don’t even know where it is?  
3 
MR. RECAMIER:  Hmm-mm.  
4 
MR. LIDSKY:  Does he --  
5 
MR. RECAMIER:  Mm-hmm.  
6 
MR. LIDSKY:  -- tell you, generally, about 
7 
-?  
8 
MR. RECAMIER:  I mean, I think, like, he 
9 
had some money on the stuff (Indiscernible 
10 
*00:48:08), and --  
11 
MR. LIDSKY:  Okay.  
12 
MR. RECAMIER:  -- (Indiscernible 
13 
*00:48:10).  
14 
MR. LIDSKY:  So, that’s what I was getting 
15 
at.  So --  
16 
MR. RECAMIER:  Yeah.  
17 
MR. LIDSKY:  -- but that is just a general 
18 
awareness?  
19 
MR. RECAMIER:  Yeah.  
20 
MR. JOHN:  Now, how long ago did you meet 
21 
Ilori?  
22 
MR. RECAMIER:  I think in 2019.   
23 
MR. JOHN:  ’19?  And again, you said you 
24 
met at Rikers, right?  
25 
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MR. RECAMIER:  Mm-hmm.   
1 
MR. JOHN:  Were you involved in anything 
2 
like this before?  
3 
MR. RECAMIER:  No.  
4 
MR. JOHN:  No?   
5 
MR. LIDSKY:  How did you learn how to do 
6 
it?  Were you, you know, coached, or just 
7 
learned by doing?  
8 
MR. RECAMIER:  Well, I learned when I left 
9 
Rikers.  
10 
MR. LIDSKY:  Oh, okay.   
11 
MR. JOHN:  Is there anything you can tell 
12 
us about why, you know, I know, you know, you 
13 
were asked before about what’s in this for you.  
14 
Is there anything you could tell us about what, 
15 
why do this?  Why you are doing it?  
16 
MR. RECAMIER:  Well, because I ended up, 
17 
like, in a bad situation.  
18 
MR. JOHN:  A bad situation?  
19 
MR. RECAMIER:  And I needed to make some 
20 
money, and --  
21 
MR. JOHN:  Okay.  
22 
MR. RECAMIER:  -- that’s it.  
23 
MR. JOHN:  So, you do get some money out 
24 
of this?  
25 
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MR. RECAMIER:  Mm-hmm.  
1 
MR. JOHN:  Okay.  Do you care to tell us 
2 
how much?  
3 
MR. RECAMIER:  Not that much.  I mean, 
4 
like, just enough to cover the rent, and food, 
5 
and that’s it.   
6 
MR. JOHN:  Okay.  
7 
MR. RECAMIER:  So.  
8 
MR. JOHN:  Do you know, approximately, how 
9 
much?  How much is the rent?  
10 
MR. RECAMIER:  Like, $3,000, or 38, 3100. 
11 
MR. JOHN:  A month?   
12 
MR. RECAMIER:  Yeah.  
13 
MR. JOHN:  Okay.   
14 
MR. RECAMIER:  (Indiscernible *00:49:52).   
15 
MR. LIDSKY:  Do you pay that, or he pays 
16 
that?  
17 
MR. RECAMIER:  He pays that.   
18 
MR. LIDSKY:  How does he pay?  A check?  
19 
MR. RECAMIER:  Money order.  
20 
MR. JOHN:  So, about how much do you spend 
21 
on food a month?   
22 
MR. RECAMIER:  Maybe, like, a few hundred 
23 
a week.  
24 
MR. JOHN:  Oh, okay.   
25 
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MR. LIDSKY:  I'm sorry.  I'm 
1 
(Indiscernible *00:50:21).  Do you remember the 
2 
bank Potash was with?  Was it Cross River?   
3 
MR. JOHN:  And can you (Indiscernible 
4 
*00:50:32).  I can't remember.  I can't 
5 
remember.   
6 
MR. LIDSKY:  Just a second.  So, do you 
7 
recall opening or having some role in opening 
8 
an account at Coin Base? (Phonetic Sp. 
9 
*00:51:19).   
10 
MR. RECAMIER:  No.   
11 
MR. LIDSKY:  Do you know what coin this 
12 
is?  
13 
MR. RECAMIER:  Mm-hmm.  
14 
MR. JOHN:  Did you open up any kind of 
15 
cryptocurrency accounts?  
16 
MR. RECAMIER:  No.  
17 
MR. JOHN:  No?  
18 
MR. RECAMIER:  I mean, I have one on my 
19 
phone, but I knew I used it.  
20 
MR. JOHN:  Okay.  
21 
MR. RECAMIER:  I have Conveys on my phone 
22 
(Indiscernible *00:51:52).   
23 
MR. LIDSKY:  So, if there was an account 
24 
at Coin Base, with your picture --  
25 
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MR. RECAMIER:  Mm-hmm.  
1 
MR. LIDSKY:  -- somebody else did that?  
2 
MR. RECAMIER:  Yup.  Like, if I go to a 
3 
bank, like, to open an account, I need to be 
4 
there, but --  
5 
MR. LIDSKY:  Right.  
6 
MR. RECAMIER:  -- Conveys is still online. 
7 
MR. LIDSKY:  Right.   
8 
MR. RECAMIER:  It’s different.  
9 
MR. LIDSKY:  All right.  Let’s come back 
10 
to that in a second.  I'm sorry.  I'm still 
11 
looking through it.  Getting closer, though.   
12 
MR. JOHN:  Yeah.  I can't remove it.  
13 
Gosh.   
14 
MR. LIDSKY:  Yeah.  
15 
MR. JOHN:  I don’t remember.   
16 
MR. LIDSKY:  It was -.  Is it M2 gold 
17 
jets?  Is that familiar to you?  
18 
MR. RECAMIER:  Yeah.   
19 
MR. LIDSKY:  How do you know -?   
20 
MR. JOHN:  I found it.  
21 
MR. LIDSKY:  How do you know M2 gold jets?  
22 
MR. JOHN:  Two gold jets.  
23 
MR. RECAMIER:  Man, you know why.   
24 
MR. LIDSKY:  I know.  But is it because of 
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a PPP loan account?   
1 
MR. RECAMIER:  Because I have been there.  
2 
I have accounts over there.  That’s not me.   
3 
MR. LIDSKY:  But do you have a Christopher 
4 
Potash identification that you are aware of?  
5 
Do you know the name Christopher Potash?  
6 
MR. RECAMIER:  Yeah.  We have an email.  
7 
That’s not me.  That’s not my picture.  
8 
MR. LIDSKY:  Okay.  This is one that I 
9 
thought was questionable.  So, do you see all 
10 
of the licenses?  
11 
MR. RECAMIER:  This was my picture.  Yeah.  
12 
I think so.  
13 
MR. LIDSKY:  Mm-hmm.  Do you know who this 
14 
person is?  
15 
MR. RECAMIER:  Never met him.  
16 
MR. LIDSKY:  So, there is a license with 
17 
your picture, with a Christopher Potash name, 
18 
but this isn't it?  
19 
MR. RECAMIER:  I know that is a picture of 
20 
me on his sanity, but that’s not my picture.   
21 
MR. LIDSKY:  How would you have, or he 
22 
did, well, you would have needed it, right, to 
23 
open the account?   
24 
MR. RECAMIER:  Mm-hmm.  
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MR. LIDSKY:  On M2 gold jets.   
1 
MR. RECAMIER:  There is no bank account 
2 
with Christopher Potash.   
3 
MR. LIDSKY:  It was just the loan?  
4 
MR. RECAMIER:  Okay.   
5 
MR. LIDSKY:  I was asking.  Was it just 
6 
the loan?  
7 
MR. RECAMIER:  I don’t even know if there 
8 
was a loan with his name.  
9 
MR. LIDSKY:  Okay.  But you know the name.  
10 
It’s just not one that you -?  
11 
MR. RECAMIER:  I know the name because you 
12 
found an email address for him.  
13 
MR. LIDSKY:  Ah.  
14 
MR. RECAMIER:  And that’s it.   
15 
MR. LIDSKY:  Okay. 
16 
MR. RECAMIER:  And it was an email address 
17 
with his name, the email address with his name.  
18 
MR. LIDSKY:  So, if an account was opened 
19 
at Coin Base.  So, I guess, I realize, you 
20 
know, answer this or don’t answer this, so, if 
21 
he has the licenses --  
22 
MR. RECAMIER:  Mm-hmm.  
23 
MR. LIDSKY:  -- so, this license, the John 
24 
Hertua license, are you familiar with that?  
25 
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MR. RECAMIER:  Yeah.  
1 
MR. LIDSKY:  And there is a John Hertua 
2 
license with your picture -- 
3 
MR. RECAMIER:  Mm-hmm.  
4 
MR. LIDSKY:  -- on it.  So, if he has 
5 
that, and does he have pictures of you?  Does 
6 
Ilori have just pictures of you, you know, 
7 
regular kind of pictures?  
8 
MR. RECAMIER:  I mean, I guess.  Yeah.  I 
9 
need to think of that.   
10 
MR. LIDSKY:  I mean, would he have been 
11 
able to take, you know, between the ID and a 
12 
picture of you --  
13 
MR. RECAMIER:  I mean --  
14 
MR. LIDSKY:  -- could he have opened an 
15 
account with your likeness, and John Hertua’s 
16 
name, at Coin Base, without your knowledge?  
17 
MR. RECAMIER:  Yes.  
18 
MR. LIDSKY:  Was he in a position to do 
19 
that?  
20 
MR. RECAMIER:  Yeah.  He would.   Yeah.  
21 
This picture the face is different from me.  
22 
MR. LIDSKY:  Yeah.  But do you know if he 
23 
has done from time to time, in the past?  
24 
(Indiscernible *00:56:20).  
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MR. RECAMIER:  Well, I know he has a new 
1 
account with Coin Base.  I don't know under 
2 
which name.  
3 
MR. LIDSKY:  Okay.   
4 
MR. RECAMIER:  Yeah.  
5 
MR. LIDSKY:  Okay.  So, if he used your 
6 
picture, it was not with your knowledge or 
7 
permission.  
8 
MR. RECAMIER:  No.  
9 
MR. LIDSKY:  Do you do this with anybody 
10 
else?  
11 
MR. RECAMIER:  No.  
12 
MR. LIDSKY:  So, if this took place, he is 
13 
the only one that could have done it?  
14 
MR. RECAMIER:  Mm-hmm.  
15 
MR. LIDSKY:  Okay.  That’s interesting.  
16 
That’s helpful.  Do you recognize this picture?  
17 
MR. RECAMIER:  Yeah.  That’s me.  
18 
MR. LIDSKY:  Yeah.  Do you remember why 
19 
you took that?   
20 
MR. RECAMIER:  Yeah.  
21 
MR. LIDSKY:  Here, take it.  What, is that 
22 
a selfie, or -?  
23 
MR. RECAMIER:  I have no idea.   
24 
MR. LIDSKY:  It looks like it’s a bakery 
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or something.  And it says cake over here.   
1 
MR. RECAMIER:  I’ll tell it ways is. 
2 
MR. LIDSKY:  Okay.  Yeah.  Would it be -.  
3 
Okay.  No.  That’s helpful.  Interesting.  
4 
Well, I'm surprised.  But (Indiscernible 
5 
*00:58:05).  Rental cars.  
6 
MR. RECAMIER:  Mm-hmm.  
7 
MR. LIDSKY:  I think you and he rented 
8 
cars fairly frequently.  This is another thing 
9 
we touched on briefly.  
10 
MR. RECAMIER:  Uh-huh.  
11 
MR. LIDSKY:  At the apartment.  Recently.  
12 
We saw you both in a white Jeep Grand Cherokee, 
13 
with Maryland plates, and tinted windows.  You 
14 
said the tint was already on there.  We thought 
15 
maybe you tinted it after the fact.  You, you 
16 
and he, you guys.  Not personally, necessarily.  
17 
But you said it was like that when you got the 
18 
vehicle.  Was your recollection.  Was that 
19 
correct?   
20 
MR. RECAMIER:  Uh.  
21 
MR. LIDSKY:  Do I remember that correctly, 
22 
or is that -?  
23 
MR. RECAMIER:  I mean, that has nothing to 
24 
do with the big tams like you were talking 
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about.   
1 
MR. LIDSKY:  No.  I agree.  But the cars 
2 
were rented.  They’re the same - some of the   
3 
same driver’s licenses.  
4 
MR. RECAMIER:  Mm-hmm.  
5 
MR. LIDSKY:  Whose idea -?  I mean, it was 
6 
just, let’s use rental cars?  Was that his 
7 
idea, or I don't know if that’s asking close to 
8 
him?  
9 
MR. RECAMIER:  Yeah.   
10 
MR. LIDSKY:  That’s fine.  But the - some 
11 
of the same driver’s licenses and the same 
12 
credit cards --  
13 
MR. RECAMIER:  Mm-hmm.  
14 
MR. LIDSKY:  -- tied to the accounts, with 
15 
the victims, were used to rent the cars.  
16 
MR. RECAMIER:  Yes.   
17 
MR. LIDSKY:  A number with Enterprise.  
18 
Avis.  
19 
MR. RECAMIER:  Mm-hmm.  
20 
MR. LIDSKY:  Most recently, the Jeep with 
21 
Avis that they repossessed.  But you said he 
22 
had told you he returned it.  Well, I mean, 
23 
again, we are certainly interested in learning 
24 
more about all of the things, that we have a 
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long list.  We certainly want to start 
1 
notifying them and helping them get back on 
2 
their feet, and we would like your ongoing help 
3 
with that.  I think it is an area we can agree 
4 
that would be the right thing to do, and we 
5 
can, we can all help in that regard.  You can 
6 
help us, and we can help them.   
7 
MR. RECAMIER:  Okay.  
8 
MR. LIDSKY:  Okay.  So - okay - so, Coin 
9 
Base, and any stock accounts that wasn’t yours?  
10 
MR. RECAMIER:  Yeah.  
11 
MR. LIDSKY:  Okay.  Okay.  I'm sorry.  It 
12 
sounded like you had -- 
13 
MR. JOHN:  No, well --  
14 
MR. LIDSKY:  -- a question.  
15 
MR. JOHN:  -- it is a couple of questions.  
16 
That’s a little different than where we are at 
17 
now.  Do you know anything or much about 
18 
Ilori’s current case that’s pending?   
19 
MR. RECAMIER:  I know the rough line.  
20 
Yeah.   
21 
MR. JOHN:  You know, sorry, what?  
22 
MR. RECAMIER:  Some of it.   
23 
MR. JOHN:  Some of it.  Okay.  Do you know 
24 
where things stand right now, as far as his 
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case, and what, where things are going, in the 
1 
future?  
2 
MR. RECAMIER:  Well, I believe he is 
3 
waiting for a sentencing.  
4 
MR. JOHN:  A sentencing.  Do you know 
5 
approximately when that may be?  
6 
MR. RECAMIER:  You would have to ask him.   
7 
MR. JOHN:  Okay.  But - okay - but do you 
8 
know?  You don’t have to tell me, but do you 
9 
know when that might be?  
10 
MR. RECAMIER:  You would have to ask him.  
11 
That’s not for me to answer.   
12 
MR. JOHN:  Yeah, yeah.  I don’t want to 
13 
know.  I don’t want you to answer me, but I 
14 
just want to know if you know what it is.  Do 
15 
you know -?  
16 
MR. RECAMIER:  I don’t understand what you 
17 
mean.   
18 
MR. JOHN:  Oh, okay.  No.  I don't want 
19 
you to answer it.  I just want you to let me -.  
20 
All right.  Let’s move on.  
21 
MR. RECAMIER:  Okay.  Thank you.  
22 
MR. JOHN:  So, when the sentencing 
23 
eventually comes -. 
24 
(Whereupon, the above-entitled matter went 
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off the record and back on the record).  
1 
MR. JOHN: Do you have any plans as to what 
2 
you are going to do afterwards?  Because you 
3 
mentioned before, he pays the rent.  
4 
MR. RECAMIER:  Uh-huh.  
5 
MR. JOHN: For you.  Part of the reason why 
6 
you do this is to, you know, get a little help, 
7 
financially.  Right?  With food, with the rent, 
8 
so on and so forth.  When the sentencing arise, 
9 
whatever eventually happens with that, what are 
10 
your plans to do afterwards?  
11 
MR. RECAMIER:  Well, the plan was to make 
12 
enough money to stop.  
13 
MR. JOHN: Make enough to stop.  
14 
MR. RECAMIER:  So, that was the plan.  
15 
MR. JOHN: Okay.   
16 
MR. RECAMIER:  All right.  
17 
MR. LIDSKY:  So, I'm guessing, you know, 
18 
even though, you know, eventually, it will 
19 
stop, between --  
20 
MR. RECAMIER:  Uh-huh.  
21 
MR. LIDSKY:  -- his court date, and --  
22 
MR. RECAMIER:  Yeah.  
23 
MR. LIDSKY:  -- you know, must make enough 
24 
money, are there any outstanding now?  Is there 
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an opportunity for you to help us prevent money 
1 
from being diverted to a stolen account, 
2 
basically?  Which would help us, essentially, 
3 
recover money.  Is there any -?  You guys seem 
4 
pretty active recently.  
5 
MR. RECAMIER:  Mm-hmm.  
6 
MR. LIDSKY:  Can you give us some insight 
7 
into what you were working on?  
8 
MR. RECAMIER:  Just SBA.   
9 
MR. LIDSKY:  Just -?  
10 
MR. RECAMIER:  SBA.  
11 
MR. LIDSKY:  Still more?  
12 
MR. RECAMIER:  Yeah.  
13 
MR. LIDSKY:  Didn't they stop it?  
14 
MR. RECAMIER:  They would take some 
15 
things, like, they were working on.   Like, it 
16 
is not finished yet.   
17 
MR. LIDSKY:  Okay.   Well, it is still 
18 
going on?  Like, Idol is still going on?  
19 
MR. RECAMIER:  Yeah.   
20 
MR. LIDSKY:  Okay.   So, the PPP --  
21 
MR. RECAMIER:  Uh-huh.  
22 
MR. LIDSKY:  -- has stopped -- 
23 
MR. RECAMIER:  The PPP.  
24 
MR. LIDSKY:  -- but Idol --  
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MR. RECAMIER:  Yeah.  
1 
MR. LIDSKY:  -- has continued.  All right.  
2 
That makes sense.  
3 
MR. RECAMIER:  Yeah, yeah.  
4 
MR. LIDSKY:  So, it’s just more of the 
5 
same?  
6 
MR. RECAMIER:  Yeah.  
7 
MR. LIDSKY:  Are there any outstanding?  
8 
Like, is there money coming in now?  Is there 
9 
something we could stop, and sort of, you know, 
10 
get some credit in your corner for preventing a 
11 
loss?  
12 
MR. RECAMIER:  I mean, you would have to 
13 
change the computer again.  And the email.   
14 
MR. LIDSKY:  Okay.  Okay.  
15 
MR. RECAMIER:  And I don’t believe 
16 
anything has been approved.   
17 
MR. LIDSKY:  But there are outstanding 
18 
ones.  Do you know which banks?   
19 
MR. RECAMIER:  No.  
20 
MR. LIDSKY:  Have, or is that actually 
21 
directly through SBA?   
22 
MR. RECAMIER:  That’s directly with SBA.   
23 
MR. LIDSKY:  Okay.  Do you submit those?  
24 
MR. RECAMIER:  Hmm-mm.   
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MR. LIDSKY:  By that answer, he submits 
1 
this?  
2 
MR. RECAMIER:  Somebody else does.  
3 
MR. LIDSKY:  Somebody else.  
4 
MR. RECAMIER:  Yeah.  
5 
MR. LIDSKY:  Okay.  
6 
MR. RECAMIER:  Yeah.  
7 
MR. LIDSKY:  Somebody else does.  Do all 
8 
of those emails - because for, correct me if 
9 
I'm wrong, but each identity gets its own 
10 
unique email, that --  
11 
MR. RECAMIER:  Mm-hmm.  
12 
MR. LIDSKY:  -- you know, they all seem to 
13 
be a combination of the name, you know, and a 
14 
number at Gmail.  
15 
MR. RECAMIER:  Mm-hmm.  
16 
MR. LIDSKY:  Right.  Do all of those 
17 
forward to one address, or do you check that 
18 
many different email addresses?  
19 
MR. RECAMIER:  No.  They don’t converge.  
20 
MR. LIDSKY:  They don’t converge.  Okay.  
21 
So, this is what you guys do all day.  This is 
22 
why --  
23 
MR. RECAMIER:  Yeah.  
24 
MR. LIDSKY:  -- I mean, (Indiscernible 
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*00:03:16).  
1 
MR. RECAMIER:  (Indiscernible *00:03:17) 
2 
there’s not that many.  So. 
3 
MR. LIDSKY:  Gotcha.   
4 
MR. JOHN: So, who does what?  Who does 
5 
what?  So, you opened the accounts?  
6 
MR. RECAMIER:  Mm-hmm.  
7 
MR. LIDSKY:  For the banks.  You do the, 
8 
you do the tax documents for the loans, right?  
9 
MR. RECAMIER:  Mm-hmm.  
10 
MR. JOHN:  What else do you handle?  
11 
MR. RECAMIER:  That’s it.  
12 
MR. JOHN:  That’s it?   
13 
MR. RECAMIER:  Yeah.  
14 
MR. JOHN:  Who gets the ID?  
15 
MR. RECAMIER:  I don't.  
16 
MR. JOHN:  You don’t.  All right.  Well, 
17 
what about the phones?  
18 
MR. RECAMIER:  I don’t.  
19 
MR. JOHN:  And the email accounts?  
20 
MR. RECAMIER:  Sometimes, I open some 
21 
email accounts.  
22 
MR. JOHN:  Sometimes some email accounts, 
23 
you open.  All right.   
24 
MR. LIDSKY:  How do you know which ones to 
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open?  Do you -?  
1 
MR. RECAMIER:  Somebody else --  
2 
MR. LIDSKY:  Somebody else --  
3 
MR. RECAMIER:  -- tells me.  
4 
MR. LIDSKY:  -- okay.  Somebody else tells 
5 
you.  I'm sorry for this. 
6 
MR. JOHN:  No.  That’s - go ahead - 
7 
that’s, yeah, that’s all I have.  
8 
MR. LIDSKY:  How many -?  Yeah.  How many 
9 
phones total are out there?   
10 
MR. RECAMIER:  Not that many.  Again, most 
11 
of them were in my apartment.  
12 
MR. LIDSKY:  Okay.  Are those phones all 
13 
still active, and used on a -?  
14 
MR. RECAMIER:  No.  
15 
MR. LIDSKY:  Are those all done?  They are 
16 
already closed out?  
17 
MR. RECAMIER:  Yeah.  
18 
MR. LIDSKY:  Okay.  But they still have 
19 
some helpful information about the victims on 
20 
them?  
21 
MR. RECAMIER:  Yeah.  And then, because it 
22 
work with WiFi, and the apps. 
23 
MR. LIDSKY:  Oh.   
24 
MR. RECAMIER:  So.  
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MR. LIDSKY:  Right.  One of the other 
1 
things, just, you know, it’s late, you’ve been 
2 
super helpful, and we certainly appreciate your 
3 
patience with the process and indulging us.  
4 
One of the other things I mentioned to you, at 
5 
the apartment, just to reiterate it.  You know 
6 
numbers.  I assume you know his number.  If you 
7 
do, you do.  If you don’t, you don’t.  But, you 
8 
know, you will have an opportunity, obviously, 
9 
to make some calls.  I both, you know, urge you 
10 
and advise you, please do not contact him.  
11 
This is obviously an ongoing investigation.  
12 
You have your piece of it.  He has his.  Or 
13 
others have theirs.  Please don’t.  If you do, 
14 
we will find out, you could be in - and I know 
15 
you said you acknowledge this, and you have no 
16 
plans to do so - but you could be charged with 
17 
obstruction.  There is no good that could come 
18 
out of it.   
19 
MR. RECAMIER:  No.  It was (Indiscernible 
20 
*00:06:04).   
21 
MR. LIDSKY:  Okay.  I was just, I just 
22 
throw it out as a reminder.   
23 
MR. RECAMIER:  Mm-hmm.  
24 
MR. LIDSKY:  It would be, it would set you 
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back.  
1 
MR. RECAMIER:  Yeah.   
2 
MR. LIDSKY:  At this point.  There is no 
3 
need.  So, I appreciate your candor in that.  I 
4 
appreciate, you know, you have been, you know, 
5 
pleasant.  I appreciate you understanding this 
6 
is professional.  You know, you have been a 
7 
gentleman.  I sat, also at the apartment, that 
8 
if you continue to act like a gentleman, we 
9 
will treat you like a gentleman.  You know, we 
10 
cuffed you in the front, or for your comfort, 
11 
because of that, you are, I mean, you have been 
12 
nothing but, you know, cooperative, and we 
13 
appreciate that.  And of course, the cuffs are 
14 
off now.  We did give you a bottle of water.  
15 
MR. RECAMIER:  Thank you.  
16 
MR. LIDSKY:  Of course.  
17 
MR. JOHN:  Mm-hmm. 
18 
MR. LIDSKY:  We did give you a bottle of 
19 
water.  We have to make sure that we report 
20 
anything we give you, we didn't give you that 
21 
in order for you to talk to us.  It’s just been 
22 
a long day, and --  
23 
MR. RECAMIER:  Mm-hmm.  
24 
MR. LIDSKY:  -- you were thirsty, too.  
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So, unless Kerwin has got any more questions --  
1 
MR. JOHN:  No.  
2 
MR. LIDSKY:  -- let’s find out - I know 
3 
this has been quite a night for you - we will 
4 
find out what the best course is for the 
5 
remainder of the evening.   
6 
MR. RECAMIER:  Mm-hmm.  
7 
MR. LIDSKY:  And then, in the car, we 
8 
discussed, too, what the process is tomorrow 
9 
morning.  You will have your initial appearance 
10 
before a federal magistrate judge.  You will 
11 
meet with pre-trial services.  They will ask 
12 
you a number of questions.  We also, too, 
13 
discussed you are not sick, you are not feeling 
14 
symptomatic.  You have been vaccinated.  In 
15 
fact --  
16 
MR. RECAMIER:  Mm-hmm.  
17 
MR. LIDSKY:  -- we found, in your pocket 
18 
was your vaccination card.  
19 
MR. RECAMIER:  Yeah.  
20 
MR. LIDSKY:  And your true name.  So, you 
21 
know, good on you for that.  We are also 
22 
vaccinated, I will say.  I don’t speak for 
23 
other people in that regard.  So, that’s it.  
24 
So, let us find out what the next step is for 
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this evening.  
1 
MR. RECAMIER:  Okay.  
2 
MR. LIDSKY:  I know it’s late.  I thank 
3 
you for your patience.  And we will, we will, 
4 
we will get moving.   
5 
MR. RECAMIER:  Okay.  
6 
MR. JOHN:  Okay. 
7 
MR. LIDSKY:  All right.  I don't know how 
8 
we turn things off.   
9 
MR. JOHN:  All right.  Well, the time now 
10 
is approximately 2:20. 
11 
MR. LIDSKY:  I guess --  
12 
MR. JOHN:  Oh. 
13 
MR. LIDSKY:  -- just for that, you know, 
14 
we have been asking you a lot of questions.  
15 
You have certainly been patient, and indulged 
16 
us with answers.  Do you have any questions of 
17 
us?  Is there anything we can help clarify?  Is 
18 
there more to this that --  
19 
MR. RECAMIER:  No.  
20 
MR. LIDSKY:  -- we should know about, that 
21 
might help us frame it in a way -- 
22 
MR. RECAMIER:  No.  
23 
MR. LIDSKY:  -- more accurately?  
24 
MR. RECAMIER:  No.  I mean, when --  
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MR. LIDSKY:  Okay.  
1 
MR. RECAMIER:  -- when you came to my 
2 
unit, we didn't, you know, pretty simple. 
3 
MR. LIDSKY:  Yeah.  Yeah.  It is.   
4 
MR. RECAMIER:  I mean, it is not brain 
5 
surgery.  It’s, like, okay.   
6 
MR. LIDSKY:  No.  
7 
MR. RECAMIER:  I mean -.  
8 
MR. LIDSKY:  You guys were pretty good.   
9 
MR. RECAMIER:  Well, not good enough.  
10 
MR. LIDSKY:  Not good enough.  You know, 
11 
we had a heck of a time, you know, finding you, 
12 
and figuring out who you were.  
13 
MR. RECAMIER:  Mm-hmm.  
14 
MR. LIDSKY:  You know, it’s to your 
15 
credit.  But yeah, you are right.  And then, 
16 
you know, I think one of the other things, too, 
17 
we mentioned, you know, you knew this day was 
18 
probably coming.  It was a bit of an 
19 
inevitability.  So, yeah.  It is pretty 
20 
straightforward.  Okay.  With that, I will let 
21 
Kerwin officially adjourn us.   
22 
MR. JOHN:  The time now is approximately 
23 
2:21 a.m.  And we are concluding this 
24 
interview.       
25 
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CERTIFICATE 
1 
 
I hereby certify that the foregoing pages 
2 
represent an accurate transcript of the 
3 
electronic sound recording of the proceedings 
4 
before the Department of Justice, Office of the 
5 
Inspector General in the matter of: 
6 
 
7 
Interview of CHRIS RECAMIER 
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9 
 
10 
 
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Brianna Rose Burton, Transcriber 
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