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NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings as to Ahmed M Sary… — USA v. Ahmed Sary - Ahmed M Sary (Dkt. 28)
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The official transcript of a detention review hearing on May 9, 2022 at 4:00 p.m. in Baltimore, Maryland, before the Honorable Deborah L. Boardman in United States of America v. Ahmed M. Sary, Criminal No. 1:22-mj-01286-JMC, filed in the U.S. District Court for the District of Maryland on May 12, 2022 as Document 28. Assistant U.S. Attorneys Paul A. Riley and Abigail E. Ticse appear for the government and Julie M. Reamy for the defendant, with interpreter Nevine Ibrahim; the court reporter is Patricia G. Mitchell. The government states that it is proceeding on an appeal of an Order Setting Conditions of Release. The court explains that it reviews the release order de novo and must decide whether conditions will reasonably assure Mr. Sary's appearance and the safety of the community. The transcript runs 58 pages.
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
Record facts
| Court | U.S. District Court for the District of Maryland |
|---|---|
| Filed | 2022-05-12 |
Cite this document
“NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings as to Ahmed M Sary… — USA v. Ahmed Sary - Ahmed M Sary (Dkt. 28).”
U.S. District Court for the District of Maryland, No. 1:22-mj-01286-JMC, Doc. 28, filed 2022-05-12. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-ahmed-sary-mdd-511816/2022-05-12-gov-uscourts-mdd-511816-28-0-doc-28/
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
NORTHERN DIVISION
UNITED STATES OF AMERICA, )
)
Plaintiff, )
vs. )
) CRIMINAL NO.:
AHMED M. SARY, ) 1:22-mj-01286-JMC
)
Defendant. )
__________________________________)
Baltimore, Maryland
May 9, 2022
4:00 p.m.
TRANSCRIPT OF PROCEEDINGS
DETENTION REVIEW HEARING
BEFORE THE HONORABLE DEBORAH L. BOARDMAN
Courtroom 3A
For the Plaintiff:
Paul A. Riley, Esquire
Abigail E. Ticse, Esquire
Assistant U.S. Attorneys
For the Defendant:
Julie M. Reamy, Esquire
Also Present: Nevine Ibrahim, Interpreter
Proceedings recorded by mechanical stenography, transcript
produced by computer.
_____________________________________________________________
Patricia G. Mitchell, RMR, CRR
Federal Official Court Reporter
101 W. Lombard Street, 4th Floor
Baltimore, Maryland 21201
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 1 of 58
P R O C E E D I N G S
(4:21 p.m.)
THE COURT: Good afternoon, everyone. The Government
please call the case.
MR. RILEY: Good afternoon, Your Honor. Calling the
case of the United States of America versus Ahmed Sary, Case
Number 22-mj-1286-JMC. Assistant U.S. Attorneys Paul Riley and
Abigail Ticse on behalf of the Government. We're proceeding in
connection with an appeal of an Order Setting Conditions of
Release, Your Honor.
THE COURT: Okay, good afternoon to both of you.
Please have a seat. Ms. Reamy?
MS. REAMY: Good afternoon, Your Honor. For the
record, my name is Julie Reamy. I represent Ahmed Sary; he's
standing to my left at trial table.
THE COURT: Okay, good afternoon to you. Good
afternoon, Mr. Sary. I'm going to remove my mask because I'm
vaccinated. If you are fully vaccinated and are speaking, you
may remove your mask. If you're comfortable, you of course can
keep your mask on all the time. If you're not vaccinated, your
mask stays on. If you're not speaking, please wear your mask.
All right?
Let's swear the interpreter in, please.
(Interpreter duly sworn.)
THE CLERK: Could you please state your name for the
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 2 of 58
record.
THE INTERPRETER: Nevine Ibrahim.
THE COURT: Are you certified interpreter of Arabic;
is that correct?
THE INTERPRETER: I am proficient interpreter, Your
Honor, towards the certification.
THE COURT: In Arabic, that's the language, correct?
THE INTERPRETER: Yes, yes.
THE COURT: Okay, you can have a seat, thank you.
THE INTERPRETER: Thank you.
THE COURT: We are here, as Mr. Riley said, on an
appeal of a detention -- excuse me, a release order issued
earlier today by Judge Hurson. The Government has appealed
that, and of course the Court reviews the pretrial release
order and any detention order de novo. I need to make an
independent determination of whether or not there are
conditions of release that will reasonably assure Mr. Sary's
appearance and the safety of the community.
So let me just tell you what I have reviewed so far.
I have reviewed Judge Hurson's release order. I have reviewed
the Government's May 8 filing in this case, document 15. I
have reviewed Ms. Reamy's submission, document 17. I have read
the criminal complaint and the affidavit in support of the
criminal complaint and the search warrant for various homes,
the Pretrial Services report, and I have the Government's
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 3 of 58
exhibit and exhibit list from this morning.
So with that, Mr. Riley, I will hear from you.
MR. RILEY: Yes, Your Honor. I don't know that I
have received a copy of Judge Hurson's detention -- release
order in this case. It may have just been docketed. Obviously
I was present at the hearing so I don't know that I -- the most
important person to have a copy is you, Your Honor, but I will
note that I have not received that. And we are moving pretty
quickly here, given that the hearing before Judge Hurson was
just a few hours ago. I did want to note that.
THE COURT: I can make you a copy if that is at all
useful.
MR. RILEY: That would be helpful, Your Honor. I'm
happy to, if Your Honor likes, if we get the copy made, if I
could have even two minutes to review it --
THE COURT: Sure.
MR. RILEY: -- very brief period of time. I think I
have a good sense of what the ruling was, but the actual
written order, it would be nice to see that --
THE COURT: Absolutely.
MR. RILEY: -- I apologize.
THE COURT: No problem, we're moving fast.
Mr. Riley, Mr. Sary has been detained since April 29;
is that correct?
MR. RILEY: Let me check my calendar here -- April
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 4 of 58
29, yes, that was Friday. Yes, Your Honor, that's correct. I
would note this matter was originally set in for a detention
hearing before Judge Copperthite on Wednesday last week. There
was a continuance asked for by counsel, granted by the Court,
which resulted in us being before Judge Hurson this morning.
THE COURT: Understood. Ms. Reamy, are the
third-party custodians that were part of the release order,
Ms. Sary and Ms. Derezinski, are they here?
MS. REAMY: Yes.
THE COURT: I see them raising their hand.
(Document tendered to counsel.)
MR. RILEY: Thank you, Your Honor. If I could have a
couple minutes to review this quickly.
THE COURT: Of course.
MR. RILEY: Thank you.
(Pause.)
MR. RILEY: Thank you, Your Honor.
THE COURT: I'm ready to hear from you, Mr. Riley.
MR. RILEY: Thank you for your patience, Your Honor.
I know Your Honor is reviewing -- for the record, Your Honor,
I'm vaxed and boosted so I'll be removing my mask.
THE COURT: Okay. If we could all slow down one
step. I'm reminding myself as well, so the interpreter can
interpret us in real time.
MR. RILEY: Thank you, Your Honor. I do have a
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 5 of 58
tendency to speak quickly, so I'll do my best. Your Honor, the
Government would ask this Court to revoke the release order
entered earlier today and enter an order of detention. The
Government is seeking detention on the basis of risk of flight
as well as economic danger to the community. The Government
also submits that there is a serious risk that this defendant
will obstruct justice or attempt to obstruct justice.
Your Honor has reviewed the complaint, Your Honor has
reviewed the Government's submission in support of detention.
I don't want to belabor the points made and the facts in those
documents, but I want to touch briefly on a couple of the
3142(g) factors that support detention here.
With respect to the nature and circumstances of the
offense, Your Honor, this defendant is charged in connection
with a sophisticated and far-reaching scheme involving the
submission of numerous Paycheck Protection Program loans,
Economic Injury Disaster Loans, both of which were provided in
connection with the CARES Act in light of the pandemic. These
were loans meant to help small business owners across the
country.
The Government's investigation has revealed that this
defendant submitted millions of dollars' worth of loans on
behalf of various purported businesses, and then he received
kickbacks as a result of his submission of these loans,
sometimes amounting to as much as 30 percent of the loan
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 6 of 58
amount. These loans were obtained by purported businesses
across the country, California, New York, New Jersey, Virginia,
Texas, Maryland and so on. And this scheme involved multiple
co-conspirators, multiple shell companies that were used to
launder these kickbacks. The PPP loan applications submitted
by this defendant were backed by fake documents such as fake
bank statements and fake IRS forms.
The complaint references, Your Honor, 40 Paycheck
Protection Program loans, 10 million -- amounting to
$10 million worth of losses and $2.5 million in kickback
payments paid to entities associated with this defendant, Your
Honor, as well as entities associated with his
co-conspirators.
Now from the Government's perspective, Your Honor,
these 40 loans, this $10 million is the tip of the iceberg in
connection with this fraud, in connection with this scheme, and
based on the results of the search warrant executed on Friday
two weeks ago, the Government has identified 54 EIDL
applications that come back to an IP address associated with
this defendant's purported business located at 1600 Hanover
Street.
Moreover, Your Honor, a search of an apartment,
Apartment B at 1600 Hanover Street adjacent to this defendant's
business, a search of that location revealed more than 90
files, hard copy files meticulously organized that reflected
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 7 of 58
businesses -- business submissions for PPP loans. These files
contained numerous amounts of PII, copies of driver's licenses,
Social Security numbers, bank statements, tax documents, as
well as copies of checks and PPP application paperwork. Some
of the files, Your Honor, contained doctored bank statements as
well.
These files weren't located in this defendant's
business address, Your Honor. They weren't located at 1600
Hanover Street. They were located in an adjacent apartment
next to the business -- hidden, from the Government's
perspective.
Based on the revelations from the search warrant
conducted on the 29th of April, the Government is still
wrapping its arms around the scope of this defendant's fraud,
but it appears to be larger and more far-reaching based on
those 90-plus files we obtained, Your Honor, than we had first
suspected. So all of this is to say, Your Honor, that the
fraud scheme at issue here, what's charged in this case, it's a
far-reaching scheme involving many loans, involving potentially
quite high loss amounts.
I note too, Your Honor, the fact that this offense
involved fake bank statements, fake tax forms, this underscores
not only the seriousness of this offense, but perhaps suggests
a facility by this defendant to obtain other fake documents,
either obtain them or create them, Your Honor. I will
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 8 of 58
acknowledge, Your Honor -- and Judge Hurson asked me about this
this morning -- the Government did not find any holograms or
any documents suggesting that he was creating fake passports or
fake licenses, I acknowledge that.
The point I'm making, Your Honor, is there's at least
some facility there or at least some facility to get in touch
with the right person and get those potentially fake travel
documents, like new driver's licenses, new passport and so on.
The type of items that could facilitate flight from justice.
And so too, Your Honor, is the fact that what was -- based on
what was recovered during the search, this defendant had access
to huge, a huge amount of PII, new Social Security numbers,
numerous copies of driver's licenses, banking information and
so on.
THE COURT: Is there any evidence that he stole that
information, or was it provided to him by people who
participated in this alleged fraud?
MR. RILEY: From the Government's perspective, we
understand it to be the latter, Your Honor, that the potential
loan applicants were arguably part of the scheme to defraud. I
don't want to foreclose the possibility there might be a victim
here or there, but that doesn't change the fact -- even if the
loan applicants were involved in the scheme, Your Honor, there
is applicant 1 referenced in the complaint who obtained a
$250,000-plus PPP loan, paid out 25 percent plus in kickbacks
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 9 of 58
to this defendant, purchased a Mercedes, purchased a luxury
apartment and so on. So it's possible, Your Honor, that some
folks could be victims, but the Government has the latter
understanding that Your Honor referenced.
The point I was making, Your Honor, is that this
defendant had access to a huge amount of PII, and he may still
potentially have access to it if he is released to his home.
I'd also note, Your Honor, that during the searches
conducted on the 29th, law enforcement recovered numerous,
numerous vehicle titles, original vehicle titles, and those
titles were not all in this defendant's name, further
underscoring this defendant's access to important documents,
the type of documents that would potentially allow him or
bespeak his ability to obtain or gain possession of a vehicle
that law enforcement might not know about, further underscoring
the risk of flight.
With respect to the weight of the evidence, the
weight of the evidence is quite strong here, Your Honor, as set
out in our detention submission. Entities that this defendant
controlled, and that were at least on paper controlled by his
associates, received numerous kickbacks from businesses that
received PPP loans. I'll just give two examples for two
purported entities tied to this defendant.
There's the Am Halal Meat company. Am Halal Meat
received $301,000 approximately in kickback payments from 15
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 10 of 58
different entities that received PPP loans. AMEX Financial
Group, another one of the defendant's purported businesses,
received $758,341.15 worth of kickback loans from 32 different
entities that received PPP loans. And there were multiple
other entities involved in this case that, from the
Government's perspective, we understand were used to launder
these kickback payments
At times, as with applicant 1, Your Honor, there were
kickback checks made out to just two entities. Certain other
occasions, there were kickback checks made out to up to nine
different entities to launder, to break up these proceeds.
I'd note as well, Your Honor, that law enforcement,
during the search conducted of Apartment B, 1600 Hanover
Street, located blank checks associated with two entities that
weren't in defendant's name; that were in the name of
defendant's associates, blank checks that were signed by
authorized signatories but with the payee left blank and with
the amount left blank, indicating, Your Honor, this defendant's
control over some of those entities that weren't in his name
that were used to launder funds.
THE COURT: So, wait, who were those blank checks
signed by, according to you?
MR. RILEY: They were signed by authorized
signatories on the accounts, not this defendant. So, for
example, Your Honor, without getting into the specific name,
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 11 of 58
one of the entities used to launder funds, from the
Government's perspective, received 173,000-plus in kickback
payments from a number of PPP loan recipients. During the
search for that purported business, law enforcement found
checks that were signed by an authorized signatory, not the
defendant, that were blank. No payee information --
THE COURT: Help me understand how that is evidence
of fraud. Are you alleging that he forged their name?
MR. RILEY: I apologize -- no, I am not. I am
suggesting this shows this defendant's control.
THE COURT: Okay, I understand.
MR. RILEY: So the entities that were in this
defendant's name, his businesses, purported businesses like Am
Halal, AMEX Financial Group, they received kickbacks from
numerous entities. Other entities that weren't in his name
received kickback payments.
THE COURT: Okay.
MR. RILEY: And two of -- for two of those entities,
there were signed checks. Again suggesting that -- his sort of
key role in this conspiracy even if his name isn't on the
purported business. Is that responsive to Your Honor?
THE COURT: It is. I understand, I believe. I was
looking at, I think, your exhibits, Exhibit 1 with various
blank checks.
MR. RILEY: Yes, Your Honor. Those blank checks are
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 12 of 58
not what I was referring to. These blank checks actually play
a different role in the scheme. Your Honor, I'll direct the
Court to Exhibit 1.
Exhibits 1 through 3, Your Honor, all reflect checks
from purported businesses that received PPP funds.
THE COURT: Okay.
MR. RILEY: All of these checks were seized during
the execution of the search warrant on the 29th. Take
Exhibit 1, for example, Your Honor. This business, this
purported business -- bear with me for one second, I apologize.
This purported business received $195,650 PPP loan,
paid kickbacks amounting to 22 percent of the loan value to
various entities, including AMEX Financial Group which is the
defendant's purported business. But what we have here, Your
Honor, is blank checks signed. We understand this to be an
authorized signatory. Numerous blank checks: $15,000, $15,000,
$4,000, $5,000, $5,000.
We understood that it was part of this defendant's
scheme to assist loan applicants with getting the PPP loans and
then request that signed checks with no payee information, with
no pay information and no date, he left with that. And that he
would be the one who would write out who -- the entities that
would receive these checks. So we understand that the
defendant was in control of the process to write out the
kickback checks, get them deposited. And the Government's
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 13 of 58
understanding is supported by what applicant 1 referred to in
the complaint said about the person who he knew as "Adam."
He said that Adam, he met Adam at the address at 1600
Hanover Street, that Adam submitted the PPP loan, that Adam
told him to sign checks, to make out the checks but to leave
payee blank.
THE COURT: Okay.
MR. RILEY: He saw those -- I'm sorry, Your Honor?
THE COURT: I understand now your point with these.
MR. RILEY: Okay. The same goes with Exhibit 2,
another purported business. This business received a $421,000
PPP loan, paid kickbacks amounting to 10 percent loan amount,
including Am Halal Meat, one of the defendant's businesses.
Exhibit 3, this entity received a PPP loan for over
$950,000, paid kickbacks amounting to 19 percent of the loan
amount, including over $70,000 to Am Halal Meat.
The pattern we've seen with respect to the kickbacks,
these blank checks secured by law enforcement consistent
with -- they corroborate our understanding of the scheme and
they corroborate what applicant 1 told law enforcement when
interviewed.
Applicant 2, not referenced in the complaint,
explained a similar experience. He said similar things to
applicant 1, Your Honor. His purported business received a
loan in excess of $250,000, and he paid approximately $75,000
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 14 of 58
in kickbacks after receiving a loan. It's approximately 30
percent of the loan value. He said that he met someone named
Adam at an address at Hanover Street and that he had never seen
the loan application, never seen the supporting documents
submitted with the loan application, such as a purported IRS
Form 940.
The IRS, of course, confirms that they have no record
of a Form 940 being filed in connection with applicant 2's
business. Applicant 2 noted further, with respect to the
kickback checks, that Adam told him to provide signed checks
with the amounts filled in but with the payee blank and that he
did so, again, consistent with what applicant 1 said and
consistent with the results of the search and consistent with
the flow of funds that we can see in connection with the
kickback payments.
So all this is to say the scheme, the laundering of
money is sophisticated, it involves multiple entities. This
defendant's own entities --
THE COURT: Let me just, so I don't want to repeat,
it's ten to 5:00. I want to cut to some things that I think
are important.
MR. RILEY: Yes, Your Honor.
THE COURT: So I definitely want to get to why you
think that he's a serious flight risk.
MR. RILEY: Yes, Your Honor.
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 15 of 58
THE COURT: But before we do that, as I read the
complaint, clearly one of the concerns the Court has is whether
or not an individual has stolen Social Security numbers, has
lied about his own identity or Social Security numbers. I'm
not at all diminishing the alleged fraud you described, but
when I read this, I don't see that he's lied about his address
or his Social Security number. Everything was submitted under
his name. Is that right?
MR. RILEY: Or his own purported businesses.
THE COURT: Or his own purported businesses which I
understand your view is those are either sham businesses or he
lied about the nature of the businesses.
MR. RILEY: And those businesses were used to launder
funds in connection with numerous other fraud --
THE COURT: For other fraudulent applications.
MR. RILEY: Yes, Your Honor. With respect to lies
and perhaps omissions, I'd note that the Pretrial Services
report references the defendant's -- just one purported
business. There's a business called Sary Stars that the
defendant says employs him. Sary Stars, Your Honor, is a
business that received kickback loans in connection with this
scheme, $218,857 from at least eight different entities that
received PPP loans.
He didn't reference to Pretrial Services --
Ms. Jackson is not here -- didn't reference Am Halal Meat,
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 16 of 58
didn't reference to Pretrial Services his employment by Am Ex
Financial Group. So those aren't lies, Your Honor, but they
are omissions and material ones. Apart from the Sary Stars
employment information, the Government is not aware of this
defendant's other employment apart from being self-employed.
Now I want to talk about this defendant's history and
characteristics which I think informs the Government's view
about risk of flight. This defendant has multiple family
members in Egypt. Over the past two years, he's taken seven
trips to Egypt. He stayed there for at least two weeks.
There's one one-month trip, there was a five-week trip, there's
a seven-week trip. The defendant just returned from Egypt on
April 9, 2022. Extensive travel to Egypt, extensive travel to
Egypt during the heart of this conspiracy.
I appreciate what counsel said in her submission and
the defendant's submission with respect to deaths in the family
during this time period as well. I appreciate the desire to be
with family during those times. But we're not talking about
one or two trips, Your Honor. We're talking about numerous
trips to Egypt.
I'd note as well, Your Honor, that the Government is
very concerned about access to at least one international
account. During a search of this defendant incident to his
arrest, his wallet, law enforcement seized a bank card for a
bank out of Egypt, in addition to numerous other bank cards.
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THE COURT: Was that bank involved in this alleged
fraud?
MR. RILEY: Your Honor, at this time the Government
has no visibility into that account, so --
THE COURT: Okay. But the funds that were obtained
weren't directed to that account as far as you know?
MR. RILEY: Not as far as I know, Your Honor.
THE COURT: All right, go ahead.
MR. RILEY: At this time I don't have visibility into
that account. So I would submit, Your Honor, that the foreign
bank account is troubling to the Government; this defendant's
extensive travel to Egypt is troubling to the Government.
One of the questions that Judge Hurson had for me a
few hours ago was, "Well, what is the current state of play
with respect to this defendant's bank accounts?" I don't have
up-to-date information, Your Honor, as to how much this
defendant currently has in his bank accounts. What I have --
and I didn't have this earlier this morning -- is historical
information.
I have one account, the ending date for this is June
2021, balance of $31,000 plus. Another account, the ending
date is October 10, '21, balance of $41,500 plus. Another
account, this is an account for Am Halal Meat business, ending
date May 31, 2021, balance of $340,150.67. AMEX Financial
Group, another account, another purported business, ending date
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May 31, 2021, balance of $147,785. And there are accounts --
two accounts associated with his wife at different banks. One
has just under $10,000, ending date October 19, '21; the other
$9,500, ending date for which we have information October 4,
2021.
So, in addition -- again, this is historical
information. I don't have updated information. We haven't
gotten the subpoena responses back yet as to the current state
of play. Those are not insignificant funds, not an
insignificant amount of money. So that coupled with the
international bank account that we, again, don't have
visibility into, potentially suggests that this defendant has
the resources to flee. And again, this is only the account the
Government knows about, Your Honor.
THE COURT: You have in the complaint that the funds
went into certain accounts, like an M&T account and other
accounts --
MR. RILEY: Yes, Your Honor.
THE COURT: Do you have access to what's in those
accounts and the current state of those accounts?
MR. RILEY: Currently, no, Your Honor. Those
accounts that -- I gave Your Honor historical information and
listed the last information that we have. I don't know what
the current state of those accounts are.
THE COURT: Let me ask you this. When was, according
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to you, that you know of, the last transmission of fraudulent
funds into one of those accounts? It looks like it ended at
the end of last year; is that correct?
MR. RILEY: Well, Your Honor, I don't know when the
last transmission of funds is. I do know, Your Honor, that
there was a submission or there were submissions of
applications as late as December 30, 2021. Submissions for PPP
EIDL loans. I can't speak to the flow after that, Your
Honor.
THE COURT: Okay.
MR. RILEY: This defendant is a naturalized U.S.
citizen. He had a U.S. passport. The Government seized his
passport. I do understand -- this is Government's Exhibit 4 --
that among the items seized by law enforcement was an Egyptian
ID card. I can't speak to this defendant's citizenship in
Egypt. I inquired with Department of Homeland Security, with
the State Department; they can't tell me whether he has a dual
citizenship with Egypt. What we see from the ID card, it's
some sort of formal relationship with the state of Egypt. The
Government's not aware of any law that would prevent the
Egyptian embassy from getting this defendant a new passport if
he were to go --
THE COURT: Do you know if he -- this is not an
Egyptian passport. This is an ID card. So do we know if he
has an Egyptian passport?
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MR. RILEY: I found out this morning when counsel
noted that he has an expired Egyptian passport, so I can't
speak to whether he has a current passport, and I can't speak
to what would happen if he were to go and try to obtain an
Egyptian passport.
THE COURT: Do we know if the Egyptian passport
that's expired is from 25 years ago or if it's from two years
ago?
MR. RILEY: I don't --
THE COURT: You don't know.
MR. RILEY: I think counsel said it expired in 2005?
I'm sure she'll correct me. I've seen some nods here. That's
old, Your Honor, but I think Your Honor -- I hope Your Honor
understands my point.
I guess what I'm getting at, Your Honor, is there's
no -- the fact that we have his American passport isn't
dispositive in this analysis.
THE COURT: What about the fact that he has five
American children here and a wife in the home? What do I do
about that fact?
MR. RILEY: Certainly those are ties. Those are ties
to Maryland, he simply wants to be with his family. I
understand that. At the same time, Your Honor, he's looking at
very significant punishment if he proceeds to trial, or if he
pleads guilty, the offense is severe here. I can see incentive
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to flee.
I can't speak to his relationship with his family.
By all accounts, he's a loving father and loving husband, but
the Government is concerned about --
THE COURT: So let me just understand. The basis for
the proffer of the serious risk of flight is he's a naturalized
citizen from Egypt, he has traveled to Egypt several times for
significant periods over the last several years, he has an
Egyptian ID card on him, and there were several hundred
thousand dollars in various accounts as of last fall.
MR. RILEY: There's significant dollar amounts. I
think probably if you add it up, we're getting pretty high up
there in terms of the amount, the total amount. Probably north
of 100, 150 -- I'm sorry, north of a half million dollars, Your
Honor. That plus the fact that we have zero -- we are aware of
a foreign bank account that unfortunately we have zero
visibility into, and coupled with just the nature of this
scheme, Your Honor --
THE COURT: Well, the nature of the scheme, the
allegations are serious, without a doubt. What I'm trying to
decide is if there are any conditions of release that will
reasonably assure the safety of the community. I'm looking at
whether or not I can trust Mr. Sary to report to Court.
Indicia of not being able to trust someone is, in my view,
certainly alleged fraudulent activity, there's deception,
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there's the creation of I guess IRS documents.
But I don't see, as you've admitted, that there's a
demonstrated or evidence of an ability to create a passport, a
travel document -- I guess I'm just having a hard time
detaining someone when they've got five children, a wife, a
house that will be posted, no criminal history, no acts of
violence, serious allegations of fraud against the Government
without a doubt. But when the standard is reasonable
assurance... I'm just not sure the Government has met its
burden by a preponderance, that there's a serious risk of
flight.
You mentioned obstruction of justice. Let me hear
about that.
MR. RILEY: Yes, Your Honor. From the Government's
perspective, there is a serious risk that at this defendant's
release, that he will obstruct or attempt to obstruct justice.
This case involves numerous co-conspirators, the folks who
submitted -- who this defendant facilitated the submission of
PPP applications for, as well as the various folks involved
with the laundering of the money through these purported
entities.
I want to talk about a phone call that was made to
this defendant's wife on May 2, 2022, which is one of the
primary -- I think this was one of the primary motivations from
the Government's perspective in raising the risk of obstruction
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of justice. During this call, essentially in substance, this
defendant's wife asked about who she should tell about what
happened to the defendant, presumably referring to his arrest
and the fall-out of his arrest.
This defendant says, quote, "Nevine and Rehab and
Mohamed, those are the people you need to keep close for sure,"
end quote.
Nevine is a reference to -- at least as the
Government understands it, Nevine Kamel. Her purported
business received a PPP loan of $104,000, and it also received
kickbacks from at least 15 entities that received PPP loans in
the total amount of $266,714.39.
Rehab, the Government understands is a reference to
Rehab Saad; a number of her purported businesses received
kickback payments too. One purported business received 15
payments from loan recipients totaling over $313,000. Another
purported business received two payments totaling over $23,000.
The third person that the Government understands the
defendant was referring to, the Mohamed, we understand was a
reference to one of Mr. Sary's other associates, Mohamed
Elessawy. One of his purported businesses received 17
kickbacks totaling over $173,000. Another received 18 kickback
checks totaling over $276,000.
There may be an innocent explanation for "these are
the people you need to keep close for sure," Your Honor, but
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every single person referred to by this defendant is a
potential co-conspirator in this case based on what I've just
said. The use of their purported businesses to launder these
kickback funds. So if conditions -- if the Court does not
revoke the order set by Judge Hurson, we are relying on this
defendant's wife to report honestly to Pretrial Services about
contact with these witnesses, these potential co-conspirators.
I don't think -- based on this phone call, I don't think we
have a good basis to rely on her to report honestly to Pretrial
Services.
The last point, Your Honor, kind of dovetails with my
next point which is Ms. Sary is not a suitable third-party
custodian for this --
THE COURT: Tell me why you don't think so.
MR. RILEY: To begin with, she hasn't been vetted by
Pretrial Services.
THE COURT: Is Ms. Sary here?
MS. REAMY: Yes, Your Honor.
THE COURT: Okay, go ahead.
MR. RILEY: She was listed as a signatory on one of
the bank accounts associated with this fraud scheme, Your
Honor. That is the bank account tied to AMEX Financial Group,
one of the defendant's purported businesses. This is the
purported business that had, at least as of May 31, 2021,
$147,785.82. So she's a signatory on the account. She's
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part -- she's in the scheme, from the Government's perspective,
and I don't think that she can be trusted to report violations
to Pretrial Services.
I note, Your Honor, that when law enforcement went to
this defendant and his wife's house, the defendant was not
there, Your Honor. He was traveling with his son -- there was
a reference to a 9-year-old son in counsel's letter. That's
not right. The son was older than 18 years old. They were
traveling to the hospital for nose surgery, I think it was.
When law enforcement asked Ms. Sary, "Where's your husband?"
she said, "I don't know." "I don't know." Lying to law
enforcement.
She did eventually acknowledge that she lied to law
enforcement, but the point I'm making, Your Honor, is that
given -- given the charges, given the scheme, given that she
was signatory on one of the accounts that received a large
amount of fraud funds, given her misstatement to law
enforcement, given the fact that she loves her husband and
doesn't want him to be detained, she's not in a position to
report honestly violations if this defendant wants to have
contact with co-conspirators or witnesses. They could come to
his house and visit. If she doesn't report it, we're not
protected against that, Your Honor.
THE COURT: Let me ask you this. I understand one of
the conditions that Judge Hurson imposed was -- I'm looking at
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the release order -- 8(d), "Post with the Court the following
proof of ownership of the designated property" and it refers to
the -- is that Magie Street home?
MR. RILEY: Yes, Your Honor.
THE COURT: It's not clear to me if he was requiring
the recording of a lien against the home as a secured property?
Do you know?
MR. RILEY: That was my -- I agree, Your Honor, it's
not clear from the record. That was my understanding, that the
home, whatever equity the defendant has in the home be put up
as security as a nonappearance bond, that he would risk losing
his equity if he fled.
THE COURT: Do you have any reason to believe or
disbelieve what's reported in the pretrial report which is that
the residence is worth about 400,000 and there's $150,000
mortgage?
MR. RILEY: Well, I know that's -- I think that's
self-reported information, Your Honor, so I do have a healthy
skepticism of what the defendant has told Pretrial, given that
he only told Pretrial about one of his purported businesses.
Standing here right now, I can't speak to how much equity he
has unfortunately.
THE COURT: I understand.
MR. RILEY: Your Honor, I'm happy to answer any
questions if the Court has them.
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THE COURT: Let me go to Ms. Reamy. Thank you very
much, Mr. Riley. I'm trying to get to the right result and
comply with the Bail Reform Act. Some of the things the
Government is telling me is troubling as to whether or not I
can trust -- Ms. Reamy, if you don't mind standing unless you
need to sit. It's just easier for me to see you, thank you --
whether or not I can trust his wife as a third-party custodian.
There seems to be a lot of money involved here and resources to
flee.
So if you could just cut to the heart of your
argument, address these more difficult questions, I would
appreciate that.
MS. REAMY: Yes. Starting with Mrs. Sary, I had a
discussion with her about what happened when the search warrant
was executed, and she indicated to me that she did tell the
officers she didn't know. She didn't know because she knew
that Mr. Sary was going to be at the hospital for some part of
the time --
THE COURT: Can you bring the microphone closer to
you.
MS. REAMY: She knew her husband was going to be at
GBMC with her son. That was an error on my part saying the
9-year old. It was the 20-year-old son that was having nasal
surgery. She also knew he had planned to go to the office
because the surgery was going to take a number of hours, so
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 28 of 58
that was what she meant in that situation. She was not lying
to the agent. She did not know where he was at that time.
This was early in the morning, she wasn't sure where he was.
So her position is that she was never trying to mislead or lie
to the officer. She just really did not know where he was and
took the question quite literally.
The passport, the Egyptian passport expired in 2005.
Mr. Sary says that he does not have it --
THE COURT: Is your client an Egyptian citizen?
MS. REAMY: I believe he is. I believe he does have
a dual citizenship, but he does not have a recent passport, it
expired in 2005. He's never renewed another one -- he's
indicating to me that he would not obtain a new passport.
But over the last 20 years, he's been making more --
he's been building deep roots in the United States. Again, as
the Court said, he's got three children -- that's very
distracting, I'm sorry.
(Discussion off the record regarding audio issues.)
THE COURT: Okay, Ms. Reamy.
MS. REAMY: Thank you, Your Honor. As I was saying,
Mr. Sary has three children under the age of 10 who have always
only known the United States as their home. The two older
children, twin boys, 20 years old, they were naturalized as
United States citizens in 2017. They both have their own lives
here. One is enrolled in Salisbury State University, one is
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enrolled in college of -- Anne Arundel Community College, the
younger children are in school. He has significant ties to the
community.
Now the references to bank accounts that have
relatively large balances in the fall of last year, these are
businesses. These are not personal bank accounts. So I don't
think that it's necessarily unusual to find business bank
accounts that have higher balances than what you would expect
to see in a personal bank account.
We've explained the trips to Egypt, and they all
surrounded his father's passing and then his mother's passing.
She was steadily declining and very sick with diabetes, and
then unfortunately she passed. Those trips all surrounded both
of those deaths and dealing with the aftermath of those
deaths.
Just a moment. I'm not sure -- can the Court help
focus me? There's a lot that I can go over. The Government
has been speaking for quite some time here so I'm trying to
organize --
THE COURT: I'm going to tell you this. I need more
information on the home and what the value is and what the
mortgage is because, to me, I think that Judge Hurson was
correct in requiring a posting of the house as security, and I
believe that's what he intended to do. But I need more
certainty that there's skin in the game in that home before I'd
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Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 30 of 58
be willing to release Mr. Sary, given some of the information
that Mr. Riley has presented to me that I don't believe was
presented to Judge Hurson, particularly about the bank
accounts -- which I understand your view is it's a business
account -- but from the Government's perspective, there are
several accounts, some with hundreds of thousands of dollars in
them as of last year.
So I'm going to need more information about --
perhaps there needs to be a title search done on the house to
know what liens are on it and a bank statement of the
mortgage.
In addition, I'd like to know more about his
relationship or friendship with Linda Derezinski and her
husband Dan. Are they here?
MS. REAMY: Yes, Ms. Derezinski is right here.
THE COURT: Okay. Your wife is not here, sir --
MS. REAMY: She's here.
THE COURT: Oh, she is --
MS. DEREZINSKI: I'm Linda; my husband is not here.
THE COURT: I'm sorry. Your husband is not here?
MS. DEREZINSKI: Correct.
THE COURT: I'm sorry. Just with the mask and you
have short hair, I apologize, and far away from me.
How long have you known Mr. Sary?
MS. DEREZINSKI: 2006.
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THE COURT: Can you come forward and speak in the
microphone? Thank you. Thank you for being here. I know you
were here this morning and here this afternoon.
MS. DEREZINSKI: Yes, Your Honor.
THE COURT: Can you tell me when you met Mr. Sary and
how you know him.
MS. DEREZINSKI: I met him through his wife, Iza.
Our son was born in 2005 in February and she was -- I've been
working home, and she was watching my son while I was -- during
working hours. Then I met Ahmed through her.
THE COURT: Were they married at the time?
MS. DEREZINSKI: They got married while I knew
them.
THE COURT: You've known them as a married couple
since then?
MS. DEREZINSKI: Yes, ma'am. They usually are with
us for Thanksgiving, Easter, different holidays. My mother
calls her "sister" and "son."
THE COURT: I'm sorry?
MS. DEREZINSKI: I said my mother calls her another
daughter. My mother is their children's American
grandmother.
THE COURT: Understood.
MS. DEREZINSKI: We know them very well.
THE COURT: You know them very well.
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MS. DEREZINSKI: Yes, ma'am.
THE COURT: Would you say you interact with them on a
weekly or monthly basis?
MS. DEREZINSKI: I mean sometimes because of kids,
lately maybe I won't talk to them for a month or two. But then
we might talk every day, you know, it's just -- our son is 17
and, you know. With each kid, it gets complicated.
THE COURT: Would you be willing to house him in your
home pending trial if I --
MS. DEREZINSKI: If that needs to be. I prefer him
to be home, but yes, ma'am. Because of their youngest having
diabetes, you know, Ahmed has the touch with the girls.
THE COURT: I understand. Thank you very much.
Thank you for being here.
MS. DEREZINSKI: Yes, ma'am.
MS. REAMY: Your Honor, I do want to address the
Government's allegations, and we did this with Judge Hurson as
well, regarding this recorded jail call. The Government has
its interpretation, but I can tell you -- it does track
conversations that I had myself with Izabela Sary which is that
they are very embarrassed about this. What she's essentially
asking is that she doesn't want to just share all of their
business; this is a very embarrassing situation for them with
anyone in the community.
So I believe that's really the nature of the
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conversation, that there are certain people that they would
trust because they're going to have to rely on some individuals
for some help while this is -- while he's detained. She's
managing all these children by herself. It was not anything
more than that kind of discussion which was --
THE COURT: I think the Government has conceded some
limitations in its interpretation of that call. I think that
your interpretation is fair, perhaps their interpretation could
be fair. At this point I really don't place much sort of
credit on that call without more in order to show that there's
a serious risk of obstruction of justice. I don't know exactly
what that call said or what was meant by it. What, frankly, at
this point I'm most concerned about is whether or not there are
conditions that will reasonably assure me that Mr. Sary will
appear in court. Here's -- go ahead.
MS. REAMY: I would also tell the Court that we
surrendered five passports this morning to the Court. I just
received a receipt. All of the minor children's passports were
initially offered, and then the two 20-year-old boys also
offered their passports which were all surrendered in Judge
Hurson's courtroom earlier this morning. As I indicated to
Judge Hurson, Mr. Sary is certainly never going to leave his
family.
This was a gesture to impress upon the Court how
serious he is about his understanding of what his obligations
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would be and hopefully a showing that he has no intention of
fleeing this case. His children are very important to him, and
it's obviously taking a huge emotional toll on him.
Particularly the youngest one with the diabetes. I did want
the Court to know that gesture has been made.
THE COURT: The five passports are Mr. Sary's, his
wife's and his three minor children?
MS. REAMY: No, Mr. Sary's passport was seized by law
enforcement. Mrs. Sary's passport is expired, she doesn't know
where it is. She looked for it in advance of today's hearing.
She thinks maybe the officers took it but doesn't know where it
is. It has expired and she's agreed she would not get another
passport. The five passports turned over to the Court this
morning were the two 20-year-old twin boys and the minor
children.
THE COURT: The children's passports.
MS. REAMY: All the children's passports --
THE COURT: Understood.
MS. REAMY: -- were turned over. A lot of this is
laid out in the letters, but I do think the Court -- is there
anything else the Court would want me to address specifically?
THE COURT: No, I don't believe so. Just give me one
moment, please.
Mr. Riley, is there anything else you want to add in
response to my discussion with Ms. Reamy?
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MR. RILEY: Very briefly, Your Honor, with respect to
Ms. Derezinski. The Government is concerned that if
Ms. Derezinski is working from 7:00 a.m. to 3:00 p.m., even if
Your Honor were to put Mr. Sary in the custody of
Ms. Derezinski, because she's working, she's not going to be in
a position to monitor this defendant closely --
THE COURT: Mr. Riley, it's impossible to find an
absolute -- a person who's going to stand by someone 24/7.
That's just unrealistic.
MR. RILEY: I understand, Your Honor.
MS. REAMY: Judge, she works from home so she's in
the home.
THE COURT: Thank you for that.
All right. This case is before me on the
Government's motion for review of a release order that
Magistrate Judge Hurson issued today, May 9. Under 18 United
States Code § 3145(b), this Court reviews the magistrate
judge's pretrial detention decision de novo. That's a cite
against United States against Clark, 865 F.2d 1433 at 1436,
Fourth Circuit, from 1989. I make an independent determination
of the proper pretrial detention or conditions of release.
That's from United States against Stewart, a 2001 Fourth
Circuit case, 19 Federal App'x 46 at 48.
Under the Bail Reform Act, the Government bears the
burden of proving by a preponderance of the evidence that no
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condition or combination of conditions will reasonably assure
Mr. Sary's appearance. I won't go into safety of the community
because the Government has not sought detention based on safety
of the community, although economic harm is a factor that I
must consider as I analyze the Bail Reform Act factors and any
potential conditions of release.
The Bail Reform Act requires that I consider the
following factors:
The nature and circumstances of the offense charged.
Here the charged offense is by criminal complaint. It's wire
fraud and money laundering, so I have to consider whether the
offense involves a crime of violence. Of course, it does not.
A federal crime of terrorism, it does not. A minor victim, it
does not. A controlled substance, firearm explosive or
destructive device, it does none of those things.
I have to consider the weight of the evidence against
Mr. Sary, and the weight of the evidence appears to be strong.
Mr. Riley has proffered the evidence; I have reviewed a summary
of the nonexhaustive evidence that is in the criminal
complaint. There was a search warrant conducted at an
apartment adjacent to his property which apparently yielded
corroborating evidence of the alleged fraud scheme. So the
weight of the evidence is in favor of the Government. I think
it's no surprise that that's almost always the case in federal
court.
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I have to consider the history and characteristics of
Mr. Sary. That includes his character, physical and mental
condition, family ties, employment, financial resources, length
of residence in the community, community ties, past conduct,
history relating to drug or alcohol abuse, criminal history,
and his record concerning court appearances. Let me address
those factors in reverse order.
Mr. Sary, according to the Pretrial Services report,
is 43 years old and has no criminal history, no prior arrests,
no interactions with law enforcement that are reported by
Pretrial Services or the Government. Therefore, there is no
history of appearing at court appearances or problems of
failing to appear. There appears to be no drug or alcohol
problem.
With respect to length of residence in the community,
community ties, this factor, I think, weighs in favor of
Mr. Sary. In that regard, he has been a United States citizen
for some time. He came to this country, according to Pretrial
Services, in his early 20s -- perhaps at 21 years old -- from
Egypt; he's a naturalized citizen. He has been married to -- I
believe Ms. Sary is an American citizen -- to an American
citizen since the mid 2000s. They have three young children.
They have owned a home since 2015 here in Baltimore where they
live as a family. There is a family friend here who has known
them for, looks like, at least 15 years and has interacted with
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them on a regular basis and observed their family and
corroborated those family and community ties.
On the other side, as Mr. Riley points out, Mr. Sary
has traveled to Egypt several times in the past couple years.
That, frankly, does not trouble me too much because it makes
sense he would travel to Egypt several times in the past few
years with parents falling ill and ultimately dying. People
don't just go for funerals. They go when people are sick and
ill, and he does have siblings there.
Having said that, I can't ignore the fact that there
is another country that he would feel comfortable in if he were
fearful of a long prison sentence. It is a factor I have to
consider. I think, however, that I can address that particular
fact with conditions because really what the concern here is
are there conditions that will reasonably assure me that he
will appear in court. I don't have the crystal ball into the
future. I cannot guarantee -- and the Bail Reform Act does not
require me to guarantee -- appearance, although I take very
seriously that I have to reasonably assure that he will --
myself that he will appear in court. So the ties to Egypt,
while not troubling, are certainly a relevant factor as I
consider conditions of release.
I also have to consider financial resources.
Mr. Riley has brought to my attention several bank accounts
that are associated with Mr. Sary that as of at least six or
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seven months ago had significant balances in them. I am
confident Ms. Reamy and Mr. Sary have an explanation for that,
but the fact is there are several hundred thousand dollars, or
there were at least six or seven months ago, in bank accounts
that Mr. Sary had access to. I don't know what the status of
those bank accounts is. I don't know how much is in them now.
I don't know if Mr. Sary would use that money in some way to
try to flee, but, again, it's a factor I have to consider. I
do think that I can address that factor with conditions of
release.
I have to consider his employment. He has reported
working for and being self-employed with Sary Stars, a music
and entertainment business. I understand Mr. Riley's point
which is he did not report the other purported businesses that
he was associated with in connection with his application for
government loans, but it does appear that there has been
consistent employment. He supports his family, he owns a home.
I see no reason -- evidence that he's not had consistent
employment history.
I have to consider physical and mental condition.
There's no evidence of mental illness and his physical health
seems fair, although I do note some potential heart issues.
I also have to consider whether at the time of the
offense Mr. Sary was on probation, parole or any other order of
release pending trial. He was not, he has no criminal history.
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And I have to consider the nature and seriousness of the danger
to any person or the community that would be posed by his
release.
First, let's address the obvious. The Government
appropriately, of course, has not alleged that Mr. Sary poses
any physical danger, that he's a violent person. There's no
evidence of that, that's not an issue here. I do believe, and
I think Mr. Riley was correct, that I have to consider and I
should consider the potential economic harm to the community or
any other person, and in this regard, I have considered
seriously the allegations against Mr. Sary. Mr. Riley, I
think, summarized them well.
The allegations are that Mr. Sary was the head of a
multibusiness, multibank account, multiperson alleged scheme to
defraud the federal government in applying for relief
associated with the CARES Act. Mr. Sary apparently submitted
applications on his behalf and on behalf of other businesses,
some of which were not actual businesses, and in doing so, he
allegedly defrauded the Government out of over $10 million, and
he and others he's associated with allegedly received about
$2.5 million in what Mr. Riley has characterized as kickbacks.
This is a serious scheme if it's proven to be true.
The question for me, though, on whether or not
release conditions can be set is whether or not I think that
Mr. Sary will continue to pose an economic harm to either the
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government, and at this point -- I understand there are no more
particular loans available -- we can also -- I will certainly
restrict his access to any bank accounts.
What I did not hear from Mr. Riley, and I appreciate
his candor, is there were not, for instance, manufactured
driver's licenses or manufactured passports that to me would
suggest a willingness, ability or propensity to flee.
So for all of those reasons, I do find that there are
conditions of release that will reasonably assure me of
Mr. Sary's appearance in court and certainly the safety of the
community, but I'm not going to set a release order just yet.
I need to know more about the home. I want to know that the
home will be security that will reasonably assure me that
Mr. Sary will not flee. So at this point, I think we need to
continue the hearing to allow Ms. Reamy and her family --
Ms. Reamy and Mr. Sary's family to find the documentation that
I need.
Ms. Reamy, is that something you and your client's
family can get together, and if it can be done sooner than when
you return, I'm happy to consider the submission and not have a
hearing? Do you need a moment to talk?
MS. REAMY: Yes, Your Honor, I do need a moment if I
could.
(Defendant conferred with his counsel.)
MS. REAMY: May I step back a moment to speak with
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his wife?
THE COURT: Please, yes.
(Pause.)
MS. REAMY: Your Honor, the answer is I don't know.
We would certainly -- I will do everything I can to try to get
this together and get the documents by tomorrow morning. I
don't know that that's going to be possible.
THE COURT: Meaning by tomorrow morning or not
possible to find documents?
MS. REAMY: By tomorrow morning.
THE COURT: I'd be surprised if you could do it by
tomorrow morning because actually I think you'd need to go to
the land records.
MS. REAMY: Probably.
THE COURT: Are you saying tomorrow morning because
you go on vacation?
MS. REAMY: I'm leaving tomorrow afternoon, so yes,
if we could miraculously pull all the documents together that
the Court needed, but I think it's unlikely.
THE COURT: Okay, I'll wait to receive the documents.
If you can get them to me by midday, I'll review them. If I'm
comfortable with them, I can issue a release order while you're
away and work with Pretrial to have him released.
Here's ultimately where I'm at. To make me
reasonably assured, I need to know that the property has some
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equity in it, and that's what I'm comfortable with.
MS. REAMY: I understand.
THE COURT: Okay? So there is an order of detention
right now, the stay in the execution of the release order
remains.
Let me ask the marshals, do I need to do anything
right now?
MARSHAL: I'd just ask Your Honor if you'd like us to
have him brought over tomorrow?
THE COURT: Why don't we do this. I will enter a
detention order; it will just be in effect. I think right now
the operative order is a release order. Mr. Riley, is that
your understanding?
MR. RILEY: Correct, Your Honor. The Government did
move to stay that, but correct, Your Honor.
THE COURT: All right. I will enter something on the
docket that indicates there is a stay in the release order so
he remains detained. I will not order him returned to the
courthouse until I know that I am comfortable issuing a release
order which will require me to review the documents. I'll be
in touch through chambers with Pretrial Services and the
marshals about when we want him brought over. Is that fair,
Marshal?
MARSHAL: Yes, ma'am.
THE COURT: Mr. Riley, anything else from your
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perspective? Then, Ms. Reamy, I'll turn to you.
MR. RILEY: No, thank you, Your Honor.
THE COURT: Thank you very much for your
presentation. Ms. Reamy?
MS. REAMY: No, Your Honor. Thank you.
THE COURT: Thank you all.
THE CLERK: All rise. This Honorable Court is now
adjourned.
(Proceedings concluded at 5:41 p.m.)
I, Patricia G. Mitchell, RMR, CRR, do hereby certify
that the foregoing is a correct transcript from the
stenographic record of proceedings in the above-entitled
matter.
Dated this 12th day of May 2022.
__________________________
Patricia G. Mitchell
Official Court Reporter
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< Dates >
April 29 4:23, 4:25.
April 9, 2022 17:13.
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balances 30:5, 30:8, 40:1.
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best 6:1.
blank 11:14, 11:16, 11:17, 11:18,
11:21, 12:6, 12:24, 12:25,
13:1, 13:15, 13:16, 14:6,
14:18, 15:11.
bond 27:11.
boosted 5:21.
born 32:8.
boys 29:23, 34:19, 35:14.
break 11:11.
brief 4:17.
briefly 6:11, 36:1.
bring 28:19.
brought 39:24, 44:9, 44:22.
building 29:15.
burden 23:10, 36:25.
business 6:19, 7:20, 7:24, 8:1,
8:8, 8:10, 12:4, 12:21, 13:9,
13:10, 13:11, 13:14, 14:11,
14:24, 15:9, 16:19, 16:21,
18:23, 18:25, 24:10, 24:15,
24:17, 25:24, 30:7, 31:4,
33:23, 40:13.
businesses 6:23, 7:1, 8:1, 10:21,
11:2, 12:13, 13:5, 14:13,
16:9, 16:10, 16:11, 16:12,
16:13, 24:14, 24:21, 25:3,
25:23, 27:20, 30:6, 40:14,
41:17, 41:18.
.
.
< C >.
calendar 4:25.
California 7:2.
call 2:4, 23:22, 24:1, 25:8, 33:18,
34:7, 34:10, 34:12.
called 16:19.
Calling 2:5.
calls 32:18, 32:20.
candor 42:5.
card 17:24, 20:15, 20:18, 20:24,
22:9.
cards 17:25.
CARES 6:18, 41:16.
Case 2:4, 2:6, 3:21, 4:5, 8:18,
11:5, 23:17, 25:2, 35:2,
36:14, 36:23, 37:24.
Certain 11:9, 19:16, 34:1.
Certainly 21:21, 22:25, 34:22,
39:21, 42:2, 42:10, 43:5.
certainty 30:25.
certification 3:6.
certified 3:3.
certify 45:11.
chambers 44:21.
change 9:22.
character 38:2.
characteristics 17:7, 38:1.
characterized 41:21.
charged 6:14, 8:18, 37:9,
37:10.
charges 26:15.
check 4:25.
checks 8:4, 11:9, 11:10, 11:14,
11:16, 11:21, 12:5, 12:19,
12:24, 12:25, 13:1, 13:4,
13:7, 13:15, 13:16, 13:20,
13:23, 13:25, 14:5, 14:18,
15:10, 24:23.
children 21:19, 23:5, 29:16,
29:21, 29:23, 30:2, 32:21,
34:4, 34:18, 35:2, 35:7,
35:15, 35:16, 35:17,
38:22.
Circuit 36:20, 36:23.
circumstances 6:13, 37:9.
cite 36:18.
citizen 20:12, 22:7, 29:9, 38:17,
38:20, 38:21, 38:22.
citizens 29:24.
citizenship 20:15, 20:18,
29:11.
Clark 36:19.
clear 27:5, 27:9.
clearly 16:2.
CLERK 2:25, 45:7.
client 29:9, 42:18.
close 24:6, 24:25.
closely 36:6.
closer 28:19.
co-conspirator 25:2.
co-conspirators 7:4, 7:13, 23:17,
25:7, 26:21.
Code 36:17.
College 30:1.
combination 37:1.
comfortable 2:19, 39:11, 43:22,
44:1, 44:19.
Community 3:18, 6:5, 22:22,
30:1, 30:3, 33:24, 37:2, 37:4,
38:4, 38:15, 38:16, 39:2,
41:2, 41:9, 42:11.
companies 7:4.
company 10:24.
complaint 3:23, 3:24, 6:8, 7:8,
9:24, 14:2, 14:22, 16:2,
19:15, 37:10, 37:20.
complicated 33:7.
comply 28:3.
computer 1:42.
conceded 34:6.
concern 39:14.
concerned 17:22, 22:4, 34:13,
36:2.
concerning 38:6.
concerns 16:2.
concluded 45:9.
condition 37:1, 38:3, 40:20.
Conditions 2:9, 3:17, 22:21,
25:4, 26:25, 34:14, 36:21,
37:1, 37:6, 39:14, 39:15,
39:22, 40:9, 41:24, 42:9.
conduct 38:4.
conducted 8:13, 10:9, 11:13,
37:20.
48
Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 48 of 58
conferred 42:24.
confident 40:2.
confirms 15:7.
connection 2:9, 6:14, 6:18, 7:16,
15:8, 15:14, 16:14, 16:21,
40:15.
consider 37:5, 37:7, 37:11,
37:16, 38:1, 39:13, 39:22,
39:23, 40:8, 40:11, 40:20,
40:23, 41:1, 41:8, 41:9,
42:20.
considered 41:10.
consistent 14:18, 15:12, 15:13,
40:17, 40:18.
conspiracy 12:20, 17:14.
contact 25:7, 26:21.
contained 8:2, 8:5.
continuance 5:4.
continue 41:25, 42:15.
control 11:19, 12:10, 13:24.
controlled 10:20, 37:14.
conversation 34:1.
conversations 33:20.
copies 8:2, 8:4, 9:13.
Copperthite 5:3.
copy 4:4, 4:7, 4:11, 4:14,
7:25.
Correct 3:4, 3:7, 4:24, 5:1, 20:3,
21:12, 30:23, 31:21, 41:8,
44:14, 44:15, 45:12.
corroborate 14:19, 14:20.
corroborated 39:2.
corroborating 37:22.
counsel 5:4, 17:15, 21:1, 21:11,
26:7.
counsel. 5:11, 42:24.
country 6:20, 7:2, 38:18,
39:11.
couple 5:13, 6:11, 32:14,
39:4.
coupled 19:10, 22:17.
course 2:19, 3:14, 5:14, 15:7,
37:12, 41:5.
courthouse 44:19.
Courtroom 1:24, 34:21.
create 8:25, 23:3.
creating 9:3.
creation 23:1.
credit 34:10.
crime 37:12, 37:13.
CRIMINAL 1:9, 3:23, 3:24,
23:6, 37:10, 37:19, 38:5,
38:9, 40:25.
CRR 1:46, 45:11.
crystal 39:16.
current 18:14, 19:8, 19:20,
19:24, 21:3.
Currently 18:17, 19:21.
custodian 25:13, 28:7.
custodians 5:7.
custody 36:4.
cut 15:20, 28:10.
.
.
< D >.
Dan 31:14.
danger 6:5, 41:1, 41:6.
date 13:21, 18:20, 18:22, 18:24,
18:25, 19:3, 19:4.
Dated 45:16.
daughter 32:21.
day 33:6, 45:16.
de 3:15, 36:18.
dealing 30:14.
deaths 17:16, 30:14, 30:15.
DEBORAH L. BOARDMAN
1:23.
deception 22:25.
decide 22:21.
decision 36:18.
declining 30:12.
deep 29:15.
definitely 15:23.
defraud 9:20, 41:15.
defrauded 41:19.
demonstrated 23:3.
Department 20:16, 20:17.
deposited 13:25.
Derezinski 5:8, 31:13, 31:15,
31:19, 31:21, 31:25, 32:4,
32:7, 32:12, 32:16, 32:20,
32:24, 33:1, 33:4, 33:10,
33:15, 36:2, 36:3, 36:5.
described 16:5.
designated 27:2.
desire 17:17.
destructive 37:15.
detained 4:23, 26:19, 34:3,
44:18.
detaining 23:5.
DETENTION 1:22, 3:12, 3:15,
4:4, 5:2, 6:3, 6:4, 6:9, 6:12,
10:19, 36:18, 36:21, 37:3,
44:3, 44:11.
determination 3:16, 36:20.
device 37:15.
diabetes 30:12, 33:12, 35:4.
different 11:1, 11:3, 11:11, 13:2,
16:22, 19:2, 32:17.
difficult 28:11.
diminishing 16:5.
direct 13:2.
directed 18:6.
Disaster 6:17.
disbelieve 27:14.
Discussion 28:14, 29:18, 34:5,
35:25.
dispositive 21:17.
distracting 29:17.
DISTRICT 1:1, 1:2.
DIVISION 1:3.
docket 44:17.
docketed 4:5.
doctored 8:5.
Document 3:21, 3:22, 5:11,
23:4.
documentation 42:16.
documents 6:11, 7:6, 8:3, 8:24,
9:3, 9:8, 10:12, 10:13, 15:4,
23:1, 43:6, 43:9, 43:18,
43:20, 44:20.
doing 41:18.
dollar 22:11.
dollars 22:10, 22:14, 31:6,
40:3.
dollars' 6:22.
done 31:9, 42:19.
doubt 22:20, 23:8.
dovetails 25:11.
down 5:22.
driver 8:2, 9:8, 9:13, 42:6.
drug 38:5, 38:13.
dual 20:17, 29:11.
duly 2:24.
During 9:11, 10:8, 11:13, 12:3,
13:7, 17:14, 17:17, 17:18,
17:23, 24:1, 32:9.
dying 39:7.
.
.
49
Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 49 of 58
< E >.
E. 1:30.
earlier 3:13, 6:3, 18:18,
34:21.
early 29:3, 38:19.
easier 28:6.
Easter 32:17.
Economic 6:5, 6:17, 37:4, 41:9,
41:25.
effect 44:11.
Egypt 17:9, 17:10, 17:12, 17:13,
17:14, 17:20, 17:25, 18:12,
20:16, 20:18, 20:19, 22:7,
30:10, 38:20, 39:4, 39:6,
39:20.
Egyptian 20:14, 20:21, 20:24,
20:25, 21:2, 21:5, 21:6, 22:9,
29:7, 29:9.
EIDL 7:18, 20:8.
eight 16:22.
either 8:25, 16:11, 41:25.
Elessawy 24:21.
embarrassed 33:21.
embarrassing 33:23.
embassy 20:21.
emotional 35:3.
employment 17:1, 17:4, 17:5,
38:3, 40:11, 40:17,
40:19.
employs 16:20.
end 20:3, 24:7.
ended 20:2.
ending 18:20, 18:21, 18:23,
18:25, 19:3, 19:4.
enforcement 10:9, 10:15, 11:12,
12:4, 14:18, 14:20, 17:24,
20:14, 26:4, 26:10, 26:12,
26:14, 26:18, 35:9,
38:10.
enrolled 29:25, 30:1.
enter 6:3, 44:10, 44:16.
entered 6:3.
entertainment 40:13.
Entities 7:11, 7:12, 10:19, 10:23,
11:1, 11:4, 11:5, 11:9, 11:11,
11:14, 11:19, 12:1, 12:12,
12:15, 12:18, 13:13, 13:22,
15:17, 15:18, 16:22, 23:21,
24:11.
entity 14:14.
equity 27:10, 27:12, 27:21,
44:1.
error 28:22.
Esquire 1:29, 1:30, 1:36.
essentially 24:1, 33:21.
eventually 26:13.
everyone 2:3.
Everything 16:7, 43:5.
evidence 9:15, 10:17, 10:18,
12:7, 23:3, 36:25, 37:16,
37:17, 37:18, 37:19, 37:22,
37:23, 40:18, 40:21,
41:7.
Ex 17:1.
exactly 34:11.
example 11:25, 13:9.
examples 10:22.
excess 14:25.
excuse 3:12.
executed 7:17, 28:15.
execution 13:8, 44:4.
Exhibit 4:1, 12:23, 13:3, 13:9,
14:10, 14:14, 20:13.
Exhibits 12:23, 13:4.
expect 30:8.
experience 14:23.
expired 21:2, 21:7, 21:11, 29:7,
29:12, 35:9, 35:12.
explained 14:23, 30:10.
explanation 24:24, 40:2.
explosive 37:14.
Extensive 17:13, 18:12.
.
.
< F >.
F.2d 36:19.
facilitate 9:9.
facilitated 23:18.
facility 8:24, 9:6.
fact 8:21, 9:10, 9:22, 21:16,
21:18, 21:20, 22:15, 26:18,
39:10, 39:14, 40:3.
factor 37:4, 38:16, 39:12, 39:21,
40:8, 40:9.
factors 6:12, 37:5, 37:8,
38:7.
facts 6:10.
failing 38:13.
fair 34:8, 34:9, 40:22,
44:22.
fake 7:6, 7:7, 8:22, 8:24, 9:3,
9:4, 9:7.
fall 22:10, 30:5.
fall-out 24:4.
falling 39:7.
family 17:8, 17:16, 17:18, 21:22,
22:2, 34:23, 38:3, 38:24,
39:1, 39:2, 40:17, 42:15,
42:16, 42:19.
far 3:19, 18:6, 18:7, 31:23.
far-reaching 6:15, 8:15,
8:19.
fast 4:22.
father 22:3, 30:11.
favor 37:23, 38:16.
fearful 39:12.
February 32:8.
Federal 1:47, 36:23, 37:13,
37:24, 41:15.
feel 39:11.
few 4:10, 18:14, 39:6.
filed 15:8.
files 7:25, 8:1, 8:5, 8:7,
8:16.
filing 3:21.
filled 15:11.
Financial 11:1, 12:14, 13:13,
17:2, 18:24, 25:22, 38:3,
39:23.
find 9:2, 30:7, 36:7, 42:8, 42:16,
43:9.
firearm 37:14.
First 8:16, 41:4.
five 21:18, 23:5, 34:17, 35:6,
35:13.
five-week 17:11.
fled 27:12.
flee 19:13, 22:1, 28:9, 40:8, 42:7,
42:14.
fleeing 35:2.
flight 6:4, 9:9, 10:16, 15:24,
17:8, 22:6, 23:11.
Floor 1:48.
flow 15:14, 20:8.
focus 30:17.
folks 10:3, 23:17, 23:19.
following 27:1, 37:8.
foreclose 9:21.
foregoing 45:12.
foreign 18:10, 22:16.
50
Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 50 of 58
forged 12:8.
Form 15:6, 15:8.
formal 20:19.
forms 7:7, 8:22.
forward 32:1.
found 12:4, 21:1.
Fourth 36:20, 36:22.
frankly 34:12, 39:5.
fraud 7:16, 8:14, 8:18, 9:17,
12:8, 16:5, 16:14, 18:2, 23:7,
25:21, 26:17, 37:11,
37:22.
fraudulent 16:15, 20:1,
22:25.
Friday 5:1, 7:17.
friend 38:24.
friendship 31:13.
fully 2:18.
funds 11:20, 12:1, 13:5, 15:14,
16:14, 18:5, 19:9, 19:15,
20:2, 20:5, 25:4, 26:17.
funerals 39:8.
future 39:17.
.
.
< G >.
G. 1:46, 45:11, 45:23.
gain 10:14.
game 30:25.
gave 19:22.
GBMC 28:22.
gesture 34:24, 35:5.
gets 33:7.
getting 11:25, 13:19, 20:21,
21:15, 22:12.
girls 33:12.
give 10:22, 35:22.
given 4:9, 26:15, 26:17, 26:18,
27:19, 31:1.
gotten 19:8.
grandmother 32:22.
granted 5:4.
Group 11:2, 12:14, 13:13, 17:2,
18:25, 25:22.
guarantee 39:17, 39:18.
guess 21:15, 23:1, 23:4.
guilty 21:25.
.
.
< H >.
hair 31:23.
Halal 10:24, 12:14, 14:13, 14:16,
16:25, 18:23.
half 22:14.
hand 5:10.
Hanover 7:20, 7:23, 8:9, 11:13,
14:4, 15:3.
happen 21:4.
happened 24:3, 28:14.
happy 4:14, 27:24, 42:20.
hard 7:25, 23:4.
harm 37:4, 41:9, 41:25.
head 41:13.
health 40:21.
healthy 27:18.
hear 4:2, 5:18, 23:12, 42:4.
HEARING 1:22, 4:6, 4:9, 5:3,
35:10, 42:15, 42:21.
heart 17:14, 28:10, 40:22.
Help 6:19, 12:7, 30:16,
34:3.
helpful 4:13.
hereby 45:11.
herself 34:4.
hidden 8:10.
high 8:20, 22:12.
higher 30:8.
historical 18:18, 19:6,
19:22.
history 17:6, 23:6, 38:1, 38:5,
38:9, 38:12, 40:19,
40:25.
holidays 32:17.
holograms 9:2.
home 10:7, 21:19, 27:3, 27:6,
27:10, 29:22, 30:21, 30:25,
32:9, 33:9, 33:11, 36:11,
36:12, 38:23, 40:17, 42:12,
42:13.
Homeland 20:16.
homes 3:24.
honestly 25:6, 25:9, 26:20.
Honorable 1:23, 45:7.
hope 21:13.
hopefully 35:1.
hospital 26:9, 28:17.
hours 4:10, 18:14, 28:25,
32:10.
house 23:6, 26:5, 26:22, 30:23,
31:9, 33:8.
huge 9:12, 10:6, 35:3.
hundred 22:9, 40:3.
hundreds 31:6.
Hurson 3:13, 3:20, 4:4, 4:9, 5:5,
9:1, 18:13, 25:5, 26:25,
30:22, 31:3, 33:17, 34:21,
34:22, 36:16.
husband 22:3, 26:10, 26:18,
28:21, 31:14, 31:19,
31:20.
.
.
< I >.
Ibrahim 1:39, 3:2.
iceberg 7:15.
ID 20:15, 20:18, 20:24,
22:9.
identified 7:18.
identity 16:4.
ignore 39:10.
ill 39:7, 39:9.
illness 40:21.
important 4:7, 10:12, 15:21,
35:2.
imposed 26:25.
impossible 36:7.
impress 34:24.
incentive 21:25.
incident 17:23.
includes 38:2.
including 13:13, 14:13,
14:16.
independent 3:16, 36:20.
indicated 28:15, 34:21.
indicates 44:17.
indicating 11:18, 29:13.
Indicia 22:24.
individual 16:3.
individuals 34:2.
information 9:13, 9:16, 12:6,
13:20, 13:21, 17:4, 18:16,
18:19, 19:4, 19:7, 19:22,
19:23, 27:18, 30:21, 31:1,
31:8.
informs 17:7.
initially 34:19.
Injury 6:17.
innocent 24:24.
inquired 20:16.
insignificant 19:9, 19:10.
51
Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 51 of 58
instance 42:5.
intended 30:24.
intention 35:1.
interact 33:2.
interacted 38:25.
interactions 38:10.
international 17:22, 19:11.
interpret 5:24.
interpretation 33:19, 34:7,
34:8.
INTERPRETER 1:39, 2:23,
2:24, 3:2, 3:3, 3:5, 3:8, 3:10,
5:23.
interviewed 14:21.
investigation 6:21.
involved 7:3, 8:22, 9:23, 11:5,
18:1, 23:19, 28:8.
involves 15:17, 23:17,
37:12.
involving 6:15, 8:19.
IP 7:19.
IRS 7:7, 15:5, 15:7, 23:1.
issue 8:18, 41:7, 43:22.
issued 3:12, 36:16.
issues 40:22.
issues. 29:18.
issuing 44:19.
items 9:9, 20:14.
Iza 32:7.
Izabela 33:20.
.
.
< J >.
Jackson 16:25.
jail 33:18.
Jersey 7:2.
Judge 3:13, 3:20, 4:4, 4:9, 5:3,
5:5, 9:1, 18:13, 25:5, 26:25,
30:22, 31:3, 33:17, 34:20,
34:22, 36:11, 36:16,
36:18.
Julie 1:36, 2:14.
justice 6:7, 9:9, 23:12, 23:16,
24:1, 34:11.
.
.
< K >.
Kamel 24:9.
keep 2:20, 24:6, 24:25.
key 12:20.
kickback 7:10, 10:25, 11:3, 11:7,
11:9, 11:10, 12:2, 12:16,
13:25, 15:10, 15:15, 16:21,
24:15, 24:22, 25:4.
kickbacks 6:24, 7:5, 9:25, 10:21,
12:14, 13:12, 14:12, 14:15,
14:17, 15:1, 24:11, 24:22,
41:21.
kid 33:7.
kids 33:4.
kind 25:11, 34:5.
know. 26:11.
known 29:22, 31:24, 32:14,
38:24.
knows 19:14.
.
.
< L >.
laid 35:20.
land 43:13.
language 3:7.
large 26:16, 30:5.
larger 8:15.
last 5:3, 19:23, 20:1, 20:3, 20:5,
22:8, 22:10, 25:11, 29:14,
30:5, 31:7.
late 20:7.
lately 33:5.
latter 9:19, 10:3.
launder 7:5, 11:6, 11:11, 11:20,
12:1, 16:13, 25:3.
laundering 15:16, 23:20,
37:11.
law 10:9, 10:15, 11:12, 12:4,
14:18, 14:20, 17:24, 20:14,
20:20, 26:4, 26:10, 26:11,
26:13, 26:17, 35:8,
38:10.
least 9:5, 9:6, 10:20, 16:22,
17:10, 17:22, 24:8, 24:11,
25:24, 38:25, 39:25,
40:4.
leave 14:5, 34:22.
leaving 43:17.
left 2:15, 11:17, 11:18,
13:21.
length 38:3, 38:15.
letter 26:7.
letters 35:20.
licenses 8:2, 9:4, 9:8, 9:13,
42:6.
lie 29:4.
lied 16:4, 16:6, 16:12,
26:13.
lien 27:6.
liens 31:10.
lies 16:16, 17:2.
light 6:18.
likes 4:14.
limitations 34:7.
Linda 31:13, 31:19.
list 4:1.
listed 19:23, 25:20.
literally 29:6.
live 38:24.
lives 29:24.
loan 6:25, 7:5, 9:20, 9:23, 9:25,
12:3, 13:11, 13:12, 13:19,
14:4, 14:12, 14:14, 14:15,
14:25, 15:1, 15:2, 15:4, 15:5,
24:10, 24:16.
Loans 6:16, 6:17, 6:19, 6:22,
6:24, 7:1, 7:9, 7:15, 8:1, 8:19,
10:22, 11:1, 11:3, 11:4,
13:19, 16:21, 16:23, 20:8,
24:11, 40:16, 42:2.
located 7:20, 8:7, 8:8, 8:9,
11:14.
location 7:24.
Lombard 1:48.
long 31:24, 39:12.
looked 35:10.
looking 12:23, 21:23, 22:22,
26:25.
looks 20:2, 38:25.
losing 27:11.
loss 8:20.
losses 7:10.
lot 28:8, 30:17, 35:19.
loves 26:18.
loving 22:3.
luxury 10:1.
Lying 26:11, 29:1.
.
.
< M >.
M&T 19:16.
M. 1:10, 1:36.
ma'am 32:16, 33:1, 33:11, 33:15,
44:24.
52
Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 52 of 58
Magie 27:3.
Magistrate 36:16, 36:17.
managing 34:4.
manufactured 42:5, 42:6.
married 32:11, 32:12, 32:14,
38:20.
MARSHAL 44:8, 44:23,
44:24.
marshals 44:6, 44:22.
Maryland 1:2, 1:16, 1:49, 7:3,
21:22.
mask 2:17, 2:19, 2:20, 2:21,
5:21, 31:22.
material 17:3.
matter 5:2, 45:14.
mean 33:4.
Meaning 43:8.
meant 6:19, 29:1, 34:12.
Meat 10:24, 14:13, 14:16, 16:25,
18:23.
mechanical 1:41.
members 17:9.
mental 38:2, 40:20, 40:21.
mentioned 23:12.
Mercedes 10:1.
met 14:3, 15:2, 23:9, 32:5, 32:7,
32:10.
meticulously 7:25.
microphone 28:19, 32:2.
mid 38:22.
midday 43:21.
million 7:9, 7:10, 7:15, 22:14,
41:19, 41:21.
millions 6:22.
mind 28:5.
minor 34:18, 35:7, 35:14,
37:13.
minutes 4:15, 5:13.
miraculously 43:18.
mislead 29:4.
misstatement 26:17.
Mitchell 1:46, 45:11, 45:23.
Mohamed 24:6, 24:19,
24:20.
moment 30:16, 35:23, 42:21,
42:22, 42:25.
money 15:17, 19:10, 23:20, 28:8,
37:11, 40:7.
monitor 36:6.
month 33:5.
monthly 33:3.
months 40:1, 40:4.
morning 4:1, 5:5, 9:2, 18:18,
21:1, 29:3, 32:3, 34:17,
34:21, 35:14, 43:6, 43:8,
43:10, 43:12, 43:15.
mortgage 27:16, 30:22,
31:11.
mother 30:11, 32:17, 32:20,
32:21.
motion 36:15.
motivations 23:24.
move 44:15.
moving 4:8, 4:22.
multibank 41:14.
multibusiness 41:14.
multiperson 41:14.
multiple 7:3, 7:4, 11:4, 15:17,
17:8.
music 40:12.
myself 5:23, 33:20, 39:20.
.
.
< N >.
name 2:14, 2:25, 10:11, 11:15,
11:19, 11:25, 12:8, 12:13,
12:15, 12:20, 16:8.
named 15:2.
nasal 28:23.
naturalized 20:11, 22:6, 29:23,
38:20.
nature 6:13, 16:12, 22:17, 22:19,
33:25, 37:9, 41:1.
necessarily 30:7.
need 3:15, 24:6, 24:25, 28:6,
30:20, 30:24, 31:8, 42:12,
42:14, 42:17, 42:21, 42:22,
43:12, 43:25, 44:6.
needed 43:19.
needs 31:9, 33:10.
Nevine 1:39, 3:2, 24:5, 24:8,
24:9.
New 7:2, 9:8, 9:12, 20:21,
29:13.
next 8:10, 25:12.
nice 4:19.
nine 11:10.
NO. 1:9.
nods 21:12.
nonappearance 27:11.
none 37:15.
nonexhaustive 37:19.
north 22:13, 22:14.
NORTHERN 1:3.
nose 26:9.
note 4:8, 4:10, 5:2, 8:21, 10:8,
11:12, 16:17, 17:21, 26:4,
40:22.
noted 15:9, 21:2.
novo 3:15, 36:18.
Number 2:7, 12:3, 16:7, 24:14,
28:25.
numbers 8:3, 9:12, 16:3,
16:4.
Numerous 6:16, 8:2, 9:13, 10:9,
10:10, 10:21, 12:15, 13:16,
16:14, 17:19, 17:25,
23:17.
.
.
< O >.
obligations 34:25.
observed 39:1.
obstruct 6:7, 23:16.
obstruction 23:12, 23:25,
34:11.
obtain 8:24, 8:25, 10:14, 21:4,
29:13.
obtained 7:1, 8:16, 9:24,
18:5.
obvious 41:4.
Obviously 4:5, 35:3.
occasions 11:10.
offense 6:14, 8:21, 8:23, 21:25,
37:9, 37:10, 37:12,
40:24.
offered 34:19, 34:20.
office 28:24.
officer 29:5.
officers 28:16, 35:11.
Official 1:47, 45:24.
Okay 2:11, 2:16, 3:9, 5:22,
12:11, 12:17, 13:6, 14:7,
14:10, 18:5, 20:10, 25:19,
29:19, 31:16, 43:20,
44:3.
old 21:13, 26:8, 28:23, 29:23,
38:9, 38:19.
older 26:8, 29:22.
omissions 16:17, 17:3.
53
Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 53 of 58
One 5:22, 11:2, 12:1, 13:10,
13:22, 14:13, 16:2, 16:18,
17:11, 17:19, 17:22, 18:13,
18:20, 19:2, 20:2, 23:23,
23:24, 24:15, 24:20, 24:21,
25:20, 25:23, 26:16, 26:24,
27:20, 29:12, 29:25, 35:4,
35:22.
one-month 17:11.
ones 17:3.
operative 44:12.
Order 2:9, 3:12, 3:15, 3:20, 4:5,
4:19, 5:7, 6:2, 6:3, 25:5, 27:1,
34:10, 36:15, 38:7, 40:24,
42:11, 43:22, 44:3, 44:4,
44:11, 44:12, 44:17, 44:18,
44:20.
organize 30:19.
organized 7:25.
original 10:10.
originally 5:2.
others 41:20.
own 15:18, 16:4, 16:9, 16:10,
29:24.
owned 38:23.
owners 6:19.
ownership 27:2.
owns 40:17.
.
.
< P >.
p.m. 1:18, 2:2, 36:3, 45:9.
paid 7:11, 9:25, 13:12, 14:12,
14:15, 14:25.
pandemic 6:18.
paper 10:20.
paperwork 8:4.
parents 39:7.
parole 40:24.
part 5:7, 9:20, 13:18, 26:1,
28:17, 28:22.
participated 9:17.
particular 39:13, 42:2.
Particularly 31:3, 35:4.
passed 30:13.
passing 30:11.
passport 9:8, 20:12, 20:13,
20:21, 20:24, 20:25, 21:2,
21:3, 21:5, 21:6, 21:16, 23:3,
29:7, 29:11, 29:13, 35:8,
35:9, 35:13.
passports 9:3, 34:17, 34:18,
34:20, 35:6, 35:13, 35:16,
35:17, 42:6.
past 17:9, 38:4, 39:4, 39:6.
patience 5:19.
Patricia 1:46, 45:11, 45:23.
pattern 14:17.
Paul 1:29, 2:7.
Pause. 5:16, 43:3.
pay 13:21.
Paycheck 6:16, 7:8.
payee 11:17, 12:6, 13:20, 14:6,
15:11.
payments 7:11, 10:25, 11:7,
12:3, 12:16, 15:15, 24:15,
24:16, 24:17.
pending 33:9, 40:25.
People 9:16, 24:6, 24:25, 34:1,
39:7, 39:8.
percent 6:25, 9:25, 13:12, 14:12,
14:15, 15:2.
perhaps 8:23, 16:17, 31:9, 34:8,
38:19.
period 4:17, 17:17.
periods 22:8.
person 4:7, 9:7, 14:2, 24:18,
25:1, 36:8, 41:2, 41:6,
41:10.
personal 30:6, 30:9.
perspective 7:14, 8:11, 9:18,
11:6, 12:2, 23:15, 23:25,
26:1, 31:5, 45:1.
phone 23:22, 25:8.
physical 38:2, 40:20, 40:21,
41:6.
PII 8:2, 9:12, 10:6.
place 34:9.
Plaintiff 1:7, 1:27.
planned 28:24.
play 13:1, 18:14, 19:9.
pleads 21:25.
Please 2:4, 2:12, 2:21, 2:23,
2:25, 35:23, 43:2.
plus 9:25, 18:21, 18:22,
22:15.
point 9:5, 10:5, 14:9, 21:14,
25:11, 25:12, 26:14, 34:9,
34:13, 40:13, 42:1,
42:14.
points 6:10, 39:3.
pose 41:25.
posed 41:2.
poses 41:5.
position 26:19, 29:4, 36:6.
possession 10:14.
possibility 9:21.
possible 10:2, 43:7, 43:9.
Post 27:1.
posted 23:6.
posting 30:23.
potential 9:19, 25:2, 25:7, 37:6,
40:22, 41:9.
potentially 8:19, 9:7, 10:7,
10:13, 19:12.
PPP 7:5, 8:1, 8:4, 9:25, 10:22,
11:1, 11:4, 12:3, 13:5, 13:11,
13:19, 14:4, 14:12, 14:14,
16:23, 20:7, 23:19, 24:10,
24:11.
prefer 33:10.
preponderance 23:10,
36:25.
Present 1:39, 4:6.
presentation 45:4.
presented 31:2, 31:3.
presumably 24:3.
Pretrial 3:14, 3:25, 16:17, 16:24,
17:1, 25:6, 25:9, 25:16, 26:3,
27:14, 27:19, 27:20, 36:18,
36:21, 38:8, 38:11, 38:18,
43:23, 44:21.
pretty 4:8, 22:12.
prevent 20:20.
primary 23:24.
prior 38:9.
prison 39:12.
Probably 22:12, 22:13,
43:14.
probation 40:24.
problem 4:22, 38:14.
problems 38:12.
proceeding 2:8.
Proceedings 1:21, 1:41, 45:9,
45:13.
proceeds 11:11, 21:24.
process 13:24.
produced 1:42.
proffer 22:6.
proffered 37:18.
54
Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 54 of 58
proficient 3:5.
Program 6:16, 7:9.
proof 27:2.
propensity 42:7.
proper 36:21.
property 27:2, 27:6, 37:21,
43:25.
protected 26:23.
Protection 6:16, 7:9.
proven 41:22.
provide 15:10.
provided 6:17, 9:16.
proving 36:25.
pull 43:18.
punishment 21:24.
purchased 10:1.
purported 6:23, 7:1, 7:20,
10:23, 11:2, 12:4, 12:13,
12:21, 13:5, 13:10, 13:11,
13:14, 14:11, 14:24, 15:5,
16:9, 16:10, 16:18, 18:25,
23:20, 24:9, 24:14, 24:15,
24:17, 24:21, 25:3, 25:23,
25:24, 27:20, 40:14.
put 27:10, 36:4.
.
.
< Q >.
question 29:6, 41:23.
questions 18:13, 27:25,
28:11.
quickly 4:9, 5:13, 6:1.
quite 8:20, 10:18, 29:6,
30:18.
quote 24:5, 24:7.
.
.
< R >.
raising 5:10, 23:25.
read 3:22, 16:1, 16:6.
ready 5:18.
real 5:24.
really 29:5, 33:25, 34:9,
39:14.
reason 27:13, 40:18.
reasonable 23:8.
reasonably 3:17, 22:22, 34:14,
37:1, 39:15, 39:19, 42:9,
42:13, 43:25.
reasons 42:8.
receipt 34:18.
receive 13:23, 43:20.
received 4:4, 4:8, 6:23, 10:21,
10:22, 10:25, 11:1, 11:3,
11:4, 12:2, 12:14, 12:16,
13:5, 13:11, 14:11, 14:14,
14:24, 16:21, 16:23, 24:10,
24:11, 24:14, 24:15, 24:17,
24:21, 24:22, 26:16, 34:18,
41:20.
receiving 15:1.
recent 29:11.
recipients 12:3, 24:16.
record 2:14, 3:1, 5:20, 15:7,
27:9, 29:18, 38:6, 45:13.
recorded 1:41, 33:18.
recording 27:6.
records 43:13.
recovered 9:11, 10:9.
reference 16:24, 16:25, 17:1,
24:8, 24:13, 24:20, 26:7.
referenced 9:24, 10:4,
14:22.
references 7:8, 16:18, 30:4.
referred 14:1, 25:1.
referring 13:1, 24:3, 24:19.
refers 27:2.
reflect 13:4.
reflected 7:25.
Reform 28:3, 36:24, 37:5, 37:7,
39:17.
regard 38:17, 41:10.
regarding 29:18, 33:18.
regular 39:1.
Rehab 24:5, 24:13, 24:14.
relating 38:5.
relationship 20:19, 22:2,
31:13.
relatively 30:5.
Release 2:10, 3:12, 3:14, 3:17,
3:20, 4:4, 5:7, 6:2, 22:21,
23:16, 27:1, 31:1, 36:15,
36:21, 37:6, 39:22, 40:10,
40:25, 41:3, 41:24, 42:9,
42:11, 43:22, 44:4, 44:12,
44:17, 44:19.
released 10:7, 43:23.
relevant 39:21.
relief 41:15.
rely 25:9, 34:2.
relying 25:5.
remains 44:5, 44:18.
reminding 5:23.
remove 2:17, 2:19.
removing 5:21.
renewed 29:12.
repeat 15:19.
report 3:25, 16:18, 22:23, 25:6,
25:9, 26:2, 26:20, 26:22,
27:14, 38:8, 40:14.
reported 27:14, 38:10,
40:11.
Reporter 1:47, 45:24.
represent 2:14.
request 13:20.
require 39:18, 44:20.
requires 37:7.
requiring 27:5, 30:23.
residence 27:15, 38:4,
38:15.
resources 19:13, 28:8, 38:3,
39:23.
respect 6:13, 10:17, 14:17, 15:9,
16:16, 17:16, 18:15, 36:1,
38:15.
response 35:25.
responses 19:8.
responsive 12:21.
restrict 42:3.
result 6:24, 28:2.
resulted 5:5.
results 7:17, 15:13.
return 42:20.
returned 17:12, 44:18.
revealed 6:21, 7:24.
revelations 8:12.
reverse 38:7.
REVIEW 1:22, 4:15, 5:13,
36:15, 43:21, 44:20.
reviewed 3:19, 3:20, 3:22, 6:8,
6:9, 37:18.
reviewing 5:20.
reviews 3:14, 36:17.
revoke 6:2, 25:5.
rise 45:7.
risk 6:4, 6:6, 10:16, 15:24, 17:8,
22:6, 23:10, 23:15, 23:25,
27:11, 34:11.
RMR 1:46, 45:11.
role 12:20, 13:2.
55
Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 55 of 58
roots 29:15.
ruling 4:18.
.
.
< S >.
Saad 24:14.
safety 3:18, 22:22, 37:2, 37:3,
42:10.
Salisbury 29:25.
saw 14:8.
saying 28:22, 29:20, 43:15.
says 16:20, 24:5, 29:8.
scheme 6:15, 7:3, 7:16, 8:18,
8:19, 9:20, 9:23, 13:2, 13:19,
14:19, 15:16, 16:22, 22:18,
22:19, 25:21, 26:1, 26:15,
37:22, 41:14, 41:22.
school 30:2.
scope 8:14.
search 3:24, 7:17, 7:22, 7:24,
8:12, 9:11, 11:13, 12:4, 13:8,
15:13, 17:23, 28:14, 31:9,
37:20.
searches 10:8.
seat 2:12, 3:9.
second 13:10.
secured 14:18, 27:6.
Security 8:3, 9:12, 16:3, 16:4,
16:7, 20:16, 27:11, 30:23,
42:13.
seeking 6:4.
seems 28:8, 40:22.
seen 14:17, 15:3, 15:4,
21:12.
seized 13:7, 17:24, 20:12, 20:14,
35:8.
self-employed 17:5, 40:12.
self-reported 27:18.
sense 4:18, 39:6.
sentence 39:12.
serious 6:6, 15:24, 22:6, 22:20,
23:7, 23:10, 23:15, 34:11,
34:25, 41:22.
seriously 39:19, 41:11.
seriousness 8:23, 41:1.
Services 3:25, 16:17, 16:24,
17:1, 25:6, 25:10, 25:16,
26:3, 38:8, 38:11, 38:19,
44:21.
set 5:2, 10:18, 25:5, 41:24,
42:11.
Setting 2:9.
seven 17:9, 40:1, 40:4.
seven-week 17:12.
several 22:7, 22:8, 22:9, 31:6,
39:4, 39:6, 39:24, 40:3.
severe 21:25.
sham 16:11.
share 33:22.
she'll 21:12.
shell 7:4.
short 31:23.
show 34:10.
showing 35:1.
shows 12:10.
siblings 39:9.
sick 30:12, 39:8.
side 39:3.
sign 14:5.
signatories 11:17, 11:24.
signatory 12:5, 13:16, 25:20,
25:25, 26:16.
signed 11:16, 11:22, 11:23, 12:5,
12:19, 13:15, 13:20,
15:10.
significant 21:24, 22:8, 22:11,
30:2, 40:1.
similar 14:23.
simply 21:22.
single 25:1.
sir 31:16.
sister 32:18.
sit 28:6.
situation 29:1, 33:23.
six 39:25, 40:4.
skepticism 27:19.
skin 30:25.
slow 5:22.
small 6:19.
Social 8:3, 9:12, 16:3, 16:4,
16:7.
someone 15:2, 22:24, 23:5,
36:8.
sometimes 6:25, 33:4.
son 26:6, 26:7, 26:8, 28:22,
28:23, 32:8, 32:9, 33:6.
son. 32:18.
sooner 42:19.
sophisticated 6:15, 15:17.
sorry 14:8, 22:14, 29:17, 31:20,
31:22, 32:19.
sort 12:19, 20:19, 34:9.
sought 37:3.
speaking 2:18, 2:21, 30:18.
specific 11:25.
specifically 35:21.
stand 36:8.
standard 23:8.
Standing 2:15, 27:21, 28:5.
Stars 16:19, 16:20, 17:3,
40:12.
Starting 28:13.
State 2:25, 18:14, 19:8, 19:20,
19:24, 20:17, 20:19,
29:25.
statement 31:10.
statements 7:7, 8:3, 8:5,
8:22.
States 1:1, 1:5, 2:6, 29:15, 29:22,
29:24, 36:17, 36:19, 36:22,
38:17.
status 40:5.
stay 44:4, 44:15, 44:17.
stayed 17:10.
stays 2:21.
steadily 30:12.
stenographic 45:13.
stenography 1:41.
step 5:23, 42:25.
Stewart 36:22.
stole 9:15.
stolen 16:3.
Street 1:48, 7:21, 7:23, 8:9,
11:14, 14:4, 15:3, 27:3.
strong 10:18, 37:17.
submission 3:22, 6:9, 6:16, 6:24,
10:19, 17:15, 17:16, 20:6,
23:18, 42:20.
Submissions 8:1, 20:6, 20:7.
submit 18:10.
submits 6:6.
submitted 6:22, 7:5, 14:4, 15:5,
16:7, 23:18, 41:16.
subpoena 19:8.
substance 24:1, 37:14.
suggest 42:7.
suggesting 9:3, 12:10,
12:19.
suggests 8:23, 19:12.
suitable 25:12.
56
Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 56 of 58
summarized 41:12.
summary 37:18.
support 3:23, 6:9, 6:12.
supported 14:1.
supporting 15:4.
supports 40:17.
surgery 26:9, 28:24, 28:25.
surprise 37:24.
surprised 43:11.
surrendered 34:17, 34:20.
surrounded 30:11, 30:13.
suspected 8:17.
swear 2:23.
sworn. 2:24.
.
.
< T >.
table 2:15.
tax 8:3, 8:22.
ten 15:20.
tendency 6:1.
tendered 5:11.
terms 22:13.
terrorism 37:13.
Texas 7:3.
Thanksgiving 32:17.
they've 23:5.
thinks 35:11.
third 24:18.
third-party 5:7, 25:12,
28:7.
though 41:23.
thousand 22:10, 40:3.
thousands 31:6.
three 29:16, 29:21, 35:7,
38:22.
Ticse 1:30, 2:8.
tied 10:23, 25:22.
ties 21:21, 30:2, 38:3, 38:4,
38:16, 39:2, 39:20.
tip 7:15.
title 31:9.
titles 10:10, 10:11.
today 3:13, 6:3, 35:10,
36:16.
together 42:19, 43:6, 43:18.
toll 35:3.
tomorrow 43:6, 43:8, 43:10,
43:12, 43:15, 43:17,
44:9.
took 29:6, 35:11.
total 22:13, 24:12.
totaling 24:16, 24:17, 24:22,
24:23.
touch 6:11, 9:6, 33:12,
44:21.
towards 3:6.
track 33:19.
TRANSCRIPT 1:21, 1:41,
45:12.
transmission 20:1, 20:5.
travel 9:7, 17:13, 18:12, 23:4,
39:6.
traveled 22:7, 39:4.
traveling 26:6, 26:9.
trial 2:15, 21:24, 33:9,
40:25.
trip 17:11, 17:12.
trips 17:10, 17:19, 17:20, 30:10,
30:13.
trouble 39:5.
troubling 18:11, 18:12, 28:4,
39:21.
true 41:22.
trust 22:23, 22:24, 28:5, 28:7,
34:2.
trusted 26:2.
try 21:4, 40:8, 43:5.
trying 22:20, 28:2, 29:4,
30:18.
turn 45:1.
turned 35:13, 35:19.
twin 29:23, 35:14.
two 4:15, 7:18, 10:22, 11:9,
11:14, 12:18, 17:9, 17:10,
17:19, 19:2, 21:7, 24:17,
29:22, 33:5, 34:19,
35:14.
type 9:9, 10:13.
.
.
< U >.
U.S. 1:31, 2:7, 20:11, 20:12.
ultimately 39:7, 43:24.
underscores 8:22.
underscoring 10:12, 10:15.
understand 9:19, 11:6, 12:7,
12:11, 12:22, 13:15, 13:23,
14:9, 16:11, 20:13, 21:23,
22:5, 24:19, 26:24, 27:23,
31:4, 33:13, 36:10, 40:13,
42:1, 44:2.
understanding 10:4, 14:1,
14:19, 27:9, 34:25,
44:13.
understands 21:14, 24:9, 24:13,
24:18.
Understood 5:6, 13:18, 32:23,
35:18.
unfortunately 22:16, 27:22,
30:13.
United 1:1, 1:5, 2:6, 29:15,
29:22, 29:24, 36:16, 36:19,
36:22, 38:17.
University 29:25.
unless 28:5.
unlikely 43:19.
unrealistic 36:9.
until 44:19.
unusual 30:7.
up-to-date 18:16.
updated 19:7.
useful 4:12.
.
.
< V >.
vacation 43:16.
vaccinated 2:18, 2:20.
value 13:12, 15:2, 30:21.
various 3:24, 6:23, 12:23, 13:13,
22:10, 23:19.
vaxed 5:21.
vehicle 10:10, 10:14.
versus 2:6.
vetted 25:15.
victim 9:21, 37:13.
victims 10:3.
view 16:11, 17:7, 22:24,
31:4.
violations 26:2, 26:20.
violence 23:7, 37:12.
violent 41:6.
Virginia 7:2.
visibility 18:4, 18:9, 19:12,
22:17.
visit 26:22.
vs 1:8.
.
.
< W >.
57
Case 1:22-mj-01286-JMC Document 28 Filed 05/12/22 Page 57 of 58
W. 1:48.
wait 11:21, 43:20.
wallet 17:24.
wants 21:22, 26:20.
warrant 3:24, 7:17, 8:12, 13:8,
28:14, 37:20.
watching 32:9.
wear 2:21.
Wednesday 5:3.
week 5:3.
weekly 33:3.
weeks 7:18, 17:10.
weighs 38:16.
weight 10:17, 10:18, 37:16,
37:17, 37:23.
whatever 27:10.
whether 3:16, 16:2, 20:17, 21:3,
22:23, 28:4, 28:7, 34:13,
37:11, 40:23, 41:23,
41:24.
wife 19:2, 21:19, 23:5, 23:23,
24:2, 25:6, 26:5, 28:7, 31:16,
32:7, 35:7, 43:1.
will 3:17, 4:2, 4:7, 6:7, 8:25,
22:21, 23:6, 23:16, 34:14,
37:1, 39:15, 39:16, 39:19,
39:20, 41:25, 42:2, 42:9,
42:13, 42:14, 43:5, 44:10,
44:11, 44:16, 44:18,
44:20.
willing 31:1, 33:8.
willingness 42:7.
wire 37:10.
without 11:25, 22:20, 23:8,
34:10.
witnesses 25:7, 26:21.
work 43:23.
working 32:9, 32:10, 36:3, 36:5,
40:12.
works 36:11.
worth 6:22, 7:10, 11:3,
27:15.
wrapping 8:14.
write 13:22, 13:24.
written 4:19.
.
.
< Y >.
year 20:3, 30:5, 31:7.
years 17:9, 21:7, 22:8, 26:8,
29:14, 29:23, 38:9, 38:19,
38:25, 39:4, 39:7.
yielded 37:21.
York 7:2.
young 38:22.
younger 30:2.
youngest 33:11, 35:4.
.
.
< Z >.
zero 22:15, 22:16.
58
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