NOTICE of Intent to Use Certified Business Records Pursuant to Rule 902(11)… — USA v. Alexandra Acosta (Dkt. 34)

Record facts

U.S. District Court for the Southern District of Florida · No. 0:23-cr-60170-RNS · Doc. 34 · 2024-05-07 · Docket on CourtListener

Summary

The United States' notice of intent to offer certified business records under Federal Rule of Evidence 902(11) in United States v. Alexandra Acosta and Vilsaint St Louis, No. 0:23-cr-60170-RNS, in the U.S. District Court for the Southern District of Florida, entered May 7, 2024 as Document 34. The notice lists twelve entities whose certified records the government intends to offer, including Cross River Bank, SunTrust/Truist Bank, the Internal Revenue Service, Google LLC and the Broward County Clerk of Courts. A footnote states that, after conferences on May 1, 2024 and May 6, 2024, Acosta does not object to certified records in lieu of records custodians but reserves objections under Rules 401, 402, and 403. It also states that counsel for St Louis represented his client intends on changing his plea. The two-page notice is signed by Assistant United States Attorney Trevor C. Jones.

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Full text

1 
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO.: 23-CR-60170-SCOLA 
 
UNITED STATES OF AMERICA, 
 
vs.  
 
ALEXANDRA ACOSTA and  
VILSAINT ST LOUIS, 
 
 
Defendants. 
 
 
 
 
            / 
 
UNITED STATES’ NOTICE OF INTENT TO OFFER CERTIFIED BUSINESS 
RECORDS PURSUANT TO FEDERAL RULE OF EVIDENCE 902(11) 
 
  
The United States provides this notice, pursuant to Federal Rule of 
Evidence 902(11), that it intends to offer into evidence the following certified 
business records produced in discovery from the following entities:1 
1. 
Cross River Bank; 
2. 
Scratch Services LLC; 
3. 
SunTrust/Truist Bank; 
4. 
Internal Revenue Service; 
5. 
AT&T; 
6. 
Comcast Cable Communications; 
 
1 Pursuant to a meet and confer via Microsoft Teams on May 1, 2024, and 
telephonic conference on May 6, 2024, Defendant Alexandra Acosta, through her 
counsel, does not object to the admission of certified records in lieu of the use of 
records custodians, i.e., authenticity and hearsay, but reserves her right to 
object under Federal Rules of Evidence 401, 402, and 403. Counsel for 
Defendant Vilsaint St Louis has represented that his client intends on changing 
his plea and has thus not been part of pretrial conferences regarding the 
admission of evidence.  
Case 0:23-cr-60170-RNS   Document 34   Entered on FLSD Docket 05/07/2024   Page 1 of 2

2 
 
7. 
DocuSign, Inc.; 
8. 
Robinhood Markets, Inc.;  
9. 
Google LLC;  
10. 
Valordog LLC;  
11. 
Broward County Sheriff’s Office; and 
12. 
Broward County Clerk of Courts. 
Respectfully submitted, 
 
    
MARKENZY LAPOINTE 
  
 
UNITED STATES ATTORNEY 
 
 
BY:      Trevor C. Jones 
TREVOR C. JONES 
Assistant United States Attorney 
Fla. Bar No. 0092793 
500 E. Broward Blvd., 7th Floor 
 
Fort Lauderdale, Florida 33394 
Tel: (786) 564-9109 
Trevor.Jones@usdoj.gov  
 
Case 0:23-cr-60170-RNS   Document 34   Entered on FLSD Docket 05/07/2024   Page 2 of 2

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