Court filing
Transcript of jury trial excerpt testimony Joana Hely — USA v. Alexandra Acosta (Dkt. 109, S.D. Fla.)
Filed August 9, 2024 in USA v. Alexandra Acosta; one of 136 filings from this case.
Record facts
| Court | U.S. District Court for the Southern District of Florida |
|---|---|
| Filed | 2024-08-09 |
U.S. District Court for the Southern District of Florida · No. 0:23-cr-60170-RNS · Doc. 109 · 2024-08-09 · Docket on CourtListener
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
CASE NO. 0:23-cr-60170-RNS-1
UNITED STATES OF AMERICA, Miami, Florida
Plaintiff, June 4, 2024
vs.
ALEXANDRA ACOSTA,
Defendant. Pages 1 to 31
______________________________________________________________
EXCERPT FROM JURY TRIAL
(TESTIMONY OF JOANA HELY)
BEFORE THE HONORABLE RONALD N. SCOLA
UNITED STATES DISTRICT JUDGE
APPEARANCES:
FOR THE PLAINTIFF: TREVOR CHRISTOPHER JONES, ESQ.
DOJ-USAO
500 East Broward Boulevard
Suite 7th Floor
Ft. Lauderdale, FL 33394
Trevor.jones@usdoj.gov
ADAM LOVE, ESQ.
US Attorney's Office
Miami, FL 33130
Adam.love@usdoj.gov
FOR THE DEFENDANT: BRIAN YAACOV SILBER, ESQ.
Law Offices of Brian Silber, P.A.
916 South Andrews Avenue
Fort Lauderdale, FL 33316
Silberlaw@gmail.com
Case 0:23-cr-60170-RNS Document 109 Entered on FLSD Docket 08/09/2024 Page 1 of 36
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STENOGRAPHICALLY REPORTED BY:
SHARON VELAZCO, RPR, FPR
Official Court Reporter
United States District Court
400 North Miami Avenue
Miami, Florida 33128
Sharon_pellvelazco@flsd.uscourts.gov
(305) 523-5636
I N D E X
WITNESS
Direct Cross Red.
JOANA HELY
By Mr. Love
3
By Mr. Silber
21
_ _ _
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(The following is an excerpt from the jury trial proceedings:)
* * * * *
MR. LOVE: Your Honor, the Government calls Joana Hely.
Thereupon:
JOANA HELY
Was called as a witness and, having been duly sworn,
was examined and testified as follows:
THE WITNESS: I do.
THE COURT: Please be seated and pull yourself up close
to the microphone. You can move the microphone left, right,
back and forth. And, when you are ready, please tell us your
name, and spell your last name.
THE WITNESS: Joana Hely, H-E-L-Y.
THE COURT: Thank you.
DIRECT EXAMINATION
BY MR. LOVE:
Q.
Good morning.
A.
Good morning.
Q.
Ms. Hely, where do you currently work?
A.
Broward County Sheriff's Office Human Resources.
Q.
And how long have you worked for the Broward County
Sheriff's Office?
A.
31 years.
Q.
Is it commonly referred to as BSO?
A.
Yes.
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Q.
And what position do you currently hold?
A.
Classification and compensation manager.
Q.
What are the duties and responsibilities in that role?
A.
Managing the activities for on-boarding and new employees,
maintaining their personnel payroll history throughout their
career, maintaining their personnel file and then, ultimately,
processing the paperwork when the employee separates.
Q.
How long have you maintained that role?
A.
20-plus years.
Q.
Are you familiar with the BSO's human resource records as a
result of your holding that role?
A.
Yes.
Q.
And, does BSO keep personal records of all its employees?
A.
Yes.
Q.
And, does that include those employees that are deputy
sheriffs?
A.
Yes.
Q.
Does BSO maintain policies and procedure manuals?
A.
Yes.
Q.
Generally speaking, what are those policies and procedure
manuals?
A.
It is the policies that the employees are responsible for
following.
Q.
Is that manual accessible for all employees of BSO?
A.
Yes, it is.
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Q.
How is it accessible?
A.
It is maintained on the BSO Informant. It is a website
where the employees have access to review.
Q.
Does BSO provide training on the manual?
A.
Yes. When an employee is on-boarded, when they are
new-hire into the Sheriff's Office, human resources reviews
with the employee the Sheriff's Office policy manual.
Q.
Who conducts the training, specifically?
A.
Human Resources.
Q.
Does BSO require employees to acknowledge the training in
any sort of way?
A.
Yes, they have to acknowledge it.
Q.
How?
A.
They have to sign off that they have seen the policies and
procedures.
Q.
And, does BSO's policies require personnel records be kept?
A.
Yes.
Q.
And HR has access to them?
A.
Yes.
Q.
What is the -- what is the record called for an individual
employee?
A.
A personnel file.
MR. LOVE: Your Honor, I have Government's Exhibit 300,
which I would like to mark for identification, just for the
witness, please.
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(Government's Exhibit No. 300 was marked for
Identification.)
THE COURT: Are your screens off?
MR. LOVE: They should be off, right.
THE COURT: Go ahead.
MR. LOVE: Thank you, your Honor.
BY MR. LOVE:
Q.
Miss Hely, do you recognize the exhibit that is in front of
you?
A.
Yes.
Q.
And, did you have an opportunity to review the exhibit
before testifying today?
A.
Yes.
Q.
And what is this exhibit?
A.
It is an employee action history report.
Q.
And who is this employee action history report for?
A.
Alexandra Acosta.
Q.
And, is this the report that was maintained in her employee
personnel file?
A.
Yes.
MR. LOVE: Your Honor, I move to admit what was
previously identified as Government's Exhibit 300 into
evidence.
MR. SILBER: No objection, your Honor.
THE COURT: Okay. That will be received in evidence.
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(Government's No. 300 was received in Evidence.)
MR. LOVE: And, if I could present that to the jury?
MR. SILBER: Your Honor, I need to clarify.
The only thing that we would do is renew our previously
made motion to the records. So, we maintain a contemporaneous
objection; but, beyond that, as to authentication, for
instance, we don't object.
THE COURT: So, I will continue to overrule the
objection that was previously made.
All right.
Can you see it now?
PANEL IN UNISON: Yes.
THE COURT: Okay.
MR. LOVE: Thank you, your Honor.
BY MR. LOVE:
Q.
Ms. Hely, I want to highlight some portions of this
document. At the top, can you please describe what it is that
we are looking at?
A.
It is an employee action history report for Alexandra
Acosta.
Q.
And what other information is contained on there?
A.
The employee's ID number, their hire date.
Q.
Where is the employee's ID number?
A.
Top left.
Q.
Is that the one that says, EMPLID?
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A.
Yes.
Q.
Do any two employees have the same employee ID number?
A.
No.
Q.
How is this report organized?
A.
It is chronological from the bottom, up. The most recent
is up on the top.
Q.
Looking at the bottom of the exhibit on Page 1, on the
first line, what does that first line indicate?
A.
It is the employee, Ms. Acosta's hire date, denoted as
June 3, 2013.
Q.
And, what was the position or job classification she was
hired for?
A.
Deputy, Sheriff Department's Law of Law Enforcement.
Q.
And based on your knowledge as a human resource officer, is
a deputy sheriff a sworn law enforcement officer?
A.
Yes.
Q.
Moving up to lines 9 through 16, what is the job
classification that Ms. Acosta held?
A.
Deputy sheriff-daily department of law enforcement.
Q.
And where was she assigned?
A.
The International Airport.
Q.
And, what does that refer to?
A.
The work location.
Q.
So, the training on the BSO manual that we refer to would
have occurred in what year?
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A.
In 2013.
Q.
Does the Broward Sheriff's Office maintain a policy
regarding off-duty employment?
A.
Yes.
Q.
What is off-duty employment?
A.
Off-duty employment is any outside activity that an
employee is performing outside of their daily responsibilities
at the Broward Sheriff's Office.
Q.
And, does BSO the policies and procedures manual that we
referred to earlier address the off-duty employment policy?
A.
Yes.
Q.
When does an employee need to seek off-duty employment
approval?
A.
At the time that they want to get approval to start that
employment.
Q.
Can you describe for the jury that process, if an employee
wants to work off-duty?
A.
They would come in for the form and they would print off
the form, the off-duty employment form. And, they would
complete the form, the information outlined on the form; the
type of business, the contact information for that business,
what they will be doing for that particular business, and then
it needs to go through their chain of command for approval.
Q.
Does HR get involved in that process?
A.
We don't. We don't review the forms for approval.
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Q.
Do you receive the forms?
A.
We receive the forms.
Q.
After you receive the forms, what is it that you do with
them?
A.
We place them in the employee's personnel file.
Q.
Does an employee need to renew their form?
A.
Yes. The form sunsets at the end of every calendar year.
It has -- it basically expires December 31st, and a new form
needs to be completed for the new and upcoming calendar year.
Q.
So, if somebody were to fill out a form on December 28th of
a certain year, it would end on that -- the end of that
calendar year?
A.
Right.
Q.
And, they would have to start another one the next year?
A.
Correct.
Q.
Did this policy exist in 2018?
A.
Yes.
Q.
And in 2019?
A.
Yes.
Q.
And how about the years 2020 and 2021?
A.
Yes.
Q.
Does the policy get updated?
A.
Yes.
Q.
How often?
A.
Depends upon review. If there is things in the policy that
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need to be updated, it will be updated.
Q.
When the policy is updated, is there a new issuance of the
policy?
A.
Yes.
Q.
Are employees informed?
A.
Yes.
Q.
And how are they informed?
A.
They will receive an email that they need to -- that there
has been a policy update, and they need to go in and review
that policy and acknowledge that they have received it and
reviewed it.
Q.
What email is used for them to receive the email?
A.
Their employee BSO email.
Q.
And, when they go into the email, how do they acknowledge
it?
A.
They go in and acknowledge that they have reviewed it, and
then you have to click on it to sign for it.
Q.
After that form is completed, is that form maintained in
the employee's personnel file?
A.
Yes.
Q.
Is it ever destroyed or deleted?
A.
No.
MR. LOVE: Your Honor, I have, for identification,
Government's Exhibit 301 through 303.
Based on the discussions with defense counsel, I move
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to admit those into evidence.
MR. SILBER: Your Honor, same comment; we renew our
previously made objections, but do not object as to
authenticity of the documents.
THE COURT: All right. So, those will be admitted over
objection.
(Government's No. 301 was received in Evidence.)
(Government's No. 302 was received in Evidence.)
(Government's No. 303 was received in evidence.)
BY MR. LOVE:
Q.
Ms. Hely, did you have an opportunity to review
Government's Exhibits 301 through 303 before coming in today?
A.
Yes.
Q.
And, generally speaking, what are those three exhibits?
A.
The employees' outside employment forms.
Q.
I just want to display 301 for you.
Do you recognize this?
A.
Yes.
Q.
What is this?
A.
This is the Sheriff's policy manual, the off-duty and extra
duty employment policy.
Q.
And, I want to direct your attention to the bottom of
Page 1 of Government's Exhibit 301. What is depicted that is
highlighted here for you?
A.
It is the policy, the effective date of the policy.
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Q.
And, we see three other dates in addition to -- can you
please describe to the jury what those relate to?
A.
There is a review date, a revised date, a rescind date and
then an effective date.
Q.
So, the review date -- what does that mean?
A.
The policy was reviewed for determination if there needed
to be any changes.
Q.
Does that correlate to the next date you see to the right,
which says "revised?"
A.
Yes.
Q.
Explain Government's Exhibit 302.
A.
So, again, moving to the bottom of the page, 1 of 302, we
have similar dates here.
Q.
Can you describe how these dates impact the previous dates
that we discussed?
A.
There is a new review date, a new revision date, a
rescinding date and then a new effective date.
Q.
And so what date was this effective?
A.
3-1-2020.
Q.
And, moving to Government's Exhibit 303, directing your
attention -- excuse me, attention to the bottom of Page 1, what
is -- what are we reviewing here?
How does it relate to the other dates?
A.
There's a new review day, a revision date, a rescind date,
and a new effective date.
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Q.
Comparing 301, 302, and 303, are there any significant
changes for the off-duty and extra duty employment portion of
the policy manual?
A.
No.
Q.
I want to direct your attention to Section 316, subsection
A at the top of Page 1 of Government's Exhibit 303. Can you
please read this section that I have highlighted to the jury?
A.
"3.16, Off-Duty and Extra Duty Employment. A, it is the
policy of the agency to permit employees to avail themselves to
work in legitimate activities outside the scope of their duties
at the Broward Sheriff's Office or in extra sworn assignments
beyond normal duty or overtime hours. Florida Statute
management rights and applicable accreditation standards permit
the sheriff to place requirements and restrictions on this
activity as described in this policy. The Department of
Professional Standards will be responsible for coordinating the
administrative requirements of this policy."
Q.
Then I want to drop down to Page 1 of this exhibit, to
subsection C-1.
Ms. Hely, what does this section refer to?
A.
The off-duty, off-duty employment, the purpose of the
policy.
Q.
And, can you please read that for the members?
A.
"For the purposes of this policy, No. 1, off- employment
will refer to any activity undertaken by a BSO employee outside
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the scope, responsibilities, working hours and colors of the
Broward Sheriff's Office, including employees who are members
on external boards, commissions, et cetera; public, private, or
nonprofit, whether compensated or not.
"For sworn deputy sheriffs, the ability to exercise law
enforcement powers may not be a condition for employment, and
employment will not provide any real or implied law enforcement
benefit to the employer.
"Further discussion of off-duty employment follows in
Section 3.16.1.
Q.
And then, moving to Section 3.16.1, which is going to be
Page 3, and Ms. Hely, directing your attention to the bottom of
Page 3, subsection G, I am going to highlight that for you.
What does this pertain to?
A.
It is the off-duty employment request form.
Q.
Is that the form that you referred to earlier?
A.
Yes.
Q.
And, under G-1, is that the form number?
A.
Yes. "Employees will complete the off-duty employment
request form, which is BSO RP number 45."
Q.
Moving to the top of the fourth page, what is depicted that
is before you at the top of the page, number 8, as in letters
A, B, C, D?
A.
When you are -- it is the criteria for when you need to
complete the form.
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Q.
And what is some of the criteria?
A.
When you are requesting to approve for off-duty employment,
when you are changing any information for the off-duty employer
or the employer address, telephone number, if you are changing
the type of work that you are going to be performing.
Q.
And, I want to direct your attention to where it says,
"Note."
Can you please read that to the jury?
A.
"Note: Self-employed employees will complete an off-duty
employment request form for each separate business activity,
i.e., lawn service business and plumbing business.
Q.
And then, moving to subsectionn 4 on the same page, does
this refer to that sunset provision you spoke about earlier?
A.
Yes.
Q.
If an employee has an ongoing business, does it mean they
have to renew their off-duty employment form every year?
A.
Every year.
Q.
Do these guidelines help an employee determine whether they
need to apply for off-duty employment approval?
A.
Yes.
Q.
What about if an employee is not sure whether something
qualifies for off-duty employment?
A.
Per the policy, they need to have their supervisor evaluate
with them to determine if it follows the policy.
Q.
Before testifying today, did you said you had an
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opportunity to review the personnel files for Ms. Acosta?
A.
Yes.
Q.
And, were you able to locate off-duty employment forms for
her?
A.
Yes.
Q.
What years were those off-duty employment forms for?
A.
2016, 2017, and 2018.
MR. LOVE: Your Honor, I have what was marked as
Government's Exhibits 304, 305, and 306. I believe, based on
previous conversations with defense counsel, we would move to
admit those.
MR. SILBER: I am sorry, your Honor. I was conferring
with my client.
Which exhibit are you referring to?
MR. LOVE: 303, 304, 305 and 306.
MR. SILBER: Your Honor, same renewal of our previously
made objection; however, we do not object to the authenticity.
THE COURT: I will overrule the objection, and those
will be admitted into evidence.
(Government's No. 303 was received in Evidence.)
(Government's No. 304 was received in Evidence.)
(Government's No. 305 was received in Evidence.)
(Government's No. 304 was received in Evidence.)
BY MR. LOVE:
Q.
Ms. Hely, I am displaying Government's Exhibit 304 for you.
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Do you recognize this?
A.
Yes.
Q.
And what is this?
A.
This is an off-duty employment form.
Q.
Who is it for?
A.
For Ms. Acosta.
Q.
And, for what business is this off-duty employment form
for?
A.
The business name is Keller Williams Realty Partners, SW.
Q.
And, for what year does this form pertain to?
A.
2016.
Q.
And, you mentioned earlier about an approval process. I am
directing your attention to the bottom of Page 1. Is this the
approval process that you were referring to earlier?
A.
Yes.
Q.
Moving to Government Exhibit 305. And, again, the same
questions.
Who is this form for?
A.
Alexandra Acosta.
Q.
And, for what year does this pertain to?
A.
2017.
Q.
And, for what business?
A.
The Keller Williams Realty Partners, SW.
Q.
And, moving to Government Exhibit 306, what form -- excuse
me. Whose form is this?
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A.
Alexandra Acosta.
Q.
And that is for what year?
A.
2018.
Q.
And for what business?
A.
Keller Williams Realty Partners SW.
Q.
Okay. Do each of these forms have a certification?
A.
Yes.
Q.
Is that the certification that you were referring to?
A.
Yes. It is acknowledging the policy.
Q.
Could you please read that for the jury?
A.
Sure. "I understand if this request is approved, it is
valid only for the employer, employer address, telephone
number, type of work and work schedule outlined in this form.
"I also understand that off-duty employment is a privilege
and not a right. This will include employees who sit on
external boards and commissions; public, private, or nonprofit,
whether compensated or not.
"I agree that I will obtain and maintain all appropriate
state, County, and/or city approvals, licenses, et cetera, as
applicable.
"I further understand that the sheriff reserves the right
to approving deny, suspend, or revoke this request at any time
for any reason.
"I have read and understand the policies as outlined in
Section 3.16 of the Sheriff's policy manual, and agree to abide
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by them.
"I understand that this request expires on December 31st of
each year.
"Once employment is terminated, I must submit an off-duty
termination form, BSO RP number 45B.
"I also understand that my failure to do so may result in
revocation of this off-duty employment request and/or
disciplinary action.
Q.
What is the off-duty termination form?
A.
It is the form number RP45 B.
Q.
And, what does it relate to?
A.
It is -- it is completed by the employee when they are no
longer going to perform outside employment work.
MR. LOVE: Your Honor, if I could have a moment,
please?
THE COURT: Yes.
BY MR. LOVE:
Q.
Ms. Hely, did you receive any off-duty employment
termination forms within the personnel file for Ms. Acosta?
A.
No.
Q.
And, were you able to find off-duty forms for her on 2019?
A.
No.
Q.
2020?
A.
No.
Q.
And 2021?
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No.
MR. LOVE: No further questions, your Honor.
THE COURT: All right.
Cross-examination?
MR. SILBER: Thank you, your Honor.
CROSS-EXAMINATION
BY MR. SILBER:
Q.
Good morning?
A.
Good morning.
Q.
Hello, Ms. Hely. Thank you for coming today. Good
morning. I just have a couple of questions.
Ms. Acosta was hired June 3, 2013; is that correct?
A.
Yes.
Q.
Okay. And, my understanding is that when a new employee is
hired, they would sign for the policy manual that they received
it?
A.
Yes, yes.
Q.
Okay. Today, we addressed only a handful of policies that
the agency has; correct?
A.
Yes.
Q.
I imagine there are many others, right?
A.
Yes.
Q.
Can you --
THE COURT: Mr. Silber, if you are not going to be at
the microphone, you need your lapel mic.
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MR. SILBER: Sorry, I apologize.
THE COURT: The lavalliere microphone.
MR. SILBER: I forgot.
THE COURT: It is okay.
BY MR. SILBER:
Q.
All right. Can you tell how many policies and regulations
BSO has?
A.
Not by number, no.
Q.
Well, if you were to print them out, would it be about this
big?
A.
It is a large --
Q.
It is a huge binder, right?
A.
Yes.
Q.
And, in fact, when people do a public records request for
regulations, it is so big you give them a CD instead of
printing it, correct?
A.
I am not familiar with that.
Q.
You don't work in public records, right?
A.
No.
Q.
Okay. Sorry. We saw that there is a number of policies
revisions, and you discussed that in your testimony. Can you
tell us how many policy revisions as to this regulation were
made between 2013 and 2021?
A.
No.
Q.
And, when a policy change is made, is there any explanation
Case 0:23-cr-60170-RNS Document 109 Entered on FLSD Docket 08/09/2024 Page 22 of 36
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for the change in policy?
A.
There is -- on the website, there is -- it is put in
legislative format so the employees can see what the change
was.
Q.
Okay. But, how does the agency make sure they actually
read it?
A.
They -- the employee has to acknowledge receipt and
electronically sign it.
Q.
Okay. And, can you tell me, in terms of the enforcement
and applicability of the policy, let's say I am a deputy, and I
want to go work as a realtor or landscaper on my off-duty time.
Who would I submit the form to?
A.
To the employees' chain of command.
Q.
And that, for the someone, that would probably be their
sergeant; correct?
A.
Whatever their chain of command is.
Q.
So, whoever the higher-ranking person is that they answer
to?
A.
Correct, their supervisor.
Q.
So, if -- let's say I am a sergeant, I might give it to my
lieutenant; correct?
A.
Correct.
Q.
And, if I am a road patrol deputy. I would give it to my
sergeant; correct?
A.
Yes.
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Q.
And, in terms of the roles of these supervisory positions,
it's that person's job -- let's say sergeant, for instance, to
be informed of what their people under them are doing; is that
correct?
A.
Yes, yes.
Q.
Okay. And the sergeant would interact with the employees
when issues come up, "I would like to go work, I like to do
whatever," correct?
A.
Correct.
Q.
Would you agree that even though BSO has all kinds of
regulations on everything, some regulations are more strictly
enforced, whereas others are a little bit more casual?
A.
A policy -- all policies are important.
Q.
I didn't say they were unimportant, but -- they are
definitely important, but there are different regulations for
different things, and they have different levels of importance;
correct?
A.
Okay. Yes.
Q.
For example, I would imagine that safe handling of firearms
must have a regulation by BSO; correct?
A.
Correct.
Q.
For instance, before an officer is allowed to go and patrol
the streets with a gun, the agency makes sure that they are
qualified in the use of that firearm; correct?
A.
Correct.
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And, I am -- I would bet your training division is all over
that, and makes sure there isn't one single deputy on the road
who doesn't know how to use a gun, right?
A.
Correct.
Q.
By contrast, this is a form that I would just hand to my
sergeant, and deal informally with my sergeant; correct?
A.
For approval, yes.
Q.
Okay. Very different than regulations that control use and
safety of a firearm, right?
A.
Again, it is a policy. It needs to be followed.
Q.
I didn't -- I didn't suggest it didn't need to be followed.
What I am asking you is there is a difference in the level of
importance and enforcement amongst different regulations;
correct?
A.
Okay, yes.
Q.
Are you aware that there is an understanding among many
employees that they only have to submit this form for each of
their commands as opposed to on an annual basis?
Have you heard of that?
A.
No.
Q.
Okay. And, the prosecutor, in his direct examination,
showed us a portion where it says, "It is this agency's policy
that an employee can work in a legitimate work."
Do you remember what I am talking about?
He blew up a -- I will just show you.
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Your Honor, can you turn on the --
THE COURT: It is on.
MR. SILBER: Thank you.
BY MR. SILBER:
Q.
I will move on from that.
Let me ask you this question directly. This is what I
am getting at. There is nothing illegal or improper, assuming
a person filled out the form, right, for a deputy to have
outside employment in their off-duty hours; correct?
A.
Correct.
Q.
And, let's say a deputy didn't fill out the form one year
and they filled it out the other years, as is the case here.
There is not necessarily something that would be punished
severely, would it?
They might be just reprimanded a little bit, told to do it
better next time.
Am I right about that?
A.
Well, that is a policy violation, not completing the form.
Q.
All right. A policy violation is different than a
regulation violation, right?
A.
I don't -- I don't understand the difference.
Q.
It might be outside your area.
And, for the years that Ms. Acosta did, in fact, submit
this form, this is something that is approved by a lot of
people in the chain of command; correct?
Case 0:23-cr-60170-RNS Document 109 Entered on FLSD Docket 08/09/2024 Page 26 of 36
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A.
Correct.
Q.
Okay. I am showing you what was previously admitted as
Government's Exhibit 304 and 305.
Do you see that; correct?
A.
Yes.
Q.
With that 2016?
A.
Yes.
Q.
Okay. So, let's look at these names here. It looks like a
colonel, colonel Pollack, another one, right, Lieutenant
Colonel Polan, Major Holmes, Captain Brooks, Lieutenant Kuker,
I think, and it looks like Sergeant Cremidis; is that right?
A.
Yes.
Q.
Okay. So, all these people reviewed this, were made aware
that she was a part-time realtor, and approved it; correct?
A.
Yes.
Q.
Okay. Same thing over here, right?
This is the other form.
Colonel Dilto or Doto. I am not sure what that says.
Do you recognize that?
A.
Colonel Dale.
Q.
Oh, Dale. Thank you.
Lieutenant Colonel Polan. It looks like this one is
missing. Major Holmes, Captain Brooks, Sergeant Frank,
Sergeant Cremidis, right?
A.
Yes.
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Q.
All these people knew she was working in real estate and
authorized; correct?
A.
Yes.
Q.
Now, isn't it true that it is common and very frequent
amongst law enforcement officers for people to have off-duty
employment?
A.
Yes.
Q.
In fact, there's a lot of employees at BSO who work as
realtors, landscapers, plumbers, and have side businesses;
correct?
A.
Yes.
Q.
Okay. So, there is nothing inappropriate about having the
outside work, is there?
A.
No.
MR. SILBER: Your Honor, if I could just have a second
to confer with my client.
THE COURT: Yes.
BY MR. SILBER:
Q.
Can you tell us, if you know, how many times or how many
employees have you ever heard of being disciplined for failing
to submit this form?
A.
I wouldn't know that information.
Q.
Well, in human resources, you would know if an employee was
terminated or suspended, wouldn't you?
A.
Just through a termination form.
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Q.
Okay. And when you get a termination form, does it tell
the reason why that person is terminated?
A.
It may -- might have different policy violations.
Q.
Okay. But, in 31 years, can you tell me any employee who
was terminated for this?
A.
Not that I am -- familiar with.
Q.
Okay. But, you work in human resources, and you hear when
such employee did something wrong, is getting in trouble; this
one is getting fired; this one is getting demoted. You must
hear about that, correct?
A.
Yes.
Q.
That is exactly the office you work in; correct?
A.
Yes.
Q.
Okay. And, in your 31 years, have you ever heard of a
deputy getting suspended because they didn't fill out a
form one year, but they filled it out other years?
A.
There is a disciplinary process if somebody doesn't
complete the form.
Q.
I understand that. But, have you ever heard of it in human
resources?
A.
I have not. Not off the top of my head, no.
Q.
So, you would say this is unusual?
A.
There could be a counseling. There could be a disciplinary
process if someone doesn't complete the form. I am just not
familiar with the particular case.
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Q.
But, you would agree with me that if you heard an employee
got terminated, demoted, or suspended for not filling out this
little form, that would be unusual to you because you never
heard it before, right?
A.
I don't know the answer to that.
MR. LOVE: I don't have anything further for this
witness, your Honor.
THE COURT: All right.
Any redirect?
MR. LOVE: No, your Honor.
THE COURT: All right.
Thank you. Ma'am, you can be excused.
(Witness Excused.)
* * * * *
_ _ _
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C E R T I F I C A T E
I hereby certify that the foregoing is an
accurate transcription of the proceedings in the
above-entitled matter.
August 8, 2024 /s/Sharon Velazco _____
DATE SHARON VELAZCO, RPR, FPR
Official Court Reporter
United States District Court
400 North Miami Avenue
8th Floor
Miami, Florida 33128
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/s/Sharon [1] - 31:7
0
0:23-cr-60170-RNS-
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20:21
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20:23
2021 [3] - 10:20,
20:25, 22:23
2024 [2] - 1:5, 31:7
21 [1] - 2:12
28th [1] - 10:10
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comparing [1] - 14:1
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compensation [1] -
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completed [3] - 10:9,
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completing [1] -
26:18
condition [1] - 15:6
conducts [1] - 5:8
confer [1] - 28:16
conferring [1] -
17:12
contact [1] - 9:21
contained [1] - 7:21
contemporaneous
[1] - 7:5
continue [1] - 7:8
contrast [1] - 25:5
control [1] - 25:8
conversations [1] -
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coordinating [1] -
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correct [30] - 10:15,
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27:14, 28:2, 28:10,
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correlate [1] - 13:8
counsel [2] - 11:25,
17:10
counseling [1] -
29:23
County [3] - 3:20,
3:21, 19:19
couple [1] - 21:11
Court [4] - 2:3, 2:3,
31:8, 31:8
COURT [19] - 1:1,
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6:25, 7:8, 7:13, 12:5,
17:18, 20:16, 21:3,
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26:2, 28:17, 30:8,
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27:24
criteria [2] - 15:24,
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cross [1] - 21:4
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D
daily [2] - 8:19, 9:7
Dale [2] - 27:20,
27:21
date [17] - 7:22, 8:9,
12:25, 13:3, 13:4,
13:5, 13:8, 13:16,
13:17, 13:18, 13:24,
13:25
DATE [1] - 31:7
dates [5] - 13:1,
13:13, 13:14, 13:23
deal [1] - 25:6
December [3] - 10:8,
10:10, 20:2
defendant [1] - 1:8
DEFENDANT [1] -
1:21
defense [2] - 11:25,
17:10
definitely [1] - 24:15
deleted [1] - 11:21
demoted [2] - 29:9,
30:2
denoted [1] - 8:9
deny [1] - 19:22
Department [1] -
14:15
department [1] -
8:19
Department's [1] -
8:13
depicted [2] - 12:23,
15:21
deputy [11] - 4:15,
8:13, 8:15, 8:19, 15:5,
23:10, 23:23, 25:2,
26:8, 26:11, 29:15
describe [4] - 7:17,
9:16, 13:2, 13:14
described [1] - 14:15
destroyed [1] - 11:21
determination [1] -
13:6
determine [2] -
16:18, 16:24
difference [2] -
25:12, 26:21
different [7] - 24:15,
24:16, 25:8, 25:13,
26:19, 29:3
Dilto [1] - 27:18
Direct [1] - 2:10
DIRECT [1] - 3:15
direct [4] - 12:22,
14:5, 16:6, 25:21
directing [3] - 13:20,
15:12, 18:13
directly [1] - 26:6
disciplinary [3] -
20:8, 29:17, 29:23
disciplined [1] -
28:20
discussed [2] -
13:15, 22:21
discussion [1] - 15:9
discussions [1] -
11:25
display [1] - 12:16
displaying [1] -
17:25
District [2] - 2:3,
31:8
DISTRICT [3] - 1:1,
1:1, 1:11
division [1] - 25:1
DIVISION [1] - 1:2
document [1] - 7:17
documents [1] - 12:4
DOJ [1] - 1:14
DOJ-USAO [1] - 1:14
Doto [1] - 27:18
down [1] - 14:18
drop [1] - 14:18
duly [1] - 3:6
duties [2] - 4:3,
14:10
Duty [2] - 14:8
duty [36] - 9:3, 9:5,
9:6, 9:10, 9:12, 9:17,
9:19, 12:20, 12:21,
14:2, 14:12, 14:21,
15:9, 15:15, 15:19,
16:2, 16:3, 16:9,
16:16, 16:19, 16:22,
17:3, 17:6, 18:4, 18:7,
19:14, 20:4, 20:7,
20:9, 20:18, 20:21,
23:11, 26:9, 28:5
E
East [1] - 1:15
effective [5] - 12:25,
13:4, 13:17, 13:18,
13:25
electronically [1] -
23:8
email [5] - 11:8,
11:12, 11:13, 11:14
EMPLID [1] - 7:25
employed [1] - 16:9
employee [27] - 4:7,
5:5, 5:7, 5:21, 6:15,
6:16, 6:18, 7:19, 8:2,
8:9, 9:7, 9:12, 9:16,
10:6, 11:13, 14:25,
16:15, 16:18, 16:21,
20:12, 21:14, 23:7,
25:23, 28:23, 29:4,
29:8, 30:1
employee's [4] -
7:22, 7:23, 10:5,
11:19
employees [19] - 4:4,
4:13, 4:15, 4:22, 4:24,
5:3, 5:10, 8:2, 11:5,
14:9, 15:2, 15:19,
16:9, 19:15, 23:3,
24:6, 25:17, 28:8,
28:20
employees' [2] -
12:15, 23:13
employer [5] - 15:8,
16:3, 16:4, 19:12
employment [33] -
9:3, 9:5, 9:6, 9:10,
9:12, 9:15, 9:19,
12:15, 12:21, 14:2,
14:21, 14:24, 15:6,
15:7, 15:9, 15:15,
15:19, 16:2, 16:10,
16:16, 16:19, 16:22,
17:3, 17:6, 18:4, 18:7,
19:14, 20:4, 20:7,
20:13, 20:18, 26:9,
28:6
Employment [1] -
14:8
end [3] - 10:7, 10:11
enforced [1] - 24:12
Enforcement [1] -
8:13
enforcement [7] -
8:15, 8:19, 15:6, 15:7,
23:9, 25:13, 28:5
entitled [1] - 31:5
ESQ [3] - 1:14, 1:18,
1:21
estate [1] - 28:1
et [2] - 15:3, 19:19
evaluate [1] - 16:23
evidence [5] - 6:23,
6:25, 12:1, 12:9,
17:19
Evidence [7] - 7:1,
12:7, 12:8, 17:20,
2
17:21, 17:22, 17:23
exactly [1] - 29:12
EXAMINATION [2] -
3:15, 21:6
examination [2] -
21:4, 25:21
examined [1] - 3:7
example [1] - 24:19
EXCERPT [1] - 1:10
excerpt [1] - 3:1
excuse [2] - 13:21,
18:24
excused [1] - 30:12
Excused [1] - 30:13
exercise [1] - 15:5
Exhibit [12] - 5:23,
6:1, 6:22, 11:24,
12:23, 13:11, 13:20,
14:6, 17:25, 18:16,
18:24, 27:3
exhibit [6] - 6:8,
6:11, 6:14, 8:7, 14:18,
17:14
Exhibits [2] - 12:12,
17:9
exhibits [1] - 12:14
exist [1] - 10:16
expires [2] - 10:8,
20:2
explain [1] - 13:11
explanation [1] -
22:25
external [2] - 15:3,
19:16
extra [3] - 12:20,
14:2, 14:11
Extra [1] - 14:8
F
fact [3] - 22:14,
26:23, 28:8
failing [1] - 28:20
failure [1] - 20:6
familiar [4] - 4:10,
22:17, 29:6, 29:25
file [6] - 4:6, 5:22,
6:19, 10:5, 11:19,
20:19
files [1] - 17:1
fill [3] - 10:10, 26:11,
29:15
filled [3] - 26:8,
26:12, 29:16
filling [1] - 30:2
firearm [2] - 24:24,
25:9
firearms [1] - 24:19
fired [1] - 29:9
first [2] - 8:8
Case 0:23-cr-60170-RNS Document 109 Entered on FLSD Docket 08/09/2024 Page 33 of 36
FL [3] - 1:16, 1:19,
1:23
Floor [2] - 1:15, 31:9
FLORIDA [1] - 1:1
Florida [4] - 1:4, 2:4,
14:12, 31:10
followed [2] - 25:10,
25:11
following [2] - 3:1,
4:23
follows [3] - 3:7,
15:9, 16:24
FOR [2] - 1:14, 1:21
foregoing [1] - 31:3
forgot [1] - 22:3
form [43] - 9:18,
9:19, 9:20, 10:6, 10:7,
10:8, 10:10, 11:18,
15:15, 15:16, 15:18,
15:20, 15:25, 16:10,
16:16, 18:4, 18:7,
18:10, 18:18, 18:24,
18:25, 19:13, 20:5,
20:9, 20:10, 23:12,
25:5, 25:17, 26:8,
26:11, 26:18, 26:24,
27:17, 28:21, 28:25,
29:1, 29:16, 29:18,
29:24, 30:3
format [1] - 23:3
forms [10] - 9:25,
10:1, 10:2, 10:3,
12:15, 17:3, 17:6,
19:6, 20:19, 20:21
Fort [1] - 1:23
forth [1] - 3:11
fourth [1] - 15:21
FPR [2] - 2:2, 31:7
Frank [1] - 27:23
frequent [1] - 28:4
FROM [1] - 1:10
front [1] - 6:8
Ft [1] - 1:16
G
G-1 [1] - 15:18
generally [2] - 4:20,
12:14
Government [3] -
3:3, 18:16, 18:24
Government's [20] -
5:23, 6:1, 6:22, 7:1,
11:24, 12:7, 12:8,
12:9, 12:12, 12:23,
13:11, 13:20, 14:6,
17:9, 17:20, 17:21,
17:22, 17:23, 17:25,
27:3
guidelines [1] -
16:18
gun [2] - 24:23, 25:3
H
H-E-L-Y [1] - 3:13
hand [1] - 25:5
handful [1] - 21:18
handling [1] - 24:19
head [1] - 29:21
hear [2] - 29:7, 29:10
heard [6] - 25:19,
28:20, 29:14, 29:19,
30:1, 30:4
held [1] - 8:18
Hello [1] - 21:10
help [1] - 16:18
Hely [11] - 3:3, 3:13,
3:19, 6:8, 7:16, 12:11,
14:20, 15:12, 17:25,
20:18, 21:10
HELY [3] - 1:10,
2:11, 3:5
hereby [1] - 31:3
higher [1] - 23:17
higher-ranking [1] -
23:17
highlight [2] - 7:16,
15:13
highlighted [2] -
12:24, 14:7
hire [3] - 5:6, 7:22,
8:9
hired [3] - 8:12,
21:12, 21:15
history [4] - 4:5,
6:15, 6:16, 7:19
hold [1] - 4:1
holding [1] - 4:11
Holmes [2] - 27:10,
27:23
Honor [19] - 3:3,
5:23, 6:6, 6:21, 6:24,
7:3, 7:14, 11:23, 12:2,
17:8, 17:12, 17:16,
20:14, 21:2, 21:5,
26:1, 28:15, 30:7,
30:10
HONORABLE [1] -
1:11
hours [3] - 14:12,
15:1, 26:9
HR [2] - 5:18, 9:24
huge [1] - 22:12
Human [1] - 3:20
human [7] - 4:10,
5:6, 5:9, 8:14, 28:23,
29:7, 29:19
I
i.e [1] - 16:11
ID [3] - 7:22, 7:23,
8:2
identification [2] -
5:24, 11:23
Identification [1] -
6:2
identified [1] - 6:22
illegal [1] - 26:7
imagine [2] - 21:21,
24:19
impact [1] - 13:14
implied [1] - 15:7
importance [2] -
24:16, 25:13
important [2] -
24:13, 24:15
improper [1] - 26:7
IN [1] - 7:12
inappropriate [1] -
28:12
include [2] - 4:15,
19:15
including [1] - 15:2
indicate [1] - 8:8
individual [1] - 5:20
informally [1] - 25:6
Informant [1] - 5:2
information [5] -
7:21, 9:20, 9:21, 16:3,
28:22
informed [3] - 11:5,
11:7, 24:3
instance [3] - 7:7,
24:2, 24:22
instead [1] - 22:15
interact [1] - 24:6
International [1] -
8:21
involved [1] - 9:24
issuance [1] - 11:2
issues [1] - 24:7
J
JOANA [3] - 1:10,
2:11, 3:5
Joana [2] - 3:3, 3:13
job [3] - 8:11, 8:17,
24:2
JONES [1] - 1:14
JUDGE [1] - 1:11
June [3] - 1:5, 8:10,
21:12
jury [7] - 3:1, 7:2,
9:16, 13:2, 14:7, 16:8,
19:10
JURY [1] - 1:10
K
keep [1] - 4:13
Keller [3] - 18:9,
18:23, 19:5
kept [1] - 5:16
kinds [1] - 24:10
knowledge [1] - 8:14
Kuker [1] - 27:10
L
landscaper [1] -
23:11
landscapers [1] -
28:9
lapel [1] - 21:25
large [1] - 22:11
last [1] - 3:12
Lauderdale [2] -
1:16, 1:23
lavalliere [1] - 22:2
Law [3] - 1:22, 8:13
law [5] - 8:15, 8:19,
15:5, 15:7, 28:5
lawn [1] - 16:11
left [2] - 3:10, 7:24
legislative [1] - 23:3
legitimate [2] -
14:10, 25:23
letters [1] - 15:22
level [1] - 25:12
levels [1] - 24:16
licenses [1] - 19:19
lieutenant [1] - 23:21
Lieutenant [3] - 27:9,
27:10, 27:22
line [2] - 8:8
lines [1] - 8:17
locate [1] - 17:3
location [1] - 8:23
look [1] - 27:8
looking [2] - 7:18,
8:7
looks [3] - 27:8,
27:11, 27:22
LOVE [21] - 1:18,
3:3, 3:16, 5:23, 6:4,
6:6, 6:7, 6:21, 7:2,
7:14, 7:15, 11:23,
12:10, 17:8, 17:15,
17:24, 20:14, 20:17,
21:2, 30:6, 30:10
Love [1] - 2:12
M
Ma'am [1] - 30:12
maintain [4] - 4:18,
7:5, 9:2, 19:18
3
maintained [4] - 4:8,
5:2, 6:18, 11:18
maintaining [2] - 4:5,
4:6
Major [1] - 27:10
major [1] - 27:23
management [1] -
14:13
manager [1] - 4:2
managing [1] - 4:4
manual [9] - 4:24,
5:4, 5:7, 8:24, 9:9,
12:20, 14:3, 19:25,
21:15
manuals [2] - 4:18,
4:21
mark [1] - 5:24
marked [2] - 6:1,
17:8
matter [1] - 31:5
mean [2] - 13:5,
16:15
members [2] - 14:23,
15:2
mentioned [1] -
18:12
MIAMI [1] - 1:2
Miami [6] - 1:4, 1:19,
2:4, 2:4, 31:9, 31:10
mic [1] - 21:25
microphone [4] -
3:10, 21:25, 22:2
might [4] - 23:20,
26:15, 26:22, 29:3
miss [1] - 6:8
missing [1] - 27:23
moment [1] - 20:14
morning [5] - 3:17,
3:18, 21:8, 21:9,
21:11
most [1] - 8:5
motion [1] - 7:5
move [5] - 3:10,
6:21, 11:25, 17:10,
26:5
moving [8] - 8:17,
13:12, 13:20, 15:11,
15:21, 16:12, 18:16,
18:24
MR [34] - 3:3, 3:16,
5:23, 6:4, 6:6, 6:7,
6:21, 6:24, 7:2, 7:3,
7:14, 7:15, 11:23,
12:2, 12:10, 17:8,
17:12, 17:15, 17:16,
17:24, 20:14, 20:17,
21:2, 21:5, 21:7, 22:1,
22:3, 22:5, 26:3, 26:4,
28:15, 28:18, 30:6,
30:10
Case 0:23-cr-60170-RNS Document 109 Entered on FLSD Docket 08/09/2024 Page 34 of 36
must [3] - 20:4,
24:20, 29:9
N
name [3] - 3:12, 18:9
names [1] - 27:8
necessarily [1] -
26:13
need [11] - 7:3, 9:12,
10:6, 11:1, 11:8, 11:9,
15:24, 16:19, 16:23,
21:25, 25:11
needed [1] - 13:6
needs [3] - 9:23,
10:9, 25:10
never [1] - 30:3
new [11] - 4:4, 5:6,
10:8, 10:9, 11:2,
13:16, 13:17, 13:24,
13:25, 21:14
new-hire [1] - 5:6
next [3] - 10:14,
13:8, 26:16
NO [1] - 1:2
nonprofit [2] - 15:4,
19:16
normal [1] - 14:12
North [2] - 2:4, 31:9
Note [1] - 16:7
note [1] - 16:9
nothing [2] - 26:7,
28:12
number [12] - 7:22,
7:23, 8:2, 15:18,
15:20, 15:22, 16:4,
19:13, 20:5, 20:10,
22:8, 22:20
O
object [3] - 7:7, 12:3,
17:17
objection [6] - 6:24,
7:6, 7:9, 12:6, 17:17,
17:18
objections [1] - 12:3
obtain [1] - 19:18
occurred [1] - 8:25
OF [3] - 1:1, 1:4, 1:10
Off-Duty [1] - 14:8
off-duty [33] - 9:3,
9:5, 9:6, 9:10, 9:12,
9:17, 9:19, 12:20,
14:2, 14:21, 15:9,
15:15, 15:19, 16:2,
16:3, 16:9, 16:16,
16:19, 16:22, 17:3,
17:6, 18:4, 18:7,
19:14, 20:4, 20:7,
20:9, 20:18, 20:21,
23:11, 26:9, 28:5
office [1] - 29:12
Office [9] - 1:18,
3:20, 3:22, 5:6, 5:7,
9:2, 9:8, 14:11, 15:2
officer [3] - 8:14,
8:15, 24:22
officers [1] - 28:5
Offices [1] - 1:22
Official [1] - 31:8
official [1] - 2:3
often [1] - 10:24
on-boarded [1] - 5:5
on-boarding [1] - 4:4
once [1] - 20:4
one [9] - 7:25, 10:14,
25:2, 26:11, 27:9,
27:22, 29:9, 29:16
ongoing [1] - 16:15
opportunity [3] -
6:11, 12:11, 17:1
opposed [1] - 25:18
organized [1] - 8:4
outlined [3] - 9:20,
19:13, 19:24
outside [9] - 9:6, 9:7,
12:15, 14:10, 14:25,
20:13, 26:9, 26:22,
28:13
overrule [2] - 7:8,
17:18
overtime [1] - 14:12
P
P.A [1] - 1:22
page [4] - 13:12,
15:21, 15:22, 16:12
Page [8] - 8:7, 12:23,
13:21, 14:6, 14:18,
15:12, 15:13, 18:13
Pages [1] - 1:8
PANEL [1] - 7:12
paperwork [1] - 4:7
part [1] - 27:14
part-time [1] - 27:14
particular [2] - 9:22,
29:25
Partners [3] - 18:9,
18:23, 19:5
patrol [2] - 23:23,
24:22
payroll [1] - 4:5
people [6] - 22:14,
24:3, 26:25, 27:13,
28:1, 28:5
per [1] - 16:23
perform [1] - 20:13
performing [2] - 9:7,
16:5
permit [2] - 14:9,
14:13
person [3] - 23:17,
26:8, 29:2
person's [1] - 24:2
personal [1] - 4:13
personnel [9] - 4:5,
4:6, 5:16, 5:22, 6:19,
10:5, 11:19, 17:1,
20:19
pertain [3] - 15:14,
18:10, 18:20
place [2] - 10:5,
14:14
Plaintiff [1] - 1:5
PLAINTIFF [1] - 1:14
plumbers [1] - 28:9
plumbing [1] - 16:11
Polan [2] - 27:10,
27:22
policies [11] - 4:18,
4:20, 4:22, 5:14, 5:16,
9:9, 19:24, 21:18,
22:6, 22:20, 24:13
policy [36] - 5:7, 9:2,
9:10, 10:16, 10:22,
10:25, 11:2, 11:3,
11:9, 11:10, 12:20,
12:21, 12:25, 13:6,
14:3, 14:9, 14:15,
14:17, 14:22, 14:24,
16:23, 16:24, 19:9,
19:25, 21:15, 22:22,
22:25, 23:1, 23:10,
24:13, 25:10, 25:22,
26:18, 26:19, 29:3
Pollack [1] - 27:9
portion [2] - 14:2,
25:22
portions [1] - 7:16
position [2] - 4:1,
8:11
positions [1] - 24:1
powers [1] - 15:6
present [1] - 7:2
previous [2] - 13:14,
17:10
previously [6] - 6:22,
7:4, 7:9, 12:3, 17:16,
27:2
print [2] - 9:18, 22:9
printing [1] - 22:16
private [2] - 15:3,
19:16
privilege [1] - 19:14
procedure [2] - 4:18,
4:20
procedures [2] -
5:15, 9:9
proceedings [2] -
3:1, 31:4
process [6] - 9:16,
9:24, 18:12, 18:14,
29:17, 29:24
processing [1] - 4:7
Professional [1] -
14:16
prosecutor [1] -
25:21
provide [2] - 5:4,
15:7
provision [1] - 16:13
public [4] - 15:3,
19:16, 22:14, 22:18
pull [1] - 3:9
punished [1] - 26:13
purpose [1] - 14:21
purposes [1] - 14:24
put [1] - 23:2
Q
qualified [1] - 24:24
qualifies [1] - 16:22
questions [3] -
18:17, 21:2, 21:11
R
ranking [1] - 23:17
read [6] - 14:7,
14:23, 16:8, 19:10,
19:24, 23:6
ready [1] - 3:11
real [2] - 15:7, 28:1
realtor [2] - 23:11,
27:14
realtors [1] - 28:9
Realty [3] - 18:9,
18:23, 19:5
reason [2] - 19:23,
29:2
receipt [1] - 23:7
receive [6] - 10:1,
10:2, 10:3, 11:8,
11:12, 20:18
received [11] - 6:25,
7:1, 11:10, 12:7, 12:8,
12:9, 17:20, 17:21,
17:22, 17:23, 21:15
recent [1] - 8:5
recognize [4] - 6:8,
12:17, 18:1, 27:19
record [1] - 5:20
records [6] - 4:10,
4:13, 5:16, 7:5, 22:14,
22:18
Red [1] - 2:10
redirect [1] - 30:9
4
refer [5] - 8:22, 8:24,
14:20, 14:25, 16:13
referred [3] - 3:24,
9:10, 15:16
referring [3] - 17:14,
18:14, 19:8
regarding [1] - 9:3
regulation [3] -
22:22, 24:20, 26:20
regulations [7] -
22:6, 22:15, 24:11,
24:15, 25:8, 25:13
relate [3] - 13:2,
13:23, 20:11
remember [1] - 25:24
renew [4] - 7:4, 10:6,
12:2, 16:16
renewal [1] - 17:16
report [5] - 6:15,
6:16, 6:18, 7:19, 8:4
REPORTED [1] - 2:1
Reporter [2] - 2:3,
31:8
reprimanded [1] -
26:15
request [8] - 15:15,
15:20, 16:10, 19:11,
19:22, 20:2, 20:7,
22:14
requesting [1] - 16:2
require [2] - 5:10,
5:16
requirements [2] -
14:14, 14:17
rescind [2] - 13:3,
13:24
rescinding [1] -
13:17
reserves [1] - 19:21
resource [2] - 4:10,
8:14
resources [4] - 5:6,
28:23, 29:7, 29:20
Resources [2] -
3:20, 5:9
responsibilities [3] -
4:3, 9:7, 15:1
responsible [2] -
4:22, 14:16
restrictions [1] -
14:14
result [2] - 4:11, 20:6
review [11] - 5:3,
6:11, 9:25, 10:25,
11:9, 12:11, 13:3,
13:5, 13:16, 13:24,
17:1
reviewed [4] - 11:11,
11:16, 13:6, 27:13
reviewing [1] - 13:22
Case 0:23-cr-60170-RNS Document 109 Entered on FLSD Docket 08/09/2024 Page 35 of 36
reviews [1] - 5:6
revised [2] - 13:3,
13:9
revision [2] - 13:16,
13:24
revisions [2] - 22:21,
22:22
revocation [1] - 20:7
revoke [1] - 19:22
rights [1] - 14:13
road [2] - 23:23, 25:2
role [3] - 4:3, 4:8,
4:11
roles [1] - 24:1
RONALD [1] - 1:11
RP [2] - 15:20, 20:5
RP45 [1] - 20:10
RPR [2] - 2:2, 31:7
S
safe [1] - 24:19
safety [1] - 25:9
saw [1] - 22:20
schedule [1] - 19:13
SCOLA [1] - 1:11
scope [2] - 14:10,
15:1
screens [1] - 6:3
seated [1] - 3:9
second [1] - 28:15
Section [4] - 14:5,
15:10, 15:11, 19:25
section [2] - 14:7,
14:20
see [5] - 7:11, 13:1,
13:8, 23:3, 27:4
seek [1] - 9:12
self [1] - 16:9
self-employed [1] -
16:9
separate [1] - 16:10
separates [1] - 4:7
sergeant [7] - 23:15,
23:20, 23:24, 24:2,
24:6, 25:6
Sergeant [3] - 27:11,
27:23, 27:24
service [1] - 16:11
severely [1] - 26:14
SHARON [2] - 2:2,
31:7
sharon_pellvelazco
@flsd.uscourts.gov
[1] - 2:5
Sheriff [1] - 8:13
sheriff [4] - 8:15,
8:19, 14:14, 19:21
Sheriff's [10] - 3:20,
3:22, 5:6, 5:7, 9:2,
9:8, 12:20, 14:11,
15:2, 19:25
sheriff-daily [1] -
8:19
sheriffs [2] - 4:16,
15:5
show [1] - 25:25
showed [1] - 25:22
showing [1] - 27:2
side [1] - 28:9
sign [4] - 5:14,
11:17, 21:15, 23:8
significant [1] - 14:1
SILBER [15] - 1:21,
6:24, 7:3, 12:2, 17:12,
17:16, 21:5, 21:7,
22:1, 22:3, 22:5, 26:3,
26:4, 28:15, 28:18
Silber [3] - 1:22,
2:12, 21:24
silberlaw@gmail.
com [1] - 1:23
similar [1] - 13:13
single [1] - 25:2
sit [1] - 19:15
someone [2] - 23:14,
29:24
sorry [3] - 17:12,
22:1, 22:20
sort [1] - 5:11
South [1] - 1:22
SOUTHERN [1] - 1:1
speaking [2] - 4:20,
12:14
specifically [1] - 5:8
spell [1] - 3:12
standards [1] - 14:13
Standards [1] -
14:16
start [2] - 9:14, 10:14
state [1] - 19:19
States [2] - 2:3, 31:8
STATES [3] - 1:1,
1:4, 1:11
Statute [1] - 14:12
STENOGRAPHICA
LLY [1] - 2:1
streets [1] - 24:23
strictly [1] - 24:11
submit [5] - 20:4,
23:12, 25:17, 26:23,
28:21
subsection [3] -
14:5, 14:19, 15:13
subsectionn [1] -
16:12
suggest [1] - 25:11
Suite [1] - 1:15
sunset [1] - 16:13
sunsets [1] - 10:7
supervisor [2] -
16:23, 23:19
supervisory [1] -
24:1
suspend [1] - 19:22
suspended [3] -
28:24, 29:15, 30:2
SW [3] - 18:9, 18:23,
19:5
sworn [4] - 3:6, 8:15,
14:11, 15:5
T
telephone [2] - 16:4,
19:12
terminated [5] -
20:4, 28:24, 29:2,
29:5, 30:2
termination [5] -
20:5, 20:9, 20:19,
28:25, 29:1
terms [2] - 23:9, 24:1
testified [1] - 3:7
testifying [2] - 6:12,
16:25
testimony [2] - 1:10,
22:21
THE [23] - 1:11, 1:14,
1:21, 3:8, 3:9, 3:13,
3:14, 6:3, 6:5, 6:25,
7:8, 7:13, 12:5, 17:18,
20:16, 21:3, 21:24,
22:2, 22:4, 26:2,
28:17, 30:8, 30:11
themselves [1] -
14:9
Thereupon [1] - 3:4
three [2] - 12:14,
13:1
throughout [1] - 4:5
today [5] - 6:12,
12:12, 16:25, 21:10,
21:18
top [7] - 7:17, 7:24,
8:6, 14:6, 15:21,
15:22, 29:21
training [5] - 5:4, 5:8,
5:10, 8:24, 25:1
transcription [1] -
31:4
TREVOR [1] - 1:14
trevor.jones@
usdoj.gov [1] - 1:16
trial [1] - 3:1
TRIAL [1] - 1:10
trouble [1] - 29:8
true [1] - 28:4
turn [1] - 26:1
two [1] - 8:2
type [3] - 9:21, 16:5,
19:13
U
ultimately [1] - 4:6
under [2] - 15:18,
24:3
undertaken [1] -
14:25
unimportant [1] -
24:14
UNISON [1] - 7:12
united [1] - 2:3
UNITED [3] - 1:1,
1:4, 1:11
United [1] - 31:8
unusual [2] - 29:22,
30:3
up [6] - 3:9, 8:5, 8:6,
8:17, 24:7, 25:25
upcoming [1] - 10:9
update [1] - 11:9
updated [4] - 10:22,
11:1, 11:2
US [1] - 1:18
USAO [1] - 1:14
V
valid [1] - 19:12
VELAZCO [2] - 2:2,
31:7
Velazco [1] - 31:7
violation [3] - 26:18,
26:19, 26:20
violations [1] - 29:3
vs [1] - 1:6
W
wants [1] - 9:17
website [2] - 5:2,
23:2
whereas [1] - 24:12
Williams [3] - 18:9,
18:23, 19:5
Witness [1] - 30:13
WITNESS [3] - 2:10,
3:8, 3:13
witness [3] - 3:6,
5:25, 30:7
Y
YAACOV [1] - 1:21
year [14] - 8:25, 10:7,
10:9, 10:11, 10:12,
10:14, 16:16, 16:17,
5
18:10, 18:20, 19:2,
20:3, 26:11, 29:16
years [9] - 3:23, 4:9,
10:20, 17:6, 26:12,
26:23, 29:4, 29:14,
29:16
yourself [1] - 3:9
Case 0:23-cr-60170-RNS Document 109 Entered on FLSD Docket 08/09/2024 Page 36 of 36File and source
- File
- gov.uscourts.flsd.654235.109.0.pdf
- Size
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- SHA-256
- cb064a3c75b3b61f5f644ceac60fc24650fe28dbef9194a13e9a6b7f8f98cc38
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