Court filing
Transcript of jury trial excerpt Closing Arguments of Counsel as to Alexandra — USA v. Alexandra Acosta (Dkt. 111, 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. 111 · 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 5, 2024
vs.
ALEXANDRA ACOSTA,
Defendant. Pages 1 to 32
______________________________________________________________
EXCERPT FROM JURY TRIAL
(CLOSING ARGUMENTS OF MR. JONES AND MR. SILBER)
BEFORE THE HONORABLE ROBERT 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 111 Entered on FLSD Docket 08/09/2024 Page 1 of 38
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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
PAGE
Closing Argument by Mr. Jones
3
Closing Argument by Mr. Silber
14
Rebuttal by Mr. Jones
28
_ _ _
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(The following is an excerpt from the jury trial proceedings:)
* * * * *
MR. JONES: Thank you, your Honor.
Quid pro quo.
You heard me say it during the trial. It is this for
that.
In this case, Ms. Acosta is charged with making false
statements to the SBA and conspiring with Vilsaint St. Louis to
do it.
The evidence that we have introduced today and
yesterday, and the day before -- I apologize. We have
demonstrated that the circumstances of this application are
completely unexplainable about the matters that are contained
in that PPP loan, the false statements, and the way that the
funds were used and forgiven.
Now, as a housekeeping matter, we have already
introduced a stipulation that there is no dispute as to the
interstate wire.
That applies to Count 4. That is wire fraud. The
parties agree that this -- that element of the case has been
met. I don't believe there is any dispute here between the
parties that there was false statements.
And, in these PPP loans; correct, I think we are all on
the same page, that the number 8,300 and some-odd dollars on
average monthly payroll, that is false; that the funds were
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going to be used for certain expenses, false; the fact that
Ms. Alex Acosta potentially signed it could be false. So, what
are we talking about now?
Knowledge.
Did Ms. Acosta know -- did the defendant know at the
time exactly what they were getting into on February 1st, when
her and St. Louis are in the same room, during the same period
when the application was created, and they submit it to the
SBA, getting a 20 thousand dollars PPP loan?
Nobody was in the room that day besides those two.
But, as the Court has instructed you, circumstantial
evidence must be weighed equally as much as direct evidence.
And, I would even say that we have direct evidence in this case
by omission. So, let's talk about the circumstances that show
that the defendant knew that the statements they made were
false or deliberately ignored it.
We start in December 2017. We have walked through this
today. We walked through it yesterday. We saw the report of
the IRS examiner documenting, realtime, the statements of
Ms. Acosta.
And, in those statements, the defendant makes clear her
interactions with St. Louis. She makes it very clear that she
goes in and sits with him. She goes through these records.
That is her position when she goes in there that day.
She tells him -- she tells that tax preparer or the tax
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auditor, "I am involved. I have seen the numbers. They come
from my head. They come from my head. And, I sat with him."
So, how do we know that is an accurate statement?
First, it was the first thing that she said. Okay?
Memory doesn't get better with age. It was exactly the
first time she spoke about it. It was fresh in her mind. It
was 2021. This was for the 2019 year, 2018 year.
And, she knew that she had gone in that day for two of
those years, and sat with him to get lower expenses calculated
for her tax return.
How else do we know that that was an accurate
statement?
We have the taxpayer questionnaires that St. Louis
submitted on her behalf in response to the audit. It shows the
date, February 4, 2020. She signed that in his office. It is
not a digital signature. It is not asterisks. It is a wet
signature. And, Ms. Acosta admits that is her signature.
And, that is the same day that her tax records were
submitted to the IRS. So, we know that that is actually an
accurate statement in that first report from the auditor.
But, as we know now, the story has changed, stories
changed to fit the circumstances, to pivot out of something.
That's the defendant. That is who testified today. A new
story, different from the one previously made.
It is only after she -- let's talk about January 21st.
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Right?
The IRS sends this examination report, changes.
It details, you saw, it details the expenses. They are
not hidden. They are large, too, and it says both, 2018 and
2019.
Ms. Acosta got that. Her tax preparer got it. They
saw it. They met together on February 1st. And, that's not
all. They actually had a call with the IRS about those charges
that day.
And, this wasn't over the course of seven hours. This
was during the period in which she had come into the office,
during her lunch break, spent about an hour there, probably,
and sat with him.
They had a call with the auditor, and then boom, the
application for PPP loan was created around noon that same day.
You see a G-mail account change, the password changes,
and then you see a new login from Victory Tax, or it says from
a new device, purportedly Victory Tax, based on IP information
we have, right?
And, within that period, the application was created.
It is all right, sent up. The numbers are in there, at that
point.
What happens later is some -- the documents get
submitted in support of the extra -- the IRS, the fake IRS
forms. Right?
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And, this whole time, the correspondence is going to
the defendant. It is not going to Vilsaint St. Louis.
The defendant testified he would have done this to make
up for the tax issue.
Okay, let's think about that.
How do you make up for something to someone without
telling them about it?
How do you get credit for fixing an issue that you
believe you caused, without letting the other person know
exactly what you did to fix it?
It doesn't make any sense.
And, it is the first time she said it out loud.
And, in a situation where it mattered, Ms. Acosta came
into the U.S. Attorney's Office. You heard the testimony.
This is at a time where the Government had the IRS records for
2018, 2019, 2020. No tax audit. That was not part of the
investigation yet. Vilsaint St. Louis was not part of the
investigation. Agent Johnson testified about that.
After meeting with Ms. Acosta, during the meeting with
Ms. Acosta, she does not disclose anything about this timeline,
about Vilsaint St. Louis and how she was being audited, and he
caused these problems with her taxes, and that this somehow
created a reason for him to inflate these things, and, here is
why. This is why this all happened.
No, not at all. She didn't mention it at all.
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The truth, the whole truth, the whole truth, nothing
but the truth.
That is incredibly telling about the state of mind of
Ms. Acosta. And, that state of mind just reflects upon the
intent, the knowledge at the time of what was right and what
was wrong.
And, she pivots based on the information that is
available to the person on the other side. That's what the
defendant has shown she does.
When the tax auditor told her that "You can get out of
doing it by writing a letter blaming him," that is what she
did. She changed her story. She was working that case up.
She was trying to get the emails.
Look. What you will see and what you have seen is that
there is correspondence about this tax case with her between
her and St. Louis.
She is active. She is trying to get this down. She is
not blaming him for anything. She is not saying, "How did
these numbers get here?"
She is not doing that at all.
She is actively working to get -- to get it down -- she
is bugging him to do it. She is sending him records that
purportedly would substantiate these losses, these expenses we
are talking about. But, still, you can even see in the IRS
records they couldn't find anything there of support, no
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annotation of anything.
And, so, when she has the opportunity to pivot, and
save herself from having to pay a certain amount of money, she
changes her story. She says, "Oh, second thought, here is what
happened. I never go in. Or, I didn't go in, in 2018. Those
two years, I didn't go in, actually; and, I don't know where he
got those numbers."
Now, again, we already talked about the fact that she
was there doing her 2019 returns because we have that
signature. We knew that was actually false. We knew that is
inconsistent with the record.
And, it is these inconsistencies that keep arising at
opportune times for Ms. Acosta that show you her knowledge and
intent.
The BSO policy -- nobody is arguing that not reporting
to the BSO policy or filling out the forms is the crime of the
century. It is not a crime at all. It is probably not even a
policy violation. The point is this: It is how she saw
herself at that time, as a worker.
She knows it is a side hustle. Right?
And, this is 2021 PPP fraud. This isn't like the
beginning where no one knew about what the program was. In
fact, she came in here and testified she didn't know what the
program was until the day in February 2021. It is up to you to
believe it.
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But, Agent Johnson testified it was permeating federal
law enforcement. They knew about it. They knew what PPP fraud
was. People knew about the program by then.
And, Defendant Acosta's inability to keep a consistent
story that makes sense is exactly why we know that she knew
what Vilsaint was doing.
Her own story now makes no sense when you take a step
back and think. An individual who knows your -- a law
enforcement, is -- is going to send -- make sure that all the
evidence of the crime that they are committing for you, with no
reason, without your knowledge, is going to use your email
address, and they don't want anything for it. They are just
happy that you get an extra $20,000. Really happy for you.
"You don't even know that I did that for you. In fact, I
committed a felony to do it, and I falsified documents. I
spent the time to do that for you, and you never even have to
know."
Pure gratis.
It is illogical.
It is -- evidence of a felony is sitting in
Ms. Acosta's email box as of February 3rd, 2021. First, the
attachment to the document, it says, "DocuSign," right -- right
there. Big sign.
And, then, it is in the attachment of the application,
with the first part of it shows this income amount of $8,000.
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It is in the first section. She knows she was not entitled to
20,180 based on the 2019 income of $13,000. She knew that.
And, that is why she didn't share that information with anyone
she cared about.
She -- in fact, not only did she not share it with
people she loved, she deliberately hid it. She took
affirmative steps to hide it from her wife.
Can you believe defendant Acosta when she is testifying
that she had no idea what was going on, this was all such a
surprise?
When her wife can't even really trust what she is doing
because she doesn't disclose significant events -- they are
not -- this is not buying an energy drink six times a week.
These were two massive life events, in theory; you have a tax
audit, which isn't a small deal. It is big. And, you hide
that from your spouse.
And then you hide what is purportedly a good thing from
your spouse. If you listen to her theory that somehow she was
entitled to this, why wouldn't you tell your wife?
It is $20,000.
This is not a girlfriend. It is not an acquaintance.
We are talking about her mother didn't know she did it, and her
wife. That is how you know that she knew.
That's how you know that Vilsaint knew that she knew,
and that is how you know that she knew Vilsaint knew.
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They are together.
When she asked him to be quiet, "Got it."
No problem.
Her wife goes in there to do her taxes.
She is being audited with this guy, the St. Louis guy.
And, her wife is heading there to do her taxes, and she doesn't
want her wife to know about that. She doesn't want her wife to
know that she is walking into a potential buzz saw, to check
her 2018, and to check her wife's 2018 and 2019 tax returns.
And, the reason why is because she knows what she is doing.
She knows, and that's why she wants him to do a lot of this,
too.
She pushes the G-mail, sure.
"Here you go. Do what you got to do. I'm not going to
look."
20 grand is perfect.
Deliberate ignorance?
Yes.
There is -- as you walk through the evidence that will
go back with you, it is not a massive amount of data within a
very small period of time. Remember, we have circumstantial
evidence of getting into the state of mind of defendant Acosta;
the timing of when the application was created, the timing of
when the forgiveness application was created, where she was
during that period, she was with him when that loan was
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created, when that loan application was created.
Each one of these pieces carries the burden of proof
beyond a reasonable doubt; that she knew, Counts 2 and 3
require knowledge and a false statement.
Again, we all agree, false statement.
The only remaining element is knowledge.
She knew.
The conspiracy, willfully joined in the conspiracy.
You have heard an instruction about good faith.
Reliance is a defense to willfulness. When you willfully agree
to have somebody submit a PPP loan application for you
containing false information, that is a conspiracy to make a
false statement.
And, that's what happened here. That's what happened
on that day between the time that she left the airport, went to
Victory Tax. You saw Victory Tax. She went to Victory Tax,
spent her lunch break there.
Agreed, it doesn't have to be some written-out plan for
conspiracy. It is an understanding. And, she doesn't have to
do every step. In fact, that is how she prefers it. Somebody
else has to do it. Somebody else has to do that work.
But, always keep asking yourself why would anybody take
those affirmative felonious steps without any benefit?
What is the benefit?
Why would St. Louis do this at all?
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They say, "Oh, because you have referrals."
That's fine. But, he would have to -- she would have
to know that she is getting benefit to keep the referrals
coming. There is always a reason for that.
There is no dispute it was created in Victory Tax. The
IP address is what it is. The Government is not hiding
anything about that. We understand what the facts are here.
We understand the circumstances. We have all seen it;
misstatements by the defendant, omission, material omissions,
even after the case started.
Because she knows. She knows that the evidence shows
she is guilty.
THE COURT: You have used 20 minutes.
MR. JONES: Thank you, your Honor. I am going to cede
my time, or hold my time.
THE COURT: Okay.
MR. JONES: Thank you.
THE COURT: Mr. Silber?
MR. SILBER: Yes, your Honor.
73.56.139.104.
73.56.139.104.
Your Honor, would you please turn on the overhead
projector?
73.56.139.104.
73.56.139.104.
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We live in the year 2024. We are -- digital evidence
is everywhere. It is following us right now. It is in our
iPhones, on our computers, and it is watching, and it is
recording. And, it is paying attention. And, two, three years
later, we can figure out the truth.
February 1st, 2021; 73.56.139.104.
February 2nd, 2021; 73.56.139.104.
February 3rd, the date the loan was approved,
73.56.139.104.
Here is the loan application. As you can see, it is
DocuSigned. And, we know it is DocuSigned because it has those
little DocuSign symbols. Do you see the DS and the little
sideways U?
Look at all these initials here and there.
There it is. DocuSign.
Alex Acosta, Alex Acosta. But, that pesky, pestering
digital evidence at the scene, 73.56.139.104, will not be a
surprise to anyone.
You have Vilsaint St. Louis, Victory Taxes@gmail.com,
December 21, 2020, before any of this happened. 73.56.139.104.
Let's talk about the forgiveness application. Do you
remember the lady with the pink hair?
What did she tell us about this signature here?
We can see this is the forgiveness application.
No. 1, she confirmed it is a digital signature. That
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is not a handwritten signature. It is not the signature we saw
on deputy Acosta's checks or on her bank card with the big fat
A's. That is a digital signature. But, that's not all. She
sat there and she told us she couldn't tell us who put that
there. You know why?
Because it is not authenticated.
It is not like this document that has a DocuSign
envelope ID, F616B. F616B. You can take the forgiveness
application and dump it because there is no evidence here.
When you go back in the jury room, take one copy of the
jury instructions, and the first thing that you ought to do is
circle every single time you see the words "intent",
"willfulness", and two very important words, "only if."
"Only if." And, remember another thing. The burden of
proof is exclusively on the people at this table. That's how
it works in America.
The accused has no burden. She does not need to prove
anything. And, here is the problem with this case. This has a
very real reasonable doubt. There is a major question here.
The evidence has shown us that Vilsaint St. Louis was the one
who submitted these applications.
And, when we take it in the context of the IRS audit,
they got this backwards. They got it totally backwards. She
is not the one who is hurting for money, finding a way to solve
her problems.
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And, how do we know that?
Two ways; one, she paid for the audit tax liability out
of her paycheck. That is irrefutable evidence. It came out of
her paycheck in full. And, it was something that was
determined after the fact. It didn't happen at this time. It
wasn't an event up in the air. There was just discussions
about how it would end. The letter she got said she might even
be due a refund.
And then, of course, let's get to the most important
piece of evidence when it comes to her intentions.
How did she spend the money?
If they put on evidence that there was a check written
to the IRS on February 5th for that amount, then yes. That
would tie it all together. But, it actually shows that there
is a major, major conflict, and the major source of reasonable
doubt why you can't convict her, because she spent the money on
other things. She tried to invest it in Robinhood. Not $1 of
that money went to the IRS. And, this is what is so important
to it. We are not talking about a gap in time. This was
applied for on February 1st. It was approved on February 3rd.
The money was in Robinhood on February 4th. We are talking
about days. Not a year later.
Deputy Acosta has conducted herself like a lady, and
like an honorable officer of the law. When she was in trouble,
just like at the airport, just like getting on SWAT, just like
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all the college grades the Government brought up, how is that
even relevant?
Who cares what she did in college?
Don't tell me because you got an A in your little
Criminal Justice class that you know anything about criminal
justice because you went to college. You can't become a police
officer and get a gun and go arrest people because you studied
a little class in college.
No, it is a very serious thing. You have to be
trained. You have to be certified. You have to do all the
things that a police officer has to do; like any other
professional lawyer or doctor, there are qualifications.
The BSO work evidence also doesn't inform us of
anything. So what, she didn't fill out a form for a couple of
years. She explained it. It was because she was at the same
command during those years. And, she admitted to you she
misunderstood the rule. But, her testimony is consistent with
the evidence because the years that she was at airport command,
she did submit the form. She did submit the form.
That only changed later. It is totally irrelevant
evidence that doesn't tell us anything. It is just an attempt
to make her look bad, like she is not a rule follower.
Let's talk about the IRS evidence.
According to the tax compliance officer -- all those
notes, by the way, with the redactions in the missing
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information that we saw -- okay. What did it say in what was
the end conclusion of this three, four-month investigation?
That they spent so many hours on discussing, that she
didn't violate anything intentionally; that she is a person
that didn't know anything about taxes; that, based on her
statements and all the evidence in the case, there was no
indication of wrongdoing on her part.
The guy with the motive here was Vilsaint St. Louis.
He was the guy who made the mistake on taxes. He was
the guy who double-entered, who didn't even know something as
basic as you can't deduct miles and expenses. He was totally
unqualified.
But, she didn't know that then. And, he kept her in
the dark. He didn't answer her calls. He told her this was a
minimal thing, "It will be over soon. You are not going to owe
any penalties."
And, he -- actually, he was right about that. She
didn't owe any penalties in the end.
But, now, now that she has got access to all these
documents, and in the discovery and the tax records and all
this stuff, fast-forward two years, she has been arrested, she
has been suspended, she is charged with major felonies in
federal court. Now, she understands it. He was covering for
him.
He was covering for him because he made a mistake that
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would potentially cost her $18,000.
And, he kept her in the dark about it. That is why he
had to handle everything. That's why he had to get access to
her email and say, "Oh, yeah. I will take care of it. I will
do everything for you."
And, do you know what that is called?
That is abuse of a position of trust.
A tax preparer may not be a neurosurgeon, but a tax
preparer owes their customers a duty, a fiduciary duty of
candor to protect their personal information.
He was not candid with her. He was misleading to her.
And, this was his attempt to fix these problems. Now, it makes
sense.
But, back then, it wasn't obvious to her.
Deputy Acosta is an exemplary deputy. She is not even
a regular deputy. She is somebody that everything she put her
mind to, and put her effort to, she made sure to accomplish.
Even in math, that she is terrible at, she had to apply herself
harder, and she got a B. Okay?
Which, for her, is a failure.
She is a straight A student. Okay?
She is one of five percent of people that graduated
from SWAT school.
She is the person who protects the president of the
United States at the airport, and other dignitaries. They
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don't just let anybody do that. You have to be vetted and
revetted. You can't even be a regular police officer. You
have to be special.
And, that is also why none of this makes sense.
Because to believe their story, this is what we have to think.
This guy, this tax preparer, he has his law enforcement client
come into his office. Oh, by the way, and her wife also is a
sergeant in a police department.
And, he says, "Hey, no problem. Don't worry about your
taxes. This is what we are going to do. We are going to go
rob a bank."
Is that what he tells the SWAT officer?
Is that the plan?
He didn't tell her that. He didn't tell her that.
That never happened. And, her testimony is irrefuted, totally
irrefuted.
There are no audio recordings of their conversation.
There is no independent witness.
What did I tell you in the opening statements?
90 percent of what you are going to hear, we agree
with.
This whole case comes down to the conversation had
between these two on February 1st. And, there were only two
people present; Deputy Acosta and Vilsaint St. Louis.
And, only those two know what was said.
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And, the problem is this, for the Government --
remember, they have the burden of proof. She has no burden at
all. And, a reasonable doubt is a roadblock to a conviction.
And, this case has real doubt.
You can't convict her with this IP address information
if that is all you have. If that is all you had, that would be
a not guilty verdict because it informs us that he was the one
that submitted everything. That's what it tells us.
Now, good faith, as the judge instructed, is the
defense to Count 1 and Count 4. Okay?
Let's talk about the two in the middle, or false
statements.
A false statement to the SBA. It is a federal crime to
knowingly make any false statement for the purpose of obtaining
a loan from the U.S. Small Business Administration, the SBA, or
for the purpose of influencing the action of the SBA in some
way, in any way.
The defendant can be found guilty of this crime only if
all of the following facts are proved beyond a reasonable
doubt. What is fact No. 1?
The defendant knowingly made a false statement.
That can't be said when you have the evidence that
shows you he is the one that made the false statement. He is
the one that submitted it. That doesn't come back to her
house. It doesn't come back to her phone. It comes back to
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him.
He is the one that submitted it.
And, by the way, let's look at her relationship with
him for a moment. Okay?
This is not a person that she met yesterday. This is
not a guy she Googled and called up, "Hey can you do my taxes,"
and she walks in, "Hey, you know you can get a PPP" --
No. This is a guy she has known since 2014. And, in
the context of their tax preparation, that was the context of
their role. They weren't friends. They are not relatives.
They only encountered each other related to taxes.
And, let's talk about what that means.
How does that work?
Well, what does a person do when they go get their
taxes prepared by somebody?
You take your W-2s, you take your 1099, you bring all
your receipts and you give it to the guy, and what does he do?
He goes on the computer and he starts using whatever
software that he uses, and he fills out the form. He figures
it out.
Just like she is not a lawyer or a physician that needs
to hire those people for those issues, so, too, she needs a tax
preparer. That is his role in this.
Did they sit down together and prepare it together?
Yeah. But, what does that mean?
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That doesn't mean she sat there with him and said, "Oh,
when you put in this field here, put that number, and when you
do this field here, do that number, use this code" -- no.
That is -- that is not what this is.
We know from the interview conducted by the tax
compliance officer that she really had no knowledge of taxes.
She was totally dependent on him. And, if he calculates and
does the thing in the computer and says it comes out to 40
thousand or 20 thousand or whatever it is, okay.
What did the note say?
Well, she had an idea in her head on what her mileage
was. She testified it was based on what her realtor app told
her. Okay?
And, when he said, "Okay, this the number," it made
sense. What more could she do than that?
What else could she do?
The bottom line is this: Like I said in my opening,
she is coming before this Court with honesty and with honor and
with integrity and with dignity. She is not fighting them on
every little thing. She is not thumbing her nose at the
Government and saying, "No, prove your case."
No, she instructed me to sign a stipulation that you
are going to see. Why?
Because we don't need a fight about the things that
don't need to be fought about. She instructed me to admit that
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a loan did exist; to admit that the loan was applied for; to
admit that the forgiveness was applied for.
She admits -- and she admits the numbers were false.
There is no dispute about any of that.
She didn't come in here and thumb her nose, "Prove your
case."
No, she is disputing the one thing that they are
alleging that is totally false, and it is her knowledge and
participation and intent.
And, this SWAT officer that was running four, five
miles a day, just to try out, and who failed the first time
because she didn't make it five feet after a 40-yard haul of a
heavy object, trained again, another four, five miles every
day, to become the first woman to pass a BSO SWAT school. And,
you know what, it is a title she still holds. And, she is also
the only woman on their SWAT team.
I am sorry to have to tell you this, but, someone who
has worked that hard and comes so far and done so much is not
going to throw away their law enforcement career on a stupid
$20,000.
Another thing, I am going to make a comparison.
Let's assume a person is in a little fender-bender at
the Publix parking lot down the street. Someone backs into
your car and they dent it, and they come running out and they
do a, "Oh, sorry, sorry. I didn't mean to do that, it was a
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total accident."
Okay. Well, you go to the other guy and say, "We have
to call the police and make a report."
The person says, "You know what, I don't want to do
that. I don't want to have my insurance involved. I don't
want to have my rates go up. Just give me a day and I will pay
you the damages."
The person agrees, "No problem. Here is my number. No
problem. Call me tomorrow."
The guy shows up with some money, three thousand
dollars for your dent. You have no reason to think this guy is
going to go rob a bank for it. And, that is exactly the
scenario we have here, because while there were questions about
his ability, sure, is he a good accountant?
A good tax preparer?
We can definitely talk about that. But, he was honest
about it. He was honest about it. He admitted to her that he
had made a mistake. And, he minimized the audit consequences
to her.
She never had a reason to question his honesty.
She never had a reason to question his honesty.
And, for her, that means something special because not
only is she law enforcement, she is a SWAT officer, which means
she interacts with some -- what can be very violent people.
She is a person that needs her information protected.
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She is a person that, when she hands a document and said, "Here
is my kid's name. This is where they live. This is where we
rest our head at night," that that is not going to get lost,
misplaced, or end up in the wrong hands.
And, she never had that problem with him. She never
had that problem with him.
She never had an identity theft issue. She never had
an issue with not securing her information. He always made her
feel comfortable.
At the end of the day, a not guilty on all these
charges has to be entered because of these doubts. And,
remember, I want to emphasize a million times over, we do not
need to prove her innocence.
They need to prove she is guilty.
I am merely pointing out why that is not possible.
There are unanswered questions here. There are conflicts in
the evidence.
And, thank God we are here to ask these questions.
Lastly, I would like to say, on behalf of my client,
thank you for your time. Thank you for your attention. Thank
you for listening to everything that was said.
And, your Honor, we appreciate the Court's time as
well. Thank you.
THE COURT: All right. Thank you.
Mr. Jones?
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Do you want either the ELMO or your computer on?
MR. JONES: No, thank you, your Honor.
Conflicts in the evidence, indeed. He talked about it.
We talked about it. She creates the conflicts. The defendant
is the one who can't keep her stories straight.
She is a very intelligent person. She knows what she
was doing then, and she knows what she was doing afterwards to
make it look like she didn't know what she was doing then.
The evidence shows that she will say what is necessary
to fix something. And, she will give the person what they need
to hear. That is what the evidence shows.
Motive. I am still trying to catch up with defendant's
thought process here about motive for St. Louis.
Who got the money?
The defendant.
It went straight to her bank account. She didn't pay
him for it. So, where is the motive there?
And, who commits the felony for free, and without the
other person knowing?
It is just -- it strains credulity.
"No reasonable doubt." It is not "all possible doubt."
You have to use your common sense as jurors. Common sense,
things that you walk around with on a daily basis.
You are making decisions. You drive over train tracks,
you don't see the lights coming, okay, you feel good to drive
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over that train track.
It doesn't mean there is no possibility the train could
be there. You know what, you have a pretty good idea that it
is safe. And, you would drive across that with your kids in
the back. That's what we are talking about. It is not "all
possible doubt."
It is Ms. Acosta and her defense counsel want you to
believe that she walked out one day and got struck by
lightning.
She was on top of the mountain, holding the rod,
telling somebody to get the lightning machine going and then
activate it.
That wasn't what happened. This wasn't a mistake, a
bunch of coincidences that all don't add up.
The amount of things showing the timeline of her
interactions with St. Louis leading up to the audit, leading up
to the PPP loan, leading up to the forgiveness -- it shows that
she does work closely with him. It shows she did interact and
talk with him about the things. She is not a wallflower. She
helps her counsel throughout the whole trial.
She is active. She is smart. She is very smart. She
is engaged. And, she has her hands and fingers in it.
She cannot claim -- you can't just play, take the keys,
go ahead, get me whatever you need. Thanks.
That is not life, and it is certainly not when you have
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the experience and the knowledge base that this defendant has.
Motive.
Defense counsel can talk about St. Louis, some bad guy.
He clearly is involved in this fraud. I didn't choose him.
The Government didn't choose him as our tax preparer. She
chose him as her tax preparer, this guy who is capable of doing
this.
Take a step back and think about that. That is her
person. She has been with him for ten years. Ten years.
Before she became a law enforcement officer, mind you, they
knew each other.
That's the relationship. That's the understanding.
That's how do you know that when she was in there that day,
there was an agreement that she would get this money, that she
would get more than she actually was deserving.
The IP address shows from -- in that place, the
application was created in or around noon. Where was she?
She was not at the airport. She told her commander --
or maybe not her commander, she told her supervisor she was
leaving. She testified that she went to Victory Taxes that
day. That's when it all started.
The fact that she now, and, when she proffered with the
U.S. Attorney's Office, cannot admit that it is crazy
suspicious circumstances to have $20,000 drop out of the sky
from the person who is responsible for getting you -- well,
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purportedly responsible for getting you in tax trouble -- that
doesn't click?
If his motive is to make it right, he is going to have
to let her know he is making it right somehow; otherwise, that
is her money. She would be entitled to it regardless.
You take a step back. The theory is -- it just -- you
cannot wrap your head around it because nobody behaves that
way.
Nobody.
Now, at the end of this, when you go back, you are
going to have a chance to review all this evidence. I want you
to take your time. Read those instructions. Understand the
distinction between some of these counts; conspiracy,
willingness; Counts 2 and 3, the knowledge, deliberate
ignorance; Count 4, the wire fraud and intent to defraud --
these are all different charges.
When you go back there and you take the time to look
over the evidence that is presented to you for the past couple
of days, we are going to ask you to come back with the only
verdict that is consistent with that evidence and the law as it
has been instructed to you, as the verdict of guilty on all
counts; Count 1, conspiracy to defraud the SBA; Count 2, false
statements to the SBA; Count 3, false statements to the SBA,
and, Count 4, wire fraud. Guilty.
Thank you.
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THE COURT: All right. Thank you.
* * * * *
_ _ _
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
9th Floor
Miami, Florida 33128
Case 0:23-cr-60170-RNS Document 111 Entered on FLSD Docket 08/09/2024 Page 32 of 38
$
$13,000 [1] - 11:2
$18,000 [1] - 20:1
$20,000 [4] - 10:13,
11:20, 25:20, 30:24
$8,000 [1] - 10:25
/
/s/Sharon [1] - 32:14
0
0:23-cr-60170-RNS-
1 [1] - 1:2
1
1 [6] - 1:8, 15:25,
17:17, 22:10, 22:20,
31:22
1099 [1] - 23:16
14 [1] - 2:11
1st [5] - 4:6, 6:7,
15:6, 17:20, 21:23
2
2 [3] - 13:3, 31:14,
31:22
20 [4] - 4:9, 12:16,
14:13, 24:9
20,180 [1] - 11:2
2014 [1] - 23:8
2017 [1] - 4:17
2018 [6] - 5:7, 6:4,
7:16, 9:5, 12:9
2019 [6] - 5:7, 6:5,
7:16, 9:9, 11:2, 12:9
2020 [3] - 5:15, 7:16,
15:20
2021 [6] - 5:7, 9:21,
9:24, 10:21, 15:6,
15:7
2024 [3] - 1:5, 15:1,
32:14
21 [1] - 15:20
21st [1] - 5:25
28 [1] - 2:11
2nd [1] - 15:7
3
3 [4] - 2:10, 13:3,
31:14, 31:23
305 [1] - 2:5
32 [1] - 1:8
33128 [2] - 2:4, 32:17
33130 [1] - 1:19
33316 [1] - 1:23
33394 [1] - 1:16
3rd [3] - 10:21, 15:8,
17:20
4
4 [5] - 3:19, 5:15,
22:10, 31:15, 31:24
40 [1] - 24:8
40-yard [1] - 25:12
400 [2] - 2:4, 32:16
4th [1] - 17:21
5
5 [1] - 1:5
500 [1] - 1:15
523-5636 [1] - 2:5
5th [1] - 17:13
7
73.56.139.104 [9] -
14:20, 14:21, 14:24,
14:25, 15:6, 15:7,
15:9, 15:17, 15:20
7th [1] - 1:15
8
8 [1] - 32:14
8,300 [1] - 3:24
9
90 [1] - 21:20
916 [1] - 1:22
9th [1] - 32:17
A
A's [1] - 16:3
ability [1] - 26:14
above-entitled [1] -
32:12
abuse [1] - 20:7
access [2] - 19:19,
20:3
accident [1] - 26:1
accomplish [1] -
20:17
according [1] - 18:24
account [2] - 6:16,
28:16
accountant [1] -
26:14
accurate [4] - 5:3,
5:11, 5:20, 32:11
accused [1] - 16:17
Acosta [19] - 3:7,
4:2, 4:5, 4:20, 5:17,
6:6, 7:13, 7:19, 7:20,
8:4, 9:13, 11:8, 12:22,
15:16, 17:23, 20:15,
21:24, 29:7
ACOSTA [1] - 1:7
Acosta's [3] - 10:4,
10:21, 16:2
acquaintance [1] -
11:21
action [1] - 22:16
activate [1] - 29:12
active [2] - 8:17,
29:21
actively [1] - 8:21
ADAM [1] - 1:18
adam.love@usdoj.
gov [1] - 1:19
add [1] - 29:14
address [4] - 10:12,
14:6, 22:5, 30:16
Administration [1] -
22:15
admit [4] - 24:25,
25:1, 25:2, 30:23
admits [3] - 5:17,
25:3
admitted [2] - 18:16,
26:17
afterwards [1] - 28:7
age [1] - 5:5
Agent [1] - 10:1
agent [1] - 7:18
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agreed [1] - 13:18
agreement [1] -
30:14
agrees [1] - 26:8
ahead [1] - 29:24
air [1] - 17:6
airport [5] - 13:15,
17:25, 18:18, 20:25,
30:18
Alex [3] - 4:2, 15:16
ALEXANDRA [1] -
1:7
alleging [1] - 25:8
America [1] - 16:16
AMERICA [1] - 1:4
amount [5] - 9:3,
10:25, 12:20, 17:13,
29:15
AND [1] - 1:10
Andrews [1] - 1:22
annotation [1] - 9:1
answer [1] - 19:14
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app [1] - 24:12
APPEARANCES [1] -
1:12
application [14] -
3:12, 4:8, 6:15, 6:20,
10:24, 12:23, 12:24,
13:1, 13:11, 15:10,
15:21, 15:24, 16:9,
30:17
applications [1] -
16:21
applied [3] - 17:20,
25:1, 25:2
applies [1] - 3:19
apply [1] - 20:18
appreciate [1] -
27:22
approved [2] - 15:8,
17:20
arguing [1] - 9:15
Argument [2] - 2:10,
2:11
ARGUMENTS [1] -
1:10
arising [1] - 9:12
arrest [1] - 18:7
arrested [1] - 19:21
assume [1] - 25:22
asterisks [1] - 5:16
attachment [2] -
10:22, 10:24
attempt [2] - 18:21,
20:12
attention [2] - 15:4,
27:20
Attorney's [3] - 1:18,
7:14, 30:23
audio [1] - 21:17
audit [7] - 5:14, 7:16,
11:15, 16:22, 17:2,
26:18, 29:16
audited [2] - 7:21,
12:5
auditor [4] - 5:1,
5:20, 6:14, 8:10
August [1] - 32:14
authenticated [1] -
16:6
available [1] - 8:8
Avenue [3] - 1:22,
2:4, 32:16
average [1] - 3:25
B
backs [1] - 25:23
backwards [2] -
16:23
bad [2] - 18:22, 30:3
bank [4] - 16:2,
21:11, 26:12, 28:16
1
base [1] - 30:1
based [5] - 6:18, 8:7,
11:2, 19:5, 24:12
basic [1] - 19:11
basis [1] - 28:23
became [1] - 30:10
become [2] - 18:6,
25:14
BEFORE [1] - 1:11
beginning [1] - 9:22
behalf [2] - 5:14,
27:19
behaves [1] - 31:7
bender [1] - 25:22
benefit [3] - 13:23,
13:24, 14:3
better [1] - 5:5
between [5] - 3:21,
8:15, 13:15, 21:23,
31:13
beyond [2] - 13:3,
22:19
big [3] - 10:23,
11:15, 16:2
blaming [2] - 8:11,
8:18
boom [1] - 6:14
bottom [1] - 24:17
Boulevard [1] - 1:15
box [1] - 10:21
break [2] - 6:12,
13:17
BRIAN [1] - 1:21
Brian [1] - 1:22
bring [1] - 23:16
brought [1] - 18:1
Broward [1] - 1:15
BSO [4] - 9:15, 9:16,
18:13, 25:14
bugging [1] - 8:22
bunch [1] - 29:14
burden [5] - 13:2,
16:14, 16:17, 22:2
Business [1] - 22:15
buying [1] - 11:13
buzz [1] - 12:8
BY [1] - 2:1
C
calculated [1] - 5:9
calculates [1] - 24:7
candid [1] - 20:11
candor [1] - 20:10
cannot [3] - 29:23,
30:23, 31:7
capable [1] - 30:6
car [1] - 25:24
card [1] - 16:2
Case 0:23-cr-60170-RNS Document 111 Entered on FLSD Docket 08/09/2024 Page 33 of 38
care [1] - 20:4
cared [1] - 11:4
career [1] - 25:19
cares [1] - 18:3
carries [1] - 13:2
CASE [1] - 1:2
case [12] - 3:7, 3:20,
4:13, 8:12, 8:15,
14:10, 16:18, 19:6,
21:22, 22:4, 24:21,
25:6
catch [1] - 28:12
caused [2] - 7:9,
7:22
cede [1] - 14:14
century [1] - 9:17
certain [2] - 4:1, 9:3
certainly [1] - 29:25
certified [1] - 18:10
certify [1] - 32:10
chance [1] - 31:11
change [1] - 6:16
changed [4] - 5:21,
5:22, 8:12, 18:20
changes [3] - 6:2,
6:16, 9:4
charged [2] - 3:7,
19:22
charges [3] - 6:8,
27:11, 31:16
check [3] - 12:8,
12:9, 17:12
checks [1] - 16:2
choose [2] - 30:4,
30:5
chose [1] - 30:6
CHRISTOPHER [1] -
1:14
circle [1] - 16:12
circumstances [5] -
3:12, 4:14, 5:22, 14:8,
30:24
circumstantial [2] -
4:11, 12:21
claim [1] - 29:23
class [2] - 18:5, 18:8
clear [2] - 4:21, 4:22
clearly [1] - 30:4
click [1] - 31:2
client [2] - 21:6,
27:19
closely [1] - 29:18
CLOSING [1] - 1:10
closing [1] - 2:10
Closing [1] - 2:11
code [1] - 24:3
coincidences [1] -
29:14
college [4] - 18:1,
18:3, 18:6, 18:8
comfortable [1] -
27:9
coming [3] - 14:4,
24:18, 28:25
command [2] -
18:16, 18:18
commander [2] -
30:18, 30:19
commits [1] - 28:18
committed [1] -
10:15
committing [1] -
10:10
common [2] - 28:22
comparison [1] -
25:21
completely [1] - 3:13
compliance [2] -
18:24, 24:6
computer [3] -
23:18, 24:8, 28:1
computers [1] - 15:3
conclusion [1] - 19:2
conducted [2] -
17:23, 24:5
confirmed [1] -
15:25
conflict [1] - 17:15
conflicts [3] - 27:16,
28:3, 28:4
consequences [1] -
26:18
consistent [3] - 10:4,
18:17, 31:20
conspiracy [6] -
13:8, 13:12, 13:19,
31:13, 31:22
conspiring [1] - 3:8
contained [1] - 3:13
containing [1] -
13:12
context [3] - 16:22,
23:9
conversation [2] -
21:17, 21:22
convict [2] - 17:16,
22:5
conviction [1] - 22:3
copy [1] - 16:10
correct [1] - 3:23
correspondence [2]
- 7:1, 8:15
cost [1] - 20:1
counsel [3] - 29:7,
29:20, 30:3
Count [8] - 3:19,
22:10, 31:15, 31:22,
31:23, 31:24
Counts [2] - 13:3,
31:14
counts [2] - 31:13,
31:22
couple [2] - 18:14,
31:18
course [2] - 6:10,
17:9
court [1] - 19:23
Court [6] - 2:3, 2:3,
4:11, 24:18, 32:15,
32:16
COURT [6] - 1:1,
14:13, 14:16, 14:18,
27:24, 32:1
Court's [1] - 27:22
covering [2] - 19:23,
19:25
crazy [1] - 30:23
created [10] - 4:8,
6:15, 6:20, 7:23,
12:23, 12:24, 13:1,
14:5, 30:17
creates [1] - 28:4
credit [1] - 7:8
credulity [1] - 28:20
crime [5] - 9:16,
9:17, 10:10, 22:13,
22:18
Criminal [1] - 18:5
criminal [1] - 18:5
customers [1] - 20:9
D
daily [1] - 28:23
damages [1] - 26:7
dark [2] - 19:14, 20:2
data [1] - 12:20
date [2] - 5:15, 15:8
DATE [1] - 32:15
days [2] - 17:22,
31:19
deal [1] - 11:15
December [2] - 4:17,
15:20
decisions [1] - 28:24
deduct [1] - 19:11
Defendant [1] - 10:4
defendant [16] - 1:8,
4:5, 4:15, 4:21, 5:23,
7:2, 7:3, 8:9, 11:8,
12:22, 14:9, 22:18,
22:21, 28:4, 28:15,
30:1
DEFENDANT [1] -
1:21
defendant's [1] -
28:12
defense [4] - 13:10,
22:10, 29:7, 30:3
definitely [1] - 26:16
defraud [2] - 31:15,
31:22
deliberate [2] -
12:17, 31:14
deliberately [2] -
4:16, 11:6
demonstrated [1] -
3:12
dent [2] - 25:24,
26:11
department [1] -
21:8
dependent [1] - 24:7
Deputy [1] - 21:24
deputy [5] - 16:2,
17:23, 20:15, 20:16
deserving [1] - 30:15
details [2] - 6:3
determined [1] -
17:5
device [1] - 6:18
different [2] - 5:24,
31:16
digital [5] - 5:16,
15:1, 15:17, 15:25,
16:3
dignitaries [1] -
20:25
dignity [1] - 24:19
direct [2] - 4:12, 4:13
disclose [2] - 7:20,
11:12
discovery [1] - 19:20
discussing [1] - 19:3
discussions [1] -
17:6
dispute [4] - 3:17,
3:21, 14:5, 25:4
disputing [1] - 25:7
distinction [1] -
31:13
District [2] - 2:3,
32:16
DISTRICT [3] - 1:1,
1:1, 1:11
DIVISION [1] - 1:2
doctor [1] - 18:12
document [3] -
10:22, 16:7, 27:1
documenting [1] -
4:19
documents [3] -
6:23, 10:15, 19:20
DocuSign [4] -
10:22, 15:12, 15:15,
16:7
DocuSigned [2] -
15:11
DOJ [1] - 1:14
2
DOJ-USAO [1] - 1:14
dollars [3] - 3:24,
4:9, 26:11
done [2] - 7:3, 25:18
double [1] - 19:10
double-entered [1] -
19:10
doubt [9] - 13:3,
16:19, 17:16, 22:3,
22:4, 22:20, 28:21,
29:6
doubts [1] - 27:11
down [5] - 8:17,
8:21, 21:22, 23:24,
25:23
drink [1] - 11:13
drive [3] - 28:24,
28:25, 29:4
drop [1] - 30:24
DS [1] - 15:12
due [1] - 17:8
dump [1] - 16:9
during [7] - 3:5, 4:7,
6:11, 6:12, 7:19,
12:25, 18:16
duty [2] - 20:9
E
East [1] - 1:15
effort [1] - 20:17
either [1] - 28:1
element [2] - 3:20,
13:6
ELMO [1] - 28:1
email [3] - 10:11,
10:21, 20:4
emails [1] - 8:13
emphasize [1] -
27:12
encountered [1] -
23:11
end [6] - 17:7, 19:2,
19:18, 27:4, 27:10,
31:10
energy [1] - 11:13
enforcement [6] -
10:2, 10:9, 21:6,
25:19, 26:23, 30:10
engaged [1] - 29:22
entered [2] - 19:10,
27:11
entitled [4] - 11:1,
11:19, 31:5, 32:12
envelope [1] - 16:8
equally [1] - 4:12
ESQ [3] - 1:14, 1:18,
1:21
event [1] - 17:6
events [2] - 11:12,
Case 0:23-cr-60170-RNS Document 111 Entered on FLSD Docket 08/09/2024 Page 34 of 38
11:14
everywhere [1] -
15:2
evidence [29] - 3:10,
4:12, 4:13, 10:10,
10:20, 12:19, 12:22,
14:11, 15:1, 15:17,
16:9, 16:20, 17:3,
17:10, 17:12, 18:13,
18:18, 18:21, 18:23,
19:6, 22:22, 27:17,
28:3, 28:9, 28:11,
31:11, 31:18, 31:20
exactly [5] - 4:6, 5:5,
7:10, 10:5, 26:12
examination [1] - 6:2
examiner [1] - 4:19
excerpt [1] - 3:1
EXCERPT [1] - 1:10
exclusively [1] -
16:15
exemplary [1] -
20:15
exist [1] - 25:1
expenses [5] - 4:1,
5:9, 6:3, 8:23, 19:11
experience [1] - 30:1
explained [1] - 18:15
extra [2] - 6:24,
10:13
F
F616B [2] - 16:8
fact [9] - 4:1, 9:8,
9:23, 10:14, 11:5,
13:20, 17:5, 22:20,
30:22
facts [2] - 14:7,
22:19
failed [1] - 25:11
failure [1] - 20:20
faith [2] - 13:9, 22:9
fake [1] - 6:24
false [21] - 3:7, 3:14,
3:22, 3:25, 4:1, 4:2,
4:16, 9:10, 13:4, 13:5,
13:12, 13:13, 22:11,
22:13, 22:14, 22:21,
22:23, 25:3, 25:8,
31:22, 31:23
falsified [1] - 10:15
far [1] - 25:18
fast [1] - 19:21
fast-forward [1] -
19:21
fat [1] - 16:2
February [13] - 4:6,
5:15, 6:7, 9:24, 10:21,
15:6, 15:7, 15:8,
17:13, 17:20, 17:21,
21:23
federal [3] - 10:1,
19:23, 22:13
feet [1] - 25:12
felonies [1] - 19:22
felonious [1] - 13:23
felony [3] - 10:15,
10:20, 28:18
fender [1] - 25:22
fender-bender [1] -
25:22
fiduciary [1] - 20:9
field [2] - 24:2, 24:3
fight [1] - 24:24
fighting [1] - 24:19
figure [1] - 15:5
figures [1] - 23:19
fill [1] - 18:14
filling [1] - 9:16
fills [1] - 23:19
fine [1] - 14:2
fingers [1] - 29:22
first [11] - 5:4, 5:6,
5:20, 7:12, 10:21,
10:25, 11:1, 16:11,
25:11, 25:14
fit [1] - 5:22
five [4] - 20:22,
25:10, 25:12, 25:13
fix [3] - 7:10, 20:12,
28:10
fixing [1] - 7:8
FL [3] - 1:16, 1:19,
1:23
Floor [2] - 1:15,
32:17
FLORIDA [1] - 1:1
Florida [3] - 1:4, 2:4,
32:17
follower [1] - 18:22
following [3] - 3:1,
15:2, 22:19
FOR [2] - 1:14, 1:21
foregoing [1] - 32:10
forgiven [1] - 3:15
forgiveness [6] -
12:24, 15:21, 15:24,
16:8, 25:2, 29:17
form [4] - 18:14,
18:19, 23:19
forms [2] - 6:25, 9:16
Fort [1] - 1:23
forward [1] - 19:21
fought [1] - 24:25
four [3] - 19:2, 25:10,
25:13
four-month [1] - 19:2
FPR [2] - 2:2, 32:15
fraud [6] - 3:19, 9:21,
10:2, 30:4, 31:15,
31:24
free [1] - 28:18
fresh [1] - 5:6
friends [1] - 23:10
FROM [1] - 1:10
Ft [1] - 1:16
full [1] - 17:4
funds [2] - 3:15, 3:25
G
G-mail [2] - 6:16,
12:13
gap [1] - 17:19
girlfriend [1] - 11:21
God [1] - 27:18
Googled [1] - 23:6
Government [6] -
7:15, 14:6, 18:1, 22:1,
24:21, 30:5
grades [1] - 18:1
graduated [1] -
20:22
grand [1] - 12:16
gratis [1] - 10:18
guilty [7] - 14:12,
22:7, 22:18, 27:10,
27:14, 31:21, 31:24
gun [1] - 18:7
guy [14] - 12:5, 19:8,
19:9, 19:10, 21:6,
23:6, 23:8, 23:17,
26:2, 26:10, 26:11,
30:3, 30:6
H
hair [1] - 15:22
handle [1] - 20:3
hands [3] - 27:1,
27:4, 29:22
handwritten [1] -
16:1
happy [2] - 10:13
hard [1] - 25:18
harder [1] - 20:19
haul [1] - 25:12
head [5] - 5:2, 24:11,
27:3, 31:7
heading [1] - 12:6
hear [2] - 21:20,
28:11
heard [3] - 3:5, 7:14,
13:9
heavy [1] - 25:13
helps [1] - 29:20
hereby [1] - 32:10
herself [4] - 9:3,
9:19, 17:23, 20:18
hid [1] - 11:6
hidden [1] - 6:4
hide [3] - 11:7,
11:15, 11:17
hiding [1] - 14:6
hire [1] - 23:22
hold [1] - 14:15
holding [1] - 29:10
holds [1] - 25:15
honest [2] - 26:16,
26:17
honesty [3] - 24:18,
26:20, 26:21
Honor [6] - 3:3,
14:14, 14:19, 14:22,
27:22, 28:2
honor [1] - 24:18
honorable [1] -
17:24
HONORABLE [1] -
1:11
hour [1] - 6:12
hours [2] - 6:10, 19:3
house [1] - 22:25
housekeeping [1] -
3:16
hurting [1] - 16:24
hustle [1] - 9:20
I
ID [1] - 16:8
idea [3] - 11:9, 24:11,
29:3
identity [1] - 27:7
ignorance [2] -
12:17, 31:15
ignored [1] - 4:16
illogical [1] - 10:19
important [3] -
16:13, 17:9, 17:18
inability [1] - 10:4
income [2] - 10:25,
11:2
inconsistencies [1] -
9:12
inconsistent [1] -
9:11
incredibly [1] - 8:3
indeed [1] - 28:3
independent [1] -
21:18
indication [1] - 19:7
individual [1] - 10:8
inflate [1] - 7:23
influencing [1] -
22:16
inform [1] - 18:13
information [9] -
3
6:18, 8:7, 11:3, 13:12,
19:1, 20:10, 22:5,
26:25, 27:8
informs [1] - 22:7
initials [1] - 15:14
innocence [1] -
27:13
instructed [5] - 4:11,
22:9, 24:22, 24:25,
31:21
instruction [1] - 13:9
instructions [2] -
16:11, 31:12
insurance [1] - 26:5
integrity [1] - 24:19
intelligent [1] - 28:6
intent [5] - 8:5, 9:14,
16:12, 25:9, 31:15
intentionally [1] -
19:4
intentions [1] - 17:10
interact [1] - 29:18
interactions [2] -
4:22, 29:16
interacts [1] - 26:24
interstate [1] - 3:18
interview [1] - 24:5
introduced [2] -
3:10, 3:17
invest [1] - 17:17
investigation [3] -
7:17, 7:18, 19:2
involved [3] - 5:1,
26:5, 30:4
IP [4] - 6:18, 14:6,
22:5, 30:16
iPhones [1] - 15:3
irrefutable [1] - 17:3
irrefuted [2] - 21:15,
21:16
irrelevant [1] - 18:20
IRS [12] - 4:19, 5:19,
6:2, 6:8, 6:24, 7:15,
8:24, 16:22, 17:13,
17:18, 18:23
issue [4] - 7:4, 7:8,
27:7, 27:8
issues [1] - 23:22
J
January [1] - 5:25
Johnson [2] - 7:18,
10:1
joined [1] - 13:8
Jones [3] - 2:10,
2:11, 27:25
JONES [6] - 1:10,
1:14, 3:3, 14:14,
14:17, 28:2
Case 0:23-cr-60170-RNS Document 111 Entered on FLSD Docket 08/09/2024 Page 35 of 38
judge [1] - 22:9
JUDGE [1] - 1:11
June [1] - 1:5
jurors [1] - 28:22
jury [3] - 3:1, 16:10,
16:11
JURY [1] - 1:10
Justice [1] - 18:5
justice [1] - 18:6
K
keep [5] - 9:12, 10:4,
13:22, 14:3, 28:5
kept [2] - 19:13, 20:2
keys [1] - 29:23
kid's [1] - 27:2
kids [1] - 29:4
knowing [1] - 28:19
knowingly [2] -
22:14, 22:21
knowledge [10] - 4:4,
8:5, 9:13, 10:11, 13:4,
13:6, 24:6, 25:8, 30:1,
31:14
known [1] - 23:8
knows [9] - 9:20,
10:8, 11:1, 12:10,
12:11, 14:11, 28:6,
28:7
L
lady [2] - 15:22,
17:23
large [1] - 6:4
lastly [1] - 27:19
Lauderdale [2] -
1:16, 1:23
law [8] - 10:2, 10:8,
17:24, 21:6, 25:19,
26:23, 30:10, 31:20
Law [1] - 1:22
lawyer [2] - 18:12,
23:21
leading [3] - 29:16,
29:17
leaving [1] - 30:20
left [1] - 13:15
letter [2] - 8:11, 17:7
letting [1] - 7:9
liability [1] - 17:2
life [2] - 11:14, 29:25
lightning [2] - 29:9,
29:11
lights [1] - 28:25
line [1] - 24:17
listen [1] - 11:18
listening [1] - 27:21
live [2] - 15:1, 27:2
loan [12] - 3:14, 4:9,
6:15, 12:25, 13:1,
13:11, 15:8, 15:10,
22:15, 25:1, 29:17
loans [1] - 3:23
login [1] - 6:17
look [7] - 8:14,
12:15, 15:14, 18:22,
23:3, 28:8, 31:17
losses [1] - 8:23
lost [1] - 27:3
loud [1] - 7:12
Louis [17] - 3:8, 4:7,
4:22, 5:13, 7:2, 7:17,
7:21, 8:16, 12:5,
13:25, 15:19, 16:20,
19:8, 21:24, 28:13,
29:16, 30:3
LOVE [1] - 1:18
loved [1] - 11:6
lower [1] - 5:9
lunch [2] - 6:12,
13:17
M
machine [1] - 29:11
mail [2] - 6:16, 12:13
major [5] - 16:19,
17:15, 19:22
massive [2] - 11:14,
12:20
material [1] - 14:9
math [1] - 20:18
matter [2] - 3:16,
32:12
mattered [1] - 7:13
matters [1] - 3:13
mean [4] - 23:25,
24:1, 25:25, 29:2
means [3] - 23:12,
26:22, 26:23
meeting [2] - 7:19
memory [1] - 5:5
mention [1] - 7:25
merely [1] - 27:15
met [3] - 3:21, 6:7,
23:5
MIAMI [1] - 1:2
Miami [6] - 1:4, 1:19,
2:4, 2:4, 32:16, 32:17
middle [1] - 22:11
might [1] - 17:7
mileage [1] - 24:11
miles [3] - 19:11,
25:11, 25:13
million [1] - 27:12
mind [6] - 5:6, 8:3,
8:4, 12:22, 20:17,
30:10
minimal [1] - 19:15
minimized [1] -
26:18
minutes [1] - 14:13
misleading [1] -
20:11
misplaced [1] - 27:4
missing [1] - 18:25
misstatements [1] -
14:9
mistake [4] - 19:9,
19:25, 26:18, 29:13
misunderstood [1] -
18:17
moment [1] - 23:4
money [10] - 9:3,
16:24, 17:11, 17:16,
17:18, 17:21, 26:10,
28:14, 30:14, 31:5
month [1] - 19:2
monthly [1] - 3:25
most [1] - 17:9
mother [1] - 11:22
motive [6] - 19:8,
28:12, 28:13, 28:17,
30:2, 31:3
mountain [1] - 29:10
MR [7] - 1:10, 3:3,
14:14, 14:17, 14:19,
28:2
must [1] - 4:12
N
name [1] - 27:2
necessary [1] - 28:9
need [7] - 16:17,
24:24, 24:25, 27:13,
27:14, 28:10, 29:24
needs [3] - 23:21,
23:22, 26:25
neurosurgeon [1] -
20:8
never [9] - 9:5,
10:16, 21:15, 26:20,
26:21, 27:5, 27:7
new [3] - 5:23, 6:17,
6:18
night [1] - 27:3
NO [1] - 1:2
nobody [4] - 4:10,
9:15, 31:7, 31:9
none [1] - 21:4
noon [2] - 6:15,
30:17
North [2] - 2:4, 32:16
nose [2] - 24:20,
25:5
note [1] - 24:10
notes [1] - 18:25
nothing [1] - 8:1
number [5] - 3:24,
24:2, 24:3, 24:14,
26:8
numbers [5] - 5:1,
6:21, 8:19, 9:7, 25:3
O
object [1] - 25:13
obtaining [1] - 22:14
obvious [1] - 20:14
odd [1] - 3:24
OF [3] - 1:1, 1:4, 1:10
Office [3] - 1:18,
7:14, 30:23
office [3] - 5:15,
6:11, 21:7
officer [10] - 17:24,
18:7, 18:11, 18:24,
21:2, 21:12, 24:6,
25:10, 26:23, 30:10
Offices [1] - 1:22
Official [1] - 32:15
official [1] - 2:3
omission [2] - 4:14,
14:9
omissions [1] - 14:9
one [15] - 5:24, 9:22,
13:2, 16:10, 16:20,
16:24, 17:2, 20:22,
22:7, 22:23, 22:24,
23:2, 25:7, 28:5, 29:8
opening [2] - 21:19,
24:17
opportune [1] - 9:13
opportunity [1] - 9:2
otherwise [1] - 31:4
ought [1] - 16:11
overhead [1] - 14:22
owe [2] - 19:15,
19:18
owes [1] - 20:9
own [1] - 10:7
P
P.A [1] - 1:22
page [1] - 3:24
PAGE [1] - 2:10
Pages [1] - 1:8
paid [1] - 17:2
parking [1] - 25:23
part [4] - 7:16, 7:17,
10:25, 19:7
participation [1] -
25:9
parties [2] - 3:20,
3:22
pass [1] - 25:14
4
password [1] - 6:16
past [1] - 31:18
pay [3] - 9:3, 26:6,
28:16
paycheck [2] - 17:3,
17:4
paying [1] - 15:4
payroll [1] - 3:25
penalties [2] - 19:16,
19:18
people [8] - 10:3,
11:6, 16:15, 18:7,
20:22, 21:24, 23:22,
26:24
percent [2] - 20:22,
21:20
perfect [1] - 12:16
period [5] - 4:7, 6:11,
6:20, 12:21, 12:25
permeating [1] -
10:1
person [16] - 7:9,
8:8, 19:4, 20:24, 23:5,
23:14, 25:22, 26:4,
26:8, 26:25, 27:1,
28:6, 28:10, 28:19,
30:9, 30:25
personal [1] - 20:10
pesky [1] - 15:16
pestering [1] - 15:16
phone [1] - 22:25
physician [1] - 23:21
piece [1] - 17:10
pieces [1] - 13:2
pink [1] - 15:22
pivot [2] - 5:22, 9:2
pivots [1] - 8:7
place [1] - 30:16
Plaintiff [1] - 1:5
PLAINTIFF [1] - 1:14
plan [2] - 13:18,
21:13
play [1] - 29:23
point [2] - 6:22, 9:18
pointing [1] - 27:15
police [5] - 18:6,
18:11, 21:2, 21:8,
26:3
policy [3] - 9:15,
9:16, 9:18
position [2] - 4:24,
20:7
possibility [1] - 29:2
possible [3] - 27:15,
28:21, 29:6
potential [1] - 12:8
potentially [2] - 4:2,
20:1
PPP [9] - 3:14, 3:23,
4:9, 6:15, 9:21, 10:2,
Case 0:23-cr-60170-RNS Document 111 Entered on FLSD Docket 08/09/2024 Page 36 of 38
13:11, 23:7, 29:17
prefers [1] - 13:20
preparation [1] -
23:9
prepare [1] - 23:24
prepared [1] - 23:15
preparer [9] - 4:25,
6:6, 20:8, 20:9, 21:6,
23:23, 26:15, 30:5,
30:6
present [1] - 21:24
presented [1] - 31:18
president [1] - 20:24
pretty [1] - 29:3
previously [1] - 5:24
pro [1] - 3:4
problem [8] - 12:3,
16:18, 21:9, 22:1,
26:8, 26:9, 27:5, 27:6
problems [3] - 7:22,
16:25, 20:12
proceedings [2] -
3:1, 32:11
process [1] - 28:13
professional [1] -
18:12
proffered [1] - 30:22
program [3] - 9:22,
9:24, 10:3
projector [1] - 14:23
proof [3] - 13:2,
16:15, 22:2
protect [1] - 20:10
protected [1] - 26:25
protects [1] - 20:24
prove [4] - 16:17,
24:21, 27:13, 27:14
Prove [1] - 25:5
proved [1] - 22:19
Publix [1] - 25:23
pure [1] - 10:18
purportedly [4] -
6:18, 8:23, 11:17,
31:1
purpose [2] - 22:14,
22:16
pushes [1] - 12:13
put [6] - 16:4, 17:12,
20:16, 20:17, 24:2
Q
qualifications [1] -
18:12
questionnaires [1] -
5:13
questions [3] -
26:13, 27:16, 27:18
quid [1] - 3:4
quiet [1] - 12:2
quo [1] - 3:4
R
rates [1] - 26:6
read [1] - 31:12
real [2] - 16:19, 22:4
really [3] - 10:13,
11:11, 24:6
realtime [1] - 4:19
realtor [1] - 24:12
reason [7] - 7:23,
10:11, 12:10, 14:4,
26:11, 26:20, 26:21
reasonable [6] -
13:3, 16:19, 17:15,
22:3, 22:19, 28:21
Rebuttal [1] - 2:11
receipts [1] - 23:17
record [1] - 9:11
recording [1] - 15:4
recordings [1] -
21:17
records [6] - 4:23,
5:18, 7:15, 8:22, 8:25,
19:20
redactions [1] -
18:25
referrals [2] - 14:1,
14:3
reflects [1] - 8:4
refund [1] - 17:8
regardless [1] - 31:5
regular [2] - 20:16,
21:2
related [1] - 23:11
relationship [2] -
23:3, 30:12
relatives [1] - 23:10
relevant [1] - 18:2
reliance [1] - 13:10
remaining [1] - 13:6
remember [5] -
12:21, 15:22, 16:14,
22:2, 27:12
report [4] - 4:18,
5:20, 6:2, 26:3
REPORTED [1] - 2:1
Reporter [2] - 2:3,
32:15
reporting [1] - 9:15
require [1] - 13:4
response [1] - 5:14
responsible [2] -
30:25, 31:1
rest [1] - 27:3
return [1] - 5:10
returns [2] - 9:9,
12:9
revetted [1] - 21:2
review [1] - 31:11
roadblock [1] - 22:3
rob [2] - 21:11, 26:12
ROBERT [1] - 1:11
Robinhood [2] -
17:17, 17:21
rod [1] - 29:10
role [2] - 23:10,
23:23
room [3] - 4:7, 4:10,
16:10
RPR [2] - 2:2, 32:15
rule [2] - 18:17,
18:22
running [2] - 25:10,
25:24
S
safe [1] - 29:4
sat [5] - 5:2, 5:9,
6:13, 16:4, 24:1
save [1] - 9:3
saw [8] - 4:18, 6:3,
6:7, 9:18, 12:8, 13:16,
16:1, 19:1
SBA [8] - 3:8, 4:9,
22:13, 22:15, 22:16,
31:22, 31:23
scenario [1] - 26:13
scene [1] - 15:17
school [2] - 20:23,
25:14
SCOLA [1] - 1:11
second [1] - 9:4
section [1] - 11:1
securing [1] - 27:8
see [10] - 6:16, 6:17,
8:14, 8:24, 15:10,
15:12, 15:24, 16:12,
24:23, 28:25
send [1] - 10:9
sending [1] - 8:22
sends [1] - 6:2
sense [8] - 7:11,
10:5, 10:7, 20:13,
21:4, 24:15, 28:22
sent [1] - 6:21
sergeant [1] - 21:8
serious [1] - 18:9
seven [1] - 6:10
share [2] - 11:3, 11:5
SHARON [2] - 2:2,
32:15
sharon_pellvelazco
@flsd.uscourts.gov
[1] - 2:5
show [2] - 4:14, 9:13
showing [1] - 29:15
shown [2] - 8:9,
16:20
shows [11] - 5:14,
10:25, 14:11, 17:14,
22:23, 26:10, 28:9,
28:11, 29:17, 29:18,
30:16
side [2] - 8:8, 9:20
sideways [1] - 15:13
sign [2] - 10:23,
24:22
signature [9] - 5:16,
5:17, 9:10, 15:23,
15:25, 16:1, 16:3
signed [2] - 4:2, 5:15
significant [1] -
11:12
SILBER [3] - 1:10,
1:21, 14:19
Silber [3] - 1:22,
2:11, 14:18
silberlaw@gmail.
com [1] - 1:23
single [1] - 16:12
sit [1] - 23:24
sits [1] - 4:23
sitting [1] - 10:20
situation [1] - 7:13
six [1] - 11:13
sky [1] - 30:24
small [2] - 11:15,
12:21
Small [1] - 22:15
smart [2] - 29:21
software [1] - 23:19
solve [1] - 16:24
some-odd [1] - 3:24
someone [3] - 7:6,
25:17, 25:23
soon [1] - 19:15
sorry [3] - 25:17,
25:25
source [1] - 17:15
South [1] - 1:22
SOUTHERN [1] - 1:1
special [2] - 21:3,
26:22
spend [1] - 17:11
spent [5] - 6:12,
10:16, 13:17, 17:16,
19:3
spouse [2] - 11:16,
11:18
St [17] - 3:8, 4:7,
4:22, 5:13, 7:2, 7:17,
7:21, 8:16, 12:5,
13:25, 15:19, 16:20,
19:8, 21:24, 28:13,
29:16, 30:3
start [1] - 4:17
started [2] - 14:10,
5
30:21
starts [1] - 23:18
state [3] - 8:3, 8:4,
12:22
statement [10] - 5:3,
5:12, 5:20, 13:4, 13:5,
13:13, 22:13, 22:14,
22:21, 22:23
statements [11] -
3:8, 3:14, 3:22, 4:15,
4:19, 4:21, 19:6,
21:19, 22:12, 31:23
STATES [3] - 1:1,
1:4, 1:11
States [3] - 2:3,
20:25, 32:16
STENOGRAPHICA
LLY [1] - 2:1
step [4] - 10:7,
13:20, 30:8, 31:6
steps [2] - 11:7,
13:23
still [3] - 8:24, 25:15,
28:12
stipulation [2] - 3:17,
24:22
stories [2] - 5:21,
28:5
story [7] - 5:21, 5:24,
8:12, 9:4, 10:5, 10:7,
21:5
straight [3] - 20:21,
28:5, 28:16
strains [1] - 28:20
street [1] - 25:23
struck [1] - 29:8
student [1] - 20:21
studied [1] - 18:7
stuff [1] - 19:21
stupid [1] - 25:19
submit [4] - 4:8,
13:11, 18:19
submitted [7] - 5:14,
5:19, 6:24, 16:21,
22:8, 22:24, 23:2
substantiate [1] -
8:23
Suite [1] - 1:15
supervisor [1] -
30:19
support [2] - 6:24,
8:25
surprise [2] - 11:10,
15:18
suspended [1] -
19:22
suspicious [1] -
30:24
SWAT [7] - 17:25,
20:23, 21:12, 25:10,
Case 0:23-cr-60170-RNS Document 111 Entered on FLSD Docket 08/09/2024 Page 37 of 38
25:14, 25:16, 26:23
symbols [1] - 15:12
T
table [1] - 16:15
Tax [6] - 6:17, 6:18,
13:16, 14:5
tax [24] - 4:25, 5:10,
5:18, 6:6, 7:4, 7:16,
8:10, 8:15, 11:14,
12:9, 17:2, 18:24,
19:20, 20:8, 21:6,
23:9, 23:22, 24:5,
26:15, 30:5, 30:6,
31:1
Taxes [1] - 30:20
taxes [10] - 7:22,
12:4, 12:6, 19:5, 19:9,
21:10, 23:6, 23:11,
23:15, 24:6
Taxes@gmail.com
[1] - 15:19
taxpayer [1] - 5:13
team [1] - 25:16
ten [2] - 30:9
terrible [1] - 20:18
testified [7] - 5:23,
7:3, 7:18, 9:23, 10:1,
24:12, 30:20
testifying [1] - 11:8
testimony [3] - 7:14,
18:17, 21:15
THE [8] - 1:11, 1:14,
1:21, 14:13, 14:16,
14:18, 27:24, 32:1
theft [1] - 27:7
theory [3] - 11:14,
11:18, 31:6
thousand [4] - 4:9,
24:9, 26:10
three [3] - 15:4, 19:2,
26:10
throughout [1] -
29:20
throw [1] - 25:19
thumb [1] - 25:5
thumbing [1] - 24:20
tie [1] - 17:14
timeline [2] - 7:20,
29:15
timing [2] - 12:23
title [1] - 25:15
today [3] - 3:10,
4:18, 5:23
together [5] - 6:7,
12:1, 17:14, 23:24
tomorrow [1] - 26:9
took [1] - 11:6
top [1] - 29:10
total [1] - 26:1
totally [6] - 16:23,
18:20, 19:11, 21:15,
24:7, 25:8
track [1] - 29:1
tracks [1] - 28:24
train [3] - 28:24,
29:1, 29:2
trained [2] - 18:10,
25:13
transcription [1] -
32:11
TREVOR [1] - 1:14
trevor.jones@
usdoj.gov [1] - 1:16
trial [3] - 3:1, 3:5,
29:20
TRIAL [1] - 1:10
tried [1] - 17:17
trouble [2] - 17:24,
31:1
trust [2] - 11:11, 20:7
truth [5] - 8:1, 8:2,
15:5
try [1] - 25:11
trying [3] - 8:13,
8:17, 28:12
turn [1] - 14:22
two [12] - 4:10, 5:8,
9:6, 11:14, 15:4,
16:13, 17:2, 19:21,
21:23, 21:25, 22:11
U
U.S [3] - 7:14, 22:15,
30:23
unanswered [1] -
27:16
unexplainable [1] -
3:13
united [1] - 2:3
UNITED [3] - 1:1,
1:4, 1:11
United [2] - 20:25,
32:16
unqualified [1] -
19:12
up [16] - 6:21, 7:4,
7:6, 8:12, 9:24, 17:6,
18:1, 23:6, 26:6,
26:10, 27:4, 28:12,
29:14, 29:16, 29:17
US [1] - 1:18
USAO [1] - 1:14
uses [1] - 23:19
V
VELAZCO [2] - 2:2,
32:15
Velazco [1] - 32:14
verdict [3] - 22:7,
31:20, 31:21
vetted [1] - 21:1
Victory [8] - 6:17,
6:18, 13:16, 14:5,
15:19, 30:20
Vilsaint [11] - 3:8,
7:2, 7:17, 7:21, 10:6,
11:24, 11:25, 15:19,
16:20, 19:8, 21:24
violate [1] - 19:4
violation [1] - 9:18
violent [1] - 26:24
vs [1] - 1:6
W
W-2s [1] - 23:16
walk [2] - 12:19,
28:23
walked [3] - 4:17,
4:18, 29:8
walking [1] - 12:8
walks [1] - 23:7
wallflower [1] -
29:19
wants [1] - 12:11
watching [1] - 15:3
ways [1] - 17:2
week [1] - 11:13
weighed [1] - 4:12
wet [1] - 5:16
whole [5] - 7:1, 8:1,
21:22, 29:20
wife [9] - 11:7, 11:11,
11:19, 11:23, 12:4,
12:6, 12:7, 21:7
wife's [1] - 12:9
willfully [2] - 13:8,
13:10
willfulness [2] -
13:10, 16:13
willingness [1] -
31:14
wire [4] - 3:18, 3:19,
31:15, 31:24
witness [1] - 21:18
woman [2] - 25:14,
25:16
words [2] - 16:12,
16:13
worker [1] - 9:19
works [1] - 16:16
worry [1] - 21:9
wrap [1] - 31:7
writing [1] - 8:11
written [2] - 13:18,
17:12
6
written-out [1] -
13:18
wrongdoing [1] -
19:7
Y
YAACOV [1] - 1:21
year [4] - 5:7, 15:1,
17:22
years [9] - 5:9, 9:6,
15:4, 18:15, 18:16,
18:18, 19:21, 30:9
yesterday [3] - 3:11,
4:18, 23:5
yourself [1] - 13:22
Case 0:23-cr-60170-RNS Document 111 Entered on FLSD Docket 08/09/2024 Page 38 of 38File and source
- File
- gov.uscourts.flsd.654235.111.0.pdf
- Size
- 406,635 bytes
- SHA-256
- 11c362e8be090ada32ee6102ac69d11010e6cd5c643d0971c39f2e7af48277ee
- Original
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