Court filing
TRANSCRIPT of Jury Trial as to Alexandra Acosta held on 06/04/2024 before Senior… — USA v. Alexandra Acosta (Dkt. 135)
Record facts
| Court | U.S. District Court for the Southern District of Florida |
|---|---|
| Filed | 2024-11-26 |
U.S. District Court for the Southern District of Florida · No. 0:23-cr-60170-RNS · Doc. 135 · 2024-11-26 · Docket on CourtListener
Summary
A transcript of jury trial proceedings for June 4, 2024 in United States of America v. Alexandra Acosta, Case No. 0:23-cr-60170-RNS-1, before the Honorable Robert N. Scola in the U.S. District Court for the Southern District of Florida, Miami Division. It is Document 135, entered on the docket November 26, 2024, and covers pages 1 to 283. Trevor Christopher Jones and Adam Love appear for the plaintiff and Brian Yaacov Silber for the defendant. The index lists four witnesses, including the defendant, and an exhibit table of government exhibits in the 200, 300, 500 and 600 series with defense exhibits B, C and D. The opening testimony comes from a Broward County Sheriff's Office human resources manager, who describes that office's personnel files and identifies Government's Exhibit 300 as an employee action history report for Alexandra Acosta, admitted without objection.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
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1
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. 8:30 a.m. - 5:37 p.m.
ALEXANDRA ACOSTA,
Defendant. Pages 1 to 283
______________________________________________________________
JURY TRIAL
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 135 Entered on FLSD Docket 11/26/2024 Page 1 of 283
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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) 523-5356
I N D E X
WITNESS
Direct Cross Red.
JOANA HELY
By Mr. Love
5
By Mr. Silber
23
VICTORIA HERNANDEZ
By Mr. Jones
32
93
By Mr. Silber
77
TONYA JOHNSON
By Mr. Jones
103
177
By Mr. Silber
160
ALEXANDRA ACOSTA
By Mr. Silber
190
By Mr. Love
_ _ _
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 2 of 283
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E X H I B I T S
GOVT. Exhibit No.
PAGE
300
8
301, 302, 303
14
304, 305, 306
19
200, 201, 202
36
203A-H
50
602
101
600
113
500, 500A, 501, 501A
118
504, 505, 506, 508
123
603, 601
133
613, 613A&B
140
604
145
605
147
606
148
608A, 608B, 608C- 608D
149
609, 610, 611
151
612, 613C, 614
154
_ _ _
E X H I B I T S
DEFENSE Exhibit No.
PAGE
B
223
C
223
D
224
_ _ _
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 3 of 283
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(The following proceedings were had:)
COURT SECURITY OFFICER: All rise.
THE COURT: Thank you. Be seated. I think we are still
missing one juror. She called, and I think she is going to be
like five or ten minutes late.
And who is your next witness?
MR. JONES: Joana Hely from Broward County Sheriff's
Office.
THE COURT: Are they here?
MR. JONES: Yes.
THE COURT: Bring them in so they are ready.
MR. LOVE: Your Honor, may I approach to put my
computer and have it set up, please?
THE COURT: Yes.
COURT SECURITY OFFICER: Ready, Judge.
THE COURT: All right. Bring in the jury, please.
COURT SECURITY OFFICER: All rise for the jury.
[Whereupon, the jury entered the courtroom, and the
following proceedings were had at 9:12 A.M.:]
THE COURT: Good morning everyone. Welcome back.
Please be seated.
Government, who is your first witness?
MR. LOVE: Your Honor, the Government calls Joana Hely.
Thereupon:
JOANA HELY
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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.
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
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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.
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
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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.
(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.
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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.
(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
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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?
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
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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?
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?
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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.
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.
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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
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?
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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
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
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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.
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?
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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.
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
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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
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
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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.
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.
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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 subsection 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
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.
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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. 304 was received in Evidence.)
(Government's No. 305 was received in Evidence.)
(Government's No. 306 was received in Evidence.)
BY MR. LOVE:
Q.
Ms. Hely, I am displaying Government's Exhibit 304 for you.
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.
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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?
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?
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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
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
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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?
A.
No.
MR. LOVE: No further questions, your Honor.
THE COURT: All right.
Cross-examination?
MR. SILBER: Thank you, your Honor.
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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.
MR. SILBER: Sorry, I apologize.
THE COURT: The lavalliere microphone.
MR. SILBER: I forgot.
THE COURT: It is okay.
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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
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.
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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.
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?
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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.
Q.
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.
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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.
Your Honor, can you turn on the --
THE COURT: It is on.
MR. SILBER: Thank you.
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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?
A.
Correct.
Q.
Okay. I am showing you what was previously admitted as
Government's Exhibit 304 and 305.
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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.
Q.
All these people knew she was working in real estate and
authorized; correct?
A.
Yes.
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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.
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.
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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.
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
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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.)
THE COURT: Who is your next witness?
MR. JONES: The Government calls Victoria Hernandez.
Thereupon:
VICTORIA HERNANDEZ
was called as a witness and, having been duly sworn, was
examined and testified as follows: .
THE WITNESS: I do.
THE COURT: Please have a seat, make yourself
comfortable. When you are ready, state your name and spell
your last name.
THE WITNESS: My name is Victoria Hernandez,
H-E-R-N-A-N-D-E-Z.
THE COURT: Thank you.
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DIRECT EXAMINATION
BY MR. JONES:
Q.
Good morning.
A.
Good morning.
Q.
Miss Hernandez, where do you work?
A.
I work for the Internal Revenue Service.
Q.
And how long have you worked there?
A.
I have worked there for 16 years.
Q.
And what is your current title?
A.
I am a court witness coordinator.
Q.
Can you describe to the jury what your duties and
responsibilities are as a court witness coordinator?
A.
As a court witness coordinator, I represent the
Commissioner in his role as a custodian of records.
Q.
So, in layman's terms, are you responsible for all the
documents kept in IRS's ordinary course of business?
A.
Yes, I am.
Q.
Are you familiar with income tax returns?
A.
Yes, I am.
Q.
Can you briefly just describe that, what they are to the
jury?
A.
Tax returns like form 1040s, business tax returns,
correspondence that's received, correspondence that is sent
out, things like that.
Q.
Are you also familiar with an IRS audit?
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A.
Yes. Yes, I am.
Q.
And what is it, in general?
A.
An audit is when our examination department will do an
additional review of an individual or a business account, or
their financial information, to review to see if the
information that they provide us is accurate, to tax law.
Q.
And, in your role as a witness coordinator, do you handle
tax returns at all?
A.
As a court witness coordinator, I certify documents that
are -- that they are true and valid to what they are on the IRS
systems and what are kept in our records.
Q.
But, you don't review them for technical accuracy?
A.
No, I do not.
Q.
Do you conduct any audits, yourself?
A.
No, I do not.
Q.
In preparation for today's testimony, did you review IRS
records related to Alexandra Acosta for the tax years 2018
through 2020?
A.
Yes, I did.
Q.
And, did those records include tax returns for 2018, 2019,
and 2020?
A.
Yes.
Q.
And, did those records also include an audit file related
to 2018 and 2019 tax years?
A.
Yes.
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Q.
Now, before I turn to any records here, can you describe or
explain what a Form 1040 is?
A.
A Form 1040 is a U.S. individual tax return. It is what
tax payers use to file their tax returns for the year, for all
monies that they received for the years, and for that year, in
specific, and to file their taxes for that year.
Q.
Are you also familiar with a Schedule C?
A.
Yes.
Q.
What is that?
A.
That is a form that is used to file profit and losses of a
business.
Q.
Can those businesses -- is that for an incorporated
business?
A.
No. Those are for sole proprietors, a single person that
owns a business.
Q.
And are you familiar with what a Form 1099 is?
A.
Yes. That is a wage statement that is sent by -- it could
be by contractors, or another person that is providing a
service will issue a -- this to an individual that has worked
for that person, a contractor to another person.
MR. JONES: At this time, the Government is going to
move to introduce Government's Exhibits 200 through 202.
And, I believe there is an objection.
MR. SILBER: Your Honor, we renew our previously made
objection on all grounds, including authenticity.
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THE COURT: All right. I will overrule those
objections, and those exhibits will be admitted.
(Government's No. 200 was received in Evidence.)
(Government's No. 201 was received in Evidence.)
(Government's No. 202 was received in Evidence.)
BY MR. JONES:
Q.
Ms. Hernandez, I am going to --
Your Honor, I apologize --
Ms. Hernandez, I have shown you right now what has been
admitted as Government's Exhibit 201.
Do you recognize this document?
A.
Yes, I do.
Q.
What is this document?
A.
This is an electronic file, Form 1040 U.S. individual
income tax return for tax year 2019.
Q.
And who is this for?
A.
Alexandra Acosta.
Q.
Okay. We are going to not going to spend a ton of time on
this, but we are just going to briefly describe some of the
numbers that we are seeing here. In this section that I am
highlighting now, can you just explain what Box 1 is?
A.
Box 1 is for wages, salaries, and tips. And, it is
reported $103,819.
Q.
And how about Box 7A?
A.
Box 7A is for other income from Schedule 1, and it is
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reported negative $9,619.
Q.
So, what does that mean when it is reported negative?
A.
It is a loss.
Q.
And, I am going to bring you now to line 9.
What is this number?
A.
This is the standard deduction, or itemized deduction.
And, it is the amount of $26,651.
Q.
And, moving down more to this bottom number, 11B, can you
tell us what that is?
A.
That is the taxable income, and the amount is $67,549.
Q.
We are still on Exhibit 201. I just got sidetracked there.
But, we are going to move down to the second page of
Exhibit 201. I am going to highlight a section here.
So, I am pulling out a section labeled "refund." Can you
describe what we are looking at?
A.
This is the part of the form that is the refund or
overpayment amount requested.
Q.
And, in this instance?
A.
It is $7,666.
Q.
What does that represent?
A.
It was requested to be direct deposited in the checking
account provided.
Q.
Okay. Now, there is a section down here entitled "Third
Party Designee."
Can you explain what that is?
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A.
A third party designee is when a taxpayer will give the
third party who is the preparer permission to speak to the IRS
if there are any discussions needed on the tax return.
Q.
And, let's kind of briefly unpack what a tax preparer can
be. How does someone become a preparer?
A.
They could apply for a preparer tax identification number,
either through mail or online, with the IRS, and they could
become a preparer.
Q.
Now, that sounds simple. Do they need any formal
education?
A.
No, they do not.
Q.
Do they need any degrees?
A.
No, they do not.
Q.
How about a high school diploma?
A.
No.
Q.
So, how about an age requirement? Don't they have to be 18
at least?
A.
No.
Q.
They don't have to be certified public accountants?
A.
No.
Q.
Do they have to be accountants at all?
A.
No.
Q.
Are these just people that choose to write numbers on paper
for other people?
A.
Anybody could be a return preparer. In order to be
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compensated, you can apply for the PTIN.
Q.
And that is a unique number assigned to each person?
A.
Yes.
Q.
And, in this instance, who is the designee's name here with
the PIN?
A.
For this one, it is Victory Tax, Inc.
Q.
And, I am going to move you down to the section just below
it. There is a statement here, next to "sign here."
What does that say?
A.
"Under penalties of perjury, I declare that I have examined
this return and accompanying schedules and statements, and to
the best of my knowledge and belief, they are true, and
correct, and complete."
Q.
And, is this section completed by the preparer or the
taxpayer?
A.
Taxpayer.
Q.
And this says the email address associated with this
taxpayer was what?
A.
Alexacosta03@gmail.com.
Q.
And, listed in occupation of?
A.
The BSO deputy.
Q.
And the date of this signature?
A.
February 4, 2020.
Q.
There is another section down here, just below that,
distinct from the taxpayer certification to the accuracy. What
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is -- what is this form, or this area of form?
A.
It is for the paid preparer, only, to provide the
information of the preparer's address.
Q.
And, here, what is the preparer's name?
A.
Vilsaint St. Louis.
Q.
And I believe this is what you are -- you have mentioned
before, that's the PTIN?
A.
Yes.
Q.
And that is?
A.
That is the PTIN number.
Q.
Okay. Can you explain what that was?
What does it stand for?
A.
The preparer tax identification number.
Q.
Thank you.
And here, we have a firm's EIN. Do you know what that
is?
A.
That is the firm's employer identification number.
Q.
And, again, the name of the firm that St. Louis purportedly
works for?
A.
Victory Tax, Inc.
Q.
I am going to go to Page 4. I am showing you Page 4 of
Government's Exhibit 201.
Do you -- do you know what this document is?
A.
It is a paid preparer's due diligence checklist.
Q.
What is that exactly?
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A.
When certain credits are requested, like child tax credit
or additional, or EIC, or -- there is a checklist that
preparers will fill out to make sure they are asking the proper
questions of their clients as a check, due diligence check.
Q.
And that is submitted to the IRS?
A.
Yes.
Q.
This form is completed by the tax preparer in this case?
A.
Yes.
Q.
Can you read line 1?
A.
"Did you complete the return based on information for tax
year 2019 provided by the taxpayer or reasonably obtained by
you?"
Q.
What was the answer to that?
A.
Excuse me, "taxpayer or reasonably obtained by you" --
sorry -- and the answer was yes.
Q.
And now, just in the general sense, that type of
certification, is that because the taxpayer is the one
responsible for the information in any tax return?
A.
Yes.
Q.
I am going to quickly scroll to Page 15 of this record.
Do you recognize what this is?
A.
Yes. It is a Schedule C.
Q.
And, what is the Schedule C for?
A.
Alexandra Acosta.
Q.
What is the listed principal business or profession of
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Alexandra Acosta?
A.
Valor Dog, LLC.
Q.
And the social security number?
A.
590-92-6946.
Q.
There is also a listed employer ID number. What is that?
A.
46-3507588.
Q.
And the business address of?
A.
7200 Northwest 94th Way, Fort Lauderdale, Florida 33321.
Q.
Now, Schedule C, in general, you testified that it was a
reporting form for businesses?
A.
Yes.
Q.
Does the form include an area for income?
A.
Yes, it does.
Q.
And, I am going to highlight a section here, part one. And
this is that section discussing income. And, what is the
amount listed for income in 2019?
A.
$13,904.
Q.
And then there is also a section on expenses.
A.
Yes.
Q.
And, in this section, what was listed as expenses?
A.
Advertising, we have $1,288, car and truck expenses,
$5,948, supplies, we have $6,389, taxes and licenses, $503,
travel and meals, for travel, we have $2,863, other expenses,
from line 48, we have $6,532.
Q.
And is there a total expense calculated?
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A.
Yes. $23,523.
Q.
And, there is also a line 2 there. What is that?
A.
Tentative profit or loss, subtract 28 from line 7, which
was the loss of $9,619.
Q.
So, in sum, this form represents that the business or Valor
Dog, LLC, or Alexandra Acosta had lost $9,619 in 2019?
A.
Yes.
Q.
Let me show you Government's Exhibit 200.
Do you recognize this?
A.
Yes.
Q.
What is this?
A.
This is an electronically filed 1040 U.S. individual tax
return for 2019.
Q.
So, this is the same type of documents we discussed as
Government's Exhibit 201?
A.
Yes, it is.
Q.
And, again, this is -- this area regarding the signature,
is this the taxpayer's signature, or the tax preparer's
signature?
A.
It is the taxpayer's electronically signed signature.
Q.
And I am sorry I didn't address this earlier. That, it is
a bunch of asterisks. So, what does that represent?
A.
An electronic signature with the five digit PIN that the
taxpayer will put in for themselves.
Q.
And, what was the date of this -- this signature?
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A.
February 6th, 2019.
Q.
And the occupation associated with Ms. Acosta at the time?
A.
BSO deputy.
Q.
I am moving down what has been listed as Schedule 1.
Can you briefly describe what Schedule 1 is?
A.
Schedule 1 is additional income and adjustments to income.
Q.
And line 12, what does that represent?
A.
Business or income loss, the Schedule C, and the amount of
a loss of $25,772.
Q.
And, does that -- so, that refers to the Schedule C in this
return?
A.
Yes.
Q.
I am showing you Page 14 of this document; same document,
Government's Exhibit 200. And, is this the Schedule C for
Alexandra Acosta?
A.
Yes.
Q.
And what is the listed principal business for this one?
A.
Partners Realty LLC.
Q.
And this lists the social security number of -- or what is
the social security number associated with it?
A.
590-92-6946.
Q.
I believe there is an address here. It is different. What
is the address?
A.
2000 Northwest 150th Avenue, Hollywood, Florida 33028.
Q.
And, just like the 2019 tax return, or Schedule C, there is
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an income section. Can you tell me what was disclosed as
income on Schedule C?
A.
$23,596.
Q.
And, just like the 2019 Schedule C, there is an area for
expenses. Can you describe the expenses listed in this form?
A.
We have advertising, $8,869; car and truck expenses,
$3,482; rent or lease for other business property, $7,455;
repairs and maintenance, $8,147; supplies, $7,445; travel and
meals for travel $2,356; other expenses from line 48, $11,614.
And then total expenses was $49,368, with the total tentative
profit or loss in the amount of a loss of $25,772.
Q.
Now, the losses associated in this Schedule C, the Schedule
C for 2019, do they offset the W-2 income of the taxpayer?
A.
What it will end up doing is reducing the total taxable
income for the year, which will lower the total tax for the
year.
Q.
So, in this instance, if we go back, we have a total loss
of 25,772; correct?
A.
Yes.
Q.
And, back at the second page, this resulted in what?
A.
This resulted in a refund.
Q.
How much?
A.
$6,702.
Q.
And, I believe I skipped over this one. The paid preparer
section here, what is listed?
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A.
The paid preparer is Jesus Medina.
Q.
And is the firm -- what is the firm's name?
A.
Victory Tax, Inc.
Q.
Was that the same company that prepared the 2019 return?
A.
Yes.
Q.
I am showing you Government's Exhibit 202.
What is this?
A.
This is electronically filed Form 1040 U.S. individual tax
return for 2020.
Q.
And who is this form for?
A.
Alexandra Acosta.
Q.
And, the social security number associated with Alexandra
Acosta?
A.
590-92-6946.
Q.
And the address?
A.
7200 Northwest 94th Way, Tamarac, Florida 33321.
Q.
And, in this section -- let me back out of here for a
second.
So, this is for the 2020 tax year; correct?
A.
Correct.
Q.
And, would this form -- it maybe seems intuitive, but are
these prepared the following year for a prior tax year, for
example, 2021 -- that is a terrible question.
Would a 2020 tax return be prepared in 2021?
A.
Yes.
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Q.
And that is customary for all of these returns, it is the
following year?
A.
Correct.
Q.
Now, in this instance, again, was this document represented
to be signed by Alexandra Acosta?
A.
Yes.
Q.
And what was the date?
A.
February 22nd, 2021.
Q.
Is there a preparer listed on this form, as well?
A.
Yes, there is.
Q.
And who is that?
A.
Vilsaint.
Q.
And the firm's name?
A.
Victory Tax, Inc.
Q.
Is this the same firm that purportedly or that filed the
last tax returns in 2018 and 2019?
A.
Yes, it is.
Q.
Is there any reference in these first two pages of this
document to any business income?
I can scroll back up for you, as well.
A.
No, there isn't.
Q.
Is there any -- when you reviewed this file for 2020, were
there any schedule Cs attached?
A.
No, there was not.
Q.
Were there any expenses listed for a business?
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A.
No, there was not.
Q.
Can an individual report expenses on a Schedule C, even if
they didn't make any money that year?
A.
From?
Q.
For losses?
A.
From a business?
Q.
For a Schedule C, you report profit, you can report loss.
We saw that in 2018 and 2019 there were losses?
A.
Um-hmm.
Q.
If, hypothetically, somebody did not have an income at all,
$0 revenue, but, that company had losses that year, for
expenses, would that be reported on a Schedule C?
A.
I don't know.
Q.
Just as a loss can be reported on a Schedule C to offset
personal income, for example?
A.
I am sorry. I am lost in the question.
Q.
That's fine. In 2018 and 2019, there were Schedule Cs that
are filed?
A.
Correct.
Q.
In fact, let's go back to one.
We are on Government's Exhibit -- we are looking at
Government's Exhibit 201, Page 15, again. And, in this
section, I will just highlight the whole area so we can see it
a little better.
Part one, we already discussed that listed the income;
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correct?
A.
Correct.
Q.
Did part two lists the expenses; correct?
A.
Correct.
Q.
The question was, could part one say zero, and part two
still include these expenses?
A.
I have seen that, yes.
Q.
And, for 2019, 2018, 2019, 2020, who is responsible for the
information submitted to the IRS?
A.
The taxpayer.
Q.
And, in this instance, who was the taxpayer?
A.
Alexandra Acosta.
MR. JONES: Your Honor, I was going to pivot to a
different line of questioning. So, if you want to break --
but, I am good to keep going.
THE COURT: Keep going.
MR. JONES: Okay.
BY MR. JONES:
Q.
Now, we previously mentioned there is an audit records
related to 2018 and 2019 tax returns. And, we just saw some of
the tax returns for those years; correct?
A.
Correct.
Q.
And, have you had a chance to review those files before
today?
A.
Yes, I have.
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Q.
And, was one of them the 489-page Government's Exhibit 203?
A.
Yes.
Q.
And, you reviewed that in preparation of your testimony
today?
A.
I did.
Q.
Was that record kept in the ordinary course of business for
the IRS?
A.
Yes, it was.
Q.
And, had the IRS provided certified copies to the U.S.
Attorney's Office in advance of trial?
A.
Yes, they did.
MR. JONES: Your Honor, I move to admit what has been
marked as Government's Exhibit 203, 203A through H, which are
subsets of 203.
MR. SILBER: Your Honor, we renew our previously made
objections, including as to authenticity.
THE COURT: All right. I will overrule those
objections, and those will be received in evidence.
(Government's No. 203 A through H was received in
Evidence.)
BY MR. JONES:
Q.
Now, I am showing you the first page of Government's
Exhibit -- well, I didn't highlight it all -- Government's
Exhibit 203. Like I said, it is a 489-page document.
But, I've got good news. We are not going through 489
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pages. I am going to discuss certain portions of this with
you. And, I have highlighted them as separate exhibits. So,
we are going to go first to 203A.
I am showing you Government's Exhibit 203A. I am going
to highlight this top section area. What are we -- what is
this document?
A.
This is the case history report of the audit file.
Q.
And, is it listed which years the audit was for here?
A.
Yes, it does.
Q.
And, what years were those?
A.
Tax years 2018 and 2019.
Q.
And is there a name of an examining officer?
A.
Yes, there is.
Q.
Who is that.
A.
Phyllis Kampmeyer.
Q.
And the taxpayer in this audit?
A.
Alexandra Acosta.
Q.
With her address?
A.
7200 Northwest 94th Way, Tamarac, Florida 33321-3043.
Q.
And, there is also a telephone number there?
A.
Yes.
Q.
And can you read what that is?
A.
(305) 494-9699.
Q.
Now, you are familiar with audits. But, you don't conduct
them, right?
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A.
Correct.
Q.
And, for purposes of conducting an audit, does the examiner
have to reach out to the taxpayer?
A.
Yes. There is back and forth contact.
Q.
And, they would use that phone number?
A.
Yes.
Q.
And, mail correspondence to that address?
A.
Correct.
Q.
Now, this first entry, this is the first entry on this
entire document. What does that represent if it is the first
entry?
A.
This is the date that everything initially started with the
audit; first entry is first contact.
Q.
Okay. And, what was the date here?
A.
December 8th of 2020.
Q.
There are remarks listed in each one of these sections.
You referenced what this meant, the impetus of the audit. But,
there are some sections here, I guess, that referenced TP.
What does TP stand for?
A.
Taxpayer.
Q.
Okay. And, you see the section -- I think it is the fourth
or fifth, maybe even the sixth sentence there, starting with,
"An in depth."
A.
Okay.
Q.
What does that say?
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A.
An in-depth income probe may be warranted, depending on
taxpayer's interview answers.
Q.
Okay. So, are interviews custom when an audit is
conducted?
A.
Yes.
Q.
I will draw your attention to the next entry here.
Can you tell us the date of this entry?
A.
December 16th of 2020.
Q.
And, what does the entry represent?
A.
It says Form 8821 received, and remarks received Form 8821
from taxpayers new power of attorney, Vilsaint St. Louis, who
is the return preparer. He faxed Form 8821 to centralized
authorized function, called power of attorney, discussed the
issues that were under review for taxpayer. Power of attorney
needs to review 2018 and 2019 returns more fully to be prepared
to answer the questions on Monday. While discussing carryover
cash contributions, power of attorney stated that he thought
you could claim these every year. Made a time for a telephone
appointment on December 21, 2020, at noon.
Q.
Okay. So, I saw a couple of acronyms there.
You were saying "point of contact."
That is POA?
A.
Yes.
Q.
And TP is taxpayer?
A.
Yes.
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Q.
And, in this instance, a Form 8821 is?
A.
It is an authorization for somebody to be a power of
attorney to act as -- to call on their behalf and to act for
them.
Q.
And, that is a limited power of attorney for purposes of
the audit?
A.
Correct.
Q.
Continuing on this section, what does it say about the
F-8821?
A.
The Form 8821 is very limited. The POA or the power of
attorney has very little representation ability. The power of
attorney cannot stop the tax compliance officer from
interviewing the taxpayer. Reviewed the revenue procedure
2014-42, and emails from 2015 describing the new instructions.
"The AFSP appears to only be in effect for Form 2848s.
Therefore, Mr. St. Louis may still provide tax information on
behalf of taxpayer. Called Mr. St. Louis and explained this.
Tax compliance officer will interview taxpayer via phone
separately.
Power of attorney provided a good cell phone number for the
taxpayer. Set a deadline of January 13, 2021, for taxpayer to
provide all documents. Power of attorney stated he will try to
have all documents faxed asap and well before January 13,
2021."
Q.
Okay. In this, that entry references an interview, an
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upcoming interview with the taxpayer?
A.
Yes.
Q.
This next section, another entry is dated what?
A.
December 17 of 2020.
Q.
And, what -- is it referenced regarding a telephone
interview?
A.
Yes.
Q.
What is it, generally?
You don't have to read it out, but just summarize.
Effectively, what was that representing happening?
A.
"The tax compliance officer took testimony as to how her
returns were prepared with the return preparer, Vilsaint
St. Louis. Taxpayer agreed to answer more questions if
necessary. Tax compliance officer explained the next steps in
the examination."
Q.
What else does it say there, to review records?
A.
"Tax compliance officer explained that the next steps in
the examination were to review her records, which she states
are with the return preparer. Later discussed with the group
manager Susan Miller to ensure consistent discussions with
return preparer who submitted Form 8821."
Q.
I am showing you, side by side here, this has been marked
as Government's Exhibit 203B and admitted into evidence. I am
going to go down to a section here that refers to that entry.
Okay. I am on Page 6 of 203B. What is the jury seeing here?
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A.
The initial interview questions and notes.
Q.
And, this is -- there is a date listed up here in the
right-hand corner. Is that the date of the interview, or the
date this was produced to the U.S. Government?
A.
I am -- I'm not sure. I don't know.
Q.
Why don't we go into the body of the interview to answer
that.
I am highlighting the substantive session of the
interview. Can you read this area for the jury?
A.
"Comments," okay. "12-17-2020, BSO deputy, revenue
examiner agent on the side. Taxpayer has been having
Mr. St. Louis prepare her returns for four to five years.
Taxpayer makes an appointment and goes to the Davie office.
She takes her W-2 and Form 1099 miscellaneous and Form 1098.
She takes in some of the receipts of purchases, advertising, CC
statements, gas receipts, supplies for home office, et cetera,
for the Schedule C expenses."
Q.
I am going to actually do one paragraph at a time so it is
bigger for everybody to see. Thank you for that. Okay.
A.
"She and return preparer figure out the expenses together.
TP doesn't really know exactly how they come up with the
figures. She has a figure in her head as to what she spent and
then she gives him her paperwork. She believes she has
analyzed -- she believe he analyzes it pretty well since she is
there for a while. She says that the figure he puts on the
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Schedule C is pretty close to what she has in her head.
She sat with Vilsaint St. Louis for 2018 and 2019. She
does not know Jesus M. Medina, who signed her 2018 return. She
doesn't remember whether she received copies of the returns or
not. She has not reviewed her returns since she got the letter
6323. She simply called the return preparer, and he said he
would take care of everything about the examination."
Q.
It goes on.
A.
"Taxpayer recalls that return preparer went over the
returns with her each year; however, she can't recall if she
had any questions about any part of them since it was a while
ago.
TP paid via credit card.
Taxpayer received direct deposits.
Taxpayer cannot recall if she signed anything.
Taxpayer states that return preparer told her if the IRS
had questions, she should ask for his assistance and he would
assist her.
After explaining some of the expenses on the 2018 Schedule
C, taxpayer reiterated that all the figures and expenses on the
schedule Cs are info that she and the return preparer came up
with together.
Q.
There are more sentences at the end here.
A.
She did not leave it all to him. Tax compliance officer
explained that she may have more questions in future, and
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taxpayer agreed to answer them if needed."
Q.
Now, we referenced a prior entry in the case history report
that the tax preparer would send in records supporting the tax
return; correct?
A.
Correct.
Q.
I am going to show you what has been entered as
Government's Exhibit 203F.
Now, what is -- what does the record here reflect as far as
the date of this document?
A.
December 29th, 2020.
Q.
And, would that be the day that it was faxed to the IRS?
A.
Yes.
Q.
And, who is it faxed from?
A.
Victory Tax, Inc.
Q.
And, at the top here, what type of form is this, and what
is the information that it is portraying?
A.
This is a taxpayer questionnaire for Alexandra Acosta.
Q.
And, it has her personal information there?
A.
Yes, it does.
Q.
Including the email address we have previously seen on
other records?
A.
Yes.
Q.
The social security number that we have seen in the other
records?
A.
Yes.
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Q.
It includes information about her bank?
A.
Yes, it does.
Q.
And what would that he about for?
A.
I am assuming for -- well, that bank information would be
for refunds.
THE COURT: Is that still an active bank account?
MR. JONES: Truist is now -- SunTrust is Truist now.
THE COURT: So, we need to redact these documents
before you actually file them.
MR. JONES: Absolutely.
THE COURT: And so, since I just interrupted, so
members of the jury, I remember at the beginning of my
instruction I told you that there may be times when evidence or
testimony is admitted for a limited purpose. So, this
testimony concerning the defendant's tax returns and audits,
okay, is one of those areas that is not directly part of the
charged offense.
She is not charged with any tax crimes. And, so, this
evidence, okay, is only admitted for a limited purpose.
You must not consider this evidence to decide whether
the defendant engaged in the activity that is alleged in the
superseding indictment. This evidence is admitted and may be
considered by you for the limited purpose of assisting you in
determining whether the defendant had the state of mind or
intent necessary to commit the crimes charged in the
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superseding indictment, whether the defendant had a motive or
opportunity to commit the acts charged in the superseding
indictment, whether the defendant acted according to a plan or
in preparation to commit a crime, or whether the defendant
committed the acts charged in the superseding indictment by
accident or mistake.
Go ahead.
MR. JONES: Thank you.
BY MR. JONES:
Q.
I will be showing you a split screen of Government's
Exhibit 201, Government's Exhibit 203F that we were just
discussing.
Now, this form that is received in the audit
purportedly corresponds to the 2019 tax return. And I just
want to show you a section of Government's Exhibit 201, listing
dependents. Do you see that?
A.
Yes.
Q.
And, does that correlate with the information that was
listed here --
A.
Yes.
Q.
-- in Government's Exhibit 203F; correct?
A.
Yes.
Q.
Scrolling further down to the section of 203F, regarding
expenses, did you have a chance to look at those?
A.
Yes, I did.
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Q.
And, do those expenses correlate with the expenses listed
here in the tax return?
A.
Yes, it did.
Q.
Likewise, Victory Taxes also faxed over a 2018
questionnaire; correct?
A.
Yes.
Q.
I apologize. I am just going to draw up the 2019
questionnaire. We will bring it down here to the bottom.
After all these expenses were listed, after the dependents
are listed, there are some more itemized expenses; correct?
A.
Yes.
Q.
Okay. And then at the end of that form, is there a section
entitled Taxpayer Questionnaire Review?
A.
Yes.
Q.
And what does that say?
A.
"The above information is true and correct, and we
understand that the information given in this questionnaire
will be used to complete my" -- I am not sure what -- does that
say 2012 tax return"?
Q.
It does.
MR. SILBER: Objection, speculation.
THE COURT: Overruled.
BY MR. JONES:
Q.
In essence, what is the certification here?
A.
It is stating that the information is complete and true.
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Q.
What is the date?
A.
February 4, 2020.
Q.
And, does it appear to be signed by the taxpayer?
A.
Yes.
Q.
As we discussed, likewise, there is a 2018 questionnaire
that was received at the same date and time?
A.
Yes.
Q.
And, this was for the same taxpayer?
A.
Yes. It is.
Q.
And, when you reviewed this record compared to the 2018 tax
return Schedule C, were the expenses listed on this Schedule C
matching up to this one, as well?
A.
Yes, it was.
THE COURT: All right. Let's take our morning recess.
It is 20 of 11. See everybody in 15 minutes, at five of 11,
all right?
15 minutes.
COURT SECURITY OFFICER: All rise for the jury.
[Whereupon, the jury left the courtroom, and the
following proceedings were had at 10:40 a.m.:]
COURT SECURITY OFFICER: All rise.
THE COURT: Thank you, be seated.
We still have a couple of minutes.
THE COURT: All right. Bring in the jury.
COURT SECURITY OFFICER: All rise for the jury.
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[Whereupon, the jury entered the courtroom, and the
following proceedings were had at 10:55 a.m.:]
THE COURT: All right. Welcome back, everyone. Please
be seated.
All right, Mr. Jones.
MR. JONES: Thank you, your Honor.
BY MR. JONES:
Q.
When we left off and we were just going over Government's
Exhibit 203E, and you were on Page 4, and I asked you whether
these expenses listed matched up to the Schedule C for the 2018
tax return year. And your testimony was yes.
And then, going down a little further, you also had a
chance to review and compare itemized expenses. And, those
were reflected on the tax return, as well?
A.
Yes, they were.
Q.
Now, this one for full disclosure is not signed by anybody;
correct?
A.
Correct.
Q.
We are going back to Government's Exhibit 203A. We last
left off, well -- just to bookend, the documents that we just
discussed as being facts, does this entry -- what is the date
of this entry?
A.
December 29th of 2020.
Q.
And, what does it represent?
A.
It is a telephone contact.
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Q.
And, what does the -- what does this entry state?
A.
"Power of attorney on 12-23 left a message on December 23rd
2020, stating he was faxing taxpayer's documents. As of
December 29, 2020, no documents had been received. Called
power of attorney, who stated he will fax over organized and
easy to understand substantiating documents ASAP.
Later received faxes relating to 2018 and 2019. Reviewed
the pages and called power of attorney back stating that what
was sent needs more explanation. Taxpayer must provide mileage
logs and odometer readings and provide more source
documentation to substantiate the expenses claimed on both 2018
and 2019 Schedule A -- excuse me, Schedule Cs. Excuse me.
POA admitted that he duplicated real estate taxes on
Schedule A.
POA -- power of attorney admits that he duplicated car
expenses by giving mileage and actual expenses on Schedule C.
Power of attorney states he did not understand the tax
rules.
Power of attorney states tax compliance officer to call him
and let him know what is missing from the documentation so he
and taxpayer can provide it. Tax compliance officer explained
she will call after a more complete review."
Q.
And, there are additional entries here. One -- let me just
highlight the -- this entry here. What is the date?
A.
January 12 of 2021.
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Q.
What are the remarks?
A.
"Power of attorney called and stated that the taxpayer does
not have any other documents to provide as of today. Return
preparer plans to talk to her and ask for one more effort on
her part to secure substantiation documents. Tax compliance
officer set a deadline of October 15, 2020, for power of
attorney to fax any new documentation.
Q.
And the next entry?
A.
January 13, 2021, "Worked on data received.
"Reviewed all documents taxpayer sent in to date.
"Prepared lead sheets.
"Added new issues for qualified business income deduction
in case taxpayer has income after all other adjustments.
"Added new issues for taxes and licenses to increase
taxpayer's credit based on information provided. Reviewed
Accurint for marriage information. No evidence of marriage.
However, TP's co-owner of her home and mother of her dependent
has the same Erin Acosta."
Q.
And that ends with "which?"
A.
Yes, "Which indicates there may be a marriage. Tax
compliance officer tried calling taxpayer but no answer and no
voicemail. Tax compliance officer will determine if a new
issue is necessary after discuss."
Q.
I cut that off?
A.
"After discussing with taxpayer."
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Q.
Okay. Now, there is another entry here. What is the date
of that?
A.
January 19, 2021.
Q.
What does the first sentence say?
A.
"No additional documents received from taxpayer or power of
attorney."
Q.
And, there is some other notes here about contacts with the
taxpayer or tax preparer?
A.
Did you want me to keep going?
Q.
You don't need to read this. Thank you.
Well, there is something here.
This next, this next entry?
A.
January 21, 2021, letter 30 days. Acting manager provided
signed letter 915 and letter S300.
Generated Form 4549. Mailed 4549, letter 915, Form 9465,
publication 3498 to taxpayer.
Mailed Form 4549, letter 951, letter 937 to power of
attorney.
Q.
And, in this instance, this letter, what exactly would this
be?
A.
The letter.
Q.
What does it signify?
A.
The correspondence sent to the taxpayer.
Q.
And, I am going to pull up Government's Exhibit 203C.
Can you tell us the date of this letter?
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A.
January 21, 2021.
Q.
And, who this letter mailed to?
A.
Alexandra Acosta.
Q.
And the address?
A.
7200 Northwest 94th Way, Tamarac, Florida 33321-3043.
Q.
And, this first -- this first section, what does it
explain?
A.
"We have enclosed two copies of our examination report
showing the changes we made to your tax for the periods shown
above. Please read the report and tell us whether you agree or
disagree with the changes."
Q.
Now, this -- this form, that is a letter. This is mailed
out U.S. mail?
A.
Yes, it is.
Q.
I am going to show you Government's Exhibit 203D.
Do you recognize what 203D is?
A.
This is the Form 4549.
Q.
And, what is the title of that document?
A.
"Report of Income Tax Examination Changes."
Q.
We have been using the term audit. Is the income tax
examination another term for audit?
A.
Yes.
Q.
So, what does this document reflect?
A.
The changes that were made to the tax returns for the
specific years.
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Q.
And, which years were there adjustments made to?
A.
Tax year 2018 and 2019.
Q.
Now, without going through exactly what the IRS determined
were excessive charges or unsupported charges at that time,
let's take a look here at the bottom section. What does number
19 represent?
A.
Number 19 is the summary of taxes, penalties, and interest.
Q.
And what was the balance due for taxes?
A.
Balance due, for one year was $9,733, and for the other
year was 4,760.
Q.
And, is this the amount of money owed to the IRS as unpaid
taxes from those years?
A.
Yes.
Q.
And, what is subsection B of that line?
A.
Penalties.
Q.
And, what is the amount calculated for 2018?
A.
1,946.
Q.
And, what was the amount calculated for 2019?
A.
8,952.
Q.
And is there also a subsection C here?
A.
Yes, for interest.
Q.
And what is that?
A.
For 2018, it was $995.95, and for 2019, it was $104.
Q.
Now, at this bottom line, D, it says what?
A.
"Amount due or refund."
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Q.
And, how much was due for the 2018 tax year?
A.
$12,675.55.
Q.
And how about the 2019 tax year?
A.
$5,816.
Q.
And I will not make you do math on the stand.
A.
Thank you.
Q.
But, is that roughly around $18,500?
A.
Yes.
Q.
Now, you mentioned this was mailed out in U.S. mail?
A.
Yes.
Q.
Can you describe to me the next entry?
A.
January 25, 2021, "Telephone contact, power of attorney
called and stated he and the taxpayer received the Form 4549
packages, power of attorney stated that the taxpayer will be
reviewing her records for more substantiation of the disallowed
expenses."
Q.
There is an entry here. It starts on the Page 3, but it
will carry over to Page 4 and I will go there.
But, what is the date?
A.
February 11, 2021, received SunTrust Bank statements.
Q.
And what is the entry?
A.
Received 19 faxes with taxpayer's SunTrust bank statements
where taxpayer has identified additional expenses. Reviewed
but found very few annotations.
Called power of attorney, who said there was only a few to
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consider.
Power of attorney also asked for an allowance for Internet
since taxpayer worked out of her home. Will review the
statement more fully as soon as possible."
Q.
There is another entry here.
A.
February 22nd, 2021, "telephone contact. Called power of
attorney, who stated he has the final documents from taxpayer
and will fax them tonight."
Q.
And, is there an entry for -- sorry. What is the next
entry?
A.
February 23, 2021, "Worked on data received. Received fax
from power of attorney with office dimensions and Home Depot
credit card statements. Evaluated, added issue for home office
expense. Prepared other lead sheets. Updated Schedule C
recap. Modified qualified business income deductions based on
all other adjustments. Called power of attorney and stated
evaluation was done. Power of attorney brought up advertising
expenses for which taxpayer has no substantiated had -- excuse
me.
"Power of attorney brought up advertising expenses for
which taxpayer has not substantiated, so, no credit has been
given.
"Power of attorney asked for penalty abatement.
"Tax compliance officer stated taxpayer must submit a
written statement.
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"Power of attorney will ask the taxpayer to write and send
the statement as soon as possible.
"Tax compliance officer will wait for the statement prior
to sending a corrected Form 4549 and letter 692.
"Added new issue for filing status based on taxpayer
testimony on February 1, 2021."
Q.
Now, it mentioned penalty abatement. And, is that in
correlation to the tax examination changes that referenced the
penalty?
A.
Yes.
Q.
And so the IRS has, in its own review, the ability to
charge penalties in certain circumstances, and not, in others?
A.
Yes.
Q.
And, that is based, I guess, on the level of conduct?
A.
Yes.
Q.
We are coming to the end here. But, just a few more. What
is this entry?
A.
March 1, 2021, "Telephone contact. Called power of
attorney and explained no statement has been received from
taxpayer regarding abatement of penalties and declaring her
reasonable cause. Discussed circumstances about reasonable
cause again with power of attorney. Power of attorney states
he will call the taxpayer again to explain what she must do.
Tax compliance officer will await the statement to consider
before sending out corrected Form 4549 and letter 692.
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Q.
Okay. Just for clarity, so we received -- it appears
that's a letter sent on January 21st; correct?
A.
Yes.
Q.
And then that included a statement of amount owed?
A.
Correct.
Q.
That wasn't final yet?
A.
No.
Q.
And so, at this point, in March of 2021, the audit is still
ongoing?
A.
Correct.
Q.
There is an entry that goes over two pages again. We are
on page -- forgive me -- Page 4, the bottom of Page 4, this
entry. What is the date?
A.
March 18, 2021, "Telephone contact, began closing.
Q.
Sorry. Can you read this section?
A.
Power of attorney called about other cases. Tax compliance
officer asked if taxpayer was going to sign Form 4549, and
power of attorney stated he will try to secure the signed Form
4549 by the end of the day.
"Solicited payment.
"Power of attorney states that the taxpayer cannot pay in
full within 120 days. Taxpayer will set up an installment
agreement with collections.
Began preparing cases for closure.
Secured IDRS prints?
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Prepared post cash T, made note" --
Q.
That is okay. Sorry. Yeah.
The next entry here?
A.
March 23, 2021, "Close unagreed."
Q.
And the remarks?
A.
"No response from taxpayer or POA; no signed 4549; prepared
case for closing. Labeled all documents received by taxpayer
or power of attorney."
Q.
Okay. Now, here is a longer one. What is the date of this
entry?
A.
April 1st, 2021, "Telephone contact."
Q.
Okay. And the remarks reference a different date?
A.
Yes. "On March 29th, TP -- taxpayer called tax compliance
officer to discuss case.
"Tax compliance officer explained the case was closed
unagreed due to no response. Taxpayer stated that she had been
calling and calling her return preparer/power of attorney who
would not return her calls. Out of frustration, she called the
tax compliance officer. Tax compliance officer explained all
allowances that had been given in detail based on taxpayer's
records submitted.
Taxpayer agreed that the nature of allowances are correct,
although taxpayer may have missed pointing out some expenses.
When questioned about how the inaccurate expenses got to
the Schedule Cs, taxpayer explained her return preparer,
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Mr. St. Louis, evaluated her books and records and placed the
analyzed figures on the Schedule Cs.
"Solicited payment.
"TP stated that she cannot pay the amount due in 120 days.
Taxpayer will have to set up an installment agreement with
collection. Taxpayer faxed a letter requesting abatement of
penalties. After careful consideration of taxpayer's oral and
written testimony against a return preparer, tax compliance
officer will abate penalties. Prepared corrected 4549 mailed
to TP, and power of attorney with letter 692 and letter 937.
Q.
Now, this referenced a letter statement from the taxpayer?
A.
Correct.
Q.
Was that in the records, as well?
A.
Yes.
Q.
Let me show you Government's Exhibits 203G.
Sorry. I should have told you to pack lozenges or
something.
What is the date of this?
What is the date of this at the top?
A.
March 29, 2021.
Q.
And who is it to?
A.
Phyllis Kampmeyer.
Q.
Phyllis Kampmeyer, the auditor?
A.
Yes.
Q.
And, who is it from?
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A.
Alexandra Acosta.
Q.
And, is it signed and dated?
A.
Yes, it is.
Q.
What is the date?
A.
March 29, 2021.
Q.
We are going to go in blocks so you can see it a little
easier. But, can you read the first portion?
A.
"I, Alexandra Acosta, gave my tax preparer Vilsaint
St. Louis from Victory Taxes several credit card and bank
statements from previous years to prepare my taxes, along with
my W-2 and 1099s. To the best of my knowledge, in both 2018
and 2019, due though to his busy schedule, he had me drop off
my paperwork, then had me return at a later date to sign it.
"In both those years, I did not sit with St. Louis to
complete my tax return. As a matter of fact, I specifically
used Mr. St. Louis as my preparer and, after the audit, I
noticed another preparer filed my taxes one of those years.
"After I carefully reviewed my tax returns pre- and post
exam and credit and bank statements from 2018 and 2019, I see
that the expenses on my tax returns do not match the expenses
on my bank and credit statements.
"I do not know where Mr. St. Louis produced some of the
figures in my returns.
"I have also asked Mr. St. Louis if I needed to file single
or married since I am married, and he stated to me that,
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according to tax law, I do not need to file married.
"After our conversation today, I understand that it is, in
fact, a law, and I will file married in future tax
preparations."
Q.
Okay. Now, as a result of this letter, the IRS changed its
penalties associated with the income tax examination?
A.
Yes.
Q.
I am showing you what has been admitted as G's
Exhibit 203H.
Do you recognize this?
A.
Yes, I do.
Q.
And what does it state up here?
A.
It is the corrected report.
Q.
Okay. This is for the same period, 2018, 2019?
A.
Yes.
Q.
Is this, in effect, an updated report from the report that
was sent on January 21, 2021?
A.
Yes.
Q.
Now, in this -- this report, we can go through the summary
here, 19, the balance due for 2018 was?
A.
$9,042.
Q.
And for 2019?
A.
$1,071 -- I can't --
Q.
I will not testify, but I think it is a 4.
A.
It looks like a 1 here. 4,071 dollars.
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Q.
And, section B. Is there anything indicated in section B?
A.
No.
Q.
And, that is the penalties that are abated because of that
statement?
A.
Correct.
Q.
Total amount due?
A.
For 2018, $88,869.55. Or $0.65, sorry. And then for 2019,
$4,169.04.
Q.
And, approximately, that being 1400, or $14,000?
A.
Correct.
Q.
Is there any evidence -- or during your review, was this
balance ultimately paid off?
A.
I don't know.
Q.
Okay.
MR. JONES: One moment, your Honor.
BY MR. JONES:
Q.
Ms. Hernandez, thank you for traveling all the way here.
We appreciate you.
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, Ms. Hernandez.
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A.
Good morning.
Q.
Thank you for coming today. If you can just give me a
second to get set up here.
All right. Work with me a second. I have to go through
this binder and get to the right page.
All right. I am showing you what was previously
admitted as Government's Exhibit 203A.
Do you see that sticker there?
A.
Yes, I do.
Q.
The title of that, "Case History Report"?
A.
Yes.
Q.
Okay. Do you see all these boxes that are blank here?
A.
Yes.
Q.
Those are redactions, right?
A.
Yes.
Q.
And, can you tell me if those redactions were put in there
by the IRS?
A.
I don't know.
Q.
Okay. Here is another one.
Let me zoom in.
Do you see that redaction there?
A.
Yes, I do.
Q.
Do you know if the IRS did that one?
A.
I don't know.
Q.
Okay. All right. I am going to ask you some other
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questions about these documents.
There is a lot here, so I just got to go back and
forth. So, if you would just bear with me --
Okay. I am just going to highlight a couple of things
here.
Looking at the note entry on February 1, 2021, okay,
isn't it true that Mr. St. Louis told the tax compliance
officer that he didn't see anything wrong with annotating my
client as single on the 2018 and 2019 returns? Isn't that
true?
A.
That is what the notes say.
Q.
Okay. Well, that was -- you are correct. Let me rephrase
that. Your official IRS record that was maintained in the
normal course of business to memorialize all the comments and
statements made between the taxpayer, the tax preparer and the
tax compliance officer are in this document, correct?
A.
Correct.
Q.
Okay. So, isn't it true that this document memorialized
that he didn't see anything wrong with annotating her as single
when she was, in fact, married?
A.
I wasn't there, present in the conversation. So, I don't
know. I can't say what -- how he felt about it.
Q.
I know. But, that is in these records, isn't it?
A.
Yes, yes.
Q.
I am not asking you if you were part of the conversation,
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you are the records custodian; correct?
A.
Yes.
Q.
I am asking you, in your context as a records custodian.
He never learned that you could take only mileage or actual
expenses. Right?
A.
If it is on the record, if that's what it says, then okay.
Q.
Here is my question. And this may be outside of your job
function. But, I imagine you must have received training at
the IRS about basic tax principles and tax, how they work and
all that stuff; is that correct?
A.
I know a little about tax law, yeah.
Q.
And, were you familiar with that law about taking mileage
or actual expense?
Is that something you would have knowledge of?
A.
I am not tax-law trained, no.
Q.
That's fair enough. No problem. How about here. Okay.
Right here. This right here. 1-19, there is a record that he
indicated he was out of the office due to the birth of his
child; correct?
A.
The record states that.
Q.
And that was on -- is this the January 21st entry or is
that a January 19th entry?
A.
It looks like the January 19th.
Q.
19th. Okay. Either way, 19, 21, around that time period,
he had a baby.
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Okay.
Q.
And, here, on April 1st, 2021, TP means taxpayer again,
right?
A.
Correct.
Q.
She stated that she had been calling her RP, return
preparer; correct?
A.
Yes.
Q.
And POA, a power of attorney; correct?
A.
Yes.
Q.
Who would not return her calls, and, out of frustration,
she called the tax compliance officer; correct?
A.
Correct.
Q.
And here, in this note --
A.
It is a little blurry.
Q.
Oh, sorry. So, to be clear about one thing, I want to be
sure. Do you see where it says, "Comments," are these comments
that the tax compliance officer would have put into this field?
A.
Which form is this?
Q.
Examiner Phyllis Kampmeyer?
A.
Okay.
Q.
Do you see what I am referring to?
A.
Yes.
Q.
These notes in here, is that something the tax compliance
officer would have written?
A.
It looks like the examiner wrote that.
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Q.
Maybe I am saying the wrong thing. What is the difference
between the examiner and the TCO?
A.
The tax examiner, the auditor, and the tax compliance
officer are two separate people. They are from two separate --
I would say divisions of departments. They work two different
aspects of, I guess, the audit.
Q.
Understood. But, either way, these are notes about the
case; correct?
A.
Yes.
Q.
Okay. So, taxpayer -- meaning Ms. Acosta -- was not
educated in the field of taxes, and no intentional disregard of
rules or regulations was evident based on taxpayer's oral
testimony and all evidence provided related to the case; is
that correct?
A.
If that's the notes that were in there, yes.
Q.
Taxpayer used and relied on Mr. Vilsaint St. Louis as her
preparer to file an accurate return based on her circumstances.
Correct?
A.
Correct.
Q.
Taxpayer, Ms. Acosta, provided her preparer to -- whoops --
provided all documentation that was requested by the preparer.
Correct?
A.
Correct.
Q.
Taxpayer believed in good faith that the tax return was
accurate and compliant. Right?
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A.
Yes.
Q.
Taxpayer requested that no penalty be assessed given she
did not know the inaccurate figures that Mr. St. Louis placed
on her Schedule Cs?
A.
Correct. Yes.
Q.
And, isn't it true he admitted that he double-entered her
property tax; correct?
A.
He admitted?
Q.
I am sorry. He entered her property tax twice by accident?
A.
If it was on one of the reports, yes.
Q.
Well, I am asking you, are you familiar with these
documents?
A.
With the report, the documents, yes.
Q.
Yes. Okay. And isn't it true that part of the problem
with her taxes was that she got depreciation for her property
tax on her house twice. Isn't that correct?
A.
I am not sure about that one.
Q.
Okay.
A.
I didn't --
THE COURT: The depreciation or deduction?
You said depreciation twice.
MR. SILBER: I am sorry. I am using the wrong word. I
mean deduction. Thank you for pointing that out.
BY MR. SILBER:
Q.
Do you know now what I am talking about?
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A.
We didn't go over.
Q.
So, in one of her returns, there's a double entry for her
property taxes. Is that correct?
A.
Yes.
Q.
And, as a result of that, her taxable income was brought
down more than it should have been; correct?
A.
Yes.
Q.
And, it was an identical double entry, almost as if someone
hit enter twice; correct?
A.
Yes.
Q.
And, he admitted he made that mistake, didn't he?
A.
If he reported it in the notes; correct.
Q.
That was in the notes, wasn't it?
A.
Yes.
Q.
Okay. And, equally, we just saw a moment ago, he admitted
that he didn't understand that you can't deduct expenses and
the actual mileage; it is one or the other; correct?
A.
I am sorry, in the -- can you repeat the question.
Q.
He admitted in his discussions with whoever made these
notes that he was not aware you could only deduct actual
mileage or expenses, as opposed to both?
A.
Correct.
Q.
And, he said that on the things that he read and maybe the
classes he took, he was never explained that, was he?
A.
Classes?
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Q.
Whatever notation that was in there, things he read, there
is a reference to certain education, he said he never learned
that, in other words, right?
A.
I didn't see that. I am sorry.
Q.
Okay. All right. Looking at this 2018 return here, do you
see this page, the first page?
A.
Yes.
Q.
Okay. What I am looking for here, if you could point out
is where is the signature block on this document where the
person --
A.
On the first page?
Q.
That is on the first page. That is down here?
A.
Where it says sign here?
Q.
Here?
A.
Yes.
Q.
Okay. And, I see the asterisks, and you said that was a
digital signature, correct?
A.
Correct. This is an electronically filed 1040 return.
Q.
Okay. How is that -- if you know, how is that digital
signature derived?
A.
When you electronically file a return, when you transmit
it, electronically, the taxpayer provides a digital PIN number,
six numbers, individual PIN that they put in before they
transmit it to the IRS.
Q.
Okay. So, if I read this document correctly, just looking
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-- and, again, you are the records custodian, and I know you
were not involved in the details of this -- does this inform us
that the taxpayer, Ms. Acosta, is the one who electronically
filed this, or it was somebody else?
A.
I don't know. I wasn't there at the time.
Q.
Okay. So, looking at this document, you can't tell us if
Ms. Acosta was the person who filed this return, or was it
somebody else?
A.
I wasn't there at the time.
Q.
I am just saying, referencing the documents, I am only
asking you in your context as records custodian, looking at
this document, can you tell me who submitted this application?
Who submitted this return?
A.
I see that it is signed, but I wasn't there at the time it
was signed. I can't tell you who signed it.
Q.
Okay. Thank you.
All right. Let's move on to 2019.
I am showing you what has been previously admitted as
Government's 201. Do you see that right there?
A.
Yes.
Q.
Okay. All right. So, I see here, wages. This indicates
to us that in 2019, she earned -- she reported income of
$103,819; is that correct?
A.
Correct.
Q.
Okay. Do you recognize the back of this?
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A.
Yes.
Q.
Second page. Okay. Same question as with 2018.
Are you able to tell me, looking at this document, who
submitted the signature?
A.
I could see that it is signed.
Q.
It is signed. But, do you know who signed it?
A.
I was not there when it was signed.
Q.
Okay. And, this part with third-party designee, what does
that tell us?
A.
That Victory Tax, Inc., was given permission to speak on
behalf of that return, if any discussions were needed.
Q.
Let's talk about that for a second.
So, in the course of the audit, my client signed what
is called a power of attorney; correct?
I am an attorney, right?
What does power of attorney mean in the context of
these audits, if you know?
A.
For this Form 8821, which is an authorization form, was
signed and given to the preparer to speak on behalf of this
form.
Q.
And, of course, someone, a taxpayer would sign this
document so that their tax preparer or accountant or CPA,
whoever that person is, could interact with the IRS on their
behalf; correct?
A.
Correct.
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Q.
So, every notice will -- once you have the power of
attorney executed, that person, the attorney who has that,
maybe he is not a lawyer, but he has the power of attorney,
will get copies of all notices that were sent to the taxpayer;
correct?
A.
But, only for that specific tax year.
Q.
So throughout this entire process, Mr. St. Louis was
apprised of every step of this audit investigation; correct?
A.
If there was a letter 937 going out, then that letter was
going to him.
Q.
Okay. And, when my client mentioned that she needed a
payment plan, that was in the month of April of 2021, wasn't
it?
A.
Yes.
Q.
And, in the end, the tax that she was due was paid in full,
wasn't it?
A.
I don't know.
Q.
Okay. But, there was an installment plan initiated;
correct?
A.
From the notes I see, she did request a payment plan, yes.
Q.
And, as opposed to a person writing a check or hitting a
credit card and paying the whole thing at once?
A.
Yes, a payment plan is that.
Q.
And, that is done through the collections department of the
IRS, right?
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A.
Or, you could go online.
Q.
Online, or just submit your monthly whatever it is?
A.
Yes. You could set up a payment plan.
Q.
Okay. And a payment plan is exactly what happened in this
case, isn't it?
A.
I am not sure.
Q.
All right. You recognize this document?
A.
Yes, I do.
Q.
Government's -- sorry, my eyes are terrible. 203H.
Okay. This was issued on April 13, 2021; is that correct?
A.
Correct.
Q.
Okay. And I see here, penalties, B, that line is blank.
Does that mean there were no penalties assessed?
A.
That was the penalties were abated.
Q.
Okay. She didn't have to pay a penalty, did she?
A.
Yes, no -- I mean, the penalties were abated.
Q.
Okay. But, when you say "abated," that means she doesn't
have to pay it, right?
A.
They were -- per her request, the letter that she
submitted, the -- they were reversed. The penalties that had
been assessed were taken back.
Q.
So, in the end, she didn't have to pay it, right?
A.
No penalties were incurred.
Q.
Okay. So, at the end of the day, for 2018, I don't know if
you can see that 18 there --
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A.
Yes.
Q.
Do you see that?
A.
Yes.
Q.
Okay. She paid interest, okay. They never get rid of the
interest, right?
A.
The interest was there. They never abated the interest,
yes.
Q.
Right. So, she just basically paid the tax that was owed
and just a little bit of interest, and the same thing again
in -- we are here in '19?
Same thing here in '19, right, just the tax, a little bit
of interest, $98, right?
A.
Correct.
Q.
Okay. And, isn't it true in those notes, it is
memorialized that my client was frustrated and that she called
on her own to the TCO to find out what was going on with the
case?
A.
There were calls to the tax compliance officer, yes.
Q.
And, she mentioned, it is in those notes that the taxpayer,
my client tried reaching Mr. St. Louis, but was unable to;
correct?
A.
Correct.
Q.
And, isn't it true that there was a portion of these notes
where the tax compliance officer is, in essence, correcting
Mr. St. Louis and advising him of the limits of his
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representation?
A.
I am not sure.
Q.
Let me get to that. Hold on.
Sorry, just bear with me one second.
I am sorry. I am just lost in my paperwork here.
That's okay. We will get to that one later.
Now, it was established in their discussions that my
client is a full time BSO deputy as well as a part-time real
estate agent; is that correct
A.
Yes.
Q.
Okay. And, isn't it true that in 2019, on her Schedule C,
she reported to the IRS that she earned $13,900; correct?
A.
Correct.
Q.
And, whatever calculation was done with the expenses of the
business, she reported and she paid accordingly; correct?
A.
Yes.
Q.
And then that was later corrected when the audit was done
because the double entry, the mileage, those things we already
discussed, and then she was assessed the tax later; correct?
A.
Correct.
Q.
And, she has paid that tax in full; correct?
A.
I don't know if she has paid in full.
Q.
Okay.
MR. SILBER: Can I have a second, your Honor?
THE COURT: Yes.
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MR. SILBER: Thank you.
All right. Nothing further for this witness at this
time.
THE COURT: All right.
Do you have redirect?
MR. JONES: Yes, your Honor.
MR. SILBER: Your Honor, before the Government begins,
I actually found the page that I wanted.
Can I ask one question more?
THE COURT: Sure.
MR. SILBER: Thank you.
And, I am not a paperwork guy.
(Continuation of cross-examination.)
BY MR. SILBER:
Q.
All right. It is right here.
THE COURT: What exhibit are you showing her, just so
we keep track.
MR. SILBER: Sorry. You know what, I pulled the wrong
one. Never mind. We will get to it later. Thank you.
THE COURT: Okay. Well, they are all in evidence,
right.
MR. SILBER: Yes, exactly. We will address it later.
THE COURT: Okay.
MR. JONES: Your Honor may I have the -- thank you.
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REDIRECT EXAMINATION
BY MR. JONES:
Q.
You were asked about the signatures on the tax returns. I
will bring your attention back to Exhibit 201. This is the
2019 tax return for Ms. Alexandra Acosta. And, Page 4, we
have a paid preparer's due diligence's checklist, as you
testified, that was something that was completed by the
preparer; correct?
A.
Correct.
Q.
And, we also discussed Government's Exhibit 203F, which is
a taxpayer questionnaire; correct?
A.
Correct.
Q.
And, as we went through this 203F, we discussed the
information that was listed in this form; correct?
A.
Correct.
Q.
And, I asked you whether it matched with the information in
the schedule or in the 2019 tax return. Correct?
A.
Correct.
Q.
And, what was your testimony?
A.
All the information matched.
Q.
And, at the bottom here, of Government's Exhibit 203F, was
it signed?
A.
Yes, it is.
Q.
And is that an electronic signature?
A.
No, it is not.
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Q.
Is that asterisks?
A.
No, it is not.
Q.
What was the date?
A.
February 4th of 2020.
Q.
Could you tell me the date that is listed here on the tax
return?
A.
February 4, 2020.
Q.
Defense counsel also brought up a power of attorney. Now,
this is from the entry of 12-16. This is at the beginning of
the audit. And, what does it say here, right after this
redacted portion?
A.
The Form 8821 is very limited. The power of attorney has
very little representation ability.
Q.
And, he asked you about these redactions, but these records
are what was produced to the United States in response to a
request?
A.
Yes.
Q.
Mr. Silber also asked you about the abatement of penalties.
He went through some of the notes on this penalty sheet
with you; correct?
A.
Correct.
Q.
Can you tell me the date of the interview with Ms. Acosta
in the beginning of this audit?
A.
December 17th, 2020.
Q.
What does she state?
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A.
She and the return preparer figured out the expenses
together.
Q.
What else does she state here, this second sentence?
A.
She sat with Vilsaint St. Louis for 2018 and 2019.
Q.
How about this last sentence?
A.
After explaining some of the expenses on the 2018 Schedule
C, taxpayer reiterated that all figures and expenses on the
Schedule C are info that she and -- that she and the return
preparer came up with together.
Q.
And, following that information, without receiving any
additional records supporting her taxes for that year, you
testified that the IRS sent an examination change report;
correct?
A.
Correct.
Q.
And, that report had penalties and interest included?
A.
Correct.
Q.
And, that was based on the information that was obtained,
to that date?
A.
Yes.
Q.
Now, in contrast, I will show you Government's
Exhibit 203G.
What does she say here in this first full sentence?
A.
"I do not know where Mr. St. Louis produced some of the
figures in my returns."
Q.
How about this other sentence here?
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I will start here, the full sentence for you, that would
make more sense.
A.
"To the best of my knowledge, in both 2018 and 2019, due to
his busy schedule, he had me drop off my paperwork then had me
return at a later date to sign it. In both those years, I did
not sit with Mr. St. Louis to complete my tax return. As a
matter of fact, I specifically used Mr. St. Louis as my
preparer and, after the audit, I noticed another preparer filed
my taxes one of those years."
Q.
Now, this was in response to the TCO's request for a letter
if they wanted abatement of penalties, right?
A.
Correct.
Q.
And, those penalties were abated because of her own
statements?
A.
Yes.
Q.
Not because she provided substantiating records?
A.
Correct.
Q.
Mr. Silber also talked to you or he mentioned that this was
all just because of real estate double reporting. I am going
to show you the examination report again.
Now, based on this, this is the -- this is Government's
Exhibit 203D. Let me -- I will go one year at a time here,
now.
It is going to bother me if I don't get the zeros on
there. I apologize
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So, what does this represent for the period ending
2018?
A.
Just adjustments for income, for Schedule C, the adjusted
gross income itemized deduction and qualified business income
deduction.
Q.
And this, these numbers, so, B, here, other expenses,
$9,214, does that represent expenses that were not qualified,
or not supported?
A.
What do you mean? I am sorry.
Q.
There is a total adjustment level down here into $34,571.
Right?
A.
Okay.
Q.
Is that a computation of all these adjustments to her
income that year?
A.
Yes.
Q.
And so in here, are there expenses listed that were
adjusted for -- for example what is subsection E, 1E?
A.
Oh, that is the line number for the schedule.
Q.
Okay. And what does it say next to it?
A.
Repairs and maintenance.
Q.
Does that have anything to do with real estate taxes?
A.
No.
Q.
And, does this indicate that that income should be
attributed back to her 2018 return, that $8,147, was expenses
that shouldn't have been used?
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A.
Those were the adjustments that were -- those were the
expenses that were on the Schedule C that were adjusted.
Q.
Correct. Unsupported?
A.
Yes, sorry.
Q.
And, likewise, supplies? 1D, correct?
A.
Correct.
Q.
Is that real estate taxes?
A.
No, it is not.
Q.
How about 1C, travel?
A.
No.
Q.
Is that real estate taxes?
A.
No, it is not.
Q.
How about 1G?
A.
Advertising, no.
MR. JONES: No further questions, your Honor.
MR. SILBER: Your Honor, I found the two documents I
wanted to ask. Would you allow me to reopen so we could
address that?
THE COURT: Okay. All right.
MR. SILBER: I appreciate it.
RECROSS-EXAMINATION
BY MR. SILBER:
Q.
Okay. I found the documents. All right. So, here we are.
Do you remember when I asked you about his comment that was
recorded in here about what he studied?
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Do you remember that part of my cross-examination?
A.
Yes.
Q.
Okay. So, power of attorney, that is Mr. St. Louis, right,
stated he didn't see anything wrong with annotating her as
single. We covered that, right? H?
"Tax compliance officer explained that the taxpayer
must file as -- what does MFJ stand for?
A.
Married filing joint.
Q.
With Ms. Thomas as Ms. Acosta's wife, right?
A.
Right.
Q.
Keep going here. What is MFS or HOH?
A.
Married filing separate, or head of household.
Q.
If the circumstances dictate, power of attorney, also
return preparer, right?
A.
Yes.
Q.
And, by the way, the return preparer is the person who
fills out the tax return and puts all the numbers in, right,
based off what the taxpayer information that is provided,
presumptively. Right?
A.
A taxpayer --
Q.
Well, for example, he admitted that he had an erroneous
double entry. She didn't provide him with two property taxes,
right?
He admitted he made a mistake?
A.
I wasn't --
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Q.
These records reflect that he admitted he made a mistake?
A.
Okay.
Q.
Yes?
A.
Okay.
Q.
Is that what these records indicate?
A.
I don't know.
Q.
Okay. Now, you don't know.
All right. "Tax compliance officer points out that the
power of attorney stated his case that he never learned you
could only take mileage or actual expenses. He never learned
this at any of the IRS forums or read this in any of the tax
law books he reviewed.
"The tax compliance officer explained that this is one
of the first things that a good return preparer learns about,
and that he is very mistaken, very mistaken about taking
mileage and in capital letters, and actual expenses which he,
he, not taxpayer, which he took on the 2018 and 2019 returns."
Right?
This is what was memorialized in the tax audit report
as his comments and her comments, correct?
A.
It is notated.
Q.
Okay. All right. This is an April 1st, 2021, entry;
correct?
A.
Correct.
Q.
Okay. On March 29, 2021, the taxpayer called --
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101
Ms. Acosta -- called tax compliance officer to discuss the
case. TCO explained that the case was closed due to no
response. Taxpayer stated that she had been calling and
calling her return preparer power of attorney who would not
return her calls.
Correct?
A.
Correct.
Q.
Out of frustration, she called the tax compliance officer.
Right?
The tax compliance officer explained all the allowances
that had been given in detail based on the records, blah blah
blah, and it goes on.
The point being, my client had to call on her own because
her power of attorney wasn't doing it for her, was he?
A.
Yes. That's what the note says.
Q.
Thank you.
Nothing further, your Honor.
MR. JONES: Can I briefly address that, your Honor?
THE COURT: Okay.
REDIRECT EXAMINATION
BY MR. JONES:
Q.
Mr. Silber asked you about the February 1st entry here.
A.
Yes.
Q.
He described how the notes reflect how bad of a tax
preparer Mr. St. Louis was?
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A.
Yes.
Q.
Who was with Mr. St. Louis during this conversation?
A.
Power of attorney and taxpayer called in.
Q.
Does that reflect that the tax preparer was there during
the conversation?
A.
Yes.
Q.
And then here, Mr. Silber was stating that the tax preparer
had to call in out of frustration?
A.
Yes.
Q.
Can you tell me what the entry for March 23 states?
A.
"No response from taxpayer or power of attorney."
Q.
Thank you.
MR. JONES: No further questions.
THE COURT: All right, thank you.
(Witness excused.)
All right, folks it is afternoon. Let's take our
luncheon recess. See everybod back at 1:30. All right? 1:30.
COURT SECURITY OFFICER: All rise.
[Whereupon, the jury left the courtroomat 12:05 p.m.,
and the following proceedings were had:]
COURT SECURITY OFFICER: All rise.
THE COURT: All right. Bring in the jury, please.
[Whereupon, the jury entered the courtroom at 1:32
p.m., and the following proceedings were had:]
THE COURT: All right. Welcome back. Please be
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seated.
Who is the Government's next witness?
MR. JONES: Government calls Special Agent Tonya
Johnson.
THE COURT: All right.
Thereupon:
TONYA JOHNSON
was called as a witness and, having been duly sworn, was
examined and testified as follows:
THE WITNESS: I do.
THE COURT: When you are ready, please tell us your
name and spell your last name.
THE WITNESS: Tonya Johnson, J-O-H-N-S-O-N.
THE COURT: Thank you.
DIRECT EXAMINATION
BY MR. JONES:
Q.
Ms. Johnson, can you tell us where you work?
A.
I work for the Office of Inspector General for the Federal
Reserve Board.
Q.
And what exactly is that?
A.
I am a special agent, and we investigate federal financial
crimes as they relate to banks that we regulate.
Q.
And how long have you worked there?
A.
Since May of 2021.
Q.
Prior to working at the Federal Reserve, where else did you
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work?
A.
I was a special agent for Department of Defense, Office of
Inspector General. And then, before that, I was a special
agent for IRS criminal investigations, or for approximately
nine years.
Q.
And what is the IRS criminal investigations? What were
your jobs and duties there?
A.
It is similar to what I do now, except for we had expanded
jurisdiction over tax laws. So, we would investigate financial
crimes related to the tax code, which is Title 26, and the
money laundering Control Act, which is Title 18, and then the
Bank Secrecy Act violations, which is Title 31.
Q.
And when did you switch to the Department of Defense?
A.
That was in December of 2018.
Q.
Do you have formal education?
A.
I do. I have a bachelor's degree in Accounting with a
double minor in criminal justice and psychology, and then I
have a Master's Degree in Business Administration.
Q.
Now, when you were with -- in 2020, and 2021, early 2021,
you were with the Department of Defense?
A.
Yes.
Q.
And had you investigated any PPP fraud at that time?
A.
I didn't have cases specifically to me. But, I was aware
of the -- I guess the violations that were becoming known to
federal law enforcement at that time.
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Q.
And how was that?
A.
We had different trainings regarding the CARES Act
violations and how it affected the Department of Defense at the
time.
Q.
Was it in the summer of 2020, the fall of 2020, was there a
lot of correspondence in your law enforcement agency about
CARES Act fraud, or PPP fraud?
A.
Yes. They had formal trainings. I know there was task
forces that were created at different agencies in the U.S.
Attorney's Office to kind of get ahead of some of the fraud
that we were becoming aware of, and misuse of PPP funds.
Q.
And, were you involved in the investigation in the
superseding indictment in this case --
A.
Yes, I was.
Q.
-- charging Vilsaint St. Louis and Alexandra Acosta?
A.
Yes.
Q.
How did you become involved in the investigation?
A.
Broward Sheriff's Office had contacted the United States
Attorney's Office and notified them that they were aware of
paycheck protection violations related to some of their
employees.
Q.
And, with that information, what did you do next?
A.
So, I reached out to that Pandemic Response Accountability
Committee, which is the PRAC, and requested information
relating to some of the individuals that we became aware of
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relating to the fraud.
Q.
So, you said -- again, PRAC, what does it stand for?
A.
Pandemic Response Accountability Committee.
Q.
Just, I guess explain to the jury what that is.
A.
They have access to SBA data, and that is a group of OIGs
that were tasked with -- following the pandemic, to investigate
any fraud or waste as it related to the COVID funds.
Q.
And what type of information did they have available for
law enforcement?
A.
They did run certain database checks. But, the main thing
was they had access to the SBA data on a rolling basis, so they
could let them know if there was PPP loans for certain
individuals, or other CARES Act loans.
Q.
And so, was the data similar to what was included in the
application, itself?
A.
Yes. It came in a spreadsheet form. It was essentially
the PPP application in a format version, so it listed the
individual's identifiers, the PPP lender, the dollar amount,
whether it was forgiven or not.
Q.
And, did you retain or obtain that information for this
case?
A.
Yes, I did.
Q.
Now, what else -- what other types of, with that
information, what did you -- what did you do next?
A.
So, the information was that the lender was Cross River
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Bank? So, we issued a subpoena to Cross River to get the
entire loan file.
Q.
Did you issue any -- or did you receive any records from
BSO at all?
A.
Yes, we also requested the outside or off-duty employment
forms for Alexandra Acosta.
Q.
And, at this stage of the investigation, what exactly are
you trying to determine?
A.
We were trying to determine, one, if there was a loan, if
there, in fact, was a loan, and if Alexandra Acosta reported
any off-duty employment to Broward Sheriff's Office.
And, we wanted to review the loan file to see what was in
there.
Q.
And I am not sure if you mentioned this, but did you get
the information about the PPP lender from the PRAC?
A.
Yes. That was Cross River, when we issued a subpoena to
Cross River for the loan file.
Q.
And what information -- you have been here sitting through
trial. The Government has admitted Government's Exhibits 100
through 102. Were those the records produced in response from
Cross River?
A.
Yes, yes.
Q.
Did they also produce Government's Exhibit 150 through 154
regarding the forgiveness?
A.
Yes.
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Q.
I will show you those later.
I will show you those. Once you received the lender
files, what information was contained in there that was helpful
to your investigation?
A.
So, it included the tax records in support of the income
for Alexandra Acosta, and, it included, you know, personal
identifying information like her email address, the phone
number, the type of business on there. And then there was also
like a DocuSign that showed the events related to signature.
Q.
Okay. I am going to show you Government's Exhibit 100.
MR. JONES: Your Honor, would you please activate the
--
Thank you.
BY MR. JONES:
Q.
Do you recognize this document, Government's Exhibit 100?
A.
Yes. That is the Paycheck Protection Program loan
application for Alexandra Acosta.
Q.
And this is what you were referencing was produced by Cross
River?
A.
Yes.
Q.
You mentioned an IP address. I am going to take you to --
this is Page 15 of Government's Exhibit 100. What are we
looking at here?
A.
So, this is a certificate of completion. It shows the
signer events for the PPP loan application, itself.
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So, at the top, it has the name of DocuSign document, which
says Paycheck Protection Program application, and then it shows
a signature on February 3, 2021. And then also, it shows the
signer event where the actual signature documents were sent,
which were sent to AlexAcosta03@Gmail.com.
Q.
And is that the email that was listed in the application?
A.
Yes.
Q.
Now, with that information, this IP address 73.56139.104,
what did you do with that?
A.
We issued a subpoena to the Internet service provider for
that. We had done an internal check, which showed that it was
Xfinity or Comcast -- I am not sure which one it was at the
time -- but, essentially, Xfinity and Comcast have the same
service address for records. So, we issued a subpoena, and it
came back nonresponsive. It was outside the scope of date that
they keep the records for, which is generally 180 days,
unfortunately.
So, by the time we issued the subpoena, the information was
no longer held by the service provider.
Q.
And are you generally familiar with what an IP or Internet
protocol address is?
A.
I am.
Q.
Can you briefly explain what that identifies, for the jury?
A.
It identifies the location of the router for the Internet.
So, if it is, you know, someone's house, it would be the
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IP address related to the router at that location.
Q.
And are there distinctions between types of IP addresses,
static versus a dynamic?
A.
Yes. Static means it stays the same unless the router
becomes disconnected. It will generally stay the same number.
But then, if it was dynamic, it changes on a rolling basis.
Q.
And this IP address, do you know whether this was static or
dynamic?
A.
I am not sure.
Q.
When you issued the subpoena to Comcast, you mentioned that
it returned no results?
A.
Right.
Q.
What information had you included in that subpoena?
A.
We -- so, we issued a couple of subpoenas. The first
subpoena, we requested just the specific IP address. And then
we issued a later subpoena for Alexandra Acosta's identifying
information and personal residence address to see if maybe they
had the records that way.
Q.
And, at this time, had you known whether this defendant
St. Louis was included in the investigation?
A.
No.
Q.
Now, it is the IP, the ISP or Internet service provider,
that is the one that retains these records, but you testified
that they have a limited retention policy?
A.
Yes, they do. Generally, they retain records for 180 days.
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By the time we issued the subpoena, it was well past that.
Q.
Is that because this event occurred in February 2021?
A.
Yes. And, I believe the initial subpoena, just based on
the IP address, itself, was sometime in later 2022.
Q.
And did you ultimately learn who was associated with this
IP address?
A.
Yes.
Q.
And how did you learn that?
A.
We received records from the defense team that showed a
DocuSign certificate for Mr. St. Louis bearing the same
IP address.
Q.
I am going to show you Government's Exhibit 602.
MR. JONES: Well, before I do that, can I move to admit
Government's Exhibit 602 into evidence?
THE COURT: You may.
All right. So 602 is in evidence.
(Government's No. 602 was received in Evidence.)
BY MR. JONES:
Q.
Showing you Government's Exhibit 602, is this the record
you were just discussing?
A.
Yes, yes, that is a DocuSign certificate.
Q.
And this was produced by the defense team when?
A.
Q.
Approximately?
A.
Sometime in early 2023.
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Q.
Now, this, this record, what was the trial subpoena issued
to?
A.
Sorry, actually I believe it was early 2024. I apologize.
Q.
And, this was a subpoena to who, that produced these
records?
A.
I think this is a subpoena to DocuSign.
Q.
And it was for what?
A.
It was requesting DocuSign certificates associated to
Victorytaxes@gmail.com.
Q.
And, in return, DocuSign returned this document, right?
A.
That's right.
Q.
Now, what does it state here in the signer events?
A.
It has Vilsaint St. Louis, Victory Taxes@gmail.com. It has
a DocuSign signature there, with the IP address of
73.56.139.104. On December 21 of 2020, it was signed.
Q.
Now, that December 21, 2020, date, that is not
February 1st, 2020, or 2021?
A.
No.
Q.
But, based on this, what is your analysis in the nature of
IP addresses?
A.
We believe it was the IP address associated to
Mr. St. Louis.
Q.
And that could have been associated with him in February of
2021?
A.
Yes.
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Q.
This second page, what exactly is this, or do you even know
what this is representing here?
A.
I believe that just shows different events related to this
DocuSign certificate. Just looking at the status, it looks
like it was created by user, Small Business Administration,
having their IP, on December 21, 2020, and then opened by
Vilsaint St. Louis on December 21, 2020.
Q.
And, this IP address that we have been talking about,
73.561.39.104, is that an IP address associated with the PPP
loan application?
A.
Yes, it is the same IP address.
Q.
Exhibit 600 --
MR. SILBER: One second.
No objection.
MR. JONES: Government moves to admit Government's
Exhibit 600.
THE COURT: Okay.
(Government's No. 600 was received in Evidence.)
BY MR. JONES:
Q.
Ms. Johnson, or Special Agent Johnson, sorry, I am showing
you Government's Exhibit 600. Do you recognize this document?
A.
Yes. This is Google subscriber information for a Gmail
account, Victory Taxes@gmail.com.
Q.
And, is this something that you obtained following the
information provided by DocuSign?
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A.
Yes. We obtained the G mail records related to the account
utilizing a search warrant.
Q.
And, prior to receiving this information, was Mr. St. Louis
a target of yours?
A.
No.
Q.
And, we discussed the PPP loan application. And, you are
aware that there was supporting documents attached to the PPP
loan application?
A.
Yes.
Q.
And what were those documents, again?
A.
They were bank statements. There was tax records, the two
different tax records, the Form 1099 miscellaneous and then a
Schedule C profit loss for a sole proprietor.
Q.
And I am appearing to show you the supporting records?
Is this the 1099 that you were discussing?
A.
Yes.
Q.
And this was submitted in support of the application?
A.
Yes, that's right.
Q.
And, you also, during your investigation, did you obtain
any official tax records?
A.
Yes. We -- we did what's called an ex parte order. It
allows the IRS to share tax records that are filed with them.
Q.
And Government's Exhibit 201, which was already introduced,
is this the 2019 official tax record that you received?
A.
Yes, it is.
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Q.
And, with this document, was there any 1099s attached to
this?
A.
I believe there was a 1099.
Q.
Let me back up there, actually.
A.
Okay.
Q.
You had a chance to, when we saw the name listed here, for
the payor, Valordog LLC?
A.
Yes.
Q.
What did you do with that information?
A.
We issued a subpoena to the entity to get any records
issued to Alexandra Acosta, and we made contact with the owner,
Todd Crevier.
Q.
Did you ask him for his 2019 records?
A.
Yes, sir.
Q.
Was that to cross-reference submitted documents?
A.
Yes. We were trying to verify if the information on here
was correct, per Mr. Crevier's records.
Q.
And did you receive those records?
A.
Yes.
Q.
I am going to show you Government's Exhibit 400.
Is this Government's Exhibit 400 what you received back
from Valordog LLC in response to your subpoena?
A.
Yes. Yes, it is. It lists compensation of $13,904.
Q.
And what was the compensation listed in the form submitted
to the SBA, in support of the PPP?
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A.
$103,255.
Q.
And, you also had seen attached to the PPP loan application
a Schedule C?
A.
Yes.
Q.
And -- one moment, excuse me.
And, when you received the 2019 tax return for -- from
the IRS, did you cross-reference the Schedule C that was filed?
A.
Yes, I did.
Q.
Is the document I am showing you on your right and on the
jury's right, is that the real, or the filed with the IRS
Schedule C for 2019?
A.
Yes, it is.
Q.
And, what was the income amount listed?
A.
$138,904.
Q.
And what was listed in the income in the form that was
submitted in support of the PPP loan application?
A.
$103,255.
Q.
And, the expenses submitted in support of the application
for the PPP loan?
A.
Supplies of $6,389.
Q.
And were there expenses listed in the Schedule C that was
actually filed with the IRS?
A.
Yes, there was a total expenses of $23,523, in the
IRS-filed copy.
Q.
Now, in addition to cross-referencing the tax records, why
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do you do that?
A.
We want to just verify that the information supplied on the
PPP loan application is accurate. And, the only way to do that
is to verify it against the IRS-filed records, and also compare
to bank records.
Q.
And, following this type of, this part of your
investigation, did you obtain any other records to support your
investigation?
A.
We did.
Q.
What types of records did you obtain?
A.
We issued subpoenas for financial accounts. So, the PPP
loan application listed a bank account at SunTrust where the
PPP proceeds were deposited. So, we started with the subpoena
there to identify whether the funds were deposited to that
account. We received the account, we analyzed it, and then we
issued additional subpoenas based on reviewing that bank
account.
Q.
When you issued the subpoenas to SunTrust, did you issue
just for that account, or for any accounts associated with
Alexandra Acosta?
A.
Any accounts.
Q.
Did you receive more than one account back?
A.
We did. It was -- we received a checking and a savings
account.
Q.
Okay.
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MR. JONES: 500 through 501A?
MR. SILBER: 500, no objection. You said 501A?
MR. JONES: Yes, that is the statement for January.
MR. SILBER: No objection.
THE COURT: So 500 and 501A.
MR. JONES: 500, 500A, 501 and 501A, please.
THE COURT: Not 500B?
MR. JONES: No, no B for either.
THE COURT: Okay.
(Government's No. 500 was received in Evidence.)
(Government's No. 500A was received in Evidence.)
(Government's No. 501 was received in Evidence.)
(Government's No. 501A was received in Evidence.)
BY MR. JONES:
Q.
Special Agent Johnson, I am showing you the first page of
Government's Exhibit 500. What is this?
A.
That is a personal account signature card for SunTrust Bank
account ending 7279, in the name of Alexandra Acosta.
Q.
And the returns here, it was a 360-page document of bank
records?
A.
Yes.
Q.
And do you recognize that signature?
A.
I do.
Q.
Did you see it elsewhere in your investigative case?
A.
Yes. I have saw it on other documents, including driver's
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license records, tax records, other records related to the IRS
audit.
Q.
Is this one of those records that you are referencing?
A.
Yes.
Q.
Okay.
I was showing the witness Government's Exhibit 203G.
Now, I am going to show you Government's Exhibit 500A,
which is just an excerpt from the banking records.
So, do you recognize this?
A.
Yes, I do. That is a bank statement for the account ending
in 7279 for December 24th to January 22nd of 2021.
Q.
And, when you were reviewing these bank records, which
account is this for?
A.
This is for the checking account where the PPP proceeds
were deposited.
Q.
And that is 7279?
A.
That's right.
Q.
And, in reviewing these records, can you describe the
income that you saw in January of 2021?
A.
Payroll deposits from Broward Sheriff's Office.
Q.
I will move to the next -- this is Page 8 of Government's
Exhibit 500 A. What are we looking at here?
A.
This is SunTrust account ending 7279, again for January 23,
2021, through February 19 of 2501.
Q.
Did you review the statement during your investigation to
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find the PPP funds?
A.
I did.
Q.
What did you find during your search?
A.
So, it showed that the PPP loan was deposited to the bank
account on February 4th of 2021.
Q.
Okay. And what was the amount?
A.
$20,180.
Q.
You also somewhere -- we have not used this in a bit, but
you can touch the screen. I believe you may be able to circle
some things, if it helps you?
A.
Sure.
Q.
And, what exactly did you see happen with this money as
between accounts?
A.
So, the same day that the deposit was made of $20,180, a
mobile app transfer was conducted, transferring $20,000 to a
SunTrust savings account ending 6716.
Q.
Is that the same savings account that you received?
A.
Yes.
Q.
Sorry.
A.
That was a horrible circle. I will not do that again.
Q.
I think if you hit the bottom here, there is --
A.
Undo. There we go.
Q.
So the $20,000 was transferred to where?
A.
To a SunTrust savings account ending 6716, which we found
to be in the name of Alexandra Acosta. And then on the same
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day, it was transferred back to this account. So, that's why
you see a $20,000 on the right-hand side going out, and then
also on February 4th, 19,000 of that was transferred back into
this account.
Q.
Now, did you also see right here the February 3rd entry?
A.
Yes. That is a $840 deposits. That is one of the stimulus
payments that the Treasury was issuing during the pandemic.
That one appears to be the second one. It is indicated by
EIP2.
Q.
What does EIP stand for?
A.
Economic impact payment.
Q.
So, that is a stimulus?
A.
Yes.
Q.
During your review of her bank records, did you find any
other payments for stimulus?
A.
Yes.
Q.
I direct your attention back to Government's Exhibit 500.
Briefly, you just mentioned -- what month are we in with this
statement?
A.
So, this is April of 2020, and it is the same bank account
ending 7279.
Q.
And, this is April 2020?
A.
Yes.
Q.
And, this is Page 139 of Government's Exhibit 500. Do you
see the deposit you were just referencing earlier?
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A.
Yes. $1,240 on April 15th from IRS Treasury.
Q.
And that is an economic impact payment again?
A.
Yes.
Q.
Stimulus?
A.
That's correct.
Q.
Back on Government's Exhibit 500A, and we are around the
time period of when the money from the PPP loan hit the
account, did you notice anything that was done with the money
besides the transfer to the savings account and back to the
checking account?
A.
There was a couple of credit card payments made. There was
one on February 4th for $900, and then I think there were a
couple more after that.
There was one on February 5th to Capital One for $900,
and then another one on February 5th to Chase Credit for $900.
And then it also looks like $9,000 was transferred out on
February 5th to the savings account ending 6716.
Q.
That is the savings account where the money was going back
and forth from?
A.
Yes.
Q.
Did you see any other transactions that caught your eye?
A.
On February 5th, there is a withdrawal for $10,000 to
Robinhood Funds.
Q.
Did you know what that was at the time?
A.
I believe that Robinhood to be a brokerage account. I
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wasn't sure. So, we issued a subpoena to Robinhood.
Q.
And, in response to that subpoena, did Robinhood produce
any records?
A.
Yes, they did.
MR. JONES: 504.
MR. SILBER: 504, no objection.
MR. JONES: It is 504 through 508.
MR. SILBER: 504, no objection. 505, no objection.
506, no objection. 507, no objection. 508, no objection.
THE COURT: All right. Those will all be admitted.
(Government's No. 504 was received in Evidence.)
(Government's No. 505 was received in Evidence.)
(Government's No. 506 was received in Evidence.)
(Government's No. 507 was received in Evidence.)
(Government's No. 508 was received in Evidence.)
BY MR. JONES:
Q.
Special Agent Johnson, I am showing you the first page of
Government's Exhibit 504. Can you explain what this was that
was returned to you?
A.
Yes. It is a Robinhood account master -- it lists the
demographical information for the account, who the
accountholder is, their associated email address, phone number,
date of birth, marital status, and I believe there is also some
of the ACH transactions that occurred in this account.
Q.
And, before we get to those transactions, was there an
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email associated with this?
A.
Yes, AlexAcosta03@@gmail.com.
Q.
And, you previously mentioned a warrant that you had
obtained. Did you obtain any information regarding this
account pursuant to that warrant?
A.
Yes, we did.
Q.
I am showing you Government's Exhibit 507.
Do you recognize -- do you recognize this?
A.
Yes. That is the Google subscriber information for the
email address, AlexAcosta@gmail.com.
Q.
Did that come back to the defendant, Alexandra Acosta?
A.
Yes.
Q.
And, as part of your investigation, you received returns
for these warrants. Were you able to review some of the
defendants' emails as it pertained to the Robinhood
transactions?
A.
Yes, I did.
Q.
Going back to Government's Exhibit 504, and we are going
down to Page 10. I know that's small. We can bring it back.
Let me highlight it closer.
Are you able to see and read the box that I have pulled
out?
A.
Yes.
Q.
What information is contained in this section?
A.
So, it lists a -- it lists different transactions that were
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either completed or cancelled. It looks like it is in reverse
chronological order. So, the bottom, it is December 2020, and
then, at the top, it is June of 2021.
Q.
And, did you find the $10,000 transfer that you saw in the
bank records in this account statement?
A.
Yes. There is a deposit on February 4th at 15:33, for
$10,000.
Q.
Was there something else notable?
A.
Yes. Underneath it, also on February 4th of 2021, there
lists a deposit for $19,000; but, then it states over in one of
the right columns that it was cancelled. And, the time was
15:30, so I guess three minutes before the $10,000 transaction.
Q.
Did that have any significance to you?
A.
Yeah. The dollar amount. Generally, items over $10,000
trigger certain reporting requirements, as required by the Bank
Secrecy Act.
Q.
It is not every transaction?
A.
No.
Q.
But, there are certain circumstances where that number
matters?
A.
Yes.
Q.
And, you knew that based on your training in law
enforcement?
A.
That's right.
Q.
I am going to be showing you some of these emails that --
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from Robinhood corresponding with this account transaction.
This is Page 1 of Government's Exhibit 508.
What are we seeing here?
A.
So, the subject line is "funds available for investing."
It is an email from Robinhood to AlexAcosta03@gmail.com on
February 4, 2021, at 15:30.
Q.
And, just for clarification, when you say, "15:30," what
time is that?
A.
That is military time for 3:30.
Q.
P.M.?
A.
P.M.
Q.
And what is the substance of this email indicating to
Ms. Acosta?
A.
It is saying that a thousand dollars is available as an
instant deposit for your recent $19,000 transfer from your bank
account ending in 7279. The remaining $18,000 will be
available when the transfer completes on Wednesday,
February 10th.
Q.
Does this email say it was denied?
A.
No.
Q.
This is Page 2 of Government's Exhibit 508.
Can you read the subject matter and the timestamp?
A.
The subject line is "Funds available for investing on
February 4th, 2021, from Robinhood to alexacosta03@gmail.com at
15:33.
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Q.
And, is that -- how many minutes after the initial transfer
is that?
A.
The initial one was 15:30. So, approximately three minutes
later.
Q.
And, in this body of this email, what does it state?
A.
It states that a thousand dollars is available as an
instant deposit for your recent $10,000 transfer from bank
account ending in 7279, the remaining $9,000 will be available
when the transfer completes on Wednesday, February 10th.
Q.
Did you find any emails from Robinhood describing a
declination of the $19,000 transfer?
A.
I did not.
Q.
Now, we're going to take you back to -- I am going to take
you to Government's Exhibit 506.
Do you recognize what this is?
A.
Yes, it is transactional records for Robinhood for
Alexandra Acosta's account ending in 5225.
Q.
And, actually, let me take you to 505 instead. It will
just be more concise.
So, what is Government's Exhibit 505?
A.
So, this is a summary, an account summary for the account
ending in 55 -- sorry. 5225, for Alexandra Acosta, and it is
for November 2020.
Q.
Okay. And, did you review the record as pertains to the
February transactions?
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A.
Yes.
Q.
So, taking you to Page 14 of Government's Exhibit 505, the
statement period --
A.
February 1st, 2021, to February 28, 2021.
Q.
And, what was the net account balance, opening?
A.
$52.80.
Q.
What was the total securities, opening?
A.
$417.93.
Q.
What was the closing balance, net account balance?
A.
$529.41.
Q.
And, the closing total securities?
A.
$7,485.09.
Q.
And, the total portfolio value at closing?
A.
$8,014.50.
Q.
And, in this account statement, does it include any
information about transaction history?
A.
Yes, it does.
Q.
Does it also include a statement about the nature of the
securities that are being held?
A.
Yes. It lists -- it lists the account type and the
different transactions that occurred, and then a description of
the securities.
Q.
I am highlighting -- we are on Page 16 of Government's
Exhibit 505, and I have pulled out the first four lines. Do
you see what I have highlighted?
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A.
Yes, I see it.
Q.
And is this in reference, or what does this reference
again?
A.
It references a buy of gold nuggets, online gaming, on
January 28, 2021, and then it references the cancellation of an
ACH of $19,000 on February 4th; and then an ACH deposit on
February 4th of $10,000, and then an ACH deposit on
February 4th of $19,000. Which looks to be the one that was
cancelled.
Q.
Now, on February 4th, were there other transactions?
A.
Yes. This was three buys listed here on the screen.
Q.
And how much was the -- can you describe the first one that
is highlighted?
A.
So, the first one is a purchase of Apex Technology stock on
February 4th of 2021. It looks like the quantity is 62.979669
shares, 15.74 apiece, for a total of $991.30.
Q.
And, going back to Government's Exhibit 508, do you see --
can you tell us the timestamp of that?
A.
February 4, 2021, 15:38, Robinhood to
alexacosta03@gmail.com.
Q.
Do you recall -- from your testimony a few minutes ago, do
you know how much later that was from when the money was
received?
A.
Five minutes later. No, I am sorry. Five seconds later.
It was 15:33; correct?
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Q.
15 --
A.
I believe, so sorry. 15:33, and this is 15:38, so --
Q.
That is minutes, though?
A.
Five minutes. You are right.
Q.
And this next email, Page 4 of Government's Exhibit 508?
A.
Yes. It says an order has been executed. The subject line
is from Robinhood to alexacosta03@gmail.com on February 4,
2021.
Q.
This discusses the account activity we were discussing in
Exhibit 505?
A.
Yes.
Q.
Now, there is also an entry here on February 10th.
Can you describe that?
A.
Yes. It looks like it is another buy, this time for Abeona
Therapeutics on February 10, 2021.
Then, it looks like it was approximately 2,431 shares at
$3.29 cents a share, for a total of $7,998.05.
Q.
And then the February 10th date, does that correlates with
the correspondence provided by Robinhood when the money would
be available?
A.
That's right.
Q.
I am showing you Government's Exhibit 508, Page 5. Can you
read the timing of this?
A.
So, the subline says, "Transfer for Robinhood completed,"
from Robinhood to alexacosta03@gmail.com on February 10, 2021,
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at 8:48.
Q.
And what is this email confirming?
A.
It says, "Your $10,000 transfer to Robinhood from your bank
account ending in 7279 has completed. A portion of your
transfer was used to cover a deficit in your account, so the
full transfer amount may not reflect in your buying power."
Q.
And, Page 6, I believe it is duplicative, Page 7?
A.
Page 7, the subject is "Your order has been executed from
Robinhood to alexacosta03 on February 10th, 2021, at 9:34."
Q.
And what does it show -- does this confirm the information
was provided in the account statement?
A.
Yes. It is confirming the buy of the ABEO shares.
Q.
Now, Special Agent Johnson, we are going to pivot back to
the PPP loan application.
A.
Okay.
Q.
Well, first, was there anything else remarkable about the
Robinhood exhibit or Robinhood records?
A.
Not that is coming to mind. I think we covered it.
Q.
Now, taking us back to the PPP loan application, as part of
this, the records that we have seen already -- and we talked
about this, but there is a day that was provided, as well?
A.
Yes.
Q.
And that was from BlueVine?
A.
Yes. That is correct.
Q.
And, during the course of your investigation, did you --
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did you cross-reference that data with emails associated with
Ms. Acosta's account?
A.
Yes.
Q.
And, did you also cross-reference that data with the IRS
tax audit information?
A.
Yes.
Q.
Specifically, the date of the application, or the date that
the application was started?
A.
Yes. According to the BlueVine log information, and email
information, it appears the PPP application was began on
February 1st of 2021, which was also the day that Alexandra
Acosta and Mr. St. Louis had a phone call with the IRS auditor.
Q.
I am actually on Government's Exhibit 502 now. This is --
this has been introduced as data, you know, BlueVine data
supporting the PPP loan application. The material part of this
record is the timing that you just referenced.
Is this the February 1st date that we were discussing?
A.
Yes. So, that's the first log into the blue line -- excuse
me, BlueVine platform, and I believe that was the same day as
the call with the IRS auditor.
Q.
I will pull that up just to verify. So, I want to take you
down to the Page 3 of the Government's Exhibit 203A. This is
the entry that you were just referencing.
A.
Yes.
Q.
And, that was important to you because?
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A.
It was the initial log into the BlueVine platform, which
serviced the PPP loan application for Alexandra Acosta.
Q.
And, did you also find the emails that we discussed that
were corroborating the activity?
A.
Yes.
Q.
And, that is -- I will show you Government's Exhibit 608 --
sorry, 603.
MR. SILBER: 603, you said?
No objection.
THE COURT: All right. So, 603 is in evidence.
(Government's No. 603 was received in Evidence.)
BY MR. JONES:
Q.
I am showing you the first page of Government's
Exhibit 603.
MR. JONES: How about 601?
Do you have any objection to 601?
MR. SILBER: 601 -- no objection.
THE COURT: Okay. 601 is in evidence.
(Government's No. 601 was received in Evidence.)
BY MR. JONES:
Q.
Showing you the first page of Government's Exhibit 601 --
what are we looking at?
A.
So, this is an email from Alexandra Acosta to Victory Taxes
on February 1st, 2021, at 11:25:25 A.M., and, the attachment
says "statements.PDF," and the subject line is "December 2020
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Acosta."
Q.
And, these -- the statements that were attached to this
email were from which date range?
A.
That is for December 2020. That is December 23, 2020, is
the ending statement date, it looks like, it begins on
November 21st of 2020.
Q.
And was there any -- what type of income was reported or
did you see during this statement period?
A.
Wages, or direct deposits from Broward Sheriff's Office.
Q.
Was there any other amounts that were unaccounted for?
A.
No.
Q.
Now, Page 10 of this exhibit, this follows the statement
and is attached to the email -- what does that represent?
A.
It says, "sent from iPhone."
Q.
And now page 11 of 601, what is this?
A.
This is an email from Alex Acosta to Victory Taxes on
February 1, 2021, at 11:56, with states that PDF is attached,
and the subject line is February 2020, Acosta.
Q.
And there were more bank statements attached to this?
A.
Yes.
Q.
But, which bank statements was that?
A.
January 25, 2020, to February 21, 2020.
Q.
And, was there anything in here reported as income, or did
you see any income, any deposits?
A.
Yes.
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Q.
What type of deposits did you see?
A.
Primarily, payroll, what looks to be payroll from Broward
Sheriff's Office.
Q.
And are there any other deposits associated with this
month?
A.
There is a tax refund totalling $7,279.10 on February 20th.
Q.
And this was also sent --
A.
Yes.
Q.
-- by iPhone?
A.
Yes, it says, "Sent from my iPhone."
Q.
Now, at this time, we are at Government's Exhibit 601,
Page 18. These are in chronological order.
But, what is the timestamp of this, date and timestamp?
A.
This is in a Google security alert dated February 1st,
2021, at 12:02 to alexacosta03.
Q.
And what does that security alert say?
A.
It says, "Your password was changed. The password for your
Google account, alexacosta03@gmail.com was changed. If you did
not change it, you should recover your account."
Q.
And is this -- do these statements have any relevance to
the PPP loan application?
A.
Yes.
Q.
How so?
A.
February 1st, if you recall from the BlueVine documents, is
the initial log into BlueVine.
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Q.
Page 19, the timestamp here?
A.
12:53.
Q.
And, that is -- how much later was that than the previous
email?
A.
The previous email was 12-something, right?
Sorry, I forgot already.
Q.
Just for the sake of completeness, I will just --
A.
Thank you.
Q.
-- come back up to Page 18, and the timestamp was --
A.
12:02.
Q.
Now, what is this email indicating?
A.
So, the subject line is "Activate your account and complete
your application."
And, it says, "We have reviewed your application, and you
are qualified for the Paycheck Protection Program. There are a
few more steps to complete your application, activate your
account, and complete a few additional tasks to continue," and
then there's a button to activate your account.
Q.
Then, later, there is another email. What does this one
signify?
A.
So, this one is another Google security alert to
alexacosta03 at 13:12, and it says, "New device signed in to
alexAcosta03@gmail.com.
Q.
We are back on the -- I am showing you a split screen.
6018 is on the left, and Government's Exhibit 102 is on the
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right, taking us down some of the login activity from BlueVine.
Does the time -- I am going to take your attention here to
the first entry. What was the timestamp here?
A.
10:11.
MR. SILBER: Objection, Your Honor, lack of foundation.
THE COURT: Overruled.
MR. SILBER: May I expound on that for a second?
THE COURT: No.
BY MR. JONES:
Q.
Is this a -- is that timestamp -- do you know exactly what
time period that -- or, sorry, what time zone that is?
A.
It is Pacific Standard Time.
Q.
And, does that correlate with this timestamp here?
A.
Yes.
Q.
I am showing Government's Exhibit 601, Page 20.
A.
Yes. That would be -- 13:12 would be 1:12:00 P.M., local
time, and in Pacific Standard Time, three hours behind us.
Q.
Okay.
A.
So, the 10:11 would equate to 1:11:00 P.M.
Q.
Were there also other emails that were forwarded to Victory
Taxes that day containing attachments?
A.
Yes.
Q.
What, exactly?
Based on Page 21, what was sent?
A.
This one is SunTrust, "2018, Acosta" is the subject line,
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it looks like it is a response, and it is from Victory Taxes to
Alex Acosta on February 1, 2021, at 13:13.
Q.
And, what is noted in the email from Ms. Acosta to Victory
Taxes?
A.
It says, "2018, SunTrust banking statements, see
specifically" -- it is a 2-6-6-4 -- sorry, it is small.
2-8-8-4, maybe -- "see specifically 28480 for realtor.com."
Q.
Does that appear to be something that was related to the
tax case?
A.
Yes.
Q.
And, likewise, a little later that day, what do we have in
Government's -- sorry on Page 22?
A.
It is, subject line, "SunTrust 2019, February 1st, 2021,"
from Alex Acosta to Vilsaint St. Louis. And, it appears to be
several SunTrust Bank statements that are attached, starting
with January of 2019.
Q.
And what did Ms. Acosta write to Mr. St. Louis?
A.
"Here is 2019. I also have a Chase account and credit card
info if I need to send. I would like to get this lowered as
much as possible."
Q.
Did you find any emails that day asking him where he got
all those numbers for the tax case?
A.
No.
Q.
Did you see any emails to him wondering or challenging his
ability to be a good tax preparer?
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A.
No.
Q.
Now, Page 23 of 601, can you tell us the subject matter and
the timestamp?
A.
It says, "Your paycheck protection loan has been
submitted."
It is from BlueVine to alexacosta03@gmail.com, on
February 1, 2021, at 13:35.
Q.
And again, is that 1:35?
A.
Yes.
Q.
And, this is after the prior emails that we went through?
A.
Yes.
Q.
And, what is the subject matter of this?
A.
It says, "Your Paycheck Protection Program loan was sent to
the Small Business Administration to be reviewed and processed.
Based on capacity, the SBA may take a few days to process your
application. We cannot guarantee loans will be approved before
PPP funding runs out. If and when processing is complete by
the SBA, we will send you an email with instructions to accept
and sign your loan offer. There is no further action required
of you at this time, and BlueVine does not have insight into
the SBA processing timeline or the status of your application
with the SBA."
Q.
Okay. And also, during this investigation, did you have a
chance to obtain telephone records for Ms. Acosta?
A.
Yes.
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Q.
Were some of those records from Verizon?
A.
Yes.
MR. JONES: This is 613B and 613A.
MR. SILBER: One second. 613A, no objection.
What was the next one?
MR. JONES: 613B.
MR. SILBER: A, B, C -- all three of them, or just 613?
MR. JONES: 613A and 613B.
THE COURT: I don't see a 613.
MR. JONES: Sorry, it is 613A, your Honor, and --
MR. SILBER: And 613?
No objection, your Honor.
THE COURT: All right. 613A and B are in evidence.
(Government's No. 613 was received in Evidence.)
(Government's No. 613A was received in Evidence.)
BY MR. JONES:
Q.
Special Agent Johnson, I am showing you Government's
Exhibit 613A. What is this?
A.
This is the subscriber information from Verizon for mobile
telephone number (305) 494-9699, in the name of Alexandra
Acosta.
Q.
And is this the telephone number that was active during the
period of Ms. Acosta's PPP loan application?
A.
Yes. It was listed on the face of the PPP application.
Q.
And, did you have a chance to review some of the call logs
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from that day on February 1st?
A.
Yes.
Q.
I am showing you Government's Exhibit 613B. Now, during
your investigation, what is this?
A.
So, this is the talk activity for billing period
January 19, 2021, through February 18, 2021. For that call
number we just spoke about, from Verizon.
Q.
And when you received these records, what were you looking
for?
A.
We were just looking for call activity in and around the
time of the PPP application, and the logins between Alexandra
Acosta and Vilsaint St. Louis.
Q.
And did you know Vilsaint St. Louis's number?
A.
Yes, I did.
Q.
Did you know more than one number of his?
A.
Yes. He has a phone number associated to the tax business
on Davie Boulevard in Fort Lauderdale, Fort Lauderdale, and
then a cell phone number we were also aware of.
Q.
And is the number associated with his business, is that
public effacing?
Is that publicly available information?
A.
Yes, you can Google "Victory Taxes" and find the number.
Q.
Did you do that?
A.
Yes.
Q.
Do you also know his personal number or work number?
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A.
Yes. He has a work cell phone number and then also a
personal cell number, as well.
Q.
And did you know that -- was that work cell number
754-200-4125?
A.
That is the number for Victory Taxes. That is actually the
tax office.
Q.
Okay. And, on this day, or having reviewed the statement
period, were you looking in any days in particular, or the
entire period?
A.
Well, we are looking at days in and around the logins
related to the PPP application, which started on February 1st.
Q.
And, did you find any calls to and from, or to or from,
Victory Taxes that day?
A.
Yes.
Q.
And how many calls, approximately, did you find?
A.
On February 1st, itself, I believe there was five calls.
If you could scroll up, maybe --
Q.
Yes, I can start.
A.
Or, maybe it does start on Page 20.
Q.
Yes. This is Government's Exhibit 613B, Page 2. I will
highlight all February 1 for you.
Feel free to use any highlighting on your end.
A.
So, I see the call, the first call is there at 9:55 A.M.
Q.
Okay.
A.
And then the next call is at 12:56 P.M., 12:57 P.M.,
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6:47 P.M., and 6:48 P.M. So, that's one, two, three, four, five
calls.
Q.
And that's a timestamp here, right next to --
A.
Yes.
Q.
Is that the length of the call?
A.
Yes. And then the origination and the destination. If it
is an incoming call, it will actually list incoming call and
the destination column. Otherwise, it was outgoing.
Q.
Okay. So, this first call in February 1st, that had has
the yellow line coming through it almost, is that to her from
Victory Taxes?
A.
Yes. That is an incoming call.
Q.
And, the other calls are on February 1st at 12:56 and
12:57 P.M. Is that from Ms. Acosta to Victory Taxes?
A.
Yes.
Q.
And then later at 6:47 and 6:48, that one is to -- one is
to or from Ms. Acosta and one is to Ms. Acosta; correct?
A.
Yes, the one at 6:48 P.M., is incoming, for three minutes.
Q.
And was that the -- these calls, did they correlate with
the time period in which this application was being created?
A.
Yes.
Q.
I think you can undo your -- there you go.
A.
Thank you.
Q.
And now, this -- this application period we have additional
emails, you received from February 2nd?
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A.
Did you mean phone calls?
Q.
No, I apologize. I am flipping back. I am going to go
down the lines here, calls, emails.
A.
Yes.
Q.
Did you also find emails corresponding to the February 2nd
date?
This has been admitted as Government's Exhibit 603.
A.
Yes.
Q.
Now, this record, this is the next day, February 2nd. But
what is the timestamp?
A.
13:55.
Q.
And, what does it state as subject matter?
A.
"Next steps on your PPP loan."
It is from BlueVine.
Q.
And the substance of this, exactly, what is it
communicating to Ms. Acosta?
A.
It is -- it is saying that "BlueVine has qualified you for
the Paycheck Protection Program, and will submit your
application to the SBA. No further action is required by you
at this time."
Q.
Now, there is another email that same day. What is the
title of it?
This is Page 3.
A.
"You have an offer for the Paycheck Protection Program,"
and it is from BlueVine to alexacosta03@gmail.com at 2129.
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Q.
And what is the substance of this message?
A.
"The SBA has finished reviewing your application and you
have been approved for your Paycheck Protection Program loan.
Accept your offer and access more information, including the
next steps."
Q.
So, this is an email sent to Ms. Acosta's gmail account?
A.
Yes.
Q.
And now, continuing to February 3, Government's
Exhibit 604.
MR. SILBER: No objection.
THE COURT: Okay.
(Government's No. 604 was received in Evidence.)
BY MR. JONES:
Q.
I am showing you Government's Exhibit 604. It has been
admitted into evidence. Can you explain the nature of this
email?
A.
This is an email from BlueVine PPP via DocuSign to
Alexandra Acosta on February 3, 2021, at 9:33 A.M., and it is
the DocuSign packet containing the Paycheck Protection Program
application.
Q.
Is this effectively the complete form? What are the three
or four documents that are attached here?
A.
Yes. It includes the application, the note for the PPP
loan, itself, and a tax form, it looks like, and
"certification-note PDF."
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Q.
And it says, at the top here, "Please DocuSign"?
A.
Yes.
Q.
But it also notes that it is completed; correct?
A.
That's right.
Q.
And, there is a chance to review completed documents, but
there is attachments, scrolling down to Page 3. This is the
first attachment to the email?
A.
Yes. That is Page 1 of the loan application.
Q.
Is this the same -- well, let me just verify. We have
talked again about DocuSign numbers. This F616B, is that the
same DocuSign record that was produced by BlueVine, or Cross
River?
A.
Yes. It is the envelope ID that contained all the signed
documents.
Q.
And, in the first page of this first attachment to the
email, regarding the PPP loan, the information, can you
describe the information that is included there?
A.
Yes. So, it lists the business name of Alexandra Acosta,
the year it was established of 2018. And, again, it lists the
business legal name of Alexandra Acosta, and it has her social
security number listed here, a phone number, email address,
primary contact of Alexandra Acosta, a business address, and
then average monthly payroll of $8,072, and then the loan
request amount of $20,180, and then lists different checkboxes
for the purpose of the loan, containing payroll costs, covered
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property damage, rent, covered supplies, utilities, covered
worker protection expenditures, covered operation expenditures,
which are all checked.
Q.
Now, we also -- we have touched on this. What is a bank
note? There is a bank note attached to this.
A.
It is, essentially, a note with the lender and the borrower
that lay out the terms of the loan. So, it will have, you
know, in payment, when payment starts and interest rate and
what is expected of the payor.
Q.
So, you have an application, and then would you classify it
as a contract?
A.
Yes, it would be a contract between the lender and the
borrower.
Q.
Which requires the signature?
A.
Yes.
Q.
And, in this instance, in this large section, does it make
it clear that this had to be signed?
A.
Yes. It says it is completed, "Please DocuSign."
Q.
Moving to Government's Exhibit 605 --
MR. SILBER: No objection.
THE COURT: Okay.
(Government's No. 605 was received in Evidence.)
BY MR. JONES:
Q.
I am showing you what has been admitted as Government's
Exhibit 605. What is this email reference?
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A.
It is saying, "Your PPP funds are on the way," is the
subject line, and it is from BlueVine to
AlexAcosta03@gmail.com, and February 4, 2021, and it is
referencing the ACH deposit of the PPP proceeds, themselves.
Q.
And, so this is formalized, the actual deposit of the
money?
A.
Yes.
Q.
And, you have already testified about what happened after
that; correct?
A.
Yes.
Q.
And, during this, also during this investigation, were
there emails associated specifically to the tax case, as well?
A.
Yes.
Q.
But, did you also -- we have talked a little bit about
stimulus payments to Ms. Acosta. Did you find emails related
to her reference to stimulus?
A.
Yes.
MR. JONES: I want to show and admit Government's
Exhibit 606.
MR. SILBER: 606, no objection.
THE COURT: Okay.
(Government's No. 606 was received in Evidence.)
BY MR. JONES:
Q.
I am showing you Government's Exhibit 606. Can you tell us
what the subject matter is, and the date?
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A.
It says, "Stimulus for baby" from Alex Acosta to Victory
Taxes on March 16th, 2021.
Q.
And what is the subject matter of this state?
A.
St. Louis -- I was just wondering about the stimulus. You
told us that Erin should receive $1,400 no matter what for
Oliver, but we have not received it yet. Can you advise on
that? Thanks.
Q.
I am going to be showing you Government's Exhibits 60 --
608 -- sorry 608B, 608C and 608D.
MR. SILBER: No objection.
THE COURT: All right. It say that? 608 --
MR. JONES: 608A, B, C, D, your Honor.
MR. SILBER: No objection, your Honor.
THE COURT: Okay.
(Government's No. 608A was received in Evidence.)
(Government's No. 608B was received in Evidence.)
(Government's No. 608C was received in Evidence.)
(Government's No. 608D was received in Evidence.)
BY MR. JONES:
Q.
We referenced there, there were some more emails referring
to the tax case and the audit. Can you briefly summarize what
this message is?
A.
Yes. That is from Alex Acosta to Victory Taxes on February
222, 2021 and it is asking for an update on the IRS case,
"Please, I spent more than $3,000 on advertising in 2018. So,
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it should bring my amount down significantly."
Q.
Now, and this message, is she challenging where he got
those numbers?
A.
No.
Q.
This is Government's Exhibit 608C. The date and time and
subject?
A.
Yes. Subject is update from Alex Acosta to Vilsaint
St. Louis on March 1st, 2021, and it is asking if he has an
update on the amount owed.
Q.
Is there anything here challenging his calculations of
those years for her?
A.
No.
Q.
Looking at Government's Exhibit 608D, top of the first
page?
A.
It is referencing a tax case from Alex Acosta to Victory
Taxes on March 23, 2021, and it says, "Can I come in today at
two?"
Q.
And, it is a string of emails?
A.
Yes.
Q.
And, I am highlighting a portion of it close to the bottom.
What is this?
A.
So, this is an email on March 23 of 2021 at 12:17, to
St. Louis, saying, "This is not the amount you last told me.
Is there a new package I should be waiting for? Please respond
ASAP. Thanks."
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Q.
And, in this upper section, what does it appear that they
are discussing?
A.
It appears they are discussing the tax case, the audit.
Q.
Are they discussing speaking on the phone or meeting in
person?
A.
Meeting in person.
MR. JONES: Government's Exhibits 609, 610, 611, any
objection?
MR. SILBER: No objection.
MR. JONES: Your Honor we move in 609, 610 and 611.
THE COURT: Okay.
(Government's No. 609 was received in Evidence.)
(Government's No. 610 was received in Evidence.)
(Government's No. 611 was received in Evidence.)
BY MR. JONES:
Q.
Now, we have heard testimony about forgiveness, and we
heard testimony from Ms. Beechan about the process for applying
for forgiveness. Turning now -- did you find any emails
associated with forgiveness?
A.
Yes, I did.
Q.
And I show you Government's Exhibit 609. What does this
reference?
A.
That is a Scratch. It is a reference as -- Scratch email
from Alex Acosta to Victory Taxes on April 2, 2021, and she is
asking if she needs to do anything with the Scratch email yet.
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And then it looks like it goes down. And, on March 2nd, 2021,
it says, "I wasn't able to make it there today. Can you tell
me if we have any good news?"
And then the preceding email -- sorry, I kind of reversed
the order -- it starts February 21, 2021, and the email is from
alexacosta03@gmail.
And "St. Louis, did you receive my Scratch email?"
And then he responds, at 1:33 P.M., it says, "Yes, I did."
And then, later on, March 2nd, it looks like they arrange a
time to meet.
Q.
Now, 610, we have another email.
A.
So, the subject is referencing Scratch email. And then it
looks like at the bottom, it starts on April 19th, 2021, at
10:27 A.M. and it is from alexacosta03@gmail.com, and it says,
"Good morning. Leave me in on Thursday, sent from my iPhone,"
and then it looks like the response is on April 19th, 2021, at
11:44, and it says, "Okay. Can I email -- actually, it looks
like another email from alexacosta03@gmail.com to Victory Taxes
on April 19th, at 11:44 A.M., and it says, "Can I email what
you need for Scratch, or do I need to come into the office
right now? I have a trial this week, and I'm unable to get
away from work."
Q.
Okay. And, just to be clear, you went through the emails
to find any relevant information pertinent to the forgiveness
and the loan?
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A.
Yes.
Q.
Now, as we move on to Government's Exhibit 611, I am going
to start here at the bottom so we don't relive the mistakes of
emails past.
We will start with this email chain. What does it
stamp here?
A.
That is from Scratch, who was the forgiveness loan
processor, on April 20, 2021 at 10:49 A.M., to
alexacosta03@gmail, and the subject line says, "Thanks for
signing up for electronic disclosures."
Q.
Okay. And, specifically, is there is anything of import
here?
A.
It says, "Thanks for checking out Scratch and consenting to
receive electronic disclosures. You can now get important
stuff like your monthly statements sent to you electronically
and have some -- save some trees along the way. You can log in
to your Scratch account to make a payment, view your payment
history, and more."
Q.
Now, following that April 20th email from Scratch, what
does Ms. Acosta do?
A.
So, then it says, "Thanks for signing up for electronic
disclosures."
So, this is an email from Alex Acosta to Victory Taxes on
April 28, 2021, and she is forwarding her G-mail login info,
her G-mail info, and then says, "alexacosta03@gmail.com," and
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what appears to be a password.
MR. JONES: And, Government's Exhibit 612, 614?
MR. SILBER: 612, no objection, 614 --
MR. JONES: Yes.
MR. SILBER: No objection.
MR. JONES: And 613B, which is --
MR. SILBER: No objection.
THE COURT: So, 612, 613A, and 614, correct?
MR. JONES: Sorry. 613C.
MR. SILBER: No objection.
THE COURT: Okay.
(Government's No. 612 was received in Evidence.)
(Government's No. 613C was received in Evidence.)
(Government's No. 614 was received in Evidence.)
BY MR. JONES:
Q.
Now, we are still on February -- or, sorry. -April 21st.
There is an email sent again to Ms. Acosta. What is this?
A.
So, this is a security alert from Google to
alexacosta03@gmail, on Wednesday, April 21st, 2021, at 15:33.
Q.
And, what is this referencing?
A.
This is referencing a new device sign in to the G-mail
account, alexacosta03@gmail.com, and it says, "Your Google
account was just signed into from a new windows device."
Q.
And, just based on your experience as a law enforcement
officer, and on these circumstances, what did that indicate?
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A.
So, this shows that after she signed up for the electronic
disclosures with Scratch, that someone signed in to her G-mail
account.
Q.
And, did you make any inference, based on the forwarding of
that G-mail log-in credentials of who that could have been?
A.
We would assume it was Vilsaint St. Louis.
And, Government's Exhibit 614?
A.
So, this is April 21st at 15:48. So, this is a little
later in time from Scratch to alexacosta03@gmail.com.
And, the subject line is, "We received your Cross River
Paycheck Protection Program loan forgiveness application."
Q.
And, the essence of this long message is what?
A.
That it has been forgiven -- or, sorry, I don't think it
has been forgiven at this point. But, they received the
forgiveness application, "they," being Scratch, and Cross
River.
Q.
Now, getting down to Page 4 of this record, and ultimately,
that loan was forgiven, as supported by the records that Cross
River supplied you pursuant to your subpoena?
A.
Yes.
Q.
Now, also, we have referenced some Verizon records. Did
you look at the calls pertaining to this time period, April 20,
21st?
A.
Yes, I did.
Q.
Showing you Government's Exhibit 613 -- what is this?
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A.
This is the call log activity for Alexandra Acosta's cell
phone, 305-494-9699, from April 19th, 2021, to May 18, 2021.
Q.
And, this includes the period of this correspondence about
the forgiveness application?
A.
Yes.
Q.
And, did you have a chance to review these, this time
period for Ms. Acosta's communications with Vilsaint St. Louis?
A.
Yes.
Q.
And did you find -- well, we have discussed already that
Mr. St. Louis has his work telephone number of (754) 200-4125?
A.
That's right.
Q.
We also referenced a work cell that we didn't discuss the
actual number, but is that number 954-655-0337?
A.
Yes.
Q.
And, did you find that number during your review of the
records of this time period?
A.
Yes, I did.
Q.
Did you find both numbers, or just the work cell phone
number?
A.
I believe it was just the work cell phone number.
Q.
And, maybe just walking through, where you have identified
it in this record, with the highlighting -- or the pointing,
that worked last time --
A.
So, the first call is April 20th at 8:56 A.M., for one
minute. And then the next call is at 9:05 A.M., same date,
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April 20th, one minute, and then the next call is April 20,
1051, A.M., and there is one more call listed here on April
20th at 12:28 P.M.
And, that one lasts one minute. And, these all appear
to be outgoing calls. None of them say, "Incoming call."
And, that is the second-to-last column.
Q.
So, these are all calls from Acosta to St. Louis?
A.
That's right.
Q.
Now --
A.
I don't know if I can undo that or not --
Q.
You had success last time.
There you go.
We have gone through a bunch of emails. But, during
the course of your investigation, did you find an email that
was particularly of interest to you that related to the tax
case and the PPP loan?
A.
Yes.
Q.
And, I am going to show you what has been marked as
Government's Exhibit 608A, and we are going to start from the
bottom on this one.
What is that, the date of this message?
A.
So, this is February 16th, 2021, at 9:56 A.M. from Alex
Acosta. It says, "St. Louis, please do not bring up anything
about my IRS case or the loan to my wife. She does not know
about it and I don't want to stress her out. Thanks."
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THE COURT: All right. We have been here more than an
hour and-a-half. So, let's take a 15-minute break.
See everybody in 15 minutes.
COURT SECURITY OFFICER: All rise.
[Whereupon, the jury left the courtroom at 3:12 and the
following proceedings were had:]
THE COURT: Let's bring in the jury, please.
COURT SECURITY OFFICER: All rise for the jury.
[Whereupon, the jury entered the courtroom at 3:32
p.m., and the following proceedings were had:]
THE COURT: All right. Welcome back, everyone, and
please be seated.
Go ahead.
MR. JONES: Thank you.
BY MR. JONES:
Q.
So, Special Agent Johnson, prior to the break, we were
discussing an email dated February 16, 2021, and I have
highlighted that for you. Can you please summarize what the
email stated?
A.
"St. Louis, please do not bring up anything about my IRS
case or the loan to my wife. She does not know about it and I
don't want to stress her out. Thanks."
Q.
And, during the course of your investigation, did you learn
anything, or do you know what Ms. Acosta's wife does for a
living?
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A.
She is also in law enforcement. She is a police officer.
Q.
And the response to this email?
A.
February 16, 2021, at 10:01 A.M., victorytaxes@gmail.com
responds with "Got it."
Q.
And, again, at the top here, we have already seen this
message. But, it was just about what?
A.
It is about Home Depot, and "I also want to make sure you
saw the realtor.com advertising for $284 a month in 2018, and
that is from Alex Acosta to Victory Taxes on February 16, 2021.
Q.
Now, you heard testimony from Valordog. We talked about
the employment of Maritza Acosta and Erin Thompson or Erin
Acosta?
A.
Yes.
Q.
And, during your investigation, did you research, determine
whether either of those individuals ever received a PPP loan?
A.
Yes, I did.
Q.
And what did the results show?
A.
Neither of them received PPP loans.
MR. JONES: No further questions, your Honor.
THE COURT: All right.
Cross-examination?
MR. SILBER: Thank you, your Honor.
Could you turn on the projector, please.
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CROSS-EXAMINATION
BY MR. SILBER:
Q.
Good afternoon, Ms. Johnson. How are you?
A.
Good afternoon. How are you?
Q.
I'm well. Thank you for being here?
THE COURT: Is your mic on.
MR. SILBER: Sorry. I keep forgetting.
Can you hear me better now?
THE WITNESS: I can.
BY MR. SILBER:
Q.
Excellent. All right. I am going to lay out a few
documents here.
A.
Okeydokey.
Q.
I know that makes everyone nervous.
Okay. The address we keep talk about --
A.
Yes, sir.
Q.
All right. I am showing you the previously admitted
certificate of completion regarding her PPP loan application.
Of course, you recognize this, right?
A.
I do.
Q.
All right. And this is the certificate of completion from
DocuSign relating to the PPP initial application; correct?
A.
Yes, that's right.
Q.
And, we will say it together. 73.56.139.104?
A.
Correct.
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Q.
And, this here is the login record from Cross River; do you
remember that?
A.
I do remember that, yes.
Q.
Okay. And 73.56.139.104, 73.56.139.104, 73.56.139.104.
Correct?
A.
Correct.
Q.
Okay. One question before I go further. Do you know what
time zone these stamps are in?
A.
Those are Pacific time zones, which is three hours behind
Eastern.
Q.
Okay. And how do you know that?
A.
I know that from reviewing the records.
Q.
Where in the records did you learn that?
A.
If you go to the DocuSign certificate, it should say,
"Pacific time zone."
Q.
Are you talking about the first document I showed you?
A.
Yes.
Q.
Okay. Well, one second. Isn't it true this document, and
over here where it says, "time zone, Pacific," this is produced
by DocuSign?
A.
Correct.
Q.
But, this document is not produced by DocuSign. Is it?
A.
No, that is a BlueVine document.
Q.
BlueVine?
A.
Yes.
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Q.
So, I reiterate my question. How do you know these are
Pacific time zones?
A.
I believe we received a spreadsheet that has the time zones
in it.
Q.
Has that been admitted into evidence?
A.
I don't think we have seen it.
Q.
Okay. You mean it has not been admitted?
A.
I don't think so.
Q.
Okay. And, do you know who you received that unadmitted
spreadsheet from?
A.
We received this information from BlueVine.
Q.
Okay. And isn't it true that Cross River -- do you
remember the lady with the blue and pink hair that testified
yesterday?
A.
Blue and purple, yes.
Q.
Sorry, blue and purple. I apologize. I should have been
more specific. Do you remember her saying that their company
was headquartered in New Jersey?
A.
She did say that, yes, I remember.
Q.
And New Jersey is on the east coast, correct?
A.
Correct.
Q.
And that would be Eastern time; correct?
A.
Yes.
Q.
Okay. But, as we sit here today, you cannot confirm for me
what time zone this is, can you?
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A.
I believe it is Pacific, based on the emails that also
correspond with this activity; but, it does not say on this
document, "Pacific time zone," no.
Q.
And, when you say you believe it, you are not entirely
sure, are you?
A.
I am not completely sure.
Q.
Okay. Just to reiterate, these IP addresses are the same
one as on her application and the one on the logins; correct?
A.
Yes.
Q.
Okay. And, of course, that matches the document that you
received from us, right?
A.
Yes. Yes.
Q.
And, the document you received from us, the DocuSign
certificate, that was Mr. St. Louis's own SBA application;
correct?
A.
That's right.
Q.
Okay. And, he submitted that application in December of
2020, correct?
A.
Yes, yes.
Q.
And, his own personal DocuSign certificate had the same
exact IP address as these logins and her DocuSign certificate;
correct?
A.
That's right.
Q.
And, of course, that follows on the heels of the evidence
we have seen where she has given him an email, her
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loginvcredentials to her G-mail account; correct?
A.
Yes.
Q.
And, of course, to DocuSign something on her behalf, he
could have used those credentials to log into the DocuSign and
sign it as though he was her; correct?
A.
Yes, he could have.
Q.
Moving on, I am showing you what was previously admitted as
Government's 401. Do you remember when Mr. Crevier testified
yesterday?
A.
Yes.
Q.
He is the guy who owned the real estate company, Valordog?
A.
Yes.
Q.
Okay. And, he provided a bunch of checks that were written
to Ms. Acosta in 2019 to pay her -- her commissions. Do you
remember that?
A.
I do remember, yes.
Q.
Okay. Looking at this first check here, Check No. 1039,
you recognize this, right?
A.
Yes.
Q.
Okay. What is that right there?
A.
That appears to be Alexandra Acosta's signature.
Q.
That is the endorsement portion of the check?
A.
Yes.
Q.
And, you would agree that is an authentic signature, don't
you?
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A.
I don't know what you mean by "authentic;" but, compared to
other signatures I have looked at, it looks like her signature.
Q.
What I mean to say is, there is no reason to think this
isn't her actual signature. It is on a check written out to
her, right?
A.
Yes.
Q.
And, that pre-dated any of this back in 2019, right?
A.
Yes. That was on October 11th of '19.
Q.
Yes. So, we can agree that this is her signature, right?
A.
It looks like her signature, and we have no reason to think
not.
Q.
Do you recognize this check?
A.
Yes.
Q.
Same thing here, that is her signature?
A.
Yes.
Q.
And, they look the same, don't they?
A.
Yes.
Q.
Okay.
A.
Similar.
Q.
And, of course, we have this one here. Do you remember
that document?
This is -- sorry, for the record, Government's admitted
500. Do you remember this one, right?
A.
Yes, I do. The signature card.
Q.
Right. And, just for one second, we all know what a
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signature card is, but, to be clear, that is when you open up a
bank account and they have you sign so they have a sample of
your signature, so that when you go and cash your check or
whatever, they can authenticate it that it is really their
customer doing whatever it is, right?
A.
Sure.
Q.
And, you would agree that this is also an authentic
signature by my client, right?
A.
Yes.
Q.
And that one, too?
A.
Yes.
Q.
And, these look the same as the other ones I just showed
you, right?
A.
They do.
Q.
Okay. And, finally, here is the other account. Do you
recognize this one?
This is Government's 501. Do you see that?
A.
Yes, that's the savings account, I believe.
Q.
All right. And you recognize these as the same signature
card, but for a different account, right?
A.
Yes.
Q.
And did you agree these are authentic signatures by
Ms. Acosta, right?
A.
Yes.
Q.
And, these also look similar to the others I just showed
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you moments ago?
A.
They do.
Q.
Okay. Okay. Now, let's talk about Robinhood for a second.
A.
Okay.
Q.
You mentioned in the very, very, very beginning of your
testimony that you had not heard of Robinhood; is that correct?
A.
I believe I said I thought it was a brokerage account, but
I wasn't sure. So, we issued a subpoena to verify.
Q.
Okay.
A.
Because I didn't know if they did other things other than
brokerage stuff.
Q.
Okay. And, when you saw that she had made the $19,000 wire
transfer -- let me go back a few steps, actually. So, let's
get a timeline down so we understand what we are talking about.
February 1st, you agree her loan application was submitted,
right?
A.
I think that was the first login, right, on February 1st?
Q.
Yes. There is a first login. That's correct.
You want me to pull it up?
Right there. Right?
A.
Yes.
Q.
Now, your understanding the facts of this case, isn't it
true that her initial SBA PPP loan application was submitted on
February 1st?
A.
I think, well, yeah. I believe the email does say
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February 1st, but the DocuSign was February 3rd.
Q.
Two different things.
A.
Okay.
Q.
I am talking about the application, not signing the loan
agreement.
A.
Okay.
Q.
Okay. So, February 1st, the process was begun; correct?
A.
Yes.
Q.
And then on February 3rd, it was approved, the loan,
everything was signed for; correct?
A.
Yes.
Q.
And that same day, $20,180 was wired to my client's
checking account; correct?
A.
I believe it was February 4th.
Q.
Oh, the next day?
A.
Yes.
Q.
Okay. Fine, the next day. And the same day that she
received those funds, February 4th, is the same day she
attempted to wire $19,000 to Robinhood; correct?
A.
I think it went to her savings account first.
Q.
It may have traveled a little bit. But, the point is, she
initiated transactions that tried to land those funds into
Robinhood; correct?
A.
Yes.
Q.
Okay. $19,000?
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A.
Yes.
Q.
Right. Okay. Now, we saw a couple of different
transactions. You mentioned something about the $10,000
threshold.
A.
Um-hmm.
Q.
About that. And that is -- because correct me if I am
wrong, but whenever someone does a transaction of $10,000 or
more, a bank must submit what is called a currency transaction
report, am I correct?
A.
I think it is more than $10,000 in currency. So, not
10,000, or more.
Q.
Sorry, I don't mean to talk about currency. I apologize.
A.
It is okay.
Q.
I don't mean just paper money. I mean a bank transaction.
So, for instance, there is a crime called structuring, right,
and that is where people break down their -- to avoid this
report, right?
A.
That's right.
Q.
But, that's not what she did in this case. She clearly did
a $10,000 or more transaction, right?
A.
Yes. It was $10,000, but not more, yes.
Q.
But, that would have triggered a report, right?
A.
Which report?
Q.
Whatever report a bank has to give to the Government about
transactions.
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A.
The $10,000 transaction would have triggered a report?
Q.
Yes.
A.
If it was in currency, yes.
Q.
But -- so, you are telling me if it is not currency, then
the bank doesn't do a report?
A.
No, not that I am aware of.
Q.
Okay. You are the expert. I wouldn't know that as well as
you. But, the point being she tried to put $19,000 of this
money into her Robinhood account the same day she got the
money; correct?
A.
Yes.
Q.
Did you do any follow-up investigating with Robinhood to
determine why the 19 was cancelled and it only remained a ten?
A.
As far as like document review, or, what -- I am sorry.
Can you please restate the question?
Q.
Sure. Let me pull up the Robinhood report that I am
referencing so we are all on the same page.
A.
Thank you.
Q.
And, this is Government's 505. Do you see down there, 505,
Page 16. That yellow design at the beginning -- we will skip
that part. So here, we see ACH deposit, February 4th, $19,000.
Right?
A.
Yes.
Q.
Okay. Then we see a $10,000 right?
A.
Yes.
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Q.
And, these are credits. Credits mean money going into the
account?
A.
Yes.
Q.
Right?
A.
That's right.
Q.
And then, of course, on the same case, we have a $19,000
debit?
A.
Yes.
Q.
So, that would mean the $19,000 cancelled out?
A.
Yes.
Q.
There's no time stamps on any of these here, are there?
A.
No. Just the dates listed there.
Q.
Okay. So, we don't know if these were seconds apart,
minutes apart, hours apart. All we know is they happened
February 4th, right?
A.
I think we know from the emails the timing, the Robinhood
email we reviewed that correlates to the transaction.
Q.
So -- which was the first transaction of these?
We have three here. Let me just identify them for the
record.
We have a $19,000 credit?
A.
Um-hmm.
Q.
Then a $10,000 credit, then a $19,000 debit.
A.
Yes.
Q.
Do you know from the emails which order these happened in?
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A.
Yes. It was a $19,000 deposit that happened first.
Q.
The credit?
A.
Yes.
Q.
Is that the first one?
A.
Yes.
Q.
And what is the second one?
A.
And then the second one -- I am not sure if it was a
cancellation. I have to see the email again. Would you mind
refreshing my memory?
Q.
We can skip that part. I want to get to the point of what
I am getting at here. Did you do any investigating to figure
out what the reason was for these three transactions here?
A.
Other than issuing a subpoena to Robinhood and reviewing
the records and comparing to the bank statements, no.
Q.
So, that is what I am getting at. As an investigator, you
have the ability to interview people to get information,
correct?
A.
We do.
Q.
And, you probably do it all the time with these different
corporations, right?
A.
Yes, sure.
Q.
You must have a counterpart at Robinhood, let's say. I am
just guessing. You tell me if I am wrong. So, some internal
security that interacts with law enforcement when there is
investigations. Am I right about that?
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A.
At Robinhood, I am not sure if they have internal security
or not.
Q.
In your general experience, corporations have someone that
law enforcement can interact with when there is an
investigation, right?
A.
Sometimes, they do, and sometimes, they don't.
Q.
And, when they don't, you would make sure to find someone
to talk to, if you had to; correct?
A.
If it was someone we needed to talk to, yes, we could.
Q.
So, other than requesting records from them, you never
spoke to anybody at Robinhood to explain any of this to you,
did you?
A.
No.
Q.
You didn't take this to someone at Robinhood and say, "Hey,
I am an investigator from the FRB OIG office. We have this
case, and can you just tell me what is going on with this?
What -- when did these -- why is there a 19 and 10 -- and
nothing like that, right?
A.
I did not interview anyone at Robinhood.
Q.
Okay. And, beyond getting the records, you didn't make any
attempts to acquire any additional information to answer this
question, did you?
A.
No.
Q.
Okay. Let's talk about the emails that my client received
in her G-mail account from Scratch, from the SBA, all these
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different places.
A.
Okay.
Q.
And, I would like to compare that to the DocuSign
certificate, just in concept. Okay?
A.
Okay.
Q.
Do you remember the discussion we had yesterday about the
27 seconds?
A.
Yes.
Q.
Okay. To your knowledge, in any of those emails, is there
any information like this that would indicate the time an email
was viewed -- I guess "signed" wouldn't apply -- but is there
any record or piece of evidence in those emails that would
indicate when it was opened and how long it was read for?
A.
No.
Q.
Okay. So, other than telling us that she received these
emails, you are not able to provide us with a piece of evidence
that would indicate they were read or opened, can you?
A.
No.
Q.
And, it is as to these emails, I am talking about --
A.
No.
Q.
Okay.
A.
Can I elaborate on that?
Q.
Sorry?
A.
Can I elaborate?
I was just going to say that some of them were forwarded.
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So, I guess that would mean it was opened, if you forward an
email.
Q.
Okay.
A.
But you have to open it to forward it, right.
Q.
That wouldn't mean the person read it?
A.
No, we don't know if she read it, no.
Q.
That is my point, right?
A.
Okay.
Q.
Another point of clarification, this is Government's 100,
the initial PPP application; correct?
A.
Yes.
Q.
Okay. Referencing business legal name, I think you
mentioned she put her business name as Alexandra Acosta,
correct?
A.
Yes.
Q.
And, isn't it true that the box here was also checked that
says, "self-employed individual"?
A.
Yes.
Q.
Okay. So, when Mr. St. Louis filled this out, he put
"self-employed individual," and, of course, she is not
incorporated. There is no business name, so her name is used,
right?
A.
I wasn't there when it was filled out. So, I don't know
who filled it out.
Q.
Okay. You don't know who filled it out?
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A.
No.
Q.
Were you there when the forgiveness loan application was
filled out?
A.
No, I was not.
Q.
Were you there when the initial loan application was
submitted?
A.
No.
Q.
Were you there when the forgiveness application was
submitted?
A.
No.
Q.
And, you can't tell us who submitted any of those, can you?
A.
No, I can't.
Q.
Other than the fact that you know the IP address is related
to Mr. St. Louis?
A.
It is.
Q.
And, there is no dispute that my client was lawfully and
legitimately working as a part time realtor in 2019; correct?
A.
She had; yes, she had real estate income for 2019.
Q.
And that was the $13,900; correct?
A.
Yes, yeah.
Q.
And, there is also no dispute that she truly and
legitimately earned the $103,000 reported on her 1040 from her
work as a Broward sheriff's deputy, correct?
A.
Her wages were listed as approximately $103,000, yes.
Q.
Okay.
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MR. SILBER: May I have a moment, your Honor?
THE COURT: Yes.
MR. SILBER: I have nothing further at this time, your
Honor.
THE COURT: All right, thank you.
Any redirect?
MR. JONES: Just briefly.
REDIRECT EXAMINATION
BY MR. JONES:
Q.
Ms. Johnson, I just want to clarify a statement that was
made in the question, because there seems to be some confusion,
if there's a transaction of $10,000, does that trigger any
requirement, or must be it be over $10,000?
A.
Over $10,000.
MR. JONES: No further questions, your Honor.
THE COURT: Okay. All right.
Thank you. You can step down.
[Witness Excused.
Who is your next witness?
MR. JONES: The Government rests, your Honor.
THE COURT: Okay. So, members of the jury, the
Government has just rested their case. I need to take up some
legal matters and take up scheduling. So, I ask you to go into
the jury room for just a few minutes, and we will be right back
with you.
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COURT SECURITY OFFICER: All rise.
[Whereupon, the jury left the courtroom at 3:58 p.m.,
and the following proceedings were had:]
THE COURT: Thank you. Please be seated.
So, we are here in open court outside the presence of
the jury, but everybody else is here, and the Government has
rested. Anybody have any motions?
MR. SILBER: I do, your Honor. I would motion for a
judgment of acquittal; a couple of points; one, I didn't hear
any evidence put on identifying the person sitting next to me
as Alexandra Acosta. I think the Government failed to identify
her as the defendant, number one.
Number two, as to the count relating to the forgiveness
application, there has been no evidence authenticating that she
is the person who submitted it. And, the witness yesterday
testified on cross that she could not tell us that the
signature on there belonged to my client, as compared by
contrast at least to the initial application, where at least
they put on evidence that it is connected to her G-mail
account. But, as to the forgiveness, there is no connection.
And, overall, we would just ask the Court to issue an
order of acquittal for the Government's failure to at least
make a prima facie case as to all counts.
THE COURT: All right.
Let me hear first on the --
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MR. SILBER: I also renew all previously made
objections.
THE COURT: Okay. Let me hear from the Government
first on the issue of identification of the defendant.
MR. JONES: Your Honor, the defendant has appeared here
pursuant to an arrest warrant. She was arrested, she has
appeared. She never contested her identity as a defendant
named in this case. The codefendant, or Vilsaint St. Louis has
stated that this person is the person that he conspired with.
That is in the --
THE COURT: When did that happen, in the last day and a
half?
I mean --
MR. JONES: Understandable, your Honor. And, in this
instance, there has been no contestation that this is not
Alexandra Acosta.
THE COURT: They just moved for a judgment of acquittal
on that ground, so I think that is contesting it.
MR. JONES: To the extent that it is considered an
issue, we would move to reopen the case.
THE COURT: And, who would you put on?
MR. JONES: Ms. Tonya Johnson, who was there, present
during this process when -- purportedly when we identified
Ms. Acosta and ultimately had her appear at her first
appearance.
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Alternatively, I can call another witness. I could
call back Mr. Crevier to identify her.
THE COURT: Is he here?
MR. JONES: He is not here, your Honor.
THE COURT: Well, assuming you called Agent Johnson
back, how is she going to identify her as having -- that she
was in court when she was arraigned, and then that's the same
person?
MR. JONES: She has also reviewed her driver's license
and advanced as checked her signatures and address and picture
of Ms. Acosta, aligned with all of the documents assigned with
this as a formally signed document with the State of Florida,
and --
THE COURT: All right.
Do you have any objection to the Government reopening
the case for that limited purpose.
MR. SILBER: I do, your Honor. I do object to that.
They have had the chance for two days to put their case
on. I object to the Court allowing them to reopen it to fix a
basic error. I mean, this is something that, you know, every
county court prosecutor learns his first day on the job.
THE COURT: Yes. As I did in 1981, for some.
MR. SILBER: And, I would object to Ms. Johnson
identifying my client because she has no personal knowledge.
All her knowledge is based on hearsay.
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THE COURT: Okay. So, I am going to allow the
Government to reopen its case to put on the agent to see if
they can establish her identification.
All right? Bring in the jury.
[Whereupon, the jury entered the courtroom, and the
following proceedings were had at 4:00 p.m.:]
THE COURT: All right. Please be seated.
All right, members of the jury, during that brief
recess, I am allowing the Government to reopen its case
briefly.
So, who do you want to call?
MR. JONES: Recalling Special Agent Tonya Johnson, your
Honor.
THE COURT: Please come back up, and you are still
under oath from earlier today.
REDIRECT EXAMINATION (RECALL)
Of TONYA JOHNSON
BY MR. JONES:
Q.
Good afternoon again, Ms. Johnson, or Special Agent
Johnson. Special agent, for point of clarification, we have --
during your investigation, did you have an opportunity to
review and obtain Florida records pertaining to Ms. Acosta?
A.
Yes.
Q.
And were some of those records -- what were some of those
records?
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A.
Florida driver's license.
Q.
And does the Florida driver's license -- when you received
those records, what was the process for obtaining them?
A.
We requested, there is an online database called David, and
it has driver's license information for the State of Florida.
Q.
And is that a program or a platform that is often
referenced by law enforcement?
A.
Yes.
Q.
And when you searched for Ms. Acosta's information, did it
populate the same address that you have her to live at?
A.
Yes.
Q.
And the image of the person that you saw, is she in the
courtroom today?
A.
She is in the courtroom today.
Q.
Where is she sitting, and can you point out what she is
wearing?
A.
She is wearing a suit, and she is next to her attorney at
the defense table.
MR. SILBER: I can't hear what is being said.
THE WITNESS: She is wearing a suit, and she is sitting
next to you at the defense table.
THE COURT: Let the record reflect she has indicated
the defendant.
BY MR. JONES:
Q.
Now, in addition -- at some point, we are here for a trial
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-- was Ms. Acosta arrested?
MR. SILBER: Objection, outside the scope of the
recall.
THE COURT: Overruled.
THE WITNESS: Yes.
BY MR. JONES:
Q.
And, at that time, did she have to make an appearance in
court?
A.
She did.
Q.
Were you there at that time?
A.
Yes, I was.
Q.
Did you see the individual that you identified as Ms.
Alexandra Acosta at that initial appearance?
A.
Yes, I did.
Q.
Did she respond in kind to the initial as if it were her
that was indicted?
A.
Yes, she did.
Q.
And, at any time, has Ms. Acosta challenged you, based on
her identity, as being the person named in this indictment?
A.
No.
MR. JONES: Nothing further.
THE COURT: Any recross on that issue?
MR. SILBER: No, thank you.
THE COURT: You may step down.
Is the Government resting?
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MR. JONES: Yes, your Honor.
THE COURT: All right, folks. You can go back into the
jury room so I can move on to other issues here.
[Whereupon, the jury left the courtroom at 4:06 p.m.,
and the following proceedings were had:]
THE COURT: Okay.
Thank you. Be seated. We are once again outside the
presence of the jurors. So, I will deny the motion for
judgment of acquittal on the issue of identification of the
defendant in court.
So, what is your response as to the underlying charges
and the sufficiency of the evidence?
MR. JONES: Yes, your Honor. Based on the agreed
elements that have been presented to the Court for the jury
instructions, we have conspiracy to commit the false statements
to the SBA and two false statements to the SBA as well as the
wire fraud.
For the first count, conspiracy to submit false
statements to the SBA, the only thing that is required is that
a false statement was made. And, I don't think anybody here
disputes that that happened. The tax records that were
supported or sent in support of the application for a PPP loan
were false. The information that was contained in the face of
the application was false.
There is evidence that there is linking in time, the
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defendant and Mr. St. Louis together in the same date that this
application was created.
There is email correspondence between them throughout
this period, relating to the tax case, relating to the SBA, the
PPP application, where the two individuals are speaking about
it, and Ms. Acosta attempts to hide this from her wife.
There is circumstantial evidence that Ms. Acosta was in
agreement with Mr. Vilsaint St. Louis, which is evidenced by
the statement that she had asked him not to tell her wife.
They conspired for that, effectively, but it shows that they
are capable of conspiring together, and that is what they did
on February 1st and February 3rd, as well as -- or February --
yeah, February 3rd, as well as April 20th and 21st. It is
clear she is involved.
The nature and circumstances of this establishing that
she knew Mr. St. Louis on February 1st either was the
hands-down, worst person in the world when it comes to
preparing taxes, or she agreed with him that this would be
something they can accomplish.
The timing and circumstances of this $18,000 loan that
is in front of them versus the seven days later applying for a
$21,000 PPP loan that is false indicates sufficient evidence
that Ms. Acosta knew the purpose of the loan, was motivated by
that, and then later, still continued to try and get -- cut
away at her IRS tax case, and, later spent the money, you know,
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just whittled it around.
So, I believe that the false statements, the knowledge
element of this is either deliberate ignorance, which is
instruction that will be given, or that is agreed by the
parties, or actual knowledge. And, those are circumstantial
evidence.
And, your Honor has instructed the jury the same, that
circumstantial evidence is just as strong as any direct
evidence. Of course, no one is going to be in the room that
day filming her while she is there.
We have to infer from the circumstances to prove our
case. And, the jury can do that, based on the evidence
presented.
As for the wire fraud counts, we have to prove an
intent to defraud. And, I do want to, I guess, come back to
the SBA, that there is no need to prove intent to defraud for
that count, or, willfulness. It is specifically omitted from
the statute, and the only requirement is knowledge and false
statement.
Now, for the wire fraud, there is a required element of
intent to defraud. And, in this circumstance, I think all --
as I have already stated, for the reasons that support the
other cases, I think that substantially supports that there was
intent and knowledge here. There is deceit that has been --
there is evidence, based on the record, and there is the scheme
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and artifice of the timing of this.
Getting off the phone with the IRS about your tax debt
and then applying for this loan the same day when you know you
only made 13,000 in the year that your tax preparer wants you
to submit in support of an application, it just strains
credulity. And, I think the jury has sufficient evidence in
order to establish or find a verdict of guilty as to all
counts, and that the defendant acted knowingly and with the
intent to defraud as to Count 4.
THE COURT: All right. I think the Government's case,
although it is circumstantial, it is sufficient to -- in the
light most favorable to the Government, to establish a prima
facie case of guilt as to each element of each offense. I will
deny the motion for judgment of acquittal.
What is the status of the defense case?
MR. SILBER: Your Honor, I would ask for us to recess
at this point so that I can work with my client to prepare her
testimony, because she wishes to testify.
THE COURT: No. It is only four o'clock. If she is
going to testify, we will go forward now.
MR. SILBER: Okay. Can I have 15 minutes to talk with
her?
Or ten minutes?
THE COURT: Ten minutes.
MR. SILBER: Thank you, your Honor.
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THE COURT: We will see everybody in ten minutes.
MR. SILBER: Thank you.
COURT SECURITY OFFICER: All rise.
(Brief recess.)
THE COURT: Please be seated.
All right. Is it your intention to call Ms. Acosta as
a witness?
MR. SILBER: Yes, your Honor.
THE COURT: All right. Ms. Acosta, let me explain to
you that as a defendant in a criminal case, you have
Constitutional right to testify, but you also have the
Constitutional right not to testify.
Do you understand that?
THE DEFENDANT: Yes.
THE COURT: And, there are three decisions, in the
context of criminal cases, in which the defendant has the
personal right to make a decision; that is whether to plead
guilty or not guilty, whether to have a trial before a judge or
jury, whether to testify or not testify.
If you want, Mr. Silber can ask your questions on
cross-examination. He can overrule you because he doesn't have
to listen to you on that particular issue.
But, on those three issues, the most important being
what we are discussing now, do you understand it is your own
personal decision to make?
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You should obviously consult with Mr. Silber and listen
to his advice. But, if he wants you to testify and you don't
want to testify, you can overrule it. Do you understand that?
THE DEFENDANT: Yes, your Honor
THE COURT: Is it your own personal decision to testify
as a witness in the case?
THE DEFENDANT: Yes, your Honor.
THE COURT: Has anybody promised you anything or forced
you, threatened you, or coerced you in any way to come to that
decision?
THE DEFENDANT: No, your Honor.
THE COURT: All right. Let's bring in the jury,
please.
COURT SECURITY OFFICER: All rise for the jury.
[Whereupon, the jury entered the courtroom at 4:25
p.m., and the following proceedings were had:]
THE COURT: All right. Welcome back, everyone, and
please be seated.
All right. When we left off, the Government had rested
its case.
And, what is the status of the defense's case?
MR. SILBER: Your Honor, at this time, we would call
the defendant, Alexandra Acosta.
THE COURT: All right.
Please come forward to be sworn, and take the witness
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stand.
Thereupon,
ALEXANDRA ACOSTA,
having been first duly sworn or affirmed, was examined
and testified as follows
THE WITNESS: I do.
THE COURT: Please have a seat, adjust the microphone,
and, when you are ready, tell us your name and spell your last
name.
THE WITNESS: It is Alexandra Acosta, A-C-O-S-T-A.
THE COURT: All right, thank you.
Is your mic on?
MR. SILBER: It is this time, your Honor.
DIRECT EXAMINATION
BY MR. SILBER:
Q.
All right. Ms. Acosta, we spent a couple of days actually
talking about you. But, this is your chance to address the
jury. Why don't we begin with your background. First of all,
how old are you?
A.
I am 38.
Q.
And, where were you born and raised?
A.
I was born and raised in Miami, Florida.
Q.
Okay. And, did you go to high school here?
A.
Yes, I went to Monsignor Pace High School.
Q.
Do you have any siblings?
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A.
No. I am an only child, first generation American.
Q.
Where are your parents from?
A.
Both from Cuba, sir.
Q.
Okay. And did you go to university or college?
A.
Yes.
Q.
And, where did you go to college?
A.
I graduated from Valdosta State University.
Q.
And did you get good marks?
A.
Yes. I was also a two-time all-American softball player.
Q.
And what degree did you get, if any?
A.
I got a bachelor's degree in Criminal Justice.
Q.
Okay. And after attending college, did you get -- did you
start working?
A.
Yes.
Q.
And what kind of work did you do?
A.
I was a teacher and a coach.
Q.
Okay. And, eventually, I guess you entered law
enforcement; correct?
A.
Yes, I did.
Q.
What year did you attend the police academy?
A.
I started in 2012.
Q.
Okay. And, how did you do at the police academy?
A.
I graduated number one overall. I was voted class
president. I gave the class speech. I would say I did pretty
well.
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Q.
Okay. And, upon graduating from police academy, did you
then get your Florida certified -- for lack of a better term,
law enforcement license?
A.
Yes. I was a certified police officer in the state of
Florida.
Q.
Okay. And that certification is still current; correct?
A.
Correct.
Q.
Okay. When did you start working at the Broward Sheriff's
Office?
A.
June 3, 2013.
Q.
Okay. And, did you begin as a road patrol deputy, I guess?
A.
Yes. I was assigned road patrol for the city of West Park.
Q.
And, at a later point in time, did you ever transfer out of
the West Park.
A.
Yes, I did.
Q.
And, where were you transferred to?
A.
I was transferred to Fort Lauderdale International Airport,
where I was on the incident containment team.
Q.
And what is an incident containment team?
A.
It is the tactical unit that was created at the airport
after the shooting, mass shooting at the Fort Lauderdale
Hollywood Airport.
Q.
And what does your team do in response to those
circumstances?
A.
We are the tactical team to prevent crime and deter, I
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guess, bad guys from coming to the airport. And, I was also
assigned the canine while I was on the unit.
Q.
And was that a normal canine or special canine?
A.
He was -- is a vapor wake bomb dog.
THE COURT: Wait. He is a what?
THE WITNESS: A vapor wake bomb dog. He is specialized
in protecting person-borne explosives. So, my dog looks for a
suicide bomb person; specifically, we work in crowds to look
for bombs on moving objects or moving people in crowds.
BY MR. SILBER:
Q.
And, when your dog detects a bomb, what is it your job,
what are you supposed to do at that point in time?
A.
I have a cover team. They address the subject, and I get
on the radio and make radio procedures.
Q.
Okay. And would it be your job to stop the person?
A.
Yes.
Q.
Okay. And, at the airport, did you have any other jobs
like protection, anything like that?
A.
Yes. The incident containment team was also in charge of
dignitary protection at the airport, protected people like the
president, the vice president.
I did daily Congress escorts to and from airplanes.
Q.
Okay. And, upon finishing your term at the airport, did
you transfer anywhere else?
A.
Yes. After my time with the airport, I am proud to say
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that I made the Broward County sheriff's office SWAT team, and
I am the first female to ever do that.
Q.
Okay. And the only female; correct?
A.
The only female to ever do that.
Q.
Well, if you need a moment, tell me.
A.
I worked really hard for that.
Q.
Tell us about that. How did you end up on SWAT?
What did you have to do to get on SWAT?
A.
Well, I was on the incident containment team.
Q.
Slow down. Don't mumble your words.
A.
While I on the incident containment team, I was afforded
the opportunity to work out on duty due to my tactical position
there, and, I was able to successfully train and complete a
three weeks SWAT school, which is one of the toughest schools
in the country.
Q.
What makes it so tough?
A.
It is extremely physical. You know, you are running
several miles a day, you are swimming, you are, you know,
shooting rifles, handguns; you are wearing probably 30 pounds
of gear all day, every day in the sun.
And, you know, at the end of the day, I am just trying to
compete and stay up with everybody else.
Q.
Do most people quit?
A.
Yes. It has got like a five percent pass rate.
Q.
Okay. And, how many times did you attempt to get in and go
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through SWAT school?
A.
I attempted SWAT school once. I had that tryout twice.
Q.
Okay. And what happened in the first tryout?
A.
I failed to pull a 225-pound sled -- probably was five feet
short of missing the time.
Q.
And, how far did you have to pull it altogether?
A.
40 yards to, and then 40 yards back, after some agility
exercises.
Q.
And you missed it by five feet.
A.
More or less.
Q.
So, you tried out again?
A.
Yes.
Q.
How much later did you try out again?
A.
I believe it was a year and a half later.
Q.
Okay. Let's pause for a moment. What year were you doing
this SWAT activity, trying out, going through SWAT?
A.
I believe it started 2019, 2020.
Q.
Okay. And, in order to get ready for SWAT tryouts, what
did you have to do?
A.
I had to sacrifice a lot of free time, a lot of time with
my family, a lot of time from work. I had to work out more
than I normally would.
Running is a big part of SWAT school. And, that is one of
my weaknesses, is running. So, I had to get myself in running
shape.
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Q.
How much running did you do every day?
A.
I would say I was running at least four to five miles every
day, if not longer.
Q.
Okay. And how long through 2020 did you do that?
A.
The whole year.
Q.
Okay. And did that take up a lot of your free time?
A.
Yes, absolutely.
Q.
Okay. And, other than the physical aspect, did you do any
additional practice, like marksmanship, or things like that?
A.
Yes. I would take free time and go to the range whenever I
could.
Q.
And, what I am getting at is to prepare for SWAT school, it
sounds like it is a lot?
A.
Yes, it is a lot. It definitely took a toll on myself and
my family.
Q.
And, of course, while you are doing that, you are also
working full time?
A.
Yes, correct.
Q.
And you mentioned your family. Are you married?
A.
Yes, I am married.
Q.
And any kids?
A.
Yes. I have two young children, a daughter and a son.
Q.
Sounds like you have a very busy schedule.
A.
Yes. My schedule is really hectic.
Q.
Okay. And, in reference to the discussions we have had
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here during the course of this trial about your real estate
activity, let's pause on your background a minute and let's
talk about your real estate background, pause on your law
enforcement background and talk about the real estate
background.
Was real estate ever a full time career for you?
A.
No, it was always a part-time thing.
Q.
And, you did it part-time while you were employed at the
Sheriff's Office?
A.
Yes, sir.
Q.
Okay. And is that a common practice amongst law
enforcement?
A.
Yes. I know several law enforcement officers who were also
realtors.
Q.
And, they could be anything else also, landscapers,
plumbers?
A.
Yes.
Q.
Pressure cleaners?
A.
Correct.
Q.
It is common in law enforcement for people to have, like, a
side gig, right?
A.
Yes. Our schedule allows for us to have a few days off.
So, we have side jobs, a lot of times.
Q.
Okay. And even though you were focused on getting into
SWAT in 2020, did you still maintain your real estate license?
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A.
Yes, I did.
Q.
And, were you available if a friend or colleague was
looking for a place to buy or to rent?
A.
Yes, absolutely. That was most of my work, was friends and
colleagues and other police officers who wanted to buy or sell
houses.
Q.
Okay. And it was just to supplement your income; correct?
A.
Correct.
Q.
Okay. All right. Moving along, so, when did you attend
SWAT school?
A.
I attended SWAT school in November of -- end of October and
November 2022.
Q.
'22. Okay. And, did you pass SWAT school, not the
tryouts, the school, on the first try?
A.
Yes, I did.
Q.
Okay.
A.
First female to ever do that.
Q.
All right. And, upon graduating from SWAT school, were you
assigned to the SWAT team?
A.
Yes.
Q.
Okay. And, just generally, without getting too far into
it, what were your duties as a SWAT officer?
A.
I was assigned to the Titan Unit, and we responded to
critical incidents throughout the county. So, if there was a
shooting, a stabbing, a robbery, they would dispatch my team
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and I. We rode in pairs to assist road patrol with the
advanced tactical expertise that we carried since our training
was so heavy.
Q.
Is it fair to say that SWAT is kind of like the stronger
forces when more of a strength is needed in a violent
situation?
A.
Yes, absolutely.
Q.
Potentially violent situation?
A.
Yes.
Q.
And, are you trained in close-quarters combat, hostage
rescue, things of that nature?
A.
Yes. We train every single Wednesday, all day.
Q.
Okay. All right. Let's talk about your audit for a
moment.
A.
Yes, sir.
Q.
Okay. Actually, before we to that, let's get into your
relationship with Mr. St. Louis, and then we will talk about
your audit.
At the time of this incident, you know, obviously, it is
now 2024. This event allegedly occurred in 2021. So,
referencing that time period, 2021, at that point in time, how
long had you known Mr. St. Louis?
A.
I had known him since 2014, '12 or '14.
Q.
All right.
A.
So, almost nine years.
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Q.
Okay. And what context did you know him?
A.
He was my tax preparer. He had always prepared my taxes.
So, we had a business relationship.
Q.
Okay. Was there anything personal about it?
Did you guys ever hang out?
A.
No. He -- we never hung out. He called me one time. I
know he was having an issue with his wife, and he called me for
advice because he knew I had gone through a similar issue; but,
other than that, no.
Q.
Okay. And that's from a prior relationship, you are
referencing?
A.
Correct.
Q.
He was getting divorced, and he had some questions about
the process?
A.
Correct.
Q.
Okay. So, it is fair to say, then, it was a strictly
business relationship?
A.
Absolutely.
Q.
Okay. And was there ever a gap in time where you did not
use him as a tax preparer?
A.
No. He prepared my taxes ever since I started going to
him.
Q.
Okay. And, to prepare your taxes, would you meet with him
annually, multiple times, or how would that go down?
A.
It was either once or twice, I would drop off documents,
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and/or sit there with him for a short amount of time, and then
leave; or, sometimes I would drop off documents and not see him
at all. It just depended on how busy he was.
Q.
Okay? Let's talk about that process just for a second.
You would drop off the documents, and would you meet with him
and discuss each individual document?
Was there a general discussion?
Can you just elaborate on that for us?
A.
No. It was, "Here is my W-2. Here is my 1099."
I gave him mileage based on what I had from my realtor app.
On the realtor app, there is an app we can use that shows the
houses that we are going to show to clients. So, I had mileage
based on that.
And, I gave him my bank statements for realtor expenses
that I spent. Any documents he ever asked for -- he asked me
to have a year-to-date for my Capital One card, which is
normally what I used for my business expenses, and I gave him
all that information.
Q.
And, what would he do with that information?
A.
He would sit behind his computer and type in the numbers.
Q.
Okay. Were you involved in the analysis portion of those
things?
A.
No. Not at all. Numbers are not really my thing. They
still confuse me.
Q.
And, of course, that is why you hired a tax preparer?
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A.
Absolutely.
Q.
Because you needed someone else to do it for you?
A.
Yes.
Q.
Okay. And, you trusted him to do it for you?
A.
Yes, I trusted him. I had never had an issue with his
honesty before. He was always somebody that did my taxes, and
I never had the trust issue with him before.
Q.
Okay. Now you do, of course?
A.
Absolutely. Yes, I have, since I learned he was doing
things incorrectly behind my back; but, I had no idea of the
things that he was doing. He was minimizing a lot of the
errors and omissions that he was making on his statements.
Q.
Are you referencing the audit?
A.
Yes. And, apparently, my taxes, as well.
Q.
Okay. Well, let's talk about that. After he completed
your tax returns, who submitted them, him or you?
A.
He did.
Q.
Okay. And, did he ever sit down with you after preparing
them and go, line item by line item, "I put this, I put that,"
or, did he just generally tell you they were done?
A.
No. He told me my taxes were done, and this is the amount
of return I should be prepared for.
Q.
Okay. And, let's talk about your trust in him for a few
minutes.
You mentioned you had never had a reason to distrust
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his honesty. Okay. Does that have any extra or special
meaning to you because you are in law enforcement
A.
Yes, absolutely. You see, he is somebody I had gone to
ever since I got into this career, and I never had an identity
issue. Not to mention that I don't want to just be giving my
information to just anyone. I mean, he had my kids' socials,
he had my wife's information, who is also in law enforcement.
Those are things that I don't want just the general public to
know. I wouldn't just give that information to anyone.
Q.
And, did you feel he kept those, that personal confidential
information secure?
A.
I mean, I had heard of identity things all the time, and I
never had any issues like that with him.
Q.
Okay. So, you always felt your information was safe with
him?
A.
Absolutely.
Q.
And, he always made you feel like you could trust him?
A.
He always made me feel I could trust him, and he never gave
me a reason not to trust him until now.
Q.
Okay. Let's fast-forward to your audit now. Okay. You
first received notice of your audit in December of 2020; is
that correct?
A.
Correct.
Q.
Okay. What happened after you got that first notice?
A.
I sent him an email saying, "Hey, I have received this
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audit. What -- like, what do I have to do?"
Q.
Okay.
A.
Or, "I received this tax examination. What do I need to
do?"
Q.
And, we are going to go step by step. What happened after
that?
A.
He responded and said to come by his office.
Q.
Okay. And did you meet with him?
A.
Yes.
Q.
And, when did you meet with him?
A.
The next day, to sign a power of attorney.
Q.
Okay. And, let's talk about the power of attorney for a
second. What did it mean to you -- why did you sign that
document?
A.
He told me in order for him to talk to the IRS on my
behalf, I needed to sign a power of attorney to him.
Q.
And, that gave him legal authority to speak on your behalf
to them?
A.
From what he told me, yes.
Q.
Okay. And they would refuse to speak to him about your
case unless you signed that document?
A.
Correct.
Q.
Okay. So, you signed the document.
What is the next step?
A.
After signing that document, he -- I believe he was in
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contact with the IRS.
Q.
Was it your impression that you would be involved in that
process, or did you generally think he would handed it?
A.
I thought he would handle everything. He told me once he
had the power of attorney, he could handle it all for me.
Q.
Okay. And, when you mentioned to him, "Hey, tax preparer,
I am being audited," what was his response?
Did he admit a problem?
Did he minimize it?
Did he say he didn't know anything about it?
A.
He made it very minimal. He made it seem like it wasn't an
issue at all. He -- as a matter of fact, on the head page of
the IRS audit, it stated something about I could get a return
back. So, it was just kind of a standard thing that some
people go through. And, from my understanding, I had had
friends and coworkers who had been audited before. It wasn't a
big deal to me.
Q.
You mentioned something about you could get money back.
Are you referencing the letter they sent you?
A.
Yes.
Q.
And what, specifically, did it say in that letter?
A.
The letter said that I could either get money back, not owe
anything at all, or I could have to owe a refund.
Q.
So, it was a -- basically, telling you, you are being
audited, and the potential outcomes?
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A.
Correct.
Q.
And, he handled the process from there?
A.
Yes.
Q.
Okay. How was he with communication?
Was it easy to get hold of him?
A.
Not always. He was pretty good, sometimes, with emails;
but, if I ever tried to call him on the phone, it was hit or
miss.
Q.
Hit or miss?
A.
Yes.
Q.
Okay. And, getting ahold of him by phone, would that
require multiple phone calls?
A.
Yes, usually, and especially during tax season.
Q.
But, he would always eventually get back to you, right?
A.
Yes. I have learned now that there was -- the times that
it took him a while to get back to me, it seemed like there was
a good reason it was taking him so long.
Q.
And what was that reason?
A.
It seemed like he was hiding something from me.
Q.
And, when did you have that realization?
A.
After all this happened.
Q.
After you were arrested?
A.
Yes.
Q.
Okay. And, we will get to that. We will circle back to
that later. And, in terms of the audit, while the audit is
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going on, since you gave him power of attorney, can you tell us
if he received, to your knowledge, all the notices and papers
that the IRS would send?
A.
Yes.
Q.
Okay. And, did you rely on him to respond and deal with it
correctly?
A.
Yes.
Q.
Okay. And, did there come a time when you disagreed with
him during the audit?
A.
Yes.
Q.
Tell us about that.
A.
Well, I realized that he wasn't making contact with the IRS
like he should have been. And, I had to end up calling the IRS
on my own behalf and seeing what was going on with my audit
because I was getting letters saying that I was going to owe
what he didn't tell me I was going to owe.
He had minimized the whole thing, saying I might not owe
anything at all. It was going to be very minimal, or, it was
just a simple mistake he made, and it would be very minor.
Q.
And, did he ever explain to you what the problem was with
your taxes?
A.
He said that he made a double entry on my -- something
about my home or mortgage, something like that.
Q.
Like, it just an error, he hit -- maybe "enter" twice by
accident?
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A.
Yes.
Q.
Okay. Did he ever confess to you that he didn't understand
that you can't take mileage and expenses?
A.
He did say that while we were on the phone with the IRS
auditor or examiner.
Q.
And was that the first time you heard that?
A.
Yes.
Q.
Okay. And, what about the other problems in the taxes?
Did he ever admit that to you?
A.
I don't really remember. I -- I still don't really
understand a lot of it, to be honest.
Q.
Okay. And, if you could point a finger at one thing he did
wrong in your mind, what is the thing?
Is it the tax -- the double entry of that property tax?
A.
No. I mean, yes, on the audit, but --
Q.
That is what I am referring to. Sorry. I meant to say in
regards to the audit.
A.
Yes. On the audit, he made a double entry.
Q.
Okay. And, at the time of the audit, when you learned that
it was possible you might owe some back tax, were you gainfully
employed at that time?
A.
Yes.
Q.
And, how much were you earning at that time?
A.
At the Broward Sheriff's Office?
Q.
Yes.
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A.
A hundred thousand dollars.
Q.
So, you weren't hurting for money. You were making a
living, right?
A.
Yes.
Q.
And you live in a house with a dual income, right?
A.
Yes.
Q.
And, after finding out that the -- you were being audited,
let's fast-forward to the end of January, 2021. Okay?
When you found out that you may potentially owe about
$18,000 -- do you recall that?
A.
Yes.
Q.
Okay. Did Mr. St. Louis advise you that that is exactly
what you would owe, or did he feel it would be much less than
that?
A.
No, he always minimized it, he always said it was going to
be much, much less than that.
Q.
And, at that point in time, did you believe him?
A.
Yes. I had no reason not to trust him.
Q.
At that time, you believed in his honesty?
A.
Yes. He had never lied to me before.
Q.
Okay. Let's fast-forward to February 1, 2021, a couple of
weeks later. Did you meet with him on that day?
A.
Yes. I did.
Q.
Okay. And, what was the purpose of that meeting?
A.
To drop off my taxes for the 2020 year, 2021 year.
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Q.
Okay. And was the audit discussed at that time?
A.
Yes. It was.
Q.
And was the PPP loan discussed at that time?
A.
Yes, it was.
Q.
Okay. Tell us what he told you about the PPP loan. Well,
first of all, let me ask you this question. Who initiated the
question about the PPP loan?
A.
He did.
Q.
He brought it up first, not you?
A.
Yes, Mr. St. Louis.
Q.
Okay. And what exactly did he say to begin the
conversation?
A.
Mr. St. Louis told me that I qualified for a payroll or
payment protection loan because I was a realtor, and I had a
1099, and he called it a COVID loan.
Q.
He called it a what?
A.
A COVID loan.
Q.
Okay. And, when he says you had a 1099, what year was he
referencing?
A.
2019.
Q.
Okay. And, when he told you, you would qualify for a
paycheck or Paycheck Protection Program, did you ask him any
questions about it?
A.
Yes, I did.
Q.
And what did you ask him?
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A.
I asked him, "Well, I don't have a payroll. I don't have
employees. It is just me. How do I qualify for this?"
Q.
And what answer did he give you?
A.
He said, "It is what they use to supplement your income
during COVID, and it was used to, you know, for COVID relief."
Q.
Did he tell you that you had to have employees to get a
payroll or Paycheck Protection Program loan?
A.
No. He said it could be used for other things. It was
just to stimulate the economy.
Q.
And, when he said the money could be used for other things,
did he elaborate and give you examples, or he just generally
spoke, and that was it?
A.
He just generally spoke and said that it was part of -- it
would be part of what I would have made during COVID.
Q.
Okay. Now, let's pause for a second. I want to go back
about how your taxes were prepared, and we will circle back to
this discussion in terms of submitting your taxes, okay, and,
in terms of the services that he provided to you.
So, you would drop off your documents, your W-2, 1099, blah
blah blah. Right?
A.
Yes.
Q.
And, he would do some kind of calculating on the computer
and fill out all the forms, right?
A.
Yes.
Q.
And then he would submit them electronically; correct?
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A.
Yes.
Q.
Okay. And that was the normal course that you did all
those years with him, in preparing the tax, right?
MR. JONES: Objection, leading.
THE WITNESS: If I stayed there with him, yes.
MR. JONES: Just objection.
THE COURT: Overruled.
BY MR. SILBER:
Q.
The point being, you provided him the documents, prepared
the taxes, and he would submit them; correct?
A.
Yes.
Q.
You never, personally, submitted your own tax returns?
A.
No, I never submitted them.
Q.
Okay. Let's go back to your PPP loan discussion.
How were you going to apply for the PPP loan?
Were you going to do it, or was he going to do it?
A.
He told me it was an easy process for him. He already had
all my paperwork, and he would apply and submit it to me just
like he always did with my taxes.
Q.
Okay. And is that, in fact, what happened?
A.
Yes.
Q.
Okay. And, to create the PPP loan in the application, and
the whole submission process, how was he able to do it in your
name?
A.
He said he just needed my email and my password. So, I
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wrote it down on a little yellow sticky note and I handed it to
him.
Q.
Why did you feel comfortable giving him that information?
A.
As somebody, one I had been going to since 2014, he has my
social security number. He has my kid's social security
number, and my address. Those are things that don't change.
If I wanted to change my password, I could always change my
password.
Q.
So, you felt there wasn't any real threat, and you had
trusted him with more serious private information, right?
A.
Yes.
Q.
Okay. So, he tells you he would handle everything. You
give him your email information. Does anything happen further
in the conversation at that time?
A.
That I would be receiving an email from Scratch.
Q.
Okay.
A.
Later on, down the road.
Q.
And, what were you supposed to do with that email?
A.
Just forward him the emails. He would handle -- that would
be part of the forgiveness portion, and he would handle that,
as well.
Q.
Okay. When you received -- let's talk about the
information that was received by your email account. Okay?
So, February 1st, you meet with him. Do you know when,
after that, he actually submits the loan papers?
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Was it the same day?
Was it the next day?
Or, do you not know?
A.
I now know it was the same day.
Q.
At that time, did you know?
A.
No.
Q.
Okay. And, as he started doing the loan application
process, were you seeing emails come into your email account?
A.
At that time, no.
Q.
Okay. And why didn't you pay attention to these emails?
A.
They were already opened. It was probably a bunch of
emails over it, and, specifically, on February 1st, when I was
there, I had a dignitary that I had to walk to the airport, to
their gate. So, I wasn't able to check my emails until way
later in the day.
Q.
Okay. Now, can you remind us again, when is it that you
tried out and attempted for SWAT school? The second tryout, I
am referring to?
A.
The second tryout, I believe was possibly June of 2022,
somewhere along there.
Q.
And, when was the first tryout?
A.
Late -- maybe late 2020.
Q.
Okay. And, during this time, did you ever stop preparing
for SWAT, stop training for SWAT?
Or, did you keep up your routine?
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A.
No. I always kept up my routine because I wanted to make
sure that I -- I knew I was trying out again, and I wanted to
make sure that I stayed in shape.
It was very hard to get to where I was, and I didn't want
to go backwards.
Q.
And, on top of your work schedule and your demands as a
parent and all that, was the SWAT training a real drain on your
leftover personal time?
A.
Yes, absolutely. In between, you know, dropping the kids
off at school, picking them up, taking them to their
appointments, it was just convenient.
Q.
And, was that a factor in why you continued to use
Mr. St. Louis at that time to handle your tax affairs?
A.
Yes. He had all my paperwork already. It is not like I
had to go to a new tax guy and fill out new paperwork and
documents and give my kid's social again, find their birth
certificates, do any of that. He just had all my stuff. So, I
just went and, you know, he always handled it for me.
Q.
All right. Let's get to the heart of the matter.
Did you have any reason at all to think that he was going
to lie on your behalf?
A.
I never would have thought he would have ever lied,
especially the way that he did. And, I never would have
allowed it, ever. I worked way too hard in my career to get to
where I am at right now, for a 20 thousand dollars loan. I
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never would have allowed that, ever.
Q.
And, when he said he was going to prepare the applications,
did you think he was going to use truthful numbers?
A.
Yes. He said I qualified. Why would I have a reason not
to believe him?
Of course, I am going to believe him.
He said I qualified. He said I was a realtor, I had a
1099, and I didn't need employees. And then, in the loan
process and the forgiveness process, I was seeing emails saying
that employees with -- or people qualified for PPP loans, no
employees, with 1099s, that were realtors. So, it is just
substantiating what he is saying.
Q.
Are you talking about market advertisements to apply for a
PPP loan?
A.
Yes.
Q.
And, you received those marketing advertisements when,
exactly?
A.
It is between -- sometime between when I got the loan and
then sometime between the forgiveness.
And, I also see, you know, there was people getting
stimulus money for everything. So, it made sense to me that he
was -- that COVID was giving PPP loans for businesses.
Q.
And, of course, let's go back in that time machine for a
moment. We are here in 2021, right, in these events; correct?
A.
Yes.
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Q.
And, at that time, COVID was raging, right?
A.
Yes.
Q.
What was going on at that time in this country because of
COVID?
A.
Well, I worked at the airport. The airport was empty. It
was nobody flying. I had less details, to be honest. But,
yeah, there was people not going to the grocery stores, you
weren't going out to dinner like you normally go, things like
that.
Q.
It was that crazy time during coronavirus, right?
A.
Yes.
Q.
Now, let's talk about your forgiveness application. Did
you participate in the filling out of the forgiveness
application?
A.
No.
Q.
Did you have any knowledge of information he put on that
application?
A.
No.
Q.
Did you participate in any part of filling out the initial
loan application?
A.
No.
Q.
And, did you have any knowledge of the numbers he put in
that loan application?
A.
No.
Q.
And, just like with the loan application, had you known
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that he was going to flub numbers, and put fake numbers to
guarantee that you got your loan forgiven, would you have
authorized that?
A.
No, absolutely. I would have never allowed that, ever.
Q.
Okay. There is an email that the Government put in, where
you told him to please not mention this to your wife. Right?
Do you know what I am talking about?
A.
Yes.
Q.
Okay. You said, please don't mention it to Erin, about the
audit or the loan; correct?
A.
Correct.
Q.
Okay. What did you mean in that email?
What were you trying to tell him?
A.
Well for one, my wife overreacts to a lot of things, and I
didn't want to stress her out. So, I didn't want to mention --
our finances are separate. We keep our finances separate. She
doesn't have to know when I buy Red Bull at the grocery store,
and I don't know when she goes to get her nails done. So, I
just didn't want her to know. It is one less argument that we
have to fight about when we are home.
Q.
And, of course, you come together to pay for mutual
household expense; correct?
A.
Absolutely, all our bills are paid.
Q.
The kids, food, all that?
A.
Yes. Absolutely.
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Q.
When did you first see the SBA loan application that he
filled out with those fake numbers?
A.
After I was suspended from work.
Q.
Okay. And that -- what year was that?
A.
2023.
Q.
Like, a couple of years later, right?
A.
Yes.
Q.
Okay. And that is long after this investigation had
started, and that whole thing, right?
A.
Correct.
Q.
When was the first time you saw the forgiveness
application?
A.
I believe that was after I was arrested.
Q.
Okay. And, when you saw the numbers that he had put in
that loan application and in the forgiveness application, did
you ever attempt to make contact with him about that?
A.
Yes. When I knew I was in trouble, we had heard it was
something to do with PPP, but I knew I had my paperwork, I
never thought -- I still didn't think I did anything wrong. I
knew I had paperwork. According to him, everything was -- I
qualified, and everything was "legit."
So, I e-mailed him and asked him, "Hey, where did you get
these numbers from?"
Q.
And did he respond?
A.
He never responded after that. I never heard from him
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again.
Q.
After this email, he ghosted you?
A.
Yes.
Q.
Now. Since you learned that he committed this fraud on
your behalf, did you take any corrective action?
A.
Yes, I did.
Q.
What did you do?
A.
Since the day I was arrested, I know I told you to convey
to Mr. Jones that I wanted to pay back the loan that I wasn't
entitled to, and I have since paid it back in full with
interest and penalties.
Q.
Do you owe any money to the IRS at all?
A.
No.
Q.
I am sorry, I mean to the SBA or anything?
A.
No.
Q.
It has been fully paid?
A.
Yes.
Q.
And, do you acknowledge here today some of things we
discussed in our opening statement?
Let's go through them. You don't deny a loan was applied
for, right?
A.
No.
Q.
You don't deny that a forgiveness application was applied
for?
A.
No.
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Q.
You don't deny that the loan was approved?
A.
No.
Q.
You don't deny that the money was given to you?
A.
No.
Q.
And, you don't deny, based on him telling you that the
money could be spent on other things, that you spent it on
personal things?
A.
No.
Q.
What do you -- what, in fact, is it that you do deny?
A.
I have no idea it was fraudulent numbers. I had no idea he
made it up. I had -- I always thought I had a 1099, and I made
money. I made $13,000 in 2019. The year before, I made
$23,000. The year before, I made, I think, $30,000. I had
a -- I was actively working in a business. And, I never had
any reason to believe I didn't qualify.
Q.
It is not as if you weren't a real estate agent, and he was
going to tell you that realtors can get this, so you could
apply for it, correct?
A.
Correct.
Q.
And, it is not like you made no money as a realtor, right?
A.
Correct.
MR. SILBER: Counsel, I am going to show her these
exhibits.
All right. I am showing what I have previously marked
as Defense Exhibit 32 through 33. It is a composite document
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for identification purposes.
Government, any objection to the admission of this
document?
MR. JONES: Sorry, your Honor. No objection.
MR. SILBER: Thank you.
THE COURT: So what, 32 and 33?
MR. SILBER: Through 33, yes.
Your Honor, at this time, I would move to admit
defendant's Exhibits 32 and 33 as Defense A.
THE COURT: Okay.
(Exhibit No. A was marked for Identification.)
THE COURT: All right. I said you could leave it as
32, or whatever. So, that's Exhibit A.
BY MR. SILBER:
Q.
Okay.
I am going to go through these documents, and then we will
talk about them. I am now showing you what was previously
marked as Defense Exhibit 21 through 23 for identification.
Government, any objection?
MR. JONES: No objection.
MR. SILBER: Your Honor, at this time, I would move to
admit Defense Exhibit 21 through 23 as defense B.
THE COURT: And what is it?
Just generally, the description.
MR. SILBER: 21 through 23, it is an email.
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THE COURT: Gmail login report?
Is that consistent with what is on your exhibit list?
MR. SILBER: Sorry, I didn't hear you.
THE COURT: Is it consistent with what is on your
exhibit list?
MR. SILBER: It should be. But, it doesn't mean I
didn't make a mistake.
THE COURT: Here, it says 21-23 is 4-21-21 email re:
G-mail login info.
MR. SILBER: It shouldn't be gmail. It is April 21,
2021 email.
THE COURT: So, that will be what, B?
MR. SILBER: B.
THE COURT: Okay.
MR. SILBER: Let me just mark it as Defendant's B.
(Defendant's Exhibit B was received in Evidence.)
MR. SILBER: And this is defense 19 through 20.
Government, any objection?
MR. JONES: No objection.
MR. SILBER: At this time, I would, move to admit
Defense 19 through 20 for identification into evidence as
Defense C.
THE COURT: Okay.
(Defendant's Exhibit C was received in Evidence.)
MR. SILBER: And this one is Defendant's 27 through 31
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for identification purposes.
Actually, one second. Let me double check that.
This is defense 27 through 31 for identification
purposes.
Any objection?
MR. JONES: No objection.
MR. SILBER: Your Honor, I move to admit Defense
Exhibit 27 through 31 as Defense D, delta.
THE COURT: Those are emails, or what is it?
MR. SILBER: It is an email from October 10th and
October 9th.
THE COURT: 9th?
MR. SILBER: Yes, and October 10th.
THE COURT: Okay. Those are in as D.
MR. SILBER: Yes, delta.
(Defendant's Exhibit D was received in Evidence.)
BY MR. SILBER:
Q.
All right. I am now showing you what has been admitted as
defense A. Do you recognize this document?
A.
Yes.
Q.
What is this?
A.
It is my certificate of my indebtedness to the SBA.
Q.
Okay. And what is the date on here?
A.
May 30, 2024.
Q.
Okay. And here is your loan number, right?
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A.
Yes.
Q.
1554728404, right?
A.
Yes.
Q.
Cross River Bank -- do you remember the lady with the
purple hair, right?
A.
Yes.
Q.
You're the borrower, Alexandra Acosta; that is your
address, 7200 Northwest 9th Way, Tamarac, right?
A.
Yes.
Q.
Okay. Loan for $20,180?
A.
Yes.
Q.
Okay. That was the forgiveness, the 2,180, right?
A.
Yes.
Q.
And now, let's go down here. You then owed interest on the
forgiveness, a PPP processing fee, and less your wire payment
of 22,750.77. Right?
A.
Yes.
Q.
Okay. This 22,750, does that represent the total of the
20,180 in interest and the $2,500 processing fee?
A.
Yes, it does.
Q.
And does this represent all the penalties, interest, and
whatever they asked you to pay?
A.
Yes.
Q.
And including the entire principal?
A.
Yes.
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Q.
And, that comes to the 22,750.77?
A.
Yes.
Q.
And, that was paid?
A.
Yes, completely.
Q.
Okay. And your total indebtedness now is?
A.
Zero.
Q.
I am now showing you what was previously admitted as
Defense C.
Let me zoom out just a little.
All right. Do you recognize this?
A.
Yes.
Q.
All right. Let me show you the next one.
Do you recognize -- first, let me take note here. Do you
see the date on here?
What does that say?
A.
March 23, 2021.
Q.
Okay. That is the 23rd. What does this one say?
A.
March 30, 2021.
Q.
Okay. And what does this one say?
A.
March 20, 2021.
Q.
Can you read that again?
A.
I mean, sorry. April 20, 2021.
Q.
Okay. And just to note, is that date significant to you,
April 20, 2021?
A.
It was the day before the loan forgiveness was applied for.
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Q.
Okay. Let's go through these real quick to see what it
says.
All right.
Q.
What is the title?
A.
Forgivable PPP Funds Available for 1099s Without Employees.
Q.
So, someone like you doesn't have employees, right?
A.
No.
Q.
And you had a 1099, right?
A.
Yes.
Q.
Okay. Read this for us.
A.
"Did you know new changes are allowing independent
contractors with no employees to qualify for the PPP forgivable
loan, and you could qualify for up to $20,833?"
Q.
Keep going.
A.
"New changes to the PPP loan program are allowing 1099
contractors, real estate agents unique access to forgivable PPP
loans. Join us on Wednesday, March 24 at 5:00 P.M. for a live
informational session with an SBA-approved lender to discuss
funds specifically allocated for 1099 contractors with no
employees. Please note, the window of funds is set for close
on March 31st, unless extended by the Government."
Q.
Okay. Let's look at this one. We don't have to read the
whole thing. But, is this materially the same?
A.
Yes.
Q.
Okay. "Forgivable PPP loan for real estate agents and 1099
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contractors, right?
A.
Yes.
Q.
"New changes to the program allowing 1099 contractors, real
estate agents," right, and all this is the same, basically?
A.
Yes.
Q.
Okay. And, they had that webinar with the SBA-approved
lender?
A.
Yes.
Q.
Right. Okay. Now, this one is similar. But, there are
some differences, right?
A.
Yes.
Q.
"Forgivable PPP loans for real estate agents"?
A.
Yes.
Q.
And, read this paragraph to us.
A.
"New changes are allowing realtors and independent
contractors with no employees to qualify for the PPP forgivable
loan, and you could qualify for two loans for up to $20,833 per
loan."
Q.
Two loans?
A.
Yes.
Q.
So, someone, conceivably, in these conditions like you, who
is a real estate agent or a 1099 holder can potentially qualify
for two loans of $20,000?
A.
Yes.
Q.
About $42,000, right?
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A.
Yes.
Q.
And the rest of it is the same as you read before; correct?
A.
It appears so.
Q.
Okay. And, to clarify, I think you told us before that you
received these emails during -- in between the time your
application was first applied for, but before the forgiveness
was sent, right?
A.
Yes.
Q.
Okay. And, what is the significance of these to you?
What did this inform you?
A.
It was just telling me everything my tax preparer had told
me. It was as a realtor, I had a 1099, no employees, and then
I qualified for a PPP loan.
Q.
Is it fair to say that it confirmed what you already
believed, based on what he told you?
A.
Yes.
Q.
Certainly, it didn't give you reason to question him,
right?
A.
No, it made -- substantiated what he was telling me.
Q.
I forgot to show you one other document.
We are referencing the repayment of the loan.
A.
Yes.
Q.
This is the second page of Defense A. I am sorry I didn't
show this to you before.
It is kind of blurry. Do you recognize this document?
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A.
Yes.
Q.
Space Coast Credit Union?
A.
Yes.
Q.
Okay. What is this document?
A.
That is the printout they gave me after I wired the money
to the SBA.
Q.
When you say, "they," who were you referring to?
A.
Space Coast Credit Union.
Q.
Okay. And this is how you made the payment to the bank to
pay for the SBA money?
A.
Yes.
Q.
Okay. And just to go over a couple of things here,
22,750.77?
A.
Yes.
Q.
And that corresponds to here, 22,750.77?
A.
Yes.
Q.
Okay. And, entered May 20, 2024, 12:31 P.M.?
A.
Yes.
Q.
Effective date, May 20th?
A.
Yes.
Q.
So, basically, this is, for lack of a better term, the
receipt you got for wiring the money to the SBA to pay for the
loan, right?
A.
Correct.
Q.
Okay. All right. Sorry, we had to go back there.
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All right. I am now showing you Defense Exhibit D. I
am going to reverse the order. Now, actually, I will put these
out both like this.
Q.
Do you recognize this document?
A.
Yes.
Q.
Okay. What is this?
A.
The loan application.
Q.
Okay. Is that the actual application, or a screen shot?
A.
No, that is an email I sent to St. Louis of a screen shot
of the application.
Q.
Okay. And what date did you send this email?
A.
I believe it was on October 9th.
Q.
October 9th. Okay.
And, what is the significance of this circle in here?
THE COURT: Wait, October 9th, 2023?
BY MR. SILBER:
Q.
Sorry.
A.
Yes, 2023.
MR. SILBER: Thank you, your Honor.
THE WITNESS: The significance is I had no idea where
that number came from, and I knew somebody was going to ask me
where did these numbers come from. So, I circled it and asked
him so that I could explain it at a later date.
Q.
Okay. And, what was going on at that time, that prompted
you to send this email?
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A.
I was suspended from the Sheriff's Office, and I had heard
that it was related to these PPP loans.
Q.
Okay. And, were you suspended with or without pay?
A.
At the time, I was suspended with pay.
Q.
Okay. And afterwards?
A.
Afterwards, I was suspended without pay.
Q.
What about your health insurance, things like that?
A.
No, I don't have -- I don't have health insurance through
the Broward Sheriff's Office.
Q.
Okay. And what does it say here in the green highlight?
Let me zoom in. Hold on.
What does that say?
A.
"Can you tell me where this number came from?"
Q.
And is that you asking St. Louis?
A.
Yes.
Q.
And is this the email you were referencing earlier when you
said he ghosted you afterwards?
A.
Yes.
THE COURT: Was it highlighted like that, in green,
when you sent it to him?
THE WITNESS: No. It wasn't highlighted like that in
green.
MR. SILBER: Okay. Good question, your Honor. Let me
just clarify.
BY MR. SILBER:
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Q.
This black circle -- was that there in your email?
A.
Yes.
Q.
Okay. And, who put this here, this green?
A.
I don't know.
Q.
Okay. Is it a highlighter?
A.
Yes.
Q.
Okay.
THE COURT: And, he never responded to that?
THE WITNESS: No.
BY MR. SILBER:
Q.
I am now showing you Defense Exhibit B that was admitted.
Do you see there?
A.
Yes.
Q.
Okay. It says, "photo" -- it looks like an iPhone screen
shot.
Do you see the second page?
A.
Yes.
Q.
Okay. What is the date on there?
Let me zoom in. I am sorry.
A.
It says, "April 21, 2021."
Q.
Okay. And what is the significance of these screen shots
here? What are we looking at?
A.
There is two different times that he screen shotted the
confirmation of forgiveness application, but one is a screen
shot he sent me as a text message, which is that first one, and
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the second one is an email that he sent me.
Q.
Okay. So, is this the screen shot of the text message?
A.
Yes.
Q.
Okay. And that is -- up here, we see the iPhone stuff.
This portion here is the email, right?
A.
Yes.
Q.
Okay.
THE COURT: But, when he sent you the text and email,
he just sent you a picture of that one little part saying, that
is the amount of money that is being applied for?
THE WITNESS: He -- it is in two pages there, but yes.
He sent it.
THE COURT: Did he ever send you the full application?
THE WITNESS: No, sir. He just sent me that screen
shot saying that my forgiveness application was completed.
BY MR. SILBER:
Q.
And, the significance of that is that he did it on your
behalf, and this was him telling you it was taken care of?
A.
Correct.
Q.
Can I have a moment, your Honor?
THE COURT: You may.
BY MR. SILBER:
Q.
Is there anything else that I didn't cover that you wish to
add?
A.
I just want to say I'm really sorry that everybody is here
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because of this. I never meant to take that money out if I
knew I didn't qualify. I have prided myself on being a good,
honest person my whole career, and I have an exemplary record
at the Sheriff's Office.
And, I would have never, ever been okay with somebody
saying I had made $103,000 when I clearly never made anything
close to that.
I am so sorry that you are here away from your families. I
am sorry I put my family through this. I am so sorry to put my
team, my kids -- this is just -- I am -- I am so sorry I
trusted him. I didn't -- if I did anything wrong, it was
trusting him because I never intended to lie on those
applications, and I never filled any of it out.
BY MR. SILBER:
Q.
So, would you have ever, for one second, let him do this?
A.
No. I -- like I said, I pride myself on being an honest
person. And, I know that sometimes, I just like convenience.
You know, he said he would handle it for me. So, I let him
handle it. And, maybe I should have looked into it further.
But, I never would have thought, I never had any reason not to
trust him, ever.
Q.
And is it fair to say you acted in good faith?
A.
Yes.
Q.
Based on things he told you?
A.
Yes.
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Q.
And, on the relationship of trust that he had with you as
tax preparer and customer?
A.
Yes. Even when he messed up on the audit, he admitted that
-- he admitted it was his mistake. I had no reason not to
trust him.
MR. SILBER: I have nothing further at this time.
THE COURT: All right cross-examination?
CROSS-EXAMINATION
BY MR. JONES:
Q.
Ms. Acosta?
A.
Yes, sir.
Q.
You mentioned you began -- you started your college career
at Manatee, Sarasota?
A.
No, sir.
Q.
Where did you start your career?
A.
Atlanta University.
Q.
And then you transferred to?
A.
Manatee College.
Q.
And then you ultimately graduated from Valdosta State
University?
A.
Yes, sir.
Q.
And that was with a Bachelor of Arts in 2008?
A.
Yes, sir.
Q.
You testified you majored in Criminal Justice?
A.
Yes.
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Q.
And you earned an A in Introduction to Criminal Justice,
does that sound right?
A.
Yes.
Q.
You earned an A in Criminal Law and Procedure, does that
sound right?
A.
Yes.
Q.
You earned an A in Criminal Law, does that sound right?
A.
Yes.
Q.
And you earned an A in Criminology, does that sound right?
A.
Yes.
Q.
You earned an A in Forensic Criminology?
A.
Yes.
Q.
You earned an A in White Collar Crime?
A.
Yes.
Q.
You earned an A in Crime Prevention through Environmental
Design?
A.
Yes.
Q.
You earned an A in Cyber Crime?
A.
Yes.
Q.
And just looking through your transcripts, do you dispute
you are an A student in this field?
A.
In Criminal Justice, yes.
Q.
Now, you started working at BSO in June 2013?
A.
Yes.
Q.
You had to go through training at the police academy before
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joining BSO; correct?
A.
Yes.
Q.
You were trained to prevent and detect criminal
investigations?
A.
Yes. Of --
Q.
Sorry?
A.
Criminal violations.
Q.
Criminal violations, I apologize.
A.
Yes.
Q.
You were first assigned to the West Park District, as you
testified?
A.
Yes.
Q.
And then in September 2, 2017, you transferred to the Fort
Lauderdale International Airport?
A.
Yes.
Q.
That is the ICT unit?
A.
Yes.
Q.
And, you had special access to the airport?
A.
Yes.
Q.
You are familiar with all the laws in force at the airport?
A.
Yes.
Q.
Did you work among customs and border patrol officers at
the airport?
A.
Yes.
Q.
Are you generally familiar with the laws that they
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enforced?
A.
They had different laws than us. But, for the most part,
yes.
Q.
Would you see postings about what people can and can't do
in the airport?
A.
Yes.
Q.
Now, your most recent position was with the SWAT team;
correct?
A.
Yes.
Q.
That is special weapons and tactics?
A.
Yes.
Q.
It is a special unit?
A.
Yes.
Q.
They have extra requirements to join that unit?
A.
Yes.
Q.
Special physical requirements that you testified about?
A.
Absolutely.
Q.
But, you also have to have an elevated sense of situational
awareness; correct?
A.
There was no test or anything for situational awareness.
It was a test for physical ability, yes.
Q.
There was no requirement that you had to have some sort of
mental acuity?
A.
It was not a test on that, no, sir.
Q.
As a SWAT team member, do you have to quickly respond and
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evaluate situations?
A.
Yes.
Q.
Do you have to be disciplined mentally and physically?
A.
Yes.
Q.
And that is probably more so than other BSO officers, is
that fair to say?
A.
Depending on the situation, yes.
Q.
But you're a special unit?
A.
Yes. There are different units assigned to different
things at the -- with different specialties in the department,
yes.
Q.
You testified that you graduated at the top of your class?
A.
Yes.
Q.
And, you don't dispute that you're an exceptional police
officer, as far as training is concerned?
A.
No.
Q.
And, during your time as a BSO deputy, have you testified
in trial before?
A.
Once.
Q.
And, have you testified in any other matters?
A.
Some traffic tickets.
Q.
Anything personal?
A.
Yes.
Q.
How many times?
A.
Once or twice.
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Q.
So, you have been sworn in to testify before?
A.
Yes.
Q.
Just like you were today?
A.
Yes.
Q.
And, you understand that when you testify, you are asked to
tell the truth, you are asked to tell the whole truth?
A.
Yes.
Q.
Nothing but the truth?
A.
Yes.
Q.
Do you understand this distinction between the whole truth
and just telling the truth?
A.
Yes.
Q.
Do you understand that that means omissions?
A.
Yes.
Q.
You testified that you started with BSO in June 2013. And
that was your first law enforcement job; correct?
A.
Correct.
Q.
You also had filed, just you -- you filed a tax return for
the 2012 year, is that accurate?
A.
Yes.
Q.
St. Louis did that tax return for you, didn't he?
A.
Yes.
Q.
You knew St. Louis before you worked at BSO?
A.
Yes.
Q.
St. Louis knew you before you were in law enforcement?
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A.
Yes.
Q.
Over the years, you have obtained his personal number?
A.
Yes.
Q.
You had his business number?
A.
Yes.
Q.
You e-mailed him at VictoryTaxes@gmail.com?
A.
Yes.
Q.
And then you used text messages to contact him?
A.
Yes.
Q.
Is it true his office was about 15 minutes from the
airport, in a drive?
A.
Yes.
Q.
Did you introduce your wife to Mr. St. Louis, to do her
taxes too; correct?
A.
Correct.
Q.
And, you referred multiple people to him for taxes?
A.
Yes.
Q.
Over five people?
A.
Probably about that.
Q.
And, he doesn't charge you sometimes for his tax
preparation, does he?
A.
Correct.
Q.
Is that because you gave him referrals in return?
A.
Yes.
Q.
Is that a give and take?
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A.
I would believe so.
Q.
Are you familiar with the Latin term, quid pro quo?
A.
No.
Q.
But, would it surprise you that it means "this for that"?
A.
No.
Q.
Is it fair to say that Mr. St. Louis is a longtime
associate of yours?
A.
Define "associate."
Q.
Well, let's talk about a meeting. Do you recall a time
after you were charged where you had an opportunity to come
speak at the U.S. Attorney's Office?
A.
Yes.
Q.
Do you recall that at that time, we agreed to meet with
you?
A.
Yes, yes.
Q.
And, you came in?
A.
Yes.
Q.
And, you sat down across from me?
A.
Yes.
Q.
And you sat down across from Special Agent Tonya Johnson?
A.
Yes.
Q.
Your attorney was present?
A.
Yes.
Q.
And, your attorney gave a -- well, let's talk about at the
beginning of that, that meeting. We discussed the importance
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of telling the truth and the whole truth?
A.
Yes.
Q.
We talked to you about the fact that this was an
opportunity for you to tell us everything that you knew about
this case?
A.
Yes.
Q.
And, in the beginning, your attorney made a statement that
you adopted. Do you recall that?
A.
I don't remember the statement exactly, but I remember him
making a statement at the beginning.
Q.
Would it surprise you that he identified Mr. St. Louis as a
longtime associate of yours during that statement?
A.
Longtime business tax preparer, yes.
Q.
In advance of that meeting, did you have an opportunity to
view all of the discovery that had been produced to that date?
A.
I don't recall.
Q.
You don't recall meeting at the U.S. Attorney's Office,
preparing to meet at the U.S. Attorney's Office about this
case?
A.
That, I recall. I don't remember any discovery, evidence
or anything.
Q.
You didn't prepare for the interview?
A.
Other than knowing what had happened, no.
Q.
How many times have you been indicted in your life?
A.
Once.
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Q.
How many times have you met with the U.S. Attorney's Office
to discuss an indictment?
A.
Once.
Q.
You can't remember whether you reviewed the records that we
were charging you, based on --
A.
Like, the paperwork?
Q.
Yes.
A.
The documents?
Q.
Yes.
A.
The materials? Yes.
Q.
You reviewed them?
A.
Yes.
Q.
You reviewed the IRS records that were produced at that
point; correct?
A.
What IRS records?
Q.
The tax return information, everything that was produced in
discovery.
A.
That, I had nothing to do with -- that had nothing to do
with the -- with PPP.
Q.
The question is did you review the tax records that were
produced in discovery?
THE COURT: Prior to meeting with you?
MR. JONES: Prior to the meeting.
THE COURT: In preparation of the meeting?
MR. JONES: In preparation of the meeting.
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Sorry, your Honor.
THE WITNESS: Not that I recall.
BY MR. JONES:
Q.
You only -- you went in with loose knowledge of all the
supporting facts related to this very important case?
A.
I reviewed the PPP information.
Q.
Would it surprise you that there was the 2018, 2019, and
2020 tax returns that were discussed today, Government's
Exhibits 200 through 201, that were included in that discovery
file?
A.
Yes.
Q.
It would surprise you, or it wouldn't surprise you?
A.
It would surprise me.
Q.
When you came in that day, and you had an opportunity to
speak with us, and you asked -- we asked you what we needed to
know about Mr. St. Louis; correct?
A.
Correct.
Q.
Well, you brought him up, as well. You have had
effectively close to the testimony that you talked about today,
except one thing. Do you know what that thing is?
A.
No.
Q.
Is it that you didn't tell us anything, not even -- not a
single statement or "Hey, by the way," or, guess what, that
during this same period, you and Mr. St. Louis, your
codefendant now, were being audited by the IRS, and had met
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with the IRS on the phone the same day that the application was
created? Was that not relevant?
A.
No, it was completely separate. Even in the email with my
-- that I explained with my wife, it says "or" not "and." They
were not two -- singular things to me, they were completely
separate issues.
Q.
Well, we are going to go back in that proffer, and we will
talk about that, as well. If you want to go to email, I am --
we will talk about the email now, too.
You're characterizing these things as separate.
A.
Yes. To me, they were separate.
Q.
Distinct.
A.
Yes.
Q.
Tax case, PPP loan. No relation.
A.
I had no reason to believe that they were together. He
always minimized the loan, and to me, it was never a big deal.
Q.
The same -- you received a letter from the IRS on
approximately January 25, 2021; correct?
A.
It sounds about right.
Q.
Seven days later, you were sitting with Mr. St. Louis
speaking to the IRS about $18,000 in tax liabilities; correct?
A.
Correct.
Q.
And, like manna from heaven, a 20,000 PPP loan is offered
to you at that moment. Boom. That is what happened?
A.
He always made it seem like the audit was going to be very
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minimal, and he gave me all the reasons that supported why I
qualified for the loan. I didn't have any reason to distrust
his honesty.
Q.
You didn't have any reason to distrust the person who
purportedly had submitted a bunch of fake numbers to the IRS
for two different tax years for you, without your knowledge?
A.
I had no idea those numbers were fake, according to that
conversation we had on the first. He was actually agreeing
that he made a mistake. So, I believed his honesty.
Q.
Mr. St. Louis mentioned that he double-reported one
specific thing. That did not substantiate the rest of these
issues; correct?
A.
Correct. I know that now.
Q.
You knew it then, didn't you?
It was in -- the changed report. It stated the exact
numbers that the IRS had deemed were unsupported, correct?
A.
Yes. But, like I said, I don't really understand any of
the IRS stuff. And, to me, when he admitted his mistakes, it
was like I felt he was being honest about what happened on the
loan, or on the audit.
THE COURT: All right. It is past 5:30. Let's take
our evening recess, and we will come back at 9:00 o'clock.
I don't have any other matters except for this trial.
So, we should start promptly at 9:00 o'clock.
So, have a safe trip home and back, and we will see all
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the jurors at 9:00 o'clock.
COURT SECURITY OFFICER: All rise.
[Whereupon, the jury left the courtroom at 5:35 p.m.,
and the following proceedings were had:]
THE COURT: Thank you, Ms. Acosta. You can go back to
your counsel table for our next discussion.
We are here outside the presence of the jurors, but
everybody else is here.
Let's just talk about scheduling a little bit. I think
we should all get together at 8:30 to go over the jury
instructions. I don't know if it is going to be the final
version, but if there are still some things in dispute, I think
we can talk about that.
Do you have any other witness, other than your client?
MR. SILBER: I expect not. But, I don't want to give
you a final answer until tomorrow, if that's possible.
THE COURT: And were you going to have any other
witnesses?
MR. SILBER: Depends on -- are you talking to the
Government?
THE COURT: The Government.
MR. JONES: I will reiterate the statement for
rebuttal, based on what the defendant is testifying to,
perhaps.
THE COURT: Well, she has already testified to
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everything. So, based on as of now, do you anticipate --
MR. JONES: As of now, I don't believe we will be
calling anybody else.
THE COURT: So, we are probably going to get to closing
arguments tomorrow.
MR. JONES: To be clear, your Honor, sorry, we have not
testified yet about the factual proffer, where I do have
witnesses for factual proffer. So, I don't know where we are
going to go with that, and that could require rebuttal.
THE COURT: What do you mean, the factual proffer?
MR. JONES: When she came into the U.S. Attorney's
office and spoke with us. There were witnesses there. To the
extent she challenges anything that was heard --
THE COURT: Okay. But, I think you just -- I mean, you
want -- I don't know what she said, because you guys have not
been through it. But, you said in front of the jury that
whatever she just said to the jury is the same thing she told
you, except about the audit.
MR. JONES: It is close, yes.
THE COURT: So, I don't know if that was a spoiler
alert that you should have given us -- but so, in any event, we
are all going to be here at 8:30 to go over the jury
instructions, and we will go forward at 9:00 o'clock with the
jury.
Okay. Have a good evening.
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1MR. SILBER: Thank you, your Honor.
MR. JONES: Thank you.
(Proceedings adjourned at 5:37 p.m.)
_ _ _
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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.
November 18, 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
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$
$0.65 [1] - 77:7
$1,071 [1] - 76:23
$1,240 [1] - 122:1
$1,288 [1] - 42:21
$1,400 [1] - 149:5
$10,000 [19] -
122:22, 125:4, 125:7,
125:12, 125:14,
127:7, 129:7, 131:3,
169:3, 169:7, 169:10,
169:20, 169:21,
170:1, 170:24,
171:23, 177:12,
177:13, 177:14
$103,000 [3] -
176:22, 176:24, 235:6
$103,255 [2] - 116:1,
116:17
$103,819 [2] - 36:23,
86:22
$104 [1] - 68:23
$11,614 [1] - 45:9
$12,675.55 [1] - 69:2
$13,000 [1] - 221:12
$13,900 [2] - 91:11,
176:19
$13,904 [2] - 42:17,
115:23
$138,904 [1] - 116:14
$14,000 [1] - 77:9
$18,000 [4] - 126:16,
185:20, 209:10,
247:21
$18,500 [1] - 69:7
$19,000 [15] -
125:10, 126:15,
127:11, 129:6, 129:8,
167:12, 168:19,
168:25, 170:8,
170:21, 171:6, 171:9,
171:21, 171:23, 172:1
$2,356 [1] - 45:9
$2,500 [1] - 225:19
$2,863 [1] - 42:23
$20,000 [4] - 120:15,
120:23, 121:2, 228:23
$20,180 [5] - 120:7,
120:14, 146:24,
168:12, 225:10
$20,833 [2] - 227:13,
228:17
$21,000 [1] - 185:22
$23,000 [1] - 221:13
$23,523 [2] - 43:1,
116:23
$23,596 [1] - 45:3
$25,772 [2] - 44:9,
45:11
$26,651 [1] - 37:7
$284 [1] - 159:8
$3,000 [1] - 149:25
$3,482 [1] - 45:7
$3.29 [1] - 130:17
$30,000 [1] - 221:13
$34,571 [1] - 97:10
$4,169.04 [1] - 77:8
$417.93 [1] - 128:8
$42,000 [1] - 228:25
$49,368 [1] - 45:10
$5,816 [1] - 69:4
$5,948 [1] - 42:22
$503 [1] - 42:22
$52.80 [1] - 128:6
$529.41 [1] - 128:10
$6,389 [2] - 42:22,
116:20
$6,532 [1] - 42:24
$6,702 [1] - 45:23
$67,549 [1] - 37:10
$7,279.10 [1] - 135:6
$7,445 [1] - 45:8
$7,455 [1] - 45:7
$7,485.09 [1] -
128:12
$7,666 [1] - 37:19
$7,998.05 [1] -
130:17
$8,014.50 [1] -
128:14
$8,072 [1] - 146:23
$8,147 [2] - 45:8,
97:24
$8,869 [1] - 45:6
$840 [1] - 121:6
$88,869.55 [1] - 77:7
$9,000 [2] - 122:16,
127:8
$9,042 [1] - 76:21
$9,214 [1] - 97:7
$9,619 [3] - 37:1,
43:4, 43:6
$9,733 [1] - 68:9
$900 [3] - 122:12,
122:14, 122:15
$98 [1] - 90:11
$991.30 [1] - 129:16
$995.95 [1] - 68:23
'
'12 [1] - 199:23
'14 [1] - 199:23
'19 [3] - 90:9, 90:10,
165:8
'22 [1] - 198:13
/
/s/Sharon [1] - 252:7
0
0 [1] - 48:11
0:23-cr-60170-RNS-
1 [1] - 1:2
1
1 [27] - 1:8, 10:2,
14:18, 15:7, 15:16,
16:1, 16:13, 16:19,
20:7, 36:21, 36:22,
36:25, 41:9, 44:4,
44:5, 44:6, 71:6,
71:18, 76:25, 79:5,
126:2, 134:17, 138:2,
139:7, 142:21, 146:8,
209:21
1,946 [1] - 68:17
1-19 [1] - 80:16
10 [5] - 124:19,
130:15, 130:25,
134:12, 173:17
10,000 [1] - 169:11
100 [5] - 107:19,
108:10, 108:15,
108:22, 175:9
101 [1] - 3:5
102 [2] - 107:20,
136:25
103 [1] - 2:15
1039 [1] - 164:17
1040 [7] - 35:2, 35:3,
36:14, 43:12, 46:8,
85:17, 176:22
1040s [1] - 33:22
1051 [1] - 157:2
1098 [1] - 56:14
1099 [18] - 35:16,
56:14, 114:12,
114:15, 115:3, 201:9,
210:15, 210:18,
211:19, 216:8,
221:11, 227:8,
227:15, 227:19,
227:25, 228:3,
228:22, 229:12
1099s [4] - 75:11,
115:1, 216:11, 227:5
10:01 [1] - 159:3
10:11 [2] - 137:4,
137:19
10:27 [1] - 152:14
10:40 [1] - 62:20
10:49 [1] - 153:8
10:55 [1] - 63:2
10th [7] - 126:18,
127:9, 130:12,
130:18, 131:9,
224:10, 224:13
11 [4] - 62:15, 69:20,
134:15
113 [1] - 3:6
118 [1] - 3:6
11:25:25 [1] - 133:24
11:44 [2] - 152:17,
152:19
11:56 [1] - 134:17
11B [1] - 37:8
11th [1] - 165:8
12 [2] - 44:7, 64:25
12-16 [1] - 94:9
12-17-2020 [1] -
56:10
12-23 [1] - 64:2
12-something [1] -
136:5
120 [2] - 72:22, 74:4
123 [1] - 3:7
12:02 [2] - 135:15,
136:10
12:05 [1] - 102:19
12:17 [1] - 150:22
12:28 [1] - 157:3
12:31 [1] - 230:17
12:53 [1] - 136:2
12:56 [2] - 142:25,
143:13
12:57 [2] - 142:25,
143:14
13 [4] - 54:21, 54:23,
65:9, 89:9
13,000 [1] - 187:4
133 [1] - 3:7
139 [1] - 121:24
13:12 [2] - 136:22,
137:16
13:13 [1] - 138:2
13:35 [1] - 139:7
13:55 [1] - 144:11
14 [3] - 3:3, 44:13,
128:2
140 [1] - 3:8
1400 [1] - 77:9
145 [1] - 3:8
147 [1] - 3:9
148 [1] - 3:9
149 [1] - 3:10
15 [10] - 41:20,
48:22, 62:15, 62:17,
65:6, 108:22, 130:1,
158:3, 187:21, 242:10
15-minute [1] - 158:2
15.74 [1] - 129:16
150 [1] - 107:23
1
150th [1] - 44:24
151 [1] - 3:10
154 [2] - 3:11, 107:23
1554728404 [1] -
225:2
15:30 [4] - 125:12,
126:6, 126:7, 127:3
15:33 [5] - 125:6,
126:25, 129:25,
130:2, 154:19
15:38 [2] - 129:19,
130:2
15:48 [1] - 155:8
15th [1] - 122:1
16 [7] - 10:12, 33:8,
128:23, 158:17,
159:3, 159:9, 170:20
160 [1] - 2:15
16th [3] - 53:8,
149:2, 157:22
17 [1] - 55:4
177 [1] - 2:15
17th [1] - 94:24
18 [9] - 38:16, 72:14,
89:24, 104:11,
135:12, 136:9, 141:6,
156:2, 252:7
180 [2] - 109:16,
110:25
19 [14] - 3:4, 66:3,
68:6, 68:7, 69:22,
76:20, 80:23, 119:24,
136:1, 141:6, 170:13,
173:17, 223:17,
223:21
19,000 [1] - 121:3
190 [1] - 2:17
1981 [1] - 180:22
19th [7] - 80:21,
80:22, 80:23, 152:13,
152:16, 152:19, 156:2
1:11:00 [1] - 137:19
1:12:00 [1] - 137:16
1:30 [2] - 102:17
1:32 [1] - 102:23
1:33 [1] - 152:8
1:35 [1] - 139:8
1C [1] - 98:9
1D [1] - 98:5
1E [1] - 97:17
1G [1] - 98:13
1MR [1] - 251:1
1st [27] - 73:11, 81:1,
100:22, 101:22,
112:17, 128:4,
132:11, 132:17,
133:24, 135:14,
135:24, 138:13,
141:1, 142:11,
142:16, 143:9,
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143:13, 150:8,
167:15, 167:17,
167:24, 168:1, 168:7,
185:12, 185:16,
213:24, 214:12
2
2 [5] - 43:2, 126:21,
142:20, 151:24,
238:13
2,180 [1] - 225:12
2,431 [1] - 130:16
2-6-6-4 [1] - 138:6
2-8-8-4 [1] - 138:7
20 [13] - 62:15,
137:15, 142:19,
153:8, 155:22, 157:1,
215:25, 223:17,
223:21, 226:20,
226:22, 226:24,
230:17
20,000 [1] - 247:23
20,180 [1] - 225:19
20-plus [1] - 6:4
200 [6] - 3:4, 35:22,
36:3, 43:8, 44:14,
246:9
200-4125 [1] - 156:10
2000 [1] - 44:24
2008 [1] - 236:22
201 [14] - 3:4, 36:4,
36:10, 37:11, 37:13,
40:22, 43:15, 48:22,
60:11, 60:15, 86:18,
93:4, 114:23, 246:9
2012 [3] - 61:19,
191:21, 241:19
2013 [7] - 10:5,
10:21, 23:7, 24:19,
192:10, 237:23,
241:15
2014 [2] - 199:23,
213:4
2014-42 [1] - 54:14
2015 [1] - 54:14
2016 [3] - 19:2, 20:5,
29:3
2017 [3] - 19:2,
20:15, 238:13
2018 [48] - 12:11,
19:2, 20:22, 34:17,
34:20, 34:24, 47:16,
48:8, 48:17, 49:8,
49:20, 51:11, 53:15,
57:2, 57:3, 57:19,
61:4, 62:5, 62:10,
63:10, 64:7, 64:11,
68:2, 68:16, 68:23,
69:1, 75:11, 75:19,
76:14, 76:20, 77:7,
79:8, 85:4, 87:1,
89:23, 95:4, 95:6,
96:3, 97:2, 97:24,
100:17, 104:14,
137:25, 138:5,
146:19, 149:25,
159:8, 246:7
2019 [60] - 12:13,
22:15, 34:20, 34:24,
36:15, 41:11, 42:16,
43:6, 43:13, 44:1,
44:25, 45:4, 45:13,
46:4, 47:16, 48:8,
48:17, 49:8, 49:20,
51:11, 53:15, 57:2,
60:14, 61:7, 64:7,
64:12, 68:2, 68:18,
68:23, 69:3, 75:12,
75:19, 76:14, 76:22,
77:7, 79:8, 86:16,
86:21, 91:10, 93:5,
93:17, 95:4, 96:3,
100:17, 114:24,
115:13, 116:6,
116:11, 138:13,
138:16, 138:18,
164:14, 165:7,
176:17, 176:18,
195:17, 210:20,
221:12, 246:7
202 [4] - 3:4, 35:22,
36:5, 46:6
2020 [50] - 12:15,
22:17, 34:18, 34:21,
39:23, 46:9, 46:19,
46:24, 47:22, 49:8,
52:15, 53:8, 53:19,
55:4, 58:10, 62:2,
63:23, 64:3, 64:4,
65:6, 94:4, 94:7,
94:24, 104:19, 105:5,
112:15, 112:16,
112:17, 113:6, 113:7,
121:20, 121:22,
125:2, 127:23,
133:25, 134:4, 134:6,
134:18, 134:22,
163:18, 195:17,
196:4, 197:25,
203:21, 209:25,
214:22, 246:8
2021 [100] - 12:15,
22:19, 24:19, 46:23,
46:24, 47:8, 54:21,
54:24, 64:25, 65:9,
66:3, 66:13, 67:1,
69:12, 69:20, 70:6,
70:11, 71:6, 71:18,
72:8, 72:14, 73:4,
73:11, 74:20, 75:5,
76:17, 79:5, 81:1,
88:11, 89:9, 100:22,
100:25, 103:24,
104:19, 109:3, 111:2,
112:17, 112:24,
119:11, 119:19,
119:24, 120:5, 125:3,
125:9, 126:6, 126:24,
128:4, 129:5, 129:15,
129:19, 130:8,
130:15, 130:25,
131:9, 132:11,
133:24, 134:17,
135:15, 138:2,
138:13, 139:7, 141:6,
145:18, 148:3, 149:2,
149:24, 150:8,
150:16, 150:22,
151:24, 152:1, 152:5,
152:13, 152:16,
153:8, 153:24,
154:19, 156:2,
157:22, 158:17,
159:3, 159:9, 199:20,
199:21, 209:8,
209:21, 209:25,
216:24, 223:11,
226:16, 226:18,
226:20, 226:22,
226:24, 233:20,
247:18
2022 [3] - 111:4,
198:12, 214:19
2023 [4] - 111:25,
219:5, 231:15, 231:18
2024 [6] - 1:5, 112:3,
199:20, 224:24,
230:17, 252:7
203 [5] - 50:1, 50:13,
50:14, 50:19, 50:24
203A [7] - 3:5, 50:13,
51:3, 51:4, 63:19,
78:6, 132:22
203A-H [1] - 3:5
203B [2] - 55:23,
55:25
203C [1] - 66:24
203D [3] - 67:15,
67:16, 96:22
203E [1] - 63:9
203F [7] - 58:7,
60:11, 60:21, 60:23,
93:10, 93:13, 93:21
203G [3] - 74:15,
95:21, 119:6
203H [2] - 76:9, 89:8
20th [7] - 135:6,
153:19, 156:24,
157:1, 157:3, 185:13,
230:19
21 [17] - 53:19,
66:13, 67:1, 76:17,
80:23, 112:15,
112:16, 113:6, 113:7,
134:22, 137:24,
152:5, 222:18,
222:22, 222:25,
223:10, 233:20
21-23 [1] - 223:8
2129 [1] - 144:25
21st [8] - 72:2, 80:20,
134:6, 154:16,
154:19, 155:8,
155:23, 185:13
22 [1] - 138:12
22,750 [1] - 225:18
22,750.77 [4] -
225:16, 226:1,
230:13, 230:15
222 [1] - 149:24
223 [2] - 3:17, 3:18
224 [1] - 3:18
225-pound [1] -
195:4
22nd [3] - 47:8, 70:6,
119:11
23 [13] - 2:10, 70:11,
73:4, 102:10, 119:23,
134:4, 139:2, 150:16,
150:22, 222:18,
222:22, 222:25,
226:16
23rd [2] - 64:2,
226:17
24 [1] - 227:17
24th [1] - 119:11
25 [3] - 69:12,
134:22, 247:18
25,772 [1] - 45:18
2501 [1] - 119:24
26 [1] - 104:10
27 [4] - 174:7,
223:25, 224:3, 224:8
28 [4] - 43:3, 128:4,
129:5, 153:24
28480 [1] - 138:7
2848s [1] - 54:15
28th [1] - 12:5
29 [4] - 64:4, 74:20,
75:5, 100:25
29th [3] - 58:10,
63:23, 73:13
2nd [5] - 143:25,
144:5, 144:9, 152:1,
152:9
3
3 [12] - 10:5, 17:7,
17:8, 23:7, 69:17,
2
109:3, 132:22,
144:23, 145:8,
145:18, 146:6, 192:10
3-1-2020 [1] - 15:14
3.16 [2] - 16:3, 21:19
3.16.1 [2] - 17:5, 17:6
30 [4] - 66:13,
194:19, 224:24,
226:18
300 [5] - 3:3, 7:18,
7:21, 8:17, 8:21
301 [7] - 3:3, 13:19,
14:2, 14:7, 14:11,
14:18, 15:21
302 [5] - 3:3, 14:3,
15:6, 15:7, 15:21
303 [8] - 3:3, 13:19,
14:4, 14:7, 15:15,
15:21, 16:1, 19:10
304 [6] - 3:4, 19:4,
19:10, 19:15, 19:19,
28:25
305 [9] - 2:5, 3:4,
19:4, 19:10, 19:16,
20:10, 28:25, 51:23,
140:20
305-494-9699 [1] -
156:2
306 [5] - 3:4, 19:4,
19:10, 19:17, 20:18
31 [7] - 5:18, 31:1,
31:11, 104:12,
223:25, 224:3, 224:8
316 [1] - 15:25
31st [3] - 12:3, 21:21,
227:21
32 [5] - 2:12, 221:25,
222:6, 222:9, 222:13
33 [4] - 221:25,
222:6, 222:7, 222:9
33028 [1] - 44:24
33128 [2] - 2:4,
252:10
33130 [1] - 1:18
33316 [1] - 1:22
33321 [2] - 42:8,
46:16
33321-3043 [2] -
51:19, 67:5
33394 [1] - 1:15
3498 [1] - 66:16
36 [1] - 3:4
360-page [1] -
118:19
38 [1] - 190:20
3:12 [1] - 158:5
3:30 [1] - 126:9
3:32 [1] - 158:9
3:58 [1] - 178:2
3rd [5] - 121:5,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 254 of
283
168:1, 168:9, 185:12,
185:13
4
4 [20] - 1:5, 18:7,
39:23, 40:21, 62:2,
63:9, 69:18, 72:12,
76:24, 93:5, 94:7,
126:6, 129:19, 130:5,
130:7, 148:3, 155:17,
187:9
4,071 [1] - 76:25
4,760 [1] - 68:10
4-21-21 [1] - 223:8
40 [2] - 195:7
400 [4] - 2:4, 115:20,
115:21, 252:9
401 [1] - 164:8
45 [1] - 17:15
4549 [11] - 66:15,
66:17, 67:17, 69:13,
71:4, 71:25, 72:17,
72:19, 73:6, 74:9
45B [1] - 21:24
46-3507588 [1] - 42:6
48 [2] - 42:24, 45:9
489 [1] - 50:25
489-page [2] - 50:1,
50:24
494-9699 [2] - 51:23,
140:20
4:00 [1] - 181:6
4:06 [1] - 184:4
4:25 [1] - 189:15
4th [16] - 94:4, 120:5,
121:3, 122:12, 125:6,
125:9, 126:24, 129:6,
129:7, 129:8, 129:10,
129:15, 168:14,
168:18, 170:21,
171:15
5
5 [2] - 2:10, 130:22
50 [1] - 3:5
500 [12] - 1:14, 3:6,
118:1, 118:2, 118:5,
118:6, 118:10,
118:16, 119:22,
121:17, 121:24,
165:23
500A [5] - 3:6, 118:6,
118:11, 119:7, 122:6
500B [1] - 118:7
501 [4] - 3:6, 118:6,
118:12, 166:17
501A [6] - 3:6, 118:1,
118:2, 118:5, 118:6,
118:13
502 [1] - 132:13
504 [8] - 3:7, 123:5,
123:6, 123:7, 123:8,
123:11, 123:18,
124:18
505 [10] - 3:7, 123:8,
123:12, 127:18,
127:20, 128:2,
128:24, 130:10,
170:19
506 [4] - 3:7, 123:9,
123:13, 127:14
507 [3] - 123:9,
123:14, 124:7
508 [9] - 3:7, 123:7,
123:9, 123:15, 126:2,
126:21, 129:17,
130:5, 130:22
5225 [2] - 127:17,
127:22
523-5356 [1] - 2:5
55 [1] - 127:22
590-92-6946 [3] -
42:4, 44:21, 46:14
5:00 [1] - 227:17
5:30 [1] - 248:21
5:35 [1] - 249:3
5:37 [2] - 1:6, 251:3
5th [4] - 122:14,
122:15, 122:17,
122:22
6
6 [2] - 55:25, 131:7
60 [1] - 149:8
600 [5] - 3:6, 113:12,
113:16, 113:18,
113:21
601 [11] - 3:7,
133:15, 133:16,
133:17, 133:18,
133:19, 133:21,
134:15, 135:11,
137:15, 139:2
6018 [1] - 136:25
602 [6] - 3:5, 111:12,
111:14, 111:16,
111:17, 111:19
603 [7] - 3:7, 133:7,
133:8, 133:10,
133:11, 133:14, 144:7
604 [4] - 3:8, 145:9,
145:12, 145:14
605 [4] - 3:9, 147:19,
147:22, 147:25
606 [5] - 3:9, 148:19,
148:20, 148:22,
148:24
608 [3] - 133:6,
149:9, 149:11
608A [4] - 3:10,
149:12, 149:15,
157:19
608B [3] - 3:10,
149:9, 149:16
608C [4] - 3:10,
149:9, 149:17, 150:5
608D [4] - 3:10,
149:9, 149:18, 150:13
609 [5] - 3:10, 151:7,
151:10, 151:12,
151:21
610 [5] - 3:10, 151:7,
151:10, 151:13,
152:11
611 [5] - 3:10, 151:7,
151:10, 151:14, 153:2
612 [5] - 3:11, 154:2,
154:3, 154:8, 154:12
613 [6] - 3:8, 140:7,
140:9, 140:11,
140:14, 155:25
613A [8] - 140:3,
140:4, 140:8, 140:10,
140:13, 140:15,
140:18, 154:8
613A&B [1] - 3:8
613B [6] - 140:3,
140:6, 140:8, 141:3,
142:20, 154:6
613C [3] - 3:11,
154:9, 154:13
614 [6] - 3:11, 154:2,
154:3, 154:8, 154:14,
155:7
62.979669 [1] -
129:15
6323 [1] - 57:6
6716 [3] - 120:16,
120:24, 122:17
692 [3] - 71:4, 71:25,
74:10
6:47 [2] - 143:1,
143:16
6:48 [3] - 143:1,
143:16, 143:18
6th [1] - 44:1
7
7 [3] - 43:3, 131:7,
131:8
7200 [5] - 42:8,
46:16, 51:19, 67:5,
225:8
7279 [8] - 118:18,
119:11, 119:16,
119:23, 121:21,
126:16, 127:8, 131:4
73.56.139.104 [5] -
112:15, 160:24, 161:4
73.561.39.104 [1] -
113:9
73.56139.104 [1] -
109:8
754 [1] - 156:10
754-200-4125 [1] -
142:4
77 [1] - 2:13
7A [2] - 36:24, 36:25
7th [1] - 1:15
8
8 [3] - 3:3, 17:17,
119:21
8,952 [1] - 68:19
8821 [8] - 53:10,
53:12, 54:1, 54:10,
55:21, 87:17, 94:12
8:30 [3] - 1:6, 249:10,
250:22
8:48 [1] - 131:1
8:56 [1] - 156:24
8th [1] - 52:15
9
9 [2] - 10:12, 37:4
915 [2] - 66:14, 66:15
916 [1] - 1:22
93 [1] - 2:12
937 [3] - 66:17,
74:10, 88:8
9465 [1] - 66:15
94th [4] - 42:8,
46:16, 51:19, 67:5
951 [1] - 66:17
954-655-0337 [1] -
156:13
9:00 [4] - 248:22,
248:24, 249:1, 250:23
9:05 [1] - 156:25
9:12 [1] - 4:19
9:33 [1] - 145:18
9:34 [1] - 131:9
9:55 [1] - 142:23
9:56 [1] - 157:22
9th [7] - 224:11,
224:12, 225:8,
231:12, 231:13,
231:15, 252:10
A
A-C-O-S-T-A [1] -
190:10
a.m [3] - 1:6, 62:20,
3
63:2
A.M [12] - 4:19,
133:24, 142:23,
145:18, 152:14,
152:19, 153:8,
156:24, 156:25,
157:2, 157:22, 159:3
abate [1] - 74:9
abated [6] - 77:3,
89:13, 89:15, 89:16,
90:5, 96:13
abatement [6] -
70:23, 71:7, 71:20,
74:6, 94:18, 96:11
ABEO [1] - 131:12
Abeona [1] - 130:14
abide [1] - 21:19
ability [7] - 16:25,
54:11, 71:11, 94:13,
138:25, 172:16,
239:21
able [11] - 18:23,
22:15, 87:2, 120:9,
124:14, 124:21,
152:2, 174:16,
194:13, 212:23,
214:14
above-entitled [1] -
252:5
absolutely [14] -
59:10, 196:7, 198:4,
199:7, 200:18, 202:1,
202:9, 203:3, 203:16,
215:9, 218:4, 218:23,
218:25, 239:17
academy [4] -
191:20, 191:22,
192:1, 237:25
accept [2] - 139:18,
145:4
access [7] - 6:23,
7:13, 106:5, 106:11,
145:4, 227:16, 238:18
accessible [2] - 6:19,
6:21
accident [3] - 60:6,
83:8, 207:25
accompanying [1] -
39:11
accomplish [1] -
185:19
according [5] - 60:3,
76:1, 132:9, 219:20,
248:7
accordingly [1] -
91:14
account [76] - 34:4,
37:22, 59:6, 113:23,
114:1, 117:12,
117:15, 117:17,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 255 of
283
117:19, 117:22,
117:24, 118:17,
118:18, 119:10,
119:13, 119:14,
119:23, 120:5,
120:16, 120:17,
120:24, 121:1, 121:4,
121:20, 122:8, 122:9,
122:10, 122:17,
122:18, 122:25,
123:20, 123:21,
123:24, 124:5, 125:5,
126:1, 126:16, 127:8,
127:17, 127:21,
128:5, 128:9, 128:15,
128:20, 130:9, 131:4,
131:5, 131:11, 132:2,
135:18, 135:19,
136:12, 136:17,
136:18, 138:18,
145:6, 153:17,
154:22, 154:23,
155:3, 164:1, 166:2,
166:15, 166:18,
166:20, 167:7,
168:13, 168:20,
170:9, 171:2, 173:25,
178:20, 213:23, 214:8
Accountability [2] -
105:23, 106:3
accountant [1] -
87:21
accountants [2] -
38:19, 38:21
accountholder [1] -
123:22
Accounting [1] -
104:16
accounts [4] -
117:11, 117:19,
117:21, 120:13
accreditation [1] -
16:8
accuracy [2] - 34:12,
39:25
accurate [6] - 34:6,
82:16, 82:24, 117:3,
241:19, 252:4
Accurint [1] - 65:16
ACH [6] - 123:24,
129:6, 129:7, 148:4,
170:21
acknowledge [7] -
7:5, 7:7, 13:5, 13:9,
13:11, 25:3, 220:18
acknowledging [1] -
21:3
Acosta [104] - 8:12,
9:15, 10:13, 18:21,
19:25, 20:13, 20:20,
22:13, 23:7, 28:20,
34:17, 36:17, 41:24,
42:1, 43:6, 44:2,
44:15, 46:11, 46:13,
47:5, 49:12, 51:17,
58:17, 65:18, 67:3,
75:1, 75:8, 82:9,
82:19, 86:2, 86:6,
93:5, 94:22, 101:1,
105:15, 107:6,
107:10, 108:6,
108:17, 115:11,
117:20, 118:18,
120:25, 124:11,
126:13, 127:22,
132:12, 133:2,
133:23, 134:1,
134:16, 134:18,
137:25, 138:2, 138:3,
138:14, 138:17,
139:24, 140:21,
141:12, 143:14,
143:17, 144:16,
145:18, 146:18,
146:20, 146:22,
148:15, 149:1,
149:23, 150:7,
150:15, 151:24,
153:20, 153:23,
154:17, 157:7,
157:23, 159:9,
159:11, 159:12,
164:14, 166:23,
175:13, 178:11,
179:16, 179:24,
180:11, 181:22,
183:1, 183:13,
183:18, 185:6, 185:7,
185:23, 188:6, 188:9,
189:23, 190:10,
190:16, 225:7,
236:10, 249:5
ACOSTA [3] - 1:7,
2:17, 190:3
Acosta's [12] - 10:4,
99:9, 110:16, 127:17,
132:2, 140:23, 145:6,
156:1, 156:7, 158:24,
164:21, 182:9
acquire [1] - 173:21
acquittal [5] - 178:9,
178:22, 179:17,
184:9, 187:14
acronyms [1] - 53:20
Act [6] - 104:11,
104:12, 105:2, 105:7,
106:13, 125:16
act [2] - 54:3
acted [3] - 60:3,
187:8, 235:22
acting [1] - 66:13
action [7] - 8:10,
8:11, 9:14, 22:2,
139:19, 144:19, 220:5
activate [3] - 108:11,
136:16, 136:18
Activate [1] - 136:12
active [2] - 59:6,
140:22
actively [1] - 221:14
activities [2] - 5:24,
16:5
activity [14] - 11:1,
16:10, 16:20, 18:5,
59:21, 130:9, 133:4,
137:1, 141:5, 141:10,
156:1, 163:2, 195:16,
197:2
acts [2] - 60:2, 60:5
actual [13] - 64:16,
80:3, 80:12, 84:16,
84:19, 100:10,
100:16, 109:4, 148:5,
156:13, 165:4, 186:5,
231:8
acuity [1] - 239:23
ADAM [1] - 1:17
adam.love@usdoj.
gov [1] - 1:19
add [1] - 234:24
added [4] - 65:12,
65:14, 70:13, 71:5
addition [3] - 14:21,
116:25, 182:25
additional [12] -
34:4, 41:2, 44:6,
64:23, 66:5, 69:23,
95:11, 117:16,
136:17, 143:24,
173:21, 196:9
address [47] - 11:5,
17:24, 21:6, 39:17,
40:3, 42:7, 43:21,
44:22, 44:23, 46:15,
51:18, 52:7, 58:20,
67:4, 92:21, 98:18,
101:18, 108:7,
108:21, 109:8,
109:14, 109:21,
110:1, 110:7, 110:15,
110:17, 111:4, 111:6,
111:11, 112:14,
112:21, 113:8, 113:9,
113:11, 123:22,
124:10, 146:21,
146:22, 160:15,
163:21, 176:13,
180:10, 182:10,
190:17, 193:13,
213:6, 225:8
addressed [1] -
23:13
addresses [3] -
110:2, 112:20, 163:7
adjourned [1] -
251:3
adjust [1] - 190:7
adjusted [3] - 97:3,
97:17, 98:2
adjustment [1] -
97:10
adjustments [7] -
44:6, 65:13, 68:1,
70:16, 97:3, 97:13,
98:1
Administration [3] -
104:18, 113:5, 139:14
administrative [1] -
16:12
admission [1] -
222:2
admit [13] - 8:16,
13:21, 19:6, 50:12,
111:13, 113:15,
148:18, 205:8, 208:9,
222:8, 222:22,
223:20, 224:7
admits [1] - 64:15
admitted [37] -
13:25, 19:14, 28:24,
36:2, 36:10, 55:23,
59:14, 59:19, 59:22,
64:13, 76:8, 78:6,
83:5, 83:7, 84:10,
84:14, 84:18, 86:17,
99:21, 99:24, 100:1,
107:19, 123:10,
144:7, 145:15,
147:24, 160:17,
162:5, 162:7, 164:7,
165:22, 224:18,
226:7, 233:11, 236:3,
236:4, 248:18
adopted [1] - 244:8
advance [2] - 50:10,
244:14
advanced [2] -
180:10, 199:2
advertisements [2] -
216:13, 216:16
advertising [8] -
42:21, 45:6, 56:15,
70:17, 70:20, 98:14,
149:25, 159:8
advice [2] - 189:2,
200:8
advise [2] - 149:6,
209:12
advising [1] - 90:24
affairs [1] - 215:13
4
affected [1] - 105:3
affirmed [1] - 190:4
afforded [1] - 194:11
AFSP [1] - 54:15
afternoon [4] -
102:16, 160:3, 160:4,
181:19
afterwards [3] -
232:5, 232:6, 232:17
age [1] - 38:16
agencies [1] - 105:9
agency [5] - 16:4,
23:14, 25:1, 26:19,
105:6
agency's [1] - 27:18
agent [9] - 56:11,
91:8, 103:21, 104:2,
104:4, 181:2, 181:20,
221:16, 228:22
Agent [11] - 103:3,
113:20, 118:15,
123:17, 131:13,
140:17, 158:16,
180:5, 181:12,
181:19, 243:20
agents [4] - 227:16,
227:25, 228:4, 228:12
agility [1] - 195:7
ago [4] - 57:12,
84:14, 129:21, 167:1
agree [10] - 21:12,
21:19, 26:6, 31:23,
67:10, 164:24, 165:9,
166:7, 166:22, 167:15
agreed [7] - 55:13,
58:1, 73:22, 184:13,
185:18, 186:4, 243:13
agreeing [1] - 248:8
agreement [4] -
72:23, 74:5, 168:5,
185:8
ahead [4] - 7:25,
60:7, 105:10, 158:13
ahold [1] - 206:11
airplanes [1] -
193:22
Airport [4] - 10:16,
192:17, 192:22,
238:14
airport [14] - 192:20,
193:1, 193:17,
193:20, 193:23,
193:25, 214:13,
217:5, 238:18,
238:20, 238:23,
239:5, 242:11
alert [5] - 135:14,
135:16, 136:21,
154:18, 250:21
Alex [11] - 134:16,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 256 of
283
138:2, 138:14, 149:1,
149:23, 150:7,
150:15, 151:24,
153:23, 157:22, 159:9
alexacosta03 [3] -
131:9, 135:15, 136:22
AlexAcosta03@@
gmail.com [1] - 124:2
alexacosta03@
gmail [3] - 152:6,
153:9, 154:19
Alexacosta03@
gmail.com [4] - 39:19,
109:5, 126:5, 148:3
alexacosta03@
gmail.com [13] -
126:24, 129:20,
130:7, 130:25,
135:18, 136:23,
139:6, 144:25,
152:14, 152:18,
153:25, 154:22, 155:9
AlexAcosta@gmail
.com [1] - 124:10
Alexandra [51] -
8:12, 9:14, 20:13,
20:20, 34:17, 36:17,
41:24, 42:1, 43:6,
44:15, 46:11, 46:12,
47:5, 49:12, 51:17,
58:17, 67:3, 75:1,
75:8, 93:5, 105:15,
107:6, 107:10, 108:6,
108:17, 110:16,
115:11, 117:20,
118:18, 120:25,
124:11, 127:17,
127:22, 132:11,
133:2, 133:23,
140:20, 141:11,
145:18, 146:18,
146:20, 146:22,
156:1, 164:21,
175:13, 178:11,
179:16, 183:13,
189:23, 190:10, 225:7
ALEXANDRA [3] -
1:7, 2:17, 190:3
aligned [1] - 180:11
all-American [1] -
191:9
alleged [1] - 59:21
allegedly [1] -
199:20
allocated [1] -
227:19
allow [2] - 98:17,
181:1
allowance [1] - 70:2
allowances [3] -
73:20, 73:22, 101:10
allowed [4] - 26:18,
215:24, 216:1, 218:4
allowing [6] -
180:19, 181:9,
227:11, 227:15,
228:3, 228:15
allows [2] - 114:22,
197:22
almost [3] - 84:7,
143:10, 199:25
alternatively [1] -
180:1
altogether [1] -
195:6
AMERICA [1] - 1:4
American [2] - 191:1,
191:9
amount [25] - 37:7,
37:10, 37:17, 42:16,
44:8, 45:11, 68:11,
68:16, 68:18, 68:25,
72:4, 74:4, 77:6,
106:18, 116:13,
120:6, 125:14, 131:6,
146:24, 150:1, 150:9,
150:23, 201:1,
202:21, 234:10
amounts [1] - 134:10
analysis [2] - 112:19,
201:21
analyzed [3] - 56:24,
74:2, 117:15
analyzes [1] - 56:24
and-a-half [1] - 158:2
Andrews [1] - 1:22
annotating [3] -
79:7, 79:18, 99:4
annotations [1] -
69:24
annual [1] - 27:14
annually [1] - 200:24
answer [12] - 25:13,
32:2, 41:13, 41:15,
53:16, 55:13, 56:6,
58:1, 65:21, 173:21,
211:3, 249:16
answers [1] - 53:2
anticipate [1] - 250:1
apart [3] - 171:13,
171:14
Apex [1] - 129:14
apiece [1] - 129:16
apologize [9] -
23:21, 36:8, 61:7,
96:25, 112:3, 144:2,
162:16, 169:12, 238:8
app [4] - 120:15,
201:10, 201:11
appear [5] - 62:3,
138:8, 151:1, 157:4,
179:24
appearance [3] -
179:25, 183:7, 183:13
APPEARANCES [1] -
1:12
appeared [2] - 179:5,
179:7
appearing [1] -
114:14
applicability [1] -
25:6
applicable [2] - 16:8,
21:14
application [84] -
86:11, 106:15,
106:17, 108:17,
108:25, 109:2, 109:6,
113:10, 114:6, 114:8,
114:17, 116:2,
116:16, 116:18,
117:3, 117:12,
131:14, 131:19,
132:7, 132:8, 132:10,
132:15, 133:2,
135:21, 136:13,
136:14, 136:16,
139:16, 139:21,
140:23, 140:24,
141:11, 142:11,
143:20, 143:24,
144:19, 145:2,
145:20, 145:23,
146:8, 147:10,
155:11, 155:15,
156:4, 160:18,
160:22, 163:8,
163:14, 163:17,
167:15, 167:23,
168:4, 175:10, 176:2,
176:5, 176:8, 178:14,
178:18, 184:22,
184:24, 185:2, 185:5,
187:5, 212:22, 214:7,
217:12, 217:14,
217:17, 217:20,
217:23, 217:25,
219:1, 219:12,
219:15, 220:23,
229:6, 231:7, 231:8,
231:10, 233:24,
234:13, 234:15, 247:1
applications [2] -
216:2, 235:13
applied [5] - 220:20,
220:23, 226:25,
229:6, 234:10
apply [8] - 18:14,
38:6, 39:1, 174:11,
212:15, 212:18,
216:13, 221:18
applying [3] -
151:17, 185:21, 187:3
appointment [2] -
53:19, 56:13
appointments [1] -
215:11
appreciate [2] -
77:18, 98:20
apprised [1] - 88:7
approach [1] - 4:12
appropriate [1] -
21:12
approval [8] - 11:8,
11:9, 11:18, 11:20,
18:14, 20:6, 20:8,
27:3
approvals [1] - 21:13
approve [1] - 17:22
approved [9] - 21:5,
28:21, 29:11, 139:16,
145:3, 168:9, 221:1,
227:18, 228:6
approving [1] -
21:16
April [29] - 73:11,
81:1, 88:11, 89:9,
100:22, 121:20,
121:22, 122:1,
151:24, 152:13,
152:16, 152:19,
153:8, 153:19,
153:24, 154:16,
154:19, 155:8,
155:22, 156:2,
156:24, 157:1, 157:2,
185:13, 223:10,
226:22, 226:24,
233:20
area [8] - 28:19,
40:1, 42:12, 43:17,
45:4, 48:23, 51:5,
56:9
areas [1] - 59:16
argument [1] -
218:19
arguments [1] -
250:5
arraigned [1] - 180:7
arrange [1] - 152:9
arrest [1] - 179:6
arrested [5] - 179:6,
183:1, 206:22,
219:13, 220:8
artifice [1] - 187:1
Arts [1] - 236:22
ASAP [2] - 64:6,
150:25
asap [1] - 54:23
aspect [1] - 196:8
5
aspects [1] - 82:5
assessed [4] - 83:1,
89:12, 89:20, 91:18
assigned [9] - 10:15,
39:2, 180:11, 192:12,
193:2, 198:19,
198:23, 238:10, 240:9
assignments [1] -
16:6
assist [2] - 57:18,
199:1
assistance [1] -
57:17
assisting [1] - 59:23
associate [3] -
243:7, 243:8, 244:12
associated [20] -
39:17, 44:2, 44:20,
45:12, 46:12, 76:6,
111:5, 112:8, 112:21,
112:23, 113:9,
117:19, 123:22,
124:1, 132:1, 135:4,
141:16, 141:19,
148:12, 151:19
assume [1] - 155:6
assuming [3] - 28:4,
59:4, 180:5
asterisks [3] - 43:22,
85:15, 94:1
Atlanta [1] - 236:16
attached [11] - 47:23,
114:7, 115:1, 116:2,
134:2, 134:13,
134:17, 134:19,
138:15, 145:22, 147:5
attachment [3] -
133:24, 146:7, 146:15
attachments [2] -
137:21, 146:6
attempt [2] - 194:25,
219:16
attempted [3] -
168:19, 195:2, 214:17
attempts [2] -
173:21, 185:6
attend [2] - 191:20,
198:9
attended [1] - 198:11
attending [1] -
191:12
attention [12] -
14:17, 15:16, 15:25,
17:7, 18:1, 20:7, 53:6,
93:4, 121:17, 137:2,
214:10
attorney [65] - 53:11,
53:13, 53:14, 53:17,
54:3, 54:5, 54:11,
54:12, 54:20, 54:22,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 257 of
283
64:2, 64:5, 64:8,
64:15, 64:17, 64:19,
65:2, 65:7, 66:6,
66:18, 69:12, 69:14,
69:25, 70:2, 70:7,
70:12, 70:16, 70:17,
70:20, 70:23, 71:1,
71:19, 71:22, 72:16,
72:18, 72:21, 73:8,
73:17, 74:10, 81:7,
87:13, 87:14, 87:15,
88:1, 88:2, 94:8,
94:12, 99:3, 99:13,
100:9, 101:4, 101:14,
102:3, 102:11,
182:17, 204:11,
204:12, 204:16,
205:5, 207:1, 243:22,
243:24, 244:7
Attorney's [9] - 1:18,
50:10, 105:10,
105:19, 243:11,
244:17, 244:18,
245:1, 250:11
attributed [1] - 97:24
audit [50] - 33:25,
34:3, 34:23, 49:19,
51:7, 51:8, 51:16,
52:2, 52:13, 52:17,
53:3, 54:6, 60:13,
67:20, 67:21, 72:8,
75:16, 82:5, 87:12,
88:7, 91:16, 94:10,
94:23, 96:8, 100:19,
119:2, 132:5, 149:21,
151:3, 199:13,
199:18, 202:13,
203:20, 203:21,
204:1, 205:13,
206:25, 207:9,
207:14, 208:15,
208:17, 208:18,
208:19, 210:1,
218:10, 236:3,
247:25, 248:20,
250:18
audited [5] - 205:7,
205:16, 205:25,
209:7, 246:25
auditor [5] - 74:23,
82:2, 132:12, 132:20,
208:5
audits [4] - 34:14,
51:24, 59:15, 87:16
authentic [4] -
164:24, 165:1, 166:7,
166:22
authenticate [1] -
166:4
authenticating [1] -
178:14
authentication [1] -
9:1
authenticity [4] -
13:24, 19:12, 35:25,
50:16
authority [1] -
204:17
authorization [2] -
54:2, 87:17
authorized [3] -
29:24, 53:13, 218:3
avail [1] - 16:4
Available [1] - 227:5
available [10] -
106:8, 126:4, 126:14,
126:17, 126:23,
127:6, 127:8, 130:20,
141:21, 198:2
Avenue [4] - 1:22,
2:4, 44:24, 252:9
average [1] - 146:23
avoid [1] - 169:16
await [1] - 71:24
aware [10] - 27:12,
29:10, 84:19, 104:23,
105:11, 105:19,
105:25, 114:7,
141:18, 170:6
awareness [2] -
239:19, 239:20
B
baby [2] - 80:24,
149:1
Bachelor [1] -
236:22
bachelor's [2] -
104:16, 191:11
background [5] -
190:18, 197:2, 197:3,
197:4, 197:5
backwards [1] -
215:5
bad [2] - 101:24,
193:1
balance [7] - 68:8,
68:9, 76:20, 77:12,
128:5, 128:9
Bank [7] - 69:20,
104:12, 107:1,
118:17, 125:15,
138:15, 225:4
bank [33] - 59:1,
59:4, 59:6, 69:22,
75:9, 75:19, 75:21,
114:11, 117:5,
117:12, 117:16,
118:19, 119:10,
119:12, 120:4,
121:14, 121:20,
125:5, 126:15, 127:7,
131:3, 134:19,
134:21, 147:4, 147:5,
166:2, 169:8, 169:14,
169:24, 170:5,
172:14, 201:14, 230:9
banking [2] - 119:8,
138:5
banks [1] - 103:22
based [37] - 10:9,
13:20, 19:4, 41:10,
65:15, 70:15, 71:5,
71:14, 73:20, 82:11,
82:16, 95:17, 96:21,
99:18, 101:11, 111:3,
112:19, 117:16,
125:22, 137:24,
139:15, 154:24,
155:4, 163:1, 180:25,
183:18, 184:13,
186:12, 186:25,
201:10, 201:13,
221:5, 229:15,
235:24, 245:5,
249:23, 250:1
basic [2] - 80:8,
180:20
basis [3] - 27:14,
106:11, 110:6
bear [2] - 79:2, 91:3
bearing [1] - 111:10
became [1] - 105:25
become [3] - 38:5,
38:8, 105:17
becomes [1] - 110:5
becoming [2] -
104:24, 105:11
Beechan [1] - 151:17
BEFORE [1] - 1:10
began [4] - 72:14,
72:24, 132:10, 236:12
begin [3] - 190:18,
192:11, 210:11
beginning [8] -
59:12, 94:9, 94:23,
167:5, 170:20,
243:25, 244:7, 244:10
begins [2] - 92:6,
134:5
begun [1] - 168:7
behalf [12] - 54:3,
54:17, 87:10, 87:18,
87:23, 164:3, 204:16,
204:17, 207:14,
215:21, 220:5, 234:18
behind [4] - 137:17,
161:9, 201:20, 202:10
belief [1] - 39:12
believes [1] - 56:23
belonged [1] -
178:17
below [2] - 39:7,
39:24
benefit [1] - 17:3
best [3] - 39:12,
75:11, 96:3
bet [1] - 26:22
better [5] - 28:13,
48:24, 160:8, 192:2,
230:21
between [14] - 24:19,
79:14, 82:1, 110:2,
120:13, 141:11,
147:12, 185:3, 215:9,
216:18, 216:19,
229:5, 241:10
beyond [3] - 9:1,
16:7, 173:20
big [5] - 24:6, 24:11,
195:23, 205:17,
247:16
bigger [1] - 56:19
billing [1] - 141:5
bills [1] - 218:23
binder [2] - 24:8,
78:4
birth [3] - 80:17,
123:23, 215:16
bit [8] - 26:8, 28:12,
90:8, 90:10, 120:8,
148:14, 168:21, 249:9
black [1] - 233:1
blah [6] - 101:11,
101:12, 211:19,
211:20
blank [2] - 78:11,
89:11
blew [1] - 27:21
block [1] - 85:8
blocks [1] - 75:6
blue [4] - 132:18,
162:13, 162:15,
162:16
BlueVine [19] -
131:23, 132:9,
132:14, 132:19,
133:1, 135:24,
135:25, 137:1, 139:6,
139:20, 144:14,
144:17, 144:25,
145:17, 146:11,
148:2, 161:23,
161:24, 162:11
blurry [2] - 81:13,
229:25
Board [1] - 103:19
boarded [1] - 6:25
boarding [1] - 5:24
6
boards [2] - 16:23,
21:10
body [2] - 56:6,
127:5
bomb [4] - 193:4,
193:6, 193:8, 193:11
bombs [1] - 193:9
bookend [1] - 63:20
books [2] - 74:1,
100:12
boom [1] - 247:24
border [1] - 238:22
born [2] - 190:21,
190:22
borne [1] - 193:7
borrower [3] - 147:6,
147:13, 225:7
bother [1] - 96:24
bottom [19] - 9:25,
10:2, 14:17, 15:7,
15:16, 17:7, 20:7,
37:8, 61:8, 68:5,
68:24, 72:12, 93:21,
120:21, 125:2,
150:20, 152:13,
153:3, 157:20
Boulevard [2] - 1:14,
141:17
Box [4] - 36:21,
36:22, 36:24, 36:25
box [2] - 124:21,
175:16
boxes [1] - 78:11
break [4] - 49:14,
158:2, 158:16, 169:16
BRIAN [1] - 1:21
Brian [1] - 1:21
Brief [1] - 188:4
brief [1] - 181:8
briefly [10] - 33:20,
36:19, 38:4, 44:5,
101:18, 109:23,
121:18, 149:21,
177:7, 181:10
bring [14] - 4:11,
4:16, 37:4, 61:8,
62:24, 93:4, 102:22,
124:19, 150:1,
157:23, 158:7,
158:20, 181:4, 189:12
brokerage [3] -
122:25, 167:7, 167:11
Brooks [2] - 29:7,
29:20
brought [6] - 70:17,
70:20, 84:4, 94:8,
210:9, 246:18
Broward [18] - 1:14,
4:7, 5:15, 5:16, 10:22,
11:3, 16:6, 16:22,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 258 of
283
105:18, 107:11,
119:20, 134:9, 135:2,
176:23, 192:8, 194:1,
208:24, 232:9
BSO [28] - 5:19, 6:8,
6:13, 6:19, 6:22, 6:24,
7:5, 10:19, 11:4, 13:8,
16:20, 17:15, 21:24,
24:3, 26:6, 26:16,
30:5, 39:21, 44:3,
56:10, 91:7, 107:4,
237:23, 238:1, 240:5,
240:17, 241:15,
241:23
BSO's [2] - 6:5, 7:11
Bull [1] - 218:17
bunch [5] - 43:22,
157:13, 164:13,
214:11, 248:5
business [47] -
11:16, 11:17, 18:5,
18:6, 18:10, 20:1,
20:3, 20:16, 20:23,
33:16, 33:22, 34:4,
35:11, 35:13, 35:15,
41:25, 42:7, 43:5,
44:8, 44:17, 45:7,
47:19, 47:25, 48:6,
50:6, 65:12, 70:15,
79:13, 91:14, 97:4,
108:8, 141:16,
141:19, 146:18,
146:20, 146:22,
175:12, 175:13,
175:21, 200:3,
200:17, 201:17,
221:14, 242:4, 244:13
Business [3] -
104:18, 113:5, 139:14
businesses [4] -
30:6, 35:12, 42:10,
216:22
busy [4] - 75:12,
96:4, 196:23, 201:3
button [1] - 136:18
buy [6] - 129:4,
130:14, 131:12,
198:3, 198:5, 218:17
buying [1] - 131:6
buys [1] - 129:11
BY [60] - 2:1, 5:11,
8:2, 9:10, 14:5, 19:18,
22:11, 23:2, 24:1,
28:1, 30:15, 33:2,
36:6, 49:18, 50:21,
60:9, 61:23, 63:7,
77:16, 83:23, 92:13,
93:2, 98:22, 101:21,
103:16, 108:14,
111:18, 113:19,
118:14, 123:16,
133:12, 133:20,
137:9, 140:16,
145:13, 147:23,
148:23, 149:19,
151:15, 154:15,
158:15, 160:2,
160:10, 177:9,
181:18, 182:24,
183:6, 190:15,
193:10, 212:8,
222:14, 224:17,
231:16, 232:25,
233:10, 234:16,
234:22, 235:14,
236:9, 246:3
C
C-1 [1] - 16:14
calculated [3] -
42:25, 68:16, 68:18
calculating [1] -
211:22
calculation [1] -
91:13
calculations [1] -
150:10
calendar [3] - 12:2,
12:4, 12:7
cancellation [2] -
129:5, 172:8
cancelled [5] -
125:1, 125:11, 129:9,
170:13, 171:9
canine [3] - 193:2,
193:3
cannot [6] - 54:12,
57:15, 72:21, 74:4,
139:16, 162:24
capable [1] - 185:11
capacity [1] - 139:15
capital [1] - 100:16
Capital [2] - 122:14,
201:16
Captain [2] - 29:7,
29:20
car [3] - 42:21, 45:6,
64:15
card [11] - 57:13,
70:13, 75:9, 88:21,
118:17, 122:11,
138:18, 165:24,
166:1, 166:20, 201:16
care [2] - 57:7,
234:18
career [7] - 6:1,
197:6, 203:4, 215:24,
235:3, 236:12, 236:15
careful [1] - 74:7
carefully [1] - 75:18
CARES [3] - 105:2,
105:7, 106:13
carried [1] - 199:2
carry [1] - 69:18
carryover [1] - 53:16
case [56] - 28:9,
31:22, 41:7, 51:7,
58:2, 65:13, 73:7,
73:14, 73:15, 82:7,
82:12, 89:4, 90:16,
100:9, 101:2, 105:13,
106:21, 118:24,
138:9, 138:22,
148:12, 149:21,
149:24, 150:15,
151:3, 157:16,
157:24, 158:21,
167:22, 169:19,
171:6, 173:16,
177:22, 178:23,
179:8, 179:20,
180:16, 180:18,
181:2, 181:9, 185:4,
185:25, 186:12,
187:10, 187:13,
187:15, 188:10,
189:6, 189:20,
189:21, 204:21,
244:5, 244:19, 246:5,
247:14
Case [1] - 78:9
CASE [1] - 1:2
cases [5] - 72:16,
72:24, 104:23,
186:23, 188:16
cash [3] - 53:17,
73:1, 166:3
casual [1] - 26:8
caught [1] - 122:21
CC [1] - 56:15
CD [1] - 24:11
cell [9] - 54:20,
141:18, 142:1, 142:2,
142:3, 156:1, 156:12,
156:18, 156:20
centralized [1] -
53:12
cents [1] - 130:17
certain [9] - 12:6,
41:1, 51:1, 71:12,
85:1, 106:10, 106:12,
125:15, 125:19
certainly [1] - 229:17
certificate [12] -
108:24, 111:10,
111:21, 113:4,
160:18, 160:21,
161:14, 163:14,
163:20, 163:21,
174:4, 224:22
certificates [2] -
112:8, 215:17
certification [7] -
20:25, 21:2, 39:25,
41:17, 61:24, 145:25,
192:6
certification-note [1]
- 145:25
certified [4] - 38:19,
50:9, 192:2, 192:4
certify [2] - 34:9,
252:3
cetera [3] - 16:23,
21:13, 56:16
chain [5] - 11:18,
25:9, 25:12, 28:22,
153:5
challenged [1] -
183:18
challenges [1] -
250:13
challenging [3] -
138:24, 150:2, 150:10
chance [10] - 49:23,
60:24, 63:13, 115:6,
139:24, 140:25,
146:5, 156:6, 180:18,
190:17
change [8] - 24:21,
24:22, 24:24, 95:12,
135:19, 213:6, 213:7
changed [4] - 76:5,
135:17, 135:18,
248:15
changes [11] - 15:2,
15:22, 67:9, 67:11,
67:24, 71:8, 110:6,
227:11, 227:15,
228:3, 228:15
Changes [1] - 67:19
changing [2] - 17:23,
17:24
characterizing [1] -
247:10
charge [3] - 71:12,
193:19, 242:20
charged [6] - 59:17,
59:18, 59:25, 60:2,
60:5, 243:10
charges [3] - 68:4,
184:11
charging [2] -
105:15, 245:5
Chase [2] - 122:15,
138:18
check [11] - 41:4,
88:20, 109:11,
164:17, 164:22,
165:4, 165:12, 166:3,
7
214:14, 224:2
Check [1] - 164:17
checkboxes [1] -
146:24
checked [3] - 147:3,
175:16, 180:10
checking [6] - 37:21,
117:23, 119:14,
122:10, 153:13,
168:13
checklist [3] - 40:24,
41:2, 93:6
checks [2] - 106:10,
164:13
child [3] - 41:1,
80:18, 191:1
children [1] - 196:22
choose [1] - 38:23
CHRISTOPHER [1] -
1:13
chronological [3] -
9:25, 125:2, 135:12
circle [6] - 120:9,
120:20, 206:24,
211:16, 231:14, 233:1
circled [1] - 231:22
circumstance [1] -
186:21
circumstances [10] -
71:12, 71:21, 82:16,
99:13, 125:19,
154:25, 185:15,
185:20, 186:11,
192:24
circumstantial [4] -
185:7, 186:5, 186:8,
187:11
city [2] - 21:13,
192:12
claim [1] - 53:18
claimed [1] - 64:11
clarification [3] -
126:7, 175:9, 181:20
clarify [4] - 8:23,
177:10, 229:4, 232:24
clarity [1] - 72:1
class [3] - 191:23,
191:24, 240:12
classes [2] - 84:23,
84:24
classification [3] -
5:22, 10:6, 10:13
classify [1] - 147:10
cleaners [1] - 197:18
clear [6] - 81:14,
147:17, 152:23,
166:1, 185:14, 250:6
clearly [2] - 169:19,
235:6
click [1] - 13:12
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 259 of
283
client [16] - 19:8,
30:13, 79:8, 87:12,
88:10, 90:14, 90:19,
91:7, 101:13, 166:8,
173:24, 176:16,
178:17, 180:24,
187:17, 249:14
client's [1] - 168:12
clients [2] - 41:4,
201:12
close [8] - 5:4, 57:1,
150:20, 199:10,
227:20, 235:7,
246:19, 250:19
Close [1] - 73:4
close-quarters [1] -
199:10
closed [2] - 73:15,
101:2
closer [1] - 124:20
closing [6] - 72:14,
73:7, 128:9, 128:11,
128:13, 250:4
closure [1] - 72:24
co [1] - 65:17
co-owner [1] - 65:17
coach [1] - 191:16
Coast [2] - 230:2,
230:8
coast [1] - 162:20
code [1] - 104:10
codefendant [2] -
179:8, 246:25
coerced [1] - 189:9
Collar [1] - 237:13
colleague [1] - 198:2
colleagues [1] -
198:5
collection [1] - 74:6
collections [2] -
72:23, 88:23
College [1] - 236:18
college [4] - 191:4,
191:6, 191:12, 236:12
colonel [2] - 29:6
Colonel [4] - 29:7,
29:15, 29:17, 29:19
colors [1] - 16:21
column [2] - 143:8,
157:6
columns [1] - 125:11
combat [1] - 199:10
Comcast [3] -
109:12, 109:13,
110:10
comfortable [2] -
32:19, 213:3
coming [7] - 14:7,
23:5, 71:16, 78:1,
131:18, 143:10, 193:1
command [4] -
11:18, 25:9, 25:12,
28:22
commands [1] -
27:14
comment [2] - 13:22,
98:24
comments [5] -
56:10, 79:13, 81:15,
100:20
Comments [1] -
81:15
Commissioner [1] -
33:14
commissions [3] -
16:23, 21:10, 164:14
commit [4] - 59:25,
60:2, 60:4, 184:15
committed [2] - 60:5,
220:4
Committee [2] -
105:24, 106:3
common [3] - 30:1,
197:11, 197:20
commonly [1] - 5:19
communicating [1] -
144:16
communication [1] -
206:4
communications [1]
- 156:7
company [4] - 46:4,
48:11, 162:17, 164:11
compare [3] - 63:13,
117:4, 174:3
compared [3] -
62:10, 165:1, 178:17
comparing [2] -
15:21, 172:14
compensated [3] -
16:24, 21:11, 39:1
compensation [3] -
5:22, 115:23, 115:24
compete [1] - 194:22
complete [19] -
11:15, 17:14, 17:20,
18:4, 31:15, 31:21,
39:13, 41:10, 61:18,
61:25, 64:22, 75:15,
96:6, 136:12, 136:16,
136:17, 139:17,
145:21, 194:13
completed [14] -
12:4, 13:13, 22:6,
39:14, 41:7, 93:7,
125:1, 130:24, 131:4,
146:3, 146:5, 147:18,
202:15, 234:15
completely [4] -
163:6, 226:4, 247:3,
247:5
completeness [1] -
136:7
completes [2] -
126:17, 127:9
completing [1] -
28:15
completion [3] -
108:24, 160:18,
160:21
compliance [34] -
54:12, 54:18, 55:11,
55:14, 55:17, 57:24,
64:19, 64:21, 65:5,
65:21, 65:22, 70:24,
71:3, 71:24, 72:16,
73:13, 73:15, 73:19,
74:8, 79:6, 79:15,
81:10, 81:16, 81:22,
82:2, 90:17, 90:23,
99:6, 100:8, 100:13,
101:1, 101:8, 101:10
compliant [1] - 82:24
composite [1] -
221:25
computation [1] -
97:13
computer [3] - 4:13,
201:20, 211:22
conceivably [1] -
228:21
concept [1] - 174:4
concerned [1] -
240:15
concerning [1] -
59:15
concise [1] - 127:19
condition [1] - 17:1
conditions [1] -
228:21
conduct [3] - 34:14,
51:24, 71:14
conducted [2] - 53:4,
120:15
conducting [1] -
52:2
conducts [1] - 7:3
confer [1] - 30:13
conferring [1] - 19:7
confess [1] - 208:2
confidential [1] -
203:10
confirm [2] - 131:10,
162:24
confirmation [1] -
233:24
confirmed [1] -
229:14
confirming [2] -
131:2, 131:12
confuse [1] - 201:24
confusion [1] -
177:11
Congress [1] -
193:22
connected [1] -
178:19
connection [1] -
178:20
consenting [1] -
153:13
consider [3] - 59:20,
70:1, 71:24
consideration [1] -
74:7
considered [2] -
59:23, 179:19
consistent [3] -
55:20, 223:2, 223:4
conspiracy [2] -
184:15, 184:18
conspired [2] -
179:9, 185:10
conspiring [1] -
185:11
Constitutional [2] -
188:11, 188:12
consult [1] - 189:1
contact [16] - 11:16,
52:4, 52:13, 53:21,
63:25, 69:12, 70:6,
71:18, 72:14, 73:11,
115:11, 146:22,
205:1, 207:12,
219:16, 242:8
contacted [1] -
105:18
contacts [1] - 66:7
contained [5] - 9:16,
108:3, 124:24,
146:13, 184:23
containing [3] -
137:21, 145:19,
146:25
containment [5] -
192:18, 192:19,
193:19, 194:9, 194:11
contemporaneous
[1] - 8:25
contestation [1] -
179:15
contested [1] - 179:7
contesting [1] -
179:18
context [5] - 80:2,
86:10, 87:15, 188:16,
200:1
continuation [1] -
92:12
continue [2] - 9:3,
8
136:17
continued [2] -
185:24, 215:12
continuing [2] -
54:8, 145:8
contract [2] - 147:11,
147:12
contractor [1] -
35:20
contractors [7] -
35:18, 227:12,
227:16, 227:19,
228:1, 228:3, 228:16
contrast [3] - 27:1,
95:20, 178:18
contributions [1] -
53:17
Control [1] - 104:11
control [1] - 27:4
convenience [1] -
235:17
convenient [1] -
215:11
conversation [8] -
76:2, 79:20, 79:24,
102:2, 102:5, 210:12,
213:14, 248:8
conversations [1] -
19:5
convey [1] - 220:8
coordinating [1] -
16:11
coordinator [5] -
33:10, 33:12, 33:13,
34:7, 34:9
copies [4] - 50:9,
57:4, 67:8, 88:3
copy [1] - 116:24
corner [1] - 56:3
coronavirus [1] -
217:10
corporations [2] -
172:20, 173:3
correct [214] - 12:10,
23:7, 23:14, 24:12,
25:11, 25:15, 25:17,
25:18, 25:20, 25:25,
26:4, 26:5, 26:13,
26:16, 26:17, 26:20,
26:21, 26:25, 27:2,
27:10, 28:6, 28:7,
28:22, 28:23, 29:1,
29:11, 29:24, 30:7,
31:7, 31:9, 39:13,
45:18, 46:19, 46:20,
47:3, 48:19, 49:1,
49:2, 49:3, 49:4,
49:21, 49:22, 52:1,
52:8, 54:7, 58:4, 58:5,
60:21, 61:5, 61:10,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 260 of
283
61:16, 63:17, 63:18,
72:2, 72:5, 72:10,
73:22, 74:12, 77:5,
77:10, 79:11, 79:15,
79:16, 79:25, 80:9,
80:18, 81:3, 81:5,
81:7, 81:10, 81:11,
82:7, 82:13, 82:17,
82:18, 82:21, 82:22,
83:4, 83:6, 83:15,
84:2, 84:5, 84:8,
84:11, 84:16, 84:21,
85:16, 85:17, 86:22,
86:23, 87:13, 87:23,
87:24, 88:4, 88:7,
88:18, 89:9, 89:10,
90:12, 90:20, 90:21,
91:8, 91:11, 91:12,
91:14, 91:18, 91:19,
91:20, 93:8, 93:9,
93:11, 93:12, 93:14,
93:15, 93:17, 93:18,
94:20, 94:21, 95:13,
95:14, 95:16, 96:12,
96:17, 98:3, 98:5,
98:6, 100:20, 100:23,
100:24, 101:6, 101:7,
115:17, 122:5,
129:25, 131:24,
143:17, 146:3, 148:9,
154:8, 160:22,
160:25, 161:5, 161:6,
161:21, 162:20,
162:21, 162:22,
163:8, 163:15,
163:18, 163:22,
164:1, 164:5, 167:6,
167:18, 168:7,
168:10, 168:13,
168:19, 168:23,
169:6, 169:9, 170:10,
172:17, 173:8,
175:10, 175:14,
176:17, 176:19,
176:23, 191:18,
192:6, 192:7, 194:3,
196:18, 197:19,
198:7, 198:8, 200:12,
200:15, 203:22,
203:23, 204:22,
206:1, 211:25,
212:10, 216:24,
218:10, 218:11,
218:22, 219:10,
221:18, 221:19,
221:21, 229:2,
230:24, 234:19,
238:1, 239:8, 239:19,
241:16, 241:17,
242:14, 242:15,
242:22, 245:14,
246:16, 246:17,
247:18, 247:21,
247:22, 248:12,
248:13, 248:16
corrected [5] - 71:4,
71:25, 74:9, 76:13,
91:16
correcting [1] -
90:23
corrective [1] - 220:5
correctly [2] - 85:24,
207:6
correlate [5] - 15:3,
60:18, 61:1, 137:13,
143:19
correlates [2] -
130:18, 171:17
correlation [1] - 71:8
correspond [1] -
163:2
correspondence [8]
- 33:23, 52:7, 66:23,
105:6, 130:19, 156:3,
185:3
corresponding [2] -
126:1, 144:5
corresponds [2] -
60:14, 230:15
corroborating [1] -
133:4
costs [1] - 146:25
counsel [5] - 13:20,
19:5, 94:8, 221:22,
249:6
counseling [1] -
31:20
count [3] - 178:13,
184:18, 186:17
Count [1] - 187:9
counterpart [1] -
172:22
country [2] - 194:15,
217:3
counts [3] - 178:23,
186:14, 187:8
County [5] - 4:7,
5:15, 5:16, 21:13,
194:1
county [2] - 180:21,
198:24
couple [13] - 23:6,
53:20, 62:23, 79:3,
110:14, 122:11,
122:13, 169:2, 178:9,
190:16, 209:21,
219:6, 230:12
course [24] - 33:16,
50:6, 79:13, 87:12,
87:20, 131:25,
157:14, 158:23,
160:19, 163:10,
163:24, 164:3,
165:20, 171:6,
175:20, 186:9,
196:16, 197:1,
201:25, 202:8, 212:2,
216:6, 216:23, 218:21
Court [7] - 2:3, 2:3,
178:21, 180:19,
184:14, 252:8, 252:9
COURT [164] - 1:1,
4:2, 4:3, 4:9, 4:11,
4:14, 4:15, 4:16, 4:17,
4:20, 5:4, 5:9, 7:23,
7:25, 8:20, 9:3, 9:8,
13:25, 19:13, 22:10,
22:22, 23:19, 23:22,
23:24, 27:23, 30:14,
32:5, 32:8, 32:11,
32:18, 32:23, 36:1,
49:16, 50:17, 59:6,
59:8, 59:11, 61:22,
62:14, 62:18, 62:21,
62:22, 62:24, 62:25,
63:3, 77:20, 83:19,
91:24, 92:3, 92:9,
92:15, 92:19, 92:22,
98:19, 101:19,
102:14, 102:18,
102:21, 102:22,
102:25, 103:5,
103:11, 103:14,
111:15, 113:17,
118:5, 118:7, 118:9,
123:10, 133:10,
133:18, 137:6, 137:8,
140:9, 140:13,
145:11, 147:21,
148:21, 149:11,
149:14, 151:11,
154:8, 154:11, 158:1,
158:4, 158:7, 158:8,
158:11, 159:20,
160:6, 177:2, 177:5,
177:16, 177:21,
178:1, 178:4, 178:24,
179:3, 179:11,
179:17, 179:21,
180:3, 180:5, 180:14,
180:22, 181:1, 181:7,
181:14, 182:22,
183:4, 183:22,
183:24, 184:2, 184:6,
187:10, 187:19,
187:24, 188:1, 188:3,
188:5, 188:9, 188:15,
189:5, 189:8, 189:12,
189:14, 189:17,
189:24, 190:7,
190:11, 193:5, 212:7,
222:6, 222:10,
222:12, 222:23,
223:1, 223:4, 223:8,
223:12, 223:14,
223:23, 224:9,
224:12, 224:14,
231:15, 232:19,
233:8, 234:8, 234:13,
234:21, 236:7,
245:22, 245:24,
248:21, 249:2, 249:5,
249:17, 249:21,
249:25, 250:4,
250:10, 250:14,
250:20
court [9] - 33:10,
33:12, 33:13, 34:9,
178:5, 180:7, 180:21,
183:8, 184:10
courtroom [13] -
4:18, 62:19, 63:1,
102:23, 158:5, 158:9,
178:2, 181:5, 182:13,
182:14, 184:4,
189:15, 249:3
courtroomat [1] -
102:19
cover [3] - 131:5,
193:13, 234:23
covered [6] - 99:5,
131:18, 146:25,
147:1, 147:2
COVID [9] - 106:7,
210:15, 210:17,
211:5, 211:14,
216:22, 217:1, 217:4
coworkers [1] -
205:16
CPA [1] - 87:21
crazy [1] - 217:10
create [1] - 212:22
created [6] - 105:9,
113:5, 143:20, 185:2,
192:20, 247:2
credentials [2] -
155:5, 164:4
Credit [3] - 122:15,
230:2, 230:8
credit [14] - 41:1,
57:13, 65:15, 70:13,
70:21, 75:9, 75:19,
75:21, 88:21, 122:11,
138:18, 171:21,
171:23, 172:2
credits [3] - 41:1,
171:1
credulity [1] - 187:6
Cremidis [2] - 29:8,
29:21
Crevier [3] - 115:12,
164:8, 180:2
9
Crevier's [1] - 115:17
Crime [3] - 237:13,
237:15, 237:18
crime [3] - 60:4,
169:15, 192:25
crimes [4] - 59:18,
59:25, 103:22, 104:10
Criminal [6] -
191:11, 236:24,
237:1, 237:4, 237:7,
237:22
criminal [8] - 104:4,
104:6, 104:17,
188:10, 188:16,
238:3, 238:7, 238:8
Criminology [2] -
237:9, 237:11
criteria [2] - 17:19,
17:21
critical [1] - 198:24
Cross [14] - 2:9,
106:25, 107:1,
107:16, 107:17,
107:21, 108:18,
146:11, 155:10,
155:15, 155:18,
161:1, 162:12, 225:4
cross [13] - 22:23,
77:21, 92:12, 99:1,
115:15, 116:7,
116:25, 132:1, 132:4,
159:21, 178:16,
188:21, 236:7
CROSS [4] - 23:1,
77:23, 160:1, 236:8
cross-examination
[7] - 22:23, 77:21,
92:12, 99:1, 159:21,
188:21, 236:7
CROSS-
EXAMINATION [4] -
23:1, 77:23, 160:1,
236:8
cross-reference [4] -
115:15, 116:7, 132:1,
132:4
cross-referencing
[1] - 116:25
crowds [2] - 193:8,
193:9
Cs [7] - 47:23, 48:17,
57:21, 64:12, 73:25,
74:2, 83:3
Cuba [1] - 191:3
currency [5] - 169:8,
169:10, 169:12,
170:3, 170:4
current [2] - 33:9,
192:6
custodian [5] -
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 261 of
283
33:14, 79:25, 80:2,
85:25, 86:10
custom [1] - 53:3
customary [1] - 47:1
customer [2] - 166:5,
236:2
customs [1] - 238:22
cut [2] - 65:24,
185:24
Cyber [1] - 237:18
D
daily [3] - 10:14,
11:2, 193:22
Dale [2] - 29:17,
29:18
damage [1] - 147:1
data [9] - 65:9,
70:11, 106:5, 106:11,
106:14, 132:1, 132:4,
132:14
database [2] -
106:10, 182:4
date [72] - 9:17, 10:4,
14:20, 14:23, 14:24,
14:25, 15:3, 15:11,
15:12, 15:13, 15:19,
15:20, 39:22, 43:25,
47:7, 52:12, 52:14,
53:7, 56:2, 56:3, 56:4,
58:9, 62:1, 62:6,
63:21, 64:24, 65:10,
66:1, 66:25, 69:19,
72:13, 73:9, 73:12,
74:18, 74:19, 75:4,
75:13, 94:3, 94:5,
94:22, 95:18, 96:5,
109:15, 112:16,
123:23, 130:18,
132:7, 132:17, 134:3,
134:5, 135:13, 144:6,
148:25, 150:5,
156:25, 157:21,
185:1, 201:16,
224:23, 226:14,
226:23, 230:19,
231:11, 231:23,
233:18, 244:15
DATE [1] - 252:8
dated [5] - 55:3,
75:2, 135:14, 158:17,
165:7
dates [6] - 14:21,
15:8, 15:9, 15:18,
171:12
daughter [1] -
196:22
David [1] - 182:4
Davie [2] - 56:13,
141:17
days [13] - 66:13,
72:22, 74:4, 109:16,
110:25, 139:15,
142:8, 142:10,
180:18, 185:21,
190:16, 197:22,
247:20
deadline [2] - 54:21,
65:6
deal [4] - 27:2,
205:17, 207:5, 247:16
debit [2] - 171:7,
171:23
debt [1] - 187:2
deceit [1] - 186:24
December [24] -
12:3, 12:5, 21:21,
52:15, 53:8, 53:19,
55:4, 58:10, 63:23,
64:2, 64:4, 94:24,
104:14, 112:15,
112:16, 113:6, 113:7,
119:11, 125:2,
133:25, 134:4,
163:17, 203:21
decide [1] - 59:20
decision [4] -
188:17, 188:25,
189:5, 189:10
decisions [1] -
188:15
declare [1] - 39:10
declaring [1] - 71:20
declination [1] -
127:11
deduct [2] - 84:15,
84:19
deduction [7] - 37:6,
65:12, 83:19, 83:22,
97:4, 97:5
deductions [1] -
70:15
deemed [1] - 248:16
defendant [20] - 1:8,
59:21, 59:24, 60:1,
60:3, 60:4, 110:19,
124:11, 178:12,
179:4, 179:5, 179:7,
182:23, 184:10,
185:1, 187:8, 188:10,
188:16, 189:23,
249:23
DEFENDANT [5] -
1:21, 188:14, 189:4,
189:7, 189:11
defendant's [3] -
59:15, 222:9, 224:16
Defendant's [4] -
223:15, 223:16,
223:24, 223:25
defendants' [1] -
124:15
defense [12] - 13:20,
19:5, 94:8, 111:9,
111:22, 182:18,
182:21, 187:15,
222:22, 223:17,
224:3, 224:19
DEFENSE [1] - 3:16
Defense [16] - 104:2,
104:13, 104:20,
105:3, 221:25, 222:9,
222:18, 222:22,
223:21, 223:22,
224:7, 224:8, 226:8,
229:23, 231:1, 233:11
defense's [1] -
189:21
deficit [1] - 131:5
define [1] - 243:8
definitely [2] - 26:11,
196:14
defraud [4] - 186:15,
186:16, 186:21, 187:9
degree [3] - 104:16,
191:10, 191:11
Degree [1] - 104:18
degrees [1] - 38:12
deleted [1] - 13:16
deliberate [1] - 186:3
delta [2] - 224:8,
224:15
demands [1] - 215:6
demographical [1] -
123:21
demoted [2] - 31:6,
31:24
denied [1] - 126:19
denoted [1] - 10:4
deny [9] - 21:16,
184:8, 187:14,
220:20, 220:23,
221:1, 221:3, 221:5,
221:9
Department [5] -
16:10, 104:2, 104:13,
104:20, 105:3
department [4] -
10:14, 34:3, 88:23,
240:10
Department's [1] -
10:8
departments [1] -
82:4
depended [1] - 201:3
dependent [1] -
65:17
dependents [2] -
60:16, 61:9
depicted [2] - 14:18,
17:16
deposit [12] -
120:14, 121:25,
125:6, 125:10,
126:15, 127:7, 129:6,
129:7, 148:4, 148:5,
170:21, 172:1
deposited [5] -
37:21, 117:13,
117:14, 119:15, 120:4
deposits [7] - 57:14,
119:20, 121:6, 134:9,
134:24, 135:1, 135:4
Depot [2] - 70:12,
159:7
depreciation [3] -
83:14, 83:19, 83:20
depth [2] - 52:23,
53:1
deputy [18] - 6:10,
10:8, 10:10, 10:14,
16:25, 25:6, 25:19,
26:23, 28:5, 28:8,
31:12, 39:21, 44:3,
56:10, 91:7, 176:23,
192:11, 240:17
derived [1] - 85:19
describe [16] - 9:12,
11:11, 14:22, 15:9,
33:11, 33:20, 35:1,
36:19, 37:15, 44:5,
45:5, 69:11, 119:18,
129:12, 130:13,
146:17
described [2] -
16:10, 101:24
describing [2] -
54:14, 127:10
description [2] -
128:21, 222:24
Design [1] - 237:16
design [1] - 170:20
Designee [1] - 37:24
designee [2] - 38:1,
87:7
designee's [1] - 39:4
destination [2] -
143:6, 143:8
destroyed [1] - 13:16
detail [2] - 73:20,
101:11
details [2] - 86:1,
217:6
detect [1] - 238:3
detects [1] - 193:11
deter [1] - 192:25
determination [1] -
15:1
determine [7] -
10
18:13, 18:19, 65:22,
107:8, 107:9, 159:14,
170:13
determined [1] -
68:3
determining [1] -
59:24
device [3] - 136:22,
154:21, 154:23
dictate [1] - 99:13
difference [3] - 27:8,
28:18, 81:25
differences [1] -
228:10
different [29] - 26:11,
26:12, 27:4, 27:9,
28:16, 30:25, 44:22,
49:14, 73:12, 82:4,
105:2, 105:9, 113:3,
114:12, 124:25,
128:21, 146:24,
166:20, 168:2, 169:2,
172:19, 174:1,
233:23, 239:2, 240:9,
240:10, 248:6
digit [1] - 43:23
digital [3] - 85:16,
85:18, 85:21
dignitary [2] -
193:20, 214:13
diligence [2] - 40:24,
41:4
diligence's [1] - 93:6
Dilto [1] - 29:15
dimensions [1] -
70:12
dinner [1] - 217:8
diploma [1] - 38:14
direct [9] - 14:17,
15:25, 18:1, 27:17,
37:21, 57:14, 121:17,
134:9, 186:8
Direct [1] - 2:9
DIRECT [4] - 5:10,
33:1, 103:15, 190:14
directing [3] - 15:15,
17:7, 20:7
directly [2] - 28:3,
59:16
disagree [1] - 67:11
disagreed [1] - 207:8
disallowed [1] -
69:15
disciplinary [3] -
22:2, 31:14, 31:20
disciplined [2] -
30:17, 240:3
disclosed [1] - 45:1
disclosure [1] -
63:16
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 262 of
283
disclosures [4] -
153:10, 153:14,
153:22, 155:2
disconnected [1] -
110:5
discovery [5] -
244:15, 244:20,
245:17, 245:21, 246:9
discuss [8] - 51:1,
65:23, 73:14, 101:1,
156:12, 201:6,
227:18, 245:2
discussed [20] -
15:10, 24:17, 43:14,
48:25, 53:13, 55:19,
62:5, 63:21, 71:21,
91:18, 93:10, 93:13,
114:6, 133:3, 156:9,
210:1, 210:3, 220:19,
243:25, 246:8
discusses [1] -
130:9
discussing [13] -
42:15, 53:16, 60:12,
65:25, 111:20,
114:15, 130:9,
132:17, 151:2, 151:3,
151:4, 158:17, 188:24
discussion [6] -
17:4, 174:6, 201:7,
211:17, 212:14, 249:6
discussions [7] -
13:20, 38:3, 55:20,
84:18, 87:10, 91:6,
196:25
dispatch [1] - 198:25
display [1] - 14:11
displaying [1] -
19:19
dispute [5] - 176:16,
176:21, 237:20,
240:14, 249:12
disputes [1] - 184:21
disregard [1] - 82:10
distinct [2] - 39:25,
247:12
distinction [1] -
241:10
distinctions [1] -
110:2
District [3] - 2:3,
238:10, 252:9
DISTRICT [3] - 1:1,
1:1, 1:11
distrust [3] - 202:25,
248:2, 248:4
division [1] - 26:22
DIVISION [1] - 1:2
divisions [1] - 82:4
divorced [1] - 200:13
document [52] -
9:12, 36:11, 36:13,
40:23, 44:13, 47:4,
47:19, 50:24, 51:6,
52:10, 58:9, 67:18,
67:23, 79:15, 79:17,
85:8, 85:24, 86:5,
86:11, 87:2, 87:21,
89:6, 108:15, 109:1,
112:10, 113:21,
115:1, 116:9, 118:19,
161:16, 161:18,
161:22, 161:23,
163:3, 163:10,
163:13, 165:21,
170:14, 180:12,
201:6, 204:14,
204:21, 204:23,
204:25, 221:25,
222:3, 224:19,
229:20, 229:25,
230:4, 231:4
documentation [4] -
64:11, 64:20, 65:7,
82:20
documents [43] -
13:24, 33:16, 34:9,
43:14, 54:22, 54:23,
59:8, 63:20, 64:3,
64:4, 64:6, 65:3, 65:5,
65:10, 66:5, 70:7,
73:7, 78:25, 83:11,
83:12, 86:9, 98:16,
98:23, 109:4, 114:7,
114:10, 115:15,
118:25, 135:24,
145:22, 146:5,
146:14, 160:12,
180:11, 200:25,
201:2, 201:5, 201:15,
211:19, 212:9,
215:16, 222:16, 245:8
DocuSign [27] -
108:9, 109:1, 111:10,
111:21, 112:6, 112:8,
112:10, 112:14,
113:4, 113:25,
145:17, 145:19,
146:1, 146:10,
146:11, 147:18,
160:22, 161:14,
161:20, 161:22,
163:13, 163:20,
163:21, 164:3, 164:4,
168:1, 174:3
Dog [2] - 42:2, 43:6
dog [4] - 193:4,
193:6, 193:7, 193:11
DOJ [1] - 1:14
DOJ-USAO [1] - 1:14
dollar [2] - 106:18,
125:14
dollars [5] - 76:25,
126:14, 127:6, 209:1,
215:25
done [9] - 70:17,
88:23, 91:13, 91:16,
109:11, 122:8,
202:20, 202:21,
218:18
Doto [1] - 29:15
double [12] - 83:5,
84:1, 84:7, 91:17,
96:19, 99:22, 104:17,
207:22, 208:14,
208:18, 224:2, 248:10
double-entered [1] -
83:5
double-reported [1]
- 248:10
down [36] - 16:13,
37:8, 37:12, 37:23,
39:7, 39:24, 44:4,
55:24, 60:23, 61:8,
63:12, 84:5, 85:11,
97:10, 124:19,
132:22, 137:1, 144:3,
146:6, 150:1, 152:1,
155:17, 167:14,
169:16, 170:19,
177:17, 183:24,
185:17, 194:10,
200:24, 202:18,
213:1, 213:17,
225:14, 243:18,
243:20
drain [1] - 215:7
draw [2] - 53:6, 61:7
drive [1] - 242:11
driver's [5] - 118:25,
180:9, 182:1, 182:2,
182:5
drop [8] - 16:13,
75:12, 96:4, 200:25,
201:2, 201:5, 209:25,
211:19
dropping [1] - 215:9
dual [1] - 209:5
due [17] - 40:24,
41:4, 68:8, 68:9,
68:25, 69:1, 73:16,
74:4, 75:12, 76:20,
77:6, 80:17, 88:14,
93:6, 96:3, 101:2,
194:12
duly [4] - 5:1, 32:15,
103:8, 190:4
duplicated [2] -
64:13, 64:15
duplicative [1] -
131:7
during [33] - 77:11,
102:2, 102:4, 114:19,
119:25, 120:3, 121:7,
121:14, 131:25,
134:8, 139:23,
140:22, 141:3,
148:11, 156:15,
157:13, 158:23,
159:14, 179:23,
181:8, 181:21, 197:1,
206:13, 207:9, 211:5,
211:14, 214:23,
217:10, 229:5,
240:17, 244:12,
246:24
duties [5] - 5:23,
16:5, 33:11, 104:7,
198:22
duty [39] - 10:23,
10:25, 11:1, 11:5,
11:7, 11:12, 11:14,
14:15, 14:16, 15:22,
16:7, 16:16, 17:4,
17:10, 17:14, 17:22,
17:23, 18:4, 18:11,
18:14, 18:17, 18:23,
19:1, 19:23, 20:1,
21:8, 21:23, 22:1,
22:3, 22:12, 22:15,
25:7, 28:6, 30:2,
107:5, 107:11, 194:12
Duty [2] - 16:3
dynamic [3] - 110:3,
110:6, 110:8
E
e-mailed [2] -
219:22, 242:6
early [3] - 104:19,
111:25, 112:3
earned [11] - 86:21,
91:11, 176:22, 237:1,
237:4, 237:7, 237:9,
237:11, 237:13,
237:15, 237:18
earning [1] - 208:23
easier [1] - 75:7
East [1] - 1:14
east [1] - 162:20
Eastern [2] - 161:10,
162:22
easy [3] - 64:6,
206:5, 212:17
economic [2] -
121:11, 122:2
economy [1] - 211:9
educated [1] - 82:10
education [3] -
11
38:10, 85:1, 104:15
effacing [1] - 141:20
effect [2] - 54:15,
76:16
effective [6] - 14:20,
14:24, 15:12, 15:13,
15:20, 230:19
effectively [4] -
55:10, 145:21,
185:10, 246:19
effort [1] - 65:4
EIC [1] - 41:2
EIN [1] - 40:15
EIP [1] - 121:10
EIP2 [1] - 121:9
either [10] - 38:7,
80:23, 82:6, 118:8,
125:1, 159:15,
185:16, 186:3,
200:25, 205:22
elaborate [4] -
174:22, 174:24,
201:8, 211:11
electronic [7] -
36:14, 43:23, 93:24,
153:10, 153:14,
153:21, 155:1
electronically [10] -
25:4, 43:12, 43:20,
46:8, 85:17, 85:20,
85:21, 86:2, 153:15,
211:25
element [3] - 186:3,
186:20, 187:13
elements [1] -
184:14
elevated [1] - 239:18
elsewhere [1] -
118:24
email [88] - 13:3,
13:7, 13:8, 13:9,
39:17, 58:20, 108:7,
109:6, 123:22, 124:1,
124:10, 126:5,
126:12, 126:19,
127:5, 130:5, 131:2,
132:9, 133:23, 134:3,
134:13, 134:16,
136:4, 136:5, 136:11,
136:19, 138:3,
139:18, 144:21,
145:6, 145:16,
145:17, 146:7,
146:16, 146:21,
147:25, 150:22,
151:23, 151:25,
152:4, 152:5, 152:7,
152:11, 152:12,
152:17, 152:18,
152:19, 153:5,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 263 of
283
153:19, 153:23,
154:17, 157:14,
158:17, 158:19,
159:2, 163:25,
167:25, 171:17,
172:8, 174:10, 175:2,
185:3, 203:25,
212:25, 213:13,
213:15, 213:18,
213:23, 214:8, 218:5,
218:12, 220:2,
222:25, 223:8,
223:11, 224:10,
231:9, 231:11,
231:25, 232:16,
233:1, 234:1, 234:5,
234:8, 247:3, 247:8,
247:9
emails [38] - 54:14,
124:15, 125:25,
127:10, 132:1, 133:3,
137:20, 138:21,
138:24, 139:10,
143:25, 144:3, 144:5,
148:12, 148:15,
149:20, 150:18,
151:18, 152:23,
153:4, 157:13, 163:1,
171:16, 171:25,
173:24, 174:9,
174:12, 174:16,
174:19, 206:6,
213:19, 214:8,
214:10, 214:12,
214:14, 216:9, 224:9,
229:5
EMPLID [1] - 9:20
employed [5] - 18:4,
175:17, 175:20,
197:8, 208:21
employee [27] - 6:2,
6:25, 7:2, 7:16, 8:10,
8:11, 8:13, 9:14, 9:22,
10:4, 11:2, 11:7,
11:11, 12:1, 13:8,
16:20, 18:10, 18:13,
18:16, 22:6, 23:9,
25:3, 27:19, 30:20,
31:1, 31:5, 31:23
employee's [4] -
9:17, 9:18, 11:25,
13:14
Employees [1] -
227:5
employees [30] -
5:24, 6:8, 6:10, 6:17,
6:19, 6:23, 7:5, 9:22,
12:25, 16:4, 16:22,
17:14, 18:4, 21:9,
24:24, 26:2, 27:13,
30:5, 30:17, 105:21,
211:2, 211:6, 216:8,
216:10, 216:11,
227:6, 227:12,
227:20, 228:16,
229:12
employees' [2] -
14:10, 25:9
employer [7] - 17:3,
17:23, 17:24, 21:6,
40:17, 42:5
employment [36] -
10:23, 10:25, 11:1,
11:5, 11:7, 11:10,
11:14, 14:10, 14:16,
15:22, 16:16, 16:19,
17:1, 17:2, 17:4,
17:10, 17:14, 17:22,
18:5, 18:11, 18:14,
18:17, 18:23, 19:1,
19:23, 20:1, 21:8,
21:23, 22:1, 22:7,
22:12, 28:6, 30:3,
107:5, 107:11, 159:11
Employment [1] -
16:3
empty [1] - 217:5
enclosed [1] - 67:8
end [17] - 12:2, 12:6,
45:14, 57:23, 61:12,
71:16, 72:19, 88:14,
89:21, 89:23, 142:22,
194:7, 194:21,
198:11, 207:13, 209:8
ending [14] - 97:1,
118:18, 119:10,
119:23, 120:16,
120:24, 121:21,
122:17, 126:16,
127:8, 127:17,
127:22, 131:4, 134:5
endorsement [1] -
164:22
ends [1] - 65:19
enforced [2] - 26:8,
239:1
Enforcement [1] -
10:8
enforcement [26] -
10:10, 10:14, 17:1,
17:2, 25:5, 27:9, 30:2,
104:25, 105:6, 106:9,
125:23, 154:24,
159:1, 172:24, 173:4,
182:7, 191:18, 192:3,
197:4, 197:12,
197:13, 197:20,
203:2, 203:7, 241:16,
241:25
engaged [1] - 59:21
ensure [1] - 55:20
enter [2] - 84:8,
207:24
entered [11] - 4:18,
58:6, 63:1, 83:5, 83:8,
102:23, 158:9, 181:5,
189:15, 191:17,
230:17
entire [5] - 52:10,
88:6, 107:2, 142:9,
225:24
entirely [1] - 163:4
entitled [4] - 37:23,
61:13, 220:10, 252:5
entity [1] - 115:10
entries [1] - 64:23
entry [47] - 52:9,
52:11, 52:13, 53:6,
53:7, 53:9, 54:25,
55:3, 55:24, 58:2,
63:21, 63:22, 64:1,
64:24, 65:8, 66:1,
66:12, 69:11, 69:17,
69:21, 70:5, 70:9,
70:10, 71:17, 72:11,
72:13, 73:3, 73:10,
79:5, 80:20, 80:21,
84:1, 84:7, 91:17,
94:9, 99:22, 100:22,
101:22, 102:10,
121:5, 130:12,
132:23, 137:3,
207:22, 208:14,
208:18
envelope [1] -
146:13
Environmental [1] -
237:15
equally [1] - 84:14
equate [1] - 137:19
Erin [5] - 65:18,
149:5, 159:11, 218:9
erroneous [1] -
99:21
error [2] - 180:20,
207:24
errors [1] - 202:12
escorts [1] - 193:22
especially [2] -
206:13, 215:23
ESQ [3] - 1:13, 1:17,
1:21
essence [3] - 61:24,
90:23, 155:12
essentially [3] -
106:16, 109:13, 147:6
establish [3] - 181:3,
187:7, 187:12
established [2] -
91:6, 146:19
establishing [1] -
185:15
estate [20] - 29:23,
64:13, 91:8, 96:19,
97:21, 98:7, 98:11,
164:11, 176:18,
197:1, 197:3, 197:4,
197:6, 197:25,
221:16, 227:16,
227:25, 228:4,
228:12, 228:22
et [3] - 16:23, 21:13,
56:16
evaluate [2] - 18:18,
240:1
evaluated [2] -
70:13, 74:1
evaluation [1] -
70:17
evening [2] - 248:22,
250:25
event [4] - 109:4,
111:2, 199:20, 250:21
events [5] - 108:9,
108:25, 112:12,
113:3, 216:24
eventually [2] -
191:17, 206:14
everybod [1] -
102:17
evidence [40] - 8:18,
8:20, 13:21, 14:4,
19:14, 50:18, 55:23,
59:13, 59:19, 59:20,
59:22, 65:16, 77:11,
82:12, 92:19, 111:14,
111:16, 133:10,
133:18, 140:13,
145:15, 162:5,
163:24, 174:12,
174:16, 178:10,
178:14, 178:19,
184:12, 184:25,
185:7, 185:22, 186:6,
186:8, 186:9, 186:12,
186:25, 187:6,
223:21, 244:20
Evidence [41] - 8:21,
14:2, 14:3, 19:15,
19:16, 19:17, 36:3,
36:4, 36:5, 50:20,
111:17, 113:18,
118:10, 118:11,
118:12, 118:13,
123:11, 123:12,
123:13, 123:14,
123:15, 133:11,
133:19, 140:14,
140:15, 145:12,
147:22, 148:22,
12
149:15, 149:16,
149:17, 149:18,
151:12, 151:13,
151:14, 154:12,
154:13, 154:14,
223:16, 223:24,
224:16
evidenced [1] -
185:8
evident [1] - 82:11
ex [1] - 114:21
exact [2] - 163:21,
248:15
exactly [18] - 31:9,
40:25, 56:21, 66:19,
68:3, 89:3, 92:21,
103:20, 107:7, 113:1,
120:12, 137:10,
137:23, 144:15,
209:12, 210:11,
216:17, 244:9
exam [1] - 75:19
Examination [1] -
67:19
EXAMINATION [13] -
5:10, 23:1, 33:1,
77:23, 93:1, 98:21,
101:20, 103:15,
160:1, 177:8, 181:16,
190:14, 236:8
examination [19] -
22:23, 27:17, 34:3,
55:15, 55:18, 57:7,
67:8, 67:21, 71:8,
76:6, 77:21, 92:12,
95:12, 96:20, 99:1,
159:21, 188:21,
204:3, 236:7
examined [5] - 5:2,
32:16, 39:10, 103:9,
190:4
examiner [7] - 52:2,
56:11, 81:18, 81:24,
82:1, 82:2, 208:5
examining [1] -
51:12
example [5] - 26:15,
46:23, 48:15, 97:17,
99:21
examples [1] -
211:11
excellent [1] -
160:11
except [4] - 104:8,
246:20, 248:23,
250:18
exceptional [1] -
240:14
excerpt [1] - 119:8
excessive [1] - 68:4
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 264 of
283
excuse [8] - 15:16,
20:18, 41:14, 64:12,
70:18, 116:5, 132:18
excused [2] - 32:9,
102:15
Excused [2] - 32:10,
177:18
executed [3] - 88:1,
130:6, 131:8
exemplary [1] -
235:3
exercise [1] - 16:25
exercises [1] - 195:8
exhibit [12] - 3:2, 8:3,
8:6, 8:9, 10:2, 16:13,
19:9, 92:15, 131:17,
134:12, 223:2, 223:5
Exhibit [115] - 3:16,
7:18, 7:21, 8:17,
13:19, 14:18, 15:6,
15:15, 16:1, 19:19,
20:10, 20:18, 28:25,
36:10, 37:11, 37:13,
40:22, 43:8, 43:15,
44:14, 46:6, 48:21,
48:22, 50:1, 50:13,
50:23, 50:24, 51:4,
55:23, 58:7, 60:11,
60:15, 60:21, 63:9,
63:19, 66:24, 67:15,
76:9, 78:6, 93:4,
93:10, 93:21, 95:21,
96:22, 107:23,
108:10, 108:15,
108:22, 111:12,
111:14, 111:19,
113:12, 113:16,
113:21, 114:23,
115:20, 115:21,
118:16, 119:6, 119:7,
119:22, 121:17,
121:24, 122:6,
123:18, 124:7,
124:18, 126:2,
126:21, 127:14,
127:20, 128:2,
128:24, 129:17,
130:5, 130:10,
130:22, 132:13,
132:22, 133:6,
133:14, 133:21,
135:11, 136:25,
137:15, 140:18,
141:3, 142:20, 144:7,
145:9, 145:14,
147:19, 147:25,
148:19, 148:24,
150:5, 150:13,
151:21, 153:2, 154:2,
155:7, 155:25,
157:19, 221:25,
222:11, 222:13,
222:18, 222:22,
223:16, 223:24,
224:8, 224:16, 231:1,
233:11
Exhibits [9] - 14:7,
19:4, 35:22, 74:15,
107:19, 149:8, 151:7,
222:9, 246:9
exhibits [4] - 14:9,
36:2, 51:2, 221:23
exist [1] - 12:11
expanded [1] - 104:8
expect [1] - 249:15
expected [1] - 147:9
expenditures [2] -
147:2
expense [4] - 42:25,
70:14, 80:12, 218:22
expenses [57] -
42:18, 42:20, 42:21,
42:23, 45:5, 45:6,
45:9, 45:10, 47:25,
48:2, 48:12, 49:3,
49:6, 56:17, 56:20,
57:19, 57:20, 60:24,
61:1, 61:9, 61:10,
62:11, 63:10, 63:13,
64:11, 64:16, 69:16,
69:23, 70:18, 70:20,
73:23, 73:24, 75:20,
80:4, 84:15, 84:20,
91:13, 95:1, 95:6,
95:7, 97:6, 97:7,
97:16, 97:24, 98:2,
100:10, 100:16,
116:18, 116:21,
116:23, 201:14,
201:17, 208:3
experience [2] -
154:24, 173:3
expert [1] - 170:7
expertise [1] - 199:2
expires [2] - 12:3,
21:21
explain [15] - 15:6,
35:2, 36:21, 37:25,
40:11, 67:7, 71:23,
106:4, 109:23,
123:18, 145:15,
173:11, 188:9,
207:20, 231:23
explained [15] -
54:17, 55:14, 55:17,
57:25, 64:21, 71:19,
73:15, 73:19, 73:25,
84:23, 99:6, 100:13,
101:2, 101:10, 247:4
explaining [2] -
57:19, 95:6
explanation [2] -
24:21, 64:9
explosives [1] -
193:7
expound [1] - 137:7
extended [1] -
227:21
extent [2] - 179:19,
250:13
external [2] - 16:23,
21:10
extra [5] - 14:15,
15:22, 16:6, 203:1,
239:14
Extra [1] - 16:3
extremely [1] -
194:17
eye [1] - 122:21
eyes [1] - 89:8
F
F-8821 [1] - 54:9
F616B [1] - 146:10
face [2] - 140:24,
184:23
facie [2] - 178:23,
187:13
fact [14] - 24:10,
28:20, 30:5, 48:20,
75:15, 76:3, 79:19,
96:7, 107:10, 176:13,
205:12, 212:20,
221:9, 244:3
factor [1] - 215:12
facts [3] - 63:21,
167:22, 246:5
factual [3] - 250:7,
250:8, 250:10
failed [2] - 178:11,
195:4
failing [1] - 30:17
failure [2] - 21:25,
178:22
fair [7] - 80:15,
199:4, 200:16,
229:14, 235:22,
240:6, 243:6
faith [2] - 82:23,
235:22
fake [4] - 218:1,
219:2, 248:5, 248:7
fall [1] - 105:5
false [9] - 184:15,
184:16, 184:18,
184:20, 184:23,
184:24, 185:22,
186:2, 186:18
familiar [15] - 6:5,
24:13, 31:3, 31:22,
33:18, 33:25, 35:7,
35:16, 51:24, 80:11,
83:10, 109:20,
238:20, 238:25, 243:2
families [1] - 235:8
family [4] - 195:21,
196:15, 196:19, 235:9
far [5] - 58:8, 170:14,
195:6, 198:21, 240:15
fast [3] - 203:20,
209:8, 209:21
fast-forward [3] -
203:20, 209:8, 209:21
favorable [1] -
187:12
fax [4] - 64:5, 65:7,
70:8, 70:11
faxed [6] - 53:12,
54:23, 58:11, 58:13,
61:4, 74:6
faxes [2] - 64:7,
69:22
faxing [1] - 64:3
February [97] -
39:23, 44:1, 47:8,
62:2, 69:20, 70:6,
70:11, 71:6, 79:5,
94:4, 94:7, 101:22,
109:3, 111:2, 112:17,
112:23, 119:24,
120:5, 121:3, 121:5,
122:12, 122:14,
122:15, 122:17,
122:22, 125:6, 125:9,
126:6, 126:18,
126:24, 127:9,
127:25, 128:4, 129:6,
129:7, 129:8, 129:10,
129:15, 129:19,
130:7, 130:12,
130:15, 130:18,
130:25, 131:9,
132:11, 132:17,
133:24, 134:17,
134:18, 134:22,
135:6, 135:14,
135:24, 138:2,
138:13, 139:7, 141:1,
141:6, 142:11,
142:16, 142:21,
143:9, 143:13,
143:25, 144:5, 144:9,
145:8, 145:18, 148:3,
149:23, 152:5,
154:16, 157:22,
158:17, 159:3, 159:9,
167:15, 167:17,
167:24, 168:1, 168:7,
168:9, 168:14,
13
168:18, 170:21,
171:15, 185:12,
185:13, 185:16,
209:21, 213:24,
214:12
Federal [2] - 103:18,
103:25
federal [2] - 103:21,
104:25
fee [2] - 225:15,
225:19
feet [2] - 195:4,
195:9
felt [4] - 79:21,
203:14, 213:9, 248:19
female [4] - 194:2,
194:3, 194:4, 198:17
few [12] - 69:24,
69:25, 71:16, 129:21,
136:16, 136:17,
139:15, 160:11,
167:13, 177:24,
197:22, 202:23
field [3] - 81:16,
82:10, 237:21
fifth [1] - 52:22
fight [1] - 218:20
figure [4] - 56:20,
56:22, 56:25, 172:11
figured [1] - 95:1
figures [7] - 56:22,
57:20, 74:2, 75:23,
83:2, 95:7, 95:24
file [24] - 6:1, 7:17,
8:14, 11:25, 13:14,
22:13, 34:23, 35:4,
35:6, 35:10, 36:14,
47:22, 51:7, 59:9,
75:24, 76:1, 76:3,
82:16, 85:20, 99:7,
107:2, 107:12,
107:17, 246:10
filed [17] - 43:12,
46:8, 47:15, 48:18,
75:17, 85:17, 86:3,
86:6, 96:8, 114:22,
116:7, 116:10,
116:22, 116:24,
117:4, 241:18
files [3] - 18:21,
49:23, 108:3
filing [3] - 71:5, 99:8,
99:12
fill [6] - 12:5, 28:8,
31:12, 41:3, 211:23,
215:15
filled [10] - 28:5,
28:9, 31:13, 175:19,
175:23, 175:24,
175:25, 176:3, 219:2,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 265 of
283
235:13
filling [3] - 31:24,
217:13, 217:19
fills [1] - 99:17
filming [1] - 186:10
final [4] - 70:7, 72:6,
249:11, 249:16
finally [1] - 166:15
finances [2] - 218:16
financial [4] - 34:5,
103:21, 104:9, 117:11
fine [2] - 48:17,
168:17
finger [1] - 208:12
finished [1] - 145:2
finishing [1] - 193:23
firearm [2] - 26:20,
27:5
firearms [1] - 26:15
fired [1] - 31:6
firm [3] - 40:18, 46:2,
47:15
firm's [4] - 40:15,
40:17, 46:2, 47:13
first [72] - 4:22, 10:3,
47:18, 50:22, 51:3,
52:9, 52:10, 52:13,
66:4, 67:6, 75:7, 85:5,
85:10, 85:11, 95:22,
100:14, 110:14,
118:15, 123:17,
128:24, 129:12,
129:14, 131:16,
132:18, 133:13,
133:21, 137:3,
142:23, 143:9, 146:7,
146:15, 150:13,
156:24, 161:16,
164:17, 167:17,
167:18, 168:20,
171:18, 172:1, 172:4,
178:25, 179:4,
179:24, 180:21,
184:18, 190:4,
190:18, 191:1, 194:2,
195:3, 198:14,
198:17, 203:21,
203:24, 208:6, 210:6,
210:9, 214:21, 219:1,
219:11, 226:13,
229:6, 233:25,
238:10, 241:16, 248:8
five [14] - 4:5, 43:23,
56:12, 62:15, 129:24,
130:4, 142:16, 143:1,
194:24, 195:4, 195:9,
196:2, 242:18
fix [1] - 180:19
FL [3] - 1:15, 1:18,
1:22
flipping [1] - 144:2
Floor [2] - 1:15,
252:10
FLORIDA [1] - 1:1
Florida [17] - 1:4,
2:4, 16:7, 42:8, 44:24,
46:16, 51:19, 67:5,
180:12, 181:22,
182:1, 182:2, 182:5,
190:22, 192:2, 192:5,
252:10
flub [1] - 218:1
flying [1] - 217:6
focused [1] - 197:24
folks [2] - 102:16,
184:2
follow [1] - 170:12
follow-up [1] -
170:12
followed [2] - 27:6,
27:7
following [21] - 4:1,
4:19, 6:18, 46:22,
47:2, 62:20, 63:2,
95:10, 102:20,
102:24, 106:6,
113:24, 117:6,
153:19, 158:6,
158:10, 178:3, 181:6,
184:5, 189:16, 249:4
follows [8] - 5:2,
17:4, 18:19, 32:16,
103:9, 134:12,
163:24, 190:5
food [1] - 218:24
FOR [2] - 1:13, 1:21
force [1] - 238:20
forced [1] - 189:8
forces [2] - 105:9,
199:5
foregoing [1] - 252:3
Forensic [1] - 237:11
forgetting [1] - 160:7
Forgivable [1] -
227:5
forgivable [5] -
227:12, 227:16,
227:25, 228:12,
228:16
forgive [1] - 72:12
forgiven [5] - 106:19,
155:13, 155:14,
155:18, 218:2
forgiveness [27] -
107:24, 151:16,
151:18, 151:19,
152:24, 153:7,
155:11, 155:15,
156:4, 176:2, 176:8,
178:13, 178:20,
213:20, 216:9,
216:19, 217:12,
217:13, 219:11,
219:15, 220:23,
225:12, 225:15,
226:25, 229:6,
233:24, 234:15
forgot [3] - 23:23,
136:6, 229:20
form [69] - 11:13,
11:14, 11:15, 12:1,
12:2, 12:3, 12:5,
13:13, 17:10, 17:11,
17:13, 17:15, 17:20,
18:5, 18:11, 19:23,
20:1, 20:4, 20:12,
20:18, 20:19, 21:7,
21:24, 22:3, 22:4,
25:8, 27:1, 27:13,
28:5, 28:8, 28:15,
28:21, 29:14, 30:18,
30:22, 30:23, 31:13,
31:15, 31:21, 31:25,
33:22, 35:10, 37:16,
40:1, 41:7, 42:10,
42:12, 43:5, 45:5,
46:10, 46:21, 47:9,
58:15, 60:13, 61:12,
67:12, 81:17, 87:17,
87:19, 93:14, 106:16,
115:24, 116:15,
145:21, 145:24
Form [26] - 35:2,
35:3, 35:16, 36:14,
46:8, 53:10, 53:12,
54:1, 54:10, 54:15,
55:21, 56:14, 66:15,
66:17, 67:17, 69:13,
71:4, 71:25, 72:17,
72:18, 87:17, 94:12,
114:12
formal [3] - 38:9,
104:15, 105:8
formalized [1] -
148:5
formally [1] - 180:12
format [2] - 24:24,
106:17
forms [12] - 11:20,
11:21, 11:22, 11:23,
14:10, 18:23, 19:1,
20:25, 22:13, 22:15,
107:6, 211:23
Fort [7] - 1:22, 42:8,
141:17, 192:17,
192:21, 238:13
forth [4] - 5:6, 52:4,
79:2, 122:19
forums [1] - 100:11
forward [9] - 175:1,
175:4, 187:20,
189:25, 203:20,
209:8, 209:21,
213:19, 250:23
forwarded [2] -
137:20, 174:25
forwarding [2] -
153:24, 155:4
foundation [1] -
137:5
four [6] - 56:12,
128:24, 143:1,
145:22, 187:19, 196:2
fourth [2] - 17:16,
52:21
FPR [2] - 2:2, 252:8
Frank [1] - 29:20
fraud [10] - 104:22,
105:7, 105:10, 106:1,
106:7, 184:17,
186:14, 186:20, 220:4
fraudulent [1] -
221:10
FRB [1] - 173:15
free [4] - 142:22,
195:20, 196:6, 196:10
frequent [1] - 30:1
friend [1] - 198:2
friends [2] - 198:4,
205:16
front [3] - 8:3,
185:21, 250:16
frustrated [1] - 90:14
frustration [4] -
73:18, 81:9, 101:8,
102:8
Ft [1] - 1:15
full [13] - 63:16,
72:22, 88:14, 91:7,
91:20, 91:21, 95:22,
96:1, 131:6, 196:17,
197:6, 220:10, 234:13
fully [3] - 53:15,
70:4, 220:16
function [2] - 53:13,
80:7
funding [1] - 139:17
funds [10] - 105:11,
106:7, 117:14, 120:1,
126:4, 148:1, 168:18,
168:22, 227:19,
227:20
Funds [3] - 122:23,
126:23, 227:5
future [2] - 57:25,
76:3
G
G's [1] - 76:8
14
G-1 [1] - 17:13
G-mail [9] - 153:24,
153:25, 154:21,
155:2, 155:5, 164:1,
173:25, 178:19, 223:9
gainfully [1] - 208:20
gaming [1] - 129:4
gap [1] - 200:19
gas [1] - 56:16
gate [1] - 214:14
gear [1] - 194:20
General [2] - 103:18,
104:3
general [6] - 34:2,
41:16, 42:9, 173:3,
201:7, 203:8
generally [15] - 6:15,
14:9, 55:8, 109:16,
109:20, 110:5,
110:25, 125:14,
198:21, 202:20,
205:3, 211:11,
211:13, 222:24,
238:25
generated [1] - 66:15
generation [1] -
191:1
ghosted [2] - 220:2,
232:17
gig [1] - 197:21
given [11] - 61:17,
70:22, 73:20, 83:1,
87:9, 87:18, 101:11,
163:25, 186:4, 221:3,
250:21
Gmail [2] - 113:22,
223:1
gmail [2] - 145:6,
223:10
gold [1] - 129:4
Google [8] - 113:22,
124:9, 135:14,
135:18, 136:21,
141:22, 154:18,
154:22
Government [30] -
4:22, 4:23, 20:10,
20:18, 32:12, 35:21,
56:4, 92:6, 103:3,
107:19, 113:15,
169:24, 177:20,
177:22, 178:6,
178:11, 179:3,
180:15, 181:2, 181:9,
183:25, 187:12,
189:19, 218:5, 222:2,
222:19, 223:18,
227:21, 249:20,
249:21
Government's [153] -
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 266 of
283
7:18, 7:21, 8:17, 8:21,
13:19, 14:2, 14:3,
14:4, 14:7, 14:18,
15:6, 15:15, 16:1,
19:4, 19:15, 19:16,
19:17, 19:19, 28:25,
35:22, 36:3, 36:4,
36:5, 36:10, 40:22,
43:8, 43:15, 44:14,
46:6, 48:21, 48:22,
50:1, 50:13, 50:19,
50:22, 50:23, 51:4,
55:23, 58:7, 60:10,
60:11, 60:15, 60:21,
63:8, 63:19, 66:24,
67:15, 74:15, 78:6,
86:18, 89:8, 93:10,
93:21, 95:20, 96:21,
103:2, 107:19,
107:23, 108:10,
108:15, 108:22,
111:12, 111:14,
111:17, 111:19,
113:15, 113:18,
113:21, 114:23,
115:20, 115:21,
118:10, 118:11,
118:12, 118:13,
118:16, 119:6, 119:7,
119:21, 121:17,
121:24, 122:6,
123:11, 123:12,
123:13, 123:14,
123:15, 123:18,
124:7, 124:18, 126:2,
126:21, 127:14,
127:20, 128:2,
128:23, 129:17,
130:5, 130:22,
132:13, 132:22,
133:6, 133:11,
133:13, 133:19,
133:21, 135:11,
136:25, 137:15,
138:12, 140:14,
140:15, 140:17,
141:3, 142:20, 144:7,
145:8, 145:12,
145:14, 147:19,
147:22, 147:24,
148:18, 148:22,
148:24, 149:8,
149:15, 149:16,
149:17, 149:18,
150:5, 150:13, 151:7,
151:12, 151:13,
151:14, 151:21,
153:2, 154:2, 154:12,
154:13, 154:14,
155:7, 155:25,
157:19, 164:8,
165:22, 166:17,
170:19, 175:9,
178:22, 187:10, 246:8
gOVT [1] - 3:2
graduated [4] -
191:7, 191:23,
236:19, 240:12
graduating [2] -
192:1, 198:18
green [4] - 232:10,
232:19, 232:22, 233:3
grocery [2] - 217:7,
218:17
gross [1] - 97:4
ground [1] - 179:18
grounds [1] - 35:25
group [2] - 55:19,
106:5
guarantee [2] -
139:16, 218:2
guess [13] - 52:18,
71:14, 82:5, 104:24,
106:4, 125:12,
174:11, 175:1,
186:15, 191:17,
192:11, 193:1, 246:23
guessing [1] -
172:23
guidelines [1] -
18:13
guilt [1] - 187:13
guilty [3] - 187:7,
188:18
gun [2] - 26:19,
26:24
guy [3] - 92:11,
164:11, 215:15
guys [3] - 193:1,
200:5, 250:15
H
H-E-L-Y [1] - 5:8
H-E-R-N-A-N-D-E-Z
[1] - 32:22
hair [2] - 162:13,
225:5
half [3] - 158:2,
179:12, 195:14
hand [3] - 27:1, 56:3,
121:2
handed [2] - 205:3,
213:1
handful [1] - 23:13
handguns [1] -
194:19
handle [9] - 34:7,
205:4, 205:5, 213:12,
213:19, 213:20,
215:13, 235:18,
235:19
handled [2] - 206:2,
215:18
handling [1] - 26:15
hands [1] - 185:17
hands-down [1] -
185:17
hang [1] - 200:5
hard [3] - 194:6,
215:4, 215:24
head [5] - 31:18,
56:22, 57:1, 99:12,
205:12
headquartered [1] -
162:18
health [2] - 232:7,
232:8
hear [8] - 31:4, 31:7,
160:8, 178:9, 178:25,
179:3, 182:19, 223:3
heard [16] - 27:15,
30:17, 31:11, 31:16,
31:23, 32:1, 151:16,
151:17, 159:10,
167:6, 203:12, 208:6,
219:17, 219:25,
232:1, 250:13
hearsay [1] - 180:25
heart [1] - 215:19
heaven [1] - 247:23
heavy [1] - 199:3
hectic [1] - 196:24
heels [1] - 163:24
held [3] - 10:13,
109:19, 128:19
Hello [1] - 23:5
help [1] - 18:13
helpful [1] - 108:3
helps [1] - 120:10
Hely [12] - 4:7, 4:23,
5:8, 5:14, 8:3, 9:11,
14:6, 16:15, 17:7,
19:19, 22:12, 23:5
HELY [2] - 2:9, 4:25
hereby [1] - 252:3
HERNANDEZ [2] -
2:12, 32:14
Hernandez [7] -
32:12, 32:21, 33:5,
36:7, 36:9, 77:17,
77:24
hide [1] - 185:6
hiding [1] - 206:19
High [1] - 190:24
high [2] - 38:14,
190:23
higher [1] - 25:13
higher-ranking [1] -
25:13
highlight [12] - 9:11,
17:8, 37:13, 42:14,
48:23, 50:23, 51:5,
64:24, 79:3, 124:20,
142:21, 232:10
highlighted [8] -
14:19, 16:2, 51:2,
128:25, 129:13,
158:18, 232:19,
232:21
highlighter [1] -
233:5
highlighting [6] -
36:21, 56:8, 128:23,
142:22, 150:20,
156:22
hire [3] - 7:1, 9:17,
10:4
hired [4] - 10:7, 23:7,
23:10, 201:25
History [1] - 78:9
history [8] - 5:25,
8:10, 8:11, 9:14, 51:7,
58:2, 128:16, 153:18
hit [6] - 84:8, 120:21,
122:7, 206:7, 206:9,
207:24
hitting [1] - 88:20
hmm [3] - 48:9,
169:5, 171:22
HOH [1] - 99:11
hold [4] - 5:21, 91:2,
206:5, 232:11
holder [1] - 228:22
holding [1] - 6:6
Hollywood [2] -
44:24, 192:22
Holmes [2] - 29:7,
29:20
Home [2] - 70:12,
159:7
home [7] - 56:16,
65:17, 70:3, 70:13,
207:23, 218:20,
248:25
honest [5] - 208:11,
217:6, 235:3, 235:16,
248:19
honesty [5] - 202:6,
203:1, 209:19, 248:3,
248:9
Honor [77] - 4:12,
4:23, 7:18, 8:1, 8:16,
8:19, 8:23, 9:9, 13:18,
13:22, 19:3, 19:7,
19:11, 22:8, 22:21,
22:24, 27:22, 30:12,
32:4, 32:7, 35:24,
36:8, 49:13, 50:12,
50:15, 63:6, 77:15,
77:19, 77:22, 91:23,
15
92:5, 92:6, 92:23,
98:15, 98:16, 101:17,
101:18, 108:11,
137:5, 140:10,
140:12, 149:12,
149:13, 151:10,
159:19, 159:22,
177:1, 177:4, 177:15,
177:20, 178:8, 179:5,
179:14, 180:4,
180:17, 181:13,
184:1, 184:13, 186:7,
187:16, 187:25,
188:8, 189:4, 189:7,
189:11, 189:22,
190:13, 222:4, 222:8,
222:21, 224:7,
231:19, 232:23,
234:20, 246:1, 250:6,
251:1
HONORABLE [1] -
1:10
horrible [1] - 120:20
hostage [1] - 199:10
hour [1] - 158:2
hours [6] - 16:7,
16:21, 28:6, 137:17,
161:9, 171:14
house [3] - 83:15,
109:25, 209:5
household [2] -
99:12, 218:22
houses [2] - 198:6,
201:12
HR [2] - 7:13, 11:19
huge [1] - 24:8
human [7] - 6:5, 7:1,
7:4, 10:9, 30:20, 31:4,
31:16
Human [1] - 5:15
hundred [1] - 209:1
hung [1] - 200:6
hurting [1] - 209:2
hypothetically [1] -
48:10
I
i.e [1] - 18:6
ICT [1] - 238:16
ID [5] - 9:17, 9:18,
9:22, 42:5, 146:13
idea [5] - 202:10,
221:10, 231:20, 248:7
identical [1] - 84:7
identification [13] -
7:19, 13:18, 38:6,
40:13, 40:17, 179:4,
181:3, 184:9, 222:1,
222:18, 223:21,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 267 of
283
224:1, 224:3
Identification [2] -
7:22, 222:11
identified [6] - 8:17,
69:23, 156:21,
179:23, 183:12,
244:11
identifiers [1] -
106:18
identifies [2] -
109:23, 109:24
identify [5] - 117:14,
171:19, 178:11,
180:2, 180:6
identifying [4] -
108:7, 110:16,
178:10, 180:24
identity [4] - 179:7,
183:19, 203:4, 203:12
IDRS [1] - 72:25
ignorance [1] - 186:3
illegal [1] - 28:4
image [1] - 182:12
imagine [3] - 23:16,
26:15, 80:7
impact [3] - 15:9,
121:11, 122:2
impetus [1] - 52:17
implied [1] - 17:2
import [1] - 153:11
importance [3] -
26:12, 27:9, 243:25
important [6] - 26:9,
26:11, 132:25,
153:14, 188:23, 246:5
impression [1] -
205:2
improper [1] - 28:4
IN [1] - 9:7
in-depth [1] - 53:1
inaccurate [2] -
73:24, 83:2
inappropriate [1] -
30:9
Inc [6] - 39:6, 40:20,
46:3, 47:14, 58:14,
87:9
incident [6] - 192:18,
192:19, 193:19,
194:9, 194:11, 199:19
incidents [1] -
198:24
include [8] - 6:10,
21:9, 34:20, 34:23,
42:12, 49:6, 128:15,
128:18
included [9] - 72:4,
95:15, 106:14, 108:5,
108:6, 110:13,
110:20, 146:17, 246:9
includes [3] - 59:1,
145:23, 156:3
including [7] - 16:22,
35:25, 50:16, 58:20,
118:25, 145:4, 225:24
income [42] - 33:18,
36:15, 36:25, 37:10,
42:12, 42:15, 42:16,
44:6, 44:8, 45:1, 45:2,
45:13, 45:15, 47:19,
48:10, 48:15, 48:25,
53:1, 65:12, 65:13,
67:20, 70:15, 76:6,
84:4, 86:21, 97:3,
97:4, 97:14, 97:23,
108:5, 116:13,
116:15, 119:19,
134:7, 134:23,
134:24, 176:18,
198:7, 209:5, 211:4
Income [1] - 67:19
Incoming [1] - 157:5
incoming [4] - 143:7,
143:12, 143:18
incorporated [2] -
35:12, 175:21
incorrectly [1] -
202:10
increase [1] - 65:14
incurred [1] - 89:22
indebtedness [2] -
224:22, 226:5
independent [2] -
227:11, 228:15
indicate [7] - 10:3,
97:23, 100:5, 154:25,
174:10, 174:13,
174:17
indicated [4] - 77:1,
80:17, 121:8, 182:22
indicates [3] - 65:20,
86:20, 185:22
indicating [2] -
126:12, 136:11
indicted [2] - 183:16,
244:24
indictment [7] -
59:22, 60:1, 60:3,
60:5, 105:13, 183:19,
245:2
individual [13] -
7:15, 34:4, 35:3,
35:19, 36:14, 43:12,
46:8, 48:2, 85:22,
175:17, 175:20,
183:12, 201:6
individual's [1] -
106:18
individuals [4] -
105:25, 106:13,
159:15, 185:5
infer [1] - 186:11
inference [1] - 155:4
info [6] - 57:21, 95:8,
138:19, 153:24,
153:25, 223:9
inform [2] - 86:1,
229:10
informally [1] - 27:2
Informant [1] - 6:22
information [84] -
9:16, 11:15, 11:16,
17:23, 30:19, 34:5,
34:6, 40:3, 41:10,
41:18, 49:9, 54:16,
58:16, 58:18, 59:1,
59:4, 60:18, 61:16,
61:17, 61:25, 65:15,
65:16, 93:14, 93:16,
93:20, 95:10, 95:17,
99:18, 105:22,
105:24, 106:8,
106:20, 106:24,
106:25, 107:15,
107:18, 108:3, 108:7,
109:8, 109:18,
110:13, 110:17,
113:22, 113:25,
114:3, 115:9, 115:16,
117:2, 123:21, 124:4,
124:9, 124:24,
128:16, 131:10,
132:5, 132:9, 132:10,
140:19, 141:21,
145:4, 146:16,
146:17, 152:24,
162:11, 172:16,
173:21, 174:10,
182:5, 182:9, 184:23,
201:18, 201:19,
203:6, 203:7, 203:9,
203:11, 203:14,
213:3, 213:10,
213:13, 213:23,
217:16, 245:16, 246:6
informational [1] -
227:18
informed [3] - 12:25,
13:2, 25:24
initial [14] - 56:1,
111:3, 127:1, 127:3,
133:1, 135:25,
160:22, 167:23,
175:10, 176:5,
178:18, 183:13,
183:15, 217:19
initiated [3] - 88:17,
168:22, 210:6
insight [1] - 139:20
Inspector [2] -
103:18, 104:3
installment [3] -
72:22, 74:5, 88:17
instance [13] - 9:2,
25:23, 26:18, 37:18,
39:4, 45:17, 47:4,
49:11, 54:1, 66:19,
147:16, 169:15,
179:15
instant [2] - 126:15,
127:7
instead [2] - 24:11,
127:18
instructed [1] -
186:7
instruction [2] -
59:13, 186:4
instructions [5] -
54:14, 139:18,
184:15, 249:11,
250:23
insurance [2] -
232:7, 232:8
intended [1] - 235:12
intent [6] - 59:25,
186:15, 186:16,
186:21, 186:24, 187:9
intention [1] - 188:6
intentional [1] -
82:10
interact [3] - 26:2,
87:22, 173:4
interacts [1] - 172:24
interest [15] - 68:7,
68:21, 90:3, 90:4,
90:5, 90:8, 90:11,
95:15, 147:8, 157:15,
220:11, 225:14,
225:19, 225:21
Internal [1] - 33:6
internal [3] - 109:11,
172:23, 173:1
International [3] -
10:16, 192:17, 238:14
Internet [5] - 70:2,
109:10, 109:20,
109:24, 110:22
interrupted [1] -
59:11
interview [13] - 53:2,
54:18, 54:25, 55:1,
55:6, 56:1, 56:3, 56:6,
56:9, 94:22, 172:16,
173:19, 244:22
interviewing [1] -
54:13
interviews [1] - 53:3
introduce [2] -
35:22, 242:13
introduced [2] -
16
114:23, 132:14
Introduction [1] -
237:1
intuitive [1] - 46:21
investigate [3] -
103:21, 104:9, 106:6
investigated [1] -
104:22
investigating [2] -
170:12, 172:11
investigation [21] -
88:7, 105:12, 105:17,
107:7, 108:4, 110:20,
114:19, 117:7, 117:8,
119:25, 124:13,
131:25, 139:23,
141:4, 148:11,
157:14, 158:23,
159:14, 173:5,
181:21, 219:8
investigations [4] -
104:4, 104:6, 172:25,
238:4
investigative [1] -
118:24
investigator [2] -
172:15, 173:15
investing [2] - 126:4,
126:23
involved [7] - 11:19,
86:1, 105:12, 105:17,
185:14, 201:21, 205:2
IP [21] - 108:21,
109:8, 109:20, 110:1,
110:2, 110:7, 110:15,
110:22, 111:4, 111:6,
111:11, 112:14,
112:20, 112:21,
113:6, 113:8, 113:9,
113:11, 163:7,
163:21, 176:13
iPhone [6] - 134:14,
135:9, 135:10,
152:15, 233:14, 234:4
IRS [60] - 33:25,
34:10, 34:16, 38:2,
38:7, 41:5, 49:9, 50:7,
50:9, 57:16, 58:11,
68:3, 68:11, 71:11,
76:5, 78:16, 78:22,
79:12, 80:8, 85:23,
87:22, 88:24, 91:11,
95:12, 100:11, 104:4,
104:6, 114:22, 116:7,
116:10, 116:22,
116:24, 117:4, 119:1,
122:1, 132:4, 132:12,
132:20, 149:24,
157:24, 158:20,
185:25, 187:2,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 268 of
283
204:15, 205:1,
205:13, 207:3,
207:12, 207:13,
208:4, 220:12,
245:13, 245:15,
246:25, 247:1,
247:17, 247:21,
248:5, 248:16, 248:18
IRS's [1] - 33:16
IRS-filed [2] -
116:24, 117:4
ISP [1] - 110:22
issuance [1] - 12:22
issue [18] - 35:19,
65:23, 70:13, 71:5,
107:3, 117:18,
178:21, 179:4,
179:20, 183:22,
184:9, 188:22, 200:7,
200:8, 202:5, 202:7,
203:5, 205:12
issued [18] - 89:9,
107:1, 107:16,
109:10, 109:14,
109:18, 110:10,
110:14, 110:16,
111:1, 112:1, 115:10,
115:11, 117:11,
117:16, 117:18,
123:1, 167:8
issues [9] - 26:3,
53:14, 65:12, 65:14,
184:3, 188:23,
203:13, 247:6, 248:12
issuing [2] - 121:7,
172:13
item [2] - 202:19
itemized [4] - 37:6,
61:10, 63:13, 97:4
items [1] - 125:14
itself [5] - 106:15,
108:25, 111:4,
142:16, 145:24
J
J-O-H-N-S-O-N [1] -
103:13
January [23] - 54:21,
54:23, 64:25, 65:9,
66:3, 66:13, 67:1,
69:12, 72:2, 76:17,
80:20, 80:21, 80:22,
118:3, 119:11,
119:19, 119:23,
129:5, 134:22,
138:16, 141:6, 209:8,
247:18
Jersey [2] - 162:18,
162:20
Jesus [2] - 46:1, 57:3
Joana [3] - 4:7, 4:23,
5:8
JOANA [2] - 2:9,
4:25
job [8] - 10:6, 10:12,
25:23, 80:6, 180:21,
193:11, 193:15,
241:16
jobs [3] - 104:7,
193:17, 197:23
JOHNSON [3] - 2:14,
103:7, 181:17
Johnson [19] -
103:4, 103:13,
103:17, 113:20,
118:15, 123:17,
131:13, 140:17,
158:16, 160:3,
177:10, 179:22,
180:5, 180:23,
181:12, 181:19,
181:20, 243:20
Join [1] - 227:17
join [1] - 239:14
joining [1] - 238:1
joint [1] - 99:8
JONES [103] - 1:13,
4:7, 4:10, 32:12, 33:2,
35:21, 36:6, 49:13,
49:17, 49:18, 50:12,
50:21, 59:7, 59:10,
60:8, 60:9, 61:23,
63:6, 63:7, 77:15,
77:16, 92:5, 92:23,
93:2, 98:15, 101:18,
101:21, 102:13,
103:3, 103:16,
108:11, 108:14,
111:13, 111:18,
113:15, 113:19,
118:1, 118:3, 118:6,
118:8, 118:14, 123:5,
123:7, 123:16,
133:12, 133:15,
133:20, 137:9, 140:3,
140:6, 140:8, 140:10,
140:16, 145:13,
147:23, 148:18,
148:23, 149:12,
149:19, 151:7,
151:10, 151:15,
154:2, 154:4, 154:6,
154:9, 154:15,
158:14, 158:15,
159:19, 177:7, 177:9,
177:15, 177:20,
179:5, 179:14,
179:19, 179:22,
180:4, 180:9, 181:12,
181:18, 182:24,
183:6, 183:21, 184:1,
184:13, 212:4, 212:6,
222:4, 222:20,
223:19, 224:6, 236:9,
245:23, 245:25,
246:3, 249:22, 250:2,
250:6, 250:11,
250:19, 251:2
Jones [3] - 2:12,
63:5, 220:9
jones [1] - 2:15
judge [1] - 188:18
Judge [1] - 4:15
JUDGE [1] - 1:11
judgment [4] - 178:9,
179:17, 184:9, 187:14
June [8] - 1:5, 10:5,
23:7, 125:3, 192:10,
214:19, 237:23,
241:15
jurisdiction [1] -
104:9
juror [1] - 4:4
jurors [3] - 184:8,
249:1, 249:7
JURY [1] - 1:10
jury [52] - 4:16, 4:17,
4:18, 8:22, 11:11,
14:22, 16:2, 18:3,
21:4, 33:11, 33:21,
55:25, 56:9, 59:12,
62:18, 62:19, 62:24,
62:25, 63:1, 102:19,
102:22, 102:23,
106:4, 109:23, 158:5,
158:7, 158:8, 158:9,
177:21, 177:24,
178:2, 178:6, 181:4,
181:5, 181:8, 184:3,
184:4, 184:14, 186:7,
186:12, 187:6,
188:19, 189:12,
189:14, 189:15,
190:18, 249:3,
249:10, 250:16,
250:17, 250:22,
250:24
jury's [1] - 116:10
justice [1] - 104:17
Justice [4] - 191:11,
236:24, 237:1, 237:22
K
Kampmeyer [4] -
51:15, 74:22, 74:23,
81:18
keep [12] - 6:8,
49:15, 49:16, 66:9,
92:16, 99:11, 109:16,
160:7, 160:15,
214:25, 218:16,
227:14
Keller [3] - 20:3,
20:17, 20:24
kept [6] - 7:11,
33:16, 34:11, 50:6,
203:10, 215:1
kid's [2] - 213:5,
215:16
kids [4] - 196:21,
215:9, 218:24, 235:10
kids' [1] - 203:6
kind [9] - 38:4,
105:10, 152:4,
183:15, 191:15,
199:4, 205:14,
211:22, 229:25
kinds [1] - 26:6
knowing [1] - 244:23
knowingly [1] -
187:8
knowledge [17] -
10:9, 39:12, 75:11,
80:13, 96:3, 174:9,
180:24, 180:25,
186:2, 186:5, 186:18,
186:24, 207:2,
217:16, 217:22,
246:4, 248:6
known [5] - 104:24,
110:19, 199:22,
199:23, 217:25
Kuker [1] - 29:7
L
labeled [2] - 37:14,
73:7
lack [3] - 137:5,
192:2, 230:21
lady [2] - 162:13,
225:4
land [1] - 168:22
landscaper [1] - 25:7
landscapers [2] -
30:6, 197:15
lapel [1] - 23:20
large [2] - 24:7,
147:16
last [12] - 5:7, 32:20,
47:16, 63:19, 95:5,
103:12, 150:23,
156:23, 157:6,
157:11, 179:11, 190:8
lasts [1] - 157:4
late [3] - 4:5, 214:22
Latin [1] - 243:2
Lauderdale [8] -
17
1:15, 1:22, 42:8,
141:17, 192:17,
192:21, 238:14
laundering [1] -
104:11
lavalliere [1] - 23:22
Law [5] - 1:21, 10:8,
237:4, 237:7
law [31] - 10:10,
10:14, 16:25, 17:2,
30:2, 34:6, 76:1, 76:3,
80:10, 80:11, 80:14,
100:12, 104:25,
105:6, 106:9, 125:22,
154:24, 159:1,
172:24, 173:4, 182:7,
191:17, 192:3, 197:3,
197:11, 197:13,
197:20, 203:2, 203:7,
241:16, 241:25
lawfully [1] - 176:16
lawn [1] - 18:6
laws [4] - 104:9,
238:20, 238:25, 239:2
lawyer [1] - 88:2
lay [2] - 147:7,
160:11
layman's [1] - 33:15
lead [2] - 65:11,
70:14
leading [1] - 212:4
learn [4] - 111:5,
111:8, 158:23, 161:13
learned [8] - 80:3,
85:1, 100:9, 100:10,
202:9, 206:15,
208:19, 220:4
learns [2] - 100:14,
180:21
lease [1] - 45:7
least [5] - 38:17,
178:18, 178:22, 196:2
leave [4] - 57:24,
152:15, 201:2, 222:12
left [13] - 5:5, 9:19,
62:19, 63:8, 63:20,
64:2, 102:19, 136:25,
158:5, 178:2, 184:4,
189:19, 249:3
leftover [1] - 215:8
legal [4] - 146:20,
175:12, 177:23,
204:17
legislative [1] -
24:24
legit [1] - 219:21
legitimate [2] - 16:5,
27:19
legitimately [2] -
176:17, 176:22
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 269 of
283
lender [8] - 106:18,
106:25, 107:15,
108:2, 147:6, 147:12,
227:18, 228:7
length [1] - 143:5
less [6] - 195:10,
209:13, 209:16,
217:6, 218:19, 225:15
letter [28] - 57:5,
66:13, 66:14, 66:15,
66:17, 66:19, 66:21,
66:25, 67:2, 67:12,
71:4, 71:25, 72:2,
74:6, 74:10, 74:11,
76:5, 88:8, 89:18,
96:10, 205:19,
205:21, 205:22,
247:17
letters [3] - 17:17,
100:16, 207:15
level [3] - 27:8,
71:14, 97:10
levels [1] - 26:12
liabilities [1] -
247:21
license [7] - 119:1,
180:9, 182:1, 182:2,
182:5, 192:3, 197:25
licenses [3] - 21:13,
42:22, 65:14
lie [2] - 215:21,
235:12
lied [2] - 209:20,
215:22
Lieutenant [3] - 29:6,
29:7, 29:19
lieutenant [1] - 25:17
life [1] - 244:24
light [1] - 187:12
likewise [4] - 61:4,
62:5, 98:5, 138:11
limited [8] - 54:5,
54:10, 59:14, 59:19,
59:23, 94:12, 110:24,
180:16
limits [1] - 90:24
line [29] - 10:3, 37:4,
41:9, 42:24, 43:2,
43:3, 44:7, 45:9,
49:14, 68:14, 68:24,
89:11, 97:18, 126:4,
126:23, 130:6,
132:18, 133:25,
134:18, 136:12,
137:25, 138:13,
143:10, 148:2, 153:9,
155:10, 202:19
lines [3] - 10:12,
128:24, 144:3
linking [1] - 184:25
list [3] - 143:7, 223:2,
223:5
listed [38] - 39:20,
41:25, 42:5, 42:16,
42:20, 44:4, 44:17,
45:5, 45:25, 47:9,
47:25, 48:25, 51:8,
52:16, 56:2, 60:19,
61:1, 61:9, 61:10,
62:11, 63:10, 93:14,
94:5, 97:16, 106:17,
109:6, 115:6, 115:24,
116:13, 116:15,
116:21, 117:12,
129:11, 140:24,
146:21, 157:2,
171:12, 176:24
listen [2] - 188:22,
189:1
listing [1] - 60:15
lists [12] - 44:19,
49:3, 115:23, 123:20,
124:25, 125:10,
128:20, 146:18,
146:19, 146:24
live [3] - 182:10,
209:5, 227:17
living [2] - 158:25,
209:3
LLC [5] - 42:2, 43:6,
44:18, 115:7, 115:22
loan [97] - 107:2,
107:9, 107:10,
107:12, 107:17,
108:16, 108:25,
113:10, 114:6, 114:8,
116:2, 116:16,
116:19, 117:3,
117:12, 120:4, 122:7,
131:14, 131:19,
132:15, 133:2,
135:21, 139:4,
139:13, 139:19,
140:23, 144:13,
145:3, 145:24, 146:8,
146:16, 146:23,
146:25, 147:7,
152:25, 153:7,
155:11, 155:18,
157:16, 157:24,
158:21, 159:15,
160:18, 167:15,
167:23, 168:4, 168:9,
176:2, 176:5, 184:22,
185:20, 185:22,
185:23, 187:3, 210:3,
210:5, 210:7, 210:14,
210:15, 210:17,
211:7, 212:14,
212:15, 212:22,
213:25, 214:7,
215:25, 216:8,
216:14, 216:18,
217:20, 217:23,
217:25, 218:2,
218:10, 219:1,
219:15, 220:9,
220:20, 221:1,
224:25, 225:10,
226:25, 227:13,
227:15, 227:25,
228:17, 228:18,
229:13, 229:21,
230:23, 231:7,
247:14, 247:16,
247:23, 248:2, 248:20
loans [12] - 106:12,
106:13, 139:16,
159:18, 216:10,
216:22, 227:17,
228:12, 228:17,
228:19, 228:23, 232:2
local [1] - 137:16
locate [1] - 18:23
location [3] - 10:18,
109:24, 110:1
log [8] - 132:9,
132:18, 133:1,
135:25, 153:16,
155:5, 156:1, 164:4
log-in [1] - 155:5
login [7] - 137:1,
153:24, 161:1,
167:17, 167:18,
223:1, 223:9
logins [4] - 141:11,
142:10, 163:8, 163:21
loginvcredentials
[1] - 164:1
logs [2] - 64:10,
140:25
longtime [3] - 243:6,
244:12, 244:13
look [9] - 29:5,
60:24, 68:5, 155:22,
165:16, 166:12,
166:25, 193:8, 227:22
looked [2] - 165:2,
235:19
looking [24] - 9:13,
10:2, 37:15, 48:21,
79:5, 85:4, 85:7,
85:24, 86:5, 86:10,
87:2, 108:23, 113:4,
119:22, 133:22,
141:8, 141:10, 142:8,
142:10, 150:13,
164:17, 198:3,
233:22, 237:20
looks [26] - 29:5,
29:8, 29:19, 76:25,
80:22, 81:24, 113:4,
122:16, 125:1, 129:8,
129:15, 130:14,
130:16, 134:5, 135:2,
138:1, 145:24, 152:1,
152:9, 152:13,
152:16, 152:17,
165:2, 165:10, 193:7,
233:14
loose [1] - 246:4
loss [11] - 37:3, 43:3,
43:4, 44:8, 44:9,
45:11, 45:17, 48:7,
48:14, 114:13
losses [5] - 35:10,
45:12, 48:5, 48:8,
48:11
lost [3] - 43:6, 48:16,
91:4
Louis [72] - 40:5,
40:18, 53:11, 54:16,
54:17, 55:13, 56:12,
57:2, 74:1, 75:9,
75:14, 75:16, 75:22,
75:24, 79:6, 82:15,
83:2, 88:6, 90:19,
90:24, 95:4, 95:23,
96:6, 96:7, 99:3,
101:25, 102:2,
105:15, 110:20,
111:10, 112:13,
112:22, 113:7, 114:3,
132:12, 138:14,
138:17, 141:12,
149:4, 150:8, 150:23,
152:7, 155:6, 156:7,
156:10, 157:7,
157:23, 158:20,
175:19, 176:14,
179:8, 185:1, 185:8,
185:16, 199:17,
199:22, 209:12,
210:10, 210:13,
215:13, 231:9,
232:14, 241:21,
241:23, 241:25,
242:13, 243:6,
244:11, 246:16,
246:24, 247:20,
248:10
Louis's [2] - 141:13,
163:14
LOVE [22] - 1:17,
4:12, 4:23, 5:11, 7:18,
7:24, 8:1, 8:2, 8:16,
8:22, 9:9, 9:10, 13:18,
14:5, 19:3, 19:10,
19:18, 22:8, 22:11,
22:21, 32:3, 32:7
18
Love [1] - 2:10
lower [1] - 45:15
lowered [1] - 138:19
lozenges [1] - 74:16
luncheon [1] -
102:17
M
Ma'am [1] - 32:9
machine [1] - 216:23
mail [14] - 38:7, 52:7,
67:13, 69:9, 114:1,
153:24, 153:25,
154:21, 155:2, 155:5,
164:1, 173:25,
178:19, 223:9
mailed [8] - 66:15,
66:17, 67:2, 67:12,
69:9, 74:9, 219:22,
242:6
main [1] - 106:10
maintain [5] - 6:13,
8:25, 10:22, 21:12,
197:25
maintained [5] - 6:3,
6:22, 8:13, 13:13,
79:12
maintaining [2] -
5:25, 6:1
maintenance [2] -
45:8, 97:20
Major [1] - 29:7
major [1] - 29:20
majored [1] - 236:24
management [1] -
16:8
manager [3] - 5:22,
55:20, 66:13
managing [1] - 5:24
Manatee [1] - 236:13
manatee [1] - 236:18
manna [1] - 247:23
manual [9] - 6:19,
6:24, 7:2, 10:19, 11:4,
14:15, 15:23, 21:19,
23:10
manuals [2] - 6:13,
6:16
March [20] - 71:18,
72:8, 72:14, 73:4,
73:13, 74:20, 75:5,
100:25, 102:10,
149:2, 150:8, 150:16,
150:22, 152:1, 152:9,
226:16, 226:18,
226:20, 227:17,
227:21
marital [1] - 123:23
Maritza [1] - 159:11
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 270 of
283
mark [2] - 7:19,
223:15
marked [8] - 7:21,
19:3, 50:13, 55:22,
157:18, 221:24,
222:11, 222:18
market [1] - 216:13
marketing [1] -
216:16
marks [1] - 191:8
marksmanship [1] -
196:9
marriage [3] - 65:16,
65:20
married [9] - 75:25,
76:1, 76:3, 79:19,
99:8, 99:12, 196:19,
196:20
mass [1] - 192:21
master [1] - 123:20
Master's [1] - 104:18
match [1] - 75:20
matched [3] - 63:10,
93:16, 93:20
matches [1] - 163:10
matching [1] - 62:12
material [1] - 132:15
materially [1] -
227:23
materials [1] -
245:10
math [1] - 69:5
matter [12] - 75:15,
96:7, 126:22, 139:2,
139:12, 144:12,
148:25, 149:3, 149:5,
205:12, 215:19, 252:5
matters [4] - 125:20,
177:23, 240:20,
248:23
meals [2] - 42:23,
45:9
mean [31] - 14:25,
18:10, 37:2, 83:22,
87:15, 89:12, 89:15,
97:9, 144:1, 162:7,
165:1, 165:3, 169:12,
169:14, 171:1, 171:9,
175:1, 175:5, 179:13,
180:20, 203:6,
203:12, 204:13,
208:15, 218:12,
220:14, 223:6,
226:22, 250:10,
250:14
meaning [2] - 82:9,
203:2
means [5] - 81:1,
89:16, 110:4, 241:13,
243:4
meant [3] - 52:17,
208:16, 235:1
Medina [2] - 46:1,
57:3
meet [9] - 152:10,
200:23, 201:5, 204:8,
204:10, 209:22,
213:24, 243:13,
244:18
meeting [11] - 151:4,
151:6, 209:24, 243:9,
243:25, 244:14,
244:17, 245:22,
245:23, 245:24,
245:25
member [1] - 239:25
members [5] - 16:18,
16:22, 59:12, 177:21,
181:8
memorialize [1] -
79:13
memorialized [3] -
79:17, 90:14, 100:19
memory [1] - 172:9
mental [1] - 239:23
mentally [1] - 240:3
mention [4] - 203:5,
218:6, 218:9, 218:15
mentioned [22] -
20:6, 40:6, 49:19,
69:9, 71:7, 88:10,
90:18, 96:18, 107:14,
108:21, 110:10,
121:18, 124:3, 167:5,
169:3, 175:13,
196:19, 202:25,
205:6, 205:18,
236:12, 248:10
message [9] - 64:2,
145:1, 149:22, 150:2,
155:12, 157:21,
159:6, 233:25, 234:2
messages [1] -
242:8
messed [1] - 236:3
met [2] - 245:1,
246:25
MFJ [1] - 99:7
MFS [1] - 99:11
MIAMI [1] - 1:2
Miami [7] - 1:4, 1:18,
2:4, 2:4, 190:22,
252:9, 252:10
mic [3] - 23:20,
160:6, 190:12
microphone [5] -
5:5, 23:20, 23:22,
190:7
might [6] - 25:16,
28:12, 28:19, 30:25,
207:17, 208:20
mileage [12] - 64:9,
64:16, 80:3, 80:11,
84:16, 84:20, 91:17,
100:10, 100:16,
201:10, 201:12, 208:3
miles [2] - 194:18,
196:2
military [1] - 126:9
Miller [1] - 55:20
mind [5] - 59:24,
92:18, 131:18, 172:8,
208:13
minimal [3] - 205:11,
207:18, 248:1
minimize [1] - 205:9
minimized [3] -
207:17, 209:15,
247:16
minimizing [1] -
202:11
minor [2] - 104:17,
207:19
minute [4] - 156:25,
157:1, 157:4, 197:2
minutes [21] - 4:5,
62:15, 62:17, 62:23,
125:12, 127:1, 127:3,
129:21, 129:24,
130:3, 130:4, 143:18,
158:3, 171:14,
177:24, 187:21,
187:23, 187:24,
188:1, 202:24, 242:10
miscellaneous [2] -
56:14, 114:12
miss [4] - 8:3, 33:5,
206:8, 206:9
missed [2] - 73:23,
195:9
missing [4] - 4:4,
29:20, 64:20, 195:5
mistake [8] - 60:6,
84:10, 99:24, 100:1,
207:19, 223:7, 236:4,
248:9
mistaken [2] -
100:15
mistakes [2] - 153:3,
248:18
misuse [1] - 105:11
mobile [2] - 120:15,
140:19
modified [1] - 70:15
moment [11] - 22:8,
77:15, 84:14, 116:5,
177:1, 194:5, 195:15,
199:14, 216:24,
234:20, 247:24
moments [1] - 167:1
Monday [1] - 53:16
money [30] - 48:3,
68:11, 104:11,
120:12, 122:7, 122:8,
122:18, 129:22,
130:19, 148:6,
169:14, 170:9,
170:10, 171:1,
185:25, 205:18,
205:22, 209:2,
211:10, 216:21,
220:12, 221:3, 221:6,
221:12, 221:20,
230:5, 230:10,
230:22, 234:10, 235:1
monies [1] - 35:5
Monsignor [1] -
190:24
month [4] - 88:11,
121:18, 135:5, 159:8
monthly [3] - 89:1,
146:23, 153:15
morning [12] - 4:20,
5:12, 5:13, 23:3, 23:4,
23:6, 33:3, 33:4,
62:14, 77:24, 77:25,
152:15
mortgage [1] -
207:23
most [7] - 9:25,
187:12, 188:23,
194:23, 198:4, 239:2,
239:7
mother [1] - 65:17
motion [4] - 8:25,
178:8, 184:8, 187:14
motions [1] - 178:7
motivated [1] -
185:23
motive [1] - 60:1
move [20] - 5:5, 8:16,
13:20, 19:5, 28:2,
35:22, 37:12, 39:7,
50:12, 86:16, 111:13,
119:21, 151:10,
153:2, 179:20, 184:3,
222:8, 222:21,
223:20, 224:7
moved [1] - 179:17
moves [1] - 113:15
moving [15] - 10:12,
15:7, 15:15, 17:6,
17:16, 18:7, 20:10,
20:18, 37:8, 44:4,
147:19, 164:7, 193:9,
198:9
MR [226] - 4:7, 4:10,
4:12, 4:23, 5:11, 7:18,
7:24, 8:1, 8:2, 8:16,
8:19, 8:22, 8:23, 9:9,
19
9:10, 13:18, 13:22,
14:5, 19:3, 19:7,
19:10, 19:11, 19:18,
22:8, 22:11, 22:21,
22:24, 23:2, 23:21,
23:23, 24:1, 27:24,
28:1, 30:12, 30:15,
32:3, 32:7, 32:12,
33:2, 35:21, 35:24,
36:6, 49:13, 49:17,
49:18, 50:12, 50:15,
50:21, 59:7, 59:10,
60:8, 60:9, 61:21,
61:23, 63:7, 77:15,
77:16, 77:22, 83:21,
83:23, 91:23, 91:25,
92:5, 92:6, 92:10,
92:13, 92:17, 92:21,
92:23, 93:2, 98:15,
98:16, 98:20, 98:22,
101:18, 101:21,
102:13, 103:3,
103:16, 108:11,
108:14, 111:13,
111:18, 113:13,
113:15, 113:19,
118:1, 118:2, 118:3,
118:4, 118:6, 118:8,
118:14, 123:5, 123:6,
123:7, 123:8, 123:16,
133:8, 133:12,
133:15, 133:17,
133:20, 137:5, 137:7,
137:9, 140:3, 140:4,
140:6, 140:7, 140:8,
140:10, 140:11,
140:16, 145:10,
145:13, 147:20,
147:23, 148:18,
148:20, 148:23,
149:10, 149:12,
149:13, 149:19,
151:7, 151:9, 151:10,
151:15, 154:3, 154:4,
154:5, 154:6, 154:7,
154:9, 154:10,
154:15, 158:14,
158:15, 159:19,
159:22, 160:2, 160:7,
160:10, 177:1, 177:3,
177:7, 177:9, 177:15,
177:20, 178:8, 179:1,
179:5, 179:14,
179:19, 179:22,
180:4, 180:9, 180:17,
180:23, 181:12,
181:18, 182:19,
182:24, 183:2, 183:6,
183:21, 183:23,
184:1, 184:13,
187:16, 187:21,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 271 of
283
187:25, 188:2, 188:8,
189:22, 190:13,
190:15, 193:10,
212:4, 212:6, 212:8,
221:22, 222:4, 222:5,
222:7, 222:14,
222:20, 222:21,
222:25, 223:3, 223:6,
223:10, 223:13,
223:15, 223:17,
223:19, 223:20,
223:25, 224:6, 224:7,
224:10, 224:13,
224:15, 224:17,
231:16, 231:19,
232:23, 232:25,
233:10, 234:16,
234:22, 235:14,
236:6, 236:9, 245:23,
245:25, 246:3,
249:15, 249:19,
249:22, 250:2, 250:6,
250:11, 250:19, 251:2
multiple [3] - 200:24,
206:12, 242:16
mumble [1] - 194:10
must [12] - 21:23,
26:16, 31:6, 59:20,
64:9, 70:24, 71:23,
80:7, 99:7, 169:8,
172:22, 177:13
mutual [1] - 218:21
N
nails [1] - 218:18
name [28] - 5:7, 20:3,
32:19, 32:20, 32:21,
39:4, 40:4, 40:18,
46:2, 47:13, 51:12,
103:12, 109:1, 115:6,
118:18, 120:25,
140:20, 146:18,
146:20, 175:12,
175:13, 175:21,
190:8, 190:9, 212:24
named [2] - 179:8,
183:19
names [1] - 29:5
nature [6] - 73:22,
112:19, 128:18,
145:15, 185:15,
199:11
necessarily [1] -
28:10
necessary [3] -
55:14, 59:25, 65:23
need [24] - 8:23,
11:7, 12:1, 12:21,
13:3, 13:4, 17:19,
18:14, 18:18, 23:20,
27:7, 38:9, 38:12,
59:8, 66:10, 76:1,
138:19, 152:20,
177:22, 186:16,
194:5, 204:3, 216:8
needed [12] - 15:1,
38:3, 58:1, 75:24,
87:10, 88:10, 173:9,
199:5, 202:2, 204:16,
212:25, 246:15
needs [6] - 11:18,
12:4, 27:6, 53:15,
64:9, 151:25
negative [2] - 37:1,
37:2
nervous [1] - 160:14
net [2] - 128:5, 128:9
never [38] - 31:25,
80:3, 84:23, 85:1,
90:3, 90:5, 92:18,
100:9, 100:10,
173:10, 179:7, 200:6,
202:5, 202:7, 202:25,
203:4, 203:13,
203:18, 209:20,
212:12, 212:13,
215:22, 215:23,
216:1, 218:4, 219:19,
219:25, 221:14,
233:8, 235:1, 235:5,
235:6, 235:12,
235:13, 235:20,
247:16
New [4] - 136:22,
162:18, 162:20,
227:15
new [26] - 5:24, 7:1,
12:3, 12:4, 12:22,
15:11, 15:12, 15:19,
15:20, 23:9, 53:11,
54:14, 65:7, 65:12,
65:14, 65:22, 71:5,
150:24, 154:21,
154:23, 215:15,
227:11, 228:3, 228:15
new-hire [1] - 7:1
news [2] - 50:25,
152:3
next [41] - 4:6, 12:9,
15:3, 28:13, 32:11,
39:8, 53:6, 55:3,
55:14, 55:17, 65:8,
66:12, 69:11, 70:9,
73:3, 97:19, 103:2,
105:22, 106:24,
119:21, 130:5, 140:5,
142:25, 143:3, 144:9,
144:13, 145:5,
156:25, 157:1,
168:15, 168:17,
177:19, 178:10,
182:17, 182:21,
204:11, 204:24,
214:2, 226:12, 249:6
nine [2] - 104:5,
199:25
NO [1] - 1:2
nobody [1] - 217:6
none [1] - 157:5
nonprofit [2] - 16:24,
21:10
nonresponsive [1] -
109:15
noon [1] - 53:19
normal [4] - 16:7,
79:13, 193:3, 212:2
normally [3] -
195:22, 201:17, 217:8
North [2] - 2:4, 252:9
Northwest [6] - 42:8,
44:24, 46:16, 51:19,
67:5, 225:8
notable [1] - 125:8
notated [1] - 100:21
notation [1] - 84:25
Note [1] - 18:2
note [14] - 18:4, 73:1,
79:5, 81:12, 101:15,
145:23, 145:25,
147:5, 147:6, 213:1,
226:13, 226:23,
227:20
noted [1] - 138:3
notes [16] - 56:1,
66:7, 79:10, 81:22,
82:6, 82:14, 84:11,
84:12, 84:19, 88:19,
90:13, 90:18, 90:22,
94:19, 101:24, 146:3
nothing [11] - 28:4,
30:9, 92:1, 101:17,
173:18, 177:3,
183:21, 236:6, 241:8,
245:18
notice [4] - 87:25,
122:8, 203:21, 203:24
noticed [2] - 75:17,
96:8
notices [2] - 88:3,
207:2
notified [1] - 105:19
november [1] - 252:7
November [4] -
127:23, 134:6,
198:11, 198:12
nuggets [1] - 129:4
number [69] - 9:17,
9:18, 9:22, 17:13,
17:15, 17:17, 17:24,
21:7, 21:24, 22:4,
24:4, 24:16, 37:5,
37:8, 38:6, 39:2,
40:10, 40:13, 40:17,
42:3, 42:5, 44:19,
44:20, 46:12, 51:20,
52:5, 54:20, 58:23,
68:5, 68:7, 85:21,
97:18, 108:8, 110:5,
123:22, 125:19,
140:20, 140:22,
141:7, 141:13,
141:15, 141:16,
141:18, 141:19,
141:22, 141:25,
142:1, 142:2, 142:3,
142:5, 146:21,
156:10, 156:13,
156:15, 156:19,
156:20, 178:12,
178:13, 191:23,
213:5, 213:6, 224:25,
231:21, 232:13,
242:2, 242:4
numbers [23] -
36:20, 38:23, 85:22,
97:6, 99:17, 138:22,
146:10, 150:3,
156:18, 201:20,
201:23, 216:3,
217:22, 218:1, 219:2,
219:14, 219:23,
221:10, 231:22,
248:5, 248:7, 248:16
O
o'clock [5] - 187:19,
248:22, 248:24,
249:1, 250:23
oath [1] - 181:15
object [6] - 9:2,
13:23, 19:12, 180:17,
180:19, 180:23
objection [47] - 8:19,
9:1, 9:4, 14:1, 19:12,
19:13, 35:23, 35:25,
61:21, 113:14, 118:2,
118:4, 123:6, 123:8,
123:9, 133:9, 133:16,
133:17, 137:5, 140:4,
140:12, 145:10,
147:20, 148:20,
149:10, 149:13,
151:8, 151:9, 154:3,
154:5, 154:7, 154:10,
180:15, 183:2, 212:4,
212:6, 222:2, 222:4,
222:19, 222:20,
223:18, 223:19,
224:5, 224:6
20
objections [5] -
13:23, 36:2, 50:16,
50:18, 179:2
objects [1] - 193:9
obtain [8] - 21:12,
106:20, 114:19,
117:7, 117:10, 124:4,
139:24, 181:22
obtained [7] - 41:11,
41:14, 95:17, 113:24,
114:1, 124:4, 242:2
obtaining [1] - 182:3
obviously [2] -
189:1, 199:19
occupation [2] -
39:20, 44:2
occurred [5] - 10:20,
111:2, 123:24,
128:21, 199:20
October [9] - 65:6,
165:8, 198:11,
224:10, 224:11,
224:13, 231:12,
231:13, 231:15
odometer [1] - 64:10
OF [2] - 1:1, 1:4
off-duty [35] - 10:23,
10:25, 11:1, 11:5,
11:7, 11:12, 11:14,
14:15, 15:22, 16:16,
17:4, 17:10, 17:14,
17:22, 17:23, 18:4,
18:11, 18:14, 18:17,
18:23, 19:1, 19:23,
20:1, 21:8, 21:23,
22:1, 22:3, 22:12,
22:15, 25:7, 28:6,
30:2, 107:5, 107:11
Off-Duty [1] - 16:3
offense [2] - 59:17,
187:13
offer [3] - 139:19,
144:24, 145:4
offered [1] - 247:23
Office [30] - 1:18,
4:8, 5:15, 5:17, 7:1,
7:2, 10:22, 11:3, 16:6,
16:22, 50:10, 103:18,
104:2, 105:10,
105:18, 105:19,
107:11, 119:20,
134:9, 135:3, 192:9,
197:9, 208:24, 232:1,
232:9, 235:4, 243:11,
244:17, 244:18, 245:1
office [13] - 31:9,
56:13, 56:16, 70:12,
70:13, 80:17, 142:6,
152:20, 173:15,
194:1, 204:7, 242:10,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 272 of
283
250:12
OFFICER [14] - 4:2,
4:15, 4:17, 62:18,
62:21, 62:25, 102:18,
102:21, 158:4, 158:8,
178:1, 188:3, 189:14,
249:2
officer [43] - 10:9,
10:10, 26:18, 51:12,
54:12, 54:18, 55:11,
55:14, 55:17, 57:24,
64:19, 64:21, 65:6,
65:21, 65:22, 70:24,
71:3, 71:24, 72:17,
73:14, 73:15, 73:19,
74:9, 79:7, 79:15,
81:10, 81:16, 81:23,
82:3, 90:17, 90:23,
99:6, 100:8, 100:13,
101:1, 101:8, 101:10,
154:25, 159:1, 192:4,
198:22, 240:15
officers [5] - 30:2,
197:13, 198:5,
238:22, 240:5
Offices [1] - 1:21
Official [1] - 252:8
official [4] - 2:3,
79:12, 114:20, 114:24
offset [2] - 45:13,
48:14
often [2] - 12:19,
182:6
OIG [1] - 173:15
OIGs [1] - 106:5
okeydokey [1] -
160:13
old [1] - 190:19
Oliver [1] - 149:6
omissions [2] -
202:12, 241:13
omitted [1] - 186:17
on-boarded [1] -
6:25
on-boarding [1] -
5:24
once [12] - 21:23,
87:25, 88:21, 108:2,
184:7, 195:2, 200:25,
205:4, 240:19,
240:25, 244:25, 245:3
one [118] - 4:4, 9:20,
12:9, 26:23, 28:8,
29:6, 29:19, 31:6,
31:13, 39:6, 41:17,
42:14, 44:17, 45:24,
48:20, 48:25, 49:5,
50:1, 52:16, 56:18,
59:16, 62:12, 63:16,
64:23, 65:4, 68:9,
73:9, 75:17, 77:15,
78:18, 78:22, 81:14,
83:9, 83:16, 84:1,
84:16, 86:2, 91:3,
91:5, 92:8, 92:18,
96:9, 96:22, 100:13,
107:9, 109:12,
110:23, 113:13,
116:5, 117:22, 119:3,
121:6, 121:8, 122:12,
122:14, 122:15,
125:10, 127:3, 129:8,
129:12, 129:14,
136:19, 136:21,
137:25, 140:4, 140:5,
141:15, 143:1,
143:16, 143:17,
143:18, 156:24,
157:1, 157:2, 157:4,
157:20, 161:7,
161:18, 163:8,
165:20, 165:23,
165:25, 166:10,
166:16, 172:4, 172:6,
172:7, 178:9, 178:12,
186:9, 191:23,
194:14, 195:23,
200:6, 208:12, 213:4,
218:14, 218:19,
223:25, 224:2,
226:12, 226:17,
226:19, 227:22,
228:9, 229:20,
233:24, 233:25,
234:1, 234:9, 235:15,
246:20, 248:10
One [2] - 122:14,
201:16
ones [1] - 166:12
ongoing [2] - 18:10,
72:9
online [5] - 38:7,
88:25, 89:1, 129:4,
182:4
open [3] - 166:1,
175:4, 178:5
opened [5] - 113:6,
174:13, 174:17,
175:1, 214:11
opening [3] - 128:5,
128:7, 220:19
operation [1] - 147:2
opportunity [10] -
8:6, 14:6, 18:21, 60:2,
181:21, 194:12,
243:10, 244:4,
244:14, 246:14
opposed [3] - 27:14,
84:20, 88:20
oral [2] - 74:7, 82:11
order [13] - 38:25,
114:21, 125:2, 130:6,
131:8, 135:12, 152:5,
171:25, 178:22,
187:7, 195:18,
204:15, 231:2
ordinary [2] - 33:16,
50:6
organized [2] - 9:24,
64:5
origination [1] -
143:6
otherwise [1] - 143:8
outcomes [1] -
205:25
outgoing [2] - 143:8,
157:5
outlined [3] - 11:15,
21:7, 21:18
outside [16] - 11:1,
11:2, 14:10, 16:5,
16:20, 22:7, 28:6,
28:19, 30:10, 80:6,
107:5, 109:15, 178:5,
183:2, 184:7, 249:7
overall [2] - 178:21,
191:23
overpayment [1] -
37:17
overreacts [1] -
218:14
overrule [6] - 9:3,
19:13, 36:1, 50:17,
188:21, 189:3
overruled [4] -
61:22, 137:6, 183:4,
212:7
overtime [1] - 16:7
owe [9] - 205:22,
205:23, 207:15,
207:16, 207:17,
208:20, 209:9,
209:13, 220:12
owed [5] - 68:11,
72:4, 90:7, 150:9,
225:14
own [10] - 71:11,
90:15, 96:13, 101:13,
163:14, 163:20,
188:24, 189:5,
207:14, 212:12
owned [1] - 164:11
owner [2] - 65:17,
115:11
owns [1] - 35:15
P
P.A [1] - 1:21
p.m [10] - 1:6,
102:19, 102:24,
158:10, 178:2, 181:6,
184:4, 189:16, 249:3,
251:3
P.M [14] - 126:10,
126:11, 137:16,
137:19, 142:25,
143:1, 143:14,
143:18, 152:8, 157:3,
227:17, 230:17
Pace [1] - 190:24
Pacific [8] - 137:12,
137:17, 161:9,
161:15, 161:19,
162:2, 163:1, 163:3
pack [1] - 74:16
package [1] - 150:24
packages [1] - 69:14
packet [1] - 145:19
PAGE [1] - 3:2
Page [47] - 10:2,
14:18, 15:16, 16:1,
16:13, 17:7, 17:8,
20:7, 40:21, 41:20,
44:13, 48:22, 55:25,
63:9, 69:17, 69:18,
72:12, 93:5, 108:22,
119:21, 121:24,
124:19, 126:2,
126:21, 128:2,
128:23, 130:5,
130:22, 131:7,
132:22, 134:12,
135:12, 136:9,
137:15, 137:24,
138:12, 139:2,
142:19, 142:20,
144:23, 146:6, 146:8,
155:17, 170:20
page [30] - 3:16,
15:7, 17:16, 17:17,
18:7, 37:12, 45:20,
50:22, 72:12, 78:4,
85:5, 85:10, 85:11,
87:1, 92:7, 113:1,
118:15, 123:17,
131:8, 133:13,
133:21, 134:15,
136:1, 146:15,
150:14, 170:17,
205:12, 229:23,
233:16
pages [5] - 47:18,
51:1, 64:8, 72:11,
234:11
Pages [1] - 1:8
paid [17] - 40:2,
40:24, 45:24, 46:1,
57:13, 77:12, 88:14,
90:3, 90:7, 91:14,
21
91:20, 91:21, 93:6,
218:23, 220:10,
220:16, 226:3
pairs [1] - 199:1
Pandemic [1] -
105:23
pandemic [3] -
106:3, 106:6, 121:7
PANEL [1] - 9:7
paper [2] - 38:23,
169:14
papers [2] - 207:2,
213:25
paperwork [12] - 6:2,
56:23, 75:13, 91:4,
92:11, 96:4, 212:18,
215:14, 215:15,
219:18, 219:20, 245:6
paragraph [2] -
56:18, 228:14
parent [1] - 215:7
parents [1] - 191:2
Park [3] - 192:12,
192:14, 238:10
part [31] - 29:11,
37:16, 42:14, 48:25,
49:3, 49:5, 57:11,
59:16, 65:5, 79:24,
83:13, 87:7, 91:7,
99:1, 117:6, 124:13,
131:19, 132:15,
170:21, 172:10,
176:17, 195:23,
197:7, 197:8, 211:13,
211:14, 213:20,
217:19, 234:9, 239:2
part-time [4] - 29:11,
91:7, 197:7, 197:8
parte [1] - 114:21
participate [2] -
217:13, 217:19
particular [4] -
11:17, 31:22, 142:8,
188:22
particularly [1] -
157:15
parties [1] - 186:5
partners [1] - 44:18
Partners [3] - 20:3,
20:17, 20:24
Party [1] - 37:24
party [3] - 38:1, 38:2,
87:7
pass [2] - 194:24,
198:13
password [6] -
135:17, 154:1,
212:25, 213:7, 213:8
past [3] - 111:1,
153:4, 248:21
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 273 of
283
patrol [6] - 25:19,
26:18, 192:11,
192:12, 199:1, 238:22
pause [4] - 195:15,
197:2, 197:3, 211:15
pay [15] - 72:21,
74:4, 89:14, 89:17,
89:21, 164:14,
214:10, 218:21,
220:9, 225:22,
230:10, 230:22,
232:3, 232:4, 232:6
Paycheck [11] -
108:16, 109:2,
136:15, 139:13,
144:18, 144:24,
145:3, 145:19,
155:11, 210:22, 211:7
paycheck [3] -
105:20, 139:4, 210:22
payers [1] - 35:4
paying [1] - 88:21
payment [16] - 72:20,
74:3, 88:11, 88:19,
88:22, 89:2, 89:3,
121:11, 122:2, 147:8,
153:17, 210:14,
225:15, 230:9
payments [4] -
121:7, 121:15,
122:11, 148:15
payor [2] - 115:7,
147:9
payroll [9] - 5:25,
119:20, 135:2,
146:23, 146:25,
210:13, 211:1, 211:7
PDF [2] - 134:17,
145:25
penalties [21] -
39:10, 68:7, 68:15,
71:12, 71:20, 74:7,
74:9, 76:6, 77:3,
89:11, 89:12, 89:13,
89:15, 89:19, 89:22,
94:18, 95:15, 96:11,
96:13, 220:11, 225:21
penalty [6] - 70:23,
71:7, 71:9, 83:1,
89:14, 94:19
people [22] - 24:10,
25:24, 28:22, 29:10,
29:23, 30:2, 38:23,
38:24, 82:3, 169:16,
172:16, 193:9,
193:20, 194:23,
197:20, 205:15,
216:10, 216:20,
217:7, 239:4, 242:16,
242:18
per [4] - 18:18,
89:18, 115:17, 228:17
percent [1] - 194:24
perform [1] - 22:7
performing [2] -
11:2, 17:25
perhaps [1] - 249:24
period [20] - 76:14,
80:23, 97:1, 122:7,
128:3, 134:8, 137:11,
140:23, 141:5, 142:8,
142:9, 143:20,
143:24, 155:22,
156:3, 156:7, 156:16,
185:4, 199:21, 246:24
periods [1] - 67:9
perjury [1] - 39:10
permission [2] -
38:2, 87:9
permit [2] - 16:4,
16:8
person [31] - 25:13,
28:5, 30:24, 35:14,
35:18, 35:20, 39:2,
85:9, 86:6, 87:22,
88:1, 88:20, 99:16,
151:5, 151:6, 175:5,
178:10, 178:15,
179:9, 180:8, 182:12,
183:19, 185:17,
193:7, 193:8, 193:15,
235:3, 235:17, 248:4
person's [1] - 25:23
person-borne [1] -
193:7
personal [19] - 6:8,
48:15, 58:18, 108:6,
110:17, 118:17,
141:25, 142:2,
163:20, 180:24,
188:17, 188:25,
189:5, 200:4, 203:10,
215:8, 221:7, 240:22,
242:2
personally [1] -
212:12
personnel [9] - 5:25,
6:1, 7:11, 7:17, 8:14,
11:25, 13:14, 18:21,
22:13
pertain [3] - 17:9,
20:4, 20:14
pertained [1] -
124:15
pertaining [2] -
155:22, 181:22
pertains [1] - 127:24
pertinent [1] -
152:24
phone [21] - 52:5,
54:18, 54:20, 108:7,
123:22, 132:12,
141:16, 141:18,
142:1, 144:1, 146:21,
151:4, 156:2, 156:18,
156:20, 187:2, 206:7,
206:11, 206:12,
208:4, 247:1
photo [1] - 233:14
Phyllis [4] - 51:15,
74:22, 74:23, 81:18
physical [4] -
194:17, 196:8,
239:16, 239:21
physically [1] - 240:3
picking [1] - 215:10
picture [2] - 180:10,
234:9
piece [2] - 174:12,
174:16
PIN [4] - 39:5, 43:23,
85:21, 85:22
pink [1] - 162:13
pivot [2] - 49:13,
131:13
place [3] - 11:25,
16:9, 198:3
placed [2] - 74:1,
83:2
places [1] - 174:1
Plaintiff [1] - 1:5
PLAINTIFF [1] - 1:13
plan [7] - 60:3,
88:11, 88:17, 88:19,
88:22, 89:2, 89:3
plans [1] - 65:4
platform [3] -
132:19, 133:1, 182:6
player [1] - 191:9
plead [1] - 188:17
plumbers [2] - 30:6,
197:16
plumbing [1] - 18:6
POA [6] - 53:22,
54:10, 64:13, 64:15,
73:6, 81:7
point [21] - 53:21,
72:8, 85:7, 101:13,
155:14, 168:21,
170:8, 172:10, 175:7,
175:9, 181:20,
182:15, 182:25,
187:17, 192:13,
193:12, 199:21,
208:12, 209:17,
212:9, 245:14
pointing [3] - 73:23,
83:22, 156:22
points [2] - 100:8,
178:9
Polan [2] - 29:7,
29:19
police [8] - 159:1,
191:20, 191:22,
192:1, 192:4, 198:5,
237:25, 240:14
policies [11] - 6:13,
6:15, 6:17, 7:9, 7:11,
11:4, 21:18, 23:13,
24:2, 24:16, 26:9
policy [37] - 7:2,
10:22, 11:5, 12:11,
12:17, 12:20, 12:22,
12:23, 13:4, 13:5,
14:15, 14:16, 14:20,
15:1, 15:23, 16:4,
16:10, 16:12, 16:17,
16:19, 18:18, 18:19,
21:3, 21:19, 23:10,
24:18, 24:21, 24:22,
25:6, 26:9, 27:6,
27:18, 28:15, 28:16,
30:25, 110:24
Pollack [1] - 29:6
populate [1] - 182:10
portfolio [1] - 128:13
portion [11] - 15:22,
27:18, 75:7, 90:22,
94:11, 131:4, 150:20,
164:22, 201:21,
213:20, 234:5
portions [2] - 9:11,
51:1
portraying [1] -
58:16
position [4] - 5:21,
10:6, 194:12, 239:7
positions [1] - 25:22
possible [5] - 70:4,
71:2, 138:20, 208:20,
249:16
possibly [1] - 214:19
post [2] - 73:1, 75:18
postings [1] - 239:4
potential [1] - 205:25
potentially [3] -
199:8, 209:9, 228:22
pounds [1] - 194:19
power [57] - 53:11,
53:13, 53:14, 53:17,
54:2, 54:5, 54:10,
54:11, 54:20, 54:22,
64:2, 64:5, 64:8,
64:15, 64:17, 64:19,
65:2, 65:6, 66:5,
66:17, 69:12, 69:14,
69:25, 70:2, 70:6,
70:12, 70:16, 70:20,
70:23, 71:1, 71:18,
71:22, 72:18, 72:21,
22
73:8, 74:10, 81:7,
87:13, 87:15, 87:25,
88:2, 94:8, 94:12,
99:3, 99:13, 100:9,
101:4, 101:14, 102:3,
102:11, 131:6,
204:11, 204:12,
204:16, 205:5, 207:1
Power [2] - 70:17,
72:16
powers [1] - 17:1
PPP [73] - 104:22,
105:7, 105:11,
106:12, 106:17,
106:18, 107:15,
108:25, 113:9, 114:6,
114:7, 115:25, 116:2,
116:16, 116:19,
117:3, 117:11,
117:13, 119:14,
120:1, 120:4, 122:7,
131:14, 131:19,
132:10, 132:15,
133:2, 135:21,
139:17, 140:23,
140:24, 141:11,
142:11, 144:13,
145:17, 145:23,
146:16, 148:1, 148:4,
157:16, 159:15,
159:18, 160:18,
160:22, 167:23,
175:10, 184:22,
185:5, 185:22, 210:3,
210:5, 210:7, 212:14,
212:15, 212:22,
216:10, 216:14,
216:22, 219:18,
225:15, 227:5,
227:12, 227:15,
227:16, 227:25,
228:12, 228:16,
229:13, 232:2,
245:19, 246:6,
247:14, 247:23
PRAC [3] - 105:24,
106:2, 107:15
practice [2] - 196:9,
197:11
pre [2] - 75:18, 165:7
pre-dated [1] - 165:7
preceding [1] - 152:4
preparation [6] -
34:16, 50:3, 60:4,
242:21, 245:24,
245:25
preparations [1] -
76:4
prepare [7] - 56:12,
75:10, 187:17,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 274 of
283
196:12, 200:23,
216:2, 244:22
prepared [15] - 46:4,
46:22, 46:24, 53:15,
55:12, 65:11, 70:14,
73:1, 73:6, 74:9,
200:2, 200:21,
202:22, 211:16, 212:9
preparer [58] - 38:2,
38:4, 38:5, 38:6, 38:8,
38:25, 39:14, 40:2,
40:13, 41:7, 45:24,
46:1, 47:9, 53:12,
55:12, 55:19, 55:21,
56:20, 57:6, 57:9,
57:16, 57:21, 58:3,
65:4, 66:8, 73:25,
74:8, 75:8, 75:16,
75:17, 79:14, 81:5,
82:16, 82:19, 82:20,
87:18, 87:21, 93:8,
95:1, 95:9, 96:8,
99:14, 99:16, 100:14,
101:4, 101:25, 102:4,
102:7, 138:25, 187:4,
200:2, 200:20,
201:25, 205:6,
229:11, 236:2, 244:13
preparer's [5] - 40:3,
40:4, 40:24, 43:18,
93:6
preparer/power [1] -
73:17
preparers [1] - 41:3
preparing [6] -
72:24, 185:18,
202:18, 212:3,
214:23, 244:18
presence [3] - 178:5,
184:8, 249:7
present [4] - 8:22,
79:20, 179:22, 243:22
presented [2] -
184:14, 186:13
president [3] -
191:24, 193:21
pressure [1] - 197:18
presumptively [1] -
99:19
pretty [4] - 56:24,
57:1, 191:24, 206:6
prevent [2] - 192:25,
238:3
Prevention [1] -
237:15
previous [5] - 15:9,
19:5, 75:10, 136:3,
136:5
previously [19] -
8:17, 8:24, 9:4, 13:23,
19:11, 28:24, 35:24,
49:19, 50:15, 58:20,
78:5, 86:17, 124:3,
160:17, 164:7, 179:1,
221:24, 222:17, 226:7
pride [1] - 235:16
prided [1] - 235:2
prima [2] - 178:23,
187:12
primarily [1] - 135:2
primary [1] - 146:22
principal [3] - 41:25,
44:17, 225:24
principles [1] - 80:8
print [2] - 11:13, 24:5
printing [1] - 24:12
printout [1] - 230:5
prints [1] - 72:25
private [3] - 16:23,
21:10, 213:10
privilege [1] - 21:8
pro [1] - 243:2
probe [1] - 53:1
problem [4] - 80:15,
83:13, 205:8, 207:20
problems [1] - 208:8
procedure [3] - 6:13,
6:15, 54:13
Procedure [1] -
237:4
procedures [3] -
7:10, 11:4, 193:14
proceedings [14] -
4:1, 4:19, 62:20, 63:2,
102:20, 102:24,
158:6, 158:10, 178:3,
181:6, 184:5, 189:16,
249:4, 252:4
Proceedings [1] -
251:3
proceeds [3] -
117:13, 119:14, 148:4
process [21] - 11:11,
11:19, 20:6, 20:8,
31:14, 31:21, 88:6,
139:15, 151:17,
168:7, 179:23, 182:3,
200:14, 201:4, 205:3,
206:2, 212:17,
212:23, 214:8, 216:9
processed [1] -
139:14
processing [5] - 6:2,
139:17, 139:21,
225:15, 225:19
processor [1] -
153:8
produce [2] - 107:23,
123:2
produced [15] - 56:4,
75:22, 94:15, 95:23,
107:20, 108:18,
111:22, 112:4,
146:11, 161:19,
161:22, 244:15,
245:13, 245:16,
245:21
profession [1] -
41:25
Professional [1] -
16:11
proffer [4] - 247:7,
250:7, 250:8, 250:10
profit [5] - 35:10,
43:3, 45:11, 48:7,
114:13
program [3] - 182:6,
227:15, 228:3
Program [11] -
108:16, 109:2,
136:15, 139:13,
144:18, 144:24,
145:3, 145:19,
155:11, 210:22, 211:7
projector [1] -
159:23
promised [1] - 189:8
prompted [1] -
231:24
promptly [1] -
248:24
proper [1] - 41:3
property [8] - 45:7,
83:6, 83:8, 83:14,
84:2, 99:22, 147:1,
208:14
proprietor [1] -
114:13
proprietors [1] -
35:14
prosecutor [2] -
27:17, 180:21
protected [1] -
193:20
protecting [1] -
193:7
protection [6] -
105:20, 139:4, 147:2,
193:18, 193:20,
210:14
Protection [11] -
108:16, 109:2,
136:15, 139:13,
144:18, 144:24,
145:3, 145:19,
155:11, 210:22, 211:7
protocol [1] - 109:21
proud [1] - 193:25
prove [3] - 186:11,
186:14, 186:16
provide [12] - 6:24,
17:2, 34:6, 40:2,
54:16, 54:22, 64:9,
64:10, 64:21, 65:3,
99:22, 174:16
provided [18] -
37:22, 41:11, 50:9,
54:20, 65:15, 66:13,
82:12, 82:19, 82:20,
96:16, 99:18, 113:25,
130:19, 131:11,
131:21, 164:13,
211:18, 212:9
provider [3] -
109:10, 109:19,
110:22
provides [1] - 85:21
providing [1] - 35:18
provision [1] - 18:8
psychology [1] -
104:17
PTIN [3] - 39:1, 40:7,
40:10
public [7] - 16:23,
21:10, 24:10, 24:14,
38:19, 141:20, 203:8
publication [1] -
66:16
publicly [1] - 141:21
pull [7] - 5:4, 66:24,
132:21, 167:19,
170:16, 195:4, 195:6
pulled [3] - 92:17,
124:21, 128:24
pulling [1] - 37:14
punished [1] - 28:10
purchase [1] -
129:14
purchases [1] -
56:15
purple [3] - 162:15,
162:16, 225:5
purportedly [5] -
40:18, 47:15, 60:14,
179:23, 248:5
purpose [8] - 16:16,
59:14, 59:19, 59:23,
146:25, 180:16,
185:23, 209:24
purposes [6] - 16:19,
52:2, 54:5, 222:1,
224:1, 224:4
pursuant [3] - 124:5,
155:19, 179:6
put [25] - 4:12, 24:23,
43:24, 78:15, 81:16,
85:22, 170:8, 175:13,
175:19, 178:10,
178:19, 179:21,
180:18, 181:2,
23
202:19, 217:16,
217:22, 218:1, 218:5,
219:14, 231:2, 233:3,
235:9
puts [2] - 56:25,
99:17
Q
qualified [14] -
26:20, 65:12, 70:15,
97:4, 97:7, 136:15,
144:17, 210:13,
216:4, 216:7, 216:10,
219:21, 229:13, 248:2
qualifies [1] - 18:17
qualify [9] - 210:21,
211:2, 221:15,
227:12, 227:13,
228:16, 228:17,
228:22, 235:2
quantity [1] - 129:15
quarters [1] - 199:10
questioned [1] -
73:24
questioning [1] -
49:14
Questionnaire [1] -
61:13
questionnaire [6] -
58:17, 61:5, 61:8,
61:17, 62:5, 93:11
questions [19] -
20:11, 22:21, 23:6,
41:4, 53:16, 55:13,
56:1, 57:11, 57:17,
57:25, 77:19, 78:25,
98:15, 102:13,
159:19, 177:15,
188:20, 200:13,
210:23
quick [1] - 227:1
quickly [2] - 41:20,
239:25
quid [1] - 243:2
quit [1] - 194:23
quo [1] - 243:2
R
radio [2] - 193:14
raging [1] - 217:1
raised [2] - 190:21,
190:22
range [2] - 134:3,
196:10
ranking [1] - 25:13
rate [2] - 147:8,
194:24
re [1] - 223:8
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 275 of
283
reach [1] - 52:3
reached [1] - 105:23
reaching [1] - 90:19
read [30] - 16:2,
16:18, 18:3, 21:4,
21:18, 25:2, 41:9,
51:22, 55:9, 56:9,
66:10, 67:10, 72:15,
75:7, 84:22, 84:25,
85:24, 100:11,
124:21, 126:22,
130:23, 174:13,
174:17, 175:5, 175:6,
226:21, 227:10,
227:22, 228:14, 229:2
readings [1] - 64:10
ready [7] - 4:11,
4:15, 5:6, 32:19,
103:11, 190:8, 195:18
real [25] - 17:2,
29:23, 64:13, 91:7,
96:19, 97:21, 98:7,
98:11, 116:10,
164:11, 176:18,
197:1, 197:3, 197:4,
197:6, 197:25, 213:9,
215:7, 221:16, 227:1,
227:16, 227:25,
228:3, 228:12, 228:22
realization [1] -
206:20
realized [1] - 207:12
really [9] - 56:21,
166:4, 194:6, 196:24,
201:23, 208:10,
234:25, 248:17
realtor [10] - 25:7,
29:11, 176:17,
201:10, 201:11,
201:14, 210:14,
216:7, 221:20, 229:12
realtor.com [2] -
138:7, 159:8
realtors [5] - 30:6,
197:14, 216:11,
221:17, 228:15
Realty [4] - 20:3,
20:17, 20:24, 44:18
reason [19] - 21:17,
30:24, 165:3, 165:10,
172:12, 202:25,
203:19, 206:17,
206:18, 209:18,
215:20, 216:4,
221:15, 229:17,
235:20, 236:4,
247:15, 248:2, 248:4
reasonable [2] -
71:21
reasonably [2] -
41:11, 41:14
reasons [2] - 186:22,
248:1
rebuttal [2] - 249:23,
250:9
RECALL [1] - 181:16
recalling [1] - 181:12
recap [1] - 70:15
receipt [2] - 25:3,
230:22
receipts [2] - 56:15,
56:16
receive [12] - 11:21,
11:22, 11:23, 13:3,
13:7, 22:12, 107:3,
115:18, 117:22,
149:5, 152:7, 153:14
received [102] - 8:20,
8:21, 13:5, 14:2, 14:3,
14:4, 19:15, 19:16,
19:17, 23:11, 33:23,
35:5, 36:3, 36:4, 36:5,
50:18, 50:19, 53:10,
57:4, 57:14, 60:13,
62:6, 64:4, 64:7, 65:9,
66:5, 69:13, 69:20,
69:22, 70:11, 71:19,
72:1, 73:7, 80:7,
108:2, 111:9, 111:17,
113:18, 114:24,
115:21, 116:6,
117:15, 117:23,
118:10, 118:11,
118:12, 118:13,
120:17, 123:11,
123:12, 123:13,
123:14, 123:15,
124:13, 129:23,
133:11, 133:19,
140:14, 140:15,
141:8, 143:25,
145:12, 147:22,
148:22, 149:6,
149:15, 149:16,
149:17, 149:18,
151:12, 151:13,
151:14, 154:12,
154:13, 154:14,
155:10, 155:14,
159:15, 159:18,
162:3, 162:9, 162:11,
163:11, 163:13,
168:18, 173:24,
174:15, 182:2,
203:21, 203:25,
204:3, 207:2, 213:22,
213:23, 216:16,
223:16, 223:24,
224:16, 229:5, 247:17
receiving [3] - 95:10,
114:3, 213:15
recent [4] - 9:25,
126:15, 127:7, 239:7
recess [6] - 62:14,
102:17, 181:9,
187:16, 188:4, 248:22
recognize [28] - 8:3,
14:12, 19:20, 29:16,
36:11, 41:21, 43:9,
67:16, 76:10, 86:24,
89:6, 108:15, 113:21,
118:22, 119:9, 124:8,
127:15, 160:19,
164:18, 165:12,
166:16, 166:19,
224:19, 226:10,
226:13, 229:25, 231:4
record [25] - 7:15,
41:20, 50:6, 58:8,
62:10, 79:12, 80:5,
80:16, 80:19, 111:19,
112:1, 114:24,
127:24, 132:16,
144:9, 146:11,
155:17, 156:22,
161:1, 165:22,
171:20, 174:12,
182:22, 186:25, 235:3
recorded [1] - 98:25
records [92] - 6:5,
6:8, 7:11, 8:25, 24:10,
24:14, 33:14, 34:11,
34:17, 34:20, 34:23,
35:1, 49:19, 55:16,
55:18, 58:3, 58:21,
58:24, 69:15, 73:21,
74:1, 74:13, 79:22,
79:25, 80:2, 85:25,
86:10, 94:14, 95:11,
96:16, 100:1, 100:5,
101:11, 107:3,
107:20, 108:5,
109:14, 109:16,
110:18, 110:23,
110:25, 111:9, 112:5,
114:1, 114:11,
114:12, 114:14,
114:20, 114:22,
115:10, 115:13,
115:17, 115:18,
116:25, 117:4, 117:5,
117:7, 117:10,
118:20, 119:1, 119:3,
119:8, 119:12,
119:18, 121:14,
123:3, 125:5, 127:16,
131:17, 131:20,
139:24, 140:1, 141:8,
155:18, 155:21,
156:16, 161:12,
161:13, 172:14,
173:10, 173:20,
181:22, 181:24,
181:25, 182:3,
184:21, 245:4,
245:13, 245:15,
245:20
recover [1] - 135:19
recross [1] - 183:22
RECROSS [1] -
98:21
RECROSS-
EXAMINATION [1] -
98:21
Red [2] - 2:9, 218:17
redact [1] - 59:8
redacted [1] - 94:11
redaction [1] - 78:20
redactions [3] -
78:13, 78:15, 94:14
redirect [3] - 32:6,
92:4, 177:6
REDIRECT [4] -
93:1, 101:20, 177:8,
181:16
reducing [1] - 45:14
refer [5] - 10:17,
10:19, 16:15, 16:20,
18:8
reference [14] -
47:18, 73:12, 85:1,
115:15, 116:7, 129:2,
132:1, 132:4, 147:25,
148:16, 151:22,
151:23, 196:25
referenced [11] -
52:17, 52:18, 55:5,
58:2, 71:8, 74:11,
132:16, 149:20,
155:21, 156:12, 182:7
references [3] -
54:25, 129:4, 129:5
referencing [20] -
86:9, 108:18, 116:25,
119:3, 121:25,
132:23, 148:4,
150:15, 152:12,
154:20, 154:21,
170:17, 175:12,
199:21, 200:11,
202:13, 205:19,
210:19, 229:21,
232:16
referrals [1] - 242:23
referred [4] - 5:19,
11:5, 17:11, 242:16
referring [8] - 19:9,
20:8, 21:2, 81:20,
149:20, 208:16,
214:18, 230:7
24
refers [2] - 44:10,
55:24
reflect [7] - 58:8,
67:23, 100:1, 101:24,
102:4, 131:6, 182:22
reflected [1] - 63:14
refreshing [1] -
172:9
refund [6] - 37:14,
37:16, 45:21, 68:25,
135:6, 205:23
refunds [1] - 59:5
refuse [1] - 204:20
regarding [10] -
10:23, 43:17, 55:5,
60:23, 71:20, 105:2,
107:24, 124:4,
146:16, 160:18
regards [1] - 208:17
regulate [1] - 103:22
regulation [3] -
24:18, 26:16, 28:17
regulations [8] -
24:2, 24:11, 26:7,
26:11, 27:4, 27:9,
82:11
reiterate [3] - 162:1,
163:7, 249:22
reiterated [2] -
57:20, 95:7
relate [4] - 14:22,
15:18, 22:5, 103:22
related [19] - 34:17,
34:23, 49:20, 82:12,
104:10, 105:20,
106:7, 108:9, 110:1,
113:3, 114:1, 119:1,
138:8, 142:11,
148:15, 157:15,
176:13, 232:2, 246:5
relating [7] - 64:7,
105:25, 106:1,
160:22, 178:13, 185:4
relation [1] - 247:14
relationship [5] -
199:17, 200:3,
200:10, 200:17, 236:1
relevance [1] -
135:20
relevant [2] - 152:24,
247:2
relied [1] - 82:15
relief [1] - 211:5
relive [1] - 153:3
rely [1] - 207:5
remained [1] -
170:13
remaining [2] -
126:16, 127:8
remarkable [1] -
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 276 of
283
131:16
remarks [5] - 52:16,
53:10, 65:1, 73:5,
73:12
remember [22] -
27:20, 57:4, 59:12,
98:24, 99:1, 161:2,
161:3, 162:13,
162:17, 162:19,
164:8, 164:15,
164:16, 165:20,
165:23, 174:6,
208:10, 225:4, 244:9,
244:20, 245:4
remind [1] - 214:16
renew [7] - 8:24,
12:1, 13:22, 18:11,
35:24, 50:15, 179:1
renewal [1] - 19:11
rent [3] - 45:7, 147:1,
198:3
reopen [5] - 98:17,
179:20, 180:19,
181:2, 181:9
reopening [1] -
180:15
repairs [2] - 45:8,
97:20
repayment [1] -
229:21
repeat [1] - 84:17
rephrase [1] - 79:11
Report [2] - 67:19,
78:9
report [31] - 8:10,
8:11, 8:13, 9:14, 9:24,
48:2, 48:7, 51:7, 58:2,
67:8, 67:10, 76:13,
76:16, 76:19, 83:12,
95:12, 95:15, 96:20,
100:19, 169:9,
169:17, 169:22,
169:23, 169:24,
170:1, 170:5, 170:16,
223:1, 248:15
REPORTED [1] - 2:1
reported [14] - 36:23,
37:1, 37:2, 48:12,
48:14, 84:11, 86:21,
91:11, 91:14, 107:10,
134:7, 134:23,
176:22, 248:10
Reporter [2] - 2:3,
252:8
reporting [3] - 42:10,
96:19, 125:15
reports [1] - 83:9
represent [13] -
33:13, 37:20, 43:22,
44:7, 52:10, 53:9,
63:24, 68:6, 97:1,
97:7, 134:13, 225:18,
225:21
representation [3] -
54:11, 90:25, 94:13
represented [1] -
47:4
representing [2] -
55:10, 113:2
represents [1] - 43:5
reprimanded [1] -
28:12
request [13] - 17:10,
17:15, 18:5, 21:5,
21:16, 21:21, 22:1,
24:10, 88:19, 89:18,
94:16, 96:10, 146:24
requested [9] -
37:17, 37:21, 41:1,
82:20, 83:1, 105:24,
107:5, 110:15, 182:4
requesting [4] -
17:22, 74:6, 112:8,
173:10
require [4] - 7:5,
7:11, 206:12, 250:9
required [5] -
125:15, 139:19,
144:19, 184:19,
186:20
requirement [4] -
38:16, 177:13,
186:18, 239:22
requirements [5] -
16:9, 16:12, 125:15,
239:14, 239:16
requires [1] - 147:14
rescind [2] - 14:23,
15:19
rescinding [1] -
15:12
rescue [1] - 199:11
research [1] - 159:14
Reserve [2] - 103:19,
103:25
reserves [1] - 21:15
residence [1] -
110:17
resource [2] - 6:5,
10:9
Resources [2] -
5:15, 7:4
resources [4] - 7:1,
30:20, 31:4, 31:17
respond [5] - 150:24,
183:15, 207:5,
219:24, 239:25
responded [4] -
198:23, 204:7,
219:25, 233:8
responds [2] - 152:8,
159:4
response [15] - 73:6,
73:16, 94:15, 96:10,
101:3, 102:11,
107:20, 115:22,
123:2, 138:1, 152:16,
159:2, 184:11,
192:23, 205:7
Response [2] -
105:23, 106:3
responsibilities [4] -
5:23, 11:2, 16:21,
33:12
responsible [5] -
6:17, 16:11, 33:15,
41:18, 49:8
rest [2] - 229:2,
248:11
restate [1] - 170:15
rested [3] - 177:22,
178:7, 189:19
resting [1] - 183:25
restrictions [1] -
16:9
rests [1] - 177:20
result [4] - 6:6,
21:25, 76:5, 84:4
resulted [2] - 45:20,
45:21
results [2] - 110:11,
159:17
retain [2] - 106:20,
110:25
retains [1] - 110:23
retention [1] -
110:24
return [69] - 35:3,
36:15, 38:3, 38:25,
39:11, 41:10, 41:18,
43:13, 44:11, 44:25,
46:4, 46:9, 46:24,
53:12, 55:12, 55:19,
55:21, 56:20, 57:3,
57:6, 57:9, 57:16,
57:21, 58:4, 60:14,
61:2, 61:19, 62:11,
63:11, 63:14, 65:3,
73:17, 73:18, 73:25,
74:8, 75:13, 75:15,
81:4, 81:9, 82:16,
82:23, 85:4, 85:17,
85:20, 86:6, 86:12,
87:10, 93:5, 93:17,
94:6, 95:1, 95:8, 96:5,
96:6, 97:24, 99:14,
99:16, 99:17, 100:14,
101:4, 101:5, 112:10,
116:6, 202:22,
205:13, 241:18,
241:21, 242:23,
245:16
returned [3] -
110:11, 112:10,
123:19
returns [31] - 33:18,
33:22, 34:8, 34:20,
35:4, 47:1, 47:16,
49:20, 49:21, 53:15,
55:12, 56:12, 57:4,
57:5, 57:10, 59:15,
67:24, 75:18, 75:20,
75:23, 79:8, 84:1,
93:3, 95:24, 100:17,
118:19, 124:13,
202:16, 212:12, 246:8
revenue [3] - 48:11,
54:13, 56:10
Revenue [1] - 33:6
reverse [2] - 125:1,
231:2
reversed [2] - 89:19,
152:4
Review [1] - 61:13
review [37] - 6:23,
8:6, 11:20, 12:20,
13:4, 14:6, 14:23,
14:25, 15:11, 15:19,
18:21, 34:4, 34:5,
34:12, 34:16, 49:23,
53:14, 53:15, 55:16,
55:18, 63:13, 64:22,
70:3, 71:11, 77:11,
107:12, 119:25,
121:14, 124:14,
127:24, 140:25,
146:5, 156:6, 156:15,
170:14, 181:22,
245:20
reviewed [24] - 13:6,
13:11, 15:1, 29:10,
47:22, 50:3, 54:13,
57:5, 62:10, 64:7,
65:10, 65:15, 69:23,
75:18, 100:12,
136:14, 139:14,
142:7, 171:17, 180:9,
245:4, 245:11,
245:13, 246:6
reviewing [8] -
15:17, 69:15, 117:16,
119:12, 119:18,
145:2, 161:12, 172:13
reviews [1] - 7:1
revised [2] - 14:23,
15:4
revision [2] - 15:11,
15:19
revisions [2] - 24:17,
24:18
25
revocation [1] - 22:1
revoke [1] - 21:16
rid [1] - 90:3
rifles [1] - 194:19
right-hand [2] - 56:3,
121:2
rights [1] - 16:8
rise [13] - 4:2, 4:17,
62:18, 62:21, 62:25,
102:18, 102:21,
158:4, 158:8, 178:1,
188:3, 189:14, 249:2
River [13] - 106:25,
107:1, 107:16,
107:17, 107:21,
108:19, 146:12,
155:10, 155:16,
155:19, 161:1,
162:12, 225:4
road [6] - 25:19,
26:23, 192:11,
192:12, 199:1, 213:17
robbery [1] - 198:25
ROBERT [1] - 1:10
Robinhood [34] -
122:23, 122:25,
123:1, 123:2, 123:20,
124:15, 126:1, 126:5,
126:24, 127:10,
127:16, 129:19,
130:7, 130:19,
130:24, 130:25,
131:3, 131:9, 131:17,
167:3, 167:6, 168:19,
168:23, 170:9,
170:12, 170:16,
171:16, 172:13,
172:22, 173:1,
173:11, 173:14,
173:19
rode [1] - 199:1
role [5] - 5:23, 6:3,
6:6, 33:14, 34:7
roles [1] - 25:22
rolling [2] - 106:11,
110:6
room [3] - 177:24,
184:3, 186:9
roughly [1] - 69:7
router [3] - 109:24,
110:1, 110:4
routine [2] - 214:25,
215:1
RP [3] - 17:15, 21:24,
81:4
RP45 [1] - 22:4
RPR [2] - 2:2, 252:8
rules [2] - 64:18,
82:11
run [1] - 106:10
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 277 of
283
running [6] - 194:17,
195:23, 195:24,
196:1, 196:2
runs [1] - 139:17
S
S300 [1] - 66:14
sacrifice [1] - 195:20
safe [3] - 26:15,
203:14, 248:25
safety [1] - 27:5
sake [1] - 136:7
salaries [1] - 36:22
sample [1] - 166:2
Sarasota [1] - 236:13
sat [4] - 57:2, 95:4,
243:18, 243:20
save [1] - 153:16
savings [9] - 117:23,
120:16, 120:17,
120:24, 122:9,
122:17, 122:18,
166:18, 168:20
saw [15] - 24:16,
48:8, 49:20, 53:20,
84:14, 115:6, 118:25,
119:19, 125:4, 159:8,
167:12, 169:2,
182:12, 219:11,
219:14
SBA [25] - 106:5,
106:11, 115:25,
139:15, 139:18,
139:21, 139:22,
144:19, 145:2,
163:14, 167:23,
173:25, 184:16,
184:19, 185:4,
186:16, 219:1,
220:14, 224:22,
227:18, 228:6, 230:6,
230:10, 230:22
SBA-approved [2] -
227:18, 228:6
Schedule [45] - 35:7,
36:25, 41:22, 41:23,
42:9, 44:4, 44:5, 44:6,
44:8, 44:10, 44:14,
44:25, 45:2, 45:4,
45:12, 48:2, 48:7,
48:12, 48:14, 48:17,
56:17, 57:1, 57:19,
62:11, 63:10, 64:12,
64:14, 64:16, 70:14,
73:25, 74:2, 83:3,
91:10, 95:6, 95:8,
97:3, 98:2, 114:13,
116:3, 116:7, 116:11,
116:21
schedule [11] - 21:7,
47:23, 57:21, 75:12,
93:17, 96:4, 97:18,
196:23, 196:24,
197:22, 215:6
schedules [1] -
39:11
scheduling [2] -
177:23, 249:9
scheme [1] - 186:25
School [1] - 190:24
school [14] - 38:14,
190:23, 194:14,
195:1, 195:2, 195:23,
196:12, 198:10,
198:11, 198:13,
198:14, 198:18,
214:17, 215:10
schools [1] - 194:14
SCOLA [1] - 1:10
scope [4] - 16:5,
16:21, 109:15, 183:2
Scratch [15] -
151:23, 151:25,
152:7, 152:12,
152:20, 153:7,
153:13, 153:17,
153:19, 155:2, 155:9,
155:15, 173:25,
213:15
screen [12] - 60:10,
120:9, 129:11,
136:24, 231:8, 231:9,
233:14, 233:21,
233:23, 233:24,
234:2, 234:14
screens [1] - 7:23
scroll [3] - 41:20,
47:20, 142:17
scrolling [2] - 60:23,
146:6
search [2] - 114:2,
120:3
searched [1] - 182:9
season [1] - 206:13
seat [2] - 32:18,
190:7
seated [12] - 4:3,
4:21, 5:4, 62:22, 63:4,
103:1, 158:12, 178:4,
181:7, 184:7, 188:5,
189:18
second [32] - 30:12,
37:12, 45:20, 46:18,
78:2, 78:3, 87:1,
87:11, 91:3, 91:23,
95:3, 113:1, 113:13,
121:8, 137:7, 140:4,
157:6, 161:18,
165:25, 167:3, 172:6,
172:7, 201:4, 204:13,
211:15, 214:17,
214:19, 224:2,
229:23, 233:16,
234:1, 235:15
second-to-last [1] -
157:6
seconds [3] -
129:24, 171:13, 174:7
Secrecy [2] - 104:12,
125:16
Section [4] - 15:25,
17:5, 17:6, 21:19
section [33] - 16:2,
16:15, 36:20, 37:13,
37:14, 37:23, 39:7,
39:14, 39:24, 42:14,
42:15, 42:18, 42:20,
45:1, 45:25, 46:17,
48:23, 51:5, 52:21,
54:8, 55:3, 55:24,
60:15, 60:23, 61:12,
67:6, 68:5, 72:15,
77:1, 124:24, 147:16,
151:1
sections [2] - 52:16,
52:18
secure [3] - 65:5,
72:18, 203:11
secured [1] - 72:25
securities [4] -
128:7, 128:11,
128:19, 128:22
security [14] - 42:3,
44:19, 44:20, 46:12,
58:23, 135:14,
135:16, 136:21,
146:21, 154:18,
172:24, 173:1, 213:5
SECURITY [14] - 4:2,
4:15, 4:17, 62:18,
62:21, 62:25, 102:18,
102:21, 158:4, 158:8,
178:1, 188:3, 189:14,
249:2
see [73] - 9:6, 14:21,
15:3, 24:24, 29:1,
34:5, 48:23, 52:21,
56:19, 60:16, 62:15,
75:6, 75:19, 78:7,
78:11, 78:20, 79:7,
79:18, 81:15, 81:20,
85:3, 85:5, 85:15,
86:13, 86:18, 86:20,
87:4, 88:19, 89:11,
89:24, 90:1, 99:4,
102:17, 107:12,
110:17, 118:24,
120:12, 121:2, 121:5,
121:25, 122:21,
124:21, 128:25,
129:1, 129:17, 134:8,
134:24, 135:1, 138:5,
138:7, 138:24, 140:9,
142:23, 158:3,
166:17, 170:19,
170:21, 170:24,
172:8, 181:2, 183:12,
188:1, 201:2, 203:3,
216:20, 219:1,
226:14, 227:1,
233:12, 233:16,
234:4, 239:4, 248:25
seeing [6] - 36:20,
55:25, 126:3, 207:14,
214:8, 216:9
seek [1] - 11:7
seem [2] - 205:11,
247:25
self [3] - 18:4,
175:17, 175:20
self-employed [3] -
18:4, 175:17, 175:20
sell [1] - 198:5
send [8] - 58:3, 71:1,
138:19, 139:18,
207:3, 231:11,
231:25, 234:13
sending [2] - 71:4,
71:25
sense [4] - 41:16,
96:2, 216:21, 239:18
Sent [1] - 135:10
sent [31] - 33:23,
35:17, 64:9, 65:10,
66:23, 72:2, 76:17,
88:3, 95:12, 109:4,
109:5, 134:14, 135:7,
137:24, 139:13,
145:6, 152:15,
153:15, 154:17,
184:22, 203:25,
205:19, 229:7, 231:9,
232:20, 233:25,
234:1, 234:8, 234:9,
234:12, 234:14
sentence [7] - 52:22,
66:4, 95:3, 95:5,
95:22, 95:25, 96:1
sentences [1] -
57:23
separate [11] - 18:5,
51:2, 82:3, 99:12,
218:16, 247:3, 247:6,
247:10, 247:11
separately [1] -
54:19
separates [1] - 6:2
September [1] -
238:13
26
Sergeant [3] - 29:8,
29:20, 29:21
sergeant [7] - 25:11,
25:16, 25:20, 25:23,
26:2, 27:2
serious [1] - 213:10
service [6] - 18:6,
35:19, 109:10,
109:14, 109:19,
110:22
Service [1] - 33:6
serviced [1] - 133:2
services [1] - 211:18
session [2] - 56:8,
227:18
set [8] - 4:13, 54:21,
65:6, 72:22, 74:5,
78:2, 89:2, 227:20
seven [2] - 185:21,
247:20
several [4] - 75:9,
138:15, 194:18,
197:13
severely [1] - 28:11
shape [2] - 195:25,
215:3
share [2] - 114:22,
130:17
shares [3] - 129:16,
130:16, 131:12
SHARON [2] - 2:2,
252:8
sharon_pellvelazco
@flsd.uscourts.gov
[1] - 2:5
sheet [1] - 94:19
sheets [2] - 65:11,
70:14
Sheriff [1] - 10:8
sheriff [4] - 10:10,
10:14, 16:9, 21:15
sheriff's [2] - 176:23,
194:1
Sheriff's [22] - 4:7,
5:15, 5:17, 7:1, 7:2,
10:22, 11:3, 14:15,
16:6, 16:22, 21:19,
105:18, 107:11,
119:20, 134:9, 135:3,
192:8, 197:9, 208:24,
232:1, 232:9, 235:4
sheriff-daily [1] -
10:14
sheriffs [2] - 6:11,
16:25
shooting [4] -
192:21, 194:19,
198:25
short [2] - 195:5,
201:1
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 278 of
283
shot [6] - 231:8,
231:9, 233:15,
233:25, 234:2, 234:15
shots [1] - 233:21
shotted [1] - 233:23
show [26] - 27:21,
43:8, 58:6, 60:15,
67:15, 74:15, 95:20,
96:20, 108:1, 108:2,
108:10, 111:12,
114:14, 115:20,
119:7, 131:10, 133:6,
148:18, 151:21,
157:18, 159:17,
201:12, 221:22,
226:12, 229:20,
229:24
showed [8] - 27:18,
108:9, 109:11, 111:9,
120:4, 161:16,
166:12, 166:25
showing [41] - 28:24,
40:21, 44:13, 46:6,
50:22, 51:4, 55:22,
60:10, 67:9, 76:8,
78:5, 86:17, 92:15,
111:19, 113:20,
116:9, 118:15, 119:6,
123:17, 124:7,
125:25, 130:22,
133:13, 133:21,
136:24, 137:15,
140:17, 141:3,
145:14, 147:24,
148:24, 149:8,
155:25, 160:17,
164:7, 221:24,
222:17, 224:18,
226:7, 231:1, 233:11
shown [2] - 36:9,
67:9
shows [7] - 108:24,
109:2, 109:3, 113:3,
155:1, 185:10, 201:11
siblings [1] - 190:25
side [7] - 30:6, 55:22,
56:11, 121:2, 197:21,
197:23
sidetracked [1] -
37:11
sign [17] - 7:9, 13:12,
23:10, 25:4, 39:8,
72:17, 75:13, 85:12,
87:20, 96:5, 139:19,
154:21, 164:5, 166:2,
204:11, 204:13,
204:16
signature [32] -
39:22, 43:17, 43:18,
43:19, 43:20, 43:23,
43:25, 85:8, 85:16,
85:19, 87:3, 93:24,
108:9, 109:3, 109:4,
112:14, 118:17,
118:22, 147:14,
164:21, 164:24,
165:2, 165:4, 165:9,
165:10, 165:14,
165:24, 166:1, 166:3,
166:8, 166:19, 178:17
signatures [4] - 93:3,
165:2, 166:22, 180:10
signed [32] - 43:20,
47:5, 57:3, 57:15,
62:3, 63:16, 66:14,
72:18, 73:6, 75:2,
86:13, 86:14, 87:4,
87:5, 87:6, 87:12,
87:18, 93:22, 112:15,
136:22, 146:13,
147:17, 154:23,
155:1, 155:2, 168:10,
174:11, 180:12,
204:21, 204:23
signer [3] - 108:25,
109:4, 112:12
significance [6] -
125:13, 229:9,
231:14, 231:20,
233:21, 234:17
significant [2] -
15:21, 226:23
significantly [1] -
150:1
signify [2] - 66:22,
136:20
signing [4] - 153:10,
153:21, 168:4, 204:25
SILBER [107] - 1:21,
8:19, 8:23, 13:22,
19:7, 19:11, 22:24,
23:2, 23:21, 23:23,
24:1, 27:24, 28:1,
30:12, 30:15, 35:24,
50:15, 61:21, 77:22,
83:21, 83:23, 91:23,
91:25, 92:6, 92:10,
92:13, 92:17, 92:21,
98:16, 98:20, 98:22,
113:13, 118:2, 118:4,
123:6, 123:8, 133:8,
133:17, 137:5, 137:7,
140:4, 140:7, 140:11,
145:10, 147:20,
148:20, 149:10,
149:13, 151:9, 154:3,
154:5, 154:7, 154:10,
159:22, 160:2, 160:7,
160:10, 177:1, 177:3,
178:8, 179:1, 180:17,
180:23, 182:19,
183:2, 183:23,
187:16, 187:21,
187:25, 188:2, 188:8,
189:22, 190:13,
190:15, 193:10,
212:8, 221:22, 222:5,
222:7, 222:14,
222:21, 222:25,
223:3, 223:6, 223:10,
223:13, 223:15,
223:17, 223:20,
223:25, 224:7,
224:10, 224:13,
224:15, 224:17,
231:16, 231:19,
232:23, 232:25,
233:10, 234:16,
234:22, 235:14,
236:6, 249:15,
249:19, 251:1
Silber [11] - 1:21,
2:10, 2:13, 2:15,
23:19, 94:18, 96:18,
101:22, 102:7,
188:20, 189:1
silber [1] - 2:17
silberlaw@gmail.
com [1] - 1:23
similar [7] - 15:8,
104:8, 106:14,
165:19, 166:25,
200:8, 228:9
simple [2] - 38:9,
207:19
simply [1] - 57:6
single [8] - 26:23,
35:14, 75:24, 79:8,
79:18, 99:5, 199:12,
246:23
singular [1] - 247:5
sit [7] - 21:9, 75:14,
96:6, 162:24, 201:1,
201:20, 202:18
sitting [5] - 107:18,
178:10, 182:15,
182:20, 247:20
situation [3] - 199:6,
199:8, 240:7
situational [2] -
239:18, 239:20
situations [1] - 240:1
six [1] - 85:22
sixth [1] - 52:22
skip [2] - 170:20,
172:10
skipped [1] - 45:24
sled [1] - 195:4
slow [1] - 194:10
small [2] - 124:19,
138:6
Small [2] - 113:5,
139:14
social [9] - 42:3,
44:19, 44:20, 46:12,
58:23, 146:20, 213:5,
215:16
socials [1] - 203:6
softball [1] - 191:9
sole [2] - 35:14,
114:13
solicited [2] - 72:20,
74:3
someone [14] -
25:10, 31:21, 38:5,
84:7, 87:20, 155:2,
169:7, 173:3, 173:7,
173:9, 173:14, 202:2,
227:6, 228:21
sometime [4] -
111:4, 111:25,
216:18, 216:19
sometimes [6] -
173:6, 201:2, 206:6,
235:17, 242:20
somewhere [2] -
120:8, 214:20
son [1] - 196:22
soon [2] - 70:4, 71:2
sorry [62] - 19:7,
23:21, 24:16, 41:15,
43:21, 48:16, 70:9,
72:15, 73:2, 74:16,
77:7, 81:14, 83:8,
83:21, 84:17, 85:3,
89:8, 91:3, 91:4,
92:17, 97:9, 98:4,
112:3, 113:20,
120:19, 127:22,
129:24, 130:2, 133:7,
136:6, 137:11, 138:6,
138:12, 140:10,
149:9, 152:4, 154:9,
154:16, 155:13,
160:7, 162:16,
165:22, 169:12,
170:14, 174:23,
208:16, 220:14,
222:4, 223:3, 226:22,
229:23, 230:25,
231:17, 233:19,
234:25, 235:8, 235:9,
235:10, 238:6, 246:1,
250:6
sort [2] - 7:6, 239:22
sound [4] - 237:2,
237:5, 237:7, 237:9
sounds [4] - 38:9,
196:13, 196:23,
247:19
27
source [1] - 64:10
South [1] - 1:22
SOUTHERN [1] - 1:1
Space [2] - 230:2,
230:8
speaking [5] - 6:15,
14:9, 151:4, 185:5,
247:21
Special [9] - 103:3,
113:20, 118:15,
131:13, 140:17,
158:16, 181:12,
181:19, 243:20
special [12] - 103:21,
104:2, 104:3, 123:17,
181:20, 193:3, 203:1,
238:18, 239:10,
239:12, 239:16, 240:8
specialized [1] -
193:6
specialties [1] -
240:10
specific [6] - 35:6,
67:25, 88:5, 110:15,
162:17, 248:11
specifically [14] -
7:3, 75:15, 96:7,
104:23, 132:7, 138:6,
138:7, 148:12,
153:11, 186:17,
193:8, 205:21,
214:12, 227:19
speculation [1] -
61:21
speech [1] - 191:24
spell [4] - 5:7, 32:19,
103:12, 190:8
spend [1] - 36:18
spent [7] - 56:22,
149:25, 185:25,
190:16, 201:15, 221:6
split [2] - 60:10,
136:24
spoiler [1] - 250:20
spreadsheet [3] -
106:16, 162:3, 162:10
St [74] - 40:5, 40:18,
53:11, 54:16, 54:17,
55:13, 56:12, 57:2,
74:1, 75:9, 75:14,
75:16, 75:22, 75:24,
79:6, 82:15, 83:2,
88:6, 90:19, 90:24,
95:4, 95:23, 96:6,
96:7, 99:3, 101:25,
102:2, 105:15,
110:20, 111:10,
112:13, 112:22,
113:7, 114:3, 132:12,
138:14, 138:17,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 279 of
283
141:12, 141:13,
149:4, 150:8, 150:23,
152:7, 155:6, 156:7,
156:10, 157:7,
157:23, 158:20,
163:14, 175:19,
176:14, 179:8, 185:1,
185:8, 185:16,
199:17, 199:22,
209:12, 210:10,
210:13, 215:13,
231:9, 232:14,
241:21, 241:23,
241:25, 242:13,
243:6, 244:11,
246:16, 246:24,
247:20, 248:10
stabbing [1] - 198:25
stage [1] - 107:7
stamp [1] - 153:6
stamps [2] - 161:8,
171:11
stand [7] - 40:12,
52:19, 69:5, 99:7,
106:2, 121:10, 190:1
Standard [2] -
137:12, 137:17
standard [2] - 37:6,
205:14
standards [1] - 16:8
Standards [1] -
16:11
start [12] - 11:9, 12:9,
96:1, 142:18, 142:19,
153:3, 153:5, 157:19,
191:13, 192:8,
236:15, 248:24
started [12] - 52:12,
117:13, 132:8,
142:11, 191:21,
195:17, 200:21,
214:7, 219:9, 236:12,
237:23, 241:15
starting [2] - 52:22,
138:15
starts [4] - 69:17,
147:8, 152:5, 152:13
state [12] - 21:13,
32:19, 59:24, 64:1,
76:12, 94:25, 95:3,
112:12, 127:5,
144:12, 149:3, 192:4
State [4] - 180:12,
182:5, 191:7, 236:19
statement [35] -
35:17, 39:8, 70:4,
70:25, 71:2, 71:3,
71:19, 71:24, 72:4,
74:11, 77:4, 118:3,
119:10, 119:25,
121:19, 125:5, 128:3,
128:15, 128:18,
131:11, 134:5, 134:8,
134:12, 142:7,
177:10, 184:20,
185:9, 186:19,
220:19, 244:7, 244:9,
244:10, 244:12,
246:23, 249:22
statements [25] -
39:11, 56:16, 69:20,
69:22, 70:13, 75:10,
75:19, 75:21, 79:14,
96:14, 114:11, 134:2,
134:19, 134:21,
135:20, 138:5,
138:15, 153:15,
172:14, 184:15,
184:16, 184:19,
186:2, 201:14, 202:12
statements.PDF [1] -
133:25
STATES [3] - 1:1,
1:4, 1:11
States [4] - 2:3,
94:15, 105:18, 252:9
states [11] - 55:18,
57:16, 64:17, 64:19,
71:22, 72:21, 80:19,
102:10, 125:10,
127:6, 134:17
static [3] - 110:3,
110:4, 110:7
stating [4] - 61:25,
64:3, 64:8, 102:7
status [6] - 71:5,
113:4, 123:23,
139:21, 187:15,
189:21
Statute [1] - 16:7
statute [1] - 186:18
stay [2] - 110:5,
194:22
stayed [2] - 212:5,
215:3
stays [1] - 110:4
STENOGRAPHICA
LLY [1] - 2:1
step [6] - 88:7,
177:17, 183:24,
204:5, 204:24
steps [6] - 55:14,
55:17, 136:16,
144:13, 145:5, 167:13
sticker [1] - 78:7
sticky [1] - 213:1
still [16] - 4:3, 37:11,
49:6, 54:16, 59:6,
62:23, 72:8, 154:16,
181:14, 185:24,
192:6, 197:25,
201:24, 208:10,
219:19, 249:12
stimulate [1] - 211:9
stimulus [8] - 121:6,
121:12, 121:15,
122:4, 148:15,
148:16, 149:4, 216:21
Stimulus [1] - 149:1
stock [1] - 129:14
stop [4] - 54:12,
193:15, 214:23,
214:24
store [1] - 218:17
stores [1] - 217:7
strains [1] - 187:5
streets [1] - 26:19
strength [1] - 199:5
stress [3] - 157:25,
158:22, 218:15
strictly [2] - 26:7,
200:16
string [1] - 150:18
strong [1] - 186:8
stronger [1] - 199:4
structuring [1] -
169:15
student [1] - 237:21
studied [1] - 98:25
stuff [6] - 80:9,
153:15, 167:11,
215:17, 234:4, 248:18
subject [22] - 126:4,
126:22, 126:23,
130:6, 131:8, 133:25,
134:18, 136:12,
137:25, 138:13,
139:2, 139:12,
144:12, 148:2,
148:25, 149:3, 150:6,
150:7, 152:12, 153:9,
155:10, 193:13
subline [1] - 130:24
submission [1] -
212:23
submit [14] - 21:23,
25:8, 27:13, 28:20,
30:18, 70:24, 89:1,
144:18, 169:8,
184:18, 187:5,
211:25, 212:10,
212:18
submits [1] - 213:25
submitted [25] -
41:5, 49:9, 55:21,
73:21, 86:11, 86:12,
87:3, 89:19, 114:17,
115:15, 115:24,
116:16, 116:18,
139:5, 163:17,
167:15, 167:23,
176:6, 176:9, 176:11,
178:15, 202:16,
212:12, 212:13, 248:5
submitting [1] -
211:17
subpoena [22] -
107:1, 107:16,
109:10, 109:14,
109:18, 110:10,
110:13, 110:15,
110:16, 111:1, 111:3,
112:1, 112:4, 112:6,
115:10, 115:22,
117:13, 123:1, 123:2,
155:19, 167:8, 172:13
subpoenas [4] -
110:14, 117:11,
117:16, 117:18
subscriber [3] -
113:22, 124:9, 140:19
subsection [7] -
15:25, 16:14, 17:8,
18:7, 68:14, 68:20,
97:17
subsets [1] - 50:14
substance [3] -
126:12, 144:15, 145:1
substantially [1] -
186:23
substantiate [2] -
64:11, 248:11
substantiated [3] -
70:18, 70:21, 229:19
substantiating [3] -
64:6, 96:16, 216:12
substantiation [2] -
65:5, 69:15
substantive [1] -
56:8
subtract [1] - 43:3
success [1] - 157:11
successfully [1] -
194:13
sufficiency [1] -
184:12
sufficient [3] -
185:22, 187:6, 187:11
suggest [1] - 27:7
suicide [1] - 193:8
suit [2] - 182:17,
182:20
Suite [1] - 1:15
sum [1] - 43:5
summarize [3] -
55:9, 149:21, 158:18
summary [4] - 68:7,
76:19, 127:21
summer [1] - 105:5
sun [1] - 194:20
28
sunset [1] - 18:8
sunsets [1] - 12:2
SunTrust [13] - 59:7,
69:20, 69:22, 117:12,
117:18, 118:17,
119:23, 120:16,
120:24, 137:25,
138:5, 138:13, 138:15
superseding [5] -
59:22, 60:1, 60:2,
60:5, 105:13
supervisor [2] -
18:18, 25:15
supervisory [1] -
25:22
supplement [2] -
198:7, 211:4
supplied [2] - 117:2,
155:19
supplies [6] - 42:22,
45:8, 56:16, 98:5,
116:20, 147:1
support [9] - 108:5,
114:17, 115:25,
116:16, 116:18,
117:7, 184:22,
186:22, 187:5
supported [4] - 97:8,
155:18, 184:22, 248:1
supporting [6] -
58:3, 95:11, 114:7,
114:14, 132:15, 246:5
supports [1] -
186:23
supposed [2] -
193:12, 213:18
surprise [6] - 243:4,
244:11, 246:7,
246:12, 246:13
Susan [1] - 55:20
suspend [1] - 21:16
suspended [8] -
30:21, 31:12, 31:24,
219:3, 232:1, 232:3,
232:4, 232:6
SW [3] - 20:3, 20:17,
20:24
SWAT [25] - 194:1,
194:7, 194:8, 194:14,
195:1, 195:2, 195:16,
195:18, 195:23,
196:12, 197:25,
198:10, 198:11,
198:13, 198:18,
198:19, 198:22,
199:4, 214:17,
214:24, 215:7, 239:7,
239:25
swimming [1] -
194:18
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 280 of
283
switch [1] - 104:13
sworn [9] - 5:1,
10:10, 16:6, 16:25,
32:15, 103:8, 189:25,
190:4, 241:1
systems [1] - 34:11
T
table [3] - 182:18,
182:21, 249:6
tactical [4] - 192:20,
192:25, 194:12, 199:2
tactics [1] - 239:10
Tamarac [4] - 46:16,
51:19, 67:5, 225:8
target [1] - 114:4
task [1] - 105:8
tasked [1] - 106:6
tasks [1] - 136:17
Tax [8] - 39:6, 40:20,
46:3, 47:14, 58:14,
65:22, 67:19, 87:9
tax [176] - 33:18,
33:22, 34:6, 34:8,
34:17, 34:20, 34:24,
35:3, 35:4, 36:15,
38:3, 38:4, 38:6,
40:13, 41:1, 41:7,
41:10, 41:18, 43:12,
43:18, 44:25, 45:15,
46:8, 46:19, 46:22,
46:24, 47:16, 49:20,
49:21, 51:11, 54:12,
54:16, 54:18, 55:11,
55:14, 55:17, 57:24,
58:3, 59:15, 59:18,
60:14, 61:2, 61:19,
62:10, 63:11, 63:14,
64:17, 64:19, 64:21,
65:5, 65:20, 66:8,
67:9, 67:20, 67:24,
68:2, 69:1, 69:3,
70:24, 71:3, 71:8,
71:24, 72:16, 73:13,
73:15, 73:19, 74:8,
75:8, 75:15, 75:18,
75:20, 76:1, 76:3,
76:6, 79:6, 79:14,
79:15, 80:8, 80:10,
80:14, 81:10, 81:16,
81:22, 82:2, 82:23,
83:6, 83:8, 83:15,
87:21, 88:5, 88:14,
90:7, 90:10, 90:17,
90:23, 91:18, 91:20,
93:3, 93:5, 93:17,
94:5, 96:6, 99:6,
99:17, 100:8, 100:11,
100:13, 100:19,
101:1, 101:8, 101:10,
101:24, 102:4, 102:7,
104:9, 104:10, 108:5,
114:11, 114:12,
114:20, 114:22,
114:24, 116:6,
116:25, 119:1, 132:5,
135:6, 138:9, 138:22,
138:25, 141:16,
142:6, 145:24,
148:12, 149:21,
150:15, 151:3,
157:15, 184:21,
185:4, 185:25, 187:2,
187:4, 200:2, 200:20,
201:25, 202:16,
204:3, 205:6, 206:13,
208:14, 208:20,
212:3, 212:12,
215:13, 215:15,
229:11, 236:2,
241:18, 241:21,
242:20, 244:13,
245:16, 245:20,
246:8, 247:14,
247:21, 248:6
tax-law [1] - 80:14
taxable [3] - 37:10,
45:14, 84:4
Taxes [19] - 61:4,
75:9, 133:23, 134:16,
137:21, 138:1, 138:4,
141:22, 142:5,
142:13, 143:11,
143:14, 149:2,
149:23, 150:16,
151:24, 152:18,
153:23, 159:9
taxes [34] - 35:6,
42:22, 64:13, 65:14,
68:7, 68:8, 68:12,
75:10, 75:17, 82:10,
83:14, 84:2, 95:11,
96:9, 97:21, 98:7,
98:11, 99:22, 185:18,
200:2, 200:21,
200:23, 202:6,
202:14, 202:21,
207:21, 208:8,
209:25, 211:16,
211:17, 212:10,
212:19, 242:14,
242:16
Taxes@gmail.com
[2] - 112:13, 113:23
Taxpayer [2] - 55:13,
61:13
taxpayer [92] - 38:1,
39:15, 39:16, 39:18,
39:25, 41:11, 41:14,
41:17, 43:24, 45:13,
49:10, 49:11, 51:16,
52:3, 52:20, 53:14,
53:24, 54:13, 54:17,
54:18, 54:21, 55:1,
56:11, 56:13, 57:9,
57:14, 57:15, 57:16,
57:20, 58:1, 58:17,
62:3, 62:8, 64:9,
64:21, 65:2, 65:10,
65:13, 65:21, 65:25,
66:5, 66:8, 66:16,
66:23, 69:13, 69:14,
69:23, 70:3, 70:7,
70:18, 70:21, 70:24,
71:1, 71:5, 71:20,
71:23, 72:17, 72:21,
72:22, 73:6, 73:7,
73:13, 73:16, 73:22,
73:23, 73:25, 74:5,
74:6, 74:11, 79:14,
81:1, 82:9, 82:15,
82:19, 82:23, 83:1,
85:21, 86:2, 87:20,
88:3, 90:18, 93:11,
95:7, 99:6, 99:18,
99:20, 100:17,
100:25, 101:3, 102:3,
102:11
taxpayer's [9] -
43:18, 43:20, 53:2,
64:3, 65:15, 69:22,
73:20, 74:7, 82:11
taxpayers [1] - 53:11
TCO [3] - 82:1,
90:15, 101:2
TCO's [1] - 96:10
teacher [1] - 191:16
team [16] - 111:9,
111:22, 192:18,
192:19, 192:23,
192:25, 193:13,
193:19, 194:1, 194:9,
194:11, 198:19,
198:25, 235:10,
239:7, 239:25
technical [1] - 34:12
Technology [1] -
129:14
Telephone [4] -
69:12, 71:18, 72:14,
73:11
telephone [11] -
17:24, 21:6, 51:20,
53:18, 55:5, 63:25,
70:6, 139:24, 140:20,
140:22, 156:10
ten [5] - 4:5, 170:13,
187:23, 187:24, 188:1
tentative [2] - 43:3,
45:10
term [6] - 67:20,
67:21, 192:2, 193:23,
230:21, 243:2
terminated [5] -
21:23, 30:21, 30:24,
31:2, 31:24
termination [5] -
21:24, 22:3, 22:13,
30:22, 30:23
terms [7] - 25:5,
25:22, 33:15, 147:7,
206:25, 211:17,
211:18
terrible [2] - 46:23,
89:8
test [3] - 239:20,
239:21, 239:24
testified [21] - 5:2,
32:16, 42:9, 93:7,
95:12, 103:9, 110:23,
148:8, 162:13, 164:8,
178:16, 190:5,
236:24, 238:11,
239:16, 240:12,
240:17, 240:20,
241:15, 249:25, 250:7
testify [12] - 76:24,
187:18, 187:20,
188:11, 188:12,
188:19, 189:2, 189:3,
189:5, 241:1, 241:5
testifying [3] - 8:7,
18:20, 249:23
testimony [18] -
24:17, 34:16, 50:3,
55:11, 59:14, 59:15,
63:11, 71:6, 74:8,
82:12, 93:19, 129:21,
151:16, 151:17,
159:10, 167:6,
187:18, 246:19
text [4] - 233:25,
234:2, 234:8, 242:8
THE [175] - 1:10,
1:13, 1:21, 4:3, 4:9,
4:11, 4:14, 4:16, 4:20,
5:3, 5:4, 5:8, 5:9,
7:23, 7:25, 8:20, 9:3,
9:8, 13:25, 19:13,
22:10, 22:22, 23:19,
23:22, 23:24, 27:23,
30:14, 32:5, 32:8,
32:11, 32:17, 32:18,
32:21, 32:23, 36:1,
49:16, 50:17, 59:6,
59:8, 59:11, 61:22,
62:14, 62:22, 62:24,
63:3, 77:20, 83:19,
91:24, 92:3, 92:9,
29
92:15, 92:19, 92:22,
98:19, 101:19,
102:14, 102:22,
102:25, 103:5,
103:10, 103:11,
103:13, 103:14,
111:15, 113:17,
118:5, 118:7, 118:9,
123:10, 133:10,
133:18, 137:6, 137:8,
140:9, 140:13,
145:11, 147:21,
148:21, 149:11,
149:14, 151:11,
154:8, 154:11, 158:1,
158:7, 158:11,
159:20, 160:6, 160:9,
177:2, 177:5, 177:16,
177:21, 178:4,
178:24, 179:3,
179:11, 179:17,
179:21, 180:3, 180:5,
180:14, 180:22,
181:1, 181:7, 181:14,
182:20, 182:22,
183:4, 183:5, 183:22,
183:24, 184:2, 184:6,
187:10, 187:19,
187:24, 188:1, 188:5,
188:9, 188:14,
188:15, 189:4, 189:5,
189:7, 189:8, 189:11,
189:12, 189:17,
189:24, 190:6, 190:7,
190:10, 190:11,
193:5, 193:6, 212:5,
212:7, 222:6, 222:10,
222:12, 222:23,
223:1, 223:4, 223:8,
223:12, 223:14,
223:23, 224:9,
224:12, 224:14,
231:15, 231:20,
232:19, 232:21,
233:8, 233:9, 234:8,
234:11, 234:13,
234:14, 234:21,
236:7, 245:22,
245:24, 246:2,
248:21, 249:5,
249:17, 249:21,
249:25, 250:4,
250:10, 250:14,
250:20
themselves [3] -
16:4, 43:24, 148:4
Therapeutics [1] -
130:15
therefore [1] - 54:16
Thereupon [4] -
4:24, 32:13, 103:6,
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 281 of
283
190:2
Third [1] - 37:23
third [3] - 38:1, 38:2,
87:7
third-party [1] - 87:7
Thomas [1] - 99:9
Thompson [1] -
159:11
thousand [4] -
126:14, 127:6, 209:1,
215:25
threat [1] - 213:9
threatened [1] -
189:9
three [16] - 14:9,
14:21, 125:12, 127:3,
129:11, 137:17,
140:7, 143:1, 143:18,
145:21, 161:9,
171:19, 172:12,
188:15, 188:23,
194:14
threshold [1] - 169:4
throughout [4] -
5:25, 88:6, 185:3,
198:24
Thursday [1] -
152:15
tickets [1] - 240:21
timeline [2] - 139:21,
167:14
timestamp [12] -
126:22, 129:18,
135:13, 136:1, 136:9,
137:3, 137:10,
137:13, 139:3, 143:3,
144:10
timing [5] - 130:23,
132:16, 171:16,
185:20, 187:1
tips [1] - 36:22
Titan [1] - 198:23
title [5] - 33:9, 67:18,
78:9, 144:22, 227:4
Title [3] - 104:10,
104:11, 104:12
today [20] - 8:7, 14:7,
18:20, 23:5, 23:13,
49:24, 50:4, 65:3,
76:2, 78:1, 150:16,
152:2, 162:24,
181:15, 182:13,
182:14, 220:18,
241:3, 246:8, 246:19
today's [1] - 34:16
Todd [1] - 115:12
together [10] - 56:20,
57:22, 95:2, 95:9,
160:24, 185:1,
185:11, 218:21,
247:15, 249:10
toll [1] - 196:14
tomorrow [2] -
249:16, 250:5
ton [1] - 36:18
tonight [1] - 70:8
Tonya [5] - 103:3,
103:13, 179:22,
181:12, 243:20
TONYA [3] - 2:14,
103:7, 181:17
took [5] - 55:11,
84:23, 100:17,
196:14, 206:16
top [17] - 9:12, 9:19,
10:1, 16:1, 17:16,
17:17, 31:18, 51:5,
58:15, 74:19, 109:1,
125:3, 146:1, 150:13,
159:5, 215:6, 240:12
total [16] - 42:25,
45:10, 45:14, 45:15,
45:17, 77:6, 97:10,
116:23, 128:7,
128:11, 128:13,
129:16, 130:17,
225:18, 226:5
totalling [1] - 135:6
touch [1] - 120:9
touched [1] - 147:4
tough [1] - 194:16
toughest [1] - 194:14
TP [9] - 52:18, 52:19,
53:24, 56:21, 57:13,
73:13, 74:4, 74:10,
81:1
TP's [1] - 65:17
track [1] - 92:16
traffic [1] - 240:21
train [2] - 194:13,
199:12
trained [3] - 80:14,
199:10, 238:3
training [12] - 6:24,
7:3, 7:5, 10:19, 26:22,
80:7, 125:22, 199:2,
214:24, 215:7,
237:25, 240:15
trainings [2] - 105:2,
105:8
transaction [12] -
125:12, 125:17,
126:1, 128:16, 169:7,
169:8, 169:14,
169:20, 170:1,
171:17, 171:18,
177:12
transactional [1] -
127:16
transactions [12] -
122:21, 123:24,
123:25, 124:16,
124:25, 127:25,
128:21, 129:10,
168:22, 169:3,
169:25, 172:12
transcription [1] -
252:4
transcripts [1] -
237:20
Transfer [1] - 130:24
transfer [15] -
120:15, 122:9, 125:4,
126:15, 126:17,
127:1, 127:7, 127:9,
127:11, 131:3, 131:5,
131:6, 167:13,
192:13, 193:24
transferred [8] -
120:23, 121:1, 121:3,
122:16, 192:16,
192:17, 236:17,
238:13
transferring [1] -
120:15
transmit [2] - 85:20,
85:23
travel [5] - 42:23,
45:8, 45:9, 98:9
traveled [1] - 168:21
traveling [1] - 77:17
Treasury [2] - 121:7,
122:1
trees [1] - 153:16
TREVOR [1] - 1:13
trevor.jones@
usdoj.gov [1] - 1:16
trial [9] - 50:10,
107:19, 112:1,
152:21, 182:25,
188:18, 197:1,
240:18, 248:23
TRIAL [1] - 1:10
tried [7] - 65:21,
90:19, 168:22, 170:8,
195:11, 206:7, 214:17
trigger [2] - 125:15,
177:12
triggered [2] -
169:22, 170:1
trip [1] - 248:25
trouble [2] - 31:5,
219:17
truck [2] - 42:21,
45:6
true [18] - 30:1,
34:10, 39:12, 61:16,
61:25, 79:6, 79:9,
79:17, 83:5, 83:13,
90:13, 90:22, 91:10,
161:18, 162:12,
167:23, 175:16,
242:10
Truist [2] - 59:7
truly [1] - 176:21
trust [9] - 202:7,
202:23, 203:17,
203:18, 203:19,
209:18, 235:21,
236:1, 236:5
trusted [4] - 202:4,
202:5, 213:10, 235:11
trusting [1] - 235:12
truth [7] - 241:6,
241:8, 241:10,
241:11, 244:1
truthful [1] - 216:3
try [5] - 54:22, 72:18,
185:24, 195:13,
198:14
trying [7] - 107:8,
107:9, 115:16,
194:21, 195:16,
215:2, 218:13
tryout [5] - 195:2,
195:3, 214:17,
214:19, 214:21
tryouts [2] - 195:18,
198:14
turn [3] - 27:22, 35:1,
159:23
turning [1] - 151:18
twice [8] - 83:8,
83:15, 83:20, 84:8,
195:2, 200:25,
207:24, 240:25
two [28] - 9:22,
47:18, 49:3, 49:5,
67:8, 72:11, 82:3,
82:4, 98:16, 99:22,
114:11, 143:1,
150:17, 168:2,
178:13, 180:18,
184:16, 185:5, 191:9,
196:22, 228:17,
228:19, 228:23,
233:23, 234:11,
247:5, 248:6
two-time [1] - 191:9
type [13] - 11:16,
17:25, 21:7, 41:16,
43:14, 58:15, 106:8,
108:8, 117:6, 128:20,
134:7, 135:1, 201:20
types [3] - 106:23,
110:2, 117:10
U
U.S [14] - 35:3,
30
36:14, 43:12, 46:8,
50:9, 56:4, 67:13,
69:9, 105:9, 243:11,
244:17, 244:18,
245:1, 250:11
ultimately [6] - 6:1,
77:12, 111:5, 155:17,
179:24, 236:19
um-hmm [3] - 48:9,
169:5, 171:22
unable [2] - 90:19,
152:21
unaccounted [1] -
134:10
unadmitted [1] -
162:9
unagreed [2] - 73:4,
73:16
under [5] - 17:13,
25:24, 39:10, 53:14,
181:15
underlying [1] -
184:11
underneath [1] -
125:9
understandable [1] -
179:14
understood [1] -
82:6
undertaken [1] -
16:20
undo [3] - 120:22,
143:22, 157:10
unfortunately [1] -
109:17
unimportant [1] -
26:10
Union [2] - 230:2,
230:8
unique [2] - 39:2,
227:16
UNISON [1] - 9:7
unit [6] - 192:20,
193:2, 238:16,
239:12, 239:14, 240:8
Unit [1] - 198:23
United [3] - 94:15,
105:18, 252:9
united [1] - 2:3
UNITED [3] - 1:1,
1:4, 1:11
units [1] - 240:9
university [1] - 191:4
University [3] -
191:7, 236:16, 236:20
unless [3] - 110:4,
204:21, 227:21
unpack [1] - 38:4
unpaid [1] - 68:11
unsupported [3] -
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 282 of
283
68:4, 98:3, 248:16
unusual [2] - 31:19,
31:25
up [55] - 4:13, 5:4,
9:25, 10:1, 10:12,
26:3, 27:21, 45:14,
47:20, 56:2, 56:21,
57:21, 61:7, 62:12,
63:10, 66:24, 70:17,
70:20, 72:22, 74:5,
76:12, 78:2, 89:2,
94:8, 95:9, 115:4,
132:21, 136:9,
142:17, 153:10,
153:21, 155:1,
157:23, 158:20,
166:1, 167:19,
170:12, 170:16,
177:22, 177:23,
181:14, 194:7,
194:22, 196:6,
207:13, 210:9,
214:25, 215:1,
215:10, 221:11,
227:13, 228:17,
234:4, 236:3, 246:18
upcoming [2] - 12:4,
55:1
update [4] - 13:4,
149:24, 150:7, 150:9
Updated [1] - 70:14
updated [5] - 12:17,
12:21, 12:22, 76:16
upper [1] - 151:1
US [1] - 1:18
USAO [1] - 1:14
user [1] - 113:5
utilities [1] - 147:1
utilizing [1] - 114:2
V
Valdosta [2] - 191:7,
236:19
valid [2] - 21:6, 34:10
valor [1] - 42:2
Valor [1] - 43:5
Valordog [4] - 115:7,
115:22, 159:10,
164:11
value [1] - 128:13
vapor [2] - 193:4,
193:6
VELAZCO [2] - 2:2,
252:8
Velazco [1] - 252:7
verdict [1] - 187:7
verify [6] - 115:16,
117:2, 117:4, 132:21,
146:9, 167:8
Verizon [4] - 140:1,
140:19, 141:7, 155:21
version [2] - 106:17,
249:12
versus [2] - 110:3,
185:21
via [3] - 54:18, 57:13,
145:17
vice [1] - 193:21
VICTORIA [2] - 2:12,
32:14
Victoria [2] - 32:12,
32:21
Victory [27] - 39:6,
40:20, 46:3, 47:14,
58:14, 61:4, 75:9,
87:9, 112:13, 113:23,
133:23, 134:16,
137:20, 138:1, 138:3,
141:22, 142:5,
142:13, 143:11,
143:14, 149:1,
149:23, 150:15,
151:24, 152:18,
153:23, 159:9
Victorytaxes@
gmail.com [2] - 112:9,
242:6
victorytaxes@
gmail.com [1] - 159:3
view [2] - 153:17,
244:15
viewed [1] - 174:11
Vilsaint [19] - 40:5,
47:12, 53:11, 55:12,
57:2, 75:8, 82:15,
95:4, 105:15, 112:13,
113:7, 138:14,
141:12, 141:13,
150:7, 155:6, 156:7,
179:8, 185:8
violation [3] - 28:15,
28:16, 28:17
violations [7] -
30:25, 104:12,
104:24, 105:3,
105:20, 238:7, 238:8
violent [2] - 199:5,
199:8
voicemail [1] - 65:22
voted [1] - 191:23
vs [1] - 1:6
W
W-2 [5] - 45:13,
56:14, 75:11, 201:9,
211:19
wage [1] - 35:17
wages [4] - 36:22,
86:20, 134:9, 176:24
wait [3] - 71:3, 193:5,
231:15
waiting [1] - 150:24
wake [2] - 193:4,
193:6
walk [1] - 214:13
walking [1] - 156:21
wants [3] - 11:12,
187:4, 189:2
warrant [4] - 114:2,
124:3, 124:5, 179:6
warranted [1] - 53:1
warrants [1] - 124:14
waste [1] - 106:7
weaknesses [1] -
195:24
weapons [1] -
239:10
wearing [4] - 182:16,
182:17, 182:20,
194:19
webinar [1] - 228:6
website [2] - 6:22,
24:23
Wednesday [5] -
126:17, 127:9,
154:19, 199:12,
227:17
week [1] - 152:21
weeks [2] - 194:14,
209:22
Welcome [1] - 4:20
welcome [4] - 63:3,
102:25, 158:11,
189:17
West [3] - 192:12,
192:14, 238:10
whereas [1] - 26:8
White [1] - 237:13
whittled [1] - 186:1
whole [11] - 48:23,
88:21, 196:5, 207:17,
212:23, 219:9,
227:23, 235:3, 241:6,
241:10, 244:1
whoops [1] - 82:19
wife [11] - 99:9,
157:24, 158:21,
158:24, 185:6, 185:9,
200:7, 218:6, 218:14,
242:13, 247:4
wife's [1] - 203:7
willfulness [1] -
186:17
Williams [3] - 20:3,
20:17, 20:24
window [1] - 227:20
windows [1] -
154:23
wire [6] - 167:12,
168:19, 184:17,
186:14, 186:20,
225:15
wired [2] - 168:12,
230:5
wiring [1] - 230:22
wish [1] - 234:23
wishes [1] - 187:18
withdrawal [1] -
122:22
WITNESS [20] - 2:9,
5:3, 5:8, 32:17, 32:21,
103:10, 103:13,
160:9, 182:20, 183:5,
190:6, 190:10, 193:6,
212:5, 231:20,
232:21, 233:9,
234:11, 234:14, 246:2
Witness [3] - 32:10,
102:15, 177:18
witness [23] - 4:6,
4:22, 5:1, 7:20, 32:4,
32:11, 32:15, 33:10,
33:12, 33:13, 34:7,
34:9, 92:1, 103:2,
103:8, 119:6, 177:19,
178:15, 180:1, 188:7,
189:6, 189:25, 249:14
witnesses [3] -
249:18, 250:8, 250:12
wondering [2] -
138:24, 149:4
word [1] - 83:21
words [2] - 85:2,
194:10
worker [1] - 147:2
works [1] - 40:19
world [1] - 185:17
worst [1] - 185:17
write [3] - 38:23,
71:1, 138:17
writing [1] - 88:20
written [5] - 70:25,
74:8, 81:23, 164:13,
165:4
wrote [2] - 81:24,
213:1
X
Xfinity [2] - 109:12,
109:13
Y
YAACOV [1] - 1:21
yards [2] - 195:7
year [53] - 10:20,
12:2, 12:4, 12:6, 12:7,
31
12:9, 18:11, 18:12,
20:4, 20:14, 20:21,
21:22, 28:8, 31:13,
35:4, 35:5, 35:6,
36:15, 41:11, 45:15,
45:16, 46:19, 46:22,
47:2, 48:3, 48:11,
53:18, 57:10, 63:11,
68:2, 68:9, 68:10,
69:1, 69:3, 88:5,
95:11, 96:22, 97:14,
146:19, 187:4,
191:20, 195:14,
195:15, 196:5,
201:16, 209:25,
210:18, 219:4,
221:12, 221:13,
241:19
year-to-date [1] -
201:16
years [33] - 5:18, 6:4,
12:15, 19:1, 28:9,
28:20, 31:1, 31:11,
31:13, 33:8, 34:17,
34:24, 35:5, 49:21,
51:8, 51:10, 51:11,
56:12, 67:25, 68:1,
68:12, 75:10, 75:14,
75:17, 96:5, 96:9,
104:5, 150:11,
199:25, 212:3, 219:6,
242:2, 248:6
yellow [3] - 143:10,
170:20, 213:1
yesterday [4] -
162:14, 164:9, 174:6,
178:15
young [1] - 196:22
yourself [3] - 5:4,
32:18, 34:14
Z
zero [2] - 49:5, 226:6
zeros [1] - 96:24
zone [6] - 137:11,
161:8, 161:15,
161:19, 162:25, 163:3
zones [3] - 161:9,
162:2, 162:3
zoom [4] - 78:19,
226:9, 232:11, 233:19
Case 0:23-cr-60170-RNS Document 135 Entered on FLSD Docket 11/26/2024 Page 283 of
283File and source
- File
- gov.uscourts.flsd.654235.135.0.pdf
- Size
- 749,018 bytes
- SHA-256
- a964e306ef36006a5b7de13f9ff6aabc436a447c7cb3693971f038d9fccfe3c2
- Original
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