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Home Court filings USA v. Thomas et al — Amanda Christian filings, N.D. Ga., Atlanta TRANSCRIPT of Proceedings as to Darrell Thomas, Andre Lee Gaines, Kahlil Gibran Green,……

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TRANSCRIPT of Proceedings as to Darrell Thomas, Andre Lee Gaines, Kahlil Gibran Green,… — USA v. Thomas et al (Dkt. 895)

Record facts

CourtU.S. District Court for the Northern District of Georgia
Filed2024-02-02

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 895 · 2024-02-02 · Docket on CourtListener

Summary

A transcript of the September 17, 2021 change of plea hearing for Andre Lee Gaines before District Judge J.P. Boulee of the U.S. District Court for the Northern District of Georgia, captioned under 1:20-cr-00296-JPB and 1:21-cr-00206-JPB and filed February 2, 2024 as Document 895. Tal Cohen Chaiken for the government verifies the signatures on the Guilty Plea and Plea Agreement, and Brian Mendelsohn appears for Gaines. After the court and counsel address Gaines's competence to enter a plea, Mendelsohn states that Gaines is pleading to the false statement charge as opposed to the fraud charge. The court explains his right to indictment by a grand jury, which he waives to proceed on an information, and the trial rights given up by pleading guilty. It refers the case to a probation officer for a presentence report.

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

Full text

THE FOLLOWING IS THE PDF OF AN OFFICIAL 
TRANSCRIPT.  OFFICIAL TRANSCRIPTS MAY ONLY BE FILED IN CM/ECF 
BY THE OFFICIAL COURT REPORTER AND WILL BE RESTRICTED IN 
CM/ECF FOR A PERIOD OF 90 DAYS.  YOU MAY CITE TO A PORTION 
OF THE ATTACHED TRANSCRIPT BY THE DOCKET ENTRY NUMBER, 
REFERENCING PAGE AND LINE NUMBER, ONLY AFTER THE COURT 
REPORTER HAS FILED THE OFFICIAL TRANSCRIPT; HOWEVER, YOU ARE 
PROHIBITED FROM ATTACHING A FULL OR PARTIAL TRANSCRIPT TO ANY 
DOCUMENT FILED WITH THE COURT. 
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
1
    UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION 
UNITED STATES OF AMERICA,
)
)
)
-VS-
) DOCKET NO. 1:20-CR-00296-JPB
)
   1:21-CR-00206-JPB
ANDRE LEE GAINES,
)
)
DEFENDANT.
)
TRANSCRIPT OF CHANGE OF PLEA PROCEEDINGS
BEFORE THE HONORABLE J.P. BOULEE
UNITED STATES DISTRICT JUDGE
SEPTEMBER 17, 2021
APPEARANCES:
ON BEHALF OF THE GOVERNMENT: 
TAL COHEN CHAIKEN, ESQ.
NATHAN KITCHENS, ESQ.
ASSISTANT UNITED STATES ATTORNEY
ON BEHALF OF THE DEFENDANT:
BRIAN MENDELSOHN, ESQ.
STENOGRAPHICALLY RECORDED BY:  
PENNY PRITTY COUDRIET, RMR, CRR
OFFICIAL COURT REPORTER
UNITED STATES DISTRICT COURT 
ATLANTA, GEORGIA
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(PROCEEDINGS HELD IN OPEN COURT AT 3:09 PM, ATLANTA, GEORGIA) 
THE COURT:  Good afternoon to all of you.  And 
apologies again.  I know that we were originally set for 2:30 
and it's 3:15, but we just had a sentencing that went a little 
bit longer -- well, a lot longer than we had expected.  So my 
apologies to counsel, Mr. Gaines and any family or friends 
that may also be here.  
So with that, Ms. Walker, if you could call the case 
and then if counsel could announce their appearances. 
COURTROOM DEPUTY CLERK:  Yes, your Honor.  This is 
case number 21-CR-206 and 20-CR-296, USA v. Gaines. 
MS. CHAIKEN:  Good afternoon, your Honor.  Tal 
Chaiken and Nathan Kitchens from the US Attorney's Office for 
the United States. 
THE COURT:  Good afternoon to both of you. 
MR. MENDELSOHN:  Good afternoon.  Brian Mendelsohn 
here with Mr. Gaines. 
THE COURT:  Good to see you, Mr. Mendelsohn.  
And, Mr. Gaines, good to see you as well, sir. 
Mr. Mendelsohn, if you and Mr. Gaines will please 
stand, Ms. Walker will swear him in. 
(The defendant was duly sworn)
COURTROOM DEPUTY CLERK:  Please say your name into 
the microphone, please. 
THE DEFENDANT:  Andre Lee Gaines. 
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THE COURT:  Thank you, Ms. Walker. 
Ms. Chaiken, if you can please verify the signatures 
on the plea agreement. 
MS. CHAIKEN:  Yes, your Honor.  
Mr. Gaines, I'm showing you a document that's titled 
"Guilty Plea and Plea Agreement."  On page 18 above where it 
says your name, is that your signature?  
THE DEFENDANT:  Yes. 
MS. CHAIKEN:  And, Mr. Mendelsohn, on page 18 above 
where it says your name, is that your signature?  
MR. MENDELSOHN:  Yes, it is. 
MS. CHAIKEN:  And for the record, this page 18 is 
also signed by a representative for the United States.  
Mr. Gaines, on page 19 above where it says your name, 
is that your signature?  
THE DEFENDANT:  Yes. 
MS. CHAIKEN:  Mr. Mendelsohn, on page 20 above where 
it says your name, is that your signature?  
MR. MENDELSOHN:  Yes, it is. 
MS. CHAIKEN:  Your Honor, may I tender the plea 
agreement?  
THE COURT:  Sure.  
Mr. Gaines, before I can accept your plea of guilty, 
I need to go over several matters with you.  As we go through 
this process, if anything I state is unclear, let me know and 
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I will repeat or rephrase it for you.  It's important that you 
understand not only my statements to you but also my 
questions.  You need to understand my questions so that you 
can answer them truthfully.  A failure to truthfully answer 
any question could result in additional charges being brought 
against you.  
Also, as I ask questions, please answer the questions 
out loud.  This will allow the court reporter to take down 
your responses so we can have an accurate record of these 
proceedings.  
Do you understand, sir?  
THE DEFENDANT:  Yes. 
THE COURT:  How old are you, sir?  
THE DEFENDANT:  Sixty-seven. 
THE COURT:  How far did you go in school?  
THE DEFENDANT:  One year in college.
THE COURT:  In the last 24 hours have you had any 
drugs, medicine, pills or had any alcoholic beverages to 
drink?  
THE DEFENDANT:  No alcohol.  I took my regular pills. 
THE COURT:  Do they affect your judgment or actions 
in any manner or your ability to understand these proceedings 
and enter a knowing plea?  
THE DEFENDANT:  No. 
THE COURT:  Have you been treated recently for any 
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mental illness or addiction to alcohol or drugs?  
THE DEFENDANT:  No. 
THE COURT:  And, Mr. Mendelsohn, are you aware of any 
issues regarding your client's competence to enter a plea?  
MR. MENDELSOHN:  Judge, he's -- I believe he is 
competent to enter a plea.  And as I'm sure we'll talk about 
later on, he does have a number of cognitive impairments as a 
result of a stroke that he had in or around 2018, but he is 
able to assist me and does -- and understands the parties and 
would satisfy the competency standards. 
THE COURT:  So I understand he had a stroke.  When 
was that?  
MR. MENDELSOHN:  Approximately 2018.
THE COURT:  Okay.  
Mr. Gaines, when you answered my questions earlier, I 
asked a follow-up question about your medicine.  And you 
mentioned that despite your medicine, you could still 
understand these proceedings and enter a knowing plea.  
Let me ask you a little bit about your stroke there.  
And, again, I just want to make sure that you understand these 
proceedings and are competent to enter this plea.  I'm not 
trying to otherwise or for any reason pry into your medical 
condition, but can you tell me a little bit about your stroke 
and how that has affected you. 
THE DEFENDANT:  It's affected me somewhat but not 
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much anymore. 
THE COURT:  Can you expand on that for me?  When you 
say it doesn't affect you much anymore, what's the current 
effect of your stroke?  
THE DEFENDANT:  Just that it's hard for me to walk 
now.  And my left side, my muscles, it's hard for me to lift. 
THE COURT:  It's more physical as opposed to any 
mental issues that are affecting your competence, is that 
right?  
THE DEFENDANT:  Right. 
MR. MENDELSOHN:  Judge, I don't want to mislead the 
Court any.  I have had Mr. Gaines evaluated by a geriatric 
neuropsychologist.  And I've shared that report with the 
government.  And in part because of that report is why we're 
pleading to the false statement charge as opposed to the fraud 
charge.  
The report found that he suffers from cognitive 
problems and has some vascular dementia.  What that -- the 
impact that that has on him is that it causes some memory 
issues and some difficulties with executive function, so the 
logic, reasoning, decisionmaking ability to process lots of 
information.  
Because of that, we have spent a lot of time going 
over it.  I mean, it's not one of these things that it's 
impossible he can't do, the stroke has impacted that and 
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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caused him some cognitive impairments.  But with the work of 
going over the information with him, spending a lot of time 
doing it and working with him, he is able to understand and to 
do it.  I mean, the difficulty comes in things like throwing a 
lot of information at him really quickly and having him try to 
sort all of that out.  But since we have been able to spend a 
lot of time going over everything, he can be -- he can 
understand and he can do it.  
THE COURT:  Okay.  
Mr. Gaines, do you agree with what your attorney just 
said?  
THE DEFENDANT:  Yes. 
THE COURT:  What's the government's position on this, 
Ms. Chaiken?  It sounds like it's something y'all have had 
some discussions about and evaluation of.  
MS. CHAIKEN:  Yes, your Honor.  We defer to 
Mr. Mendelsohn's -- he's obviously spent a lot more time   
with his client.  We have engaged in discussions with him 
especially after receiving the psychological evaluation, and 
that is what led to the agreement that we've made here today 
to have Mr. Gaines plead to a much lesser charge than what he 
was initially charged with.  
And as far as his competence to enter his -- this 
plea, we defer to Mr. Mendelsohn, who we understand has had 
lengthy meetings with him leading up to this proceeding. 
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THE COURT:  Okay.  Well, I'm satisfied based on what 
I've heard that both Mr. Gaines and Mr. Mendelsohn are aware 
of the issue and have discussed the issue and feel that 
Mr. Gaines is competent to enter a plea, but what I'm hearing 
is that we want to make sure that we're going slow enough and 
not throwing enough -- all at the same time that it gets 
confusing.  
So I'm going to move a little bit slower than I 
normally would.  And, Mr. Gaines, if we get to the point that 
you feel like it's too much and you don't understand, let me 
know or let your attorney know and we will either take a break 
and rejoin later today or we can do part of it today, part of 
it next week, part of it the week after that.  
The bottom line is it sounds like we just need to 
make sure we're going slow and make sure you're digesting 
this.  And you're going to need to be the one telling me.  
And, Mr. Mendelsohn, I'll be looking to you as well 
to be checking in with your client.  
Okay, Mr. Gaines?  
THE DEFENDANT:  Yes. 
THE COURT:  All right.  What I'm going to do first  
is go over the rights that you're guaranteed under the 
Constitution and laws of the United States.  I want to be sure 
that you understand your rights and that by entering this plea 
of guilty, you're giving up many of your rights.  
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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The first thing I want to talk to you about is the 
fact that you were charged here by an information as opposed 
to an indictment.  
Under the Constitution and laws of the United States 
you have the right to be -- right to require the government to 
present your case to a grand jury for indictment before 
entering a plea.  The grand jury would receive evidence only 
from the government.  And based on that evidence, the grand 
jury would determine if there was sufficient evidence 
presented to require you to answer the charges.  If you waive 
or give up your right to an indictment, charges may be brought 
against you by means of an information filed by the United 
States Attorney.  
The charges in your case have been brought by an 
information.  Are you willing to give up your right to require 
the government to first present the charges to a grand jury 
and proceed on the information that's been filed by the United 
States Attorney?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that under the 
Constitution and laws of the United States you have the right 
to plead not guilty and have a trial by jury?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that you're entitled to 
a speedy and public trial on the charges against you?  
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THE DEFENDANT:  Yes. 
THE COURT:  Bear with me a moment.  
I'm sorry, I said "charges against you."  I should 
have said the charge against you.  
Do you understand that you have the right to be 
represented by an attorney throughout all proceedings, and if 
you cannot afford an attorney, one will be appointed to 
represent you at no cost to you?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that if you pled not 
guilty and went to trial, at the trial you would be presumed 
to be innocent and the government would have to overcome that 
presumption and prove you guilty beyond a reasonable doubt?
THE DEFENDANT:  Yes.
THE COURT:  Do you understand that at a trial you 
would not have to prove that you're innocent because the 
burden would be on the government to prove you guilty beyond a 
reasonable doubt?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that at a trial you 
would have the right to subpoena witnesses, which would be an 
order from the Court compelling their appearance at trial to 
testify on your behalf?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that during a trial 
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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witnesses for the government must come to court and testify in 
your presence?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that your attorney 
would have the opportunity to cross-examine the witnesses for 
the government, object to evidence offered by the government 
and offer evidence on your behalf?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that at a trial, while 
you would have the right to testify if you chose to do so, you 
also would have the right not to testify?  
THE DEFENDANT:  Yes. 
THE COURT:  And do you understand that if you chose 
not to testify or put on any evidence, those facts could not 
be used against you?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that in order to 
convict you at a trial, the jury would have to reach a 
unanimous verdict that you were guilty of the crime with which 
you're charged?  
THE DEFENDANT:  Yes. 
THE COURT:  If I accept your plea of guilty, you will 
not have a trial and a jury will not decide your guilt, but I 
will find that you're guilty of the charge based on your 
admission that you're guilty.  Do you understand that?  
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THE DEFENDANT:  Yes. 
THE COURT:  Are you willing to give up your right to 
a trial and proceed with the plea of guilty at this time?  
THE DEFENDANT:  Yes. 
THE COURT:  I'm about to move on to, I guess, the 
second group of questions.  Are you okay to go forward now or 
would you like a short break?  
THE DEFENDANT:  Yes.  
MR. MENDELSOHN:  Are you ready to go forward or do 
you want a break?  
THE DEFENDANT:  To go forward? 
THE COURT:  I took that to say, yes, you're okay to 
go forward, sir?  
THE DEFENDANT:  Yes. 
THE COURT:  You earlier verified your signature on 
the plea agreement that you entered into with the government.  
In a moment, I will ask the Assistant US Attorney to review 
the terms of the plea agreement other than the potential 
penalties and the factual basis of the plea, which we will 
discuss a bit later in the proceeding.  
After that I'll be asking you whether the agreement 
as presented accurately reflects your understanding of the 
agreement that you've reached with the government.  
Ms. Chaiken. 
MS. CHAIKEN:  Thank you, your Honor.  
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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The plea agreement provides that Mr. Gaines will be 
pleading to Count 1 of the criminal information.  
Pursuant to paragraph 11, the government agrees to 
dismiss the indictment against the defendant in case number 
1:20-CR-296.  
Paragraph 12 sets forth that the government agrees 
not to bring further charges related to the charges to which 
Mr. Gaines is pleading guilty.  
Paragraphs 13 and 14 set forth a series of guideline 
stipulations.  Specifically, paragraph -- specifically the 
applicable offense guideline is Section 2B1.1, and that there 
will be no adjustment pursuant to Section 2B1.1(b)(1) because 
the amount of loss is $6,500 or less.  
Paragraph 15 provides that the government will 
recommend an adjustment for acceptance of responsibility to 
the maximum extent authorized by the guidelines subject to the 
exceptions that are listed in that paragraph.  
Paragraph 16 provides that the parties recognize  
each party reserves the right to make recommendations for 
sentencing and that there are no agreements on the guidelines 
other than those mentioned in the agreement.  
Paragraph 17 provides that the United States reserves 
the right to modify its sentencing recommendation if it 
receives additional information.  
Paragraph 18 provides a cooperation agreement, that 
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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the defendant agrees to cooperate truthfully and completely 
with the government, including producing all records 
requested, making himself available for interviews, responding 
truthfully to all government inquiries and at the government's 
request testifying at trial or other proceedings.  
Paragraph 19 provides that the government agrees to 
abide by Section 1B1.8 of the United States Sentencing 
Guidelines to not use information previously unknown to the 
government for sentencing purposes with the caveat that if the 
defendant is not truthful or candid in cooperation, he may be 
prosecuted for perjury, false statements, obstruction and all 
information he provided may be used against him.  
Paragraph 20 sets forth a conditional 5K and Rule 35 
motion.  The government agrees to inform the Court of the 
defendant's cooperation.  And if the government determines 
that that cooperation qualifies as substantial assistance, it 
will file a motion for downward departure if that happens 
before sentencing, or Rule 35 motion for reduction of sentence 
if that happens after sentencing.  
The defendant understands that the government alone 
determines if the defendant provided substantial assistance.  
And he understands that the government may recommend a 
sentence if it files such a motion but that the ultimate 
decision on his sentence rests with the Court.  
Paragraph 21 provides that the government agrees to a 
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low-end recommendation subject to the caveat in paragraph 15 
related to acceptance of responsibility.  
Paragraph 22 provides that the government agrees to 
make no specific recommendation as to the fine to be imposed.  
Paragraphs 23 through 28 provide that the defendant 
agrees to forfeiture of $177,828.46 seized from a JPMorgan 
Chase account held in the name of Gaines Reservation & Travel, 
and $9,314.28 from a PNC Bank account in the name of Gaines 
Reservation & Travel.  And the defendant agrees to the 
forfeiture procedure set forth in paragraphs 23 through 28.  
Paragraphs 29 through 30 provide that the defendant 
agrees to pay $806,710, plus applicable interest in 
restitution to the two victims and in the amounts identified 
in the plea agreement.  And that the defendant agrees to 
cooperate fully in the collection of restitution.  
Paragraph 31 provides that the defendant agrees to 
pay a special assessment of $100.  
Paragraphs 32 through 36 provide that the defendant 
agrees to cooperate fully in the collection of any restitution 
or fine pursuant to the terms that are laid out in those 
paragraphs.  
Paragraph 37 provides that the defendant understands 
the recommendations in the plea agreement are not binding on 
the Court.  
Paragraph 38 sets forth a limited waiver of appeal, 
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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which I will read in full into the record.  
To the maximum extent permitted by federal law, the 
defendant voluntarily and expressly waives the right to appeal 
his conviction and sentence and the right to collaterally 
attack his conviction and sentence in any post-conviction 
proceeding, including but not limited to motions filed 
pursuant to 28 United States Code, Section 2255, on any ground 
except that the defendant may file a direct appeal of an 
upward departure or upward variance above the sentencing 
guideline range as calculated by the district court.  
Claims that the defendant's counsel rendered 
constitutionally ineffective assistance are excepted from this 
waiver.  
The defendant understands that this plea agreement 
does not limit the government's right to appeal, but if the 
government initiates a direct appeal of the sentence imposed, 
the defendant may file a cross-appeal of that same sentence.  
Paragraph 39 sets forth the defendant agrees to the 
standard FOIA and Privacy Act waiver.  
And paragraph 40 provides there are no other 
agreements between the parties.
THE COURT:  Thank you.  
Mr. Gaines, does that accurately reflect the 
agreement you believe you've reached with the government?  
THE DEFENDANT:  Yes. 
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THE COURT:  Do you understand that any provisions in 
the agreement regarding recommendations to be made by the 
government are not binding on the Court?  
THE DEFENDANT:  Yes. 
THE COURT:  In other words, if I choose not to follow 
some recommendation that the government makes, do you 
understand that you will still be bound by your plea of guilty 
and would not be entitled to withdraw the plea based on the 
Court not following the recommendation?  
THE DEFENDANT:  Yes. 
THE COURT:  Is this the only agreement that you've 
entered into with the government?  
THE DEFENDANT:  Yes. 
THE COURT:  Other than the terms of this agreement 
has any promise of any kind been made to you to cause you to 
plead guilty?  
THE DEFENDANT:  Yes. 
THE COURT:  Okay.  What other promise -- 
THE DEFENDANT:  No.  No, there's -- there's nothing 
else. 
THE COURT:  All right.  So the answer to my 
question -- other than the terms of this agreement has any 
promise of any kind been made to you, the answer to that 
question is no?  
THE DEFENDANT:  The answer is no. 
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THE COURT:  Okay.  Thank you.  
Per the terms of the plea agreement, the United 
States Attorney has agreed not to bring any additional charges 
related to the offense to which you're pleading guilty.  
Other than those terms, has anyone threatened or 
forced you to plead guilty or told you that if you do not 
plead guilty further charges will be brought against you or 
other adverse action taken against you?  
And that's a mouthful, so I'm going to let 
Mr. Mendelsohn talk with you a second just to make sure that 
you understand my question.  
MR. MENDELSOHN:  Judge, I boiled that down to has 
anybody made a threat against you or is anybody holding a gun 
to your head to make you plead guilty. 
THE COURT:  All right.  What's the answer to that 
question, sir?  
THE DEFENDANT:  No. 
THE COURT:  All right.  And, Mr. Mendelsohn, are you 
aware of any plea agreement or promise being made to your 
client other than what's been discussed here in open court?  
MR. MENDELSOHN:  No. 
THE COURT:  All right.  Mr. Gaines, I'm going to now 
have Ms. Chaiken go over the factual basis for the plea.  
Would you like to take a break or are you okay to kind of go 
into this next section of the plea colloquy?  
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MR. MENDELSOHN:  He feels okay to go forward.
THE COURT:  What's that?  
MR. MENDELSOHN:  He feels okay to go forward. 
THE COURT:  So now I'm going to ask the Assistant US 
Attorney to state the elements of the offense to which you're 
pleading guilty.  The elements of the offense are those 
matters that the government must prove beyond a reasonable 
doubt in order to convict you of the charge.  
Ms. Chaiken. 
MS. CHAIKEN:  Your Honor, just so it's clear for the 
record, although Mr. Gaines was previously charged by a 
criminal indictment, this is his first appearance on the 
criminal information.  And we do have the waiver of indictment 
form.  And we just want to make sure that we have an 
opportunity to review the nature of the charge with him before 
that information is deemed filed and we get too far into the 
plea hearing. 
THE COURT:  Okay.  I was not aware of that.  So you 
want to take a moment and do that now?  
MS. CHAIKEN:  Yes, your Honor, if we could. 
THE COURT:  Go ahead. 
MS. CHAIKEN:  Would you like me to -- 
THE COURT:  Sure.  I've already asked him the 
question about the waiver of indictment, so go ahead. 
MS. CHAIKEN:  Mr. Gaines, do you understand that the 
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criminal information that we gave you a copy of charges you 
with a violation of Title 18 United States Code, Section 1001, 
which makes it a crime to make false statements to a federal 
law enforcement officer?  
THE DEFENDANT:  Yes. 
MS. CHAIKEN:  And have you had an opportunity to 
review the criminal information with your attorney?  
THE DEFENDANT:  Yes. 
THE COURT:  And do you understand that you have the 
right to be charged by criminal indictment rather than by this 
information, meaning that we would have to present your case 
to the grand jury and have them return an indictment as 
opposed to us coming to court in this information and making 
the allegation against you?  
MR. MENDELSOHN:  One second. 
MS. CHAIKEN:  That was a mouthful, sorry.  
(Pause in the proceedings.)
MR. MENDELSOHN:  So I translated that to do you 
understand that we could present -- you have the right to have 
this presented to a grand jury as opposed to having a charge 
made by the US Attorney.  And his response is, yes, he does 
understand. 
MS. CHAIKEN:  Would you like us to read a copy of the 
information to you or do you waive a formal reading of the 
information?  
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THE DEFENDANT:  Waive. 
THE COURT:  And given your understanding of these 
rights and of the nature of the charge in the information, is 
it your desire to waive formal indictment and proceed with 
charges pursuant to the criminal information?  
THE DEFENDANT:  Yes. 
THE COURT:  And is this your signature on the waiver 
of indictment form above your name?  
THE DEFENDANT:  Yes. 
THE COURT:  And, Mr. Mendelsohn, is that your 
signature on the waiver of indictment form above your name?  
MR. MENDELSOHN:  Yes, it is. 
MS. CHAIKEN:  Your Honor, may I tender the waiver of 
indictment form?  
THE COURT:  Sure.  Thank you.  
MS. CHAIKEN:  Thank you.  
THE COURT:  Anything else on that front, Ms. Chaiken?  
MS. CHAIKEN:  No, your Honor.  Would you like me to 
proceed with the elements?  
THE COURT:  Yes.  Thank you. 
MS. CHAIKEN:  Thank you, your Honor.  
Mr. Gaines is pleading guilty to Count 1 of the 
criminal information, which charges making a false statement 
to a department or agency of the United States in violation of 
Title 18 United States Code, Section 1001.  
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The elements of that offense are as follows:  
One, the defendant made a statement or 
representation; 
Two, the statement was false, fictitious or 
fraudulent;
Three, the statement or representation was material;
Four, the defendant acted knowingly and willfully;
And, five, the statement or representation pertained 
to a matter within the jurisdiction of the executive branch of 
the United States Government.  
THE COURT:  Thank you.  And, Mr. Gaines, do you 
understand that those are the elements that the government 
would have to prove beyond a reasonable doubt in order to 
convict you of the charge?  
THE DEFENDANT:  Yes. 
THE COURT:  In a moment I will ask the Assistant US 
Attorney to summarize the evidence that the government would 
expect to present at trial to prove each of these elements.  
In other words, these are what the government contends are the 
facts of the case.  
It's necessary for the government to state these 
facts because I must determine whether there's a factual basis 
for you to enter this plea of guilty.  
After this statement I will ask you whether you 
disagree with any of the facts as stated by the prosecutor.  
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If you do, tell me, and we will discuss those facts at that 
time.  
Ms. Chaiken. 
MS. CHAIKEN:  Thank you, your Honor.  
If this case were to go to trial, the United States 
would prove by admissible evidence and beyond a reasonable 
doubt the following facts:  
The Paycheck Protection Program, which is known as 
the PPP, was authorized as part of the Coronavirus Aid, Relief 
and Economic Security Act to provide forgivable loans to 
eligible small businesses.  
Under the PPP small businesses could apply for loans 
that must be used for payroll expenses, interest on mortgage, 
rent and/or utilities.  
The amount of a PPP loan that a business could 
receive was generally two-and-a-half times, or 250 percent, of 
the business's average monthly payroll cost.  
While the United States Small Business Administration 
oversaw the PPP, individual PPP loans were issued by private 
approved lenders, including Cross River Bank, which is a 
federally insured financial institution.  
The PPP borrower application form asked the applicant 
to provide information related to their loan application, 
including the amount of the business's average monthly 
payroll, the number of the business's employees and the 
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purpose of the loan, with options for payroll, lease or 
mortgage interest, utilities and/or other.  
The lender then used this information to calculate 
the amount of the loan that the business was eligible to 
receive.  
The application form also included certain 
representations and certifications, including certifications 
as to the accuracy of the information included in the 
application itself and in any supporting documents and a 
certification that the funds would be used to retain workers 
and maintain payroll or to make mortgage interest payments, 
lease payments and utility payments.  
Defendant Andre Lee Gaines is the owner of a Georgia 
company called Gaines Reservation & Travel, which I'll refer 
to as Gaines Reservation.  
On or about May 18th, 2020, Gaines Reservations 
submitted a PPP loan application.  In the PPP loan 
application, Gaines Reservation represented that it had 69 
employees and $322,684 in average monthly payroll and that the 
purpose of the loan was payroll, lease, mortgage interest or 
utilities.  
To support these payroll figures, Gaines Reservations 
submitted IRS Form 941s, which are quarterly employer's tax 
returns for Gaines Reservations for each quarter of 2019 and a 
JPMorgan Chase Bank statement for Gaines Reservation for 
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February of 2020.  
The documents submitted with Gaines Reservations PPP 
loan application were fabricated.  The IRS confirmed that 
Gaines Reservation did not file a Form 941 for any quarter in 
2019 and bank records for Gaines Reservations show that the 
bank statement submitted with the PPP loan application was 
fake.  
In reality, Gaines Reservation did not have any 
employees or any monthly payroll costs.  
Based on the false representations in Gaines 
Reservations' PPP loan application and the fabricated 
supporting documents, Cross River Bank issued a $806,710 
PPP loan to Gaines Reservations.  
On or about July 2nd, 2020, a special agent of the 
Federal Bureau of Investigation interviewed Mr. Gaines by 
telephone.  During that telephonic interview, Gaines made 
various false statements about Gaines Reservations and its PPP 
loan application which were material facts of the 
investigation.  
Among these false statements, Gaines represented that 
Gaines Reservation has 69 employees.  At the time that he made 
that statement, Mr. Gaines knew that Gaines Reservations did 
not have any employees.
THE COURT:  Thank you. 
MR. MENDELSOHN:  Judge, typically I know you would 
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ask Mr. Gaines about this.  If I could add a couple of little 
details here to explain sort of what was going on just so the 
bigger picture is clear. 
THE COURT:  Sure. 
MR. MENDELSOHN:  The events that happened in this 
case happened in 2020, two years after Mr. Gaines' stroke.  
Mr. Gaines did not file the PPP loan application.  
They were filed electronically by an individual who's named as 
a co-defendant in the PPP indictment.  
Mr. Gaines never saw the application.  Mr. Gaines 
never saw the supporting documentation.  
He was misled as to what was being filed and what the 
whole purpose of this information was and only found out that 
a PPP loan was filed in the name of his company after the 
fact.  
And as I've said to the government, it's argued that 
the evidence at trial would show that Mr. Gaines was a victim 
of some hustlers out there who took advantage of his cognitive 
impairments to file the loan on his behalf or in the name of 
his company.  
After all of this happened and after all the funds 
were disbursed an FBI agent came -- or made phone calls to 
Mr. Gaines to ask him about the PPP loan.  There was one phone 
call in which they had a discussion where I don't believe any 
false statements were made.  There was a call later in the day 
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in which Mr. Gaines did make the false statement.  In between 
that, it's my understanding that Mr. Gaines spoke with one of 
the individuals who had misled him and told him what to say.  
So he acknowledges he made the false statement, but 
with that background about what happened with the PPP loan, I 
think it's important to have on the record that were this case 
to go to trial, that Mr. Gaines did not actually file the PPP 
loan application. 
THE COURT:  Mr. Gaines, let me ask you, do you 
disagree with anything that Ms. Chaiken has said with the 
caveats that Mr. Mendelsohn has given?  
And I think -- Ms. Chaiken, Mr. Kitchens, chime in, 
but I think as far as the elements for false statements, even 
with those caveats, it seems like there is still a factual 
basis from my perspective, unless anyone disagrees. 
MS. CHAIKEN:  We agree, your Honor. 
MR. MENDELSOHN:  And we are in no way denying any 
part of -- what happened on July 2nd, he made the false 
statement.  We totally -- 
THE COURT:  I understand.  
Mr. Gaines, my question is pending to you?  
THE DEFENDANT:  Yes. 
THE COURT:  All right.  So you do not disagree with 
anything, correct?  
THE DEFENDANT:  Correct. 
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THE COURT:  Let me ask you about those elements.  
Do you admit that you made a statement or a 
representation that was false, fictitious or fraudulent?  
THE DEFENDANT:  Yes. 
THE COURT:  And do you admit that that statement or 
representation was material?  
THE DEFENDANT:  Yes. 
THE COURT:  Is the answer to my question "yes," sir?  
THE DEFENDANT:  Yes, sir. 
THE COURT:  And do you admit that you acted knowingly 
and willfully?  
THE DEFENDANT:  Yes.  
THE COURT:  Do you admit that the statement or 
representation pertained to a matter within the jurisdiction 
of the executive branch of the United States Government?  
THE DEFENDANT:  Yes. 
THE COURT:  And, sir, I'm now going to have 
Ms. Chaiken talk about the potential penalties that you face 
for the charge, including the maximum penalties and any 
mandatory minimums.  
Are you okay to go forward with that now or would you 
like to take a break?  
THE DEFENDANT:  I would like to go forward. 
THE COURT:  All right.  Ms. Chaiken, go ahead. 
MS. CHAIKEN:  Thank you, your Honor.  
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Mr. Gaines faces the following maximum and mandatory 
minimum penalties as to the offense charged:  
The maximum term of imprisonment is five years.  
There is no mandatory minimum term of imprisonment.  
The authorized term of supervised release is zero to 
three years.  
The maximum fine is $250,000 or twice the gain or 
twice the loss, whichever is greatest.  
He will also have to pay full restitution, a 
mandatory special assessment of $100 and forfeiture of any 
property, real or personal, constituting or derived from 
proceeds obtained directly or indirectly as a result of the 
offense. 
THE COURT:  Thank you.  Mr. Gaines, do you understand 
that those are the possible penalties that you could receive 
in this case?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that it's not possible 
for me to state to you today what your exact sentence will be?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that in deciding your 
sentence, I will consider sentencing guidelines and that the 
guidelines are advisory, which means that I have the 
discretion to impose a sentence that is either within the 
guidelines, greater than the guidelines or less than the 
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guidelines?  
THE DEFENDANT:  Yes. 
THE COURT:  And bear with me a moment. 
In the plea agreement that was reviewed with you a 
little while ago you waived certain appeal rights.  I want to 
be sure that you understand the meaning of that waiver.  
Let me first state to you the rights you would have 
if you did not waive or give up those rights.  
The defendant in every criminal case has the right  
to file a direct appeal immediately after his conviction and 
sentence.  In that appeal you may raise any issue concerning 
the handling of your case in this court that you wish to 
raise.  Those issues would be reviewed by the Court of 
Appeals.  If errors were found, the Court of Appeals could 
order that action be taken to correct those errors.  
Besides that right to a direct appeal, you would have 
an additional opportunity for review of your case by filing a 
writ of habeas corpus pursuant to 28 USC, Section 2255.  
That's another opportunity for you to challenge the legality 
of your conviction and/or your sentence.  
These are rights that every defendant has unless he 
waives or gives them up.  
In your plea agreement you have, for the most part, 
given up these rights.  Your right of review will be limited 
to three specific circumstances.  
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First, if after calculating the sentencing guidelines 
that apply to your case, I then impose a sentence that is 
greater than the guidelines, you would have the right to file 
a direct appeal challenging that sentence.  
Second, if the government files an appeal for any 
reason, you have a right to file a cross-appeal raising any 
issues that you wish to raise.  
Finally, you always reserve the right to challenge 
constitutionally ineffective assistance of counsel.  
But aside from these three very narrow circumstances, 
you will have no right of appeal and will be essentially bound 
by my decision.  
Do you understand that, sir?  
THE DEFENDANT:  Yes. 
THE COURT:  And, Mr. Mendelsohn, have you reviewed 
the rights with your client such that you're comfortable he 
understands both his rights and the waiver of those rights?  
MR. MENDELSOHN:  I have. 
THE COURT:  Mr. Gaines, I'm going to now go through 
some other issues.  Are you okay to go forward or would you 
like to take a break?  
THE DEFENDANT:  I would like to go forward. 
THE COURT:  All right.  
First, do you understand that parole has been 
abolished in the federal system and that if you're sentenced 
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to prison, you will not be released early on parole?  
(Pause in the proceedings.)
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that you may be 
sentenced to a term of supervised release that will follow any 
term of imprisonment and will include rules governing your 
conduct that if you violate could result in more time in 
prison?  
THE DEFENDANT:  Yes. 
THE COURT:  Bear with me a moment. 
Do you understand you may be ordered to pay 
restitution to any victim of the offense?  
THE DEFENDANT:  Yes. 
THE COURT:  Are you a citizen of the United States 
Government, sir?  
MR. MENDELSOHN:  Are you a United States citizen?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that as part of your 
sentence certain property that's been identified by the 
government may be forfeited by you to the government?  
THE DEFENDANT:  Yes.  
THE COURT:  Is there anything we've talked about 
today that you do not feel you fully understand?  
THE DEFENDANT:  Yes. 
MR. MENDELSOHN:  Well -- I'm sorry, Judge.  I just 
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said to him do you feel like you've understood everything. 
THE COURT:  Let me just ask it that way.  
Sir, Mr. Gaines, have you understood everything we've 
discussed today?  
THE DEFENDANT:  Yes. 
THE COURT:  Have you had a sufficient opportunity to 
talk about your case with your attorney and have your attorney 
answer any questions that you have before entering your plea?
THE DEFENDANT:  Yes. 
THE COURT:  Are you satisfied with the representation 
that your attorney has provided to you?  
THE DEFENDANT:  Yes. 
THE COURT:  How do you plea to the information, 
guilty or not guilty?  
THE DEFENDANT:  Guilty. 
THE COURT:  Mr. Mendelsohn, do you feel that you've 
had a sufficient opportunity to investigate your client's case 
and advise him concerning the entry of this plea?  
MR. MENDELSOHN:  I do. 
THE COURT:  Are you aware of any reason I should not 
accept the plea?  
MR. MENDELSOHN:  I am not. 
THE COURT:  Is there anything else you want me to 
address with your client on the record at this time?  
MR. MENDELSOHN:  No.  Thank you. 
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THE COURT:  Ms. Chaiken, is there anything further 
that the government wishes the Court to address at this time?  
MS. CHAIKEN:  No, your Honor.  Thank you. 
THE COURT:  Does the government object to the 
defendant remaining on bond subject to the previous 
conditions?  
MS. CHAIKEN:  No, your Honor. 
THE COURT:  Mr. Gaines, tell me in your own words 
what we've done here today. 
THE DEFENDANT:  We've discussed my plea agreement 
of -- my guilty plea with the US Attorney today.  And I waived 
my right to -- and -- so that I could plead guilty to the 
charge of making a false statement to a federal agent. 
THE COURT:  Okay.  Thank you, sir.  
I find the defendant understands the charge and the 
consequences of the plea.  
I've observed the defendant during this proceeding 
and he does not appear to be under the influence of any 
substance that might affect his judgment or actions in any 
manner.  
I've also discussed at length his competence to enter 
the plea, and I'm satisfied that he is competent to enter a 
knowing plea here today and understands these proceedings.  
I normally don't ask that final question of a 
defendant, what happened here today, what are we doing.  And 
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the defendant stated without any prompting by his attorney I 
think exactly the purpose of today's proceeding and what we've 
done.  And I thought he did so artfully.  
So the Court finds that the plea has a factual basis 
and is free of any coercive influence of any kind.  
I find that there have been no promises made to the 
defendant except those set out in the plea agreement.  
I find that the defendant is competent to understand 
these proceedings and enter a knowing plea of guilty as just 
discussed in more detail.  
I find that the plea is freely and voluntarily 
entered.  
It's, therefore, entered that the plea of guilty of 
the defendant to the information is accepted and entered.  
Mr. Gaines, you are hereby adjudged guilty of the 
charge contained in the information.  
I will now be referring your case to a probation 
officer who will prepare a presentence report.  Before I 
receive the report, Mr. Gaines, you and your attorney will 
receive a copy of the report and will have an opportunity to 
object to any findings in the report.  
At your sentencing hearing I will hear from the 
government and any witnesses it wishes to present and from 
you, your attorney and any witnesses that you wish to present.  
At that time I will decide the proper sentence in your case.  
Case 1:20-cr-00296-JPB-CMS     Document 895     Filed 02/02/24     Page 36 of 38

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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
36
Do you understand that, sir?  
THE DEFENDANT:  Yes. 
THE COURT:  Counsel, anything else?  
MS. CHAIKEN:  Not from the government, your Honor. 
MR. MENDELSOHN:  No, Judge.  Thank you. 
THE COURT:  All right.  Good to see everyone.  
And, Ms. Walker, Ms. Coudriet, Officer, thank you all 
very much.  
We're adjourned.
(PROCEEDINGS REPORTED WERE CONCLUDED AT 4:03 PM.)
___________________________ 
Case 1:20-cr-00296-JPB-CMS     Document 895     Filed 02/02/24     Page 37 of 38

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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
37
C E R T I F I C A T E
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
I do hereby certify that the foregoing pages are a true
and correct transcript of the proceedings taken down by me in 
the case aforesaid.
   This the 25th day of January, 2024.  
    ________________________________
  
  
               
    PENNY PRITTY COUDRIET, RMR, CRR
    OFFICIAL COURT REPORTER
Case 1:20-cr-00296-JPB-CMS     Document 895     Filed 02/02/24     Page 38 of 38

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