Pandemic Darlings The pandemic economy, in original documents
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,……

Court filing

TRANSCRIPT of Proceedings as to Darrell Thomas, Andre Lee Gaines, Kahlil Gibran Green,… — USA v. Thomas et al (Dkt. 919)

Record facts

CourtU.S. District Court for the Northern District of Georgia
Filed2024-02-12

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 919 · 2024-02-12 · Docket on CourtListener

Summary

The official transcript of change of plea proceedings for defendant John Gaines on January 31, 2024 before U.S. District Judge J.P. Boulee, in No. 1:20-cr-00296-JPB-CMS in the U.S. District Court for the Northern District of Georgia, filed February 12, 2024 as Document 919. The court reviews the defendant's trial rights, and Assistant U.S. Attorney Tal Chaiken summarizes the plea agreement, under which the remaining counts would be dismissed and the parties stipulate an offense level of 21 under Section 2B1.1 for a loss between $550,000 and $1.5 million. According to that summary, Gaines is pleading guilty to a money laundering offense under Section 1956 and agrees to pay $806,710 plus interest in restitution to Cross River Bank and the Small Business Administration and a special assessment of $100. The agreement's appeal waiver in paragraph 31 is read into the record.

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. 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 1 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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
) 
JOHN GAINES,
)
)
DEFENDANT.
)
TRANSCRIPT OF CHANGE OF PLEA PROCEEDINGS
BEFORE THE HONORABLE J.P. BOULEE
UNITED STATES DISTRICT JUDGE
JANUARY 31, 2024
APPEARANCES:
ON BEHALF OF THE GOVERNMENT: 
TAL CHAIKEN, ESQ. 
SAMIR KAUSHAL, ESQ.
BABASIJIBOMI MOORE, ESQ. 
ASSISTANT UNITED STATES ATTORNEYS
ON BEHALF OF THE DEFENDANT:
DEANA TIMBERLAKE-WILEY, ESQ.
STENOGRAPHICALLY RECORDED BY:  
PENNY PRITTY COUDRIET, RMR, CRR
OFFICIAL COURT REPORTER
UNITED STATES DISTRICT COURT 
ATLANTA, GEORGIA 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 2 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
2
(PROCEEDINGS HELD IN OPEN COURT AT 11:38 AM, ATLANTA, GEORGIA)
COURTROOM DEPUTY CLERK:  The Court has set aside time 
for A change of plea in United States v. John Gaines, Case 
Number 1:20-CR-296.  
Counsel, will you please make your appearances for 
the record. 
MS. CHAIKEN:  Good morning, your Honor.  Tal Chaiken 
for the United States.  Seated with me at counsel table is my 
co-counsel Samir Kaushal and Siji Moore.  Seated behind us are 
FBI Special Agents Joe Stites and Stefan Bublitz. 
MS. TIMBERLAKE-WILEY:  Good morning, your Honor.  My 
name is Deana Timberlake-Wiley, and I have the pleasure of 
representing Mr. John Gaines who is seated at the table here 
with me. 
THE COURT:  Good to see all of you this morning.  
If we can please swear in the defendant.  
(The defendant was duly sworn) 
THE COURT:  Ms. Chaiken, if you can please verify the 
signatures on the plea agreement. 
MS. CHAIKEN:  Yes, your Honor.  
Good morning, Mr. Gaines, I'm showing you a document 
that's entitled "Guilty Plea and Plea Agreement."  Have you 
had an opportunity to review this document with your attorney?  
THE DEFENDANT:  Yes. 
MS. CHAIKEN:  Turning to page 14 of this document, on 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 3 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
3
the right side above where it says your name, is that your 
signature?  
THE DEFENDANT:  Yes. 
MS. CHAIKEN:  And, Ms. Timberlake-Wiley, on the left 
side above where it says your name, is that your signature?  
MS. TIMBERLAKE-WILEY:  Yes, ma'am. 
MS. CHAIKEN:  Your Honor, page 14 is also signed by 
myself, approving official Stephen H. McClain and Siji Moore.  
Turning to page 15, Mr. Gaines, is that your 
signature above where it says your name?  
THE DEFENDANT:  Yes. 
MS. CHAIKEN:  Turning to page 16, 
Ms. Timberlake-Wiley, is that your signature above where it 
says your name?  
MS. TIMBERLAKE-WILEY:  Yes. 
MS. CHAIKEN:  Your Honor, may I tender the plea 
agreement?  
THE COURT:  Yes.  Thank you.  
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 
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 you can 
answer them truthfully.  A failure to truthfully answer any 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 4 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
4
question can 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 and how far did you go in 
school?  
THE DEFENDANT:  58.  And I got an EdS in education. 
THE COURT:  In the last 24 hours have you taken any 
drugs, medicine, pills or had any alcoholic beverages to  
drink?  
THE DEFENDANT:  No. 
THE COURT:  Have you been treated recently for any 
mental illness or addiction to alcohol or drugs?  
THE DEFENDANT:  No. 
THE COURT:  And, Ms. Timberlake-Wiley, are you aware 
of any issues regarding your client's competence to enter a 
plea this morning?  
MS. TIMBERLAKE-WILEY:  No, your Honor. 
THE COURT:  Sir, I'm now going to review with you the 
rights you're guaranteed under the Constitution and laws of 
the United States.  I want to be sure that you understand your 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 5 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
5
rights and that by entering this plea of guilty you're giving 
up many of these rights.  
Do you understand, first off, that 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?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand that you have the right 
to be represented by an attorney throughout all proceedings 
and that 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 if you pled not guilty 
and went to trial, at the trial you would 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 at a trial you would 
not have to prove 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 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 6 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
6
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 
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 
would also have the right not to testify?  
THE DEFENDANT:  Yes. 
THE COURT:  Do you understand 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 crimes with 
which you're charged?  
THE DEFENDANT:  Yes. 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 7 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
7
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 you're guilty of the charge based on your admission 
that you're guilty.  Do you understand?  
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:  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 factual basis for the 
plea and potential penalties, which we will discuss a bit 
later in this proceeding.  
After that I will 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.  
The plea agreement sets forth that Mr. Gaines is 
pleading guilty because he is, in fact, guilty of the offense 
charged.  
Paragraphs two through six set forth an 
acknowledgment and a waiver of the rights that the Court just 
reviewed with Mr. Gaines.  
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 8 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
8
Paragraphs seven through nine set forth an 
acknowledgment of the penalties that I understand we'll review 
shortly.  
According to paragraph 11, the remaining counts that 
are pending against Mr. Gaines will be dismissed on entry of 
his plea.  
Paragraph 12, the US Attorney for the Northern 
District of Georgia agrees not to bring further charges 
against Mr. Gaines related to the charges to which he's 
pleading guilty.  
Paragraphs 13 through 15 set forth a series of 
guideline stipulations, specifically that the applicable 
offense guideline is 2S1.1(a)(1), that the offense level for 
the underlying offense is 21 under Section 2B1.1 because the 
base offense level is 7, and a 14-level upward adjustment 
applies for amount of loss, between $550,000 and $1.5 million.  
The two-level upward adjustment will apply under 
Section 2S1.1 (b)(2)(B) because Mr. Gaines is pleading guilty 
to a money laundering offense under Section 1956.  
A two-level adjustment under Section 2S1.1(b)(3) will 
not apply for sophisticated laundering.  
And a three-level upward adjustment will apply 
pursuant to Section 3B1.1(b) for Mr. Gaines' role in the 
offense because he was a manager or supervisor and the 
criminal activity involved five or more participants.  
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 9 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
9
In paragraph 16 the government agrees to recommend a 
two-level downward adjustment for acceptance of responsibility 
subject to exceptions set forth in that paragraph, including 
if the defendant engages in conduct inconsistent with 
acceptance of responsibility.  
Paragraph 17 sets forth the parties' understanding 
that each party reserves the right to make recommendations for 
sentencing and that there are no agreements on the guidelines 
other than those that are set forth in the plea agreement.  
In paragraph 18 the government reserves the right to 
modify its sentencing recommendation if it receives additional 
information that bears on its sentencing recommendation.  
In paragraph 19 the government agrees to recommend a 
sentence within the adjusted guideline range so long as the 
defendant does not engage in conduct inconsistent with 
acceptance of responsibility.  
Paragraph 20, the government agrees to make no 
specific recommendation as to the fine to be imposed.  
Paragraph 21, Mr. Gaines agrees to pay $806,710 plus 
applicable interest in restitution to Cross River Bank and the 
Small Business Administration in the amount set forth in that 
paragraph.  
In paragraphs 22 and 23 Mr. Gaines agrees to 
forfeiture of any assets that have been seized in connection 
with this case.  
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 10 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
10
In paragraph 24 Mr. Gaines agrees to pay a special 
assessment of $100.  
In paragraphs 25 through 29 Mr. Gaines agrees to 
cooperate fully in the collection of any restitution or fine 
that's imposed pursuant to the terms that are set forth in 
those paragraphs.  
In paragraph 30 Mr. Gaines provides that he 
understands that the recommendations in the plea agreement are 
not binding on the Court.  
Paragraph 31 sets forth appeal waiver, which I would 
like to read in full into the record. 
THE COURT:  Go ahead. 
MS. CHAIKEN:  Thank you.  
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 USC, Section 2255 on any ground except that the 
defendant may file a direct appeal of an upward departure or 
upward variance above the sentencing guidelines range as 
calculated by the district court.  
Claims that the defendant's counsel rendered 
constitutionally ineffective assistance are excepted from this 
waiver.  
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 11 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
11
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 the same sentence.  
And paragraph 32 sets forth FOIA and Privacy Act 
waiver.  
And paragraph 33 sets forth that there are no other 
agreements between the parties other than this plea agreement. 
THE COURT:  All right.  Thank you.  
Mr. Gaines, does that accurately reflect the 
agreement that you believe you've reached with the government?  
THE DEFENDANT:  Yes. 
THE COURT:  And she read to you about your appeal 
rights in paragraph 31 and the three circumstances in which 
you might be able to appeal, but do you understand that you 
otherwise will have no right of appeal and will be essentially 
bound by my decision at sentencing?  
THE DEFENDANT:  Yes. 
THE COURT:  And, Ms. Timberlake-Wiley, have you 
reviewed those rights regarding waiver of appeal with your 
client such that you're comfortable he understands both his 
rights and waiver of those rights?  
MS. TIMBERLAKE-WILEY:  Yes, your Honor, I have.  
THE COURT:  And, Mr. Gaines, do you understand that 
any provisions in the agreement regarding recommendations to 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 12 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
12
be made by the government are not binding on 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 cause you to plead 
guilty?  
THE DEFENDANT:  No. 
THE COURT:  And per the terms of the plea agreement, 
the US Attorney for the Northern District of Georgia 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?  
THE DEFENDANT:  No. 
THE COURT:  And, Ms. Timberlake-Wiley, are you aware 
of any plea agreement or promise being made to your client 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 13 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
13
other than what's been discussed here in court?  
MS. TIMBERLAKE-WILEY:  No, your Honor. 
THE COURT:  In a moment I will ask Ms. Chaiken to 
state the elements -- excuse me -- 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:  Thank you, your Honor.  
Mr. Gaines is pleading guilty to Count 47 of the 
second superseding indictment which charges money laundering 
in violation of Title 18 United States Code, 
Section 1956(a)(1)(B)(i) and Section 2.  
The elements of that offense are as follows:  
One, the defendant knowingly conducted or tried to 
conduct a financial transaction;
Two, the defendant knew that the money or property 
involved in the transaction were proceeds of some kind of 
unlawful activity;
Three, money or property did come from an unlawful 
activity, specifically wire fraud; 
And, four, the defendant knew that the transaction 
was designed in whole or in part to conceal or disguise the 
nature, location, source, ownership or control of the 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 14 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
14
proceeds. 
THE COURT:  All right.  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'll ask the Assistant US 
Attorney to summarize the evidence 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 a plea of guilty.  
After this statement, I will ask you whether you 
disagree with any facts stated by the prosecutor.  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, 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.  
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 15 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
15
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 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, an FDIC insured 
financial institution based in Fort Lee, New Jersey.  
The PPP borrower application form asks 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 
purpose of the loan with options for payroll, lease and 
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.  
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 16 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
16
Defendant John Gaines, who at all relevant times was 
in the Northern District of Georgia, was a relative of Andre 
Gaines, who owned a Georgia company called Gaines Reservation 
& Travel.  
On or around May 18th, 2020, Gaines Reservation 
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 or mortgage interest and 
utilities.  
To support these payroll figures Gaines Reservation 
submitted IRS Form 941s for Gaines Reservation for each 
quarter of 2019, and a JPMorgan Chase bank statement for 
Gaines Reservation for February 2020.  
The documents submitted with Gaines Reservation's 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 Reservation 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 representation in Gaines 
Reservation's PPP application and the fabricated supporting 
documents, Cross River Bank issued an $806,710 PPP loan to 
Gaines Reservation.  
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 17 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
17
John Gaines, using his alias Marty Gaines, worked 
with Darrell Thomas and others to obtain Gaines Reservation's 
fraudulent PPP loan.  E-mails would shown that Defendant 
Gaines e-mailed a person who makes fake documents for him and 
asked that person to create fake bank statements for Gaines 
Reservation that would show payroll withdrawals.  
Defendant Gaines then sent multiple fabricated bank 
statements to Darrell Thomas, and one of those bank statements 
was submitted with Gaines Reservation's PPP loan application.  
Defendant Gaines also e-mailed various other 
documents to Darrell Thomas related to Gaines Reservation, 
including a PPP application form that left the number of 
employees and the amount of payroll blank so that Darrell 
Thomas and others working with him could fill in those blanks 
with fake numbers.  
After the PPP loan money was deposited into Gaines 
Reservation's bank account, on which Defendant Gaines was a 
signer, Defendant Gaines directed various financial 
transactions to make it look like Gaines Reservation was 
making payments for payroll and rent which are approved 
expenses under the PPP.  
For example, on June 22nd, 2020, Defendant Gaines 
caused a wire transfer to be sent from Gaines Reservation to a 
company called Management Resource Services in the amount of 
$179,985.72.  The purpose of the transfer was listed as 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 18 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
18
payroll services.  In reality, however, Gaines Reservation had 
no payroll and the purpose of the transfer was not payroll 
services.  Instead, the transfer was designed to conceal the 
location, nature and source of the fraudulently obtained PPP 
loan proceeds by making them appear to be spent on payroll 
while sending them to an account controlled by Mr. Gaines' 
ex-wife, Carla Jackson. 
THE COURT:  Thank you.  
Mr. Gaines, do you disagree with any of the facts as 
stated by the Assistant US Attorney?  
MS. TIMBERLAKE-WILEY:  Your Honor, we don't disagree 
but we do have just a clarification. 
THE COURT:  Sure. 
MS. TIMBERLAKE-WILEY:  In the beginning where 
Prosecutor Chaiken stated that Mr. Gaines was a relative of 
Andre Gaines who owned a Georgia company, we just want to make 
it clear that Andre Gaines owned the Gaines Reservation & 
Travel.  That's just important to my client that that be 
stated.  
And also in the last paragraph where the prosecutor 
stated that Mr. Gaines caused the wire transfer to be sent, we 
don't dispute that, but the wire transfer was actually sent by 
Co-Defendant Andre Gaines. 
THE COURT:  Very well.  
Mr. Gaines, with those caveats by your client (sic), 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 19 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
19
do you disagree with anything else that the Assistant US 
Attorney said?  
THE DEFENDANT:  No.  
THE COURT:  Very well.  
Do you admit each of the elements she listed earlier?  
THE DEFENDANT:  I beg your pardon?  
THE COURT:  Do you admit each of the elements of the 
offense she listed earlier?  
THE DEFENDANT:  Oh, yes. 
THE COURT:  And, Ms. Chaiken, if you can please state 
the potential penalties the defendant faces for the charge, 
including the maximum penalties and any mandatory minimums. 
MS. CHAIKEN:  Yes, your Honor.  
As to Count 47, the maximum term of imprisonment is 
20 years.  There is no mandatory minimum term of imprisonment.  
The authorized term of supervised release is zero to three 
years.  The maximum fine is $500,000, or twice the value of 
the property involved in the transaction, whichever is 
greatest, due and payable immediately.  And then there's also 
full restitution due immediately, a mandatory special 
assessment of $100 and forfeiture of any and all proceeds from 
the commission of the offense, any and all property used or 
intended to be used to facilitate the offense and any property 
involved in the offense. 
THE COURT:  All right.  Thank you.  
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 20 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
20
Mr. Gaines, do you understand those are the possible 
penalties you can 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 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 I have the discretion to 
impose a sentence that is either within the guidelines, 
greater than the guidelines or less than the guidelines?  
THE DEFENDANT:  Yes. 
THE COURT:  In the plea agreement -- excuse me.  
In the plea agreement that was reviewed with you 
earlier -- we discussed that waiver of appeal already.  So 
strike that.  
Do you understand that parole has been abolished in 
the federal system and that if you're sentenced to prison, you 
will not be released early on parole?  
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?  
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 21 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
21
THE DEFENDANT:  Yes. 
THE COURT:  And do you understand that you may be 
ordered to pay restitution to any victims of the offense?  
THE DEFENDANT:  Yes. 
THE COURT:  Are you a citizen of the US Government, 
sir?  Are you a US citizen?  
THE DEFENDANT:  Yes. 
THE COURT:  Ms. Chaiken and Ms. Timberlake-Wiley, is 
there any forfeiture at issue?  
MS. CHAIKEN:  Your Honor, there were funds that were 
seized from accounts on which -- or at least one account on 
which Mr. Gaines is a signer, but our understanding is that 
that amount has already been forfeited through the judicial 
process, which is why it's not specifically identified as a 
forfeiture. 
THE COURT:  Very well.  
Sir, is there anything we've talked about today that 
you do not feel that you fully understand?  
THE DEFENDANT:  No. 
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?  
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 22 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
22
THE DEFENDANT:  Yes. 
THE COURT:  How do you plea to Count 47 of the 
indictment?  
THE DEFENDANT:  Guilty. 
THE COURT:  Ms. Timberlake-Wiley, 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?  
MS. TIMBERLAKE-WILEY:  Yes, your Honor. 
THE COURT:  Are you aware of any reason I should not 
accept the plea?  
MS. TIMBERLAKE-WILEY:  No, your Honor. 
THE COURT:  Is there anything else that you want me 
to address with your client on the record at this time?  
MS. TIMBERLAKE-WILEY:  No, your Honor. 
THE COURT:  And, 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:  I find that the defendant understands the 
charge and the consequences of the plea.  
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 23 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
23
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.  
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.  
I find that the plea is freely and voluntarily 
entered.  
It's, therefore, ordered that the plea of guilty of 
the defendant to Count 47 of the indictment is accepted and 
entered.  
Mr. Gaines, you are hereby adjudged guilty of the 
charge contained in Count 47 of the indictment.  
I'll now be referring your case to a probation 
officer who will prepare a presentence report.  Before I 
receive the report, sir, 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 that it wishes to present, and 
from you, your attorney, and any witnesses that you wish to 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 24 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
24
present.  
At that time I will decide the proper sentence in 
your case.  
Do you understand?  
THE DEFENDANT:  Yes. 
THE COURT:  Counsel, let me now give you some 
instructions but these will all be included in the notice of 
sentencing that will be filed on the docket.  
If either party requests a departure or a variance or 
if there's a disputed guidelines issue, I require a sentencing 
memo to be filed ten business days before the sentencing 
hearing, the date of which will be provided to you later by 
Ms. Lee.  
Responses are mandatory and must be filed five 
business days before the hearing.  
In the event that the parties agree on the 
appropriate sentence, please inform the Court no later than 
five business days in advance of the hearing.  
Counsel, is there anything else from either side?  
MS. CHAIKEN:  No, your Honor.  Thank you.  
MS. TIMBERLAKE-WILEY:  No, your Honor. 
THE COURT:  All right.  Good to see all of you.  
Ms. Lee, thank you.  
Ms. Coudriet, thank you.  
Officer, I appreciate your help this morning, I guess 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 25 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
25
now this afternoon as well.  
Mr. Gaines, you have taken responsibility for your 
actions this morning.  As I'm sure your attorney has explained 
to you federal law looks favorably on people who do so.  We 
will figure out your sentence in a few months, but I do want 
to commend you here for taking the first step towards making 
things right here.  Okay?  
THE DEFENDANT:  Yes. 
THE COURT:  Take care, everyone.
(PROCEEDINGS REPORTED WERE CONCLUDED 12:06 PM)
___________________________ 
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 26 of 27

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
26
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 11th Day of February, 2024. 
    ________________________________
  
  
               
    PENNY PRITTY COUDRIET, RMR, CRR
    OFFICIAL COURT REPORTER
Case 1:20-cr-00296-JPB-CMS     Document 919     Filed 02/12/24     Page 27 of 27

File and source

File
gov.uscourts.gand.292218.919.0.pdf
Size
233,796 bytes
SHA-256
a98f97aaac9aacf1eabe80821e0cb4ed4ca5bf031df9da2d9ac1fa700318b3ce
Our copy
gov.uscourts.gand.292218.919.0.pdf
Original
PACER (login required)
Back to top