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TRANSCRIPT of Jury Trial Proceedings as to Carla Jackson, Jerry Baptiste, Teldrin… — USA v. Thomas et al (Dkt. 1024)
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An official certified transcript of Jury Trial Proceedings, Volume 1, before the Honorable J.P. Boulee on FEBRUARY 5, 2024, Document 1024 filed 06/14/24, Docket No. 1:20-CR-00296-JPB, in the United States District Court for the Northern District of Georgia, Atlanta Division. Appearances include Tal C. Chaiken, Samir Kaushal and Babasijibomi Moore for the Government and counsel for defendants Teldrin Foster and Carla Jackson, with standby counsel for Jerry Baptiste, who is not present. The Court states it intends to issue a warrant to have Mr. Baptiste brought to court and later states that it signed a warrant for his arrest. The Court also explains its rulings denying Mr. Foster's motion to exclude expert testimony and motion to sever.
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| Court | U.S. District Court for the Northern District of Georgia |
|---|---|
| Filed | 2024-06-14 |
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“TRANSCRIPT of Jury Trial Proceedings as to Carla Jackson, Jerry Baptiste, Teldrin… — USA v. Thomas et al (Dkt. 1024).”
U.S. District Court for the Northern District of Georgia, No. 1:20-cr-00296-JPB-CMS, Doc. 1024, filed 2024-06-14. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-amanda-christian-gand-292218/2024-06-14-gov-uscourts-gand-292218-1024-0-doc-1024/
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA,
)
)
)
-VS-
) DOCKET NO. 1:20-CR-00296-JPB
) VOLUME 1
TELDRIN FOSTER, ET AL,
)
)
DEFENDANT.
)
TRANSCRIPT OF JURY TRIAL PROCEEDINGS
BEFORE THE HONORABLE J.P. BOULEE
UNITED STATES DISTRICT JUDGE
FEBRUARY 5, 2024
APPEARANCES:
ON BEHALF OF THE GOVERNMENT:
TAL C. CHAIKEN, ESQ.
SAMIR KAUSHAL, ESQ.
BABASIJIBOMI MOORE, ESQ.
ASSISTANT UNITED STATES ATTORNEYS
ON BEHALF OF THE DEFENDANT - TELDRIN FOSTER:
LEIGH ANN WEBSTER, ESQ.
SARALIENE DURRETT, ESQ.
ON BEHALF OF THE DEFENDANT - CARLA JACKSON:
DAVID D. MARSHALL, ESQ.
ON BEHALF OF THE DEFENDANT - JERRY BAPTIST (NOT PRESENT)
DOUGLAS W. GILFILLAN, ESQ.
ADITYA SHRIVASTAVA, 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 9:08 AM, ATLANTA, GEORGIA)
COURTROOM DEPUTY CLERK: The Court has set aside time
for a jury trial in Case Number 120-CR-296, the
United States v. Jackson, et al.
Counsel, will you please make your appearances for
the record.
MS. CHAIKEN: Good morning, Your Honor. Tal Chaiken
for the United States. I'm joined by my trial counsel, Samir
Kaushal and Siji Moore. Behind us is our Alisha Holland from
our office, as well as Special Agents Joe Stites and Stefan
Bublitz from the FBI.
THE COURT: Good to see all of you.
MS. WEBSTER: Good morning, Your Honor. Leigh Ann
Webster on behalf of Teldrin Foster, who is here. And then
Saraliene Durrett is downstairs.
THE COURT: All right. Thank you very much.
MR. MARSHALL: Good morning, Judge. David Marshall
on behalf of Defendant Carla Jackson. And with us at the
table is our paralegal, Ms. Sophia Ryan.
MR. GILFILLAN: Good morning, Your Honor. Doug
Gilfillan, standby counsel for Mr. Baptiste. I am here today.
THE COURT: All right. Good to see all of you.
All right. We have a couple unexpected issues that
have arisen over the last 24, 48 hours or so. Let me take the
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one that's just arisen in the last ten minutes or so.
Mr. Baptiste is not here. He's been duly notified of
this trial date and he's not here. And I understand that
we've made attempts to reach out to him to no avail. Is that
correct, Ms. Lee?
COURTROOM DEPUTY CLERK: Yes.
THE COURT: Is that correct, Mr. Gilfillan?
MR. GILFILLAN: Yes, Your Honor.
THE COURT: It's my intent, therefore, to issue a
warrant to have Mr. Baptiste brought to court.
Ms. Lee, if you could coordinate that with
Ms. Chaiken and with the US Marshal Service, I would
appreciate it.
The second issue is -- one moment.
Ms. Durrett, I'll ask you on this second issue.
Would you like me to go under seal for this discussion? I
know that you'd e-mailed the Court and the -- all the counsel
as to the issue, but I'd be happy to go under seal for this if
you'd like.
I think she can hear us, but we can't hear her
perhaps. So, yeah, she'll just call in.
(The following proceedings are under seal:)
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(The record is unsealed)
(Off-the-record discussion.)
(After a recess, the proceedings continued at
9:44 a.m. as follows:)
THE COURT: The record will reflect that I just
signed a warrant for the arrest of Jerry Baptiste. Thank you.
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We're off the record.
(Off-the-record discussion.)
(After a recess, the proceedings continued at 10:02
a.m. as follows:)
THE COURT: All right. Before we begin the trial, I
wanted to just follow up with some orders that I issued via
docket entry just in summary form last week. I wanted to
follow up and give more detail on my rulings of those.
I think it was January 31st I entered an order
denying Mr. Foster's motion to exclude expert testimony and
also his motion to sever.
As far as the motion to exclude the expert testimony,
it was 830. In short, the parties dispute what deadline for
expert disclosure applied to the government in this case. In
any event, the government's disclosure of its intent to call
Special Agent Jay Berni to testify as to cell site data on
January 19th, 2024, may have been untimely. And for the
purposes of this motion and my ruling, I'm going to assume it
was, but I recognize the government's arguments to the
contrary. And it's a little confusing.
On December 1st, 2022, the Federal Rule of Criminal
Procedure was amended to require that the Court, by order or
local rule, must set a time for the government to make its
disclosures. Under the rule, the time must be sufficiently
before trial to provide a fair opportunity for the defendant
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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to meet the government's evidence.
After the rule was amended, this district implemented
a pretrial scheduling order that requires the government to
disclose its expert, if requested by the defendant, no later
than 14 days after the case is certified ready for trial, but
that scheduling order wasn't entered in this case because it
was before that.
Defendant argues for this case, the Court's local
rules provide that the deadline was, in fact, earlier, at the
time of the arrangement.
But, anyway, I'm going to assume it was untimely for
the purposes of my ruling.
If a party fails to comply with the requirements of
Rule 16, a trial court may, A, order that the party permit the
discovery or inspection, specify its time, place and manner
and prescribe other just terms and conditions; B, grant a
continuance; C, prohibit that party from introducing the
undisclosed evidence or enter any other order that is just
under the circumstances. And this Court has wide discretion
in deciding whether to admit the testimony. And also the
discretion to fashion other appropriate relief. That's the US
v. Perez case, 960 F.2d 1569 at 1572 from the Eleventh
Circuit.
In exercising its discretion, the district court must
weigh several factors, and if it decides a sanction is in
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order, should fashion the least severe sanction that will
accomplish the desired result, prompting full compliance with
the Court's discovery orders. That's US v. Euceda,
E-U-C-E-D-A, Hernandez, 768 F.2d 1307 at 1312, Eleventh
Circuit, 1985.
Among the factors the Court must weigh are the
reasons for the government's delay in affording the required
discovery, the extent of prejudice, if any, the defendant has
suffered because of the delay, and the feasibility of curing
such prejudice by granting a continuance or, if the jury's
been sworn and trial has begun, a recess.
The presence of a clear violation of a discovery
order does not excuse a trial from weighing these -- trial
judge from weighing these factors and imposing the least
severe but effective sanction.
Here, Defendant Foster has requested the government
be prohibited from introducing Special Agent Jay Berni's
expert testimony at trial. Exclusion of the evidence is an
extreme sanction. That's from Perez at 1573, quoting US v.
Turner, 871 F.2d 1574 at 1580, also the Eleventh Circuit. And
that was a cert denied case at 493 US 997 from 1989.
I'll also note that the purpose for requiring the
government to disclose evidence is to promote the fair and
efficient administration of criminal justice by providing the
defendant with enough information to make an informed decision
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as to a plea by minimizing the undesirable effect of surprise
at trial and by otherwise contributing to an accurate
determination of the issue of guilt or innocence.
That's also from Euceda-Hernandez. And that's
quoting a Federal Rule of Criminal Procedure, 16 Advisory
Committee Note.
By suppressing the government's evidence rather than
granting a continuance or recess, a trial judge may achieve a
speedier resolution to a criminal case and reduce his docket,
but he does so at the expense of sacrificing the fair
administration of justice and the accurate determination of
guilt and innocence. That's at 1312.
Weighing the circumstance surrounding the
government's arguably late disclosure here, the Court finds
that the extreme sanction of excluding evidence is unwarranted
in this instance. The Court is not convinced that the
January 19th, 2024, disclosure will unfairly prejudice Foster
such that the agent's testimony need to be admitted.
The record demonstrates that Foster possessed the
underlying evidence, the cell site location data, to which the
agent will be testifying for two-and-a-half years. The
government's offered -- and the government has represented
that the testimony is needed to rebut the proffered testimony
of Foster's own expert, who was disclosed on January 12th,
2024.
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Moreover, there's no allegation that the government's
late disclosure was done in bad faith.
However, to alleviate any potential prejudice in
accordance with Rule 16(d)(2)(D), which allows the Court to
enter any other order that is just under the circumstances, on
February 2nd, the Court ordered that the government make
Special Agent Berni available to defense counsel prior to
trial so that defense counsel had an opportunity to consult
with the expert before the testimony is elicited. And that
was docket entry 854.
And that's in part in response to, in the reply
brief, the defendant argued that the government's late
disclosure deprived Mr. Foster of the ability to meaningfully
consult with the expert to challenge the witness's testimony.
Moreover, the government (sic) is now going to direct
the government not to call Agent Berni before Thursday of this
week to give defense a little extra time to digest those
issues.
The Court finds that this is the least severe remedy
necessary to ensure -- these remedies are the least severe
necessary to ensure that Foster has adequate time to assess
the opinions that will be elicited at trial and to prepare
Mr. Foster's defense.
The motion to exclude, again, is denied.
Additionally, the Court is not persuaded that a
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pretrial Daubert hearing is necessary for the agent's
testimony. This type of expert testimony is routine for cases
involving cell site location information and its reliability
for determining the general location of a cell phone is well
established. United States v. Crumpton, 3:22-CR-12-TES-1,
2023 WL 6323792 at 4, Middle District of Georgia, from
September 28th, 2023, noting that district courts largely
agree on the reliability of historical cell site analysis.
While Daubert requires the district court to serve as
a gatekeeper, it need not conduct a formal hearing where the
reliability of an expert's methods is properly taken for
granted, US v. Rodriguez, 591 F.App'x 897 and 899, it's the
Eleventh Circuit from 2015, quoting Kumho Tire, 526 US 152.
However, if at the time of the testimony, defense
counsel believes Agent Berni's testimony doesn't meet the
requirements of 702, they may object at the time of trial.
Again, the request is denied.
And I will add, in deciding this, I noted that late
disclosure of evidence required to be turned over under
Rule 16 or a standing discovery order necessitates reversal
only when -- my decision would be reversed only if it violates
a defendant's substantial rights. So I thought about whether
or not this would violate substantial rights. And that's from
the Camargo-Vergara case, 57 F.3d at 993 at 998, Eleventh
Circuit, in 1995.
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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And the factors there are substantial prejudicial
results if a defendant is unduly surprised and lacks an
adequate opportunity to prepare a defense.
And, again, I don't know that there is any undue
surprise here, especially given the extra time that's been
given and the opportunity to consult with the expert and,
frankly, the reason the government came in with the expert in
response to the defense expert. And I believe the defendant
has now had adequate opportunity to prepare the defense and
will have additional time to do so.
As far as the motion to sever, Docket 866, in the
Eleventh Circuit, the general rule is that defendants who are
jointly indicted should usually be tried together, US v.
Lopez, 648 F.3d at 1222, pinpoint's 1234, Eleventh Circuit,
from 2011.
This is especially true where defendants are charged
in a common conspiracy. This general rule reduces the risk of
inconsistent verdicts and the unfairness inherent in serial
trials, lightens the burden on victims and witnesses,
increases efficiency and conserves scarce judicial resources.
However, Federal Rule of Criminal Procedure 14(a)
provides if the joinder of offenses or defendants in an
indictment and information or consolidation for trial appears
to prejudice the defendant or the government, the Court may
order separate trials of counts, sever the defendants' trials,
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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or provide any other relief that justice requires.
Thus, if a defendant is able to demonstrate that a
joint trial will result in specific and compelling prejudice
to the conduct of his defense, a Rule 14 severance may be
granted. That's the US v. Blasingame case, 219 F.App'x 934 at
948, Eleventh Circuit, 2007. To determine whether a defendant
has demonstrated compelling prejudice, the Court must assess
whether under all the circumstances of a particular case, as a
practical matter, it is within the capacity of the jury to
follow the instructions and, accordingly, appraise the
independent evidence against each defendant's own acts,
statements or conduct.
A defendant can show compelling prejudice by showing
that the jury would be unable to sift through the evidence and
make an individualized determination as to each defendant,
United States v. Cassano, 132 F.3d 646 at 651, Eleventh
Circuit, 1998.
Moreover, to show compelling prejudice warranting
severance, a defendant must show that the other remedies, such
as jury instructions, are not sufficient.
Here, the Court is not persuaded that the jury will
be unable to sift through the evidence and make an
individualized determination as to Mr. Foster, merely because
evidence introduced at trial makes reference to auto loans.
The government has previously represented that it will not
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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introduce any affirmative evidence of auto loan fraud, and the
Court finds that, if needed, an appropriate limiting
instruction to the jury should guard against any prejudice
that would arise from the introduction of such evidence and/or
focus on it during potential cross-examination.
Thus, the motion to sever is denied.
And I'd be happy if -- whether it's this motion to
sever or the other motion to sever, again, if anyone wants a
jury instruction at any point, I'd be happy to review your
proposed instruction and entertain giving that at the
appropriate time. Just let me know and please present to me
whatever you might like and we can discuss it.
All right. That is all I needed to handle before we
got started this morning. But before we get started, before
we start this trial, I want to discuss the issue of
Mr. Baptiste's absence.
Again, at 9:00 he was not here. We attempted to
contact him. His standby counsel attempted to contact him.
All to no avail.
Waited a little while and then issued a warrant at
about 9:45 or so. It is now 10:15. So we have a few
options -- well, at least a couple.
One is we can start the trial without Mr. Baptiste,
which obviously would require us to try Mr. Baptiste at some
later date. And I'm aware of the fact that this is set to be
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probably about a two-week trial. That's option 1.
Option 2 is we could wait a little while to see if
the US Marshals are able to find Mr. Baptiste and bring him
here for trial. And I said a few, but I think it's just a
couple, unless, Ms. Chaiken, you can think of any other
options. And as far as how long we wait, that can be until
after lunch, that could be until tomorrow morning.
I've spoken with jury management and they have jurors
available for us now. Those jurors can wait and have a nice
long lunch and be here after lunch, or those jurors could come
back in the morning.
So happy to open the floor and hear from anyone as to
your thoughts on what we should do. I think it's probably
most relevant to hear from the government, but to the extent
that anyone else wants to be heard, I'd be happy to hear from
them as well.
MS. CHAIKEN: Could we have one moment, Your Honor?
THE COURT: Sure.
(Pause in the proceedings.)
MS. CHAIKEN: Your Honor, we'd like to give agents a
couple of hours to try to locate him and start after lunch, if
possible. We have several witnesses who we anticipate
testifying whose testimony will no longer be needed if
Mr. Baptiste is not part of the trial. And so if he's not
located, the trial will be shorter anyway. So we're not, you
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know -- we don't think we really lose much by waiting a couple
of hours.
But, obviously, if we do find him during that time,
that would eliminate the need for a whole second trial. So
while we don't want to wait too long, we do have some
potential addresses and potential things we can try to track
down that we think it's at least worth just waiting a couple
of hours to find.
THE COURT: Okay.
MS. CHAIKEN: Or to pursue.
THE COURT: Give me a better feel for -- and I
know -- I think your last estimate was probably about two
weeks, might go a little into the third week for this trial.
Tell me how the length of this trial is affected if he were
not here and how long you think it would take to try him
separately.
MS. CHAIKEN: I think if he were -- if he were not
here, this trial would probably be shortened by approximately
two days.
THE COURT: And I'm not going to hold you --
MS. CHAIKEN: Two to three days.
THE COURT: I'm just trying to get an estimate.
MS. CHAIKEN: Two days, I think. If we were to try
him alone, I think the trial would probably be three to five
days.
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THE COURT: Okay. Thank you.
Although I know perhaps there's not a dog in the hunt
exactly, but I'd be happy to hear from counsel for Ms. Jackson
or counsel for Mr. Foster, if you have any thoughts on this
issue.
MS. WEBSTER: I don't think that we have strong
feelings on how to move forward with this.
THE COURT: Very well.
MR. MARSHALL: Judge, I have no objection to the
government's recommendation. I had to do that in another case
of mine, we had to wait a few hours, so that's fine.
THE COURT: Okay. Let's do this, let's see where we
are at 1:00. And we'll decide then -- I'll let you know. I
mean, there's a possibility, obviously, at 1:00 Mr. Baptiste
will be here and hunky-dory and we'll start jury selection.
And if he's not, we may either move forward with jury
selection without him or I may decide to wait until tomorrow
morning to start jury selection.
I would like -- you know, I think as -- I mean,
coincidentally, I was just reading some of the materials on
the severance motion and some of the reasons you don't want to
sever, including judicial efficiency and whatnot. And I'd
like to, and I think it would serve justice, to try everyone
together here, if possible. So it may be that I decide to
wait until tomorrow morning anyway, but let's just at least
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see where we are at 1:00.
All right. So we will --
MR. MARSHALL: Your Honor?
THE COURT: Yes.
MR. MARSHALL: Can I address one matter before we
adjourn?
THE COURT: Yes.
MR. MARSHALL: I filed yesterday on ECF a motion in
limine. And I e-mailed a copy of that to chambers. And I
wanted --
THE COURT: I've got it right here in front of me.
MR. MARSHALL: Thank you, Judge.
And I know the government hasn't had a chance to
obviously file a written response, but I wanted to address it
before we started with opening statements for sure, Judge.
THE COURT: Okay. Thank you. Yes.
I was aware of it. Frankly, had it on the back
burner relative to some concerns we addressed under seal
earlier this morning involving some health issues and then
Mr. Baptiste's absence and the motions I wanted to get on the
record.
But, yes, I'm aware of that. Thank you.
And while we're at it, let me hear from the
government as to when might be a good time to respond.
Obviously, I'd like to decide that if I can before opening
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statements.
MS. CHAIKEN: I'm happy to respond now, Your Honor,
if that would be appropriate.
THE COURT: Well, it would had I read the motion yet.
And I have to confess that I haven't. So it probably would be
a more worthwhile response after I've read the motion, so --
MS. CHAIKEN: I can narrow the issues.
THE COURT: If you want to narrow the part of the
motion that's going to be relevant after you say something,
I'm happy to have you do that.
MS. CHAIKEN: Yes. So, Your Honor, we had been
preparing for a trial with four defendants, including John
Gaines, as to whom we had filed a 404(b) notice. He pled
guilty, I think, on Wednesday. We did not remove the exhibits
that we were planning to introduce. We had not, at the time
we shared our exhibits with the defense, sorted through what
we were and were not going to introduce now that he was no
longer part of the case.
So there were materials that Mr. Marshall had
identified in his motion that related to a Paycheck Protection
Program loan filed by a -- or prepared in connection with a
business called Roadrunner Automotive Group. We are not going
to be seeking to admit those materials at trial.
The only thing that we are seeking to admit at trial
related to Roadrunner Automotive Group is bank records that
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show that in June of 2020 Ms. Jackson and John Gaines were
signers together on that account and that money from the
Gaines Reservation & Travel PPP loan went from Gaines
Reservation & Travel to Darrell Thomas's company, Bellator
Phront Group, and then to Roadrunner. And that those were
proceeds of the same loan with which Ms. Jackson is charged
with laundering money that went to a separate account that she
was a signer on. And, actually, at the time it went to that
account she was the only signer on the account. John Gaines
was added to that account a little bit after that.
And so the -- you know, I understand the Court may
want to read the motion and then hear my argument about why
it's intrinsic evidence in our view, but everything other than
that that's addressed in the motion we're not planning to
introduce.
THE COURT: All right. Well, so since we're so far
down the road already, why don't you go ahead and make your
argument. And then I'll adjust your argument from the written
record after I've read the motion.
So go ahead.
MS. CHAIKEN: Our view is that it's intrinsic
evidence because it's necessary to understand the crime
charged. It's necessary to understand the Gaines Reservation
& Travel loan and where those proceeds went. And we have to
prove that the Gaines Reservation & Travel loan was
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fraudulent.
We have to -- even though Ms. Jackson is not charged
with the fraud itself, we have to prove as a third element of
money laundering that the money did come from an unlawful
activity, which is wire fraud. The fact that that money was
used to go to the account of Darrell Thomas, who was involved
in the submission and preparation of the Gaines Reservation &
Travel loan and then went back to John Gaines and Carla
Jackson is relevant to proving that that loan was fraudulent.
And it's also part of the same series of transactions that
Ms. Jackson is charged with, the movement of the money from
the Gaines Reservation & Travel loan.
THE COURT: All right. Thank you.
Mr. Marshall, anything in reply?
MR. MARSHALL: Judge, I just think it -- that
reference, if they introduce the signature card, that makes
the jurors think that somehow she's involved some way with
Darrell Thomas and John Gaines involved in those moneys.
She's not charged in a conspiracy count, Judge. She's charged
with two counts related to Management Resource Services, which
is her company.
So one thing I could suggest, if the government's
fine, I don't mind this stuff coming in if we could redact
Ms. Jackson's name on the signature card. You know, it
doesn't need to be there to show that she was a signer on the
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account. Mr. Gaines was a signer on the account, and I think
that's what they're trying to aim for, is the movement of
money and the activities of John Gaines and Darrell Thomas,
not my client.
I think it improperly puts my client's character at
issue for a charge that she's not -- she hasn't been charged
with any of these, the conspiracy count, or any of the other
charges, Judge.
MS. CHAIKEN: Your Honor, Mr. Gaines was not a signer
on the account at the time that the money came in. And so to
redact her name from the signature card would leave the jury
with having no idea who the signer was on the account at the
time the money went into it.
And it's also highly relevant evidence to the jury's
understanding of Ms. Jackson's relationship and connection to
John Gaines, who we understand is going to be a defense
witness at trial. And she is charged with Mr. Gaines in money
laundering -- in the money laundering counts related to
Management Resource Services. And this is part of their
understanding of what John Gaines' and Carla Jackson's
financial entanglements were at that point in time.
It's the exact same time period, June 2020, in which
she's charged with money laundering proceeds of the same loan
that went into another account. It shows the jury that
there's two separate accounts that went in there.
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THE COURT: Thank you, Ms. Chaiken.
Mr. Marshall, your motion, so I'll give you the last
word.
MR. MARSHALL: Again, I think it would have been more
appropriate if, for instance, the government had filed a
404(b) notice at the start against my client to give an
indication that they were going to introduce any records
related to Roadrunner. And she's just not charged with any of
the conspiracy counts, what expands it, and it gives the jury
a thought to think that she's involved in another company, in
other activities, and I just think it broadens it, Judge, and
it's not permissible. It's not intrinsic evidence.
THE COURT: All right. Thank you.
I will review the motion and then I'll look back over
the court reporter's record of this conversation and I'll
circle back and let you know what my ruling is, or I may have
some follow-up questions at that time when I'm a little bit
better informed.
All right. It is 10:28. Can anyone else think of
any productive use of our time or should we just recess till
1:00?
MS. CHAIKEN: Your Honor, Mr. Kaushal has a couple
more things.
MR. KAUSHAL: Your Honor, just one issue that we are
now -- since we've talked about the potential of John Gaines
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being called, I just want to flag for Your Honor that there
may be a question as to whether witnesses that are called by
the defense need to be advised of their Fifth Amendment rights
to remain silent when they testify.
For example, Mr. Gaines has a pending sentencing
before Your Honor. I've -- we've loosely discussed the matter
with defense counsel, but I think -- we don't need a final
answer right now. I just wanted to flag it for your Honor's
consideration as we move through the trial and reach that
point. We can have the discussion at that time, but I just
wanted to raise it for Your Honor, that that may be an issue
that comes up.
MR. MARSHALL: Judge, can I address that too?
THE COURT: Yes.
MR. MARSHALL: Judge, while I would hope that the
government also provided that same type of cautionary
instruction or discussion with Darrell Thomas, who is expected
to testify for the government, I don't know if they've done
that.
I've had communications with Mr. John Gaines'
counsel, Ms. Wiley, and she indicated that there were
discussions with the government -- I'm summarizing, Judge, I'm
not -- as I understood it, was that there was some indication,
some kind of -- I don't want to call it a threat -- an implied
threat would be the worst I would say, Judge, of a possible
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obstruction charge. If not an obstruction charge, that
Mr. John Gaines would face an elevated sentencing guideline if
he testified.
And if that wasn't enough, I think there was a
suggestion that he could take the Fifth, invoke his Fifth
Amendment right on the stand. I consider that interfering
with the witness, Judge. I think if I were doing that to a
witness that the government was intending to call, I think
there would be a lot of concern for me.
So I think Ms. Wiley is the one who needs to have
that communicated to by the government, and Ms. Wiley can
decide if she wants to discuss that with him or not.
MR. KAUSHAL: Your Honor, this is a serious
accusation from the defense, and I don't think that they're
thinking through what actually occurred. The defense counsel
was not involved in the conversation that we had with the
defendant, Mr. Gaines' counsel. Mr. Gaines was not on that
phone call, to our knowledge.
We were discussing, in the context of a plea
negotiation, the possibility that there could be something
that occurs when the defendant testifies and that that could
raise a risk of something occurring with the guidelines. We
did not threaten the witness. We did not suggest that the
defendant would be charged with obstruction. We merely noted
that there is a possibility that somebody who testifies and
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has exposure could potentially receive an enhancement under
the guidelines.
So if defense wants to level this accusation, I think
they shouldn't be allowed to do it in this way. They should
formalize their accusation if they are serious about it. But
that is not what occurred. And that is not what the
government was doing when it had a discussion with defense
counsel about a possible risk in the context of a plea
negotiation.
There is a distinguishing factor between these
particular -- for example, Mr. Gaines, who has a pending
sentencing, and any potential cooperator in this case, and,
you know, the government has not -- the individuals who may
testify in this case have entered into plea agreements with
the government. They -- those plea agreements formalize their
cooperation.
And, again, that's an issue. If the defense has a
concern, we can talk about whether there's a necessity to
advise those individuals as well, if they really believe
that's necessary. This is not an attempt to intimidate any
witness. I was just raising the issue so that the Court would
be aware that there's a potential that this may occur.
And there is at least one other witness that the
government is aware of that may be called by a defense party,
not Mr. Marshall, but the government learned that counsel for
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Mr. Foster may be having a witness appear, Ricky Dixon, which
is another individual who may testify on behalf of the
defense. And if he testifies, the same issue comes up.
According to the docket, he is pro se at this time and he has
a pending 2255.
So this is an issue that there just needs to be a
frank discussion about. This is not an effort to influence
any particular witness's testimony. It is simply a way to
protect those defendants' rights. That is all the government
has proposed and tossed out there for the Court to consider as
we approach these -- as we move towards that part of the case.
THE COURT: All right. Thanks, everyone.
Please just remind me when we get to -- if and when
Mr. Gaines is called and if and when Mr. Dixon is called, we
can address that issue then. It may be that they have counsel
with them when they appear or may not --
MS. WEBSTER: I'm sorry, Your Honor, I can't hear
you.
THE COURT: Sure. It may be that they have counsel
with them when they appear and that might affect how we handle
the issue. But I'm always happy to read somebody their
constitutional rights when necessary. Just let me know.
All right?
MR. KAUSHAL: Thank you, Your Honor.
THE COURT: Okay. What else, if anything, can we do
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to occupy our time or have we completed the list?
MS. WEBSTER: Your Honor, we were going to address
this ex parte, but I think that for Mr. Dixon and any other
witness, I think it's appropriate for counsel to be appointed
at some point to advise them as to their rights. I think it's
a little different with Mr. Gaines, because he currently has
counsel, but for Mr. Dixon, I think it would be appropriate
for the Court to appoint counsel to advise him before he
testifies.
THE COURT: He's currently pro se?
MS. CHAIKEN: That's our understanding, Your Honor.
He filed a pro se 2255 challenging his conviction on the basis
that his attorney was ineffective. And so unless a new
attorney has in some way been appointed for him that we're not
aware of, he's pro se.
THE COURT: I'm happy to let him talk to an attorney
and do that, if we can get those documents drawn up, and if he
wants to speak with someone, he can. Okay.
Ms. Mueller, if you can perhaps assist with that.
Thank you.
All right. Anything else?
MS. CHAIKEN: Your Honor, I just want to preview for
the Court that if Mr. Baptiste ultimately does not show up,
we -- with the way we've scheduled our witnesses and with the
Court's order now that Mr. Berni -- or Agent Berni cannot
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testify until Thursday, we may end up having some dead time on
Wednesday. We are working --
THE COURT: Let's do it -- I just want to give the
defense a little extra time. And, frankly, we've now got a
few hours here with nothing to do. So would noon Wednesday be
workable for the government? I don't want to inconvenience
the government too much, but at the same time, I want to make
sure Defendant Foster has a little extra time.
Would noon Wednesday be better?
MS. CHAIKEN: It's fine with us. We --
THE COURT: I would like to avoid dead time, and
you're telling me that there's dead time if it's not until
Thursday?
MS. CHAIKEN: Well, we're calling -- we have several
witnesses who are not scheduled to arrive until late
Wednesday, and we've asked our witness coordinators to get in
touch with all of them and see if they can come earlier. And
so we're working on it as we speak. I just wanted to preview
that we don't -- we're not 100 percent sure we can fill all
that time because we're going to lose several witnesses if
Mr. Baptiste is not here.
THE COURT: All right. If you make efforts to fill
time and you can wait until Thursday to call him, let's do
that.
MS. CHAIKEN: Okay.
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THE COURT: But if there's going to be dead time and
you tell me you've made efforts to fill it and otherwise he's
who we've got here and ready, I'd be inclined to let you call
him on Wednesday afternoon.
And if at that point, Ms. Webster, you need an
additional half day to prepare for that testimony, let me know
as they call him and I'll cross that bridge when we come to
it. Okay?
MS. WEBSTER: Thank you, Your Honor.
MS. CHAIKEN: Thank you, Your Honor.
MR. MARSHALL: Has the government provided -- have
you provided a full witness list yet?
MS. CHAIKEN: No. We're planning on providing our
witnesses the evening before each --
MR. MARSHALL: Day before each one?
MS. CHAIKEN: Yeah. We have provided last night our
witnesses for today.
THE COURT: All right. Thanks, everyone. We'll see
you at 1:00. Thanks for everyone's patience. Take care.
(After a recess, proceedings were continued as
follows:)
THE COURT: It is about 1:00. Back on the record.
Do we have any report from the marshals?
MS. CHAIKEN: Your Honor, we have a -- some updated
information we would like to provide to the Court but not in
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open court.
THE COURT: Okay. If I could ask everyone to step
out except Ms. Chaiken and government counsel for a moment.
Is it something that not even the other counsel could
hear?
MS. CHAIKEN: That would be our preference, Your
Honor. It relates to ongoing investigative --
THE COURT: Can you give me just like subject matter
so I can make a record of that.
MS. CHAIKEN: Just ongoing investigative efforts to
locate Mr. Baptiste.
THE COURT: All right.
Counsel, any objection to stepping out for a moment
just while I discuss that issue with the government?
MS. WEBSTER: I don't think so, Your Honor.
THE COURT: Thanks, everyone. If you'll step out
just for a moment.
(Courtroom cleared of all but United States
Attorney's Office personnel.)
(The following proceedings are under seal.)
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(Record is unsealed and the courtroom open.)
(Parties entered the courtroom.)
THE COURT: We are back out under seal and back on
the record with other counsel back in the courtroom now that
I've had a conversation with the government about their
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efforts to locate Mr. Baptiste, the sum and substance of which
is that they have not located Mr. Baptiste, but they think
there's a possibility they might be able to locate him this
afternoon.
I'm an optimist and I'm hopeful that we will be able
to have Mr. Baptiste here tomorrow morning so that we can have
this trial with the three remaining defendants all at one
time. And I think it's worthwhile to give it the afternoon to
see if that is possible or not.
Also, I'm cognitive of the fact it's 1:15 almost
already, and it would probably be another 15 minutes before
all the jurors are shuffled in if we went forward without him
this afternoon. And who knows what we have for juror
conflicts and et cetera, the 5:00 hour with childcare. So I
don't know how much we would get through of voir dire today
anyway.
Therefore, I would like everyone to report tomorrow
at 9:00 at which time it will be my intent to bring the jury
up, whether we have Mr. Baptiste or whether we don't have
Mr. Baptiste.
And at that time if we don't have Mr. Baptiste,
Mr. Gilfillan, I'll release you and your co-counsel. I know
that you've already spent a lot of time here waiting to see
what happens. And I thank you for your service to the Court.
All right. Would anyone like to be heard before we
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recess for the day?
MS. WEBSTER: I just have one issue, Your Honor.
Specifically we had filed the request for -- about
Ricky Dixon and the writ, for him to be produced ex parte and
under seal.
THE COURT: Sorry, I couldn't hear you.
MS. WEBSTER: We had filed our request for Ricky
Dixon to be produced, the petition for writ under seal and
ex parte. And to my knowledge, no one knew about it but us
and the Court and the judge that signed it. So it's
concerning to us that things that were filed ex parte and that
relate to our defense strategy have been disclosed without our
knowledge to the government. So I would like to address that.
THE COURT: Okay. You're addressing it now. Go
ahead. You would like to address it, so go ahead and make
your record.
MS. WEBSTER: I would like to know how that happened.
We are filing and have filed a number of things ex parte and
under seal, and I want to have some indication that that is --
those are going to be ex parte and under seal and not
disclosed to the government.
THE COURT: All right. And I don't -- I still don't
know what happened. Can you fill me in? I would expect that
if you filed something under seal, it would have been handled
under seal. Was there a mistake or did something go wrong?
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MS. WEBSTER: I don't know what happened, Your Honor.
Sorry. That's what I'm trying to say. When Mr. Kaushal said
earlier today that they are aware that we have tried to get --
or are trying to get Mr. Dixon here, that's the first time I
had any indication that anyone other than us knew about that.
So that's what I'm concerned about.
THE COURT: I guess I'm in the dark, too, but I would
be happy to hear from the government.
MS. CHAIKEN: Your Honor, we have not seen any
ex parte filings that the defense has made. We were contacted
by a BOP administrative person at the facility where Mr. Dixon
is being held because she had not seen a writ that looked the
way his writ looked and she called us to see if we needed him.
And we told her it was not our writ and it was probably issued
by one of the defense attorneys and she should look for a name
on the documentation. And that's how that was brought to our
attention. We have not seen any ex parte filings on that or
on anything else that the defense has made.
THE COURT: Okay. I don't know what we can do
differently on that front if somebody calls up and asks them a
question.
MS. WEBSTER: Sure. I understand. I just wanted to
sort of just note it was concerning to us, but I understand
how it happened. And we just wanted some assurance that that
was not coming from anyone in the courthouse, I guess. So I
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think we have that now. Thank you.
THE COURT: Okay. Very well. Okay. I hope everyone
has an unexpectedly relaxing afternoon, and we'll see you in
the morning right after I hear from Mr. Marshall.
MR. MARSHALL: Sorry, Judge.
Can I ask you to possibly revisit one of your orders.
It was a small administrative motion that I filed. And I
didn't know what the Court's position was on this. I filed a
motion to try to see if my client would be able to have access
to her phone during the trial.
That's just more logistics, like I've had this happen
where I've had somebody in the cafeteria and I can't find them
and I need to get them to court and all that. That's really
it, Your Honor. I wouldn't need anything else, but it would
be -- it would help quite a bit. But if the Court doesn't
normally do that for defendants during trials, I understand,
but I wanted to ask.
THE COURT: All right. Motion to reconsider denied,
I'm sorry.
MR. MARSHALL: Thank you, Judge.
THE COURT: I understand how that would in some ways
make things logistically perhaps a bit easier. There's some
downsides there, too, to opening the floodgates to letting
defendants come on in with their cell phones unfortunately.
And, you know, I think it's probably an instance in
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which a few bad apples have spoiled the barrel for everyone.
I don't doubt perhaps it wouldn't be an issue here, but I'm
worried about setting a precedent that's going to cause me
trouble down the line.
MR. MARSHALL: Yes, Your Honor. Thank you.
THE COURT: I'll certainly understand if there's ever
a slight delay getting somebody back into the courtroom after
a break or something for that reason. And I'll try to be
really clear how long our breaks will be for comfort breaks,
lunch breaks, et cetera.
All right. Anything else?
MS. CHAIKEN: No, Your Honor.
THE COURT: Hearing nothing, enjoy that relaxing
afternoon. See y'all in the morning.
(After a recess taken at 1:15 PM, proceedings were
continued as follows on February 6, 2024:)
___________________________
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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 5th Day of February, 2024.
________________________________
PENNY PRITTY COUDRIET, RMR, CRR
OFFICIAL COURT REPORTER
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1
1 [2] - 1:6, 20:1
100 [1] - 34:19
10:02 [1] - 11:3
10:15 [1] - 19:21
10:28 [1] - 28:19
120-CR-296 [1] - 2:4
1222 [1] - 17:14
1234 [1] - 17:14
12TH [1] - 14:24
1307 [1] - 13:4
1312 [2] - 13:4, 14:12
132 [1] - 18:16
14 [2] - 12:5, 18:4
14(A [1] - 17:21
15 [1] - 40:11
152 [1] - 16:13
1569 [1] - 12:22
1572 [1] - 12:22
1573 [1] - 13:19
1574 [1] - 13:20
1580 [1] - 13:20
16 [3] - 12:14, 14:5, 16:20
16(D)(2)(D [1] - 15:4
1985 [1] - 13:5
1989 [1] - 13:21
1995 [1] - 16:25
1998 [1] - 18:17
19TH [2] - 11:17, 14:17
1:00 [6] - 22:13, 22:14, 23:1, 28:21,
35:19, 35:22
1:15 [2] - 40:10, 44:15
1:20-CR-00296-JPB [1] - 1:5
1ST [1] - 11:21
2
2 [1] - 20:2
2007 [1] - 18:6
2011 [1] - 17:15
2015 [1] - 16:13
2020 [2] - 25:1, 27:22
2022 [1] - 11:21
2023 [2] - 16:6, 16:7
2024 [6] - 1:10, 11:17, 14:17, 14:25,
44:16, 45:9
219 [1] - 18:5
2255 [2] - 32:5, 33:12
24 [1] - 2:25
28TH [1] - 16:7
2ND [1] - 15:6
3
31ST [1] - 11:9
3:22-CR-12-TES-1 [1] - 16:5
4
4 [1] - 16:6
404(B [2] - 24:13, 28:6
48 [1] - 2:25
493 [1] - 13:21
5
5 [1] - 1:10
526 [1] - 16:13
57 [1] - 16:24
591 [1] - 16:12
5:00 [1] - 40:14
5TH [1] - 45:9
6
6 [1] - 44:16
6323792 [1] - 16:6
646 [1] - 18:16
648 [1] - 17:14
651 [1] - 18:16
7
702 [1] - 16:16
768 [1] - 13:4
8
830 [1] - 11:13
854 [1] - 15:10
866 [1] - 17:11
871 [1] - 13:20
897 [1] - 16:12
899 [1] - 16:12
9
90 [1] - 1:5
934 [1] - 18:5
948 [1] - 18:6
960 [1] - 12:22
993 [1] - 16:24
997 [1] - 13:21
998 [1] - 16:24
9:00 [2] - 19:17, 40:18
9:08 [1] - 2:2
9:44 [1] - 10:23
9:45 [1] - 19:21
A
A.M [2] - 10:23, 11:4
ABILITY [1] - 15:13
ABLE [5] - 18:2, 20:3, 40:3, 40:5, 43:9
ABSENCE [2] - 19:16, 23:20
ACCESS [1] - 43:9
ACCOMPLISH [1] - 13:2
ACCORDANCE [1] - 15:4
ACCORDING [1] - 32:4
ACCORDINGLY [1] - 18:10
ACCOUNT [11] - 25:2, 25:7, 25:9, 25:10,
26:6, 27:1, 27:10, 27:12, 27:24
1
ACCOUNTS [1] - 27:25
ACCURATE [2] - 14:2, 14:11
ACCUSATION [3] - 30:14, 31:3, 31:5
ACHIEVE [1] - 14:8
ACTIVITIES [2] - 27:3, 28:11
ACTIVITY [1] - 26:5
ACTS [1] - 18:11
ADD [1] - 16:18
ADDED [1] - 25:10
ADDITIONAL [2] - 17:10, 35:6
ADDITIONALLY [1] - 15:25
ADDRESS [7] - 23:5, 23:14, 29:13,
32:15, 33:2, 41:13, 41:15
ADDRESSED [2] - 23:18, 25:14
ADDRESSES [1] - 21:6
ADDRESSING [1] - 41:14
ADEQUATE [3] - 15:21, 17:3, 17:9
ADITYA [1] - 1:20
ADJOURN [1] - 23:6
ADJUST [1] - 25:18
ADMINISTRATION [2] - 13:24, 14:11
ADMINISTRATIVE [2] - 42:11, 43:7
ADMIT [3] - 12:20, 24:23, 24:24
ADMITTED [1] - 14:18
ADVISE [3] - 31:19, 33:5, 33:8
ADVISED [1] - 29:3
ADVISORY [1] - 14:5
AFFECT [1] - 32:20
AFFECTED [1] - 21:14
AFFORDING [1] - 13:7
AFORESAID [1] - 45:8
AFTER [1] - 1:7
AFTERNOON [6] - 35:4, 40:4, 40:8,
40:13, 43:3, 44:14
AGENT [1] - 14:21
AGENT [6] - 11:16, 13:17, 15:7, 15:16,
16:15, 33:25
AGENT'S [2] - 14:18, 16:1
AGENTS [1] - 20:20
AGENTS [1] - 2:11
AGREE [1] - 16:8
AGREEMENTS [2] - 31:14, 31:15
AHEAD [4] - 25:17, 25:20, 41:15
AIM [1] - 27:2
AL [1] - 1:6
AL [1] - 2:5
ALISHA [1] - 2:10
ALLEGATION [1] - 15:1
ALLEVIATE [1] - 15:3
ALLOWED [1] - 31:4
ALLOWS [1] - 15:4
ALMOST [1] - 40:10
ALONE [1] - 21:24
AM [1] - 2:2
AMENDED [2] - 11:22, 12:2
AMENDMENT [2] - 29:3, 30:6
AMERICA [1] - 1:4
AN [1] - 1:2
ANALYSIS [1] - 16:8
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AND [2] - 1:4, 1:7
ANN [1] - 2:14
ANN [1] - 1:16
ANSWER [1] - 29:8
ANTICIPATE [1] - 20:22
ANY [1] - 1:9
ANYWAY [4] - 12:11, 20:25, 22:25,
40:16
APPEAR [3] - 32:1, 32:16, 32:20
APPEARANCES [1] - 2:6
APPEARANCES [1] - 1:11
APPLES [1] - 44:1
APPLIED [1] - 11:14
APPOINT [1] - 33:8
APPOINTED [2] - 33:4, 33:14
APPRAISE [1] - 18:10
APPRECIATE [1] - 3:13
APPROACH [1] - 32:11
APPROPRIATE [7] - 12:21, 19:2, 19:11,
24:3, 28:5, 33:4, 33:7
ARE [1] - 1:8
ARGUABLY [1] - 14:14
ARGUED [1] - 15:12
ARGUES [1] - 12:8
ARGUMENT [3] - 25:12, 25:18
ARGUMENTS [1] - 11:19
ARISE [1] - 19:4
ARISEN [2] - 2:25, 3:1
ARRANGEMENT [1] - 12:10
ARREST [1] - 10:25
ARRIVE [1] - 34:15
ASIDE [1] - 2:3
ASSESS [2] - 15:21, 18:7
ASSIST [1] - 33:19
ASSISTANT [1] - 1:14
ASSUME [2] - 11:18, 12:11
ASSURANCE [1] - 42:24
AT [1] - 2:2
ATLANTA [3] - 1:2, 1:24, 2:2
ATTACHED [1] - 1:6
ATTACHING [1] - 1:9
ATTEMPT [1] - 31:20
ATTEMPTED [2] - 19:17, 19:18
ATTEMPTS [1] - 3:4
ATTENTION [1] - 42:17
ATTORNEY [3] - 33:13, 33:14, 33:16
ATTORNEY'S [1] - 36:19
ATTORNEYS [1] - 1:14
ATTORNEYS [1] - 42:15
AUTO [2] - 18:24, 19:1
AUTOMOTIVE [2] - 24:22, 24:25
AVAIL [2] - 3:4, 19:19
AVAILABLE [2] - 15:7, 20:9
AVOID [1] - 34:11
AWARE [7] - 19:25, 23:17, 23:22, 31:22,
31:24, 33:15, 42:3
B
BABASIJIBOMI [1] - 1:14
BAD [2] - 15:2, 44:1
BANK [1] - 24:25
BAPTIST [1] - 1:19
BAPTISTE [18] - 2:22, 3:2, 3:10, 10:25,
19:23, 19:24, 20:3, 20:24, 22:14,
33:23, 34:21, 36:11, 40:1, 40:2, 40:6,
40:19, 40:20, 40:21
BAPTISTE'S [2] - 19:16, 23:20
BARREL [1] - 44:1
BASIS [1] - 33:12
BE [2] - 1:3, 1:4
BEFORE [1] - 1:9
BEGIN [1] - 11:5
BEGUN [1] - 13:11
BEHALF [3] - 2:15, 2:19, 32:2
BEHALF [4] - 1:12, 1:15, 1:17, 1:19
BEHIND [1] - 2:10
BELIEVES [1] - 16:15
BELLATOR [1] - 25:4
BERNI [5] - 11:16, 15:7, 15:16, 33:25
BERNI'S [2] - 13:17, 16:15
BETTER [3] - 21:11, 28:18, 34:9
BETWEEN [1] - 31:10
BIT [4] - 25:10, 28:17, 43:15, 43:22
BLASINGAME [1] - 18:5
BOP [1] - 42:11
BOULEE [1] - 1:9
BREAK [1] - 44:8
BREAKS [3] - 44:9, 44:10
BRIDGE [1] - 35:7
BRIEF [1] - 15:12
BRING [2] - 20:3, 40:18
BROADENS [1] - 28:11
BROUGHT [2] - 3:10, 42:16
BUBLITZ [1] - 2:12
BURDEN [1] - 17:19
BURNER [1] - 23:18
BUSINESS [1] - 24:22
BY [3] - 1:4, 1:6, 1:21
C
CAFETERIA [1] - 43:12
CAMARGO [1] - 16:24
CAMARGO-VERGARA [1] - 16:24
CANNOT [1] - 33:25
CAPACITY [1] - 18:9
CARD [3] - 26:16, 26:24, 27:11
CARE [1] - 35:19
CARLA [1] - 1:17
CARLA [3] - 2:19, 26:8, 27:20
CASE [16] - 11:14, 12:5, 12:6, 12:8,
12:22, 13:21, 14:9, 16:24, 18:5, 18:8,
22:10, 24:18, 31:12, 31:14, 32:11,
45:8
CASE [1] - 2:4
CASES [1] - 16:2
CASSANO [1] - 18:16
CAUTIONARY [1] - 29:16
CELL [6] - 11:16, 14:20, 16:3, 16:4,
2
16:8, 43:24
CERT [1] - 13:21
CERTAINLY [1] - 44:6
CERTIFIED [1] - 12:5
CERTIFY [1] - 45:6
CETERA [2] - 40:14, 44:10
CHAIKEN [27] - 1:13, 2:8, 20:17, 20:20,
21:10, 21:17, 21:21, 21:23, 24:2, 24:7,
24:11, 25:21, 27:9, 28:22, 33:11,
33:22, 34:10, 34:14, 34:25, 35:10,
35:13, 35:16, 35:24, 36:6, 36:10, 42:9,
44:12
CHAIKEN [5] - 2:8, 3:12, 20:5, 28:1,
36:3
CHALLENGE [1] - 15:14
CHALLENGING [1] - 33:12
CHAMBERS [1] - 23:9
CHANCE [1] - 23:13
CHARACTER [1] - 27:5
CHARGE [3] - 27:6, 30:1
CHARGED [12] - 17:16, 25:6, 25:23,
26:2, 26:11, 26:19, 27:6, 27:17, 27:23,
28:8, 30:24
CHARGES [1] - 27:8
CHILDCARE [1] - 40:14
CIRCLE [1] - 28:16
CIRCUIT [9] - 12:23, 13:5, 13:20, 16:13,
16:25, 17:12, 17:14, 18:6, 18:17
CIRCUMSTANCE [1] - 14:13
CIRCUMSTANCES [3] - 12:19, 15:5,
18:8
CITE [1] - 1:5
CLEAR [2] - 13:12, 44:9
CLEARED [1] - 36:18
CLERK [2] - 2:3, 3:6
CLIENT [3] - 27:4, 28:6, 43:9
CLIENT'S [1] - 27:5
CM/ECF [2] - 1:3, 1:5
CO [1] - 40:22
CO-COUNSEL [1] - 40:22
COGNITIVE [1] - 40:10
COINCIDENTALLY [1] - 22:20
COMFORT [1] - 44:9
COMING [2] - 26:23, 42:25
COMMITTEE [1] - 14:6
COMMON [1] - 17:17
COMMUNICATED [1] - 30:11
COMMUNICATIONS [1] - 29:20
COMPANY [3] - 25:4, 26:21, 28:10
COMPELLING [4] - 18:3, 18:7, 18:13,
18:18
COMPLETED [1] - 33:1
COMPLIANCE [1] - 13:2
COMPLY [1] - 12:13
CONCERN [2] - 30:9, 31:18
CONCERNED [1] - 42:6
CONCERNING [2] - 41:11, 42:23
CONCERNS [1] - 23:18
CONDITIONS [1] - 12:16
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CONDUCT [3] - 16:10, 18:4, 18:12
CONFESS [1] - 24:5
CONFLICTS [1] - 40:14
CONFUSING [1] - 11:20
CONNECTION [2] - 24:21, 27:15
CONSERVES [1] - 17:20
CONSIDER [2] - 30:6, 32:10
CONSIDERATION [1] - 29:9
CONSOLIDATION [1] - 17:23
CONSPIRACY [4] - 17:17, 26:19, 27:7,
28:9
CONSTITUTIONAL [1] - 32:22
CONSULT [3] - 15:8, 15:14, 17:6
CONTACT [2] - 19:18
CONTACTED [1] - 42:10
CONTEXT [2] - 30:19, 31:8
CONTINUANCE [3] - 12:17, 13:10, 14:8
CONTINUED [4] - 10:22, 11:3, 35:20,
44:16
CONTRARY [1] - 11:20
CONTRIBUTING [1] - 14:2
CONVERSATION [3] - 28:15, 30:16,
39:25
CONVICTION [1] - 33:12
CONVINCED [1] - 14:16
COOPERATION [1] - 31:16
COOPERATOR [1] - 31:12
COORDINATE [1] - 3:11
COORDINATORS [1] - 34:16
COPY [1] - 23:9
CORRECT [3] - 3:5, 3:7, 45:7
COUDRIET [2] - 1:22, 45:15
COUNSEL [26] - 2:6, 2:9, 2:22, 3:17,
15:7, 15:8, 16:15, 19:18, 22:3, 22:4,
29:7, 29:21, 30:15, 30:17, 31:8, 31:25,
32:15, 32:19, 33:4, 33:7, 33:8, 36:3,
36:4, 36:13, 39:24, 40:22
COUNT [2] - 26:19, 27:7
COUNTS [4] - 17:25, 26:20, 27:18, 28:9
COUPLE [7] - 2:24, 19:22, 20:5, 20:21,
21:1, 21:7, 28:22
COURT [7] - 3:10, 12:14, 12:24, 16:9,
28:15, 36:1, 43:13
COURT [24] - 2:3, 3:17, 11:22, 12:19,
13:6, 14:14, 14:16, 15:4, 15:6, 15:19,
15:25, 17:24, 18:7, 18:21, 19:2, 25:11,
31:21, 32:10, 33:8, 33:23, 35:25,
40:24, 41:10, 43:15
COURT [61] - 1:4, 1:7, 1:10, 1:1, 1:23,
1:23, 2:2, 2:13, 2:17, 2:23, 3:7, 3:9,
10:24, 11:5, 20:18, 21:9, 21:11, 21:20,
21:22, 22:1, 22:8, 22:12, 23:4, 23:7,
23:11, 23:16, 24:4, 24:8, 25:16, 26:13,
28:1, 28:13, 29:14, 32:12, 32:19,
32:25, 33:10, 33:16, 34:3, 34:11,
34:22, 35:1, 35:18, 35:22, 36:2, 36:8,
36:12, 36:16, 39:23, 41:6, 41:14,
41:22, 42:7, 42:19, 43:2, 43:18, 43:21,
44:6, 44:13, 45:3, 45:15
COURT'S [4] - 12:8, 13:3, 33:25, 43:8
COURTHOUSE [1] - 42:25
COURTROOM [1] - 36:18
COURTROOM [2] - 2:3, 3:6
COURTROOM [4] - 39:21, 39:22, 39:24,
44:7
COURTS [1] - 16:7
CRIME [1] - 25:22
CRIMINAL [3] - 11:21, 14:5, 17:21
CRIMINAL [2] - 13:24, 14:9
CROSS [2] - 19:5, 35:7
CROSS-EXAMINATION [1] - 19:5
CRR [2] - 1:22, 45:15
CRUMPTON [1] - 16:5
CURING [1] - 13:9
D
DARK [1] - 42:7
DARRELL [5] - 25:4, 26:6, 26:18, 27:3,
29:17
DATA [2] - 11:16, 14:20
DATE [2] - 3:3, 19:25
DAUBERT [2] - 16:1, 16:9
DAVID [1] - 2:18
DAVID [1] - 1:18
DAYS [1] - 1:5
DAYS [5] - 12:5, 21:19, 21:21, 21:23,
21:25
DEAD [4] - 34:1, 34:11, 34:12, 35:1
DEADLINE [2] - 11:13, 12:9
DECEMBER [1] - 11:21
DECIDE [5] - 22:13, 22:17, 22:24, 23:25,
30:12
DECIDES [1] - 12:25
DECIDING [2] - 12:20, 16:18
DECISION [2] - 13:25, 16:21
DEFENDANT [17] - 11:25, 12:4, 12:8,
13:8, 13:25, 15:12, 17:2, 17:8, 17:24,
18:2, 18:6, 18:13, 18:15, 18:19, 30:17,
30:21, 30:24
DEFENDANT [4] - 1:7, 1:15, 1:17, 1:19
DEFENDANT [3] - 2:19, 13:16, 34:8
DEFENDANT'S [2] - 16:22, 18:11
DEFENDANTS [7] - 17:12, 17:16, 17:22,
24:12, 40:7, 43:16, 43:24
DEFENDANTS' [2] - 17:25, 32:9
DEFENSE [25] - 15:7, 15:8, 15:17,
15:23, 16:14, 17:3, 17:8, 17:9, 18:4,
24:16, 27:16, 29:3, 29:7, 30:14, 30:15,
31:3, 31:7, 31:17, 31:24, 32:3, 34:4,
41:12, 42:10, 42:15, 42:18
DELAY [3] - 13:7, 13:9, 44:7
DEMONSTRATE [1] - 18:2
DEMONSTRATED [1] - 18:7
DEMONSTRATES [1] - 14:19
DENIED [5] - 13:21, 15:24, 16:17, 19:6,
43:18
DENYING [1] - 11:10
DEPRIVED [1] - 15:13
DEPUTY [2] - 2:3, 3:6
3
DESIRED [1] - 13:2
DETAIL [1] - 11:8
DETERMINATION [4] - 14:3, 14:11,
18:15, 18:23
DETERMINE [1] - 18:6
DETERMINING [1] - 16:4
DIFFERENT [1] - 33:6
DIFFERENTLY [1] - 42:20
DIGEST [1] - 15:17
DIRE [1] - 40:15
DIRECT [1] - 15:15
DISCLOSE [2] - 12:4, 13:23
DISCLOSED [3] - 14:24, 41:12, 41:21
DISCLOSURE [7] - 11:14, 11:15, 14:14,
14:17, 15:2, 15:13, 16:19
DISCLOSURES [1] - 11:24
DISCOVERY [5] - 12:15, 13:3, 13:8,
13:12, 16:20
DISCRETION [3] - 12:19, 12:21, 12:24
DISCUSS [4] - 19:12, 19:15, 30:12,
36:14
DISCUSSED [1] - 29:6
DISCUSSING [1] - 30:19
DISCUSSION [7] - 3:16, 10:21, 11:2,
29:10, 29:17, 31:7, 32:7
DISCUSSIONS [1] - 29:22
DISPUTE [1] - 11:13
DISTINGUISHING [1] - 31:10
DISTRICT [1] - 16:6
DISTRICT [6] - 1:1, 1:1, 1:10, 1:23, 45:3,
45:4
DISTRICT [4] - 12:2, 12:24, 16:7, 16:9
DIVISION [1] - 1:2
DIXON [8] - 32:1, 32:14, 33:3, 33:7,
41:4, 41:8, 42:4, 42:11
DOCKET [4] - 11:7, 14:9, 15:10, 32:4
DOCKET [1] - 17:11
DOCKET [2] - 1:6, 1:5
DOCUMENT [1] - 1:10
DOCUMENTATION [1] - 42:16
DOCUMENTS [1] - 33:17
DOG [1] - 22:2
DONE [2] - 15:2, 29:18
DORY [1] - 22:15
DOUBT [1] - 44:2
DOUG [1] - 2:21
DOUGLAS [1] - 1:19
DOWN [4] - 21:7, 25:17, 44:4, 45:7
DOWNSIDES [1] - 43:23
DOWNSTAIRS [1] - 2:16
DRAWN [1] - 33:17
DULY [1] - 3:2
DURING [4] - 19:5, 21:3, 43:10, 43:16
DURRETT [2] - 2:16, 3:15
DURRETT [1] - 1:16
E
E-MAILED [2] - 3:17, 23:9
EASIER [1] - 43:22
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 49 of 55
ECF [1] - 23:8
EFFECT [1] - 14:1
EFFECTIVE [1] - 13:15
EFFICIENCY [2] - 17:20, 22:22
EFFICIENT [1] - 13:24
EFFORT [1] - 32:7
EFFORTS [4] - 34:22, 35:2, 36:10, 40:1
EITHER [1] - 22:16
ELEMENT [1] - 26:3
ELEVATED [1] - 30:2
ELEVENTH [9] - 12:22, 13:4, 13:20,
16:13, 16:24, 17:12, 17:14, 18:6,
18:16
ELICITED [2] - 15:9, 15:22
ELIMINATE [1] - 21:4
END [1] - 34:1
ENHANCEMENT [1] - 31:1
ENJOY [1] - 44:13
ENSURE [2] - 15:20, 15:21
ENTANGLEMENTS [1] - 27:21
ENTER [2] - 12:18, 15:5
ENTERED [4] - 11:9, 12:6, 31:14, 39:22
ENTERTAIN [1] - 19:10
ENTRY [2] - 11:7, 15:10
ENTRY [1] - 1:6
ESPECIALLY [2] - 17:5, 17:16
ESQ [8] - 1:13, 1:13, 1:14, 1:16, 1:16,
1:18, 1:19, 1:20
ESTABLISHED [1] - 16:5
ESTIMATE [2] - 21:12, 21:22
ET [1] - 1:6
ET [3] - 2:5, 40:14, 44:10
EUCEDA [2] - 13:3, 14:4
EUCEDA [1] - 13:4
EUCEDA-HERNANDEZ [1] - 14:4
EVENING [1] - 35:14
EVENT [1] - 11:15
EVIDENCE [18] - 12:1, 12:18, 13:18,
13:23, 14:7, 14:15, 14:20, 16:19,
18:11, 18:14, 18:22, 18:24, 19:1, 19:4,
25:13, 25:22, 27:14, 28:12
EX [8] - 33:3, 41:4, 41:9, 41:11, 41:18,
41:20, 42:10, 42:17
EXACT [1] - 27:22
EXACTLY [1] - 22:3
EXAMINATION [1] - 19:5
EXAMPLE [2] - 29:5, 31:11
EXCEPT [1] - 36:3
EXCLUDE [3] - 11:10, 11:12, 15:24
EXCLUDING [1] - 14:15
EXCLUSION [1] - 13:18
EXCUSE [1] - 13:13
EXERCISING [1] - 12:24
EXHIBITS [2] - 24:14, 24:16
EXPANDS [1] - 28:9
EXPECT [1] - 41:23
EXPECTED [1] - 29:17
EXPENSE [1] - 14:10
EXPERT [12] - 11:10, 11:12, 11:14,
12:4, 13:18, 14:24, 15:9, 15:14, 16:2,
17:6, 17:7, 17:8
EXPERT'S [1] - 16:11
EXPOSURE [1] - 31:1
EXTENT [2] - 13:8, 20:14
EXTRA [4] - 15:17, 17:5, 34:4, 34:8
EXTREME [2] - 13:19, 14:15
F
F.2D [3] - 12:22, 13:4, 13:20
F.3D [3] - 16:24, 17:14, 18:16
F.APP'X [2] - 16:12, 18:5
FACE [1] - 30:2
FACILITY [1] - 42:11
FACT [4] - 12:9, 19:25, 26:5, 40:10
FACTOR [1] - 31:10
FACTORS [4] - 12:25, 13:6, 13:14, 17:1
FAILS [1] - 12:13
FAIR [3] - 11:25, 13:23, 14:10
FAITH [1] - 15:2
FAR [4] - 11:12, 17:11, 20:6, 25:16
FASHION [2] - 12:21, 13:1
FBI [1] - 2:12
FEASIBILITY [1] - 13:9
FEBRUARY [3] - 15:6, 44:16, 45:9
FEBRUARY [1] - 1:10
FEDERAL [3] - 11:21, 14:5, 17:21
FEELINGS [1] - 22:7
FEW [5] - 19:21, 20:4, 22:11, 34:5, 44:1
FIFTH [3] - 29:3, 30:5
FILE [1] - 23:14
FILED [3] - 1:3, 1:8, 1:10
FILED [12] - 23:8, 24:13, 24:21, 28:5,
33:12, 41:3, 41:7, 41:11, 41:18, 41:24,
43:7, 43:8
FILING [1] - 41:18
FILINGS [2] - 42:10, 42:17
FILL [4] - 34:19, 34:22, 35:2, 41:23
FINAL [1] - 29:7
FINANCIAL [1] - 27:21
FINE [3] - 22:11, 26:23, 34:10
FIRST [1] - 42:4
FIVE [1] - 21:24
FLAG [2] - 29:1, 29:8
FLOODGATES [1] - 43:23
FLOOR [1] - 20:12
FOCUS [1] - 19:5
FOLLOW [4] - 11:6, 11:8, 18:10, 28:17
FOLLOW-UP [1] - 28:17
FOLLOWING [2] - 3:22, 36:20
FOLLOWING [1] - 1:2
FOLLOWS [4] - 10:23, 11:4, 35:21,
44:16
FOR [2] - 1:5, 1:1
FOREGOING [1] - 45:6
FORM [1] - 11:7
FORMAL [1] - 16:10
FORMALIZE [2] - 31:5, 31:15
FORWARD [3] - 22:7, 22:16, 40:12
4
FOSTER [10] - 2:15, 13:16, 14:17,
14:19, 15:13, 15:21, 18:23, 22:4, 32:1,
34:8
FOSTER [2] - 1:6, 1:15
FOSTER'S [3] - 11:10, 14:24, 15:23
FOUR [1] - 24:12
FRANK [1] - 32:7
FRANKLY [3] - 17:7, 23:17, 34:4
FRAUD [3] - 19:1, 26:3, 26:5
FRAUDULENT [2] - 26:1, 26:9
FROM [1] - 1:9
FRONT [2] - 23:11, 42:20
FULL [2] - 13:2, 35:12
FULL [1] - 1:9
G
GAINES [23] - 24:13, 25:1, 25:3, 25:9,
25:23, 25:25, 26:7, 26:8, 26:12, 26:18,
27:1, 27:3, 27:9, 27:16, 27:17, 28:25,
29:5, 30:2, 30:17, 31:11, 32:14, 33:6
GAINES' [3] - 27:20, 29:20, 30:17
GATEKEEPER [1] - 16:10
GENERAL [3] - 16:4, 17:12, 17:17
GEORGIA [4] - 1:1, 1:24, 2:2, 45:4
GEORGIA [1] - 16:6
GILFILLAN [3] - 1:19, 2:21, 3:8
GILFILLAN [3] - 2:22, 3:7, 40:22
GIVEN [2] - 17:5, 17:6
GOVERNMENT [36] - 11:14, 11:23,
12:3, 13:16, 13:23, 14:22, 15:6, 15:15,
15:16, 17:7, 17:24, 18:25, 20:14,
23:13, 23:24, 28:5, 29:16, 29:18,
29:22, 30:8, 30:11, 31:7, 31:13, 31:15,
31:24, 31:25, 32:9, 34:6, 34:7, 35:11,
36:3, 36:14, 39:25, 41:13, 41:21, 42:8
GOVERNMENT [1] - 1:12
GOVERNMENT'S [11] - 11:15, 11:19,
12:1, 13:7, 14:7, 14:14, 14:22, 15:1,
15:12, 22:10, 26:22
GRANT [1] - 12:16
GRANTED [2] - 16:12, 18:5
GRANTING [2] - 13:10, 14:8
GROUP [3] - 24:22, 24:25, 25:5
GUARD [1] - 19:3
GUESS [2] - 42:7, 42:25
GUIDELINE [1] - 30:2
GUIDELINES [2] - 30:22, 31:2
GUILT [2] - 14:3, 14:12
GUILTY [1] - 24:14
H
HALF [2] - 14:21, 35:6
HANDLE [2] - 19:13, 32:20
HANDLED [1] - 41:24
HAPPY [11] - 3:18, 19:7, 19:9, 20:12,
20:15, 22:3, 24:2, 24:10, 32:21, 33:16,
42:8
HAS [1] - 1:8
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 50 of 55
HEALTH [1] - 23:19
HEAR [13] - 3:20, 20:12, 20:14, 20:15,
22:3, 23:23, 25:12, 32:17, 36:5, 41:6,
42:8, 43:4
HEARD [2] - 20:15, 40:25
HEARING [3] - 16:1, 16:10, 44:13
HELD [1] - 42:12
HELD [1] - 2:2
HELP [1] - 43:15
HEREBY [1] - 45:6
HERNANDEZ [2] - 13:4, 14:4
HIGHLY [1] - 27:14
HISTORICAL [1] - 16:8
HOLD [1] - 21:20
HOLLAND [1] - 2:10
HONOR [32] - 2:8, 2:14, 2:21, 3:8,
20:17, 20:20, 23:3, 24:2, 24:11, 27:9,
28:22, 28:24, 29:1, 29:6, 29:11, 30:13,
32:17, 32:24, 33:2, 33:11, 33:22, 35:9,
35:10, 35:24, 36:7, 36:15, 41:2, 42:1,
42:9, 43:14, 44:5, 44:12
HONOR'S [1] - 29:8
HONORABLE [1] - 1:9
HOPE [2] - 29:15, 43:2
HOPEFUL [1] - 40:5
HOUR [1] - 40:14
HOURS [6] - 2:25, 20:21, 21:2, 21:8,
22:11, 34:5
HOWEVER [1] - 1:8
HUNKY [1] - 22:15
HUNKY-DORY [1] - 22:15
HUNT [1] - 22:2
I
IDEA [1] - 27:12
IDENTIFIED [1] - 24:20
IMPLEMENTED [1] - 12:2
IMPLIED [1] - 29:24
IMPOSING [1] - 13:14
IMPROPERLY [1] - 27:5
IN [3] - 1:3, 1:4, 2:2
INCLINED [1] - 35:3
INCLUDING [2] - 22:22, 24:12
INCONSISTENT [1] - 17:18
INCONVENIENCE [1] - 34:6
INCREASES [1] - 17:20
INDEPENDENT [1] - 18:11
INDICATED [1] - 29:21
INDICATION [4] - 28:7, 29:23, 41:19,
42:5
INDICTED [1] - 17:13
INDICTMENT [1] - 17:23
INDIVIDUAL [1] - 32:2
INDIVIDUALIZED [2] - 18:15, 18:23
INDIVIDUALS [2] - 31:13, 31:19
INEFFECTIVE [1] - 33:13
INFLUENCE [1] - 32:7
INFORMATION [4] - 13:25, 16:3, 17:23,
35:25
INFORMED [2] - 13:25, 28:18
INHERENT [1] - 17:18
INNOCENCE [2] - 14:3, 14:12
INSPECTION [1] - 12:15
INSTANCE [3] - 14:16, 28:5, 43:25
INSTRUCTION [4] - 19:3, 19:9, 19:10,
29:17
INSTRUCTIONS [2] - 18:10, 18:20
INTENDING [1] - 30:8
INTENT [3] - 3:9, 11:15, 40:18
INTERFERING [1] - 30:6
INTIMIDATE [1] - 31:20
INTRINSIC [3] - 25:13, 25:21, 28:12
INTRODUCE [6] - 19:1, 24:15, 24:17,
25:15, 26:16, 28:7
INTRODUCED [1] - 18:24
INTRODUCING [2] - 12:17, 13:17
INTRODUCTION [1] - 19:4
INVESTIGATIVE [2] - 36:7, 36:10
INVOKE [1] - 30:5
INVOLVED [5] - 26:6, 26:17, 26:18,
28:10, 30:16
INVOLVING [2] - 16:3, 23:19
IS [1] - 1:2
ISSUE [19] - 3:9, 3:14, 3:15, 3:18, 14:3,
19:15, 22:5, 27:6, 28:24, 29:11, 31:17,
31:21, 32:3, 32:6, 32:15, 32:21, 36:14,
41:2, 44:2
ISSUED [3] - 11:6, 19:20, 42:14
ISSUES [4] - 2:24, 15:18, 23:19, 24:7
ITSELF [1] - 26:3
J
J.P [1] - 1:9
JACKSON [8] - 2:5, 2:19, 22:3, 25:1,
25:6, 26:2, 26:9, 26:11
JACKSON [1] - 1:17
JACKSON'S [3] - 26:24, 27:15, 27:20
JANUARY [4] - 11:9, 11:17, 14:17,
14:24
JAY [2] - 11:16, 13:17
JERRY [1] - 10:25
JERRY [1] - 1:19
JOE [1] - 2:11
JOHN [11] - 24:12, 25:1, 25:9, 26:8,
26:18, 27:3, 27:16, 27:20, 28:25,
29:20, 30:2
JOINDER [1] - 17:22
JOINED [1] - 2:9
JOINT [1] - 18:3
JOINTLY [1] - 17:13
JUDGE [7] - 13:14, 14:8, 22:9, 26:15,
29:13, 29:15, 41:10
JUDGE [1] - 1:10
JUDGE [11] - 2:18, 23:12, 23:15, 26:19,
27:8, 28:11, 29:22, 29:25, 30:7, 43:5,
43:20
JUDICIAL [2] - 17:20, 22:22
JUNE [2] - 25:1, 27:22
5
JUROR [1] - 40:13
JURORS [5] - 20:8, 20:9, 20:10, 26:17,
40:12
JURY [1] - 1:9
JURY [15] - 2:4, 18:9, 18:14, 18:20,
18:21, 19:3, 19:9, 20:8, 22:15, 22:16,
22:18, 27:11, 27:24, 28:9, 40:18
JURY'S [2] - 13:10, 27:14
JUSTICE [4] - 13:24, 14:11, 18:1, 22:23
K
KAUSHAL [3] - 2:10, 28:22, 42:2
KAUSHAL [4] - 1:13, 28:24, 30:13,
32:24
KIND [1] - 29:24
KNOWLEDGE [3] - 30:18, 41:9, 41:13
KNOWS [1] - 40:13
KUMHO [1] - 16:13
L
LACKS [1] - 17:2
LARGELY [1] - 16:7
LAST [6] - 2:25, 3:1, 11:7, 21:12, 28:2,
35:16
LATE [5] - 14:14, 15:2, 15:12, 16:18,
34:15
LAUNDERING [5] - 25:7, 26:4, 27:18,
27:23
LEARNED [1] - 31:25
LEAST [8] - 13:1, 13:14, 15:19, 15:20,
19:22, 21:7, 22:25, 31:23
LEAVE [1] - 27:11
LEE [2] - 3:5, 3:11
LEIGH [1] - 1:16
LEIGH [1] - 2:14
LENGTH [1] - 21:14
LETTING [1] - 43:23
LEVEL [1] - 31:3
LIGHTENS [1] - 17:19
LIMINE [1] - 23:9
LIMITING [1] - 19:2
LINE [1] - 1:7
LINE [1] - 44:4
LIST [2] - 33:1, 35:12
LOAN [10] - 19:1, 24:21, 25:3, 25:6,
25:24, 25:25, 26:8, 26:9, 26:12, 27:23
LOANS [1] - 18:24
LOCAL [2] - 11:23, 12:8
LOCATE [4] - 20:21, 36:11, 40:1, 40:3
LOCATED [2] - 20:25, 40:2
LOCATION [3] - 14:20, 16:3, 16:4
LOGISTICALLY [1] - 43:22
LOGISTICS [1] - 43:11
LOOK [2] - 28:14, 42:15
LOOKED [2] - 42:12, 42:13
LOOSELY [1] - 29:6
LOPEZ [1] - 17:14
LOSE [2] - 21:1, 34:20
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 51 of 55
LUNCH [5] - 20:7, 20:10, 20:21, 44:10
M
MAILED [2] - 3:17, 23:9
MANAGEMENT [2] - 26:20, 27:19
MANAGEMENT [1] - 20:8
MANNER [1] - 12:15
MARSHAL [1] - 3:12
MARSHALL [6] - 2:18, 24:19, 26:14,
28:2, 31:25, 43:4
MARSHALL [16] - 1:18, 2:18, 22:9, 23:3,
23:5, 23:8, 23:12, 26:15, 28:4, 29:13,
29:15, 35:11, 35:15, 43:5, 43:20, 44:5
MARSHALS [1] - 35:23
MARSHALS [1] - 20:3
MATERIALS [3] - 22:20, 24:19, 24:23
MATTER [4] - 18:9, 23:5, 29:6, 36:8
MAY [2] - 1:3, 1:5
MEAN [2] - 22:14, 22:19
MEANINGFULLY [1] - 15:13
MEET [2] - 12:1, 16:15
MERELY [2] - 18:23, 30:24
METHODS [1] - 16:11
MIDDLE [1] - 16:6
MIGHT [5] - 19:12, 21:13, 23:24, 32:20,
40:3
MIND [1] - 26:23
MINE [1] - 22:11
MINIMIZING [1] - 14:1
MINUTES [2] - 3:1, 40:11
MISTAKE [1] - 41:25
MOMENT [5] - 3:14, 20:17, 36:3, 36:13,
36:17
MONEY [12] - 25:2, 25:7, 26:4, 26:5,
26:11, 27:3, 27:10, 27:13, 27:17,
27:18, 27:23
MONEYS [1] - 26:18
MOORE [1] - 2:10
MOORE [1] - 1:14
MOREOVER [3] - 15:1, 15:15, 18:18
MORNING [13] - 2:8, 2:14, 2:18, 2:21,
19:14, 20:7, 20:11, 22:18, 22:25,
23:19, 40:6, 43:4, 44:14
MOST [1] - 20:14
MOTION [23] - 11:10, 11:11, 11:12,
11:18, 15:24, 17:11, 19:6, 19:7, 19:8,
22:21, 23:8, 24:4, 24:6, 24:9, 24:20,
25:12, 25:14, 25:19, 28:2, 28:14, 43:7,
43:9, 43:18
MOTIONS [1] - 23:20
MOVE [4] - 22:7, 22:16, 29:9, 32:11
MOVEMENT [2] - 26:11, 27:2
MR [20] - 2:18, 2:21, 3:8, 22:9, 23:3,
23:5, 23:8, 23:12, 26:15, 28:4, 28:24,
29:13, 29:15, 30:13, 32:24, 35:11,
35:15, 43:5, 43:20, 44:5
MS [37] - 2:8, 2:14, 20:17, 20:20, 21:10,
21:17, 21:21, 21:23, 22:6, 24:2, 24:7,
24:11, 25:21, 27:9, 28:22, 32:17, 33:2,
33:11, 33:22, 34:10, 34:14, 34:25,
35:9, 35:10, 35:13, 35:16, 35:24, 36:6,
36:10, 36:15, 41:2, 41:7, 41:17, 42:1,
42:9, 42:22, 44:12
MUELLER [1] - 33:19
MUST [6] - 11:23, 11:24, 12:24, 13:6,
18:7, 18:19
N
NAME [3] - 26:24, 27:11, 42:15
NARROW [2] - 24:7, 24:8
NECESSARY [7] - 15:20, 15:21, 16:1,
25:22, 25:23, 31:20, 32:22
NECESSITATES [1] - 16:20
NECESSITY [1] - 31:18
NEED [9] - 14:18, 16:10, 21:4, 26:25,
29:3, 29:7, 35:5, 43:13, 43:14
NEEDED [5] - 14:23, 19:2, 19:13, 20:23,
42:13
NEEDS [2] - 30:10, 32:6
NEGOTIATION [2] - 30:20, 31:9
NEW [1] - 33:13
NICE [1] - 20:9
NIGHT [1] - 35:16
NO [1] - 1:5
NOON [2] - 34:5, 34:9
NORMALLY [1] - 43:16
NORTHERN [2] - 1:1, 45:4
NOT [1] - 1:19
NOTE [2] - 13:22, 42:23
NOTE [1] - 14:6
NOTED [2] - 16:18, 30:24
NOTHING [2] - 34:5, 44:13
NOTICE [2] - 24:13, 28:6
NOTIFIED [1] - 3:2
NOTING [1] - 16:7
NUMBER [2] - 1:6, 1:7
NUMBER [1] - 2:4
NUMBER [1] - 41:18
O
OBJECT [1] - 16:16
OBJECTION [2] - 22:9, 36:13
OBSTRUCTION [3] - 30:1, 30:24
OBVIOUSLY [5] - 19:24, 21:3, 22:14,
23:14, 23:25
OCCUPY [1] - 33:1
OCCUR [1] - 31:22
OCCURRED [2] - 30:15, 31:6
OCCURRING [1] - 30:22
OCCURS [1] - 30:21
OF [11] - 1:2, 1:5, 1:6, 1:1, 1:4, 1:9, 1:12,
1:15, 1:17, 1:19, 45:4
OFF-THE-RECORD [2] - 10:21, 11:2
OFFENSES [1] - 17:22
OFFERED [1] - 14:22
OFFICE [1] - 36:19
OFFICE [1] - 2:11
6
OFFICIAL [6] - 1:2, 1:3, 1:4, 1:8, 1:23,
45:15
ON [4] - 1:12, 1:15, 1:17, 1:19
ONE [15] - 3:1, 3:14, 19:23, 20:17, 23:5,
26:22, 28:24, 30:10, 31:23, 35:15,
40:7, 41:2, 41:9, 42:15, 43:6
ONGOING [2] - 36:7, 36:10
ONLY [2] - 1:3, 1:7
OPEN [1] - 2:2
OPEN [3] - 20:12, 36:1, 39:21
OPENING [3] - 23:15, 23:25, 43:23
OPINIONS [1] - 15:22
OPPORTUNITY [5] - 11:25, 15:8, 17:3,
17:6, 17:9
OPTIMIST [1] - 40:5
OPTION [2] - 20:1, 20:2
OPTIONS [2] - 19:22, 20:6
OR [1] - 1:9
ORDER [12] - 11:9, 11:22, 12:3, 12:6,
12:14, 12:18, 13:1, 13:13, 15:5, 16:20,
17:25, 33:25
ORDERED [1] - 15:6
ORDERS [3] - 11:6, 13:3, 43:6
OTHERWISE [2] - 14:2, 35:2
OWN [2] - 14:24, 18:11
P
PAGE [1] - 1:7
PAGES [1] - 45:6
PARALEGAL [1] - 2:20
PART [7] - 15:11, 20:24, 24:8, 24:18,
26:10, 27:19, 32:11
PARTE [8] - 33:3, 41:4, 41:9, 41:11,
41:18, 41:20, 42:10, 42:17
PARTIAL [1] - 1:9
PARTICULAR [3] - 18:8, 31:11, 32:8
PARTIES [1] - 39:22
PARTIES [1] - 11:13
PARTY [4] - 12:13, 12:14, 12:17, 31:24
PATIENCE [1] - 35:19
PAUSE [1] - 20:19
PAYCHECK [1] - 24:20
PDF [1] - 1:2
PENDING [3] - 29:5, 31:11, 32:5
PENNY [2] - 1:22, 45:15
PERCENT [1] - 34:19
PEREZ [2] - 12:22, 13:19
PERHAPS [5] - 3:21, 22:2, 33:19, 43:22,
44:2
PERIOD [1] - 1:5
PERIOD [1] - 27:22
PERMISSIBLE [1] - 28:12
PERMIT [1] - 12:14
PERSON [1] - 42:11
PERSONNEL [1] - 36:19
PERSUADED [2] - 15:25, 18:21
PETITION [1] - 41:8
PHONE [3] - 16:4, 30:18, 43:10
PHONES [1] - 43:24
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 52 of 55
PHRONT [1] - 25:5
PINPOINT'S [1] - 17:14
PLACE [1] - 12:15
PLANNING [3] - 24:15, 25:14, 35:13
PLEA [5] - 14:1, 30:19, 31:8, 31:14,
31:15
PLED [1] - 24:13
PM [1] - 44:15
POINT [5] - 19:9, 27:21, 29:10, 33:5,
35:5
PORTION [1] - 1:5
POSITION [1] - 43:8
POSSESSED [1] - 14:19
POSSIBILITY [4] - 22:14, 30:20, 30:25,
40:3
POSSIBLE [5] - 20:22, 22:24, 29:25,
31:8, 40:9
POSSIBLY [1] - 43:6
POTENTIAL [7] - 15:3, 19:5, 21:6,
28:25, 31:12, 31:22
POTENTIALLY [1] - 31:1
PPP [1] - 25:3
PRACTICAL [1] - 18:9
PRECEDENT [1] - 44:3
PREFERENCE [1] - 36:6
PREJUDICE [10] - 13:8, 13:10, 14:17,
15:3, 17:24, 18:3, 18:7, 18:13, 18:18,
19:3
PREJUDICIAL [1] - 17:1
PREPARATION [1] - 26:7
PREPARE [4] - 15:22, 17:3, 17:9, 35:6
PREPARED [1] - 24:21
PREPARING [1] - 24:12
PRESCRIBE [1] - 12:16
PRESENCE [1] - 13:12
PRESENT [1] - 1:19
PRESENT [1] - 19:11
PRETRIAL [2] - 12:3, 16:1
PREVIEW [2] - 33:22, 34:18
PREVIOUSLY [1] - 18:25
PRITTY [2] - 1:22, 45:15
PRO [4] - 32:4, 33:10, 33:12, 33:15
PROCEDURE [3] - 11:22, 14:5, 17:21
PROCEEDINGS [1] - 1:9
PROCEEDINGS [9] - 2:2, 3:22, 10:22,
11:3, 20:19, 35:20, 36:20, 44:15, 45:7
PROCEEDS [3] - 25:6, 25:24, 27:23
PRODUCED [2] - 41:4, 41:8
PRODUCTIVE [1] - 28:20
PROFFERED [1] - 14:23
PROGRAM [1] - 24:21
PROHIBIT [1] - 12:17
PROHIBITED [1] - 1:9
PROHIBITED [1] - 13:17
PROMOTE [1] - 13:23
PROMPTING [1] - 13:2
PROPERLY [1] - 16:11
PROPOSED [2] - 19:10, 32:10
PROTECT [1] - 32:9
PROTECTION [1] - 24:20
PROVE [2] - 25:25, 26:3
PROVIDE [4] - 11:25, 12:9, 18:1, 35:25
PROVIDED [4] - 29:16, 35:11, 35:12,
35:16
PROVIDES [1] - 17:22
PROVIDING [2] - 13:24, 35:13
PROVING [1] - 26:9
PURPOSE [1] - 13:22
PURPOSES [2] - 11:18, 12:12
PURSUE [1] - 21:10
PUTS [1] - 27:5
Q
QUESTIONS [1] - 28:17
QUITE [1] - 43:15
QUOTING [3] - 13:19, 14:5, 16:13
R
RAISE [2] - 29:11, 30:22
RAISING [1] - 31:21
RATHER [1] - 14:7
REACH [2] - 3:4, 29:9
READ [5] - 24:4, 24:6, 25:12, 25:19,
32:21
READING [1] - 22:20
READY [2] - 12:5, 35:3
REALLY [4] - 21:1, 31:19, 43:13, 44:9
REASON [2] - 17:7, 44:8
REASONS [2] - 13:7, 22:21
REBUT [1] - 14:23
RECEIVE [1] - 31:1
RECESS [8] - 10:22, 11:3, 13:11, 14:8,
28:20, 35:20, 41:1, 44:15
RECOGNIZE [1] - 11:19
RECOMMENDATION [1] - 22:10
RECONSIDER [1] - 43:18
RECORD [15] - 2:7, 10:20, 10:21, 10:24,
11:1, 11:2, 14:19, 23:21, 25:19, 28:15,
35:22, 36:9, 39:21, 39:24, 41:16
RECORDED [1] - 1:21
RECORDS [2] - 24:25, 28:7
REDACT [2] - 26:23, 27:11
REDUCE [1] - 14:9
REDUCES [1] - 17:17
REFERENCE [2] - 18:24, 26:16
REFERENCING [1] - 1:7
REFLECT [1] - 10:24
RELATE [1] - 41:12
RELATED [5] - 24:20, 24:25, 26:20,
27:18, 28:8
RELATES [1] - 36:7
RELATIONSHIP [1] - 27:15
RELATIVE [1] - 23:18
RELAXING [2] - 43:3, 44:13
RELEASE [1] - 40:22
RELEVANT [4] - 20:14, 24:9, 26:9,
27:14
7
RELIABILITY [3] - 16:3, 16:8, 16:11
RELIEF [2] - 12:21, 18:1
REMAIN [1] - 29:4
REMAINING [1] - 40:7
REMEDIES [2] - 15:20, 18:19
REMEDY [1] - 15:19
REMIND [1] - 32:13
REMOVE [1] - 24:14
REPLY [2] - 15:11, 26:14
REPORT [2] - 35:23, 40:17
REPORTER [4] - 1:4, 1:8, 1:23, 45:15
REPORTER'S [1] - 28:15
REPRESENTED [2] - 14:22, 18:25
REQUEST [3] - 16:17, 41:3, 41:7
REQUESTED [2] - 12:4, 13:16
REQUIRE [2] - 11:22, 19:24
REQUIRED [2] - 13:7, 16:19
REQUIREMENTS [2] - 12:13, 16:16
REQUIRES [3] - 12:3, 16:9, 18:1
REQUIRING [1] - 13:22
RESERVATION [6] - 25:3, 25:4, 25:23,
25:25, 26:7, 26:12
RESOLUTION [1] - 14:9
RESOURCE [2] - 26:20, 27:19
RESOURCES [1] - 17:20
RESPOND [2] - 23:24, 24:2
RESPONSE [4] - 15:11, 17:8, 23:14,
24:6
RESTRICTED [1] - 1:4
RESULT [2] - 13:2, 18:3
RESULTS [1] - 17:2
REVERSAL [1] - 16:20
REVERSED [1] - 16:21
REVIEW [2] - 19:9, 28:14
REVISIT [1] - 43:6
RICKY [3] - 32:1, 41:4, 41:7
RIGHTS [6] - 16:22, 16:23, 29:3, 32:9,
32:22, 33:5
RISK [3] - 17:17, 30:22, 31:8
RMR [2] - 1:22, 45:15
ROAD [1] - 25:17
ROADRUNNER [4] - 24:22, 24:25, 25:5,
28:8
RODRIGUEZ [1] - 16:12
ROUTINE [1] - 16:2
RULE [7] - 11:21, 12:14, 14:5, 15:4,
16:20, 17:21, 18:4
RULE [5] - 11:23, 11:24, 12:2, 17:12,
17:17
RULES [1] - 12:9
RULING [3] - 11:18, 12:12, 28:16
RULINGS [1] - 11:8
RYAN [1] - 2:20
S
SACRIFICING [1] - 14:10
SAMIR [1] - 1:13
SAMIR [1] - 2:9
SANCTION [5] - 12:25, 13:1, 13:15,
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 53 of 55
13:19, 14:15
SARALIENE [1] - 1:16
SARALIENE [1] - 2:16
SCARCE [1] - 17:20
SCHEDULED [2] - 33:24, 34:15
SCHEDULING [2] - 12:3, 12:6
SE [4] - 32:4, 33:10, 33:12, 33:15
SEAL [12] - 3:16, 3:18, 3:22, 23:18,
36:20, 39:23, 41:5, 41:8, 41:19, 41:20,
41:24, 41:25
SECOND [3] - 3:14, 3:15, 21:4
SEE [13] - 2:13, 2:23, 20:2, 22:12, 23:1,
34:17, 35:18, 40:9, 40:23, 42:13, 43:3,
43:9, 44:14
SEEKING [2] - 24:23, 24:24
SELECTION [3] - 22:15, 22:17, 22:18
SENTENCING [3] - 29:5, 30:2, 31:12
SEPARATE [3] - 17:25, 25:7, 27:25
SEPARATELY [1] - 21:16
SEPTEMBER [1] - 16:7
SERIAL [1] - 17:18
SERIES [1] - 26:10
SERIOUS [2] - 30:13, 31:5
SERVE [2] - 16:9, 22:23
SERVICE [1] - 40:24
SERVICE [1] - 3:12
SERVICES [2] - 26:20, 27:19
SET [3] - 2:3, 11:23, 19:25
SETTING [1] - 44:3
SEVER [7] - 11:11, 17:11, 17:25, 19:6,
19:8, 22:22
SEVERAL [4] - 12:25, 20:22, 34:14,
34:20
SEVERANCE [3] - 18:4, 18:19, 22:21
SEVERE [4] - 13:1, 13:15, 15:19, 15:20
SHARED [1] - 24:16
SHORT [1] - 11:13
SHORTENED [1] - 21:18
SHORTER [1] - 20:25
SHOW [6] - 18:13, 18:18, 18:19, 25:1,
26:25, 33:23
SHOWING [1] - 18:13
SHOWS [1] - 27:24
SHRIVASTAVA [1] - 1:20
SHUFFLED [1] - 40:12
SIC [1] - 15:15
SIFT [2] - 18:14, 18:22
SIGNATURE [3] - 26:16, 26:24, 27:11
SIGNED [2] - 10:25, 41:10
SIGNER [6] - 25:8, 25:9, 26:25, 27:1,
27:9, 27:12
SIGNERS [1] - 25:2
SIJI [1] - 2:10
SILENT [1] - 29:4
SIMPLY [1] - 32:8
SITE [4] - 11:16, 14:20, 16:3, 16:8
SLIGHT [1] - 44:7
SMALL [1] - 43:7
SOMEONE [1] - 33:18
SOPHIA [1] - 2:20
SORRY [5] - 32:17, 41:6, 42:2, 43:5,
43:19
SORT [1] - 42:23
SORTED [1] - 24:16
SPECIAL [4] - 2:11, 11:16, 13:17, 15:7
SPECIFIC [1] - 18:3
SPECIFICALLY [1] - 41:3
SPECIFY [1] - 12:15
SPEEDIER [1] - 14:9
SPENT [1] - 40:23
SPOILED [1] - 44:1
SPOKEN [1] - 20:8
STAND [1] - 30:6
STANDBY [2] - 2:22, 19:18
STANDING [1] - 16:20
START [6] - 19:15, 19:23, 20:21, 22:15,
22:18, 28:6
STARTED [3] - 19:14, 23:15
STATEMENTS [3] - 18:12, 23:15, 24:1
STATES [5] - 2:5, 2:9, 16:5, 18:16,
36:18
STATES [6] - 1:1, 1:4, 1:10, 1:14, 1:23,
45:3
STEFAN [1] - 2:11
STENOGRAPHICALLY [1] - 1:21
STEP [2] - 36:2, 36:16
STEPPING [1] - 36:13
STILL [1] - 41:22
STITES [1] - 2:11
STRATEGY [1] - 41:12
STRONG [1] - 22:6
STUFF [1] - 26:23
SUBJECT [1] - 36:8
SUBMISSION [1] - 26:7
SUBSTANCE [1] - 40:1
SUBSTANTIAL [3] - 16:22, 16:23, 17:1
SUFFERED [1] - 13:9
SUFFICIENT [1] - 18:20
SUFFICIENTLY [1] - 11:24
SUGGEST [2] - 26:22, 30:23
SUGGESTION [1] - 30:5
SUM [1] - 40:1
SUMMARIZING [1] - 29:22
SUMMARY [1] - 11:7
SUPPRESSING [1] - 14:7
SURPRISE [2] - 14:1, 17:5
SURPRISED [1] - 17:2
SURROUNDING [1] - 14:13
SWORN [1] - 13:11
T
TABLE [1] - 2:20
TAL [1] - 1:13
TAL [1] - 2:8
TELDRIN [2] - 1:6, 1:15
TELDRIN [1] - 2:15
TEN [1] - 3:1
TERMS [1] - 12:16
8
TESTIFIED [1] - 30:3
TESTIFIES [4] - 30:21, 30:25, 32:3, 33:9
TESTIFY [6] - 11:16, 29:4, 29:18, 31:14,
32:2, 34:1
TESTIFYING [2] - 14:21, 20:23
TESTIMONY [16] - 11:10, 11:12, 12:20,
13:18, 14:18, 14:23, 15:9, 15:14, 16:2,
16:14, 16:15, 20:23, 32:8, 35:6
THE [66] - 1:2, 1:4, 1:6, 1:7, 1:8, 1:10,
1:1, 1:9, 1:12, 1:15, 1:17, 1:19, 2:13,
2:17, 2:23, 3:7, 3:9, 10:24, 11:5,
20:18, 21:9, 21:11, 21:20, 21:22, 22:1,
22:8, 22:12, 23:4, 23:7, 23:11, 23:16,
24:4, 24:8, 25:16, 26:13, 28:1, 28:13,
29:14, 32:12, 32:19, 32:25, 33:10,
33:16, 34:3, 34:11, 34:22, 35:1, 35:18,
35:22, 36:2, 36:8, 36:12, 36:16, 39:23,
41:6, 41:14, 41:22, 42:7, 42:19, 43:2,
43:18, 43:21, 44:6, 44:13
THEREFORE [2] - 3:9, 40:17
THEY'VE [1] - 29:18
THINKING [1] - 30:15
THIRD [2] - 21:13, 26:3
THOMAS [4] - 26:6, 26:18, 27:3, 29:17
THOMAS'S [1] - 25:4
THOUGHTS [2] - 20:13, 22:4
THREAT [2] - 29:24, 29:25
THREATEN [1] - 30:23
THREE [3] - 21:21, 21:24, 40:7
THURSDAY [4] - 15:16, 34:1, 34:13,
34:23
TIRE [1] - 16:13
TO [2] - 1:5, 1:9
TODAY [4] - 2:22, 35:17, 40:15, 42:3
TOGETHER [3] - 17:13, 22:24, 25:2
TOMORROW [5] - 20:7, 22:17, 22:25,
40:6, 40:17
TOSSED [1] - 32:10
TOUCH [1] - 34:17
TOWARDS [1] - 32:11
TRACK [1] - 21:6
TRANSACTIONS [1] - 26:10
TRANSCRIPT [1] - 45:7
TRANSCRIPT [5] - 1:3, 1:6, 1:8, 1:9, 1:9
TRANSCRIPTS [1] - 1:3
TRAVEL [6] - 25:3, 25:4, 25:24, 25:25,
26:8, 26:12
TRIAL [1] - 1:9
TRIAL [37] - 2:4, 2:9, 3:3, 11:5, 11:25,
12:5, 12:14, 13:11, 13:13, 13:18, 14:2,
14:8, 15:8, 15:22, 16:16, 17:23, 18:3,
18:24, 19:15, 19:23, 20:1, 20:4, 20:24,
20:25, 21:4, 21:13, 21:14, 21:18,
21:24, 24:12, 24:23, 24:24, 27:17,
29:9, 40:7, 43:10
TRIALS [4] - 17:19, 17:25, 43:16
TRIED [2] - 17:13, 42:3
TROUBLE [1] - 44:4
TRUE [2] - 17:16, 45:6
TRY [8] - 19:24, 20:21, 21:6, 21:15,
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 54 of 55
21:23, 22:23, 43:9, 44:8
TRYING [4] - 21:22, 27:2, 42:2, 42:4
TURNED [1] - 16:19
TURNER [1] - 13:20
TWO [8] - 14:21, 20:1, 21:12, 21:19,
21:21, 21:23, 26:20, 27:25
TWO-AND-A-HALF [1] - 14:21
TWO-WEEK [1] - 20:1
TYPE [2] - 16:2, 29:16
U
ULTIMATELY [1] - 33:23
UNABLE [2] - 18:14, 18:22
UNDER [18] - 3:16, 3:18, 3:22, 11:24,
12:19, 15:5, 16:19, 18:8, 23:18, 31:1,
36:20, 39:23, 41:5, 41:8, 41:19, 41:20,
41:24, 41:25
UNDERLYING [1] - 14:20
UNDERSTOOD [1] - 29:23
UNDESIRABLE [1] - 14:1
UNDISCLOSED [1] - 12:18
UNDUE [1] - 17:4
UNDULY [1] - 17:2
UNEXPECTED [1] - 2:24
UNEXPECTEDLY [1] - 43:3
UNFAIRLY [1] - 14:17
UNFAIRNESS [1] - 17:18
UNFORTUNATELY [1] - 43:24
UNITED [6] - 1:1, 1:4, 1:10, 1:14, 1:23,
45:3
UNITED [5] - 2:5, 2:9, 16:5, 18:16, 36:18
UNLAWFUL [1] - 26:4
UNLESS [2] - 20:5, 33:13
UNSEALED [2] - 10:20, 39:21
UNTIMELY [2] - 11:17, 12:11
UNWARRANTED [1] - 14:15
UP [10] - 11:6, 11:8, 28:17, 29:12, 32:3,
33:17, 33:23, 34:1, 40:19, 42:20
UPDATED [1] - 35:24
US [10] - 3:12, 12:21, 13:3, 13:19, 13:21,
16:12, 16:13, 17:13, 18:5, 20:3
V
VERDICTS [1] - 17:18
VERGARA [1] - 16:24
VIA [1] - 11:6
VICTIMS [1] - 17:19
VIEW [2] - 25:13, 25:21
VIOLATE [1] - 16:23
VIOLATES [1] - 16:21
VIOLATION [1] - 13:12
VOIR [1] - 40:15
VOLUME [1] - 1:6
VS [1] - 1:5
W
WAIT [8] - 20:2, 20:6, 20:9, 21:5, 22:11,
22:17, 22:25, 34:23
9
WAITED [1] - 19:20
WAITING [3] - 21:1, 21:7, 40:23
WANTS [5] - 19:8, 20:15, 30:12, 31:3,
33:18
WARRANT [3] - 3:10, 10:25, 19:20
WARRANTING [1] - 18:18
WAYS [1] - 43:21
WEBSTER [12] - 1:16, 2:14, 22:6, 32:17,
33:2, 35:9, 36:15, 41:2, 41:7, 41:17,
42:1, 42:22
WEBSTER [2] - 2:15, 35:5
WEDNESDAY [6] - 24:14, 34:2, 34:5,
34:9, 34:16, 35:4
WEEK [4] - 11:7, 15:17, 20:1, 21:13
WEEKS [1] - 21:13
WEIGH [2] - 12:25, 13:6
WEIGHING [3] - 13:13, 13:14, 14:13
WHATNOT [1] - 22:22
WHOLE [1] - 21:4
WIDE [1] - 12:19
WILEY [3] - 29:21, 30:10, 30:11
WILL [1] - 1:4
WIRE [1] - 26:5
WITH [1] - 1:10
WITNESS [10] - 27:17, 30:7, 30:8,
30:23, 31:21, 31:23, 32:1, 33:4, 34:16,
35:12
WITNESS'S [2] - 15:14, 32:8
WITNESSES [8] - 17:19, 20:22, 29:2,
33:24, 34:15, 34:20, 35:14, 35:17
WL [1] - 16:6
WORD [1] - 28:3
WORKABLE [1] - 34:6
WORRIED [1] - 44:3
WORST [1] - 29:25
WORTH [1] - 21:7
WORTHWHILE [2] - 24:6, 40:8
WRIT [5] - 41:4, 41:8, 42:12, 42:13,
42:14
WRITTEN [2] - 23:14, 25:18
Y
Y'ALL [1] - 44:14
YEARS [1] - 14:21
YESTERDAY [1] - 23:8
YOU [2] - 1:5, 1:8
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 55 of 55File and source
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