Court filing
TRANSCRIPT of Jury Trial Proceedings as to Carla Jackson, Teldrin Foster held on… — USA v. Thomas et al (Dkt. 1027)
Summary
A transcript of jury trial proceedings, Volume 4 (PM Session), dated FEBRUARY 8, 2024, Document 1027, stamped Filed 06/14/24, in United States of America v. Carla Jackson and Teldrin Foster, Docket No. 1:20-CR-00296-JPB, in the United States District Court for the Northern District of Georgia, Atlanta Division, before the Honorable J.P. Boulee. The index lists continued direct examination of Joseph Stites, direct examination of Salvatore Hazel, and cross-examination of Stites by Mr. Marshall and Ms. Webster. The text shown covers the start of the afternoon session and Agent Stites's direct testimony about a PPP loan involving Infinite Education Services, including emails and Form 941 attachments identified as Government Exhibits.
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
Record facts
| Court | U.S. District Court for the Northern District of Georgia |
|---|---|
| Filed | 2024-06-14 |
Cite this document
“TRANSCRIPT of Jury Trial Proceedings as to Carla Jackson, Teldrin Foster held on… — USA v. Thomas et al (Dkt. 1027).”
U.S. District Court for the Northern District of Georgia, No. 1:20-cr-00296-JPB-CMS, Doc. 1027, 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-292218-1027-0-doc-1027/
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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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 4 (PM SESSION)
CARLA JACKSON AND
)
TELDRIN FOSTER,
)
)
DEFENDANTS.
)
TRANSCRIPT OF JURY TRIAL PROCEEDINGS
BEFORE THE HONORABLE J.P. BOULEE
UNITED STATES DISTRICT JUDGE
FEBRUARY 8, 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.
STENOGRAPHICALLY RECORDED BY:
PENNY PRITTY COUDRIET, RMR, CRR
OFFICIAL COURT REPORTER
UNITED STATES DISTRICT COURT
ATLANTA, GEORGIA
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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I N D E X
WITNESS:
PAGE:
1. JOSEPH STITES
DIRECT EXAMINATION (CONT'D)................163
2. SALVATORE HAZEL
DIRECT EXAMINATION.........................209
3. JOSEPH STITES (RESUMED)
CROSS-EXAMINATION (MARSHALL)...............215
CROSS-EXAMINATION (WEBSTER)................237
- - - - -
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(PROCEEDINGS HELD IN OPEN COURT AT 1:44 PM, ATLANTA, GEORGIA)
THE COURT: Y'all can be seated. Let's bring out the
jury.
MS. CHAIKEN: Your Honor?
THE COURT: One moment.
Yes.
MS. CHAIKEN: We have another witness whose testimony
we anticipate being brief who has a scheduling conflict. His
flight is leaving tomorrow morning at 11:45 a.m. We've
discussed with defense counsel putting him up after Agent
Stites's direct and before his cross, if the Court is amenable
to that.
Everybody consents?
MR. MARSHALL: Yes, Judge.
MS. WEBSTER: Yes.
THE COURT: Yeah, that's fine.
MS. CHAIKEN: He's on his way. We've asked him to
come as soon as he can to the courthouse.
THE COURT: No problem.
(The jury entered the courtroom at 1:45 p.m.)
THE COURT: Off the record.
(Off-the-record discussion.)
THE COURT: Y'all can be seated. Thank you.
Ladies and gentlemen of the jury, I hope you had a
wonderful lunch and that you're enjoying our delightful
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federal courthouse cafeteria as much as I do.
All right. Ms. Chaiken, you have the floor.
MS. CHAIKEN: Thank you, Your Honor.
DIRECT EXAMINATION
BY MS. CHAIKEN:
Q.
All right. Agent Stites, we are going to move on to
talking about Infinite Education Services, okay?
A.
Okay.
Q.
Is that another one of the PPP loans involved in your
investigation?
A.
It is.
MS. CHAIKEN: Could you please publish Government
Exhibit 2431.
BY MS. CHAIKEN:
Q.
What's 2431?
A.
This is an e-mail from Teldrin Foster iCloud account to
Darrell Thomas on April 27, 2020, at 3:29 p.m. And it's a
forward of a message from Teldrin Foster Yahoo! account to
Teldrin Foster iCloud account. The subject is Infinite.
MS. CHAIKEN: And could you please publish 2431C and
D side by side.
BY MS. CHAIKEN:
Q.
Are these 941s that were attached to Mr. Foster's e-mail?
A.
Yes.
Q.
And then are these 941s stamped?
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A.
No, they're not.
Q.
Do they include the same numbers that we looked at
earlier for all of the businesses that submitted identical
forms?
A.
Yes.
MS. CHAIKEN: Could you please publish 2413A and
2431B side by side.
BY MS. CHAIKEN:
Q.
Is 2431B a 940 that Teldrin Foster sent to Darrell
Thomas?
A.
Yes.
Q.
And is 2413A a 940 that was prepared for Bellator Phront
Group?
A.
Yes, it is.
Q.
And are the numbers on those documents identical?
A.
They're identical.
Q.
Was anything changed?
A.
Just the information changed to Infinite Education
Services and the EIN number and then the address information
for Infinite Education Services.
MS. CHAIKEN: If you could please publish Government
Exhibit 2436. And if you could pull that out, please. Thank
you.
BY MS. CHAIKEN:
Q.
What's Government Exhibit 2436?
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A.
It's an e-mail from Teldrin Foster iCloud account to
Darrell Thomas on April 28th, 2020, at 1:13 a.m. It's a
forward of a message from Utwuan Cooper to Teldrin Foster
iCloud account.
Q.
And, again, did you speak to Teldrin Foster about Utwuan
Cooper in your interview?
A.
Yes.
Q.
And does Teldrin Foster know Utwuan Cooper?
A.
He does.
MS. CHAIKEN: And if you could scroll down.
BY MS. CHAIKEN:
Q.
Was there an attachment embedded within the e-mail?
A.
Yes.
Q.
And what was that?
A.
It's a Form 941 for 2020, first quarter for Infinite
Education Services, Inc. It shows 66 employees. And the
wages were 959,946.42. And it does have stamps on it.
Q.
And what quarter did you say this was for?
A.
The first quarter.
Q.
Of 2020?
A.
Of 2020.
Q.
Okay. So it ended in March of 2020?
A.
Yes.
Q.
What was the date of the stamp on the form?
A.
It says April 22nd of 2019.
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Q.
So is it stamped as being received before the quarter
even ended?
A.
Yes.
MS. CHAIKEN: If you could please publish 2318 and
2318A side by side. And if you could pull out that second
message, please, Ms. Holland.
BY MS. CHAIKEN:
Q.
Was this a document that Darrell Thomas sent to Teldrin
Foster on May 5th of 2020?
A.
Yes.
Q.
What was the document?
A.
It is a document from Internal Revenue Service to
Infinite Education Services, Inc., a letter thanking them for
the inquiry on March 29th, 2017, and providing an EIN number.
MS. CHAIKEN: If you could please go to 2445 and
2445G.
BY MS. CHAIKEN:
Q.
Is this the same e-mail we've looked at with the
identical payroll spreadsheets for various businesses?
A.
Yes.
Q.
Was there a spreadsheet for Infinite Education?
A.
Yes.
Q.
Again, was this that spreadsheet that used the template
that was created by Gena Pyfrom-Foster for Bellator?
A.
Yes.
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MS. CHAIKEN: Could you please publish 2332, page 2.
BY MS. CHAIKEN:
Q.
And could you please just read the conversation to the
jury.
A.
So Darrell Thomas says, Resend Infinite 941 forms.
And Teldrin Foster replied, SMH, or shaking my head.
Q.
And what was the date of those messages?
A.
6/16/2020.
Q.
At this point in time had Darrell Thomas already begun
communicating directly with Gena Pyfrom-Foster via WhatsApp?
A.
Yes.
Q.
And who did Darrell Thomas send this WhatsApp message to
when he wanted the Infinite 941 forms to be re-sent?
A.
To Teldrin Foster.
MS. CHAIKEN: Could you please publish 2513.
BY MS. CHAIKEN:
Q.
And tell me what that exhibit is?
A.
It's an e-mail from Teldrin Foster Yahoo account to
Darrell Thomas on June 25th, 2020, at 12:58 a.m.
Q.
And what did that e-mail attach?
A.
It attached payroll reports for Infinite Education
Services, 941s for 2019 and a -- let's see. That's it.
MS. CHAIKEN: Could you please publish 2513C.
BY MS. CHAIKEN:
Q.
Is this the payroll spreadsheet that was sent by Teldrin
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Foster at Yahoo?
A.
Yes.
Q.
Did it change the amount of the payroll from the
spreadsheet that had previously been sent by Teldrin Foster at
iCloud?
A.
Yes.
Q.
Did it change the names?
A.
Yes.
Q.
And did this happen in June after Gena Pyfrom-Foster
started communicating directly with Darrell Thomas via
WhatsApp?
A.
Yes.
MS. CHAIKEN: Could you please publish 2513F.
BY MS. CHAIKEN:
Q.
Is this one of the Form 941s that the Yahoo account sent?
A.
Yes, it is.
Q.
And are the numbers on this 941 different from the
numbers that teldrinfoster@icloud had previously sent?
A.
Yes.
Q.
Was this document stamped?
A.
No.
MS. CHAIKEN: Could you go to 2474, please.
I'm sorry, before we get to 2474.
Your Honor, I'm going to --
Can you go back to 2513 real quick, please.
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Okay. I'm going to move to admit 2348, which was
previously authenticated by Candace Hunter.
MS. WEBSTER: No objection.
THE COURT: Mr. Marshall?
MR. MARSHALL: Yes, Judge, I'm pulling it up.
Okay. No objection.
THE COURT: It's admitted.
MS. CHAIKEN: Thank you.
Ms. Holland, could you please publish 2348.
BY MS. CHAIKEN:
Q.
Is this a WhatsApp message from Darrell Thomas to Gena
Pyfrom-Foster?
A.
Yes.
Q.
Okay. And what did Darrell Thomas say in the first
message?
A.
Good morning. Sounds great.
Q.
What's the date of these messages?
A.
6/25 of 2020.
Q.
Is that the same date that the Yahoo account sent the
Infinite Education documents?
A.
Yes.
Q.
And what did Gena Pyfrom-Foster say?
A.
Okay. Did you get the three from yesterday?
Q.
What did Darrell Thomas say?
A.
Yeah, just waiting on him to knock the stamps out.
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MS. CHAIKEN: Could you pull that message out,
please, Ms. Holland.
BY MS. CHAIKEN:
Q.
He said, Yeah, just waiting on him to knock the stamps
out?
A.
Yes.
MS. CHAIKEN: If you could please publish 2474.
BY MS. CHAIKEN:
Q.
What's 2474?
A.
It's an e-mail message from Teldrin Foster iCloud account
to Darrell Thomas on June 26th, 2020, at 1:40 a.m.
Q.
Is that late at night after the messages we just looked
at?
A.
Yes.
Q.
Did this e-mail come from the iCloud account?
A.
It did.
MS. CHAIKEN: And if you could please publish 2474A
and B.
BY MS. CHAIKEN:
Q.
Were these two of the attachments that were included in
that e-mail from the iCloud account?
A.
Yes.
Q.
And were they Form 941s for Infinite Education Services?
A.
Yes.
Q.
Did these have stamps on them?
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A.
They do.
Q.
So did this loan follow the same pattern where the iCloud
account sent identical documents, then the Yahoo account
changed those documents and the iCloud account stamped them?
A.
Yes.
Q.
Okay. Let's move on to Advertising and Then Some. Is
that the name of a business that was involved in your
investigation?
A.
Yes.
MS. CHAIKEN: Could you please publish 2441.
BY MS. CHAIKEN:
Q.
What's 2441?
A.
It's an e-mail from Teldrin Foster iCloud account to
Darrell Thomas on May 6th, 2020, 11:12 p.m. And its subject
is Advertising.
MS. CHAIKEN: If you could please publish 2441A and B
side by side.
BY MS. CHAIKEN:
Q.
Were these two of the attachments that were included in
the e-mail?
A.
Yes.
Q.
What were those attachments?
A.
Form 941s for 2019, quarter 3 and quarter 4, for
Advertising and Then Some, Inc.
Q.
Did these forms have the same numbers as the set of
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numbers we've looked at earlier?
A.
Yes.
MS. CHAIKEN: If you could go to 2447, please.
BY MS. CHAIKEN:
Q.
What's 2447?
A.
It's an e-mail from Teldrin Foster iCloud to Darrell
Thomas on May 8th, 2020, at 12:51 a.m. And the subject is
Advertising and Then Some.
MS. CHAIKEN: If you could please put 2447A side by
side with 2445D.
BY MS. CHAIKEN:
Q.
Is 2447 the payroll spreadsheet that was attached to the
iCloud e-mail for Advertising and Then Some?
A.
Yes.
Q.
And is 2445D the payroll spreadsheet we looked at earlier
for Gaines Reservation & Travel?
A.
It is.
Q.
Are they the same or different?
A.
They are the same except for the company name.
Q.
And the -- are the employee names different as well?
A.
And the employee names, yes.
MS. CHAIKEN: Could you please publish 2322.
BY MS. CHAIKEN:
Q.
Is this a series of messages from Darrell Thomas to
Teldrin Foster on May 12th of 2020?
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A.
Yes, it is.
Q.
And looking at the page, what did Darrell Thomas send to
Teldrin Foster?
A.
Sending a business name, a QuickBooks login, letter of
incorporation, EIN, DL front and back, voided check, business
card, utility bill. It's a listing of things that were going
to be needed for the businesses.
Q.
And looking down below, is there additional information
listed for more businesses?
A.
Yes.
MS. CHAIKEN: And if you could scroll down,
Ms. Holland.
BY MS. CHAIKEN:
Q.
Was there a long list of businesses?
A.
Yes.
Q.
Do you see Continuing Success on there in the middle?
A.
Yes.
Q.
Is that one of the businesses we've talked about?
A.
Yes.
MS. CHAIKEN: Okay. And if you could go up a little
bit. Right there.
BY MS. CHAIKEN:
Q.
Do you see Advertising and Then Some?
A.
Yes, I do. Right at the bottom of the -- where the
government exhibit sticker is.
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MS. CHAIKEN: If you could go to 2512, please.
BY MS. CHAIKEN:
Q.
What's 2512?
A.
It's an e-mail from Teldrin Foster Yahoo account to
Darrell Thomas on June 15, 2020, at 9:20 p.m. And the subject
is Advertising and Then Some.
Q.
And what did that e-mail attach?
A.
Several 941s for 2019 and the first quarter of 2020. And
then payroll reports for 2019 and 2020.
MS. CHAIKEN: And if you could go to 2512D and 2512E.
BY MS. CHAIKEN:
Q.
Are these two of the attachments that were attached to
the Yahoo e-mail?
A.
Yes.
Q.
And did these -- did these numbers in these documents
change from what Teldrin at iCloud had previously sent?
A.
Yes.
Q.
Was the 941 form stamped?
A.
No.
MS. CHAIKEN: If you could please go to 2472.
BY MS. CHAIKEN:
Q.
What's 2472?
A.
It's an e-mail from Teldrin Foster iCloud to Darrell
Thomas, June 16th, 2020, at 5:37 a.m. And the subject is
Some, Inc.
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Q.
Is this the day -- is this sent after the Yahoo e-mail?
A.
Yes.
MS. CHAIKEN: Could you please publish 2472A and
2472B.
BY MS. CHAIKEN:
Q.
Were these two of the forms that were attached to the
iCloud e-mail to Darrell Thomas?
A.
Yes.
Q.
And were these forms stamped?
A.
Yes, they were.
MS. CHAIKEN: Ms. Holland, if you could blow up the
first half -- the top half of 2472B.
BY MS. CHAIKEN:
Q.
What quarter was this 941 for?
A.
What -- say it again.
Q.
I'm sorry. What quarter was it for?
A.
Quarter. The fourth quarter.
Q.
Which months are those?
A.
October, November, December.
Q.
So when did the fourth quarter of 2019 end?
A.
December 31st.
Q.
Of 2019?
A.
2019.
Q.
And do you see the stamp there in the middle of the page?
A.
I do.
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Q.
And what date is listed on that stamp?
A.
10/21/2019.
Q.
Is it stamped as if it was received before the quarter
ended?
A.
Yes.
MS. CHAIKEN: If you could please go to 2336. And if
you could blow up that green message, please, Ms. Holland.
BY MS. CHAIKEN:
Q.
Did Darrell Thomas message anybody about the mistake in
the stamp?
A.
Yes.
Q.
Who did he message?
A.
Teldrin Foster.
Q.
And what did he say?
A.
And fourth quarter Advertising you have to put the 2020
stamp on it.
Q.
At this point in time was Darrell Thomas already
communicating via WhatsApp with Gena Pyfrom-Foster?
A.
Yes.
Q.
If he wanted Gena Pyfrom-Foster to fix the stamp, could
he have messaged her?
A.
Yes.
Q.
What was the date and time of this e-mail?
A.
It would be 6/27/2020. And if you take it back the four
hours, then it would have been 6/26/2020.
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Q.
Okay. So June 26th, 2020, at about 8:05?
A.
8:05.
MS. CHAIKEN: Okay. If you could please publish 2477
and 2477A.
BY MS. CHAIKEN:
Q.
What's 2477?
A.
It's an e-mail from Teldrin Foster iCloud account to
Darrell Thomas on June 27th, 2020, at 1:25 a.m. Subject is
Advertising.
Q.
And is that a few hours after the WhatsApp message we
just looked at?
A.
Yes.
Q.
What was the attachment?
A.
The Form 941 for 2019 fourth quarter for Advertising and
Then Some, with a corrected stamp.
Q.
Okay. So the stamp now is a 2020 date?
A.
Now the stamp's at 2020. It's January 24th, 2020.
Q.
Okay. So Darrell Thomas WhatsApped Teldrin Foster to say
you need a 2020 stamp. And then the iCloud account sent a
Form 941 with a 2020 stamp?
A.
Yes.
Q.
Let's talk about D. Parker Holdings. Is that another
business that was involved in your investigation?
A.
Yes.
MS. CHAIKEN: Could you please publish 2322, page 2.
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BY MS. CHAIKEN:
Q.
Is this the list of businesses we were looking at before?
A.
Yes.
Q.
Was D. Parker on that list down towards the bottom?
A.
Yes. Yes. Right -- kind of a little bit lower than the
middle.
Q.
Did Darrell Thomas send the list of various documents?
A.
Yes.
MS. CHAIKEN: Could you please publish 2324 and
2324A.
BY MS. CHAIKEN:
Q.
Did Darrell Thomas send Teldrin Foster an image on the
late night of May 16th, 2020?
A.
Yes, he did.
Q.
What was that image?
A.
An image that had a business name of D. Parker Holdings
with the address for D. Parker Holdings, a contact name of
Derek Parker, a phone number for Derek Parker, or for the D.
Parker Holdings, and then the EIN.
MS. CHAIKEN: Could you please go to 2464.
BY MS. CHAIKEN:
Q.
Is this an e-mail from the iCloud account to Darrell
Thomas?
A.
Yes.
Q.
And is it sent on May 17th, 2020, at 3:24 a.m.?
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A.
It is.
Q.
Was that shortly after the WhatsApp message we just
looked at?
A.
Yes.
MS. CHAIKEN: If you could go to 2464B and C, please.
BY MS. CHAIKEN:
Q.
What were the attachments?
A.
Form 941s for 2019, the fourth quarter and the third
quarter, for D. Parker Holdings.
Q.
And did these 941s have the same numbers as forms we've
been looking at?
A.
Yes, these are the ones that are exactly the same.
MS. CHAIKEN: Could you please go to 2329 and 2329A.
BY MS. CHAIKEN:
Q.
Down at the bottom, the bottom message on the right, did
Darrell Thomas send Teldrin Foster a document?
A.
Yes.
Q.
What was that document?
A.
A Bank of America bank statement for D. Parker Holdings
for the month of February 2020, with an account number ending
in 1920.
Q.
Did you get bank records for this bank account?
A.
Yes.
Q.
Was this a real bank statement?
A.
No.
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Q.
And in your review of the WhatsApp messages between
Darrell Thomas and Teldrin Foster, did you see anything that
would explain why they were exchanging documents related to
all these businesses other than PPP program?
A.
No.
MS. CHAIKEN: Could you go to 2467, please.
BY MS. CHAIKEN:
Q.
What's 2467?
A.
It's an e-mail from Teldrin Foster iCloud account to
Darrell Thomas on June 4th, 2020, at 12:55 a.m.
Q.
Okay. And is this just about one day before Gena
Pyfrom-Foster and Darrell Thomas started communicating via
WhatsApp?
A.
Yes.
MS. CHAIKEN: Could you do 2445D side by side with
2467A, please.
BY MS. CHAIKEN:
Q.
Is 2467A what Teldrin at iCloud sent to Darrell Thomas on
June 4th?
A.
Yes.
Q.
And is 2445D the payroll spreadsheet we looked at before
for Gaines Reservation & Travel?
A.
Yes.
Q.
Are the numbers the same?
A.
Numbers are the same.
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Q.
Are the names the same?
A.
The names are different.
Q.
And is the business name the same?
A.
The business name is different.
Q.
Okay. So used the same numbers, different names?
A.
Yes.
MS. CHAIKEN: Could you go to 2508, please.
BY MS. CHAIKEN:
Q.
What's the date of this e-mail?
A.
June 8th, 2020, at 7:39 p.m.
Q.
And who is it from and to?
A.
teldrin_foster@yahoo to Darrell Thomas. And the subject
is D. Parker Holdings, Inc.
Q.
And is this document -- is this e-mail about four days
after the e-mail we just looked at from the iCloud account?
A.
Yes.
Q.
And is this e-mail after Gena Pyfrom-Foster started
communicating with Darrell Thomas via WhatsApp?
A.
Yes.
MS. CHAIKEN: Could you go to 2508H side by side with
2467A, please.
BY MS. CHAIKEN:
Q.
Is 2467A on the right the payroll spreadsheet that the
Teldrin iCloud account sent to Darrell Thomas?
A.
Yes.
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Q.
And is 2508H on the left the payroll document that
Teldrin at Yahoo sent to Darrell Thomas?
A.
Yes.
Q.
Did the numbers change in them?
A.
Yes.
Q.
Did the names change?
A.
Yes.
Q.
Is this the same pattern where the iCloud account
prepared the documents and then the Yahoo account came in and
changed them?
A.
Yes.
Q.
Let's go to ML Exotic Customs.
MS. CHAIKEN: Could you publish 2511, please.
BY MS. CHAIKEN:
Q.
What's Government Exhibit 2511?
A.
It's an e-mail from Teldrin Foster Yahoo account to
Darrell Thomas on June 14th, 2020, at 8:02 p.m. And the
subject is ML Exotic Customs.
Q.
And this was after Darrell Thomas and Gena Pyfrom-Foster
were in communication?
A.
Yes.
MS. CHAIKEN: If you could go to 2511E, please.
BY MS. CHAIKEN:
Q.
Was this one of the attachments to the Yahoo e-mail?
A.
Yes.
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Q.
And was it a 941 for 2019?
A.
Yes, it is.
Q.
Was it stamped?
A.
No.
MS. CHAIKEN: If you could go back to 2511.
BY MS. CHAIKEN:
Q.
What was the date on that e-mail?
A.
June 14th, 2020, at 8:02 p.m.
MS. CHAIKEN: If you could go to 2332, please. And
if you could pull out the big green message, please.
BY MS. CHAIKEN:
Q.
What did Darrell Thomas text to Teldrin Foster on the
late night of June 15th, 2020?
A.
What's the ETA on ML Customs?
Q.
Okay. And was that about 8:28 p.m. June 15th?
A.
Approximately, yes.
MS. CHAIKEN: Could you please publish 2471.
BY MS. CHAIKEN:
Q.
And what's 2471?
A.
An e-mail from Teldrin Foster iCloud to Darrell Thomas on
June 16th, 2020, at 4:14 a.m. Subject is ML Exotic Custom.
Q.
Was that a few hours after the WhatsApp message we just
saw?
A.
Yes.
MS. CHAIKEN: And if you could please publish 2471A
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and B.
BY MS. CHAIKEN:
Q.
Were these the attachments to the e-mail from the iCloud
account?
A.
Yes, they are.
Q.
And this time were the Form 941s stamped?
A.
Yes, they were.
Q.
So the Yahoo account sent the 941s -- Darrell Thomas sent
a message on WhatsApp to Teldrin Foster and then the iCloud
account sent the stamped documents?
A.
That's correct.
Q.
All right. Is another loan involved in your
investigation Bellevie?
A.
Yes.
MS. CHAIKEN: Could you please publish 2333 and
2333A. If you could pull out that message at the top right
corner, please.
BY MS. CHAIKEN:
Q.
What did Darrell Thomas send to Teldrin Foster on
June 23rd, 2020?
A.
A Paycheck Protection Program borrowing application for
Bellevie Corp.
Q.
And at this point in time on June 23rd, 2020, was Darrell
Thomas already in direct communication via WhatsApp with Gena
Pyfrom-Foster?
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A.
Yes.
Q.
Could he have sent this to her?
A.
He could have.
MS. CHAIKEN: Could you please go to 2514.
BY MS. CHAIKEN:
Q.
What was 2514?
A.
It's an e-mail from teldrin_foster@yahoo to Darrell
Thomas on June 26th, 2020, at 12:08 a.m.
Q.
And did it attach payroll spreadsheets and 941s for
Bellevie?
A.
Yes.
MS. CHAIKEN: If you could publish 2514G, please.
BY MS. CHAIKEN:
Q.
Is this one of the 941s that was attached to the e-mail?
A.
Yes.
Q.
Were the 941 forms stamped?
A.
No.
MS. CHAIKEN: Could you go to 2475, please.
BY MS. CHAIKEN:
Q.
What's 2475?
A.
An e-mail from Teldrin Foster iCloud account to Darrell
Thomas on June 26th, 2020, at 7:38 a.m.
MS. CHAIKEN: If you could please publish 2475A and
B. And if you could scroll down on 2475A, please.
BY MS. CHAIKEN:
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Q.
Were these two of the attachments to the iCloud e-mail?
A.
Yes.
Q.
And were they 941 forms?
A.
Yes.
Q.
Were they stamped?
A.
Yes.
Q.
Did this loan follow the same pattern where the Yahoo
account sent the documents and then the iCloud account stamped
them?
A.
Yes.
Q.
Finally let's talk about Mickies Auto and Tire. Is that
another loan that was involved in your investigation?
A.
Yes.
MS. CHAIKEN: Could you please publish 2516.
BY MS. CHAIKEN:
Q.
What is 2516?
A.
It's an e-mail from teldrin_foster@yahoo account to
Darrell Thomas. And the subject is Mickies Auto and Tire,
LLC.
Q.
Did it attach payroll spreadsheets and 941s?
A.
Yes.
MS. CHAIKEN: Could you go to 2516E, please.
BY MS. CHAIKEN:
Q.
Is this one of the 941s that was attached to the e-mail?
A.
Yes.
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Q.
Was it stamped?
A.
No.
MS. CHAIKEN: Could you go to 2479, please.
BY MS. CHAIKEN:
Q.
What's 2479?
A.
That's an e-mail from Teldrin Foster iCloud account to
Darrell Thomas on June 30th, 2020, 11:11 p.m. And the subject
is Mickies.
MS. CHAIKEN: And if you could go to 2479A and B,
please.
BY MS. CHAIKEN:
Q.
Were these two of the attachments to the iCloud e-mail?
A.
Yes.
Q.
Were they Form 941s?
A.
Yes.
Q.
And were these copies of the 941s stamped?
A.
Yes, they were.
Q.
Of the 14 businesses that we've just talked about, is
Mickies Auto and Tire the only one that you didn't see
referenced in the WhatsApp communications between Darrell
Thomas and Teldrin Foster?
A.
Yes.
Q.
Did it follow the same pattern where the Yahoo account
sent the documents and then the iCloud account sent the
stamped documents?
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A.
Yes, that's correct.
MS. CHAIKEN: Is 2348 in?
MS. HOLLAND: Yes.
MS. CHAIKEN: Could we please publish 2300, page 388,
side by side with 2348.
BY MS. CHAIKEN:
Q.
On the left side, 2300, page 388, is that a string of
WhatsApps between Darrell Thomas and Teldrin Foster?
A.
Yes.
Q.
And on the right side, is that a string of WhatsApp
messages between Darrell Thomas and Gena Pyfrom-Foster?
A.
Yes.
Q.
Were both of these messages -- message strings on the
same date, June 25th of 2020?
A.
Yes.
Q.
And if Darrell Thomas wanted to be communicating with
Gena Pyfrom-Foster at this time, could he have -- would he
have messaged her?
A.
Yes.
Q.
And if he wanted to communicate with Teldrin Foster,
would he have messaged Teldrin Foster?
A.
Yes.
Q.
When you reviewed the WhatsApp messages between Darrell
Thomas and Teldrin Foster on the one hand and Darrell Thomas
and Gena Pyfrom-Foster on the other hand, did you notice a
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difference in communication styles between them?
A.
Yes.
Q.
Can you describe those?
A.
Gena Pyfrom-Foster's messages with Darrell Thomas are a
little more verbose, you know, full sentences, a lot of
punctuation, capitalization. And even the -- even Darrell
Thomas's responses are a little more, you know, full
sentence-type structure; where the communication between
Mr. Foster and Darrell Thomas is more maybe traditional, sort
of short text messages, shortened words. You know, there's
curse words and stuff in the language, not really punctuating
or creating, you know, full sentences, but just very
shortened, to-the-point sort of messaging.
MS. CHAIKEN: Your Honor, I'm going to move to admit
2350, which was authenticated by Candace Hunter.
MS. WEBSTER: No objection.
MR. MARSHALL: No objection.
THE COURT: It's admitted.
MS. CHAIKEN: Thank you.
Could you publish 2350, please.
BY MS. CHAIKEN:
Q.
Is this a string of text messages between Darrell Thomas
and Gena Pyfrom-Foster?
A.
Yes.
Q.
Okay. And can you just describe what you saw in the
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language that you were using now that -- the language that you
were describing now that you have this exhibit in front of
you?
A.
Yes. Just on -- on Darrell Thomas's message, he's
writing pretty long, you know -- long sentences with
punctuation. And then when you get to the Gena response,
she's responding in longer sentences and clear words, not
shortened words with punctuation.
MS. CHAIKEN: If you could go down to page 2.
BY MS. CHAIKEN:
Q.
Did Darrell Thomas say to Gena Pyfrom-Foster, Yeah, if it
isn't too much trouble --
A.
Yes.
Q.
-- in that message at the top?
A.
Yes.
Q.
Did you ever see him say anything like that when he was
talking to Teldrin Foster?
A.
No.
Q.
Did Darrell Thomas speak differently to Gena
Pyfrom-Foster than to Teldrin Foster?
A.
Yes.
Q.
Based on your review of all the evidence we've looked at
and the e-mails and the messages, did you determine that after
Gena Pyfrom-Foster began communicating directly with Darrell
Thomas via WhatsApp, that Teldrin Foster stayed involved and
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also continued working with Darrell Thomas?
A.
Yes.
Q.
Based on your review of the phone calls, did they
continue talking on the phone every day or nearly every day
during that period?
A.
Yes.
Q.
Based on your review of the WhatsApp messages between
Teldrin Foster and Darrell Thomas, was there anything else the
two of them could have been talking about daily other than the
PPP program?
A.
No.
Q.
In your interview with Teldrin Foster, did he tell you
how much money he got from Darrell Thomas since April of 2020?
A.
Yes. He said between 50 and $60,000.
MS. CHAIKEN: Ms. Holland, could you publish 2250G,
please.
(Government Exhibit 2250G published.)
MS. CHAIKEN: And if you could go to 2879, please.
BY MS. CHAIKEN:
Q.
Is this the check we looked at earlier that Teldrin
Foster got from Bellator Phront Group?
A.
Yes.
Q.
What did the memo line say?
A.
Roswell Road office.
Q.
Did you ever see anything in their conversations about a
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Roswell Road office?
A.
No.
MS. CHAIKEN: Could you go to 2871, page 2, please.
BY MS. CHAIKEN:
Q.
Was this the bank statement for Teldrin Foster that we
looked at earlier?
A.
Yes.
Q.
And do you see the deposit there of the $34,500 check?
A.
I do.
MS. CHAIKEN: If you could scroll down to page 3,
Ms. Holland.
BY MS. CHAIKEN:
Q.
What kind of transactions were in the account after that?
A.
A little bit of cash withdrawal and a lot of Cash App
payments and Zelle payments. A little bit of purchasing.
MS. CHAIKEN: If you could go to 2872, page 2,
please.
BY MS. CHAIKEN:
Q.
Is this the account statement for Teldrin Foster for the
following month, June 11th, 2020, to July 10th of 2020?
A.
Yes.
Q.
And what kinds of transactions were there in the account
that month?
A.
Same sort of thing, purchases at retail stores, Zelle
transfers, some cash withdrawals, Cash App.
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Q.
In your investigation did you get bank records for Gena
Pyfrom-Foster's bank account at Bank of America?
A.
Yes.
MS. CHAIKEN: Your Honor, I'll move to admit
Government's Exhibits 2940 through 2943, pursuant to
Rule 902.11.
MS. WEBSTER: No objection.
MR. MARSHALL: No objection, Judge.
THE COURT: It's admitted. One moment.
MR. MARSHALL: No objection, I'm sorry.
THE COURT: Oh. Ms. Lee is indicating that she had
those admitted yesterday already.
MS. CHAIKEN: Okay.
THE COURT: They're either admitted now or admitted
twice now then.
Ladies and gentlemen of the jury, those are
definitely in.
MS. CHAIKEN: I was not trying to sneak them in, Your
Honor.
THE COURT: I understand.
MS. CHAIKEN: Okay. Could we publish 2943, please.
THE COURT: The record will reflect laughter in the
courtroom. That was all a joke. Nobody was being serious.
BY MS. CHAIKEN:
Q.
Okay. What is 2943?
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THE COURT: The documents are in.
THE WITNESS: It is a check from Bellator Phront
Group to Pyfrom Exclusive Consulting on 6/11/2020 for $10,560.
And the memo line says, Payroll services accounting.
MS. CHAIKEN: Could you please publish Government
Exhibit 2940.
BY MS. CHAIKEN:
Q.
Is this the signature card for the Pyfrom Exclusive
Consulting account?
A.
Yes, it is.
Q.
And whose name was on that account?
A.
Gena Pyfrom-Foster.
Q.
When was that account opened?
A.
June 10th of 2020.
MS. CHAIKEN: Could you please go to 2941, page 3.
BY MS. CHAIKEN:
Q.
Is this the bank statement for that Pyfrom Exclusive
Consulting account starting on June 10th, 2020?
A.
Yes.
Q.
Was the $10,560 check from Bellator deposited into this
account?
A.
Yes, it was.
Q.
What date was it deposited?
A.
6/11 of 2020.
Q.
Was that the day after the account was opened?
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A.
Yes.
MS. CHAIKEN: Could you go to 2942, page 3, please.
BY MS. CHAIKEN:
Q.
Is this the bank statement for that account for July 1st
to July 31st of 2020?
A.
Yes.
Q.
Does it reflect an approximately $9,810 withdrawal from
that account --
A.
Yes.
Q.
-- on July 24th?
A.
Yes.
Q.
Was this money that represented a portion of that $10,560
check?
A.
Yes, for sure.
Q.
Did you ask Teldrin Foster about this payment from
Bellator Phront Group to Pyfrom Exclusive Consulting when you
interviewed him?
A.
I did.
MS. CHAIKEN: Could you please publish Government
Exhibit 2250H.
(Government Exhibit 2250H published.)
MS. CHAIKEN: Your Honor, I previously moved to admit
2250I. I'm going to withdraw 2250I and move to admit 2250W in
its place pursuant to our conversation earlier?
MS. WEBSTER: No objection to that, Your Honor.
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THE COURT: It's admitted.
MS. CHAIKEN: Could you please publish 2250W.
(Government Exhibit 2250W published.)
BY MS. CHAIKEN:
Q.
Did Mr. Foster tell you that the check that was made out
to Pyfrom Exclusive Consulting was actually a check for him?
A.
That's what he said, yes.
Q.
And he told you that he took that money from the account?
A.
Yes.
Q.
Did he tell you that he got the approximately $34,000
check and deposited it in his Navy Federal account?
A.
Yes.
Q.
Is that consistent with what you saw in the Navy Federal
account?
A.
Yes.
MS. CHAIKEN: Could you please publish Government
Exhibit 1146, page 6.
BY MS. CHAIKEN:
Q.
Is this a bank statement for Elite Executive Services,
Inc.?
A.
Yes, it is.
Q.
Is Elite Executive Services the business we talked about
yesterday that got the payroll payment from Gaines Reservation
& Travel?
A.
Yes.
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Q.
And did that business get payroll payments from other of
the businesses that we've been looking at?
A.
Yes, they did.
Q.
On May 22nd of 2020, did Darrell Thomas -- or did Elite
Executive Services make a Cash App payment?
MS. CHAIKEN: If we can pull or highlight that
May 22nd payment.
THE WITNESS: Yes, they made a Cash App payment on
May 22nd, 2020, and it says Teldrin, for 1,380.41.
BY MS. CHAIKEN:
Q.
And I think I actually misspoke. The date that it was
posted was May 22nd?
A.
Yes.
Q.
Is there a different date listed in the description of
the transaction?
A.
5/21. 05/21.
MS. CHAIKEN: Is 2327 in?
Can we please publish 2327 and 2327A. Could you pull
out that top right message, please.
BY MS. CHAIKEN:
Q.
Was this a WhatsApp that Darrell Thomas sent to Teldrin
Foster on May 20th of 2020?
A.
Yes.
Q.
What was the attachment?
A.
It is information regarding a rapid! PayCard program,
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which is a corporate prepaid payroll card company, rapid!.
Q.
Did you determine during the course of your investigation
what rapid! PayCard is?
A.
Yes.
Q.
What is it?
A.
It's a payroll card company that allows companies to set
up an account, deposit funds into the account and then set up
prepaid debit cards for their employees and be able to
transfer money from the main account, the company account, to
those cards for payroll purposes.
Q.
So instead of cutting checks to their employees, they can
load up their employees' debit cards?
A.
Yes.
Q.
Did you get -- and do you see that this document that
Darrell Thomas sent to Teldrin Foster is an agreement between
the Green Dot Corporation doing business as rapid! PayCard and
then Bellator Phront Group?
A.
Yes.
Q.
That's Darrell Thomas's company?
A.
Yes.
Q.
Did you get records from MetaBank for the rapid! PayCard
account that's associated with Bellator?
A.
Yes, we did.
MS. CHAIKEN: Your Honor, I move to admit
Government's Exhibits 2950 through 2954, pursuant to
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Rule 902.11.
MS. WEBSTER: No objection.
MR. MARSHALL: No objection, Judge.
THE COURT: They're admitted.
BY MS. CHAIKEN:
Q.
Based on your review of the MetaBank records, how was
Bellator's rapid! PayCard account used?
A.
It was used to distribute funds to numerous individuals
in different names. Primarily there was a lot of names of
people that were involved in the PPP loans. And they would
distribute the money to the cards. Actually, the funding of
the account came from the various business owners' companies.
Once they got their PPP funding, there were deposits or
transfers made to the Bellator rapid! PayCard account, and
then the money was distributed to the cards.
Q.
Okay. So when we were talking about Gaines Reservation &
Travel, we saw payments to Elite Executive Services for
payroll?
A.
Yes.
Q.
Later on with some of the business applications, the PPP
loan applications that were submitted later, did those
businesses send money to rapid! PayCard for payroll?
A.
Yes.
Q.
And did all of that money go to Bellator's rapid! PayCard
account?
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A.
Yes. It was a single rapid! PayCard account in the name
of Bellator.
Q.
And then were there various cards that were tied to that
account?
A.
Yes.
MS. CHAIKEN: Could you please publish Government
Exhibit 2954 and pull out line 51, please. Scroll down,
please.
BY MS. CHAIKEN:
Q.
Do you see line 51 there?
A.
I do.
Q.
Whose name -- is this a listing of the payroll cards that
were issued by Bellator Phront Group?
A.
Yes, these are the rapid! PayCards.
Q.
And whose name is associated with the PayCard that's on
line number 51?
A.
Teldrin Foster.
Q.
Was there also a card in the name of Gena Foster?
A.
Yes, right below it.
Q.
And the address that's listed there for Teldrin Foster,
is that his real address?
A.
No.
Q.
Do you still have that binder in front of you?
A.
I do.
Q.
Could you please review Government's Exhibits --
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Government Exhibit 3015 and tell me if you recognize it?
A.
3015?
Q.
Yes.
A.
There it is. It's the last one. Yes, I do.
Q.
What do you recognize it as?
A.
This is a listing of all the rapid! PayCard transactions
that were associated with the rapid! PayCard assigned to
Teldrin Foster.
MS. CHAIKEN: I move to admit Government
Exhibit 3015.
MR. MARSHALL: No objection from Ms. Jackson, Judge.
MS. WEBSTER: Can I have one second, Your Honor? I'm
sorry.
No objection.
THE COURT: It's admitted.
MS. CHAIKEN: Could you please publish 3015.
BY MS. CHAIKEN:
Q.
Is this a summary of the transactions on the Teldrin
Foster rapid! PayCard?
A.
Yes.
Q.
And what was the time frame for these transactions?
A.
Started June 2nd of 2020. And then at the bottom is
July 20th of 2020.
Q.
And is the June 2nd of 2020 a transaction on the card?
A.
No. That is just the creation of the card.
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Q.
How much money was spent on the Teldrin Foster payroll
card in July of 2020?
A.
It was approximately -- just a little over $8,000.
Q.
Did the records that you got from T-Mobile for Teldrin
Foster's cell phone that we looked at yesterday, did those
include cell site location information?
A.
Yes.
Q.
Did you ask another agent to analyze those cell site
locations that Teldrin Foster's cell phone hit on the dates of
these transactions?
A.
Yes.
Q.
And who was that agent?
A.
James Berni, Agent James Berni.
Q.
Could you please take a look in your binder at 3005 and
tell me if you recognize it?
A.
Yes.
Q.
What is it?
A.
These are call records between Teldrin Foster and Gena
Pyfrom-Foster.
MS. CHAIKEN: Your Honor, I move to admit
Government's Exhibit --
BY MS. CHAIKEN:
Q.
And are these taken from the T-Mobile records for Teldrin
Foster?
A.
Yes.
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MS. CHAIKEN: Your Honor, I move to admit Government
Exhibit 3005.
MS. WEBSTER: Your Honor, we object to relevance
on -- for at least part of this exhibit. It covers a very
long period of time that doesn't include -- or extends well
past the dates of the charged conspiracies.
THE COURT: Mr. Marshall?
MR. MARSHALL: I have no objection, Judge.
THE COURT: Let me pull it up.
All right. I guess, first off, which dates -- which
date ranges do you object to, what date range? This is a
26-page document.
MS. WEBSTER: Your Honor, we object to any -- to the
inclusion of calls outside of the August 2020 -- I believe
Darrell Thomas was arrested on August 6th, 2020, and we would
object to anything after that date.
THE COURT: All right. So you don't object to
pages 1, 2, and 3, and you object to pages 4 through 26?
MS. WEBSTER: Correct.
THE COURT: Ms. Chaiken?
MS. CHAIKEN: Your Honor, this is relevant to showing
that Teldrin Foster and Gena Pyfrom-Foster each had possession
of their own phone and continued to have possession of their
own phone after the relevant time period.
THE COURT: Well, you closed your argument with
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"after the relevant time period." So what's the relevance of
whether or not they had their own phones after the relevant
time period?
MS. CHAIKEN: Your Honor, the fact that they
continued calling each other on their phones for several
months after this time period that we're looking at is
relevant to the showing that during that time period they
would have each had their own phones and that they each used
their own phones separately, including to call each other.
THE COURT: I kind of feel like we're going in
circles, but why is it relevant after August 6th?
MS. CHAIKEN: Because it shows that Teldrin Foster
continued to have his phone, that this is his phone that he
used before, that he used during this time period, and that he
used after this time period is highly relevant to showing that
this is his phone. If the defense is not going to challenge
that he's the one using the phone, then we don't need to admit
the rest of these pages.
THE COURT: Ms. Webster?
MS. WEBSTER: We're challenging the fact that he was
not the only person with access to his WhatsApp account. So I
don't know -- but even in light of that argument, I'm not sure
what relevance calls after the relevant time period have to
whether or not he had -- he was the person who had access to
his WhatsApp -- the only person who had access to his WhatsApp
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account.
THE COURT: All right. I'll sustain the objection as
to pages 4 through 26.
Ms. Chaiken, I'm not convinced of why you're telling
me what happened after August 6th and who had the phone after
August 6th is -- has any relevance.
Go ahead.
MS. CHAIKEN: Okay. Your Honor, the version we have
in Trial Director has all of the pages, but can we publish it
and not go --
THE COURT: Just publish the first three and make
sure the hard copy document that goes to Ms. Lee just has the
first three, please.
MS. CHAIKEN: Okay.
THE COURT: Thank you.
MS. CHAIKEN: Could you please publish 3005.
BY MS. CHAIKEN:
Q.
Okay. Is this a summary of the communications, phone
calls and texts between Gena Pyfrom-Foster and Teldrin Foster?
A.
Yes.
Q.
And is July 1st, 2020, the earliest date for which you
have this set of records from T-Mobile?
A.
Yes.
Q.
Is July 2020 the time frame for which you've summarized
the transactions in the rapid! PayCard account?
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A.
Yes.
Q.
And that's the same time frame for which you asked the
agent to analyze the cell site location for Teldrin Foster's
phone?
A.
That's correct.
Q.
And during this time frame did Teldrin Foster and Gena
Pyfrom-Foster regularly call each other?
A.
Yes, calls and texts.
MS. CHAIKEN: If you could go down to page 2,
Ms. Holland.
BY MS. CHAIKEN:
Q.
Did they continue communicating regularly throughout July
of 2020?
A.
Yes.
Q.
If Gena Pyfrom-Foster was the one who had Teldrin
Foster's phone during this time period, would you expect there
to be calls between Teldrin Foster and Gena Pyfrom-Foster?
A.
No.
Q.
Did you ask Teldrin Foster about the rapid! PayCard in
your interview?
A.
Yes.
MS. CHAIKEN: Ms. Holland, could you please publish
2250T.
(Government Exhibit 2250T published.)
BY MS. CHAIKEN:
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Q.
Did Mr. Foster tell you that the rapid! PayCard was going
to make it look like there was a paper trail of money going to
people?
A.
Yes.
Q.
And did he tell you that he got a rapid! PayCard from
Darrell Thomas?
A.
Yes, he got a card.
Q.
Did he tell you that he got some money off of it?
A.
He said maybe a thousand dollars.
MS. CHAIKEN: Could you please publish 2250U.
(Government Exhibit 2250U published.)
BY MS. CHAIKEN:
Q.
Did Mr. Foster tell you he knew what they did with
Bellator was wrong?
A.
Yes.
Q.
Did he tell you his motive was to try to get money back
from Darrell if he got a PPP loan?
A.
Yes.
Q.
When you interviewed Teldrin Foster, did he tell you he
knew that what he did with the Bellator loan would have
consequences?
A.
Yes.
MS. CHAIKEN: Could you please publish 2250Q.
(Government Exhibit 2250Q published.)
MS. CHAIKEN: Your Honor, could I have a few moments,
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please?
THE COURT: I'm sorry?
MS. CHAIKEN: Could I have a few moments, please?
THE COURT: Of course.
MS. CHAIKEN: Thank you.
(Pause in proceedings.)
MS. CHAIKEN: Your Honor, I have no further questions
for this witness.
THE COURT: All right. Thank you.
Ladies and gentlemen of the jury, you'll recall this
morning we took one witness out of order, given some
scheduling issues. We've got something else like that now.
Normally what would happen after the government does their
direct examination of someone is that the defense attorneys
would take an opportunity and cross-examine that witness if
they chose to.
What we're going to do here instead is take a break
from Special Agent Stites's testimony and hear from a
different witness entirely. After that witness, we will have
Special Agent Stites back up if there's any cross-examination
of him.
So, sir, you can step down.
(Witness excused from the witness stand.)
THE COURT: And, Counsel, how long will this next
witness last?
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MR. MOORE: Less than 15 minutes, Your Honor.
THE COURT: Okay. Let's go ahead and call him or
her, please.
MR. MOORE: United States calls Salvatore Hazel.
THE COURT: Good afternoon, sir.
THE WITNESS: Good afternoon.
THE COURT: How are you?
THE WITNESS: I'm good. How are you?
THE COURT: I'm well, thank you.
_____________________________
SALVATORE HAZEL
a witness herein, being first duly sworn,
was examined and testified as follows:
____________________________
DIRECT EXAMINATION
BY MR. MOORE:
Q.
Please state and spell your name for the record.
A.
My name is Salvatore Hazel. That's S-A-L-V-A-T-O-R-E.
Hazel, H-A-Z-E-L.
Q.
Where do you work?
A.
I work for the Internal Revenue Service.
Q.
What is your title?
A.
My current title is a court witness coordinator.
Q.
Can you explain what a court witness coordinator does?
A.
Yes, I can. As a court witness coordinator, I represent
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the Commissioner of the Internal Revenue Service as his role
of custodial records. I'm tasked with gathering these
records, certifying and testifying that they are, in fact, in
the possession of the IRS.
Q.
In your time with the IRS have you become familiar with
how taxes are filed?
A.
Yes, I have.
Q.
Are you familiar with the IRS Form 941?
A.
Yes, I am.
Q.
What is that?
A.
That is the quarterly form that's filed by an employer
just for the withholdings taken out of the employees'
paychecks each month.
Q.
So that's filed four times a year?
A.
Yes, it is, each quarter.
Q.
Are you familiar with the IRS Form 940?
A.
Yes, I am.
Q.
What is that?
A.
The Form 940 is an annual form. And that's a form that
the employers file to help fund the federal unemployment tax
system.
Q.
Does the IRS have a recordkeeping system?
A.
Yes, it does.
Q.
Are you familiar with it?
A.
Yes, I am.
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Q.
Do you work in that system in the regular course of your
job?
A.
Yes, I do.
Q.
What is the name of that system?
A.
The name of that system is the Integrated Data Retrieval
System. It's also known as the IDRS system.
Q.
What is stored in the IDRS system?
A.
Most of the taxpayer information. It's considered the
master file that IRS employees like myself have access to to
access information of taxpayers.
Q.
Are those records regularly made and preserved as part of
the public business of the IRS?
A.
Yes, they are.
Q.
Can searches be ran in the IDRS system?
A.
Yes, they can.
Q.
Do you know how to conduct searches in the system?
A.
Generally, most times I do, yes.
Q.
And that's a regular part of your job?
A.
Yes, it is.
Q.
During this investigation, were you asked to check if 940
and 941 forms were filed for certain businesses?
A.
Yes, I was.
Q.
I'm going to list off a series of businesses, and could
you please tell the jury if these are the businesses you
looked for:
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Bellator Phront Group, Arcade Painting, Impact Creations,
Gaines Reservation & Travel, Transportation Management
Services, Lee Operations, D. Parker Holdings, All Star Room
and Board Services of Michigan, Continuing Success, ML Exotic
Customs, Bellevie, Advertising and Then Some, Infinite
Education, Mickies Auto and Tire, Roadrunner Automotive,
Management Resource Services, Technology Analysis System,
Premier Choice Office Supply, and A1 Cuts Barber Shop.
Did you look up 940s and 941s for those companies?
A.
Yes, I did.
Q.
Did any of those companies file a 940 or 941?
A.
There might have been one or two filed for one or two of
the companies. I don't know the exact companies and filings
and so forth right now.
MR. MOORE: Can we publish 2116.
BY MR. MOORE:
Q.
This is a document that had been previously shown to the
jury. Do you know if this document was filed to the IRS?
A.
I do not believe so.
Q.
Does the IRS stamp documents?
A.
They do.
Q.
Does the IRS send the documents back to the individuals
after they are stamped?
A.
They do not.
Q.
So in the typical course of business would a taxpayer
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have a stamped version of their document?
A.
They would not.
MR. MOORE: Can we publish 2116 -- sorry. 2222.
BY MR. MOORE:
Q.
So this is a 941 for a business purportedly called
Bellator Phront Group. Was this document filed with the IRS?
A.
It was not.
Q.
And, again, would you expect the taxpayer to have a
stamped version of the document as this taxpayer supposedly
had?
A.
I would not.
MR. MOORE: Just one moment, Your Honor.
(Pause in proceedings.)
BY MR. MOORE:
Q.
And just to be clear, you had said that they may have
filed a few tax documents, correct, the businesses I listed
off?
A.
There might have been a couple 941s out of all those
companies.
Q.
All right. But when we asked you to look for
specifically 2019 for 941s, were there any 941s filed in the
year 2019 for any of the companies that I listed?
A.
No. Specifically for the tax year 2019, there were no
returns filed.
MR. MOORE: Okay. All right. Thank you. Nothing
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further.
THE WITNESS: You're welcome.
THE COURT: Any cross-examination?
MS. DURRETT: Your Honor, we have no questions for
this witness.
MR. MARSHALL: No questions, Judge.
THE COURT: All right. Sir, you can step down.
Thank you.
THE WITNESS: Thank you, Your Honor.
(Witness excused.)
THE COURT: Probably a decent time for us to take a
short comfort break, all right? Thank you.
MS. WEBSTER: Your Honor.
(After a recess at 3:03 p.m., the proceedings
continued at 3:19 p.m. as follows:)
MS. WEBSTER: Your Honor, assuming it's okay with
you, Mr. Marshall is going to do the first cross-examination
of Agent Stites.
THE COURT: That's fine.
MR. MARSHALL: That's fine, Judge.
THE COURT: Off the record.
(Off-the-record discussion.)
(The jury entered the courtroom at 3:20 p.m.)
THE COURT: All right. You can be seated. Thank
you.
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Mr. Marshall, your witness.
MR. MARSHALL: Thank you.
Ladies and gentlemen.
CROSS-EXAMINATION
BY MR. MARSHALL:
Q.
Good afternoon, Agent Stites.
A.
Good afternoon.
Q.
So I want to do a little bit of overview of your
investigation. I know there's been a lot of evidence put on
the record, but you're just -- your overall view when you do
an investigation for a case like this, you interview the
witnesses that you find important to interview; correct?
A.
Correct.
Q.
And in this case, you also obtained records. And you do
that through subpoenas that get issued?
A.
Yes.
Q.
Search warrants occasionally --
A.
Occasionally.
Q.
-- right?
Did you do that in this case?
A.
A couple. Actually, about -- if you include search
warrants for records, almost ten total --
Q.
For the search warrants you have to go to a -- write out
an affidavit, an application, and present it to a judge and
get approved for a search warrant to be executed; correct?
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A.
Yes.
Q.
Okay. And in this case you've got, I guess, all of
these -- the WhatsApp messages and so forth. Where did -- did
that mostly come out of laptop analysis or what?
A.
The WhatsApp came out of Darrell Thomas's phone.
Q.
So that's one -- that's another thing you did in this
case; right?
A.
We --
Q.
Correct? Okay.
A.
We processed phones, yes, and other devices. We
processed seized phones and other devices.
Q.
This type of investigation, that could mean like cell
phones can be important, correct --
A.
Yes.
Q.
-- in the case?
Desktop computers can be important; correct?
A.
Yes.
Q.
Laptop computers, other digital devices; correct?
A.
Yes.
Q.
And you've done that in this case for at least Darrell
Thomas; right?
A.
Correct.
Q.
Just curious, in this case did you ever try to get any --
either a search warrant or any kind of effort to try to
analyze Ms. Jackson's devices?
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A.
No.
Q.
So you didn't get her cell phone; correct?
A.
No.
Q.
All right. You didn't get any laptops that she's used
during this time period of the investigation; correct?
A.
No.
Q.
Or any desktop computers?
A.
No.
Q.
Would you say that there could be information that might
be important on those devices if you had obtained some
authorizations to get those devices?
A.
I wouldn't know if there is. I guess there could be.
Q.
But you made no effort to get any of those devices;
correct?
A.
No.
Q.
All right. Let's go to the interviews again. You've
interviewed a lot of witnesses in this case; right?
A.
Yes.
Q.
I want to go over a little bit of the technique. You saw
Ms. Jackson on July 7th, 2020; is that correct?
A.
That is correct.
Q.
And you went over there with Agent Cromer. He's another
FBI agent --
A.
Correct.
Q.
-- right?
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I think it was about, what, 9:40 in the morning when you
went over there --
A.
Yes.
Q.
-- right?
Is it normally -- now, at that time you had a grand jury
subpoena in your possession; right?
A.
I did.
Q.
So it was twofold. You had two purposes. You wanted to
go over there, I guess, and question Ms. Jackson, but also you
wanted to serve the subpoena on her; is that right?
A.
Correct.
Q.
All right. Did you know her phone number at that time
before you went over there?
A.
I'm sure we did. We would have done some analysis about
her before showing up.
Q.
Did you think about making an attempt just to call her
before you went over there?
A.
No.
Q.
Is it normally just your best method just to show up and
do these interviews?
A.
It depends. It depends on the situation. Every
investigation, every person we want to interview we think
through, you know, what's the best way to do it. And for
Ms. Jackson, it was -- we thought the best way to do it would
be a knock-and-talk and serve a subpoena.
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Q.
These knock-and-talks, that's a phrase you use. These
knock-and-talks, how many do you think you've done in your
career similar to this type of investigation?
A.
Hundred plus.
Q.
Would you find it -- you're an FBI agent. Would you
agree with the statement that a lot of people are kind of
shocked and surprised when an FBI agent shows up at their
front door?
A.
Some.
Q.
Was Ms. Jackson, in your opinion, in the way she appeared
and answered, did she seem surprised?
A.
She actually seemed pretty comfortable, to be honest.
Q.
You didn't think she wanted to be somewhere else and be
working at the time?
A.
She definitely was working, but she was willing to spend
the time that she spent with us. I think it was like 12 --
12, 13 minutes.
Q.
Okay. I'm going to go over some of the things that y'all
talked about during your interview with her. And we already
had the recording played in court; correct?
A.
Yes.
Q.
Now, I think the government prosecutor asked you a couple
questions about some details that Ms. Jackson didn't provide
to you. For instance, this real estate project in Alabama, do
you remember her talking about that?
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A.
Yes.
Q.
And I think you mentioned that -- I think the prosecutor
asked you if Ms. Jackson provided any documentation similar
to, for instance, the proposal that she mentioned, any
documents related to this real estate project to you as part
of her response to your grand jury subpoena.
Do you remember that?
A.
Correct, yes. I remember that.
Q.
Now, you had just shown up at the front door with the
grand jury subpoena in your hand; right?
A.
Yes.
Q.
So you didn't know about a real estate project that she
had been working on at that time; right?
A.
No.
Q.
So that question for those types of records wouldn't have
been in that grand jury subpoena, in that request for records,
would it?
A.
The grand jury subpoena was directed at any activities
associated with the inflow of the money that was associated
with the money that came in on that --
Q.
Okay. But more specifically -- but in direct response to
my question, there was no question in the grand jury subpoena
requesting records about real estate projects and things like
that; right?
A.
Right.
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Q.
Or a proposal; correct? Any types of things like that,
contracts?
A.
I don't believe so.
Q.
Now, I think you asked (sic) a bunch of questions. I
think you mentioned Andre Gaines; is that right?
A.
Yes.
Q.
At that time you didn't mention John Gaines during that
first interview. Was he on your radar at that point?
A.
We knew about John Gaines at that point.
Q.
Now, this interview, it lasted probably about 13 minutes;
correct?
A.
Correct.
Q.
Or less than that because there was some walking time
before you got up to her; right?
A.
Right.
Q.
Did you have a second interview with Ms. Jackson?
A.
The second interview with Ms. Jackson was when we went to
knock on her front door asking for Mr. Gaines.
Q.
Okay. That's what I was going to ask you about.
So you were going there for the purpose of talking to
Mr. John Gaines; correct?
A.
Correct.
Q.
And do you recall when that second interview was with
Ms. Jackson?
A.
I believe it was on the 27th of July. So it was maybe,
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what, 20 days later.
Q.
Were you with Agent Cromer again for the second
interview?
A.
I was.
Q.
Was he there? Okay.
So do you recall when you -- did you find out whether
Mr. Gaines was there that day?
A.
Ms. Jackson said that Mr. Gaines was not there or she
didn't know where he was, something to the effect. That she
doesn't know -- you know, she's not his babysitter, I think
she used.
Q.
Did you have some reason to believe that John Gaines had
been living there?
A.
We had seen a vehicle that was registered to him that
was, I believe, outside the residence.
Q.
Do you recall finding out that actually Mr. Gaines
occasionally spent time overnight at that residence?
A.
I think we knew that that was a possibility.
Q.
So at least at that point you knew that he probably spent
some time at Ms. Jackson's residence; correct?
A.
Yes.
Q.
Okay. Now, we had previously introduced into evidence I
think Government's Exhibit Number -- I think it was 1700. The
divorce petition.
Do you recall that?
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A.
Yes.
Q.
And I think that there was a separation date at some
point. Do you recall when they might have been separated,
when that petition was filed?
A.
Yeah. It was November something. I don't remember the
exact date, but November of 2019.
Q.
Okay.
A.
Is that correct?
Q.
November 26th, that sound about right? Somewhere around
there?
A.
Yeah.
Q.
Okay. All right. Let me move you over to something
else, a different topic right now.
MR. MARSHALL: Ms. Holland, if you could possibly
bring up Government's Exhibit 1116.
BY MR. MARSHALL:
Q.
Do you recall this exhibit being introduced into
evidence, Agent Stites?
A.
Yes, I do.
Q.
What is this record? If you can tell the jury again
about what this is.
A.
This is a listing of the -- I believe the Wells Fargo --
this is the Wells Fargo bank account transactions or activity
with the addresses and the dates.
Q.
So is there anything important about the IP address in
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this exhibit that you had pointed out during your testimony?
A.
That the IP address had come back to Ms. Jackson's
residence.
Q.
You had established that through a separate request, I
think, through Comcast; right? To find out who --
A.
(Nods head.)
Q.
Okay.
And so the IP address, do you know which one of those
belongs to Ms. Jackson?
A.
It is the 76.105.87.198.
Q.
And over to the right, the second from the -- from the
very right side, those columns, the second column from the
right, I think it says, what is that, SID. Do you know what
that means? Do you have any idea?
A.
I don't know. I just -- I recognized it as a city name
that's in that column. I don't know what SID stands for.
Q.
And it has Stone Mountain down there; is that correct?
For most -- I guess that's the location for all these --
A.
Yes.
Q.
-- IP addresses?
A.
Yes.
Q.
Is there anything here that -- well, you already know
from the other thing that this IP address comes from
Ms. Jackson's residence or not?
A.
Yes.
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Q.
The address?
A.
The IP address comes back to her residence.
Q.
Okay. And are these logins or -- what are these entries
here? If this is interaction with Wells Fargo, what do these
dates on the very left-hand side, what do they signify?
A.
The date that the access -- a date of access.
Q.
And, again, you just answered a couple questions ago from
me a little bit -- and these -- well, let me back up a little
bit.
The dates on the left, are they generally -- what months
are showing there that you can tell?
A.
Those are May and June.
Q.
Primarily May and June, would that be correct?
A.
Yes.
Q.
And that's 2020?
A.
Correct.
Q.
And that's a month or two before you made your visit with
Ms. Jackson; correct?
A.
Correct.
Q.
And you just testified just a little while ago that you
had information that Mr. Gaines was staying at that residence
at least occasionally; correct?
A.
Yes. We figured at least occasionally.
Q.
All right. So at least from this record, especially if
you know that Mr. Gaines might be living at that residence for
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some time, you don't know who specifically accessed the Wells
Fargo account at all from that address at that time, do you?
A.
Correct.
Q.
It could be Mr. Gaines; correct?
A.
Correct.
Q.
Or anybody else there at that location?
A.
Yes.
Q.
I'd like to go over to Government's Exhibit 1150. Turn
over a little bit to -- this is a -- well, we'll get that back
up first.
Do you recognize this exhibit?
A.
Yes, I do.
Q.
This was previously admitted earlier. What is this
exhibit again?
A.
This is the Bank of America signature card for Roadrunner
Automotive Group, LLC.
Q.
Thank you.
MR. MARSHALL: And, Ms. Holland, can you go to the
next page. I think this is a two-page document.
Thank you.
BY MR. MARSHALL:
Q.
Is this another signature card for Bank of America?
A.
That's the original signature card.
Q.
Okay. That's the original one, you say. So down at the
bottom, whose name is there?
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A.
Carla Jackson.
Q.
And there's her signature to the right?
A.
Yes.
Q.
What's the date of this original signature card?
A.
12/30 of 2019.
MR. MARSHALL: Ms. Holland, can you go to the first
page again, please. Thank you.
BY MR. MARSHALL:
Q.
And what's the date of this second signature card?
A.
6/17 of 2020.
Q.
And what's different with this card? Who's added?
A.
John Stacey Gaines.
MR. MARSHALL: Ms. Holland, that's fine with that
one. Could you please go to Government's Exhibit 1151. If
you could go down to the transaction page. I think it's
either page -- that's good right there. Thank you.
If you could -- if you can't see it all right, if you
could maybe pull out the deposit section. Thank you very
much.
BY MR. MARSHALL:
Q.
There was testimony earlier that you provided about some
of these transactions and deposits on this exhibit.
Do you recall that?
A.
Yes.
Q.
And I'm going to refer your attention to the dated
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transaction of June 5th, 2020.
Do you see a deposit amount there?
A.
I do.
Q.
And this is made into a Roadrunner account; right?
A.
Yes.
Q.
And we just saw the signature card for that Roadrunner
account. So we know that Ms. Jackson and Mr. Gaines is
associated with this account; correct?
A.
Mr. Gaines is associated as of 6/17.
Q.
Well, I'm going to ask you about that in a second too.
All right. You don't have any evidence in any e-mails --
let's see.
Do you have any e-mail communications from Ms. Carla
Jackson regarding this deposit that you see here in the amount
of $71,144.35?
A.
Can you restate -- do I have an e-mail?
Q.
Any e-mails in the record that have been presented at
trial that discuss -- where Ms. Jackson is in the e-mail
discussing this deposit?
A.
No.
Q.
As a sender of an e-mail?
A.
No.
Q.
As a recipient of an e-mail?
A.
No.
Q.
Or being copied on an e-mail?
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A.
No.
MR. MARSHALL: Could you also go down to the
transactions below. Thank you. Pull that all up. Thank you
very much.
BY MR. MARSHALL:
Q.
So let's look at these here, these transactions. Who are
the majority of these transactions done by?
A.
A majority of them are associated with John Gaines.
Q.
John Gaines. In fact, that's all the way down, I guess,
till the bottom, which is, what, with the last entry? Would
that be correct?
A.
The last entry, a Geico entry for Carla Jackson.
Q.
And that's, what, June 17, 2020?
A.
Yes.
Q.
Now, you just testified a little while that Mr. Gaines
had been added on, I guess -- well, that -- he was added on to
the Bank of America account as a -- to be able to participate
in the bank transactions; correct?
A.
Correct.
Q.
But he had been associated with Roadrunner before that;
do you recall?
Well, let me ask you this: Do you know if he was a
founding organizer or a member of Roadrunner?
A.
I believe he was on the Secretary of State for Roadrunner
Automotive.
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Q.
Do you know what that year was when it was formed?
A.
I don't really recall. If you want to show me something
to refresh my --
MR. MARSHALL: Your Honor, can I approach the
witness?
THE COURT: Yes. Again, y'all can feel free to move
about the courtroom.
BY MR. MARSHALL:
Q.
Agent Stites, I'd like to refresh your recollection with
this document here and then I'll ask you a question.
A.
Okay.
Q.
Are you able to determine the date when that was formed?
A.
It says the effective date is 1/24 of 2019.
Q.
Okay. Thank you very much.
So Mr. John Gaines would have been involved with this
company from its inception; correct?
A.
Since -- yeah. Yes.
Q.
So he didn't just start doing transactions at the dates
that we're seeing here in the Bank of America in June of 2020,
he had been involved with the company earlier than that?
A.
He had been involved with the company. He was not a
signer on the account.
Q.
And we don't have a Bank of America official here
testifying. We don't really know what the reason is why
Mr. Gaines got added that particular day to that account, do
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we, the Bank of America account?
A.
We don't know.
MR. MARSHALL: Could we please go to 1166,
Ms. Holland. Thank you.
BY MR. MARSHALL:
Q.
Do you recall this exhibit being entered into evidence?
A.
Yes.
MR. MARSHALL: If we could go down to the deposit
sections, the transaction sections, and pull that part out,
please.
BY MR. MARSHALL:
Q.
Do you remember testifying about these transactions?
A.
Yes.
Q.
Okay. And of note there are two deposits there. What
are the two big deposits there that you see?
A.
The 155,252.50, which was the check that was deposited.
And then the wire from PNC Bank for 179,985.72.
Q.
I'm going to come back a little bit and make a big
general comment again. In your investigation we presented all
these WhatsApp messages that have been entered into the
record; correct?
A.
Correct.
Q.
All kinds of e-mail messages that we've seen from
different parties in this case; correct?
A.
Yes.
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Q.
Text messages?
A.
Yes, some text messages.
Q.
Have any WhatsApp messages, e-mail messages or text
messages had Carla Jackson as one of the parties
communicating?
A.
No.
Q.
So we're not going to find any kind of e-mails or any
kind of communications about why this deposit came in and so
forth on June 8th, 2020, in that amount of about $155,000;
correct?
A.
Not e-mail.
Q.
Same thing with the second deposit, 179 -- almost
$180,000, no communications between Carla Jackson and John
Gaines, for instance?
A.
Not between Carla Jackson and John Gaines.
Q.
Or Carla Jackson and Andre Gaines; correct?
A.
No.
Q.
And Andre Gaines is the founder of Gaines Travel &
Reservation; right?
A.
Correct.
Q.
All right. Down below, I think there's some extra
testimony --
MR. MARSHALL: Let's go to -- if we could go to
Government's Exhibit 1169. Go down to -- yes, that's fine.
That's fine.
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BY MR. MARSHALL:
Q.
Do you remember this exhibit?
A.
Yes.
Q.
What is this exhibit that you recall? What's this
withdrawal receipt?
A.
This is the withdrawal receipt from Wells Fargo to -- to
get the three certified checks.
Q.
Okay. All right.
MR. MARSHALL: Go down -- there's some certified
checks in there. If you could go down below where the checks
are, there are some images. Let's pull that one up.
BY MR. MARSHALL:
Q.
So after these two deposits have been entered, there is
some money taken out and these cashier's checks are obtained;
right?
A.
Correct.
Q.
And do we know from this document right here who the
person was that took this check out?
A.
Yes. The remitter was Carla Jackson.
Q.
Who is the payee? Who is this made out to?
A.
365 Enterprise, LLC.
Q.
And who do we know from previous testimony who that
company belongs to?
A.
John Gaines.
Q.
And have you entered -- is there anything in the record
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that shows any e-mail communications from John Gaines to Carla
Jackson or Carla Jackson to John Gaines about this check?
A.
No.
Q.
Are there any communications from Andre Gaines to Carla
Jackson about this check?
A.
No.
MR. MARSHALL: If we can go to the next image,
please. It's another check.
BY MR. MARSHALL:
Q.
Here's another one here. This is one of the other
cashier's checks taken out that day; correct?
A.
Yes.
Q.
Who took this one out?
A.
Carla Jackson.
Q.
And that's in the amount of how much?
A.
$10,000.
Q.
Okay. Similar to the last amount on the last check?
A.
Yes.
Q.
Right?
Okay. And down below there's a notation there. What
does it say down below? It has something redacted, but what
does it have noted there?
A.
John Gaines auto loan.
Q.
Okay.
A.
The account ending in 5813.
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Q.
And we had additional testimony about payment being on an
auto loan related to this; correct?
A.
Correct.
Q.
Again, is there anything in the record, any e-mail
communications, WhatsApp messages, text messages that you have
that show Carla Jackson in contact with John Gaines about this
matter?
A.
No.
MR. MARSHALL: If you can go to the next one. Thank
you.
BY MR. MARSHALL:
Q.
Who took this cashier's check out?
A.
Carla Jackson.
Q.
And who's this -- I should maybe reference this.
Who's this payee in this one?
A.
USAA.
Q.
And down below there's a notation again. What does that
say, handwritten or printed?
A.
Auto loan number ending 4019.
Q.
Okay. What's the name there?
A.
John Gaines.
Q.
What's the amount of this check?
A.
$10,000.
Q.
And, again, same question. Any communications at all
between John Gaines that we have in the record here and Carla
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Jackson about this check and why it's being taken out?
A.
No.
Q.
Okay. Thank you.
Let me ask you a little bit more about the -- just
generally about your interviews that you do. And I want to
ask -- so Ms. Jackson indicated this information about this
real estate project that she was involved in; right?
A.
I think she called it a construction project.
Q.
During that second visit did you ever ask her -- do you
recall asking her any additional -- for any additional
information about that project?
A.
No.
Q.
You wouldn't have requested it in your grand jury
subpoena because you didn't know about it at that time?
A.
I didn't ask her in the second one because I knew that
she was seeking counsel.
Q.
Did you ask -- do you recall asking her during that one
if she had an attorney at that point?
A.
Yes, I did.
Q.
Do you know if she had one?
A.
I believe she said Dwight Thomas was going to be her
attorney.
Q.
Did you ever reach out to Attorney Dwight Thomas to find
out if he'd talk to you about that or if his client would talk
to you about that?
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A.
I personally did not.
Q.
I know there was a question asked during the -- when you
spoke with Ms. Jackson on July 7th, 2020, you asked her about
Andre Gaines. Remember that?
A.
Yes.
Q.
And what do you recall her response was?
A.
She said that she was referred -- or that he was referred
to her, there was a referral, but that she didn't really know
him prior to this.
Q.
Do you recall her saying that she knew of him or
something?
A.
She knew of him. She didn't know him.
MR. MARSHALL: Just a minute, Your Honor. One
second, Judge.
Nothing further, Judge.
Thank you, Agent Stites.
THE WITNESS: Thank you.
THE COURT: Ms. Webster, any questions?
MS. WEBSTER: I do. Thank you.
CROSS-EXAMINATION
BY MS. WEBSTER:
Q.
Good afternoon, Agent Stites.
A.
Good afternoon.
Q.
We've heard a lot about certain people in this case, but
there are a lot of other people that were charged in this
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indictment as well; is that right?
A.
Yes.
MS. WEBSTER: Could we see Government's Exhibit 3000,
please, Ms. Holland.
BY MS. WEBSTER:
Q.
How many people were charged in this case? Do you know
off the top of your head?
A.
24.
Q.
So were they each involved in one of these loans?
A.
Yes.
Q.
And, in fact, Mr. Foster's actually charged in at least
one count with most of them; is that right?
A.
Yes.
Q.
So let's go through some of those people.
We've heard a lot about Darrell Thomas, but can you just
describe his role again?
A.
Darrell Thomas is sort of the main guy. He was
responsible for submitting the fraudulent loans. He recruited
individuals to go out and find business owners who would
submit information for PPP loans.
Q.
Okay. You would describe him as the ring leader?
A.
Yes.
Q.
And he was the one who was communicating with the
recruiters?
A.
Yes.
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Q.
And he was the one -- well, was he the one communicating
with all of the business owners or were they sometimes
communicating through the recruiters?
A.
Most of the time through the recruiters.
Q.
Okay. And then Meghan Thomas is also charged. Do you
know which of these loans she's charged with?
A.
I know Bellator, but I don't remember exactly which -- I
don't remember which loans she was exactly charged with.
Q.
What was her role?
A.
Meghan's role was more of a collector of documents and
managing the -- sort of the checklist of items that were
collected.
Q.
Okay.
A.
And assisting Mr. Thomas with whatever, you know, he
asked her to do.
Q.
And they were married?
A.
They were married.
Q.
And Jesika Blakely, what was her role?
A.
Jesika Blakely played a very similar role, where she was
managing the listing of loans and what documents were
collected and what still was outstanding and kind of managing
the process of collecting the documents.
Q.
And she -- did she consider herself an employee of
Mr. Thomas?
A.
Yes, she considered herself as part of Bellator.
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Q.
As part of Bellator.
And she had a Bellator Phront Group e-mail address?
A.
She had an e-mail address.
Q.
And do you remember which of these loans she was involved
with?
A.
I don't recall which ones she was charged with. If you
provide me with something to refresh my memory, I would...
Q.
It's fine.
And then who is Kahlil Green?
A.
Kahlil Green was the business owner for Impact Creations.
Q.
Do you know if he had direct communication with Darrell
Thomas?
A.
Yes. Yes, he did.
Q.
And in this case, right, you subpoenaed a lot of e-mails;
is that correct?
A.
Yes.
Q.
And that includes Darrell Thomas's e-mail addresses;
correct?
A.
Yes.
Q.
Okay. So that includes his Bellator Phront Group e-mail
address?
A.
Yes.
Q.
And a Gmail account; correct?
A.
Correct.
Q.
And you didn't subpoena Mr. Foster's e-mail address; is
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that right?
A.
No.
Q.
Did you subpoena Mr. Green's e-mail address?
A.
His -- no.
Q.
Okay.
A.
Can I ask what e-mail address are you referring to for
Mr. Green?
Q.
I don't have one. I was just wondering if you had
subpoenaed any e-mails from Mr. Green.
A.
No.
Q.
Okay.
And then John Gaines is also charged in this case;
correct?
A.
Correct.
Q.
And do you -- what was his role?
A.
John Gaines was a recruiter, sort of a middle person on
the Gaines Reservation & Travel loan. And the borrower was
Andre Gaines.
Q.
Say that last part again.
A.
The borrower was Andre Gaines.
Q.
Okay. And so was Gaines Reservation & Travel the only
loan that -- or the only company that he was responsible for?
A.
The -- of the ones that got charged.
Q.
But there are other ones that happened that were not
charged; is that right?
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A.
There were other loans that were in the works, yes.
Q.
And who was Amanda Christian?
A.
Amanda Christian is an individual that was in -- sort of
a recruiter or sort of a middle person between Darrell and a
business owner. And she also had a business of her own.
Q.
Okay. And what business did she have?
A.
She had Advertising and Then Some.
Q.
And that's one of the loans that's charged here; is that
right?
A.
Yes.
Q.
And was she also responsible for preparing some fake
documents?
A.
I believe so.
Q.
Okay. And then who is Mr. Charles Petty?
A.
Charles Petty is a recruiter, sort of a middle person
between Darrell and business owner. He was primarily involved
in the Transportation Management loan.
Q.
Did you have -- see any evidence of communication between
Mr. Petty and Mr. Foster?
A.
No, I don't believe so.
Q.
Who is Jerry Baptiste?
A.
Jerry Baptiste is an individual that was a middle person
between Darrell Thomas and Bern Benoit. In the Transportation
Management loan, Mr. Petty and Mr. Baptiste worked together on
that loan.
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Q.
Okay. Was there any evidence of communication between
Mr. Baptiste and Mr. Foster?
A.
I don't recall that there were.
Q.
You can't recall --
A.
I don't recall that there were.
Q.
Okay. Thank you.
And Bern Benoit, you just said, was associated with the
Transportation Management group?
A.
Yes.
Q.
Do you have any evidence of communication with Teldrin
Foster and Bern Benoit?
A.
I don't think so.
Q.
Who is Denesseria Slaton? Am I saying that name
correctly?
A.
Close. I think she goes by Dee, Dee Slaton.
Q.
Okay. Who is she?
A.
Again, she's a recruiter for -- that Darrell used to find
borrowers.
Q.
And do you know which of these loans she's responsible
for?
A.
I think she had her hand in several of them. I don't
recall exactly which ones at this point.
Q.
Okay. And tell me about Ricky Dixon. Who is that?
A.
Ricky Dixon is a recruiter, but he also had his own
business, Arcade Painting. So he was a borrower, and he also
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recruited some individuals to submit loans.
Q.
And do you know who he recruited?
A.
Edward Lee from Lee Operations. Derek Parker from D.
Parker Holdings. Charmaine Redding from All Star Room and
Board. ML Exotic Customs, Ryan Whittley. And that might be
it.
Q.
Okay. And Mr. Dixon corresponded quite a bit with
Darrell Thomas; is that correct?
A.
Say that again.
Q.
Mr. Dixon corresponded quite a bit with Darrell Thomas;
is that right?
A.
There was a decent number of e-mails, communication.
Q.
There were also messages on Mr. Thomas's phone; is that
right? Do you recall those?
A.
From Mr. Dixon?
Q.
Uh-huh (affirmative).
A.
I believe there were some. I don't recall what they
were, though.
Q.
Tell me who Charmaine Redding is.
A.
Charmaine Redding was the owner of All Star Room and
Board or the borrower for All Star Room and Board Services of
Michigan.
Q.
And she was communicating with Ricky Dixon; is that
right?
A.
Yes.
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Q.
And Darrell Thomas?
A.
I believe there might have been some e-mails.
Q.
And who is Derek Parker? His name is on at least one of
these accounts; right?
A.
Yes. He's the borrower for D. Parker Holdings, Inc.
Q.
And did he communicate with Mr. Thomas or did he only
communicate with Mr. Dixon?
A.
D. Parker -- Derek Parker communicated through Ricky
Dixon.
Q.
So there was no evidence of communication between him and
Teldrin Foster?
A.
Between Derek Parker and Teldrin Foster?
Q.
Yes.
A.
I don't believe so.
Q.
Okay. And who is David Belgrave?
A.
David Belgrave was the borrower for Continuing Success,
Inc.
Q.
So he's a business owner?
A.
Yes.
Q.
And who was he communicating with?
A.
I believe he was communicating with Amanda Christian.
Q.
Okay. Was there any evidence of communications directly
with Darrell Thomas?
A.
I don't believe so.
Q.
Tell me about Charles Hill. Who is that?
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A.
Charles Hill was -- let me see. Which one was he?
Infinite Education Services. He was the borrower for Infinite
Education Services, Inc.
Q.
And who was he communicating with?
A.
I believe he was Dee Slaton. He was communicating
through Dee Slaton.
Q.
And so did he communicate with Darrell Thomas or it all
went through Dee Slaton?
A.
I don't recall if there were any communications with
Darrell Thomas directly.
Q.
Okay. But the primary communication would have been with
Ms. Slaton?
A.
I believe so.
Q.
Who is Ryan Whittley?
A.
Ryan Whittley is the borrower for ML Exotic Customs, Inc.
Q.
Okay. And who did he communicate with?
A.
That'd be Ricky Dixon.
Q.
Okay. And was there any evidence that he was actually
communicating with Darrell Thomas?
A.
I believe he had some communications with Darrell Thomas.
Q.
Okay.
A.
And just to note, they're -- at some point, you know, I
think Darrell Thomas had stated that he had put some -- or
that he had communicated with the borrowers once they got the
loans through the recruiters on how to get the money back to
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him.
Q.
I'm sorry, I just want to make sure I understood what you
were saying.
That once the loans were approved and they received the
funds, Darrell Thomas then began communicating --
A.
Was communicating through the recruiters to dictate -- or
direct where the money flow was supposed to go.
Q.
Okay. So when the loan came in to the borrower's
account, it all went into the business owners' accounts; is
that right?
A.
Right.
Q.
And then Darrell Thomas would tell the recruiters to tell
the business owners where to send the money?
A.
Correct.
Q.
And was Teldrin Foster involved in that process?
A.
I don't believe so.
Q.
Who is Dwan Ashong?
A.
Dwan Ashong is a -- I guess we'll call her a recruiter,
but she also had some of her own loans that she was doing.
Q.
And do you mean that -- when you say she was doing her
own loans, that she was also a business owner or that she was
also preparing fraudulent loans outside of Darrell Thomas?
A.
I think she was doing some stuff outside of Darrell
Thomas.
Q.
Okay.
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A.
But also had some loans that she was working with Darrell
Thomas. And then the one, Bellevie Corporation, her husband,
El Hadj Sall, was the borrower for that.
Q.
So tell me who that is again. Say his name again.
A.
El Hadj Sall.
Q.
So he's the owner of Bellevie; is that right?
A.
Correct.
Q.
And did he have any communications with Darrell Thomas?
A.
I don't believe so.
Q.
And then who is Rick McDuffie?
A.
He is the borrower for Mickies Auto and Tires, LLC.
Q.
Okay. And who was he communicating with?
A.
I believe it was Amanda Christian, but I'm not positive.
Q.
Was he communicating with Teldrin Foster?
A.
I don't believe so.
Q.
So we've seen a lot of communications and e-mails between
Teldrin Foster's e-mail addresses and Darrell Thomas's e-mail
addresses. And we've also seen the WhatsApps. But we haven't
seen any e-mails between Teldrin Foster and any of these other
people; is that right?
A.
That's correct.
Q.
And we haven't seen any WhatsApp messages between Teldrin
Foster and these people that I've mentioned?
A.
Correct.
Q.
Okay. So I want to spend some time talking about Darrell
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Thomas.
You've spent a lot of time investigating this case; is
that right?
A.
Yes.
Q.
That might be an understatement, I imagine.
A.
There was a lot of hours put in.
Q.
And so you spent a lot of time reviewing his
communications?
A.
Whose communications?
Q.
Darrell Thomas's communications.
A.
Yes.
Q.
And that includes his e-mails?
A.
Correct.
Q.
And other messages that are on his phone?
A.
Correct.
Q.
So that includes WhatsApp messages?
A.
Yes.
Q.
And not just with Teldrin Foster; right?
A.
Yeah.
Q.
And have you reviewed his Telegram messages?
A.
Darrell's Telegram messages?
Q.
Yes.
A.
No.
Q.
So you haven't -- are you aware that there are Telegram
messages on his phone?
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A.
I don't recall the Telegram messages.
Q.
Do you know what Telegram is?
A.
Yes.
Q.
Tell us what it is.
A.
I know it's a messaging platform.
Q.
Is it sort of like WhatsApp?
A.
I believe it's similar, yeah.
Q.
Okay. And what about Signal?
A.
I believe Signal is another type of messaging platform.
Q.
And did you review any messages between Darrell Thomas
and anyone on -- using Signal?
A.
No.
Q.
So you haven't reviewed any messages between Darrell
Thomas and Jesika Blakely on Telegram; is that right?
A.
Correct.
Q.
Okay. And Bellator Phront Group was Darrell's company;
correct?
A.
Yes.
Q.
And it was the first company that applied for a PPP loan?
A.
I believe that's the first one out of this group, yes.
Q.
Okay. And as we were discussing earlier, when the money
came in for loans for other companies, he instructed them what
to do with the money?
A.
Correct.
Q.
And some of those companies sent funds to the Bellator
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Phront Group; is that right?
A.
Yes.
Q.
And Darrell Thomas controlled Bellator Phront Group?
A.
Yes.
Q.
And during this investigation, you've obtained Georgia
Secretary of State records for Bellator Phront Group; is that
right?
A.
Yes.
Q.
And other companies as well?
A.
Correct.
Q.
Can you look in the binder in front of you and turn to
Exhibit 1B, please?
A.
I'm sorry, which one was it?
Q.
1B.
A.
1B. Okay.
Q.
Do you recognize these documents?
A.
It looks like the State of Georgia Secretary -- it's the
registration for Bellator Phront Group.
Q.
Thank you.
MS. WEBSTER: Your Honor, we'd move to admit
Exhibit 1B under Rule 902.11.
MS. CHAIKEN: No objection, Your Honor.
MR. MARSHALL: No objection, Judge.
THE COURT: It's admitted.
MS. WEBSTER: Thank you.
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I'm going to use the Elmo here.
BY MS. WEBSTER:
Q.
Can you tell me what this document is?
A.
Is there a way to turn off the --
Q.
The thing on the side?
A.
Yeah.
MS. WEBSTER: I don't know where that's coming from.
Is it a touch screen?
(Organizational pause.)
MS. WEBSTER: Okay. All right. Problem solved.
Okay. Thank you. Here we go. Okay.
BY MS. WEBSTER:
Q.
Can you tell me what that document is?
A.
That looks like the articles of incorporation for
Bellator Phront Group.
Q.
Who's listed as the incorporator?
A.
This one says Meghan Thomas.
Q.
And that's not Darrell Thomas; correct?
A.
Correct.
Q.
Can you tell me what this is?
A.
It looks like an amended annual registration for Bellator
Phront Group.
Q.
What year is this? It's on the top right corner, filing
date.
A.
Filing date is 9/23/2019.
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Q.
And you see who is listed as the CEO or CFO, I believe?
A.
Yes.
Q.
And that's Darrell Thomas?
A.
It is.
Q.
And then Meghan Thomas is listed as the secretary?
A.
Yes.
Q.
And then Kevin James is listed as the CEO. Do you know
who that is?
A.
We had heard the name -- we had heard the name Kevin
James, but we don't really know who he is.
Q.
To your knowledge, was he actually a CEO of Bellator
Phront Group?
A.
I don't believe so.
Q.
Thank you.
And then if we're looking at the -- this document, this
was also filed in December of -- or this was also filed in
2019; is that right?
A.
Correct.
Q.
And that's another amended annual registration for
Bellator Phront Group; correct?
A.
Yes.
Q.
And now where it says officers, Darrell Thomas is still
listed as CFO; correct?
A.
Correct.
Q.
And Meghan Thomas is still listed as secretary; correct?
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A.
Yep.
Q.
But now someone named Brenda Johnson Miller is listed as
CEO; is that right?
A.
Correct.
Q.
And do you -- I think you testified yesterday about where
Darrell Thomas was living during the time of the -- of the PPP
loans. Was that the address 7200 Grandview Overlook, Duluth,
Georgia?
A.
That was the address that he was living, yes.
Q.
Do you know who Brenda Johnson Miller is?
A.
I believe she's the mother of Dwan Ashong.
Q.
And is she the CEO of Bellator Phront Group?
A.
No.
Q.
Do you know why she was listed here?
A.
I don't.
Q.
But through your investigation you learned that she
doesn't know Darrell Thomas; is that right?
A.
Correct.
Q.
And she's definitely not the CEO of Bellator Phront
Group?
A.
Correct.
Q.
Are you aware that Bellator Phront Group was dissolved --
administratively dissolved by the Georgia Secretary of State
in 2021 for failing to register?
A.
I believe I knew that.
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Q.
But did you know that it's been reinstated in July of
2023?
MS. CHAIKEN: Your Honor, objection. Relevance.
We're now three years outside the time frame.
THE COURT: Ms. Webster?
MS. WEBSTER: I think it goes to show that -- there's
a set of follow-up questions that's relevant to this that
shows that Darrell Thomas is still using other people's names
in order to further his -- what I would call his fraud and
his --
THE COURT: Well, I know earlier you cut off
Ms. Chaiken's document --
MS. CHAIKEN: August 6th.
THE COURT: -- on August 6th of 2020, I think. So
wouldn't the same thing apply here?
MS. WEBSTER: This document's already been admitted
into evidence, Your Honor, without objection.
THE COURT: That won't do it. Why don't you answer
my question.
MS. WEBSTER: Okay. I can move on, Your Honor. It's
fine.
THE COURT: Very well. It sounds like the question
is withdrawn; therefore, I don't need to rule on the
objection.
Go ahead.
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MS. WEBSTER: Thank you.
BY MS. WEBSTER:
Q.
But the name Brenda Miller wasn't just used on the
Secretary of State registration; is that right?
A.
I'm trying to think of where else it was. I don't
remember where else it was used.
Q.
Do you remember seeing the name in e-mails?
A.
I -- I do recall seeing e-mails with Brenda Miller in
them.
Q.
Okay. If you look at F19 and F19A and B in the binder in
front of you.
A.
You said F19, one-nine?
Q.
Yes, sir. One-nine, yeah.
A.
19A?
Q.
A and B.
A.
A and B.
Q.
Have you reviewed those documents? Are you still working
on it?
A.
Oh, sorry. Didn't know you wanted me to review them.
Q.
Yes, please.
A.
Okay.
Q.
Do these appear to be documents that were received from
GoDaddy in response to your subpoena for Darrell Thomas's
e-mails?
A.
Yes.
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MS. WEBSTER: Move to admit those pursuant to
Rule 902.11.
MS. CHAIKEN: Your Honor, we object under Rules 401
and 608.
THE COURT: May I see a copy of the document?
MS. WEBSTER: Yes.
THE COURT: All right, Ms. Chaiken, if you can expand
on that, please.
MS. CHAIKEN: Your Honor, Rule 608 allows impeachment
only of a witness who has testified in trial. This exhibit,
and a lot of the lines of questionings that have been pursued
so far are directed to impeachment of Darrell Thomas through
this witness. Darrell Thomas has not testified in this trial
and, therefore, Rule 608 does not allow impeachment of him,
especially not through another witness. So it's otherwise
irrelevant.
THE COURT: Well, what I've been given is a document
with the -- looks to be a bio of a Ms. Miller.
MS. CHAIKEN: Right. I think it's being used to show
that there was a fake bio created for a fake CEO of Bellator
Phront Group. And we've given leeway on these questions
because they really are not relevant to anything, but the only
purpose of these documents being admitted is to impeach
Darrell Thomas and show that he's engaged in other preparation
of fraudulent bios. It's not relevant to any issue in the
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case.
THE COURT: Well -- so you're saying improper
impeachment of someone who hasn't been a witness?
MS. CHAIKEN: Correct. Rule 608 only allows
impeachment of somebody who is a witness. And the Eleventh
Circuit has held the term "witness" refers to someone who
testified personally at trial or whose testimony has been
otherwise introduced as a substantive legal equivalent of
in-person testimony, like through a stipulation as to what
they would testify to.
THE COURT: All right. Ms. Webster?
MS. WEBSTER: Your Honor, I'm not admitting this to
call Darrell Thomas a liar. I'm admitting -- or I'm seeking
to admit it because I think the evidence will show that he had
a pattern and practice of using other people's names when it
benefited him. So using other people's names for, maybe,
applying for credit, things like that. Putting things in
other people's names.
And that's entirely relevant to our defense because,
obviously, our defense is that he was using Mr. Foster's
e-mail addresses and things like that. So I think it directly
goes to that. I think it's sort of like MO evidence,
basically.
THE COURT: Sorry, I didn't catch the last thing you
said. Sort of like what?
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MS. WEBSTER: MO evidence.
THE COURT: Okay. One moment.
MS. CHAIKEN: Your Honor, on that basis we'd invoke
Rule 404 as well.
THE COURT: Give me a minute.
I want to hear you, Ms. Chaiken, but I can't hear you
and try to process what's already been said at the same time.
All right. Go ahead, Ms. Chaiken.
MS. CHAIKEN: Your Honor, just based on the
explanation Ms. Webster just offered for why they're offering
this, we would invoke Rule 404. It sounds like propensity
evidence.
THE COURT: Ms. Webster?
MS. WEBSTER: I'm sorry, I'm not sure what you mean
by you invoke 404.
MS. CHAIKEN: 404 bars the introduction of propensity
evidence to prove that a person acted in conformity with a
particular character or trait on a particular occasion. And
it sounds like that's exactly what Mr. Foster is --
Ms. Webster is trying to do here.
MS. WEBSTER: Your Honor, it's not meant for
propensity purposes. It's to establish that he -- there was
modus -- MO, modus operandi, is a permissible purpose under
404. And I think that is what this is going to.
I also think it's just relevant to the course of the
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investigation. These e-mails, these documents were being sent
during and around the time of these charges. They also -- I
have another exhibit that's relevant to this and it goes to
show there was other stuff going on besides the PPP fraud.
And I think all of that is relevant to rebut the government's
case.
THE COURT: Ms. Chaiken, anything else? It's your
objection, I'll give you the last word.
MS. CHAIKEN: Still improper impeachment under 608,
Your Honor.
THE COURT: All right. Overruled. Go ahead.
MS. WEBSTER: Thank you, Your Honor.
Can I have that copy back?
THE COURT: Sure.
BY MS. WEBSTER:
Q.
Okay, Agent Stites. Can you tell us who this e-mail was
sent from?
A.
bpgintakecoordinator@gmail.com.
Q.
That was labeled as Meghan Thomas; correct?
A.
Yes.
Q.
And it was sent to Darrell Thomas; correct?
A.
Yes.
Q.
And it says, The requested items are attached; yes?
A.
Yes.
Q.
And then what was attached is this document; right? And
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this says it's the bio of Brenda J. Miller, a real estate
developer and CEO of Bellator Phront Group; correct?
A.
Yes.
Q.
And so it says that Ms. Miller leads all divisions of
operations, business development and construction as the CEO
of Bellator Phront Group, that she served in that capacity
since 2017 and had continued to develop and grow in the
multifamily industry, and that she brings a level of expertise
and knowledge in rebuilding multifamily complexes.
Is any of that true to your knowledge?
A.
I don't have -- no. I don't know. I don't think she's
part of Bellator Phront Group after interviewing her.
Q.
And then when it says that Bellator Phront Group sets the
industry standard in model multifamily living, does that seem
accurate based on your investigation of Bellator Phront Group?
A.
No.
Q.
No; right?
A.
No.
Q.
Thank you.
I'm showing you what I've marked as Defendant's
Exhibit 408.
Was this also a document that you received in your
response to your subpoena to GoDaddy?
A.
Yes, I remember seeing this e-mail.
Q.
You recall seeing it?
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A.
Yeah, I remember seeing some e-mails from an Andrew
Berkovitz.
Q.
Okay. Thank you.
MS. WEBSTER: We'd move to admit Defendant's Exhibit
F408, also under Rule 902.11.
MS. CHAIKEN: No objection, Your Honor.
THE COURT: It's admitted.
MS. WEBSTER: Thank you.
BY MS. WEBSTER:
Q.
Can you -- this is a document where there's communication
between this individual and allegedly Brenda Miller; correct?
It's the same document you have in your hand, if that's easier
to read.
A.
It's cut off on the top, so I just want to make sure I've
got the same thing you're looking at.
It's from Andrew Berkovitz to
info@bellatorphrontgroup.com.
Q.
Do you see who it's addressed to?
A.
It says, Hi, Brenda.
Q.
And it says, Thanks for this application; correct?
A.
Yes.
Q.
Okay. And you said that you read this e-mail before. Is
that --
A.
No. I said I've seen some e-mails from this individual.
Q.
And do you recall that these e-mails generally discuss
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some sort of equipment loan?
A.
I don't recall.
Q.
You don't recall that? Okay. Thank you.
I want to go back to Ricky Dixon for a little while.
He -- as I think we mentioned, he had a lot of interactions
with Darrell Thomas; is that right?
A.
He had some interactions with Darrell Thomas, yes.
Q.
Some? Do you disagree --
A.
I don't know the number.
Q.
Okay. But he had more than one interaction with Darrell
Thomas.
A.
Yes. True.
Q.
And he -- I think you testified earlier that he was
involved with the Lee Operations loan; is that correct?
A.
Yes. He was the recruiter for Edward Lee.
Q.
And if you turn to Exhibits 20A and 20 -- through 20D,
can you take a look at those?
Have you reviewed all those pages?
A.
Yes. Just 20A and B; right?
Q.
A, B, C and D.
A.
I didn't hear C and D, sorry.
Q.
You're fine.
A.
Yes.
Q.
Can you tell me what that appears to be?
A.
It's an e-mail from Darrell Thomas from his Gmail account
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to Ricky Dixon to his Hotmail account. And it has a --
basically a write-up of -- regarding Lee Operations and, you
know, the -- something to do with the PPP loan and...
Q.
And then what is 20C and D?
A.
This is an e-mail from Ricky Dixon to Darrell Thomas.
And it has a -- has that same verbiage, that same paragraph
about Lee Operations. And it's signed Edward Lee, with a
signature. And then there's a notary stamp. Then looks like
there's some other kind of stamp. I'm not sure what that
other stamp is.
Q.
Okay. And so are these documents that you received in
response to a subpoena to Google?
A.
Yes, we got these through the Google subpoena.
Q.
Thank you.
MS. WEBSTER: I'd move to admit F20A through F20D.
MS. CHAIKEN: No objection.
THE COURT: Hearing no objection from Mr. Marshall
either, they're admitted.
MR. MARSHALL: No objection, Judge.
BY MS. WEBSTER:
Q.
So just to be clear, this is -- first, 20A is an e-mail
from Darrell Thomas; correct?
A.
Yes.
Q.
And it's to Ricky Dixon and it sends an attachment?
A.
Yes.
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Q.
And that attachment is an unsigned statement; is that
right?
A.
Yes.
Q.
And that statement relates to Lee Operations; correct?
A.
Yes.
Q.
Okay. And so specifically it says, On May 21st after
discussing the loan I obtained for my employees at Lee
Operations with my investor Darrell Thomas, we discussed that
he had recently set up his payroll through rapid! PayCards for
accurate bookkeeping.
And it basically discusses this alleged agreement that
they had; correct?
A.
Correct.
Q.
And then the F20C is the document where Ricky Dixon sends
that statement back to Darrell Thomas; is that right?
A.
Yes.
Q.
But now the statement is signed and certified; correct?
A.
I don't know about certified but it's notarized.
Q.
Notarized, sorry. I used the wrong word there.
A.
I'm not sure it's certification.
Q.
And so Ricky Dixon and Darrell Thomas were communicating
and coming up with ideas on how to make sure that they could
get the funds from the loans that Lee Operations received; is
that right?
A.
Yeah, that appears what they were trying to do.
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Q.
Are you aware that Darrell Thomas actually sent that
statement to Gena Pyfrom-Foster in order to see if she thought
that it was okay or acceptable or a good idea?
A.
Am I aware that Darrell Thomas sent that to her?
Q.
Yes.
A.
I don't recall it, but you could refresh my recollection.
Yes, this is in the WhatsApp between Darrell and Gena on
6/30 of 2020.
Q.
And so he's asking her basically if she thinks that's
okay?
A.
Yeah.
Q.
Okay.
A.
Well, is the one on top after or before? I -- the
message basically just has the -- those words. It doesn't ask
do you think this is okay or anything.
Q.
Okay.
A.
It just has the -- that paragraph. There's no other --
Q.
Can I see?
A.
Okay. Okay.
Q.
So it's asking?
A.
Yeah. I didn't know about that other message. Sorry.
Q.
Sure. I wanted to confirm before I told you.
A.
Okay. I gotcha.
Q.
So there are communications between Ricky Dixon and
Darrell Thomas about these loans that are charged in this
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indictment?
A.
Yes.
Q.
And that's not just -- that's not the only one, that's
just one example; is that right?
A.
That's not the only what, e-mail?
Q.
That's not the only communication between Darrell Thomas
and Ricky --
A.
No, I believe there are more e-mails between Ricky Dixon
and Darrell Thomas, yes.
Q.
Okay. And in this case one of the things that you did
was you conducted interviews; is that right?
A.
Yes.
Q.
And you actually interviewed a lot of the people in this
case; is that right?
A.
Yes.
Q.
You had what we call sort of proffer sessions with some
of them; is that correct?
A.
Yes.
Q.
And that's where you have meetings with them?
A.
It's an interview. It includes the individual that we're
interviewing, it has -- their attorney is there, the US
Attorney's Office is there and agents involved in the case are
there.
Q.
So those are prearranged ahead of time; is that right?
A.
Yes.
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Q.
And those people are represented by counsel?
A.
Yes.
Q.
And when you come into a meeting, their attorneys are
there?
A.
Yes.
Q.
They're there, obviously, the person being interviewed?
A.
Yes.
Q.
You're there as the agent?
A.
Yes.
Q.
And then there are prosecutors from the US Attorney's
Office?
A.
Correct. And usually other agents that are involved in
the case are there as well.
Q.
Okay. And in this case, one of those interviews was --
or one of those proffer sessions was with Ricky Dixon; is that
correct?
A.
Yes.
Q.
And so you had a meeting with him?
A.
Yes.
Q.
And that was -- I believe it was Webex or Zoom or
something?
A.
It was a Webex.
Q.
Because it was during the pandemic?
A.
Yes.
Q.
So his attorney was present?
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A.
Yes.
Q.
And he spoke with you pursuant to a proffer letter?
A.
Yes.
Q.
And a proffer letter, it sort of sets out -- is a letter
that sort of sets out the terms of that interview; is that
right?
A.
Yes.
Q.
That's not what happened when you interviewed Teldrin
Foster; correct?
A.
Correct.
Q.
And at that time he did not have a lawyer?
A.
No.
Q.
There was no proffer letter setting out the terms of the
interview?
A.
No.
Q.
You didn't advise him about any -- how the statements
could be used against him?
A.
No.
Q.
You -- he came in, you just started talking basically; is
that correct?
A.
Pretty much, yes.
Q.
But back to Ricky Dixon.
He came in and he was asked to talk about his involvement
in the case; is that right?
A.
Yes.
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Q.
And he gave you a version of events?
A.
Yes.
Q.
And that version of events was inaccurate?
MS. CHAIKEN: Objection, Your Honor, 608.
MS. WEBSTER: Your Honor, I'm not trying to impeach
Ricky Dixon. I think that he falsely identified Teldrin
Foster and that's what it's being admitted for.
MS. CHAIKEN: Your Honor, the government hasn't
relied on Ricky Dixon in any way to prove its case against
Teldrin Foster. So whether or not Ricky Dixon said it was
Teldrin Foster or not is completely irrelevant.
THE COURT: All right. I was close to taking a break
anyway, so why don't we take that comfort break and then we'll
come back and discuss this issue and then I'll bring the jury
in. I don't think they need to be here for all that anyway.
Ladies and gentlemen of the jury, let's take a short
comfort break. Your break may be a little bit longer than all
of ours. All right? You're reminded of your instructions for
breaks. Thank you.
(The jury exited the courtroom at 4:40 p.m.)
THE COURT: Y'all can be seated. Thank you.
It's been a while, so why don't we all take a comfort
break first and we'll come back and debate that issue. Thank
you.
(After a recess at 4:41 p.m., the proceedings
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continued at 4:57 p.m. as follows:)
THE COURT: Let's put 608 to the side for a second.
I know that, Ms. Chaiken, you also made the relevance
objection, so -- I guess under 401, I guess even to the extent
there's some relevance, 403. Let's talk about that.
I guess I -- Ms. Webster, I don't know why we're
going down the road of attacking Ricky Dixon if the government
isn't using Ricky Dixon to prove their case.
MS. WEBSTER: It's not about attacking him per se, or
not really attacking him or impeaching him at all. The idea
is that not just Ricky Dixon but other people in this case,
when they were asked about who they were communicating with,
they -- I'm sorry.
Can the agent be excused for this part of the
conversation since it's the subject of the testimony?
THE COURT: Sure. Can you step down, please.
(Witness exited the courtroom.)
THE COURT: Give me one more moment, Ms. Webster.
MS. WEBSTER: Okay.
THE COURT: All right. Go ahead, Ms. Webster.
MS. WEBSTER: So it wasn't just Ricky Dixon, Your
Honor. It was multiple witnesses that were interviewed by the
government who were involved in this case who, to my
knowledge, had no actual communication with Teldrin Foster.
Somehow, when they went in to interview and to proffer, they
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lied to the agents and said that they were communicating
exclusively with Teldrin Foster and were not communicating
with Darrell Thomas. And so we know that's a lie because we
know they were communicating with Darrell Thomas.
And so -- and the agent actually called -- especially
with Ricky Dixon, actually confronted him and said you are
lying, like this is not true. You've known Darrell Thomas,
you were interacting with Darrell Thomas. And then the
proffer sort of ended at that point.
And so our defense is that it wasn't actually Teldrin
Foster sending the e-mails or in the WhatsApp chats. And so
that is -- this evidence goes to there being other efforts to
sort of point the finger at Teldrin Foster when they are not
true.
THE COURT: So what you want to get out through this
agent is, you talked with Bob, Bob said I talked to Foster,
but that wasn't true. I talked to Susie who said she talked
to Foster, but that wasn't true. I talked to Jimbo, Jimbo
said he talked to Foster, but that wasn't true, et cetera,
et cetera, et cetera. These are the -- where we're going with
this and it sounds like a lot of other questions.
MS. WEBSTER: I don't think there are a lot of other
questions, Your Honor, but there are -- there -- when you say
et cetera, et cetera, et cetera, there aren't like ten
examples of this. I think there are approximately three
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examples of this.
And those are basically the questions, that he said
Teldrin Foster, he was actually communicating with Darrell
Thomas. He did not communicate with Teldrin Foster. He was
lying to you about that; right? Those are -- and for Ricky
Dixon, he didn't even like -- he called him Taldrid. It was
like he didn't even know his real name.
So I think it all is -- those are the questions. I
think it all goes to the idea that there were efforts to blame
Mr. Foster for things that Darrell Thomas was doing.
THE COURT: Okay.
First off, I guess, how do you -- how are you getting
in any of these other statements? Through what rule?
MS. WEBSTER: None of them are being offered for the
truth of the matter, so they're not hearsay because they're
lies, so...
THE COURT: Ms. Chaiken, what's your issue with this
testimony?
MS. CHAIKEN: Your Honor, we're not relying on Ricky
Dixon or anybody else implicating Teldrin Foster. We're
relying on the evidence itself. I think this is completely
irrelevant. It doesn't in any way support that there was some
concerted effort to frame Teldrin Foster.
I think that the jury would need to understand that
these people received target letters telling them they were
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going to be charged with federal crimes. Some of them came in
for proffers. Some of them had already been charged. They
were obviously trying to save themselves by pointing the
finger at other people.
We did not rely on that in any way. And as
Ms. Webster said, Agent Stites confronted Ricky Dixon and
said, you're lying. So that's not any part of the
government's proof in this case. And unless Ms. Webster is
planning to introduce some kind of affirmative evidence that
someone was told to lie or to implicate Teldrin Foster, to
frame him and that he was not involved, there is just nothing
in this case that's consistent with somebody being framed.
As the Court knows, there's been 24 people charged.
Every single one of them who is not here in this trial has
pleaded guilty, has said I was involved. And so the
suggestion that Darrell Thomas has an MO of falsely
implicating people in things is just not borne out by any
evidence and it's incredibly misleading to the jury to suggest
that it is.
If you look at the evidence that came in about Brenda
Miller, Brenda Miller was a name on a piece of paper that
Darrell Thomas used. There's no doubt he put a fake name on a
piece of paper of someone that was not involved with Bellator.
But he did not have hundreds of e-mails with Brenda Miller, he
did not have WhatsApp messages with her. There's no
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indication at all that he took over her e-mail account or took
over her phone and was impersonating her. He just took a name
of someone he knew, the mother of one of his co-conspirators,
and put her name on a piece of paper. That's not an MO of
what's happening here with Teldrin Foster.
THE COURT: All right. Thank you.
Ms. Webster, I think Ms. Chaiken has an okay
relevance argument here, to the extent she's arguing. The
relevance of this is pretty slight.
However, I see your argument, that there's arguably
some slight relevance. So I'm going to give you a little
leeway. You know, under 403 and that balance, I think it'll
depend on how much of this -- how far you want to go down this
road because I think as you -- if you go too far down it, I
think you may run afoul of wasting time. And that 403 balance
may cut against you eventually.
I know that Ms. Chaiken has also mentioned the
misleading part. And perhaps that's at play as well.
So I'm going to give you a little leeway on these
types of questions and we'll see how far you go and whether
there's a renewed objection under 403 at any point, depending
on how far you decide to go.
Let's bring in the jury, please.
And let's bring in the witness. Thank you.
How much longer do you think you have of cross,
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Ms. Webster? I'm trying to just gauge our evening.
MS. WEBSTER: I'm not going to finish today.
THE COURT: Very well.
You can have a seat, sir.
(Witness recalled to the witness stand.)
THE COURT: Y'all can be seated until the jury comes
in.
(The jury entered the courtroom at 5:07 p.m.)
THE COURT: Y'all can be seated. Thank you.
Ms. Webster, go ahead.
The objection's overruled.
MS. WEBSTER: Thank you, Your Honor.
BY MS. WEBSTER:
Q.
So going back to where we were before we broke, you were
interviewing Ricky Dixon; is that correct?
A.
Yes.
Q.
And that was in a proffer session via Zoom or Webex?
A.
Correct.
Q.
And in that interview he told you that he had not been
communicating with Darrell Thomas; is that correct?
A.
He said that he had not been communicating to him
regarding the PPP loan.
Q.
Right. And, in fact, instead he said that it was Teldrin
Foster that he had been communicating with?
A.
He did.
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Q.
But he didn't actually say Teldrin. Does this sound
familiar?
A.
Yeah. I think he said Taldrin.
Q.
Taldrid?
A.
Taldrid.
Q.
Like T-A-L-D-R-I-D?
A.
Something like that. Yeah, it was a little bit off.
Q.
So he didn't actually affirmatively say Teldrin?
A.
Correct.
Q.
And, in fact, he lied or misstated what he had been doing
so much that you had to confront him on it; is that right?
A.
Yes.
Q.
And you had to say, we know that you're lying about this;
is that right?
A.
Yes.
Q.
And then at that point he had to take a break in the
interview?
A.
Yes.
Q.
And took a moment to speak with his lawyer?
A.
Yes.
Q.
And then that was the end of the interview; correct?
A.
Correct.
Q.
But Ricky Dixon wasn't the only one who denied
communicating with Darrell Thomas; is that right?
A.
I'm not sure who you're referring to, but...
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Q.
Okay. Charmaine Redding also came in for an interview;
is that right?
A.
Yes.
Q.
Okay. And she also said that she had not been
communicating with Darrell Thomas about the PPP fraud; is that
correct?
A.
I -- I would have to relisten to that to confirm.
Q.
Okay. Do you recall that she said that she did talk to
Teldrin Foster?
A.
Again, I would have to listen to Charmaine's interview
again.
Q.
Okay. Let me -- I'm going to circle back to that.
And so you are the case agent, as we said, in this case;
correct?
A.
Yes.
Q.
Okay. So you're responsible for the overarching
investigation?
A.
Correct.
Q.
And some people are not located in Atlanta; is that
right?
A.
Correct.
Q.
So, for example, Amanda Christian lives in South
Carolina?
A.
Yes.
Q.
Okay. And when her loan -- the PPP funds were deposited
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into her account, the Secret Service went to interview her; is
that right?
A.
Yes.
Q.
And in that interview she denied knowing that it was
fraudulent; is that right?
A.
Yes.
Q.
And then she said that she had received telephone calls
from an individual with the last name of Foster; is that
right?
A.
Again, I'd have to probably relisten to confirm that.
Q.
Would seeing the report from that interview help you
refresh your recollection?
A.
Sure. This is the Secret Service interview?
Q.
Yes. In this paragraph.
A.
She references Foster FNU, so first name unknown.
Q.
So she says that someone from this CDC SBF -- is that
the small business --
A.
It just says --
MS. CHAIKEN: Your Honor. Your Honor.
I object to this. He's reading from a report that he
was -- of an interview he was not present for and a report he
did not write and an interview he has no firsthand knowledge
of.
THE COURT: Ms. Webster?
MS. WEBSTER: He -- well, one, you can refresh
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someone's recollection with anything. He doesn't have to have
been part of the initial interview, but he testified that he
was the case agent and he's responsible for the entire
investigation. So I'm happy for him to put the report down
and testify about if his recollection was refreshed.
MS. CHAIKEN: Your Honor, you can't refresh someone's
recollection about something they never knew in the first
place. He read the report, but he was not there for the
interview, so he doesn't know what was said.
THE COURT: Ms. Webster?
MS. WEBSTER: I think the rules are pretty clear that
you can refresh recollection with anything and if -- and so he
knows what's in the report.
THE COURT: You can. I think the issue is if he ever
had the information in his mind at any point. So let's
establish that and then you can --
MS. WEBSTER: Okay.
BY MS. WEBSTER:
Q.
Agent Stites, did you previously during your
investigation read the report about the interview with Amanda
Christian?
A.
I believe I've seen this report. I got it from the
Secret Service agent that interviewed Ms. Christian.
Q.
And that was part of your investigation in this case;
correct?
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A.
Yeah.
Q.
Right? You received it as part of your duties as the
case agent?
A.
Yes.
Q.
And so would seeing -- does seeing it now refresh your
recollection about the contents of it?
A.
It does.
MS. CHAIKEN: Your Honor, the report is hearsay of a
different agent who is not here. And refreshing recollection
is about refreshing a witness's recollection about something
they did or something they knew, not about something they
read. Otherwise you could just put any document before a
witness and refresh their recollection about what that
document says.
THE COURT: Ms. Webster?
MS. WEBSTER: Again, it's not being offered for the
truth of the matter, Your Honor. It's -- because she's
clearly, I think, lying about basically everything in there,
so it's not hearsay, it's not being offered for that.
Again, this was -- he's the case agent who
investigated the entirety of the case. So this is part of his
investigation, part of his efforts.
THE COURT: All right. This is seeming awfully
messy, folks.
Ladies and gentlemen of the jury, why don't you-all
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have a great evening and we'll see you tomorrow at 9:00. And
perhaps by then I will have waded through this and figured it
out. Okay?
Have a great evening. See you at 9:00.
(The jury exited the courtroom at 5:14 p.m.)
THE COURT: Y'all can have a seat. Thank you.
Give me a moment.
I guess the issue is, you know, how far does the
fact that --
And, sir, if you could step outside the courtroom,
please.
(Witness exited the courtroom.)
THE COURT: I feel like we're in a bit of a bizarre
scenario. I'm just trying to break down where we are.
I don't know that I've seen this happen before.
That's not to say it's wrong and you can't do it, it's just I
haven't seen this before. So I just want everyone to break it
down for me and we can think about the actual Rules of
Evidence.
We have the case agent on the stand; right?
MS. WEBSTER: Yes.
THE COURT: Knows a lot about the case.
MS. WEBSTER: Yes.
THE COURT: Didn't do everything on the case, but did
some stuff on the case and read a lot of other stuff about the
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case; right?
MS. WEBSTER: Yes.
THE COURT: Agree, Ms. Chaiken?
MS. CHAIKEN: Yes, Your Honor.
THE COURT: All right. And you want to ask him
questions about a lot of different things?
MS. WEBSTER: Many different things.
THE COURT: Okay. I'm going to ask some questions
right now, Ms. Webster, and then I'll let you make your
argument, okay?
MS. WEBSTER: Okay.
THE COURT: Thank you.
And what you want to do is ask him some questions
about Amanda Christian, who was part of this investigation;
right?
MS. WEBSTER: Yes. And someone that he was
charged -- Mr. Foster was charged with conspiring with, I
believe.
THE COURT: So far, so good.
And, Ms. Chaiken, it seemed like you were fine with
questions about Amanda Christian until she wanted to refresh
his recollection about Amanda Christian; right?
MS. CHAIKEN: Yes, Your Honor.
THE COURT: Okay. And you didn't want her to be
able -- you didn't want her to be able to provide the agent a
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copy of the interview transcript to refresh his recollection?
MS. CHAIKEN: Well, Your Honor, it's not an interview
transcript. It's a report of an interview that was done by an
agent from a different agency who was not involved in this
investigation.
THE COURT: Okay. Whether it's that or whether it's
a telephone book, does it matter what she wants to refresh his
recollection with?
MS. CHAIKEN: It matters because you can only refresh
a witness's recollection about something they once had a
recollection about. And so I --
THE COURT: And I think she established that he would
have known this at one point.
MS. CHAIKEN: He would have read it, but he
doesn't -- when you refresh a witness's recollection,
generally the witness was at an interview and wrote a report
and then you ask the agent, you know, did the witness say X,
and the agent says, I don't remember exactly. And then they
look at a copy of their report that they wrote and that
reminds them that in the interview the witness said X.
But, here, the agent doesn't know that because he
wasn't at the interview. He has no idea what was said because
he didn't write the report. All he did was get a copy of the
report and read it.
And so if you could refresh an agent's recollection
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with everything he read in the course of his investigation,
you could just present your entire case through reports,
hearsay reports from third parties that the agent has no
personal knowledge of.
THE COURT: Do you have something that shows me you
can't do that?
MS. CHAIKEN: Not right in this moment. I agree that
you can refresh a witness's recollection with anything, but I
don't think that she's established that it refreshed his
recollection about what was said in the interview. All she's
done is refreshed his recollection about what's in the report.
THE COURT: Well, that sounds just like an issue with
semantics then and how the question's phrased.
MS. CHAIKEN: The report is hearsay. She is offering
it for the truth of what the report says, which is Amanda
Christian said she had calls with Foster, or whatever it is.
So that's the whole point, is that --
THE COURT: That seems to make sense to me,
Ms. Webster. When you're going that far and trying to get
that statement in, that does seem to be different.
MS. WEBSTER: I'm not --
THE COURT: And I know you say, oh, I'm not offering
it for the truth of the matter asserted, but what are you
offering it for, if not?
MS. WEBSTER: I'm not offering the --
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THE COURT: And I'll let you know, I don't -- I'm not
persuaded by Ms. Chaiken's argument about you can't use this,
that or the other to refresh somebody's recollection if it
refreshes it. But I do think her argument about hearsay makes
sense. And I'm just not understanding why -- if you're just
having him read what she said in an interview and then spill
it out to the jury, that does seem like for the truth of the
matter asserted.
MS. WEBSTER: So, Your Honor, we're not -- I think
there's potentially two levels of hearsay. We're not trying
to get in that the Secret Service agent said anything. We're
just trying to get out that Amanda Christian made the false
statement. And so that statement, I think, is what is not
being offered for the truth of the matter. And so I think
that it's admissible.
And I would just tell the Court, I'm not -- that's
basically the last question I have for him, is just to say,
that's what she said, she identified Mr. Foster, which I think
he's already testified to. And then to say there's no
indication that that's actually true what happened. That's
it. That's the entirety of the questioning about that.
THE COURT: Well, you asked, Sure, this is a Secret
Service interview. Yes, in this paragraph. She references
Foster, first name unknown. So she says that someone from the
CDC SBF -- is that the small business -- is that -- that seems
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like a different question than what you just said you were
going to ask.
MS. WEBSTER: I'm sorry. Say it again.
THE COURT: It looks to me like you're just going
through her testimony and have him say did she say this, did
she say this.
MS. WEBSTER: But what she's saying is not being
offered for the truth of the matter because it's not true.
Because the idea that someone named Foster from CDC SBF called
her and that's when she knew that it was a lie, is not true.
So it can't be offered for the truth of the matter. And,
therefore, it's not hearsay.
MS. CHAIKEN: Your Honor, you can't get to that
second level of what she said and what that is offered for
without first getting to the first part, which is this is a
Secret Service agent who is saying Amanda Christian said X.
And that is hearsay.
We don't know if that is true or not, we weren't
there. Nobody was there. And you can't get to what Amanda
Christian said. They should call the Secret Service agent if
they want to establish what Amanda Christian said, but she's
having our agent read a different agent's report in order to
prove what was said.
I agree that the underlying -- if she actually said
it is not true and would -- well, I don't know if it's not
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true, but it's fine that they're not offering it for the
truth.
But the fact that it was said in and of itself is
hearsay because it's coming from an out-of-court declarant's
report.
MS. WEBSTER: When she's in -- sorry.
When I was offering, I was not asking him, And did
the Secret Service agent tell you that she said this? I said
she was interviewed by the Secret Service and then she said
this; right? So I'm not offering that middle level or that --
THE COURT: You've lost me, Ms. Webster. I mean, the
question was, So she says that someone from the CDC SBF -- is
that the small business -- it just says -- and so he's -- you
know, at that point he's reading from the report what the
agent asked and what she said, which Ms. Chaiken has said,
well, it's -- at least what the agent said someone else said
is hearsay.
And, you know, perhaps if you want her answer to come
in and that's not offered for the truth, Ms. Chaiken said
fine, but at least what the Secret Service agent asked is
hearsay.
MS. WEBSTER: But what the -- I didn't offer anything
about what the Secret Service asked. When I referred to the
CDC SBF, that is the bank and who she --
THE COURT: Why don't you give me the exhibit.
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MS. WEBSTER: Yes.
THE COURT: And we can go line by line what questions
you're going to ask and why you're going to ask them. And
I'll let Ms. Chaiken object.
The only -- the only question that's currently
objected to is, So she says that someone from the CDC SBF --
is that the small business.
So hand me the document that says that and we'll
figure it out.
MS. WEBSTER: Your Honor, it's two pages, but the
relevant part is just this top paragraph on this page.
THE COURT: Well, for now, I'm guessing. We're going
to have this conversation, then you're going to ask the next
question. So give me a moment to read this.
Which page is the first page of this two-page
document?
MS. WEBSTER: The complete one is the first page that
goes all the way down. And then the second page only goes
part of the way down.
THE COURT: And this is a report of investigation,
just paragraphs, notes from some agent that wrote them at some
point?
MS. WEBSTER: It was produced to us in discovery as a
document from the Secret Service. I recognize it's not on the
form, but that's how it was produced to us in discovery.
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THE COURT: All right. I've now read through this.
Point me to -- so she says that someone from the CDC SBF -- is
that the small business -- where in here exactly is that?
MS. WEBSTER: It's the first paragraph on the second
page, Your Honor.
THE COURT: I don't see the SBF part.
MS. WEBSTER: Or -- I'm sorry, I guess I'm -- it's
CDC Finance.
THE COURT: All right. So what question are you
going to ask? So she says that someone from this CDC SBF, CDC
Finance, is that the small business -- go ahead with what your
question was going to be before Ms. Chaiken objected.
MS. WEBSTER: It was going to be, she said that she
received a call from CDC Finance, that that person had the
last name of Foster, and that's when she figured out that it
was a fraud allegedly.
THE COURT: I don't see that in this document.
MS. WEBSTER: Christian stated that at this point she
began to suspect that the loan was a part of a scam.
It's the last -- the entirety of the first paragraph;
right. That's it.
THE COURT: All right. And, Ms. Chaiken, your
objection to her asking Agent Stites, was this what she said,
is what?
MS. CHAIKEN: Your Honor, it's just pure hearsay.
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The agent would just be reading off what another agent said
that Amanda Christian said. There's no other basis for our
agent to know what Amanda Christian said in that interview
other than somebody else saying it in a report.
THE COURT: All right. So you're -- where you're
going is not the underlying Amanda Christian statement.
You're conceding, okay, that might not be offered for the
truth. But this is saying what somebody else said about what
Amanda Christian said; correct?
MS. CHAIKEN: Right. Right. Because they are
offering the agent's statement to prove the truth that this is
what Amanda Christian said. You can't get to what Amanda --
THE COURT: Very well.
Ms. Webster, how do you get around that? That seems
to be a fair argument on Ms. Chaiken's point.
And I'm sorry it took me 15 minutes to understand
what you were saying, but that does seem -- you've got -- I
don't know if double hearsay is the correct way to say it, but
you've got one rung there that does seem like hearsay. I get
that under the rung below that, you're saying, well, that's
not offered for the truth, but it's still hearsay of this
other agent.
So I don't know who wrote this. Maybe we bring him
in and you might not have a problem, but I think you've got a
problem right now if you want to get this in through Agent
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Stites.
MS. WEBSTER: Because my arguments are a couple. One
is that I'm not offering -- I'm not going to ask the agent,
another agent told you this; correct? No. I just want to ask
him if this is what was said.
So the hearsay layer that the government is worried
about is not being offered into evidence. That's one.
THE COURT: Well, of course it is.
MS. WEBSTER: What do you mean?
THE COURT: Did you just say that the hearsay the
government's not (sic) worried about isn't being offered into
evidence? You're doing exactly that.
MS. WEBSTER: The hearsay level that the
government -- because I'm not going to introduce a statement
from the agent saying another agent interviewed her and then
she said, right?
THE COURT: So you'd like to just skip that level and
pretend it doesn't exist?
MS. WEBSTER: Yes.
THE COURT: Okay. I'm not going to let you do that.
MS. WEBSTER: Okay.
THE COURT: So objection sustained on that grounds.
MS. WEBSTER: Okay. Can I -- but let me make a
couple different arguments.
First of all, it's relevant to the entirety of the --
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or to the course of the investigation, which I think we
have --
THE COURT: I'm with you on relevance. You don't
have to argue relevance.
MS. WEBSTER: Okay.
THE COURT: What you do have to argue is the hearsay,
which I just sustained.
MS. WEBSTER: Okay. Can I have one second?
THE COURT: Yes.
MS. WEBSTER: Your Honor, it is not -- that middle
level of hearsay I think is not actually being offered for the
truth of the matter either. It's actually being offered to
show the effect on the investigation, which is something that
the government uses all the time to get in what would
otherwise be hearsay evidence because this woman, Amanda
Christian, ended up being charged in a -- the same count with
Teldrin Foster about this crime. And so -- or about this loan
that she's referring to; right? And so I'm entitled to ask
him about that statement and the effect that it had on his
investigation.
THE COURT: Ms. Chaiken?
MS. CHAIKEN: Your Honor, this is just an attempt to
end run here. Just to be clear, this interview was not
conducted at Agent Stites's direction. This was a separate
investigation that was being conducted by the Secret Service.
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When we -- when we did our investigation, we found
out that the Secret Service had a separate investigation that
they had closed into Amanda Christian. We got the documents
because we have an obligation to turn over a defendant's
statement. And Amanda Christian was a defendant, and so we
got this and we turned it over.
But the defense doesn't have any evidence that we
charged Teldrin Foster because Amanda Christian identified a
CDC Finance employee as first name unknown Foster. She can't
show that this did have any impact on the investigation or
that Agent Stites in some way decided Teldrin Foster was
involved because of this statement by Amanda Christian.
She hasn't laid a foundation for that at all. And
saying "effect on the investigation" is just an attempt to end
run the fact that she can't get in the fact that this
statement was made.
THE COURT: All right. Yeah.
I'm happy to see if you can lay that foundation about
the effect on the investigation, but, otherwise, I think
Ms. Chaiken's -- that layer of hearsay objection is well
taken. And it's sustained but without prejudice to lay the
foundation for the effect on the investigation.
MS. WEBSTER: Thank you.
And just to be clear, we would argue a lack of the
effect on the investigation is also relevant.
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THE COURT: Okay.
MS. WEBSTER: Thank you, Your Honor.
THE COURT: Very well.
All right. Anything else that we can anticipate
discussing to save us some time? I mean, I would hate to come
back at 9:00 and then five minutes later after the jury comes
back and we get through this issue, there's another big issue
that's going to take us a long time to debate.
So anything coming down the pipe?
MS. WEBSTER: I am a little concerned about timing
for tomorrow, so maybe we should take that up. So I still
have a fair amount to go through with Agent Stites. The
government has -- did you say six -- six more witnesses that
it needs to go through and maybe get them all done tomorrow?
Right. But they're supposed to be short, I think. And I'm
just talking for them.
But then we also need to get to Persinger because of
his conflict. And so that's sort of the issue.
THE COURT: Well, I thought we already agreed that
Persinger, at some point, you would call him and it would be
out of order.
MS. WEBSTER: I think that that's right, Your Honor,
but we're just -- I think we're worried about me being able to
finish with Agent Stites, get all the witnesses that have to
go tomorrow, and then get to Persinger before the end of the
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day.
THE COURT: I'm missing something. I mean, if that's
the problem, do Persinger earlier in the day.
MS. CHAIKEN: Well, Your Honor, that's the problem.
We have a witness who needs to be done by 3:00 tomorrow. And
then we have five other witnesses who are short, like
Ms. Liddiard, the bank witnesses, who will, you know, each be
five minutes. But they have been here since Wednesday.
They're all here from out of town, mostly from the west coast,
and they also need to be done tomorrow. We can't keep them
here over the weekend. We can't bring them back next week.
And so we're just worried about running out of time, because
all of our --
THE COURT: This seems like -- these seem like
problems we can handle. So let's do this.
What's our estimate for how long, Ms. Webster, you
need with Mr. Persinger?
MS. WEBSTER: With Mr. Persinger, I think we -- on
direct, an hour, an hour and a half. An hour and a half might
be a little extra.
THE COURT: What's your anticipated cross of
Mr. Persinger? Or is it Dr. Persinger?
MS. CHAIKEN: Probably about 45 minutes, Your Honor.
MR. MARSHALL: Your Honor, I have my own mini
scheduling issue. So I'm assuming that we would not get to my
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part of the case and my witness until at least Monday? Is
that fair?
MS. CHAIKEN: I think so.
MR. MARSHALL: Think?
MS. CHAIKEN: Yeah, I don't think -- we're not going
to get to him tomorrow.
MR. MARSHALL: Okay. Because I've got to arrange --
I have one witness, so...
THE COURT: All right. So Persinger will last about
two hours and 15 minutes, give or take. You have five or six
short witnesses.
MS. CHAIKEN: We have five bank witnesses who we
anticipate, you know, assuming that there's no cross, as there
wasn't for Ms. Liddiard, we'd estimate, you know, 45 minutes
tops for those together, collectively. 30, 45 minutes.
THE COURT: So far I've got a total of three hours
for Persinger and those five witnesses.
MS. CHAIKEN: And then we've got one more that our --
the cell site analyst, who our examination would probably be
30 minutes, 45 minutes.
THE COURT: And how long does the defense counsel
believe their cross of these five bank experts and this one
other cell person will be?
MS. WEBSTER: I don't anticipate having any cross of
the bank witnesses, but I anticipate that the cross for the
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cell site expert will be approximately an hour.
MR. MARSHALL: I don't anticipate any on that
witness, Judge.
THE COURT: All right. Persinger, two hours and
15 minutes. The five bank witnesses, 45 minutes. That's a
total of three hours.
Cell tower person, 30 to 45, plus one. Let's call it
an hour and 45 minutes. That's a total of three, plus hour 45
is four hours and 45 minutes, which we should be able to do;
right?
I must be missing something.
MS. WEBSTER: My finishing the cross of Agent Stites.
THE COURT: Oh, that's where we might have to give.
So I guess you get to decide. Do you want to finish
crossing Agent Stites tomorrow morning and risk not getting
through Persinger? Or do you want to pause with Agent Stites,
do all these bank witnesses and the cell witness and
Persinger, and then come back to Stites at the end of the day
if we have time?
MS. WEBSTER: That is what I suggested, but there's
an issue with the government, because while Agent Stites is on
the stand, they cannot talk to him. And he's their case
agent.
MS. CHAIKEN: Your Honor, Agent Stites is our agent.
We haven't been able to speak to him since he started
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testifying yesterday. And if he doesn't finish tomorrow, we
won't be able to talk to him over the weekend and we'll be
preparing for the defense case, we'll be preparing for
closings, and that, you know, is going to severely limit our
ability to work through things. He's an integral part of our
team.
THE COURT: All right. Here's what we'll do.
Ms. Webster can finish her cross-examination of
Mr. Stites, at which point we will then hear from the five
bank witnesses. Then we will hear from Mr. Persinger.
And then if we have time, we'll hear from the cell
phone person. It may be that one cell phone person will have
to come back.
MS. CHAIKEN: Your Honor, he's on leave next week.
He's out of town next week, the cell site expert is.
THE COURT: Who is the cell site expert?
MS. CHAIKEN: His name is Jay Berni.
THE COURT: Is he a government employee?
MS. CHAIKEN: He's an FBI agent.
THE COURT: Okay.
MS. WEBSTER: Your Honor, can we propose a slightly
different solution? Which is that we agree that the
government can speak with Agent Stites over the weekend so
long as it's not about his testimony? Would that solve the
problem?
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MS. CHAIKEN: Your Honor, the time we've estimated
still leaves about three hours for tomorrow morning for the
cross of Agent Stites. Is that -- do we really think you're
going to need longer than that to finish crossing him?
MS. WEBSTER: I'm sorry, one second.
Alternatively, why can't we do the bank witnesses,
the cell site expert, let us do Persinger, and we can put
Agent Stites at the end of the day and hopefully it'll be
done.
THE COURT: But if he's not?
MS. WEBSTER: But if it's not, then, again, we agree
that they can talk to him over the weekend.
THE COURT: About anything and everything?
MS. WEBSTER: Except for what he's testified to,
yeah.
MS. CHAIKEN: Your Honor, he's testified about
basically the whole case. When we're talking through closing
and what we're going to say and what the defenses are and what
the responses are to that, that's obviously going to implicate
things he's testified about. I don't think that's a line we
can really draw.
THE COURT: I agree. I'm not going to ask the
government -- I mean, this is, from what I've seen, their most
important witness, who is kind of helping them with the entire
case. So I'm not willing to accommodate your witness issue --
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MS. WEBSTER: Sure.
THE COURT: -- stymie the government, so --
MS. WEBSTER: We'll agree they can talk to him.
THE COURT: -- absent the defense -- both defendants
saying, yes, if we don't finish Stites tomorrow, the
government can talk with Stites about anything and everything,
what I'm going to do is have Stites go first, followed by the
five bank witnesses, followed by the cell phone expert,
followed by Persinger, if and when we get to him.
But I don't think it's -- you know, the government's
already saying, fine, we can interrupt our case to have your
expert witness, but, you know, to do that, to then bind them
out of talking to their agent over the weekend, when I would
assume everybody's going to be working pretty hard on this
case, that's not an acceptable solution.
MS. WEBSTER: Okay. We'll agree to it, Your Honor.
MR. MARSHALL: Yeah. And we'd have no objection to
it.
THE COURT: All right. Very well.
So just so we're clear then, before we begin
tomorrow, if we don't get back to Stites and finish Stites
tomorrow, the government's not going to be prohibited from
speaking to him about anything and everything.
Is that correct, Ms. Webster?
MS. WEBSTER: That's correct.
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THE COURT: Is that correct, Mr. Marshall?
MR. MARSHALL: Yes.
THE COURT: All right. Very well then.
In that case, it would seem prudent to tie up this
last little line of questioning with Agent Stites, and then to
pause him and do everyone else and then go back to him at the
end of the day to the extent we have time left.
Does everyone agree?
MS. WEBSTER: Yes.
MS. CHAIKEN: Sure, yes.
MR. MARSHALL: I'm fine with that, Judge.
Judge, can I add one more thing when you get to the
next thing?
Can I ask, Ms. Webster, how many -- other than
Mr. Persinger, how many other witnesses you have and how long
it might take?
MS. WEBSTER: Sorry, my mind has just gone totally
blank.
MR. MARSHALL: That's okay.
MS. WEBSTER: I think we have -- we're not entirely
sure. I think it might be three, but I'm not positive.
THE COURT: And that was the first part of
Mr. Marshall's questions.
MR. MARSHALL: And then about how long?
MS. WEBSTER: How long they will take?
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MR. MARSHALL: Yeah.
MS. WEBSTER: One of them is our investigator, who
could take -- and we're going to admit various records through
her. So that one could take, you know, a few hours or an
hour, maybe two.
And then the other two I think should be fairly
short.
THE COURT: Okay.
MR. MARSHALL: Okay.
THE COURT: All right. Anything else for this
evening, Counsel?
MR. MARSHALL: No, Judge. At some point, when we get
to my part and my witnesses, we'll have to advise my client of
her right to testify if she wants to and all that. We might
still call her.
THE COURT: Certainly. I'll do that as to both
defendants when we get there.
All right. Anything else?
MS. CHAIKEN: Yes, Your Honor.
We had raised this in some of our pretrial briefing
and at the pretrial conference. I do think at this point that
the defense has opened the door to admission of the
co-defendants' guilty pleas. First of all, by asking about
how many people were charged and going through the fact that
they were charged and not tying up that loop of what happened
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with those charges, but also by suggesting to the jury that
Darrell Thomas falsely implicated people, and none of those
people who were charged were falsely implicated.
And I think that this is exactly what we predicted
was going to happen and the argument that was going to be
made. And I think the door's been opened to that and we
should be able to put that in on redirect.
MS. WEBSTER: Your Honor, I just have litigated this
issue in the Eleventh Circuit recently. I think that the law
is very clear that you can't admit -- it's a confrontation
clause issue. And so the law is very clear that you can't
admit co-defendants' guilty pleas without having them come and
testify.
And I think I cited two cases in the response to the
government's motion in limine, and I think they're named
Griffin and Easley, something like that, and I can provide
those to the Court, but I think the law is pretty clear on
that.
We are not -- we have not suggested that any of the
co-defendants have been falsely charged. If the government
has a guilty plea from Brenda Miller, I guess that would be
relevant potentially, but I don't think that's what has
happened here. So I don't think that we have opened the door
to that.
And I don't think that it's admissible. I think the
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law is very clear, that co-defendants' guilty pleas are not
admissible unless they come and testify.
THE COURT: Mr. Marshall, anything to add?
MR. MARSHALL: No, Your Honor. It's not directed
towards me, I don't believe. Is that correct, Ms. Chaiken?
MS. CHAIKEN: Well, it would be evidence that would
come in at the trial that the jury would hear as to everyone.
MR. MARSHALL: Well, what would you actually be
trying to introduce?
MS. CHAIKEN: We would be introducing that all of the
list of people that Ms. Webster went through for each one and
asked if they were charged and asked if they communicated with
Darrell Thomas and in some way implied, I think, that they
were not really involved, they didn't talk to Darrell Thomas,
but they were charged, that they pleaded guilty and admitted
that they were involved.
MS. WEBSTER: That was -- I'm sorry.
THE COURT: That was a response to Mr. Marshall's
question, so I'll let Mr. Marshall speak and then I'll hear
from you, Ms. Webster.
MR. MARSHALL: I really don't have a dog in that
fight, but I'll just object based -- I'll follow co-counsel's
arguments, Judge.
THE COURT: I'll have to look back at that. Yeah.
It seems that we are somewhere different than we were at the
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pretrial conference, given some of the questions that were
asked. So I don't know -- I don't know where that shakes out.
I'll take a look.
MS. CHAIKEN: Your Honor, I would just note that we
had filed a motion in limine to preclude reference to charging
decisions and to who was charged and who was not charged,
precisely because who was not charged and was not charged is
not generally relevant to the jury's consideration. The
questions could have been asked as who was the owner, what did
you determine about the owner's involvement, without putting
before the jury that they were charged.
But it was the defense that chose to go into that,
despite the case law that charging decisions really are not
relevant, and I think that the jury may be left with a
misimpression based on the nature of the questions about
people's interactions with Darrell Thomas directly tied to
whether they were charged. Who was this person, did they
communicate with Darrell Thomas, I think implies to the jury,
oh, here's another person that didn't communicate with Darrell
Thomas and was charged with a crime.
MS. WEBSTER: Your Honor, there were -- first of all,
these people are charged in the same indictment. They're
charged in the same counts as Mr. Foster, so the government's
case, when they are saying, like, look at these communications
between these two people, it doesn't address other people that
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he's charged with conspiring with. And so I'm entitled to ask
the agent about their role.
It was not -- the point of that line of questioning,
of did they communicate with Darrell Thomas or not was to lead
to the questions where Ricky Dixon was falsely identifying
Mr. Foster. That is the whole point. That was the setup for
those questions, is to say these people -- some of them were
communicating directly with Darrell Thomas, some of them
weren't. But Ricky Dixon absolutely was. Amanda Christian --
Charmaine Redding also was and was not communicating with
Teldrin Foster.
THE COURT: Right. Didn't you ask about the charge?
MS. WEBSTER: I said they were charged in this case.
And is the jury not going to get a copy of the indictment that
has them charged?
I think there's a limiting instruction that says, you
know, you don't consider anyone else's guilt or -- like
what -- how they answer their charges is left for another day,
basically, and you're only considering whether or not Teldrin
Foster and Ms. Jackson are guilty.
But the idea that just because I said other people
were charged in this case means that their guilty pleas get to
come in without them testifying violates a number of
Constitutional rights, his confrontation clause rights, due
process rights.
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THE COURT: I asked for Ms. Chaiken, Ms. Webster.
MS. CHAIKEN: Your Honor, first of all, I think it
was put before the jury that other people in this case pleaded
guilty and not by us earlier in the case. So I think the door
has been opened to that in any event.
But Ms. Webster said, in the presence of the jury,
several times that Mr. Foster's defense is that Darrell
Thomas's MO is to use other people's names and suggesting that
he falsely implicates people. And I think the brief they
filed pretrial said that that was their defense. That he, at
least in part, falsely implicates people or falsely inculpates
people.
And I think telling the jury that all of these people
have been charged, trying to distance them from Darrell
Thomas, and in some way suggesting to the jury that, you know,
this is all a big conspiracy against people who don't know
Darrell and don't talk to Darrell, I think leaves the
impression that Darrell Thomas may have falsely inculpated
other people. And that is not true.
There is nobody who has been charged in this case who
has not admitted their guilt, other than the people who are
here on trial and Mr. Baptiste. We're certainly happy for the
Court to give a limiting instruction that the jurors should
not rely on anybody else's guilt to determine Mr. Foster or
Ms. Jackson's guilt. We are not offering it for that purpose.
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We certainly agree that the jury should not consider it for
that purpose.
But guilty pleas are permitted to be considered for
other purposes. And here it's to rebut the defense that
Darrell Thomas has an MO of falsely implicating people.
THE COURT: All right. One moment.
All right. Anything else from either side on this
for right now?
MR. MARSHALL: I would just say, Judge, from my
side -- well, when you get to me, Your Honor.
THE COURT: Go ahead.
MR. MARSHALL: If there is any ruling that admits any
of these plea agreements, obviously, if they're standard plea
agreements, I'm not assuming any of them make any reference to
my client in any way. So I'd object if there was any kind of
reference like that. So I think I'm in a different position
from Mr. Foster's counsel, but I will -- I just object on that
additional ground.
MS. CHAIKEN: Just to be clear, Your Honor, we're not
seeking to introduce any actual plea agreements, just the fact
there was a guilty plea.
THE COURT: Anything else, Ms. Webster?
MS. WEBSTER: Your Honor, I would like to be able to
provide you with the citations to the cases if you're inclined
to grant the government's motion.
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THE COURT: All right. I think I'd like more than
that. I think this would -- I want to be very cautious.
Ms. Chaiken, I'm not sure you're not right, you might
be, but I want to be very cautious if I take that step and
admit what you want me to admit. Therefore, I'd like a motion
from the government, a response and a reply. So perhaps by
tomorrow morning you could put together a motion of what you
want to do and why. And then it might be that we get to --
over the weekend I get some response briefs and I'll let y'all
know on Monday when it's looking like the government's case
will still be open at this point.
All right. Okay. Thanks, everyone. Have a good
evening. See you at 9:00.
(After a recess at 5:57 p.m., proceedings were
continued on February 9, 2024, as follows:)
- - - - -
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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 7th Day of February, 2024.
________________________________
PENNY PRITTY COUDRIET, RMR, CRR
OFFICIAL COURT REPORTER
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 153 of 174
$
$10,000 [2] - 235:16, 236:23
$10,560 [3] - 195:3, 195:20, 196:12
$155,000 [1] - 233:9
$180,000 [1] - 233:13
$34,000 [1] - 197:10
$34,500 [1] - 193:8
$60,000 [1] - 192:14
$71,144.35 [1] - 229:15
$8,000 [1] - 203:3
$9,810 [1] - 196:7
0
05/21 [1] - 198:16
1
1 [2] - 162:3, 204:18
1,380.41 [1] - 198:9
1/24 [1] - 231:13
10/21/2019 [1] - 177:2
10TH [3] - 193:20, 195:14, 195:18
1116 [1] - 224:15
1146 [1] - 197:17
1150 [1] - 227:8
1151 [1] - 228:14
1166 [1] - 232:3
1169 [1] - 233:24
11:11 [1] - 188:7
11:12 [1] - 172:14
11:45 [1] - 163:9
11TH [1] - 193:20
12 [2] - 220:16, 220:17
12/30 [1] - 228:5
12:08 [1] - 186:8
12:51 [1] - 173:7
12:55 [1] - 181:10
12:58 [1] - 168:19
12TH [1] - 173:25
13 [2] - 220:17, 222:10
14 [1] - 188:18
14TH [2] - 183:17, 184:8
15 [5] - 175:5, 210:1, 292:16, 298:10,
299:5
155,252.50 [1] - 232:16
15TH [2] - 184:13, 184:15
16TH [3] - 175:24, 179:13, 184:21
17 [1] - 230:13
1700 [1] - 223:23
179 [1] - 233:12
179,985.72 [1] - 232:17
17TH [1] - 179:25
1920 [1] - 180:21
19A [1] - 257:14
1:13 [1] - 166:2
1:20-CR-00296-JPB [1] - 160:5
1:25 [1] - 178:8
1:31 [1] - 163:1
1:40 [1] - 171:11
1:45 [1] - 163:20
1B [4] - 252:12, 252:14, 252:15, 252:21
1ST [2] - 196:4, 206:21
2
2 [7] - 168:1, 178:25, 191:9, 193:3,
193:16, 204:18, 207:9
20 [2] - 223:1, 264:16
2017 [2] - 167:14, 262:7
2019 [18] - 166:25, 168:22, 172:23,
175:8, 175:9, 176:20, 176:22, 176:23,
178:14, 180:8, 184:1, 214:21, 214:22,
214:23, 224:6, 228:5, 231:13, 254:17
2020 [69] - 164:17, 166:2, 166:15,
166:20, 166:21, 166:22, 167:9,
168:19, 170:18, 171:11, 172:14,
173:7, 173:25, 175:5, 175:8, 175:9,
175:24, 177:15, 178:1, 178:8, 178:16,
178:17, 178:19, 178:20, 179:13,
179:25, 180:20, 181:10, 182:10,
183:17, 184:8, 184:13, 184:21,
185:20, 185:23, 186:8, 186:22, 188:7,
189:14, 192:13, 193:20, 195:14,
195:18, 195:24, 196:5, 198:4, 198:9,
198:22, 202:22, 202:23, 202:24,
203:2, 204:14, 204:15, 206:21,
206:24, 207:13, 218:20, 226:15,
228:10, 229:1, 230:13, 231:19, 233:9,
238:3, 256:14, 267:8
2021 [1] - 255:24
2023 [1] - 256:2
2024 [3] - 160:11, 311:15, 312:9
20A [3] - 264:16, 264:19, 265:21
20C [1] - 265:4
20D [1] - 264:16
20TH [2] - 198:22, 202:23
2116 [2] - 213:15, 214:3
21ST [1] - 266:6
2222 [1] - 214:3
2250G [2] - 192:15, 192:17
2250H [2] - 196:20, 196:21
2250I [2] - 196:23
2250Q [2] - 208:23, 208:24
2250T [2] - 207:23, 207:24
2250U [2] - 208:10, 208:11
2250W [3] - 196:23, 197:2, 197:3
22ND [5] - 166:25, 198:4, 198:7, 198:9,
198:12
2300 [2] - 189:4, 189:7
2318 [1] - 167:4
2318A [1] - 167:5
2322 [2] - 173:22, 178:25
2324 [1] - 179:9
2324A [1] - 179:10
2327 [2] - 198:17, 198:18
2327A [1] - 198:18
2329 [1] - 180:13
2329A [1] - 180:13
312
2332 [2] - 168:1, 184:9
2333 [1] - 185:15
2333A [1] - 185:16
2336 [1] - 177:6
2348 [4] - 170:1, 170:9, 189:2, 189:5
2350 [2] - 190:15, 190:20
23RD [2] - 185:20, 185:23
24 [2] - 239:8, 275:13
2413A [2] - 165:6, 165:12
2431 [2] - 164:13, 164:15
2431B [2] - 165:7, 165:9
2431C [1] - 164:20
2436 [2] - 165:22, 165:25
2441 [2] - 172:10, 172:12
2441A [1] - 172:16
2445 [1] - 167:15
2445D [4] - 173:10, 173:15, 181:15,
181:21
2445G [1] - 167:16
2447 [3] - 173:3, 173:5, 173:12
2447A [1] - 173:9
2464 [1] - 179:20
2464B [1] - 180:5
2467 [2] - 181:6, 181:8
2467A [4] - 181:16, 181:18, 182:21,
182:23
2471 [2] - 184:17, 184:19
2471A [1] - 184:25
2472 [2] - 175:20, 175:22
2472A [1] - 176:3
2472B [2] - 176:4, 176:12
2474 [4] - 169:22, 169:23, 171:7, 171:9
2474A [1] - 171:17
2475 [2] - 186:18, 186:20
2475A [2] - 186:23, 186:24
2477 [2] - 178:3, 178:6
2477A [1] - 178:4
2479 [2] - 188:3, 188:5
2479A [1] - 188:9
24TH [2] - 178:17, 196:10
2508 [1] - 182:7
2508H [2] - 182:20, 183:1
2511 [3] - 183:13, 183:15, 184:5
2511E [1] - 183:22
2512 [2] - 175:1, 175:3
2512D [1] - 175:10
2512E [1] - 175:10
2513 [2] - 168:15, 169:25
2513C [1] - 168:23
2513F [1] - 169:13
2514 [2] - 186:4, 186:6
2514G [1] - 186:12
2516 [2] - 187:14, 187:16
2516E [1] - 187:22
25TH [2] - 168:19, 189:14
26 [2] - 204:18, 206:3
26-PAGE [1] - 204:12
26TH [5] - 171:11, 178:1, 186:8, 186:22,
224:9
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27 [1] - 164:17
27TH [2] - 178:8, 222:25
2871 [1] - 193:3
2872 [1] - 193:16
2879 [1] - 192:18
28TH [1] - 166:2
2940 [2] - 194:5, 195:6
2941 [1] - 195:15
2942 [1] - 196:2
2943 [3] - 194:5, 194:21, 194:25
2950 [1] - 199:25
2954 [2] - 199:25, 201:7
29TH [1] - 167:14
2ND [2] - 202:22, 202:24
3
3 [6] - 160:6, 172:23, 193:10, 195:15,
196:2, 204:18
30 [3] - 298:15, 298:20, 299:7
3000 [1] - 239:3
3005 [3] - 203:14, 204:2, 206:16
3015 [4] - 202:1, 202:2, 202:10, 202:16
30TH [1] - 188:7
31ST [2] - 176:21, 196:5
365 [1] - 234:21
388 [2] - 189:4, 189:7
3:00 [1] - 297:5
3:03 [1] - 215:14
3:19 [1] - 215:15
3:20 [1] - 215:23
3:24 [1] - 179:25
3:29 [1] - 164:17
4
4 [3] - 172:23, 204:18, 206:3
401 [2] - 258:3, 272:4
4019 [1] - 236:19
403 [4] - 272:5, 276:12, 276:15, 276:21
404 [5] - 260:4, 260:11, 260:15, 260:16,
260:24
408 [1] - 262:21
45 [9] - 297:23, 298:14, 298:15, 298:20,
299:5, 299:7, 299:8, 299:9
4:14 [1] - 184:21
4:40 [1] - 271:20
4:41 [1] - 271:25
4:57 [1] - 272:1
4TH [2] - 181:10, 181:19
5
5/21 [1] - 198:16
50 [1] - 192:14
51 [3] - 201:7, 201:10, 201:16
5813 [1] - 235:25
5:07 [1] - 277:8
5:14 [1] - 283:5
5:37 [1] - 175:24
5:57 [1] - 311:14
5TH [2] - 167:9, 229:1
6
6 [1] - 197:17
6/11 [1] - 195:24
6/11/2020 [1] - 195:3
6/16/2020 [1] - 168:8
6/17 [2] - 228:10, 229:9
6/25 [1] - 170:18
6/26/2020 [1] - 177:25
6/27/2020 [1] - 177:24
6/30 [1] - 267:8
608 [7] - 258:4, 258:9, 258:14, 259:4,
261:9, 271:4, 272:2
66 [1] - 166:16
6TH [7] - 172:14, 204:15, 205:11, 206:5,
206:6, 256:13, 256:14
7
7 [1] - 160:11
7200 [1] - 255:7
76.105.87.198 [1] - 225:10
7:38 [1] - 186:22
7:39 [1] - 182:10
7TH [3] - 218:20, 238:3, 312:9
8
8:02 [2] - 183:17, 184:8
8:05 [2] - 178:1, 178:2
8:28 [1] - 184:15
8TH [3] - 173:7, 182:10, 233:9
9
9 [1] - 311:15
9/23/2019 [1] - 253:25
90 [1] - 1:5
902.11 [5] - 194:6, 200:1, 252:21, 258:2,
263:5
940 [6] - 165:9, 165:12, 211:16, 211:19,
212:20, 213:11
940S [1] - 213:9
941 [15] - 166:15, 168:5, 168:13, 169:17,
175:18, 176:14, 178:14, 178:20,
184:1, 186:16, 187:3, 211:8, 212:21,
213:11, 214:5
941S [21] - 164:23, 164:25, 168:22,
169:15, 171:23, 172:23, 175:8, 180:8,
180:10, 185:6, 185:8, 186:9, 186:14,
187:20, 187:24, 188:14, 188:16,
213:9, 214:18, 214:21
959,946.42 [1] - 166:17
9:00 [4] - 283:1, 283:4, 296:6, 311:13
9:20 [1] - 175:5
9:40 [1] - 219:1
A
A.M [12] - 163:9, 166:2, 168:19, 171:11,
313
173:7, 175:24, 178:8, 179:25, 181:10,
184:21, 186:8, 186:22
A1 [1] - 213:8
ABILITY [1] - 300:5
ABLE [11] - 199:8, 230:17, 231:12,
284:25, 296:23, 299:9, 299:25, 300:2,
305:7, 310:23
ABSENT [1] - 302:4
ABSOLUTELY [1] - 308:9
ACCEPTABLE [2] - 267:3, 302:15
ACCESS [7] - 205:21, 205:24, 205:25,
212:9, 212:10, 226:6
ACCESSED [1] - 227:1
ACCOMMODATE [1] - 301:25
ACCOUNT [82] - 164:16, 164:18,
164:19, 166:1, 166:4, 168:18, 169:15,
170:19, 171:10, 171:15, 171:21,
172:3, 172:4, 172:13, 175:4, 178:7,
178:19, 179:22, 180:20, 180:22,
181:9, 182:15, 182:24, 183:8, 183:9,
183:16, 185:4, 185:8, 185:10, 186:21,
187:8, 187:17, 188:6, 188:23, 188:24,
193:13, 193:19, 193:22, 194:2, 195:9,
195:11, 195:13, 195:18, 195:21,
195:25, 196:4, 196:8, 197:8, 197:11,
197:14, 199:7, 199:9, 199:22, 200:7,
200:12, 200:14, 200:25, 201:1, 201:4,
205:21, 206:1, 206:25, 224:23, 227:2,
229:4, 229:7, 229:8, 230:17, 231:22,
231:25, 232:1, 235:25, 241:23, 248:9,
264:25, 265:1, 276:1, 280:1
ACCOUNTING [1] - 195:4
ACCOUNTS [2] - 246:4, 248:9
ACCURATE [2] - 262:15, 266:10
ACTED [1] - 260:17
ACTIVITIES [1] - 221:18
ACTIVITY [1] - 224:23
ACTUAL [3] - 272:24, 283:18, 310:20
ADD [2] - 303:12, 306:3
ADDED [4] - 228:11, 230:16, 231:25
ADDITIONAL [5] - 174:8, 236:1, 237:10,
310:18
ADDRESS [20] - 165:19, 179:17,
201:20, 201:21, 224:25, 225:2, 225:8,
225:23, 226:1, 226:2, 227:2, 241:2,
241:3, 241:21, 241:25, 242:3, 242:6,
255:7, 255:9, 307:25
ADDRESSED [1] - 263:18
ADDRESSES [6] - 224:24, 225:20,
241:17, 249:17, 249:18, 259:21
ADMINISTRATIVELY [1] - 255:23
ADMISSIBLE [3] - 287:15, 305:25,
306:2
ADMISSION [1] - 304:22
ADMIT [20] - 170:1, 190:14, 194:4,
196:22, 196:23, 199:24, 202:9,
203:20, 204:1, 205:17, 252:20, 258:1,
259:14, 263:4, 265:15, 304:3, 305:10,
305:12, 311:5
ADMITS [1] - 310:12
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 155 of 174
ADMITTED [18] - 170:7, 190:18, 194:9,
194:12, 194:14, 197:1, 200:4, 202:15,
227:13, 252:24, 256:16, 258:23,
263:7, 265:18, 271:7, 306:15, 309:21
ADMITTING [2] - 259:12, 259:13
ADVERTISING [12] - 172:6, 172:15,
172:24, 173:8, 173:13, 174:23, 175:6,
177:15, 178:9, 178:14, 213:5, 243:7
ADVISE [2] - 270:16, 304:13
AFFIDAVIT [1] - 216:24
AFFIRMATIVE) [1] - 245:16
AFFIRMATIVELY [1] - 278:8
AFORESAID [1] - 312:8
AFOUL [1] - 276:15
AFTER [1] - 1:7
AFTERNOON [6] - 210:5, 210:6, 216:6,
216:7, 238:22, 238:23
AGENCY [1] - 285:4
AGENT [29] - 163:10, 164:6, 203:13,
209:18, 209:20, 215:18, 216:6,
218:22, 223:2, 224:18, 238:16,
238:22, 261:16, 275:6, 291:23,
292:25, 294:24, 295:11, 296:12,
296:24, 299:12, 299:15, 299:16,
299:21, 299:24, 300:23, 301:3, 301:8,
303:5
AGENT [47] - 203:8, 203:12, 207:3,
218:23, 220:5, 220:7, 231:9, 269:8,
272:14, 273:5, 273:16, 279:13, 281:3,
281:19, 281:23, 282:3, 282:9, 282:20,
283:20, 284:25, 285:4, 285:17,
285:18, 285:21, 286:3, 287:11,
288:16, 288:20, 288:22, 289:8,
289:15, 289:16, 289:20, 290:21,
292:1, 292:3, 292:22, 293:3, 293:4,
293:15, 299:23, 299:24, 300:19,
302:13, 308:2
AGENT'S [3] - 285:25, 288:22, 292:11
AGENTS [3] - 268:22, 269:12, 273:1
AGO [2] - 226:7, 226:20
AGREE [11] - 220:6, 284:3, 286:7,
288:24, 300:22, 301:11, 301:22,
302:3, 302:16, 303:8, 310:1
AGREED [1] - 296:19
AGREEMENT [2] - 199:15, 266:11
AGREEMENTS [3] - 310:13, 310:14,
310:20
AHEAD [10] - 206:7, 210:2, 256:25,
260:8, 261:11, 268:24, 272:20,
277:10, 291:11, 310:11
ALABAMA [1] - 220:24
ALLEGED [1] - 266:11
ALLEGEDLY [2] - 263:11, 291:16
ALLOW [1] - 258:14
ALLOWS [3] - 199:6, 258:9, 259:4
ALMOST [2] - 216:22, 233:12
ALTERNATIVELY [1] - 301:6
AMANDA [26] - 243:2, 243:3, 246:21,
249:13, 279:22, 281:20, 284:14,
284:21, 284:22, 286:15, 287:12,
288:16, 288:19, 288:21, 292:2, 292:3,
292:6, 292:9, 292:12, 294:15, 295:3,
295:5, 295:8, 295:12, 308:9
AMENABLE [1] - 163:11
AMENDED [2] - 253:21, 254:19
AMERICA [1] - 160:4
AMERICA [8] - 180:19, 194:2, 227:15,
227:22, 230:17, 231:19, 231:23, 232:1
AMOUNT [8] - 169:3, 229:2, 229:14,
233:9, 235:15, 235:17, 236:22, 296:12
AN [1] - 1:2
ANALYSIS [2] - 217:4, 219:14
ANALYSIS [1] - 213:7
ANALYST [1] - 298:19
ANALYZE [3] - 203:8, 207:3, 217:25
AND [3] - 1:4, 1:7, 160:6
AND.. [1] - 265:3
ANDRE [7] - 222:5, 233:16, 233:18,
235:4, 238:4, 242:18, 242:20
ANDREW [2] - 263:1, 263:16
ANN [1] - 160:18
ANNUAL [3] - 211:19, 253:21, 254:19
ANSWER [3] - 256:18, 289:18, 308:18
ANSWERED [2] - 220:11, 226:7
ANTICIPATE [6] - 163:8, 296:4, 298:13,
298:24, 298:25, 299:2
ANTICIPATED [1] - 297:21
ANY [1] - 1:9
ANYWAY [2] - 271:13, 271:15
APP [4] - 193:14, 193:25, 198:5, 198:8
APPEAR [1] - 257:22
APPEARANCES [1] - 160:13
APPEARED [1] - 220:10
APPLICATION [3] - 185:21, 216:24,
263:20
APPLICATIONS [2] - 200:20, 200:21
APPLIED [1] - 251:19
APPLY [1] - 256:15
APPLYING [1] - 259:17
APPROACH [1] - 231:4
APPROVED [2] - 216:25, 248:4
APRIL [4] - 164:17, 166:2, 166:25,
192:13
ARCADE [2] - 213:1, 244:25
ARE [1] - 1:8
ARGUABLY [1] - 276:10
ARGUE [3] - 294:4, 294:6, 295:24
ARGUING [1] - 276:8
ARGUMENT [9] - 204:25, 205:22, 276:8,
276:10, 284:10, 287:2, 287:4, 292:15,
305:5
ARGUMENTS [3] - 293:2, 293:24,
306:23
ARRANGE [1] - 298:7
ARRESTED [1] - 204:15
ARTICLES [1] - 253:14
ASHONG [3] - 248:17, 248:18, 255:11
ASSERTED [2] - 286:23, 287:8
ASSIGNED [1] - 202:7
314
ASSISTANT [1] - 160:16
ASSISTING [1] - 240:14
ASSOCIATED [10] - 199:22, 201:15,
202:7, 221:19, 229:8, 229:9, 230:8,
230:20, 244:7
ASSUME [1] - 302:14
ASSUMING [4] - 215:16, 297:25,
298:13, 310:14
AT [1] - 163:1
ATLANTA [1] - 279:19
ATLANTA [3] - 160:2, 160:25, 163:1
ATTACH [4] - 168:20, 175:7, 186:9,
187:20
ATTACHED [9] - 164:23, 168:21,
173:12, 175:12, 176:6, 186:14,
187:24, 261:23, 261:25
ATTACHED [1] - 1:6
ATTACHING [1] - 1:9
ATTACHMENT [5] - 166:12, 178:13,
198:24, 265:24, 266:1
ATTACHMENTS [9] - 171:20, 172:19,
172:22, 175:12, 180:7, 183:24, 185:3,
187:1, 188:12
ATTACKING [3] - 272:7, 272:9, 272:10
ATTEMPT [3] - 219:16, 294:22, 295:14
ATTENTION [1] - 228:25
ATTORNEY [4] - 237:18, 237:22,
268:21, 269:25
ATTORNEY [1] - 237:23
ATTORNEY'S [2] - 268:22, 269:10
ATTORNEYS [2] - 209:14, 269:3
ATTORNEYS [1] - 160:16
AUGUST [7] - 204:14, 204:15, 205:11,
206:5, 206:6, 256:13, 256:14
AUTHENTICATED [2] - 170:2, 190:15
AUTHORIZATIONS [1] - 218:11
AUTO [3] - 235:23, 236:2, 236:19
AUTO [5] - 187:11, 187:18, 188:19,
213:6, 249:11
AUTOMOTIVE [3] - 213:6, 227:16,
230:25
AWARE [4] - 250:24, 255:22, 267:1,
267:4
AWFULLY [1] - 282:23
B
BABASIJIBOMI [1] - 160:15
BABYSITTER [1] - 223:10
BALANCE [2] - 276:12, 276:15
BANK [9] - 180:19, 194:2, 227:15,
227:22, 230:17, 231:19, 231:23,
232:1, 232:17
BANK [22] - 180:19, 180:22, 180:24,
193:5, 194:1, 194:2, 195:17, 196:4,
197:19, 224:23, 230:18, 289:24,
297:7, 298:12, 298:22, 298:25, 299:5,
299:17, 300:10, 301:6, 302:8
BAPTISTE [5] - 243:21, 243:22, 243:24,
244:2, 309:22
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 156 of 174
BARBER [1] - 213:8
BARS [1] - 260:16
BASED [8] - 191:22, 192:3, 192:7,
200:6, 260:9, 262:15, 306:22, 307:15
BASIS [2] - 260:3, 292:2
BE [2] - 1:3, 1:4
BECOME [1] - 211:5
BEFORE [1] - 160:10
BEGAN [3] - 191:24, 248:5, 291:19
BEGIN [1] - 302:20
BEGUN [1] - 168:9
BEHALF [3] - 160:14, 160:17, 160:20
BELGRAVE [2] - 246:15, 246:16
BELLATOR [39] - 165:12, 167:24,
192:21, 195:2, 195:20, 196:16,
199:17, 199:22, 200:14, 201:2,
201:13, 208:14, 208:20, 213:1, 214:6,
240:7, 240:25, 241:1, 241:2, 241:20,
251:16, 251:25, 252:3, 252:6, 252:18,
253:15, 253:21, 254:11, 254:20,
255:12, 255:19, 255:22, 258:20,
262:2, 262:6, 262:12, 262:13, 262:15,
275:23
BELLATOR'S [2] - 200:7, 200:24
BELLEVIE [6] - 185:13, 185:22, 186:10,
213:5, 249:2, 249:6
BELONGS [2] - 225:9, 234:23
BELOW [9] - 174:8, 201:19, 230:3,
233:21, 234:10, 235:20, 235:21,
236:17, 292:20
BENEFITED [1] - 259:16
BENOIT [3] - 243:23, 244:7, 244:11
BERKOVITZ [2] - 263:2, 263:16
BERN [3] - 243:23, 244:7, 244:11
BERNI [3] - 203:13, 300:17
BEST [3] - 219:19, 219:23, 219:24
BETWEEN [35] - 181:1, 188:20, 189:8,
189:11, 189:23, 190:1, 190:8, 190:22,
192:7, 192:14, 199:15, 203:18,
206:19, 207:17, 233:13, 233:15,
236:25, 243:4, 243:16, 243:18,
243:23, 244:1, 246:10, 246:12,
249:16, 249:19, 249:22, 251:10,
251:13, 263:11, 267:7, 267:24, 268:6,
268:8, 307:25
BIG [5] - 184:10, 232:15, 232:18, 296:7,
309:16
BILL [1] - 174:6
BIND [1] - 302:12
BINDER [4] - 201:23, 203:14, 252:11,
257:10
BIO [3] - 258:18, 258:20, 262:1
BIOS [1] - 258:25
BIT [16] - 174:21, 179:5, 193:14, 193:15,
216:8, 218:19, 226:8, 226:9, 227:9,
232:18, 237:4, 245:7, 245:10, 271:17,
278:7, 283:13
BIZARRE [1] - 283:13
BLAKELY [3] - 240:18, 240:19, 251:14
BLAME [1] - 274:9
BLANK [1] - 303:18
BLOW [2] - 176:11, 177:7
BOARD [4] - 213:4, 245:5, 245:21
BOB [2] - 273:16
BOOK [1] - 285:7
BOOKKEEPING [1] - 266:10
BORNE [1] - 275:17
BORROWER [10] - 242:17, 242:20,
244:25, 245:21, 246:5, 246:16, 247:2,
247:15, 249:3, 249:11
BORROWER'S [1] - 248:8
BORROWERS [2] - 244:18, 247:24
BORROWING [1] - 185:21
BOTTOM [7] - 174:24, 179:4, 180:15,
202:22, 227:25, 230:10
BOULEE [1] - 160:10
BPGINTAKECOORDINATOR@GMAIL
.COM [1] - 261:18
BREAK [10] - 209:17, 215:12, 271:12,
271:13, 271:17, 271:23, 278:16,
283:14, 283:17
BREAKS [1] - 271:19
BRENDA [11] - 255:2, 255:10, 257:3,
257:8, 262:1, 263:11, 263:19, 275:20,
275:21, 275:24, 305:21
BRIEF [2] - 163:8, 309:9
BRIEFING [1] - 304:20
BRIEFS [1] - 311:9
BRING [7] - 163:2, 224:15, 271:14,
276:23, 276:24, 292:23, 297:11
BRINGS [1] - 262:8
BROKE [1] - 277:14
BUNCH [1] - 222:4
BUSINESS [34] - 172:7, 174:4, 174:5,
178:23, 179:16, 182:3, 182:4, 197:22,
198:1, 199:16, 200:12, 200:20,
212:12, 213:25, 214:5, 239:19, 240:2,
241:10, 243:5, 243:6, 243:16, 244:25,
246:18, 248:9, 248:13, 248:21, 262:5,
280:17, 287:25, 289:13, 290:7, 291:3,
291:11
BUSINESSES [15] - 165:3, 167:19,
174:7, 174:9, 174:14, 174:18, 179:2,
181:4, 188:18, 198:2, 200:22, 212:21,
212:23, 212:24, 214:16
BUT.. [1] - 278:25
BY [107] - 1:4, 1:6, 160:23, 164:5,
164:14, 164:22, 165:8, 165:24,
166:11, 167:7, 167:17, 168:2, 168:16,
168:24, 169:14, 170:10, 171:3, 171:8,
171:19, 172:11, 172:18, 173:4,
173:11, 173:23, 174:13, 174:22,
175:2, 175:11, 175:21, 176:5, 176:13,
177:8, 178:5, 179:1, 179:11, 179:21,
180:6, 180:14, 181:7, 181:17, 182:8,
182:22, 183:14, 183:23, 184:6,
184:11, 184:18, 185:2, 185:18, 186:5,
186:13, 186:19, 186:25, 187:15,
187:23, 188:4, 188:11, 189:6, 190:21,
191:10, 192:19, 193:4, 193:12,
315
193:18, 194:24, 195:7, 195:16, 196:3,
197:4, 197:18, 198:10, 198:20, 200:5,
201:9, 202:17, 203:22, 206:17,
207:11, 207:25, 208:12, 210:16,
213:16, 214:4, 214:14, 216:5, 224:16,
227:21, 228:8, 228:20, 230:5, 231:8,
232:5, 232:11, 234:1, 234:12, 235:9,
236:11, 238:21, 239:5, 253:2, 253:12,
257:2, 261:15, 263:9, 265:20, 277:13,
281:18
C
CAFETERIA [1] - 164:1
CANDACE [2] - 170:2, 190:15
CANNOT [1] - 299:22
CAPACITY [1] - 262:6
CAPITALIZATION [1] - 190:6
CARD [16] - 174:6, 195:8, 199:1, 199:6,
201:18, 202:24, 202:25, 203:2, 208:7,
227:15, 227:22, 227:23, 228:4, 228:9,
228:11, 229:6
CARDS [7] - 199:8, 199:10, 199:12,
200:11, 200:15, 201:3, 201:12
CAREER [1] - 220:3
CARLA [2] - 160:6, 160:20
CARLA [15] - 228:1, 229:13, 230:12,
233:4, 233:13, 233:15, 233:16,
234:19, 235:1, 235:2, 235:4, 235:14,
236:6, 236:13, 236:25
CAROLINA [1] - 279:23
CASE [59] - 216:11, 216:14, 216:20,
217:2, 217:7, 217:15, 217:20, 217:23,
218:17, 232:24, 238:24, 239:6,
241:14, 242:12, 250:2, 259:1, 261:6,
268:10, 268:14, 268:22, 269:13,
269:14, 270:24, 271:9, 272:8, 272:11,
272:23, 275:8, 275:12, 279:13, 281:3,
281:24, 282:3, 282:20, 282:21,
283:20, 283:22, 283:24, 283:25,
284:1, 286:2, 298:1, 299:22, 300:3,
301:17, 301:25, 302:11, 302:15,
303:4, 307:13, 307:24, 308:13,
308:22, 309:3, 309:4, 309:20, 311:10,
312:8
CASES [2] - 305:14, 310:24
CASH [2] - 193:14, 193:25
CASH [4] - 193:14, 193:25, 198:5, 198:8
CASHIER'S [3] - 234:14, 235:11, 236:12
CATCH [1] - 259:24
CAUTIOUS [2] - 311:2, 311:4
CDC [12] - 280:16, 287:25, 288:9,
289:12, 289:24, 290:6, 291:2, 291:8,
291:10, 291:14, 295:9
CELL [18] - 203:5, 203:6, 203:8, 203:9,
207:3, 217:12, 218:2, 298:19, 298:23,
299:1, 299:7, 299:17, 300:11, 300:12,
300:15, 300:16, 301:7, 302:8
CEO [9] - 254:1, 254:7, 254:11, 255:3,
255:12, 255:19, 258:20, 262:2, 262:5
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 157 of 174
CERTAIN [2] - 212:21, 238:24
CERTAINLY [3] - 304:16, 309:22, 310:1
CERTIFICATION [1] - 266:20
CERTIFIED [4] - 234:7, 234:9, 266:17,
266:18
CERTIFY [1] - 312:6
CERTIFYING [1] - 211:3
CETERA [6] - 273:19, 273:20, 273:24
CFO [2] - 254:1, 254:23
CHAIKEN [22] - 164:2, 204:20, 206:4,
258:7, 260:6, 260:8, 261:7, 272:3,
274:17, 276:7, 276:17, 284:3, 284:20,
289:15, 289:19, 290:4, 291:12,
291:22, 294:21, 306:5, 309:1, 311:3
CHAIKEN [228] - 160:14, 163:4, 163:7,
163:17, 164:3, 164:5, 164:12, 164:14,
164:20, 164:22, 165:6, 165:8, 165:21,
165:24, 166:10, 166:11, 167:4, 167:7,
167:15, 167:17, 168:1, 168:2, 168:15,
168:16, 168:23, 168:24, 169:13,
169:14, 169:22, 170:8, 170:10, 171:1,
171:3, 171:7, 171:8, 171:17, 171:19,
172:10, 172:11, 172:16, 172:18,
173:3, 173:4, 173:9, 173:11, 173:22,
173:23, 174:11, 174:13, 174:20,
174:22, 175:1, 175:2, 175:10, 175:11,
175:20, 175:21, 176:3, 176:5, 176:11,
176:13, 177:6, 177:8, 178:3, 178:5,
178:25, 179:1, 179:9, 179:11, 179:20,
179:21, 180:5, 180:6, 180:13, 180:14,
181:6, 181:7, 181:15, 181:17, 182:7,
182:8, 182:20, 182:22, 183:13,
183:14, 183:22, 183:23, 184:5, 184:6,
184:9, 184:11, 184:17, 184:18,
184:25, 185:2, 185:15, 185:18, 186:4,
186:5, 186:12, 186:13, 186:18,
186:19, 186:23, 186:25, 187:14,
187:15, 187:22, 187:23, 188:3, 188:4,
188:9, 188:11, 189:2, 189:4, 189:6,
190:14, 190:19, 190:21, 191:9,
191:10, 192:15, 192:18, 192:19,
193:3, 193:4, 193:10, 193:12, 193:16,
193:18, 194:4, 194:13, 194:18,
194:21, 194:24, 195:5, 195:7, 195:15,
195:16, 196:2, 196:3, 196:19, 196:22,
197:2, 197:4, 197:16, 197:18, 198:6,
198:10, 198:17, 198:20, 199:24,
200:5, 201:6, 201:9, 202:9, 202:16,
202:17, 203:20, 203:22, 204:1,
204:21, 205:4, 205:12, 206:8, 206:14,
206:16, 206:17, 207:9, 207:11,
207:22, 207:25, 208:10, 208:12,
208:23, 208:25, 209:3, 209:5, 209:7,
252:22, 256:3, 256:13, 258:3, 258:9,
258:19, 259:4, 260:3, 260:9, 260:16,
261:9, 263:6, 265:16, 271:4, 271:8,
274:19, 280:19, 281:6, 282:8, 284:4,
284:23, 285:2, 285:9, 285:14, 286:7,
286:14, 288:13, 291:25, 292:10,
294:22, 297:4, 297:23, 298:3, 298:5,
298:12, 298:18, 299:24, 300:14,
300:17, 300:19, 301:1, 301:16,
303:10, 304:19, 306:6, 306:10, 307:4,
309:2, 310:19
CHAIKEN'S [4] - 256:12, 287:2, 292:15,
295:20
CHALLENGE [1] - 205:16
CHALLENGING [1] - 205:20
CHANGE [5] - 169:3, 169:7, 175:16,
183:4, 183:6
CHANGED [4] - 165:17, 165:18, 172:4,
183:10
CHARACTER [1] - 260:18
CHARGE [1] - 308:12
CHARGED [41] - 204:6, 238:25, 239:6,
239:11, 240:5, 240:6, 240:8, 241:6,
242:12, 242:23, 242:25, 243:8,
267:25, 275:1, 275:2, 275:13, 284:17,
294:16, 295:8, 304:24, 304:25, 305:3,
305:20, 306:12, 306:15, 307:6, 307:7,
307:11, 307:17, 307:20, 307:22,
307:23, 308:1, 308:13, 308:15,
308:22, 309:14, 309:20
CHARGES [3] - 261:2, 305:1, 308:18
CHARGING [2] - 307:5, 307:13
CHARLES [4] - 243:14, 243:15, 246:25,
247:1
CHARMAINE [5] - 245:4, 245:19,
245:20, 279:1, 308:10
CHARMAINE'S [1] - 279:10
CHATS [1] - 273:11
CHECK [19] - 174:5, 192:20, 193:8,
195:2, 195:20, 196:13, 197:5, 197:6,
197:11, 212:20, 232:16, 234:18,
235:2, 235:5, 235:8, 235:17, 236:12,
236:22, 237:1
CHECKLIST [1] - 240:11
CHECKS [6] - 199:11, 234:7, 234:10,
234:14, 235:11
CHOICE [1] - 213:8
CHOSE [2] - 209:16, 307:12
CHRISTIAN [26] - 243:2, 243:3, 246:21,
249:13, 279:22, 281:21, 281:23,
284:14, 284:21, 284:22, 286:16,
287:12, 288:16, 288:20, 288:21,
292:2, 292:3, 292:6, 292:9, 292:12,
294:16, 295:3, 295:5, 295:8, 295:12,
308:9
CHRISTIAN [1] - 291:18
CIRCLE [1] - 279:12
CIRCLES [1] - 205:11
CIRCUIT [2] - 259:6, 305:9
CITATIONS [1] - 310:24
CITE [1] - 1:5
CITED [1] - 305:14
CITY [1] - 225:15
CLAUSE [2] - 305:11, 308:24
CLEAR [12] - 191:7, 214:15, 265:21,
281:11, 294:23, 295:24, 302:20,
305:10, 305:11, 305:17, 306:1, 310:19
316
CLEARLY [1] - 282:18
CLIENT [3] - 237:24, 304:13, 310:15
CLOSE [2] - 244:15, 271:12
CLOSED [2] - 204:25, 295:3
CLOSING [1] - 301:17
CLOSINGS [1] - 300:4
CM/ECF [2] - 1:3, 1:5
CO [6] - 276:3, 304:23, 305:12, 305:20,
306:1, 306:22
CO-CONSPIRATORS [1] - 276:3
CO-COUNSEL'S [1] - 306:22
CO-DEFENDANTS [1] - 305:20
CO-DEFENDANTS' [3] - 304:23,
305:12, 306:1
COAST [1] - 297:9
COLLECTED [2] - 240:12, 240:21
COLLECTING [1] - 240:22
COLLECTIVELY [1] - 298:15
COLLECTOR [1] - 240:10
COLUMN [2] - 225:12, 225:16
COLUMNS [1] - 225:12
COMCAST [1] - 225:5
COMFORT [4] - 215:12, 271:13, 271:17,
271:22
COMFORTABLE [1] - 220:12
COMING [4] - 253:7, 266:22, 289:4,
296:9
COMMENT [1] - 232:19
COMMISSIONER [1] - 211:1
COMMUNICATE [9] - 189:20, 246:6,
246:7, 247:7, 247:16, 274:4, 307:18,
307:19, 308:4
COMMUNICATED [3] - 246:8, 247:24,
306:12
COMMUNICATING [35] - 168:10,
169:10, 177:18, 181:12, 182:18,
189:16, 191:24, 207:12, 233:5,
239:23, 240:1, 240:3, 245:23, 246:20,
246:21, 247:4, 247:5, 247:19, 248:5,
248:6, 249:12, 249:14, 266:21,
272:12, 273:1, 273:2, 273:4, 274:3,
277:20, 277:21, 277:24, 278:24,
279:5, 308:8, 308:10
COMMUNICATION [14] - 183:20,
185:24, 190:1, 190:8, 241:11, 243:18,
244:1, 244:10, 245:12, 246:10,
247:11, 263:10, 268:6, 272:24
COMMUNICATIONS [19] - 188:20,
206:18, 229:13, 233:8, 233:13, 235:1,
235:4, 236:5, 236:24, 246:22, 247:9,
247:20, 249:8, 249:16, 250:8, 250:9,
250:10, 267:24, 307:24
COMPANIES [11] - 199:6, 200:12,
213:9, 213:11, 213:13, 214:19,
214:22, 251:22, 251:25, 252:9
COMPANY [12] - 173:19, 199:1, 199:6,
199:9, 199:19, 231:16, 231:20,
231:21, 234:23, 242:22, 251:16,
251:19
COMPLETE [1] - 290:17
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 158 of 174
COMPLETELY [2] - 271:11, 274:21
COMPLEXES [1] - 262:9
COMPUTERS [3] - 217:16, 217:18,
218:7
CONCEDING [1] - 292:7
CONCERNED [1] - 296:10
CONCERTED [1] - 274:23
CONDUCT [1] - 212:16
CONDUCTED [3] - 268:11, 294:24,
294:25
CONFERENCE [2] - 304:21, 307:1
CONFIRM [3] - 267:22, 279:7, 280:10
CONFLICT [2] - 163:8, 296:18
CONFORMITY [1] - 260:17
CONFRONT [1] - 278:11
CONFRONTATION [2] - 305:10, 308:24
CONFRONTED [2] - 273:6, 275:6
CONSENTS [1] - 163:13
CONSEQUENCES [1] - 208:21
CONSIDER [3] - 240:23, 308:17, 310:1
CONSIDERATION [1] - 307:8
CONSIDERED [3] - 212:8, 240:25,
310:3
CONSIDERING [1] - 308:19
CONSISTENT [2] - 197:13, 275:12
CONSPIRACIES [1] - 204:6
CONSPIRACY [1] - 309:16
CONSPIRATORS [1] - 276:3
CONSPIRING [2] - 284:17, 308:1
CONSTITUTIONAL [1] - 308:24
CONSTRUCTION [2] - 237:8, 262:5
CONSULTING [5] - 195:3, 195:9,
195:18, 196:16, 197:6
CONT'D)................232 [1] - 162:5
CONTACT [2] - 179:17, 236:6
CONTENTS [1] - 282:6
CONTINUE [2] - 192:4, 207:12
CONTINUED [8] - 192:1, 204:23, 205:5,
205:13, 215:15, 262:7, 272:1, 311:15
CONTINUING [3] - 174:16, 213:4,
246:16
CONTRACTS [1] - 222:2
CONTROLLED [1] - 252:3
CONVERSATION [4] - 168:3, 196:24,
272:15, 290:13
CONVERSATIONS [1] - 192:25
CONVINCED [1] - 206:4
COOPER [3] - 166:3, 166:6, 166:8
COORDINATOR [3] - 210:23, 210:24,
210:25
COPIED [1] - 229:25
COPIES [1] - 188:16
COPY [7] - 206:12, 258:5, 261:13,
285:1, 285:19, 285:23, 308:14
CORNER [2] - 185:17, 253:23
CORP [1] - 185:22
CORPORATE [1] - 199:1
CORPORATION [2] - 199:16, 249:2
CORRECT [117] - 185:11, 189:1, 204:19,
207:5, 214:16, 216:12, 216:13,
216:25, 217:9, 217:13, 217:16,
217:18, 217:22, 218:2, 218:5, 218:14,
218:20, 218:21, 218:24, 219:11,
220:20, 221:8, 222:1, 222:11, 222:12,
222:21, 222:22, 223:20, 224:8,
225:17, 226:13, 226:16, 226:18,
226:19, 226:22, 227:3, 227:4, 227:5,
229:8, 230:11, 230:18, 230:19,
231:16, 232:21, 232:22, 232:24,
233:10, 233:16, 233:20, 234:16,
235:11, 236:2, 236:3, 241:15, 241:18,
241:23, 241:24, 242:13, 242:14,
245:8, 248:14, 249:7, 249:21, 249:24,
250:13, 250:15, 251:15, 251:17,
251:24, 252:10, 253:18, 253:19,
254:18, 254:20, 254:23, 254:24,
254:25, 255:4, 255:18, 255:21, 259:4,
261:19, 261:21, 262:2, 263:11,
263:20, 264:14, 265:22, 266:4,
266:12, 266:13, 266:17, 268:17,
269:12, 269:16, 270:9, 270:10,
270:20, 277:15, 277:18, 277:20,
278:9, 278:21, 278:22, 279:6, 279:14,
279:18, 279:21, 281:25, 292:9,
292:18, 293:4, 302:24, 302:25, 303:1,
306:5, 312:7
CORRECTED [1] - 178:15
CORRECTLY [1] - 244:14
CORRESPONDED [2] - 245:7, 245:10
COUDRIET [2] - 160:24, 312:15
COUNSEL [2] - 209:24, 304:11
COUNSEL [5] - 163:10, 237:16, 269:1,
298:21, 310:17
COUNSEL'S [1] - 306:22
COUNT [2] - 239:12, 294:16
COUNTS [1] - 307:23
COUPLE [6] - 214:18, 216:21, 220:22,
226:7, 293:2, 293:24
COURSE [8] - 199:2, 209:4, 212:1,
213:25, 260:25, 286:1, 293:8, 294:1
COURT [168] - 1:4, 1:7, 1:10, 160:1,
160:24, 160:25, 163:1, 163:2, 163:5,
163:16, 163:19, 163:21, 163:23,
170:4, 170:7, 190:18, 194:9, 194:11,
194:14, 194:20, 194:22, 195:1, 197:1,
200:4, 202:15, 204:7, 204:9, 204:17,
204:20, 204:25, 205:10, 205:19,
206:2, 206:11, 206:15, 209:2, 209:4,
209:9, 209:24, 210:2, 210:5, 210:7,
210:9, 215:3, 215:7, 215:11, 215:19,
215:21, 215:24, 231:6, 238:18,
252:24, 256:5, 256:11, 256:14,
256:18, 256:22, 258:5, 258:7, 258:17,
259:2, 259:11, 259:24, 260:2, 260:5,
260:13, 261:7, 261:11, 261:14, 263:7,
265:17, 271:12, 271:21, 272:2,
272:16, 272:18, 272:20, 273:15,
274:11, 274:17, 276:6, 277:3, 277:6,
277:9, 280:24, 281:10, 281:14,
317
282:15, 282:23, 283:6, 283:13,
283:22, 283:24, 284:3, 284:5, 284:8,
284:12, 284:19, 284:24, 285:6,
285:12, 286:5, 286:12, 286:18,
286:22, 287:1, 287:22, 288:4, 289:11,
289:25, 290:2, 290:12, 290:20, 291:1,
291:6, 291:9, 291:17, 291:22, 292:5,
292:13, 293:8, 293:10, 293:17,
293:20, 293:22, 294:3, 294:6, 294:9,
294:21, 295:17, 296:1, 296:3, 296:19,
297:2, 297:14, 297:21, 298:9, 298:16,
298:21, 299:4, 299:13, 300:7, 300:16,
300:18, 300:20, 301:10, 301:13,
301:22, 302:2, 302:4, 302:19, 303:1,
303:3, 303:22, 304:8, 304:10, 304:16,
306:3, 306:18, 306:24, 308:12, 309:1,
310:6, 310:11, 310:22, 311:1, 312:3,
312:15
COURT [5] - 210:23, 210:24, 210:25,
220:20, 289:4
COURT [5] - 163:11, 275:13, 287:16,
305:17, 309:23
COURTHOUSE [2] - 163:18, 164:1
COURTROOM [10] - 163:20, 194:23,
215:23, 231:7, 271:20, 272:17, 277:8,
283:5, 283:10, 283:12
COVERS [1] - 204:4
CREATED [2] - 167:24, 258:20
CREATING [1] - 190:12
CREATION [1] - 202:25
CREATIONS [2] - 213:1, 241:10
CREDIT [1] - 259:17
CRIME [2] - 294:17, 307:20
CRIMES [1] - 275:1
CROMER [2] - 218:22, 223:2
CROSS [14] - 163:11, 209:15, 209:20,
215:3, 215:17, 276:25, 297:21,
298:13, 298:22, 298:24, 298:25,
299:12, 300:8, 301:3
CROSS [2] - 216:4, 238:20
CROSS-EXAMINATION [4] - 209:20,
215:3, 215:17, 300:8
CROSS-EXAMINATION [2] - 216:4,
238:20
CROSS-EXAMINE [1] - 209:15
CROSSING [2] - 299:15, 301:4
CRR [2] - 160:24, 312:15
CURIOUS [1] - 217:23
CURRENT [1] - 210:23
CURSE [1] - 190:11
CUSTODIAL [1] - 211:2
CUSTOM [1] - 184:21
CUSTOMS [6] - 183:12, 183:18, 184:14,
213:5, 245:5, 247:15
CUT [3] - 256:11, 263:14, 276:16
CUTS [1] - 213:8
CUTTING [1] - 199:11
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 159 of 174
D
DAILY [1] - 192:9
DARRELL [154] - 164:17, 165:9, 166:2,
167:8, 168:5, 168:9, 168:12, 168:19,
169:10, 170:11, 170:14, 170:24,
171:11, 172:14, 173:6, 173:24, 174:2,
175:5, 175:23, 176:7, 177:9, 177:17,
178:8, 178:18, 179:7, 179:12, 179:22,
180:16, 181:2, 181:10, 181:12,
181:18, 182:12, 182:18, 182:24,
183:2, 183:17, 183:19, 184:12,
184:20, 185:8, 185:19, 185:23, 186:7,
186:21, 187:18, 188:7, 188:20, 189:8,
189:11, 189:16, 189:23, 189:24,
190:4, 190:6, 190:9, 190:22, 191:4,
191:11, 191:19, 191:24, 192:1, 192:8,
192:13, 198:4, 198:21, 199:15,
199:19, 204:15, 208:6, 208:17, 217:5,
217:20, 239:15, 239:17, 241:11,
241:17, 243:4, 243:16, 243:23,
244:17, 245:8, 245:10, 246:1, 246:23,
247:7, 247:10, 247:19, 247:20,
247:23, 248:5, 248:12, 248:22,
248:23, 249:1, 249:8, 249:17, 249:25,
250:10, 251:10, 251:13, 252:3,
253:18, 254:3, 254:22, 255:6, 255:17,
256:8, 257:23, 258:12, 258:13,
258:24, 259:13, 261:21, 264:6, 264:7,
264:10, 264:25, 265:5, 265:22, 266:8,
266:15, 266:21, 267:1, 267:4, 267:7,
267:25, 268:6, 268:9, 273:3, 273:4,
273:7, 273:8, 274:3, 274:10, 275:16,
275:22, 277:20, 278:24, 279:5, 305:2,
306:13, 306:14, 307:16, 307:18,
307:19, 308:4, 308:8, 309:7, 309:14,
309:17, 309:18, 310:5
DARRELL'S [2] - 250:21, 251:16
DATA [1] - 212:5
DATE [27] - 166:24, 168:7, 170:17,
170:19, 177:1, 177:23, 178:16, 182:9,
184:7, 189:14, 195:23, 198:11,
198:14, 204:11, 204:16, 206:21,
224:2, 224:6, 226:6, 228:4, 228:9,
231:12, 231:13, 253:24, 253:25
DATED [1] - 228:25
DATES [7] - 203:9, 204:6, 204:10,
224:24, 226:5, 226:10, 231:18
DAVID [2] - 246:15, 246:16
DAVID [1] - 160:20
DAYS [2] - 182:14, 223:1
DAYS [1] - 1:5
DEBATE [2] - 271:23, 296:8
DEBIT [2] - 199:8, 199:12
DECEMBER [3] - 176:19, 176:21,
254:16
DECENT [2] - 215:11, 245:12
DECIDE [2] - 276:22, 299:14
DECIDED [1] - 295:11
DECISIONS [2] - 307:6, 307:13
DECLARANT'S [1] - 289:4
DEE [5] - 244:15, 247:5, 247:6, 247:8
DEFENDANT [2] - 160:17, 160:20
DEFENDANT [1] - 295:5
DEFENDANT'S [2] - 262:20, 263:4
DEFENDANT'S [1] - 295:4
DEFENDANTS [3] - 302:4, 304:17,
305:20
DEFENDANTS [1] - 160:8
DEFENDANTS' [3] - 304:23, 305:12,
306:1
DEFENSE [15] - 163:10, 205:16, 209:14,
259:19, 259:20, 273:10, 295:7,
298:21, 300:3, 302:4, 304:22, 307:12,
309:7, 309:10, 310:4
DEFENSES [1] - 301:18
DEFINITELY [3] - 194:17, 220:15,
255:19
DELIGHTFUL [1] - 163:25
DENESSERIA [1] - 244:13
DENIED [2] - 278:23, 280:4
DEPOSIT [9] - 193:8, 199:7, 228:18,
229:2, 229:14, 229:19, 232:8, 233:8,
233:12
DEPOSITED [5] - 195:20, 195:23,
197:11, 232:16, 279:25
DEPOSITS [5] - 200:13, 228:22, 232:14,
232:15, 234:13
DEREK [6] - 179:18, 245:3, 246:3,
246:8, 246:12
DESCRIBE [4] - 190:3, 190:25, 239:16,
239:21
DESCRIBING [1] - 191:2
DESCRIPTION [1] - 198:14
DESKTOP [2] - 217:16, 218:7
DESPITE [1] - 307:13
DETAILS [1] - 220:23
DETERMINE [5] - 191:23, 199:2,
231:12, 307:10, 309:24
DEVELOP [1] - 262:7
DEVELOPER [1] - 262:2
DEVELOPMENT [1] - 262:5
DEVICES [7] - 217:10, 217:11, 217:18,
217:25, 218:10, 218:11, 218:13
DICTATE [1] - 248:6
DIFFERENCE [1] - 190:1
DIFFERENT [23] - 169:17, 173:18,
173:20, 182:2, 182:4, 182:5, 198:14,
200:9, 209:19, 224:13, 228:11,
232:24, 282:9, 284:6, 284:7, 285:4,
286:20, 288:1, 288:22, 293:24,
300:22, 306:25, 310:16
DIFFERENTLY [1] - 191:19
DIGITAL [1] - 217:18
DIRE [1] - 162:4
DIRECT [7] - 163:11, 185:24, 209:14,
221:21, 241:11, 248:7, 297:19
DIRECT [4] - 162:4, 162:5, 164:4,
210:15
DIRECTED [3] - 221:18, 258:12, 306:4
318
DIRECTION [1] - 294:24
DIRECTLY [8] - 168:10, 169:10, 191:24,
246:22, 247:10, 259:21, 307:16, 308:8
DIRECTOR [1] - 206:9
DISAGREE [1] - 264:8
DISCOVERY [2] - 290:23, 290:25
DISCUSS [3] - 229:18, 263:25, 271:14
DISCUSSED [2] - 163:10, 266:8
DISCUSSES [1] - 266:11
DISCUSSING [4] - 229:19, 251:21,
266:7, 296:5
DISCUSSION [2] - 163:22, 215:22
DISSOLVED [2] - 255:22, 255:23
DISTANCE [1] - 309:14
DISTRIBUTE [2] - 200:8, 200:11
DISTRIBUTED [1] - 200:15
DISTRICT [6] - 160:1, 160:1, 160:10,
160:25, 312:3, 312:4
DIVISION [1] - 160:2
DIVISIONS [1] - 262:4
DIVORCE [1] - 223:24
DIXON [34] - 244:23, 244:24, 245:7,
245:10, 245:15, 245:23, 246:7, 246:9,
247:17, 264:4, 265:1, 265:5, 265:24,
266:14, 266:21, 267:24, 268:8,
269:15, 270:22, 271:6, 271:9, 271:10,
272:7, 272:8, 272:11, 272:21, 273:6,
274:6, 274:20, 275:6, 277:15, 278:23,
308:5, 308:9
DL [1] - 174:5
DOCKET [2] - 1:6, 160:5
DOCUMENT [36] - 167:8, 167:11,
167:12, 169:20, 180:16, 180:18,
182:14, 183:1, 199:14, 204:12,
206:12, 213:17, 213:18, 214:1, 214:6,
214:9, 227:19, 231:10, 234:17, 253:3,
253:13, 254:15, 256:12, 258:5,
258:17, 261:25, 262:22, 263:10,
263:12, 266:14, 282:12, 282:14,
290:8, 290:16, 290:24, 291:17
DOCUMENT [1] - 1:10
DOCUMENT'S [1] - 256:16
DOCUMENTATION [1] - 221:3
DOCUMENTS [28] - 165:15, 170:20,
172:3, 172:4, 175:15, 179:7, 181:3,
183:9, 185:10, 187:8, 188:24, 188:25,
195:1, 213:20, 213:22, 214:16, 221:5,
240:10, 240:20, 240:22, 243:12,
252:16, 257:17, 257:22, 258:23,
261:1, 265:11, 295:3
DOG [1] - 306:21
DOLLARS [1] - 208:9
DONE [10] - 217:20, 219:14, 220:2,
230:7, 285:3, 286:11, 296:14, 297:5,
297:10, 301:9
DOOR [6] - 220:8, 221:9, 222:18,
304:22, 305:23, 309:4
DOOR'S [1] - 305:6
DOT [1] - 199:16
DOUBLE [1] - 292:18
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 160 of 174
DOUBT [1] - 275:22
DOWN [36] - 166:10, 174:8, 174:11,
179:4, 180:15, 186:24, 191:9, 193:10,
201:7, 207:9, 209:22, 215:7, 225:17,
227:24, 228:15, 230:2, 230:9, 232:8,
233:21, 233:24, 234:9, 234:10,
235:20, 235:21, 236:17, 272:7,
272:16, 276:13, 276:14, 281:4,
283:14, 283:18, 290:18, 290:19,
296:9, 312:7
DR [1] - 297:22
DRAW [1] - 301:21
DUE [1] - 308:24
DULUTH [1] - 255:7
DULY [1] - 210:12
DURING [19] - 192:5, 199:2, 205:7,
205:14, 207:6, 207:16, 212:20, 218:5,
220:19, 222:7, 225:1, 237:9, 237:17,
238:2, 252:5, 255:6, 261:2, 269:23,
281:19
DURRETT [2] - 160:18, 215:4
DUTIES [1] - 282:2
DWAN [3] - 248:17, 248:18, 255:11
DWIGHT [2] - 237:21, 237:23
E
E-MAIL [70] - 164:16, 164:23, 166:1,
166:12, 167:18, 168:18, 168:20,
171:10, 171:15, 171:21, 172:13,
172:20, 173:6, 173:13, 175:4, 175:7,
175:13, 175:23, 176:1, 176:7, 177:23,
178:7, 179:22, 181:9, 182:9, 182:14,
182:15, 182:17, 183:16, 183:24,
184:7, 184:20, 185:3, 186:7, 186:14,
186:21, 187:1, 187:17, 187:24, 188:6,
188:12, 229:13, 229:16, 229:18,
229:21, 229:23, 229:25, 232:23,
233:3, 233:11, 235:1, 236:4, 241:2,
241:3, 241:17, 241:20, 241:25, 242:3,
242:6, 249:17, 259:21, 261:16,
262:24, 263:22, 264:25, 265:5,
265:21, 268:5, 276:1
E-MAILS [21] - 191:23, 229:11, 229:17,
233:7, 241:14, 242:9, 245:12, 246:2,
249:16, 249:19, 250:12, 257:7, 257:8,
257:24, 261:1, 263:1, 263:24, 263:25,
268:8, 273:11, 275:24
EARLIEST [1] - 206:21
EASIER [1] - 263:12
EASLEY [1] - 305:16
EDUCATION [12] - 164:7, 165:18,
165:20, 166:16, 167:13, 167:21,
168:21, 170:20, 171:23, 213:6, 247:2,
247:3
EDWARD [3] - 245:3, 264:15, 265:7
EFFECT [7] - 223:9, 294:13, 294:19,
295:14, 295:19, 295:22, 295:25
EFFECTIVE [1] - 231:13
EFFORT [3] - 217:24, 218:13, 274:23
EFFORTS [3] - 273:12, 274:9, 282:22
EIN [4] - 165:19, 167:14, 174:5, 179:19
EITHER [6] - 194:14, 217:24, 228:16,
265:18, 294:12, 310:7
EL [2] - 249:3, 249:5
ELEVENTH [2] - 259:5, 305:9
ELITE [4] - 197:19, 197:22, 198:4,
200:17
ELMO [1] - 253:1
EMBEDDED [1] - 166:12
EMPLOYEE [5] - 173:20, 173:21,
240:23, 295:9, 300:18
EMPLOYEES [5] - 166:16, 199:8,
199:11, 212:9, 266:7
EMPLOYEES' [2] - 199:12, 211:12
EMPLOYER [1] - 211:11
EMPLOYERS [1] - 211:20
END [8] - 176:20, 278:21, 294:23,
295:14, 296:25, 299:18, 301:8, 303:7
ENDED [5] - 166:22, 167:2, 177:4,
273:9, 294:16
ENDING [3] - 180:20, 235:25, 236:19
ENGAGED [1] - 258:24
ENJOYING [1] - 163:25
ENTERED [7] - 163:20, 215:23, 232:6,
232:20, 234:13, 234:25, 277:8
ENTERPRISE [1] - 234:21
ENTIRE [3] - 281:3, 286:2, 301:24
ENTIRELY [3] - 209:19, 259:19, 303:20
ENTIRETY [4] - 282:21, 287:21, 291:20,
293:25
ENTITLED [2] - 294:18, 308:1
ENTRIES [1] - 226:3
ENTRY [3] - 230:10, 230:12
ENTRY [1] - 1:6
EQUIPMENT [1] - 264:1
EQUIVALENT [1] - 259:8
ESPECIALLY [3] - 226:24, 258:15,
273:5
ESQ [6] - 160:14, 160:15, 160:15,
160:18, 160:18, 160:20
ESTABLISH [3] - 260:22, 281:16,
288:21
ESTABLISHED [3] - 225:4, 285:12,
286:9
ESTATE [6] - 220:24, 221:5, 221:12,
221:23, 237:7, 262:1
ESTIMATE [2] - 297:16, 298:14
ESTIMATED [1] - 301:1
ET [6] - 273:19, 273:20, 273:24
ETA [1] - 184:14
EVENING [5] - 277:1, 283:1, 283:4,
304:11, 311:13
EVENT [1] - 309:5
EVENTS [2] - 271:1, 271:3
EVENTUALLY [1] - 276:16
EVIDENCE [1] - 283:19
EVIDENCE [28] - 191:22, 216:9, 223:22,
224:18, 229:11, 232:6, 243:18, 244:1,
319
244:10, 246:10, 246:22, 247:18,
256:17, 259:14, 259:22, 260:1,
260:12, 260:17, 273:12, 274:21,
275:9, 275:18, 275:20, 293:7, 293:12,
294:15, 295:7, 306:6
EXACT [2] - 213:13, 224:6
EXACTLY [9] - 180:12, 240:7, 240:8,
244:22, 260:19, 285:18, 291:3,
293:12, 305:4
EXAMINATION [5] - 162:5, 164:4,
210:15, 216:4, 238:20
EXAMINATION [6] - 209:14, 209:20,
215:3, 215:17, 298:19, 300:8
EXAMINATION.........................142 [1] -
162:4
EXAMINATION......................218 [1] -
162:4
EXAMINE [1] - 209:15
EXAMINED [1] - 210:13
EXAMPLE [2] - 268:4, 279:22
EXAMPLES [2] - 273:25, 274:1
EXCEPT [2] - 173:19, 301:14
EXCHANGING [1] - 181:3
EXCLUSIVE [5] - 195:3, 195:8, 195:17,
196:16, 197:6
EXCLUSIVELY [1] - 273:2
EXCUSED [3] - 209:23, 215:10, 272:14
EXECUTED [1] - 216:25
EXECUTIVE [4] - 197:19, 197:22, 198:5,
200:17
EXHIBIT [15] - 168:17, 174:25, 191:2,
204:4, 224:17, 225:1, 227:11, 227:14,
228:22, 232:6, 234:2, 234:4, 258:10,
261:3, 289:25
EXHIBIT [28] - 164:13, 165:22, 165:25,
183:15, 192:17, 195:6, 196:20,
196:21, 197:3, 197:17, 201:7, 202:1,
202:10, 203:21, 204:2, 207:24,
208:11, 208:24, 223:23, 224:15,
227:8, 228:14, 233:24, 239:3, 252:12,
252:21, 262:21, 263:4
EXHIBITS [4] - 194:5, 199:25, 201:25,
264:16
EXIST [1] - 293:18
EXITED [4] - 271:20, 272:17, 283:5,
283:12
EXOTIC [6] - 183:12, 183:18, 184:21,
213:4, 245:5, 247:15
EXPAND [1] - 258:7
EXPECT [2] - 207:16, 214:8
EXPERT [6] - 299:1, 300:15, 300:16,
301:7, 302:8, 302:12
EXPERTISE [1] - 262:8
EXPERTS [1] - 298:22
EXPLAIN [2] - 181:3, 210:24
EXPLANATION [1] - 260:10
EXTENDS [1] - 204:5
EXTENT [3] - 272:4, 276:8, 303:7
EXTRA [2] - 233:21, 297:20
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 161 of 174
F
F19 [2] - 257:10, 257:12
F19A [1] - 257:10
F20A [1] - 265:15
F20C [1] - 266:14
F20D [1] - 265:15
F408 [1] - 263:5
FACT [13] - 205:4, 205:20, 211:3, 230:9,
239:11, 277:23, 278:10, 283:9, 289:3,
295:15, 304:24, 310:20
FAILING [1] - 255:24
FAIR [3] - 292:15, 296:12, 298:2
FAIRLY [1] - 304:6
FAKE [4] - 243:11, 258:20, 275:22
FALSE [1] - 287:12
FALSELY [11] - 271:6, 275:16, 305:2,
305:3, 305:20, 308:5, 309:9, 309:11,
309:18, 310:5
FAMILIAR [5] - 211:5, 211:8, 211:16,
211:24, 278:2
FAR [9] - 258:12, 276:13, 276:14,
276:20, 276:22, 283:8, 284:19,
286:19, 298:16
FARGO [5] - 224:22, 224:23, 226:4,
227:2, 234:6
FBI [4] - 218:23, 220:5, 220:7, 300:19
FEBRUARY [1] - 160:11
FEBRUARY [3] - 180:20, 311:15, 312:9
FEDERAL [2] - 197:11, 197:13
FEDERAL [3] - 164:1, 211:20, 275:1
FEW [6] - 178:10, 184:22, 208:25,
209:3, 214:16, 304:4
FIGHT [1] - 306:22
FIGURE [1] - 290:9
FIGURED [3] - 226:23, 283:2, 291:15
FILE [3] - 211:20, 212:9, 213:11
FILED [3] - 1:3, 1:8, 1:10
FILED [15] - 211:6, 211:11, 211:14,
212:21, 213:12, 213:18, 214:6,
214:16, 214:21, 214:24, 224:4,
254:16, 307:5, 309:10
FILING [2] - 253:23, 253:25
FILINGS [1] - 213:13
FINALLY [1] - 187:11
FINANCE [4] - 291:8, 291:11, 291:14,
295:9
FINE [14] - 163:16, 215:19, 215:20,
228:13, 233:24, 233:25, 241:8,
256:21, 264:22, 284:20, 289:1,
289:20, 302:11, 303:11
FINGER [2] - 273:13, 275:4
FINISH [8] - 277:2, 296:24, 299:14,
300:1, 300:8, 301:4, 302:5, 302:21
FINISHING [1] - 299:12
FIRST [34] - 166:15, 166:19, 170:14,
175:8, 176:12, 204:10, 206:11,
206:13, 210:12, 215:17, 222:8,
227:10, 228:6, 251:19, 251:20,
265:21, 271:23, 274:12, 280:15,
281:7, 287:24, 288:15, 290:15,
290:17, 291:4, 291:20, 293:25, 295:9,
302:7, 303:22, 304:23, 307:21, 309:2
FIRSTHAND [1] - 280:22
FIVE [10] - 296:6, 297:6, 297:8, 298:10,
298:12, 298:17, 298:22, 299:5, 300:9,
302:8
FIX [1] - 177:20
FLIGHT [1] - 163:9
FLOOR [1] - 164:2
FLOW [1] - 248:7
FNU [1] - 280:15
FOLKS [1] - 282:24
FOLLOW [5] - 172:2, 187:7, 188:23,
256:7, 306:22
FOLLOW-UP [1] - 256:7
FOLLOWED [3] - 302:7, 302:8, 302:9
FOLLOWING [1] - 193:20
FOLLOWING [1] - 1:2
FOLLOWS [4] - 210:13, 215:15, 272:1,
311:15
FOR [2] - 1:5, 160:1
FOREGOING [1] - 312:6
FORM [6] - 166:24, 175:18, 211:11,
211:19, 290:25
FORM [12] - 166:15, 169:15, 171:23,
172:23, 178:14, 178:20, 180:8, 185:6,
188:14, 211:8, 211:16, 211:19
FORMED [2] - 231:1, 231:12
FORMS [10] - 165:4, 168:5, 168:13,
172:25, 176:6, 176:9, 180:10, 186:16,
187:3, 212:21
FORTH [3] - 213:14, 217:3, 233:9
FORWARD [2] - 164:18, 166:3
FOSTER [2] - 160:7, 160:17
FOSTER [144] - 164:16, 164:18, 164:19,
165:9, 166:1, 166:3, 166:5, 166:8,
167:9, 167:24, 168:6, 168:10, 168:14,
168:18, 169:1, 169:4, 169:9, 170:12,
170:22, 171:10, 172:13, 173:6,
173:25, 174:3, 175:4, 175:23, 177:13,
177:18, 177:20, 178:7, 178:18,
179:12, 180:16, 181:2, 181:9, 181:12,
182:17, 183:16, 183:19, 184:12,
184:20, 185:9, 185:19, 185:25,
186:21, 188:6, 188:21, 189:8, 189:11,
189:17, 189:20, 189:21, 189:24,
189:25, 190:9, 190:23, 191:11,
191:17, 191:20, 191:24, 191:25,
192:8, 192:12, 192:21, 193:5, 193:19,
195:12, 196:15, 197:5, 198:22,
199:15, 201:17, 201:18, 201:20,
202:8, 202:19, 203:1, 203:18, 203:19,
203:24, 204:22, 205:12, 206:19,
207:6, 207:7, 207:15, 207:17, 207:19,
208:1, 208:13, 208:19, 243:19, 244:2,
244:11, 246:11, 246:12, 248:15,
249:14, 249:19, 249:23, 250:18,
260:19, 267:2, 270:9, 271:7, 271:10,
271:11, 272:24, 273:2, 273:11,
320
273:13, 273:16, 273:18, 273:19,
274:3, 274:4, 274:10, 274:20, 274:23,
275:10, 276:5, 277:24, 279:9, 280:8,
280:15, 284:17, 286:16, 287:18,
287:24, 288:9, 291:15, 294:17, 295:8,
295:9, 295:11, 307:23, 308:6, 308:11,
308:20, 309:24
FOSTER'S [13] - 164:23, 190:4, 194:2,
203:5, 203:9, 207:3, 207:16, 239:11,
241:25, 249:17, 259:20, 309:7, 310:17
FOUNDATION [3] - 295:13, 295:18,
295:22
FOUNDER [1] - 233:18
FOUNDING [1] - 230:23
FOUR [4] - 177:24, 182:14, 211:14,
299:9
FOURTH [5] - 176:17, 176:20, 177:15,
178:14, 180:8
FRAME [7] - 202:21, 206:24, 207:2,
207:6, 256:4, 274:23, 275:11
FRAMED [1] - 275:12
FRAUD [4] - 256:9, 261:4, 279:5, 291:16
FRAUDULENT [4] - 239:18, 248:22,
258:25, 280:5
FREE [1] - 231:6
FROM [1] - 1:9
FRONT [8] - 174:5, 191:2, 201:23,
220:8, 221:9, 222:18, 252:11, 257:11
FULL [3] - 190:5, 190:7, 190:12
FULL [1] - 1:9
FUND [1] - 211:20
FUNDING [2] - 200:11, 200:13
FUNDS [6] - 199:7, 200:8, 248:5,
251:25, 266:23, 279:25
G
GAINES [45] - 173:16, 181:22, 197:23,
200:16, 213:2, 222:5, 222:7, 222:9,
222:18, 222:21, 223:7, 223:8, 223:12,
223:16, 226:21, 226:25, 227:4,
228:12, 229:7, 229:9, 230:8, 230:9,
230:15, 231:15, 231:25, 233:14,
233:15, 233:16, 233:18, 234:24,
235:1, 235:2, 235:4, 235:23, 236:6,
236:21, 236:25, 238:4, 242:12,
242:16, 242:17, 242:18, 242:20,
242:21
GATHERING [1] - 211:2
GAUGE [1] - 277:1
GEICO [1] - 230:12
GENA [31] - 167:24, 168:10, 169:9,
170:11, 170:22, 177:18, 177:20,
181:11, 182:17, 183:19, 185:24,
189:11, 189:17, 189:25, 190:4,
190:23, 191:6, 191:11, 191:19,
191:24, 194:1, 195:12, 201:18,
203:18, 204:22, 206:19, 207:6,
207:15, 207:17, 267:2, 267:7
GENERAL [1] - 232:19
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 162 of 174
GENERALLY [6] - 212:17, 226:10,
237:5, 263:25, 285:16, 307:8
GENTLEMEN [6] - 163:24, 194:16,
209:10, 216:3, 271:16, 282:25
GEORGIA [4] - 252:5, 252:17, 255:8,
255:23
GEORGIA [4] - 160:1, 160:25, 163:1,
312:4
GIVEN [4] - 209:11, 258:17, 258:21,
307:1
GMAIL [2] - 241:23, 264:25
GODADDY [2] - 257:23, 262:23
GOOGLE [2] - 265:12, 265:13
GOTCHA [1] - 267:23
GOVERNMENT [17] - 164:12, 165:21,
165:25, 183:15, 192:17, 195:5,
196:19, 196:21, 197:3, 197:16, 201:6,
202:1, 202:9, 204:1, 207:24, 208:11,
208:24
GOVERNMENT [18] - 174:25, 209:13,
220:22, 271:8, 272:7, 272:23, 293:6,
293:14, 294:14, 296:13, 299:21,
300:18, 300:23, 301:23, 302:2, 302:6,
305:20, 311:6
GOVERNMENT [1] - 160:14
GOVERNMENT'S [9] - 261:5, 275:8,
293:11, 302:10, 302:22, 305:15,
307:23, 310:25, 311:10
GOVERNMENT'S [10] - 194:5, 199:25,
201:25, 203:21, 223:23, 224:15,
227:8, 228:14, 233:24, 239:3
GRAND [7] - 219:5, 221:6, 221:10,
221:16, 221:18, 221:22, 237:13
GRANDVIEW [1] - 255:7
GRANT [1] - 310:25
GREAT [3] - 170:16, 283:1, 283:4
GREEN [3] - 199:16, 241:9, 241:10
GREEN [4] - 177:7, 184:10, 242:7,
242:9
GREEN'S [1] - 242:3
GRIFFIN [1] - 305:16
GROUND [1] - 310:18
GROUNDS [1] - 293:22
GROUP [29] - 165:13, 192:21, 195:3,
196:16, 199:17, 201:13, 213:1, 214:6,
227:16, 241:2, 241:20, 251:16, 252:1,
252:3, 252:6, 252:18, 253:15, 253:22,
254:12, 254:20, 255:12, 255:20,
255:22, 258:21, 262:2, 262:6, 262:12,
262:13, 262:15
GROUP [2] - 244:8, 251:20
GROW [1] - 262:7
GUESS [16] - 204:10, 217:2, 218:12,
219:9, 225:18, 230:9, 230:16, 248:18,
272:4, 272:6, 274:12, 283:8, 291:7,
299:14, 305:21
GUESSING [1] - 290:12
GUILT [4] - 308:17, 309:21, 309:24,
309:25
GUILTY [11] - 275:15, 304:23, 305:12,
305:21, 306:1, 306:15, 308:20,
308:22, 309:4, 310:3, 310:21
GUY [1] - 239:17
H
H-A-Z-E-L [1] - 210:19
HADJ [2] - 249:3, 249:5
HALF [4] - 176:12, 297:19
HAND [7] - 189:24, 189:25, 221:10,
226:5, 244:21, 263:12, 290:8
HANDLE [1] - 297:15
HANDWRITTEN [1] - 236:18
HAPPY [3] - 281:4, 295:18, 309:22
HARD [2] - 206:12, 302:14
HAS [1] - 1:8
HATE [1] - 296:5
HAZEL [3] - 210:4, 210:18, 210:19
HAZEL [1] - 210:11
HEAD [3] - 168:6, 225:6, 239:7
HEAR [9] - 209:18, 260:6, 264:21,
300:9, 300:10, 300:11, 306:7, 306:19
HEARD [4] - 238:24, 239:15, 254:9
HEARING [1] - 265:17
HEARSAY [23] - 274:15, 282:8, 282:19,
286:3, 286:14, 287:4, 287:10, 288:12,
288:17, 289:4, 289:17, 289:21,
291:25, 292:18, 292:19, 292:21,
293:6, 293:10, 293:13, 294:6, 294:11,
294:15, 295:20
HELD [1] - 163:1
HELD [1] - 259:6
HELP [2] - 211:20, 280:11
HELPING [1] - 301:24
HEREBY [1] - 312:6
HEREIN [1] - 210:12
HERSELF [2] - 240:23, 240:25
HI [1] - 263:19
HIGHLIGHT [1] - 198:6
HIGHLY [1] - 205:15
HILL [2] - 246:25, 247:1
HIT [1] - 203:9
HOLDINGS [10] - 178:22, 179:16,
179:17, 179:19, 180:9, 180:19,
182:13, 213:3, 245:4, 246:5
HOLLAND [16] - 167:6, 170:9, 171:2,
174:12, 176:11, 177:7, 192:15,
193:11, 207:10, 207:22, 224:14,
227:18, 228:6, 228:13, 232:4, 239:4
HOLLAND [1] - 189:3
HONEST [1] - 220:12
HONOR [83] - 163:4, 164:3, 169:24,
190:14, 194:4, 194:19, 196:22,
196:25, 199:24, 202:12, 203:20,
204:1, 204:3, 204:13, 204:21, 205:4,
206:8, 208:25, 209:7, 210:1, 214:12,
215:4, 215:9, 215:13, 215:16, 231:4,
238:13, 252:20, 252:22, 256:3,
256:17, 256:20, 258:3, 258:9, 259:12,
260:3, 260:9, 260:21, 261:10, 261:12,
321
263:6, 271:4, 271:5, 271:8, 272:22,
273:23, 274:19, 277:12, 280:19,
281:6, 282:8, 282:17, 284:4, 284:23,
285:2, 287:9, 288:13, 290:10, 291:5,
291:25, 294:10, 294:22, 296:2,
296:22, 297:4, 297:23, 297:24,
299:24, 300:14, 300:21, 301:1,
301:16, 302:16, 304:19, 305:8, 306:4,
307:4, 307:21, 309:2, 310:10, 310:19,
310:23
HONORABLE [1] - 160:10
HOPE [1] - 163:24
HOPEFULLY [1] - 301:8
HOTMAIL [1] - 265:1
HOUR [7] - 297:19, 299:1, 299:8, 304:5
HOURS [11] - 177:25, 178:10, 184:22,
250:6, 298:10, 298:16, 299:4, 299:6,
299:9, 301:2, 304:4
HOWEVER [1] - 1:8
HUNDRED [1] - 220:4
HUNDREDS [1] - 275:24
HUNTER [2] - 170:2, 190:15
HUSBAND [1] - 249:2
I
ICLOUD [33] - 164:16, 164:19, 166:1,
166:4, 169:5, 171:10, 171:15, 171:21,
172:2, 172:4, 172:13, 173:6, 173:13,
175:16, 175:23, 176:7, 178:7, 178:19,
179:22, 181:9, 181:18, 182:15,
182:24, 183:8, 184:20, 185:3, 185:9,
186:21, 187:1, 187:8, 188:6, 188:12,
188:24
IDEA [7] - 225:14, 267:3, 272:10, 274:9,
285:22, 288:9, 308:21
IDEAS [1] - 266:22
IDENTICAL [5] - 165:3, 165:15, 165:16,
167:19, 172:3
IDENTIFIED [3] - 271:6, 287:18, 295:8
IDENTIFYING [1] - 308:5
IDRS [3] - 212:6, 212:7, 212:14
IMAGE [4] - 179:12, 179:15, 179:16,
235:7
IMAGES [1] - 234:11
IMAGINE [1] - 250:5
IMPACT [1] - 295:10
IMPACT [2] - 213:1, 241:10
IMPEACH [2] - 258:23, 271:5
IMPEACHING [1] - 272:10
IMPEACHMENT [6] - 258:9, 258:12,
258:14, 259:3, 259:5, 261:9
IMPERSONATING [1] - 276:2
IMPLICATE [2] - 275:10, 301:19
IMPLICATED [2] - 305:2, 305:3
IMPLICATES [2] - 309:9, 309:11
IMPLICATING [3] - 274:20, 275:17,
310:5
IMPLIED [1] - 306:13
IMPLIES [1] - 307:18
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 163 of 174
IMPORTANT [6] - 216:12, 217:13,
217:16, 218:10, 224:25, 301:24
IMPRESSION [1] - 309:18
IMPROPER [2] - 259:2, 261:9
IN [3] - 1:3, 1:4, 163:1
IN-PERSON [1] - 259:9
INACCURATE [1] - 271:3
INC [10] - 166:16, 167:13, 172:24,
175:25, 182:13, 197:20, 246:5,
246:17, 247:3, 247:15
INCEPTION [1] - 231:16
INCLINED [1] - 310:24
INCLUDE [4] - 165:2, 203:6, 204:5,
216:21
INCLUDED [2] - 171:20, 172:19
INCLUDES [5] - 241:17, 241:20, 250:12,
250:16, 268:20
INCLUDING [1] - 205:9
INCLUSION [1] - 204:14
INCORPORATION [2] - 174:5, 253:14
INCORPORATOR [1] - 253:16
INCREDIBLY [1] - 275:18
INCULPATED [1] - 309:18
INCULPATES [1] - 309:11
INDICATED [1] - 237:6
INDICATING [1] - 194:11
INDICATION [2] - 276:1, 287:20
INDICTMENT [4] - 239:1, 268:1, 307:22,
308:14
INDIVIDUAL [6] - 243:3, 243:22, 263:11,
263:24, 268:20, 280:8
INDIVIDUALS [4] - 200:8, 213:22,
239:19, 245:1
INDUSTRY [2] - 262:8, 262:14
INFINITE [15] - 164:7, 164:19, 165:18,
165:20, 166:15, 167:13, 167:21,
168:5, 168:13, 168:21, 170:20,
171:23, 213:5, 247:2
INFLOW [1] - 221:19
INFO@BELLATORPHRONTGROUP.
COM [1] - 263:17
INFORMATION [13] - 165:18, 165:19,
174:8, 198:25, 203:6, 212:8, 212:10,
218:9, 226:21, 237:6, 237:11, 239:20,
281:15
INITIAL [1] - 281:2
INQUIRY [1] - 167:14
INSTANCE [3] - 220:24, 221:4, 233:14
INSTEAD [3] - 199:11, 209:17, 277:23
INSTRUCTED [1] - 251:22
INSTRUCTION [2] - 308:16, 309:23
INSTRUCTIONS [1] - 271:18
INTEGRAL [1] - 300:5
INTEGRATED [1] - 212:5
INTERACTING [1] - 273:8
INTERACTION [2] - 226:4, 264:10
INTERACTIONS [3] - 264:5, 264:7,
307:16
INTERNAL [3] - 167:12, 210:21, 211:1
INTERRUPT [1] - 302:11
INTERVIEW [42] - 166:6, 192:12,
207:20, 216:11, 216:12, 219:22,
220:19, 222:8, 222:10, 222:16,
222:17, 222:23, 223:3, 268:20, 270:5,
270:14, 272:25, 277:19, 278:17,
278:21, 279:1, 279:10, 280:1, 280:4,
280:11, 280:13, 280:21, 280:22,
281:2, 281:9, 281:20, 285:1, 285:2,
285:3, 285:16, 285:20, 285:22,
286:10, 287:6, 287:23, 292:3, 294:23
INTERVIEWED [10] - 196:17, 208:19,
218:17, 268:13, 269:6, 270:8, 272:22,
281:23, 289:9, 293:15
INTERVIEWING [3] - 262:12, 268:21,
277:15
INTERVIEWS [5] - 218:16, 219:20,
237:5, 268:11, 269:14
INTRODUCE [4] - 275:9, 293:14, 306:9,
310:20
INTRODUCED [3] - 223:22, 224:17,
259:8
INTRODUCING [1] - 306:10
INTRODUCTION [1] - 260:16
INVESTIGATED [1] - 282:21
INVESTIGATING [1] - 250:2
INVESTIGATION [39] - 164:10, 172:8,
178:23, 185:13, 187:12, 194:1, 199:2,
212:20, 216:9, 216:11, 217:12, 218:5,
219:22, 220:3, 232:19, 252:5, 255:16,
261:1, 262:15, 279:17, 281:4, 281:20,
281:24, 282:22, 284:14, 285:5, 286:1,
290:20, 294:1, 294:13, 294:20,
294:25, 295:1, 295:2, 295:10, 295:14,
295:19, 295:22, 295:25
INVESTIGATOR [1] - 304:2
INVESTOR [1] - 266:8
INVOKE [3] - 260:3, 260:11, 260:15
INVOLVED [26] - 164:9, 172:7, 178:23,
185:12, 187:12, 191:25, 200:10,
231:15, 231:20, 231:21, 237:7, 239:9,
241:4, 243:16, 248:15, 264:14,
268:22, 269:12, 272:23, 275:11,
275:15, 275:23, 285:4, 295:12,
306:14, 306:16
INVOLVEMENT [2] - 270:23, 307:10
IP [6] - 224:25, 225:2, 225:8, 225:20,
225:23, 226:2
IRRELEVANT [3] - 258:16, 271:11,
274:22
IRS [11] - 211:4, 211:5, 211:8, 211:16,
211:22, 212:9, 212:12, 213:18,
213:20, 213:22, 214:6
IS [1] - 1:2
ISSUE [15] - 258:25, 271:14, 271:23,
274:17, 281:14, 283:8, 286:12, 296:7,
296:18, 297:25, 299:21, 301:25,
305:9, 305:11
ISSUED [2] - 201:13, 216:15
ISSUES [1] - 209:12
322
IT'LL [2] - 276:12, 301:8
ITEMS [2] - 240:11, 261:23
ITSELF [2] - 274:21, 289:3
J
J.P [1] - 160:10
JACKSON [33] - 202:11, 218:20, 219:9,
219:24, 220:10, 220:23, 221:3,
222:16, 222:17, 222:24, 223:8, 225:9,
226:18, 228:1, 229:7, 229:14, 229:18,
230:12, 233:4, 233:13, 233:15,
233:16, 234:19, 235:2, 235:5, 235:14,
236:6, 236:13, 237:1, 237:6, 238:3,
308:20
JACKSON [2] - 160:6, 160:20
JACKSON'S [5] - 217:25, 223:20, 225:2,
225:24, 309:25
JAMES [4] - 203:13, 254:7, 254:10
JANUARY [1] - 178:17
JAY [1] - 300:17
JERRY [2] - 243:21, 243:22
JESIKA [3] - 240:18, 240:19, 251:14
JIMBO [2] - 273:18
JOB [2] - 212:2, 212:18
JOHN [19] - 222:7, 222:9, 222:21,
223:12, 228:12, 230:8, 230:9, 231:15,
233:13, 233:15, 234:24, 235:1, 235:2,
235:23, 236:6, 236:21, 236:25,
242:12, 242:16
JOHNSON [2] - 255:2, 255:10
JOKE [1] - 194:23
JOSEPH [1] - 162:3
JUDGE [17] - 163:14, 170:5, 194:8,
200:3, 202:11, 204:8, 215:6, 215:20,
238:14, 238:15, 252:23, 265:19,
299:3, 303:11, 304:12, 306:23, 310:9
JUDGE [1] - 160:10
JUDGE [2] - 216:24, 303:12
JULY [13] - 193:20, 196:4, 196:5,
196:10, 202:23, 203:2, 206:21,
206:24, 207:12, 218:20, 222:25,
238:3, 256:1
JUNE [32] - 168:19, 169:9, 171:11,
175:5, 175:24, 178:1, 178:8, 181:10,
181:19, 182:10, 183:17, 184:8,
184:13, 184:15, 184:21, 185:20,
185:23, 186:8, 186:22, 188:7, 189:14,
193:20, 195:14, 195:18, 202:22,
202:24, 226:12, 226:13, 229:1,
230:13, 231:19, 233:9
JURORS [1] - 309:23
JURY [1] - 160:9
JURY [40] - 163:3, 163:20, 163:24,
168:4, 194:16, 209:10, 212:24,
213:18, 215:23, 219:5, 221:6, 221:10,
221:16, 221:18, 221:22, 224:20,
237:13, 271:14, 271:16, 271:20,
274:24, 275:18, 276:23, 277:6, 277:8,
282:25, 283:5, 287:7, 296:6, 305:1,
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 164 of 174
306:7, 307:11, 307:14, 307:18,
308:14, 309:3, 309:6, 309:13, 309:15,
310:1
JURY'S [1] - 307:8
K
KAHLIL [2] - 241:9, 241:10
KAUSHAL [1] - 160:15
KEEP [1] - 297:10
KEVIN [2] - 254:7, 254:9
KIND [12] - 179:5, 193:13, 205:10,
217:24, 220:6, 233:7, 233:8, 240:21,
265:9, 275:9, 301:24, 310:15
KINDS [2] - 193:22, 232:23
KNOCK [6] - 170:25, 171:4, 219:25,
220:1, 220:2, 222:18
KNOCK-AND-TALK [1] - 219:25
KNOCK-AND-TALKS [2] - 220:1, 220:2
KNOWING [1] - 280:4
KNOWLEDGE [6] - 254:11, 262:9,
262:10, 272:24, 280:22, 286:4
KNOWN [3] - 212:6, 273:7, 285:13
KNOWS [3] - 275:13, 281:13, 283:22
L
LABELED [1] - 261:19
LACK [1] - 295:24
LADIES [6] - 163:24, 194:16, 209:10,
216:3, 271:16, 282:25
LAID [1] - 295:13
LANGUAGE [3] - 190:11, 191:1
LAPTOP [2] - 217:4, 217:18
LAPTOPS [1] - 218:4
LAST [15] - 202:4, 209:25, 230:10,
230:12, 235:17, 242:19, 259:24,
261:8, 280:8, 287:17, 291:15, 291:20,
298:9, 303:5
LASTED [1] - 222:10
LATE [3] - 171:12, 179:13, 184:13
LAUGHTER [1] - 194:22
LAW [5] - 305:9, 305:11, 305:17, 306:1,
307:13
LAWYER [2] - 270:11, 278:19
LAY [2] - 295:18, 295:21
LAYER [2] - 293:6, 295:20
LEAD [1] - 308:4
LEADER [1] - 239:21
LEADS [1] - 262:4
LEARNED [1] - 255:16
LEAST [12] - 204:4, 217:20, 223:19,
226:22, 226:23, 226:24, 239:11,
246:3, 289:16, 289:20, 298:1, 309:11
LEAVE [1] - 300:14
LEAVES [2] - 301:2, 309:17
LEAVING [1] - 163:9
LEE [13] - 194:11, 206:12, 213:3, 245:3,
264:14, 264:15, 265:2, 265:7, 266:4,
266:7, 266:23
LEEWAY [3] - 258:21, 276:12, 276:19
LEFT [7] - 183:1, 189:7, 226:5, 226:10,
303:7, 307:14, 308:18
LEFT-HAND [1] - 226:5
LEGAL [1] - 259:8
LEIGH [1] - 160:18
LESS [1] - 210:1
LESS [1] - 222:13
LETTER [6] - 167:13, 174:4, 270:2,
270:4, 270:13
LETTERS [1] - 274:25
LEVEL [6] - 262:8, 288:14, 289:10,
293:13, 293:17, 294:11
LEVELS [1] - 287:10
LIAR [1] - 259:13
LIDDIARD [2] - 297:7, 298:14
LIE [3] - 273:3, 275:10, 288:10
LIED [2] - 273:1, 278:10
LIES [1] - 274:16
LIGHT [1] - 205:22
LIMINE [2] - 305:15, 307:5
LIMIT [1] - 300:4
LIMITING [2] - 308:16, 309:23
LINE [1] - 1:7
LINE [10] - 192:23, 195:4, 201:7, 201:10,
201:16, 290:2, 301:20, 303:5, 308:3
LINES [1] - 258:11
LIST [6] - 174:14, 179:2, 179:4, 179:7,
212:23, 306:11
LISTED [14] - 174:9, 177:1, 198:14,
201:20, 214:16, 214:22, 253:16,
254:1, 254:5, 254:7, 254:23, 254:25,
255:2, 255:14
LISTEN [1] - 279:10
LISTING [5] - 174:6, 201:12, 202:6,
224:22, 240:20
LITIGATED [1] - 305:8
LIVES [1] - 279:22
LIVING [5] - 223:13, 226:25, 255:6,
255:9, 262:14
LLC [4] - 187:19, 227:16, 234:21,
249:11
LOAD [1] - 199:12
LOAN [25] - 172:2, 185:12, 187:7,
187:12, 200:21, 208:17, 208:20,
235:23, 236:2, 236:19, 242:17,
242:22, 243:17, 243:24, 243:25,
248:8, 251:19, 264:1, 264:14, 265:3,
266:7, 277:22, 279:25, 291:19, 294:17
LOANS [23] - 164:9, 200:10, 239:9,
239:18, 239:20, 240:6, 240:8, 240:20,
241:4, 243:1, 243:8, 244:19, 245:1,
247:25, 248:4, 248:19, 248:21,
248:22, 249:1, 251:22, 255:7, 266:23,
267:25
LOCATED [1] - 279:19
LOCATION [4] - 203:6, 207:3, 225:18,
227:6
LOCATIONS [1] - 203:9
LOGIN [1] - 174:4
323
LOGINS [1] - 226:3
LOOK [13] - 203:14, 208:2, 213:9,
214:20, 230:6, 252:11, 257:10,
264:17, 275:20, 285:19, 306:24,
307:3, 307:24
LOOKED [14] - 165:2, 167:18, 171:12,
173:1, 173:15, 178:11, 180:3, 181:21,
182:15, 191:22, 192:20, 193:6, 203:5,
212:25
LOOKING [9] - 174:2, 174:8, 179:2,
180:11, 198:2, 205:6, 254:15, 263:15,
311:10
LOOKS [6] - 252:17, 253:14, 253:21,
258:18, 265:8, 288:4
LOOP [1] - 304:25
LOST [1] - 289:11
LOWER [1] - 179:5
LUNCH [1] - 163:25
LYING [5] - 273:7, 274:5, 275:7, 278:13,
282:18
M
MAIL [70] - 164:16, 164:23, 166:1,
166:12, 167:18, 168:18, 168:20,
171:10, 171:15, 171:21, 172:13,
172:20, 173:6, 173:13, 175:4, 175:7,
175:13, 175:23, 176:1, 176:7, 177:23,
178:7, 179:22, 181:9, 182:9, 182:14,
182:15, 182:17, 183:16, 183:24,
184:7, 184:20, 185:3, 186:7, 186:14,
186:21, 187:1, 187:17, 187:24, 188:6,
188:12, 229:13, 229:16, 229:18,
229:21, 229:23, 229:25, 232:23,
233:3, 233:11, 235:1, 236:4, 241:2,
241:3, 241:17, 241:20, 241:25, 242:3,
242:6, 249:17, 259:21, 261:16,
262:24, 263:22, 264:25, 265:5,
265:21, 268:5, 276:1
MAILS [21] - 191:23, 229:11, 229:17,
233:7, 241:14, 242:9, 245:12, 246:2,
249:16, 249:19, 250:12, 257:7, 257:8,
257:24, 261:1, 263:1, 263:24, 263:25,
268:8, 273:11, 275:24
MAIN [2] - 199:9, 239:17
MAJORITY [2] - 230:7, 230:8
MANAGEMENT [5] - 213:2, 213:7,
243:17, 243:24, 244:8
MANAGING [3] - 240:11, 240:20,
240:21
MARCH [2] - 166:22, 167:14
MARKED [1] - 262:20
MARRIED [2] - 240:16, 240:17
MARSHALL [8] - 170:4, 204:7, 215:17,
216:1, 265:17, 303:1, 306:3, 306:19
MARSHALL [57] - 160:20, 163:14,
170:5, 190:17, 194:8, 194:10, 200:3,
202:11, 204:8, 215:6, 215:20, 216:2,
216:5, 224:14, 224:16, 227:18,
227:21, 228:6, 228:8, 228:13, 228:20,
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 165 of 174
230:2, 230:5, 231:4, 231:8, 232:3,
232:5, 232:8, 232:11, 233:23, 234:1,
234:9, 234:12, 235:7, 235:9, 236:9,
236:11, 238:13, 252:23, 265:19,
297:24, 298:4, 298:7, 299:2, 302:17,
303:2, 303:11, 303:19, 303:24, 304:1,
304:9, 304:12, 306:4, 306:8, 306:21,
310:9, 310:12
MARSHALL'S [2] - 303:23, 306:18
MASTER [1] - 212:9
MATTER [10] - 236:7, 274:15, 282:17,
285:7, 286:23, 287:8, 287:14, 288:8,
288:11, 294:12
MATTERS [1] - 285:9
MAY [2] - 1:3, 1:5
MCDUFFIE [1] - 249:10
MEAN [8] - 217:12, 248:20, 260:14,
289:11, 293:9, 296:5, 297:2, 301:23
MEANS [2] - 225:14, 308:22
MEANT [1] - 260:21
MEETING [2] - 269:3, 269:18
MEETINGS [1] - 268:19
MEGHAN [5] - 240:5, 253:17, 254:5,
254:25, 261:19
MEGHAN'S [1] - 240:10
MEMBER [1] - 230:23
MEMO [2] - 192:23, 195:4
MEMORY [1] - 241:7
MENTION [1] - 222:7
MENTIONED [6] - 221:2, 221:4, 222:5,
249:23, 264:5, 276:17
MESSAGE [24] - 164:18, 166:3, 167:6,
168:12, 170:11, 170:15, 171:1,
171:10, 177:7, 177:9, 177:12, 178:10,
180:2, 180:15, 184:10, 184:22, 185:9,
185:16, 189:13, 191:4, 191:14,
198:19, 267:14, 267:21
MESSAGED [3] - 177:21, 189:18,
189:21
MESSAGES [34] - 168:7, 170:17,
171:12, 173:24, 181:1, 189:11,
189:13, 189:23, 190:4, 190:10,
190:22, 191:23, 192:7, 217:3, 232:20,
232:23, 233:1, 233:2, 233:3, 233:4,
236:5, 245:13, 249:22, 250:14,
250:16, 250:20, 250:21, 250:25,
251:1, 251:10, 251:13, 275:25
MESSAGING [3] - 190:13, 251:5, 251:9
MESSY [1] - 282:24
METABANK [2] - 199:21, 200:6
METHOD [1] - 219:19
MICHIGAN [2] - 213:4, 245:22
MICKIES [6] - 187:11, 187:18, 188:8,
188:19, 213:6, 249:11
MIDDLE [9] - 174:16, 176:24, 179:6,
242:16, 243:4, 243:15, 243:22,
289:10, 294:10
MIGHT [17] - 213:12, 214:18, 218:9,
224:3, 226:25, 245:5, 246:2, 250:5,
292:7, 292:24, 297:19, 299:13,
303:16, 303:21, 304:14, 311:3, 311:8
MILLER [12] - 255:2, 255:10, 257:3,
257:8, 258:18, 262:1, 262:4, 263:11,
275:21, 275:24, 305:21
MIND [2] - 281:15, 303:17
MINI [1] - 297:24
MINUTE [2] - 238:13, 260:5
MINUTES [16] - 210:1, 220:17, 222:10,
292:16, 296:6, 297:8, 297:23, 298:10,
298:14, 298:15, 298:20, 299:5, 299:8,
299:9
MISIMPRESSION [1] - 307:15
MISLEADING [2] - 275:18, 276:18
MISSING [2] - 297:2, 299:11
MISSPOKE [1] - 198:11
MISSTATED [1] - 278:10
MISTAKE [1] - 177:9
ML [7] - 183:12, 183:18, 184:14, 184:21,
213:4, 245:5, 247:15
MO [7] - 259:22, 260:1, 260:23, 275:16,
276:4, 309:8, 310:5
MOBILE [3] - 203:4, 203:23, 206:22
MODEL [1] - 262:14
MODUS [2] - 260:23
MOMENT [10] - 163:5, 194:9, 214:12,
260:2, 272:18, 278:19, 283:7, 286:7,
290:14, 310:6
MOMENTS [2] - 208:25, 209:3
MONDAY [2] - 298:1, 311:10
MONEY [20] - 192:13, 196:12, 197:8,
199:9, 200:11, 200:15, 200:22,
200:24, 203:1, 208:2, 208:8, 208:16,
221:19, 221:20, 234:14, 247:25,
248:7, 248:13, 251:21, 251:23
MONTH [5] - 180:20, 193:20, 193:23,
211:13, 226:17
MONTHS [3] - 176:18, 205:6, 226:10
MOORE [11] - 160:15, 210:1, 210:4,
210:16, 213:15, 213:16, 214:3, 214:4,
214:12, 214:14, 214:25
MORNING [7] - 163:9, 170:16, 209:11,
219:1, 299:15, 301:2, 311:7
MOST [6] - 212:8, 212:17, 225:18,
239:12, 240:4, 301:23
MOSTLY [2] - 217:4, 297:9
MOTHER [2] - 255:11, 276:3
MOTION [5] - 305:15, 307:5, 310:25,
311:5, 311:7
MOTIVE [1] - 208:16
MOUNTAIN [1] - 225:17
MOVE [17] - 164:6, 170:1, 172:6,
190:14, 194:4, 196:23, 199:24, 202:9,
203:20, 204:1, 224:12, 231:6, 252:20,
256:20, 258:1, 263:4, 265:15
MOVED [1] - 196:22
MR [66] - 163:14, 170:5, 190:17, 194:8,
194:10, 200:3, 202:11, 204:8, 210:1,
210:4, 210:16, 213:15, 213:16, 214:3,
214:4, 214:12, 214:14, 214:25, 215:6,
215:20, 216:2, 216:5, 224:14, 224:16,
324
227:18, 227:21, 228:6, 228:8, 228:13,
228:20, 230:2, 230:5, 231:4, 231:8,
232:3, 232:5, 232:8, 232:11, 233:23,
234:1, 234:9, 234:12, 235:7, 235:9,
236:9, 236:11, 238:13, 252:23,
265:19, 297:24, 298:4, 298:7, 299:2,
302:17, 303:2, 303:11, 303:19,
303:24, 304:1, 304:9, 304:12, 306:4,
306:8, 306:21, 310:9, 310:12
MS [340] - 163:4, 163:7, 163:15, 163:17,
164:3, 164:5, 164:12, 164:14, 164:20,
164:22, 165:6, 165:8, 165:21, 165:24,
166:10, 166:11, 167:4, 167:7, 167:15,
167:17, 168:1, 168:2, 168:15, 168:16,
168:23, 168:24, 169:13, 169:14,
169:22, 170:3, 170:8, 170:10, 171:1,
171:3, 171:7, 171:8, 171:17, 171:19,
172:10, 172:11, 172:16, 172:18,
173:3, 173:4, 173:9, 173:11, 173:22,
173:23, 174:11, 174:13, 174:20,
174:22, 175:1, 175:2, 175:10, 175:11,
175:20, 175:21, 176:3, 176:5, 176:11,
176:13, 177:6, 177:8, 178:3, 178:5,
178:25, 179:1, 179:9, 179:11, 179:20,
179:21, 180:5, 180:6, 180:13, 180:14,
181:6, 181:7, 181:15, 181:17, 182:7,
182:8, 182:20, 182:22, 183:13,
183:14, 183:22, 183:23, 184:5, 184:6,
184:9, 184:11, 184:17, 184:18,
184:25, 185:2, 185:15, 185:18, 186:4,
186:5, 186:12, 186:13, 186:18,
186:19, 186:23, 186:25, 187:14,
187:15, 187:22, 187:23, 188:3, 188:4,
188:9, 188:11, 189:2, 189:3, 189:4,
189:6, 190:14, 190:16, 190:19,
190:21, 191:9, 191:10, 192:15,
192:18, 192:19, 193:3, 193:4, 193:10,
193:12, 193:16, 193:18, 194:4, 194:7,
194:13, 194:18, 194:21, 194:24,
195:5, 195:7, 195:15, 195:16, 196:2,
196:3, 196:19, 196:22, 196:25, 197:2,
197:4, 197:16, 197:18, 198:6, 198:10,
198:17, 198:20, 199:24, 200:2, 200:5,
201:6, 201:9, 202:9, 202:12, 202:16,
202:17, 203:20, 203:22, 204:1, 204:3,
204:13, 204:19, 204:21, 205:4,
205:12, 205:20, 206:8, 206:14,
206:16, 206:17, 207:9, 207:11,
207:22, 207:25, 208:10, 208:12,
208:23, 208:25, 209:3, 209:5, 209:7,
215:4, 215:13, 215:16, 238:19,
238:21, 239:3, 239:5, 252:20, 252:22,
252:25, 253:2, 253:7, 253:10, 253:12,
256:3, 256:6, 256:13, 256:16, 256:20,
257:1, 257:2, 258:1, 258:3, 258:6,
258:9, 258:19, 259:4, 259:12, 260:1,
260:3, 260:9, 260:14, 260:16, 260:21,
261:9, 261:12, 261:15, 263:4, 263:6,
263:8, 263:9, 265:15, 265:16, 265:20,
271:4, 271:5, 271:8, 272:9, 272:19,
272:21, 273:22, 274:14, 274:19,
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 166 of 174
277:2, 277:12, 277:13, 280:19,
280:25, 281:6, 281:11, 281:17,
281:18, 282:8, 282:16, 283:21,
283:23, 284:2, 284:4, 284:7, 284:11,
284:16, 284:23, 285:2, 285:9, 285:14,
286:7, 286:14, 286:21, 286:25, 287:9,
288:3, 288:7, 288:13, 289:6, 289:22,
290:1, 290:10, 290:17, 290:23, 291:4,
291:7, 291:13, 291:18, 291:25,
292:10, 293:2, 293:9, 293:13, 293:19,
293:21, 293:23, 294:5, 294:8, 294:10,
294:22, 295:23, 296:2, 296:10,
296:22, 297:4, 297:18, 297:23, 298:3,
298:5, 298:12, 298:18, 298:24,
299:12, 299:20, 299:24, 300:14,
300:17, 300:19, 300:21, 301:1, 301:5,
301:11, 301:14, 301:16, 302:1, 302:3,
302:16, 302:25, 303:9, 303:10,
303:17, 303:20, 303:25, 304:2,
304:19, 305:8, 306:6, 306:10, 306:17,
307:4, 307:21, 308:13, 309:2, 310:19,
310:23
MULTIFAMILY [3] - 262:8, 262:9,
262:14
MULTIPLE [1] - 272:22
MUST [1] - 299:11
N
NAME [37] - 172:7, 173:19, 174:4,
179:16, 179:17, 182:3, 182:4, 195:11,
201:1, 201:12, 201:15, 201:18,
210:17, 210:18, 212:4, 212:5, 225:15,
227:25, 236:20, 244:13, 246:3, 249:4,
254:9, 257:3, 257:7, 274:7, 275:21,
275:22, 276:2, 276:4, 280:8, 280:15,
287:24, 291:15, 295:9, 300:17
NAMED [3] - 255:2, 288:9, 305:15
NAMES [14] - 169:7, 173:20, 173:21,
182:1, 182:2, 182:5, 183:6, 200:9,
256:8, 259:15, 259:16, 259:18, 309:8
NATURE [1] - 307:15
NAVY [2] - 197:11, 197:13
NEARLY [1] - 192:4
NEED [9] - 178:19, 205:17, 256:23,
271:15, 274:24, 296:17, 297:10,
297:17, 301:4
NEEDED [1] - 174:7
NEEDS [2] - 296:14, 297:5
NEVER [1] - 281:7
NEXT [9] - 209:24, 227:19, 235:7, 236:9,
290:13, 297:11, 300:14, 300:15,
303:13
NIGHT [3] - 171:12, 179:13, 184:13
NINE [2] - 257:12, 257:13
NO [1] - 160:5
NOBODY [3] - 194:23, 288:19, 309:20
NONE [2] - 274:14, 305:2
NORMALLY [3] - 209:13, 219:5, 219:19
NORTHERN [2] - 160:1, 312:4
NOTARIZED [2] - 266:18, 266:19
NOTARY [1] - 265:8
NOTATION [2] - 235:20, 236:17
NOTE [3] - 232:14, 247:22, 307:4
NOTED [1] - 235:22
NOTES [1] - 290:21
NOTHING [3] - 214:25, 238:15, 275:11
NOTICE [1] - 189:25
NOVEMBER [4] - 176:19, 224:5, 224:6,
224:9
NUMBER [1] - 223:23
NUMBER [2] - 1:6, 1:7
NUMBER [10] - 165:19, 167:14, 179:18,
180:20, 201:16, 219:12, 236:19,
245:12, 264:9, 308:23
NUMBERS [12] - 165:2, 165:15, 169:17,
169:18, 172:25, 173:1, 175:15,
180:10, 181:24, 181:25, 182:5, 183:4
NUMEROUS [1] - 200:8
O
OBJECT [12] - 204:3, 204:11, 204:13,
204:16, 204:17, 204:18, 258:3,
280:20, 290:4, 306:22, 310:15, 310:17
OBJECTED [2] - 290:6, 291:12
OBJECTION [31] - 170:3, 170:6, 190:16,
190:17, 194:7, 194:8, 194:10, 196:25,
200:2, 200:3, 202:11, 202:14, 204:8,
206:2, 252:22, 252:23, 256:3, 256:17,
256:24, 261:8, 263:6, 265:16, 265:17,
265:19, 271:4, 272:4, 276:21, 291:23,
293:22, 295:20, 302:17
OBJECTION'S [1] - 277:11
OBLIGATION [1] - 295:4
OBTAINED [5] - 216:14, 218:10, 234:14,
252:5, 266:7
OBVIOUSLY [5] - 259:20, 269:6, 275:3,
301:19, 310:13
OCCASION [1] - 260:18
OCCASIONALLY [5] - 216:17, 216:18,
223:17, 226:22, 226:23
OCTOBER [1] - 176:19
OF [10] - 1:2, 1:5, 1:6, 160:1, 160:4,
160:9, 160:14, 160:17, 160:20, 312:4
OFF-THE-RECORD [2] - 163:22, 215:22
OFFER [1] - 289:22
OFFERED [15] - 260:10, 274:14, 282:16,
282:19, 287:14, 288:8, 288:11,
288:14, 289:19, 292:7, 292:21, 293:7,
293:11, 294:11, 294:12
OFFERING [11] - 260:10, 286:14,
286:22, 286:24, 286:25, 289:1, 289:7,
289:10, 292:11, 293:3, 309:25
OFFICE [2] - 192:24, 193:1
OFFICE [3] - 213:8, 268:22, 269:11
OFFICERS [1] - 254:22
OFFICIAL [1] - 231:23
OFFICIAL [6] - 1:2, 1:3, 1:4, 1:8, 160:24,
312:15
325
ON [3] - 160:14, 160:17, 160:20
ONCE [4] - 200:13, 247:24, 248:4,
285:10
ONE [79] - 163:5, 164:9, 169:15, 174:18,
181:11, 183:24, 186:14, 187:24,
188:19, 189:24, 194:9, 202:4, 202:12,
205:17, 207:15, 209:11, 213:12,
214:12, 217:6, 225:8, 227:24, 228:14,
233:4, 234:11, 235:10, 235:13, 236:9,
236:15, 237:15, 237:17, 237:20,
238:13, 239:9, 239:12, 239:23, 240:1,
242:8, 243:8, 246:3, 247:1, 249:2,
251:20, 252:13, 253:17, 257:12,
257:13, 260:2, 264:10, 267:13, 268:3,
268:4, 268:10, 269:14, 269:15,
272:18, 275:14, 276:3, 278:23,
280:25, 285:13, 290:17, 292:19,
293:2, 293:7, 294:8, 298:8, 298:18,
298:22, 299:7, 300:12, 301:5, 303:12,
304:2, 304:4, 306:11, 310:6
ONE-NINE [2] - 257:12, 257:13
ONES [5] - 180:12, 241:6, 242:23,
242:24, 244:22
ONLY [2] - 1:3, 1:7
OPEN [1] - 311:11
OPEN [1] - 163:1
OPENED [6] - 195:13, 195:25, 304:22,
305:6, 305:23, 309:5
OPERANDI [1] - 260:23
OPERATIONS [1] - 262:5
OPERATIONS [8] - 213:3, 245:3,
264:14, 265:2, 265:7, 266:4, 266:8,
266:23
OPINION [1] - 220:10
OPPORTUNITY [1] - 209:15
OR [1] - 1:9
ORDER [5] - 209:11, 256:9, 267:2,
288:22, 296:21
ORGANIZATIONAL [1] - 253:9
ORGANIZER [1] - 230:23
ORIGINAL [3] - 227:23, 227:24, 228:4
OTHERWISE [5] - 258:15, 259:8,
282:12, 294:15, 295:19
OUT-OF-COURT [1] - 289:4
OUTSIDE [6] - 204:14, 223:15, 248:22,
248:23, 256:4, 283:10
OUTSTANDING [1] - 240:21
OVERALL [1] - 216:10
OVERARCHING [1] - 279:16
OVERLOOK [1] - 255:7
OVERNIGHT [1] - 223:17
OVERRULED [2] - 261:11, 277:11
OVERVIEW [1] - 216:8
OWN [10] - 204:23, 204:24, 205:2,
205:8, 205:9, 243:5, 244:24, 248:19,
248:21, 297:24
OWNER [8] - 241:10, 243:5, 243:16,
245:20, 246:18, 248:21, 249:6, 307:9
OWNER'S [1] - 307:10
OWNERS [3] - 239:19, 240:2, 248:13
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 167 of 174
OWNERS' [2] - 200:12, 248:9
P
P.M [18] - 163:20, 164:17, 172:14,
175:5, 182:10, 183:17, 184:8, 184:15,
188:7, 215:14, 215:15, 215:23,
271:20, 271:25, 272:1, 277:8, 283:5,
311:14
PAGE [1] - 1:7
PAGE [27] - 162:2, 168:1, 174:2, 176:24,
178:25, 189:4, 189:7, 191:9, 193:3,
193:10, 193:16, 195:15, 196:2,
197:17, 207:9, 227:19, 228:7, 228:15,
228:16, 290:11, 290:15, 290:17,
290:18, 291:5
PAGES [8] - 204:18, 205:18, 206:3,
206:9, 264:18, 290:10, 312:6
PAINTING [2] - 213:1, 244:25
PANDEMIC [1] - 269:23
PAPER [4] - 208:2, 275:21, 275:23,
276:4
PARAGRAPH [7] - 265:6, 267:17,
280:14, 287:23, 290:11, 291:4, 291:20
PARAGRAPHS [1] - 290:21
PARKER [18] - 178:22, 179:4, 179:16,
179:17, 179:18, 179:19, 180:9,
180:19, 182:13, 213:3, 245:3, 245:4,
246:3, 246:5, 246:8, 246:12
PART [28] - 204:4, 212:11, 212:18,
221:5, 232:9, 240:25, 241:1, 242:19,
262:12, 272:14, 275:7, 276:18, 281:2,
281:24, 282:2, 282:21, 282:22,
284:14, 288:15, 290:11, 290:19,
291:6, 291:19, 298:1, 300:5, 303:22,
304:13, 309:11
PARTIAL [1] - 1:9
PARTICIPATE [1] - 230:17
PARTICULAR [3] - 231:25, 260:18
PARTIES [3] - 232:24, 233:4, 286:3
PAST [1] - 204:6
PATTERN [5] - 172:2, 183:8, 187:7,
188:23, 259:15
PAUSE [3] - 253:9, 299:16, 303:6
PAUSE [2] - 209:6, 214:13
PAYCARD [17] - 198:25, 199:3, 199:16,
199:21, 200:7, 200:14, 200:22,
200:24, 201:1, 201:15, 202:6, 202:7,
202:19, 206:25, 207:19, 208:1, 208:5
PAYCARDS [2] - 201:14, 266:9
PAYCHECK [1] - 185:21
PAYCHECKS [1] - 211:13
PAYEE [2] - 234:20, 236:15
PAYMENT [6] - 196:15, 197:23, 198:5,
198:7, 198:8, 236:1
PAYMENTS [4] - 193:15, 198:1, 200:17
PAYROLL [22] - 167:19, 168:21, 168:25,
169:3, 173:12, 173:15, 175:9, 181:21,
182:23, 183:1, 186:9, 187:20, 197:23,
198:1, 199:1, 199:6, 199:10, 200:18,
200:22, 201:12, 203:1, 266:9
PAYROLL [1] - 195:4
PDF [1] - 1:2
PENNY [2] - 160:24, 312:15
PEOPLE [35] - 200:10, 208:3, 220:6,
238:24, 238:25, 239:6, 239:14,
249:20, 249:23, 268:13, 269:1,
272:11, 274:25, 275:4, 275:13,
275:17, 279:19, 304:24, 305:2, 305:3,
306:11, 307:22, 307:25, 308:7,
308:21, 309:3, 309:9, 309:11, 309:12,
309:13, 309:16, 309:19, 309:21, 310:5
PEOPLE'S [6] - 256:8, 259:15, 259:16,
259:18, 307:16, 309:8
PER [1] - 272:9
PERHAPS [4] - 276:18, 283:2, 289:18,
311:6
PERIOD [12] - 192:5, 204:5, 204:24,
205:1, 205:3, 205:6, 205:7, 205:14,
205:15, 205:23, 207:16, 218:5
PERIOD [1] - 1:5
PERMISSIBLE [1] - 260:23
PERMITTED [1] - 310:3
PERSINGER [17] - 296:17, 296:20,
296:25, 297:3, 297:17, 297:18,
297:22, 298:9, 298:17, 299:4, 299:16,
299:18, 300:10, 301:7, 302:9, 303:15
PERSON [19] - 205:21, 205:24, 205:25,
219:22, 234:18, 242:16, 243:4,
243:15, 243:22, 259:9, 260:17, 269:6,
291:14, 298:23, 299:7, 300:12,
307:17, 307:19
PERSONAL [1] - 286:4
PERSONALLY [2] - 238:1, 259:7
PERSUADED [1] - 287:2
PETITION [2] - 223:24, 224:4
PETTY [4] - 243:14, 243:15, 243:19,
243:24
PHONE [25] - 179:18, 192:3, 192:4,
203:5, 203:9, 204:23, 204:24, 205:13,
205:16, 205:17, 206:5, 206:18, 207:4,
207:16, 217:5, 218:2, 219:12, 245:13,
250:14, 250:25, 276:2, 300:12, 302:8
PHONES [7] - 205:2, 205:5, 205:8,
205:9, 217:10, 217:11, 217:13
PHRASE [1] - 220:1
PHRASED [1] - 286:13
PHRONT [28] - 165:12, 192:21, 195:2,
196:16, 199:17, 201:13, 213:1, 214:6,
241:2, 241:20, 251:16, 252:1, 252:3,
252:6, 252:18, 253:15, 253:22,
254:12, 254:20, 255:12, 255:19,
255:22, 258:21, 262:2, 262:6, 262:12,
262:13, 262:15
PIECE [3] - 275:21, 275:23, 276:4
PIPE [1] - 296:9
PLACE [2] - 196:24, 281:8
PLANNING [1] - 275:9
PLATFORM [2] - 251:5, 251:9
PLAY [1] - 276:18
326
PLAYED [2] - 220:20, 240:19
PLEA [5] - 305:21, 310:13, 310:20,
310:21
PLEADED [3] - 275:15, 306:15, 309:3
PLEAS [5] - 304:23, 305:12, 306:1,
308:22, 310:3
PLUS [3] - 220:4, 299:7, 299:8
PM [2] - 160:6, 163:1
PNC [1] - 232:17
POINT [30] - 168:9, 177:17, 185:23,
190:13, 222:8, 222:9, 223:19, 224:3,
237:18, 244:22, 247:22, 273:9,
273:13, 276:21, 278:16, 281:15,
285:13, 286:17, 289:14, 290:22,
291:2, 291:18, 292:15, 296:20, 300:9,
304:12, 304:21, 308:3, 308:6, 311:11
POINTED [1] - 225:1
POINTING [1] - 275:3
PORTION [1] - 196:12
PORTION [1] - 1:5
POSITION [1] - 310:16
POSITIVE [2] - 249:13, 303:21
POSSESSION [4] - 204:22, 204:23,
211:4, 219:6
POSSIBILITY [1] - 223:18
POSSIBLY [1] - 224:14
POSTED [1] - 198:12
POTENTIALLY [2] - 287:10, 305:22
PPP [15] - 164:9, 181:4, 192:10, 200:10,
200:13, 200:20, 208:17, 239:20,
251:19, 255:6, 261:4, 265:3, 277:22,
279:5, 279:25
PRACTICE [1] - 259:15
PREARRANGED [1] - 268:24
PRECISELY [1] - 307:7
PRECLUDE [1] - 307:5
PREDICTED [1] - 305:4
PREJUDICE [1] - 295:21
PREMIER [1] - 213:8
PREPAID [2] - 199:1, 199:8
PREPARATION [1] - 258:24
PREPARED [2] - 165:12, 183:9
PREPARING [4] - 243:11, 248:22, 300:3
PRESENCE [1] - 309:6
PRESENT [4] - 216:24, 269:25, 280:21,
286:2
PRESENTED [2] - 229:17, 232:19
PRESERVED [1] - 212:11
PRETEND [1] - 293:18
PRETRIAL [4] - 304:20, 304:21, 307:1,
309:10
PRETTY [7] - 191:5, 220:12, 270:21,
276:9, 281:11, 302:14, 305:17
PREVIOUS [1] - 234:22
PREVIOUSLY [9] - 169:4, 169:18,
170:2, 175:16, 196:22, 213:17,
223:22, 227:13, 281:19
PRIMARILY [3] - 200:9, 226:13, 243:16
PRIMARY [1] - 247:11
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 168 of 174
PRINTED [1] - 236:18
PRITTY [2] - 160:24, 312:15
PROBLEM [7] - 163:19, 253:10, 292:24,
292:25, 297:3, 297:4, 300:25
PROBLEMS [1] - 297:15
PROCEEDINGS [6] - 209:6, 214:13,
215:14, 271:25, 311:14, 312:7
PROCEEDINGS [2] - 160:9, 163:1
PROCESS [4] - 240:22, 248:15, 260:7,
308:25
PROCESSED [2] - 217:10, 217:11
PRODUCED [2] - 290:23, 290:25
PROFFER [8] - 268:16, 269:15, 270:2,
270:4, 270:13, 272:25, 273:9, 277:17
PROFFERS [1] - 275:2
PROGRAM [3] - 181:4, 192:10, 198:25
PROGRAM [1] - 185:21
PROHIBITED [1] - 1:9
PROHIBITED [1] - 302:22
PROJECT [6] - 220:24, 221:5, 221:12,
237:7, 237:8, 237:11
PROJECTS [1] - 221:23
PROOF [1] - 275:8
PROPENSITY [3] - 260:11, 260:16,
260:22
PROPOSAL [2] - 221:4, 222:1
PROPOSE [1] - 300:21
PROSECUTOR [2] - 220:22, 221:2
PROSECUTORS [1] - 269:10
PROTECTION [1] - 185:21
PROVE [5] - 260:17, 271:9, 272:8,
288:23, 292:11
PROVIDE [5] - 220:23, 241:7, 284:25,
305:16, 310:24
PROVIDED [2] - 221:3, 228:21
PROVIDING [1] - 167:14
PRUDENT [1] - 303:4
PUBLIC [1] - 212:12
PUBLISH [45] - 164:12, 164:20, 165:6,
165:21, 167:4, 168:1, 168:15, 168:23,
169:13, 170:9, 171:7, 171:17, 172:10,
172:16, 173:22, 176:3, 178:3, 178:25,
179:9, 183:13, 184:17, 184:25,
185:15, 186:12, 186:23, 187:14,
189:4, 190:20, 192:15, 194:21, 195:5,
196:19, 197:2, 197:16, 198:18, 201:6,
202:16, 206:9, 206:11, 206:16,
207:22, 208:10, 208:23, 213:15, 214:3
PUBLISHED [6] - 192:17, 196:21,
197:3, 207:24, 208:11, 208:24
PULL [13] - 165:22, 167:5, 171:1,
184:10, 185:16, 198:6, 198:18, 201:7,
204:9, 228:18, 230:3, 232:9, 234:11
PULLING [1] - 170:5
PUNCTUATING [1] - 190:11
PUNCTUATION [3] - 190:6, 191:6,
191:8
PURCHASES [1] - 193:24
PURCHASING [1] - 193:15
PURE [1] - 291:25
PURPORTEDLY [1] - 214:5
PURPOSE [5] - 222:20, 258:23, 260:23,
309:25, 310:2
PURPOSES [4] - 199:10, 219:8, 260:22,
310:4
PURSUANT [5] - 194:5, 196:24, 199:25,
258:1, 270:2
PURSUED [1] - 258:11
PUT [14] - 173:9, 177:15, 216:9, 247:23,
250:6, 272:2, 275:22, 276:4, 281:4,
282:12, 301:7, 305:7, 309:3, 311:7
PUTTING [3] - 163:10, 259:17, 307:10
PYFROM [33] - 167:24, 168:10, 169:9,
170:12, 170:22, 177:18, 177:20,
181:12, 182:17, 183:19, 185:25,
189:11, 189:17, 189:25, 190:4,
190:23, 191:11, 191:20, 191:24,
194:2, 195:3, 195:8, 195:12, 195:17,
196:16, 197:6, 203:19, 204:22,
206:19, 207:7, 207:15, 207:17, 267:2
PYFROM-FOSTER [26] - 167:24,
168:10, 169:9, 170:12, 170:22,
177:18, 177:20, 181:12, 182:17,
183:19, 185:25, 189:11, 189:17,
189:25, 190:23, 191:11, 191:20,
191:24, 195:12, 203:19, 204:22,
206:19, 207:7, 207:15, 207:17, 267:2
PYFROM-FOSTER'S [2] - 190:4, 194:2
Q
QUARTER [18] - 166:15, 166:18,
166:19, 167:1, 172:23, 175:8, 176:14,
176:16, 176:17, 176:20, 177:3,
177:15, 178:14, 180:8, 180:9, 211:15
QUARTERLY [1] - 211:11
QUESTION'S [1] - 286:13
QUESTIONING [3] - 287:21, 303:5,
308:3
QUESTIONINGS [1] - 258:11
QUESTIONS [25] - 209:7, 215:4, 215:6,
220:23, 222:4, 226:7, 238:18, 256:7,
258:21, 273:21, 273:23, 274:2, 274:8,
276:20, 284:6, 284:8, 284:13, 284:21,
290:2, 303:23, 307:1, 307:9, 307:15,
308:5, 308:7
QUICK [1] - 169:25
QUICKBOOKS [1] - 174:4
QUITE [2] - 245:7, 245:10
R
RADAR [1] - 222:8
RAISED [1] - 304:20
RAN [1] - 212:14
RANGE [1] - 204:11
RANGES [1] - 204:11
RAPID [18] - 198:25, 199:3, 199:16,
199:21, 200:7, 200:14, 200:22,
200:24, 201:1, 201:14, 202:6, 202:7,
202:19, 206:25, 207:19, 208:1, 208:5,
327
266:9
RAPID! [1] - 199:1
RE [1] - 168:13
RE-SENT [1] - 168:13
REACH [1] - 237:23
READ [14] - 168:3, 263:13, 263:22,
281:8, 281:20, 282:12, 283:25,
285:14, 285:24, 286:1, 287:6, 288:22,
290:14, 291:1
READING [3] - 280:20, 289:14, 292:1
REAL [10] - 169:25, 180:24, 201:21,
220:24, 221:5, 221:12, 221:23, 237:7,
262:1, 274:7
REALLY [12] - 190:11, 231:2, 231:24,
238:8, 254:10, 258:22, 272:10, 301:3,
301:21, 306:14, 306:21, 307:13
REASON [2] - 223:12, 231:24
REBUILDING [1] - 262:9
REBUT [2] - 261:5, 310:4
RECALLED [1] - 277:5
RECEIPT [2] - 234:5, 234:6
RECEIVED [11] - 167:1, 177:3, 248:4,
257:22, 262:22, 265:11, 266:23,
274:25, 280:7, 282:2, 291:14
RECENTLY [2] - 266:9, 305:9
RECESS [3] - 215:14, 271:25, 311:14
RECIPIENT [1] - 229:23
RECOGNIZE [6] - 202:1, 202:5, 203:15,
227:11, 252:16, 290:24
RECOGNIZED [1] - 225:15
RECOLLECTION [22] - 231:9, 267:6,
280:12, 281:1, 281:5, 281:7, 281:12,
282:6, 282:9, 282:10, 282:13, 284:22,
285:1, 285:8, 285:10, 285:11, 285:15,
285:25, 286:8, 286:10, 286:11, 287:3
RECORD [14] - 163:21, 163:22, 194:22,
210:17, 215:21, 215:22, 216:10,
224:20, 226:24, 229:17, 232:21,
234:25, 236:4, 236:25
RECORDED [1] - 160:23
RECORDING [1] - 220:20
RECORDKEEPING [1] - 211:22
RECORDS [18] - 180:22, 194:1, 199:21,
200:6, 203:4, 203:18, 203:23, 206:22,
211:2, 211:3, 212:11, 216:14, 216:22,
221:15, 221:16, 221:23, 252:6, 304:3
RECRUITED [3] - 239:18, 245:1, 245:2
RECRUITER [7] - 242:16, 243:4,
243:15, 244:17, 244:24, 248:18,
264:15
RECRUITERS [6] - 239:24, 240:3,
240:4, 247:25, 248:6, 248:12
REDACTED [1] - 235:21
REDDING [5] - 245:4, 245:19, 245:20,
279:1, 308:10
REDIRECT [1] - 305:7
REFER [1] - 228:25
REFERENCE [4] - 236:14, 307:5,
310:14, 310:16
REFERENCED [1] - 188:20
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 169 of 174
REFERENCES [2] - 280:15, 287:23
REFERENCING [1] - 1:7
REFERRAL [1] - 238:8
REFERRED [3] - 238:7, 289:23
REFERRING [3] - 242:6, 278:25, 294:18
REFERS [1] - 259:6
REFLECT [2] - 194:22, 196:7
REFRESH [18] - 231:3, 231:9, 241:7,
267:6, 280:12, 280:25, 281:6, 281:12,
282:5, 282:13, 284:21, 285:1, 285:7,
285:9, 285:15, 285:25, 286:8, 287:3
REFRESHED [3] - 281:5, 286:9, 286:11
REFRESHES [1] - 287:4
REFRESHING [2] - 282:9, 282:10
REGARDING [4] - 198:25, 229:14,
265:2, 277:22
REGISTER [1] - 255:24
REGISTERED [1] - 223:14
REGISTRATION [4] - 252:18, 253:21,
254:19, 257:4
REGULAR [2] - 212:1, 212:18
REGULARLY [3] - 207:7, 207:12,
212:11
REINSTATED [1] - 256:1
RELATED [3] - 181:3, 221:5, 236:2
RELATES [1] - 266:4
RELEVANCE [12] - 204:3, 205:1,
205:23, 206:6, 256:3, 272:3, 272:5,
276:8, 276:9, 276:11, 294:3, 294:4
RELEVANT [21] - 204:21, 204:24, 205:1,
205:2, 205:7, 205:11, 205:15, 205:23,
256:7, 258:22, 258:25, 259:19,
260:25, 261:3, 261:5, 290:11, 293:25,
295:25, 305:22, 307:8, 307:14
RELIED [1] - 271:9
RELISTEN [2] - 279:7, 280:10
RELY [2] - 275:5, 309:24
RELYING [2] - 274:19, 274:21
REMEMBER [15] - 220:25, 221:7, 221:8,
224:5, 232:12, 234:2, 238:4, 240:7,
240:8, 241:4, 257:6, 257:7, 262:24,
263:1, 285:18
REMINDED [1] - 271:18
REMINDS [1] - 285:20
REMITTER [1] - 234:19
RENEWED [1] - 276:21
REPLIED [1] - 168:6
REPLY [1] - 311:6
REPORT [22] - 280:11, 280:20, 280:21,
281:4, 281:8, 281:13, 281:20, 281:22,
282:8, 285:3, 285:16, 285:19, 285:23,
285:24, 286:11, 286:14, 286:15,
288:22, 289:5, 289:14, 290:20, 292:4
REPORTER [4] - 1:4, 1:8, 160:24,
312:15
REPORTS [4] - 168:21, 175:9, 286:2,
286:3
REPRESENT [1] - 210:25
REPRESENTED [2] - 196:12, 269:1
REQUEST [2] - 221:16, 225:4
REQUESTED [2] - 237:13, 261:23
REQUESTING [1] - 221:23
RESEND [1] - 168:5
RESERVATION [8] - 173:16, 181:22,
197:23, 200:16, 213:2, 233:19,
242:17, 242:21
RESIDENCE [8] - 223:15, 223:17,
223:20, 225:3, 225:24, 226:2, 226:21,
226:25
RESOURCE [1] - 213:7
RESPONDING [1] - 191:7
RESPONSE [11] - 191:6, 221:6, 221:21,
238:6, 257:23, 262:23, 265:12,
305:14, 306:18, 311:6, 311:9
RESPONSES [2] - 190:7, 301:19
RESPONSIBLE [6] - 239:18, 242:22,
243:11, 244:19, 279:16, 281:3
REST [1] - 205:18
RESTATE [1] - 229:16
RESTRICTED [1] - 1:4
RETAIL [1] - 193:24
RETRIEVAL [1] - 212:5
RETURNS [1] - 214:24
REVENUE [3] - 167:12, 210:21, 211:1
REVIEW [8] - 181:1, 191:22, 192:3,
192:7, 200:6, 201:25, 251:10, 257:19
REVIEWED [5] - 189:23, 250:20,
251:13, 257:17, 264:18
REVIEWING [1] - 250:7
RICK [1] - 249:10
RICKY [31] - 244:23, 244:24, 245:23,
246:8, 247:17, 264:4, 265:1, 265:5,
265:24, 266:14, 266:21, 267:24,
268:7, 268:8, 269:15, 270:22, 271:6,
271:9, 271:10, 272:7, 272:8, 272:11,
272:21, 273:6, 274:5, 274:19, 275:6,
277:15, 278:23, 308:5, 308:9
RIGHTS [3] - 308:24, 308:25
RING [1] - 239:21
RISK [1] - 299:15
RMR [2] - 160:24, 312:15
ROAD [2] - 272:7, 276:14
ROAD [2] - 192:24, 193:1
ROADRUNNER [7] - 213:6, 227:15,
229:4, 229:6, 230:20, 230:23, 230:24
ROLE [8] - 211:1, 239:16, 240:9,
240:10, 240:18, 240:19, 242:15, 308:2
ROOM [4] - 213:3, 245:4, 245:20,
245:21
ROSWELL [2] - 192:24, 193:1
RULE [10] - 194:6, 200:1, 252:21, 258:2,
258:9, 258:14, 259:4, 260:4, 260:11,
263:5
RULE [2] - 256:23, 274:13
RULES [2] - 258:3, 283:18
RULES [1] - 281:11
RULING [1] - 310:12
RUN [3] - 276:15, 294:23, 295:15
RUNG [2] - 292:19, 292:20
RUNNING [1] - 297:12
328
RYAN [3] - 245:5, 247:14, 247:15
S
S-A-L-V-A-T-O-R-E [1] - 210:18
SALL [2] - 249:3, 249:5
SALVATORE [2] - 210:4, 210:18
SALVATORE [1] - 210:11
SAMIR [1] - 160:15
SARALIENE [1] - 160:18
SAVE [2] - 275:3, 296:5
SAW [6] - 184:23, 190:25, 197:13,
200:17, 218:19, 229:6
SBF [9] - 280:16, 287:25, 288:9, 289:12,
289:24, 290:6, 291:2, 291:6, 291:10
SCAM [1] - 291:19
SCENARIO [1] - 283:14
SCHEDULING [3] - 163:8, 209:12,
297:25
SCREEN [1] - 253:8
SCROLL [5] - 166:10, 174:11, 186:24,
193:10, 201:7
SE [1] - 272:9
SEARCH [5] - 216:17, 216:21, 216:23,
216:25, 217:24
SEARCHES [2] - 212:14, 212:16
SEAT [2] - 277:4, 283:6
SEATED [6] - 163:2, 163:23, 215:24,
271:21, 277:6, 277:9
SECOND [20] - 167:5, 202:12, 222:16,
222:17, 222:23, 223:2, 225:11,
225:12, 228:9, 229:10, 233:12, 237:9,
237:15, 238:14, 272:2, 288:14,
290:18, 291:4, 294:8, 301:5
SECRET [14] - 280:1, 280:13, 281:23,
287:11, 287:22, 288:16, 288:20,
289:8, 289:9, 289:20, 289:23, 290:24,
294:25, 295:2
SECRETARY [5] - 230:24, 252:6,
252:17, 255:23, 257:4
SECRETARY [2] - 254:5, 254:25
SECTION [1] - 228:18
SECTIONS [2] - 232:9
SEE [32] - 168:22, 174:16, 174:23,
176:24, 181:2, 188:19, 191:16,
192:25, 193:8, 199:14, 201:10,
228:17, 229:2, 229:12, 229:14,
232:15, 239:3, 243:18, 247:1, 254:1,
258:5, 263:18, 267:2, 267:18, 276:10,
276:20, 283:1, 283:4, 291:6, 291:17,
295:18, 311:13
SEEING [9] - 231:19, 257:7, 257:8,
262:24, 262:25, 263:1, 280:11, 282:5
SEEKING [3] - 237:16, 259:13, 310:20
SEEM [8] - 220:11, 262:14, 286:20,
287:7, 292:17, 292:19, 297:14, 303:4
SEEMING [1] - 282:23
SEIZED [1] - 217:11
SEMANTICS [1] - 286:13
SEND [9] - 168:12, 174:2, 179:7,
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 170 of 174
179:12, 180:16, 185:19, 200:22,
213:22, 248:13
SENDER [1] - 229:21
SENDING [2] - 174:4, 273:11
SENDS [2] - 265:24, 266:14
SENSE [2] - 286:18, 287:5
SENT [31] - 165:9, 167:8, 168:13,
168:25, 169:4, 169:15, 169:18,
170:19, 172:3, 175:16, 176:1, 178:19,
179:25, 181:18, 182:24, 183:2, 185:8,
185:10, 186:2, 187:8, 188:24, 198:21,
199:15, 251:25, 261:1, 261:17,
261:21, 267:1, 267:4
SENTENCE [1] - 190:8
SENTENCE-TYPE [1] - 190:8
SENTENCES [4] - 190:5, 190:12, 191:5,
191:7
SEPARATE [3] - 225:4, 294:24, 295:2
SEPARATED [1] - 224:3
SEPARATELY [1] - 205:9
SEPARATION [1] - 224:2
SERIES [2] - 173:24, 212:23
SERIOUS [1] - 194:23
SERVE [2] - 219:10, 219:25
SERVED [1] - 262:6
SERVICE [17] - 167:12, 210:21, 211:1,
280:1, 280:13, 281:23, 287:11,
287:23, 288:16, 288:20, 289:8, 289:9,
289:20, 289:23, 290:24, 294:25, 295:2
SERVICES [17] - 164:7, 165:19, 165:20,
166:16, 167:13, 168:22, 171:23,
197:19, 197:22, 198:5, 200:17, 213:3,
213:4, 213:7, 245:21, 247:2, 247:3
SERVICES [1] - 195:4
SESSION [1] - 160:6
SESSION [1] - 277:17
SESSIONS [2] - 268:16, 269:15
SET [6] - 172:25, 199:6, 199:7, 206:22,
256:7, 266:9
SETS [3] - 262:13, 270:4, 270:5
SETTING [1] - 270:13
SETUP [1] - 308:6
SEVERAL [4] - 175:8, 205:5, 244:21,
309:7
SEVERELY [1] - 300:4
SHAKES [1] - 307:2
SHAKING [1] - 168:6
SHOCKED [1] - 220:7
SHOP [1] - 213:8
SHORT [7] - 190:10, 215:12, 271:16,
296:15, 297:6, 298:11, 304:7
SHORTENED [3] - 190:10, 190:13,
191:8
SHORTLY [1] - 180:2
SHOW [10] - 219:19, 231:2, 236:6,
256:6, 258:19, 258:24, 259:14, 261:4,
294:13, 295:10
SHOWING [6] - 204:21, 205:7, 205:15,
219:15, 226:11, 262:20
SHOWN [2] - 213:17, 221:9
SHOWS [6] - 166:16, 205:12, 220:7,
235:1, 256:8, 286:5
SIC [2] - 222:4, 293:11
SID [2] - 225:13, 225:16
SIDE [24] - 164:21, 165:7, 167:5,
172:17, 173:9, 173:10, 181:15,
182:20, 189:5, 189:7, 189:10, 225:12,
226:5, 253:5, 272:2, 310:7, 310:10
SIGNAL [3] - 251:8, 251:9, 251:11
SIGNATURE [9] - 195:8, 227:15,
227:22, 227:23, 228:2, 228:4, 228:9,
229:6, 265:8
SIGNED [2] - 265:7, 266:17
SIGNER [1] - 231:22
SIGNIFY [1] - 226:5
SIMILAR [5] - 220:3, 221:3, 235:17,
240:19, 251:7
SINGLE [2] - 201:1, 275:14
SITE [8] - 203:6, 203:8, 207:3, 298:19,
299:1, 300:15, 300:16, 301:7
SITUATION [1] - 219:21
SIX [3] - 296:13, 298:10
SKIP [1] - 293:17
SLATON [6] - 244:13, 244:15, 247:5,
247:6, 247:8, 247:12
SLIGHT [2] - 276:9, 276:11
SLIGHTLY [1] - 300:21
SMALL [6] - 280:17, 287:25, 289:13,
290:7, 291:3, 291:11
SMH [1] - 168:6
SNEAK [1] - 194:18
SO.. [2] - 274:16, 298:8
SOLUTION [2] - 300:22, 302:15
SOLVE [1] - 300:24
SOLVED [1] - 253:10
SOMEONE [16] - 209:14, 255:2, 259:3,
259:6, 275:10, 275:23, 276:3, 280:16,
284:16, 287:24, 288:9, 289:12,
289:16, 290:6, 291:2, 291:10
SOMETIMES [1] - 240:2
SOMEWHERE [3] - 220:13, 224:9,
306:25
SOON [1] - 163:18
SORRY [22] - 169:23, 176:16, 194:10,
202:13, 209:2, 214:3, 248:2, 252:13,
257:19, 259:24, 260:14, 264:21,
266:19, 267:21, 272:13, 288:3, 289:6,
291:7, 292:16, 301:5, 303:17, 306:17
SORT [19] - 190:9, 190:13, 193:24,
239:17, 240:11, 242:16, 243:3, 243:4,
243:15, 251:6, 259:22, 259:25, 264:1,
268:16, 270:4, 270:5, 273:9, 273:13,
296:18
SOUND [2] - 224:9, 278:1
SOUNDS [6] - 170:16, 256:22, 260:11,
260:19, 273:21, 286:12
SOUTH [1] - 279:22
SPEAKING [1] - 302:23
SPECIAL [2] - 209:18, 209:20
SPECIFICALLY [5] - 214:21, 214:23,
329
221:21, 227:1, 266:6
SPELL [1] - 210:17
SPEND [2] - 220:15, 249:25
SPENT [6] - 203:1, 220:16, 223:17,
223:19, 250:2, 250:7
SPILL [1] - 287:6
SPREADSHEET [8] - 167:21, 167:23,
168:25, 169:4, 173:12, 173:15,
181:21, 182:23
SPREADSHEETS [3] - 167:19, 186:9,
187:20
STACEY [1] - 228:12
STAMP [14] - 166:24, 176:24, 177:1,
177:10, 177:16, 177:20, 178:15,
178:16, 178:19, 178:20, 213:20,
265:8, 265:9, 265:10
STAMP'S [1] - 178:17
STAMPED [19] - 164:25, 167:1, 169:20,
172:4, 175:18, 176:9, 177:3, 184:3,
185:6, 185:10, 186:16, 187:5, 187:8,
188:1, 188:16, 188:25, 213:23, 214:1,
214:9
STAMPS [4] - 166:17, 170:25, 171:4,
171:25
STAND [4] - 209:23, 277:5, 283:20,
299:22
STANDARD [2] - 262:14, 310:13
STANDS [1] - 225:16
STAR [4] - 213:3, 245:4, 245:20, 245:21
START [1] - 231:18
STARTED [6] - 169:10, 181:12, 182:17,
202:22, 270:19, 299:25
STARTING [1] - 195:18
STATE [1] - 210:17
STATE [5] - 230:24, 252:6, 252:17,
255:23, 257:4
STATEMENT [23] - 180:19, 180:24,
193:5, 193:19, 195:17, 196:4, 197:19,
220:6, 266:1, 266:4, 266:15, 266:17,
267:2, 286:20, 287:13, 292:6, 292:11,
293:14, 294:19, 295:5, 295:12, 295:16
STATEMENTS [2] - 270:16, 274:13
STATES [6] - 160:1, 160:4, 160:10,
160:16, 160:25, 312:3
STATES [1] - 210:4
STAYED [1] - 191:25
STAYING [1] - 226:21
STENOGRAPHICALLY [1] - 160:23
STEP [5] - 209:22, 215:7, 272:16,
283:10, 311:4
STICKER [1] - 174:25
STILL [12] - 201:23, 240:21, 254:22,
254:25, 256:8, 257:17, 261:9, 292:21,
296:11, 301:2, 304:15, 311:11
STIPULATION [1] - 259:9
STITES [32] - 164:6, 209:20, 215:18,
216:6, 224:18, 231:9, 238:16, 238:22,
261:16, 275:6, 281:19, 291:23, 293:1,
295:11, 296:12, 296:24, 299:12,
299:15, 299:16, 299:18, 299:21,
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 171 of 174
299:24, 300:9, 300:23, 301:3, 301:8,
302:5, 302:6, 302:7, 302:21, 303:5
STITES [1] - 162:3
STITES'S [3] - 163:11, 209:18, 294:24
STONE [1] - 225:17
STORED [1] - 212:7
STORES [1] - 193:24
STRING [3] - 189:7, 189:10, 190:22
STRINGS [1] - 189:13
STRUCTURE [1] - 190:8
STUFF [5] - 190:11, 248:23, 261:4,
283:25
STYLES [1] - 190:1
STYMIE [1] - 302:2
SUBJECT [11] - 164:19, 172:14, 173:7,
175:5, 175:24, 178:8, 182:12, 183:18,
187:18, 188:7, 272:15
SUBJECT [1] - 184:21
SUBMIT [2] - 239:20, 245:1
SUBMITTED [2] - 165:3, 200:21
SUBMITTING [1] - 239:18
SUBPOENA [15] - 219:6, 219:10,
219:25, 221:6, 221:10, 221:16,
221:18, 221:22, 237:14, 241:25,
242:3, 257:23, 262:23, 265:12, 265:13
SUBPOENAED [2] - 241:14, 242:9
SUBPOENAS [1] - 216:15
SUBSTANTIVE [1] - 259:8
SUCCESS [3] - 174:16, 213:4, 246:16
SUGGEST [1] - 275:18
SUGGESTED [2] - 299:20, 305:19
SUGGESTING [3] - 305:1, 309:8,
309:15
SUGGESTION [1] - 275:16
SUMMARIZED [1] - 206:24
SUMMARY [2] - 202:18, 206:18
SUPPLY [1] - 213:8
SUPPORT [1] - 274:22
SUPPOSED [2] - 248:7, 296:15
SUPPOSEDLY [1] - 214:9
SURPRISED [2] - 220:7, 220:11
SUSIE [1] - 273:17
SUSPECT [1] - 291:19
SUSTAIN [1] - 206:2
SUSTAINED [3] - 293:22, 294:7, 295:21
SWORN [1] - 210:12
SYSTEM [9] - 211:21, 211:22, 212:1,
212:4, 212:5, 212:6, 212:7, 212:14,
212:16
SYSTEM [2] - 212:6, 213:7
T
T-MOBILE [3] - 203:4, 203:23, 206:22
TAL [1] - 160:14
TALDRID [2] - 278:4, 278:5
TALDRID [1] - 274:6
TALDRID [1] - 278:6
TALDRIN [1] - 278:3
TALKS [2] - 220:1, 220:2
TARGET [1] - 274:25
TASKED [1] - 211:2
TAX [3] - 211:20, 214:16, 214:23
TAXES [1] - 211:6
TAXPAYER [4] - 212:8, 213:25, 214:8,
214:9
TAXPAYERS [1] - 212:10
TEAM [1] - 300:6
TECHNIQUE [1] - 218:19
TECHNOLOGY [1] - 213:7
TELDRIN [106] - 164:16, 164:18, 164:19,
165:9, 166:1, 166:3, 166:5, 166:8,
167:8, 168:6, 168:14, 168:18, 168:25,
169:4, 171:10, 172:13, 173:6, 173:25,
174:3, 175:4, 175:16, 175:23, 177:13,
178:7, 178:18, 179:12, 180:16, 181:2,
181:9, 181:18, 182:24, 183:2, 183:16,
184:12, 184:20, 185:9, 185:19,
186:21, 188:6, 188:21, 189:8, 189:20,
189:21, 189:24, 191:17, 191:20,
191:25, 192:8, 192:12, 192:20, 193:5,
193:19, 196:15, 198:9, 198:21,
199:15, 201:17, 201:20, 202:8,
202:18, 203:1, 203:4, 203:9, 203:18,
203:23, 204:22, 205:12, 206:19,
207:3, 207:6, 207:15, 207:17, 207:19,
208:19, 244:10, 246:11, 246:12,
248:15, 249:14, 249:17, 249:19,
249:22, 250:18, 270:8, 271:6, 271:10,
271:11, 272:24, 273:2, 273:10,
273:13, 274:3, 274:4, 274:20, 274:23,
275:10, 276:5, 277:23, 278:1, 278:8,
279:9, 294:17, 295:8, 295:11, 308:11,
308:19
TELDRIN [2] - 160:7, 160:17
TELDRIN_FOSTER@YAHOO [3] -
182:12, 186:7, 187:17
TELDRINFOSTER@ICLOUD [1] -
169:18
TELEGRAM [6] - 250:20, 250:21,
250:24, 251:1, 251:2, 251:14
TELEPHONE [2] - 280:7, 285:7
TEMPLATE [1] - 167:23
TEN [2] - 216:22, 273:24
TERM [1] - 259:6
TERMS [2] - 270:5, 270:13
TESTIFIED [13] - 210:13, 226:20,
230:15, 255:5, 258:10, 258:13, 259:7,
264:13, 281:2, 287:19, 301:14,
301:16, 301:20
TESTIFY [5] - 259:10, 281:5, 304:14,
305:13, 306:2
TESTIFYING [5] - 211:3, 231:24,
232:12, 300:1, 308:23
TESTIMONY [13] - 163:7, 209:18, 225:1,
228:21, 233:22, 234:22, 236:1, 259:7,
259:9, 272:15, 274:18, 288:5, 300:24
TEXT [7] - 184:12, 190:10, 190:22,
233:1, 233:2, 233:3, 236:5
TEXTS [2] - 206:19, 207:8
330
THANKING [1] - 167:13
THAT'D [1] - 247:17
THE [179] - 1:2, 1:4, 1:6, 1:7, 1:8, 1:10,
160:1, 160:10, 160:14, 160:17,
160:20, 163:2, 163:5, 163:16, 163:19,
163:21, 163:23, 170:4, 170:7, 190:18,
194:9, 194:11, 194:14, 194:20,
194:22, 195:1, 195:2, 197:1, 198:8,
200:4, 202:15, 204:7, 204:9, 204:17,
204:20, 204:25, 205:10, 205:19,
206:2, 206:11, 206:15, 209:2, 209:4,
209:9, 209:24, 210:2, 210:5, 210:6,
210:7, 210:8, 210:9, 215:2, 215:3,
215:7, 215:9, 215:11, 215:19, 215:21,
215:24, 231:6, 238:17, 238:18,
252:24, 256:5, 256:11, 256:14,
256:18, 256:22, 258:5, 258:7, 258:17,
259:2, 259:11, 259:24, 260:2, 260:5,
260:13, 261:7, 261:11, 261:14, 263:7,
265:17, 271:12, 271:21, 272:2,
272:16, 272:18, 272:20, 273:15,
274:11, 274:17, 276:6, 277:3, 277:6,
277:9, 280:24, 281:10, 281:14,
282:15, 282:23, 283:6, 283:13,
283:22, 283:24, 284:3, 284:5, 284:8,
284:12, 284:19, 284:24, 285:6,
285:12, 286:5, 286:12, 286:18,
286:22, 287:1, 287:22, 288:4, 289:11,
289:25, 290:2, 290:12, 290:20, 291:1,
291:6, 291:9, 291:17, 291:22, 292:5,
292:13, 293:8, 293:10, 293:17,
293:20, 293:22, 294:3, 294:6, 294:9,
294:21, 295:17, 296:1, 296:3, 296:19,
297:2, 297:14, 297:21, 298:9, 298:16,
298:21, 299:4, 299:13, 300:7, 300:16,
300:18, 300:20, 301:10, 301:13,
301:22, 302:2, 302:4, 302:19, 303:1,
303:3, 303:22, 304:8, 304:10, 304:16,
306:3, 306:18, 306:24, 308:12, 309:1,
310:6, 310:11, 310:22, 311:1
THEMSELVES [1] - 275:3
THEREFORE [4] - 256:23, 258:14,
288:12, 311:5
THINKS [1] - 267:9
THIRD [2] - 180:8, 286:3
THOMAS [148] - 164:17, 165:10, 166:2,
167:8, 168:5, 168:9, 168:12, 168:19,
169:10, 170:11, 170:14, 170:24,
171:11, 172:14, 173:7, 173:24, 174:2,
175:5, 175:24, 176:7, 177:9, 177:17,
178:8, 178:18, 179:7, 179:12, 179:23,
180:16, 181:2, 181:10, 181:12,
181:18, 182:12, 182:18, 182:24,
183:2, 183:17, 183:19, 184:12,
184:20, 185:8, 185:19, 185:24, 186:8,
186:22, 187:18, 188:7, 188:21, 189:8,
189:11, 189:16, 189:24, 190:4, 190:9,
190:22, 191:11, 191:19, 191:25,
192:1, 192:8, 192:13, 198:4, 198:21,
199:15, 204:15, 208:6, 217:21,
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 172 of 174
237:21, 237:23, 239:15, 239:17,
240:5, 240:14, 240:24, 241:12,
243:23, 245:8, 245:10, 246:1, 246:6,
246:23, 247:7, 247:10, 247:19,
247:20, 247:23, 248:5, 248:12,
248:22, 248:24, 249:2, 249:8, 250:1,
251:10, 251:14, 252:3, 253:17,
253:18, 254:3, 254:5, 254:22, 254:25,
255:6, 255:17, 256:8, 258:12, 258:13,
258:24, 259:13, 261:19, 261:21,
264:6, 264:7, 264:11, 264:25, 265:5,
265:22, 266:8, 266:15, 266:21, 267:1,
267:4, 267:25, 268:6, 268:9, 273:3,
273:4, 273:7, 273:8, 274:4, 274:10,
275:16, 275:22, 277:20, 278:24,
279:5, 305:2, 306:13, 306:14, 307:16,
307:18, 307:20, 308:4, 308:8, 309:15,
309:18, 310:5
THOMAS'S [10] - 190:7, 191:4, 199:19,
217:5, 241:17, 245:13, 249:17,
250:10, 257:23, 309:8
THOUSAND [1] - 208:9
THREE [11] - 170:23, 206:11, 206:13,
234:7, 256:4, 273:25, 298:16, 299:6,
299:8, 301:2, 303:21
THROUGHOUT [1] - 207:12
TIE [1] - 303:4
TIED [2] - 201:3, 307:16
TIMING [1] - 296:10
TIRE [4] - 187:11, 187:18, 188:19, 213:6
TIRES [1] - 249:11
TITLE [2] - 210:22, 210:23
TO [2] - 1:5, 1:9
TO-THE-POINT [1] - 190:13
TODAY [1] - 277:2
TOGETHER [3] - 243:24, 298:15, 311:7
TOMORROW [15] - 163:9, 283:1,
296:11, 296:14, 296:25, 297:5,
297:10, 298:6, 299:15, 300:1, 301:2,
302:5, 302:21, 302:22, 311:7
TOOK [10] - 197:8, 209:11, 234:18,
235:13, 236:12, 276:1, 276:2, 278:19,
292:16
TOP [9] - 176:12, 185:16, 191:14,
198:19, 239:7, 253:23, 263:14,
267:13, 290:11
TOPIC [1] - 224:13
TOPS [1] - 298:15
TOTAL [4] - 216:22, 298:16, 299:6,
299:8
TOTALLY [1] - 303:17
TOUCH [1] - 253:8
TOWARDS [2] - 179:4, 306:5
TOWER [1] - 299:7
TOWN [2] - 297:9, 300:15
TRADITIONAL [1] - 190:9
TRAIL [1] - 208:2
TRAIT [1] - 260:18
TRANSACTION [5] - 198:15, 202:24,
228:15, 229:1, 232:9
TRANSACTIONS [15] - 193:13, 193:22,
202:6, 202:18, 202:21, 203:10,
206:25, 224:23, 228:22, 230:3, 230:6,
230:7, 230:18, 231:18, 232:12
TRANSCRIPT [5] - 1:3, 1:6, 1:8, 1:9,
160:9
TRANSCRIPT [3] - 285:1, 285:3, 312:7
TRANSCRIPTS [1] - 1:3
TRANSFER [1] - 199:9
TRANSFERS [2] - 193:25, 200:14
TRANSPORTATION [4] - 213:2, 243:17,
243:23, 244:8
TRAVEL [8] - 173:16, 181:22, 197:24,
200:17, 213:2, 233:18, 242:17, 242:21
TRIAL [1] - 206:9
TRIAL [7] - 229:18, 258:10, 258:13,
259:7, 275:14, 306:7, 309:22
TRIAL [1] - 160:9
TROUBLE [1] - 191:12
TRUE [15] - 262:10, 264:12, 273:7,
273:14, 273:17, 273:18, 273:19,
287:20, 288:8, 288:10, 288:18,
288:25, 289:1, 309:19, 312:6
TRUTH [14] - 274:15, 282:17, 286:15,
286:23, 287:7, 287:14, 288:8, 288:11,
289:2, 289:19, 292:8, 292:11, 292:21,
294:12
TRY [4] - 208:16, 217:23, 217:24, 260:7
TRYING [13] - 194:18, 257:5, 260:20,
266:25, 271:5, 275:3, 277:1, 283:14,
286:19, 287:10, 287:12, 306:9, 309:14
TURN [5] - 227:8, 252:11, 253:4,
264:16, 295:4
TURNED [1] - 295:6
TWICE [1] - 194:15
TWO [24] - 171:20, 172:19, 175:12,
176:6, 187:1, 188:12, 192:9, 213:12,
219:8, 226:17, 227:19, 232:14,
232:15, 234:13, 287:10, 290:10,
290:15, 298:10, 299:4, 304:5, 304:6,
305:14, 307:25
TWO-PAGE [2] - 227:19, 290:15
TWOFOLD [1] - 219:8
TYING [1] - 304:25
TYPE [4] - 190:8, 217:12, 220:3, 251:9
TYPES [3] - 221:15, 222:1, 276:20
TYPICAL [1] - 213:25
U
UNDER [9] - 252:21, 258:3, 260:23,
261:9, 263:5, 272:4, 276:12, 276:21,
292:20
UNDERLYING [2] - 288:24, 292:6
UNDERSTATEMENT [1] - 250:5
UNDERSTOOD [1] - 248:2
UNEMPLOYMENT [1] - 211:20
UNITED [6] - 160:1, 160:4, 160:10,
160:16, 160:25, 312:3
UNITED [1] - 210:4
331
UNKNOWN [3] - 280:15, 287:24, 295:9
UNLESS [2] - 275:8, 306:2
UNSIGNED [1] - 266:1
UP [29] - 163:10, 170:5, 174:20, 176:11,
177:7, 199:7, 199:12, 204:9, 209:20,
213:9, 219:15, 219:19, 220:7, 221:9,
222:14, 224:15, 226:8, 227:10, 230:3,
234:11, 256:7, 265:2, 266:9, 266:22,
294:16, 296:11, 303:4, 304:25
US [2] - 268:21, 269:10
USAA [1] - 236:16
USES [1] - 294:14
UTILITY [1] - 174:6
UTWUAN [3] - 166:3, 166:5, 166:8
V
VARIOUS [5] - 167:19, 179:7, 200:12,
201:3, 304:3
VEHICLE [1] - 223:14
VERBIAGE [1] - 265:6
VERBOSE [1] - 190:5
VERSION [5] - 206:8, 214:1, 214:9,
271:1, 271:3
VIA [8] - 168:10, 169:10, 177:18,
181:12, 182:18, 185:24, 191:25,
277:17
VIEW [1] - 216:10
VIOLATES [1] - 308:23
VISIT [2] - 226:17, 237:9
VOIDED [1] - 174:5
VOIR [1] - 162:4
VOLUME [1] - 160:6
VS [1] - 160:5
W
WADED [1] - 283:2
WAGES [1] - 166:17
WAITING [2] - 170:25, 171:4
WALKING [1] - 222:13
WANTS [2] - 285:7, 304:14
WARRANT [2] - 216:25, 217:24
WARRANTS [3] - 216:17, 216:22,
216:23
WASTING [1] - 276:15
WEBEX [3] - 269:20, 269:22, 277:17
WEBSTER [112] - 160:18, 163:15,
170:3, 190:16, 194:7, 196:25, 200:2,
202:12, 204:3, 204:13, 204:19,
205:20, 215:13, 215:16, 238:19,
238:21, 239:3, 239:5, 252:20, 252:25,
253:2, 253:7, 253:10, 253:12, 256:6,
256:16, 256:20, 257:1, 257:2, 258:1,
258:6, 259:12, 260:1, 260:14, 260:21,
261:12, 261:15, 263:4, 263:8, 263:9,
265:15, 265:20, 271:5, 272:9, 272:19,
272:21, 273:22, 274:14, 277:2,
277:12, 277:13, 280:25, 281:11,
281:17, 281:18, 282:16, 283:21,
283:23, 284:2, 284:7, 284:11, 284:16,
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 173 of 174
286:21, 286:25, 287:9, 288:3, 288:7,
289:6, 289:22, 290:1, 290:10, 290:17,
290:23, 291:4, 291:7, 291:13, 291:18,
293:2, 293:9, 293:13, 293:19, 293:21,
293:23, 294:5, 294:8, 294:10, 295:23,
296:2, 296:10, 296:22, 297:18,
298:24, 299:12, 299:20, 300:21,
301:5, 301:11, 301:14, 302:1, 302:3,
302:16, 302:25, 303:9, 303:17,
303:20, 303:25, 304:2, 305:8, 306:17,
307:21, 308:13, 310:23
WEBSTER [31] - 205:19, 238:18, 256:5,
259:11, 260:10, 260:13, 260:20,
272:6, 272:18, 272:20, 275:6, 275:8,
276:7, 277:1, 277:10, 280:24, 281:10,
282:15, 284:9, 286:19, 289:11,
292:14, 297:16, 300:8, 302:24,
303:14, 306:11, 306:20, 309:1, 309:6,
310:22
WEDNESDAY [1] - 297:8
WEEK [3] - 297:11, 300:14, 300:15
WEEKEND [6] - 297:11, 300:2, 300:23,
301:12, 302:13, 311:9
WELCOME [1] - 215:2
WELLS [5] - 224:22, 224:23, 226:4,
227:1, 234:6
WEST [1] - 297:9
WHATSAPP [33] - 168:10, 168:12,
169:11, 170:11, 177:18, 178:10,
180:2, 181:1, 181:13, 182:18, 184:22,
185:9, 185:24, 188:20, 189:10,
189:23, 191:25, 192:7, 198:21,
205:21, 205:25, 217:3, 217:5, 232:20,
233:3, 236:5, 249:22, 250:16, 251:6,
267:7, 273:11, 275:25
WHATSAPPED [1] - 178:18
WHATSAPPS [2] - 189:8, 249:18
WHITTLEY [3] - 245:5, 247:14, 247:15
WHOLE [3] - 286:17, 301:17, 308:6
WILL [1] - 1:4
WILLING [2] - 220:15, 301:25
WIRE [1] - 232:17
WITH [1] - 1:10
WITHDRAW [1] - 196:23
WITHDRAWAL [4] - 193:14, 196:7,
234:5, 234:6
WITHDRAWALS [1] - 193:25
WITHDRAWN [1] - 256:23
WITHHOLDINGS [1] - 211:12
WITNESS [39] - 162:2, 163:7, 209:8,
209:11, 209:15, 209:19, 209:23,
209:25, 210:12, 210:23, 210:24,
210:25, 215:5, 216:1, 231:5, 258:10,
258:13, 258:15, 259:3, 259:5, 259:6,
272:17, 276:24, 277:5, 282:13,
283:12, 285:16, 285:17, 285:20,
297:5, 298:1, 298:8, 299:3, 299:17,
301:24, 301:25, 302:12
WITNESS [2] - 209:23, 215:10
WITNESS [7] - 195:2, 198:8, 210:6,
332
210:8, 215:2, 215:9, 238:17
WITNESS'S [4] - 282:10, 285:10,
285:15, 286:8
WITNESSES [18] - 216:12, 218:17,
272:22, 296:13, 296:24, 297:6, 297:7,
298:11, 298:12, 298:17, 298:25,
299:5, 299:17, 300:10, 301:6, 302:8,
303:15, 304:13
WOMAN [1] - 294:15
WONDERFUL [1] - 163:25
WONDERING [1] - 242:8
WORD [2] - 261:8, 266:19
WORDS [5] - 190:10, 190:11, 191:7,
191:8, 267:14
WORKS [1] - 243:1
WORRIED [4] - 293:6, 293:11, 296:23,
297:12
WOULD.. [1] - 241:7
WRITE [4] - 216:23, 265:2, 280:22,
285:23
WRITE-UP [1] - 265:2
WRITING [1] - 191:5
WROTE [4] - 285:16, 285:19, 290:21,
292:23
Y
Y'ALL [9] - 163:2, 163:23, 220:18,
231:6, 271:21, 277:6, 277:9, 283:6,
311:9
YAHOO [16] - 164:18, 168:18, 169:1,
169:15, 170:19, 172:3, 175:4, 175:13,
176:1, 183:2, 183:9, 183:16, 183:24,
185:8, 187:7, 188:23
YEAR [5] - 211:14, 214:22, 214:23,
231:1, 253:23
YEARS [1] - 256:4
YESTERDAY [6] - 170:23, 194:12,
197:23, 203:5, 255:5, 300:1
YOU [2] - 1:5, 1:8
YOU-ALL [1] - 282:25
Z
ZELLE [2] - 193:15, 193:24
ZOOM [2] - 269:20, 277:17
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 174 of 174File and source
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