TRANSCRIPT of Jury Trial Proceedings as to Carla Jackson, Teldrin Foster held on… — USA v. Thomas et al (Dkt. 1032)

Summary

A transcript of jury trial proceedings, Volume 8 (PM Session), dated FEBRUARY 14, 2024, Document 1032, 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 proceedings begin at 1:59 PM with instructions from Judge Boulee to the jury on the rules of law. The instructions cover the presumption of innocence, the government's burden of proof beyond a reasonable doubt, evidence and witness credibility, and the wire fraud and willfulness standards. The pages end with a word index of the transcript.

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

Full text

UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
THE FOLLOWING IS THE PDF OF AN OFFICIAL 
TRANSCRIPT.  OFFICIAL TRANSCRIPTS MAY ONLY BE FILED IN CM/ECF 
BY THE OFFICIAL COURT REPORTER AND WILL BE RESTRICTED IN 
CM/ECF FOR A PERIOD OF 90 DAYS.  YOU MAY CITE TO A PORTION   
OF THE ATTACHED TRANSCRIPT BY THE DOCKET ENTRY NUMBER, 
REFERENCING PAGE AND LINE NUMBER, ONLY AFTER THE COURT 
REPORTER HAS FILED THE OFFICIAL TRANSCRIPT; HOWEVER, YOU ARE 
PROHIBITED FROM ATTACHING A FULL OR PARTIAL TRANSCRIPT TO ANY 
DOCUMENT FILED WITH THE COURT. 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 1 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
141
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 8 (PM SESSION)
CARLA JACKSON AND
) 
TELDRIN FOSTER,
)
)
DEFENDANTS.
)
TRANSCRIPT OF JURY TRIAL PROCEEDINGS
BEFORE THE HONORABLE J.P. BOULEE
UNITED STATES DISTRICT JUDGE
FEBRUARY 14, 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
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 2 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
142
(PROCEEDINGS HELD IN OPEN COURT AT 1:59 PM, ATLANTA, GEORGIA)
(The jury entered the courtroom.)
THE COURT:  Y'all can be seated.  
Members of the jury, it's my duty to instruct you 
on the rules of law that you must use in deciding this case.  
After I've completed these instructions, you'll go to the jury 
room and begin your discussions.  What we call your 
deliberations.  
You must decide whether the government has proved the 
specific facts necessary to find each defendant guilty beyond 
a reasonable doubt.  
Your decision must be based only on the evidence 
presented during the trial.  You must not be influenced in any 
way by either sympathy for or prejudice against any defendant 
or the government.  
You must follow the law as I explain it, even if you 
do not agree with the law, and you must follow all of my 
instructions as a whole.  You must not single out or disregard 
any of the Court's instructions on the law.  
The indictment or formal charge against a defendant 
isn't evidence of guilt.  The law presumes every defendant is 
innocent.  Each defendant does not have to prove his or her 
innocence or produce any evidence at all.  A defendant does 
not have to testify, and if any defendant chose not to 
testify, you cannot consider that in any way while making your 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 3 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
143
decision.  The government must prove guilt beyond a reasonable 
doubt.  If it fails to do so, you must find the defendant not 
guilty.  
The government's burden of proof is heavy, but it 
doesn't have to prove a defendant's guilt beyond all possible 
doubt.  The government's proof only has to exclude any 
reasonable doubt concerning each defendant's guilt.
A reasonable doubt is a real doubt based on your 
reason and common sense after you've carefully and impartially 
considered all the evidence in the case.  
Proof beyond a reasonable doubt is proof so 
convincing that you would be willing to rely and act on it 
without hesitation in the most important of your own affairs.  
If you're convinced that a defendant has been proved guilty 
beyond a reasonable doubt, say so.  If you're not convinced, 
say so.  
As I said before, you must consider only the evidence 
that I have admitted in the case.  Evidence includes the 
testimony of witnesses and the exhibits admitted.  But 
anything the lawyers say is not evidence and isn't binding on 
you.  
You shouldn't assume from anything I've said that I 
have any opinion about any factual issue in this case.  Except 
for my instructions to you on the law, you should disregard 
anything I may have said during the trial in arriving at your 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 4 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
144
own decision about the facts.  
Your own recollection and interpretation of the 
evidence is what matters.  
In considering the evidence, you may use reasoning 
and common sense to make deductions and reach conclusions.  
You shouldn't be concerned about whether the evidence is 
direct or circumstantial.  
Direct evidence is the testimony of a person who 
asserts that he or she has actual knowledge of a fact, such as 
an eyewitness.  
Circumstantial evidence is proof of a chain of facts 
and circumstances that tend to prove or disprove a fact.  
There's no legal difference in the weight you may give to 
either direct or circumstantial evidence.  
When I say you must consider all the evidence, I 
don't mean that you must accept all the evidence as true or 
accurate.  You should decide whether you believe what each 
witness had to say and how important that testimony was.  In 
making that decision, you may believe or disbelieve any 
witness, in whole or in part.  The number of witnesses 
testifying concerning a particular point doesn't necessarily 
matter.  
To decide whether you believe any witness, I suggest 
that you ask yourself a few questions:  
Did the witness impress you as one who was telling 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 5 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
145
the truth?  
Did the witness have any particular reason not to 
tell the truth?
Did the witness have a personal interest in the 
outcome of the case?
Did the witness seem to have a good memory?  
Did the witness have the opportunity and ability to 
accurately observe the things he or she testified about?  
Did the witness appear to understand the questions 
clearly and answer them directly?
Did the witness's testimony differ from other 
testimony or other evidence?
If the government offers evidence the defendant made 
a statement or admission to someone, you must decide for 
yourself:  One, whether the defendant made the statement, and, 
two, if so, how much weight to give it.  To make these 
decisions, you must consider all the evidence about the 
statement, including the circumstances under which it was 
made.  
Any such statement is not evidence about any other 
defendant.  
You should ask yourself whether there was evidence 
that a witness testified falsely about an important fact.  And 
ask whether there was evidence that at some other time a 
witness said or did something or didn't say or do something 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 6 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
146
that was different from the testimony the witness gave during 
this trial.  
But keep in mind that a simple mistake doesn't mean a 
witness wasn't telling the truth as he or she remembers it.  
People naturally tend to forget some things or remember them 
inaccurately.  So if a witness misstated something, you must 
decide whether it was because of an innocent lapse in memory 
or an intentional deception.  The significance of your 
decision may depend on whether the misstatement is about an 
important fact or about an unimportant detail.  
You've been permitted to take notes during the trial, 
most of you, perhaps all of you, have taken average of that 
opportunity.  
You must use your notes only as a memory aid during 
deliberations.  You must not give your notes priority over 
your independent recollection of the evidence.  And you must 
not allow yourself to be unduly influenced by the notes of 
other jurors.  
I emphasize that notes are not entitled to any 
greater weight than your memories or impressions about the 
testimony.  
When scientific, technical or other specialized 
knowledge might be helpful, a person who has special training 
or experience in that field is allowed to state an opinion 
about the matter.  
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 7 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
147
But that doesn't mean you must accept the witness's 
opinion.  As with any other witness's testimony, you must 
decide for yourself whether to rely upon the opinion.  
The indictment charges 42 separate crimes called 
counts against some or all of the defendants.  Each count has 
a number.  Specifically, Defendant Foster is charged in 
Counts 1 through 28, Counts 30 through 41 and Count 59.  And 
Defendant Jackson is charged in Counts 46 and 47.  You'll be 
given a copy of the indictment to refer to during your 
deliberations.  
Some of the counts charge that Defendant Foster 
knowingly and willfully conspired to commit bank fraud and/or 
wire fraud.  
Other counts charge that Defendants Jackson and/or 
Foster committed what are called substantive offenses, 
specifically bank fraud, wire fraud, making false statements 
to a federally insured financial institution and/or money 
laundering.  I will explain the law governing those 
substantive offenses -- excuse me -- those substantive 
offenses in a moment.  
But first note that the defendants who are charged  
in conspiracy counts are not charged in those counts with 
committing a substantive offense.  They are charged with 
conspiring to commit that offense.  
I will also give you specific instructions on 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 8 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
148
conspiracy.  
It's possible to prove a defendant guilty of a crime 
even without evidence that the defendant personally performed 
every act charged.  
Ordinarily, any act a person can do may be done by 
directing another person or agent.  Or it may be done by 
acting with or under the direction of others.  
A defendant aids and abets a person if the defendant 
intentionally joins with the person to commit a crime.  
A defendant is criminally responsible for the acts of 
another person if the defendant aids and abets the other 
person.  A defendant is also responsible if the defendant 
willfully directs or authorizes the acts of an agent, employee 
or other associate.  
But finding that a defendant is criminally 
responsible for the acts of another person requires proof that 
the defendant intentionally associated with or participated in 
the crime.  Not just proof that the defendant was simply 
present at the scene of a crime or knew about it.  
In other words, you must find beyond a reasonable 
doubt that the defendant was a willful participant and not 
merely a knowing spectator.  
It's a federal crime to carry out or attempt to carry 
out a scheme to defraud a financial institution, or to get 
money or property owned or controlled by a financial 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 9 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
149
institution by using false pretenses, representations or 
promises.  
Each defendant can be found guilty of this crime only 
if all the following acts are proved beyond a reasonable 
doubt:  
The defendant knowingly carried out or attempted to 
carry out a scheme to defraud a financial institution or to 
get money, assets or other property from a financial 
institution by using false or fraudulent pretenses, 
representations or promises about a material fact; 
The false or fraudulent pretenses, representations or 
promises were material;
The defendant intended to defraud the financial 
institution;
And the federal institution was federally insured.  
A scheme to defraud includes any plan or course of 
action intended to deceive or cheat someone out of money or 
property by using false or fraudulent pretenses, 
representations or promises relating to a material fact.  
The statement or representation is false or 
fraudulent if it is about a material fact that the speaker 
knows is untrue or makes with reckless indifference as to the 
truth and makes with intent to defraud.  A statement or 
representation may be false or fraudulent when it's a half 
truth or effectively conceals a material fact and it was -- 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 10 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
150
and is made with the intent to defraud.  
A material fact is an important fact that a 
reasonable person would use to decide whether to do or not to 
do something.  A fact is material if it has the capacity or 
natural tendency to influence a person's decision.  It doesn't 
matter whether the decisionmaker actually relied on the 
statement or knew or should have known the statement was 
false.  
To act with intent to defraud means to act knowingly 
and with the specific intent to use false or fraudulent 
pretenses, representations or promises to cause loss or 
injury.  Proving intent to deceive a loan without the intent 
to cause loss or injury is not sufficient to prove intent to 
defraud.  
The government doesn't have to prove all the details 
alleged in the indictment about the precise nature and purpose 
of the scheme.  It also doesn't have to prove that the alleged 
scheme actually succeeded in defrauding anyone.  What must be 
proved beyond a reasonable doubt is that the defendant 
knowingly attempted or carried out a scheme substantially 
similar to the one alleged in the indictment.  
It's a federal crime to use interstate wire, radio or 
television communications to carry out a scheme to defraud 
someone else.  
Each defendant can be found guilty of this crime -- 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 11 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
151
Counsel, when we were reviewing these, bank fraud and 
wire fraud both say "each defendant."  Shouldn't that just say 
"a defendant"?  
MS. WEBSTER:  That seems right.  
THE COURT:  Agreed, Ms. Webster?  
MS. WEBSTER:  Yes.
MR. MARSHALL:  Yes, Judge.  
THE COURT:  Okay, Mr. Marshall?  
MR. MARSHALL:  Yes. 
THE COURT:  Government?  
MR. KAUSHAL:  Either way is fine, Your Honor. 
THE COURT:  Okay.  
When I was describing the bank fraud, I said "each 
defendant" can be found, but I should have read "a defendant" 
can be found.  And here again with wire fraud, I'm going to 
say it's a federal crime to use interstate wire, radio or 
television communications to carry out a scheme to defraud 
someone else.  
A defendant can be found guilty of this crime only if 
all the following facts are proved beyond a reasonable doubt.  
And, Ms. Mueller, if you can change that on page 14 
and 12 and reprint those two pages.  Thank you.  
The following facts are proved beyond a reasonable 
doubt:  
The defendant knowingly devised or participated in a 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 12 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
152
scheme to defraud someone by using false or fraudulent 
pretenses, representations or promises; 
The false pretenses, representations or promises were 
about a material fact; 
The defendant acted with the intent to defraud;
And the defendant transmitted or caused to be 
transmitted by wire some communication in interstate commerce 
to help carry out the scheme to defraud.  
A scheme to defraud means any plan or course of 
action intended to deceive or cheat someone out of money or 
property by using false or fraudulent pretenses, 
representations or promises.  
A statement of representation is false or fraudulent 
if it's about a material fact the speaker knows is untrue or 
makes with reckless indifference to the truth and makes with 
the intent to defraud.  A statement or representation may be 
false or fraudulent when it is a half-truth, or effectively 
conceals a material fact and is made with the intent to 
defraud.  
A material fact is an important fact that a 
reasonable person would use to decide whether to do or not do 
something.  A material fact, it has the capacity or natural 
tendency to influence a person's decision -- excuse me.  
A fact is material if it has the capacity or natural 
tendency to influence a person's decision.  It doesn't matter 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 13 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
153
whether the decisionmaker actually relied on the statement or 
knew or should have known the statement was false.  
To act with intent to defraud means to act knowingly 
and with the specific intent to use false or fraudulent 
pretenses, representations or promises to cause loss or 
injury.  Proving intent to deceive alone, without the intent 
to cause loss or injury, is not sufficient to prove intent to 
defraud.  
The government does not have to prove all the details 
alleged in the indictment about the precise nature and purpose 
of the scheme.  It also doesn't have to prove the material -- 
does not have to prove that the material transmitted by 
interstate wire was itself false or fraudulent; or that using 
the wire was intended as the specific or exclusive means of 
carrying out the alleged fraud; or that the defendant 
personally made the transmission over the wire.  And it 
doesn't have to prove that the alleged scheme actually 
succeeded in defrauding anyone.  
To use interstate wire communications is to act      
so that something would normally be sent through wire 
communications in the normal course of business.  
Each separate use of the interstate wire 
communications as part of the scheme to defraud is a separate 
crime.  
It's a federal crime to knowingly and willfully 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 14 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
154
conspire or agree with someone to do something that, if 
actually carried out, would result in the crime of bank fraud 
or wire fraud.  
A conspiracy is an agreement by two or more persons 
to commit an unlawful act.  In other words, it is a kind of 
partnership for criminal purposes.  Every member of the 
conspiracy becomes the agent or partner of every other member.  
The government does not have to prove that all the 
people named in the indictment were members of the plan or 
that those who were members made any kind of formal agreement.  
The heart of a conspiracy is the making of the unlawful plan 
itself, so the government does not have to prove that the 
conspirators succeeded in carrying out the plan.  
Each defendant can be found guilty of this conspiracy 
offense only if all the following facts are proved beyond a 
reasonable doubt:  
Two or more persons in some way or manner agreed to 
try to accomplish a common and unlawful plan to commit bank 
fraud or wire fraud as charged in the indictment; 
And the defendant knew the unlawful purpose of the 
plan and willfully joined in it.  
A person may be a conspirator even without knowing 
all the details of the unlawful plan or the names and 
identities of all the other alleged conspirators.  
If the defendant played only a minor role in the plan 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 15 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
155
but had a general understanding of the unlawful purpose of the 
plan and willfully joined in the plan on at least one 
occasion, that's sufficient for you to find the defendant 
guilty.  
But simply being present at the scene of an event or 
merely associating with certain people and discussing common 
goals and interests doesn't establish proof of a conspiracy.  
Also, a person who doesn't know about a conspiracy but happens 
to act in a way that advances some purpose of one doesn't 
automatically become a conspirator.  
In this case, some of the conspiracy counts in the 
indictment allege that a defendant conspired to commit bank 
fraud and to commit wire fraud.  In other words, in some 
counts the defendants are charged with conspiring to commit 
two separate substantive crimes.  
The government does not have to prove that a 
defendant willfully conspired to commit both crimes.  It is 
sufficient if the government proves beyond a reasonable doubt 
that a defendant willfully conspired to commit one of those 
crimes.  But to return a verdict of guilty, you must all agree 
on which of the two crimes the defendant conspired to commit.  
It's a federal crime to knowingly make a false 
statement or report to a federally insured financial 
institution.  
Each defendant can be found guilty of this crime only 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 16 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
156
if all the following facts are proved beyond a reasonable 
doubt:  
The defendant made a false statement or report; 
The defendant did so knowingly and with intent to 
influence an action of the institution described in the 
indictment regarding an application, advance, commitment or 
loan or a change or extension to any of those; 
And the deposits of the institution were insured by 
the Federal Deposit Insurance Corporation.  
A statement or report is false if it is untrue and 
made and the person making it knows it is untrue.  
The heart of the crime is the attempt to influence 
the action of the institution by knowingly making a false 
statement or report.  The government does not have to prove 
that the institution was actually influenced or misled.  
It's a federal crime to knowingly engage in certain 
kinds of financial transactions, commonly known as money 
laundering.  
Each defendant can be found guilty of this crime only 
if all the following facts are proved beyond a reasonable 
doubt:  
The defendant knowingly conducted or tried to conduct 
a financial transaction; 
The defendant knew that the money or property 
involved in the transaction were the proceeds of some kind of 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 17 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
157
unlawful activity;
Money or property did come from a specified unlawful 
activity, specifically wire fraud;
And the defendant knew that the transaction was 
designed, in whole or in part, to conceal or disguise the 
nature, location, source, ownership or the control of the 
proceeds.  
One moment.  
To conduct a transaction means to start or finish a 
transaction or participate in a transaction at any point.  
A transaction means a purchase, sale, loan, promise, 
gift, transfer, delivery or other disposition of money or 
property.  A transaction with a financial institution also 
includes a deposit, withdrawal, transfer between accounts, 
exchange of currency, loan, extension of credit, use of a safe 
deposit box or purchase or sale of any stock, bonds, 
certificate of deposit or other monetary instrument.  
A financial transaction means a transaction that    
in any way or to any degree affects interstate or foreign 
commerce by sending or moving money by wire or other means; or 
a transaction that in any way or to any degree affects 
interstate or foreign commerce by involving one or more 
monetary instruments.  The phrase "monetary instruments" 
includes coins or currency of any country, Travelers or 
personal checks, bank checks or money orders, or investment 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 18 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
158
securities or negotiable instruments in a form that allows 
ownership to transfer on delivery; a transaction involving the 
use -- or a transaction involving the use of a financial 
institution that is involved in interstate or foreign commerce 
or whose activities affect interstate or foreign commerce in 
any way or degree.  The phrase "financial institution" 
includes a bank insured by the Federal Deposit Insurance 
Corporation.  
Interstate or foreign commerce means trade and other 
business activity between people or businesses in at least two 
states or between people or businesses in the United States 
and people or businesses outside the United States.  
To know that the money or property involved in the 
transaction came from some kind of unlawful activity is to 
know that the money or property came from an activity that's a 
felony under state, federal or foreign law.  
The term "proceeds" means any property derived from 
or obtained or retained, directly or indirectly, through some 
form of unlawful activity, including the gross receipts of the 
activity.  
The phrase "specified unlawful activity" means wire 
fraud.  
To prove the element of concealment, the government 
must prove that the purpose, not merely the effect, was to 
conceal or disguise the nature, location, source, ownership or 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 19 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
159
control of the proceeds.  Evidence of concealment must be 
substantial.  Merely conducting a transaction with money whose 
nature has been concealed is not in and of itself a crime.  
Where a statute specifies multiple alternative ways 
in which an offense may be committed, the indictment may 
allege the multiple ways in the conjunctive, that is by using 
the word "and."  If only one of the alternatives is proved 
beyond a reasonable doubt, that is sufficient for a conviction 
so long as you agree unanimously as to that alternative.  
Good faith is a complete defense to a charge that 
requires intent to defraud.  A defendant isn't required to 
prove good faith.  The government must prove intent to defraud 
beyond a reasonable doubt.  
An honestly held opinion or an honestly formed belief 
cannot be fraudulent -- excuse me -- cannot be fraudulent 
intent, even if the opinion or belief is mistaken.  Similarly, 
evidence of a mistake in judgment, an error in management or 
carelessness can't establish fraudulent intent.  
But an honest belief that a business venture would 
ultimately succeed doesn't constitute good faith if the 
defendant intended to deceive others by making representations 
the defendant knew to be false or fraudulent.  
You'll see that the indictment charges that a crime 
was committed on or about a certain date.  The government 
doesn't have to prove that the crime occurred on an exact 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 20 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
160
date.  The government only has to prove beyond a reasonable 
doubt that the crime was committed on a date reasonably close 
to the date alleged.  
The word "knowingly" means that an act was done 
voluntarily and intentionally and not because of a mistake or 
an accident -- or by accident.  
The word "willfully" means that the act was committed 
voluntarily and purposely, with the intent to do something the 
law forbids; that is, with the bad purpose to disobey or 
disregard the law.  While a person must have acted with the 
intent to do something the law forbids before you can find 
that the person acted willfully, the person need not be aware 
of the specific law or rule that his or her conduct may be 
violating.  
This next instruction applies only to the 
government's case against Defendant Jackson.  It does not 
apply to the government's case against Defendant Foster.  
If a defendant's knowledge of a fact is an essential 
element of a crime, it's enough that the defendant was aware 
of a high probability that the fact existed unless the 
defendant actually believed the fact didn't exist.  
Deliberate avoidance of positive knowledge, which is 
the equivalent of knowledge, occurs, for example, if a 
defendant possesses a package and believes it contains a 
controlled substance but deliberately avoids learning that it 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 21 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
161
contains the controlled substance so he or she can deny 
knowledge of the package's contents.  
So you may find the defendant -- that a defendant 
knew about the possession of a controlled substance if you 
determine beyond a reasonable doubt that the defendant 
actually knew about the controlled substance or had every 
reason to know but deliberately closed his or her eyes.  
And I would add, with counsel's permission, for 
example.  Hearing no objection.  
But I must emphasize that negligence, carelessness or 
foolishness isn't enough to prove that the defendant knew 
about the possession of the controlled substance, in that 
example.  
Each count of the indictment charges a separate crime 
against one or more of the defendants.  You must consider each 
crime and the evidence related to it separately.  And you must 
consider the case of each defendant separately and 
individually.  If you find a defendant guilty of one crime, 
that must not affect your verdict for any other crime or any 
other defendant.  
I caution you that each defendant is on trial only 
for the specific crimes charged in the indictment.  You're 
here to determine from the evidence in this case whether each 
defendant is guilty or not guilty of those specific crimes.  
You must never consider punishment in any way to 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 22 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
162
decide whether a defendant is guilty.  If you find a defendant 
guilty, the punishment is for the judge alone to decide later.  
Your verdict, whether guilty or not guilty, must be 
unanimous.  In other words, you must all agree.  Your 
deliberations are secret and you'll never have to explain your 
verdict to anyone.  
Each of you must decide the case yourself, but only 
after fully considering the evidence with the other jurors.  
So you must discuss the case with one another and try to reach 
an agreement.  While you're discussing the case, don't 
hesitate to re-examine your own opinion and change your mind 
if you become convinced that you were wrong.  But don't give 
up your honest beliefs just because others think differently 
or because you simply want to get the case over with.  
Remember that, in a very real way, you're judges, 
judges of the facts.  Your only interest is to seek the truth 
from the evidence in this case.  
One moment.  
All right.  Before I complete the instructions, 
either my law clerk or one of the counsel has identified a 
couple other places where I've said "each defendant" where it 
should have said "a defendant."  
When I was describing conspiracy to commit bank fraud 
and/or wire fraud I said, "each" defendant can be found guilty 
of this conspiracy offense.  I should have said "a" defendant 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 23 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
163
can be found guilty.  
Same thing when I was discussing false statement to a 
federally insured institution, I said "each" defendant can be 
found guilty of this crime.  I should have said "a" defendant 
can be found guilty of this crime.  
Counsel, does that address those "each" versus "a" 
issues that I -- some of which I found as I was reading 
through, others of which someone else found as I was reading 
through and I didn't see the e-mail until just now?  
MS. WEBSTER:  Yes, your Honor, I think so. 
MR. MARSHALL:  Yes, your Honor. 
MR. KAUSHAL:  Your Honor, since we are making these 
small edits, page 18, the sentence that says -- that starts 
with, "In other words," should say "a defendant" is charged, 
instead of "the defendants" are charged. 
THE COURT:  Okay.  
All right.  And pardon us, ladies and gentlemen of 
the jury.  We went through all of these but missed a few of 
the things we were supposed to switch around.  
When you get to the jury room, choose one of your 
members to act as foreperson.  The foreperson will direct your 
deliberations and will speak for you in court.  
A verdict form has been prepared for your 
convenience.
Ms. Lee, can you put the verdict form on the -- I 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 24 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
164
always thought it was an Elmo, but I heard somebody call it an 
Exhibitron during this trial, which I thought was an even 
better way to describe it.  So I might use Exhibitron from now 
on.  
Can you put the verdict form on the Exhibitron, 
Ms. Lee?  
COURTROOM DEPUTY CLERK:  Yes.  Which one first?  
THE COURT:  Let's start with Mr. Foster's.  
All right.  So you're going to have two separate 
verdict forms, ladies and gentlemen of the jury.  The first 
one involves Mr. Foster.  
And for each of the counts listed there, for example, 
Count 1, as to Count 1 of the indictment charging conspiracy 
to commit wire fraud as to Bellator Phront Group, Inc., we, 
the jury, unanimously find defendant, Teldrin Foster, and 
you'll check either not guilty or guilty.  
For some of these, for example -- can you go to 
Count 6 on page 2, Ms. Lee?  
Some of these will ask you -- and only if you reach a 
guilty verdict.  If you reach a not guilty verdict, you don't 
answer the second part of the question.  But if you reach a 
guilty verdict, you then answer whether or not you find -- 
unanimously find the government proved that the object of the 
conspiracy was bank fraud, wire fraud or both.  
And you'll just answer those questions for all the 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 25 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
165
counts up to Count 59.  And then you will sign and date -- and 
the foreperson will sign and date the verdict form.  
With Ms. Jackson's verdict form, which we see here, 
you will -- just like with the first count mentioned of 
Mr. Foster's verdict form, you will simply decide between the 
options listed there, not guilty and guilty.  And then, again, 
the foreperson will sign and date the form.  
You'll have the verdict form with you in the jury 
room.  When you've agreed on your verdict, the foreperson, 
again, will sign the form and date it and carry it back in to 
the courtroom.  
You will have -- in addition to the verdict form, you 
will have a copy of my instructions.  You will also have the 
indictment.  And you will have all of the exhibits.  
Which, Ms. Lee, have you and the various parties 
worked through those exhibits?  Are those close?  
COURTROOM DEPUTY CLERK:  They're close. 
THE COURT:  Okay.  Those will -- we'll get a packet 
with you including all these materials shortly.  
I'll also say, by agreement of the parties, you'll 
see in the indictment there are references to company 1, for 
example, and bank 1, for example.  And there's a stipulation 
that the parties agreed to that describe which companies and 
banks are listed therein.  
If you wish to communicate with me at any time, 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 26 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
166
please write down your message or question and give it to the 
court security officer.  He or she will bring it to me and 
I'll respond as promptly as possible, either in writing or by 
talking to you in the courtroom.  But I caution you not to 
tell me how many jurors have voted one way or the other at any 
time.  
All right.  Jurors 27 and Juror 30, who are you?  
I've lost track. 
Okay.  Jurors 27 and 30, you are alternate jurors in 
this case, so you will not go back and deliberate, but I do 
need you to stand by in case we need you at any point.  Thank 
you.  
All right.  So now I'll ask the jury -- or, first 
off, Counsel, other than all those "each" and "a" issues that 
I think we fixed, any issues with the charge other than what's 
been previously objected to?  
MS. WEBSTER:  Your Honor, I think -- 
MR. KAUSHAL:  No. 
MS. WEBSTER:  Your Honor, I think I have to renew my 
objection to the previously decided ones to preserve it for 
appeal.  
THE COURT:  All right.  Thank you, Ms. Webster. 
MR. MARSHALL:  Judge, and I think the Court already 
said it, subject to previous objections. 
THE COURT:  I did. 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 27 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
167
MR. KAUSHAL:  No objection from the government. 
THE COURT:  All right.  Thank you.  
Okay.  You can now, please -- 12 of the 14 of you, 
please go to the jury room to deliberate and we will be there 
shortly with the verdict form, the indictment and the 
instructions and the exhibits.  Thank you.  
(The jury exited the courtroom to deliberate.) 
THE COURT:  Counsel, anything else for now?  
MS. WEBSTER:  I do have one issue, Your Honor. 
THE COURT:  All right.  Let's wait for the jury to go 
out.  
Yes, Ms. Webster?  
Y'all can be seated.  
MS. WEBSTER:  Thank you, Your Honor.
We are requesting that the Court find that there was 
a constructive amendment or a material variance during the 
government's closing argument, specifically as the Court is 
aware, I -- we've litigated a bunch of motions about the 
conspiracy -- or not a bunch.  We litigated a multiplicitous 
argument arguing that it should be one conspiracy and not 14.  
And the government opposed that at every step along the way.  
And then I believe they stood up in closing and said that it's 
actually one conspiracy.  
And so we would move for a -- for the Court to find 
that there's a material -- or constructive amendment or 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 28 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
168
material variance on that basis. 
THE COURT:  Yes, Ms. Chaiken. 
MS. CHAIKEN:  Your Honor, first of all, this wasn't 
raised in any contemporaneous objection, so I don't think it's 
been preserved.  
But in any event, I don't think anything I said in 
closing suggested that there was only one conspiracy.  What I 
said is that as to each loan Teldrin Foster conspired with 
Darrell Thomas.  And I don't think there was any constructive 
amendment.  
The evidence at trial showed the existence of 
multiple conspiracies because it established that the business 
owners did not work together with each other, were not 
connected by any kind of rim.  So I think based on our prior 
briefing I don't think anything I said in closing changed the 
propriety of the way that the case was charged. 
THE COURT:  All right.  One moment.  
All right.  Ms. Webster, anything else?  
MS. WEBSTER:  Nothing additional, Your Honor. 
THE COURT:  All right.  I'm going to deny that 
motion.  
All right.  Thanks, everyone.  
(After a recess at 1:39 p.m., the proceedings 
continued at 4:31 p.m., as follows:) 
THE COURT:  Y'all can be seated.  Thank you. 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 29 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
169
I wanted to check in and get on the record given the 
issues we've been having.  You know, it's pretty typical,    
you know, sometimes to tell the jury, okay, begin your 
deliberations, we'll -- or go back to the jury room, we'll 
have the stack here for you shortly with the verdict form, 
instructions, if y'all have consented to send them back and 
have agreed to send them back, and then the exhibits.  That 
happened here, too.  My impression was that things were about 
ready.  
You know, there was a question from the jury if they 
could begin deliberations before they got everything.  And I 
had Ms. Lee check with counsel to get counsel's position on 
that.  I was told that counsel did not want that to happen, 
and I was only going to let that happen if everybody agreed.  
So I said okay, I understand no one wanted that to happen, so 
I said, tell the jury not to begin deliberations then.  
Then I got a follow-up message a little bit later 
saying the documents still weren't ready but could -- was it 
permissible to let the jury start deliberating.  I was told 
all counsel was amenable to that.  So I said, fine, let the 
jury know they can begin deliberating, thinking again we were 
close to having the stack sent back to them.  
So, first off, is my understanding of the 
communications so far, is that accurate, Ms. Chaiken?  
MS. CHAIKEN:  Yes, your Honor. 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 30 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
170
THE COURT:  Ms. Webster?  
MS. WEBSTER:  Yes, your Honor. 
THE COURT:  Mr. Marshall?  
MR. MARSHALL:  Yes, your Honor. 
THE COURT:  That unfortunately was probably an hour 
and half plus ago.  And I understand -- well, first off, I 
understand that a member of the Foster defense team was ill 
and so wasn't here, your paralegal, which would explain maybe 
why we're having some issues.  
But bottom line is, you know, I think at this point I 
need to bring the jury in and say, we're having some trouble 
with the documents and we're going to pause for the rest of 
the day and bring you back in in the morning, at which time we 
will have all the documents ready to go.  
To me, that seems clearly like what we should do at 
this point unless, Ms. Webster, you tell me that your 
documents are minutes away from being ready to go back. 
MS. WEBSTER:  I don't think I can say that they're 
minutes away from going back.  Hopefully within half an hour 
or something, but I -- I'm very sorry, but I don't think I can 
promise they're minutes away. 
THE COURT:  Okay.  Would anyone like to be heard on 
my suggestion, and that is, again, that I release the jury and 
have them come back in the morning given this issue?  
MS. CHAIKEN:  No, your Honor. 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 31 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
171
MR. MARSHALL:  Your Honor, is there any instruction 
we can give them that just reminds them that they don't have 
the exhibits yet and not to form any conclusions in the case 
or anything related to that until they have all the 
evidence -- 
THE COURT:  Well, we've already told them they could 
begin deliberations by consent of everyone, so I'm not going 
to try to get into the verbal gymnastics of don't decide 
anything or do decide something.  I don't think that would be 
fair to them given that we've by consent told them they could 
go ahead and talk about the case and that the documents are on 
the way.  
Do you want to be further heard, Mr. Marshall?  
MR. MARSHALL:  No, that's fine, Your Honor.
THE COURT:  So my intent is just to bring the jury in 
and say, without any attribution as to which party has caused 
the issue, just to say we're having some issues with the 
documents unfortunately.  Minutes have turned into hours and 
I've decided to pause your deliberations until you can come 
back in the morning with the documents.  
Is that acceptable to everyone?  
Ms. Chaiken?  
MS. CHAIKEN:  Yes, your Honor. 
THE COURT:  Ms. Webster?  
MS. WEBSTER:  Yes, your Honor. 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 32 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
172
THE COURT:  Mr. Marshall?  
MR. MARSHALL:  Yes, Judge. 
THE COURT:  Could someone grab the CSO and have him 
bring in the jury.  Thank you.  
And, Ms. Webster, again, I understand your paralegal 
that normally does all this stuff was not here and that makes 
sense to me it would become an issue.  It's unfortunate but 
it's fine and we're dealing with it and everything's going to 
be okay.  
MS. WEBSTER:  Thank you, Your Honor.  I appreciate 
that.  
COURTROOM DEPUTY CLERK:  As to the alternates, do you 
want me to message them they're not to come in?  
THE COURT:  Yes, that would be fine. 
Actually, does everyone consent, the alternates, to 
release them but tell them they're on standby to potentially 
need to come back?  
Ms. Chaiken?  
MS. CHAIKEN:  That's fine, Your Honor. 
THE COURT:  Ms. Webster?  
MS. WEBSTER:  Yes, Your Honor. 
THE COURT:  Mr. Marshall?  
MR. MARSHALL:  Yes, Judge.
THE COURT:  Actually are they close by?  I want to 
bring them in and tell them that in person and thank them.  
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 33 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
173
Thank you.  Just have them come up, please.  
Counsel, does everyone also consent to my telling 
them once they receive the stack in the morning, they can 
restart their deliberations without me coming into -- bringing 
them into the courtroom and bringing you all in the courtroom 
and telling them that?  
MS. CHAIKEN:  Yes, Your Honor. 
MS. WEBSTER:  Yes, Your Honor. 
MR. MARSHALL:  Yes, Your Honor.  
And, Your Honor, I believe Mr. Foster's counsel is 
submitting I think -- 
THE COURT:  I'm sorry, let me interrupt you.  I won't 
say restart, I'll just say continue. 
MR. MARSHALL:  Continue, yes. 
I believe Mr. Foster's counsel has documents that 
will be submitted on a flash drive.  
Is that correct, Ms. Webster?  
MS. WEBSTER:  Yes, Your Honor.  I was going to put 
that on the record.  
I think by consent of the parties we have documents 
that we had admitted into evidence and it turns out that they 
were not actually all printed, which is part of the issue.  
And so we had discussed putting them on a flash drive and 
sending them back that way, so to avoid the time in printing 
and stickering them and stuff.  And so I think all the parties 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 34 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
174
have agreed, so that's what we are planning to do.  I think 
we're trying to wrap up that process.  
THE COURT:  That's fine.  Do you have a list of 
exhibits that's going to apply to?  I guess we should just put 
that on the record if you have it or we might need to do that 
tomorrow. 
MS. WEBSTER:  I think tomorrow. 
THE COURT:  All right.  Thank you.  
Ready.  Thank you, Officer.  
(The jury entered the courtroom at 4:43 p.m.) 
THE COURT:  All right.  You can be seated.  
Ladies and gentlemen of the jury, so we have had some 
issues with the exhibits, with the documents.  As you know, 
this has been a fairly document intensive case with some hard 
documents, some electronic documents, et cetera.  
When I sent you back to choose your foreperson, it 
was my expectation that soon thereafter we would be giving you 
a stack of the materials.  I thought that was going to be in a 
few minutes or a couple minutes.  A couple minutes have turned 
into a couple hours.  It's now 4:45.  I think I sent you back 
at 2:30-something or so.  
A little while after I sent you back, it was 
confirmed after discussions with the parties that you weren't 
to begin your deliberations until you got the documents, but 
when we realized it was going to be a little bit longer for 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 35 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
175
the documents, the parties consented to allow you to begin 
your deliberations without the documents, which was 
communicated to you, again, with the expectation that those 
documents would be coming fairly shortly.  
But now as additional time has passed and you still 
don't have the documents, I've decided to direct you to pause 
your deliberations for the day.  And we will be putting the 
documents together once and for all this afternoon into this 
evening, as long as it takes for there to be a stack of 
documents ready for you to go tomorrow morning at 9:00.  
I want to underscore to you that I'm not happy that 
this has transpired this way.  And I know we've taken a lot of 
your time for this trial and this has been an even greater 
inconvenience over the last couple hours dealing with this.  
I apologize that this has happened, but we're going 
to try to get it fixed the rest of this afternoon, into this 
evening, and make sure we have a stack for you at 9:00 
tomorrow morning.  
I've also, just to save us a little time of the 
back-and-forth, spoken with the parties and they've consented 
that once all 12 of you are here in the morning and you have 
that stack of documents, you can continue your deliberations 
at that point.  I'm not going to bring you back into the 
courtroom just to tell you to continue your deliberations.  
So, again, you have my apologies that this has 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 36 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
176
happened.  I'm sorry that it's happened.  I'm sorry that it's 
inconvenienced you, but we will hopefully have things straight 
and ready for you to go full speed ahead with your 
deliberations with everything you need at 9:00 tomorrow 
morning.  
All right.  Thank you very much.  And, again, I 
apologize.  
And to the two alternates, I'll release the jury and 
then I need to talk to the two alternates as well.  
Thank you.  Y'all have a good evening. 
(The jury exited the courtroom at 4:47 p.m.) 
THE COURT:  All right.  Y'all can be seated.  
Jurors 27 and 30, hello.  I want to thank you also 
for being here throughout this case and the attention you've 
given it.  I've spoken with the parties and what we're going 
to do, instead of continue to hold you here while the rest of 
the jury deliberates and have you come back tomorrow while 
they deliberate, I'm instead going to release you on the 
condition that you will keep your cell phones with you and 
have them at the ready should we lose one of the other jurors 
for some reason tomorrow or however long they deliberate, we 
may still need to bring one or both of you back to become 
jurors.  
Does that make sense?  
All right.  Both Jurors 27 and 30 are indicating, 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 37 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
177
yes, it makes sense.  
So thank you for your service on this jury.  It may 
well be that I don't see you again.  If not, thank you.  
Take care.
(Alternate jurors excused.)  
THE COURT:  Anything else this evening, Counsel?  
MS. CHAIKEN:  No, Your Honor. 
THE COURT:  And just so I'm abundantly clear on this, 
I don't care if -- it's 4:48, I don't care if it takes to 5:58 
or 6:58 or 3:00-in-the-morning-48, let's make darn sure we 
have that stack ready to go for the jury at 9:00.  Okay. 
MS. WEBSTER:  Yes, sir. 
MR. MARSHALL:  Your Honor, I think we have all our 
exhibits in.  I don't think we need to stay.  We only had a 
few anyway, Judge. 
THE COURT:  I understand that, Mr. Marshall, but 
thank you.  All right.  
Best of luck.  And, again, I understand the 
situation.  And had I had a, you know, when I was practicing, 
a gigantic case with a million pages of documents and without 
a paralegal, I probably would have had a similar problem.  So 
all will be well.  
Take care, everyone. 
(After a recess at 4:49 p.m., the proceedings were 
continued as follows on February 15, 2024:)
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 38 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
178
- - - - - 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 39 of 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
179
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 14th Day of February, 2024.  
    ________________________________
  
  
               
    PENNY PRITTY COUDRIET, RMR, CRR
    OFFICIAL COURT REPORTER 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 40 of 49

1
1 [5] - 147:7, 164:13, 165:21, 165:22
12 [3] - 151:22, 167:3, 175:21
14 [4] - 141:11, 151:21, 167:3, 167:20
14TH [1] - 179:9
15 [1] - 177:25
18 [1] - 163:13
1:20-CR-00296-JPB [1] - 141:5
1:39 [1] - 168:23
1:59 [1] - 142:1
2
2 [1] - 164:18
2024 [3] - 141:11, 177:25, 179:9
27 [4] - 166:7, 166:9, 176:13, 176:25
28 [1] - 147:7
2:30-SOMETHING [1] - 174:21
3
30 [5] - 147:7, 166:7, 166:9, 176:13, 
176:25
3:00-IN-THE-MORNING-48 [1] - 177:10
4
41 [1] - 147:7
42 [1] - 147:4
46 [1] - 147:8
47 [1] - 147:8
4:31 [1] - 168:24
4:43 [1] - 174:10
4:45 [1] - 174:20
4:47 [1] - 176:11
4:48 [1] - 177:9
4:49 [1] - 177:24
5
59 [2] - 147:7, 165:1
5:58 [1] - 177:9
6
6 [1] - 164:18
6:58 [1] - 177:10
8
8 [1] - 141:6
9
90 [1] - 1:5
9:00 [4] - 175:10, 175:17, 176:4, 177:11
A
ABETS [2] - 148:8, 148:11
ABILITY [1] - 145:7
ABUNDANTLY [1] - 177:8
ACCEPT [2] - 144:16, 147:1
ACCEPTABLE [1] - 171:21
ACCIDENT [2] - 160:6
ACCOMPLISH [1] - 154:18
ACCOUNTS [1] - 157:14
ACCURATE [2] - 144:17, 169:24
ACCURATELY [1] - 145:8
ACT [13] - 143:12, 148:4, 148:5, 150:9, 
153:3, 153:19, 154:5, 155:9, 160:4, 
160:7, 163:21
ACTED [3] - 152:5, 160:10, 160:12
ACTING [1] - 148:7
ACTION [4] - 149:17, 152:10, 156:5, 
156:13
ACTIVITIES [1] - 158:5
ACTIVITY [8] - 157:1, 157:3, 158:10, 
158:14, 158:15, 158:19, 158:20, 
158:21
ACTS [4] - 148:10, 148:13, 148:16, 
149:4
ACTUAL [1] - 144:9
ADD [1] - 161:8
ADDITION [1] - 165:12
ADDITIONAL [2] - 168:19, 175:5
ADDRESS [1] - 163:6
ADMISSION [1] - 145:14
ADMITTED [3] - 143:18, 143:19, 173:21
ADVANCE [1] - 156:6
ADVANCES [1] - 155:9
AFFAIRS [1] - 143:13
AFFECT [2] - 158:5, 161:19
AFFECTS [2] - 157:19, 157:21
AFORESAID [1] - 179:8
AFTER [1] - 1:7
AFTERNOON [2] - 175:8, 175:16
AGENT [3] - 148:6, 148:13, 154:7
AGO [1] - 170:6
AGREE [5] - 142:17, 154:1, 155:20, 
159:9, 162:4
AGREED [7] - 151:5, 154:17, 165:9, 
165:23, 169:7, 169:14, 174:1
AGREEMENT [4] - 154:4, 154:10, 
162:10, 165:20
AHEAD [2] - 171:11, 176:3
AID [1] - 146:14
AIDS [2] - 148:8, 148:11
ALLEGE [2] - 155:12, 159:6
ALLEGED [8] - 150:16, 150:17, 150:21, 
153:10, 153:15, 153:17, 154:24, 160:3
ALLOW [2] - 146:17, 175:1
ALLOWED [1] - 146:24
ALLOWS [1] - 158:1
ALONE [2] - 153:6, 162:2
ALTERNATE [2] - 166:9, 177:5
ALTERNATES [4] - 172:12, 172:15, 
176:8, 176:9
ALTERNATIVE [2] - 159:4, 159:9
ALTERNATIVES [1] - 159:7
AMENABLE [1] - 169:20
180
AMENDMENT [3] - 167:16, 167:25, 
168:10
AMERICA [1] - 141:4
AN [1] - 1:2
AND [3] - 1:4, 1:7, 141:6
ANN [1] - 141:18
ANSWER [4] - 145:10, 164:21, 164:22, 
164:25
ANY [1] - 1:9
ANYWAY [1] - 177:15
APOLOGIES [1] - 175:25
APOLOGIZE [2] - 175:15, 176:7
APPEAL [1] - 166:21
APPEAR [1] - 145:9
APPEARANCES [1] - 141:13
APPLICATION [1] - 156:6
APPLIES [1] - 160:15
APPLY [2] - 160:17, 174:4
APPRECIATE [1] - 172:10
ARE [1] - 1:8
ARGUING [1] - 167:20
ARGUMENT [2] - 167:17, 167:20
ARRIVING [1] - 143:25
ASSERTS [1] - 144:9
ASSETS [1] - 149:8
ASSISTANT [1] - 141:16
ASSOCIATE [1] - 148:14
ASSOCIATED [1] - 148:17
ASSOCIATING [1] - 155:6
ASSUME [1] - 143:22
AT [1] - 142:1
ATLANTA [3] - 141:2, 141:25, 142:1
ATTACHED [1] - 1:6
ATTACHING [1] - 1:9
ATTEMPT [2] - 148:23, 156:12
ATTEMPTED [2] - 149:6, 150:20
ATTENTION [1] - 176:14
ATTORNEYS [1] - 141:16
ATTRIBUTION [1] - 171:16
AUTHORIZES [1] - 148:13
AUTOMATICALLY [1] - 155:10
AVERAGE [1] - 146:12
AVOID [1] - 173:24
AVOIDANCE [1] - 160:22
AVOIDS [1] - 160:25
AWARE [3] - 160:12, 160:19, 167:18
B
BABASIJIBOMI [1] - 141:15
BACK-AND-FORTH [1] - 175:20
BAD [1] - 160:9
BANK [12] - 147:12, 147:16, 151:1, 
151:13, 154:2, 154:18, 155:12, 
157:25, 158:7, 162:23, 164:24, 165:22
BANKS [1] - 165:24
BASED [3] - 142:12, 143:8, 168:14
BASIS [1] - 168:1
BE [2] - 1:3, 1:4
BECOME [4] - 155:10, 162:12, 172:7, 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 41 of 49

176:22
BECOMES [1] - 154:7
BEFORE [1] - 141:10
BEGIN [8] - 142:7, 169:3, 169:11, 
169:16, 169:21, 171:7, 174:24, 175:1
BEHALF [3] - 141:14, 141:17, 141:20
BELIEF [3] - 159:14, 159:16, 159:19
BELIEFS [1] - 162:13
BELIEVES [1] - 160:24
BELLATOR [1] - 164:14
BEST [1] - 177:18
BETTER [1] - 164:3
BETWEEN [4] - 157:14, 158:10, 158:11, 
165:5
BEYOND [18] - 142:10, 143:1, 143:5, 
143:11, 143:15, 148:20, 149:4, 
150:19, 151:20, 151:23, 154:15, 
155:18, 156:1, 156:20, 159:8, 159:13, 
160:1, 161:5
BINDING [1] - 143:20
BIT [2] - 169:17, 174:25
BONDS [1] - 157:16
BOTTOM [1] - 170:10
BOULEE [1] - 141:10
BOX [1] - 157:16
BRIEFING [1] - 168:15
BRING [8] - 166:2, 170:11, 170:13, 
171:15, 172:4, 172:25, 175:23, 176:22
BRINGING [2] - 173:4, 173:5
BUNCH [2] - 167:18, 167:19
BURDEN [1] - 143:4
BUSINESS [4] - 153:21, 158:10, 159:19, 
168:12
BUSINESSES [3] - 158:10, 158:11, 
158:12
BY [3] - 1:4, 1:6, 141:23
C
CANNOT [3] - 142:25, 159:15
CAPACITY [3] - 150:4, 152:22, 152:24
CARE [4] - 177:4, 177:9, 177:23
CAREFULLY [1] - 143:9
CARELESSNESS [2] - 159:18, 161:10
CARLA [2] - 141:6, 141:20
CARRIED [3] - 149:6, 150:20, 154:2
CARRY [7] - 148:23, 149:7, 150:23, 
151:17, 152:8, 165:10
CARRYING [2] - 153:15, 154:13
CASE [24] - 142:5, 143:10, 143:18, 
143:23, 145:5, 155:11, 160:16, 
160:17, 161:17, 161:23, 162:7, 162:9, 
162:10, 162:14, 162:17, 166:10, 
166:11, 168:16, 171:3, 171:11, 
174:14, 176:14, 177:20, 179:8
CAUSED [2] - 152:6, 171:16
CAUTION [2] - 161:21, 166:4
CELL [1] - 176:19
CERTAIN [3] - 155:6, 156:16, 159:24
CERTIFICATE [1] - 157:17
CERTIFY [1] - 179:6
CETERA [1] - 174:15
CHAIKEN [8] - 141:14, 168:3, 169:25, 
170:25, 171:23, 172:19, 173:7, 177:7
CHAIKEN [4] - 168:2, 169:24, 171:22, 
172:18
CHAIN [1] - 144:11
CHANGE [3] - 151:21, 156:7, 162:11
CHANGED [1] - 168:15
CHARGE [5] - 142:20, 147:11, 147:14, 
159:10, 166:15
CHARGED [12] - 147:6, 147:8, 147:21, 
147:22, 147:23, 148:4, 154:19, 
155:14, 161:22, 163:14, 163:15, 
168:16
CHARGES [3] - 147:4, 159:23, 161:14
CHARGING [1] - 164:13
CHEAT [2] - 149:17, 152:10
CHECK [3] - 164:16, 169:1, 169:12
CHECKS [2] - 157:25
CHOOSE [2] - 163:20, 174:16
CHOSE [1] - 142:24
CIRCUMSTANCES [2] - 144:12, 145:18
CIRCUMSTANTIAL [3] - 144:7, 144:11, 
144:14
CITE [1] - 1:5
CLEAR [1] - 177:8
CLEARLY [2] - 145:10, 170:15
CLERK [1] - 162:20
CLERK [3] - 164:7, 165:17, 172:12
CLOSE [5] - 160:2, 165:16, 165:17, 
169:22, 172:24
CLOSED [1] - 161:7
CLOSING [4] - 167:17, 167:22, 168:7, 
168:15
CM/ECF [2] - 1:3, 1:5
COINS [1] - 157:24
COMING [2] - 173:4, 175:4
COMMERCE [6] - 152:7, 157:20, 
157:22, 158:4, 158:5, 158:9
COMMIT [13] - 147:12, 147:24, 148:9, 
154:5, 154:18, 155:12, 155:13, 
155:14, 155:17, 155:19, 155:21, 
162:23, 164:14
COMMITMENT [1] - 156:6
COMMITTED [5] - 147:15, 159:5, 
159:24, 160:2, 160:7
COMMITTING [1] - 147:23
COMMON [4] - 143:9, 144:5, 154:18, 
155:6
COMMONLY [1] - 156:17
COMMUNICATE [1] - 165:25
COMMUNICATED [1] - 175:3
COMMUNICATION [1] - 152:7
COMMUNICATIONS [6] - 150:23, 
151:17, 153:19, 153:21, 153:23, 
169:24
COMPANIES [1] - 165:23
COMPANY [1] - 165:21
181
COMPLETE [2] - 159:10, 162:19
COMPLETED [1] - 142:6
CONCEAL [2] - 157:5, 158:25
CONCEALED [1] - 159:3
CONCEALMENT [2] - 158:23, 159:1
CONCEALS [2] - 149:25, 152:18
CONCERNED [1] - 144:6
CONCERNING [2] - 143:7, 144:21
CONCLUSIONS [2] - 144:5, 171:3
CONDITION [1] - 176:19
CONDUCT [3] - 156:22, 157:9, 160:13
CONDUCTED [1] - 156:22
CONDUCTING [1] - 159:2
CONFIRMED [1] - 174:23
CONJUNCTIVE [1] - 159:6
CONNECTED [1] - 168:14
CONSENT [5] - 171:7, 171:10, 172:15, 
173:2, 173:20
CONSENTED [3] - 169:6, 175:1, 175:20
CONSIDER [7] - 142:25, 143:17, 
144:15, 145:17, 161:15, 161:17, 
161:25
CONSIDERED [1] - 143:10
CONSIDERING [2] - 144:4, 162:8
CONSPIRACIES [1] - 168:12
CONSPIRACY [17] - 147:22, 148:1, 
154:4, 154:7, 154:11, 154:14, 155:7, 
155:8, 155:11, 162:23, 162:25, 
164:13, 164:24, 167:19, 167:20, 
167:23, 168:7
CONSPIRATOR [2] - 154:22, 155:10
CONSPIRATORS [2] - 154:13, 154:24
CONSPIRE [1] - 154:1
CONSPIRED [6] - 147:12, 155:12, 
155:17, 155:19, 155:21, 168:8
CONSPIRING [2] - 147:24, 155:14
CONSTITUTE [1] - 159:20
CONSTRUCTIVE [3] - 167:16, 167:25, 
168:9
CONTAINS [2] - 160:24, 161:1
CONTEMPORANEOUS [1] - 168:4
CONTENTS [1] - 161:2
CONTINUE [5] - 173:13, 173:14, 175:22, 
175:24, 176:16
CONTINUED [2] - 168:24, 177:25
CONTROL [2] - 157:6, 159:1
CONTROLLED [6] - 148:25, 160:25, 
161:1, 161:4, 161:6, 161:12
CONVENIENCE [1] - 163:24
CONVICTION [1] - 159:8
CONVINCED [3] - 143:14, 143:15, 
162:12
CONVINCING [1] - 143:12
COPY [2] - 147:9, 165:13
CORPORATION [2] - 156:9, 158:8
CORRECT [2] - 173:17, 179:7
COUDRIET [2] - 141:24, 179:15
COUNSEL [2] - 166:14, 177:6
COUNSEL [10] - 151:1, 162:20, 163:6, 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 42 of 49

167:8, 169:12, 169:13, 169:20, 173:2, 
173:10, 173:15
COUNSEL'S [2] - 161:8, 169:12
COUNT [3] - 147:5, 161:14, 165:4
COUNT [5] - 147:7, 164:13, 164:18, 
165:1
COUNTRY [1] - 157:24
COUNTS [9] - 147:5, 147:11, 147:14, 
147:22, 155:11, 155:14, 164:12, 165:1
COUNTS [3] - 147:7, 147:8
COUPLE [5] - 162:21, 174:19, 174:20, 
175:14
COURSE [3] - 149:16, 152:9, 153:21
COURT [2] - 163:22, 166:2
COURT [47] - 1:4, 1:7, 1:10, 141:1, 
141:24, 141:25, 142:1, 142:3, 151:5, 
151:8, 151:10, 151:12, 163:16, 164:8, 
165:18, 166:22, 166:25, 167:2, 167:8, 
167:10, 168:2, 168:17, 168:20, 
168:25, 170:1, 170:3, 170:5, 170:22, 
171:6, 171:15, 171:24, 172:1, 172:3, 
172:14, 172:20, 172:22, 172:24, 
173:12, 174:3, 174:8, 174:11, 176:12, 
177:6, 177:8, 177:16, 179:3, 179:15
COURT [4] - 166:23, 167:15, 167:17, 
167:24
COURT'S [1] - 142:19
COURTROOM [9] - 142:2, 165:11, 
166:4, 167:7, 173:5, 174:10, 175:24, 
176:11
COURTROOM [3] - 164:7, 165:17, 
172:12
CREDIT [1] - 157:15
CRIME [29] - 148:2, 148:9, 148:18, 
148:19, 148:23, 149:3, 150:22, 
150:25, 151:16, 151:19, 153:24, 
153:25, 154:2, 155:22, 155:25, 
156:12, 156:16, 156:19, 159:3, 
159:23, 159:25, 160:2, 160:19, 
161:14, 161:16, 161:18, 161:19, 
163:4, 163:5
CRIMES [7] - 147:4, 155:15, 155:17, 
155:20, 155:21, 161:22, 161:24
CRIMINAL [1] - 154:6
CRIMINALLY [2] - 148:10, 148:15
CRR [2] - 141:24, 179:15
CSO [1] - 172:3
CURRENCY [2] - 157:15, 157:24
D
DARN [1] - 177:10
DARRELL [1] - 168:9
DATE [8] - 159:24, 160:1, 160:2, 160:3, 
165:1, 165:2, 165:7, 165:10
DAVID [1] - 141:20
DAYS [1] - 1:5
DEALING [2] - 172:8, 175:14
DECEIVE [5] - 149:17, 150:12, 152:10, 
153:6, 159:21
DECEPTION [1] - 146:8
DECIDE [14] - 142:9, 144:17, 144:23, 
145:14, 146:7, 147:3, 150:3, 152:21, 
162:1, 162:2, 162:7, 165:5, 171:8, 
171:9
DECIDED [3] - 166:20, 171:19, 175:6
DECIDING [1] - 142:5
DECISION [8] - 142:12, 143:1, 144:1, 
144:19, 146:9, 150:5, 152:23, 152:25
DECISIONMAKER [2] - 150:6, 153:1
DECISIONS [1] - 145:17
DEDUCTIONS [1] - 144:5
DEFENDANT [78] - 142:10, 142:14, 
142:20, 142:21, 142:22, 142:23, 
142:24, 143:2, 143:14, 145:13, 
145:15, 145:21, 148:2, 148:3, 148:8, 
148:10, 148:11, 148:12, 148:15, 
148:17, 148:18, 148:21, 149:3, 149:6, 
149:13, 150:19, 150:25, 151:2, 151:3, 
151:14, 151:19, 151:25, 152:5, 152:6, 
153:15, 154:14, 154:20, 154:25, 
155:3, 155:12, 155:17, 155:19, 
155:21, 155:25, 156:3, 156:4, 156:19, 
156:22, 156:24, 157:4, 159:11, 
159:21, 159:22, 160:19, 160:21, 
160:24, 161:3, 161:5, 161:11, 161:17, 
161:18, 161:20, 161:21, 161:24, 
162:1, 162:21, 162:22, 162:24, 
162:25, 163:3, 163:4, 163:14, 164:15
DEFENDANT [5] - 147:6, 147:8, 147:11, 
160:16, 160:17
DEFENDANT [2] - 141:17, 141:20
DEFENDANT'S [3] - 143:5, 143:7, 
160:18
DEFENDANTS [5] - 147:5, 147:21, 
155:14, 161:15, 163:15
DEFENDANTS [1] - 141:8
DEFENDANTS [1] - 147:14
DEFENSE [2] - 159:10, 170:7
DEFRAUD [21] - 148:24, 149:7, 149:13, 
149:16, 149:23, 150:1, 150:9, 150:14, 
150:23, 151:17, 152:1, 152:5, 152:8, 
152:9, 152:16, 152:19, 153:3, 153:8, 
153:23, 159:11, 159:12
DEFRAUDING [2] - 150:18, 153:18
DEGREE [3] - 157:19, 157:21, 158:6
DELIBERATE [6] - 160:22, 166:10, 
167:4, 167:7, 176:18, 176:21
DELIBERATELY [2] - 160:25, 161:7
DELIBERATES [1] - 176:17
DELIBERATING [2] - 169:19, 169:21
DELIBERATIONS [17] - 142:8, 146:15, 
147:10, 162:5, 163:22, 169:4, 169:11, 
169:16, 171:7, 171:19, 173:4, 174:24, 
175:2, 175:7, 175:22, 175:24, 176:4
DELIVERY [2] - 157:12, 158:2
DENY [2] - 161:1, 168:20
DEPOSIT [2] - 156:9, 158:7
DEPOSIT [3] - 157:14, 157:16, 157:17
DEPOSITS [1] - 156:8
182
DEPUTY [3] - 164:7, 165:17, 172:12
DERIVED [1] - 158:17
DESCRIBE [2] - 164:3, 165:23
DESCRIBED [1] - 156:5
DESCRIBING [2] - 151:13, 162:23
DESIGNED [1] - 157:5
DETAIL [1] - 146:10
DETAILS [3] - 150:15, 153:9, 154:23
DETERMINE [2] - 161:5, 161:23
DEVISED [1] - 151:25
DIFFER [1] - 145:11
DIFFERENCE [1] - 144:13
DIFFERENT [1] - 146:1
DIFFERENTLY [1] - 162:13
DIRECT [5] - 144:7, 144:8, 144:14, 
163:21, 175:6
DIRECTING [1] - 148:6
DIRECTION [1] - 148:7
DIRECTLY [2] - 145:10, 158:18
DIRECTS [1] - 148:13
DISBELIEVE [1] - 144:19
DISCUSS [1] - 162:9
DISCUSSED [1] - 173:23
DISCUSSING [3] - 155:6, 162:10, 163:2
DISCUSSIONS [2] - 142:7, 174:23
DISGUISE [2] - 157:5, 158:25
DISOBEY [1] - 160:9
DISPOSITION [1] - 157:12
DISPROVE [1] - 144:12
DISREGARD [3] - 142:18, 143:24, 
160:10
DISTRICT [6] - 141:1, 141:1, 141:10, 
141:25, 179:3, 179:4
DIVISION [1] - 141:2
DOCKET [2] - 1:6, 141:5
DOCUMENT [1] - 174:14
DOCUMENT [1] - 1:10
DOCUMENTS [21] - 169:18, 170:12, 
170:14, 170:17, 171:11, 171:18, 
171:20, 173:15, 173:20, 174:13, 
174:15, 174:24, 175:1, 175:2, 175:4, 
175:6, 175:8, 175:10, 175:22, 177:20
DONE [3] - 148:5, 148:6, 160:4
DOUBT [21] - 142:11, 143:2, 143:6, 
143:7, 143:8, 143:11, 143:15, 148:21, 
149:5, 150:19, 151:20, 151:24, 
154:16, 155:18, 156:2, 156:21, 159:8, 
159:13, 160:2, 161:5
DOWN [2] - 166:1, 179:7
DRIVE [2] - 173:16, 173:23
DURING [8] - 142:13, 143:25, 146:1, 
146:11, 146:14, 147:9, 164:2, 167:16
DURRETT [1] - 141:18
DUTY [1] - 142:4
E
E-MAIL [1] - 163:9
EDITS [1] - 163:13
EFFECT [1] - 158:24
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 43 of 49

EFFECTIVELY [2] - 149:25, 152:17
EITHER [6] - 142:14, 144:14, 151:11, 
162:20, 164:16, 166:3
ELECTRONIC [1] - 174:15
ELEMENT [2] - 158:23, 160:19
ELMO [1] - 164:1
EMPHASIZE [2] - 146:19, 161:10
EMPLOYEE [1] - 148:13
ENGAGE [1] - 156:16
ENTERED [2] - 142:2, 174:10
ENTITLED [1] - 146:19
ENTRY [1] - 1:6
EQUIVALENT [1] - 160:23
ERROR [1] - 159:17
ESQ [6] - 141:14, 141:15, 141:15, 
141:18, 141:18, 141:20
ESSENTIAL [1] - 160:18
ESTABLISH [2] - 155:7, 159:18
ESTABLISHED [1] - 168:12
ET [1] - 174:15
EVENING [4] - 175:9, 175:17, 176:10, 
177:6
EVENT [2] - 155:5, 168:6
EVIDENCE [32] - 142:12, 142:21, 
142:23, 143:10, 143:17, 143:18, 
143:20, 144:3, 144:4, 144:6, 144:8, 
144:11, 144:14, 144:15, 144:16, 
145:12, 145:13, 145:17, 145:20, 
145:22, 145:24, 146:16, 148:3, 159:1, 
159:17, 161:16, 161:23, 162:8, 
162:17, 168:11, 171:5, 173:21
EXACT [1] - 159:25
EXAMINE [1] - 162:11
EXAMPLE [7] - 160:23, 161:9, 161:13, 
164:12, 164:17, 165:22
EXCEPT [1] - 143:23
EXCHANGE [1] - 157:15
EXCLUDE [1] - 143:6
EXCLUSIVE [1] - 153:14
EXCUSE [3] - 147:19, 152:23, 159:15
EXCUSED [1] - 177:5
EXHIBITRON [3] - 164:2, 164:3, 164:5
EXHIBITS [9] - 143:19, 165:14, 165:16, 
167:6, 169:7, 171:3, 174:4, 174:13, 
177:14
EXIST [1] - 160:21
EXISTED [1] - 160:20
EXISTENCE [1] - 168:11
EXITED [2] - 167:7, 176:11
EXPECTATION [2] - 174:17, 175:3
EXPERIENCE [1] - 146:24
EXPLAIN [4] - 142:16, 147:18, 162:5, 
170:8
EXTENSION [2] - 156:7, 157:15
EYES [1] - 161:7
EYEWITNESS [1] - 144:10
F
FACT [21] - 144:9, 144:12, 145:23, 
146:10, 149:10, 149:19, 149:21, 
149:25, 150:2, 150:4, 152:4, 152:14, 
152:18, 152:20, 152:22, 152:24, 
160:18, 160:20, 160:21
FACTS [9] - 142:10, 144:1, 144:11, 
151:20, 151:23, 154:15, 156:1, 
156:20, 162:16
FACTUAL [1] - 143:23
FAILS [1] - 143:2
FAIR [1] - 171:10
FAIRLY [2] - 174:14, 175:4
FAITH [3] - 159:10, 159:12, 159:20
FALSE [23] - 147:16, 149:1, 149:9, 
149:11, 149:18, 149:20, 149:24, 
150:8, 150:10, 152:1, 152:3, 152:11, 
152:13, 152:17, 153:2, 153:4, 153:13, 
155:22, 156:3, 156:10, 156:13, 
159:22, 163:2
FALSELY [1] - 145:23
FAR [1] - 169:24
FEBRUARY [2] - 177:25, 179:9
FEBRUARY [1] - 141:11
FEDERAL [2] - 156:9, 158:7
FEDERAL [8] - 148:23, 149:15, 150:22, 
151:16, 153:25, 155:22, 156:16, 
158:16
FEDERALLY [4] - 147:17, 149:15, 
155:23, 163:3
FELONY [1] - 158:16
FEW [4] - 144:24, 163:18, 174:19, 
177:15
FIELD [1] - 146:24
FILED [3] - 1:3, 1:8, 1:10
FINANCIAL [13] - 147:17, 148:24, 
148:25, 149:7, 149:8, 149:13, 155:23, 
156:17, 156:23, 157:13, 157:18, 
158:3, 158:6
FINE [7] - 151:11, 169:20, 171:14, 
172:8, 172:14, 172:19, 174:3
FINISH [1] - 157:9
FIRST [8] - 147:21, 164:7, 164:10, 
165:4, 166:13, 168:3, 169:23, 170:6
FIXED [2] - 166:15, 175:16
FLASH [2] - 173:16, 173:23
FOLLOW [3] - 142:16, 142:17, 169:17
FOLLOW-UP [1] - 169:17
FOLLOWING [1] - 1:2
FOLLOWING [6] - 149:4, 151:20, 
151:23, 154:15, 156:1, 156:20
FOLLOWS [2] - 168:24, 177:25
FOOLISHNESS [1] - 161:11
FOR [2] - 1:5, 141:1
FORBIDS [2] - 160:9, 160:11
FOREGOING [1] - 179:6
FOREIGN [6] - 157:19, 157:22, 158:4, 
158:5, 158:9, 158:16
FOREPERSON [6] - 163:21, 165:2, 
165:7, 165:9, 174:16
FORGET [1] - 146:5
FORM [15] - 158:1, 158:19, 163:23, 
183
163:25, 164:5, 165:2, 165:3, 165:5, 
165:7, 165:8, 165:10, 165:12, 167:5, 
169:5, 171:3
FORMAL [2] - 142:20, 154:10
FORMED [1] - 159:14
FORMS [1] - 164:10
FORTH [1] - 175:20
FOSTER [2] - 141:7, 141:17
FOSTER [8] - 147:6, 147:11, 147:15, 
160:17, 164:11, 164:15, 168:8, 170:7
FOSTER'S [4] - 164:8, 165:5, 173:10, 
173:15
FRAUD [22] - 147:12, 147:13, 147:16, 
151:1, 151:2, 151:13, 151:15, 153:15, 
154:2, 154:3, 154:19, 155:13, 157:3, 
158:22, 162:23, 162:24, 164:14, 
164:24
FRAUDULENT [16] - 149:9, 149:11, 
149:18, 149:21, 149:24, 150:10, 
152:1, 152:11, 152:13, 152:17, 153:4, 
153:13, 159:15, 159:18, 159:22
FROM [1] - 1:9
FULL [1] - 176:3
FULL [1] - 1:9
FULLY [1] - 162:8
G
GENERAL [1] - 155:1
GENTLEMEN [3] - 163:17, 164:10, 
174:12
GEORGIA [4] - 141:1, 141:25, 142:1, 
179:4
GIFT [1] - 157:12
GIGANTIC [1] - 177:20
GIVEN [5] - 147:9, 169:1, 170:24, 
171:10, 176:15
GOALS [1] - 155:7
GOVERNING [1] - 147:18
GOVERNMENT [1] - 141:14
GOVERNMENT [19] - 142:9, 142:15, 
143:1, 145:13, 150:15, 151:10, 153:9, 
154:8, 154:12, 155:16, 155:18, 
156:14, 158:23, 159:12, 159:24, 
160:1, 164:23, 167:1, 167:21
GOVERNMENT'S [5] - 143:4, 143:6, 
160:16, 160:17, 167:17
GRAB [1] - 172:3
GREATER [2] - 146:20, 175:13
GROSS [1] - 158:19
GROUP [1] - 164:14
GUESS [1] - 174:4
GUILT [4] - 142:21, 143:1, 143:5, 143:7
GUILTY [30] - 142:10, 143:3, 143:14, 
148:2, 149:3, 150:25, 151:19, 154:14, 
155:4, 155:20, 155:25, 156:19, 
161:18, 161:24, 162:1, 162:2, 162:3, 
162:24, 163:1, 163:4, 163:5, 164:16, 
164:20, 164:22, 165:6
GYMNASTICS [1] - 171:8
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 44 of 49

H
HALF [4] - 149:24, 152:17, 170:6, 
170:19
HALF-TRUTH [1] - 152:17
HAPPY [1] - 175:11
HARD [1] - 174:14
HAS [1] - 1:8
HEARD [3] - 164:1, 170:22, 171:13
HEARING [1] - 161:9
HEART [2] - 154:11, 156:12
HEAVY [1] - 143:4
HELD [1] - 159:14
HELD [1] - 142:1
HELLO [1] - 176:13
HELP [1] - 152:8
HELPFUL [1] - 146:23
HEREBY [1] - 179:6
HESITATE [1] - 162:11
HESITATION [1] - 143:13
HIGH [1] - 160:20
HOLD [1] - 176:16
HONEST [2] - 159:19, 162:13
HONESTLY [2] - 159:14
HONOR [28] - 151:11, 163:10, 163:11, 
163:12, 166:17, 166:19, 167:9, 
167:14, 168:3, 168:19, 169:25, 170:2, 
170:4, 170:25, 171:1, 171:14, 171:23, 
171:25, 172:10, 172:19, 172:21, 
173:7, 173:8, 173:9, 173:10, 173:18, 
177:7, 177:13
HONORABLE [1] - 141:10
HOPEFULLY [2] - 170:19, 176:2
HOUR [2] - 170:5, 170:19
HOURS [3] - 171:18, 174:20, 175:14
HOWEVER [1] - 1:8
I
IDENTIFIED [1] - 162:20
IDENTITIES [1] - 154:24
ILL [1] - 170:7
IMPARTIALLY [1] - 143:9
IMPORTANT [6] - 143:13, 144:18, 
145:23, 146:10, 150:2, 152:20
IMPRESS [1] - 144:25
IMPRESSION [1] - 169:8
IMPRESSIONS [1] - 146:20
IN [3] - 1:3, 1:4, 142:1
INACCURATELY [1] - 146:6
INC [1] - 164:14
INCLUDES [5] - 143:18, 149:16, 157:14, 
157:24, 158:7
INCLUDING [3] - 145:18, 158:19, 
165:19
INCONVENIENCE [1] - 175:14
INCONVENIENCED [1] - 176:2
INDEPENDENT [1] - 146:16
INDICATING [1] - 176:25
INDICTMENT [18] - 142:20, 147:4, 
147:9, 150:16, 150:21, 153:10, 154:9, 
154:19, 155:12, 156:6, 159:5, 159:23, 
161:14, 161:22, 164:13, 165:14, 
165:21, 167:5
INDIFFERENCE [2] - 149:22, 152:15
INDIRECTLY [1] - 158:18
INDIVIDUALLY [1] - 161:18
INFLUENCE [5] - 150:5, 152:23, 152:25, 
156:5, 156:12
INFLUENCED [3] - 142:13, 146:17, 
156:15
INJURY [4] - 150:12, 150:13, 153:6, 
153:7
INNOCENCE [1] - 142:23
INNOCENT [2] - 142:22, 146:7
INSTEAD [3] - 163:15, 176:16, 176:18
INSTITUTION [16] - 147:17, 148:24, 
149:1, 149:7, 149:9, 149:14, 149:15, 
155:24, 156:5, 156:8, 156:13, 156:15, 
157:13, 158:4, 158:6, 163:3
INSTRUCT [1] - 142:4
INSTRUCTION [2] - 160:15, 171:1
INSTRUCTIONS [9] - 142:6, 142:18, 
142:19, 143:24, 147:25, 162:19, 
165:13, 167:6, 169:6
INSTRUMENT [1] - 157:17
INSTRUMENTS [3] - 157:23, 158:1
INSURANCE [2] - 156:9, 158:7
INSURED [6] - 147:17, 149:15, 155:23, 
156:8, 158:7, 163:3
INTENDED [5] - 149:13, 149:17, 152:10, 
153:14, 159:21
INTENSIVE [1] - 174:14
INTENT [23] - 149:23, 150:1, 150:9, 
150:10, 150:12, 150:13, 152:5, 
152:16, 152:18, 153:3, 153:4, 153:6, 
153:7, 156:4, 159:11, 159:12, 159:16, 
159:18, 160:8, 160:11, 171:15
INTENTIONAL [1] - 146:8
INTENTIONALLY [3] - 148:9, 148:17, 
160:5
INTEREST [2] - 145:4, 162:16
INTERESTS [1] - 155:7
INTERPRETATION [1] - 144:2
INTERRUPT [1] - 173:12
INTERSTATE [11] - 150:22, 151:16, 
152:7, 153:13, 153:19, 153:22, 
157:19, 157:22, 158:4, 158:5, 158:9
INVESTMENT [1] - 157:25
INVOLVED [3] - 156:25, 158:4, 158:13
INVOLVES [1] - 164:11
INVOLVING [3] - 157:22, 158:2, 158:3
IS [1] - 1:2
ISSUE [6] - 143:23, 167:9, 170:24, 
171:17, 172:7, 173:22
ISSUES [7] - 163:7, 166:14, 166:15, 
169:2, 170:9, 171:17, 174:13
ITSELF [3] - 153:13, 154:12, 159:3
184
J
J.P [1] - 141:10
JACKSON [3] - 147:8, 147:14, 160:16
JACKSON [2] - 141:6, 141:20
JACKSON'S [1] - 165:3
JOINED [2] - 154:21, 155:2
JOINS [1] - 148:9
JUDGE [4] - 151:7, 172:2, 172:23, 
177:15
JUDGE [2] - 162:2, 166:23
JUDGE [1] - 141:10
JUDGES [2] - 162:15, 162:16
JUDGMENT [1] - 159:17
JUROR [1] - 166:7
JURORS [1] - 176:25
JURORS [10] - 146:18, 162:8, 166:5, 
166:7, 166:9, 176:13, 176:20, 176:23, 
177:5
JURY [1] - 141:9
JURY [29] - 142:2, 142:4, 142:6, 163:18, 
163:20, 164:10, 164:15, 165:8, 
166:13, 167:4, 167:7, 167:10, 169:3, 
169:4, 169:10, 169:16, 169:19, 
169:21, 170:11, 170:23, 171:15, 
172:4, 174:10, 174:12, 176:8, 176:11, 
176:17, 177:2, 177:11
K
KAUSHAL [5] - 141:15, 151:11, 163:12, 
166:18, 167:1
KEEP [2] - 146:3, 176:19
KIND [5] - 154:5, 154:10, 156:25, 
158:14, 168:14
KINDS [1] - 156:17
KNOWING [2] - 148:22, 154:22
KNOWINGLY [13] - 147:12, 149:6, 
150:9, 150:20, 151:25, 153:3, 153:25, 
155:22, 156:4, 156:13, 156:16, 
156:22, 160:4
KNOWLEDGE [6] - 144:9, 146:23, 
160:18, 160:22, 160:23, 161:2
KNOWN [3] - 150:7, 153:2, 156:17
KNOWS [3] - 149:22, 152:14, 156:11
L
LADIES [3] - 163:17, 164:10, 174:12
LAPSE [1] - 146:7
LAST [1] - 175:14
LAUNDERING [2] - 147:18, 156:18
LAW [13] - 142:5, 142:16, 142:17, 
142:19, 142:21, 143:24, 147:18, 
158:16, 160:9, 160:10, 160:11, 
160:13, 162:20
LAWYERS [1] - 143:20
LEARNING [1] - 160:25
LEAST [2] - 155:2, 158:10
LEE [5] - 163:25, 164:6, 164:18, 165:15, 
169:12
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 45 of 49

LEGAL [1] - 144:13
LEIGH [1] - 141:18
LINE [1] - 170:10
LINE [1] - 1:7
LIST [1] - 174:3
LISTED [3] - 164:12, 165:6, 165:24
LITIGATED [2] - 167:18, 167:19
LOAN [5] - 150:12, 156:7, 157:11, 
157:15, 168:8
LOCATION [2] - 157:6, 158:25
LOSE [1] - 176:20
LOSS [4] - 150:11, 150:13, 153:5, 153:7
LOST [1] - 166:8
LUCK [1] - 177:18
M
MAIL [1] - 163:9
MANAGEMENT [1] - 159:17
MANNER [1] - 154:17
MARSHALL [13] - 141:20, 151:7, 151:9, 
163:11, 166:23, 170:4, 171:1, 171:14, 
172:2, 172:23, 173:9, 173:14, 177:13
MARSHALL [6] - 151:8, 170:3, 171:13, 
172:1, 172:22, 177:16
MATERIAL [18] - 149:10, 149:12, 
149:19, 149:21, 149:25, 150:2, 150:4, 
152:4, 152:14, 152:18, 152:20, 
152:22, 152:24, 153:11, 153:12, 
167:16, 167:25, 168:1
MATERIALS [2] - 165:19, 174:18
MATTER [4] - 144:22, 146:25, 150:6, 
152:25
MATTERS [1] - 144:3
MAY [2] - 1:3, 1:5
MEAN [3] - 144:16, 146:3, 147:1
MEANS [13] - 150:9, 152:9, 153:3, 
153:14, 157:9, 157:11, 157:18, 
157:20, 158:9, 158:17, 158:21, 160:4, 
160:7
MEMBER [3] - 154:6, 154:7, 170:7
MEMBERS [4] - 142:4, 154:9, 154:10, 
163:21
MEMORIES [1] - 146:20
MEMORY [3] - 145:6, 146:7, 146:14
MENTIONED [1] - 165:4
MERELY [4] - 148:22, 155:6, 158:24, 
159:2
MESSAGE [3] - 166:1, 169:17, 172:13
MIGHT [3] - 146:23, 164:3, 174:5
MILLION [1] - 177:20
MIND [2] - 146:3, 162:11
MINOR [1] - 154:25
MINUTES [7] - 170:17, 170:19, 170:21, 
171:18, 174:19
MISLED [1] - 156:15
MISSED [1] - 163:18
MISSTATED [1] - 146:6
MISSTATEMENT [1] - 146:9
MISTAKE [3] - 146:3, 159:17, 160:5
MISTAKEN [1] - 159:16
MOMENT [4] - 147:20, 157:8, 162:18, 
168:17
MONETARY [3] - 157:17, 157:23
MONEY [14] - 147:17, 148:25, 149:8, 
149:17, 152:10, 156:17, 156:24, 
157:2, 157:12, 157:20, 157:25, 
158:13, 158:15, 159:2
MOORE [1] - 141:15
MORNING [8] - 170:13, 170:24, 171:20, 
173:3, 175:10, 175:18, 175:21, 176:5
MOST [2] - 143:13, 146:12
MOTION [1] - 168:21
MOTIONS [1] - 167:18
MOVE [1] - 167:24
MOVING [1] - 157:20
MR [16] - 151:7, 151:9, 151:11, 163:11, 
163:12, 166:18, 166:23, 167:1, 170:4, 
171:1, 171:14, 172:2, 172:23, 173:9, 
173:14, 177:13
MS [24] - 151:4, 151:6, 163:10, 166:17, 
166:19, 167:9, 167:14, 168:3, 168:19, 
169:25, 170:2, 170:18, 170:25, 
171:23, 171:25, 172:10, 172:19, 
172:21, 173:7, 173:8, 173:18, 174:7, 
177:7, 177:12
MUELLER [1] - 151:21
MULTIPLE [3] - 159:4, 159:6, 168:12
MULTIPLICITOUS [1] - 167:19
MUST [36] - 142:5, 142:9, 142:12, 
142:13, 142:16, 142:17, 142:18, 
143:1, 143:2, 143:17, 144:15, 144:16, 
145:14, 145:17, 146:6, 146:14, 
146:15, 146:16, 147:1, 147:2, 148:20, 
150:18, 155:20, 158:24, 159:1, 
159:12, 160:10, 161:10, 161:15, 
161:16, 161:19, 161:25, 162:3, 162:4, 
162:7, 162:9
N
NAMED [1] - 154:9
NAMES [1] - 154:23
NATURAL [3] - 150:5, 152:22, 152:24
NATURALLY [1] - 146:5
NATURE [5] - 150:16, 153:10, 157:6, 
158:25, 159:3
NECESSARILY [1] - 144:21
NECESSARY [1] - 142:10
NEED [10] - 160:12, 166:11, 170:11, 
172:17, 174:5, 176:4, 176:9, 176:22, 
177:14
NEGLIGENCE [1] - 161:10
NEGOTIABLE [1] - 158:1
NEVER [2] - 161:25, 162:5
NEXT [1] - 160:15
NO [1] - 141:5
NORMAL [1] - 153:21
NORMALLY [2] - 153:20, 172:6
NORTHERN [2] - 141:1, 179:4
185
NOTE [1] - 147:21
NOTES [5] - 146:11, 146:14, 146:15, 
146:17, 146:19
NOTHING [1] - 168:19
NUMBER [2] - 144:20, 147:6
NUMBER [2] - 1:6, 1:7
O
OBJECT [1] - 164:23
OBJECTED [1] - 166:16
OBJECTION [4] - 161:9, 166:20, 167:1, 
168:4
OBJECTIONS [1] - 166:24
OBSERVE [1] - 145:8
OBTAINED [1] - 158:18
OCCASION [1] - 155:3
OCCURRED [1] - 159:25
OCCURS [1] - 160:23
OF [10] - 1:2, 1:5, 1:6, 141:1, 141:4, 
141:9, 141:14, 141:17, 141:20, 179:4
OFFENSE [5] - 147:23, 147:24, 154:15, 
159:5, 162:25
OFFENSES [3] - 147:15, 147:19, 147:20
OFFERS [1] - 145:13
OFFICER [1] - 166:2
OFFICER [1] - 174:9
OFFICIAL [6] - 1:2, 1:3, 1:4, 1:8, 141:24, 
179:15
ON [3] - 141:14, 141:17, 141:20
ONCE [3] - 173:3, 175:8, 175:21
ONE [26] - 144:25, 145:15, 150:21, 
155:2, 155:9, 155:19, 157:8, 157:22, 
159:7, 161:15, 161:18, 162:9, 162:18, 
162:20, 163:20, 164:7, 164:11, 166:5, 
167:9, 167:20, 167:23, 168:7, 168:17, 
169:15, 176:20, 176:22
ONES [1] - 166:20
ONLY [2] - 1:3, 1:7
OPEN [1] - 142:1
OPINION [7] - 143:23, 146:24, 147:2, 
147:3, 159:14, 159:16, 162:11
OPPORTUNITY [2] - 145:7, 146:13
OPPOSED [1] - 167:21
OPTIONS [1] - 165:6
OR [1] - 1:9
ORDERS [1] - 157:25
ORDINARILY [1] - 148:5
OUTCOME [1] - 145:5
OUTSIDE [1] - 158:12
OWN [4] - 143:13, 144:1, 144:2, 162:11
OWNED [1] - 148:25
OWNERS [1] - 168:13
OWNERSHIP [3] - 157:6, 158:2, 158:25
P
P.M [5] - 168:23, 168:24, 174:10, 
176:11, 177:24
PACKAGE [1] - 160:24
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 46 of 49

PACKAGE'S [1] - 161:2
PACKET [1] - 165:18
PAGE [3] - 151:21, 163:13, 164:18
PAGE [1] - 1:7
PAGES [3] - 151:22, 177:20, 179:6
PARALEGAL [3] - 170:8, 172:5, 177:21
PARDON [1] - 163:17
PART [5] - 144:20, 153:23, 157:5, 
164:21, 173:22
PARTIAL [1] - 1:9
PARTICIPANT [1] - 148:21
PARTICIPATE [1] - 157:10
PARTICIPATED [2] - 148:17, 151:25
PARTICULAR [2] - 144:21, 145:2
PARTIES [9] - 165:15, 165:20, 165:23, 
173:20, 173:25, 174:23, 175:1, 
175:20, 176:15
PARTNER [1] - 154:7
PARTNERSHIP [1] - 154:6
PARTY [1] - 171:16
PASSED [1] - 175:5
PAUSE [3] - 170:12, 171:19, 175:6
PDF [1] - 1:2
PENNY [2] - 141:24, 179:15
PEOPLE [6] - 146:5, 154:9, 155:6, 
158:10, 158:11, 158:12
PERFORMED [1] - 148:3
PERHAPS [1] - 146:12
PERIOD [1] - 1:5
PERMISSIBLE [1] - 169:19
PERMISSION [1] - 161:8
PERMITTED [1] - 146:11
PERSON [18] - 144:8, 146:23, 148:5, 
148:6, 148:8, 148:9, 148:11, 148:12, 
148:16, 150:3, 152:21, 154:22, 155:8, 
156:11, 160:10, 160:12, 172:25
PERSON'S [3] - 150:5, 152:23, 152:25
PERSONAL [2] - 145:4, 157:25
PERSONALLY [2] - 148:3, 153:16
PERSONS [2] - 154:4, 154:17
PHONES [1] - 176:19
PHRASE [3] - 157:23, 158:6, 158:21
PHRONT [1] - 164:14
PLACES [1] - 162:21
PLAN [11] - 149:16, 152:9, 154:9, 
154:11, 154:13, 154:18, 154:21, 
154:23, 154:25, 155:2
PLANNING [1] - 174:1
PLAYED [1] - 154:25
PLUS [1] - 170:6
PM [2] - 141:6, 142:1
POINT [6] - 144:21, 157:10, 166:11, 
170:10, 170:16, 175:23
PORTION [1] - 1:5
POSITION [1] - 169:12
POSITIVE [1] - 160:22
POSSESSES [1] - 160:24
POSSESSION [2] - 161:4, 161:12
POSSIBLE [3] - 143:5, 148:2, 166:3
POTENTIALLY [1] - 172:16
PRACTICING [1] - 177:19
PRECISE [2] - 150:16, 153:10
PREJUDICE [1] - 142:14
PREPARED [1] - 163:23
PRESENT [2] - 148:19, 155:5
PRESENTED [1] - 142:13
PRESERVE [1] - 166:20
PRESERVED [1] - 168:5
PRESUMES [1] - 142:21
PRETENSES [9] - 149:1, 149:9, 149:11, 
149:18, 150:11, 152:2, 152:3, 152:11, 
153:5
PRETTY [1] - 169:2
PREVIOUS [1] - 166:24
PREVIOUSLY [2] - 166:16, 166:20
PRINTED [1] - 173:22
PRINTING [1] - 173:24
PRIORITY [1] - 146:15
PRITTY [2] - 141:24, 179:15
PROBABILITY [1] - 160:20
PROBLEM [1] - 177:21
PROCEEDINGS [3] - 168:23, 177:24, 
179:7
PROCEEDINGS [2] - 141:9, 142:1
PROCEEDS [4] - 156:25, 157:7, 158:17, 
159:1
PROCESS [1] - 174:2
PRODUCE [1] - 142:23
PROHIBITED [1] - 1:9
PROMISE [2] - 157:11, 170:21
PROMISES [9] - 149:2, 149:10, 149:12, 
149:19, 150:11, 152:2, 152:3, 152:12, 
153:5
PROMPTLY [1] - 166:3
PROOF [8] - 143:4, 143:6, 143:11, 
144:11, 148:16, 148:18, 155:7
PROPERTY [10] - 148:25, 149:8, 
149:18, 152:11, 156:24, 157:2, 
157:13, 158:13, 158:15, 158:17
PROPRIETY [1] - 168:16
PROVE [24] - 142:22, 143:1, 143:5, 
144:12, 148:2, 150:13, 150:15, 
150:17, 153:7, 153:9, 153:11, 153:12, 
153:17, 154:8, 154:12, 155:16, 
156:14, 158:23, 158:24, 159:12, 
159:25, 160:1, 161:11
PROVED [11] - 142:9, 143:14, 149:4, 
150:19, 151:20, 151:23, 154:15, 
156:1, 156:20, 159:7, 164:23
PROVES [1] - 155:18
PROVING [2] - 150:12, 153:6
PUNISHMENT [2] - 161:25, 162:2
PURCHASE [2] - 157:11, 157:16
PURPOSE [7] - 150:16, 153:10, 154:20, 
155:1, 155:9, 158:24, 160:9
PURPOSELY [1] - 160:8
PURPOSES [1] - 154:6
PUT [4] - 163:25, 164:5, 173:18, 174:4
186
PUTTING [2] - 173:23, 175:7
Q
QUESTIONS [3] - 144:24, 145:9, 164:25
R
RADIO [2] - 150:22, 151:16
RAISED [1] - 168:4
RE [1] - 162:11
RE-EXAMINE [1] - 162:11
REACH [5] - 144:5, 162:9, 164:19, 
164:20, 164:21
READ [1] - 151:14
READING [2] - 163:7, 163:8
READY [9] - 169:9, 169:18, 170:14, 
170:17, 174:9, 175:10, 176:3, 176:20, 
177:11
REAL [2] - 143:8, 162:15
REALIZED [1] - 174:25
REASON [4] - 143:9, 145:2, 161:7, 
176:21
REASONABLE [21] - 142:11, 143:1, 
143:7, 143:8, 143:11, 143:15, 148:20, 
149:4, 150:3, 150:19, 151:20, 151:23, 
152:21, 154:16, 155:18, 156:1, 
156:20, 159:8, 159:13, 160:1, 161:5
REASONABLY [1] - 160:2
REASONING [1] - 144:4
RECEIPTS [1] - 158:19
RECEIVE [1] - 173:3
RECESS [2] - 168:23, 177:24
RECKLESS [2] - 149:22, 152:15
RECOLLECTION [2] - 144:2, 146:16
RECORD [3] - 169:1, 173:19, 174:5
RECORDED [1] - 141:23
REFER [1] - 147:9
REFERENCES [1] - 165:21
REFERENCING [1] - 1:7
REGARDING [1] - 156:6
RELATED [2] - 161:16, 171:4
RELATING [1] - 149:19
RELEASE [4] - 170:23, 172:16, 176:8, 
176:18
RELIED [2] - 150:6, 153:1
RELY [2] - 143:12, 147:3
REMEMBER [2] - 146:5, 162:15
REMEMBERS [1] - 146:4
REMINDS [1] - 171:2
RENEW [1] - 166:19
REPORT [4] - 155:23, 156:3, 156:10, 
156:14
REPORTER [4] - 1:4, 1:8, 141:24, 
179:15
REPRESENTATION [4] - 149:20, 
149:24, 152:13, 152:16
REPRESENTATIONS [10] - 149:1, 
149:10, 149:11, 149:19, 150:11, 
152:2, 152:3, 152:12, 153:5, 159:21
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 47 of 49

REPRINT [1] - 151:22
REQUESTING [1] - 167:15
REQUIRED [1] - 159:11
REQUIRES [2] - 148:16, 159:11
RESPOND [1] - 166:3
RESPONSIBLE [3] - 148:10, 148:12, 
148:16
REST [3] - 170:12, 175:16, 176:16
RESTART [2] - 173:4, 173:13
RESTRICTED [1] - 1:4
RESULT [1] - 154:2
RETAINED [1] - 158:18
RETURN [1] - 155:20
REVIEWING [1] - 151:1
RIM [1] - 168:14
RMR [2] - 141:24, 179:15
ROLE [1] - 154:25
ROOM [5] - 142:7, 163:20, 165:9, 167:4, 
169:4
RULE [1] - 160:13
RULES [1] - 142:5
S
SAFE [1] - 157:15
SALE [2] - 157:11, 157:16
SAMIR [1] - 141:15
SARALIENE [1] - 141:18
SAVE [1] - 175:19
SCENE [2] - 148:19, 155:5
SCHEME [14] - 148:24, 149:7, 149:16, 
150:17, 150:18, 150:20, 150:23, 
151:17, 152:1, 152:8, 152:9, 153:11, 
153:17, 153:23
SCIENTIFIC [1] - 146:22
SEATED [5] - 142:3, 167:13, 168:25, 
174:11, 176:12
SECOND [1] - 164:21
SECRET [1] - 162:5
SECURITIES [1] - 158:1
SECURITY [1] - 166:2
SEE [5] - 159:23, 163:9, 165:3, 165:21, 
177:3
SEEK [1] - 162:16
SEEM [1] - 145:6
SEND [2] - 169:6, 169:7
SENDING [2] - 157:20, 173:24
SENSE [5] - 143:9, 144:5, 172:7, 
176:24, 177:1
SENT [5] - 153:20, 169:22, 174:16, 
174:20, 174:22
SENTENCE [1] - 163:13
SEPARATE [6] - 147:4, 153:22, 153:23, 
155:15, 161:14, 164:9
SEPARATELY [2] - 161:16, 161:17
SERVICE [1] - 177:2
SESSION [1] - 141:6
SHORTLY [4] - 165:19, 167:5, 169:5, 
175:4
SHOWED [1] - 168:11
SIGN [4] - 165:1, 165:2, 165:7, 165:10
SIGNIFICANCE [1] - 146:8
SIMILAR [2] - 150:21, 177:21
SIMILARLY [1] - 159:16
SIMPLE [1] - 146:3
SIMPLY [4] - 148:18, 155:5, 162:14, 
165:5
SINGLE [1] - 142:18
SITUATION [1] - 177:19
SMALL [1] - 163:13
SOMEONE [9] - 145:14, 149:17, 150:24, 
151:18, 152:1, 152:10, 154:1, 163:8, 
172:3
SOMETIMES [1] - 169:3
SOON [1] - 174:17
SORRY [4] - 170:20, 173:12, 176:1
SOURCE [2] - 157:6, 158:25
SPEAKER [2] - 149:21, 152:14
SPECIAL [1] - 146:23
SPECIALIZED [1] - 146:22
SPECIFIC [8] - 142:10, 147:25, 150:10, 
153:4, 153:14, 160:13, 161:22, 161:24
SPECIFICALLY [4] - 147:6, 147:16, 
157:3, 167:17
SPECIFIED [2] - 157:2, 158:21
SPECIFIES [1] - 159:4
SPECTATOR [1] - 148:22
SPEED [1] - 176:3
SPOKEN [2] - 175:20, 176:15
STACK [8] - 169:5, 169:22, 173:3, 
174:18, 175:9, 175:17, 175:22, 177:11
STAND [1] - 166:11
STANDBY [1] - 172:16
START [3] - 157:9, 164:8, 169:19
STARTS [1] - 163:13
STATE [2] - 146:24, 158:16
STATEMENT [17] - 145:14, 145:15, 
145:18, 145:20, 149:20, 149:23, 
150:7, 152:13, 152:16, 153:1, 153:2, 
155:23, 156:3, 156:10, 156:14, 163:2
STATEMENTS [1] - 147:16
STATES [6] - 141:1, 141:4, 141:10, 
141:16, 141:25, 179:3
STATES [1] - 158:11
STATES [2] - 158:11, 158:12
STATUTE [1] - 159:4
STAY [1] - 177:14
STENOGRAPHICALLY [1] - 141:23
STEP [1] - 167:21
STICKERING [1] - 173:25
STILL [3] - 169:18, 175:5, 176:22
STIPULATION [1] - 165:22
STOCK [1] - 157:16
STOOD [1] - 167:22
STRAIGHT [1] - 176:2
STUFF [2] - 172:6, 173:25
SUBJECT [1] - 166:24
SUBMITTED [1] - 173:16
SUBMITTING [1] - 173:11
187
SUBSTANCE [5] - 160:25, 161:1, 161:4, 
161:6, 161:12
SUBSTANTIAL [1] - 159:2
SUBSTANTIALLY [1] - 150:20
SUBSTANTIVE [5] - 147:15, 147:19, 
147:23, 155:15
SUCCEED [1] - 159:20
SUCCEEDED [3] - 150:18, 153:18, 
154:13
SUFFICIENT [5] - 150:13, 153:7, 155:3, 
155:18, 159:8
SUGGEST [1] - 144:23
SUGGESTED [1] - 168:7
SUGGESTION [1] - 170:23
SUPPOSED [1] - 163:19
SWITCH [1] - 163:19
SYMPATHY [1] - 142:14
T
TAL [1] - 141:14
TEAM [1] - 170:7
TECHNICAL [1] - 146:22
TELDRIN [2] - 164:15, 168:8
TELDRIN [2] - 141:7, 141:17
TELEVISION [2] - 150:23, 151:17
TEND [2] - 144:12, 146:5
TENDENCY [3] - 150:5, 152:23, 152:25
TERM [1] - 158:17
TESTIFIED [2] - 145:8, 145:23
TESTIFY [2] - 142:24, 142:25
TESTIFYING [1] - 144:21
TESTIMONY [8] - 143:19, 144:8, 
144:18, 145:11, 145:12, 146:1, 
146:21, 147:2
THE [51] - 1:2, 1:4, 1:6, 1:7, 1:8, 1:10, 
141:1, 141:10, 141:14, 141:17, 
141:20, 142:3, 151:5, 151:8, 151:10, 
151:12, 163:16, 164:8, 165:18, 
166:22, 166:25, 167:2, 167:8, 167:10, 
168:2, 168:17, 168:20, 168:25, 170:1, 
170:3, 170:5, 170:22, 171:6, 171:15, 
171:24, 172:1, 172:3, 172:14, 172:20, 
172:22, 172:24, 173:12, 174:3, 174:8, 
174:11, 176:12, 177:6, 177:8, 177:16
THEREAFTER [1] - 174:17
THEREIN [1] - 165:24
THEY'VE [1] - 175:20
THINKING [1] - 169:21
THOMAS [1] - 168:9
THROUGHOUT [1] - 176:14
TO [2] - 1:5, 1:9
TOGETHER [2] - 168:13, 175:8
TOMORROW [7] - 174:6, 174:7, 175:10, 
175:18, 176:4, 176:17, 176:21
TRACK [1] - 166:8
TRADE [1] - 158:9
TRAINING [1] - 146:23
TRANSACTION [15] - 156:23, 156:25, 
157:4, 157:9, 157:10, 157:11, 157:13, 
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 48 of 49

157:18, 157:21, 158:2, 158:3, 158:14, 
159:2
TRANSACTIONS [1] - 156:17
TRANSCRIPT [1] - 179:7
TRANSCRIPT [5] - 1:3, 1:6, 1:8, 1:9, 
141:9
TRANSCRIPTS [1] - 1:3
TRANSFER [3] - 157:12, 157:14, 158:2
TRANSMISSION [1] - 153:16
TRANSMITTED [3] - 152:6, 152:7, 
153:12
TRANSPIRED [1] - 175:12
TRAVELERS [1] - 157:24
TRIAL [8] - 142:13, 143:25, 146:2, 
146:11, 161:21, 164:2, 168:11, 175:13
TRIAL [1] - 141:9
TRIED [1] - 156:22
TROUBLE [1] - 170:11
TRUE [2] - 144:16, 179:6
TRUTH [8] - 145:1, 145:3, 146:4, 
149:23, 149:25, 152:15, 152:17, 
162:16
TRY [4] - 154:18, 162:9, 171:8, 175:16
TRYING [1] - 174:2
TURNED [2] - 171:18, 174:19
TURNS [1] - 173:21
TWO [10] - 145:16, 151:22, 154:4, 
154:17, 155:15, 155:21, 158:10, 
164:9, 176:8, 176:9
TYPICAL [1] - 169:2
U
ULTIMATELY [1] - 159:20
UNANIMOUS [1] - 162:4
UNANIMOUSLY [3] - 159:9, 164:15, 
164:23
UNDER [3] - 145:18, 148:7, 158:16
UNDERSCORE [1] - 175:11
UNDULY [1] - 146:17
UNFORTUNATE [1] - 172:7
UNFORTUNATELY [2] - 170:5, 171:18
UNIMPORTANT [1] - 146:10
UNITED [6] - 141:1, 141:4, 141:10, 
141:16, 141:25, 179:3
UNITED [2] - 158:11, 158:12
UNLAWFUL [11] - 154:5, 154:11, 
154:18, 154:20, 154:23, 155:1, 157:1, 
157:2, 158:14, 158:19, 158:21
UNLESS [2] - 160:20, 170:16
UNTRUE [4] - 149:22, 152:14, 156:10, 
156:11
UP [6] - 162:13, 165:1, 167:22, 169:17, 
173:1, 174:2
V
VARIANCE [2] - 167:16, 168:1
VARIOUS [1] - 165:15
VENTURE [1] - 159:19
188
VERBAL [1] - 171:8
VERDICT [19] - 155:20, 161:19, 162:3, 
162:6, 163:23, 163:25, 164:5, 164:10, 
164:20, 164:22, 165:2, 165:3, 165:5, 
165:8, 165:9, 165:12, 167:5, 169:5
VERSUS [1] - 163:6
VIOLATING [1] - 160:14
VOLUME [1] - 141:6
VOLUNTARILY [2] - 160:5, 160:8
VOTED [1] - 166:5
VS [1] - 141:5
W
WAIT [1] - 167:10
WAYS [2] - 159:4, 159:6
WEBSTER [10] - 151:5, 166:22, 167:12, 
168:18, 170:1, 170:16, 171:24, 172:5, 
172:20, 173:17
WEBSTER [18] - 141:18, 151:4, 151:6, 
163:10, 166:17, 166:19, 167:9, 
167:14, 168:19, 170:2, 170:18, 
171:25, 172:10, 172:21, 173:8, 
173:18, 174:7, 177:12
WEIGHT [3] - 144:13, 145:16, 146:20
WHOLE [3] - 142:18, 144:20, 157:5
WILL [1] - 1:4
WILLFUL [1] - 148:21
WILLFULLY [9] - 147:12, 148:13, 
153:25, 154:21, 155:2, 155:17, 
155:19, 160:7, 160:12
WILLING [1] - 143:12
WIRE [22] - 147:13, 147:16, 150:22, 
151:2, 151:15, 151:16, 152:7, 153:13, 
153:14, 153:16, 153:19, 153:20, 
153:22, 154:3, 154:19, 155:13, 157:3, 
157:20, 158:21, 162:24, 164:14, 
164:24
WISH [1] - 165:25
WITH [1] - 1:10
WITHDRAWAL [1] - 157:14
WITNESS [14] - 144:18, 144:20, 144:23, 
144:25, 145:2, 145:4, 145:6, 145:7, 
145:9, 145:23, 145:25, 146:1, 146:4, 
146:6
WITNESS'S [3] - 145:11, 147:1, 147:2
WITNESSES [2] - 143:19, 144:20
WORD [3] - 159:7, 160:4, 160:7
WORDS [5] - 148:20, 154:5, 155:13, 
162:4, 163:14
WRAP [1] - 174:2
WRITE [1] - 166:1
WRITING [1] - 166:3
Y
Y'ALL [6] - 142:3, 167:13, 168:25, 
169:6, 176:10, 176:12
YOU [2] - 1:5, 1:8
YOURSELF [6] - 144:24, 145:15, 
145:22, 146:17, 147:3, 162:7
Case 1:20-cr-00296-JPB-CMS     Document 1032     Filed 06/14/24     Page 49 of 49

File and source

File

gov.uscourts.gand.292218.1032.0.pdf

Size

528,823 bytes

SHA-256

67417b6e000d5baadc51ed95c5a55d25bca20671f6ca639049d1b1d782a3eb9d

Our copy

gov.uscourts.gand.292218.1032.0.pdf

Original

PACER (login required)