Court filing
TRANSCRIPT filed as to Defendant Richard Ayvazyan, Marietta Terabelian, Artur… — USA v. Ayvazyan et al (Dkt. 672)
Record facts
| Court | U.S. District Court for the Central District of California |
|---|---|
| Filed | 2021-07-09 |
U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 672 · 2021-07-09 · Docket on CourtListener
Summary
A reporter's transcript of Jury Trial - Day Two, Volume 1, A.M. Session, in United States of America v. Richard Ayvazyan, et al., No. CR 20-579 SVW, held in Los Angeles on Wednesday, June 16, 2021 at 9:00 a.m. before United States District Judge Stephen V. Wilson in the U.S. District Court for the Central District of California, Western Division, and filed July 9, 2021 as Doc. 672. Counsel are listed for the Government and for each of the four named defendants. The index lists seven witnesses with the pages of their direct and cross-examinations by the several defense attorneys, and an exhibit table showing lettered and numbered series, among them 1A - 1S and 30 - 36, marked and received at page 16. The opening records proceedings held outside the presence of the jury. The transcript is 143 pages and closes with a word index.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION
HONORABLE STEPHEN V. WILSON
UNITED STATES DISTRICT JUDGE PRESIDING
- - -
United States of America,
)
PLAINTIFF, )
)
VS. ) NO. CR 20-579 SVW
)
Richard Ayvazyan, et al.,
)
DEFENDANT, )
___________________________________)
REPORTER'S TRANSCRIPT OF PROCEEDINGS
LOS ANGELES, CALIFORNIA
JURY TRIAL - DAY TWO
VOLUME 1 - A.M. SESSION
WEDNESDAY, JUNE 16, 2021
_____________________________________
KATIE E. THIBODEAUX, CSR 9858
U.S. Official Court Reporter
Suite 4311
350 West 1st Street
Los Angeles, CA 90012
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APPEARANCES OF COUNSEL:
ON BEHALF OF THE PLAINTIFF, UNITED STATES OF AMERICA:
U.S. DEPARTMENT OF JUSTICE
U.S. ATTORNEY'S OFFICE
BY: CATHERINE SUN AHN, AUSA
-and- SCOTT PAETTY, AUSA
312 North Spring Street
Twelfth Floor
Los Angeles, CA 90012
-and-
Christopher Fenton
US Department of Justice
1400 New York Avenue, NW
Washington, DC 20530
FOR DEFENDANT R. AYVAZYAN:
Ashwin J. Ram
Steptoe and Johnson LLP
633 West 5th Street
Suite 1900
Los Angeles, CA 90071
Meghan Newcomer
Steptoe and Johnson LLP
1114 Avenue of the Americas
New York, NY 10036
Michael A. Keough
Steptoe and Johnson LLP
1 Market Street
Spear Tower Suite 3900
San Francisco, CA 94105
Nicholas P. Silverman
Steptoe and Johnson LLP
1330 Connecticut Avenue NW
Washington, DC 20036
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APPEARANCES (Cont'd):
FOR DEFENDANT TERABELIAN:
John Lewis Littrell
Bienert Katzman Littrell Williams LLP
903 Calle Amanecer
Suite 350
San Clemente, CA 92673
Ryan Vaughan Fraser
Bienert Katzman Littrell Williams LLP
601 West 5th Street
Suite 720
Los Angeles, CA 90071
FOR DEFENDANT ARTUR AYVAZYAN:
Jennifer J. Wirsching
1935 Alpha Road
Suite 216
Glendale, CA 91208
Thomas A. Mesereau, Jr.
Mesereau Law Group
10100 Santa Monica Boulevard
Suite 300
Los Angeles, CA 90067
FOR DEFENDANT VAHE DADYAN:
Peter Johnson
Law Office of Peter Johnson
409 North Pacific Coast Highway
Suite 651
Redondo Beach, CA 90277
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I N D E X
WITNESS NAME PAGE
KATHLEEN LITTWIN
Direct Examination by Ms. Ahn 16
Cross-Examination by Mr. Silverman 38
Cross-Examination by Mr. Mesereau 50
Cross-Examination by Mr. Johnson 52
MARK ZINDROSKI
Direct Examination by Mr. Fenton 61
Cross-Examination by Ms. Newcomer 67
BREANNA FITZGERALD
Direct Examination by Mr. Paetty 69
Cross-Examination by Mr. Keough 76
JACK RUNYAN
Direct Examination by Mr. Fenton 81
Cross-Examination by Ms. Newcomer 89
VICTORIA HERNANDEZ
Direct Examination by Mr. Paetty 90
Cross-Examination by Mr. Keough 98
Cross-Examination by Mr. Johnson 102
ALEXANDER FARD
Direct Examination by Mr. Fenton 106
Cross-Examination by Mr. Keough 113
PINAL MODI
Direct Examination by Mr. Paetty 115
Cross-Examination by Mr. Keough 122
EXHIBIT I.D. IN EVID.
1A - 1S, 2A - 2Q, 3A - 3S 16 16
4A - 4Y, 5A - 5Z, 6A - 6Y 16 16
30 - 36 16 16
83 16 16
38-42 16 16
16 47 48
48 92 97
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LOS ANGELES, CALIFORNIA; WEDNESDAY, JUNE 16, 2021
9:00 A.M.
- - - - -
(The following proceedings were held outside the
presence of the jury:)
THE COURT: Okay. We are present with the parties
and counsel. You may be seated.
Just some short comment on some of the matters
that happened yesterday. We are going to begin promptly
at 9:00 o'clock. I don't intend this to be a lengthy
hearing, but the main purpose is to let whoever is left
to make the opening statement, I don't know if you intend
to get into Grigoryan's plea agreement in your opening
statement, but does anyone intend to do that?
MR. JOHNSON: This is Peter Johnson on behalf of
Vahe Dadyan, no.
MS. WIRSCHING: Jennifer Wirsching for Artur
Ayvazian. No, your Honor.
THE COURT: Okay. Good. So I will take that
issue up later but, just briefly, I have spent the
evening looking into the matter, and, in my view, the
lawyer for Terabelian, Ryan Fraser, improperly used the
plea agreement in the opening statement. But I am not
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going to get into that further now until we have a break
because it is going to take up a little time. I do think
the government's proposed instruction is appropriate, and
I intend to give that at a later point but I don't want
to delay the proceedings.
Is it 9:00 o'clock now?
THE CLERK: It is 2 after.
THE COURT: 2 after. Let's get the jury.
MR. JOHNSON: Just one issue.
THE COURT: No issues.
MR. FENTON: Your Honor, we just have one
housekeeping matter.
THE COURT: No housekeeping matters. We start at
9:00 o'clock.
(The following proceedings were held in the
presence of the jury:)
THE COURT: Good morning, members of the jury.
The parties, counsel and the court appreciate your being
so punctual. I know it takes a special effort, and, as I
said, once you are all here we can begin promptly and we
are going to do that. I hope we can do this every day so
we complete the trial in the most efficient way.
We are going to continue with the opening
statements. So who intends to make the next opening
statement?
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MS. WIRSCHING: I will, your Honor. Jennifer
Wirsching for Artur Ayvazian.
THE COURT: Yes. Thank you.
MS. WIRSCHING: My name is Jennifer Wirsching. I
am going to be speaking for Artur Ayvazian.
Artur Ayvazian is a hard-working family man.
He is a blue collar truck driver. He didn't graduate
from high school but supports his family and his children
by hauling goods over long stretches of the road often
late into the night and early hours of the morning. He
sometimes doesn't even get home at night.
Nearly ten years ago in 2012, Artur Ayvazian
established a small business to manage his trucking jobs.
Artur Ayvazian named his small business Allstate Towing
and Transport. Once his small business was established,
he opened bank accounts for the small business, Allstate
Towing and Transport.
All of these things will be shown by the
evidence that is presented to you.
What the evidence will not show is that Artur
Ayvazian posed as another person. The evidence will not
show that Artur Ayvazian used fake identifications. The
evidence will not show that Artur Ayvazian filed any
false applications. The evidence will not show that
Artur Ayvazian concealed any funds.
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And perhaps, most importantly, the evidence
will not show that Artur Ayvazian conspired with anyone
to do any of those things.
Thank you.
THE COURT: Thank you, Ms. Wirsching.
Is there another party who wishes to make on
opening statement statement?
MR. JOHNSON: Yes, your Honor.
THE COURT: Okay. Go ahead, sir.
MR. JOHNSON: A victim or a participant?
THE COURT: This is on behalf of your client?
MR. JOHNSON: Yes, your Honor.
THE COURT: Vahe Dadyan; correct.
MR. JOHNSON: My name is Peter Johnson, and I
represent Vahe Dadyan.
This is Vahe Dadyan, a husband, a father and a
legitimate business owner. In May of 2020, he filled out
a PPP loan in his own name for his own business, a single
loan. He applied for that loan with the help of his
cousin, Tamara Dadyan, and his cousin at the time
convinced him, yeah, you have a legitimate business,
apply for the loan. I can fill it out.
MS. AHN: Objection. Not in evidence, your Honor.
THE COURT: I mean, what grounds?
MS. AHN: These facts are --
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THE COURT: I can't hear you. I'm sorry.
MS. AHN: These facts are not anticipated to be in
evidence, your Honor.
THE COURT: Well, in an opening statement, members
of the jury, as I said, the lawyers have a duty to only
tell you what evidence they will introduce or they
anticipate another party will introduce. And it is
improper for any lawyer, government or defense, to make
an opening statement that is unsupported by matters that
will be the subject of evidence. I don't know these
things now because I am just like you, I am waiting to
hear the evidence.
But was that your point?
MS. AHN: Yes, your Honor.
THE COURT: All right.
Then, proceed, Mr. Johnson.
MR. JOHNSON: The evidence that you will see in
this trial and the evidence that will come from that
stand is that the PPP loan application was filled out on
a mobile phone. The evidence you will also see is that
the PPP loan application, the single application by
Mr. Vahe Dadyan was submitted from the home of Tamara
Dadyan.
You will hear witnesses talk about IP
addresses and things like that. That is what the
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evidence will be coming from that stand. You will also
hear evidence that Mr. Dadyan had a bank account in his
own name, in his own business: Wells Fargo. There is no
concealment of any kind of money from Mr. Dadyan. The
question at the end of this trial will be is he a victim
or a participant.
Now, what is important in this case is that
two big things you have to pay attention to. The
government has the burden of proving beyond a reasonable
doubt, but they have to show back in May of 2020 there
was two things: Number one, proof beyond a reasonable
doubt of a guilty act. The second is proof beyond a
reasonable doubt of a guilty mind. These are two big
things that I need the jury to pay attention to.
To put it in context, you can think of a case
like a bank robbery, and I know this case is not a bank
robbery but think of it like that just for a second. And
at the end of the trial, the question is is Mr. Dadyan
the taxi driver or the get-away driver. That is the
important question. And we can talk about, over the next
two weeks, you will see 20-plus witnesses get on the
stand here, and you will hear -- there are so many
documents, but I need to you pay attention to those two
things.
We are not disputing the act. He submitted
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the loan for Voyage Limo, but he is the single loan in
this case with his own name and his own business. What
we are saying here today is Tamara Dadyan submitted the
application on his behalf because he didn't understand
English very well, and he needed somebody to guide him
through it.
A victim or a participant? The evidence in
this case again will be some times exhausting. And who
was exhausted yesterday? I mean, I was. I was exhausted
at the end of the day. I mean, there were things that
were just flying by me in the end. And it is scary
because we have to pay attention not to all the evidence
of this guilty act but we have to see evidence coming
from there that Mr. Dadyan had the mind set that he
knowingly jumped in as a participant and not a victim.
That is what we are looking for here. So it
is a criminal case, and we are asking you all to really
pay attention. Again, this is important. We are all
going to be exhausted over the next two weeks. We are
all going to try to figure out what is going on, but we
have to think about the taxi driver or the get-away
driver, the participant in this or the victim.
Let me just briefly go over the evidence and
how we will know at the end of this trial that he is not
jumped in as a participant. The evidence you will see
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again is that there is a single loan in his name. You
heard evidence of stolen identities, credit cards and we
saw even yesterday that things put up on the screen.
MR. FENTON: Objection, your Honor. He is making
reference to --
THE COURT: What ground?
MR. FENTON: He is making reference to the
evidence.
THE COURT: I can't hear you. I'm sorry. I just
can't hear you.
MR. JOHNSON: I understood it. I will make a
clarification. I am not -- the evidence -- we didn't
hear any evidence. Who would be surprised to believe
that we didn't hear any evidence so far. Nothing. The
evidence actually comes from that stand. Everything that
people are saying if it were this side or that side, they
are just statements about what the evidence will show.
Instead, you all, the 12 of you or 16 of you, are the
most important people in the room.
You evaluate not what we are saying but what
happens there, and that is what we are looking for as
evidence that he knew, was a knowing participant and
jumped in instead of being a victim, and we are asking
you to pay attention to the presumption of innocence.
So, again, this is the evidence you will see.
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You will see evidence again of that single loan, but you
won't hear evidence of Mr. Dadyan applying for a loan in
somebody else's name. Fictitious identifications. No
searching of his home. Think about this when you hear
all of this evidence: Did they search his home to find
evidence. You won't see it.
What you will see is in the home of Tamara
Dadyan, a photograph of what we will argue that is the
intent to take his identification. You will see text
messages from other people in the case. What you won't
see is a text message from Mr. Dadyan jumping in. And it
is significant because you will read those text messages.
MR. FENTON: Objection, your Honor. This is
argument.
THE COURT: That is argument. You can outline
what evidence will be introduced on behalf of your client
or whether there will be no evidence, but don't tell the
jury what is important or significant aside from what you
said about the importance of their paying close
attention.
MR. JOHNSON: Understood, your Honor. I would
like for you all to pay attention to the text messages
that you see, and what you will see in those text
messages is not from Mr. Dadyan, but he is referred
specifically as the idiot by Tamara Dadyan. You will not
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see evidence of Mr. Dadyan with gold coins, expensive
jewelry, diamonds, homes, all the evidence that the
government talked about. That is not connected in any
way to Mr. Dadyan.
I am asking you to keep the presumption of
innocence alive, to pay attention to the evidence that
comes from that stand as to what he knew and when he knew
it. And unless and until the government proves beyond a
reasonable doubt that he knowingly jumped in, was more
than a victim, knowing that he was a participant, I am
asking you to find him not guilty. So that is what I
will be asking at the end of this trial. Thank you, and
I look forward to the evidence.
THE COURT: Thank you, Mr. Johnson.
Government, call your first witness.
MS. AHN: Your Honor, before the first witness is
called, the government would like to move into evidence
certain items that have been supported by 90211
certifications.
THE COURT: Is it necessary for that witness?
MS. AHN: Yes, your Honor. They will be
referencing load files.
MR. LITTRELL: Your Honor, we would make a motion
to exclude all fact witnesses at this point before the
witness is called.
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THE COURT: I can't hear you.
MR. LITTRELL: I just want to make sure the court
orders that all witnesses are excluded before we start.
THE COURT: Yes. If there are any potential
witnesses in the courtroom at this time, you should
proceed to the witness room and wait there until you are
called. You should not be here until your presence is
needed to testify. Okay. Go ahead.
MR. LITTRELL: Your Honor, I see one more fact
witness is left. Mr. Clark is still here.
THE COURT: Who?
MR. LITTRELL: Jeffrey Clark.
THE COURT: He can stay here.
MR. LITTRELL: Very well.
THE COURT: Go ahead.
MS. AHN: Yes, your Honor. The government would
like to move into evidence Exhibits 1A through 1S. So
all the letters between A and S for Exhibit 1. Exhibit
2A through 2Q. So all the evidence between 2A and the
letters between A and Q. Exhibits 3A through 3S. So all
the exhibits between A and S. Exhibits 4A through 4Y.
So all the exhibits of the letters 4A through Y.
Exhibits 5A through 5Z. So all the letters between A and
Z for Exhibit 5. Exhibits 6A through 6Y. So the letters
between A and Y for exhibit 6.
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Exhibits 30, 31, 32 and 33. Exhibits 34, 35
and 36. Exhibits 83, 38, 39, 40, 41 and 42.
MR. JOHNSON: Can you repeat that last part?
MS. AHN: 34, 35, 36, 83,
THE COURT: Received in evidence.
MS. AHN: Yes, your Honor. We may have some
further, but we will leave that for another time, your
Honor.
THE COURT: Let's get the witness.
MS. AHN: Yes, your Honor. The government would
like to call SBA witness Kathleen Littwin.
(The witness was sworn.)
DIRECT EXAMINATION
BY MS. AHN:
Q
Good morning, Ms. Littwin. Please state and spell
your name for the record, please.
A
Kathleen Littwin, K-A-T-H-L-E-E-N, L-I-T-T-W-I-N.
THE COURT: Keep your voice up if you can,
Ms. Littwin.
MS. AHN: Thank you.
Q
Are you employed?
A
Yes.
Q
Where do you work?
A
The United States Small Business Administration.
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Q
And what is the mission of the SBA?
A
To assist small businesses.
Q
How long have you worked at the SBA?
A
Almost 16 years.
Q
Do your duties involve managing SBA programs?
A
Yes.
Q
Do you manage loan officers as part of that job?
A
Yes.
Q
Is the term Paycheck Protection Program or PPP
familiar to you?
A
Yes.
Q
What is that?
A
It is a program that was established by the CARES
Act, and that program assists businesses with keeping
employees employed during the Covid pandemic.
Q
And could you explain for the jury what the CARES
Act is?
A
It is legislation that was passed during 2020 that
provided assistance where SBA could guarantee loans that
would provide funding for businesses to pay employees.
Q
And who provides the funds for the PPP?
A
Participating lenders.
Q
Is that in the private sector?
A
Yes.
Q
You mentioned a guarantee. Are PPP funds
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guaranteed by the SBA?
A
Yes. They are 100 percent guaranteed.
Q
Are they also forgivable?
A
Yes, they are.
Q
Can you explain what that means for the jury?
A
If the borrower meets certain requirements after a
certain time period, they can apply to have the loan
forgiven so that they do not have to repay that loan.
Q
Based upon your experience at the SBA, are you
aware of the application process for a PPP loan?
A
Yes.
Q
Did the SBA initially receive those applications?
A
No.
Q
Who did the applications go to?
A
The participating lender.
Q
In the private sector?
A
Yes.
Q
Can you generally describe the process of a PPP
application, though, for the jury?
A
Yes. The applicant will go to a participating
lender. They will submit the application. The
participating lender will review that application and
then submit that to the SBA.
Q
Is supporting documentation included with the
application sent to the lender?
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A
Yes.
Q
Does the SBA receive information about the
application?
A
Yes.
Q
What role, if any, does the SBA employ in the
authorization of the loan?
A
They issue a loan number and pay a fee to the
lender.
Q
You mentioned businesses applying. Who is eligible
to apply for a PPP loan on behalf of a business?
A
The owner of the business or an authorized
representative for the business.
Q
You have also referenced providing an application.
Is there a form used to provide that information for the
application?
A
Yes.
Q
Who issued that form?
A
SBA.
Q
Are you generally familiar with that form?
A
Yes.
MS. AHN: Your Honor, request permission to
publish Government Exhibit 2E which was previously
admitted pursuant to 90211 certification.
THE COURT: All right.
Q BY MS. AHN: Do you recognize this form? Without
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speaking to the content, just the form generally.
A
Yes.
Q
What is it?
A
The PPP application.
Q
Does this form describe how much a business is
eligible to receive?
A
Yes.
Q
Can you direct the jury to that section, and, after
you direct it, I would ask that it be magnified.
A
There is a box that states average monthly payroll,
and see if I can -- that box indicates a blank where they
fill in the average monthly payroll for the business.
Q
Is there a calculation next to it?
A
Yes.
MS. AHN: I would just ask that the whole section
be magnified.
Q
What is that calculation?
A
It indicates times 2.5 plus EIDL which stands for
Economic Injury Disaster Loan, call net of advance, if
applicable equals loan request.
Q
I will ask you about EIDL in a sec. I just want to
focus on the PPP Section here. So if the average monthly
payroll reported on the form is higher, is a business
eligible to receive more PPP money?
A
Yes.
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Q
Does this PPP form also ask for the number of
employees?
A
Yes.
Q
Does an applicant have to have employees to receive
PPP money?
A
Yes.
Q
Why does a business have to have employees?
A
The purpose is to pay payroll.
Q
Does the form also ask for identification numbers?
A
Yes.
MS. AHN: Let's clear the screen if we.
Q
Can. Where does it ask for identification numbers?
A
In the section applicant ownership, there is a box
that indicates some abbreviations of TIN, EIN and SSN.
MS. AHN: Could we magnify that section, please.
Q
And what is a TIN, EIN or SSN?
A
It is a tax identification number, an employer
identification number or a Social Security number.
Q
Is that a unique number?
A
Yes.
Q
Does the form also ask for information on who owns
the business applying for the loan?
A
Yes.
Q
Is that displayed on your screen there?
A
Yes.
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Q
And who is displayed as the owner for this
particular business?
A
Mark Zindroski.
Q
Based upon your experience for the SBA, does the
SBA ask for certifications?
A
Yes.
Q
What are certifications?
A
It is asking the applicant to certify as to the
truthfulness of the information provided on the
application.
Q
Why is that important?
A
We must rely on the information that the applicant
is providing to us to be able to issue the loan.
Q
Were these loans issued over a short timeframe or a
reduced timeframe?
A
Yes.
Q
And what was that?
A
We were trying to get assistance into these
business owners' hands as quickly as possible. We want
them to keep their business owners employed or to keep
them from closing their doors. Assistance is very
important to ensure that these businesses do not go out
of business.
Q
Were certifications requested for the PPP form?
A
Yes.
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Q
And were they required in order to submit the form?
A
Yes.
MS. AHN: So I would like to go to the next page.
Next page after that. Okay.
Q
Do you see what is on your screen, Ms. Littwin?
A
Yes.
Q
Are these the certifications?
A
Yes.
Q
Is there a signature that is required as part of
this application?
A
Yes.
Q
And who is allowed to sign?
A
The owner of the business or the authorized
representative.
Q
And, here, whose signature is indicated?
A
Mark Zindroski.
Q
You mentioned earlier that there is a certification
required for truthfulness and accuracy. Can you point it
out for the jury.
A
The second to last paragraph, it states -- do you
want me to --
Q
You can just mark it for the jury?
MR. SILVERMAN: Your Honor, we would ask for a
limiting instruction on statements of law.
THE COURT: What did you say?
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MR. SILVERMAN: We would ask for a limiting
instruction that the court will instruct on what the law
is at the conclusion of the trial, and this is just being
offered into evidence and received into evidence for the
purpose of showing knowledge.
THE COURT: You may be seated.
Proceed.
Q BY MS. AHN: Could you also -- was there also
limitations on the use of PPP funds for businesses who
received them?
A
Yes.
MR. SILVERMAN: Objection, your Honor.
THE COURT: Overruled.
Q BY MS. AHN: Was that included in the certification?
A
Yes.
Q
Can you point to where that is for the jury?
A
The third bullet.
Q
Was there also a certification relating to
supporting documentation?
A
Yes.
Q
Can you point to where that is for the jury?
A
The fourth bullet.
Q
Thank you. Directing your attention to the first
certification, is a date indicated there?
A
Yes.
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Q
What was that date?
A
February 15th of 2020.
Q
Why is that date significant if at all?
A
It is the date that the business needed to be in
operation to be eligible for assistance.
Q
So if a business did not begin operations until
March of 2020, could it receive PPP funds?
A
No.
Q
If a business did not exist until March of 2020,
could it receive PPP funds?
A
No.
Q
Ms. Littwin, just as a general matter, does a
business need to exist at all to have PPP funds?
A
Yes.
Q
Was there a limited amount of money available for
PPP loans?
A
Yes.
Q
Were there -- were there more than one round of PPP
loans provided?
A
Yes.
Q
Did money in fact run out for PPP during one of the
rounds?
A
The timeframe for PPP first round did end. Yes.
Q
And what happens once the money is gone?
A
No more assistance is provided.
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Q
Even for legitimate businesses?
A
Yes.
MS. AHN: Go ahead and clear the screen now.
MR. JOHNSON: Your Honor, this is Peter Johnson.
I just wanted to make sure that the jurors, if
you could check to make sure that the jurors could see
the witness.
THE COURT: We went into that yesterday. I will
take that up later.
MR. JOHNSON: I understand, your Honor.
THE COURT: And I am understanding that the
witnesses are on the screen; is that correct? They are
all on the screen.
MR. JOHNSON: I apologize, your Honor. I didn't
know that.
THE COURT: All the jurors can see the witnesses.
Let's proceed.
MS. AHN: Yes, your Honor.
Q
You mentioned EIDL or the Economic Injury Disaster
Loan Program earlier. Are you familiar with that
program?
A
Yes.
Q
Is that through your work at the SBA?
A
Yes.
Q
And you mentioned that you managed SBA programs.
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Does that include EIDL?
A
Yes.
Q
Can you generally describe what the EIDL program
does?
A
It provides working capital. It is assistance to
the business for economic injury to pay for items that
the business cannot pay for because of the disaster.
Q
Were EIDL funds distributed in response to
Covid-19?
A
Yes.
Q
Can you describe how that happened to the jury?
A
A disaster was declared because of Covid. That
opened up funding for the SBA disaster loan program.
That program allows for funding directly from SBA. With
the CARES Act, it broadened that program.
Q
Thank you. Were certain industries eligible for
Covid-19 EIDL funds?
A
Yes. The disaster programs opened to corporations,
LLC's, sole proprietorships, independent contractors, and
it was also broadened to including agriculture
enterprises.
Q
Were small businesses eligible?
A
Yes. Only small businesses.
Q
Who provides the funds for EIDL loans?
A
The federal government.
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Q
Is that through the SBA?
A
Yes.
Q
Is there a particular office with the SBA
responsible for transmitting the funds?
A
Yes.
Q
Where is that office located?
A
It is the Denver Finance Center in Colorado.
Q
It is physically in Colorado?
A
Yes.
Q
Are you familiar with the EIDL application process?
A
Yes.
Q
Can you generally describe that process?
A
The applicant will go to the SBA web page. They
will click on the link to apply for an Economic Injury
Disaster Loan. They will submit the information that is
requested. SBA will then review that information, make a
determination on approval. Once it is approved, a loan
number will be issued. They will sign the closing
documents, and the funds will be disbursed.
Q
Is supporting documentation required for an EIDL
loan?
A
During the initial phase, no.
Q
Why not?
A
We have to rely on the information they are
providing to us to provide timely assistance.
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Q
What makes it timely?
A
We are trying to get funds in the hands of these
businesses as quickly as possible so that they don't fail
so that they can meet their obligations. If they are
closed, they don't have any revenue coming in, and they
need these funds to continue their operations.
Q
Can businesses provide supporting documentation?
A
Yes.
Q
You mentioned earlier that there was limited
funding for PPP. Is that also true for EIDL?
A
Yes.
Q
In addition to a loan, does the EIDL program offer
other funds for businesses?
A
Yes.
Q
Can you describe that for the jury.
A
There is also a program called the EIDL advance.
It is a grant program. It is on the same application as
the Economic Injury Disaster Loan. And you can apply for
that additional assistance, that additional grant on that
application.
Q
What is that -- what is that funding predicated on,
if anything?
A
At the time, it was based on the number of
employees.
Q
Who is eligible to apply for EIDL funds on behalf
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of a business whether it is a loan or or an advance, who
is eligible to apply for those funds on behalf of the
business?
A
The owner of the business or an authorized
representative.
Q
Is there an application form associated with that
process?
A
Yes.
Q
Does it have a name?
A
The Disaster Business Loan Application.
Q
Are you familiar with the form generally?
A
Yes.
MS. AHN: Your Honor, request permission to
publish Government Exhibit 2L, I believe the fourth page.
THE COURT: You may.
MS. AHN: Can you go to the next page.
Q
I recognize the font is a little small so we will
magnify when needed.
Do you generally recognize what is shown on
the page?
A
Yes.
Q
What is it?
A
This is the application data.
Q
When you say application data, is this the actual
application form?
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A
It is the data that they enter into the application
form.
Q
Is this information received by the SBA from the
applicant?
A
Yes.
Q
And how is this information submitted?
A
Through the SBA web page online.
Q
Does this form ask for information on business
expenses?
A
Yes.
Q
What kind?
A
The business revenues.
Q
Can you generally show the jury where that is, and
we will magnify it for you.
A
I believe it is line 34. Sorry. I gave you the
wrong number.
MS. AHN: Do you mind just highlighting the
questions and magnifying them.
Q
Do you mind pointing out to where that might be on
the form?
A
Question 14.
Q
What kind of expense does it ask for?
A
The gross revenues for the 12 months preceding the
date of the disaster, January 31, 2020.
Q
Does the reported information impact the amount of
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funds a business is eligible to receive under EIDL?
A
Yes.
Q
How does it impact it?
A
We use that information to calculate the eligible
loan amount.
Q
Could providing false information about these
expenses influence the SBA's to approve a loan?
A
Yes.
Q
Would inflating these numbers inflate the amount of
money a business is eligible for?
A
Yes.
Q
Are EIDL funds only authorized for certain uses?
A
Yes.
Q
What are those uses?
A
It is for working capital to meet business
obligations that the business cannot meet because of the
disaster.
Q
Does the form generally tell us whether an
applicant asked for an advance?
A
Yes.
MS. AHN: Let's go ahead and clear the screen.
Q
Is that showing on your screen?
A
Yes.
Q
Can you show us on the screen where that is?
A
Question 68.
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Q
All right. Can you go ahead and mark it on your
screen.
Did this particular applicant ask for an
advance?
A
Yes.
Q
How can you tell?
A
This is a check box, and the applicant checked that
box. It shows a value of 1 which means they checked the
box.
Q
Next to the type check box, it says required no.
What does that mean?
A
That means it is not a required field. They do not
have to answer that field.
Q
Does this form also ask for the number of
employees?
A
Yes.
Q
How does that impact a business' eligibility for an
advance?
A
At the time of this application, the number of
employees related to the amount of the grant you would
receive. If you stated one employee, you would receive
$1,000, up to 10 employees you would receive $10,000.
Q
You mentioned certifications before. Does the EIDL
form include certifications?
A
Yes.
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Q
What does that certification require?
A
That the information provided is truthful and it
states that SBA is relying on that information to offer
the loan.
MS. AHN: Could we go to question 72. Great.
Q
And I see that you have highlighted on the screen.
Is that the certification that is required?
A
That is a portion of it, yes.
Q
Did this person make the certification?
A
Yes.
Q
Can you direct us to how you know that is true?
A
This is a check box, and the value shows 1 which
means that they checked the box.
MS. AHN: I am going to ask that we exit out of
the magnification and highlight the text below the end of
the question.
Q
You mentioned that it shows part of the
certification. Does this include additional
certifications?
A
Yes.
Q
If the SBA learned that false information was
provided with the loan application, would that affect the
lending decision?
A
Yes.
Q
After an EIDL application is approved initially,
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what happens next?
A
After it is approved, SBA will send an e-mail
advising them to log in and sign the loan closing
documents. They will log into their portal account and
sign the loan closing documents, and, then, once that has
been completed, we will disburse those funds, the loan
funds.
MS. AHN: I am going to go ahead and clear the
screen. Could we go to Government Exhibit 24, page 10.
Q
Do you recognize this?
A
Yes.
Q
What is it?
A
It is the loan authorization and agreement. It is
the terms and conditions of the loan.
Q
Is this required to close the loan or to disburse
the funds?
A
Yes.
Q
Does this form describe permissible uses of the
funds?
A
Yes.
MS. AHN: Can we go to the next page.
Q
Can you point out generally where that is?
A
The second paragraph.
Q
What is the permissible use of the funds described
there?
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A
Working capital to alleviate economic injury caused
by the disaster occurring in the month of January 31,
2020, and continuing thereafter. And, then, there is
also a $100 fee for the recording of the UCC.
Q
What does UCC stand for?
A
Uniform Commercial Code. It is a document that we
file to have collateral, to secure collateral for the
loan.
Q
Would the use of the funds for purely personal
expenses qualify?
A
No.
Q
Does this form also contain certifications?
A
Yes.
Q
Did you see that on your screen?
A
Yes.
MS. AHN: Highlight that section. Is that -- go
ahead and clear the highlighting.
Q
Is that section magnified on your screen?
A
Yes.
Q
Does this contain additional certifications
regarding the truth and accuracy of the form?
A
Yes.
Q
Does this form also require a signature?
A
Yes.
Q
From who?
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A
The owner of the business or an authorized
representative.
MS. AHN: Let me exit out of the application.
Next page.
Q
Is this form signed?
A
Yes.
Q
Who is it signed by?
A
Lulu Ozodco(Phon.), owner, slash, officer of
Timeline Transport, Inc..
Q
If an applicant did not intend to use the funds for
business expenses, would that influence the SBA's
decision to approve the loan?
A
Yes.
Q
If the business had no operations, would it be
eligible for EIDL funds?
A
No.
Q
If it had no employees, would it be eligible for
EIDL funds, employees -- if the business had identified
employees but, in fact, had no employees, would it be
eligible for EIDL funds?
MR. JOHNSON: I'm sorry, your Honor. I don't
understand the --
THE COURT: Just make an objection. Legal
grounds.
MR. JOHNSON: Objection, your Honor, as to clarify
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the question.
MS. AHN: I am happy to rephrase, your Honor.
Q
If the business falsely reported employees, would
that impact the BSBA's decision on approving a loan?
A
Yes.
Q
If the identified owner was not a real person,
would that impact the SBA's decision to approve the loan?
A
Yes.
MS. AHN: No further questions at this time, your
Honor.
THE COURT: Cross-examination.
MR. SILVERMAN: I would ask -- a few people have
gone in and out of the courtroom, I would ask you just
reiterate that no witnesses are in the courtroom.
THE COURT: If there are any witnesses in the
courtroom, they should proceed to the witness room.
MR. SILVERMAN: Thank you, your Honor.
CROSS-EXAMINATION
BY MR. SILVERMAN:
Q
Good morning, Ms. Littwin.
A
Good morning.
Q
You are a lawyer for the SBA; correct?
A
Yes.
Q
And you have been a lawyer there for 16 years I
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believe you testified?
A
Almost. Yes.
Q
Was the CARES Act unique in your experience?
A
Yes.
Q
We were facing a quarantine; correct?
A
Yes.
Q
And it had crashed consumer spending?
A
Yes.
Q
And that is why business were at risk; correct?
A
Yes.
Q
And the CARES Act was passed to stabilize the
economy; right?
A
Yes.
Q
And ultimately that authority was delegated to the
SBA in part?
A
A portion of it, yes.
Q
And the SBA and the CARES Act succeeded in
stabilizing that economy; right?
MS. AHN: Objection. Foundation.
THE COURT: Sustained.
Q BY MR. SILVERMAN: You mentioned that the CARES Act
had PPP loans; correct? Or led to PPP loans. Excuse me?
A
Yes.
Q
Those PPP loans you discussed that they went to
small businesses?
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A
Yes.
Q
Some of them also went to large businesses;
correct?
A
I don't have any knowledge of that.
Q
Do you know whether EIDL loans went to large
businesses?
A
I don't have any knowledge of that.
Q
The SBA was under pressure to move fast around
March, 2020; correct?
A
Yes.
Q
After the CARES Act was passed, do you know how
long did it take for PPP loan applications to become
available?
A
No, I do not.
Q
Was it less than a month?
A
I do not know.
Q
Do you recall whether the SBA issued interpretive
rules?
A
Yes.
Q
And is it fair to say that loan applications became
quickly available?
MS. AHN: Objection. Asked and answered.
THE COURT: Overruled.
Q BY MR. SILVERMAN: Would you like me to repeat the
question?
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A
Yes, please.
Q
Is it fair to say that the loan applications become
quickly available?
A
I don't know.
Q
Now, how often did the SBA issue interpretive
regulations regarding the loan applications specifically?
MS. AHN: Objection. Relevance.
THE COURT: I don't know at this point. The
objection is overruled at this point.
THE WITNESS: I don't know.
Q BY MR. SILVERMAN: The SBA issued interpretive
regulations in part to guide applicants; correct?
A
Yes.
Q
And is it fair to say that the SBA issued
interpretive rules more than five times in April of 2020?
MS. AHN: Objection. Asked and answered.
THE COURT: Overruled.
THE WITNESS: I do not know.
Q BY MR. SILVERMAN: Did you ever know that?
A
No.
Q
And the SBA also issued frequently asked questions;
correct?
A
Yes.
Q
The SBA also issued frequently asked questions for
loan applicants; correct.
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A
Yes.
Q
And those frequently asked questions were updated
over time?
A
Yes.
Q
The responses changed?
A
That I do not know.
Q
So an application that was submitted in April might
not be submitted under the same guidance or frequently
asked questions as an application that was submitted in
June; is that right?
A
I do not know.
Q
And it would be up to the applicant to know the
differences if they existed?
A
I do not know.
Q
Now, we talked about how the SBA was under a lot of
time pressure?
A
Yes.
Q
And I believe you talked about the SBA was trying
to approve applications quickly. Is that roughly
accurate?
A
Yes.
Q
Loans that the SBA received were often approved in
as little as one day; is that right?
A
Are we talking about economic injury loans?
Q
PPP loans were often approved in as little as one
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day; correct?
A
SBA does not approve PPP loans.
Q
Excuse me. PPP loans were often funded in as
little as one day; is that right?
A
SBA does not fund PPP loans. They are funded by
the participating lender.
Q
EIDL loans were often approved in as little as one
day; is that correct?
A
Yes.
Q
And for PPP loans, as you mentioned, they are
approved by the participating lender?
A
Yes.
Q
And it is up to the participating lender to review
the applications?
A
Yes.
Q
And so it would be the participating lender that is
relying upon information in this application to the
extent it is relying upon that information?
A
Yes.
Q
And if the PPP lender fails to do due diligence,
what happens to the SBA's liability?
A
At the original stage, the SBA is only receiving
the information from the participating lender. At a
later date when the participating lender asks for SBA to
guarantee or pay out on the guarantee or to do the
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forgiveness, there is a review of the loan information at
that time.
Q
And if the participating lender had failed to
complete the due diligence, would the SBA honor the
guarantee?
A
I don't know.
Q
Is it possible that the SBA would refuse to pay out
money based on the lack of due diligence by a lender?
A
It is possible.
Q
Now, I would like to ask a few questions about how
money is transferred in relation to EIDL loans. Is that
your focus, EIDL loans?
A
Yes.
Q
Do I understand correctly from your testimony that
EIDL loans are disbursed directly from the SBA to
lenders -- or to banks. Excuse me?
A
It is disbursed directly by SBA through the
treasury to the borrower.
Q
You said to the borrower. The government actually
wires the money from a treasury to a bank; correct?
A
No. To the borrower's bank account.
Q
So the other end of the wire transaction is a bank
in some location; correct?
A
Yes.
Q
And once the bank receives the money, it notes a
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credit on the borrower's account; correct?
A
Yes.
Q
Now, once the funds are credited to a borrower's
account, does the SBA monitor how the borrower spends
them?
A
No.
Q
It would be difficult to monitor how a borrower
spent the funds; right?
A
We don't have access to that information.
Q
And some borrowers already have money in their
accounts; correct?
MS. AHN: Objection. Calls for speculation and
foundation.
MR. SILVERMAN: I will rephrase, your Honor.
THE COURT: Sustained. You can ask the question a
different way.
Q BY MR. SILVERMAN: Does the SBA require that
borrowers have zero money in their accounts in order to
submit an application?
A
No.
Q
Now, if a borrower had money in their accounts, the
SBA would not be able to monitor whether they are
spending that money or the loan money; is that right?
MS. AHN: Objection. Relevance and lack of
foundation.
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THE COURT: Well, I mean, the witness can answer
the question.
THE WITNESS: We can't monitor anything in their
bank account.
Q BY MR. SILVERMAN: Now, Ms. Littwin, I want to ask
to clarify a little bit the difference between EIDL and
PPP loans. Is one difference that EIDL loans have to be
paid back?
A
Yes.
Q
And, in fact, the government takes a security
interest in the business' property; is that right?
A
Yes.
Q
Can you explain to the jury what a security
interest is?
A
We take collateral so that if the loan is not
repaid SBA could take -- in this situation, it is a
security interest in business contents. SBA could take
action to recover those business contents.
Q
So, essentially, if the business doesn't repay the
loan, SBA can file a civil lawsuit; right?
A
Yes.
Q
And they could even foreclose upon business
property; right?
A
We did not take any real property so we could not
foreclose.
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Q
It could seize personal property?
A
Yes.
Q
Now, as for PPP loans, those loans are forgivable;
correct?
A
If they meet requirements, yes.
Q
And you discuss how there were multiple rounds of
SBA, excuse me, of PPP loans in 2020; is that right?
A
In 2020, there, I believe, was only one round.
Q
And that one round, did that end around August 8th,
2020?
A
I would have to check the date.
MR. SILVERMAN: I would ask that we display just
for the witness -- oh, I need to switch -- defense
Exhibit 16, please.
Is it showing up for everybody, counsel?
MS. AHN: Well, the screens at counsel table can
be seen by the jury.
MR. SILVERMAN: Is there a way to display just for
the witness?
THE COURT: What is the issue?
THE COURT: Is the issue when the first round of
PPP loans expired?
MR. SILVERMAN: Correct, your Honor.
THE COURT: That is the issue. Is there any
dispute about that?
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MS. AHN: No, your Honor. There is no dispute.
THE COURT: Then, what is the date? Tell us.
MR. SILVERMAN: August 8, 2020.
THE COURT: All right. Then that stands.
Next question.
MR. SILVERMAN: Yes, your Honor.
Q
And at the conclusion of that first round, the SBA
or the program had given out millions of loans; correct?
A
I do not know the number.
Q
And the program still had money left to lend,
didn't it?
A
I do not know.
Q
Do you know whether the SBA issued weekly or
monthly reports on the program?
A
Yes, we did.
Q
And did those reports include the amount of money
that was left to lend?
A
I would assume.
MR. SILVERMAN: At this point, I would offer into
evidence Defense Exhibit 16.
MS. AHN: No objection, your Honor.
THE COURT: All right. Received.
MR. SILVERMAN: If we could post Defendant's
Exhibit 16 for the jury, please, or for the entire
courtroom, and, actually, if we can stay on this page for
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one second.
Q
Does this appear to be one of the weekly or monthly
reports?
A
It appears to be.
Q
And is it put out by the Small Business
Administration?
A
Yes.
Q
And it says approvals through August 8th of 2020;
correct?
A
Yes.
Q
So that is through the end of the 2020 program?
A
It appears to be.
MR. SILVERMAN: And if we could go to page 9,
please.
Q
So fair to say that at the conclusion of the 2020
program, there was almost a $134 billion left over?
A
That appears to be.
Q
Thank you, Ms. Littwin.
MR. SILVERMAN: No further questions, your Honor?
THE COURT: Any further cross-examination.
MR. MESEREAU: Yes.
THE COURT: Go ahead, Mr. Mesereau.
///
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CROSS-EXAMINATION
BY MR. MESEREAU:
Q
Good morning, Ms. Littwin?
A
Good morning.
Q
My name is Tom Mesereau, and I speak for Mr. Artur
Ayvazian. Just like to ask you a few questions about the
purpose of the program.
A
Okay.
Q
The prosecutor showed you a document when you began
testifying, Exhibit 2E, which dealt with questions about
the purpose of the loan requested; correct?
A
Was that for the Paycheck Protection Program?
Q
Yes.
A
Okay.
Q
And correct me if I am wrong. I think you said the
purpose was to meet payroll; is that correct?
A
One of the purposes, yes.
Q
There were far more purposes than just meeting
payroll; correct?
A
There were additional, yes.
Q
And some of those purposes were paying rent;
correct?
A
Yes.
Q
Paying a mortgage interest?
A
Yes.
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Q
Paying utilities?
A
Yes.
Q
And then there was a section where if you had
another purpose, you could say other, you could fill out
what the other purpose would be; correct?
A
Yes.
Q
And what are some of the other purposes that you
recall the loans were made for?
A
I believe you could pay off an Economic Injury
Disaster Loan or refinance an Economic Injury Disaster
Loan.
Q
Just to clarify proper uses because the prosecutor
asked you questions about proper uses of these funds.
Let's say someone is having business problems, owes
mortgage interest, haven't paid the utility bills,
something like that. The pandemic hits. The program is
put into effect, the CARES program.
Theoretically, can a small business owner use
these loans to pay those utility bills or those mortgage
bills or other related expenses?
A
Business expenses?
Q
Yes.
A
Yes.
MR. MESEREAU: No further questions, your Honor.
Thank you.
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THE COURT: Anything further?
MR. LITTRELL: Nothing from us, your Honor.
MR. JOHNSON: Your Honor, Peter Johnson.
THE COURT: Go ahead.
CROSS-EXAMINATION
BY MR. JOHNSON:
Q
Good morning.
A
Good morning.
Q
I am here to talk to you about legitimate loans.
The SBA was acting through banks; isn't that correct?
A
For the PPP loans.
Q
Yes. And the banks, for legitimate businesses,
provided funding?
A
Yes.
Q
These fundings were for business owners, small
business owners to get their business back on track;
correct?
A
For PPP?
Q
Yes.
A
It was to keep employees employed.
Q
To keep employees employed. But the application,
you said during direct examination that you are familiar
with the application; isn't that correct, the PPP loan
application?
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A
Yes.
Q
And that application, in the application, the
guidance is that it was supposed to be able to be filled
out in eight minutes?
A
Okay.
Q
Are you familiar with that?
A
Not off the top of my head, no.
MR. JOHNSON: Can we pull up Exhibit 2K.
Q
Have you looked up the loan applications that the
government provided?
A
The one that we looked at earlier?
Q
Not the one that we looked at earlier but other
applications?
A
No.
Q
Now, is there a reason why you didn't look at the
other applications?
A
No.
MR. JOHNSON: So this case, I would ask the
witness to -- does the witness have exhibits in front of
her?
MS. AHN: There is no physical exhibits.
MR. JOHNSON: I think we lost power.
Q
There is a definition in the exhibit in the PPP
application for payroll; isn't that correct?
A
I do not know without looking at it.
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MR. JOHNSON: Just a minute.
Is the government able to pull up Exhibit 2K.
MS. AHN: We are happy to.
Do you mind if I approach to switch over the
lecturn.
MR. JOHNSON: Please.
Q BY MR. JOHNSON: This is a PPP loan application;
correct?
A
Yes.
Q
And this is the PPP loan application in the name of
Voyage Limo?
A
Yes.
Q
You have no information to believe that Voyage Limo
is a fake company; correct?
A
I have no information on the business.
Q
And the loan is applied for by a Vahe Dadyan. Do
you see that?
A
Yes.
Q
Now, this loan application had some instructions;
correct?
A
Yes.
Q
And part of those instructions were for small
business owners; correct?
A
Yes.
Q
And sometimes the small business owners needed
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authorized representatives to fill out the forms; isn't
that correct?
A
Yes.
Q
Because there were documents that had to be
attached; correct?
A
Attached to the application?
Q
To the application.
A
I don't know how they attached the documents.
These weren't submitted to the SBA.
Q
But SBA required certain documents to be attached
to the application; isn't that right?
A
SBA required the PPP lender to obtain them.
Q
SBA required the PPP lender to obtain documents to
support the loan; Isn't that correct?
A
Yes.
Q
So sometimes these applications require authorized
representatives, people, not the owner of the business to
attach documents; isn't that correct?
A
I don't know. They might have.
Q
So isn't it correct that the form actually -- that
part of the instructions --
THE COURT: Let's clarify that. The question was
does the form require the actual lender or an authorized
representative to sign the application? It can be either
one?
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THE WITNESS: It can be signed by the applicant or
an authorized representative.
THE COURT: I see. All right.
MR. JOHNSON: What I would like to do is zoom in
on purpose of this form, that paragraph.
Q
And just to be clear, this form is for small
business owners; correct?
Q
They are supposed to fill this out.
Q
And isn't it true that the form says this form is
to be completed by the authorized representative?
A
Yes. A corporation has an authorized
representative meaning a president or secretary. An LLC
has a manager.
Q
And is that in the form?
A
I would have to look at it in more depth.
Q
So you have been with the SBA how long?
A
Almost 16 years.
Q
And you are familiar with this PPP loan program;
correct?
A
The PPP program is new. It is from 2020.
Q
So, since 2020, you have been familiar with it;
correct?
A
Yes.
Q
You have been focusing on this in your practice.
You are an attorney; correct?
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A
I focus on the economic injury.
Q
But you are not familiar with this form of the PPP
loan?
A
I am familiar with it, yes.
Q
But the statements that this authorized -- that you
just said about corporate representatives, that is not in
the form; isn't that correct?
MS. AHN: Your Honor, this question has been asked
and answered a number of times.
THE COURT: She can answer it one more time.
Q BY MR. JOHNSON: The statements that you just
provided, this additional information that you just
provided, that is not in the form; right?
A
I would have to look at it. I don't know.
Q
Why don't you take some time to look at it if we
can. So you don't have that -- well, you don't know
right now?
A
It is blown up. If we can remove the blown up
portion.
Q
Why don't we say this, that it is fair to say that
at this point in time you don't know whether that is in
this form?
A
Correct.
Q
What I would like to do is, next, you said that the
payroll, isn't payroll consist of a variety of things?
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Doesn't payroll consist of a variety of things?
MS. AHN: Objection. Vague.
MR. JOHNSON: Let's go to the document. Let's
pull up the definition of payroll. The next paragraph,
please.
Q
This is what they laid out as the definition of
payroll on the form; correct?
A
Yes.
Q
Down on the bottom, that last line says --
MR. JOHNSON: Can you highlight that last line,
please.
MS. AHN: May I approach?
Q BY MR. JOHNSON: Why don't you read that last line.
A
Independent contractor or sole proprietor wage,
commissions, income or net earnings from self employment
or similar compensation.
Q
And small business owners at the time were expected
to interpret this to fill out the form; isn't that
correct?
A
Yes.
Q
And they were also expected to fill out, to make
calculations on the form; correct.
A
Yes.
Q
Or their authorized representative was going to
make those calculations; right?
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A
Yes.
MR. JOHNSON: Can we zone in on the next
paragraph, please.
Q
And part of that for the purposes of calculating,
they had to try to figure out how to calculate monthly
payroll; right?
A
Yes.
Q
And that required somewhat of a complex
calculation; correct?
A
I don't know if it would be complex, but it
required a calculation, certainly.
Q
It required a calculation. But you are aware that
many small business owners were struggling trying to
figure out how to apply for these loans; isn't that
correct?
MS. AHN: Objection. Speculation. Foundation.
THE COURT: Sustained.
Q BY MR. JOHNSON: Are you aware of the small --
whether small businesses were struggling to try to figure
out how to apply for these loans?
A
No.
Q
When -- there is also a definition of how long it
takes to read this form; correct?
A
Yes.
Q
So this 4-page form, it says that the individuals
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had -- it was expected that they could read this in eight
minutes?
A
Yes.
Q
And that is for English speakers; correct?
A
Yes.
Q
Final question, is it possible for the loan
application to be submitted by mobile phone?
THE COURT: By what?
Q BY MR. JOHNSON: By a mobile phone?
A
For PPP, I do not know. It would depend on the
participating lender.
Q
Understood.
MR. JOHNSON: No further questions, your Honor.
THE COURT: Any other counsel have questions?
Thank you, ma'am, for being here.
Next witness.
THE WITNESS: Thank you.
MR. FENTON: The government calls Mark Zindroski.
MR. JOHNSON: Your Honor, Peter Johnson. I
requested a limiting instruction for this witness.
THE COURT: Next witness.
THE CLERK: The witness will please step forward.
(The witness was sworn.)
THE CLERK: Please state your name and spell it
for the record.
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THE WITNESS: Mark Anthony Zindroski,
Z-I-N-D-R-O-S-K-I.
DIRECT EXAMINATION
BY MR. FENTON:
Q
Good morning, Mr. Zindroski.
A
Morning.
Q
Can you tell where do you currently live?
A
Pardon?
Q
Where do you currently live?
A
I live at 16417 Tulsa Street, Granada Hills, 91344.
Q
All right. And what, if anything, do you do for
employment?
A
Pardon?
Q
What, if anything, do you do for employment?
A
I am a general contractor, semi retired.
Q
And do you own your own company?
A
Yes.
Q
And what is your company name?
A
Top Quality Contracting Services.
Q
And when did you start your company?
A
About 35 years ago.
Q
Are you the sole owner of that company?
A
Always have been. Yes.
Q
And do you have any employees?
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A
No, sir.
Q
So is it fair to say that you are the only person
working for Top Quality contracting?
A
I didn't understand that.
Q
So is it fair to say that you are the only person
working for Top Quality contracting?
A
Yes.
Q
Are you familiar with the Paycheck Protection
Program or PPP program?
A
I have heard about it, yes.
Q
Have you ever applied for a PPP loan?
A
Never.
Q
I am showing you what has been previously admitted
as Government Exhibit 2E.
A
Okay.
Q
Directing your attention to the top of the page, do
you see your name there at the top?
A
Yes.
Q
And is that the name of your company to the right?
A
It is missing the services, but, yes, Top Quality
contracting, yes. That is me.
Q
Did you submit this PPP loan application?
A
No, sir.
Q
Did you authorize anyone to submit this PPP loan
application --
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A
No, sir.
Q
-- on behalf of your company?
A
No.
Q
To your knowledge, did you ever receive any PPP
loan money?
A
Never.
MR. FENTON: If we can just go back to the top of
that page again.
Q
If you look to the right it says business TIN/EIN.
Is that your EIN number?
A
I have never had one.
Q
Top Quality contracting has never had an EIN
number?
A
I have my license number 696119.
Q
But not an Employer Identification Number?
A
Yeah. Never.
Q
How about that telephone number, the business phone
number to the right, is that your telephone number?
A
Let's see. No.
Q
And what about that e-mail address?
A
Pardon?
Q
And what about the e-mail address?
A
No. Not at all.
MR. FENTON: All right. Let's turn to page 3.
Let's go to the bottom of the page.
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Q
So directing your attention, sir, to the bottom of
the page there, is this your signature?
A
No, sir.
Q
And let's turn to page 47.
Sir, is this your driver's license?
A
No.
Q
Okay.
Q
Is that your address?
A
It is off to the -- turn it around.
Q
16417 Tulsa Street?
A
That is me. Yeah.
Q
That is you, but that is not you; correct?
A
Yeah. It is not me, but that address is mine. And
my birth date is mine.
Q
But that is not your driver's license?
A
That is not my driver's license or my driver's
license number I see.
Q
Does Top Quality contracting have a bank account?
A
Yes.
Q
Where do you bank?
A
Bank of America.
Q
Do you bank anywhere else?
A
No, sir.
Q
All right.
MR. FENTON: Your Honor, permission to publish
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Government Exhibit 1F to the jury.
THE COURT: Okay.
MR. FENTON: And can we blow up the top of this
document.
Q
All right. Do you see the name of your business
there Top Quality contracting?
A
Yes.
Q
Did you ever open an account in the name of Top
Quality contracting at Wells Fargo?
A
No.
Q
Did you authorize anyone to open up a bank
account --
A
Never.
Q
-- at Wells Fargo using your business' name?
A
No.
Q
Do you see the name there, Ulia Zhadko?
A
Yes.
Q
Do you know anyone named Ulia Zhadko?
A
No, sir.
Q
Has anyone named Ulia Zhadko ever worked for you as
an employee at Top Quality contracting?
A
No. Never.
Q
Let's go to page 2 at the bottom. All right. Just
a couple more questions.
Sir, do you see there at the bottom where it
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says your name?
A
Yes.
Q
Next to it is signature?
A
No.
Q
Well, to the right. Do you see the signature to
the right?
A
No. And that is my father's address.
THE COURT: What was the question? Does he see
the signature, or is it his signature? What was the
question?
MR. FENTON: Yes, your Honor.
Q
The first question is can you see the signature,
Mr. Zindroski?
A
Yes.
Q
Is that your signature?
A
No.
Q
And how about that address. Is that your address?
A
That was my father's address. And mine when I was
a kid.
Q
All right, sir. Thank you, sir.
MR. FENTON: No further questions?
THE COURT: Cross-examination?
MR. LITTRELL: Your Honor, can we take a 5-minute
break before cross-examination. I don't intend to
cross-examine the witness, but we need --
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THE COURT: You need a 5-minute break.
MR. LITTRELL: Yes, your Honor.
THE COURT: What time is it?
THE CLERK: It is 10:30.
MR. RAM: We can cross in five minutes and be
done.
THE COURT: This will be the morning recess.
We will take the morning recess as I told you
now for 10 minutes to refresh yourselves, and then we
will go on until 12:00 o'clock. Thank you.
(Recess from 10:31 to 10:48 a.m.)
(The following proceedings were held in the
presence of the jury:)
THE COURT: Cross-examination?
CROSS-EXAMINATION
BY MS. NEWCOMER:
Q
Good morning, Mr. Zindroski.
A
Morning.
Q
You learned that a PPP loan had been applied for in
your company's name when the government contacted you; is
that correct?
A
Yes.
Q
You don't know whether Manuk Grigorian submitted
that application; correct?
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A
Pardon.
Q
You don't know whether a man named Manuk Grigoryan
is the one who submitted the application in your
company's name; correct?
A
I don't know who.
Q
You don't know whether any of the defendants
sitting at this table are the ones who submitted the loan
application in your company's name?
THE COURT: Why isn't the government objecting?
MR. FENTON: Objection, your Honor.
THE COURT: Sustained.
MS. NEWCOMER: Thank you, your Honor.
MS. AHN: Your Honor, we request that the question
be struck from the record.
THE COURT: When I sustain an objection, the
question and the answer have no bearing on the case.
MS. AHN: Thank you, your Honor.
THE COURT: Now, if it is unclear, the answer is
struck.
Now, call your next witness. Let's go.
MR. PAETTY: Your Honor, the United States calls
Brianna Fitzgerald.
THE COURT: You should get these witnesses lined
up so we don't have to wait for them to come in. You
know who the order is.
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MS. AHN: Yes, your Honor.
(The witness was sworn.)
MR. PAETTY: Your Honor, at this time the
government would move to admit Government's 51A under
federal rule of evidence 803(8) and 803(10).
THE COURT: Proceed.
THE CLERK: Please state your full name and spell
it for the record.
THE WITNESS: My full name is Breanna,
B-R-E-A-N-N-A. Last name Fitzgerald,
F-I-T-Z-G-E-R-A-L-D.
DIRECT EXAMINATION
BY MR. PAETTY:
Q
Good morning. Ms. Fitzgerald, where do you work?
A
I work for the Department of Motor Vehicles.
Q
And what do you do for the DMV?
A
At the DMV, I am a senior motor vehicle technician
also known as a SMVT.
Q
How long have you been in that job?
A
For this position, I have been in this position for
two months now.
Q
And what do do you in that job?
A
As a SMVT, my duties are to process vehicle
registration, driver's license, ID's, occupational
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license applications with the highest level of expertise
to review fraud, possible fraud, to process complex
transactions such as lien sales or complex transactions.
Also, to provide customer service and to mediate customer
complaints as well as assist our training staff and
assist my management staff or whatever else is needed.
Q
Are you familiar with the types of records that are
kept by the DMV?
A
I am.
Q
Are names kept as part of DMV records?
A
Yes, they are.
Q
Are driver's license numbers kept as part of DMV
records?
A
Yes, they are.
Q
Are dates of birth kept as DMV records?
A
Yes, they are.
Q
Are those records kept in a database?
A
Yes.
Q
Do you have access to that database as part of your
job?
A
Yes, I do.
Q
Is that database searchable?
A
Yes, it is.
Q
Do you know how to run searches on it?
A
Yes, I do.
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Q
Is it part of the regular course of your job duties
to run searches in the DMV database?
A
Yes, it is.
Q
Can you generate reports based on those searches?
A
Yes, we can.
Q
I will show you what has been admitted as
Government's Exhibit 51A. Are there names, a set of
names, driver's license and dates of birth in paragraph 6
here?
A
Yes, they are.
Q
And did you run a search of names and the driver's
license numbers that are listed here and the dates of
birth?
A
Yes, I did.
Q
Did you run a search for Ulia Zhadko?
A
Yes, I did.
Q
One moment, please.
So for Ulia Zhadko, driver's license B66244
with a date of birth January 15th, 1990?
A
Yes, I did.
Q
What process did you use to run that search?
A
Per training, to locate or look up a customer's
vehicle record or ID record if you will, we do use the
DOB database.
So, first, it is two searches. Since I was
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Case 2:20-cr-00579-SVW Document 672 Filed 07/09/21 Page 71 of 143 Page ID
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given a driver's license number and a name and birth
date. So the first search allows you to type in the
first and last name and birth date, and then it comes up
with a record. And the second search will allow you to
put in specifically only the driver's license or ID
number to pull up a record.
Q
What was the result of that search here?
A
For customer Zhadko, when I typed in the name and
birth date, there was no record. When I typed in the
driver's license, number there was also no record.
Q
Is that an invalid license?
A
Correct.
Q
Did you also run a search for Ulia Zhadko with
driver's license number C8924483 and a date of birth
January 15th, 1990?
A
Yes, I did.
Q
Was that also a three-point check?
A
That was also a three-point check.
Q
Where were the results of that search?
A
So, again, with the first and last name and birth
date, there was no hit, no match or no record, and, also,
for the driver's license number, there was no hit, no
match, no record.
Q
So was that an invalid license?
A
Invalid license. Yes.
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Q
Did you also run a search for Victoria Kauichko,
the driver's license number D3257870 and a date of birth
January 9th, 1989?
A
Yes, I did.
Q
Was that also a three-point search?
A
That was also a three-point search, yes.
Q
What were the results of that?
A
So with the name, Victoria Kauichko, hope I am
saying that right, the system is set up to when you put
in the name, if there is a record that is similar, it
does come up. So with this particular name and birth
date, the same spelling for Viktoria came up, but the
last name was different and the birthday was different.
So with the three-point match, it is not the same record.
It is not the person in the other record. And, then, for
the driver's license, there was a record, but it was for
a three-point match not the same name and birth date so
it is not the same record.
Q
So does this record belong to someone else?
A
Belongs to someone else. That's correct.
Q
Did you also run a search for Anton Kudiumov with
driver's license A6001420 and a date of birth March 19th,
1994?
A
Yes, I did.
Q
Was that a three-point check?
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A
That was a three-point check, name and birth date,
no record, no match, no hit. For the driver's license
number, there was a record, but per the three-point
match, it is not -- it doesn't match. It is an invalid
record. Not the same person.
Q
How about for Anton Kudiumov, driver's license
number D6343561 and a date of birth March 19th, 1994?
A
Yes, I ran that as well.
Q
Was that a three-point check?
A
Three-point check. The name and birth date, no
record, no hit or match. The driver's license, there was
a record, but per three-point match after verifying the
record does not belong to Anton Kudiumov.
Q
How about for Anna Dzukaeva, driver's license
number A8002470, date of birth, November 29th, 1995?
A
Yes, I ran that record as well.
Q
And was that a three-point check?
A
Yes. Three-point check. On the first name, last
name, there was no record. And then the driver's license
number that was given, there was also no hit, no match,
no record.
Q
How about for Medel Murat, driver's license number
Y3081786 and a date of birth, April 25th, 1994?
A
Yes, I ran that record as well.
Q
And what was the result of that?
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A
Again, verifying the three-point match with a first
and last name and birth date, there was no record, no hit
or match. However, the driver's license number, there
was a record but per the three-point match and training,
this record does not belong to the person.
Q
Let's continue to Anna Manukyan, driver's license
Y3365633 and date of birth November 2nd, 1984. Did you
run a three-point check for that?
A
I did run a three-point check for that.
Q
And what were the results?
A
The results were the same. So the record did
belong to Anna Manukyan, and the driver's license number
was verified it does belong to that person.
Q
And the last name on the list, Roza Avakyan,
driver's license No. D36423006 and a date of birth
April 23rd, 1924?
A
Yes. I ran that record as well.
Q
And what were the results of that?
A
The results of that, it did come back as a match.
The name, birth date and driver's license belonged to
that person.
Q
Was that expired?
A
Yes. It was expired.
Q
Was it renewed?
A
No, it was not.
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MR. PAETTY: No further questions, your Honor.
THE COURT: Cross-examination.
CROSS-EXAMINATION
BY MR. KEOUGH:
Q
Good morning, Ms. Fitzgerald.
A
Good morning.
Q
You testified that as part of your work at the DMV,
the DMV keeps records of driver's licenses?
A
Correct.
Q
And that you were asked to run certain searches to
determine if the information from the licenses was found
in your database?
A
Right.
Q
One of those licenses that we heard about just now
was Victoria Kauichko, and you recall running that
search?
A
Yes, I do.
Q
And you didn't find any information that they asked
you to search for?
A
No. I did not find a record for that person.
Q
And you determined that that was thus an invalid
license?
A
Yes. That is correct.
Q
And that the record didn't belong to Victoria
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Kauichko, must have belonged to someone else?
A
Correct.
Q
And you can't tell us, though, whether that someone
else was, for instance, a man named Manuk Grigoryan?
A
No, I couldn't tell you that.
Q
And you couldn't tell us whether or not the person
who that record belongs to is a woman named Tamara
Dadyan?
A
No, I cannot.
Q
You also testified you searched for a license with
the name Anton Kudiumov?
A
Correct.
Q
And you recall that that search revealed no
information?
A
For the name and birth date, there is no record for
that person.
Q
And, as a result, you determined it was an invalid
license?
A
Correct.
Q
And you determined that the record belonged to
someone else?
A
Correct.
Q
But you can't tell us whether or not that record
belonged to a man named Manuk Grigoryan?
A
No, I can not.
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Q
And you can't tell us whether or not that record
belonged to a woman named Victoria Kauichko?
A
Well, okay.
Q
Excuse me. A woman named Tamara Dadyan?
A
Okay. I apologize. On the record, it has a
specific name and birth date. So I can say that I don't
recall the name, but it would tell you whose name it is
as far as if a record does come up, it does show a first
name, last name and a birth date. So I would be able to,
if I see the record if it is that person, but I don't
recall those names.
Q
Fair enough. Now, you also testified about running
a search for a driver's license in the name of Anna
Manukyan. Do you recall that?
A
Yes.
Q
And do you recall as part of that search, were you
asked to cross-reference information for Anna Manukyan to
see if there was any relationship with a man named Manuk
Grigoryan?
A
No. I was not asked to that.
Q
You also testified that you ran a search for a
license in the name of Ulia Zhadko?
A
Correct.
Q
And when you ran that search, no information came
back?
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A
Correct.
Q
So you determined that was an invalid license?
A
That is correct.
Q
As part of that search were you asked to
cross-reference any information against information
belonging to a man named Manuk Grigoryan?
A
No, I was not.
Q
And were you asked to cross-reference any
information belonging to a woman named Tamara Dadyan?
A
No, I was not.
Q
And you can't tell us whether or not the someone
else that record belonged to was a man named Manuk
Grigoryan; correct?
A
Correct.
Q
And you can't tell us whether the record, the
someone else that record belonged to was a woman named
Tamara Dadyan; correct?
A
Correct.
Q
In fact, you can't tell us for the invalid licenses
who any of those records belonged to?
A
No because it is a security breach, but, if I have
the record pulled up, I could tell you the name. But,
no, I wouldn't be able to tell you right now to confirm
that that is the name that is on the record. What I can
tell you is the driver's license number based on the
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information that was given to me did not match the name
and birthday that was given to me. Those did not match.
Q
Thank you, Ms. Fitzgerald.
THE COURT: Anyone else?
MR. LITTRELL: No, your Honor.
THE COURT: Thank you, ma'am. Thank you for being
here.
THE WITNESS: Thank you.
THE COURT: You are excused.
Call the next witness.
MR. FENTON: The government calls Jack Runyan.
THE CLERK: The witness will please step forward.
(The witness was sworn.)
THE COURT: Mr. Fenton, when you speak, is it
possible to drop your mask, or do you feel more
comfortable with the mask over your mouth?
MR. FENTON: I can drop my mask.
THE COURT: Okay. It would be helpful.
MR. FENTON: Yes, your Honor.
THE CLERK: The witness will please state his name
and spell it for the record.
THE WITNESS: Full name, Jack Lloyd Runyan,
J-A-C-K, L-L-O-Y-D, R-U-N-Y-A-N.
THE CLERK: Thank you.
///
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Case 2:20-cr-00579-SVW Document 672 Filed 07/09/21 Page 80 of 143 Page ID
#:10119
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DIRECT EXAMINATION
BY MR. FENTON:
Q
Good morning, Mr. Runyan.
A
Good morning.
Q
What town and state do you currently live in?
A
Clovis, California.
Q
And what, if anything, do you do for employment?
A
I have a tax practice. I do prepare income tax
returns.
Q
And do you own your own company?
A
Yes, I do.
Q
What is your company named?
A
It is Runyan Tax Service, Inc.
Q
And when did you start your company?
A
I incorporated in 2003.
Q
And are you the sole owner of the company?
A
Yes, I am now.
Q
Who previously -- who, if anyone, previously owned
the company with you?
A
My late wife owned half of it.
Q
But you are currently the sole owner?
A
Yes.
Q
Do you have any employees who work for you?
A
No, I do not.
Q
Has Runyan Tax Service, Inc. ever had any employees
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other than yourself?
A
My wife while she was living.
Q
Anyone else?
A
No.
Q
What does a tax preparer do?
A
Well, I meet with clients, gather information,
gather income, report the income and expenses related to
the individual or corporation or partnership and then
prepare the tax return to be filed with the IRS and the
state that they live in.
Q
And approximately how many clients did you have in
2019?
A
2019? 230.
Q
And approximately how many clients did you have in
2020?
A
235.
Q
Do you have a -- what types of clients do you have?
Do you have individuals?
A
I have individuals, some corporations, some
partnerships and some trusts.
Q
And do you have a system for keeping track of your
clients?
A
Prior information, prior years tax returns, and I
keep a ledger.
Q
A ledger with the names of your clients?
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A
Yes.
Q
So would you say that you know the name of each of
your clients?
A
Oh, definitely.
Q
And how do you know?
A
Well, my clientele is mainly clients that I have
had for I would say 20 to 30 years of service except for
occasionally I will pick up a new client.
Q
Sir, are you familiar with the Paycheck Protection
Program or the PPP program?
A
Not totally. I am familiar with it, but I don't
know the details of it.
Q
All right. Have any of your clients asked you to
assist them to apply for a PPP loan?
A
No.
Q
All right.
MR. FENTON: Your Honor, permission to publish for
the jury Government Exhibit 2P.
THE COURT: Go ahead.
Q BY MR. FENTON: Mr. Runyan, showing you what has
previously been admitted as Government's Exhibit 2P, and
I am going to direct your attention to a specific
document within this form -- within this file.
Sir, are you familiar with this type of form?
A
Yes. It is a 940, a payroll tax report.
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Q
And what is a Form 940?
A
940 is an annual report for federal unemployment
tax.
Q
Okay. And is there a quarterly version of these
types of filings as well?
A
Yes. That is a 941.
Q
All right. Do you -- in the course of your
business, do you help clients prepare Form 940's?
A
Currently, no. I used to, but, currently, no.
Q
And when you say used to, how long ago did you use
to prepare those forms?
A
Probably was five, ten years ago, just one or two
corporations or businesses.
Q
And would the same be true with respect to Form
941's?
A
Yes.
Q
Turning back this document at the top of page 1,
there is a name on this form. We are going to magnify
the top here, Mr. Runyan.
So at the top of the form it says Ulia Zhadko.
Is Ulia Zhadko a client of yours?
A
No, he is not.
Q
Do you know anybody named Ulia Zhadko?
A
No, I do not.
Q
What about this company name that is listed here,
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Turing Info Solutions, Inc.
Is that a client of yours?
A
No, they are not.
Q
Have you ever heard of that company before?
A
No, I have not.
MR. FENTON: Let's scroll down to the next page.
Go to part 6.
Q
Sir, can you see here at the bottom it says "paid
preparer use only"?
A
Yes.
Q
And do you see your name listed?
A
Yes, I do.
Q
Were you ever the designee for an individual named
Ulia Zhadko?
A
No, I was not.
Q
Or for a company called Turing Solutions?
A
No, I was not.
Q
And did you prepare this form?
A
No, I did not.
Q
Has Runyan Tax Service, Inc. ever submitted an
application for a PPP loan?
A
Not that I am aware of.
Q
To your knowledge, have you ever received any PPP
loan money?
A
No, I have not.
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MR. FENTON: Your Honor, permission to publish
Government Exhibit 2N.
THE COURT: Go ahead.
Q BY MR. FENTON: Mr. Runyan, showing you a document
previously admitted, Government Exhibit 2N, have you ever
seen this document before?
A
No, I have not.
Q
All right. Directing your attention to the top of
the page, what is the name of the business listed here?
A
Runyan Tax Service, Inc.
Q
And is that your business, sir?
A
Yes, it is.
Q
Turning the page -- let's turn to page 2 and about
to the bottom of the page. Do you see at the bottom of
the page there, sir, it lists the CEO of Runyan Tax
Service, Inc.?
A
I see the name.
Q
And what name do you see?
A
Viktoria -- I can't pronounce that. Kauichko.
Q
Do you know this individual, sir?
A
No, I do not.
Q
Does this individual work for Runyan Tax Service?
A
They do not.
Q
Is this individual a client of Runyan Tax Service,
Inc.?
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A
No, they are not.
Q
Did you ever authorize anyone to submit this
application on your behalf?
A
No, I did not.
Q
All right. Turning your attention to page 23 of
the exhibit. All right.
Sir, do you recognize this form?
A
Yes. It is a 940.
Q
Okay. Was the name -- and you see the name
Victoria Kauichko and the company Runyan Tax Service
listed there at the top?
A
Yes.
Q
Let's scroll down to the next page, and it says
here at the bottom for preparer use only. The preparer's
name is Jack Runyan. Is that true, sir?
A
Yes.
Q
Were you the preparer of this form?
A
No, I was not.
Q
Did you ever submit a Form 940 on behalf of your
company?
A
No, I did not.
Q
And did you authorize anyone to use your name to
prepare a 940 on behalf of your company?
A
No, I did not.
Q
All right, sir. I would like to show you just one
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more exhibit.
MR. FENTON: Your Honor, permission to publish for
the jury Government Exhibit 1P.
THE COURT: Go ahead.
Q BY MR. FENTON: Mr. Runyan, does Runyan Tax Service,
Inc. have a bank account?
A
Yes.
Q
And where does it bank?
A
Bank of America.
Q
All right. I am showing you Government Exhibit 1P,
do you recognize this document?
A
No, I do not.
Q
And this says the account title is Runyan Tax
Service, Inc., and that is your company, sir; correct?
A
Yes.
Q
And the account owner is Victoria Kauichko. Do you
see that?
A
Yes, I do.
Q
Did you ever authorize anyone named Victoria
Kauichko to open a Bank of America account in the name of
your company?
A
No, I did not.
Q
Thank you, sir.
MR. FENTON: No further questions.
THE COURT: Cross-examination.
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MS. NEWCOMER: Yes, your Honor.
CROSS-EXAMINATION
BY MS. NEWCOMER:
Q
Good morning, Mr. Runyan?
A
Morning.
Q
You learned that your, the name of your tax
business was used on PPP loan applications when the
government reached out to you to discuss that; is that
correct?
A
No.
Q
How did you find out, then?
A
I'm sorry. I don't understand the question.
Q
Sure. I will ask it better. Did you learn from
the government that your company's name, Runyan Tax
Service, had been used on PPP loan applications?
A
You mean the IRS?
Q
Yes.
A
They contacted me, yes.
Q
And before the IRS contacted you, did you know that
your company's name had been used?
A
No.
Q
And you don't know who created the Form 940 forms
using Runyan Tax Service's name; is that right?
A
Correct.
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Q
Thank you.
MS. NEWCOMER: No further questions.
THE COURT: Okay. Anything else?
MR. LITTRELL: No, your Honor.
THE COURT: All right. Thank you, sir. Thank
you.
Mr. Runyan, thank you for being here. You are
excused. Thank you.
Call the next witness.
MR. PAETTY: Your Honor, the United States calls
Victoria Hernandez.
THE CLERK: The witness will please step forward.
(The witness was sworn.)
THE CLERK: Please have a seat and state your full
name and spell it for the record.
THE WITNESS: Victoria Hernandez,
H-E-R-N-A-N-D-E-Z.
DIRECT EXAMINATION
BY MR. PAETTY:
Q
Good morning, Ms. Hernandez.
A
Good morning.
Q
Where do you work?
A
I work for the Internal Revenue Service.
Q
What do you do for the IRS?
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A
I am a court witness coordinator.
Q
What does a court witness coordinator do?
A
I represent the commissioner in his role as a
custodian of records. I review tax returns and
transcripts and certify that they are true, valid copies
of what is on the tax payer's account.
THE COURT: Could you keep your voice up a little
bit.
THE WITNESS: Sure can. Thank you. Sorry.
Q BY MR. PAETTY: There is a microphone in front of
you, Ms. Hernandez. You can speak into that too.
A
Okay.
Q
How long have you been doing that job?
A
I have been in this position for one year.
Q
And how long have you been with the IRS?
A
For 13 years.
Q
What job did you have before being a court witness
coordinator?
A
I was a customer service representative.
Q
Does the IRS have a record-keeping system?
A
Yes, we do.
Q
Are you familiar with it?
A
Yes, I am.
Q
Do you work with that system in the regular course
of your job?
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A
Yes, I do.
Q
What is that system?
A
It is called the IRS master file. We access -- it
is an interface that we use to access our integrated data
retrieval system that we can get information off of.
Q
Is that used in the regular course of business at
the IRS?
A
Yes, it is.
Q
What kinds of records are kept there?
A
Tax return information, tax filings, taxpayer
account information.
Q
Can searches be run on it?
A
Yes, they can.
Q
Do you know how to conduct searches on that system?
A
Yes, I do.
Q
Do you do that as a regular part of your job?
A
Yes, I do.
Q
Were you asked by the United States Attorney's
office to conduct searches of IRS records related to this
case?
A
Yes, I was.
Q
I will show you Government's Exhibit 47.
MR. PAETTY: Mr. Cruz, is there a way to display
it to the witness for identification?
Q
Do you recognize this document?
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A
There is nothing on here as of yet.
Q
Do you see the document now, Ms. Hernandez?
A
Yes, I do.
Q
And do you recognize this?
A
Yes, I do.
Q
How do you recognize it?
A
It is a certification of lack of records.
Q
And are these certifications kept in the regular
course of the IRS business?
A
Yes, it is.
Q
Are they kept in the database?
A
Yes, it is.
MR. PAETTY: Your Honor, the government moves to
admit under Federal Rule of Evidence 803(8) and 803(10)
Government's Exhibit 47.
THE COURT: Proceed.
Q BY MR. PAETTY: So, as you stated, Ms. Hernandez,
there are more than one of these. How many certificates
are in Exhibit 47?
A
Approximately 87.
Q
And did you run searches for the tax records for
each of the companies and the EIN's that are listed in
Exhibit 47?
A
Yes, I did.
Q
We won't look at all of them, but let's look at one
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or two. So directing your attention to the description
of records sought section. I will highlight that.
So what is the company name -- what are the
records sought here in this certificate?
A
It is for a company Turing Info Solutions with an
Employee Identification Number of 85-2214789.
Q
And what documents were sought?
A
Form 1120 US Corporate Income Tax Return.
Q
What is a Form 1120?
A
It is a US income tax return for corporations.
Q
And did you run a search for tax records for Turing
Info Solutions for the --
THE COURT: You know something, your voice is
trailing off. You don't speak into the microphone. Say
that again.
MR. PAETTY: Yes, your Honor.
Q
So did you run a search for Turing Info Solutions
with Taxpayer Identification Number 85-2214789?
A
Yes, I did.
Q
And what were the results of that?
A
For the years that were listed on this certificate
of lack of record, there was no records found.
Q
What were those tax years?
A
Tax year 2018 and tax year 2019.
Q
Direct your attention now to page 75. So that is
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the same company name, Turing Info Solutions, the same
Taxpayer Identification Number 85-2214789. The
information sought is a Form 940. What is a Form 940?
A
Employer's Annual Federal Unemployment Tax Return.
Q
Did you run a search for records for Form 940 for
Turing Info Solutions?
A
Yes, I did.
Q
Is that for tax periods 2018 and 2019?
A
Yes.
Q
What were the results of that?
A
There was no returns found for those years.
Q
Page 76 of Exhibit 47. Can you describe what the
description of records sought and the results are for
this document?
A
For Turing Info Solutions, Employer Identification
Number 85-2214789, we -- I researched for Form 941
employer's quarterly federal tax return. And for the
years 2018, 2019 and the ending first quarter of 2020,
and there was no record of returns filed.
Q
So the searches that you ran for all of the
companies and taxpayer identification numbers in Exhibit
47, for all of those, what was the results?
A
There was no record of returns filed for those lack
of records.
THE COURT: I didn't understand the question and
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answer. Can you repeat that?
MR. PAETTY: Yes, your Honor.
Q
So you stated that you conducted searches for all
of the companies and Employer Identification Numbers in
Exhibit 47; is that right?
A
Yes, I did.
Q
And what were those results for the tax years
listed in Exhibit 47?
A
There were no returns listed for those years.
Q
For those companies and those identification
numbers?
A
Yes.
MR. PAETTY: Mr. Cruz, can I show the witness
Government Exhibit 48 for identification.
Q
Ms. Hernandez, do you recognize these documents?
A
Yes, I do.
Q
How do you recognize them?
A
I was requested to research over these letters.
Q
What are they?
A
Fact-of-filing letters.
Q
What is a fact-of-filing letter. It is a letter
stating of all filings for the years requested for that
company.
Q
And are these fact-of-filing letters kept in the
regular course of business of the IRS?
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A
Yes, they are.
Q
And is this information located in the IRS
database?
A
Yes, it is.
MR. PAETTY: Your Honor, the government moves
Exhibit 48 into evidence?
THE COURT: Received.
Q BY MR. PAETTY: I will just ask you some questions
about some specific companies and EIN's that are in
Exhibit 48.
Did you run a search for tax records for G&A
Diamonds with an EIN 60-3252838?
A
Yes, I did.
Q
What were the results of that search?
A
There was no record of that Employer Identification
Number. It is an invalid EIN.
Q
How about for Hart Construction, did you also run a
search for tax records for Hart Construction with EIN
54-8649260.
A
Yes, I did.
Q
What was the result of that search?
A
There was no record of an account. That EIN is
invalid.
Q
Top Quality contracting. Did you also run a search
for that company with EIN 82-5088385?
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A
Yes, I did.
Q
What was the result of that search?
A
The business that is tied to that Employer
Identification Number was different than the business
listed.
Q
Did the EIN that you searched reference Top Quality
contracting?
A
No, it did not.
MR. PAETTY: No further questions, your Honor.
THE COURT: Cross-examination.
CROSS-EXAMINATION
BY MR. KEOUGH:
Q
Good morning.
A
Good morning.
Q
TIN is a Taxpayer Identification Number; correct?
A
Correct.
Q
And an employer can register for a TIN, and they
can use it when they file tax returns?
A
Correct.
Q
And similar idea with an Employer Identification
Number. A business can register for an EIN but use it
when they file forms with the IRS?
A
Correct.
Q
Does a business need a TIN or an EIN in order to
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operate?
A
Yes.
Q
So if a business doesn't have a TIN or an EIN, your
testimony is there is no way that could be a real
business?
A
Can you ask it -- I'm sorry.
Q
Would you agree that, for example, if there was a
sole proprietorship and somebody filed through their
personal income taxes, they might be operating a business
in the state where they live but they wouldn't
necessarily need a TIN or an EIN in order to file a tax
return because they would use their own Social Security
number?
MR. PAETTY: Objection. Lacks foundation.
THE COURT: Sustained.
Q BY MR. KEOUGH: You testified about searches that
you ran through the IRS master file; correct?
A
Yes.
Q
And you testified about a search you ran for Turing
Info Solutions; correct?
A
Correct.
Q
And that search using a taxpayer identification
number returned no records?
A
For the years listed of this certificate.
Q
For the years you were asked to search, there were
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no records?
A
Correct.
Q
And who asked you to run the searches for the
Turing Info Solutions information?
A
The Assistant U.S. Attorney.
Q
And who provided you the name Turing Info
Solutions?
A
The lack of record had it listed on there.
Q
So the Assistant U.S. Attorney provided you with
the taxpayer identification number and then you ran the
lack of record but found that it was associated with that
business name?
A
Excuse me?
MR. PAETTY: Objection. Misstates the evidence.
THE COURT: Sustained.
Q BY MR. KEOUGH: You testified that you were provided
the Taxpayer Identification Number by the Assistant US
Attorney; correct?
A
Correct.
Q
And when you ran that search, you found that the
Taxpayer Identification Number was associated with a name
called Turing Info Solutions; correct?
MR. PAETTY: Objection. Misstates the evidence.
THE COURT: Sustained.
MR. KEOUGH: As part of that search for Turing
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Info Solutionss, were you asked to cross-reference any
information and determine whether that Taxpayer
Information Number was used by a man named Manuk
Grigoryan.
MR. PAETTY: Objection. Lacks foundation.
THE COURT: Sustained. I mean, the question is
was she asked to do it, and she can answer "yes" or "no".
MR. KEOUGH: Thank you, your Honor.
You can answer.
THE WITNESS: Can you repeat the question.
Q BY MR. KEOUGH: The question was as part of the
search that you testified to about the Turing Info
Solutions TIN, were you asked to cross-reference
information to determine whether this TIN was used by a
man named Manuk Grigoryan?
A
No.
Q
And were you asked to cross-reference information
to determine whether that TIN was used by a woman named
Tamara Dadyan?
MR. PAETTY: Objection. Vague as to
cross-reference.
THE COURT: Can you ask the question more
specifically.
MR. KEOUGH: Of course, your Honor.
Q
As part of the searches that you ran with Turing
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Info Solutions, were you provided with any information
related to a woman named Tamara Dadyan and asked to
determine if that information was associated with Turing
Info Solutionss in the IRS master file?
A
No.
MR. KEOUGH: Thank you. No further questions.
MR. LITTRELL: No questions, your Honor.
CROSS-EXAMINATION
BY MR. JOHNSON:
Q
Good morning.
A
Good morning.
Q
Were you asked to search for a company named Voyage
Limo?
A
I do remember the name in part of the searches that
I did, yes.
Q
Did you have a record that is related to Voyage
Limo being a legitimate company?
MR. PAETTY: Objection. Foundation.
THE COURT: I couldn't hear the question.
Q BY MR. JOHNSON: Do you have a record -- You talked
about Exhibit 47; isn't that correct?
A
Yes.
Q
And did you review Exhibit 47 before testifying
today?
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A
Yes.
Q
And inside of Exhibit 47, is there any reference to
a company called Voyage Limo?
A
Yes.
Q
And where is that?
A
The lack of records?
Q
Is there a lack -- yes. Where is that inside
Exhibit 47?
A
I don't have it up here so there is a lot of lack
of records.
Q
So can the government show the witness Exhibit 47,
please. While I am going through that, in terms of
Exhibit 48, is there a reference to Voyage Limo in
Exhibit 48?
A
I can't see Exhibit 48 up here. Sorry.
Q
Did you review Exhibit 48 in advance of testifying
today?
A
Yes, I did.
Q
And do you recall whether there is a reference to
Voyage Limo in the Exhibit 48?
A
I can't recall. I'm sorry. I can only see the
lack of record up here.
Q
So, in reviewing, do you need the time to review
through the 87 pages of the exhibit to determine whether
Exhibit 48 has a reference to Voyage Limo?
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THE COURT: I mean, can counsel help?
MR. PAETTY: Yes, your Honor, I can.
THE COURT: What is the answer?
MR. PAETTY: The answer is that there is a record.
It is at Bates Range 147569, your Honor.
May I approach the witness?
THE COURT: Yes.
THE WITNESS: Yes, I see it now.
Q BY MR. JOHNSON: Do you have that record in front of
you? What is the information related to Voyage Limo?
A
For the years listed and the forms listed as well,
there was no record of any forms being filed.
Q
And when a company is applying for a business --
they can apply for as a business under a sole
proprietorship; isn't that correct?
A
Correct.
Q
And a sole proprietorship would be listed under the
personal tax returns of the individual; isn't that
correct?
A
Correct.
Q
And that is in the form of the Schedule C; isn't
that correct?
A
Yes.
Q
And where there is a Schedule C, the person can
list inside the Schedule C business expenses; is that
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correct?
A
Correct.
Q
And that Schedule C would also show whether they
had expenses for independent contractors; is that
correct?
A
Correct.
Q
Were you asked to look at the documents for the
personal records, the personal tax returns of Vahe
Dadyan?
A
No.
Q
Thank you.
MR. LITTRELL: No further questions?
THE COURT: Thank you, ma'am. Ms. Hernandez, you
are excused.
THE WITNESS: Thank you.
THE COURT: Call the next witness.
MR. PAETTY: Your Honor, may I approach to get the
folder back?
THE COURT: Yes.
MR. FENTON: The government calls Alexander Fard.
THE CLERK: The witness will please step forward.
(The witness was sworn.)
THE CLERK: Please be seated.
Please state your full name and spell it for
the record.
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THE WITNESS: Alexander Benjamin Fard,
A-L-E-X-A-N-D-E-R, B-E-N-J-A-M-I-N, F-A-R-D.
DIRECT EXAMINATION
BY MR. FENTON:
Q
Good morning, Mr. Fard.
A
Good morning.
Q
Can you tell us what city and state do you live in?
A
Sherman Oaks, California.
Q
And what, if anything, do you do for employment?
A
I am a CPA. I run my own business.
Q
And what is the name of your business?
A
Fard Tax and Accounting.
Q
And do you have any employees?
A
One employee.
Q
And what does that employee do for you?
A
Some tax preparation and bookkeeping.
Q
Do they have their own clients?
A
No.
Q
All the clients are yours?
A
Yes.
Q
What does a tax preparer do?
A
Typically prepares income tax returns and other
types of tax return forms that are necessary in order to
be compliant.
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Q
And do you provide those tax services for your
clients?
A
Yes.
Q
Do you provide any other types of services as well?
A
I provide accounting services in addition to that
so monthly account maintenance like bookkeeping.
THE COURT: Is it possible for you to take the
mask down when you speak? Thank you.
Q BY MR. FENTON: How many clients did you have in
2019?
A
About 120.
Q
And how about 2020?
A
About 160.
Q
What types of clients do you have generally?
A
Individuals and small businesses.
Q
Do you have a system for keeping track of your
clients?
A
Multiple.
Q
And can you describe that system for the jury?
A
My first system is my tax preparation software in
which I can see my entire client list. In addition to
that, I have a work flow management system called Jetpack
which allows me to keep track of multiple jobs for
clients.
Q
So would you say that you know the name of each of
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your clients?
A
Yes.
Q
And are you familiar with the Paycheck Protection
Program or the PPP program?
A
Yes.
Q
And how are you familiar with that?
A
It was necessary information for me to know for my
clients in order to give them as good advice and guidance
as possible as their accountant.
Q
All right. So have any of your clients asked you
to assist them to apply for a PPP loan?
A
Yes.
Q
What, if anything, did they specifically ask you to
do?
A
I have had two clients I have had to hold their
hands through the process of the PPP loan application.
Other than that, other clients have just requested the
documentation necessary to apply for a PPP loan.
Q
I am going to show you what was previously admitted
as Government Exhibit 2M. All right. Directing your
attention to page 8.
Do you recognize this type of document?
A
Yes.
Q
What is it?
A
This is an unemployment tax return that needs to be
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filed annually.
Q
So what is an unemployment tax return?
A
So if you are an employer who has payroll, for the
first $7,000 of wages, you are required to pay $42 in
unemployment taxes. This is the form that you use in
order to calculate that exact amount.
Q
And is there a quarterly version of those same
filings?
A
There is a quarterly payroll tax return, a Form 941
which is for Social Security and Medicare wages whereas
this is for unemployment wages or unemployment.
Q
And if a company were to have employees, you would
expect that they would submit both of those types of
forms?
A
Yes.
Q
Do you help your clients prepare these types of
forms, the Form 940's?
A
Occasionally. I usually outsource it to a payroll
service in which I help my client set up the service and
the service will maintain the form filings for them.
Q
When you say payroll service, what type of service
are you referring to?
A
ADP, Gusto, Intuit full service payroll, and some
of my clients will use Heartland payroll as well.
Q
And would the same be true for the Form 940's as
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well?
A
Yes.
Q
Turning back to this document at the top of page 1,
the name of the form, is Anton Kudiumov.
Do you see that, sir?
A
Yes.
Q
So the top there it says Anton Kudiumov. Is Anton
Kudiumov a client of yours?
A
No.
Q
Do you know anyone named Anton Kudiumov?
A
No.
Q
How about the company that is named there. Do you
see that company?
A
Yes, I do see it.
Q
Redline Auto Mechanics, is that a client of yours?
A
No, they are not.
Q
Do you know the company Redline Auto Mechanics?
A
No.
Q
Let's scroll down one page. Let's look to part 6
here next to designee's name and phone number. Can you
please tell what name you see listed there.?
A
That is my name, Alexander Fard.
Q
And are you the designee for Anton Kudiumov?
A
No.
Q
Are you the designee for Redline Auto Mechanics?
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A
No.
Q
What about that telephone number there, is that
your telephone number?
A
No. That is not my telephone number.
Q
All right. Let's look down to the bottom of the
page where it says paid preparer use only. Next to
preparer's name, it says Alexander Fard via Gusto
Payroll.
Do you work for Gusto Payroll?
A
No.
Q
And how about the rest of this information here, is
this information accurate information, the PTIN, for
example? Let's talk about the PTIN.
A
The PTIN is not correct.
Q
What is a PTIN?
A
PTIN is a Preparer Tax Identification Number. In
order to prepare tax returns for individuals, you must
register with the IRS, and they give you that number.
Q
Is this your PTIN?
A
No.
Q
Here it also lists an address. Is this your
address?
A
That was an address that I had used previously. It
was an address that I was meeting clients at. Typically
speaking, I set my home base of operations as my house in
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Sherman Oaks, and so I never actually used that address
in order to prepare or file any returns. It was an
address that was used for me to meet clients.
Q
All right, sir. We are going to take a look at
another exhibit.
MR. FENTON: Your Honor, request permission to
publish to the jury Government Exhibit 2Q.
THE COURT: Yes.
MR. FENTON: We are going to scroll down to page
21.
Q
All right. Sir, do you recognize this form of
document?
A
Yes.
Q
And what do you recognize this to be?
A
This is the quarterly payroll tax return for first
quarter of 2020.
Q
This was the form that we spoke about earlier; is
that right?
A
Yes. So where the Social Security wages and
Medicare wages are reported.
Q
The top of the page there, it says the name Anna
Dzukaeva. Is Anna Dzukaeva client of yours?
A
No.
Q
What about that company name that is stated there,
Six Star Farms. Is that company a client of yours?
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A
No.
Q
Do you know the name Six Star Farms?
A
No.
Q
Let's scroll to the next page at the bottom of the
page here. It says paid preparer use only, and next to
preparer's name it says Alexander Fard via Gusto Payroll.
Did you prepare this form, sir?
A
No.
Q
Did you authorize anyone else to prepare this form
on your behalf?
A
No.
MR. FENTON: No further questions. Thank you.
THE COURT: Cross-examination.
CROSS-EXAMINATION
BY MR. KEOUGH:
Q
Thank you, Mr. Fard, for coming in this morning.
You were just asked some questions about government
Exhibit 2M which was a PPP application filed by Anton
Kudiumov.
Do you recall that?
A
Yes.
Q
And is it fair to say that you learned that your
company's name had been used on these forms when the IRS
reached out to you?
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A
Could you repeat that question one more time.
Q
Sure. Let me ask it a different way. Is it fair
to say that before the IRS reached out to you to tell you
that your company name had been used on these forms, you
didn't know that someone had submitted this PPP loan
application?
A
Correct.
Q
And is it fair to say that you have no idea who
prepared these forms?
A
Correct.
Q
You were also asked questions about government
Exhibit 2Q which was a PPP application submitted by
someone named Anna Dzukaeva for a company named Six Star
Farms. Do you recall that?
A
Yes.
Q
It is also true that you didn't know this
application had been submitted before the IRS reached out
to you?
A
Correct.
Q
And is it fair to say you don't know who submitted
the application or who created those forms?
A
Correct.
Q
Thank you, Mr. Fard.
THE COURT: Any other cross-examination?
MR. LITTRELL: No.
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THE COURT: Thank you, sir. You are excused.
Next witness.
MR. PAETTY: Your Honor, the United States calls
Pinal Modi.
THE CLERK: The witness will please step forward.
(The witness was sworn.)
THE CLERK: Please be seated.
State your full name and spell it for the
record. Speak directly into the mic, please.
THE WITNESS: Sure. My name name is Pinal Modi,
P-I-N-A-L, and last name is M-O-D-I.
THE CLERK: Thank you.
DIRECT EXAMINATION
BY MR. PAETTY:
Q
Good morning, Ms. Modi.
A
Good morning.
Q
Where do you work?
A
I work for EDD, Employment Development Department,
State of California.
Q
What is your job there?
A
My job is a staff tax auditor and as a hearing rep.
I represent the department in the hearing.
THE COURT: Ms. Modi, please speak more loudly in
the microphone.
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THE WITNESS: Sure.
Q BY MR. PAETTY: What is your job with EDD, Ms. Modi?
A
My job is as a staff tax auditor.
Q
I think you mentioned something else, a hearing
representative. What is that?
A
Yes. So as a staff tax auditor, I conduct the
audit of the payroll taxes, and I also represent, mainly
last five years, I am working as a hearing rep
representing the department in the court hearing.
Q
And are you a custodian of records for the EDD?
A
Yes, I do.
THE COURT: What is EDD? What is EDD?
THE WITNESS: EDD is Employment Development
Department, State of California.
Q BY MR. PAETTY: And what does the Employment
Development Department do?
A
The Employment Development Department administers
the unemployment and the disability programs. It also
administers the payroll taxes. So state payroll taxes
filed with the EDD.
Q
And does it have a record -- does EDD have a
record-keeping system?
A
Yes, it does.
Q
Are you familiar with it?
A
Yes, I am.
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Q
Do you work with it as a regular part of your job?
A
Yes, I am.
Q
What is the system?
A
The system is the name is ACES, Accounting
Compliance Enterprise System.
Q
Can you describe it?
A
So the system that we use, it stores the business
payroll information, the business locations, the address,
the federal ID and every quarterly federal return and the
federal filings with the EDD.
Q
Can searches be run on that system?
A
Yes, it can be done in that system.
Q
Do you know how to conduct those searches?
A
Yes, I do.
Q
Do you run searches in that system as part of your
job?
A
Yes.
Q
So were you asked by the United States attorney's
office to conduct searches of the EDD database related to
this case?
A
Yes, we were asked for that.
MR. PAETTY: So, Mr. Cruz, I am going to show the
witness Exhibit 45 marked for identification,
Government's Exhibit 45.
Q
Do you recognize this document?
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A
Yes, I do.
Q
How do you recognize it?
A
It is the EDD logo on the top, and I recognize it
as EDD document, and it is a certified document by the
EDD.
Q
And did you run -- did you run searches in the
database for the list of companies and EIN's that appear
on this document?
A
Yes, I did.
Q
Is this document a true and accurate copy of the
results of your searches?
A
Yes, it does.
MR. PAETTY: Your Honor, move to admit Exhibit 45
under Federal Rule of Evidence 803(8) and 803(10.)?
THE COURT: Proceed.
MR. PAETTY: Permission to publish?
THE COURT: Yes.
Q BY MR. PAETTY: So, Ms. Modi, the first column, the
taxpayer column, what is that.
A
The taxpayer column is the business name.
Q
How about the SSN, FEIN employer payroll tax
account number. What is in that column?
A
For that column, the listed numbers are the federal
ID number that is associated with these businesses.
Q
So we will move over two columns to the records
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column. What is in this column?
A
I'm sorry. Which column?
Q
The records column, two columns over?
A
Yes. So the records column is the form, the DE9
which is a payroll tax return, and the DE9C which is the
wage report that every quarter the business with the
employees, they have to file. Required to file. So
these are the forms that required to file every quarter.
Q
So if an employer paid payroll taxes and had
payroll expenses, would you expect that to be reflected
in the Form 9 or the Form 9C?
A
Yes. It should be reflected in there.
Q
Going back to the top, the top of the form, it says
that there were no records found. What does that mean?
A
So meaning that under these businesses in the
federal ID, there were no DE9 or DE9C filed with the
department. So we didn't find any records for these
businesses.
Q
And that is for the tax periods listed on the far
right column?
A
Yes.
Q
And what tax periods were those?
A
So the tax period is January 1, 2019, to March 31,
2021. It listed as 19-1 which is the form that we use
because we use the quarterly system for filing. So it is
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a 19-1 represent the first quarter of 2019 to the first
quarter of 2021.
Q
So the companies listed in the EIN's in Exhibit 45,
does that mean that they did not pay payroll taxes or
report payroll expenses for the quarters that you just
mentioned?
A
That would be correct.
Q
In addition to the results of the searches that we
just discussed, did you also run a search for Sabala
Construction with EIN 84-2698846 for DE9 and DE9C filings
for the tax period of 2019 to the first quarter of 2021?
A
Yes, I did.
Q
What were the results of that?
A
We didn't find any results. We didn't find any
records for that business.
Q
So no payroll taxes, no payroll expenses for that
business?
A
That would be correct.
Q
Did you run a search for Timeline Transport with
EIN 85-0925228 for DE9 and DE9C filings for the tax years
that we discussed with the other companies?
A
Yes, I did.
Q
What was the result of that search?
A
It was the same. We didn't find any tax records.
DE9D, DE9C.
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Q
So no payroll expenses, no payroll taxes for
Timeline Transport for that period.
A
That would be correct.
Q
Top Quality contracting. Did you also run a search
for that company with EIN 82-5088385 for DE9 and DE9C
filings for the tax periods in the years we discussed
with the other companies?
A
Yes. I did search for that company, and we found
no results, no payroll forms or returns were filed.
Q
So no payroll taxes, no payroll expenses?
A
That would be correct.
Q
Did you also run a search for Redline Auto
Mechanics, with an EIN of 81-5450370 for DE9 and DE9C
filings for the tax years discussed with the other
companies?
A
Yes, I did.
Q
What was the result of that?
A
That result was also the same. There was no record
for that business as well. No DE9, DE9C.
Q
No payroll taxes, no payroll expenses for that
company?
A
That would be correct. Yes.
MR. PAETTY: No further questions, your Honor?
THE COURT: Cross-examination.
///
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Case 2:20-cr-00579-SVW Document 672 Filed 07/09/21 Page 121 of 143 Page ID
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CROSS-EXAMINATION
BY MR. KEOUGH:
Q
Thank you for coming in this morning. You
testified about searches you ran in a database called
ACES; correct?
A
Yes.
Q
And ACES is pretty much the place where EDD keeps
the records it has related to businesses in California?
A
Yes, that would be correct.
Q
Do those EDD records show the relationships that
might exist between individuals and the companies that
you have recordings for?
MR. PAETTY: Objection. Foundation. Vague.
THE COURT: Well, I mean, do you know of your own
knowledge the matters asked in the question. First,
answer that question.
THE WITNESS: Can you repeat the question?
MR. KEOUGH: Sure.
Q
Do the EDD records show relationships between
certain individuals and the companies that you have
records for in the ACES database?
A
Are you asking in terms of the employees?
Q
So for anyone. Whether it is the proprietor -- if
I wanted to find out the relationship between individuals
and those companies, is there a search I could perform to
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Case 2:20-cr-00579-SVW Document 672 Filed 07/09/21 Page 122 of 143 Page ID
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do it?
A
So if it is the business corporations, then the
ownership, the officers, they are also listed in the
system. So we can search with the officer's names and
the Social Security number that is provided. When it
comes through the employee, then the DE9C is the form
that the business owners or whoever is handling the
payroll is required to report each employee's name, their
Social Security numbers, their wages that were paid, the
personal income tax, state income tax which is withheld.
So those are also the information stored in the system.
Q
Thank you. Now, let's say it is not a officer and
it is not an employee. Say it is more informal
relationship. Would that type of relationship be
captured in the records that you were able to search in
the ACES database?
MR. PAETTY: Objection. Foundation. Vague.
THE COURT: Sustained.
Q BY MR. KEOUGH: Who provided the information that
you used to conduct the searches that you testified
about?
A
We were requested from the courthouse.
Q
And do you know who specifically provided that
information?
A
I believe the attorney requested it.
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Q
And was that the United States Attorney's office?
A
Yes.
Q
And as part of those searches that you were asked
to conduct, were you provided with any information
related to a man named Manuk Grigoryan?
A
If I have the exhibit, then I would look at it.
The searches that I did, it was in the exhibit.
Q
And were there any names of individuals in that
list?
A
I have to look at it, the exhibit. If it is not
listed there, then maybe not.
Q
So fair to say an individual is not in there, you
weren't asked to search for it?
A
That would be correct, yes.
Q
And were you asked to search for -- were you
provided with any information related to a woman named
Tamara Dadyan as part of your searches?
A
Again, if it is listed in the exhibit, then I have
conducted the search. If it is not in there, then I did
not.
MR. KEOUGH: Let's pull up a copy of the Exhibit.
THE COURT: Are you going to ask her whether the
name is there in there?
MR. KEOUGH: Yes, your Honor.
THE COURT: Let's not do that.
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125
MR. KEOUGH: Fair enough, your Honor.
Q
As part of the searches that you ran, were you
asked to look for relationships between a man named Manuk
Grigoryan and the companies that were on the list
provided to you by the US Attorney's office?
MR. PAETTY: Objection. Foundation. Vague.
THE COURT: Well, the question is just was she
asked to do that, "yes" or "no".
THE WITNESS: As I said, if the name is listed in
the exhibits, then I would have run the search.
THE COURT: I mean, she has said, and I am not the
trier of fact here, but my impression of what she said is
she was asked to only look at the names that are on the
list; is that right?
THE WITNESS: Yes. That would be right.
THE COURT: What exhibit is that?
THE WITNESS: I'm sorry.
THE COURT: What exhibit number is that.
THE WITNESS: It was 45. It was just specific to
us.
THE COURT: And so if a name is not on that list,
you weren't asked about it; correct?
THE WITNESS: That would be correct, yes.
MR. KEOUGH: Thank you, your Honor.
Q
And just one last question. Is it fair to say that
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if a name was not on your list, you were not asked to
look for relationships between people who weren't on your
list and the companies that were on your list.
MR. PAETTY: Objection. Asked and answered.
THE COURT: I mean, if the name is not on the
list, how is she able to do what you just asked?
MR. KEOUGH: That is the question, your Honor.
THE COURT: All right. So it is self evident.
She wasn't able to do that. Okay.
MR. KEOUGH: Thank you.
THE COURT: Thank you.
Thank you, ma'am, for being here, and you
are excused. Thank you.
THE WITNESS: Thank you.
THE COURT: I am looking at the clock, and it is
now 5 or 6 after 12:00. So let's come back at 10 after
1:00 and we will go to 5:00 o'clock.
(Luncheon recess from 12:05 to 1:10 p.m.)
(Proceedings concluded.)
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#:10165
CERTIFICATE
I hereby certify that pursuant to Section 753, Title 28,
United States Code, the foregoing is a true and correct
transcript of the stenographically reported proceedings held
in the above-entitled matter and that the transcript page
format is in conformance with the regulations of the
Judicial Conference of the United States.
Date: June 16, 2021
/s/ Katie Thibodeaux, CSR No. 9858, RPR, CRR
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Case 2:20-cr-00579-SVW Document 672 Filed 07/09/21 Page 127 of 143 Page ID
#:10166
MR. FENTON: [24] 6/10 12/3
12/6 13/12 60/17 63/6 63/23
64/24 65/2 66/10 66/20 68/9
80/10 80/16 80/18 83/16 85/5
85/25 88/1 88/23 105/19
112/5 112/8 113/11
MR. JOHNSON: [27] 5/16 6/8
8/7 8/9 8/11 8/13 9/16 12/10
13/20 16/2 26/3 26/9 26/13
37/20 37/24 52/2 53/7 53/17
53/21 53/25 54/5 56/3 58/2
58/9 59/1 60/12 60/18
MR. KEOUGH: [11] 100/24
101/7 101/23 102/5 122/17
124/20 124/23 124/25 125/23
126/6 126/9
MR. LITTRELL: [13] 14/22
15/1 15/8 15/11 15/13 52/1
66/22 67/1 80/4 90/3 102/6
105/11 114/24
MR. MESEREAU: [2] 49/20
51/23
MR. PAETTY: [29] 68/20 69/2
75/25 90/9 92/22 93/12 94/15
96/1 96/12 97/4 98/8 99/13
100/13 100/22 101/4 101/19
102/18 104/1 104/3 105/16
115/2 117/21 118/12 118/15
121/22 122/12 123/16 125/5
126/3
MR. RAM: [1] 67/4
MR. SILVERMAN: [15] 23/22
23/25 24/11 38/11 38/16
45/13 47/11 47/17 47/22 48/2
48/5 48/18 48/22 49/12 49/18
MS. AHN: [48] 8/22 8/24 9/1
9/13 14/15 14/20 15/15 16/3
16/5 16/9 16/20 19/20 20/14
21/10 21/14 23/2 26/2 26/17
30/12 30/15 31/16 32/20 34/4
34/13 35/7 35/20 36/15 37/2
38/1 38/8 39/18 40/21 41/6
41/15 45/11 45/23 47/15
47/25 48/20 53/20 54/2 57/7
58/1 58/11 59/15 68/12 68/16
68/25
MS. NEWCOMER: [3] 68/11
88/25 90/1
MS. WIRSCHING: [3] 5/18
6/25 7/3
THE CLERK: [15] 6/6 60/21
60/23 67/3 69/6 80/11 80/19
80/23 90/11 90/13 105/20
105/22 115/4 115/6 115/11
THE COURT: [128]
THE WITNESS: [25] 41/9
41/17 46/2 55/25 60/16 60/25
69/8 80/7 80/21 90/15 91/8
101/9 104/7 105/14 105/25
115/9 115/25 116/12 122/16
125/8 125/14 125/16 125/18
125/22 126/13
$
$1,000 [1] 33/22
$10,000 [1] 33/22
$100 [1] 36/4
$134 [1] 49/16
$42 [1] 109/4
$7,000 [1] 109/4
-
-and [2] 2/5 2/8
/
/s [1] 127/12
0
0925228 [1] 120/20
1
10 [7] 33/22 35/9 67/9 69/5
93/14 118/14 126/16
100 percent [1] 18/2
10036 [1] 2/18
10100 [1] 3/15
102 [1] 4/14
106 [1] 4/16
10:30 [1] 67/4
10:31 [1] 67/11
10:48 [1] 67/11
1114 [1] 2/17
1120 [2] 94/8 94/9
113 [1] 4/16
115 [1] 4/18
12 [2] 12/18 31/23
120 [1] 107/11
122 [1] 4/18
12:00 [1] 126/16
12:00 o'clock [1] 67/10
12:05 [1] 126/18
13 [1] 91/16
1330 [1] 2/23
14 [1] 31/21
1400 [1] 2/10
147569 [1] 104/5
15th [3] 25/2 71/19 72/15
16 [22] 1/17 4/4 4/21 4/21
4/21 4/21 4/22 4/22 4/22
4/22 4/23 4/23 4/23 5/1
12/18 17/4 38/25 47/14 48/20
48/24 56/17 127/10
160 [1] 107/13
16417 [2] 61/11 64/10
19 [2] 27/9 27/17
19-1 [2] 119/24 120/1
1900 [1] 2/15
1924 [1] 75/16
1935 [1] 3/12
1984 [1] 75/7
1989 [1] 73/3
1990 [2] 71/19 72/15
1994 [3] 73/23 74/7 74/23
1995 [1] 74/15
19th [2] 73/22 74/7
1:00 [1] 126/17
1:10 [1] 126/18
1A [2] 4/21 15/17
1F [1] 65/1
1P [2] 88/3 88/10
1S [2] 4/21 15/17
1st [1] 1/22
2
2.5 [1] 20/18
20 [1] 83/7
20-579 [1] 1/8
20-plus [1] 10/21
2003 [1] 81/15
20036 [1] 2/23
2012 [1] 7/12
2018 [3] 94/24 95/8 95/18
2019 [9] 82/12 82/13 94/24
95/8 95/18 107/10 119/23
120/1 120/11
2020 [23] 8/17 10/10 17/18
25/2 25/7 25/9 31/24 36/3
40/9 41/15 47/7 47/8 47/10
48/3 49/8 49/11 49/15 56/20
56/21 82/15 95/18 107/12
112/16
2021 [6] 1/17 5/1 119/24
120/2 120/11 127/10
20530 [1] 2/10
21 [1] 112/10
216 [1] 3/13
2214789 [4] 94/6 94/18 95/2
95/16
23 [1] 87/5
230 [1] 82/13
235 [1] 82/16
23rd [1] 75/16
24 [1] 35/9
25th [1] 74/23
2698846 [1] 120/10
28 [1] 127/4
29th [1] 74/15
2A [3] 4/21 15/19 15/19
2E [3] 19/22 50/10 62/14
2K [2] 53/8 54/2
2L [1] 30/14
2M [2] 108/20 113/19
2N [2] 86/2 86/5
2nd [1] 75/7
2P [2] 83/18 83/21
2Q [4] 4/21 15/19 112/7
114/12
3
30 [3] 4/22 16/1 83/7
300 [1] 3/16
31 [4] 16/1 31/24 36/2
119/23
312 [1] 2/6
32 [1] 16/1
3252838 [1] 97/12
33 [1] 16/1
34 [3] 16/1 16/4 31/15
35 [3] 16/1 16/4 61/22
350 [2] 1/22 3/5
36 [3] 4/22 16/2 16/4
38 [2] 4/5 16/2
38-42 [1] 4/23
39 [1] 16/2
3900 [1] 2/20
3A [2] 4/21 15/20
3S [2] 4/21 15/20
4
4-page [1] 59/25
40 [1] 16/2
409 [1] 3/20
41 [1] 16/2
42 [2] 4/23 16/2
4311 [1] 1/22
45 [5] 117/23 117/24 118/13
120/3 125/19
47 [15] 4/23 64/4 92/22
93/15 93/19 93/23 95/12
95/22 96/5 96/8 102/22
102/24 103/2 103/8 103/11
48 [11] 4/23 4/24 96/14 97/6
97/10 103/13 103/14 103/15
103/16 103/20 103/25
4A [3] 4/21 15/21 15/22
4Y [2] 4/21 15/21
5
5-minute [2] 66/23 67/1
50 [1] 4/5
5088385 [2] 97/25 121/5
51A [2] 69/4 71/7
52 [1] 4/6
54-8649260 [1] 97/19
5450370 [1] 121/13
579 [1] 1/8
5:00 o'clock [1] 126/17
5A [2] 4/21 15/23
5th [2] 2/14 3/8
5Z [2] 4/21 15/23
6
60-3252838 [1] 97/12
Case 2:20-cr-00579-SVW Document 672 Filed 07/09/21 Page 128 of 143 Page ID
#:10167
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601 [1] 3/8
61 [1] 4/7
633 [1] 2/14
651 [1] 3/21
67 [1] 4/8
68 [1] 32/25
69 [1] 4/9
696119 [1] 63/14
6A [2] 4/21 15/24
6Y [2] 4/21 15/24
7
72 [1] 34/5
720 [1] 3/8
75 [1] 94/25
753 [1] 127/4
76 [2] 4/10 95/12
8
803 [6] 69/5 69/5 93/14
93/14 118/14 118/14
81 [1] 4/11
81-5450370 [1] 121/13
82-5088385 [2] 97/25 121/5
83 [3] 4/22 16/2 16/4
84-2698846 [1] 120/10
85-0925228 [1] 120/20
85-2214789 [4] 94/6 94/18
95/2 95/16
8649260 [1] 97/19
87 [2] 93/20 103/24
89 [1] 4/12
8th [2] 47/9 49/8
9
90 [1] 4/13
90012 [2] 1/23 2/7
90067 [1] 3/16
90071 [2] 2/15 3/9
90211 [2] 14/18 19/23
90277 [1] 3/21
903 [1] 3/5
91208 [1] 3/13
91344 [1] 61/11
92 [1] 4/24
92673 [1] 3/6
940 [10] 83/25 84/1 84/2
87/8 87/19 87/23 89/23 95/3
95/3 95/5
940's [3] 84/8 109/17 109/25
941 [3] 84/6 95/16 109/9
941's [1] 84/15
94105 [1] 2/21
97 [1] 4/24
98 [1] 4/14
9858 [2] 1/21 127/12
9:00 [1] 5/2
9:00 o'clock [3] 5/12 6/6
6/14
9C [1] 119/11
9th [1] 73/3
A
A-L-E-X-A-N-D-E-R [1] 106/2
a.m [3] 1/16 5/2 67/11
A6001420 [1] 73/22
A8002470 [1] 74/15
abbreviations [1] 21/14
able [9] 22/13 45/22 53/3
54/2 78/9 79/23 123/15 126/6
126/9
about [54] 9/24 10/20 11/21
12/17 13/4 13/19 14/3 19/2
20/21 32/6 42/15 42/18 42/24
44/10 47/25 50/6 50/10 51/13
52/10 57/6 61/22 62/10 63/17
63/20 63/22 66/17 74/6 74/14
74/22 76/15 78/12 84/25
86/13 97/9 97/17 99/16 99/19
101/12 102/22 107/11 107/12
107/13 110/12 111/2 111/11
111/13 112/17 112/24 113/18
114/11 118/21 122/4 123/21
125/22
above [1] 127/7
above-entitled [1] 127/7
access [4] 45/9 70/19 92/3
92/4
account [18] 10/2 35/4 44/21
45/1 45/4 46/4 64/18 65/8
65/12 88/6 88/13 88/16 88/20
91/6 92/11 97/22 107/6
118/22
accountant [1] 108/9
accounting [3] 106/13 107/5
117/4
accounts [4] 7/16 45/11
45/18 45/21
accuracy [2] 23/18 36/21
accurate [3] 42/20 111/12
118/10
ACES [5] 117/4 122/5 122/7
122/21 123/16
act [11] 10/12 10/25 11/13
17/14 17/17 27/15 39/3 39/11
39/17 39/21 40/11
acting [1] 52/11
action [1] 46/18
actual [2] 30/24 55/23
actually [5] 12/15 44/19
48/25 55/20 112/1
addition [4] 29/12 107/5
107/21 120/8
additional [6] 29/19 29/19
34/18 36/20 50/20 57/12
address [15] 63/20 63/22
64/8 64/13 66/7 66/17 66/17
66/18 111/21 111/22 111/23
111/24 112/1 112/3 117/8
addresses [1] 9/25
administers [2] 116/17
116/19
Administration [2] 16/25
49/6
admit [3] 69/4 93/14 118/13
admitted [6] 19/23 62/13
71/6 83/21 86/5 108/19
ADP [1] 109/23
advance [7] 20/19 29/16 30/1
32/19 33/4 33/18 103/16
advice [1] 108/8
advising [1] 35/3
affect [1] 34/22
after [11] 6/7 6/8 18/6 20/8
23/4 34/25 35/2 40/11 74/12
126/16 126/16
again [10] 11/8 11/18 12/1
12/25 13/1 63/8 72/20 75/1
94/15 124/18
against [1] 79/5
ago [4] 7/12 61/22 84/10
84/12
agree [1] 99/7
agreement [3] 5/15 5/25
35/13
agriculture [1] 27/20
ahead [13] 8/9 15/8 15/15
26/3 32/21 33/1 35/8 36/17
49/22 52/4 83/19 86/3 88/4
AHN [3] 2/5 4/4 16/15
al [1] 1/9
ALEXANDER [6] 4/15 105/20
106/1 110/22 111/7 113/6
alive [1] 14/6
all [55] 6/20 7/18 9/15
11/12 11/17 11/18 11/20
12/18 13/5 13/22 14/2 14/24
15/3 15/18 15/19 15/20 15/22
15/23 19/24 25/3 25/13 26/13
26/16 33/1 48/4 48/22 56/3
61/12 63/23 63/24 64/24 65/5
65/23 66/20 83/13 83/16 84/7
86/8 87/5 87/6 87/25 88/10
90/5 93/25 95/20 95/22 96/3
96/22 106/20 108/10 108/20
111/5 112/4 112/11 126/8
alleviate [1] 36/1
allow [1] 72/4
allowed [1] 23/12
allows [3] 27/14 72/2 107/23
Allstate [2] 7/14 7/16
almost [4] 17/4 39/2 49/16
56/17
Alpha [1] 3/12
already [1] 45/10
also [51] 9/20 10/1 18/3
19/13 21/1 21/9 21/21 24/8
24/8 24/18 27/20 29/10 29/16
33/14 36/4 36/12 36/23 40/2
41/21 41/24 58/21 59/22
69/19 70/4 72/10 72/13 72/17
72/18 72/21 73/1 73/5 73/6
73/21 74/20 77/10 78/12
78/21 97/17 97/24 105/3
111/21 114/11 114/16 116/7
116/18 120/9 121/4 121/12
121/18 123/3 123/11
Always [1] 61/24
am [35] 5/25 7/5 9/11 9/11
12/12 14/5 14/10 26/11 34/14
35/8 38/2 50/15 52/10 57/4
61/16 62/13 69/18 70/9 73/8
81/17 83/11 83/22 85/22
88/10 91/1 91/23 103/12
106/11 108/19 116/8 116/25
117/2 117/22 125/11 126/15
Amanecer [1] 3/5
America [5] 1/6 2/3 64/21
88/9 88/20
Americas [1] 2/17
amount [7] 25/15 31/25 32/5
32/9 33/20 48/16 109/6
ANGELES [7] 1/14 1/23 2/7
2/15 3/9 3/16 5/1
Anna [8] 74/14 75/6 75/12
78/13 78/17 112/21 112/22
114/13
annual [2] 84/2 95/4
annually [1] 109/1
another [6] 7/21 8/6 9/7
16/7 51/4 112/5
answer [11] 33/13 46/1 57/10
68/16 68/18 96/1 101/7 101/9
104/3 104/4 122/16
answered [4] 40/22 41/16
57/9 126/4
Anthony [1] 61/1
anticipate [1] 9/7
anticipated [1] 9/2
Anton [10] 73/21 74/6 74/13
77/11 110/4 110/7 110/7
110/10 110/23 113/19
any [46] 7/23 7/25 8/3 9/8
10/4 12/13 12/14 14/3 15/4
19/5 29/5 38/15 40/4 40/7
46/24 47/24 49/20 60/14
61/25 63/4 68/6 76/19 78/18
79/5 79/8 79/20 81/23 81/25
83/13 85/23 101/1 102/1
103/2 104/12 106/14 107/4
108/10 112/2 114/24 119/17
120/14 120/14 120/24 124/4
124/8 124/16
anybody [1] 84/23
anyone [15] 5/16 8/2 62/24
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A
anyone... [12] 65/11 65/18
65/20 80/4 81/18 82/3 87/2
87/22 88/19 110/10 113/9
122/23
anything [9] 29/22 46/3 52/1
61/12 61/15 81/7 90/3 106/10
108/13
anywhere [1] 64/22
apologize [2] 26/14 78/5
appear [2] 49/2 118/7
APPEARANCES [2] 2/1 3/1
appears [3] 49/4 49/12 49/17
applicable [1] 20/20
applicant [13] 18/20 21/4
21/13 22/8 22/12 28/13 31/4
32/19 33/3 33/7 37/10 42/12
56/1
applicants [2] 41/12 41/25
application [59] 9/19 9/21
9/21 11/4 18/10 18/19 18/21
18/22 18/25 19/3 19/13 19/15
20/4 22/10 23/10 28/10 29/17
29/20 30/6 30/10 30/23 30/24
30/25 31/1 33/19 34/22 34/25
37/3 42/7 42/9 43/17 45/19
52/22 52/24 52/25 53/2 53/2
53/24 54/7 54/10 54/19 55/6
55/7 55/11 55/24 60/7 62/22
62/25 67/25 68/3 68/8 85/21
87/3 108/16 113/19 114/6
114/12 114/17 114/21
applications [16] 7/24 18/12
18/14 40/12 40/20 41/2 41/6
42/19 43/14 53/9 53/13 53/16
55/16 70/1 89/8 89/16
applied [4] 8/19 54/16 62/11
67/20
apply [13] 8/22 18/7 19/10
28/14 29/18 29/25 30/2 59/14
59/20 83/14 104/14 108/11
108/18
applying [4] 13/2 19/9 21/22
104/13
appreciate [1] 6/18
approach [4] 54/4 58/12
104/6 105/17
appropriate [1] 6/3
approval [1] 28/17
approvals [1] 49/8
approve [5] 32/7 37/12 38/7
42/19 43/2
approved [7] 28/17 34/25
35/2 42/22 42/25 43/7 43/11
approving [1] 38/4
approximately [3] 82/11
82/14 93/20
April [4] 41/15 42/7 74/23
75/16
April 23rd [1] 75/16
April 25th [1] 74/23
are [129]
argue [1] 13/8
argument [2] 13/14 13/15
around [3] 40/8 47/9 64/9
ARTUR [13] 3/11 5/19 7/2 7/5
7/6 7/12 7/14 7/20 7/22 7/23
7/25 8/2 50/5
as [88]
Ashwin [1] 2/13
aside [1] 13/18
ask [30] 20/9 20/15 20/21
21/1 21/9 21/12 21/21 22/5
23/23 24/1 31/8 31/22 33/3
33/14 34/14 38/12 38/13
44/10 45/15 46/5 47/12 50/6
53/18 89/14 97/8 99/6 101/22
108/13 114/2 124/22
asked [42] 32/19 40/22 41/16
41/21 41/24 42/2 42/9 51/13
57/8 76/11 76/19 78/17 78/20
79/4 79/8 83/13 92/18 99/25
100/3 101/1 101/7 101/13
101/17 102/2 102/13 105/7
108/10 113/18 114/11 117/18
117/21 122/15 124/3 124/13
124/15 125/3 125/8 125/13
125/22 126/1 126/4 126/6
asking [7] 11/17 12/23 14/5
14/11 14/12 22/8 122/22
asks [1] 43/24
assist [5] 17/2 70/5 70/6
83/14 108/11
assistance [8] 17/19 22/18
22/21 25/5 25/25 27/5 28/25
29/19
Assistant [3] 100/5 100/9
100/17
assists [1] 17/14
associated [5] 30/6 100/11
100/21 102/3 118/24
assume [1] 48/18
attach [1] 55/18
attached [4] 55/5 55/6 55/8
55/10
attention [18] 10/8 10/14
10/23 11/12 11/18 12/24
13/20 13/22 14/6 24/23 62/16
64/1 83/22 86/8 87/5 94/1
94/25 108/21
attorney [5] 56/25 100/5
100/9 100/18 123/25
attorney's [5] 2/4 92/18
117/18 124/1 125/5
audit [1] 116/7
auditor [3] 115/22 116/3
116/6
August [3] 47/9 48/3 49/8
August 8th [2] 47/9 49/8
AUSA [2] 2/5 2/5
authority [1] 39/14
authorization [2] 19/6 35/13
authorize [6] 62/24 65/11
87/2 87/22 88/19 113/9
authorized [13] 19/11 23/13
30/4 32/12 37/1 55/1 55/16
55/23 56/2 56/10 56/11 57/5
58/24
Auto [4] 110/15 110/17
110/25 121/12
available [4] 25/15 40/13
40/21 41/3
Avakyan [1] 75/14
Avenue [3] 2/10 2/17 2/23
average [3] 20/10 20/12
20/22
aware [4] 18/10 59/12 59/18
85/22
away [2] 10/19 11/21
Ayvazian [12] 5/20 7/2 7/5
7/6 7/12 7/14 7/21 7/22 7/23
7/25 8/2 50/6
Ayvazyan [3] 1/9 2/12 3/11
B
B-E-N-J-A-M-I-N [1] 106/2
B-R-E-A-N-N-A [1] 69/10
B66244 [1] 71/18
back [11] 10/10 46/8 52/17
63/7 75/19 78/25 84/17
105/18 110/3 119/13 126/16
bank [18] 7/16 10/2 10/16
10/16 44/20 44/21 44/22
44/25 46/4 64/18 64/20 64/21
64/22 65/11 88/6 88/8 88/9
88/20
banks [3] 44/16 52/11 52/13
base [1] 111/25
based [6] 18/9 22/4 29/23
44/8 71/4 79/25
Bates [1] 104/5
be [82]
Beach [1] 3/21
bearing [1] 68/16
became [1] 40/20
because [13] 6/2 9/11 11/4
11/12 13/12 27/7 27/12 32/16
51/12 55/4 79/21 99/12
119/25
become [2] 40/12 41/2
been [22] 14/18 35/6 38/25
56/16 56/21 56/24 57/8 61/24
62/13 67/20 69/20 69/21 71/6
83/21 89/16 89/21 91/13
91/14 91/15 113/24 114/4
114/17
before [12] 14/16 14/24 15/3
33/23 66/24 85/4 86/6 89/20
91/17 102/24 114/3 114/17
began [1] 50/9
begin [3] 5/11 6/20 25/6
behalf [13] 2/3 5/17 8/11
11/4 13/16 19/10 29/25 30/2
63/2 87/3 87/19 87/23 113/10
being [10] 6/18 12/23 24/3
60/15 80/6 90/7 91/17 102/18
104/12 126/12
believe [9] 12/13 30/14
31/15 39/1 42/18 47/8 51/9
54/13 123/25
belong [6] 73/19 74/13 75/5
75/12 75/13 76/25
belonged [8] 75/20 77/1
77/20 77/24 78/2 79/12 79/16
79/20
belonging [2] 79/6 79/9
belongs [2] 73/20 77/7
below [1] 34/15
Benjamin [1] 106/1
better [1] 89/14
between [12] 15/18 15/19
15/20 15/21 15/23 15/25 46/6
122/11 122/19 122/24 125/3
126/2
beyond [4] 10/9 10/11 10/12
14/8
Bienert [2] 3/4 3/7
big [2] 10/8 10/13
billion [1] 49/16
bills [3] 51/15 51/19 51/20
birth [26] 64/14 70/15 71/8
71/13 71/19 72/1 72/3 72/9
72/14 72/20 73/2 73/11 73/17
73/22 74/1 74/7 74/10 74/15
74/23 75/2 75/7 75/15 75/20
77/15 78/6 78/9
birthday [2] 73/13 80/2
bit [2] 46/6 91/8
blank [1] 20/11
blow [1] 65/3
blown [2] 57/18 57/18
blue [1] 7/7
bookkeeping [2] 106/17 107/6
borrower [6] 18/6 44/18
44/19 45/4 45/7 45/21
borrower's [3] 44/21 45/1
45/3
borrowers [2] 45/10 45/18
both [1] 109/13
bottom [11] 58/9 63/25 64/1
65/23 65/25 85/8 86/14 86/14
87/14 111/5 113/4
Boulevard [1] 3/15
box [9] 20/10 20/11 21/13
33/7 33/8 33/9 33/10 34/12
34/13
Case 2:20-cr-00579-SVW Document 672 Filed 07/09/21 Page 130 of 143 Page ID
#:10169
B
breach [1] 79/21
break [3] 6/1 66/24 67/1
BREANNA [2] 4/9 69/9
Brianna [1] 68/22
briefly [2] 5/22 11/23
broadened [2] 27/15 27/20
BSBA's [1] 38/4
bullet [2] 24/17 24/22
burden [1] 10/9
business [95]
business' [3] 33/17 46/11
65/14
businesses [23] 17/2 17/14
17/20 19/9 22/22 24/9 26/1
27/22 27/23 29/3 29/7 29/13
39/25 40/2 40/6 52/13 59/19
84/13 107/15 118/24 119/15
119/18 122/8
C
C8924483 [1] 72/14
CA [9] 1/23 2/7 2/15 2/21
3/6 3/9 3/13 3/16 3/21
calculate [3] 32/4 59/5
109/6
calculating [1] 59/4
calculation [5] 20/13 20/17
59/9 59/11 59/12
calculations [2] 58/22 58/25
CALIFORNIA [8] 1/2 1/14 5/1
81/6 106/9 115/20 116/14
122/8
call [7] 14/15 16/11 20/19
68/20 80/10 90/9 105/16
Calle [1] 3/5
called [10] 14/17 14/25 15/7
29/16 85/16 92/3 100/22
103/3 107/22 122/4
calls [7] 45/12 60/18 68/21
80/11 90/10 105/20 115/3
came [2] 73/12 78/24
can [94]
can't [14] 9/1 12/9 12/10
15/1 46/3 77/3 77/23 78/1
79/11 79/15 79/19 86/19
103/15 103/21
cannot [3] 27/7 32/16 77/9
capital [3] 27/5 32/15 36/1
captured [1] 123/15
cards [1] 12/2
CARES [9] 17/13 17/16 27/15
39/3 39/11 39/17 39/21 40/11
51/17
case [11] 10/7 10/15 10/16
11/2 11/8 11/17 13/10 53/18
68/16 92/20 117/20
CATHERINE [1] 2/5
caused [1] 36/1
Center [1] 28/7
CENTRAL [1] 1/2
CEO [1] 86/15
certain [8] 14/18 18/6 18/7
27/16 32/12 55/10 76/11
122/20
certainly [1] 59/11
certificate [4] 94/4 94/21
99/24 127/1
certificates [1] 93/18
certification [10] 19/23
23/17 24/14 24/18 24/24 34/1
34/7 34/9 34/18 93/7
certifications [11] 14/19
22/5 22/7 22/24 23/7 33/23
33/24 34/19 36/12 36/20 93/8
certified [1] 118/4
certify [3] 22/8 91/5 127/4
changed [1] 42/5
check [15] 26/6 33/7 33/10
34/12 47/11 72/17 72/18
73/25 74/1 74/9 74/10 74/17
74/18 75/8 75/9
checked [3] 33/7 33/8 34/13
children [1] 7/8
Christopher [1] 2/9
city [1] 106/8
civil [1] 46/20
clarification [1] 12/12
clarify [4] 37/25 46/6 51/12
55/22
Clark [2] 15/10 15/12
clear [6] 21/11 26/3 32/21
35/8 36/17 56/6
Clemente [1] 3/6
click [1] 28/14
client [12] 8/11 13/16 83/8
84/21 85/2 86/24 107/21
109/19 110/8 110/15 112/22
112/25
clientele [1] 83/6
clients [26] 82/6 82/11
82/14 82/17 82/22 82/25 83/3
83/6 83/13 84/8 106/18
106/20 107/2 107/9 107/14
107/17 107/24 108/1 108/8
108/10 108/15 108/17 109/16
109/24 111/24 112/3
clock [1] 126/15
close [2] 13/19 35/15
closed [1] 29/5
closing [4] 22/21 28/18 35/3
35/5
Clovis [1] 81/6
Coast [1] 3/20
Code [2] 36/6 127/5
coins [1] 14/1
collar [1] 7/7
collateral [3] 36/7 36/7
46/15
Colorado [2] 28/7 28/8
column [11] 118/18 118/19
118/20 118/22 118/23 119/1
119/1 119/2 119/3 119/4
119/20
columns [2] 118/25 119/3
come [6] 9/18 68/24 73/11
75/19 78/8 126/16
comes [4] 12/15 14/7 72/3
123/6
comfortable [1] 80/16
coming [5] 10/1 11/13 29/5
113/17 122/3
comment [1] 5/10
Commercial [1] 36/6
commissioner [1] 91/3
commissions [1] 58/15
companies [15] 93/22 95/21
96/4 96/10 97/9 118/7 120/3
120/21 121/7 121/15 122/11
122/20 122/25 125/4 126/3
company [40] 54/14 61/17
61/19 61/21 61/23 62/19 63/2
81/10 81/12 81/14 81/16
81/19 84/25 85/4 85/16 87/10
87/20 87/23 88/14 88/21 94/3
94/5 95/1 96/23 97/25 102/13
102/18 103/3 104/13 109/12
110/12 110/13 110/17 112/24
112/25 114/4 114/13 121/5
121/8 121/21
company's [6] 67/21 68/4
68/8 89/15 89/21 113/24
compensation [1] 58/16
complaints [1] 70/5
complete [2] 6/22 44/4
completed [2] 35/6 56/10
complex [4] 59/8 59/10 70/2
70/3
Compliance [1] 117/5
compliant [1] 106/25
concealed [1] 7/25
concealment [1] 10/4
concluded [1] 126/19
conclusion [3] 24/3 48/7
49/15
conditions [1] 35/14
conduct [7] 92/14 92/19
116/6 117/13 117/19 123/20
124/4
conducted [2] 96/3 124/19
Conference [1] 127/9
confirm [1] 79/23
conformance [1] 127/8
connected [1] 14/3
Connecticut [1] 2/23
consist [2] 57/25 58/1
conspired [1] 8/2
Construction [3] 97/17 97/18
120/10
consumer [1] 39/7
Cont'd [1] 3/1
contacted [3] 67/21 89/19
89/20
contain [2] 36/12 36/20
content [1] 20/1
contents [2] 46/17 46/18
context [1] 10/15
continue [3] 6/23 29/6 75/6
continuing [1] 36/3
contracting [12] 61/20 62/3
62/6 62/21 63/12 64/18 65/6
65/9 65/21 97/24 98/7 121/4
contractor [2] 58/14 61/16
contractors [2] 27/19 105/4
convinced [1] 8/21
coordinator [3] 91/1 91/2
91/18
copies [1] 91/5
copy [2] 118/10 124/21
corporate [2] 57/6 94/8
corporation [2] 56/11 82/8
corporations [5] 27/18 82/19
84/13 94/10 123/2
correct [112]
correctly [1] 44/14
could [27] 17/16 17/19 21/15
24/8 25/7 25/10 26/6 26/6
32/6 34/5 35/9 46/16 46/17
46/22 46/24 47/1 48/23 49/13
51/4 51/4 51/9 60/1 79/22
91/7 99/4 114/1 122/25
couldn't [3] 77/5 77/6
102/20
counsel [7] 2/1 5/9 6/18
47/15 47/16 60/14 104/1
couple [1] 65/24
course [7] 71/1 84/7 91/24
92/6 93/9 96/25 101/24
court [9] 1/1 1/21 6/18 15/2
24/2 91/1 91/2 91/17 116/9
courthouse [1] 123/22
courtroom [5] 15/5 38/13
38/14 38/16 48/25
cousin [2] 8/20 8/20
Covid [4] 17/15 27/9 27/12
27/17
Covid-19 [2] 27/9 27/17
CPA [1] 106/11
CR [1] 1/8
crashed [1] 39/7
created [2] 89/23 114/21
credit [2] 12/2 45/1
credited [1] 45/3
criminal [1] 11/17
cross [40] 4/5 4/5 4/6 4/8
4/10 4/12 4/14 4/14 4/16
Case 2:20-cr-00579-SVW Document 672 Filed 07/09/21 Page 131 of 143 Page ID
#:10170
C
cross... [31] 4/18 38/11
38/19 49/20 50/1 52/6 66/22
66/24 66/25 67/5 67/14 67/16
76/2 76/4 78/17 79/5 79/8
88/25 89/3 98/10 98/12 101/1
101/13 101/17 101/21 102/9
113/13 113/15 114/24 121/24
122/1
cross-examination [31] 4/5
4/5 4/6 4/8 4/10 4/12 4/14
4/14 4/16 4/18 38/11 38/19
49/20 50/1 52/6 66/22 66/24
67/14 67/16 76/2 76/4 88/25
89/3 98/10 98/12 102/9
113/13 113/15 114/24 121/24
122/1
cross-examine [1] 66/25
cross-reference [7] 78/17
79/5 79/8 101/1 101/13
101/17 101/21
CRR [1] 127/12
Cruz [3] 92/23 96/13 117/22
CSR [2] 1/21 127/12
currently [6] 61/8 61/10
81/5 81/21 84/9 84/9
custodian [2] 91/4 116/10
customer [4] 70/4 70/4 72/8
91/19
customer's [1] 71/22
D
D3257870 [1] 73/2
D36423006 [1] 75/15
D6343561 [1] 74/7
DADYAN [29] 3/18 5/18 8/13
8/15 8/16 8/20 9/22 9/23
10/2 10/4 10/18 11/3 11/14
13/2 13/8 13/11 13/24 13/25
14/1 14/4 54/16 77/8 78/4
79/9 79/17 101/19 102/2
105/9 124/17
data [4] 30/23 30/24 31/1
92/4
database [13] 70/17 70/19
70/22 71/2 71/24 76/13 93/11
97/3 117/19 118/7 122/4
122/21 123/16
date [32] 24/24 25/1 25/3
25/4 31/24 43/24 47/11 48/2
64/14 71/19 72/2 72/3 72/9
72/14 72/21 73/2 73/12 73/17
73/22 74/1 74/7 74/10 74/15
74/23 75/2 75/7 75/15 75/20
77/15 78/6 78/9 127/10
dates [3] 70/15 71/8 71/12
day [7] 1/15 6/21 11/10
42/23 43/1 43/4 43/8
DC [2] 2/10 2/23
DE9 [7] 119/4 119/16 120/10
120/20 121/5 121/13 121/19
DE9C [9] 119/5 119/16 120/10
120/20 120/25 121/5 121/13
121/19 123/6
DE9D [1] 120/25
dealt [1] 50/10
decision [4] 34/23 37/12
38/4 38/7
declared [1] 27/12
DEFENDANT [5] 1/9 2/12 3/3
3/11 3/18
Defendant's [1] 48/23
defendants [1] 68/6
defense [3] 9/8 47/13 48/20
definitely [1] 83/4
definition [4] 53/23 58/4
58/6 59/22
delay [1] 6/5
delegated [1] 39/14
Denver [1] 28/7
department [10] 2/4 2/9
69/16 115/19 115/23 116/9
116/14 116/16 116/17 119/17
depend [1] 60/10
depth [1] 56/15
describe [10] 18/18 20/5
27/3 27/11 28/12 29/15 35/18
95/12 107/19 117/6
described [1] 35/24
description [2] 94/1 95/13
designee [3] 85/13 110/23
110/25
designee's [1] 110/20
details [1] 83/12
determination [1] 28/17
determine [6] 76/12 101/2
101/14 101/18 102/3 103/24
determined [4] 76/22 77/17
77/20 79/2
Development [4] 115/19
116/13 116/16 116/17
diamonds [2] 14/2 97/12
did [101]
didn't [17] 7/7 11/4 12/12
12/14 26/14 48/11 53/15 62/4
76/19 76/25 95/25 114/5
114/16 119/17 120/14 120/14
120/24
difference [2] 46/6 46/7
differences [1] 42/13
different [5] 45/16 73/13
73/13 98/4 114/2
difficult [1] 45/7
diligence [3] 43/20 44/4
44/8
direct [20] 4/4 4/7 4/9 4/11
4/13 4/16 4/18 16/14 20/8
20/9 34/11 52/23 61/4 69/13
81/1 83/22 90/19 94/25 106/4
115/14
directing [6] 24/23 62/16
64/1 86/8 94/1 108/20
directly [4] 27/14 44/15
44/17 115/9
disability [1] 116/18
disaster [14] 20/19 26/19
27/7 27/12 27/13 27/18 28/15
29/18 30/10 31/24 32/17 36/2
51/10 51/10
disburse [2] 35/6 35/15
disbursed [3] 28/19 44/15
44/17
discuss [2] 47/6 89/9
discussed [5] 39/24 120/9
120/21 121/6 121/14
display [3] 47/12 47/18
92/23
displayed [2] 21/24 22/1
dispute [2] 47/25 48/1
disputing [1] 10/25
distributed [1] 27/8
DISTRICT [3] 1/1 1/2 1/4
DIVISION [1] 1/2
DMV [9] 69/17 69/18 70/8
70/10 70/12 70/15 71/2 76/8
76/9
do [170]
DOB [1] 71/24
document [20] 36/6 50/9 58/3
65/4 83/23 84/17 86/4 86/6
88/11 92/25 93/2 95/14
108/22 110/3 112/12 117/25
118/4 118/4 118/8 118/10
documentation [5] 18/24
24/19 28/20 29/7 108/18
documents [12] 10/23 28/19
35/4 35/5 55/4 55/8 55/10
55/13 55/18 94/7 96/15 105/7
does [64]
doesn't [5] 7/11 46/19 58/1
74/4 99/3
doing [1] 91/13
don't [39] 5/12 5/14 6/4
9/10 13/17 29/3 29/5 37/21
40/4 40/7 41/4 41/8 41/10
44/6 45/9 55/8 55/19 57/14
57/15 57/16 57/16 57/20
57/21 58/13 59/10 66/24
67/24 68/2 68/5 68/6 68/24
78/6 78/10 83/11 89/13 89/23
94/14 103/9 114/20
done [2] 67/6 117/12
doors [1] 22/21
doubt [4] 10/10 10/12 10/13
14/9
down [7] 58/9 85/6 87/13
107/8 110/19 111/5 112/9
driver [5] 7/7 10/19 10/19
11/21 11/22
driver's [31] 64/5 64/15
64/16 64/16 69/25 70/12 71/8
71/11 71/18 72/1 72/5 72/10
72/14 72/22 73/2 73/16 73/22
74/2 74/6 74/11 74/14 74/19
74/22 75/3 75/6 75/12 75/15
75/20 76/9 78/13 79/25
drop [2] 80/15 80/17
due [3] 43/20 44/4 44/8
during [5] 17/15 17/18 25/21
28/22 52/23
duties [3] 17/5 69/24 71/1
duty [1] 9/5
Dzukaeva [4] 74/14 112/22
112/22 114/13
E
e-mail [3] 35/2 63/20 63/22
each [4] 83/2 93/22 107/25
123/8
earlier [6] 23/17 26/20 29/9
53/11 53/12 112/17
early [1] 7/10
earnings [1] 58/15
economic [10] 20/19 26/19
27/6 28/14 29/18 36/1 42/24
51/9 51/10 57/1
economy [2] 39/12 39/18
EDD [16] 115/19 116/2 116/10
116/12 116/12 116/13 116/20
116/21 117/10 117/19 118/3
118/4 118/5 122/7 122/10
122/19
effect [1] 51/17
efficient [1] 6/22
effort [1] 6/19
EIDL [28] 20/18 20/21 26/19
27/1 27/3 27/8 27/17 27/24
28/10 28/20 29/10 29/12
29/16 29/25 32/1 32/12 33/23
34/25 37/15 37/18 37/20 40/5
43/7 44/11 44/12 44/15 46/6
46/7
eight [2] 53/4 60/1
EIN [19] 21/14 21/16 63/9
63/10 63/12 97/12 97/16
97/18 97/22 97/25 98/6 98/22
98/25 99/3 99/11 120/10
120/20 121/5 121/13
EIN's [4] 93/22 97/9 118/7
120/3
either [1] 55/24
eligibility [1] 33/17
eligible [14] 19/9 20/6
20/24 25/5 27/16 27/22 29/25
30/2 32/1 32/4 32/10 37/15
37/17 37/20
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else [14] 64/22 70/6 73/19
73/20 77/1 77/4 77/21 79/12
79/16 80/4 82/3 90/3 113/9
116/4
else's [1] 13/3
employ [1] 19/5
employed [5] 16/22 17/15
22/20 52/21 52/22
employee [7] 33/21 65/21
94/6 106/15 106/16 123/6
123/13
employee's [1] 123/8
employees [23] 17/15 17/20
21/2 21/4 21/7 29/24 33/15
33/20 33/22 37/17 37/18
37/19 37/19 38/3 52/21 52/22
61/25 81/23 81/25 106/14
109/12 119/7 122/22
employer [11] 21/17 63/15
95/15 96/4 97/15 98/3 98/18
98/21 109/3 118/21 119/9
employer's [2] 95/4 95/17
employment [9] 58/15 61/13
61/15 81/7 106/10 115/19
116/13 116/15 116/17
end [11] 10/5 10/18 11/10
11/11 11/24 14/12 25/23
34/15 44/22 47/9 49/11
ending [1] 95/18
English [2] 11/5 60/4
enough [2] 78/12 125/1
ensure [1] 22/22
enter [1] 31/1
Enterprise [1] 117/5
enterprises [1] 27/21
entire [2] 48/24 107/21
entitled [1] 127/7
equals [1] 20/20
essentially [1] 46/19
established [3] 7/13 7/15
17/13
et [1] 1/9
evaluate [1] 12/20
even [4] 7/11 12/3 26/1
46/22
evening [1] 5/23
ever [14] 41/19 62/11 63/4
65/8 65/20 81/25 85/4 85/13
85/20 85/23 86/5 87/2 87/19
88/19
every [4] 6/21 117/9 119/6
119/8
everybody [1] 47/15
Everything [1] 12/15
EVID [1] 4/20
evidence [53] 7/19 7/20 7/21
7/23 7/24 8/1 8/23 9/3 9/6
9/10 9/12 9/17 9/18 9/20
10/1 10/2 11/7 11/12 11/13
11/23 11/25 12/2 12/8 12/12
12/13 12/14 12/15 12/17
12/22 12/25 13/1 13/2 13/5
13/6 13/16 13/17 14/1 14/2
14/6 14/13 14/17 15/17 15/19
16/5 24/4 24/4 48/20 69/5
93/14 97/6 100/14 100/23
118/14
evident [1] 126/8
exact [1] 109/6
examination [46] 4/4 4/5 4/5
4/6 4/7 4/8 4/9 4/10 4/11
4/12 4/13 4/14 4/14 4/16
4/16 4/18 4/18 16/14 38/11
38/19 49/20 50/1 52/6 52/23
61/4 66/22 66/24 67/14 67/16
69/13 76/2 76/4 81/1 88/25
89/3 90/19 98/10 98/12 102/9
106/4 113/13 113/15 114/24
115/14 121/24 122/1
examine [1] 66/25
example [2] 99/7 111/13
except [1] 83/7
exclude [1] 14/24
excluded [1] 15/3
excuse [6] 39/22 43/3 44/16
47/7 78/4 100/13
excused [5] 80/9 90/8 105/14
115/1 126/13
exhausted [3] 11/9 11/9
11/19
exhausting [1] 11/8
exhibit [65]
exhibits [13] 15/17 15/20
15/21 15/21 15/22 15/23
15/24 16/1 16/1 16/2 53/19
53/21 125/10
exist [3] 25/9 25/13 122/11
existed [1] 42/13
exit [2] 34/14 37/3
expect [2] 109/13 119/10
expected [3] 58/17 58/21
60/1
expense [1] 31/22
expenses [15] 31/9 32/7
36/10 37/11 51/20 51/21 82/7
104/25 105/4 119/10 120/5
120/16 121/1 121/10 121/20
expensive [1] 14/1
experience [3] 18/9 22/4
39/3
expertise [1] 70/1
expired [3] 47/22 75/22
75/23
explain [3] 17/16 18/5 46/13
extent [1] 43/18
F
F-A-R-D [1] 106/2
F-I-T-Z-G-E-R-A-L-D [1]
69/11
facing [1] 39/5
fact [10] 14/24 15/9 25/21
37/19 46/10 79/19 96/20
96/21 96/24 125/12
fact-of-filing [3] 96/20
96/21 96/24
facts [2] 8/25 9/2
fail [1] 29/3
failed [1] 44/3
fails [1] 43/20
fair [15] 40/20 41/2 41/14
49/15 57/20 62/2 62/5 78/12
113/23 114/2 114/8 114/20
124/12 125/1 125/25
fake [2] 7/22 54/14
false [3] 7/24 32/6 34/21
falsely [1] 38/3
familiar [20] 17/10 19/19
26/20 28/10 30/11 52/23 53/6
56/18 56/21 57/2 57/4 62/8
70/7 83/9 83/11 83/24 91/22
108/3 108/6 116/24
family [2] 7/6 7/8
far [4] 12/14 50/18 78/8
119/19
FARD [10] 4/15 105/20 106/1
106/6 106/13 110/22 111/7
113/6 113/17 114/23
Fargo [3] 10/3 65/9 65/14
Farms [3] 112/25 113/2
114/14
fast [1] 40/8
father [1] 8/16
father's [2] 66/7 66/18
February [1] 25/2
February 15th [1] 25/2
federal [12] 27/25 69/5 84/2
93/14 95/4 95/17 117/9 117/9
117/10 118/14 118/23 119/16
fee [2] 19/7 36/4
feel [1] 80/15
FEIN [1] 118/21
Fenton [8] 2/9 4/7 4/11 4/16
61/5 80/14 81/2 106/5
few [3] 38/12 44/10 50/6
Fictitious [1] 13/3
field [2] 33/12 33/13
figure [4] 11/20 59/5 59/14
59/19
file [13] 36/7 46/20 83/23
92/3 98/19 98/23 99/11 99/17
102/4 112/2 119/7 119/7
119/8
filed [11] 7/23 82/9 95/19
95/23 99/8 104/12 109/1
113/19 116/20 119/16 121/9
files [1] 14/22
filing [4] 96/20 96/21 96/24
119/25
filings [10] 84/5 92/10
96/22 109/8 109/20 117/10
120/10 120/20 121/6 121/14
fill [7] 8/22 20/12 51/4
55/1 56/8 58/18 58/21
filled [3] 8/17 9/19 53/3
Final [1] 60/6
Finance [1] 28/7
find [10] 13/5 14/11 76/19
76/21 89/12 119/17 120/14
120/14 120/24 122/24
first [23] 14/15 14/16 24/23
25/23 47/21 48/7 66/12 71/25
72/2 72/3 72/20 74/18 75/1
78/8 95/18 107/20 109/4
112/15 118/18 120/1 120/1
120/11 122/15
FITZGERALD [6] 4/9 68/22
69/10 69/15 76/6 80/3
five [4] 41/15 67/5 84/12
116/8
Floor [1] 2/6
flow [1] 107/22
flying [1] 11/11
focus [3] 20/22 44/12 57/1
focusing [1] 56/24
folder [1] 105/18
following [3] 5/6 6/15 67/12
font [1] 30/17
foreclose [2] 46/22 46/25
foregoing [1] 127/5
forgivable [2] 18/3 47/3
forgiven [1] 18/8
forgiveness [1] 44/1
form [77]
format [1] 127/8
forms [15] 55/1 84/11 89/23
98/23 104/11 104/12 106/24
109/14 109/17 113/24 114/4
114/9 114/21 119/8 121/9
forward [6] 14/13 60/22
80/12 90/12 105/21 115/5
found [7] 76/12 94/22 95/11
100/11 100/20 119/14 121/8
foundation [10] 39/19 45/13
45/25 59/16 99/14 101/5
102/19 122/13 123/17 125/6
fourth [2] 24/22 30/14
Francisco [1] 2/21
Fraser [2] 3/7 5/24
fraud [2] 70/2 70/2
frequently [4] 41/21 41/24
42/2 42/8
front [3] 53/19 91/10 104/9
full [7] 69/7 69/9 80/22
90/14 105/24 109/23 115/8
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fund [1] 43/5
funded [2] 43/3 43/5
funding [6] 17/20 27/13
27/14 29/10 29/21 52/14
fundings [1] 52/16
funds [32] 7/25 17/21 17/25
24/9 25/7 25/10 25/13 27/8
27/17 27/24 28/4 28/19 29/2
29/6 29/13 29/25 30/2 32/1
32/12 35/6 35/7 35/16 35/19
35/24 36/9 37/10 37/15 37/18
37/20 45/3 45/8 51/13
further [17] 6/1 16/7 38/9
49/19 49/20 51/24 52/1 60/13
66/21 76/1 88/24 90/2 98/9
102/6 105/12 113/12 121/23
G
gather [2] 82/6 82/7
gave [1] 31/15
general [2] 25/12 61/16
generally [11] 18/18 19/19
20/1 27/3 28/12 30/11 30/19
31/13 32/18 35/22 107/14
generate [1] 71/4
get [14] 5/15 6/1 6/8 7/11
10/19 10/21 11/21 16/9 22/18
29/2 52/17 68/23 92/5 105/17
get-away [2] 10/19 11/21
give [3] 6/4 108/8 111/18
given [5] 48/8 72/1 74/20
80/1 80/2
Glendale [1] 3/13
go [32] 8/9 11/23 15/8 15/15
18/14 18/20 22/22 23/3 26/3
28/13 30/16 32/21 33/1 34/5
35/8 35/9 35/21 36/16 49/13
49/22 52/4 58/3 63/7 63/25
65/23 67/10 68/20 83/19 85/7
86/3 88/4 126/17
going [21] 5/11 6/1 6/2 6/21
6/23 7/5 11/19 11/20 11/20
34/14 35/8 58/24 83/22 84/18
103/12 108/19 112/4 112/9
117/22 119/13 124/22
gold [1] 14/1
gone [2] 25/24 38/13
good [28] 5/21 6/17 16/16
38/21 38/22 50/3 50/4 52/8
52/9 61/6 67/18 69/15 76/6
76/7 81/3 81/4 89/5 90/21
90/22 98/14 98/15 102/11
102/12 106/6 106/7 108/8
115/16 115/17
goods [1] 7/9
government [39] 9/8 10/9
14/3 14/8 14/15 14/17 15/16
16/10 19/22 27/25 30/14 35/9
44/19 46/10 53/10 54/2 60/18
62/14 65/1 67/21 68/9 69/4
80/11 83/18 86/2 86/5 88/3
88/10 89/9 89/15 93/13 96/14
97/5 103/11 105/20 108/20
112/7 113/18 114/11
government's [7] 6/3 69/4
71/7 83/21 92/22 93/15
117/24
graduate [1] 7/7
Granada [1] 61/11
grant [3] 29/17 29/19 33/20
Great [1] 34/5
Grigorian [1] 67/24
Grigoryan [10] 68/2 77/4
77/24 78/19 79/6 79/13 101/4
101/15 124/5 125/4
Grigoryan's [1] 5/15
gross [1] 31/23
ground [1] 12/6
grounds [2] 8/24 37/24
Group [1] 3/15
guarantee [5] 17/19 17/25
43/25 43/25 44/5
guaranteed [2] 18/1 18/2
guidance [3] 42/8 53/3 108/8
guide [2] 11/5 41/12
guilty [4] 10/12 10/13 11/13
14/11
Gusto [4] 109/23 111/7 111/9
113/6
H
H-E-R-N-A-N-D-E-Z [1] 90/17
had [34] 10/2 11/14 37/14
37/17 37/18 37/19 39/7 39/22
44/3 45/21 48/8 48/10 51/3
54/19 55/4 59/5 60/1 63/11
63/12 67/20 81/25 83/7 89/16
89/21 100/8 105/4 108/15
108/15 111/23 113/24 114/4
114/5 114/17 119/9
half [1] 81/20
handling [1] 123/7
hands [3] 22/19 29/2 108/16
happened [2] 5/11 27/11
happens [4] 12/21 25/24 35/1
43/21
happy [2] 38/2 54/3
hard [1] 7/6
hard-working [1] 7/6
Hart [2] 97/17 97/18
has [17] 10/9 35/5 56/11
56/13 57/8 62/13 63/12 65/20
71/6 78/5 81/25 83/20 85/20
103/25 109/3 122/8 125/11
hauling [1] 7/9
have [112]
haven't [1] 51/15
having [1] 51/14
he [24] 7/7 7/7 7/10 7/16
8/17 8/19 10/5 10/25 11/1
11/4 11/5 11/14 11/24 12/4
12/7 12/22 13/24 14/7 14/7
14/9 14/10 15/13 66/8 84/22
head [1] 53/7
hear [13] 9/1 9/12 9/24 10/2
10/22 12/9 12/10 12/13 12/14
13/2 13/4 15/1 102/20
heard [4] 12/2 62/10 76/15
85/4
hearing [6] 5/13 115/22
115/23 116/4 116/8 116/9
Heartland [1] 109/24
held [4] 5/6 6/15 67/12
127/6
help [5] 8/19 84/8 104/1
109/16 109/19
helpful [1] 80/18
her [2] 53/20 124/22
here [32] 6/20 10/22 11/3
11/16 15/7 15/10 15/13 20/22
23/15 52/10 60/15 71/9 71/12
72/7 80/7 84/19 84/25 85/8
86/9 87/14 90/7 93/1 94/4
103/9 103/15 103/22 110/20
111/11 111/21 113/5 125/12
126/12
hereby [1] 127/4
HERNANDEZ [9] 4/13 90/11
90/16 90/21 91/11 93/2 93/17
96/15 105/13
high [1] 7/8
higher [1] 20/23
highest [1] 70/1
highlight [4] 34/15 36/16
58/10 94/2
highlighted [1] 34/6
highlighting [2] 31/17 36/17
Highway [1] 3/20
Hills [1] 61/11
him [3] 8/21 11/5 14/11
his [21] 7/8 7/8 7/13 7/14
7/15 8/18 8/18 8/19 8/20
10/2 10/3 11/2 11/2 11/4
12/1 13/4 13/5 13/9 66/9
80/20 91/3
hit [6] 72/21 72/22 74/2
74/11 74/20 75/2
hits [1] 51/16
hold [1] 108/15
home [6] 7/11 9/22 13/4 13/5
13/7 111/25
homes [1] 14/2
honor [84]
HONORABLE [1] 1/3
hope [2] 6/21 73/8
hours [1] 7/10
house [1] 111/25
housekeeping [2] 6/12 6/13
how [50] 11/24 17/3 20/5
27/11 31/6 32/3 33/6 33/17
34/11 40/11 41/5 42/15 44/10
45/4 45/7 47/6 55/8 56/16
59/5 59/14 59/20 59/22 63/17
66/17 69/20 70/24 74/6 74/14
74/22 82/11 82/14 83/5 84/10
89/12 91/13 91/15 92/14 93/6
93/18 96/17 97/17 107/9
107/12 108/6 110/12 111/11
117/13 118/2 118/21 126/6
However [1] 75/3
husband [1] 8/16
I
I'm [8] 9/1 12/9 37/21 89/13
99/6 103/21 119/2 125/17
I.D [1] 4/20
ID [5] 71/23 72/5 117/9
118/24 119/16
ID's [1] 69/25
idea [2] 98/21 114/8
identification [25] 13/9
21/9 21/12 21/17 21/18 63/15
92/24 94/6 94/18 95/2 95/15
95/21 96/4 96/10 96/14 97/15
98/4 98/16 98/21 99/22
100/10 100/17 100/21 111/16
117/23
identifications [2] 7/22
13/3
identified [2] 37/18 38/6
identities [1] 12/2
idiot [1] 13/25
impact [5] 31/25 32/3 33/17
38/4 38/7
importance [1] 13/19
important [7] 10/7 10/20
11/18 12/19 13/18 22/11
22/22
importantly [1] 8/1
impression [1] 125/12
improper [1] 9/8
improperly [1] 5/24
Inc [10] 37/9 81/13 81/25
85/1 85/20 86/10 86/16 86/25
88/6 88/14
include [4] 27/1 33/24 34/18
48/16
included [2] 18/24 24/14
including [1] 27/20
income [10] 58/15 81/8 82/7
82/7 94/8 94/10 99/9 106/23
123/10 123/10
incorporated [1] 81/15
independent [3] 27/19 58/14
105/4
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indicated [2] 23/15 24/24
indicates [3] 20/11 20/18
21/14
individual [7] 82/8 85/13
86/20 86/22 86/24 104/18
124/12
individuals [9] 59/25 82/18
82/19 107/15 111/17 122/11
122/20 122/24 124/8
industries [1] 27/16
inflate [1] 32/9
inflating [1] 32/9
influence [2] 32/7 37/11
Info [15] 85/1 94/5 94/12
94/17 95/1 95/6 95/15 99/20
100/4 100/6 100/22 101/1
101/12 102/1 102/4
informal [1] 123/13
information [59] 19/2 19/14
21/21 22/9 22/12 28/15 28/16
28/24 31/3 31/6 31/8 31/25
32/4 32/6 34/2 34/3 34/21
43/17 43/18 43/23 44/1 45/9
54/13 54/15 57/12 76/12
76/19 77/14 78/17 78/24 79/5
79/5 79/9 80/1 82/6 82/23
92/5 92/10 92/11 95/3 97/2
100/4 101/2 101/3 101/14
101/17 102/1 102/3 104/10
108/7 111/11 111/12 111/12
117/8 123/11 123/19 123/24
124/4 124/16
initial [1] 28/22
initially [2] 18/12 34/25
injury [10] 20/19 26/19 27/6
28/14 29/18 36/1 42/24 51/9
51/10 57/1
innocence [2] 12/24 14/6
inside [3] 103/2 103/7
104/25
instance [1] 77/4
instead [2] 12/18 12/23
instruct [1] 24/2
instruction [4] 6/3 23/24
24/2 60/20
instructions [3] 54/19 54/22
55/21
integrated [1] 92/4
intend [6] 5/12 5/14 5/16
6/4 37/10 66/24
intends [1] 6/24
intent [1] 13/9
interest [5] 46/11 46/14
46/17 50/24 51/15
interface [1] 92/4
Internal [1] 90/24
interpret [1] 58/18
interpretive [4] 40/17 41/5
41/11 41/15
introduce [2] 9/6 9/7
introduced [1] 13/16
Intuit [1] 109/23
invalid [10] 72/11 72/24
72/25 74/4 76/22 77/17 79/2
79/19 97/16 97/23
involve [1] 17/5
IP [1] 9/24
IRS [19] 82/9 89/17 89/20
90/25 91/15 91/20 92/3 92/7
92/19 93/9 96/25 97/2 98/23
99/17 102/4 111/18 113/24
114/3 114/17
is [461]
isn't [18] 52/11 52/24 53/24
55/1 55/11 55/14 55/18 55/20
56/9 57/7 57/25 58/18 59/14
68/9 102/22 104/15 104/18
104/21
issue [8] 5/22 6/9 19/7
22/13 41/5 47/20 47/21 47/24
issued [9] 19/17 22/14 28/18
40/17 41/11 41/14 41/21
41/24 48/13
issues [1] 6/10
it [265]
items [2] 14/18 27/6
J
J-A-C-K [1] 80/23
JACK [4] 4/11 80/11 80/22
87/15
January [6] 31/24 36/2 71/19
72/15 73/3 119/23
January 15th [2] 71/19 72/15
January 31 [2] 31/24 36/2
January 9th [1] 73/3
Jeffrey [1] 15/12
Jennifer [4] 3/12 5/19 7/1
7/4
Jetpack [1] 107/22
jewelry [1] 14/2
job [15] 17/7 69/20 69/23
70/20 71/1 91/13 91/17 91/25
92/16 115/21 115/22 116/2
116/3 117/1 117/16
jobs [2] 7/13 107/23
John [1] 3/4
Johnson [17] 2/14 2/17 2/19
2/22 3/19 3/20 4/6 4/14 5/17
8/14 9/16 14/14 26/4 52/3
52/7 60/19 102/10
Jr [1] 3/14
JUDGE [1] 1/4
Judicial [1] 127/9
jumped [4] 11/15 11/25 12/23
14/9
jumping [1] 13/11
JUNE [4] 1/17 5/1 42/10
127/10
jurors [3] 26/5 26/6 26/16
jury [28] 1/15 5/7 6/8 6/16
6/17 9/5 10/14 13/18 17/16
18/5 18/19 20/8 23/19 23/22
24/16 24/21 27/11 29/15
31/13 46/13 47/17 48/24 65/1
67/13 83/18 88/3 107/19
112/7
just [45] 5/10 5/22 6/9 6/11
9/11 10/17 11/11 11/23 12/9
12/17 15/2 20/1 20/15 20/21
23/22 24/3 25/12 26/5 31/17
37/23 38/13 47/12 47/18 50/6
50/18 51/12 54/1 56/6 57/6
57/11 57/12 63/7 65/23 76/15
84/12 87/25 97/8 108/17
113/18 120/5 120/9 125/7
125/19 125/25 126/6
JUSTICE [2] 2/4 2/9
K
K-A-T-H-L-E-E-N [1] 16/18
KATHLEEN [3] 4/4 16/11 16/18
KATIE [2] 1/21 127/12
Katzman [2] 3/4 3/7
Kauichko [9] 73/1 73/8 76/16
77/1 78/2 86/19 87/10 88/16
88/20
keep [9] 14/5 16/19 22/20
22/20 52/21 52/22 82/24 91/7
107/23
keeping [5] 17/14 82/21
91/20 107/16 116/22
keeps [2] 76/9 122/7
Keough [9] 2/19 4/10 4/14
4/16 4/18 76/5 98/13 113/16
122/2
kept [9] 70/8 70/10 70/12
70/15 70/17 92/9 93/8 93/11
96/24
kid [1] 66/19
kind [3] 10/4 31/11 31/22
kinds [1] 92/9
knew [3] 12/22 14/7 14/7
know [58] 5/14 6/19 9/10
10/16 11/24 26/15 34/11 40/5
40/11 40/16 41/4 41/8 41/10
41/18 41/19 42/6 42/11 42/12
42/14 44/6 48/9 48/12 48/13
53/25 55/8 55/19 57/14 57/16
57/21 59/10 60/10 65/18
67/24 68/2 68/5 68/6 68/25
70/24 83/2 83/5 83/12 84/23
86/20 89/20 89/23 92/14
94/13 107/25 108/7 110/10
110/17 113/2 114/5 114/16
114/20 117/13 122/14 123/23
knowing [2] 12/22 14/10
knowingly [2] 11/15 14/9
knowledge [6] 24/5 40/4 40/7
63/4 85/23 122/15
known [1] 69/19
Kudiumov [10] 73/21 74/6
74/13 77/11 110/4 110/7
110/8 110/10 110/23 113/20
L
L-I-T-T-W-I-N [1] 16/18
L-L-O-Y-D [1] 80/23
lack [11] 44/8 45/24 93/7
94/22 95/23 100/8 100/11
103/6 103/7 103/9 103/22
Lacks [2] 99/14 101/5
laid [1] 58/6
large [2] 40/2 40/5
last [16] 16/3 23/20 58/9
58/10 58/13 69/10 72/3 72/20
73/13 74/18 75/2 75/14 78/9
115/11 116/8 125/25
late [2] 7/10 81/20
later [4] 5/22 6/4 26/9
43/24
law [4] 3/15 3/20 23/24 24/2
lawsuit [1] 46/20
lawyer [4] 5/24 9/8 38/23
38/25
lawyers [1] 9/5
learn [1] 89/14
learned [4] 34/21 67/20 89/7
113/23
leave [1] 16/7
lecturn [1] 54/5
led [1] 39/22
ledger [2] 82/24 82/25
left [5] 5/13 15/10 48/10
48/17 49/16
Legal [1] 37/23
legislation [1] 17/18
legitimate [6] 8/17 8/21
26/1 52/10 52/13 102/18
lend [2] 48/10 48/17
lender [18] 18/15 18/21
18/22 18/25 19/8 43/6 43/11
43/13 43/16 43/20 43/23
43/24 44/3 44/8 55/12 55/13
55/23 60/11
lenders [2] 17/22 44/16
lending [1] 34/23
lengthy [1] 5/12
less [1] 40/15
let [4] 5/13 11/23 37/3
114/2
let's [29] 6/8 16/9 21/11
26/17 32/21 51/14 55/22 58/3
58/3 63/19 63/24 63/25 64/4
Case 2:20-cr-00579-SVW Document 672 Filed 07/09/21 Page 135 of 143 Page ID
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L
let's... [16] 65/23 68/20
75/6 85/6 86/13 87/13 93/25
110/19 110/19 111/5 111/13
113/4 123/12 124/21 124/25
126/16
letter [2] 96/21 96/21
letters [8] 15/18 15/20
15/22 15/23 15/24 96/18
96/20 96/24
level [1] 70/1
Lewis [1] 3/4
liability [1] 43/21
license [40] 63/14 64/5
64/15 64/16 64/17 69/25 70/1
70/12 71/8 71/12 71/18 72/1
72/5 72/10 72/11 72/14 72/22
72/24 72/25 73/2 73/16 73/22
74/2 74/6 74/11 74/14 74/19
74/22 75/3 75/6 75/12 75/15
75/20 76/23 77/10 77/18
78/13 78/22 79/2 79/25
licenses [4] 76/9 76/12
76/15 79/19
lien [1] 70/3
like [17] 9/11 9/25 10/16
10/17 13/22 14/17 15/17
16/11 23/3 40/24 44/10 50/6
51/16 56/4 57/24 87/25 107/6
limitations [1] 24/9
limited [2] 25/15 29/9
limiting [3] 23/24 24/1
60/20
Limo [10] 11/1 54/11 54/13
102/14 102/18 103/3 103/13
103/20 103/25 104/10
line [4] 31/15 58/9 58/10
58/13
lined [1] 68/23
link [1] 28/14
list [12] 75/14 104/25
107/21 118/7 124/9 125/4
125/14 125/21 126/1 126/3
126/3 126/6
listed [24] 71/12 84/25
85/11 86/9 87/11 93/22 94/21
96/8 96/9 98/5 99/24 100/8
104/11 104/11 104/17 110/21
118/23 119/19 119/24 120/3
123/3 124/11 124/18 125/9
lists [2] 86/15 111/21
little [8] 6/2 30/17 42/23
42/25 43/4 43/7 46/6 91/7
Littrell [3] 3/4 3/4 3/7
LITTWIN [11] 4/4 16/11 16/16
16/18 16/20 23/5 25/12 38/21
46/5 49/18 50/3
live [7] 61/8 61/10 61/11
81/5 82/10 99/10 106/8
living [1] 82/2
LLC [1] 56/12
LLC's [1] 27/19
Lloyd [1] 80/22
LLP [6] 2/14 2/17 2/19 2/22
3/4 3/7
load [1] 14/22
loan [82]
loans [33] 17/19 22/14 25/16
25/19 27/24 39/22 39/22
39/24 40/5 42/22 42/24 42/25
43/2 43/3 43/5 43/7 43/10
44/11 44/12 44/15 46/7 46/7
47/3 47/3 47/7 47/22 48/8
51/8 51/19 52/10 52/12 59/14
59/20
locate [1] 71/22
located [2] 28/6 97/2
location [1] 44/23
locations [1] 117/8
log [2] 35/3 35/4
logo [1] 118/3
long [9] 7/9 17/3 40/12
56/16 59/22 69/20 84/10
91/13 91/15
look [18] 14/13 53/15 56/15
57/14 57/15 63/9 71/22 93/25
93/25 105/7 110/19 111/5
112/4 124/6 124/10 125/3
125/13 126/2
looked [3] 53/9 53/11 53/12
looking [5] 5/23 11/16 12/21
53/25 126/15
LOS [7] 1/14 1/23 2/7 2/15
3/9 3/16 5/1
lost [1] 53/22
lot [2] 42/15 103/9
loudly [1] 115/24
Lulu [1] 37/8
Luncheon [1] 126/18
M
M-O-D-I [1] 115/11
ma'am [4] 60/15 80/6 105/13
126/12
made [1] 51/8
magnification [1] 34/15
magnified [3] 20/9 20/16
36/18
magnify [4] 21/15 30/18
31/14 84/18
magnifying [1] 31/18
mail [3] 35/2 63/20 63/22
main [1] 5/13
mainly [2] 83/6 116/7
maintain [1] 109/20
maintenance [1] 107/6
make [14] 5/14 6/24 8/6 9/8
12/11 14/23 15/2 26/5 26/6
28/16 34/9 37/23 58/21 58/25
makes [1] 29/1
making [2] 12/4 12/7
man [11] 7/6 68/2 77/4 77/24
78/18 79/6 79/12 101/3
101/15 124/5 125/3
manage [2] 7/13 17/7
managed [1] 26/25
management [2] 70/6 107/22
manager [1] 56/13
managing [1] 17/5
Manuk [11] 67/24 68/2 77/4
77/24 78/18 79/6 79/12 101/3
101/15 124/5 125/3
Manukyan [4] 75/6 75/12
78/14 78/17
many [6] 10/22 59/13 82/11
82/14 93/18 107/9
March [6] 25/7 25/9 40/9
73/22 74/7 119/23
March 19th [2] 73/22 74/7
March 31 [1] 119/23
mark [7] 4/7 22/3 23/16
23/22 33/1 60/18 61/1
marked [1] 117/23
Market [1] 2/20
mask [4] 80/15 80/16 80/17
107/8
master [3] 92/3 99/17 102/4
match [16] 72/21 72/23 73/14
73/17 74/2 74/4 74/4 74/11
74/12 74/20 75/1 75/3 75/4
75/19 80/1 80/2
matter [4] 5/23 6/12 25/12
127/7
matters [4] 5/10 6/13 9/9
122/15
may [9] 5/9 8/17 10/10 16/6
24/6 30/15 58/12 104/6
105/17
maybe [1] 124/11
me [22] 11/11 11/23 23/21
37/3 39/22 40/24 43/3 44/16
47/7 50/15 62/21 64/11 64/13
78/4 80/1 80/2 89/19 100/13
107/23 108/7 112/3 114/2
mean [13] 8/24 11/9 11/10
33/11 46/1 89/17 101/6 104/1
119/14 120/4 122/14 125/11
126/5
meaning [2] 56/12 119/15
means [4] 18/5 33/8 33/12
34/13
Mechanics [4] 110/15 110/17
110/25 121/13
Medel [1] 74/22
mediate [1] 70/4
Medicare [2] 109/10 112/20
meet [7] 29/4 32/15 32/16
47/5 50/16 82/6 112/3
meeting [2] 50/18 111/24
meets [1] 18/6
Meghan [1] 2/16
members [2] 6/17 9/4
mentioned [12] 17/25 19/9
23/17 26/19 26/25 29/9 33/23
34/17 39/21 43/10 116/4
120/6
Mesereau [6] 3/14 3/15 4/5
49/22 50/2 50/5
message [1] 13/11
messages [4] 13/10 13/12
13/22 13/24
mic [1] 115/9
Michael [1] 2/19
microphone [3] 91/10 94/14
115/25
might [5] 31/19 42/7 55/19
99/9 122/11
millions [1] 48/8
mind [5] 10/13 11/14 31/17
31/19 54/4
mine [3] 64/13 64/14 66/18
minute [3] 54/1 66/23 67/1
minutes [4] 53/4 60/2 67/5
67/9
missing [1] 62/20
mission [1] 17/1
Misstates [2] 100/14 100/23
mobile [3] 9/20 60/7 60/9
MODI [7] 4/17 115/4 115/10
115/16 115/24 116/2 118/18
moment [1] 71/17
money [20] 10/4 20/24 21/5
25/15 25/21 25/24 32/10 44/8
44/11 44/20 44/25 45/10
45/18 45/21 45/23 45/23
48/10 48/16 63/5 85/24
Monica [1] 3/15
monitor [4] 45/4 45/7 45/22
46/3
month [2] 36/2 40/15
monthly [7] 20/10 20/12
20/22 48/14 49/2 59/5 107/6
months [2] 31/23 69/22
more [17] 14/9 15/9 20/24
25/18 25/25 41/15 50/18
56/15 57/10 65/24 80/15 88/1
93/18 101/22 114/1 115/24
123/13
morning [34] 6/17 7/10 16/16
38/21 38/22 50/3 50/4 52/8
52/9 61/6 61/7 67/7 67/8
67/18 67/19 69/15 76/6 76/7
81/3 81/4 89/5 89/6 90/21
90/22 98/14 98/15 102/11
102/12 106/6 106/7 113/17
115/16 115/17 122/3
Case 2:20-cr-00579-SVW Document 672 Filed 07/09/21 Page 136 of 143 Page ID
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M
mortgage [3] 50/24 51/15
51/19
most [3] 6/22 8/1 12/19
motion [1] 14/23
motor [2] 69/16 69/18
mouth [1] 80/16
move [6] 14/17 15/17 40/8
69/4 118/13 118/25
moves [2] 93/13 97/5
Mr [28] 4/5 4/5 4/6 4/7 4/9
4/10 4/11 4/13 4/14 4/14
4/16 4/16 4/18 4/18 38/20
50/2 52/7 61/5 69/14 76/5
81/2 90/20 98/13 102/10
106/5 113/16 115/15 122/2
Mr. [32] 9/16 9/22 10/2 10/4
10/18 11/14 13/2 13/11 13/24
14/1 14/4 14/14 15/10 49/22
50/5 61/6 66/13 67/18 80/14
81/3 83/20 84/19 86/4 88/5
89/5 90/7 92/23 96/13 106/6
113/17 114/23 117/22
Mr. Artur [1] 50/5
Mr. Clark [1] 15/10
Mr. Cruz [3] 92/23 96/13
117/22
Mr. Dadyan [9] 10/2 10/4
10/18 11/14 13/2 13/11 13/24
14/1 14/4
Mr. Fard [3] 106/6 113/17
114/23
Mr. Fenton [1] 80/14
Mr. Johnson [2] 9/16 14/14
Mr. Mesereau [1] 49/22
Mr. Runyan [7] 81/3 83/20
84/19 86/4 88/5 89/5 90/7
Mr. Vahe [1] 9/22
Mr. Zindroski [3] 61/6 66/13
67/18
Ms [6] 4/4 4/8 4/12 16/15
67/17 89/4
Ms. [22] 8/5 16/16 16/20
23/5 25/12 38/21 46/5 49/18
50/3 69/15 76/6 80/3 90/21
91/11 93/2 93/17 96/15
105/13 115/16 115/24 116/2
118/18
Ms. Fitzgerald [3] 69/15
76/6 80/3
Ms. Hernandez [6] 90/21
91/11 93/2 93/17 96/15
105/13
Ms. Littwin [8] 16/16 16/20
23/5 25/12 38/21 46/5 49/18
50/3
Ms. Modi [4] 115/16 115/24
116/2 118/18
Ms. Wirsching [1] 8/5
much [2] 20/5 122/7
multiple [3] 47/6 107/18
107/23
Murat [1] 74/22
must [3] 22/12 77/1 111/17
my [33] 5/23 7/4 8/14 50/5
53/7 63/14 64/14 64/16 64/16
66/7 66/18 69/9 69/24 70/6
80/17 81/20 82/2 83/6 106/11
107/20 107/20 107/21 108/7
109/19 109/24 110/22 111/4
111/25 111/25 115/10 115/22
116/3 125/12
N
name [106]
named [30] 7/14 65/18 65/20
68/2 77/4 77/7 77/24 78/2
78/4 78/18 79/6 79/9 79/12
79/16 81/12 84/23 85/13
88/19 101/3 101/15 101/18
102/2 102/13 110/10 110/12
114/13 114/13 124/5 124/16
125/3
names [9] 70/10 71/7 71/8
71/11 78/11 82/25 123/4
124/8 125/13
Nearly [1] 7/12
necessarily [1] 99/11
necessary [4] 14/20 106/24
108/7 108/18
need [10] 10/14 10/23 25/13
29/6 47/13 66/25 67/1 98/25
99/11 103/23
needed [6] 11/5 15/8 25/4
30/18 54/25 70/6
needs [1] 108/25
net [2] 20/19 58/15
never [8] 62/12 63/6 63/11
63/12 63/16 65/13 65/22
112/1
new [4] 2/10 2/18 56/20 83/8
Newcomer [5] 2/16 4/8 4/12
67/17 89/4
next [29] 6/24 10/20 11/19
20/13 23/3 23/4 30/16 33/10
35/1 35/21 37/4 48/5 57/24
58/4 59/2 60/16 60/21 66/3
68/20 80/10 85/6 87/13 90/9
105/16 110/20 111/6 113/4
113/5 115/2
Nicholas [1] 2/22
night [2] 7/10 7/11
no [174]
North [2] 2/6 3/20
not [117]
notes [1] 44/25
nothing [3] 12/14 52/2 93/1
November [2] 74/15 75/7
November 29th [1] 74/15
November 2nd [1] 75/7
now [28] 6/1 6/6 9/11 10/7
26/3 41/5 42/15 44/10 45/3
45/21 46/5 47/3 53/15 54/19
57/17 67/9 68/18 68/20 69/22
76/15 78/12 79/23 81/17 93/2
94/25 104/8 123/12 126/16
number [60] 10/11 19/7 21/1
21/17 21/18 21/18 21/19
28/18 29/23 31/16 33/14
33/19 48/9 57/9 63/10 63/13
63/14 63/15 63/17 63/18
63/18 64/17 72/1 72/6 72/10
72/14 72/22 73/2 74/3 74/7
74/15 74/20 74/22 75/3 75/12
79/25 94/6 94/18 95/2 95/16
97/16 98/4 98/16 98/22 99/13
99/23 100/10 100/17 100/21
101/3 110/20 111/2 111/3
111/4 111/16 111/18 118/22
118/24 123/5 125/18
numbers [10] 21/9 21/12 32/9
70/12 71/12 95/21 96/4 96/11
118/23 123/9
NW [2] 2/10 2/23
NY [1] 2/18
O
o'clock [5] 5/12 6/6 6/14
67/10 126/17
Oaks [2] 106/9 112/1
objecting [1] 68/9
objection [28] 8/23 12/4
13/13 24/12 37/23 37/25
39/19 40/22 41/7 41/9 41/16
45/12 45/24 48/21 58/2 59/16
68/10 68/15 99/14 100/14
100/23 101/5 101/20 102/19
122/13 123/17 125/6 126/4
obligations [2] 29/4 32/16
obtain [2] 55/12 55/13
occasionally [2] 83/8 109/18
occupational [1] 69/25
occurring [1] 36/2
off [5] 51/9 53/7 64/9 92/5
94/14
offer [3] 29/12 34/3 48/19
offered [1] 24/4
office [8] 2/4 3/20 28/3
28/6 92/19 117/19 124/1
125/5
officer [2] 37/8 123/12
officer's [1] 123/4
officers [2] 17/7 123/3
Official [1] 1/21
often [6] 7/9 41/5 42/22
42/25 43/3 43/7
oh [2] 47/13 83/4
okay [19] 5/8 5/21 8/9 15/8
23/4 50/8 50/14 53/5 62/15
64/7 65/2 78/3 78/5 80/18
84/4 87/9 90/3 91/12 126/9
once [7] 6/20 7/15 25/24
28/17 35/5 44/25 45/3
one [34] 6/9 6/11 10/11 15/9
25/18 25/21 33/21 42/23
42/25 43/4 43/7 46/7 47/8
47/9 49/1 49/2 50/17 53/11
53/12 55/25 57/10 63/11 68/3
71/17 76/15 84/12 87/25
91/14 93/18 93/25 106/15
110/19 114/1 125/25
ones [1] 68/7
online [1] 31/7
only [14] 9/5 27/23 32/12
43/22 47/8 62/2 62/5 72/5
85/9 87/14 103/21 111/6
113/5 125/13
open [3] 65/8 65/11 88/20
opened [3] 7/16 27/13 27/18
opening [8] 5/14 5/15 5/25
6/23 6/24 8/7 9/4 9/9
operate [1] 99/1
operating [1] 99/9
operation [1] 25/5
operations [4] 25/6 29/6
37/14 111/25
order [10] 23/1 45/18 68/25
98/25 99/11 106/24 108/8
109/6 111/17 112/2
orders [1] 15/3
original [1] 43/22
other [20] 13/10 29/13 44/22
51/4 51/5 51/7 51/20 53/12
53/16 60/14 73/15 82/1
106/23 107/4 108/17 108/17
114/24 120/21 121/7 121/14
our [2] 70/5 92/4
out [32] 8/17 8/22 9/19
11/20 22/22 23/19 25/21
31/19 34/14 35/22 37/3 38/13
43/25 44/7 48/8 49/5 51/4
53/4 55/1 56/8 58/6 58/18
58/21 59/5 59/14 59/20 89/9
89/12 113/25 114/3 114/17
122/24
outline [1] 13/15
outside [1] 5/6
outsource [1] 109/18
over [12] 7/9 10/20 11/19
11/23 22/14 42/3 49/16 54/4
80/16 96/18 118/25 119/3
overruled [4] 24/13 40/23
41/9 41/17
owes [1] 51/14
own [14] 8/18 8/18 10/3 10/3
11/2 11/2 61/17 61/17 81/10
Case 2:20-cr-00579-SVW Document 672 Filed 07/09/21 Page 137 of 143 Page ID
#:10176
O
own... [5] 81/10 99/12
106/11 106/18 122/14
owned [2] 81/18 81/20
owner [14] 8/17 19/11 22/1
23/13 30/4 37/1 37/8 38/6
51/18 55/17 61/23 81/16
81/21 88/16
owners [9] 22/20 52/16 52/17
54/23 54/25 56/7 58/17 59/13
123/7
owners' [1] 22/19
ownership [2] 21/13 123/3
owns [1] 21/21
Ozodco [1] 37/8
P
P-I-N-A-L [1] 115/11
p.m [1] 126/18
Pacific [1] 3/20
PAETTY [7] 2/5 4/9 4/13 4/18
69/14 90/20 115/15
page [41] 4/3 23/3 23/4
28/13 30/14 30/16 30/20 31/7
35/9 35/21 37/4 48/25 49/13
59/25 62/16 63/8 63/24 63/25
64/2 64/4 65/23 84/17 85/6
86/9 86/13 86/13 86/14 86/15
87/5 87/13 94/25 95/12
108/21 110/3 110/19 111/6
112/9 112/21 113/4 113/5
127/7
pages [1] 103/24
paid [7] 46/8 51/15 85/8
111/6 113/5 119/9 123/9
pandemic [2] 17/15 51/16
paragraph [6] 23/20 35/23
56/5 58/4 59/3 71/8
paragraph 6 [1] 71/8
Pardon [4] 61/9 61/14 63/21
68/1
part [28] 16/3 17/7 23/9
34/17 39/15 41/12 54/22
55/21 59/4 70/10 70/12 70/19
71/1 76/8 78/16 79/4 85/7
92/16 100/25 101/11 101/25
102/15 110/19 117/1 117/15
124/3 124/17 125/2
participant [8] 8/10 10/6
11/7 11/15 11/22 11/25 12/22
14/10
participating [12] 17/22
18/15 18/20 18/22 43/6 43/11
43/13 43/16 43/23 43/24 44/3
60/11
particular [4] 22/2 28/3
33/3 73/11
parties [2] 5/8 6/18
partnership [1] 82/8
partnerships [1] 82/20
party [2] 8/6 9/7
passed [3] 17/18 39/11 40/11
pay [19] 10/8 10/14 10/23
11/12 11/18 12/24 13/22 14/6
17/20 19/7 21/8 27/6 27/7
43/25 44/7 51/9 51/19 109/4
120/4
Paycheck [5] 17/9 50/12 62/8
83/9 108/3
payer's [1] 91/6
paying [4] 13/19 50/21 50/24
51/1
payroll [44] 20/10 20/12
20/23 21/8 50/16 50/19 53/24
57/25 57/25 58/1 58/4 58/7
59/6 83/25 109/3 109/9
109/18 109/21 109/23 109/24
111/8 111/9 112/15 113/6
116/7 116/19 116/19 117/8
118/21 119/5 119/9 119/10
120/4 120/5 120/16 120/16
121/1 121/1 121/9 121/10
121/10 121/20 121/20 123/8
people [6] 12/16 12/19 13/10
38/12 55/17 126/2
per [4] 71/22 74/3 74/12
75/4
percent [1] 18/2
perform [1] 122/25
perhaps [1] 8/1
period [4] 18/7 119/23
120/11 121/2
periods [4] 95/8 119/19
119/22 121/6
permissible [2] 35/18 35/24
permission [8] 19/21 30/13
64/25 83/17 86/1 88/2 112/6
118/16
person [15] 7/21 34/9 38/6
62/2 62/5 73/15 74/5 75/5
75/13 75/21 76/21 77/6 77/16
78/10 104/24
personal [7] 36/9 47/1 99/9
104/18 105/8 105/8 123/10
Peter [7] 3/19 3/20 5/17
8/14 26/4 52/3 60/19
phase [1] 28/22
Phon [1] 37/8
phone [5] 9/20 60/7 60/9
63/17 110/20
photograph [1] 13/8
physical [1] 53/21
physically [1] 28/8
pick [1] 83/8
PINAL [3] 4/17 115/4 115/10
place [1] 122/7
PLAINTIFF [2] 1/7 2/3
plea [2] 5/15 5/25
please [28] 16/16 16/17
21/15 41/1 47/14 48/24 49/14
54/6 58/5 58/11 59/3 60/22
60/24 69/7 71/17 80/12 80/20
90/12 90/14 103/12 105/21
105/23 105/24 110/21 115/5
115/7 115/9 115/24
plus [2] 10/21 20/18
point [29] 6/4 9/13 14/24
23/18 24/16 24/21 35/22 41/8
41/9 48/19 57/21 72/17 72/18
73/5 73/6 73/14 73/17 73/25
74/1 74/3 74/9 74/10 74/12
74/17 74/18 75/1 75/4 75/8
75/9
pointing [1] 31/19
portal [1] 35/4
portion [3] 34/8 39/16 57/19
posed [1] 7/21
position [3] 69/21 69/21
91/14
possible [9] 22/19 29/3 44/7
44/9 60/6 70/2 80/15 107/7
108/9
post [1] 48/23
potential [1] 15/4
power [1] 53/22
PPP [69]
practice [2] 56/24 81/8
preceding [1] 31/23
predicated [1] 29/21
preparation [2] 106/17
107/20
prepare [11] 81/8 82/9 84/8
84/11 85/18 87/23 109/16
111/17 112/2 113/7 113/9
prepared [1] 114/9
preparer [8] 82/5 85/9 87/14
87/17 106/22 111/6 111/16
113/5
preparer's [3] 87/14 111/7
113/6
prepares [1] 106/23
presence [4] 5/7 6/16 15/7
67/13
present [1] 5/8
presented [1] 7/19
president [1] 56/12
PRESIDING [1] 1/4
pressure [2] 40/8 42/16
presumption [2] 12/24 14/5
pretty [1] 122/7
previously [8] 19/22 62/13
81/18 81/18 83/21 86/5
108/19 111/23
prior [2] 82/23 82/23
private [2] 17/23 18/16
Probably [1] 84/12
problems [1] 51/14
proceed [8] 9/16 15/6 24/7
26/17 38/16 69/6 93/16
118/15
proceedings [7] 1/13 5/6 6/5
6/15 67/12 126/19 127/6
process [9] 18/10 18/18
28/10 28/12 30/7 69/24 70/2
71/21 108/16
program [29] 17/9 17/13
17/14 26/20 26/21 27/3 27/13
27/14 27/15 29/12 29/16
29/17 48/8 48/10 48/14 49/11
49/16 50/7 50/12 51/16 51/17
56/18 56/20 62/9 62/9 83/10
83/10 108/4 108/4
programs [4] 17/5 26/25
27/18 116/18
promptly [2] 5/11 6/20
pronounce [1] 86/19
proof [2] 10/11 10/12
proper [2] 51/12 51/13
property [4] 46/11 46/23
46/24 47/1
proposed [1] 6/3
proprietor [2] 58/14 122/23
proprietorship [3] 99/8
104/15 104/17
proprietorships [1] 27/19
prosecutor [2] 50/9 51/12
Protection [5] 17/9 50/12
62/8 83/9 108/3
proves [1] 14/8
provide [8] 17/20 19/14
28/25 29/7 70/4 107/1 107/4
107/5
provided [20] 17/19 22/9
25/19 25/25 34/2 34/22 52/14
53/10 57/12 57/13 100/6
100/9 100/16 102/1 123/5
123/19 123/23 124/4 124/16
125/5
provides [3] 17/21 27/5
27/24
providing [4] 19/13 22/13
28/25 32/6
proving [1] 10/9
PTIN [6] 111/12 111/13
111/14 111/15 111/16 111/19
publish [8] 19/22 30/14
64/25 83/17 86/1 88/2 112/7
118/16
pull [5] 53/8 54/2 58/4 72/6
124/21
pulled [1] 79/22
punctual [1] 6/19
purely [1] 36/9
purpose [9] 5/13 21/8 24/5
50/7 50/11 50/16 51/4 51/5
56/5
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purposes [5] 50/17 50/18
50/21 51/7 59/4
pursuant [2] 19/23 127/4
put [6] 10/15 12/3 49/5
51/17 72/5 73/9
Q
qualify [1] 36/10
Quality [12] 61/20 62/3 62/6
62/20 63/12 64/18 65/6 65/9
65/21 97/24 98/6 121/4
quarantine [1] 39/5
quarter [7] 95/18 112/16
119/6 119/8 120/1 120/2
120/11
quarterly [7] 84/4 95/17
109/7 109/9 112/15 117/9
119/25
quarters [1] 120/5
question [34] 10/5 10/18
10/20 31/21 32/25 34/5 34/16
38/1 40/25 45/15 46/2 48/5
55/22 57/8 60/6 66/8 66/10
66/12 68/13 68/16 89/13
95/25 101/6 101/10 101/11
101/22 102/20 114/1 122/15
122/16 122/17 125/7 125/25
126/7
questions [28] 31/18 38/9
41/21 41/24 42/2 42/9 44/10
49/19 50/6 50/10 51/13 51/24
60/13 60/14 65/24 66/21 76/1
88/24 90/2 97/8 98/9 102/6
102/7 105/12 113/12 113/18
114/11 121/23
quickly [5] 22/19 29/3 40/21
41/3 42/19
R
R-U-N-Y-A-N [1] 80/23
Ram [1] 2/13
ran [14] 74/8 74/16 74/24
75/17 78/21 78/24 95/20
99/17 99/19 100/10 100/20
101/25 122/4 125/2
Range [1] 104/5
reached [4] 89/9 113/25
114/3 114/17
read [4] 13/12 58/13 59/23
60/1
real [3] 38/6 46/24 99/4
really [1] 11/17
reason [1] 53/15
reasonable [4] 10/9 10/11
10/13 14/9
recall [12] 40/17 51/8 76/16
77/13 78/7 78/11 78/14 78/16
103/19 103/21 113/21 114/14
receive [12] 18/12 19/2 20/6
20/24 21/4 25/7 25/10 32/1
33/21 33/21 33/22 63/4
received [8] 16/5 24/4 24/10
31/3 42/22 48/22 85/23 97/7
receives [1] 44/25
receiving [1] 43/22
recess [4] 67/7 67/8 67/11
126/18
recognize [17] 19/25 30/17
30/19 35/10 87/7 88/11 92/25
93/4 93/6 96/15 96/17 108/22
112/11 112/14 117/25 118/2
118/3
record [69]
record-keeping [2] 91/20
116/22
recording [1] 36/4
recordings [1] 122/12
records [39] 70/7 70/10
70/13 70/15 70/17 76/9 79/20
91/4 92/9 92/19 93/7 93/21
94/2 94/4 94/11 94/22 95/5
95/13 95/24 97/11 97/18
99/23 100/1 103/6 103/10
105/8 116/10 118/25 119/3
119/4 119/14 119/17 120/15
120/24 122/8 122/10 122/19
122/21 123/15
recover [1] 46/18
Redline [4] 110/15 110/17
110/25 121/12
Redondo [1] 3/21
reduced [1] 22/15
reference [14] 12/5 12/7
78/17 79/5 79/8 98/6 101/1
101/13 101/17 101/21 103/2
103/13 103/19 103/25
referenced [1] 19/13
referencing [1] 14/22
referred [1] 13/24
referring [1] 109/22
refinance [1] 51/10
reflected [2] 119/10 119/12
refresh [1] 67/9
refuse [1] 44/7
regarding [2] 36/21 41/6
register [3] 98/18 98/22
111/18
registration [1] 69/25
regular [7] 71/1 91/24 92/6
92/16 93/8 96/25 117/1
regulations [3] 41/6 41/12
127/8
reiterate [1] 38/14
related [11] 33/20 51/20
82/7 92/19 102/2 102/17
104/10 117/19 122/8 124/5
124/16
relating [1] 24/18
relation [1] 44/11
relationship [4] 78/18
122/24 123/14 123/14
relationships [4] 122/10
122/19 125/3 126/2
Relevance [2] 41/7 45/24
rely [2] 22/12 28/24
relying [3] 34/3 43/17 43/18
remember [1] 102/15
remove [1] 57/18
renewed [1] 75/24
rent [1] 50/21
rep [2] 115/22 116/8
repaid [1] 46/16
repay [2] 18/8 46/19
repeat [6] 16/3 40/24 96/1
101/10 114/1 122/17
rephrase [2] 38/2 45/14
report [6] 82/7 83/25 84/2
119/6 120/5 123/8
reported [5] 20/23 31/25
38/3 112/20 127/6
Reporter [1] 1/21
REPORTER'S [1] 1/13
reports [4] 48/14 48/16 49/3
71/4
represent [5] 8/15 91/3
115/23 116/7 120/1
representative [11] 19/12
23/14 30/5 37/2 55/24 56/2
56/10 56/12 58/24 91/19
116/5
representatives [3] 55/1
55/17 57/6
representing [1] 116/9
request [5] 19/21 20/20
30/13 68/13 112/6
requested [9] 22/24 28/16
50/11 60/20 96/18 96/22
108/17 123/22 123/25
require [5] 34/1 36/23 45/17
55/16 55/23
required [18] 23/1 23/9
23/18 28/20 33/10 33/12 34/7
35/15 55/10 55/12 55/13 59/8
59/11 59/12 109/4 119/7
119/8 123/8
requirements [2] 18/6 47/5
research [1] 96/18
researched [1] 95/16
respect [1] 84/14
response [1] 27/8
responses [1] 42/5
responsible [1] 28/4
rest [1] 111/11
result [8] 72/7 74/25 77/17
97/21 98/2 120/23 121/17
121/18
results [17] 72/19 73/7
75/10 75/11 75/18 75/19
94/20 95/10 95/13 95/22 96/7
97/14 118/11 120/8 120/13
120/14 121/9
retired [1] 61/16
retrieval [1] 92/5
return [14] 82/9 92/10 94/8
94/10 95/4 95/17 99/12
106/24 108/25 109/2 109/9
112/15 117/9 119/5
returned [1] 99/23
returns [14] 81/9 82/23 91/4
95/11 95/19 95/23 96/9 98/19
104/18 105/8 106/23 111/17
112/2 121/9
revealed [1] 77/13
revenue [2] 29/5 90/24
revenues [2] 31/12 31/23
review [9] 18/22 28/16 43/13
44/1 70/2 91/4 102/24 103/16
103/23
reviewing [1] 103/23
Richard [1] 1/9
right [57] 9/15 19/24 33/1
39/12 39/18 42/10 42/23 43/4
45/8 45/23 46/11 46/20 46/23
47/7 48/4 48/22 55/11 56/3
57/13 57/17 58/25 59/6 61/12
62/19 63/9 63/18 63/24 64/24
65/5 65/23 66/5 66/6 66/20
73/9 76/14 79/23 83/13 83/16
84/7 86/8 87/5 87/6 87/25
88/10 89/24 90/5 96/5 108/10
108/20 111/5 112/4 112/11
112/18 119/20 125/14 125/15
126/8
risk [1] 39/9
road [2] 3/12 7/9
robbery [2] 10/16 10/17
role [2] 19/5 91/3
room [3] 12/19 15/6 38/16
roughly [1] 42/19
round [6] 25/18 25/23 47/8
47/9 47/21 48/7
rounds [2] 25/22 47/6
Roza [1] 75/14
RPR [1] 127/12
rule [3] 69/5 93/14 118/14
rules [2] 40/18 41/15
run [31] 25/21 70/24 71/2
71/11 71/15 71/21 72/13 73/1
73/21 75/8 75/9 76/11 92/12
93/21 94/11 94/17 95/5 97/11
97/17 97/24 100/3 106/11
117/11 117/15 118/6 118/6
120/9 120/19 121/4 121/12
125/10
running [2] 76/16 78/12
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RUNYAN [23] 4/11 80/11 80/22
81/3 81/13 81/25 83/20 84/19
85/20 86/4 86/10 86/15 86/22
86/24 87/10 87/15 88/5 88/5
88/13 89/5 89/15 89/24 90/7
Ryan [2] 3/7 5/24
S
Sabala [1] 120/9
said [11] 6/20 9/5 13/19
44/19 50/15 52/23 57/6 57/24
125/9 125/11 125/12
sales [1] 70/3
same [15] 29/17 42/8 73/12
73/14 73/17 73/18 74/5 75/11
84/14 95/1 95/1 109/7 109/25
120/24 121/18
San [2] 2/21 3/6
Santa [1] 3/15
saw [1] 12/3
say [27] 23/25 30/24 40/20
41/2 41/14 49/15 51/4 51/14
57/20 57/20 62/2 62/5 78/6
83/2 83/7 84/10 94/14 107/25
109/21 113/23 114/3 114/8
114/20 123/12 123/13 124/12
125/25
saying [4] 11/3 12/16 12/20
73/9
says [18] 33/10 49/8 56/9
58/9 59/25 63/9 66/1 84/20
85/8 87/13 88/13 110/7 111/6
111/7 112/21 113/5 113/6
119/13
SBA [63] 16/11 17/1 17/3
17/5 17/19 18/1 18/9 18/12
18/23 19/2 19/5 19/18 22/4
22/5 26/23 26/25 27/13 27/14
28/1 28/3 28/13 28/16 31/3
31/7 34/3 34/21 35/2 38/23
39/15 39/17 40/8 40/17 41/5
41/11 41/14 41/21 41/24
42/15 42/18 42/22 43/2 43/5
43/22 43/24 44/4 44/7 44/15
44/17 45/4 45/17 45/22 46/16
46/17 46/20 47/7 48/7 48/13
52/11 55/9 55/10 55/12 55/13
56/16
SBA's [4] 32/7 37/11 38/7
43/21
scary [1] 11/11
Schedule [4] 104/21 104/24
104/25 105/3
school [1] 7/8
SCOTT [1] 2/5
screen [15] 12/3 21/11 21/24
23/5 26/3 26/12 26/13 32/21
32/22 32/24 33/2 34/6 35/9
36/14 36/18
screens [1] 47/16
scroll [5] 85/6 87/13 110/19
112/9 113/4
search [50] 13/5 71/11 71/15
71/21 72/2 72/4 72/7 72/13
72/19 73/1 73/5 73/6 73/21
76/17 76/20 77/13 78/13
78/16 78/21 78/24 79/4 94/11
94/17 95/5 97/11 97/14 97/18
97/21 97/24 98/2 99/19 99/22
99/25 100/20 100/25 101/12
102/13 120/9 120/19 120/23
121/4 121/8 121/12 122/25
123/4 123/15 124/13 124/15
124/19 125/10
searchable [1] 70/22
searched [2] 77/10 98/6
searches [28] 70/24 71/2
71/4 71/25 76/11 92/12 92/14
92/19 93/21 95/20 96/3 99/16
100/3 101/25 102/15 117/11
117/13 117/15 117/19 118/6
118/11 120/8 122/4 123/20
124/3 124/7 124/17 125/2
searching [1] 13/4
seat [1] 90/14
seated [4] 5/9 24/6 105/23
115/7
sec [1] 20/21
second [6] 10/12 10/17 23/20
35/23 49/1 72/4
secretary [1] 56/12
section [10] 20/8 20/15
20/22 21/13 21/15 36/16
36/18 51/3 94/2 127/4
sector [2] 17/23 18/16
secure [1] 36/7
security [10] 21/18 46/10
46/13 46/17 79/21 99/12
109/10 112/19 123/5 123/9
see [50] 9/17 9/20 10/21
11/13 11/25 12/25 13/1 13/6
13/7 13/9 13/11 13/23 13/23
14/1 15/9 20/11 23/5 26/6
26/16 34/6 36/14 54/17 56/3
62/17 63/19 64/17 65/5 65/16
65/25 66/5 66/8 66/12 78/10
78/18 85/8 85/11 86/14 86/17
86/18 87/9 88/17 93/2 103/15
103/21 104/8 107/21 110/5
110/13 110/14 110/21
seen [2] 47/17 86/6
seize [1] 47/1
self [2] 58/15 126/8
semi [1] 61/16
send [1] 35/2
senior [1] 69/18
sent [1] 18/25
service [21] 70/4 81/13
81/25 83/7 85/20 86/10 86/16
86/22 86/24 87/10 88/5 88/14
89/16 90/24 91/19 109/19
109/19 109/20 109/21 109/21
109/23
Service's [1] 89/24
services [5] 61/20 62/20
107/1 107/4 107/5
SESSION [1] 1/16
set [5] 11/14 71/7 73/9
109/19 111/25
she [10] 57/10 82/2 101/7
101/7 125/7 125/11 125/12
125/13 126/6 126/9
Sherman [2] 106/9 112/1
short [2] 5/10 22/14
should [5] 15/5 15/7 38/16
68/23 119/12
show [20] 7/20 7/22 7/23
7/24 8/2 10/10 12/17 31/13
32/24 71/6 78/8 87/25 92/22
96/13 103/11 105/3 108/19
117/22 122/10 122/19
showed [1] 50/9
showing [7] 24/5 32/22 47/15
62/13 83/20 86/4 88/10
shown [2] 7/18 30/19
shows [3] 33/8 34/12 34/17
side [2] 12/16 12/16
sign [5] 23/12 28/18 35/3
35/5 55/24
signature [10] 23/9 23/15
36/23 64/2 66/3 66/5 66/9
66/9 66/12 66/15
signed [3] 37/5 37/7 56/1
significant [3] 13/12 13/18
25/3
Silverman [3] 2/22 4/5 38/20
similar [3] 58/16 73/10
98/21
since [2] 56/21 71/25
single [5] 8/18 9/21 11/1
12/1 13/1
sir [29] 8/9 62/1 62/23 63/1
64/1 64/3 64/5 64/23 65/19
65/25 66/20 66/20 83/9 83/24
85/8 86/11 86/15 86/20 87/7
87/15 87/25 88/14 88/23 90/5
110/5 112/4 112/11 113/7
115/1
sitting [1] 68/7
situation [1] 46/16
Six [3] 112/25 113/2 114/13
slash [1] 37/8
small [21] 7/13 7/14 7/15
7/16 16/25 17/2 27/22 27/23
30/17 39/25 49/5 51/18 52/16
54/22 54/25 56/6 58/17 59/13
59/18 59/19 107/15
SMVT [2] 69/19 69/24
so [103]
Social [6] 21/18 99/12
109/10 112/19 123/5 123/9
software [1] 107/20
sole [8] 27/19 58/14 61/23
81/16 81/21 99/8 104/14
104/17
Solutions [14] 85/1 85/16
94/5 94/12 94/17 95/1 95/6
95/15 99/20 100/4 100/7
100/22 101/13 102/1
Solutionss [2] 101/1 102/4
some [20] 5/10 5/10 11/8
16/6 21/14 40/2 44/23 45/10
50/21 51/7 54/19 57/15 82/19
82/19 82/20 97/8 97/9 106/17
109/23 113/18
somebody [3] 11/5 13/3 99/8
someone [10] 51/14 73/19
73/20 77/1 77/3 77/21 79/11
79/16 114/5 114/13
something [3] 51/16 94/13
116/4
sometimes [3] 7/11 54/25
55/16
somewhat [1] 59/8
sorry [11] 9/1 12/9 31/15
37/21 89/13 91/9 99/6 103/15
103/21 119/2 125/17
sought [5] 94/2 94/4 94/7
95/3 95/13
speak [7] 50/5 80/14 91/11
94/14 107/8 115/9 115/24
speakers [1] 60/4
speaking [3] 7/5 20/1 111/25
Spear [1] 2/20
special [1] 6/19
specific [4] 78/6 83/22 97/9
125/19
specifically [6] 13/25 41/6
72/5 101/23 108/13 123/23
speculation [2] 45/12 59/16
spell [7] 16/16 60/24 69/7
80/21 90/15 105/24 115/8
spelling [1] 73/12
spending [2] 39/7 45/23
spends [1] 45/4
spent [2] 5/22 45/8
spoke [1] 112/17
Spring [1] 2/6
SSN [3] 21/14 21/16 118/21
stabilize [1] 39/11
stabilizing [1] 39/18
staff [5] 70/5 70/6 115/22
116/3 116/6
stage [1] 43/22
stand [6] 9/19 10/1 10/22
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stand... [3] 12/15 14/7 36/5
stands [2] 20/18 48/4
Star [3] 112/25 113/2 114/13
start [4] 6/13 15/3 61/21
81/14
state [15] 16/16 60/24 69/7
80/20 81/5 82/10 90/14 99/10
105/24 106/8 115/8 115/20
116/14 116/19 123/10
stated [4] 33/21 93/17 96/3
112/24
statement [8] 5/14 5/16 5/25
6/25 8/7 8/7 9/4 9/9
statements [5] 6/24 12/17
23/24 57/5 57/11
states [16] 1/1 1/4 1/6 2/3
16/25 20/10 23/20 34/3 68/21
90/10 92/18 115/3 117/18
124/1 127/5 127/9
stating [1] 96/22
stay [2] 15/13 48/25
stenographically [1] 127/6
step [5] 60/22 80/12 90/12
105/21 115/5
STEPHEN [1] 1/3
Steptoe [4] 2/14 2/17 2/19
2/22
still [2] 15/10 48/10
stolen [1] 12/2
stored [1] 123/11
stores [1] 117/7
Street [7] 1/22 2/6 2/14
2/20 3/8 61/11 64/10
stretches [1] 7/9
struck [2] 68/14 68/19
struggling [2] 59/13 59/19
subject [1] 9/10
submit [10] 18/21 18/23 23/1
28/15 45/19 62/22 62/24 87/2
87/19 109/13
submitted [17] 9/22 10/25
11/3 31/6 42/7 42/8 42/9
55/9 60/7 67/24 68/3 68/7
85/20 114/5 114/12 114/17
114/20
succeeded [1] 39/17
such [1] 70/3
Suite [8] 1/22 2/15 2/20 3/5
3/8 3/13 3/16 3/21
SUN [1] 2/5
support [1] 55/14
supported [1] 14/18
supporting [4] 18/24 24/19
28/20 29/7
supports [1] 7/8
supposed [2] 53/3 56/8
sure [9] 15/2 26/5 26/6
89/14 91/9 114/2 115/10
116/1 122/18
surprised [1] 12/13
sustain [1] 68/15
Sustained [9] 39/20 45/15
59/17 68/11 99/15 100/15
100/24 101/6 123/18
SVW [1] 1/8
switch [2] 47/13 54/4
sworn [7] 16/12 60/23 69/2
80/13 90/13 105/22 115/6
system [22] 73/9 82/21 91/20
91/24 92/2 92/5 92/14 107/16
107/19 107/20 107/22 116/22
117/3 117/4 117/5 117/7
117/11 117/12 117/15 119/25
123/4 123/11
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table [2] 47/16 68/7
take [14] 5/21 6/2 13/9 26/9
40/12 46/15 46/16 46/17
46/24 57/15 66/23 67/8 107/7
112/4
takes [3] 6/19 46/10 59/23
talk [4] 9/24 10/20 52/10
111/13
talked [4] 14/3 42/15 42/18
102/21
talking [1] 42/24
Tamara [12] 8/20 9/22 11/3
13/7 13/25 77/7 78/4 79/9
79/17 101/19 102/2 124/17
tax [70]
taxes [11] 99/9 109/5 116/7
116/19 116/19 119/9 120/4
120/16 121/1 121/10 121/20
taxi [2] 10/19 11/21
taxpayer [12] 92/10 94/18
95/2 95/21 98/16 99/22
100/10 100/17 100/21 101/2
118/19 118/20
technician [1] 69/18
telephone [5] 63/17 63/18
111/2 111/3 111/4
tell [21] 9/6 13/17 32/18
33/6 48/2 61/8 77/3 77/5
77/6 77/23 78/1 78/7 79/11
79/15 79/19 79/22 79/23
79/25 106/8 110/21 114/3
ten [2] 7/12 84/12
TERABELIAN [2] 3/3 5/24
term [1] 17/9
terms [3] 35/14 103/12
122/22
testified [11] 39/1 76/8
77/10 78/12 78/21 99/16
99/19 100/16 101/12 122/4
123/20
testify [1] 15/8
testifying [3] 50/10 102/24
103/16
testimony [2] 44/14 99/4
text [6] 13/9 13/11 13/12
13/22 13/23 34/15
than [9] 14/10 25/18 40/15
41/15 50/18 82/1 93/18 98/4
108/17
thank [48] 7/3 8/4 8/5 14/12
14/14 16/21 24/23 27/16
38/17 49/18 51/25 60/15
60/17 66/20 67/10 68/12
68/17 80/3 80/6 80/6 80/8
80/24 88/23 90/1 90/5 90/5
90/7 90/8 91/9 101/8 102/6
105/11 105/13 105/15 107/8
113/12 113/17 114/23 115/1
115/12 122/3 123/12 125/24
126/10 126/11 126/12 126/13
126/14
that [558]
That's [1] 73/20
their [19] 13/19 22/20 22/21
29/4 29/6 35/4 45/10 45/18
45/21 46/3 52/17 58/24 99/8
99/12 106/18 108/9 108/15
123/8 123/9
them [15] 22/20 22/21 24/10
31/18 35/3 40/2 45/5 55/12
68/24 83/14 93/25 96/17
108/8 108/11 109/20
then [22] 9/16 18/23 28/16
35/5 36/3 48/2 48/4 51/3
67/9 72/3 73/15 74/19 82/8
89/12 100/10 123/2 123/6
124/6 124/11 124/18 124/19
125/10
Theoretically [1] 51/18
there [115]
thereafter [1] 36/3
these [35] 7/18 8/25 9/2
9/10 10/13 22/14 22/18 22/22
23/7 29/2 29/6 32/6 32/9
51/13 51/19 52/16 55/9 55/16
59/14 59/20 68/23 84/4 93/8
93/18 96/15 96/18 96/24
109/16 113/24 114/4 114/9
118/24 119/8 119/15 119/17
they [77]
THIBODEAUX [2] 1/21 127/12
things [12] 7/18 8/3 9/11
9/25 10/8 10/11 10/14 10/24
11/10 12/3 57/25 58/1
think [8] 6/2 10/15 10/17
11/21 13/4 50/15 53/22 116/4
third [1] 24/17
this [143]
Thomas [1] 3/14
those [43] 8/3 10/23 13/12
13/23 18/12 30/2 32/14 35/6
39/24 42/2 46/18 47/3 48/16
50/21 51/19 51/19 54/22
58/25 70/17 71/4 76/15 78/11
79/20 80/2 84/11 94/23 95/11
95/22 95/23 96/7 96/9 96/10
96/10 107/1 109/7 109/13
114/21 117/13 119/22 122/10
122/25 123/11 124/3
though [2] 18/19 77/3
three [18] 72/17 72/18 73/5
73/6 73/14 73/17 73/25 74/1
74/3 74/9 74/10 74/12 74/17
74/18 75/1 75/4 75/8 75/9
three-point [18] 72/17 72/18
73/5 73/6 73/14 73/17 73/25
74/1 74/3 74/9 74/10 74/12
74/17 74/18 75/1 75/4 75/8
75/9
through [21] 11/6 15/17
15/19 15/20 15/21 15/22
15/23 15/24 26/23 28/1 31/7
44/17 49/8 49/11 52/11 99/8
99/17 103/12 103/24 108/16
123/6
thus [1] 76/22
tied [1] 98/3
time [19] 6/2 8/20 15/5 16/7
18/7 29/23 33/19 38/9 42/3
42/16 44/2 57/10 57/15 57/21
58/17 67/3 69/3 103/23 114/1
timeframe [3] 22/14 22/15
25/23
Timeline [3] 37/9 120/19
121/2
timely [2] 28/25 29/1
times [4] 11/8 20/18 41/15
57/9
TIN [11] 21/14 21/16 63/9
98/16 98/18 98/25 99/3 99/11
101/13 101/14 101/18
TIN/EIN [1] 63/9
title [2] 88/13 127/4
today [3] 11/3 102/25 103/17
told [1] 67/8
Tom [1] 50/5
too [1] 91/11
top [28] 53/7 61/20 62/3
62/6 62/16 62/17 62/20 63/7
63/12 64/18 65/3 65/6 65/8
65/21 84/17 84/19 84/20 86/8
87/11 97/24 98/6 110/3 110/7
112/21 118/3 119/13 119/13
121/4
totally [1] 83/11
Tower [1] 2/20
Towing [2] 7/14 7/17
town [1] 81/5
track [4] 52/17 82/21 107/16
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track... [1] 107/23
trailing [1] 94/14
training [3] 70/5 71/22 75/4
transaction [1] 44/22
transactions [2] 70/3 70/3
transcript [3] 1/13 127/6
127/7
transcripts [1] 91/5
transferred [1] 44/11
transmitting [1] 28/4
Transport [5] 7/15 7/17 37/9
120/19 121/2
treasury [2] 44/18 44/20
trial [8] 1/15 6/22 9/18
10/5 10/18 11/24 14/12 24/3
trier [1] 125/12
truck [1] 7/7
trucking [1] 7/13
true [10] 29/10 34/11 56/9
84/14 87/15 91/5 109/25
114/16 118/10 127/5
trusts [1] 82/20
truth [1] 36/21
truthful [1] 34/2
truthfulness [2] 22/9 23/18
try [3] 11/20 59/5 59/19
trying [4] 22/18 29/2 42/18
59/13
Tulsa [2] 61/11 64/10
Turing [16] 85/1 85/16 94/5
94/11 94/17 95/1 95/6 95/15
99/19 100/4 100/6 100/22
100/25 101/12 101/25 102/3
turn [4] 63/24 64/4 64/9
86/13
Turning [4] 84/17 86/13 87/5
110/3
Twelfth [1] 2/6
two [14] 1/15 10/8 10/11
10/13 10/21 10/23 11/19
69/22 71/25 84/12 94/1
108/15 118/25 119/3
type [6] 33/10 72/2 83/24
108/22 109/21 123/14
typed [2] 72/8 72/9
types [8] 70/7 82/17 84/5
106/24 107/4 107/14 109/13
109/16
Typically [2] 106/23 111/24
U
U.S [5] 1/21 2/4 2/4 100/5
100/9
UCC [2] 36/4 36/5
Ulia [11] 65/16 65/18 65/20
71/15 71/18 72/13 78/22
84/20 84/21 84/23 85/14
ultimately [1] 39/14
unclear [1] 68/18
under [10] 32/1 40/8 42/8
42/15 69/4 93/14 104/14
104/17 118/14 119/15
understand [7] 11/4 26/10
37/22 44/14 62/4 89/13 95/25
understanding [1] 26/11
understood [3] 12/11 13/21
60/12
unemployment [8] 84/2 95/4
108/25 109/2 109/5 109/11
109/11 116/18
Uniform [1] 36/6
unique [2] 21/19 39/3
UNITED [13] 1/1 1/4 1/6 2/3
16/25 68/21 90/10 92/18
115/3 117/18 124/1 127/5
127/9
unless [1] 14/8
unsupported [1] 9/9
until [7] 6/1 14/8 15/6 15/7
25/6 25/9 67/10
up [34] 5/22 6/2 12/3 16/19
26/9 27/13 33/22 42/12 43/13
47/15 53/8 53/9 54/2 57/18
57/18 58/4 65/3 65/11 68/24
71/22 72/3 72/6 73/9 73/11
73/12 78/8 79/22 83/8 91/7
103/9 103/15 103/22 109/19
124/21
updated [1] 42/2
upon [5] 18/9 22/4 43/17
43/18 46/22
us [21] 2/9 22/13 28/25
32/18 32/24 34/11 48/2 52/2
77/3 77/6 77/23 78/1 79/11
79/15 79/19 94/8 94/10
100/17 106/8 125/5 125/20
use [23] 24/9 32/4 35/24
36/9 37/10 51/18 71/21 71/23
84/10 85/9 87/14 87/22 92/4
98/19 98/22 99/12 109/5
109/24 111/6 113/5 117/7
119/24 119/25
used [18] 5/24 7/22 19/14
84/9 84/10 89/8 89/16 89/21
92/6 101/3 101/14 101/18
111/23 112/1 112/3 113/24
114/4 123/20
uses [5] 32/12 32/14 35/18
51/12 51/13
using [3] 65/14 89/24 99/22
usually [1] 109/18
utilities [1] 51/1
utility [2] 51/15 51/19
V
Vague [5] 58/2 101/20 122/13
123/17 125/6
VAHE [8] 3/18 5/18 8/13 8/15
8/16 9/22 54/16 105/8
valid [1] 91/5
value [2] 33/8 34/12
variety [2] 57/25 58/1
Vaughan [1] 3/7
vehicle [3] 69/18 69/24
71/23
Vehicles [1] 69/16
verified [1] 75/13
verifying [2] 74/12 75/1
version [2] 84/4 109/7
very [3] 11/5 15/14 22/21
via [2] 111/7 113/6
victim [7] 8/10 10/5 11/7
11/15 11/22 12/23 14/10
VICTORIA [11] 4/13 73/1 73/8
76/16 76/25 78/2 87/10 88/16
88/19 90/11 90/16
view [1] 5/23
Viktoria [2] 73/12 86/19
voice [3] 16/19 91/7 94/13
VOLUME [1] 1/16
Voyage [10] 11/1 54/11 54/13
102/13 102/17 103/3 103/13
103/20 103/25 104/10
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wage [2] 58/14 119/6
wages [6] 109/4 109/10
109/11 112/19 112/20 123/9
wait [2] 15/6 68/24
waiting [1] 9/11
want [6] 6/4 15/2 20/21
22/19 23/21 46/5
wanted [2] 26/5 122/24
was [157]
Washington [2] 2/10 2/23
wasn't [1] 126/9
way [7] 6/22 14/4 45/16
47/18 92/23 99/4 114/2
we [111]
web [2] 28/13 31/7
WEDNESDAY [2] 1/17 5/1
weekly [2] 48/13 49/2
weeks [2] 10/21 11/19
well [23] 9/4 11/5 15/14
46/1 47/16 57/16 66/5 70/5
74/8 74/16 74/24 75/17 78/3
82/6 83/6 84/5 104/11 107/4
109/24 110/1 121/19 122/14
125/7
Wells [3] 10/3 65/9 65/14
went [4] 26/8 39/24 40/2
40/5
were [85]
weren't [4] 55/9 124/13
125/22 126/2
West [3] 1/22 2/14 3/8
WESTERN [1] 1/2
what [150]
whatever [1] 70/6
when [28] 13/4 14/7 30/18
30/24 43/24 47/21 50/9 59/22
61/21 66/18 67/21 68/15 72/8
72/9 73/9 78/24 80/14 81/14
84/10 89/8 98/19 98/23
100/20 104/13 107/8 109/21
113/24 123/5
where [28] 16/24 17/19 20/11
21/12 24/16 24/21 28/6 31/13
31/19 32/24 35/22 51/3 61/8
61/10 64/20 65/25 69/15
72/19 88/8 90/23 99/10 103/5
103/7 104/24 111/6 112/19
115/18 122/7
whereas [1] 109/10
whether [26] 13/17 30/1
32/18 40/5 40/17 45/22 48/13
57/21 59/19 67/24 68/2 68/6
77/3 77/6 77/23 78/1 79/11
79/15 101/2 101/14 101/18
103/19 103/24 105/3 122/23
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which [16] 19/22 20/18 33/8
34/12 50/10 107/21 107/23
109/10 109/19 113/19 114/12
119/2 119/5 119/5 119/24
123/10
while [2] 82/2 103/12
who [37] 6/24 8/6 11/8 12/13
15/11 17/21 18/14 19/9 19/17
21/21 22/1 23/12 24/9 27/24
29/25 30/1 36/25 37/7 68/3
68/5 68/7 68/25 77/7 79/20
81/18 81/18 81/23 89/23
100/3 100/6 109/3 114/8
114/20 114/21 123/19 123/23
126/2
whoever [2] 5/13 123/7
whole [1] 20/15
whose [2] 23/15 78/7
why [10] 21/7 22/11 25/3
28/23 39/9 53/15 57/15 57/20
58/13 68/9
wife [2] 81/20 82/2
will [78]
Williams [2] 3/4 3/7
WILSON [1] 1/3
wire [1] 44/22
wires [1] 44/20
Wirsching [5] 3/12 5/19 7/2
7/4 8/5
wishes [1] 8/6
withheld [1] 123/10
within [2] 83/23 83/23
without [2] 19/25 53/25
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16/11 16/12 26/7 38/16 46/1
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60/16 60/20 60/21 60/22
60/23 66/25 68/20 69/2 80/10
80/12 80/13 80/20 90/9 90/12
90/13 91/1 91/2 91/17 92/24
96/13 103/11 104/6 105/16
105/21 105/22 115/2 115/5
115/6 117/23
witnesses [10] 9/24 10/21
14/24 15/3 15/5 26/12 26/16
38/14 38/15 68/23
woman [8] 77/7 78/2 78/4
79/9 79/16 101/18 102/2
124/16
won't [4] 13/2 13/6 13/10
93/25
work [15] 16/24 26/23 69/15
69/16 76/8 81/23 86/22 90/23
90/24 91/24 107/22 111/9
115/18 115/19 117/1
worked [2] 17/3 65/20
working [7] 7/6 27/5 32/15
36/1 62/3 62/6 116/8
would [75]
wouldn't [2] 79/23 99/10
wrong [2] 31/16 50/15
Y
Y3081786 [1] 74/23
Y3365633 [1] 75/7
yeah [4] 8/21 63/16 64/11
64/13
year [3] 91/14 94/24 94/24
years [23] 7/12 17/4 38/25
56/17 61/22 82/23 83/7 84/12
91/16 94/21 94/23 95/11
95/18 96/7 96/9 96/22 99/24
99/25 104/11 116/8 120/20
121/6 121/14
yes [307]
yesterday [4] 5/11 11/9 12/3
26/8
yet [1] 93/1
York [2] 2/10 2/18
you [547]
your [196]
yours [7] 84/21 85/2 106/20
110/8 110/15 112/22 112/25
yourself [1] 82/1
yourselves [1] 67/9
Z
Z-I-N-D-R-O-S-K-I [1] 61/2
zero [1] 45/18
Zhadko [12] 65/16 65/18
65/20 71/15 71/18 72/8 72/13
78/22 84/20 84/21 84/23
85/14
ZINDROSKI [8] 4/7 22/3 23/16
60/18 61/1 61/6 66/13 67/18
zone [1] 59/2
zoom [1] 56/4
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