Court filing
TRANSCRIPT of Proceedings (Motion Hearing) as to Carl Delano Torjagbo held on 12/09/2024,… — USA v. Torjagbo (Dkt. 167)
Record facts
| Court | U.S. District Court for the Northern District of Georgia |
|---|---|
| Filed | 2025-02-12 |
U.S. District Court for the Northern District of Georgia · No. 1:22-cr-00171-MLB-RDC · Doc. 167 · 2025-02-12 · Docket on CourtListener
Summary
A transcript of proceedings on a motion in United States of America v. Carl Delano Torjagbo, Criminal Action File No. 1:22-CR-00171-MLB, held December 9, 2024 before the Honorable Michael L. Brown in the U.S. District Court for the Northern District of Georgia, Atlanta Division, and filed February 12, 2025 as Document 167. The 95-page transcript opens with a court reporter notice on the handling of official transcripts, followed by appearances by Nicholas Evert and Sekret Sneed for the government and Kendal D. Silas for the defendant and an index to examinations. The hearing takes up the government's motion to sell three properties, with the court identifying the showing required under Supplemental Rule G7. Defense counsel contests the government's factual assertions about one of the properties. Three witnesses are called and examined.
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
NORTHERN DISTRICT OF GEORGIA
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- - -
Stenographic Court Reporter Note:
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA,
)
)
Plaintiff, ) CRIMINAL ACTION FILE
v. ) NO. 1:22-CR-00171-MLB
)
CARL DELANO TORJAGBO,
)
)
Defendant.
)
_______________________________)
--------------------------------------------------------------
BEFORE THE HONORABLE MICHAEL L. BROWN
TRANSCRIPT OF PROCEEDINGS
DECEMBER 9, 2024
--------------------------------------------------------------
Proceedings recorded by mechanical stenography
and computer-aided transcript produced by
JANA B. COLTER, FAPR, RDR, CRR, CRC
Realtime Systems Administrator
Official Court Reporter
1949 U.S. Courthouse
75 Ted Turner Drive, SW
Atlanta, Georgia 30303
(404) 215-1456
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
APPEARANCES:
For the Plaintiff: OFFICE OF THE U.S. ATTORNEY
(By: Nicholas Evert
Sekret Sneed)
For the Defendant: FEDERAL DEFENDER PROGRAM, INC.
(By: Kendal D. Silas)
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
INDEX TO EXAMINATIONS
WITNESS PAGE
JANET FRANCHI
Direct Examination By Mr. Evert
9
Cross-Examination By Mr. Silas
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ADRIANO GHISI
Direct Examination By Mr. Evert
45
Cross-Examination By Mr. Silas
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SCOTT CARUANA
Direct Examination By Mr. Evert
59
Cross-Examination By Mr. Silas
66
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
_ _ _
P R O C E E D I N G S
(Atlanta, Fulton County, Georgia, December 9, 2024, in
open court.)
THE COURT: All right. We are here on a motion by
the government to sell several properties in 22-cr-171.
Can I have appearances starting with counsel for the
United States?
MR. EVERT: Good afternoon, Your Honor.
Nick Evert on the behalf of the government.
And with me at counsel table is Scott Caruana of the
FBI and Sekret Sneed, who is also an Assistant United States
Attorney.
THE COURT: And for the defendant?
MR. SILAS: Kendal Silas, Your Honor.
And also present at counsel table with me is Carl
Torjagbo and Charlotte Diggs, who is a paralegal with the
Federal Defender Program.
THE COURT: Okay. Am I right that that's why we're
here?
MR. EVERT: Yes.
THE COURT: You looked at me a little funny when I
said it and I thought maybe I was wrong about why we were
here.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. EVERT: No, that's correct.
THE COURT: Okay. I put out an order when the
government filed its initial motion saying that you have an
obligation to prove something in order to sell these
properties and that it appeared the defendant was challenging
your assertion in regards to it.
I think it's the Greythorne, is that the name of it?
MR. EVERT: Correct, yeah.
THE COURT: I'm assuming the defendant does not
challenge your position on the other properties.
Is that right, Mr. Silas?
MR. SILAS: Well, Your Honor, we're challenging the
government's effort -- or the government's motion to force a
sale of all of the properties, but I think the Greythorne one,
in particular, we were honed in on that one because the
government's assertion that the property was falling into a
state of disrepair and that there were squatters on the
property. And so we were specifically disputing those facts
as to the Greythorne property.
THE COURT: Okay. And are you --
MR. SILAS: And the other ones are undeveloped,
Your Honor.
THE COURT: Are you-all aware of that, that that's
not really the only one they're disputing?
MR. EVERT: Yes, Your Honor.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
We're prepared to go forward on all three properties.
THE COURT: Okay. All right. You have the burden.
MR. EVERT: Yes.
THE COURT: It is my belief that you have to show
that there is some basis. We're dealing with Supplemental
Rule G7; is that right?
MR. EVERT: Yes, Your Honor.
THE COURT: And that you have to show that the
property is somehow at risk of deterioration, that the expense
is excessive or that there is a mortgage on which the owner is
in default or any other type of good cause.
I think that's what we're talking about, right?
MR. EVERT: Yes, Your Honor.
Also the taxes would be another basis.
THE COURT: Sure. Do you agree with that, Mr. Silas,
that's the issue here?
MR. SILAS: Yes, Your Honor.
THE COURT: All right. Go ahead.
MR. EVERT: Okay. I would like to call our first
witness, Janet Franchi.
THE COURT: Okay.
MR. EVERT: Oh, yeah. And there will be three
witnesses, Your Honor.
THE COURT: Okay.
MR. EVERT: Mrs. Franchi, who is with the homeowner's
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
association, Detective Ghisi with the Cobb County Police
Department and Scott Caruana, who is the case agent with the
FBI.
THE COURT: Okay. Sorry about that. They make me
bring my phone in here in order to turn on my computer and
occasionally I forget to kill the sound.
MR. SILAS: And, Your Honor, I would invoke the rule,
Your Honor.
THE COURT: Okay. Well, is there anyone else in here
that you expect to testify other than the agent?
MR. EVERT: No, Your Honor.
THE COURT: Okay.
MR. EVERT: The other witnesses are outside in the
hallway.
THE COURT: Mr. Silas, do you have any objection to
the agent being in here?
MR. SILAS: No, Your Honor.
THE COURT: Perfect.
Okay. Ma'am, would you mind standing up and taking
an oath?
THE WITNESS: Yes.
- - -
JANET FRANCHI,
A witness herein, having been first duly sworn, was examined
and testified as follows:
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
- - -
COURTROOM DEPUTY: Thank you. For the record, will
you please state and spell your first and last name?
THE WITNESS: Yes. I'm Janet Franchi. It's
J-A-N-E-T, F-R-A-N-C-H-I.
COURTROOM DEPUTY: Thank you.
MR. EVERT: And, Your Honor, just for the record, we
would also invoke the rule.
THE COURT: Okay. Mr. Silas, what is good for the
goose is good for the gander.
Okay. Good morning, ma'am, how are you doing?
THE WITNESS: Good morning. Fine, thanks.
THE COURT: Good.
DIRECT EXAMINATION
BY MR. EVERT:
Q.
Good morning, Ms. Franchi.
A.
Good morning.
Q.
Where do you live?
A.
I live in East Cobb at 2114 Castlewycke Court.
Q.
And how long have you lived there?
A.
About 12 and a half years.
Q.
And are you familiar with the property at 5114 Greythorne
Lane in Marietta, Georgia?
A.
Yes.
Q.
What -- where is that in relation to your house?
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
It's next door, on the right side if you're in my house.
THE COURT: Immediately next door?
THE WITNESS: Yes.
THE COURT: Okay.
BY MR. EVERT:
Q.
Do you know the owner of 5114 Greythorne Lane?
A.
I don't know him, but I know the name as Carl Delano or
Torjagbo or something. I'm not sure how to pronounce it.
Q.
And is there a homeowner's association or HOA for the area
where you live?
A.
Yes, there is.
Q.
What is that HOA called?
A.
It's the Brookshire Manor Homeowner's Association.
Q.
How many houses does the HOA cover?
A.
17.
Q.
Is every one of those homes required to be part of the
HOA?
A.
Yes.
Q.
And about how much are the homes in the area worth
generally?
A.
They are generally worth between one and a half million to
maybe two and a half, 2.8, according to current listings.
Q.
And is 5114 Greythorne Lane covered by the HOA?
A.
Yes, it is.
Q.
Do you have a role with the HOA?
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
I do.
Q.
What is that role?
A.
I'm the treasurer.
Q.
And how long have you been the treasurer?
A.
My first year was 2018.
Q.
And in your role as treasurer, do you have knowledge as to
how the HOA is funded?
A.
Yes.
Q.
And how -- how is the HOA funded?
A.
Every homeowner pays an annual association due.
Q.
And is every home in the HOA required to pay that -- those
dues?
A.
Yes, they are.
Q.
How much are the dues?
A.
They're currently 2,150 -- yeah, 2,150.
Q.
And has that been the case since 2022?
A.
Let's see. We raised the dues in -- for the 2023 year by
$500 per home.
Q.
Got it. So what were they before they were --
A.
They were $1,650.
Q.
And so is the owner of 5114 Greythorne Lane, that being
Mr. Delano or Torjagbo, is he required to pay dues?
A.
Yes, he is.
Q.
And is he up to date on those dues?
A.
He is not.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
How much does he currently owe in dues?
A.
Well, he would owe for -- I don't know the exact number,
he would owe for 2023 and 2024, plus interest and late fees.
THE COURT: He didn't pay at all in 2023?
THE WITNESS: I don't think so.
THE COURT: Or at all in 2024?
THE WITNESS: 2024, right.
THE COURT: So that's in excess of $40,000 or so?
Were you getting there?
THE WITNESS: No. Well, we have a ledger that shows
the exact amounts, yeah.
THE COURT: Okay.
MR. EVERT: I believe it would be $4,000, not
$40,000.
THE COURT: Oh, it's $2,100 a month? A year?
THE WITNESS: No, a year.
THE COURT: A year, oh, okay.
THE WITNESS: It's annual, so...
THE COURT: I thought that sounded like a lot.
THE WITNESS: We just pay them once a year, not
monthly.
THE COURT: Okay. Got it. That makes a little bit
more sense.
BY MR. EVERT:
Q.
So do you know what Mr. Torjagbo or Delano's current
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
living situation is?
A.
I'm aware that he's incarcerated.
Q.
And when he first became incarcerated, was anyone looking
after 5114 Greythorne Lane on his behalf?
A.
Yes, we think so.
Q.
And who -- who was that?
A.
It was somebody that identified himself as kind of a
cousin and his name was Peter.
Q.
Is that person still looking after the property, to your
knowledge?
A.
No.
Q.
When did that person, Peter, stop doing so?
A.
It was early 2023.
Q.
Has anyone been looking after the property on
Mr. Torjagbo/Delano's behalf since April 2023, to your
knowledge?
A.
I don't believe so, no.
Q.
So what happened to 5114 Greythorne Lane after Peter
stopped looking after it?
A.
Well, the -- we believe the home was falling into
disrepair. The yard was not being maintained, no trimming, no
pine straw, no mowing. There was -- as an HOA, we're allowed
to go inspect the property if we feel it isn't being taken
care of, and there was debris in the backyard. It was
generally a mess.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
So some of the neighbors who see it every day from
the front of their homes were expressing concern at how bad it
was looking. And so the HOA started giving the appropriate
notice under our bylaws and covenants to the homeowner asking
them to take care of the yard.
Q.
I see.
MR. EVERT: May I approach, Your Honor?
THE COURT: Yes. Thank you.
BY MR. EVERT:
Q.
So I'm showing you what's been marked for identification
as Government's Exhibit 1.
Do you recognize this photograph?
A.
Yes, I do.
Q.
What does it depict?
A.
This shows the pool and backyard of 5114 Greythorne.
Q.
And where is this in relation to your house?
A.
This is -- his backyard backs up to my backyard. I'm
behind that row of trees that you see on the upper left of the
photograph.
Q.
And when was this photograph taken?
A.
I believe it was in the spring of this year.
Q.
Is this a fair and accurate depiction of the pool at 5114
Greythorne Lane as it appeared in the spring of 2024?
A.
Yes. Yes. It actually shows -- it's the -- for the
Court's reference, the pool had been covered --
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: Yes.
THE WITNESS: -- a year or so prior and so this is
standing water on top of the cover that's on the pool.
MR. EVERT: Your Honor, I would move to admit
Government's Exhibit 1.
MR. SILAS: No objection, Your Honor.
THE COURT: All right. Number 1 is admitted.
BY MR. EVERT:
Q.
And Ms. Franchi, how would you describe the color of the
water in this pool?
A.
Well, it's -- it's green and full of debris and swimming
things.
Q.
And what -- what is that in the -- I guess the bottom of
the photograph as it appears to --
A.
Yeah. I think that's just some branches that have fallen
from the trees. There's a lot of pine trees and foliage all
around the property and so there's a lot of debris in the pool
and all around the grounds, actually.
Q.
And there appears to be an item sort of in the middle of
the page, it's a little bit lighter in color than the water.
Do you know what that is?
A.
In the middle, are you referring to --
Q.
Okay. Yeah. In the middle here, this item (indicating)?
THE COURT: It looks like the sunk cover.
THE WITNESS: Yeah. I don't know if there's a --
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
like a tanning ledge or something, but I think that's just
part of the cover.
BY MR. EVERT:
Q.
Understood. Thank you.
THE COURT: Does it smell? Can you smell in it from
your house?
THE WITNESS: Not from my house. We are concerned
about what, you know, might be breeding over there. We can't
take care of the backyard because we believe the water has
been shut off. And plus it's cost prohibitive to maintain the
pool for the neighborhood.
THE COURT: Okay.
BY MR. EVERT:
Q.
So what did the HOA do in response to 5114 Graythorne Lane
falling into what you described as a state of disrepair?
A.
Right. Well, we -- we sent an appropriate notice. We
worked with our property management company to word it and
sent a notice as required by our bylaws and covenants to the
homeowner, which I believe gives ten days, you know, asks him
to take action or let us know what action they're going to
take within ten days.
MR. EVERT: Your Honor, may I approach?
THE COURT: Yes.
MR. EVERT: I've provided defense counsel with the
exhibits.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: Thank you.
BY MR. EVERT:
Q.
So I'm showing you what's been marked for identification
as Government's Exhibit 2.
What is this?
A.
This is the notice that we sent dated April 24th, 2023, to
Mr. Delano by U.S. mail, email and hand delivery, giving
notice of his noncompliance and asking him to take corrective
action to bring the yard up into compliance with the standards
of the neighborhood.
Q.
And did you participate in writing this letter?
A.
Yes, I did.
Q.
And is that your name at the bottom of the letter?
A.
That's correct, yes.
MR. EVERT: So I would move to admit Government's
Exhibit 2.
MR. SILAS: No Objection, Your Honor.
THE COURT: Okay. It's admitted.
BY MR. EVERT:
Q.
So can you please read the first paragraph of the letter?
A.
Yes.
Dear Mr. Delano, we write to you as the board of
directors of the Brookshire Manor Homeowner's Association to
remind you of the association's declarations of covenants
and/or rules regarding maintenance of the exterior of your
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UNITED STATES DISTRICT COURT
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home.
Specifically, each homeowner is required to main his
lot -- to maintain his lot, quote, in a neat, clean and
sanitary condition and such responsibility shall include but
not be limited to the maintenance and care of interior and
exterior surfaces of all improvements, buildings and other
structures located on the lot, including repainting and all
landscaping. And that's Article 6, Section 6.01.
Q.
And that paragraph mentions the association's declarations
of covenants.
What is that?
A.
Yes. Those are the governing documents that are prepared
in accordance with Georgia statutes that govern all of the
rules and responsibilities of each homeowner in the
neighborhood as well as the HOA.
Q.
And the letter says that each homeowner is required to
maintain his lot in a neat and clean and sanitary condition.
Was it the HOA's position that Mr. Delano was not
doing so?
A.
That is correct.
Q.
Okay. Would you please read the next paragraph?
A.
Yes.
The board has determined that your property is in
need of attention in order to be in compliance to maintain the
uniform quality and property values desired in Brookshire
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UNITED STATES DISTRICT COURT
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Manor.
Per the declarations, we request that you take
corrective action within ten days of receipt of this letter,
including mowing the lawn, weed control, maintaining the pool,
pressure washing all exterior surfaces, trimming/pruning
overgrown trees and brush, refreshing pine straw and/or mulch.
Q.
And was Mr. Delano not doing these things?
A.
He was not.
Q.
Thank you.
And in response to this letter, did Mr. Delano take
any action?
A.
No.
MR. EVERT: May I approach?
THE COURT: You may.
BY MR. EVERT:
Q.
I'm showing you what's been marked for identification as
Government's Exhibit 3.
What is this?
A.
This is the second notice that we sent to Mr. Delano as
required by the covenants dated June 12, 2023.
Q.
And did you participate in writing this letter?
A.
Yes.
Q.
And is that your name on the third page of the letter?
A.
Yes, it is.
MR. EVERT: I would move to admit Government's
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UNITED STATES DISTRICT COURT
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Exhibit 3.
THE COURT: Any objection?
MR. SILAS: No, Your Honor.
THE COURT: Did you admit 2 as well?
MR. EVERT: I believe I did, but if I didn't -- if I
forgot that --
THE COURT: 2 and 3 are admitted. Okay.
BY MR. EVERT:
Q.
And can you please read the first three paragraphs of this
letter?
A.
The first three?
Q.
Yes, the first three.
A.
Yes.
Dear Mr. Delano, this is a follow-up to our letter
dated April 24, 2023, regarding the care and maintenance of
the exterior of your home.
The HOA has determined that you have failed to make
the necessary corrections to bring your home into compliance
with the declaration of covenants, conditions, restrictions
and easements for Brookshire Manor.
The HOA has obtained an estimate for a one-time
cleanup or your yard by Gutierrez Lawn Care, LLC, for the
amount of $1,960 and biweekly maintenance of $140 per month.
We respectfully request that you complete this work
within ten days. Please note this includes landscaping only
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and does not include cleanup or maintenance of the pool, which
also needs attention.
This letter serves as notice of the HOA's intent to
exercise the right of abatement or self-help, if you do not
complete the landscape work within ten days pursuant to the
HOA's authority as provided in the declaration of covenants,
conditions, et cetera.
All amounts incurred in the maintenance of your
property will be your responsibility, will become due and
payable immediately and will be added to your assessment.
To the extent that any amounts become past due, all
collections, provisions in the declaration of covenants,
et cetera, and Georgia law will be enforced.
Q.
And what -- the letter mentions the right of abatement or
self-help.
Can you explain what that is, please?
A.
Under the bylaws and the covenants, if the HOA -- if a
homeowner is not maintaining their yard or home in compliance
within their responsibilities, the HOA has the authority to go
onto the property, undertake the work and add the cost of the
work to the homeowner's assessment.
Q.
And did Mr. Delano complete the work within ten days?
A.
He did not.
Q.
And so what did the homeowner's association do in
response?
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A.
We started self-help. And that means we started
maintaining the front of the home only because of budgetary
constraints.
Q.
And if you were to see a photograph of the front of the
home in -- how would you expect the condition of the front of
the home to look?
A.
The front looks okay. I mean, you can see that it needs
to be power washed and there needs to be trimming and, you
know, maintaining of the landscape, but we keep the yard
mowed, we do a trim once a year and we add pine straw once a
year.
Q.
And so how much did the landscaping -- in total, how much
has the landscaping cost the homeowner's association?
A.
It's -- well, it's $150 a month plus the cleanup, so it's
over $2,000 a year.
Q.
And I believe you mentioned that the homeowner's
association is only doing the landscaping for the front of the
house, correct?
A.
That's correct.
Q.
Is the homeowner's association doing anything to the back
of the house?
A.
That's correct.
Q.
Or is it doing anything?
A.
They are not. We're not doing anything for the back. We
are doing the front just to keep up appearances. You know,
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there is a home for sale in the neighborhood and the neighbors
want all the houses to look like they're maintained, at least
from the front.
The back is not really visible unless you walk back
there. And I don't think there is any water running, so
there's really no way to do a power wash or to maintain the
pool and we don't have the finances to undertake that expense.
Q.
Understood.
MR. EVERT: May I approach?
THE COURT: You may.
BY MR. EVERT:
Q.
So, Ms. Franchi, I'm showing you what's been premarked for
identification as Government's Exhibit 7.
Do you recognize this?
A.
Yes, I do.
Q.
What is it?
A.
This is the ledger that was prepared by our property
management company, which is PMI Terminus, they're on the
upper left, for the 5114 Graythorne property.
Q.
And have you confirmed that the numbers reflected in this
chart are accurate?
A.
Yes.
MR. EVERT: I would move to admit Government's
Exhibit 7.
THE COURT: Any objection?
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MR. SILAS: No, Your Honor.
THE COURT: It's admitted.
BY MR. EVERT:
Q.
And so starting at the bottom section, where it says
maintenance/repair charge 2024, can you explain what that is?
A.
Yes. Thrive Land Care was the landscape contractor that
we employed for calendar year 2024. So all of those entries
are the invoices that we received from Thrive for maintenance,
the mowing twice a month.
The entry for $750 down at the bottom, that includes
the trimming that we did, the pruning and the pine straw
application.
The top line there, previous balance, $1,300, that
was the carryover from calendar year 2023 where we started --
we started the self-help in July of 2023.
And the minus 150, the very last line, I found an
error in the carryover balance to that amount, 150, so PMI
just subtracted it at the end.
Q.
Understood.
And at the bottom, it says total for this section,
can you read that number, please?
A.
Total for the repair and maintenance is $3,400.
Q.
And so is $3,400 the amount that the HOA has spent on
maintenance of 5114 Graythorne Lane?
A.
That is correct, yes.
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Q.
The next section up says legal fees.
Can you please explain what those are for?
A.
Yes. Lueder, Larkin & Hunter is the law firm that we as
an HOA retain to protect the interests of the HOA and the
neighbors.
We did that in -- well, I guess the first invoice
there is in April, so it was earlier this year, 2024, and
he -- the attorney there, Stephen Finamore, undertook to
review all of the legal matters that were going on and he got
a lien recorded on behalf of the HOA to protect our financial
interests.
Q.
And are all of the numbers -- are all of the bills
reflect -- there related to the situation where -- in which
the house has fallen into disrepair?
A.
Yes, that is correct. We would not need an attorney, an
outside counsel but for this.
Q.
And there's a number previous balance.
Do you know what that is?
A.
Yes. Our previous management company had an in-house
counsel that we thought was doing this for us, but didn't do a
good job. And that was their legal fee, $75.
Q.
Understood.
So could you please read the total number for legal
fee?
A.
For legal fees, yes, $3,080.
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Q.
All right. And the next section up says collection admin.
fee, 2024. And then it provides a previous balance of $25.
Can you explain what that is?
A.
Yes. When the first dues went unpaid, the prior
management company sent it to their collections department so
that was their fee.
Q.
And the next section up says assessment homeowner 2024.
Can you please explain what that is?
A.
Yes. The 1650 is the first year that the dues went
unpaid. And then the 2150 is for calendar year 2024, where
the dues went unpaid, so a total of unpaid dues is $3,800.
Q.
And the 1650, that was 2023, was the first year?
A.
That's correct.
Q.
And the next section up is assessment homeowner,
parentheses, delinquent interest 2024 and it provides a
previous balance of $105.93.
Can you please explain what that is?
A.
Yes. So that was calculated by our prior management
company. And that would be the interest on the unpaid $1,650.
Q.
And then the final section here is titled assessment
homeowner, parentheses, delinquent fee 2024.
Can you please explain what that is?
A.
Yes. That's the interest, the $18 a month is the -- so
that's the interest on the 2150 that's delinquent and I think
that's divided by 12 months.
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Q.
And is the -- and then there's a line for previous
balance.
Can you explain what that is?
A.
Yeah. That would be the 10 percent of the 1,650 from the
prior year.
Q.
And what's the total balance?
A.
The total -- total interest there is $309.
Q.
And looking at the very bottom of the page, what is the
total of all of these?
A.
Yeah. The total ledger amount is $10,719.93.
Q.
And so is that all the money that the homeowner's
association has had to spend as a result of Mr. Delano's house
falling into disrepair?
A.
Yes. This -- up until the beginning of December, yes. Of
course it will continue.
Q.
And are you aware of any other issues at 5114 Graythorne
Lane?
A.
Yes. There have been other issues.
Q.
Can you briefly describe those, please?
A.
Yes. At some point, we became aware that one or more
individuals, it looked like they were trying to occupy the
home without any legal authority or permission from the
homeowner.
Q.
And approximately when -- when was that going on?
A.
That would have been in the spring or -- spring of this
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year, 2024.
MR. EVERT: No further questions, Your Honor.
THE COURT: Did somebody chase them away, the
squatters or the potential squatters?
THE WITNESS: It was a group effort, yes.
MR. EVERT: I anticipate the next witness will
testify about that.
THE COURT: Okay. Cross-examination?
MR. SILAS: Yes, Your Honor.
THE COURT: Okay.
CROSS-EXAMINATION
BY MR. SILAS:
Q.
Good morning, Ms. Franchi.
A.
Good morning.
Q.
I've got a few questions for you.
A.
Okay.
Q.
So I understand that you live in the home that is next to
5114 Graythorne Lane; is that right?
A.
That's correct.
Q.
So you see this property on a regular basis; is that
right?
A.
It's a small neighborhood and we see it when we're walking
around the neighborhood.
Q.
Okay. And do you walk on that street where 5114
Graythorne Lane is?
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A.
Yes.
Q.
So do you walk past that property?
A.
All the time.
Q.
All the time.
Did you walk past it today?
A.
Not today.
Q.
Over the weekend?
A.
Yes.
Q.
Okay. And as I understand it, one of the concerns about
the condition of 5114 Graythorne Lane is that it impacts
potentially the property values of the entire neighborhood; is
that right?
A.
The neighbors are concerned about that, yes.
Q.
And you are the homeowner's association president, right?
A.
No, I'm the treasurer.
Q.
You're the treasurer, okay.
But you also as both an officer of the homeowner's
association and also a resident in the neighborhood, you have
some concern about the appearance and upkeep of that
particular property, right?
A.
Yes, that's correct.
Q.
And as you mentioned, there were a couple of demand
letters that were sent out to Mr. Torjagbo, or Mr. Delano, as
you may know him, and there was no response to those demand
letters, right?
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A.
That's correct.
Q.
Is it your understanding -- it's your understanding now
that Mr. Delano has been -- is currently incarcerated,
correct?
A.
That's my understanding.
Q.
Is it your understanding now that throughout this period
where there were demand letters sent and then subsequent
self-help that Mr. Delano was incarcerated throughout that
period?
A.
Yes.
Q.
Okay. And it's your understanding that at one point,
there was a relative of Mr. Delano's who was sort of
exercising or engaging in some sort of maintenance or upkeep
on the property; is that right?
A.
That's right.
Q.
But that discontinued at some point?
A.
Yes.
Q.
And there was a landscaping company that was hired by the
homeowner's association to do -- to maintain the yard and the
exterior of the property; is that right?
A.
Right.
Q.
Was the name of that landscape company Gutierrez
Landscaping; is that right?
A.
It ended up not -- we got an estimate from Gutierrez
Landscaping, and we ended up choosing a different contractor
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to do the work.
Q.
Oh, is that Thrive that you-all ultimately chose?
A.
That's correct, it was Thrive.
Q.
Okay. And I understand it, Thrive comes out twice a month
to do the upkeep on the outside; is that right?
A.
They come twice a month to mow the front yard.
Q.
Okay. And they're coming and mowing the yard that has
continued up until this point; is that right?
A.
Since July 2023, yes.
Q.
Okay. And do you have a copy of Government's Exhibit 7 up
there with you?
A.
Yes.
Q.
And I wanted to ask you a question about the
maintenance/repairs charged 2024 section at the bottom.
A.
Yes.
Q.
You know we see a listing of various charges beginning on
May 10th of 2024 down through December 3rd, 2024, but at the
very beginning, there is a previous balance section of $1,300.
Was that charges that were accumulated through Thrive
for some point prior to May of 2024?
A.
Yes, we changed property management companies starting
January 1, 2024, so the previous balance is the landscape
charges from the previous management company so it's a
different ledger.
So this management company, PMI, took that
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information and put it in their own ledger as previous balance
so that carries over from 2023.
Q.
Okay.
A.
And also the dates on the left are the dates that this
management company entered the information to compile the
ledger.
Q.
Okay.
A.
It's not the date that the work was done. Okay?
There's an invoice number for each one and the
invoice -- and the invoices themselves have the date of the
work.
Q.
Okay. I had a question also about the -- at the very
beginning in the top section where it says assessment, dash,
homeowner delinquent fee, 2024 and it has a previous balance
of 165, and you indicated that that is 10 percent of 1,650,
which is correct.
But why is that a -- why is that a charge that's
listed there?
A.
That's the interest. We're allowed to charge 10 percent
interest on delinquent assessments.
Q.
Okay.
A.
And that was for 2023, so that was -- it says previous,
that was the prior management company.
Q.
I want to show you a couple of photographs here. I'll
mark the first Defendant's Exhibit 1 and the second
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Defendant's Exhibit Number 2.
Ms. Franchi, do you recognize what is depicted in
that photograph?
A.
Yes.
Q.
What is -- what is shown there?
A.
That's 5114 Graythorne Lane.
Q.
So that is the property that is at issue in this
proceeding where the homeowner's association is I guess
engaged in self-help to sort of improve the -- or maintain the
exterior of the property?
A.
Yes.
Q.
And that's the property that Mr. Delano has -- that he
owns and has resided at?
A.
Yes.
Q.
And is that a fair depiction of what that property looks
like now?
A.
Well, you can't really see the yard.
Q.
But from that angle, from that --
A.
This part is my yard.
Q.
Okay. So that's -- so you're right next to door to it?
A.
Yes.
Q.
So if we were standing in that part of your yard or next
to that part of your yard, that is what you would see if you
were looking at 5114 Graythorne Lane?
A.
Yes. But you're not -- this doesn't show it directly in
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front of the side -- you know, a direct full frontal view of
his home.
Q.
Okay. But that being said, that is an angle of what the
property looks like, right?
A.
That is correct, yes.
MR. SILAS: I would move into evidence Defendant's
Exhibit Number 1, Your Honor.
THE COURT: Any objection?
MR. EVERT: No objection.
THE COURT: May I took a look at it, though?
MR. SILAS: Yes, Your Honor.
THE COURT: Unless you have a copy for me.
MR. SILAS: I do -- I can give you one, Your Honor.
THE COURT: That would be great. Yes.
MR. SILAS: I mismarked this, Your Honor. I'm sorry.
THE COURT: That's okay.
MR. SILAS: And, Ms. Franchi --
THE COURT: So this is your yard here?
THE WITNESS: That's correct.
THE COURT: That's the house at issue?
THE WITNESS: Yes.
THE COURT: But you really can't see the yard because
your yard is in the way, right?
THE WITNESS: In this picture.
THE COURT: Okay. Fair enough. Thank you.
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MR. SILAS: And, Your Honor, I'm going to --
BY MR. SILAS:
Q.
Well, Ms. Franchi, I have a second picture to show you.
A.
Okay.
Q.
Is that another picture of 5114 Graythorne Lane?
A.
Yes.
Q.
The house next to yours?
A.
That's correct.
Q.
And this is a property -- this is a view that's from more
the frontal view of the house, right?
A.
Yes, it is.
Q.
And you can see the driveway and you can see -- you know,
you look down directly at the front of the house; is that
right?
A.
Yes.
MR. SILAS: Your Honor, I would move into evidence
Defendant's Exhibit Number 2.
MR. EVERT: No objection.
THE COURT: It's admitted.
MR. SILAS: And I have a copy for the Court,
Your Honor.
THE COURT: Thank you.
So now I'm looking at a driveway. Is that the
driveway to the house at issue?
THE WITNESS: Yes, yes.
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THE COURT: And we can see across the yard to the
house, correct?
THE WITNESS: Correct.
THE COURT: Okay.
BY MR. SILAS:
Q.
And again the yard that we see it as -- as shown in that
photograph is as it is currently being maintained by Thrive
Land Care, right?
A.
Well, I don't know when this picture was taken, but yes.
Q.
Okay.
THE COURT: This is far better than what it looked
like when you-all began self-help?
THE WITNESS: Yes. Because the grass is at least
low. But you can see how overgrown all of the trees and
shrubs are and the driveway -- you can't really see as much in
this picture, the driveway and sidewalks are really dark and
moldy because it hasn't been power washed, but, you know, you
can hardly see -- the front door is there (indicating).
THE COURT: Yes.
THE WITNESS: And, you know, all of this is
overgrown.
THE COURT: Okay.
THE WITNESS: And, you know, the backyard is far
worse.
THE COURT: Right. Because you-all haven't done
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self-help in the backyard?
THE WITNESS: That's correct.
BY MR. SILAS:
Q.
And from standing from the front, though, at those vantage
points that are depicted in Defendant's Exhibits Numbers 1 and
2, you can't see the backyard; is that right?
A.
That's right.
Q.
And I understand that the homeowner's association is
working with an attorney to sort of protect the interest of
the collective set of homeowners in that neighborhood, right?
A.
Yes.
Q.
And there are fees listed here for $3,080 that have been
paid to date to that lawyer?
A.
Yes.
Q.
And is that in relation -- for services rendered in
connection with this effort to maintain the
5114 Graythorne Lane property?
A.
Yes. And, yes, to protect our interest as an HOA.
Q.
Okay. And have you consulted with that lawyer about the
possibility at some point of seeking sort of recompense from
Mr. Delano for the fees that have been charged for that -- for
these services?
A.
Well, it's my understanding with -- after talking with the
lawyer that our recourse is to have a lien filed on the home.
And when the home is sold, however the priority of liens
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shakes out, that's how we would get the monies returned.
Q.
And eventually, when the -- whenever the property is sold,
whether it be next month or next year, if there was a lien
that's been put in place, you would expect that the homeowners
would be able to recoup the expenses that they've incurred; is
that right?
A.
In theory. But if the home value sinks so low that it
doesn't cover the liens, then there's not going to be enough
money left.
Q.
And you don't know any -- I mean, you don't have an
understanding about the -- whether there's a mortgage on the
property or anything like that, do you?
A.
I don't believe there is a mortgage.
Q.
Okay. So you don't believe that there is a mortgage on
the property, so at this point, the property is owned free and
clear?
A.
There's a federal lis pendens on it.
Q.
Aside from the lis pendens, but what -- but in terms of
the valuation of the property, what you're talking about in
terms of what may be recouped upon sale is whatever the sale
price is but with no deduction going to a -- going to a --
going to a bank?
MR. EVERT: Objection.
THE WITNESS: Not --
MR. EVERT: It exceeds the scope of the direct
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examination.
THE COURT: I'm going to overrule it. The point is
that they could get their money -- if they just keep paying
for him, maybe they can get their money back upon the sale,
correct?
MR. SILAS: Correct, Your Honor.
THE COURT: So, I mean, in other words, right now,
he's not paying his fair share, right?
THE WITNESS: Right. The neighbors are paying for
it.
THE COURT: Yes. You're also having to come out of
pocket to pay for upkeep.
THE WITNESS: Yes.
THE COURT: You're also having to come out of pocket
to pay for a lawyer.
THE WITNESS: Yes.
THE COURT: And you're also coming out of pocket
because you haven't -- you're losing interest that you would
get, right?
THE WITNESS: Yes.
THE COURT: All of which you're accounting for in
detail, right?
THE WITNESS: Of the actual expenditures, but this
doesn't account for a decrease in the property value.
THE COURT: Of course not.
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THE WITNESS: And the government lien and the tax
lien, because public records show no taxes have been paid.
THE COURT: Yes. Your little piece of this is that
it's an eyesore. It's difficult for your neighbors. He's not
a good neighbor. And it's actually now costing you money.
THE WITNESS: Correct.
THE COURT: Okay. And maybe you would have a
right -- have your lawyers told you that if you wait and wait
and wait, if this house is ever sold that you can then file a
lien for however much you're owed, right?
THE WITNESS: Yes, the lien has been recorded.
THE COURT: Yes. So if it creeps up to 30,000 in
three years or 40,000, you can then come and recover that
amount of money, right?
THE WITNESS: In theory, yes.
THE COURT: In theory correct. Yes.
Okay. Anything else you want to ask about that
issue?
MR. SILAS: No. No, Your Honor. Just one last
question.
THE COURT: We all know that's the truth, right?
MR. SILAS: Right.
THE COURT: I don't know, maybe one of the things
that matter is -- we're not here about whether he's a bad
neighbor.
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THE WITNESS: Correct.
THE COURT: And whether he's abusing the relationship
that he has with the other people there. That's your fight.
THE WITNESS: Yeah. It's the value of the home.
THE COURT: Yes.
THE WITNESS: And the safety, if there are
unauthorized people in there, which is against all of our
interests.
THE COURT: Exactly right.
And the issue for me is whether there is specific
things that matter under the law so that I can force or allow
the government to force a sale. And whether he's a bad
neighbor may not be enough.
Do you understand that?
THE WITNESS: Of course.
THE COURT: But I don't know, maybe it will be when
they tie it with all of the other stuff, but I think that's
kind of where we are, right?
MR. SILAS: That's right.
THE COURT: So far, there's not a single fact in
dispute as far as I can tell, is there?
MR. SILAS: There doesn't seem to be much so,
Your Honor.
THE COURT: What does the government say?
MR. EVERT: I don't think there's been anything in
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dispute so far.
THE COURT: He's a bad neighbor and he's taking
advantage of these people and he's making them do all of these
things that he's not doing.
MR. SILAS: Well, I would retract, I guess my last --
I wouldn't say that he was a bad neighbor. I wouldn't agree
on that part, Your Honor.
But I would say, yes, that the homeowner's
association are incurring --
THE COURT: Okay. I won't put a subjective label on
it. He's not paying his fair share. He's not keeping up his
property. He's causing the neighborhood to do those things
and he's causing lot of anxiety and frustration for all of his
neighbors and potentially the diminution in value.
Whether that makes him, quote, a bad neighbor, close
quote, or not, those are the facts that are not in dispute,
right?
MR. SILAS: I can't speak to the neighbor's anxiety.
I can see that they say -- I could understand and I can see
from Ms. Franchi's testimony and also obviously from the
demand letters that the neighbors have some concern about the
property, yes.
THE COURT: Wouldn't you?
MR. SILAS: Well, I don't want to speak to myself,
Your Honor.
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THE COURT: No. But I mean seriously, though,
wouldn't anybody feel that way if they had a house like this
next door to them and every -- most people, for most people,
their home is their primary asset.
It's also where they spend most of their time and
want to relax. And to have something like this is -- I think
it would be bothersome to anybody, don't you?
We don't check our humanity and normalcy because
we're lawyers. I think every -- how can you not admit that?
MR. SILAS: I don't want to make myself a witness,
Judge.
THE COURT: You're not a witness.
MR. SILAS: So but I certainly understand the Court's
point, Your Honor. I appreciate it. And I absolutely hear
the Court loud and clear on it. I just wanted to make one --
one last point, Ms. Franchi, which is --
THE COURT: Sure.
BY MR. SILAS:
Q.
-- that when you -- I think in the earlier part of your
testimony, I think that you said that the typical homeowner --
the value of these homes in this neighborhood range from about
1.5 to about $2.8 million, right?
A.
That's correct.
Q.
And we would expect that based on what this house was --
do you know what this house was sold for when it was initially
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purchased in 2021 by Mr. Delano?
A.
I don't know. I think it was listed for maybe 2.6 or 2.8.
Q.
Something north of that 1.5 number?
A.
Yes. Yes. It's a big, beautiful -- it was a beautiful
custom home and they're expensive to maintain.
MR. SILAS: That's all I have, Your Honor.
THE COURT: Okay. Thank you.
Any redirect?
MR. EVERT: No, Your Honor.
THE COURT: Okay. Thank you very much for coming
down. I appreciate it.
THE WITNESS: Thank you.
MR. EVERT: And may the witness be excused?
THE COURT: Yes, you may.
THE WITNESS: Thank you.
THE COURT: Thank you.
MR. EVERT: Oh, yeah.
Your Honor, we would call Detective Adriano Ghisi.
THE WITNESS: Okay.
- - -
ADRIANO GHISI,
A witness herein, having been first duly sworn, was examined
and testified as follows:
- - -
COURTROOM DEPUTY: Thank you.
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For the record, will you please state and spell your
first and last name?
THE WITNESS: Detective Ghisi. First name
A-D-R-I-A-N-O, last name Ghisi, G-H-I-S-I.
COURTROOM DEPUTY: Thank you.
DIRECT EXAMINATION
BY MR. EVERT:
Q.
Mr. Ghisi, where do you work?
A.
I work with Cobb County Police Department.
Q.
And what is your title there?
A.
I am a police detective with the criminal investigation
unit.
Q.
And how long have you been a detective with the criminal
investigation unit?
A.
A detective coming on four years now.
Q.
And how long have you worked for the police department
overall?
A.
I've been employed with Cobb County since April of 2018.
Q.
Are you familiar with a property located at
5114 Graythorne Lane in Marietta, Georgia?
A.
I am.
Q.
How did you become familiar with it?
A.
The property in which you're referring to came to my desk
as a theft report, a report was taken where the complainant
was alleging a possible theft involving a family member.
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Q.
And who -- who was the complainant in that incident?
A.
It was Mr. Carl Torjagbo.
Q.
And who was the person that he accused of potential theft?
A.
It would be Mr. Peter Irie. I think that's how you
pronounce it.
Q.
And who is the owner of 5114 Graythorne Lane, to your
knowledge?
A.
Carl Torjagbo.
Q.
How do you know that?
A.
This is information that I found on a Cobb County tax
assessor's website.
Q.
And have you ever spoken with Mr. Torjagbo about squatters
in his house?
A.
I have.
Q.
Was anyone else on that call?
A.
Yes.
Q.
Who -- who was that?
A.
Mr. Silas, his defense attorney.
Q.
What, if anything, did Mr. Torjagbo say about who had
permission to be in his home?
A.
So during our conversation -- and I believe you're
referring to when I obtained a criminal trespass letter,
during that conversation, he advised that only one person,
Mr. Gonzo, was the one authorized to be at the home while he
was away.
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Q.
And other than Mr. Gonzo, had anyone previously had
permission to be at his home?
A.
Previously, yes.
Q.
And who was that?
A.
Mr. Petey -- oh, sorry, Peter Irie.
Q.
And other than Mr. Gonzo and Mr. Irie, was anyone else
permitted to be at the home?
A.
Negative, no.
Q.
And are you aware of anyone other than Mr. Irie and
Mr. Gonzo being inside the house at 5114 Graythorne Lane?
A.
Yes.
Q.
Who?
A.
A male by the name of Brian Holland and an unknown female.
Q.
Did you speak with Mr. Holland on the phone?
A.
I did.
Q.
When was that?
A.
This was -- I believe it was a couple of months after the
investigation was initiated, so I don't recall the date
correctly. I would have to look at my report.
Q.
If I -- if I showed you your report, would that refresh
your recollection?
A.
Yes.
MR. EVERT: May I approach?
THE COURT: Yes.
MR. EVERT: This is his report.
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MR. SILAS: Oh, okay.
THE WITNESS: Thank you. So I spoke to
Mr. Brian Holland on Tuesday, May 14th.
BY MR. EVERT:
Q.
Of what year?
A.
2024.
Q.
And what did -- what, if anything, did Mr. Holland say
about whether he had been in the house at
5114 Graythorne Lane?
A.
I did inquire about his interaction with Mr. Irie at the
house. Mr. Holland claimed that he called Cobb County, I
don't know what number he called, but he claimed that he
called Cobb County, obtained a list of homes with unpaid
taxes.
He goes then and pays the taxes for the home. Then
he says that because he paid the taxes of the home, he went to
the house and entered the home uninvited.
Now, because he paid the taxes, he decided to put no
trespassing signs on the home, therefore now he had a claim to
the house. Our conversation initiated that way.
I then looked into this information. I called the
Cobb County tax assessor's website to follow up on an update
on the status of the home, had the home been placed on
auction, was it foreclosed, Cobb County confirmed it was not.
I then checked that information with the DA's office
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and also one of my supervisors is an attorney, and I ran this
by them. And we all were in agreement that somebody cannot
just out of the blue enter a home and claim it's their own.
So then I talked to Mr. Brian Holland and I
confronted him with this information. He claimed he had a
legal right to the home and I said, no, you do not.
And because there's a criminal investigation, if I
happen to arrive at this home and somebody who's not
authorized to be there is there, I will charge them.
And then that's what I decided to do with Mr. Carl
was to obtain a criminal trespass letter, because at the time,
to my knowledge, he is the homeowner of the home, so I
obtained that letter so our officers could issue a CT warning
to anyone.
Q.
And you mentioned Mr. Holland maybe saying something about
paying the taxes.
Are you aware of whether he, in fact, paid taxes on
the home or is that just something that he either said he did
or was planning to do?
A.
So he claimed he did. During my conversation with Cobb
County tax assessor's office, they said the taxes were unpaid.
THE COURT: So who is this guy?
THE WITNESS: It's a -- it's just a random person
that --
THE COURT: Is he random to you-all, too?
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MR. EVERT: I'm not familiar with him.
THE COURT: So he just said he paid the taxes and
therefore he now had possession of the home and he didn't even
pay the taxes and yet paying the taxes doesn't give you
possession; is that kind of the long and short of it?
THE WITNESS: That's correct, yes, sir.
THE COURT: Okay.
BY MR. EVERT:
Q.
And how did Mr. Holland come to your attention in the
first place?
A.
So when I spoke to Mr. Gonzo and Mr. Irie, they made me
aware. Mr. Irie during his misunderstanding with Mr. Carl,
Mr. Irie was in possession of Mr. Carl's BMW, so he goes -- he
said I don't -- because I don't want the situation to escalate
beyond what it is now, I want to return this car.
He goes to the home, returns the car. When he
arrives, Mr. Holland and a female are inside of the home. He
confronts them, talks to them, why are you here? Who are you?
And that's when the story with the taxes, I have an
interest in this home came about.
Mr. Irie went to his vehicle to grab something. When
he comes back, the male and the female are gone in the wind.
He claims that he then called the male, because at
this time he had his phone number and a copy of his driver's
license. Said where did you go?
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And he was like I talked to my attorney, my attorney
advised that I should not come back to this house. And that's
how I came across this.
Q.
And when you talked to Mr. Holland, that was after that
interaction, but he was still asserting that he had some sort
of right to the property; is that correct?
A.
That's correct.
Q.
And since your conversation with Mr. Holland, do you know
if anyone other than Mr. Gonzo and Mr. Irie have been on the
property?
A.
Yes. So I spoke to the HOA soon -- soon after this
incident. And because I was conducting an active
investigation, I said any issues that you have with this home,
let me know, I need to find out.
So I was notified by patrol, like, hey, we responded
to this address again. You have a criminal trespass letter,
right? And I say yes.
So they get to the address, there is a male there, an
unknown male, that said, Hey, Mr. Holland said that I could
stay at the house.
Officers, of course, explained like he has no right.
You need to get out. So they leave.
Days after, we get another call. Officers respond to
the residence. When they get there, somebody runs inside the
house and they don't answer the door.
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So after that, I have no more knowledge, I haven't
been in touch, I haven't received any updates or anything.
Q.
And approximately this second incident after the stuff
with Mr. Holland when -- when approximately did that occur?
A.
I would say this was probably one or two months after
Mr. Holland's incident.
Q.
Okay. And so Mr. Holland's incident was -- remind me,
sorry, when was Mr. Holland's incident?
A.
I spoke to him in May.
Q.
In May.
A.
So this would have happened within a month or two after
that, yeah.
Q.
So June or July, approximately?
A.
That's correct, yes.
MR. EVERT: No further questions, Your Honor.
THE WITNESS: Okay.
THE COURT: Any redirect?
MR. SILAS: Just a little cross, Your Honor.
THE COURT: Sure. I'm sorry, I mean any cross.
CROSS-EXAMINATION
BY MR. SILAS:
Q.
Detective Gonzo -- I'm sorry. I'm sorry.
Detective Ghisi, rather, I'm sorry.
A.
Yes, sir.
Q.
Your involvement with this property came initially because
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there was a report by Mr. Torjagbo of concern, I guess, in
relation to a theft, that he thought that family members had
taken some things from his property; is that right?
A.
Correct.
Q.
And eventually, you reached out to Mr. Torjagbo via phone
with his lawyer, me, also on the phone call, where you
informed Mr. Torjagbo that you -- that the results of your
investigation were essentially that this was a civil issue
between him and his family members about missing property from
the house?
A.
That's correct.
Q.
Okay. Subsequently, you reached back out to Mr. Torjagbo
because you had learned about Mr. Holland having been on the
property, right?
A.
Correct.
Q.
You had talked to Peter -- Irie is how I pronounce it --
and he indicated to you that he had gone to take the BMW back
to the property and he encountered Mr. Holland when he was
there, right?
A.
Correct.
Q.
Okay. And subsequently, you did your own investigation
about whether or not there could be some truthfulness to what
Mr. Holland says about how he claimed to have paid the taxes
and obtained the right to be on the property, right?
A.
Yes.
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Q.
And you learned that what he was saying didn't hold water
essentially, right?
A.
Correct.
Q.
One, that you can't actually obtain a possessory interest
in a property that way, right?
By -- and you learned that by contacting the Cobb
County tax assessor's office, right?
A.
Correct.
Q.
And also by consulting with your colleagues, basically,
right?
A.
Yes.
Q.
And you also even learned that Mr. Holland actually hadn't
even paid the taxes, right?
A.
Correct.
Q.
So you contacted him directly and told him do not come
back to this property?
A.
Correct.
Q.
And if you do, you will be arrested, right?
And as far as we know, Mr. Holland hasn't been back
to the property, right?
A.
As far as I know, yes.
Q.
I mean, you've not seen him and there have been no
Cobb County police officers who have informed you or made
reports that Brian Holland has been back to that property?
A.
As far as I know, correct.
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Q.
And as far as you know, no neighbors have called to the
police to say Mr. Holland is back?
A.
To my knowledge, no.
Q.
Okay. And the neighbors have reached out to the police
after that to say, hey, there's somebody else here on this
property, right?
A.
Correct.
Q.
Okay. And did that then lead to uniformed officers going
out to the property then and having a second incident where
they encountered people on the property?
A.
Yes.
Q.
And they told them by this point, hey, there has been a
trespass letter that's been signed by Mr. Torjagbo saying that
there's only one person essentially who has authorization --
his authorization to be on the property, right?
A.
Correct.
Q.
And that would be his friend, Brahim Ganzou, right?
A.
Ganzou, yes.
Q.
Anybody else, if the Cobb County encountered those people
on the property, they're subject to being arrested, right?
A.
Correct.
Q.
Okay. So that resolved that matter when -- the second
time when the Cobb police went to the property and they told
those people you'd better leave or else you're going to be
arrested, right?
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A.
Correct.
Q.
And then there was I think one more time, as far as you
know, something like this happened where a male was there and
the police -- I guess there was a call to the Cobb County
police again about somebody being on the property, right?
A.
Correct.
Q.
And this time, that person also said Brian Holland told me
I could come here, right?
A.
If that's the one I mentioned earlier, yes.
Q.
Okay. And again, that person was informed that they had
to leave or else they would be arrested, right?
A.
Correct.
Q.
And as far as you know, since then there have been no more
incidents of people coming to the property.
A.
There was one additional incident. The one I mentioned
where officers arrived and a squatter or whoever it is, an
unknown person rushes inside of the home, locks themselves in
and don't answer the door.
Q.
Okay.
A.
So there's that one incident. Other than that, I have not
been personally notified. If the officers answered to the
residence, I have no idea, I haven't been told.
THE COURT: How did you get that guy out?
THE WITNESS: I have no idea how -- how they followed
up with that case.
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BY MR. SILAS:
Q.
And you don't know what actions were taken by the
uniformed officers after that point?
A.
I do not at that point, because my investigation had been
concluded on the theft allegation. I have no knowledge of
what happened afterwards.
THE COURT: Right. You only got involved because he
called you to get you involved.
THE WITNESS: Correct.
THE COURT: And that led to these other incidents
you're aware of.
THE WITNESS: That is correct.
THE COURT: But you don't know whether there have
been other problems that neighbors or other people have had to
go over there and respond to things of that nature?
THE WITNESS: Correct.
BY MR. SILAS:
Q.
But as far as you know, at this point, I understand that
your knowledge is limited, because your personal investigation
has been concluded, but as far as you know, there are no
squatters on the property at this point?
A.
At this point, I'm not aware. I have no knowledge of
this.
THE COURT: One way or the other?
THE WITNESS: Correct.
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BY MR. SILAS:
Q.
And, again, as far as the incident where the person -- the
last incident where the person runs back into the house, that
was several months ago; is that right?
A.
I would have to check our call history. I don't remember
how long ago it was.
MR. SILAS: That's all I have for this witness,
Your Honor.
THE COURT: Okay. Any redirect or is this witness
excused?
MR. EVERT: Nothing, Your Honor.
THE COURT: Okay. Thank you very much.
THE WITNESS: Thank you.
THE COURT: I'm still not sure there are any factual
issues here that are in dispute, are there?
He doesn't live at the house so he doesn't know
what's going on there. And when a friend or a family member
was taking advantage of him or he thought he was, he called
the police and that led the police to be aware of other
things. But there's nobody at the house on a day-to-day
timeframe to make sure that these things don't repeat.
MR. EVERT: Yes.
And then, Your Honor, we would call our next witness,
Scott Caruana of the Federal Bureau of Investigation.
THE COURT: Okay.
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- - -
SCOTT CARUANA,
A witness herein, having been first duly sworn, was examined
and testified as follows:
- - -
COURTROOM DEPUTY: Thank you.
For the record, will you please state and spell your
first and last name.
THE WITNESS: First name is Scott, S-C-O-T-T. Last
name is Caruana, C-A-R-U-A-N-A.
DIRECT EXAMINATION
BY MR. EVERT:
Q.
Special Agent Caruana, where do you work?
A.
For the Federal Bureau of Investigation.
Q.
And what is your title there?
A.
I'm a special agent.
Q.
And how long have you been a special agent with the FBI?
A.
Approximately 22 and a half years.
Q.
Are you familiar with 5114 Graythorne Lane in Marietta,
Georgia?
A.
Yes, I am.
Q.
And how did you become familiar with it?
A.
That is the property that came under investigation
involving a Carl Torjagbo.
Q.
Do you know when it was purchased?
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A.
I believe it was sometime in 2021.
Q.
And do you know how it was purchased?
A.
Proceeds of the substantive fraud in the case that I'm
investigating.
Q.
Do you know if there are currently any taxes owed on the
property?
A.
Yes, there are.
Q.
How do you know?
A.
Through my investigation. And they're located on the
county website for the property in Cobb County.
MR. EVERT: May I approach?
THE COURT: You may.
BY MR. EVERT:
Q.
I'm showing you what's been premarked for identification
as Government's Exhibit 4.
What is this?
A.
I'm sorry?
Q.
What -- what is this?
A.
This is a -- the listing of the property tax transactions
that was located on the Cobb County website, property tax
website.
Q.
Is this a fair and accurate representation of the
Cobb County tax website as it appeared -- or what --
Do you know when this was taken?
A.
This was taken -- it was last week when I looked at the
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unpaid property taxes.
Q.
Does December 3rd sound right?
A.
I believe -- yes, I believe it was like a Thursday,
Wednesday or Thursday, December 3rd.
Q.
So is this a fair and accurate representation of the
Cobb County tax website as it appeared on December 3rd of
2024?
A.
It is.
MR. EVERT: I would move to admit Government's
Exhibit 4.
MR. SILAS: No objection, Your Honor.
THE COURT: Okay. 4 is admitted.
BY MR. EVERT:
Q.
So looking at the line for 2022, how much is owed in taxes
for 2022?
A.
Unpaid taxes for 2022 are $22,546.49.
Q.
Next line, looking at the line for 2023, how much is
unpaid in taxes for 2023?
A.
For 2023, $23,095.35.
Q.
And looking at the line for 2024, how much is owed in
taxes for 2024?
A.
For 2024, it's $20,799.46.
Q.
And in Cobb County, when are property taxes for a given
year due?
A.
October the 15th.
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Q.
So is it correct that the total amount of unpaid taxes for
5114 Graythorne Lane in Marietta, Georgia, is $66,441.28?
A.
That's correct. That's the total of those three numbers
that I just recited.
Q.
I don't expect you to be able to do that math on the fly,
so...
Are you familiar with a property located at 101
Holt Drive in Acworth, Georgia?
A.
Yes, I am.
Q.
How are you familiar with it?
A.
That's another property that came up in my investigation
involving Carl Torjagbo. And the government filed a
lis pendens on that as well.
Q.
Do you know when that was purchased?
A.
I don't recall. I believe it was sometime in 2021 as well
with the proceeds of the fraud in my investigation.
Q.
And what kind of property is that?
A.
It's undeveloped land.
Q.
And do you know if there are any taxes currently owed on
the property?
A.
Yes, there are.
Q.
How do you know?
A.
Again, the Holt Drive is in Cherokee County. And I
consulted with the Cherokee County property tax website and
identified that the unpaid -- that the property taxes were
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unpaid as well.
MR. EVERT: May I approach?
THE COURT: You may.
MR. EVERT: Thank you.
THE COURT: Thank you.
BY MR. EVERT:
Q.
So I'm showing you what's been premarked for
identification as Government's Exhibit 5.
What is this?
A.
This is the property tax schedule for the property located
at 101 Holt Drive in Cherokee County.
Q.
And is this a fair and accurate representation of the
Cherokee County website as it appeared on December 3rd, 2024?
A.
Yes, it is.
MR. EVERT: I would move to admit Government's
Exhibit 5.
THE COURT: Any objection?
MR. SILAS: No, Your Honor.
THE COURT: Then it is admitted.
BY MR. EVERT:
Q.
So looking at the line for 2022, how much is due in taxes?
A.
For 2022, the amount of unpaid taxes is $3,962.78.
Q.
And when was that due?
A.
November 15th of 2022.
Q.
Then the next line up is 2023.
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Can you say what the amount due in taxes is?
A.
The amount due for 2023 was $2,118.42. And the due date
of that was 11/15 of '23.
Q.
And looking up at the next line for 2024, can you please
say what the amount due is?
A.
$1,855.89. And that was due on November 15th of 2024.
Q.
And I'm not going to give you a math quiz.
So is it correct that the total of those numbers is
$7,937.09?
A.
Yes. And just to note the deed name on this schedule is
under the name of FlyingJack Freight and Logistics, LLC. That
is a company owned by Mr. Torjagbo.
Q.
And are you familiar with the property located at Tract 4,
Fiber Drive in Cartersville, Georgia?
A.
Yes, I am.
Q.
How are you familiar with it?
A.
Again, that's a property that came up in my investigation
with -- of Carl Torjagbo. And the government filed a
lis pendens on that property as well.
Q.
And what kind of property is that?
A.
It's undeveloped land.
Q.
Do you know when it was purchased?
A.
Yeah, sometime in 2021.
Q.
And do you know how it was purchased?
A.
With proceeds of the fraud of the instant case.
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Q.
Do you know if there are currently any taxes owed on that
Fiber Drive property?
A.
Yes, there are.
Q.
How do you know?
A.
I consulted the Bartow County website and that website
listed the amount of unpaid taxes.
MR. EVERT: May I approach?
THE COURT: You may.
Thank you.
BY MR. EVERT:
Q.
Excuse me. So I'm showing you what's been premarked for
identification as Government's Exhibit 6.
What is this?
A.
This is the printout from the Bartow County tax website
showing the amount of tax activity for the
5114 Greythorne Lane. And it shows the amount that is due and
outstanding -- outstanding and due.
Q.
And looking at the top right corner of this document, what
was the date when it was printed?
A.
It was printed on December 4th of 2024.
MR. EVERT: I would move to admit Government's
Exhibit 6.
THE COURT: Any objection?
MR. SILAS: No, Your Honor.
THE COURT: It is admitted.
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BY MR. EVERT:
Q.
Can you please read the total due at the bottom?
A.
The total due is $3,614 and 9 cents.
Q.
And looking at the due date on the top of the page, when
was that due?
A.
November 15th of 2024.
MR. EVERT: No further questions.
THE COURT: Any cross-examination for this witness?
MR. SILAS: Yes. Briefly, Your Honor.
CROSS-EXAMINATION
BY MR. SILAS:
Q.
Agent Caruana, maybe I misunderstood, but I just wanted to
clarify first that Exhibit 6 relates to the Fiber Drive
property in Cartersville, is that right, which was I think the
last exhibit that went in?
A.
Oh, Exhibit 6 relates to the Fiber Drive, correct.
Q.
Okay. And that is also undeveloped property; is that
right?
A.
That's correct.
Q.
And so the same with regard to the 101 Holt Drive property
in Acworth, Georgia, that's also undeveloped.
A.
Correct.
Q.
And the only developed property here would be the
5114 Graythorne Lane property in Marietta?
A.
Yes, sir.
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Q.
And with regard to each property, the government has filed
a lis pendens; is that right?
A.
That's correct.
Q.
To, in essence, provide -- to provide notice of the
government's interest with regard to that property?
A.
That's what my understanding is -- the purpose of a
lis pendens is.
Q.
In essence to prevent the -- or to maintain the status quo
as far as title on a property while this litigation is
pending; is that right?
A.
It's -- from my understanding, it's the government's claim
on that property so at the end of the day it can be forfeited
and the proceeds can be distributed amongst the victims in
this case.
Q.
Okay. So with regard to each of these three properties,
the government has all -- has formally entered its claim with
regard to each one of these three properties already?
A.
Yes.
Q.
Okay.
MR. SILAS: That's all I have, Your Honor.
THE COURT: Okay. Anything else for this witness or
may he step down?
MR. EVERT: He may step down.
THE COURT: Okay. Sir, thank you very much. I
appreciate it.
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All right. What else is there?
MR. EVERT: Your Honor, just a brief closing
statement would be -- would be all. Oh, unless -- unless the
defendant has any witnesses.
MR. SILAS: Oh, I'm sorry. I don't -- I don't have
any evidence, Your Honor.
MR. EVERT: We have no further witnesses.
THE COURT: Okay. So what, do y'all want to make
some argument on this? He hasn't paid taxes on any of them.
MR. EVERT: Correct.
THE COURT: Isn't that enough under the statute?
MR. EVERT: Yes, Your Honor.
THE COURT: Mr. Silas?
MR. SILAS: Well, Your Honor, I believe that this
is -- would be a extraordinary step, and one that rarely
happens, for the Court to allow the government to have --
THE COURT: Rarely happens because it's not permitted
under the law or because the government doesn't seek it?
Because I'm just kind of curious what you mean by
that, because I thought, unless you have an argument with the
government's legal authority, they tell me that under the
statute that you-all agreed applies, it authorizes a court to
enter an order preserving the property subject to a pending
forfeiture action if the property is subject to a mortgage or
tax in which the owner is in default.
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I mean, the backyard looked pretty awful. The front
yard, through the self-help of the neighbors, they've gotten
looking at least passible, perhaps, from what I see.
But the witness was pretty obvious that -- or pretty
clear that, you know, you really can't see some of it, but
that there is a lot of mold and mildew on the ground and that
things are becoming overgrown. But the backyard looks pretty
awful.
I mean, I don't know how long a pool can be totally
neglected before it fails. And then you're selling a house
subject to a busted, rotted pool rather than with a pool. But
I suspect that's a big factor in it. And maybe the government
wants to argue that, if we do briefing.
But putting that aside, why isn't the fact that he
hasn't paid taxes on this property enough?
Is the statute wrong?
MR. SILAS: Your Honor, again, what I -- what I think
that would normally happen in this situation is that we would
see the litigation through. And I think that we are probably
going to see the litigation through to the point of whether
there is a conviction or not sometime here in 2025. I mean,
that's going to -- that's going to happen. We're not --
THE COURT: I think it's just been certified ready;
is that right?
MR. SILAS: I think that's right, Your Honor, so it's
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not --
THE COURT: I'm going to move it forward. I'm going
to get it the first part of 2025.
I'm going to look at what it is. I think there's a
couple of things, there is an outstanding motion to suppress.
And I just kind of glanced at the docket, I think it's just
been sent to me.
MR. SILAS: So if that's the case, Your Honor, I
would not -- if that's the case, I think it's reasonable then
to -- for the Court to not require basically a sale on the
property.
Here -- I mean, to the extent that there are unpaid
taxes, the government -- certainly Cobb County and
Bartow County can collect those taxes once the -- once -- if
there is a conviction, once the property has been sold, the
government has stated its claim, it's formally staked its
claim on the property and basically says essentially it's ours
to get the proceeds back to repay the victims, to the extent
that victims exist in this case.
So there is no need -- I guess that's my point,
there's no really need -- there's no need to take this.
Everybody's interest here can reasonably be protected.
The homeowners will get their money. They filed a
lien. To the extent that Cobb County has a tax lien, they
will get their money. As we -- as we can hear from the
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evidence, Your Honor, there is no -- I mean, there is no
mortgage on this property. This is a property that's probably
valued at --
THE COURT: How much is this property worth with a
busted pool that needs to be completely fixed or whatever
happens when it sits with ponding water for three years?
MR. SILAS: Well, I don't have a copy of the tax
assessor's statement, I wish I had brought it. But I think
this property is worth about $2 million, Your Honor.
$2 million with no -- you know, so there's no bank -- there's
no loan on the property at all.
So even if there is some repair work or cleanup work
that needs to be done to the pool, there is plenty enough
money to take care of that.
THE COURT: Why hasn't he done it?
MR. SILAS: Well, mainly because he's -- he's in
jail, so he hasn't been able to take care of it.
THE COURT: No, but who should pay for the pool to be
fixed up now? Who should pay for that? It kind of seems to
me it's a threat to the value of the house.
MR. SILAS: Well --
THE COURT: Is the air-conditioning in the house
working?
MR. EVERT: Your Honor, we haven't been inside.
THE COURT: Is there power to the house? I'd like to
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know those things. I think that if a house in the south sits
unair-conditioned for a summer, I think there is risk of a lot
of mold inside.
And when that happens, you get really, really big
expenses because you start talking about drywall failure and
things like that, but I don't have any of that in front of me.
But it sounds like the government is going just on --
What's the government's argument for this?
MR. EVERT: So, Your Honor, for the two undeveloped
properties, Your Honor, our argument is just on the tax front.
On the 5114 Graythorne Lane, our argument is
two-pronged. On the one hand, there's the tax issue, which is
sufficient under the statute.
But the statute also provides the additional basis of
if the property is perishable or at risk of deterioration,
decay or injury by being detained in custody pending the
action. And here, we think that that is certainly satisfied.
THE COURT: Okay. I'm going to give you-all time to
file very short briefs on this issue.
Okay?
I'd like to see if there is a case that says I can do
it just because of the unpaid taxes or the case that says I
can't do it because of the unpaid taxes. There ought to be
something out there that says that.
The way I read the statute, it's pretty clear. It
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says: On a motion by a party having custody of the
property --
Who has custody of the property, the government?
MR. EVERT: No, Your Honor.
We don't have custody of the property.
THE COURT: So who has custody of it?
MR. EVERT: The defendant.
MS. SNEED: I'll just -- I'll answer this,
Your Honor.
MR. EVERT: Yeah.
MS. SNEED: So for real property, the government
cannot take custody before there is a conviction.
THE COURT: All right. Well, the statute that you've
cited to me says on a motion by a party having custody of the
property, the Court may order all or part of the property sold
if, (c), the property is subject to a mortgage or a tax on
which the owner is in default.
MS. SNEED: So I think under --
THE COURT: Does that apply here? Because that seems
to be what you cited.
MS. SNEED: Yes. The defendant technically has
custody of the property, because it's still in his name.
THE COURT: Right. So he can force a sale if there's
taxes owed.
MS. SNEED: No. Any party can, Your Honor.
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So on a motion by a party --
THE COURT: Oh, I'm sorry, you're right. Yes, you're
right.
MS. SNEED: Sometimes it happens.
THE COURT: Well, I doubt it's just sometimes.
All right. So I think you ought to brief that issue.
I think it says that.
Doesn't it say that, Mr. Silas?
MR. SILAS: Well, I do want to look at the -- to do
more research on the actual issue.
THE COURT: Well, it's kind of weird that we've known
this day was coming and you've had a couple of continuances of
this hearing for this purpose. It's kind of weird that you're
not ready to talk about it and cite me a case.
Is the government ready to do that?
MR. EVERT: Your Honor, I think the statute is pretty
clear.
THE COURT: It is. I agree.
MR. EVERT: I don't have a case that says what the
statute says other than what the statute says.
And I would also add that another -- that part (d) is
other good cause, and I think the squatters would constitute
other good cause.
THE COURT: Well, I am worried about that. And that
is why I asked questions of that police officer. There have
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
been threats to the property in the form of Mr. Holland coming
in and buying it by not paying the taxes and then some other
squatter.
And Mr. Silas makes the point that, well, there's no
other evidence of any other problems, but that's because
there's nobody to look over the house. There's nobody to look
into it and know what's going on.
For all we know, there could be people living in it
right now. I'm not saying that happened, but I don't think
anybody is looking over the property, is there? Well, there's
no evidence of that.
So I'd like you to file something that makes your
argument based on what we've heard today. And I think what
we've heard today is that the homeowner's association is
having to do much more than they should have to do to have a
bare minimum acceptability by their standards of the front
yard.
That nobody is doing anything with the backyard.
That the pool looks awful. That the pool -- I don't need a
pool expert to tell me that a pool filter is not meant to keep
up with branches, a broken and torn cover and however many
years of debris falling in the pool, so I think the pool is a
danger, if anybody were to get into it, and it's a serious
risk to the value of the property.
I think those are the facts. And that the
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association is continuing to incur debt, that, yes, they could
come back sometime down the road and get in line with somebody
else to try to get their money back, but they want to cut off
the difficulty right now, and maybe that is cause.
But in addition, we have the fact that he has not
paid his taxes. And in addition to that, we have that there
has been some problem with people claiming access or ownership
to the house that has required the police to become involved
on at least two occasions, it sounds like. Once with
Mr. Holland and once with some other squatters that went
inside. More than that, we don't know.
Is that enough?
Okay. Make sense?
MR. EVERT: Yes, Your Honor.
THE COURT: Five pages each. Five pages each.
How long do you want?
MR. EVERT: Would we need the transcript for that
or --
THE COURT: Probably.
MR. SILAS: Can I have at least 14 days after we get
the transcript?
THE COURT: That's fine. And if that hits at the
holiday, let me know. I don't want to wreck anybody's
holiday.
Okay?
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MR. EVERT: Understood.
THE COURT: But I'm going to move on it quickly. And
I'm going to move this case forward quickly.
What year was this case filed?
MR. EVERT: 2022.
THE COURT: 2022. And we're at the end of 2024.
Docket Order 19, May of 2022, granting the
defendant's motion to reset the pretrial conference until
August that had been set for July.
Docket 30, August 1st, order granting defendant's
motion for continuance of the pretrial conference, now setting
it for late August.
Docket 33, August 26th, motion granting defendant's
motion to reset the pretrial conference, setting it for
September of 2022.
Docket 36, order granting the motion to continue the
pretrial conference, that's entered three days before the
pretrial conference was supposed to be, setting it to
October 26th. It's not clear to me how that one was
continued, but it was.
Ex parte pretrial conference, I haven't listened to
the tape. Motion to stay. Motion for evaluation. Motion to
continue the evaluation. Motion for new counsel. Motion to
continue the pretrial conference which was now set for July 8,
2023.
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NORTHERN DISTRICT OF GEORGIA
Docket 76, order granting that motion to continue the
pretrial conference now set to January of 2024.
Docket 78, motion to continue that pretrial
conference until February.
That's a lot of motions to continue the pretrial
conference in front of the magistrate judge. No wonder these
cases take two years.
Then there's a superseding indictment, right?
MR. EVERT: There is.
THE COURT: Pretrial motion continued again by the
magistrate judge until October of 2024.
I had to continue this evidentiary motion from
November until today, that's the defendant's motion. Well,
and then I had to do it again at the joint request.
Another motion in the magistrate court to continue
the deadlines for pretrial motions. And another one. The
last one pushed it until the 6th.
Have all of the pretrial motions been filed?
MR. SILAS: Yes, Your Honor.
THE COURT: It looks like she put out a report and
recommendation about two weeks ago.
And then a motion for bill of particulars was filed.
Is that in front of a magistrate judge?
MR. SILAS: Yeah, I guess the district court could
handle it, but...
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THE COURT: So it has not yet been certified ready
for trial? No?
MR. SILAS: If not, I expect it to be soon, Judge, if
not --
THE COURT: That is very optimistic. And I know
you-all weren't the lawyers the whole time, for most of the
time.
But there's no part of this that gives me any belief
that it's coming. That is very optimistic from reading the
docket the way I've just read the docket to think that we're
on the verge of being certified ready for trial.
But I'll tell you this very plainly. When this case
is certified ready for trial and it gets in front of me, we're
all going to get together and we're going to pick a date and
we're going to try this case in the first half of 2025.
Do you understand?
We might even go into the summer, but we're going to
pick a date in the first quarter of 2025, because I'm going to
set an expectation that it be certified ready to me by that
time. And we are going to try this case in the first half of
next year.
Okay?
I don't think this case -- I'm not fussing at the
parties. I know there have been things that have gone on.
But I was a prosecutor for seven years, I was a defense
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
attorney for ten years. There is nothing about this case that
makes me think it should take two plus years to get from
indictment to trial.
And I don't know why we let cases linger like that in
the magistrate court. I know defendants say I need more time
and it happens.
But when this case is to me, we're going to move it
forward expeditiously.
Does everybody understand that?
MR. EVERT: Yes, Your Honor.
MR. SILAS: Yes, Your Honor.
THE COURT: So I'm going to give you until two weeks
from the time Ms. Colter tells me that she has finalized the
transcript in order for you to file simultaneous, five pages
each, a motion as to that question of whether or not the mere
fact that there is taxes owed and unpaid going back on each
property, I think two properties three years and one property
two years; is that right?
I think the last property was just two years, but I
could be wrong.
MR. EVERT: I think that was just the -- I think the
last would be just rolls up the -- all of the things into one.
THE COURT: I see.
MR. EVERT: Whereas the other ones break it out into
the three different years.
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THE COURT: The three different years. Okay. Fair
enough.
So whether that's enough.
And secondarily, whether the other facts that I think
are largely in dispute, you can characterize them one way or
another, but let's not start quibbling over the facts, I don't
think the facts are really in dispute. I listened to the
witnesses, I listened to the cross. There's not a lot of
factual disputes.
Whether those types of things, like the abuse of the
homeowner's association, the fact that the police officers
have to come there because there's been people at least twice
trying to claim ownership or access to the house, and, third,
the condition of the pool and what nuisance or whatever else
it might do, whether those things are enough to provide
independent good cause or good cause that wraps with the taxes
and then makes it the right course of conduct.
Everybody got it?
MR. SILAS: Yes, Your Honor.
THE COURT: All right. Anything else?
MR. SILAS: No, Your Honor.
MR. EVERT: No, Your Honor.
THE COURT: Okay. Thank you.
(Whereupon, the proceedings were adjourned at 11:42
a.m.)
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
REPORTERS CERTIFICATE
I, Jana B. Colter, Official Court Reporter for the
United States District Court for the Northern District of
Georgia, with offices at Atlanta, do hereby certify:
That I reported on the Stenograph machine the
proceedings held in open court on December 9, 2024, in the
matter of United States of America v. Carl Delano Torjagbo,
Case Number 1:22-CR-00171-MLB; that said proceedings in
connection with the hearing were reduced to typewritten form
by me; and that the foregoing transcript is a true and
accurate record of the proceedings.
This the 12th day of February, 2025.
_______________________________
/s/ Jana B. Colter, FAPR, RDR, CRR, CRC
Official Court Reporter
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Case 1:22-cr-00171-MLB-RDC Document 167 Filed 02/12/25 Page 82 of 95
BY MR. EVERT: [23] 9/1510/512/24
14/915/816/316/1317/217/1919/1520/8
23/1124/345/748/450/859/1260/1361/13
63/663/2065/1066/1
BY MR. SILAS: [10] 28/1235/236/537/3
43/1852/2157/157/1758/166/11
COURTROOM DEPUTY: [5] 9/29/6
44/2545/559/6
MR. EVERT: [70] 5/105/226/16/86/25
7/37/77/137/197/227/258/118/139/7
12/1314/715/416/2216/2417/1519/13
19/2520/523/923/2328/228/634/935/18
38/2338/2541/2544/944/1344/1747/23
47/2550/152/1558/1158/2260/1161/9
63/263/463/1565/765/2166/767/2368/2
68/768/1068/1271/2472/973/473/773/10
74/1674/1976/1476/1777/177/578/9
80/1080/2180/2481/22
MR. SILAS: [54] 5/166/126/217/178/7
8/1715/617/1720/324/128/934/634/11
34/1334/1534/1735/135/1635/2039/6
40/1940/2241/1941/2242/542/1842/24
43/1043/1344/648/152/1858/761/11
63/1865/2466/967/2068/568/1469/17
69/2570/871/771/1671/2174/976/20
78/1978/2479/380/1181/1981/21
MS. SNEED: [6] 73/873/1173/1873/21
73/2574/4
THE COURT: [160]
THE WITNESS: [52] 8/219/49/1210/3
12/512/712/1012/1612/1812/2015/2
15/2516/728/534/1934/2134/2435/25
36/336/1336/2036/2337/238/2439/9
39/1339/1639/2039/2340/140/640/11
40/1541/141/441/641/1544/1244/15
44/1945/348/249/2350/652/1656/2457/9
57/1257/1657/2558/1359/9
$
$1,300 [2] 24/1331/18
$1,650 [2] 11/2026/19
$1,855.89 [1] 64/6
$1,960 [1] 20/23
$10,719.93 [1] 27/10
$105.93 [1] 26/16
$140 [1] 20/23
$150 [1] 22/14
$18 [1] 26/23
$2 [2] 71/971/10
$2 million [2] 71/971/10
$2,000 [1] 22/15
$2,100 [1] 12/15
$2,118.42 [1] 64/2
$2.8 [1] 43/22
$2.8 million [1] 43/22
$20,799.46 [1] 61/22
$22,546.49 [1] 61/16
$23,095.35 [1] 61/19
$25 [1] 26/2
$3,080 [2] 25/2537/12
$3,400 [2] 24/2224/23
$3,614 [1] 66/3
$3,800 [1] 26/11
$3,962.78 [1] 63/22
$309 [1] 27/7
$4,000 [1] 12/13
$40,000 [2] 12/812/14
$500 [1] 11/18
$66,441.28 [1] 62/2
$7,937.09 [1] 64/9
$75 [1] 25/21
$750 [1] 24/10
'
'23 [1] 64/3
-
-- a [1] 15/2
/
/s [1] 82/18
1
1,650 [2] 27/432/15
1.5 [2] 43/2244/3
10 percent [3] 27/432/1532/19
101 [3] 62/763/1166/20
10th [1] 31/17
11/15 [1] 64/3
11:42 [1] 81/24
12 [3] 9/2119/2026/25
12th [1] 82/14
14 [1] 76/20
1456 [1] 2/20
14th [1] 48/3
15 [1] 64/3
150 [2] 24/1624/17
15th [4] 61/2563/2464/666/6
165 [1] 32/15
1650 [2] 26/926/12
17 [1] 10/15
171 [1] 5/7
19 [1] 77/7
1949 [1] 2/18
1:22-CR-00171-MLB [2] 2/482/10
1st [1] 77/10
2
2,150 [2] 11/1511/15
2.6 [1] 44/2
2.8 [2] 10/2244/2
2018 [2] 11/545/18
2021 [4] 44/160/162/1564/23
2022 [11] 11/1661/1461/1561/1663/21
63/2263/2477/577/677/777/15
2023 [20] 11/1712/312/413/1313/1517/6
19/2020/1524/1424/1526/1231/932/2
32/2261/1761/1861/1963/2564/277/25
2024 [35] 2/115/312/312/612/714/23
24/524/725/726/226/726/1026/1526/21
28/131/1431/1731/1731/2031/2232/14
48/661/761/2061/2161/2263/1364/464/6
65/2066/677/678/278/1182/8
2025 [5] 69/2170/379/1579/1882/14
2114 [1] 9/19
215-1456 [1] 2/20
2150 [2] 26/1026/24
22 [1] 59/18
22-cr-171 [1] 5/7
24 [1] 20/15
24th [1] 17/6
26th [2] 77/1377/19
3
30 [1] 77/10
30,000 [1] 40/12
30303 [1] 2/19
33 [1] 77/13
36 [1] 77/16
3rd [5] 31/1761/261/461/663/13
4
40,000 [1] 40/13
404 [1] 2/20
4th [1] 65/20
5
5114 [18] 9/2210/610/2311/2113/413/18
14/1514/2216/1423/1924/2427/1628/18
28/2429/1033/633/2435/5
5114 Graythorne Lane [9] 37/1745/20
46/647/1048/959/1962/266/2472/11
5114 Greythorne Lane [1] 65/16
6
6.01 [1] 18/8
6th [1] 78/17
7
75 [1] 2/19
76 [1] 78/1
78 [1] 78/3
9
90 [1] 1/4
A
a.m [1] 81/25
abatement [2] 21/421/14
able [3] 38/562/571/17
about [37] 5/247/128/49/2110/1916/8
28/729/929/1329/1931/1332/1237/19
38/1138/1940/1740/2442/2143/2143/22
46/1246/1948/848/1049/1550/2053/9
53/1353/2253/2356/571/972/574/14
74/2478/2180/1
absolutely [1] 43/14
abuse [1] 81/10
abusing [1] 41/2
acceptability [1] 75/16
access [2] 76/781/13
accordance [1] 18/13
according [1] 10/22
account [1] 39/24
accounting [1] 39/21
accumulated [1] 31/19
accurate [6] 14/2223/2160/2261/563/12
82/13
accused [1] 46/3
across [2] 36/151/3
action [8] 2/416/2016/2017/919/319/11
68/2472/17
actions [1] 57/2
active [1] 51/12
activity [1] 65/15
actual [2] 39/2374/10
actually [5] 14/2415/1840/554/454/12
Acworth [2] 62/866/21
add [3] 21/2022/1074/21
added [1] 21/10
addition [2] 76/576/6
additional [2] 56/1572/14
address [2] 51/1651/18
adjourned [1] 81/24
admin [1] 26/1
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Administrator [1] 2/17
admit [9] 15/417/1519/2520/423/2343/9
61/963/1565/21
admitted [8] 15/717/1820/724/235/19
61/1263/1965/25
Adriano [2] 44/1844/21
advantage [2] 42/358/18
advised [2] 46/2351/2
after [18] 1/713/413/913/1413/1813/19
37/2347/1751/451/1151/2352/152/352/5
52/1155/557/376/20
afternoon [1] 5/10
afterwards [1] 57/6
again [10] 36/651/1656/556/1058/2
62/2364/1769/1778/1078/14
against [1] 41/7
agent [7] 8/28/108/1659/1359/1659/17
66/12
ago [3] 58/458/678/21
agree [3] 7/1542/674/18
agreed [1] 68/22
agreement [1] 49/2
ahead [1] 7/18
AI [1] 1/13
aided [1] 2/15
air [1] 71/22
air-conditioning [1] 71/22
all [58] 5/66/146/237/17/27/1812/412/6
15/715/1615/1818/618/718/1319/521/8
21/1123/224/725/925/1225/1226/127/9
27/1129/329/431/236/1236/1436/20
36/2539/2140/2141/741/1742/342/13
44/649/249/2558/767/1667/2068/168/3
68/2271/1172/1873/1373/1574/675/8
78/1879/679/1480/2281/20
allegation [1] 57/5
alleging [1] 45/25
allow [2] 41/1168/16
allowed [2] 13/2232/19
already [1] 67/17
also [23] 5/135/177/149/821/229/17
29/1832/432/1239/1139/1439/1742/20
43/549/153/654/954/1256/766/1766/21
72/1474/21
am [7] 5/2045/1145/2159/2162/964/15
74/24
AMERICA [2] 2/382/9
amongst [1] 67/13
amount [13] 20/2324/1724/2327/10
40/1462/163/2264/164/264/565/665/15
65/16
amounts [3] 12/1121/821/11
angle [2] 33/1834/3
annual [2] 11/1012/18
another [8] 7/1435/551/2362/1174/21
78/1578/1681/6
answer [3] 51/2556/1873/8
answered [1] 56/21
anticipate [1] 28/6
anxiety [2] 42/1342/18
any [32] 1/97/118/1519/1120/221/11
23/523/2527/1627/2234/838/1044/8
51/1352/252/1752/1958/958/1460/5
62/1963/1765/165/2366/868/468/668/9
72/673/2575/579/8
anybody [5] 43/243/755/1975/1075/23
anybody's [1] 76/23
anyone [9] 8/913/313/1446/1547/147/6
47/949/1451/9
anything [12] 22/2022/2322/2438/12
40/1741/2546/1948/752/267/2175/18
81/20
appearance [1] 29/19
appearances [3] 3/25/822/25
appeared [5] 6/514/2360/2361/663/13
appears [2] 15/1415/19
application [1] 24/12
applies [1] 68/22
apply [1] 73/19
appreciate [3] 43/1444/1167/25
approach [8] 14/716/2219/1323/947/23
60/1163/265/7
appropriate [2] 14/316/16
approximately [5] 27/2452/352/452/13
59/18
April [5] 13/1517/620/1525/745/18
April 2023 [1] 13/15
April 24th [1] 17/6
are [70] 1/85/66/206/216/238/139/11
9/2210/1910/2111/1311/1415/2216/7
18/1218/1220/722/2422/2523/2124/8
25/225/1225/1227/1629/1329/1432/4
36/1536/1637/537/1239/941/641/1842/9
42/1642/1645/1947/949/1750/1750/18
50/1850/2257/2058/1458/1558/1559/19
60/560/761/1661/2362/762/1062/19
62/2164/1364/1665/165/369/769/19
70/1275/2579/2081/581/781/15
area [2] 10/910/19
argue [1] 69/13
argument [6] 68/968/2072/872/1072/11
75/13
around [3] 15/1715/1828/23
arrested [4] 54/1855/2055/2556/11
arrive [1] 49/8
arrived [1] 56/16
arrives [1] 50/17
Article [1] 18/8
as [72] 6/198/2510/711/611/613/713/22
14/1114/2315/1416/1516/1817/417/22
18/1518/1519/1619/1920/421/321/6
23/1325/327/1229/929/1729/2229/23
32/136/636/636/736/1537/1841/2141/21
44/2345/2454/1954/1954/2154/2154/25
54/2555/155/156/256/256/1356/1357/18
57/1857/2057/2058/258/259/460/15
60/2361/662/1362/1563/163/863/13
64/1965/1267/967/970/2570/2580/15
aside [2] 38/1869/14
ask [2] 31/1340/17
asked [1] 74/25
asking [2] 14/417/8
asks [1] 16/19
asserting [1] 51/5
assertion [2] 6/66/16
assessment [6] 21/1021/2126/726/14
26/2032/13
assessments [1] 32/20
assessor's [5] 46/1148/2249/2154/7
71/8
asset [1] 43/4
Assistant [1] 5/13
association [19] 8/110/910/1311/10
17/2321/2422/1322/1722/2027/1229/14
29/1830/1933/837/842/975/1476/181/11
association's [2] 17/2418/9
assuming [1] 6/9
ATLANTA [4] 2/22/195/382/6
attached [1] 1/5
attaching [1] 1/8
attention [3] 18/2421/250/9
attorney [10] 3/35/1425/825/1537/9
46/1849/151/151/180/1
auction [1] 48/24
August [4] 77/977/1077/1277/13
August 1st [1] 77/10
August 26th [1] 77/13
authority [4] 21/621/1927/2268/21
authorization [2] 55/1455/15
authorized [2] 46/2449/9
authorizes [1] 68/22
aware [10] 6/2313/227/1627/2047/9
49/1750/1257/1157/2258/19
away [2] 28/346/25
awful [3] 69/169/875/19
B
back [18] 22/2022/2423/423/439/4
50/2251/253/1253/1754/1654/1954/24
55/258/370/1876/276/380/16
backs [1] 14/17
backyard [11] 13/2414/1514/1714/17
16/936/2337/137/669/169/775/18
bad [6] 14/240/2441/1242/242/642/15
balance [11] 24/1324/1725/1726/2
26/1627/227/631/1831/2232/132/14
bank [2] 38/2271/10
bare [1] 75/16
Bartow [3] 65/565/1470/14
Bartow County [3] 65/565/1470/14
based [2] 43/2475/13
basically [3] 54/970/1070/17
basis [4] 7/57/1428/2072/14
be [61] 1/21/37/147/2210/1612/1315/19
16/818/518/2421/921/1021/1322/822/8
26/1927/434/1438/338/538/838/2041/13
41/1641/2243/744/1346/446/2046/24
47/247/749/953/2253/2454/1855/15
55/1755/2456/1158/1962/566/2367/12
67/1368/368/368/1569/970/2271/571/13
71/1872/2373/2075/877/1879/379/19
80/2080/22
beautiful [2] 44/444/4
beautiful -- it [1] 44/4
became [2] 13/327/20
because [35] 6/1516/922/234/2236/13
36/1736/2539/1840/243/848/1648/18
49/749/1150/1450/2351/1252/2553/13
57/457/757/1968/1768/1868/1968/20
71/1672/572/2272/2373/1973/2275/5
79/1881/12
become [5] 21/921/1145/2259/2276/8
becoming [1] 69/7
been [56] 8/2411/411/1613/1414/10
14/2516/1017/319/1623/1227/1827/25
30/336/1737/1237/2138/440/240/11
41/2544/2245/1345/1848/848/2351/9
52/253/1354/1954/2254/2455/1255/13
56/1356/2156/2257/457/1457/2059/3
59/1760/1463/765/1169/2370/770/15
71/1771/2475/176/777/978/1879/179/24
81/12
before [5] 2/1011/1969/1073/1277/17
Case 1:22-cr-00171-MLB-RDC Document 167 Filed 02/12/25 Page 84 of 95
B
began [1] 36/12
beginning [4] 27/1431/1631/1832/13
behalf [4] 5/1113/413/1525/10
behind [1] 14/18
being [11] 8/1611/2113/2113/2334/3
36/747/1055/2056/572/1679/11
belief [2] 7/479/8
believe [17] 12/1313/1713/2014/2116/9
16/1920/522/1638/1338/1446/2147/17
60/161/361/362/1568/14
better [2] 36/1155/24
between [2] 10/2153/9
beyond [1] 50/15
big [3] 44/469/1272/4
bill [1] 78/22
bills [1] 25/12
bit [2] 12/2215/20
biweekly [1] 20/23
blue [1] 49/3
BMW [2] 50/1353/17
board [2] 17/2218/23
both [1] 29/17
bothersome [1] 43/7
bottom [8] 15/1317/1324/424/1024/20
27/831/1466/2
Brahim [1] 55/17
branches [2] 15/1575/21
break [1] 80/24
breeding [1] 16/8
Brian [5] 47/1348/349/454/2456/7
brief [2] 68/274/6
briefing [1] 69/13
briefly [2] 27/1966/9
briefs [1] 72/19
bring [3] 8/517/920/18
broken [1] 75/21
Brookshire [4] 10/1317/2318/2520/20
brought [1] 71/8
BROWN [1] 2/10
brush [1] 19/6
budgetary [1] 22/2
buildings [1] 18/6
burden [1] 7/2
Bureau [2] 58/2459/14
busted [2] 69/1171/5
buying [1] 75/2
bylaws [3] 14/416/1821/17
C
C-A-R-U-A-N-A [1] 59/10
calculated [1] 26/18
calendar [3] 24/724/1426/10
call [8] 7/1944/1846/1551/2353/656/4
58/558/23
called [9] 10/1248/1148/1248/1348/21
50/2355/157/858/18
came [7] 45/2350/2051/352/2559/23
62/1164/17
can [43] 5/816/517/2020/921/1622/7
24/524/2125/226/326/826/1726/2227/3
27/1934/1335/1235/1236/136/1436/18
39/440/940/1341/1141/2142/1942/19
43/964/164/466/267/1267/1369/970/14
70/2270/2572/2173/2373/2576/2081/5
can't [9] 16/833/1734/2236/1537/6
42/1854/469/572/23
cannot [2] 49/273/12
car [2] 50/1550/16
care [10] 13/2414/516/918/520/1520/22
24/636/871/1471/17
CARL [11] 2/55/1710/746/246/849/10
50/1259/2462/1264/1882/9
Carl's [1] 50/13
carries [1] 32/2
carryover [2] 24/1424/17
Cartersville [2] 64/1466/14
Caruana [7] 5/128/258/2459/259/10
59/1366/12
case [22] 8/211/1656/2560/364/2567/14
70/870/970/1972/2172/2274/1474/19
77/377/479/1279/1579/2079/2380/180/7
82/10
Case Number [1] 82/10
cases [2] 78/780/4
Castlewycke [1] 9/19
cause [6] 7/1174/2274/2376/481/16
81/16
causing [2] 42/1242/13
cents [1] 66/3
certainly [3] 43/1370/1372/17
CERTIFICATE [1] 82/1
certified [6] 1/1469/2379/179/1179/13
79/19
certify [1] 82/6
cetera [2] 21/721/13
challenge [1] 6/10
challenging [2] 6/56/12
changed [1] 31/21
characterize [1] 81/5
charge [4] 24/532/1732/1949/9
charged [2] 31/1437/21
charges [3] 31/1631/1931/23
Charlotte [1] 5/18
chart [1] 23/21
chase [1] 28/3
check [2] 43/858/5
checked [1] 48/25
Cherokee [4] 62/2362/2463/1163/13
choosing [1] 30/25
chose [1] 31/2
cite [2] 1/574/14
cited [2] 73/1473/20
civil [1] 53/8
claim [7] 48/1949/367/1167/1670/16
70/1781/13
claimed [5] 48/1148/1249/549/2053/23
claiming [1] 76/7
claims [1] 50/23
clarify [1] 66/13
clean [2] 18/318/17
cleanup [4] 20/2221/122/1471/12
clear [6] 38/1643/1569/572/2574/17
77/19
close [1] 42/15
closing [1] 68/2
CM [2] 1/21/3
CM/ECF [2] 1/21/3
Cobb [22] 8/19/1945/945/1846/1048/11
48/1348/2248/2449/2054/654/2355/19
55/2356/460/1060/2060/2361/661/23
70/1370/24
Cobb County [6] 54/2360/2361/661/23
70/1370/24
colleagues [1] 54/9
collect [1] 70/14
collection [1] 26/1
collections [2] 21/1226/5
collective [1] 37/10
color [2] 15/915/20
COLTER [4] 2/1780/1382/482/18
come [10] 31/639/1139/1440/1350/9
51/254/1556/876/281/12
comes [2] 31/450/22
coming [8] 31/739/1744/1045/1556/14
74/1275/179/9
companies [1] 31/21
company [12] 16/1723/1825/1926/5
26/1930/1830/2231/2331/2532/532/23
64/12
compile [1] 32/5
complainant [2] 45/2446/1
complete [3] 20/2421/521/22
completely [1] 71/5
compliance [4] 17/918/2420/1821/18
computer [2] 2/158/5
computer-aided [1] 2/15
concern [4] 14/229/1942/2153/1
concerned [2] 16/729/13
concerns [1] 29/9
concluded [2] 57/557/20
condition [5] 18/418/1722/529/1081/14
conditioned [1] 72/2
conditioning [1] 71/22
conditions [2] 20/1921/7
conduct [1] 81/17
conducting [1] 51/12
conference [10] 77/877/1177/1477/17
77/1877/2177/2478/278/478/6
confirmed [2] 23/2048/24
confronted [1] 49/5
confronts [1] 50/18
connection [2] 37/1682/11
constitute [1] 74/22
constraints [1] 22/3
consulted [3] 37/1962/2465/5
consulting [1] 54/9
contacted [1] 54/15
contacting [1] 54/6
continuance [1] 77/11
continuances [1] 74/12
continue [9] 27/1577/1677/2377/24
78/178/378/578/1278/15
continued [3] 31/877/2078/10
continuing [1] 76/1
contractor [2] 24/630/25
control [1] 19/4
conversation [5] 46/2146/2348/20
49/2051/8
conviction [3] 69/2170/1573/12
copy [5] 31/1034/1235/2050/2471/7
corner [1] 65/18
correct [59] 6/16/817/1418/2022/18
22/1922/2224/2525/1526/1328/1929/21
30/130/431/332/1634/534/1935/836/2
36/337/239/539/640/640/1641/143/23
50/651/651/752/1453/453/1153/1553/20
54/354/854/1454/1754/2555/755/16
55/2156/156/656/1257/957/1257/16
57/2562/162/364/866/1666/1966/2267/3
68/10
corrections [1] 20/18
corrective [2] 17/819/3
correctly [1] 47/19
Case 1:22-cr-00171-MLB-RDC Document 167 Filed 02/12/25 Page 85 of 95
C
cost [3] 16/1021/2022/13
costing [1] 40/5
could [11] 25/2339/342/1949/1351/19
53/2256/875/876/178/2480/20
counsel [7] 5/85/125/1716/2425/16
25/2077/23
county [29] 5/38/145/945/1846/1048/11
48/1348/2248/2449/2154/754/2355/19
56/460/1060/1060/2060/2361/661/23
62/2362/2463/1163/1365/565/1470/13
70/1470/24
couple [5] 29/2232/2447/1770/574/12
course [5] 27/1539/2541/1551/2181/17
court [22] 1/31/71/91/121/142/12/185/4
9/1935/2043/1568/1668/2270/1073/15
78/1578/2480/582/482/582/882/19
Court's [2] 14/2543/13
Courthouse [1] 2/18
cousin [1] 13/8
covenants [9] 14/416/1817/2418/10
19/2020/1921/621/1221/17
cover [6] 10/1415/315/2416/238/875/21
covered [2] 10/2314/25
cr [3] 2/45/782/10
CRC [2] 2/1782/18
creeps [1] 40/12
criminal [7] 2/445/1145/1346/2249/7
49/1151/16
cross [8] 28/828/1152/1852/1952/20
66/866/1081/8
cross-examination [5] 28/828/1152/20
66/866/10
CRR [2] 2/1782/18
CT [1] 49/13
curious [1] 68/19
current [2] 10/2212/25
currently [7] 11/1512/130/336/760/5
62/1965/1
custody [8] 72/1673/173/373/573/6
73/1273/1473/22
custom [1] 44/5
cut [1] 76/3
D
DA's [1] 48/25
danger [1] 75/23
dark [1] 36/16
dash [1] 32/13
date [10] 11/2432/832/1037/1347/18
64/265/1966/479/1479/18
dated [3] 17/619/2020/15
dates [2] 32/432/4
day [6] 14/158/2058/2067/1274/12
82/14
days [10] 1/416/1916/2119/320/2521/5
21/2251/2376/2077/17
deadlines [1] 78/16
dealing [1] 7/5
Dear [2] 17/2220/14
debris [4] 13/2415/1115/1775/22
debt [1] 76/1
decay [1] 72/16
DECEMBER [10] 2/115/327/1431/17
61/261/461/663/1365/2082/8
December 3rd [5] 31/1761/261/461/6
63/13
December 4th [1] 65/20
decided [2] 48/1849/10
declaration [3] 20/1921/621/12
declarations [3] 17/2418/919/2
decrease [1] 39/24
deduction [1] 38/21
deed [1] 64/10
default [3] 7/1168/2573/17
defendant [8] 2/63/55/156/56/968/4
73/773/21
defendant's [9] 32/2533/134/635/17
37/577/877/1077/1378/13
defendants [1] 80/5
DEFENDER [2] 3/55/19
defense [3] 16/2446/1879/25
DELANO [18] 2/510/711/2217/717/22
18/1819/719/1019/1920/1421/2229/23
30/330/833/1237/2144/182/9
Delano's [4] 12/2513/1527/1230/12
delinquent [5] 26/1526/2126/2432/14
32/20
delivery [1] 17/7
demand [4] 29/2229/2430/742/21
department [4] 8/226/545/945/16
depict [1] 14/14
depicted [2] 33/237/5
depiction [2] 14/2233/15
describe [2] 15/927/19
described [1] 16/15
desired [1] 18/25
desk [1] 45/23
detail [1] 39/22
detained [1] 72/16
detective [8] 8/144/1845/345/1145/13
45/1552/2252/23
Detective Ghisi [1] 52/23
deterioration [2] 7/972/15
determined [2] 18/2320/17
developed [1] 66/23
did [32] 13/1216/1417/1117/1219/10
19/2120/420/521/2221/2321/2422/12
24/1125/628/329/545/2246/1947/14
47/1548/748/748/1049/1849/2050/9
50/2552/453/2155/856/2359/22
didn't [5] 12/420/525/2050/354/1
different [4] 30/2531/2480/2581/1
difficult [1] 40/4
difficulty [1] 76/4
Diggs [1] 5/18
diminution [1] 42/14
direct [5] 9/1434/138/2545/659/11
directly [3] 33/2535/1354/15
directors [1] 17/23
discontinued [1] 30/16
dispute [6] 41/2142/142/1658/1581/5
81/7
disputes [1] 81/9
disputing [2] 6/186/24
disrepair [5] 6/1713/2116/1525/14
27/13
distributed [1] 67/13
district [6] 1/142/12/178/2482/582/5
divided [1] 26/25
DIVISION [1] 2/2
do [70] 7/158/159/1810/610/2511/111/6
12/2514/1214/1315/2116/1421/421/24
22/1023/623/1423/1525/1825/2028/24
29/230/1931/131/531/1033/234/1338/12
41/1442/342/1243/2545/846/949/649/10
49/1951/854/1554/1857/459/1359/25
60/260/560/860/2462/562/1462/1962/22
64/2264/2465/165/468/869/1372/21
72/2374/974/974/1575/1575/1576/16
78/1479/1681/1582/6
docket [10] 1/670/677/777/1077/13
77/1678/178/379/1079/10
document [2] 1/965/18
documents [1] 18/12
does [10] 6/910/1412/114/1416/521/1
41/2461/273/1980/9
doesn't [9] 33/2538/839/2441/2250/4
58/1658/1668/1874/8
doing [12] 9/1113/1218/1919/722/17
22/2022/2322/2422/2525/2042/475/18
don't [46] 10/712/212/513/1715/2523/5
23/736/938/1038/1038/1338/1440/23
41/1641/2542/2443/743/843/1044/2
47/1848/1250/1450/1451/2556/1857/2
57/1358/558/2162/562/1568/568/569/9
71/772/673/574/1975/975/1976/1176/23
79/2380/481/6
done [4] 32/836/2571/1371/15
door [7] 10/110/233/2036/1843/351/25
56/18
doubt [1] 74/5
down [7] 24/1031/1735/1344/1167/22
67/2376/2
Drive [9] 2/1962/862/2363/1164/1465/2
66/1366/1666/20
driver's [1] 50/24
driveway [5] 35/1235/2335/2436/15
36/16
drywall [1] 72/5
due [17] 11/1021/921/1161/2463/21
63/2364/164/264/264/564/665/1665/17
66/266/366/466/5
dues [10] 11/1211/1411/1711/2211/24
12/126/426/926/1126/11
duly [3] 8/2444/2259/3
during [4] 46/2146/2349/2050/12
E
each [11] 18/218/1418/1632/967/1
67/1567/1776/1576/1580/1580/16
earlier [3] 25/743/1956/9
early [1] 13/13
easements [1] 20/20
East [1] 9/19
ECF [2] 1/21/3
effort [3] 6/1328/537/16
either [1] 49/18
else [13] 8/940/1746/1547/655/555/19
55/2456/1167/2168/176/381/1481/20
email [1] 17/7
employed [2] 24/745/18
encountered [3] 53/1855/1055/19
end [3] 24/1867/1277/6
ended [2] 30/2430/25
enforced [1] 21/13
engaged [1] 33/9
engaging [1] 30/13
enough [10] 34/2538/841/1368/11
69/1571/1376/1281/281/381/15
enter [2] 49/368/23
entered [4] 32/548/1767/1677/17
entire [1] 29/11
entries [1] 24/7
Case 1:22-cr-00171-MLB-RDC Document 167 Filed 02/12/25 Page 86 of 95
E
entry [2] 1/624/10
error [1] 24/17
escalate [1] 50/14
essence [2] 67/467/8
essentially [4] 53/854/255/1470/17
estimate [2] 20/2130/24
et [2] 21/721/13
et cetera [2] 21/721/13
evaluation [2] 77/2277/23
even [5] 50/354/1254/1371/1279/17
eventually [2] 38/253/5
ever [2] 40/946/12
Evert [2] 3/35/11
every [6] 10/1611/1011/1114/143/343/9
everybody [2] 80/981/18
Everybody's [1] 70/22
evidence [6] 34/635/1668/671/175/5
75/11
evidentiary [1] 78/12
Ex [1] 77/21
Ex parte [1] 77/21
exact [2] 12/212/11
Exactly [1] 41/9
examination [9] 9/1428/828/1139/1
45/652/2059/1166/866/10
EXAMINATIONS [1] 4/1
examined [3] 8/2444/2259/3
exceeds [1] 38/25
excess [1] 12/8
excessive [1] 7/10
Excuse [1] 65/11
excused [2] 44/1358/10
exercise [1] 21/4
exercising [1] 30/13
exhibit [22] 14/1115/517/417/1619/17
20/123/1323/2431/1032/2533/134/7
35/1760/1561/1063/863/1665/1265/22
66/1366/1566/16
Exhibit 1 [3] 14/1115/532/25
Exhibit 2 [1] 17/4
Exhibit 3 [2] 19/1720/1
Exhibit 4 [2] 60/1561/10
Exhibit 5 [2] 63/863/16
Exhibit 6 [4] 65/1265/2266/1366/16
Exhibit 7 [3] 23/1323/2431/10
exhibits [2] 16/2537/5
exist [1] 70/19
expect [6] 8/1022/538/443/2462/579/3
expectation [1] 79/19
expeditiously [1] 80/8
expenditures [1] 39/23
expense [2] 7/923/7
expenses [2] 38/572/5
expensive [1] 44/5
expert [1] 75/20
explain [8] 21/1624/525/226/326/8
26/1726/2227/3
explained [1] 51/21
expressing [1] 14/2
extent [4] 21/1170/1270/1870/24
exterior [6] 17/2518/619/520/1630/20
33/10
extraordinary [1] 68/15
eyesore [1] 40/4
F
F-R-A-N-C-H-I [1] 9/5
fact [6] 41/2049/1769/1476/580/16
81/11
factor [1] 69/12
facts [6] 6/1842/1675/2581/481/681/7
factual [2] 58/1481/9
failed [1] 20/17
fails [1] 69/10
failure [1] 72/5
fair [9] 14/2233/1534/2539/842/1160/22
61/563/1281/1
fallen [2] 15/1525/14
falling [5] 6/1613/2016/1527/1375/22
familiar [10] 9/2245/1945/2250/159/19
59/2262/762/1064/1364/16
family [4] 45/2553/253/958/17
FAPR [2] 2/1782/18
far [15] 36/1136/2341/2041/2142/1
54/1954/2154/2555/156/256/1357/18
57/2058/267/9
FBI [3] 5/138/359/17
February [2] 78/482/14
federal [5] 3/55/1938/1758/2459/14
fee [6] 25/2125/2426/226/626/2132/14
feel [2] 13/2343/2
fees [5] 12/325/125/2537/1237/21
female [3] 47/1350/1750/22
few [1] 28/15
Fiber [4] 64/1465/266/1366/16
fight [1] 41/3
file [5] 2/440/972/1975/1280/14
filed [12] 1/21/71/96/337/2462/1264/18
67/170/2377/478/1878/22
filter [1] 75/20
final [1] 26/20
finalized [1] 80/13
Finamore [1] 25/8
finances [1] 23/7
financial [1] 25/10
find [1] 51/14
fine [2] 9/1276/22
firm [1] 25/3
first [26] 7/198/249/311/513/317/2020/9
20/1120/1225/626/426/926/1232/25
44/2245/245/350/1059/359/859/966/13
70/379/1579/1879/20
five [3] 76/1576/1580/14
fixed [2] 71/571/19
fly [1] 62/5
FlyingJack [1] 64/11
foliage [1] 15/16
follow [2] 20/1448/22
follow-up [1] 20/14
followed [1] 56/24
following [1] 1/1
follows [3] 8/2544/2359/4
force [4] 6/1341/1141/1273/23
foreclosed [1] 48/24
foregoing [1] 82/12
forfeited [1] 67/12
forfeiture [1] 68/24
forget [1] 8/6
forgot [1] 20/6
form [2] 75/182/11
formally [2] 67/1670/16
forward [4] 7/170/277/380/8
found [2] 24/1646/10
four [1] 45/15
Franchi [12] 7/207/258/239/49/1615/9
23/1228/1333/234/1735/343/16
Franchi's [1] 42/20
fraud [3] 60/362/1664/25
free [1] 38/15
Freight [1] 64/11
friend [2] 55/1758/17
front [20] 14/222/222/422/522/722/17
22/2523/331/634/135/1336/1837/469/1
72/672/1075/1678/678/2379/13
frontal [2] 34/135/10
frustration [1] 42/13
full [3] 1/815/1134/1
Fulton [1] 5/3
funded [2] 11/711/9
funny [1] 5/23
further [4] 28/252/1566/768/7
fussing [1] 79/23
G
G-H-I-S-I [1] 45/4
G7 [1] 7/6
gander [1] 9/10
Ganzou [2] 55/1755/18
generally [3] 10/2010/2113/25
GEORGIA [13] 2/12/195/39/2318/13
21/1345/2059/2062/262/864/1466/21
82/6
get [21] 38/139/339/439/1951/1851/22
51/2351/2456/2357/870/370/1870/23
70/2572/475/2376/276/376/2079/1480/2
gets [1] 79/13
getting [1] 12/9
Ghisi [7] 8/144/1844/2145/345/445/8
52/23
give [5] 34/1350/464/772/1880/12
given [1] 61/23
gives [2] 16/1979/8
giving [2] 14/317/7
glanced [1] 70/6
go [7] 7/17/1813/2321/1950/2557/15
79/17
goes [3] 48/1550/1350/16
going [33] 16/2025/927/2435/138/8
38/2138/2138/2239/255/855/2458/17
64/769/2069/2269/2270/270/270/472/7
72/1875/777/277/379/1479/1479/15
79/1779/1879/2080/780/1280/16
gone [3] 50/2253/1779/24
Gonzo [7] 46/2447/147/647/1050/11
51/952/22
good [17] 5/107/119/99/109/119/129/13
9/169/1725/2128/1328/1440/574/22
74/2381/1681/16
goose [1] 9/10
got [7] 11/1912/2225/928/1530/2457/7
81/18
gotten [1] 69/2
govern [1] 18/13
governing [1] 18/12
government [19] 5/75/116/340/141/12
41/2462/1264/1867/167/1668/1668/18
69/1270/1370/1672/773/373/1174/15
government's [22] 6/136/136/1614/11
15/517/417/1519/1719/2523/1323/23
31/1060/1561/963/863/1565/1265/21
67/567/1168/2172/8
grab [1] 50/21
granting [5] 77/777/1077/1377/1678/1
Case 1:22-cr-00171-MLB-RDC Document 167 Filed 02/12/25 Page 87 of 95
G
grass [1] 36/13
Graythorne [19] 16/1423/1924/2427/16
28/1828/2529/1033/633/2435/537/17
45/2046/647/1048/959/1962/266/24
72/11
great [1] 34/14
green [1] 15/11
Greythorne [12] 6/76/146/199/2210/6
10/2311/2113/413/1814/1514/2365/16
Greythorne Lane [4] 11/2113/413/18
14/23
ground [1] 69/6
grounds [1] 15/18
group [1] 28/5
guess [8] 15/1325/633/842/553/156/4
70/2078/24
Gutierrez [3] 20/2230/2230/24
guy [2] 49/2256/23
H
had [27] 14/2525/1927/1232/1243/2
46/1947/147/148/848/1948/2349/550/3
50/2451/553/253/1353/1653/1756/10
57/457/1471/874/1277/978/1278/14
hadn't [1] 54/12
half [6] 9/2110/2110/2259/1879/15
79/20
hallway [1] 8/14
hand [2] 17/772/12
handle [1] 78/25
happen [3] 49/869/1869/22
happened [5] 13/1852/1156/357/675/9
happens [6] 68/1668/1771/672/474/4
80/6
hardly [1] 36/18
has [39] 1/711/1613/1416/918/2320/17
20/2121/1922/1324/2325/1427/1230/3
31/732/1433/1233/1340/1141/351/21
54/2455/1255/1457/2067/167/1667/16
68/470/1570/1670/2473/373/673/2176/5
76/776/879/180/13
hasn't [6] 36/1754/1968/969/1571/15
71/17
have [80] 5/86/37/27/47/88/159/20
10/2511/411/612/1015/1520/1723/7
23/2027/1827/2529/1831/1032/1034/12
35/335/2037/1237/1937/2137/2438/10
40/240/740/842/2143/644/645/1345/16
46/1246/1447/1950/1951/951/1351/16
52/152/1153/2354/2254/2355/155/4
56/1356/2056/2256/2457/557/1357/14
57/2258/558/759/1767/2068/568/768/16
68/2071/772/673/574/1974/2575/15
75/1576/576/676/2078/1879/2479/24
81/12
haven't [7] 36/2539/1852/152/256/22
71/2477/21
having [10] 8/2439/1139/1444/2253/13
55/959/373/173/1475/15
he [78] 11/2211/2311/2411/2512/112/2
12/312/413/319/821/2325/825/933/12
41/342/646/346/2346/2448/848/1148/12
48/1248/1248/1548/1648/1648/1648/18
48/1848/1949/549/549/1249/1749/18
49/1849/2049/2049/2550/250/250/350/3
50/1350/1350/1650/1650/1750/2250/23
50/2350/2451/151/551/551/2153/253/17
53/1753/1853/1853/2354/157/758/16
58/1658/1858/1858/1867/2267/2368/9
69/1471/1571/1773/2376/5
he's [16] 13/239/840/440/2441/241/12
42/242/242/342/442/1142/1142/1242/13
71/1671/16
hear [2] 43/1470/25
heard [2] 75/1375/14
hearing [2] 74/1382/11
held [1] 82/8
help [9] 21/421/1522/124/1530/833/9
36/1237/169/2
here [23] 5/65/215/257/168/58/98/16
15/2326/2032/2434/1837/1240/2450/18
55/556/858/1566/2369/2170/1270/22
72/1773/19
hereby [1] 82/6
herein [3] 8/2444/2259/3
hey [4] 51/1551/1955/555/12
him [14] 10/716/1917/829/2439/442/15
49/550/152/953/954/1554/1554/2258/18
himself [1] 13/7
hired [1] 30/18
his [29] 13/413/814/1717/818/218/3
18/1734/239/842/1142/1142/1346/13
46/1846/2047/247/2548/1050/1250/21
50/2450/2453/353/653/955/1555/17
73/2276/6
history [1] 58/5
hits [1] 76/22
HOA [23] 10/910/1210/1410/1710/23
10/2511/711/911/1113/2214/316/14
18/1520/1720/2121/1721/1924/2325/4
25/425/1037/1851/11
HOA's [3] 18/1821/321/6
hold [1] 54/1
holiday [2] 76/2376/24
Holland [23] 47/1347/1448/348/748/11
49/449/1550/950/1751/451/851/1952/4
53/1353/1853/2354/1254/1954/2455/2
56/775/176/10
Holland's [3] 52/652/752/8
Holt [4] 62/862/2363/1166/20
Holt Drive [4] 62/862/2363/1166/20
home [41] 11/1111/1813/2018/120/16
20/1821/1822/222/522/623/127/2228/17
34/237/2437/2538/741/443/444/546/20
46/2447/247/748/1548/1648/1748/19
48/2348/2349/349/649/849/1249/1850/3
50/1650/1750/2051/1356/17
homeowner [14] 11/1014/416/1918/2
18/1418/1621/1826/726/1426/2127/23
32/1443/2049/12
homeowner's [18] 7/2510/910/1317/23
21/2121/2422/1322/1622/2027/1129/14
29/1730/1933/837/842/875/1481/11
homeowners [3] 37/1038/470/23
homes [5] 10/1610/1914/243/2148/13
honed [1] 6/15
Honor [72] 5/105/166/126/226/257/7
7/137/177/238/78/88/118/179/714/715/4
15/616/2217/1720/324/128/228/934/7
34/1134/1334/1535/135/1635/2139/6
40/1941/2342/742/2543/1444/644/9
44/1852/1552/1858/858/1158/2361/11
63/1865/2466/967/2068/268/668/12
68/1469/1769/2570/871/171/971/2472/9
72/1073/473/973/2574/1676/1478/19
80/1080/1181/1981/2181/22
HONORABLE [1] 2/10
house [41] 9/2510/114/1616/616/7
22/1822/2125/1425/1927/1234/2035/7
35/1035/1335/2436/240/943/243/24
43/2546/1347/1048/848/1148/1748/20
51/251/2051/2553/1058/358/1658/20
69/1071/2071/2271/2572/175/676/8
81/13
houses [2] 10/1423/2
how [49] 9/119/2010/810/1410/1911/4
11/711/911/911/1412/114/215/922/5
22/1222/1236/1438/143/945/1345/16
45/2246/446/950/951/353/1653/2356/23
56/2456/2458/659/1759/2260/260/8
61/1461/1761/2062/1062/2263/2164/16
64/2465/469/971/476/1677/19
however [4] 1/837/2540/1075/21
humanity [1] 43/8
Hunter [1] 25/3
I
I'd [3] 71/2572/2175/12
I'll [4] 32/2473/873/879/12
I'm [42] 6/99/410/811/313/214/1014/17
17/319/1623/1229/1534/1535/135/23
39/250/152/1952/2252/2252/2357/22
58/1459/1660/360/1460/1763/764/7
65/1168/568/1970/270/270/472/1874/2
75/977/277/379/1879/2380/12
I've [4] 16/2428/1545/1879/10
idea [2] 56/2256/24
identification [7] 14/1017/319/1623/13
60/1463/865/12
identified [2] 13/762/25
immediately [2] 10/221/10
impacts [1] 29/10
improve [1] 33/9
improvements [1] 18/6
INC [1] 3/5
incarcerated [4] 13/213/330/330/8
incident [11] 46/151/1252/352/652/7
52/855/956/1556/2058/258/3
incidents [2] 56/1457/10
include [2] 18/421/1
includes [2] 20/2524/10
including [2] 18/719/4
incur [1] 76/1
incurred [2] 21/838/5
incurring [1] 42/9
independent [1] 81/16
INDEX [1] 3/7
indicated [2] 32/1553/17
indicating [2] 15/2336/18
indictment [2] 78/880/3
individuals [1] 27/21
information [6] 32/132/546/1048/21
48/2549/5
informed [3] 53/754/2356/10
initial [1] 6/3
initially [2] 43/2552/25
initiated [2] 47/1848/20
injury [1] 72/16
inquire [1] 48/10
inside [7] 47/1050/1751/2456/1771/24
72/376/11
inspect [1] 13/23
instant [1] 64/25
Case 1:22-cr-00171-MLB-RDC Document 167 Filed 02/12/25 Page 88 of 95
I
intent [1] 21/3
interaction [2] 48/1051/5
interest [15] 12/326/1526/1926/23
26/2427/732/1932/2037/937/1839/18
50/2054/467/570/22
interests [3] 25/425/1141/8
interior [1] 18/5
investigating [1] 60/4
investigation [16] 45/1145/1447/18
49/751/1353/853/2157/457/1958/24
59/1459/2360/962/1162/1664/17
invoice [3] 25/632/932/10
invoices [2] 24/832/10
invoke [2] 8/79/8
involved [3] 57/757/876/8
involvement [1] 52/25
involving [3] 45/2559/2462/12
Irie [11] 46/447/547/647/948/1050/11
50/1250/1350/2151/953/16
is [288]
isn't [3] 13/2368/1169/14
issue [12] 7/1633/734/2035/2440/18
41/1049/1353/872/1272/1974/674/10
issues [4] 27/1627/1851/1358/15
it [164]
it's [53] 6/79/410/110/1312/1512/18
14/2415/1115/1115/2016/1017/1822/14
22/1422/1424/228/2230/230/1131/23
32/835/1937/2340/440/440/541/443/5
44/449/349/2349/2361/2262/1864/21
67/1167/1168/1769/2369/2570/670/9
70/1670/1771/2072/2573/2274/574/11
74/1375/2377/1979/9
item [2] 15/1915/23
its [4] 6/367/1670/1670/16
J
J-A-N-E-T [1] 9/5
jail [1] 71/17
JANA [3] 2/1782/482/18
Janet [3] 7/208/239/4
January [2] 31/2278/2
January 1 [1] 31/22
job [1] 25/21
joint [1] 78/14
judge [5] 43/1178/678/1178/2379/3
July [5] 24/1531/952/1377/977/24
July 2023 [1] 31/9
July 8 [1] 77/24
June [2] 19/2052/13
June 12 [1] 19/20
just [31] 9/712/2015/1516/122/2524/18
39/340/1943/1549/349/1849/2350/2
52/1862/464/1066/1268/268/1969/23
70/670/672/772/1072/2273/874/579/10
80/1980/2180/22
K
keep [4] 22/922/2539/375/20
keeping [1] 42/11
Kendal [2] 3/55/16
Kendal Silas [1] 5/16
kill [1] 8/6
kind [10] 13/741/1850/562/1764/20
68/1970/671/1974/1174/13
know [66] 10/610/710/712/212/2515/21
15/2516/816/1916/2022/922/2525/18
29/2431/1634/135/1236/936/1736/20
36/2338/1040/2140/2341/1643/2544/2
46/948/1251/851/1454/1954/2154/25
55/156/356/1357/257/1357/1857/20
58/1659/2560/260/560/860/2462/14
62/1962/2264/2264/2465/165/469/569/9
71/1072/175/775/876/1176/2379/579/24
80/480/5
knowledge [10] 11/613/1013/1646/7
49/1252/155/357/557/1957/22
known [1] 74/11
L
label [1] 42/10
land [4] 24/636/862/1864/21
landscape [5] 21/522/924/630/2231/22
landscaping [8] 18/820/2522/1222/13
22/1730/1830/2330/25
Lane [26] 9/2310/610/2311/2113/4
13/1814/2316/1424/2427/1728/1828/25
29/1033/633/2435/537/1745/2046/6
47/1048/959/1962/265/1666/2472/11
largely [1] 81/5
Larkin [1] 25/3
last [15] 9/324/1640/1942/543/1645/2
45/458/359/859/960/2566/1578/1780/19
80/22
late [2] 12/377/12
law [4] 21/1325/341/1168/18
lawn [2] 19/420/22
lawyer [5] 37/1337/1937/2439/1553/6
lawyers [3] 40/843/979/6
lead [1] 55/8
learned [4] 53/1354/154/654/12
least [6] 23/236/1369/376/976/2081/12
leave [3] 51/2255/2456/11
led [2] 57/1058/19
ledge [1] 16/1
ledger [6] 12/1023/1727/1031/2432/1
32/6
left [4] 14/1823/1932/438/9
legal [8] 25/125/925/2125/2325/25
27/2249/668/21
let [4] 16/2051/1476/2380/4
let's [2] 11/1781/6
letter [17] 17/1117/1317/2018/1619/3
19/1019/2119/2320/1020/1421/321/14
46/2249/1149/1351/1655/13
letters [4] 29/2329/2530/742/21
license [1] 50/25
lien [9] 25/1037/2438/340/140/240/10
40/1170/2470/24
liens [2] 37/2538/8
lighter [1] 15/20
like [26] 7/1912/1915/2416/123/227/21
33/1634/436/1238/1243/243/651/151/15
51/2156/361/371/2572/672/772/2175/12
76/978/2080/481/10
limited [2] 18/557/19
line [12] 1/624/1324/1627/161/1461/17
61/1761/2063/2163/2564/476/2
linger [1] 80/4
lis [6] 38/1738/1862/1364/1967/267/7
lis pendens [6] 38/1738/1862/1364/19
67/267/7
list [1] 48/13
listed [4] 32/1837/1244/265/6
listened [3] 77/2181/781/8
listing [2] 31/1660/19
listings [1] 10/22
litigation [3] 67/969/1969/20
little [5] 5/2312/2215/2040/352/18
live [5] 9/189/1910/1028/1758/16
lived [1] 9/20
living [2] 13/175/8
LLC [2] 20/2264/11
loan [1] 71/11
located [7] 18/745/1960/960/2062/7
63/1064/13
locks [1] 56/17
Logistics [1] 64/11
long [9] 9/2011/445/1345/1650/558/6
59/1769/976/16
look [9] 22/623/234/1035/1347/1970/4
74/975/675/6
looked [6] 5/2327/2136/1148/2160/25
69/1
looking [17] 13/313/913/1413/1914/3
27/833/2435/2361/1461/1761/2063/21
64/465/1866/469/375/10
looks [7] 15/2422/733/1534/469/775/19
78/20
losing [1] 39/18
lot [12] 12/1915/1615/1718/318/318/7
18/1742/1369/672/278/581/8
loud [1] 43/15
low [2] 36/1438/7
Lueder [1] 25/3
M
ma'am [2] 8/199/11
machine [1] 82/7
made [2] 50/1154/23
magistrate [5] 78/678/1178/1578/23
80/5
mail [1] 17/7
main [1] 18/2
mainly [1] 71/16
maintain [10] 16/1018/318/1718/2423/6
30/1933/937/1644/567/8
maintained [3] 13/2123/236/7
maintaining [4] 19/421/1822/222/9
maintenance [12] 17/2518/520/15
20/2321/121/824/524/824/2224/2430/13
31/14
maintenance/repair [1] 24/5
maintenance/repairs [1] 31/14
make [7] 8/420/1743/1043/1558/2168/8
76/13
makes [6] 12/2242/1575/475/1280/2
81/17
making [1] 42/3
male [6] 47/1350/2250/2351/1851/19
56/3
management [10] 16/1723/1825/19
26/526/1831/2131/2331/2532/532/23
Manor [4] 10/1317/2319/120/20
many [2] 10/1475/21
Marietta [5] 9/2345/2059/1962/266/24
mark [1] 32/25
marked [3] 14/1017/319/16
math [2] 62/564/7
matter [4] 40/2441/1155/2282/9
matters [1] 25/9
may [30] 1/21/514/716/2219/1319/14
23/923/1029/2431/1731/2034/1038/20
Case 1:22-cr-00171-MLB-RDC Document 167 Filed 02/12/25 Page 89 of 95
M
may... [17] 41/1344/1344/1447/2348/3
52/952/1060/1160/1263/263/365/765/8
67/2267/2373/1577/7
May 10th [1] 31/17
May 14th [1] 48/3
maybe [11] 5/2410/2239/440/740/23
41/1644/249/1566/1269/1276/4
me [28] 5/125/175/238/434/1241/10
50/1151/1452/753/656/765/1168/2170/7
71/2072/673/1474/1475/2076/2377/19
79/879/1379/1980/280/780/1382/12
mean [12] 22/738/1039/743/152/19
54/2268/1969/169/969/2170/1271/1
means [1] 22/1
meant [1] 75/20
mechanical [1] 2/15
member [2] 45/2558/17
members [2] 53/253/9
mentioned [5] 22/1629/2249/1556/9
56/15
mentions [2] 18/921/14
mere [1] 80/15
mess [1] 13/25
MICHAEL [1] 2/10
middle [3] 15/1915/2215/23
might [3] 16/879/1781/15
mildew [1] 69/6
million [4] 10/2143/2271/971/10
mind [1] 8/19
minimum [1] 75/16
minus [1] 24/16
mismarked [1] 34/15
missing [1] 53/9
misunderstanding [1] 50/12
misunderstood [1] 66/12
MLB [2] 2/482/10
mold [2] 69/672/3
moldy [1] 36/17
money [10] 27/1138/939/339/440/5
40/1470/2370/2571/1476/3
monies [1] 38/1
month [9] 12/1520/2322/1424/926/23
31/431/638/352/11
monthly [1] 12/21
months [4] 26/2547/1752/558/4
more [10] 12/2327/2035/952/156/2
56/1374/1075/1576/1180/5
morning [6] 9/119/129/169/1728/13
28/14
mortgage [7] 7/1038/1138/1338/14
68/2471/273/16
most [4] 43/343/343/579/6
motion [25] 5/66/36/1370/573/173/14
74/177/877/1177/1377/1477/1677/22
77/2277/2277/2377/2378/178/378/10
78/1278/1378/1578/2280/15
motions [3] 78/578/1678/18
move [13] 15/417/1519/2523/2334/6
35/1661/963/1565/2170/277/277/380/7
mow [1] 31/6
mowed [1] 22/10
mowing [4] 13/2219/424/931/7
Mr [7] 20/1447/147/1448/749/1551/19
53/13
Mr. [73] 6/117/158/159/911/2212/25
13/1517/717/2218/1819/719/1019/19
21/2227/1229/2329/2330/330/830/12
33/1237/2144/145/846/246/446/1246/18
46/1946/2447/547/647/647/947/1048/3
48/1048/1149/449/1050/950/1150/11
50/1250/1250/1350/1350/1750/2151/4
51/851/951/952/452/652/752/853/153/5
53/753/1253/1853/2354/1254/1955/2
55/1364/1268/1374/875/175/476/10
Mr. Brian [1] 49/4
Mr. Brian Holland [1] 48/3
Mr. Carl [3] 46/249/1050/12
Mr. Carl's [1] 50/13
Mr. Delano [14] 11/2217/717/2218/18
19/719/1019/1921/2229/2330/330/8
33/1237/2144/1
Mr. Delano's [2] 27/1230/12
Mr. Ghisi [1] 45/8
Mr. Gonzo [5] 46/2447/647/1050/11
51/9
Mr. Holland [13] 48/1150/950/1751/4
51/852/453/1853/2354/1254/1955/275/1
76/10
Mr. Holland's [3] 52/652/752/8
Mr. Irie [8] 47/647/948/1050/1150/12
50/1350/2151/9
Mr. Peter [1] 46/4
Mr. Petey [1] 47/5
Mr. Silas [8] 6/117/158/159/946/18
68/1374/875/4
Mr. Torjagbo [10] 12/2529/2346/12
46/1953/153/553/753/1255/1364/12
Mr. Torjagbo/Delano's [1] 13/15
Mrs. [1] 7/25
Mrs. Franchi [1] 7/25
Ms [2] 9/1634/17
Ms. [8] 15/923/1228/1333/235/342/20
43/1680/13
Ms. Colter [1] 80/13
Ms. Franchi [6] 15/923/1228/1333/2
35/343/16
Ms. Franchi's [1] 42/20
much [17] 10/1911/1412/122/1222/12
36/1540/1041/2244/1058/1261/1461/17
61/2063/2167/2471/475/15
mulch [1] 19/6
my [27] 7/48/58/510/111/514/1716/7
30/533/1937/2342/545/2347/1949/1
49/1249/2051/151/155/357/460/962/11
62/1664/1767/667/1170/20
myself [2] 42/2443/10
N
name [17] 6/79/310/713/817/1319/23
30/2245/245/345/447/1359/859/959/10
64/1064/1173/22
nature [1] 57/15
neat [2] 18/318/17
necessary [1] 20/18
need [10] 18/2425/1551/1451/2270/20
70/2170/2175/1976/1780/5
needs [5] 21/222/722/871/571/13
Negative [1] 47/8
neglected [1] 69/10
neighbor [6] 40/540/2541/1342/242/6
42/15
neighbor's [1] 42/18
neighborhood [11] 16/1117/1018/15
23/128/2228/2329/1129/1837/1042/12
43/21
neighbors [12] 14/123/125/529/1339/9
40/442/1442/2155/155/457/1469/2
new [1] 77/23
next [20] 10/110/218/2125/126/126/7
26/1428/628/1733/2033/2235/738/338/3
43/358/2361/1763/2564/479/21
Nicholas [1] 3/3
Nick [1] 5/11
Nick Evert [1] 5/11
no [67] 1/132/46/18/118/1712/1012/16
13/1113/1713/2113/2113/2215/617/17
19/1220/323/624/128/229/1529/2434/9
35/1838/2140/240/1940/1943/144/947/8
48/1849/651/2152/152/1554/2255/155/3
56/1356/2256/2457/557/2057/2261/11
63/1865/2466/768/770/2070/2170/21
71/171/171/1071/1071/1171/1873/4
73/2575/475/1178/679/279/881/2181/22
nobody [4] 58/2075/675/675/18
noncompliance [1] 17/8
normalcy [1] 43/8
normally [1] 69/18
north [1] 44/3
NORTHERN [2] 2/182/5
not [71] 6/96/2410/811/2512/1312/20
13/2116/718/518/1819/719/821/121/4
21/1821/2322/2422/2423/425/1529/6
30/2432/833/2538/838/2439/839/2540/4
40/2441/1341/2042/442/1142/1142/16
42/1643/943/1248/2449/649/850/151/2
53/2254/1554/2256/2057/457/2258/14
64/768/1769/2169/2270/170/970/10
74/1475/275/975/2076/577/1979/179/3
79/479/2380/1581/681/8
note [3] 1/1220/2564/10
nothing [2] 58/1180/1
notice [8] 14/416/1616/1817/617/8
19/1921/367/4
notified [2] 51/1556/21
November [4] 63/2464/666/678/13
November 15th [3] 63/2464/666/6
now [17] 30/230/633/1635/2339/740/5
45/1548/1848/1950/350/1571/1975/9
76/477/1177/2478/2
nuisance [1] 81/14
number [15] 1/61/612/215/724/2125/17
25/2332/933/134/735/1744/348/1250/24
82/10
Number 1 [1] 34/7
Number 2 [2] 33/135/17
numbers [5] 23/2025/1237/562/364/8
O
oath [1] 8/20
objection [12] 8/1515/617/1720/223/25
34/834/935/1838/2361/1163/1765/23
obligation [1] 6/4
obtain [2] 49/1154/4
obtained [5] 20/2146/2248/1349/13
53/24
obvious [1] 69/4
obviously [1] 42/20
occasionally [1] 8/6
occasions [1] 76/9
occupy [1] 27/21
occur [1] 52/4
October [3] 61/2577/1978/11
October 26th [1] 77/19
Case 1:22-cr-00171-MLB-RDC Document 167 Filed 02/12/25 Page 90 of 95
O
off [2] 16/1076/3
office [4] 3/348/2549/2154/7
officer [2] 29/1774/25
officers [9] 49/1351/2151/2354/2355/8
56/1656/2157/381/11
offices [1] 82/6
official [8] 1/11/21/31/71/142/1882/4
82/19
oh [11] 7/2212/1512/1731/244/1747/5
48/166/1668/368/574/2
okay [82] 5/206/26/207/27/197/217/24
8/48/98/128/199/99/1110/412/1212/17
12/2215/2316/1217/1818/2120/722/7
28/828/1028/1628/2429/929/1630/11
31/431/731/1032/332/732/832/1232/21
33/2034/334/1634/2535/436/436/10
36/2237/1938/1440/740/1742/1044/7
44/1044/1948/150/752/752/1653/12
53/2155/455/855/2256/1056/1958/9
58/1258/2561/1266/1767/1567/1967/21
67/2468/872/1872/2076/1376/2579/22
81/181/23
once [8] 12/2022/1022/1070/1470/14
70/1576/976/10
one [36] 6/146/156/2410/1610/2120/21
27/2029/930/1132/934/1340/1940/23
43/1543/1646/2346/2449/152/554/4
55/1456/256/956/1556/1556/2057/24
67/1768/1572/1277/1978/1678/1780/17
80/2281/5
one-time [1] 20/21
ones [2] 6/2180/24
only [10] 1/21/76/2420/2522/222/17
46/2355/1457/766/23
open [2] 5/482/8
optimistic [2] 79/579/9
order [11] 6/26/48/518/2468/2373/15
77/777/1077/1678/180/14
other [30] 6/106/217/118/108/1318/6
27/1627/1839/741/341/1747/147/647/9
51/956/2057/1057/1457/1457/2458/19
74/2074/2274/2375/275/575/576/10
80/2481/4
ought [2] 72/2374/6
our [20] 7/1914/416/1716/1820/1423/17
25/1025/1926/1837/1837/2441/743/8
46/2148/2049/1358/558/2372/1072/11
ours [1] 70/17
out [18] 6/229/2331/438/139/1139/14
39/1749/351/1451/2253/553/1255/455/9
56/2372/2478/2080/24
outside [3] 8/1325/1631/5
outstanding [3] 65/1765/1770/5
over [8] 16/822/1529/732/257/1575/6
75/1081/6
overall [1] 45/17
overgrown [4] 19/636/1436/2169/7
overrule [1] 39/2
owe [3] 12/112/212/3
owed [8] 40/1060/561/1461/2062/19
65/173/2480/16
own [3] 32/149/353/21
owned [2] 38/1564/12
owner [6] 7/1010/611/2146/668/25
73/17
ownership [2] 76/781/13
owns [1] 33/13
P
page [6] 1/64/215/2019/2327/866/4
pages [3] 76/1576/1580/14
paid [11] 37/1340/248/1648/1849/17
50/253/2354/1368/969/1576/6
paragraph [3] 17/2018/918/21
paragraphs [1] 20/9
paralegal [1] 5/18
parentheses [2] 26/1526/21
part [11] 10/1616/233/1933/2233/23
42/743/1970/373/1574/2179/8
parte [1] 77/21
partial [1] 1/9
participate [2] 17/1119/21
particular [2] 6/1529/20
particulars [1] 78/22
parties [1] 79/24
party [4] 73/173/1473/2574/1
passible [1] 69/3
past [3] 21/1129/229/5
patrol [1] 51/15
pay [9] 11/1111/2212/412/2039/12
39/1550/471/1871/19
payable [1] 21/10
paying [7] 39/339/839/942/1149/1650/4
75/2
pays [2] 11/1048/15
PDF [1] 1/1
pendens [6] 38/1738/1862/1364/1967/2
67/7
pending [3] 67/1068/2372/16
people [13] 41/341/742/343/343/355/10
55/1955/2456/1457/1475/876/781/12
per [3] 11/1819/220/23
percent [3] 27/432/1532/19
Perfect [1] 8/18
perhaps [1] 69/3
period [3] 1/430/630/9
perishable [1] 72/15
permission [3] 27/2246/2047/2
permitted [2] 47/768/17
person [11] 13/913/1246/346/2349/23
55/1456/756/1056/1758/258/3
personal [1] 57/19
personally [1] 56/21
Peter [6] 13/813/1213/1846/447/553/16
Petey [1] 47/5
phone [5] 8/547/1450/2453/553/6
photograph [7] 14/1214/1914/2015/14
22/433/336/7
photographs [1] 32/24
pick [2] 79/1479/18
picture [5] 34/2435/335/536/936/16
piece [1] 40/3
pine [5] 13/2215/1619/622/1024/11
place [2] 38/450/10
placed [1] 48/23
plainly [1] 79/12
Plaintiff [2] 2/43/3
planning [1] 49/19
please [17] 9/317/2018/2120/920/25
21/1624/2125/225/2326/826/1726/22
27/1945/159/764/466/2
plenty [1] 71/13
plus [4] 12/316/1022/1480/2
PMI [3] 23/1824/1731/25
pocket [3] 39/1239/1439/17
point [19] 27/2030/1130/1631/831/20
37/2038/1539/243/1443/1655/1257/3
57/457/1857/2157/2269/2070/2075/4
points [1] 37/5
police [15] 8/145/945/1145/1654/23
55/255/455/2356/456/558/1958/1974/25
76/881/11
ponding [1] 71/6
pool [23] 14/1514/2214/2515/315/10
15/1716/1119/421/123/769/969/1169/11
71/571/1371/1875/1975/1975/2075/20
75/2275/2281/14
portion [1] 1/5
position [2] 6/1018/18
possession [3] 50/350/550/13
possessory [1] 54/4
possibility [1] 37/20
possible [1] 45/25
potential [2] 28/446/3
potentially [2] 29/1142/14
power [4] 22/823/636/1771/25
premarked [4] 23/1260/1463/765/11
preparation [1] 1/13
prepared [3] 7/118/1223/17
present [1] 5/17
preserving [1] 68/23
president [1] 29/14
pressure [1] 19/5
pretrial [13] 77/877/1177/1477/1777/18
77/2177/2478/278/378/578/1078/16
78/18
pretty [6] 69/169/469/469/772/2574/16
prevent [1] 67/8
previous [12] 24/1325/1725/1926/2
26/1627/131/1831/2231/2332/132/14
32/22
previously [2] 47/147/3
price [1] 38/21
primary [1] 43/4
printed [2] 65/1965/20
printout [1] 65/14
prior [6] 15/226/426/1827/531/2032/23
priority [1] 37/25
probably [4] 52/569/1971/276/19
problem [1] 76/7
problems [2] 57/1475/5
proceeding [1] 33/8
proceedings [6] 2/112/1581/2482/8
82/1082/13
proceeds [5] 60/362/1664/2567/13
70/18
produced [1] 2/15
PROGRAM [2] 3/55/19
prohibited [1] 1/8
prohibitive [1] 16/10
pronged [1] 72/12
pronounce [3] 10/846/553/16
properties [9] 5/76/56/106/147/167/15
67/1772/1080/17
property [116]
prosecutor [1] 79/25
protect [4] 25/425/1037/937/18
protected [1] 70/22
prove [1] 6/4
provide [3] 67/467/481/15
provided [2] 16/2421/6
provides [3] 26/226/1572/14
provisions [1] 21/12
pruning [2] 19/524/11
Case 1:22-cr-00171-MLB-RDC Document 167 Filed 02/12/25 Page 91 of 95
P
public [1] 40/2
purchased [6] 44/159/2560/262/14
64/2264/24
purpose [2] 67/674/13
pursuant [1] 21/5
pushed [1] 78/17
put [6] 6/232/138/442/1048/1878/20
putting [1] 69/14
Q
quality [1] 18/25
quarter [1] 79/18
question [4] 31/1332/1240/2080/15
questions [5] 28/228/1552/1566/7
74/25
quibbling [1] 81/6
quickly [2] 77/277/3
quiz [1] 64/7
quo [1] 67/8
quote [3] 18/342/1542/16
R
raised [1] 11/17
ran [1] 49/1
random [2] 49/2349/25
range [1] 43/21
rarely [2] 68/1568/17
rather [2] 52/2369/11
RDR [2] 2/1782/18
reached [3] 53/553/1255/4
read [8] 17/2018/2120/924/2125/2366/2
72/2579/10
reading [1] 79/9
ready [7] 69/2374/1474/1579/179/11
79/1379/19
real [1] 73/11
really [12] 6/2423/423/633/1734/22
36/1536/1669/570/2172/472/481/7
Realtime [1] 2/17
reasonable [1] 70/9
reasonably [1] 70/22
recall [2] 47/1862/15
receipt [1] 19/3
received [2] 24/852/2
recited [1] 62/4
recognize [3] 14/1223/1433/2
recollection [1] 47/21
recommendation [1] 78/21
recompense [1] 37/20
record [5] 9/29/745/159/782/13
recorded [3] 2/1525/1040/11
records [1] 40/2
recoup [1] 38/5
recouped [1] 38/20
recourse [1] 37/24
recover [1] 40/13
redirect [3] 44/852/1758/9
reduced [1] 82/11
reference [1] 14/25
referencing [1] 1/6
referring [3] 15/2245/2346/22
reflect [1] 25/13
reflected [1] 23/20
refresh [1] 47/20
refreshing [1] 19/6
regard [5] 66/2067/167/567/1567/17
regarding [2] 17/2520/15
regards [1] 6/6
regular [1] 28/20
related [1] 25/13
relates [2] 66/1366/16
relation [4] 9/2514/1637/1553/2
relationship [1] 41/2
relative [1] 30/12
relax [1] 43/6
remember [1] 58/5
remind [2] 17/2452/7
rendered [1] 37/15
repainting [1] 18/7
repair [3] 24/524/2271/12
repairs [1] 31/14
repay [1] 70/18
repeat [1] 58/21
report [7] 45/2445/2447/1947/2047/25
53/178/20
reported [1] 82/7
Reporter [6] 1/31/71/122/1882/482/19
REPORTERS [1] 82/1
reports [1] 54/24
representation [3] 60/2261/563/12
request [3] 19/220/2478/14
require [1] 70/10
required [8] 10/1611/1111/2216/1818/2
18/1619/2076/8
research [1] 74/10
reset [2] 77/877/14
resided [1] 33/13
residence [2] 51/2456/22
resident [1] 29/18
resolved [1] 55/22
respectfully [1] 20/24
respond [2] 51/2357/15
responded [1] 51/15
response [4] 16/1419/1021/2529/24
responsibilities [2] 18/1421/19
responsibility [2] 18/421/9
restricted [1] 1/3
restrictions [1] 20/19
result [1] 27/12
results [1] 53/7
retain [1] 25/4
retract [1] 42/5
return [1] 50/15
returned [1] 38/1
returns [1] 50/16
review [1] 25/9
right [99]
risk [4] 7/972/272/1575/24
road [1] 76/2
role [3] 10/2511/211/6
rolls [1] 80/22
rotted [1] 69/11
row [1] 14/18
rule [3] 7/68/79/8
rules [2] 17/2518/14
running [1] 23/5
runs [2] 51/2458/3
rushes [1] 56/17
S
S-C-O-T-T [1] 59/9
safety [1] 41/6
said [14] 5/2434/343/2049/649/1849/21
50/250/1450/2551/1351/1951/1956/7
82/10
sale [8] 6/1423/138/2038/2039/441/12
70/1073/23
same [1] 66/20
sanitary [2] 18/418/17
satisfied [1] 72/17
say [14] 41/2442/642/842/1946/1948/7
51/1752/555/255/564/164/574/880/5
saying [5] 6/349/1554/155/1375/9
says [20] 18/1624/424/2025/126/126/7
32/1332/2248/1653/2370/1772/2172/22
72/2473/173/1474/774/1974/2074/20
schedule [2] 63/1064/10
scope [1] 38/25
Scott [5] 5/128/258/2459/259/9
second [6] 19/1932/2535/352/355/9
55/22
secondarily [1] 81/4
section [11] 18/824/424/2025/126/1
26/726/1426/2031/1431/1832/13
see [28] 11/1714/114/614/1822/422/7
28/2028/2231/1633/1733/2334/2235/12
35/1236/136/636/1436/1536/1837/6
42/1942/1969/369/569/1969/2072/21
80/23
seek [1] 68/18
seeking [1] 37/20
seem [1] 41/22
seems [2] 71/1973/19
seen [1] 54/22
Sekret [2] 3/45/13
self [9] 21/421/1522/124/1530/833/9
36/1237/169/2
self-help [9] 21/421/1522/124/1530/8
33/936/1237/169/2
sell [2] 5/76/4
selling [1] 69/10
sense [2] 12/2376/13
sent [8] 16/1616/1817/619/1926/529/23
30/770/7
September [1] 77/15
serious [1] 75/23
seriously [1] 43/1
serves [1] 21/3
services [2] 37/1537/22
set [5] 37/1077/977/2478/279/19
setting [3] 77/1177/1477/18
seven [1] 79/25
several [2] 5/758/4
shakes [1] 38/1
shall [1] 18/4
share [2] 39/842/11
she [2] 78/2080/13
short [2] 50/572/19
should [5] 51/271/1871/1975/1580/2
show [6] 7/47/832/2433/2535/340/2
showed [1] 47/20
showing [8] 14/1017/319/1623/1260/14
63/765/1165/15
shown [2] 33/536/6
shows [4] 12/1014/1514/2465/16
shrubs [1] 36/15
shut [1] 16/10
side [2] 10/134/1
sidewalks [1] 36/16
signed [1] 55/13
signs [1] 48/19
Silas [10] 3/55/166/117/158/159/946/18
68/1374/875/4
Case 1:22-cr-00171-MLB-RDC Document 167 Filed 02/12/25 Page 92 of 95
S
simultaneous [1] 80/14
since [6] 11/1613/1531/945/1851/8
56/13
single [1] 41/20
sinks [1] 38/7
sir [4] 50/652/2466/2567/24
sits [2] 71/672/1
situation [4] 13/125/1350/1469/18
small [1] 28/22
smell [2] 16/516/5
Sneed [2] 3/45/13
so [116]
sold [6] 37/2538/240/943/2570/1573/15
some [19] 7/514/115/1527/2029/19
30/1330/1631/2037/2042/2151/553/3
53/2268/969/571/1275/276/776/10
somebody [8] 13/728/349/249/851/24
55/556/576/2
somehow [1] 7/9
something [11] 6/410/816/143/644/3
49/1549/1850/2156/372/2475/12
sometime [5] 60/162/1564/2369/2176/2
sometimes [2] 74/474/5
soon [3] 51/1151/1179/3
sorry [11] 8/434/1547/552/852/1952/22
52/2252/2360/1768/574/2
sort [7] 15/1930/1230/1333/937/937/20
51/5
sound [2] 8/661/2
sounded [1] 12/19
sounds [2] 72/776/9
south [1] 72/1
speak [3] 42/1842/2447/14
special [3] 59/1359/1659/17
specific [1] 41/10
specifically [2] 6/1818/2
spell [3] 9/345/159/7
spend [2] 27/1243/5
spent [1] 24/23
spoke [4] 48/250/1151/1152/9
spoken [1] 46/12
spring [4] 14/2114/2327/2527/25
squatter [2] 56/1675/3
squatters [7] 6/1728/428/446/1257/21
74/2276/10
staked [1] 70/16
standards [2] 17/975/16
standing [4] 8/1915/333/2237/4
start [2] 72/581/6
started [5] 14/322/122/124/1424/15
starting [3] 5/824/431/21
state [5] 6/179/316/1545/159/7
stated [1] 70/16
statement [2] 68/371/8
STATES [6] 2/12/35/95/1382/582/9
status [2] 48/2367/8
status quo [1] 67/8
statute [10] 68/1168/2269/1672/13
72/1472/2573/1374/1674/2074/20
statutes [1] 18/13
stay [2] 51/2077/22
Stenograph [1] 82/7
Stenographic [1] 1/12
stenography [1] 2/15
step [3] 67/2267/2368/15
Stephen [1] 25/8
Stephen Finamore [1] 25/8
still [4] 13/951/558/1473/22
stop [1] 13/12
stopped [1] 13/19
story [1] 50/19
straw [4] 13/2219/622/1024/11
street [1] 28/24
structures [1] 18/7
stuff [2] 41/1752/3
subject [5] 55/2068/2368/2469/1173/16
subjective [1] 42/10
subsequent [1] 30/7
subsequently [2] 53/1253/21
substantive [1] 60/3
subtracted [1] 24/18
such [1] 18/4
sufficient [1] 72/13
summer [2] 72/279/17
sunk [1] 15/24
superseding [1] 78/8
supervisors [1] 49/1
Supplemental [1] 7/5
supposed [1] 77/18
suppress [1] 70/5
sure [6] 7/1510/843/1752/1958/1458/21
surfaces [2] 18/619/5
suspect [1] 69/12
SW [1] 2/19
swimming [1] 15/11
sworn [3] 8/2444/2259/3
Systems [1] 2/17
T
table [2] 5/125/17
take [14] 14/516/916/2016/2117/819/2
19/1053/1770/2171/1471/1773/1278/7
80/2
taken [8] 13/2314/2036/945/2453/357/2
60/2460/25
taken -- it [1] 60/25
taking [3] 8/1942/258/18
talk [1] 74/14
talked [4] 49/451/151/453/16
talking [4] 7/1237/2338/1972/5
talks [1] 50/18
tanning [1] 16/1
tape [1] 77/22
tax [19] 40/146/1048/2249/2154/760/19
60/2060/2361/662/2463/1065/1465/15
68/2570/2471/772/1072/1273/16
taxes [41] 7/1440/248/1448/1548/16
48/1849/1649/1749/2150/250/450/4
50/1953/2354/1360/561/161/1461/16
61/1861/2161/2362/162/1962/2563/21
63/2264/165/165/668/969/1570/1370/14
72/2272/2373/2475/276/680/1681/16
technically [1] 73/21
technology [1] 1/13
Ted [1] 2/19
tell [4] 41/2168/2175/2079/12
tells [1] 80/13
ten [7] 16/1916/2119/320/2521/521/22
80/1
Terminus [1] 23/18
terms [2] 38/1838/20
testified [3] 8/2544/2359/4
testify [2] 8/1028/7
testimony [2] 42/2043/20
than [12] 8/1015/2036/1147/147/647/9
51/956/2069/1174/2075/1576/11
thank [24] 9/29/614/816/417/119/9
34/2535/2244/744/1044/1244/1544/16
44/2545/548/258/1258/1359/663/463/5
65/967/2481/23
thanks [1] 9/12
that [406]
that's [78] 5/206/16/237/127/1612/8
15/315/1516/117/1418/822/1922/22
26/1326/2326/2426/2426/2528/1929/21
30/130/530/1531/332/1732/1933/633/12
33/2034/1634/1934/2035/835/937/237/7
38/138/440/2141/341/1741/1943/2344/6
46/449/1050/650/1951/251/752/1453/11
55/1356/958/762/362/362/1164/1766/19
66/2167/367/667/2069/1269/2269/22
69/2570/870/970/2071/275/576/2277/17
78/578/1381/3
theft [5] 45/2445/2546/353/257/5
their [17] 14/221/1821/1925/2126/526/6
32/139/339/443/443/443/549/370/23
70/2575/1676/3
them [12] 12/2014/528/342/343/349/2
49/950/1850/1855/1268/981/5
themselves [2] 32/1056/17
then [29] 26/226/1026/2027/130/738/8
40/940/1348/1548/1548/2148/2549/4
49/1050/2355/855/956/256/1358/23
63/1963/2569/1070/975/278/878/14
78/2281/17
theory [3] 38/740/1540/16
there [98]
there's [32] 15/1615/1715/2523/625/17
27/132/938/838/1138/1741/2041/2549/7
55/555/1456/2058/2070/470/2170/21
71/1071/1072/1273/2375/475/675/6
75/1078/879/881/881/12
therefore [2] 48/1950/3
these [12] 6/419/727/937/2242/342/3
43/2157/1058/2167/1567/1778/6
they [34] 8/410/2111/1311/1911/19
11/2022/2427/2131/639/339/339/441/17
42/1943/243/549/2150/1151/1851/22
51/2451/2555/1055/1255/2356/1056/11
56/2468/2170/2370/2475/1576/176/3
they're [9] 6/2411/1516/2023/223/18
31/744/555/2060/9
they've [2] 38/569/2
things [18] 15/1219/740/2341/1142/4
42/1253/357/1558/2058/2169/770/572/1
72/679/2480/2281/1081/15
think [48] 6/76/147/1212/513/515/15
16/123/526/2441/1741/2543/643/943/19
43/2044/246/456/266/1469/1769/19
69/2369/2570/470/670/971/872/172/2
72/1773/1874/674/774/1674/2275/9
75/1375/2275/2579/1079/2380/280/17
80/1980/2180/2181/481/7
third [2] 19/2381/13
this [138]
those [21] 6/1810/1611/1111/2418/12
24/725/227/1929/2437/442/1242/16
55/1955/2462/364/870/1472/175/25
81/1081/15
though [3] 34/1037/443/1
thought [6] 5/2412/1925/2053/258/18
68/20
threat [1] 71/20
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threats [1] 75/1
three [14] 7/17/2220/920/1120/1240/13
62/367/1567/1771/677/1780/1780/25
81/1
Thrive [7] 24/624/831/231/331/431/19
36/7
through [6] 31/1731/1960/969/269/19
69/20
throughout [2] 30/630/8
Thursday [2] 61/361/4
tie [1] 41/17
time [15] 20/2129/329/443/549/1150/24
55/2356/256/772/1879/679/779/2080/5
80/13
timeframe [1] 58/21
title [3] 45/1059/1567/9
titled [1] 26/20
today [5] 29/529/675/1375/1478/13
together [1] 79/14
told [6] 40/854/1555/1255/2356/756/22
too [1] 49/25
took [2] 31/2534/10
top [5] 15/324/1332/1365/1866/4
TORJAGBO [21] 2/55/1810/811/22
12/2513/1529/2346/246/846/1246/19
53/153/553/753/1255/1359/2462/12
64/1264/1882/9
torn [1] 75/21
total [15] 22/1224/2024/2225/2326/11
27/627/727/727/927/1062/162/364/8
66/266/3
totally [1] 69/9
touch [1] 52/2
Tract [1] 64/13
transactions [1] 60/19
transcript [11] 1/11/51/81/91/142/11
2/1576/1776/2180/1482/12
transcripts [1] 1/2
treasurer [5] 11/311/411/629/1529/16
trees [5] 14/1815/1615/1619/636/14
trespass [4] 46/2249/1151/1655/13
trespassing [1] 48/19
trial [4] 79/279/1179/1380/3
trim [1] 22/10
trimming [4] 13/2119/522/824/11
trimming/pruning [1] 19/5
true [1] 82/12
truth [1] 40/21
truthfulness [1] 53/22
try [3] 76/379/1579/20
trying [2] 27/2181/13
Tuesday [1] 48/3
turn [1] 8/5
Turner [1] 2/19
twice [4] 24/931/431/681/12
two [13] 10/2252/552/1172/972/1276/9
78/778/2180/280/1280/1780/1880/19
two-pronged [1] 72/12
type [1] 7/11
types [1] 81/10
typewritten [1] 82/11
typical [1] 43/20
U
U.S [3] 1/142/183/3
U.S. [1] 17/7
U.S. mail [1] 17/7
ultimately [1] 31/2
unair [1] 72/2
unair-conditioned [1] 72/2
unauthorized [1] 41/7
under [10] 14/421/1741/1159/2364/11
68/1168/1868/2172/1373/18
understand [10] 28/1729/931/437/8
41/1442/1943/1357/1879/1680/9
understanding [9] 30/230/230/530/6
30/1137/2338/1167/667/11
Understood [5] 16/423/824/1925/22
77/1
undertake [2] 21/2023/7
undertook [1] 25/8
undeveloped [6] 6/2162/1864/2166/17
66/2172/9
uniform [1] 18/25
uniformed [2] 55/857/3
uninvited [1] 48/17
unit [2] 45/1245/14
UNITED [6] 2/12/35/95/1382/582/9
United States [1] 5/9
unknown [3] 47/1351/1956/17
unless [5] 23/434/1268/368/368/20
unpaid [19] 26/426/1026/1126/1126/19
48/1349/2161/161/1661/1862/162/25
63/163/2265/670/1272/2272/2380/16
until [8] 27/1431/877/878/478/1178/13
78/1780/12
up [26] 8/1911/2414/1717/920/1422/25
25/126/126/726/1427/1430/2430/2531/8
31/1040/1242/1148/2256/2562/1163/25
64/464/1771/1975/2180/22
update [1] 48/22
updates [1] 52/2
upkeep [4] 29/1930/1331/539/12
upon [2] 38/2039/4
upper [2] 14/1823/19
us [2] 16/2025/20
used [1] 1/13
V
valuation [1] 38/19
value [7] 38/739/2441/442/1443/21
71/2075/24
valued [1] 71/3
values [2] 18/2529/11
vantage [1] 37/4
various [1] 31/16
vehicle [1] 50/21
verge [1] 79/11
very [11] 24/1627/831/1832/1244/10
58/1267/2472/1979/579/979/12
via [1] 53/5
victims [3] 67/1370/1870/19
view [3] 34/135/935/10
visible [1] 23/4
W
wait [3] 40/840/840/9
walk [4] 23/428/2429/229/5
walking [1] 28/22
want [13] 23/232/2440/1742/2443/6
43/1050/1450/1568/874/976/376/16
76/23
wanted [3] 31/1343/1566/12
wants [1] 69/13
warning [1] 49/13
was [132]
wash [1] 23/6
washed [2] 22/836/17
washing [1] 19/5
water [7] 15/315/1015/2016/923/554/1
71/6
way [9] 23/634/2343/248/2054/557/24
72/2579/1081/5
we [76] 5/65/246/156/189/711/1712/10
12/2013/513/2013/2316/716/816/916/16
16/1616/1617/617/2219/219/1920/24
22/122/122/922/1022/1022/2423/724/7
24/824/1124/1424/1525/325/625/15
25/2027/2028/2230/2430/2531/1631/21
33/2236/136/638/140/2141/1843/843/24
44/1849/251/1551/2354/1958/2368/7
69/1369/1869/1970/2570/2571/2472/17
73/575/876/576/676/1176/1776/2079/17
79/2080/4
we're [19] 5/206/127/17/57/1213/22
22/2428/2232/1940/2443/969/2277/6
79/1079/1379/1479/1579/1780/7
we've [3] 74/1175/1375/14
website [12] 46/1148/2260/1060/20
60/2160/2361/662/2463/1365/565/5
65/14
Wednesday [1] 61/4
weed [1] 19/4
week [1] 60/25
weekend [1] 29/7
weeks [2] 78/2180/12
weird [2] 74/1174/13
well [33] 6/128/912/212/1013/2015/11
16/1618/1520/422/1425/633/1735/336/9
37/2342/542/2462/1362/1563/164/19
68/1471/771/1671/2173/1374/574/9
74/1174/2475/475/1078/13
went [8] 26/426/926/1148/1650/21
55/2366/1576/10
were [26] 5/246/156/176/1811/1911/19
11/2012/914/222/425/927/2129/2229/23
30/731/1933/2233/2449/249/2153/857/2
62/2575/2381/2482/11
weren't [1] 79/6
what [84]
what's [11] 14/1017/319/1623/1227/6
58/1760/1463/765/1172/875/7
whatever [3] 38/2071/581/14
when [44] 5/236/213/313/1214/2026/4
27/2427/2428/2236/936/1237/2538/2
41/1643/1943/2546/2247/1650/1150/16
50/1950/2151/451/2452/452/452/853/18
55/2255/2358/1759/2560/2460/2561/23
62/1463/2364/2265/1966/471/672/4
79/1280/7
whenever [1] 38/2
where [24] 9/189/2510/1014/1624/4
24/1425/1326/1028/2430/732/1333/8
41/1843/545/845/2450/2553/655/956/3
56/1658/258/359/13
Whereas [1] 80/24
Whereupon [1] 81/24
whether [17] 38/338/1140/2441/241/10
41/1242/1548/849/1753/2257/1369/20
80/1581/381/481/1081/15
which [15] 7/1016/1921/123/1825/13
32/1639/2141/743/1645/2366/1468/25
72/1273/1777/24
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while [2] 46/2467/9
who [25] 5/135/187/258/213/613/614/1
30/1246/146/146/346/646/1746/1746/19
47/447/1249/2250/1854/2355/1471/18
71/1973/373/6
who's [1] 49/8
whoever [1] 56/16
whole [1] 79/6
why [9] 5/205/2432/1732/1750/1869/14
71/1574/2580/4
will [16] 1/37/229/221/921/921/1021/13
27/1528/641/1645/149/954/1859/770/23
70/25
wind [1] 50/22
wish [1] 71/8
within [7] 16/2119/320/2521/521/19
21/2252/11
without [1] 27/22
witness [15] 4/27/208/2428/643/10
43/1244/1344/2258/758/958/2359/366/8
67/2169/4
witnesses [5] 7/238/1368/468/781/8
won't [1] 42/10
wonder [1] 78/6
word [1] 16/17
words [1] 39/7
work [13] 20/2421/521/2021/2121/22
31/132/832/1145/845/959/1371/1271/12
worked [2] 16/1745/16
working [2] 37/971/23
worried [1] 74/24
worse [1] 36/24
worth [4] 10/1910/2171/471/9
would [56] 7/147/198/78/199/812/212/3
12/1315/415/917/1518/2119/2522/5
23/2325/1526/1927/427/2533/2334/6
34/1435/1638/138/438/539/1840/742/5
42/843/743/2444/1846/447/1947/2052/5
52/1155/1756/1158/558/2361/963/15
65/2166/2368/368/368/1569/1869/18
70/974/2174/2276/1780/22
wouldn't [4] 42/642/642/2343/2
wraps [1] 81/16
wreck [1] 76/23
write [1] 17/22
writing [2] 17/1119/21
wrong [3] 5/2469/1680/20
Y
y'all [1] 68/8
yard [20] 13/2114/517/920/2221/1822/9
30/1931/631/733/1733/1933/2233/23
34/1834/2234/2336/136/669/275/17
yeah [15] 6/87/2211/1512/1115/15
15/2315/2527/427/1041/444/1752/12
64/2373/1078/24
year [24] 11/511/1712/1512/1612/17
12/2014/2115/222/1022/1122/1524/7
24/1425/726/926/1026/1227/528/138/3
48/561/2477/479/21
years [15] 9/2140/1345/1559/1871/6
75/2278/779/2580/180/280/1780/18
80/1980/2581/1
yes [134]
yet [2] 50/479/1
you [264]
you'd [1] 55/24
you're [20] 10/129/1633/2033/2538/19
39/1139/1439/1739/1839/2140/1043/12
45/2346/2155/2457/1169/1074/274/2
74/13
you've [3] 54/2273/1374/12
you-all [8] 6/2331/236/1236/2549/25
68/2272/1879/6
your [120]
Your Honor [60] 5/105/166/126/226/25
7/77/137/177/238/78/88/179/714/715/4
15/616/2217/1728/228/934/734/1334/15
35/135/1635/2139/640/1941/2342/7
42/2543/1444/644/1852/1552/1858/8
58/1158/2361/1166/967/2068/268/6
68/1268/1469/1769/2570/871/2472/9
73/473/973/2574/1676/1478/1980/10
80/1181/19
yours [1] 35/7
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