Court filing
TRANSCRIPT of Proceedings (Jury Trial) as to Carl Delano Torjagbo held on 07/22/2025,… — USA v. Torjagbo (Dkt. 265)
Record facts
| Court | U.S. District Court for the Northern District of Georgia |
|---|---|
| Filed | 2026-02-10 |
U.S. District Court for the Northern District of Georgia · No. 1:22-cr-00171-MLB-RDC · Doc. 265 · 2026-02-10 · Docket on CourtListener
Summary
Volume 2 of the transcript of jury trial proceedings for July 22, 2025 in United States of America v. Carl Delano Torjagbo, also known as Karl Lucius Delano, Criminal Action File No. 1:22-CR-00171-MLB, before the Honorable Michael L. Brown in the U.S. District Court for the Northern District of Georgia, Atlanta Division. It is Doc. 265, filed February 10, 2026, and runs to 281 pages. The morning session addresses jury instructions: the court reports its own edits, says it will instruct the jury before closing arguments, and notes a dispute over whether an intent to cause a loss must be shown. The government tenders a cautionary instruction under Rule 404(b), modified from the Eleventh Circuit pattern, to be read before testimony about the acquisition of two Social Security numbers. Counsel also discuss reading stipulations to the jury.
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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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
) VOLUME 2
CARL DELANO TORJAGBO
)
also known as
)
KARL LUCIUS DELANO,
)
)
Defendant.
)
_______________________________)
--------------------------------------------------------------
BEFORE THE HONORABLE MICHAEL L. BROWN
TRANSCRIPT OF PROCEEDINGS
JULY 22, 2025
--------------------------------------------------------------
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
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APPEARANCES:
For the Plaintiff: OFFICE OF THE U.S. ATTORNEY
(By: Kelly K. Connors
Nicholas L. Evert)
For the Defendant: LAW OFFICE OF L. BURTON FINLAYSON
(By: L. Burton Finlayson)
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INDEX TO EXAMINATIONS
WITNESS PAGE
TYSON FOWLDER
Direct Examination By Ms. Connors
291
Cross-Examination By Mr. Finlayson
379
Redirect Examination By Ms. Connors
393
Recross-Examination By Mr. Finlayson
396
KOBINA OPPONG
Direct Examination By Ms. Connors
398
Cross-Examination By Mr. Finlayson
422
Redirect Examination By Ms. Connors
428
Recross-Examination By Mr. Finlayson
429
Further Direct Examination By Ms. Connors
431
MONICA SWEETEN
Direct Examination By Mr. Evert
432
Cross-Examination By Mr. Finlayson
439
Redirect Examination By Mr. Evert
443
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_ _ _
P R O C E E D I N G S
(Atlanta, Fulton County, Georgia, July 22, 2025, in open
court.)
THE COURT: Okay. We're still waiting on two or
three jurors. I'm getting updates that they're close. That
would not have worked with my father on a cold hunting
morning, but at any rate.
A couple of things. I got your jury instructions.
I'm not going to look at that, because I already made those
changes and I took out the aggravated. And then where you
explained which count is which, I updated those, I think that
was the two significant changes.
MS. CONNORS: Yes, Your Honor.
Of course there could be some additions as the trial
goes on.
THE COURT: Yes. But I've got the pen now. So if
you want more, then you just send me what you want to add,
talk to each other and send it to me, but that way I'm working
to put it in the right format and things like that.
Okay?
And by the way, I'm going to -- I typically instruct
the jury before your closing arguments. I know that that's
not standard here, but I had a couple of judges I was in front
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of who did that, it makes it a lot -- I think it makes it
better for the jury, because they know what they need to
listen to. And I thought it was helpful to the parties
because they don't have to carry the water of explaining
something for the first time, so that's my plan. That's what
I've always done.
If somebody has some belief that it shouldn't be done
that way, let me know, but my plan is to instruct the jury on
everything ahead of time except for the instruction where you
say the next thing you do is go select a foreperson and then
start your deliberations. Okay? That's one thing.
The second thing is we will probably talk about jury
instructions tomorrow. I see the dispute that you-all are
having about whether or not there has to be an intent to cause
a loss. Let's talk about that.
I did not like that Takhalov case when it came out.
I think that Takhalov case was misargued by the government as
to what the actual loss was, given the context of what the
fraud was in that case. I don't think the fraud was about
selling a quality of alcohol, I think the fraud was different
in that case, and so I want to think and talk with you more
about that tomorrow.
I'm also not sure that it makes much of a difference
in this case, because this case is about money, right?
In this case the claim is that he -- it did inflict a
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monetary loss on the government, right?
Is there going to be any claim that it was accidental
or unintentional?
He said -- allegedly said give me money for this. So
I'm not sure it really matters, but we'll talk about it at the
time. Okay?
MR. FINLAYSON: Maybe as to one count.
THE COURT: What's that?
MR. FINLAYSON: Maybe as to one count, that is --
THE COURT: Right. We're talking about the bank
fraud and the wire fraud, that's the two that it applies to.
MR. FINLAYSON: Right.
THE COURT: Okay. Well, we can talk about it at the
time.
Okay?
You're saying not -- that it didn't apply for the
tax?
MR. FINLAYSON: Correct.
THE COURT: Okay. Well, we can talk about that at
the time. So be ready to talk about that tomorrow at the end
of the day.
Is the government planning on putting in the
recording today?
MS. CONNORS: No, Your Honor. I think that's going
to come in through one of the agents tomorrow.
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THE COURT: Okay. So let's also talk about that at
the end of the day today.
MS. CONNORS: Okay.
THE COURT: I looked at it yesterday. My intention
in regards to that is there are some statements in there where
it's just the agents talking. And then there's no follow-up
question such that what they say to the defendant might be
relevant to the defendant's response.
So, for example, there's a point where they want the
defendant to open up the garage door so that they can I think
seize a car or something.
MS. CONNORS: Um-hmm.
THE COURT: And they're explaining to him that if
they don't, they'll go get a warrant or something to that
effect.
And they say something to the defendant and he
answers in a fairly nonresponsive way. And then there's about
a page of the agents explaining to him what's going to happen
and what they're going to do. And then they say something, so
I just want to tell you whether you consent to us opening the
door. And he says I do.
And so none of that seems relevant, right?
None of that stuff about what they say to him -- it's
not like they -- their other context where they say to him,
look, don't lie to us. We have a lot of information. We know
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you didn't buy this with your own funds, don't tell us that
you did. And then his response is well, no, but I did.
That seems to me to be the context of the defendant's
statement, they're confronting him with the strength of their
case and they are -- and then he is still pushing ahead with
his insistence. And that would seem to be contextually
relevant to what's being said, such that it is not hearsay.
The other ones where it's just sort of like they're
saying something really strong to him and then there's no
follow-up question whatsoever, that does not seem to me to be
admissible for a couple of reasons.
First of all, it is not putting that type of hearsay
into any context for the jury to evaluate his response.
And, secondly, there's a lot of stuff that the agents
say in there about their case, which might be prejudicial to
the jury or to the defendant in front of the jury, so that's
sort of where I have in my mind tried to divide up what can
come in and what can't.
We will talk about it at the end of the day
specifically so that you-all can be thinking about it ahead of
time.
Okay?
You didn't give me any citations to authority or
anything like that. If you have authority that you want me to
look at, send it to me today and I'll look at it at one of the
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breaks. But my plan would be at the end of the day to go
through -- I've already done it, but we'll just talk about the
different provisions.
Okay?
Does that make sense to everybody?
MR. FINLAYSON: Yes, sir.
MS. CONNORS: Yes, sir.
THE COURT: So if both of you have some type of
authority, today would be the day to give it to me before our
afternoon break.
Okay?
All right. Anything else y'all want to talk about?
MS. CONNORS: Yes, Your Honor.
I did hand up, and I believe you probably have it on
the bench, we had talked yesterday about a 404(b) instruction
at the point where we would be discussing the acquisition of
the two Social Security numbers, so we did modify the standard
cautionary instruction from the Eleventh Circuit pattern.
Defense counsel has reviewed and agrees that this
would be an appropriate instruction to give. I think
essentially all that really is different from the pattern is
the first sentence, because the typical pattern instruction is
talking about other offenses and so this is more specific to
say that they're going to hear evidence about acquiring the
two Social Security numbers.
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Also, the pattern was changed, the pattern is usually
given after the testimony, so it's phrased that way; however,
here, we had asked to be able to get to the point in the
agent's testimony, give the instruction at that point before
he starts going into that area.
THE COURT: Okay.
MS. CONNORS: And if the Court needs another copy, I
do have it.
THE COURT: I don't.
MS. CONNORS: Okay.
THE COURT: I'm looking for my pattern instruction
book, but I never, ever, ever seem to be able to find it.
It's like looking for a screwdriver at my house that my kids
always put somewhere else. I just don't know who to blame in
this instance. I want to just look at the pattern.
Do you agree with this instruction?
MR. FINLAYSON: Well, it's the lesser of evils,
Your Honor.
THE COURT: Right.
MR. FINLAYSON: Obviously, I'd objected to the
evidence, but I think if the evidence is coming, I think I'd
be remiss not to ask for the instruction, so if that -- that's
a half-hearted yes, I guess.
THE COURT: Okay. You just -- you'll tell me when to
give it?
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MS. CONNORS: Yes, Your Honor, I'll stop at that
point --
THE COURT: And just say, Judge, this is --
MR. FINLAYSON: -- during the direct examination and
ask the Court to do the instruction.
THE COURT: Okay. All right. And what about
stipulations, I got some stipulations yesterday.
Do you want to read those to the jury or do you want
me to read them to the jury?
I would prefer you to read them to the jury when the
right time approaches.
MS. CONNORS: Yes, Your Honor. I think that was
going to be our plan. The Court may have noticed essentially
the numbered items one and two would deal with kind of more
the -- any element of an offense or at least touching on an
element of the offense.
Paragraph 3 is really just covering all of the
business records and certified public records so that we can
dispense with any kind of custodian. So as we're doing our
presentation, before moving to admit any of those, we'll
remind the Court that that's subject to our stipulation.
THE COURT: Okay. Well, hold on. You're going to
let me know and then you're going to explain it to the jury or
are you just talking about -- let me --
MS. CONNORS: Just in regards to the business
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records.
THE COURT: Okay. Fair enough.
MS. CONNORS: Yes, Your Honor.
THE COURT: Got it. Okay.
MR. FINLAYSON: And, Your Honor, just to be clear,
the stipulation is to the authenticity of the documents, not
necessarily to the admissibility.
THE COURT: Do you have an objection to the
admissibility of the documents? You'll make that if you have
it at the time?
MR. FINLAYSON: I will, yes.
And, Your Honor, as long as we're talking about that
sort of thing, and I know we're going to talk about the
statement coming in tomorrow, but I have a -- I know most
judges don't like a rambling speaking objection about, you
know, why something should be suppressed, and I don't intend
to make those.
THE COURT: It's not just judges, it's just the law.
MR. FINLAYSON: That, too. Well, and so along those
lines, you know, in my line of work, we're always worried
about waiver at the Eleventh Circuit, so I always feel the
need to renew and preserve objections from things that happen
below.
I tend to use a code phrase that I hope is
acceptable. I go -- you know, I will say something like,
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Your Honor, we renew our objections on the motion to suppress
from below. Or we renew our objection to the statement as
ruled upon -- something -- just when I say below, I'm
referring to the magistrate ruling that we've already
litigated, so -- and I hope -- that's what I'm talking about
when I say that.
THE COURT: That's fine.
MR. FINLAYSON: Thank you.
THE COURT: If it's something different, you've got
to let me know, right?
MR. FINLAYSON: Yes.
THE COURT: And I'm pretty good with the rules of
evidence, so if you give me one sentence, that's probably
enough. If need be, I'll excuse the jury.
I don't like talking up here with the white noise on,
I find that uncomfortable and just sort of awkward, so I -- I
mean, and they're all able to walk around pretty easily, so
I'm just going to send them out even if it's just for 30 or 45
seconds.
Okay?
MR. FINLAYSON: Okay. And the thing I anticipate
that on the most is the statement, the custodial interview.
THE COURT: Okay.
MR. FINLAYSON: So that's where I think that's going
to happen.
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THE COURT: Okay. So, Ms. Connors, for the
stipulations, you will read one and two at the appropriate
time?
MS. CONNORS: Yes, Your Honor.
THE COURT: Okay. And then I will just ask you at
that point, Mr. Finlayson, to confirm that that is a
stipulation.
MR. FINLAYSON: Yes, sir.
THE COURT: Okay. All right. Everybody get nervous,
the U.S. Attorney I think is about to walk in.
Ms. Kelley, will you check on them?
COURTROOM DEPUTY: On the jury?
THE COURT: Yes. All right. I'm going to step off
for a second. I'm not going to say anything to the jury this
morning, because I don't want to make those two people feel
bad.
I'm going to say something to them this afternoon, at
the end of the day, and ask them if they want to go back to
9:00, rather than 8:30, but we can't wait 20 minutes.
By now, when I was a kid, you'd be waking up in a
tent with no fire going and your father having driven away all
alone at the age of eight. At any rate, okay. We'll be back.
(Whereupon, a recess was taken.)
THE COURT: All right. This has tried my patience
and pushed my anxiety. We are missing one juror still. We
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were missing more, we thought they were -- the other ones were
here. Apparently, we do not know where Mr. Mourad --
Is that the one, Ms. Kelley?
Juror 31, the grocer who's from France, who has a
daughter at Georgia Tech. We cannot find him. He's not
answering. We had thought for a bit that he was close, but
that was a bit of a snafu or misunderstanding from the jury
office, so we don't know where he is.
Any ideas about what to do? I'll wait longer. I'll
continue to push down the anxiety. But we could also move
forward without Mr. Mourad and then go with just one
alternate.
What do y'all want to do?
Do y'all want to talk about it and think about it for
a minute?
MR. FINLAYSON: Yeah. I kind of like him.
THE COURT: What's that?
MR. FINLAYSON: I said I kind of like him.
THE COURT: Well, do you want to give him another 20
minutes?
MR. FINLAYSON: Let's give him 15 minutes.
THE COURT: All right. We'll give him 15 minutes. I
intend to write a strongly worded letter or -- I'm not going
to say anything if he does show up this morning. I'm going to
say something at the end of the day. But I am very
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frustrated.
Okay?
(Whereupon, there was an off-the-record discussion.)
(Whereupon, a recess was taken.)
THE COURT: Y'all talk about it. We'll spend ten
minutes waiting longer, maybe we'll hear from him, but I don't
know.
MS. CONNORS: Thank you.
MR. FINLAYSON: Thank you, Your Honor.
(Whereupon, a recess was taken.)
THE COURT: All right. Sorry. Tomorrow, well-oiled
machine. All right? Starting tomorrow.
So we have found Mr. Mourad. He went to work today.
He is on his way from work in Sandy Springs. My guess is 25
more minutes.
So what do y'all want to do?
MR. FINLAYSON: I feel like we've waited this long, I
kind of hate to cave now.
MS. CONNORS: The government's preference would be
that we strike him and do an alternate at this point.
THE COURT: I'm inclined to do that, because I'm not
sure how he could have misunderstood the mission. And I worry
about him going forward.
But I'm not going to do that unless the defendant
agrees to that. So we will wait for him to get here.
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Is that what you want to do?
MR. FINLAYSON: We'll wait for him, Judge. Sorry.
THE COURT: Okay. Would you tell the jurors that
we're waiting on one more and we're going to wait. Don't tell
them why we're going to wait, but just tell them that I said
we're going to wait.
Okay?
Is that okay with everybody if he tells them that?
MR. FINLAYSON: That's fine.
MS. CONNORS: Yes, Your Honor.
THE COURT: How late do y'all want to go today?
MR. FINLAYSON: Your pleasure, Your Honor.
THE COURT: I do think -- remember, we have another
juror who starts a new job on Monday.
MS. CONNORS: Yes.
THE COURT: And if she misses that start time, she
misses orientation. And that's not the same as just missing a
day. It's missing a day with her peers to know what she's
supposed to do and sort of get brought into the fold, so I
think we still need to plan on making up the time that we're
missing today, which is really half a day by the time, right?
MS. CONNORS: So is the plan then that we would stay
until 6:30? I feel like maybe --
THE COURT: Yes, maybe starting tomorrow. I guess.
I don't think I can do that to these other jurors, but I may
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tell them that we're going to have longer hours starting
tomorrow.
Okay?
I just don't know what else to do about it.
MS. CONNORS: Your Honor, we can certainly maybe give
an idea when we're getting close to 4:30 and leaving of
approximately where we are in terms of how many witnesses we
have left.
THE COURT: Yes.
MS. CONNORS: I mean, I do think that we're not going
to get to as many witnesses today as we had originally
planned.
We do have a couple of witnesses that have conflicts
tomorrow, so we will get them on the stand so that they can --
but we had, you know, ensured them that they would get on the
stand today, so we definitely want that to happen, so we will
probably have to change up our order significantly because of
the delay, but we're willing to do that. That's fine.
THE COURT: Okay. Well, we will -- if he's not here
by 10 until 11:00, I'm going to just excuse the juror. I
think that's beyond reasonable. I've got to keep this case
moving. But now we're sort of in a hard spot, because we
might wind up losing a juror at the end. I don't know. But I
hate to just have one alternate.
Okay. All right. We'll see you in a little bit.
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MR. FINLAYSON: Thank you, sir.
(Whereupon, a recess was taken.)
COURTROOM DEPUTY: Please be seated.
THE COURT: All right. What do y'all say? Do you
still want me to wait?
MR. FINLAYSON: I guess if there's any update, if we
know anything.
THE COURT: We haven't heard from him. We did call
his employer. His employer knew that he had jury duty today,
but was sort of confused as to why he showed up for work. I
can't offer anything more than that.
What do you-all want to do?
MR. FINLAYSON: But is he here?
THE COURT: No.
MR. FINLAYSON: Well --
MS. CONNORS: The government's position is the same.
We -- he should be excused, we should go ahead, and the first
alternate should come into that place.
MR. FINLAYSON: I think -- I don't have any
additional position. I defer.
THE COURT: Do you still want to wait?
MR. FINLAYSON: I defer to the Court.
THE COURT: Okay.
MR. FINLAYSON: I think we've waited enough,
Your Honor.
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THE COURT: Okay. I agree with you.
I'm going to excuse that juror. I'm going to have
that juror, if they show up, sit here for the day. And then
I'm going to talk to that person. But we've spent enough time
on this person. We need people who are serious and dedicated
to this process. And this person either doesn't have the
inclination or doesn't have the ability to do it.
And this is the epitome, in my mind, of a dollar
waiting on a dime. And we have done it for long enough. And
so we are going to -- we've got to keep moving or we're going
to run into problems with these other jurors.
So let's bring the jury in. And we will keep moving,
which means that one of -- our first alternate will move up
into that position, which I think is Durand maybe, but however
it works out.
All right. Thank you.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. You can be seated.
Let me first start off by apologizing to you-all. We
were all ready to go at 8:30. We have been waiting for one of
you-all. He is supposed to be here. We have been in contact
with him. But we are not going to wait for that person any
longer.
Okay?
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We're going to push on without that person. If you
see him around, do not speak to him. Treat him as if he is no
longer a part of your jury, because he is not a part of your
jury any longer.
Okay?
So if you see him in the courthouse today, and he
speaks to you, do not speak with him in any way. All right?
Do you understand that?
Anybody have any problems or issues yesterday?
Everybody abide my instructions about not talking to people?
Okay. Very good.
All right. Now I'm going to have you placed under
oath. And this is a different oath from the last one you
took. This is an oath that handles your conduct as the jury
who is trying this case rather than as the possible jurors who
are answering our questions.
So please stand up as Ms. Kelley administers the
oath.
COURTROOM DEPUTY: Please raise your right hand.
(Whereupon, the jury was sworn.)
COURTROOM DEPUTY: Thank you. You may be seated.
THE COURT: Okay. If you did take the oath and you
said I do, then you can be seated. Stand up if you didn't
take it. All right. Everybody has been sworn.
Now that you have done that, by your verdict, you
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will decide the disputed issues of fact in this case. I am
going to begin by explaining some basic principles about a
criminal trial and your duty as jurors.
These are just preliminary instructions. I will give
you more detailed instructions particularly about the law at
issue at the end of the trial. It will be your duty to decide
what happened so you can determine whether the defendant is
guilty or not guilty of the crime charged in the indictment.
At the end of the trial, again, I will explain the
law that you must follow in reaching your verdict and you must
follow the law as I explain it to you, even if you don't agree
with it.
You must decide this case only on the evidence
presented in the courtroom. That evidence will come in many
forms. It will primarily consist of testimony from witnesses,
who will be sitting up here, or from exhibits, documents,
maybe videos, things that we will display to you and that you
will hear referred to as exhibits.
I suspect in this case you might hear about the
parties having stipulated to certain facts as being true. You
must treat those stipulated facts as proved in this case. I
will let you know and the parties will let you know when there
are those agreed-upon stipulations that you must accept.
There are generally two kinds of evidence, there is
direct and there is circumstantial evidence. Direct evidence
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is direct proof of a fact, like testimony from an eyewitness,
so if somebody told you that they saw your neighbor out
fishing in the creek, that would be direct evidence that your
neighbor was out fishing.
Okay?
That's direct, eyewitness testimony.
There's also something called circumstantial
evidence. Circumstantial evidence is evidence of facts from
which you can infer or conclude other facts.
So if instead of somebody seeing your neighbor
fishing down at the creek they saw your neighbor walking up
from the creek holding a fishing pole and a couple of fish on
a stringer, that would be circumstantial evidence from which
you could conclude that your neighbor had been fishing.
Do y'all understand the difference between direct and
circumstantial evidence?
Great.
Now let me tell you this, that as far as the law is
concerned, it makes no difference whether evidence is direct
or evidence is circumstantial. You may choose to believe or
disbelieve either kind of evidence. Your job is to give each
piece of evidence whatever weight you think it deserves.
I'll give you more instructions about that at the end
of the case, but I want you to know from the outset that you
can consider both kinds of evidence.
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Let's talk about what is not evidence.
Okay?
You will hear some things in the courtroom that are
not evidence and that you cannot consider as evidence. First
of all, the lawyers' statements, in their opening statements
to you or their closing arguments to you are not evidence.
They will have an opportunity to discuss the case with you,
and their remarks can help you understand the case, understand
their theory, understand how they want you to view the case,
but their remarks themselves are not evidence and shouldn't
play a role of evidence in your deliberation.
Second, the lawyer's questions are not evidence. The
question is just what the lawyer wants to ask. The evidence
is what the witness says in response to that question. Don't
decide something is true just because a lawyer's question
suggests that it's true. Wait to hear what the answer is
because that's the evidence.
Okay?
I might point this out to you from time to time and
I'll remind you of what I've said, that questions are not
evidence.
For example, somebody says something like you saw
Mr. Smith run the light, didn't you? Is that evidence that
Mr. Smith ran the light? No. The witness might say yes, I
did or the witness might say no, I didn't, and that would be
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the evidence in the case, the answer.
Okay?
You might also hear lawyers object from time to time,
they'll say, Judge, I object to that. I want to explain that
a little bit to you. There are rules of evidence about what
can come in or what can't come in or how it can come in.
When a lawyer thinks that a question is
inappropriate, the lawyer may object to that. And when the
lawyer objects to it.
I'm guessing he's here. Well, he's just going to
have to sit back there.
Okay?
You can tell him we've moved on and we'll talk to him
in a minute.
Okay?
I saw one court security officer motion to the other
court security officer and I saw a couple of y'all see it, so
I just wanted to address it.
All right?
Let me go back. Lawyers might object to things and I
will then have to rule on that objection.
Okay?
I'll have to decide whether the question is
appropriate, whether the testimony can come in, or whether an
exhibit can be admitted.
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Okay?
If I overrule the objection, that means the witness
can answer or the document can come in and you can consider
it.
If I sustain the objection, then you will not be able
to hear that answer or see that document. I will not be
admitting it at least at that time.
Okay?
When I do that, when I sustain an objection, you must
ignore the question and not guess what the answer might have
been.
Okay?
If I sustain something, that means it's not something
at that point that you can consider.
Okay?
Sometimes I will strike evidence. If there is a
question that's asked and then the answer comes out before an
objection or the answer is something that wasn't anticipated
and then there is an objection, I'll tell you to strike it. I
will strike it and I'll tell you to disregard it, so you've
got to push that over to the side of your brain and not
consider it.
Okay?
I will be real clear about that as we go forward.
Okay?
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I may allow some evidence for only a limited purpose.
When I do that, I will give you an instruction as to how you
can consider the evidence only for one purpose and you have to
abide that instruction.
Okay?
I'll be -- and again, I'll try to be as clear as I
can. And of course you might hear things outside the
courtroom, you can't consider that.
Okay?
That shouldn't happen, but sometimes mistakes are
made and you can't consider that in any way.
Okay?
All right. It will be up to you to decide which
witnesses to believe, which witnesses not to believe, and how
much of any witness's testimony you should accept or you
should reject. To decide whether you believe any witness, I
suggest that you ask yourself a couple of questions. These
are kind of common sense, but think about what they are.
First, did the witness impress you as someone who was
telling the truth?
Did the witness have any particular reason not to
tell the truth?
Did the witness have a personal interest in the
outcome of the case?
Did the witness have a bias or a prejudice?
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Did the witness seem to have a good memory?
Did the witness have the opportunity to see or hear
the things about which he or she testifies?
Did the witness appear to understand the question
clearly and answer it directly?
Did the witness's testimony differ from other
testimony or other evidence?
And of course the witness's demeanor while they were
testifying, how did they seem?
And you can consider any other facts you might hear
about that witness's credibility. At the end of the day, I'll
kind of go over these again with you and might add some
additional things for your consideration.
All right?
I've told you that is a criminal case. I've told you
a little bit what it's about, none of that counts as evidence.
You'll hear more about it in just a minute, but I want to give
you some rules that apply in a criminal case.
First, as I told you before, really important, the
defendant is presumed innocent of the charges in this case
until proven guilty.
The indictment against the defendant brought by the
government is only an accusation, nothing more. It is not
proof of guilt or anything else. The defendant starts this
case with a clean slate.
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Second, the burden of proof is on the government
until the very end of this case, they have the only burden of
proof in this case. The defendant has no burden whatsoever to
prove his innocence or to present any evidence or to testify
at all.
Since the defendant has a right to remain silent, the
law prohibits you from arriving at your verdict by considering
whether he does or does not testify -- or that he does not
testify.
Okay?
Let me say that again. You cannot put any weight on
a defendant's choice not to testify. It's not evidence. He
starts with a clean slate.
As I said, the government must prove the defendant's
guilt beyond a reasonable doubt. I will give you more
instruction on that point at the end, but keep in mind that
this is a criminal case, it's different from any civil case,
including because the burden of proof is higher in a criminal
case.
The United States, as I've said, has the burden of
proving the defendant's guilt beyond a reasonable doubt.
Let's talk a little bit about your conduct as a jury, as
jurors. I've gone over this a little bit with you yesterday.
First of all, don't discuss this case with anyone or
let anyone discuss it with you until I tell you to begin
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deliberating. Until you retire and you have that instruction,
you simply cannot talk about this case, even amongst each
other. Don't go back in the jury room at a break and talk
about what you think you heard or anything like that. You
cannot talk about this case until you hear everything.
Okay?
You have to keep an open mind until you've heard all
of the evidence, gotten my instructions on the law, and heard
the parties' closings arguments, only then will I tell you
very clearly now is the time to talk about this case with each
other.
Don't read or listen to anything touching on this
case. I don't think there will be, but should that happen,
don't read it, don't look at it, don't listen to it. If
anyone approaches you and wants to ask you anything about this
case or talk to you about this case in any way, walk away from
them quickly and come tell me.
Okay?
Don't do any research or make any investigation. I
told you that last night. Don't Google stuff or look things
up or ask somebody, anything like that. Don't get anything
from the news. We will be here to give you the information
you need, the parties, the evidence and me the law.
Okay?
Do y'all have your cellphones with you? Are they in
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the jury room?
Okay. We used to take them from everybody, they had
to lock them up downstairs so now you get to keep them while
you're in there.
Okay?
And so you can look at them, but don't look at them
to look things up, do any of that kind of stuff.
Okay?
I don't know how to impress that upon you more, but
it will ruin the whole thing if you look at that, if you look
at a dictionary or anything like that. Don't search out any
information in any way.
Do you think you can post anything about this case?
Can you go on Instagram? No. Definitely not, right? This is
way more serious than that.
Okay?
So don't do anything like that for a number of
reasons. First of all, it's just not appropriate, it's
disrespectful. And of course somebody will comment and now
you're starting a conversation with somebody, so I don't want
to see posts from back in my jury room or anything like that.
Okay?
All right. Exhibits that are admitted will be
available to you. We'll collect them down here somewhere and
you'll have them here either in notebooks at the end of the
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day, you'll get to take them back to the jury room, you'll
have them to look through. We will display them to you during
the course of the trial. If there's something that you want
to read in them, you'll have a chance.
If you want a second longer during the trial or a
couple of seconds to make sure that you read it, just raise
your hand and say, Judge, I'm not ready to move on. But know
they'll all go back there with you, so you'll have a chance to
see them, they will be up on the screens and things like that
now, but you'll have a chance to touch them and everything
like that later. If there's recordings or things of that
nature, they'll be back there for you to listen to again.
Okay?
But again, if you have trouble seeing it or you need
a couple more minutes or so to look at it, don't hesitate to
tell me while we're going through it.
Okay?
Transcripts, Ms. Colter takes down everything that's
said.
Okay.
None of that will be available to you.
Okay?
She's doing that for me, she's doing that for
purposes of making a record. But those transcripts will not
be available to the jury.
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Okay?
You-all have notebooks. Everybody have a notebook?
And a pencil? You can take notes if you want to.
Okay?
You don't have to. Each of you can decide what you
want to do. Don't worry about what your neighbor does, make
that decision yourself. If you decide to take notes, a lot of
people do, but if you decide to, don't become so distracted by
your notes that you're not paying attention to what's going
on.
Right?
One of the things I told you about is maybe think
about the witness's demeanor, but if you have your head down
and you're writing everything, not only might you miss
something, but you might miss their demeanor.
Okay?
So don't get so caught up in it that you forget to
pay attention to what's going on.
And your notes should only be used as an aid to your
memory. I'll talk to you about this again.
Okay?
But if you get back there in the end and you have
something that you recall but you wrote something different,
go with your memory.
All right?
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And don't -- if you don't take notes, don't be
influenced unnecessarily by somebody else's notes.
Okay?
Your memory is just as good as what somebody else
wrote down. And notes are not entitled to any greater weight
than the recollection or impression that each of you has about
the testimony or the evidence.
Okay?
Any questions about that?
Keep an open mind throughout the trial.
Okay?
You're going to get a little bit from one witness, a
little bit from another witness, something might not be clear
to you and maybe it will be cleared up later. You might think
you have heard everything, but then another witness will come
in and tell you something you didn't know. So what you have
to do is you have to keep an open mind and not reach any
judgment, even in your own head, until you've heard all of the
testimony, all of my instructions, and the parties' arguments.
Okay?
I may from time to time either ask the lawyers to
come up here so we can talk about something out of your
earshot or I might just ask you to step in the back for a
couple of minutes. We do that so that we can make sure that
you're hearing what you're supposed to be hearing. And I may
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need a couple more minutes to talk with them about something.
Okay?
Don't worry about what we're talking about, don't try
to guess what we're talking about. Don't try to read our lips
or read my face or anything like that.
Okay?
It's just not part of evidence.
All right. Last thing I want to talk to you about
the order of the trial.
Here's how it goes. In just a moment, I'm going to
allow both parties a chance to give what's called their
opening statements to you.
Okay?
Then the government will get a chance to present its
case, what we call their case-in-chief, remember, they have
the burden, so they present their case-in-chief. When they
finish, they will announce that they are resting their case.
At that point, the defendant can, if he wants to, present
witnesses or other evidence, not required to, but he can.
And then the United States may cross-examine those
witnesses. After that, with certain limitations, the
government can call additional witnesses in what we call the
rebuttal phase of the case.
All right?
So the government goes first in their case-in-chief.
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Then the defendant goes, if they want to. And then if the
defendant has done that, then the government may have a chance
to put on a rebuttal case.
All right?
They begin the case and they have the rebuttal
opportunity, because, as I told you, they have the burden of
proof in this case.
Again, I'll talk to you more about what beyond a
reasonable doubt means, but that's their burden.
When all of that is done, I'll give you some more
instructions about the law to apply in this case. And then
the parties will have a chance to do their closing arguments.
Okay?
Any questions about that process?
All right. We are now going to begin with opening
statements by the lawyers for both sides. It is their chance
to make statements to explain the issues that they expect this
case to present, the facts or the evidence that they expect to
provide to you. The statements they make now are not
evidence, right, it is not part of the evidence in this case.
I've already gone over that with you.
But these are important statements because they're
intended to help you understand the issues and the evidence
that they will present, as well as what their respective
positions are. So please pay close attention. These are
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important parts of the trial, even if they don't have the role
of evidence.
Okay?
And we're going to go -- I don't know how long it is
going to take, but we're going to go probably until they're
done or 12:30-ish? If we go much after that, then we run into
the chance of y'all not getting to eat. And I'm definitely
going to eat because I brought my food in, so we're going to
go a little bit and try to catch up on the time we missed this
morning.
Okay?
Everybody feeling good?
All right. I will now ask the United States if they
want to give their opening statement.
MR. EVERT: Yes, Your Honor. Thank you.
THE COURT: Do you -- are you using the ELMO in any
way?
MR. EVERT: We have a PowerPoint, so if we could
switch to the PowerPoint.
THE COURT: Do you want that to stay where it is or
do you want that moved?
MR. EVERT: I think they can see it on their screens,
so...
THE COURT: Can everybody see a screen well enough?
All right. Thank you, sir.
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MR. EVERT: Good morning. This is a case about a man
who got his hands on millions of dollars that he had no right
to. The defendant, Karl Delano, formerly known as Carl
Torjagbo got over $12 million through two fraudulent schemes.
The first was a PPP fraud scheme where he got a
$9.5 million loan on behalf of his made-up mining company.
The second was a fraudulent tax scheme, where he
submitted two bogus tax returns falsely claiming that he was
entitled to a refund of over $3 million on each return.
And what did he do once he got his hands on over
$12 million? He spent lavishly, buying a big house, fancy
cars and putting the down payment on a yacht.
First, I want to tell you about the PPP fraud scheme,
which is the basis of the bank fraud charge. During the
COVID-19 pandemic, with everything shutting down, there was a
serious concern that small businesses would fail and their
employees would have to go without their paychecks and be
unable to make ends meet.
In order to stop this crisis from happening, the
government created the Paycheck Protection Program or PPP.
Under this program, small businesses could apply to banks for
loans. The banks would get the money out as quickly as
possible to the small businesses and the government would
guarantee the loans, meaning that if the small businesses were
unable to pay the banks back, the government would step in and
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make those payments to the banks.
The evidence will show that Karl Delano took
advantage of the PPP, not because he had a small business that
needed to be kept afloat, but because of greed.
You'll hear how the defendant manipulated the
requirements of the PPP to get what he wanted, which was over
$9.5 million. You'll hear that the sizeable loan that a small
business was entitled to get was based on its monthly payroll.
Specifically, a small business could get a loan for 2.5 times
its monthly payroll. But you'll hear that there were
requirements that a small business had to meet in order to be
eligible for a PPP loan. Specifically, the business had to
have been in operation as of February 15th of 2020. The
business's employees had to reside in the United States. The
loan had to be necessary to support the ongoing operations of
the business. And the loan had to be used for authorized
purchases, such as retaining employees and maintaining
payroll.
The defendant wasn't eligible for a PPP loan because
he did not have a small business that met these requirements.
Undeterred, he created a fake mining company called
Kremkov Industries and applied for a $9.5 million loan on its
behalf. You're going to see the application he submitted and
it is full of false information.
He claimed that his business had been in operation --
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had been in operation since 2014. That was false. The
evidence will show that he didn't even register
Kremkov Industries until January 2021, just one month before
he applied for the PPP loan and almost a year after the
February 15th, 2020 eligibility cutoff date.
He said that the loan was necessary to support the
ongoing operations of Kremkov Industries. That was false.
The evidence will show that Kremkov Industries had no
operations that would have made it eligible for a PPP loan.
He said that Kremkov Industries had an average
monthly payroll of over $3.8 million and that it had paid its
employees over $45 million in 2020. That was false.
You're going to see the payroll documents that he
submitted to the bank in support of that loan and they were
completely fake and full of false information.
He also claimed that he withheld specific amounts of
federal taxes and Social Security payments on behalf of each
of his 493 employees. That was false. You will hear from
representatives of both the IRS and the Social Security
Administration, which are the agencies to whom those payments
would have went. They will -- and you'll hear that
Kremkov Industries never paid any money to either of those
agencies ever for any employee.
The defendant also claimed that Kremkov Industries
had 493 employees who resided in the United States. That was
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false. The evidence will show that Kremkov Industries had no
employees in the United States. And you're going to see the
list of the employees that the defendant submitted to the bank
in support of his application. Some of those 493 employees
may sound familiar to you, names like Keanu Reeves, Oliver
Twist, Charlie Brown, Bruce Willis, Gene Hackman, John Snow,
and Jason Bourne. The defendant claimed that those people
worked for his mining company.
As a result of this false information, you're going
to hear that the defendant received a $9.5 million loan from
the lending bank. And you'll hear from the bank that they
never would have given him this money if they had known that
the information that he provided in his loan application was
false.
You're also going to hear that the defendant's
fraudulent activity didn't stop there. During the same
timeframe, the defendant used two different Social Security
numbers to submit two fraudulent 2020 income tax returns. The
fraudulent tax returns are the basis for the wire fraud
charges.
In both returns, he claimed that Kremkov Industries,
which he owned, had withheld more than $3 million in taxes
from his pay and that he was entitled to a refund of that
money. Of course this was false. You'll hear from a witness
with the IRS that Kremkov Industries never paid any taxes to
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the IRS, so the defendant was not entitled to a refund of
money that was never paid to the IRS in the first place.
On top of this glaring problem, you will also see
that there is no way that these tax returns, which were both
submitted by the defendant within hours of each other, could
both be true. The defendant submitted both tax returns in his
name but he reported different earnings, losses and
withholdings from his pay. And each return sought a refund of
a different amount. With this different information, there is
no way that these two different returns, both supposedly from
the same person for the same year could possibly have both
been true. It's one guy, two different sets of information.
But you'll hear that one of these tax returns was
actually paid out and resulted in the defendant receiving a
check for more than $3.3 million from the IRS.
Finally, you're going to hear about what the
defendant did with the $12 million that he received from the
PPP fraud and the tax return fraud, and that is going to be
the basis of the money laundering charges.
The evidence will show that on March 29th, 2021, the
$9.5 million from the PPP loan hit the defendant's account.
About three weeks later, in April of 2021, he went under
contract to buy a $1.6 million house in Marietta, Georgia, and
he did this with no mortgage.
Also in April 2021, the $3.3 million from the tax
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return fraud hit his account. Once he had that money, you
will hear that the defendant took steps to hide the fact that
the source of his money was fraud proceeds.
In July of 2021, just four months after the PPP money
hit his account and three months after he got the IRS money,
you'll hear that the defendant filed a petition to legally
change his name from Carl Torjagbo to Karl, with a K, Delano.
The next month, he created a new company called
FlyingJack. The evidence will show that having a new name and
a new company name allowed him to hide that the source of his
money was the crimes he had committed using his old name,
Carl Torjagbo and using his old company name,
Kremkov Industries. He also funneled the money from account
to account in an effort to cover up the paper trail.
You will also hear that over this same time period,
the defendant went on a wild spending spree with the stolen
money. In August of 2021, he bought a Range Rover for over
$90,000 with no auto loan.
In October of 2021, he spent $98,000 to buy land in
Cartersville, Georgia.
In January of 2022, he bought a $120,000 BMW, again
with no auto loan.
In March of 2022, he spent $155,000 to buy more land,
this time in Acworth, Georgia.
Then in April of 2022, he spent $333,000 to buy a
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Lamborghini, again, no auto loan.
And still in April of 2022, he signed a contract to
buy a 72-foot yacht for $510,000, and he put down a $51,000
deposit.
Then during this same time period, he also spent more
than $900,000 to buy a fleet of trucks and trailers.
After hearing all of the evidence about how the
defendant fraudulently obtained and spent millions of dollars,
we're confident that you'll find that the defendant,
Karl Delano, formerly known as Carl Torjagbo is guilty of all
charges beyond a reasonable doubt.
Thank you.
MR. FINLAYSON: Good morning. It is morning, isn't
it?
I'm going to begin on behalf of Mr. Delano and all of
the parties by thanking you for your service here in this
case. It's a very important matter that you're here to listen
to, it's a very important matter that you're here to judge.
It's been said that our juries are all that stands
between tyranny and the innocent. In short, for Karl, you are
the bastion of liberty. It is your job to make sure that the
government does its job. It's your job to make sure they
prove him guilty beyond a reasonable doubt. And if they can't
meet that burden, and when they don't meet that burden, it's
your job and your sacred duty to return a verdict which speaks
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the truth and find him not guilty.
Now, you've heard the government's opening, you've
heard what they say this case is about. I'm going to tell you
what I say this case is about. And this isn't evidence. What
he said isn't evidence. The evidence is going to come from
here (indicating). They've got to prove -- it's a nice story,
it's a nice theory, it sounds impressive, the pictures were
nice, but that's not proof, that's not proof. They've got to
bring proof.
This is a case about Karl Delano, formerly
Carl Torjagbo. And let's address that real quick. The
government said, ooh, four months after he gets this PPP loan,
he changes his name.
First of all, if you're going to change your name
after getting a bunch of stolen money, the evidence would
show, or you would think you wouldn't wait four months. Four
months later, he changes his name from Carl Torjagbo, Carl
Delano Torjagbo, changes his name to Karl Delano. That is not
any kind of massive coverup, that is not a sneaky behind the
back let me go hide the money kind of thing.
This is a man -- and you'll hear about the name
change and why he changed his name. This is a man who never
liked the last name, was made fun of by a teacher when he was
a child by his last name, and a man who always wanted to
change it and he finally did.
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He's an immigrant in a new country where that name is
a hard name. And, yes, he took a more western name, Delano,
his middle name. That is not evidence of a coverup. And
that's sort of the government's whole theory about the money
laundering is that he covered this thing up.
There's a term in the law we hear sometimes called --
there's a phrase, really, open and notorious. And, in fact,
if I was going to tell you there's one thing that you're going
to see in this case, open and notorious are the two words I
want you to remember. Everything Karl did was open and
notorious. He didn't trick anybody. He had no intent, the
evidence will show, no intent to commit fraud, no intent to
launder money.
The government -- he submitted these documents for
the PPP loan, the bank had these documents. He submitted his
tax returns to the IRS, the IRS had the documents. The bank
documents say Charlie Brown, Keanu Reeves, Gene Hackman, rest
his soul, all these names. The bank didn't care. The bank
issued the PPP loan.
Now, you've heard the government say, ooh, he got
$9.5 million and then $6 million here. Let's be real clear.
The PPP loan was $9.5 million. The bank very quickly pulled
back $6 million of that, within the first month. The bank
pulled back $6 million so that 3 and some change came from the
PPP loan, it's not 16 million.
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The tax returns, you're going to hear about the tax
returns, there were two. Karl filed one of those, he did not
file both of those, and open and notorious. He will tell you,
he's going to testify. You're going to hear him explain what
happened. He filed one of those returns.
And the IRS looked at that return and they sent him a
check for the money that was paid in by Kremkov, paid in for
him to get a tax return, open and notorious, everything that
he did in this case was open and notorious, and the evidence
is going to show you that.
Changing his name from Carl Torjagbo to
Karl Delano -- Elon Musk and Google will find you real fast,
it's just -- it was not some kind of scheme to hide the money.
A little bit about Karl. Karl was raised in Ghana.
His father was an officer in the Ghana Navy, his mother taught
chemistry in secondary school, she was an assistant head
mistress.
When Karl was 17, he came to this country on an F-1
Visa. He went to Florida Institute of Technology and he
graduated in December of 2001. He studied aviation management
with a flight option. He wanted to be a pilot because his
uncle was a pilot. He became a pilot. He passed and obtained
his student license, his instrument license, his multi-engine
license and beyond. His senior year, he had an instructor's
license.
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Early in his career, he taught flight lessons at the
Patrick Air Force Base. He flew Cessnas and small planes. He
stuck with it, he worked his way up. His pilot ratings went
up, his training hours went up and up. He eventually was
certified to fly the 737 Max. He went on to fly for SkyWest,
for Mesa Airlines and Flydubai Airlines. And that's Karl in
the cockpit.
Let's talk about Kremkov and Ghana. Kremkov
Industries, Karl founded this company with a partner. The
backstory, the history was Karl's great grandfather, Carl
Hoyle was a tribal chief. And as you may know, Ghana is a
country rich in minerals, rich in gold.
In the '70s tribal leaders issued his great
grandfather leases to two pieces of property for 75 years,
75-year leases with mining rights to two pieces of land in
Ghana. One parcel was in the Ashanti region, the other was in
the western region.
Karl's grandpa died when he was six. Turned out,
what Karl learned later, that when his grandpa, great grandpa
died, he willed these leases and its -- on this land to Karl.
Around 2014, Karl's working as a pilot in Dubai. He meets a
Chinese man named Michael Lee, and after several discussions,
they decide to start this mining company, and
Kremkov Industries was born.
Michael Lee agreed to invest, he paid the
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developmental cost, he paid the labor costs, Karl would
provide access to the land through the leases.
Michael Lee would be repaid for his investment.
Michael Lee invested almost $12 million into
Kremkov Industries. He took multiple -- he was repaid for his
investment with gold from that at $50,000 a year. He got paid
back in about 240 kilos of gold and Karl made out pretty well
as well.
In this type of mining, the type of mining they were
doing in Ghana, it's called galamsey, galamsey. It's a Ghana
word that I'm probably mispronouncing, but it is an artisanal,
small family mining practice that's going on right now in
Ghana. And you're going to hear some about this.
And that practice is it's all done by hand. It's
shovels, wheelbarrows, hands, dig a hole, reinforce it, you go
down in the mine and you carry the dirt out, it's all by hand.
And it requires many, many workers. And you will learn some
of these -- they're small mines, some of them have over a
thousand workers down in the hole, carrying out the dirt,
carrying out the gold.
These mines are -- I call them bootleg mines.
They're completely off the books. They're not regulated or
they're barely regulated. They are not very safe. They are
not environmentally friendly.
And they are -- they're not taxed by the Ghana
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government. They are not preserved or maintained with a great
record system. They are holes in the ground with people
digging dirt, pulling out the gold when they can get it.
And this I'm going to show you, this is demonstrative
evidence, this is not Kremkov, but this is what we're talking
about, this is what they look like. This is not Kremkov, but
this is what they look like.
(Whereupon, the recording was played)
MR. FINLAYSON: PPP loan. Karl applied for a
PPP loan to help keep Kremkov Industries afloat during the
COVID pandemic.
Did he apply for this loan? Yes, he did. Open and
notorious, and you're going to see it. He signed it, he
submitted it. List of names, Charlie Brown, Keanu Reeves, all
of these people went right to the bank. There was no fraud,
there was no secret, there was no -- there was nothing done
bait and switch. He laid it all right out there for the bank.
They gave him the loan. Did he do everything
correctly? Did he do everything perfectly? Probably not.
Because the one thing you're going to learn is when
the mine shuts down, he takes that money and builds a trucking
company in this country. And we'll talk about that in a
minute, but that's -- again, that's not a secret. The FBI
comes out and interviews him, he tells them, yeah, I put the
money from the PPP loan into the trucking company. That's
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what I did.
And the government said, well, you're probably not
supposed to do that. Here's the thing about PPP loans, and
you're going to learn this, the directions are very clear. If
you spend the PPP money on a different business, you've got to
pay it back. You don't get forgiven if you spend it on a
different business. And that's what Karl did, he spent the
PPP money on a different business.
And the evidence is clear as can be, he never asked
for forgiveness. He didn't say, well, you took back
$6 million already, I still owe you $3 million, but I want it
to be forgiven.
No. That $3 million that remained on that PPP loan
became a regular loan that he was obligated and willing and
able to repay. And he told them that, open and notoriously.
You'll hear it, there is a recording with the bank, bank
worker where he's like they pulled back $6 million. He's
talking to them, like, what's going on, why are you doing
this?
And he goes I have a deferral period, a deferral
window before my repayments are due. And if you're going to
hold back the $6 million, I want you to at least put that in
writing to me so when my payments become due, I'm paying the
right amount. And I'm not going to pay on the part that you
pulled back. You'll hear that recording.
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He never says, oh, let me off the hook. He has
never -- he never asked for forgiveness, not once, not once.
The February deadline, and the government has said
there's a deadline of February 15th, 2020, and that you had to
be -- and his words were absolutely right, he said exactly the
true thing, the right thing, had to be in operation before
February 15th, 2020.
Karl and Kremkov were in operation before
February 15th, 2020. Did they have a registration with the
Secretary of State in Georgia before that date? No.
And the government says, well, that's ah-ha, no, no,
it wasn't registered and they're going to put that document
in, that's going to be Document Number 1. You're going to see
that date.
The rules did not require registration with the
Secretary of State before that date, they required your
business is operating before that date. The business went
back to 2014. You're going to hear Karl for Kremkov had a EIN
number, an employment identification number from 2018, 2018,
he's got an EIN number for that company. It's in his name and
he's using it for the company.
But the point is, and we all know that -- we're all
common sense here, you can have a business in this country,
you don't necessarily -- you don't necessarily incorporate
with the Secretary of State until you have to or you want to
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or it becomes the right thing or the most tax efficient thing
to do. And the rules did not require that you be incorporated
as of that date.
And this is the language from the CFR, in fact,
you're eligible if you're an individual who operates under a
sole proprietorship or as an independent contractor if you are
in operation on February 15th, 2020. Karl was in operation on
that date.
I think I've covered the name a little bit already,
but this is -- just so you know, when Karl came to this
country, he was 17 years old, his full name was Carl Delano
Akpene Kqadzo Torjagbo. That's a mouthful, and I'm sorry if I
mispronounced it. It then became shortened to Carl Delano
Torjagbo. And then he finally changed it to Karl Lucius
Delano. That is not somebody that's trying to -- if you are
going to change your name, go be John Snow or go be John
Smith.
If you are trying to hide, if you are trying to be
surreptitious, you change your name, you know, to something
that's not you. If you look at his Instagram, his Facebook,
all of those things, he's been Karl Delano since -- with a
K -- Karl Delano since 2018. Again, they're going to find
you. That's not -- it's not a big secret, let me go and hide
my identity and bury the money, it's just not that kind of
thing.
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I've mentioned you're going to hear the phone call
where he tells the bank representative I'm going to make the
repayments. If you're going to hold back the 6 million, tell
me why and put it in writing so I don't have to make the
payments on that.
Let's talk about the tax returns, Counts Two and
Three. There are two different tax returns you're going to
see. Karl filed one of them, his assistant filed the other
one. Karl did not file two tax returns with two different
birthdays, he did not. And he's going to explain to you how
that happened.
What's interesting is the IRS sends him a big fat
check. And again, he was open and notorious about everything
he did there. And you're going to see a document in this
case, it is going to be -- likely going to be Government's
Exhibit 201A or I will make it Defendant's 1 if it doesn't
come in through them.
And it's a transcript of his Social Security record.
And it's a transcript that's prepared -- I want to say the
date is like 2025 is when they actually printed this thing
out. And it -- it will show Karl's payments for that 2020
return. And it shows the balance that he owes for that 2020
return, and the balance it shows owed is zero.
They sent him almost a $3.4 million check and his
account balance is zero. If he got a fraudulent tax return of
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$3.4 million, his account balance would be negative
$3.4 million.
It gets more interesting. And you see the
withholdings, they're not W-2 withholdings, they're 1099
withholdings, he did not make W-2 withholdings, but you see
the withholdings are credited for that year, $3,459,835. And
you see that in the IRS summary document.
Well, that's fascinating, and what you're going to
see is that's the check that they mailed him. They mailed him
the check and on the return that he filed, they sent him
$3,366,240.76. You're going to see the return that generated
that check.
And what's fascinating is the return amount he
requested on that return is like $3,373,000, and they give him
a return of $3,366,000, they take out $7,200 of that check and
you're going to hear why, because he owed back taxes from the
previous years. He owed $7,000 from some previous years, the
IRS processes this thing, they look at their books, they look
at what he's paid in, they look at what he's requesting for
2020, they said he owes this amount for past years, they
deduct it, they deduct $7,000 from that -- from that tax
return check.
The IRS calculated this correctly. The government is
going to argue to you that he didn't pay any money in, he
wasn't entitled to a dime, it was all fraud. But it didn't
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just come straight through, like maybe, you know, like bam,
bam, bam, you know, computers are running the world. If it
had been the exact amount that was exactly what was requested
on the IRS form, perhaps that would be more consistent, but
the evidence in this case is going to show you that's not what
happened.
He was open and notorious. He requested 3.37, they
gave him 3-point -- they give him 3,366,000, they took $7,000
out of the check for previous year's owed taxes. They looked
at -- they looked at what he paid in, they looked at what he
was requesting and they did the math correctly. That's the
IRS. So this is not fraud. This is the IRS doing the math,
paying him what he was entitled to.
Where did the PPP money go? Well, first of all,
$6.5 million went back to the bank. I don't know if it goes
back to the bank or back to the government, but it comes from
the government, goes to the bank, went to Karl, went back to
the bank, I assume the bank sent it back to the government,
but I don't know that.
The rest went to start FlyingJack Freight and
Logistics, an American-based company. And you're going to
hear about all of these trucks, all of the -- there's two land
purchases he bought for that company. Trucks, tractors,
insurance, registrations, drivers, labor, that's what the PPP
money did.
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And again, they want to say well, the PPP money was
for Kremkov Industries. You're not supposed to spend
Kremkov's money on a trucking company. And you're not. But
if you do, you have to repay it.
If you do it fraudulently, then that's a crime. But
if you do it open and notoriously -- he told everybody what he
was doing. He told everybody, he told the FBI, he told --
you're going to hear from a witness, a Mr. Oppong, a childhood
friend, allegedly, he told him, he said, look, the mine is
shutting down, I'm going to -- I'm putting the money into
FlyingJack, the trucking company. He told everybody what he
was doing. And the bank records are clear as day, it is clear
as day what he was doing. He took the PPP money and he put it
into a trucking company.
There are trucks, logos, you'll see it, you'll see it
all. He bought land, he paid drivers. He never asked for
forgiveness, he never intended to defraud anybody.
All right. The money laundering counts, and he's
charged with two kinds of money laundering, the first kind of
money laundering he's charged with, counts are called
concealment money laundering counts. And that's where you
like doing sneaky stuff to try to conceal that you got illegal
money. And you see it in drug cases, you see it in all kinds
of cases where you're trying to hide the nature of the illegal
activity, you're trying to conceal it.
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Karl didn't conceal anything in this case. It's
clear as day, it's bank -- it is a paper trail a mile long,
bank account to bank account. PPP to Chase, to the next bank
account to Kremkov or to Chase to the freight company, to the
trucks. Did he buy these things they're talking about? He
bought every one of them. Absolutely, open and notorious,
no -- nothing sneaky or hidy about it.
You know, the cars were at his house, like one was at
a dealership, he didn't -- Carl Delano, Karl Delano, okay,
maybe that's the big sneaky part, but he didn't do -- he did
this stuff wide open.
And what you'll see when you'll see where this money
comes from, it's 3 million from PPP and that went to the
trucking company. 3.36 from the tax return and his other
money went to buy the house, the cars, the toys, all the stuff
that they say is all this ill-gotten wealth. The wealth was
not ill-gotten. The wealth came from his tax return. And the
wealth came from some money he had before, he didn't have a
lot of money before, but he was a pilot, remember that, he was
a pilot. He flew 737s, he had some money before.
He gets a tax return, buys the toys, he's not
spending PPP money on the toys. And that's what that --
that's their theory, is he spent PPP money -- PPP money on the
toys. The evidence doesn't show that. He bought the toys,
absolutely. He bought them in his name. He was not hiding
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anything, he's not concealing anything.
The transactional money laundering, that's saying,
well, you're buying stuff that costs over $10,000 with funds
from unlawful activity. And he did not do -- did he buy
things over $10,000? Yes, absolutely, open and notorious in
his name.
Did he buy the toys? Sure, he did. But he did not
buy them with unlawfully gotten funds. And that's what
they've got to prove here.
The evidence will show Karl did not commit PPP loan
fraud nor did he knowingly or intentionally commit wire fraud
upon the IRS.
He did not launder money to conceal its source.
Again, there's a paper trail a mile long, everything is in his
name, Karl Delano -- Carl Torjagbo, Karl Delano. He didn't
conceal anything. His purchases and transactions did not make
use of funds derived from unlawful activity.
And you've heard the Judge talk to you a little about
the burden, and you're going to hear more about it. You're
going to hear more about it during the case and at closing
argument.
The government has got to prove this stuff to you
beyond a reasonable doubt. That is the highest standard we
have in our legal system. Karl doesn't have to prove to you
that Kremkov existed. Karl doesn't have to prove to you that
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he had 493 workers.
And by the way, let me clarify something about those
workers, those workers did not have to live in the
United States. Those workers had to have their legal
residence in the United States. He believed and he understood
that he had workers in that mine that were expats working in
Ghana. They did not have to live here. So he didn't have to
like try to pull a fraud with that.
But he doesn't have to prove any of that to y'all.
The government's got to prove to you those 493 workers didn't
exist. And truthfully, that's -- they have to prove the
company and the payroll didn't exist. 493 is not a magic
number, by any means, you'll learn this. It's the amount of
payroll that's important. And again, Karl did not
fraudulently intend to do anything here. He submitted the
documents plain as day.
You're going to learn when you hear about proof
beyond a reasonable doubt, it's a level of certainty -- proof
beyond a reasonable doubt is proof to such a level of
certainty that you would be willing to rely upon it in your
everyday affairs, in your most important everyday affairs.
And when the government can't give you that proof and
that certainty in that case, you are going to come out here
with doubt. And when we're done with all of this, I'm going
to come back to you and I'm going to ask you to return a
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verdict which speaks the truth. And that verdict that speaks
the truth will be not guilty.
Thank you.
THE COURT: Okay. Call your first witness, please.
MS. CONNORS: Your Honor, the United States calls
Special Agent Tyson Fowler.
- - -
TYSON FOWLER,
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: Sure. My name is Tyson Fowler, and
it's T-Y-S-O-N, F-O-W-L-E-R.
COURTROOM DEPUTY: Thank you.
DIRECT EXAMINATION
BY MS. CONNORS:
Q.
Agent Fowler, can you please tell the jury where you
currently work?
A.
I currently work for the Social Security Administration,
Office of the Inspector General.
Q.
And do you have other law enforcement experience?
A.
I do. This is my 21st year in law enforcement. Prior to
the SSA OIG, I worked for the FBI for 12 years as a special
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agent.
Q.
And what's your educational background?
A.
I have two bachelor's degrees from the University of
Central Florida. And then I also have multiple cyber
certifications and an anti-money laundering certification.
Q.
And as part of your employment with Social Security OIG
and FBI, did you have to go through any kind of specialized
training?
A.
Yes.
Q.
And what was that?
A.
With the FBI, I was a cyber agent. And basically my role
was anything that was criminally motivated cyber intrusions,
which dealt with fraud via computers, so account takeovers,
ransomware, things like that, I had specialized training, like
I said, I hold six different cyber certifications, including
forensics and a number of others, and then I have an
anti-money laundering certification and also now 21 years of
experience.
Q.
And what are some of your duties as a special agent with
the Social Security Administration?
A.
So the Office of Inspector General is tasked with waste,
fraud and abuse with the Social Security Administration. That
can include any material misrepresentations to the
Social Security Administration or anything that would involve
reputational harm or false reporting to the Social Security
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Administration.
Q.
Agent Fowler, are you one of the case agents related to
this investigation?
A.
I am not.
Q.
What role did you have in this investigation?
A.
I received an allegation of potential material
misrepresentation to the Social Security Administration and I
conducted my own logical investigation based on the data I
received.
Q.
Okay. And did you -- as an agent with the Social Security
Administration, do you have access to Social Security systems
that may maintain data related to Social Security numbers?
A.
I do. I have access to the entire history of
Social Security Administration's data from the creation of it
to current.
Q.
And in terms of the information that the Social Security
Administration keeps or keeps a record of, would that include
things like wages and earnings that are reported for
individuals?
A.
Yes, it does.
Q.
Does it include as well things like Social Security taxes,
Medicare taxes that may be paid?
A.
That's correct.
Q.
And why is it that the Social Security Administration
keeps track of Social Security tax, Medicare tax and wages and
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earnings of individuals?
A.
So that they can properly calculate your retirement
benefit when you reach that age. So every American citizen is
probably familiar with it, but when you work in a W-2 or an
environment where you have a job and you get a paycheck, taxes
are automatically taken out and those calculations go into
your retirement -- retirement benefit later in life, or if you
needed disability benefits, should you need to.
Q.
And in terms of those taxes, essentially is that then sort
of like the money you get back in terms of those benefits
later on?
A.
Yes. It calculates your qualification for how much you
would get back in retirement per your Social Security benefit.
Q.
And how does the Social Security Administration typically
receive that type of information, information about wages and
earnings of individuals and any kind of tax withholdings?
A.
So for the majority of citizens, your employer takes care
of that. Your employer, when they issue your W-2, that gets
reported to the Social Security Administration, and then it
goes to the IRS.
In cases where you are a business owner, you have a
responsibility to either do it through your tax preparer or
through what's called Business Services Online, which is an
account you would create with the Social Security
Administration. And you would file employee data through that
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database before you file or as you file your W-3 or W-2
tax-related data for your employees.
Q.
So essentially does it end up that there are times where
potentially IRS and Social Security are both accessing the
same data through W-2s, W-3s, W-4s?
A.
That's correct.
Q.
As part of your involvement in this case specifically, did
you search for Social Security records related to
Kremkov Industries?
A.
Yes, I did.
Q.
Was Kremkov Industries registered in the State of Georgia?
A.
Not with the Social Security Administration.
Q.
So in terms of your experience as a special agent, are you
aware that some companies can register with the Secretary of
State?
A.
Yes.
Q.
And if you would look in that binder, there should be an
Exhibit 1 in there. If you will take a look at that document.
A.
Yes.
Q.
And what is that document?
A.
That is a State of Georgia from the Secretary of State
Corporation Division and it's the registration of
Kremkov Industries.
MS. CONNORS: And, Your Honor, we do have a
stipulation as to authenticity of that record. And I move to
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admit.
MR. FINLAYSON: No objection.
THE COURT: Okay. Then Government's Exhibit 1 is
admitted into evidence and you may publish it to the jury.
MS. CONNORS: Thank you, Your Honor.
And if we could please pull up Exhibit 1.
BY MS. CONNORS:
Q.
So before the jury could see this, you indicated some
information, but I want to make sure that they know what we're
looking at.
So for Exhibit 1, is this related to
Kremkov Industries?
A.
Yes, it is.
MS. CONNORS: And if we can go down to Page 2 of this
exhibit.
BY MS. CONNORS:
Q.
And is this the actual certificate that gets issued by the
Secretary of State?
A.
Yes, it is.
Q.
And what is the date identified as when Kremkov Industries
was organized in the State of Georgia?
A.
It was January 11th of 2021 is when there was an official
seal and it was signed. And then -- but it has been duly
organized as of January 4th of 2021.
Q.
And is that something that you've seen before, that the
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certificate is issued at a later date from when there's -- the
information is submitted to the Secretary of State?
A.
Yes.
Q.
Okay.
MS. CONNORS: And if we can go down to Page 3 of that
exhibit.
BY MS. CONNORS:
Q.
And at the top here, is this still related to
Kremkov Industries?
A.
Yes, it is.
Q.
And in -- there's a principal office address, what city is
that address in?
A.
Douglasville, Georgia.
Q.
And is it 3081 Leatherleaf Trail?
A.
Yes, ma'am.
Q.
And then there is a section for organizers. And for the
organizer, who is that?
A.
It says Carl Delano Torjagbo.
Q.
Okay. And, Agent Fowler, if you will look at Exhibit 13,
it's probably in that same binder. And what is -- what is
that exhibit?
A.
It's a petition to change the name of an adult.
Q.
Is it a petition to change Carl Torjagbo's name?
A.
Yes, it is.
MS. CONNORS: Your Honor, this is also a document
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that was subject to our stipulation for authenticity. And I
would move to admit.
MR. FINLAYSON: No objection.
THE COURT: Okay. It is admitted. What's the
exhibit number?
MS. CONNORS: Exhibit 13.
THE COURT: Exhibit 13 is admitted.
MS. CONNORS: Thank you, Your Honor.
And may I publish?
THE COURT: You may. If I admit it, you-all both can
publish it.
MS. CONNORS: Thank you, Your Honor.
THE COURT: Y'all have the controller on that, right?
MS. CONNORS: Yes, Your Honor.
THE COURT: Okay. Thank you.
BY MS. CONNORS:
Q.
Okay. And so, Agent Fowler, what is the -- what's
identified under that Number 1 as essentially the petitioner's
current name?
A.
It says the petitioner's name is Carl Delano Torjagbo.
Q.
And does it have a date of birth identified?
A.
Yes, it says 9/10 of 1979.
Q.
And is there also a city and country of birth?
A.
There is. And it's -- forgive me if I'm pronouncing it
wrong, but Accra, Ghana.
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Q.
And then below that, does it indicate what name
Mr. Torjagbo wants to change his name to?
A.
Yes, to Karl with a K, Lucius Delano.
Q.
Okay. And at the top, was this filed in the Superior
Court of Cobb County?
A.
Yes.
Q.
And I know it might be kind of hard to see, but in the top
right corner, is there a date identified as filed in office?
A.
July 29th of 2021.
Q.
Thank you.
MS. CONNORS: And if we could move to Page 12 of that
exhibit.
BY MS. CONNORS:
Q.
And was the name change granted?
A.
Yes, it was.
Q.
And it's a bit hard to see the handwritten date that's in
the middle for after so ordered, but there's also the date
filed in court in the bottom left. And what is that date?
A.
Forgive me, I can't read the so ordered date, but it says
September of 2021. And then down at the bottom, it says filed
in court, and it says September 17th of 2021.
Q.
Okay. And so would that be the time that then the name
change was granted?
A.
That's correct.
Q.
And so going forward during your testimony, if I refer to
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Karl Delano or Mr. Delano, would you understand that any
documents that are also referencing Karl Delano Torjagbo would
be talking about the same person?
A.
Yes.
Q.
Agent Fowler, are you -- do you have some awareness of the
Paycheck Protection Program?
A.
I do.
Q.
And I know it may not be quite the expertise of
Social Security, but just what's your general understanding of
what that program is for?
A.
My general understanding is during COVID times, it was a
program created to help businesses pay their employees when
the business was tough due to the lockdowns.
Q.
And are you aware that -- of Kremkov Industries, a company
in that name, that you were also looking at Social Security
data for filing for a Paycheck Protection Program loan?
A.
Yes.
Q.
And if you will look at Exhibit 101.
A.
Which? Just regular 101?
Q.
Yes, yes.
A.
Yes, ma'am.
Q.
Is that a copy of the Paycheck Protection Program loan?
A.
Yes, ma'am.
Q.
Okay.
MS. CONNORS: Your Honor, this record is part of
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Chase records that were stipulated to and I would move to
admit.
THE COURT: Any objection?
MR. FINLAYSON: No objection.
THE COURT: All right. 101 is admitted.
MS. CONNORS: Okay. And if we can go ahead and pull
up that exhibit. Thank you.
BY MS. CONNORS:
Q.
Now, Agent Fowler, in terms of the -- this loan document,
is it multiple pages?
A.
Yes, it is.
Q.
Okay. Is there essentially this application to begin with
and then some supporting documentation as well?
A.
Yes.
Q.
Okay. So to go over this particular part of the
application, is Kremkov Industries, LLC, identified as the
business legal name of the company that's requesting this
PPP loan?
A.
Yes, it is.
Q.
And what is the year of establishment for the company
that's near the top right?
A.
In the top right, it says 12/31 of 2014.
Q.
And then do you see where there is a business address?
A.
I do.
Q.
Is that the same Douglasville address that was on the
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Georgia Secretary of State documents?
A.
It is, the Leatherleaf Trail.
Q.
And do you see where there is a primary contact name?
A.
Yes.
Q.
And whose name appears there?
A.
Carl Torjagbo.
Q.
And then at sort of the bottom, if you -- is your screen
on?
A.
It flickers.
Q.
Okay.
A.
So I was reading off the paper.
Q.
So it might be easier. So do you see the section where it
says applicant ownership?
A.
Oh, yes, ma'am.
Q.
Okay. And what name is listed as the owner name?
A.
Carl Torjagbo.
Q.
And what's the title?
A.
Owner and 100 percent ownership.
Q.
Is there any indication in that box that there is a
partner?
A.
No.
Q.
Any indication that anyone else owns any percentage of
Kremkov Industries?
A.
No.
Q.
And then if you can look back towards the -- that top half
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of the page, where it lists a business TIN, EIN or SSN.
A.
Yes.
MS. CONNORS: It's the section above. If you will
zoom out of that. There you go.
Sorry. I wanted to make sure that they can see it on
their screen.
BY MS. CONNORS:
Q.
So there is a business essentially identification. Is
that what that is?
A.
Yes, ma'am.
Q.
So are you familiar with the term EIN?
A.
Yes, I am.
Q.
What is that?
A.
It's an employee identification number. It's used to
identify businesses with the IRS and Social Security
Administration.
Q.
Okay. And in terms of this particular business
identification number, does it end in 7540?
A.
Yes, it does.
Q.
Okay. And I think you probably just answered this, but
just to confirm, just is this one way that Social Security is
tracking any of those wages, records, any kind of
Social Security tax that would be paid, or Medicare tax?
A.
Yes, it is.
Q.
And then if you look across, there is an amount for
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average monthly payroll. And what is that number?
A.
It's $3,821,770.
Q.
And then kind of going across that line to the end, is
there a number of employees listed?
A.
Yes. It says 493.
Q.
And so what was the total amount of the loan request
that's sort of in the middle of that line?
A.
$9,554,425.
Q.
All right.
MS. CONNORS: And we're going to move ahead in that
exhibit to Page 10.
BY MS. CONNORS:
Q.
And, Agent Fowler, before testifying today, have you had
an opportunity to look at the information related to this PPP
application?
A.
Yes, I have.
Q.
And in regards to this particular document, does it
have -- does it indicate that it is a payroll journal detail
report at the top?
A.
Yes, it does.
Q.
And what's the name of the company that this is -- this
payroll relates to?
A.
Kremkov Industries.
Q.
And what is the date range for this particular payroll?
A.
For this page, it's February -- or 2/1 of 2020 to the end
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of February, so it's the month of February for 2020.
Q.
Okay. And is this a document that was -- your
understanding it was provided as a supporting document as a
part of that PPP loan application?
A.
Yes, it was.
Q.
And if you look in the top right corner, does it indicate
this is just Page 1 of this payroll journal detail report?
A.
Yes, Page 1 of 71.
Q.
Now, looking at the payroll, are there columns underneath
each person's name that has a different what appear to be
abbreviations?
A.
Yes.
Q.
Okay. So do you see an abbreviation for, for example, fed
tax, SS tax, med tax?
A.
Yes.
Q.
And is there also an abbreviation, the third from the last
column, of FICA?
A.
Yes, FICA or FICA.
Q.
And in terms of these sort of abbreviations, do you see
that there is a key to explain what those mean?
A.
Oh, yes.
Q.
And so according to these abbreviations, what does SS tax
stand for?
A.
SS tax stands for Social Security tax.
Q.
Would that typically mean tax paid for Social Security
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Administration?
A.
Yes, it would.
Q.
Okay. And in terms of med tax, what does that stand for?
A.
Medicare tax.
Q.
And what's the interplay with Medicare and
Social Security?
A.
Depending on your -- your income levels depend on what you
end up paying for your Medicare premiums when you retire. So
a lot of times it -- they mutually impact each other. Based
on your Social Security premium and your Medicare premium and
also it will fluctuate based on your income, so it has to be
calculated altogether.
Q.
Okay. And so is that why Medicare tax would also be
something that Social Security is keeping a record of?
A.
That's correct, yes.
Q.
And in terms of Social Security tax and Medicare tax,
would this be something that U.S. individuals are paying into
the Social Security system to be able to ultimately get
Social Security retirement and Medicare coverage?
A.
Yes.
Q.
And I think you've already mentioned this to some degree,
but can you explain how it would be that employers may
withhold those taxes or deduct the tax amounts from payroll?
A.
It's by law. But unless you work for an employer that
doesn't collect Social Security tax, and there's very few of
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those, by law, employers have to take out Social Security tax
so that your proper calculations for your retirement are able
to be completed.
Q.
Okay. And in terms of like the W-2s and W-3s and W-4s, is
that how employers would be able to get information about how
much of that tax they're supposed to withhold from the
employee's paycheck?
A.
Yes.
Q.
And again, those are forms that get submitted to
Social Security and also may get submitted to IRS?
A.
Yes.
Q.
And who typically gets them first?
A.
Social Security.
Q.
Okay. All right. And so Agent Fowler, looking at this
particular payroll, in terms of each column, is there a gross
amount and then a net pay amount that you can see?
A.
Yes.
Q.
And is that typically the difference between gross
earnings someone may have and what they would actually get
paid after any kind of tax deductions?
A.
Yes.
Q.
Or maybe potentially some other type of deduction,
insurance, something like that?
A.
Yes, there's a number of things that could be taken out
that would -- your net pay would be what you take home and
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your gross is your -- the whole amount before things are taken
out.
Q.
Okay. And so for this payroll, do you see that there is
kind of like a minus sign or negative sign in front of the
Social Security tax number, the med tax number and some of
these other figures?
A.
Yes.
Q.
Is that indicating that those amounts are being deducted
from the gross pay?
A.
Yes.
Q.
And I think the one acronym we mentioned earlier that we
haven't gone over yet is that FICA.
What exactly -- well, first of all, in terms of the
key at the top of that, is there a description of what the
FICA is?
A.
Yes, there is.
Q.
And what is that?
A.
It says employee's portion or employer's portion of
Social Security and Medicare tax combined, it's a plus.
Q.
Okay. And so how does that work in terms of FICA?
A.
So it's what the employer is responsible for, because your
employer contributes to the tax as well, so employees are
responsible and employers are responsible to pay tax for
your -- ultimately your calculation for Social Security
benefits.
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Q.
Okay. And in terms of FICA, since that's something that
your employer is supposed to be paying for, that would not be
deducted from the employee's pay?
A.
Right.
Q.
Okay. But is that number still something that
Social Security would be keeping track of?
A.
Yes.
Q.
Okay. So if Kremkov Industries was deducting
Social Security tax from its employee's payroll, would the
Social Security Administration be aware of those taxes being
paid?
A.
Yes.
Q.
Would Social Security have a record of those taxes being
paid?
A.
Yes.
Q.
Would that record exist under the EIN for
Kremkov Industries, that employer identification number?
A.
Yes.
Q.
And would that be the same for the Medicare tax?
If Medicare taxes were being withheld from
Kremkov Industries employees, would the Social Security
Administration have a record of that?
A.
Yes.
Q.
And if Kremkov Industries was paying the FICA portion for
any employees, would Social Security have a record of that?
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A.
Yes.
Q.
Okay. And, Agent Fowler, we looked at that first page of
the PPP application a few minutes ago.
Was that an EIN -- was there an EIN on that for 7540?
A.
Yes.
Q.
And in terms of that particular EIN, were you able to
search for any kind of records related to Kremkov Industries
and that EIN through Social Security's system?
A.
Yes, I was.
Q.
And if you will please look at Exhibit 3. Do you
recognize that exhibit?
A.
I do.
Q.
And does it relate to the EIN ending in 7540?
A.
It does. It's a screenshot that I took.
Q.
Okay. And is it something from Social Security's system?
A.
It is.
MS. CONNORS: And, Your Honor, the Social Security
records are part of our stipulation related to authenticity.
And I would move to admit Exhibit 3.
MR. FINLAYSON: No objection.
THE COURT: Okay. Exhibit 3 is admitted.
MS. CONNORS: Thank you, Your Honor. And if we can
go ahead and publish. Thank you.
BY MS. CONNORS:
Q.
Okay. And so, Agent Fowler, can you explain -- you said
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it's a screenshot. Exactly what is this screenshot?
A.
So it looks a little archaic, but this is the system we
use to query EINs. We have the same similar system query SSNs
as well.
And if you look at the top, it says employer
identification number, and then it says EIN, and that's the
EIN ending in 7540.
And then the report period, I can either specify
individual years, in this case I did a range, and I did it
from '14, which is 2014 to 2025, and I submitted that query
for any results that would come up.
Q.
And in regards to that date range starting in 2014, was
that because the PPP application indicated that that was when
Kremkov Industries was established?
A.
Yes.
Q.
And in regards to your search of the EIN ending in 7540,
were there any records?
A.
There were not. You can see at the bottom in red where it
says no records found for specified EIN years.
Q.
And so what does that mean?
A.
It means there was nothing reported to the Social Security
Administration.
Q.
Does that mean that there are no Social Security -- there
was never any Social Security tax information submitted for
employees of this company?
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A.
That's correct.
Q.
Does it mean that there was never any information about
Medicare taxes for any employees of this company?
A.
Yes.
Q.
Does it mean that there were no --
MR. FINLAYSON: Objection, Your Honor. Objection,
we're leading here. Sorry. Does it mean.
MS. CONNORS: I don't think does it mean is a leading
question.
THE COURT: I will overrule the objection. I don't
need y'all going back and forth. I'm just trying to think,
not waiting for more.
I'm going to overrule the objection. Go ahead.
MS. CONNORS: Thank you, Your Honor.
BY MS. CONNORS:
Q.
So if there were any FICA withholdings submitted on behalf
of Kremkov Industries for any employees under this EIN, would
it have returned a record?
A.
It would have, yes.
Q.
And, Agent Fowler, were you also -- did you also query two
other EINs that were related to either Kremkov Industries or
potentially another company name?
A.
Yes.
Q.
Okay. And if you could look at Exhibits 4 and 5, and let
me know if you recognize those.
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A.
Yes.
Q.
And what are those?
A.
Those are screenshots that I took of my query for two
other EINs that I was given as per the allegation.
Q.
Okay.
MS. CONNORS: And, Your Honor, again, the
Social Security records were part of our stipulation related
to authenticity. And I would move to admit Government's
Exhibits 4 and 5.
MR. FINLAYSON: No objection.
THE COURT: Okay. 4 and 5 are admitted.
MS. CONNORS: Okay. And if we could pull up 4.
BY MS. CONNORS:
Q.
And in regards to this query, what's the last four of the
EIN number that was searched?
A.
8332.
Q.
And did you search for the same timeframe for this one?
A.
I did. In the middle you can see where it says '14 to
'25.
Q.
And for this EIN, were any records found in the
Social Security system?
A.
No.
Q.
And so in terms of any kind of tax -- Social Security
taxes, Medicare taxes or FICA?
A.
There was no records found for any of them -- of those.
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Q.
And then if you can --
MS. CONNORS: If we can pull up Exhibit 5.
BY MS. CONNORS:
Q.
And was this a third EIN that was being searched?
A.
Yes, ma'am.
Q.
Okay. And for this EIN, what's the last four numbers?
A.
1377.
Q.
And did you search the same timeframe for this one as
well?
A.
I did.
Q.
And for this EIN, were any records found in
Social Security's systems?
A.
No.
Q.
And again, what would that mean related to this EIN?
A.
No Social Security tax, no W-2 or W-3 was reported at all,
which would include all of those -- those different deductions
and different taxes.
Q.
Okay. And, Agent Fowler, we're going to go back to that
payroll that was on the PPP application in Exhibit 101. And
we're going to -- I'm going to go to -- back to Page 10 that
we were looking at before.
And so I want to go through a few examples from this
payroll. The first individual it looks like the name is Scott
Ackers, I think it's pronounced.
Now, does -- in regards to Scott Ackers, does this
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payroll indicate that Social Security taxes, Medicare taxes
and FICA were paid?
A.
Yes.
Q.
And in regards to the three EINs that you had searched,
did any of those return anything consistent with Social
Security taxes, Medicare taxes and FICA being paid to this
employee of Kremkov Industries?
A.
No.
Q.
And in regards to every employee on this particular page,
does it have a column for every employee listing that
Social Security taxes, Medicare taxes were being withheld and
that FICA was being paid?
A.
Yes, it does.
Q.
And did you see any evidence of tax -- those tax
categories being paid in Social Security's system for any of
the three EINs that you checked?
A.
No.
MS. CONNORS: And if we can move down to Page 11, the
next page.
BY MS. CONNORS:
Q.
Is this page similar?
A.
Yes.
Q.
All right. So do you essentially see the same thing in
terms of the different columns of tax withholdings for
Social Security tax, Medicare tax and FICA?
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A.
Yes.
Q.
And is this information, in terms of those tax
withholdings, consistent with what you searched for for those
three EINs?
A.
No, nothing on this sheet showed up in my records, in my
search.
Q.
Okay. And I'm going to skip ahead a few pages to page 16
of this payroll. And do you see the same thing here?
A.
Yes.
Q.
And in regards to this payroll, the PPP application had
identified that there were 493 employees or said there were
493 employees for Kremkov Industries. Were 493 names
submitted for this payroll?
A.
Yes.
Q.
And for the 493 names, is each one indicating that there
is Social Security tax, Medicare tax and FICA paid?
A.
That's correct.
MS. CONNORS: And if we can go to Page 80 and show
the bottom of this list for payroll.
BY MS. CONNORS:
Q.
Does it have grand totals listed at the bottom?
A.
I'm sorry.
Q.
No, not a problem.
A.
Yes, ma'am.
Q.
And it might be a little hard to see with it zoomed out,
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but is this indicating that there is a grand total for
Social Security taxes?
A.
Yes.
Q.
And I don't know if you can kind of tell on your paper a
little bit better, but in terms of that amount, what was
the -- what was the grand total for the Social Security taxes
paid?
A.
$241,902.91.
Q.
And did you -- when you queried those three EINs, did you
see any -- any record that that amount of money had been paid
to Social Security for Kremkov employees?
A.
No.
Q.
And in terms of these grand totals, is there a total for
Medicare taxes?
A.
Yes.
Q.
And what's that total?
A.
$56,573.27.
Q.
And in regards to the queries that you conducted through
the Social Security system for all three of these EINs, did
you see anything consistent with that amount being paid?
A.
No.
Q.
And then finally, for FICA, is there also a grand total
for that?
A.
Yes.
Q.
And in regards to that grand total, what is the amount?
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A.
$298,476.18.
Q.
And in regards to the queries that you did for the three
different EINs, did you see any evidence of that amount being
paid?
A.
No.
Q.
And in regards to these particular totals here, would this
only relate to the February of 2020 timeframe that was on that
first page of this payroll?
A.
Yes.
MS. CONNORS: Your Honor, I don't know if we were
doing a lunch.
THE COURT: How about lunch? Okay. We're going to
take our lunch break for one hour, a hard one hour.
All right. Don't talk about this case. You don't
know anything other than what you've heard so far. Remember,
I'm going to keep telling you that, don't talk about anything
to do with this case. Talk about other stuff. All right?
Okay. Thank you-all very much. We'll see you in an
hour.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Y'all can be seated.
Okay. Anything to talk about?
MR. FINLAYSON: No, sir.
THE COURT: All right. We'll see you in an hour.
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Thank you.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, a lunch recess was taken.)
THE COURT: Sir, what happened today?
Y'all can be seated.
JUROR: I didn't know actually I was supposed to be
here this morning. It said to call.
THE COURT: But remember when I told you at the end
of the day yesterday, see you at 8:30? Didn't I tell you
that?
JUROR: Can I sit down?
THE COURT: Yes.
JUROR: It's possible you told me but I don't
remember. I'm sorry.
THE COURT: Okay. All right. Well, I don't know
what I can say about it, but you were supposed to be here at
8:30 today. You've put us in a bad spot. We've had to move
on without you. There's a little bit of room for that, but if
you're called again, and you get selected for jury service,
you have to serve.
Do you understand?
JUROR: Yes, I do understand.
THE COURT: If you don't, some judges would send the
marshals to come get you and bring you here in a very unhappy
way.
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Do you understand?
JUROR: Even when they say it's on call?
THE COURT: You're not on call. I told you yesterday
you had been selected.
JUROR: Oh.
THE COURT: I told you that you had been selected.
Remember you sat up in the jury box?
JUROR: Yes, I did.
THE COURT: And I told you that you're now the jury
that's going to serve and that you need to be back here today
at 8:30. Remember, I said it's got to be at 8:30. We're
going to start right at 8:30.
JUROR: Yes, you said that. Yes, I do remember.
THE COURT: All right. Next time that happens, if it
happens to me, I'm going to send the marshals to come get you
and pull you out of your employment or wherever you are.
Do you understand that?
JUROR: I apologize.
THE COURT: Okay. Thank you.
JUROR: Thank you, sir.
THE COURT: All right. Now, you can't -- we have
moved on without you. You've got to go. You're done.
JUROR: Okay. Thank you.
THE COURT: Oh, I'm sorry. I thought you were
bringing them in. I saw you go back there. I'm sorry. I was
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paying attention to something else. It was getting awfully
quiet in here.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. Y'all can be seated.
Everybody okay?
All right. Go ahead, please.
MS. CONNORS: Thank you, Your Honor.
BY MS. CONNORS:
Q.
Agent Fowler, if you will pull Exhibit 101 back up,
Page 80.
MR. EVERT: We need to switch from the ELMO.
MS. CONNORS: Oh, I've gotcha.
BY MS. CONNORS:
Q.
So, Agent Fowler, before the lunch break, we were ending
on going over some of these grand totals on Page 80 of
Exhibit 101.
And I wanted to make sure that we could confirm, in
terms of this document, is this part of the PPP loan
application for Kremkov Industries?
A.
Yes, it is.
Q.
And were there other payroll documents that were also
submitted by Kremkov Industries to support its PPP
application?
A.
Yes, I believe I had the whole year.
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MS. CONNORS: And so, Ms. Wilson, if you could go
down to Page 118, please.
BY MS. CONNORS:
Q.
Agent Fowler, is this one of the documents -- what you
were just referring to?
A.
Yes, ma'am.
Q.
Okay. So this is different than the payroll document that
we just looked at?
A.
Yes. The beginning and end date, you can see the
difference between the document we just looked at and this
document.
Q.
Okay. And I think you already said it, but I just want to
make sure.
A.
I'm sorry.
Q.
-- that the -- that it's clear for the jury. What is the
beginning date and what's the end date for this payroll
document.
A.
It's 1/1 of 2020, the begin date, and the end date is
12 -- or December 31st of 2020.
Q.
And I think it has just a slightly different title of
payroll journal summary report?
A.
Yes, ma'am. It says payroll journal summary report at the
top.
Q.
Okay.
Q.
The company that's identified?
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A.
Kremkov Industries.
Q.
Okay.
MS. CONNORS: And if we can zoom out of that.
BY MS. CONNORS:
Q.
And this document, is it also a number of pages?
A.
Yes, ma'am.
Q.
Okay. And looking at that top right corner, how many
pages total is this payroll journal summary report?
A.
42.
Q.
Okay. Is this the first page of that?
A.
Yes.
Q.
Now, at the top, do you -- do you see a key similar to
what we looked at before?
A.
Yes, I do.
Q.
Okay. In terms of that key, are the column abbreviations,
do they appear the same at least in regards to Social Security
tax, Medicare tax and FICA?
A.
Yes.
Q.
Okay. Okay. And so SS tax, is that still Social Security
tax?
A.
Yes.
Q.
Med tax, is that still Medicare tax?
A.
Yes.
Q.
And then FICA, is that still used?
A.
Yes.
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Q.
Okay. Now, looking at the first individual, we looked at
Scott Ackers, the -- in regards to that February of 2020
payroll.
Here, does -- is this supposed to be listing the
entire year payroll information for Scott Ackers?
A.
That's how I read it, yes.
Q.
Okay. Does it indicate like an hours/maybe quantity, I
guess is what that's supposed to mean, gross, fed tax, SS tax,
et cetera?
A.
Yes.
Q.
Okay. Now, in return -- in regards to Scott Ackers, does
indicate a gross pay of $92,213?
A.
Yes, it does.
Q.
Okay. And then are there amounts identified for
Social Security tax and Medicare tax withholdings?
A.
Yes.
Q.
The Social Security tax, what is that amount?
A.
$5,717.23.
Q.
Okay. And for the Medicare tax, what is that amount?
A.
$1,337.10.
Q.
And finally, for the FICA, what was that amount?
A.
$7,054.33.
Q.
Okay. Now, when you searched by the three EINs, the three
employer identification numbers for companies associated with
the defendant, did you see a record of any of these taxes
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being paid?
A.
No, I didn't.
Q.
Did you see a record of any taxes being paid even for the
entire timeframe that you searched?
A.
No.
Q.
And just to remind the jury, what was that entire
timeframe that you searched?
A.
2014 through 2025.
Q.
So now looking at this page, if you're going down the
column for the individual -- the individual employees that are
listed on this is -- do you basically have Social Security tax
$5,700 or more for everyone?
A.
Yes.
Q.
And for Medicare tax, do you have essentially $1,300 for
everyone?
A.
Yes. Approximately, yes.
Q.
And then for FICA, I think the low -- at least $7,000 for
everyone?
A.
Yes.
Q.
And for each one of those amounts, if those amounts had
been paid, would Social Security have a record of it?
A.
Yes.
Q.
And under all three EINs for companies associated with the
defendant, including Kremkov Industries, did you see any
record of that money being paid?
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A.
No.
Q.
And I asked you earlier in terms of the names that were on
that February 2020 payroll. And how many names were on that
list, what was the number?
A.
493.
Q.
And have you also looked at the yearly payroll for
Kremkov Industries related to the number of employees that are
listed?
A.
Yes. I believe it was on the last page, I had a summary.
Q.
Okay. And what is the number for this -- for the yearly
payroll in terms of number of employees?
A.
For employees, ma'am? I'm sorry.
Q.
For the number of employees --
Q.
Oh, 493.
Q.
-- the total number of employees.
I apologize. I was talking over you.
A.
That's okay.
Q.
What was the total number of employees?
A.
493.
Q.
Okay. Okay. Agent Fowler, I'm going to go through just
some of the specific names on this list. We've already talked
about Scott Ackers.
MS. CONNORS: Ms. Wilson, if you will move to Page 86
of this exhibit.
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BY MS. CONNORS:
Q.
And, Agent Fowler, we're going to zoom in on the name
Jason Bourne that's listed.
Is the name of an alleged employee that's receiving
payroll from Kremkov Industries in 2020?
A.
Yes.
Q.
And consistent with some -- with the other page that we
looked at, is there 50 -- approximately $5,700 in
Social Security tax listed?
A.
Yes.
Q.
Is there approximately $1,300 in Medicare tax listed?
A.
Yes.
Q.
Is there approximately 7,000 or more than 7,000 in FICA
tax withholdings for Jason Bourne listed?
A.
Yes.
Q.
Does Social Security have a record of any of that money?
A.
No.
Q.
Does Social Security have a record of any wages being paid
to Jason Bourne through Kremkov Industries?
A.
No.
MS. CONNORS: And if we can scroll down to the next
page, Page 87.
BY MS. CONNORS:
Q.
And do you see the name Charlie Brown listed?
A.
I do.
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Q.
And in regards to this payroll for Charlie Brown, is it
also consistent with some of the numbers that we saw on --
that we've already seen related to these yearly payroll?
A.
Yes, it is.
Q.
Okay. So for Charlie Brown, is the amount of
Social Security withholdings approximately $5,700 or more?
A.
Yes.
Q.
Is the amount for Medicare tax approximately $1,300 or
more?
A.
Yes.
Q.
And is the amount for FICA approximately $7,000 or more?
A.
Yes.
Q.
And for this individual and when you've searched
Social Security records, did you see any information reporting
wages or taxes for Charlie Brown related to
Kremkov Industries?
A.
No.
Q.
And there's a first number, that first column is for
hours, quantity. The second column there is for gross.
What is the amount of gross wages for Charlie Brown?
A.
$92,610.
Q.
And does Social Security have any information concerning
either gross or net wages for Charlie Brown related to
Kremkov Industries?
A.
No.
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Q.
Okay.
MS. CONNORS: And if we can move to Page 92 of that
exhibit.
BY MS. CONNORS:
Q.
And do you see the name Karl Delano?
A.
I do.
Q.
Is that the name of the defendant?
A.
Yes.
Q.
And if we can look at that, does this indicate that the
defendant had Social Security withholdings of approximately
$5,700?
A.
Yes.
Q.
Medicare taxes of approximately $1,300?
A.
Yes.
Q.
And FICA of approximately $7,000?
A.
Yes.
Q.
Are those numbers roughly consistent with the other
employees that we've just discussed related to this yearly
payroll?
A.
Yes, they are.
Q.
And in terms of Karl Delano, what does it indicate was the
gross pay for him?
A.
$92,633.50.
Q.
And in regards to Mr. Delano, does Social Security have
any record of wages being paid to him under
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Kremkov Industries?
A.
No.
Q.
Does Social Security have any record of Social Security
tax, Medicare tax or FICA being paid for him under
Kremkov Industries?
A.
No.
Q.
And can you remind the jury who is the 100 percent owner
of Kremkov Industries?
A.
Karl Delano.
MS. CONNORS: And if we can move to Page 97.
BY MS. CONNORS:
Q.
And you may be able to see it on the screen now.
A.
Yes.
Q.
And the last employee on that list, is it identified as
Gene Hackman?
A.
It is.
Q.
And in regards to Gene Hackman, do you see similar numbers
in terms of the Social Security tax, the Medicare tax and FICA
withholdings?
A.
I do, yes.
Q.
And in regards to Gene Hackman, what was the gross wages
for him?
A.
$92,931.36.
Q.
Does Social Security have any record of wages,
Social Security tax, Medicare tax or FICA being paid ever for
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Gene Hackman for Kremkov Industries?
A.
No.
MS. CONNORS: And if we can move to Page 114 of that
exhibit.
BY MS. CONNORS:
Q.
And the second name from the top, do you see the name
Keanu Reeves?
A.
I do.
Q.
Now, this document, again, was this submitted as part of
Kremkov Industries' PPP loan application?
A.
Yes, it was.
Q.
Is this indicating that Keanu Reeves received payroll in
2020 from Kremkov Industries?
A.
Yes.
Q.
Does Social Security have any record of Keanu Reeves
receiving income, wages from Kremkov Industries?
A.
No.
Q.
And if you look at the Social Security tax and the
Medicare tax and FICA that is reported here for Keanu Reeves,
is that consistent, approximate amounts to some of the other
employees that we've looked at?
A.
Yes, it is.
Q.
And in regards to Keanu Reeves, what is the -- what is the
alleged gross wages that he earned through Kremkov Industries?
A.
$93,253.76.
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Q.
That gross wage amount, does Social Security have any
record of that amount being paid to Keanu Reeves through
Kremkov Industries?
A.
No.
Q.
And would that apply to all of the employer identification
numbers that you have searched through Social Security's
system related to Kremkov Industries or companies controlled
by the defendant?
A.
That's correct, yes.
MS. CONNORS: And if we can go to Page 118. You can
scroll down to Page 118. There you go. Okay.
BY MS. CONNORS:
Q.
On Page 118, do you see kind of in the middle of the page
the name Monica Sweeten?
A.
Yes.
Q.
So does this indicate that this individual is an alleged
employee of Kremkov Industries?
A.
Yes, it does.
Q.
And is this reflecting payroll paid to Monica Sweeten in
2020?
A.
Yes.
Q.
Does it reflect Social Security taxes, Medicare taxes and
FICA being withheld for Monica Sweeten for her employment at
Kremkov Industries?
A.
Yes, it indicates that.
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Q.
And did you -- when you searched Social Security's
records, did you see any indication of wages or taxes being
paid on behalf of Monica Sweeten through Kremkov Industries?
A.
No.
Q.
And would that apply to all three employer identification
accounts that you looked at?
A.
Yes.
MS. CONNORS: And if we can go to the next page, 119.
BY MS. CONNORS:
Q.
And on this page, do you see the name Oliver Twist?
A.
Yes.
Q.
Is this indicating that Oliver Twist was an employee for
Kremkov Industries in 2020?
A.
Yes.
Q.
And does this have Social Security tax, Medicare tax and
FICA withholdings listed?
A.
Yes, it does.
Q.
When you searched for any of the employer identification
numbers for Kremkov Industries or associated with the
defendant, did you see any record of those withholdings being
paid on behalf of Oliver Twist?
A.
No, no record.
Q.
And again, is this an individual who was identified in
payroll that was submitted as part of the PPP loan
application?
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A.
Yes.
MS. CONNORS: Okay. And finally, if we could go to
Page 121.
BY MS. CONNORS:
Q.
Do you see the name Bruce Willis?
A.
Yes, I do.
Q.
Is this indicating that Bruce Willis is an employee of
Kremkov Industries in 2020?
A.
Yes.
Q.
And for Bruce Willis, is there Social Security tax,
Medicare tax and FICA listed?
A.
Yes.
Q.
And in terms of your research in Social Security's
systems, did you see any record that the Social Security tax,
Medicare tax or FICA were paid by Kremkov Industries for
Bruce Willis?
A.
No.
Q.
Did you see any record of any of these employees on this
payroll having wages from Kremkov Industries?
A.
No.
Q.
And is that the case for all three employer identification
accounts that you looked at?
A.
Yes.
MS. CONNORS: And if we could go to Page 122 of that
exhibit.
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BY MS. CONNORS:
Q.
Do we have grand totals listed here?
A.
Yes.
Q.
And in terms of the grand totals listed, is there a column
for gross wages?
A.
Yes.
Q.
I know it's kind of a long number, but if you can, what is
the amount for gross wages?
A.
It's $45,861,255.93.
Q.
Is that total indicating that Kremkov Industries paid
approximately $45.8 million gross wages to 493 employees in
2020?
A.
Yes.
Q.
And do you also see a net pay column?
A.
Yes.
Q.
Does that net pay column list a number, $32 million?
A.
Yes, it does.
Q.
And is that indicating that that is the gross pay for the
493 employees with Kremkov Industries in 2020?
A.
It would be the net pay.
Q.
I'm sorry, the net pay.
A.
Yes, ma'am.
Q.
Does it have a figure for Social Security -- total
Social Security tax paid?
A.
Yes.
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Q.
Does it also have a figure for total Medicare tax paid?
A.
Yes.
Q.
And finally, does it have a figure for total FICA paid?
A.
Yes.
Q.
Were any of those payments received and recorded by
Social Security?
A.
No.
Q.
And would that be when you searched all three employee
identification number accounts either under the name of
Kremkov Industries or any other company controlled by the
defendant?
A.
Correct, yes.
Q.
I guess maybe I should clarify. Controlled by the
defendant, related to him at the time of 2020?
A.
Yes, ma'am.
Q.
Now, in addition to these payroll documents, were tax
documents also provided as part of the PPP loan application?
A.
Yes.
Q.
And if you'll look at Page 141 of this exhibit.
A.
I'll read it off the screen.
MS. CONNORS: And, Ms. Wilson, yes, if you will zoom
in on that top section.
BY MS. CONNORS:
Q.
Agent Fowler, do you have some experience with this form?
A.
Yes.
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Q.
Okay. And can you generally explain what this form is?
A.
In general terms, it's an employer's quarterly federal tax
return. Many businesses file quarterly for their taxes and
then they fill out this form and submit that to the
government.
Q.
Okay. And in terms of the employer identification number,
is it the 7540 number that we saw on the PPP loan application?
A.
Yes.
Q.
The address listed, is that the same Douglasville address
that we've previously discussed during your testimony?
A.
Yes, it is.
Q.
Now, you mentioned that this is for a quarter.
Does it indicate which quarter or at least which
months are covered in the quarter that's reported?
A.
In the box to the right, it put an X in January, February
and March.
Q.
Okay. Yes.
A.
For the first quarter.
Q.
And in regards to this form, is it in the name
Kremkov Industries?
A.
Yes.
MS. CONNORS: Now if we can zoom out of that.
BY MS. CONNORS:
Q.
Does this form report any Social Security wages and
Social Security taxes that would be due?
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A.
Yes, it does.
Q.
Okay. And is that the section there, it's kind of all of
the numbers that have A 5 outside of it, it's like 5A, 5B, 5C?
A.
Yes.
Q.
Okay. Now in terms of this information, is this claiming
that these are taxable Social Security wages that are -- that
were paid during that quarter to employees of
Kremkov Industries?
A.
Yes, that's what it appeared to indicate.
Q.
Okay. And then as Column 2, it looks like there's
essentially a math equation that happens, like a
multiplication and then an equals?
A.
You say Column 2?
Q.
Yes, if you see it.
A.
Oh, yes. The two columns, yes.
Q.
Okay. I'm not going to ask you to do math, but
ultimately, Line 5E, does that indicate a total of the
information reported from 5A to 5D?
A.
Yes.
Q.
Okay. And what is that amount?
A.
On 5E, it's 1.8 million, so $1,807,988.67.
Q.
And so would this relate to total amount going for
Social Security and Medicare tax for that quarter?
A.
Yes.
Q.
And in terms of specifically looking at the employer
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identification number ending in 7540, did you find any record
of that amount being paid?
A.
No.
MS. CONNORS: And if we can go down one page to 142.
BY MS. CONNORS:
Q.
Is there an electronic signature on this document?
A.
Yes.
Q.
And who -- what's the name in that signature?
A.
Carl Torjagbo.
Q.
Is that the former name of the defendant?
A.
Yes, it is.
Q.
Now, if this Form 941 had been filed, would
Social Security have been able to capture this information
related to Social Security tax, any kind of Social Security
wages, Medicare tax and Medicare wages?
A.
So this form is for the IRS.
Q.
Um-hmm.
A.
But the information with the Social Security taxes would
have had to have been reported to the Social Security
Administration.
Q.
Okay. So essentially that information ends up getting
shared by the two agencies?
A.
Yes.
Q.
Now I'm going to move to Page 143 and I'm going to avoid
going through all of the numbers on these.
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Is this a different 941 covering a different quarter?
A.
Yes, Quarter 2, April, May, June.
Q.
And for this quarter, is this also being filed related to
employer identification number ending in 7540?
A.
Yes.
MS. CONNORS: And if we can zoom out of that.
BY MS. CONNORS:
Q.
And is there a number in the Line 1 column for the number
of employees during that quarter?
A.
Yes. It says 493.
Q.
Okay. And I'm not going to pull it back up, but if you
would not mind flipping back to the first page of the 941 that
we just looked at, I believe it should be Page 141.
Do you want us to move it on the screen?
A.
I can -- I'm sorry, the numbers are -- yes, ma'am.
Q.
Okay. Now, on that 941 that we looked for the first
quarter, did it also have 493 employees?
A.
Yes, it did.
Q.
Now, in terms of this 941, is it similar in that it
reports taxable Social Security wages, taxable Medicare wages
and then also has these calculations for Social Security and
Medicare taxes?
A.
Yes, it does.
Q.
Does Social Security have any record of those numbers?
A.
No.
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MS. CONNORS: And if we can move to Page 144, the
next page of this exhibit. I'm sorry, let me go one more
page, 145.
BY MS. CONNORS:
Q.
Is there an electronic signature on this 941 as well?
A.
Yes.
Q.
And whose signature is on this one?
A.
Carl Torjagbo.
Q.
Is that the defendant?
A.
Yes.
Q.
Okay.
MS. CONNORS: And I'm going to move to Page 146.
BY MS. CONNORS:
Q.
And is this another 941 for a different quarter?
A.
Yes, ma'am, it's for quarter three, July, August,
September.
Q.
Okay.
MS. CONNORS: If we can zoom out of that.
BY MS. CONNORS:
Q.
And what is the number of employees for this 941?
A.
493.
Q.
Does this one also indicate Social Security wages,
Medicare wages and Social Security and Medicare tax amounts?
A.
Yes, it does.
Q.
Does Social Security have any record of those amounts
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being paid?
A.
No.
Q.
Would that be the case under the employee identification
number ending in 7540?
A.
Yes.
Q.
Did you find any record under the other two employer
identifications that you looked at related to
Kremkov Industries or a company associated with the defendant?
A.
No other records.
Q.
Okay.
MS. CONNORS: And if we can go to Page 148.
BY MS. CONNORS:
Q.
Is there also a signature, an electronic signature on this
941?
A.
Yes, ma'am.
Q.
And is it the same name we've seen?
A.
It is. Carl Torjagbo, the defendant.
Q.
Okay.
MS. CONNORS: And then finally if we can go to
Page 149.
BY MS. CONNORS:
Q.
Is this a 941 for the final quarter in 2020?
A.
Yes.
Q.
And is the employer identification number still listed as
7540?
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A.
Yes, it is.
Q.
For Kremkov Industries?
A.
Yes.
MS. CONNORS: If we can zoom out of that.
BY MS. CONNORS:
Q.
And how many employees are identified?
A.
493.
Q.
Now, does this 941 also report taxable Social Security
wages, taxable Medicare wages and Social Security and Medicare
taxes due?
A.
Yes, it does.
Q.
And does Social Security have any record of those amounts
being paid by Kremkov Industries?
A.
No.
Q.
Does that include specifically for the EIN ending in 7540
as well as the other two EINs that you researched?
A.
Yes, it applies to all, there were no records.
Q.
All right. Agent Fowler, you talked before about there's
some kind of reasons why Social Security and Medicare taxes
are being withheld.
Would you expect a goldmine that operates solely in
Ghana to deduct Social Security and Medicare taxes from
employees' wages?
A.
Not unless they had U.S. employees.
Q.
So if it was U.S. employees, would you expect that you are
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receiving the documentation to support that Social Security
taxes, Medicare taxes and wages were being paid to those
employees?
A.
Correct. It would have to be reported to the government.
Q.
And in regards to Kremkov Industries, you were able to
find that there was an employer identification number for that
company ending in 7540?
A.
There was an EIN for that, but there was no record in the
Social Security Administration for anything filed for that
EIN.
Q.
So there's no record of any U.S. employees being paid
Social Security wages -- taxable Social Security wages,
taxable Medicare wages or Kremkov Industries paying FICA on
behalf of any U.S. employees?
A.
Correct.
Q.
Okay. And, Agent Fowler, I'm going to have you look at
Exhibit 201 in the binder first.
A.
Is that a different binder? Yes.
THE COURT: 201, you said?
MS. CONNORS: Yes, Your Honor. 201. 201.
BY MS. CONNORS:
Q.
And, Agent Fowler, can you tell me what that document is?
A.
It's a 1040 tax form for the year 2020.
Q.
And whose name is on that tax return?
A.
It's Carl Torjagbo.
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MS. CONNORS: And, Your Honor, the information from
the Internal Revenue Service is part of our stipulation as
authentic records. And I would move to admit Exhibit 201.
MR. FINLAYSON: No objection.
THE COURT: Okay. 201 is admitted.
MS. CONNORS: And, Ms. Wilson, if you could please
pull that up.
BY MS. CONNORS:
Q.
And so, Agent Fowler, you indicated that this -- Carl
Torjagbo's name is on this one. Do you also see --
MS. CONNORS: And if we can zoom into that. There we
go.
BY MS. CONNORS:
Q.
Is a Douglasville address, the same one that we've seen
before, is that also listed on this return?
A.
Yes, it is.
Q.
Okay. Now, on Line 1, do you see a figure of 9,199,411?
A.
Yes.
Q.
Now, in terms of what that amount is, do you see kind of
more on the left side what that amount is supposed to
represent?
A.
It's wage, salaries, tips, et cetera, Form W-2.
Q.
Okay.
MS. CONNORS: And if we can go to Page 2 of the
exhibit. And if we'll -- there you go.
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BY MS. CONNORS:
Q.
Okay. And I'm going to ask you to look at Line 34 in the
refund section. And we'll try to zoom in for you. There you
go.
A.
Yes.
Q.
And can you read what it says is supposed to be reported
in Line 34?
A.
If Line 33 is more than Line 24, subtract Line 24 from
Line 33, this is the amount you overpaid.
Q.
And what is the answer to Line 34?
A.
3,373,441.
Q.
And can you also read what's supposed to be reported in
Line 35A?
Q.
Amount of Line 34 you want refunded to you. If Form 8888
is attached, check here.
Q.
And what is the amount reported in 35A?
A.
3,373,441.
MS. CONNORS: Now I'm going to pull up Page 13 of
that exhibit. If we can zoom in on the text. Thank you.
BY MS. CONNORS:
Q.
Okay. Agent Fowler, do you see an employer identification
number listed?
A.
Yes, I do.
Q.
And what are the last four digits of that employer
identification number?
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A.
1377.
Q.
Okay. Is that one of the employer identification numbers
that you researched through Social Security's system?
A.
It is.
Q.
Now, in the Block C, what is the employer -- the
employer's name?
A.
Kremkov Industries.
Q.
And does it list a Douglasville address?
A.
It does.
Q.
Now, in regards to that employer identification number
ending in 1377, is that a different number than what was on
the PPP application that we just looked at?
A.
Yes, it is.
Q.
And do you recall which one was used on the PPP
application?
A.
It was the one ending in 7540, I believe.
Q.
Yes. Let's see. Now, in terms of the EIN 1377, when you
researched Social Security's system, did you find any record
of wages, Social Security taxes or Social Security -- or
Medicare taxes under that EIN?
A.
No.
Q.
If an employee had those wages for a company using that
EIN, would Social Security have a record of it?
A.
Yes.
Q.
Now, this W-2, if you can look down at E, whose W-2 is
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this?
A.
That's Carl Torjagbo, the defendant.
Q.
Okay. Now, this identifies the employer name as
Kremkov Industries.
In regards to Kremkov Industries, is Carl Torjagbo
the person who was the organizer and 100 percent owner of that
company?
A.
Yes, he was.
Q.
Now, for wages, tips and other compensation, what does it
list?
A.
9,199,411.
Q.
Now, Agent Fowler, do you recall that we looked at the
2020 payroll for Kremkov Industries that was submitted with
the PPP loan?
A.
Yes.
Q.
Was a much smaller amount for wages listed for Karl
Delano?
A.
For Karl Delano, yes.
Q.
Was it approximately 92 or $93,000?
A.
Yes, it was 92 or 93.
Q.
Okay. And in terms of this W-2, is this supposed to be
reporting any wages and taxes in 2020 for this individual?
A.
Yes.
Q.
So this -- is the amount here for wages and tips and other
compensation inconsistent with what you saw identified on the
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payroll?
A.
Yes.
Q.
And here, is there an amount listed for Social Security
wages and Social Security tax withholdings?
A.
Yes.
Q.
Is there also an amount listed for Medicare wages and
Medicare tax withheld?
A.
Yes.
Q.
Did you find any record of Carl Torjagbo or Karl Delano
having any wages, Social Security taxes, Medicare taxes
associated with Kremkov Industries?
A.
No.
Q.
And for any employee of Kremkov Industries, did you find
any record of any Social Security taxes, Medicare taxes or
wages?
A.
No.
Q.
Now, again, this EIN relates to 13 -- it's 1377, and I'll
briefly pull up Exhibit 5 that has already been admitted.
So to confirm something, is this the EIN that's
listed on that W-2?
A.
Yes.
Q.
And for that EIN, did you find any records?
A.
No.
Q.
Okay. And if you can look at Exhibit 202. I'm sorry.
202.
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A.
Yes, ma'am.
Q.
And what is that document?
A.
It is a 1040 tax form for the year of 2020.
Q.
In regards to Exhibit 201 that we just looked at, was that
also a Form 1040 for tax year 2020?
A.
Yes.
Q.
And whose name is on Exhibit 202?
A.
Carl Torjagbo, the defendant.
Q.
Okay.
MS. CONNORS: And, Your Honor --
THE COURT: Hold on. Did you-all see that?
JURORS: No.
THE COURT: I did not see it.
MS. CONNORS: Oh, I had not moved to admit it yet.
THE COURT: Oh, I'm sorry. I'm getting ahead of you.
MS. CONNORS: That was the very next thing.
Your Honor, I would move to admit Government's
Exhibit 202. And this is a document from the
Internal Revenue Service that we had the stipulation related
to authenticity.
MR. FINLAYSON: No objection.
THE COURT: Okay. Then it is now admitted and can be
published.
MS. CONNORS: Thank you, Your Honor.
Okay. And if we can now zoom in on the top for this
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one.
BY MS. CONNORS:
Q.
To confirm, whose name is on this return?
A.
Carl Torjagbo.
Q.
Okay.
MS. CONNORS: And if we can zoom in, please.
BY MS. CONNORS:
Q.
At the bottom, is there a Houston address that's listed?
A.
Oh, it was just there. Yes, there is.
Q.
Okay. Okay.
MS. CONNORS: And if we can go to Page 17 of this
exhibit.
BY MS. CONNORS:
Q.
Does this W-2 use the same employee identification number
ending in 1377 that we just saw on a different W-2?
A.
Yes, it does.
Q.
Is Kremkov Industries listed as the employer on this W-2?
A.
Yes.
Q.
Does this W-2 have an employee address of 2220 Westcreek
Lane, Apartment E71 in Houston, Texas?
A.
Yes.
Q.
Now, looking on the right side for the wages, tips and
other compensation, is it possible to compare?
MS. CONNORS: And do you know, is it possible to flip
those so we see the first one that we were looking at on the
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left side and the other one on the right? Okay. Yes. If you
can zoom in. And if you would like just do the right side of
both of those that has the two columns going down, to make it
a little easier to read. Yes. Okay. And if you can zoom in
on the other one the same way.
BY MS. CONNORS:
Q.
Okay. Now, Agent Fowler, these W-2s, both supposed to be
for Carl Torjagbo?
A.
Yes.
Q.
For the defendant?
A.
Yes.
Q.
Now, the one on the left screen is from Exhibit 201, and
the one on the right side of the screen is from Exhibit 202.
Are different amounts listed for wages?
A.
Yes.
Q.
Are different amounts listed for federal income tax
withheld?
A.
Yes.
Q.
Are different amounts listed for Social Security wages?
A.
Yes.
Q.
Is the amount for Social Security tax withheld the same?
A.
Yes.
Q.
Are Medicare wages and tips the same?
A.
Yes.
Q.
And then for Medicare tax withheld, are those different?
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A.
Yes.
Q.
Now, in regards to attached -- either -- the data in
either one of these W-2s, did Social Security have a record of
any of these wages, Social Security taxes or Medicare taxes
being paid by Kremkov Industries for any employee?
A.
No.
Q.
And did that include the defendant?
A.
Yes.
Q.
Okay.
MS. CONNORS: And, your Honor, this would be the time
for the limiting instruction.
THE COURT: Okay.
MS. CONNORS: You can take those down.
THE COURT: I told you I might from time to time give
you specific instructions about how you can use evidence and
this is one of those times.
You are about to hear evidence concerning two
Social Security numbers allegedly acquired by the defendant
prior to the offenses charged in this indictment.
You must not consider this evidence to decide if the
defendant engaged in the activity alleged in the indictment,
but you may consider this evidence to decide whether the
defendant had the state of mind or intent necessary to commit
the crime charged in the indictment, if the defendant had a
motive or the opportunity to commit the acts charged in the
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indictment, if the defendant acted according to a plan or in
preparation to commit a crime, or if the defendant committed
the acts charged in the indictment by accident or mistake.
Okay. Do you understand that?
That's a limited purpose. You will have this
instruction at the end, by the way. I'm going to give you-all
copies of all of my instructions. And you will have this
instruction within it.
Okay?
But just keep in mind that this next what you're
going to hear about, the defendant having allegedly acquired
two Social Security numbers is being admitted for that limited
purpose.
Okay?
Questions? Concerns?
All right. Thank you.
MR. FINLAYSON: Your Honor, just for the record, I
would renew my objection to this.
THE COURT: Yes. Yes. Not to the instruction but to
the evidence?
MR. FINLAYSON: Correct.
THE COURT: Okay. Thank you.
Go ahead, please.
MS. CONNORS: Thank you.
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BY MS. CONNORS:
Q.
Okay. So, Agent Fowler, we just looked at Exhibits 201
and 202, but I'm going to get some more specific information.
So if you would look back at 201 and Page 1 of that
exhibit. And we're also going to compare that to Exhibit 202
and the first page of that one.
A.
Um-hmm.
MS. CONNORS: And if it is possible, can we kind of
zoom in on that top section?
BY MS. CONNORS:
Q.
Okay. So for these two tax returns for the year 2020,
you've already gone through some of the information on both
returns. But just to confirm, both are in the name
Carl Torjagbo; is that correct?
A.
Yes, ma'am.
Q.
So in the tax return that is Exhibit 201, what are the
last four numbers in the Social Security number?
A.
0540.
Q.
And then for Exhibit 202, what are the last four digits of
the Social Security?
A.
6010.
Q.
And did you have an opportunity to research both of these
Social Security numbers?
A.
I did.
Q.
And what were you -- were you able to obtain copies of
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applications for Social Security numbers in the name of
Carl Torjagbo?
A.
I was.
Q.
And in terms of these two Social Security numbers, were
you able to determine anything related to if one was obtained
first and then another one was obtained later?
A.
Yes. One was obtained, I believe it was 6010 was obtained
first. And then 0540 was obtained after.
Q.
And do you remember approximately how much time lapsed
between both of those?
A.
I believe it was about seven years.
Q.
Okay.
A.
Maybe six.
Q.
And, Agent Fowler, if you'll look at Exhibit 7.
Okay. And we're going to discuss these two Social
Security numbers in chronological order to hopefully prevent
confusion.
So in terms of Exhibit 7, do you know which -- I'm
sorry, what is this exhibit?
A.
It's a Social Security Administration record of an
application for a Social Security card.
Q.
Okay. Does this concern a Social Security application for
the defendant?
A.
Yes, it's in the name of Carl Delano Torjagbo.
MS. CONNORS: And, Your Honor, I would move to admit
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Government's Exhibit 7. It is also subject to the
stipulation.
MR. FINLAYSON: And, Your Honor, I would object to it
for the reasons put forth earlier, 401, 403, as well as
relevance.
THE COURT: Okay. Overruled. It's admitted.
MS. CONNORS: Thank you, Your Honor.
And if we could pull up Exhibit 7. And if --
THE COURT: Just to be clear, Mr. Finlayson, your
objection was not to the stipulation?
MR. FINLAYSON: Correct. Not to -- but for those
reasons discussed earlier in my motion.
THE COURT: Okay. Fair. Thank you.
MS. CONNORS: And we can, yes, zoom in on that top
part. Thank you. Okay.
BY MS. CONNORS:
Q.
And I believe you already pointed out, but since the jury
can now see this exhibit, what is the name on this
application?
A.
It's Carl Delano Torjagbo.
Q.
And looking at some of the information on here, is there a
date of birth that is listed?
A.
Yes.
Q.
And what's the date of birth?
A.
09/08 of 1975.
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Q.
And was there a place of birth listed?
A.
Yes.
Q.
And what's the police of birth?
A.
It is Accra, Ghana.
MS. CONNORS: And if you can zoom out of that section
and then go to the 14 and 16.
BY MS. CONNORS:
Q.
Now, it has -- is there a line for today's date?
A.
Yes.
Q.
And it's a little hard to see, but what is the -- what is
the date?
A.
11/21 of '97.
Q.
Okay. And if we can -- and is there a signature line?
A.
There is.
Q.
Okay. And is there an indication of who is essentially
requesting the Social Security number?
A.
The box marked self was X'd or checked.
Q.
Okay. Does that mean that Mr. Delano was requesting the
Social Security number?
A.
It would indicate the name on the application was who was
filing it.
Q.
Okay.
MS. CONNORS: And if we can zoom in at the bottom
section, in that box at the bottom.
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BY MS. CONNORS:
Q.
To issue a Social Security number to someone, does Social
Security require any information?
A.
Yes.
Q.
What do they require?
A.
It depends on how you're applying. Oftentimes, it's
immigration forms and passports from your country, if you're
coming from out of the country.
In cases where you're merely born in the U.S., it's a
birth certificate.
But in this case, you can see a Ghanaian passport
number, and I believe an immigration document mentioned.
Q.
Okay. So does that mean -- so what does that mean in
terms of being in that section for evidence submitted?
A.
That that's what was submitted in order to obtain the
Social Security number.
Q.
Okay. And as a result of this application, was a
Social Security number issued?
A.
Yes.
Q.
And which Social Security number was issued?
A.
The one ending in 6010.
Q.
And, Agent Fowler, if you will look at Exhibit 8 in the
binder. And is that document familiar to you?
A.
Yes.
Q.
And what is it?
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A.
It's an application for replacement Social Security card.
Q.
Okay. Is it a replacement Social Security card related to
the Social Security number ending in 6010?
A.
I missed it on the page, but yes.
Q.
Okay.
MS. CONNORS: Your Honor, I would move to admit
Government's Exhibit 8.
MR. FINLAYSON: Same objections, Your Honor. Renewal
and 401, 403, and 404(a).
THE COURT: Okay. It's overruled. Go ahead.
MS. CONNORS: Thank you.
THE COURT: The document is admitted.
MS. CONNORS: Okay. And if we can pull up Exhibit 8.
And if you'll try to scroll in on the text. There we go.
BY MS. CONNORS:
Q.
Okay. So in terms of this document, does it still
indicate a birthdate of 9/8/1975?
A.
Yes, it does.
Q.
And does it continue to have an applicant name of Carl
Delano Torjagbo?
A.
Yes, Carl Delano Torjagbo.
Q.
And I think you can maybe tell, it says last SSN. And
then does it include the SSN ending in 6010?
A.
It does.
Q.
So if this is an application for a replacement card, is
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that the Social that's being asked to have the replacement
card issued?
A.
Yes, it is.
Q.
Okay. Now if we can go to the date on that form.
A.
Yes, I can see it.
Q.
Okay. And what was the date for this form?
A.
11/27 of '02.
Q.
Okay.
MS. CONNORS: And if you can back out of the zoom for
that one. And if you can zoom in at the bottom where it
starts, "acceptable evidence."
BY MS. CONNORS:
Q.
Does Social Security also require some kind of information
to be able to issue a replacement Social Security card?
A.
Yes, it does.
Q.
And here, are there some types of evidence that were
listed as submitted?
A.
Yes.
Q.
Okay. Now, I want you to focus, do you see an FL and then
a space and then ID?
A.
Yes.
Q.
Now, and is there a number after it? Well, it starts with
a T and then there's a number?
A.
Yes.
Q.
Okay. So if you can look at Government's Exhibit 11.
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And is this -- is this a record from an agency?
A.
Yes. It's from the Florida Highway Safety and Motor
Vehicles.
Q.
Okay. Does it relate to a driver's license for the
defendant?
A.
Yes. I'm sorry. It does.
Q.
Okay.
MS. CONNORS: Your Honor, I move to admit
Government's Exhibit 11 and these -- the authenticity of these
records were included in the stipulation.
MR. FINLAYSON: Same objection.
THE COURT: Overruled. It's admitted.
MS. CONNORS: And if we can pull up Exhibit 11 and
look at page 1. And if you will -- about three-quarters.
BY MS. CONNORS:
Q.
Okay. Do you see where it says application for driver's
license or ID card?
A.
Yes, ma'am.
Q.
And what's the date for the application?
A.
6/19 of 2000.
Q.
Okay. And is there a photograph?
A.
Yes.
Q.
Now, there is a date of birth listed?
A.
Yes.
Q.
What is that date of birth?
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A.
9/8 of '75.
Q.
Is that the same date of birth that was associated with
the Social Security application as well as the replacement
Social Security card application?
A.
For the one ending in 6010, yes, ma'am.
Q.
Okay. And looking just under that blue kind of box that
says verification, do you see a Social Security number listed?
A.
Yes.
Q.
And what Social Security number is that?
A.
It's the one ending in 6010.
MS. CONNORS: Now, Ms. Wilson, if you can, can you
bring up that driver's license ID number that's on the
document.
And then can you also bring up Exhibit 8, that bottom
section for the "evidence submitted" portion, just the
acceptable -- yes.
BY MS. CONNORS:
Q.
Okay. So, Agent Fowler, can you see the Florida ID number
that's listed for the Social Security application for the
replacement Social Security card?
A.
Yes.
Q.
Is the number listed the same as what is on the Florida
driver's license record?
A.
Yes.
Q.
And in regards to the particular driver's license record,
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is it for Carl Torjagbo?
A.
Yes.
Q.
And does it list an address in Florida?
A.
Yes, it does.
Q.
Okay. And if you will, can you look at Government's
Exhibit 12.
Is that a record -- a driver's license record from a
different state?
A.
Yes, it is.
Q.
And which state is it?
A.
From the Texas Department of Public Safety, so from Texas.
Q.
And is this a driver's license for the defendant?
A.
Yes.
MS. CONNORS: Your Honor, I'd move to admit
Government's Exhibit 12. And this is a record that's also in
our stipulation related to authenticity.
MR. FINLAYSON: Same objection as to Exhibits 7
through 11 and made before renewing.
THE COURT: Okay. Overruled.
And, Ms. Connors, will you let me know when we get to
the end of this evidence, to which the limiting instruction
applies. Are we past that now?
MS. CONNORS: This would be all after the limiting
instruction.
THE COURT: Okay. Just the application of the Social
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Securities?
MS. CONNORS: The rest of his testimony I think would
be covered under the limiting instruction.
THE COURT: Oh, okay. Thank you. So it still
applies? My limiting instruction still applies --
MS. CONNORS: Yes.
THE COURT: -- at this point?
MS. CONNORS: Yes, Your Honor.
THE COURT: Okay.
MS. CONNORS: Okay. And if we can pull up
Exhibit 12.
BY MS. CONNORS:
Q.
And so which state is this a record from?
A.
Texas.
Q.
Is -- does this relate to a driver's license as well?
A.
Yes, it does.
Q.
Okay. And if you can look, is this also in the name of
Carl Torjagbo?
A.
Yes.
Q.
Do you see a date of birth?
A.
Yes. 9/8 of '75.
Q.
Is that the same date of birth that is associated with the
6010 Social Security number?
A.
Yes, it is.
Q.
And there's a date for image date. What is that?
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A.
7/23 of 2004.
Q.
And then do you also see an address listed?
A.
Yes.
Q.
And is that address in Houston, Texas?
A.
Yes, it is.
Q.
And in case you need to look back, could you look at
Exhibit 2 -- 202, just the tax return filed under 6010, and
tell me if it has the same Houston address on it.
A.
Yes, it does.
Q.
Okay. Agent Fowler, if you could look at Exhibit 9.
A.
Yes, ma'am.
Q.
And what is this exhibit?
A.
It's another application for a Social Security card that
was a record I pulled from the Social Security Administration.
MS. CONNORS: Your Honor, I would move to admit
Government's Exhibit 9.
MR. FINLAYSON: Same objection, Your Honor.
THE COURT: Overruled.
MS. CONNORS: And if we can pull up Exhibit 9.
BY MS. CONNORS:
Q.
Okay. Now, for this Social Security application for a
Social Security card, whose name is this one in?
A.
It's also in the name of Carl Torjagbo.
Q.
Okay. Now, for this Social Security -- this application
for a Social Security card, what does it identify as the date
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of birth?
A.
9/10 of '79.
Q.
And what does it identify as the place of birth?
A.
A city called -- I believe it's pronounced Takoradi,
Ghana.
Q.
Is that a different city in Ghana than what was listed on
the prior application?
A.
Yes, it is.
Q.
Is it a different date of birth than what was listed on
the prior application?
A.
Yes.
Q.
Okay.
MS. CONNORS: And if we can zoom out of that and go
to the date that was submitted, Line 14.
BY MS. CONNORS:
Q.
And what was the date for this application?
A.
It was 2/2 of 2005.
Q.
Now, the prior application for the 6010 Social Security
number, was that one in 1997?
A.
Yes, it was.
Q.
Now, if we can look at this one at the bottom, where it
says "evidence submitted."
Is this similar with your prior testimony that some
type of identity information is necessary?
A.
Yes.
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Q.
All right. So does this indicate that some kinds of
documents were provided to support the application for this
Social Security card?
A.
Yes.
Q.
Okay.
MS. CONNORS: And if you can zoom out of that and go
to Section 10, zoom in on Section 10.
BY MS. CONNORS:
Q.
And can you read the question in Section 10?
A.
It says: Has the applicant or anyone acting on his or her
behalf ever filed for or received a Social Security number
card before.
Q.
What was the response?
A.
The box of no was X'd or it had been checked.
Q.
Okay. Now, looking at the options there, if the first box
for yes had been checked, were there additional questions that
needed to be answered?
A.
Yes.
MS. CONNORS: And if we can look at -- zoom into the
Questions 11,12 and 13.
BY MS. CONNORS:
Q.
Would it have -- would the person have had to enter the
Social Security number that they were previously assigned?
A.
Yes.
Q.
Would a name be required?
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A.
Yes.
Q.
And if there was a different date of birth used on an
earlier application, did it have to be identified?
A.
Yes.
Q.
Now, in regards to all three of these sections, was there
no response?
A.
There was nothing in the form.
Q.
And then if we can look at Section 16, was this
application signed? Is there a signature that appears?
A.
There is.
Q.
And can you read what 16 says?
A.
I declare under penalty of perjury that I have examined
all of the information on this form and on any accompanying
statements or forms and it is true and correct to the best of
my knowledge. And it says your signature.
Q.
Now, as a result of this application, was a second Social
Security number assigned to the defendant?
A.
To the name Carl Torjagbo, yes.
Q.
Okay.
A.
Sorry.
Q.
And do you recall which -- the last four of that Social?
A.
I believe it was 0540.
Q.
Or if you want to look at --
A.
Did I say it --
Q.
-- exhibit -- let's see -- if you could pull up
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Exhibit 201.
A.
Yes, ma'am.
Q.
Okay. And the Social Security number for that tax return,
what were the last four digits?
A.
0540.
Q.
So is that the -- is that the second Social Security
number that was issued?
A.
Yes, it is.
Q.
Okay. Now, generally speaking, with the Social Security
Administration, are individuals assigned one Social Security
number or multiple?
A.
Generally speaking, one. You have one Social Security
number for your whole life and to get a second one is a very
difficult process.
Q.
Okay. Is it rare?
A.
Yes.
Q.
Now, for this particular application, since the answer was
no to having a prior Social Security number, is that a reason
why a second one was actually issued?
A.
Yes.
Q.
Now, if this application had identified the same date of
birth as the first, the first application that we saw, the
same place of birth and provided the same identity evidence as
was used for the first application, would Social Security have
possibly been able to determine that it was the same person
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applying for both Social Security numbers?
A.
Yes.
Q.
Because that information was different, did that mean that
Social Security did not recognize that this was the same
person applying for both Social Security numbers?
A.
Yes, the second application had different information.
MS. CONNORS: And if we can look at -- pull up
Exhibit 11 again and go to Page 10.
BY MS. CONNORS:
Q.
Now, we looked at a Social -- or, I'm sorry, a Florida
driver's license information previously.
Is this application at the top, does it have a -- is
this a later date?
A.
Yes.
Q.
Okay. And what was the date for this application?
A.
February 20th of 2007.
Q.
Was that a date after the second Social Security number
was issued?
A.
Yes.
Q.
And what was the date of birth for this driver's license?
A.
9/10 of '79.
Q.
Is that the same date of birth that was on the second
application for a Social Security number?
A.
Yes, it was.
Q.
And, Agent Fowler, if you could look at Government's
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Exhibit 10 in the binder.
And does this relate to another driver's license?
A.
Yes, it does.
MS. CONNORS: Your Honor, I would move to admit
Government's Exhibit 10.
MR. FINLAYSON: Same objections as before.
THE COURT: Okay. It's overruled. It's admitted.
MS. CONNORS: And if we can pull up Exhibit 10.
BY MS. CONNORS:
Q.
Now, which state was this driver's license record?
A.
Georgia.
Q.
Okay. Now, for this driver's license, does it include the
Karl Lucius Delano name?
A.
Yes, it does.
Q.
The date of birth, is that the same date of birth that's
associated with the 0540 Social Security number?
A.
Yes, it is.
Q.
Now the issue date for this driver's license, was it in
2022?
A.
Yes, 2/11 of 2022.
Q.
And so at this time, the date of birth being used is
consistent with that -- the date of birth that was on the
second Social Security application?
A.
Yes.
MS. CONNORS: You can take that down.
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BY MS. CONNORS:
Q.
Now, Agent Fowler, were you able to search both of these
Social Security numbers through Social Security's system?
A.
Yes, I was.
Q.
Under either one of the Social Security numbers, did you
see over $9 million in wages and earnings under the
defendant's two different Social Security numbers that was
associated with earnings from Kremkov Industries?
A.
No.
Q.
Did you see any earning posted for employment at
Kremkov Industries under either Social Security number?
A.
No.
Q.
Did you see evidence of any Social Security or Medicare
taxes related to withholdings from Kremkov Industries for
either one of the defendant's Social Security numbers?
A.
No.
MS. CONNORS: Just a moment, Your Honor.
That's all I have. Thank you.
THE COURT: All right. Do you want our mid-afternoon
break? Yes? You want to push on? I see a couple yeses. All
right. We're going to take a ten-minute break, and then we're
going to go until 4:30. Okay? All right. Just ten minutes.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: All right. I have a question from the
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jury. Y'all can be seated. It says --
MS. CONNORS: Your Honor, is it something that the
witness cannot be in here for?
THE COURT: He's fine. No, he can be in here.
It says: Please reiterate the limiting instruction
how we can use info regarding different Social Security
numbers. The info in this case very confusing. Thank you.
Juror 24.
So they want me to explain it to them better.
Thoughts?
MR. FINLAYSON: Your Honor, I think that the proper
time would be at the close of the case. I don't think we need
to read it to them again at this point.
MS. CONNORS: I agree, Your Honor. I don't know that
there is anything else that we could really do to try to
clarify it further. I think it's something we'll be able to
reiterate at the end of the case.
THE COURT: So just tell them no?
MS. CONNORS: Your Honor, I think at the most, I
would read the exact same instruction again. I don't think
that we should modify the instruction further. We did try to
make sure that we were using primarily the pattern instruction
and only changing as necessary to fit the facts of this case.
And we did also want to be able to give it at that
specific point in the testimony rather than waiting until
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after the testimony was already given.
But I think any additional changes at this point we
shouldn't do.
THE COURT: I'm going to read them this instruction
again, and I'm going to tell them that he's not charged with
any crime involving obtaining the two Social Security numbers.
It's just a -- it's a poorly done instruction. I
know it's got the stamp of being a pattern charge, but tell me
what it means that you cannot consider this to decide if the
defendant engaged in the activity alleged in the indictment.
Of course you can.
Because you can decide that he had the right state of
mind or the wrong state of mind or did not commit an accident
or that he had the opportunity. All of those things are -- he
had the opportunity to engage in it. You can use it to
determine that he had the opportunity. I think that's the
same thing as part of your decision as to whether he engaged
in that activity. It's just a poor instruction, I suppose.
But I'm going to -- is there any objection to me
giving it to them again?
MR. FINLAYSON: Yes, sir.
THE COURT: You do object to that?
MR. FINLAYSON: I do, yes, sir.
THE COURT: Okay. I won't do it then. We've got a
jury that's asking a question. And we're going to tell them
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they can't have the answer.
Is that what you want me to do as well?
MS. CONNORS: No, Your Honor. We're comfortable with
the Court reading the instruction again.
THE COURT: All right. I'm going to do it. Bring
them in.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: By the way, you-all don't have to sit in
the same spot every time. You can move around if you want,
meet new people, sit next to new people. Or if you like the
spot, you can keep your spot.
Okay?
Y'all can sit down. Thank you.
I got your question or your note. Let me try again
now that you've heard some of them.
Okay?
You've heard evidence about the defendant allegedly
acquiring two Social Security numbers. I want to make sure
that it's clear. The defendant is not charged in this case
with a crime of obtaining those two Social Security numbers.
Okay?
You heard what the charges are in this case during
the opening statements. What I want to make sure you
understand about the limited purpose of this evidence about
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the Social Security numbers is that you cannot consider that
evidence to decide if the defendant, in fact, engaged in the
alleged activity, the alleged illegal activity claimed in the
indictment in this case. You cannot use that evidence to
decide if he engaged in that criminal activity.
You can use it for a very limited purpose. You can
consider it to decide if he had the state of mind or intent
necessary to commit the crime charged. I will tell you what
that intent and state of mind is later.
Okay?
You will be able to consider this evidence to
determine if he had the intent or state of mind. You will
also be able to use it to decide whether he had the motive or
the opportunity to commit the crimes charged in the
indictment. You will be able to use it to decide whether he
acted according to a plan or in preparation to commit the
crimes charged. And you will be able to use it to determine
whether he committed the acts charged in the indictment
because of a mistake or an accident.
Okay?
So that's the limited nature. When I -- at the end
of the case, I will give you an instruction on the elements of
the offense, those are the things that the government has to
show in order to prove its case. Okay?
And some of those things will talk about intent or
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things of that nature and you will be able to consider this
evidence about the Social Security number for those limited
purposes I've gone over. Okay?
I think you'll find at the end, when you see the
elements of the offense that this instruction will make more
sense then. Okay?
The purpose now is really to know that it's for that
limited purpose and not for the broader idea of deciding if
he, in fact, engaged in the activity.
That sounds very lawyerly. And there's probably like
a month of law school in that. But if you trust me, it will
make more sense at the end when you have everything. The
important part is just to know that this limited instruction
applies to the stuff you're hearing about the Social Security
numbers. Okay?
All right. Anything else?
MR. FINLAYSON: I'd just renew my objection,
Your Honor.
THE COURT: Sure. Okay. Anything from the
government?
MS. CONNORS: No, Your Honor.
THE COURT: Okay. I appreciate both of y'all. Thank
you.
All right. Now it is time that the defendant has an
opportunity to cross-Examine ability witness. Thank you.
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MR. FINLAYSON: Thank you.
CROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
Agent Fowler, how are you, sir?
A.
Good. How are you, sir?
Q.
I've got a few questions for you.
We've just been talking about these Social Security
cards, right?
A.
Yes, sir.
Q.
Okay. In the first one, if I understand your testimony,
Mr. -- in the name Torjagbo, he got the first one in 1997; is
that right?
A.
Yes, sir.
Q.
So that's over 28 years ago, right?
A.
That sounds right, yes, sir.
Q.
Do you trust me on that?
A.
Yes, sir.
Q.
Okay. '97. 28 years ago.
And then the second one, he gets a new one, was that
2004?
A.
I think it was 04, or '05. I'd have to look at the
application again. I apologize. It was either '04 or '05.
Q.
Okay. So that's over 20 years ago as well, right?
A.
Either right at 20 or over 20, yes, sir.
Q.
Okay. So '97, he's like what, 17 years old or 21 years
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old, depending on which birthday you go with, right?
A.
I trust your math. It would be dependent on the birthday.
Q.
He was a young man probably?
A.
Yes, sir.
Q.
He had just come to this country?
A.
I only knew when he applied. I don't know when he came to
the country.
Q.
Okay. You testified that generally people -- most people
only get one Social Security card, right?
A.
Yes, sir.
Q.
But you can get a replacement. People do change the
number, don't they?
A.
No, not very often.
Q.
Not very often, but it does happen?
A.
Right. Only under specific circumstances.
Q.
Such as fraud, right? If somebody is a victim of fraud,
right?
A.
Not generally. Even under those circumstances, there has
to be additional reasons why you need -- need a replacement.
Q.
If they're a victim of domestic abuse, that happens,
right?
A.
That could be one, yes, sir.
Q.
Okay. Do you know that Mr. Torjagbo was -- did report
being a victim of domestic abuse?
A.
I don't know his -- his past reporting, sir.
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Q.
Okay. You can also get a different card if you have
religious objection to the numbers that are listed there?
A.
If documentation is filed and you have a religious
objection, you can get a different one, yes, sir.
Q.
Okay. So it does happen, right?
A.
Rarely, yes, sir, but...
Q.
I mean, have you done a survey? Have you counted? I
mean, across the country, are we talking ten people or 10,000
people?
A.
I don't know the number as I sit here, sir.
Q.
Okay. Did you ever know the number?
A.
No.
Q.
Okay. So when you say rarely, you don't really -- you
can't quantify that, can you, sir?
A.
I can't quantify it. I can just say what in my dealings
and work with the Social Security Administration, they do
everything they can not to issue additional Social Security
numbers, because it can confuse credit reports and a number of
other things, so they make every effort not to issue an
additional one.
Q.
Okay. You mentioned -- you looked at the different
applications for these Social Security numbers. And you
looked at the evidence that was submitted to support like the
dates of birth and that type of thing, the things at the
bottom of the page?
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A.
Yes, sir.
Q.
So on one of those we had a birth certificate from Ghana,
right?
A.
I don't recall that. I remember it mentioning a passport.
Q.
Right. That was the first one. The first one, the 1975
birthday, the first one there, it was supported by a passport
from Ghana, right?
A.
I believe that's correct, yes, sir.
Q.
Okay. And a passport from Ghana, we're relying on the
government of Ghana to get it right, aren't we?
A.
I don't know passports in Ghana or how they're issued.
Q.
Okay. Well, you do know -- obviously when looking at that
form, some officer, some United States government officer
looked at what he presented, the Ghanaian passport, and
decided to accept their word for it, right?
A.
Oh, the evidence listed is what was accepted to issue the
Social Security number, the thing at the bottom of the page.
Q.
Yes.
A.
That's what was accepted to issue the Social Security
number, yes, sir.
Q.
Right. So if the Ghanaian passport was wrong, the
Social Security number application is going to be wrong, isn't
it? If it's incorrect?
A.
If it's wrong, then the application would be wrong.
Q.
Correct?
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A.
Yes, sir.
Q.
So I'm guessing you, in your research, didn't go back and
look at the Ghanaian passport document yourself, did you?
A.
We don't have that in the Social Security Administration.
I was not able to pull it.
Q.
Okay. That would be probably maintained -- the original
records I guess would come out of Ghana, right?
A.
I believe so, yes, sir.
Q.
Okay. And I'm guessing you didn't go to Ghana to look at
those records?
A.
No, sir.
Q.
Okay. So when a Ghana -- when Ghana issued a passport and
they had a -- and they put a typo in that passport --
Mr. Torjagbo then, Delano now -- he's stuck with that passport
he comes to this country with, wasn't he?
Do you follow my question?
A.
I think so, sir. I'm trying.
Q.
Okay. If you --
A.
I want to make sure that I answer your question.
Q.
Okay. Let me say it again more clear. He gets a passport
from Ghana, it has a -- I want to make sure you understand my
hypothetical here.
He gets a passport from Ghana, it has a typographical
error for his date of birth. He comes to this country with
it. He presents it to the immigration officer there.
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He's locked into that passport, isn't he? He
can't -- he can't prove a different number at that point, can
he, or a different date of birth?
A.
If you're asking me to speculate, I can. You can -- in my
experience with passports, you can request a correction from
the country you come from to provide a corrected passport.
But in your hypothetical, I'm not sure how I can answer it.
Q.
You kind of did. So you could get a corrected passport at
some point, right?
A.
Again, I don't know Ghana.
Q.
Okay.
A.
But if there were some mistake on a passport, I would
imagine you can, but I don't know that process.
Q.
Okay. Well, in 2004, he presented the birth certificate
from Ghana with the 1979 birthdate, and he corrected the
information with -- with immigration, right, or Social
Security, I guess?
A.
In that block, I don't know if it was a birth certificate.
There were several things listed, but I -- I'm not sure
exactly what those were.
Q.
Okay. But they issued him, based on what he presented in
2004 or '5, the second number, he presented the evidence and
they issued him the Social Security number with the date of
birth 1979?
A.
Yes, sir.
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Q.
Okay. And you don't know really when he was born, do you?
A.
I don't know which date of birth is correct.
Q.
Or any -- you weren't there, right?
A.
I was -- no, sir.
Q.
Yeah. And you didn't go back and talk to his mom or
anything like that?
A.
No, sir.
Q.
Okay.
A.
Sorry.
Q.
And by the way, I'm kind of working backwards through what
you've testified to, so that's -- just so you know where I'm
going.
You talked about the different EIN numbers, right?
A.
Yes, sir.
Q.
And there are three that were associated with Kremkov and
Mr. Delano, three EIN numbers?
A.
Yes, sir.
Q.
And one of those numbers ended in 1377, correct?
A.
Was it 1337 or 1377?
Q.
I've got 1377.
A.
I believe you. I could look at it, but I believe you,
yes, sir.
Q.
Well, let's go ahead and look.
A.
I'm sorry, sir. All right. Do we know the number?
Q.
I might --
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MS. CONNORS: It should be Exhibit 5.
BY MR. FINLAYSON:
Q.
Exhibit 5 might help you.
A.
Sure. 1377.
Q.
Right?
A.
You were correct, yes, sir.
Q.
And that number was assigned in 2018, wasn't it, sir?
A.
I don't know when it was assigned.
Q.
Okay. Can you -- do you have any reason to believe it
wasn't assigned in 2018?
A.
I have no reason to believe that.
Q.
Okay.
A.
Either way.
Q.
Either way.
You testified about I guess Government's Exhibit 1,
the Secretary of State record, right?
A.
Yes, sir.
Q.
And the Secretary of State record shows when
Kremkov Industries was incorporated with the Georgia Secretary
of State, right?
A.
Yes, sir.
Q.
Companies do exist in other forms prior to being
incorporated, don't they?
A.
I'm not a business owner, but I -- I believe they can be.
Q.
Yeah. I mean, not all -- let me put it an even better
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way.
Not all businesses are incorporated, are they?
A.
I don't know that answer.
Q.
Okay. You never run into -- you've run into businesses,
mom-and-pop businesses that are not incorporated?
A.
If they have to file taxes, they have to be incorporated.
So if they're filing taxes, then I would think that they would
be incorporated, but I don't -- there's different versions of
corporations.
Q.
Or what if you're a sole proprietorship?
A.
That's a version, sole proprietorship, LLP, limited
liability, parternship, or LLC. It all depends on what
corporation you are.
Q.
But again if you're not incorporated, then you don't have
to be incorporated, do you? You could still be a business?
A.
I don't know. I believe so. I don't know, sir.
Q.
And you -- you talked about the -- and I guess the point
of this is the PPP loan application, and this is kind of where
you started, in fact, it doesn't require you to be
incorporated to get a PPP loan, it just requires you to be in
operation in the February deadline, right?
A.
I don't know.
Q.
You don't know?
A.
I don't know the rules for filing a PPP loan.
Q.
Okay. Didn't you testify about the PPP loan application?
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A.
That one was filed, yes, sir.
Q.
Okay. Okay. You went through the list of those -- the
77-page document with the employees, right?
A.
Yes, sir.
Q.
Now, that -- that's part of the loan application, right?
A.
Yes, sir.
Q.
And it isn't filed with your agency, you don't issue the
loan. It's the bank that actually receives and processes that
loan, right?
A.
The Social Security Administration does not issue the
loans.
Q.
Okay. And the IRS doesn't issue the loan?
A.
I don't -- I don't think so.
Q.
Okay. The loan application and that list, that document
that you went through, it is submitted to the bank, right?
A.
I don't know who -- I don't know the process, sir. I
don't know who it's submitted to.
Q.
You don't know where it goes? You don't know that that's
submitted to a bank?
A.
I never filed a PPP loan.
Q.
Okay. So that list of employees, you don't really know
where -- where it got submitted or who would review that?
A.
I know the government received it.
Q.
Eventually, obviously. Here we are.
A.
Yes, sir.
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Q.
But you don't know -- you don't know who -- I gather you
don't even know who filed it, who physically filed it?
A.
I know the name on the application and I know what --
what's on the document.
Q.
Okay. So you don't know that Mr. Delano actually filed
that himself, do you?
A.
I only know the name on the application.
Q.
Okay. And you don't know, I gather, who actually prepared
that list of employees, do you?
A.
No.
Q.
Okay. And I guess you don't know who at the bank actually
reviewed that list of employees, right?
A.
I don't know.
Q.
You went through a list of several names. Jason Bourne,
is that one of the names on the list?
A.
Yes, sir.
Q.
Charlie Brown, a name on the list?
A.
Yes, sir.
Q.
Karl Delano, that the name was on the list?
A.
Yes, sir.
Q.
You don't know that that's the same Karl Delano as my Karl
Delano, do you?
A.
I only know that it's spelled with a K and that it's Karl
Delano under the Kremkov Industries.
Q.
And none of those names on that employee list actually
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have Social Security numbers attached, do they?
A.
No.
Q.
And no dates of birth?
A.
No.
Q.
Just names?
A.
Yes, sir.
Q.
And is Charlie Brown a real person or a fake person?
A.
I know one that is fake, but I don't know if there's
somebody actually named that in the country.
Q.
So you know the character, the Charles Schulz lovely
character, Charlie Brown.
But there might be actually somebody else named
Charlie Brown?
A.
There could be.
Q.
And we know there was a Gene Hackman, but he's dead,
right?
A.
Yes.
Q.
Okay. But you didn't actually dig into those names to
make sure that they -- you didn't have anything to work with.
You didn't have their Social Security numbers at all,
right?
A.
I did not have the Social Security numbers, no. No, sir.
Q.
And the same for -- we've got Monica Sweeten, right?
A.
Yes, sir.
Q.
And did you have her Social?
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A.
Not on the application.
Q.
Okay. Bruce Willis, same?
A.
Not on the application.
Q.
Okay. And again, you don't know who prepared that list?
A.
No, sir.
Q.
Okay. You did talk about the tax return, 05, it's in the
0540, right? Mr. Delano filed it, right? At least that's the
name -- Torjagbo's name is on the thing, on the return, right?
A.
Yes, sir.
Q.
And you testified the amount -- and we can look, if you
need to, because it's kind of a long number.
The amount here requested in his return is
$3,373,441.
A.
Do you know what exhibit number that was?
Q.
I want to say it's 201. Is that right?
MS. CONNORS: I'm sorry, which one was that?
MR. FINLAYSON: I want to say it's 201 or 202. Let's
have a look.
BY MR. FINLAYSON:
Q.
It is 201. Huh.
A.
Yes, I'm looking at it.
Q.
And so the amount he requested in that return, it's
$3,373,441, correct?
A.
Yes.
Q.
And can you tell me why they paid him $7,000 less than
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that amount requested?
A.
I don't work for the IRS. I don't know.
Q.
Okay. You testified about a company based in a foreign --
in a foreign country, right?
She asked you some questions about let's say a
goldmine in a foreign country. And the employees there,
whether or not they would file tax -- have to file tax
documents, such as tax returns, or whatever in this country if
they're U.S. citizens working there.
Do you remember that general topic?
A.
I remember the general topic, yes, sir.
Q.
Now, there is a whole -- and maybe you can answer it,
maybe you can't -- there is a whole notion of foreign-earned
income, right?
A.
Yes. There's a rule with expats and -- or not just
expats, I'm sorry, people working internationally, there's a
certain income threshold, but I don't remember what it is.
Q.
Okay. But if they are under that threshold, they don't
have to file those taxes in the U.S., correct?
A.
I don't remember the exact rules. I only knew that in my
personal capacity, not that I've ever done it, but I don't
know it -- like I don't work for the IRS, so I don't know
exactly what that is.
Q.
Okay. But it's a thing, right?
A.
Yes, sir.
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Q.
Okay.
MR. FINLAYSON: If I may have one moment, Your Honor.
THE COURT: Yes.
MR. FINLAYSON: Nothing further, Judge.
THE COURT: Okay. Any redirect for this witness?
MS. CONNORS: Very brief, Your Honor.
THE COURT: Sure.
REDIRECT EXAMINATION
BY MS. CONNORS:
Q.
Agent Fowler, if someone was applying to get a new
Social Security number based on being a victim of domestic
abuse, would the application for that new Social Security
number still need to be accurate?
A.
Yes.
Q.
Would that application still have to be signed under
penalty of perjury that it was accurate?
A.
Yes.
Q.
And if you qualified to get a new Social Security number
due to domestic abuse, would there be a reason not to answer
the application questions truthfully?
MR. FINLAYSON: Objection.
MS. CONNORS: I can rephrase, Your Honor.
THE COURT: Hold on. Hold on.
I'm going to sustain the objection and ask you to
disregard that last question.
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Remember, I told you sometimes I'm going to do that.
I'm going to ask you to disregard that last question.
You can go at it a different way, if you want.
MS. CONNORS: Thank you, Your Honor.
BY MS. CONNORS:
Q.
The application for the second Social Security number
here, is there anywhere on that that indicates it is being
reissued -- that a new Social Security number is being issued
because an individual was a victim of domestic abuse?
A.
No.
Q.
And, Agent Fowler, you talked a little bit earlier today
about forms that are prepared by employers related to the tax
withholdings, W-2s -- I'm sorry, W-2s, W-3s and W-4s; is that
right?
A.
Yes.
Q.
Now, in terms of those forms, are they -- is an employer
submitting that related to their specific employees?
A.
Yes.
Q.
And do those forms usually have the Social Security number
of the employee on it?
A.
Yes.
Q.
And why is that?
A.
To identify the employee. And so that it can track their
wages throughout their lifetime so that they can be -- the
calculation for their Social Security retirement income is
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calculated properly.
Q.
So is it the case that just because -- if 493 people all
work for the same company, can they potentially have different
Social Security taxes, different Medicare taxes, different
wages?
A.
Yes.
Q.
So is it something that is important to make sure that
those -- that that information is reflected under the specific
employee as well.
A.
That's correct, yes.
Q.
But to make sure it's clear, those forms are prepared by
the employer?
A.
Typically in W-2s, especially in W-2s, the forms are
filled -- are created by the employer, just like you get your
W-2 at the end of the year.
And they would have already been -- or they are in
the process of being submitted either through the tax preparer
or through the business services online agreement, if the
employer has one direct with the SSA. Those are really the
two ways that they get submitted.
Q.
Okay. So to submit any kind of Social Security tax,
Medicare tax on behalf of a specific employee, would that
specific employee, their Social Security number need to be
available to the employer?
A.
Yes.
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Q.
Now, when we looked at the payroll, their -- you testified
there's no Social Security numbers on there. And there's not
a date of birth?
A.
Correct.
Q.
But in order to report the information on that payroll
related to Social Security tax and Medicare tax for the 493
employees that were listed, it would have been
Kremkov Industries that had to have those Social Security
numbers?
A.
Yes.
MS. CONNORS: Thank you.
MR. FINLAYSON: Just a quick follow-up.
THE COURT: Sure.
RECROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
So correct me if I'm wrong, but we're talking -- the main
thing we're talking about here is the -- or a main thing we're
talking about is the PPP loan application, right?
A.
That's one of the things, yes, sir.
Q.
Right, right.
A.
Yes, sir.
Q.
I mean, he -- my client is not charged with, you know,
these things about the FICA withholdings or that sort of
thing, that's -- that's not what he's on trial for, it's the
PPP loan application, right?
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A.
I don't know the indictment.
Q.
Okay. On the PPP loan application, there's a payroll with
493 names that's submitted, and none of those names have
Social Security numbers attached to them, right?
A.
Correct.
Q.
And none of those names have dates of birth attached to
them, correct?
A.
Correct.
Q.
We don't know who those people are, do we?
A.
No.
Q.
And the bank was totally fine with that, weren't they?
A.
I can't speak for the bank, sir.
MR. FINLAYSON: No further questions.
THE COURT: Okay. Is this witness excused?
MR. FINLAYSON: Yes, sir.
MS. CONNORS: Yes, Your Honor.
THE COURT: Agent Fowler, you're good to go. Thank
you very much.
THE WITNESS: Thank you, sir.
THE COURT: All right. Next witness.
MS. CONNORS: Your Honor, the government calls
Kobina Oppong.
- - -
KOBINA OPPONG,
A witness herein, having been first duly sworn, was examined
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and testified as follows:
- - -
COURTROOM DEPUTY: Thank you.
For the record, will you please state and spell your
first and last name?
THE WITNESS: K-O-B-I-N-A is my first name.
O-P-P-O-N-G is my last name.
COURTROOM DEPUTY: Thank you.
COURTROOM SECURITY OFFICER: You can be seated.
DIRECT EXAMINATION
BY MS. CONNORS:
Q.
Good afternoon, sir. Can you tell us, do you currently
live in the Atlanta area?
A.
Yes.
Q.
Okay.
THE COURT: Scoot up so you can talk into that
microphone. Thank you.
THE WITNESS: Okay. Yeah.
MS. CONNORS: And may I approach, Judge? I'll move
it down a little bit.
BY MS. CONNORS:
Q.
There we go.
A.
Oh okay.
Q.
And, Mr. Oppong, how long have you lived in the Atlanta
area?
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A.
Almost 30 years.
Q.
And what do you do for a living currently?
A.
I'm a Realtor and I own an ATM company as well.
Q.
Okay. And where did you grow up before coming to the
Atlanta area?
A.
In Ghana.
Q.
And when did you move to the United States? Was that 30
years ago or even longer?
A.
No, late '90s.
Q.
Okay. And since then, have you been here?
A.
Yes.
Q.
In the U.S.?
A.
Yes.
Q.
Okay. Now, Mr. Oppong, do you know Carl Delano Torjagbo?
A.
Yes.
Q.
And do you see him in the courtroom?
A.
Yes, he's right there (indicating).
Q.
Okay. And just so we're clear, who are you pointing to?
A.
Oh, Carl Torjagbo.
Q.
Okay.
A.
Sorry.
Q.
That's okay. Now, do you call him Carl?
A.
No. No. You know, in Ghana we have nicknames, so I call
him Majingo.
Q.
Okay. Did you know him primarily as Carl Torjagbo, that
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last name?
A.
Yes.
Q.
Okay.
A.
At school, yes.
Q.
And are you aware that he changed his name at some point?
A.
Yes. Yes, ma'am.
Q.
Okay. Are you aware that it's now Karl Lucius Delano?
A.
Yes, ma'am.
Q.
So if I refer to a Mr. Delano during your testimony, will
you know who I'm talking about?
A.
Yes, ma'am.
Q.
Okay. Thank you. Now, I think you just mentioned that
you -- you know Mr. Delano. How do you know him?
A.
Well, we were in boarding school together since the age of
12.
Q.
Okay. And where was that boarding school?
A.
Mfantsipim School in Cape Coast in Ghana.
Q.
Okay. And now can you explain, is that where you first
met him was when you were in the boarding school?
A.
Yes, ma'am.
Q.
Okay.
THE COURT: Hold on. Let her finish her question
before you answer. Okay? I don't want y'all talking over
each other. It's hard for our court reporter. Okay?
THE WITNESS: Okay.
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THE COURT: Thank you.
BY MS. CONNORS:
Q.
So age 12, was it age 12 when you first met?
A.
Yes, ma'am.
Q.
Okay. And so how long have you known him, how many years
approximately?
A.
38 years. I'm 50 now.
Q.
You're 50 now?
A.
Yes.
Q.
And do you know how old the defendant is?
A.
He's around my age.
Q.
Okay. Now, when you were in school in Ghana, were y'all
in the same grade or you were in -- or were you in different
grades?
A.
Same.
Q.
Okay.
A.
Same grade.
Q.
And can you explain -- and in terms of school in Ghana, is
it -- I believe -- do you have kids who are in school here?
A.
Yes, ma'am.
Q.
Okay. So do your kids here, do they essentially have the
same age peers going into the same grade level as them?
A.
So in Ghana it's different. I would say it's slightly
different.
Q.
Okay. Can you explain how it's different?
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A.
So you cannot be more than a couple of years older or
younger, so for example I'll be 12 years -- I was 12 years old
when we met, so that means that Carl -- you know,
Carl Torjagbo cannot be like 8 or 9 or even 10. He -- he will
be 11, 12 or 12, for the most part, yes.
Q.
Okay. So you're essentially around the same age. You
might be -- you know, the person could be a little older or a
little younger, but not substantially older or younger?
A.
Yes, ma'am.
Q.
Okay. And I think you probably just answered one of my
questions.
Could Mr. Torjagbo have been four years younger than
you and in the same grade level?
A.
No, ma'am.
Q.
Now, can you describe what the boarding school was like in
Ghana? Is this where you would stay at school like in a dorm
or do you go home every day?
A.
No, you stay in a dorm. And on vacation, you go home.
Q.
Okay. And so in terms of the particular boarding school
that you were in when you met him, did you both go like
through graduation or was there a different timeframe?
A.
Yes, we -- yes. About 1992, we went through graduation in
1992.
Q.
Okay. And so did you essentially graduate together?
A.
Yes, ma'am.
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Q.
Now, after boarding school, did you -- it appears that you
continued to stay in touch; would that be right?
A.
Yes, ma'am.
Q.
Now, you talked about moving here to the United States.
Were you still in touch with Mr. Delano up until the
time that you moved to the United States?
A.
Yes, ma'am.
Q.
Okay. And did you stay in touch after you moved to the
United States?
A.
Yes, ma'am.
Q.
Okay. Now, was there a time -- do you -- that Mr. -- that
you were aware that Mr. Delano also moved to the United
States?
A.
If I can recollect, he moved here before I did, actually.
Q.
Okay. Now, did you have any idea of why he was moving to
the United States? Did he ever talk to you about it?
A.
No, ma'am.
Q.
Okay. So then when you came to the United States, did
y'all stay in touch at that point?
A.
Yes, ma'am, I went to visit him.
Q.
Okay. Where did you visit him?
A.
Florida.
Q.
Okay. Now, at that time, were you also living in Florida
or were you living somewhere else?
A.
No, I've lived -- I've lived in Georgia for the most part.
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Q.
Ever since you came here, you've been in Georgia?
A.
I lived in New York for probably like six months. And
then move to Georgia afterwards.
Q.
Okay. Now, at some point, did you end up -- since you
were here in Georgia, then was there a time where Mr. Delano
also was living in Georgia?
A.
Yes, ma'am.
Q.
Okay. Now, after he moved, was he also kind of in the
Atlanta area?
A.
Yes, ma'am.
Q.
Okay. Now, after he moved to the Atlanta area as well,
were you still keeping in touch and visiting sometimes?
A.
Yes, ma'am, from time to time.
Q.
Okay. And, Mr. Oppong, do you know if Mr. Delano is a
pilot?
A.
Yes, ma'am.
Q.
Okay. And have you spoken to him before about his work as
a pilot?
A.
Well, numerous times.
Q.
Okay. And now was there a timeframe where you believed he
might have been working overseas as a pilot?
A.
Yes, ma'am.
Q.
Okay. And do you know roughly when that time period was?
A.
So I would say it was prepandemic, so I'm thinking around
2017 to 2019.
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Q.
And did you know where overseas he might have been
working?
A.
Dubai.
Q.
Did you ever go visit him when he was in Dubai?
A.
No, ma'am.
Q.
Now, at some point, did you -- did Mr. Delano move back to
the United States?
A.
Yes, ma'am.
Q.
Was he in the United States -- in the Atlanta area at that
time?
A.
Yes, ma'am. I think Douglasville.
Q.
Okay. And what approximate timeframe would that have
been?
A.
So I think it was after the pandemic, after the lockdown.
Q.
Okay. Do you remember when the pandemic kind of hit, what
year?
A.
Yeah. So I'm thinking, hmm, early 2021.
Q.
Okay.
A.
That's -- I'm sorry. That's the best I can do.
Q.
That's okay. No problem.
Now, when he moved back to the United States, were
you talking to him and visiting him some?
A.
Well, it was just one time that he wanted me to show him
houses.
Q.
Okay. Can you tell us about that?
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A.
So when he came back, he called me and he came by my house
and, you know, he was like, hey, I want you to show me some
houses around $500,000.
And I was like, okay, but my wife is out of town so
I'll have to get my kids. And, you know, I said I can -- you
know, we -- as long as we can be done by 2:00.
So we just started from Cumming all the way to
Douglasville that day. And it was just one day that we did,
yeah.
Q.
Okay. So you were showing him houses?
A.
Yes, ma'am.
Q.
Did y'all look at multiple houses?
A.
Yes, ma'am, like around $500,000 range, yes.
Q.
And did y'all discuss at all how he was going to purchase
the houses that -- the house if he liked one of the ones that
you showed him?
A.
Not necessarily. I assumed that because --
MR. FINLAYSON: Objection.
THE WITNESS: Yeah, so...
THE COURT: I'm going to sustain the objection. You
can ask -- you can talk about what you did or what you saw or
what you said, but don't assume.
THE WITNESS: Okay.
THE COURT: But you can testify close to that if you
explain what you did. Okay?
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THE WITNESS: Okay.
BY MS. CONNORS:
Q.
So did y'all have any kind of specific conversations about
how he was going to purchase a house?
A.
He was going to pay cash.
Q.
Okay. And prior to that time, is that when you knew that
he was working as a pilot?
A.
Yes, ma'am.
Q.
Okay. Now, did he end up buying one of the houses that
you showed him?
A.
No, ma'am.
Q.
Did you later find out that he bought a house, something
that you didn't show him?
A.
Yes, ma'am.
Q.
Okay. And can you tell us about that, how you found out
that he bought another house?
A.
So I think I showed him the houses around March. And by
probably around May, he calls me out of the blue and said,
hey, guess what, I just bought a house. And he had previously
told me that he was going to get a house in Florida. He
changed his mind, and so he didn't -- he basically said that
he wasn't going to use me as a realtor any longer. And I
found that he bought the one house in Marietta.
Q.
Did you look up any information related to that house?
Q.
Yes, I did. Because I basically wanted to know how much
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it cost, how much I was going to make from my commission if he
had used me. And I got angry at him.
Q.
Why did you get angry?
A.
Because I'm like I wasted my time, you know, showing you
houses, and you just did not use me any longer.
Q.
Okay. And when you looked up information, do you recall
if there was an approximate price for the house that he
purchased?
A.
Like around $1.8 million.
Q.
Okay. And was that a good bit more than the price point
that you were looking at with him?
A.
Oh, yeah, that was way more. It was like $500,000 with
me.
Q.
Okay. And have you ever been to that house, the house
that he purchased?
A.
Multiple times.
Q.
And what's that house like?
A.
If I can recall, it's like an eight-bedroom house and it's
probably like 10,000 square feet.
Q.
Okay. Now, in terms of your conversations, you've had a
long history with Mr. Delano.
Did he talk to you about any other employment besides
being a pilot?
A.
No, ma'am.
Q.
And in terms of Kremkov Industries, is that a company that
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you're familiar with or have you heard that name before?
A.
Yes, ma'am.
Q.
Okay. And how are you familiar with Kremkov Industries?
A.
Because Karl told me about his company called
Kremkov Industries.
Q.
Okay. And when did that happen?
A.
That was around the time that he bought the house.
Q.
Okay. Now, before then, had you ever heard of
Kremkov Industries?
A.
No, ma'am.
Q.
And in addition to talking to the defendant about
Kremkov Industries, after he bought that house, was there
anything else that you ever saw related to Kremkov Industries?
A.
Can you say --
Q.
Okay. Yes. So -- well, let me ask this.
Did you ever do any research on Kremkov Industries?
A.
Yes, ma'am.
Q.
Okay. And why was that?
A.
It was because I had knew someone who wanted to build a
website for anyone I knew. And I had my website already, so I
decided that why not just -- so I just Googled
Kremkov Industries.
Q.
Okay. And when you Googled Kremkov Industries, was there
anything particular that stood out to you?
A.
It had only one information on there.
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Q.
Okay. And what was that related to?
A.
PPP loan.
Q.
And did you look at any of the kind of details that were
available related to that PPP loan?
A.
Yes, ma'am.
Q.
And did anything about that stand out to you?
A.
I think it -- it said that he had received about 9.4,
$9.5 million of PPP loan.
Q.
Okay. And was that surprising to you?
A.
Oh, very much. I mean, I think -- I mean, he's been my
friend since we're 12 years old, so -- and I've been at the
house so many times, so in my head I'm like, okay, it was a
lot.
Q.
Okay.
A.
I couldn't sleep that night.
Q.
Okay. Did you learn any information about number of
employees or approximately how much an average salary was
supposed to be with Kremkov Industries?
A.
So it was 493 employees, it was -- it's a $95,000 payroll
per person, if I can remember correctly. It was -- yes.
Q.
Okay. Now, after you saw this information related to this
PPP loan, did you talk to Mr. Delano about the PPP loan?
A.
Yes, ma'am, the next day.
Q.
Okay. Was that a conversation that was in person or it
was by phone?
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A.
In person.
Q.
Okay. And did you ask him about the loan?
A.
Yes, ma'am.
Q.
Okay. And what was -- what did y'all discuss?
A.
Oh, it was a lot. So I asked him specifically why -- the
reason why -- I told him I was -- excuse me -- the reason why
I was researching the company. And I said this -- for a
website. And I asked him why he didn't have a website.
And he -- he said he was dealing with goldmining and
you don't need a website, it's secretive. And he also said
that, you know, he would be -- like Kremkov was the big
company, like the -- what word should I use? He was going to
have other companies under Kremkov, which Dragonfly or
something like that would be underneath of that.
And so we had a long conversation about it. And
we -- we argued a lot throughout the whole conversation,
because he didn't -- he didn't want to hear me and I didn't
want to hear him.
Q.
Okay. And, I mean, why was that? Why were -- why were
you upset or why was --
MR. FINLAYSON: Your Honor, I've got an objection.
Maybe we need to take this matter up outside the presence.
THE COURT: Okay. Why don't you-all step out for a
second. Okay?
COURTROOM SECURITY OFFICER: All rise.
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(Whereupon, the jurors exited the courtroom.)
MS. CONNORS: Should the witness step out?
MR. FINLAYSON: Probably so, yes.
THE COURT: Hold on one second. Let's let them get
out first.
Okay. You can then head outside the courtroom and
just wait outside on the outside there. Okay?
THE WITNESS: Yes.
THE COURT: Thank you, sir.
Okay. What's the issue?
MR. FINLAYSON: Thank you, Judge.
Your Honor, my concern is this witness is sort of --
he's providing this -- first of all, there's a recording of
this conversation, but that's maybe not the point.
He is providing a narrative of his concerns, his
thoughts, he's summarizing his statements.
You know, arguably what Mr. Delano would say would be
a party admission in these environments, but it's almost kind
of like the issue with the interrogation as well. I don't
think he should be allowed to speculate or we don't need to
hear what he was thinking and what his -- his internal
monologue about, well, I thought that was -- and I went -- he
basically did his own investigation.
And I don't think that there's -- and there's a
hearsay aspect to this, if he's going and doing research and
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he's looking on the computer and he's seeing things and then
sort of telling the jury of these things he saw.
You know, some of these we don't dispute, but it
feels that it is -- I think the guts of it is it's a hearsay
problem in that he is being allowed -- it's also a
foundational problem where he is being allowed to testify
about his thought process when his thought process is not
relevant, it's not -- it's not good evidence, it's not --
it's -- it's one thing for him to be able to say pretty much
what Mr. Delano said. And that's what's bothering me about
this. And I apologize I didn't articulate that better.
THE COURT: That's okay. I think I get the idea.
Are we going to hear a recording of this conversation?
MS. CONNORS: No, Your Honor. We're trying to avoid
having to play a very lengthy conversation, recording of the
conversation, so I do think it's appropriate. I mean, the --
THE COURT: What was the question you were going to
ask him?
MS. CONNORS: The question that raised the objection
was why are you upset, which I think is something that's
relevant and that he would be able to say.
THE COURT: He's going to say something like I was
upset because I thought he was lying to me or something like
that.
MS. CONNORS: I'm -- I'm not sure exactly what he's
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going to say. I mean, I think he's going to say that he had
concerns and was worried about his friend.
THE COURT: Hold on. But let's be honest. You want
to put in the fact that he was worried about -- so far what
he's explained is that he confronted the defendant about this
loan. And the defendant said something about having a
goldmine that he wanted to keep secret. And he was going to
make other companies underneath that goldmine.
And you want to ask him why he got upset.
And he's going to say -- you expect him to say
something about suspicion about the defendant's explanation.
MS. CONNORS: What -- I think he's going to express
some kind of concern about that the defendant may have gotten
this loan, yes, for -- based on incorrect information.
THE COURT: Okay. You should ask him what he said to
the defendant. Okay?
What did you say to the defendant.
Because I think Mr. Finlayson has a good point. His
suspicions aren't really relevant. What matters is what he
said to the defendant.
Okay?
MS. CONNORS: Okay.
THE COURT: I mean, his -- the jury -- maybe he's
just a suspicious guy. What matters is if he challenged him.
MS. CONNORS: Okay. And just to make sure that I can
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clarify, because it seemed like Mr. Finlayson's objection was
to that testimony. He wants it to only be that the witness
would be able to say what the defendant said. But I do think
that that would be difficult to play out without also being
able to ask him what he said to the defendant.
THE COURT: No, you can ask him what he said to the
defendant is what I'm saying.
MS. CONNORS: Okay.
THE COURT: What you asked was why were you upset or
why was he upset, the answer to which has to be something like
I didn't believe him. And that's fine. But the jury doesn't
need to know that, right?
The jury needs to know what did you do next. Well, I
argued with him. What did you argue about? I argued about
whether or not he was telling the truth. I thought there was
some fraud. What did you do? I said this. What did he do?
I said that. What did you do next? I did that.
And let me be clear. I think you can typically ask a
witness some information about why they did what they did. I
had my suspicions because I've known him forever and he had
never owned a goldmine. I never heard him say anything about
being in the goldmining business, let alone having $9 million.
And if you want to ask him those questions, you can ask him
those specific questions, and you can even lead him in some
way.
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MS. CONNORS: Okay.
THE COURT: But you're asking a guy really open-ended
questions, which might very well have him just start spouting
off all of his individual suspicions. Okay?
MS. CONNORS: Okay. Yes, Your Honor.
THE COURT: Am I helping you with that at all?
MS. CONNORS: I think so.
THE COURT: I don't want to make it more confusing,
but I would like you to be like why were you confronting him
about that.
MS. CONNORS: Okay.
THE COURT: What was it that you didn't understand?
What was it that he said that you didn't believe? Why didn't
you believe that? I think all of that is fair.
But just an open broad thing that he just may go off
into some long-winded explanation is not appropriate. Okay?
MS. CONNORS: Okay.
THE COURT: And if you think he's saying something
that's inappropriate, we'll stop it again. Okay?
But I do think that you're allowed to say you knew
this guy, you've known him all your life.
And one night you heard about Kremkov Industries and
$9 million and you couldn't sleep. And so the next day you
went over there and you started asking questions.
I think he's allowed to say if he wasn't getting
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answers that he thought were correct, given what he knows
about him. All right?
MS. CONNORS: Okay. Okay.
THE COURT: And I'm assuming the jury is going to
hear that this was recorded, so...
MR. FINLAYSON: And I'm struggling greatly with that,
because I've -- I don't really want to sit here to hear it,
but there is a part of me that it's tempting to -- at some
point, it's going to be better to play the recording than to
not. But I haven't quite crossed that line yet.
THE COURT: Well, we're not in the process so far in
this case of moving quickly.
MR. FINLAYSON: Thanks.
THE COURT: Not for anybody's fault, but...
MR. FINLAYSON: Yeah.
THE COURT: But certainly speed has not been an
objective of today, right?
MS. CONNORS: And, Your Honor, I -- just to point out
on that topic, this witness has an unmoveable conflict
tomorrow. He's got two children who are racing in the junior
olympics, so our goal has been to try to make sure that he can
get off the stand today because he does have that issue.
THE COURT: Okay. All right. Do you want to bring
them back in?
Have I helped you clarify where the lines are?
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MS. CONNORS: I think so, Your Honor.
MR. FINLAYSON: Thank you.
THE COURT: Come on back up. Yes, sir. Come on in.
I hear you've got kids running in a race tomorrow?
THE WITNESS: Yes, sir. Yes, sir.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
COURTROOM SECURITY OFFICER: Be seated.
BY MS. CONNORS:
Q.
You can go ahead and sit back down. Thank you.
Okay. So, Mr. Oppong, to make sure that we're clear,
did you specifically talk to the defendant about the PPP loan?
A.
Yes.
Q.
Okay. And why did you talk to him about the PPP loan?
A.
Because I was trying to make sure that what I read was
true or not.
Q.
And in regards to the business, what is it that he told
you was the business of Kremkov Industries?
A.
A mining company.
Q.
And prior to that, had he ever mentioned a mining company
before?
A.
No, ma'am.
Q.
Had Mr. Delano ever talked to you about having hundreds of
employees?
A.
No, ma'am.
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Q.
Do you recall if you specifically asked him about the
employees of Kremkov Industries?
A.
I don't know, are you talking about the same day that we
had a conversation or previously?
Q.
Yes. Yes.
A.
No, we didn't talk about that.
Q.
Okay. Do you recall if you asked him about the average
salary of the employees for Kremkov Industries?
A.
No, ma'am.
Q.
Okay. Now, in terms of any other types of businesses, had
the defendant talked to you about any other businesses that he
owned or wanted to operate?
A.
Logistics company.
Q.
Okay. And now in terms of the logistics company, at the
time that you were talking to him about the PPP loan, was that
company -- what was the status of that company?
A.
He said he was about to start it.
Q.
Okay. So just about to start it, I'm sorry, is that what
you said?
A.
Yes, ma'am.
Q.
Okay. Now, at any time during your history of knowing the
defendant, did he talk to you about paying millions of dollars
to employees every year?
A.
No, ma'am.
Q.
And in terms of after this conversation happened about the
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PPP loan, did you know if Mr. Delano was buying anything like
vehicles or trucks?
A.
No, ma'am. Before the PPP loan?
Q.
No, after.
A.
Oh, yes, ma'am.
Q.
Okay. And what are some examples?
A.
Tractor-trailer trucks.
Q.
Okay.
A.
Personal vehicles.
Q.
Okay.
A.
And so --
Q.
Did you ever ride in any of those personal vehicles?
A.
No, ma'am.
Q.
Okay.
A.
I mean, I sat in it when one of them -- when the first one
came in, but I never rode in it.
Q.
Okay.
A.
I take it back. The day of the -- when we had the
conversation, we drove to his office, so yeah.
Q.
Now, that office, was that somewhere that you had been
before that day?
A.
Not that day. I had been previously, previous days, but
not -- that specific day was in the morning, so I went to his
house and then we went to the office.
Q.
And do you recall, were you ever at that office before the
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PPP loan?
A.
No, ma'am. That was my first time in the office, around
that period of time.
Q.
Okay. So do you know if he had that office before the
PPP loan?
A.
No, ma'am.
THE COURT: No, you don't know? Or, no, he didn't?
THE WITNESS: No, he didn't.
THE COURT: Okay.
MS. CONNORS: Thank you.
BY MS. CONNORS:
Q.
Okay. And did you ever -- you've mentioned one of the
vehicles that you saw. Were there any other vehicles?
A.
Yes, ma'am.
Q.
Do you remember any of them?
A.
He had a white BMW and then he had a Range Rover.
Q.
Okay. In terms of those vehicles, were these his
vehicles, you saw them with him?
A.
Yes, ma'am.
Q.
Were those different vehicles than he had before the
PPP loan?
A.
The BMW was before.
Q.
And let's see. And just to clarify one thing, you said
that you were 12 years old when you met the defendant and
you're around 50 now? What year were you born in?
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A.
1975.
MS. CONNORS: I think that's it.
Thank you, Your Honor.
THE COURT: Any cross-examination.
MR. FINLAYSON: Yes, sir, briefly.
CROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
Mr. Oppong, how are you, sir?
A.
Good. How are you?
Q.
Now we've spoken before, right?
A.
Yes, sir.
Q.
We talked on the phone for quite awhile?
A.
Yes, sir.
Q.
And you're testifying that you met Karl in Ghana when you
were kids?
A.
Yes, sir.
Q.
And you're saying you guys are the same age approximately?
A.
Yes, sir.
Q.
Really?
A.
I mean, I look good, I mean.
Q.
Okay. And you're 50, right?
A.
Yes, sir.
Q.
All right. You weren't born in Ghana, were you?
A.
Yes, sir.
Q.
You were born in Ghana?
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A.
Yes, sir.
Q.
Not in Jamaica?
A.
No, sir.
Q.
What's your date of birth?
A.
April 15, 1975.
Q.
Tax day?
A.
Sorry. What did you say?
Q.
Tax day?
A.
Oh, yes. Tax day, yes, that's it.
Q.
So when you came to this country, did you come in with a
Ghanaian passport?
A.
Yes, sir.
Q.
Okay. And are you -- did you -- did they get all of your
documents right when you came into this country?
A.
Yes, sir.
Q.
Okay. You and I talked about this a little before.
Is it common that Ghanaian documents aren't always
right when you come out?
A.
Yes, sir.
Q.
Okay. And --
A.
Sometimes.
Q.
Sometimes. And people coming out of Ghana, sometimes
their paperwork gets messed up and they end up with the wrong
birthdate?
A.
Yes, sir.
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Q.
You've seen that happen?
A.
Yes, sir.
Q.
Now, you were with -- you said you met Karl in the
secondary school, right?
A.
Yes, sir.
Q.
Okay. So not elementary school?
A.
No, sir.
Q.
Not second grade?
A.
No, sir.
Q.
Okay. He -- you knew he was a pilot, right?
A.
Yes, sir.
Q.
You knew he worked in Dubai for several years, right?
A.
A few years.
Q.
And you lost touch with him when he was in Dubai, right?
A.
Yes, sir.
Q.
You never went and visited him there?
A.
No, sir.
Q.
You don't know what he was doing over there, do you?
A.
He told me he was flying planes.
Q.
All right. But you didn't go and see what he was doing,
right?
A.
No, sir.
Q.
Okay. You don't know what business ventures he got into
while he was in Dubai, do you?
A.
No, sir.
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Q.
You showed him some -- are you all right?
A.
I'm just trying to get some water. Thank you. Go ahead.
Q.
You showed him some houses on one day?
A.
Yes, sir.
Q.
And he, to put it probably in a real way, he went around
your back, right?
A.
Yes, sir.
Q.
And you were mad about that, right?
A.
Yes, sir.
Q.
Because he didn't use you for his agent to purchase a
house, right?
A.
Yes, sir.
Q.
And you went to confront him about these things, right?
A.
Yes, sir.
Q.
And your main focus was you were trying to get him to make
a website, right?
A.
Yeah. Yes, sir.
Q.
You had a friend who was in the website business and you
were trying to get Karl to make a website for Kremkov with
your friend, right?
A.
Yes, sir.
Q.
Were you going to get a piece of that money?
A.
No. I think you're conflicting two things.
Q.
Okay. Tell me.
A.
So you're talking about when I confronted Karl, I
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confronted Karl about when he bought the house. I thought
that's what you were talking about. But, yeah, so I didn't
know you were talking about a website.
Q.
Let's go to the website day.
A.
Okay.
Q.
Do you remember that day where you tried to get him to buy
a website or you tried to get him to make a website?
A.
Yes. Yes.
Q.
You recorded that conversation, right?
A.
Yes.
Q.
Like an hour long?
A.
45 minutes.
A.
Yes.
Q.
Where you're trying to get Karl to buy a website for
Kremkov Industries, right?
A.
No.
Q.
You weren't encouraging him to buy a website?
A.
I was telling -- I was -- I didn't -- okay. So I was
telling him he needs a website. But I wasn't trying to
like -- and I kept telling him in a very -- if you can -- if
you listen to it, I said I'm not trying to tell you what to
do, but when I Googled, it was only PPP loan document but at
least you need a website.
Q.
Okay. And Karl was flatout no, I didn't need a website,
right?
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A.
Exactly.
Q.
He said you don't put your address to where your hidden
goldmine is in Ghana. You ain't going to put that on a
website, right?
A.
He didn't say anything about an address. He said it's a
secret company, you don't put it on --
Q.
So it's a secret location, right?
A.
He said goldmining is normally a secret, so you don't put
it online.
Q.
Did you go look at other gold company websites?
A.
No, I didn't care about that.
Q.
You didn't care. You didn't go that deep?
A.
No.
Q.
Okay. So you put this idea out there and he flatout
refused. He said I will not need a website for the goldmine,
right?
A.
Yes, sir.
Q.
You thought it would look better if he had a website,
right, you thought that would be better?
A.
I mean, it's -- we live in a digital word, like, and I
told him on the -- you know, throughout the conversation like
everybody has a website.
Q.
Okay. And he said I maybe -- I'll make a website for the
trucking company when that's off the ground?
A.
Yes, he said that.
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Q.
That's what he told you?
A.
Yes, sir.
Q.
Okay. He never said to you or told you, hey, man, I don't
have a goldmine, it's all fake, right? He never said nothing
like that, did he?
A.
No.
Q.
Okay. He told you he had a goldmine?
A.
Yes, sir.
MR. FINLAYSON: That's all my questions, Judge.
THE COURT: Is the witness excused or any redirect?
MS. CONNORS: Very briefly.
REDIRECT EXAMINATION
BY MS. CONNORS:
Q.
Now, Mr. Oppong, what was the context of why you were
recommending the website?
A.
Basically, because everybody has a website. And I
specifically said that in the conversation that if anybody,
including his neighbors, ask him what he did for a living and
they Google it, everybody in the world will see that it's --
it's PPP, it's right there, it's -- my 13-year-old daughter
can even see that.
Q.
Okay. And at that point -- up until you had this
conversation, you weren't aware of anything else related to
Kremkov Industries beside the PPP loan?
A.
No, not at all. I had no idea -- I had no idea about a
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PPP loan.
Q.
And you also -- you did not ever have a conversation with
him prior to that where he said he had a, you know, lucrative
goldmine in Ghana?
A.
No, ma'am.
MS. CONNORS: Thank you.
MR. FINLAYSON: Very quickly.
RECROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
You just said you didn't know about his PPP loan. But you
had a PPP loan before this, right?
A.
Yes, sir.
Q.
You got like a $20,000 PPP loan, right?
A.
Yes, sir.
Q.
And your loan was forgiven by the government, right?
A.
There's two loans that I had. One of them was forgiven,
one of them was not. I'm still paying $96 a month for it.
Q.
Okay. Which one was forgiven then?
A.
There's -- there's -- I don't remember the name of the --
SBA has different -- as you know, has different programs. One
of them, the pandemic loans you can request to -- for it to be
dissolved, and I did that through my CPA, so that one was
dissolved, but the PPP loan, the $20,000, I'm paying it, 96
bucks a month.
Q.
So which one -- how much was the one that was forgiven?
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A.
That one was also 20 grand, like 19 and some change.
Q.
So you had $20,000 you asked the -- I guess it's the bank,
really, you asked the government, but then the loan came from
the bank, right?
A.
Of course, yeah.
Q.
Yes. So you asked for that one to be forgiven. You did
not have to pay the bank back that $20,000, right?
A.
That one that is forgivable --
Q.
Right.
A.
-- in terms of -- again, it was all related to COVID, and
there was so many programs at the time, so I was able to use
two different -- two different times, by the way. Because, I
mean, as you are aware, the CARES act and also the -- I can't
remember the name of it, but like, you know, there were two
different government programs. And one was the one president,
the other one was a different president, so...
Q.
So to get forgiven, you had to -- you had to actually ask
for that, right, you had to request that they forgive the
loan?
A.
Of course.
Q.
And if you didn't request they forgive the loan, then you
would have to pay it back?
A.
Yes, sir.
MR. FINLAYSON: Nothing further, Judge.
MS. CONNORS: Your Honor, very briefly.
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FURTHER DIRECT EXAMINATION
BY MS. CONNORS:
Q.
Mr. Oppong, your 19, $20,000 PPP loan, how many employees
did you have?
A.
Just me.
MS. CONNORS: Thank you.
THE COURT: Okay. The witness may be excused?
All right, sir. Thank you very much. I hope you
have a nice day.
THE WITNESS: Thank you.
THE COURT: All right. Do you have another witness
you want to get into today?
MS. CONNORS: We do have one short witness, if it is
possible.
THE COURT: What do you think?
JURORS: Yeah.
THE COURT: Yeah. All right. Okay. Let's go. I
like that decisiveness.
MS. CONNORS: They're walking around. I apologize,
Your Honor.
COURTROOM DEPUTY: Please raise your right hand.
- - -
MONICA SWEETEN,
A witness herein, having been first duly sworn, was examined
and testified as follows:
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- - -
COURTROOM DEPUTY: Thank you.
For the record please state and spell your first and
last name.
THE WITNESS: Monica Sweeten, M-O-N-I-C-A,
s-W-E-E-T-E-N.
COURTROOM DEPUTY: Thank you. You may be seated.
DIRECT EXAMINATION
BY MR. EVERT:
Q.
Good afternoon, Ms. Sweeten, where do you live?
A.
In Houston.
Q.
And how long -- is that Houston, Texas?
A.
Houston, Texas, yes.
Q.
And how long have you lived in Texas?
A.
All my life. I mean, half of my life, since I moved to
the states, so about 19 years or so.
Q.
And what is your job?
A.
I'm an airline pilot.
THE COURT: I'm sorry, an airline pilot?
THE WITNESS: Yes, sir.
THE COURT: Who do you fly for?
THE WITNESS: For American Airlines.
THE COURT: Okay. Thank you.
THE WITNESS: Um-hmm.
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BY MR. EVERT:
Q.
Okay. And how long have you been a pilot?
A.
Since I was 17, but for -- for America, two and a half
years. And I -- before that, I worked for another airline
called Mesa Airlines.
Q.
And do you have a rank as a pilot?
A.
Yes. Well, you kind of like -- I'm a first officer right
now, but when I was with Mesa, I was a captain.
Q.
And did you know an individual by the name of Karl Delano
or former Carl Torjagbo?
A.
Yes.
Q.
Which name do you know him by?
A.
Both.
Q.
Okay. And if I refer to him as Mr. Delano, we'll know
that we're talking about the same person?
A.
Yes, sir.
Q.
All right. So do you see Mr. Delano in the courtroom
today?
A.
He's there (indicating).
Q.
What -- could you identify him by something he's wearing?
A.
He's wearing a black suit with a white shirt.
MR. EVERT: Could the record please reflect that she
identified the defendant?
THE COURT: Any objection?
MR. FINLAYSON: No.
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THE COURT: Okay. She has. Thank you.
BY MR. EVERT:
Q.
So how did you meet Mr. Delano?
A.
We met at Mesa Airlines. We basically was in training.
We went to training together at Mesa Airlines.
Q.
And about how long ago was that?
A.
That was in 2017.
Q.
And you had mentioned that you don't work at Mesa Airlines
anymore?
A.
No. I left when I went to American Airlines two and a
half years ago. So when I -- yeah, basically I went from Mesa
to American.
Q.
And do you know if Mr. Delano still works for Mesa
Airlines?
A.
I don't think so.
Q.
Did you remain friendly with him after you -- you both --
you stopped working together?
A.
Yeah. We used to talk once a year or so, just to keep in
touch, but not like talk every month or anything like that,
but just -- just keep in touch.
Q.
Now, would you mind looking in your binder at Government's
Exhibit 101.
MR. EVERT: And if we could pull that up on the
screen, that might be easier.
THE COURT: You can look at this screen.
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BY MR. EVERT:
Q.
You can just look at the monitor, too, it will probably be
easier.
A.
Okay.
MR. EVERT: And if we could turn to Page 81 please.
BY MR. EVERT:
Q.
Can you read the name -- what the title of this document
is just at the top there?
A.
At the top. Oh, the top, the date?
Q.
Just the title of the document.
A.
Payroll journal summary report.
Q.
And is this for --
A.
Kremkov Industries.
Q.
Great. And what's the date range on this?
A.
01/01/2020 and 12/31/2020.
Q.
Got it. And have you ever worked for a company called
Kremkov Industries?
A.
No.
Q.
Have you ever worked for Karl Delano in any capacity?
A.
No.
Q.
Have you ever worked for a mining company?
A.
No.
Q.
Have you ever been to Ghana?
A.
No.
MR. EVERT: Turning to Page 118, in the middle of the
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page, if we could blow up Monica Sweeten's name.
BY MR. EVERT:
Q.
Is that your name there?
A.
Yes.
Q.
And in the first column next to your name, it says
hours/quantity, I believe it says 1,852.47.
Did you work 1,852 hours for a company called
Kremkov Industries in 2020?
A.
No.
Q.
And where were you working in 2020?
A.
In 2020, I was still working at Mesa Airlines.
Q.
And was that a full-time job?
A.
Yes.
Q.
And under gross, it says $92,623.50.
Were you paid $92,000 -- or about $92,000 by
Kremkov Industries in 2020?
A.
No.
Q.
And under SIT, it says negative $4,817.79.
What state did you live in in 2020?
A.
In Texas.
Q.
Does Texas have state income tax?
A.
No.
Q.
Did you ever give Mr. Delano permission to claim that he
was -- that you were his employee?
A.
No.
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Q.
Did you ever give anyone else permission to say that you
worked for Kremkov Industries?
A.
No.
Q.
Have you ever had any financial dealings with Mr. Delano?
A.
No, except for in -- when I was purchasing a house back --
like two and a half years ago, I mention to him -- we just
have one of those days, one conversation, and I mentioned to
him that I -- I saw a house that I really like and it's -- it
was pretty, it was like what I was looking for.
Then I -- but I was going to close, but I have
basically a savings of the amount I need, but we have in cash,
so he's like -- they wanted like a record of four -- which I
can prove everything, but basically I have the -- we have to
have it in the bank like four months or so, so by the time
that we will have it in the bank, the house would be gone.
So I was talking to him about that. And he say I can
help with you that. So basically, if you give me the cash, I
send it back to a market company and then --
Q.
Okay. So just we can unpack that. You were going to
close on a house. Was the house in Houston?
A.
Yes, sir.
Q.
And in order -- as part of the closing, you needed to send
how much money for the closing?
A.
$40,000.
Q.
And of that 40 -- and you and your mother had that money
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in cash, but was it the bank or the Realtor wasn't willing to
accept that?
A.
The Realtor, me -- they want to do the loan.
Q.
Got it. And so Mr. Torjagbo -- or, sorry, Mr. Delano, he
had said that he could help you with that.
And did -- so did he, in fact, end up helping you
with that?
A.
He did.
Q.
So how did that -- how did that transaction work?
A.
So right after -- before the closing, me and my mom, we
came to Georgia and we gave the $40,000 in cash to him. So we
went to a bank and he deposited it in his account. And then
he -- we basically went to another bank and he wired the money
to the lender.
Q.
Okay.
A.
Exactly the $40,000 I gave him in cash.
Q.
Got it. So it was you giving him $40,000 cash, him wiring
that money to the lender?
A.
Yes.
Q.
So that wiring -- just to be perfectly clear, that wiring
of $40,000, that had nothing to do with you being an employee
of Kremkov Industries?
A.
No, no. That was my money, just my money, I give it to
him and he just --
Q.
Okay. And for the record, that also had nothing to do
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with you being an employee of him in any way?
A.
No.
MR. EVERT: No further questions. Thank you.
THE COURT: Cross-examination?
MR. FINLAYSON: Yes, sir. I'm going to ask for 101
back up and Page 118.
CROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
Mr. Sweeten, I have a few questions for you.
A.
Yes, sir.
Q.
First of all, you mentioned you've known Mr. Delano by
Mr. Delano and Mr. Torjagbo, right?
A.
Yes, sir.
Q.
Delano used to be his middle name or do you even know?
A.
I don't know.
Q.
It's not unusual to you that he's Mr. Delano?
A.
Um-hmm.
Q.
Were you ever like Instagram friends with him or something
like that?
A.
I think at some point, maybe just Facebook, but...
Q.
Facebook?
A.
Yeah.
Q.
He was Delano on Facebook, right?
A.
I don't remember.
Q.
Okay. So if I understand right -- let's go backwards.
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You -- you were buying a house in Houston?
A.
Um-hmm.
Q.
And you needed to make a down payment of $40,000, right?
A.
Correct.
Q.
And you and your mom had $40,000 in cash?
A.
Yes.
Q.
In Houston, right?
A.
Um-hmm.
Q.
I guess money maybe you and your mom had saved up over the
years?
A.
Yes, sir.
Q.
And you -- you couldn't -- they wouldn't take cash for the
down payment on the house?
A.
That's correct. That's because --
Q.
So you told Mr. Delano and he offered to help you, right?
A.
Um-hmm, yes, sir.
Q.
You flew all the way to Georgia with a bag of cash, right?
A.
Yes, sir.
Q.
Took it to the bank; is that right?
A.
That's correct.
Q.
And then he wired the money back to the lender so you
could buy your house?
A.
Correct.
Q.
Let's make it very clear, did he rip you off in any way?
A.
No.
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Q.
Did he hurt you or was it like -- was he helping or
hurting you in that situation?
A.
He helped me in that situation, yes.
Q.
Okay. And you got your house?
A.
Yes, sir.
Q.
Do you have still have it?
A.
Yes, sir, I'm paying.
Q.
Got it. Good. Good.
A.
Still paying.
MR. FINLAYSON: Okay. If we could see 101, Page 118,
the one we just saw. Okay. And then can we like zoom in on
her name, the whole line? And I say her name.
BY MR. EVERT:
Q.
So we have on this line -- you can see that?
A.
Yes, sir.
Q.
It says Monica Sweeten, right? Does that line have your
date of birth in there in any way?
A.
No.
Q.
Does it have your Social Security number in any place?
A.
No.
Q.
It's just a name, Monica Sweeten, right?
A.
Yes.
Q.
Is that correct? You've got to say it out loud.
A.
That's all I can see, yes.
Q.
It's just the same -- it happens to be the same name as
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yours, right? You've got to say it.
A.
Yes, sir.
MR. FINLAYSON: Okay. You can take it down.
BY MR. FINLAYSON:
Q.
Are you the only Monica Sweeten in the universe?
A.
I don't know.
Q.
Have you ever Googled yourself?
A.
No.
Q.
Okay. But you didn't work for Kremkov, right?
A.
No.
Q.
And you didn't pay taxes or have taxes paid for any of
that kind of work?
That document doesn't have your Social Security
number at all, does it?
A.
No.
Q.
Have you had any -- besides having to come all the way
across the country and do this, has the fact that the name
that's the same as your name, not necessarily you, but the
fact that that name is on there, has this caused you any
problems in the world, has your credit been messed up?
A.
No.
Q.
Has it hurt you in any way because -- because the same
name was on that piece of paper, besides having to come here?
A.
Well, it -- I don't think so, no.
Q.
Okay.
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MR. FINLAYSON: Nothing further, Judge.
THE COURT: Anything else?
MR. EVERT: Just two questions.
THE COURT: Sure.
REDIRECT EXAMINATION
BY MR. EVERT:
Q.
Ms. Sweeten, you testified that you and Mr. Delano are
acquaintances.
A.
Um-hmm, yes.
Q.
Are you aware of if he's acquainted with anybody with --
sorry. Are you aware of him being acquainted with anybody
else by the name of Monica Sweeten?
MR. FINLAYSON: Objection.
THE WITNESS: No.
THE COURT: Overruled.
BY MR. EVERT:
Q.
You can answer the question.
A.
No.
Q.
Thank you.
MR. EVERT: No further questions.
THE COURT: Okay. Can the witness be excused?
MR. FINLAYSON: Yes.
THE COURT: All right. Thank you very much. Do you
have another short witness?
MS. CONNORS: No, Your Honor.
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THE COURT: All right. We're going to break today,
because we're going to go over the other thing we talked about
this morning.
Okay. Everybody feeling okay?
All right. We are going to break until -- now 8:30
still work for everybody tomorrow or do y'all want to go to
9:00? 8:30? All right, 8:30 having had.
MR. FINLAYSON: 9:00.
THE COURT: I know you-all got that today. That
other gentleman did not. But we're going to start at 8:30
tomorrow morning, ready to go.
Did they have coffee in there by the time you got
here today?
JURORS: They did.
THE COURT: And something to eat, too?
JURORS: They did.
THE COURT: So, Ms. Kelley, you were stern enough
with them, and I appreciate that.
Don't talk about it today. You know a little bit
more about this case, you've heard from a couple of witnesses.
But you don't know everything. Remember what I've said,
you've got to keep your mind open until the very end. So
don't tell anybody about it, don't talk with anybody about it,
don't let anybody talk with you about it. Just go home and
watch the Braves or do whatever you want to do.
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Okay?
All right. Thank you-all very much.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Okay. Y'all ready to talk about this
statement?
MR. FINLAYSON: I'm looking for it.
THE COURT: I'm assuming this will be coming in
tomorrow; is that right?
MS. CONNORS: Well, since we're off, I'm not quite
sure. It might end up being Thursday.
THE COURT: All right. Well, we'll just deal with it
today while it's in front of us.
MR. FINLAYSON: So my paralegal has made two filings,
and that paralegal, of course, is me.
THE COURT: Do you-all have another copy for him?
MR. FINLAYSON: I have one, just the one that I
wanted was the one -- I had a better marked up one. This is
fine.
THE COURT: Let's turn to Page 9. That's the first
bit.
The government has agreed to take out a portion, but
the agent's admonition that he can't lie, what's wrong with
that? He says I know I can't.
MR. FINLAYSON: Well, the answer does sort of balance
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out the question, so I'm not going to die on that hill.
THE COURT: All right. So if we go to the next page,
the portion starting at Line 4 is crossed off.
I'm going to -- I haven't gotten any authority from
you-all, by the way, but I'm going to overrule the defense
objection to this. I think that the witness's -- it's a back
and forth with the witness and the agent where the agent is
trying to explain to the -- I'm sorry, the defendant and the
agent, where the agent is trying to explain to the defendant
the strength of their case and what their case is. And I
believe that puts it in context, so I'm going to overrule the
objection by the defendant of Line 4 to 24 on Page 10.
The next portion is Page 16 starting at Line 11 and
moving on to Page 17, Line 3. Again, I think this puts it
into the proper context, the back and forth between the agent
and the defendant, leading up to the defendant's answer on
Page 17 that begins at Line 4.
And, Ms. Connors, can I ask you to file a copy of
this version as an exhibit for today's hearing, or for this
hearing, so that we have it in case there's an appeal.
MS. CONNORS: Yes, Your Honor. Do you want the
highlighted version?
THE COURT: Yes, the highlighted. Because I'm
referring to the highlighted portion of the page. And
whatever you-all have later might be different.
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MS. CONNORS: Yes, Your Honor, we're happy to do
that.
THE COURT: Okay. Page 25 is the next portion. I'm
going to -- I'm going to sustain the objection to all of the
highlighted there. It sort of looks like he's leading up to a
question, but this is where I was talking about today where
really it's the agent giving the defendant his opinion about a
number of things about the strength of their case.
It looks like they're going into a statement by
Mr. Torjagbo, but then it ends with, look, we just want you to
give us access, are you going to let us have access. There's
not an understanding there that needs to be -- an
understanding of something that the agent actually says.
The same thing on Page 25.
MR. EVERT: I'm sorry, I think we were just talking
about 25.
THE COURT: I'm sorry. Oh, I'm sorry, yes, 27,
sorry.
MR. FINLAYSON: So we're going to strike from Line 9
all the way down, is that --
THE COURT: Line 9 on Page 25 through Line 21 on
Page 26.
Does it matter that they gave him -- he let them into
the house?
MR. FINLAYSON: I'm okay with that fact.
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THE COURT: Well, I mean, they were willing to take
out the long portion on Page 25 from Line 15 to 24.
But my understanding is you still wanted the part on
Page 25 that's highlighted in yellow and the rest of Page 26
that's highlighted in yellow, you wanted all of that out.
MR. FINLAYSON: That's correct.
THE COURT: I'm going to do that because it's not
really part of a conversation that leads to the defendant's
admission. If there's some reason that it has to be said that
he let them in to get access to the vehicle, is that part of
anything?
Which vehicle is this?
MR. FINLAYSON: BMW.
THE COURT: And there's going to be testimony that
they got it out of his garage and took it?
MR. FINLAYSON: Right.
THE COURT: Okay.
MS. CONNORS: I mean, perhaps not that specific.
THE COURT: Okay. Something like that?
Okay. If there's any doubt about that -- and, by the
way, let me be clear about something, this is something that
the defendant has to be careful not to open door for, right?
I'm giving these rulings with the expectation that
the defendant won't try to use it sort of as a sword to try to
make the agent misinterpret or misexplain the way that the
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interview went.
And if that happens, then the government can come
back and say, Judge, we think the way that they've
cross-examined this, this now should come in.
Does everybody understand that?
MR. FINLAYSON: Understood.
MS. CONNORS: Yes, Your Honor.
And to clarify, though, would we be able to ask the
agent if he pushed back. Because, you know, one concern I
have is Page 25, Lines 9 through 14, that is the agent
responding to the defendant's statements to say he -- to push
back. So without that information in there, where this lands
is only the defendant's answer coming in, not also the agent
then pushing back on him and telling him that he -- that
that's inconsistent.
THE COURT: Yes, that's right. And I think that's
fine when it's done that. But like all you're doing is
arguing with him and you don't get him to then commit to the
lie again. In this instance, he doesn't do that, because he's
just sort of making his case to him.
And then what's the answer? All right. I consent to
us to open -- do you consent to us opening your garage?
That's coming in.
But it's not like he's saying, no, no, this is all
fake, it's all false and he's saying, no, it's not.
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MS. CONNORS: Well --
THE COURT: He tries to say something. And I'm doing
the same, you know, to the best of my ability without, you
know, making it look like --
You're not doing so good.
Uh-huh.
Then he says, They're bullshit, they're da-da-da,
we've got bigger problems to deal with. We've done our
homework, we've done our investigation. This is the end.
That's why I've told you it's game over.
Now, are you going to give us consent to open the
garage and get that vehicle? We have a search warrant --
otherwise, we're going to have to go get a search warrant.
There's no like -- he's not coming up and -- this is
all the agent talking to him. And it doesn't end with
Mr. Torjagbo saying despite all these things you're telling
me, I insist that I'm being honest. It ends with him saying
yeah, you can go in my garage.
The agent can say I didn't believe -- you know, I
thought this was inconsistent, things like that.
But what's the relevance of that? What do you say to
the jury because of this?
MS. CONNORS: Yes, Your Honor.
The conversation that's right before that is the
agent pushing him on the 940s, the 941s, telling him that's --
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that's fake information.
THE COURT: Yes.
MS. CONNORS: And he's -- he's, you know, saying,
uh-huh. And then the agent's saying why that is not a
believable response from him.
And then at the very last line on Page 25 is the
agent coming and saying I'm trying --
THE COURT: Yes. But what does it matter that the
agent here says it's not accurate?
MS. CONNORS: The concern is that then, again, where
this is going to land is only the defendant's response, so it
gives that implication.
THE COURT: But isn't that up to you to prove that it
wasn't true?
MS. CONNORS: Yes, Your Honor.
But I like then, you know, we are also dealing with a
circumstance where Mr. Torjagbo's response was not, No, no,
no, you have it all wrong. So that's why we have had some
concerns, significant concerns about doing this type of
editing, because we are -- we're left with this kind of
unchallenged aspect then of the transcript. And that's not
accurate in terms of what happened in the conversation.
THE COURT: Let me draw a comparison. Okay?
It's one thing to have a conversation that's relevant
to an issue. And that is because the agent -- the witness
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says something, the agent confronts, and the witness -- and
the defendant doubles down. Look at Page 16 to 17. Okay?
How clear can I make it, the agent says.
This is a paper case and it's a follow-the-money
case. And the evidence shows what you're telling me --
Uh-huh.
-- is BS. You're not going to help yourself by
giving us a bunch of BS. Okay?
How -- how honest can I be with you?
And then he says, Like I said, to the best of my
ability, I'm being plain, I'm being plain and honest.
That is exactly what you're talking about. The
defendant says something, the agent confronts him with the
fact that it's not right, and the defendant doubles down on
it. That's what's missing from Page 25 to 26.
Because the agent talks over him and then says, We're
done with that. We want to get access to the garage or we're
going to go get a warrant.
Had the agent -- had the defendant doubled down, it
would be like the other one. You're pushing him, it's the
context of what he says.
We've already heard about the 940 and the 941s,
right?
MR. FINLAYSON: Yeah.
MS. CONNORS: Yes, Your Honor.
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THE COURT: I mean, there's not going to be any
argument there -- yes. I mean, so do you understand the line
I'm drawing?
It doesn't -- it's not helpful to the jury to know
that the agent, what he believes. What matters is what the
jury believes. It matters how the defendant responds to it.
And the potential prejudice here is that you just
have the government agent saying everything that he wants to
say. When this is about his statement, his interview.
MS. CONNORS: Yes, Your Honor.
And so I understand the Court's position. I will
note based on the opening statement, it sounds as if the
defense here is going to be that Mr. Torjagbo was not the
person who was creating any of these documents and submitting
them.
So again, a concern is that by taking out when he's
confronted on his 940s and 941s, his response is not, Oh, but
my assistant is the one who prepared those documents, so in
some ways --
THE COURT: But hold on. Wait, wait, wait, wait.
Where do you give him a chance to say that? In this instance,
on 25, I agree with you. That's relevant. You have it
elsewhere.
But where does he get a chance to say that from
Page 25 to 26 that he doesn't say it?
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MS. CONNORS: Your Honor --
THE COURT: The agent buffaloes right through it. He
starts to -- and I'm doing the same, you know, to the best of
my ability without, you know, making it look like you ain't
doing so good, so but anyways.
Uh-huh.
Your 940s and your 941s are BS. The W-2s that you
filed, that you didn't file yourself are BS.
Right?
That's just him, the agent arguing about the strength
of his case. It's not the -- it's not what he says.
What does the jury take from this?
The jury takes from it that an agent in interviewing
him was talking about the strength of their case. So? Let's
go to the next page.
MS. CONNORS: Yes, Your Honor.
THE COURT: The next page, You can sit here and you
tell me you used your bank account, your own money, which is
BS. Right now, I mean, the evidence -- I'm taking out the
green that you've agreed not to include.
And he says, You started -- you'd originated with
Kremkov and then you transferred to PNC. And you started
FlyingJack. Why did you change your name?
Why is the lead-up to a completely separate question
relevant?
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MS. CONNORS: Your Honor, I mean, he's talking about
moving the money to the different accounts.
THE COURT: I understand that.
MS. CONNORS: And then FlyingJack. And as the Court
is aware, part of our theory of the concealment is movement of
the funds to these different accounts and also changing his
name and also creating FlyingJack to then have a bank account
where money is flowing to FlyingJack instead of keeping any
money in Kremkov or keeping any money in the -- it's sending
out some of the money from the personal account.
THE COURT: Right.
MS. CONNORS: So I do -- that is the context of that.
THE COURT: The context of what?
MS. CONNORS: The concealment, so that's why there is
the --
THE COURT: Yes. But what is the relevance of this
to what he says?
So, in other words, if this is right, then in an
interview, an agent could stand up and say everything they
want about their theory of the case.
Right?
And then say, Can I come in your home? And
everything that agent said would then be part of the case.
There's no evidentiary value of it.
If he said -- if he said, Look, we know where the
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money came from, it didn't come from your own bank account,
yeah, but guess what, it originated with Kremkov and then you
did it to PNC and then to Bank of America and then to
FlyingJack.
What do you have to say about that?
And he says, it's all legitimate, it's all
aboveboard. That would be one thing.
But you don't even ask him what he has to say about
that. It's a completely different topic. Why did you change
your name?
I did it when I was in the military.
So what's the lead-up for? There's no -- there's no
lead up to that. Let me -- let me -- I'm not -- I'm afear
that I'm not explaining myself well.
Go to Page 45. I'm not going to say that because,
like I said, you know, the loan was not approved based on
that, it was approved based on how much money you made because
it was cancelled so it was approved because they changed the
rules of the PPP and the loan was approved based on how much
money you made instead of how much -- how many employees you
had.
The agent says, We can try to use that as an
argument, but it's not going to fly, so, I mean, think about
it.
What does the jury do with that? The jury knows that
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the government doesn't -- that that agent did not agree with
his explanation.
Right?
But is that evidence in this case?
Because the next question that's asked, Do you have
any questions? He asks the other guy.
And then the next question that's asked, When was
Kremkov begun? It's not, Hey, I think this is -- that's never
going to float, do you want to change your answer. It's
nothing. It's just the agent saying -- confronting him with
something and he doesn't back down.
Let's go to page -- so I think that comes out as
well. You have part of that highlighted in green that you --
I think you agree to take the green out; is that right?
MS. CONNORS: On 45, Your Honor, yes.
THE COURT: Yes. Go to Page 52. Like I'm saying,
that is tax credit based on dredging.
The agent says, That's not a tax credit. I mean, you
can try to make that argument, too. It's not going to win.
And what you're going to do is end up shooting yourself in the
foot, because the benefit -- the cooperation you're doing is
going to be negated by all the BS you're telling us, which you
don't want to do. All right?
All right.
And he says, like I said, I'm not telling you BS, I'm
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just trying to answer your questions.
I think all of that comes in, the green and the
yellow. Because that's an agent confronting a witness with
something that the agent believes to be unreliable and
unbelievable and explaining to him why and the witness then
still saying I'm sticking with my story.
So the agent's pontificating puts into context the
defendant's statement. But an agent pontificating in the
abstract that he does not ask the defendant to respond to is
not relevant, in my opinion.
MS. CONNORS: Your Honor, if you are going to
Page 54, we just realized that one was mishighlighted.
THE COURT: That should be green?
MS. CONNORS: Yes, we --
THE COURT: I thought so.
MS. CONNORS: Okay. Yes. We had indicated we would
take out essentially through the end, there was a brief stop
in the audio, and then Mr. Torjagbo was talking again. But
all of that part, we've already agreed, we weren't planning on
playing.
THE COURT: So Page 54, Page 55, 57 -- or 56, 57, 58
comes out?
MS. CONNORS: Yes, Your Honor.
THE COURT: And you've agreed that the portions on --
you got them somehow where he decides not to answer questions?
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MS. CONNORS: Well, Your Honor, I mean, I will say
that was because we were trying to see if there was an avenue
to, you know, kind of meet the defendant halfway, based on
sort of some of our conversations with defense counsel.
But, I mean, it certainly would be that if his answer
of strictly I refrain from answering that question was
something that had to be taken out, it would essentially be
that then it's still just -- the audio would be he's not
responding to that question.
But Mr. Finlayson had raised a concern about him
specifically stating that he was refraining -- he didn't want
to answer the question. Again, it was kind of trying to meet
halfway, but certainly, the question is absolutely relevant of
the agent asking him how did you get those names. And then
his response of not wanting to answer that question. I do
think that is relevant or either if --
THE COURT: Why is that not admissible?
MR. FINLAYSON: I think they told him he had a right
to remain silent and he --
THE COURT: But he didn't. He didn't invoke his
right to remain silent, did he?
MR. FINLAYSON: I think he did on that question, that
would be the argument that if he --
THE COURT: I don't want to answer that question.
MR. FINLAYSON: That's invoking.
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THE COURT: Do you have a case that says that, that
says when you're interviewing and you say I don't want to
answer a question, that that's invocating your right to remain
silent.
Is that what it is?
MR. FINLAYSON: I would think --
MS. CONNORS: No, Your Honor. The Supreme Court said
the opposite, that any kind --
THE COURT: In which case?
MS. CONNORS: I apologize, I'm not going to be able
to pull the name of the case immediately. But certainly
there's been consistent authority from the Supreme Court that
anytime someone is going to now invoke any kind of right,
right to remain silent, right to counsel, it has to be clear
and unequivocal, and then there's no more answers. So all he
was saying is I don't want to answer that question.
And I'll point out as well that that was something
that was raised during the original suppression hearing, in
the sense of saying that he -- that this should be suppressed.
And so the Court has really already determined that nothing
about that question or the fact that he then refused to answer
it led to any kind of suppression here.
MR. FINLAYSON: And with all due respect, I would say
that's a very different issue in terms of whether -- I think
prior counsel was litigating the admissibility of the entire
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statement. And he was suggesting and arguing that the -- that
those statements were -- were an absolute invocation. And I
guess I don't waive those or withdraw those arguments. I
would just build on them.
And I would submit that in this context, I think the
fact that he invoked on those specific questions -- and I
thought we were past this, so I don't have a case, either.
I'd be glad to look at it overnight.
And just so the Court had asked about other cases on
this, and I did not send them over, but I have a couple of
cases, out of all places, South Carolina, about the officer's
testimony in this kind of context, it's not the question we're
talking about right now, but it's about the bigger -- the
officers pontificating in the middle of an interview and I can
send those over.
THE COURT: Well, I've already drawn the line on
that.
MR. FINLAYSON: That's fine. And I appreciate that.
But, no, in terms of -- I -- I think when he says I don't want
to answer that, I think that's exercising a Fifth Amendment
right.
I don't think that it makes the rest of the
interview -- well, I don't want to go further. It is what it
is. But I think he does -- I don't think the jury should hear
that, but that's all I would say.
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THE COURT: Well, I'm going to let you-all send me
this evening any authority you have on when a person is
answering a -- is asked -- is not invoked. Did he waive in
writing?
MS. CONNORS: Yes, Your Honor.
THE COURT: Waived his right to remain silent and
then refrains from answering a specific question, whether that
refusal to answer can be told to the jury.
Okay?
Otherwise, you're just taking out the question that
he refuses to answer.
All right. So I'm going to let you send me that.
That's the only one I'm going to leave out, so you might
leave -- you might have two versions of it ready, but --
MS. CONNORS: Okay. And, Your Honor on Page 43 as
well, right?
THE COURT: Yes. I think we're talking about Page 43
and Page 44, right?
MS. CONNORS: Yes, Your Honor.
THE COURT: Because y'all are taking out Page 45.
And I agree with that, I mean there's no question there.
I think you can even leave in the yellow part of 45.
Or you could try to use that as an argument, but it's not
going to fly. So, I mean, think about that. And he doesn't
say anything. I mean, he just says, Uh-huh. So he's
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acknowledged that. He doesn't say anything. It doesn't
change his story in any way, right?
MR. FINLAYSON: Well, I'm bothered about talking to
the attorney part.
THE COURT: No, that's coming out.
MR. FINLAYSON: Okay.
THE COURT: I think you can leave his uh-huh in as an
answer to that question. He's telling them to think about it.
He says uh-huh. And then he doesn't say anything else.
MS. CONNORS: So the yellow part would stay in? I
mean, once you talk to an attorney would come out?
THE COURT: Comes out. And then uh-huh stays in.
MS. CONNORS: And then, I mean, they can counsel you
on that would come out and the second uh-huh would stay in or
how would we do that?
THE COURT: Yes, both uh-huhs stay in.
MR. FINLAYSON: I mean, I feel like the uh-huh is a
response to you're -- once you talk to your attorney.
THE COURT: Well, do you want to put the whole thing
in then?
MR. FINLAYSON: I do not.
THE COURT: Okay. All right. But do you
understand -- does the government understand the point that
I'm trying to make?
I think it is one thing for an agent just to
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pontificate. I don't mean that derogatively, just to opine as
to what they're hearing. And if the person sticks with it
after that, I think it's relevant.
And I don't know, I haven't seen it, does -- is the
thing -- do you flip back on these issues later? I've only
read what you've given me.
Do you flip back on these questions later? Like, for
example -- maybe I should have read -- you ask him -- the
easiest example I can give you is -- where is the reference to
the forms?
Your 940s and your 941s with your payroll, your
average monthly payroll --
Uh-huh.
-- is BS. And you know that's fake, too, right.
That's why I'm telling you you need to cooperate. That's
Page 25. Do you flip back to that issue later?
MR. FINLAYSON: I don't think so.
MS. CONNORS: Do you mean in regards to the remainder
of the transcript?
THE COURT: Yes. Here's the point I'm trying to
make.
MS. CONNORS: I don't recall.
MR. FINLAYSON: Yeah.
THE COURT: Here's the point I'm trying to make.
MR. FINLAYSON: I don't think so.
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THE COURT: If you are confronting him with something
that he says that you don't believe and he sticks with it,
whether immediately or later, then that statement can come in.
But if you're just arguing with him and then you
don't give him an opportunity to double down on what he was
saying before, then it doesn't come in.
Because what makes all of this relevant -- that's a
hearsay statement, that's an out-of-court statement by the
agent. We can argue about whether it's being offered for the
truth or not, but it is the truth that you're arguing in this
case, that these records are not real, that all of this is
made up.
So the way to have the agent's statement admitted,
despite being hearsay, is because of the impact on the
listener. The defendant's statements all come in, because
he's an opponent.
And so the relevance of the agent's statement to him
is the impact on him, or the context of the things that he
says.
But when an agent argues with him and says what
you've told me is BS, but we're moving to something else, can
I get into the garage. Or but we're moving to something else,
why did you change your name.
Then it offers nothing for a jury. But if later on
you circle back to it, then we can talk about it.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Do you understand?
MS. CONNORS: Yes, Your Honor.
THE COURT: So I just don't know. Are there times
that you circle back? I looked at what you-all asked me to
look at.
MR. FINLAYSON: I don't -- I'm not aware of any.
THE COURT: Off the top of your head, like I'm not.
What I'm asking is if somebody has looked at it.
MS. CONNORS: Your Honor, I haven't looked at it with
the specific -- trying to specifically look to see if they
address those two forms again. I don't know that they do.
But if they do, we'll -- we'll make sure to pull that out.
THE COURT: Well, let's look at this. Let's look at
Page 25. You-all are upset that I'm not letting that in.
MR. FINLAYSON: No, I'm not.
THE COURT: I'm talking to them. You say you're
talking about your payroll, your average monthly payroll.
That's what the 940s is, right?
MS. CONNORS: The quarterly.
THE COURT: It's the quarterly payroll?
MS. CONNORS: Um-hmm.
THE COURT: And you're saying, We know it's fake.
The papers won't prove it, the papers are floating money.
I've been doing this for a long time.
Do you ever circle back and talk to him about that
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
payroll issue again?
You do, you go on 43, and there you call it fake
payroll.
MS. CONNORS: Yes, on 43.
MR. FINLAYSON: But that's not the 940s.
THE COURT: No, but it touches on the same thing, the
payroll. The 940s is just the quarterly report of the
payroll.
All I can do is I can point you to Page 52 where I'm
letting all of that in because that's a great contrast where
you're telling him that it's BS and that it's going to hurt
him. And you're thinking about it. And he says -- he sticks
with his story.
So if you can fit these other portions into that,
let's talk about it.
Okay?
MS. CONNORS: Okay. Thank you.
THE COURT: But otherwise, I just don't think an
agent's opining about their opinion is relevant on this. I
don't think you could -- you might ask him did you believe
that upon what you say and was that statement consistent with
what you saw in the type of testimony you could get.
But when we're talking about his statement coming in,
I don't think it's relevant there.
All right?
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MS. CONNORS: Okay.
THE COURT: And I think it's great potential for
prejudice, because it really is -- what did Mr. Finlayson say?
Mr. Finlayson described it as just a couple of closing
arguments in the middle of an interview. And it only has
relevance if he says, No, I'm sticking with my statement.
All right?
But I really do want to see this -- this issue. You
say you think there's a Supreme Court -- I'm not talking about
a case that says -- I understand that if you're being
interviewed -- well, let's see how close you can get it to
something like this.
But what I think he's saying is I'm willing to
continue talking with you, but that one question I don't want
to answer.
MS. CONNORS: Umm-hmm.
THE COURT: And whether that can be used against
somebody. Okay?
MR. FINLAYSON: And what I think I should go look at,
besides the cases, obviously, are the way the Miranda was
phrased, because I've had cases where the officer when
they're -- when they're advising the client, they're like
telling them, hey, look, if you don't want to answer
something, you know, that's fine, you don't have to. So I
need to go back and look at that, too because --
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: Well, we have it. You have a right to
have a lawyer with you during questions. If you can't afford
a lawyer, we'll appoint one to work with you. You have a
right to remain silent. Anything you say will be used against
you.
You have the right to talk to a lawyer before we ask
any questions. If you decide to answer questions now without
a lawyer present, you have the right to stop answering at any
time.
MR. FINLAYSON: Umm-hmm.
THE COURT: Can we speak with you?
Yeah, I'll speak with you briefly.
So you waive all those rights.
MR. FINLAYSON: I guess the question is --
THE COURT: The question is when you've waived your
right and you're having an interview and then there's a
specific question that you refuse to -- that you say you don't
want to answer --
MR. FINLAYSON: Right.
THE COURT: -- you don't -- you don't say because of
a lawyer or because of Miranda, I don't want to answer that
question, and then you continue answering, is that -- does
that create a donut that can't be used. I don't know the
answer to that.
MR. FINLAYSON: Okay.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: Okay? It doesn't seem like an invocation
of rights. It seems like a decision not to answer one
question, for whatever reason.
But, you know, the United States can tell me what
they have on that and whether they want to introduce it.
Do you want to introduce it?
MS. CONNORS: That he -- again, we were willing to
take out him saying the specific words of I don't want to
answer that question.
But essentially then where it would land in terms of
audio would be there's just silence there. And we were
willing to do that because of defense counsel saying that he
thought maybe it hit on a Fifth Amendment right.
But I think it -- the question is posed. I think the
question is relevant. I mean, the agent is asking him
specific information about the loan. So the question I think
is not something that would have to be removed. And then
essentially the jury would just hear that he does not respond
to the question.
THE COURT: That might be more misleading than --
that would suggest to the jury that he just stopped talking.
Right, he just ignored it.
Whereas the purpose, if he has a right not to answer
it, then he has a right to do that without it being used
against him. And what you essentially would be doing in that
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
case is you would be allowing it to be used against him when,
if he has a right, it's the opposite.
Do you see what I mean?
That doesn't really help. You could put in the first
question and then the second one. It's a lot of names. I
mean, did you use them for anything else or was it just for
the payroll, did you pay somebody to get those names. You
could do it that way. Because he answers that question and he
says no.
But I'm kind of uncomfortable with having the
question asked and then make it look to the jury like he
didn't answer it. Because then you can stand up in closing
and you can say we asked him that and he didn't answer it.
Whereas if, in fact, he invoked his right to remain silent,
then he invoked his right to remain silent and for that not to
be used against him, right?
MR. FINLAYSON: And I think if we left the question
but -- silence the question, in a way, it is -- it's almost
testimony from the agent at that point, too, it's sort of --
you know, there's no answer.
THE COURT: You're right. You've got to take out the
question. I mean, did you use them for anything else or was
it just on the payroll file.
You could leave -- you could have it -- and this is
important, because, I mean, it's a lot of names. Did you
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
pay -- did you pay someone to get those names. You can do
that. That's a fair question. What if I asked it this way.
Did you pay someone to get those names? That can come in.
Is there any argument that doesn't come in? He
answered it.
So I think you can skip over the green. No, I think
you've got to go one sentence before the green.
So I'm going to give the government an option. I'm
not going to let you just have the question and then a vacant
no answer unless you can establish that this is not an
invocation of the right to remain silent.
Okay?
MS. CONNORS: Yes, Your Honor.
And, I'm sorry, I was just trying to read through. I
mean, I do think on Page 44, just for the sense of trying to
make sure we were able to get this ready in case the agent
takes the stand tomorrow, 44 I think is potentially a
redundant question, so --
THE COURT: Yes.
MS. CONNORS: -- if we want to take that out and that
response. And I was just trying to read on 43 to see what
position we're in.
THE COURT: Here's my concern 43.
Did you use them for anything else or was it just on
the payroll file?
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Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 243 of 281
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
That and the part that's green may be improper
because he's invoking his right to remain silent. That seems
right. That seems like that's a selective decision to invoke
his Fifth Amendment, right?
But I want to -- if you have case law that says you
can't do that, then I'd like to see it. Okay?
MS. CONNORS: Yes, Your Honor.
And if the Court is saying on 43 what would be
removed is from, "and this is important," is that the --
THE COURT: No, it's the sentence after that.
MS. CONNORS: That part of the question.
THE COURT: I mean, did you use them for anything
else or was it just on the payroll.
MS. CONNORS: Okay. And there was no request for
the, "Did you pay somebody to get those names." And then
that's the question. Then there's the response to no.
THE COURT: Yes.
MS. CONNORS: So again, to help try to make sure that
we can get this taken care of, because it is going to be a
good bit of slicing and dicing audio as well, we would be
willing -- we'll -- we'll agree to take out the green. We're
certain -- we'll still have --
THE COURT: And the sentence that says, I mean, did
you get them from any -- did you use them for anything else or
was it just the payroll file.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MS. CONNORS: Yes, Your Honor.
THE COURT: And so you'll have Line 15, one word on
line 16, and then the last word on Line 22 and then
continuing.
MS. CONNORS: Yes, Your Honor.
THE COURT: I think that's right. I think that's
what we ought to do. Unless you change your mind and you send
me a case that says somebody can invoke selectively during an
interview. And I just don't -- I don't know why I don't know
the answer to that. But I don't know the answer to that.
I've never seen it come up.
MS. CONNORS: I think it more often comes up in that
sense of are they invoking to where then after -- it's usually
in the context of suppression. And if they say those words,
what does it mean, in terms of everything that flows from the
interview afterwards and certainly that's what I was referring
to in terms of a Supreme Court case.
THE COURT: Right.
MS. CONNORS: This is a more specific issue. But
again, I think we're comfortable taking that out.
THE COURT: Okay.
MS. CONNORS: That section out so that we can go
ahead and be able to be prepared for the agent.
THE COURT: Okay. All right. Anything else?
MR. FINLAYSON: No, sir.
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Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 245 of 281
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: I think that's probably the right thing.
I'm going to look at that issue myself, because I kind of want
to know it.
It seems Fifth Amendmenty to me. But it also seems
like maybe not because they're continuing to talk. And I
think probably this hasn't come up a lot because I don't know
how new recording all these statements is, but it didn't
happen a lot when I came up, so we may not have that type of
specific drilling down.
Okay. All right. Anything else?
MS. CONNORS: I think we're good. Thank you,
Your Honor.
THE COURT: Okay. We will see you-all tomorrow at
8:30, ready to go.
Mr. Finlayson, I know you don't like that time.
MR. FINLAYSON: Oh, I'm getting --
THE COURT: So if you're not here, we're going to be
really questioning that.
MR. FINLAYSON: I will be here. I have had my had --
I've been had, whatever.
(Whereupon, the proceedings were adjourned at 5::28
p.m.)
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Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 246 of 281
476
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 July 22, 2025, in the matter
of United States of America v. Carl Delano Torjagbo also known
as Karl Lucius Delano, 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 10th day of November, 2025.
_______________________________
/s/ Jana B. Colter, FAPR, RDR, CRR, CRC
Official Court Reporter
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Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 247 of 281
BY MR. EVERT: [9] 432/9432/25434/2
435/1435/6436/2441/13443/6443/16
BY MR. FINLAYSON: [8] 379/3386/2
391/19396/15422/7429/9439/8442/4
BY MS. CONNORS: [74] 291/18296/7
296/16297/7298/16299/13301/8303/7
304/12310/24312/15313/13314/3315/20
316/20321/9321/14322/3323/4326/25
327/23329/4330/11331/5332/12333/9
334/4335/1336/23337/23339/5340/7
341/4341/13341/19342/12342/21343/5
344/21345/8345/13346/1346/20351/2
351/7351/13352/6354/25355/10357/16
358/7358/25360/15361/12362/15363/17
365/12366/20367/15368/8368/21371/9
372/9373/1393/9394/5398/11398/21
401/2407/2418/9421/11428/13431/2
COURTROOM DEPUTY: [11] 244/12
249/3251/19251/21291/12291/16398/3
398/8431/21432/2432/7
COURTROOM SECURITY OFFICER:
[11] 250/17318/20319/2321/3373/23
376/7398/9411/25418/6418/8445/3
JUROR: [11] 319/6319/11319/13319/22
320/2320/5320/8320/13320/18320/20
320/23
JURORS: [4] 350/12431/16444/14
444/16
MR. EVERT: [13] 267/15267/18267/22
268/1321/12433/22434/23435/5435/25
439/3443/3443/20447/15
MR. FINLAYSON: [119] 236/7236/9
236/12236/18239/6240/17240/20241/4
242/5242/11242/19243/8243/11243/21
243/24244/8245/16245/18245/21246/9
246/17247/2247/9247/12249/1249/6
249/13249/15249/19249/22249/24
274/13280/9296/2298/3301/4310/20
312/6313/10318/24345/4350/21354/17
354/21357/3357/11360/8362/11364/17
366/17372/6374/11375/21375/23378/17
379/1391/17393/2393/4393/21396/12
397/13397/15406/18411/21412/3412/11
417/6417/13417/15418/2422/5428/9
429/7430/24433/25439/5441/10442/3
443/1443/13443/22444/8445/7445/14
445/17445/25447/19447/25448/6448/13
448/16449/6452/24459/18459/22459/25
460/6460/23461/18463/3463/6463/17
463/21464/17464/23464/25466/6466/15
467/5468/19469/10469/14469/19469/25
471/17474/25475/16475/19
MS. CONNORS: [207] 234/15236/24
237/3237/12239/7239/13240/7240/10
241/1241/12241/25242/3244/4246/8
246/19247/10247/15247/22248/5248/10
249/16291/5295/24296/5296/14297/5
297/25298/6298/8298/12298/14299/11
300/25301/6303/3304/10310/17310/22
312/8312/14313/6313/12314/2315/18
316/18318/10321/8321/13322/1323/3
326/23327/21329/2330/10331/3332/10
333/8334/2334/24336/21337/22339/4
340/6341/1341/12341/18342/11342/19
343/4344/20345/1345/6345/11345/24
346/18350/10350/14350/16350/24351/6
351/11351/24353/10353/13354/24355/8
356/25357/7357/14358/5358/23360/6
360/11360/13361/9362/8362/13363/11
364/14364/23365/2365/6365/8365/10
366/15366/19367/13368/6368/19371/7
372/4372/8372/25373/17374/2374/14
374/19376/3378/21386/1391/16393/6
393/22394/4396/11397/16397/21398/19
412/2413/14413/19413/25414/12414/22
414/25415/8416/1416/5416/7416/11
416/17417/3417/18418/1421/10422/2
428/11429/6430/25431/6431/13431/19
443/25445/10446/21447/1448/18449/7
450/1450/23451/3451/10451/15452/25
453/10454/1454/16455/1455/4455/12
455/14457/15458/11458/14458/16
458/23459/1460/7460/10462/5462/15
462/19463/10463/13464/18464/22466/2
466/9466/19466/21467/4467/17468/1
468/16470/7472/13472/20473/7473/11
473/14473/18474/1474/5474/12474/19
474/22475/11
THE COURT: [260]
THE WITNESS: [17] 291/14397/19
398/6398/18400/25406/19406/23407/1
412/8418/5421/8431/10432/5432/20
432/22432/24443/14
$
$1,300 [4] 325/14327/11328/8329/13
$1,337.10 [1] 324/20
$1,807,988.67 [1] 338/21
$1.6 [1] 272/23
$1.6 million [1] 272/23
$1.8 [1] 408/9
$1.8 million [1] 408/9
$10,000 [2] 289/3289/5
$12 [4] 268/4268/11272/17279/4
$12 million [4] 268/4268/11272/17
279/4
$120,000 [1] 273/21
$155,000 [1] 273/23
$20,000 [5] 429/13429/23430/2430/7
431/3
$241,902.91 [1] 317/8
$298,476.18 [1] 318/1
$3 [4] 268/9271/22281/11281/13
$3 million [4] 268/9271/22281/11
281/13
$3,366,000 [1] 285/15
$3,366,240.76 [1] 285/11
$3,373,000 [1] 285/14
$3,373,441 [2] 391/13391/23
$3,459,835 [1] 285/6
$3,821,770 [1] 304/2
$3.3 [2] 272/15272/25
$3.3 million [2] 272/15272/25
$3.4 [3] 284/24285/1285/2
$3.4 million [2] 284/24285/2
$3.8 [1] 270/11
$3.8 million [1] 270/11
$32 [1] 335/16
$32 million [1] 335/16
$333,000 [1] 273/25
$4,817.79 [1] 436/18
$40,000 [7] 437/24438/11438/16438/17
438/21440/3440/5
$45 [1] 270/12
$45 million [1] 270/12
$45,861,255.93 [1] 335/9
$45.8 [1] 335/11
$45.8 million [1] 335/11
$5,700 [4] 325/12327/8328/6329/11
$5,717.23 [1] 324/18
$50,000 [1] 279/6
$500,000 [3] 406/3406/13408/12
$51,000 [1] 274/3
$510,000 [1] 274/3
$56,573.27 [1] 317/17
$6 [6] 276/21276/23276/24281/11
281/17281/22
$6 million [6] 276/21276/23276/24
281/11281/17281/22
$6.5 [1] 286/15
$6.5 million [1] 286/15
$7,000 [7] 285/17285/21286/8325/17
328/11329/15391/25
$7,054.33 [1] 324/22
$7,200 [1] 285/15
$9 [3] 373/6415/22416/23
$9 million [2] 373/6416/23
$9,554,425 [1] 304/8
$9.5 [8] 268/6269/7269/22271/10272/21
276/21276/22410/8
$9.5 million [8] 268/6269/7269/22
271/10272/21276/21276/22410/8
$90,000 [1] 273/18
$900,000 [1] 274/6
$92,000 [2] 436/15436/15
$92,213 [1] 324/12
$92,610 [1] 328/21
$92,623.50 [1] 436/14
$92,633.50 [1] 329/23
$92,931.36 [1] 330/23
$93,000 [1] 348/19
$93,253.76 [1] 331/25
$95,000 [1] 410/19
$96 [1] 429/17
$98,000 [1] 273/19
'
'02 [1] 361/7
'04 [1] 379/22
'05 [2] 379/21379/22
'14 [2] 311/10313/18
'25 [1] 313/19
'5 [1] 384/22
'70s [1] 278/13
'75 [2] 363/1365/21
'79 [2] 367/2371/21
'90s [1] 399/9
'97 [3] 358/12379/18379/25
-
-- at [1] 365/7
-- during [1] 241/4
-- exhibit [1] 369/25
-- if [1] 472/20
-- in [1] 430/10
-- is [2] 452/7464/14
-- the [1] 326/15
-- you [1] 469/20
/
/s [1] 476/18
0
01/01/2020 [1] 435/15
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0
04 [1] 379/21
05 [1] 391/6
0540 [6] 355/18356/8369/22370/5
372/16391/7
08 [1] 357/25
09/08 [1] 357/25
1
1,852 [1] 436/7
1,852.47 [1] 436/6
1.8 million [1] 338/21
1/1 [1] 322/18
10 [15] 248/20298/22304/11314/20
367/2368/7368/7368/9371/8371/21
372/1372/5372/8402/4446/12
10,000 [2] 381/8408/19
100 percent [3] 302/18330/7348/6
101 [9] 300/18300/19301/5314/19
321/10321/17434/22439/5441/10
1040 [3] 344/23350/3350/5
1099 [1] 285/4
10th [1] 476/14
11 [9] 315/18361/25362/9362/13364/18
371/8372/20402/5446/13
11,12 [1] 368/20
11/21 [1] 358/12
11/27 [1] 361/7
114 [1] 331/3
118 [7] 322/2332/10332/11332/13
435/25439/6441/10
119 [1] 333/8
11:00 [1] 248/20
11th [1] 296/22
12 [15] 291/25299/11322/19364/6
364/15365/11400/15401/3401/3402/2
402/2402/5402/5410/11421/24
12/31 [1] 301/22
12/31/2020 [1] 435/15
121 [1] 334/3
122 [1] 334/24
12:30-ish [1] 267/6
13 [6] 297/19298/6298/7346/18349/17
368/20
13-year-old [1] 428/20
1337 [1] 385/19
1377 [10] 314/7347/1347/11347/17
349/17351/15385/18385/19385/20386/4
14 [3] 358/6367/14449/10
141 [2] 336/19340/13
142 [1] 339/4
143 [1] 339/24
144 [1] 341/1
145 [1] 341/3
1456 [1] 231/23
146 [1] 341/12
148 [1] 342/11
149 [1] 342/20
15 [5] 245/21245/22423/5448/2474/2
15th [6] 269/13270/5282/4282/7282/9
283/7
16 [7] 316/7358/6369/8369/11446/13
452/2474/3
16 million [1] 276/25
17 [8] 277/18283/11351/11379/25433/3
446/14446/17452/2
17th [1] 299/21
19 [5] 268/15362/20430/1431/3432/16
1949 [1] 231/21
1975 [5] 357/25360/17382/5422/1423/5
1979 [3] 298/22384/15384/24
1992 [2] 402/22402/23
1997 [2] 367/19379/11
1:22-CR-00171-MLB [2] 231/4476/10
2
2.5 [1] 269/9
2/1 [1] 304/25
2/11 [1] 372/20
2/2 [1] 367/17
20 [6] 244/19245/19379/23379/24
379/24430/1
2000 [1] 362/20
2001 [1] 277/20
2004 [4] 366/1379/20384/14384/22
2005 [1] 367/17
2007 [1] 371/16
201 [15] 344/17344/19344/20344/20
345/3345/5350/4352/12355/2355/4
355/16370/1391/15391/17391/20
2014 [7] 270/1278/21282/18301/22
311/10311/12325/8
2017 [2] 404/25434/7
2018 [5] 282/19282/19283/22386/7
386/10
2019 [1] 404/25
201A [1] 284/16
202 [10] 349/24349/25350/7350/18
352/13355/3355/5355/19366/7391/17
2020 [40] 269/13270/5270/12271/18
282/4282/7282/9283/7284/21284/22
285/20304/25305/1318/7322/18322/19
324/2326/3327/5331/13332/20333/13
334/8335/12335/19336/14342/22344/23
348/13348/22350/3350/5355/11435/15
435/15436/8436/10436/11436/16436/19
2021 [13] 270/3272/20272/22272/25
273/4273/17273/19296/22296/24299/9
299/20299/21405/17
2022 [6] 273/21273/23273/25274/2
372/19372/20
2025 [7] 231/12234/3284/20311/10
325/8476/8476/14
20th [1] 371/16
21 [4] 292/17358/12379/25447/21
215-1456 [1] 231/23
21st [1] 291/24
22 [4] 231/12234/3474/3476/8
2220 [1] 351/19
23 [1] 366/1
24 [5] 346/8346/8374/8446/12448/2
240 kilos [1] 279/7
25 [14] 246/14447/3447/14447/16
447/21448/2448/4449/10451/6452/15
453/22453/25464/16466/14
26 [4] 447/22448/4452/15453/25
27 [2] 361/7447/17
28 [2] 379/14379/18
29th [2] 272/20299/9
2:00 [1] 406/6
2s [9] 295/5307/4352/7353/3394/13
394/13395/13395/13454/7
3
3 million [1] 288/13
3,366,000 [1] 286/8
3,373,441 [2] 346/11346/17
3-point [1] 286/8
3.36 [1] 288/14
3.37 [1] 286/7
30 [3] 243/18399/1399/7
30303 [1] 231/22
3081 [1] 297/14
31 [2] 245/4301/22
31st [1] 322/19
33 [2] 346/8346/9
34 [4] 346/2346/7346/10346/14
35A [2] 346/13346/16
38 [1] 401/7
3s [3] 295/5307/4394/13
4
40 [1] 437/25
401 [2] 357/4360/9
403 [2] 357/4360/9
404 [3] 231/23239/15360/9
42 [1] 323/9
43 [7] 462/15462/17467/2467/4472/21
472/23473/8
44 [3] 462/18472/15472/17
45 [6] 243/18426/12456/15457/15
462/20462/22
493 [24] 270/18270/25271/4290/1
290/10290/12304/5316/11316/12316/12
316/15326/5326/14326/19335/11335/19
340/10340/17341/21343/7395/2396/6
397/3410/19
4:30 [2] 248/6373/22
4s [3] 295/5307/4394/13
4th [1] 296/24
5
50 [5] 327/8401/7401/8421/25422/21
52 [2] 457/16467/9
54 [2] 458/12458/21
55 [1] 458/21
56 [1] 458/21
57 [2] 458/21458/21
58 [1] 458/21
5::28 [1] 475/22
5A [2] 338/3338/18
5B [1] 338/3
5C [1] 338/3
5D [1] 338/18
5E [2] 338/17338/21
6
6/19 [1] 362/20
6010 [10] 355/21356/7359/21360/3
360/23363/5363/10365/23366/7367/18
6:30 [1] 247/23
7
7,000 [2] 327/13327/13
7/23 [1] 366/1
71 [1] 305/8
72-foot [1] 274/3
737 [1] 278/5
737s [1] 288/20
75 [2] 231/22278/14
75-year [1] 278/15
7540 [13] 303/18310/4310/13311/7
311/16337/7339/1340/4342/4342/25
343/15344/7347/16
77-page [1] 388/3
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 249 of 281
8
80 [3] 316/18321/11321/16
81 [1] 435/5
8332 [1] 313/16
86 [1] 326/23
87 [1] 327/22
8888 [1] 346/14
8:30 [12] 244/19250/21319/9319/17
320/11320/11320/12444/5444/7444/7
444/10475/14
9
9,199,411 [2] 345/17348/11
9.4 [1] 410/7
9/10 [3] 298/22367/2371/21
9/8 [2] 363/1365/21
9/8/1975 [1] 360/17
90 [1] 1/4
92 [3] 329/2348/19348/20
93 [1] 348/20
940 [1] 452/22
940s [7] 450/25453/17454/7464/11
466/18467/5467/7
941 [11] 339/12340/1340/12340/16
340/19341/5341/14341/20342/14342/22
343/8
941s [5] 450/25452/22453/17454/7
464/11
96 [1] 429/23
97 [1] 330/10
9:00 [3] 244/19444/7444/8
A
abbreviation [2] 305/13305/16
abbreviations [4] 305/11305/19305/22
323/15
abide [2] 251/10257/4
ability [5] 250/7378/25450/3452/11
454/4
able [34] 240/3240/12243/17256/5
281/15306/18307/2307/5310/6330/12
339/13344/5355/25356/5361/14370/25
373/2374/16374/24377/11377/13377/15
377/17378/1383/5413/9413/21415/3
415/5430/11449/8460/10472/16474/23
about [243] 235/12235/14235/15235/19
235/22235/24236/5236/10236/13236/19
236/20237/1237/17237/23238/15238/19
238/20239/2239/12239/15239/23239/24
241/6241/24242/12242/13242/15242/21
243/5244/10245/9245/14245/14246/5
246/23248/4251/10252/2252/5252/19
253/23254/1255/5256/24257/18258/3
258/11258/16258/17259/22260/2260/4
260/5260/10260/15260/16261/13263/6
263/12263/13263/20264/6264/9264/22
265/1265/3265/3265/4265/8266/8
266/11266/14268/1268/13272/16272/22
274/7275/3275/4275/10275/21276/4
277/1277/14278/8279/7279/13280/6
280/22281/3284/6284/13286/22288/5
288/7289/18289/19289/20290/2290/17
294/15300/3307/5312/2318/12318/14
318/16318/17318/23319/16326/22
343/18353/15353/17354/11356/11
362/14376/18376/25376/25377/25378/2
378/14379/7385/13386/15387/17387/25
391/6392/3392/5394/12396/17396/18
396/23400/10402/22403/4403/16404/17
405/25406/21407/3407/15408/22409/4
409/11410/6410/7410/16410/22411/2
411/15412/22413/7413/10414/2414/4
414/5414/6414/11414/11414/13415/14
415/14415/19415/21416/10416/22417/2
418/12418/14418/23419/1419/3419/6
419/7419/11419/15419/17419/18419/22
419/25423/16425/8425/13425/25426/1
426/2426/3427/5427/11428/25429/10
432/16433/15434/6436/15437/16444/2
444/19444/20444/23444/23444/24445/5
447/6447/7447/8447/16448/20448/21
451/19452/12452/22453/9454/10454/14
455/1455/20456/5456/8456/23459/10
460/21461/9461/11461/13461/13462/17
462/24463/3463/8465/9465/25466/17
466/25467/12467/15467/19467/23468/9
470/16
above [1] 303/3
aboveboard [1] 456/7
absolute [1] 461/2
absolutely [5] 282/5288/6288/25289/5
459/13
abstract [1] 458/9
abuse [6] 292/22380/20380/24393/12
393/19394/9
accept [4] 252/23257/15382/15438/2
acceptable [3] 242/25361/11363/16
accepted [2] 382/16382/19
access [7] 279/2293/11293/13447/11
447/11448/10452/17
accessing [1] 295/4
accident [3] 354/3375/13377/19
accidental [1] 236/2
accompanying [1] 369/13
according [3] 305/22354/1377/16
account [17] 272/21273/1273/5273/13
273/14284/25285/1288/3288/3288/4
292/13294/24438/12454/18455/7455/10
456/1
accounts [5] 333/6334/22336/9455/2
455/6
Accra [2] 298/25358/4
accurate [5] 393/13393/16451/9451/22
476/13
accusation [1] 258/23
Ackers [6] 314/24314/25324/2324/5
324/11326/22
acknowledged [1] 463/1
acquaintances [1] 443/8
acquainted [2] 443/10443/11
acquired [2] 353/18354/11
acquiring [2] 239/24376/19
acquisition [1] 239/16
acronym [1] 308/11
across [4] 303/25304/3381/8442/17
act [1] 430/13
acted [2] 354/1377/16
acting [1] 368/10
ACTION [1] 231/4
activity [11] 271/16287/25289/4289/17
353/21375/10375/18377/3377/3377/5
378/9
acts [3] 353/25354/3377/18
actual [2] 235/18296/17
actually [16] 272/14284/20307/19319/6
370/19388/8389/5389/8389/11389/25
390/9390/12390/18403/14430/17447/13
Acworth [1] 273/24
add [2] 234/19258/12
addition [2] 336/16409/11
additional [8] 249/20258/13265/22
368/16375/2380/19381/17381/20
additions [1] 234/16
address [19] 255/18275/11297/11
297/12301/23301/25337/9337/9345/14
347/8351/8351/19364/3366/2366/4
366/8427/2427/5466/11
adjourned [1] 475/22
administers [1] 251/17
Administration [27] 270/20291/21
292/20292/22292/24293/1293/7293/11
293/17293/24294/14294/19294/25
295/12303/16306/1309/10309/22311/22
339/20344/9356/20366/14370/10381/16
383/4388/10
Administration's [1] 293/14
Administrator [1] 231/20
admissibility [3] 242/7242/9460/25
admissible [2] 238/11459/17
admission [2] 412/18448/9
admit [16] 241/20296/1298/2298/10
301/2310/19313/8345/3350/14350/17
356/25360/6362/8364/14366/15372/4
admitted [17] 255/25261/23296/4298/4
298/7301/5310/21313/11345/5349/18
350/22354/12357/6360/12362/12372/7
465/13
admitting [1] 256/7
admonition [1] 445/23
adult [1] 297/22
advantage [1] 269/3
advising [1] 468/22
afear [1] 456/13
affairs [2] 290/21290/21
afford [1] 469/2
afloat [2] 269/4280/10
after [33] 1/7240/2265/21267/6270/4
273/4273/5274/7275/12275/15278/22
299/17307/20356/8361/22364/23371/17
375/1403/1403/8404/8404/11405/14
405/14409/12410/21419/25420/4434/16
438/10464/3473/10474/13
afternoon [5] 239/10244/17373/19
398/12432/10
afterwards [2] 404/3474/16
again [48] 252/9257/6258/12259/11
262/12262/14263/20266/8273/21274/1
280/23283/22284/13287/1289/14290/14
307/9313/6314/14319/19331/9333/23
349/17371/8374/13374/20375/5375/20
376/4376/15379/22383/20384/10387/14
391/4416/19430/10446/14449/19451/10
453/16458/18459/12466/11467/1470/7
473/18474/20
against [6] 258/22468/17469/4470/25
471/1471/16
age [9] 244/22294/3400/14401/3401/3
401/11401/22402/6422/17
agencies [3] 270/20270/23339/22
agency [2] 362/1388/7
agent [87] 291/6291/19292/1292/11
292/19293/2293/10295/13297/19298/17
300/5301/9304/13307/14310/2310/25
312/20314/18321/10321/15322/4326/20
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 250 of 281
A
agent... [65] 327/2336/24343/18344/16
344/22345/9346/21348/12352/7355/2
356/14359/22363/18366/10371/25373/2
379/4393/10394/11397/17425/10446/7
446/7446/9446/9446/15447/7447/13
448/25449/9449/10449/13450/15450/19
450/25451/7451/9451/25452/1452/3
452/13452/16452/19453/5453/8454/2
454/10454/13455/19455/23456/22457/1
457/10457/18458/3458/4458/8459/14
463/25465/9465/20470/15471/19472/16
474/23
Agent Fowler [12] 307/14345/9346/21
348/12352/7355/2359/22371/25379/4
393/10394/11397/17
agent's [7] 240/4445/23451/4458/7
465/13465/17467/19
agents [5] 236/25237/6237/18238/14
293/2
aggravated [1] 234/12
ago [8] 310/3379/14379/18379/23399/8
434/6434/11437/6
agree [9] 240/16250/1252/11374/14
453/22457/1457/14462/21473/21
agreed [6] 252/23278/25445/22454/20
458/19458/24
agreed-upon [1] 252/23
agreement [1] 395/18
agrees [2] 239/19246/25
ah [1] 282/11
ah-ha [1] 282/11
ahead [17] 235/9238/5238/20249/17
301/6304/10310/23312/13316/7321/7
350/15354/23360/10385/23418/10425/2
474/23
AI [1] 1/13
aid [1] 263/19
aided [1] 231/18
ain't [2] 427/3454/4
Air [1] 278/2
airline [3] 432/18432/19433/4
Airlines [10] 278/6278/6432/22433/5
434/4434/5434/8434/10434/14436/11
Akpene [1] 283/12
Akpene Kqadzo [1] 283/12
alcohol [1] 235/20
all [209] 235/13238/12238/20239/12
239/21241/6241/17243/17244/9244/13
244/21244/24245/22246/11246/12
248/25249/4249/12250/16250/17250/19
250/20250/21250/22251/7251/12251/24
254/5255/19257/13258/14259/5259/24
260/7261/18261/23262/8263/2263/25
264/18264/19265/8265/24266/4266/10
266/15267/13267/25274/7274/10274/15
274/19275/14276/18279/14279/16
280/14280/17282/22282/22283/21
285/25286/14286/22286/22287/16
287/18287/23288/15288/16290/24
298/10301/5304/9307/14308/13314/15
314/16315/23317/19318/14318/17
318/18318/20318/25319/2319/15320/14
320/21321/3321/5321/7325/23332/5
333/5334/21336/8338/2339/25343/17
343/18350/11354/6354/7354/16364/23
368/1369/5369/13373/18373/19373/20
373/22373/23373/25375/14376/5376/7
376/9378/16378/24385/24386/25387/2
387/12390/20395/2397/20406/7406/14
411/23411/25412/13416/4416/6416/14
416/21417/2417/23418/6422/23423/13
424/20425/1428/4428/9428/25430/10
431/8431/11431/17432/15433/17439/11
440/17441/24442/14442/16443/23444/1
444/5444/7444/9445/2445/2445/3
445/12445/16446/2446/5446/25447/4
447/20448/5449/17449/21449/24449/25
450/15450/16451/18456/6456/6457/22
457/23457/24458/2458/19460/15460/23
461/11461/25462/1462/12463/22465/7
465/11465/15466/4466/14467/9467/10
467/25468/7469/13474/24475/7475/10
475/13
allegation [2] 293/6313/4
alleged [7] 327/4331/24332/16353/21
375/10377/3377/3
allegedly [5] 236/4287/9353/18354/11
376/18
allow [2] 257/1265/11
allowed [6] 273/10412/20413/5413/6
416/20416/25
allowing [1] 471/1
almost [6] 270/4279/4284/24399/1
412/18471/18
alone [2] 244/22415/22
along [1] 242/19
already [20] 234/11239/2243/4266/21
281/11283/9306/21322/12326/21328/3
349/18355/12357/17375/1395/16409/20
452/22458/19460/20461/16
also [75] 231/6235/23237/1240/1
245/10253/7255/3270/16270/24271/15
272/3272/25273/13273/15274/5292/4
292/17297/25298/23299/17300/2300/15
305/16306/11306/13307/10312/20
312/20317/22321/22323/5326/6328/2
335/14336/1336/17340/3340/17340/21
341/22342/13343/8345/10345/15346/12
349/6350/5355/5357/1361/13363/14
364/15365/17366/2366/23374/24377/13
381/1403/12403/23404/6404/8411/10
413/5415/4429/2430/1430/13438/25
449/13451/16455/6455/7475/4476/9
alternate [5] 245/12246/20248/24
249/18250/13
altogether [1] 306/12
always [6] 235/6240/14242/20242/21
275/24423/17
am [5] 245/25252/1293/4303/12416/6
Amendment [3] 461/20470/13473/4
Amendmenty [1] 475/4
AMERICA [4] 231/3433/3456/3476/9
American [5] 286/21294/3432/22
434/10434/12
American-based [1] 286/21
amongst [1] 260/2
amount [44] 272/9281/24285/13285/20
286/3290/13303/25304/6307/16307/16
308/1317/5317/10317/20317/25318/3
324/17324/19324/21328/5328/8328/11
328/20332/1332/2335/8338/20338/22
339/2345/19345/20346/9346/14346/16
348/16348/24349/3349/6352/21391/10
391/12391/22392/1437/11
amounts [13] 270/16306/23308/8
324/14325/20325/20331/20341/23
341/25343/12352/14352/16352/19
angry [2] 408/2408/3
announce [1] 265/17
another [16] 240/7245/19247/13264/13
264/15312/22341/14356/6366/13372/2
407/16431/11433/4438/13443/24445/16
answer [52] 254/16255/1256/3256/6
256/10256/17256/18258/5346/10370/17
376/1383/19384/7387/3392/12393/19
400/23415/10443/17445/25446/16
449/13449/21457/9458/1458/25459/5
459/12459/15459/24460/3460/16460/21
461/20462/8462/11463/8468/15468/23
469/7469/18469/21469/24470/2470/9
470/23471/12471/13471/20472/10
474/10474/10
answered [4] 303/20368/17402/10
472/5
answering [7] 245/6251/16459/6462/3
462/7469/8469/22
answers [4] 237/17417/1460/15471/8
anti [2] 292/5292/17
anti-money [2] 292/5292/17
anticipate [1] 243/21
anticipated [1] 256/18
anxiety [2] 244/25245/10
any [167] 1/9234/9236/2238/13238/23
241/15241/19241/20244/22245/9249/6
249/19250/23251/4251/7251/9257/11
257/15257/16257/21258/10259/4259/11
259/17260/16260/19260/19261/7261/11
261/12264/5264/9264/17266/14267/16
270/22270/23271/25275/19285/24290/9
290/13292/7292/23294/16300/1301/3
302/19302/22302/22303/22303/22
307/20309/25310/7311/11311/17311/24
312/2312/3312/16312/17313/20313/23
313/25314/11315/5315/14315/15317/10
317/10318/3324/25325/3325/24327/16
327/18328/14328/22329/25330/3330/24
331/15332/1333/2333/18333/20334/14
334/18334/18336/5336/10337/24339/1
339/14340/24341/25342/6343/12344/11
344/14347/18348/22349/9349/10349/13
349/14349/14349/22353/4353/5359/3
369/13373/10373/13375/2375/6375/19
385/3386/9393/5395/21403/15407/3
407/22407/24408/5408/22409/16410/3
410/16419/10419/11419/21420/12
421/13421/15422/4428/10433/24435/19
437/4439/1440/24441/17441/19442/11
442/16442/19442/22446/4448/20453/1
453/14455/8455/9457/6460/8460/13
460/22462/2463/2466/6469/7469/8
472/4473/24
anybody [9] 251/9276/11287/17428/17
443/10443/11444/23444/23444/24
anybody's [1] 417/14
anymore [1] 434/9
anyone [7] 259/24259/25260/15302/22
368/10409/20437/1
anything [57] 238/24239/12244/14
245/24249/7249/11258/24260/4260/12
260/15260/21260/21261/11261/13
261/17261/21265/5288/1289/1289/1
289/16290/15292/12292/24315/5317/20
318/15318/16318/23344/9356/5374/15
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 251 of 281
A
anything... [25] 378/16378/19385/6
390/19409/13409/24410/6415/21420/1
427/5428/23434/19443/2448/11462/25
463/1463/9469/4471/6471/22472/24
473/12473/24474/24475/10
anytime [1] 460/13
anyways [1] 454/5
anywhere [1] 394/7
Apartment [1] 351/20
apologize [6] 320/18326/16379/22
413/11431/19460/10
apologizing [1] 250/20
Apparently [1] 245/2
appeal [1] 446/20
appear [3] 258/4305/10323/16
APPEARANCES [1] 231/24
appeared [1] 338/9
appears [3] 302/5369/9403/1
applicant [3] 302/13360/19368/10
application [70] 269/23271/4271/13
301/12301/16304/15305/4310/3311/13
314/19316/10321/20321/24331/10
333/25336/17337/7347/12347/15356/21
356/22357/19358/20359/17360/1360/25
362/16362/19363/3363/4363/19364/25
366/13366/21366/24367/7367/10367/16
367/18368/2369/3369/9369/16370/17
370/21370/22370/24371/6371/12371/15
371/23372/23379/22382/22382/24
387/18387/25388/5388/14389/3389/7
391/1391/3393/12393/15393/20394/6
396/18396/25397/2
applications [2] 356/1381/22
applied [4] 269/22270/4280/9380/6
applies [6] 236/11343/17364/22365/5
365/5378/14
apply [7] 236/16258/18266/11268/21
280/12332/5333/5
applying [4] 359/6371/1371/5393/10
appoint [1] 469/3
appreciate [3] 378/22444/18461/18
approach [1] 398/19
approaches [2] 241/11260/15
appropriate [6] 239/20244/2255/24
261/18413/16416/16
approved [4] 456/16456/17456/18
456/19
approximate [3] 331/20405/12408/7
approximately [17] 248/7325/16327/8
327/11327/13328/6328/8328/11329/10
329/13329/15335/11348/19356/9401/6
410/17422/17
April [6] 272/22272/25273/25274/2
340/2423/5
April 15 [1] 423/5
April 2021 [1] 272/25
archaic [1] 311/2
are [169] 1/8235/13237/5238/5241/24
244/25248/7250/5250/10250/23251/16
252/4252/23252/24254/3254/6254/10
254/12254/20255/5257/10257/18257/18
260/25261/23264/5265/17266/15266/19
266/22266/25266/25267/16270/20
271/19274/19274/20276/9279/21279/23
279/23279/25280/1280/2281/4281/18
281/21283/6283/15283/18283/18284/7
285/6286/2287/12287/15287/20290/23
292/19293/2293/18294/6294/21295/3
295/4295/13300/2300/5300/14303/11
305/9306/17307/2307/9308/1308/8
308/22308/23310/18311/23313/2313/3
313/11320/16323/15324/14325/10326/7
329/17329/20337/14338/6338/6340/15
343/6343/20343/25346/24352/14352/16
352/19352/23352/25353/17355/13
355/16355/19361/16364/22370/10
375/14376/23377/23379/4379/5381/2
381/8385/15387/2387/2387/5387/13
388/24392/18394/12394/16395/11
395/13395/14395/16395/19397/9399/18
400/5400/7401/19409/3413/13413/20
417/20417/25419/3420/6422/8422/9
422/17423/13425/1430/13442/5443/7
443/10443/11444/5447/11450/11451/16
451/20454/7454/8458/11462/20465/1
465/11466/3466/14466/23468/20474/13
area [7] 240/5398/13398/25399/5404/9
404/11405/9
aren't [3] 382/10414/19423/17
arguably [1] 412/17
argue [3] 285/24415/14465/9
argued [3] 411/16415/14415/14
argues [1] 465/20
arguing [5] 449/18454/10461/1465/4
465/10
argument [7] 289/21453/2456/23
457/19459/23462/23472/4
arguments [7] 234/24254/6260/9
264/19266/12461/3468/5
around [17] 243/17251/2278/21376/10
401/11402/6404/24406/3406/13407/17
407/18408/9409/7421/2421/25425/5
431/19
arriving [1] 259/7
articulate [1] 413/11
artisanal [1] 279/11
as [153] 231/6234/16235/17236/7236/9
241/19242/12242/12243/2247/17248/11
248/11249/10251/2251/14251/15251/17
252/3252/11252/18252/20252/21253/18
253/18254/4256/24257/2257/6257/6
257/19258/16258/19259/14259/20
259/22259/22263/19264/4264/4266/6
266/24266/24268/3268/22268/22269/13
269/17271/9274/10278/11278/21279/8
281/9283/3283/6287/12287/13288/2
290/16291/10291/25292/6292/19293/10
293/21295/1295/7295/13295/25296/20
296/24298/18299/8301/13301/16302/15
305/3305/3308/22311/4313/4314/8
330/14331/9333/24336/17338/10341/5
342/24343/16343/16345/2348/3351/17
357/4357/4359/17361/17363/3363/3
363/22364/17365/15366/25367/3369/16
370/22370/23372/6374/23375/17375/17
376/2379/23380/16381/10389/21392/8
395/9398/1399/3399/25401/22404/11
404/17404/21406/6406/6407/7407/22
412/19429/20430/13431/25433/6433/14
437/22441/25442/18446/19448/24
453/12455/4456/22457/12460/17462/15
462/23463/7464/1468/4473/20476/10
Ashanti [1] 278/16
ask [37] 240/22241/5244/5244/18
254/13257/17260/15260/21264/21
264/23267/13290/25338/16346/2393/24
394/2406/21409/15411/2413/18414/9
414/15415/5415/6415/18415/23415/23
428/18430/17439/5446/18449/8456/8
458/9464/8467/20469/6
asked [24] 240/3256/17281/9282/2
287/16326/2361/1392/5411/5411/8
415/9419/1419/7430/2430/3430/6457/5
457/7461/9462/3466/4471/11471/13
472/2
asking [7] 375/25384/4416/2416/24
459/14466/8470/15
asks [1] 457/6
aspect [2] 412/25451/21
assigned [6] 368/23369/17370/10386/7
386/8386/10
assistant [3] 277/16284/8453/18
associated [10] 324/24325/23333/19
342/8349/11363/2365/22372/16373/8
385/15
assume [2] 286/18406/22
assumed [1] 406/17
assuming [2] 417/4445/8
ATLANTA [10] 231/2231/22234/3
398/13398/24399/5404/9404/11405/9
476/6
ATM [1] 399/3
attached [6] 1/5346/15353/2390/1397/4
397/6
attaching [1] 1/8
attention [4] 263/9263/18266/25321/1
attorney [5] 232/2244/10463/4463/11
463/18
audio [4] 458/18459/8470/11473/20
August [2] 273/17341/15
authentic [1] 345/3
authenticity [8] 242/6295/25298/1
310/18313/8350/20362/9364/16
authority [6] 238/23238/24239/9446/4
460/12462/2
authorized [1] 269/16
auto [3] 273/18273/22274/1
automatically [1] 294/6
available [5] 261/24262/21262/25
395/24410/4
avenue [1] 459/2
average [6] 270/10304/1410/17419/7
464/12466/17
aviation [1] 277/20
avoid [2] 339/24413/14
aware [12] 295/14300/14309/10400/5
400/7403/12428/23430/13443/10443/11
455/5466/6
awareness [1] 300/5
away [2] 244/21260/16
awfully [1] 321/1
awhile [1] 422/12
awkward [1] 243/16
B
bachelor's [1] 292/3
back [74] 244/18244/22255/11255/20
260/3261/21262/1262/8262/12263/22
264/23268/25275/20276/23276/24279/7
281/6281/10281/17281/22281/25282/18
284/3285/16286/15286/16286/16286/17
286/18290/25294/10294/13302/25
312/11314/18314/20320/10320/25
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 252 of 281
B
back... [36] 321/10340/11340/12355/4
361/9366/6383/2385/5405/6405/21
406/1417/24418/3418/10420/18425/6
430/7430/22437/5437/18439/6440/21
446/6446/15449/3449/9449/12449/14
457/11464/5464/7464/16465/25466/4
466/25468/25
background [1] 292/2
backstory [1] 278/10
backwards [2] 385/10439/25
bad [2] 244/16319/17
bag [1] 440/17
bait [1] 280/17
balance [5] 284/22284/23284/25285/1
445/25
bam [3] 286/1286/2286/2
bank [46] 236/10268/14270/14271/3
271/11271/11276/15276/16276/18
276/18276/22276/23280/15280/17
281/16281/16284/2286/15286/16286/17
286/18286/18287/12288/2288/3288/3
288/3388/8388/15388/19389/11397/11
397/12430/2430/4430/7437/14437/15
438/1438/12438/13440/19454/18455/7
456/1456/3
banks [4] 268/21268/22268/25269/1
barely [1] 279/23
Base [1] 278/2
based [15] 269/8286/21293/8306/9
306/11384/21392/3393/11414/14453/12
456/16456/17456/19457/17459/3
basic [1] 252/2
basically [12] 292/11325/11407/21
407/25412/23428/16434/4434/11437/11
437/13437/17438/13
basis [3] 268/14271/19272/19
bastion [1] 274/21
be [248]
became [3] 277/22281/14283/13
because [85] 234/11235/2235/4235/24
239/22244/15246/21248/17248/22251/3
254/15254/17259/18266/6266/22267/8
269/3269/4269/19277/21280/20285/16
308/21311/13371/3375/12377/19381/18
391/11394/9395/2406/17407/25408/4
409/4409/19411/17413/23414/18415/1
415/20417/7417/22418/15425/10428/16
430/12440/14442/22442/22444/2446/23
448/7449/9449/19450/22451/20451/25
452/16456/15456/17456/18457/5457/21
458/3459/2462/20465/7465/14465/15
467/10468/3468/21468/25469/20469/21
470/12471/8471/12471/25473/2473/19
475/2475/5475/6
become [2] 263/8281/23
becomes [1] 283/1
bedroom [1] 408/18
been [49] 250/21250/22251/24253/14
256/11269/13269/25270/1272/12274/19
283/21286/3291/9296/23317/10320/4
320/6325/21339/12339/13339/19349/18
368/14368/16370/25379/7395/16396/7
397/25399/10402/12404/1404/21405/1
405/13408/14410/10410/11417/16
417/21420/20420/22431/24433/2435/23
442/20460/12466/24475/20
before [52] 231/11234/24239/9240/4
241/20256/17258/19270/3281/21282/6
282/8282/10282/16282/17288/18288/19
288/20295/1296/8296/25304/13308/1
314/21321/15323/13343/18345/15
364/18368/12372/6399/4400/23403/14
404/17409/1409/8418/21420/3420/21
420/25421/4421/20421/22422/10423/16
429/11433/4438/10450/24465/6469/6
472/7
begin [7] 252/2259/25266/5266/15
274/15301/12322/18
beginning [2] 322/9322/16
begins [1] 446/17
begun [1] 457/8
behalf [10] 268/6269/23270/17274/15
312/16333/3333/21344/14368/11395/22
behind [1] 275/19
being [59] 238/7252/20308/8309/10
309/13309/20314/4315/6315/11315/12
315/15317/20318/3325/1325/3325/25
327/18329/25330/4330/25332/2332/23
333/2333/20339/2340/3342/1343/13
343/20344/2344/11353/5354/12359/14
361/1372/21375/8380/24386/22393/11
394/7394/8395/17408/23413/5413/6
415/4415/22438/21439/1443/11445/11
450/17452/11452/11465/9465/14468/10
470/24
belief [1] 235/7
believable [1] 451/5
believe [32] 239/14253/20257/14
257/14257/16321/25326/9340/13347/16
356/7356/11357/17359/12367/4369/22
382/8383/8385/21385/21386/9386/11
386/24387/16401/19415/11416/13
416/14436/6446/11450/19465/2467/20
believed [2] 290/5404/20
believes [3] 453/5453/6458/4
below [4] 242/23243/2243/3299/1
bench [1] 239/15
benefit [4] 294/3294/7294/13457/21
benefits [3] 294/8294/10308/25
beside [1] 428/24
besides [4] 408/22442/16442/23468/20
best [5] 369/14405/19450/3452/10
454/3
better [9] 235/2317/5374/9386/25
413/11417/9427/18427/19445/18
between [6] 253/15274/20307/18
322/10356/10446/15
beyond [10] 248/21259/15259/21266/8
274/11274/23277/24289/23290/18
290/19
bias [1] 257/25
big [5] 268/11283/23284/12288/10
411/11
bigger [2] 450/8461/13
binder [7] 295/17297/20344/17344/18
359/23372/1434/21
birth [37] 298/21298/23357/22357/24
358/1358/3359/10362/23362/25363/2
365/20365/22367/1367/3367/9369/2
370/22370/23371/20371/22372/15
372/15372/21372/22381/24382/2383/24
384/3384/14384/18384/24385/2390/3
396/3397/6423/4441/17
birthdate [3] 360/17384/15423/24
birthday [3] 380/1380/2382/6
birthdays [1] 284/10
bit [21] 245/6245/7248/25255/5258/16
259/22259/23264/12264/13267/9277/14
283/9299/16317/5319/18394/11398/20
408/10444/19445/21473/20
black [1] 433/21
blame [1] 240/14
block [2] 347/5384/18
blow [1] 436/1
blue [2] 363/6407/18
BMW [4] 273/21421/16421/22448/13
boarding [6] 400/14400/16400/19
402/15402/19403/1
bogus [1] 268/8
book [1] 240/12
books [2] 279/22285/18
bootleg [1] 279/21
born [6] 278/24359/9385/1421/25
422/23422/25
both [28] 239/8253/25265/11266/16
270/19271/21272/4272/6272/6272/10
272/11277/3295/4298/10352/3352/7
355/12355/13355/22356/10371/1371/5
373/2378/22402/20433/13434/16463/16
bothered [1] 463/3
bothering [1] 413/10
bottom [14] 299/18299/20302/7311/18
316/19316/21351/8358/23358/24361/10
363/14367/21381/25382/17
bought [14] 273/17273/21286/23
287/16288/6288/24288/25407/12407/16
407/19407/23409/7409/12426/1
Bourne [5] 271/7327/3327/14327/19
389/14
box [8] 302/19320/7337/15358/17
358/24363/6368/14368/15
brain [1] 256/21
Braves [1] 444/25
break [8] 239/10260/3318/13321/15
373/20373/21444/1444/5
breaks [1] 239/1
brief [2] 393/6458/17
briefly [5] 349/18422/5428/11430/25
469/12
bring [7] 250/12275/9319/24363/12
363/14376/5417/23
bringing [1] 320/25
broad [1] 416/15
broader [1] 378/8
brought [3] 247/19258/22267/8
BROWN [14] 231/11271/6276/17280/14
327/24328/1328/5328/15328/20328/23
389/17390/7390/11390/13
Bruce [6] 271/6334/5334/7334/10
334/16391/2
Bruce Willis [1] 334/16
BS [10] 452/7452/8454/7454/8454/19
457/22457/25464/14465/21467/11
bucks [1] 429/24
buffaloes [1] 454/2
build [2] 409/19461/4
builds [1] 280/21
bullshit [1] 450/7
bunch [2] 275/15452/8
burden [11] 259/1259/2259/3259/18
259/20265/16266/6266/9274/24274/24
289/19
BURTON [2] 232/4232/5
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 253 of 281
B
bury [1] 283/24
business [32] 241/18241/25269/3269/8
269/9269/11269/12269/16269/20269/25
281/5281/7281/8282/17282/17282/23
294/21294/23300/13301/17301/23303/1
303/8303/17386/24387/15395/18415/22
418/17418/18424/23425/18
business's [1] 269/14
businesses [12] 268/16268/21268/23
268/24300/12303/15337/3387/2387/4
387/5419/10419/11
buy [16] 238/1272/23273/19273/23
273/25274/3274/6288/5288/15289/4
289/7289/8426/6426/14426/17440/22
buying [5] 268/11289/3407/9420/1
440/1
buys [1] 288/21
C
calculate [1] 294/2
calculated [3] 285/23306/12395/1
calculates [1] 294/12
calculation [2] 308/24394/25
calculations [3] 294/6307/2340/21
call [13] 249/8265/15265/22265/22
279/21284/1291/4319/7320/2320/3
399/22399/23467/2
called [15] 253/7265/11269/21273/8
276/6279/10287/20294/23319/19367/4
406/1409/4433/5435/16436/7
calls [3] 291/5397/21407/18
came [18] 235/16276/24277/18283/10
288/17288/18380/6403/18404/1406/1
406/1420/16423/10423/14430/3438/11
456/1475/8
can [252]
can't [23] 238/18244/19249/11255/6
257/8257/11274/23290/22299/19320/21
376/1381/14381/15384/2384/2392/13
397/12430/13445/23445/24469/2469/23
473/6
cancelled [1] 456/18
cannot [11] 245/5254/4259/11260/2
260/5374/3375/9377/1377/4402/1402/4
capacity [2] 392/21435/19
Cape [1] 400/17
captain [1] 433/8
capture [1] 339/13
car [1] 237/11
card [16] 356/21360/1360/2360/25
361/2361/14362/17363/4363/20366/13
366/22366/25368/3368/12380/9381/1
cards [1] 379/8
care [5] 276/18294/17427/11427/12
473/19
career [1] 278/1
careful [1] 448/22
CARES [1] 430/13
CARL [48] 231/5268/3273/7273/12
274/10275/11275/17275/17277/11
278/10283/11283/13288/9289/15297/18
297/23298/20302/6302/16339/9341/8
342/17344/25345/9348/2348/5349/9
350/8351/4352/8355/14356/2356/24
357/20360/19360/21364/1365/18366/23
369/18399/14399/19399/22399/25402/3
402/4433/10476/9
Carl Delano [2] 283/11288/9
Carl Torjagbo [19] 273/12274/10
275/11275/17277/11289/15302/6302/16
352/8355/14356/2364/1365/18366/23
369/18399/19399/25402/4433/10
Carl Torjagbo's [1] 297/23
Carolina [1] 461/11
carry [2] 235/4279/16
carrying [2] 279/19279/20
cars [3] 268/12288/8288/15
Cartersville [1] 273/20
case [107] 235/16235/17235/19235/21
235/24235/24235/25238/5238/15248/21
251/15252/1252/13252/19252/21253/24
254/7254/8254/9255/1257/24258/15
258/18258/20258/25259/2259/3259/17
259/17259/19259/24260/2260/5260/10
260/13260/16260/16261/13265/15
265/15265/16265/17265/23265/25266/3
266/5266/7266/11266/18266/20268/1
274/17275/3275/4275/10276/9277/9
284/15286/5288/1289/20290/23293/2
295/7311/9318/14318/17334/21342/3
359/11366/6374/7374/12374/17374/23
376/20376/23377/4377/22377/24395/2
417/12444/20446/10446/10446/20447/8
449/20452/4452/5454/11454/14455/20
455/23457/4460/1460/9460/11461/7
465/11468/10471/1472/16473/5474/8
474/17476/10
case Number [1] 476/10
cases [8] 287/23287/24294/21359/9
461/9461/11468/20468/21
cash [10] 407/5437/11437/17438/1
438/11438/16438/17440/5440/12440/17
catch [1] 267/9
categories [1] 315/15
caught [1] 263/17
cause [1] 235/14
caused [1] 442/19
cautionary [1] 239/18
cave [1] 246/18
cellphones [1] 260/25
Central [1] 292/4
certain [4] 252/20265/21392/17473/22
certainly [6] 248/5417/16459/5459/13
460/11474/16
certainty [3] 290/18290/20290/23
certificate [7] 296/17297/1359/10382/2
384/14384/18476/1
certification [2] 292/5292/17
certifications [2] 292/5292/15
certified [3] 1/14241/18278/5
certify [1] 476/6
Cessnas [1] 278/2
cetera [2] 324/9345/22
CFR [1] 283/4
challenged [1] 414/24
chance [11] 262/4262/8262/10265/11
265/14266/2266/12266/16267/7453/21
453/24
change [21] 248/17273/7275/14275/22
275/25276/24283/16283/19297/22
297/23299/2299/14299/23380/11430/1
454/23456/9457/9463/2465/23474/7
changed [6] 240/1275/22283/14400/5
407/21456/18
changes [6] 234/12234/14275/13
275/17275/18375/2
changing [3] 277/11374/23455/6
character [2] 390/10390/11
charge [2] 268/14375/8
charged [14] 252/8287/19287/20
353/19353/24353/25354/3375/5376/20
377/8377/14377/17377/18396/22
charges [5] 258/20271/20272/19274/11
376/23
Charles [1] 390/10
Charlie [13] 271/6276/17280/14327/24
328/1328/5328/15328/20328/23389/17
390/7390/11390/13
Charlie Brown [2] 390/7390/13
Chase [3] 288/3288/4301/1
check [12] 244/11272/15277/7284/13
284/24285/9285/10285/12285/15285/22
286/9346/15
checked [4] 315/16358/17368/14
368/16
chemistry [1] 277/16
chief [4] 265/15265/16265/25278/11
child [1] 275/24
childhood [1] 287/8
children [1] 417/20
Chinese [1] 278/22
choice [1] 259/12
choose [1] 253/20
chronological [1] 356/16
circle [3] 465/25466/4466/25
Circuit [2] 239/18242/21
circumstance [1] 451/17
circumstances [2] 380/15380/18
circumstantial [6] 252/25253/7253/8
253/13253/16253/20
citations [1] 238/23
cite [1] 1/5
citizen [1] 294/3
citizens [2] 294/17392/9
city [4] 297/11298/23367/4367/6
civil [1] 259/17
claim [3] 235/25236/2436/23
claimed [6] 269/25270/16270/24271/7
271/21377/3
claiming [2] 268/8338/5
clarify [7] 290/2336/13374/16415/1
417/25421/23449/8
clean [2] 258/25259/13
clear [23] 242/5256/24257/6264/13
276/21281/4281/9287/12287/12288/2
322/15357/9376/20383/20395/11399/18
415/18418/11438/20440/24448/21452/3
460/14
cleared [1] 264/14
clearly [2] 258/5260/10
client [2] 396/22468/22
close [9] 234/7245/6248/6266/25
374/12406/24437/10437/20468/11
closing [9] 234/24254/6266/12289/20
437/22437/23438/10468/4471/12
closings [1] 260/9
CM [2] 1/21/3
CM/ECF [2] 1/21/3
Coast [1] 400/17
Cobb [1] 299/5
Cobb County [1] 299/5
cockpit [1] 278/7
code [1] 242/24
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 254 of 281
C
coffee [1] 444/12
cold [1] 234/8
collect [2] 261/24306/25
COLTER [4] 231/20262/18476/4476/18
column [14] 305/17307/15315/10
323/15325/10328/18328/19335/4335/14
335/16338/10338/13340/8436/5
columns [4] 305/9315/24338/15352/3
combined [1] 308/19
come [42] 236/25238/18249/18252/14
255/6255/6255/6255/24256/3260/17
264/15264/22275/5284/17286/1290/23
290/25311/11319/24320/15380/5383/7
384/6418/3418/3423/10423/18442/16
442/23449/2449/4455/22456/1463/11
463/14465/3465/6465/15472/3472/4
474/11475/6
comes [11] 256/17280/24286/16288/13
383/15383/24457/12458/2458/22463/12
474/12
comfortable [2] 376/3474/20
coming [12] 240/21242/14359/8399/4
423/22445/8449/13449/23450/14451/7
463/5467/23
comment [1] 261/19
commission [1] 408/1
commit [11] 276/12289/10289/11
353/23353/25354/2375/13377/8377/14
377/16449/18
committed [3] 273/11354/2377/18
common [3] 257/18282/23423/17
companies [7] 295/14324/24325/23
332/7386/22411/13414/8
company [53] 268/6269/21271/8273/8
273/10273/12278/9278/23280/22280/25
282/20282/21286/21286/23287/3287/11
287/14288/4288/14290/12300/14301/17
301/20304/21311/25312/3312/22322/25
336/10342/8344/7347/22348/7392/3
395/3399/3408/25409/4411/7411/12
418/19418/20419/13419/14419/16
419/16427/6427/10427/24435/16435/21
436/7437/18
compare [2] 351/23355/5
comparison [1] 451/23
compensation [3] 348/9348/25351/23
completed [1] 307/3
completely [4] 270/15279/22454/24
456/9
computer [2] 231/18413/1
computer-aided [1] 231/18
computers [2] 286/2292/13
conceal [5] 287/22287/25288/1289/13
289/16
concealing [1] 289/1
concealment [3] 287/21455/5455/14
concern [9] 268/16356/22412/12
414/13449/9451/10453/16459/10472/23
concerned [1] 253/19
concerning [2] 328/22353/17
concerns [5] 354/15412/15414/2
451/19451/19
conclude [2] 253/9253/14
conduct [2] 251/14259/22
conducted [2] 293/8317/18
confident [1] 274/9
confirm [6] 244/6303/21321/18349/19
351/3355/13
conflict [1] 417/19
conflicting [1] 425/23
conflicts [1] 248/13
confront [1] 425/13
confronted [4] 414/5425/25426/1
453/17
confronting [5] 238/4416/9457/10
458/3465/1
confronts [2] 452/1452/13
confuse [1] 381/18
confused [1] 249/10
confusing [2] 374/7416/8
confusion [1] 356/17
connection [1] 476/11
Connors [4] 232/3244/1364/20446/18
consent [4] 237/20449/21449/22450/11
consider [16] 253/25254/4256/3256/14
256/22257/3257/8257/11258/10353/20
353/22375/9377/1377/7377/11378/1
consideration [1] 258/13
considering [1] 259/7
consist [1] 252/15
consistent [11] 286/4315/5316/3
317/20327/7328/2329/17331/20372/22
460/12467/21
contact [2] 250/22302/3
context [15] 235/18237/24238/3238/13
428/14446/11446/15452/21455/12
455/13458/7461/5461/12465/18474/14
contextually [1] 238/6
continue [4] 245/10360/19468/14
469/22
continued [1] 403/2
continuing [2] 474/4475/5
contract [2] 272/23274/2
contractor [1] 283/6
contrast [1] 467/10
contributes [1] 308/22
controlled [3] 332/7336/10336/13
controller [1] 298/13
conversation [21] 261/20410/24411/15
411/16412/14413/13413/15413/16419/4
419/25420/19426/9427/21428/17428/23
429/2437/7448/8450/24451/22451/24
conversations [3] 407/3408/20459/4
cooperate [1] 464/15
cooperation [1] 457/21
copies [2] 354/7355/25
copy [4] 240/7300/22445/16446/18
corner [3] 299/8305/6323/7
corporation [2] 295/22387/13
corporations [1] 387/9
correct [35] 236/18293/23295/6299/24
306/15312/1316/17332/9336/12344/4
344/15354/21355/14357/11369/14382/8
382/25385/2385/18386/6391/23392/19
395/10396/4396/16397/5397/7397/8
417/1440/4440/14440/20440/23441/23
448/6
corrected [3] 384/6384/8384/15
correction [1] 384/5
correctly [4] 280/19285/23286/11
410/20
cost [2] 279/1408/1
costs [2] 279/1289/3
could [49] 234/16245/10246/22253/14
267/18268/21269/9272/5272/11296/6
296/8299/11307/24312/24313/12321/18
322/1334/2334/24345/6357/8366/6
366/10369/25371/25374/15380/22384/8
385/21387/15390/14402/7402/12433/20
433/22434/23435/5436/1438/5440/22
441/10455/19462/23467/20467/22471/4
471/8471/24471/24
couldn't [3] 410/15416/23440/12
counsel [6] 239/19459/4460/14460/25
463/13470/12
count [3] 234/13236/7236/9
counted [1] 381/7
country [22] 276/1277/18278/12280/22
282/23283/11298/23359/7359/8380/5
380/7381/8383/15383/24384/6390/9
392/4392/6392/8423/10423/14442/17
counts [5] 258/16284/6287/18287/20
287/21
County [2] 234/3299/5
couple [16] 234/10234/25238/11248/13
253/12255/17257/17262/6262/15264/24
265/1373/20402/1444/20461/10468/4
course [10] 234/16257/7258/8261/19
262/3271/24375/11430/5430/20445/15
court [33] 1/31/71/91/121/14231/1
231/21234/4240/7241/5241/13241/21
249/22255/16255/17299/5299/18299/21
376/4400/24455/4460/7460/12460/20
461/9465/8468/9473/8474/17476/4
476/5476/8476/19
Court's [1] 453/11
courthouse [2] 231/21251/6
courtroom [14] 250/18252/14254/3
257/8318/21321/4373/24376/8399/16
412/1412/6418/7433/17445/4
cover [1] 273/14
coverage [1] 306/19
covered [4] 276/5283/9337/14365/3
covering [2] 241/17340/1
coverup [2] 275/19276/3
COVID [4] 268/15280/11300/11430/10
COVID-19 [1] 268/15
CPA [1] 429/22
CR [2] 231/4476/10
CRC [2] 231/20476/18
create [2] 294/24469/23
created [5] 268/20269/21273/8300/12
395/14
creating [2] 453/14455/7
creation [1] 293/14
credibility [1] 258/11
credit [4] 381/18442/20457/17457/18
credited [1] 285/6
creek [3] 253/3253/11253/12
crime [7] 252/8287/5353/24354/2375/6
376/21377/8
crimes [3] 273/11377/14377/17
criminal [7] 231/4252/3258/15258/18
259/17259/18377/5
criminally [1] 292/12
crisis [1] 268/19
cross [8] 265/20378/25379/2422/4
422/6439/4439/7449/4
cross-examination [5] 379/2422/4
422/6439/4439/7
cross-Examine [2] 265/20378/25
cross-examined [1] 449/4
crossed [2] 417/10446/3
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 255 of 281
C
CRR [2] 231/20476/18
Cumming [1] 406/7
current [2] 293/15298/19
currently [4] 291/20291/21398/12399/2
custodial [1] 243/22
custodian [1] 241/19
cutoff [1] 270/5
cyber [4] 292/4292/11292/12292/15
D
da [3] 450/7450/7450/7
da-da-da [1] 450/7
data [8] 293/8293/12293/14294/25
295/2295/5300/16353/2
database [1] 295/1
date [62] 270/5282/10282/14282/16
282/17283/3283/8284/20296/20297/1
298/21299/8299/16299/17299/18299/19
304/24311/12322/9322/16322/16322/18
322/18357/22357/24358/8358/11361/4
361/6362/19362/23362/25363/2365/20
365/22365/25365/25366/25367/9367/14
367/16369/2370/21371/13371/15371/17
371/20371/22372/15372/15372/18
372/21372/22383/24384/3384/23385/2
396/3423/4435/9435/14441/17
dates [3] 381/24390/3397/6
daughter [2] 245/5428/20
day [36] 236/21237/2238/19239/1239/9
244/18245/25247/18247/18247/21250/3
258/11262/1287/12287/13288/2290/16
319/9402/17406/8406/8410/23416/23
419/3420/18420/21420/22420/23423/6
423/8423/9425/3426/4426/6431/9
476/14
days [3] 1/4420/22437/7
dead [1] 390/15
deadline [3] 282/3282/4387/21
deal [3] 241/14445/12450/8
dealership [1] 288/9
dealing [2] 411/9451/16
dealings [2] 381/15437/4
dealt [1] 292/13
December [2] 277/20322/19
December 31st [1] 322/19
decide [21] 252/1252/6252/13254/15
255/23257/13257/16263/5263/7263/8
278/23353/20353/22375/9375/12377/2
377/5377/7377/13377/15469/7
decided [2] 382/15409/21
decides [1] 458/25
deciding [1] 378/8
decision [4] 263/7375/17470/2473/3
decisiveness [1] 431/18
declare [1] 369/12
dedicated [1] 250/5
deduct [4] 285/21285/21306/23343/22
deducted [2] 308/8309/3
deducting [1] 309/8
deduction [1] 307/22
deductions [2] 307/20314/16
deep [1] 427/12
defendant [96] 231/7232/4237/7237/10
237/16238/16246/24252/7258/20258/22
258/24259/3259/6265/18266/1266/2
268/3269/5269/19270/24271/3271/7
271/10271/17272/1272/5272/6272/14
272/17273/2273/6273/16274/8274/9
324/25325/24329/7329/10332/8333/20
336/11336/14339/10341/9342/8342/17
348/2350/8352/10353/7353/18353/21
353/23353/24354/1354/2354/11356/23
362/5364/12369/17375/10376/18376/20
377/2378/24401/10409/11414/5414/6
414/13414/16414/17414/20415/3415/5
415/7418/12419/11419/22421/24433/23
446/8446/9446/12446/16447/7448/22
448/24452/2452/13452/14452/19453/6
458/9459/3
defendant's [18] 237/8238/3259/12
259/14259/21271/15272/21284/16373/7
373/15414/11446/16448/8449/11449/13
451/11458/8465/15
defense [5] 239/19446/5453/13459/4
470/12
defer [2] 249/20249/22
deferral [2] 281/20281/20
definitely [3] 248/16261/14267/7
defraud [1] 287/17
degree [1] 306/21
degrees [1] 292/3
DELANO [81] 231/5231/6268/3269/2
273/7274/10274/15275/10275/18275/18
276/2277/12283/11283/13283/15283/21
283/22288/9288/9289/15289/15297/18
298/20299/3300/1300/1300/2329/5
329/21329/24330/9348/17348/18349/9
356/24357/20358/18360/20360/21
372/13383/14385/16389/5389/19389/21
389/22389/24391/7399/14400/7400/9
400/13403/5403/12404/5404/14405/6
408/21410/22412/17413/10418/23420/1
433/9433/14433/17434/3434/13435/19
436/23437/4438/4439/11439/12439/14
439/16439/23440/15443/7476/9476/10
delay [1] 248/18
deliberating [1] 260/1
deliberation [1] 254/11
deliberations [1] 235/11
demeanor [3] 258/8263/13263/15
demonstrative [1] 280/4
Department [1] 364/11
depend [1] 306/7
dependent [1] 380/2
depending [2] 306/7380/1
depends [2] 359/6387/12
deposit [1] 274/4
deposited [1] 438/12
derived [1] 289/17
derogatively [1] 464/1
describe [1] 402/15
described [1] 468/4
description [1] 308/14
deserves [1] 253/22
despite [2] 450/16465/14
detail [2] 304/18305/7
detailed [1] 252/5
details [1] 410/3
determine [6] 252/7356/5370/25375/16
377/12377/17
determined [1] 460/20
developmental [1] 279/1
dicing [1] 473/20
dictionary [1] 261/11
did [224] 235/1235/16235/25238/2
238/2239/14239/17249/8251/22254/25
257/19257/21257/23257/25258/1258/2
258/4258/6258/9268/10269/20272/17
272/24275/25276/10277/2277/9280/12
280/12280/18280/19281/1281/7282/9
282/15283/2284/9284/10284/14285/5
286/11286/14286/25288/5288/10289/4
289/4289/7289/7289/7289/10289/11
289/13289/16290/3290/7290/14292/7
293/5293/10295/7295/10311/9311/9
312/20313/17313/18314/8314/10315/5
315/14317/9317/9317/19318/2318/3
320/8324/25325/3325/24328/14333/1
333/2333/20334/14334/18339/1340/17
340/18342/6347/18349/9349/13349/22
350/11350/13353/3353/7355/22355/24
369/3369/24371/3371/4373/5373/10
373/13374/21374/24375/13380/23
381/11383/3384/8390/22390/25391/6
399/4399/7399/25402/20402/24403/1
403/8403/14403/15403/16403/18403/21
404/4405/1405/4405/6405/6406/8
406/12406/14406/21406/25407/3407/9
407/12407/24407/25408/3408/5408/22
409/6409/16410/3410/6410/16410/22
411/2411/4412/23414/17415/13415/14
415/16415/16415/17415/17415/19
415/19418/12418/14419/22420/1420/12
421/12423/7423/10423/13423/13427/10
428/5428/18429/2429/22430/6431/4
433/9434/3434/16436/7436/19436/23
437/1438/6438/6438/8438/9438/9
440/24441/1444/10444/12444/14444/16
454/23456/3456/9456/11457/1459/14
459/21459/22461/10462/3465/23467/20
468/3471/6471/7471/22471/25472/1
472/3472/24473/12473/15473/23473/24
didn't [68] 236/16238/1238/23251/23
254/23254/25264/16270/2271/16276/11
276/18281/10285/24285/25288/1288/9
288/10288/18289/15290/7290/10290/12
319/6319/9325/2383/2383/9385/5
387/25390/18390/19390/20407/13
407/21411/8411/17411/17411/17413/11
415/11416/12416/13416/13419/6421/7
421/8424/20425/10426/2426/18426/24
427/5427/11427/12427/12429/10430/21
442/9442/11450/19454/8456/1459/11
459/20459/20471/12471/13475/7
die [1] 446/1
died [2] 278/18278/20
differ [1] 258/6
difference [5] 235/23253/15253/19
307/18322/10
different [72] 235/20239/3239/21243/9
251/13259/17263/23271/17272/7272/9
272/9272/10272/12281/5281/7281/8
284/7284/9292/15305/10314/16314/17
315/24318/3322/7322/20340/1340/1
341/14344/18347/11351/15352/14
352/16352/19352/25364/8367/6367/9
369/2371/3371/6373/7374/6381/1381/4
381/21384/2384/3385/13387/8394/3
395/3395/4395/4401/13401/23401/24
401/25402/21421/20429/20429/20
430/12430/12430/15430/16446/25455/2
455/6456/9460/24
difficult [2] 370/14415/4
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 256 of 281
D
dig [2] 279/15390/18
digging [1] 280/3
digital [1] 427/20
digits [3] 346/24355/19370/4
dime [2] 250/9285/25
direct [13] 241/4252/25252/25253/1
253/3253/6253/15253/19291/17395/19
398/10431/1432/8
directions [1] 281/4
directly [1] 258/5
dirt [3] 279/16279/19280/3
disability [1] 294/8
disbelieve [1] 253/21
discuss [6] 254/7259/24259/25356/15
406/14411/4
discussed [3] 329/18337/10357/12
discussing [1] 239/16
discussion [1] 246/3
discussions [1] 278/22
dispense [1] 241/19
display [2] 252/17262/2
dispute [2] 235/13413/3
disputed [1] 252/1
disregard [3] 256/20393/25394/2
disrespectful [1] 261/19
dissolved [2] 429/22429/23
distracted [1] 263/8
District [5] 1/14231/1231/1476/5476/5
divide [1] 238/17
DIVISION [2] 231/2295/22
do [259]
docket [1] 1/6
document [38] 1/9256/3256/6282/12
282/13284/14285/7295/18295/20297/25
301/9304/17305/2305/3321/19322/7
322/10322/11322/17323/5331/9339/6
344/22350/2350/18359/12359/23360/12
360/16363/13383/3388/3388/14389/4
426/22435/7435/10442/13
documentation [3] 301/13344/1381/3
documents [21] 242/6242/9252/16
270/13276/14276/15276/16276/17
290/16300/2302/1321/22322/4336/16
336/17368/2392/8423/14423/17453/14
453/18
does [128] 238/10239/5245/24259/8
259/8259/8263/6274/22293/20293/21
294/14295/3298/21299/1303/18303/19
304/17304/18304/20305/6305/22306/3
308/20310/13310/14311/20311/23312/2
312/5312/7312/8314/25314/25315/10
315/13316/21324/4324/7324/11324/13
327/16327/18328/22329/9329/21329/24
330/3330/24331/15332/1332/16332/18
332/22333/15333/17335/16335/17
335/23336/1336/3337/13337/24338/1
338/17340/23340/24341/22341/24
341/25343/8343/11343/12343/15347/8
347/9348/9351/14351/16351/19356/22
358/18359/2359/13359/13360/16360/18
360/19360/23360/24361/13361/15362/4
362/6364/3364/4365/15365/16366/9
366/25367/3368/1371/12372/2372/3
372/12372/14380/14381/5388/10417/22
436/21441/16441/19442/14445/25
447/23449/5451/8453/24454/12456/25
458/9461/24463/23464/4469/22470/18
474/15
doesn't [26] 250/6250/7284/16288/24
289/24289/25290/9306/25387/19388/12
415/11442/13449/19450/15453/4453/25
457/1457/11462/24463/1463/1463/9
465/6470/1471/4472/4
doing [23] 241/19262/23262/23279/10
281/18286/12287/7287/12287/13287/22
318/11412/25424/18424/20449/17450/2
450/5451/19454/3454/5457/21466/24
470/25
dollar [1] 250/8
dollars [3] 268/2274/8419/22
domestic [5] 380/20380/24393/11
393/19394/9
don't [191] 235/4235/19237/14237/25
238/1240/9240/14242/15242/16243/15
244/15245/8246/6247/4247/25248/4
248/23249/19252/11254/14259/24260/3
260/12260/13260/14260/14260/14
260/19260/20260/21261/6261/9261/11
261/17261/20262/15263/5263/6263/8
263/17264/1264/1264/1265/3265/3
265/4267/1267/4274/24281/6282/24
282/24284/4286/15286/19312/8312/10
317/4318/10318/14318/14318/16319/13
319/15319/23374/12374/14374/20376/9
380/6380/12380/25381/10381/13382/4
382/11383/4384/10384/13384/18385/1
385/2386/8386/23387/3387/8387/14
387/16387/16387/22387/23387/24388/7
388/13388/13388/16388/16388/17
388/18388/18388/21389/1389/1389/2
389/5389/8389/11389/13389/21390/8
391/4392/2392/2392/17392/18392/20
392/21392/22392/22397/1397/9400/23
406/22411/10411/23412/19412/20
412/24413/3416/8417/7419/3421/7
424/18424/23427/2427/6427/8428/3
429/19434/8434/15439/15439/24442/6
442/24444/19444/21444/23444/23
444/24449/18456/8457/23459/24460/2
460/16461/3461/7461/19461/22461/23
461/24464/1464/4464/17464/22464/25
465/2465/5466/3466/6466/11467/18
467/20467/24468/14468/23468/24
469/17469/20469/20469/21469/23470/8
474/9474/9474/9474/10475/6475/15
done [20] 235/6235/7239/2250/9251/25
266/2266/10267/6279/14280/16290/24
320/22375/7381/7392/21406/6449/17
450/8450/9452/17
donut [1] 469/23
door [3] 237/10237/21448/22
dorm [2] 402/16402/18
double [1] 465/5
doubled [1] 452/19
doubles [2] 452/2452/14
doubt [10] 259/15259/21266/9274/11
274/23289/23290/18290/19290/24
448/20
Douglasville [7] 297/13301/25337/9
345/14347/8405/11406/8
down [40] 245/10253/11261/24262/18
263/13264/5268/12268/15274/3279/16
279/19280/21287/10296/14297/5299/20
315/18319/11322/2325/9327/21332/11
339/4347/25352/3353/13372/25376/14
398/20418/10440/3440/13442/3447/20
452/2452/14452/19457/11465/5475/9
downstairs [1] 261/3
Dragonfly [1] 411/13
draw [1] 451/23
drawing [1] 453/3
drawn [1] 461/16
dredging [1] 457/17
drilling [1] 475/9
Drive [1] 231/22
driven [1] 244/21
driver's [14] 362/4362/16363/12363/23
363/25364/7364/12365/15371/11371/20
372/2372/10372/12372/18
drivers [2] 286/24287/16
drove [1] 420/19
drug [1] 287/23
Dubai [6] 278/21405/3405/4424/12
424/14424/24
due [7] 281/21281/23300/13337/25
343/10393/19460/23
duly [4] 291/9296/23397/25431/24
Durand [1] 250/14
during [19] 241/4262/2262/5268/14
271/16274/5280/10289/20299/25300/11
337/10338/7340/9376/23400/9419/21
460/18469/2474/8
duties [1] 292/19
duty [4] 249/9252/3252/6274/25
E
E71 [1] 351/20
each [16] 234/20253/21260/2260/10
263/5264/6268/9270/17272/5272/8
305/10306/9307/15316/15325/20400/24
earlier [6] 308/11326/2357/4357/12
369/3394/11
early [2] 278/1405/17
earned [2] 331/24392/13
earning [1] 373/10
earnings [7] 272/7293/18294/1294/16
307/19373/6373/8
earshot [1] 264/23
easier [4] 302/12352/4434/24435/3
easiest [1] 464/9
easily [1] 243/17
eat [3] 267/7267/8444/15
ECF [2] 1/21/3
editing [1] 451/20
educational [1] 292/2
effect [1] 237/15
efficient [1] 283/1
effort [2] 273/14381/19
eight [2] 244/22408/18
eight-bedroom [1] 408/18
EIN [32] 282/18282/20303/1303/11
309/16310/4310/4310/6310/8310/13
311/6311/7311/16311/19312/17313/15
313/20314/4314/6314/11314/14343/15
344/8344/10347/17347/20347/23349/17
349/19349/22385/13385/16
EINs [12] 311/3312/21313/4315/4
315/16316/4317/9317/19318/3324/23
325/23343/16
either [22] 250/6253/21261/25264/21
270/22294/22311/8312/21328/23336/9
353/2353/3373/5373/11373/15379/22
379/24386/13386/14395/17459/16461/7
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 257 of 281
E
electronic [3] 339/6341/5342/13
element [2] 241/15241/16
elementary [1] 424/6
elements [2] 377/22378/5
Eleventh [2] 239/18242/21
eligibility [1] 270/5
eligible [4] 269/12269/19270/9283/5
ELMO [2] 267/16321/12
Elon [1] 277/12
else [26] 239/12240/14248/4258/24
264/4302/22321/1374/15378/16390/12
403/24409/13428/23437/1443/2443/12
463/9465/21465/22471/6471/22472/24
473/13473/24474/24475/10
else's [1] 264/2
elsewhere [1] 453/23
employee [27] 270/23294/25303/14
315/7315/9315/10327/4330/14332/17
333/12334/7336/8342/3347/22349/13
351/14351/19353/5389/25394/20394/23
395/9395/22395/23436/24438/21439/1
employee's [4] 307/7308/18309/3309/9
employees [58] 268/17269/14269/17
270/12270/18270/25271/2271/3271/4
295/2300/12304/4308/22309/21309/25
311/25312/3312/17316/11316/12317/11
325/10326/7326/11326/12326/13326/15
326/18329/18331/21334/18335/11
335/19338/7340/9340/17341/20343/6
343/24343/25344/3344/11344/14388/3
388/21389/9389/12392/6394/17396/7
410/17410/19418/24419/2419/8419/23
431/3456/20
employees' [1] 343/23
employer [33] 249/9249/9294/17294/18
306/24308/21308/22309/2309/17311/5
324/24332/5333/5333/18334/21337/6
338/25340/4342/6342/24344/6346/21
346/24347/2347/5347/10348/3351/17
394/16395/12395/14395/19395/24
employer's [3] 308/18337/2347/6
employers [5] 306/22307/1307/5308/23
394/12
employment [6] 282/19292/6320/16
332/23373/10408/22
encouraging [1] 426/17
end [41] 236/20237/2238/19239/1
244/18245/25248/23252/6252/9253/23
258/11259/2259/16261/25263/22295/3
303/18304/3304/25306/8319/8322/9
322/16322/18354/6364/21374/17377/21
378/4378/12395/15404/4407/9423/23
438/6444/22445/11450/9450/15457/20
458/17
ended [2] 385/18416/2
ending [17] 310/13311/7311/16321/15
339/1340/4342/4343/15344/7347/11
347/16351/15359/21360/3360/23363/5
363/10
ends [4] 268/18339/21447/10450/17
enforcement [2] 291/23291/24
engage [1] 375/15
engaged [6] 353/21375/10375/17377/2
377/5378/9
engine [1] 277/23
enough [7] 242/2243/14249/24250/4
250/9267/24444/17
ensured [1] 248/15
enter [1] 368/22
entered [4] 250/18321/4376/8418/7
entire [5] 293/13324/5325/4325/6
460/25
entitled [7] 264/5268/9269/8271/23
272/1285/25286/13
entry [1] 1/6
environment [1] 294/5
environmentally [1] 279/24
environments [1] 412/18
epitome [1] 250/8
equals [1] 338/12
equation [1] 338/11
error [1] 383/24
especially [1] 395/13
essentially [20] 239/21241/13294/9
295/3298/18301/12303/8315/23325/14
338/11339/21358/15401/21402/6402/24
458/17459/7470/10470/18470/25
establish [1] 472/10
established [1] 311/14
establishment [1] 301/20
et [2] 324/9345/22
et cetera [1] 345/22
evaluate [1] 238/13
even [18] 243/18252/11260/2264/18
267/1270/2320/2325/3380/18386/25
389/2399/8402/4415/24428/21439/14
456/8462/22
evening [1] 462/2
eventually [2] 278/4388/24
ever [30] 240/12240/12270/23330/25
368/11381/11392/21403/16404/1405/4
408/14409/8409/13409/16418/20418/23
420/12420/25421/12429/2435/16435/19
435/21435/23436/23437/1437/4439/18
442/7466/25
Evert [1] 232/3
every [9] 288/6294/3315/9315/10
376/10381/19402/17419/23434/19
everybody [19] 239/5244/9247/8251/10
251/24261/2263/2267/12267/24287/6
287/7287/11321/6427/22428/16428/19
444/4444/6449/5
everyday [2] 290/21290/21
everyone [3] 325/12325/15325/18
everything [21] 235/9260/5262/10
262/18263/14264/15268/15276/10277/8
280/18280/19284/13289/14378/12
381/17437/13444/21453/8455/19455/23
474/15
evidence [98] 239/24240/21240/21
243/13252/13252/14252/24252/25
252/25253/3253/8253/8253/8253/13
253/16253/19253/20253/21253/22
253/25254/1254/4254/4254/6254/10
254/11254/12254/13254/17254/21
254/23255/1255/5256/16257/1257/3
258/7258/16259/4259/12260/8260/23
264/7265/7265/19266/18266/20266/20
266/23267/2269/2270/2270/8271/1
272/20273/9274/7275/4275/5275/5
275/15276/3276/12277/9280/5281/9
286/5288/24289/10296/4315/14318/3
353/15353/17353/20353/22354/20
359/14361/11361/16363/15364/21
367/22370/23373/13376/18376/25377/2
377/4377/11378/2381/23382/16384/22
413/8452/5454/19457/4
evidentiary [1] 455/24
evils [1] 240/17
exact [3] 286/3374/20392/20
exactly [10] 282/5286/3308/13311/1
384/20392/23413/25427/1438/16452/12
examination [15] 241/4291/17379/2
393/8396/14398/10422/4422/6428/12
429/8431/1432/8439/4439/7443/5
EXAMINATIONS [1] 233/1
examine [2] 265/20378/25
examined [5] 291/9369/12397/25
431/24449/4
example [6] 237/9254/22305/13402/2
464/8464/9
examples [2] 314/22420/6
except [2] 235/9437/5
excuse [4] 243/14248/20250/2411/6
excused [5] 249/17397/14428/10431/7
443/21
exercising [1] 461/20
exhibit [80] 255/25284/16295/18296/3
296/6296/11296/15297/6297/19297/21
298/5298/6298/7299/12300/18301/7
304/11310/10310/11310/19310/21314/2
314/19321/10321/17326/24329/3331/4
334/25336/19341/2344/17345/3345/25
346/19349/18349/24350/4350/7350/18
351/12352/12352/13355/5355/5355/16
355/19356/14356/18356/19357/1357/8
357/18359/22360/7360/13361/25362/9
362/13363/14364/6364/15365/11366/7
366/10366/12366/16366/19369/25370/1
371/8372/1372/5372/8386/1386/3
386/15391/14434/22446/19
Exhibit 1 [5] 295/18296/3296/6296/11
386/15
Exhibit 10 [3] 372/1372/5372/8
Exhibit 101 [5] 300/18314/19321/10
321/17434/22
Exhibit 11 [3] 361/25362/9362/13
Exhibit 12 [3] 364/6364/15365/11
Exhibit 13 [3] 297/19298/6298/7
Exhibit 2 [1] 366/7
Exhibit 201 [6] 344/17345/3350/4
352/12355/16370/1
Exhibit 201A [1] 284/16
Exhibit 202 [6] 349/24350/7350/18
352/13355/5355/19
Exhibit 3 [3] 310/10310/19310/21
Exhibit 5 [4] 314/2349/18386/1386/3
Exhibit 7 [4] 356/14356/18357/1357/8
Exhibit 8 [4] 359/22360/7360/13363/14
Exhibit 9 [3] 366/10366/16366/19
exhibits [7] 252/16252/18261/23312/24
313/9355/2364/17
exist [4] 290/11290/12309/16386/22
existed [1] 289/25
exited [4] 318/21373/24412/1445/4
expats [3] 290/6392/15392/16
expect [5] 266/17266/18343/21343/25
414/10
expectation [1] 448/23
experience [5] 291/23292/18295/13
336/24384/5
expertise [1] 300/8
explain [18] 241/23252/9252/11255/4
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 258 of 281
E
explain... [14] 266/17277/4284/10
305/20306/22310/25337/1374/9400/18
401/18401/25406/25446/8446/9
explained [2] 234/13414/5
explaining [6] 235/4237/13237/18252/2
456/14458/5
explanation [3] 414/11416/16457/2
express [1] 414/12
eyewitness [2] 253/1253/6
F
F-1 [1] 277/18
F-O-W-L-E-R [1] 291/15
face [1] 265/5
Facebook [4] 283/20439/20439/21
439/23
fact [17] 252/1253/1273/2276/7283/4
377/2378/9387/19414/4438/6442/17
442/19447/25452/14460/21461/6471/14
facts [7] 252/20252/21253/8253/9
258/10266/18374/23
fail [1] 268/16
fair [4] 242/2357/13416/14472/2
fairly [1] 237/17
fake [10] 269/21270/15390/7390/8
428/4449/25451/1464/14466/22467/2
false [12] 269/24270/1270/7270/12
270/15270/18271/1271/9271/14271/24
292/25449/25
falsely [1] 268/8
familiar [6] 271/5294/4303/11359/23
409/1409/3
family [1] 279/12
fancy [1] 268/11
FAPR [2] 231/20476/18
far [4] 253/18318/15414/4417/11
fascinating [2] 285/8285/13
fast [1] 277/12
fat [1] 284/12
father [3] 234/8244/21277/15
fault [1] 417/14
FBI [5] 280/23287/7291/25292/7292/11
February [16] 269/13270/5282/3282/4
282/7282/9283/7304/25305/1305/1
318/7324/2326/3337/15371/16387/21
February 15th [4] 270/5282/7282/9
283/7
February 2020 [1] 326/3
February 20th [1] 371/16
fed [2] 305/13324/8
federal [3] 270/17337/2352/16
feel [5] 242/21244/15246/17247/23
463/17
feeling [2] 267/12444/4
feels [1] 413/4
feet [1] 408/19
few [7] 306/25310/3314/22316/7379/6
424/13439/9
FICA [34] 305/17305/18305/18308/12
308/15308/20309/1309/24312/16313/24
315/2315/6315/12315/25316/16317/22
323/17323/24324/21325/17327/13
328/11329/15330/4330/18330/25331/19
332/23333/16334/11334/15336/3344/13
396/23
Fifth [4] 461/20470/13473/4475/4
Fifth Amendment [2] 461/20473/4
Fifth Amendmenty [1] 475/4
figure [4] 335/23336/1336/3345/17
figures [1] 308/6
file [16] 231/4277/3284/9294/25295/1
295/1337/3387/6392/7392/7392/19
446/18454/8471/23472/25473/25
filed [27] 1/21/71/9273/6277/2277/5
284/8284/8285/10299/4299/8299/18
299/20339/12340/3344/9366/7368/11
381/3388/1388/7388/20389/2389/2
389/5391/7454/8
filing [4] 300/16358/21387/7387/24
filings [1] 445/14
fill [1] 337/4
filled [1] 395/14
final [1] 342/22
finally [8] 272/16275/25283/14317/22
324/21334/2336/3342/19
financial [1] 437/4
find [16] 240/12243/16245/5274/9275/1
277/12283/22339/1342/6344/6347/18
349/9349/13349/22378/4407/12
fine [10] 243/7247/9248/18374/4397/11
415/11445/19449/17461/18468/24
finish [2] 265/17400/22
FINLAYSON [9] 232/4232/5244/6357/9
414/18459/10468/3468/4475/15
Finlayson's [1] 415/1
fire [1] 244/21
first [64] 235/5238/12239/22249/17
250/13250/20254/4257/19258/19259/24
261/18265/25268/5268/13272/2275/14
276/23286/14287/19291/4291/9291/13
307/12308/13310/2314/23318/8323/10
324/1328/18328/18337/18340/12340/16
344/17351/25355/6356/6356/8368/15
370/22370/22370/24379/10379/11382/5
382/5382/6397/25398/5398/6400/18
401/3412/5412/13420/15421/2431/24
432/3433/7436/5439/11445/20471/4
fish [1] 253/12
fishing [5] 253/3253/4253/11253/12
253/14
fit [2] 374/23467/14
FL [1] 361/19
flatout [2] 426/24427/14
fleet [1] 274/6
flew [3] 278/2288/20440/17
flickers [1] 302/9
flight [2] 277/21278/1
flip [4] 351/24464/5464/7464/16
flipping [1] 340/12
float [1] 457/9
floating [1] 466/23
Florida [10] 277/19292/4362/2363/18
363/22364/3371/10403/22403/23407/20
flowing [1] 455/8
flows [1] 474/15
fluctuate [1] 306/11
fly [5] 278/5278/5432/21456/23462/24
Flydubai [1] 278/6
flying [1] 424/19
FlyingJack [8] 273/9286/20287/11
454/23455/4455/7455/8456/4
focus [2] 361/19425/15
fold [1] 247/19
follow [7] 237/6238/10252/10252/11
383/16396/12452/4
follow-up [3] 237/6238/10396/12
following [1] 1/1
follows [3] 291/10398/1431/25
food [1] 267/8
foot [2] 274/3457/21
Force [1] 278/2
foregoing [1] 476/12
foreign [4] 392/3392/4392/6392/13
foreign-earned [1] 392/13
forensics [1] 292/16
foreperson [1] 235/10
forever [1] 415/20
forget [1] 263/17
forgivable [1] 430/8
forgive [4] 298/24299/19430/18430/21
forgiven [8] 281/6281/12429/15429/16
429/18429/25430/6430/17
forgiveness [3] 281/10282/2287/17
form [19] 286/4336/24337/1337/4
337/19337/24339/12339/16344/23
345/22346/14350/3350/5361/4361/6
369/7369/13382/13476/12
format [1] 234/21
former [2] 339/10433/10
formerly [3] 268/3274/10275/10
forms [12] 252/15307/9359/7369/14
386/22394/12394/16394/19395/11
395/13464/10466/11
forth [4] 312/11357/4446/7446/15
forward [4] 245/11246/23256/24299/25
found [7] 246/13311/19313/20313/25
314/11407/15407/23
foundational [1] 413/6
founded [1] 278/9
four [14] 273/4275/12275/16275/16
313/14314/6346/24355/17355/19369/21
370/4402/12437/12437/14
Fowler [39] 291/6291/8291/14291/19
293/2297/19298/17300/5301/9304/13
307/14310/2310/25312/20314/18321/10
321/15322/4326/20327/2336/24343/18
344/16344/22345/9346/21348/12352/7
355/2356/14359/22363/18366/10371/25
373/2379/4393/10394/11397/17
France [1] 245/4
fraud [25] 235/19235/19235/20236/11
236/11268/5268/13268/14271/19272/18
272/18273/1273/3276/12280/15285/25
286/12289/11289/11290/8292/13292/22
380/16380/16415/16
fraudulent [6] 268/4268/7271/16271/18
271/19284/25
fraudulently [3] 274/8287/5290/15
freight [2] 286/20288/4
friend [5] 287/9410/11414/2425/18
425/20
friendly [2] 279/24434/16
friends [1] 439/18
front [4] 234/25238/16308/4445/13
frustrated [1] 246/1
full [5] 1/8269/24270/15283/11436/12
full-time [1] 436/12
Fulton [1] 234/3
fun [1] 275/23
funds [5] 238/1289/3289/8289/17455/6
funneled [1] 273/13
further [10] 374/16374/21393/4397/13
430/24431/1439/3443/1443/20461/23
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 259 of 281
G
galamsey [2] 279/10279/10
game [1] 450/10
garage [7] 237/10448/15449/22450/12
450/18452/17465/22
gather [2] 389/1389/8
gave [5] 280/18286/8438/11438/16
447/23
Gene [7] 271/6276/17330/15330/17
330/21331/1390/15
general [7] 291/22292/21300/9300/11
337/2392/10392/11
generally [6] 252/24337/1370/9370/12
380/8380/18
generated [1] 285/11
gentleman [1] 444/10
GEORGIA [23] 231/1231/22234/3245/5
272/23273/20273/24282/10295/11
295/21296/21297/13302/1372/11386/19
403/25404/1404/3404/5404/6438/11
440/17476/6
get [81] 237/14240/3244/9246/25
247/19248/11248/14248/15260/21261/3
262/1263/17263/22264/12265/14268/22
269/6269/8269/9277/8280/3281/6294/5
294/10294/13306/18307/5307/9307/10
307/19319/19319/24320/15355/3364/20
370/13380/9380/11381/1381/4382/10
384/8387/20393/10393/18395/14395/20
406/5407/20408/3412/4413/12417/22
423/13425/2425/15425/19425/22426/6
426/7426/14430/17431/12448/10449/18
450/12450/13452/17452/18453/24
459/14465/22467/22468/11471/7472/1
472/3472/16473/15473/19473/24
gets [10] 275/12285/3288/21294/18
296/17307/12379/19383/20383/23
423/23
getting [9] 234/7248/6267/7275/15
321/1339/21350/15416/25475/16
Ghana [42] 277/14277/15278/8278/11
278/16279/10279/10279/13279/25290/7
298/25343/22358/4367/5367/6382/2
382/7382/9382/10382/11383/7383/9
383/12383/12383/21383/23384/10
384/15399/6399/23400/17401/12401/18
401/23402/16422/14422/23422/25
423/22427/3429/4435/23
Ghanaian [6] 359/11382/14382/21
383/3423/11423/17
give [38] 236/4238/23239/9239/20
240/4240/25243/13245/19245/21245/22
248/5252/4253/21253/23257/2258/17
259/15260/22265/11266/10267/14
285/14286/8290/22353/14354/6374/24
377/22436/23437/1437/17438/23447/11
450/11453/21464/9465/5472/8
given [7] 235/18240/2271/12313/4
375/1417/1464/6
gives [1] 451/12
giving [5] 375/20438/17447/7448/23
452/8
glad [1] 461/8
glaring [1] 272/3
go [108] 235/10237/14239/1242/25
244/18245/11247/11249/17250/21
255/20256/24258/12260/3261/14262/8
263/24267/4267/5267/6267/9268/17
275/20279/15283/16283/16283/23
286/14292/7294/6296/14297/5301/6
301/15303/4310/23312/13314/18314/20
314/22316/18320/22320/25321/7322/1
326/20332/10332/11333/8334/2334/24
339/4341/2342/11342/19345/12345/24
345/25346/4351/11354/23358/6360/10
360/14361/4367/13368/6371/8373/22
380/1383/2383/9385/5385/23394/3
397/17398/22402/17402/18402/20405/4
416/15418/10424/20425/2426/4427/10
427/12431/17439/25444/2444/6444/11
444/24446/2450/13450/18452/18454/15
456/15457/12457/16461/23467/2468/19
468/25472/7474/22475/14
goal [1] 417/21
goes [9] 234/17265/10265/25266/1
281/20286/15286/17294/20388/18
going [215] 234/11234/23236/2236/24
237/18237/19239/24240/5241/13241/22
241/23242/13243/18243/24244/13
244/14244/17244/21245/23245/24
246/23246/24247/4247/5247/6248/1
248/10248/20250/2250/2250/4250/10
250/10250/23251/1251/12252/2255/10
262/16263/9263/18264/12265/10266/15
267/4267/5267/5267/8267/8269/23
270/13271/2271/9271/15272/16272/18
274/15275/3275/5275/14276/8276/8
277/1277/4277/4277/10279/12279/13
280/4280/13280/20281/4281/18281/21
281/24282/12282/13282/13282/18
283/16283/22284/1284/2284/3284/7
284/10284/14284/15284/15285/8285/11
285/16285/24286/5286/21287/8287/10
289/19289/20290/17290/23290/24
290/25299/25304/3304/10312/11312/13
314/18314/20314/20316/7318/12318/16
320/10320/12320/15321/16325/9326/20
327/2338/16338/22339/24339/24339/25
340/11341/12344/16346/2346/18352/3
354/6354/11355/3355/5356/15373/21
373/22375/4375/5375/19375/25376/5
382/22385/12393/24394/1394/2401/22
406/14406/20407/4407/5407/20407/22
408/1411/12412/25413/13413/17413/22
414/1414/1414/7414/10414/12417/4
417/9425/22427/3437/10437/19439/5
444/1444/2444/5444/10446/1446/4
446/5446/11447/4447/4447/9447/11
447/19448/7448/14450/11450/13451/11
452/7452/18453/1453/13456/15456/23
457/9457/19457/20457/22458/11460/10
460/13462/1462/12462/13462/24467/11
472/8472/9473/19475/2475/17
gold [6] 278/12279/6279/7279/20280/3
427/10
goldmine [10] 343/21392/6414/7414/8
415/21427/3427/15428/4428/7429/4
goldmining [3] 411/9415/22427/8
gone [6] 259/23266/21308/12355/12
378/3437/15
good [22] 243/12251/11258/1264/4
267/12268/1274/13379/5397/17398/12
408/10413/8414/18422/9422/20432/10
441/8441/8450/5454/5473/20475/11
Google [3] 260/20277/12428/19
Googled [4] 409/21409/23426/22442/7
got [56] 234/10234/18241/7242/4243/9
248/21250/10256/21268/2268/4268/5
268/10273/5275/6275/8276/20279/6
281/5282/20284/25287/22289/9289/22
290/10320/11320/22375/8375/24376/15
379/6379/11385/20388/22390/23408/2
411/21414/9417/20418/4424/23429/13
435/16438/4438/17441/4441/8441/23
442/1444/9444/12444/22448/15450/8
458/25471/21472/7
gotcha [1] 321/13
gotten [6] 260/8288/16288/17289/8
414/13446/4
government [44] 235/17236/1236/22
258/23259/1259/14265/14265/22265/25
266/2268/20268/23268/25274/22275/12
276/14276/20280/1281/2282/3282/11
285/23286/16286/17286/18289/22
290/22337/5344/4377/23378/20382/10
382/13388/23397/21429/15430/3430/15
445/22449/2453/8457/1463/23472/8
government's [20] 246/19249/16275/2
276/4284/15290/10296/3313/8350/17
357/1360/7361/25362/9364/5364/15
366/16371/25372/5386/15434/21
grade [5] 401/13401/17401/22402/13
424/8
grades [1] 401/14
graduate [1] 402/24
graduated [1] 277/20
graduation [2] 402/21402/22
grand [10] 316/21317/1317/6317/13
317/22317/25321/16335/2335/4430/1
grandfather [2] 278/10278/14
grandpa [3] 278/18278/19278/19
granted [2] 299/14299/23
great [8] 253/17278/10278/13278/19
280/1435/14467/10468/2
greater [1] 264/5
greatly [1] 417/6
greed [1] 269/4
green [9] 454/20457/13457/14458/2
458/13472/6472/7473/1473/21
grocer [1] 245/4
gross [18] 307/15307/18308/1308/9
324/8324/12328/19328/20328/23329/22
330/21331/24332/1335/5335/8335/11
335/18436/14
ground [2] 280/2427/24
grow [1] 399/4
guarantee [1] 268/24
guess [19] 240/23246/14247/24249/6
256/10265/4324/8336/13383/7384/17
386/15387/17389/11407/19430/2440/9
456/2461/3469/14
guessing [3] 255/10383/2383/9
guilt [3] 258/24259/15259/21
guilty [7] 252/8252/8258/21274/10
274/23275/1291/2
guts [1] 413/4
guy [5] 272/12414/24416/2416/21457/6
guys [1] 422/17
H
ha [1] 282/11
Hackman [7] 271/6276/17330/15330/17
330/21331/1390/15
had [136] 234/25239/15240/3245/6
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 260 of 281
H
had... [132] 248/11248/15249/9253/14
261/2268/2269/3269/11269/12269/14
269/15269/16269/25270/1270/8270/10
270/11270/25271/1271/12271/22273/1
273/11276/11276/15276/16277/24282/4
282/6282/18286/3288/18288/20290/1
290/4290/6292/14304/13315/4316/10
317/10319/17320/4320/6321/25325/20
326/9329/10339/12339/19343/24347/22
350/14350/19353/23353/24368/14
368/16368/22370/21371/6375/12375/14
375/15375/16377/7377/12377/13380/5
382/2383/13396/8407/19408/2408/20
409/8409/19409/20409/25410/7411/15
414/1415/20415/20418/20418/23419/4
419/10420/18420/20420/22421/4421/16
421/16421/20425/18427/18428/7428/22
428/25428/25429/3429/11429/16430/2
430/17430/17430/18434/8437/4437/25
438/5438/21438/25440/5440/9442/16
444/7445/18451/18452/19452/19456/21
458/16459/7459/10459/18461/9468/21
475/19475/19475/20
half [7] 240/23247/21302/25432/15
433/3434/11437/6
half-hearted [1] 240/23
halfway [2] 459/3459/13
hand [6] 239/14251/19262/7279/14
279/16431/21
handles [1] 251/14
hands [3] 268/2268/10279/15
handwritten [1] 299/16
happen [11] 237/18242/22243/25
248/16257/10260/13380/14381/5409/6
424/1475/8
happened [7] 252/7277/5284/11286/6
319/4419/25451/22
happening [1] 268/19
happens [6] 320/14320/15338/11
380/20441/25449/2
happy [1] 447/1
hard [8] 248/22276/2299/7299/16
316/25318/13358/10400/24
harm [1] 292/25
has [57] 1/7235/7235/14239/19244/24
245/4251/24259/3259/6259/20264/6
266/2282/1282/3289/22296/23305/10
306/11322/20340/21349/18352/3358/8
366/8368/10377/23378/24380/18383/21
383/23395/19414/18415/10417/16
417/19417/21427/22428/16429/20
429/20434/1442/17442/19442/20442/22
445/14445/22448/9448/22456/8460/14
460/20466/8468/5470/23470/24471/2
hasn't [1] 475/6
hate [2] 246/18248/24
have [295]
haven't [6] 249/8308/12417/10446/4
464/4466/9
having [20] 235/14244/21252/20273/9
291/9334/19349/10354/11370/18397/25
413/15414/6415/22418/23431/24442/16
442/23444/7469/16471/10
he [454]
he's [64] 245/5248/19255/10255/10
276/1277/4281/17281/17282/20282/21
283/21284/10285/19285/19287/18
287/20288/21289/1374/4375/5379/25
383/14384/1390/15396/24399/17401/11
410/10412/13412/16412/25413/1413/1
413/22413/25414/1414/5414/10414/12
414/23416/18416/25417/20433/19
433/20433/21437/12439/16443/10447/5
449/19449/24449/25450/14451/3451/3
453/16455/1459/8462/25463/8465/16
468/13473/2
head [6] 263/13264/18277/16410/12
412/6466/7
hear [53] 239/24246/6252/18252/19
254/3254/16255/3256/6257/7258/2
258/10258/17260/5269/5269/7269/10
270/18270/21271/10271/11271/15
271/24272/13272/16273/2273/6273/15
275/21276/6277/1277/4279/13281/16
281/25282/18284/1285/16286/22287/8
289/19289/20290/17353/17354/11
411/17411/18412/21413/13417/5417/7
418/4461/24470/18
heard [20] 249/8260/4260/7260/8
264/15264/18275/2275/3276/20289/18
318/15376/16376/18376/23409/1409/8
415/21416/22444/20452/22
hearing [9] 264/25264/25274/7378/14
446/19446/20460/18464/2476/11
hearsay [6] 238/7238/12412/25413/4
465/8465/14
hearted [1] 240/23
held [1] 476/8
help [11] 254/8266/23280/10300/12
386/3437/17438/5440/15452/7471/4
473/18
helped [2] 417/25441/3
helpful [2] 235/3453/4
helping [3] 416/6438/6441/1
her [8] 247/18332/23368/10390/25
400/22400/22441/12441/12
here [67] 234/25240/3243/15245/2
246/25248/19249/13250/3250/22252/16
255/10260/22261/24261/25264/22
274/16274/17274/18275/6276/21282/23
289/9290/7290/15290/23297/8312/7
316/8318/6319/7319/16319/24320/10
321/2324/4331/19335/2346/15348/24
349/3357/21361/16374/3374/4381/10
383/22388/24391/12394/7396/17399/10
401/19401/21403/4403/14404/1404/5
417/7442/23444/13451/9453/7453/13
454/17460/22475/17475/19
Here's [5] 265/10281/3464/20464/24
472/23
hereby [1] 476/6
herein [3] 291/9397/25431/24
hesitate [1] 262/15
hey [5] 406/2407/19428/3457/8468/23
hidden [1] 427/2
hide [7] 273/2273/10275/20277/13
283/18283/23287/24
hiding [1] 288/25
hidy [1] 288/7
higher [1] 259/18
highest [1] 289/23
highlighted [7] 446/22446/23446/24
447/5448/4448/5457/13
Highway [1] 362/2
hill [1] 446/1
him [174] 237/13237/18237/23237/24
238/4238/9245/5245/16245/18245/19
245/21245/22246/6246/20246/23246/25
247/2249/8250/23251/2251/2251/2
251/6251/7255/13255/13271/12273/10
274/23275/1277/4277/6277/8280/18
280/24284/12284/24285/9285/9285/10
285/14286/8286/8286/13287/9329/22
329/25330/4330/22336/14384/21384/23
391/25399/16399/22399/24399/25
400/13400/19401/5402/20403/20403/21
404/17405/4405/22405/22405/23406/10
406/16407/10407/13407/17408/2408/11
411/2411/5411/6411/8411/18413/9
413/18414/9414/10414/15414/24415/5
415/6415/11415/14415/20415/21415/23
415/23415/24416/3416/9416/21417/2
418/14419/1419/7419/15421/18424/14
424/16425/1425/3425/13425/15426/6
426/7426/17426/19426/20427/21428/18
429/3433/12433/14433/20434/16437/6
437/8437/16438/11438/16438/17438/17
438/24439/1439/18443/11445/16447/23
449/14449/14449/18449/18449/20
450/15450/17450/25450/25451/5452/13
452/16452/20453/21454/10454/14456/8
457/10458/5459/10459/14459/18464/8
465/1465/4465/5465/17465/18465/20
466/25467/11467/12467/20470/8470/15
470/25471/1471/13471/16
himself [1] 389/6
his [120] 238/2238/6238/13246/14
249/9249/9259/4268/2268/6268/10
269/25270/18271/4271/8271/13271/23
272/6272/8273/1273/3273/5273/7
273/10273/11273/12275/13275/17
275/18275/22275/24276/3276/15276/18
277/11277/15277/15277/21277/23
277/23277/23277/24278/1278/3278/3
278/4278/13278/19279/3279/5282/5
282/20283/11283/20283/20284/8284/18
284/24285/1288/8288/14288/17288/25
289/6289/14289/16299/2365/2368/10
380/25380/25383/24385/5391/12400/5
404/17407/21409/4412/15412/15412/16
412/21412/21412/23413/7413/7414/2
414/18414/23416/4420/19420/23421/17
425/10428/18429/10436/24438/12
439/14447/7448/15449/20453/9453/9
453/17453/17454/11455/6457/2459/5
459/15459/20462/6463/2463/7467/13
467/23471/14471/15473/2473/4
history [4] 278/10293/13408/21419/21
hit [5] 272/21273/1273/5405/15470/13
hmm [13] 237/12339/17355/7405/17
432/24439/17440/2440/8440/16443/9
466/21468/16469/10
hold [11] 241/22281/22284/3292/15
350/11393/23393/23400/22412/4414/3
453/20
holding [1] 253/12
hole [2] 279/15279/19
holes [1] 280/2
home [5] 307/25402/17402/18444/24
455/22
homework [1] 450/9
honest [4] 414/3450/17452/9452/11
Honor [99] 234/15236/24239/13240/18
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 261 of 281
H
Honor... [95] 241/1241/12242/3242/5
242/12243/1244/4246/9247/10247/12
248/5249/25267/15291/5295/24296/5
297/25298/8298/12298/14300/25310/17
310/22312/6312/14313/6318/10321/8
344/20345/1350/10350/17350/24353/10
354/17356/25357/3357/7360/6360/8
362/8364/14365/8366/15366/17372/4
373/17374/2374/11374/14374/19376/3
378/18378/21393/2393/6393/22394/4
397/16397/21411/21412/12413/14416/5
417/18418/1422/3430/25431/20443/25
446/21447/1449/7450/23451/15452/25
453/10454/1454/16455/1457/15458/11
458/23459/1460/7462/5462/15462/19
466/2466/9472/13473/7474/1474/5
475/12
HONORABLE [1] 231/11
hook [1] 282/1
hope [3] 242/24243/5431/8
hopefully [1] 356/16
hour [5] 318/13318/13318/19318/25
426/11
hours [7] 248/1272/5278/4324/7328/19
436/6436/7
hours/maybe [1] 324/7
hours/quantity [1] 436/6
house [35] 240/13268/11272/23288/8
288/15406/1406/15407/4407/12407/16
407/19407/20407/23407/24408/7408/14
408/14408/17408/18409/7409/12410/12
420/24425/11426/1437/5437/8437/15
437/20437/20440/1440/13440/22441/4
447/24
houses [9] 405/24406/3406/10406/12
406/15407/9407/17408/5425/3
Houston [10] 351/8351/20366/4366/8
432/11432/12432/13437/20440/1440/7
how [70] 246/22247/11248/7254/9
255/6257/2257/14258/9261/9265/10
267/4269/5274/7284/10294/12294/14
306/22307/5307/5308/20318/12323/7
324/6326/3343/6353/15356/9359/6
374/6379/4379/5382/11384/7398/24
400/13401/5401/5401/10401/25406/14
407/4407/15407/25408/1409/3410/17
422/8422/9429/25431/3432/12432/14
433/2434/3434/6437/23438/9438/9
452/3452/9452/9453/6456/17456/19
456/20456/20459/14463/15468/11475/7
however [3] 1/8240/2250/14
Hoyle [1] 278/11
huh [12] 391/20450/6451/4452/6454/6
462/25463/7463/9463/12463/14463/17
464/13
huhs [1] 463/16
hundreds [1] 418/23
hunting [1] 234/8
hurt [3] 441/1442/22467/11
hurting [1] 441/2
hypothetical [2] 383/22384/7
I
I'd [7] 240/20240/21364/14378/17
379/21461/8473/6
I'll [24] 238/25241/1243/14245/9245/9
253/23254/20255/23256/19256/20257/6
257/6258/11263/20266/8266/10336/20
349/17398/19402/2406/5427/23460/17
469/12
I'm [176] 234/7234/11234/20234/23
235/23236/5240/11243/3243/5243/12
243/18244/13244/14244/17245/23
245/24246/21246/21246/24248/20250/2
250/2250/4251/12255/10262/7265/10
267/7274/15275/3279/11280/4281/23
281/24283/12284/2287/10287/10290/24
290/25298/24312/11312/13314/20316/7
316/22318/16319/14320/15320/24
320/25322/14326/12326/20335/21
338/16339/24339/24340/11340/15341/2
341/12344/16346/2346/18349/24350/15
350/15354/6355/3356/18362/6371/10
375/4375/5375/19376/5383/2383/9
383/17384/7384/19385/10385/11385/24
386/24391/16391/21392/16393/24394/1
394/2394/13396/16399/3400/10401/7
404/24405/17405/19406/20408/4410/12
413/25413/25415/7417/4417/6419/18
425/2426/21429/17429/23432/18432/19
433/7439/5441/7445/7445/8445/10
446/1446/4446/5446/8446/11446/23
447/3447/4447/15447/17447/17447/25
448/7448/23450/2450/17451/7452/11
452/11453/3454/3454/19456/13456/13
456/14456/15457/16457/25457/25458/6
460/10462/1462/12462/13463/3463/24
464/15464/20464/24466/6466/7466/8
466/14466/15466/16467/9468/6468/9
468/13471/10472/8472/8472/14475/2
475/16
I've [31] 234/18235/6239/2248/21
254/20258/15258/15259/20259/23
266/21283/9284/1321/13378/3379/6
385/20392/21403/25403/25410/11
411/21415/20417/7444/21450/10461/16
464/5466/24468/21474/11475/20
ID [4] 361/20362/17363/12363/18
idea [7] 248/6378/8403/15413/12
427/14428/25428/25
ideas [1] 245/9
identification [23] 282/19303/8303/14
303/18309/17311/6324/24332/5333/5
333/18334/21336/9337/6339/1340/4
342/3342/24344/6346/21346/25347/2
347/10351/14
identifications [1] 342/7
identified [15] 296/20298/18298/21
299/8301/16316/11322/25324/14330/14
333/23343/6348/25369/3370/21433/23
identifies [1] 348/3
identify [5] 303/15366/25367/3394/23
433/20
identity [3] 283/24367/24370/23
ignore [1] 256/10
ignored [1] 470/22
ill [2] 288/16288/17
ill-gotten [2] 288/16288/17
illegal [3] 287/22287/24377/3
image [1] 365/25
imagine [1] 384/13
immediately [2] 460/11465/3
immigrant [1] 276/1
immigration [4] 359/7359/12383/25
384/16
impact [3] 306/9465/14465/18
implication [1] 451/12
important [11] 258/19266/22267/1
274/17274/18290/14290/21378/13395/7
471/25473/9
impress [2] 257/19261/9
impression [1] 264/6
impressive [1] 275/7
improper [1] 473/1
inappropriate [2] 255/8416/19
inclination [1] 250/7
inclined [1] 246/21
include [9] 292/23293/17293/21314/16
343/15353/7360/23372/12454/20
included [1] 362/10
including [4] 259/18292/15325/24
428/18
income [9] 271/18306/7306/11331/16
352/16392/14392/17394/25436/21
inconsistent [3] 348/25449/15450/20
incorporate [1] 282/24
incorporated [10] 283/2386/19386/23
387/2387/5387/6387/8387/14387/15
387/20
incorrect [2] 382/23414/14
independent [1] 283/6
INDEX [1] 232/7
indicate [16] 299/1304/18305/6315/1
324/7324/12329/9329/21332/16337/13
338/9338/17341/22358/20360/17368/1
indicated [4] 296/8311/13345/9458/16
indicates [2] 332/25394/7
indicating [11] 275/6308/8316/15317/1
331/12333/12334/7335/10335/18399/17
433/19
indication [4] 302/19302/22333/2
358/15
indictment [12] 252/8258/22353/19
353/21353/24354/1354/3375/10377/4
377/15377/18397/1
individual [13] 283/5311/9314/23324/1
325/10325/10328/13332/16333/23
348/22394/9416/4433/9
individuals [5] 293/19294/1294/16
306/17370/10
Industries [108] 269/22270/3270/7
270/8270/10270/22270/24271/1271/21
271/25273/13278/9278/24279/5280/10
287/2295/9295/11295/23296/12296/20
297/9300/14301/16302/23304/23309/8
309/17309/21309/24310/7311/14312/17
312/21315/7316/12321/20321/23323/1
325/24326/7327/5327/19328/16328/24
330/1330/5330/8331/1331/13331/16
331/24332/3332/7332/17332/24333/3
333/13333/19334/8334/15334/19335/10
335/19336/10337/20338/8342/8343/2
343/13344/5344/13347/7348/4348/5
348/13349/11349/13351/17353/5373/8
373/11373/14386/19389/24396/8408/25
409/3409/5409/9409/12409/13409/16
409/22409/23410/18416/22418/18419/2
419/8426/15428/24435/13435/17436/8
436/16437/2438/22
Industries' [1] 331/10
infer [1] 253/9
inflict [1] 235/25
influenced [1] 264/2
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 262 of 281
I
info [2] 374/6374/7
information [51] 237/25260/22261/12
269/24270/15271/9271/13272/9272/12
293/16294/15294/15296/9297/2304/14
307/5311/24312/2316/2324/5328/14
328/22338/5338/18339/13339/18339/21
345/1355/3355/12357/21359/3361/13
367/24369/13371/3371/6371/11384/16
395/8396/5407/24408/6409/25410/16
410/21414/14415/19449/12451/1470/16
innocence [1] 259/4
innocent [2] 258/20274/20
insist [1] 450/17
insistence [1] 238/6
Inspector [2] 291/22292/21
Instagram [3] 261/14283/20439/18
instance [3] 240/15449/19453/21
instead [3] 253/10455/8456/20
Institute [1] 277/19
instruct [2] 234/23235/8
instruction [33] 235/9239/15239/18
239/20239/22240/4240/11240/16240/22
241/5257/2257/4259/16260/1353/11
354/6354/8354/19364/21364/24365/3
365/5374/5374/20374/21374/22375/4
375/7375/18376/4377/22378/5378/13
instructions [11] 234/10235/13251/10
252/4252/5253/23260/8264/19266/11
353/15354/7
instructor's [1] 277/24
instrument [1] 277/23
insurance [2] 286/24307/23
intend [3] 242/16245/23290/15
intended [2] 266/23287/17
intent [9] 235/14276/11276/12276/12
353/23377/7377/9377/12377/25
intention [1] 237/4
intentionally [1] 289/11
interest [1] 257/23
interesting [2] 284/12285/3
internal [3] 345/2350/19412/21
Internal Revenue Service [2] 345/2
350/19
internationally [1] 392/16
interplay [1] 306/5
interrogation [1] 412/19
interview [10] 243/22449/1453/9455/19
461/14461/23468/5469/16474/9474/16
interviewed [1] 468/11
interviewing [2] 454/13460/2
interviews [1] 280/24
introduce [2] 470/5470/6
intrusions [1] 292/12
invest [1] 278/25
invested [1] 279/4
investigation [6] 260/19293/3293/5
293/8412/23450/9
investment [2] 279/3279/6
invocating [1] 460/3
invocation [3] 461/2470/1472/11
invoke [4] 459/20460/13473/3474/8
invoked [4] 461/6462/3471/14471/15
invoking [3] 459/25473/2474/13
involve [1] 292/24
involvement [1] 295/7
involving [1] 375/6
IRS [25] 270/19271/25272/1272/2
272/15273/5276/16276/16277/6284/12
285/7285/18285/23286/4286/12286/12
289/12294/20295/4303/15307/10339/16
388/12392/2392/22
is [640]
is -- where [1] 464/9
ish [1] 267/6
isn't [7] 274/13275/4275/5382/22384/1
388/7451/13
issue [22] 252/6294/18359/2361/14
372/18381/17381/19382/16382/19388/7
388/10388/12412/10412/19417/22
451/25460/24464/16467/1468/8474/19
475/2
issued [15] 276/19278/13296/17297/1
359/18359/20361/2370/7370/19371/18
382/11383/12384/21384/23394/8
issues [5] 251/9252/1266/17266/23
464/5
it [639]
it's [194] 237/6237/23238/8240/2
240/13240/17242/18242/18243/9243/18
247/18254/16256/13258/16259/12
259/17261/18261/18265/7272/12274/17
274/18274/19274/22274/24275/6275/7
276/25277/13279/10279/10279/14
279/14279/16282/20283/23283/24
284/18284/19288/1288/2288/13290/13
290/18291/15295/22297/20297/22
298/24299/16303/3303/14303/14304/2
304/25305/1306/24308/19308/21310/14
311/1314/24319/13320/2320/11322/15
322/18335/7335/9337/2338/2338/3
338/21341/15344/23344/25345/22
349/17356/20356/24357/6357/20358/10
359/6359/9360/1360/10362/2362/12
363/10366/13366/23367/4372/7372/7
374/16375/7375/7375/8375/18376/20
378/7382/23382/24388/8388/17389/23
389/23391/6391/11391/15391/17391/22
392/24395/11396/24400/7400/24401/23
401/23401/25408/18408/18410/19
411/10412/18413/4413/5413/8413/8
413/8413/9413/9413/16417/8417/9
427/5427/7427/20428/4428/19428/20
428/20428/20430/2437/8439/16441/21
441/25445/13446/6447/7448/7449/17
449/24449/25449/25450/10451/9451/24
452/4452/14452/20453/4454/11454/11
455/9456/6456/6456/9456/23457/8
457/9457/10457/19459/8461/12461/13
462/23464/3465/9466/20466/22467/11
467/11467/24468/2471/2471/5471/18
471/19471/25473/10474/13
it's -- it [1] 437/8
items [1] 241/14
its [11] 265/14269/8269/10269/22
270/11274/22278/20289/13309/9321/23
377/24
J
Jamaica [1] 423/2
JANA [3] 231/20476/4476/18
January [5] 270/3273/21296/22296/24
337/15
January 11th [1] 296/22
January 2021 [1] 270/3
Jason [5] 271/7327/3327/14327/19
389/14
Jason Bourne [1] 271/7
job [9] 247/14253/21274/21274/22
274/22274/25294/5432/17436/12
John [3] 271/6283/16283/16
John Snow [2] 271/6283/16
journal [6] 304/18305/7322/21322/22
323/8435/11
judge [13] 241/3247/2255/4262/7
274/18289/18393/4398/19412/11428/9
430/24443/1449/3
judges [4] 234/25242/15242/18319/23
judgment [1] 264/18
JULY [6] 231/12234/3273/4299/9
341/15476/8
July 29th [1] 299/9
June [1] 340/2
junior [1] 417/20
juries [1] 274/19
juror [8] 244/25245/4247/14248/20
248/23250/2250/3374/8
jurors [15] 234/7247/3247/25250/11
250/18251/15252/3259/23318/21321/4
373/24376/8412/1418/7445/4
jury [58] 234/10234/24235/2235/8
235/12238/13238/16238/16241/8241/9
241/10241/23243/14244/12244/14245/7
249/9250/12251/3251/4251/14251/20
259/22260/3261/1261/21262/1262/25
291/19296/4296/8319/19320/7320/9
322/15325/6330/7357/17374/1375/25
413/2414/23415/11415/13417/4450/22
453/4453/6454/12454/13456/25456/25
461/24462/8465/24470/18470/21471/11
just [166] 234/19237/6237/20238/8
239/2240/14240/15240/24241/3241/17
241/24241/25242/5242/18242/18243/3
243/16243/18243/18244/5245/11247/5
247/17248/4248/20248/24252/4254/13
254/15255/10255/18258/17261/18262/6
264/4264/23265/7265/10270/3273/4
277/13283/10283/24286/1300/9300/19
303/20303/21303/21305/7312/11322/5
322/8322/10322/12322/20325/6326/20
329/18340/13347/12350/4351/9351/15
352/2354/10354/17355/2355/13357/9
363/6363/15364/25366/7373/17373/22
374/18375/7375/18378/13378/17379/7
380/5381/15385/11387/20390/5392/15
395/2395/14396/12399/18400/12402/10
405/23406/7406/8407/19408/5409/21
409/21412/7414/24414/25416/3416/15
416/15417/18419/18421/23425/2429/10
431/5434/18434/20434/20435/2435/8
435/10437/6437/19438/20438/23438/24
439/20441/11441/21441/25443/3444/24
445/12445/17447/10447/15449/20453/7
454/10457/10458/1458/12459/8461/4
461/9462/10462/25463/25464/1465/4
466/3467/7467/18468/4470/11470/18
470/21470/22471/6471/23472/9472/14
472/15472/21472/24473/13473/25474/9
K
K-O-B-I-N-A [1] 398/6
KARL [66] 231/6268/3269/2273/7
274/10274/20275/10275/18276/10277/2
277/12277/14277/14277/18278/6278/9
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 263 of 281
K
KARL... [50] 278/19278/20279/1279/7
280/9281/7282/8282/18283/7283/10
283/14283/21283/22284/8284/9286/17
288/1288/9289/10289/15289/15289/24
289/25290/14299/3300/1300/2329/5
329/21330/9348/16348/18349/9372/13
389/19389/21389/21389/23400/7409/4
422/14424/3425/19425/25426/1426/14
426/24433/9435/19476/10
Karl Delano [12] 274/10275/10275/18
277/12283/21283/22288/9289/15289/15
300/1300/2389/19
Karl's [4] 278/10278/18278/21284/21
Keanu [9] 271/5276/17280/14331/7
331/12331/15331/19331/23332/2
keep [16] 248/21250/10250/12259/16
260/7261/3264/10264/17280/10318/16
354/10376/12414/7434/18434/20444/22
keeping [5] 306/14309/6404/12455/8
455/9
keeps [3] 293/17293/17293/25
Kelley [4] 244/11245/3251/17444/17
Kelly [1] 232/3
kept [2] 269/4426/20
key [4] 305/20308/14323/12323/15
kid [1] 244/20
kids [6] 240/13401/19401/21406/5
418/4422/15
kilos [1] 279/7
kind [55] 241/14241/19245/16245/18
246/18253/21257/18258/12261/7275/19
275/20277/13283/24287/19292/7294/16
299/7303/22304/3307/20308/4310/7
313/23317/4332/13335/7338/2339/14
343/19345/19355/8361/13363/6384/8
385/10387/18391/11395/21404/8405/15
407/3410/3412/18414/13433/7442/12
451/20459/3459/12460/8460/13460/22
461/12471/10475/2
kinds [5] 252/24253/25287/19287/23
368/1
knew [9] 249/9380/6392/20407/6
409/19409/20416/20424/10424/12
know [177] 234/24235/2235/8237/25
240/14241/23242/13242/14242/16
242/20242/25243/10245/2245/8246/7
247/18248/4248/15248/23249/7252/22
252/22253/24261/9262/7264/16267/4
278/11282/22283/10283/19286/1286/2
286/15286/19288/8296/9299/7300/8
312/25317/4318/10318/15319/6319/15
335/7351/24356/18364/20374/14375/8
378/7378/13380/6380/23380/25381/10
381/11382/11382/12384/10384/13
384/18385/1385/2385/11385/24386/8
387/3387/16387/16387/22387/23387/24
388/16388/16388/17388/18388/18
388/21388/23389/1389/1389/2389/3
389/3389/5389/7389/8389/11389/13
389/21389/23390/8390/8390/10390/15
391/4391/14392/2392/22392/22396/22
397/1397/9399/14399/23399/25400/10
400/13400/13401/10402/3402/7404/14
404/23405/1406/2406/5406/6407/25
408/4411/11412/17413/3415/12415/13
419/3420/1421/4421/7424/18424/23
426/3427/21429/3429/10429/20430/14
433/9433/12433/14434/13439/14439/15
442/6444/9444/19444/21445/24449/9
450/3450/4450/19451/3451/16453/4
454/3454/4455/25456/16459/3464/4
464/14466/3466/11466/22468/24469/23
470/4471/20474/9474/9474/10475/3
475/6475/15
knowing [1] 419/21
knowingly [1] 289/11
knowledge [1] 369/15
known [9] 231/6268/3271/12274/10
401/5415/20416/21439/11476/9
knows [2] 417/1456/25
Kobina [2] 397/22397/24
Kobina Oppong [1] 397/22
Kqadzo [1] 283/12
Kremkov [127] 269/22270/3270/7270/8
270/10270/22270/24271/1271/21271/25
273/13277/7278/8278/8278/24279/5
280/5280/6280/10282/8282/18287/2
288/4289/25295/9295/11295/23296/12
296/20297/9300/14301/16302/23304/23
309/8309/17309/21309/24310/7311/14
312/17312/21315/7316/12317/11321/20
321/23323/1325/24326/7327/5327/19
328/16328/24330/1330/5330/8331/1
331/10331/13331/16331/24332/3332/7
332/17332/24333/3333/13333/19334/8
334/15334/19335/10335/19336/10
337/20338/8342/8343/2343/13344/5
344/13347/7348/4348/5348/13349/11
349/13351/17353/5373/8373/11373/14
385/15386/19389/24396/8408/25409/3
409/5409/9409/12409/13409/16409/22
409/23410/18411/11411/13416/22
418/18419/2419/8425/19426/15428/24
435/13435/17436/8436/16437/2438/22
442/9454/22455/9456/2457/8
Kremkov Industries [101] 269/22270/3
270/7270/8270/10270/22270/24271/1
271/21271/25273/13278/24279/5280/10
287/2295/9295/11295/23296/12296/20
297/9300/14301/16302/23304/23309/8
309/17309/21309/24310/7311/14312/17
312/21315/7316/12326/7328/16328/24
330/1330/5330/8331/1331/13331/16
331/24332/3332/7332/17332/24333/3
333/13333/19334/8334/15334/19335/10
335/19336/10337/20338/8342/8343/2
343/13344/5344/13347/7348/4348/5
348/13349/11349/13351/17353/5373/8
373/11373/14386/19389/24396/8408/25
409/3409/5409/9409/12409/13409/16
409/22409/23410/18416/22418/18419/2
419/8426/15428/24435/13435/17436/8
436/16437/2438/22
Kremkov Industries' [1] 331/10
Kremkov's [1] 287/3
L
labor [2] 279/1286/24
laid [1] 280/17
Lamborghini [1] 274/1
land [9] 273/19273/23278/15278/20
279/2286/22287/16451/11470/10
lands [1] 449/12
Lane [1] 351/20
language [1] 283/4
lapsed [1] 356/9
last [25] 251/13260/20265/8275/23
275/24291/13305/16313/14314/6326/9
330/14346/24355/17355/19360/22
369/21370/4393/25394/2398/5398/7
400/1432/4451/6474/3
late [2] 247/11399/9
later [18] 262/11264/14272/22275/17
278/19294/7294/11297/1356/6371/13
377/9407/12446/25464/5464/7464/16
465/3465/24
launder [2] 276/13289/13
laundering [9] 272/19276/5287/18
287/19287/20287/21289/2292/5292/17
lavishly [1] 268/11
law [17] 232/4242/18252/5252/10
252/11253/18259/7260/8260/23266/11
276/6291/23291/24306/24307/1378/11
473/5
lawyer [9] 254/13255/7255/8255/9
469/2469/3469/6469/8469/21
lawyer's [2] 254/12254/15
lawyerly [1] 378/10
lawyers [4] 255/3255/20264/21266/16
lawyers' [1] 254/5
lead [4] 415/24454/24456/12456/13
lead-up [2] 454/24456/12
leaders [1] 278/13
leading [4] 312/7312/8446/16447/5
leads [1] 448/8
learn [6] 279/17280/20281/4290/13
290/17410/16
learned [1] 278/19
leases [4] 278/14278/15278/20279/2
least [8] 241/15256/7281/22323/16
325/17337/13391/7426/23
Leatherleaf [2] 297/14302/2
Leatherleaf Trail [1] 302/2
leave [5] 462/13462/14462/22463/7
471/24
leaving [1] 248/6
led [1] 460/22
Lee [4] 278/22278/25279/3279/4
left [8] 248/8299/18345/20352/1352/12
434/10451/20471/17
legal [3] 289/24290/4301/17
legally [1] 273/6
legitimate [1] 456/6
lender [3] 438/14438/18440/21
lending [1] 271/11
lengthy [1] 413/15
less [1] 391/25
lesser [1] 240/17
lessons [1] 278/1
let [37] 235/8241/23241/24243/10
250/20252/22252/22253/18255/20
259/11259/25275/20282/1283/23290/2
312/24341/2364/20376/15383/20386/25
400/22409/15412/4415/18415/22444/24
447/11447/23448/10448/21451/23
456/13456/13462/1462/12472/9
let's [29] 235/15237/1245/21250/12
254/1259/22275/11276/21278/8284/6
347/17369/25385/23391/17392/5412/4
414/3421/23426/4431/17439/25440/24
445/20454/14457/12466/13466/13
467/15468/11
letter [1] 245/23
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 264 of 281
L
letting [2] 466/14467/10
level [4] 290/18290/19401/22402/13
levels [1] 306/7
liability [1] 387/12
liberty [1] 274/21
license [18] 277/23277/23277/24
277/25362/4362/17363/12363/23363/25
364/7364/12365/15371/11371/20372/2
372/10372/12372/18
lie [3] 237/25445/23449/19
life [5] 294/7370/13416/21432/15
432/15
lifetime [1] 394/24
light [2] 254/23254/24
like [131] 234/21235/16237/24238/8
238/24240/13242/15242/25243/15
245/16245/18246/17247/23253/1254/22
260/4260/21261/11261/17261/21262/9
262/11265/5271/5280/6280/7281/17
281/18284/20285/14286/1286/1287/22
288/8290/8292/14292/14293/18293/21
294/10307/4307/23308/4314/23324/7
338/3338/10338/11352/2376/11378/10
379/25381/23385/6392/22395/14402/4
402/15402/16402/20404/2406/2406/4
406/13408/4408/9408/12408/17408/18
408/19410/12411/11411/12411/14
412/19413/22413/23415/1415/10416/9
416/9420/1426/11426/20427/20427/21
428/5429/13430/1430/14431/18433/7
434/19434/19437/6437/8437/9437/12
437/12437/14439/18439/19441/1441/11
447/5447/9448/19449/17449/24450/4
450/14450/20451/16452/10452/20454/4
456/16457/16457/25463/17464/7466/7
468/12468/22470/1470/2471/11473/3
473/6475/5475/15
liked [2] 275/23406/15
likely [1] 284/15
limitations [1] 265/21
limited [10] 257/1354/5354/12376/25
377/6377/21378/2378/8378/13387/11
limiting [6] 353/11364/21364/23365/3
365/5374/5
line [38] 1/6242/20304/3304/7338/17
340/8345/17346/2346/7346/8346/8
346/8346/9346/10346/13346/14358/8
358/13367/14417/10441/12441/14
441/16446/3446/12446/13446/14446/17
447/19447/21447/21448/2451/6453/2
461/16474/2474/3474/3
Line 1 [1] 340/8
Line 22 [1] 474/3
Line 5E [1] 338/17
lines [3] 242/20417/25449/10
lips [1] 265/4
list [21] 271/3280/14316/19326/4
326/21330/14335/16347/8348/10364/3
388/2388/14388/21389/9389/12389/14
389/15389/17389/19389/25391/4
listed [41] 302/15304/4316/21325/11
326/8327/3327/9327/11327/14327/24
333/16334/11335/2335/4337/9342/24
345/15346/22348/16349/3349/6349/20
351/8351/17352/14352/16352/19357/22
358/1361/17362/23363/7363/19363/22
366/2367/6367/9381/2382/16384/19
396/7
listen [6] 235/3260/12260/14262/12
274/17426/21
listener [1] 465/15
listing [2] 315/10324/4
lists [1] 303/1
litigated [1] 243/5
litigating [1] 460/25
little [23] 248/25255/5258/16259/22
259/23264/12264/13267/9277/14283/9
289/18311/2316/25317/5319/18352/4
358/10394/11398/20402/7402/8423/16
444/19
live [6] 290/3290/7398/13427/20432/10
436/19
lived [5] 398/24403/25403/25404/2
432/14
living [5] 399/2403/23403/24404/6
428/18
LLC [2] 301/16387/12
LLP [1] 387/11
loan [88] 268/6269/7269/9269/12
269/15269/16269/19269/22270/4270/6
270/9270/14271/10271/13272/21273/18
273/22274/1275/12276/15276/19276/22
276/25280/9280/10280/12280/18280/25
281/13281/14289/10300/16300/22301/9
301/18304/6305/4321/19331/10333/24
336/17337/7348/14387/18387/20387/24
387/25388/5388/8388/9388/12388/14
388/20396/18396/25397/2410/2410/4
410/8410/22410/22411/2414/6414/14
418/12418/14419/15420/1420/3421/1
421/5421/21426/22428/24429/1429/10
429/11429/13429/15429/23430/3430/19
430/21431/3438/3456/16456/19470/16
loans [6] 268/22268/24281/3388/11
429/16429/21
location [1] 427/7
lock [1] 261/3
lockdown [1] 405/14
lockdowns [1] 300/13
locked [1] 384/1
logical [1] 293/8
logistics [3] 286/21419/13419/14
logos [1] 287/15
long [21] 242/12246/17250/9267/4
288/2289/14335/7391/11398/24401/5
406/6408/21411/15416/16426/11432/12
432/14433/2434/6448/2466/24
long-winded [1] 416/16
longer [10] 245/9246/6248/1250/24
251/3251/4262/5399/8407/22408/5
look [85] 234/11237/25238/25238/25
240/15260/14260/20261/6261/6261/7
261/10261/10262/2262/15280/6280/7
283/20285/18285/18285/19287/9295/17
295/18297/19300/18302/25303/25
304/14305/6310/10311/5312/24329/9
331/18336/19344/16346/2347/25349/24
355/4356/14359/22361/25362/14364/5
365/17366/6366/6366/10367/21368/19
369/8369/23371/7371/25379/21383/3
383/9385/21385/23391/10391/18406/12
407/24410/3422/20427/10427/18434/25
435/2447/10450/4452/2454/4455/25
461/8466/5466/10466/13466/13468/19
468/23468/25471/11475/2
looked [31] 237/4277/6286/9286/10
286/10310/2322/8322/10323/13324/1
326/6327/8331/21333/6334/22340/13
340/16342/7347/12348/12350/4355/2
371/10381/21381/23382/14396/1408/6
466/4466/8466/9
looking [23] 240/11240/13296/10
300/15305/9307/14314/21323/7324/1
325/9338/25351/22351/25357/21363/6
368/15382/12391/21408/11413/1434/21
437/9445/7
looks [5] 311/2314/23338/10447/5
447/9
losing [1] 248/23
loss [3] 235/15235/18236/1
losses [1] 272/7
lost [1] 424/14
lot [13] 235/1237/25238/14263/7288/19
306/9410/13411/5411/16471/5471/25
475/6475/8
loud [1] 441/23
lovely [1] 390/10
low [1] 325/17
LUCIUS [6] 231/6283/14299/3372/13
400/7476/10
lucrative [1] 429/3
lunch [5] 318/11318/12318/13319/3
321/15
lying [1] 413/23
M
M-O-N-I-C-A [1] 432/5
ma'am [69] 297/15300/21300/23302/14
303/10314/5316/24322/6322/22323/6
326/12335/22336/15340/15341/15
342/15350/1355/15362/18363/5366/11
370/2400/6400/8400/11400/20401/4
401/20402/9402/14402/25403/3403/7
403/10403/17403/20404/7404/10404/13
404/16404/22405/5405/8405/11406/11
406/13407/8407/11407/14408/24409/2
409/10409/17410/5410/23411/3418/22
418/25419/9419/20419/24420/3420/5
420/13421/2421/6421/14421/19429/5
machine [2] 246/12476/7
mad [1] 425/8
made [11] 234/11257/11268/6270/9
275/23279/7364/18445/14456/17456/20
465/12
made-up [1] 268/6
magic [1] 290/12
magistrate [1] 243/4
mailed [2] 285/9285/9
main [3] 396/16396/17425/15
maintain [1] 293/12
maintained [2] 280/1383/6
maintaining [1] 269/17
Majingo [1] 399/24
majority [1] 294/17
make [58] 239/5242/9242/17244/15
260/19262/6263/6264/24266/17266/19
268/18269/1274/21274/22284/2284/4
284/16285/5289/16296/9303/5321/18
322/13352/3374/22376/19376/24378/5
378/12381/19383/19383/21390/19395/7
395/11408/1414/8414/25416/8417/21
418/11418/15425/15425/19426/7427/23
440/3440/24448/25452/3457/19463/24
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 265 of 281
M
make... [6] 464/21464/24466/12471/11
472/16473/18
makes [6] 235/1235/1235/23253/19
461/22465/7
making [5] 247/20262/24449/20450/4
454/4
man [7] 268/1275/21275/22275/24
278/22380/3428/3
management [1] 277/20
manipulated [1] 269/5
many [14] 248/7248/11252/14279/17
279/17323/7326/3337/3343/6401/5
410/12430/11431/3456/20
March [4] 272/20273/23337/16407/17
Marietta [2] 272/23407/23
marked [2] 358/17445/18
market [1] 437/18
marshals [2] 319/24320/15
massive [1] 275/19
material [2] 292/23293/6
math [5] 286/11286/12338/11338/16
380/2
matter [6] 274/17274/18411/22447/23
451/8476/8
matters [5] 236/5414/19414/24453/5
453/6
Max [1] 278/5
may [35] 1/21/5241/13247/25251/21
253/20255/8257/1264/21264/25265/20
266/2271/5278/11293/12293/22296/4
298/9298/10300/8306/22307/10307/19
330/12340/2353/22393/2398/19407/18
414/13416/15431/7432/7473/1475/8
maybe [28] 236/7236/9246/6247/23
247/24248/5250/14252/17263/12264/14
286/1288/10307/22324/7336/13356/13
360/22392/12392/13411/22412/14
414/23427/23439/20440/9464/8470/13
475/5
me [93] 234/19234/20235/8236/4238/3
238/10238/23238/24238/25239/9240/24
241/9241/23241/24243/10243/13249/5
250/20253/18255/20259/11260/17
260/23262/16262/23275/20281/23282/1
283/23284/4290/2298/24299/19312/25
319/13320/15341/2344/22364/20366/8
374/9375/8375/19376/2376/15378/11
379/16383/20384/4386/25391/25396/16
405/23406/1406/2407/18407/20407/22
408/2408/5408/13409/4409/15411/6
411/17413/10413/23415/18417/8424/19
425/24431/5437/17438/3438/10441/3
445/15448/21450/17451/23452/5454/18
456/13456/13462/1462/12464/6465/21
466/4470/4474/8475/4476/12
mean [59] 243/17248/10305/20305/25
311/20311/23312/2312/5312/7312/8
314/14324/8358/18359/13359/13371/3
381/7381/8386/25396/22410/10410/10
411/19413/16414/1414/23420/15422/20
422/20427/20430/13432/15448/1448/18
453/1453/2454/19455/1456/23457/18
459/1459/5462/21462/24462/25463/11
463/13463/17464/1464/18470/15471/3
471/6471/22471/25472/15473/12473/23
474/15
meaning [1] 268/24
means [8] 250/13256/2256/13266/9
290/13311/21375/9402/3
mechanical [1] 231/18
med [4] 305/14306/3308/5323/22
Medicare [63] 293/22293/25303/23
306/4306/5306/8306/10306/13306/16
306/19308/19309/19309/20312/3313/24
315/1315/6315/11315/25316/16317/14
323/17323/22324/15324/19325/14
327/11328/8329/13330/4330/18330/25
331/19332/22333/15334/11334/15336/1
338/23339/15339/15340/20340/22
341/23341/23343/9343/9343/19343/22
344/2344/13347/20349/6349/7349/10
349/14352/23352/25353/4373/13395/4
395/22396/6
meet [8] 268/18269/11274/24274/24
376/11434/3459/3459/12
meets [1] 278/21
memory [4] 258/1263/20263/24264/4
mention [1] 437/6
mentioned [12] 284/1306/21308/11
337/12359/12381/21400/12418/20
421/12434/8437/7439/11
mentioning [1] 382/4
merely [1] 359/9
Mesa [9] 278/6433/5433/8434/4434/5
434/8434/11434/13436/11
messed [2] 423/23442/20
met [9] 269/20400/19401/3402/3402/20
421/24422/14424/3434/4
Mfantsipim [1] 400/17
MICHAEL [5] 231/11278/22278/25
279/3279/4
microphone [1] 398/17
mid [1] 373/19
mid-afternoon [1] 373/19
middle [9] 276/3299/17304/7313/18
332/13435/25439/14461/14468/5
might [36] 237/7238/15248/23252/19
254/19254/24254/25255/3255/20256/10
257/7258/10258/12263/14263/15264/13
264/14264/23299/7302/12316/25353/14
385/25386/3390/12402/7404/21405/1
416/3434/24445/11446/25462/13462/14
467/20470/20
mile [2] 288/2289/14
military [1] 456/11
million [41] 268/4268/6268/9268/11
269/7269/22270/11270/12271/10271/22
272/15272/17272/21272/23272/25
276/21276/21276/22276/23276/24
276/25279/4281/11281/11281/13281/17
281/22284/3284/24285/1285/2286/15
288/13335/11335/16338/21373/6408/9
410/8415/22416/23
millions [3] 268/2274/8419/22
mind [18] 238/17250/8259/16260/7
264/10264/17340/12353/23354/10
375/13375/13377/7377/9377/12407/21
434/21444/22474/7
mine [4] 279/16280/21287/9290/6
minerals [1] 278/12
mines [3] 279/18279/21279/21
mining [11] 268/6269/21271/8278/15
278/23279/9279/9279/12418/19418/20
435/21
minus [1] 308/4
minute [5] 245/15255/14258/17280/23
373/21
minutes [12] 244/19245/20245/21
245/22246/6246/15262/15264/24265/1
310/3373/22426/12
Miranda [2] 468/20469/21
misargued [1] 235/17
misexplain [1] 448/25
mishighlighted [1] 458/12
misinterpret [1] 448/25
misleading [1] 470/20
mispronounced [1] 283/13
mispronouncing [1] 279/11
misrepresentation [1] 293/7
misrepresentations [1] 292/23
miss [2] 263/14263/15
missed [2] 267/9360/4
misses [2] 247/16247/17
missing [6] 244/25245/1247/17247/18
247/21452/15
mission [1] 246/22
mistake [3] 354/3377/19384/12
mistakes [1] 257/10
mistress [1] 277/17
misunderstanding [1] 245/7
misunderstood [1] 246/22
MLB [2] 231/4476/10
modify [2] 239/17374/21
mom [5] 385/5387/5438/10440/5440/9
moment [3] 265/10373/17393/2
Monday [1] 247/14
monetary [1] 236/1
money [74] 235/24236/4268/22270/22
271/12271/24272/2272/19273/1273/3
273/4273/5273/11273/13273/17275/15
275/20276/4276/13277/7277/13280/21
280/25281/5281/8283/24285/24286/14
286/25287/1287/3287/10287/13287/18
287/19287/20287/21287/23288/12
288/15288/18288/19288/20288/22
288/23288/23289/2289/13292/5292/17
294/10317/10325/25327/16425/22
437/23437/25438/13438/18438/23
438/23440/9440/21452/4454/18455/2
455/8455/9455/9455/10456/1456/17
456/20466/23
Monica [12] 332/14332/19332/23333/3
390/23431/23432/5436/1441/16441/21
442/5443/12
Monica Sweeten [2] 332/14332/19
monitor [1] 435/2
monologue [1] 412/22
month [8] 270/3273/8276/23305/1
378/11429/17429/24434/19
monthly [6] 269/8269/10270/11304/1
464/12466/17
months [8] 273/4273/5275/12275/16
275/17337/14404/2437/14
more [50] 234/19235/21239/23241/14
245/1246/15247/4249/11252/5253/23
258/17258/23259/15261/9261/15262/15
265/1266/8266/10271/22272/15273/23
274/5276/2285/3286/4289/19289/20
312/12325/12327/13328/6328/9328/11
341/2345/20346/8355/3378/5378/12
383/20402/1408/10408/12416/8444/20
460/15470/20474/12474/19
morning [11] 234/9244/15245/24
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 266 of 281
M
morning... [8] 267/10268/1274/13
274/13319/7420/23444/3444/11
mortgage [1] 272/24
most [8] 242/14243/22283/1290/21
374/19380/8402/5403/25
mother [2] 277/15437/25
motion [3] 243/1255/16357/12
motivated [1] 292/12
motive [2] 353/25377/13
Motor [1] 362/2
Mourad [3] 245/2245/11246/13
mouthful [1] 283/12
move [33] 245/10250/13262/7295/25
298/2299/11301/1304/10310/19313/8
315/18319/17326/23329/2330/10331/3
339/24340/14341/1341/12345/3350/17
356/25360/6362/8364/14366/15372/4
376/10398/19399/7404/3405/6
moved [12] 255/13267/21320/22350/14
403/6403/8403/12403/14404/8404/11
405/21432/15
movement [1] 455/5
moving [11] 241/20248/22250/10
250/12403/4403/15417/12446/14455/2
465/21465/22
Mr [10] 244/6357/9379/11403/11414/18
415/1459/10468/3468/4475/15
Mr. [57] 245/2245/11246/13254/23
254/24274/15287/8299/2300/1329/24
358/18380/23383/14385/16389/5391/7
398/24399/14400/9400/13402/12403/5
403/12404/5404/14404/14405/6408/21
410/22412/17413/10418/11418/23420/1
422/8428/14431/3433/14433/17434/3
434/13436/23437/4438/4438/4439/9
439/11439/12439/12439/16440/15443/7
447/10450/16451/17453/13458/18
Mr. Delano [32] 274/15300/1329/24
358/18385/16389/5391/7400/9400/13
403/5403/12404/5404/14405/6408/21
410/22412/17413/10418/23420/1433/14
433/17434/3434/13436/23437/4438/4
439/11439/12439/16440/15443/7
Mr. Mourad [3] 245/2245/11246/13
Mr. Oppong [8] 287/8398/24399/14
404/14418/11422/8428/14431/3
Mr. Smith [2] 254/23254/24
Mr. Sweeten [1] 439/9
Mr. Torjagbo [10] 299/2380/23383/14
402/12438/4439/12447/10450/16453/13
458/18
Mr. Torjagbo's [1] 451/17
Ms. [15] 244/1244/11245/3251/17
262/18322/1326/23336/21345/6363/11
364/20432/10443/7444/17446/18
Ms. Colter [1] 262/18
Ms. Connors [3] 244/1364/20446/18
Ms. Kelley [4] 244/11245/3251/17
444/17
Ms. Sweeten [2] 432/10443/7
Ms. Wilson [5] 322/1326/23336/21
345/6363/11
much [22] 235/23257/15267/6294/12
307/6318/18348/16356/9397/18407/25
408/1410/10410/17413/9429/25431/8
437/23443/23445/2456/17456/19456/20
multi [1] 277/23
multi-engine [1] 277/23
multiple [6] 279/5292/4301/10370/11
406/12408/16
multiplication [1] 338/12
Musk [1] 277/12
must [8] 252/10252/10252/13252/21
252/23256/9259/14353/20
mutually [1] 306/9
my [79] 234/8235/5235/8237/4238/17
239/1240/11240/13240/13242/20244/24
244/25246/14250/8251/10260/8261/21
264/19265/5267/8281/21281/23283/24
291/14291/24292/11293/8300/11313/3
316/5316/5354/7354/18357/12365/5
369/15378/17381/15383/16383/21384/4
389/21392/20396/22398/6398/7401/11
402/10406/1406/4406/5408/1408/4
409/20410/10410/12412/12415/20421/2
428/9428/20429/22432/15432/15438/10
438/23438/23445/14448/3450/3450/18
452/10453/18454/4458/6458/10468/6
472/23475/19
myself [2] 456/14475/2
N
name [117] 272/7273/7273/9273/10
273/11273/12275/13275/14275/17
275/18275/21275/22275/23275/24276/1
276/2276/2276/3277/11282/20283/9
283/11283/16283/19288/25289/6289/15
291/13291/14297/22297/23298/19
298/20299/1299/2299/14299/22300/15
301/17302/3302/5302/15302/15304/21
305/10312/22314/23327/2327/4327/24
329/5329/7331/6331/6332/14333/10
334/5336/9337/19339/8339/10342/16
344/24345/10347/6348/3350/7351/3
355/13356/1356/24357/18358/20360/19
365/17366/22366/23368/25369/18
372/13379/11389/3389/7389/17389/19
391/8391/8398/5398/6398/7400/1400/5
409/1429/19430/14432/4433/9433/12
435/7436/1436/3436/5439/14441/12
441/12441/21441/25442/17442/18
442/19442/23443/12454/23455/7456/10
460/11465/23
named [3] 278/22390/9390/12
names [23] 271/5276/18280/14316/12
316/15326/2326/3326/21389/14389/15
389/25390/5390/18397/3397/3397/6
459/14471/5471/7471/25472/1472/3
473/15
narrative [1] 412/15
nature [4] 262/12287/24377/21378/1
Navy [1] 277/15
near [1] 301/21
necessarily [5] 242/7282/24282/24
406/17442/18
necessary [6] 269/15270/6353/23
367/24374/23377/8
need [29] 235/2242/22243/14247/20
250/5260/23262/14265/1294/8312/11
320/10321/12366/6374/12380/19380/19
391/11393/13395/23411/10411/22
412/20415/12426/23426/24427/15
437/11464/15468/25
needed [5] 269/4294/8368/17437/22
440/3
needs [4] 240/7415/13426/19447/12
negated [1] 457/22
negative [3] 285/1308/4436/18
neighbor [6] 253/2253/4253/10253/11
253/14263/6
neighbors [1] 428/18
nervous [1] 244/9
net [7] 307/16307/25328/23335/14
335/16335/20335/21
never [24] 240/12270/22271/12271/25
272/2275/22281/9282/1282/2282/2
287/16287/17311/24312/2387/4388/20
415/21415/21420/16424/16428/3428/4
457/8474/11
new [14] 247/14273/8273/9273/10
276/1376/11376/11379/19393/10393/12
393/18394/8404/2475/7
New York [1] 404/2
news [1] 260/22
next [24] 235/10273/8288/3315/19
320/14327/21333/8341/2350/16354/10
376/11397/20410/23415/13415/17
416/23436/5446/2446/13447/3454/15
454/17457/5457/7
nice [4] 275/6275/7275/8431/9
Nicholas [1] 232/3
nicknames [1] 399/23
night [3] 260/20410/15416/22
no [209] 1/13231/4237/6238/2238/9
244/21249/14251/2253/19254/24254/25
259/3261/14268/2270/8271/1272/4
272/10272/24273/18273/22274/1276/11
276/12276/12280/15280/16280/16
281/13282/10282/11282/11288/7296/2
298/3301/4302/21302/24310/20311/19
311/23312/5313/10313/22313/25314/13
314/15314/15315/8315/17316/5316/23
317/12317/21318/5318/24325/2325/5
326/1327/17327/20328/17328/25330/2
330/6331/2331/17332/4333/4333/22
333/22334/17334/20336/7339/3340/25
342/2342/9343/14343/17344/8344/11
345/4347/21349/12349/16349/23350/12
350/21353/6368/14369/6370/18373/9
373/12373/16374/4374/18380/13381/12
383/11385/4385/7386/11389/10390/2
390/3390/4390/22390/22391/5394/10
396/2397/10397/13399/9399/23399/23
402/14402/18403/17403/25405/5405/20
407/11408/24409/10415/6418/22418/25
419/6419/9419/24420/3420/4420/13
421/2421/6421/7421/7421/8423/3424/7
424/9424/17424/22424/25425/23426/16
426/24427/11427/13428/6428/25428/25
428/25429/5433/25434/10435/18435/20
435/22435/24436/9436/17436/22436/25
437/3437/5438/23438/23439/2439/3
440/25441/18441/20442/8442/10442/15
442/21442/24443/14443/18443/20
449/24449/24449/25450/14451/17
451/17451/18455/24456/12456/12
460/15461/19462/21463/5466/15467/6
468/6471/9471/20472/6472/10473/10
473/14473/16474/25
No, [6] 236/24376/3378/21413/14
443/25460/7
No, Your Honor [6] 236/24376/3378/21
413/14443/25460/7
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 267 of 281
N
noise [1] 243/15
none [7] 237/22237/23258/16262/21
389/25397/3397/6
nonresponsive [1] 237/17
normally [1] 427/8
NORTHERN [2] 231/1476/5
not [259]
note [3] 1/12376/15453/12
notebook [1] 263/2
notebooks [2] 261/25263/2
notes [7] 263/3263/7263/9263/19264/1
264/2264/5
nothing [15] 258/23280/16288/7311/21
316/5369/7393/4428/4430/24438/21
438/25443/1457/10460/20465/24
noticed [1] 241/13
notion [1] 392/13
notorious [11] 276/7276/9276/11277/3
277/8277/9280/13284/13286/7288/6
289/5
notoriously [2] 281/15287/6
November [1] 476/14
now [128] 234/18244/20246/18248/22
251/12251/25253/18260/10261/3261/19
262/10266/15266/19267/13275/2276/20
279/12292/17301/9305/9314/25320/9
320/21323/12324/1324/11324/23325/9
330/12331/9336/16337/12337/22338/5
339/12339/24340/16340/19343/8345/17
345/19346/18347/5347/10347/17347/25
348/3348/9348/12349/17350/22350/25
351/22352/7352/12353/2357/18358/8
361/4361/19361/22362/23363/11364/22
366/21366/24367/18367/21368/15369/5
369/16370/9370/17370/21371/10372/10
372/12372/18373/2376/16378/7378/24
383/14388/5392/12394/16396/1399/14
399/22400/7400/12400/18401/7401/8
401/12402/15403/1403/4403/11403/15
403/23404/4404/8404/11404/20405/6
405/21407/9408/20409/8410/21419/10
419/14419/21420/20421/25422/10424/3
428/14433/8434/21444/5449/4450/11
454/19460/13461/13469/7
number [106] 1/61/6261/17282/13
282/19282/19282/20290/13292/16298/5
298/18303/14303/18304/1304/4307/24
308/5308/5309/5309/17311/6313/15
323/5326/4326/7326/10326/11326/13
326/15326/18328/18335/7335/16336/9
337/6337/7339/1340/4340/8340/8
341/20342/4342/24344/6346/22346/25
347/10347/11351/14355/17358/16
358/19359/2359/12359/16359/18359/20
360/3361/22361/23363/7363/9363/12
363/18363/22365/23367/19368/11
368/23369/17370/3370/7370/11370/13
370/18371/17371/23372/16373/11378/2
380/12381/10381/11381/18382/17
382/20382/22384/2384/22384/23385/24
386/7391/11391/14393/11393/13393/18
394/6394/8394/19395/23410/16441/19
442/14447/8476/10
numbered [1] 241/14
numbers [47] 239/17239/25271/18
293/12314/6324/24328/2329/17330/17
332/6333/19338/3339/25340/15340/24
347/2353/18354/12355/17355/23356/1
356/4356/16371/1371/5373/3373/5
373/7373/15374/7375/6376/19376/21
377/1378/15381/2381/18381/22385/13
385/16385/18390/1390/20390/22396/2
396/9397/4
numerous [1] 404/19
O
O-P-P-O-N-G [1] 398/7
oath [5] 251/13251/13251/14251/18
251/22
object [6] 255/3255/4255/8255/20357/3
375/22
objected [1] 240/20
objection [42] 242/8242/15243/2
255/21256/2256/5256/9256/18256/19
296/2298/3301/3301/4310/20312/6
312/6312/10312/13313/10345/4350/21
354/18357/10362/11364/17366/17
375/19378/17381/2381/4393/21393/24
406/18406/20411/21413/19415/1433/24
443/13446/6446/12447/4
objections [4] 242/22243/1360/8372/6
objective [1] 417/17
objects [1] 255/9
obligated [1] 281/14
obtain [2] 355/25359/15
obtained [7] 274/8277/22356/5356/6
356/7356/7356/8
obtaining [2] 375/6376/21
obviously [4] 240/20382/12388/24
468/20
October [1] 273/19
off [15] 244/13246/3250/20279/22282/1
302/11336/20416/4416/15417/22427/24
440/24445/10446/3466/7
offense [4] 241/15241/16377/23378/5
offenses [2] 239/23353/19
offer [1] 249/11
offered [2] 440/15465/9
offers [1] 465/24
office [13] 232/2232/4245/8291/22
292/21297/11299/8420/19420/20420/24
420/25421/2421/4
officer [8] 255/16255/17277/15382/13
382/13383/25433/7468/21
officer's [1] 461/11
officers [1] 461/14
offices [1] 476/6
official [9] 1/11/21/31/71/14231/21
296/22476/4476/19
often [3] 380/13380/14474/12
Oftentimes [1] 359/6
oh [24] 282/1302/14305/21320/5320/24
321/13326/14338/15350/14350/15351/9
365/4382/16398/23399/19408/12410/10
411/5420/5423/9435/9447/17453/17
475/16
OIG [2] 291/25292/6
oiled [1] 246/11
okay [480]
old [10] 273/11273/12283/11379/25
380/1401/10402/2410/11421/24428/20
older [3] 402/1402/7402/8
Oliver [4] 271/5333/10333/12333/21
Oliver Twist [3] 333/10333/12333/21
olympics [1] 417/21
once [7] 268/10273/1282/2282/2434/18
463/11463/18
one [147] 235/11236/7236/9236/25
238/25241/14243/13244/2244/25245/3
245/11247/4248/24250/13250/21251/13
255/16257/3263/12264/12270/3272/12
272/13276/8277/2277/5278/16280/20
284/8284/9288/6288/8293/2303/21
308/11313/17314/8316/15318/13318/13
322/4325/20339/4341/2341/7341/22
345/10345/14347/2347/14347/16351/1
351/25352/1352/5352/12352/13353/3
353/16355/6356/5356/6356/7359/21
361/10363/5363/10366/22367/19367/21
370/10370/12370/12370/13370/19373/5
373/15379/10379/11379/19379/19380/9
380/22381/4381/20382/2382/5382/5
382/6385/18388/1389/15390/8391/16
393/2395/19396/19402/10405/23406/8
406/15407/9407/23409/25412/4413/9
416/22420/15420/15421/12421/23425/3
429/16429/17429/18429/20429/22
429/25429/25430/1430/6430/8430/15
430/15430/16431/13437/7437/7441/11
445/17445/17445/18445/18449/9451/24
452/20453/18456/7458/12462/13463/25
468/14469/3470/2471/5472/7474/2
ones [3] 238/8245/1406/15
ongoing [2] 269/15270/7
online [3] 294/23395/18427/9
only [27] 1/21/7252/13257/1257/3
258/23259/2260/9263/14263/19318/7
374/23380/6380/9380/15389/7389/23
392/20409/25415/2426/22442/5449/13
451/11462/13464/5468/5
ooh [2] 275/12276/20
open [26] 234/3237/10260/7264/10
264/17276/7276/9276/10277/3277/8
277/9280/12281/15284/13286/7287/6
288/6288/11289/5416/2416/15444/22
448/22449/22450/11476/8
open-ended [1] 416/2
opening [9] 237/20254/5265/12266/15
267/14275/2376/24449/22453/12
operate [1] 419/12
operates [2] 283/5343/21
operating [1] 282/17
operation [8] 269/13269/25270/1282/6
282/8283/7283/7387/21
operations [3] 269/15270/7270/9
opine [1] 464/1
opining [1] 467/19
opinion [3] 447/7458/10467/19
opponent [1] 465/16
Oppong [10] 287/8397/22397/24398/24
399/14404/14418/11422/8428/14431/3
opportunity [12] 254/7258/2266/6
304/14353/25355/22375/14375/15
375/16377/14378/25465/5
opposite [2] 460/8471/2
option [2] 277/21472/8
options [1] 368/15
order [9] 248/17265/9268/19269/11
356/16359/15377/24396/5437/22
ordered [2] 299/17299/19
organized [2] 296/21296/24
organizer [2] 297/17348/6
organizers [1] 297/16
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 268 of 281
O
orientation [1] 247/17
original [2] 383/6460/18
originally [1] 248/11
originated [2] 454/21456/2
other [58] 234/20237/24238/8239/23
245/1247/25250/11253/9255/16258/6
258/7258/10260/3260/11265/19272/5
278/16284/8288/14291/23306/9307/22
308/6312/21313/4318/15318/17321/22
327/7329/17331/20336/10342/6342/9
343/16348/9348/24351/23352/1352/5
381/19386/22400/24408/22411/13414/8
419/10419/11421/13427/10430/16444/2
444/10452/20455/18457/6461/9467/14
others [1] 292/16
otherwise [3] 450/13462/10467/18
ought [1] 474/7
our [25] 239/9241/13241/19241/21
243/1243/2248/17250/13251/16265/4
274/19289/24298/1310/18313/7318/13
345/2364/16373/19400/24417/21450/8
450/9455/5459/4
out [89] 234/12235/16243/18250/15
253/2253/4254/19256/17261/11264/22
268/22272/14278/18279/7279/16279/19
279/20280/3280/17280/24284/21285/15
286/9290/23294/6303/4307/1307/24
308/2316/25320/16323/3337/4337/22
340/6341/18343/4357/17358/5359/8
361/9367/13368/6383/7406/4407/12
407/15407/18409/24410/6411/23412/2
412/5415/4417/18423/18423/22427/14
441/23445/22446/1448/2448/5448/15
453/16454/19455/10457/12457/14
458/17458/22459/7460/17461/11462/10
462/13462/20463/5463/11463/12463/14
465/8466/12470/8471/21472/20473/21
474/20474/22
outcome [1] 257/24
outset [1] 253/24
outside [6] 257/7338/3411/22412/6
412/7412/7
over [34] 256/21258/12259/23266/21
268/4268/9268/10269/6270/11270/12
273/15273/17279/18289/3289/5301/15
308/12321/16326/16373/6378/3379/14
379/23379/24400/23416/24424/18440/9
444/2450/10452/16461/10461/15472/6
overnight [1] 461/8
overpaid [1] 346/9
overrule [5] 256/2312/10312/13446/5
446/11
overruled [7] 357/6360/10362/12
364/19366/18372/7443/15
overseas [2] 404/21405/1
owe [1] 281/11
owed [4] 284/23285/16285/17286/9
owes [2] 284/22285/20
own [7] 238/1264/18293/8399/3412/23
454/18456/1
owned [3] 271/22415/21419/12
owner [6] 294/21302/15302/18330/7
348/6386/24
ownership [2] 302/13302/18
owns [1] 302/22
P
p.m [1] 475/23
page [103] 1/6233/2237/18296/14297/5
299/11303/1304/11304/25305/7305/8
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332/13332/13333/8333/10334/3334/24
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341/2341/3341/12342/11342/20345/24
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371/8381/25382/17388/3435/5435/25
436/1439/6441/10445/20446/2446/12
446/13446/14446/17446/24447/3447/14
447/21447/22448/2448/4448/4449/10
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pages [4] 301/10316/7323/5323/8
paid [55] 270/11270/22271/25272/2
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285/19286/10287/16293/22303/23
305/25307/20309/11309/14315/2315/6
315/12315/15316/16317/7317/10317/20
318/4325/1325/3325/21325/25327/18
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333/21334/15335/10335/24336/1336/3
338/7339/2342/1343/13344/2344/11
353/5391/25436/15442/11
pandemic [5] 268/15280/11405/14
405/15429/21
paper [7] 273/14288/2289/14302/11
317/4442/23452/4
papers [2] 466/23466/23
paperwork [1] 423/23
Paragraph [1] 241/17
paralegal [2] 445/14445/15
parcel [1] 278/16
part [38] 251/3251/3265/7266/20281/24
288/10292/6295/7300/25301/15305/4
310/18313/7321/19331/9333/24336/17
345/2357/15375/17378/13388/5402/5
403/25417/8437/22448/3448/8448/10
455/5455/23457/13458/19462/22463/4
463/10473/1473/11
parternship [1] 387/12
partial [1] 1/9
particular [13] 257/21301/15303/17
304/17304/24307/15310/6315/9318/6
363/25370/17402/19409/24
particularly [1] 252/5
parties [7] 235/3252/20252/22260/23
265/11266/12274/16
parties' [2] 260/9264/19
partner [2] 278/9302/20
parts [1] 267/1
party [1] 412/18
passed [1] 277/22
passport [17] 359/11382/4382/6382/9
382/14382/21383/3383/12383/13383/14
383/20383/23384/1384/6384/8384/12
423/11
passports [3] 359/7382/11384/5
past [4] 285/20364/22380/25461/7
patience [1] 244/24
Patrick [1] 278/2
pattern [9] 239/18239/21239/22240/1
240/1240/11240/15374/22375/8
pay [30] 263/18266/25268/25271/23
272/8281/6281/24285/24300/12307/16
307/25308/9308/23309/3324/12329/22
335/14335/16335/18335/20335/21407/5
430/7430/22442/11471/7472/1472/1
472/3473/15
paycheck [6] 268/20294/5300/6300/16
300/22307/7
paychecks [1] 268/17
paying [14] 263/9281/23286/13306/8
306/17309/2309/24321/1344/13419/22
429/17429/23441/7441/9
payment [3] 268/12440/3440/13
payments [7] 269/1270/17270/20
281/23284/5284/21336/5
payroll [66] 269/8269/10269/18270/11
270/13290/12290/14304/1304/18304/22
304/24305/7305/9306/23307/15308/3
309/9314/19314/23315/1316/8316/10
316/13316/19318/8321/22322/7322/16
322/21322/22323/8324/3324/5326/3
326/6326/11327/5328/1328/3329/19
331/12332/19333/24334/19336/16
348/13349/1396/1396/5397/2410/19
435/11464/11464/12466/17466/17
466/20467/1467/3467/7467/8471/7
471/23472/25473/13473/25
PDF [1] 1/1
peers [2] 247/18401/22
pen [1] 234/18
penalty [2] 369/12393/16
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pencil [1] 263/3
people [18] 244/15250/5251/10263/8
271/7280/2280/15376/11376/11380/8
380/8380/11381/8381/9392/16395/2
397/9423/22
per [3] 294/13313/4410/20
percent [3] 302/18330/7348/6
percentage [1] 302/22
perfectly [2] 280/19438/20
perhaps [2] 286/4448/18
period [7] 1/4273/15274/5281/20311/8
404/23421/3
perjury [2] 369/12393/16
permission [2] 436/23437/1
person [21] 250/4250/5250/6250/23
251/1272/11300/3348/6368/22370/25
371/5390/7390/7402/7410/20410/24
411/1433/15453/14462/2464/2
person's [1] 305/10
personal [5] 257/23392/21420/9420/12
455/10
petition [3] 273/6297/22297/23
petitioner's [2] 298/18298/20
phase [1] 265/23
phone [3] 284/1410/25422/12
photograph [1] 362/21
phrase [2] 242/24276/7
phrased [2] 240/2468/21
physically [1] 389/2
pictures [1] 275/7
piece [3] 253/22425/22442/23
pieces [2] 278/14278/15
pilot [17] 277/21277/22277/22278/3
278/21288/19288/20404/15404/18
404/21407/7408/23424/10432/18432/19
433/2433/6
place [6] 249/18272/2358/1367/3
370/23441/19
placed [1] 251/12
places [1] 461/11
plain [3] 290/16452/11452/11
Plaintiff [2] 231/4232/2
plan [8] 235/5235/8239/1241/13247/20
247/22354/1377/16
planes [2] 278/2424/19
planned [1] 248/12
planning [2] 236/22458/19
play [4] 254/11413/15415/4417/9
played [1] 280/8
playing [1] 458/20
please [20] 249/3251/17251/19266/25
291/4291/13291/19296/6310/10321/7
322/2345/6351/6354/23374/5398/4
431/21432/3433/22435/5
pleasure [1] 247/12
plus [1] 308/19
PNC [2] 454/22456/3
point [37] 237/9239/16240/3240/4241/2
244/6246/20254/19256/14259/16265/18
282/22286/8365/7374/13374/25375/2
384/2384/9387/17400/5403/19404/4
405/6408/10412/14414/18417/9417/18
428/22439/20460/17463/23464/20
464/24467/9471/19
pointed [1] 357/17
pointing [1] 399/18
pole [1] 253/12
police [1] 358/3
pontificate [1] 464/1
pontificating [3] 458/7458/8461/14
poor [1] 375/18
poorly [1] 375/7
pop [1] 387/5
portion [11] 1/5308/18308/18309/24
363/15445/22446/3446/13446/24447/3
448/2
portions [2] 458/24467/14
posed [1] 470/14
position [5] 249/16249/20250/14
453/11472/22
positions [1] 266/25
possible [7] 251/15268/23319/13
351/23351/24355/8431/14
possibly [2] 272/11370/25
post [1] 261/13
posted [1] 373/10
posts [1] 261/21
potential [3] 293/6453/7468/2
potentially [5] 295/4307/22312/22
395/3472/17
PowerPoint [2] 267/18267/19
PPP [81] 268/5268/13268/20269/3
269/6269/12269/19270/4270/9272/18
272/21273/4275/12276/15276/19276/22
276/25280/9280/10280/25281/3281/5
281/8281/13286/14286/24287/1287/13
288/3288/13288/22288/23288/23289/10
301/18304/14305/4310/3311/13314/19
316/10321/19321/23331/10333/24
336/17337/7347/12347/14348/14387/18
387/20387/24387/25388/20396/18
396/25397/2410/2410/4410/8410/22
410/22418/12418/14419/15420/1420/3
421/1421/5421/21426/22428/20428/24
429/1429/10429/11429/13429/23431/3
456/19
PPP loan [46] 270/9276/19276/22
276/25280/9280/10280/25281/13289/10
301/18305/4321/19331/10333/24336/17
337/7348/14387/18387/20387/24387/25
388/20396/18396/25397/2410/2410/4
410/8410/22410/22418/12418/14419/15
420/1420/3421/1421/5421/21426/22
428/24429/1429/10429/11429/13429/23
431/3
PPP loans [1] 281/3
practice [2] 279/12279/14
prefer [1] 241/10
preference [1] 246/19
prejudice [3] 257/25453/7468/3
prejudicial [1] 238/15
preliminary [1] 252/4
premium [2] 306/10306/10
premiums [1] 306/8
prepandemic [1] 404/24
preparation [3] 1/13354/2377/16
prepared [7] 284/19389/8391/4394/12
395/11453/18474/23
preparer [2] 294/22395/17
presence [1] 411/22
present [7] 259/4265/14265/16265/18
266/18266/24469/8
presentation [1] 241/20
presented [5] 252/14382/14384/14
384/21384/22
presents [1] 383/25
preserve [1] 242/22
preserved [1] 280/1
president [2] 430/15430/16
presumed [1] 258/20
pretty [5] 243/12243/17279/7413/9
437/9
prevent [1] 356/16
previous [4] 285/17285/17286/9420/22
previously [6] 337/10368/23371/11
407/19419/4420/22
price [2] 408/7408/10
primarily [3] 252/15374/22399/25
primary [1] 302/3
principal [1] 297/11
principles [1] 252/2
printed [1] 284/20
prior [12] 291/24353/19367/7367/10
367/18367/23370/18386/22407/6418/20
429/3460/25
probably [23] 235/12239/14243/13
248/17267/5279/11280/19281/2294/4
297/20303/20378/10380/3383/6402/10
404/2407/18408/19412/3425/5435/2
475/1475/6
problem [5] 272/3316/23405/20413/5
413/6
problems [4] 250/11251/9442/20450/8
proceedings [6] 231/12231/18475/22
476/8476/11476/13
proceeds [1] 273/3
process [9] 250/6266/14370/14384/13
388/16395/17413/7413/7417/11
processes [2] 285/18388/8
produced [1] 231/18
program [7] 268/20268/21300/6300/10
300/12300/16300/22
programs [3] 429/20430/11430/15
prohibited [1] 1/8
prohibits [1] 259/7
pronounced [2] 314/24367/4
pronouncing [1] 298/24
proof [13] 253/1258/24259/1259/3
259/18266/7275/8275/8275/9290/17
290/18290/19290/22
proper [3] 307/2374/11446/15
properly [2] 294/2395/1
property [1] 278/14
proprietorship [3] 283/6387/10387/11
Protection [4] 268/20300/6300/16
300/22
prove [16] 259/4259/14274/23275/6
289/9289/22289/24289/25290/9290/10
290/11377/24384/2437/13451/13466/23
proved [1] 252/21
proven [1] 258/21
provide [3] 266/19279/2384/6
provided [5] 271/13305/3336/17368/2
370/23
providing [2] 412/13412/15
proving [1] 259/21
provisions [1] 239/3
public [2] 241/18364/11
publish [4] 296/4298/9298/11310/23
published [1] 350/23
pull [23] 290/8296/6301/6313/12314/2
320/16321/10340/11345/7346/18349/18
357/8360/13362/13365/10366/19369/25
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pull... [6] 371/7372/8383/5434/23
460/11466/12
pulled [5] 276/22276/24281/17281/25
366/14
pulling [1] 280/3
purchase [3] 406/14407/4425/10
purchased [2] 408/8408/15
purchases [3] 269/17286/23289/16
purchasing [1] 437/5
purpose [9] 257/1257/3354/5354/13
376/25377/6378/7378/8470/23
purposes [2] 262/24378/3
push [5] 245/10251/1256/21373/20
449/11
pushed [2] 244/25449/9
pushing [4] 238/5449/14450/25452/20
put [24] 234/21240/14259/11266/3
274/3280/24281/22282/12284/4287/13
319/17337/15357/4383/13386/25414/4
425/5427/2427/3427/6427/8427/14
463/19471/4
puts [3] 446/11446/14458/7
putting [4] 236/22238/12268/12287/10
Q
qualification [1] 294/12
qualified [1] 393/18
quality [1] 235/20
quantify [2] 381/14381/15
quantity [3] 324/7328/19436/6
quarter [14] 337/12337/13337/14
337/18338/7338/23340/1340/2340/3
340/9340/17341/14341/15342/22
quarterly [5] 337/2337/3466/19466/20
467/7
quarters [1] 362/14
queried [1] 317/9
queries [2] 317/18318/2
query [6] 311/3311/3311/10312/20
313/3313/14
question [65] 237/7238/10254/13
254/14254/15255/7255/23256/10256/17
258/4312/9368/9373/25375/25376/15
383/16383/19393/25394/2400/22413/17
413/19443/17446/1447/6454/24457/5
457/7459/6459/9459/12459/13459/15
459/22459/24460/3460/16460/21461/12
462/7462/10462/21463/8468/14469/14
469/15469/17469/22470/3470/9470/14
470/15470/16470/19471/5471/8471/11
471/17471/18471/22472/2472/9472/18
473/11473/16
questioning [1] 475/18
questions [31] 251/16254/12254/20
257/17264/9266/14354/15368/16368/20
379/6392/5393/20397/13402/11415/23
415/24416/3416/24428/9439/3439/9
443/3443/20457/6458/1458/25461/6
464/7469/2469/7469/7
quick [2] 275/11396/12
quickly [5] 260/17268/22276/22417/12
429/7
quiet [1] 321/2
quite [4] 300/8417/10422/12445/10
R
race [1] 418/4
racing [1] 417/20
raise [3] 251/19262/6431/21
raised [4] 277/14413/19459/10460/18
rambling [1] 242/15
ran [1] 254/24
range [7] 273/17304/24311/9311/12
406/13421/16435/14
rank [1] 433/6
ransomware [1] 292/14
rare [1] 370/15
rarely [2] 381/6381/13
rate [2] 234/9244/22
rather [3] 244/19251/15374/25
ratings [1] 278/3
RDR [2] 231/20476/18
reach [2] 264/17294/3
reaching [1] 252/10
read [27] 241/8241/9241/10244/2
260/12260/14262/4262/6265/4265/5
299/19324/6336/20346/6346/12352/4
368/9369/11374/13374/20375/4418/15
435/7464/6464/8472/14472/21
reading [2] 302/11376/4
ready [8] 236/20250/21262/7444/11
445/5462/14472/16475/14
real [7] 256/24275/11276/21277/12
390/7425/5465/11
realized [1] 458/12
really [26] 236/5238/9239/21241/17
247/21258/19276/7374/15378/7381/13
385/1388/21395/19414/19416/2417/7
422/19430/3437/8447/7448/8460/20
468/3468/8471/4475/18
Realtime [1] 231/20
realtor [4] 399/3407/22438/1438/3
reason [9] 257/21370/18386/9386/11
393/19411/6411/6448/9470/3
reasonable [9] 248/21259/15259/21
266/9274/11274/23289/23290/18290/19
reasons [6] 238/11261/18343/19357/4
357/12380/19
rebuttal [3] 265/23266/3266/5
recall [11] 263/23347/14348/12369/21
382/4408/6408/18419/1419/7420/25
464/22
receive [1] 294/15
received [9] 271/10272/17293/6293/9
331/12336/5368/11388/23410/7
receives [1] 388/8
receiving [4] 272/14327/4331/16344/1
recess [5] 244/23246/4246/10249/2
319/3
recognize [3] 310/11312/25371/4
recollect [1] 403/14
recollection [1] 264/6
recommending [1] 428/15
record [61] 246/3262/24280/2284/18
291/12293/17295/25300/25306/14
309/13309/16309/22309/25312/18
317/10324/25325/3325/21325/25327/16
327/18329/25330/3330/24331/15332/2
333/20333/22334/14334/18339/1340/24
341/25342/6343/12344/8344/11347/18
347/23349/9349/14353/3354/17356/20
362/1363/23363/25364/7364/7364/15
365/13366/14372/10386/16386/18398/4
432/3433/22437/12438/25476/13
recorded [4] 231/18336/5417/5426/9
recording [9] 236/23280/8281/16
281/25412/13413/13413/15417/9475/7
recordings [1] 262/11
records [26] 241/18241/18242/1287/12
295/8301/1303/22310/7310/18311/17
311/19313/7313/20313/25314/11316/5
328/14333/2342/9343/17345/3349/22
362/10383/7383/10465/11
RECROSS [2] 396/14429/8
RECROSS-EXAMINATION [2] 396/14
429/8
red [1] 311/18
redirect [5] 393/5393/8428/10428/12
443/5
reduced [1] 476/11
redundant [1] 472/18
Reeves [9] 271/5276/17280/14331/7
331/12331/15331/19331/23332/2
refer [3] 299/25400/9433/14
reference [1] 464/9
referencing [2] 1/6300/2
referred [1] 252/18
referring [4] 243/4322/5446/24474/16
reflect [2] 332/22433/22
reflected [1] 395/8
reflecting [1] 332/19
refrain [1] 459/6
refraining [1] 459/11
refrains [1] 462/7
refund [5] 268/9271/23272/1272/8
346/3
refunded [1] 346/14
refusal [1] 462/8
refuse [1] 469/17
refused [2] 427/15460/21
refuses [1] 462/11
regarding [1] 374/6
regards [32] 237/5241/25304/17311/12
311/16313/14314/25315/4315/9316/10
317/18317/25318/2318/6323/16324/2
324/11328/1329/24330/17330/21331/23
337/19344/5347/10348/5350/4353/2
363/25369/5418/17464/18
region [2] 278/16278/17
register [2] 270/2295/14
registered [2] 282/12295/11
registration [3] 282/9282/15295/22
registrations [1] 286/24
regular [2] 281/14300/19
regulated [2] 279/22279/23
reinforce [1] 279/15
reissued [1] 394/8
reiterate [2] 374/5374/17
reject [1] 257/16
relate [6] 310/13318/7338/22362/4
365/15372/2
related [37] 293/2293/12295/2295/8
296/11297/8304/14310/7310/18312/21
313/7314/14326/7328/3328/15328/23
329/18332/7336/14339/14340/3342/7
350/19356/5360/2364/16373/14394/12
394/17396/6407/24409/13410/1410/4
410/21428/23430/10
relates [2] 304/22349/17
relevance [5] 357/5450/21455/16
465/17468/6
relevant [17] 237/8237/22238/7413/8
413/21414/19451/24453/22454/25
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relevant... [8] 458/10459/13459/16
464/3465/7467/19467/24470/15
religious [2] 381/2381/3
rely [1] 290/20
relying [1] 382/9
remain [12] 259/6434/16459/19459/21
460/3460/14462/6469/4471/14471/15
472/11473/2
remainder [1] 464/18
remained [1] 281/13
remarks [2] 254/8254/10
remember [25] 247/13265/15276/10
288/19318/15319/8319/14320/7320/11
320/13356/9382/4392/10392/11392/17
392/20394/1405/15410/20421/15426/6
429/19430/14439/24444/21
remind [4] 241/21254/20325/6330/7
remiss [1] 240/22
removed [2] 470/17473/9
renew [5] 242/22243/1243/2354/18
378/17
Renewal [1] 360/8
renewing [1] 364/18
repaid [2] 279/3279/5
repay [2] 281/15287/4
repayments [2] 281/21284/3
rephrase [1] 393/22
replacement [9] 360/1360/2360/25
361/1361/14363/3363/20380/11380/19
report [12] 304/19305/7311/8322/21
322/22323/8337/24343/8380/23396/5
435/11467/7
reported [14] 272/7293/18294/19
311/21314/15331/19337/14338/18
339/19344/4346/6346/12346/16476/7
reporter [7] 1/31/71/12231/21400/24
476/4476/19
REPORTERS [1] 475/24
reporting [4] 292/25328/14348/22
380/25
reports [2] 340/20381/18
represent [1] 345/21
representative [1] 284/2
representatives [1] 270/19
reputational [1] 292/25
request [6] 304/6384/5429/21430/18
430/21473/14
requested [6] 285/14286/3286/7391/12
391/22392/1
requesting [5] 285/19286/11301/17
358/16358/18
require [6] 282/15283/2359/3359/5
361/13387/19
required [3] 265/19282/16368/25
requirements [3] 269/6269/11269/20
requires [2] 279/17387/20
research [6] 260/19334/13355/22383/2
409/16412/25
researched [3] 343/16347/3347/18
researching [1] 411/7
reside [1] 269/14
resided [1] 270/25
residence [1] 290/5
respect [1] 460/23
respective [1] 266/24
respond [2] 458/9470/18
responding [2] 449/11459/9
responds [1] 453/6
response [14] 237/8238/2238/13
254/14368/13369/6451/5451/11451/17
453/17459/15463/18472/21473/16
responsibility [1] 294/22
responsible [3] 308/21308/23308/23
rest [5] 276/17286/20365/2448/4461/22
resting [1] 265/17
restricted [1] 1/3
result [3] 271/9359/17369/16
resulted [1] 272/14
results [1] 311/11
retaining [1] 269/17
retire [2] 260/1306/8
retirement [7] 294/2294/7294/7294/13
306/19307/2394/25
return [33] 268/9272/8272/18273/1
274/25277/6277/8284/22284/23284/25
285/10285/11285/13285/14285/15
285/22288/14288/17288/21290/25315/5
324/11337/3344/24345/15351/3355/16
366/7370/3391/6391/8391/12391/22
returned [1] 312/18
returns [18] 268/8271/18271/19271/21
272/4272/6272/10272/13276/16277/1
277/2277/5284/6284/7284/9355/11
355/13392/8
Revenue [2] 345/2350/19
review [1] 388/22
reviewed [2] 239/19389/12
rich [2] 278/12278/12
ride [1] 420/12
right [263]
rights [3] 278/15469/13470/2
rip [1] 440/24
rise [9] 250/17318/20319/2321/3373/23
376/7411/25418/6445/3
rode [1] 420/16
role [4] 254/11267/1292/11293/5
room [5] 260/3261/1261/21262/1
319/18
roughly [2] 329/17404/23
Rover [2] 273/17421/16
ruin [1] 261/10
rule [2] 255/21392/15
ruled [1] 243/3
rules [8] 243/12255/5258/18282/15
283/2387/24392/20456/19
ruling [1] 243/4
rulings [1] 448/23
run [5] 250/11254/23267/6387/4387/4
running [2] 286/2418/4
S
s-W-E-E-T-E-N [1] 432/6
sacred [1] 274/25
safe [1] 279/23
Safety [2] 362/2364/11
said [73] 236/4236/4238/7245/18247/5
251/23254/20259/14259/20262/19270/6
270/10274/19275/5275/12281/2282/3
282/5285/20287/9292/15310/25316/11
319/7320/11320/13322/12344/19406/5
406/22407/18407/21410/7411/7411/9
411/10413/10414/6414/15414/20415/3
415/5415/6415/16415/17416/13419/17
419/19421/23424/3426/21427/2427/5
427/8427/15427/23427/25428/3428/4
428/17429/3429/10438/5444/21448/9
452/10455/23455/25455/25456/16
457/25460/7476/11
salaries [1] 345/22
salary [2] 410/17419/8
same [66] 247/17249/16271/16272/11
272/11273/15274/5295/5297/20300/3
301/25309/19311/3313/17314/8315/23
316/8323/16337/9342/16345/14351/14
352/5352/21352/23360/8362/11363/2
363/22364/17365/22366/8366/17370/21
370/23370/23370/25371/4371/22372/6
372/15374/20375/17376/10389/21
390/23391/2395/3401/13401/15401/17
401/22401/22402/6402/13419/3422/17
433/15441/25441/25442/18442/22
447/14450/3454/3467/6
Sandy [1] 246/14
sat [2] 320/7420/15
saved [1] 440/9
savings [1] 437/11
saw [20] 253/2253/11254/22255/16
255/17320/25328/2337/7348/25351/15
370/22406/21409/13410/21413/2421/13
421/18437/8441/11467/22
say [93] 235/10237/7237/16237/19
237/23237/24238/15239/24241/3242/25
243/3243/6244/14244/17245/24245/25
249/4254/24254/25255/4259/11262/7
275/3275/4276/17276/20281/10284/19
287/1288/16319/16320/2338/13369/24
381/13381/15383/20391/15391/17392/5
401/23404/24409/14412/17413/9413/21
413/22414/1414/1414/10414/10414/17
415/3415/21416/20416/25423/7427/5
437/1437/16441/12441/23442/1449/3
449/11450/2450/19450/21453/9453/21
453/24453/25455/19455/22456/5456/8
456/15459/1460/2460/23461/25462/25
463/1463/9466/16467/21468/3468/9
469/4469/17469/20471/13474/14
saying [25] 236/16238/9289/2415/7
416/18422/17449/24449/25450/16
450/17451/3451/4451/7453/8457/10
457/16458/6460/16460/19465/6466/22
468/13470/8470/12473/8
says [68] 237/21254/14254/22282/1
282/11297/18298/20298/22299/19
299/20299/21301/22302/13304/5308/18
311/5311/6311/19313/18322/22340/10
346/6360/22362/16363/7367/22368/10
369/11369/15374/1374/5436/5436/6
436/14436/18441/16445/24447/13450/7
451/9452/1452/3452/10452/13452/16
452/21454/11454/21455/17456/6456/22
457/18457/25460/1460/2461/19462/25
463/9465/2465/19465/20467/12468/6
468/10471/9473/5473/23474/8
SBA [1] 429/20
scheme [4] 268/5268/7268/13277/13
schemes [1] 268/4
school [16] 277/16378/11400/4400/14
400/16400/17400/19401/12401/18
401/19402/15402/16402/19403/1424/4
424/6
Schulz [1] 390/10
Scoot [1] 398/16
Scott [6] 314/23314/25324/2324/5
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 272 of 281
S
Scott... [2] 324/11326/22
Scott Ackers [1] 324/11
screen [10] 267/24302/7303/6330/12
336/20340/14352/12352/13434/24
434/25
screens [2] 262/9267/22
screenshot [3] 310/14311/1311/1
screenshots [1] 313/3
screwdriver [1] 240/13
scroll [3] 327/21332/11360/14
seal [1] 296/23
search [10] 261/11295/8310/7311/16
313/17314/8316/6373/2450/12450/13
searched [12] 313/15314/4315/4316/3
324/23325/4325/7328/13332/6333/1
333/18336/8
seated [11] 249/3250/19251/21251/23
318/22319/5321/5374/1398/9418/8
432/7
second [24] 235/12244/14254/12259/1
262/5268/7328/19331/6369/16370/6
370/13370/19371/6371/17371/22372/23
379/19384/22394/6411/24412/4424/8
463/14471/5
secondary [2] 277/16424/4
secondly [1] 238/14
seconds [2] 243/19262/6
secret [7] 280/16280/23283/23414/7
427/6427/7427/8
Secretary [11] 282/10282/16282/25
295/14295/21296/18297/2302/1386/16
386/18386/19
secretive [1] 411/10
section [16] 297/16302/12303/3336/22
338/2346/3355/9358/5358/24359/14
363/15368/7368/7368/9369/8474/22
sections [1] 369/5
Securities [1] 365/1
security [236] 239/17239/25255/16
255/17270/17270/19271/17284/18
291/21292/6292/20292/22292/24292/25
293/7293/10293/11293/12293/14293/16
293/21293/24293/25294/13294/14
294/19294/24295/4295/8295/12300/9
300/15303/15303/21303/23305/24
305/25306/6306/10306/14306/16306/18
306/19306/25307/1307/10307/13308/5
308/19308/24309/6309/9309/10309/13
309/21309/25310/17311/21311/23
311/24313/7313/21313/23314/15315/1
315/6315/11315/25316/16317/2317/6
317/11317/19323/16323/19324/15
324/17325/11325/21327/9327/16327/18
328/6328/14328/22329/10329/24330/3
330/3330/18330/24330/25331/15331/18
332/1332/22333/15334/10334/14335/23
335/24336/6337/24337/25338/6338/23
339/13339/14339/14339/18339/19
340/20340/21340/24341/22341/23
341/25343/8343/9343/12343/19343/22
344/1344/9344/12344/12347/19347/19
347/23349/3349/4349/10349/14352/19
352/21353/3353/4353/18354/12355/17
355/20355/23356/1356/4356/16356/20
356/21356/22358/16358/19359/2359/3
359/16359/18359/20360/1360/2360/3
361/13361/14363/3363/4363/7363/9
363/19363/20365/23366/13366/14
366/21366/22366/24366/25367/18368/3
368/11368/23369/17370/3370/6370/9
370/10370/12370/18370/24371/1371/4
371/5371/17371/23372/16372/23373/3
373/5373/7373/11373/13373/15374/6
375/6376/19376/21377/1378/2378/14
379/7380/9381/16381/17381/22382/17
382/19382/22383/4384/17384/23388/10
390/1390/20390/22393/11393/12393/18
394/6394/8394/19394/25395/4395/21
395/23396/2396/6396/8397/4441/19
442/13
Security's [10] 310/8310/15314/12
315/15332/6333/1334/13347/3347/18
373/3
see [115] 235/13248/25251/2251/6
255/17256/6258/2261/21262/9267/22
267/24269/23270/13271/2272/3276/9
280/13282/13284/8284/14285/3285/5
285/7285/9285/11287/15287/15287/23
287/23288/12288/12296/8299/7299/16
301/23302/3302/12303/5305/13305/19
307/16308/3311/18313/18315/14315/23
316/8316/25317/10317/20318/3318/18
318/25319/9322/9323/12324/25325/3
325/24327/24328/14329/5330/12330/17
331/6332/13333/2333/10333/20334/5
334/14334/18335/14338/14345/10
345/17345/19346/21347/17350/11
350/13351/25357/18358/10359/11361/5
361/19362/16363/7363/18365/20366/2
369/25373/6373/10373/13373/20378/4
399/16421/23424/20428/19428/21
433/17441/10441/14441/24459/2466/10
468/8468/11471/3472/21473/6475/13
seeing [3] 253/10262/14413/1
seem [6] 238/6238/10240/12258/1
258/9470/1
seemed [1] 415/1
seems [7] 237/22238/3470/2473/2
473/3475/4475/4
seen [7] 296/25328/3342/16345/14
424/1464/4474/11
seize [1] 237/11
select [1] 235/10
selected [3] 319/19320/4320/6
selective [1] 473/3
selectively [1] 474/8
self [1] 358/17
selling [1] 235/20
send [13] 234/19234/20238/25243/18
319/23320/15437/18437/22461/10
461/15462/1462/12474/7
sending [1] 455/9
sends [1] 284/12
senior [1] 277/24
sense [8] 239/5257/18282/23378/6
378/12460/19472/15474/13
sent [4] 277/6284/24285/10286/18
sentence [5] 239/22243/13472/7473/10
473/23
separate [1] 454/24
September [3] 299/20299/21341/16
September 17th [1] 299/21
serious [3] 250/5261/15268/16
serve [2] 319/20320/10
service [4] 274/16319/19345/2350/19
services [2] 294/23395/18
sets [1] 272/12
seven [1] 356/11
several [4] 278/22384/19389/14424/12
shared [1] 339/22
she [7] 247/16247/16258/3277/16392/5
433/22434/1
she's [3] 247/18262/23262/23
sheet [1] 316/5
shirt [1] 433/21
shooting [1] 457/20
short [3] 274/20431/13443/24
shortened [1] 283/13
should [24] 242/16249/17249/17249/18
257/15257/16260/13263/19294/8295/17
336/13340/13374/21386/1411/12412/2
412/20414/15449/4458/13460/19461/24
464/8468/19
shouldn't [4] 235/7254/10257/10375/3
shovels [1] 279/15
show [21] 245/24250/3269/2270/2
270/8271/1272/20273/9275/16276/12
277/10280/4284/21286/5288/24289/10
316/18377/24405/23406/2407/13
showed [7] 249/10316/5406/16407/10
407/17425/1425/3
showing [2] 406/10408/4
shows [4] 284/22284/23386/18452/5
shuts [1] 280/21
shutting [2] 268/15287/10
side [6] 256/21345/20351/22352/1
352/2352/13
sides [1] 266/16
sign [2] 308/4308/4
signature [9] 339/6339/8341/5341/7
342/13342/13358/13369/9369/15
signed [5] 274/2280/13296/23369/9
393/15
significant [2] 234/14451/19
significantly [1] 248/17
silence [2] 470/11471/18
silent [11] 259/6459/19459/21460/4
460/14462/6469/4471/14471/15472/11
473/2
similar [6] 311/3315/21323/12330/17
340/19367/23
simply [1] 260/2
since [15] 259/6270/1283/21283/22
309/1357/17370/17399/10400/14404/1
404/4410/11432/15433/3445/10
sir [120] 239/6239/7244/8249/1267/25
318/24319/4320/20375/21375/23379/4
379/5379/9379/13379/15379/17379/24
380/4380/10380/22380/25381/4381/6
381/10381/14382/1382/8382/20383/1
383/8383/11383/17384/25385/4385/7
385/14385/17385/22385/24386/6386/7
386/17386/21387/16388/1388/4388/6
388/16388/25389/16389/18389/20390/6
390/22390/24391/5391/9392/11392/25
396/19396/21397/12397/15397/19
398/12412/9418/3418/5418/5422/5
422/8422/11422/13422/16422/18422/22
422/24423/1423/3423/12423/15423/19
423/25424/2424/5424/7424/9424/11
424/15424/17424/22424/25425/4425/7
425/9425/12425/14425/17425/21427/17
428/2428/8429/12429/14430/23431/8
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 273 of 281
S
sir... [14] 432/20433/16437/21439/5
439/10439/13440/11440/16440/18441/5
441/7441/15442/2474/25
sit [11] 250/3255/11319/11376/9376/11
376/14381/10417/7418/10436/18454/17
sitting [1] 252/16
situation [2] 441/2441/3
six [4] 278/18292/15356/13404/2
sizeable [1] 269/7
skip [2] 316/7472/6
SkyWest [1] 278/5
slate [2] 258/25259/13
sleep [2] 410/15416/23
slicing [1] 473/20
slightly [2] 322/20401/23
small [12] 268/16268/21268/23268/24
269/3269/7269/9269/11269/20278/2
279/12279/18
smaller [1] 348/16
Smith [3] 254/23254/24283/17
snafu [1] 245/7
sneaky [4] 275/19287/22288/7288/10
Snow [2] 271/6283/16
so [326]
Social [249]
Social Security [172] 239/17239/25
270/17270/19271/17284/18291/21292/6
292/20292/22292/24292/25293/7293/10
293/11293/12293/14293/16293/21
293/24293/25294/13294/14294/19
294/24295/4295/8295/12300/9300/15
303/15303/21303/23305/24305/25306/6
306/10306/14306/16306/18306/19
306/25307/1307/10307/13308/5308/19
308/24309/6309/9309/10309/13309/21
309/25310/17311/21311/23311/24313/7
313/21313/23314/15315/1315/11315/25
316/16317/2317/6317/11323/19324/15
324/17325/21327/9327/16327/18328/6
328/14328/22329/10329/24330/3330/3
330/18330/24330/25331/15331/18332/1
332/22333/15334/10334/14335/23
335/24336/6337/24337/25338/6338/23
339/13339/14339/14339/18339/19
340/20340/21340/24341/22341/25343/8
343/9343/12343/19343/22344/1344/9
344/12347/19347/19347/23349/3349/4
349/10349/14352/19352/21353/3353/4
353/18354/12356/20359/18363/7365/23
367/18370/3370/9370/18371/1371/5
371/17371/23372/16373/3374/6375/6
376/19376/21377/1378/14381/17381/22
382/17382/22384/23388/10390/1390/20
390/22393/11393/12393/18394/6394/8
394/19394/25395/23396/2396/8397/4
442/13
Social Security's [9] 310/8310/15
314/12315/15332/6333/1334/13347/3
347/18
sole [3] 283/6387/10387/11
solely [1] 343/21
some [73] 234/16235/7237/5239/8
241/7252/2254/3257/1258/12258/18
266/10271/4276/24277/13279/13279/17
279/18285/17288/18288/20292/19
295/14296/8300/5301/13306/21307/22
308/5319/23321/16326/21327/7328/2
331/20336/24343/19355/3355/12357/21
361/13361/16367/23368/1376/16377/25
382/13382/13384/9384/12392/5400/5
404/4405/6405/22406/2413/3414/13
415/16415/19415/24416/16417/8420/6
425/1425/2425/3430/1439/20448/9
451/18453/19455/10459/4
somebody [18] 235/7253/2253/10
254/22260/21261/19261/20264/2264/4
283/15380/16390/9390/12466/8468/18
471/7473/15474/8
somehow [1] 458/25
someone [8] 257/19307/19359/2393/10
409/19460/13472/1472/3
something [69] 235/5237/11237/14
237/16237/19238/9242/16242/25243/3
243/9244/17245/25253/7254/15254/22
256/13256/13256/18262/3263/15263/23
263/23264/13264/16264/22265/1283/19
290/2296/25306/14306/17307/23309/1
309/5310/15321/1349/19374/2374/16
395/7407/12411/14413/20413/22413/23
414/6414/11415/10416/18433/20439/18
444/15447/13448/19448/21448/21450/2
452/1452/13457/11458/4459/7460/17
465/1465/21465/22468/12468/24470/17
sometimes [8] 256/16257/10276/6
394/1404/12423/21423/22423/22
somewhere [4] 240/14261/24403/24
420/20
sorry [38] 246/11247/2283/12303/5
312/7316/22319/14320/24320/25322/14
326/12335/21340/15341/2349/24350/15
356/19362/6369/20371/10385/9385/24
391/16392/16394/13399/21405/19
419/18423/7432/19438/4443/11446/8
447/15447/17447/17447/18472/14
sort [21] 238/8238/17242/13243/16
247/19248/22249/10276/4294/9302/7
304/7305/19396/23412/12413/2445/25
447/5448/24449/20459/4471/19
sought [1] 272/8
soul [1] 276/18
sound [1] 271/5
sounds [4] 275/7378/10379/15453/12
source [3] 273/3273/10289/13
South [1] 461/11
space [1] 361/20
speak [5] 251/2251/7397/12469/11
469/12
speaking [3] 242/15370/9370/12
speaks [4] 251/7274/25291/1291/1
special [4] 291/6291/25292/19295/13
specialized [2] 292/7292/14
specific [23] 239/23270/16326/21
353/15355/3374/25380/15394/17395/8
395/22395/23407/3415/24420/23448/18
461/6462/7466/10469/17470/8470/16
474/19475/9
specifically [12] 238/20269/9269/12
295/7338/25343/15411/5418/12419/1
428/17459/11466/10
specified [1] 311/19
specify [1] 311/8
speculate [2] 384/4412/20
speed [1] 417/16
spell [3] 291/13398/4432/3
spelled [1] 389/23
spend [4] 246/5281/5281/6287/2
spending [2] 273/16288/22
spent [9] 250/4268/11273/19273/23
273/25274/5274/8281/7288/23
spoken [2] 404/17422/10
spot [5] 248/22319/17376/10376/12
376/12
spouting [1] 416/3
spree [1] 273/16
Springs [1] 246/14
square [1] 408/19
SS [5] 305/14305/22305/24323/19324/8
SSA [2] 291/25395/19
SSN [3] 303/1360/22360/23
SSNs [1] 311/3
stamp [1] 375/8
stand [11] 248/14248/16251/17251/23
305/23306/3410/6417/22455/19471/12
472/17
standard [3] 234/25239/17289/23
stands [2] 274/19305/24
start [10] 235/11247/16250/20278/23
286/20320/12416/3419/17419/18444/10
started [5] 387/19406/7416/24454/21
454/22
starting [7] 246/12247/24248/1261/20
311/12446/3446/13
starts [7] 240/5247/14258/24259/13
361/11361/22454/3
state [29] 282/10282/16282/25291/13
295/11295/15295/21295/21296/18
296/21297/2302/1353/23364/8364/10
365/13372/10375/12375/13377/7377/9
377/12386/16386/18386/20398/4432/3
436/19436/21
statement [19] 238/4242/14243/2
243/22267/14445/6447/9453/9453/12
458/8461/1465/3465/8465/8465/13
465/17467/21467/23468/6
statements [15] 237/5254/5254/5
265/12266/16266/17266/19266/22
369/14376/24412/16449/11461/2465/15
475/7
states [26] 231/1231/3259/20265/20
267/13269/14270/25271/2290/4290/5
291/5382/13399/7403/4403/6403/9
403/13403/16403/18405/7405/9405/21
432/16470/4476/5476/9
stating [1] 459/11
status [1] 419/16
stay [10] 247/22267/20402/16402/18
403/2403/8403/19463/10463/14463/16
stays [1] 463/12
Stenograph [1] 476/7
Stenographic [1] 1/12
stenography [1] 231/18
step [5] 244/13264/23268/25411/23
412/2
steps [1] 273/2
stern [1] 444/17
sticking [2] 458/6468/6
sticks [3] 464/2465/2467/12
still [32] 234/6238/5244/25247/20249/5
249/21274/2281/11297/8309/5323/19
323/22323/24342/24360/16365/4365/5
387/15393/13393/15403/5404/12429/17
434/13436/11441/6441/9444/6448/3
458/6459/8473/22
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 274 of 281
S
stipulated [3] 252/20252/21301/1
stipulation [13] 241/21242/6244/7
295/25298/1310/18313/7345/2350/19
357/2357/10362/10364/16
stipulations [4] 241/7241/7244/2
252/23
stolen [2] 273/16275/15
stood [1] 409/24
stop [6] 241/1268/19271/16416/19
458/17469/8
stopped [2] 434/17470/21
story [4] 275/6458/6463/2467/13
straight [1] 286/1
strength [5] 238/4446/10447/8454/10
454/14
strictly [1] 459/6
strike [5] 246/20256/16256/19256/20
447/19
stringer [1] 253/13
strong [1] 238/9
strongly [1] 245/23
struggling [1] 417/6
stuck [2] 278/3383/14
student [1] 277/23
studied [1] 277/20
stuff [11] 237/23238/14260/20261/7
287/22288/11288/15289/3289/22318/17
378/14
subject [3] 241/21298/1357/1
submit [4] 271/18337/4395/21461/5
submitted [35] 268/8269/23270/14
271/3272/5272/6276/14276/15280/14
290/15297/2307/9307/10311/10311/24
312/16316/13321/23331/9333/24348/13
359/14359/15361/17363/15367/14
367/22381/23388/15388/17388/19
388/22395/17395/20397/3
submitting [2] 394/17453/14
substantially [1] 402/8
subtract [1] 346/8
such [6] 237/7238/7269/17290/19
380/16392/8
suggest [2] 257/17470/21
suggesting [1] 461/1
suggests [1] 254/16
suit [1] 433/21
summarizing [1] 412/16
summary [6] 285/7322/21322/22323/8
326/9435/11
Superior [1] 299/4
support [8] 269/15270/6270/14271/4
321/23344/1368/2381/23
supported [1] 382/6
supporting [2] 301/13305/3
suppose [1] 375/18
supposed [17] 247/19250/22264/25
281/3287/2307/6309/2319/6319/16
324/4324/8345/20346/6346/12348/21
352/7410/18
supposedly [1] 272/10
suppress [1] 243/1
suppressed [2] 242/16460/19
suppression [3] 460/18460/22474/14
Supreme [4] 460/7460/12468/9474/17
sure [37] 235/23236/5246/22262/6
264/24274/21274/22289/7291/14296/9
303/5321/18322/13374/22376/19376/24
378/19383/19383/21384/7384/19386/4
390/19393/7395/7395/11396/13413/25
414/25417/21418/11418/15443/4445/11
466/12472/16473/18
surprising [1] 410/9
surreptitious [1] 283/19
survey [1] 381/7
suspect [1] 252/19
suspicion [1] 414/11
suspicions [3] 414/19415/20416/4
suspicious [1] 414/24
sustain [6] 256/5256/9256/13393/24
406/20447/4
SW [1] 231/22
Sweeten [14] 332/14332/19332/23
333/3390/23431/23432/5432/10439/9
441/16441/21442/5443/7443/12
Sweeten's [1] 436/1
switch [3] 267/19280/17321/12
sword [1] 448/24
sworn [5] 251/20251/24291/9397/25
431/24
system [14] 280/2289/24306/18310/8
310/15311/2311/3313/21315/15317/19
332/7347/3347/18373/3
systems [4] 231/20293/11314/12
334/14
T
T-Y-S-O-N [1] 291/15
take [29] 251/22251/24261/2262/1
263/3263/7264/1267/5285/15295/18
307/1307/25318/13353/13372/25373/21
411/22420/18440/12442/3445/22448/1
454/12457/14458/17470/8471/21472/20
473/21
taken [10] 244/23246/4246/10249/2
294/6307/24308/1319/3459/7473/19
takeovers [1] 292/13
takes [5] 262/18280/21294/17454/13
472/17
Takhalov [2] 235/16235/17
taking [5] 453/16454/19462/10462/20
474/20
Takoradi [1] 367/4
talk [62] 234/20235/12235/15235/21
236/5236/13236/19236/20237/1238/19
239/2239/12242/13245/14246/5250/4
254/1255/13259/22260/2260/3260/5
260/10260/16263/20264/22265/1265/8
266/8278/8280/22284/6289/18318/14
318/16318/17318/23377/25385/5391/6
398/16403/16406/21408/22410/22
418/12418/14419/6419/22434/18434/19
444/19444/23444/24445/5463/11463/18
465/25466/25467/15469/6475/5
talked [12] 239/15326/21343/18385/13
387/17394/11403/4418/23419/11422/12
423/16444/2
talking [47] 236/10237/6239/23241/24
242/12243/5243/15251/10265/3265/4
280/5281/18288/5300/3326/16379/7
381/8396/16396/17396/18400/10400/23
405/22409/11419/3419/15425/25426/2
426/3433/15437/16447/6447/15450/15
452/12454/14455/1458/18461/13462/17
463/3466/16466/17467/23468/9468/14
470/21
talks [1] 452/16
tasked [1] 292/21
taught [2] 277/15278/1
tax [134] 236/17268/7268/8271/18
271/19272/4272/6272/13272/18272/25
276/16277/1277/1277/8283/1284/6
284/7284/9284/25285/21288/14288/17
288/21293/25293/25294/16294/22295/2
303/23303/23305/14305/14305/14
305/22305/24305/24305/25306/3306/4
306/13306/16306/16306/23306/25307/1
307/6307/20308/5308/5308/19308/22
308/23309/9309/19311/24313/23314/15
315/14315/14315/24315/25315/25316/2
316/16316/16323/17323/17323/19
323/20323/22323/22324/8324/8324/15
324/15324/17324/19325/11325/14327/9
327/11327/14328/8330/4330/4330/18
330/18330/25330/25331/18331/19
333/15333/15334/10334/11334/14
334/15335/24336/1336/16337/2338/23
339/14339/15341/23344/23344/24349/4
349/7350/3350/5352/16352/21352/25
355/11355/16366/7370/3391/6392/7
392/7392/8394/12395/17395/21395/22
396/6396/6423/6423/8423/9436/21
457/17457/18
tax-related [1] 295/2
taxable [7] 338/6340/20340/20343/8
343/9344/12344/13
taxed [1] 279/25
taxes [59] 270/17271/22271/25285/16
286/9293/21293/22294/5294/9306/23
309/10309/13309/20312/3313/24313/24
314/17315/1315/1315/6315/6315/11
315/11317/2317/6317/14324/25325/3
328/15329/13332/22332/22333/2337/3
337/25339/18340/22343/10343/19
343/22344/2344/2347/19347/20348/22
349/10349/10349/14349/14353/4353/4
373/14387/6387/7392/19395/4395/4
442/11442/11
teacher [1] 275/23
Tech [1] 245/5
technology [2] 1/13277/19
Ted [1] 231/22
tell [42] 237/20238/1240/24247/3247/4
247/5248/1253/18255/13256/19256/20
257/22259/25260/9260/17262/16264/16
268/13275/3276/8277/3284/3291/19
317/4319/9344/22360/22366/8374/18
375/5375/8375/25377/8391/25398/12
405/25407/15425/24426/21444/23
454/18470/4
telling [17] 257/20318/16413/2415/15
426/18426/19426/20449/14450/16
450/25452/5457/22457/25463/8464/15
467/11468/23
tells [3] 247/8280/24284/2
tempting [1] 417/8
ten [4] 246/5373/21373/22381/8
ten-minute [1] 373/21
tend [1] 242/24
tent [1] 244/21
term [2] 276/6303/11
terms [57] 248/7293/16294/9294/10
295/13301/9303/17305/19306/3306/16
307/4307/15308/13308/20309/1310/6
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 275 of 281
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terms... [41] 313/23315/24316/2317/5
317/13321/19323/15326/2326/11329/21
330/18334/13335/4337/2337/6338/5
338/25340/19345/19347/17348/21356/4
356/18359/14360/16394/16401/18
402/19408/20408/25419/10419/14
419/25421/17430/10451/22460/24
461/19470/10474/15474/17
testified [10] 291/10380/8385/11386/15
391/10392/3396/1398/1431/25443/7
testifies [1] 258/3
testify [8] 259/4259/8259/9259/12277/4
387/25406/24413/6
testifying [3] 258/9304/13422/14
testimony [24] 240/2240/4252/15253/1
253/6255/24257/15258/6258/7264/7
264/19299/25337/10365/2367/23374/25
375/1379/10400/9415/2448/14461/12
467/22471/19
Texas [10] 351/20364/11364/11365/14
366/4432/12432/13432/14436/20436/21
text [2] 346/19360/14
than [23] 244/19249/11251/15261/15
264/6271/22272/15274/6318/15322/7
327/13346/8347/11367/6367/9374/25
391/25402/1402/12408/10417/9421/20
470/20
Thank [73] 243/8246/8246/9249/1
250/16251/21267/15267/25274/12291/3
291/12291/16296/5298/8298/12298/15
299/10301/7310/22310/23312/14318/18
319/1320/19320/20320/23321/8346/19
350/24354/16354/22354/24357/7357/13
357/15360/11365/4373/18374/7376/14
378/22378/25379/1394/4396/11397/17
397/19398/3398/8398/17400/12401/1
412/9412/11418/2418/10421/10422/3
425/2429/6431/6431/8431/10432/2
432/7432/23434/1439/3443/19443/23
445/2467/17475/11
thanking [1] 274/16
Thanks [1] 417/13
that [1293]
that's [174] 234/24235/5235/5235/11
236/11236/24238/16240/22241/21243/5
243/7243/13243/24243/24247/9247/17
248/18248/21253/6254/17256/17262/18
266/9275/8275/8276/4278/6279/12
280/23280/23280/25281/7282/11282/13
283/12283/15283/20283/23284/19285/8
285/9286/5286/11286/24287/5287/21
288/10288/22288/23289/2289/8290/11
290/14293/23295/6299/16299/24301/17
301/21304/7306/15309/1311/6312/1
316/17320/10322/25324/6324/8326/17
327/3327/4332/9337/14338/9348/2
349/19351/8354/5359/15361/1363/12
363/19364/15372/15373/18375/16
375/25377/21379/14379/23382/8382/19
385/11387/11388/5388/18389/21391/7
395/10396/19396/24396/24397/3399/22
405/19405/19405/20412/14413/10
413/12413/20415/11416/19422/2423/9
426/2427/24428/1428/9440/14440/14
440/20441/24442/18445/20448/4448/5
448/6449/15449/16449/16449/23450/10
450/24450/25451/1451/18451/21451/24
452/15453/22454/10455/14457/5457/7
457/8457/18458/3459/25460/3460/24
461/18461/20461/25462/13463/5464/14
464/15464/15465/7465/8466/18467/5
467/10468/24472/2473/1473/3473/16
474/6474/6474/16475/1
their [43] 237/24238/4238/15254/5
254/6254/8254/9254/10263/15265/11
265/15265/16265/17265/25266/9266/12
266/16266/24267/14267/22268/16
268/17285/18288/23290/4300/12303/6
337/3382/15390/20394/17394/23394/24
394/25395/23396/1423/23446/10446/10
447/8454/14455/20467/19
them [76] 241/9241/10243/18244/11
244/17244/18247/5247/5247/8248/1
248/14248/15260/17261/2261/3261/3
261/6261/6261/24261/25262/1262/2
262/2262/4262/9262/10265/1279/18
279/21280/24281/15281/18284/8284/17
288/6288/25289/8307/12313/25320/25
374/9374/13374/18375/4375/5375/20
375/25376/6376/16397/4397/7401/22
412/4417/24420/15421/15421/18429/16
429/17429/21444/18447/23448/10
453/15458/25461/4461/10463/8466/16
468/23471/6471/22472/24473/12473/24
473/24
themselves [1] 254/10
then [156] 234/12234/19235/10237/6
237/17237/19238/2238/5238/9241/23
244/5245/11247/22250/3251/23255/21
256/5256/17256/19260/9264/15265/14
265/20266/1266/1266/2266/11267/6
273/25274/5276/21283/13283/14287/5
292/4292/16294/9294/19296/3296/23
297/16299/1299/20299/22301/13301/23
302/7302/25303/25304/3307/16311/6
311/8314/1317/22323/24324/14325/17
337/4338/10338/12340/21342/19350/22
352/25355/19356/6356/8358/6360/23
361/19361/20361/23363/14366/2369/8
373/21375/24378/6379/19382/24383/14
387/7387/14399/10403/18404/3404/5
409/8412/6413/1420/24421/16429/18
430/3430/21437/10437/18438/12440/21
441/11447/10449/2449/14449/18449/21
450/7451/4451/6451/10451/16451/21
452/10452/16454/22455/4455/7455/18
455/22455/23456/2456/3456/3457/7
458/5458/18459/8459/14460/15460/21
462/7463/9463/12463/13463/20465/3
465/4465/6465/24465/25469/16469/22
470/10470/17470/24471/5471/11471/12
471/15472/9473/6473/15473/16474/3
474/3474/13
theory [6] 254/9275/7276/4288/23455/5
455/20
there [182] 234/16235/14236/2237/5
237/5238/15246/3252/22252/24252/24
252/25255/5255/11256/16256/19260/13
261/4262/8262/12263/22268/15269/10
271/16272/4272/9277/2280/15280/16
280/16280/16280/17281/16284/7284/14
287/15295/3295/17295/18296/22297/16
298/23298/24299/8301/12301/23302/3
302/5302/19302/19303/4303/8303/25
304/4305/9305/16305/20307/15308/3
308/14308/16310/4311/17311/18311/21
311/23311/23312/2312/5312/16313/25
316/11316/11316/15317/1317/13317/22
320/25321/22324/14327/8327/11327/13
328/19332/11334/10335/4338/2339/6
340/8341/5342/13343/17344/6344/8
344/8345/11345/25346/3349/3349/6
351/8351/9351/9357/21358/1358/8
358/13358/14358/15360/14361/16
361/22362/21362/23368/15368/16369/2
369/5369/7369/9369/10374/15375/19
380/18381/2382/6383/25384/12384/19
385/3385/15390/12390/14390/15392/6
392/9392/12392/13393/19394/7396/2
398/22399/17402/21403/11404/5404/20
408/7409/12409/23409/25412/7415/15
416/24417/8421/13424/16424/18427/14
428/20430/11430/14433/19435/8436/3
441/17442/19444/12447/5447/12449/12
453/2455/14458/17459/2462/21466/3
467/2467/24470/11472/4473/14
there's [59] 237/6237/9237/17238/9
238/14249/6253/7262/3262/11276/6
276/7276/8282/4286/22289/14297/1
297/11299/17306/25307/24319/18
328/18338/10343/18344/11361/23
365/25378/10387/8390/8392/15392/16
396/2396/2397/2412/13412/24412/24
429/16429/19429/19446/20447/11448/9
448/14448/20450/14453/1455/24456/12
456/12460/12460/15462/21468/9469/16
470/11471/20473/16
these [62] 247/25250/11252/4257/17
258/12266/22266/25269/20272/4272/10
272/13276/14276/15276/18278/20
279/18279/21280/15286/22288/5305/19
305/22308/6317/13317/19318/6321/16
324/25328/3334/18336/16338/6339/25
340/21352/7353/3353/4355/11355/22
356/4356/15362/9362/9369/5373/2
379/7381/22396/23412/18413/2413/3
421/17425/13448/23450/16453/14455/6
464/5464/7465/11467/14475/7
they [162] 235/2235/2235/4237/7237/9
237/10237/14237/16237/19237/23
237/24237/24238/5244/18245/1248/14
248/15250/3253/2253/11254/7254/9
257/18258/8258/9259/2260/25261/2
262/9265/15265/16265/16265/17265/17
266/1266/5266/5266/6266/17266/18
266/19266/24267/1267/13267/22270/14
270/21271/11271/12274/22274/23
274/24275/3277/6278/23279/9279/23
279/23279/25280/1280/2280/3280/6
280/7280/18281/17282/9282/16284/20
284/24285/9285/9285/10285/14285/15
285/18285/18285/19285/20285/20
285/21286/7286/8286/8286/9286/10
286/10286/11287/1288/16290/7290/11
294/2294/18296/9303/5306/9307/19
320/2323/16329/20337/4343/24359/5
368/23374/9376/1380/12381/16381/17
381/19383/13383/13384/21384/23
386/23386/24387/2387/6387/6387/7
390/1390/19391/25392/7392/18392/18
394/16394/24395/3395/16395/16395/20
397/11401/21415/19415/19423/13
423/23428/19430/18430/21437/12438/3
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 276 of 281
T
they... [18] 440/12444/12444/14444/16
447/23448/1448/15455/19456/18459/18
463/13466/10466/11466/12470/5470/5
474/13474/14
they'll [4] 237/14255/4262/8262/12
they're [33] 234/7237/13237/19238/4
238/8239/24243/17266/22267/5279/18
279/22279/22279/23279/25282/12
283/22285/4285/4288/5307/6380/20
382/11387/7392/9431/19447/9450/7
450/7464/2468/22468/22468/22475/5
they've [4] 275/6275/8289/9449/3
thing [42] 235/10235/11235/12242/13
243/21261/10265/8275/20276/5276/8
280/20281/3282/6282/6283/1283/1
283/25284/20285/18315/23316/8350/16
375/17381/24382/17391/8392/24396/17
396/17396/24413/9416/15421/23444/2
447/14451/24456/7463/19463/25464/5
467/6475/1
things [39] 234/10234/21242/22252/17
254/3255/20257/7258/3258/13260/20
261/7262/9262/11263/12283/21288/5
289/5292/14293/18293/21307/24308/1
375/14377/23377/25378/1381/19381/24
384/19396/19396/23413/1413/2425/13
425/23447/8450/16450/20465/18
think [138] 234/13235/1235/17235/19
235/20235/21236/24237/10239/20
240/21240/21241/12243/24244/10
245/14247/13247/20247/25248/10
248/21249/19249/24250/14253/22
257/18260/4260/13261/13263/12264/14
267/22275/16283/9303/20306/21308/11
312/8312/11314/24322/12322/20325/17
360/22365/2374/11374/12374/16374/19
374/20375/2375/16378/4379/21383/17
387/7388/13400/12402/10405/11405/14
407/17410/7410/10412/20412/24413/4
413/12413/16413/20414/1414/12414/18
415/3415/18416/7416/14416/18416/20
416/25418/1422/2425/23431/15434/15
439/20442/24446/6446/14447/15449/3
449/16456/23457/8457/12457/14458/2
459/16459/18459/22460/6460/24461/5
461/19461/20461/22461/24461/24
462/17462/22462/24463/7463/8463/25
464/3464/17464/25467/18467/20467/24
468/2468/9468/13468/19470/14470/14
470/16471/17472/6472/6472/15472/17
474/6474/6474/12474/20475/1475/6
475/11
thinking [5] 238/20404/24405/17
412/21467/12
thinks [1] 255/7
third [2] 305/16314/4
this [416]
those [106] 234/11234/13241/8241/20
242/17242/19244/15252/21252/23
262/24265/20269/1270/20270/22271/4
271/7277/2277/3277/5283/21290/2
290/3290/4290/10294/6294/9294/10
303/22305/20306/23307/1307/9308/8
309/10309/13312/25313/2313/3313/25
314/16314/16315/5315/14316/2316/3
317/9325/20325/20329/17333/20336/5
340/24341/25343/12344/2347/22351/25
352/3352/25353/13353/16356/10357/11
375/14376/21377/23377/25378/2380/18
382/2383/10384/20385/18388/2389/25
390/18392/19394/16394/19395/8395/11
395/19396/8397/3397/6397/9415/23
415/24420/12421/17421/20437/7453/18
459/14461/2461/3461/3461/6461/15
466/11469/13471/7472/1472/3473/15
474/14
though [1] 449/8
thought [17] 235/3245/1245/6320/24
412/22413/7413/7413/23415/15417/1
426/1427/18427/19450/20458/15461/7
470/13
thoughts [2] 374/10412/16
thousand [1] 279/19
three [21] 234/7272/22273/5284/7315/4
315/16316/4317/9317/19318/2324/23
324/23325/23333/5334/21336/8341/15
362/14369/5385/15385/16
three-quarters [1] 362/14
threshold [2] 392/17392/18
through [42] 236/25239/2262/2262/16
268/4279/2284/17286/1292/7294/22
294/23294/25295/5310/8314/22317/18
325/8326/20327/19331/24332/2332/6
333/3339/25347/3355/12364/18373/3
385/10388/2388/15389/14395/17395/18
402/21402/22429/22447/21449/10454/2
458/17472/14
throughout [4] 264/10394/24411/16
427/21
Thursday [1] 445/11
time [59] 235/5235/9236/6236/14
236/20238/21241/11242/10244/3247/16
247/20247/21250/4254/19254/19255/3
255/3256/7260/10264/21264/21267/9
273/15273/24274/5299/22320/14336/14
353/10353/14353/14356/9372/21374/12
376/10378/24403/6403/11403/23404/5
404/13404/13404/23405/10405/23407/6
408/4409/7419/15419/21421/2421/3
430/11436/12437/14444/12466/24469/9
475/15
timeframe [9] 271/17313/17314/8318/7
325/4325/7402/21404/20405/12
times [10] 269/9295/3300/11306/9
353/16404/19408/16410/12430/12466/3
TIN [1] 303/1
tips [5] 345/22348/9348/24351/22
352/23
title [4] 302/17322/20435/7435/10
today [26] 236/23237/2238/25239/9
246/13247/11247/21248/11248/16249/9
251/6304/13319/4319/17320/10394/11
417/17417/22431/12433/18444/1444/9
444/13444/19445/13447/6
today's [2] 358/8446/19
together [4] 400/14402/24434/5434/17
told [35] 253/2258/15258/15258/19
260/20263/12266/6281/15287/6287/7
287/7287/7287/9287/11319/8319/13
320/3320/6320/9353/14394/1407/20
409/4411/6418/17424/19427/21428/1
428/3428/7440/15450/10459/18462/8
465/21
tomorrow [17] 235/13235/22236/20
236/25242/14246/11246/12247/24248/2
248/14417/20418/4444/6444/11445/9
472/17475/13
too [7] 242/19435/2444/15457/19
464/14468/25471/19
took [13] 234/12251/14269/2273/2
276/2279/5281/10286/8287/13310/14
313/3440/19448/15
top [24] 272/3297/8299/4299/7301/21
301/22302/25304/19305/6308/14311/5
322/23323/7323/12331/6336/22350/25
355/9357/14371/12435/8435/9435/9
466/7
topic [4] 392/10392/11417/19456/9
TORJAGBO [54] 231/5268/4273/7
273/12274/10275/11275/17275/18
277/11283/12283/14289/15297/18
298/20299/2300/2302/6302/16339/9
341/8342/17344/25348/2348/5349/9
350/8351/4352/8355/14356/2356/24
357/20360/20360/21364/1365/18366/23
369/18379/11380/23383/14399/14
399/19399/25402/4402/12433/10438/4
439/12447/10450/16453/13458/18476/9
Torjagbo's [4] 297/23345/10391/8
451/17
total [16] 304/6317/1317/6317/13
317/16317/22317/25323/8326/15326/18
335/10335/23336/1336/3338/17338/22
totally [1] 397/11
totals [6] 316/21317/13318/6321/16
335/2335/4
touch [9] 262/10403/2403/5403/8
403/19404/12424/14434/19434/20
touches [1] 467/6
touching [2] 241/15260/12
tough [1] 300/13
towards [1] 302/25
town [1] 406/4
toys [6] 288/15288/21288/22288/24
288/24289/7
track [3] 293/25309/6394/23
tracking [1] 303/22
Tractor [1] 420/7
Tractor-trailer [1] 420/7
tractors [1] 286/23
trail [5] 273/14288/2289/14297/14302/2
trailer [1] 420/7
trailers [1] 274/6
training [5] 278/4292/8292/14434/4
434/5
transaction [1] 438/9
transactional [1] 289/2
transactions [1] 289/16
transcript [12] 1/11/51/81/91/14231/12
231/18284/18284/19451/21464/19
476/12
transcripts [3] 1/2262/18262/24
transferred [1] 454/22
treat [2] 251/2252/21
trial [10] 234/16252/3252/6252/9262/3
262/5264/10265/9267/1396/24
tribal [2] 278/11278/13
trick [1] 276/11
tried [4] 238/17244/24426/6426/7
tries [1] 450/2
trouble [1] 262/14
trucking [7] 280/21280/25287/3287/11
287/14288/14427/24
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 277 of 281
T
trucks [7] 274/6286/22286/23287/15
288/5420/2420/7
true [10] 252/20254/15254/16272/6
272/12282/6369/14418/16451/14476/13
trust [3] 378/11379/16380/2
truth [8] 257/20257/22275/1291/1291/2
415/15465/10465/10
truthfully [2] 290/11393/20
try [18] 257/6265/3265/4267/9287/22
290/8346/3360/14374/15374/21376/15
417/21448/24448/24456/22457/19
462/23473/18
trying [29] 251/15283/15283/18283/18
287/24287/25312/11383/17413/14
418/15425/2425/15425/19426/14426/19
426/21446/8446/9451/7458/1459/2
459/12463/24464/20464/24466/10
472/14472/15472/21
turn [2] 435/5445/20
Turned [1] 278/18
Turner [1] 231/22
Turning [1] 435/25
Twist [4] 271/6333/10333/12333/21
two [56] 234/6234/14236/11239/17
239/25241/14244/2244/15252/24268/4
268/8271/17271/18272/10272/12276/9
277/2278/14278/15284/6284/7284/9
284/9286/22287/19292/3312/20313/3
338/15339/22342/6343/16352/3353/17
354/12355/11356/4356/15373/7375/6
376/19376/21395/20417/20425/23
429/16430/12430/12430/14433/3434/10
437/6443/3445/14462/14466/11
type [11] 238/12239/8279/9279/9
294/15307/22367/24381/24451/19
467/22475/8
types [2] 361/16419/10
typewritten [1] 476/12
typical [1] 239/22
typically [7] 234/23294/14305/25
307/12307/18395/13415/18
typo [1] 383/13
typographical [1] 383/23
tyranny [1] 274/20
Tyson [3] 291/6291/8291/14
U
U.S [6] 1/14231/21232/2359/9392/19
399/12
U.S. [7] 244/10306/17343/24343/25
344/11344/14392/9
U.S. Attorney [1] 244/10
U.S. citizens [1] 392/9
U.S. employees [4] 343/24343/25
344/11344/14
U.S. individuals [1] 306/17
uh [12] 450/6451/4452/6454/6462/25
463/7463/9463/12463/14463/16463/17
464/13
uh-huh [11] 450/6451/4452/6454/6
462/25463/7463/9463/12463/14463/17
464/13
uh-huhs [1] 463/16
ultimately [3] 306/18308/24338/17
Um [10] 237/12339/17355/7432/24
439/17440/2440/8440/16443/9466/21
Um-hmm [10] 237/12339/17355/7
432/24439/17440/2440/8440/16443/9
466/21
Umm [2] 468/16469/10
Umm-hmm [2] 468/16469/10
unable [2] 268/18268/25
unbelievable [1] 458/5
unchallenged [1] 451/21
uncle [1] 277/22
uncomfortable [2] 243/16471/10
under [30] 251/12268/21272/22283/5
298/18309/16312/17325/23329/25330/4
336/9342/3342/6347/20363/6365/3
366/7369/12373/5373/6373/11380/15
380/18389/24392/18393/15395/8411/13
436/14436/18
underneath [3] 305/9411/14414/8
understand [26] 251/8253/15254/8
254/8254/9258/4266/23300/1319/21
319/22320/1320/17354/4376/25379/10
383/21416/12439/25449/5453/2453/11
455/3463/23463/23466/1468/10
understanding [6] 300/9300/11305/3
447/12447/13448/3
understood [2] 290/5449/6
Undeterred [1] 269/21
unequivocal [1] 460/15
unhappy [1] 319/24
unintentional [1] 236/3
UNITED [25] 231/1231/3259/20265/20
267/13269/14270/25271/2290/4290/5
291/5382/13399/7403/4403/6403/9
403/12403/16403/18405/7405/9405/21
470/4476/5476/9
United States [18] 259/20265/20
267/13269/14270/25271/2290/4290/5
291/5382/13399/7403/4403/6403/9
403/18405/7405/9470/4
universe [1] 442/5
University [1] 292/3
unlawful [2] 289/4289/17
unlawfully [1] 289/8
unless [5] 246/24306/24343/24472/10
474/7
unmoveable [1] 417/19
unnecessarily [1] 264/2
unpack [1] 437/19
unreliable [1] 458/4
until [18] 247/23248/20258/21259/2
259/25260/1260/5260/7264/18267/5
270/3282/25373/22374/25403/5428/22
444/5444/22
unusual [1] 439/16
up [95] 237/6237/10238/10238/17
239/14243/15244/20245/24247/20
248/17248/23249/10250/3250/13251/17
251/23252/16253/11257/13260/21261/3
261/7262/9263/17264/14264/22267/9
268/6273/14276/5278/3278/4278/4
278/4295/3296/6301/7306/8311/11
313/12314/2316/5320/7321/10339/21
340/11345/7346/18349/18357/8360/13
362/13363/12363/14365/10366/19
369/25371/7372/8396/12398/16399/4
403/5404/4407/9407/24408/6411/22
418/3423/23423/23428/22434/23436/1
438/6439/6440/9442/20445/11445/18
446/16447/5450/14451/13454/24455/19
456/12456/13457/20465/12471/12
474/11474/12475/6475/8
update [1] 249/6
updated [1] 234/13
updates [1] 234/7
upon [6] 243/3252/23261/9289/12
290/20467/21
upset [7] 411/20413/20413/23414/9
415/9415/10466/14
us [16] 237/20237/25238/1319/17
340/14398/12405/25407/15445/13
447/11447/11449/22449/22450/11452/8
457/22
use [25] 242/24289/17311/3351/14
353/15374/6375/15377/4377/6377/13
377/15377/17407/22408/5411/12425/10
430/11448/24456/22462/23471/6471/22
472/24473/12473/24
used [21] 1/13261/2263/19269/16
271/17303/14323/24347/14369/2370/24
372/21408/2434/18439/14454/18468/17
469/4469/23470/24471/1471/16
using [6] 267/16273/11273/12282/21
347/22374/22
usually [3] 240/1394/19474/13
V
vacant [1] 472/9
vacation [1] 402/18
value [1] 455/24
vehicle [3] 448/10448/12450/12
vehicles [9] 362/3420/2420/9420/12
421/13421/13421/17421/18421/20
ventures [1] 424/23
verdict [6] 251/25252/10259/7274/25
291/1291/1
verification [1] 363/7
version [3] 387/11446/19446/22
versions [2] 387/8462/14
very [35] 245/25251/11259/2260/10
274/17274/18276/22279/23281/4306/25
318/18319/24350/16370/13374/7377/6
378/10380/13380/14393/6397/18410/10
413/15416/3426/20428/11429/7430/25
431/8440/24443/23444/22445/2451/6
460/24
via [1] 292/13
victim [5] 380/16380/20380/24393/11
394/9
videos [1] 252/17
view [1] 254/9
Visa [1] 277/19
visit [3] 403/20403/21405/4
visited [1] 424/16
visiting [2] 404/12405/22
VOLUME [1] 231/5
W
W-2 [16] 285/4285/5294/4294/18295/1
314/15345/22347/25347/25348/21
349/20351/14351/15351/17351/19
395/15
W-2s [9] 295/5307/4352/7353/3394/13
394/13395/13395/13454/7
W-3 [2] 295/1314/15
W-3s [3] 295/5307/4394/13
W-4s [3] 295/5307/4394/13
wage [2] 332/1345/22
wages [51] 293/18293/25294/15303/22
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 278 of 281
W
wages... [47] 327/18328/15328/20
328/23329/25330/21330/24331/16
331/24333/2334/19335/5335/8335/11
337/24338/6339/15339/15340/20340/20
341/22341/23343/9343/9343/23344/2
344/12344/12344/13347/19347/22348/9
348/16348/22348/24349/4349/6349/10
349/15351/22352/14352/19352/23353/4
373/6394/24395/5
wait [17] 244/19245/9246/25247/2
247/4247/5247/6249/5249/21250/23
254/16275/16412/7453/20453/20453/20
453/20
waited [2] 246/17249/24
waiting [7] 234/6246/6247/4250/9
250/21312/12374/25
waive [3] 461/3462/3469/13
waived [2] 462/6469/15
waiver [1] 242/21
waking [1] 244/20
walk [3] 243/17244/10260/16
walking [2] 253/11431/19
want [101] 234/19234/19235/21237/9
237/20238/24239/12240/15241/8241/8
244/15244/18245/13245/14245/19
246/16247/1247/11248/16249/5249/12
249/21253/24254/9255/4258/17261/20
262/3262/5263/3263/6265/8266/1
267/14267/20267/21268/13276/10
281/11281/22282/25284/19287/1296/9
314/22322/12340/14346/14361/19
369/23373/19373/20374/9374/24376/2
376/10376/19376/24383/19383/21
391/15391/17394/3400/23406/2411/17
411/18414/3414/9415/23416/8417/7
417/23431/12438/3444/6444/25446/21
447/10452/17455/20457/9457/23459/11
459/24460/2460/16461/19461/23463/19
468/8468/14468/23469/18469/21470/5
470/6470/8472/20473/5475/2
wanted [15] 255/18269/6275/24277/21
303/5321/18405/23407/25409/19414/7
419/12437/12445/18448/3448/5
wanting [1] 459/15
wants [6] 254/13260/15265/18299/2
415/2453/8
warrant [4] 237/14450/12450/13452/18
was [426]
wasn't [12] 256/18269/19282/12285/25
383/15386/7386/10407/22416/25426/19
438/1451/14
waste [1] 292/21
wasted [1] 408/4
watch [1] 444/25
water [2] 235/4425/2
way [48] 234/20234/23235/8237/17
240/2246/14251/7257/11260/16261/12
261/15267/17272/4272/10278/3290/2
303/21319/25352/5354/6376/9385/10
386/13386/14387/1394/3406/7408/12
415/25425/5430/12439/1440/17440/24
441/17442/16442/22446/5447/20448/21
448/25449/3463/2465/13468/20471/8
471/18472/2
ways [2] 395/20453/19
we [262]
we'll [26] 236/5239/2241/20244/22
245/22246/5246/6247/2248/25255/13
261/24280/22318/18318/25345/25346/3
374/16416/19433/14445/12466/12
466/12469/3473/21473/21473/22
we're [72] 234/6236/10241/19242/12
242/13242/20247/4247/4247/5247/6
247/20248/1248/6248/10248/18248/22
250/10251/1262/16265/3265/4267/4
267/5267/8274/9280/5282/22290/24
296/9304/10312/7314/18314/20318/12
320/11327/2355/5356/15373/21373/21
375/25376/3382/9396/16396/17396/17
399/18410/11413/14417/11418/11
433/15444/1444/2444/10445/10447/1
447/19450/13451/20452/16452/17
461/12462/17465/21465/22467/23
472/22473/21474/20475/11475/17
we've [23] 243/4246/17249/24250/4
250/10255/13319/17326/21328/3329/18
331/21337/10342/16345/14375/24379/7
390/23422/10450/8450/8450/9452/22
458/19
wealth [4] 288/16288/16288/17288/18
wearing [2] 433/20433/21
website [24] 409/20409/20411/8411/8
411/10425/16425/18425/19426/3426/4
426/7426/7426/14426/17426/19426/23
426/24427/4427/15427/18427/22427/23
428/15428/16
websites [1] 427/10
weeks [1] 272/22
weight [3] 253/22259/11264/5
well [73] 236/13236/19238/2240/17
241/22242/19245/19246/11248/19
249/15255/10266/24267/24279/7279/8
281/2281/10282/11285/8286/14287/1
289/3293/21301/13308/13308/22311/4
314/9319/15341/5343/16357/4361/22
363/3365/15376/2379/23382/12384/14
385/23395/9399/3400/14404/11404/19
405/23409/15412/19412/22415/13416/3
417/11433/7442/24445/10445/12445/25
448/1450/1456/14457/13459/1460/17
461/16461/23462/1462/16463/3463/19
466/13468/11469/1473/20
well-oiled [1] 246/11
went [34] 246/13270/21272/22273/16
277/19278/3278/4278/5280/15282/17
286/15286/17286/17286/20288/13
288/15388/2388/15389/14402/22403/20
412/22416/24420/23420/24424/16425/5
425/13434/5434/10434/11438/12438/13
449/1
were [129] 245/1245/1245/1250/21
258/8268/24269/10270/14272/4275/7
277/2279/9282/5282/8288/8290/6
300/15301/1309/20310/6311/17311/18
312/5312/16312/20312/21313/7313/20
314/11314/21315/2315/11316/11316/11
316/12318/10319/16320/24321/15
321/22321/22322/5326/2326/3334/15
336/5336/16338/7343/17344/2344/5
351/25355/25355/25356/4361/16362/10
368/2368/16368/23370/4373/2374/22
384/12384/19384/20385/15386/6396/7
400/14400/19401/12401/12401/13
401/13402/20403/5403/12403/23403/24
404/5404/12405/21406/10408/11410/3
411/19411/19413/17415/9416/9417/1
419/15420/25421/13421/17421/20
421/24421/25422/15422/23422/25424/3
425/8425/15425/19425/22426/2426/3
428/14430/14436/10436/15436/24
437/19439/18440/1444/17447/15448/1
459/2461/2461/2461/7470/7470/11
472/16475/22476/11
weren't [6] 385/3397/11422/23426/17
428/23458/19
Westcreek [1] 351/19
western [2] 276/2278/17
what [300]
what's [38] 236/8237/18238/7245/17
263/9263/18265/11281/18284/12285/13
292/2294/23298/4298/17300/9302/17
304/21306/5313/14314/6317/16322/16
339/8346/12357/24358/3362/19389/4
408/17412/10413/10423/4435/14445/23
449/21450/21452/15456/12
whatever [6] 253/22392/8444/25446/25
470/3475/20
whatsoever [2] 238/10259/3
wheelbarrows [1] 279/15
when [110] 235/16240/24241/10243/3
243/6244/20248/6252/22255/7255/8
256/9256/9257/2265/16266/10274/24
275/23277/18278/18278/19280/3280/20
281/23283/10284/20288/12290/17
290/22290/24294/3294/4294/18296/20
296/22297/1300/12306/8311/13317/9
319/8320/2324/23328/13333/1333/18
336/8347/17364/20377/21378/4378/12
380/6380/6381/13382/12383/12383/12
385/1386/8386/18396/1399/7400/19
401/3401/12402/3402/20403/18404/23
405/4405/15405/21406/1407/6408/6
409/6409/23413/7420/15420/15420/18
421/24422/14423/10423/14423/18
424/14425/25426/1426/22427/24433/8
434/10434/11437/5449/17453/9453/16
456/11457/7460/2461/19462/2465/20
467/23468/21468/22469/15471/1475/8
where [75] 234/12235/9237/5237/9
237/24238/8238/17239/16243/24245/2
245/8248/7267/20268/5268/7276/1
281/17284/2286/14287/21287/24288/12
291/19294/5294/21295/3301/23302/3
302/12303/1311/18313/18359/9361/10
362/16367/21385/11387/18388/18
388/22388/22399/4400/16400/18402/16
403/21404/5404/20405/1413/6417/25
426/6426/14427/2429/3432/10436/10
446/7446/9447/6447/6449/12451/10
451/17453/21453/24455/8455/25458/25
464/9467/9467/10468/21470/10474/13
Whereas [2] 470/23471/14
Whereupon [17] 244/23246/3246/4
246/10249/2250/18251/20280/8318/21
319/3321/4373/24376/8412/1418/7
445/4475/22
wherever [1] 320/16
whether [22] 235/14237/20252/7253/19
255/23255/24255/24257/16259/8353/22
375/17377/13377/15377/18392/7415/15
460/24462/7465/3465/9468/17470/5
which [48] 234/13234/13238/15247/21
250/13250/14253/9253/13257/13257/14
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 279 of 281
W
which... [38] 258/3268/14269/6270/20
271/22272/4274/25291/1292/13294/23
300/19311/10314/16337/13337/13
347/14356/18359/20364/10364/21
365/13369/21372/10380/1385/2391/16
411/13413/20415/10416/3429/18429/25
433/12437/12448/12454/18457/22460/9
while [5] 258/8261/3262/16424/24
445/13
white [3] 243/15421/16433/21
who [41] 235/1240/14245/4247/14
250/5251/15251/15252/16257/19268/2
270/25275/22275/24283/5297/17307/12
330/7333/23339/8348/6358/15358/20
388/16388/17388/22389/1389/2389/2
389/8389/11391/4397/9399/18400/10
401/19409/19417/20425/18432/21
453/14453/18
who's [1] 245/4
whole [10] 261/10276/4308/1321/25
370/13392/12392/13411/16441/12
463/19
whom [1] 270/20
whose [7] 302/5341/7344/24347/25
350/7351/3366/22
why [48] 242/16247/5249/10275/22
281/18284/4285/16293/24306/13343/19
370/19380/19391/25394/22403/15408/3
409/18409/21411/5411/6411/6411/8
411/19411/19411/19411/20411/23
413/20414/9415/9415/10415/19416/9
416/13418/14428/14450/10451/4451/18
454/23454/24455/14456/9458/5459/17
464/15465/23474/9
wide [1] 288/11
wife [1] 406/4
wild [1] 273/16
will [112] 1/3235/12238/19242/11
242/25244/2244/5244/11246/25248/14
248/16248/19250/12250/13252/1252/4
252/6252/9252/14252/15252/16252/17
252/18252/22252/22254/3254/7255/21
256/5256/6256/16256/20256/24257/2
257/13259/15260/9260/13260/22261/10
261/19261/23262/2262/9262/21262/24
264/14264/15265/14265/17266/12
266/24267/13269/2270/2270/8270/18
270/21271/1272/3272/20273/2273/9
273/15276/12277/3277/12279/17284/16
284/21289/10291/2291/12295/18297/19
300/18303/3306/11310/10312/10321/10
326/23336/21354/5354/7359/22362/14
364/5364/20377/8377/11377/12377/15
377/17377/22377/25378/1378/5378/11
398/4400/9402/4427/15428/19435/2
437/15445/8453/11459/1469/4475/13
475/19
willed [1] 278/20
willing [9] 248/18281/14290/20438/1
448/1468/13470/7470/12473/21
Willis [6] 271/6334/5334/7334/10
334/16391/2
Wilson [5] 322/1326/23336/21345/6
363/11
win [1] 457/19
wind [1] 248/23
winded [1] 416/16
window [1] 281/21
wire [3] 236/11271/19289/11
wire fraud [1] 236/11
wired [2] 438/13440/21
wiring [3] 438/17438/20438/20
withdraw [1] 461/3
withheld [10] 270/16271/22309/20
315/11332/23343/20349/7352/17352/21
352/25
withhold [2] 306/23307/6
withholdings [21] 272/8285/4285/4
285/5285/5285/6294/16312/16315/24
316/3324/15327/14328/6329/10330/19
333/16333/20349/4373/14394/13396/23
within [3] 272/5276/23354/8
without [11] 245/11251/1268/17319/18
320/22415/4449/12450/3454/4469/7
470/24
witness [43] 233/2254/14254/24254/25
256/2257/16257/19257/21257/23257/25
258/1258/2258/4264/12264/13264/15
271/24287/8291/4291/9374/3378/25
393/5397/14397/20397/25412/2412/12
415/2415/19417/19428/10431/7431/11
431/13431/24443/21443/24446/7451/25
452/1458/3458/5
witness's [6] 257/15258/6258/8258/11
263/13446/6
witnesses [10] 248/7248/11248/13
252/15257/14257/14265/19265/21
265/22444/20
won't [3] 375/24448/24466/23
word [6] 279/11382/15411/12427/20
474/2474/3
worded [1] 245/23
words [5] 276/9282/5455/18470/8
474/14
work [22] 242/20246/13246/14249/10
291/20291/21294/4306/24308/20381/16
390/19392/2392/22395/3404/17434/8
436/7438/9442/9442/12444/6469/3
worked [10] 234/8271/8278/3291/25
424/12433/4435/16435/19435/21437/2
worker [1] 281/17
workers [8] 279/17279/19290/1290/3
290/3290/4290/6290/10
working [12] 234/20278/21290/6
385/10392/9392/16404/21405/2407/7
434/17436/10436/11
works [2] 250/15434/13
world [3] 286/2428/19442/20
worried [3] 242/20414/2414/4
worry [3] 246/22263/6265/3
would [164] 234/8238/6239/1239/9
239/16239/20241/10241/14246/19247/3
247/22248/15253/3253/13254/25268/16
268/17268/22268/23268/25270/9270/21
271/12275/15275/16279/1279/3285/1
286/4290/20292/24293/17294/13294/24
294/25295/17298/2299/22300/1300/2
301/1303/23305/25306/2306/13306/17
306/22307/5307/19307/25307/25309/2
309/6309/9309/13309/16309/19309/21
309/25310/19311/11312/17312/19313/8
314/14314/16318/6319/23325/21332/5
333/5335/20336/8337/25338/22339/12
339/18340/12342/3343/21343/25344/4
345/3347/23350/17352/2353/10354/18
355/4356/25357/3358/20360/6364/23
365/2366/15368/22368/22368/25370/24
372/4374/12374/20380/2382/24383/6
383/7384/12387/7387/7388/22392/7
393/12393/15393/19395/16395/22396/7
401/23402/16403/2404/24405/12411/11
411/14412/17412/17413/21415/3415/4
416/9427/18427/19430/22434/21437/15
449/8452/20455/23456/7458/16459/5
459/7459/8459/23460/6460/23461/4
461/5461/25463/10463/11463/14463/14
463/15470/10470/11470/17470/18
470/21470/25471/1473/8473/20
wouldn't [2] 275/16440/12
write [1] 245/23
writing [4] 263/14281/23284/4462/4
wrong [10] 298/25375/13382/21382/22
382/24382/24396/16423/23445/23
451/18
wrote [2] 263/23264/5
X
X'd [2] 358/17368/14
Y
y'all [30] 239/12245/13245/14246/5
246/16247/11249/4253/15255/17260/25
267/7290/9298/13312/11318/22319/5
321/5374/1376/14378/22400/23401/12
403/19406/12406/14407/3411/4444/6
445/5462/20
yacht [2] 268/12274/3
yeah [24] 245/16280/24385/5386/25
398/18405/17406/9406/19408/12417/15
420/19425/17426/2430/5431/16431/17
434/11434/18439/22450/18452/24456/2
464/23469/12
year [20] 270/4272/11277/24278/15
279/6285/6291/24301/20321/25324/5
344/23350/3350/5355/11395/15405/16
419/23421/25428/20434/18
year's [1] 286/9
yearly [4] 326/6326/10328/3329/18
years [32] 278/14283/11285/17285/17
285/20291/25292/17311/9311/19356/11
379/14379/18379/23379/25379/25399/1
399/8401/5401/7402/1402/2402/2
402/12410/11421/24424/12424/13
432/16433/4434/11437/6440/10
yellow [5] 448/4448/5458/3462/22
463/10
yes [521]
yeses [1] 373/20
yesterday [7] 237/4239/15241/7251/9
259/23319/9320/3
yet [3] 308/12350/14417/10
York [1] 404/2
you [1301]
you'd [2] 244/20454/21
you'll [31] 240/24242/9258/17261/25
262/1262/1262/4262/8262/10269/5
269/7269/10270/21271/11271/24272/13
273/6274/9275/21281/16281/25287/15
287/15288/12288/12290/13336/19
356/14360/14378/4474/2
you're [98] 236/16241/22241/23261/4
261/20263/9263/14264/12264/25264/25
269/23270/13271/2271/9271/15272/16
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 280 of 281
Y
you're... [82] 274/17274/18275/14276/8
277/1277/4279/13280/13280/20281/2
281/4281/21282/13282/18283/5283/5
284/1284/3284/7284/14285/8285/11
285/16286/21287/2287/3287/8287/24
287/25289/3289/19289/19290/17319/19
320/3320/9320/22325/9354/10359/6
359/7359/9378/14384/4387/10387/14
397/17401/8402/6409/1416/2416/20
421/25422/14422/17422/21425/23
425/25426/14449/17450/5450/16452/5
452/7452/12452/20457/20457/21457/22
460/2462/10463/18465/4465/10466/16
466/22467/11467/12468/10469/16
471/21475/17
you've [38] 243/9256/20260/7264/18
275/2275/2276/20281/5289/18296/25
306/21318/15319/17320/22328/13
355/12376/16376/18385/11387/4404/1
408/20416/21418/4421/12424/1439/11
441/23442/1444/20444/22454/20458/24
464/6465/21469/15471/21472/7
you-all [21] 235/13238/20249/12250/20
250/22263/2298/10318/18350/11354/6
376/9411/23444/9445/2445/16446/5
446/25462/1466/4466/14475/13
young [1] 380/3
younger [4] 402/2402/8402/8402/12
your [258]
your Honor [87] 234/15239/13240/18
241/1241/12242/5242/12243/1244/4
246/9247/10247/12248/5249/25267/15
291/5295/24296/5297/25298/8298/12
298/14310/17310/22312/6312/14313/6
318/10321/8344/20345/1350/10350/17
350/24353/10354/17356/25357/3357/7
360/6360/8362/8364/14365/8366/15
366/17372/4373/17374/2374/11374/14
374/19378/18393/2393/6393/22394/4
397/16397/21411/21416/5417/18418/1
422/3430/25431/20446/21447/1449/7
450/23451/15452/25453/10454/1454/16
455/1457/15458/11458/23459/1462/5
462/15466/2466/9472/13473/7475/12
yours [1] 442/1
yourself [7] 257/17263/7383/3442/7
452/7454/8457/20
Z
zero [2] 284/23284/25
zoom [26] 303/4323/3327/2336/21
337/22340/6341/18343/4345/11346/3
346/19350/25351/6352/2352/4355/9
357/14358/5358/23361/9361/10367/13
368/6368/7368/19441/11
zoomed [1] 316/25
Case 1:22-cr-00171-MLB-RDC Document 265 Filed 02/10/26 Page 281 of 281File and source
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