Court filing
TRANSCRIPT of Proceedings (Jury Trial) as to Carl Delano Torjagbo held on 07/23/2025,… — USA v. Torjagbo (Dkt. 266)
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. 266 · 2026-02-10 · Docket on CourtListener
Summary
Volume 3 of the transcript of jury trial proceedings for July 23, 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. 266, filed February 10, 2026, and runs to 324 pages. Before the jury enters, the court states that the defendant did not invoke a right to silence by declining to answer particular questions. The government then presses its unopposed motion in limine to exclude evidence blaming the victims, while defense counsel answers that his questions go to materiality and to what a lender relied on. The court rules that counsel may cross-examine on materiality but may not argue that the victims were at fault; the argument concerns a document said to list 493 names.
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
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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 3
CARL DELANO TORJAGBO
)
also known as
)
KARL LUCIUS DELANO,
)
)
Defendant.
)
_______________________________)
--------------------------------------------------------------
BEFORE THE HONORABLE MICHAEL L. BROWN
TRANSCRIPT OF PROCEEDINGS
JULY 23, 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
NORTHERN DISTRICT OF GEORGIA
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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UNITED STATES DISTRICT COURT
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INDEX TO EXAMINATIONS
WITNESS PAGE
ROSEMARIE DRAKE
Direct Examination By Mr. Evert
496
Cross-Examination By Mr. Finlayson
522
Redirect Examination By Mr. Evert
529
Recross-Examination By Mr. Finlayson
531
Further Direct Examination By Mr. Evert
532
Further Cross-Examination By Mr. Finlayson
536
KELLI CARPENTER
Direct Examination By Mr. Evert
539
Cross-Examination By Mr. Evert
596
Redirect Examination By Mr. Evert
609
JAMES DAVIS
Direct Examination By Ms. Connors
614
Cross-Examination By Mr. Finlayson
654
JOHN HORNER
Direct Examination By Mr. Evert
663
Cross-Examination By Mr. Finlayson
666
Redirect Examination By Mr. Evert
669
SALVATORE HAZEL
Direct Examination By Ms. Connors
671
Cross-Examination By Mr. Finlayson
730
Redirect Examination By Ms. Connors
741
Recross-Examination By Mr. Finlayson
744
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
_ _ _
P R O C E E D I N G S
(Atlanta, Fulton County, Georgia, July 23, 2025, in open
court.)
THE COURT: All right. Everybody's here, ready to
go. I heard from the Court security officer that the young
woman who starts her new job on Monday, the nurse, is worried,
okay, about her ability to start the job.
Nothing we need to decide right now. You-all take
all the time that you want to try this case the way you want
to. But just keep in mind that that may be something that we
have to talk about sometime tomorrow or whenever.
Okay?
If you want to keep her and inconvenience her, I
don't mean that like it would be -- it's her job to be here
right now. So if we want to keep her, we keep her. If we
don't, we decide what to do, but I'll leave that to you-all.
Just be thinking about what your position might be.
Okay?
I also did some research overnight. I don't think
that -- I think the government can include the parts with
unanswered questions. I think that he did not invoke, and I
don't think there's a partial invocation. We can talk more
about it at a break.
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But I think that he is told that he has the right not
to speak, but that if he does, it can be used against him. He
continues to talk. And I don't think that a statement of I
don't want to answer that particular question but I'll answer
these other ones is an invocation of a right such that there's
some violation there.
Okay?
We left that sort of up in the air a little bit
yesterday. I know the government might have already decided
what they wanted to do, but I wanted to mention that at my
first opportunity.
Okay?
All right. Let's bring them in.
COURTROOM SECURITY OFFICER: Yes, sir.
THE COURT: Have you got a witness?
MS. CONNORS: Yes.
THE COURT: Okay. You don't have to call them until
they get in, but I just wanted to make sure that they were
ready and close.
MS. CONNORS: Your Honor, I think we did have one
quick issue.
THE COURT: Oh, hold on, sir.
Yes.
MR. EVERT: So, Your Honor, we had filed a
motion in limine to exclude blaming the victim evidence and
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suggestions that the victims in this case were somehow at
fault. That -- I understood from the pretrial conference that
that was unopposed.
THE COURT: I did, too. Wasn't it?
MR. FINLAYSON: It was.
THE COURT: Okay.
MR. EVERT: And so I thought that was a pretty clear
line. And I think the opening statement came dangerously
close to that line, if not already crossing it with -- with
the argument that, look, I gave these documents to the bank, I
gave these documents to the IRS, they gave me the money.
I mean, I think that's -- that's shifting the blame
for the fact that the money was given to him from the
defendant to the victims, so I -- you know, I think what
happened in the opening was probably improper, but I just want
to be really sure that we're not going to get anywhere close
to that line going forward.
THE COURT: Why would you think that? I think he's
got a theory of it was open and notorious.
MR. EVERT: Right. But I don't think that --
THE COURT: And that's his theme.
MR. EVERT: Right.
THE COURT: I'm saying I wouldn't have too much
confidence -- if you think open and notorious is something
like that, which I think it touches on that notion, then I
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think it is naive to think he's not going to get into that.
MR. EVERT: Yes. So I guess I would say I believe
that line has been crossed and I believe that it has been
crossed improperly. And I just would ask that he not be able
to continue down that road of essentially shifting the blame
for his obvious fraud from himself to -- to the victims of his
fraud.
MR. FINLAYSON: And I understand their argument. I
understand the point. But it's not shifting blame, it goes to
the issue of materiality, because the government has
alleged --
THE COURT: You can argue it materiality, right?
MR. FINLAYSON: Correct.
THE COURT: You need to tie it to what you're saying.
You need to tie it to that idea.
Okay?
MR. FINLAYSON: Okay.
THE COURT: You can't just say it because it goes to
something and then not argue it in the light of that. That's
like saying we're putting some 404(b) in there to show it's --
that it's not an accident. And then you just put it in there
and you just talk about that thing and you don't say how it
can be used, right? It's just --
MR. FINLAYSON: And I will -- I will tie that
together. I think it's an argument issue. But in terms of
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examining a witness, I do think the government is being -- is
allowed to present this document that they submit is
fraudulent and they said that it had these 493 names and these
names are fake. And this is a material -- this was a
material -- I assume --
I don't know what the witness is going to say on
direct. But I assume the witness is going to say this was
material to our decision to loan the money. And if we had
known that these were all fake, then we wouldn't have loaned
the money, which makes it a material --
THE COURT: Is the guy going to say that?
MR. EVERT: I think that's essentially part of what
she's going to say.
THE COURT: All right.
MR. EVERT: And I think my concern is --
THE COURT: Well, hold on. Hold on. Let him finish.
MR. EVERT: Okay.
MR. FINLAYSON: And I just think that once they get
to lay that out there, I get to cross-examine on the
credibility and the believability of how material it was. And
that's -- I'm not trying to shift the blame.
But I think I'm entitled to go into what was
presented to the bank, what they actually relied upon, and
whether or not it was material.
MR. EVERT: I think that's essentially saying we're
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going to say -- you know, if she testifies, you know, we got
this list, the fact that this list was provided was -- we
wouldn't have given -- if we had known that the information in
this list was false, we would not have issued the loan. And
then if he's going to say, well, look at all the information
in this list, like, I mean, I think the --
THE COURT: Like what? Follow that out. Like she's
going to say --
MR. EVERT: Yeah.
THE COURT: And then he's going to say if they would
have just looked, they would have seen John Snow.
MR. EVERT: Right. If they would have just looked,
they would have seen Oliver Twist. If they had just looked,
they would have seen Keanu Reeves. And so I --
THE COURT: Are you going to say that --
MR. FINLAYSON: I'm going to say --
THE COURT: Hold on. Hold on. You can't interrupt
me.
MR. FINLAYSON: I'm sorry.
THE COURT: -- shame on them for not looking?
Because if they would, they would have seen John Snow,
Oliver Twist and Charlie Brown, so it can't really be
material, because they never look at it.
MR. FINLAYSON: I think for argument, for closing, I
think it is that there was nothing material -- it was not a
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material falsehood. And that because -- and we know it wasn't
material, because they -- they had the documents, they -- they
could and should have relied upon it. But -- so it doesn't --
it wasn't like he misled them. It was all right there. So I
don't -- I'm not trying to --
THE COURT: What do you mean, it wasn't like he
misled them?
He said John Snow worked for them. He said
Charlie Brown worked for them. You're just saying that it was
just such a stupid lie, that they would have caught it.
Amongst the 493, they should seen the seven obviously
fraudulent lies and shame on them for not. Right? How can
you say it's not a lie.
Did John Snow work for him?
MR. FINLAYSON: Someone by that name could have
worked there.
THE COURT: Okay. Well, that's fine. You can make
that argument.
MR. FINLAYSON: And I think -- and there may be --
THE COURT: It would be a funny cast of characters.
MR. FINLAYSON: Yes, it would. But I still think if
they're relying -- if they're putting in the document, which
they've already put in, and they're going to present it to the
woman -- to the woman from the bank, and she's going to say,
you know, we relied on this and this is, in part, why we made
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UNITED STATES DISTRICT COURT
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this loan and it was materially false, I think I get to -- I
get to ask about, you know, what was false about it.
And, you know, if you had seen it, you know, I mean,
you saw it. I don't think it's an improper cross. I'm not
trying to blame them. I just think I'm entitled to go into
what they had, what they considered and how it was material to
their loan process.
THE COURT: Yes. I think you can do all of that.
What you cannot do is blame the victim. You've already agreed
that you can't say that the victim is so -- it's their fault,
shame on them, it's their fault.
I mean, if you just look at the document itself I
acknowledge that the lender will confirm the eligible loan
amount using the required documents submitted. I understand
and acknowledge and agree that the lender can share my tax
information.
I mean, I don't know that this is really much of an
issue. Isn't he told in the -- this is from the application,
isn't he acknowledging that the stuff he gives is material?
Isn't he?
MR. FINLAYSON: I don't know that that meets the
element for proof in a trial. I don't know that --
THE COURT: I acknowledge that the lender will
confirm the eligible loan amount using the required documents
submitted.
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MR. FINLAYSON: I guess -- I haven't really thought
that through before. I don't know that -- I mean, that's --
that seems like that's an element they have to prove and maybe
that's part of their proof. I guess maybe there's a question
of -- I just haven't thought it through like that. It almost
seems like -- it seems that that almost removes the element
from the jury consideration.
THE COURT: No, of course not. Of course not. It's
an acknowledgment by him at the time of what he is told they
will consider. You can still argue it's not material. But, I
mean, I think in the light of that, is there really an
argument -- I'd like to know what your argument of blaming --
of saying it's not material in the light of that.
MR. FINLAYSON: I think it really depends on what the
witness says. I mean, just because I think there is that
document that the defendant allegedly signed, I don't think
that changes the -- I assume the bank officer's testimony is
going to be that we relied on these documents. And I don't
think that removes them of that piece of the case. I think
they still have to prove that, so I don't -- I don't think
that ends the question.
THE COURT: He asserts it in good faith that the
funds will be used to retain workers and maintain payroll and
some other things. And if it's used for unauthorized
purposes, the government will hold him legally liable for such
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charges of fraud.
At any rate, I think we all agree where at least one
bright line is, which is that you cannot blame the victim for
falling for the fraud. You can attack materiality. But if
you're going to argue the point, you have to argue it as on
the grounds of materiality.
If there was 404(b) evidence coming in for something
like lack of mistake and the government -- and I let it in and
the government only argued -- or just kept hammering the fact
that your client did something wrong at another time and never
tied it to how the jury could use it, that would be improper.
If it's admitted for a purpose it has to be argued
for that purpose. If you're going to go to things about the
open and obvious nature of the misrepresentations that your
client allegedly made in order to challenge materiality,
that's the way you have to do it. I think that gives you what
you want.
I mean, do you disagree with what I'm saying as far
as the law?
MR. FINLAYSON: I don't. I think I get it. And I
think it's more of a -- I'll make sure that I argue it the
right way at closing. I do think -- I just want to make sure
that I can ask about the names. I can at least inquire about
well, this name was here and this name was here?
THE COURT: Yes.
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MR. FINLAYSON: Okay. And that's all I want to do.
THE COURT: Yes. I'm assuming what they're going to
say is there are 493 names here. We look for a bunch of
different names that is included in all of these things. We
don't go do background checks and, yes, maybe we don't do look
at each individual name. I scanned the list and most of them
just looked like names of people. I mean, I had no idea who
Monica Sweeten was. Y'all kept asking about her and now I
know who she is, she is a person. It's not like every one.
It's not like he got the list of the entire cast of the House
of Stark or something like that. I mean, at any rate, you-all
can argue it that way.
Mr. Evert, does that give you what you were looking
for at least some?
MR. EVERT: Yeah, I think at least some --
THE COURT: So at least I think we're all on the same
page. Whether there is abiding of it, at least in the spirit,
we'll have to see. But you can also ask for an instruction --
MR. EVERT: Okay.
THE COURT: -- in this regard. If you think that
there is a series of evidence that's come out one way, we can
instruct the jury as to things like that. I'm not telling you
that I think we're there yet. I'm looking at your
instructions now.
But I think we do have materiality as defined, I
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would assume. But, you know, you can consider whether to do
that. But he does get to make an argument that like -- I
suppose at some point, a lie is so dumb that no one could
possibly rely upon it and, therefore, it can't possibly be
material.
I don't think this is that type of case. I think in
this case, in the reality of it, I think the government was
pushing out as much money as they could and they were going to
go back and they were going to police people. And there
wasn't a lot of policing on the front end.
MR. EVERT: Right.
THE COURT: And that may be -- so that may be here,
that that's part of this. But certainly there could be some
things that are said in a different context that are so
outrageous, no one could possibly rely upon it. And so that
concept does exist in a fraud case.
MR. EVERT: Sure. But I think we're pretty far from
that.
THE COURT: I think so, too.
MR. EVERT: Yeah.
THE COURT: I think so, too.
And I think defense counsel recognizes that and
that's why he's agreed that's what the sort of playing field
is.
MR. EVERT: I understand.
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THE COURT: You will just have to police it either
with objections or with an instruction.
MR. EVERT: Okay. Understood.
THE COURT: And, by the way, this idea that you can't
object in a closing argument for both sides, I mean, so what
if you object during a closing argument. I mean, that's
always been like forbidden, people are like, oh, why would you
object.
But if somebody is saying something wrong in closing
arguments, what's wrong with objecting?
I've interrupted people in closing if they've done
something that I've said they can't do. This is supposed to
be a fair playing field. And so that's how you keep it fair.
So we have all of those -- you have all of those to
try to police the line that you think exists and that I think
he acknowledges exists and that both of you want to abide.
All right? Thank you.
MS. CONNORS: Your Honor, I apologize. I just wanted
to just point out one thing, just to front this, because I
know we're going to talk about jury instructions later.
But just since we were just talking about reliance
and victim relying on information, I just want to remind the
Court that the Eleventh Circuit pattern jury instruction on
wire fraud and bank fraud says a fact is material if it has
the capacity or natural tendency to influence a person's
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decision.
It doesn't matter whether the decision maker actually
relied on the statement or knew or should have known that the
statement was false. I only point that out because I just to
make sure that we're all --
THE COURT: I think that goes right to this issue.
I'm sorry, I didn't mean to cut you off. I think that goes
exactly to this issue.
MS. CONNORS: Yes, Your Honor. And that's why I just
wanted to point it out --
THE COURT: Yes.
MS. CONNORS: -- to make it clear. Because I know we
were talking about maybe there could be something so absurd
that somebody didn't rely upon it, but just that is not going
to be the standard ultimately.
THE COURT: You're right. When I say that, I'm
talking about something that we would all recognize as puffery
in a commercial context. That's what I'm talking about.
MS. CONNORS: Okay.
THE COURT: I'm not talking about anything like
John Snow worked for me. I suspect that they never looked at
that. I suspect that they skimmed through it and saw it and
they looked at the part where he said we have 493 employees,
and they saw that there were a bunch of names attached. I'll
bet that's what they did. And so I think that instruction is
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exactly what we want.
MS. CONNORS: I agree.
MR. FINLAYSON: No.
THE COURT: And I don't know how many times you want
to say it during your closing, but I'm not going to stop you
from saying it as many times as you want and I'm going to tell
them that before you start or something like that.
Okay?
MR. FINLAYSON: Understood.
THE COURT: All right. Do you want to say something?
MR. FINLAYSON: No, sir.
THE COURT: All right. Let's bring them in.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. Y'all can be seated.
Everybody okay?
Everybody abide the rules?
Sorry to have kept you waiting. We had some things
that we had to address this morning. Okay?
We were here until pretty late last night and then we
wanted to sort of circle back on a couple of things. Okay?
But I know you-all have got expectations for when
this will be done and we're being mindful of that. Okay?
And, sir, I wore my Falcons tie today, all right.
JUROR: Okay.
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THE COURT: I'm not trying to start beef. Y'all have
got a better team.
JUROR: A championship, too.
THE COURT: I hear you. At least he didn't say 28 to
3. I appreciate that.
All right. Government, go ahead and call your next
witness.
MR. EVERT: The government would call
Rosemarie Drake.
THE COURT: I was thinking about you last night. I
got home and my kids were watching a show called
Abbot Elementary. And it's got this great scene where Hurts
and a couple of other guys appear on it and it was pretty
funny.
- - -
ROSEMARIE DRAKE,
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: Rosemarie R-O-S-E-M-A-R-I-E, middle
initial A, Drake, D-R-A-K-E.
COURTROOM DEPUTY: Thank you. You may be seated.
DIRECT EXAMINATION
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BY MR. EVERT:
Q.
Good morning, Ms. Drake.
A.
Good morning.
Q.
Where do you work?
A.
The U.S. Small Business Administration.
Q.
And what is the U.S. Small Business Administration?
A.
It's a federal agency used to support small businesses to
aid and access to capital, contracting assistance as well as
counseling and mentoring.
Q.
And where are the small businesses that the -- and if I
refer to the Small Business Administration as the SBA, is
that --
A.
That is correct. That's the acronym, that's correct.
Q.
So where are the small businesses that the SBA helps
located?
A.
In the United States and its territories.
Q.
In general, what types of businesses are considered small
businesses?
A.
Small businesses are usually less than 500 employees.
Also the size standard based on their revenue would be based
on the NAICS Code.
Q.
And what is your title at the SBA?
A.
My current title is the deputy district director for the
State of Georgia.
Q.
And what are your duties as the deputy district director
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for the State of Georgia?
A.
Currently, I support businesses in Georgia, whether
they're in business or not, entrepreneurs looking to get in
business, for technical assistance, helping them get resources
for access to capital. I also do compliance for our
procurement program, the 8A program, as well as support the
small business development centers, which is our resource
partners.
Q.
And how long have you been with the SBA?
A.
I started in 2013, with a short break, and I've been here
since then.
Q.
And what was your role when you first started at the SBA?
A.
I was a lender relations specialist in the Philadelphia
district office.
Q.
And you mentioned that you briefly left the SBA. When was
that?
A.
I did. I left in 2018.
Q.
And what -- where were you when you left?
A.
I went to Bank of America back to banking.
Q.
And when did you return to the SBA?
A.
I returned in 2019.
Q.
And when you first rejoined the SBA, what was your
position?
A.
I came back as the 7A policy chief over the loan program
and policy.
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Q.
And is the 7A program, is that focused on loans for small
businesses?
A.
It does.
Q.
Where are the small businesses that the 7A program helps
located?
A.
In the United States and its territories.
Q.
Does the 7A program provide loans to non-United States
businesses?
A.
No.
Q.
How long have you been the 7A policy chief -- or how long
were you in the 7A policy chief position?
A.
From 2019 until January 2022.
Q.
And what were your duties as the 7A policy chief?
A.
Assisting with writing the policy for the 7A loan program
as well as training lenders. Also supporting the application
for the 7A loan program, and of course the Paycheck Protection
Loan Program, which is a subprogram of the 7A loan program.
Q.
And did you remain in that role until January '22, and
then transition into -- back into your current role?
A.
Yes.
Q.
So you mentioned the Paycheck Protection Program or PPP,
can you briefly describe that?
A.
It was a temporary loan program during the pandemic to
support American businesses and keep American employees
employed during the pandemic.
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Q.
And what was the SBA's role with respect to the PPP
program?
A.
Along with the U.S. Treasury, we were implementing the
program for the policies and supporting lenders with getting
the monies rolled out to the businesses.
Q.
And did you have personal involvement with the PPP?
A.
Yes.
Q.
What was your role with respect to the PPP program?
A.
Along with the team, supporting the team with the rollout
of the application, the interim final rules as well as the
policies related to that and supporting the lenders throughout
the program.
Q.
And you mentioned on creating -- you mentioned working on
creating application. Can you explain what that -- what that
entailed?
A.
Yes. Our normal application, the 1919, which was the 7A
loan application was not used.
THE COURT: Could you just talk a little slower?
THE WITNESS: Oh okay. I'm sorry.
THE COURT: You have great volume, just a little bit
slower.
THE WITNESS: Okay. All right.
THE COURT: Thank you.
THE WITNESS: So, yes. The 7A loan application was
not used. We modified the loan application so that it would
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be more efficient and get the loan funds out quicker for the
loans so we were able to put together a one- or two-page
application to allow for quick expedition of getting the loans
out.
BY MR. EVERT:
Q.
And in terms of developing the policies and procedures for
the -- for the PPP, what -- what were the goals of the PPP
program?
A.
To keep American workers employed and paid.
Q.
And was speed also a part of the goal?
A.
Yes.
Q.
Now, you mentioned keeping Americans workers employed and
paid.
Was a goal of the program to help keep workers in
Ghana employed and paid?
A.
No.
Q.
And why was the focus on American workers specifically?
A.
Because there was a mandate to shut down the U.S. during
the pandemic, so that there was less of being out in the
public. We wanted to make sure that they were -- the
employee -- the employees were paid and stayed hired.
Q.
And is the SBA an international organization or is it an
American organization, can -- is it -- is it an agency of the
U.S. Government?
A.
It is a domestic organization -- agency under the federal
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government.
Q.
The U.S. federal government?
A.
The U.S. federal government.
Q.
And were foreign businesses eligible for PPP loans?
A.
No.
Q.
Would a mining company with all of its employees in Ghana
have been eligible for a PPP loan?
A.
No.
Q.
So you mentioned that speed was an issue.
Why was processing these loans quickly important as
part of the PPP program?
A.
One, it was a mandate by the United States president.
And secondly, it was to get the funds directly to the
businesses that were in need of getting the funds.
Q.
And when was the PPP program originally created?
A.
On March 2020.
Q.
And were there multiple opportunities to get PPP loans?
A.
Yes.
Q.
When was the second round of the PPP program announced?
A.
The second round was December of 2020.
Q.
And specifically was the -- was that part of the Economic
Aid Act passed by Congress and signed into law in -- on
December 27th of 2020?
A.
Yes.
Q.
During what time period could businesses apply for a
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PPP loan during that second round?
A.
It was through March of 2021.
Q.
And starting in January?
A.
January -- January 13th. There was a short period that
allowed for smaller businesses to apply for the loan, just a
two-day period, a two-day period.
Q.
So businesses were eligible to apply starting in January
of 2021?
A.
Yes.
Q.
Was there a high demand for PPP loans?
A.
Yes.
Q.
Were there more applications for PPP loans than businesses
that got PPP loans?
A.
Yes.
Q.
If a business wanted a PPP loan, who would it apply to for
the loan?
A.
It would apply to lenders that would approve through the
SBA.
Q.
And so what was the lender's role with -- and just to be
clear, was the SBA the lender or were there different lenders?
A.
SBA was not a direct lender.
Q.
So would the lenders be institutions like banks?
A.
Yes.
Q.
What were -- what was the lender's role with respect to a
given PPP loan?
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A.
To originate, underwrite, service, close and liquidate, if
necessary.
Q.
And could you just explain a little bit what those --
those terms mean?
A.
Sure. They were responsible for completing the
application, the borrower/applicant would complete the
application, submit it to the lender.
The lender then was required to take the borrower's
applicant -- I keep saying applicant and borrower because it's
an applicant before the loan is done -- the information
provided on the application, the lender then would take that
information, make sure that it was in compliance with the
rules set -- set at the time. And then they would close the
loan, fund the loan and then service the loan.
Q.
And so if a business got a PPP loan, who would the money
for that loan be coming from?
A.
The lender.
Q.
And what type of verification were the lenders required to
do with respect to the information in a given loan
application?
A.
The lenders were allowed to use the borrower's
certification that the information was true and correct.
Q.
And was that different from the process -- was the process
for verification of a PPP loan different from the process of
getting a normal loan?
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A.
Yes.
Q.
Can you explain how this was different?
A.
Sure. During the normal process of obtaining an SBA loan,
the lender would have to collect all the information,
underwrite the loan. And at the time of underwriting, verify
that all the information was correct and get the tax
transcripts prior to submitting to SBA for a loan number prior
to closing and disbursing the funds to the borrower.
Q.
And so was -- was any of that required with respect to a
PPP loan?
A.
It was not.
Q.
Why were there these different verification requirements
between a regular loan and a PPP loan?
A.
Because this was during the emergency of a -- a national
emergency that the U.S. president, along with Congress, said
that those things were exempt during this process. And it was
a 100 percent guaranteed loan, which allowed for full
forgiveness if it was closed in compliance and the funds were
disbursed and used in accordance with the guidelines.
Q.
And if there was false information in the loan
application, was that the lender's fault or was that the
applicant's fault?
A.
It would be the applicant's.
Q.
Could an applicant choose which lender they wanted to get
a loan from?
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A.
Yes.
Q.
What was the SBA's role with respect to a given PPP loan?
A.
SBA's role was to allow for the lenders to get a
100 percent guarantee if the loan was closed and serviced in
accordance with the guidelines and so they backed the loan.
Q.
And by backing the loan, does that just mean that the
lender would give the amount of the loan to the bank on the
back end, if the requirements had been met?
A.
In the event of default.
Q.
Okay. Were there requirements -- were all businesses
eligible for PPP loans?
A.
No.
Q.
Were there -- were there requirements that a business had
to meet to be eligible for a PPP loan?
A.
Yes.
Q.
If you wouldn't mind flipping in your binder to what's
been premarked for identification as Government's Exhibit 150,
please.
A.
There are three binders.
Q.
Okay.
A.
Five, actually.
Q.
Oh, it's in the first binder, binder number one.
A.
Binder number one. Did you say which page again?
Q.
It's the last page of the first binder or the last
document in the first binder. Document Number 150. Is that
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it?
A.
No.
Q.
Oh, no. Okay.
THE COURT: Just come on up and find it for her.
BY MR. EVERT:
Q.
I'll find it. I'll help you.
A.
This is binder number one. This is binder number two.
Q.
Let's see. Okay.
MS. CONNORS: Your Honor --
BY MR. EVERT:
Q.
And we also -- well -- so do you recognize this document?
A.
Yes.
Q.
What is it?
A.
It's the Paycheck Protection Program borrower obligation.
Q.
And who created this form?
A.
The SBA in consultation with the IRS, U.S. Department of
Treasury.
Q.
And are you familiar with this form?
A.
Yes.
Q.
Were you involved with its creation?
A.
Yes.
Q.
How were you involved?
A.
My team put together the application and I was the one
that submitted it to OPM.
MR. EVERT: I would move to admit Government's
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Exhibit 150.
MR. FINLAYSON: No objection.
THE COURT: Okay. 150 is admitted. And as we talked
about yesterday, anything admitted can be published to the
jury.
MR. EVERT: Could we please publish Government's
Exhibit 150.
BY MR. EVERT:
Q.
So -- and this is a blank form?
A.
It is not.
Q.
Oh, so nobody has filled this -- this --
A.
Oh, correct.
Q.
Yeah.
A.
Yes.
Q.
Did every applicant for a PPP loan have to fill out the
information in this form, regardless of what bank they were
getting their loan from?
A.
Yes.
Q.
And why was that required?
A.
All the information required determined if the applicant
was eligible.
Q.
And was it important to -- for purposes of the PPP loan --
that the information -- that all the information provided in
this loan be included?
A.
It's required.
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Q.
And was it important that the information provided in this
form be accurate?
A.
Yes.
Q.
Were there any requirements on when a business had to have
been in operation in order to be eligible to get a PPP loan?
A.
Yes.
Q.
When did the business have to have been in operation by?
A.
On or before February the 15th, 2020.
Q.
And why did that restriction exist?
A.
It existed because the business had to be in operation in
order to qualify for a PPP loan.
Q.
And was the purpose of the PPP program, was that geared
towards helping existing businesses --
A.
Yes.
Q.
-- with -- that were affected by the COVID 19 pandemic?
A.
Yes.
Q.
On Page 2, the bottom half of the page, there are --
there's a series of ten statements, starting right here
(indicating).
MR. EVERT: If we could just blow that up.
BY MR. EVERT:
Q.
Can you please explain what these -- without reading them
all, what -- what are these statements?
A.
These statements are making sure that the applicant was in
business prior to February the 15th, 2020.
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But also that there was a need to have a funding to
support the business that was in operation and that the funds
would be used for the intended purpose of the program and that
all the information provided within the application was true
and correct.
Q.
And the line right here that begins the authorized
representative of the applicant must certify -- there's a line
that says the authorized representative of the applicant must
certify in good faith to all of the below by initialing next
to each one.
Would you please read the first statement that needed
to be initialed?
A.
Are we talking about the applicant was in operation?
Q.
Yes.
A.
Okay. The application -- the applicant was in operation
on February the 15th, 2020, and has not permanently closed,
and was either an eligible self-employed individual,
independent contractor, or sole proprietorship with no
employees, or had employees for whom it paid salaries and
payroll taxes or paid independent contractors, as reported on
Forms 1099-MISC.
Q.
Did every application -- applicant for a PPP loan have to
certify that that statement was true?
A.
Yes.
Q.
And what did it mean to be in operation?
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A.
It meant that the business had generated revenues.
Q.
If a business was operating in Ghana but not operating in
the United States, would it have been correct to say that it
was in operation for purposes of this form?
A.
No.
Q.
If a business did not provide documentation showing that
it was in operation as of February 15th, 2020, could it have
gotten a PPP loan?
A.
No.
Q.
Can you please read the second certification on Page 2.
A.
Current economic uncertainty makes this loan request
necessary to support the ongoing operations of the applicant.
Q.
And why was this certification included?
A.
We wanted to make sure that the applicant was currently in
operation and they did not have liquidity to support the
ongoing operations of the business.
Q.
If a company did not have any operations, could the loan
have possibly been necessary to support the ongoing operations
of the business?
A.
No.
Q.
If a company was registered in the United States but did
not have any U.S. operations, would it have been eligible for
a PPP loan?
A.
No.
Q.
Were there any restrictions on the number of employees
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that a business could have?
A.
Yes.
Q.
In general, how many -- what was that cap?
A.
In general, it's 500 employees.
Q.
And why did that restriction exist?
A.
Because that's a part of the size standard to determine
small businesses.
A.
And turning back to Page 1, if we could look at the top
right-hand corner. It says, Applicant including affiliates --
it's the second box on the right down here.
It says, Applicant including affiliates, if
applicable, meets size standard. And then there are three
boxes to check.
A.
Yes.
Q.
Is this -- is this box geared towards making sure that the
business meets that requirement?
A.
That is correct.
Q.
Were there any limits on the amount of money that an
applicant could get a PPP loan for?
A.
Yes.
Q.
What were those limits?
A.
For the first round, it was $10 million. For the second
round, it would have been $2 million.
Q.
And when you say the first round and second round, you
mean if you were getting your first loan, you could get
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$10 million -- up to $10 million?
A.
Up to $10 million.
Q.
And then if you were applying for a second loan, you could
get up to $2 million; is that correct?
A.
Yes.
Q.
So how was the amount of money for a PPP loan calculated?
A.
Based on the average payroll amount.
MR. EVERT: And if we could zoom back out and zoom
into this middle section here.
BY MR. EVERT:
Q.
And specifically, how did the average monthly payroll
factor into the amount of the loan?
A.
It was based on the average monthly payroll times two and
a half.
Q.
And were there any restrictions on where the employees had
to reside for purposes of calculating the average monthly
payroll?
A.
Yes. The employees had to reside -- their principal place
of residence had to reside in the United States.
Q.
And why did that restriction exist?
A.
Because the PPP loan was geared towards American workers.
Q.
On Page 1, Item Number 7, it says, Is the United States
the principal place of residence for all employees included in
the applicant's payroll calculation above? Why did the form
include this?
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A.
Because that's a part of the eligibility.
Q.
And if the answer to that question had been no, could the
loan have been approved?
A.
It would not have been eligible.
Q.
And how was it determined whether the United States was an
employee's principal place of residence?
A.
It's based on the IRS determination of place of residence.
Q.
And if a business had employees in foreign countries,
could payments to those employees be counted for purposes of
calculating the amount of the PPP loan that the business could
receive?
A.
No.
Q.
Was it enough that a person was a U.S. citizen for that
person -- if -- if that person lived in another country, could
a U.S. citizen who lived in -- who resided in other countries
payroll be counted in terms of calculating the amount of the
loan?
A.
Would you repeat the question?
Q.
Yes. Sorry. That was terrible. Sorry.
All right. If a person was a U.S. citizen but they
resided in another country, could their employer count the
money paid to that employee when calculating the average
monthly payroll for purposes of calculating the size of the
PPP loan they could get?
A.
No.
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Q.
And why, why not?
A.
Because the purpose of the PPP loan was to keep American
workers paid. And the determination for the number of
employees was based on a size standard, not to calculate the
loan amount.
Q.
And what about if an American expat who lived and worked
in Ghana but still had a house in the United States, would
that person -- would you be allowed -- would a business be
allowed to count that person's pay in calculating their
average monthly payroll?
A.
They would not if they did not meet the IRS standard for
principal place of residence.
Q.
And if a business used independent contractors, could
payments to those contractors be included in the business's
monthly payroll?
A.
No. Independent contractors were eligible to apply
separately.
Q.
And what about employees paid in cash under the table,
could they count towards monthly payroll?
A.
No.
Q.
If a company was registered in the United States but
operating solely in another country, would that company be
eligible for a PPP loan?
A.
No.
Q.
Why not?
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A.
Because it was for U.S. businesses.
Q.
If a company's owner lived in the United States but the
company solely operated in another country, would that change
the answer?
A.
No.
Q.
Were there any restrictions on how much an employee could
make in order for the payments to that employee to count
towards the monthly payroll calculation?
A.
Yes.
Q.
What was that limit?
A.
$100,000.
Q.
So say an employee made $250,000 a year, how much would
that employee -- and -- how much would that employee's pay
count for when calculating the employer's average monthly
payroll?
A.
Up to $100,000.
Q.
So say employee X makes -- say a company has one employee,
employee X, employee X makes $250,000.
What amount can they say their average monthly
payroll is?
A.
Based on $100,000.
Q.
Got it. So even if an employee made more than $100,000,
did that employee still count towards the 500 employee cap?
A.
Yes.
Q.
Were there any circumstances where the amount of the loan
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could be based on gross income as opposed to average monthly
payroll?
A.
Yes.
Q.
What were those circumstances?
A.
The Schedule F for farmers and ranchers.
THE COURT: Wait. Say that again. A schedule F?
THE WITNESS: Schedule F.
THE COURT: For farmers and ranchers?
THE WITNESS: Yes.
THE COURT: Okay.
BY MR. EVERT:
Q.
And was there a cap as to the size of the loan that could
be received based on gross income?
A.
Yes.
Q.
Was that -- what -- what was that cap?
A.
$100,000.
Q.
So you -- you couldn't say you had average monthly payroll
of more than $100,000 based on that; is that correct?
Strike that. That was --
A.
Okay. I didn't understand the question.
Q.
Yeah. But there was a $100,000 cap on that, correct?
A.
There's a $100,000 cap when calculating the average
calculation for individuals, employees.
Q.
And given that cap, would it be possible to get a
$9 million PPP loan based on the gross income of the company?
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A.
No.
Q.
If a loan was going to be based on gross income, would
that have had to have been reflected on the form?
A.
Yes.
Q.
In connection with a PPP loan application, did an
applicant have to submit any documentation of its payroll?
A.
Yes.
Q.
If a business submitted tax records in support of its
application, did those documents have to have actually been
filed with the IRS?
A.
Yes.
Q.
And if a -- if a business supported documents in support
of its application, did those documents have to contain true
information?
A.
Yes.
Q.
Was an applicant allowed to make up information --
A.
No.
Q.
-- in order to get a PPP loan?
A.
No.
Q.
Were there requirements for how funds received from a
PPP loan had to be used?
A.
Yes.
Q.
What -- what did the proceeds of a PPP loan have to be
used for?
A.
Payroll, rent, mortgage expense, mortgage interest
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expense, excuse me, covered expenditures, covered protection
wear and utilities.
Q.
Turning to Page 2, if we could please look at the third
certification, starting with, The funds will be used.
It states the funds will be used to retain workers,
maintain payroll or make payments for mortgage, interest,
rent, utilities, covered operations, expenditures, covered
property damage costs, covered supplier costs and covered
worker protection expenditures.
THE COURT: You're now going too fast.
THE WITNESS: Yes.
MR. EVERT: I'm going too fast, okay.
THE COURT: Everybody should talk slower than they
think is normal.
MR. EVERT: Okay.
BY MR. EVERT:
Q.
So this -- this certification, which says the funds will
be used to retain workers and maintain payroll or make various
other payments, was this geared towards those spending
requirements for the proceeds of the loan?
A.
Yes.
Q.
Could PPP funds be used to support non-U.S. workers?
A.
No.
Q.
Could PPP funds be used to support non-U.S. operations?
A.
No.
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Q.
Could PPP funds be used to purchase personal residences?
A.
No.
Q.
What if the business that had applied for the PPP loan was
headquartered at a personal residence?
A.
If it was an eligible expense, they could use it for that
purpose, but no.
Q.
And eligible expense meaning -- can you explain what that
means?
A.
If there's a home office and they use a home office and
they use that for the purpose of the IRS and they report it to
the IRS, for that purpose of that home office expense, they
could use some of it for the home office expense.
Q.
Would they be allowed to buy the whole -- buy a whole
house, a whole new house?
A.
No.
Q.
Could PPP funds be used to purchase personal vehicles?
A.
No.
Q.
Could PPP funds be used to start a new business?
A.
No.
Q.
Why not?
A.
You had to be in operation before February the 15th, 2020.
Q.
If a -- if an individual wanted to start a new business
and wanted assistance from the SBA to do so, are there
programs available that could provide such a loan?
A.
Yes.
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Q.
Did those exist in 2021?
A.
Yes.
Q.
And in order to get a loan under such a program, would an
applicant need to provide more or less documentation than what
was required to get a PPP loan?
A.
It would be required to provide all the information that
would be for a 7A loan, so it would be more information.
Q.
And in getting a 7A loan, would the -- would the
verification that the -- that the lender would be -- do --
sorry.
In order to get a 7A loan, would the verification
that the lender would be doing be more onerous or less onerous
than what -- what was done for a PPP loan?
A.
It would be more onerous.
Q.
And I believe you -- you touched on this already, but just
to be clear, why was there less documentation required for a
PPP loan than a conventional loan?
A.
Due to the national emergency, the speed in getting the
funds out to American businesses.
Q.
Were there circumstances under which a PPP loan could be
forgiven?
A.
Yes.
Q.
If an applicant was not planning to seek forgiveness, was
the applicant allowed to use the funds for non-business
purposes?
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A.
No.
Q.
If the applicant was not planning to seek forgiveness, was
the applicant allowed to use the funds to buy a personal
residence?
A.
No.
Q.
If the applicant was not planning to seek forgiveness, was
the applicant allowed to use the funds to buy personal
vehicles?
A.
No.
Q.
If the applicant was not planning to seek forgiveness, was
the applicant allowed to use the funds to start a new
business?
A.
No.
Q.
If the applicant did not plan to seek forgiveness, was the
applicant allowed to provide false information in his or her
application?
A.
No.
Q.
Was it important that the information -- well, was it
important that the applicant attested that the information
provided in its application was correct?
A.
Yes.
Q.
If an applicant did not attest to the accuracy of the
information in the application and the supporting documents,
could the loan have been issued?
A.
No.
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MR. EVERT: No further questions.
CROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
Good morning, Ms. Drake.
A.
Good morning. How are you?
Q.
I'm good. I have a few questions for you. So you're with
the SBA?
A.
Yes.
Q.
And that is a -- is that a Georgia agency or is it a
federal agency?
A.
It's a federal agency.
Q.
And you are under what branch of the government?
A.
Executive branch.
Q.
You guys are still funded?
A.
We are still funded.
Q.
Good to hear.
So going back to the pandemic times, the PPP loan
program was originated by Congress and the president, right?
A.
Yes.
Q.
Okay. And SBA did not loan the money, it was the banks
that were actually loaning out the money, right?
A.
Yes.
Q.
And the SBA, did the SBA or the United States government
guarantee those loans?
A.
The SBA guaranteed the loans.
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Q.
Okay. And that means the bank wasn't on the hook for it,
right?
A.
Yes, they were on the hook.
Q.
They were on the hook?
A.
Yes.
Q.
So if there is a default on the loan, the bank has to pay
that money?
A.
No. SBA guaranteed the loan. But the lender still had to
disburse the funds, they had to close the loan, they had to
liquidate the loan, then they had to submit it to SBA for the
guarantee.
Q.
Okay. And so when someone applied for a PPP loan, they
did not come to the SBA, right?
A.
No.
Q.
They went to the bank, right?
A.
Yes.
Q.
And the bank was the one that processed that application?
A.
Yes.
Q.
And the bank did have a due diligence requirement there,
did it not?
A.
Yes.
Q.
And you actually -- he asked you the direct question, if
there was -- I guess if there was misinformation -- his
question was is that the lender's fault or the applicant's
fault, right?
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A.
He did ask that question.
Q.
And you said it would be the applicant's fault, right?
A.
I said it would be the applicant's fault if the applicant
provided false information.
Q.
But the lender did have some due diligence obligation, did
it not?
A.
The lender had due diligence, but the lender could
attest -- could take the applicant's information that it was
true and correct.
Q.
Okay. So if you submitted something crazy in crayon and
said I am the king and give me the money and the bank
processed that, that would be okay?
A.
It would not.
Q.
The bank has to look at the documents, does it not?
A.
The bank reviews the application and can request
additional documentation.
Q.
The bank does make money on these -- on these loans, don't
they?
A.
Yes.
Q.
Okay. They get money on the front end and the back end?
A.
No, just the front end.
Q.
Okay. And what kind of percentage does the bank make?
A.
It was 1 percent.
Q.
You asked -- you were talking about -- and I'm going to
change topics here -- who is qualified to be counted as an
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employee.
And you were asked if there were workers that were
out of the country but their house was in the United States,
you said that that person couldn't be counted as an employee
for a -- for PPP calculations, right?
A.
What I said is that they had to be counted for affiliation
purposes, all employees domestic and foreign have to be
counted for size standards to determine if the business is
small, but when you determine the loan amount, it was based on
the number of employees in the United States and their
principal residences in the United States.
Q.
Well, and it's -- it's the principal place of residency, I
believe you said as defined by the IRS, right?
A.
That is correct.
Q.
You're not the IRS, I'm guessing, right?
A.
I am not.
Q.
Do you actually have that definition of as defined by the
IRS, what that means?
A.
I do not. But we do have reference to it in the CFR.
Q.
Okay. So if for IRS -- if the IRS decides you are a
resident of the United States, even if you live abroad, then
you could be counted, right?
A.
If the IRS determines that your principal place of
residence is in the United States, you would be considered the
principal place of residence in the United States.
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Q.
And, for example, like where somebody resides -- maybe
somebody wants to say they reside in Florida because they've
got better tax laws, but they spend 51 percent of the year --
or, no, 49 percent of the year in Vermont, I mean, that's --
the IRS -- there are rules for that and the IRS decides where
you are a legal resident of, right?
A.
I presume, yes.
Q.
And you're not an expert on that stuff, I'm guessing?
A.
I am not.
Q.
Okay. So you can't say, for instance, that Mr. Delano's
employees that were working in Ghana, whether they met the
legal definition of resident there or here, can you?
A.
I cannot.
Q.
Okay. You were asked about the -- there's a requirement
that the business had to be in operation before February 15th,
2020, correct?
A.
On or before.
Q.
On or before, okay. And that's in operation, right?
A.
That's correct.
Q.
It's not incorporated, right?
A.
That's correct.
Q.
Okay. And you mentioned that PPP loans could be forgiven,
right?
A.
Yes.
Q.
If they met the criteria?
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A.
Yes.
Q.
And if the person asked for the loan to be forgiven,
correct?
A.
Yes.
Q.
And what means, if you ask for your loan to be forgiven
and it was agreed to be forgiven by, I guess -- who made that
decision, the bank or you guys?
A.
The bank looks at the application, the information
provided, to determine if it met the forgiveness requirements.
And then the bank would then submit, unless the loan was under
$150,000.
And the loans under $150,000 could do direct
forgiveness. Loans over $150,000 had to go through the
lender, the lender would determine if it met the criteria
based on the documents provided to submit for forgiveness.
Q.
Okay. And if the person didn't ask for forgiveness,
they -- it became a regular loan which they had to repay,
right?
A.
They would be required to make the payments on the loan.
Q.
And there was a deferral period in that repayment plan?
A.
It was.
Q.
Okay. How long was that deferral?
A.
I don't recall because it was extended.
Q.
Maybe it was originally six months and then it went out to
over a year, right? Does that sound right?
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A.
It was originally six months. I don't recall how it was
extended, it was 8 or 12 months.
Q.
And I gather that when the payments became due on the
loan, the bank would send the borrower notices saying, hey,
this is what you have due and this is when it's due. They
would send a regular loan statement; is that fair?
A.
I presume they would.
Q.
Okay. And I gather -- I mean, you have -- do you still
have to supervise these folks that have like part of the PPP
program like --
A.
I don't directly supervise them. I work with the lenders
in Georgia.
Q.
You work with the lenders. But do you have to review like
where loans are being repaid to this very day?
A.
SBA does, yes.
Q.
Not you personally?
A.
Not me personally.
Q.
Okay. And just to be clear, if someone met the criteria
for forgiveness and they requested it, they could be -- a
whole 100 percent of that loan could be forgiven?
A.
Yes.
Q.
And if they didn't request it, then a whole 100 percent of
that loan had to be repaid?
A.
Yes.
MR. FINLAYSON: Nothing further, Judge.
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REDIRECT EXAMINATION
BY MR. EVERT:
Q.
Sorry, I'll just touch briefly on something that defense
counsel said. He said that if -- if the applicant didn't seek
forgiveness, the loan became a regular loan.
Was -- if you applied for a PPP loan, was it a
PPP loan at all times?
A.
Yes.
Q.
So even if you weren't seeking forgiveness, the -- you
still had a PPP loan; is that correct?
A.
That is correct.
Q.
And were you allowed to use the proceeds of your PPP loan
for ineligible purposes, even if you weren't seeking
forgiveness?
A.
No.
Q.
And even if -- even if a loan wasn't in -- wasn't seeking
to be forgiven, were you allowed to buy a personal residence?
A.
No.
Q.
Were you allowed to use the money to start a new business?
A.
No.
Q.
Were you allowed to buy personal vehicles?
A.
No.
Q.
Were you allowed to --
MR. FINLAYSON: Your Honor, objection; asked and
answered.
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MR. EVERT: Were you allowed to put the down payment
on a yacht?
THE COURT: Let me rule.
MR. EVERT: I'm sorry.
THE COURT: I'm going to overrule the objection.
Go ahead.
BY MR. EVERT:
Q.
Were you allowed to put the down payment on a yacht?
A.
No.
Q.
So on day one of the loan application, the person is
attesting that they are going to use that loan for authorized
purchases, correct?
A.
Yes.
Q.
And the person isn't seeking -- seeking forgiveness on day
one of the application, correct?
A.
No.
Q.
And regardless of what is in the person's head about if
they want to seek forgiveness down the line, if they don't
want to seek forgiveness down the line --
MR. FINLAYSON: Objection.
THE COURT: Ask the question.
BY MR. EVERT:
Q.
So regardless of what is in a person's head about whether
they want to seek forgiveness down the line, whether they
don't want to seek forgiveness down the line, were they ever
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allowed to provide false information in their loan
application?
A.
No.
THE COURT: Overruled. Yes. You looked like you
were withdrawing your objection.
MR. FINLAYSON: That's correct.
THE COURT: Okay. You can answer the question. What
was the answer to the question?
THE WITNESS: It was no.
BY MR. EVERT:
Q.
So they were never allowed to provide false information?
A.
No.
MR. EVERT: No further questions. Thank you.
MR. FINLAYSON: Very quickly.
RECROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
So the requirements when you submit a PPP application and
say you're going to use this money for eligible expenditures,
right?
A.
Yes.
Q.
And there's also a provision that says if you don't,
you're not going to be entitled to forgiveness, right?
A.
Yes.
Q.
That's what the form -- that's what the paperwork says.
If you use it -- like say you go start another business with
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it, you can't get forgiven for that, can you?
A.
It's ineligible. You're not supposed to use it for those
purposes. Even though the loan was -- would be not forgiven,
the use of the proceeds must be for the payroll expense and
other covered -- covered expenditures.
Q.
And the documentation, though, that is provided with
the -- with the PPP application says if you use it for
something else, you are not going to get forgiven, right?
A.
Correct.
MR. FINLAYSON: Thank you.
MR. EVERT: One quick follow-up question.
FURTHER DIRECT EXAMINATION
BY MR. EVERT:
Q.
If we could please turn to Page 2 of Government's
Exhibit 150. And if we could look at the second to last
certification there.
Would you please read that?
A.
I further certify that the information provided in this
application and the information provided in all supporting
documents and forms is true and accurate in all material
respects.
I understand that knowingly making a false statement
to obtain a guaranteed loan from the SBA is punishable under
law -- under the law.
Q.
And we can stop there.
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A.
Okay.
MR. EVERT: No further questions.
THE COURT: Okay. May the witness step down? No.
Go ahead.
MR. FINLAYSON: Let me do this the right way.
MR. EVERT: Yeah, I'm going to -- this wasn't in
effect at the time he applied for the loan.
MR. FINLAYSON: No. Oh, okay.
MR. EVERT: There are updated regs. They were
updated many times after that.
MR. FINLAYSON: Well, I'm going to see if she can
recognize it.
BY MR. FINLAYSON:
Q.
I'm going to hand you what I've marked as Defendant's
Exhibit 1.
MR. EVERT: I would object on relevance grounds.
THE COURT: Okay. Why don't y'all step out for a
second. It seems like this might be a little more involved.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE WITNESS: Do you need me to step out, too?
THE COURT: And, ma'am, why don't you step out for
just a minute. Okay?
(Whereupon, the witness exited the courtroom.)
THE COURT: What are we talking about?
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MR. FINLAYSON: CFR regulations about the use of --
of PPP funds for unauthorized purposes. And what I want to
get out of her is the provision that SBA will direct you to
repay those amounts.
And they object because they say this -- these CFRs
were updated subsequently and were not in effect at the time
of the loan.
MR. EVERT: There's been -- there were multiple --
this is the -- this is the March 2020 version of the regs. We
have the regs here that are --
THE COURT: That were in effect at the time?
MR. EVERT: That were in effect at the time.
THE COURT: What was the date of his loan?
MR. EVERT: His was March -- or he applied in
February 16th of 2021.
THE COURT: Okay.
MR. FINLAYSON: And my only -- this is the only copy
I've got in discovery, so I --
MR. EVERT: Well, you provided this in discovery,
yeah.
THE COURT: Hold on, y'all. Can you talk to me about
this.
MR. EVERT: So he -- yeah.
THE COURT: If it's not in effect, then it's not
relevant to show the witness.
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MR. FINLAYSON: Okay.
THE COURT: And my concern is that you're not going
to tell the witness it's not in effect and you're going to get
the witness to -- I don't know. I don't know what your plan
to do is.
But we ought to -- if we know it's not in effect and
therefore not relevant, we ought not show it to the witness or
the jury.
MR. FINLAYSON: And she's already given me the
answer, so I don't want to die on the hill. I do -- I guess
I've got it -- maybe it was in my file from prior counsel. I
thought it had come from the government. I thought it was in
discovery.
THE COURT: Okay.
MR. EVERT: We may have provided old -- numerous
copies of the regulations, but these -- these are available
online.
THE COURT: Okay. All right. So what do you want to
do? Are you done with her then?
MR. FINLAYSON: I'm done with her.
THE COURT: We'll call her back in and we'll bring
them back in.
But y'all keep in mind redirect and recross are
supposed to get narrower to what's been brought up, not what
you didn't cover the last time. Okay?
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I'm not such a stickler about it, because I want you
to try your case, but we ought to be moving that way. Okay?
MR. EVERT: Understood.
THE COURT: All right. Why don't you bring them in.
And why doesn't somebody grab Ms. Drake. Ms. Drake,
is that her name?
MS. CONNORS: Ms. Drake, yes.
MR. FINLAYSON: I guess I will -- actually, I will
ask her one question, Judge.
THE COURT: Okay.
MR. FINLAYSON: I'm not going to use -- okay.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the witness entered the courtroom.)
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. Y'all can be seated.
Go ahead, sir.
FURTHER CROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
Just one last question, ma'am. And I want to confirm. If
someone -- they were told when they get the loan, if somebody
uses PPP funds for an unauthorized purpose, SBA will direct
you --
MR. EVERT: Objection.
THE COURT: Let him finish the question.
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BY MR. EVERT:
Q.
SBA will direct you to repay the loan or repay the
amounts?
THE COURT: Basis for the objection?
MR. EVERT: Relevance.
THE COURT: You can ask it a different way.
MR. FINLAYSON: They were --
THE COURT: You can ask him what he was told or you
can ask him what's in a document or something like that, but
you just can't ask abstractly what somebody was told, unless
she knows. I don't know.
BY MR. EVERT:
Q.
Or what the policy was, would the policy for the program,
people were told if you use it for something else, you're
going to have to repay it? Is that fair or true?
A.
I don't know what lenders told applicants. But SBA's
direction to lenders, that it was supposed to be used for the
intended purpose. Because we had other loan programs.
And I'll give you an example. Our 7A loan program
during the same CARES Act had another loan if you were a
business getting a loan, the first six months of your payments
were made for you by SBA. So there were other loan programs
available for businesses that did not intend to use the
proceeds for the intended purposes.
Q.
Okay. So is it your testimony -- let me ask it this way.
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There was a policy put out there by SBA or the
government that if the loan was used for something
different --
MR. EVERT: Objection.
THE COURT: Let him finish the question.
BY MR. EVERT:
Q.
-- they have to -- they have to repay the loan, right?
MR. EVERT: Objection.
THE COURT: Basis?
MR. EVERT: Relevance as what we discussed at the --
THE COURT: Sustained. This issue has been gone over
quite at length.
MR. FINLAYSON: Okay. We're good. Thank you.
THE COURT: Oh, all done? Okay. You can step down.
Thank you very much.
THE WITNESS: Thank you.
THE COURT: I hope you have a nice day.
THE WITNESS: You, too. Thank you.
COURTROOM SECURITY OFFICER: Watch your step.
THE WITNESS: Thank you.
THE COURT: All right. Call your next witness.
MR. EVERT: The government calls Kelli Carpenter.
- - -
KELLI CARPENTER,
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: My name is Kelli Carpenter. It's
K-E-L-L-I, C-A-R-P-E-N-T-E-R.
COURTROOM DEPUTY: Thank you.
DIRECT EXAMINATION
BY MR. EVERT:
Q.
Good morning, Ms. Carpenter.
A.
Good morning.
Q.
Where do you work?
A.
I work for JPMorgan Chase.
THE COURT: Pull that microphone a little closer or
scoot up and really project.
And we've all been telling everybody to talk slowly.
Okay?
THE WITNESS: Okay.
THE COURT: We have to take it all down. Thanks.
BY MR. EVERT:
Q.
And how long have you been -- is JPMorgan Chase also known
as Chase?
A.
Yes.
Q.
I'll refer to it as Chase, so we can know that we're
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talking about the same entity?
A.
Yes.
Q.
All right. So have you -- how long have you been with
Chase?
A.
Total time of about ten years.
Q.
Can you please walk me through the roles that you've had
at Chase?
A.
Absolutely. I was hired as an SBA eligibility officer
about 12 years ago.
I briefly left the firm for about 15 months to work
as an underwriter at another lender.
And then I returned 15 months later as the manager of
a team that I had been a part of as an SBA credit manager.
Then I moved, about three and a half years later, to
our risk team, to manage our SBA national underwriting team
for about five and a half years.
And then about seven months ago, I moved back to our
SBA solutions team to manage the entire team that I had been a
part of.
Q.
And in the roles that you've had at Chase, did you have
personal involvement with the Paycheck Protection Program or
the PPP?
A.
Yes.
Q.
How were you involved with the PPP?
A.
It was part of when I was part of the risk organization, I
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managed a team of credit officers that reviewed the
applications and I also reviewed them myself.
Q.
And so you personally reviewed loans; is that correct?
A.
I personally reviewed PPP applications, yes.
Q.
And I believe you mentioned you had a managerial role.
Can you explain what your role was with respect to
the team that was working on the PPP --
A.
Yes.
Q.
-- issue?
A.
I had 12 credit officers that reported to me that were
also reviewing PPP applications.
Q.
So with respect to the PPP program more broadly, what was
Chase's role specifically?
A.
So the program was designed for the lenders to review and
approve the applications in conjunction with the SBA and the
Treasury Department for assistance in getting the funds out
more quickly.
Q.
And so you can sort of explain the dynamic between Chase
and the SBA as it related to a given PPP loan?
A.
So the lenders were required to do a good-faith review of
the application in a reasonable amount of time. And the SBA
provided 100 percent guarantee on those loans, so if there was
a default, the bank would be repaid in whole for that loan.
Q.
So even though the PPP is an SBA program, who was actually
putting up the money for the loan?
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A.
The lenders did the funding.
Q.
So in this case, in the case where Chase was the lender,
it would have been Chase's money that was going out to the --
to the applicant?
A.
Correct.
Q.
So if a PPP applicant wanted to get a loan through Chase,
what was the process for how that would work?
A.
So in 2021, applicants accessed a portal after they had
logged into their Chase business account. So they were
required to be a Chase client and when they logged into their
account, they could see a link to digitally apply for a
PPP loan.
Q.
And when -- when an individual clicked the link to apply
for a PPP loan, what would -- what would happen next?
A.
So there was different questions and information that
would be provided as part of that application that was based
on the information in the SBA forms required to be used to
analyze, you know, the application.
Q.
And were there requirements for what had to be included in
a PPP application?
A.
Yes, based on the SBA form, there were certain data
elements that had to be in each of the applications for it to
proceed.
Q.
And who set those requirements for what had to be included
as part of the SBA -- as part of an application?
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A.
The SBA did.
Q.
And what type of information did the SBA require to be
part of the application for a PPP loan?
A.
So like the name of the business, their origination date,
number of employees, your average monthly payroll. There were
certifications that were required, certain questions that had
to be addressed by the applicant.
Q.
And was there additionally documentation that had to be
provided by the applicant?
A.
Correct, yeah. So there was payroll information that had
to be required as well as documentation that they were in
business as of the beginning of the pandemic, which SBA
established February 15th, 2020, as that like cutoff date that
that was what they set as the eligible date.
Q.
And could the documentation that a given business provided
to Chase in support of the loan have varied from loan to loan?
A.
Absolutely.
Q.
But it had to establish those things that you just
mentioned, the eligibility, the eligibility for the loan?
A.
Correct.
Q.
Did Chase have any additional requirements that it made
businesses meet?
A.
No.
Q.
Are you familiar with a Chase customer called
Kremkov Industries?
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A.
Yes.
Q.
Did Kremkov Industries apply for a PPP loan from Chase?
A.
Yes.
Q.
Did Chase ultimately give Kremkov Industries a PPP loan?
A.
Yes.
Q.
What was the size of the loan -- of the PPP loan that
Chase gave to Kremkov Industries?
A.
It was a little over 9,500,000.
Q.
And are you familiar with a Chase customer named
Carl Torjagbo now known as Karl Delano?
A.
Yes. He was the owner, stated owner on the application.
Q.
On Kremkov Industries' application?
A.
Correct.
Q.
And what was his role with respect to the PPP loan
application?
A.
So he was the authorized person from the company that
applied for the PPP loan.
Q.
And in your binder, there are government exhibits that --
that -- there are documents that have been marked for
identification as Government's Exhibits 101, 101A. I believe
it's that open binder that should be near the front.
101, 101A, 101B, 101C, 102, 102A, 103, 103A, 104,
105, 106, 107, 108, 310 and 310A, do you recognize these
documents? I know it's a lot of them.
A.
This is -- 101 is an application, so it has the SBA form,
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so yes, I do.
Q.
I can provide them -- I've got them in folders here if
that's easier.
A.
Okay.
Q.
And I'll just ask you, are these Chase business records
relating to Kremkov Industries and Carl Torjagbo?
A.
Yes.
Q.
And have -- have you reviewed these records in preparation
for your testimony today?
A.
Yes.
MR. EVERT: I would move to admit Government's
Exhibits 101, 101A, 101B, 101C, 102, 102A, 103, 103A, 104,
105, 106, 107, 108, 310 and 310A.
MR. FINLAYSON: Is 108 the call, the recording?
MR. EVERT: Yes.
MR. FINLAYSON: No objection.
THE COURT: 101 is already admitted; is that right?
MR. EVERT: Oh, I apologize. Yes, 101 is already
admitted, correct.
THE COURT: Other than that, they're all admitted and
may be published.
MR. EVERT: All right. If we could pull up
Government's Exhibit 101 on the screen, please.
BY MR. EVERT:
Q.
What is this?
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A.
This -- this is the PPP application form.
Q.
And was this submitted to Chase?
A.
Yes.
Q.
And pages -- what are Pages 1 to 4 of this form?
A.
So the first page, the top identifies the business and the
requested amount, the intended use of funds and the ownership.
And then there are questions that determined eligibility as
well as certifications.
Q.
And who -- who created this form?
A.
This is an SBA form.
Q.
And who filled out the information in this form?
A.
The applicant.
Q.
Was this included for every PPP application?
A.
Yes.
Q.
Why was this included as part of the application process?
A.
It was required by the SBA.
Q.
And at the top of Page 1 below where it says business
legal name, can you please read what it says?
A.
Kremkov Industries, LLC.
Q.
So this was Kremkov Industries, LLC's application for a
PPP loan?
A.
Correct.
Q.
Turning to Page 2, if we could look at the bottom of the
page, and it will get pulled up on your screen.
Can you -- where -- where it says signature of
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authorized representative of applicant, whose name appears
there?
A.
Carl Torjagbo.
Q.
And right next to the signature is a date. Could you
please read that date?
A.
2/16/2021.
Q.
So is that the date when this application was submitted?
A.
Correct.
Q.
Two paragraphs above Carl Torjagbo's name, can you please
read where it says the -- can you please read the paragraph
beginning where it says, I further certify?
A.
I further certify that the information provided in this
application and the information provided in all of the
supporting documents and forms is true and accurate in all
material respects. I understand that knowingly making a false
statement to obtain a guaranteed loan from the SBA is
punishable under the law.
Q.
And you can stop there. We don't have to -- it's a long
paragraph. So whose initials are next to that statement?
A.
CT, which is --
Q.
And?
A.
-- Carl's.
Q.
And turning back to Page 1, in the middle of the page, it
says -- where it says applicant ownership, it's this middle --
middle box here or third box down. Yeah, perfect.
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A.
Yeah. So Carl Torjagbo is listed as 100 percent owner on
the form.
Q.
Is there any mention of someone named Michael Lee having
an ownership stake in Kremkov Industries?
A.
No.
Q.
Now, if we can go out of this and look at the top
right-hand corner. It says year of establishment. Can you
please read the date there?
A.
12/31/2014.
Q.
And now why did it matter what year the business had been
established?
A.
So to be eligible for a PPP loan, you had to have already
been established and in operation as of 2/15/2020.
MR. EVERT: And if we could please turn to Page 2.
And then middle -- middle part of the page. Yeah, great.
BY MR. EVERT:
Q.
And then it says the authorized representative of the
applicant must certify in good faith to all of the below by
initialing next to each one. Can you please read the first
item on that list?
A.
The applicant was in operation on February 15th, 2020, has
not permanently closed, and was either an eligible
self-employed individual, independent contractor or sole
proprietorship with no employees, or had employees for whom it
paid salaries and payroll taxes or paid independent
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contractors as reported on Form 1099 miscellaneous.
Q.
Was it important to Chase that -- and, sorry, whose --
whose initials are next to that statement?
A.
CT.
Q.
And is that Carl Torjagbo?
A.
Yes.
Q.
Now known as Karl Delano?
A.
Yes.
Q.
Was it important to Chase that Kremkov Industries was, in
fact, in operation on February 15th of 2020?
A.
It was a requirement of the program, yeah.
Q.
If Chase had known that Kremkov Industries was not really
in operation on February 15th of 2020, would this loan have
been approved?
A.
No.
Q.
And turning back to Page 1, where it says in the top
right-hand corner applicant including affiliates, if
applicable, meets size standard. Can you please read the box
that is checked?
A.
No more than 500 employees.
Q.
And was there a maximum number of employees that a
business could have in order to be eligible to get a PPP loan?
A.
There were multiple size standards that were allowable,
the two lower boxes relate to SBA size standards, but
employees was one measurement as well.
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Q.
And if this box was checked, did that mean that the
applicant was certifying that it qualified based on this first
criteria being the no more than 500 employees?
A.
Correct.
Q.
And then on the bottom of the -- on the bottom half of the
page, we have a payroll calculation -- we'll have a payroll --
MR. EVERT: A little further up. Sorry. Yeah.
BY MR. EVERT:
Q.
We have a payroll calculation, correct?
A.
Yes.
Q.
And we're going to talk a lot more about that. But it
says -- then in the next section down, it says -- on the
bottom half of the page, could you please read Question Number
7.
A.
Is the United States the principal place of residence for
all employees included in the applicant's payroll calculation
above.
Q.
What is your understanding as to why the application asked
this question?
A.
So employees that resided outside of the United States
were not eligible to be included in the program for their
calculation.
Q.
And what is the response to this question on this -- on
Kremkov Industries' form?
Oh, sorry. I guess we'll have to zoom out.
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A.
Yes. It's yes.
Q.
It's yes, okay.
And if the answer to that question had been no, would
Chase have approved the loan to Kremkov Industries?
A.
No.
Q.
So was it important to Chase that the principal place of
residence for the 493 employees of Kremkov Industries that
were used in calculating the payroll was, in fact, the
United States?
A.
Yes, as a determined eligibility by SBA policy.
Q.
If the applicant had, for example, 492 employees in the
United States but just one employee was only in Ghana, would
it have been correct to say yes in response to this -- in
response to this question?
A.
No.
Q.
By putting 493 as the number of employees, was the
applicant attesting to the bank that all 493 employees reside
in the United States?
A.
Yes.
Q.
And I will just pull up that average monthly payroll
again. And the number of employees next to average monthly
payroll is 493; is that correct?
A.
Correct.
Q.
All right. And then looking at this box, in the middle of
the page it says average monthly payroll. Can you please read
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that amount?
A.
$3,821,770.
Q.
And would that figure have been inputted by the applicant?
A.
Yes.
Q.
In this case, Carl Torjagbo, now known as Karl Delano?
A.
Yes.
Q.
And was it important to Chase that the number accurately
reflected the average monthly payroll that Kremkov Industries
had for Kremkov Industries' employees in the United States?
A.
Yes.
Q.
In the next box over, it says times 2.5 plus EIDL equals
loan request amount; is that correct?
A.
Yes.
Q.
Can you explain what that means?
A.
So the loan amount was based on two and a half times the
monthly average payroll. There was an ability to also
refinance EIDL loans within the PPP program, if they chose.
Q.
And can you please read the figure that's -- that's there?
THE COURT: What's EIDL? Could we --
BY MR. EVERT:
Q.
Oh, yes. What -- what is EIDL?
A.
So EIDL was a direct program from the SBA where they
funded those loans direct to the applicants themselves.
Q.
Got it. And if you're looking at this figure here, is --
can you please read that number?
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A.
$9,554,425.
Q.
And is 2.5 -- can -- can you do the math of --
A.
Yes. It's two and a half times.
Q.
It's two and a half times that $3 million number?
And is that the size of the loan that Kremkov
Industries got from Chase?
A.
Correct.
Q.
That $9,554,425 number?
So how was the amount of this loan calculated?
A.
The program was based on the two and a half times the
average monthly payroll. That was the maximum amount
allowable for each business.
Q.
Was this loan based in any way on the amount of the income
that Kremkov Industries had?
A.
No.
Q.
Was it based on Kremkov Industries' revenue?
A.
No.
Q.
If -- if -- strike that.
If JPMorgan Chase had known that Kremkov did not in
fact have an average monthly payroll of $3,821,770 for
U.S. employees, would it have approved the loan?
A.
No.
Q.
Was it important to Chase that that $3 million --
$3.8 million number was, in fact, accurate?
A.
Yes.
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Q.
If Chase had known that Kremkov's average monthly payroll
to employees who resided in the United States was zero
dollars, how much of a loan would Kremkov have received?
A.
Zero.
Q.
So let's look at the next box down on Page 1. It says
purpose of the loan, select all that apply. Can you please
read the boxes that are checked?
A.
Payroll costs, rent/mortgage interest, utilities, covered
operation expenditures, covered property damage and covered
worker's protection expenditures.
Q.
And then on Page 2, if you could please read the third
attestation down starting with "the funds will be used."
A.
The funds will be used to retain workers and maintain
payroll or make payments for mortgage interest, rent,
utilities, covered operation expenditures, covered property
damage costs, covered supplier costs, and covered worker
protection expenditures as specified under the Paycheck
Protection Program rules.
I understand if the funds are knowingly used for
unauthorized purposes, the federal government may hold me
legally liable such as for charges of fraud.
Q.
And whose initials are next to that statement?
A.
CT.
Q.
And is that Carl Torjagbo?
A.
Yes.
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Q.
Why was this attestation required?
A.
So there were multiple certifications provided as part of
the application, this one specifically is around the use of
the funds.
Q.
And was it important to Chase that the funds from the
PPP loan be used for authorized purposes?
A.
Yes.
Q.
If Chase had known that the proceeds of the loan were
going to be used to buy a personal residence for Karl Delano,
would it have approved the loan?
A.
No.
Q.
If Chase had known that the proceeds of the loan were
going to be used to buy luxury vehicles for Karl Delano, would
it have approved the loan?
A.
No.
Q.
If Chase had known that the proceeds of the loan were
going to be used to put the down payment on a yacht, would it
have approved the loan?
A.
No.
MR. FINLAYSON: Objection, Your Honor. Objection.
These questions all assume facts not in evidence.
THE COURT: Okay. Remember questions are not
evidence, right? So the question was if these things
occurred, would this be okay. So it's a hypothetical
question. But it doesn't imply that those things occurred.
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Is that appropriate?
MR. FINLAYSON: Yes, sir. Thank you.
THE COURT: Okay. Do you understand that? So if
these things were used for -- what was your question?
MR. EVERT: I believe the last question that drew the
objection was if the -- if Chase had known that the proceeds
of the loan were going to be used to put the down payment on a
yacht --
THE COURT: Okay.
MR. EVERT: -- would the -- would it have been
approved.
THE COURT: So the witness can answer that question
as to whether or not that would have been approved. That
doesn't mean the money was used for that purpose. If that's
the case, maybe we'll hear about it later, okay?
But don't assume it was used because of a
hypothetical. But I think you probably get that it was a
hypothetical question.
Okay. Go ahead.
BY MR. EVERT:
Q.
If Chase had known that the proceeds of the loan were
going to be used to start a new business, would it have
approved the loan?
A.
No.
Q.
Did Mr. Delano ever tell Chase that he was going to use
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the proceeds of the loan to start a trucking and logistics
company?
A.
No.
Q.
And one certification above that one, the second one down,
can you please read that?
A.
Current economic uncertainty makes this loan request
necessary to support the ongoing operations of the applicant.
Q.
If a company was able to pay its employees $45 million in
2020, would that suggest that the loan was necessary to
support its ongoing operations?
A.
Yes.
Q.
It could suggest that?
A.
It could.
Q.
Okay. Were the -- were the -- were the proceeds of a
PPP loan allowed to be used to support non-U.S. operations of
a business?
A.
No.
Q.
If Kremkov Industries did not have any operations in the
United States, would it have been important to Chase to know
that?
A.
Yes.
Q.
If Chase had known that Kremkov Industries did not have
any operations in the United States, would it have approved
the loan?
A.
No.
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Q.
Were applicants required to submit any documentation with
their loan application?
A.
Yes.
Q.
What type of verification were lenders required to do with
respect to that documentation?
A.
It was a good-faith review according to the SBA policy in
a reasonable amount of time. So there was a cursory review of
documents to see if they generally aligned with the
application.
Q.
Were lenders allowed to rely on the information in the
loan application as true?
A.
Yes, based on the certifications provided by the
applicant.
Q.
Was there any requirement that the lender call the
applicant to verify the information in this application?
A.
No.
Q.
Was there any requirement that the lender check with the
IRS to see if the taxes that an applicant claimed to have paid
were, in fact, paid?
A.
No.
Q.
Is the level of review that Chase did when approving
PPP loans the same as what it does when it approves regular
non-PPP loans?
A.
Absolutely not.
Q.
Can you explain why this difference exists or existed?
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A.
The SBA designed the program due to the urgency of getting
the funds out to the applicant businesses for there not to be
the due diligence checks that are existing in traditional
lending as that often takes, you know, multiple weeks to be
able to fund a loan. So that would not have been timely
enough to address the concerns around the pandemic.
Q.
And was that dictated by the SBA or was that Chase's
decision to do that type of verification for PPP loans?
A.
That was SBA's policy on the program. It was their rules
and regulations around the payment protection program.
Q.
And you mentioned that there was a -- there was a more
in-depth process for non-PPP loans. Did they have to go
through an underwriting process?
A.
PPP loans did not. Traditional loans do, yes.
Q.
And so when -- what does the underwriting process of a
traditional loan entail?
A.
Typically, you know, credit reports, potentially cash flow
analysis, due diligence checks that are -- were not part of
the PPP program.
Q.
And if a defendant -- or if the defendant had wanted a
conventional non-PPP loan, in order to start a new business,
would he have had to go through a different process than the
one he went through to get his PPP loan?
A.
Yes.
Q.
And I believe you just described that process, but on a
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high level, how would that process have been different?
A.
Credit reports were -- are a fundamental part of our
underwriting process as well as more financial information and
doing due diligence checks as well.
Q.
And so would those -- you mentioned that it -- for a
PPP loan, there were certifications that -- made by the
applicant that -- that the -- that Chase was allowed to rely
on.
Would that be the case for a traditional loan, would
Chase just rely on certifications by an applicant?
A.
No.
Q.
So was the loan that Kremkov Industries received ever
converted into a non-PPP loan -- a traditional non-PPP loan?
A.
No.
Q.
Was Kremkov's loan ever anything other than a PPP loan?
A.
No.
Q.
Did Karl Delano, formerly known as Carl Torjagbo, ever
submit any documentation to support the assertion that
Kremkov Industries had an average monthly payroll of
approximately $3.8 million?
A.
Yes.
Q.
What -- what did he submit?
A.
There were 941 forms, which are quarterly tax statements
that were provided for all four quarters of 2020. He also
provided a payroll document and a personal tax return and the
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940 form, which is the annual tax statement as well.
Q.
Without that documentation, would the loan have been
approved?
A.
No.
Q.
Did Chase rely on the supporting documentation provided by
Mr. Delano in order to approve the loan?
A.
Yes, we used the 941 forms.
Q.
Did tax documents submitted in support of the PPP loan
have to have actually been submitted to the IRS?
A.
Yes.
Q.
If Chase had known that the information in the supporting
documents was untrue, would it have approved the loan?
A.
No.
Q.
Turning to Page 10, if we could look at this. What is
this document?
A.
This document is the February payroll statement for 2020.
Q.
For Kremkov Industries?
A.
For Kremkov, yes.
Q.
And who submitted this?
A.
Karl did, along with his other application forms.
Q.
And turning to Page 80, where it says grand totals. What
the is the grand total for --
MR. EVERT: And if we could just zoom in on the one
above as well so we get the names of the -- the names of the
columns.
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BY MR. EVERT:
Q.
So what is the grand total for Kremkov Industries'
purported monthly pay for February of 2020?
A.
$3,901,665.45.
Q.
And then looking at the next column over, how much did
Kremkov Industries purportedly withhold in federal taxes in
February of 2020?
A.
$433,043.27.
Q.
And would that money have gone to the IRS?
A.
Yes.
Q.
And the next column over, how much did Kremkov Industries
purportedly withhold in Social Security taxes in February of
2020?
A.
$241,902.91.
Q.
And would that money have gone to the Social Security
Administration?
A.
Correct.
Q.
All right. Let's move on to the next document, Page 81.
What does this document purport to be?
A.
This is the Kremkov Industries' annual payroll statement
for all of 2020.
Q.
And who submitted this document?
A.
Karl did.
Q.
And turning to Page 122, where it says the grand totals,
what was the grand total that Kremkov Industries purportedly
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paid to its employees for the tax year of -- for the year of
2020?
A.
$45,861,255.93.
Q.
And then looking at the next column over, how much did
Kremkov Industries purportedly withhold in federal taxes from
its employees' pay in 2020?
A.
$5,096,786.12.
Q.
And would that money have gone to the IRS?
A.
Correct.
Q.
The next column over, how much did Kremkov Industries
purportedly withhold in Social Security taxes in February of
20820?
A.
$2,843,396.26.
Q.
And would that money have gone to the Social Security
Administration?
A.
Correct.
Q.
If Chase had known the people listed in these payroll
documents did not actually work for Kremkov Industries, would
it have approved the loan?
A.
No.
Q.
If Chase had known that the information about Kremkov's
federal tax and Social Security withholdings was not true,
would it have approved the loan?
A.
No.
Q.
Now, turning to Page 123, I believe you mentioned a number
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of tax documents. Who -- is this the start of where the tax
documents begin in this form?
A.
Yes.
Q.
And who -- who submitted these?
A.
Karl did. Karl Delano/Torjagbo.
Q.
If the tax documents were -- were -- if tax documents -- I
believe you testified earlier that if tax documents were
submitted in connection with a PPP loan, those had to have
been real tax documents that were filed with the IRS, correct?
A.
Yes.
Q.
If Chase knew that the tax documents had not actually been
filed with the IRS, would it have approved the loan?
A.
No.
Q.
Was it important that the information in the tax documents
was accurate?
A.
Yes.
Q.
If Chase had known that there was inaccurate information
in the tax documents provided for Kremkov Industries and for
Mr. Delano, would -- would it have approved the loan?
A.
No.
Q.
So turning to Page 125, what is this?
A.
This is Carl's personal tax return, the 1040 form from
2020.
Q.
And the name is Carl Torjagbo; is that correct?
A.
Yes.
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Q.
And could you read the Social -- the last four digits of
the Social Security number?
A.
0540.
Q.
And is Carl Torjagbo the person who submitted this in
connection with the PPP application?
A.
Yes.
Q.
What year is this for?
A.
2020.
Q.
Now, Item 1 on this form in the -- in the bottom right
here, it's -- what is he saying his wages, salaries and tips
is for -- for the year 2020?
A.
$9,199,411.
Q.
And Item 8 is other income from Schedule 1, Line 9. What
does he say that his other income was?
A.
A negative $9,099,360.
Q.
And so then one line down, what is he saying his total
income is?
A.
A negative $799,949.
Q.
And then turning ahead to Page 129. I believe you
mentioned there were some numbers in the negative. What --
what are the source -- what is the source of that -- of that
negative number, Item Number 28 above here?
A.
That is Kremkov Industries.
Q.
Just the thing above that.
MR. EVERT: Can you zoom?
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BY MR. EVERT:
Q.
And what's the EIN number there ending in?
A.
7540.
Q.
And let's turn ahead to Page 132. What is this document?
A.
That's the Georgia tax return, annual tax return.
Q.
And looking at your first name and your last name, who --
who is this -- who is this for?
A.
This is Carl Torjagbo's Georgia return for 2020.
Q.
And Item Number 4 says residency status. And then there's
a 1 next to it. What does that mean?
MR. EVERT: If we can zoom in on that.
BY MR. EVERT:
Q.
And there's a little code beneath the Item Number 4.
A.
Full year resident is number one.
Q.
So does that mean he was a full year resident of Georgia
in 2020?
A.
Correct.
Q.
Turning to Page 141. What is this? Or just -- I guess I
would just ask one more question on that.
Any -- any indication that he lived in Texas on that,
on that Georgia tax return?
A.
No.
Q.
Turning to Page 141, what is this?
A.
This is the quarterly tax statement 941s for the first
quarter of 2020.
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Q.
And what company is this for?
A.
Kremkov Industries.
Q.
And what -- what are the months that this -- that this
document covers?
A.
January, February and March.
Q.
Of 2020?
A.
Correct.
Q.
And can you please read item Number 1 below?
A.
Number of employees, 493.
Q.
So this is saying that he had had 493 employees in
January, February and March of 2020?
A.
Correct.
Q.
And can you please read Item Number 2?
A.
Wages, tips and other compensation.
Q.
And it's $11,366,813.09; is that correct?
A.
Correct.
Q.
And then there's federal income tax withheld from wages
and compensation.
How much did Kremkov Industries purportedly withhold
in federal income tax in the first quarter of 2020?
A.
$1,316,144.46.
Q.
And turning to Page 142, who is this signed by?
A.
Carl Torjagbo.
MR. EVERT: Let's turn to Page 143. And we'll zoom
at the top there.
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BY MR. EVERT:
Q.
And is this Kremkov's -- Kremkov Industries' quarterly tax
return for the next quarter?
A.
Correct.
Q.
So April, May and June of 2020?
A.
Correct.
Q.
Then let's look at -- a little bit below Item Number 1.
How many employees did Kremkov Industries have -- purportedly
have in the second quarter of 2020?
A.
493.
Q.
And did it pay them -- did it purportedly pay them
approximately $11.4 million in quarter two of 2020?
A.
That's correct.
Q.
And did it purportedly withhold approximately $1.3 million
in quarter 2 of -- sorry, strike that.
Did it purportedly withhold approximately
$1.3 million in federal income taxes in quarter 2 of 2020?
A.
Yes.
Q.
And now let's turn to Page 145. And I'll ask you who
signed this document.
A.
Carl Torjagbo.
Q.
All right. Now let's turn to Page 146. Is this
Kremkov Industries' quarterly federal tax returns for the next
quarter?
A.
Yes.
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Q.
What -- so what months is it for?
A.
July, August and September.
Q.
Of 2020?
A.
Correct.
Q.
And how many employees did Kremkov Industries purportedly
have?
A.
493.
Q.
And did it purportedly pay them wages, tips and other
compensation of 13 -- about $13.4 million?
A.
Correct.
Q.
And how much -- did it purportedly withhold approximately
$1.5 million in federal taxes?
A.
Correct.
Q.
And then turning to Page 148. Would you please read who
signed this?
A.
Carl Torjagbo.
Q.
Let's turn to Page 149. Is this Kremkov Industries'
quarterly federal tax return for the next quarter, quarter 4
of 2020?
A.
Correct.
Q.
And how many employees did Kremkov Industries purportedly
have in October, November and December of 2020?
A.
493.
Q.
And did it purportedly pay them wages, tips and other
compensation of about $7.8 million?
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A.
Correct.
Q.
And did it purportedly withhold about $892,000 from -- in
federal income taxes from their -- from their pay?
A.
Correct.
Q.
And then turning to Page 151. Who signed this?
A.
Carl Torjagbo.
Q.
Let's turn to Page 152. What is this?
A.
This is the annualized 940 form, so it adds all of those
941s together into one document.
Q.
And looking at Item Number 3, can you please read what
that is.
A.
Total payments to all employees.
Q.
And what is the total payment to all employees?
A.
$45,861,255.93.
Q.
And is that the same number as the total gross pay on
Page 122 that was reflected in those payroll journals that we
looked through earlier? We can -- we can check, too. That
should be Page 122.
A.
Yes.
Q.
Okay. So they're the same number?
A.
They're the same number.
Q.
And then -- and I've got a calculator for you there, if
you need it.
But is -- is 45 million, is that number divided by
12 -- would you do that number divided by 12, please. Could
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you -- could you read your answer?
A.
$3,821,771.20.
Q.
And looking at Page 1 of this document, of the
application, if you look at the average monthly payroll there,
is that about $1 more than the average monthly payroll?
A.
Correct.
Q.
And then if we could go back to -- I'm sorry. The
document we were at earlier was -- well, was that other
document -- was the analyzed 1040, was that also signed by
Carl Torjagbo?
A.
Yes.
Q.
All right.
MR. EVERT: I think this would be a good point for a
break, if that works.
THE COURT: Okay. That's fine. How about our
mid-morning break, 10 minutes, maybe 12 minutes.
Okay?
Depending on if we've got things to talk about. And
we'll be back at that time.
Okay. Thank you.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Okay. Anything y'all want to talk about?
MR. FINLAYSON: No, sir.
THE COURT: All right. We'll see you in about ten
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minutes.
(Whereupon, a recess was taken.)
THE COURT: Okay. Ready?
MS. CONNORS: Yes, Your Honor.
MR. EVERT: Yes, sir.
MS. CONNORS: If I may, we realized we had one issue
with one exhibit in our system, so I'm going to need to be
able to go back and forth between my computer.
So after this witness is done, if you wouldn't mind
giving us just a couple of minutes to be able to switch out.
THE COURT: That's fine. Yes.
COURTROOM SECURITY OFFICER: Are you ready?
THE COURT: Yes.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: Okay. Y'all can be seated.
Are you done with your examination?
MR. EVERT: Oh, no.
THE COURT: Okay.
MR. EVERT: I didn't realize the be seated didn't
apply to me, but I'll -- I'll come up.
THE COURT: And we're going to go until about 12:30
before we have our lunch break. Is that all right with
everybody?
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BY MR. EVERT:
Q.
All right. So I believe you testified on direct that in
support of the PPP application for Kremkov Industries,
Mr. Delano submitted a number of documents, including payroll
logs, Tax Form 941s, Tax Form 940 and a personal tax return;
is that correct?
A.
Yes.
Q.
And all documents submitted in support of the loan
application had to be accurate; is that correct?
A.
The applicants were required to certify the information
was true and accurate.
Q.
And they -- they, in fact, attested to Mr. -- Mr. Delano,
formerly Torjagbo, in fact, attested to that in his
application, correct?
A.
Correct.
Q.
And so I believe you mentioned that Chase focused on the
941 to support the date of the business operations; is that
correct?
A.
Yes.
Q.
But all of the -- all of the documents had to be accurate;
is that correct?
A.
Yes.
Q.
And if any of the documents -- if Chase had known that any
of the information in any of documents was inaccurate, would
it have approved the loan?
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A.
No.
Q.
Thank you.
MR. EVERT: So I'd like to put up Government's
Exhibit 101A, which is already in evidence.
BY MR. EVERT:
Q.
And so what is -- what is this document?
A.
This is a screenshot of our internal lending platform
called ApStar.
Q.
And looking at -- what does this document reflect?
A.
This indicates that Kremkov Industries applied digitally.
It has their contact information. It shows the SBA status is
approved. And it also has the date as being 2/19/21.
Q.
And is that the date that the loan was approved?
A.
Correct.
Q.
And who -- and turning to Page 2, can you -- there is a
lengthy paragraph that provides a number of certifications
that the -- that the applicant made; is that correct?
A.
This is specific to the lender certifications that are
required and they are based on the applicant's certifications.
Q.
Got it. So it says the applicant has certified to the
lender that it was in operation on February 15th, 2020,
correct?
A.
Correct.
Q.
And the answer to that is?
A.
Yes.
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Q.
Yes. And then there are a number of other certifications
as well as part of this document, correct?
A.
Correct.
Q.
Was it important to Chase that the answer -- that the
answers provided by the applicant to all of these questions
was accurate?
A.
Yes. That was the design of the program, for the
applicant to provide the certifications of the information,
validity in the application.
Q.
And turning to Page 3, could you please -- it should --
maybe it's Page 2. Oh, yeah. I'm sorry, yeah. The first
item, could you please read that?
A.
The applicant has certified that the principal place of
residence for all employees included in the applicant's
payroll calculation is the United States.
Q.
And what was the answer to that question?
A.
Yes.
Q.
If the answer had been no, would the loan have been
approved?
A.
No.
Q.
All right. Now I'm going to show you Government's
Exhibit 101B on the screen, please. This is already in
evidence. What does this document reflect?
A.
This shows the ApStar ID, which is basically the
associated coding that identifies this application. It has
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the timeline of the application being 2/16/2021. And then it
would have -- the far right shows the web session IP address
that was associated with that application.
Q.
So the date, the TRX normalized date time, was that
reflect -- what does that reflect?
A.
When the application was submitted.
Q.
By the applicant to Chase?
A.
Correct.
Q.
And then the web session IP address, can you explain what
that is?
A.
That's the applicant's IP address, so wherever they were
accessing the Chase systems, that would be their associated IP
address for their computer.
Q.
Got it. And I know you're not an expert on IP addresses,
but could you just provide the jury just a very high level
what is -- what an IP address is?
A.
Yeah. It's just an identifier to show the location of
like where your computer is located and how it's accessing the
systems.
Q.
All right. And then -- and was February -- that
February 16th, 2021 date, was that the same date that was on
the application that we -- that we reviewed?
A.
Yes, that's correct.
Q.
And then was that the only PPP loan application that
Mr. Delano, formerly known as Mr. Torjagbo, submitted on
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behalf of Kremkov Industries to Chase?
A.
No.
Q.
I'm showing you Government's Exhibit 102 which is already
in evidence. What is this?
A.
This was the previous application that was provided on
February 9th.
Q.
And so I -- you just answered my next question. But this
was provided -- this was submitted on February 9th; is that
correct?
A.
Correct.
Q.
If we go to Page 2, bottom of the page, same person
submitted this?
A.
Correct.
Q.
Karl Delano, formerly known as Carl Torjagbo?
A.
Correct.
Q.
And have you compared this application with the one that
was submitted on February 16th of 2021?
A.
Yes.
Q.
And that's the application that we already went over?
A.
Correct.
Q.
Were the two applications slightly different?
A.
Minimally, yes.
Q.
Yeah. Did the latter application -- the one -- the
February 16th one include a few additional documents?
A.
Yes.
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Q.
But apart from these minor differences, were the two --
were the two submissions substantially the same?
A.
Yes.
Q.
And was this 2/9, this February 9th, 2021 application, was
that approved?
A.
No.
Q.
I'm showing you Government's Exhibit 102A, which is
already in evidence. And then is this the ApStar for the
2/9/2021 application?
A.
Correct.
Q.
And can you please read the -- the top of the page?
A.
It was Kremkov Industries, LLC declined as of 2/16/2021.
Q.
Is that the same date that the first PPP application that
we looked at was submitted?
A.
Yes.
Q.
So it was the second PPP application he applied for with
Chase Bank, but it was the first one we together looked at?
A.
Correct.
Q.
Okay. So is it correct that the same day his first
application was denied, he submitted the second application?
A.
Yes.
Q.
And that second application was the one that was
ultimately approved?
A.
Correct.
Q.
And then turning to Page 11, are you able to tell why
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this -- why the first application was denied?
A.
The reviewer was -- were looking for additional documents.
Q.
Understood.
MR. EVERT: Can we please pull up 103, which is
already in evidence.
BY MR. EVERT:
Q.
What are -- what are the -- what does Government 103
consist of?
A.
This is a business signature card, which would be
associated with the checking account of Kremkov Industries.
Q.
And at the top of Page 1, where it says date opened, can
you please read that date?
A.
1/25/2021.
Q.
So that's the date that this account for
Kremkov Industries was opened?
A.
Correct.
Q.
And that's just a few weeks before Kremkov Industries
applied for the PPP loan; is that correct?
A.
Yes.
Q.
And then on Page 2, it says deposit and withdrawal
offeree -- deposit and withdrawal authorization and there is a
name below that. Can you please read the name? Yeah, it's
middle of the page, right before those lines. Yeah.
A.
Carl Torjagbo.
Q.
And were there any other names of individuals -- there was
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obviously the name of Kremkov Industries. But were there any
names of any other individuals associated with this account?
A.
No.
Q.
So was anyone other than Carl Torjagbo authorized to
conduct transactions using this account?
A.
No.
Q.
Did someone named Michael Lee have the authority to
conduct transactions in this account?
A.
No.
Q.
And then on Page 3, does it indicate who the person who
opened the bank account on behalf of Kremkov Industries was?
A.
Carl Torjagbo.
Q.
Was this -- did Carl Torjagbo have an additional account
at Chase?
A.
Yes.
Q.
Was it a personal credit card account?
A.
Yes.
Q.
Are the statements for that account contained in
Government's Exhibit 310? We don't need to pull it up, but --
A.
Yes.
MR. EVERT: So let's turn to Page 10 of Government's
Exhibit 103.
BY MR. EVERT:
Q.
Can you please read the amount of the last deposit on that
page?
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We may need to blow it up a little bit more.
A.
$9,554,425.
Q.
And what is the source of that money?
A.
The PPP loan.
Q.
And what is the date of that deposit?
A.
3/29.
Q.
Of 2021?
A.
Correct.
Q.
And so just a few weeks after the -- about -- I'm terrible
at math on the fly, but a handful of weeks after the loan
application, correct?
A.
Correct.
Q.
And then turning to Page 13, it says checks paid and then
amount $3 million. What does that mean?
A.
There was a check presented to this checking account for
$3 million.
Q.
And was the check going into the account or out of the
account?
A.
Out of the account.
Q.
And what is the date of that transaction?
A.
4/9/2021.
Q.
And turning to Page 14. What is that?
A.
That is an image of the check.
Q.
And who is the check from?
A.
Kremkov Industries.
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Q.
And is that from -- is it written off of
Kremkov Industries' Chase account?
A.
Correct.
Q.
And who is it written to?
A.
Kremkov Industries.
Q.
And what does it say on the for line of the check?
A.
Payroll.
Q.
So this is saying that the check is written for payroll?
A.
Correct.
Q.
And assuming that it had any payroll, could
Kremkov Industries have paid its payroll directly from its
Chase account?
A.
Yes.
Q.
Do other companies pay their payroll directly from their
Chase accounts?
A.
Yes.
Q.
Did Chase monitor the use of PPP funds on an ongoing
basis?
A.
Yes.
Q.
Why did it do that?
A.
It's part of just normal regulation for all money movement
within banks.
Q.
And on its face, would a check written for payroll using
PPP funds have raised any red flags for Chase?
A.
No.
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Q.
If instead there was a $1.6 million wire transfer to pay
for a home, would that have raised any red flags for Chase?
A.
Yes.
Q.
Why would that have raised red flags?
A.
That was not an eligible use of proceeds for the
PPP loans.
Q.
If instead there was a $300,000 payment for a Lamborghini,
would that have raised any red flags for Chase?
A.
Yes.
Q.
Why?
A.
Also not an eligible use of proceeds for PPP loans.
Q.
What about a $50,000 payment for a yacht, would that have
raised any red flags for Chase?
A.
Yes.
Q.
Why?
A.
Also not eligible to be used for PPP funds.
Q.
Was the $9.5 million PPP loan issued to Kremkov Industries
one of the larger PPP loans that Chase issued?
A.
Yes.
Q.
Did there come a time when Chase began to question the
accuracy of the information that had been provided in the
PPP loan application that was submitted by the defendant?
A.
Yes.
Q.
Did those questions arise before or after the loan had
already been paid out?
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A.
After.
Q.
Did those questions arise before or after the $3 million
check was drawn off of the account?
A.
After.
Q.
Based on the questions that Chase had, did there come a
time when Chase froze Kremkov Industries' account at JPMorgan
Chase?
A.
Yes.
Q.
And does freezing an account just mean that the defendant
would have been prohibited from withdrawing funds from the
account?
A.
Correct.
Q.
And do you know when the account was frozen, off the top
of your head? If you don't, that's fine.
A.
I don't remember.
Q.
But it was after this $3 million check?
A.
Correct.
Q.
Couldn't have -- couldn't have sent a check out of the
account -- couldn't have written a check for $3 million if the
account was frozen, right?
A.
That is correct.
Q.
So as a result of the questions that Chase had, did it
require Kremkov Industries to provide any additional
information to establish that Kremkov Industries was, in fact,
in operation as of February 15th of 2020?
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A.
Yes.
Q.
So I'm going to play Government's Exhibit 108, which is
already in evidence, but if we could just get a quick preview
of it so we can -- so you can provide the details on what it
is. And are you familiar with what Government's Exhibit 108
is?
A.
Yes.
Q.
What is it?
A.
It's a recording of a complaint lodged due to the freezing
of the account and the inability to access the funds in that
checking account.
Q.
And who -- who was calling to complain about the freezing
of the funds?
A.
Carl Torjagbo.
Q.
And do you know the date of this call?
A.
May 7th, 2021.
Q.
All right. So we'll play the call.
(Whereupon, the recording was played)
MR. EVERT: All right. So because nobody likes to be
on hold, let's skip ahead until the 15 minute and 14 seconds
mark.
(Whereupon, the recording was played)
MR. EVERT: All right. So we can end that there.
BY MR. EVERT:
Q.
On this call, was Mr. Delano, formerly Mr. Torjagbo, and
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the Chase representative discussing how he needed to submit
additional documentations about Kremkov Industries?
A.
Yes.
Q.
And was one of the documents he was told he could provide
an EIN letter dated before February of 2020?
A.
Yes.
Q.
Was another document he was told he could provide a bank
statement from another bank --
A.
Yes.
Q.
-- showing business activity?
A.
Yes.
Q.
And was another document he was told he could provide a
tax document that had been filed?
A.
Yes.
Q.
And all of that had to have been dated before February of
2020, correct?
A.
Correct.
Q.
And in response to this call, did Mr. Delano, in fact,
submit additional documents to Chase?
A.
Correct.
Q.
I'll show you Government's Exhibit 104, which is in
evidence.
And if you could please read the entry dated May 7th
of 2021.
A.
EIN letter and tax returns scanned to KYC.
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Q.
And what is KYC?
A.
Know your customer.
Q.
And is that a department at Chase?
A.
It's a federal regulation around authentication of
individuals and businesses.
Q.
And February 7th of 2021, is that the same date as that
telephone call we just listened to?
A.
Yes.
Q.
And so the additional documentation that he provided, it's
an EIN letter and a tax return; is that correct?
A.
Yes.
Q.
Okay. So I'm showing you -- I'm going to show you
Government's Exhibit 106, which is already in evidence. What
is this?
A.
That's an IRS EIN letter.
Q.
So what is this letter -- you don't have to read it word
for word, but what is it -- what is it saying?
A.
It is sent to businesses when they're applying for an EIN
number, which is tied to tax payments.
Q.
And is this a notice from the IRS -- or does this purport
to be a notice from the IRS saying that a particular EIN was
assigned to Kremkov Industries?
A.
Yes.
Q.
So looking at the name at the top there, that says
Kremkov Industries, right?
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A.
Yes.
Q.
And then date of the notice, can you please read that
date?
A.
9/1/2018.
Q.
And then could you read the employer identification
number?
A.
83-182-1377.
Q.
And I lost it. All right. All right. Can we turn to
Government's Exhibit -- so does this letter purport to show
that -- that that EIN number was issued to Kremkov Industries
on January -- on September 1st of 2018?
A.
Correct.
Q.
And this supposedly came from the IRS, right?
A.
Yes.
Q.
And Mr. Delano, formerly known as Mr. Torjagbo, submitted
this in an effort -- in response to the call about his account
being frozen?
A.
Correct.
Q.
Was the -- in order to get his account unfrozen?
A.
Yes.
Q.
All right.
MR. EVERT: And then let's turn to Government's
Exhibit 107, which is already in evidence. And we can zoom in
at the top there so we can read it a little bit better.
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BY MR. EVERT:
Q.
Was this also submitted by Mr. Delano?
A.
Yes.
Q.
In response to the call about needing to submit additional
documentation?
A.
Yes.
Q.
Because Kremkov Industries' account was frozen?
A.
Correct.
Q.
And what does this document purport to be?
A.
Carl Torjagbo's personal tax return from 2020.
Q.
And when was this -- when did he submit this to Chase?
A.
5/7/2021.
Q.
Okay. And turning to Page 5, below where it says income
or loss from a partnership or S corporation, can you please
read the company on line A, just right up there.
A.
Kremkov Industries.
Q.
And what is the employer identification number identified
for Kremkov Industries on this form?
A.
83-182-1377.
Q.
Okay. And did Karl Delano, formerly known as
Carl Torjagbo, submit -- also submit his 1040 as part of the
February 16th, 2021 PPP application?
A.
Correct.
MR. EVERT: Let's pull up Government's Exhibit 101,
which is already in evidence, and pull that up side by side
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with -- with this page. 125. Thank you. Perfect.
BY MR. EVERT:
Q.
And so is this -- does this purport to be his 2020 -- the
2020 1040 for Carl Torjagbo?
A.
Yes.
Q.
So the one on the right is the one that he submitted in
connection with his February 16th loan application. And the
one on the left is the one he submitted when he was trying to
get his account unfrozen, correct?
A.
Correct.
MR. EVERT: And then if we turn to Page 129 of 101,
so we're looking at the same page of what should be the same
document. Below the line, if we could blow up for both
documents Item 28.
BY MR. EVERT:
Q.
So for document on the left, which is what was submitted
on May 7th, 2021, is the employee identification number
83-182-1377?
A.
Correct.
Q.
And for the document on the right, which is what he
submitted in January, on January 16th of 2021, is the
document -- is the employee identification -- employer
identification number for Kremkov Industries 86-134 -- sorry.
Is the employer identification number 86-134-7540?
A.
Yes.
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Q.
So these are -- and when -- when documents were submitted
in connection with a PPP loan, they were supposed to be
documents that were actually filed with the IRS, right?
A.
Yes.
Q.
And so these are both supposed to be Carl Torjagbo's 2020
Form 1040, correct?
A.
Correct.
Q.
And are the EIN numbers submitted on these two different
forms, which were submitted on two different dates, the same?
A.
No.
Q.
So these are -- they're -- they're different EINs for
Kremkov on the two forms?
A.
Correct.
Q.
And did Government's Exhibits 106 and 107, which were the
exhibits we just discussed that were submitted on May 7th, did
those both purport to show that Kremkov Industries was in
operation as of February 15th of 2020?
A.
Yes.
Q.
Despite the submission of these additional documents, did
Chase ultimately freeze Kremkov's account?
Or, I'm sorry, did Chase ultimately unfreeze
Kremkov's account?
A.
No.
Q.
So did the document provide sufficient proof to show that
Kremkov Industries was, in fact, eligible for a PPP loan --
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for the PPP loan that the bank had issued him?
A.
No.
Q.
Turning to Page 15 of Government's Exhibit 103. And
Government's Exhibit 103 is the bank records for
Kremkov Industries' Chase Bank account, correct?
A.
Yes.
Q.
So if we look at the other withdrawals --
MR. EVERT: Can we blow that up, please? Thank you.
BY MR. EVERT:
Q.
So there's an entry -- or there's only one entry, and it's
dated 5/18. Can you describe what this is?
A.
This is the amount of the funds that the bank clawed back
from the account.
Q.
So it's -- and can you read the amount that the bank
clawed back?
A.
$6,554,515.
Q.
And then the same date -- and the date, which is 5/18 of
2012, correct?
A.
Correct.
Q.
The daily ending balance that day, what was the balance?
A.
Zero.
Q.
So the bank clawed back all of the money in the account,
correct?
A.
Correct.
Q.
And what does it mean to clawback money?
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A.
Remove the money from the account.
Q.
Why did Chase clawback the money?
A.
Determined that the loan was not eligible.
Q.
And on your -- and then showing you Government's
Exhibit 104, which is already in evidence. Turning to Page 3,
what is this?
A.
This is an account closure letter.
Q.
And what is the date of this letter?
A.
August 10th, 2021.
Q.
And can you please read the first three lines of this
letter, starting with important information.
A.
Important information. We have decided to close your
account, Dear Kremkov Industries, LLC, after a recent review
of your account, we have decided to end our relationship with
you.
Q.
Thank you. And was that the only account belonging to
Carl Torjagbo, now known as Karl Delano, that Chase decided to
close?
A.
No.
Q.
Turning to Government's Exhibit 310A, which is already in
evidence, what is this?
A.
This is a screenshot from our customer assist program that
outlines relationship information.
Q.
And does this relate to Mr. Delano's credit card with
Chase?
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Q.
Yes. It does.
Q.
Turning to Page 3, what is this?
A.
This is an account closure letter for a credit card.
Q.
Okay. And can you please read the paragraph that begins
after careful consideration?
A.
After careful consideration, we decided to close your
credit card account on September 8th, 2021, because Chase
closed a previous credit card deposit or investment account.
Q.
And I want to show you Government's Exhibit 105, which is
already in evidence. If we could please go to Page 3. And
then what is this letter?
A.
This is a default letter.
Q.
And can you explain what that is?
A.
So if payment is not made when it is due, the borrower is
sent a letter notifying of that default.
Q.
So -- so this loan to Kremkov Industries, it says the
amount -- it says we are writing to let you know that your
loan is in default and now due in full. Please pay the
principal amount of $2,999,910 immediately plus accrued
interest and -- accrued and accruing interest and any costs
and fees.
Now that -- that $2.9 million number, what does that
represent?
A.
That represents what was outstanding on the PPP loan.
Q.
And is that the amount that Chase was unable to claw back
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from Kremkov Industries' bank account?
A.
Yes.
Q.
The $3 million check minus $90, if my math is correct?
A.
Yes. If your math is correct, yes.
Q.
Did Kremkov Industries or Karl Delano, formerly known as
Carl Torjagbo, ever pay back the remaining nearly $3 million
that was due on the loan?
A.
No.
Q.
Does -- did Chase ever receive any indication from
Mr. Delano that he was attempting to pay -- pay back that
money?
A.
Not that I'm aware of.
Q.
Did SBA ultimately forgive this loan?
A.
No, they did not.
MR. EVERT: No further questions. Thank you.
THE COURT: Could y'all step out for just one moment,
please.
COURTROOM SECURITY OFFICER: All rise.
THE COURT: It's just going to be a minute. Okay?
(Whereupon, the jurors exited the courtroom.)
THE COURT: Y'all can be seated.
What was that wailing, do you know?
MARSHAL: It was a family member from another
courtroom.
THE COURT: Okay. All right. It's all over with?
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MARSHAL: I believe so. They escorted them out.
THE COURT: Okay. I saw some of those folks getting
distracted. I just wanted to make sure that it wouldn't
happen again.
All right. You can bring them back in.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: Okay. Y'all can be seated go ahead.
MR. FINLAYSON: If I can have Page 101C -- or
Exhibit 101C, Page 105.
CROSS-EXAMINATION
BY MR. EVERT:
Q.
And, ma'am, do you recognize that document?
A.
Yes.
Q.
And can you tell the jury what it -- tell the jury what it
is?
A.
This would be a commercial loan invoice.
Q.
And what's the account number?
A.
Can you make it a little bit bigger?
Q.
I'm sorry? For the -- how about this, this is for the
PPP loan; is that fair?
A.
Yes.
Q.
Okay. And what -- and the statement date there is -- it
looks like April 29th, 2022?
A.
Correct.
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Q.
I'm going to hand you up what's marked Defendant's 2 and
Defendant's 3 and see if you can, based on that, recognize
these. Do you recognize them? They seem to be from the same
account, same account number.
A.
Yes.
Q.
Okay. And they're just later -- they're July and August
of '22 statements, right?
A.
Correct.
MR. FINLAYSON: Your Honor, I would move in
Defendant's 2 and 3.
THE COURT: Any objection to 2 and 3?
MS. CONNORS: No objection.
THE COURT: Okay. Defense 2 and 3 are admitted.
MR. FINLAYSON: Thank you.
BY MR. FINLAYSON:
Q.
Ma'am, if you could look at 2. And that's the July
statement, correct?
A.
Yes.
Q.
And that is the PPP loan we've been talking about here
today, right?
A.
That is correct.
Q.
And what does it show there, the balance on the account as
of July 2022?
A.
The balance is $2,999,910.
Q.
And on the first page, what does it say -- what is the
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payment amount due in July of 2022?
A.
In July of '22, it was zero.
Q.
Okay. And the -- and that is consistent with the payments
being deferred on the PPP loans, right?
A.
That is correct.
Q.
And if you look at the next one, Defendant's 3, that's the
following month's statement, right?
A.
That is correct.
Q.
And it's probably got the same balance, I'll bet?
A.
Correct.
Q.
Okay. And on the front page, that actually shows a
payment due, right?
A.
That is correct.
Q.
Okay. And that shows his first payment is due on what
date?
A.
8/29/22.
Q.
8/29/22 is when the first payment is due, right?
A.
That is correct.
Q.
And then you just testified earlier about a default notice
that went out from the bank in December of 2022, right?
A.
I don't recall the date, but yes.
Q.
Okay. Do you know whether Mr. Torjagbo -- I can't say it,
Mr. Delano, that's why we do that, Mr. Delano, do you know
where he was in August of 2022?
MR. EVERT: Objection.
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THE COURT: Overruled.
The question is do you know where the defendant was
in August of 2022?
THE WITNESS: I don't.
BY MR. EVERT:
Q.
Do you know why he didn't make a payment in August of
2022?
A.
I don't.
Q.
Did you talk to him about it at all?
A.
No, I did not.
Q.
Have you ever talked to Mr. Delano?
A.
I have not.
Q.
Thank you. All right. You mentioned that the bank clawed
back money, right?
A.
Yes.
Q.
So the bank clawed back like 6.5 million?
A.
Yes.
Q.
And so the amount due in August of 2022, was just under
$3 million, right?
A.
Correct.
Q.
Now, you don't know where that $3 million went, do you?
A.
No, I don't.
Q.
You were asked a series of hypothetical questions, like
well, if you bought a house with that, with that money, with
that $3 million PPP loan, that would be bad, right?
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A.
That's correct.
Q.
Or if you bought a car with that PPP money, that would be
bad?
A.
Correct.
Q.
What was the other one. If you started a new business
with that PPP money, that would be bad, correct?
A.
Correct.
Q.
Now, if you bought a house with your tax return or your
own money, not PPP money, that doesn't violate the PPP rules,
does it?
A.
That's correct.
Q.
Okay. And if you buy a car with tax return money or your
own income money, that doesn't violate PPP, right?
A.
Absolutely not.
Q.
Okay. And the same with starting a new business, correct?
A.
Correct.
Q.
Okay. So if I understand right, you -- Chase was an
authorized lending institution for the PPP program?
A.
Correct.
Q.
And that was sort of governed by the SBA and the federal
government?
A.
Correct.
Q.
You guys were the lender, right?
A.
Correct.
Q.
But that money was guaranteed by the government?
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A.
Correct.
Q.
So you guys -- it sounds like a whole new department
opened up, I assume?
A.
We pivoted from traditional lending to PPP.
Q.
Okay. So you got -- you guys -- you guys didn't do this
for free, right?
A.
No.
Q.
Okay. You were paid -- the bank made 1 percent of the
loan amount, right?
A.
I'm not exactly sure the exact -- there was -- there was
some fee income. I don't know the percentage myself.
Q.
Okay. Does 1 percent sound unusual or unreasonable?
A.
No, that -- I just don't know the exact amount.
Q.
1 percent can -- 1 percent of $9.25 million is $95,000.
Does that sound right?
A.
Yes.
THE COURT: That sounds right that that's the amount?
THE WITNESS: That sounds like 1 percent.
THE COURT: Okay.
MR. FINLAYSON: No. Thank you.
BY MR. EVERT:
Q.
And we have a calculator, I guess. You don't disagree --
I think that's right. 1 percent of $9.5 million is $95,000?
A.
Correct.
Q.
Somebody correct me if I'm wrong.
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So the bank processes the applications for PPP loans,
right?
A.
Correct.
Q.
And there is a -- there may be not as much as a
traditional loan, but there is level of diligence that is
required by the bank in that process, right?
A.
Yes, there was a review process required.
Q.
And, in fact, you -- the first loan or application that
Mr. Torjagbo sent in, it was rejected, right?
A.
That is correct.
Q.
So y'all are looking at these documents, right?
A.
Correct.
Q.
Okay. And you mentioned the first one was rejected
because maybe there was a problem with the payroll
information?
A.
There was something missing from the application.
Q.
You said -- did you say payroll information or was that
somewhere -- no?
A.
No.
Q.
Okay. So subsequently, there is a phone call that we
heard played, the Government's 108, that call?
A.
Correct.
Q.
And Mr. Torjagbo was saying, hey, why is my -- why is my
account frozen, correct?
A.
That's correct.
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Q.
And the person on the phone is -- puts him on hold for
several minutes, ten minutes, and can't quite give him an
answer why; is that fair?
A.
That's fair.
Q.
And then ultimately, she said, well, you have to -- when
she came back on, she said you have to submit some more
documents?
A.
Correct.
Q.
Okay. And in that call, Mr. Torjagbo is saying -- he's
grumpy because he's like I've got to repay this money. And if
you're going to hold it, I want that written in writing
somewhere so I don't have to repay what I didn't get. Is that
a fair synopsis?
A.
Correct.
Q.
He says I'm going to repay it, but I don't want to pay for
what I didn't get. That's the tenor for why he's complaining;
is that fair?
A.
Yes.
Q.
Okay. Now, there is -- the PPP program did have a
forgiveness option available, right?
A.
That's correct.
Q.
And many people in this country had their PPP loans
forgiven, correct?
A.
Correct.
Q.
Didn't have to pay them back?
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A.
That's correct.
Q.
But Chase Bank, when there was forgiveness, you didn't
lose money, did you, Chase Bank?
A.
For forgiveness?
Q.
Yes.
A.
No. It would -- the government -- the SBA would pay the
funds --
Q.
Okay.
A.
-- to pay off the loans that were with Chase --
Q.
Okay.
A.
-- for those PPP loans.
Q.
And if there's a default, I assume the government also
repays Chase.
A.
Yes, just like in our traditional SBA lending, there is a
guarantee associated with these loans.
Q.
Okay. So you didn't -- you guys didn't lose any money on
this?
A.
I can't say for certain all of the logistics of the
program.
Q.
Okay. Do you know if -- if the -- if the fees to
Chase Bank were based on the original approved amount, but
then there was a clawback, did that fee go down or do you
know?
A.
I don't know.
Q.
You don't know, okay. You mentioned that in approving the
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PPP loan -- and these are all looped together or lumped
together, there were sort of three things that were relied
upon. There was 941 forms, correct?
A.
Correct.
Q.
There were payroll documents, correct?
A.
There were payroll documents as part of the application,
yes.
Q.
And that's the list of the employees. Is that what we're
talking about?
A.
Yes.
Q.
Go ahead.
A.
Chase relied on the 941 forms, but there were other
documents as part of the application.
Q.
Well, when he asked you the question earlier, they got
lumped together. It was 941 forms, payroll documents and
personal tax returns.
A.
That was all provided as part of the application, correct.
Q.
And those were all relied upon by Chase in approving the
loan, right?
A.
No, we used the 941 forms as part of our review.
Q.
So you didn't rely on the payroll documents at all?
A.
We used the 941 tax forms.
Q.
So the list of employees, the 493 names, you didn't rely
on that at all?
A.
I can't speak to what the reviewer looked at as part of
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the review. But what was documented as our review was using
the 941 forms.
Q.
Okay. So you -- you didn't actually do any of this; is
that fair?
A.
I reviewed applications. I didn't review this
application.
Q.
You didn't review this application?
A.
Correct.
Q.
So you don't really know what that person relied on?
A.
Well, we do have documentation of what documents were
utilized to make the calculation to support the payroll
amount.
Q.
Who did approve -- who was the person that reviewed these
documents?
A.
It was in a prior screen. Louis Glauser was the credit
officer who approved this transaction.
Q.
I'm sorry, what's the last name?
A.
Glauser.
Q.
Can you spell that for us?
A.
I don't exactly know how to spell it, but it is in one of
the exhibits.
Q.
So Louis Glauser looked at this application and was the
person that decided to grant it or not?
A.
That is correct.
Q.
Was he the person that did the -- rejected the earlier
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one?
A.
I don't know.
Q.
So you're just sort of looking at internal documents after
the fact; is that fair?
A.
That's fair.
Q.
Okay. Did you know when this loan was going out? Did you
review it at all?
A.
I did not review it at time of originations.
Q.
Okay. We talked about forgiveness a little bit.
There was a deadline in the program for when
borrowers could ask for forgiveness, right?
A.
That is correct.
Q.
And letters were sent out to all the borrowers saying,
hey, if you want forgiveness, now or never, it's the time to
ask; is that right?
A.
I'm not specifically aware of the outreach around the
communication for that. I can't -- I can't speak to that. I
wasn't part of that process.
Q.
Okay. But you do know there was a deadline?
A.
I am very aware of the deadline, yes.
Q.
Okay. And is it -- were the borrowers told about the
deadline?
A.
It was part of the note document, so they were told.
Q.
Okay. And if they were told about the deadline, if they
opted in for forgiveness, they could, but if they didn't opt
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in, they had to repay the money?
A.
Correct.
Q.
Okay. Have you reviewed the list of employees, the
payroll list at all?
A.
I have.
Q.
Okay. You've seen the names on that list?
A.
I have.
Q.
Okay. Like Charlie Brown?
A.
Yes.
Q.
Isaac Newton?
A.
Yes.
Q.
Oliver Twist?
A.
Yes.
Q.
John Snow? John Snow?
A.
I don't remember that one specifically.
Q.
James Brown?
A.
Yes.
Q.
Nancy Drew?
A.
I don't remember that one.
Q.
Colin Farrell? Daniel Glover?
A.
I don't remember that one in detail.
Q.
Gene Hackman?
A.
Yes, I do remember that one.
Q.
Bless his soul.
A.
Edwin Moses.
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A.
I don't remember that one.
Q.
Keanu Reeves.
A.
Yes, I remember that one.
Q.
Bruce Willis?
A.
Yes, I remember that one.
MR. FINLAYSON: Those are all my questions, Judge.
THE COURT: Any redirect?
MR. EVERT: Yes. So a few questions, please.
If we could please pull up Page 81 of Government's
Exhibit 101.
REDIRECT EXAMINATION
BY MR. EVERT:
Q.
Let's just take a look at some of these pages.
These are -- there is a list of the employees that
the defendant submitted in support of the PPP loan
application, correct?
A.
Yes.
Q.
Do you recognize any of the names on this page?
A.
No.
Q.
How about the next page?
A.
No.
Q.
How about the next page?
A.
No.
Q.
How about the next page?
A.
No.
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Q.
So we're looking through -- so there were 42 pages of
annual payroll submitted. If you look at the top right of
this document, that will help.
A.
Yes.
Q.
And there were -- if we look at Page 80, we'll be able to
see that there are 71 pages of February 2020 payroll
submitted?
A.
Yes.
Q.
So there were some names that you recognized on this list?
A.
Yes.
Q.
And -- but there were a lot of other names that you
didn't -- that aren't recognizable on this list, correct?
A.
Correct.
Q.
And was the point -- what was the point -- what was -- was
speed of the essence when it came to the PPP program?
A.
Absolutely.
Q.
Why was speed of the essence?
A.
Because of the -- how quickly the pandemic was impacting
the economic environment of the country and potentially
businesses and their ability to pay their employees.
Q.
And what -- did SBA, in fact, require Chase to work
quickly on these -- on these applications?
A.
Yes.
Q.
And under the SBA regulations, was -- was Chase required
to look at every one of these names of all these people and
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call them?
A.
No.
Q.
Was Chase required to go to the IRS and see, hey, has
anyone named Nick Wyllys paid -- had Social Security taxes
paid or anything like that?
A.
No.
Q.
The point was to get the money out to the small businesses
as quickly as possible?
A.
Correct.
Q.
And the applicants had to certify that the information
they were providing was correct, right?
A.
Yes.
Q.
So the clawback occurred before the forgiveness deadline;
is that correct?
A.
Yes.
Q.
And the account was frozen before -- before the -- before
the loan was in default; is that correct?
A.
That's correct.
Q.
And nothing about the defendant's decision to ask for
forgiveness or not impacted the clawback; is that correct?
A.
That's correct.
Q.
Yeah, I believe defense counsel said on cross-examination
that in that recording, Government Exhibit 108, the defendant
said I am going to repay the loan.
Did he say that on that call, those -- use those
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exact words?
A.
I don't recall.
Q.
As a result -- what -- as a result of this -- of this
loan -- the loan was in default for approximately $3 million;
is that correct?
A.
Correct.
Q.
Was that money ever forgiven by the SBA?
A.
No.
Q.
So did Chase lose that -- Chase is out that money; is that
correct?
A.
That is correct.
Q.
And I believe you testified that based on the documents
you've seen, it looks like what -- what Chase specifically
relied on in confirming the eligibility date -- or confirming
that Kremkov was in operation as of February 15th, 2020, was
the 941 form, correct?
A.
No, they used the February payroll document.
Q.
Oh, they used the February payroll document.
And that is the document that includes -- that
document includes Charlie Brown?
A.
Correct.
Q.
Does it include Keanu Reeves?
A.
I believe so.
Q.
Does it include Bruce Willis?
A.
Yes.
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Q.
So Chase did rely on that February 2020 payroll document
in -- in its decision to approve this loan?
A.
Yes.
Q.
And all of the documents submitted, if Chase had known
that there was false information in there, would it have, in
fact, approved the loan?
A.
No.
MR. EVERT: No further questions. Thank you.
THE COURT: May the witness be excused?
MR. FINLAYSON: She may.
THE COURT: Thank you very much.
All right. Call your next witness.
MS. CONNORS: Your Honor, I mentioned we might need
just a couple of minutes.
THE COURT: Do you want the jury to step out while
you do it?
MS. CONNORS: That probably would be good.
THE COURT: Okay. Five minutes. I'm not even going
to get up.
(Whereupon, the jurors exited the courtroom.)
MS. CONNORS: Okay. Thank you so much, Judge. I
think I'm good.
THE COURT: All right. Let's bring them in.
Around 12:30-ish, if you get to a good stopping
point, I'm not a stickler either way.
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MS. CONNORS: Okay.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. You can be seated.
Call your next witness, please.
MS. CONNORS: Thank you, Your Honor.
The United States calls James Davis.
- - -
JAMES DAVIS,
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 for the record.
THE WITNESS: James Howard Davis, J-A-M-E-S,
H-O-W-A-R-D, D-A-V-I-S.
COURTROOM DEPUTY: Thank you.
DIRECT EXAMINATION
BY MS. CONNORS:
Q.
And, Mr. Davis, there you go. I was about to say if you
could scoot up a little bit, we should be able to hear you.
Good afternoon. Can you tell us where you're
currently employed?
A.
I work for Intuit, Incorporated.
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Q.
Okay. And how long have you been with Intuit?
A.
About -- approximately 13 years.
Q.
Okay. And what is your position with Intuit?
A.
I'm an applications operations engineer, senior
applications operations engineer.
Q.
Um-hmm. Now, prior to starting with Intuit, what field
were you in?
A.
I had an information technology background.
Q.
Okay. Now, Mr. Davis, you work for Intuit.
Is there a particular tax product that Intuit puts
out or makes available to individuals?
A.
My position at Intuit is I administrate and manage the
electronic filing engine. And all of Intuit's tech products
use that electronic filing engine to submit returns to state
and federal agencies.
Q.
Okay. And is TurboTax one of the filings -- or a system
for filing with Intuit or --
A.
It is.
Q.
Okay. So can you kind of give us a general idea of how
that process would work of using TurboTax?
And then you indicated there is an electronic filing
engine that you specifically work with?
A.
Yeah. The process -- where I'm involved is -- is once the
customer submits the filing. But so you're in your tax
application, TurboTax, we're talking about. And when you're
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finished doing the final part of that application, you're
going to end up after -- after digitally signing it and that,
you're going to hit the submit button. And that's when it
goes to the electronic filing engine.
At that time, your return has been -- the return has
been completed by the customer, they've -- they've filled out
all the information on it. They hit that submit button and it
sends it to the electronic filing engine.
And at that time, that filing is first going to go
through some -- some checks to make sure it's -- it's got the
correct format, it's got the correct data per preset
instructions for that. And it's going to -- it's going to be
able to kick that back to the customer if there's something
missing really quick, and they can fix that.
If everything passes that, it's going to go through
the electronic filing engine and it's going to be changed into
the format that the state or federal agency wants that
electronic data to be trans -- transmitted in.
Q.
Okay.
A.
That process is pretty quick. There is -- there is some
conversion of that data before it's transmitted and then it's
batched and sent to the agency.
Q.
And when you refer to agency, would the IRS be one of
those agencies?
A.
IRS is one of the agencies, yes.
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Q.
Okay. Now, before I move on, I want to try to backpedal
just a little bit.
So before there is the actual submission of the tax
filing and you're in the actual TurboTax application, is that
going to be based on user data or user input for the
information?
A.
Yeah. As the customer uses the product, you know, it's
designed to help you fill out these forms, the state and
federal forms and others.
And the customer is going to input the data required.
This -- the tool itself is -- helps you walk through that
process. There's various versions of getting your data. You
can be manually entering it or you can -- you can have it
exported and imported into TurboTax.
All of that process is managed by the customer. And
the customer has to review it and look at it. But there is
some -- some pieces of it where you can get the data entered
that way.
Q.
Now, when you talk about importing that data, is it that
TurboTax is directly linked to, say, an IRS system to where
you could just put in either your name or your social and it
will immediately pull in any data?
A.
No, that's -- it's a little different than that. TurboTax
has the ability to connect with the customer's accounts that
they have, their systems, and the customer logs themselves in,
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essentially using TurboTax. And then can -- like with ADP or
another payroll service, can download their W-4 and get that
data. But that's a -- that's a manual process that the
customer initiates and manages within the TurboTax
application.
Q.
Okay. And that would be -- you mentioned like ADP, a
third-party processer, more -- is it on the side of like
private companies --
A.
Yeah, I --
Q.
-- that you would be able to import your data from?
A.
Yeah, external company. Yeah, it's not associated with
Intuit. But, yes, they would use their own account to log
into that and export data.
Q.
Okay. And just to be clear, TurboTax does not link
automatically with, say, Social Security's databases and
systems and it doesn't link directly with IRS databases and
systems for purposes of putting information into the tax
return?
A.
That's correct.
Q.
So in terms of the information that gets listed in a tax
return, is that going to be input by the user or if they're
going to import, it's still the user who has to do that
import?
A.
Yeah. And the software would prompt the user also to
review the data that's imported. It's -- it's -- that's part
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of the steps as you're going through the application.
Q.
Okay. Is that essentially to ensure accuracy of the
return?
A.
Absolutely. And to make sure that the customer is aware
of the data that was inputted.
Q.
Okay. And then you mentioned there could be some prompts
along the way to assist with filling out the form?
Would that be like, for example, if someone says that
they are a business owner, would it possibly -- would Intuit
have maybe questions or something to try to determine what
potential tax forms needed to be filed?
A.
Correct. And the application itself is trying to help
you, you know, do your return correctly, your returns
correctly, so, yeah, there's prompts and that to assist you in
finding the right forms and making sure that you complete the
process correctly.
Q.
Okay. And you mentioned a few moments ago about
electronically signing the tax filing. How does that happen
through TurboTax?
A.
When you're -- when you're at the end of the process
before you submit it, you're required to produce an ID and
your pin to be able to submit to the IRS. That's an IRS
requirement. And TurboTax facilitates that.
Q.
Okay. Do you mean that for an electronic tax return, IRS
has that requirement?
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A.
Correct.
Q.
And it's TurboTax, since you're going to be submitting the
returns to the IRS and potentially other agencies, you're
meeting their requirements, is that what's happening?
A.
That's -- that's what's happening. That's an IRS
requirement to be able to submit to their systems.
Q.
Okay. And along the way in the data being filled out or
the information being entered into the tax filing through
Intuit, Intuit -- or I should refer to TurboTax, TurboTax is
not independently checking for accuracy of that data?
A.
There's no way for TurboTax to know the accuracy of the
data. That's why the customer is required to look through the
data and make sure that it's accurate.
Q.
Okay. Now, you mentioned that once the tax return is
submitted by the user, it goes through this additional
process. Is that kind of strictly behind the scenes from the
customer?
A.
Yeah. It's -- that's part of the electronic filing engine
doing the different things that have to be done after the
return is filed. Part of it is reviewing it for errors, part
of it is making sure that it's meeting the state and federal
agency requirements to be in the right format and configured
correctly. And then it has to be prepared to be able to be
submitted. And that's -- that's a process of grouping filings
together and then sending them off to the agency.
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Q.
Okay. Now, in terms of once that filing is transmitted to
the agency, is the TurboTax system or the EF -- the electronic
filing engine still kind of monitoring that return, if you
will?
A.
Yeah. We -- we constantly check for the acknowledgment
from the -- from the IRS for -- for filings. And they give
acknowledgments in batches, large batches of filings. And
we -- we check consistently and those are retrieved from the
IRS.
Q.
Okay. Now, what exactly is the acknowledgment that you're
looking for?
A.
The acknowledgment is going to come back as succeeded,
meaning that the return was accepted by the IRS, or rejected,
and if it's rejected, it's going to have an error associated
with it. The IRS is going to return a very clear error for
what's wrong with it and that will -- those are the two
responses.
Q.
Okay. So let's talk about if a return is rejected by the
IRS or by an agency. Would TurboTax relay that information?
A.
Yes. TurboTax, depending on the error from the agency,
TurboTax is going to give a response to the customer with the
information on how to solve the problem, how to fix the
return. That's -- that's the most common one.
The other -- the other thing that can happen is there
will be an error from the IRS in this case that is unknown,
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the error is not known. And that will go into a system where
the content folk will review it first and see what the error
is and then help the customer take action.
Or possibly it's something that our system created
and we can actually fix the error and return the filing to the
IRS, resubmit it.
Q.
Okay. So in terms of what TurboTax or Intuit would kind
of fix in terms of errors, what would be some examples of
those?
A.
Where the -- our system -- maybe there's a timestamp
issue. I'm just guessing here. But there -- we don't get
this very often, but there could be a problem with our system.
Maybe our -- one of our system IDs wasn't accepted. And it
could come back with an error on that and we can just
retransmit it quickly, even though it did have an error, a
transmission error, so that's the most common.
Q.
Okay. So is that kind of like a technical error --
A.
Yeah, it's --
Q.
-- or something that prevented the transmission?
A.
Correct.
Q.
Now, if it's an error that is specific to the information
in the tax return, is that going to have to go to the user to
fix that error?
A.
Yeah. The user is going to be responsible for changing
the data in their return, if that's what -- if that's what the
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error implies.
And that gets kicked back to the user with
information, maybe a link to a support answer where they could
walk -- where you could get walked through the solution. Or
maybe even you might be called by a support representative,
depending on the issue.
Q.
Okay.
A.
To help.
Q.
And so TurboTax may assist in terms of walking through the
correction, but would it be the user that had to actually
input the correction if it is an issue of some type of data or
information in the return?
A.
Yes.
Q.
And in terms of the rejection, I think you've mentioned
TurboTax is going to relay that.
Are they also trying to give, you know, pretty good
information about what's wrong?
A.
Yeah, a lot of the errors, the information is known
information that can be, you know, given easily in an email
and inside the app.
Q.
Okay. And so you just mentioned email, is that -- and
also the app, is that typically how any kind of error would
be -- or error information would be relayed to the user?
A.
Yes.
Q.
Okay. And in terms of an accepted filing, is -- is the
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customer notified by TurboTax if the return goes through?
A.
Yes.
Q.
And, Mr. Davis, if you would look at -- you already have
one exhibit on the screen, because that's a little easier to
look at. That is Exhibit 220. There should also be a binder
in front of you for some additional exhibits.
MS. CONNORS: And may I approach, Your Honor?
THE COURT: You may.
BY MR. EVERT:
Q.
And, Mr. Davis, in that binder, you would see Exhibits 221
through 228. And there's tabs on them.
Can you just briefly look at those and let me know if
you recognize those documents.
A.
These all appear to be 1040 forms.
Q.
Okay. And specifically, are they documents related to
filings that went through TurboTax?
A.
I'd have to correlate them, but that's what -- these just
look like 1040 forms to me.
Q.
Okay. Prior to your testimony today, did you have an
opportunity to look at these exhibits, Exhibits 220 to 228?
A.
In the -- in the information we provided in the Excel
spreadsheet.
Q.
Yeah. And based on that, are -- did Intuit -- were there
filings with TurboTax?
A.
Yes.
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Q.
Okay.
MS. CONNORS: Your Honor, I would move to admit
Government's Exhibits 220 to 228.
THE COURT: Any objection to 220 to 228?
MR. FINLAYSON: No objection.
THE COURT: Okay. They are admitted.
MS. CONNORS: Okay.
BY MS. CONNORS:
Q.
And Mr. Davis, I am going to be have you look at 220
first.
MS. CONNORS: And, Ms. Kelley, could you turn on the
podium? Or, I'm sorry, is it already on?
THE COURT: The jurors?
MS. CONNORS: Yes, yes. Oh, I see it on his screen,
but I don't see it on the back one.
THE COURT: His matches yours. Now she'll display it
to everybody.
Can y'all see it?
MS. CONNORS: Oh, okay.
BY MS. CONNORS:
Q.
Okay. So this is an Excel spreadsheet, there's a lot of
columns. I'm going to have to scroll to the side, so bear
with me.
But, Mr. Davis, have you had an opportunity to look
at this Excel spreadsheet before?
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A.
I have.
Q.
Okay. Now, in terms of this spreadsheet, do you see rows
2 through 9 that have essentially different tax filings
associated with them?
A.
Yes.
Q.
Now, for the -- I'm going to hopefully try to see if I can
highlight this first row.
Okay. So looking at the first row here -- I'm going
to scroll. Okay. There is a Social Security number listed
in -- it's under Column B ending in 6010. Do you see that?
A.
I do.
Q.
Okay. Now, if you look, is there another return at Row 7
that also has a Social Security ending in 6010?
A.
I see that also.
Q.
And then for the other returns in between, do the rest of
them have 0540 as the Social Security number?
A.
They do.
Q.
And so going across with Row 2, I'm -- yes, Row 2 for that
top return ending in 6010 for the SSN, what was the status of
that filing?
A.
That filing is rejected agency.
Q.
And in terms of the agency, would that be IRS that's
reflected with the filing type?
A.
Correct.
Q.
Okay. And for period, it says Y2020, what would that
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mean?
A.
That's the tax year.
Q.
Okay. Now, there's a received stamp, received timestamp.
What is the received date and time for this filing?
A.
February 6, 2021, 6:05:57 p.m.
Q.
Okay. And in terms of that information, is that something
that Intuit or TurboTax's system report is that filing
timestamp?
A.
Correct. That's the timestamp when the electronic filing
engine receives it.
Q.
And so for this return, since it was rejected, when you've
looked at this before, is the rejection code noted?
A.
Yeah. If you scroll over, it will have the reject reason
there.
Q.
Okay. So before we even get to that, in terms of the --
every row for the various filings here, is the legal name
Carl Torjagbo for all of them?
A.
It is.
Q.
Now, for this first one that we're looking at, is there an
address in Houston, Texas, that was used for the return?
A.
That is the address that was entered on the return, yes.
Q.
Okay. And there's taxpayer phone number, is that phone
number the same for every return?
A.
It is.
Q.
And taxpayer date of birth is part of the data that
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TurboTax collected?
A.
Correct. That's the -- that date of birth that was
entered by the customer.
Q.
Okay. And that date of birth is what?
A.
September 8th, 1975, 12:00 a.m.
Q.
Is the 12:00 a.m. a default in the system or --
A.
I believe so.
Q.
Okay.
A.
I mean, start of the day, I guess.
Q.
Okay. Gotcha. Okay. And then looking -- it looks like
there's a carldelano3@outlook.com email address associated
with that return and you see that again in Row 7?
A.
I do.
Q.
But -- and then in between, there's a torjagboc@gmail.com
email address used for the other returns?
A.
Correct.
Q.
Okay. And now, IP address, are you familiar with IP
addresses?
A.
I am.
Q.
Okay. And what is an IP address, generally speaking?
A.
This is a network address assigned to that network point
where the computer was.
Q.
And so would that be the user's IP address that's getting
recorded there?
A.
That would be the IP address of the system that we
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connected to.
Q.
Okay. And in terms of the IP address listed, was the IP
address the same for all of these electronic filings?
A.
It is.
Q.
Okay. And then there is information for a bank account
and routing number. Why does that information get collected?
A.
That's collected to -- for either paying your taxes or
having your refund direct deposited to your bank account.
Q.
Okay. And then I'm going to see if I can scroll over to
the error information.
So for this one, there is an error code and a -- in
that row, and then is there some -- a specific error message
that's kind of in that -- in that text that's highlighted?
A.
Yes.
Q.
Okay. And looks like this earlier part, pretty much up
until the words error message, there's sort of some numbers
and other things, but starting at -- after that equal sign
there, error message equals, what -- what was the error
message?
A.
This error message is noting that on the W-2, Line B, the
employer EIN was issued after the tax year in the return
header. This is an IRS error, this is an error that they have
caught.
Q.
Okay.
A.
And have sent back.
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Q.
All right. So that error message then meant that IRS
rejected this return and --
A.
Yes, this is the IRS rejecting the return for apparently
an invalid EIN.
Q.
Okay. And then kind of looking ahead a little bit, Row 3
and Row 5, do those have the same error message?
A.
They do.
Q.
Okay.
MS. CONNORS: And, Ms. Kelley, if you will send it
back to the paralegals, I'm going to ask them to pull up
Exhibit 221.
Oh, I'm sorry, Ms. Kelley, it didn't connect. Could
you --
COURTROOM DEPUTY: It switched. It might be
something with the laptop.
MS. CONNORS: Oh, okay.
And, Ms. Wilson, if you will go to Page 25 of that
exhibit. Okay. And if you can zoom in on this part here
(indicating).
BY MR. EVERT:
Q.
All right. Mr. Davis, do you see a -- in terms of this
document, is it summarizing the W-2 information?
A.
Yes.
Q.
Okay. And now do you see that in -- there's a bold B and
then it says employer ID number?
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A.
I do.
Q.
Okay. And that employer ID number, what are the last four
digits?
A.
7540.
Q.
And in terms of the bottom section with employee
information that starts letter E and F, for E, who was -- what
was the name of the individual employee whose W-2 data this
is?
A.
Carl, sorry if I don't pronounce this right, Torjagbo.
Q.
Torjagbo?
A.
Yeah.
Q.
Okay. And then is there an address?
A.
Yes.
Q.
In Houston, Texas?
A.
Correct.
Q.
Okay. And you may not remember exactly, but do you recall
that we saw on Exhibit 220 the Excel spreadsheet that a
Houston, Texas, address was associated with a rejected return?
A.
I did.
Q.
And in terms of Government's Exhibit 221, is this the
return information related to that rejected return, that first
row on the spreadsheet?
A.
Yes, this appears to be data from that filing.
Q.
Okay.
MS. CONNORS: And, Ms. Wilson, if you'll zoom out of
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that one and get us to Page 20 of the tax filing.
BY MS. CONNORS:
Q.
And in terms of this tax filing, does it indicate that --
is there a box that's checked for taxpayer is a resident of
the state above for the entire year?
A.
There is.
Q.
Okay. And then is there an abbreviation for the state a
little bit above that?
A.
Yeah, Texas.
Q.
Texas. And now when this return was rejected because of
the issue with the EIN not being in a year, an appropriate
year for the 2020 return, would that have been conveyed to the
user?
A.
It would.
Q.
Now, after that gets conveyed to the user, would the user
be able to go back to the tax return in TurboTax's system and
make any changes?
A.
Yeah, that's -- that's how it works. So you get the error
and now you're -- when you go back to TurboTax, you would --
you would be put with -- you would be put back into the return
at that point where you can make the changes.
Q.
Okay. And we saw there was an email address listed.
Would notification about the rejection go to email or some
other electronic method?
A.
It would. And it would be in the app, obviously, when you
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logged in, you would -- you would see the notification.
Q.
Okay.
MS. CONNORS: Your Honor, I think that's the breaking
point.
THE COURT: Okay. Lunch. We'll be back in one hour.
Okay?
Thank you-all very much. Continue following my
instruction. Don't talk to each other about this. Okay?
Talk to each other about anything else.
All right. Thank you.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: You can step down. Just be back here at
12:30, all right?
All right. Anything y'all want to talk about?
I'm sorry, 1:30.
MS. CONNORS: Yeah, I was about to say that didn't
sound right.
THE COURT: Anybody got anything to talk about?
MR. FINLAYSON: I've got something to talk about and
I hate to bring this up.
THE COURT: Y'all can be seated.
MR. FINLAYSON: As I'm hearing about these engines,
these -- and I don't know, she may be done with the engines
and --
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MS. CONNORS: Counsel for Intuit is still in the
courtroom. I don't know if that matters.
MR. FINLAYSON: I think it's okay. I just -- my
concern is that whether we're in the land of expert testimony.
And I know she hasn't called him as such and there's been no
notice of such, but his stuff is pretty darn technical.
And --
THE COURT: I mean, all he's talking about now is
sort of the interface of software. He's not talking about --
he's talking about the operation of a software system. It's
fairly simple. It's input this and it prints out.
MR. FINLAYSON: Well, that's why I didn't bring it up
before, so I --
THE COURT: Okay.
MR. FINLAYSON: I'll -- that's fine.
THE COURT: Okay.
MR. FINLAYSON: I don't --
THE COURT: I'm going to bring you-all back after
lunch copies of the current state of the jury instructions
with my redlines on top of what you-all gave me.
I've changed that one disputed issue a little bit to
make it more in line with the Supreme Court case that you-all
cite.
MS. CONNORS: For Kousisis, Your Honor?
THE COURT: Yes. Let me just see if I can --
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MS. CONNORS: I don't know how to spell it. Let me
just see.
THE COURT: To say -- you'll see it, but I'm going to
point it out to you so you can look at it and think about it
so we can talk and make some decisions at the end of the day.
But the way I have changed it, or proposed to do it,
is to say or promises to obtain the victim's money or
property, proving intent to defraud does not require proof
that the defendant acted with the intent to leave the victim
economically worse off or cause the victim a net pecuniary
loss. Y'all had it as to cause the victim economic loss.
MR. FINLAYSON: Your Honor.
THE COURT: Yes.
MR. FINLAYSON: Just to be clear, we disagreed on
that. I recognize the change in the law after Kousisis, but I
submit there's an ex post facto, so --
THE COURT: I know. I get that. But I'm kind of
doing both things.
MR. FINLAYSON: Okay. Got it.
THE COURT: I want you to look at the language that
I've proposed and tell me if you disagree with that as opposed
to the language you initially provided.
And then secondarily, we'll go with Mr. Finlayson's
objection to the ex post facto issue.
Okay?
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MS. CONNORS: Is there any way that we could get
that, just that snippet over the lunch break?
THE COURT: Yes. You want it over the lunch break?
MS. CONNORS: Yes. If you wouldn't mind, it would be
helpful.
THE COURT: Yes, if you give us a minute, we'll print
a copy out. We'll print out two copies or three copies.
Okay?
MS. CONNORS: Thank you, Your Honor.
MR. EVERT: Thank you.
THE COURT: Yes. Ms. Hendrix will be back shortly
with it. Okay?
Thanks.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, a lunch recess was taken.)
THE COURT: Are y'all ready for the jury?
MS. CONNORS: Yes, Your Honor.
THE COURT: Okay.
MS. CONNORS: Can we go ahead and bring in the
witness, too?
THE COURT: Yes.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: Okay. Y'all can be seated.
Go ahead, please.
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By the way, we're trying to get it a little bit
warmer in here. But we may regret that if they -- there's not
exactly a lot of sensitivity to the dial, so we'll see how it
goes, but we're trying to get it warmer.
MS. CONNORS: I appreciate it.
THE COURT: Yes.
BY MS. CONNORS:
Q.
Okay. Mr. Davis, we had just ended looking at that
rejected IRS filing under the Social Security Number 6010.
MS. CONNORS: And, Ms. Kelley, if I could have my
station.
BY MS. CONNORS:
Q.
Okay. Okay. Now, Mr. Davis, I'm going to go through some
of the information again for the next two filings here.
Now I'm going to scroll over one. And I've
highlighted Row 3 and Row 4 of the Government's Exhibit 220.
And in terms of the Social Security number that was
being used for these filings, is it a Social ending in 0540?
A.
Yes.
Q.
Okay. And then currently with the columns that are on the
screen, if you'd look over to the far right and you see
there's the received timestamp.
Are both of the highlighted returns submitted on
February 6th, 2021 at 11:06 p.m.?
A.
They are.
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Q.
Okay. Now, does one indicate that it's an IRS filing and
is the other one a Georgia filing?
A.
It is.
Q.
If someone is using TurboTax to file their federal and
state tax return at the same time, is this typical that they
both get transmitted at the same time?
A.
In this -- what happens with the state is when the feds
reject it -- oh, first of all, the fed has to be accepted
before we transmit to the state if they're not transmitted at
the same time.
But also when the feds rejected, the state's
automatically rejected in the system, so the state filing is
rejected because of the federal returns rejection.
Q.
Okay. And so you were just going over the information in
the status.
What about for the timestamp, is it that this was
submitted into the system, into the EFE at the same time?
A.
Yes. Yes. Both filings came in at the same time. They
come in together.
Q.
So kind of they're coupled together, if you will, the
federal and the associated state return?
A.
Correct.
Q.
Okay. And now, you already mentioned it, this -- these
two returns -- and I'll probably mostly refer to the federal
return here -- but both of these were rejected by the agency?
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A.
So the Georgia return is rejected because of the federal
return and the fed return was rejected by the agency.
Q.
Okay. So once that happened, then there was -- the
Georgia return was going to get rejected as well?
A.
It did -- for the Georgia return to have been filed, it
would have had to have had a successful fed filing.
Q.
Okay. And are we -- it -- here does it still indicate
that the tax year is 2020?
A.
Yes.
Q.
And I am going to scroll over some. Now we looked at this
earlier, but in terms of legal name, still Carl Torjagbo for
these two filings?
A.
Yes.
Q.
Okay. And is one -- is there a difference in terms of the
address for the taxpayer used between the one that we just
discussed that shows in Row 2 versus the returns that we're
discussing now in Rows 3 and 4?
A.
Yes, the addresses are different.
Q.
Okay. Is it also a different -- is it a different state?
A.
It is.
Q.
Now, I think you mentioned it earlier, but is the taxpayer
phone number the same for these filings as it is for all of
the ones?
A.
Yes, they are using the same phone number.
Q.
Okay. Now, there's a taxpayer date of birth that's
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identified. Is that a part of the data that's been obtained
for -- through TurboTax?
A.
Yes, it's customer input data.
Q.
Okay. And that customer input data, the date of birth is
what?
A.
Of the two highlighted.
Q.
Yes.
A.
September 10th, 1979.
Q.
And I'll scroll over a bit more. Now, we went over it
earlier, are these two returns associated with the gmail
account, the gmail email address?
A.
They are.
Q.
Is the IP address the same as the return that we looked at
before and same as the other ones?
A.
Yes, that is the same IP address.
Q.
And again, is there bank account information being listed
associated with this return?
A.
Yeah, one of them.
Q.
Now, here in terms of that return, is the same error
message related to the W-2 Line B employer EIN was issued
after the tax year?
A.
Correct, same error.
Q.
And I think you mentioned earlier that's a rejection code
at least the one for Row 3, is that an IRS rejection code?
A.
No, that's a -- that's an internal rejection code
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signifying that the fed was -- that the fed failed and was not
succeeded agency.
Q.
Okay. In terms of the like the FW2505-01, is that
TurboTax code?
A.
That's an IRS error code.
Q.
All right. And so these -- these returns are -- more
specifically, the federal return, was the error message the
same as what had happened with the return we discussed in Row
2 that that was filed under the 6010 Social Security number?
A.
Yes, same error.
MS. CONNORS: Now if we could switch, Ms. Kelley,
back to the paralegal table.
BY MS. CONNORS:
Q.
And, Mr. Davis, I'm going to pull up Government's Exhibits
222 and 223. I'm really mostly going to go with 222.
MS. CONNORS: You could actually just have 222 up.
BY MS. CONNORS:
Q.
But in terms of Exhibits 222 and 223, were those the
corresponding returns for Rows 3 and 4?
A.
I believe so.
Q.
Okay.
MS. CONNORS: Could you make that the full screen?
It's hard to see. That's okay. If you zoom in at the top
where it shows the individual data.
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BY MS. CONNORS:
Q.
Okay. And just so that we can confirm, is this a return
that identifies the Social Security number 0540?
A.
It does.
MS. CONNORS: And then if we can go to Page 14 of
that exhibit. And then if you can zoom in on this section
here (indicating).
BY MS. CONNORS:
Q.
Okay. Now, we looked at a form W-2 for Exhibit 221 before
the lunch break. Here, what is the name on the W-2?
A.
Carl Torjagbo.
Q.
Okay. And does it indicate that this is a W-2 related to
employer Kremkov Industries in Section C?
A.
It does.
Q.
Okay. And now in terms of the employer ID number, is the
employer ID number -- does that end in 8332?
A.
It does.
Q.
Okay. And you might have to look back at the binder, at
Exhibit 221. I'll tell you, it should be Page 25 of that
exhibit.
Now, looking back at Exhibit 221, and the W-2 for
that first tax return that we discussed, what -- what's the
EIN on that W-2?
A.
86-1347540.
Q.
So is that different than the EIN number on this W-2?
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A.
It is.
MS. CONNORS: And if we can go to Page 9 of this
Exhibit 222.
BY MS. CONNORS:
Q.
And this one will come up on your screen. Now, for this
return --
MS. CONNORS: Can you zoom in under that taxpayer
section?
BY MS. CONNORS:
Q.
Okay. For this return, is it marked for taxpayer's
resident of the state above for the entire year?
A.
It is.
Q.
And what state is referenced?
A.
Georgia.
Q.
Now, the first return that we looked at, did it reference
Texas?
A.
It did.
Q.
Okay.
MS. CONNORS: And, Ms. Kelley, if you can put it back
with me, please.
BY MS. CONNORS:
Q.
Okay. So now there's Rows 5 and 6 of Exhibit 220, is this
again where there's a federal return and an associated Georgia
return?
A.
Correct.
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Q.
Now, like the two returns listed in Rows 3 and 4 for Rows
5 and 6, is the Social Security number 0540?
A.
It is.
Q.
Now, is this also referring to filings through TurboTax
for tax year 2020?
A.
It is.
Q.
Now, was -- were these two returns, the federal and the
associated Georgia, were these rejected by the agency?
A.
Scroll over. Oh, no, it's right here. Sorry. Yes, they
are rejected by the agency.
Q.
Okay. Now, in terms of the received timestamp for Rows 5
and 6, was this return submitted through the TurboTax program
on February 12th of 2021 at 6:15 p.m.?
A.
Yeah. They were, yes.
Q.
Now I'm going to scroll over. Now, does this return also
use a Douglasville, Georgia, address?
A.
It does.
Q.
Okay. Does it have still the birthdate associated of
September 10, 1979?
A.
It does.
Q.
Same IP address again?
A.
Yes.
Q.
And I'm going to scroll over to the error again. Sorry,
trying not to make everybody dizzy.
And is there the same error message related to the
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IRS return?
A.
It is.
Q.
So again, is it that the employer EIN was issued after tax
year 2020? Because that's the tax return year we're talking
about, right?
A.
Correct.
Q.
All right. Now, if -- in terms of Government's Exhibits
224 and 225, are these the associated returns for those two
rows on this spreadsheet, 5 and 6?
A.
What was the question?
Q.
Were Government's Exhibits 224 and 225, which are probably
in the binder --
MS. CONNORS: Okay. And, Ms. Kelley, if you could
give it back to the paralegal, please.
And if we can pull up Exhibit 224.
BY MS. CONNORS:
Q.
All right. And for Exhibit 224, are we talking about a
tax return filed under Social Security Number 0540?
A.
Yes.
MS. CONNORS: And, Ms. Wilson, if you'll go to
Page 14 of that exhibit.
BY MS. CONNORS:
Q.
And in terms of the last four of the EIN used for this
W-2, what is it?
A.
7540.
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Q.
Okay.
MS. CONNORS: And, Ms. Kelley, will you put it back
with me, please?
BY MS. CONNORS:
Q.
Okay. And so, Mr. Davis, we're going now to Government's
Exhibit 220 again. Looking at Row 7, now for Row 7, are we --
is -- are we looking again at a filing using the
Social Security number ending in 6010?
A.
Yes.
Q.
Okay. Now, in terms of the status this time, what was the
status?
A.
Succeeded agency.
Q.
Okay. And here, is there only the one return with IRS,
there's no accompanying state tax return?
A.
Correct.
Q.
And is it still for tax year 2020?
A.
It is.
Q.
Now, if you can look at the timestamp there in relation to
the two returns that we just talked about, the received
timestamp was February 12th of 2021 at 6:15 p.m.; is that
right?
A.
Yes.
Q.
Okay. And that's what appears in Rows 5 and 6. Is that
the return that we just looked that had the Social ending in
0540?
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A.
Yes.
Q.
Now for Row 7, using Social Security number ending in
6010, what is the timestamp?
A.
February 12th, 2021, 6:37.
Q.
Approximately how much time later?
A.
22 minutes. Yeah. A little less than 22.
Q.
Okay. And now since this one went -- says succeeded, does
that mean no error message?
A.
Correct. It means the federal agency accepted the filing.
Q.
Okay. And does this return list the Houston, Texas,
address? Again, it would be the row in yellow.
A.
It does.
Q.
And taxpayer date of birth that was transmitted,
September 8 of 1975?
A.
Correct.
MS. CONNORS: And, Ms. Kelley, if you will put it
back at the paralegal for me.
And if you can pull up Government's Exhibit 226,
please.
BY MS. CONNORS:
Q.
Now, Government's Exhibit 226, does this correspond to
that Row 7 on the spreadsheet?
A.
Can I see the spreadsheet again?
Q.
Absolutely.
MS. CONNORS: I'm sorry, Ms. Kelley. Could you
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switch us back to the spreadsheet, please.
BY MS. CONNORS:
Q.
So for the return for Row 7, Social Security Number 6010?
A.
And can you scroll over?
Q.
Yes.
A.
Yes.
Q.
Okay. So 226 relates to that Row 7?
A.
It does.
Q.
Okay.
MS. CONNORS: Now, I apologize, Ms. Kelley. If you
could switch us back to the paralegal desk.
And if you'll pull up Exhibit 226.
BY MS. CONNORS:
Q.
Okay. So here, do you see the Houston address again and
the Social Security number ending in 6010 for this return?
A.
I do.
Q.
Okay.
MS. CONNORS: And, Ms. Wilson, if you will go to
Page 25 of this exhibit. And if you will zoom in on that top
information.
BY MS. CONNORS:
Q.
Now, for this 2020 W-2, does it still identify the
employer as Kremkov Industries?
A.
It does.
Q.
In regards to the EIN, does it have an EIN ending in 1377?
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A.
It does.
Q.
Is that a different EIN than we've seen before?
A.
I'd have to look back.
Q.
Sure. If you would look back, you can look back at
Exhibit 221.
MS. CONNORS: If you will pull up Page 25 of that.
THE WITNESS: Yes, they're different.
MS. CONNORS: Okay. And can you go back to 226,
please. And go to Page 20.
BY MS. CONNORS:
Q.
And for this return, is Texas identified as the place of
residence for the entire year?
A.
It is.
Q.
Okay.
MS. CONNORS: And, Ms. Kelley, if you can switch back
to me, please.
BY MS. CONNORS:
Q.
Okay. So for Rows 8 and 9 --
Woops, I apologize. I'm not scrolled over all the
way. There we go.
For 8 and 9, are these also listed as succeeded?
A.
They are.
Q.
Now, for this return -- these two returns, which again,
I'm mostly just going to focus on the federal return that's in
Line 8, does it -- is this also for tax year 2020?
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A.
It is.
Q.
And is this under the Social Security ending in 0540?
A.
It is.
Q.
Now in terms of timing, when was this return transmitted
through TurboTax's system?
A.
February 13th, 2021 at 8:42.
Q.
Is that a.m.?
A.
A.m., sorry.
Q.
So essentially the next morning from what's reflected in
Row 7?
A.
Correct.
Q.
Now, since this return succeeded, does that mean it went
through to IRS?
A.
It did. IRS accepted this return.
Q.
And I'm just going to scroll over. So does -- this return
has the Douglasville address on it; is that right?
A.
It does.
Q.
Okay. And does it have a date of birth of September 10,
1975?
A.
'79.
Q.
Oh, I'm sorry, yes, '79?
A.
Yes.
Q.
Okay. And since this one went through, there is going to
be no error message to the right?
A.
Correct.
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Q.
Okay.
MS. CONNORS: And, Ms. Kelley, I think this is
hopefully the last time, maybe, in terms of if you could
switch that back.
Okay. And if we can pull up Government's Exhibit 27.
MS. WILSON: 227?
THE COURT: I'm sorry. Yes, 227.
BY MS. CONNORS:
Q.
Okay. And is this the return associated with that
federal -- that last federal return?
A.
Yes, it appears to be.
Q.
And for this one, the -- is the Social ending in 0540?
A.
It is.
MS. CONNORS: And then if we can go to -- uh-oh. I
don't have my page number listed. Let's see. If you can
scroll down for me. I think it's going to be around Page 17.
Keep going. Let me find that page number. My apologies.
All right. I want to make sure that we don't have to
search. Okay. Page 14. Oh, sorry, you found it before me.
BY MS. CONNORS:
Q.
Okay. In terms of Page 14 of Exhibit 227, what is the EIN
number that's listed?
A.
83-1821377.
Q.
And if you need to look back at Exhibit 226, I'm going to
ask if that's the same EIN that was used in Exhibit 226 that
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we went through the return?
A.
Could I look back, please?
Q.
Yes.
MS. CONNORS: If we go to 226 and then it should be
Page 25.
BY MS. CONNORS:
Q.
Okay.
A.
And that is the same.
Q.
Okay. Now in terms of those earlier attempts, do they
have a different EIN number, the ones that were rejected?
A.
Yes.
Q.
And to confirm, Mr. Davis, all of the returns that we just
went through, including the ones that succeeded, all of those
were transmitted electronically?
A.
They were.
Q.
So what, does that mean they went over the Internet?
A.
It does.
Q.
And does Intuit or TurboTax have servers that they use to
receive this kind of data?
A.
We do.
Q.
And can you give us an idea about how that process works?
A.
Yeah. Intuit uses AWS, it's a server -- it's a company
that provides infrastructure and hardware to companies like
Intuit. They have data centers across the country.
And basically, Intuit enters into a contract with
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them and we use that hardware and their services to put our
software and programs on it.
Q.
Okay.
A.
That's -- that's the gist of it.
Q.
Okay. And how many servers do y'all use for the TurboTax?
A.
Altogether, there's probably maybe 60.
Q.
Okay. And what about for the data centers?
A.
How many data centers? We use two data centers.
Q.
Okay. And are those in different states than Georgia?
A.
They are. There's one in Ohio and one in Oregon.
MS. CONNORS: And, Your Honor, we do have a
stipulation to read into the record.
THE COURT: Okay.
MS. CONNORS: As to Counts Two and Three of the --
THE COURT: Oh, hold on a second.
Remember, this is a fact that the parties agree on
and that you have to accept as established.
Okay?
This is a fact that is accepted by the parties as
established, so listen to it carefully.
MS. CONNORS: Thank you, Your Honor.
As to Counts Two and Three of the third superseding
indictment, the wire transfers described therein were
transmitted by means of wire communication and interstate
commerce.
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Thank you, Your Honor.
There you go. Thanks.
CROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
Good afternoon, Mr. Davis. Good afternoon. I just have a
few questions for you.
MR. FINLAYSON: This -- if I could see the 220 that's
on the government's computer. No?
I'm sorry. Madam Clerk, can I get 220 that's on the
government's computer.
MS. CONNORS: The paralegal table.
COURTROOM DEPUTY: So it's at the podium.
MR. FINLAYSON: Right.
MS. CONNORS: Oh, sorry.
MR. FINLAYSON: Thank you. Wonderful.
BY MR. FINLAYSON:
Q.
This document we've been talking about for a good while
now, that's an Excel spreadsheet, right?
A.
Yes.
Q.
And did you prepare that document?
A.
My team did, yeah.
Q.
And so that is the --
A.
Or part of the team.
Q.
Okay. So it's a summary of a variety of other documents,
right? Is that fair?
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A.
No, this is data taken right from our databases.
Q.
So that -- was this -- was this -- let me ask it this way:
Was that automatically generated by your databases?
A.
No. So the data is in the database per the subpoena
requirements, we do a search based on what the court's asking
us to look for. And then we search the databases and this was
what was returned from those searches.
Q.
But was it returned in one single spreadsheet or was it
copied over from the individual documents?
A.
No. It was put right into a spreadsheet. The data pulled
from the database and put into a spreadsheet.
Q.
And how is it pulled? Is it copied or is it somehow
automatically populated?
A.
So it's a -- it's a -- it's done by the servers. It's --
it's code that actually talks to the database, makes a request
for the data in the database, using a search. The database
responds providing that, that data is stored on a server and
then -- and then we pick it up and give it to you, the
subpoena request.
Q.
There's a whole lot in that. I'm going to have to help
you take me through it.
Did you -- so do you have to like build a code to
make this spreadsheet happen?
A.
That's -- build a code. Well, everything is built. I
mean, you know, everything's been built to do this, yes.
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Q.
So is it like SAS or some type of program like that that
would --
A.
No, it's -- it's not. It's a service. I'm not a
programmer, but it's a service designed to read the database
with a query and have it return the data.
Q.
And so that program that some programmer, not you, built
in your office gathered this data somehow and put it into this
Excel spreadsheet?
A.
Yeah, I would -- I would say it talks to the database and
the database responds, putting that -- putting that data in a
spreadsheet form.
Q.
Okay. So nobody went in individually and copied and
pasted and copied and pasted?
A.
No, it's all automated. And it's -- the database is huge,
first of all, so it takes some time to look through the entire
database for the query.
Q.
Okay. I think I've got it.
And we are looking at I guess it's eight entries that
are on this spreadsheet?
A.
Yes.
Q.
And it looks like there were three returns -- three
returns that were accepted, five that were rejected; is that
right?
A.
Yes, that's what I see.
Q.
Now, you're just on the back end, you're -- you're -- you
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are just looking at the data after somebody hits submit and it
comes over to TurboTax, right?
A.
So the data is sent directly to the electronic filing
engine. I don't -- looking at it is not a thing.
But it goes into the system and it starts being
processed to be able to be transmitted to the agency and then
to talk to the agency to get the response from the agency.
Q.
And is it fair to say you're not there or present at all
on the front end when somebody's putting data in?
A.
Correct. The electronic filing engine is after TurboTax.
Q.
Okay.
A.
That's where this data came from.
Q.
So you don't -- you don't actually know who put that data
into the system at all, right?
A.
No, there's no way to tell. We know that somebody logged
in with a TurboTax account and entered this data.
Q.
And that -- so I guess there are probably IDs and
passwords for that?
A.
There's an identity system that TurboTax uses. And so to
log in, you have to be able to be that person, you have to
have the information to log in.
Q.
You can share -- that information can be shared, right?
A.
Yes.
Q.
So if someone -- like if I had your password and your user
identity, I in theory, could log in as you and file your
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taxes?
A.
Well, if there was a secondary authentication to your
phone, you wouldn't be able to do that.
Q.
Did you have that back in 2021?
A.
I do not know.
Q.
You don't know. Because we have it now, right, we have
that now?
A.
Absolutely.
Q.
But 2021, you're not sure?
A.
I'm not sure.
Q.
Okay. So you testified on direct that the TurboTax
program is designed to be user-friendly, right?
A.
It's designed to assist the user and hopefully in a
friendly way.
Q.
In fact, you even mentioned like if it -- it's designed if
there -- if a return is rejected, it's designed to spit it
back to the user so they can make corrections and resubmit; is
that right?
A.
Yeah, it's -- the idea is that the error message back from
let's say the IRS, we want to make sure that the customer
understands what the error is. And if we have like some step
by step stuff to provide them, we -- that's given to them also
in the app.
Q.
So the system is built for those corrections to be made by
the user, right?
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A.
Correct.
Q.
So it's not -- there's nothing surreptitious about getting
a rejection notice and then sending it -- making a change and
sending it back in?
A.
No. Not uncommon, either.
Q.
Not uncommon, right?
A.
Correct. Correct. I'm sorry.
Q.
Yeah, it's -- people all day long are struggling with
these things, right, there's not easy?
A.
The system is designed for that, correct.
Q.
Okay. And I gather you're -- you're then -- you have your
computer system and they were dealing also with the IRS
computer system, right?
A.
I don't know what you mean by mine.
Q.
Well, Intuit's. You have the Intuit system.
A.
Oh, gotcha. Yes. There's -- Intuit hosts their own
service, that's what the EFE's runs on, Intuit hosted servers.
And we connect to the IRS, which has their own systems.
Q.
Okay. And that system is a little old, for lack of a
better word?
A.
I do not know what their system is and they keep it quite
a secret.
Q.
It's -- let's say this, it's not perfect, is it?
A.
I wouldn't -- I wouldn't know how to know if it was
perfect, but I would assume no.
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Q.
Okay. And you mentioned before that there are sometimes
in your -- even on your end, on the Intuit side, will there be
some errors and particularly you mentioned on like filing
dates or filing stamps?
A.
There can be transmission errors --
Q.
Okay.
A.
-- that -- and there can also be errors with Intuit
communicating with the IRS that can be caused by multiple
things. And those -- and those failed transmissions are then
manually retransmitted to the agency. So they require some
intervention. It's a very, very small amount of filings
compared to how many are filed, but, yeah, that can happen.
Q.
Okay. And the filings that happened in this case, you
don't have any real-time knowledge of them, do you? Did you
have any realtime knowledge of the filing -- of like the
filings that are reflected on this spreadsheet were you --
A.
Real-time meaning?
Q.
Were you there on, you know, February the 6th?
A.
Oh, did I see those filings filed.
Q.
Right.
A.
No.
Q.
So you can't say when any of these actually came through,
can you?
A.
I can. I can look at the -- I can look at the record and
I know that the records kept in the normal course of business
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are accurate.
Q.
Okay. But besides looking at the records, you weren't --
there's no way you would have actually been in the room to see
it come across, would you?
A.
They're coming back, you know, hundreds per second. So,
no, I wouldn't have been able to see if it went by in front of
me on a screen.
Q.
Okay. Okay. You mentioned that -- you went through there
some different EIN numbers listed on different returns; is
that correct?
A.
Yes.
Q.
And the one -- I guess the one that went through was the
EIN number ending in 1377?
A.
I believe so. Sorry, I'm not --
Q.
This was accepted by the IRS?
A.
Yeah, I believe so. That's what we confirmed.
Q.
And before you had mentioned that I guess the error code
was the EIN number had to be the wrong one, because it didn't
exist -- that EIN number didn't exist at the tax year that the
earlier tax return was filed, right?
A.
That's what the -- that's the error the IRS provided.
Q.
Okay. So then the user put in the 1377, and that was --
that went through and that was successful?
A.
Apparently, yes. The IRS accepted the entire return.
Q.
Okay.
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MR. FINLAYSON: That's all my questions, Your Honor.
THE COURT: Any redirect?
MS. CONNORS: No, Your Honor.
THE COURT: All right, sir. You can step down.
Thank you very much.
THE WITNESS: Thank you.
THE COURT: Who's up next?
MS. CONNORS: I'll just grab my computer.
MR. EVERT: The government calls John Horner.
THE COURT: Okay.
- - -
JOHN HORNER,
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: John Horner, J-O-H-N, H-O-R-N-E-R.
COURTROOM DEPUTY: Thank you. You may be seated.
THE COURT: Any relation to Bob Horner?
THE WITNESS: No, but I watched him when I was a kid.
THE COURT: Yes, me too. I was hoping maybe.
THE WITNESS: I'm sorry to disappoint you.
THE COURT: I'm sure you're fine. It's going to be
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all right.
DIRECT EXAMINATION
BY MR. EVERT:
Q.
Good afternoon, Mr. Horner.
A.
Good afternoon.
Q.
Where do you work?
A.
I work at Gables Residential.
Q.
And what is Gables Residential?
A.
So we are a company that builds apartment complexes. We
own and operate and we develop them.
Q.
How long have you been with Gables Residential?
A.
Ten years.
Q.
And what's your title there?
A.
Director of construction.
Q.
So we're going to display on the screen Government's
Exhibit 202, which is already in evidence.
MR. EVERT: Could we please put that up. And if we
could please turn to Page 2 at the bottom of the page.
BY MR. EVERT:
Q.
Could you please read the date next to where it says sign
here.
MR. EVERT: And we'll zoom in on that. Thank you.
BY MR. EVERT:
Q.
Okay.
A.
It says February 12th, 2021.
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MR. EVERT: And then if we could go to Page 1,
please. And zoom in on the top with the information about the
person whose taxes this is.
BY MR. EVERT:
Q.
Would you please read the name of the person who's filing
this?
A.
Carl -- I can't pronounce the name. I'm sorry. Carl
Torjagbo.
Q.
And then two lines down, would you please read the address
associated with this individual?
A.
Yes, it's 2220 Westcreek Lane, Apartment E71.
Q.
And what city is that in?
A.
It is in Houston.
Q.
And the state is Texas?
A.
That is correct.
Q.
Are you familiar with the address 220 Westcreek Lane in
Houston, Texas?
A.
I am.
Q.
How are you familiar with it?
A.
That's where we built an apartment complex called
Gables Crimson.
Q.
And have you reviewed the records for Gables Crimson?
A.
I have.
Q.
And is there an apartment -- is there an Apartment Number
E71 at Gables Crimson at 220 Westcreek Lane?
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A.
No, there is not.
Q.
In Houston. Sorry, I spoke over you.
A.
That's okay. No, there's not. We don't label our
apartments alphabetically.
Q.
And how long has Gables Residential owned 2220 Westcreek
Lane?
A.
So the property was purchased in 2015.
Q.
And when Gables Residential purchased 2220 Westcreek Lane,
what was there?
A.
An existing building.
Q.
And what did Gables Residential do with the existing
building?
A.
We hired a contractor to tear it down.
Q.
And when was that older building torn down?
A.
2017.
Q.
And then I understand that Gables Residential constructed
a new building; is that correct?
A.
We did. We started in 2018.
Q.
And how long did the construction of that new building
take?
A.
So it was substantially complete or complete enough that
we could have occupancy in it in April of 2020.
Q.
Did anyone live at 2220 Westcreek Lane while the
construction was taking place?
A.
No, sir. That would not be allowed by the City of
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Houston.
Q.
So between 2017, when it was torn down, and I believe you
said April 2020 --
A.
Yes, sir.
Q.
-- nobody lived there?
A.
That's correct.
Q.
And since the new building has opened in April 2020, has
an individual named Carl Torjagbo ever resided at that
address?
A.
No.
Q.
And how about an individual by the name of Karl Delano,
has someone by that name ever resided at 2220 Westcreek Lane
since it opened in April of 2020?
A.
No.
MR. EVERT: No further questions. Thank you.
CROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
Mr. Horner --
A.
Sir.
Q.
-- not Bob.
A.
No.
Q.
Do you get that all the time?
A.
I do.
Q.
Do you live here?
A.
I do.
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Q.
So you don't live in Houston?
A.
I don't.
Q.
Did you ever live in Houston?
A.
No.
Q.
So you just looked at records about this address?
A.
No. I flew there every other week for two years to manage
it.
Q.
Oh, all right. So you have been there?
A.
Yes, sir.
Q.
Okay. So if I understand what you're saying is there was
an apartment building there that would have had the number
E71, right?
A.
I'm not saying that.
Q.
You're not saying that. You're saying there is no E71
now?
A.
I'm saying that since Gables Residential owned the land in
2015, there has never been an E71.
Q.
Okay. And the old building was torn down?
A.
Yes, sir.
Q.
Okay. The -- I gather you don't -- you're not the
property manager of that -- of that residence, are you?
A.
No, sir.
Q.
Do you know every resident that's living in the building?
A.
No. That's why we reached out to our senior VP of
operations who does.
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Q.
Okay. Well, let's not repeat what he said, because that
will be hearsay. So let's talk about what you know.
A.
Sure.
Q.
You obviously -- there -- when people sign a lease for an
apartment, they put their name on that lease, right?
A.
I would imagine. I'm not involved with that process, but
that seems logical.
Q.
Seems logical. And they're supposed to probably put the
other people that live in there as well, right?
A.
Again, I'm not sure.
Q.
You don't know, okay.
So you don't know if somebody has a relative or a
guest or you don't know if somebody else has somebody living
in their apartment that's not on a lease?
A.
I don't know.
Q.
Okay. Does -- and you may not know this, but does old
mail still show up for the old addresses?
A.
I don't know that.
Q.
Okay. And you don't know that's not the case, I gather,
either?
A.
I don't know.
Q.
Okay. Have you been in the offices at the new building?
A.
I've been in the new building many times.
Q.
Okay.
A.
And that's where the mail is received.
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Q.
Okay. Have you looked -- do you ever look at that mail?
A.
No, sir.
Q.
Okay.
MR. FINLAYSON: That's all my questions, Judge.
THE COURT: Any redirect?
MR. EVERT: Just one brief question.
REDIRECT EXAMINATION
BY MR. EVERT:
Q.
On cross-examination, you were asked about whether it
would be possible for a relative to live in someone else's
apartment.
In 2020 or 2021, would it have been possible for
anybody to live in Apartment E71 at 2220 Westcreek Lane?
A.
No.
Q.
Why not?
A.
Because it doesn't exist.
Q.
Thank you.
MR. EVERT: No further questions.
THE COURT: All right. Can he step down?
Thank you very much. Are you still a Braves fan?
THE WITNESS: Yes, sir. Went last night.
THE COURT: You did? That was a hard game.
THE WITNESS: My daughter's first game there.
THE COURT: Oh, no kidding. That's wonderful.
That's a great place to see a game. I wish that team was a
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little bit better.
THE WITNESS: She was excited nonetheless.
THE COURT: Yes. I'd like to pay them not to hit
home runs or at least to try not to hit home runs. I wonder
what that would do. Anyway, thanks for coming in. I
appreciate it.
All right. Who is your next witness?
MS. CONNORS: Your Honor, the government calls
Salvatore Hazel.
THE COURT: I think Bob Horner was the best player in
major league baseball and they refused to pay him $2 million
that year. That's how tight it was back then.
- - -
Salvatore Hazel,
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: Should I sit down?
THE COURT: Yes.
THE WITNESS: May name is Salvatore Hazel. That's
S-A-L-V-A-T-O-R-E, Hazel, H-A-Z-E-L.
COURTROOM DEPUTY: Thank you.
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DIRECT EXAMINATION
BY MS. CONNORS:
Q.
Good afternoon, Mr. Hazel.
A.
Good afternoon.
Q.
Will you -- oh, I'm sorry. Do we need to get you a
different bottle of water?
A.
No, no, no. That's good.
Q.
Mr. Hazel, can you tell the jury where you're currently
employed?
A.
I work for the Internal Revenue Service.
Q.
And how long have you been with the
Internal Revenue Service?
A.
October will be 16 years.
Q.
And what has been some of your positions with the IRS?
A.
My first year with the Internal Revenue Service, I was a
customer service representative. I answered the toll-free
number. Taxpayers would call the 1-800 number, have questions
about their account, status of their refund and I would try to
assist them over the phone. I did that for one year.
And then I moved on to the taxpayer assistance
center, so much like helping taxpayers over the phone, now
taxpayers had the option to walk into one of the assistance
centers and speak to someone face-to-face. There we were also
allowed to accept payments, provide transcripts, forms,
instructions, along with trying to assist on any other
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questions they had with their account. And I did that for
five years.
After that, I moved on to the taxpayer advocate
service. So the taxpayer advocate service is basically the
1-800 tax help that you hear all of those commercials about,
that's what the taxpayer advocate service is for the IRS. it's
a division put in place to help bridge the communications
between taxpayer and IRS.
You were promised your refund in six weeks, it's been
six months, you haven't heard anything, you know, no letters,
can't get anybody on the phone. You can reach out to the
advocates and we kind of like bridge that communication and
just try to help resolve any issues you have with the IRS. I
did that for five years.
And now I'm in my current position as a court witness
coordinator.
Q.
Thank you, Mr. Hazel.
A.
You're welcome.
Q.
So and are you familiar with some tax filings related to
Carl Torjagbo and other tax information related to him and
Kremkov Industries?
A.
Yes, I am.
Q.
And before coming to court today, did you assist with
getting certified copies of different IRS documents?
A.
Yes, I did.
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MS. CONNORS: Your Honor, I would move to admit
Government's Exhibits 201A, 201B, 203, 204, 205 -- well, let
me just say 205 through 213.
THE COURT: Any objection?
MR. FINLAYSON: No objection.
THE COURT: All right. Those exhibits are admitted.
MS. CONNORS: Thank you, Your Honor.
BY MS. CONNORS:
Q.
And, Mr. Hazel, in terms of the records that you have
looked at for this particular case and investigation, have you
seen multiple records related to different 2020 Form 1040s?
A.
Yes, I have.
Q.
And are those 1040s from multiple sources, such as filings
that went through with TurboTax, filings that the IRS
processed as well as information -- the 1040s that were
submitted with -- to Chase Bank?
A.
Yes, they were.
Q.
Now, in terms of those 1040s, are they reporting a good
bit of information, such as Social Security number that's on
the return, date of the filing, an EIN that was used on a W-2
and an EIN on a schedule E?
A.
Yes, they are.
Q.
And to assist with your testimony today, was a summary of
those filings and a specific summary related to the date of
the filing, Social Security number used, the employee
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identification number listed on the W-2 and the employer
identification number listed on the Schedule 3, was that
summarized?
A.
Yes, it was.
Q.
And prior to coming in today, did you review the records
underlying this exhibit, the summary, to ensure accuracy?
A.
Yes, I did.
Q.
And then in addition, was a summary of employee
identification numbers prepared related to three different
employer identification numbers associated with Carl Torjagbo
or Kremkov Industries?
A.
Yes, they are.
Q.
And in terms of your testimony, would both of those
summaries that I've just referred to, which are premarked as
Government's Exhibits 503 and 504, would those aid in your
testimony today?
A.
Yes, they would.
MS. CONNORS: Your Honor, I'd move to admit
Government's Exhibits 503 and 504.
MR. FINLAYSON: No objection for them used to assist
the witness in the testimony. I don't think they would go
into evidence, however.
MS. CONNORS: Your Honor, they are summary exhibits,
summary exhibits are admissible into evidence. They're not
for demonstrative purposes.
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THE COURT: Okay. You mean whether they'll go back
to the jury?
MR. FINLAYSON: Correct.
THE COURT: Okay. Well, we'll talk about that later
under -- is it 1001?
MS. CONNORS: 1006.
THE COURT: 1006. We'll talk about that in a bit.
Okay?
But for now, without the defendant's objection, they
are admitted.
MS. CONNORS: Thank you, Your Honor. Okay.
THE COURT: So you may or may not have this document
or this exhibit when you go -- what number?
MS. CONNORS: 503 and 504.
THE COURT: 503 and 504, that's TBD. Okay?
MS. CONNORS: Thank you, Your Honor.
Okay. And if we could pull up Exhibit 503.
BY MS. CONNORS:
Q.
And, Mr. Hazel, does the IRS keep records of employer
identification numbers?
A.
Yes, it does.
Q.
And can you explain what an employer identification number
is?
A.
Yes, I can. So an employee identification number, also
known as an EIN number, is the business's tax ID number, it's
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basically the business's Social Security number. And that's
used to identify -- the IRS uses it to identify the business.
Q.
Now, in terms of an EIN, if -- does the IRS obtain data
when that EIN is created?
A.
Yes. An application is sent into the IRS requesting the
EIN. The IRS will review the application and either approve
and provide an EIN tax ID number to that business or not.
Q.
Now, if any information is subsequently changed to the
EIN, would that be reflected in IRS's systems?
A.
It should be.
Q.
And so to give an example, I'm going to have you, if you
will, look at the column that has the EIN ending in 1377.
And for that EIN, was there a change at one point to
some information for this record?
A.
Yes, it looks like there is a change of the address.
Q.
And is the change that is reflected here, is that
something that you were able to find in the IRS's records
related to this EIN?
A.
Yes, it was.
Q.
And so in terms of the associated addresses that are
listed for this EIN, are the two addresses that are reflected
here, are those the only two addresses that you were able to
find in IRS's system related to this EIN?
A.
Yes.
Q.
And so there is one address kind of at the bottom that is
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in Douglasville, and there is a date range under it.
Was that the date range that that address was the
address for this business in IRS's records?
A.
That is correct.
Q.
And then did there come a point where there was a request
to change the address associated with this EIN?
A.
Yes, there was.
Q.
And were you able to see that change request in IRS's
system?
A.
Yes, I was.
Q.
Did the change -- was that change to put the address for
that EIN in Marietta, Georgia?
A.
That is correct.
Q.
Now, in terms of this summary, if there had been any other
changes to that EIN ending in 1377 regarding business name,
establish date or name control, would it be reflected here?
A.
It should be, yes.
Q.
Okay. And here, what is the business name for the EIN
ending in 1377?
A.
The business name listed here is Carl D. Torjagbo.
Q.
And what month and year was this business EIN created?
A.
The EIN was established in September of 2018.
Q.
And there's a line for name control that has TORJ. So
what's a name control?
A.
So it's one of the ways that the IRS identifies either an
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individual or a business. They take the last four letters of
the last name, for an individual or for the business.
Q.
Okay. So because this business name was Carl D. Torjagbo,
is that why the name control is TORJ?
A.
That is correct.
Q.
Now, did you see any record establishing that the business
name for the EIN ending in 1377 was Kremkov Industries?
A.
I did not.
Q.
And did you see any kind of change request where at some
point that name was changed, added, removed, Kremkov
Industries?
A.
I did not.
Q.
Okay. And then if you'll look at the second column for
8332, what was the establish date for that EIN?
A.
The establish date for the EIN ending in 8332 is January
of 2021.
Q.
And for the business name, what is the entire business
name for this EIN?
A.
The entire business name is Kremkov Industries, Carl
Delano Torjagbo, sole member.
Q.
Now here what is the name control?
A.
The name control on this will be that -- off the first
name, the Kremkov, which will be KREM.
Q.
And there's an address in Douglasville listed for this
EIN. Now, is that the only address you've -- you found in
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IRS's system associated with the EIN ending in 8332?
A.
That is correct.
Q.
So unlike 1377, did you find any record that the
address -- there had ever been an address change request for
8332?
A.
I did not find any address changes or request.
Q.
And in terms of that address, what does it say is the
street address in Douglasville?
A.
3081 Leatherleaf Trail, Douglasville, Georgia, 30135.
Q.
Okay. And if you look at the bottom address under 1377,
is there a somewhat similar address but not the same?
A.
It is not the same.
Q.
And there is the street name listed as Leatherly instead
of Leatherleaf?
A.
That is correct.
Q.
And Trail is spelled out under 1377 whereas it appears
that there is an abbreviation for 8332?
A.
That is correct.
Q.
Okay. Now, for the EIN ending in 7540, what is the
business name for that EIN?
A.
The EIN with the last four digits of 7540, the name is
Kremkov Industries, LLC, Carl Torjagbo, sole member.
Q.
Okay. So for that EIN, are there some differences from
8332 in terms of the business name?
A.
There are some differences in the name, yes.
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Q.
Okay. And what are some of those differences?
A.
It lists as an LLC, the name Carl Torjagbo is there for
the 7540, where in the 8332, it's Carl Delano Torjagbo.
Q.
And for both 8332 and 7540, what is the establishment
date?
A.
That is also January 2021.
Q.
And here is the name control the same?
A.
Yes, it is.
Q.
And I believe you talked about how the name control is --
what it's based on, but is that -- is that consistent that it
would be KREM if the company name started with Krem -- or was
Kremkov?
A.
Yes, it is.
Q.
Okay. And then here, between 8332 and 7540, are the
Douglasville addresses the same?
A.
Yes, they are.
Q.
Okay.
MS. CONNORS: Can you pull up 106 and put it beside
503. Do the whole letter. Is there a way to make that one
slightly bigger? No.
BY MS. CONNORS:
Q.
Okay. Mr. Hazel, have you -- have you seen this letter
before that's Government's Exhibit 106?
A.
Yes, I have.
Q.
Now, in terms of this letter, is it your understanding
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this was submitted to Chase Bank on May 7th of 2021?
A.
That is correct.
Q.
Now, could you say what the -- who is this letter
purportedly issued to?
A.
To Kremkov Industries, Carl Delano Torjagbo, sole member.
Q.
And what is the address that is listed on this letter?
A.
That would be -- thank you. Thank you -- 3081 Leatherleaf
Trail, Douglasville, Georgia, 30135.
Q.
Okay.
MS. CONNORS: And could we slide over 503 possibly so
we could see that a little more side by side? There we go.
BY MS. CONNORS:
Q.
Okay. So, Mr. Hazel, what is the employer identification
number that is purportedly on this letter?
A.
The EIN identification -- employer identification number
listed on this letter is 83-1821377.
Q.
So looking at Exhibit 503, is that the EIN that's in the
first column?
A.
That is correct.
Q.
Okay. And, Mr. Hazel, in regards to 1833, does IRS's
system have any information that would be consistent with a
letter being issued with 1377 on it but addressed to
Kremkov Industries, Carl Delano Torjagbo, sole member, at 3081
Leatherleaf Trail, Douglasville, Georgia?
A.
I could not find any letter.
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Q.
And in terms of the EIN 1377, is the business name for
that EIN Kremkov Industries, Carl Delano Torjagbo, sole
member?
A.
No, it is not.
Q.
And in terms of EIN 1377, has there ever been an address
associated with that EIN that says 3081 Leatherleaf Trail, the
abbreviation for Leatherleaf Trail, in Douglasville, Georgia?
A.
I did not find that address, no.
Q.
You found a somewhat similar address but not the same, is
that right, from the one that was identified from September of
2018 to June of 2021?
A.
That is correct.
Q.
And this notice is indicating that it's issued
September 1st of 2018; is that right?
A.
That is correct.
Q.
Okay. But in terms of the address and Social -- or, I'm
sorry, in IRS's system in September of 2018, this was not the
address?
A.
That is correct.
MS. CONNORS: And if you can zoom out of that letter
and pull up the text.
BY MS. CONNORS:
Q.
Now, in terms of this letter, is it giving some
information related to Form 941s and 940s that would have to
be filed?
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A.
That is correct, yes.
Q.
Okay. And at the top, is it saying that this would be for
the EIN ending in 1377?
A.
Yes.
MS. CONNORS: If we can go to Page 2 of Exhibit 106.
BY MS. CONNORS:
Q.
And, Mr. Hazel, there's -- the very bottom line says thank
you for your cooperation. But do you see the paragraph right
above that?
A.
Yes, I do.
Q.
Okay. And you can read that first sentence in that
paragraph?
A.
Your name control associated with this EIN is KREM.
Q.
Does the IRS have any record of KREM being the name
control for the EIN ending in 1377?
A.
It does not.
MS. CONNORS: Let's go to Exhibit 201.
BY MS. CONNORS:
Q.
And, Mr. Hazel, do you recognize this tax return?
A.
Yes, I do.
Q.
And in terms of this tax return, what is the
Social Security number being used?
A.
The Social Security number listed on this tax return is
771-36-0540.
Q.
And if we can zoom out -- well, let me first ask you,
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whose name is on this tax return?
A.
Carl Torjagbo.
Q.
And does this tax return list that 3081 Leatherleaf Trail
address that we just saw?
A.
Yes, it does.
MS. CONNORS: And if we can zoom out of that part and
then show the itemization. Yeah.
BY MS. CONNORS:
Q.
Okay. And, Mr. Hazel, in terms of the wages, salaries and
tips, what was the amount listed?
A.
The amount on Line 1 under wages, salaries and tips, the
amount listed is $9,199,411.
Q.
Now, in terms of the wages, salaries, that are supposed
to -- that are recorded in that section, is that supposed to
be what the individual received during the tax year?
A.
That is correct.
Q.
And if you can look at Line 8, there's a negative in front
of the number, but what's -- what is that number?
A.
The number listed on 8 is a minus $9,999,360.
Q.
And then there is an additional figure in Line 9 that also
has a negative in front of it. And what is that number?
A.
The number listed on line 9 is minus 799,000 -- $799,949.
MS. CONNORS: And if we can go to Page 2 of that
exhibit, please. If you will capture that top portion. Thank
you.
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BY MS. CONNORS:
Q.
Okay. And, Mr. Hazel, you've probably looked at a lot of
these, but so that we can walk through it, is there a line at
25 that's asking for a federal income tax withheld and then it
says from and colon. Below that, there's letters. Is that
supposed to be depending on your situation, you fill those
out?
A.
That is correct.
Q.
So now for this 1040, there's a Line 25A, and what is the
number there?
A.
The number listed on line 25A is $3,371,641.
Q.
And then there's also a line for 25C. And what is that?
A.
That's from other forms or instructions. And that amount
listed is $88,194.
Q.
Now, in terms of Line 25D, is that supposed to be adding
25A, B and C and any of those?
A.
That is correct.
Q.
Now, in terms of this figure, $3,459,834, what is that
supposed to reflect?
A.
That should reflect the taxes paid or withheld.
Q.
Have you had an opportunity to research the
Social Security number ending in 0540 to determine if there
were any tax withholdings paid to the IRS in 2020?
A.
I was able to research the account and there were no taxes
paid to the Internal Revenue Service.
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Q.
So that figure is -- there's nothing to suggest that that
money was ever paid to IRS?
A.
Per my research, I could not find any withholdings listed
for the -- under that tax ID number for the tax year 2020.
Q.
Now, Mr. Hazel, can you explain in terms of tax
withholdings, how did -- how does that reflect when you are --
well, let me see how should I ask you this.
If you have tax withholdings, is that what is going
to determine in large measure whether is a potential refund of
any taxes paid at the end of the year?
A.
Yes, it does.
Q.
So how does that work essentially?
A.
So on a basic W-2, where you receive your paycheck, like
every two weeks, you have your income, what you paid, and your
withholdings. And the withholdings is the credit that you're
getting for paying the taxes.
At the end of the year, you file Form 1040, right?
It's basically a balance sheet of what you did. You list on
the first -- that Line 7 all the income you earned, received,
being paid.
And there's a chart that says how much tax liability
you should have. If your withholdings is more than your tax
liability, you have a surplus, you'll get a refund.
If your withholdings is below the amount you should
have paid, you may owe the IRS some money at the end of the
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year.
Q.
Now, does the IRS in terms of tax returns rely on
information that the individual is putting into the form to
process the tax return?
A.
So the whole basic tax system, the IRS is trusting that
the taxpayer files their return honestly and accurately as
possible. So if there's a return on file, and there's a W-2
and those numbers match as close as possible together, the IRS
won't -- in most cases won't question it at first and will
release the refund, as they know people need their refund. So
they're instructed by the federal government to try to get the
refunds out as soon as possible, because many people are
depending on that.
Q.
And if they're owed the money back, then they -- the IRS
wants to gets them that money back as quickly as possible?
A.
That is correct.
Q.
Now, if we can look here at the bottom of that screen, as
a result of the figures going into this 1040, was there an
amount that was stated for a refund?
A.
Yes, it is.
Q.
And what was the amount of the refund being requested?
A.
The amount listed on line 35A is $3,373,441.
Q.
And when IRS is processing this return, is it processing
it with the assumption that this is accurate information?
A.
That is correct.
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Q.
Now, could there be some adjustments that IRS is doing to
that refund amount?
A.
There can be.
Q.
Okay. Now, in terms of 2020, were there kind of some
common reasons in terms of prior stimulus payments that there
may have been an adjustment in a refund?
A.
There may be.
Q.
Can you explain kind of what was going on with stimulus
payments at that time?
A.
Well, during 2020, it was just at the beginning of COVID
and the federal government knew that, you know, some people
were out of work and so forth. So they started offering some
kind of, you know, tax credits, I believe it was a $600 and
maybe $1,200 and so forth. So they were allowing -- you know,
sending the checks to the taxpayers.
Q.
So if someone claimed a stimulus payment in their tax
return but they had actually already received it previously,
would that amount get deducted?
A.
In most cases, it would.
Q.
Now, in terms of that recovery rebate, was that something
that if someone had already received it, it's kind of known in
an IRS's system?
A.
It should be, yes.
Q.
So in terms of -- did a -- did someone necessarily have to
lay eyes on the return to be able to potentially see that that
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refund amount had already been -- had already been obtained --
I'm sorry. Not the refund amount. That the stimulus payment
had already been paid by IRS?
A.
I believe so, yes.
MS. CONNORS: And if we can zoom out of that. And if
you will go down to the section that says sign here.
BY MS. CONNORS:
Q.
Now, on the IRS tax return, there is a sign here. And you
were just testifying that IRS is relying on the information to
be accurate.
Does IRS even require that someone signs their tax
return saying under penalties of perjury, you declare that I
have examined this return and accompanying schedules and
statements and to the best of my knowledge and belief, they
are true, correct and complete?
A.
Yes, that is correct.
Q.
Does the IRS rely on the person signing the tax return and
attesting under penalty of perjury that their tax return is
correct?
A.
That's correct. It's one of the reasons why the IRS
requires that you sign your tax return.
Q.
And now here, is this -- does -- does it essentially end
up with an electronic signature?
A.
That is correct.
Q.
And how did the electronic signatures work for IRS?
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A.
Well, because you're doing the tax return on your computer
over your Internet, you can't put a wet signature on it, like
an old-school, paper return. So the IRS could provide you a
pin number, a personal identification number.
And there's a couple of ways you could establish it,
you can pick one out, they ask you a couple of questions. Do
you remember your AGI from the year before. If not, then it
will go to your date of birth, something like that, just to
confirm that they have the right taxpayer. And then they'll
provide you a signature pen and that's what's used to sign --
electronically sign the tax return.
Q.
And so those steps of trying to -- of asking for that
information, like AGI or date of birth, is that to verify or
at least attempt to verify the identity of the taxpayer?
A.
That is correct.
Q.
In terms of an IRS tax return, is that only the person
whose information is used could get the refund?
A.
That is correct.
Q.
Now, even if someone else is filing your return for you,
are you still ultimately -- is the individual still ultimately
responsible for making sure that the IRS has the correct data?
A.
So do you mean if a preparer, yes.
Q.
Yes.
A.
So if you have a paid preparer who does your return and
it's like listed a little bit below that, your paid preparer
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needs to be listed on the return, right? And he needs to have
an identification number, because he's being paid to prepare
your tax return.
But in the end, the taxpayer is still required to
sign that return to say I reviewed all of this. Even though I
did not prepare this return, my preparer did, I reviewed this
and I'm signing saying, yes, everything -- all the information
on here is correct.
Q.
Okay.
MS. CONNORS: And, oh, sorry, if you could pull up
that section again.
BY MS. CONNORS:
Q.
Here, was there any indication that someone other than
Carl Torjagbo was submitting this return?
A.
Can you just scroll down a little further? Thank you.
Per this return, there's no information listed under
the paid preparer, so it would be the taxpayer prepared the
return in the eyes of the Internal Revenue Service.
Q.
Okay. Now, what if someone who is not an official tax
preparer, but you wanted to have your friend or parent or
someone like that file your return, is it still the
responsibility of the taxpayer to make sure that the
information is correct?
A.
In the end, it's always the responsibility of the
taxpayer. It's your name on the return, you know, you're
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signing the return, you're asking for that refund or saying
that you owe X amount of dollars.
Q.
Okay. And even if you look at the sign here section
again, after the statement that I read earlier, does it also
say declaration of preparer in parentheses, other than
taxpayer, is based on all information of which preparer has
any knowledge.
A.
That is correct.
Q.
Should it be that if someone is filing the tax return that
they have, they are getting the information from the
individual so that they can file this tax return accurately?
A.
That is correct.
Q.
Okay.
MS. CONNORS: And we're going to go to Page 11 of
this exhibit. And if you can -- yep, if you will go about
halfway. That's good.
BY MS. CONNORS:
Q.
Okay. So, Mr. Hazel, you've looked at this before in
terms of this particular document. Is it Page 2 of one of the
schedules?
A.
Yes, it's Page 2 of the Schedule E.
Q.
And a Schedule E, what is that generally reporting in
terms of a tax return?
A.
It could be other incomes or losses under the individual
and if any business is established with it.
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Q.
Okay. Now, here, on this tax return -- and, again, this
was the one filed under the 0540 Social Security number that's
in the top right corner?
A.
That is correct.
Q.
And does it list Kremkov Industries as a company name?
A.
Yes, it does.
Q.
Now, is there -- and in terms of the employer
identification number, is it the one ending in 8332?
A.
Yes, it is.
Q.
Now, at the kind of bottom part, there's some information,
there's kind of a bold field for passive income and loss and
then non-passive income and loss. Were non-passive losses
reported?
A.
Under non-passive income and losses, it looks like Column
I, the amount listed on Row A is $9,999,360.
Q.
Now, we saw on the first page of this return that there
was a figure of over $9 million that was identified for the
wages; is that right?
A.
That is correct.
Q.
Now, when these passive -- nonpassive losses are kind of
represented in terms of the tax return, what would happen
there?
A.
Well, that number gets carried over to the front of the
tax return.
Q.
Okay. So does it end up essentially being deducted from
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the wages and earnings?
A.
Depending on where the numbers are listed, it could lower
your tax liability, yes.
Q.
Okay. In terms of this particular return, was a refund
ultimately -- there was a refund claimed that we saw earlier
on Page 2 over $3 million?
A.
That is correct.
Q.
So in terms of how that refund amount kind of came about,
did it come about because of the identified wages being offset
by the non-passive losses?
A.
That is correct.
Q.
When that happens, does that essentially decrease the tax
liability for someone?
A.
Right. So what would happen is the losses here offsets
the income, the money earned, that 9 million and change, so
you have no income really to report because it was zeroed out.
But you're also letting the IRS know but I already
paid $3,600,000 in withholdings based on that original
$9 million. But now the $9 million has been offset and now
you have a surplus of the $3 million.
Q.
Okay. So because the wages that were reported were offset
entirely by the loss, the amount that was claimed as what had
been paid to the IRS in tax withholdings, was that entire
amount going to be due back?
A.
That is correct, because there's no tax liability.
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Q.
But again, to confirm, did you find any record that any
money was paid to the IRS for Carl Torjagbo in 2020?
A.
There was no money paid.
Q.
So that offset that then resulted in that tax refund of
over $3 million was -- it strictly happened because he had
listed that he had that tax withholding?
A.
That is correct.
Q.
The IRS is only refunding what someone had already paid
in. Is that how that process works?
A.
That is correct.
Q.
Now, Mr. Hazel, when you have -- I'm not going to go
through every page of this tax return, but have you had an
opportunity to fully review this tax return?
A.
Yes, I have.
Q.
Now in terms of the refund that was generated for this tax
return, was it related to that withholding amount that was
reported or was there anything in this return to suggest that
the defendant qualified for some kind of tax credit where the
IRS was going to just give him $3.3 million?
A.
Based on the information on this 2020 1040, the refund was
generated or came about from the withholdings amount listed on
the return.
MS. CONNORS: And if we could go to Page 13 of this
tax return. And zoom in on the whole W-2.
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BY MS. CONNORS:
Q.
Now, here, is this where there is the wages identified and
that tax withholding number identified?
A.
That is correct.
Q.
And nothing on the W-2, this W-2 does not say that the
federal tax was zero?
A.
No, this -- the W-2 has the information from the earnings
and the income from that year.
Q.
Okay. Now, this W-2, it's issued to Carl Torjagbo, and it
has the employer as Kremkov Industries.
You're familiar with whether or not that is
Carl Torjagbo's company?
A.
Yes, it is.
Q.
And so in terms of the W-2, it would be someone associated
with -- Kremkov Industries would have to be the one to say
that this is the amount that was paid?
A.
Generally that's how it works, yes.
Q.
And in terms of a W-2, it is supposed to reflect accurate
information?
A.
That is correct.
Q.
And it's supposed to say the correct wages, it's supposed
to say the correct tax withholdings, the other Social Security
wages and taxes withheld, all of that should be correct?
A.
Correct. The importance of the W-2 is that's the main
piece of information that a taxpayer uses at the end of the
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year to file their tax return, income and withholdings.
MS. CONNORS: And if we could bring up side by side
with this Government's Exhibit 503 again.
BY MS. CONNORS:
Q.
And, Mr. Hazel, we just looked at the Schedule E that
listed an EIN for Kremkov of 8332. What EIN is on the W-2?
A.
On the W-2, if you could blow that up just a little bit.
Okay. The EIN listed on the W-2 at Line B is 83-1821377.
Q.
And then looking at Government's Exhibit 503, is that EIN
the one that is in the name Carl D. Torjagbo?
A.
Yes, it is.
Q.
And for that EIN, it is not associated with the name
Kremkov Industries?
A.
It is not.
Q.
Now, have you previously reviewed information from
TurboTax?
A.
Yes, I did.
Q.
And are you aware that there were rejected tax filings,
essentially attempts?
A.
Yes, there was a couple of rejected filing attempts.
Q.
Now, were you able to search IRS's system to see if under
this Social Security number, 0540, there had been rejected
attempts at returns during 2020?
A.
Yes, I was.
Q.
And was there -- do those rejections, are they coded?
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A.
Yes, they are.
Q.
And were you able to compare the kind of rejection or
error code in IRS's system with what was reflected in the
TurboTax records?
A.
Yes, I was.
Q.
In terms of that error, did it relate to the EIN and the
tax year?
A.
Yes, it did.
Q.
Could you explain that?
A.
Yes. So basically when you make an attempt, an electronic
attempt to file a tax return with the
Internal Revenue Service, one of two things is going to
happen. They're going either to accept it or they're going to
reject it. And for whatever reason or reasons they've
rejected, there's codes. And someone like myself, an IRS
employee, we can look up the codes. Everything the IRS has is
in codes, so you have to look it up.
So when I looked up the codes of the two rejection
attempts, it said it was based off the EIN listed in the
return, which would be the EIN listed on the W-2s.
Q.
Okay. Now, this return that's in Government's
Exhibit 201, is that the one that actually went through to the
IRS?
A.
I believe so, yes.
Q.
Now, that W-2 lists the 1377 EIN. And looking at 503, was
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that one established in September of 2018?
A.
That is correct.
Q.
Now, this return is in 2020. So the W-2 is listed as
2020. Since 2018 is before 2020, would that have created a
problem?
A.
It would not.
Q.
Now, for the EIN 8332 and 7540, would that create a
problem for a 2020 tax return?
A.
Yes, if those -- either of those EINs are listed, it
would -- in most cases, it would cause a rejection because the
businesses were established in January of 2021, you're filing
a tax return for 2020, so the businesses were established
after the tax year.
Q.
Okay.
MS. CONNORS: And if we could pull up Government's
Exhibit 504. And if you'll kind of zoom in on sort of the
pink area and then that white column on the side, please.
BY MS. CONNORS:
Q.
And you testified earlier that you had had an opportunity
to ensure that this information was correct for this summary.
A.
That is correct, yes.
Q.
Now, here is this reflecting the rejected returns, the
ones that got an error message on TurboTax's system?
A.
Yes, they are.
Q.
And looking at the EIN on the Form W-2 for that line, were
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the rejected returns trying to use the 7540 and the 8332 EIN
number?
A.
That is correct.
Q.
And does that mean that they got rejected because those
EINs were not created until January of 2021, after calendar
year and tax year 2020?
A.
In most cases, that's why, yes.
Q.
Okay.
MS. CONNORS: And if you could please pull back up
201 for me. And if you will go to Page 17. Yes.
BY MS. CONNORS:
Q.
And hopefully this won't be too difficult to read. But
can you kind of explain, there's sort of two kind of sections
here, where there's the bold additional return summary data.
Where is the information there coming from?
A.
That's all coming from when the IRS received a tax return.
Q.
And is it, when it's being received, transmitted
through -- here through TurboTax?
A.
Correct, through the -- basically the Internet, yes.
Q.
And then the top portion, is that when the IRS actually
got it into their system?
A.
Yes.
Q.
And the very top line, what was the receive date?
A.
The receive date listed is February 13th of 2021.
Q.
And here, is there the date of birth listed ending in
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1979?
A.
Yes, it's September 10th, 1979.
Q.
And this is for the return with a Social Security number
ending in 0540?
A.
That is correct, yes.
Q.
And you had mentioned a pin before. Does it indicate what
type of pin was used?
A.
Listed pin type is self-selected online.
Q.
Does that just essentially mean that the individual was
able to make up their own number?
A.
That is correct.
Q.
Okay.
MS. CONNORS: And if we can pull up Exhibit 212,
please.
BY MS. CONNORS:
Q.
Mr. Hazel, can you tell us what -- if -- what this
transcript relates to?
A.
Yes. This is a wage and income transcript, so this would
list all the income that was reported to the
Internal Revenue Service for one specific tax year for a
specific tax ID number for an individual.
Q.
Okay.
MS. CONNORS: And if we can kind of zoom in on that
part. Yes, that's probably good.
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BY MS. CONNORS:
Q.
So here at the very, very top, does this have the
Social Security number that you researched?
A.
Yes, it does.
Q.
Was it the one ending in 0540?
A.
Yes, it is.
Q.
And it says tax period requested, December 2020. Is this
only capturing that month and year?
A.
That's for the entire year ending in December of 2020.
Q.
Okay. So is that kind of just sort of the IRS's unique
way?
A.
Yes, it is.
Q.
Now, here -- there it says Form 1099-INT and then payor is
PNC bank. What is this reporting?
A.
So basically, PNC Bank reported to the IRS on a Form
1099-INT, interest. And then they have the recipient's name
underneath it, Carl Torjagbo. And it would list if there was
any amounts paid for interest for that year.
Q.
So in terms of this particular transcript for 2020, under
the Social Security, 0540, if there had been any federal tax
withholdings, submitted by a company, would it have been
reflected on this transcript?
A.
That is correct.
Q.
So this transcript, the wage and income transcript is
supposed to capture everything?
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A.
The wage and income transcript is built to report anything
listed under the Social Security number, so a 1099, interest,
your W-2 withholdings. Even if you had any gambling winnings,
it would be like -- under a 1099-G. If you hit the lottery,
went to a casino or whatever and the casino reported it to the
IRS, that will all be listed there.
Q.
Okay. And in terms of --
MS. CONNORS: If we can back out of that. And if you
will scroll to the second page.
BY MS. CONNORS:
Q.
There's two bold headings for Form 1099-INT again. Is
that reporting the same thing, interest from a bank?
A.
That is correct.
Q.
And if we move to Page 3, is that just kind of the
remainder of that 1099?
A.
That is correct.
Q.
Now, for -- is this the extent of this transcript in
regards to all wage and income for 2020 for looking at the
Social Security number ending in 0540?
A.
This wage and income transcript reflects all income that
was reported to the IRS under that tax ID number.
Q.
Now, if a -- if federal tax withholdings had been paid to
IRS, would it appear here?
A.
Yes, it would.
Q.
And in terms of W-2, if the W-2 had been -- had gone
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through to the IRS from a company, would that get reflected
here?
A.
Yes, it would.
Q.
Now, we just looked at a W-2 associated with the tax
return -- I'm sorry, with the Exhibit 201, again for this
Social Security number.
Can you explain is -- that W-2 that is the data for a
W-2 transmitted with a return, is that really the official
W-2?
A.
What -- when you mean official W-2, I mean, there is --
Q.
Well --
A.
Per my research, there was no W-2s. Because the
information will reflect on the wage and income, but there was
a W-2 on the tax return.
Q.
Okay. Now, if someone is filing a tax return and
indicates that they have a W-2, it fills out that information,
will IRS receive that information as a W-2?
A.
That is correct.
Q.
Okay. So it is not that that W-2 had ever been
transmitted before to IRS?
A.
That is correct.
Q.
It just sort of gets created and attached, if you will, to
the tax return?
A.
Because it was attached to the tax return, that is
correct, yes.
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MS. CONNORS: Your Honor, I'm not sure if you wanted
to take an afternoon break.
THE COURT: I do. I do. But I didn't want to
interrupt you.
Are you almost done with your direct?
MS. CONNORS: I do have some more, but this would
probably be a good time.
THE COURT: All right. Let's take a short ten-minute
break, stretch your legs, get some coffee. Do what you want
to do and we'll be back in 10 minutes.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: You can step down. Thank you.
THE WITNESS: Thank you.
(Whereupon, a recess was taken.)
THE COURT: I want to make sure that we have time to
do the jury instructions, so we're going to stop somewhere
around 4:30ish. Okay?
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. Y'all can be seated.
Go ahead, Ms. Connors.
MS. CONNORS: Thank you, Your Honor.
I'm sorry. 201A. Can you pull that up?
BY MS. CONNORS:
Q.
And it's hard to see right now. We'll blow it up. But
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are you familiar with account transcripts?
A.
Yes, I am.
Q.
Okay. Now, for this account transcript, does this relate
to the Social Security number ending in 0540 that we were just
going over the return for?
A.
Yes, it does.
Q.
Okay.
MS. CONNORS: And if we could maybe go to the top
section until maybe you hit transactions.
BY MS. CONNORS:
Q.
And what's the purpose of this account transcript?
A.
So the main purpose of the account transcript is put in
place for the taxpayers. So you can see any kind of
transactions that have taken place on your account for that
specific tax year.
It will show if your tax return was filed, what kind
of a filing status you have, were there any adjustments made,
were there any payments made or you received a refund.
Anything that has taken place, any transaction that's taken
place for that specific tax year should be listed on an
account transcript.
Q.
Okay. So for this transcript, is it reflecting the tax
year of 2020?
A.
Yes, it is.
Q.
Okay. And at the top, there's a form number on the left
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side, and all the way over, there's 1040. So is this related
specifically to the 1040 that was filed in 2020 under the
Social Security number ending 0540?
A.
That is correct.
Q.
Now in terms of this transcript, is -- you mentioned it's
kind of making any adjustments that the IRS had to make
related to the refund amount. Would that include like what
you talked about with the stimulus payments earlier?
A.
Yes.
Q.
And would it also reflect any other changes related to
deductions in the amount of the return that -- the refund that
was requested?
A.
Yes, it should.
Q.
Now, in terms of this transcript, it -- right there, kind
of in the middle of the page, has account balance zero.
And in terms of the account balance, here there was a
refund requested. Was that refund paid out?
A.
Yes, the refund was issued.
Q.
So does the IRS then owe the taxpayer money for this
return or has the refund already been issued?
A.
Yes, it has been.
Q.
Okay. So in terms of account balance, is that reflecting
that the IRS has essentially balanced out this account in
regards to this tax year?
A.
That is correct.
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Q.
Now, although it says zero and that refund was paid, is
there anything about this transcript that means that that
refund was actually owed to the taxpayer?
A.
It does not.
Q.
So this is not a sign that the IRS has said, no, actually,
we made a mistake and there actually were tax withholdings and
so that tax refund should have gone out?
A.
That's correct.
Q.
And you just mentioned, was a tax refund issued on this
account?
A.
Yes, it was.
Q.
Okay.
MS. CONNORS: Okay. And if we could pull up
Exhibit 201B.
BY MS. CONNORS:
Q.
And in terms of this refund, was it paid by check?
A.
Yes, it was.
Q.
And do you see a date on the check? There's a lot of
numbers, but does it look like April 23rd of 2021?
A.
Yes, it does.
MS. CONNORS: And so that the jury can see it, can
you zoom in? There you go. Okay.
BY MS. CONNORS:
Q.
So this was -- does that mean this check was essentially
cut by the U.S. Treasury on or about April 23rd of 2021?
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A.
That is correct.
Q.
And since this is a check, would it have had to have been
mailed?
A.
Yes.
Q.
So then would there have been some additional time period
for the mailing to occur?
A.
There could have been, yes.
Q.
And in regards to the amount of the refund check, is it
$3,366,240.76?
A.
That is correct.
Q.
Now, if IRS is going to send out a refund check, does it
specifically send out any kind of notice in advance saying
we're issuing your check on this date? We're going to put it
in the mail on this date and you will receive it on this date?
A.
If it's just a basic refund check, the IRS, they don't
send a letter for every refund they send out.
Q.
And here, even though it was a large refund -- refund
amount, is it still a basic Treasury check?
A.
It looks -- it appears so, yeah.
Q.
And I just wanted to get a bit more specific. In regards
to this check, we've talked about that the stimulus payments
were deducted from the full refund amount that was requested
on the tax return.
Was anything else also deducted from the tax return?
A.
I believe there were two offsets. The taxpayer owed money
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to the Internal Revenue Service for previous tax years, I
believe it was either 2013 and '14 or '14 and '15, so it's
just standard procedure. If money is owed to the IRS, before
they send you your refund, they're going to take their money,
all right. And then whatever the remaining amount is what
you're entitled to as your refund.
So basically it squares out, you no longer have a
balance, no penalties, no interest, washed off, remaining
amount, that becomes your refund.
Q.
Okay. Now, in here, you've testified that the
defendant -- there is no record of any tax withholdings
actually being paid to the IRS in 2020?
A.
That is correct.
Q.
So does that mean that if those back taxes were
essentially deducted from the refund, but the refund was not
owed to begin with, are the back taxes still owed?
A.
The taxes will be owed, yes.
Q.
Okay.
MS. CONNORS: And if we could pull up Exhibit 202.
BY MS. CONNORS:
Q.
And, Mr. Hazel, you're familiar with an additional tax
return for 2020 filed in the name of Carl Torjagbo?
A.
I am, yes.
Q.
Now, for this tax return, was there a different
Social Security number used?
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A.
Yes, there was.
Q.
Now, in terms of IRS tax returns, is an individual
expected to only file one tax return?
A.
That is correct.
Q.
Now, if there had been a mistake or something like that on
a tax return, would you be able to maybe file an amended one
or corrected one, something like that?
A.
Correct. Generally, if a taxpayer needs to make an
adjustment or made an error, needs to add something else,
they'll file an amended return just to, you know, make the
adjustment or correction, make the IRS aware, hey listen, I
made a mistake, I forgot to include this W-2 or put the number
in the wrong spot, this is what the return should look like.
Q.
Now, if someone filed a tax return, or they tried to file
two tax returns using the same Social Security number on both
returns, would the IRS accept and process two tax returns that
are purporting to be filed under -- for the same individual
with the same Social Security number?
A.
Generally, the IRS will only accept one return per tax ID
number.
Q.
In this circumstance, since there were two different
Social Security numbers used, did that make it -- increase the
possibility that IRS would actually receive and process the
two different tax returns?
A.
It would make it more possible that the IRS actually
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accepts the return. But processing, you know, they may take a
closer look at it.
Q.
Okay. But in terms of the acceptance, is that kind of
just in terms -- does that mean it's accepted -- in the kind
of filing system, it's kind of accepted as a return that was
filed?
A.
Correct.
Q.
And then the processing is what sort of happens after?
A.
Correct. That's basically completing the return, going
over it line by line saying check, looks good. If it's a
refund, send a refund out.
Q.
So if the same Social Security number was used, the second
return may have just gotten rejected.
A.
That mostly likely would have gotten electronically
rejected, because the tax ID number was already used.
Q.
In terms of this 1040, does it list a Houston, Texas
address?
A.
Yes, it does.
MS. CONNORS: And if we can back out of that area.
And if you'll go to all of the numbered lines.
BY MS. CONNORS:
Q.
Now, for this, this tax return, were $9,999,360, was that
what was reported as wages, salaries and tips for
Carl Torjagbo?
A.
That is the amount listed on Line 1, yes.
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Q.
Okay. And in terms of the information in Line 8, is there
a negative number, negative $8,999,360?
A.
Yes, there is.
Q.
And then in Line 9, there's a figure of exactly
$1 million?
A.
That is correct.
MS. CONNORS: And then if we could go to Page 2 of
that exhibit.
BY MS. CONNORS:
Q.
Okay. Now, for this return, we had looked at the
Exhibit 201, the tax return under 0540 that resulted in that
$3.3 million check. And it had reported some federal income
tax withholdings as well in Line 25.
Here, is there also tax withholdings reported for
Line 25A?
A.
Yes, on Line 25A under the federal taxes withheld from
your W-2, the amount listed is $3,365,212.
Q.
And then is there an additional amount of withholdings
from that other form?
A.
Yes, there's an additional amount listed on Line 25C of
$68,394.
Q.
So in terms of this return, have you had an opportunity to
look to see if the Social Security number ending in 6010, if
the IRS had any record of federal tax withholdings being paid?
A.
There was zero federal taxes withheld from this tax ID
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number to the Internal Revenue Service.
Q.
Now, in terms of the overall information in this return,
have you had a chance to look at everything before?
A.
Yes, I have.
Q.
Similar to the last return that we looked at, does this
return also indicate that there were some non-passive losses
on a Schedule E?
A.
I believe so, yes.
Q.
And before I get -- turn to that page, on this particular
tax return under the Social Security number ending in 6010,
was a refund being requested?
A.
The refund amount being requested on Line 35A is
$3,015,573.
Q.
And in terms of the 1040 here, is it identical to other
1040s in the sense of this is a standard form, it still
includes the signature requirement and also still includes the
information that it's -- you're declaring under penalty of
perjury that the information in the return is correct?
A.
That is correct. This is a standard tax year 2020 1040.
Q.
And in terms of this return for the electronic signature,
is it dated February 12th of 2021?
A.
Yes, it is.
Q.
Okay.
MS. CONNORS: And if we can zoom out of that so we
can see the bottom part.
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BY MS. CONNORS:
Q.
Here was there anyone listed as a paid preparer?
A.
No paid preparer listed on this return.
Q.
Okay. And if someone was not a paid preparer, was just an
unpaid preparer, maybe a friend, someone else who was going to
be the person inputting the information for this return, would
that have to be based on accurate information?
A.
Yes, it is.
Q.
And is it still the responsibility of the taxpayer to
ensure that accurate information is being transmitted to the
IRS for this return?
A.
It is always the responsibility of the taxpayer.
MS. CONNORS: And if we could go to Page 15 of this
exhibit.
BY MS. CONNORS:
Q.
Now, we saw in Exhibit 201 that there was a Schedule E,
and specifically, we pulled up Page 2 of that Schedule E.
Does this one also indicate that Kremkov Industries
is a business in that Line A?
A.
That is correct.
Q.
And now for this return is there a EIN that's 7540?
A.
Yes, it is.
Q.
On this return, was there also an amount for non-passive
losses?
A.
Yes, there is.
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Q.
And what is that number?
A.
The amount listed under non-passive losses on Line A under
Column I is $9,999,360.
Q.
And so, Mr. Hazel, can you explain what happened with this
return in regards to -- we just saw that figure of a little
over $3 million being the requested refund amount.
Did the same thing happen with this return that
happened on the first one in the sense that the non-passive
losses entirely offset the earnings?
A.
That is correct.
Q.
And as we saw before, this tax return also indicated that
there were substantial tax withholdings, over $3 million in
tax withholdings, under the Social Security number 6010?
A.
That is correct.
Q.
In terms of that $3 million refund amount, is that because
of the offset of the earnings and the losses, then you're
looking at the amount that was claimed as additional
withholdings over and above that?
A.
That is correct.
Q.
Now, in regards to this tax return, did this tax return
end up getting paid out?
A.
It did not.
Q.
And why not?
A.
It could be -- and I'm not certain that the IRS saw --
MR. FINLAYSON: Objection. I'm going to object.
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THE COURT: He can't speculate. You can ask him if
there's possibilities, if he knows of any. But he can't
speculate. If he doesn't know, he doesn't know.
MS. CONNORS: Okay.
BY MS. CONNORS:
Q.
In terms of this particular tax refund, there's -- nothing
goes out. Do you know if IRS was able to associate two
returns to Carl Torjagbo?
A.
Based on the tax ID numbers, there's two ID numbers. But
the taxpayer is only allowed one ID number, one tax return.
MS. CONNORS: And if we can go to Page 25 of this
exhibit.
BY MS. CONNORS:
Q.
Okay. And similar to Exhibit 201, in terms of the bottom
half of this page, is this the information coming from
TurboTax?
A.
That is correct.
Q.
And then the top portion, is that the information from
when IRS receives the return transmittal from TurboTax?
A.
That is correct.
Q.
And for this return, did IRS receive it on February 13th
of 2021?
A.
That is correct, yes.
Q.
And for this return, was date of birth in 1975 transmitted
as part of that data?
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A.
Yes, it was.
Q.
Now, the signature date that we already saw was on
February 12th of 2021; is that right?
A.
That is correct.
Q.
Okay. And can that sometimes happen that the return takes
a little longer than expected to go from TurboTax to the IRS?
A.
It -- the return could have been electronically signed by
the taxpayer and then transmitted through TurboTax or
whatever, you know, service -- software they're using. And
there could be -- you know, if they sent it later at night,
the IRS is not -- may not receive it until the following day.
Q.
Okay.
MS. CONNORS: And if we can pull up Exhibit 213,
please.
BY MS. CONNORS:
Q.
Now, we looked earlier at a wage and income transcript
under the Social Security ending in 0540.
In terms of this wage and income transcript, is it
for the other Social Security number ending in 6010?
A.
Yes, it is.
Q.
For -- under that Social Security number, did you find any
information about wages and income?
A.
As you can see, based on the wage and income transcript
under that tax ID number, the IRS did not receive any income
information for that year.
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Q.
So does that mean no W-2 was recorded by the IRS for that
tax year?
A.
No W-2s, no 1099s, no income reported.
MS. CONNORS: And I apologize, I'm going to back up
to Page 17 real quick on this one. Oh, I'm sorry, on 202.
And if we can zoom in on this. And if we can also
pull up Government's Exhibit 503. That should be good. Thank
you. Okay.
BY MS. CONNORS:
Q.
Okay. I realized I forgot to show you the W-2 for that
tax return we were going over.
So on this W-2, is this the same circumstance that we
had before, where W-2 information is being reported in the tax
return so this kind of form gets filled out and transmitted to
IRS?
A.
That is correct.
Q.
But the actual transcript of wages and earnings for the
Social Security number ending in 6010, there's no record of
the actual W-2 coming through?
A.
No record on file.
Q.
Is the employer identification number used on this W-2,
does it end in the 1377?
A.
Yes, it does.
Q.
And in terms of reminding the jury, for the -- that EIN,
what was the establish date for the 1377?
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A.
The establish date for that business is September of 2018.
Q.
But the business associated with 1377 is not
Kremkov Industries?
A.
It is not.
Q.
And are you familiar -- did you get an opportunity to
review the TurboTax records in terms of a prior rejected
return that had been filed under 6010?
A.
Yes, I did.
Q.
And in reviewing that information, was there an error code
similar to what we saw in Exhibit 201?
A.
Yes, there was.
Q.
Was that error message related to a different EIN number
originally being used on that W-2 that was not issued --
that's one of the EINs that was not issued until 2021?
A.
Yes. The error message was the same as before indicating
that the EIN, there was an issue with that.
Q.
All right.
MS. CONNORS: And if we could go to Government's
Exhibit 101.
BY MS. CONNORS:
Q.
And, Mr. Hazel, do you see that this relates to a paycheck
protection program?
A.
Yes, I do.
Q.
And is the business identified as Kremkov Industries?
A.
Yes, it is.
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Q.
And there is a business EIN, the same one -- one of the
ones we've been looking at today, the 7540 listed?
A.
Yes, it is.
Q.
In terms of that EIN, have you had an opportunity to
research if any tax withholdings, federal tax withholdings
were ever paid to the IRS related to employees of that EIN?
A.
There was no tax withheld and paid over to the
Internal Revenue Service.
MS. CONNORS: And if we could go to Page 10 of this
exhibit.
BY MS. CONNORS:
Q.
And, Mr. Hazel, does this indicate that it's a payroll
journal from the month of February, 2020 for
Kremkov Industries?
A.
Yes. That's what it says, yes.
Q.
And do you see at the top above the bold line that there
is an acronym for fed tax?
A.
Yes, I do.
Q.
And is fed tax supposed to stand for federal income tax?
A.
That is correct.
Q.
And is there also an acronym for FUTA, federal
unemployment tax?
A.
That is correct.
Q.
FUTA, what -- is there a document that that typically is
reported on?
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A.
Yes. The FUTA, federal unemployment tax, the FUTA is the
Federal Unemployment Tax Act that's been put in place, so
companies with employees -- with employees generally are
required to file a yearly form, a Form 940, and they have to
pay into it. They're basically help funding the unemployment
system.
Q.
Okay. And in terms of federal income tax withholdings, is
there also a form that is supposed to get submitted to the IRS
reporting the federal income taxes withheld?
A.
Yes, there is.
Q.
And what form is that?
A.
Generally, depending on the size of the company, anybody
more than I believe it's 5 employees or over $5,000 paid in
wages, you're required to file a quarterly tax return, it's
the 941.
And in the 941, the employer lists the name of the
company, tax ID number and so forth, but what it really lists
is the number of employees they had for that quarter, the
number -- the amount of wages they paid in that quarter and
the amount of withholdings that they withheld, your federal
taxes that they withheld and paid to the
Internal Revenue Service for that quarter.
Q.
Okay.
MS. CONNORS: Now if we can zoom out of that portion.
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BY MS. CONNORS:
Q.
Just looking here at just this page of this payroll, does
it indicate that federal taxes were being withheld from pay?
A.
Yes, it does.
Q.
And the FUTA just says zero on this page; is that right?
A.
Yes, it does.
Q.
In terms of your research related to the EIN ending in
7540, have you been able to see any tax withholdings from any
employees associate with that EIN?
A.
There were no tax withholdings reported to the
Internal Revenue Service.
Q.
And if any taxes had been withheld from employee's pay,
would IRS have a record of it?
A.
Yes, they would.
MS. CONNORS: And if we'll go to Page 80 of this
exhibit.
BY MS. CONNORS:
Q.
Is there a grand total indicating federal tax, taxes
withheld for the month of February 2020 of $433,043.27?
A.
Yes, it is.
Q.
Is that consistent with anything that you have been able
to research for 2020 under EIN 7540?
A.
No, it is not.
MS. CONNORS: And if we could go to Page 81.
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BY MS. CONNORS:
Q.
And here, is it indicating at the top that this would be
full year of 2020, federal -- I'm sorry, payroll information?
A.
Yes, it does.
Q.
Okay. And here is there also a column for fed tax and for
FUTA?
A.
Yes, there is.
MS. CONNORS: And we're going to go down to Page 122.
BY MS. CONNORS:
Q.
Okay. And for the grand totals listed there at the
bottom, does this indicate that $5,096,786.12 was paid to the
IRS for federal taxes for employees?
A.
Yes, it does.
Q.
Is that accurate?
A.
That is inaccurate.
Q.
And in terms of the FUTA, does it indicate $20,707.31
being paid?
A.
Yes, it does.
Q.
Is that accurate?
A.
It is inaccurate.
MS. CONNORS: And if we can go to Page 126.
BY MS. CONNORS:
Q.
And here, do you see --
MS. CONNORS: I'm sorry. Let's go to 125 for the
first page of that.
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BY MS. CONNORS:
Q.
Okay. And are you aware that a 1040 had been submitted to
Chase Bank in relation to a PPP loan?
A.
Yes, I was.
Q.
And this 1040 lists 0540?
A.
That is correct.
MS. CONNORS: And if we can go to Page 129.
BY MS. CONNORS:
Q.
The EIN that was used for this return listed in the
Schedule, is it 7540?
A.
That is correct.
MS. CONNORS: And if we can go to Page 141.
BY MS. CONNORS:
Q.
And here, is this a -- the Form 941 that you referenced
earlier?
A.
Yes, it is.
Q.
Now, have you been able to research whether any 941s were
filed?
A.
Yes, I was.
Q.
Were any?
A.
There were no returns filed and received by the IRS.
Q.
And these returns are reporting amounts allegedly withheld
for employees of Kremkov Industries. Is that the purpose of
this form?
A.
That is correct.
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Q.
Is this information in any way consistent with what you
were able to research and find in IRS's system?
A.
I could not find any returns filed and received with the
IRS.
Q.
And, Mr. Hazel, did you have an opportunity to look at
some of the 941s associated with this PPP application?
A.
I was.
Q.
So to avoid having to actually pull all of them up, but
were four issued for each quarter of 2020?
A.
That is correct.
MS. CONNORS: And if we can go to Page 152.
BY MS. CONNORS:
Q.
And was a 940 submitted with the PPP application?
A.
Yes, it was.
Q.
And is this 940 consistent with what you were able to
research in IRS's system?
A.
I could not find a 940 on file with the IRS.
Q.
Okay.
MS. CONNORS: And in terms of the information, if we
could pull up Exhibit 204.
BY MS. CONNORS:
Q.
And what is this document?
A.
This is a Form 3050, certification of lack of record.
This is basically saying that the company in the middle,
listing the company and the tax ID number and the address and
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the Form 940 and 941s have description of information right
underneath there, there are no returns.
And to be more specific, if you go down to the
bottom, it has between March 31st of 2014 to December 31st of
2021, so the first quarter of 2014 to the last quarter of
2021, there are no Forms 940s, nor Forms 941s on file with the
IRS for that company.
Q.
Okay. And just to confirm --
MS. CONNORS: If we can back out of that.
BY MS. CONNORS:
Q.
-- is this related to the EIN ending in 7540?
A.
Yes, it is.
Q.
Did you also do similar research related to the other two
EINs that are on the summary, the one ending in 8332 and the
one ending in 1377?
A.
Yes, I did.
MS. CONNORS: If we could pull up Exhibit 205.
BY MS. CONNORS:
Q.
For the same timeframe, were you able to find any 940 or
941 being filed with the IRS related to Kremkov Industries'
EIN ending in 8332?
A.
I was unable to find any returns on file.
MS. CONNORS: And if we can pull up Exhibit 206.
BY MS. CONNORS:
Q.
For the EIN issued in the name of Carl D. Torjagbo that
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ends in 1377, were you able to find any record of 940 --
940s or 941s between 2014 and December of 2021?
A.
I was unable to find any returns for -- during these
periods.
Q.
Okay.
MS. CONNORS: And if we can pull up Government's
Exhibit 504.
BY MS. CONNORS:
Q.
And is this a summary? We looked at part of it earlier.
A.
Yes.
Q.
Okay. Now, in terms of the kind of different-colored
blocks here, we have the 2020 forms, 1040 prepared on
TurboTax, the rejected ones.
And then in green, they're the two returns that were
processed or at least submitted to IRS?
A.
That is correct.
Q.
And then finally, we've seen that there was a 1040
submitted to Chase Bank in relation to the PPP loan and then
we also -- and then are you aware that there was also a 1040
that was submitted on May 7th of 2021 to Chase Bank?
A.
Yes, I was.
Q.
Okay. Now, looking across at the information, was
information changing on these different submissions of the
1040s? And I can perhaps be more specific with my question.
A.
Yes, please.
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Q.
So in terms of the rejected ones, we had looked at those
previously, you have the EINs on the W-2s, the EIN of 7540,
and then 8332.
A.
That is correct.
Q.
Okay. And those are the returns that got rejected and had
that error code related to the EIN wasn't even issued in 2020?
A.
Yes.
Q.
Okay. But then moving to the two tax returns that
actually succeeded in getting transmitted to the IRS, the one
that has the Social Security number ending in 0540 as well as
the one that we saw that did not get paid out that was -- that
ends in 6010, for both of those returns, do they list the 1377
EIN on the W-2?
A.
Yes, they do.
Q.
And now that EIN had been issued prior to 2020?
A.
Yes, it was.
Q.
So neither one of those got rejected?
A.
That is correct.
Q.
Now -- but even within those two returns, one has 7540 on
the Schedule E and one has 8332 on the Schedule E?
A.
That is correct.
Q.
And those are the two that actually got transmitted to
IRS, IRS got into their system?
A.
Yes.
Q.
Okay. Now, finally if we look at the 1040s that were
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submitted to Chase Bank, the first one from February 16th,
2021, associated with the PPP loan has 7540 listed on the
Schedule E.
A.
Yes.
Q.
Okay. And you may recall that the EIN on the PPP
application itself is that 7540 number.
A.
Correct.
Q.
So the EIN on the Schedule E matched what was -- matched
the company that was requesting the PPP loan?
A.
Correct.
Q.
But on May 7th of 2021, a different 1040 was submitted,
still under the Social Security number for Carl Torjagbo of
0540, but this time what changes?
A.
The EIN.
Q.
And is that the only EIN he had access to that was prior
to February 15 of 2020?
A.
Correct.
MS. CONNORS: Thank you.
THE COURT: Okay. Cross-examination.
MR. FINLAYSON: Thank you, sir.
CROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
Mr. Hazel, I have a few questions for you.
A.
Good afternoon, sir.
Q.
How are you?
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So if I understand, there was an EIN with a number
ending in 1377, right?
A.
Yes.
Q.
And that number was issued back in 2018?
A.
Yes. I believe September of 2018, yes.
Q.
Okay. And so that's obviously well before February 15th
of 2020, right?
A.
Correct.
Q.
So there were other EINs associated with Kremkov and my
client, Mr. Delano Torjagbo, there are other EINs as well?
A.
Yes.
Q.
And there's nothing wrong with having multiples, is there?
A.
No.
Q.
It can be for different companies or you could reorganize
a company, it's very -- it's common, right?
A.
There can be different EINs, yes.
Q.
Okay. You talked a lot about W-2 payments made into the
IRS. You were looking for records at the IRS of payments
being made in, correct?
A.
Do you mean the tax withholdings?
Q.
Tax withholdings. That's a good word.
A.
Yes, yes.
Q.
And that's a big deal, right, that's -- that's how the
government gets its money, right, is the tax withholdings.
A.
And that's how the taxpayer gets credit for their tax
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withholdings, yes.
Q.
And so you went -- how did you search for that?
A.
As an IRS employee, I have access to certain applications,
and the IRS master file. And then most times, you use -- you
start the search with a tax ID number and the name of the
individual or the companies.
And you can find different things, was there a tax
return filed, was there tax returns received, is -- were there
payments made. And as an IRS employee, like I said, I have
access to that.
Q.
So that means when somebody makes a payment to the IRS, it
needs to be logged in by somebody under the number that links
to the payor; is that fair?
A.
Right. The IRS requires -- if you're going to make a
payment to put your tax ID number on it. If you just send a
check to the IRS, they don't know who it belongs to.
Q.
Right. And there are -- there are multiple ways to make
payments to the IRS, right?
A.
Yes, there are.
Q.
You can wire money, can't you?
A.
I believe so.
Q.
You would have to -- I assume you would have to have the
wiring information for the IRS for some recipient to take that
money, right?
A.
I believe so.
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Q.
And have you ever seen that in the -- in the -- in your
many years, have you seen money wired in?
A.
I've seen it electronically transferred over, yes.
Q.
And I guess you can write a paper check to the IRS?
A.
Right. And once the IRS receives it, deposits it, makes
sure the check is a good check, the taxpayer or the business
will get credit for that payment.
Q.
And that's -- I gather that's like a line person like a --
what would you call the person that processes those checks
when they come in?
A.
I don't know. I've never processed checks.
Q.
So you don't know who does that?
A.
Someone in the Internal Revenue Service does, but I don't
know their title.
Q.
Okay. And I gather -- do you know what the title of the
person would be that would process the wires that come in?
A.
I do not know their title.
Q.
Okay. So let's say hypothetically, if you were working
for a U.S.-based company in another country, and you wired in
money from Europe or from Africa, that would -- I mean, people
do -- you do have people expatriates, people that have to wire
money back in to pay their taxes, right?
A.
So you're saying someone making a payment to the IRS?
Q.
Correct, from another country.
A.
Okay.
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Q.
And that -- I mean, that does happen, right?
A.
I believe so.
Q.
Okay. Have you ever seen how that gets logged in?
A.
I do not. Once again, I don't process checks or payments.
Q.
Okay. So many businesses and I guess self-employed
people, too, they have to file -- they file quarterly
withholding payments, right?
A.
Are you referring to the Form 941?
Q.
Not the form itself, just the money. I'm talking about
the actual payments for their own taxes.
A.
Correct.
Q.
And so they will send either a check or a wire, they'll
send that to the IRS in some form?
A.
Yes.
Q.
Okay. And that's kind of -- again, it's got to be logged
in, right?
A.
Yes, it does.
Q.
And by -- it needs to be with the right account number.
A.
Correct.
Q.
Okay. And you searched many -- you searched all kinds of
numbers for Mr. Torjagbo, right?
A.
That is correct.
Q.
And you're saying you didn't find -- you didn't find the
money being paid in?
A.
I didn't find any returns nor any payments made.
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Q.
Okay. Now --
MR. FINLAYSON: Can I see 201A? And can we make it a
little bigger. Let's stop at the top third. Yeah. That's
good. Thank you.
BY MR. FINLAYSON:
Q.
So you talked about this exhibit, this 201A, right?
A.
That is correct.
Q.
And let's start at the very beginning. The requested date
for this transcript is June the 4th, 2025; is that correct?
A.
That is correct.
Q.
And I guess it was cranked out or the response came across
on June the 4th, 2025, right?
A.
That is when I pulled the account, yes.
Q.
So you actually made this yourself?
A.
I requested it from the IRS system, yes.
Q.
Okay. And you said this was a document that was sort of
designed for the taxpayer's benefit? Is that what you said?
A.
Yes, it is.
Q.
Okay. And this tracking number, is that tracking number
just applied to this document, is that the tracking number?
A.
Yes, that's what it is.
Q.
Okay. So -- and this is a report for tax period ending in
12/31/2020.
MR. FINLAYSON: Can we highlight that?
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BY MR. FINLAYSON:
Q.
So that's -- that's the period you're asking about, right?
A.
This is specifically for tax year 2020, yes.
Q.
And you're asking -- again, you're asking this very year,
2025 is when you're asking, right?
A.
On June -- June 4, 2025, that is correct.
Q.
Okay. And you're requesting the taxpayer, we go down,
it's Carl Torjagbo, right?
A.
Yes, it is.
Q.
And there's an office address at 1855 Piedmont Road, Suite
100?
A.
That is correct.
Q.
Okay.
MR. FINLAYSON: And if we could take the middle third
of the page to zoom. Thank you.
BY MR. FINLAYSON:
Q.
And we see the very first line here. The very first line
says account balance. And we go across, we see that account
balance is zero, correct?
A.
That is correct.
Q.
And then the next line we see accrued interest, that's
also zero, right?
A.
That is correct.
Q.
And there's no penalty and no accruals?
A.
That is correct.
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Q.
Okay. We go further down, we see adjusted gross income
negative 799,949?
A.
That is correct.
Q.
Okay. And that's a -- so that's a tax loss, as we'd say,
right?
A.
That's a negative number, correct.
Q.
Okay. And then we have tax per return, $88,194. Is that
the amount of tax owed or the --
A.
Based on the return, yes.
Q.
Okay. And then we have the processing date of April 26,
2021.
A.
That is correct.
Q.
Okay.
MR. FINLAYSON: Can we see the bottom third or the
very bottom after transactions?
BY MR. FINLAYSON:
Q.
And we see the code 806?
A.
Yes.
Q.
W-2 or 1099 withholdings?
A.
Yes.
Q.
And that number is -- that's a negative, negative
$3,459,835, right?
A.
That is correct.
Q.
And then we have credit to your account, we see a $1,200,
that is the -- I guess that's the stimulus money we were
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talking about?
A.
That was the stimulus money during COVID, yes.
Q.
Okay. And then we see a refund issued. I guess that's --
again, that's the COVID money, right?
A.
That's, yeah, the $1,200.
Q.
Okay. And then there's another 600, kind of the same
thing?
A.
Correct.
Q.
Okay. And again, the very top of this, his balance for
2022 was zero, right?
A.
That what it reads, yes.
Q.
Okay. Now --
MR. FINLAYSON: And you can take that down. Thank
you.
BY MR. FINLAYSON:
Q.
So W-2s are, by their nature, they're created by the
employer, right?
A.
They should be, yes.
Q.
So it's not a -- a government agency doesn't make W-2s,
right?
A.
They do not.
Q.
So if -- so employers make W-2s, send them in if they are
for W-2 employees, right?
A.
That is correct.
Q.
There are also other kinds of employees, aren't there?
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A.
There could be, yes.
Q.
There are 1099 employees?
A.
That is correct.
Q.
Okay. So 1099 employees wouldn't be getting a W-2?
A.
No, they would be getting a 1099.
Q.
A 1099, okay.
You talked about the numbers -- and let me -- we have
two different -- two main different tax returns we're talking
about here, right?
Where with the one that paid out and then one that
didn't pay out, fair?
A.
Are you speaking specifically on the 1040s?
Q.
Yes.
A.
Yes.
Q.
Okay. And one was 0610. Is that the right number?
Sorry.
THE DEFENDANT: 6010.
BY MR. FINLAYSON:
Q.
6010.
A.
Okay.
Q.
And that's the one that didn't pay out, right?
A.
Is that the one with the Houston address?
Q.
Yes.
A.
Yes, that one didn't pay out.
Q.
And the other one is 0540?
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A.
Correct.
Q.
And that's the one that paid money, right?
A.
That issued the refund, yes.
Q.
Okay. And you talked through this a bit. There were
some -- besides the COVID adjustments, there were other
adjustments to that return or to that -- to that payment from
that return, right?
A.
That is correct.
Q.
Because what -- there was basically a reduction of the
refund by about $7,000, right?
A.
Are you speaking about the offsets for the money owed from
the previous years?
Q.
Correct.
A.
That is correct.
Q.
So there was money owed from like 2013 and what was the
other year?
A.
I think it was '14, '13 and 14.
Q.
So that refund was reduced by the $7,000 to pay for those
old debts?
A.
I don't think the exact amount, but, yes, they were
reduced to pay off previous debts with the IRS.
Q.
Okay.
MR. FINLAYSON: May I have one moment?
BY MR. FINLAYSON:
Q.
One last thing, so when you say negative, the account
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balance we were looking through?
A.
The account transcripts, yes.
Q.
When you see that, when you see negatives on that balance,
those are credits, right?
A.
Under the withholdings, the 806, that's the credit.
That's the withholding credit that was reported on the return.
Q.
Okay. And it actually showed -- it actually says that I
think on the transcript, that negatives are a credit?
A.
It is a credit, yes.
Q.
Okay. Thank you.
MR. FINLAYSON: Nothing further, Judge.
THE COURT: Okay. Any redirect?
MS. CONNORS: Yes, Your Honor briefly.
REDIRECT EXAMINATION
BY MS. CONNORS:
Q.
Mr. Hazel, you were asked about whether there could be
different forms of payment related to tax withholdings?
A.
Correct.
Q.
Okay. And you were asked about could expats be -- could
they make payments to IRS, people who no longer live in the
United States?
A.
I believe so.
Q.
Okay. But if anyone is making a payment to the IRS, would
IRS link that payment based on either an EIN, Social Security
number, some kind of information like that?
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A.
Yes. The IRS requires that you put some kind of
information on the payment to make sure that they know who to
give the credit to.
Q.
Okay. Now, in this case, what we saw was that, for
example, with be a PPP loan, four different 941s were included
with that PPP documentation. Did every single one of those
have an EIN on it?
A.
I believe so, yes.
Q.
So they had -- they actually have an EIN on it. So if any
withholdings were actually paid to IRS, it would not have been
difficult for that company to list their EIN?
A.
That is correct.
Q.
It would match, it should match what is on the 941, right?
A.
Right. And the business would get credit for those
payments.
Q.
And if someone is a sole proprietor and they're instead
using their Social instead of an EIN, they'd have had to put
that on the form and they should know that number?
A.
Right. Your tax ID number should be on the payment.
Q.
Okay. Now, you were asked about W-2s, that they're made
by an employer. And that perhaps there could be other things
like 1099s that are done instead of a W-2.
Here did we see multiple examples of W-2s?
A.
It was all W-2 information.
Q.
And every one of those W-2s said that it was from
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Kremkov Industries?
A.
That is correct.
Q.
And every single one of those W-2s identified an EIN?
A.
That is correct.
Q.
And so with that information, you would expect that then
that's actually going into IRS's system, if it's accurate?
A.
If it is accurate, it should go to the IRS.
Q.
And now you were asked about the negative number in front
of that $3.4 million figure on the transcript.
And you have testified a few times over that no
withholdings were associated with the Social Security number
ending in 0540.
In terms of that negative, is it negative on that
transcript because the refund was paid out?
A.
Yes. And it is negative on the transcript because those
numbers, the 806, which is the code for federal tax
withholdings, are all carried over from the return that the
IRS receives. They take the numbers, they carry it over to
the account transcript.
And then as, you know, time goes by and if there is
any further adjustments on that account, you would see it as
you go down as transactions if something was done with the
account.
Q.
Okay. So that number is actually because that is the
number that was on Carl Torjagbo's 1040?
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A.
Those numbers are just carried over from the return that
was sent to the IRS.
Q.
That does not mean that IRS has determined that they are
accurate?
A.
That is correct.
MS. CONNORS: Thank you.
MR. FINLAYSON: One quick question.
RECROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
Do foreign-based companies have to file 941s?
MS. CONNORS: Objection, Your Honor, beyond the
scope.
THE COURT: Grounds?
Overruled.
THE WITNESS: I don't know the answer to that
question.
MR. FINLAYSON: Fair enough. Thank you, sir.
THE COURT: Okay. Anything else?
MS. CONNORS: No, Your Honor. Thank you.
THE COURT: All right. You can step down.
Thank you, sir.
THE WITNESS: Thank you, Your Honor.
THE COURT: All right. That's as far as we're going
to go with you-all today. We've got some discussions to go
over about jury instructions.
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Okay?
We've got to keep moving on that so that we're ready
when the time comes.
Okay?
Any thoughts, concerns, questions for us?
All right. Are you going to talk about this when you
get home with anybody? No, right? Continue to abide all of
my instructions.
Did 8:30 work for y'all today?
All right. We'll be here ready to go at 8:30 in the
morning.
Thank you-all very much.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: All right. Y'all can be seated.
Are y'all ready to talk about jury instructions?
MR. FINLAYSON: One second.
MS. CONNORS: Yes.
MR. FINLAYSON: Ready.
THE COURT: I gave you all of the redlines so that
you would have what you gave me back.
MS. CONNORS: I don't think -- did we get a copy of a
redline?
THE COURT: I thought you got it at lunch.
MS. CONNORS: We only got the one snippet.
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THE COURT: Oh, do you have a big copy for all of
them?
LAW CLERK: I'll do it.
THE COURT: Oh, boy, it's going to take a little bit.
All right. We'll have them in a minute. Don't go anywhere.
You can do your cleanup.
MR. FINLAYSON: Can we go to the bathroom?
THE COURT: Yes. I want to try to get this done as
soon as we can. Okay?
(Whereupon, a recess was taken.)
THE COURT: Okay. So you have it with all of the
redlines just so you have my edits --
Y'all can be seated.
-- from where we were before. Okay?
I'm going to give you another version that's going to
get rid of all of these redlines when we're done, but this is
just for your tracking purposes. Okay?
MS. CONNORS: Your Honor, does the updated version
still have headers on it?
THE COURT: No.
MS. CONNORS: It just runs as text?
THE COURT: I'm going to give them a bunch of
different copies. It's not going to have headers or really
even page interruptions, things like that. Okay?
And I might move them around if there's a better
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order for them, but I'll give you that the next time. I left
it in this order because then you can see what's actually
removed rather than just -- what is actually omitted rather
than what is moved around. Okay?
I think there are very few things to talk about. Let
me get to it. I want you-all to spend some time tonight
making sure that I've gotten the numbers right.
If you look at Page 21, where I think I have gotten
the numbers of which charges are which, but I want you-all to
make sure of that. Okay?
And just because I have the pen, you-all are still
responsible for the instructions and making sure what I get
out there is correct. Okay?
MS. CONNORS: Judge, are you looking at a color
version? I can't tell where there was the change for Counts
Three and Four -- if the Four is actually marked out or not.
THE COURT: Let me see your version.
MS. CONNORS: It doesn't have an underline on it
right there. I can't tell.
THE COURT: Let me see. I think -- yeah, what can't
you tell?
MS. CONNORS: I can't tell if the Four is marked out.
THE COURT: Yeah, the Four is marked our.
MS. CONNORS: Okay.
THE COURT: It now says Two and Three rather than
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Three and Four.
MS. CONNORS: Okay.
THE COURT: Yes, I see what you mean. The Four looks
like --
MS. CONNORS: Because the line sits right there at
that bottom bar.
THE COURT: Yes.
MS. CONNORS: Thank you.
THE COURT: And I'll give you either first thing in
the morning or I can email you later today the clean version.
Are we going to close tomorrow? Is the government --
how are we doing on the case?
MS. CONNORS: We have two witnesses left. One is
going to be the agent where we're playing the transcript, the
recording. And I think that's now about 30 minutes or a
little less.
MR. EVERT: 35, yeah.
MS. CONNORS: For just that, that part.
And then afterwards, it will be someone going over
the financials, so I would guess we would maybe rest before
lunch or it might be right after lunch.
THE COURT: Okay.
MR. FINLAYSON: And, Your Honor I think our case will
take half a day, I mean, if that much. So we could close --
I'd love to close on Friday morning, if we could.
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THE COURT: I can't promise you that. I normally
would, but I can't promise you that. We lost almost half a
day yesterday. And I worry about going into Monday for that
one juror. Okay? But we'll see. Okay?
Let's see where we get to tomorrow. All right?
Okay. Can we go to aiding and abetting.
Do we need that charge?
MS. CONNORS: No, Your Honor. I think we can take it
out. I mean, it's always charged -- I mean it is the statute
that they're going to see in the indictment.
THE COURT: Okay. Well, then we ought to leave it
in.
Let's see. The other one, good faith defense, that's
to be determined, right?
MR. FINLAYSON: I think so.
THE COURT: Okay. Does that apply if he doesn't
testify?
MR. FINLAYSON: It probably would not.
THE COURT: Okay. All right. So the only one to
really discuss is knowingly and willfully.
I mean, the statute doesn't have willfully in it,
right? So what's the grounds to have it?
MR. FINLAYSON: I think it's just more of a general
intent. I think it goes with the notion or the burden or the
element of intent that they have to prove. I think -- I'm
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sure their cases say that it's covered by other things, but
it's sort of the -- that it's not -- well, it's in there. The
Eleventh Circuit had it in there. How's that?
THE COURT: What do you mean?
MR. FINLAYSON: I think the Eleventh Circuit had it
in the charge, that's why, that's in the pattern.
MS. CONNORS: Yeah, I think that instruction was
actually updated within the last year, I believe. And so now
where it used to have kind of the separate knowingly section
separate, willfully, they tried to combine it, but it's clear
from the pattern that you're supposed to choose if it's
applicable.
I would point out United States v. Newton, which is a
2019 Eleventh Circuit case. It's an unpublished case, but it
came out of our district, and it was one where they were
explicit that there is no willfulness requirement for mail
fraud and wire fraud. And it would certainly seem that -- and
the holding was related to, it's not a word in the statute, so
it shouldn't be really adding a burden that is not clear in
the statute.
THE COURT: I mean, I'm looking at the current
pattern charge for bank fraud. I don't see it in there.
MR. FINLAYSON: I think it's in the knowingly, it was
in the -- you know, there was part of knowingly and willfully.
It wasn't in the bank fraud charge. I think it's maybe in the
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general principles section.
THE COURT: I don't see it in the wire fraud. Are
you talking about it's in the general definition of knowingly?
MS. CONNORS: Yes, Your Honor. It's in the --
THE COURT: I know what you mean. In the base
offense instruction, it has the definition that has on the
same page knowingly and willfully?
MS. CONNORS: Yes, Your Honor. And again, that was
an instruction that was specifically modified. The
instruction number used to be -- I believe it was B9.1 and now
you see that there is a 9.1A that replaced it.
THE COURT: Yes.
MS. CONNORS: And so now it is just trying to put
both of those as options in one instruction. However, it's
clear if you pull that one up that it's not saying that you
have to give willful if you are giving knowingly. It is
supposed to be specific to the case.
And here, I would add that the government also
objects because, you know, willfulness in this sense is not
even the general willfulness, because the Eleventh Circuit
pattern instructions also talk about that in terms of
willfulness, you usually don't need a specific instruction,
that it's usually captured within the offense instruction.
This is more on the side of things like tax fraud,
which is not what we have here. We do not have tax fraud
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where there is a willful component, we have wire fraud. And
although that relates to the submission of tax returns, we
have not charged him with an actual tax offense, so the
willfulness would not apply.
MR. FINLAYSON: And for what it's worth, I think
that's probably why they charged it the way they charged it in
that probably the burdens are easier in a wire fraud than they
are in a tax -- a tax fraud case. So she is correct they
haven't charged the tax fraud. But at its heart, those counts
are tax fraud counts.
THE COURT: Yes. I think this is a good change to
the law. The concept of willfully get to the mens rea element
of a crime, which in many instances requires some
intentionality to do something that the law forbids.
But I think that that's subsumed within the other
elements of both the wire fraud and the bank fraud charges
here.
So I'm not going to -- it's also just sort of like,
hey, why would I tell them something -- the definition of a
word that is nowhere else in the instructions. What would we
tell them to do with it?
Willfully means this. We might as well, you know,
tell them any definition we want. They don't have any way to
apply it, they wouldn't know how to apply it, they wouldn't
know where to apply it.
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MR. FINLAYSON: It does feel like a general intent,
like a --
THE COURT: Well, you're saying that the absence of a
willful-type concept makes it a general intent crime?
MR. FINLAYSON: Yes.
THE COURT: I respect that argument. And I think
that that is a -- that in some instances, I think that applies
like in some securities fraud cases, it might apply. But the
problem here is that the other elements of the crimes charged
encompass that idea, a scheme to defraud, for example, in the
wire fraud. I think that encompasses that specific intent
that's necessary to not make it a general intent crime.
So I'm -- and again, unless we're going to rewrite
the entire instruction to tell them about some type of mental
element of the offense, what the mens rea is, something apart
from what's already in the pattern instruction, we're just
making it up, so we can't add something like willfulness where
Congress hasn't added that word, unless you have a broader
argument about criminal culpability that has not been made.
MR. FINLAYSON: I'm --
THE COURT: You're trying to circle around it because
of what I've said, but you haven't made it yet.
MR. FINLAYSON: Well, I thought --
THE COURT: And I don't know what it would be. You
would have to tell me what it is you want to do.
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MR. FINLAYSON: Yeah, I guess the reason I wanted it
in there is because I think it's a general intent. He didn't
intend to defraud and so you didn't have intent to defraud
somebody or defraud -- yeah.
THE COURT: Right. But the problem is if I were to
include the term willfully as you have it in your proposal,
I'd then have to go back and tell them how to use it. Right?
I'd have to then say as an element of this, you must
decide that they did whatever willfully, right?
And that is not part of the charge. It's not part of
the statute, it's not part of the charge. I'm adding an
element there. Right?
Otherwise, you might as well, I don't know, I can't
think of the right word, but you could just give them any old
word. It doesn't mean anything unless you tell them how to
use it.
MR. FINLAYSON: What is --
THE COURT: Right. You would have to give them some
definition of, I don't know, aglet. And then how would they
know what an aglet is and where to use the word aglet? I
can't think of another obscure word other than that, but okay.
At any rate, I don't see how a definition hanging
around helps them in any way.
Okay. The real one is -- so we have a two-part for
the proposed change to the bank fraud, which is requested 24,
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and the wire fraud, requested 26.
And that is -- so there's two questions, the first
one is: Is there any opposition to the change that has been
included, which is, as you can see, for example, on Page 48,
to obtain the victim's money or property, proving intent to
defraud does not require proof that the defendant acted with
the intent to leave the victim economically worse off or cause
the victim a net pecuniary loss. That's the closest I can get
to the language of Kousisis.
MS. CONNORS: Kousisis.
THE COURT: Kousisis.
MS. CONNORS: Yes.
THE COURT: Any objection to that language by the
United States?
MS. CONNORS: Your Honor, only in part. Our position
would be that the or caused the victim a net pecuniary loss
would not be necessary. And it seems almost like it's saying
the same thing.
THE COURT: Do you want to leave it at -- it does --
leave the victim economically worse off?
MS. CONNORS: Yes. Because I think that's language
directly from Kousisis. And since we were in a circumstance
of that coming out, I think that would be appropriate, but
yes, our concern would just be the or after.
THE COURT: Well, the Supreme Court says both ways in
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Kousisis.
MS. CONNORS: Kousisis.
THE COURT: Kousisis. And so it just appears to me
as though you're better off telling a jury two different --
the same thing, but maybe it resonates with one of them one
way and one the other way, but that's fine. I don't really
care. So we'll just end that sentence at -- well, let me say
this, I know, Mr. Finlayson, you disagree with any of this.
MR. FINLAYSON: That's true.
THE COURT: But do you like it more with or cause the
victim a net pecuniary loss?
MR. FINLAYSON: I think you're right. I don't like
any of it, so I do object on ex post facto grounds. I like --
I mean, I don't like it, but I guess I like what you have
better than what she wants, just maybe because she wants it,
but...
THE COURT: Well, that's not a reason to do it.
MR. FINLAYSON: Sorry.
THE COURT: That's definitely not a reason to do it.
MR. FINLAYSON: No, it's not. It's not a good
argument. I'm sorry. But again, you know, I object for ex
post facto reasons.
THE COURT: Then I will make the edit that the United
States requests to the wording of it, as much as I hate ending
a sentence with the word off, we will end the sentence with
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the word off.
MR. FINLAYSON: Ooh.
THE COURT: Okay. But okay, it's not my writing.
MS. CONNORS: I think the Supreme Court did it, too,
so maybe you're forgiven.
THE COURT: All right. On the ex post facto, it's
not that. Ex post facto is a law that's enacted. There's no
change in the law here. All this is is an explanation of the
law. And it would be weird if what we did was continue to
instruct the law in a way that the Supreme Court has said is
not right. We're not changing the law in any way. We're just
changing how we're explaining it to the jurors. And I don't
think that raises ex post facto.
I actually think the change is really almost
inapplicable in this case, because this is a case that only
involves economic loss, so it's really not much of a change at
all.
MR. FINLAYSON: And just for the record, I would
respectfully disagree, and submit that it does change the law,
and I think I put this in the -- well, I don't know where I
put it.
But that argument would be the way the law was
charged at the time of the crime would make something legal
that the way it's changed since Kousisis would make it
illegal, and that's my concern, so that -- that's what I'm
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seeking to avoid and that's why I oppose the charge.
MS. CONNORS: To the extent the Court would like the
government to respond, the Supreme Court has long made it
clear that when they interpret a law, what they are doing is
interpreting the law as it has always been.
THE COURT: That's right.
MS. CONNORS: And so it is always going to be applied
retroactively because what they're just saying is all along
this is what the standard was, it is never --
THE COURT: And if you look at Carpenter and those
others. I can't remember the other case.
MS. CONNORS: Yes, there's quite a lot of them. I
think Rivers V. Roadway Express was even one that I pulled
with some good language on that, but that is always the issue.
I will say my only kind of concern is that I do think
we want to make it clear that when we're talking about jury
instructions, we -- obviously it needs to be instructed on
what the law is.
And so sometimes there are going to be occasions
where the particular maybe eccentricity of part of an
instruction doesn't apply to a case, but that doesn't usually
mean that we don't still give that instruction. We still give
the instruction.
We usually give the whole wire fraud instruction. We
did that when Takhalov was in place, right?
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So even when it was a case that wasn't an issue of
fraud and the inducement in any way, we still gave the
instruction, so that would be my only other comment.
THE COURT: Yes, but I'm -- aren't I giving you what
you wanted?
MS. CONNORS: Oh, no, no, no. I'm sorry. The first
thing I said was just in case you needed a record from us, so,
yes, I agree with Your Honor.
THE COURT: All right. Okay. Anything else that we
need to talk about on these?
MR. FINLAYSON: No, sir.
MS. CONNORS: Judge, I think maybe --
MR. FINLAYSON: The transcript.
MS. CONNORS: I think since we had the 404(b), I
don't -- I think we're going to need to add 404(b).
THE COURT: We will add that.
MS. CONNORS: And then let me see what was my other
comment.
MR. FINLAYSON: I guess the transcript --
MS. CONNORS: And then stipulation as well.
MR. FINLAYSON: I don't think the transcript is going
to the jury.
THE COURT: No, I'm going to add this to the
instruction.
MR. FINLAYSON: Okay.
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THE COURT: Okay? I'll add it at the end and then
we'll work on -- you know, I guess accomplice, witness with
immunity, that doesn't seem necessary, but we'll just cut that
out at the end if it's not. Okay?
MS. CONNORS: I apologize, Your Honor. I was looking
at something. Was that --
THE COURT: You also have in yours accomplice
testimony that I don't think we need.
MS. CONNORS: Yes. I agree, Your Honor.
THE COURT: Okay.
MS. CONNORS: And then I don't think there's an
instruction on a stipulation; is that right?
THE COURT: I don't think there is, either. If
you-all want to send me one, I'll include it. But I've made
it pretty clear to them already that those are agreed to. But
do you want me to put one of those in?
MS. CONNORS: No, Your Honor. I was just
double-checking that there wasn't a pattern. I don't think
that there is.
THE COURT: I don't think that there is.
MS. CONNORS: Okay.
THE COURT: There is -- I think there is in the
before trial section.
MS. CONNORS: Oh, yeah.
THE COURT: Because I already gave that to them.
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MS. CONNORS: In the preliminary.
THE COURT: Okay. All right. Anything else?
Can you -- could one of you email this to my law
clerk or my courtroom deputy. This is the 404(b) instruction.
MS. CONNORS: Oh, okay.
THE COURT: So we can drop it into that. All right?
Okay. Anything else we need to talk about today?
MR. FINLAYSON: No, sir.
MS. CONNORS: I don't think so.
THE COURT: 8:30 tomorrow.
MS. CONNORS: Yes, Your Honor.
THE COURT: Okay. Thank you.
(Whereupon, the proceedings were adjourned at 5:09
p.m.)
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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 23, 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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BY MR. EVERT: [48] 496/1500/5506/5
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663/23664/4669/8
BY MR. FINLAYSON: [17] 522/3531/16
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JUROR: [2] 494/25495/3
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625/11625/14625/19630/9630/16631/25
633/3633/17634/1634/24635/1636/1
636/4636/9636/17636/19637/5637/10
641/11641/16641/22642/5643/2643/7
643/19645/13645/20646/2647/16647/25
648/10648/18649/6649/8649/15651/2
651/14652/4653/11653/14653/21654/11
654/14662/3662/8670/8673/1673/7
674/18674/23675/6675/11675/14675/16
680/18681/10682/20683/5683/17684/6
684/23689/5691/10692/14695/23697/2
699/15700/9701/13701/23703/8705/1
705/6705/22706/8708/13708/21710/19
712/19713/7714/24715/13717/4717/11
718/13719/4720/18721/9722/24723/15
723/24724/8724/21724/24725/7725/12
726/11726/19727/9727/17727/23728/6
730/18741/13744/6744/11744/19745/18
745/22745/25746/18746/21747/14
747/18747/22747/24748/2748/5748/8
748/13748/18749/8750/7751/4751/8
751/13755/10755/12755/15755/21756/2
757/4758/2758/7758/12759/6759/12
759/14759/17759/20760/5760/9760/11
760/17760/21760/24761/1761/5761/9
761/11
MS. WILSON: [1] 651/6
THE COURT: [247] 480/6481/15481/17
481/22482/4482/6482/18482/21482/23
483/12483/14483/18484/11484/14
484/16485/7485/10485/15485/17485/20
486/6486/17486/20487/8487/23488/8
488/22489/25490/2490/16490/20491/12
491/19491/21492/1492/4493/6493/11
493/16493/20494/4494/10494/12494/15
495/1495/4495/10499/18499/20499/23
506/4507/3516/6516/8516/10518/10
518/13530/3530/5530/21531/4531/7
533/3533/17533/22533/25534/11534/13
534/16534/21534/24535/2535/14535/18
535/21536/4536/10536/15536/24537/4
537/6537/8538/5538/9538/11538/14
538/17538/21539/15539/20545/17
545/20552/19555/22556/3556/9556/12
571/15571/23571/25572/3572/11572/13
572/16572/19572/22595/16595/19
595/21595/25596/2596/8597/11597/13
599/1601/17601/19609/7613/9613/11
613/15613/18613/23614/4624/8625/4
625/6625/13625/16633/5633/13633/19
633/22634/8634/14634/16634/18634/25
635/3635/13635/17635/20636/3636/6
636/11636/16636/18636/21636/24637/6
651/7653/13653/15662/2662/4662/7
662/10662/21662/23662/25669/5669/19
669/22669/24670/3670/10670/22673/4
673/6675/1675/4675/7675/12675/15
705/3705/8705/13705/16705/20717/1
730/19741/12744/13744/18744/20
744/23745/15745/20745/24746/1746/4
746/8746/11746/20746/22747/17747/20
747/23747/25748/3748/7748/9748/22
749/1749/11749/16749/19750/4750/21
751/2751/5751/12752/11753/3753/6
753/21753/24754/5754/18755/11755/13
755/19755/25756/3756/10756/17756/19
756/23757/3757/6758/6758/10759/4
759/9759/16759/23760/1760/7760/10
760/13760/20760/22760/25761/2761/6
761/10761/12
THE DEFENDANT: [1] 739/17
THE WITNESS: [30] 495/22499/19
499/22499/24516/7516/9518/11531/9
533/21538/16538/18538/20539/6539/19
599/4601/18614/16649/7662/6662/19
662/22662/24669/21669/23670/2670/21
670/23705/14744/15744/22
$
$1 [2] 571/5713/5
$1 million [1] 713/5
$1,200 [3] 688/14737/24738/5
$1,316,144.46 [1] 567/21
$1.3 [2] 568/14568/17
$1.3 million [2] 568/14568/17
$1.5 [1] 569/12
$1.5 million [1] 569/12
$1.6 [1] 583/1
$1.6 million [1] 583/1
$10 [4] 511/22512/1512/1512/2
$10 million [4] 511/22512/1512/1512/2
$100,000 [8] 515/11515/16515/21
515/22516/16516/18516/21516/22
$11,366,813.09 [1] 567/15
$11.4 [1] 568/12
$11.4 million [1] 568/12
$13.4 [1] 569/9
$13.4 million [1] 569/9
$150,000 [3] 527/11527/12527/13
$2 [3] 511/23512/4670/11
$2 million [3] 511/23512/4670/11
$2,843,396.26 [1] 563/13
$2,999,910 [2] 594/19597/24
$2.9 [1] 594/22
$2.9 million [1] 594/22
$20,707.31 [1] 724/16
$241,902.91 [1] 562/14
$250,000 [2] 515/12515/18
$3 [19] 553/4553/23581/14581/16584/2
584/16584/19595/3595/6599/19599/21
599/25612/4694/6694/20695/5716/6
716/12716/15
$3 million [18] 553/4553/23581/14
581/16584/2584/16584/19595/3595/6
599/19599/25612/4694/6694/20695/5
716/6716/12716/15
$3,015,573 [1] 714/13
$3,365,212 [1] 713/17
$3,366,240.76 [1] 709/9
$3,371,641 [1] 685/11
$3,373,441 [1] 687/22
$3,459,834 [1] 685/18
$3,459,835 [1] 737/22
$3,600,000 [1] 694/18
$3,821,770 [2] 552/2553/20
$3,821,771.20 [1] 571/2
$3,901,665.45 [1] 562/4
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 288 of 324
$
$3.3 [2] 695/19713/12
$3.3 million [2] 695/19713/12
$3.4 [1] 743/9
$3.4 million [1] 743/9
$3.8 [2] 553/24560/20
$3.8 million [2] 553/24560/20
$300,000 [1] 583/7
$433,043.27 [2] 562/8723/19
$45 [1] 557/8
$45 million [1] 557/8
$45,861,255.93 [2] 563/3570/14
$5,000 [1] 722/13
$5,096,786.12 [2] 563/7724/11
$50,000 [1] 583/12
$6,554,515 [1] 592/16
$600 [1] 688/13
$68,394 [1] 713/21
$7,000 [2] 740/10740/18
$7.8 [1] 569/25
$7.8 million [1] 569/25
$799,949 [2] 565/18684/22
$8,999,360 [1] 713/2
$88,194 [2] 685/14737/7
$892,000 [1] 570/2
$9 [4] 516/25693/17694/19694/19
$9 million [4] 516/25693/17694/19
694/19
$9,099,360 [1] 565/15
$9,199,411 [2] 565/12684/12
$9,554,425 [3] 553/1553/8581/2
$9,999,360 [4] 684/19693/15712/22
716/3
$9.25 [1] 601/14
$9.25 million [1] 601/14
$9.5 [2] 583/17601/23
$9.5 million [1] 583/17
$90 [1] 595/3
$95,000 [2] 601/14601/23
'
'13 [1] 740/17
'13 and [1] 740/17
'14 [3] 710/2710/2740/17
'15 [1] 710/2
'22 [3] 498/18597/7598/2
'79 [2] 650/20650/21
-
-- for [1] 604/11
-- from [1] 746/14
-- in [2] 490/20517/18
-- is [1] 727/11
-- issue [1] 541/9
-- nobody [1] 666/5
-- not [1] 666/20
-- or [1] 622/19
-- showing [1] 586/10
-- that [2] 618/10660/7
-- they [1] 538/7
-- to [2] 493/12604/9
-- would [1] 556/10
/
/s [1] 762/18
0
01 [1] 641/3
0540 [26] 565/3626/16637/18642/3
644/2645/18646/25650/2651/12683/24
685/22693/2697/22701/4702/5702/20
703/19706/4707/3713/11718/17725/5
729/10730/13739/25743/12
0610 [1] 739/15
1
1 percent [7] 524/23601/8601/12
601/14601/14601/18601/23
1-800 [2] 671/17672/5
1/25/2021 [1] 579/13
10 [7] 561/14571/16580/21644/19
650/18705/10721/9
100 [2] 504/17736/11
100 percent [5] 505/4528/20528/22
541/22548/1
1001 [1] 675/5
1006 [2] 675/6675/7
101 [11] 544/20544/22544/25545/12
545/17545/18545/23589/24590/11
609/10720/19
101A [4] 544/20544/22545/12574/4
101B [3] 544/22545/12575/22
101C [4] 544/22545/12596/9596/10
102 [3] 544/22545/12577/3
102A [3] 544/22545/12578/7
103 [7] 544/22545/12579/4579/7580/22
592/3592/4
103A [2] 544/22545/12
104 [4] 544/22545/12586/21593/5
1040 [23] 564/22571/9589/21590/4
591/6624/14624/18685/9686/17687/18
695/20707/1707/2712/16714/14714/19
725/2725/5728/12728/17728/19730/11
743/25
1040s [8] 673/11673/13673/15673/18
714/15728/24729/25739/12
105 [4] 544/23545/13594/9596/10
106 [7] 544/23545/13587/13591/14
680/18680/23683/5
107 [4] 544/23545/13588/23591/14
108 [7] 544/23545/13545/14585/2585/5
602/21611/23
1099 [8] 549/1703/2703/15737/19739/2
739/4739/5739/6
1099-G [1] 703/4
1099-INT [3] 702/13702/16703/11
1099-MISC [1] 509/21
1099s [2] 719/3742/22
10th [4] 593/9640/8701/2762/14
11 [2] 578/25692/14
11:06 p.m [1] 637/24
12 [6] 528/2540/9541/10570/25570/25
571/16
12/31/2014 [1] 548/9
12/31/2020 [1] 735/23
122 [4] 562/24570/16570/18724/8
123 [1] 563/25
125 [3] 564/21590/1724/24
126 [1] 724/21
129 [3] 565/19590/11725/7
12:00 a.m [2] 628/5628/6
12:30 [2] 572/22633/14
12:30-ish [1] 613/24
12th [6] 644/13646/20647/4663/25
714/21718/3
13 [4] 569/9581/13615/2695/23
132 [1] 566/4
134 [1] 590/23
1347540 [1] 642/24
1377 [26] 588/7589/19590/18648/25
661/13661/22676/12677/15677/19678/7
679/3679/10679/16681/22682/1682/5
683/3683/15698/25719/22719/25720/2
727/15728/1729/12731/2
13th [4] 502/4650/6700/24717/21
14 [7] 581/22585/20642/5645/21651/19
651/21740/17
141 [3] 566/18566/23725/12
142 [1] 567/22
143 [1] 567/24
145 [1] 568/19
1456 [1] 477/23
146 [1] 568/22
148 [1] 569/14
149 [1] 569/17
15 [6] 540/10540/12585/20592/3715/13
730/16
150 [6] 505/17505/25507/1507/3507/7
532/15
151 [1] 570/5
152 [2] 570/7726/11
15th [15] 508/8508/25509/16510/7
519/21526/15543/13548/21549/10
549/13574/21584/25591/17612/15731/6
16 [1] 671/13
16th [8] 534/15576/21577/17577/24
589/22590/7590/21730/1
17 [3] 651/16700/10719/5
18 [2] 592/11592/17
1821377 [3] 651/23681/16697/8
1833 [1] 681/20
1855 [1] 736/10
19 [1] 508/15
1919 [1] 499/16
1949 [1] 477/21
1975 [4] 628/5647/14650/19717/24
1979 [4] 640/8644/19701/1701/2
1:22-CR-00171-MLB [2] 477/4762/10
1:30 [1] 633/16
1st [2] 588/11682/14
2
2.5 [2] 552/11553/2
2/15/2020 [1] 548/13
2/16/2021 [3] 547/6576/1578/12
2/19/21 [1] 574/12
2/9 [1] 578/4
2/9/2021 [1] 578/9
20 [2] 632/1649/9
201 [8] 683/17698/22700/10704/5
713/11715/16717/14720/10
2012 [1] 592/18
2013 [3] 497/10710/2740/15
2014 [4] 548/9727/4727/5728/2
2015 [2] 665/7667/17
2017 [2] 665/15666/2
2018 [13] 497/17588/4588/11665/18
677/22682/11682/14682/17699/1699/4
720/1731/4731/5
2019 [3] 497/21498/12750/14
201A [4] 673/2705/23735/2735/6
201B [2] 673/2708/14
202 [3] 663/16710/19719/5
2020 [98] 501/16501/20501/23508/8
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 289 of 324
2
2020... [94] 508/25509/16510/7519/21
526/16534/9543/13548/13548/21549/10
549/13557/9560/24561/16562/3562/7
562/13562/21563/2563/6564/23565/8
565/11566/8566/16566/25567/6567/11
567/20568/5568/9568/12568/17569/3
569/19569/22574/21584/25586/5586/16
589/10590/3590/4591/5591/17610/6
612/15613/1632/12639/8644/5645/4
646/16648/22649/25665/22666/3666/7
666/13669/12673/11685/23686/4688/4
688/10695/2697/23699/3699/4699/4
699/8699/12700/6702/7702/9702/19
703/18706/23707/2710/12710/22714/19
721/13723/19723/22724/3726/9728/12
729/6729/15730/16731/7735/23736/3
2020 1040 [1] 695/20
2021 [54] 502/2502/8520/1534/15542/8
547/6576/1576/21577/17578/4578/9
578/12579/13581/7581/21585/16586/24
587/6589/12589/22590/17590/21593/9
594/7627/5637/24644/13646/20647/4
650/6658/4658/9663/25669/12678/16
680/6681/1682/11699/11700/5700/24
708/19708/25714/21717/22718/3720/14
727/5727/6728/2728/20730/2730/11
737/11
2022 [10] 498/12596/24597/23598/1
598/20598/24599/3599/7599/18738/10
2025 [7] 477/12480/3735/9735/12736/5
736/6762/14
203 [1] 673/2
204 [2] 673/2726/20
205 [3] 673/2673/3727/17
206 [1] 727/23
20820 [1] 563/12
21 [2] 574/12747/8
212 [1] 701/13
213 [2] 673/3718/13
215-1456 [1] 477/23
22 [4] 598/16598/17647/6647/6
220 [13] 624/5624/20625/3625/4625/9
631/17637/16643/22646/6654/7654/9
664/16664/25
221 [7] 624/10630/11631/20642/9
642/19642/21649/5
222 [5] 641/15641/15641/16641/18
643/3
2220 [6] 664/11665/5665/8665/23
666/12669/13
223 [2] 641/15641/18
224 [4] 645/8645/11645/15645/17
225 [2] 645/8645/11
226 [8] 647/18647/21648/7648/12649/8
651/24651/25652/4
227 [3] 651/6651/7651/21
228 [4] 624/11624/20625/3625/4
23 [3] 477/12480/3762/8
23rd [2] 708/19708/25
24 [1] 754/25
25 [8] 630/17642/19648/19649/6652/5
685/4713/13717/11
25A [5] 685/9685/11685/16713/15
713/16
25C [2] 685/12713/20
25D [1] 685/15
26 [2] 737/10755/1
27 [1] 651/5
27th [1] 501/23
28 [3] 495/4565/22590/14
29 [1] 581/6
29th [1] 596/24
2s [11] 698/20704/12719/3729/2738/16
738/19738/22742/20742/23742/25743/3
3
3/29 [1] 581/6
30 [1] 748/15
30135 [2] 679/9681/8
30303 [1] 477/22
3050 [1] 726/23
3081 [5] 679/9681/7681/23682/6684/3
310 [3] 544/23545/13580/19
310A [3] 544/23545/13593/20
31st [2] 727/4727/4
35 [1] 748/17
35A [2] 687/22714/12
4
4/9/2021 [1] 581/21
404 [6] 477/23483/20489/7759/14
759/15761/4
42 [1] 610/1
45 million [1] 570/24
48 [1] 755/4
49 percent [1] 526/4
492 [1] 551/11
493 [14] 484/3486/11490/3493/23551/7
551/16551/17551/22567/9567/10568/10
569/7569/23605/23
4:30ish [1] 705/18
4th [2] 735/9735/12
5
5/18 [2] 592/11592/17
5/7/2021 [1] 589/12
500 [5] 496/19511/4515/23549/20550/3
503 [12] 674/15674/19675/14675/15
675/17680/19681/10681/17697/3697/9
698/25719/7
504 [6] 674/15674/19675/14675/15
699/16728/7
51 percent [1] 526/3
5:09 [1] 761/14
6
6.5 million [1] 599/16
60 [1] 653/6
600 [1] 738/6
6010 [18] 626/10626/13626/19637/9
641/9646/8647/3648/3648/15713/23
714/10716/13718/19719/18720/7729/12
739/17739/19
6:05:57 p.m [1] 627/5
6:15 [1] 646/20
6:15 p.m [1] 644/13
6:37 [1] 647/4
6th [2] 637/24660/18
7
71 [1] 610/6
75 [1] 477/22
7540 [21] 566/3590/24631/4645/25
679/19679/21680/3680/4680/14699/7
700/1715/21721/2723/8723/22725/10
727/11729/2729/19730/2730/6
771-36-0540 [1] 683/24
799,000 [1] 684/22
799,949 [1] 737/2
7A [16] 497/24498/1498/4498/7498/10
498/11498/13498/14498/16498/17
499/16499/24520/7520/8520/11537/19
7th [8] 585/16586/23587/6590/17
591/15681/1728/20730/11
8
8/29/22 [2] 598/16598/17
80 [3] 561/21610/5723/15
800 [2] 671/17672/5
806 [3] 737/17741/5743/16
81 [3] 562/18609/9723/24
83-182-1377 [3] 588/7589/19590/18
83-1821377 [3] 651/23681/16697/8
8332 [18] 642/16678/14678/15679/1
679/5679/17679/24680/3680/4680/14
693/8697/6699/7700/1727/14727/21
729/3729/20
86-134 [1] 590/23
86-1347540 [1] 642/24
8:30 [3] 745/9745/10761/10
8:42 [1] 650/6
8A [1] 497/6
8th [2] 594/7628/5
9
9 million [1] 694/15
9,500,000 [1] 544/8
9.1A [1] 751/11
9/1/2018 [1] 588/4
90 [1] 1/4
940 [10] 561/1570/8573/5722/4726/13
726/15726/17727/1727/19728/1
940s [3] 682/24727/6728/2
941 [16] 560/23561/7573/17605/3
605/12605/15605/20605/22606/2612/16
722/15722/16725/14727/20734/8742/13
941s [11] 566/24570/9573/5682/24
725/17726/6727/1727/6728/2742/5
744/10
9th [3] 577/6577/8578/4
A
a.m [4] 628/5628/6650/7650/8
Abbot [1] 495/12
Abbot Elementary [1] 495/12
abbreviation [3] 632/7679/17682/7
abetting [1] 749/6
abide [3] 492/16494/17745/7
abiding [1] 490/17
ability [4] 480/9552/16610/20617/24
able [36] 483/4500/2557/8559/5572/8
572/10578/25610/5614/22616/13618/10
619/22620/6620/23632/16657/6657/20
658/3661/6676/17676/22677/8685/24
688/25697/21698/2701/10711/6717/7
723/8723/21725/17726/2726/15727/19
728/1
about [139] 480/9480/13480/19480/25
483/22487/2487/2489/13489/23489/23
490/8492/20492/21493/13493/17493/18
493/20495/10507/4509/13514/6514/18
524/24526/14530/17530/23533/25534/1
534/21536/1540/1540/5540/9540/10
540/14540/16540/17550/11556/15
563/21569/9569/25570/2571/5571/15
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 290 of 324
A
about... [94] 571/18571/23571/25
572/22581/9583/12585/12586/2588/16
589/4596/20597/19598/19599/9605/9
607/9607/21607/24609/20609/22609/24
611/19614/21615/2615/25617/19619/17
621/18623/17632/23633/8633/9633/15
633/17633/19633/20633/23634/8634/9
634/10635/4638/16645/5645/17646/19
652/21653/7654/17659/2664/2666/11
667/5668/2669/9671/18672/5675/4
675/7680/9692/15694/8694/9695/21
707/8708/2708/25709/21718/22731/17
734/9735/6736/2738/1739/7739/9
740/10740/11741/16741/19742/20743/8
744/25745/6745/16747/5748/15749/3
751/3751/21753/14753/19758/16759/10
761/7
above [13] 512/24547/9550/17557/4
561/24565/22565/24632/5632/8643/11
683/9716/18721/16
abroad [1] 525/21
absence [1] 753/3
Absolutely [8] 540/8543/17558/24
600/14610/16619/4647/24658/8
abstractly [1] 537/10
absurd [1] 493/13
accept [5] 653/17671/24698/13711/16
711/19
acceptance [1] 712/3
accepted [12] 621/13622/13623/25
638/8647/9650/14653/19656/22661/15
661/24712/4712/5
accepts [1] 712/1
access [6] 496/8497/5585/10730/15
732/3732/10
accessed [1] 542/8
accessing [2] 576/12576/18
accident [1] 483/21
accompanying [2] 646/14689/13
accomplice [2] 760/2760/7
accordance [2] 504/19505/5
according [1] 558/6
account [80] 542/9542/11579/10579/14
580/2580/5580/8580/11580/13580/16
580/18581/15581/17581/18581/19582/2
582/12584/3584/6584/9584/11584/13
584/19584/20585/10585/11588/16
588/19589/7590/9591/20591/22592/5
592/13592/22593/1593/7593/13593/14
593/16594/3594/7594/8595/1596/18
597/4597/4597/22602/24611/16618/12
629/5629/8640/11640/16657/16671/18
672/1685/24706/1706/3706/11706/12
706/14706/21707/15707/16707/22
707/23708/10734/18735/13736/18
736/18737/24740/25741/2743/19743/21
743/23
accounts [2] 582/15617/24
accruals [1] 736/24
accrued [3] 594/19594/20736/21
accruing [1] 594/20
accuracy [6] 521/22583/21619/2620/10
620/11674/6
accurate [22] 508/2532/20547/14
553/24564/15573/9573/11573/20575/6
620/13661/1687/24689/10696/18715/7
715/10724/14724/19743/6743/7744/4
762/13
accurately [3] 552/7687/6692/11
acknowledge [3] 487/13487/15487/23
acknowledges [1] 492/16
acknowledging [1] 487/19
acknowledgment [4] 488/9621/5
621/10621/12
acknowledgments [1] 621/7
acronym [3] 496/13721/17721/21
across [6] 626/18652/24661/4728/22
735/11736/18
Act [3] 501/22537/20722/2
acted [2] 635/9755/6
action [2] 477/4622/3
activity [1] 586/10
actual [6] 617/3617/4719/17719/19
734/10752/3
actually [46] 484/23493/2505/21517/9
522/21523/22525/17536/8541/24561/9
563/18564/11591/3598/11606/3622/5
623/10641/16655/15657/13660/22661/3
688/17698/22700/20708/3708/5708/6
710/12711/23711/25726/8729/9729/22
735/14741/7741/7742/9742/10743/6
743/24747/2747/3747/16750/8757/14
add [7] 711/9751/18753/17759/15
759/16759/23760/1
added [2] 678/10753/18
adding [3] 685/15750/19754/11
addition [1] 674/8
additional [20] 524/16543/21577/24
579/2580/13584/23586/2586/19587/9
589/4591/19620/15624/6684/20700/14
709/5710/21713/18713/20716/17
additionally [1] 543/8
address [60] 494/19559/6576/2576/9
576/11576/13576/16627/20627/21
628/11628/15628/17628/20628/21
628/23628/25629/2629/3631/12631/18
632/22639/15640/11640/13640/15
644/16644/21647/11648/14650/16664/9
664/16666/9667/5676/15676/25677/2
677/3677/6677/11678/24678/25679/4
679/4679/6679/7679/8679/10679/11
681/6682/5682/8682/9682/16682/18
684/4712/17726/25736/10739/22
addressed [2] 543/7681/22
addresses [8] 576/14628/18639/18
668/17676/20676/21676/22680/15
adds [1] 570/8
adjourned [1] 761/14
adjusted [1] 737/1
adjustment [3] 688/6711/9711/11
adjustments [6] 688/1706/17707/6
740/5740/6743/21
administrate [1] 615/12
Administration [5] 496/5496/6496/11
562/16563/15
Administrator [1] 477/20
admissible [1] 674/24
admit [5] 506/25545/11625/2673/1
674/18
admitted [10] 489/12507/3507/4545/17
545/19545/20597/13625/6673/6675/10
ADP [2] 618/1618/6
advance [1] 709/12
advocate [3] 672/3672/4672/6
advocates [1] 672/12
affected [1] 508/15
affiliates [3] 511/9511/11549/17
affiliation [1] 525/6
Africa [1] 733/20
after [35] 1/7533/10542/8572/9581/9
581/10583/24584/1584/2584/4584/16
593/13594/5594/6607/3616/2616/2
620/19629/17629/21632/15634/18
635/15640/21645/3657/1657/10672/3
692/4699/13700/5712/8737/15748/21
755/24
afternoon [9] 614/23654/5654/5663/4
663/5671/3671/4705/2730/24
afterwards [1] 748/19
again [33] 505/23516/6551/21596/4
628/12637/14640/16643/23644/21
644/23645/3646/6646/7647/11647/23
648/14649/23668/10691/11692/4693/1
695/1697/3703/11704/5734/4734/15
736/4738/4738/9751/8753/13756/21
against [1] 481/2
agencies [4] 615/15616/24616/25620/3
agency [28] 496/7500/23500/25522/9
522/10522/11616/17616/22616/23
620/22620/25621/2621/19621/20626/21
626/22638/25639/2641/2644/8644/10
646/12647/9657/6657/7657/7660/10
738/19
agent [1] 748/14
AGI [2] 690/7690/13
aglet [3] 754/19754/20754/20
ago [3] 540/9540/17619/17
agree [6] 487/15489/2494/2653/16
759/8760/9
agreed [4] 487/9491/23527/6760/15
ahead [14] 495/6530/6533/4536/16
556/19565/19566/4585/20596/8605/11
630/5636/19636/25705/21
AI [1] 1/13
aid [3] 496/8501/22674/15
aided [1] 477/18
aiding [1] 749/6
air [1] 481/8
aligned [1] 558/8
all [207] 480/6480/10480/11480/18
481/13484/9484/14485/5486/4487/8
489/2490/1490/4490/11490/16492/14
492/14492/17493/5493/17494/10494/12
494/13494/15494/22494/24495/6499/22
501/6504/4504/6505/10507/20507/23
508/23509/4509/9512/23513/20520/6
525/7529/7532/19532/20533/19535/18
536/4536/12536/15538/14538/21539/17
539/20540/3545/20545/22547/13547/14
548/18550/16551/17551/24554/6555/21
560/24562/18562/21568/22570/8570/12
570/13571/12571/21571/25572/14
572/23573/2573/8573/20573/20575/5
575/14575/21576/20582/21585/17
585/19585/23586/15588/8588/8588/21
592/22595/18595/25595/25596/5596/6
599/9599/13604/18605/1605/17605/18
605/21605/24607/7607/13608/4609/6
610/25613/4613/12613/23614/2614/4
615/13616/7617/15624/14627/17629/3
630/1630/21633/7633/10633/11633/14
633/15634/8634/18634/20634/22636/14
636/22638/8639/22641/6645/7645/17
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 291 of 324
A
all... [67] 649/19651/18652/12652/13
656/14656/15657/8657/14659/8662/1
662/4663/1666/22667/8669/4669/19
670/7672/5673/6686/19691/5691/7
692/6696/23700/16701/19703/6703/18
703/20705/8705/11705/20707/1710/5
712/20720/17726/8734/20742/24743/17
744/20744/23744/24745/6745/7745/10
745/12745/13745/15745/20746/1746/5
746/11746/16747/6747/9747/11749/5
749/19757/6757/8757/17758/8759/9
760/14761/2761/6
alleged [1] 483/11
allegedly [3] 488/16489/15725/22
allow [2] 500/3505/3
allowable [2] 549/23553/12
allowed [28] 484/2502/5503/21504/17
514/8514/9517/16519/13520/24521/3
521/7521/11521/15529/12529/17529/19
529/21529/23530/1530/8531/1531/11
557/15558/10560/7665/25671/24717/10
allowing [1] 688/14
almost [6] 488/5488/6705/5749/2
755/17757/14
along [8] 499/3499/9504/15561/20
619/7620/7671/25758/8
alphabetically [1] 665/4
already [40] 481/9482/9486/23487/9
520/15535/9545/17545/18548/12574/4
575/22577/3577/19578/8579/5583/25
585/3587/13588/23589/25593/5593/20
594/10624/3625/12638/23663/16688/17
688/21689/1689/1689/3694/17695/8
707/20712/15718/2753/16760/15760/25
also [66] 477/6480/21490/18496/20
497/5498/15500/10506/11509/1531/21
539/22541/2541/11552/16560/24571/9
574/12583/11583/16589/2589/21604/12
618/24623/16623/22624/5626/13626/14
638/11639/19644/4644/15649/21649/25
658/22659/12660/7671/23675/24680/6
684/20685/12692/4694/17707/10709/24
713/14714/6714/16715/18715/23716/11
719/6721/21722/8724/5727/13728/19
728/19736/22738/25751/18751/21
752/18760/7762/9
although [2] 708/1752/2
Altogether [1] 653/6
always [7] 492/7691/24715/12749/9
758/5758/7758/14
am [12] 524/11525/16526/9607/20
611/24625/9628/19639/10664/18672/22
706/2710/23
amended [2] 711/6711/10
AMERICA [3] 477/3497/19762/9
American [9] 498/24498/24500/9
500/17500/23512/21514/2514/6520/19
Americans [1] 500/12
Amongst [1] 486/11
amount [78] 487/14487/24505/7511/18
512/6512/7512/12513/10513/16514/5
515/19515/25525/9541/21546/6552/1
552/12552/15553/9553/11553/13558/7
580/24581/14592/12592/14594/17
594/19594/25598/1599/18601/9601/13
601/17604/21606/12660/11684/10
684/11684/12685/13686/24687/19
687/21687/22688/2688/18689/1689/2
692/2693/15694/8694/22694/24695/16
695/21696/16707/7707/11709/8709/18
709/22710/5710/9712/25713/17713/18
713/20714/12715/23716/2716/6716/15
716/17722/19722/20737/8740/20
amounts [4] 534/4537/3702/18725/22
analysis [1] 559/18
analyze [1] 542/18
analyzed [1] 571/9
announced [1] 501/19
annual [4] 561/1562/20566/5610/2
annualized [1] 570/8
another [19] 489/10513/14513/21
514/22515/3531/25537/20540/11586/7
586/8586/12595/23618/2626/12733/19
733/24738/6746/15754/21
answer [17] 481/4481/4513/2515/4
531/7531/8535/10551/3556/12571/1
574/24575/4575/16575/18603/3623/3
744/15
answered [3] 529/25577/7671/16
answers [1] 575/5
any [119] 1/9489/2490/11504/9508/4
510/17510/22510/25511/18512/15515/6
515/25517/6543/21548/3553/13557/18
557/23558/1558/14558/17560/18566/20
566/20573/23573/23573/24579/25580/1
580/2582/10582/24583/2583/8583/13
584/23594/20595/9597/11604/16606/3
609/7609/18617/22623/22625/4632/17
636/1660/14660/15660/22662/2662/21
669/5671/25672/13673/4676/8677/14
678/6678/9679/3679/6681/21681/25
683/14685/16685/23686/3686/10691/13
692/7692/25695/1695/1702/18702/20
703/3706/13706/17706/18706/19707/6
707/10709/12710/11713/24717/2718/21
718/24721/5723/8723/8723/12725/17
725/20726/1726/3727/19727/22728/1
728/3734/25734/25741/12742/9743/21
745/5752/23752/23754/14754/22754/23
755/3755/13756/8756/13757/11759/2
anybody [5] 633/19669/13672/11
722/12745/7
anyone [5] 580/4611/4665/23715/2
741/23
anything [20] 493/20507/4560/15
571/23611/5633/9633/15633/19672/10
695/17703/1706/19708/2709/24723/21
744/18754/15759/9761/2761/7
Anyway [1] 670/5
anywhere [2] 482/16746/5
apart [2] 578/1753/15
apartment [10] 663/9664/11664/20
664/24664/24667/11668/5668/14669/11
669/13
apartments [1] 665/4
apologies [1] 651/17
apologize [6] 492/18545/18648/10
649/19719/4760/5
app [4] 623/20623/22632/25658/23
apparently [2] 630/3661/24
appear [3] 495/13624/14703/23
APPEARANCES [1] 477/24
appears [7] 547/1631/23646/23651/11
679/16709/19756/3
applicable [3] 511/12549/18750/12
applicant [62] 503/6503/9503/9503/10
504/24507/15507/20508/24509/7509/8
509/13509/15509/22510/12510/14511/9
511/11511/19517/6517/16520/4520/23
520/24521/2521/3521/6521/7521/10
521/11521/14521/15521/19521/22524/3
529/4542/4542/6543/7543/9546/12
547/1547/24548/18548/21549/17550/2
551/11551/17552/3557/7558/13558/15
558/18559/2560/7560/10574/17574/20
575/5575/8575/13576/7
applicant's [11] 504/22504/23512/24
523/24524/2524/3524/8550/16574/19
575/14576/11
applicants [6] 537/16542/8552/23558/1
573/10611/10
application [104] 487/18498/15499/10
499/14499/16499/17499/24499/25500/3
503/6503/7503/11503/20504/21506/23
509/4509/15509/22517/5517/9517/13
521/16521/20521/23523/17524/15527/8
530/10530/15531/2531/17532/7532/19
541/21542/16542/18542/20542/25543/3
544/11544/12544/15544/25546/1546/13
546/15546/20547/7547/13550/18555/3
558/2558/9558/11558/15561/20565/5
571/4573/3573/9573/14575/9575/25
576/1576/3576/6576/22576/24577/5
577/16577/19577/23578/4578/9578/13
578/16578/20578/20578/22579/1581/11
583/22589/22590/7602/8602/16605/6
605/13605/17606/6606/7606/22609/16
615/25616/1617/4618/5619/1619/12
676/5676/6726/6726/13730/6
applications [13] 502/12541/2541/4
541/11541/15542/22577/21602/1606/5
610/22615/4615/5732/3
applied [11] 519/3523/12529/6533/7
534/14544/17574/10578/16579/18
735/20758/7
applies [1] 753/7
apply [18] 501/25502/5502/7502/15
502/17514/16542/11542/13544/2554/6
572/21749/16752/4752/24752/24752/25
753/8758/21
applying [2] 512/3587/18
appreciate [3] 495/5637/5670/6
approach [1] 624/7
appropriate [3] 556/1632/11755/23
approve [6] 502/17541/15561/6606/13
613/2676/6
approved [26] 513/3549/14551/4
553/21555/10555/14555/18556/11
556/13556/23557/23561/3561/12563/19
563/23564/12564/19573/25574/12
574/13575/19578/5578/23604/21606/16
613/6
approves [1] 558/22
approving [3] 558/21604/25605/18
approximately [8] 560/20568/12568/14
568/16569/11612/4615/2647/5
April [9] 568/5596/24665/22666/3666/7
666/13708/19708/25737/10
April 2020 [2] 666/3666/7
April 23rd [2] 708/19708/25
April 29th [1] 596/24
ApStar [3] 574/8575/24578/8
are [202] 1/8484/4485/15490/3491/14
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 292 of 324
A
are... [197] 491/14492/7496/10496/14
496/17496/19496/25498/4505/19506/18
508/17508/23508/24509/13511/12
519/23522/5522/12522/14522/15525/20
526/5526/6528/14530/11532/8533/9
533/25534/10535/16535/19535/23
543/24544/9544/18544/19545/5546/4
546/7547/19549/3554/7554/19554/22
555/22559/3559/18560/2560/23565/21
567/3572/12572/17574/18574/19575/1
578/25579/7579/7580/18585/5591/1
591/5591/8591/11594/17597/13602/11
605/1609/6609/14610/6619/9621/8
621/16623/16624/15624/23625/6628/17
631/2636/16637/20637/23637/25639/7
639/18639/24640/10640/12641/6644/10
645/8645/11645/17646/6646/7649/21
649/22653/9653/10656/18656/19657/1
657/17659/8660/1660/9660/12660/16
661/1663/9664/16664/19667/21669/20
672/19673/6673/13673/18673/22674/12
674/14674/23674/24675/10676/20
676/21676/21676/22679/23679/25680/1
680/14680/16684/13684/14686/6687/12
689/15690/20692/10693/20694/2697/18
697/25698/1699/9699/24705/5706/1
710/16711/17720/5722/3725/2725/22
727/2727/6727/14728/19729/5729/22
730/25731/10732/17732/17732/19734/8
738/16738/22738/25739/2739/12740/11
741/4741/8742/22743/17744/1744/3
745/6745/16747/5747/9747/11747/14
748/11748/12751/2751/16752/7752/8
752/10758/4758/19760/15
area [2] 699/17712/19
aren't [3] 610/12738/25759/4
argue [7] 483/12483/19488/10489/5
489/5489/21490/12
argued [2] 489/9489/12
argument [14] 482/10483/8483/25
485/24486/18488/12488/12491/2492/5
492/6753/6753/19756/21757/22
arguments [1] 492/10
arise [2] 583/24584/2
around [12] 555/3559/6559/10587/4
607/16613/24651/16705/18746/25747/4
753/21754/23
as [195] 477/6489/5489/18489/19
490/22490/25491/8491/8493/17494/6
494/6495/18496/8496/8496/11496/25
497/6497/6497/24498/13498/15498/15
499/10499/10501/10505/17507/3509/20
510/7516/1516/12524/25525/4525/13
525/17533/14538/10539/1539/23539/25
540/8540/11540/12540/13541/19542/16
542/25542/25543/11543/11543/12
543/13543/14544/10544/20546/7546/8
546/15548/1548/13549/1549/7549/25
550/18551/10551/16552/5554/17554/21
555/2556/13558/11558/22559/4560/3
560/3560/4560/17561/1561/24570/15
574/12575/2575/2576/25577/14578/12
584/22584/25587/6588/15589/20589/21
591/17593/17595/5597/22602/4602/4
605/6605/13605/17605/20605/25606/1
611/8611/8612/3612/3612/15614/11
617/7619/1621/12626/16633/23634/5
635/11635/21639/4639/22640/13640/14
641/8648/23649/11649/21653/14653/17
653/19653/22657/25662/14668/9670/16
672/15673/13673/15673/15673/19
674/14675/25679/13680/2687/6687/8
687/8687/10687/12687/12687/15687/15
687/17693/5694/22696/10699/3704/17
710/6712/5712/23713/13715/2716/11
716/17717/25718/23720/15720/24
729/10729/10731/10732/3732/9737/4
743/20743/21743/22744/23744/23746/8
746/9746/21751/14752/22754/6754/8
754/13755/4756/4756/24756/24758/5
759/20762/9
ask [27] 483/4487/2489/23490/18524/1
527/5527/16530/21536/9537/6537/8
537/9537/10537/25545/5566/19568/19
607/11607/15611/19630/10651/25655/2
683/25686/7690/6717/1
asked [14] 523/22524/24525/2526/14
527/2529/24550/18599/23605/14669/9
741/16741/19742/20743/8
asking [9] 490/8655/5685/4690/12
692/1736/2736/4736/4736/5
assertion [1] 560/18
asserts [1] 488/22
assigned [2] 587/22628/21
assist [10] 593/22619/7619/14623/9
658/13671/19671/25672/23673/23
674/20
assistance [6] 496/8497/4519/23
541/16671/20671/22
Assisting [1] 498/14
associate [2] 717/7723/9
associated [34] 575/25576/3576/12
579/10580/2604/15618/11621/14626/4
628/11631/18638/21640/10640/17
643/23644/8644/18645/8651/9664/10
674/10676/20677/6679/1682/6683/13
696/14697/12704/4720/2726/6730/2
731/9743/11
assume [10] 484/5484/7488/17491/1
555/21556/16601/3604/12659/25732/22
assuming [2] 490/2582/10
assumption [1] 687/24
ATLANTA [4] 477/2477/22480/3762/6
attached [4] 1/5493/24704/22704/24
attaching [1] 1/8
attack [1] 489/4
attempt [3] 690/14698/10698/11
attempting [1] 595/10
attempts [5] 652/9697/19697/20697/23
698/19
attest [2] 521/22524/8
attestation [2] 554/12555/1
attested [3] 521/19573/12573/13
attesting [3] 530/11551/17689/18
ATTORNEY [1] 478/2
August [7] 569/2593/9597/6598/24
599/3599/6599/18
August 10th [1] 593/9
authentication [2] 587/4658/2
authority [1] 580/7
authorization [1] 579/21
authorized [9] 509/6509/8530/11
544/16547/1548/17555/6580/4600/18
automated [1] 656/14
automatically [4] 618/15638/12655/3
655/13
available [5] 519/24535/16537/23
603/20615/11
average [23] 512/7512/11512/13512/16
513/22514/10515/14515/19516/1516/17
516/22543/5551/20551/21551/25552/8
552/16553/11553/20554/1560/19571/4
571/5
avoid [2] 726/8758/1
aware [8] 595/12607/16607/20619/4
697/18711/11725/2728/19
AWS [1] 652/22
B
B9.1 [1] 751/10
back [83] 491/9494/21497/19497/24
498/19505/8511/8512/8522/17524/20
535/21535/22540/17547/23549/16571/7
571/19572/8592/12592/15592/22594/25
595/6595/10596/5599/14599/16603/6
603/25616/13621/12622/14623/2625/15
629/25630/10632/16632/19632/20633/5
633/13634/18636/11641/12642/18
642/21643/19645/14646/2647/17648/1
648/11649/3649/4649/4649/8649/15
651/4651/24652/2656/25658/4658/17
658/19659/4661/5670/12675/1687/14
687/15694/24700/9703/8705/10710/14
710/16712/19719/4727/9731/4733/22
745/21754/7
backed [1] 505/5
background [2] 490/5615/8
backing [1] 505/6
backpedal [1] 617/1
bad [3] 599/25600/3600/6
balance [15] 592/20592/20597/22
597/24598/9686/18707/15707/16707/22
710/8736/18736/19738/9741/1741/3
balanced [1] 707/23
bank [60] 482/10484/23486/24488/17
492/24497/19505/7507/16523/1523/6
523/15523/17523/19524/11524/14
524/15524/17524/22527/7527/8527/10
528/4541/23551/17578/17580/11586/7
586/8592/1592/4592/5592/12592/14
592/22595/1598/20599/13599/16601/8
602/1602/6604/2604/3604/21629/5
629/8640/16673/16681/1702/14702/15
703/12725/3728/18728/20730/1750/22
750/25752/16754/25
banking [1] 497/19
banks [3] 502/22522/20582/22
bar [1] 748/6
base [1] 751/5
baseball [1] 670/11
based [42] 496/20496/20512/7512/13
513/7514/4515/21516/1516/13516/18
516/25517/2525/9527/15542/16542/21
550/2552/15553/10553/13553/16558/12
574/19584/5597/2604/21612/12617/5
624/23655/5680/10692/6694/18695/20
698/19715/7717/9718/23733/19737/9
741/24744/10
basic [4] 686/13687/5709/15709/18
basically [13] 575/24652/25672/4676/1
686/18698/10700/19702/15710/7712/9
722/5726/24740/9
basis [3] 537/4538/9582/18
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 293 of 324
B
batched [1] 616/22
batches [2] 621/7621/7
bathroom [1] 746/7
be [323]
bear [1] 625/22
became [3] 527/17528/3529/5
because [71] 483/10483/18485/21
485/23486/1486/2488/15492/19493/4
493/12500/18503/9504/14508/10511/6
512/21513/1514/2515/1526/2527/23
534/5536/1537/18556/16585/19589/7
594/7602/14603/10610/18624/4632/10
638/13639/1645/4658/6661/18668/1
669/16678/3687/12690/1691/2694/9
694/16694/21694/25695/5699/10700/4
704/12704/24712/15716/15740/9743/14
743/15743/24747/2747/11748/5751/19
751/20753/21754/2755/21756/15757/15
758/8760/25
becomes [1] 710/9
beef [1] 495/1
been [114] 483/3483/3492/7495/17
497/9497/10498/10501/7505/8505/17
508/5508/7510/3510/18510/22511/23
513/2513/3513/4517/3517/9521/24
534/8535/24538/11538/25539/17539/22
540/3540/13540/18542/3544/19548/10
548/13549/14551/3551/13552/3556/10
556/13557/19559/5560/1561/2561/9
564/9564/11575/18575/18583/21583/25
584/10586/13586/15597/19614/10615/1
616/5616/6632/12634/5639/5640/1
654/17655/25661/3661/6662/13663/11
667/8667/17668/22668/23669/12670/15
671/11671/14672/9677/14679/4682/5
688/6689/1689/1689/3694/19694/23
697/22702/20702/21703/22703/25
704/19707/20707/21709/2709/5709/7
711/5718/7720/7721/2722/2723/8
723/12723/21725/2725/17729/15742/10
753/19755/3758/5
before [52] 477/11488/2494/7503/10
508/8519/21526/15526/17526/18572/23
579/17579/23583/24584/2586/5586/15
611/13611/16611/16611/16616/21617/1
617/3619/21625/25627/12627/15634/13
638/9640/14642/9649/2651/19660/1
661/17672/23680/23690/7692/18699/4
701/6704/20710/3714/3714/9716/11
719/13720/15731/6746/14748/20760/23
began [1] 583/20
begin [2] 564/2710/16
beginning [4] 543/12547/11688/10
735/8
begins [2] 509/6594/4
behalf [2] 577/1580/11
behind [1] 620/16
being [37] 484/1494/23500/19528/14
550/3574/12576/1588/17598/4620/7
620/8632/11637/18640/16657/5681/22
683/14683/22686/20687/21691/2693/25
694/9700/17710/12713/24714/11714/12
715/10716/6719/13720/13723/3724/17
727/20731/19734/24
belief [1] 689/14
believability [1] 484/20
believe [38] 483/2483/3520/15525/13
541/5544/20556/5559/25563/25564/7
565/19573/2573/16596/1611/22612/12
612/23628/7641/20661/14661/16666/2
680/9688/13689/4698/24709/25710/2
714/8722/13731/5732/21732/25734/2
741/22742/8750/8751/10
belonging [1] 593/16
belongs [1] 732/16
below [11] 509/9546/17548/18567/8
568/7579/22589/13590/13685/5686/24
690/25
beneath [1] 566/13
benefit [1] 735/17
beside [1] 680/18
besides [2] 661/2740/5
best [2] 670/10689/14
bet [2] 493/25598/9
better [8] 495/2526/3588/24659/20
670/1746/25756/4756/15
between [11] 504/13541/18572/8
626/15628/14639/15666/2672/8680/14
727/4728/2
beyond [1] 744/11
big [2] 731/23746/1
bigger [3] 596/19680/20735/3
binder [14] 505/16505/22505/22505/23
505/24505/25506/7506/7544/18544/21
624/5624/10642/18645/12
binders [1] 505/19
birth [11] 627/25628/2628/4639/25
640/4647/13650/18690/8690/13700/25
717/24
birthdate [1] 644/18
bit [23] 481/8499/20503/3568/7581/1
588/24596/19607/9614/22617/2630/5
632/8634/21637/1640/9670/1673/19
675/7690/25697/7709/20740/4746/4
blame [7] 482/12483/5483/9484/21
487/5487/9489/3
blaming [2] 481/25488/12
blank [1] 507/9
Bless [1] 608/24
blocks [1] 728/12
blow [6] 508/20581/1590/13592/8697/7
705/25
Bob [3] 662/21666/20670/10
bold [5] 630/24693/11700/14703/11
721/16
borrower [6] 503/6503/9504/8506/14
528/4594/14
borrower's [2] 503/8503/21
borrower/applicant [1] 503/6
borrowers [3] 607/11607/13607/21
both [17] 492/5492/16590/13591/5
591/16635/18637/23638/6638/18638/25
674/13680/4711/15729/12751/14752/16
755/25
bottle [1] 671/6
bottom [21] 508/17546/23550/5550/5
550/13565/9577/11631/5663/18676/25
679/10683/7687/17693/10714/25717/14
724/11727/4737/14737/15748/6
bought [3] 599/24600/2600/8
box [10] 511/10511/15547/25547/25
549/18550/1551/24552/11554/5632/4
boxes [3] 511/13549/24554/7
boy [1] 746/4
branch [2] 522/12522/13
Braves [1] 669/20
break [10] 480/25497/10571/14571/16
572/23636/2636/3642/10705/2705/9
breaking [1] 633/3
bridge [2] 672/7672/12
brief [1] 669/6
briefly [6] 497/15498/22529/3540/10
624/12741/13
bright [1] 489/3
bring [11] 481/13494/12535/21536/4
596/5613/23633/21634/12634/18636/19
697/2
broader [1] 753/18
broadly [1] 541/12
brought [1] 535/24
BROWN [6] 477/11485/22486/9608/8
608/16612/20
Bruce [2] 609/4612/24
build [2] 655/22655/24
building [11] 665/10665/12665/14
665/17665/19666/7667/11667/18667/23
668/22668/23
builds [1] 663/9
built [6] 655/24655/25656/6658/24
664/20703/1
bunch [3] 490/3493/24746/22
burden [2] 749/24750/19
burdens [1] 752/7
BURTON [2] 478/4478/5
business [82] 496/5496/6496/11497/3
497/4497/7502/15503/15505/13508/4
508/7508/10508/25509/2510/1510/2
510/6510/16510/19511/1511/16513/8
513/10514/8514/13517/8517/12519/3
519/18519/22520/24521/12525/8526/15
529/19531/25537/21542/9543/4543/12
543/15545/5546/5546/17548/10549/22
553/12556/22557/16559/21573/17579/9
586/10600/5600/15619/9660/25676/2
676/7677/3677/15677/18677/20677/21
678/1678/2678/3678/6678/17678/17
678/19679/20679/24682/1692/25715/19
720/1720/2720/24721/1733/6742/14
business's [3] 514/14675/25676/1
businesses [33] 496/7496/10496/14
496/17496/18496/19497/2498/2498/4
498/8498/24499/5501/4501/14501/25
502/5502/7502/12505/10508/13511/7
515/1520/19537/23543/22559/2587/5
587/18610/20611/7699/11699/12734/5
button [2] 616/3616/7
buy [9] 519/13519/13521/3521/7529/17
529/21555/9555/13600/12
C
C-A-R-P-E-N-T-E-R [1] 539/7
calculate [1] 514/4
calculated [2] 512/6553/9
calculating [9] 512/16513/10513/16
513/22513/23514/9515/14516/22551/8
calculation [9] 512/24515/8516/23
550/6550/9550/16550/22575/15606/11
calculations [1] 525/5
calculator [2] 570/22601/22
calendar [1] 700/5
call [23] 481/17495/6495/8535/21
538/21545/14558/14585/15585/17
585/25586/18587/7588/16589/4602/20
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 294 of 324
C
call... [8] 602/21603/9611/1611/25
613/12614/5671/17733/9
called [6] 495/11543/24574/8623/5
634/5664/20
calling [1] 585/12
calls [4] 538/22614/7662/9670/8
came [12] 482/8497/24588/13603/6
610/15638/18657/12660/22694/8695/21
735/11750/15
can [239] 480/22480/24481/2483/12
483/23486/12486/17487/8487/15488/10
489/4489/23489/23490/12490/18490/21
491/1494/15498/22499/14500/23504/2
507/4508/22510/10515/19519/7524/15
526/12531/7532/1532/25533/11534/21
536/15537/6537/8537/9538/14539/25
540/6541/6541/18545/2546/18546/25
547/9547/10547/18548/6548/7548/19
549/18551/25552/14552/18552/25553/2
553/2554/6556/12557/5558/25565/25
566/11567/8567/13570/10570/17570/17
572/16574/15576/9578/11579/4579/11
579/22580/24585/4585/4585/23588/2
588/8588/23588/24589/14592/8592/11
592/14593/10594/4594/13595/21596/5
596/8596/9596/15596/19597/2601/14
606/19614/4614/23615/19616/14617/13
617/13617/13617/17618/1618/2621/24
622/5622/14623/19624/12625/18626/6
629/9630/18632/21633/13633/22634/25
635/4635/5636/19636/24642/2642/5
642/6643/2643/7643/19645/15646/18
647/18647/23648/4649/4649/8649/15
651/5651/14651/15652/21654/9657/22
657/22658/17660/5660/7660/8660/12
660/23660/24660/24660/24662/4669/19
671/8672/11675/22675/24680/18682/20
683/5683/11683/25684/6684/17684/23
685/3686/5687/17688/3688/8689/5
690/6691/15692/11692/15698/16700/13
701/13701/16701/23703/8704/7705/13
705/20705/23706/13708/21708/21
712/19714/24714/25716/4717/1717/11
718/5718/13718/23719/6719/6722/24
724/21725/7725/12726/11727/9727/23
728/6728/24731/14731/16732/7732/20
733/4735/2735/2735/24737/14738/13
744/20745/15746/6746/7746/9746/13
747/2748/10749/6749/8755/4755/8
761/3761/6
can't [33] 483/18485/17485/22487/10
491/4492/4492/12526/10532/1537/10
598/22603/2604/18605/25607/17607/17
660/22664/7672/11690/2717/1717/2
732/20747/15747/19747/20747/22749/1
749/2753/17754/13754/21758/11
cannot [3] 487/9489/3526/13
cap [7] 511/3515/23516/12516/15
516/21516/22516/24
capacity [1] 492/25
capital [2] 496/8497/5
capture [2] 684/24702/25
captured [1] 751/23
capturing [1] 702/8
car [2] 600/2600/12
card [6] 579/9580/16593/24594/3594/7
594/8
care [1] 756/7
careful [2] 594/5594/6
carefully [1] 653/20
CARES [1] 537/20
CARL [63] 477/5544/10545/6547/3
547/9548/1549/5552/5554/24560/17
564/24565/4566/8567/23568/21569/16
570/6571/10577/14579/24580/4580/12
580/13585/14589/10589/21590/4591/5
593/17595/6627/17631/9639/11642/11
664/7664/7666/8672/20674/10677/20
678/3678/19679/22680/2680/3681/5
681/23682/2684/2691/14695/2696/9
696/12697/10702/17710/22712/24717/8
727/25730/12736/8743/25762/9
Carl Torjagbo [10] 544/10589/21590/4
593/17595/6627/17712/24717/8730/12
736/8
Carl Torjagbo's [3] 591/5696/12743/25
Carl's [2] 547/22564/22
carldelano3 [1] 628/11
Carpenter [5] 538/22538/24539/6
539/11758/10
carried [3] 693/23743/17744/1
carry [1] 743/18
case [31] 480/11482/1488/19491/6
491/7491/16536/2542/2542/2552/5
556/15560/9621/25634/22660/13668/19
673/10742/4748/12748/23750/14750/14
751/17752/8757/15757/15758/11758/21
759/1759/7762/10
case Number [1] 762/10
cases [6] 687/9688/19699/10700/7
750/1753/8
cash [2] 514/18559/17
casino [2] 703/5703/5
cast [2] 486/20490/10
caught [2] 486/10629/23
cause [5] 635/10635/11699/10755/7
756/10
caused [2] 660/8755/16
center [1] 671/21
centers [6] 497/7652/24653/7653/8
653/8671/23
certain [5] 542/21543/6604/18716/24
732/3
certainly [2] 491/13750/17
CERTIFICATE [1] 762/1
certification [8] 503/22510/10510/13
518/4518/17532/16557/4726/23
certifications [11] 543/6546/8555/2
558/12560/6560/10574/16574/18574/19
575/1575/8
certified [4] 1/14574/20575/13672/24
certify [10] 509/7509/9509/23532/18
547/11547/12548/18573/10611/10762/6
certifying [1] 550/2
CFR [2] 525/19534/1
CFRs [1] 534/5
challenge [1] 489/15
championship [1] 495/3
chance [1] 714/3
change [22] 515/3524/25635/15659/3
676/13676/15676/16677/6677/8677/11
677/11678/9679/4694/15747/15752/11
754/25755/3757/8757/14757/16757/19
changed [6] 616/16634/21635/6676/8
678/10757/24
changes [7] 488/17632/17632/21
677/15679/6707/10730/13
changing [4] 622/24728/23757/11
757/12
characters [1] 486/20
charge [7] 749/7750/6750/22750/25
754/10754/11758/1
charged [7] 749/9752/3752/6752/6
752/9753/9757/23
charges [4] 489/1554/21747/9752/16
Charlie [4] 485/22486/9608/8612/20
Charlie Brown [2] 486/9608/8
chart [1] 686/21
Chase [106] 539/14539/22539/23
539/25540/4540/7540/20541/18542/2
542/6542/9542/10543/16543/21543/24
544/2544/4544/7544/9545/5546/2549/2
549/9549/12551/4551/6552/7553/6
553/19553/23554/1555/5555/8555/12
555/16556/6556/21556/25557/19557/22
558/21560/7560/10561/5561/11563/17
563/21564/11564/17573/16573/23575/4
576/7576/12577/1578/17580/14582/2
582/12582/15582/17582/24583/2583/8
583/13583/18583/20584/5584/6584/7
584/22586/1586/19587/3589/11591/20
591/21592/5593/2593/17593/25594/7
594/25595/9600/17604/2604/3604/9
604/13604/21605/12605/18610/21
610/24611/3612/9612/9612/13613/1
613/4673/16681/1725/3728/18728/20
730/1
Chase Bank [4] 604/21681/1728/18
730/1
Chase's [3] 541/13542/3559/7
check [34] 511/13558/17570/17581/15
581/17581/23581/24582/6582/8582/23
584/3584/16584/18584/19595/3621/5
621/8708/16708/18708/24709/2709/8
709/11709/13709/15709/18709/21
712/10713/12732/16733/4733/6733/6
734/12
checked [4] 549/19550/1554/7632/4
checking [5] 579/10581/15585/11
620/10760/18
checks [10] 490/5559/3559/18560/4
581/13616/10688/15733/9733/11734/4
chief [4] 497/24498/10498/11498/13
choose [2] 504/24750/11
chose [1] 552/17
circle [2] 494/21753/21
Circuit [5] 492/23750/3750/5750/14
751/20
circumstance [3] 711/21719/12755/22
circumstances [3] 515/25516/4520/20
cite [2] 1/5634/23
citizen [3] 513/13513/15513/20
city [2] 664/12665/25
claimed [5] 558/18688/16694/5694/22
716/17
claw [1] 594/25
clawback [5] 592/25593/2604/22
611/13611/20
clawed [5] 592/12592/15592/22599/13
599/16
clean [1] 748/10
cleanup [1] 746/6
clear [14] 482/7493/12502/20520/16
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 295 of 324
C
clear... [10] 528/18618/14621/15635/14
750/10750/19751/15758/4758/16760/15
clerk [2] 654/9761/4
clicked [1] 542/13
client [4] 489/10489/15542/10731/10
close [13] 481/19482/9482/16503/1
503/13523/9593/12593/18594/6687/8
748/11748/24748/25
closed [5] 504/18505/4509/16548/22
594/8
closer [2] 539/15712/2
closest [1] 755/8
closing [8] 485/24489/22492/5492/6
492/9492/11494/5504/8
closure [2] 593/7594/3
CM [2] 1/21/3
CM/ECF [2] 1/21/3
code [18] 496/21566/13627/12629/11
640/23640/24640/25641/4641/5655/15
655/22655/24661/17698/3720/9729/6
737/17743/16
coded [1] 697/25
codes [4] 698/15698/16698/17698/18
coding [1] 575/25
coffee [1] 705/9
Colin [1] 608/20
Colin Farrell [1] 608/20
collect [1] 504/4
collected [3] 628/1629/6629/7
colon [1] 685/5
color [1] 747/14
colored [1] 728/11
COLTER [3] 477/20762/4762/18
column [12] 562/5562/11563/4563/10
626/10676/12678/13681/18693/14
699/17716/3724/5
columns [3] 561/25625/22637/20
combine [1] 750/10
come [16] 490/21506/4523/13535/12
572/21583/20584/5621/12622/14638/19
643/5661/4677/5694/9733/10733/16
comes [2] 657/2745/3
coming [11] 489/7503/16661/5670/5
672/23674/5700/15700/16717/15719/19
755/23
comment [2] 759/3759/18
commerce [1] 653/25
commercial [2] 493/18596/17
commercials [1] 672/5
common [4] 621/23622/16688/5731/15
communicating [1] 660/8
communication [3] 607/17653/24
672/12
communications [1] 672/7
companies [7] 582/14618/8652/23
722/3731/14732/6744/10
company [30] 501/6510/17510/21
514/21514/22515/3515/17516/25544/16
557/2557/8567/1589/15618/11652/22
663/9680/11693/5696/12702/21704/1
722/12722/17726/24726/25727/7730/9
731/15733/19742/11
company's [1] 515/2
compare [1] 698/2
compared [2] 577/16660/12
compensation [4] 567/14567/18569/9
569/25
complain [1] 585/12
complaining [1] 603/16
complaint [1] 585/9
complete [5] 503/6619/15665/21665/21
689/15
completed [1] 616/6
completing [2] 503/5712/9
complex [1] 664/20
complexes [1] 663/9
compliance [3] 497/5503/12504/18
component [1] 752/1
computer [11] 477/18572/8576/13
576/18628/22654/8654/10659/12659/13
662/8690/1
computer-aided [1] 477/18
concept [3] 491/16752/12753/4
concern [6] 484/15535/2634/4755/24
757/25758/15
concerns [2] 559/6745/5
conduct [2] 580/5580/8
conference [1] 482/2
confidence [1] 482/24
configured [1] 620/22
confirm [8] 487/13487/24536/19642/2
652/12690/9695/1727/8
confirmed [1] 661/16
confirming [2] 612/14612/14
Congress [4] 501/22504/15522/18
753/18
conjunction [1] 541/15
connect [3] 617/24630/12659/18
connected [1] 629/1
connection [6] 517/5564/8565/5590/7
591/2762/11
Connors [2] 478/3705/21
consider [2] 488/10491/1
consideration [3] 488/7594/5594/6
considered [3] 487/6496/17525/24
consist [1] 579/8
consistent [6] 598/3680/10681/21
723/21726/1726/15
consistently [1] 621/8
constantly [1] 621/5
constructed [1] 665/16
construction [3] 663/14665/19665/24
consultation [1] 506/16
contact [1] 574/11
contain [1] 517/13
contained [1] 580/18
content [1] 622/2
context [2] 491/14493/18
continue [4] 483/5633/7745/7757/9
continues [1] 481/3
contract [1] 652/25
contracting [1] 496/8
contractor [3] 509/18548/23665/13
contractors [5] 509/20514/13514/14
514/16549/1
control [10] 677/16677/23677/24678/4
678/21678/22680/7680/9683/13683/15
conventional [2] 520/17559/21
conversion [1] 616/21
converted [1] 560/13
conveyed [2] 632/12632/15
cooperation [1] 683/8
coordinator [1] 672/16
copied [4] 655/9655/12656/12656/13
copies [6] 535/16634/19636/7636/7
672/24746/23
copy [4] 534/17636/7745/22746/1
corner [4] 511/9548/7549/17693/3
corporation [1] 589/14
correct [326]
corrected [1] 711/7
correction [3] 623/10623/11711/11
corrections [2] 658/17658/24
correctly [4] 619/13619/14619/16
620/23
correlate [1] 624/17
correspond [1] 647/21
corresponding [1] 641/19
costs [6] 518/8518/8554/8554/16
554/16594/20
could [160] 486/3486/15489/11491/3
491/8491/13491/15493/13499/18501/25
503/3504/24507/6508/20510/7510/17
511/1511/8511/19511/25512/3512/8
513/2513/9513/10513/14513/21513/24
514/13514/19515/6516/1516/12518/3
518/22518/24519/1519/5519/12519/16
519/18519/24520/20521/24524/7524/8
525/22526/22527/12528/19528/20
532/14532/15542/11543/15545/22
546/23547/4548/14549/22550/13552/19
554/11557/12557/13561/14561/23565/1
570/25571/1571/7575/10575/12576/15
582/10585/3586/4586/7586/12586/23
588/5590/13594/10595/16597/16607/11
607/25609/9614/22617/21619/6622/12
622/14623/3623/4625/11630/12636/1
637/10641/11641/16641/22645/13
647/25648/11651/3652/2654/7657/25
663/17663/18663/20664/1665/22675/17
681/3681/10681/11681/25686/3688/1
690/3690/5690/17691/10692/24694/2
695/23697/2697/7698/9699/15700/9
706/8708/13709/7710/19713/7715/13
716/24718/7718/10720/18721/9723/24
726/3726/17726/20727/17731/14736/14
739/1741/16741/19741/19742/21748/24
748/25754/14761/3
couldn't [5] 516/17525/4584/18584/18
584/19
counsel [5] 491/22529/4535/11611/22
634/1
counseling [1] 496/9
count [6] 513/21514/9514/19515/7
515/14515/23
counted [7] 513/9513/16524/25525/4
525/6525/8525/22
countries [2] 513/8513/15
country [10] 513/14513/21514/22515/3
525/3603/22610/19652/24733/19733/24
counts [5] 653/14653/22747/15752/9
752/10
County [1] 480/3
couple [7] 494/21495/13572/10613/14
690/5690/6697/20
coupled [1] 638/20
course [4] 488/8488/8498/16660/25
court [22] 1/31/71/91/121/14477/1
477/21480/4480/7492/23634/22672/15
672/23755/25757/4757/10758/2758/3
762/4762/5762/8762/19
court's [1] 655/5
Courthouse [1] 477/21
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 296 of 324
C
courtroom [19] 494/14533/20533/24
536/13536/14571/22572/15595/20
595/24596/7613/20614/3633/12634/2
636/23705/12705/19745/14761/4
cover [1] 535/25
covered [16] 518/1518/1518/7518/7
518/8518/8532/5532/5554/8554/9554/9
554/15554/15554/16554/16750/1
covers [1] 567/4
COVID [5] 508/15688/10738/2738/4
740/5
CR [2] 477/4762/10
cranked [1] 735/11
crayon [1] 524/10
crazy [1] 524/10
CRC [2] 477/20762/18
create [1] 699/7
created [10] 501/15506/15546/9622/4
676/4677/21699/4700/5704/22738/16
creating [2] 499/13499/14
creation [1] 506/20
credibility [1] 484/20
credit [22] 540/13541/1541/10559/17
560/2580/16593/24594/3594/7594/8
606/15686/15695/18731/25733/7737/24
741/5741/6741/8741/9742/3742/14
credits [2] 688/13741/4
crime [4] 752/13753/4753/12757/23
crimes [1] 753/9
criminal [2] 477/4753/19
Crimson [3] 664/21664/22664/25
criteria [4] 526/25527/14528/18550/3
cross [11] 484/19487/4522/2536/17
596/11611/22654/3666/16669/9730/19
730/21
cross-examination [9] 522/2536/17
596/11611/22654/3666/16669/9730/19
730/21
cross-examine [1] 484/19
crossed [2] 483/3483/4
crossing [1] 482/9
CRR [2] 477/20762/18
CT [3] 547/20549/4554/23
culpability [1] 753/19
current [7] 496/23498/19510/11557/6
634/19672/15750/21
currently [5] 497/2510/14614/24637/20
671/8
cursory [1] 558/7
customer [24] 543/24544/9587/2
593/22615/24616/6616/13617/7617/10
617/15617/16617/25618/4619/4620/12
620/17621/21622/3624/1628/3640/3
640/4658/20671/16
customer's [1] 617/24
cut [3] 493/7708/25760/3
cutoff [1] 543/13
D
D-A-V-I-S [1] 614/17
D-R-A-K-E [1] 495/23
daily [1] 592/20
damage [3] 518/8554/9554/16
dangerously [1] 482/8
Daniel [1] 608/20
darn [1] 634/6
data [52] 542/21616/11616/18616/21
617/5617/10617/12617/17617/19617/22
618/3618/10618/13618/25619/5620/7
620/10620/12620/13622/25623/11
627/25631/7631/23640/1640/3640/4
641/24652/19652/24653/7653/8653/8
655/1655/4655/10655/16655/17656/5
656/7656/10657/1657/3657/9657/12
657/13657/16676/3690/21700/14704/7
717/25
database [10] 655/4655/11655/15
655/16655/16656/4656/9656/10656/14
656/16
databases [5] 618/15618/16655/1655/3
655/6
date [64] 534/13543/4543/13543/14
547/4547/5547/7548/8573/17574/12
574/13576/4576/4576/21576/21578/13
579/11579/12579/14581/5581/20585/15
587/6588/2588/3592/17592/17593/8
596/23598/15598/21612/14627/4627/25
628/2628/4639/25640/4647/13650/18
663/20673/20673/24677/1677/2677/16
678/14678/15680/5690/8690/13700/23
700/24700/25708/18709/13709/14
709/14717/24718/2719/25720/1735/8
737/10
dated [5] 586/5586/15586/23592/11
714/21
dates [2] 591/9660/4
daughter's [1] 669/23
Davis [16] 614/7614/9614/16614/21
615/9624/3624/10625/9625/24630/21
637/8637/13641/14646/5652/12654/5
day [15] 502/6502/6528/14530/10
530/14538/17578/19592/20628/9635/5
659/8718/11748/24749/3762/14
days [1] 1/4
deadline [6] 607/10607/19607/20
607/22607/24611/13
deal [1] 731/23
dealing [1] 659/12
Dear [1] 593/13
debts [2] 740/19740/21
December [8] 501/20501/23569/22
598/20702/7702/9727/4728/2
December 2020 [1] 702/7
December 27th [1] 501/23
December 31st [1] 727/4
decide [3] 480/10480/18754/9
decided [6] 481/9593/12593/14593/17
594/6606/23
decides [2] 525/20526/5
decision [7] 484/8493/1493/2527/7
559/8611/19613/2
decisions [1] 635/5
declaration [1] 692/5
declare [1] 689/12
declaring [1] 714/17
declined [1] 578/12
decrease [1] 694/12
deducted [5] 688/18693/25709/22
709/24710/15
deductions [1] 707/11
default [11] 505/9523/6541/23594/12
594/15594/18598/19604/12611/17612/4
628/6
defendant [15] 477/7478/4482/14
488/16559/20559/20583/22584/9599/2
609/15611/23635/9695/18710/11755/6
defendant's [7] 533/14597/1597/2
597/10598/6611/19675/9
defense [5] 491/22529/3597/13611/22
749/13
deferral [2] 527/20527/22
deferred [1] 598/4
defined [3] 490/25525/13525/17
definitely [1] 756/19
definition [8] 525/17526/12751/3751/6
752/19752/23754/19754/22
defraud [6] 635/8753/10754/3754/3
754/4755/6
DELANO [36] 477/5477/6544/10549/7
552/5555/9555/13556/25560/17561/6
564/5564/19573/4573/12576/25577/14
585/25586/18588/15589/2589/20593/17
595/5595/10598/23598/23599/11666/11
678/20680/3681/5681/23682/2731/10
762/9762/10
Delano's [2] 526/10593/24
Delano/Torjagbo [1] 564/5
demand [1] 502/10
demonstrative [1] 674/25
denied [2] 578/20579/1
department [4] 506/16541/16587/3
601/2
depending [7] 571/18621/20623/6
685/6687/13694/2722/12
depends [1] 488/14
deposit [5] 579/20579/21580/24581/5
594/8
deposited [1] 629/8
deposits [1] 733/5
depth [1] 559/12
deputy [3] 496/23496/25761/4
describe [2] 498/22592/11
described [2] 559/25653/23
description [1] 727/1
design [1] 575/7
designed [10] 541/14559/1617/8656/4
658/12658/13658/15658/16659/10
735/17
desk [1] 648/11
Despite [1] 591/19
detail [1] 608/21
details [1] 585/4
determination [2] 513/7514/3
determine [8] 511/6525/8525/9527/9
527/14619/10685/22686/9
determined [7] 507/20513/5546/7
551/10593/3744/3749/14
determines [1] 525/23
develop [1] 663/10
developing [1] 500/6
development [1] 497/7
dial [1] 637/3
dictated [1] 559/7
did [191] 480/21480/23481/20482/4
486/14489/10493/25497/17497/20
498/18499/6505/23507/15508/7508/9
509/22509/25510/6510/15510/17510/21
511/5512/11512/20512/24514/11515/23
517/5517/9517/13517/23520/1521/14
521/22522/20522/23523/13523/19
523/20524/1524/5524/5537/23540/20
542/1543/1543/2543/21544/2544/4
548/10550/1553/19556/25557/18557/22
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 297 of 324
D
did... [135] 558/21559/12559/14560/17
560/22561/5561/8561/20562/5562/11
562/23563/4563/10563/18564/5567/19
568/8568/11568/11568/14568/16569/5
569/8569/11569/21569/24570/2577/23
580/7580/13582/17582/20583/20583/24
584/2584/5584/22586/18589/11589/20
591/14591/15591/19591/21591/24593/2
595/5595/9595/13595/14599/9599/10
602/17603/19604/3604/22606/13606/25
607/6607/6607/8610/21611/25612/9
613/1622/15624/19624/23631/19639/5
643/15643/17650/14654/20654/21
655/22658/4660/14660/19665/11665/18
665/19665/23667/3669/22671/19672/1
672/14672/23672/25674/5674/7677/5
677/11678/6678/8678/9678/12679/3
679/6682/8686/6686/18688/24688/24
689/25691/6691/6694/9695/1697/17
698/6698/8711/22716/7716/20716/22
717/21718/21718/24720/5720/8726/5
727/13727/16729/11732/2742/6742/23
745/9745/22754/9757/4757/9758/25
didn't [39] 493/7493/14495/4516/20
527/16528/22529/4535/25572/20572/20
599/6601/5603/12603/16603/25604/2
604/16604/16605/21605/23606/3606/5
606/7607/25610/12630/12633/17634/12
661/18661/19705/3734/23734/23734/25
739/11739/21739/24754/2754/3
die [1] 535/10
difference [2] 558/25639/14
differences [4] 578/1679/23679/25
680/1
different [49] 490/4491/14502/20
503/23503/24504/2504/12537/6538/3
542/15559/22560/1577/21591/8591/9
591/11617/23620/19626/3639/18639/19
639/19642/25649/2649/7652/10653/9
661/9661/9671/6672/24673/11674/9
710/24711/21711/24720/12728/11
728/23730/11731/14731/16732/7739/8
739/8741/17742/5746/23756/4
different-colored [1] 728/11
difficult [2] 700/12742/11
digitally [3] 542/11574/10616/2
digits [3] 565/1631/3679/21
diligence [7] 523/19524/5524/7559/3
559/18560/4602/5
direct [19] 484/7495/25502/21523/22
527/12532/12534/3536/21537/2539/9
552/22552/23573/2614/19629/8658/11
663/2671/1705/5
direction [1] 537/17
directly [8] 501/13528/11582/11582/14
617/20618/16657/3755/22
director [3] 496/23496/25663/14
disagree [5] 489/18601/22635/21756/8
757/19
disagreed [1] 635/14
disappoint [1] 662/24
disburse [1] 523/9
disbursed [1] 504/19
disbursing [1] 504/8
discovery [3] 534/18534/19535/13
discuss [1] 749/20
discussed [5] 538/10591/15639/16
641/8642/22
discussing [2] 586/1639/17
discussions [1] 744/24
display [2] 625/16663/15
disputed [1] 634/21
distracted [1] 596/3
district [9] 1/14477/1477/1496/23
496/25497/14750/15762/5762/5
divided [2] 570/24570/25
division [2] 477/2672/7
dizzy [1] 644/24
do [155] 480/18481/10484/1486/6487/8
487/9489/16489/18489/22490/1490/5
490/5490/25491/1492/12494/10496/4
497/5503/19506/11519/23520/9525/17
525/19525/19527/12528/8528/13533/5
533/21535/5535/10535/18535/19539/13
541/20544/23545/1553/2556/3558/4
559/8559/14570/25582/14582/20584/13
585/15595/22596/13597/3598/22598/23
598/23599/2599/6599/21601/5604/20
604/22606/3606/10607/19608/23609/18
613/15613/16618/22619/13619/24626/2
626/10626/11626/15626/17628/13630/6
630/7630/21630/24631/1631/16635/6
648/14648/16652/9652/20653/5653/11
655/5655/22655/25658/3658/5659/21
660/14663/6665/11666/22666/23666/24
666/25667/23669/1670/5671/5680/19
683/8683/10683/19683/20690/6690/22
697/25705/3705/3705/6705/9705/10
705/17708/18717/7720/21720/23721/16
721/18724/23727/13729/12729/14
731/20733/15733/17733/21733/21734/4
738/21744/10746/1746/3746/6749/7
750/4751/25752/14752/21753/25755/19
756/10756/13756/17756/19758/15
760/16762/6
docket [1] 1/6
document [52] 1/9484/2486/22487/12
488/16505/25505/25506/11537/9560/25
561/15561/16562/18562/19562/22566/4
567/4568/20570/9571/3571/8571/9
574/6574/9575/2575/23586/7586/12
586/13589/9590/13590/16590/20590/22
591/24596/13607/23610/3612/17612/18
612/19612/20613/1630/22654/17654/20
675/12692/19721/24726/22735/16
735/20
documentation [18] 510/6517/6520/4
520/16524/16532/6543/8543/11543/15
558/1558/5560/18561/2561/5587/9
589/5606/10742/6
documentations [1] 586/2
documented [1] 606/1
documents [59] 482/10482/11486/2
487/14487/24488/18517/9517/12517/13
521/23524/14527/15532/20544/19
544/24547/14558/8561/8561/12563/18
564/1564/2564/6564/6564/7564/9
564/11564/14564/18573/4573/8573/20
573/23573/24577/24579/2586/4586/19
590/14591/1591/3591/19602/11603/7
605/5605/6605/13605/15605/21606/10
606/14607/3612/12613/4624/13624/15
654/24655/9672/24
does [144] 481/2490/13491/2491/16
498/3498/7505/6524/14524/17524/22
527/25528/15558/22559/15562/19
565/14566/10566/15574/9575/23576/5
579/7580/10581/14582/6584/9587/20
588/9589/9590/3592/25593/24594/1
594/22595/9597/22597/25600/10601/12
601/15612/22612/24618/14619/18629/6
632/3635/8638/1639/7642/4642/12
642/14642/16642/17644/15644/17
644/18644/20647/7647/10647/12647/21
648/8648/22648/24648/25649/1649/25
650/12650/15650/17650/18652/16
652/17652/18667/25668/16668/16
675/19675/21676/3679/7681/20683/14
683/16684/3684/5686/6686/11686/12
687/2689/11689/17689/22689/22690/24
692/4693/5693/6693/25694/12696/5
700/4701/6701/9702/2702/4706/3706/6
707/19708/4708/19708/20708/24709/11
710/14712/4712/16712/18714/5715/18
719/1719/22719/23721/12723/2723/4
723/6724/4724/11724/13724/16724/18
733/12733/13734/1734/17744/3746/18
749/16753/1755/6755/19757/19
doesn't [19] 486/3493/2536/5555/25
556/14600/9600/13618/16669/16717/3
717/3738/19747/18749/16749/21754/15
758/21758/21760/3
doing [9] 520/12560/4616/1620/19
635/18688/1690/1748/12758/4
dollars [2] 554/3692/2
domestic [2] 500/25525/7
don't [126] 480/16480/18480/21480/24
481/3481/4481/17482/20483/22484/6
486/5487/4487/17487/21487/22488/2
488/16488/18488/20488/20489/20490/5
490/5491/6494/4524/17527/23528/1
528/11530/18530/25531/21533/17
533/22535/4535/4535/10536/4537/11
537/16547/18556/16580/19584/14
584/15587/16598/21599/4599/8599/21
599/22601/11601/13601/22603/12
603/15604/24604/25606/9606/20607/2
608/15608/19608/21609/1612/2622/11
625/15631/9633/8633/24634/2634/17
635/1651/15651/18657/4657/13657/13
658/6659/14660/14665/3667/1667/2
667/20668/11668/12668/13668/15
668/18668/19668/21674/21709/15
732/16733/11733/12733/13734/4740/20
744/15745/22746/5750/22751/2751/22
752/23753/24754/13754/19754/22756/6
756/12756/14757/12757/20758/22
759/15759/21760/8760/11760/13760/18
760/20761/9
done [17] 492/11494/23503/10520/13
535/19535/20538/14572/9572/17620/19
633/24655/14705/5742/22743/22746/8
746/16
double [1] 760/18
double-checking [1] 760/18
Douglasville [10] 644/16650/16677/1
678/24679/8679/9680/15681/8681/24
682/7
down [41] 483/5500/18511/10530/1
530/8530/18530/19530/24530/25533/3
538/14539/20547/25550/12554/5554/12
555/17556/7557/4565/16604/22633/13
651/16662/4664/9665/13665/14666/2
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 298 of 324
D
down... [13] 667/18669/19670/21689/6
691/15705/13724/8727/3736/7737/1
738/13743/22744/20
download [1] 618/2
Drake [8] 495/9495/16495/23496/2
522/4536/5536/5536/7
drawn [1] 584/3
drew [2] 556/5608/18
Drive [1] 477/22
drop [1] 761/6
due [21] 520/18523/19524/5524/7528/3
528/5528/5559/1559/3559/18560/4
585/9594/14594/18595/7598/1598/12
598/14598/17599/18694/24
duly [5] 495/17538/25614/10662/13
670/15
dumb [1] 491/3
during [16] 492/6494/5498/23498/25
500/18501/25502/1504/3504/14504/16
537/20684/15688/10697/23728/3738/2
duties [2] 496/25498/13
dynamic [1] 541/18
E
E71 [6] 664/11664/25667/12667/14
667/17669/13
each [8] 490/6509/10542/22548/19
553/12633/8633/9726/9
earlier [20] 564/7570/17571/8598/19
605/14606/25629/15639/11639/21
640/10640/23652/9661/20692/4694/5
699/19707/8718/16725/15728/9
earned [2] 686/19694/15
earnings [5] 694/1696/7716/9716/16
719/17
easier [3] 545/3624/4752/7
easily [1] 623/19
easy [1] 659/9
eccentricity [1] 758/20
ECF [2] 1/21/3
economic [6] 501/21510/11557/6
610/19635/11757/16
economically [3] 635/10755/7755/20
edit [1] 756/23
edits [1] 746/12
Edwin [1] 608/25
EF [1] 621/2
EFE [1] 638/17
EFE's [1] 659/17
effect [7] 533/7534/6534/11534/12
534/24535/3535/6
efficient [1] 500/1
effort [1] 588/16
EIDL [5] 552/11552/17552/19552/21
552/22
eight [1] 656/18
EIN [106] 566/2586/5586/25587/10
587/15587/18587/21588/10591/8629/21
630/4632/11640/20642/23642/25645/3
645/23648/25648/25649/2651/21651/25
652/10661/9661/13661/18661/19673/20
673/21675/25676/3676/4676/6676/7
676/9676/12676/13676/18676/21676/23
677/6677/12677/15677/18677/21677/22
678/7678/14678/15678/18678/25679/1
679/19679/20679/21679/23681/15
681/17682/1682/2682/5682/6683/3
683/13683/15697/6697/6697/8697/9
697/12698/6698/19698/20698/25699/7
699/25700/1715/21719/24720/12720/16
721/1721/4721/6723/7723/9723/22
725/9727/11727/21727/25729/2729/6
729/13729/15730/5730/8730/14730/15
731/1741/24742/7742/9742/11742/17
743/3
EINs [9] 591/11699/9700/5720/14
727/14729/2731/9731/10731/16
either [17] 492/1509/17548/22613/25
617/21629/7659/5668/20676/6677/25
698/13699/9710/2734/12741/24748/9
760/13
electronic [19] 615/13615/14615/21
616/4616/8616/16616/18619/24620/18
621/2627/9629/3632/24657/3657/10
689/23689/25698/10714/20
electronically [6] 619/18652/14690/11
712/14718/7733/3
element [8] 487/22488/3488/6749/25
752/12753/15754/8754/12
Elementary [1] 495/12
elements [3] 542/22752/16753/9
Eleventh [5] 492/23750/3750/5750/14
751/20
eligibility [7] 513/1540/8543/19543/19
546/7551/10612/14
eligible [27] 487/13487/24501/4501/7
502/7505/11505/14507/21508/5509/17
510/22513/4514/16514/23519/5519/7
531/18543/14548/12548/22549/22
550/21583/5583/11583/16591/25593/3
else [13] 532/8537/14633/9668/13
690/19709/24711/9715/5744/18752/20
759/9761/2761/7
else's [1] 669/10
email [9] 623/19623/21628/11628/15
632/22632/23640/11748/10761/3
emergency [3] 504/14504/15520/18
employed [9] 498/25500/9500/12
500/15509/17548/23614/24671/9734/5
employee [26] 500/21513/22515/6
515/7515/12515/13515/17515/17515/18
515/18515/22515/23515/23525/1525/4
551/12590/17590/22631/5631/7673/25
674/8675/24698/16732/3732/9
employee's [3] 513/6515/13723/12
employees [64] 493/23496/19498/24
500/21501/6509/19509/19510/25511/4
512/15512/18512/23513/8513/9514/4
514/18516/23525/7525/10526/11543/5
548/24548/24549/20549/21549/25550/3
550/16550/20551/7551/11551/16551/17
551/21552/9553/21554/2557/8563/1
567/9567/10568/8569/5569/21570/12
570/13575/14605/8605/23608/3609/14
610/20721/6722/3722/3722/13722/18
723/9724/12725/23738/23738/25739/2
739/4
employees' [1] 563/6
employer [26] 513/21588/5589/17
590/22590/24629/21630/25631/2640/20
642/13642/15642/16645/3648/23674/1
674/10675/19675/22681/13681/15693/7
696/10719/21722/16738/17742/21
employer's [1] 515/14
employers [1] 738/22
enacted [1] 757/7
encompass [1] 753/10
encompasses [1] 753/11
end [28] 491/10505/8524/20524/20
524/21585/23593/14616/2619/20635/5
642/16656/25657/9660/2686/10686/17
686/25689/22691/4691/24693/25696/25
716/21719/22756/7756/25760/1760/4
ended [1] 637/8
ending [47] 566/2592/20626/10626/13
626/19637/18646/8646/24647/2648/15
648/25650/2651/12661/13676/12677/15
677/19678/7678/15679/1679/19683/3
683/15685/22693/8700/25701/4702/5
702/9703/19706/4707/3713/23714/10
718/17718/19719/18723/7727/11727/14
727/15727/21729/10731/2735/22743/12
756/24
ends [3] 488/21728/1729/12
engine [11] 615/13615/14615/22616/4
616/8616/16620/18621/3627/10657/4
657/10
engineer [2] 615/4615/5
engines [2] 633/23633/24
enough [4] 513/13559/6665/21744/17
ensure [4] 619/2674/6699/20715/10
entail [1] 559/16
entailed [1] 499/15
entered [13] 494/14536/13536/14
572/15596/7614/3617/17620/8627/21
628/3636/23657/16705/19
entering [1] 617/13
enters [1] 652/25
entire [12] 490/10540/18632/5643/11
649/12656/15661/24678/17678/19
694/23702/9753/14
entirely [2] 694/22716/9
entitled [4] 484/22487/5531/22710/6
entity [1] 540/1
entrepreneurs [1] 497/3
entries [1] 656/18
entry [4] 1/6586/23592/10592/10
environment [1] 610/19
equal [1] 629/17
equals [2] 552/11629/18
error [49] 621/14621/15621/20621/25
622/1622/2622/5622/14622/15622/16
622/17622/21622/23623/1623/22623/23
629/10629/11629/12629/16629/18
629/18629/20629/22629/22630/1630/6
632/18640/19640/22641/5641/7641/10
644/23644/25647/8650/24658/19658/21
661/17661/21698/3698/6699/23711/9
720/9720/12720/15729/6
errors [6] 620/20622/8623/18660/3
660/5660/7
escorted [1] 596/1
essence [2] 610/15610/17
essentially [16] 483/5484/12484/25
618/1619/2626/3650/9686/12689/22
693/25694/12697/19701/9707/23708/24
710/15
establish [8] 543/18584/24677/16
678/14678/15690/5719/25720/1
established [10] 543/13548/11548/13
653/17653/20677/22692/25699/1699/11
699/12
establishing [1] 678/6
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 299 of 324
E
establishment [2] 548/7680/4
Europe [1] 733/20
even [26] 515/22525/21529/9529/13
529/16529/16532/3541/24613/18622/15
623/5627/15658/15660/2689/11690/19
691/5692/3703/3709/17729/6729/19
746/24751/20758/13759/1
event [1] 505/9
ever [20] 530/25556/25560/12560/15
560/17595/6595/9599/11612/7666/8
666/12667/3669/1679/4682/5686/2
704/19721/6733/1734/3
Evert [2] 478/3490/13
every [15] 490/9507/15509/22546/13
610/25627/16627/23667/6667/23686/14
695/12709/16742/6742/25743/3
everybody [7] 494/16494/17518/13
539/17572/24625/17644/24
Everybody's [1] 480/6
everything [6] 616/15655/24691/7
698/16702/25714/3
everything's [1] 655/25
evidence [21] 481/25489/7490/21
555/21555/23574/4575/23577/4578/8
579/5585/3586/22587/13588/23589/25
593/5593/21594/10663/16674/22674/24
ex [7] 635/16635/24756/13756/21757/6
757/7757/13
exact [4] 601/10601/13612/1740/20
exactly [8] 493/8494/1601/10606/20
621/10631/16637/3713/4
examination [22] 495/25522/2529/1
531/15532/12536/17539/9572/17596/11
609/11611/22614/19654/3663/2666/16
669/7669/9671/1730/19730/21741/14
744/8
EXAMINATIONS [1] 479/1
examine [1] 484/19
examined [6] 495/17538/25614/10
662/13670/15689/13
examining [1] 484/1
example [8] 526/1537/19551/11619/8
676/11742/5753/10755/4
examples [2] 622/8742/23
Excel [6] 624/21625/21625/25631/17
654/18656/8
excited [1] 670/2
exclude [1] 481/25
excuse [1] 518/1
excused [1] 613/9
Executive [1] 522/13
exempt [1] 504/16
exhibit [90] 505/17507/1507/7532/15
533/15545/23572/7574/4575/22577/3
578/7580/19580/22585/2585/5586/21
587/13588/9588/23589/24592/3592/4
593/5593/20594/9596/10609/10611/23
624/4624/5630/11630/18631/17631/20
637/16642/6642/9642/19642/20642/21
643/3643/22645/15645/17645/21646/6
647/18647/21648/12648/19649/5651/5
651/21651/24651/25663/16674/6675/13
675/17680/23681/17683/5683/17684/24
692/15697/3697/9698/22699/16701/13
704/5708/14710/19713/8713/11715/14
715/16717/12717/14718/13719/7720/10
720/19721/10723/16726/20727/17
727/23728/7735/6
Exhibit 1 [1] 533/15
Exhibit 101 [4] 545/23589/24609/10
720/19
Exhibit 101A [1] 574/4
Exhibit 101B [1] 575/22
Exhibit 101C [1] 596/10
Exhibit 102 [1] 577/3
Exhibit 102A [1] 578/7
Exhibit 103 [3] 580/22592/3592/4
Exhibit 104 [2] 586/21593/5
Exhibit 105 [1] 594/9
Exhibit 106 [3] 587/13680/23683/5
Exhibit 107 [1] 588/23
Exhibit 108 [3] 585/2585/5611/23
Exhibit 150 [4] 505/17507/1507/7
532/15
Exhibit 201 [7] 683/17698/22704/5
713/11715/16717/14720/10
Exhibit 201B [1] 708/14
Exhibit 202 [2] 663/16710/19
Exhibit 204 [1] 726/20
Exhibit 205 [1] 727/17
Exhibit 206 [1] 727/23
Exhibit 212 [1] 701/13
Exhibit 213 [1] 718/13
Exhibit 220 [5] 624/5631/17637/16
643/22646/6
Exhibit 221 [6] 630/11631/20642/9
642/19642/21649/5
Exhibit 224 [2] 645/15645/17
Exhibit 226 [5] 647/18647/21648/12
651/24651/25
Exhibit 227 [1] 651/21
Exhibit 27 [1] 651/5
Exhibit 310 [1] 580/19
Exhibit 310A [1] 593/20
Exhibit 503 [5] 675/17681/17697/3
697/9719/7
Exhibit 504 [2] 699/16728/7
exhibits [21] 544/18544/20545/12
591/14591/15606/21624/6624/10624/20
624/20625/3641/14641/18645/7645/11
673/2673/6674/15674/19674/23674/24
Exhibits 101 [1] 544/20
exist [8] 491/16508/9511/5512/20520/1
661/19661/19669/16
existed [2] 508/10558/25
existing [4] 508/13559/3665/10665/11
exists [3] 492/15492/16558/25
exited [8] 533/20533/24571/22595/20
613/20633/12705/12745/14
expat [1] 514/6
expatriates [1] 733/21
expats [1] 741/19
expect [1] 743/5
expectations [1] 494/22
expected [2] 711/3718/6
expedition [1] 500/3
expenditures [9] 518/1518/7518/9
531/18532/5554/9554/10554/15554/17
expense [7] 517/25518/1519/5519/7
519/11519/12532/4
expert [3] 526/8576/14634/4
explain [18] 499/14503/3504/2508/22
519/7541/6541/18552/14558/25576/9
594/13675/22686/5688/8698/9700/13
704/7716/4
explaining [1] 757/12
explanation [1] 757/8
explicit [1] 750/16
export [1] 618/13
exported [1] 617/14
Express [1] 758/13
extended [2] 527/23528/2
extent [2] 703/17758/2
external [1] 618/11
eyes [2] 688/25691/18
F
face [3] 582/23671/23671/23
facilitates [1] 619/23
fact [21] 482/13485/2489/9492/24
549/10551/8553/20553/24558/19573/12
573/13584/24586/18591/25602/8607/4
610/21613/6653/16653/19658/15
facto [7] 635/16635/24756/13756/22
757/6757/7757/13
factor [1] 512/12
facts [1] 555/21
failed [2] 641/1660/9
fair [17] 492/13492/13528/6537/15
596/21603/3603/4603/13603/17606/4
607/4607/5654/25657/8732/13739/11
744/17
fairly [1] 634/11
faith [6] 488/22509/9541/20548/18
558/6749/13
fake [2] 484/4484/9
Falcons [1] 494/24
falling [1] 489/4
false [12] 485/4487/1487/2493/4504/20
521/15524/4531/1531/11532/22547/15
613/5
falsehood [1] 486/1
familiar [12] 506/18543/24544/9585/5
628/17664/16664/19672/19696/11706/1
710/21720/5
family [1] 595/23
fan [1] 669/20
FAPR [2] 477/20762/18
far [5] 489/18491/17576/2637/21744/23
farmers [2] 516/5516/8
Farrell [1] 608/20
fast [2] 518/10518/12
fault [9] 482/2487/10487/11504/21
504/22523/24523/25524/2524/3
February [55] 508/8508/25509/16510/7
519/21526/15534/15543/13548/21
549/10549/13561/16562/3562/7562/12
563/11567/5567/11574/21576/20576/21
577/6577/8577/17577/24578/4584/25
586/5586/15587/6589/22590/7591/17
610/6612/15612/17612/18613/1627/5
637/24644/13646/20647/4650/6660/18
663/25700/24714/21717/21718/3721/13
723/19730/1730/16731/6
February 12th [6] 644/13646/20647/4
663/25714/21718/3
February 13th [3] 650/6700/24717/21
February 15 [1] 730/16
February 15th [7] 526/15543/13548/21
549/10549/13574/21731/6
February 16th [7] 534/15576/21577/17
577/24589/22590/7730/1
February 2020 [1] 613/1
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 300 of 324
F
February 6 [1] 627/5
February 6th [1] 637/24
February 7th [1] 587/6
February 9th [2] 577/6578/4
fed [8] 638/8639/2639/6641/1641/1
721/17721/19724/5
federal [58] 496/7500/25501/2501/3
522/10522/11554/20562/6563/5563/22
567/17567/20568/17568/23569/12
569/18570/3587/4600/20615/15616/17
617/9620/21638/4638/13638/21638/24
639/1641/7643/23644/7647/9649/24
651/10651/10685/4687/11688/11696/6
702/20703/22713/12713/16713/24
713/25721/5721/19721/21722/1722/2
722/7722/9722/20723/3723/18724/3
724/12743/16
federal regulation [1] 587/4
feds [2] 638/7638/11
fee [2] 601/11604/22
feel [1] 753/1
fees [2] 594/21604/20
few [10] 522/6577/24579/17581/9609/8
619/17654/6730/23743/10747/5
field [4] 491/23492/13615/6693/11
figure [10] 552/3552/18552/24684/20
685/18686/1693/17713/4716/5743/9
figures [1] 687/18
file [24] 477/4535/11638/4657/25
686/17687/7691/21692/11697/1698/11
711/3711/6711/10711/14719/20722/4
722/14726/17727/6727/22732/4734/6
734/6744/10
filed [31] 1/21/71/9481/24517/10564/9
564/12586/13591/3619/11620/20639/5
641/9645/18660/12660/19661/20682/25
693/2706/16707/2710/22711/14711/17
712/6720/7725/18725/21726/3727/20
732/8
files [1] 687/6
filing [48] 615/13615/14615/17615/21
615/24616/4616/8616/9616/16617/4
619/18620/8620/18621/1621/3622/5
623/25626/20626/21626/23627/4627/7
627/9631/23632/1632/3637/9638/1
638/2638/12639/6646/7647/9657/3
657/10660/3660/4660/15664/5673/20
673/25690/19692/9697/20699/11704/15
706/17712/5
filings [24] 615/16620/24621/6621/7
624/16624/24626/3627/16629/3637/14
637/18638/18639/12639/22644/4660/11
660/13660/16660/19672/19673/13
673/14673/24697/18
fill [3] 507/15617/8685/6
filled [5] 507/11546/11616/6620/7
719/14
filling [1] 619/7
fills [1] 704/16
final [2] 499/10616/1
finally [2] 728/17729/25
financial [1] 560/3
financials [1] 748/20
find [23] 506/4506/6651/17676/17
676/23679/3679/6681/25682/8686/3
695/1718/21726/2726/3726/17727/19
727/22728/1728/3732/7734/23734/23
734/25
finding [1] 619/15
fine [7] 486/17571/15572/11584/14
634/15662/25756/6
finish [3] 484/16536/24538/5
finished [1] 616/1
FINLAYSON [3] 478/4478/5756/8
Finlayson's [1] 635/23
firm [1] 540/10
first [67] 481/11495/17495/21497/12
497/22505/22505/24505/25509/11
511/22511/24511/25537/21538/25539/5
546/5548/19550/2566/6566/24567/20
575/11578/13578/17578/19579/1593/10
597/25598/14598/17602/8602/13614/10
614/15616/9622/2625/10626/7626/8
627/19631/21638/8642/22643/15656/15
662/13662/18669/23670/15670/20
671/15678/22681/18683/11683/25
686/19687/9693/16716/8724/25727/5
730/1736/17736/17748/9755/2759/6
five [6] 505/21540/16613/18656/22
672/2672/14
fix [5] 616/14621/22622/5622/8622/23
flags [5] 582/24583/2583/4583/8583/13
flew [1] 667/6
flipping [1] 505/16
Florida [1] 526/2
flow [1] 559/17
fly [1] 581/10
focus [2] 500/17649/24
focused [2] 498/1573/16
folders [1] 545/2
folk [1] 622/2
folks [2] 528/9596/2
follow [2] 485/7532/11
follow-up [1] 532/11
following [4] 1/1598/7633/7718/11
follows [5] 495/18539/1614/11662/14
670/16
forbidden [1] 492/7
forbids [1] 752/14
foregoing [1] 762/12
foreign [4] 501/4513/8525/7744/10
foreign-based [1] 744/10
forgive [1] 595/13
forgiven [13] 520/21526/22527/2527/5
527/6528/20529/17532/1532/3532/8
603/23612/7757/5
forgiveness [29] 504/18520/23521/2
521/6521/10521/14527/9527/13527/15
527/16528/19529/5529/9529/14530/14
530/18530/19530/24530/25531/22
603/20604/2604/4607/9607/11607/14
607/25611/13611/20
forgot [2] 711/12719/10
form [57] 506/15506/18507/9507/16
508/2510/4512/24517/3531/24542/21
544/25546/1546/4546/9546/10546/11
548/2549/1550/24561/1564/2564/22
565/9570/8573/5573/5589/18591/6
612/16619/7642/9656/11673/11682/24
686/17687/3699/25702/13702/15703/11
706/25713/19714/15719/14722/4722/4
722/8722/11725/14725/24726/23727/1
734/8734/9734/13742/18762/12
format [3] 616/11616/17620/22
formerly [8] 560/17573/13576/25
577/14585/25588/15589/20595/5
forms [27] 509/21532/20542/17547/14
560/23561/7561/20591/9591/12605/3
605/12605/15605/20605/22606/2617/8
617/9619/11619/15624/14624/18671/24
685/13727/6727/6728/12741/17
forth [4] 572/8688/12688/14722/17
forward [1] 482/17
found [3] 651/19678/25682/9
four [14] 560/24565/1631/2645/23
678/1679/21726/9742/5747/16747/16
747/22747/23748/1748/3
fraud [28] 483/6483/7489/1489/4
491/16492/24492/24554/21750/17
750/17750/22750/25751/2751/24751/25
752/1752/7752/8752/9752/10752/16
752/16753/8753/11754/25755/1758/24
759/2
fraudulent [2] 484/3486/12
free [2] 601/6671/16
freeze [1] 591/20
freezing [3] 584/9585/9585/12
Friday [1] 748/25
friend [2] 691/20715/5
friendly [2] 658/12658/14
front [13] 491/10492/19524/20524/21
544/21598/11624/6657/9661/6684/17
684/21693/23743/8
froze [1] 584/6
frozen [6] 584/13584/20588/17589/7
602/24611/16
full [8] 1/8504/17566/14566/15594/18
641/22709/22724/3
fully [1] 695/13
Fulton [1] 480/3
fund [2] 503/14559/5
fundamental [1] 560/2
funded [3] 522/14522/15552/23
funding [3] 509/1542/1722/5
funds [40] 488/23500/1501/13501/14
504/8504/18509/2517/20518/4518/5
518/17518/22518/24519/1519/16519/18
520/19520/24521/3521/7521/11523/9
534/2536/21541/16546/6554/12554/13
554/19555/4555/5559/2582/17582/24
583/16584/10585/10585/13592/12604/7
funny [2] 486/20495/14
further [18] 522/1528/25531/13532/12
532/18533/2536/17547/11547/12550/7
595/15613/8666/15669/18691/15737/1
741/11743/21
FUTA [7] 721/21721/24722/1722/1
723/5724/6724/16
FW2505 [1] 641/3
FW2505-01 [1] 641/3
G
Gables [11] 663/7663/8663/11664/21
664/22664/25665/5665/8665/11665/16
667/16
Gables Crimson [1] 664/21
Gables Residential [1] 665/16
gambling [1] 703/3
game [3] 669/22669/23669/25
gather [7] 528/3528/8659/11667/20
668/19733/8733/15
gathered [1] 656/7
gave [9] 482/10482/11482/11544/7
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 301 of 324
G
gave... [5] 634/20745/20745/21759/2
760/25
geared [4] 508/12511/15512/21518/19
Gene [1] 608/22
general [12] 496/17511/3511/4615/19
749/23751/1751/3751/20753/1753/4
753/12754/2
generally [8] 558/8628/20692/22696/17
711/8711/19722/3722/12
generated [4] 510/1655/3695/15695/21
GEORGIA [27] 477/1477/22480/3
496/24497/1497/2522/9528/12566/5
566/8566/15566/21638/2639/1639/4
639/5643/14643/23644/8644/16653/9
677/12679/9681/8681/24682/7762/6
get [89] 481/18482/16483/1484/18
484/19487/1487/2489/20491/2497/3
497/4500/1501/13501/17504/6504/24
505/3508/5511/19511/25512/4513/24
516/24517/18520/3520/5520/11524/20
532/1532/8534/3535/3535/24536/20
542/6546/24549/22556/17559/23561/24
585/3588/19590/9603/12603/16611/7
613/19613/24617/17618/2622/11623/4
627/15629/6632/1632/18635/17636/1
637/1637/4638/6639/4654/9657/7
666/22671/5672/11686/23687/11688/18
690/17704/1705/9709/20714/9720/5
722/8729/11733/7742/14745/7745/22
746/8746/16747/6747/12749/5752/12
755/8
gets [10] 618/20623/2632/15687/15
693/23704/22719/14731/24731/25734/3
getting [22] 499/4500/3501/14503/25
507/17511/25520/8520/18537/21541/16
559/1596/2617/12628/23659/2672/24
686/16692/10716/21729/9739/4739/5
Ghana [6] 500/15501/6510/2514/7
526/11551/12
gist [1] 653/4
give [27] 490/13505/7524/11537/19
544/4603/2615/19621/6621/21623/16
636/6645/14652/21655/18676/11695/19
742/3746/15746/22747/1748/9751/16
754/14754/18758/22758/22758/24
given [11] 482/13485/3502/25503/19
505/2516/24535/9541/19543/15623/19
658/22
gives [2] 487/19489/16
giving [4] 572/10682/23751/16759/4
Glauser [3] 606/15606/18606/22
Glover [1] 608/20
gmail [2] 640/10640/11
gmail.com [1] 628/14
go [95] 480/7484/22487/5489/13490/5
491/9495/6527/13530/6531/25533/4
536/16548/6556/19559/12559/22571/7
572/8572/22577/11594/10596/8604/22
605/11611/3614/21616/9616/15622/1
622/22630/17632/16632/19632/23
635/23636/19636/25637/13641/15642/5
643/2645/20648/18649/8649/9649/20
651/14652/4654/2664/1674/21675/1
675/13681/11683/5683/17684/23689/6
690/8692/14692/15695/11695/23700/10
705/21706/8708/22712/20713/7715/13
717/11718/6720/18721/9723/15723/24
724/8724/21724/24725/7725/12726/11
727/3736/7736/18737/1743/7743/22
744/24744/24745/10746/5746/7749/6
754/7
goal [2] 500/10500/14
goals [1] 500/7
goes [12] 483/9483/18493/6493/7616/4
620/15624/1637/4657/5717/7743/20
749/24
going [154] 482/16482/17483/1484/6
484/7484/11484/13485/1485/5485/8
485/10485/15485/16486/23486/24
488/18489/5489/13490/2491/8491/9
492/20493/14494/5494/6517/2518/10
518/12522/17524/24530/5530/11531/18
531/22532/8533/6533/11533/14535/2
535/3536/11537/15542/3550/11555/9
555/13555/17556/7556/22556/25572/7
572/22575/21581/17585/2587/12595/19
597/1603/11603/15607/6611/24613/18
616/2616/3616/9616/12616/12616/15
616/16617/5617/10618/21618/22619/1
620/2621/12621/14621/15621/21622/22
622/24623/15625/9625/22626/6626/8
626/18629/9630/10634/18635/3637/13
637/15638/14639/4639/10641/14641/15
644/15644/23646/5649/24650/15650/23
651/16651/17651/24655/20662/25
663/15676/11686/8687/18688/8692/14
694/24695/11695/19698/12698/13
698/13705/17706/5709/11709/13710/4
712/9715/5716/25719/4719/11724/8
732/14743/6744/23745/6746/4746/15
746/15746/22746/23748/11748/14
748/19749/3749/10752/18753/13758/7
758/19759/15759/21759/23
gone [7] 538/11562/9562/15563/8
563/14703/25708/7
good [42] 488/22496/2496/3509/9522/4
522/5522/6522/16538/13539/11539/12
541/20548/18558/6571/13613/17613/22
613/24614/23623/16654/5654/5654/17
663/4663/5671/3671/4671/7673/18
692/16701/24705/7712/10719/7730/24
731/21733/6735/4749/13752/11756/20
758/14
good-faith [2] 541/20558/6
got [43] 481/15482/19485/1490/10
494/22495/2495/11495/12502/13503/15
515/22526/3534/18535/11545/2552/24
553/6570/22571/18574/20576/14598/9
601/5603/10605/14616/10616/11633/19
633/20635/19656/17699/23700/4700/21
729/5729/17729/22729/23734/15744/24
745/2745/24745/25
gotcha [2] 628/10659/16
gotten [5] 510/8712/13712/14747/7
747/8
governed [1] 600/20
government [36] 480/22481/9483/10
484/1488/25489/8489/9491/7495/6
495/8500/24501/1501/2501/3522/12
522/23535/12538/2538/22544/18554/20
579/7600/21600/25604/6604/12611/23
662/9670/8687/11688/11731/24738/19
748/11751/18758/3
government's [52] 505/17506/25507/6
532/14544/20545/11545/23574/3575/21
577/3578/7580/19580/21585/2585/5
586/21587/13588/9588/22589/24591/14
592/3592/4593/4593/20594/9602/21
609/9625/3631/20637/16641/14645/7
645/11646/5647/18647/21651/5654/8
654/10663/15673/2674/15674/19680/23
697/3697/9698/21699/15719/7720/18
728/6
grab [2] 536/5662/8
grand [7] 561/21561/22562/2562/24
562/25723/18724/10
grant [1] 606/23
great [4] 495/12499/20548/15669/25
green [1] 728/14
gross [6] 516/1516/13516/25517/2
570/15737/1
grounds [5] 489/6533/16744/13749/22
756/13
grouping [1] 620/24
grumpy [1] 603/10
guarantee [5] 505/4522/24523/11
541/22604/15
guaranteed [6] 504/17522/25523/8
532/23547/16600/25
guess [25] 483/2488/1488/4523/23
527/6535/10536/8550/25566/18601/22
628/9656/18657/17661/12661/17733/4
734/5735/11737/25738/3748/20754/1
756/14759/19760/2
guessing [3] 525/15526/8622/11
guest [1] 668/13
guidelines [2] 504/19505/5
guy [1] 484/11
guys [8] 495/13522/14527/7600/23
601/2601/5601/5604/16
H
H-A-Z-E-L [1] 670/24
H-O-R-N-E-R [1] 662/19
H-O-W-A-R-D [1] 614/17
Hackman [1] 608/22
had [162] 481/24484/3484/8485/3
485/13486/2487/3487/6490/7494/18
494/19505/8505/13508/4508/10509/19
510/1512/15512/18512/19513/2513/8
514/7516/17517/3517/21519/3519/21
523/8523/9523/9523/10524/7525/6
526/15527/13527/17528/23529/10
535/12537/18537/20540/6540/13540/18
540/20541/5541/10542/8542/19542/22
542/24543/6543/8543/10543/18548/10
548/12548/24549/12551/3551/11552/9
553/14553/19554/1555/8555/12555/16
556/6556/21557/22559/20559/22560/19
561/11563/17563/21564/8564/11564/17
567/10567/10572/6573/9573/20573/23
575/18582/10583/21583/24584/5584/22
586/13586/15592/1603/22608/1611/4
611/10613/4615/8623/10625/24635/11
637/8639/6639/6641/8646/24657/24
661/17661/18667/11671/22672/1677/14
679/4685/21688/17688/21689/1689/1
689/3694/22695/5695/6695/8695/12
697/22699/19699/19701/6702/20703/3
703/22703/25703/25704/19707/6709/2
711/5713/10713/12713/22713/24714/3
719/13720/7721/4722/18723/12725/2
729/1729/5729/15730/15742/9742/17
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 302 of 324
H
had... [3] 750/3750/5759/14
half [13] 508/17512/14540/14540/16
550/5550/13552/15553/3553/4553/10
717/15748/24749/2
halfway [1] 692/16
hammering [1] 489/9
hand [5] 511/9533/14548/7549/17597/1
handful [1] 581/10
hanging [1] 754/22
happen [12] 542/14596/4619/18621/24
655/23660/12693/21694/14698/13716/7
718/5734/1
happened [7] 482/15639/3641/8660/13
695/5716/4716/8
happening [2] 620/4620/5
happens [3] 638/7694/12712/8
hard [3] 641/23669/22705/25
hardware [2] 652/23653/1
has [69] 1/7481/1483/3483/3483/10
489/12492/24507/11509/16515/17523/6
524/14538/11544/25548/21574/11
574/12574/20575/13575/25611/3616/5
616/5617/16617/24618/22619/25620/23
626/13638/8650/16659/18665/5666/7
666/7666/12667/17668/12668/13671/14
676/12677/23682/5684/21690/21692/6
694/19696/7696/10698/16706/19707/15
707/20707/21707/23708/5727/4729/10
729/19729/20730/2744/3751/6751/6
753/19755/3757/10758/3758/5
hasn't [2] 634/5753/18
hate [2] 633/21756/24
have [360]
haven't [5] 488/1488/5672/10752/9
753/22
having [9] 495/17538/25548/3614/10
629/8662/13670/15726/8731/12
Hazel [28] 670/9670/14670/23670/24
671/3671/8672/17673/9675/19680/22
681/13681/20683/7683/19684/9685/2
686/5692/18695/11697/5701/16710/21
716/4720/21721/12726/5730/23741/16
he [76] 480/23481/1481/1481/2481/2
483/4486/4486/6486/8486/8487/18
487/19487/19487/20488/9488/22490/10
491/2492/16493/23495/4523/22524/1
529/4533/7534/14534/23537/8544/11
544/16556/25559/22559/23560/22
560/24565/10565/14565/16566/15
566/20567/10578/16578/20586/1586/4
586/4586/7586/7586/12586/12587/9
589/11590/6590/8590/8590/20595/10
598/24599/6603/15605/14606/25611/25
668/1669/19691/1695/5695/6717/1
717/2717/2717/3717/3730/15749/16
754/2
he's [12] 482/18483/1485/5485/10
491/23603/9603/10603/16634/8634/9
634/10691/2
head [3] 530/17530/23584/14
header [1] 629/22
headers [2] 746/19746/23
headings [1] 703/11
headquartered [1] 519/4
hear [5] 495/4522/16556/15614/22
672/5
heard [3] 480/7602/21672/10
hearing [2] 633/23762/11
hearsay [1] 668/2
heart [1] 752/9
held [1] 762/8
help [12] 500/14506/6610/3617/8
619/12622/3623/8655/20672/5672/7
672/13722/5
helpful [1] 636/5
helping [3] 497/4508/13671/21
helps [4] 496/14498/4617/11754/23
Hendrix [1] 636/11
her [16] 480/8480/9480/15480/15
480/16480/17480/17490/8506/4521/15
534/3535/19535/20535/21536/6536/9
here [85] 480/6480/16489/24489/24
490/3491/12494/20497/10508/18509/6
511/10512/9524/25526/12534/10545/2
547/25552/24565/10565/22597/19
622/11626/8627/16630/18633/13637/2
637/14638/25639/7640/19642/7642/10
644/9646/13648/14663/21666/24676/16
676/22677/16677/18677/20678/21680/7
680/14687/17689/6689/8689/22691/8
691/13692/3693/1694/14696/2699/22
700/14700/18700/25702/2702/13703/23
704/2707/16709/17710/10713/14714/14
715/2723/2724/2724/5724/23725/14
728/12736/17739/9742/23745/10751/18
751/25752/17753/9757/8
hereby [1] 762/6
herein [5] 495/17538/25614/10662/13
670/15
hey [6] 528/4602/23607/14611/3711/11
752/19
high [3] 502/10560/1576/15
highlight [2] 626/7735/24
highlighted [4] 629/13637/16637/23
640/6
hill [1] 535/10
him [21] 481/2482/13484/16486/14
488/9488/25536/24537/8537/9538/5
592/1599/9603/1603/2634/5662/22
670/11672/20695/19717/1752/3
himself [1] 483/6
hired [3] 500/21540/8665/13
his [27] 482/21483/6483/6521/15
523/23534/13534/14544/14559/23
561/20565/10565/14565/16573/13
578/19588/16588/19589/21590/3590/7
590/9598/14608/24625/14625/16634/6
738/9
hit [6] 616/3616/7670/3670/4703/4
706/9
hits [1] 657/1
hmm [1] 615/6
hold [12] 481/22484/16484/16485/17
485/17488/25534/21554/20585/20603/1
603/11653/15
holding [1] 750/18
home [9] 495/11519/9519/9519/11
519/12583/2670/4670/4745/7
honestly [1] 687/6
Honor [47] 481/20481/24492/18493/9
506/9529/24555/20572/4597/9613/13
614/6624/7625/2633/3634/24635/12
636/9636/17653/11653/21654/1662/1
662/3670/8673/1673/7674/18674/23
675/11675/16705/1705/22741/13744/11
744/19744/22746/18748/23749/8751/4
751/8755/15759/8760/5760/9760/17
761/11
HONORABLE [1] 477/11
hook [3] 523/1523/3523/4
hope [1] 538/17
hopefully [4] 626/6651/3658/13700/12
hoping [1] 662/23
Horner [7] 662/9662/12662/19662/21
663/4666/18670/10
hosted [1] 659/17
hosts [1] 659/16
hour [1] 633/5
house [7] 490/10514/7519/14519/14
525/3599/24600/8
Houston [13] 627/20631/14631/18
647/10648/14664/13664/17665/2666/1
667/1667/3712/16739/22
how [93] 483/22484/20486/12487/6
489/11492/13494/4497/9498/10498/10
504/2506/22511/3512/6512/11513/5
515/6515/12515/13517/20522/5527/22
528/1539/22540/3540/24542/7553/9
554/3560/1562/5562/11563/4563/10
567/19568/8569/5569/11569/21571/15
576/18586/1596/20606/20609/20609/22
609/24610/18615/1615/19619/18621/22
621/22623/22632/18635/1637/3647/5
652/21653/5653/8655/12659/24660/12
663/11664/19665/5665/19666/11670/12
671/11680/9686/6686/6686/7686/12
686/21689/25694/8695/9696/17730/25
731/23731/25732/2734/3748/12752/24
754/7754/15754/19754/22757/12
How's [1] 750/3
Howard [1] 614/16
however [3] 1/8674/22751/14
huge [1] 656/14
hundreds [1] 661/5
Hurts [1] 495/12
hypothetical [4] 555/24556/17556/18
599/23
hypothetically [1] 733/18
I
I'd [9] 488/12574/3624/17649/3670/3
674/18748/25754/7754/8
I'll [25] 480/18481/4489/21493/24506/6
506/6529/3537/19539/25545/5568/19
572/21572/21586/21598/9634/15638/24
640/9642/19662/8746/3747/1748/9
760/1760/14
I'm [127] 482/23484/21484/22485/16
485/19486/5487/4487/5489/18490/2
490/22490/23493/7493/16493/18493/20
494/5494/6495/1499/19518/12522/6
524/24525/15526/8530/4530/5533/6
533/11533/14535/20536/1536/11571/7
572/7575/11575/21577/3578/7581/9
585/2587/12587/12591/21595/12596/20
597/1601/10601/25603/15606/17607/16
613/18613/22613/25615/4615/23622/11
625/12625/22626/6626/8626/18629/9
630/10630/12633/16633/23634/18635/3
635/17637/13637/15641/14641/15
644/15644/23647/25649/19649/24
650/15650/21651/7651/24654/9655/20
656/3658/10659/7661/14662/24662/25
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 303 of 324
I
I'm... [35] 664/7667/13667/16668/6
668/10671/5672/15676/11682/16689/2
691/7695/11704/5705/1705/23716/24
716/25719/4719/5724/3724/24734/9
746/15746/22749/25750/21752/18
753/13753/20754/11756/21757/25759/4
759/6759/23
I've [21] 492/11492/12497/10533/14
534/18535/11545/2570/22603/10633/20
634/21635/21637/15656/17668/23
674/14733/3733/11747/7753/22760/14
ID [23] 575/24619/21630/25631/2
642/15642/16675/25676/7686/4701/21
703/21711/19712/15713/25717/9717/9
717/10718/24722/17726/25732/5732/15
742/19
idea [7] 483/15490/7492/4615/19
652/21658/19753/10
identical [1] 714/14
identification [22] 505/17544/20588/5
589/17590/17590/22590/23590/24674/1
674/2674/9674/10675/20675/22675/24
681/13681/15681/15690/4691/2693/8
719/21
identified [10] 589/17640/1649/11
682/10693/17694/9696/2696/3720/24
743/3
identifier [1] 576/17
identifies [4] 546/5575/25642/3677/25
identify [3] 648/22676/2676/2
identity [3] 657/19657/25690/14
IDs [2] 622/13657/17
illegal [1] 757/25
image [1] 581/23
imagine [1] 668/6
immediately [2] 594/19617/22
immunity [1] 760/3
impacted [1] 611/20
impacting [1] 610/18
implementing [1] 499/3
implies [1] 623/1
imply [1] 555/25
import [3] 618/10618/22618/23
importance [1] 696/24
important [16] 501/10507/22508/1
521/18521/19549/2549/9551/6552/7
553/23555/5557/19564/14575/4593/11
593/12
imported [2] 617/14618/25
importing [1] 617/19
improper [3] 482/15487/4489/11
improperly [1] 483/4
inability [1] 585/10
inaccurate [4] 564/17573/24724/15
724/20
inapplicable [1] 757/15
include [9] 480/22512/25577/24612/22
612/24707/7711/12754/6760/14
included [14] 490/4507/24510/13
512/23514/14542/19542/24546/13
546/15550/16550/21575/14742/5755/4
includes [4] 612/19612/20714/16
714/16
including [5] 511/9511/11549/17573/4
652/13
income [44] 516/1516/13516/25517/2
553/13565/13565/14565/17567/17
567/20568/17570/3589/13600/13601/11
685/4686/14686/19693/11693/12693/14
694/15694/16696/8697/1701/18701/19
702/24703/1703/18703/20703/20704/13
713/12718/16718/18718/22718/23
718/24719/3721/19722/7722/9737/1
incomes [1] 692/24
inconvenience [1] 480/15
incorporated [2] 526/20614/25
increase [1] 711/22
independent [6] 509/18509/20514/13
514/16548/23548/25
independently [1] 620/10
INDEX [1] 478/7
indicate [12] 580/10632/3638/1639/7
642/12701/6714/6715/18721/12723/3
724/11724/16
indicated [2] 615/21716/11
indicates [2] 574/10704/16
indicating [7] 508/19630/19642/7
682/13720/15723/18724/2
indication [3] 566/20595/9691/13
indictment [2] 653/23749/10
individual [23] 490/6509/17519/22
542/13548/23631/7641/24655/9664/10
666/8666/11678/1678/2684/15687/3
690/20692/11692/24701/9701/21711/2
711/17732/6
individually [1] 656/12
individuals [5] 516/23579/25580/2
587/5615/11
inducement [1] 759/2
Industries [81] 543/25544/2544/4544/7
545/6546/19546/20548/4549/9549/12
551/4551/7552/8553/6553/14557/18
557/22560/12560/19561/17562/6562/11
562/25563/5563/10563/18564/18565/23
567/2567/19568/8569/5569/21573/3
574/10577/1578/12579/10579/15579/17
580/1580/11581/25582/5582/11583/17
584/23584/24586/2587/22587/25588/10
589/16589/18590/23591/16591/25
593/13594/16595/5642/13648/23672/21
674/11678/7678/11678/19679/22681/5
681/23682/2693/5696/10696/15697/13
715/18720/3720/24721/14725/23743/1
Industries' [15] 544/12550/24552/9
553/16562/2562/20568/2568/23569/17
582/2584/6589/7592/5595/1727/20
ineligible [2] 529/13532/2
influence [1] 492/25
information [141] 485/3485/5487/16
492/22503/10503/12503/19503/22504/4
504/6504/20507/16507/20507/23507/23
508/1509/4517/14517/16520/6520/7
521/15521/18521/19521/23524/4524/8
527/8531/1531/11532/18532/19542/15
542/17543/2543/10546/11547/12547/13
558/10558/15560/3561/11563/21564/14
564/17573/10573/24574/11575/8583/21
584/24593/11593/12593/23602/15
602/17611/10613/5615/8616/7617/6
618/17618/20620/8621/19621/22622/21
623/3623/12623/17623/18623/19623/23
624/21627/6629/5629/6629/10630/22
631/6631/21637/14638/14640/16648/20
657/21657/22664/2672/20673/15673/19
676/8676/14681/21682/24687/3687/24
689/9690/13690/17691/7691/16691/23
692/6692/10693/10695/20696/7696/19
696/25697/15699/20700/15704/13
704/16704/17713/1714/2714/17714/18
715/6715/7715/10717/15717/18718/22
718/25719/13720/9724/3726/1726/19
727/1728/22728/23732/23741/25742/2
742/24743/5
infrastructure [1] 652/23
initial [1] 495/23
initialed [1] 509/12
initialing [2] 509/9548/19
initially [1] 635/22
initials [3] 547/19549/3554/22
initiates [1] 618/4
input [7] 617/5617/10618/21623/11
634/11640/3640/4
inputted [2] 552/3619/5
inputting [1] 715/6
inquire [1] 489/23
inside [1] 623/20
instance [1] 526/10
instances [2] 752/13753/7
instead [6] 583/1583/7679/13742/16
742/17742/22
institution [1] 600/18
institutions [1] 502/22
instruct [2] 490/22757/10
instructed [2] 687/11758/17
instruction [22] 490/18492/2492/23
493/25633/8750/7751/6751/9751/10
751/14751/22751/23753/14753/16
758/21758/22758/23758/24759/3759/24
760/12761/4
instructions [14] 490/24492/20616/12
634/19671/25685/13705/17744/25745/8
745/16747/12751/21752/20758/17
INT [3] 702/13702/16703/11
intend [2] 537/23754/3
intended [4] 509/3537/18537/24546/6
intent [12] 635/8635/9749/24749/25
753/1753/4753/11753/12754/2754/3
755/5755/7
intentionality [1] 752/14
interest [12] 517/25518/6554/8554/14
594/20594/20702/16702/18703/2703/12
710/8736/21
interface [1] 634/9
interim [1] 499/10
internal [16] 574/7607/3640/25671/10
671/12671/15685/25691/18698/12
701/20710/1714/1721/8722/22723/11
733/13
Internal Revenue Service [13] 671/10
671/12671/15685/25691/18698/12
701/20710/1714/1721/8722/22723/11
733/13
international [1] 500/22
Internet [3] 652/16690/2700/19
interpret [1] 758/4
interpreting [1] 758/5
interrupt [2] 485/17705/4
interrupted [1] 492/11
interruptions [1] 746/24
interstate [1] 653/24
intervention [1] 660/11
Intuit [25] 614/25615/1615/3615/6615/9
615/10615/12615/17618/12619/9620/9
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 304 of 324
I
Intuit... [14] 620/9622/7624/23627/7
634/1652/18652/22652/24652/25659/15
659/16659/17660/2660/7
Intuit's [2] 615/13659/15
invalid [1] 630/4
investigation [1] 673/10
investment [1] 594/8
invocation [2] 480/24481/5
invoice [1] 596/17
invoke [1] 480/23
involved [6] 506/20506/22533/18
540/24615/23668/6
involvement [2] 499/6540/21
involves [1] 757/16
IP [16] 576/2576/9576/11576/12576/14
576/16628/17628/17628/20628/23
628/25629/2629/2640/13640/15644/21
IRS [174] 482/11506/16513/7514/11
517/10519/10519/11525/13525/15
525/18525/20525/20525/23526/5526/5
558/18561/9562/9563/8564/9564/12
587/15587/20587/21588/13591/3611/3
616/23616/25617/20618/16619/22
619/22619/24620/3620/5621/6621/9
621/13621/15621/19621/25622/6626/22
629/22630/1630/3637/9638/1640/24
641/5645/1646/13650/13650/14658/20
659/12659/18660/8661/15661/21661/24
671/14672/6672/8672/13672/24673/14
675/19676/2676/3676/5676/6677/25
683/14685/23686/2686/25687/2687/5
687/8687/14687/23688/1689/3689/8
689/9689/11689/17689/20689/25690/3
690/16690/21694/17694/23695/2695/8
695/19698/15698/16698/23700/16
700/20702/15703/6703/21703/23704/1
704/17704/20707/6707/19707/23708/5
709/11709/15710/3710/12711/2711/11
711/16711/19711/23711/25713/24
715/11716/24717/7717/19717/21718/6
718/11718/24719/1719/15721/6722/8
723/13724/12725/21726/4726/17727/7
727/20728/15729/9729/23729/23731/18
731/18732/3732/4732/9732/11732/14
732/16732/18732/23733/4733/5733/23
734/13735/15740/21741/20741/23
741/24742/1742/10743/7743/18744/2
744/3
IRS's [15] 676/9676/17676/23677/3
677/8679/1681/20682/17688/22697/21
698/3702/10726/2726/16743/6
is [989]
Isaac [1] 608/10
ish [1] 613/24
isn't [4] 487/18487/19487/20530/14
issue [19] 481/21483/10483/25487/18
493/6493/8501/9538/11541/9572/6
622/11623/6623/11632/11634/21635/24
720/16758/14759/1
issued [25] 485/4521/24583/17583/18
588/10592/1629/21640/20645/3681/4
681/22682/13696/9707/18707/20708/9
720/13720/14726/9727/25729/6729/15
731/4738/3740/3
issues [1] 672/13
issuing [1] 709/13
it [820]
it's [192] 480/16483/9483/20483/21
483/23483/25486/13487/4487/10487/11
488/8488/10488/13488/24489/12489/21
490/9490/10495/12496/7503/9505/22
505/24506/14507/25511/4511/10513/7
522/11525/12525/12526/20528/5532/2
534/24534/24535/3535/6539/6544/21
544/24547/18547/24551/1551/2553/3
553/4555/24565/10567/15575/11576/17
576/18579/22582/21585/9587/4587/9
592/10592/14595/19595/25598/9607/14
616/10616/10616/11616/12616/12
616/15616/16616/21616/21617/7617/23
618/11618/22618/25618/25620/2620/13
620/18620/21621/14621/14622/4622/18
622/21626/10634/3634/10634/11638/1
640/3641/23644/9651/16652/22652/22
654/12654/24655/14655/14655/14
655/14655/15656/3656/3656/3656/4
656/14656/14656/18658/13658/15
658/16658/19659/2659/8659/23659/23
660/11662/25664/11672/6672/9675/25
677/25680/3680/10682/13686/18688/21
689/20690/25691/24691/25692/21696/9
696/21696/21700/17701/2705/25707/5
709/15710/2712/4712/5712/10714/17
721/12722/13722/14731/15731/15
734/15736/8738/19743/6746/4746/23
749/9749/23750/1750/2750/2750/2
750/10750/11750/14750/18750/23
750/25751/3751/4751/14751/15751/23
752/5752/18754/2754/10754/11755/17
756/20756/20757/3757/6757/16757/24
760/4
item [13] 512/22548/20565/9565/13
565/22566/9566/13567/8567/13568/7
570/10575/12590/14
itemization [1] 684/7
its [18] 496/16498/6501/6506/20517/6
517/8517/13521/20557/8557/10563/1
563/6582/11582/11582/23613/2731/24
752/9
itself [5] 487/12617/11619/12730/6
734/9
J
J-A-M-E-S [1] 614/16
J-O-H-N [1] 662/19
James [4] 608/16614/7614/9614/16
James Davis [1] 614/7
JANA [3] 477/20762/4762/18
January [15] 498/12498/18502/3502/4
502/4502/7567/5567/11588/11590/21
590/21678/15680/6699/11700/5
January '22 [1] 498/18
January 13th [1] 502/4
January 2021 [1] 680/6
January 2022 [1] 498/12
job [3] 480/8480/9480/16
John [10] 485/11485/21486/8486/14
493/21608/14608/14662/9662/12662/19
John Horner [1] 662/19
John Snow [5] 485/21486/8486/14
493/21608/14
journal [1] 721/13
journals [1] 570/16
JPMorgan [4] 539/14539/22553/19
584/6
Judge [8] 528/25536/9609/6613/21
669/4741/11747/14759/12
JULY [9] 477/12480/3569/2597/6
597/16597/23598/1598/2762/8
June [6] 568/5682/11735/9735/12736/6
736/6
June 4 [1] 736/6
juror [1] 749/4
jurors [16] 494/14533/20536/14571/22
572/15595/20596/7613/20614/3625/13
633/12636/23705/12705/19745/14
757/12
jury [23] 488/7489/11490/22492/20
492/23507/5535/8576/15596/15596/15
613/15634/19636/16671/8675/2705/17
708/21719/24744/25745/16756/4758/16
759/22
just [166] 480/12480/19481/18482/15
483/4483/18483/21483/22483/23484/18
485/11485/12485/13486/9486/10487/5
487/12488/5488/15489/9489/22490/7
492/1492/18492/19492/19492/21492/21
492/22493/4493/9493/14499/18499/20
502/5502/19503/3505/6506/4508/20
520/15524/21528/18529/3533/23536/19
537/10543/18545/5551/12551/20559/25
560/10561/23565/24566/18566/19
572/10576/15576/15576/17577/7579/17
581/9582/21584/9585/3587/7589/15
591/15595/16595/19596/3597/6598/19
599/18601/13604/14607/3609/13613/14
617/2617/21618/14622/11622/14623/21
624/12624/17633/13634/3634/25635/2
635/14636/2637/8638/14639/15641/16
642/2646/19646/24649/24650/15652/12
654/5656/25657/1662/8667/5669/6
672/13673/3674/14684/4688/10689/9
690/8691/15695/19697/5697/7701/9
702/10703/14704/4704/22706/4708/9
709/15709/20710/3711/10712/4712/13
715/4716/5723/2723/2723/5727/8
732/15734/9735/20744/1746/12746/17
746/21747/3747/11748/18749/23751/13
752/18753/16754/14755/24756/3756/7
756/15757/11757/18758/8759/7760/3
760/17
K
K-E-L-L-I [1] 539/7
KARL [17] 477/6544/10549/7552/5
555/9555/13560/17561/20562/23564/5
564/5577/14589/20593/17595/5666/11
762/10
Keanu [3] 485/14609/2612/22
keep [15] 480/12480/15480/17480/17
492/13498/24500/9500/14503/9514/2
535/23651/17659/21675/19745/2
keeping [1] 500/12
Kelley [13] 625/11630/9630/12637/10
641/11643/19645/13646/2647/16647/25
648/10649/15651/2
Kelli [3] 538/22538/24539/6
Kelli Carpenter [1] 538/22
Kelly [1] 478/3
kept [4] 489/9490/8494/18660/25
kick [1] 616/13
kicked [1] 623/2
kid [1] 662/22
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 305 of 324
K
kidding [1] 669/24
kids [1] 495/11
kind [47] 524/22615/19620/16621/3
622/7622/17623/22629/13630/5635/17
638/20652/19672/12676/25678/9688/4
688/8688/13688/21693/10693/11693/20
694/8695/18698/2699/16700/13700/13
701/23702/10703/14706/13706/16707/6
707/14709/12712/3712/4712/5719/14
728/11734/15738/6741/25742/1750/9
758/15
kinds [2] 734/20738/25
king [1] 524/11
knew [3] 493/3564/11688/11
know [125] 481/9482/14484/6485/1
485/1486/1486/25487/2487/3487/3
487/17487/21487/22488/2488/12490/9
491/1492/20493/12494/4494/22535/4
535/4535/6537/11537/16539/25542/18
544/24557/19559/4559/17576/14584/13
585/15587/2594/17595/22598/22598/23
599/2599/6599/21601/11601/13604/20
604/23604/24604/25606/9606/20607/2
607/6607/19617/7619/13620/11623/16
623/19624/12633/24634/2634/5635/1
635/17655/25657/13657/15658/5658/6
659/14659/21659/24659/24660/18
660/25661/5667/23668/2668/11668/12
668/13668/15668/16668/18668/19
668/21672/10687/10688/11688/13
688/14691/25694/17711/10712/1717/3
717/3717/7718/9718/10732/16733/11
733/12733/14733/15733/17742/2742/18
743/20744/15750/24751/5751/19752/22
752/24752/25753/24754/13754/19
754/20756/8756/21757/20760/2
knowingly [10] 532/22547/15554/19
749/20750/9750/23750/24751/3751/7
751/16
knowledge [4] 660/14660/15689/14
692/7
known [35] 477/6484/9485/3493/3
539/22544/10549/7549/12552/5553/19
554/1555/8555/12555/16556/6556/21
557/22560/17561/11563/17563/21
564/17573/23576/25577/14588/15
589/20593/17595/5613/4622/1623/18
675/25688/21762/9
knows [2] 537/11717/2
Kousisis [10] 634/24635/15755/9
755/10755/11755/22756/1756/2756/3
757/24
KREM [5] 678/23680/11680/11683/13
683/14
Kremkov [105] 543/25544/2544/4544/7
544/12545/6546/19546/20548/4549/9
549/12550/24551/4551/7552/8552/9
553/5553/14553/16553/19554/3557/18
557/22560/12560/19561/17561/18562/2
562/6562/11562/20562/25563/5563/10
563/18564/18565/23567/2567/19568/2
568/8568/23569/5569/17569/21573/3
574/10577/1578/12579/10579/15579/17
580/1580/11581/25582/2582/5582/11
583/17584/6584/23584/24586/2587/22
587/25588/10589/7589/16589/18590/23
591/12591/16591/25592/5593/13594/16
595/1595/5612/15642/13648/23672/21
674/11678/7678/10678/19678/23679/22
680/12681/5681/23682/2693/5696/10
696/15697/6697/13715/18720/3720/24
721/14725/23727/20731/9743/1
Kremkov Industries [54] 543/25560/19
561/17562/6562/11562/25563/5563/10
564/18565/23567/2567/19568/8569/5
569/21573/3574/10577/1578/12579/10
579/15579/17580/1580/11581/25582/5
582/11583/17584/23584/24586/2587/22
587/25588/10589/16589/18590/23
591/16591/25593/13594/16595/5681/23
682/2693/5696/10696/15697/13715/18
720/3720/24721/14725/23743/1
Kremkov Industries' [11] 562/2562/20
568/2568/23569/17582/2584/6589/7
592/5595/1727/20
Kremkov's [6] 554/1560/15563/21
568/2591/20591/22
KYC [2] 586/25587/1
L
label [1] 665/3
lack [3] 489/8659/19726/23
Lamborghini [1] 583/7
land [2] 634/4667/16
Lane [8] 664/11664/16664/25665/6
665/8665/23666/12669/13
language [6] 635/20635/22755/9755/13
755/21758/14
laptop [1] 630/15
large [3] 621/7686/9709/17
larger [1] 583/18
last [29] 494/20495/10495/21505/24
505/24532/15535/25536/19539/5556/5
565/1566/6580/24606/17614/15631/2
645/23651/3651/10662/18669/21670/20
678/1678/2679/21714/5727/5740/25
750/8
late [1] 494/20
later [9] 492/20540/12540/14556/15
597/6647/5675/4718/10748/10
latter [1] 577/23
law [20] 478/4489/19501/22532/24
532/24547/17635/15752/12752/14757/7
757/8757/9757/10757/11757/19757/22
758/4758/5758/18761/3
laws [1] 526/3
lay [2] 484/19688/25
league [1] 670/11
lease [3] 668/4668/5668/14
least [11] 489/2489/23490/14490/15
490/16490/17495/4640/24670/4690/14
728/15
Leatherleaf [7] 679/9679/14681/7
681/24682/6682/7684/3
Leatherly [1] 679/13
leave [6] 480/18635/9749/11755/7
755/19755/20
Lee [2] 548/3580/7
left [10] 481/8497/15497/17497/18
540/10590/8590/16706/25747/1748/13
legal [6] 526/6526/12546/18627/16
639/11757/23
legally [2] 488/25554/21
legs [1] 705/9
lender [28] 487/13487/15487/23497/13
502/20502/21503/7503/8503/11503/17
504/4504/24505/7520/9520/12523/8
524/5524/7524/7527/14527/14540/11
542/2558/14558/17574/18574/21600/23
lender's [4] 502/19502/24504/21523/24
lenders [18] 498/15499/4499/11502/17
502/20502/22503/18503/21505/3528/11
528/13537/16537/17541/14541/20542/1
558/4558/10
lending [5] 559/4574/7600/18601/4
604/14
length [1] 538/12
lengthy [1] 574/16
less [7] 496/19500/19520/4520/12
520/16647/6748/16
let [22] 484/16489/8530/3533/5536/24
537/25538/5594/17624/12634/25635/1
651/17655/2673/2683/25686/7739/7
747/5747/17747/20756/7759/17
let's [32] 481/13494/12506/8554/5
562/18566/4567/24568/7568/19568/22
569/17570/7580/21585/20588/22589/24
609/13613/23621/18651/15658/20
659/23668/1668/2683/17705/8724/24
733/18735/3735/8749/5749/13
letter [26] 586/5586/25587/10587/15
587/16588/9593/7593/8593/11594/3
594/11594/12594/15631/6680/19680/22
680/25681/3681/6681/14681/16681/22
681/25682/20682/23709/16
letters [4] 607/13672/10678/1685/5
letting [1] 694/17
level [4] 558/21560/1576/15602/5
liability [5] 686/21686/23694/3694/13
694/25
liable [2] 488/25554/21
lie [3] 486/10486/13491/3
lies [1] 486/12
light [3] 483/19488/11488/13
like [105] 480/16482/25483/20485/6
485/7485/7486/4486/6488/3488/5488/6
488/12489/8490/7490/9490/10490/11
490/22491/2492/7492/7493/20494/7
502/22526/1528/9528/10528/13531/4
531/25533/18537/9543/4543/13574/3
576/18596/24599/16599/23601/2601/18
603/10604/14608/8611/5612/13618/1
618/6618/7619/8622/17624/18628/10
629/15641/3644/1652/23655/22656/1
656/1656/21657/24658/15658/21660/3
660/15670/3671/21672/12676/15686/13
690/2690/8690/13690/25691/21693/14
698/15703/4707/7708/19711/5711/7
711/13732/9733/8733/8740/15741/25
742/22746/24748/4751/24752/18753/1
753/2753/8753/17755/17756/10756/12
756/13756/14756/14758/2
likely [1] 712/14
likes [1] 585/19
limine [1] 481/25
limit [1] 515/10
limits [2] 511/18511/21
line [56] 1/6482/8482/9482/17483/3
489/3492/15509/6509/7530/18530/19
530/24530/25565/13565/16582/6589/15
590/13629/20634/22640/20649/25
677/23683/7684/11684/17684/20684/22
685/3685/9685/11685/12685/15686/19
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 306 of 324
L
line... [22] 687/22697/8699/25700/23
712/10712/10712/25713/1713/4713/13
713/15713/16713/20714/12715/19716/2
721/16733/8736/17736/17736/21748/5
Line 1 [1] 684/11
Line 8 [1] 649/25
lines [4] 579/23593/10664/9712/20
link [6] 542/11542/13618/14618/16
623/3741/24
linked [1] 617/20
links [1] 732/12
liquidate [2] 503/1523/10
liquidity [1] 510/15
list [24] 485/2485/2485/4485/6490/6
490/10548/20605/8605/23608/3608/4
608/6609/14610/9610/12647/10684/3
686/18693/5701/19702/17712/16729/12
742/11
listed [58] 548/1563/17618/20626/9
629/2632/22640/16644/1649/21651/15
651/22661/9674/1674/2676/21677/20
678/24679/13681/6681/16683/23684/10
684/12684/19684/22685/11685/14686/3
687/22690/25691/1691/16693/15694/2
695/6695/21697/6697/8698/19698/20
699/3699/9700/24700/25701/8703/2
703/6706/20712/25713/17713/20715/2
715/3716/2721/2724/10725/9730/2
listen [2] 653/20711/11
listened [1] 587/7
listing [1] 726/25
lists [5] 680/2698/25722/16722/17
725/5
little [34] 481/8499/18499/20503/3
533/18539/15544/8550/7566/13568/7
581/1588/24596/19607/9614/22617/2
617/23624/4630/5632/8634/21637/1
647/6659/19670/1681/11690/25691/15
697/7716/5718/6735/3746/4748/16
live [9] 525/21665/23666/24667/1667/3
668/9669/10669/13741/20
lived [6] 513/14513/15514/6515/2
566/20666/5
living [2] 667/23668/13
LLC [5] 546/19578/12593/13679/22
680/2
LLC's [1] 546/20
loan [243] 484/8485/4487/1487/7
487/13487/24497/24498/14498/16
498/17498/17498/23499/17499/24
499/25500/1501/7502/1502/5502/15
502/16502/25503/10503/14503/14
503/14503/15503/16503/19503/24
503/25504/3504/5504/7504/10504/13
504/13504/17504/20504/25505/2505/4
505/5505/6505/7505/14507/15507/17
507/22507/24508/5508/11509/22510/8
510/11510/17510/23511/19511/25512/3
512/6512/12512/21513/3513/10513/17
513/24514/2514/5514/23515/25516/12
516/25517/2517/5517/18517/21517/23
518/20519/3519/24520/3520/5520/7
520/8520/11520/13520/17520/17520/20
521/24522/17522/20523/6523/8523/9
523/10523/12525/9527/2527/5527/10
527/17527/19528/4528/6528/20528/23
529/5529/5529/6529/7529/10529/12
529/16530/10530/11531/1532/3532/23
533/7534/7534/13536/20537/2537/18
537/19537/20537/21537/22538/2538/7
541/19541/23541/25542/6542/12542/14
543/3543/16543/16543/16543/19544/2
544/4544/6544/6544/14544/17546/21
547/16548/12549/13549/22551/4552/12
552/15553/5553/9553/13553/21554/3
554/6555/6555/8555/10555/12555/14
555/16555/18556/7556/21556/23557/1
557/6557/9557/15557/24558/2558/11
559/5559/16559/21559/23560/6560/9
560/12560/13560/13560/15560/15561/2
561/6561/8561/12563/19563/23564/8
564/12564/19573/8573/25574/13575/18
576/24579/18581/4581/10583/17583/22
583/24590/7591/2591/25592/1593/3
594/16594/18594/24595/7595/13596/17
596/21597/19599/25601/9602/5602/8
605/1605/19607/6609/15611/17611/24
612/4612/4613/2613/6725/3728/18
730/2730/9742/5
loaned [1] 484/9
loaning [1] 522/21
loans [37] 498/1498/7500/2500/3501/4
501/10501/17502/10502/12502/13
505/11522/24522/25524/17526/22
527/12527/13528/14541/3541/22552/17
552/23558/22558/23559/8559/12559/14
559/14583/6583/11583/18598/4602/1
603/22604/9604/11604/15
located [3] 496/15498/5576/18
location [1] 576/17
lodged [1] 585/9
log [4] 618/12657/20657/21657/25
logged [7] 542/9542/10633/1657/15
732/12734/3734/15
logical [2] 668/7668/8
logistics [2] 557/1604/18
logs [2] 573/5617/25
long [14] 497/9498/10498/10527/22
539/22540/3547/18615/1659/8663/11
665/5665/19671/11758/3
longer [3] 710/7718/6741/20
look [65] 482/10485/5485/23487/12
490/3490/5511/8518/3524/14532/15
546/23548/6554/5561/14568/7571/4
592/7597/16598/6609/13610/2610/5
610/25617/16620/12624/3624/5624/12
624/18624/20625/9625/24626/12635/4
635/20637/21642/18646/18649/3649/4
649/4651/24652/2655/6656/15660/24
660/24669/1676/12678/13679/10684/17
687/17692/3698/16698/17708/19711/13
712/2713/23714/3726/5729/25747/8
758/10
looked [31] 485/11485/12485/13490/7
493/21493/23531/4570/17578/14578/17
605/25606/22627/12639/10640/13642/9
643/15646/24667/5669/1673/10685/2
692/18697/5698/18704/4713/10714/5
718/16728/9729/1
looking [45] 485/20490/13490/23497/3
551/24552/24562/5563/4566/6570/10
571/3574/9579/2587/24590/12602/11
607/3610/1621/11626/8627/19628/10
630/5637/8642/21646/6646/7656/18
657/1657/4661/2681/17697/9698/25
699/25703/18716/17721/2723/2728/22
731/18741/1747/14750/21760/5
looks [11] 527/8596/24612/13628/10
629/15656/21676/15693/14709/19
712/10748/3
looped [1] 605/1
lose [3] 604/3604/16612/9
loss [11] 589/14635/11635/11693/11
693/12694/22737/4755/8755/16756/11
757/16
losses [11] 692/24693/12693/14693/20
694/10694/14714/6715/24716/2716/9
716/16
lost [2] 588/8749/2
lot [12] 491/10544/24550/11610/11
623/18625/21637/3655/20685/2708/18
731/17758/12
lottery [1] 703/4
Louis [2] 606/15606/22
Louis Glauser [2] 606/15606/22
love [1] 748/25
lower [2] 549/24694/2
LUCIUS [2] 477/6762/10
lumped [2] 605/1605/15
lunch [10] 572/23633/5634/19636/2
636/3636/15642/10745/24748/21748/21
luxury [1] 555/13
M
ma'am [4] 533/22536/19596/13597/16
machine [1] 762/7
Madam [1] 654/9
made [27] 486/25489/15515/12515/22
527/6537/22543/21560/6574/17594/14
601/8658/24706/17706/18708/6711/9
711/12731/17731/19732/9734/25735/14
742/20753/19753/22758/3760/14
mail [5] 668/17668/25669/1709/14
750/16
mailed [1] 709/3
mailing [1] 709/6
main [3] 696/24706/12739/8
maintain [4] 488/23518/6518/18554/13
major [1] 670/11
make [59] 481/18486/17489/21489/22
491/2493/5493/12500/20503/12510/14
515/7517/16518/6518/18524/17524/22
527/19554/14596/3596/19599/6606/11
616/10619/4620/13632/17632/21634/22
635/5641/22644/24651/18655/23658/17
658/20680/19691/22698/10701/10
705/16707/6711/8711/10711/11711/22
711/25732/14732/17735/2738/19738/22
741/20742/2747/10753/12756/23757/23
757/24758/16
maker [1] 493/2
makes [10] 484/10510/11515/17515/18
557/6615/11655/15732/11733/5753/4
making [14] 508/24511/15532/22
547/15619/15620/21659/3690/21707/6
733/23741/23747/7747/12753/17
manage [4] 540/15540/18615/12667/6
managed [2] 541/1617/15
manager [3] 540/12540/13667/21
managerial [1] 541/5
manages [1] 618/4
mandate [2] 500/18501/12
manual [1] 618/3
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 307 of 324
M
manually [2] 617/13660/10
many [17] 494/4494/6511/3533/10
568/8569/5569/21603/22653/5653/8
660/12668/23687/12733/2734/5734/20
752/13
March [7] 501/16502/2534/9534/14
567/5567/11727/4
March 2020 [2] 501/16534/9
March 31st [1] 727/4
Marietta [1] 677/12
mark [1] 585/21
marked [7] 533/14544/19597/1643/10
747/16747/22747/23
master [1] 732/4
match [3] 687/8742/13742/13
matched [2] 730/8730/8
matches [1] 625/16
material [18] 484/4484/5484/8484/10
484/20484/24485/23485/25486/1486/2
487/6487/19488/10488/13491/5492/24
532/20547/15
material -- it [1] 485/25
materiality [6] 483/10483/12489/4489/6
489/15490/25
materially [1] 487/1
math [4] 553/2581/10595/3595/4
matter [3] 493/2548/10762/8
matters [1] 634/2
maximum [2] 549/21553/11
may [43] 1/21/5480/12486/19491/12
491/12495/24533/3535/15545/21554/20
568/5572/6581/1585/16586/23590/17
591/15602/4613/9613/10623/9624/7
624/8631/16633/24637/2662/20668/16
670/23675/12675/12681/1686/25688/6
688/7712/1712/13718/11728/20730/5
730/11740/23
May 7th [7] 585/16586/23590/17591/15
681/1728/20730/11
maybe [31] 488/3488/4490/5493/13
526/1527/24535/11556/15571/16575/11
602/14619/10622/10622/13623/3623/5
651/3653/6662/23688/14706/8706/9
711/6715/5748/20750/25756/5756/15
757/5758/20759/12
me [51] 482/11485/18493/21518/1
524/11528/17530/3533/5533/21534/21
535/9537/25540/6541/10554/20572/21
601/25624/12624/18625/23634/20
634/25635/1635/21643/20646/3647/17
649/16651/16651/17651/19655/2655/21
661/7662/23673/3683/25686/7700/10
739/7745/21747/6747/17747/20753/25
756/3756/7759/17760/14760/16762/12
mean [63] 480/16482/12485/6486/6
487/3487/12487/17488/2488/11488/15
489/18490/7490/11492/5492/6493/7
503/4505/6509/25511/25526/4528/8
550/1556/14566/10566/15581/14584/9
592/25619/24627/1628/9634/8647/8
650/12652/16655/25659/14675/1690/22
700/4701/9704/10704/10708/24710/14
712/4719/1731/20733/20734/1744/3
748/3748/24749/9749/9749/21750/4
750/21751/5754/15756/14758/22
meaning [3] 519/7621/13660/17
means [10] 519/8523/1525/18527/5
552/14647/9653/24708/2732/11752/22
meant [2] 510/1630/1
measure [1] 686/9
measurement [1] 549/25
mechanical [1] 477/18
meet [3] 505/14514/11543/22
meeting [2] 620/4620/21
meets [4] 487/21511/12511/16549/18
member [6] 595/23678/20679/22681/5
681/23682/3
mens [2] 752/12753/15
mental [1] 753/14
mention [2] 481/10548/3
mentioned [35] 497/15498/21499/13
499/13500/12501/9526/22541/5543/19
559/11560/5563/25565/20573/16599/13
602/13604/25613/13618/6619/6619/17
620/14623/14623/21638/23639/21
640/23658/15660/1660/3661/8661/17
701/6707/5708/9
mentoring [1] 496/9
message [16] 629/12629/16629/18
629/19629/20630/1630/6640/20641/7
644/25647/8650/24658/19699/23720/12
720/15
met [6] 505/8526/11526/25527/9527/14
528/18
method [1] 632/24
MICHAEL [3] 477/11548/3580/7
microphone [1] 539/15
mid [1] 571/16
mid-morning [1] 571/16
middle [12] 495/22512/9547/23547/24
547/25548/15548/15551/24579/23
707/15726/24736/14
might [12] 480/19481/9533/18613/13
623/5630/14642/18746/25748/21752/22
753/8754/13
million [51] 511/22511/23512/1512/1
512/2512/4516/25553/4553/23553/24
557/8560/20568/12568/14568/17569/9
569/12569/25570/24581/14581/16583/1
583/17584/2584/16584/19594/22595/3
595/6599/16599/19599/21599/25601/14
601/23612/4670/11693/17694/6694/15
694/19694/19694/20695/5695/19713/5
713/12716/6716/12716/15743/9
mind [5] 480/12505/16535/23572/9
636/4
mindful [1] 494/23
mine [1] 659/14
Minimally [1] 577/22
mining [1] 501/6
minor [1] 578/1
minus [3] 595/3684/19684/22
minute [6] 533/23585/20595/19636/6
705/8746/5
minutes [11] 571/16571/16572/1572/10
603/2603/2613/14613/18647/6705/10
748/15
MISC [1] 509/21
miscellaneous [1] 549/1
misinformation [1] 523/23
misled [2] 486/4486/7
misrepresentations [1] 489/14
missing [2] 602/16616/14
mistake [4] 489/8708/6711/5711/12
MLB [2] 477/4762/10
modified [2] 499/25751/9
moment [2] 595/16740/23
moments [1] 619/17
Monday [2] 480/8749/3
money [74] 482/11482/13484/8484/10
491/8503/15511/18512/6513/22522/20
522/21523/7524/11524/17524/20529/19
531/18541/25542/3556/14562/9562/15
563/8563/14581/3582/21592/22592/25
593/1593/2595/11599/14599/24600/2
600/6600/9600/9600/12600/13600/25
603/10604/3604/16608/1611/7612/7
612/9635/7686/2686/25687/14687/15
694/15695/2695/3707/19709/25710/3
710/4731/24732/20732/24733/2733/20
733/22734/9734/24737/25738/2738/4
740/2740/11740/15755/5
Monica [1] 490/8
monies [1] 499/5
monitor [1] 582/17
monitoring [1] 621/3
month [4] 677/21702/8721/13723/19
month's [1] 598/7
monthly [25] 512/11512/13512/16
513/23514/10514/15514/19515/8515/14
515/19516/1516/17543/5551/20551/21
551/25552/8552/16553/11553/20554/1
560/19562/3571/4571/5
months [10] 527/24528/1528/2537/21
540/10540/12540/17567/3569/1672/10
more [37] 480/24489/21500/1502/12
515/22516/18520/4520/7520/12520/14
533/18541/12541/17549/20550/3550/11
559/11560/3566/19571/5581/1603/6
618/7634/22640/9641/6681/11686/22
705/6709/20711/25722/13727/3728/24
749/23751/24756/10
morning [12] 494/19496/2496/3522/4
522/5539/11539/12571/16650/9745/11
748/10748/25
mortgage [5] 517/25517/25518/6554/8
554/14
Moses [1] 608/25
most [8] 490/6621/23622/16687/9
688/19699/10700/7732/4
mostly [4] 638/24641/15649/24712/14
motion [1] 481/25
move [10] 506/25545/11562/18597/9
617/1625/2673/1674/18703/14746/25
moved [5] 540/14540/17671/20672/3
747/4
movement [1] 582/21
moving [3] 536/2729/8745/2
Mr [27] 573/12635/23666/18671/3671/8
672/17673/9675/19680/22681/13681/20
683/7683/19684/9685/2686/5692/18
695/11701/16710/21716/4720/21721/12
726/5730/23741/16756/8
Mr. [41] 490/13526/10556/25561/6
564/19573/4573/12576/25576/25585/25
585/25586/18588/15588/15589/2593/24
595/10598/22598/23598/23599/11602/9
602/23603/9614/21615/9624/3624/10
625/9625/24630/21637/8637/13641/14
646/5652/12654/5663/4697/5731/10
734/21
Mr. Davis [13] 614/21615/9624/3624/10
625/9625/24630/21637/8637/13641/14
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 308 of 324
M
Mr. Davis... [3] 646/5652/12654/5
Mr. Delano [15] 556/25561/6564/19
573/4573/12576/25585/25586/18588/15
589/2595/10598/23598/23599/11731/10
Mr. Delano's [2] 526/10593/24
Mr. Evert [1] 490/13
Mr. Hazel [1] 697/5
Mr. Horner [1] 663/4
Mr. Torjagbo [8] 576/25585/25588/15
598/22602/9602/23603/9734/21
Ms [6] 496/2522/4536/5536/5536/7
648/10
Ms. [19] 539/11625/11630/9630/12
630/17631/25636/11637/10641/11
643/19645/13645/20646/2647/16647/25
648/18649/15651/2705/21
Ms. Carpenter [1] 539/11
Ms. Connors [1] 705/21
Ms. Hendrix [1] 636/11
Ms. Kelley [12] 625/11630/9630/12
637/10641/11643/19645/13646/2647/16
647/25649/15651/2
Ms. Wilson [4] 630/17631/25645/20
648/18
much [28] 482/23487/17491/8515/6
515/12515/13538/15554/3562/5562/11
563/4563/10567/19569/11602/4613/11
613/21629/15633/7647/5662/5669/20
671/21686/21745/12748/24756/24
757/16
multiple [10] 501/17534/8549/23555/2
559/4660/8673/11673/13732/17742/23
multiples [1] 731/12
must [5] 509/7509/8532/4548/18754/8
my [46] 481/10484/15487/15494/24
495/11496/23506/23534/17535/2535/11
539/6572/8577/7595/3602/23602/23
609/6615/12633/7634/3634/20637/10
651/15651/17654/21662/1662/8669/4
669/23671/15672/15686/3689/14691/6
704/12728/24731/9745/8746/12757/3
757/25758/15759/3759/17761/3761/4
myself [3] 541/2601/11698/15
N
NAICS [1] 496/21
naive [1] 483/1
name [73] 486/15489/24489/24490/6
495/21536/6539/5539/6543/4546/18
547/1547/9564/24566/6566/6579/22
579/22580/1587/24606/17614/15617/21
627/16631/7639/11642/10662/18664/5
664/7666/11666/12668/5670/20670/23
677/15677/16677/18677/20677/23
677/24678/2678/3678/4678/7678/10
678/17678/18678/19678/21678/22
678/23679/13679/20679/21679/24
679/25680/2680/7680/9680/11682/1
683/13683/14684/1691/25693/5697/10
697/12702/16710/22722/16727/25732/5
named [5] 544/9548/3580/7611/4666/8
names [17] 484/3484/4489/23490/3
490/4490/7493/24561/24561/24579/25
580/2605/23608/6609/18610/9610/11
610/25
Nancy [1] 608/18
narrower [1] 535/24
national [3] 504/14520/18540/15
natural [1] 492/25
nature [2] 489/14738/16
near [1] 544/21
nearly [1] 595/6
necessarily [1] 688/24
necessary [8] 503/2510/12510/18557/7
557/9753/12755/17760/3
need [21] 480/10483/14483/15501/14
509/1520/4533/21570/23572/7580/19
581/1613/13651/24671/5687/10749/7
751/22759/10759/15760/8761/7
needed [4] 509/11586/1619/11759/7
needing [1] 589/4
needs [7] 691/1691/1711/8711/9732/12
734/18758/17
negative [17] 565/15565/18565/20
565/22684/17684/21713/2713/2737/2
737/6737/21737/21740/25743/8743/13
743/13743/15
negatives [2] 741/3741/8
neither [1] 729/17
net [4] 635/10755/8755/16756/11
network [2] 628/21628/21
never [8] 485/23489/10493/21531/11
607/14667/17733/11758/9
new [16] 480/8519/14519/18519/22
521/11529/19556/22559/21600/5600/15
601/2665/17665/19666/7668/22668/23
Newton [2] 608/10750/13
next [36] 495/6509/9538/21542/14
547/4547/19548/19549/3550/12551/21
552/11554/5554/22562/5562/11562/18
563/4563/10566/10568/3568/23569/18
577/7598/6609/20609/22609/24613/12
614/5637/14650/9662/7663/20670/7
736/21747/1
nice [1] 538/17
Nicholas [1] 478/3
Nick [1] 611/4
night [4] 494/20495/10669/21718/10
no [222] 1/13477/4488/8490/7491/3
491/15494/3494/11498/9500/16501/5
501/8505/12506/2506/3507/2509/18
510/5510/9510/20510/24513/2513/12
513/25514/16514/20514/24515/5517/1
517/17517/19518/23518/25519/2519/6
519/15519/17519/19521/1521/5521/9
521/13521/17521/25522/1523/8523/14
524/21526/4529/15529/18529/20529/22
530/9530/16531/3531/9531/12531/13
533/2533/3533/8543/23545/16548/5
548/24549/15549/20550/3551/3551/5
551/15553/15553/17553/22555/11
555/15555/19556/24557/3557/17557/25
558/16558/20560/11560/14560/16561/4
561/13563/20563/24564/13564/20
566/22571/24572/18574/1575/18575/20
577/2578/6580/3580/6580/9582/25
591/10591/23592/2593/19595/8595/14
595/15597/12599/10599/22601/7601/13
601/20602/18602/19604/6605/20609/19
609/21609/23609/25611/2611/6612/8
612/17613/7613/8617/23620/11625/5
634/5640/25644/9646/14647/8650/24
654/8655/1655/4655/10656/3656/14
657/15657/15659/5659/25660/21661/3
661/6662/22665/1665/3665/25666/10
666/14666/15666/21667/4667/6667/14
667/22667/24669/2669/14669/18669/24
671/7671/7671/7672/10673/5674/20
680/20682/4682/8685/24691/16694/16
694/25695/3696/7704/12708/5710/7
710/8710/8710/11715/3719/1719/3
719/3719/3719/18719/20721/7723/10
723/23725/21727/2727/6731/13736/24
736/24739/5741/20743/10745/7746/20
750/16756/20757/7759/6759/6759/6
759/11759/23761/8
No, [4] 662/3744/19749/8760/17
No, Your Honor [4] 662/3744/19749/8
760/17
nobody [4] 507/11585/19656/12666/5
non [18] 498/7518/22518/24520/24
557/15558/23559/12559/21560/13
560/13693/12693/12693/14694/10714/6
715/23716/2716/8
non-business [1] 520/24
non-passive [8] 693/12693/12693/14
694/10714/6715/23716/2716/8
non-PPP loan [3] 559/21560/13560/13
non-PPP loans [2] 558/23559/12
non-U.S [2] 518/22518/24
non-U.S. operations [1] 557/15
non-United States [1] 498/7
nonetheless [1] 670/2
nonpassive [1] 693/20
normal [6] 499/16503/25504/3518/14
582/21660/25
normalized [1] 576/4
normally [1] 749/1
NORTHERN [2] 477/1762/5
not [248] 480/23481/1482/9482/16
483/1483/4483/9483/19483/21484/21
484/24485/4485/20485/25486/5486/12
486/13487/4488/8488/8488/10488/13
490/9490/10490/22493/14493/20494/5
495/1497/3499/17499/25502/21504/11
507/10509/16510/2510/6510/15510/17
510/22513/4514/1514/4514/11514/11
514/25519/20520/23521/2521/6521/10
521/14521/22522/20523/13523/20524/6
524/13524/14525/15525/16525/19526/8
526/9526/20528/16528/17531/22532/2
532/3532/8534/6534/24534/24535/2
535/3535/6535/7535/7535/24536/1
536/11537/23548/22549/12550/21
553/19555/21555/22556/13557/18
557/22558/24559/2559/5559/14559/18
563/18563/22564/11576/14583/5583/11
583/16593/3594/14595/12595/14599/10
599/12600/9600/14601/10602/4606/23
607/8607/16611/20613/18613/25618/11
618/14620/10622/1631/16632/11634/9
635/8637/2638/9641/1644/24649/19
656/3656/3656/6657/4657/8658/5658/9
658/10659/2659/5659/6659/9659/21
659/23661/14665/1665/3665/25666/20
667/13667/14667/20668/1668/6668/10
668/14668/16668/19669/15670/3670/4
674/24675/12676/7678/8678/12679/6
679/11679/12681/25682/4682/8682/9
682/17683/16686/3689/2690/7691/6
691/19695/11696/5696/11697/12697/14
699/6700/5704/19705/1708/4708/5
710/15715/4716/22716/23716/24718/11
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 309 of 324
N
not... [47] 718/11718/24720/2720/4
720/13720/14723/23726/3726/17729/11
733/17734/4734/9738/19738/21742/10
744/3746/23747/16749/18750/2750/18
750/19751/15751/19751/25751/25752/3
752/4752/18753/12753/19754/10754/10
754/11755/6755/17756/17756/19756/20
756/20757/3757/7757/11757/11757/16
760/4
note [2] 1/12607/23
noted [1] 627/12
nothing [10] 480/10485/25528/25
611/19659/2686/1696/5717/6731/12
741/11
notice [8] 587/20587/21588/2598/19
634/6659/3682/13709/12
notices [1] 528/4
notification [2] 632/23633/1
notified [1] 624/1
notifying [1] 594/15
noting [1] 629/20
notion [2] 482/25749/24
notorious [2] 482/19482/24
November [2] 569/22762/14
now [172] 480/10480/17490/8490/24
500/12518/10544/10548/6548/10549/7
552/5563/25565/9568/19568/22575/21
593/17594/18594/22599/21600/8603/19
607/14615/6615/9617/1617/19620/14
621/1621/10622/21625/16626/2626/6
626/12627/3627/19628/17630/24632/10
632/15632/19634/8637/13637/15638/1
638/23639/10639/17639/21639/25640/9
640/19641/11642/9642/15642/21643/5
643/15643/22644/1644/4644/7644/11
644/15644/15645/7646/5646/6646/10
646/18647/2647/7647/21648/10648/22
649/23650/4650/12652/9654/18656/25
658/6658/7667/15671/21672/15673/18
675/9676/3676/8677/14678/6678/21
678/25679/19680/25681/3682/23684/13
685/9685/15685/18686/5687/2687/17
688/1688/4688/20689/8689/22690/19
691/19693/1693/7693/10693/16693/20
694/19694/19695/11695/15696/2696/9
697/15697/21698/21698/25699/3699/7
699/22702/13703/17703/22704/4704/15
705/25706/3707/5707/14708/1709/11
710/10710/24711/2711/5711/14712/22
713/10714/2715/16715/21716/20718/2
718/16722/24725/17728/11728/22
729/15729/19729/25735/1738/12742/4
742/20743/8747/25748/15750/8751/10
751/13
nowhere [1] 752/20
number [178] 1/61/6504/7505/22
505/23505/25506/7506/7510/25512/22
514/3525/10543/5549/21550/13551/16
551/21552/7552/25553/4553/8553/24
563/25565/2565/22565/22566/2566/9
566/13566/14567/8567/9567/13568/7
570/10570/15570/20570/21570/24
570/25573/4574/16575/1587/19588/6
588/10589/17590/17590/23590/24
594/22596/18597/4626/9626/16627/22
627/23629/6630/25631/2637/9637/17
639/22639/24641/9642/3642/15642/16
642/25644/2645/18646/8647/2648/3
648/15651/15651/17651/22652/10
661/13661/18661/19664/24667/11
671/17671/17673/19673/25674/1674/2
675/13675/22675/24675/25675/25676/1
676/7681/14681/15683/22683/23684/18
684/18684/19684/21684/22685/10
685/11685/22686/4690/4690/4691/2
693/2693/8693/23696/3697/22700/2
701/3701/10701/21702/3703/2703/19
703/21704/6706/4706/25707/3710/25
711/12711/15711/18711/20712/12
712/15713/2713/23714/1714/10716/1
716/13717/10718/19718/21718/24
719/18719/21720/12722/17722/18
722/19726/25729/10730/6730/12731/1
731/4732/5732/12732/15734/18735/19
735/19735/20737/6737/21739/15741/25
742/18742/19743/8743/11743/24743/25
751/10762/10
Number 0540 [1] 645/18
Number 1 [2] 567/8568/7
Number 150 [1] 505/25
Number 2 [1] 567/13
Number 28 [1] 565/22
Number 3 [1] 570/10
Number 4 [2] 566/9566/13
Number 6010 [2] 637/9648/3
Number 7 [1] 512/22
number 86-134-7540 [1] 590/24
numbered [1] 712/20
numbers [20] 565/20591/8629/16661/9
674/9674/10675/20687/8694/2708/19
711/22717/9717/9734/21739/7743/16
743/18744/1747/7747/9
numerous [1] 535/15
nurse [1] 480/8
O
object [8] 492/5492/6492/8533/16534/5
716/25756/13756/21
objecting [1] 492/10
objection [26] 507/2529/24530/5
530/20531/5536/23537/4538/4538/8
545/16555/20555/20556/6597/11597/12
598/25625/4625/5635/24673/4673/5
674/20675/9716/25744/11755/13
objections [1] 492/2
objects [1] 751/19
obligation [2] 506/14524/5
obscure [1] 754/21
obtain [5] 532/23547/16635/7676/3
755/5
obtained [2] 640/1689/1
obtaining [1] 504/3
obvious [2] 483/6489/14
obviously [6] 486/11580/1632/25668/4
731/6758/17
occasions [1] 758/19
occupancy [1] 665/22
occur [1] 709/6
occurred [3] 555/24555/25611/13
October [2] 569/22671/13
off [16] 493/7582/1584/3584/13604/9
620/25635/10678/22698/19710/8740/21
755/7755/20756/4756/25757/1
offense [4] 751/6751/23752/3753/15
offeree [1] 579/21
offering [1] 688/12
office [9] 478/2478/4497/14519/9519/9
519/11519/12656/7736/10
officer [3] 480/7540/8606/16
officer's [1] 488/17
officers [2] 541/1541/10
offices [2] 668/22762/6
official [11] 1/11/21/31/71/14477/21
691/19704/8704/10762/4762/19
offset [6] 694/9694/19694/21695/4
716/9716/16
offsets [3] 694/14709/25740/11
often [2] 559/4622/12
oh [38] 481/22492/7499/19505/22506/3
507/11507/12533/8538/14545/18550/25
552/21572/18575/11612/18625/14
625/19630/12630/16638/8644/9650/21
651/14651/19653/15654/14659/16
660/19667/8669/24671/5691/10719/5
746/1746/4759/6760/24761/5
Ohio [1] 653/10
okay [442]
old [8] 535/15659/19667/18668/16
668/17690/3740/19754/14
old-school [1] 690/3
older [1] 665/14
Oliver [3] 485/13485/22608/12
Oliver Twist [1] 485/22
omitted [1] 747/3
once [7] 484/18615/23620/14621/1
639/3733/5734/4
one [164] 481/20489/2490/9490/21
491/3491/15492/19500/2501/12505/22
505/23506/7506/23509/10515/17523/17
530/10530/15532/11536/9536/19548/19
549/25551/12555/3557/4557/4557/4
559/23561/23565/16566/14566/19570/9
572/6572/7577/16577/23577/24578/17
578/22583/18586/4590/6590/6590/8
590/8592/10595/16598/6600/5602/13
606/20607/1608/15608/19608/21608/23
609/1609/3609/5610/25615/16616/23
616/25621/23622/13624/4625/15627/19
629/11632/1633/5634/21637/15638/1
638/2639/14639/15640/18640/24643/5
646/13647/7650/23651/12653/10653/10
655/8661/12661/12661/18669/6671/19
671/22676/13676/25677/25680/19
682/10689/20690/6692/19693/2693/8
696/15697/10698/12698/22699/1701/20
702/5711/3711/6711/7711/19715/18
716/8717/10717/10719/5720/14721/1
721/1727/14727/15729/9729/11729/17
729/19729/20730/1739/10739/10739/15
739/21739/22739/24739/25740/2740/23
740/25742/6742/25743/3744/7745/17
745/25748/13749/4749/13749/19750/15
751/14751/15754/24755/3756/5756/5
756/6758/13760/14760/16761/3
onerous [3] 520/12520/12520/14
ones [9] 481/5639/23640/14652/10
652/13699/23721/2728/13729/1
ongoing [6] 510/12510/16510/18557/7
557/10582/17
online [2] 535/17701/8
only [26] 1/21/7489/9493/4534/17
534/17551/12576/24592/10593/16
646/13676/22678/25690/16695/8702/8
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 310 of 324
O
only... [10] 711/3711/19717/10730/15
745/25749/19755/15757/15758/15759/3
Ooh [1] 757/2
open [6] 480/3482/19482/24489/14
544/21762/8
opened [6] 579/11579/15580/11601/3
666/7666/13
opening [2] 482/8482/15
operate [1] 663/10
operated [1] 515/3
operating [3] 510/2510/2514/22
operation [24] 508/5508/7508/10509/2
509/13509/15509/25510/4510/7510/15
519/21526/15526/18548/13548/21
549/10549/13554/9554/15574/21584/25
591/17612/15634/10
operations [16] 510/12510/16510/17
510/18510/22518/7518/24557/7557/10
557/15557/18557/23573/17615/4615/5
667/25
OPM [1] 506/24
opportunities [1] 501/17
opportunity [10] 481/11624/20625/24
685/21695/13699/19713/22720/5721/4
726/5
oppose [1] 758/1
opposed [2] 516/1635/21
opposition [1] 755/3
opt [1] 607/25
opted [1] 607/25
option [2] 603/20671/22
options [1] 751/14
order [13] 489/15508/5508/11515/7
517/18520/3520/11549/22559/21561/6
588/19747/1747/2
Oregon [1] 653/10
organization [4] 500/22500/23500/25
540/25
original [2] 604/21694/18
originally [4] 501/15527/24528/1
720/13
originate [1] 503/1
originated [1] 522/18
origination [1] 543/4
originations [1] 607/8
other [69] 481/5488/24495/13513/15
518/19532/5537/18537/22545/20560/15
561/20565/13565/14567/14569/8569/24
571/8575/1579/25580/2580/4582/14
592/7600/5605/12610/11620/3621/24
621/24626/15628/15629/17632/24633/8
633/9638/2640/14654/24667/6668/9
671/25672/20677/14685/13691/13692/5
692/24696/22707/10713/19714/14
718/19727/13731/9731/10738/25739/25
740/5740/16742/21749/13750/1752/15
753/9754/21756/6758/11759/3759/17
others [2] 617/9758/11
Otherwise [1] 754/13
ought [4] 535/6535/7536/2749/11
our [32] 484/8497/5497/7499/16537/19
540/15540/15540/17560/2571/15572/7
572/23574/7593/14593/22604/14605/20
606/1622/4622/10622/12622/13622/13
653/1655/1665/3667/24747/23748/23
750/15755/15755/24
out [95] 484/19485/7490/21491/8
492/19493/4493/10499/5500/1500/4
500/19507/15512/8520/19522/21525/3
527/24533/17533/21533/22534/3538/1
541/16542/3546/11548/6550/25559/2
572/10581/17581/19583/25584/18
595/16596/1598/20607/6607/13611/7
612/9613/15615/11616/6617/8619/7
620/7631/25634/11635/4636/7636/7
667/24672/11679/16682/20683/25684/6
685/7687/12688/12689/5690/6694/16
703/8704/16707/17707/23708/7709/11
709/12709/16710/7712/11712/19714/24
716/21717/7719/14722/24727/9729/11
735/11739/10739/11739/21739/24
743/14747/13747/16747/22749/9750/13
750/15755/23760/4
outlines [1] 593/23
outlook.com [1] 628/11
outrageous [1] 491/15
outreach [1] 607/16
outside [1] 550/20
outstanding [1] 594/24
over [56] 497/24527/13527/25538/11
544/8552/11562/5562/11563/4563/10
577/19595/25627/13629/9636/2636/3
637/15637/21638/14639/10640/9640/9
644/9644/15644/23648/4649/19650/15
652/16655/9657/2665/2671/19671/21
681/10690/2693/17693/23694/6695/5
706/5707/1712/10716/6716/12716/18
719/11721/7722/13733/3743/10743/17
743/18744/1744/25748/19
overall [1] 714/2
overnight [1] 480/21
overrule [1] 530/5
Overruled [3] 531/4599/1744/14
owe [3] 686/25692/2707/19
owed [10] 687/14708/3709/25710/3
710/16710/16710/17737/8740/11740/15
own [8] 600/9600/13618/12659/16
659/18663/10701/10734/10
owned [2] 665/5667/16
owner [5] 515/2544/11544/11548/1
619/9
ownership [3] 546/6547/24548/4
P
p.m [5] 627/5637/24644/13646/20
761/15
page [135] 1/6479/2490/17500/2505/23
505/24508/17508/17510/10511/8512/22
518/3532/14546/5546/17546/23546/24
547/23547/23548/14548/15549/16550/6
550/13551/25554/5554/11561/14561/21
562/18562/24563/25564/21565/19566/4
566/18566/23567/22567/24568/19
568/22569/14569/17570/5570/7570/16
570/18571/3574/15575/10575/11577/11
577/11578/11578/25579/11579/20
579/23580/10580/21580/25581/13
581/22589/13590/1590/11590/12592/3
593/5594/2594/10596/9596/10597/25
598/11609/9609/18609/20609/22609/24
610/5630/17632/1642/5642/19643/2
645/21648/19649/6649/9651/15651/16
651/17651/19651/21652/5663/18663/18
664/1683/5684/23692/14692/19692/21
693/16694/6695/12695/23700/10703/9
703/14707/15713/7714/9715/13715/17
717/11717/15719/5721/9723/2723/5
723/15723/24724/8724/21724/25725/7
725/12726/11736/15746/24747/8751/7
755/4
Page 1 [7] 511/8512/22546/17547/23
549/16571/3579/11
Page 10 [3] 561/14580/21721/9
Page 105 [1] 596/10
Page 11 [2] 578/25692/14
Page 122 [4] 562/24570/16570/18724/8
Page 123 [1] 563/25
Page 125 [1] 564/21
Page 126 [1] 724/21
Page 129 [2] 590/11725/7
Page 13 [2] 581/13695/23
Page 132 [1] 566/4
Page 14 [5] 581/22642/5645/21651/19
651/21
Page 141 [3] 566/18566/23725/12
Page 142 [1] 567/22
Page 143 [1] 567/24
Page 145 [1] 568/19
Page 146 [1] 568/22
Page 149 [1] 569/17
Page 15 [2] 592/3715/13
Page 151 [1] 570/5
Page 152 [1] 570/7
Page 17 [2] 651/16719/5
Page 2 [18] 508/17510/10518/3532/14
546/23548/14554/11574/15575/11
577/11579/20663/18684/23692/19
692/21694/6713/7715/17
Page 20 [2] 632/1649/9
Page 21 [1] 747/8
Page 25 [4] 630/17648/19652/5717/11
Page 3 [6] 575/10580/10593/5594/2
594/10703/14
Page 48 [1] 755/4
Page 5 [1] 589/13
Page 80 [3] 561/21610/5723/15
Page 81 [3] 562/18609/9723/24
Page 9 [1] 643/2
pages [5] 546/4546/4609/13610/1610/6
paid [63] 500/9500/13500/15500/21
509/19509/20513/22514/3514/18548/25
548/25558/18558/19563/1581/13582/11
583/25601/8611/4611/5685/20685/23
685/25686/2686/10686/14686/20686/25
689/3690/24690/25691/2691/17694/18
694/23695/2695/3695/8696/16702/18
703/22707/17708/1708/16710/12713/24
715/2715/3715/4716/21721/6721/7
722/13722/19722/21724/11724/17
729/11734/24739/10740/2742/10743/14
pandemic [8] 498/23498/25500/19
508/15522/17543/12559/6610/18
paper [2] 690/3733/4
paperwork [1] 531/24
paragraph [6] 547/10547/19574/16
594/4683/8683/12
paragraphs [1] 547/9
paralegal [5] 641/12645/14647/17
648/11654/11
paralegals [1] 630/10
parent [1] 691/20
parentheses [1] 692/5
part [58] 484/12486/25488/4491/13
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 311 of 324
P
part... [54] 493/23500/10501/11501/21
511/6513/1528/9540/13540/19540/25
540/25542/16542/25542/25543/3546/15
548/15555/2559/18560/2575/2582/21
589/21605/6605/13605/17605/20605/25
607/18607/23616/1618/25620/18620/20
620/20627/25629/15630/18640/1654/23
684/6693/10701/24714/25717/25728/9
748/18750/24754/10754/10754/11
754/24755/15758/20
partial [2] 1/9480/24
particular [10] 481/4587/21615/10
673/10692/19694/4702/19714/9717/6
758/20
particularly [1] 660/3
parties [2] 653/16653/19
partners [1] 497/8
partnership [1] 589/14
parts [1] 480/22
party [1] 618/7
passed [1] 501/22
passes [1] 616/15
passive [10] 693/11693/12693/12
693/14693/20694/10714/6715/23716/2
716/8
password [1] 657/24
passwords [1] 657/18
pasted [2] 656/13656/13
pattern [7] 492/23750/6750/11750/22
751/21753/16760/18
pay [34] 514/9515/13523/6557/8562/3
563/6568/11568/11569/8569/24570/3
570/15582/14583/1594/18595/6595/10
595/10603/15603/25604/6604/9610/20
670/3670/11722/5723/3723/12733/22
739/11739/21739/24740/18740/21
paycheck [7] 498/16498/21506/14
540/21554/17686/13720/21
paying [2] 629/7686/16
payment [26] 530/1530/8555/17556/7
559/10570/13583/7583/12594/14598/1
598/12598/14598/17599/6688/16689/2
732/11732/15733/7733/23740/6741/17
741/23741/24742/2742/19
payments [28] 513/9514/14515/7518/6
518/19527/19528/3537/21554/14570/12
587/19598/3671/24688/5688/9706/18
707/8709/21731/17731/18732/9732/18
734/4734/7734/10734/25741/20742/15
payor [2] 702/13732/13
payroll [73] 488/23509/20512/7512/11
512/13512/17512/24513/16513/23
514/10514/15514/19515/8515/15515/20
516/2516/17517/6517/25518/6518/18
532/4543/5543/10548/25550/6550/6
550/9550/16551/8551/20551/22551/25
552/8552/16553/11553/20554/1554/8
554/14560/19560/25561/16562/20
563/17570/16571/4571/5573/4575/15
582/7582/8582/10582/11582/14582/23
602/14602/17605/5605/6605/15605/21
606/11608/4610/2610/6612/17612/18
613/1618/2721/12723/2724/3
PDF [1] 1/1
pecuniary [4] 635/10755/8755/16
756/11
pen [2] 690/10747/11
penalties [2] 689/12710/8
penalty [3] 689/18714/17736/24
people [19] 490/7491/9492/7492/11
537/14563/17603/22610/25659/8668/4
668/9687/10687/12688/11733/20733/21
733/21734/6741/20
per [8] 616/11655/4661/5686/3691/16
704/12711/19737/7
percent [15] 504/17505/4524/23526/3
526/4528/20528/22541/22548/1601/8
601/12601/14601/14601/18601/23
percentage [2] 524/22601/11
perfect [4] 547/25590/1659/23659/25
perhaps [2] 728/24742/21
period [11] 1/4501/25502/4502/6502/6
527/20626/25702/7709/5735/22736/2
periods [1] 728/4
perjury [3] 689/12689/18714/18
permanently [2] 509/16548/22
person [29] 490/9513/13513/14513/14
513/20514/8525/4527/2527/16530/10
530/14544/16565/4577/11580/10603/1
606/9606/13606/23606/25657/20664/3
664/5689/17690/16715/6733/8733/9
733/16
person's [4] 492/25514/9530/17530/23
personal [17] 499/6519/1519/4519/16
521/3521/7529/17529/21540/21555/9
560/25564/22573/5580/16589/10605/16
690/4
personally [4] 528/16528/17541/3
541/4
Philadelphia [1] 497/13
phone [10] 602/20603/1627/22627/22
639/22639/24658/3671/19671/21672/11
pick [2] 655/18690/6
piece [2] 488/19696/25
pieces [1] 617/17
Piedmont [1] 736/10
pin [5] 619/22690/4701/6701/7701/8
pink [1] 699/17
pivoted [1] 601/4
place [21] 512/18512/23513/6513/7
514/12525/12525/23525/25550/15551/6
575/13649/11665/24669/25672/7706/13
706/14706/19706/20722/2758/25
Plaintiff [2] 477/4478/2
plan [3] 521/14527/20535/4
planning [4] 520/23521/2521/6521/10
platform [1] 574/7
play [2] 585/2585/17
played [3] 585/18585/22602/21
player [1] 670/10
playing [3] 491/23492/13748/14
please [76] 495/21505/18507/6508/22
509/11510/10518/3532/14532/17539/4
540/6545/23546/18547/5547/9547/10
548/8548/14548/19549/18550/13551/25
552/18552/25554/6554/11557/5567/8
567/13569/14570/10570/25575/10
575/12575/22578/11579/4579/12579/22
580/24586/23588/2589/14592/8593/10
594/4594/10594/18595/17609/8609/9
614/5614/14636/25643/20645/14646/3
647/19648/1649/9649/16652/2662/17
663/17663/18663/20664/2664/5664/9
670/19684/24699/17700/9701/14718/14
728/25
plus [2] 552/11594/19
PNC [2] 702/14702/15
podium [2] 625/12654/12
point [19] 483/9489/5491/3492/19493/4
493/10571/13610/14610/14611/7613/25
628/21632/21633/4635/4676/13677/5
678/10750/13
police [3] 491/9492/1492/15
policies [3] 499/4499/11500/6
policing [1] 491/10
policy [12] 497/24497/25498/10498/11
498/13498/14537/13537/13538/1551/10
558/6559/9
populated [1] 655/13
portal [1] 542/8
portion [5] 1/5684/24700/20717/18
722/24
position [7] 480/19497/23498/11615/3
615/12672/15755/15
positions [1] 671/14
possibilities [1] 717/2
possibility [1] 711/23
possible [9] 516/24611/8669/10669/12
687/7687/8687/12687/15711/25
possibly [7] 491/4491/4491/15510/18
619/9622/4681/10
post [7] 635/16635/24756/13756/22
757/6757/7757/13
potential [2] 619/11686/9
potentially [4] 559/17610/19620/3
688/25
PPP [155] 498/21499/1499/6499/8
500/7500/7501/4501/7501/11501/15
501/17501/19502/1502/10502/12502/13
502/15502/25503/15503/24504/10
504/13505/2505/11505/14507/15507/22
508/5508/11508/12509/22510/8510/23
511/19512/6512/21513/10513/24514/2
514/23516/25517/5517/18517/21517/23
518/22518/24519/1519/3519/16519/18
520/5520/13520/17520/20522/17523/12
525/5526/22528/9529/6529/7529/10
529/12531/17532/7534/2536/21540/22
540/24541/4541/7541/11541/12541/19
541/24542/6542/12542/14542/20543/3
544/2544/4544/6544/14544/17546/1
546/13546/21548/12549/22552/17555/6
557/15558/22558/23559/8559/12559/14
559/19559/21559/23560/6560/13560/13
560/15561/8564/8565/5573/3576/24
578/13578/16579/18581/4582/17582/24
583/6583/11583/16583/17583/18583/22
589/22591/2591/25592/1594/24596/21
597/19598/4599/25600/2600/6600/9
600/9600/13600/18601/4602/1603/19
603/22604/11605/1609/15610/15725/3
726/6726/13728/18730/2730/5730/9
742/5742/6
PPP loan [78] 501/7502/1502/15502/25
503/15503/24504/10504/13505/2505/14
507/15507/22508/5508/11509/22510/8
510/23511/19512/6512/21513/10513/24
514/2514/23516/25517/5517/18517/21
517/23519/3520/5520/13520/17520/20
522/17523/12529/6529/7529/10529/12
541/19542/12542/14543/3544/2544/4
544/6544/14544/17546/21548/12549/22
555/6557/15559/23560/6560/15561/8
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 312 of 324
P
PPP loan... [20] 564/8576/24579/18
581/4583/17583/22591/2591/25592/1
594/24596/21597/19599/25605/1609/15
725/3728/18730/2730/9742/5
PPP loans [15] 502/10502/12502/13
505/11526/22558/22559/8559/14583/6
583/11583/18598/4602/1603/22604/11
preliminary [1] 761/1
premarked [2] 505/17674/14
preparation [2] 1/13545/8
prepare [3] 654/20691/2691/6
prepared [4] 620/23674/9691/17728/12
preparer [12] 690/22690/24690/25
691/6691/17691/20692/5692/6715/2
715/3715/4715/5
present [3] 484/2486/23657/8
presented [2] 484/23581/15
preset [1] 616/11
president [3] 501/12504/15522/18
presume [2] 526/7528/7
pretrial [1] 482/2
pretty [9] 482/7491/17494/20495/13
616/20623/16629/15634/6760/15
prevented [1] 622/19
preview [1] 585/3
previous [5] 577/5594/8710/1740/12
740/21
previously [3] 688/17697/15729/2
principal [12] 512/18512/23513/6
514/12525/11525/12525/23525/25
550/15551/6575/13594/19
principles [1] 751/1
print [2] 636/6636/7
prints [1] 634/11
prior [12] 504/7504/7508/25535/11
606/15615/6624/19674/5688/5720/6
729/15730/15
private [1] 618/8
probably [15] 482/15556/17598/9
613/17638/24645/11653/6657/17668/8
685/2701/24705/7749/18752/6752/7
problem [7] 602/14621/22622/12699/5
699/8753/9754/5
procedure [1] 710/3
procedures [1] 500/6
proceed [1] 542/23
proceedings [6] 477/12477/18761/14
762/8762/11762/13
proceeds [14] 517/23518/20529/12
532/4537/24555/8555/12555/16556/6
556/21557/1557/14583/5583/11
process [36] 487/7503/23503/23503/24
504/3504/16542/7546/15559/12559/13
559/15559/22559/25560/1560/3602/6
602/7607/18615/20615/23616/20617/12
617/15618/3619/16619/20620/16620/24
652/21668/6687/4695/9711/16711/23
733/16734/4
processed [6] 523/17524/12657/6
673/15728/15733/11
processer [1] 618/7
processes [2] 602/1733/9
processing [6] 501/10687/23687/23
712/1712/8737/10
procurement [1] 497/6
produce [1] 619/21
produced [1] 477/18
product [2] 615/10617/7
products [1] 615/13
program [55] 497/6497/6497/24498/1
498/4498/7498/14498/16498/17498/17
498/21498/23499/2499/4499/8499/12
500/8500/14501/11501/15501/19506/14
508/12509/3520/3522/18528/10537/13
537/19540/21541/12541/14541/24
549/11550/21552/17552/22553/10
554/18559/1559/9559/10559/19575/7
593/22600/18603/19604/19607/10
610/15644/12656/1656/6658/12720/22
programmer [2] 656/4656/6
programs [4] 519/24537/18537/22
653/2
prohibited [2] 1/8584/10
project [1] 539/16
promise [2] 749/1749/2
promised [1] 672/9
promises [1] 635/7
prompt [1] 618/24
prompts [2] 619/6619/14
pronounce [2] 631/9664/7
proof [5] 487/22488/4591/24635/8
755/6
property [7] 518/8554/9554/15635/8
665/7667/21755/5
proposal [1] 754/6
proposed [3] 635/6635/21754/25
proprietor [1] 742/16
proprietorship [2] 509/18548/24
protection [11] 498/16498/21506/14
518/1518/9540/21554/10554/17554/18
559/10720/22
prove [3] 488/3488/20749/25
provide [22] 498/7510/6519/24520/4
520/6521/15531/1531/11545/2575/8
576/15584/23585/4586/4586/7586/12
591/24658/22671/24676/7690/3690/10
provided [35] 485/2503/11507/23508/1
509/4521/20524/4527/9527/15532/6
532/18532/19534/19535/15541/22
542/16543/9543/15547/12547/13555/2
558/12560/24560/25561/5564/18575/5
577/5577/8583/21587/9605/17624/21
635/22661/21
provides [2] 574/16652/23
providing [2] 611/11655/17
proving [2] 635/8755/5
provision [2] 531/21534/3
public [1] 500/20
publish [1] 507/6
published [2] 507/4545/21
puffery [1] 493/17
pull [34] 539/15545/22551/20579/4
580/19589/24589/25609/9617/22630/10
641/14645/15647/18648/12649/6651/5
675/17680/18682/21691/10699/15700/9
701/13705/23708/13710/19718/13719/7
726/8726/20727/17727/23728/6751/15
pulled [6] 546/24655/10655/12715/17
735/13758/13
punishable [2] 532/23547/17
purchase [2] 519/1519/16
purchased [2] 665/7665/8
purchases [1] 530/12
purport [6] 562/19587/20588/9589/9
590/3591/16
purported [1] 562/3
purportedly [18] 562/6562/12562/25
563/5563/11567/19568/8568/11568/14
568/16569/5569/8569/11569/21569/24
570/2681/4681/14
purporting [1] 711/17
purpose [15] 489/12489/13508/12
509/3514/2519/6519/10519/11536/21
537/18554/6556/14706/11706/12725/23
purposes [17] 488/25507/22510/4
512/16513/9513/23520/25525/7529/13
532/3534/2537/24554/20555/6618/17
674/25746/17
pushing [1] 491/8
put [40] 483/21486/23500/2506/23
530/1530/8538/1555/17556/7574/3
617/21632/20632/20643/19646/2647/16
653/1655/10655/11656/7657/13661/22
663/17668/5668/8672/7677/11680/18
690/2706/12709/13711/12722/2732/15
742/1742/17751/13757/20757/21760/16
puts [2] 603/1615/10
putting [9] 483/20486/22541/25551/16
618/17656/10656/10657/9687/3
Q
qualified [3] 524/25550/2695/18
qualify [1] 508/11
quarter [16] 566/25567/20568/3568/9
568/12568/15568/17568/24569/18
569/18722/18722/19722/22726/9727/5
727/5
quarterly [7] 560/23566/24568/2568/23
569/18722/14734/6
quarters [1] 560/24
query [2] 656/5656/16
question [40] 481/4488/4488/21513/2
513/18516/20523/22523/24524/1530/21
531/7531/8532/11536/9536/19536/24
538/5550/13550/19550/23551/3551/14
555/23555/25556/4556/5556/12556/18
566/19575/16577/7583/20599/2605/14
645/10669/6687/9728/24744/7744/16
questions [32] 480/23522/1522/6
531/13533/2542/15543/6546/7555/21
555/22575/5583/24584/2584/5584/22
595/15599/23609/6609/8613/8619/10
654/6662/1666/15669/4669/18671/17
672/1690/6730/23745/5755/2
quick [8] 481/21500/3532/11585/3
616/14616/20719/5744/7
quicker [1] 500/1
quickly [8] 501/10531/14541/17610/18
610/22611/8622/15687/15
quite [4] 538/12603/2659/21758/12
R
R-O-S-E-M-A-R-I-E [1] 495/22
raised [5] 582/24583/2583/4583/8
583/13
raises [1] 757/13
ranchers [2] 516/5516/8
range [2] 677/1677/2
rate [3] 489/2490/11754/22
rather [3] 747/3747/3747/25
RDR [2] 477/20762/18
rea [2] 752/12753/15
reach [1] 672/11
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 313 of 324
R
reached [1] 667/24
read [45] 509/11510/10532/17546/18
547/5547/10547/10548/8548/19549/18
550/13551/25552/18552/25554/7554/11
557/5565/1567/8567/13569/14570/10
571/1575/12578/11579/12579/22580/24
586/23587/16588/2588/5588/24589/15
592/14593/10594/4653/12656/4663/20
664/5664/9683/11692/4700/12
reading [1] 508/22
reads [1] 738/11
ready [9] 480/6481/19572/3572/12
636/16745/2745/10745/16745/19
real [5] 564/9660/14660/17719/5754/24
real-time [2] 660/14660/17
reality [1] 491/7
realize [1] 572/20
realized [2] 572/6719/10
really [20] 482/16485/22487/17488/1
488/11488/14539/16549/12606/9616/14
641/15694/16704/8722/17746/23749/20
750/19756/6757/14757/16
realtime [2] 477/20660/15
reason [5] 627/13698/14754/1756/17
756/19
reasonable [2] 541/21558/7
reasons [4] 688/5689/20698/14756/22
rebate [1] 688/20
recall [6] 527/23528/1598/21612/2
631/16730/5
receive [12] 513/11595/9652/19686/13
700/23700/24704/17709/14711/23
717/21718/11718/24
received [21] 516/13517/20554/3
560/12627/3627/3627/4637/22644/11
646/19668/25684/15686/19688/17
688/21700/16700/17706/18725/21726/3
732/8
receives [4] 627/10717/19733/5743/18
recent [1] 593/13
recess [4] 572/2636/15705/15746/10
recipient [1] 732/23
recipient's [1] 702/16
recognizable [1] 610/12
recognize [11] 493/17506/11533/12
544/23596/13597/2597/3609/18624/13
635/15683/19
recognized [1] 610/9
recognizes [1] 491/22
record [23] 495/20539/4614/14614/15
653/12660/24662/17670/19676/14678/6
679/3683/14695/1710/11713/24719/18
719/20723/13726/23728/1757/18759/7
762/13
recorded [4] 477/18628/24684/14719/1
recording [6] 545/14585/9585/18
585/22611/23748/15
records [17] 517/8545/5545/8592/4
660/25661/2664/22667/5673/9673/11
674/5675/19676/17677/3698/4720/6
731/18
recovery [1] 688/20
recross [3] 531/15535/23744/8
RECROSS-EXAMINATION [2] 531/15
744/8
red [5] 582/24583/2583/4583/8583/13
redirect [9] 529/1535/23609/7609/11
662/2669/5669/7741/12741/14
redline [1] 745/23
redlines [4] 634/20745/20746/12746/16
reduced [3] 740/18740/21762/11
reduction [1] 740/9
Reeves [3] 485/14609/2612/22
refer [5] 496/11539/25616/23620/9
638/24
reference [2] 525/19643/15
referenced [2] 643/13725/14
referencing [1] 1/6
referred [1] 674/14
referring [2] 644/4734/8
refinance [1] 552/17
reflect [10] 574/9575/23576/5576/5
685/19685/20686/6696/18704/13707/10
reflected [13] 517/3552/8570/16626/23
650/9660/16676/9676/16676/21677/16
698/3702/22704/1
reflecting [3] 699/22706/22707/22
reflects [1] 703/20
refund [57] 629/8671/18672/9686/9
686/23687/10687/10687/19687/21688/2
688/6689/1689/2690/17692/1694/4
694/5694/8695/4695/15695/20706/18
707/7707/11707/17707/17707/18707/20
708/1708/3708/7708/9708/16709/8
709/11709/15709/16709/17709/17
709/22710/4710/6710/9710/15710/15
712/11712/11714/11714/12716/6716/15
717/6738/3740/3740/10740/18743/14
refunding [1] 695/8
refunds [1] 687/12
refused [1] 670/11
regard [1] 490/20
regarding [1] 677/15
regardless [3] 507/16530/17530/23
regards [8] 648/25681/20703/18707/24
709/8709/20716/5716/20
registered [2] 510/21514/21
regret [1] 637/2
regs [3] 533/9534/9534/10
regular [5] 504/13527/17528/6529/5
558/22
regulation [2] 582/21587/4
regulations [4] 534/1535/16559/10
610/24
reject [3] 627/13638/8698/14
rejected [39] 602/9602/13606/25621/13
621/14621/18626/21627/11630/2631/18
631/21632/10637/9638/11638/12638/13
638/25639/1639/2639/4644/8644/10
652/10656/22658/16697/18697/20
697/22698/15699/22700/1700/4712/13
712/15720/6728/13729/1729/5729/17
rejecting [1] 630/3
rejection [11] 623/14627/12632/23
638/13640/23640/24640/25659/3698/2
698/18699/10
rejections [1] 697/25
rejoined [1] 497/22
relate [4] 549/24593/24698/6706/3
related [28] 499/11541/19624/15631/21
640/20642/12644/25672/19672/20
673/11673/24674/9676/18676/23682/24
695/16707/1707/7707/10720/12721/6
723/7727/11727/13727/20729/6741/17
750/18
relates [4] 648/7701/17720/21752/2
relating [1] 545/6
relation [4] 646/18662/21725/3728/18
relations [1] 497/13
relationship [2] 593/14593/23
relative [2] 668/12669/10
relay [2] 621/19623/15
relayed [1] 623/23
release [1] 687/10
relevance [3] 533/16537/5538/10
relevant [2] 534/25535/7
reliance [1] 492/21
relied [10] 484/23486/3486/25488/18
493/3605/2605/12605/18606/9612/14
rely [12] 491/4491/15493/14558/10
560/7560/10561/5605/21605/23613/1
687/2689/17
relying [3] 486/22492/22689/9
remain [1] 498/18
remainder [1] 703/15
remaining [3] 595/6710/5710/8
remember [13] 555/22584/15608/15
608/19608/21608/23609/1609/3609/5
631/16653/16690/7758/11
remind [1] 492/22
reminding [1] 719/24
Remove [1] 593/1
removed [2] 678/10747/3
removes [2] 488/6488/19
rent [4] 517/25518/7554/8554/14
rent/mortgage [1] 554/8
reorganize [1] 731/14
repaid [3] 528/14528/23541/23
repay [11] 527/17534/4537/2537/2
537/15538/7603/10603/12603/15608/1
611/24
repayment [1] 527/20
repays [1] 604/13
repeat [2] 513/18668/1
replaced [1] 751/11
report [5] 519/10627/7694/16703/1
735/22
reported [19] 509/20541/10549/1
693/13694/21695/17701/19702/15703/5
703/21712/23713/12713/14719/3719/13
721/25723/10741/6762/7
Reporter [6] 1/31/71/12477/21762/4
762/19
REPORTERS [1] 761/16
reporting [6] 673/18692/22702/14
703/12722/9725/22
reports [2] 559/17560/2
represent [1] 594/23
representative [7] 509/7509/8547/1
548/17586/1623/5671/16
represented [1] 693/21
represents [1] 594/24
request [12] 510/11524/15528/22
552/12557/6655/15655/19677/5677/8
678/9679/4679/6
requested [14] 528/19546/6687/21
702/7707/12707/17709/22714/11714/12
716/6735/8735/15754/25755/1
requesting [3] 676/5730/9736/7
requests [1] 756/24
require [7] 543/2584/23610/21635/8
660/10689/11755/6
required [33] 487/14487/24503/8
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 314 of 324
R
required... [30] 503/18504/9507/19
507/20507/25520/5520/6520/16527/19
541/20542/10542/17543/6543/11546/16
555/1558/1558/4573/10574/19602/6
602/7610/24611/3617/10619/21620/12
691/4722/4722/14
requirement [11] 511/16523/19526/14
549/11558/14558/17619/23619/25620/6
714/16750/16
requirements [15] 504/12505/8505/10
505/13508/4517/20518/20527/9531/17
542/19542/24543/21620/4620/22655/5
requires [4] 689/21732/14742/1752/13
research [12] 480/21685/21685/24
686/3704/12721/5723/7723/22725/17
726/2726/16727/13
researched [1] 702/3
reside [5] 512/16512/18512/19526/2
551/17
resided [6] 513/15513/21550/20554/2
666/8666/12
residence [16] 512/19512/23513/6
513/7514/12519/4521/4525/24525/25
529/17550/15551/7555/9575/14649/12
667/21
residences [2] 519/1525/11
residency [2] 525/12566/9
resident [8] 525/21526/6526/12566/14
566/15632/4643/11667/23
Residential [8] 663/7663/8663/11665/5
665/8665/11665/16667/16
resides [1] 526/1
resolve [1] 672/13
resonates [1] 756/5
resource [1] 497/7
resources [1] 497/4
respect [11] 499/1499/8502/24503/19
504/9505/2541/6541/12544/14558/5
753/6
respectfully [1] 757/19
respects [2] 532/21547/15
respond [1] 758/3
responds [2] 655/17656/10
response [9] 550/23551/13551/14
586/18588/16589/4621/21657/7735/11
responses [1] 621/17
responsibility [4] 691/22691/24715/9
715/12
responsible [4] 503/5622/24690/21
747/12
rest [2] 626/15748/20
restricted [1] 1/3
restriction [3] 508/9511/5512/20
restrictions [3] 510/25512/15515/6
resubmit [2] 622/6658/17
result [4] 584/22612/3612/3687/18
resulted [2] 695/4713/11
retain [4] 488/23518/5518/18554/13
retransmit [1] 622/15
retransmitted [1] 660/10
retrieved [1] 621/8
retroactively [1] 758/8
return [216] 497/20560/25564/22566/5
566/5566/8566/21568/3569/18573/5
587/10589/10600/8600/12616/5616/5
618/18618/21619/3619/13619/24620/14
620/20621/3621/13621/15621/18621/23
622/5622/22622/25623/12624/1626/12
626/19627/11627/20627/21627/23
628/12629/21630/2630/3631/18631/21
631/21632/10632/12632/16632/20638/5
638/21638/25639/1639/2639/2639/4
639/5640/13640/17640/19641/7641/8
642/2642/22643/6643/10643/15643/23
643/24644/12644/15645/1645/4645/18
646/13646/14646/24647/10648/3648/15
649/11649/23649/24650/4650/12650/14
650/15651/9651/10652/1656/5658/16
661/20661/24673/20683/19683/21
683/23684/1684/3687/4687/6687/7
687/23688/17688/25689/8689/12689/13
689/17689/18689/21690/1690/3690/11
690/16690/19690/24691/1691/3691/5
691/6691/14691/16691/18691/21691/25
692/1692/9692/11692/23693/1693/16
693/21693/24694/4695/12695/13695/16
695/17695/22695/24697/1698/11698/20
698/21699/3699/8699/12700/14700/16
701/3704/5704/8704/14704/15704/23
704/24706/5706/16707/11707/20709/23
709/24710/22710/24711/3711/6711/10
711/13711/14711/19712/1712/5712/9
712/13712/22713/10713/11713/22714/2
714/5714/6714/10714/18714/20715/3
715/6715/11715/21715/23716/5716/7
716/11716/20716/20717/10717/19
717/21717/24718/5718/7719/11719/14
720/7722/14725/9732/8737/7737/9
740/6740/7741/6743/17744/1
returned [4] 497/21540/12655/7655/8
returns [49] 568/23586/25605/16
615/14619/13620/3626/15628/15637/23
638/13638/24639/16640/10641/6641/19
644/1644/7645/8646/19649/23652/12
656/21656/22661/9687/2697/23699/22
700/1711/2711/15711/16711/16711/24
717/8725/21725/22726/3727/2727/22
728/3728/14729/5729/8729/12729/19
732/8734/25739/8752/2
revenue [15] 496/20553/16671/10
671/12671/15685/25691/18698/12
701/20710/1714/1721/8722/22723/11
733/13
revenues [1] 510/1
review [22] 528/13541/14541/20558/6
558/7558/21593/13602/7605/20606/1
606/1606/5606/7607/7607/8617/16
618/25622/2674/5676/6695/13720/6
reviewed [13] 541/1541/2541/3541/4
545/8576/22606/5606/13608/3664/22
691/5691/6697/15
reviewer [2] 579/2605/25
reviewing [3] 541/11620/20720/9
reviews [1] 524/15
rewrite [1] 753/13
rid [1] 746/16
right [256] 480/6480/10480/17481/1
481/5481/13482/20482/22483/12483/23
484/14485/12486/4486/12489/22491/11
492/17493/6493/16494/10494/12494/15
494/24495/6499/22508/18509/6511/9
511/10513/20522/18522/21523/2523/13
523/15523/25524/2525/5525/13525/15
525/22526/6526/18526/20526/23527/18
527/25527/25531/19531/22532/8533/5
535/18536/4536/15538/7538/21540/3
545/17545/22547/4548/7549/17551/24
555/23562/18565/9568/22571/12571/25
572/23573/2575/21576/2576/20579/23
584/20585/17585/19585/23587/25588/8
588/8588/13588/21589/15590/6590/20
591/3595/25596/5597/7597/20598/4
598/7598/12598/17598/20599/13599/14
599/19599/25600/13600/17600/23601/6
601/9601/15601/17601/23602/2602/6
602/9602/11603/20605/19607/11607/15
610/2611/11613/12613/23614/4619/15
620/22630/1630/21631/9633/10633/14
633/15633/18637/21641/6644/9645/5
645/7645/17646/21650/16650/24651/18
654/13654/18654/25655/1655/10656/23
657/2657/14657/22658/6658/12658/18
658/25659/6659/9659/13660/20661/20
662/4663/1667/8667/12668/5668/9
669/19670/7673/6682/10682/14683/8
686/17690/9691/1693/3693/18694/14
705/8705/20705/25707/14710/5718/3
720/17723/5727/1731/2731/7731/15
731/23731/24732/14732/17732/18
732/24733/5733/22734/1734/7734/16
734/18734/21735/6735/12736/2736/5
736/8736/22737/5737/22738/4738/10
738/17738/20738/23739/9739/15739/21
740/2740/7740/10741/4742/13742/14
742/19744/20744/23745/6745/7745/10
745/15746/5747/7747/19748/5748/21
749/5749/14749/19749/22754/5754/7
754/9754/12754/14754/18756/12757/6
757/11758/6758/25759/9760/12761/2
761/6
right-hand [3] 511/9548/7549/17
rise [13] 494/13533/19536/12571/21
572/14595/18596/6614/2633/11636/14
636/22705/11745/13
risk [2] 540/15540/25
Rivers [1] 758/13
road [2] 483/5736/10
Roadway [1] 758/13
role [13] 497/12498/18498/19499/1
499/8502/19502/24505/2505/3541/5
541/6541/13544/14
roles [2] 540/6540/20
rolled [1] 499/5
rollout [1] 499/9
room [1] 661/3
Rosemarie [3] 495/9495/16495/22
Rosemarie Drake [1] 495/9
round [7] 501/19501/20502/1511/22
511/23511/24511/24
routing [1] 629/6
row [25] 626/7626/8626/12626/18
626/18627/16628/12629/12630/5630/6
631/22637/16637/16639/16640/24641/8
646/6646/6647/2647/11647/22648/3
648/7650/10693/15
rows [10] 626/2639/17641/19643/22
644/1644/1644/11645/9646/23649/18
rule [1] 530/3
rules [7] 494/17499/10503/13526/5
554/18559/9600/9
runs [4] 659/17670/4670/4746/21
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 315 of 324
S
said [32] 484/3486/8486/8491/14
492/12493/23504/15524/2524/3524/11
525/4525/6525/13529/4529/4602/17
603/5603/6611/22611/24666/3668/1
698/19708/5732/9735/16735/17742/25
753/22757/10759/7762/10
salaries [7] 509/19548/25565/10684/9
684/11684/13712/23
Salvatore [3] 670/9670/14670/23
same [61] 490/16537/20540/1558/22
570/15570/20570/21576/21577/11578/2
578/13578/19587/6590/12590/12591/9
592/17597/3597/4598/9600/15627/23
629/3630/6638/5638/6638/10638/17
638/18639/22639/24640/13640/14
640/15640/19640/22641/8641/10644/21
644/25651/25652/8679/11679/12680/7
680/15682/9703/12711/15711/17711/18
712/12716/7719/12720/15721/1727/19
738/6751/7755/18756/5
SAS [1] 656/1
saw [17] 487/4493/22493/24596/2
631/17632/22684/4693/16694/5715/16
716/5716/11716/24718/2720/10729/11
742/4
say [70] 483/2483/18483/22484/6484/7
484/11484/13485/1485/5485/8485/10
485/15485/16486/13486/24487/10490/3
493/16494/5494/10495/4505/23510/3
511/24515/12515/17515/17515/19516/6
516/17526/2526/10531/18531/25534/5
551/13565/14582/6597/25598/22602/17
604/18611/25614/21617/20618/15
633/17635/3635/7656/9657/8658/20
659/23660/22673/3679/7681/3691/5
692/5696/5696/15696/21696/22733/18
737/4740/25750/1754/8756/7758/15
saying [38] 482/23483/14483/20484/25
486/9488/13489/18492/9494/6503/9
528/4565/10565/16567/10582/8587/17
587/21602/23603/9607/13667/10667/13
667/14667/14667/16683/2689/12691/7
692/1709/12712/10726/24733/23734/23
751/15753/3755/17758/8
says [57] 488/15492/24509/8511/9
511/11512/22518/17531/21531/24532/7
546/17546/18546/25547/10547/11
547/24547/24548/7548/17549/16550/12
550/12551/25552/11554/5561/21562/24
566/9574/20579/11579/20581/13587/24
589/13594/16594/17603/15619/8626/25
630/25647/7663/20663/25682/6683/7
685/5686/21689/6702/7702/13708/1
721/15723/5736/18741/7747/25755/25
SBA [63] 496/11496/14496/22497/9
497/12497/15497/20497/22500/22
502/18502/20502/21504/3504/7506/16
519/23522/7522/20522/23522/23522/25
523/8523/10523/13528/15532/23534/3
536/21537/2537/22538/1540/8540/13
540/15540/18541/15541/19541/21
541/24542/17542/21542/25543/1543/2
543/12544/25546/10546/16547/16
549/24551/10552/22558/6559/1559/7
574/11595/13600/20604/6604/14610/21
610/24612/7
SBA's [5] 499/1505/2505/3537/16559/9
scanned [2] 490/6586/25
scene [1] 495/12
scenes [1] 620/16
schedule [17] 516/5516/6516/7565/13
673/21674/2692/21692/22697/5714/7
715/16715/17725/10729/20729/20730/3
730/8
schedules [2] 689/13692/20
scheme [1] 753/10
school [1] 690/3
scoot [2] 539/16614/22
scope [1] 744/12
screen [12] 545/23546/24575/22606/15
624/4625/14637/21641/22643/5661/7
663/15687/17
screenshot [2] 574/7593/22
scroll [15] 625/22626/9627/13629/9
637/15639/10640/9644/9644/15644/23
648/4650/15651/16691/15703/9
scrolled [1] 649/19
search [7] 651/19655/5655/6655/16
697/21732/2732/5
searched [2] 734/20734/20
searches [1] 655/7
seated [14] 494/15495/24536/15572/16
572/20595/21596/8614/4633/22636/24
662/20705/20745/15746/13
second [21] 501/19501/20502/1510/10
511/10511/22511/24512/3532/15533/18
557/4568/9578/16578/20578/22653/15
661/5678/13703/9712/12745/17
secondarily [1] 635/23
secondary [1] 658/2
secondly [1] 501/13
seconds [1] 585/20
secret [1] 659/22
section [14] 512/9550/12631/5642/6
642/13643/8684/14689/6691/11692/3
706/9750/9751/1760/23
sections [1] 700/13
securities [1] 753/8
security [55] 480/7562/12562/15563/11
563/14563/22565/2611/4626/9626/13
626/16637/9637/17641/9642/3644/2
645/18646/8647/2648/3648/15650/2
673/19673/25676/1683/22683/23685/22
693/2696/22697/22701/3702/3702/20
703/2703/19704/6706/4707/3710/25
711/15711/18711/22712/12713/23
714/10716/13718/17718/19718/21
719/18729/10730/12741/24743/11
Security's [1] 618/15
see [85] 490/18506/8533/11542/11
558/8558/18571/25597/2610/6611/3
622/2624/10625/14625/15625/18626/2
626/6626/10626/14628/12629/9630/21
630/24633/1634/25635/2635/3637/3
637/21641/23647/23648/14651/15654/7
656/24660/19661/3661/6669/25677/8
678/6678/9681/11683/8686/7688/25
697/21705/25706/13708/18708/21
713/23714/25718/23720/21721/16723/8
724/23735/2736/17736/18736/21737/1
737/14737/17737/24738/3741/3741/3
742/23743/21747/2747/17747/20748/3
749/4749/5749/10749/13750/22751/2
751/11754/22755/4759/17
seek [10] 520/23521/2521/6521/10
521/14529/4530/18530/19530/24530/25
seeking [6] 529/9529/13529/16530/14
530/14758/1
seem [3] 597/3750/17760/3
seems [7] 488/3488/6488/6533/18
668/7668/8755/17
seen [16] 485/11485/13485/14485/21
486/11487/3608/6612/13649/2673/11
680/22728/17733/1733/2733/3734/3
select [1] 554/6
selected [1] 701/8
self [4] 509/17548/23701/8734/5
self-employed [3] 509/17548/23734/5
self-selected [1] 701/8
send [14] 528/4528/6630/9709/11
709/12709/16709/16710/4712/11732/15
734/12734/13738/22760/14
sending [4] 620/25659/3659/4688/15
sends [1] 616/8
senior [2] 615/4667/24
sense [3] 714/15716/8751/19
sensitivity [1] 637/3
sent [11] 584/18587/18594/15602/9
607/13616/22629/25657/3676/5718/10
744/2
sentence [4] 683/11756/7756/25756/25
separate [2] 750/9750/10
separately [1] 514/17
September [16] 569/2588/11594/7
628/5640/8644/19647/14650/18677/22
682/10682/14682/17699/1701/2720/1
731/5
September 10th [1] 640/8
September 1st [2] 588/11682/14
September 8 [1] 647/14
September 8th [2] 594/7628/5
series [3] 490/21508/18599/23
server [2] 652/22655/17
servers [4] 652/18653/5655/14659/17
service [24] 503/1503/14618/2656/3
656/4659/17671/10671/12671/15671/16
672/4672/4672/6685/25691/18698/12
701/20710/1714/1718/9721/8722/22
723/11733/13
serviced [1] 505/4
services [1] 653/1
session [2] 576/2576/9
set [4] 503/13503/13542/24543/14
seven [2] 486/11540/17
several [1] 603/2
shame [3] 485/20486/12487/11
share [2] 487/15657/22
shared [1] 657/22
she [15] 485/1490/9490/9533/11537/11
603/5603/6603/6613/10633/24634/5
670/2752/8756/15756/15
she'll [1] 625/16
she's [4] 484/13485/7486/24535/9
sheet [1] 686/18
shift [1] 484/21
shifting [3] 482/12483/5483/9
short [3] 497/10502/4705/8
shortly [1] 636/11
should [33] 486/3486/11493/3518/13
544/21570/18575/10590/12614/22620/9
624/5642/19652/4670/21676/10677/17
685/20686/7686/22686/24688/23692/9
696/23706/20707/13708/7711/13719/7
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 316 of 324
S
should... [5] 738/18742/13742/18
742/19743/7
shouldn't [1] 750/19
show [17] 483/20495/11534/25535/7
575/21576/17586/21587/12588/9591/16
591/24594/9597/22668/17684/7706/16
719/10
showed [1] 741/7
showing [6] 510/6577/3578/7586/10
587/12593/4
shows [7] 574/11575/24576/2598/11
598/14639/16641/24
shut [1] 500/18
side [12] 589/25589/25618/7625/22
660/2681/11681/11697/2697/2699/17
707/1751/24
sides [1] 492/5
sign [11] 629/17663/20668/4689/6
689/8689/21690/10690/11691/5692/3
708/5
signature [9] 546/25547/4579/9689/23
690/2690/10714/16714/20718/2
signatures [1] 689/25
signed [8] 488/16501/22567/22568/20
569/15570/5571/9718/7
signifying [1] 641/1
signing [5] 616/2619/18689/17691/7
692/1
signs [1] 689/11
similar [6] 679/11682/9714/5717/14
720/10727/13
simple [1] 634/11
since [16] 492/21497/11620/2627/11
647/7650/12650/23666/7666/13667/16
699/4709/2711/21755/22757/24759/14
single [3] 655/8742/6743/3
sir [23] 481/14481/22494/11494/24
536/16556/2571/24572/5662/4665/25
666/4666/19667/9667/19667/22669/2
669/21730/20730/24744/17744/21
759/11761/8
sit [1] 670/21
sits [1] 748/5
situation [1] 685/6
six [5] 527/24528/1537/21672/9672/10
size [13] 496/20511/6511/12513/23
514/4516/12525/8544/6549/18549/23
549/24553/5722/12
skimmed [1] 493/22
skip [1] 585/20
slide [1] 681/10
slightly [2] 577/21680/20
slower [3] 499/18499/21518/13
slowly [1] 539/17
small [15] 496/5496/6496/7496/10
496/11496/14496/17496/19497/7498/1
498/4511/7525/9611/7660/11
smaller [1] 502/5
snippet [2] 636/2745/25
Snow [7] 485/11485/21486/8486/14
493/21608/14608/14
so [427]
social [62] 562/12562/15563/11563/14
563/22565/1565/2611/4617/21618/15
626/9626/13626/16637/9637/17637/18
641/9642/3644/2645/18646/8646/24
647/2648/3648/15650/2651/12673/19
673/25676/1682/16683/22683/23685/22
693/2696/22697/22701/3702/3702/20
703/2703/19704/6706/4707/3710/25
711/15711/18711/22712/12713/23
714/10716/13718/17718/19718/21
719/18729/10730/12741/24742/17
743/11
Social Security [53] 562/12562/15
563/11563/14563/22565/2611/4626/13
626/16637/9637/17641/9642/3644/2
645/18646/8647/2648/3648/15650/2
673/19673/25676/1683/22683/23685/22
693/2696/22697/22701/3702/3702/20
703/2703/19704/6706/4707/3710/25
711/15711/18711/22712/12713/23
714/10716/13718/17718/19718/21
719/18729/10730/12741/24743/11
Social Security's [1] 618/15
software [5] 618/24634/9634/10653/2
718/9
sole [8] 509/18548/23678/20679/22
681/5681/23682/2742/16
solely [2] 514/22515/3
solution [1] 623/4
solutions [1] 540/18
solve [1] 621/22
some [73] 480/21481/6483/20488/24
490/14490/15491/3491/13494/18519/12
524/5565/20596/2601/11603/6609/13
610/9616/10616/10616/20617/17617/17
619/6622/8623/11624/6629/12629/16
632/23635/5637/13639/10656/1656/6
656/15658/21660/3660/10661/9671/14
672/19676/14678/9679/23679/25680/1
682/23686/25688/1688/4688/11688/12
693/10695/18705/6705/9709/5713/12
714/6726/6732/23734/13740/5741/25
742/1744/24747/6752/13753/7753/8
753/14754/18758/14
somebody [16] 492/9493/14526/1
526/2536/5536/20537/10601/25657/1
657/15668/12668/13668/13732/11
732/12754/4
somebody's [1] 657/9
somehow [3] 482/1655/12656/7
someone [33] 486/15523/12528/18
536/20548/3580/7619/8638/4657/24
666/12669/10671/23688/16688/21
688/24689/11690/19691/13691/19
691/21692/9694/13695/8696/14698/15
704/15711/14715/4715/5733/13733/23
742/16748/19
something [39] 480/12482/24483/19
489/7489/10490/11492/9492/12493/13
493/17494/7494/10524/10529/3532/8
537/9537/14538/2602/16616/13619/10
622/4622/19627/6630/15633/20676/17
688/20690/8711/5711/7711/9743/22
752/14752/19753/15753/17757/23760/6
sometime [1] 480/13
sometimes [3] 660/1718/5758/19
somewhat [2] 679/11682/9
somewhere [3] 602/18603/12705/17
soon [2] 687/12746/9
sorry [50] 485/19493/7494/18499/19
513/19513/19520/10529/3530/4549/2
550/7550/25568/15571/7575/11590/23
591/21596/20606/17625/12630/12631/9
633/16644/9644/23647/25650/8650/21
651/7651/19654/9654/14659/7661/14
662/24664/7665/2671/5682/17689/2
691/10704/5705/23719/5724/3724/24
739/16756/18756/21759/6
sort [17] 481/8491/23494/21541/18
600/20605/2607/3629/16634/9699/16
700/13702/10704/22712/8735/16750/2
752/18
soul [1] 608/24
sound [4] 527/25601/12601/15633/18
sounds [3] 601/2601/17601/18
source [3] 565/21565/21581/3
sources [1] 673/13
speak [4] 481/2605/25607/17671/23
speaking [3] 628/20739/12740/11
specialist [1] 497/13
specific [14] 574/18622/21629/12
673/24701/20701/21706/15706/20
709/20727/3728/24751/17751/22753/11
specifically [17] 500/17501/21512/11
541/13555/3607/16608/15612/13615/22
624/15641/7707/2709/12715/17736/3
739/12751/9
specified [1] 554/17
speculate [2] 717/1717/3
speed [5] 500/10501/9520/18610/15
610/17
spell [8] 495/21539/4606/19606/20
614/14635/1662/17670/19
spelled [1] 679/16
spend [2] 526/3747/6
spending [1] 518/19
spirit [1] 490/17
spit [1] 658/16
spoke [1] 665/2
spot [1] 711/13
spreadsheet [19] 624/22625/21625/25
626/2631/17631/22645/9647/22647/23
648/1654/18655/8655/10655/11655/23
656/8656/11656/19660/16
squares [1] 710/7
SSN [1] 626/19
stake [1] 548/4
stamp [1] 627/3
stamps [1] 660/4
stand [1] 721/19
standard [11] 493/15496/20511/6
511/12514/4514/11549/18710/3714/15
714/19758/9
standards [3] 525/8549/23549/24
Stark [1] 490/11
start [15] 480/9494/7495/1519/18
519/22521/11529/19531/25556/22557/1
559/21564/1628/9732/5735/8
started [6] 497/10497/12600/5665/18
680/11688/12
starting [9] 502/3502/7508/18518/4
554/12593/11600/15615/6629/17
starts [3] 480/8631/6657/5
state [24] 495/21496/24497/1539/4
614/14615/14616/17617/8620/21632/5
632/7634/19638/5638/7638/9638/12
638/21639/19643/11643/13646/14
662/17664/14670/19
state's [1] 638/11
stated [2] 544/11687/19
statement [21] 481/3482/8493/3493/4
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 317 of 324
S
statement... [17] 509/11509/23528/6
532/22547/16547/19549/3554/22561/1
561/16562/20566/24586/8596/23597/17
598/7692/4
statements [7] 508/18508/23508/24
560/23580/18597/7689/14
states [40] 477/1477/3496/16498/6
498/7501/12510/3510/21512/19512/22
513/5514/7514/21515/2518/5522/23
525/3525/10525/11525/21525/24525/25
550/15550/20551/9551/12551/18552/9
554/2557/19557/23575/15614/7653/9
741/21750/13755/14756/24762/5762/9
station [1] 637/11
status [8] 566/9574/11626/19638/15
646/10646/11671/18706/17
statute [5] 749/9749/21750/18750/20
754/11
stayed [1] 500/21
Stenograph [1] 762/7
Stenographic [1] 1/12
stenography [1] 477/18
step [15] 533/3533/17533/21533/22
538/14538/19595/16613/15633/13
658/21658/22662/4669/19705/13744/20
steps [2] 619/1690/12
stickler [2] 536/1613/25
still [35] 486/21488/10488/20514/7
515/23522/14522/15523/8528/8529/10
618/22621/3634/1639/7639/11644/18
646/16648/22668/17669/20690/20
690/20691/4691/21709/18710/16714/15
714/16715/9730/12746/19747/11758/22
758/22759/2
stimulus [8] 688/5688/8688/16689/2
707/8709/21737/25738/2
stipulation [3] 653/12759/20760/12
stop [5] 494/5532/25547/18705/17
735/3
stopping [1] 613/24
stored [1] 655/17
street [2] 679/8679/13
stretch [1] 705/9
strictly [2] 620/16695/5
strike [3] 516/19553/18568/15
struggling [1] 659/8
stuff [4] 487/19526/8634/6658/22
stupid [1] 486/10
submission [3] 591/19617/3752/2
submissions [2] 578/2728/23
submit [26] 484/2503/7517/6523/10
527/10527/15531/17558/1560/18560/22
586/1586/19589/4589/11589/21589/21
603/6615/14616/3616/7619/21619/22
620/6635/16657/1757/19
submits [1] 615/24
submitted [54] 487/14487/25506/24
517/8524/10546/2547/7561/8561/9
561/19562/22564/4564/8565/4573/4
573/8576/6576/25577/8577/12577/17
578/14578/20583/22588/15589/2590/6
590/8590/16590/21591/1591/8591/9
591/15609/15610/2610/7613/4620/15
620/24637/23638/17644/12673/16681/1
702/21722/8725/2726/13728/15728/18
728/20730/1730/11
submitting [3] 504/7620/2691/14
subpoena [2] 655/4655/19
subprogram [1] 498/17
subsequently [3] 534/6602/20676/8
substantial [1] 716/12
substantially [2] 578/2665/21
subsumed [1] 752/15
succeeded [8] 621/12641/2646/12
647/7649/21650/12652/13729/9
successful [2] 639/6661/23
such [11] 481/5486/10488/25519/24
520/3536/1554/21634/5634/6673/13
673/19
sufficient [1] 591/24
suggest [4] 557/9557/12686/1695/17
suggestions [1] 482/1
Suite [1] 736/10
summaries [1] 674/14
summarized [1] 674/3
summarizing [1] 630/22
summary [12] 654/24673/23673/24
674/6674/8674/23674/24677/14699/20
700/14727/14728/9
superseding [1] 653/22
supervise [2] 528/9528/11
supplier [2] 518/8554/16
support [25] 496/7497/2497/6498/24
509/2510/12510/15510/18517/8517/12
518/22518/24543/16557/7557/10557/15
560/18561/8573/3573/8573/17606/11
609/15623/3623/5
supported [1] 517/12
supporting [9] 498/15499/4499/9
499/11521/23532/19547/14561/5561/11
suppose [1] 491/3
supposed [20] 492/12532/2535/24
537/17591/2591/5668/8684/13684/14
685/6685/15685/19696/18696/21696/21
702/25721/19722/8750/11751/17
supposedly [1] 588/13
Supreme [5] 634/22755/25757/4757/10
758/3
sure [38] 481/18482/16489/21489/22
491/17493/5500/20503/5503/12504/3
508/24510/14511/15596/3601/10616/10
619/4619/15620/13620/21649/4651/18
658/9658/10658/20662/25668/3668/10
690/21691/22705/1705/16733/6742/2
747/7747/10747/12750/1
surplus [2] 686/23694/20
surreptitious [1] 659/2
suspect [2] 493/21493/22
Sustained [1] 538/11
SW [1] 477/22
Sweeten [1] 490/8
switch [6] 572/10641/11648/1648/11
649/15651/4
switched [1] 630/14
sworn [5] 495/17538/25614/10662/13
670/15
synopsis [1] 603/13
system [45] 572/7615/16617/20621/2
622/1622/4622/10622/12622/13627/7
628/6628/25632/16634/10638/12638/17
650/5657/5657/14657/19658/24659/10
659/12659/13659/15659/19659/21
676/23677/9679/1681/21682/17687/5
688/22697/21698/3699/23700/21712/5
722/6726/2726/16729/23735/15743/6
systems [9] 477/20576/12576/19
617/25618/16618/17620/6659/18676/9
T
table [3] 514/18641/12654/11
tabs [1] 624/11
take [21] 480/10503/8503/11524/8
539/20609/13622/3655/21665/20678/1
705/2705/8710/4712/1732/23736/14
738/13743/18746/4748/24749/8
taken [8] 572/2636/15655/1705/15
706/14706/19706/19746/10
takes [3] 559/4656/15718/5
Takhalov [1] 758/25
taking [1] 665/24
talk [31] 480/13480/24481/3483/22
492/20499/18518/13534/21539/17
550/11571/18571/23599/9617/19621/18
633/8633/9633/15633/19633/20635/5
657/7668/2675/4675/7745/6745/16
747/5751/21759/10761/7
talked [11] 507/3599/11607/9646/19
680/9707/8709/21731/17735/6739/7
740/4
talking [23] 492/21493/13493/17493/18
493/20509/13524/24533/25540/1597/19
605/9615/25634/8634/9634/10645/4
645/17654/17734/9738/1739/8751/3
758/16
talks [2] 655/15656/9
tax [231] 487/15504/6517/8526/3
560/23560/25561/1561/8563/1563/22
564/1564/1564/6564/6564/7564/9
564/11564/14564/18564/22566/5566/5
566/21566/24567/17567/20568/2568/23
569/18573/5573/5573/5586/13586/25
587/10587/19589/10600/8600/12605/16
605/22615/10615/24617/3618/17618/20
619/11619/18619/24620/8620/14622/22
626/3627/2629/21632/1632/3632/16
638/5639/8640/21642/22644/5645/3
645/4645/18646/14646/16649/25661/19
661/20672/5672/19672/20675/25676/7
683/19683/21683/23684/1684/3684/15
685/4685/23686/4686/4686/5686/8
686/21686/22687/2687/4687/5688/13
688/16689/8689/11689/17689/18689/21
690/1690/11690/16691/3691/19692/9
692/11692/23693/1693/21693/24694/3
694/12694/23694/25695/4695/6695/12
695/13695/15695/18695/24696/3696/6
696/22697/1697/18698/7698/11699/8
699/12699/13700/6700/16701/20701/21
702/7702/20703/21703/22704/4704/14
704/15704/23704/24706/15706/16
706/20706/22707/24708/6708/7708/9
709/23709/24710/1710/11710/21710/24
711/2711/3711/6711/14711/15711/16
711/19711/24712/15712/22713/11
713/13713/14713/24713/25714/10
714/19716/11716/12716/13716/20
716/20717/6717/9717/10718/24719/2
719/11719/13721/5721/5721/7721/17
721/19721/19721/22722/1722/2722/7
722/14722/17723/8723/10723/18724/5
726/25729/8731/20731/21731/24731/25
732/5732/7732/8732/15735/22736/3
737/4737/7737/8739/8741/17742/19
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 318 of 324
T
tax... [9] 743/16751/24751/25752/2
752/3752/8752/8752/9752/10
taxes [32] 509/20548/25558/18562/6
562/12563/5563/11568/17569/12570/3
611/4629/7658/1664/3685/20685/24
686/10686/16696/23710/14710/16
710/17713/16713/25722/9722/21723/3
723/12723/18724/12733/22734/10
taxpayer [33] 627/22627/25632/4
639/15639/21639/25643/7647/13671/20
672/3672/4672/6672/8687/6690/9
690/14691/4691/17691/22691/25692/6
696/25707/19708/3709/25711/8715/9
715/12717/10718/8731/25733/6736/7
taxpayer's [2] 643/10735/17
taxpayers [5] 671/17671/21671/22
688/15706/13
TBD [1] 675/15
team [14] 495/2499/9499/9506/23
540/13540/15540/15540/18540/18541/1
541/7654/21654/23669/25
tear [1] 665/13
tech [1] 615/13
technical [3] 497/4622/17634/6
technology [2] 1/13615/8
Ted [1] 477/22
telephone [1] 587/7
tell [23] 494/6535/3556/25578/25
596/15596/15614/23635/21642/19
657/15671/8701/16747/15747/19747/21
747/22752/19752/21752/23753/14
753/25754/7754/15
telling [3] 490/22539/17756/4
temporary [1] 498/23
ten [6] 508/18540/5571/25603/2663/12
705/8
ten-minute [1] 705/8
tendency [1] 492/25
tenor [1] 603/16
term [1] 754/6
terms [102] 483/25500/6503/4513/16
618/20621/1622/7622/8623/9623/14
623/25626/2626/22627/6627/15629/2
630/21631/5631/20632/3637/17639/11
639/14640/19641/3641/18642/15644/11
645/7645/23646/10650/4651/3651/21
652/9673/9673/18674/13676/3676/20
677/14679/7679/24680/25682/1682/5
682/16682/23683/21684/9684/13685/15
685/18686/5687/2688/4688/5688/20
688/24690/16692/19692/23693/7693/21
694/4694/8695/15696/14696/18698/6
702/19703/7703/25707/5707/14707/16
707/22708/16711/2712/3712/4712/16
713/1713/22714/2714/14714/20716/15
717/6717/14718/18719/24720/6721/4
722/7723/7724/16726/19728/11729/1
743/13751/21
terrible [2] 513/19581/9
territories [2] 496/16498/6
testified [13] 495/18539/1564/7573/2
598/19612/12614/11658/11662/14
670/16699/19710/10743/10
testifies [1] 485/1
testify [1] 749/17
testifying [1] 689/9
testimony [10] 488/17537/25545/9
624/19634/4673/23674/13674/16674/21
760/8
Texas [12] 566/20627/20631/14631/18
632/9632/10643/16647/10649/11664/14
664/17712/16
text [3] 629/13682/21746/21
than [31] 496/19502/12515/22516/18
518/13520/4520/13520/17545/20549/20
550/3559/22560/15571/5580/4617/23
642/25647/6649/2653/9686/22691/13
692/5718/6722/13747/3747/4747/25
752/7754/21756/15
thank [73] 492/17495/20495/24499/23
531/13532/10538/13538/15538/16
538/18538/20539/3539/8556/2571/20
574/2590/1592/8593/16595/15597/14
599/13601/20613/8613/11613/21614/6
614/13614/18633/7633/10636/9636/10
653/21654/1654/15662/5662/6662/16
662/20663/22666/15669/17669/20
670/18670/25672/17673/7675/11675/16
681/7681/7683/7684/24691/15705/13
705/14705/22719/7730/18730/20735/4
736/15738/13741/10744/6744/17744/19
744/21744/22745/12748/8761/12
thanks [4] 539/20636/13654/2670/5
that [1655]
that's [213] 482/12482/12482/21483/19
484/12484/21484/25486/17488/2488/3
488/4489/16490/1490/21491/13491/23
491/23492/6492/13493/9493/18493/25
496/13496/13511/6513/1526/4526/18
526/19526/21531/6531/24531/24545/3
552/18552/18556/14566/5568/13571/15
572/11576/11576/23577/19579/14
579/17584/14587/15597/16598/6598/23
600/1600/11601/17601/23602/25603/4
603/16603/21604/1605/8607/5611/18
611/21616/3617/23618/3618/3618/19
618/25618/25619/22620/5620/5620/5
620/12620/18620/24620/24621/23
621/23622/16622/25622/25624/4624/17
626/22627/2627/9628/2628/23629/7
629/13629/13632/4632/18632/18633/3
634/12634/15639/25640/1640/23640/25
640/25641/5641/23645/4646/23649/24
651/22651/25653/4653/4654/7654/9
654/18655/24656/24657/12658/22
659/17661/16661/21661/21662/1664/20
665/3666/6667/23667/24668/14668/19
668/25669/4669/24669/25670/12670/23
671/7672/6673/19675/15676/1680/23
681/17685/4685/13689/20690/10692/16
693/2696/17696/24698/21700/7700/16
701/24702/9706/19708/8712/9715/21
720/14721/15722/2731/6731/21731/23
731/23731/23731/25733/8733/8734/15
735/3735/21736/2736/2736/21737/4
737/4737/6737/21737/25738/3738/4
738/5739/21740/2741/5741/6743/6
744/23746/15748/15749/13750/6750/6
752/6752/15753/12755/8755/21756/6
756/9756/17756/19757/7757/25757/25
758/1758/6
their [65] 483/8487/7487/10487/11
488/4496/20507/17512/18513/21514/9
515/19525/3525/10531/1542/9542/10
543/4550/21558/2559/9570/3570/3
574/11576/12576/13582/14582/14
603/22610/20610/20617/25618/2618/12
620/4620/6622/25638/4653/1659/16
659/18659/21668/5668/14671/18671/18
672/1687/6687/10688/16689/11689/18
697/1700/21701/10710/4729/23731/25
733/14733/17733/22734/10738/16
742/11742/17750/1
them [70] 481/13481/17485/20486/4
486/7486/8486/9486/12487/5487/11
488/19490/6494/7494/12497/4508/22
528/11535/22536/4541/2544/24545/2
545/2568/11568/11569/8569/24596/1
596/5597/3603/25611/1613/23620/25
624/11624/17626/4626/16627/17630/10
640/18653/1658/22658/22660/14663/10
670/3671/19674/20687/15726/8738/22
746/2746/5746/22746/25747/1752/19
752/21752/23753/14754/7754/14754/15
754/18754/23756/5758/12760/15760/25
theme [1] 482/21
themselves [2] 552/23617/25
then [158] 482/25483/19483/21484/9
485/5485/10494/20497/11498/19503/8
503/11503/13503/14511/12512/3523/10
525/21527/10527/10527/24528/22
534/24535/19540/12540/14540/17546/7
548/15548/17550/5550/12551/24554/11
562/5563/4565/16565/19566/9567/17
568/7569/14570/5570/22571/7575/1
576/1576/9576/20576/24578/8578/25
579/20580/10581/13581/13588/2588/5
588/22590/11592/17593/4594/11598/19
603/5604/22615/21616/21618/1619/6
620/23620/25622/3626/15628/10628/14
629/5629/9629/12630/1630/5630/25
631/12632/7635/23637/20639/3642/5
642/6651/14652/4655/6655/18655/18
657/6659/3659/11660/9661/22664/1
664/9665/16670/12671/20674/8677/5
678/13680/14684/7684/20685/4685/12
687/14690/7690/9693/12695/4697/9
699/17700/20702/13702/16707/19709/5
710/5712/8713/4713/7713/18716/16
717/18718/8728/14728/17728/18728/19
729/3729/8732/4736/21737/7737/10
737/24738/3738/6739/10743/5743/20
747/2748/19749/11754/7754/8754/19
756/23759/17759/20760/1760/11
theory [2] 482/19657/25
there [348]
there's [85] 480/24481/5488/4508/18
509/7516/22519/9526/14531/21534/8
566/9566/13567/17592/10592/10604/12
616/13617/12619/14620/11622/10
624/11625/21627/3627/22628/11628/14
629/16630/24634/5635/16637/2637/22
639/25643/22643/23646/14653/6653/10
655/20657/15657/19659/2659/9659/16
661/3665/3677/23678/24683/7684/17
685/5685/9685/12686/1686/21687/7
687/7690/5691/16693/10693/11694/25
698/15700/13700/14703/11706/25707/1
708/18713/4713/20717/2717/6717/9
719/18731/12736/10736/24738/6746/25
755/2757/7758/12760/11
therefore [2] 491/4535/7
therein [1] 653/23
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 319 of 324
T
these [74] 481/5482/10482/11484/3
484/3484/9488/18490/4501/10504/12
508/22508/23508/24524/17524/17528/9
534/5535/16535/16544/23545/5545/8
555/21555/23556/4563/17564/4575/5
578/1591/1591/5591/8591/11591/19
597/3602/11604/15605/1606/13609/13
609/14610/22610/22610/25610/25617/8
624/14624/17624/20629/3633/23633/24
637/18638/23638/25639/12639/22
640/10641/6641/6644/7644/8645/8
649/21649/23659/9660/22685/3693/20
725/22728/3728/23746/16759/10
they [230] 481/10481/18481/18482/11
484/2484/3484/18484/23485/10485/11
485/12485/13485/13485/14485/21
485/21485/23486/2486/2486/2486/2
486/10486/11487/6487/6488/3488/9
488/20491/8491/8491/9492/12493/21
493/22493/23493/24493/25500/20503/5
503/13504/24505/5507/16510/15513/20
513/24514/11514/11514/19515/19
518/13519/5519/9519/10519/10519/11
519/13523/3523/4523/9523/9523/10
523/12523/15524/18524/20525/6526/2
526/3526/11526/25527/17527/17527/19
528/5528/7528/19528/19528/22530/11
530/18530/18530/24530/24530/25
531/11533/9534/5534/5536/20536/20
537/7538/7538/7542/8542/9542/10
542/11543/11543/14552/17552/22558/8
559/12573/12573/12574/19576/11591/2
595/14596/1597/3605/14607/23607/24
607/24607/25607/25608/1611/11612/17
612/18616/7616/14617/25618/12619/9
621/6623/3623/16624/15625/6626/17
629/22630/7637/2637/25638/5638/18
639/24640/12644/9644/14649/22652/9
652/15652/16652/18652/24653/10
658/17659/12659/21660/10668/5670/11
672/1673/17673/18673/22674/12674/17
674/21674/23675/9678/1680/16687/10
687/14688/12688/14688/17689/14690/6
690/9692/10692/10692/11697/25698/1
699/24700/4702/16704/16709/15709/16
710/4711/14712/1718/10722/4722/18
722/19722/20722/21723/14729/12
729/14732/16733/10734/6734/6734/12
738/18738/21738/22739/5740/20741/20
742/2742/9742/9742/18743/18743/18
744/3749/25750/10750/15752/6752/6
752/7752/8752/23752/24752/24754/9
754/19758/4758/4
they'd [1] 742/17
they'll [4] 675/1690/9711/10734/12
they're [33] 486/22486/22486/23490/2
497/3545/20570/20570/21587/18591/11
591/11597/6597/6618/21638/9638/20
649/7661/5668/8674/24687/11687/14
698/13698/13710/4718/9722/5728/14
738/16742/16742/20749/10758/8
they've [6] 486/23492/11526/2616/6
616/6698/14
thing [13] 483/22492/19565/24621/24
657/4703/12716/7738/7740/25748/9
755/18756/5759/7
things [26] 488/24489/13490/4490/22
491/14494/18494/21504/16543/18
555/23555/25556/4571/18605/2620/19
629/17635/18659/9660/9698/12732/7
742/21746/24747/5750/1751/24
think [125] 480/21480/22480/23480/24
481/1481/3481/20482/8482/12482/14
482/18482/18482/20482/24482/25483/1
483/1483/25484/1484/12484/15484/18
484/22484/25485/6485/24485/25486/19
486/21487/1487/4487/5487/8488/11
488/14488/15488/16488/19488/19
488/20489/2489/16489/20489/21489/22
490/15490/16490/20490/23490/25491/6
491/6491/7491/17491/19491/21491/22
492/15492/15493/6493/7493/25518/14
556/17571/13601/23613/22623/14633/3
634/3635/4639/21640/23651/2651/16
656/17670/10674/21740/17740/20741/8
745/22747/5747/8747/20748/15748/23
749/8749/15749/23749/24749/25750/5
750/7750/23750/25752/5752/11752/15
753/6753/7753/11754/2754/14754/21
755/21755/23756/12757/4757/13757/14
757/20758/13758/15759/12759/14
759/15759/21760/8760/11760/13760/18
760/20760/22761/9
thinking [2] 480/19495/10
third [8] 518/3547/25554/11618/7
653/22735/3736/14737/14
third-party [1] 618/7
this [527]
those [90] 492/14492/14503/3503/4
504/16511/21513/9514/14516/4517/9
517/13518/19520/1522/24532/2534/4
541/22542/24543/18552/23555/25560/5
564/8570/8570/16579/23583/24584/2
591/16596/2604/11605/18609/6611/25
611/25616/24621/8621/16622/9624/12
624/13630/6641/18645/8652/9652/13
653/9655/7658/24660/9660/9660/19
672/5673/6673/13673/18673/24674/13
674/15676/22680/1685/6685/16687/8
690/12697/25699/9699/9700/4710/14
729/1729/5729/12729/17729/19729/22
733/9740/18741/4742/6742/14742/25
743/3743/15744/1751/14752/9758/10
760/15760/16
though [7] 532/3532/6541/24622/15
691/5709/17756/4
thought [7] 482/7488/1488/5535/12
535/12745/24753/23
thoughts [1] 745/5
three [14] 505/19511/12540/14593/10
605/2636/7653/14653/22656/21656/21
674/9747/16747/25748/1
through [55] 488/2488/5493/22502/2
502/17527/13540/6542/6559/13559/22
559/23570/17610/1616/10616/15617/11
619/1619/19620/8620/12620/15623/4
623/9624/1624/11624/16626/3637/13
640/2644/4644/12650/5650/13650/23
652/1652/13655/21656/15660/22661/8
661/12661/23673/3673/14685/3695/12
698/22700/18700/18700/19704/1718/8
719/19740/4741/1
throughout [1] 499/11
tie [4] 483/14483/15483/24494/24
tied [2] 489/11587/19
tight [1] 670/12
time [45] 480/11488/9489/10501/25
503/13504/5533/7534/6534/11534/12
535/25540/5541/21558/7571/19576/4
583/20584/6607/8607/14616/5616/9
627/4638/5638/6638/10638/17638/18
646/10647/5651/3656/15660/14660/17
666/22688/9705/7705/16709/5730/13
743/20745/3747/1747/6757/23
timeframe [1] 727/19
timeline [1] 576/1
timely [1] 559/5
times [14] 494/4494/6512/13522/17
529/7533/10552/11552/15553/3553/4
553/10668/23732/4743/10
timestamp [10] 622/10627/3627/8
627/9637/22638/16644/11646/18646/20
647/3
timing [1] 650/4
tips [7] 565/10567/14569/8569/24
684/10684/11712/23
title [6] 496/22496/23663/13733/14
733/15733/17
today [13] 494/24545/9597/20624/19
672/23673/23674/5674/16721/2744/24
745/9748/10761/7
together [12] 483/25500/2506/23570/9
578/17605/1605/2605/15620/25638/19
638/20687/8
told [14] 481/1487/18488/9536/20537/8
537/10537/14537/16586/4586/7586/12
607/21607/23607/24
toll [1] 671/16
toll-free [1] 671/16
tomorrow [4] 480/13748/11749/5
761/10
tonight [1] 747/6
too [15] 482/4482/23491/19491/21
495/3518/10518/12533/21538/18570/17
636/20662/23700/12734/6757/4
tool [1] 617/11
top [30] 511/8546/5546/17548/6549/16
567/25578/11579/11584/13587/24
588/24610/2626/19634/20641/23648/19
664/2683/2684/24693/3700/20700/23
702/2706/8706/25717/18721/16724/2
735/3738/9
topics [1] 524/25
TORJ [2] 677/23678/4
TORJAGBO [68] 477/5544/10545/6
547/3548/1549/5552/5554/24560/17
564/5564/24565/4567/23568/21569/16
570/6571/10573/13576/25577/14579/24
580/4580/12580/13585/14585/25588/15
589/21590/4593/17595/6598/22602/9
602/23603/9627/17631/9631/10639/11
642/11664/8666/8672/20674/10677/20
678/3678/20679/22680/2680/3681/5
681/23682/2684/2691/14695/2696/9
697/10702/17710/22712/24717/8727/25
730/12731/10734/21736/8762/9
Torjagbo's [6] 547/9566/8589/10591/5
696/12743/25
torjagboc [1] 628/14
torn [3] 665/14666/2667/18
total [9] 540/5561/22562/2562/25
565/16570/12570/13570/15723/18
totals [3] 561/21562/24724/10
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 320 of 324
T
touch [1] 529/3
touched [1] 520/15
touches [1] 482/25
towards [7] 508/13511/15512/21514/19
515/8515/23518/19
tracking [4] 735/19735/19735/20
746/17
traditional [8] 559/3559/14559/16560/9
560/13601/4602/5604/14
Trail [7] 679/9679/16681/8681/24682/6
682/7684/3
training [1] 498/15
trans [1] 616/18
transaction [3] 581/20606/16706/19
transactions [6] 580/5580/8706/9
706/14737/15743/22
transcript [39] 1/11/51/81/91/14477/12
477/18701/17701/18702/19702/22
702/24702/24703/1703/17703/20706/3
706/11706/12706/21706/22707/5707/14
708/2718/16718/18718/23719/17735/9
741/8743/9743/14743/15743/19748/14
759/13759/19759/21762/12
transcripts [5] 1/2504/7671/24706/1
741/2
transfer [1] 583/1
transferred [1] 733/3
transfers [1] 653/23
transition [1] 498/19
transmission [3] 622/16622/19660/5
transmissions [1] 660/9
transmit [1] 638/9
transmittal [1] 717/19
transmitted [19] 616/18616/21621/1
638/6638/9647/13650/4652/14653/24
657/6700/17704/8704/20715/10717/24
718/8719/14729/9729/22
Treasury [5] 499/3506/17541/16708/25
709/18
trial [2] 487/22760/23
tried [2] 711/14750/10
trucking [1] 557/1
true [14] 503/22509/4509/23517/13
524/9532/20537/15547/14558/11563/22
573/11689/15756/9762/13
trusting [1] 687/5
TRX [1] 576/4
try [11] 480/11492/15536/2617/1619/10
626/6670/4671/18672/13687/11746/8
trying [15] 484/21486/5487/5495/1
590/8619/12623/16637/1637/4644/24
671/25690/12700/1751/13753/21
TurboTax [50] 615/16615/20615/25
617/4617/14617/20617/23618/1618/4
618/14619/19619/23620/2620/9620/9
620/11621/2621/19621/20621/21622/7
623/9623/15624/1624/16624/24628/1
632/19638/4640/2641/4644/4644/12
652/18653/5657/2657/10657/16657/19
658/11673/14697/16698/4700/18717/16
717/19718/6718/8720/6728/13
TurboTax's [4] 627/7632/16650/5
699/23
turn [15] 532/14548/14566/4567/24
568/19568/22569/17570/7580/21588/8
588/22590/11625/11663/18714/9
Turner [1] 477/22
turning [26] 511/8518/3546/23547/23
549/16561/14561/21562/24563/25
564/21565/19566/18566/23567/22
569/14570/5574/15575/10578/25581/13
581/22589/13592/3593/5593/20594/2
Twist [3] 485/13485/22608/12
two [61] 500/2502/6502/6506/7512/13
547/9549/24552/15553/3553/4553/10
568/12577/21578/1578/2591/8591/9
591/12621/16636/7637/14638/24639/12
640/6640/10644/1644/7645/8646/19
649/23653/8653/14653/22664/9667/6
676/21676/22686/14698/12698/18
700/13703/11709/25711/15711/16
711/21711/24717/7717/9727/13728/14
729/8729/19729/22739/8739/8747/25
748/13754/24755/2756/4
two-day [2] 502/6502/6
two-page [1] 500/2
two-part [1] 754/24
type [12] 491/6503/18543/2558/4559/8
623/11626/23656/1701/7701/8753/4
753/14
types [1] 496/17
typewritten [1] 762/12
typical [1] 638/5
typically [3] 559/17623/22721/24
U
U.S [6] 1/14477/21478/2506/16518/22
518/24
U.S. [17] 496/5496/6499/3500/18
500/24501/2501/3504/15510/22513/13
513/15513/20515/1553/21557/15708/25
733/19
U.S. businesses [1] 515/1
U.S. citizen [3] 513/13513/15513/20
U.S. during [1] 500/18
U.S. employees [1] 553/21
U.S. federal [2] 501/2501/3
U.S. Government [1] 500/24
U.S. operations [1] 510/22
U.S. president [1] 504/15
U.S. Small [2] 496/5496/6
U.S. Treasury [2] 499/3708/25
U.S.-based [1] 733/19
uh [1] 651/14
uh-oh [1] 651/14
ultimately [10] 493/15544/4578/23
591/20591/21595/13603/5690/20690/20
694/5
Um [1] 615/6
Um-hmm [1] 615/6
unable [3] 594/25727/22728/3
unanswered [1] 480/23
unauthorized [4] 488/24534/2536/21
554/20
uncertainty [2] 510/11557/6
uncommon [2] 659/5659/6
under [53] 500/25514/18520/3520/20
522/12527/10527/12532/23532/24
547/17554/17599/18610/24626/10637/9
641/9643/7645/18650/2675/5677/1
679/10679/16684/11686/4689/12689/18
691/16692/24693/2693/14697/21702/19
703/2703/4703/21707/2711/17713/11
713/16714/10714/17716/2716/2716/13
718/17718/21718/24720/7723/22730/12
732/12741/5
underline [1] 747/18
underlying [1] 674/6
underneath [2] 702/17727/2
understand [13] 483/8483/9487/14
491/25516/20532/22547/15554/19556/3
600/17665/16667/10731/1
understanding [2] 550/18680/25
understands [1] 658/21
understood [5] 482/2492/3494/9536/3
579/3
underwrite [2] 503/1504/5
underwriter [1] 540/11
underwriting [5] 504/5540/15559/13
559/15560/3
unemployment [4] 721/22722/1722/2
722/5
unfreeze [1] 591/21
unfrozen [2] 588/19590/9
unique [1] 702/10
UNITED [38] 477/1477/3496/16498/6
498/7501/12510/3510/21512/19512/22
513/5514/7514/21515/2522/23525/3
525/10525/11525/21525/24525/25
550/15550/20551/9551/12551/18552/9
554/2557/19557/23575/15614/7741/21
750/13755/14756/23762/5762/9
United States [29] 496/16498/6501/12
510/3510/21512/19512/22513/5514/7
514/21515/2522/23525/3525/10525/11
525/21525/25550/20551/9551/12551/18
552/9554/2557/19557/23575/15614/7
741/21750/13
unknown [1] 621/25
unless [5] 527/10537/10753/13753/18
754/15
unlike [1] 679/3
unopposed [1] 482/3
unpaid [1] 715/5
unpublished [1] 750/14
unreasonable [1] 601/12
until [11] 481/17494/20498/12498/18
572/22585/20629/16700/5706/9718/11
720/14
untrue [1] 561/12
unusual [1] 601/12
up [79] 481/8506/4508/20512/1512/2
512/4515/16517/16532/11535/24539/16
541/25545/22546/24550/7551/20572/21
574/3579/4580/19581/1589/15589/24
589/25590/13592/8597/1601/3609/9
613/19614/22616/2629/15630/10633/21
634/12641/14641/16643/5645/15647/18
648/12649/6651/5655/18662/7663/17
668/17675/17680/18682/21689/23
691/10693/25697/2697/7698/16698/17
698/18699/15700/9701/10701/13705/23
705/25708/13710/19715/17716/21
718/13719/4719/7726/8726/20727/17
727/23728/6751/15753/17
updated [5] 533/9533/10534/6746/18
750/8
upon [7] 484/23486/3491/4491/15
493/14605/3605/18
urgency [1] 559/1
us [13] 572/10606/19614/23615/19
632/1636/6648/1648/11652/21655/6
701/16745/5759/7
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 321 of 324
U
use [41] 489/11503/21519/5519/9
519/10519/12520/24521/3521/7521/11
529/12529/19530/11531/18531/25532/2
532/4532/7534/1536/11537/14537/23
546/6555/3556/25582/17583/5583/11
611/25615/14618/12644/16652/18653/1
653/5653/8700/1732/4754/7754/16
754/20
used [67] 1/13481/2483/23488/23
488/24496/7499/17499/25504/19509/3
514/13517/21517/24518/4518/5518/18
518/22518/24519/1519/16519/18537/17
538/2542/17551/8554/12554/13554/19
555/6555/9555/13555/17556/4556/7
556/14556/16556/22557/15561/7583/16
605/20605/22612/17612/18627/20
628/15637/18639/15645/23651/25
673/20673/25674/20676/2683/22690/10
690/17701/7710/25711/22712/12712/15
719/21720/13725/9750/9751/10
user [20] 617/5617/5618/21618/22
618/24620/15622/22622/24623/2623/10
623/23632/13632/15632/15657/24
658/12658/13658/17658/25661/22
user's [1] 628/23
user-friendly [1] 658/12
uses [6] 536/21617/7652/22657/19
676/2696/25
using [15] 487/14487/24580/5582/23
606/1615/20618/1638/4639/24646/7
647/2655/16711/15718/9742/17
usually [5] 496/19751/22751/23758/21
758/24
utilities [4] 518/2518/7554/8554/15
utilized [1] 606/11
V
validity [1] 575/9
varied [1] 543/16
variety [1] 654/24
various [3] 518/18617/12627/16
vehicles [4] 519/16521/8529/21555/13
verification [7] 503/18503/24504/12
520/9520/11558/4559/8
verify [4] 504/5558/15690/13690/14
Vermont [1] 526/4
version [6] 534/9746/15746/18747/15
747/17748/10
versions [1] 617/12
versus [1] 639/16
very [26] 528/14531/14538/15576/15
607/20613/11621/15622/12633/7660/11
660/11662/5669/20683/7700/23702/2
702/2731/15735/8736/4736/17736/17
737/15738/9745/12747/5
victim [13] 481/25487/9487/10489/3
492/22635/9635/10635/11755/7755/8
755/16755/20756/11
victim's [2] 635/7755/5
victims [3] 482/1482/14483/6
violate [2] 600/9600/13
violation [1] 481/6
volume [2] 477/5499/20
VP [1] 667/24
W
W-2 [58] 629/20630/22631/7640/20
642/9642/10642/12642/21642/23642/25
645/24648/22673/20674/1686/13687/7
695/24696/5696/5696/7696/9696/14
696/18696/24697/6697/7697/8698/25
699/3699/25703/3703/25703/25704/4
704/7704/8704/9704/10704/14704/16
704/17704/19711/12713/17719/1719/10
719/12719/13719/19719/21720/13
729/13731/17737/19738/23739/4742/22
742/24
W-2s [11] 698/20704/12719/3729/2
738/16738/19738/22742/20742/23
742/25743/3
W-4 [1] 618/2
wage [9] 701/18702/24703/1703/18
703/20704/13718/16718/18718/23
wages [20] 565/10567/14567/17569/8
569/24684/9684/11684/13693/18694/1
694/9694/21696/2696/21696/23712/23
718/22719/17722/14722/19
wailing [1] 595/22
Wait [1] 516/6
waiting [1] 494/18
walk [5] 540/6617/11623/4671/22685/3
walked [1] 623/4
walking [1] 623/9
want [48] 480/11480/11480/15480/17
481/4482/15489/17489/22490/1492/16
492/22494/1494/4494/6494/10530/18
530/19530/24530/25534/2535/10535/18
536/1536/19571/23594/9603/11603/15
607/14613/15617/1633/15635/20636/3
651/18658/20705/3705/9705/16746/8
747/6747/9752/23753/25755/19758/16
760/14760/16
wanted [20] 481/10481/10481/18
492/18493/10494/21500/20502/15
504/24510/14519/22519/23542/6559/20
596/3691/20705/1709/20754/1759/5
wants [5] 526/2616/17687/15756/15
756/15
warmer [2] 637/2637/4
was [660]
washed [1] 710/8
wasn't [15] 482/4486/1486/4486/6
491/10523/1529/16529/16533/6607/18
622/13729/6750/25759/1760/18
Watch [1] 538/19
watched [1] 662/22
watching [1] 495/11
water [1] 671/6
way [38] 480/11489/16489/22490/12
490/21492/4533/5536/2537/6537/25
553/13613/25617/18619/7620/7620/11
635/6636/1637/1649/20655/2657/15
658/14661/3680/19702/11707/1726/1
752/6752/23754/23756/6756/6757/10
757/11757/22757/24759/2
ways [4] 677/25690/5732/17755/25
we [334]
we'd [1] 737/4
we'll [28] 490/18535/21535/21550/6
550/25556/15567/24571/19571/25
585/17610/5633/5635/23636/6636/7
637/3663/22675/4675/7705/10705/25
723/15745/10746/5749/4756/7760/2
760/3
we're [42] 482/16483/20484/25490/16
490/23491/17492/20493/5494/23538/13
539/25550/11572/22590/12605/8610/1
615/25627/19634/4637/1637/4639/16
645/4646/5663/15692/14705/17709/13
709/13724/8739/8744/23745/2746/16
748/14753/13753/16757/11757/11
757/12758/16759/15
we've [10] 539/17571/18597/19649/2
654/17709/21721/2728/17744/24745/2
wear [1] 518/2
web [2] 576/2576/9
week [1] 667/6
weeks [6] 559/4579/17581/9581/10
672/9686/14
weird [1] 757/9
welcome [1] 672/18
well [57] 484/16485/5486/17489/24
496/8497/6498/15499/10506/11521/18
525/12533/11534/19543/11546/8549/25
560/3560/4561/1561/24571/8575/2
599/24603/5605/14606/10634/12639/4
655/24658/2659/15668/1668/9673/2
673/15675/4683/25686/7688/10690/1
693/23704/11713/13729/10731/6731/10
749/11750/2752/22753/3753/23754/13
755/25756/7756/17757/20759/20
went [25] 497/19523/15527/24559/23
577/19598/20599/21624/16640/9647/7
650/12650/23652/1652/13652/16656/12
661/6661/8661/12661/23669/21673/14
698/22703/5732/2
were [247] 481/18482/1484/9490/13
491/8491/9492/21493/13493/24494/20
495/11497/18498/11498/13499/3500/2
500/7500/20500/21501/4501/14501/17
502/7502/12502/20502/24503/5503/18
503/21504/12504/16504/18505/10
505/10505/13505/13506/20506/22
507/16508/4508/15510/25511/18511/21
511/25512/3512/15514/16515/6515/25
516/4517/20520/20522/21523/3523/4
524/24525/2525/2525/2526/11526/14
529/12529/17529/19529/21529/23530/1
530/8530/25531/5531/11533/9534/6
534/6534/8534/11534/12536/20537/7
537/14537/20537/22537/22540/24
541/10541/20542/9542/19542/21543/5
543/6543/11549/23549/23550/21551/8
555/2555/8555/12555/16556/4556/7
556/21557/14557/14557/14558/1558/4
558/10558/19559/18560/2560/6560/23
560/24564/6564/6564/7564/9565/20
571/8573/10576/11577/21578/1578/2
579/2579/25580/1591/1591/2591/3
591/9591/14591/15599/23600/23601/8
604/9604/21605/2605/2605/5605/6
605/12605/18606/10607/13607/21
607/23607/24610/1610/5610/9610/11
611/11615/7624/23638/14638/25641/18
644/7644/8644/14645/11652/10652/14
652/15653/23656/21656/22656/22
659/12660/16660/18669/9671/23672/9
673/15673/17676/17676/22677/8685/23
685/24688/4688/12688/14689/9693/12
694/21694/21697/18697/21698/2699/11
699/12699/25700/5706/4706/17706/18
708/6709/22709/25710/14711/21712/22
714/6716/12719/11721/6723/3723/10
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 322 of 324
W
were... [32] 725/17725/20725/21726/2
726/9726/15727/19728/1728/14729/25
731/9731/18732/8733/18737/25740/4
740/5740/20741/1741/16741/19742/5
742/10742/20743/8743/11746/14750/15
754/5755/22761/14762/11
weren't [3] 529/9529/13661/2
Westcreek [8] 664/11664/16664/25
665/5665/8665/23666/12669/13
wet [1] 690/2
what [362]
what's [23] 492/10505/16535/24537/9
552/19566/2596/18597/1606/17620/4
620/5621/16623/17642/22650/9663/13
677/24684/18690/10706/11747/2749/22
753/16
whatever [5] 698/14703/5710/5718/9
754/9
when [96] 493/16494/22497/12497/15
497/18497/20497/22501/15501/19508/4
508/7511/24513/22515/14516/22523/12
525/9528/3528/5531/17536/20540/25
542/10542/13542/13547/7558/21558/22
559/15576/6583/20584/6584/13587/18
589/11589/11590/8591/1591/1594/14
598/17603/5604/2605/14607/6607/10
610/15615/25616/3616/23617/19619/20
619/20627/9627/11632/10632/19632/25
638/7638/11650/4657/9660/22662/22
665/8665/14666/2668/4675/13676/4
686/6687/23693/20694/12695/11698/10
698/18700/16700/17700/20704/10
717/19732/11733/10735/13736/5740/25
741/3741/3745/3745/6746/16758/4
758/16758/25759/1
whenever [1] 480/13
where [74] 489/2493/23495/12496/4
496/10496/14497/18498/4512/15515/25
526/1526/5528/14539/13542/2546/17
546/25546/25547/10547/11547/24
549/16552/22561/21562/24564/1576/18
579/11589/13598/24599/2599/21614/23
615/23617/17617/20622/1622/10623/3
623/4628/22632/21641/24643/23657/12
663/6663/20664/20668/25671/8677/5
678/9680/3686/13694/2695/18696/2
700/14700/15719/13739/10746/14747/8
747/15748/14749/5750/9750/15752/1
752/25753/17754/20757/20758/20
where it [1] 562/24
whereas [1] 679/16
Whereupon [23] 494/14533/20533/24
536/13536/14571/22572/2572/15585/18
585/22595/20596/7613/20614/3633/12
636/15636/23705/12705/15705/19
745/14746/10761/14
wherever [1] 576/11
whether [18] 484/24490/17491/1493/2
497/2513/5526/11530/23530/24556/13
598/22634/4669/9675/1686/9696/11
725/17741/16
which [53] 482/25484/10486/22489/3
497/7498/17499/16504/17504/24505/23
518/17520/20527/17543/12547/20
560/23561/1574/4575/24577/3578/7
579/4579/9585/2586/21587/13587/19
588/23589/25590/16590/20591/9591/14
592/17593/5593/20594/9645/11649/23
659/18663/16674/14678/23692/6698/20
743/16747/9747/9750/13751/25752/13
754/25755/4
while [3] 613/15654/17665/23
white [1] 699/17
who [53] 480/8490/7490/9502/15
503/15506/15513/15513/15514/6524/25
527/6541/24542/24546/9546/9546/11
554/2561/19562/22564/1564/4564/4
565/4566/6566/7566/7567/22568/19
569/14570/5574/15580/10580/10581/24
582/4585/12585/12606/13606/13606/16
618/22631/6657/13667/25670/7681/3
690/24691/19715/5732/16733/12741/20
742/2
who's [2] 662/7664/5
whole [12] 519/13519/13519/14528/20
528/22541/23601/2655/20680/19687/5
695/24758/24
whom [2] 509/19548/24
whose [9] 547/1547/19549/2549/3
554/22631/7664/3684/1690/17
why [55] 482/18486/25491/23492/7
493/9500/17501/10504/12507/19508/9
510/13511/5512/20512/24514/1514/1
514/25519/20520/16533/17533/22536/4
536/5546/15548/10550/18555/1558/25
578/25579/1582/20583/4583/10583/15
593/2598/23599/6602/23602/23603/3
603/16610/17620/12629/6634/12667/24
669/15678/4689/20700/7716/23750/6
752/6752/19758/1
will [76] 1/3483/24483/24487/13487/23
488/10488/23488/25492/1494/23495/20
518/4518/5518/17534/3536/8536/8
536/21537/2539/4546/24551/20554/12
554/13610/3614/14617/22621/4621/16
621/25622/1622/2627/13630/9630/17
636/11638/20643/5646/2647/16648/18
648/19649/6660/2662/17668/2670/19
671/5671/13676/6676/12678/22678/23
684/24687/9689/6690/8692/15700/10
703/6703/9704/13704/17704/22706/16
709/14710/17711/19733/7734/12748/19
748/23756/23756/25758/15759/16
willful [3] 751/16752/1753/4
willful-type [1] 753/4
willfully [9] 749/20749/21750/10750/24
751/7752/12752/22754/6754/9
willfulness [6] 750/16751/19751/20
751/22752/4753/17
Willis [2] 609/4612/24
Wilson [4] 630/17631/25645/20648/18
winnings [1] 703/3
wire [15] 492/24583/1653/23653/24
732/20733/21734/12750/17751/2752/1
752/7752/16753/11755/1758/24
wired [2] 733/2733/19
wires [1] 733/16
wiring [1] 732/23
wish [1] 669/25
withdrawal [2] 579/20579/21
withdrawals [1] 592/7
withdrawing [2] 531/5584/10
withheld [14] 567/17685/4685/20
696/23713/16713/25721/7722/9722/20
722/21723/3723/12723/19725/22
withhold [9] 562/6562/12563/5563/11
567/19568/14568/16569/11570/2
withholding [5] 695/6695/16696/3
734/7741/6
withholdings [42] 563/22685/23686/3
686/6686/8686/15686/15686/22686/24
694/18694/23695/21696/22697/1702/21
703/3703/22708/6710/11713/13713/14
713/18713/24716/12716/13716/18721/5
721/5722/7722/20723/8723/10731/20
731/21731/24732/1737/19741/5741/17
742/10743/11743/17
within [8] 509/4552/17582/22618/4
729/19750/8751/23752/15
without [3] 508/22561/2675/9
witness [30] 479/2481/15484/1484/6
484/7488/15495/7495/17533/3533/24
534/25535/3535/4535/7536/13538/21
538/25556/12572/9613/9613/12614/5
614/10636/20662/13670/7670/15672/15
674/21760/2
witnesses [1] 748/13
woman [3] 480/8486/24486/24
won't [3] 687/9687/9700/12
wonder [1] 670/4
wonderful [2] 654/15669/24
Woops [1] 649/19
word [13] 587/16587/17659/20731/21
750/18752/20753/18754/14754/15
754/20754/21756/25757/1
wording [1] 756/24
words [2] 612/1629/16
wore [1] 494/24
work [22] 486/14496/4528/11528/13
539/13539/14540/10542/7563/18610/21
614/25615/9615/20615/22663/6663/7
671/10686/12688/12689/25745/9760/2
worked [5] 486/8486/9486/16493/21
514/6
worker [2] 518/9554/16
worker's [1] 554/10
workers [12] 488/23500/9500/12500/14
500/17512/21514/3518/5518/18518/22
525/2554/13
working [4] 499/13526/11541/7733/18
works [5] 571/14632/18652/21695/9
696/17
worried [1] 480/8
worry [1] 749/3
worse [3] 635/10755/7755/20
worth [1] 752/5
would [282] 480/16482/18483/2483/4
485/4485/10485/11485/12485/13485/14
485/21485/21486/10486/20486/21
489/11491/1492/7493/17495/8496/20
499/25501/6502/15502/17502/17502/22
503/6503/11503/13503/15504/4504/23
505/7506/25509/3509/11510/3510/22
511/23513/4513/18514/7514/8514/8
514/11514/22515/3515/12515/13516/24
517/2519/13520/3520/6520/7520/7
520/8520/8520/9520/11520/12520/14
524/2524/3524/12524/13525/24527/10
527/14527/19528/4528/6528/7532/3
532/17533/16537/13541/23542/3542/7
542/14542/14542/16545/11549/13551/3
551/12552/3553/21554/3555/10555/13
555/17555/24556/10556/10556/13
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 323 of 324
W
would... [184] 556/22557/9557/19
557/23559/5559/22560/1560/5560/9
560/9561/2561/12562/9562/15563/8
563/14563/18563/23564/12564/19
564/19566/19569/14570/25571/13
573/24575/18576/2576/12579/9582/23
583/2583/4583/8583/12584/10596/17
597/9599/25600/2600/6604/6604/6
613/5613/17615/20616/23618/6618/10
618/12618/24619/8619/9619/9621/19
622/7622/8623/10623/22623/23624/3
624/10625/2626/22626/25628/23628/25
632/12632/14632/15632/19632/20
632/20632/23632/25632/25633/1633/1
636/4639/6647/11649/4656/2656/9
656/9659/25661/3661/4664/5664/9
665/25667/11668/6669/10669/12670/5
671/17671/18673/1674/13674/15674/17
674/21676/9677/16680/11681/7681/21
682/24683/2688/18688/19691/17693/21
694/14696/14696/15698/20699/4699/6
699/7699/10699/10701/18702/17702/21
703/4703/23703/24704/1704/3705/6
707/7707/10709/2709/5711/6711/16
711/23711/25712/14715/6723/13723/14
724/2732/22732/22733/9733/16733/16
733/20739/5741/23742/10742/13742/14
743/5743/21745/21748/20748/20749/2
749/18750/13750/17751/18752/4752/19
752/20753/24753/25754/18754/19
755/16755/17755/23755/24757/9757/18
757/22757/23757/24758/2759/3
wouldn't [14] 482/23484/9485/3505/16
572/9596/3636/4658/3659/24659/24
661/6739/4752/24752/24
write [1] 733/4
writing [4] 498/14594/17603/11757/3
written [6] 582/1582/4582/8582/23
584/19603/11
wrong [9] 489/10492/9492/10601/25
621/16623/17661/18711/13731/12
Wyllys [1] 611/4
Y
y'all [25] 490/8494/15495/1533/17
534/21535/23536/15571/23572/16
595/16595/21596/8602/11625/18633/15
633/22635/11636/16636/24653/5705/20
745/9745/15745/16746/13
Y2020 [1] 626/25
yacht [5] 530/2530/8555/17556/8
583/12
yeah [60] 485/9490/15491/20507/13
516/21533/6534/20534/23543/10547/25
548/1548/15549/11550/7575/11575/11
576/17577/23579/22579/23611/22
615/23617/7618/9618/11618/11618/24
619/14620/18621/5622/18622/24623/18
624/23627/13631/11632/9632/18633/17
640/18644/14647/6652/22654/21656/9
658/19659/8660/12661/16684/7709/19
735/3738/5747/20747/23748/17750/7
754/1754/4760/24
year [59] 515/12526/3526/4527/25
548/7548/10563/1563/1565/7565/11
566/14566/15627/2629/21632/5632/11
632/12639/8640/21643/11644/5645/4
645/4646/16649/12649/25661/19670/12
671/15671/19677/21684/15686/4686/10
686/17687/1690/7696/8697/1698/7
699/13700/6700/6701/20702/8702/9
702/18706/15706/20706/23707/24
714/19718/25719/2724/3736/3736/4
740/16750/8
yearly [1] 722/4
years [13] 540/5540/9540/14540/16
615/2663/12667/6671/13672/2672/14
710/1733/2740/12
yellow [1] 647/11
yep [1] 692/15
yes [478]
yesterday [3] 481/9507/4749/3
yet [2] 490/23753/22
you [931]
you'd [1] 637/21
you'll [8] 631/25635/3645/20648/12
678/13686/23699/16712/20
you're [73] 483/14486/9489/5489/13
493/16518/10522/6525/15526/8531/18
531/22532/2535/2535/3537/14552/24
576/14603/11607/3614/23615/24615/25
616/1616/3617/4619/1619/20619/20
619/21620/2620/3621/10632/19656/25
656/25656/25657/8658/9659/11659/11
662/25667/10667/14667/14667/20671/8
672/18686/15690/1691/25692/1694/17
696/11699/11710/6710/21714/17716/16
722/14732/14733/23734/23736/2736/4
736/4736/5736/7750/11753/3753/21
756/4756/12757/5
you've [11] 487/9540/6540/20608/6
612/13623/14627/11678/25685/2692/18
710/10
you-all [14] 480/10480/18490/11494/22
633/7634/18634/20634/22744/24745/12
747/6747/9747/11760/14
young [1] 480/7
your [177] 480/19481/20481/24488/12
489/10489/14490/23492/18493/9494/5
495/6495/21496/22496/25497/12497/22
498/13498/19499/8505/16506/9511/25
525/23527/5529/12529/24531/5535/4
536/2537/21537/25538/19538/21539/4
541/6543/5544/18545/9546/24550/18
555/20556/4566/6566/6571/1572/4
572/17576/18584/14587/2593/4593/12
593/14594/6594/17595/4597/9600/8
600/8600/12613/12613/13614/5614/6
614/14615/3615/24616/5617/12617/21
617/21618/10619/13619/13619/22624/7
624/19625/2629/7629/8629/8633/3
634/24635/12636/9636/17643/5653/11
653/21654/1655/3656/7657/24657/24
657/25658/2659/11660/2660/2662/1
662/3662/17663/13670/7670/8670/19
671/14672/9673/1673/7673/23674/13
674/15674/18674/23675/11675/16
680/25683/8683/13685/6686/13686/14
686/14686/22686/22686/24689/21690/1
690/2690/7690/8690/19690/24690/25
691/3691/20691/21691/25694/3703/3
705/1705/5705/9705/22706/14706/16
709/13710/4710/6710/9713/17722/20
723/7732/15733/1737/24741/13742/19
744/11744/19744/22746/6746/17746/18
747/17748/23749/8751/4751/8754/6
755/15759/8760/5760/9760/17761/11
Your Honor [41] 481/20481/24492/18
506/9555/20572/4597/9613/13614/6
624/7625/2633/3634/24635/12636/9
636/17653/11653/21654/1662/1670/8
673/1673/7674/18674/23675/11675/16
705/1705/22741/13744/11744/22746/18
748/23751/4751/8755/15759/8760/5
760/9761/11
yours [2] 625/16760/7
yourself [1] 735/14
Z
zero [12] 554/2554/4592/21598/2696/6
707/15708/1713/25723/5736/19736/22
738/10
zeroed [1] 694/16
zoom [28] 512/8512/8550/25561/23
565/25566/11567/24588/23630/18
631/25641/23642/6643/7648/19663/22
664/2682/20683/25684/6689/5695/24
699/16701/23708/22714/24719/6722/24
736/15
Case 1:22-cr-00171-MLB-RDC Document 266 Filed 02/10/26 Page 324 of 324File and source
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- 1,518,654 bytes
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