Court filing
TRANSCRIPT of Proceedings (Jury Trial) as to Carl Delano Torjagbo held on 07/24/2025,… — USA v. Torjagbo (Dkt. 267)
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. 267 · 2026-02-10 · Docket on CourtListener
Summary
Volume 4 of the transcript of jury trial proceedings for July 24, 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. 267, filed February 10, 2026. Kelly K. Connors and Nicholas L. Evert appear for the plaintiff and L. Burton Finlayson for the defendant. A special agent with the FBI testifies that he opened an investigation in January of 2022 after a PPP loan of about nine and a half million dollars to Kremkov Industries came to his attention, and that the company was incorporated January 4th of 2021 and registered as a goldmining company in Georgia. He describes subpoenaing records from Chase and identifying accounts at PNC Bank. The transcript runs to 359 pages.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
1
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
The following is the PDF of an official transcript.
Official transcripts may be filed in CM/ECF only by the
Official Court Reporter and will be restricted in CM/ECF for a
period of 90 days.
You may cite to a portion of the attached transcript
by the docket entry number, referencing page and line number,
only after the Court Reporter has filed the official
transcript; however, you are prohibited from attaching a full
or partial transcript to any document filed with the Court.
- - -
Stenographic Court Reporter Note:
No AI technology was used in the preparation of this
Official Certified U.S. District Court transcript.
- - -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 1 of 359
763
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 4
CARL DELANO TORJAGBO
)
also known as
)
KARL LUCIUS DELANO,
)
)
Defendant.
)
_______________________________)
--------------------------------------------------------------
BEFORE THE HONORABLE MICHAEL L. BROWN
TRANSCRIPT OF PROCEEDINGS
JULY 24, 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
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 2 of 359
764
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)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 3 of 359
765
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
INDEX TO EXAMINATIONS
WITNESS PAGE
SCOTT CARAUNA
Direct Examination By Mr. Evert
767
Cross-Examination By Mr. Finlayson
840
Redirect Examination By Mr. Evert
874
Recross-Examination By Mr. Finlayson
878
Further Direct Examination By Mr. Evert
881
ADRIENNE RICHARDSON
Direct Examination By Ms. Connors
882
Cross-Examination By Mr. Finlayson
938
Redirect Examination By Ms. Connors
949
THOMAS THURMOND
Direct Examination By Mr. Finlayson
968
Cross-Examination By Ms. Connors
970
SOLOMON OWUSU
Direct Examination By Ms. Connors
971
Cross-Examination By Mr. Evert
975
KARL DELANO
Direct Examination By Mr. Finlayson
984
Cross-Examination By Ms. Connors
1040
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 4 of 359
766
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
_ _ _
P R O C E E D I N G S
(Atlanta, Fulton County, Georgia, July 24, 2025, in open
court.)
THE COURT: All right. Y'all can be seated.
All right. Everybody ready?
MR. FINLAYSON: Yes, sir.
THE COURT: You all should have a copy of the jury
instructions. I'm going to think about today where to move
them to, how to move them around. We're going to talk about
them right after lunch. Okay?
So between now and right after lunch, make sure that
you go through them and have any final requests for changes or
things like that. They're your instructions, so if there's
anything you want to change, let me know. If there is
something out of order, let me know. Although I'll be
reshuffling the order, but if there is any problem with it,
let me know. Okay?
All right. You can bring them in.
COURTROOM SECURITY OFFICER: Yes, sir.
MS. CONNORS: I'm sorry, Judge.
THE COURT: Yeah.
MS. CONNORS: One thing I wanted to follow up on is
yesterday we moved to admit two summary exhibits. And we
ended up leaving it at we were going to resolve it, we
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 5 of 359
767
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
certainly don't have to resolve it right this second, but just
wanted to make sure that we do.
THE COURT: Yes. That's just an issue of whether
they will go back to the jury or whether they were just for
use with that witness. We'll talk about that. Okay?
MS. CONNORS: I appreciate it, Your Honor.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. Y'all can be seated.
Everybody good? Any problems, concerns?
Okay. All right. Call your next witness, please.
MR. EVERT: The government calls Scott Carauna.
- - -
SCOTT CARAUNA,
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: My name is Scott Carauna.
C-A-R-U-A-N-A.
COURTROOM DEPUTY: Thank you.
DIRECT EXAMINATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 6 of 359
768
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MR. EVERT:
Q.
Good morning, Special Agent Caruana. Where are you
employed?
A.
Good morning. I'm currently a special agent with the FBI
in the Atlanta division.
Q.
And are you actively working?
A.
I am not. I am going through the retirement process.
Q.
And when you were actively working for the FBI, what was
your title?
A.
I was a special agent and I've been an special agent for a
little bit over 23 years. I worked on the complex financial
crimes squad. And I was on that squad for my -- the entirety
of my 23 years.
I worked violations which included mail fraud, wire
fraud, bank fraud, money laundering, the PPP program, or PPP
fraud, payroll protection program, investment fraud, Ponzi
schemes, just to name a few.
Q.
And prior to your work at the FBI, do you have any work
experience that would be relevant to a case like this?
Q.
I do. I was a certified public accountant. I worked at a
global accounting consulting firm for about eight years where
I worked in the tax compliance and tax consulting section and
left there after about eight years as a senior manager to
become a special agent with the FBI.
Q.
And are you familiar with a case involving Karl Delano,
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 7 of 359
769
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
formerly known as Carl Torjagbo?
A.
Yes, I am.
Q.
Do you see Mr. Delano in the courtroom today?
A.
I do. He's at the defense table in the tan suit.
MR. EVERT: Please let the record reflect that the
witness identified the defendant.
THE COURT: Okay. Thank you. It will.
BY MR. EVERT:
Q.
So how -- how were you involved with this case?
A.
So I was the original case agent. And I opened the
investigation back in January of 2022.
Q.
And what led you to start investigating the case?
A.
So around that time of January of 2022, the payroll
protection program, I'll say PPP, fraud was rampant. The
PPP loans that were provided to people were -- it was a matter
of public record, it was presented on the Internet.
So I was perusing the Internet on a specific area,
ZIP code, and going through the pages of pages of PPP loans
that were given. And most of the loans were about in the
$18,000 rage, $18,000 and some change.
And then all of a sudden about a nine and a half
million dollar PPP loan popped up, which kind of struck -- it
just struck my interest.
Q.
Did anything else about that loan cause you to look a
little closer?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 8 of 359
770
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
So that -- that was rather large. And based upon my
training and experience, I knew that a 9 and a half million
dollar PPP loan, it would have to be a substantial company,
size of a company to get a loan that large, because the
PPP loan is based upon the payroll of the employees at a
company.
So from there, you know, I did a little bit more due
diligence before I actually opened the formal investigation.
Based -- based upon public record, the loan was given
to a company by the name of Kremkov Industries. I pulled that
up on the Internet, the Georgia Secretary of State, saw that
it was a relatively newly formed company in the State of
Georgia. It had an address of the -- the principal place of
business for the company, pulled that up on the Internet, it
was a location, it was a very modest residence in
Douglasville, Georgia, which is in the Northern District of
Georgia, which is the area that we cover.
And it just didn't -- it didn't make sense that a
very large -- what should have been a very large company to
get that size a loan was headquartered in Douglasville,
Georgia, in a very modest house and it was a newly formed
company. So from there, we opened up -- the FBI opened up a
formal investigation into Kremkov Industries.
Q.
And was there anything about the type of company that
Kremkov Industries purported to be that gave you pause?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 9 of 359
771
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes. The -- Kremkov was opened up as a goldmining company
in Georgia.
Q.
Are you familiar with many goldmines in the Douglasville,
area?
A.
I am not, no.
Q.
So I'm going to --
MR. EVERT: If we could put Government's Exhibit 1 up
on the screen, please, which is already in evidence.
BY MR. EVERT:
Q.
Is this the -- and then looking at Page 1, can you see the
date of incorporation? It should be in that bottom right-hand
corner there.
A.
Date of incorporation was January 4th of 2021.
Q.
And are you familiar with the requirements of the PPP
program --
A.
Yes, I am.
Q.
-- broadly?
A.
Yes.
Q.
And when were -- when were -- were there any requirements
about when a business had to have been in operation?
A.
So according to the rules, a business had to be in
operation on or before February 15th of 2020. And the date of
incorporation of Kremkov Industries was substantially after
that required date.
Q.
And so did there come a time when you -- you mentioned
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 10 of 359
772
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
there came a time when you opened up a formal investigation;
is that correct?
A.
Correct.
Q.
What did that formal investigation entail?
A.
So with the -- knowing that, you know, with a PPP loan,
the -- the money is provided to the applicant. And from
there, it's just a matter of following -- you know, follow the
money, where did the -- you know, where did the money go to,
what accounts did it go into, the bank accounts of Kremkov and
just follow the monies. Determine what the money was used
for.
Under the PPP program, the -- which was instituted
during the COVID time, the money was supposed to be used
for -- primarily to retain and pay the employees of companies
during that COVID time period.
So it -- it's a paper case and it's follow the money
to see where the money came -- you know, which accounts it
went into and what the money was used for.
And looking for -- to determine whether or not the
money was used to pay for payroll for employees, for the --
you know, and there was a certain other criteria that the
money could be used for, like rent and utilities, that kind of
thing. But for the most part, the money was supposed to be
used for -- to pay the employees during that time period.
Q.
And as part of your investigation, was what you were --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 11 of 359
773
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
did you --
A.
So to follow the money, my first step was to issue
subpoenas to the financial institution which provided the
loan, which was Chase.
I subpoenaed the records, got the financial records,
the banking records from Chase, whatever information they had
related to Kremkov, bank accounts related to people who were
related to Kremkov, whatever -- you know, I prepared a
subpoena, got those bank records where I was able to identify
the money coming into the account.
And then, again, following the money to see where
that money went. And it -- that money was then transferred
into a variety of other different accounts. The first account
was transferred -- was transferred into another Kremkov
account. And then the money was transferred into various
other accounts of the defendant's.
Q.
So in the course of your investigation, did you identify
accounts at PNC Bank related to Mr. Delano?
A.
Yes, I did.
Q.
And if you would look at Government Exhibits 300, that
should be in your binder there, 300A, 300B, 301, 301A to C,
302, 302A to E, 303, 303A, 304.
And these are documents that you've had a chance to
review beforehand?
A.
Yeah.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 12 of 359
774
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
But we'll find them.
A.
There's a different binder.
Q.
And I'll just read them off for the record, 311 through
313 and 315. So I'll read that again, because I know that was
a lengthy list.
300A, 300B, 301, 301A through 301C, 302, 302A through
E, 303, 303A, 304, 311 through 313, and 315.
A.
Yes, these are all records that I used during my
investigation.
Q.
And are these all records from PNC Bank?
A.
Yes.
MR. EVERT: I would move to admit -- and these are
subject to the authenticity stipulation. And I would move to
admit them at this time.
THE COURT: Any objection?
MR. FINLAYSON: No objection.
THE COURT: Okay. They are admitted.
BY MR. EVERT:
Q.
And in the course of your investigation, did you also
identify accounts at Bank of America related to Mr. Delano?
A.
Yes, I did.
Q.
Could you please look at Government's Exhibits 305 and
305A through I.
A.
305A through I?
Q.
Yes. And 305 itself as well.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 13 of 359
775
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Okay. Yes, these are all of the Bank of America records.
MR. EVERT: I would move to admit -- these are also
subject to the authenticity stipulation. And I would move to
admit them as well.
THE COURT: 305 and 305A through I?
MR. EVERT: Yes, Your Honor.
THE COURT: All right. Any objection?
MR. FINLAYSON: No objection.
THE COURT: All right. They are admitted.
MR. EVERT: And I'd also like to read a stipulation
at this time.
THE COURT: Okay. Again, an agreed upon fact that
you have to accept as a part of this case. Okay? A
stipulated fact, and agreed upon fact.
Go ahead.
MR. EVERT: At all times material to the third
superseding indictment, JPMorgan Chase Bank, PNC Bank and Bank
of America were each a financial institution as defined in
Title 18 United States Code Section 20 and it's -- and their
deposits were insured by the Federal Deposit Insurance
Corporation, also known as FDIC. And the parties hereby
stipulate and agree to that fact.
THE COURT: Agreed?
MR. FINLAYSON: Agreed.
THE COURT: Okay. Go ahead.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 14 of 359
776
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MR. EVERT:
Q.
So -- so did there come a time when you invited other
investigation -- other investigative agencies to join your
investigation?
A.
Yes, there was. First off, I invited the TIGTA, which is
the Treasury Inspector General for tax administration, a
special agent of that office assisted in the investigation.
And then at a later date, invited a special agent from the
criminal investigative division of the Internal Revenue
Service.
Q.
And why did you invite those other agencies to join the
investigation?
A.
All a point of the investigation, it expanded from the PPP
fraud investigation into fraudulent filings, which we
suspected -- alleged fraudulent filings of tax returns, so --
well, TIGTA was brought in earlier on because they handled PPP
as well.
But IRS was brought in at a later date once we
discovered the potential fraudulent tax returns that were
filed, or I brought those in when I discovered that.
Q.
And so you mentioned that there was a PPP loan and then
also potentially fraudulent tax return filings.
Were you able to obtain the IP -- was the
investigation able to uncover the IP addresses associated with
the filing of the PPP loan and the filing of the tax returns?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 15 of 359
777
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
The IP addresses were identified. And I requested the
records for those IP addresses. But the company that
maintained -- supposedly maintained them was Comcast and they
don't -- Comcast does not maintain those records for a very
long period of time.
MR. EVERT: So if we could pull up, please, the
snippet of Government's Exhibit 220, which is that Excel
sheet, side by side with Government Exhibit 101B, both of
which are already in evidence. And if we could zoom into that
IP address column on both of these.
BY MR. EVERT:
Q.
So the one on the left is from the tax -- the filing -- is
the IP addresses associated with the tax returns; is that
correct?
A.
Correct.
Q.
And the one on the right is the IP address associated with
the filing of the PPP application; is that correct?
A.
Correct. And you'll notice that they are both the same --
they are the same IP addresses.
Q.
So you mentioned that you weren't able -- that -- I
believe you said -- did you say it was Comcast or the --
A.
I believe it was Comcast. And dependent upon the company,
the service provider, they have retention policies that are
different. Comcast doesn't retain the IP address data for a
very long time.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 16 of 359
778
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
So -- so the data -- so the data indicates that these IP
addresses were both used and that they are the same, but when
you say that they don't retain the data, what would that data
that Comcast might retain be?
A.
So the IP addresses identify a location of where the
service is being provided. And, you know, when -- during an
investigation, you see the IP address, but what is the
underlying data behind that IP address, it's the subscriber
information, it's who -- who the subscriber is, what -- what
the actual location is, whether it's a residence or a
business.
Comcast did not retain that information, so I wasn't
able to identify the true -- I mean the actual subscriber for
that IP address, but noticed that it was a commonality between
the tax returns that were filed in -- you'll have to refresh
my memory with the tax returns, either Mr. Delano's name or
Kremkov Industries' name. I think it was Mr. Delano's name,
because it was a 1040.
And that was the same IP address for Mr. Delano's
1040 was used for the PPP loan, that was applied in -- for in
Kremkov Industries name, which Kremkov Industries is
Mr. Delano.
Q.
Thank you.
MR. EVERT: So if we could take these down please.
And pull up Government's Exhibit 101, which is in evidence.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 17 of 359
779
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MR. EVERT:
Q.
So what is this?
A.
That is the PPP application.
Q.
And on Page 1, there is -- there is listed a -- what is
listed as the business address?
A.
So the -- well, the business legal name is
Kremkov Industries, LLC. The business address is 3081
Leatherleaf Trail in Douglasville, Georgia, 30135.
The primary contact for that industry is
Carl Torjagbo, with an email address of torjagbo,
T-O-R-J-A-G-B-O-C, @gmail.com.
Q.
And are you familiar with the boundaries of the Northern
District of Georgia?
A.
Yes, I am.
Q.
And is Douglasville, Georgia, in the Northern District of
Georgia?
A.
It is.
Q.
And so turning to Page 2, when did -- when did Mr. Delano
submit this?
A.
So it --
Q.
If you look at the bottom there.
A.
The application was submitted on February 16th of 2021.
Q.
And did anything --
A.
Which again is at -- well, yeah, it's February 16th, 2021.
Q.
Did anything about this application stick out to you when
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 18 of 359
780
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
you reviewed it? As part of this application, were there --
was this application the only document that was attached or
did it have other documents attached to it?
A.
So the -- the application is lengthy and a substantial
amount of documents were submitted with the application to
support -- again, the payroll protection or the PPP loan is
based upon the payroll amount.
So in addition with the filled out application where
the defendant acknowledged that all the requirements are met,
a substantial list, I believe it was like 71 pages of 493
employees that Kremkov Industries had was submitted along with
the application to Chase Bank.
Q.
And did any of the names on that list stand out to you?
A.
There are a variety of different names. And perusing the
list, there were a lot of names -- well, a handful of names
that kind of struck me by surprise. One was Keanu Reeves, who
is a -- was a major Hollywood actor, Bruce Willis, another
Hollywood actor, there was Gene Hackman, who was a Hollywood
actor, along with Jason Bourne, Jason Bourne was played
by -- it was a trilogy that was played by Matt Damon in the
movies, so those kind of struck out at me as interesting.
Q.
Did the name Charlie Brown --
A.
Charlie Brown was there.
Q.
Who is Charlie Brown?
A.
Charlie Brown, with Snoopy, cartoon character back in the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 19 of 359
781
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
day.
Q.
How about the name Oliver Twist, did that stick out?
A.
Oliver Twist, Isaac Newton in physics.
Q.
Who is Oliver Twist?
A.
Oliver Twist was -- he was in a play, I guess.
Q.
Is he a character in a Charles Dickens novel?
A.
Possibly.
Q.
All right.
THE COURT: In fairness, he's an accountant, not an
actor.
BY MR. EVERT:
Q.
So excuse me. What year were the payroll records for?
A.
I believe they were for -- you'd have to refresh my
memory.
MR. EVERT: If we could pull up Page 81 of
Government's Exhibit 101, please.
THE COURT: Did you say a play?
THE WITNESS: Yeah, I did.
THE COURT: What play were you thinking about?
THE WITNESS: I don't know.
THE COURT: It might be.
THE WITNESS: I'm thinking -- I don't think -- I
guess Charles Dickens, I was kind of equating those two
together.
THE COURT: I was trying to think if you were going
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 20 of 359
782
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Broadway or something. I'm sorry. I digress.
BY MR. EVERT:
Q.
So what year was this payroll for?
A.
So it was for 2020.
Q.
And then did anything about the EIN number that was
submitted in connection with this application stick out to
you?
A.
So the -- one way TIGTA was able to facilitate and help
through the investigation is they have the information about
the EINs, the employee identification numbers, and it was
determined that that EIN was -- or at least the EIN that was
used by Kremkov was issued by the IRS after that
February 15th, 2020 requirement date for PPP.
Q.
And why was that, why was that significant to you?
A.
Well, again, it shows that the company legally wasn't in
existence after the PPP program had ended.
MR. EVERT: And if we could please put up
Government's Exhibit 201, which is in evidence. And if we
just look at the top of the document.
BY MR. EVERT:
Q.
What is the address associated with this return?
A.
3081 Leatherleaf Trail, Douglasville, Georgia, 30135. And
that's the same address that was on the Georgia Secretary of
State for Carl Torjagbo or Kremkov Industries as well as the
address on the PPP application.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 21 of 359
783
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And turning to Page 17, what date was this received by the
IRS?
MR. EVERT: If we can just blow up that top portion
there, please.
BY MR. EVERT:
Q.
Okay.
A.
So the receive date was February 13th of 2021.
Q.
So the PPP application was February 16th. This was
February 13th, both 2021? Were you able to determine where
Mr. Delano was living during that period?
A.
He was living -- based -- the investigation revealed that
he was living in the Northern District of Georgia.
Q.
How were you able to determine that?
A.
Well, based upon his financial records, his driver's
license had the Leatherleaf Trail address on it. And all the
documents -- well, all the documents that he had filed with
the bank and the IRS showed that Leatherleaf Trail address,
which is in the Northern District of Georgia.
Q.
Did you also look at any transaction data from his credit
card --
A.
Oh, yes.
Q.
-- to determine whether he was making purchases at that
time?
A.
Oh, well, yes. So he physically resided in -- based upon
the bank records, I looked at some transactions during this --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 22 of 359
784
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
like this weekly time period from February 13th through
February 16th. And there were multiple transactions that were
physically made in the Atlanta area, covered by the Northern
District of Georgia.
Q.
Like what kind of --
A.
I remember there was a QT, there was an exotic dancing
establishment, there were -- I'd have to look at the
transactions.
Q.
Any restaurants or -- we can pull up Government's
Exhibit --
A.
I believe there were a couple of restaurants, yeah.
Q.
And then so this is the -- if you look at the statement
period at the top, if we would pull that up.
MR. EVERT: And, yeah, Page 45 of 211, yes, thank
you. Or if you -- I'm sorry, it should be up a little bit
above this.
BY MR. EVERT:
Q.
If you look in the top left corner there, the statement
period?
A.
Yeah, so that's a statement period for the PNC account
number ending 5837 for the period 2/12/21 through 3/14/21.
MR. EVERT: And then if we back out, please.
BY MR. EVERT:
Q.
And then look in the bottom right. Whose name is on this
account?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 23 of 359
785
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Carl Torjagbo with that 3081 Leatherleaf Trail address in
Douglasville.
MR. EVERT: And then if we can turn to the next page,
please. And we can just pull up the top few transactions.
BY MR. EVERT:
Q.
Where are those taking place?
A.
Okay. Yeah, so --
Q.
Looking at February --
A.
February 13th, Fannie's Cabaret in Atlanta, Georgia,
February 14th, and this is 2021, Walmart, February 14th, we
have Kay Jewelers in Douglasville, Georgia, the Walmart was in
Douglasville, Georgia, again Fannie's Cabaret in Atlanta,
Georgia, and then a QT Douglasville, Georgia.
And then even after that, the charges are in the
Douglasville, Georgia area, Lithia Springs, Georgia area,
which all are located in the Northern District of Georgia.
Q.
And you mentioned --
MR. EVERT: And we can take that down. Thank you.
BY MR. EVERT:
Q.
You mentioned that you saw records of him making -- of --
well, you followed the money, correct?
A.
Correct.
Q.
Did -- did you see records of him making a number of
purchases?
A.
Yes, I did.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 24 of 359
786
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
If you would please look in your binder. And I believe
you've had the chance to review these before.
But what's been premarked for identification as
Government's Exhibit 401, 401A, 401B, 402 through 417.
There's another binder up there that might be it,
too. I can help you if you need it.
A.
I've got it here. So 401.
Q.
401, 401A, 401B, and 402 through 417.
A.
I'm sorry, repeat that again, 401A, 401B.
Q.
401, 401A, 401B, 402 through 417.
A.
402.
Q.
Through 417.
MR. EVERT: And these are subject to the stipulation
of authenticity.
MR. FINLAYSON: That's correct.
THE COURT: Any objection?
MR. FINLAYSON: No objection.
THE COURT: All right. They're admitted.
MR. EVERT: All right. Thank you.
THE COURT: Do you want me to go over which ones they
are?
THE WITNESS: No, I've got them here.
THE COURT: All right.
THE WITNESS: Thank you. I appreciate it.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 25 of 359
787
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MR. EVERT:
Q.
All right. And once you've had a chance to look at them,
just let me know and we'll --
MR. EVERT: And while he's looking --
THE WITNESS: Okay. Yes, these are all records that
I obtained throughout the investigation and that I am familiar
with. And these were used to help me follow the money of
where the PPP proceeds went.
MR. EVERT: Understood.
If we could please pull up Page 10 of GX 103.
BY MR. EVERT:
Q.
What account is this for?
A.
So this -- this is the Chase account for
Kremkov Industries with the last four digits of 8755.
MR. EVERT: And if we could please pull up the
deposits and addition section of this document.
BY MR. EVERT:
Q.
What does that bottom transaction reflect?
A.
So on March 29th of 20 -- so 2021 --
Q.
Yeah.
A.
It's the deposit from the Small Business Administration of
the PPP proceeds into the Kremkov Industries' account.
Q.
Is it from the Small Business Administration or does it
just say small business?
A.
It just says small business.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 26 of 359
788
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And you -- you said that that was March 29th of 2021,
correct?
A.
Correct.
Q.
And how much money was that?
A.
The amount of the deposit was $9,554,425.
Q.
And based on your investigation, do you know what the
source of that money was?
A.
It was the proceeds of the PPP loan or the application
that Kremkov Industries obtained.
Q.
And let's --
MR. EVERT: If we could turn to Page 7 of
Government's Exhibit 301.
BY MR. EVERT:
Q.
And then looking at the top right corner, who is this
account for?
A.
So that's an account for Kremkov Industries, last four
digits of 9499, and I missed the bank on the first page.
MR. EVERT: If we can zoom out and go back one page.
THE WITNESS: I believe it's PNC. Yeah, PNC Bank.
MR. EVERT: And then if we could jump back, the
transaction on 4/27, if we go down -- down a little bit. Next
section down to the deposits.
BY MR. EVERT:
Q.
So the transaction on 4/27, do you know what that
transaction was?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 27 of 359
789
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yeah. So that $3,366,240.76 deposit was the refund that
the IRS issued to the defendant based upon that 1040 tax
return that he filed.
Q.
And just above that there is another $3 million deposit.
Were you able to tell where that came from?
A.
I did. That was a check that was written -- written from
the Chase Kremkov account to Kremkov Industries, it was
written by Kremkov Industries to Kremkov Industries from a
Chase account and deposited into a PNC account Of
Kremkov Industries.
MR. EVERT: If we could pull up Government's -- if we
could pull up Government's Exhibit 301B, which is already in
evidence.
BY MR. EVERT:
Q.
Is that the check you were just talking about?
A.
It is.
Q.
So --
A.
And what stood out on that is that the -- in the memo line
or on this check, the for line, it indicates payroll. And it
stood out because, again, in my training and experience, this
was a PPP loan, it's supposed to be used to pay for payroll
and so if payroll is written on this check as a transfer or a
deposit, theoretically, it's not going to cause any red flags.
Q.
Was there anything about the Chase account that led you to
believe that Mr. Delano would have been unable to pay payroll
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 28 of 359
790
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
from that account?
A.
If I remember right, the Kremkov Industries' Chase account
really had no money in it prior to the deposit of the PPP
proceeds.
Q.
And during your time as an FBI agent, have you
investigated how people conceal the source of their funds?
A.
Multiple transfers is standard in -- to conceal sources of
the funds. It makes the tracing of the money difficult. And
a lot -- it's done a lot of times where it's just transferred
from one account to the next to the next and then kind of like
shotgun blasts to multiple different accounts, which is the
same thing that I found in this investigation.
The other thing that -- that I've discovered in -- in
investigating PPP fraud is that a lot -- a lot -- so if a PPP
loan is taken out by a company.
MR. FINLAYSON: Objection. Objection, Your Honor.
THE COURT: Basis?
MR. FINLAYSON: Profile, this is profiling
information, it's not --
THE COURT: Would y'all step out for just a second?
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Okay. Y'all can be seated.
Have I heard the door shut yet? There it is.
Tell me what your concern is.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 29 of 359
791
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. FINLAYSON: And there's been a bit of this. And
it's -- it's profile information, as in other cases there's
this and in this and this. And we've heard a bit of it
already.
But to -- you know, to say -- I mean, I think the
agent should testify what he saw in this case, not what he saw
in other cases. And he's just -- it's trying to create a
profile that -- and I just don't think it's proper to go
there.
THE COURT: What do you say?
MR. EVERT: So, I mean, I think he is testifying and
will testify about what he saw in this case and how that --
and the significance of that to him.
So I think -- you know, I think it's proper to
explain like this is -- this is how money laundering works.
There's layering, there's transactions from account to account
with different names.
I think it's -- I think it's proper for him to
explain based on his training and experience that this is --
this is how this works and why it happens. Because otherwise,
I don't -- I don't know that it's clear what the -- what the
significance of it is.
THE COURT: I mean, I'm not sure that the right word
is profiling.
MR. FINLAYSON: Well --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 30 of 359
792
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: That's not in today's world. Profiling
in today's world sort of has a connotation of grouping people
because of race, ethnicity or something like that. And he's
certainly not doing that.
What he's explaining is the types of things that they
look for in criminal cases.
MR. FINLAYSON: Which is not relevant, I would
submit.
THE COURT: Well, it is, because he's going to
explain how he got to where he got.
MR. FINLAYSON: And I would submit that how he got
there is not what the trial -- what we're here for. It's
where he got and what he saw, what he did. And what he
actually -- and then we've got a lot of why he went there and
how he did it.
And typically an officer's motivations or an agent's
motivations are not -- are not relevant to the trial. And so
I don't think -- I don't think he should be allowed to testify
to every little thing he did and why did you do that. That's
not -- that's not a relevant issue for trial.
MR. EVERT: I mean, I would --
THE COURT: I smelled what I thought was marijuana
coming from the car, so I asked him to step out.
I saw a guy running from a bank, I thought that was
suspicious, so I followed him.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 31 of 359
793
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. EVERT: I know that everybody that runs in
Atlanta smokes marijuana when they're running. I mean, it
seems like they do, but -- or when you drive around, you're
like where is that coming from. But maybe not the best
analogy.
But I think when he starts going into well,
everybody -- all of these other people that I've investigated
did it in this way, it's suggesting that he did it this way.
And also it feels like --
THE COURT: Well, I think he's trying to suggest
that.
MR. FINLAYSON: And I think he --
THE COURT: I mean, the government is trying to
suggest that.
MR. FINLAYSON: Then my other concern about this is
that it becomes expert testimony.
THE COURT: No, I don't think it does. Why would it
become expert testimony?
MR. FINLAYSON: Because he's providing specialized
knowledge that we don't -- that other people don't otherwise
have.
THE COURT: Okay. What I'm going to ask you to do is
I'm going to ask you to ask him in terms of what was he
looking for.
MR. EVERT: Okay.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 32 of 359
794
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: And then why was he looking for that.
MR. EVERT: Okay.
THE COURT: Okay.
MR. EVERT: Yeah.
THE COURT: And I'm going to have you tie it to that.
Okay?
And do you want me to instruct to the jury that they
are to consider what he's looking for only in terms of
understanding what he did and that's the limited reason they
can use that?
MR. FINLAYSON: Sure.
THE COURT: Okay. All right. You can bring them
back in. And let's --
Hold on one second. And let's try to keep it rather
direct in what he was trying to do in this case and why he was
doing it in this case, rather than writ large what people who
are committing fraud sometimes do. Okay?
MR. EVERT: Sure, yes.
THE COURT: I think that's really the relevance of it
is explaining his testimony as to why he might pull a
different account or look at a different account or why this
might mean something.
For example, I think he explained most people get
$18,000, this one was $9 million and that was a reason he did
more.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 33 of 359
795
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Okay. All right. Let's bring them in.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: I'm going to let him ask his first
question and then I'll give them an instruction.
All right. Y'all can be seated.
BY MR. EVERT:
Q.
So you testified earlier that you were looking at
different accounts controlled by Mr. Delano.
What were you looking for when you were -- when you
were looking at -- looking at those different accounts?
THE COURT: All right. He's going to explain a
little bit of why he did some of the things that he did, okay?
And I'm allowing that testimony in order for you to
understand exactly that, why he did what he did and what it
meant during his investigation. But that's the limited
purpose of it. Okay?
You cannot consider it for anything else other than
understanding his testimony. Okay?
Does everybody understand that instruction?
You can't use it more broadly to say that the
defendant must have done what's alleged in this case, it's for
you to understand this witness's testimony. Okay?
Any objection to that instruction?
MR. FINLAYSON: No, sir.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 34 of 359
796
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: From the government?
MR. EVERT: Oh, no, Your Honor.
THE COURT: Okay. All right. Go ahead.
THE WITNESS: So the thing that stuck out to me is
the money, the PPP proceeds were deposited into
Kremkov Industries' account, which is a corporate account.
It was transferred to another Kremkov corporate
account. And then from there, it was transferred into an
individual account, Mr. Delano's, the defendant's, individual
bank account.
And the reason why that was important to me, and I'm
going to try to tread lightly here just because I don't
want -- but what's important is that the PPP proceeds have to
be deposited into the applicant's account, so if it's a
business account, it has to be transferred into a business
account. If it's a business account, it can't be transferred
into -- from the bank into a personal account, the proceeds
would be rejected by -- or the transfer would be rejected by
the bank.
BY MR. EVERT:
Q.
And why is that, what -- what's the -- can you -- can you
explain a little bit more why that is?
A.
The proceeds have to go to the entity that is applying for
the loan. If it's a corporate loan, it needs to go to that
corporation, not to an individual. And that's a red flag if
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 35 of 359
797
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
it -- if a corporation -- if a corporation PPP proceeds are
going to an individual, that's a red flag.
Q.
And you testified that funds ultimately went into
accounts -- went from accounts in the Kremkov name to personal
accounts, correct?
A.
Correct. They went from a corporate account in Kremkov's
name to another corporate account in Kremkov's name to then an
account in the defendant's name.
Q.
And were there accounts in another name as well?
A.
Yes, there was.
Q.
What was that name?
A.
Originally, it was Carl Torjagbo, and then there was --
there were additional accounts in Karl Lucius Delano's name
and then Flying -- FlyingJack Freight's name, which is another
corporation that the defendant incorporated or started.
Q.
And we'll talk more about them in a little bit.
MR. EVERT: So if we could look at Government's
Exhibit 302B, which is in evidence, and turn to Page 1.
BY MR. EVERT:
Q.
Whose name is --
A.
Can I make one clarification?
The personal accounts -- I would have to see the
records, but I'm not quite clear if there were personal bank
accounts in both Carl Torjagbo's name and Karl Lucius Delano's
name, so I correct that. I'm not quite clear unless I see the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 36 of 359
798
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
original bank accounts again.
Q.
Understood. Thank you for clarifying.
So on -- whose name is on this account?
A.
This -- the name on this account is a PNC Bank account in
the name of Carl Torjagbo ending in 9849.
Q.
And on Page 2, below deposits and other additions, can you
please read the entry dated 4/19?
A.
So on 4/19 of 2021, this was a $100,000 online transfer
from an account ending in 9498.
Q.
And if we turn to Government's Exhibit 300B, whose name is
on PNC 4999 -- 9499?
A.
So 9499, the name on the account was Kremkov Industries
with the -- that Leatherleaf Trail address, so this is where
that $100,000 came from, Kremkov Industries.
Q.
And then looking at Government's Exhibit 302C, whose name
is on this account?
A.
So this was the account that the money went into, and
that -- the name on that account is Carl Torjagbo, with the
same address, 3081 Leatherleaf Trail.
Q.
And then on Page 2, could you please read the entry dated
May 11th of 2021?
A.
So on May 11th, 2021, that was a $6 million transfer from
that 9499 account, which was the account in the name of
Kremkov Industries.
Q.
And what was the source of that $6 million based on your
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 37 of 359
799
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
investigation.
A.
That was a combination -- it came from the Kremkov
account, which would have been -- it was the PPP proceeds as
well as the IRS tax refund that Kremkov received.
Q.
And I'm showing --
MR. EVERT: If we could please pull up Government's
Exhibit 401.
BY MR. EVERT:
Q.
What is this?
A.
So that is a -- it's called a settlement statement. It's
a statement that reflects the -- a real estate transaction and
this is dated June 2nd of 2021.
And in this case, a buyer by the name of
Carl Torjagbo with that same Leatherleaf Trail address
purchased a property located at 5114 Greythorne Lane in
Marietta, Georgia. And the -- and that property is located in
the Northern District of Georgia.
And the place of the settlement was in Alpharetta,
Georgia, which is in the Northern District of Georgia. So
this reflects the purchase of a property by Mr. Torjagbo from
the property owner of 5114 Greythorne Lane.
Q.
And just below all of that, what -- what is the contract
sales price?
A.
The contract sales price is $1,675,000.
Q.
And turning to Page 4, please, what is the title of
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 38 of 359
800
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
this -- this document?
A.
So that's a purchase and sale agreement dated April 20th
of 2021.
Q.
And if you look at the bottom of the page, right next to
the buyer's initials, can you see the date?
A.
April 20th of 2021.
Q.
So is that about three weeks after Mr. Delano received the
PPP money?
A.
It is.
Q.
And turning to Page 12 of this exhibit, which was -- which
was -- was this part of this document?
A.
This document up on the screen right now?
Q.
Was this -- was this submitted as part of -- was this
received as part of --
A.
Yes, it was part of the purchase -- or the real estate
package that I subpoenaed reflecting that purchase of that
property, yes.
Q.
And what account is that from?
A.
This is the Chase account of Kremkov Industries ending in
8755.
Q.
And why would this -- why would this document have been
included as part of the real estate --
A.
To document --
Q.
-- closing documents?
A.
In my training and experience, it would be included to
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 39 of 359
801
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
document the -- that funds are available to purchase the
property.
Q.
And looking at the bottom -- the bottom here -- or well,
if you look at the ending balance, what is the balance in this
account?
A.
$9,554 -- $9,554 -- $9,554,515.
Q.
And then if we look at the deposits and additions, what
is -- what is that 3/29 transaction?
A.
That's the deposit of the PPP proceeds, which is the bulk
or substantial -- the entire amount of the funds in the
account.
Q.
Just about 100 bucks in the account other than that?
A.
Correct.
Q.
And were you able to look at what this residence looks
like?
A.
I did. It was part of my investigation.
Q.
And I'm -- and if you could look at in your binder what's
been premarked for identification as Government's Exhibit 451.
A.
Okay.
Q.
Based on your investigation, do these photographs fairly
and accurately depict 5114 Greythorne Lane as you know it to
look?
A.
They do.
MR. EVERT: I move to admit Government's Exhibit 451.
THE COURT: Any objection?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 40 of 359
802
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. FINLAYSON: No objection.
THE COURT: Okay. 451 is admitted.
MR. EVERT: And if we could please pull up
Government's Exhibit 451.
BY MR. EVERT:
Q.
What does this depict?
A.
That is the front of the residence located at 5114
Greythorne Lane.
Q.
And then if we could look at Page 2. What does that
depict?
A.
That is the rear of the residence.
Q.
All right. And if we could please turn to Government
Exhibit 403, which is already in evidence. What -- what is
this?
A.
So that's another settlement statement to reflect the
purchase of a property by Karl Lucius Delano for a property
located at Tract 4 Fiber Drive, Cartersville, Georgia, 30120.
Q.
And what is the contract sales price?
MR. EVERT: If we could zoom out. And then pull it
up right, right there. Yeah. Thank you.
BY MR. EVERT:
Q.
Okay.
A.
Contract sales price is $95,000.
Q.
And if we could just go back to the name, did you learn
that the defendant changed his name at a certain point?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 41 of 359
803
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
I did.
Q.
What did he change it from and to?
A.
He changed his name from Carl Torjagbo to Karl Lucius
Delano. And the Karl Lucius Delano is the name that's on this
settlement statement.
Q.
And when -- when was that in relation to his receipt of
the PPP money and the -- and the tax refund?
A.
I would have to see the exact -- that exact date, but
the -- I believe it was after he received the proceeds.
MR. EVERT: If we can pull up the -- if we could pull
up Government's Exhibit 13, please, is already in evidence.
BY MR. EVERT:
Q.
So if we look in the top right-hand corner.
A.
Yeah. So the name change was filed July 29th of 2021,
which was a couple of months after the receipt of the PPP
proceeds.
Q.
And why was the name change significant to you?
A.
Again, in these types of investigations, things are done
to try to deceive --
MR. FINLAYSON: Objection. Same Objection,
Your Honor, or similar objection. Relevancy, 401.
THE COURT: Again, I'm going to allow the witness
to -- I'll overrule the objection and allow the witness to
answer the question, but caution you that it's to be
considered by you for a very limited purpose and that is to
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 42 of 359
804
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
consider where he was looking, not to determine that the
defendant did it for that purpose. You'll have to decide that
from all of the evidence. You might not even have to decide
that issue.
Okay. Does everyone understand my instruction?
Okay. Go ahead.
THE WITNESS: It was a red flag to me.
BY MR. EVERT:
Q.
And if we look at Government's Exhibit 405, which is
already in evidence. What is this?
A.
This is another -- it represents a real estate
transaction.
Q.
And --
A.
For the purchase of a property located at 101 Holt Drive
in Acworth, Georgia, by FlyingJack Freight and Logistics and
that property is located in the Northern District of Georgia
as well.
Q.
And what is the contract sales price for this -- for this
purchase?
A.
The sale price of the property is $155,000. And my
investigation revealed that FlyingJack Freight and Logistics
is a company that is -- was owned and operated by the
defendant.
Q.
Did you obtain documentation related to the incorporation
of FlyingJack Freight and Logistics?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 43 of 359
805
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes, I did.
Q.
If you could please look at what's been premarked for
identification as Government's Exhibit 14 in your binder.
MR. EVERT: This is subject to the authenticity
stipulation.
BY MR. EVERT:
Q.
It would be in your binder. Or we can pull it up on the
screen.
A.
I'm sorry.
Q.
Just not display it to the jury yet.
MS. CONNORS: I think Ms. Kelley has to do that. It
would probably be easier to look at it in the binder.
BY MR. EVERT:
Q.
Government's Exhibit 14 in the binder?
A.
I think that's in another binder somewhere.
COURTROOM DEPUTY: Are you publishing it or not
publishing it yet?
MR. EVERT: Not publishing it yet because it hasn't
been admitted yet.
COURTROOM DEPUTY: Okay.
BY MR. EVERT:
Q.
What -- what is this?
A.
So this was a document obtained during the investigation.
It's the incorporation documents for FlyingJack Freight and
Logistics.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 44 of 359
806
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. EVERT: And if we could just zoom in before we --
well, first I would move to admit this document.
MR. FINLAYSON: No objection.
THE COURT: Okay. It is admitted.
MR. EVERT: And if we --
THE COURT: It's exhibit?
MR. EVERT: 14.
THE COURT: 14.
MR. EVERT: So if we could just zoom in on the top
half and publish it to the jury. Just the top half there, up
to here (indicating). Just a little bit further. Perfect.
All right. If we could publish that, please.
BY MR. EVERT:
Q.
So looking at -- looking at this first paragraph, when was
FlyingJack created?
A.
August 17th of 2021.
Q.
And just to be clear, did this company exist at the time
the PPP loan was applied for?
A.
It did not.
Q.
And did this company exist at the time that the money from
the tax return was received?
A.
It did not. It was incorporated after the fact.
Q.
And did FlyingJack have its own bank account?
A.
It did.
MR. EVERT: If we could please pull up --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 45 of 359
807
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: You said it did or it didn't?
THE WITNESS: It did. Yes, it did. FlyingJack
Freight and Logistics had its own bank account.
BY MR. EVERT:
Q.
And if we're referring to FlyingJack, we know we're
referring to FlyingJack Freight and Logistics?
A.
Correct.
MR. EVERT: If we could pull up Government's
Exhibit 305, please.
BY MR. EVERT:
Q.
What is -- what is this?
A.
So this is the customer profile information for the
FlyingJack bank account showing an address of 5114 Greythorne
Lane in Marietta, Georgia.
Q.
And what bank was this at?
A.
I believe it was --
Q.
If you can turn to -- was it at Bank of America?
A.
I believe, yes, it was. I believe it was at Bank of
America.
Q.
Thank you. And so that 5114 Greythorne Lane address, is
that the address of the house that we just saw a picture of?
A.
Yes, it is. And the signer, which is -- on the customer
profile, on the signature card, has Carl Torjagbo listed as
the signer.
Q.
And what was the source of the overwhelming majority of
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 46 of 359
808
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
the funds that's came into this account?
A.
It was the money from the Kremkov bank accounts.
Q.
And was that -- was it --
A.
I'm sorry. Which the source of the funds were from the
PPP proceeds and the IRS refund.
Q.
Did Mr. Delano purchase any assets for FlyingJack?
A.
Yes, he did.
Q.
What -- what did he purchase for FlyingJack?
A.
He purchased multiple semitrucks, I believe there were 12,
and then also approximately 12 semitruck trailers, so it was
the tractor and the trailer.
Q.
And about how much in total did he spend on all of that?
A.
I believe it was about $900,000.
Q.
And do Government Exhibits 409 through 417 reflect the
purchase of those trucks and trailers?
A.
Those are the ones that we looked at earlier?
Q.
Yes.
A.
Yes, they do. And that stuck out to me because that was
not payroll, which was what the PPP program was designed for.
Q.
Was there any mention of FlyingJack Freight and Logistics
in the PPP application?
A.
There was not, no.
Q.
Now if we could please discuss Government's Exhibit 406,
which is already in evidence. What -- what is this?
A.
This is a purchase of a 2014 Lamborghini Aventador.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 47 of 359
809
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And if we could please turn to Page 2.
A.
And it's dated April 15th of 2020 -- well, that may be a
different date.
Q.
If we can turn to Page 22, or, I'm sorry, Page 2.
Looking at the middle of the page on the right, what
is the total sales price?
A.
Total sales price for that vehicle is $332,999.80.
Q.
What's the year, make and model of this vehicle?
A.
It was a 2014 Lamborghini Aventador.
Q.
And on this document, who's listed as the buyer of the
vehicle?
A.
Karl Lucius Delano at that 5114 Greythorne Lane.
Q.
And was that the name on the PPP application?
A.
It was not.
Q.
What was the name of the person whose -- what was the name
on the PPP application?
A.
Kremkov Industries.
Q.
And who -- who was the person that -- what was the name of
the person?
A.
Carl -- Carl Torjagbo.
Q.
And did that name appear on the tax return?
A.
This Karl Lucius Delano name?
Q.
Correct.
A.
You'll have to refresh my memory.
Q.
Did -- so the tax return, when was that filed?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 48 of 359
810
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
No, the name on the tax return.
Q.
Oh, yeah.
MR. EVERT: If we could pull up 201, please.
THE WITNESS: I get confused on what name was used
for what.
BY THE COURT:
Q.
Oh, no problem. Yeah.
A.
Yeah, so the name on the tax return was Carl Torjagbo.
Q.
Okay. And so then going back to 406, please, Page 2, what
was the name of the dealership here?
A.
Atlanta Autos on Cobb Parkway in Marietta, Georgia, which
is in the Northern District of Georgia.
Q.
Have you seen this vehicle before?
A.
I have.
Q.
When did you see it?
A.
I don't recall the specific date, but I seized it from the
Lamborghini dealership when it was there for repairs.
Q.
And I'm showing you what's -- if we could look at
Government's Exhibit 452 in your binder, it should be right
after the picture of the house in the binder.
A.
Oh, 452?
Q.
Yeah.
A.
Okay.
Q.
What -- what is this?
A.
That is -- those are photographs of that Lamborghini
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 49 of 359
811
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
documented on those statements parked in the FBI parking lot
for temporary storage after I seized it.
Q.
Do these photographs fairly and accurately depict the
vehicle as it appeared when you saw it?
A.
Yes.
MR. EVERT: I move to admit Government's Exhibit 452.
MR. FINLAYSON: No objection.
THE COURT: All right. 452 is admitted.
MR. EVERT: Could we please publish it. Thank you.
BY MR. EVERT:
Q.
So what is this?
A.
That is the Lamborghini that I seized. And that is the
Lamborghini that was purchased by funds -- with funds
from -- it was commingled funds of the PPP proceeds and the
IRS tax refund.
Q.
And turning to Page 2, same car?
A.
Yes.
Q.
Different angle?
A.
Yes.
Q.
All right. If we could please discuss Government's
Exhibit 404, which is already in evidence.
MR. EVERT: And pull that up, please.
BY MR. EVERT:
Q.
What is this?
A.
That is another purchase -- documentation for another
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 50 of 359
812
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
vehicle that Carl Delano Torjabgo purchased.
Q.
And what is the year, make and model of the vehicle?
A.
That is a 2022 BMW M850XI.
Q.
And what is the location of the dealership for this
vehicle?
A.
It's got an Atlanta, Georgia, address, which is in the
Northern District of Georgia.
Q.
And what is the -- looking at the middle of the page, what
is the purchase price for this vehicle, total vehicle price
right there?
A.
So on the bottom, the amount due on delivery was
$118,299.79. But there was a down payment, so the total
vehicle cash price was $120,799.79.
Q.
Have you seen this vehicle before?
A.
I have.
Q.
When did you see it?
A.
The FBI seized this vehicle as well and it was transported
to the FBI lot in Atlanta for temporary storage and I saw it
at the lot.
Q.
If we could please look at Government's Exhibit 453 in
your binder. What is this?
A.
That is the BMW that is listed on the purchase agreement
that we just saw.
Q.
Do those photographs fairly and accurately depict the
vehicle as it appeared when you saw it?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 51 of 359
813
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
It does. And the VINs on those purchase agreements
matched the vehicles that these photographs represent.
Q.
This and the other one as well?
A.
Correct.
MR. EVERT: Okay. I move to admit Government's
Exhibit 453.
MR. FINLAYSON: No objection.
THE COURT: It's admitted.
MR. EVERT: Could we please display Government's
Exhibit 453.
BY MR. EVERT:
Q.
Is this the front of the car?
A.
It is.
Q.
And turning to the next page.
A.
Side profile, yes.
Q.
Same car?
A.
Yes.
Q.
All right.
MR. EVERT: Now, could we please pull up Government's
Exhibit 402 which is already in evidence.
BY MR. EVERT:
Q.
What is this?
A.
That is another purchase agreement or purchase
documentation with the buyer as Carl Delano Torjagbo at the
5114 Greythorne Lane address in Marietta, Georgia, purchasing
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 52 of 359
814
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
a 2021 Land Rover Range Rover Velar.
Q.
And just below that, what's the total sales price? That
should be on the screen.
A.
Total sales price is -- do you want to scroll down a
little bit, just to -- because that includes the finance costs
and all of that. I just want to make sure that that's the
accurate price.
Okay. So total price would be $92,520.
Q.
And who -- you mentioned the buyer was Karl Delano?
A.
Correct.
Q.
Have you seen this vehicle before?
A.
I have.
Q.
When did you see it?
A.
That was at the location of -- of the defendant's arrest.
And that was seized by the FBI and then transported by our
office for temporary storage as well.
Q.
And where -- where geographically was it when you seized
it?
A.
It was in the Dallas, Georgia, area, which is the Northern
District of Georgia.
Q.
And if you could please turn in your binder to
Government's Exhibit 454.
A.
Okay.
Q.
What is that?
A.
That is the Range Rover that we just discussed.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 53 of 359
815
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Does it fairly and accurately depict the vehicle as it
appeared when you saw it?
A.
It does. Yes, it does.
MR. EVERT: I would move to admit Government's
Exhibit 454.
MR. FINLAYSON: No objection.
THE COURT: Okay. 454 is admitted.
MR. EVERT: And can we please publish this to the
jury.
BY THE COURT:
Q.
This is the --
A.
That is the vehicle that we just discussed that was
purchased. And again, the -- my investigation traced the
proceeds of the PPP funds and the IRS tax refund into the
purchase of this vehicle and the other vehicle that we just
discussed and it wasn't payroll related.
MR. EVERT: And then if we could please turn to
Government's Exhibit 407, which is in evidence.
BY MR. EVERT:
Q.
What is this?
A.
So this is a purchase and sale agreement of a -- we'll
call it a yacht that I identified throughout the investigation
as well. And subpoenaed these records. And these are the
records that represented the purchase of a yacht by
Carl Torjagbo. And the make and model of the yacht was an
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 54 of 359
816
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Astondoa, Kartessa 3, it's a 72GLX. It's a 1998 76 footer.
Q.
And what was the purchase price of this?
A.
The purchase price was $510,000.
Q.
And was there a deposit that needed to be put down for
that?
A.
There was. I believe it was -- okay, a $51,000 deposit
was provided from one of Mr. Delano's bank accounts. I can't
recall if it was his personal account or FlyingJack provided
that $51,000 deposit.
Q.
Did he ever end up paying the full amount of that
$510,000?
A.
He did not, because after I identified it, I obtained a
seizure warrant for that -- those funds and seized the funds.
MR. EVERT: Let's turn to Government's Exhibit 408.
BY MR. EVERT:
Q.
What is this?
A.
That is documentation of a medical procedure, specifically
plastic surgery, that was purchased by Carl Torjagbo.
Q.
And on Page 1, the first date of contact, what is that?
A.
First date of contact was April 5th of 2021, which was
just shortly after the receipt of the PPP proceeds.
Q.
Do you recall off the top of your head about how many days
after?
A.
I believe it was March 29th of 2021, which was when the
proceeds were deposited, I believe.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 55 of 359
817
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
So about a week later?
A.
About a week later.
Q.
All right.
A.
And again, there were -- there was no funds or very little
funds in his accounts prior to the receipt of that PPP
deposit.
Q.
And so apart from the money from the PPP loan and the
money from the tax return, in all the financial records, did
you see any substantial earnings --
MR. FINLAYSON: Objection, Your Honor. I can't let
this sit. Can we clarify what the plastic surgery was for?
THE COURT: Hold on. You can do it during
cross-examination, it's not -- step out a second. Okay?
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: You can't be like in the middle of his
direct I want to ask one more question right here, so I'm
going to object. That's not even an objection.
MR. FINLAYSON: It's very misleading to hang out
there.
THE COURT: He scheduled some plastic surgery, I get
it, everybody's wondering what it is. I am, too.
But that's cross -- I don't care what it's for.
You're dying to say it. But if he puts it in, so be it. If
not, you put it when you want.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 56 of 359
818
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
But you know it's not proper to stand up and be like
I want to ask one clarifying question in the middle of his
direct. That's just not like not the law, it's not -- it's
just kind of like a -- it's just made up.
MR. FINLAYSON: I think it's misleading to the jury
to hang out there.
THE COURT: It's not. He's left it hanging out
there. I grant you that. Maybe it's going to come up. I
don't know.
But there's no such thing as I'm objecting because
it's hanging out there and I want the jury to know something
now, that seems -- that makes it seem better rather than them
having this big old hanging chad out there or whatever it is.
Okay?
So let's just do it the right way and -- I don't -- I
don't care if you ask it or not.
MR. EVERT: Frankly, it was a procedure called
gladiator abs, and I thought that might be too prejudicial, so
that's why I wasn't going to go there, but...
MS. CONNORS: It was prejudicial --
MR. FINLAYSON: It's not penis enlargement. I mean,
you know --
THE COURT: Whoa, look. I try to be -- I try to be a
little informal, but that's not, right. Okay? And all the
side talk is not right either.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 57 of 359
819
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Okay. I try to be conversational, because it makes
it better, but y'all have got to be -- y'all have got to act
appropriate. Okay?
I'm going to let the witness -- I'm going to bring
the jury back in. And you can decide to do whatever you want.
And he can cross him the way that he wants.
And my job is if you ask a question that's wrong, I
rule on it, so you don't have to -- you do have self
restraint, but you do what you want to do and he can do what
he's supposed to do. And we'll all do it the right way.
Okay?
I'm pretty good at objections, but we can't have that
like kind of stuff. Okay?
MR. FINLAYSON: I'm sorry. I apologize.
THE COURT: All right. Bring them on in. Thanks.
We're going to take a break around 10:30-ish.
MS. CONNORS: Your Honor, we're going to be playing
that call. Do you want to do the break before the call?
THE COURT: Yes. When you get to that point, just
let me know.
MR. EVERT: It's right after this line of
questioning, so...
THE COURT: Okay. Good enough. Do you want to
break -- so we're about to get -- this is the last of the sort
of -- oh, if we could --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 58 of 359
820
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
COURTROOM SECURITY OFFICER: Ready?
THE COURT: Yes.
COURTROOM SECURITY OFFICER: All rise.
THE COURT: Just tell me when you want to break,
that's fine. We could be talking sidebar. It's not a big
deal to send them out again. Okay? Even if it's two
questions from now, whatever you want to do.
MR. EVERT: It's about that.
THE COURT: Okay.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. Y'all can be seated.
Go ahead, sir.
BY MR. EVERT:
Q.
So apart from the -- apart from the money from the
PPP loan and the money from the tax return, in all the -- in
all of the financial records, did you see any substantial
earnings or income that would have made the purchases of the
real estate, the vehicles, the yacht, the plastic surgery
we've been talking about possible?
A.
No, I did not.
MR. EVERT: I think this would be a good time.
THE WITNESS: And I did not see any payroll
expenditures as well.
MR. EVERT: I think this would be a good time for the
break.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 59 of 359
821
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: How long is the --
MR. EVERT: It's about 35 minutes. And then I've got
probably 15 or 20 minutes of questions, maybe less than that.
THE COURT: Okay. We are going to take our
mid-morning break right now. Okay?
We have some big chunks that come afterwards and
rather than interrupting it for that, we're going to take our
midmorning break now. And we'll be back in about ten minutes.
Okay?
Now, did they have coffee and snacks in there today?
JUROR: Yes.
THE COURT: And you have got plenty of water, too.
JUROR: Yeah.
THE COURT: All right.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Okay. Y'all can be seated.
I'm going to -- right before we bring the jury back
in, I'm going to spend a couple of minutes, I'm going to give
you-all a copy of the current version of the jury
instructions, where I've put them in the right order.
I'm going to spend five -- three minutes talking with
you through a couple of things that are highlighted in there
for your consideration over the lunch hour.
Okay?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 60 of 359
822
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
All right. We'll see you in a couple of minutes.
COURTROOM SECURITY OFFICER: All rise.
MR. FINLAYSON: How long? I'm sorry.
THE COURT: Seven minutes. All right?
(Whereupon, a recess was taken.)
THE COURT: Y'all can be seated.
So very quickly going through this. Okay?
I just want to flip through this real quickly and
point some things out for you.
At the beginning, I've changed it a little bit to
indicate on Page 1 that I'm going to give the instructions
before they hear closing arguments.
On Pages 2 and 3, there was just some -- there was a
duplicate instruction. And then the highlighted portion has
to do with whether or not the defendant testifies, we have to
consider that. Okay?
Moving on, Pages 6 and 7, there was a duplicate
instruction depending on whether or not the defendant
testifies, so the highlighted portion needs to be included if
he does testify. If he doesn't testify, the highlighted
portion comes out, I believe.
Page 8, I've put the transcript instruction in that
location and that's one of the things I want you-all to
consider is the location of the various instructions.
Going on to --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 61 of 359
823
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. FINLAYSON: Your Honor, I just don't think there
is going to be an exhibit number for the transcript. I think
it's just going to be tracking on the screen.
THE COURT: Oh, so we don't need that at all?
MS. CONNORS: That's right, Your Honor.
THE COURT: Perfect.
MS. CONNORS: The jury would just have access to
strictly the audio.
THE COURT: The jury will only have the audio?
MS. CONNORS: I'm sorry, for deliberations.
THE COURT: Good. Okay. Fine. Then we'll take that
out.
All right. Then Page 10, I put the on or about
instruction there before we get into what the specific
instructions are. Okay?
As well as the paragraph right before that about
alternate ways in which an offense can be committed.
Then on Page 22, I've highlighted this issue about
aiding and abetting, it's just -- I know that it is -- that
that provision is charged. But if I were a jury, I would just
be like what are they talking about, I haven't heard about
anybody else. So just think about that. I don't have to hear
about it, just think about it. Okay?
Then I've put the 404(b) evidence instruction right
after that. Okay?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 62 of 359
824
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
And then -- oh, good faith would come after that.
Okay?
I plan to give the instruction up until the end of
page -- what you have as Page 27 and give them the limited
instruction on 28 after your closing arguments. Okay?
Any questions about the way I've organized this for
your consideration?
MR. FINLAYSON: No questions about that.
THE COURT: Okay. So then when we get back from
lunch, my question is going to be anything you want to change
or objections to these instructions, other than the objections
that were made about the couple of issues that the defense
raised. Okay?
All on the same page?
MS. CONNORS: Yes, Your Honor.
THE COURT: My goal is to keep this moving so that
right after lunch, we can be printing out the final that I'm
going to read and making sure that we're not -- the jury is
not waiting for us to finalize instructions.
All right?
All right. Bring the jury in. Thank you.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. Y'all can be seated. Go
ahead, please.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 63 of 359
825
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. EVERT: Just a couple of things I wanted to clean
up before moving on to the next topic. If we could pull up
Government's Exhibit 300A, please.
BY MR. EVERT:
Q.
What is this?
A.
It's a PNC Bank statement. It's the account registration
and agreement for PNC Bank. The name listed on it is
Carl Torjagbo.
Q.
And if you go down to the signature.
A.
The -- it's signed by Carl Torjagbo with a signature there
and the account number ends in 9814.
Q.
And there's two other account numbers as well?
A.
Oh, I'm sorry. 9814, we've got 9822 and then 9849.
Q.
Are these three of the accounts -- the PNC accounts we
were discussing earlier?
A.
Yes, they are.
MR. EVERT: And then if we could turn to 300B,
please.
BY MR. EVERT:
Q.
What is -- what is this?
A.
It's another PNC Bank signature card account registration
agreement card listing the title -- or the name on the account
as Kremkov Industries with the 3081 Leatherleaf Trail,
Douglasville address.
Q.
And that -- that -- can you read the last four digits of
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 64 of 359
826
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
that identification number for Kremkov Industries?
A.
The TIN there?
Q.
Yeah.
A.
8332.
Q.
And then if -- if we go to the bottom, whose signature is
on this account?
A.
Carl Torjagbo.
Q.
And what's the date?
A.
January 29th of 2021.
Q.
So this -- that's -- is that the date when this account
would have been opened?
A.
Yes, and it shows the -- well, the application was
January 28th, and then it was opened the day after.
Q.
And then I believe there was an issue --
A.
And I don't know if I testified to it, but the account was
9499.
Q.
Oh, yes, thank you.
And then there was an issue -- earlier I was asking
you about plastic surgery. Did you look at some of the
procedures that were done there?
A.
I did.
Q.
Did any stand out to you?
A.
The document reflected certain procedures, yes.
Q.
What -- what -- anything stand out to you about the
procedures?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 65 of 359
827
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
It was listed as gladiator abs.
Q.
All right. Did there come a time when Mr. Delano,
formerly known as Mr. Torjagbo, was arrested?
A.
Yes, there was.
Q.
Where was he arrested?
A.
He was arrested in Dallas, Georgia. It was at a large
trucking storage lot, which was basically an empty lot that
was gated and secured. And the tractors and trailers that I
testified to earlier, most of them were present in that lot
and he was arrested inside that lot.
Q.
And when was he arrested?
A.
It was May of 2022, May -- it was like May 11th, 12th,
13th, somewhere around there of 2022.
Q.
When Mr. Delano was arrested, did he have any
identification on him?
A.
Yes, he did.
Q.
If you could turn to Government Exhibit 44 in the binder,
please. It would probably be the first binder.
A.
Okay.
Q.
What -- what is that?
A.
These are two driver's -- Georgia driver's license that
were obtained from the defendant subsequent to his arrest.
Q.
And he had both of these when he was arrested?
A.
Yes.
Q.
And if we could --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 66 of 359
828
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. EVERT: I would move to admit Government's
Exhibit 44.
MR. FINLAYSON: Your Honor, my only objection would
be renewal of anything from below that was raised.
THE COURT: Okay. Subject to that, it's admitted.
MR. EVERT: And if we could please display
Government's Exhibit 44.
So looking at the ID on the left. If we could zoom
in on that, please.
BY MR. EVERT:
Q.
What's the name on that?
A.
Karl Lucius Delano.
Q.
And then what is the address?
A.
5114 Greythorne Lane, Marietta, Georgia.
Q.
And then if we could look at the other -- the other ID
card.
A.
And it's got a date of birth of 1979.
MR. EVERT: Put that back up.
BY MR. EVERT:
Q.
And then on the other -- what is the name on that?
A.
Carl Delano Torjagbo with the 3051 Leatherleaf Trail,
Douglasville, Georgia, address with a date of birth of
September 10th of 1979.
Q.
After Mr. Delano was arrested, did he agree to speak with
you?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 67 of 359
829
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes, he did.
Q.
When he was arrested, were -- did you advise him of his
Miranda rights?
A.
Yes, I did.
Q.
Did he agree to waive those rights and speak with you?
A.
He did waive those rights and voluntarily agreed --
voluntarily agreed to speak with me.
Q.
Did he sign a form reflecting the agreement to speak with
you?
A.
Yes, he did.
Q.
If you could turn in your binder to number -- Exhibit
Number 43.
A.
Okay.
Q.
What is that?
A.
This is the advice of rights that I administered to him
subsequent to his arrest on -- to the defendant on May 12th of
2022, approximately 9:58 a.m.
And it was witnessed by -- that top signature is my
signature. And then there was another special agent present
with me who witnessed this form as well. And the signature
under the consent area was the defendant's signature.
MR. EVERT: And if we could move to admit that,
please.
MR. FINLAYSON: Your Honor, I would only renew
objection from below.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 68 of 359
830
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: Okay. Subject to that, it's admitted.
MR. EVERT: If we could please display Government's
Exhibit 43.
BY MR. EVERT:
Q.
All right. And so you -- you were testifying about a
number of signatures.
A.
Yes.
Q.
Whose signature -- whose signature is on the line
that's -- on that first witness line?
A.
So the signature on the first witness line in the bottom
left-hand corner is my signature.
The second signature is the signature of another FBI
special agent that was present with me during the interview.
Q.
And then whose signature is below the statement I have
read this statement of my rights and I understand what my
rights are. At this time, I'm willing to answer questions
without a lawyer present?
A.
That is the defendant's signature.
Q.
So who was present at the time of this interview?
A.
So this was immediately after Mr. Torjagbo's -- or the
defendant's arrest. It was conducted in my government-issued
bureau vehicle. I was present as well as another special
agent by the name of Marissa Pressley. I was seated in the
back seat, back left seat of my vehicle, the defendant was in
the back right seat of the vehicle next to me, and Agent
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 69 of 359
831
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Pressley was in the front passenger seat, the car was running,
the air-conditioning was turned on.
Q.
And you should have in front of you a CD titled -- with a
sticker that says Government's Exhibit 41.
A.
Yes.
Q.
What is that?
A.
The interview was recorded audibly, by audio, and this is
a disc which contains the audio of that interview.
Q.
And how do you recognize that this is that disc?
A.
I reviewed the audio prior to today's proceedings and
initialed it. And this is the exhibit that is initialed with
my initials.
Q.
And is that the entire recording for purposes of trial
today?
A.
Yes, it is.
Q.
And does it accurately capture your interview with
Mr. Delano as it occurred on May 12th of 2022?
A.
Yes, it does.
Q.
And was there a transcript also prepared to appear on the
screen to assist the jury today?
A.
Yes, there was and there is.
MR. EVERT: So I would move to admit the audio as
Government's Exhibit 41 and then the synched transcript would
just be a demonstrative.
MR. FINLAYSON: Renew objection from below. Nothing
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 70 of 359
832
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
else.
THE COURT: Okay. Subject to that, it's admitted.
So keep in mind you're going to see a transcript,
okay? But you need to listen to the words in the recording.
Okay? You will not have the words back there with you, the
written words that you'll see on the screen, you will only
have the recording. Okay?
Do you understand that?
The words are there to help you, but if you hear
something different from the words, go with what you hear.
But know that you will not have the words -- the written words
with you in the jury room.
Is that correct, counsel?
MR. EVERT: Yes, Your Honor.
THE COURT: Any objection to the instruction I've
given them?
MR. FINLAYSON: No, sir.
THE COURT: Okay. Go ahead, please.
THE WITNESS: Can I clarify something?
BY MR. EVERT:
Q.
Yes?
A.
So in this recording, you will hear the voice of a third
special agent, that was another special agent that was on the
lot. We had a team of agents out there. And we were
executing the seizure warrants of the tractors and trailers
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 71 of 359
833
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
and the Range Rover that was in the lot as well.
And that agent approached the vehicle from the
outside through the window asking for some keys or the keys
were for some of the vehicles, so you will hear that on the
audio as well.
MR. EVERT: All right. So with the Court's
permission, I will play the recording.
THE COURT: Please do.
MR. EVERT: Will you please play the recording.
(Whereupon, the recording was played)
THE COURT: Can you pause it? I'm going to ask you
to go back before I interrupted, but can y'all hear it okay?
JUROR: Um-hmm.
THE COURT: It sounds to me like it's only coming out
of my speaker. Do y'all have other speakers over there?
JUROR: Um-hmm.
THE COURT: Are you sure?
Okay. It seems suspicious. Just rewind it 10 or 15
seconds, would you. Thanks.
MR. EVERT: Thanks.
(Whereupon, the recording was played)
BY MR. EVERT:
Q.
So in the recording, Mr. Delano said that
Kremkov Industries was a mining company; is that right?
A.
Correct.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 72 of 359
834
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Did you see anything in any of the records that would be
consistent with Mr. Delano operating a mining company?
A.
No, I did not.
Q.
When you interviewed him, did Mr. Delano estimate the
maximum number of employees that Kremkov had?
A.
Yes, he did.
Q.
How many did he say?
A.
It was approximately 50, 60.
Q.
Was that consistent with what was in his PPP application?
A.
It was not, no.
MR. EVERT: Could we please pull up Government's
Exhibit 101, which is in evidence. Let's look at Page 1,
middle of the page.
BY MR. EVERT:
Q.
How many employees did he claim to have?
A.
493.
Q.
And turning to Page 141 of the same application, what is
this?
A.
That's a Form 941. And it's a form that's used to report
quarterly payroll to the IRS.
Q.
And question number one, how many employees did he say he
had?
A.
493.
Q.
And for what months was this?
A.
January, February, March of 2020.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 73 of 359
835
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. EVERT: And then let's move on to the next one.
And let's just go quickly to the next page.
BY MR. EVERT:
Q.
And who signed this?
A.
Carl Torjagbo.
Q.
All right. And was this submitted as part of the PPP loan
application?
A.
Yes, it was.
MR. EVERT: Can we turn to Page 143, please.
BY MR. EVERT:
Q.
What is this?
A.
It's another 941 for 2020 in the -- it's for the quarter
of April, May and June of 2020, filed by Kremkov Industries.
Q.
And what's the number of employees who received wages,
tips and other compensation for the -- for the pay period from
Kremkov Industries?
A.
493.
Q.
All right.
MR. EVERT: And then if we could go two pages down.
BY MR. EVERT:
Q.
Who signed this?
A.
Carl Torjagbo.
Q.
All right.
MR. EVERT: Let's go to the next page. Blow that up.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 74 of 359
836
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MR. EVERT:
Q.
What time period is this for?
A.
July, August, September of 2020.
Q.
And what's this document?
A.
It's another 941 for 2020, quarterly payroll reporting to
the IRS filed by Kremkov Industries.
Q.
And what's the number of employees who received wages, or
other compensation from Kremkov Industries?
A.
493.
MR. EVERT: And let's turn to the next page, the
following page. My apologies.
BY MR. EVERT:
Q.
Who signed this?
A.
Carl Torjagbo.
Q.
All right.
MR. EVERT: Let's go to the next page, please.
BY MR. EVERT:
Q.
What is this?
A.
Another form, a 941 of 2020 filed by Kremkov Industries
for the quarter of October, November, December of 2020.
Q.
What company is this for?
A.
Kremkov Industries.
Q.
What's the number of employees who received wages, tips or
other compensation for the pay period of October, November,
December of 2020?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 75 of 359
837
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
493.
MR. EVERT: And if we can go two pages down.
BY MR. EVERT:
Q.
Who signed this document?
A.
Carl Torjagbo.
Q.
All right.
MR. EVERT: And then if we can turn to the next page,
please.
BY MR. EVERT:
Q.
What is this?
A.
That's a Form 940 for 2020. And it's a form that's filed
with the IRS to report federal unemployment tax that is
withheld from payroll. And it's filed -- it was filed by
Kremkov Industries.
MR. EVERT: And then if we go down just a little bit.
BY MR. EVERT:
Q.
What's the total payments to all employees in -- in the --
for this year?
A.
4 -- $45,861,255.93.
Q.
And what -- what year was this for?
A.
Was it 2020? 2020.
Q.
And the COVID-19 pandemic, when was that, when did that
start?
A.
It was 2020, beginning of 2020, end of '19, beginning of
2020.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 76 of 359
838
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And two pages down, who is this signed by?
A.
Carl Torjagbo.
Q.
Now, Mr. Delano claimed in his interview that he never
planned to ask for forgiveness.
Under the PPP program, were you allowed to provide
false information to a lender if you didn't plan to ask for
forgiveness?
A.
No, you were not.
Q.
Now, in the recording, Mr. Delano claimed that his loan
was based on earnings. Have you reviewed that -- that loan
application?
A.
Yes, I did.
Q.
Does anything in that document suggest that the loan
amount was based on earnings?
A.
No, it does not.
Q.
Mr. Delano claimed that his loan was based on how much he
actually made and not the number of employees he had. How was
the amount of the loan he received calculated?
A.
The amount of the loan is calculated based upon a formula
which involves the amount of payroll for employees.
Q.
And was there anything in the application that would
indicate that the $9,554,425 that the loan was sought for was
sought based on income?
A.
Say that one more time.
Q.
Did anything in the application suggest that he was
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 77 of 359
839
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
seeking $9,554,425 based on income?
A.
No, it did not.
Q.
In the interview, Mr. Delano admitted that his operations
were in -- or -- well, I'll strike that.
Where -- what did Mr. Delano say with respect to
where his operations were during the interview?
A.
Africa.
MR. EVERT: If we could go to Page 1 of Government's
Exhibit 101.
BY MR. EVERT:
Q.
And if you could read page -- Question Number 7, please.
A.
Question number 7: Is the United States the principal
place of residence for all employees included in the
applicant's payroll calculation above.
Q.
And what did he answer in response to that question?
A.
There is a check in the column for the yes box.
Q.
And Mr. Delano -- what did Mr. Delano claim in his
interview about how he had been able to purchase the house and
the cars?
A.
With his own money.
Q.
And was that with the PPP money?
A.
He just said it was with his own money.
Q.
Did your analysis show that those -- those items were not
purchased with PPP money?
A.
My analysis showed that they were purchased with PPP money
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 78 of 359
840
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
or -- and/or the federal tax refund money.
Q.
Based on the records that you've seen, did Mr. Delano's
lifestyle change after he obtained the PPP loan and the tax
refund?
A.
Yes.
Q.
In what way?
A.
Well, based upon the financial records that I obtained
from the bank accounts, there was very minimal activity. He
had -- he was renting and leasing certain items.
And once he obtained the substantial PPP money and
the tax refund, he started paying hundreds of thousands of
dollars in cash for real estate, vehicles, his personal
residence. And there was nothing indicative of that prior to
the deposit of the PPP money and the refund, IRS refund check.
Q.
Apart from the money from the PPP loan and the tax refund,
were there ever any million dollar influxes of cash into any
of Mr. Delano's bank accounts that you saw?
A.
None that I saw in the bank records that I obtained.
MR. EVERT: No further questions. Thank you.
THE COURT: Okay. Cross-examination for this
witness?
MR. FINLAYSON: Thank you, sir.
CROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
How are you, sir?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 79 of 359
841
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Good.
Q.
I'm going to ask you a few questions. Let's start with
sort of the back and then we'll move back to the front.
So you arrested Mr. Delano on May the 12th, 2022,
right?
A.
Correct.
Q.
And that was -- that was in -- was that in Cartersville?
A.
That was in Dallas, Georgia.
Q.
Dallas, Georgia. And that was at the trucking lot for
FlyingJack, right?
A.
Yes.
Q.
And that was the business he was -- he was developing
there on that truck lot?
A.
Correct.
Q.
And there were, what, nine tractor-trailers up there?
A.
Yeah, I think it turned out to be about nine.
Q.
And you and the government seized every one of those,
right?
A.
Yes, we obtained seizure warrants from the Court and
seized what we had seizure warrants for at that time.
Q.
Okay. And you seized the Range Rover?
A.
Yes.
Q.
And you asked him where is the -- where are your other
cars, where is the BMW, he told you that's back at the house,
right?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 80 of 359
842
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes.
Q.
And you were able to go seize that?
A.
Yes.
Q.
And you were able to seize the Lamborghini from the car
dealership where it was being repaired?
A.
Yes.
Q.
Okay. He didn't hide those things from you in any way,
did he?
A.
No.
Q.
Okay. And his house, I guess he didn't really hide the
house from you, did he?
A.
No.
Q.
And it's -- it was in his name, right?
A.
Yes.
Q.
And then the pieces of property that were bought for
FlyingJack, were those in the name of FlyingJack or were they
in his personal name?
A.
I mean, I would have to go back and look at the records --
Q.
Okay.
A.
-- to clarify.
Q.
But when you went to FlyingJack, FlyingJack led you right
back to Karl Delano, right?
A.
Yes.
Q.
And, I mean, that was the person who incorporated
FlyingJack, right?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 81 of 359
843
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Well, the actual incorporation did not indicate
Carl Torjagbo. But the addresses and the operations of
FlyingJack was Carl Torjagbo.
Q.
Well, it wasn't a hard -- it wasn't hard for you to follow
that paper trail, was it?
A.
I'm not going to say it was hard or easy. I mean, it
was -- there's a process involved.
Q.
But was there a -- did he have another name that we don't
know about? Is there some -- I'm trying to --
A.
I don't know. Does he?
Q.
I'm asking you.
A.
I don't know. I mean, I know the names that I discovered
during the investigation.
Q.
My question to you is: When you went to investigate
FlyingJack, did you have any problem associating it with
Mr. Delano?
A.
No, because the records that I obtained amongst --
during -- throughout the investigation all pointed back to the
defendant.
Q.
It went right there, right?
A.
Correct.
Q.
Let's talk about the name. When you first started looking
at him, I guess you knew him as Carl Delano Torjagbo, right?
A.
Yes.
Q.
And Delano was his middle name, right?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 82 of 359
844
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
That's what it showed, yes.
Q.
Okay. Do you have some reason to believe that it wasn't?
A.
I mean, that's the name that he used. That's the name
that was documented on the documents.
Q.
Okay. And then when he changed his name, he became Karl
Lucius Delano, right?
A.
That's what the documents show, yes.
Q.
So the middle name became his last name, correct?
A.
That's what the documents show, yes.
Q.
Okay. You talked about the movement of funds from bank
account to bank account, right?
A.
Yes.
Q.
And you've been doing this a long time, right, sir?
A.
I testified approximately 23 years.
Q.
Okay. And you have -- you talked -- you alluded to like
sort of other cases of money laundering. What -- what
other -- what money launderers might do in other situations,
right?
A.
Yes.
Q.
And one of the things you mentioned was like sending money
through multiple accounts to hide, I guess, the owner or the
source or to hide who's dealing with it, right?
A.
Correct.
Q.
In this case, we had money coming from Chase Bank -- well,
I guess it came from the government to Chase Bank to
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 83 of 359
845
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Kremkov Industries, right, that was like the first -- let's
say that's sort of the first step, right?
A.
Yes.
Q.
And that Kremkov Industries, that's Mr. Delano, right?
A.
Yes.
Q.
And that's -- that's at Chase Bank is where that first
deposit goes in, right?
A.
Correct.
Q.
And then that money goes from the Chase Bank to
Kremkov Industries at PNC Bank, right?
A.
Yes.
Q.
And that PNC Bank, that's in the name Karl Delano, right?
A.
Yes.
Q.
So it's not like a third-party name or some other person,
right?
A.
Yeah, it went from Kremkov to Kremkov to Karl Delano.
Q.
Right. That's a pretty simple trail, right?
A.
Once you got the bank records, yes.
Q.
Yeah. Kremkov to Kremkov to Karl Delano?
A.
The problem is, is that's what called layering. Because
if the money was deposited from a corporate PPP loan into a
personal account, it would never have been issued.
Q.
So --
A.
So it had to go to multiple accounts to a personal
account.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 84 of 359
846
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
So it went from one account to a second account then to
Karl Delano, correct?
A.
Right. That's what the records show.
Q.
And PPP money eventually has got to get to a personal
account, right?
A.
Not for a company, no.
Q.
Well, it's got to be paid out -- if it's paid out to
employees, that's going to personal accounts?
A.
It's -- it could be. It could be issued by check, it
could be issued by wire, it could be issued by payroll, but
it's going to an employee, which is what the program was
designed for.
Q.
Eventually it's going to go to a personal account?
A.
It depends. Because not all the PPP money is destined for
payroll. Like I testified, some of the money could be used
for rent and utilities and such as part of the program, but
the majority of it is supposed to get paid out to payrolls of
a U.S. established company for their -- for their wages.
Q.
Well, let's talk about that. The requirements are that
the employees have a principal residence of the United States.
That's what the paperwork says, right?
A.
No, it said the -- we can go back and look at the -- the
exhibit to clarify.
Q.
I don't know that I have that number off the top of my
head.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 85 of 359
847
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. EVERT: 101.
MR. FINLAYSON: All right. 101.
BY MR. FINLAYSON:
Q.
Number 7: Is the United States the principal place of
residence for all employees included in the applicant's
payroll calculation.
A.
Okay. Yeah.
Q.
That's what it says, right?
A.
It does. And Mr. Torjagbo indicated in the interview that
all of his employees were in Africa, besides 50 or 60.
Q.
Let me ask you a question, sir.
A.
Sure.
Q.
The question is that's what the form said, that's --
that's what was certified. The principal place of residence
was in the United States, correct, sir? Is that correct?
A.
The question --
Q.
Is that correct?
A.
The question you just read was Number 7.
Q.
Yes, sir.
A.
Can we pull that back up again?
Q.
Sure.
A.
So what that says is: Is the United States the principal
place of residence for all employees included in the
applicant's payroll calculation above. And it's checked yes.
Q.
Thank you, sir.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 86 of 359
848
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes.
Q.
That's what it says, correct?
A.
Yes.
Q.
You don't dispute that?
A.
No.
Q.
Principal place of residence?
A.
Yes.
Q.
For all employees, correct?
A.
Correct.
Q.
Okay. It doesn't say the company has to be all based in
the United States, does it?
A.
Not Number 7.
Q.
No. It says the workers, in Number 7, it says the workers
have to have their principal place of residence in the
United States.
A.
That's what Number 7 says, yes.
Q.
Okay. And principal place of residence, do you even know
that means?
A.
That's -- I'm not -- I'm not -- I'm a special agent. I
don't determine what a principal place of residence is.
Q.
It's defined by another department, right?
A.
Exactly.
Q.
IRS maybe? Do you know?
A.
I don't know who -- what -- who designed that language,
but principal place of residence is where a person -- is their
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 87 of 359
849
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
principal -- it's where they reside.
Q.
Where their principal place of residence is, right?
A.
Correct.
Q.
So you could be -- a principal place of residence in the
United States, you could be working outside of the country in
a mine or on an oil rig, correct?
A.
Okay. And the evidence that I found showed that there
was --
Q.
That's not my question.
THE COURT: Hold on. Let him answer the question.
THE WITNESS: There was no evidence of 493 employees
at all. And Mr. Torjagbo told me that he only had 50 or 60.
BY MR. FINLAYSON:
Q.
Well, let's ask about that. You asked him a very -- first
of all, we'll back up. You guys arrested him, right?
A.
Yes.
Q.
And when I say you guys, it was like ten people, right?
A.
We'd have to go back to the documents. I don't know
exactly how many people we had. It was three years ago.
Q.
You were there, right?
A.
Absolutely, I was there.
Q.
You don't remember?
A.
Not every person that was there from three years ago, no.
Q.
That's not my question.
A.
We had -- we had -- we had a sizeable amount of agents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 88 of 359
850
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
there to -- to effect the arrest and the execution of the
seizure warrants. If it was ten, I don't know exactly. It
could be 9, could have been 11.
Q.
Fine. Could be 9, could be 11?
A.
Yes.
Q.
Guns were drawn, right?
A.
Yes. It was an arrest operation.
Q.
That means guns were drawn?
A.
Yes.
Q.
It was a takedown?
A.
Yes.
Q.
There were people with automatic like submachine-gun type
weapons?
A.
No, we had a combination of pistols and assault rifles
that are not -- that are not automatic.
MR. EVERT: Objection.
THE COURT: Grounds.
MR. EVERT: It might be better to discuss outside the
presence of the jury.
THE COURT: Okay. Step outside a second.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: What's the issue?
MR. EVERT: Your Honor, at defense counsel's request
we sliced out all of the audio related to the arrest and the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 89 of 359
851
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
guns at the arrest.
And now he's -- rather than what was actually in the
recording, he's trying to -- he's trying to get a skewed
version of that -- of what happened into the record. So we
would ask that if he wants to discuss -- if he wants the
information about the takedown, there is approximately 7 or so
more minutes of audio that we're happy to play, but this is
not -- this was done at his request, that that was cut out, so
we don't think it's proper for him to be going into what he
asked to cut.
THE COURT: Did you ask that it get cut out?
MR. FINLAYSON: I thought -- my recollection of that
whole process was it was at a -- first of all, the tape had
stopped, it was sort of a revising of the discussion.
I don't mind playing it, if you want to play it, it's
fine. I just didn't think it was relevant in terms of what --
what -- it's fine. It wasn't -- this -- obviously I didn't
mind this part, because I'm asking about it, but -- and I'm
not trying to skew anything. I think when we're talking about
a defendant's state of mind who's making a statement to
officers after being arrested, I think I'm totally entitled to
go into.
THE COURT: In think you are, too. I think the
government's point is not that.
The government's point is that it's unfair for you to
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 90 of 359
852
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
keep it out and then put it in because it makes it like look
like the government is doing something deceptive.
Is that the government's point?
MR. EVERT: Yes. That's the point. And yeah, and
this is what he asked for and now he's doing it. It's just
not -- it's not fair.
THE COURT: Yes, it seems -- I get it.
MR. FINLAYSON: And I apologize if that's how it's
perceived. I don't -- I don't -- my recollection -- my
recollection of why I didn't want that in wasn't this. So
I -- I don't mind playing that part. I don't -- I don't --
I'm not trying to -- I wasn't trying to mislead them and bait
and switch. I really --
THE COURT: I understand that but --
MR. FINLAYSON: But I don't mind playing it.
THE COURT: It seems to them as if it's in the arena.
What do you want to do about it?
MR. EVERT: I mean, I don't know because we --
THE COURT: I have to let him get into it.
MR. EVERT: The problem is we've diced up this
recording because of this, so now I think we're going to have
to -- I don't know, what's -- it's going to -- yeah, it's
going to take some time to reclip it, unfortunately.
THE COURT: Do you mean the portion of the recording
that leads up -- that starts the initial encounter the whole
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 91 of 359
853
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
time he's interviewed?
MR. EVERT: No, so the initial part of the encounter
isn't recorded. There's about -- I think it's -- I don't
remember off the top of your head exactly how much, but I
think it's about seven minutes where then after the interview
concludes, Mr. Delano says you guys didn't need to come here
with all those machine guns and stuff. And he actually
chuckled.
The notion that it's like he's scared, he's doing
this because he was scared. Like if you listen to the
recording, that's just not what happened.
And then, you know, he says, look, I mean, the
reason -- I don't remember exactly off the top of my head, but
it was like, look, we can't be too careful. Everybody is
going home to their families safe today or something like
that.
And so, I mean, just presenting it as this like
military op where it's going to scare him, that is just a
skewed depiction of it and so --
MR. FINLAYSON: I mean, she's pulled my email about
it. In the email, I said I don't see a need to go into the --
tape's stopped. And I said I don't see a need to go into this
specific thing.
But I have no specifics about -- I mean, he's
complaining -- the defendant is complaining about why did you
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 92 of 359
854
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
have to do all of this stuff, so I'm fine with that. I didn't
really think this was an issue, obviously, but if they want to
play the rest of it, I think it's totally fine.
THE COURT: The problem is now that they're here,
they don't have the rest of it ready to go.
MR. FINLAYSON: I'm sorry about that.
THE COURT: So I guess what we could do is we can --
you can go on with your cross-examination. I'm going to give
the agent leeway to explain the context.
And then I'm going to allow the government to get
back into it on redirect, including if you need to have --
showing him the transcript -- do you have a transcript of this
portion?
And you can ask him questions then about how that
went. And you can say is that part of -- do you have a
recording of that portion, too.
And then the jury will know at least there was a
recording of it that neither of you decided to play. I mean,
I don't know.
MR. EVERT: I mean, I think that -- I don't think
that really solves it, because he's saying -- I mean, he
says -- I don't know the exact words off the top of my head,
but he chuckles when he's like you didn't have to come here
with like all of this --
THE COURT: Did you have him ask that?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 93 of 359
855
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Did he chuckle?
Did you talk with him about it?
Yes.
Did he seem upset?
No.
Why do you say that?
Because there was even a part where he chuckled about
having all of these guns. And we told him that we did it for
this reason or the other.
Can't you explain that context?
Did he seem like to you that he felt intimidated or
threatened by any of these guns or things?
No, he didn't.
I mean, I don't know if that's what he would say or
not, but I think you can do that.
MR. EVERT: Yeah. I -- yeah, I mean, I think his --
I mean, I think the -- you know, hearing the defendant chuckle
is much more powerful than the agent saying he didn't think he
was intimidated, but...
THE COURT: But you can --
MR. EVERT: And we'll try to do our best to get it
respliced and, I mean --
THE COURT: Yes.
MR. EVERT: But yeah, I just --
THE COURT: I get it. I don't think that -- I don't
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 94 of 359
856
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
think the defendant was in that email saying we don't see any
need to go here. I don't think he was trying to bait and
switch you.
MR. EVERT: Right. I mean, I guess --
THE COURT: What he was trying to do was say that's
not really a part of it.
But I can see how you've got some feelings about
that, because you had a part of the tape that at his request
you took out, which you think is contrary to the image he's
trying to paint.
MR. EVERT: And to be clear, that's what that part of
the recording is. It's not --
THE COURT: Yes.
MS. CONNORS: There's nothing else, so I don't -- I
really don't see what else -- not need it, like not wanting to
get into that would be other than this specific issue that
he's into.
THE COURT: Well, let's just -- we've got to move
forward from here. And I've got to let him get into the
circumstances surrounding the encounter. But I'm going to
give you plenty of leeway on redirect to flush this out.
Do you understand that?
MR. FINLAYSON: I do.
THE COURT: Do you agree with that?
MR. FINLAYSON: I think it's fair.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 95 of 359
857
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: Okay.
MR. FINLAYSON: And I think I just -- so my
intention, I don't mean to beat this much more anyway, is to
look at the beginning, because at the beginning of the
takedown, they're inherently traumatic. And maybe the
aftermath wasn't so bad. But I think -- I think I'm focusing
on the beginning.
THE COURT: And the jury will understand all of this.
He didn't seem upset or confused or intimidated during the
interview, but at any rate.
Okay. Everybody got the ground rules? I'm going to
let you do what you're trying to do despite what you-all
talked about before.
But I'm going to give the government some leeway on
redirect in order to make sure that they can illuminate it.
And if you want to bring him back later to play that
part of the tape, you can do that out of order. Whatever you
need to do.
MR. EVERT: Appreciate it. Thank you.
THE COURT: Okay. Thank you. All right. I think
everybody ought to try the case they want. And when these
types of things happen, we all have just got to adjust and
you'll both get there.
But I think both of you are trying to do what you're
allowed to do, so communication or miscommunication in the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 96 of 359
858
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
prep ought not prevent it.
MR. FINLAYSON: Sorry.
THE COURT: Okay. Let's bring them back in. Thank
you.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: Go ahead. Oh, I'm sorry. You may be
seated. Go ahead. I'm sorry.
BY MR. FINLAYSON:
Q.
Agent Caruana, we were talking about the takedown on
May 12th, 2022, correct?
A.
Yes.
Q.
And that's the day that you guys arrested Mr. Delano?
A.
Yes.
Q.
And is it fair -- let's put it this way, it was a standard
takedown operation; is that fair?
A.
This was a law enforcement operation. There's never a
standard law enforcement takedown, because we never know what
we are going to encounter. So this was an arrest operation
that we tried to plan for to the best of our ability. But
there's still a myriad of unknowns when you get to a situation
like that.
Q.
And there's also a seizure operation as well?
A.
And then we were executing a seizure operation as well, so
there were many agents there. The exact amount, I don't
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 97 of 359
859
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
recall, but we had many agents there.
Q.
And what were those agents wearing?
A.
So we -- we -- again, because it's a law enforcement
operation, we were in our tactical vests, clearly identified
with FBI. We had our issued handguns, we had issued rifles,
we had our med kits on us. We had -- so we were plainly
identified as FBI agents.
And when -- when we executed the arrest, the -- you
know, we clearly announced our presence and things happened
very quickly without incident. And I believe that typically
happens for us. And in this situation, it's because we came
in force and we were able to take control of the scene
quickly.
Q.
Okay. And Mr. Delano didn't fight with you in any way?
A.
Did not fight, did not seem concerned, did not scare. I
think he was a little bit startled, but once I got him into
the car and he sat there, there was a period of time that he
sat in the air-conditioner -- air-conditioned car before I
spoke with him. He had time to settle down.
When I -- when I spoke with him, I spoke with him
prior to what was caught on that recording to explain the
situation, build rapport, explain the federal system with him.
Q.
And my question was he didn't fight with you?
A.
No, he didn't.
Q.
Thank you. And my next question is: He didn't try to run
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 98 of 359
860
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
away from you?
A.
No, he didn't.
Q.
Okay. He didn't pull a gun on you?
A.
No, he didn't.
Q.
And nobody else did, either, right?
A.
No.
Q.
Okay.
A.
And there were multiple people in that lot as well that we
had no idea who they were. So we were able to take control of
that scene with the force that we had, a reasonable amount of
force, and thankfully things turned out fine.
Q.
And you put Mr. Torjagbo -- Mr. Delano, you put him on the
ground face down, I assume?
A.
As soon as we executed the arrest and we identified
ourselves, absolutely, yes.
Q.
And you cuffed him behind his back?
A.
Yes.
Q.
Okay. Did you put the other people on the ground?
A.
We did not.
Q.
And those were workers --
A.
Because we only had one subject.
Q.
And those were just workers out there working on the truck
lot, right?
A.
Once we identified who they were, yes.
Q.
Okay.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 99 of 359
861
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
We've -- we identified who they were and they turned out
to be workers on the truck lot. The Judge that was indicated
in the recording, the painters that were putting the logos on
the trailers.
Q.
Okay.
A.
But we had to sort all of that out.
Q.
Sure. And by your investigation, FlyingJack was a
legitimate company, right?
A.
It was a company that Mr. Torjagbo used PPP proceeds and
illegally gotten funds from the IRS to purchase trucks and
trailers and real estate.
Q.
Okay. So --
A.
Whether it was a legitimate operation, I don't know.
Q.
You don't have any evidence that it was not, right?
A.
All I have is evidence of the use of those funds.
Q.
Well, let's talk about the use of the funds.
So you had -- originally the PPP loan was
$9.5 million from Chase Bank, right?
A.
Correct.
Q.
And they clawed back pretty quickly $6.5 million, right?
A.
That's what my understanding is, yes.
Q.
So that only $3 million went over to the next Kremkov
account, right?
A.
Whatever -- whatever the number was, yes.
Q.
So $3 million from PPP and then there's $3.4 million from
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 100 of 359
862
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
the tax return, right?
A.
You said about 3 and a half million.
Q.
3.4?
A.
Or 3.4. Yeah, whatever the numbers show. There was the
money from the IRS refund.
Q.
And that goes into the same account, right?
A.
Yes.
Q.
Now, the purchases for FlyingJack, they weren't all of
that money, were they?
A.
Yeah. None of it had to do with payroll.
Q.
That's not my question. The part -- let me ask it better.
So he bought all the trucks at FlyingJack, right?
A.
Correct.
Q.
He bought all the land at FlyingJack, right?
A.
Correct.
Q.
He had to pay all that insurance you were talking about,
right?
A.
Correct.
Q.
I guess there were some license fees or there were some --
there's some kind of registration fees, that kind of thing?
A.
Anything to establish a trucking company with PPP funds he
had to pay for.
Q.
But the money that went to FlyingJack was less than
$3 million, right?
A.
Yes. I think I testified the quantification of the money
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 101 of 359
863
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
that he used to at least purchase the trucks and trailers was
about $900,000.
Q.
Right. And the land, one piece was maybe about $100,000?
A.
Yes.
Q.
Maybe the other piece I want to say a little less than
that?
A.
Correct.
Q.
So that gets us to about a million two or something like
that.
A.
Okay.
Q.
Does that sound about right? You don't disagree?
A.
I mean, it's -- it sounds reasonable, but unless we
actually get into the financial records and all that to
quantify it specifically, I mean, it's a ballpark.
Q.
A ballpark. But it's definitely less than $3 million,
right?
A.
Absolutely, yeah.
Q.
Okay. And the PPP loan was $3 million, right?
A.
Yes.
Q.
And the tax return was $3 million or 3.4 or 5?
A.
Yes.
Q.
So when the money goes to FlyingJack, you can't say that
it was PPP money that went to FlyingJack, can you?
A.
Yes, you can, because the money was commingled in one
account. And when it's commingled, then it's commingled funds
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 102 of 359
864
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
at that point.
Q.
So you don't --
A.
And at the end of the day, it doesn't matter, because it's
still fraudulent money.
Q.
That's if --
A.
If any dollar was used to pay for FlyingJack's assets,
it's -- it's a fraud.
Q.
That's your theory, right?
A.
It's coming from the PPP funds and the stolen IRS refund
check.
Q.
So the --
A.
Because there was no money in the account before these --
these deposits were put into the account.
Q.
Okay. So the purchases, the house that was purchased, you
don't actually know which funds the house came from, do you?
A.
It came from stolen funds.
Q.
That's your theory, right?
A.
No, that's what the evidence showed.
Q.
Okay. So we have money from the tax return, right?
A.
Yes.
Q.
That's $3.4 million goes into the account?
A.
Yes.
Q.
And you've got money from PPP that goes into the account?
A.
Correct.
Q.
You can't say that PPP money went into the house, can you?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 103 of 359
865
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
It was commingled, so a portion of it could have -- could
have been, yes.
Q.
Could have, okay.
A.
And when we looked at the bank records, I believe he had
$100 or so or some change in the account prior to the deposit
of both of these fraudulent proceeds.
Q.
Did you ever look at his overseas accounts?
A.
I did not identify any overseas account, so I don't know
if any overseas account exists.
Q.
Okay. Did you look?
A.
We tried to get whatever bank records we could based upon
the evidence that we obtained.
Q.
So --
A.
And I need to clarify something, too, because when you
focused on Item Number 7, so that's one of the reasons why I
bought in TIGTA -- can I clarify?
THE COURT: Are you answering this question.
MR. FINLAYSON: No.
THE WITNESS: No.
THE COURT: Oh, you want to go back to something
else?
THE WITNESS: Yes.
THE COURT: They can ask you about that on redirect.
Okay? Sorry.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 104 of 359
866
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MR. FINLAYSON:
Q.
So let's go back to something that you asked him that we
just heard on the recording. Did you --
A.
That I asked who?
Q.
Mr. Delano, I'm sorry.
A.
During the interview?
Q.
Yes.
A.
Okay.
Q.
So you testified -- well, you were asking him how many
employees did you have at Kremkov, right?
A.
Yes.
Q.
And he was having trouble giving you a number, right?
A.
Yes.
Q.
And you said come on, just give me a ballpark, kind of
like we just did.
A.
Right.
Q.
He was asking just to give him a ballpark, right?
A.
Right.
Q.
And then you asked him, you said let's say 2020, 2021,
that was your question, and I can -- if you want to look at
it?
A.
I remember that, yeah.
THE COURT: The jury will think -- again, remember
what a witness says is not necessarily the evidence -- or a
question is. Y'all will have to think about it.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 105 of 359
867
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
If he says that's what it was, maybe that's evidence,
too. But y'all will have to remember what the testimony was
in the transcript, or in the recording, and you will have it
back there, too.
BY MR. FINLAYSON:
Q.
And you remember, it was you asked him 2020, 2021,
correct?
A.
Yes.
Q.
That's two years, right?
A.
Yes.
Q.
He answered probably about 50, right?
A.
Again, if you -- he's -- 50 to 60. We can go back to the
transcript.
Q.
I can refresh your recollection if you want to be
refreshed.
A.
Sure.
Q.
Okay.
A.
Okay. Let's say 2020, 2021. He affirms.
THE COURT: Okay. Hold on. Hold on.
THE WITNESS: Probably about 50.
MR. FINLAYSON: That's good.
THE COURT: You guys know how to do this. You've
asked him. Now you can say does that refresh your memory.
THE WITNESS: Yes.
THE COURT: Okay. Now you have to testify from your
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 106 of 359
868
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
memory, not from what you read. Okay?
THE WITNESS: Okay.
THE COURT: All right. It's technical but that's the
way you've got to do it. Okay?
THE WITNESS: Yes.
BY MR. FINLAYSON:
Q.
So what you do now remember, sir?
A.
It refreshes my memory.
Q.
Well done. He said probably about 50, right?
A.
Yes.
Q.
In response to let's say 2020, 2021?
A.
Yes.
Q.
That's two years, right?
A.
Yeah, it was two years that were presented in the
question.
Q.
Okay. Now, you talked about the 941s, right?
A.
Yes.
Q.
The 941 forms were for 2020, weren't they, sir?
A.
Correct.
Q.
They're not for 2021?
A.
Correct.
Q.
There were no 941 and 940 forms for 2021?
A.
Not that we had.
Q.
Okay.
A.
The 493 employees that he listed on those forms were for
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 107 of 359
869
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
2020, though.
Q.
Thanks. So you talked about you found payments for
plastic surgery, right?
A.
Yes.
Q.
Now, let's be very clear. It's not for his face, right?
He didn't get plastic surgery --
A.
I mean, I can testify to what the document said it was
for.
Q.
Tell us. What did it say it was for?
A.
If you can refresh my memory on that, so...
Well, I mean I testified it was for gladiator -- it
was for gladiator abs.
THE COURT: Stop. Stop. Stop. You cannot refresh
his memory by pointing to a part of your body, Mr. Finlayson.
MR. FINLAYSON: Well --
THE COURT: If there's a document that indicates it,
you can show that to the witness.
Or you can testify about what you think you recall.
But let's just -- let's do it right without --
MR. FINLAYSON: Comedy.
THE COURT: Yes, or signaling. Let's just let the
jury get what really is evidence. I'm sorry to do this in
front of you. It's kind of making sausage right now.
Okay. But do you remember from your mind what it
was?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 108 of 359
870
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE WITNESS: I do. And it was for gladiator abs,
but there -- there was -- there was a lot of documentation on
that, the --
BY MR. FINLAYSON:
Q.
That's all I need.
A.
-- the medical records, so I wanted to make sure that I
got it absolutely correct.
Q.
Okay.
A.
But it was gladiator abs.
Q.
It was not his facial -- he didn't have his face
reconstructed?
A.
I don't recall anything about facial reconstruction on
the -- on the plastic surgery documentation.
Q.
Thank you. And you don't have any evidence that he's had
his face reconstructed or something like that, right?
A.
Not that I saw, no.
Q.
Okay. Now, when you interviewed him, he told you that he
was -- he had moved the money into -- he was putting the money
into FlyingJack, right?
A.
Yes.
Q.
And he told you that he intended to take it as a loan and
not asking for forgiveness, right?
A.
That's what he -- he stated, yes.
Q.
You learned along the way he was actually a pilot, right?
A.
Yes.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 109 of 359
871
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And did you find his pilot licenses and that sort of
thing?
A.
I don't recall if -- if I did or not. It's been three
years.
Q.
Okay.
A.
But I knew he was a pilot and I looked into that, yes.
Q.
Okay. You asked him about Monica Sweeten, right?
A.
Correct.
Q.
And I gather because you had seen the $40,000 transferred
in and out of -- I guess $40,000 went to her and came back or
came from her and went to her?
A.
I did see that, yes.
Q.
And you saw the money where there was actually a deposit
that came in for $40,000?
A.
I believe so. I also saw she was listed as an employee
for Kremkov Industries --
Q.
Well --
A.
-- as well on that 493 employee list.
Q.
Okay. Right. And that name, by the way, that was -- it
was just Monica Sweeten, right?
A.
Yes.
Q.
No middle name?
A.
I think it said Monica Sweeten.
Q.
No middle name?
A.
It said Monica Sweeten.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 110 of 359
872
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Thank you. No date of birth, correct?
A.
Correct.
Q.
No Social Security number?
A.
Correct.
Q.
So same possible name, but you don't know that it was her?
A.
Correct.
Q.
Okay. Now -- and to be clear she's not any kind of victim
in this case, right? She wasn't defrauded money or something
of that nature?
A.
She was a witness in the case.
Q.
Right. Okay. Now, and she -- I mean, she needed help
buying a house is what was going on, right?
A.
According to what the defendant told me is that she needed
help buying the house.
Q.
Okay. And you don't have any reason to dispute that, do
you?
A.
I would have to refresh my memory on the interview of
Monica Sweeten at that time.
Q.
That's okay. She testified already. It's okay.
A.
Okay.
Q.
All right. Now, let's talk about the list of 493 names.
So you looked at that list and some names caught your eye,
right?
A.
They did.
Q.
And we talked about Oliver Twist, right?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 111 of 359
873
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes.
Q.
Charlie Brown?
A.
Yes.
Q.
Keanu Reeves?
A.
Correct.
Q.
Bruce Willis?
A.
Correct.
Q.
A Gene Hackman, correct?
A.
Yes.
Q.
John Snow ring a bell?
A.
I don't remember John Snow on there, but there could be.
Q.
Right. And those jumped out at you, right?
A.
They were -- yeah, they jumped out.
Q.
Yeah. They didn't -- you thought maybe they weren't real?
A.
Based upon what the evidence had shown to that point,
it -- they were red flags.
Q.
Okay. And that would be a red flag to the bank as well,
wouldn't it?
A.
That you would have to talk to the bankers about and what
they actually look at.
Q.
Okay.
MR. FINLAYSON: One moment, Your Honor.
THE COURT: Yes.
MR. FINLAYSON: Nothing further, Your Honor.
THE COURT: Okay. Any redirect?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 112 of 359
874
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. EVERT: Yes, briefly. Thank you.
REDIRECT EXAMINATION
BY MR. EVERT:
Q.
So you were asked on direct [sic] examination about the
circumstances of the arrest, correct?
A.
Correct.
Q.
And did Mr. Delano talk to you about the circumstances of
the arrest?
A.
He did after we interviewed him.
Q.
Did he seem traumatized by that -- by that experience?
A.
Not at all. In a recording that I have of that
interaction actually shows that he chuckled when he asked me
that question.
Q.
We'd like to supplement the exhibit and add Government's
Exhibit 42 to the -- to what -- to the current exhibit that's
the recording. Or I guess it would just be a separate
exhibit.
THE COURT: Was it a recording of this portion?
MR. EVERT: We were able to get that.
THE COURT: Any objection?
MR. FINLAYSON: No. I mean, considering where we
are, I think it's appropriate, but I would renew the objection
from below.
THE COURT: Okay. So you're going to hear a little
bit more of the recording now, that includes this portion, it
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 113 of 359
875
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
sounds like. Okay?
Again, it might or might not have words on it, you
won't have the transcript portion when you go back there.
Okay?
All right. Go ahead, please.
MR. EVERT: If we can go ahead and play that, please.
(Whereupon, the recording was played)
BY MR. EVERT:
Q.
All right. Thank you. So how would you describe
Mr. Delano's tone when he was talking about the takedown?
A.
He was very calm. He didn't seem concerned. He wasn't --
he didn't seem afraid or scared. And everything that -- I
mean, I informed him that he could refuse whatever he wanted
to refuse and he continued to voluntarily speak with me.
Q.
And when you interviewed him, did -- did Mr. Delano
specifically say that he used the PPP money for -- did he tell
you that he used the tax money to buy the house?
A.
If he's -- if he's labeling his personal money as the tax
money, he could have meant that. He said he did not use the
PPP money, he used his personal money. The only money --
additional money I found in his accounts was the tax money.
Q.
And were -- was the tax money -- how -- how would you
distinguish between the tax money and the PPP money?
A.
When it's commingled, you can't. You look at the
beginning balance and you see what the flow -- the flow of
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 114 of 359
876
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
funds are and you kind of run a daily balance of -- and I --
you know, I didn't do the detailed financials of that, but
when you run a daily balance, you can see what that balance is
and compare that to the purchases.
Q.
And were those two sources of money, were they both in the
same account?
A.
They were, yes. Initially, yes.
Q.
And defense counsel asked you if you looked at any
international banking records, correct?
A.
I did not identify any international banking records.
Q.
And did you ask Kremkov Industries if -- if -- for any
records they had that might be relevant to this case?
A.
I believe I did subpoena Kremkov for -- for those records,
yes. And I did not receive anything. I believe I subpoenaed
Kremkov Industries as well as FlyingJack. And there was no
documentation that was returned.
MR. EVERT: If we could pull up Government's
Exhibit 406, please.
BY MR. EVERT:
Q.
So defense counsel asked you -- what -- what is this
exhibit?
A.
That was the purchase of the 2014 Lamborghini.
Q.
So defense counsel asked you if Mr. Delano purchased the
Lamborghini in his own name, right?
A.
Yes.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 115 of 359
877
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And if we go to the next page, whose name is on it?
A.
It's Karl Lucius Delano is the buyer.
Q.
But then if we go to the next page, Page 3, where did the
wire come from that paid for that, that paid $269,999 for
that?
A.
It was an incoming wire from FlyingJack Freight and
Logistics for $269,999.80.
Q.
And defense counsel asked you -- you know, you asked him
to ballpark how many employees Kremkov Industries had, right?
A.
Correct.
Q.
Would you say that 50 or 60 is in the same ballpark as
493?
A.
No, it is not. And that's what I was getting at during
the interview.
Q.
And you also asked -- you asked him how many employees he
had in 2020 and 2021, right?
A.
Yes.
Q.
Did you also ask him what was the maximum number of
employees he had?
A.
Yes.
Q.
Did he ever -- did he -- any number that was anything
close to 493?
A.
He did not, no.
Q.
If someone misrepresents what -- if someone obtains money
fraudulently, is that their personal money?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 116 of 359
878
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
No.
Q.
And if somebody says -- if somebody misrepresents
information to the IRS in order to get a return and they, in
fact, get a -- get money from the IRS, does that mean that
that money is their personal money?
A.
No.
MR. EVERT: Nothing further. Thank you.
MR. FINLAYSON: Very briefly.
THE COURT: Okay.
RECROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
You just said that -- we heard a second recording, right?
A.
Yes.
Q.
And you said Mr. Delano did not seem scared when he was
talking to you, I guess in that recording?
A.
Yes.
Q.
He said he was scared in that recording. We just heard
it, right?
A.
Yes.
Q.
And he was complaining about the AR16s and the guns that
were displayed on him?
A.
Yes.
Q.
He said you could have just come to my house, I would have
come out, right?
A.
Yes, after he chuckled.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 117 of 359
879
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
So you think he was happy about it?
A.
His -- his demeanor at the time, he was not -- he was not
scared. He -- he said he was scared and that's what the
reporting captured, but he was not scared. And you could tell
in his demeanor in the recording.
Q.
So ten agents take him down, put him face down on the
ground.
A.
He wasn't -- he wasn't scared at the time of the
interview. He was not under duress. I mean, obviously that's
going to startle you. And he was scared -- he may have been
scared at that time.
And that's why I testified that there was a time
period of a cooling off period before I actually started
interviewing him and reading him his rights. And he
ultimately agreed to voluntarily interview.
Q.
Are you a mind reader, sir?
A.
No.
Q.
So whether he was scared or not --
A.
I just testified that he probably was scared --
THE COURT: Hold on.
THE WITNESS: -- at the beginning of the arrest.
BY MR. FINLAYSON:
Q.
He probably was scared?
A.
Yes.
Q.
Most people would be scared if ten agents with guns put
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 118 of 359
880
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
them face down on the ground, wouldn't they?
A.
I would be, too. And then what transitioned after the
fact is what is in question. The demeanor at that point
during the interview.
Q.
Do you have --
A.
His state of mind and his demeanor, his actions, you know,
we -- we try to look at all of that stuff.
Q.
And he brought this -- you guys had already stopped
recording and he brought this up, right?
A.
Yes.
Q.
And he -- so you started recording again?
A.
Yes.
Q.
And he said you didn't have to do this, you didn't have to
come with these M16s and AR15s. That's what he said, right?
A.
What the recording -- the recording speaks for itself.
Q.
I can't remember, I'm sorry, the type of guns.
A.
Yeah.
Q.
But guns. And he said he was scared. That's what he
said?
A.
Yes.
Q.
Okay. Now, moving on, you did not locate any foreign
business records, right, or foreign bank accounts, right?
A.
Yes.
Q.
You just testified that you had issued subpoenas on
Kremkov, right?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 119 of 359
881
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Correct. If I'm not mistaken, I believe -- I believe I
did. If we can refresh my memory if we have those subpoenas.
But I recall that, yes, I did issue subpoenas to
Kremkov Industries and FlyingJack.
Q.
Okay.
A.
And I received no records in return.
Q.
And that -- that was after May the 12th of 2022, right?
A.
I believe it was. I mean I believe I issued them to his
attorney, emailed them to his attorney.
Q.
Right. And that was after he was arrested and in jail,
right?
A.
Yes.
Q.
Thank you.
A.
Yes.
THE COURT: Anything on re-redirect?
MR. EVERT: One question.
FURTHER DIRECT EXAMINATION
BY MR. EVERT:
Q.
When you were interviewing Mr. Delano, did you have any
concern that he was so scared that he didn't know what he was
talking about?
A.
No, I had no concerns with that.
MR. EVERT: No further questions. Thank you.
THE COURT: Okay. May the witness be excused?
MR. FINLAYSON: Yes, sir.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 120 of 359
882
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. EVERT: Yes.
THE COURT: All right. Thank you, sir. Appreciate
your time.
Next.
MS. CONNORS: The United States calls Adrienne
Richardson.
THE COURT: Come on up.
- - -
ADRIENNE RICHARDSON,
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: Adrienne Richardson, A-D-R-I-E-N-N-E,
Richardson, R-I-C-H-A-R-D-S-O-N.
COURTROOM DEPUTY: Thank you. You may be seated.
DIRECT EXAMINATION
BY MS. CONNORS:
Q.
Ms. Richardson, can you tell the jurors where you're
currently employed?
A.
Here at the United States Attorney's Office.
Q.
And what's your position with the United States Attorney's
Office?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 121 of 359
883
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
I am a forensic auditor.
Q.
And how long have you been in that position?
A.
About eight and a half years.
Q.
And prior to working with the U.S. Attorney's Office, did
you have any other training and experience in any kind of
auditing activities?
A.
Yes. Actually, I've been an auditor probably about 25
years.
Q.
And what about do you have any certifications relevant to
your position as an auditor?
A.
Yes. So I am a certified fraud examiner, I'm a certified
economic crimes forensic examiner, and I am certified forensic
investigator.
Q.
Now, in terms of working as an auditor, what are some of
the things that you do?
A.
So as an auditor, you go through and here at the
United States Attorney's Office, I review bank statements, any
type of financial documents to try to create some type of
money flow chart for the attorneys in the cases that they're
working on.
Q.
And in regards to the case involving Karl Delano, formerly
known as Carl Torjagbo, is that what you did?
A.
Yes, umm-hmm.
Q.
So did you have access to certain records that had been
collected as part of the investigation in this case?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 122 of 359
884
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes, I did.
Q.
And what kind of records did you have?
A.
So I had bank records, credit card statements and auto
statements.
Q.
And in regards to bank records, were there some specific
banks that you were looking at the records from?
A.
Yes.
Q.
What were those?
A.
So I reviewed statements from Bank of America, Chase Bank
and PNC Bank.
Q.
Now, in terms of those accounts, were those personal
accounts or business accounts?
A.
They were both.
Q.
Now, in terms of specifically the identified exhibits that
have been involved in this case, prior to testifying, did you
have an opportunity to review the marked exhibits from the
government?
A.
Yes, I did.
Q.
And in terms of some of those records, are the bank
records contained in Government's Exhibits 103, 103A, and 301
through 304, including any sub exhibits, items that you
reviewed?
A.
Yes, they were.
Q.
Did you also review signature cards for accounts?
A.
Yes, I did.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 123 of 359
885
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And did you also review Government's Exhibit 305 related
to a Bank of America account?
A.
Yes, I did.
MS. CONNORS: And, Your Honor, I would just note for
the record, all of those have previously been admitted.
THE COURT: Okay.
BY MS. CONNORS:
Q.
Now, did you -- you mentioned some credit cards. What
credit card accounts did you look at?
A.
So Chase and PNC.
Q.
And in regards to Chase, if you can tell us, was that
Exhibit 310 for the government?
A.
Yes, I do believe it was.
MS. CONNORS: Now, let me check. I don't believe
that 311 and 310 have been previously admitted.
BY MS. CONNORS:
Q.
So if you could look in the binder. And we do have
several binders. There's also another one right there. It
will be the one that says 300 exhibits.
A.
Let me get my glasses on. That's two.
Q.
And I apologize, I think we can actually avoid that,
because it looks like we did go ahead and admit those
Governments 311, 313, were there some PNC credit cards that
you looked at?
A.
Yes, there were.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 124 of 359
886
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Okay. Now you also mentioned an auto loan.
A.
Yes. Yes, it was Wells Fargo auto loan.
Q.
Okay. Now that one I think we have not admitted yet.
MR. EVERT: Correct.
MS. CONNORS: Correct. Okay.
BY MS. CONNORS:
Q.
So for Exhibit 314, could you look in that binder and look
at those records?
A.
Hang on. Yes.
Q.
Okay. Are -- now, that's a thick binder.
A.
Voluminous, voluminous.
Q.
So, Ms. Richardson, in regards to Exhibit 314, are those
records related to the auto loan that you reviewed?
A.
Yes, they are.
MS. CONNORS: Your Honor, I would move to admit
Government's Exhibit 314.
MR. FINLAYSON: No objection.
THE COURT: Okay. It's admitted. Thank you.
BY MS. CONNORS:
Q.
And did you also review any purchase records as part of
your activities in this case?
A.
Oh, yes, I did, um-hmm.
Q.
Okay. And were those purchases of some particular types
of items?
A.
Yes. Yes, they were.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 125 of 359
887
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
What are some examples?
A.
So I reviewed the purchase of several vehicles as well as
several real estate purchases.
Q.
Okay. Did you also look at records related to a yacht
down payment?
A.
Oh, yes. Um-hmm. Yeah, there was a yacht.
Q.
And in terms of vehicles, would that have been like car
purchases as well as truck and trailer purchases?
A.
Trucks and trailers, yes, um-hmm.
Q.
Now, Ms. Richardson, to prepare for your testimony, did
you summarize the bank records?
A.
Yes. I wouldn't dare let you flip through all of this.
Q.
Okay. And is that because they are indeed voluminous
records?
A.
Very voluminous, yes.
Q.
And if you would look at Government's Exhibit 501, which
is likely in a much smaller binder.
A.
Okay. Excuse me, everyone. Your Honor.
THE COURT: You're fine.
THE WITNESS: That's smaller. Oh, yes.
BY MS. CONNORS:
Q.
And, Ms. Richardson, do you recognize that exhibit?
A.
Yes, ma'am.
Q.
And what is it?
A.
So this is my version of summarizing all of the financial
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 126 of 359
888
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
information into a smaller format.
Q.
Okay. And to create that summary exhibit, did you use the
records that we just discussed in terms of bank records, other
financial documents, purchase records, essentially anything
that may be an exhibit?
A.
Yes, I did.
Q.
And in terms of the content in that exhibit, does it
accurately reflect the information contained in all of those
records?
A.
Yes, it does.
MS. CONNORS: Your Honor, I would move to admit
Government's Exhibit 501.
MR. FINLAYSON: No objection for this purpose.
THE COURT: Okay. We'll talk about the caveat there
at a break.
MR. FINLAYSON: Fair.
THE COURT: All right. But 501 is admitted.
MS. CONNORS: Thank you, Your Honor.
And if we can go ahead and bring up Exhibit 501.
BY MS. CONNORS:
Q.
Now, Ms. Richardson, this is 27 pages under one exhibit.
A.
Um-hmm.
Q.
So if we're referring to any of the specific pages, if
you'll point out the page number, that would be helpful.
A.
Absolutely.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 127 of 359
889
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And if you don't, hopefully, I will remember.
A.
Yes, ma'am.
Q.
But in terms of Page 1, what is this -- what information
is being summarized?
A.
So on Page 1, I basically went through all of the bank
statements and put a listing of what bank name, the name that
was on the account, the account number and the date that that
account was opened.
Q.
And if you can look in terms of the first three
accounts --
A.
Umm-hmm.
Q.
-- were they all opened on the same day?
A.
Yes, ma'am. June 1st, 2015.
Q.
And for those particular accounts, are those business
accounts or personal accounts?
A.
Those are personal accounts.
Q.
Now, in terms of the next two accounts, one with Chase and
one with PNC --
A.
Um-hmm.
Q.
-- are those business or personal accounts?
A.
Those are business accounts.
Q.
And what's the name of the business on the account?
A.
Kremkov Industries, LLC.
Q.
And when were -- when were those accounts opened?
A.
So the one at Chase was opened on January 25th of 2021.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 128 of 359
890
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
And the one at PNC was opened January 28th of 2021.
Q.
And then finally, there's a Bank of America account. When
was that account opened?
A.
So that account was opened on August the 26th, 2021.
Q.
Now, in terms of the deposits into the initial accounts,
were you able to review some information about those personal
accounts?
A.
Yes, I was.
MS. CONNORS: And if we can go to Page 2.
BY MS. CONNORS:
Q.
And what is this page reflecting?
A.
So this is a summary of the deposits for the year of 2020,
that actually shows you for the three accounts that were open
at that timeframe, I summarized the accounts ending in the
last four digits, so we didn't have to put the entire account
number, so it would be for the account ending in 9814, the
9822 and 9849.
Q.
And again, these accounts had been opened since 2015?
A.
Yes, they were.
Q.
Why were you focusing on 2020?
A.
So the PPP application was actually submitted with tax
documents as well as payroll for the year of 2020, so I
started my analysis from that point.
Q.
Okay. And in terms of what we just saw on Page 1 --
A.
Umm-hmm.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 129 of 359
891
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
-- did you review any bank accounts under
Kremkov Industries that were opened in 2020?
A.
There were no bank statements opened in -- for Kremkov in
2020.
Q.
Is that because those accounts weren't open until January
of 2021?
A.
Yes, these were not opened until January of 2021.
Q.
Okay. And are you -- were you also reviewing tax -- other
tax documents that were involved in this case?
A.
For?
Q.
For the calendar year or tax year 2020?
A.
Yes, yes, yes.
Q.
So was that an additional reason why you're focusing on
2020 as the year for the deposits?
A.
Yes, yes.
Q.
Now, if you can explain just these categories, some of
them may appear self-explanatory, but I want to make sure that
we can get it all on the record. In terms of bank credit,
what was that?
A.
So with the bank credit, any time you have -- like if
someone has -- you have a dispute with the bank and you want
them to -- like you're saying that's not my charge, I want
that money back. That was a good bit of that money.
And then the other credit would be like if they
charged you, say, a banking fee for an ATM fee, but yet they
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 130 of 359
892
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
should not have charged you, so they refund you that money
back, that is that money also.
Q.
Okay. Cash in is just cash --
A.
Cash in the door, yes, ma'am.
Q.
Okay. And then a check or was that multiple checks?
A.
No, that was one check. And then the interest payment
would be the amount of money that the bank actually gives you
interest on your account for holding money in their bank.
And then the U.S. Treasury check was a stimulus check
that a lot of people got, you know, from -- during COVID.
Q.
And in terms of these deposits into this account, you have
a note on this summary. Are there other transactions that are
not reflected?
A.
So there were transfers in between the accounts, whenever
you transfer money like from your savings to your checking,
and this, that and the other, for fear of double counting, I
did not include transfers going back and forth, because that's
all the same money.
Q.
Okay. And so in terms of deposits into these three PNC
accounts during 2020, what was the total?
A.
The total amount was $2,139.36.
Q.
Now, that's additional deposits in 2020.
A.
Um-hmm.
Q.
At the outset of 2020, was there money in the -- in these
bank accounts?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 131 of 359
893
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Prior to 2020, correct, yes, there were, um-hmm.
Q.
Okay. So were you able to look at -- through the calendar
year 2020 any kind of disbursements on the account?
A.
Yes, I did see.
Q.
Did you see disbursements?
A.
Yes.
MS. CONNORS: And if we can move to Page 3 of the
exhibit.
BY MS. CONNORS:
Q.
Is that what is reflected here?
A.
Yeah. So this is a summary of the disbursements for that
same timeframe, for the year of 2020, for the same three
accounts in totality.
Q.
Okay. So we just saw there's not -- there's not a
significant amount of deposits coming in, but there is money
going out of that account?
A.
Correct, yes.
Q.
Now, for the disbursements, were you also excluding any
potential account-to-account transfers?
A.
Yes, I did not include any transfers in between savings,
checking or whatever accounts.
Q.
Okay. And can you give the jury an idea of how you kind
of categorized the different disbursements?
A.
Sure. So like for the one that says credit card loan and
it says Chase, instead of listing, say, 12 payments to Chase
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 132 of 359
894
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Bank, I just lumped them altogether to Chase Bank, correct.
And same thing with if you do PNC, the same thing with
Wells Fargo Auto, so that would be -- so I basically just
summarized so we just didn't have a whole lot of, you know,
transactions listed right there together.
Q.
So would that be the same thing for like food and drink --
A.
Yes.
Q.
-- it might have been multiple purchases at --
A.
Absolutely. So this is literally for the entire year of
2020, so you figure from January 1 to the 31st of December for
all three of the accounts. This is where all of the
transactions that took place.
Q.
Okay. And just to confirm, at the beginning of 2020,
there was a balance in the account that would have been able
to cover these disbursements?
A.
Yes, ma'am, it was. Yes, um-hmm.
Q.
And in terms generally of any money that had come in that
was available in these accounts in 2020, what was the source?
A.
So there were some wires that had come in that I saw that
were in 2019 that actually was about -- they came in and they
sourced this money. So at the beginning of 2020, when I added
all of the accounts together for beginning balance of 2020, it
was a little bit over $66,000 for all three accounts.
Q.
Okay. Now, if we can go to -- let's see. And let's see.
In terms of your review, sorry, before we move on, in terms of
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 133 of 359
895
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
these disbursements --
A.
Um-hmm.
Q.
-- were you able to find any disbursements that appeared
to be consistent with ongoing payroll payments?
A.
Oh, no. I did not see any payroll payments.
Q.
Did you see any disbursements that would appear consistent
with operating a business?
A.
No, ma'am.
Q.
And what would be you looking for, for those things?
A.
So whenever you're looking at business expenses, like most
people, you have payroll expenses, you might have some
accounting expenses, some rent that you pay, you know,
utilities or what you have and none of that was available.
MS. CONNORS: Okay. Let's see. Okay. And if we can
go to Page 4.
BY MS. CONNORS:
Q.
And what is summarized on this page?
A.
So at this point, this is the summary of all of the
accounts that were open as of March 28th of 2021. So as you
see, you've also -- I've now included Chase Bank with Kremkov
and PNC that has Kremkov. So this would be the balances for
all five of the accounts now as of March 28th of 2021.
Q.
And in terms of the total, has it decreased from what you
were seeing at the beginning of 2020?
A.
Yes, um-hmm. Yeah, yeah, yeah.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 134 of 359
896
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And why was it that you selected March 28 of 2021 to
summarize the balances?
A.
So I was looking to see how much money was actually in the
accounts prior to the PPP money actually being deposited into
the accounts.
Q.
And so that we're specific, in terms of Chase Bank on
March 28th of 2021, what was the balance in
Kremkov Industries' account?
A.
For Chase Bank it was $105.
Q.
And for PNC Bank, the Kremkov account ending in 9499 what
was the balance on March 28 of 2021?
A.
It was $107.10.
Q.
And I think you already mentioned it, was there a deposit
into one of these accounts on March 28th -- or, I'm sorry,
March 29 of 2021?
A.
Yes, ma'am. Yes, there was.
Q.
And what was that deposit?
A.
That deposit was the $9 million for the PPP from
Chase Bank, yeah.
Q.
Okay.
MS. CONNORS: And if we can go to Page 5.
BY MS. CONNORS:
Q.
Is that what is reflected here?
A.
Yes, ma'am. This is actually the image from the bank
statement that shows me the deposit that was made into the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 135 of 359
897
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Kremkov account ending in 8755.
MS. CONNORS: And then if we can go to Page 6.
BY MS. CONNORS:
Q.
And so, Ms. Richardson, can you explain what happened
after that $9.5 million PPP loan went into the Chase Bank
account?
A.
Yes. So this slide is actually giving you information
regarding the deposit. It shows you that as of the 29th of
March, the loan actually came in for the 9.5, it went into the
Chase account in the form of an electronic deposit.
Then on April the 9th of 2021, there was a check that
was written from that same Chase account for $3 million.
Q.
And after that check is written, does something else
happen?
A.
Yes, ma'am. As soon as the check itself is written, it's
actually deposited over into the account at PNC of 9499. And
PNC then, in turn, that account sends $100,000 transfer over
to one of the other accounts that's 9849.
Q.
Okay.
MS. CONNORS: And can y'all pull up Exhibit 301B for
me, please.
BY MS. CONNORS:
Q.
Ms. Richardson, is this a copy of the $3 million check
that you were just referencing?
A.
Yes, ma'am, um-hmm.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 136 of 359
898
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And you indicated that this check gets deposited, so which
account does it get deposited into?
A.
So this goes over to the PNC account that is the 9499.
MS. CONNORS: And if you can zoom out of that.
BY MS. CONNORS:
Q.
Is -- like at the very bottom, there's a series of some
numbers there. The one on the bottom, does it end 9499?
A.
Yes, ma'am.
Q.
Okay. Is that reflecting where that check was deposited?
A.
Yes, ma'am.
Q.
Now, is 9499 one of the other accounts that is in the name
of Kremkov Industries?
A.
Yes, ma'am.
MS. CONNORS: And if we can go back to Exhibit 501.
And go to Page 4, please.
BY MS. CONNORS:
Q.
And to remind the jury, what was the balance on -- in that
PNC account before the PPP money is received?
A.
So prior to, for the Kremkov account ending in 9499, the
balance is $107.10.
MS. CONNORS: Now, if we can go to Page 6 of this
exhibit.
BY MS. CONNORS:
Q.
What ends up -- so you've already talked a little bit
about what happens after that $3 million check gets deposited
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 137 of 359
899
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
into 9499.
A.
Um-hmm.
Q.
Does it go to another account?
A.
Yes.
Q.
Or a portion of the money?
A.
Yeah. So a portion of the money at that point on April
the 19th of '21, there is a $100,000 internal transfer that
goes from 9499 to 9849.
Q.
And 9849 is an account in what name?
A.
Carl Torjagbo.
Q.
Is it a business account?
A.
No, this is a personal account.
MS. CONNORS: And if we can pull up Exhibit 302B and
go to Page 2. There you go. And then if you will -- there's
a deposit and other additions.
BY MS. CONNORS:
Q.
And in that very top portion, is that what is reflected
there, that $100,000 transfer?
A.
Yes, ma'am. So this is actually the copy of the actual
bank statement that shows that the wire transfer was done
online from this account over -- you know, from the 4 --
excuse me, the 9499 to the 9849.
Q.
Okay. And now they're also showing on the screen there's
online and electronic banking deductions.
A.
Yes, ma'am.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 138 of 359
900
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Are there transfers after that $100,000 goes into 9849, or
then -- is the money then getting transferred out of 9849 to
different accounts?
A.
Yes, ma'am, including on the same day. So on April the
19th when the $100,000 comes in, a full $50,000 comes right
back out of that account over to 9814.
And then shortly thereafter, like the next day,
there's one for $10,000 that goes over to that same 9814
account and so on.
MS. CONNORS: And if we can zoom out of that. And if
you'll zoom in on that daily balance detail.
BY MS. CONNORS:
Q.
In terms of the daily balance --
A.
Um-hmm.
Q.
-- the daily balance for April 19th is identified, and
that's the date that the $100,000 gets transferred?
A.
Yes. Yes, ma'am. Yes.
Q.
Okay. Now before that, the next balance that was
provided, it was a little bit over $10,000?
A.
Yes, ma'am. Yeah, um-hmm.
Q.
And you had indicated that even on April 19th, after that
$100,000 comes in, transfers are going back out?
A.
Immediately, yes.
Q.
So is that why instead of the balance saying $100,000
plus, it's $60,000?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 139 of 359
901
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes, ma'am. Yes.
Q.
All right. Okay.
MS. CONNORS: If we can go back to Exhibit 501 and go
to Page 7. Thank you.
BY MS. CONNORS:
Q.
And so just to be able to go through some of those
transfers, is that what is reflected here?
A.
Yes. So I tried to make it easier on you to be able to
see that this is how the money flow was going from -- on the
19th, the $100,00 goes into 9849 and it immediately comes from
9849 on the 19th, the $50,000 goes over to 9814.
And then the very next day, $10,000 goes to 9814.
And then two days later, another $20,000 goes to 9814. And
then three days after that, another $21,000 actually ends up
going over to 9814.
Q.
And in terms of these transfers --
A.
Um-hmm.
Q.
-- the maximum amount in that account prior to the
$100,000 deposit was $10,000; is that right?
A.
From the day -- yes, um-hmm.
Q.
And so while this money comes in, $50,000 is going out --
A.
Um-hmm.
Q.
-- $50,000 transfer could only be a part of at least --
would have to be at least a part of the 100,000?
A.
It would have to be a part of the $100,00, yes.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 140 of 359
902
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Okay.
MS. CONNORS: And if we can go to Page 8. Thank you.
BY MS. CONNORS:
Q.
And, Ms. Richardson, what is being reflected in this
summary?
A.
So at this point, I went through and looked at the account
that was the 9814, since it got so many of the transactions, I
wanted to see like what was the balance before the transfers
came in. And then what would it end up being at the end of
the same timeframe.
So once all of the transfers come in, the $50,000,
the $10,000, the $20,000, the $21,000, it ends up with a
balance of 20,000, but it started at 91 -- $9,100.
Q.
And so that ending balance there --
A.
Umm-hmm.
Q.
-- that's where we were -- are on April 26?
A.
April 26, yes, ma'am.
Q.
And on April -- after April 26, did something else happen?
A.
Yes.
Q.
And what was that?
A.
So there were credit card payments and loan payments that
started going -- going out from the 9814 account.
Q.
Okay.
MS. CONNORS: And if we can go to Page 9.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 141 of 359
903
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MS. CONNORS:
Q.
And could you explain what this summary is -- represents?
A.
Sure. So when I was looking at the 9814 account for that
same timeframe where we saw all these wires coming in the door
from the other account, I was looking to see what payments
were actually being disbursed.
At this point, on April the 22nd, there was a wire
for $17,000 that went out to O’Kelley & Sorohan for a real
estate down payment.
On the 23rd, there was an Internet payment that was
made to Chase Bank for $10,031, and this was for a personal
credit card at Chase Bank.
And then on the 23rd also, there was an Internet
payment of a little over $6,400 to Synchrony that was a
personal credit card.
On the 26th of April, there was a check payment that
was made to Wells Fargo Auto for approximately $24,799.
And then a -- on the same day, the 26th, a check
payment was made for a little over $23,000 to PNC Bank, which
that was a line of credit at PNC Bank.
Q.
Okay. And so in relation to these expenditures --
A.
Um-hmm.
Q.
-- at -- before the PPP money came into any account, would
there have been a balance to cover $81,000?
A.
Oh, no. Huh-uh, no.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 142 of 359
904
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Okay. And are all of these credit card payments going out
after that initial $100,000 is transferred of the PPP money?
A.
Yes.
Q.
Now, are you aware -- well, let me ask you, in terms of
April 26th being kind of your cutoff date here, was there a
reason for that?
A.
Yes. So after April the 26th, there was an IRS check that
was deposited.
Q.
Okay.
MS. CONNORS: And if we can pull up Exhibit 301C.
BY MS. CONNORS:
Q.
Is this a copy of the IRS check?
A.
Yes, it is.
Q.
And which account did this money go into?
A.
This one went into the 9499.
Q.
And how much was this check?
A.
This check is $3,366,240.76.
Q.
And who was the check issued to?
A.
Carl Torjagbo.
Q.
And what account was this check deposited into?
A.
It was deposited into 9499.
Q.
Is 9499 a bank account for Kremkov Industries?
A.
Yes, it is.
Q.
So even though this check was written as a personal check,
it goes into a business bank account?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 143 of 359
905
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
That is correct.
Q.
And is that the same bank account that had already
received the $3 million payroll check deposit?
A.
It is, yes.
MS. CONNORS: And if we can go to -- pull back 501
and go to Page 11.
BY MS. CONNORS:
Q.
Now, at this point, is the money from PPP and the IRS tax
refund converged in the same account?
A.
Yes, it has.
Q.
And so at that point, what is the balance in the account
that has received both of those payments?
A.
So for the 9499 account, the balance would end up being on
the 27th of April, 2021, $6,266,327.86.
Q.
Now, after that money goes -- the IRS money gets deposited
into 9499, what happens?
A.
So then there is a wire transfer that happens.
Q.
Okay.
A.
After that timeframe.
Q.
Okay.
MS. CONNORS: If we can go to Page 11 please. I'm
sorry, Page 12.
BY MS. CONNORS:
Q.
And, Ms. Richardson, can you explain what this page is
reflecting?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 144 of 359
906
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
So this is a summary of transfers between May 10th of '21
and May 11th. The account balance for 9849 was actually
$7,300. And then there is a wire that happens on May the 11th
of '21 that comes from 9499 to the 9849 account in the amount
of $6 million.
Q.
Okay. And just to confirm, is 9499 where the PPP money,
the $3 million of PPP money went into and the IRS tax refund
check?
A.
Yes, it is.
Q.
Prior to either one of those deposits, would 9499 -- did
9499 have over $6 million in it?
A.
No.
Q.
And did it only have essentially $100, $107 in it?
A.
$107.10.
Q.
Okay.
MS. CONNORS: And if we can go to Page 13.
BY MS. CONNORS:
Q.
What happened after $6 million gets transferred?
A.
So this slide actually shows you all the transactions from
May the 12th of '21 through April 30th of '22. And this shows
you the purchases that were made and transfers that were done
from the 9849 account.
Q.
And again, is 9849 a personal account?
A.
Yes, it is a personal account.
Q.
And what was the total amount of disbursements from 9849?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 145 of 359
907
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
It was $4,208,888.37.
Q.
And is that money -- was that spent from PPP money and IRS
tax refund money?
A.
Both, yes.
Q.
Did this account have any -- in total with his accounts,
did he have anywhere close to that amount of money in his PNC
accounts prior to the PPP money and the IRS tax money coming
in?
A.
No, huh-uh.
Q.
And in terms of this summary from the time period of May
2021 to April of 2022, you have deposits listed as well to
9849?
A.
Yes.
Q.
What's the one deposit?
A.
So this would be interest that's accruing on the account
every month, so this is a cumulative of them. So it would be
$1,994.87.
Q.
And in terms of the disbursements on the account, what
types of disbursements did you see?
A.
So I saw purchases as well as a lot of transfers between
accounts.
Q.
And did you summarize some of these specific purchases?
A.
Yes, I did.
Q.
Okay.
MS. CONNORS: And if we can go to Page 14, please.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 146 of 359
908
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MS. CONNORS:
Q.
And, Ms. Richardson, are you familiar with the defendant's
purchase of a house in Marietta as Greythorne property?
A.
Yes, I am.
Q.
And does this page summarize information related to that
purchase?
A.
Yes, it does.
Q.
Okay. And can you explain?
A.
So this particular slide shows you the transactions that
would have gone directly for the purchase of the property at
Greythorne. So on the -- and I kept it with the $100,00 that
we already knew.
So on the 19th of April, you saw again the $50,000
that was transferred from 9849 to 9814. And then again from
9814 -- from 9849 to 9814, there was the same day another
$10,000.
And then you have a down payment for the home that
happens from that same 9814 account, it's wired out to
O’Kelley & Sorohan for $17,000, that's the down payment of
that home.
And then the transfer that happens on May the 11th,
from 9499 to 9849 for $6 million, that is actually also
funding the wire for the purchase of the home at closing on
May the 28th for the amount of $1,660,861.01.
MS. CONNORS: Okay. And if we can pull up
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 147 of 359
909
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Exhibit 302A.
BY MS. CONNORS:
Q.
And is this the wire transfer record for the $1.6 million
for the house?
A.
Yes, ma'am, it is, um-hmm.
Q.
Okay.
MS. CONNORS: And if we can go to Page 2 of that
exhibit at the top.
BY MS. CONNORS:
Q.
Did -- did that money go to a First Citizen's Bank & Trust
account?
A.
Yes, it is.
Q.
And to confirm, the money was being sent out of a PNC
account?
A.
That is correct, yes, ma'am.
Q.
The defendant's PNC account?
A.
Yes, that is correct.
Q.
And what was the source of this transaction?
A.
The $6 million transfer.
Q.
Without the $6 million transfer, would there have been
sufficient funds in that account to send a $1.6 million wire?
A.
No, it would not.
MS. CONNORS: And if we can pull up 501 again. Thank
you.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 148 of 359
910
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MS. CONNORS:
Q.
Are you familiar with a purchase of a piece of property
located at Fiber Drive?
A.
So Page 15 does show that this is the transactions for the
property for Fiber Drive.
THE COURT: Is this a good time for lunch?
Or do you have another better stopping spot in the
next 10 or 15 minutes?
MS. CONNORS: It will take longer than that, so maybe
it is a good time.
THE COURT: Okay. Y'all ready for lunch?
All right. We're going to have our lunch break.
Don't talk about the case, talk about other stuff. The Braves
stunk it up again yesterday, so stay away from that topic.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Okay. We will see you guys in about 55
minutes, because we're going to spend a couple of minutes on
these instructions.
And I know that means you've got to work over your
lunch hour, but I don't know if we're going to close today.
Do you think we're closing today?
MS. CONNORS: I would guess not, because -- I mean
especially I'm guessing it would take at least 30 minutes to
do the instructions.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 149 of 359
911
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: Is this your last witness.
MS. CONNORS: She is, yes.
THE COURT: And then do you anticipate putting on a
case?
MR. FINLAYSON: I do. I have two short witnesses and
then Mr. Delano.
THE COURT: We might get there. How long do you
think your closing will be?
MS. CONNORS: I do anticipate it's going to be at
least 45 minutes, potentially closer to an hour.
THE COURT: All right. We're not going to close
today then.
MS. CONNORS: Okay.
THE COURT: I mean, it just seems like we'd be
rushing it, because you've got to both get done and stuff.
So we'll come back in an hour and talk about this at
the end of the day. Okay?
But I want firm thoughts on this at the end of the
day and then we'll close first thing in the morning. Okay?
But we will get all the evidence in today. Okay?
That will give them most of the day tomorrow to deliberate.
And then at the end of the day, y'all will have to
think now, think down the road, what we're going to do with
the young lady who starts a brand-new job that she's really
excited for on Monday. And if we don't let her go, she will
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 150 of 359
912
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
be behind and miss starting with her peers. I have no opinion
on it. Y'all do whatever you want. But you-all will have to
let me know what you think. Okay?
MS. CONNORS: Thank you, Your Honor.
MR. FINLAYSON: Thank you.
(Whereupon, a lunch recess was taken.)
THE COURT: Okay. Y'all can be seated.
The marshals wisely reminded me that we're going to
take a -- if the defendant is going to testify, I need you to
just say, Judge, can I have a couple of minutes so that he can
move up here outside the presence of the jury, because I think
he's still shackled, right?
Yes, okay. So we're all on the same page.
I appreciate the marshals reminding me of that.
All right. You can bring them in.
MS. CONNORS: Oh, I thought -- are we doing anything
with the jury instructions?
THE COURT: No. We're doing them at the end of the
day.
MS. CONNORS: Oh, at the end of the day.
THE COURT: I took back our lunchtime.
MS. CONNORS: Sounds good.
THE COURT: Yes.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 151 of 359
913
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: All right. Y'all can be seated.
Okay. Go ahead.
MS. CONNORS: Thank you, Your Honor.
BY MS. CONNORS:
Q.
Okay. Ms. Richardson, right before the break we were just
getting into this page, so I think you already mentioned some
information, but just so we can backtrack and make sure that
we get the full picture here, can you explain what's being
described on Page 15 of Exhibit 501?
A.
Sure. So this is a slide with respect to the transactions
that took place for the Fiber Drive property. So this would
be the -- our $6 million transfer that came from the PNC 9499
to the 9849 on May the 11th.
And then 9849 actually sent out a wire in the amount
of $7,000 on September 20th of '21 to North Atlanta Law Group.
This would have been the down payment or deposit for the Fiber
Drive property.
And then on the 27th of October, 9849 wired out
$91,076.66 to North Atlanta Law Group for the closing
transaction that took place for that same property.
Q.
Okay. And let's look at the wire transfer information.
MS. CONNORS: Can we pull up Exhibit 302A and go to
Page 11. Thank you.
BY MS. CONNORS:
Q.
And, Ms. Richardson, does this document relate to that
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 152 of 359
914
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
wire transfer for a little over $91,000?
A.
Yes, ma'am. Yes.
Q.
And is that what's in that payment instructions?
A.
Yes. It's to wire out the $91,000, yes.
Q.
Okay. And whose account was sending that money?
A.
The Carl Torjagbo account ending 9849.
Q.
Okay. And account ending in 9849 had about $7,300 in it
before it got a $6 million transfer?
A.
That is correct, yes.
Q.
And that $6 million transfer was sourced from PPP money
and IRS check money.
A.
That is correct.
MS. CONNORS: And if we can go to Page 12. Thank
you.
BY MS. CONNORS:
Q.
Look at the top, what was the -- which bank received this
money?
A.
Cadence Bank.
Q.
And just to be clear, the account that sent the money, was
that PNC?
A.
Yes, it is.
Q.
Okay.
MS. CONNORS: And if we can go back to Exhibit 501,
please, and go to Page 16.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 153 of 359
915
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MS. CONNORS:
Q.
And are you familiar with the purchase of a property at
101 Holt Drive?
A.
Yes, I am.
Q.
Okay. And is that what's described here as purchase
transactions?
A.
Yes. It is, yes.
Q.
And can you go through this page of the exhibit?
A.
Sure. So again, our same transfer, May the 11th, that is
from the 9499, the $6 million that goes over to 9849.
On February the 7th of '22, PNC 9849 got a cashier's
check in the amount of $500,000, and it was deposited over
into the Bank of America account ending in 1199.
And then on February the 18th, that Bank of America
account ending in 1199 wired $5,000 over to Ganek PC for the
down payment of the Holt Drive property.
And then that same account, Bank of America ending in
1199 wired out on March the 7th of '22 a wire in the amount of
$150,005.13 to Ganek PC for the closing of that property on
Holt Drive.
Q.
Okay. And Bank of America account ending in 1199 is in
the name -- is in what name?
A.
FlyingJack.
Q.
Now, did the FlyingJack account, it opened approximately
when?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 154 of 359
916
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
I do believe it was August. We can go back to our
exhibit. So on our Page 1 of our summary of bank accounts, it
is -- it shows that it was opened August the 26th of 2021.
Q.
So at the time that the PPP money and IRS check money are
received, was there any money in a bank account related to
FlyingJack?
A.
No, huh-uh.
Q.
And in terms of this $6 million transfer, was there --
would there have been -- I'm sorry. Let me go to the $500,000
cashier's check, at any point prior to -- between March 29th
of 2021, which is the date of the PPP deposit --
A.
Um-hmm.
Q.
-- and February 7th of 2022 --
A.
Um-hmm.
Q.
-- did $500 come in that was not PPP or IRS money?
A.
Did $500 come in that's --
Q.
$500,000 into 9849?
A.
That was not part of the -- I'm making sure I'm
understanding.
Q.
The PPP or the IRS money.
A.
No, no, no. No, no.
Q.
Okay. And in terms of -- we saw some information earlier
about any kind of potential deposits into 9849 that were not
the PPP money and not IRS money.
A.
Correct.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 155 of 359
917
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And do you recall approximately how much that was?
A.
As far as what was actually in both of the accounts prior
to?
Q.
Anything that got deposited into 9849 after March 29th of
2021 that was not PPP or IRS tax money?
A.
Just our -- our interest funds that went in. You would
have had interest every month into that account.
Q.
Is that approximately 1900 or so dollars?
A.
That would have been for the whole timeframe.
Q.
Okay.
A.
Yeah, umm-hmm.
Q.
Okay. But that was it?
A.
That's it. Yeah, that's it.
MS. CONNORS: And if we can go ahead and pull up
Government's Exhibit 305F. And if we'll go to the next page.
And then the page after that.
BY MS. CONNORS:
Q.
Does this -- is this a copy of the cashier's check
related -- that $500,000 cashier's check?
A.
Yes. For the February 7th, yes.
Q.
Okay. And cashier's check, is that written directly from
a bank account or is that -- the individual's bank account or
is the bank issuing that check?
A.
So the bank issues the check, but you go in and you do the
withdrawal of the funds from whichever account that you have
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 156 of 359
918
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
at that bank. They issue a cashier's check for whatever
amount and to whomever you request.
Q.
Okay. And so in relation to this specific cashier's
check --
A.
Umm-hmm.
Q.
-- did you see the corresponding withdrawal of $500,000
from 9849 to fund the check?
A.
Yes, I did, um-hmm.
Q.
Okay.
MS. CONNORS: And if we could pull up Exhibit 305I.
Thank you.
BY MS. CONNORS:
Q.
And we're looking at Page 4 and the very top transaction.
And what is that showing?
A.
So this is actually -- the bank statement is showing you
where they actually wired the funds from this account over to
Ganek for the purchase of the -- and they actually have the
address there of the 101 Holt Drive.
MS. CONNORS: And if we can go back to Exhibit 501,
Page 17.
BY MS. CONNORS:
Q.
Okay. And what is being summarized here?
A.
So this is a summary of all of the real estate purchases
that I reviewed. So for the Greythorne Lane property, this is
the full amount that was paid in the amount of $1,677,861.01.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 157 of 359
919
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
The amount for the Holt Drive of $155,005.13.
And the Tract 4, which is the Fiber Drive, that gives
you the $98,000.
For a total of real estate purchases in the amount of
$1,980,842.80.
Q.
Thank you.
MS. CONNORS: And if we can go to Page 18.
BY MS. CONNORS:
Q.
What is being summarized on Page 18?
A.
I also reviewed some vehicles, and this was for the 2022
BMW M850XI.
Q.
And is this a purchase that the defendant made?
A.
Yes. Yes.
Q.
And in regards to these transactions, what happened?
A.
So again we're looking at our $6 million transfer that
happened on May the 11th that went to the 9849. The 9849
account on August the 3rd of 2021, there is a check card
purchase, so that's kind of like when you have your debit
card, you go and you run your debit card, it comes up as a
check card purchase on your bank account, for the amount of
$2,500 to Global Imports.
And then PNC account 9849 on January the 11th of '22
wired $500,000 over to the Bank of America account that ends
in 1199. And then that same Bank of America account, 1199,
withdrew -- a cashier's check came out, that was printed at
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 158 of 359
920
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
the bank on the 24th of January, '22, in the amount of
115,250.79 written to Global Imports.
That same account, Bank of America account ending
1199, same day, there was another check card purchase again
where they swiped their card in the amount of $3,049 at Global
Imports.
MS. CONNORS: And if we can pull up Exhibit 302A.
And go to Page 20.
BY MS. CONNORS:
Q.
And is this a wire transfer or a transfer record related
to that $500,000?
A.
Yes, ma'am, umm-hmm.
Q.
And does this show that it's Carl Torjagbo who's sending
money?
A.
Yes. Yes. From the PNC account, yes.
Q.
Okay. And in terms of the date that this money is going
out, what is the date?
A.
It is January 11th, 2022.
Q.
Is that date after September of 2021?
A.
Yes, it is.
Q.
You're aware of whether or not the defendant changed his
name on that date?
A.
On specifically that date? I did not know what was the
specific date of the name change.
Q.
Do you know if he did change his name?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 159 of 359
921
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
I had gotten information saying that he had changed his
name.
Q.
Is his new name Carl Torjagbo -- I'm sorry, Karl Delano?
A.
Delano, yes. That's the name I was told.
Q.
On January 2022 to buy a BMW, it's still listing
Carl Torjagbo?
A.
Yes, it is.
MS. CONNORS: And if we can go to -- I'm sorry,
before I go there.
BY MS. CONNORS:
Q.
This money is going into a business account at FlyingJack?
A.
In the name of FlyingJack, yes, that is correct.
Q.
And then this BMW gets purchased out of a FlyingJack
account; is that right?
A.
That is correct, yes.
Q.
Okay.
MS. CONNORS: If we can go to 305E. Thank you.
BY MS. CONNORS:
Q.
And then at the top here, is this the cashier's check that
paid that wire -- or, I'm sorry, that paid for the BMW?
A.
Yes. That appears to be that, yes. Um-hmm, yep.
Q.
And what was the source of funds for this cashier's check?
A.
It would be the $6 million that was sent over.
MS. CONNORS: And if we can go to Exhibit 501,
Page 19.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 160 of 359
922
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MS. CONNORS:
Q.
And, Ms. Richardson, can you explain what this page
summarizes?
A.
Sure. So this is the 2021 Land Rover Range Rover
purchase. Again, our same $6 million transfer, May 11th from
9499 to 9849.
The 9849 account on August the 4th of '21 wired
$87,020 over to Niello Imports II. And then there's a PNC
account 1837 that's actually a credit card, the PNC credit
card, that was charged August the 6th of '21 for $3,500 at the
same vendor.
Q.
And in regards to this, I'm going to go ahead and pull up
Exhibit 302A, Page 3.
Is this the wire or the transfer information related
to that transaction?
A.
Yes, ma'am, it is. Yes.
Q.
And is this, again, the defendant sending money over?
A.
Yes, it is.
Q.
Okay.
MS. CONNORS: And if we could go to the next page.
BY MS. CONNORS:
Q.
And at the top, is it a Bank of America account that the
money is going into?
A.
Yes, ma'am. Yes.
Q.
And what was the source of these funds?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 161 of 359
923
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
This was the same $6 million transfer.
MS. CONNORS: And then if we can go to Exhibit 501,
Page 20. There you go. Okay.
BY MS. CONNORS:
Q.
Did the defendant purchase a Lamborghini?
A.
Yes, ma'am. Yes.
Q.
And what does this page summarize?
A.
So this is the summary of transactions for the purchase of
the 2014 Lamborghini. Our same $6 million that was
transferred over to 9849. 9849 purchases another cashier's
check on April the 14th of '22 for $500,000.
That $500,000 goes over to Bank of America account
ending 1199. And Bank of America account ending in 1199 wired
out on April the 15th of '22 $60,000 to Atlanta Used Cars as
part of the down payment for this Lamborghini.
That same account on April the 22nd wired out funds
in amount of $269,999.80 to Atlanta Used Cars for the complete
purchase for the 2014 Lamborghini.
Q.
And in regards to this purchase, the Bank of America
account being used is a FlyingJack account?
A.
That is correct, yes.
Q.
Now, could a wire transfer have been sent directly out of
9849?
A.
Absolutely, yes, um-hmm.
Q.
Is there any -- was there anything that you reviewed that
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 162 of 359
924
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
indicated the money had to come out of FlyingJack's bank
account instead of a bank account in the defendant's name?
A.
No, no.
MS. CONNORS: And if we can pull up Exhibit 305G.
BY MS. CONNORS:
Q.
Was there -- does this relate to the $500,000 cashier's
check that essentially transferred money from 9849 into 1199?
A.
Yes.
MS. CONNORS: And if we'll go to the second page of
that.
BY MS. CONNORS:
Q.
Again, is this cashier's check that would be --
essentially withdrawn from the bank's own account?
A.
Yes.
Q.
But did you see a corresponding transaction indicating
that the $500,000 was coming out of 9849?
A.
Yes, I did, uh-huh.
MS. CONNORS: And then if we can pull up Exhibit 305
and go to Page 77. And now in the kind of little bit --
perfect.
BY MS. CONNORS:
Q.
Okay. And on that top transaction for April 22nd of 2022,
does that relate to the remaining balance transfer for that
Lamborghini?
A.
Yes. That is the wire transaction, yes.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 163 of 359
925
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And does it indicate it is going to Atlanta Used Cars?
A.
Yes, it does.
Q.
And what was the beneficiary bank account there?
A.
Pinnacle Bank.
Q.
And does -- do you see sort of like an information line or
payment detail line?
A.
Yes, um-hmm.
Q.
And what was it indicating was the payment detail here?
A.
It's identified as equipment purchase.
Q.
And again, this is for a Lamborghini?
A.
Yes, ma'am, um-hmm.
Q.
And so is FlyingJack's business account being used to make
this purchase?
A.
Yes, it is.
Q.
And to confirm, what was the source of the funds?
A.
The $6 million.
MS. CONNORS: And now staying on that exhibit, if
you'll go and pull out one above that, a transaction on
April 21st of 2022.
BY MS. CONNORS:
Q.
And you mentioned earlier today about you had reviewed
records related to a yacht?
A.
Yes, ma'am. I did, yes.
Q.
Now was the yacht ultimately purchased in full?
A.
No. No, it was not. This was just the down payment for
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 164 of 359
926
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
the purchase of the yacht.
Q.
Okay. And so who was the beneficiary of this wire?
A.
This is Reel Deal Yachts, Inc.
Q.
And was it -- the payment details, does that reflect the
deposit on -- and then name of a yacht type?
A.
Yes, um-hmm.
Q.
And what was the source of that money?
A.
The $6 million.
MS. CONNORS: If we can go back to go Exhibit 501 and
go to Page 21.
BY MS. CONNORS:
Q.
And what does this summarize?
A.
So this is a summary of all the motor vehicles that I saw
within the accounts. The 2022 BMW, the 2021 Land Rover, the
2014 Lamborghini and the 76-foot yacht, that was just a down
payment for that one, with a total in amount purchases or
amount spent of $595,000, basically, 319.59.
Q.
Okay. And I believe you mentioned earlier today that
there were some other vehicles that were purchased?
A.
Yes, um-hmm. Yes, um-hmm.
MS. CONNORS: And if we can go to Page 22.
BY MS. CONNORS:
Q.
And what's reflected in this summary?
A.
So this a listing of all the truck sales that I saw go
through the different accounts that were held either in the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 165 of 359
927
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
name of FlyingJack or Carl Torjagbo.
Q.
And I think you probably jumped to my next question. So
all of these trucks are not purchased directly from the
FlyingJack account?
A.
No. No, no. So as you see, if you go almost halfway down
the page, the first one that's for Ameritruck, it says PNC
account ending 9849 actually pays $90,100 for that vehicle.
Q.
And then the bottom line, is there an additional
transaction for one of these trucks that were --
A.
There's actually two. Yeah, there's two, there's 9849
does another Ameritruck for 49,900.
And then 9849 does another one at Southern Truck
Sales for 73,900.41.
Q.
And in terms of the funds in 9849, when all three of those
transactions occur, what would have been the source of the
money?
A.
The same $6 million.
Q.
And that $6 million is both PPP money and IRS tax refund
money?
A.
Yes, it is.
Q.
And then the source of funds for the other remaining
trucks that were purchased out of FlyingJack's account, what
would -- what's the source of the funds?
A.
The same $6 million.
Q.
And that $6 million represents both PPP money and IRS
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 166 of 359
928
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
refund money?
A.
Yes, it does.
MS. CONNORS: And let's go to Page 23.
BY MS. CONNORS:
Q.
And what is this summarizing?
A.
So this is a listing of all the trailers that were
purchased from the FlyingJack account at Bank of America
ending in 1199.
MS. CONNORS: And let's go to the next page.
BY MS. CONNORS:
Q.
Did you review incoming deposits to each one of the
defendant's accounts after May 12th of 2021?
A.
Yes, I did.
Q.
And did you summarize each account individually?
A.
Yes, I did.
Q.
So first looking at Page 24, are these the incoming
deposits to that account?
A.
Yes. This is for the PNC account ending 9499. This would
be all of the remaining deposits that were into this account
from May 12th of '21 until April 29th of '22. There were two
deposits totaling $46.17.
Q.
And again, is this Kremkov's account?
A.
Yes, it is.
Q.
Now, in terms of the Mary 12th starting date, why was that
date selected?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 167 of 359
929
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
So this was the date that would have been after all of the
deposits and everything were done as far as for the IRS money
would have already been deposited, the PPP money would have
already been deposited. So this was after everything had been
deposited, looking at the timeframe of what other income could
have come in to all of the different accounts after that
timeframe.
Q.
Thank you.
MS. CONNORS: And if we can go to Page 25.
BY MS. CONNORS:
Q.
And which account is this?
A.
This is the PNC account ending 9849 for that same time
period.
Q.
Total -- the total money coming in, a little over $500?
A.
Yes, ma'am. A total of five deposits for the total of
$523.77.
MS. CONNORS: And let's look at Page 26.
BY MS. CONNORS:
Q.
Which account is this?
A.
This is for the PNC account ending in 9822.
Q.
$183 and some change?
A.
Yes, ma'am, for six deposits for that same time period.
Q.
Okay.
MS. CONNORS: And then finally let's look at Page 27.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 168 of 359
930
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MS. CONNORS:
Q.
And is this the FlyingJack account?
A.
Yes, it is. Bank of America account ending in 1199.
Q.
Now, the top transaction has a $40,000 cash in.
A.
Um-hmm.
Q.
When you were reviewing the records around that same day,
did you also see $40,000 going out related to a real estate
purchase?
A.
Yes, I did. It's actually on the -- when you see the
transactions all listed for the 9849 account, it was the
$40,000 that was listed as a disbursement that went out of
that account.
Q.
Okay. So even though -- so the $40,000 cash goes into a
1199, but then a different account sends out the $40,000 wire?
A.
That is correct.
Q.
Now, Ms. Richardson, in terms of this money, you've talked
about the $6 million transfer to 9849.
A.
Umm-hmm.
Q.
Now that $6 million goes out of 9499.
A.
That is correct.
Q.
And is 9499 the account that had both a $3 million check
deposited into it for payroll as well as $3.3 million tax
refund check?
A.
It is, yes.
Q.
Now, once both of those deposits were in the account,
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 169 of 359
931
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
would you be able to believe what dollar is PPP money and what
dollar is IRS refund money?
A.
Not once it's commingled together, no.
Q.
So then that $6 million transfer happens and that's all --
that's going to be from both, right, because --
A.
Yes, the two together.
Q.
Because we do not have that the -- the PPP money did not
get $6 million into an account -- well, let me say didn't get
$6 million into 9499 from PPP money?
A.
No, huh-uh.
Q.
And did not get $6 million in an IRS refund check?
A.
No, huh-uh.
Q.
So that money was combined to be able to get to the
$6 million?
A.
That is correct, yes.
Q.
Now, we've gone through quite a bit of transfers.
And did you prepare a demonstrative exhibit to help
kind of follow the flow of funds and to display that for the
jury, kind of in a graphic, if you will?
A.
Yes, I did.
Q.
And does that exhibit fairly and accurately reflect the
flow of funds?
A.
Yes, it does.
Q.
And was there even an adjustment at the request of the
defense?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 170 of 359
932
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes, there was.
MS. CONNORS: Your Honor, I move to admit
Government's Exhibit 502 for demonstrative purposes.
MR. FINLAYSON: No other objection.
THE COURT: Okay. It's admitted.
MS. CONNORS: Okay. If we could pull up 502. Thank
you.
BY MS. CONNORS:
Q.
Okay. So, Ms. Richardson, we just talked about a lot of
transfers, a lot of different dollar numbers, a few we
repeated over and over again.
But if you can start at the far left and let us know
what that represents.
A.
Okay. So starting at the far left is your initial PPP
money, the $9,554,425.
THE COURT: You can actually -- by the way, I think
if you touch that screen, it will put a mark on it.
THE WITNESS: Oh, I can touch it?
THE COURT: Isn't that right? Give it a shot. Did
it put a mark on there?
MS. CONNORS: It made like a little highlighter.
THE WITNESS: It made a -- it made a highlighter.
THE COURT: Touch it more authoritatively. Yes, see
that.
THE WITNESS: Oh, and it's purple.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 171 of 359
933
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: And you can erase it by hitting --
THE WITNESS: The eraser? Nope, that don't do it.
THE COURT: Maybe you have to do it, Ms. Connors.
COURTROOM DEPUTY: I think either one of y'all can.
THE WITNESS: Which one is the --
THE COURT: Touch the corner of your screen,
Ms. Connors.
MS. CONNORS: Just the corner?
THE COURT: Did it come up with it?
THE WITNESS: Oh, I don't have a green arrow.
MS. CONNORS: Oh, this one?
THE COURT: Yes.
COURTROOM DEPUTY: So like you can change the color
right here, but you can't erase her mark.
THE COURT: So you have to touch -- no, no. You
don't have to do it like that. You can just hit back. Hold
on. All right. I've taught you to fish. I'm going to leave
you alone.
THE WITNESS: I've got it.
MS. CONNORS: Okay.
BY MS. CONNORS:
Q.
All right. So we have the $9.5 million PPP money.
A.
Umm-hmm.
Q.
And then where does that get deposited?
A.
So that money is actually deposited over to the --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 172 of 359
934
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
JPMorgan Chase actually puts that money into the account that
is the 8755.
Q.
Okay. And if you can go ahead and discuss what is
reflected there in terms of the red dotted arrow.
A.
So this was the money that was actually clawed back by PNC
Bank. They removed from that same account $6,554,515.
Q.
Now, before that happened, is that what the next
transaction is moving to the right that's referred to as the
$3 million check?
A.
Yes, um-hmm.
Q.
And just to confirm, you have seen that check before?
A.
Oh, yes, um-hmm.
Q.
Okay. And was there a memo line on that check?
A.
Yes. That check on the memo, it actually said payroll.
Q.
Now, did you see anything that looked like payroll going
out of 9499 after that check was transferred?
A.
No, no.
Q.
Did you see any evidence of payroll coming out before any
money was -- came in for the PPP loan?
A.
Oh, no, huh-uh.
Q.
Okay. So the $3 million check going into 9499?
A.
Um-hmm.
Q.
And then you have another arrow going to that same
account. What does that represent?
A.
So that is from the IRS check that is the $3,366,240.76,
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 173 of 359
935
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
that is that check going to the PNC account ending 9499.
Q.
And do you recall the approximate date of that check
deposit?
A.
That was our April 27th of 2021.
Q.
And do you recall when that check was issued, like the
date on the check?
A.
It was April the 23rd of 2021.
Q.
And what happens next?
A.
So then from here, this is showing you where the
$6.1 million transfer went from 9499 to the 9849 account at
PNC.
Q.
Okay. Now, we've been talking a lot about a $6 million
transfer. So how do you end up with $6.1 million in terms of
this exhibit?
A.
So remember back in the beginning, the very first one that
I -- that I tracked was the $100,000 transfer that went over
that paid all the credit cards and the car off. So that's the
$100,000. And then the $6 million transfer happened after
that, so it leaves you at $6.1 million.
Q.
Okay. And so that money goes into 9849. And then there's
a lot of arrows. What do those arrows represent?
A.
There are a lot of arrows. And I did not put it in date
order, I put it in amount order clockwise.
Q.
Okay.
A.
So it actually shows you the 2021 Land Rover for the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 174 of 359
936
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
$90,000, the Tract 4. And this would be funds that came from
9849, whether it was actually spent out of 9849 or 9849
supplied the funds to purchase it, okay?
So 9849 actually goes for the 2021 Land Rover at
90,000; the Tract 4, at $98,000; the ten trailers at $177,000;
the BMW 850 at $120,000; the 101 Holt Drive at $155,000; the
2014 Lamborghini at $332,000; the ten tractors at $741,000;
and the property at Greythorne Lane for $1,677,000
approximately.
Q.
Okay. Now, after March 29th of 2021, when there is the
receipt of that $9.5 million in PPP money, did you see any
incoming transfers for any of the accounts that are identified
here from foreign bank accounts?
A.
I'm sorry, did you say before or after?
Q.
After. After March 29th of 2021, did you -- did you see
any incoming funds to these accounts from foreign bank
accounts?
A.
No, huh-uh.
Q.
And aside from the PPP money and the IRS tax refund money,
did you see any multimillion dollar deposits into any of the
bank accounts?
A.
No, huh-uh.
Q.
And in total, you had indicated on Exhibit 501 there was
approximately $4.2 million going out from 9849; is that right?
A.
That is correct, yes.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 175 of 359
937
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Now, were there also expenditures on some of the accounts
that would be day-to-day kinds of expenditures?
A.
From the -- all of the different accounts?
Q.
Yes.
A.
Day-to-day like, yeah, um-hmm. I would see some
day-to-day charges, yes.
Q.
Like going out to eat or something like that?
A.
Oh, yes, Starbucks or Dunkin Donuts or what have you, yes.
Q.
Okay. And now to confirm, in terms of what the defendant
was actually able to access and have available to him --
A.
Um-hmm.
Q.
-- we know that we get the clawback of the PPP money.
A.
Umm-hmm.
Q.
How much was he able to get transferred total into 9499,
or maybe I should say deposited into 9499?
A.
The $6.1 million.
Q.
Now, does he -- is it actually a little bit more than
that?
A.
Into the 9849 or the 9499?
Q.
Oh, I apologize. I may have said the wrong account.
A.
Okay.
Q.
So here you have the $3 million check going into 9499 --
A.
Yes.
Q.
-- and that's PPP money, right?
A.
Yeah, that is correct.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 176 of 359
938
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Okay. And then you have the IRS refund check of over
$3.3 million.
A.
Yes, that is correct.
Q.
So in terms of proceeds of both the PPP and the tax fraud,
are we looking at the total of 3 million plus the 3.3?
A.
Yes, so they would be $6,366,240.76.
MS. CONNORS: I think that's all I have. Thank you.
THE COURT: Okay. Cross-examination.
MR. FINLAYSON: Thank you, sir.
CROSS-EXAMINATION
BY MR. FINLAYSON:
Q.
Go afternoon, Ms. Richardson.
A.
Good afternoon.
Q.
How are you?
A.
Good. How are you?
Q.
I've got just a few questions for you.
A.
Sure.
MR. FINLAYSON: And we can take 502 down.
BY MR. FINLAYSON:
Q.
So if I understand right, you work in an office with these
guys at the U.S. Attorney's Office?
A.
Yes. I work on the same floor, yes.
Q.
And that's 9:00 to 5:00 or probably 8:30 to 6:00, that
sort of thing?
A.
Yeah.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 177 of 359
939
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And how long have you been there?
A.
Eight and a half years.
Q.
Okay. And you are a forensic auditor, right?
A.
That is correct.
Q.
Okay. You are not a -- you're not a law enforcement
officer, right?
A.
No, I'm not a law enforcement officer.
Q.
So you don't go out in the scene and investigate and do
surveillance and that kind of thing?
A.
Oh, no. I don't do that, no.
Q.
So you review the records, you look at the paper sort of
after they've done all that part, right, or sometimes during?
A.
Sometimes during. Yes, umm-hmm.
Q.
In this case, did you during or after?
A.
After, that's correct.
Q.
So in this case, these guys or somebody in the office
brings you piles of paper or records, I'll bet they email them
to you, and ask you to look at them, right?
A.
Yes, that is correct.
Q.
And then try to figure out what happened here?
A.
So they asked me to review the financial statements, yes.
Q.
Okay. And you work with what they give you, right?
A.
I go through what was provided via a grand jury subpoena.
Q.
Okay.
A.
But that's the gist.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 178 of 359
940
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
But you don't go out and gather -- you don't go out on the
street and gather records?
A.
Oh, no.
Q.
Somebody in the U.S. Attorneys Office hands you a bunch of
records and says have at it. Maybe that's not fair. That's a
little -- they ask you to analyze them?
A.
That is correct, yes.
Q.
Okay. Better word.
Okay. So you have analyzed PNC Bank records here?
A.
PNC Bank, yes.
Q.
PNC Bank. Chase records here?
A.
That is correct.
Q.
Bank of America records here?
A.
That is correct.
Q.
You didn't review or analyze any foreign bank account
records, right?
A.
No, I did not.
Q.
Okay. Because they ordered -- none of them were given to
you in this case?
A.
So they were not subpoenaed. I go through what was
actually subpoenaed.
Q.
Okay.
A.
I didn't see any actual bank accounts that were provided
via a subpoena.
Q.
Okay. So you didn't have any foreign bank account
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 179 of 359
941
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
documents to analyze; is that fair?
A.
That is fair.
Q.
You mentioned on direct examination that -- I think I
heard this right -- after a certain date, you didn't see any
wires coming in from foreign bank accounts. Do you remember
that testimony?
A.
Yes, um-hmm.
Q.
Which sort of suggested to me but before that certain date
or at a certain point in time you did see some wires coming in
from foreign bank accounts?
A.
That is correct.
Q.
Okay. And do you recall when those were?
A.
So that was in 2019.
Q.
Okay. And do you remember which bank they came from?
A.
I don't know where they come from, because I only saw the
recipient bank. So we received the wire transfers from PNC
Bank.
Q.
Okay.
A.
And when they provided us the wire transfer information,
it gave us the -- some of the ones that happened in 2019, and
it showed that it came from a foreign bank account.
Q.
Okay. Was it like a United Emirates or something like
that, do you remember the country?
A.
I did see United Emirates, but I do not know a bank name.
Q.
And is that -- United Emirates, is that also Dubai?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 180 of 359
942
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
I do believe that is Dubai.
Q.
Okay. So you talked about there were purchases of some
vehicles, right?
A.
That is correct.
Q.
And again, you're looking -- you're looking from the
records, right? That's what you're basing this testimony
from?
A.
That is correct, yes.
Q.
And so you saw a vehicle was purchased on a certain date
or at a certain place in a certain name, correct?
A.
That is correct, yes.
Q.
And do you actually have any real-time knowledge or real
knowledge of who really was there at the dealership buying
that thing, you are just looking at the paper; is that fair?
A.
So I know who signed the paperwork.
Q.
Okay.
A.
And I do see the paperwork. But to say -- there's no
video footage or anything that I saw of someone standing
there.
Q.
Okay. You see the name that is signed there, right?
A.
There is a signature.
Q.
Okay. Yeah, yeah. We don't need to go there. But, I
mean, you're not a handwriting analyst or any of that stuff,
right?
A.
Oh, no, not by far.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 181 of 359
943
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
So you made a point with her, with the prosecutor, that
there is a BMW bought, right?
A.
That is correct.
Q.
And it was bought in the name of Carl Torjagbo, right?
A.
That is correct.
Q.
And you mentioned that it was bought after he had changed
his name to Karl Delano, right?
A.
No, that's not correct. I don't know when he changed his
name. That was my statement.
Q.
Okay.
A.
But I don't know the exact date of when he changed his
name. I was just told that the name had changed.
Q.
Okay. But if he bought the BMW in the name of
Karl Delano, that's not a change, is it?
A.
So all the paperwork that I reviewed had the name of
Carl Torjagbo.
Q.
Or, I'm sorry, yeah. And I got that wrong. He bought the
BMW in the name of Carl Torjagbo, right?
A.
All the paperwork that I reviewed had the name
Carl Torjagbo.
Q.
Right. Which he didn't say my name is John Smith, right?
A.
Not that I saw.
Q.
Right. He said his name is Carl Torjagbo?
A.
I saw the name Carl Torjagbo.
Q.
That' not concealing his identity, is it?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 182 of 359
944
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
I do not know that.
Q.
Okay. I want to make sure we've got all the banks. We've
got PNC, right?
A.
Right.
Q.
Bank of America?
A.
Right.
Q.
Chase?
A.
Correct.
Q.
Those are just the three?
A.
Yes, that's correct.
Q.
Okay. All right. So and we've been through several
accounts that you looked at, right?
A.
Yes, that's correct.
Q.
And some of them were in the name of Carl Torjagbo, right?
A.
That's correct.
Q.
Some of them were in the name of Kremkov Industries,
right?
A.
That's correct.
Q.
And Kremkov Industries is Carl Torjagbo, right, to your
knowledge?
A.
To my knowledge, there is an account that has both names
on it.
Q.
Yeah. And then FlyingJack has the name -- it also had
Carl Torjagbo associated with it, didn't it?
A.
On the signature card, yes.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 183 of 359
945
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Yeah. So, I mean, some of your cases, they've got a whole
lot more names in the middle there, right? Is that fair?
A.
In the middle, I don't understand what you mean.
Q.
If all the accounts had his name on there, it's kind of --
it makes your job easier to follow from A to B to C; is that
fair?
A.
By the name?
Q.
Yes.
A.
I don't track by the name. I track via accounts.
Q.
Okay. So when we're talking about concealing the identity
of a person that's transferring money, if it's all in his
name, it's not very concealed, is it?
A.
Well, I don't do money concealment on a name. I don't --
I don't have any experience on money concealment on a name.
Q.
Okay. But is it fair to say if it's got the same name on
it, it sure looks like the same guy, right?
A.
Not necessarily. I mean, I don't know who was in the bank
doing whatever transactions unless they provide -- which
sometimes the banks will provide video, but unless I have
video to say that it's the same date, time, whatever, I don't
have the individual.
Q.
Okay.
A.
I just have the bank accounts.
Q.
So if he goes in and buys a BMW in his own name, Carl --
or in the name of Carl Torjagbo, that's not concealing his
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 184 of 359
946
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
identity, is it?
A.
Not that I know of, if that's his name.
Q.
Okay. So you mentioned there was that $40,000 deposit and
then a $40,000 withdrawal in very close time?
A.
Yes, um-hmm.
Q.
And you looked at that money?
A.
I did, yeah.
Q.
And that was associated with a real estate purchase,
right?
A.
That is correct, yes.
Q.
And that was a lady Monica Sweeten; is that right?
A.
Yes, um-hmm.
Q.
Did it look like the cash came in from her and then a
check -- a wire went out on her behalf to purchase property?
A.
I don't know who put the cash in the bank. I don't have a
video or anything. It just said $40,000 cash in.
Q.
Okay. And did you have any -- did you have any documents
on Monica Sweeten?
A.
There was a closing transaction for her real estate
purchase. That was the only thing that I saw.
Q.
Okay. So you mentioned -- and I think the date I got -- I
saw was -- there's a summary. And you mentioned that before
March 28th of 2021, there wasn't much money in the Kremkov
account, right? Is that -- is that what you said?
A.
For which -- for the 9499 account?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 185 of 359
947
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
It's a Chase -- I thought it was a Chase account. Does
that sound like 9499?
A.
May I flip back through?
Q.
You may, yes.
A.
So for the Kremkov for the Chase account, it is 8755 for
Chase.
Q.
Okay. I'm just trying to remember the one you testified
about. And you made the point that there wasn't much money in
the account before that date.
A.
So the -- our Page 4 of our exhibit actually gave you the
listing of all of the accounts.
Q.
Okay.
A.
So not just the one at Chase. It gave you Chase and PNC.
Q.
Okay. So March of 2021, we are almost a year -- just
about a year to the date to the COVID shutdown, aren't we?
A.
Yes, um-hmm.
Q.
So the COVID shutdown was March of 2020, wasn't it?
A.
That is correct, yes.
Q.
All these trucks, you tracked the purchases of all those
trucks?
A.
So I went through and -- yes, I did. Yeah.
Q.
And we went and you added up all those numbers?
A.
Yeah, I added up all those numbers.
Q.
And all of those trucks have been seized?
A.
To my knowledge, yes, they have.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 186 of 359
948
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Okay. And there was cash seized out of bank accounts as
well, right?
A.
Yes. It was, um-hmm.
Q.
Like a couple of million out of one account?
A.
That's correct, yeah.
Q.
And I can't -- the other one was $800,000?
A.
Seized?
Q.
Yes, ma'am.
A.
No, I don't know about $800,000.
Q.
Okay.
A.
Seized.
Q.
Was there a second bank --
A.
There was a second bank account that was seized, yes.
Q.
Okay. And the vehicles like the Lamborghini was seized?
A.
To my knowledge, yes.
Q.
And the Range Rover was seized?
A.
That's correct.
Q.
And the BMW was seized?
A.
Yes.
Q.
And the properties are -- have liens on them or something
of that nature?
A.
Presumably, yes. I'm -- I don't do that part of it, but
yes.
Q.
Okay.
MR. FINLAYSON: I think that's all my questions,
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 187 of 359
949
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Judge.
THE COURT: Okay. Any redirect?
MS. CONNORS: Yes, Your Honor.
REDIRECT EXAMINATION
BY MS. CONNORS:
Q.
Ms. Richardson, you were asked about any kind of foreign
bank accounts. Now, you mentioned foreign account transfers
in 2019.
A.
Um-hmm.
Q.
And I think you may have hit on this a little bit during
your direct.
Are those the transactions that you referenced that
essentially funded the 2020 expenditures, that approximately
$33,000?
A.
Oh, yes. That is correct, yes.
Q.
But then by the time of March 28, 2021, before that PPP
money comes in, had a good bit of those funds been depleted
already?
A.
That is correct, yes.
Q.
Now, in terms of any kind of foreign account funds, did
you look at the specific bank transaction records associated
with each one of the wires or cashier's checks, whatever it
was, for the vehicles, for the house, for any of those trucks
and trailers, other real estate purchases?
A.
I'm sorry, could you --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 188 of 359
950
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Sure.
A.
-- reword that?
Q.
So in terms of the source of funds --
A.
Um-hmm.
Q.
-- let's give an example. BMW.
A.
Um-hmm.
Q.
Is there any question to you that the money came out of a
foreign bank account?
A.
Oh, no. None of that money came from a foreign bank
account.
Q.
Okay. Have you been able to see the transaction coming
out of one of the -- either the PNC accounts, Bank of America
account or the Chase account belonging to Mr. Torjagbo?
A.
Yes. All the funds for the BMW came from those accounts.
Q.
Okay. And in terms of the other items that we talked
about today, like the house, the other two real estate
purchases, the trucks, the tractors, the Lamborghini, and I'm
forgetting -- the Range Rover --
A.
Umm-hmm.
Q.
-- all of those --
A.
Um-hmm.
Q.
-- was it -- did you have documentation to support that no
foreign money was being used to fund those purchases?
A.
Yes. Yes, um-hmm.
Q.
Now, in terms of the PPP money and this IRS check, PPP
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 189 of 359
951
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
money goes into 8755?
A.
Yes.
Q.
Is there anything that you have reviewed that said it had
to go -- that it could not stay in that account and be spent
directly from that account?
A.
Oh, no. Huh-uh, no.
Q.
And even did you see any attempt at other transactions out
of 8755 besides the $3 million check?
A.
No.
Q.
Okay.
MS. CONNORS: Let me pull up --
MR. FINLAYSON: Objection. Outside the scope.
THE COURT: Overruled.
MS. CONNORS: Let's pull up 8755. I think it's 103.
BY MS. CONNORS:
Q.
All right. And is this the Chase account that received
the PPP money?
A.
Yes, it is.
Q.
Okay.
MS. CONNORS: Now, if we can go to Page 17 of this
exhibit.
BY MS. CONNORS:
Q.
Is this a check?
A.
That is a check.
Q.
Okay. Now, are you familiar with kind of the codes at the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 190 of 359
952
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
bottom of that check in terms of what's the routing number and
what's the bank account number and then usually there's a
check number?
A.
Yes, um-hmm.
Q.
Okay. Is this -- and when you look at the second series
of numbers in between 7 and 5, would that represent the
account number for that check?
A.
Yes, it does.
Q.
So 8755, is that the same Chase account?
A.
Yes, it is.
Q.
And what date was this check written?
A.
May the 3rd, 2021.
Q.
And do you see it says deposit 1855?
A.
Yes.
Q.
Now, in terms of the Chase account, did you see that this
check actually was able to clear?
A.
Yes, um-hmm.
Q.
That $1,600 was removed from 8755?
A.
Removed from -- oh, from the account itself?
Q.
Yes.
A.
Oh, yes. No.
Q.
Okay. Because if you --
A.
No, it was not.
Q.
If you go back to -- up, is it that this $3 million check
transfer was the only money that was able to get removed.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 191 of 359
953
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
That's it, yes.
Q.
But even this attempted check, it just -- there was a
possibility that checks could have been issued directly from
8755?
A.
Yes, uh-huh.
Q.
Now, the IRS check, it could have been deposited directly
into any one of the accounts?
MR. FINLAYSON: Objection, again, outside the scope.
MS. CONNORS: Your Honor, he's indicating that
there's potentially foreign or other --
THE COURT: Okay. It's okay. I'm going to overrule
the objection.
BY MS. CONNORS:
Q.
Okay. So for the -- you have the accounts, could a check
have been deposited into any one of the bank accounts?
A.
That's correct.
Q.
So was there any reason that you could tell from the bank
records that would say it wasn't possible to have the money
separated, PPP money versus IRS money?
A.
No, it could have gone anywhere.
Q.
And in regards to that $3 million check, you talked about
that it said payroll?
A.
Yes, um-hmm.
Q.
And in terms of Paycheck Protection Program, do you have
any awareness of that program?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 192 of 359
954
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
I know a little bit about the program, just from reading
through documents.
Q.
Okay. It has paycheck at the beginning, was it related to
payroll paying individuals?
A.
That's correct.
Q.
So would payroll on its face seem consistent with that?
A.
Yes.
Q.
And in terms of your analysis, when you were talking about
the funds going from different accounts, is it that you had to
trace out these transactions either maybe you saw an initial
withdrawal from an account, did you then have to figure out
where that money went?
A.
Yes, I did. Yes, um-hmm.
Q.
Or if there was a purchase, were you trying to backtrack
and figure out how that money was originally sourced?
A.
That's correct, yes.
Q.
And in your summary, there's a few examples of where money
goes in and then it gets transferred to -- like there's
multiple account transfers?
A.
That's correct.
Q.
So you had to trace it multiple different steps?
A.
Yes, that's correct.
Q.
And did that involve tracing sometimes a business account
transaction to a personal account?
A.
Yes, it did.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 193 of 359
955
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Or a personal account to another personal account?
A.
Yes, it did.
Q.
Or a personal account to a business account?
A.
Yes, it did.
Q.
And ultimately, in regards to the FlyingJack account, that
is not the same company that got that PPP deposit?
A.
No, it is not the same company.
Q.
And it's not a company that was identified in any way on
the IRS check?
A.
No, it is not.
MS. CONNORS: And then just to clarify, if we can
bring up Exhibit 501 and go to Page 13.
BY MS. CONNORS:
Q.
You were asked about the transfer related to
Monica Sweeten?
A.
Um-hmm.
Q.
And during your testimony earlier, you referenced that
wire going out, but I don't think we were actually looking at
the page at the time.
Is that transaction of $40,000 to Great American
Title Company, was that the transaction?
A.
That is the transaction. Yes, it is.
Q.
Thank you.
A.
Um-hmm.
THE COURT: Anything?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 194 of 359
956
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. FINLAYSON: No, sir.
THE COURT: All right. You can step down.
Thank you very much.
THE WITNESS: Thank you.
THE COURT: All right. Call your next witness.
MS. CONNORS: Your Honor, if we may double-check
exhibits.
THE COURT: Okay.
MS. CONNORS: Your Honor, subject to the Court's
ruling related to our summary exhibits, the government rests.
MR. FINLAYSON: Your Honor, I have a motion.
THE COURT: Okay. We have some housekeeping to take
care of.
Would you-all step out for just a moment and we'll
come get you. It might take a couple of minutes, okay?
But we're moving along very well.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Okay.
MR. FINLAYSON: Your Honor, for the record, I would
make a motion for acquittal under Rule 29, asking the Court to
dismiss all counts submitting that the government has not met
their burden sufficiently to get the case to the jury on Count
One, the bank fraud, on Counts Two and Three, the wire fraud.
THE COURT: What do you think is missing on Count
One?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 195 of 359
957
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. FINLAYSON: Sufficient evidence of intent to
commit fraud.
THE COURT: Okay.
MR. FINLAYSON: And that's probably the gist of that
at this point.
THE COURT: Okay. Two and Three?
MR. FINLAYSON: Two and Three, the same insufficient
evidence to show intent to commit wire fraud. I submit for
the record they have failed to sufficiently prove all material
elements of those offenses.
THE COURT: Well, I know. But hold on. That's
really like a vague motion. If you want to make a motion that
you want me to consider, I can't do your work for you.
MR. FINLAYSON: Understood.
THE COURT: You've got to tell me what you think is
wrong.
MR. FINLAYSON: Well, I would submit on both of
those, on Counts One and Two and Three there's insufficient
evidence of criminal intent to commit those frauds.
As to Counts Four through Six, the concealment money
laundering, there is insufficient evidence of intent as well
as insufficient factual evidence of concealment. The evidence
has been very clear here that everything is done very
blatantly tied to Mr. Torjagbo. And if -- and the biggest
jump there is the name Delano, which they have -- that gap has
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 196 of 359
958
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
been bridged very easily. They haven't -- it hasn't caused an
obstacle. There's been no evidence that anything was
concealed because of that name change, so I submit there's a
factual insufficient facts there as well to get that to the
jury.
As to Counts Seven and Eight, the transactional money
laundering, even though there is evidence that transactions
were made, we submit there's insufficient evidence that the
funds came from unlawful activity. Furthermore that
Mr. Delano knew they came from unlawful activity or intended
to commit those crimes.
So based on that, Your Honor, I would ask you to
dismiss all counts.
THE COURT: Government?
MS. CONNORS: Your Honor, in relation to intent here,
the government has made it clear that this -- the PPP fraud
required a substantial amount of documents to accomplish that
scheme. We made it clear that that was something that was --
THE COURT: That's the bank fraud count?
MS. CONNORS: Yes, Your Honor, so for Count One.
THE COURT: I'm going to deny it on the bank fraud
count. I don't think there is any doubt that there is plenty
of evidence from which a jury can decide that there was the
intent to commit fraud. I mean, there were so many different
lies in that -- that's the application, right?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 197 of 359
959
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MS. CONNORS: Yes, Your Honor.
THE COURT: So many different lies in the application
from the number of employees to the fact that the employees
were in the United States to the fact that the company existed
at all at the relevant time.
For Two and Three, the wire fraud, the two false tax
returns, we've heard about the falseness of those tax returns.
I'm not even sure I understand the argument that they're not
fraudulent.
What's the argument that they're not fraudulent?
MR. FINLAYSON: Well, that they weren't -- they
have -- well, two things.
First of all, they haven't shown identity -- they
haven't proven that he filed both of them. And we've conceded
he filed one, so I don't think I can argue that. But the
second one on Count Three, we haven't -- they haven't proved
identity of it.
THE COURT: It was filed under one of his driver's
license numbers, right?
MR. FINLAYSON: That is correct.
THE COURT: It was filed -- didn't we hear it from a
guy that had the IP address that was the same as all the
others?
MS. CONNORS: Yes, Your Honor.
THE COURT: Okay.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 198 of 359
960
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. FINLAYSON: Well, I also submit there is
insufficient evidence of intent to commit fraud there.
THE COURT: By saying --
MR. FINLAYSON: Taxes are complicated.
THE COURT: He's entitled to a $3 million refund?
Isn't that what it was, $3 million?
MS. CONNORS: 3.3.
MR. FINLAYSON: Taxes are hard.
THE COURT: Yes. The key part, though, for a refund
is paying taxes, having income and then wanting some amount of
it back.
So what about the Counts Four through Six, what does
the government say about that?
MS. CONNORS: Your Honor, I'll remind the Court as
it's clear in our jury instructions, concealment is not just
an identity issue. It is not simply that it is who is
controlling or who, quote/unquote, owns the funds.
It is concealment and disguising the nature, source,
location, ownership and control. And in regards to concealing
the source and the nature of these funds, that is precisely
what was occurring here.
The check that says payroll is -- you heard the Chase
witness say that that wouldn't have raised any red flags,
because this was a PPP program, so saying payroll on that
check allowed him to easily move that money out of Chase.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 199 of 359
961
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: I think she said if it would have said
something else, they would have caught.
MS. CONNORS: Exactly.
THE COURT: I don't remember what the -- yes.
MS. CONNORS: Yes. Certainly if it had said to buy a
house, she was clear that that would not have been something
that would have occurred.
And then in regards to Counts Five and Six, again, we
are talking about that he is distancing himself from these
transactions. Because I'll note although he sends the money
through an account that is still in the Carl Torjagbo name for
one of the properties, he's titling the property in the other
name. He's claiming that this is for FlyingJack. So both of
those two other parcels of land are supposed to be for
FlyingJack.
But what the source of that funds again is the PPP
money, that that would have been an impermissible purpose.
And so by funneling that money, and you just heard
Ms. Richardson talk about how much he funneled money, so this
is not a simple thing of just one easy transaction. She
talked about how this money gets routed all into 9849 and then
from 9849, it's funneling down through all of these various
accounts.
THE COURT: Yes.
MS. CONNORS: That in its nature is concealing the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 200 of 359
962
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
nature and source of those funds.
THE COURT: I think there's plenty there as the
government is saying for the intended -- intent to conceal it.
What about the last one, Seven, Eight, Nine and Ten?
MS. CONNORS: Your Honor, if his only argument is
that it does not appear that these are proceeds, I think by
the Court recognizing that Counts One, Two and Three would be
presented to the jury, then it should be the jury who decides
if these are proceeds of a criminal offense. I think we have
given sufficient information for them to be able to make that
decision.
And in terms of intent, we are talking about
transactions where as soon as that money is coming out, he is
spending it.
THE COURT: I think that's right. I think
considering all of the elements of the offense, and I've been
going along, and I have jury instructions up here and I've
been kind of making notes, I think there's plenty of evidence
for the jury to find all of the elements of all of the
charges, so I'm going to deny the Rule 29 motion.
What do we do next?
MR. FINLAYSON: Your Honor, I've got two witnesses
and then the defendant wishes to testify.
THE COURT: Okay.
MR. FINLAYSON: I just need to grab them in the hall.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 201 of 359
963
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: Okay. So --
MS. CONNORS: Your Honor.
THE COURT: Yes.
MS. CONNORS: I think we will have to resolve
something, because we've made it clear to Mr. Finlayson that
we believe that one of the individuals he plans to call, the
person he notified as an expert, there is no relevance to that
witness.
He has indicated that it would only -- that he has
even accepted that his client would have to testify to
potentially end up with any relevance of this expert, so we
would object to the possibility that the expert testifies
first.
MR. FINLAYSON: Two things. One, I don't -- I don't
intend at this juncture to qualify him as an expert. I think
he can testify as a fact witness. He's -- he is a -- I've
noticed, just in case, I covered 701 and 702 and fact witness
but he is a -- he's a mining expert from Ghana. And he is
familiar with small family mines, small scale mining in Ghana.
And he will testify that that is a thing, because I know the
Court just said we don't even know that the mine existed.
THE COURT: Did I say that?
MR. FINLAYSON: Well, something of that nature.
Maybe that's what I thought you said.
THE COURT: I thought I said he had to have income.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 202 of 359
964
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. FINLAYSON: No, I'm sorry. I thought I heard
there was a question about the mining, but anyway.
So he's going to confirm -- he's going to corroborate
the existence first of mines in Ghana, because not everybody
may know that, so that's a fact that it makes it more probable
than not that his story is legitimate or is confirmed.
So it's -- he's going to testify about these small
family mines and then about the number of workers that
typically you see that he personally has seen in these kind of
mines, and that's it.
THE COURT: He's going to say there are mines in
Ghana?
MR. FINLAYSON: Yeah.
THE COURT: They're for gold?
MS. CONNORS: Yeah.
THE COURT: And they have employees.
MR. FINLAYSON: And they have -- and that 493 -- and
anywhere from 10 to 2,000, that they're small -- these small
family mines that are off the -- off the books, if you will,
yes.
MS. CONNORS: Your Honor, a lay --
THE COURT: Is that where Keanu Reeves was working?
MR. FINLAYSON: Yes. And Gene Hackman, rest his
soul, yes.
MS. CONNORS: Your Honor, there's certainly a
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 203 of 359
965
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
flipflop here. He even said he is a mining expert.
THE COURT: Yes, but --
MS. CONNORS: If he is an expert, then he should be
qualified as an expert.
THE COURT: No. He can pivot and he's going to say
he's not an expert. He is just going to say there are mines
and they have employees.
MS. CONNORS: Well, I think that's going to actually
be the distinction that matters. Because if he is not going
to -- if he's not testifying as an expert, then what you are
doing is saying he's got to be a lay witness then.
And what dot we need for the lay witness testimony?
We need personal knowledge. And the idea that you're going to
have somebody sit up there and say I do all of this stuff with
mining. But he is not going to say I know this defendant and
I have been to his mine and I have seen that he has workers.
That's the -- that's the issue here.
Because that is not going to be personal knowledge
then that is relevant to this case. The issue is whether
Mr. Torjagbo actually had a mine and whether when he had it in
2020, mind you. So someone coming in now and just saying
there's a thing such as mines in Africa, there is no relevance
to that.
MR. FINLAYSON: We heard -- we heard -- I mean, I was
arguing about profile, maybe that's the wrong word, but this
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 204 of 359
966
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
whole notion of the law enforcement officers often will get up
and give testimony about other -- you know, what other
defendants do or what other cases do or what people typically
do in this kind of situation, I'm not -- I think it's good for
the goose and the gander.
If they can put -- have their officer testify about,
you know, what other -- what money launderers do and this is
consistent with money laundering, I submit that -- and he
wasn't qualified as an expert. I mean, he's testifying from
his experience. My guy is going to testify from his
experience, his own observation --
THE COURT: Is there evidence in the record that he
had a mine?
MR. FINLAYSON: His statements. His statements.
THE COURT: The recorded statement where he said it?
MR. FINLAYSON: Correct.
MS. CONNORS: And, Your Honor, I would note, too,
that from reading the CV that we were presented with this
individual and doing our own research on him, he has never
worked in a Galamsey mine, so he is not going to be able to
offer any personal information about how these mines operate.
THE COURT: What did you call it? A Galamsey.
MS. CONNORS: A Galamsey mine. That's -- I'm sorry.
MR. FINLAYSON: That's the term of art.
MS. CONNORS: That's the terminology.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 205 of 359
967
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. FINLAYSON: I'm not sure what they prefer. If
they want me to qualify him as an expert, I will do that. I
don't know which they prefer. I can do either one. All
right. It's just a question of --
THE COURT: I'm going to let him testify to the very
limited things you've said you want, which is that there is a
country called Ghana in which there are mines and there are
people who work in those mines.
MR. FINLAYSON: And can we talk about how many people
he has seen working in those mines?
THE COURT: Yes.
MR. FINLAYSON: Thank you. It will be short.
THE COURT: Yes, okay. And then what, and then who?
MR. FINLAYSON: Tom Thurman. And he'll be short as
well.
THE COURT: Okay. And then I'm going to take a break
for our afternoon break. And then at that point, you can tell
me whether he's going to testify and we'll move him up here
while the jury is out.
MR. FINLAYSON: Very good.
THE COURT: All right. You may bring them in.
MR. FINLAYSON: Let me go get my witness.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: Y'all may be seated.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 206 of 359
968
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. FINLAYSON: Your Honor, we call Tom Thurman.
THE COURT: I thought you were calling somebody else
first.
MR. FINLAYSON: No.
THE COURT: Okay. Come on up.
MR. FINLAYSON: Sorry.
- - -
THOMAS THURMOND,
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: It's Thomas, T-H-O-M-A-S, Thurmond,
T-H-U-R-M-O-N-D.
DIRECT EXAMINATION
BY MR. FINLAYSON:
Q.
Mr. Thurmond, how are you employed, sir?
A.
I'm a self-employed private investigator.
Q.
And how long have you been doing that?
A.
About 12 or 13 years.
Q.
And what did you do before that?
A.
I was a United States probation officer for the Northern
District of Georgia.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 207 of 359
969
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
In this very building?
A.
Yes.
Q.
And did you have any specialties or things that you did in
that job?
A.
Yes, I was a sentencing guidelines specialist with
emphasis in fraud and organizational offenders.
Q.
And now you work as a private investigator?
A.
Yes, I do.
Q.
And did I ask you to do some work for me in this case?
A.
Yes, you did.
Q.
Okay. Did I ask you to do some investigation on a woman
named Monica Sweeten?
A.
Yes, you did.
Q.
Did you have a -- did you have a date of birth for Monica
Sweeten?
A.
No, I did not.
Q.
Did you have a Social Security for Monica Sweeten.
A.
No, I did not.
Q.
Did you have a middle name for Monica Sweeten?
A.
No, I did not.
Q.
Based on your investigation, how many different Monica
Sweetens did you come up with?
A.
I came up with at least six.
Q.
And how did you do that?
A.
I started with a generic search engine and just typed in
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 208 of 359
970
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
that name and I came back with a lot of different hits, six of
which turned out to be exactly Monica Sweeten.
Q.
Okay. And then how did you determine some of them were
different or how did you know -- how did you know it wasn't
all the same person six times?
A.
Some of the entries that came back had different ages and
some of them had different cities where the person resided.
Q.
So there are at least six people that have you found with
the name Monica Sweeten; is that right?
Q.
And they are different people?
A.
Yes.
MR. FINLAYSON: That's all my questions, Judge.
THE COURT: Okay. Any cross-examination?
MS. CONNORS: Yes, Your Honor.
CROSS-EXAMINATION
BY MS. CONNORS:
Q.
Mr. Thurmond, did you find a Monica Sweeten who works for
a mine in Ghana?
A.
I did not.
MS. CONNORS: Thank you.
MR. FINLAYSON: Nothing further.
THE COURT: Okay. You may be excused. Thank you.
THE WITNESS: Thank you, Your Honor.
MR. FINLAYSON: Your Honor, we call Dr. Owusu.
- - -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 209 of 359
971
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
SOLOMON OWUSU,
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: My first name is Solomon,
S-O-L-O-M-O-N. And my last name is Owusu, O-W-U-S-U.
DIRECT EXAMINATION
BY MS. CONNORS:
Q.
Can you pull the mic closer to you?
A.
Oh, okay.
Q.
Dr. Owusu, where are you employed?
A.
Ghana.
Q.
You're employed in Ghana now?
A.
Oh, employed?
Q.
Yes, sir.
A.
In Nevada.
Q.
Okay. And what do you do there, sir?
A.
I'm a mining engineer.
Q.
Okay. And where are you from originally?
A.
Ghana.
Q.
And when did you come to the States?
A.
I came here 2011.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 210 of 359
972
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Okay.
A.
To study.
Q.
What's your educational background?
A.
I hold a Ph.D. in mining engineering from Colorado School
of Mines and my master's from New Mexico Institute of Mining
and Technology in New Mexico.
Q.
Okay. Talk in the mic so we can hear you?
A.
New Mexico Institute of Mining and Technology from New
Mexico, and my bachelor's in geological engineering from
Ghana, Investors of Mines and Technology.
Q.
Did you grow up in Ghana?
A.
Yes.
Q.
Are you familiar with the goldmines in Ghana?
A.
Yes.
Q.
Can you tell us a little bit about the prevalence of gold
and goldmines in Ghana?
A.
Yeah. So in Ghana we have the large-scale goldmine and we
have the small-scale goldmine. The large scale is where we
have Newmont's Akyem, the big goldmines.
Q.
Say the name or spell it out if you can.
A.
Large-scale goldmining companies.
Q.
Okay.
A.
And we have small-scale goldmining companies. So the
small scale, we have those who are registered by the Minerals
Commission, they are the licensed small-scale minors. And
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 211 of 359
973
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
then we have those who are not licensed or regulated, they are
the illegal small-scale minors, properly known as Galamsey.
Q.
Galamsey. How do we spell Galamsey?
A.
Galamsey is G-A-L-A-M-S-E-Y.
Q.
And have you been down in some of those Galamsey, those
small-scale mines?
A.
Yes. And I do consult for some of them.
Q.
Okay.
A.
I guide them, advise them with my experience and
educational background.
Q.
Okay. How many times have you been down in some of those
small-scale mines?
A.
More than ten times.
Q.
And about how many are there in Ghana, if you know?
A.
There are a lot of small-scale mining operations all over
the country. We have 16 regions and 14 out of the 16 regions
we have small-scale mining operations going on, both legal and
illegal.
Q.
And approximately how many people will work in these
small -- that you have seen will work in these small-scale
mines?
A.
Yeah. So depending on the concession area, the size --
Q.
Yes, sir.
A.
-- somebody can employ ten people, somebody can employ
2,000 people, I have a friend who has employed over 1,500
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 212 of 359
974
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
people.
Q.
And they'll all go down in the hole?
A.
Some are underground, some are operated on the surface.
Q.
And what -- how do they do the work in these mines?
A.
So when they have the area, some use shovels and pickaxe,
you know, rudiment tools. And some also use sophisticated
heavy equipment like excavators, dozers and all that to mine.
They put it on the equipment that is tilted that they
wash, you know, gold is heavy so they put blankets and they
wash. And then the sand goes down and then the gold gets
stuck in the blanket. They remove the blanket, wash in
bucket. Some have big -- you know, big equipment that they
wash in so that the gold will settle down. Then they decant.
After they decant, then they use mercury and other
chemicals to extract the gold, we call it amalgam. So after
they melt the amalgam and then the mercury get out of the gold
and they get the real gold.
Q.
And is this all done by hand?
A.
Some are done with hands, some are done with equipment.
Now the Chinese guys have created a whole lot of sophisticated
equipment that they use in the small scale -- originally,
small scale was supposed to be using rudimental tools and, you
know, and the Ghanaians.
But now, there are a lot of invasion of Chinese guys
in small-scale mining and they are the guys polluting all the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 213 of 359
975
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
water bodies and degrading the mines.
Q.
Does 493 people seem like a normal number that you might
see down in one of these -- working in one of these small
mines?
A.
Yes.
MR. FINLAYSON: That's all my questions, Judge.
THE COURT: Okay. Any cross-examination?
MR. EVERT: Yes, Your Honor.
CROSS-EXAMINATION
BY MR. EVERT:
Q.
Good afternoon.
A.
Good afternoon, sir.
Q.
Were you paid to be here?
A.
Sorry?
Q.
Were you paid to be here?
A.
Well, I heard I'll be paid in October. There's no money.
Q.
Okay. And how much -- how much are you going to be paid
in October?
A.
I think the budget is $7,000. Actually, I wanted to
charge 40,000, but he said there's no money, so I said, well,
let me do it for $7,000.
Q.
He's paying you $7,000 to be here?
A.
Maximum. According to him, yeah.
Q.
All right. Does it depend on what you say here how much
he's going to pay you?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 214 of 359
976
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Ideally, my hours. You know, I would have charged more,
like I said, but I said $7,000 is okay. I'm just coming to
let him know that what he's asking for is something that is
common knowledge in Ghana that, you know, I can provide.
Q.
Sure. So have you ever been to a Galamsey mine owned by
Kremkov Industries?
A.
Please come again.
Q.
Have you ever been to a Galamsey mine owned by a company
called Kremkov Industries?
A.
No. I've visited a lot of Galamsey mines, but some of
them I don't know their names.
Q.
Have you ever heard of a company called
Kremkov Industries?
A.
Nope.
Q.
Have you ever been to a Galamsey mine owned by someone
named Carl Torjagbo?
A.
Nope.
Q.
Before he hired you to be here, have you ever heard of
Carl Torjagbo?
A.
No. Well, Lawyer Leigh told me to come.
Q.
Yes.
A.
But the person that I'm coming to testify, I don't know.
Q.
You don't even know, so you've never heard of him?
A.
Yeah.
Q.
How about Karl Delano, have you ever heard of him?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 215 of 359
977
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
No, I've not heard the name until.
Q.
Until --
A.
Yeah.
Q.
-- he hired you, right?
And you've never been to a mine -- you never heard of
him having -- you've never heard of him and you never heard of
him having a mine, right?
A.
No.
Q.
How much do people who work in Galamsey mines make?
A.
In Ghana cities, those who operate excavators, I heard
they take 5,000 Ghana cedis a month. But every day, they give
them 500 Ghana cedis for daily keeping.
Q.
Okay. And so sorry. This is the people working in the
mines, they're making -- if I showed you a BBC article that
says that a person who works in a Galamsey mine makes about
$125 U.S. dollars per week, is that about right?
A.
125, if you convert to Ghana cedis -- I don't have my
phone here.
Q.
I've got a calculator there for you if you need it.
A.
Yeah, it is like --
Q.
Yeah.
A.
1,301. 1,300 pay week could be the guys who wash the
sand. But the excavator operators, I think they should get
more than that, because every day, according to what I heard
from some of my friends, every day they give them like 500
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 216 of 359
978
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Ghana cedis, so three days would be like a thousand five, 500,
yeah, like a thousand five for daily keeping money alone, that
is the excavator operators.
Q.
All right.
A.
But then those who wash the sand and orpailleurs, they are
called orpailleurs, I don't know that much, it's not going to
be up to 500 Ghana cedis, but for 1,300 pay week will be
small.
Q.
And that's -- sorry, that's in Ghana?
A.
In Ghana, yes.
Q.
So about -- like how much would you say in U.S. dollars is
somebody working in one of those mines making?
A.
In U.S. dollars, let me go back to the calculator.
Q.
Yeah, yeah, please.
A.
Let me see.
Q.
Well, let me just put it to you this way.
THE COURT: Hold on. Let him do it.
MR. EVERT: Yeah.
THE WITNESS: In a month, I will say approximately
$500.
BY MR. EVERT:
Q.
$500 a month?
A.
Approximately.
Q.
Okay. And so over the course of a year, about 6,000 U.S.
dollars is what somebody who is working in one of those mines
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 217 of 359
979
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
makes?
A.
Yes. 5 total, yeah.
Q.
Okay.
MR. EVERT: No further questions.
MR. FINLAYSON: Nothing further, Your Honor.
THE COURT: Okay. Sir, you may step down. Thank you
for coming. Appreciate you.
THE WITNESS: Thank you, sir.
THE COURT: All right. I have to take a quick --
we're going to have our afternoon break right now. Okay?
We're going to work through it a little bit, but
we're going to give you-all 10, 12 minutes for our break.
Okay. All right. Thank you.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Okay. What's next?
MR. FINLAYSON: Mr. Delano wishes to testify,
Your Honor.
THE COURT: Okay. So we're going to take about a
ten-minute break. And when we come back, we'll have him
brought up to the stand and then he can testify from up there.
Okay?
MR. FINLAYSON: Very good.
THE WITNESS: Let me ask you one question first.
I noticed in the playing of the tape, okay, do you
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 218 of 359
980
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
remember the issue came up about the question, it was on
Page 43 of the transcript, where he was asked did he use
those -- the names for anything else or was it just for
payroll.
And I had originally -- originally, the government
was going to take those out, the question where he says,
honestly, I refrain from answering that question. And I just
want to make sure that I know what was done there.
Because we don't have the transcript, they're not
going to have a transcript for the record on appeal. I came
back the next morning, so that would have been yesterday
morning, and I said that I thought you could include
Mr. Delano's statements that he did not want to answer the
question.
You did not include them, did you?
MS. CONNORS: That's correct, Your Honor.
THE COURT: Okay. But did you include the question?
MS. CONNORS: No. For -- for that one, what we had
talked about the day before, I know you came back yesterday
morning, so what would that have been, Tuesday, when we left
this, we were instructed to take out the part where he said,
Did you file for anything else or was it just the payroll,
only that one sentence there.
I mean, did you use them for anything else or was it
just on the payroll?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 219 of 359
981
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
We cut out then. But then you did allow us to keep
in, Did you pay somebody to get those names.
THE COURT: Yes. Well, the defendant did not object
to that. So if we're looking at the transcript -- is the
transcript in the record anywhere? Yes, it is.
MS. CONNORS: I did file -- we filed the one that had
the highlighting.
THE COURT: Okay.
MS. CONNORS: But I do think that one --
THE COURT: I believe what you did.
MS. CONNORS: -- there was an additional line that
came out.
THE COURT: I believe what you did is you did not
include Line 16 on Page 43, Line 16 after the word "names."
MS. CONNORS: That's right.
THE COURT: And then you picked it back up on Line 22
with the word "did."
MS. CONNORS: That's right, Your Honor.
THE COURT: Okay. Do you agree with that, that
that's what happened, sir?
MR. FINLAYSON: I don't disagree, Your Honor. I
think the -- well, there's not going to be a transcript, is
there?
THE COURT: No, but there is the audio recording.
MR. FINLAYSON: I think that's the best record.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 220 of 359
982
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: I just wanted to make sure, because part
of our job is we have to make sure that we have the record
right.
MR. FINLAYSON: Right.
THE COURT: So I believe that means that
Mr. Finlayson got out the portion that he objected to.
MS. CONNORS: That's correct, Your Honor.
THE COURT: And despite the fact that I said the
government could include it, the government decided not to do
that.
MS. CONNORS: That's correct, Your Honor. And there
were actually I think two or either three places where that
happened. We had already reworked everything so we didn't
mess with it.
THE COURT: Yes, okay. I just want to make sure
that -- I don't want there to be confusion as to where -- he
got out the portion he wanted to keep out in that regard?
MS. CONNORS: Yes, Your Honor.
THE COURT: All right. Okay. We'll be back in about
seven minutes. Okay?
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, a recess was taken.)
THE COURT: All right.
MR. FINLAYSON: One moment. I'm going to want the
ELMO.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 221 of 359
983
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: Wait. Hold on a second. Do you have to
stay there? Do you have to stay there? Is one of you going
to stay there?
MARSHAL: We're just going to put one. We were
trying to figure out the opening process of this, Your Honor.
THE COURT: What do you mean? How to open it?
MARSHAL: Yes, Your Honor.
THE COURT: It's closed right now?
MARSHAL: It's closed right now. But we press this
button and now there's a double button system, so we were
like -- we'll get it worked out, Your Honor.
THE COURT: I think the buttons, the bottom one says
open door, I think.
All right. Bring them in. We're good.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. Y'all can be seated.
Call your next witness.
MR. FINLAYSON: Your Honor, we call Karl Delano.
THE COURT: Okay. Ms. Kelley.
- - -
KARL DELANO,
Defendant herein, having been first duly sworn, was examined
and testified as follows:
- - -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 222 of 359
984
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
COURTROOM DEPUTY: Thank you. You may be seated.
Will you please state and spell your first and last
name for the record.
THE WITNESS: Karl Delano, K-A-R-L, D-E-L-A-N-O.
DIRECT EXAMINATION
BY MR. FINLAYSON:
Q.
How are you, sir?
A.
Good.
Q.
I'm going to ask you a few questions. All right?
A.
Okay.
Q.
Okay. Mr. Delano -- and speak slowly so everybody can
hear you.
A.
Okay.
Q.
Tell us your full name at birth.
A.
My full name at birth was Carl Delano Akpene Kwdzo
Torjagbo.
Q.
Can you spell those for the court reporter, the middle
ones, particularly.
A.
Uh-oh.
Q.
Akpene?
A.
Akepene is spelled A-K-P-E-N-E. Kwdzo is spelled
K-W-D-Z-O, I believe.
Q.
That's a lot of names.
A.
Yeah.
Q.
Okay. You don't go by all of those, right?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 223 of 359
985
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
No, I do not.
Q.
Okay. In 2021, did you actually have your name legally
changed?
A.
Yes, I did.
Q.
And what did you change it to?
A.
I changed it to Karl Delano, which is my first and middle
name.
Q.
And why did you change your name?
A.
Well, I decided to change my name because when I was back
in primary school and high school, nobody could pronounce the
name. The teachers were laughing at me. One, in particular,
my math teacher, he --
Q.
Pull the mic up a little closer.
A.
Oh, okay.
One, in particular, my math teacher, he always used
to call me touchable, so now then everybody in the class was
calling me touche, so I had the name change thing in my mind
for a long time, but because I was flying all over the place,
I never really had the chance to do it.
Q.
Okay. Did you change your name to hide your identity?
A.
No, I did not.
Q.
Did you change your name to commit fraud?
A.
No, I did not.
Q.
Did you change your name to launder money?
A.
No, I did not.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 224 of 359
986
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Had you used the name Karl Delano in the past before you
even got your name changed?
A.
Yes, I did.
Q.
Let me hand you what I've marked as Defendant's 4 and 5,
and ask you if you recognize these.
A.
Yes, I do recognize them. These are pictures from my
Instagram.
Q.
Look at both of them.
A.
Yes, they're both --
Q.
Is that you?
A.
Yeah, that's me.
Q.
Does it fairly and accurately represent you?
A.
Yes, it does.
MR. FINLAYSON: Okay. Your Honor, I move Defendant's
4 and 5 into evidence.
THE COURT: Any objection?
MS. CONNORS: No, Your Honor.
THE COURT: Okay. Defendant's 4 and 5 are admitted.
MR. FINLAYSON: If I may publish with the ELMO,
Ms. Kelley?
BY MR. FINLAYSON:
Q.
Okay. So, Mr. Delano, is that your Instagram name?
A.
Yes, it is.
Q.
And what does that say about what the name is?
A.
Karl Delano.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 225 of 359
987
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And there's a 3 on there, right?
A.
Yes, Karl Delano 3.
Q.
And what's the date of that Instagram post?
A.
That's November 2nd, 2015.
Q.
Okay. I'm showing you Defendant's 5.
A.
And that's also Karl Delano 3.
Q.
Okay.
A.
And that's me 21st of 2016.
Q.
2016?
A.
Yes.
Q.
Thank you, sir.
MR. FINLAYSON: Thank you. You can turn that off.
BY MS. CONNORS:
Q.
Let's talk about your background a little bit. Where did
you grow up, sir?
A.
I was raised in Ghana until I was about 17 years. And
then I migrated to the U.S. on an F-1 visa to --
Q.
Slow down.
A.
Okay.
Q.
What did your parents do in Ghana?
A.
Okay. My dad is a Naval officer and my mom is a teacher
in chemistry.
Q.
Okay.
A.
And they later became -- my dad later became the director
of Naval operations for the Ghana Navy.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 226 of 359
988
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
And my mom became the central regional director of
education for the entire central region.
Q.
Central region of Ghana?
A.
Yes, sir.
Q.
Did you come to the United States to go to college?
A.
Yes, I did.
Q.
And where did you go?
A.
I attended Florida Institute of Technology in Melbourne,
Florida.
Q.
And when did you come to the United States for that?
A.
1997.
Q.
Okay. And when did you graduate?
A.
2001, in December of 2001.
Q.
December of 2001 --
A.
2001.
Q.
-- you graduated?
A.
Yes.
Q.
And what did you study at Florida Institute of Technology?
A.
I studied aviation management with flight option.
Q.
Aviation management with flight option?
A.
Yes. With flight option, yes.
Q.
What does that mean?
A.
Okay. Aviation management has got to do with airport
operations, airport management. And the flight portion allows
you to fly airplanes, instruct in airplanes, et cetera.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 227 of 359
989
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And did you learn how to fly airplanes?
A.
Yes, I did.
Q.
And did you become a licensed pilot?
A.
Yes, I became a licensed pilot.
Q.
And what are your -- what licenses did you -- or what
ratings -- take us through your ratings and what type of --
yeah, what kind of ratings you had as a pilot, what that
progress was.
A.
Okay. So you begin with your student pilot's license in
my freshman year. And then by the time I finished the
freshman year, I got the private pilot's license. Then I want
on to get my instrument rating. After I got the instrument
rating, I got the -- my commercial license. That was I
believe in my -- by the end of the junior year.
Q.
Of college?
A.
Of college, yeah.
And then I got my multiengine rating. And by the
time I was a senior, I had my flight instructors license.
Q.
And so what's the smallest plane you were flying?
A.
At that time, it will be training aircrafts, like the
Piper Cherokee, Cessna 172, 182.
Q.
What was the biggest plane you ever flew?
A.
The Boeing 737 MAX.
Q.
We'll cover that in a little bit.
A.
Um-hmm.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 228 of 359
990
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
A very important question, sir.
A.
Um-hmm.
Q.
How old are you right now?
A.
I'm 45 years.
Q.
What's your date of birth?
A.
9/10/1979.
Q.
And you've heard all kinds of things in this case about
that issue, right?
A.
Yes, I have.
Q.
All right. We're going to go through that.
Did you at one point end up with a birthdate listed
as 1975?
A.
Yes.
Q.
Tell this jury how that happened.
A.
Okay. When I was coming to the United States, I had a
visa appointment. And I got my passport --
Q.
This is when you're coming in at 17 for college?
A.
Yes.
Q.
Your first time coming here?
A.
Yes. This was my first time coming, yeah.
Q.
Keep going.
A.
And when the passport was issued, it had the wrong date of
birth on it.
Q.
And this is the Ghana passport?
A.
Yes. My Ghana passport, yes.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 229 of 359
991
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
And my visa appointment was almost like a month
later, so there was no time to rectify or fix the change on
the passport, because if I attempted to do that, I would have
missed my visa interview.
So I came to -- I went to the visa interview, I got
granted the visa. And then I came to -- I came to the
university with the -- with a passport. So that 9/8/75 date
of birth, I was stuck with it because that was the only
documentation that I had.
Q.
So you were stuck with it for several years, right?
A.
Yes.
Q.
Okay. I mean, did -- when you were 17, were you trying to
commit fraud or was there something tricky about how you got
that date of birth back then?
A.
No. Because actually my dad got the passport for me. You
know, he did all of the paperwork for the passport. I had
nothing to do with it.
Q.
Did you try to correct this at one point?
A.
Yes, I did.
Q.
In fact, did you apply for Social Security cards?
A.
Yes, I did.
Q.
Okay. And how did you try to correct that mistake that
was made -- I guess -- let me strike that.
A.
Um-hmm.
Q.
Your first Social Security card you got, what date of
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 230 of 359
992
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
birth did it have attached to it?
A.
It has the -- had the 9/8/1975.
Q.
And was that correct?
A.
Yeah, that was correct because that was the -- it
technically was wrong. But if you're talking in terms of the
document, that's the only documentation, legal documentation I
had, so it just trickled down to every -- every other
paperwork that I got.
Q.
Okay. And then did you later try to correct that?
A.
Yes, I did.
Q.
And how did you do that?
A.
When I was applying for my green card and -- yeah, green
card, what I did was -- everything I had was still in 9/8/75,
so what I did was in the application process, I submitted all
the documents with the 9/8/75 on it.
And I wrote a letter to the INS explaining how --
everything I just described. And I attached the birth
certificate to all of the documentation and asked them to
correct it.
Q.
Okay. So you attached the birth certificate that showed
1979?
A.
Yes, I did.
Q.
And that's when they changed it?
A.
That's when they changed it, yes.
Q.
And you were about how old then?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 231 of 359
993
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
When I applied for the green card?
Q.
When you -- when you straightened that out. When you
fixed that, that was like 20 years ago, wasn't it?
A.
Yeah. Yeah, that was over 20 years ago.
Q.
Did you request a new Social Security number for any
fraudulent reasons?
A.
No, I did not.
Q.
You did get a new Social Security number, right?
A.
Yes, I did.
Q.
And why did you do that?
A.
I did that for two reasons.
One, now that I had my employment authorization,
which was my legal document to work and do anything in the
United States, obtain a driver's license, ID card, anything,
it's now 9/10/1979. Now, you have the Social Security card,
which has information of 9/8/75, so that would be conflicting.
If I go for a job and they run a background check, one, you
have two conflicting documents.
Two, I was having problems with my wife at that time.
The marriage was very abusive. Without going into further
details, I was afraid, you know, that when we separated that
she was going to get -- she could legally get loans and credit
cards in both names because, you know, you guys are still
married and she has access to all of your personal
information, so I told them about it and I tried to change it.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 232 of 359
994
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Okay. And you got a second Social Security number?
A.
Yes, I did.
Q.
Were you trying to do that for any fraudulent reason?
A.
No, I did not. As a matter of fact, after I got the new
Social Security number, I've never used that old
Social Security number since then.
Q.
Never?
A.
Never.
Q.
So let's talk about --
A.
Umm-hmm.
Q.
-- your careers a little bit.
A.
Okay.
Q.
After college, what jobs or career did you have?
A.
Right when I was a senior in college, I was -- I got my
first job, which was instructing the United States, the
Patrick Air Force Base Aero Club.
Q.
Okay.
A.
Yeah. And I was teaching cadets, people who were
interested in going to the U.S. Navy, Air Force, Marines, I
was -- I was teaching them how to fly.
Q.
So you were teaching on Patrick Air Force base --
A.
Yes.
Q.
-- people how to -- people how to fly?
A.
Yes, I was.
Q.
So you were not enlisted at that point, but you were
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 233 of 359
995
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
teaching enlisted people how to fly?
A.
Pretty much, yeah.
Q.
Do I -- do I have it right?
A.
Yes, you have it right.
Q.
Okay. And what type of planes were you training in at
that point?
A.
It's -- it's a military -- it's the military version of
the Cessna 172. They call it the T-41.
Should I continue?
Q.
Sure, yes. Where -- and what was your next job?
A.
Okay. So from there, from teaching in the T-41 for
Patrick for about two, two or three years, I had another job
in Houston, Texas, where I was teaching at Fletcher Aviation
as an instructor. And at the same time, I was working for
Panel Mill Investments as a corporate pilot.
COURT REPORTER: What investments?
THE WITNESS: Panel, like a panel. Panel Mill
Investments.
BY MR. FINLAYSON:
Q.
Panel?
A.
Yeah. Panel Mill Investments, yeah.
Q.
Yeah. You're flying for -- you were a corporate pilot?
A.
Yes.
Q.
And did you fly for some doctors, too, around that time?
A.
Yeah. Yeah.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 234 of 359
996
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Okay.
A.
Actually, Dr. Miller is the owner of Panel Mill
Investments.
Q.
Doctor who?
A.
Dr. Miller.
Q.
Miller?
A.
Miller, yeah.
Q.
Okay. So and you were doing that out in Texas?
A.
Yes, I was.
Q.
And what was your address out in Texas?
A.
It was 2220 Westcreek Lane, Apartment --
Q.
Keep going.
A.
Yeah, apartment E71, Houston, Texas.
Q.
And that's the number -- that's an address we heard about
in this case, right?
A.
Yes.
Q.
Did you live there at some point?
A.
Yes, I did.
Q.
When did you live there?
A.
Throughout my stay in Texas, when I was an instructor and
working for Panel Mill Investments.
Q.
You're talking 15 years ago? When -- when was this?
A.
Yeah. About 15 years ago, yeah. Also after about 2003
onwards -- upwards, yeah.
Q.
Okay. And did you have a driver's license for that --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 235 of 359
997
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
with that address?
A.
Yes, I did.
Q.
Did you -- obviously you moved from there, right?
A.
Yes, I moved from there.
Q.
Okay. But that was an old address of yours?
A.
Yes, that was an old address of mine.
Q.
You didn't live there after they tore down the building?
A.
No, I did not.
Q.
Did you say you lived there after they tore down the
building?
A.
No, I did not.
Q.
Okay. What -- what was your next job in the -- in the
aviation world or -- what did you do next?
A.
Okay. So after Panel Mill Investments, I actually
enlisted in the U.S. Army.
Q.
Okay. And how long was that?
A.
The U.S. Army, I was there for about a year, it was pretty
short.
Q.
Okay. Is there a term that -- was your exit -- did you
get an honorable or a dishonorable discharge?
A.
I was honorably discharged.
Q.
Did you chapter out?
A.
Yeah. We call it chaptering out, yes.
Q.
Where did you go next?
A.
Actually, when I got out of the U.S. Army, my intention
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 236 of 359
998
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
was to go back in as a warrant officer. That was my goal, to
fly the Apache helicopters, the Black Hawks and the 810s.
But when I got out from being enlisted, they were
giving me the runaround. During that time, SkyWest Airlines
was hiring, so I applied for that and --
Q.
SkyWest?
A.
Yeah, SkyWest Airlines.
Q.
And where are they located?
A.
The main -- what do you call it? -- headquarters is I
think Salt Lake City, Utah.
Q.
And they're a subsidiary of somebody?
A.
Delta, Delta Airlines.
Q.
And did you go to work for them?
A.
Yes.
Q.
And is that one of the uniform pictures we see or is that
Flydubai?
A.
No, actually -- yeah, it's one of the uniform pictures you
see.
Q.
Okay. How long were you with SkyWest?
A.
I was with SkyWest for about two years. And then after I
left SkyWest, I went to Mercer Airlines, which is a subsidiary
of United Airlines.
Q.
Okay. Did you at some point go to FlyDubai?
A.
Yes, I was with Mercer Airlines for a little bit, about a
year and a half. And I wanted to fly something bigger. I got
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 237 of 359
999
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
a job with FlyDubai Airlines for the 737 MAX, so I took it.
Q.
Okay.
A.
And then --
Q.
Yeah. And where was FlyDubai based out of?
A.
The United Arab Emirates.
Q.
Where were you -- where was your primary residency during
that period, if you know?
A.
Yeah, my primary -- my primary residency was still in the
United States, in my Douglasville house, the 3081 Leatherleaf
Trail.
Q.
Okay.
A.
But then I was working in the United Emirates. They call
us Expats, people who live outside -- who have a permanent
residence somewhere else but are working outside.
Q.
Sure. How long were you there?
A.
I was there for about three years.
Q.
Okay. I'm going to ask you some questions about Kremkov
Industries.
A.
Okay.
Q.
Okay. Do you know this company?
A.
Yes, it's my company.
Q.
What did Kremkov do?
A.
Kremkov is a mining -- a mining business.
Q.
Okay. When did Kremkov start?
A.
Okay. Kremkov started -- I'll go back to 2013. I had
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 238 of 359
1000
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
a -- when I was a -- my great grandpa was a travel chief for
the Volta Region and --
Q.
And, by the way, any word that is sort of foreign --
A.
It isn't.
Q.
-- either spell it or say it really slowly.
A.
Okay. Volta Region is spelled V-O-L-T-A.
Q.
Okay.
A.
And region, of course, you can spell region, yeah, Volta
Region. He had two pieces of property, one in the Ashanti
Region.
Q.
Ashanti.
A.
Yeah. A-S-H-A-N-T-I Region. And the other one in the
Western Region. And he had leases for 75 years for -- what do
you call it? -- wood properties, with permits for mining.
Q.
Okay.
A.
And when he passed away, I was around six years old, and
he passed those rights down to me via a will.
Q.
When he died and you were -- you got those through a will,
right?
A.
Yes.
Q.
Did -- was there any mine there at that time?
A.
No, there was not.
Q.
There was just permits for it?
A.
Yeah, just permits for it.
Q.
And this was for small-family mining?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 239 of 359
1001
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yeah, for small-scale mining, yes.
Q.
All right. Keep going. When -- when did it -- when did
something start happening with Kremkov?
A.
So I had a childhood friend back in Ghana, her [sic] name
is Anabel Kufour and --
Q.
Kufour?
A.
Yeah. Kufour is spelled K-U-F-O-U-R.
And his parents are also in the mining business.
When I was in the U.S., we sort of like kept in touch. And he
knew I had -- what do you call it? -- because it was a
mine -- because he knew I had the pieces of property that was
willed to me, but, you know, I never really talked much of it,
because I never had any funds to fund a mining business.
So he said he knew this Chinese guy called Mr. Lee
that he would love to introduce to me because he'll be able to
help me develop the land.
Q.
Okay. Did you start -- did you meet Mr. Lee somehow?
A.
Yes.
Q.
Through what medium?
A.
It was like through Skype, you know. Initially it was
through Skype, me, Mr. Lee and Anabel.
Q.
Okay.
A.
And after a few Skype, you know, meetings, he -- he
decided to travel down to Ghana to take a look at the
property.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 240 of 359
1002
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Okay.
A.
So when he -- when he came down to Ghana, he met my father
then, and after --
Q.
Were you there? For that first meeting, were you there?
A.
No, no. I was still in the United States, yeah.
Q.
You were still communicating by Skype?
A.
Yes.
Q.
Okay.
A.
I was communicating by Skype.
Q.
Did you actually meet Mr. Lee in person at one point?
A.
Yes, I did.
Q.
And where did that happen?
A.
That happened when I was in Dubai.
Q.
And tell us about what happened from there.
A.
Okay. So from when he met my dad, they made a deal, you
know, made a deal with us to help develop the land, to mine
the gold. But in exchange, we had to sell him the gold in
payment for the money he invested at 50,000 a kilo.
Q.
Is that like half price, basically?
A.
Pretty much. So we made the deal. And then that began
the -- the mining venture in Ghana.
Q.
And what year are we talking about, approximately?
A.
That's in 2013 when all of these meetings and stuff
happened. So the actual process of starting to develop the
land into any sort of -- you know, starting any mining
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 241 of 359
1003
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
activity on the land, it started with something called -- they
called the environmental impact assessment.
First of all, what happened was my dad went to the
Department of Mining Services, just to inquire about the
permit to see if there was anything else they needed, but he
was told since those permits were issued before that -- even
that Department of Land and Mining Services were formed, there
were no other payments required.
But he -- but they recommended we do something called
an environmental impact assessment to make sure there were no
endangered species, no -- what do you call it? -- endangered
animals or species on the land and that the mining activities
were not going to cause any adverse effect to the ecosystem,
so that started that.
So from 2014 to 2015, the land in the Ashanti Region,
we did the environmental impact assessment. That piece of
property is about ten acres.
And then from 2015 to 2016, we did the environmental
impact assessment for the piece of property in the Western
Region.
Q.
Okay. When did you actually start digging in Ghana?
A.
We started digging around 2019.
Q.
Okay. And who is we? Who was doing the digging?
A.
I was mostly still involved in flying and stuff, so I
wasn't part of the day-to-day, you know, operation of the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 242 of 359
1004
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
mine. It was my dad, my assistant.
Q.
Who is your assistant?
A.
Andrea Lewis.
Q.
Okay.
A.
And Mr. Lee, his brother, Chung Lee, and then there was
another guy called Xing Kong Xi.
Q.
Can you spell that one?
A.
Xing, I think he spells it X-I-N-G. And then it's
K-O-N-G. And then X-I, Xi.
Q.
So you're still flying airplanes. And you're still based
in the U.S.; is that right?
A.
No, no. At this point I'm in Dubai.
Q.
So you're in Dubai?
A.
Yeah. At this point I'm in Dubai, yeah.
Q.
Okay. And this work is going on in Ghana?
A.
Yes.
Q.
Okay. You got an EIN number around this time, didn't you?
A.
Yes. So around 2018, I obtained an EIN. The whole idea
was to -- after the debt for the exploration and the
development was paid for, the -- my long-term goal was to
build a refinery here and make -- sort of like import the gold
here and make deals with like Kay the jewelry, the gallery of
jewelries, Swarovski. What do you call it? What's the name
of that -- the store -- Kay, Jared.
Q.
Are you talking about jewelry companies that the --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 243 of 359
1005
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yeah. Jewelry companies in the U.S. to supply them gold
for their jewelry.
Q.
Do you remember what that EIN number was that you got in
2018?
A.
I believe it's the one ending in 1377.
Q.
Okay. Did you employ workers or did the -- did Kremkov
employ workers there in Ghana?
A.
Yes, they did.
Q.
And how do you know that?
A.
Because I visited all the time. And my assistant, my
assistant and the foremen were in charge of that, so...
Q.
Okay.
A.
Yes.
Q.
So you went -- you actually -- did you actually ever go
down in the mine?
A.
Yes, I did.
Q.
How many times?
A.
In 2018, I visited eight times.
Q.
What about '19, if you remember?
A.
In 2019, I visited six times.
Q.
And how many workers were working in that mine?
A.
For the ten-acre one, the one in the Ashanti Region, there
was about 300, 312. For the one in the Western Region, there
was about 300.
Q.
So that was like 600 people?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 244 of 359
1006
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes.
Q.
This is two different mine sites?
A.
Yes.
Q.
Okay. And were they -- were they all U.S. citizens?
A.
Not all of them.
Q.
Okay. Were some of them?
A.
Yeah. Some of them, yeah.
Q.
Who kept track of the payroll documents for those workers?
A.
Andrea did.
Q.
Andrea Lewis?
A.
Yeah. Andrea Lewis did.
Q.
And how did she maintain -- how were those people paid?
A.
Usually, Mr. Lee does the payment and then we transfer the
money -- we transfer gold to pay for whatever expenses he did.
Q.
But how would the workers actually get paid?
A.
Wire transferred.
Q.
Okay. And who paid them? Who put the button -- who hit
the button that sent them the money, if you know?
A.
Mr. Lee did.
Q.
Were there -- to your knowledge and belief, were there 493
workers there at one point?
A.
Yes, there was.
Q.
Okay. We've heard a lot about a PPP loan, right?
A.
Yes.
Q.
Did you apply for a PPP loan?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 245 of 359
1007
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes, I did.
Q.
What was your purpose -- original purpose or intent in
applying for that loan?
A.
Original purpose and intent for applying for the PPP loan
was to keep the mine in business, operational during the COVID
pandemic.
Q.
Now, what was your understanding about the requirement for
an U.S.-based company or a Ghanaian-based company, what was
your -- what did -- what did you believe was required of you
to apply for that loan?
A.
Okay. So like when I was reading the application and I
was filling it out, what I saw, it says the -- what do you
call it? -- the principal residence of the people should be
in the United States. I relate to that, because I'm an Expat.
I work in the UAE. My principal residence is in the
United States. It's sort of like having an oil rig.
Q.
Okay.
A.
The oil rig is in the middle of the ocean, right? The --
it's not on the soil of the United States. However, the
people that work on the rig have their permanent residence in
the United States, so that's how I saw it.
Q.
How did you learn -- how did you figure out how to fill
out the PPP loan application?
A.
How did I -- I just -- just like any person, I just --
just like everybody else, I just went online and read the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 246 of 359
1008
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
requirements and, you know, just determined if it applied to
me or not. And if it -- you know, when I read all of it to a
layperson, yeah, it applied to me, so I --
Q.
Okay. Was it -- was it easy or was it complicated for
you?
A.
I mean, it was pretty straightforward, you know. I just
read it and I understood what was written in there and I took
it at face value, yes, sir.
Q.
Did you have a lawyer or any kind of advisor help you do
that?
A.
The only help I got was with the documentation. That was
with Andrea gave me the documentation, yeah.
Q.
Andrea gave you help with documentation that was submitted
with that loan?
A.
Yes.
Q.
And what did she give you?
A.
She prepared the payroll list, the -- what do you call it?
She has an accounting degree, so all the -- like the payroll
summary documents, she did. She did the 941s and 940 as well.
And I actually even asked her to help me with my tax returns
because --
Q.
All right. We'll get there in a minute.
A.
But, yeah.
Q.
So you're saying that that list with 493 people on it, you
didn't prepare that list yourself?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 247 of 359
1009
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
No, I did not.
Q.
Did you ask Andrea to give you a list of the eligible
employees for the company?
A.
Yes, I did. I asked her to give me all the people that
would be eligible for the PPP based on the U.S. being their
permanent or like the principal place of residence apparently.
Q.
Did you -- did you read that list carefully?
A.
No. I just look at the first few ones and, you know, that
was it. I didn't --
Q.
Did you notice that Charlie Brown worked for Kremkov?
A.
Honestly, I don't even know who Charlie Brown is so...
Q.
Well --
A.
Yeah, I don't know who Charlie Brown is, so...
Q.
Do you know who -- you've heard of the name John Snow,
maybe?
A.
Yeah. I've heard the name John Snow, yeah.
Q.
Oliver Twist?
A.
I don't know Oliver Twist.
Q.
All right. So these -- you didn't -- you didn't read this
thing with a fine-tooth comb, obviously.
A.
No, I did not.
Q.
Okay. When you applied for that PPP loan --
A.
Um-hmm.
Q.
-- for Kremkov, did you think that was okay?
A.
Yes.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 248 of 359
1010
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Did -- well, let me -- going back to the names real quick.
A.
Umm-hmm.
Q.
You heard Monica Sweeten testify in the trial, right?
A.
Yes, I did. Yeah.
Q.
Did that Monica -- did that woman work for Kremkov?
A.
No, she did not.
Q.
You knew her though, right?
A.
I knew her, yes.
Q.
You knew her -- how did you know her?
A.
We worked together as simulator partners in -- what do you
call it? -- Mercer Airlines.
Q.
So you were training as pilots together?
A.
Yes.
Q.
She didn't work down in the mine at Kremkov?
A.
No, she did not.
Q.
Okay.
A.
I mean, you know, like the guy testified, you know, there
could be several people with the same name, yeah, so...
Q.
Did you -- you did help her buy her house, right?
A.
Yes, I did help her buy her house.
Q.
And why did you do that?
A.
That's because I knew her, I trusted her. And I knew, you
know, she wasn't up to anything. Anything -- what do you call
it? -- shady, so I just helped her.
Q.
Okay. You just helped her?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 249 of 359
1011
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yeah.
Q.
Okay. So let's go back to the PPP loan.
A.
Um-hmm.
Q.
Did Chase Bank approve you originally for a -- approve you
for a $9.5 million?
A.
Yes.
Q.
What -- what happened very quickly with that money?
A.
After the loan was approved, I think $6.5 million was
clawed back.
Q.
Okay. And what was your reaction to that?
A.
I didn't quite understand why that happened, so I called
them to find out what it was. It took about two weeks of
going back and forth and with phone calls and being on hold
for like 45 minutes to an hour.
And then eventually, the -- I think -- I believe they
told me to submit certain documents so they could unfreeze it.
I submitted the documents, nothing happened. Eventually, I
kept calling and the answer I got was that the program had run
out of money, so I -- I just --
Q.
And we heard a call --
A.
Umm-hmm.
Q.
-- government's 108. Was that you on the call there?
A.
Yeah, it was me.
Q.
What did you tell them? Were you frustrated in that call?
A.
Yes. I was very frustrated, yeah.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 250 of 359
1012
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Okay. And what did you tell them your plan was with
regard -- or your concern was with regarding them holding back
that $6 million or $6.5 million?
A.
Yeah, I wasn't quite sure what was going on. And my
concern was that they were holding onto the money. And there
was a timeframe that you needed to use the money to gain the
productive out of the money.
So let's say if I was going to restock, you know --
what do you call it? Keep the mining business going and stuff
like that, I needed to pay the workers to keep them going to
generate some income. And if they were holding on to the
funds and I couldn't do that, and then now the grace period
has passed, then now you'll be faced with, you know, a shorter
time to repay the loan.
Q.
Okay. And you told them that, right, on the phone.
A.
Yes, and I asked them -- yeah. I asked them to give me
something in writing stating the reason why they were
withholding the funds. And, you know, that way I have
something in writing to back me up.
Q.
Because at this point, were you already contemplating
FlyingJack, the trucking company? Were you already getting
ready to -- or thinking about putting the money into
FlyingJack?
A.
No. I'm not quite sure what the timing, because it was --
as soon as I got -- yes, it was around that time. It was
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 251 of 359
1013
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
around that time. Because after I transferred the money
from -- the $3 million from Chase to -- to what do you call
it? -- the PNC account.
Q.
Um-hmm.
A.
I called Ghana. And when I called Ghana, I spoke to my
dad. And he spoke to the minister -- the ministry of health
there. And he was telling him -- you know, he was told that
they had no idea when the COVID vaccine would be available.
And there was no specific timeframe, you know, in the U.S.,
you know, and other countries, they had started vaccinating
people, but they didn't have a specific timeframe as to where
the vaccine went and when the vaccine would be available, so,
I mean, if we -- even if we restarted the -- if we just --
what do you call it? -- try to keep the mining going, we'll be
faced with the same problems we were, so it wasn't going to be
feasible.
Q.
Did you shut the mine down?
A.
Yeah. So after that, we shut the mine down.
Q.
Okay. And what was your understanding --
A.
Um-hmm.
Q.
-- or belief that what you could do with that PPP money
when you shut the mine down?
A.
Okay. So I did a little bit of research. And I went to
the SBA website. And they were -- they were giving examples
of what qualified for forgiveness and what did not qualify for
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 252 of 359
1014
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
forgiveness.
One of the examples that was given was if you have --
let's say you had two McDonald's, and you borrowed money for a
PPP loan for one McDonald and then used the money for the
second McDonald, right, would it qualify for forgiveness? It
says no, it wouldn't qualify for forgiveness, you would be
responsible for paying the money back.
And another example that was cited on the SBA website
was let's say you had a business and the business caught on
fire or a tornado or something terrible happened and destroyed
the business, and the business owner had no reasonable way of
continuing the business, and you've already had the PPP money,
what do you do with it? You had two options. You could give
the money back. Or if you had another business, you could
invest it in that business.
Q.
But could you get forgiveness of the loan?
A.
No. Then it would be the sole responsibility of the
business. And I believe you are trying to show an article and
I think the prosecutor --
Q.
That's okay, don't --
A.
That's okay, yeah. Don't -- okay.
Q.
So when the mine shut down, Kremkov -- the mine --
A.
Um-hmm.
Q.
-- shut down in Ghana; is that right?
A.
Yes, yeah, yeah.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 253 of 359
1015
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Okay. And at that point, did you decide to put the money
into the trucking company?
A.
Yes, but actually, they're -- you know, I hadn't made up
my mind then. I started FlyingJack as a brokerage.
Q.
Okay.
A.
So I started FlyingJack as a brokerage just to have
something to do. I held on a little bit of the money, because
I wasn't sure what to do. And we weren't out of the pandemic
yet. So basically we were operating as a brokerage, pairing
people looking for carriers to carry their goods for them.
Q.
Okay.
A.
And in about two months into the brokerage, I realized --
it became -- it was more of a carrier's market. A carrier's
market is if you have too many loads and not enough trucks to
carry the loads.
Q.
But did you buy trucks?
A.
Yeah, so that's when I made the decision to use some of
the PPP money to expand the brokerage to include a carrier
business.
Q.
And how many trucks did you buy?
A.
I bought 11 tractors and ten trailers.
Q.
Did you buy pieces of land?
A.
Yes, I bought two pieces of land that I was going to
convert into a truck yard, where -- where you could service
the trucks, park the trucks and so forth and so on.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 254 of 359
1016
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And did you have to pay insurance on all of those trucks?
A.
Yeah, I had to pay insurance on the trucks, the trailers.
Q.
What other expenses did you have there for FlyingJack?
A.
I had other expenses, like training of employees -- what
do you call it? -- advertising, website.
A.
Did you actually build a website for FlyingJack?
A.
Yes, we did have a website.
Q.
All right. Let me -- I'm going to divert real quick here.
A.
Okay.
Q.
You heard the testimony from Mr. Oppong, right?
A.
Yes. I did.
Q.
Did you know him in Ghana?
A.
Yes, I did know him in Ghana.
Q.
Did you go to school with him in Ghana?
A.
Yes, I went to school with him in Ghana.
Q.
Were you in the same grade in Ghana?
A.
No, we're not.
Q.
What's the difference in age there?
A.
I was about four years younger than him.
Q.
Okay. And you went to the same secondary school; is that
right?
A.
We went to the same secondary school. He was in a
different grade. I was -- but because we are from -- we are
both from the same town, we were friends.
Q.
Okay. And so do you remember when he came over to your
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 255 of 359
1017
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
house and tried to talk to you about a website?
A.
Yes, I remember that.
Q.
And how did that go? Where was -- it was to your
business, wasn't it, it was to your office?
A.
Yeah, yeah. He came to my house and then I was going to
my office, so he was in my car and we're driving. That's when
all the argument and the recording he was doing was taking
place.
Q.
Okay. And what did he want you to do in that call, in
that -- in that meeting?
A.
Basically, he was trying to get me to -- what do you call
it? -- pay or, you know, get services from one of his friends
in building a website for Kremkov.
Q.
He thought you needed a website for Kremkov?
A.
Yes, he thought I needed a website.
Q.
And what did you tell him?
A.
I told him, no, I didn't need a website, because -- what
do you call it? -- with the mining for security reasons, you
don't post -- post your location online. That way you don't
have any -- anybody with a -- with a web point coming in there
trying to look for gold, so it was not necessary.
Q.
Okay. Did you then -- but you did get a website, you're
saying, for FlyingJack?
A.
Yes, I did get a website for FlyingJack.
Q.
And did you use his guy for that?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 256 of 359
1018
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
No, I did not.
Q.
So you're four years younger than Oppong?
A.
Yes, I am.
Q.
Now, this may seem weird. But we heard about you having
some plastic surgery, right?
A.
Yes.
Q.
Did you have your face redone?
A.
No, I did not.
Q.
To make you look younger or something?
A.
No, I did not.
Q.
That was your stomach, right?
A.
Yes.
Q.
Okay. So he said y'all were the same age. Oppong said
you two were the same age.
A.
I didn't recall him saying that. He said something that
we couldn't be like that far -- the age difference couldn't be
that afar apart. I don't recall him -- I don't recall him
saying we're the same age.
Q.
But regardless, that's not true, is it?
A.
No, it's not. We're not the same age, no.
Q.
All right. Going back to you putting money into
FlyingJack --
A.
Um-hmm.
Q.
-- you admit that you do that, right?
A.
Yes, I did.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 257 of 359
1019
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And that -- and where did that money come from?
A.
The money came from the PPP loan.
Q.
Okay. Did you think there was something wrong with that?
A.
No, I did not.
Q.
What was your intent in terms of what to do with that
money that you owed the bank?
A.
The intent was to pay it back, because I -- you know, like
I said -- like I stated earlier, if you did not, you know --
actually, let me backtrack a bit.
You know, during the time that I was, you know,
contemplating what to do, I was receiving letters from the
bank. And in one of those letters, it stated if you do not
apply for forgiveness by this date period, then the loan
becomes a loan that you have to pay. Okay. So, you know,
that kind of reinforced what I read on the website, so at this
point.
So I made up my mind, okay, I wasn't going to apply
for forgiveness. I was just going to take the loan, you know,
to use it to expand the brokerage or the carrier for -- to
include a carrier and then pay the bank back when the money
started -- the payments were due.
Q.
Okay. I'm going to hand you up what's in evidence.
A.
Umm-hmm.
MR. FINLAYSON: May I approach, Your Honor?
THE COURT: You may.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 258 of 359
1020
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
BY MR. FINLAYSON:
Q.
-- Defendant's 2 and 3.
A.
Um-hmm.
Q.
Which are already in.
A.
Umm-hmm.
Q.
Do you recognize those bank statements?
A.
Yes.
Q.
And what are they?
A.
They are the -- they are invoices for the PPP loan from
Chase Bank.
Q.
Okay. And what does the July one say that you owed?
A.
The July one said that I did not owe anything, zero
balance.
Q.
Okay. So when was the first payment due to Chase Bank for
the PPP loan?
A.
I believe it says August 29th.
Q.
Of what year?
A.
August 29th of 2022.
Q.
August 29th of 2022 is your first payment due?
A.
Yes.
Q.
Did you make that payment?
A.
No, because I was arrested on May 12th of 2022.
Q.
Thank you. And to just maybe state the obvious, after you
got arrested, you didn't get out; is that right?
A.
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 259 of 359
1021
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Let's talk about your tax return a little bit.
A.
Okay.
Q.
Did you file a tax return for the year 2020?
A.
Yes, I did.
Q.
How many tax returns did you file for 2020, actually file
and have accepted for 2020?
A.
Okay. So I filed the one ending -- with the
Social Security number ending in 5040, which was rejected
once, and then I resubmitted it again.
Q.
Okay. And did you file the other one?
A.
No, I did not.
Q.
Who filed the other one?
A.
Andrea did.
Q.
Andrea who?
A.
Andrea Lewis, my assistant.
Q.
And how did that happen?
A.
Okay. So while we were playing catch-up for the
documentation that was required, you know, for the PPP and the
taxes and all that stuff, Andrea had suggested to me, because
she had an accounting degree, there was certain tax returns
and tax credits that I could claim as a business owner that I
was not aware of. She said something about mining exploration
tax credits, and some other business tax credits that I'll
qualify for as a business owner.
Previously, I filed my own taxes, but never in that
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 260 of 359
1022
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
capacity, so I said, okay, if you know it, you -- can you do
it for me? And she agreed -- she agreed to do it. But then
she started dragging her feet. And I was kind of in the
middle of studying for interviews and preparing for --
preparing for 777 training and stuff like that so --
Q.
I'm sorry, 777, what is that?
A.
Oh, I'm sorry. It was the Boeing 777.
Q.
How were you going to train for that?
A.
I enrolled in --
Q.
Yeah, sorry. You're good.
A.
Yeah. I enrolled in some courses to get myself ready.
Because I had jobs lined up with China Southern Airlines and
then Vietnam Airlines.
Q.
For the 777?
A.
Yeah, the Boeing 777 for China Southern and the Boeing 787
for Vietnam Airlines.
Q.
Okay. So you're trying to file your taxes, your tax
returns for 2020, right?
A.
Yes.
Q.
Okay. And Andrea agrees to help you?
A.
Yes.
Q.
So tell me, how could she help you? How can she access
your stuff?
A.
So I gave her my user name and my password. She had the
key to the house.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 261 of 359
1023
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
You gave her -- you gave someone else your user name and
password?
A.
Yeah.
Q.
Okay.
A.
To TurboTax, to the TurboTax app. And I kept calling her,
you know, and she wasn't answering.
My usual routine was during around 5:00 -- between
5:00 and I'll say 8:00 p.m. was to go to the clubhouse in our
subdivision, play a little bit of chess, use the gym, and, you
know, come back home around 8:00 or 9:00.
I think when I was in the clubhouse, she came to the
house, because she thought I was -- I told her I was leaving
for Miami. She thought I had already left for Miami. So she
came to the house and I believe that's when she filed the tax
return. I told her all the information she needed for my tax
return.
Q.
And how would she get that information?
A.
It's on my laptop. And I told her all of the information
she required to file the taxes were in a folder on my desktop.
Q.
And what all information did you have in that folder?
A.
I had -- what do you call it? -- like driver's license,
Social Security number, you know, all kinds of things.
Q.
Did you have the old information as well as the new?
A.
Yes, I had the old information as well as the new. And I
think when she accessed the computer, she saw the information
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 262 of 359
1024
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
for my -- what do you call it? -- my Texas and Social Security
number ending in the 6010, which was that 9/8/75.
Because my last base before I went to the UAE was
Houston, Texas, so she accidentally filed using that
information thinking it was the right information.
Q.
Okay.
A.
And then I didn't know. I came back home. I -- what do
you call it? -- I did what I had to do. Then I filed the
return. Because I didn't hear anything from her, I filed the
return ending in -- with the -- with my information, the
correct information I have, the 0540 and my correct date of
birth.
The following day, I left for Miami. Because I was
supposed to meet with a friend who was flying in from Air
India. I was in Miami for about I think four or five days.
On my return from Miami, I get a -- I think an email
alert or a text alert that my tax return had been rejected
because that -- that came from TurboTax, because the -- the
EIN that was used to file the tax return was issued after --
it was issued in 2021, so it cannot be --
Q.
Okay. How many EINs did you have?
A.
I had one TIN, the 1377 and two EINs, I think 7 --
Q.
Okay. You don't need to -- you had the 1377, that was
from 2018?
A.
Yeah.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 263 of 359
1025
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
And that was the oldest one you had?
A.
Yeah, that was the oldest one I had.
Q.
Did you get the other ones for any kind of malicious or
mal reason?
A.
No.
Q.
So when it spit -- when TurboTax spit you out --
A.
Um-hmm.
Q.
-- for having the wrong EIN, did you just try another one?
What -- what happened?
A.
Yeah, so when I am -- eventually -- I didn't get -- I go
home that day later in the evening, because I had to go to
Rome, Georgia, for, you know, a friend's birthday party. When
I came back home -- when I was at the party, actually, Andrea
called me, but I did not return the call. I did not hear the
phone ring, there was so much noise at the party.
I got home that day and the following morning, I
resubmitted the tax return with the -- what do you call it?
-- the EIN that was issued in 2018.
Later on that day, I called Andrea and she told me
that she was calling me at the party, because she -- she saw
that she had filed the tax return and she saw the alert that
the tax return that she had filed was -- what do you call it?
-- rejected because of the same reason that was given to me,
that the EIN was issued at a later date than the tax year that
was supposed to be used for. So she resubmitted it with the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 264 of 359
1026
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
EIN -- the EIN that was issued in 2018.
Q.
Did you know she was doing that?
A.
No, I did not.
Q.
Did you ask her to do that?
A.
I asked her to, yeah. I asked her to do it, but I
didn't -- she didn't respond, so I assumed she wasn't going to
do it.
Q.
So you originally asked her to file your taxes?
A.
Yes.
Q.
You didn't think she did it?
A.
Yeah.
Q.
So you filed them?
A.
Yes.
Q.
And then she did it?
A.
Yes.
Q.
And she used the wrong information?
A.
Yes.
Q.
Okay.
A.
So at this point, I tried to contact TurboTax to see if
they could cancel the one she filed, because I knew I had the
wrong information. I haven't used that since I got my new --
the new Social Security number, I've never used that
Social Security number, I've never used it for anything.
Q.
Okay.
A.
So I contacted TurboTax and I was told that the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 265 of 359
1027
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
information has already been sent, so there's nothing I can do
to cancel it. I'll just have to wait for the IRS to get -- to
get in touch with me if they have any questions.
Q.
Did you actually get a tax refund for 2020?
A.
Yes, I did.
Q.
And do you remember about how much it was?
A.
It was about 3.36.
Q.
3.36 million?
A.
Yes, million.
Q.
And you've heard lots of talk about this return. Did you
pay in tax withholdings for that year?
A.
Yes, I did.
Q.
You personally did or someone did it for you?
A.
I didn't personally do it. Mr. Lee did that.
Q.
Why would he do that?
A.
I asked him to do that because I was trying to get all my
paperwork ready so that I could apply for the PPP loan.
So what I did was the last amount of gold I had, I
traded that in, it was about 80 kilos, approximately,
$4 million, and I asked him to -- asked him to pay my taxes
and then pay for a loan that I had with Abu Dhabi Commercial
Bank for $500,000.
Q.
So let me break that down a little bit.
A.
Um-hmm.
Q.
So you basically made a deal with him for a large quantity
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 266 of 359
1028
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
of gold for $4 million?
A.
Yes.
Q.
Okay. And he agreed to pay your tax withholdings for the
year?
A.
Yes.
Q.
And then repay a loan in Abu Dhabi?
A.
Yeah, Abu Dhabi Commercial Bank, yeah.
Q.
How much loan did you owe in Abu Dhabi?
A.
$500,000.
Q.
Did you have bank accounts in the UAE?
A.
Yes, I did.
Q.
How many did you have?
A.
About three of them.
Q.
What was the $500,000 loan for?
A.
That was for me.
Q.
For you.
A.
Actually for Kremkov. Let's put it that way, yeah.
Q.
Okay. All right. So you got that return. Did they give
you -- did the IRS give you all the money that you actually
asked for on that return?
A.
No, he did not -- they did not.
Q.
They took some of it out, right?
A.
They took some of that. So what happened was after I
filed the returns, I got a letter from the IRS. The letter
stated that I owed them $7,000, and if I had any objections --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 267 of 359
1029
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
if that was deducted from my refund, and if I had any
objections, I should put the objections in writing. So what I
did was I wrote back to them saying, no, I did not have,
objection, you can deduct the amount. And then later they
send me the -- they send me the -- what do you call it? -- the
refund in the mail.
Q.
Do you have a sense of what that delay was, like how much
time that was?
A.
From the time they send me the letter, I would say about
three weeks.
Q.
Okay.
A.
I think about three weeks.
Q.
And you did not object to that?
A.
No, I did not object to that.
Q.
So did you think someone was actually looking at your
return?
A.
Yes, they were.
Q.
The money you used to buy the house and the cars --
A.
Um-hmm.
Q.
-- where did that money come from?
A.
For all the personal items, the house and the personal
vehicles, it came from my refund.
Q.
Did it come from a PPP loan?
A.
No, it did not.
Q.
The PPP money went to FlyingJack; is that right?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 268 of 359
1030
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes. Roughly about a million dollars, a million point 1
was spent for the trucks, the trailers, insurance,
registration, the pieces of property, the two pieces of
property.
And the rest, which is the $2 million that's left out
of the PPP funds was seized by the government.
Q.
Was that when you were arrested, around the time you were
arrested, they took $2 million out of your account?
A.
Yes.
Q.
And that was -- that was May of 2022, right?
A.
May of 2022, yes.
Q.
You originally got the money -- you originally got the
PPP loan funded in March of '21, right?
A.
Yes.
Q.
Okay. So they -- around April of '21, they clawed back 6
and a half million; is that right?
A.
Yes.
Q.
And even after a whole year later, you had over $2 million
still in the bank, right?
A.
Yes.
Q.
Did you try to conceal that money in any way?
A.
No, I did not.
Q.
When you bought your cars --
A.
Um-hmm.
Q.
-- did you try to conceal your identity in any way?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 269 of 359
1031
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
No, I did not.
Q.
What name did you buy your cars under, if you remember?
A.
Personal vehicles?
Q.
Yes.
A.
Mostly Carl Torjagbo.
Q.
Okay. Why not Karl Delano?
A.
I believed one of them I bought in Delano, because I
bought it after I changed the name, I made the name change,
yeah, legally changing that, yeah.
Q.
And when they came to arrest you, did you tell them where
your cars were?
A.
Yes, I told them where they were.
Q.
Okay. And they -- they took them?
A.
Yeah, they took them. They seized them.
Q.
Let's talk about the day you were arrested, okay?
A.
Um-hmm.
Q.
Do you remember that day?
A.
Yes, I do.
Q.
May the 12th, 2022.
A.
Yes, I do.
Q.
And we heard a recording of your interview?
A.
Yes, we did.
Q.
What was it like when they -- what did they do when they
first saw you and arrested you?
A.
I was just -- I was -- actually, I was expecting the DOT
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 270 of 359
1032
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
to show up, the Department of Transaction, because they said
they were going to come and inspect my trucks and stuff like
that, so I had all the paperwork ready, was at the truck yard
waiting for them, just pacing around the trucks.
And then all of a sudden, there was a bunch of SUVs
just boxed me and people -- you know, FBI officers just rushed
out of the car with, you know, AR15s and M16 rifles and
yelling, yelling, get on the ground, get on the ground.
And I'm like -- you know, I was stunned in the
beginning. And then it took me a couple of seconds to
actually comprehend what was going on, get on the ground. And
so I get on the ground and then they put me in cuffs and --
Q.
Was that scary for you?
A.
Yes, it was.
Q.
About how many people did it look like?
A.
It was about ten of them.
Q.
Okay.
A.
It was about ten of them, yeah.
Q.
You brought that up at the end of that recording, right,
you brought it up?
A.
Yes, I did.
Q.
And what did you tell the guy? What did you tell the
agent?
A.
I told the agent, you know -- you know, the way -- the
manner of the arrest I think was -- from one, I think it was a
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 271 of 359
1033
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
little bit use of excessive force, to be honest with you.
Q.
Okay. Did you --
A.
Um-hmm.
Q.
I mean, were you laughing? Did you think it was fun or
anything like that?
A.
No, it was not fun. No, it was not.
Q.
Okay. When he interviewed you --
A.
Um-hmm.
Q.
-- did you have any documents with you to review?
When he interviewed you that day at the arrest, did
you have documents with you about Kremkov or PPP to review?
A.
No, I did not.
Q.
Okay. Were you giving him the best estimates that you
could at that time?
A.
Yes, because one, the -- you know, I was mentally
distracted, you know. I did my best to keep my composure and
stuff like that, but -- and in those conditions, I mean, you
know, things are jumbled up in your head, you're not -- you
know, you're not thinking right. You're in fight or flight
mode, so you're not really thinking.
Q.
And did you try to flee? Did you try to run?
A.
No. I did not try to run, no.
Q.
Did you fight with them in any way?
A.
No, I did not.
Q.
Did you try to be as cooperative as you could?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 272 of 359
1034
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes, I did.
Q.
The funds that you received from your tax return --
A.
Um-hmm.
Q.
-- did you believe that these were from lawful or unlawful
activities?
A.
They're from lawful activities. What happened was, like,
as an expat, when I was working for FlyDubai and things like
that, I still filed taxes.
There's something called a foreign earned income tax
law. I'll just touch on that briefly. If you were working
outside the U.S. and you meet -- you're a U.S. citizen working
outside of U.S. and you meet anywhere from zero to $130,000,
that's about the range, right, it was tax exempt.
And anything above that, the government charges you
for taxes. Actually, I filed a couple of tax returns for some
American guys, American pilots that work for Emirates itself.
And if you make anywhere more than $130,000, it automatically
charges you for the taxes.
And how do you pay for it? Because those foreign
companies don't have an EIN. They don't have a -- what do you
call it? -- they have no records in the U.S.
So what you do is you -- there are two methods of
payment with the IRS. You just send a wire transfer for the
amount you owe and then reference your Social Security number.
That's how you make the payment.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 273 of 359
1035
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Or you can use the IRS free debit system and then you
can make that payment or you can write them a check. So when
I was, you know, trying to get all my -- my -- my -- what do
you call it? -- paperwork ready, Kremkov earnings so the
income that I earned from all the mining from Kremkov, I just
submitted what my tax liabilities will be with the
withholdings and things like that, because I was way above
$130,000, and applying the foreign earned income tax is not
going to make a difference, so which --
Q.
You took a loss, didn't you, you took a passive loss
through --
A.
Yeah, I took a passive loss, too.
Q.
And how did you get that loss?
A.
We got the passive loss because when -- in the middle of
2019, when we started actually digging for the gold, it
took -- it takes awhile to dig the shafts, the mine shafts and
the tunnels for you to get to the gold and extract it.
Our labor cost at that time with the impact
assessment, the mining exploration, the labor costs, by the
time we actually started making -- inputting about 100 kilos
per month, it was over $12 million.
Q.
And how much were you paying your workers at Kremkov?
A.
We paid them about $50 an hour.
Q.
So we heard Dr. Owusu talking about what he saw. Your
world was a little different?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 274 of 359
1036
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
My world is a little different because mostly -- what do
you call it? -- the Chinese people have -- like we have --
with the equipment and stuff we use, we're able to bring in
more gold at a faster rate than the people -- most of the
other people that do it, so...
Q.
And you also had U.S. citizens working in your mine?
A.
Yes, I did.
Q.
Did you have to pay them more?
A.
Yes.
Q.
We heard about --
A.
Um-hmm.
Q.
-- the fact that you incorporated FlyingJack in Wyoming;
is that correct?
A.
Yes.
Q.
Did you do that for any kind of sneaky reason? Why
Wyoming?
A.
Okay. So when I was preparing for the -- setting up the
brokerage, right, I had -- I took an online course on -- to
learn about how the brokerage system works and to get the
brokerage license.
Q.
What does that mean, like the trucking industry? What is
a brokerage? What do you mean by a brokerage?
A.
So it's just like a real estate brokerage where, you know,
like a broker. But in this sense, it's just transportation.
Where you link a business with a carrier and then you get
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 275 of 359
1037
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
profit off -- you make profit off transporting their goods for
them.
Q.
Is that like drop shipping or something?
A.
No. So the broker just connects -- like let's say you own
a Walmart, right? And you want -- and let's say you wanted --
I'll explain.
Let's say you own a Walmart, and another person owns
a milk farm or something like that, cattle with milk, and they
want their milk transported from Point A to Walmart, right,
you are the broker.
So you contact the farmer, who's looking for the
trucks. You -- what do you call it? -- you try to get the
best carrier who is going to give them the cheapest rate. You
transport the goods for them and then you charge a fee for
that. That's a brokerage.
Q.
That's what you were doing before you went to -- before
you started FlyingJack? That was like a side project of
yours?
A.
No, it was FlyingJack but --
Q.
All right.
A.
But, you see, so the logistics is having the brokerage and
the carrier. You can either be a carrier, broker or you do
both.
Q.
Okay. So going back to my question.
A.
Um-hmm.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 276 of 359
1038
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Why Wyoming? How did that happen?
A.
Oh, yeah. So when I was taking the course, right, one of
the advice the instructors -- the instructors gave was that if
you are setting up your brokerage, set it up as a -- use asset
protection lawyers.
And the reason he gave for that was there was this
famous case, right, where a broker hired a carrier to carry
certain goods. But what happened was the broker did not --
did not research the carrier's background and didn't know that
the carrier didn't have insurance.
Long story short, he hired him, he picked up the
goods, was driving, and then the truck ran into a car full of
family members. And the entire family was killed. And there
was a civil lawsuit, a wrongful civil lawsuit, a wrongful
death civil lawsuit filed.
And the broker was eventually held liable because the
judge said or the court said that if he had done his due
diligence, right, then he would have known the carrier didn't
have insurance and wouldn't have hired him and would have
saved the lives.
So, I mean, there was like -- it was like a
multimillion dollar lawsuit and he said so, you know, not
to --
Q.
Let me stop you there.
A.
I get it, I think. Why Wyoming though?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 277 of 359
1039
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Ah, yes. So they said use asset protection lawyers. So
what I did was I researched -- I researched asset protection
lawyers. And I called them through a legal zoom. And then
they advised me, okay, you know, the best thing to do is set
up as a Wyoming, LLC, that protects your personal assets from
civil lawsuits in case something like this happens.
Q.
Okay.
A.
So I paid them a fee and they set up the company for me.
Q.
And what name did you use for that?
A.
FlyingJack Logistics, yeah.
Q.
And what name did you personally use for that? Did you
mention Torjagbo or Delano or do you remember?
A.
Oh, Torjagbo. Torjagbo, yeah.
Q.
So were you trying to hide your identity or somehow hide
behind FlyingJack when you created it in Delaware [sic]?
A.
No, I did not.
Q.
And your name --
A.
Um-hmm.
Q.
-- either Delano or Torjagbo, it's attached to everything
we've talked about in this case, right?
A.
Yes.
Q.
And did you ever try to hide or conceal yourself?
A.
No, I did not.
Q.
Is there anything that I haven't covered that you think I
need to bring up?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 278 of 359
1040
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Let me think.
Q.
It's okay.
A.
I couldn't think of anything, yeah.
MR. FINLAYSON: No further questions, Your Honor.
THE COURT: All right. Cross-examination?
MS. CONNORS: Yes, Your Honor.
THE COURT: Are you guys okay to stay a little later?
Okay. All right. Very good. I like the enthusiasm.
CROSS-EXAMINATION
BY MS. CONNORS:
Q.
All right. So, Mr. Torjagbo --
A.
Umm-hmm.
Q.
-- I'm going to try to see if I can clarify a few things.
So you just testified that in preparation for getting
ready to file your PPP loan.
A.
Yeah.
Q.
Okay.
A.
Uh-huh.
Q.
So preparing to get ready to file your PPP loan would have
happened January of 2021?
A.
Yeah. I'd say something like that, yes.
Q.
Okay. And so you testified that you asked Mr. Lee to pay
your taxes for you so that it was -- in preparation for your
PPP loan.
So you asked him to pay $3.4 million to the IRS for
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 279 of 359
1041
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
taxes for you?
A.
Yes, I did.
Q.
Just to get the taxes back from IRS?
A.
I had to file my taxes, yes.
Q.
You didn't have to file taxes. You -- or if you were
going to file taxes, you didn't have to invent withholdings to
then get back from the IRS.
You could have just said I didn't pay any
withholdings. And what would have happened then?
You would have gotten zero dollars. Because you
would have offset your income by those passive losses that you
were talking about.
The only way you got a tax refund was because of
saying you had withholdings that you supposedly asked your
friend to send to the IRS.
Is that your testimony?
A.
My testimony is I paid withholdings and I filed my taxes.
I didn't invent anything.
Q.
Okay. But you did not testify that you paid your
withholdings. You're claiming you got somebody else to pay
withholdings?
A.
Yes, because we -- given the short timeframe, the best
person to do that for me was Mr. Lee.
Q.
Okay. But do you understand that in January of 2021,
you're in a new tax year.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 280 of 359
1042
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
So if you had not paid withholdings in 2020 yet, then
you just don't pay withholdings, right?
A.
No, that -- you know, for -- you know, if -- if I'm -- I'm
thinking of foreign earned income. I don't think it works
that way.
Q.
But you weren't reporting foreign earned income, were you?
A.
No, because I was way above -- I wasn't claiming the
foreign earned income, because I was way above the $130,000.
Q.
But you didn't report any foreign earned income, did you?
A.
Because I'm not required to report foreign earned income.
Q.
You wouldn't be required to pay tax withholdings if you
didn't actually have any tax withholdings, right?
A.
I don't get what you're trying to get. I don't get your
point.
Q.
So you're saying -- well, let's clarify.
A.
Um-hmm.
Q.
Tax withholdings --
A.
Umm-hmm.
Q.
-- are supposed to be because you are paying the IRS in
advance, which typically is through a W-2.
So your employer withholds your federal tax liability
as the year is going on so that at the end of the year, you
don't end up with a big bill.
A.
Umm-hmm.
Q.
But it's based on what your earnings are and the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 281 of 359
1043
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
withholdings are going over.
A.
Um-hmm.
Q.
So there was no reason for you to have to pay
withholdings, or more particularly, to allege that you had
withholdings on a tax return, right?
A.
So I don't -- I don't get what you are trying to -- you
know, what you're insinuating, but...
Q.
Well, let's back up then.
A.
Okay.
Q.
So you said you had earnings --
A.
Umm-hmm.
Q.
-- in 2020?
A.
Yes.
Q.
You said -- well, you told Agent Caruana you always file
your own tax returns.
A.
Um-hmm.
Q.
You said you filed the tax return ending in 0540?
A.
Yes, I did.
Q.
Why would it be that you had to fill out the field for
withholdings. You've seen your tax returns. There are a lot
blank spaces on there, right?
A.
Yeah.
Q.
There's no requirement that you have to fill something in
for withholdings, right?
A.
Okay. So all of the information that I input for the tax
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 282 of 359
1044
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
returns was computed by software, so I just go by what the
software says.
Q.
Okay. But you understand, you heard Intuit come in
here --
A.
Umm-hmm.
Q.
-- and they said they don't suddenly -- they don't invent
in your tax return that --
A.
That was -- it was --
(Multiple Voices Overlapping)
Q.
They're paying you $3.4 million in tax withholdings,
right?
A.
It wasn't Intuit. We have a bookkeeping software that
computes how much tax liability I'm supposed to have based on
the income I have. And based on that, I input that
information into the -- you know, into the -- what do you call
it? -- into the Intuit software. And then it goes to the IRS.
It's the -- it's the same as if I -- when I was
working for FlyDubai or something. I get my paycheck, you
know -- you know for -- what do you call it? -- I get my
income, I input it in the software, it takes me -- it tells me
whether I have -- based on foreign earned income, whether I
have a liability or not, so that's what I did.
Q.
And if you didn't have any liability, you just wouldn't
have any, right?
A.
Yes. If I didn't, yes.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 283 of 359
1045
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
Okay.
A.
But according to the software, it says I had, so whatever
the liability that the software said I had, that's what I
paid.
Q.
So let's --
A.
Umm-hmm.
Q.
-- go back to the beginning.
A.
Okay.
Q.
You said you had earnings of $9 million.
A.
Yes.
Q.
But you had losses of over $9 million.
A.
Yes.
Q.
But you're saying your bookkeeping system wouldn't have
computed that that was zero dollars, then, and so, therefore,
you would have zero tax liability?
A.
No, it did not compute that.
Q.
All right. And then let's talk about your assistant, this
Andrea.
A.
Um-hmm.
Q.
Did you provide Andrea's phone number to anybody?
A.
No, because the -- what do you call it? -- my phone,
laptop, documentations, birth certificate, a whole bunch of
other items was stolen when I was moving from the 3081
Leatherleaf Trail. And that issue was brought up during
the -- during my bond hearing. So I lost contact. I don't
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 284 of 359
1046
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
have that information.
Q.
So you don't know and you don't have any idea about where
she lives, if she works for anyone else. You would have no
way to get in touch with her?
A.
She and her husband moved to Romania.
Q.
Okay. So let's talk about the -- her filing tax returns
for you.
A.
Um-hmm.
Q.
So your claim is what -- or your testimony was --
A.
Umm-hmm.
Q.
-- is that she came to your house when you were not there
and then looked at a folder on your computer and found old
documentation predating 2002 saved on your current computer;
is that right?
A.
Yes.
Q.
And you say she was there at your house to file that tax
return, right?
A.
Yes.
Q.
She's at your house in Douglasville?
A.
Yeah.
Q.
Why on earth would she put a Houston address on your tax
return?
A.
Because I thought -- you know, my last place of operation
was Houston, Texas. So she might have seen that and thought
that was the current information.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 285 of 359
1047
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
But she didn't put a base in Houston, Texas, on your tax
return as the place -- as your address, as where you live,
right?
A.
No, she did not.
Q.
And you're saying that this person is coming to your house
in Georgia, knows you, comes to your house before, right?
A.
Yeah.
Q.
But yet on that tax return, you saw that the 6010 tax
return claims that you were a Texas resident for the entire
year of 2020?
A.
Yes, because the information she saw was my Texas address
and Social Security number and that's the information she
used. I cannot -- I cannot -- I cannot speculate on what she
was thinking and how she made her decisions, but that's what
she did.
Q.
Okay.
MS. CONNORS: So, Ms. Kelley, if you could please
give me the --
BY MS. CONNORS:
Q.
So, Mr. Torjagbo, your testimony earlier was that Andrea
calls you, you're at a party, you miss the call?
A.
Yes.
Q.
But then you're talking to her and she says, oh, I
accidentally submitted this tax return, it had gotten
rejected, I then went ahead and resubmitted it again.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 286 of 359
1048
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
She didn't say she accidentally. She said she
submitted -- she filed a tax return, it was rejected. So she
was calling me to tell me that she was resubmitting it. But I
didn't pick up the call because I was at a party.
Q.
Okay. And you talked to her on what -- at what timeframe?
Were you talking to her after the party?
A.
That was the next day. That was the next day, yeah.
Q.
Okay. Okay. And so you're -- you've seen before the
Intuit records, right?
A.
Which records are you referring to?
Q.
So I'm going to pull up Exhibit 220.
MS. CONNORS: Ms. Kelley, could I have the station --
oh, it doesn't look like it's coming on.
COURTROOM DEPUTY: Just give it a second. There you
go.
MS. CONNORS: Okay.
BY MS. CONNORS:
Q.
All right. So it's your testimony she's filing this tax
return 6:30, 7:00 p.m. that goes through.
And then the next morning, bright and early, 8:42
a.m., you're hitting resubmit on your tax return that you're
claiming you did file under 0540.
And conveniently, the only thing that changes between
both of those tax returns is the EIN on the W-2?
A.
Because that was the message that she got or she saw and I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 287 of 359
1049
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
saw the same message.
Q.
Okay. The message didn't say it's because you need to put
1377 as the EIN on the W-2, right?
A.
Okay. Because the -- all EINs and all documentations for
Kremkov were in a folder and if she looked at it, she knew --
she knew that the EIN -- the tax was rejected because of the
EIN and not being issued after certain date, automatically,
she would use the only EIN, which is the 1377, that was issued
in 2018.
Q.
Okay. Issued in 2018?
A.
Yes.
Q.
Long after 2002, when you said that you changed your
Social Security number, right?
A.
Yes.
Q.
So you said you had a file on your computer with your old
documentation. Why would you have an EIN from 2018 in this
old documentation that she had to have used to file this tax
return?
A.
Because everything on my desktop is organized. Okay. So
I have personal information, company information, pictures,
you know, different folders. So she was looking in the folder
where -- where the information for Kremkov was. Obviously,
she's going to see the EIN, which is --
Q.
Not associated with Kremkov, right? That EIN does not
have Kremkov's name on it, does it?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 288 of 359
1050
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
I don't think so. I'm not -- I'm not sure.
Q.
It doesn't. You saw the records from IRS. 1377 --
A.
Um-hmm.
Q.
-- does not have Kremkov's name on it. It has your name
on it?
A.
Yes, but --
Q.
It has Carl D. Torjagbo.
A.
Yes, but it was the only EIN or TIN that was issued in
2018, so it made perfect sense that that would be the EIN that
she would use.
MS. CONNORS: Can we pull up Government's
Exhibit 106, please.
And, Ms. Kelley, can you transfer it to the
paralegal, please?
BY MS. CONNORS:
Q.
Mr. Torjagbo --
A.
Um-hmm.
Q.
-- on May 7th, 2021 --
A.
Um-hmm.
Q.
-- after you have a phone call with Chase Bank that we
heard in court --
A.
Umm-hmm.
Q.
-- you were told you needed to provide information to
establish that Kremkov Industries was in operation before
February 15, 2020.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 289 of 359
1051
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
And they even specifically told you that any
documentation needed to have the name of the company on it
that you got your PPP loan on -- application -- the loan
under.
A.
Um-hmm.
Q.
And you submitted this document, knowing that it was fake.
This is for 1377. You just admitted that company -- this EIN
is not associated with Kremkov Industries, there -- it is
impossible for IRS to have issued you this notice on
September 1st of 2018, with EIN 1377 saying Kremkov
Industries, Carl Delano Torjagbo, sole member, right?
A.
Okay. I have -- I have no knowledge of anything fake.
EINs, and I have no way of generating -- what do you call it?
-- a letter with the letterhead from the IRS. Each time you
apply for an EIN or TIN, a letter is automatically generated
and mailed to you, so when they --
Q.
Okay. So --
A.
So when they -- when they asked for -- what do you call
it? -- either a tax return or something with the company's
name on it, I went digging and this is what I found and that's
what I sent.
Q.
Okay. But you just admitted that EIN is not associated
with Kremkov Industries, right?
A.
Well, I just saw that when the agent -- the agent was
testifying about the procedure for changing it. And, you
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 290 of 359
1052
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
know, I don't know anything about that.
Q.
Okay. But this is still -- this is a form you submitted,
right? This is a letter you submitted to the bank?
A.
Yes, it's a letter I submitted.
Q.
Okay.
A.
And it's a letter I received, so...
MS. CONNORS: If we can pull up Government's
Exhibit 503 and put it side by side with this.
BY MS. CONNORS:
Q.
Now, Mr. Torjagbo --
A.
Um-hmm.
Q.
-- you've seen Government's Exhibit 503 before, right?
A.
Yes, I have.
Q.
You see that the address in September 2018 --
A.
Umm-hmm.
Q.
-- for EIN 1377 is 3081 Leatherly Trail. And it does not
get changed until you end up renting an office suite after you
already got your PPP money, right?
A.
Yes.
Q.
So it is impossible that the IRS could have sent you a
letter on September 1st of 2018 instead addressed to 3081
Leatherleaf Trail, right?
A.
No. You said the address on file was 3081 Leatherleaf
Trail, Douglasville, Georgia. And in the bottom, it says
September 2018 to June 2021.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 291 of 359
1053
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
That's correct.
A.
Yeah.
Q.
Do you understand that the name of the street is
different?
A.
Yes, but...
Q.
It says Leatherly Trail and not Leatherleaf Trail.
A.
Yeah. Yeah, but because the name of the street is
different doesn't mean a letter wouldn't come there. If
you -- you know, let's say you -- you are trying to mail
something to somebody. You put in an address and even the ZIP
Code is not correct, the post office sometimes figures that
out and they'll send it to you so just because the Leatherleaf
wasn't --
Q.
So wait. I want to make sure that I understand.
So you think that the post office pulled the correct
address for you and put it on an IRS letter. Is that what
your testimony is?
A.
Yeah. My testimony is whatever was sent to me via the
IRS, I received it, even if the spelling of the name was not
correct.
Q.
So let's point out another thing about this.
A.
Um-hmm.
Q.
You said how would you be able to make this letter.
A.
Um-hmm.
Q.
Well, because you probably did receive a letter for 8332
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 292 of 359
1054
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
that you were able to change, right?
A.
No, I cannot -- I have no way of changing a letter, no.
Q.
So if you look at 8332, the name of that company is
identical to what is on this letter. Do you see that?
A.
The name of which company?
Q.
8332, it says Kremkov Industries, Carl Delano Torjagbo,
sole member.
And that is the same exact name as what appears on
this EIN letter?
A.
Yeah, but it doesn't mean I changed it.
Q.
Well --
A.
It doesn't prove that I changed it or it doesn't mean that
I did it.
Q.
Well, let's talk about a couple of other things with this
letter.
A.
Um-hmm.
MS. CONNORS: If we can zoom in on the part that has
941s. There you go.
BY MS. CONNORS:
Q.
So, Mr. Torjagbo, you submitted four EIN -- or, sorry,
four 941s when you filed your PPP loan, right?
A.
Yes, I did.
Q.
Okay. So you're familiar with 941s, right?
A.
Not until -- I didn't know what were 941s until the PPP
process. And actually with those 941s, Andrea was the one
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 293 of 359
1055
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
that generated them and did that, yeah, filled it -- filled
them out.
Q.
Okay. It's convenient. Andrea seems to do everything.
Is she here in the United States at this time or was
she in Ghana at the mine?
A.
She's not in Ghana at the mine. She's currently in
Romania with her husband.
Q.
Okay. But what about in 2021, where was she?
A.
In 20 --
Q.
Here, right?
A.
Yeah. She was here, yeah.
Q.
So you're saying somehow she's able to get all of the
information being in the United States, she's able to get the
accurate information about your mine, but somehow you can't?
A.
Which information are we referring to?
Q.
Anything. 941s, 940s, the payroll. You're saying she's
here in the United States, just like you.
Why would you rely on what she is saying in terms of
these forms?
A.
I rely on what she's saying because I'm a pilot, she's an
accountant, she's the bookkeeper. I fly airplanes, you know.
Q.
But you're the owner of the company, right?
A.
Yes, I'm the owner of the company. But she does the
bookkeeping and she, you know, does the payroll and she
maintains all of that stuff. She has an accounting degree.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 294 of 359
1056
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
So I actually lean on her expertise for things like that.
That's why I hired her.
Q.
So her expertise is creating fake payroll that says
Keanu Reeves is an employee of your mine?
A.
There -- it's not the Keanu Reeves actor. Just because
the name Keanu Reeves appears on that, that doesn't mean
it's -- there are a dozen of people called Keanu Reeves.
Q.
How do you know that?
A.
You know, I'll implore you to Google it and search it
like -- what do you call it? -- the agent here did, you would
probably find --
Q.
How do you know somebody named Keanu Reeves is an employee
of your company? How do you know somebody named Keanu Reeves
is an employee of your company?
A.
I just heard it here when you -- you know, it's been the
center of the topic of discussion in the last two hours.
Q.
So you're saying you never looked at a single document for
this PPP application that you submitted?
A.
I looked at them, but I did not scrutinize and go through
line by line by line for each and every employee that was
listed there. No, I did not do that.
Q.
But you still signed the certification saying that all of
the information in that PPP loan was accurate.
A.
Yes, it was accurate, to the best of my knowledge. If
that employee is in my database, they get paid by us, then
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 295 of 359
1057
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
they're our employees and the information is accurate.
Q.
And so you have access to that, that information? You're
saying you've got an employee database that you can pull
information from?
A.
Yes.
Q.
Have you pulled any information to provide for this case?
A.
I've been locked up. I don't --
Q.
A subpoena was still served. But nothing was turned over,
right?
A.
Yes, a subpoena was served, but it doesn't -- a subpoena
doesn't do any good if I don't have access to the information
to provide.
Q.
You have friends here who have access to your place. In
fact, you had someone who was staying in your house after you
got locked up, right? Trying to take care of things, right?
A.
I did mention earlier that when I was moving --
Q.
No, Mr. Torjagbo. Answer my question.
We are talking about when you got arrested --
A.
Um-hmm --
Q.
-- when you got arrested in 2022 --
A.
Um-hmm.
Q.
-- after you got arrested, someone was staying in your
house. That is a year after you had moved into that house.
A.
Nobody was staying in my house.
Q.
You were paying -- you had some friends, I think they've
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 296 of 359
1058
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
even been in court this week. You had some friends who were
coming to your house. They were trying to take care of
things. I think you even sued one of them or got mad at them
because you thought they were not handling your stuff
properly.
Any one of those people could have accessed your
documents and turned them over, provided them, right?
A.
Okay. Backtrack. The laptop that I have, which had all
the information from Kremkov on it was the laptop that was
stolen, together with my birth certificates, my phones, every
information that I had. And that was documented or spoken
about during the bond -- bond hearing. It's in all the
dockets in the bond hearing, so you can look that up.
So after I had moved from 3081 Leatherleaf Trail to
5104 Greythorne Lane, the laptop that -- that I had with all
of the information on it does not exist.
The people -- the people that I am referring to that
they are supposed to be in my house and taking care of my --
my stuff, are actually stealing and selling the stuff, so...
Q.
Well, Mr. Torjagbo, let me ask you this.
A.
Um-hmm.
Q.
You're saying -- your mines are in Ghana.
A.
Yes.
Q.
You have to rely on people to give you the information
from Ghana, right?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 297 of 359
1059
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes.
Q.
So it doesn't matter if your laptop is stolen, right?
A.
What -- what information are we talking about?
Q.
You -- Kremkov Industries --
A.
Um-hmm.
Q.
-- if you needed to ask --
A.
Um-hmm.
Q.
-- Michael Lee, someone that you mentioned -- you've said
you had a foreman.
A.
Um-hmm.
Q.
You could have asked those people to provide you
documentation related to Kremkov and the employees that you
had in 2020, right?
A.
Not if I don't have any contact information. I don't have
anything.
Q.
You could have contacted family members, someone else.
You've still got family in Ghana, right?
A.
I tried. I tried. There's one sitting in the back of the
room. You can ask him. It's been awhile. It was a wild
goose hunt looking for people in a foreign country without an
address, a street address, a phone number, no way of locating
them.
Things in Ghana don't work like the United States
where you have a street address and you can just pull up to
somebody's address, 1985, you know, K Street and then you find
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 298 of 359
1060
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
the person. It doesn't work like that.
Q.
I'm going to agree with you.
A.
Umm-hmm.
Q.
They don't work the same.
A.
Um-hmm.
Q.
You don't pay Social Security taxes in Ghana. You don't
pay U.S. federal taxes in Ghana. You don't pay Medicare taxes
in Ghana, right?
A.
I'm a U.S. citizen. I pay for it.
Q.
You wouldn't have to, right?
A.
Well, it's a choice. I pay for it.
Q.
Yes. But certainly there's no reason that all of your
employees, 493 people, that you would be withholding
U.S. federal taxes for them, Social Security taxes, Medicare
taxes and claiming that you were even going to pay federal
unemployment tax for them?
A.
Okay. So let me elaborate on that. Like I said, Andrea
and -- Andrea was in charge of that. I'm a pilot. You know,
I fly airplanes. At any given time, I could, you know, be in
four different continents, okay?
That issue about the withholdings came to light when
we were preparing for -- and, you know, I asked her to prepare
the documentation. Actually, with the documentation, the
instructions on the Chase Bank documentation said if you
haven't yet applied for your -- what do you call it?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 299 of 359
1061
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Let me phrase it differently. If you have not yet
submitted your documentation for taxes, because the PPP portal
was opened in January and most taxes were filed in April,
submit estimates of what you intend to file.
Q.
Well --
A.
So let me finish.
So now, this documentation submitted were estimates.
Now the -- what do you call it? -- when we are trying to
figure out what documents needed to be sorted out with the IRS
and what needed not to be sorted out, we go -- we -- we would
go to the IRS website. And that's where we were -- I
realized, okay, she's deducting all of this stuff that doesn't
need to be deducted because of foreign earned income laws.
And according to the IRS, if a company is physically
located outside of the geographic boundaries of the
United States, the company doesn't even need to file a 940 or
a 941.
Q.
So you're saying you told Andrea to file those for your
PPP loan? Is that your testimony?
A.
Yeah. My testimony was that the application requested
documentation if you hadn't paid for that. If you hadn't yet
filed for taxes, submit estimates of what you intend to file.
But then when we -- after we had submitted the
documents and we're trying to play catch up, because like with
the PPP application, there was a long line of people, I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 300 of 359
1062
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
learned that -- you know, before I -- I decided to go into it,
I read online, I watched the news media, everybody's just
rushing to apply for it.
Now, if you don't get your application in on time,
you know, you might never get the money. So even when my
documentations were not all in line altogether, I just sent
the application with the estimates anyway. That way, you
know, by the time the application gets processed, I had
everything in place, so that's what I did.
Q.
But you didn't have anything in place, right? Because you
never paid Social Security taxes to any of those people. You
never paid federal taxes to any of -- for any of those people.
You never paid Medicare taxes?
A.
Yeah, well, I never did that.
Q.
All you did --
A.
Umm-hmm.
Q.
-- was write numbers on forms that you're saying you had
actually never even paid out?
A.
Yeah, we -- we --
Q.
So do you understand --
A.
Yeah, I understand it, but like --
Q.
Mr. Torjagbo, let me finish.
A.
Okay.
Q.
Do you understand --
A.
Um-hmm.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 301 of 359
1063
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
-- that your PPP loan had to be based on accurate
information. You were attesting that it was true and
accurate. You were not attesting --
MR. FINLAYSON: Objection. Objection. I'm sorry.
The compound -- way compound question, it's just too many --
MS. CONNORS: Okay.
THE COURT: I'm going to overrule the objection. You
were trying to make a point. Do you want to start again?
MS. CONNORS: Yes, Your Honor.
THE COURT: Now, he interrupted and now you
interrupted. So just go back, take a minute. You know where
you are. Start again however you want.
And people, let her ask her question. Okay? Thank
you.
BY MS. CONNORS:
Q.
All right. Mr. Torjagbo --
A.
Yes.
Q.
-- when you signed --
A.
Um-hmm.
Q.
-- that PPP application, you were saying that all of that
information was true and correct. There was nothing on that
form that said that you could just guess, right?
A.
It wasn't a guess. The information there was true and
accurate. However, when we went back -- all -- when I went --
when we went back and looked at the rules, right, it did not
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 302 of 359
1064
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
apply to us, foreign earned -- if the company is physically
located outside the United States, I did not have to file a
941, I did not have to withhold W-2 -- what do you call it? --
federal income taxes and do all of those withholdings because
of foreign earned income's law.
Q.
And you also then did not qualify for a PPP loan, right?
A.
No, I did qualify. Because to the best of my knowledge,
the application said that to a layperson who doesn't know
anything, if you read the application, you know, they don't
expect us to be psychic to kind of guess what Congress
intended the PPP application, the PPP loan to be or what --
what do you feel it -- somebody who made the application, you
know, their frame of mind or what they intended.
What they put on the application is what a layperson
who doesn't know anything about -- what do you call it? --
anything relating to the formation of those forms or what you
intended would portray what's on the form to be.
And it says plainly in Line 7, and we read it, the
principal place -- the principal -- the applicant's principal
place of residence has to be in the United States. And to the
best of my knowledge, it applied to me. So I didn't see
anything wrong.
Q.
So let's talk about that, Mr. Torjagbo.
A.
Yeah.
Q.
So you just testified that nothing on the application says
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 303 of 359
1065
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
this stuff. And you're also testifying, though, you read the
regulations so closely that your opinion was you could open a
new company with PPP money, right?
A.
I never said you could open a new company with PPP money.
I just said if the money is used for a different business, or,
you know -- and for -- you know, a different business, other
than the business you applied, you applied for originally with
the PPP, then it becomes your responsibility.
Q.
Okay. Well, that's not what you said. You gave this
example of if you owned two McDonald's, right?
A.
Um-hmm.
Q.
That's what you said.
A.
Yeah.
Q.
You read these regulations so closely that your opinion
was if someone owned two McDonald's --
A.
Um-hmm.
Q.
-- right --
A.
Um-hmm.
Q.
-- so you already have both of them?
A.
Um-hmm.
Q.
And one of them for some reason you couldn't go forward
with --
A.
Um-hmm.
Q.
-- you could then use your remaining company -- you could
use the PPP money for that right one, right?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 304 of 359
1066
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
Yes, if you did, then you don't qualify for forgiveness,
you have to pay for it then.
Q.
Well, it's not even the issue of forgiveness. Then under
your theory, that would have been a permissible purpose for
the PPP money, right, to use it for the second McDonald's that
you already had?
A.
Okay. Yeah --
Q.
You could use it for that, right?
A.
I didn't create those examples. It's an SBA website that
gave those examples because --
Q.
Let's focus on the example that you used here in court.
A.
Okay.
Q.
So when you're talking about the two McDonald's that you
said earlier, right?
A.
Um-hmm.
Q.
So you said that your understanding --
A.
Um-hmm.
Q.
-- was that if you owned two companies --
A.
Um-hmm.
Q.
-- and that you got the PPP loan under just one of them --
A.
Um-hmm.
Q.
-- that you could use the money for the other one, right?
A.
Um-hmm.
Q.
FlyingJack didn't exist when you got your PPP loan, right?
A.
No, it did not.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 305 of 359
1067
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Q.
So there would be no reason for you to believe that you
could use PPP money for FlyingJack, right?
A.
I did not use PPP money -- let me phrase it a different
way.
The initial startup cost of PPP money was from -- the
startup cost for a brokerage is not very expensive for -- the
filing cost was about $2,500, you buy phones, telephones,
about four or six phones, I bought about six computers for
about -- I had, you know, a deal with Dell. They gave me
these computers for like $300 apiece. I bought six of them,
telephones, Internet, and then your insurance. That's all you
need for the brokerage. And it didn't cost me more than
$8,000 to set up the brokerage.
Q.
But that's after you already had the PPP money, right?
A.
Yes, that's after I had the PPP loan, so it --
Q.
So, Mr. Torjagbo, listen to my question.
A.
Um-hmm.
Q.
So there is no possibility that you could have taken.
A.
Umm-hmm.
Q.
The two McDonald's example that you supposedly saw --
A.
Umm-hmm.
Q.
-- and convert that into what I could do is use that PPP
money for some entirely different business venture, right?
A.
That was just one example of many examples.
Q.
But it's --
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 306 of 359
1068
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
A.
So in -- if you're comparing apples to apples or apples to
oranges, it wouldn't work out this way. Because that was just
one example of somebody owning two McDonald's, getting a loan
in one and using it for the other.
There were several other examples -- other examples.
The other example was if you owned, let's say, you know -- I
think, you know, the business stated something like it was in
Florida or something like that, like a bakery or something
like that and you had a tornado or a fire and the business was
damaged or destroyed, so that you could not reasonably
continue, then if you used the money for something else and
not that business, it becomes your responsibility.
Q.
There was no tornado, there's no hurricane, there's no
flood. There's nothing like that that prevented you from
going forward with Kremkov Industries, right?
A.
The vaccines, the lack of vaccination. The COVID lack of
vaccination, yeah.
Q.
The PPP loan -- oh, I'm sorry.
THE COURT: Do you want to continue on longer? Do
you want to take a break for the evening and continue after?
What do you want to do?
MS. CONNORS: I think I'm fine if the jury is fine.
But I understand if they're not.
THE COURT: I'm seeing less enthusiasm, so why don't
you get to a good stoping point and then we will pick it up in
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 307 of 359
1069
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
the morning. Okay? I'm going to make that decision, too,
because we've got to talk about -- say again.
MS. CONNORS: I'm feeling like maybe there is a
conflict.
JUROR: This juror needs to let her dad know. We're
happy to stay longer, but she needs to -- she needs to make a
phone call.
THE COURT: Why don't y'all step back there, talk
about how long you want to stay between now and 6:00. And
then come out.
But listen to me real quick. We're on good timing.
Okay?
But you-all come back here in a couple of minutes or
just tell the CSO and then we'll talk about it.
Okay?
Thank you.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Y'all can be seated. I'm sorry to have
stopped you.
MS. CONNORS: No, not at all.
THE COURT: I don't know what their plan is for that.
And we do have to do a little bit more on the jury
instructions.
Okay?
Well, why don't we do that now. We're all here.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 308 of 359
1070
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
We've all got a lot of energy.
You have my written copy. Anybody want to talk about
any part of it? Any problems or concerns about the edits that
are in here?
MR. FINLAYSON: No new concerns, Your Honor.
Obviously I would renew the Kousisis argument, but nothing
besides that.
THE COURT: No. Yours was not that, yours was a due
process claim -- I mean, a --
MR. FINLAYSON: Ex post facto issue.
THE COURT: Yes.
MR. FINLAYSON: But it was related to Kousisis.
THE COURT: Okay.
MR. FINLAYSON: But nothing additional.
THE COURT: So on Page 7, we will now keep the
highlighted part, because the defendant has elected to
testify.
We'll take out Page 8, the discussion of a
transcript.
MS. CONNORS: Your Honor, Page 2 had that
highlighting about if the defendant did not testify. That
would need to be removed.
THE COURT: We'll take that highlighted part out
because he has now testified. Thank you.
On Page 22, we're going to keep in the aiding and
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 309 of 359
1071
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
abetting provision?
MS. CONNORS: Yes, Your Honor.
THE COURT: No one has asked me to take it out. And
at least now we've heard about a person in Romania and some
other folks.
Okay?
Good faith, do we keep that in now?
MR. FINLAYSON: I would ask.
THE COURT: Okay. Anything the government wants to
say about that?
MS. CONNORS: No, Your Honor.
THE COURT: Okay. I think that's it then.
All right. So we're going to prepare a final final
version. If you-all see something after court today that's
different, I want you to let me know. But keep in mind I
don't want to be working on it tomorrow morning, I want to be
working on it this evening.
COURTROOM SECURITY OFFICER: They're ready to leave
now.
THE COURT: Okay. They want to leave now?
COURTROOM SECURITY OFFICER: Yes.
THE COURT: Okay. Why don't you have them come in
and we will dismiss them. I'm going to give them one more set
of information.
Okay?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 310 of 359
1072
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
But hold on. How long do you think you have on this?
MS. CONNORS: Probably longer than they would like.
THE COURT: Okay. I'm not going to give them an
estimate. I'm just going to tell them they're going to hear
closing arguments and begin their deliberations tomorrow.
Does that sound -- does everybody think that's
happening?
MS. CONNORS: Yes, Your Honor.
THE COURT: Okay. All right.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: Okay. Y'all can be seated.
So we're going to stop for the day. That's what I
understand?
JUROR: Yes.
THE COURT: Okay. I want to let you know we are in
good shape as far as the timing.
Okay?
You will hear my final instructions and you will
certainly begin deliberations tomorrow.
Okay?
I know the estimate we gave you and we are doing our
best to keep it on track so everyone should not worry about
that.
Okay?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 311 of 359
1073
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
All right. Thank you. Don't talk about this case.
You know what I'm going to say about that, right? Everybody
at home is abiding that instruction, right?
Okay. Thank you very much. We'll see you tomorrow.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
JUROR: Can I ask a question?
THE COURT: Yes. Go ahead. What's your question?
JUROR: So when we're done with this, are we still on
call for next week?
THE COURT: No.
JUROR: That was my question.
THE COURT: No. Thinking ahead. All right.
JUROR: Well, yeah, I have plans.
THE COURT: All right. Y'all can be seated.
And you can step down, sir.
THE WITNESS: Thank you.
THE COURT: All right. Anything y'all need to talk
about tonight?
MS. CONNORS: Your Honor, the summary exhibit issue,
if we can get that resolved?
THE COURT: Yes. We're talking about the one that
has the chart that we've now used with the different -- is
that the one we're talking about?
MS. CONNORS: We have the four summary exhibits, the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 312 of 359
1074
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
two that came in through IRS Agent Sal Hazel as well as the
two from Adrienne Richardson today.
THE WITNESS: What do you want to say about that?
MR. FINLAYSON: I'm trying to remember. I feel like
the rule changed and I just kind of want to remember what it
is. But I generally would object to the summary exhibit going
back. But if the rule has changed and it goes back, then I --
THE COURT: All right. Take a look at it. I think
it has and I think it does.
MR. FINLAYSON: Okay. I've been wrong before.
THE COURT: You can look at it.
Do you think it has and do you think it does?
MS. CONNORS: Yes, Your Honor. Rule 1006, summary
exhibit may be admitted as evidence to prove content of
voluminous records, whether those records have been admitted
or not. And that then becomes the evidence is what that Rule
implies. It is affirmative evidence, it's not a
demonstrative.
THE COURT: Yes. The demonstrative is what was
created by the U.S. Attorney's Office. That's not included in
your motion, right?
MS. CONNORS: That's correct, Your Honor. 502 is the
demonstrative that would not go back.
THE COURT: All right. Do you understand and agree?
MR. FINLAYSON: I agree.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 313 of 359
1075
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: Okay. All right. Then they are admitted
to go back.
All right. Anything else?
MS. CONNORS: The only other thing I wanted to find
out is the stipulation. I think we had talked about you might
put one line into the jury instructions just to say that --
THE COURT: I'll do that. Okay. Anything else?
MS. CONNORS: Do you want that admitted? Do you want
us to put an exhibit sticker on the stipulation?
THE COURT: If you-all want to admit it, that's fine.
MS. CONNORS: We'll admit it as Government's Exhibit
50.
THE COURT: Okay. Any objection to that?
MR. FINLAYSON: No sir.
THE COURT: Okay. Anything else?
MS. CONNORS: I think that's it for me.
THE COURT: So we'll stick one sentence in there that
I just remind them that there are stipulations that they are
required to accept. We'll put that in right before the charge
offense, right after the one about on or about, I think, or
whatever -- maybe not on or about. There's one in there right
before it. I'll look at it.
Okay?
I want to give a shout-out to the young lady doing
all of the PowerPoints and the exhibits or the highlighting
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 314 of 359
1076
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
all the time. I've tried a lot of cases. I know that's hard
work. You're paying attention the whole time. And it's like
somebody's talking both sides and you're highlighting it.
MS. CONNORS: Judge, it's her first trial.
THE COURT: Is that right? It's your first trial.
MS. WILSON: Yes.
THE COURT: You're doing a great job. I've been
watching it the whole time.
MS. WILSON: Thank you.
THE COURT: All right. Thank you.
And y'all be thinking about what's going to happen if
they don't reach a verdict tomorrow and what's going to happen
to the young lady on the end. Okay?
(Whereupon, the proceedings were adjourned at 5:12
p.m.)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 315 of 359
1077
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
REPORTERS CERTIFICATE
I, Jana B. Colter, Official Court Reporter for the
United States District Court for the Northern District of
Georgia, with offices at Atlanta, do hereby certify:
That I reported on the Stenograph machine the
proceedings held in open court on July 24, 2025, in the matter
of United States of America v. Carl Delano Torjagbo also known
as Karl Lucius Delano, case Number 1:22-CR-00171-MLB; that
said proceedings in connection with the hearing were reduced
to typewritten form by me; and that the foregoing transcript
is a true and accurate record of the proceedings.
This the 10th day of November, 2025.
_______________________________
/s/ Jana B. Colter, FAPR, RDR, CRR, CRC
Official Court Reporter
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 316 of 359
BY MR. EVERT: [66] 767/25769/8771/9
774/18776/1777/11779/1781/11782/2
782/20783/5784/17784/23785/5785/19
786/25787/11787/17788/13788/23
789/14795/7796/20797/19799/8802/5
802/21803/12804/8805/6805/13805/21
806/13807/4807/10811/10811/23813/11
813/21815/19816/15820/13825/4825/19
828/10828/19830/4832/20833/22834/14
835/3835/10835/20835/25836/12836/17
837/3837/9837/16839/10874/3875/8
876/19881/18975/10978/21
BY MR. FINLAYSON: [17] 840/24847/3
849/13858/9865/25867/5868/6870/4
878/11879/22938/11938/19968/18984/6
986/21995/191020/1
BY MS. CONNORS: [71] 882/20885/7
885/16886/6886/19887/21888/20890/10
893/9895/16896/22897/3897/22898/5
898/16898/23899/16900/12901/5902/3
902/25904/11905/7905/23906/17908/1
909/2909/9909/25913/4913/24914/15
914/25917/17918/12918/21919/8920/9
921/10921/18922/1922/21923/4924/5
924/11924/21925/20926/11926/22928/4
928/10929/10929/18929/25932/8933/21
949/5951/15951/22953/13955/13970/16
971/11987/131040/101047/191048/17
1050/151052/91054/191063/15
BY THE COURT: [2] 810/6815/10
COURT REPORTER: [1] 995/16
COURTROOM DEPUTY: [12] 767/18
767/23805/16805/20882/13882/18933/4
933/13968/12971/5984/11048/14
COURTROOM SECURITY OFFICER:
[22] 766/20767/7790/21795/2817/14
820/1820/3821/15822/2824/22850/21
858/5910/15912/24967/23979/14982/21
983/151071/181071/211072/101073/5
JUROR: [10] 821/11821/13833/13
833/161069/51072/151073/71073/9
1073/121073/14
MARSHAL: [3] 983/4983/7983/9
MR. EVERT: [116] 767/12769/5771/7
774/12775/2775/6775/10775/16777/6
778/24781/15782/17783/3784/14784/22
785/3785/18786/13786/19787/4787/9
787/15788/11788/18788/20789/11
791/11792/21793/1793/25794/2794/4
794/18796/2797/17799/6801/24802/3
802/19803/10805/4805/18806/1806/5
806/7806/9806/25807/8810/3811/6
811/9811/22813/5813/9813/19815/4
815/8815/17816/14818/17819/21820/8
820/21820/24821/2825/1825/17828/1
828/6828/18829/22830/2831/22832/14
833/6833/9833/20834/11835/1835/9
835/19835/24836/10836/16837/2837/7
837/15839/8840/19847/1850/16850/18
850/24852/4852/18852/20853/2854/20
855/16855/21855/24856/4856/11857/19
874/1874/19875/6876/17878/7881/16
881/23882/1886/4975/8978/18979/4
MR. FINLAYSON: [127] 766/7774/16
775/8775/24786/15786/17790/16790/18
791/1791/25792/7792/11793/12793/15
793/19794/11795/25802/1803/20806/3
811/7813/7815/6817/10817/19818/5
818/21819/14822/3823/1824/8828/3
829/24831/25832/17840/22847/2851/12
852/8852/15853/20854/6856/23856/25
857/2858/2865/18867/21869/15869/20
873/22873/24874/21878/8881/25886/17
888/13888/16911/5912/5932/4938/9
938/18948/25951/12953/8956/1956/11
956/19957/1957/4957/7957/14957/17
959/11959/20960/1960/4960/8962/22
962/25963/14963/23964/1964/13964/17
964/23965/24966/14966/16966/24967/1
967/9967/12967/14967/20967/22968/1
968/4968/6970/12970/21970/24975/6
979/5979/17979/23981/21981/25982/4
982/24983/19986/14986/19987/12
1019/241040/41063/41070/51070/10
1070/121070/141071/81074/41074/10
1074/251075/14
MS. CONNORS: [148] 766/21766/23
767/6805/11818/20819/17823/5823/7
823/10824/15856/14882/5885/4885/14
886/5886/15888/11888/18890/9893/7
895/14896/21897/2897/20898/4898/14
898/21899/13900/10901/3902/2902/24
904/10905/5905/21906/16907/25908/25
909/7909/23910/9910/23911/2911/9
911/13912/4912/16912/20912/22913/3
913/22914/13914/23917/14918/10
918/19919/7920/7921/8921/17921/24
922/20923/2924/4924/9924/18925/17
926/9926/21928/3928/9929/9929/17
929/24932/2932/6932/21933/8933/11
933/20938/7949/3951/11951/14951/20
953/9955/11956/6956/9958/15958/20
959/1959/24960/7960/14961/3961/5
961/25962/5963/2963/4964/15964/21
964/25965/3965/8966/17966/23966/25
970/14970/20980/16980/18981/6981/9
981/11981/15981/18982/7982/11982/18
986/171040/61047/171048/121048/16
1050/111052/71054/171063/61063/9
1068/221069/31069/201070/201071/2
1071/111072/21072/81073/201073/25
1074/131074/221075/41075/81075/11
1075/161076/4
MS. WILSON: [2] 1076/61076/9
THE COURT: [291] 766/5766/8766/22
767/3767/9769/7774/15774/17775/5
775/7775/9775/12775/23775/25781/9
781/17781/19781/21781/25786/16
786/18786/20786/23790/17790/20
790/23791/10791/23792/1792/9792/22
793/10793/13793/17793/22794/1794/3
794/5794/12794/19795/4795/12796/1
796/3801/25802/2803/22806/4806/6
806/8807/1811/8813/8815/7817/12
817/16817/21818/7818/23819/15819/19
819/23820/2820/4820/9820/11821/1
821/4821/12821/14821/17822/4822/6
823/4823/6823/9823/11824/9824/16
824/24828/5830/1832/2832/15832/18
833/8833/11833/14833/17840/20849/10
850/17850/20850/23851/11851/23852/7
852/14852/16852/19852/24854/4854/7
854/25855/20855/23855/25856/5856/13
856/18856/24857/1857/8857/20858/3
858/7865/17865/20865/23866/23867/19
867/22867/25868/3869/13869/16869/21
873/23873/25874/18874/20874/24878/9
879/20881/15881/24882/2882/7885/6
886/18887/19888/14888/17910/6910/11
910/17911/1911/3911/7911/11911/14
912/7912/18912/21912/23913/1932/5
932/16932/19932/23933/1933/3933/6
933/9933/12933/15938/8949/2951/13
953/11955/25956/2956/5956/8956/12
956/18956/24957/3957/6957/11957/15
958/14958/19958/21959/2959/18959/21
959/25960/3960/5960/9961/1961/4
961/24962/2962/15962/24963/1963/3
963/22963/25964/11964/14964/16
964/22965/2965/5966/12966/15966/22
967/5967/11967/13967/16967/21967/25
968/2968/5970/13970/22975/7978/17
979/6979/9979/16979/19980/17981/3
981/8981/10981/13981/16981/19981/24
982/1982/5982/8982/15982/19982/23
983/1983/6983/8983/12983/17983/20
986/16986/181019/251040/51040/7
1063/71063/101068/191068/241069/8
1069/181069/211070/81070/111070/13
1070/151070/231071/31071/91071/12
1071/201071/221072/31072/91072/12
1072/161073/81073/111073/131073/15
1073/181073/221074/81074/111074/19
1074/241075/11075/71075/101075/13
1075/151075/171076/51076/71076/10
THE WITNESS: [43] 767/21781/18
781/20781/22786/22786/24787/5788/19
796/4804/7807/2810/4820/22832/19
849/11865/19865/22867/20867/24868/2
868/5870/1879/21882/16887/20932/18
932/22932/25933/2933/5933/10933/19
956/4968/15970/23971/8978/19979/8
979/24984/4995/171073/171074/3
$
$1,600 [1] 952/18
$1,660,861.01 [1] 908/24
$1,675,000 [1] 799/24
$1,677,000 [1] 936/8
$1,677,861.01 [1] 918/25
$1,980,842.80 [1] 919/5
$1,994.87 [1] 907/17
$1.6 [2] 909/3909/21
$1.6 million [1] 909/21
$10,000 [6] 900/8900/19901/12901/19
902/12908/16
$10,031 [1] 903/11
$100 [2] 865/5906/13
$100,00 [3] 901/10901/25908/11
$100,000 [15] 798/8798/14863/3897/17
899/7899/18900/1900/5900/16900/22
900/24901/19904/2935/16935/18
$105 [1] 896/9
$107 [1] 906/13
$107.10 [3] 896/12898/20906/14
$118,299.79 [1] 812/12
$12 [1] 1035/21
$120,000 [1] 936/6
$120,799.79 [1] 812/13
$125 [1] 977/16
$130,000 [4] 1034/121034/171035/8
1042/8
$150,005.13 [1] 915/19
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 317 of 359
$
$155,000 [2] 804/20936/6
$155,005.13 [1] 919/1
$17,000 [2] 903/8908/19
$177,000 [1] 936/5
$18,000 [3] 769/20769/20794/24
$183 [1] 929/21
$2 [3] 1030/51030/81030/18
$2 million [3] 1030/51030/81030/18
$2,139.36 [1] 892/21
$2,500 [2] 919/211067/7
$20,000 [2] 901/13902/12
$21,000 [2] 901/14902/12
$23,000 [1] 903/19
$24,799 [1] 903/17
$269,999 [1] 877/4
$269,999.80 [2] 877/7923/17
$3 [22] 789/4861/22861/25862/24
863/15863/18863/20897/12897/23
898/25905/3906/7930/21934/9934/21
937/22951/8952/24953/21960/5960/6
1013/2
$3 million [22] 789/4861/22861/25
862/24863/15863/18863/20897/12
897/23898/25905/3906/7930/21934/9
934/21937/22951/8952/24953/21960/5
960/61013/2
$3,049 [1] 920/5
$3,366,240.76 [3] 789/1904/17934/25
$3,500 [1] 922/10
$3.3 [2] 930/22938/2
$3.3 million [2] 930/22938/2
$3.4 [4] 861/25864/211040/251044/10
$3.4 million [4] 861/25864/211040/25
1044/10
$300 [1] 1067/10
$33,000 [1] 949/14
$332,000 [1] 936/7
$332,999.80 [1] 809/7
$4 [2] 1027/201028/1
$4 million [1] 1027/20
$4,208,888.37 [1] 907/1
$4.2 [1] 936/24
$4.2 million [1] 936/24
$40,000 [12] 871/9871/10871/14930/4
930/7930/11930/13930/14946/3946/4
946/16955/20
$45,861,255.93 [1] 837/19
$46.17 [1] 928/21
$5,000 [1] 915/15
$50 [1] 1035/23
$50,000 [6] 900/5901/11901/21901/23
902/11908/13
$500 [5] 916/15916/16929/14978/20
978/22
$500,000 [14] 915/12916/9916/17
917/19918/6919/23920/11923/11923/12
924/6924/161027/221028/91028/14
$51,000 [2] 816/6816/9
$510,000 [2] 816/3816/11
$523.77 [1] 929/16
$595,000 [1] 926/17
$6 [34] 798/22798/25906/5906/11
906/18908/22909/19909/20913/12914/8
914/10915/10916/8919/15921/23922/5
923/1923/9925/16926/8927/17927/18
927/24927/25930/17930/19931/4931/8
931/9931/11931/14935/12935/181012/3
$6 million [33] 798/22798/25906/5
906/11906/18908/22909/19909/20
913/12914/8914/10915/10916/8919/15
921/23922/5923/1923/9925/16926/8
927/17927/18927/25930/17930/19931/4
931/8931/9931/11931/14935/12935/18
1012/3
$6,266,327.86 [1] 905/14
$6,366,240.76 [1] 938/6
$6,400 [1] 903/14
$6,554,515 [1] 934/6
$6.1 [4] 935/10935/13935/19937/16
$6.1 million [3] 935/10935/13935/19
$6.5 [3] 861/201011/81012/3
$6.5 million [3] 861/201011/81012/3
$60,000 [2] 900/25923/14
$66,000 [1] 894/23
$7,000 [6] 913/15975/19975/21975/22
976/21028/25
$7,300 [2] 906/3914/7
$741,000 [1] 936/7
$8,000 [1] 1067/13
$800,000 [2] 948/6948/9
$81,000 [1] 903/24
$87,020 [1] 922/8
$9 [4] 794/24896/181045/91045/11
$9 million [4] 794/24896/181045/9
1045/11
$9,100 [1] 902/13
$9,554 [2] 801/6801/6
$9,554,425 [4] 788/5838/22839/1932/15
$9,554,515 [1] 801/6
$9.5 [5] 861/18897/5933/22936/11
1011/5
$9.5 million [5] 861/18897/5933/22
936/111011/5
$90,000 [1] 936/1
$90,100 [1] 927/7
$900,000 [2] 808/13863/2
$91,000 [2] 914/1914/4
$91,076.66 [1] 913/19
$92,520 [1] 814/8
$95,000 [1] 802/23
$98,000 [2] 919/3936/5
'
'19 [2] 837/241005/19
'21 [10] 899/7906/1906/4906/20913/15
922/7922/10928/201030/131030/15
'22 [8] 906/20915/11915/18919/22920/1
923/11923/14928/20
-
-- $50,000 [1] 901/23
-- after [2] 1050/201057/22
-- all [1] 950/20
-- and [5] 916/13937/241044/61066/20
1067/22
-- are [2] 889/201042/19
-- as [1] 871/18
-- at [2] 879/21903/23
-- broadly [1] 771/17
-- closing [1] 800/24
-- Defendant's [1] 1020/2
-- did [6] 891/1916/15918/61030/25
1033/91034/4
-- does [1] 1050/4
-- either [2] 1000/51039/19
-- for [3] 1009/241025/81052/16
-- go [1] 1045/7
-- government's [1] 1011/22
-- he [1] 977/4
-- I'm [1] 1040/13
-- if [1] 1059/6
-- in [1] 1043/12
-- is [1] 1046/11
-- it [1] 894/8
-- let's [1] 950/5
-- Michael [1] 1059/8
-- on [1] 1050/18
-- or [1] 1013/21
-- people [1] 994/23
-- reword [1] 950/2
-- right [1] 1065/17
-- shut [1] 1014/24
-- so [1] 1065/19
-- somebody [1] 973/24
-- that [3] 1063/11063/201066/22
-- that's [1] 902/16
-- the [3] 900/15901/181036/12
-- there [1] 981/11
-- to [2] 783/22842/20
-- was [3] 950/221062/171066/18
-- we [1] 937/12
-- were [2] 889/12895/3
-- when [2] 1057/201063/18
-- where [1] 1029/20
-- you [4] 988/161018/241050/23
1065/24
-- you've [1] 1052/12
-- your [1] 994/11
/
/s [1] 1077/18
0
0540 [3] 1024/111043/171048/22
1
1,300 [2] 977/22978/7
1,301 [1] 977/22
1,500 [1] 973/25
10 [6] 787/10823/13833/18910/8964/18
979/12
100 [1] 801/12
100 kilos [1] 1035/20
100,000 [1] 901/24
1006 [1] 1074/13
101 [10] 778/25781/16804/14834/12
839/9847/1847/2915/3918/18936/6
101B [1] 777/8
103 [3] 787/10884/20951/14
103A [1] 884/20
1040 [3] 778/18778/20789/2
106 [1] 1050/12
108 [1] 1011/22
10:30-ish [1] 819/16
10th [3] 828/23906/11077/14
11 [6] 850/3850/4905/6905/21913/23
1015/21
115,250.79 [1] 920/2
1199 [13] 915/13915/15915/18915/21
919/24919/24920/4923/13923/13924/7
928/8930/3930/14
11th [12] 798/21798/22827/12906/2
906/3908/21913/13915/9919/16919/22
920/18922/5
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 318 of 359
1
12 [8] 800/10808/9808/10893/25905/22
914/13968/22979/12
125 [1] 977/17
12th [11] 827/12829/16831/17841/4
858/11906/20928/12928/20928/24
1020/221031/19
12th of [1] 881/7
13 [4] 803/11906/16955/12968/22
1377 [9] 1005/51024/221024/231049/3
1049/81050/21051/71051/101052/16
13th [4] 783/9784/1785/9827/13
14 [6] 805/3805/14806/7806/8907/25
973/16
141 [1] 834/17
143 [1] 835/9
1456 [1] 763/23
14th [3] 785/10785/10923/11
15 [8] 821/3833/18910/4910/8913/9
996/22996/231050/25
15th [4] 771/22782/13809/2923/14
16 [5] 914/24973/16973/16981/14
981/14
16th [4] 779/22779/24783/8784/2
17 [6] 783/1918/20951/20987/16990/17
991/12
172 [2] 989/21995/8
17th [1] 806/16
18 [3] 775/19919/7919/9
182 [1] 989/21
1837 [1] 922/9
1855 [1] 952/13
18th [1] 915/14
19 [4] 798/7798/8837/22921/25
1900 [1] 917/8
1949 [1] 763/21
1975 [2] 990/12992/2
1979 [5] 828/17828/23990/6992/21
993/15
1985 [1] 1059/25
1997 [1] 988/11
1998 [1] 816/1
19th [7] 899/7900/5900/15900/21
901/10901/11908/13
1:22-CR-00171-MLB [2] 763/41077/10
1st [3] 889/131051/101052/21
2
2,000 [2] 964/18973/25
2/12/21 [1] 784/21
20 [8] 775/19787/19821/3920/8923/3
993/3993/41055/9
20,000 [1] 902/13
2001 [4] 988/13988/13988/14988/15
2002 [2] 1046/131049/12
2003 [1] 996/23
201 [2] 782/18810/3
2011 [1] 971/25
2013 [2] 999/251002/23
2014 [8] 808/25809/9876/22923/9
923/18926/15936/71003/15
2015 [5] 889/13890/18987/41003/15
1003/18
2016 [3] 987/8987/91003/18
2018 [14] 1004/181005/41005/18
1024/241025/181026/11049/91049/10
1049/161050/91051/101052/141052/21
1052/25
2019 [7] 894/20941/13941/20949/8
1003/221005/201035/15
2020 [57] 771/22782/4782/13809/2
834/25835/12835/13836/3836/5836/19
836/20836/25837/11837/21837/21
837/24837/24837/25866/19867/6867/18
868/11868/18869/1877/16890/12890/20
890/22891/2891/4891/11891/14892/20
892/22892/24893/1893/3893/12894/10
894/13894/18894/21894/22895/24
947/17949/13965/211021/31021/5
1021/61022/181027/41042/11043/12
1047/101050/251059/13
2021 [66] 771/13779/22779/24783/7
783/9785/10787/19788/1798/8798/21
798/22799/12800/3800/6803/14806/16
814/1816/20816/24826/9866/19867/6
867/18868/11868/20868/22877/16
889/25890/1890/4891/6891/7895/19
895/22896/1896/7896/11896/15897/11
905/14907/11916/3916/11917/5919/17
920/19922/4926/14928/12935/4935/7
935/25936/4936/10936/15946/23947/14
949/16952/12985/21024/201040/20
1041/241050/181052/251055/8
2022 [25] 769/11769/13812/3827/12
827/13829/17831/17841/4858/11881/7
907/11916/13919/10920/18921/5924/22
925/19926/141020/181020/191020/22
1030/101030/111031/191057/20
2025 [4] 763/12766/31077/81077/14
20th [3] 800/2800/6913/15
21 [3] 784/21784/21926/10
211 [1] 784/14
215-1456 [1] 763/23
21st [2] 925/19987/8
22 [5] 809/4823/18926/21981/16
1070/25
220 [2] 777/71048/11
2220 [1] 996/11
22nd [3] 903/7923/16924/22
23 [4] 768/11768/13844/14928/3
23rd [3] 903/10903/13935/7
24 [4] 763/12766/3928/161077/8
24th [1] 920/1
25 [2] 883/7929/9
25th [1] 889/25
26 [4] 902/16902/17902/18929/17
26th [6] 890/4903/16903/18904/5904/7
916/3
27 [5] 788/21788/24824/4888/21929/24
27th [3] 905/14913/18935/4
28 [4] 824/5896/1896/11949/16
28th [8] 826/13890/1895/19895/22
896/7896/14908/24946/23
29 [4] 801/8896/15956/20962/20
29th [13] 788/1803/14816/24826/9
897/8916/10917/4928/20936/10936/15
1020/161020/181020/19
2nd [1] 987/4
3
3 million [1] 938/5
3.3 [2] 938/5960/7
3.36 [1] 1027/7
3.36 million [1] 1027/8
3.4 [3] 862/3862/4863/20
3/14/21 [1] 784/21
3/29 [1] 801/8
30 [1] 910/24
300 [4] 773/20885/191005/231005/24
300A [3] 773/21774/6825/3
300B [4] 773/21774/6798/10825/17
301 [4] 773/21774/6788/12884/20
30120 [1] 802/17
30135 [2] 779/8782/22
301A [2] 773/21774/6
301B [2] 789/12897/20
301C [2] 774/6904/10
302 [2] 773/22774/6
302A [6] 773/22774/6909/1913/22920/7
922/13
302B [2] 797/18899/13
302C [1] 798/15
303 [2] 773/22774/7
30303 [1] 763/22
303A [2] 773/22774/7
304 [3] 773/22774/7884/21
305 [6] 774/22774/25775/5807/9885/1
924/18
3051 [1] 828/21
305A [3] 774/23774/24775/5
305E [1] 921/17
305F [1] 917/15
305G [1] 924/4
305I [1] 918/10
3081 [11] 779/7782/22785/1798/19
825/23999/91045/231052/161052/21
1052/231058/14
30th [1] 906/20
310 [2] 885/12885/15
311 [4] 774/3774/7885/15885/23
312 [1] 1005/23
313 [3] 774/4774/7885/23
314 [3] 886/7886/12886/16
315 [2] 774/4774/7
319.59 [1] 926/17
31st [1] 894/10
35 [1] 821/2
3rd [2] 919/17952/12
4
4/19 [2] 798/7798/8
4/27 [2] 788/21788/24
40,000 [1] 975/20
401 [6] 786/4786/7786/8786/10799/7
803/21
401A [4] 786/4786/8786/9786/10
401B [4] 786/4786/8786/9786/10
402 [5] 786/4786/8786/10786/11813/20
403 [1] 802/13
404 [3] 763/23811/21823/24
405 [1] 804/9
406 [3] 808/23810/9876/18
407 [1] 815/18
408 [1] 816/14
409 [1] 808/14
41 [4] 831/4831/23995/8995/11
417 [5] 786/4786/8786/10786/12808/14
42 [1] 874/15
43 [4] 829/12830/3980/2981/14
44 [3] 827/17828/2828/7
45 [4] 784/14911/10990/41011/14
451 [4] 801/18801/24802/2802/4
452 [4] 810/19810/21811/6811/8
453 [3] 812/20813/6813/10
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 319 of 359
4
454 [3] 814/22815/5815/7
49,900 [1] 927/11
493 [17] 780/10834/16834/23835/17
836/9837/1849/11868/25871/18872/21
877/12877/22964/17975/21006/20
1008/241060/13
4999 [1] 798/11
4th [2] 771/13922/7
5
5,000 [1] 977/11
50 [9] 834/8847/10849/12867/11867/12
867/20868/9877/111075/12
50,000 [1] 1002/18
500 [4] 977/12977/25978/1978/7
501 [16] 887/16888/12888/17888/19
898/14901/3905/5909/23913/9914/23
918/19921/24923/2926/9936/23955/12
502 [4] 932/3932/6938/181074/22
503 [2] 1052/81052/12
5040 [1] 1021/8
5104 [1] 1058/15
5114 [9] 799/15799/21801/21802/7
807/13807/20809/12813/25828/14
55 [1] 910/17
5837 [1] 784/21
5:00 [2] 1023/71023/8
5:00 or [1] 938/23
5:12 [1] 1076/15
5th [1] 816/20
6
6,000 [1] 978/24
60 [5] 834/8847/10849/12867/12877/11
600 [1] 1005/25
6010 [2] 1024/21047/8
6:00 [2] 938/231069/9
6:30 [1] 1048/19
6th [1] 922/10
7
701 [1] 963/17
702 [1] 963/17
71 [1] 780/10
72GLX [1] 816/1
73,900.41 [1] 927/13
737 [2] 989/23999/1
75 [6] 763/22991/7992/13993/16
1000/131024/2
76 [1] 816/1
76-foot [1] 926/15
77 [1] 924/19
777 [5] 1022/51022/61022/71022/14
1022/15
787 [1] 1022/15
7:00 p.m [1] 1048/19
7th [5] 915/11915/18916/13917/20
1050/18
8
80 kilos [1] 1027/19
81 [1] 781/15
810s [1] 998/2
8332 [4] 826/41053/251054/31054/6
850 [1] 936/6
8755 [11] 787/14800/20897/1934/2
947/5951/1951/8951/14952/9952/18
953/4
8:00 [1] 1023/10
8:00 p.m [1] 1023/8
8:30 [1] 938/23
8:42 [1] 1048/20
9
9.5 [1] 897/9
9/10/1979 [2] 990/6993/15
9/8/1975 [1] 992/2
9/8/75 [4] 991/7992/13993/161024/2
9/8/75 on [1] 992/15
90 [1] 1/4
90,000 [1] 936/5
91 [1] 902/13
940 [4] 837/11868/221008/191061/16
940s [1] 1055/16
941 [8] 834/19835/12836/5836/19
868/18868/221061/171064/3
941s [8] 868/161008/191054/181054/21
1054/231054/241054/251055/16
9498 [1] 798/9
9499 [41] 788/17798/11798/12798/23
826/16896/10897/16898/3898/7898/11
898/19899/1899/8899/22904/15904/21
904/22905/13905/16906/4906/6906/10
906/11908/22913/12915/10922/6928/18
930/19930/21931/9934/16934/21935/1
935/10937/14937/15937/19937/22
946/25947/2
9814 [16] 825/11825/13890/16900/6
900/8901/11901/12901/13901/15902/7
902/22903/3908/14908/15908/15908/18
9822 [3] 825/13890/17929/20
9849 [58] 798/5825/13890/17897/18
899/8899/9899/22900/1900/2901/10
901/11906/2906/4906/22906/23906/25
907/12908/14908/15908/22913/13
913/14913/18914/6914/7915/10915/11
916/17916/23917/4918/7919/16919/16
919/22922/6922/7923/10923/10923/23
924/7924/16927/7927/10927/12927/14
929/12930/10930/17935/10935/20936/2
936/2936/2936/4936/24937/19961/21
961/22
9:00 [2] 938/231023/10
9:58 [1] 829/17
9th [1] 897/11
A
a.m [2] 829/171048/21
abetting [2] 823/191071/1
abiding [1] 1073/3
ability [1] 858/20
able [37] 773/9776/23776/24777/20
778/13782/8783/9783/13789/5801/14
839/18842/2842/4859/12860/9874/19
890/6893/2894/14895/3901/6901/8
931/1931/13937/10937/14950/11952/16
952/25962/10966/201001/151036/3
1053/231054/11055/121055/13
about [248] 766/9766/10767/5768/21
768/23769/19769/21769/24770/24
771/20779/25781/2781/19782/5782/9
789/15789/24791/12793/15797/16800/7
801/12808/12808/13816/22817/1817/2
819/24820/8820/19821/2821/8823/13
823/16823/18823/21823/21823/22
823/23823/23824/6824/8824/12826/19
826/24830/5839/18841/16843/9843/22
844/10846/19849/14851/6851/18851/19
852/17853/3853/5853/20853/24853/25
854/6854/14855/2855/7856/7857/13
858/10861/16862/2862/16863/2863/3
863/8863/11865/23866/25867/11867/20
868/9868/16869/2869/18870/12871/7
872/21872/25873/19874/4874/7875/10
878/20879/1881/21883/3883/7883/9
888/14890/6894/20898/25910/13910/13
910/17911/16914/7916/23925/21930/17
932/9935/12942/2945/10947/8947/15
948/9949/6950/16953/21954/1954/8
955/14959/7960/12960/13961/9961/19
961/21962/4962/12964/2964/7964/8
965/25966/2966/6966/21967/9968/22
972/15973/14976/25977/15977/16
978/11978/24979/19980/1980/19982/19
986/24987/14987/16990/7991/13992/25
993/25994/9995/12996/14996/23996/23
997/17998/20998/24999/16999/17
1002/141002/221003/41003/171004/25
1005/191005/231005/241006/231007/7
1011/121012/221015/121016/191017/1
1018/41021/11021/221024/151027/6
1027/71027/101027/191028/131029/9
1029/121030/11031/151032/151032/16
1032/181033/111034/131035/20
1035/231035/241036/101036/19
1039/201041/121045/171046/21046/6
1051/251052/11053/211054/141055/8
1055/141057/181058/121059/31060/21
1064/151064/231066/131067/71067/8
1067/81067/91069/21069/91069/14
1070/21070/31070/211071/41071/10
1072/231073/11073/21073/191073/22
1073/241074/31075/51075/201075/20
1075/211076/11
above [9] 784/16789/4839/14847/24
925/181034/141035/71042/71042/8
abs [5] 818/18827/1869/12870/1870/9
absolutely [7] 849/21860/15863/17
870/7888/25894/9923/24
Abu [4] 1027/211028/61028/71028/8
abusive [1] 993/20
accept [2] 775/131075/19
accepted [2] 963/101021/6
access [8] 823/7883/24937/10993/24
1022/221057/21057/111057/13
accessed [2] 1023/251058/6
accidentally [3] 1024/41047/241048/1
accomplish [1] 958/17
according [6] 771/21872/13975/23
977/241045/21061/14
account [247] 773/10773/13773/15
784/20784/25787/12787/13787/22
788/15788/16789/7789/9789/9789/24
790/1790/2790/10791/16791/16794/21
794/21796/6796/6796/8796/9796/10
796/14796/15796/16796/16796/17797/6
797/7797/8798/3798/4798/4798/9
798/12798/16798/17798/18798/23
798/23799/3800/18800/19801/5801/11
801/12806/23807/3807/13808/1816/8
825/6825/11825/12825/21825/22826/6
826/10826/15844/11844/11845/22
845/25846/1846/1846/5846/13861/23
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 320 of 359
A
account... [175] 862/6863/25864/12
864/13864/21864/23865/5865/8865/9
876/6885/2889/7889/7889/8889/22
890/2890/3890/4890/15890/16892/8
892/11893/3893/16893/19893/19894/14
896/8896/10897/1897/6897/10897/12
897/16897/17898/2898/3898/18898/19
899/3899/9899/11899/12899/21900/6
900/9901/18902/6902/22903/3903/5
903/23904/14904/20904/22904/25905/2
905/9905/11905/13906/2906/4906/22
906/23906/24907/5907/15907/18908/18
909/11909/14909/16909/21914/5914/6
914/7914/19915/13915/15915/17915/21
915/24916/5917/7917/22917/22917/25
918/16919/17919/20919/22919/23
919/24920/3920/3920/15921/11921/14
922/7922/9922/22923/12923/13923/16
923/20923/20924/2924/2924/13925/3
925/12927/4927/7927/22928/7928/14
928/17928/18928/19928/22929/11
929/12929/19929/20930/2930/3930/10
930/12930/14930/21930/25931/8934/1
934/6934/24935/1935/10937/20940/15
940/25941/21944/21946/24946/25947/1
947/5947/9948/4948/13949/7949/20
950/8950/10950/13950/13951/4951/5
951/16952/2952/7952/9952/15952/19
954/11954/19954/23954/24955/1955/1
955/3955/3955/5961/111013/31030/8
accountant [3] 768/20781/91055/21
accounting [5] 768/21895/121008/18
1021/201055/25
accounts [104] 772/9772/9772/17773/7
773/13773/16773/18774/20790/11795/9
795/11797/4797/4797/5797/9797/13
797/22797/24798/1808/2816/7817/5
825/14825/14840/8840/17844/21845/24
846/8865/7875/21880/22884/11884/12
884/12884/24885/9889/10889/14889/15
889/15889/16889/17889/20889/21
889/24890/5890/7890/13890/14890/18
891/1891/5892/14892/20892/25893/13
893/21894/11894/18894/22894/23
895/19895/22896/4896/5896/14897/18
898/11900/3907/5907/7907/21916/2
917/2926/14926/25928/12929/6936/12
936/13936/16936/17936/21937/1937/3
940/23941/5941/10944/12945/4945/9
945/23947/11948/1949/7950/12950/14
953/7953/14953/15954/9961/231028/10
accruing [1] 907/15
accurate [9] 814/71055/141056/23
1056/241057/11063/11063/31063/24
1077/13
accurately [8] 801/21811/3812/24815/1
831/16888/8931/21986/12
acknowledged [1] 780/9
acquittal [1] 956/20
acre [1] 1005/22
acres [1] 1003/17
act [1] 819/2
ACTION [1] 763/4
actions [1] 880/6
actively [2] 768/6768/8
activities [5] 883/6886/211003/12
1034/51034/6
activity [4] 840/8958/9958/101003/1
actor [5] 780/17780/18780/19781/10
1056/5
actual [6] 778/10778/13843/1899/19
940/231002/24
actually [90] 770/8792/14838/17851/2
853/7863/13864/15870/24871/13873/20
874/12879/13883/7885/21890/13890/21
892/7894/20896/3896/4896/24897/7
897/9897/16899/19901/14903/6906/2
906/19908/22913/14917/2918/15918/16
918/17922/9927/7927/10930/9932/16
933/25934/1934/5934/14935/25936/2
936/4937/10937/17940/21942/12947/10
952/16955/18965/8965/20975/19982/12
985/2991/15996/2997/14997/25998/17
1002/101003/211005/141005/14
1006/151008/201015/31016/61019/9
1021/51025/131027/41028/171028/19
1029/151031/251032/111034/15
1035/151035/201042/121054/251056/1
1058/191060/231062/18
Acworth [1] 804/15
add [1] 874/14
added [3] 894/21947/22947/23
addition [2] 780/8787/16
additional [7] 797/13875/21891/13
892/22927/8981/111070/14
additions [3] 798/6801/7899/15
address [46] 770/13777/10777/16
777/24778/7778/8778/14778/19779/5
779/7779/10782/21782/23782/25783/15
783/17785/1798/13798/19799/14807/13
807/20807/21812/6813/25825/24828/13
828/22918/18959/22996/10996/14997/1
997/5997/61046/211047/21047/11
1052/141052/231053/101053/16
1059/211059/211059/241059/25
addressed [1] 1052/21
addresses [8] 776/24777/1777/2777/13
777/19778/2778/5843/2
adjourned [1] 1076/15
adjust [1] 857/22
adjustment [1] 931/24
administered [1] 829/15
administration [3] 776/6787/21787/23
Administrator [1] 763/20
admit [20] 766/24774/12774/14775/2
775/4801/24806/2811/6813/5815/4
828/1829/22831/22885/22886/15888/11
932/21018/241075/101075/11
admitted [26] 774/17775/9786/18802/2
805/19806/4811/8813/8815/7828/5
830/1832/2839/3885/5885/15886/3
886/18888/17932/5986/181051/7
1051/221074/141074/151075/11075/8
Adrienne [4] 882/5882/9882/161074/2
advance [1] 1042/20
adverse [1] 1003/13
advertising [1] 1016/5
advice [2] 829/151038/3
advise [2] 829/2973/9
advised [1] 1039/4
advisor [1] 1008/9
Aero [1] 994/16
afar [1] 1018/17
affirmative [1] 1074/17
affirms [1] 867/18
afraid [2] 875/12993/21
Africa [3] 839/7847/10965/22
after [100] 1/7766/11766/12768/23
771/23782/12782/16785/14800/7803/9
803/15806/22810/20811/2816/12816/21
816/23819/21823/25824/1824/5824/17
826/13828/24830/20840/3851/21853/5
874/9878/25880/2881/7881/10897/5
897/13898/25900/1900/21901/14902/18
904/2904/7905/15905/19906/18917/4
917/16920/19928/12929/1929/4929/6
934/16935/18936/10936/14936/15
936/15939/12939/14939/15941/4943/6
974/14974/15981/14989/12994/4994/13
996/23997/7997/9997/14998/201001/23
1002/31004/191011/81013/11013/18
1020/231024/191028/231030/181031/8
1048/61049/71049/121050/201052/17
1057/141057/221057/231058/14
1061/231067/141067/151068/20
1071/141075/20
aftermath [1] 857/6
afternoon [6] 938/12938/13967/17
975/11975/12979/10
afterwards [1] 821/6
again [46] 773/11774/4775/12779/24
780/6782/15785/12786/9789/20798/1
803/18803/22815/13817/4820/6847/20
859/3866/23867/12875/2880/11890/18
906/23908/13908/14909/23910/14915/9
919/15920/4922/5922/17924/12925/10
928/22932/11942/5953/8961/8961/16
976/71021/91047/251063/81063/12
1069/2
age [6] 1016/181018/131018/14
1018/161018/181018/20
agencies [2] 776/3776/11
agent [28] 768/2768/4768/10768/10
768/24769/10776/7776/8790/5791/6
829/19830/13830/23830/25832/23
832/23833/2848/19854/9855/18858/10
1032/231032/241043/141051/24
1051/241056/101074/1
Agent Caruana [1] 1043/14
agent's [1] 792/16
agents [8] 832/24849/25858/25859/1
859/2859/7879/6879/25
ages [1] 970/6
ago [6] 849/19849/23993/3993/4996/22
996/23
agree [8] 775/22828/24829/5856/24
981/191060/21074/241074/25
agreed [10] 775/12775/14775/23775/24
829/6829/7879/151022/21022/21028/3
agreement [7] 800/2812/22813/23
815/21825/7825/22829/8
agreements [1] 813/1
agrees [1] 1022/20
Ah [1] 1039/1
ahead [20] 775/15775/25796/3804/6
820/12824/25832/18858/7858/8875/5
875/6885/22888/19913/2917/14922/12
934/31047/251073/81073/13
AI [1] 1/13
aided [1] 763/18
aiding [2] 823/191070/25
air [7] 831/2859/18859/18994/16994/19
994/211024/14
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 321 of 359
A
air-conditioned [1] 859/18
air-conditioner [1] 859/18
air-conditioning [1] 831/2
aircrafts [1] 989/20
Airlines [11] 998/4998/7998/12998/21
998/22998/24999/11010/111022/12
1022/131022/16
airplanes [6] 988/25988/25989/1
1004/101055/211060/19
airport [2] 988/23988/24
Akepene [1] 984/21
Akpene [2] 984/15984/20
Akyem [1] 972/19
alert [3] 1024/171024/171025/21
all [295] 766/5766/6766/8766/19767/7
767/9767/11769/21774/8774/10775/1
775/7775/9775/16776/13780/9781/8
783/15783/16785/16786/18786/19
786/23787/2787/5790/21793/7794/12
795/1795/2795/6795/12796/3799/22
802/12804/3806/12808/12811/8811/20
813/18814/6817/3817/8817/14818/24
819/10819/15820/3820/11820/15820/16
821/14821/15821/20822/1822/2822/4
822/23823/4823/13824/14824/20824/21
824/22824/24827/2830/5833/6835/6
835/18835/23836/15837/6837/17839/13
843/18846/14847/2847/5847/10847/23
848/8848/10849/12849/15850/21850/25
851/13853/7854/1854/24855/8857/8
857/12857/20857/22858/5861/6861/15
862/8862/12862/14862/16863/13868/3
870/5872/21874/11875/5875/9880/7
882/2885/5887/12887/25888/8888/17
889/5889/12891/18892/18894/11894/11
894/22894/23895/18895/22901/2902/11
903/4904/1906/19910/12910/15911/11
911/20912/2912/13912/15912/24913/1
918/23926/13926/24927/3927/14928/6
928/19929/1929/6930/10931/4933/17
933/22935/17937/3938/7939/12943/15
943/19944/2944/11945/4945/11947/11
947/19947/19947/22947/23947/24
948/25950/14950/20951/16956/2956/5
956/14956/21957/9958/13959/5959/13
959/22961/21961/22962/16962/19
962/19965/14967/3967/21967/23970/5
970/12973/15974/2974/7974/18974/25
975/6975/24978/4979/9979/12979/13
979/14982/19982/21982/23983/14
983/15983/17984/9984/25985/18990/7
990/10991/16992/14992/18993/24
1001/21002/231003/31005/101006/4
1006/51008/21008/181008/221009/4
1009/191016/11016/81017/71018/21
1021/191023/151023/181023/20
1023/221027/161028/181028/19
1029/211032/31032/51035/31035/5
1037/201040/51040/81040/111043/25
1045/171048/181049/41049/41055/12
1055/251056/221058/81058/121058/15
1060/121061/121062/61062/151063/16
1063/201063/241064/41067/111069/13
1069/201069/251070/11071/131071/14
1072/91072/101073/11073/51073/13
1073/151073/181074/81074/241075/1
1075/31075/101075/251076/11076/10
allege [1] 1043/4
alleged [2] 776/15795/22
allow [4] 803/22803/23854/10981/1
allowed [4] 792/18838/5857/25960/25
allowing [1] 795/14
allows [1] 988/24
alluded [1] 844/15
almost [3] 927/5947/14991/1
alone [2] 933/18978/2
along [5] 780/11780/19870/24956/16
962/17
Alpharetta [1] 799/18
already [31] 771/8777/9789/12791/4
802/13803/11804/10808/24811/21
813/20872/19880/8896/13898/24905/2
908/12913/6929/3929/4949/18982/13
1012/201012/211014/121020/41023/13
1027/11052/181065/191066/61067/14
also [41] 763/6774/19775/2775/10
775/21776/22783/19793/9808/10831/19
858/23871/15877/15877/18884/24885/1
885/18886/1886/20887/4891/8892/2
893/18895/20899/23903/13908/22
919/10930/7937/1941/25944/23960/1
974/6987/6996/231001/81036/61064/6
1065/11077/9
alternate [1] 823/17
although [2] 766/16961/10
altogether [2] 894/11062/6
always [2] 985/151043/14
am [16] 768/7768/7769/2771/5771/16
779/14787/6817/22883/1883/11883/12
908/4915/41018/31025/101058/17
amalgam [2] 974/15974/16
AMERICA [26] 763/3774/20775/1
775/18807/17807/19884/9885/2890/2
915/13915/14915/17915/21919/23
919/24920/3922/22923/12923/13923/19
928/7930/3940/13944/5950/121077/9
American [3] 955/201034/161034/16
Ameritruck [2] 927/6927/11
amongst [1] 843/17
amount [41] 780/5780/7788/5801/10
812/11816/10838/14838/18838/19
838/20849/25858/25860/10892/7892/21
893/15901/18906/4906/25907/6908/24
913/14915/12915/18918/2918/25918/25
919/1919/4919/20920/1920/5923/17
926/16926/17935/23958/17960/10
1027/181029/41034/24
Anabel [2] 1001/51001/21
analogy [1] 793/5
analysis [4] 839/23839/25890/23954/8
analyst [1] 942/23
analyze [3] 940/6940/15941/1
analyzed [1] 940/9
Andrea [21] 1004/31006/91006/10
1006/111008/121008/131009/21021/13
1021/141021/151021/191022/20
1025/131025/191045/181047/20
1054/251055/31060/171060/181061/18
Andrea's [1] 1045/20
angle [1] 811/18
animals [1] 1003/12
announced [1] 859/9
another [43] 773/14780/17786/5789/4
796/7797/7797/9797/14802/15804/11
805/15811/25811/25813/23825/21
829/19830/12830/22832/23835/12836/5
836/19843/8848/21885/18899/3901/13
901/14908/15910/7920/4923/10927/11
927/12934/23955/1995/121004/61014/8
1014/141025/81037/71053/21
answer [7] 803/24830/16839/15849/10
980/131011/181057/17
answered [1] 867/11
answering [3] 865/17980/71023/6
anticipate [2] 911/3911/9
any [143] 1/9766/13766/17767/10
768/18771/19774/15775/7780/13783/19
784/9786/16789/23795/24801/25808/6
808/20817/9820/16820/22824/6826/22
827/14832/15834/1840/16840/16842/7
843/15855/12856/1857/10859/14861/14
864/6865/8865/9870/14872/7872/15
873/25874/20876/8876/10876/11877/21
880/21881/19883/5883/5883/9883/17
884/21886/20888/23891/1891/20893/3
893/18893/20894/17895/3895/5895/6
903/23907/5916/5916/10916/23923/25
934/18934/18936/11936/12936/16
936/20936/20940/15940/23940/25941/4
942/12942/23945/14946/17946/17949/2
949/6949/20949/23950/7951/7953/7
953/15953/17953/25955/8958/22960/23
963/11966/21969/3970/13975/7986/16
993/5994/31000/31000/211001/13
1002/251002/251003/131007/241008/9
1017/201025/31027/31028/251029/1
1030/211030/251033/91033/231036/15
1041/81042/91042/121044/231044/24
1046/21051/11057/61057/111058/6
1059/141060/191062/111062/12
1062/121070/31070/31075/13
anybody [4] 823/221017/201045/20
1070/2
anyone [1] 1046/3
anything [61] 766/15769/24770/24
779/23779/25782/5789/24795/18824/10
826/24828/4834/1838/13838/21838/25
851/19862/21870/12876/14877/21
881/15888/4912/16917/4923/25934/15
942/18946/16951/3955/25958/2980/3
980/22980/24993/13993/141003/5
1010/231010/231020/121024/91026/23
1033/51034/141039/241040/31041/18
1051/121052/11055/161059/151062/10
1064/91064/151064/161064/221071/9
1073/181075/31075/71075/15
anyway [3] 857/3964/21062/7
anywhere [6] 907/6953/20964/18981/5
1034/121034/17
Apache [1] 998/2
apart [5] 817/7820/14820/14840/15
1018/17
apartment [2] 996/11996/13
apiece [1] 1067/10
apologies [1] 836/11
apologize [4] 819/14852/8885/21
937/20
app [1] 1023/5
apparently [1] 1009/6
appeal [1] 980/10
appear [5] 809/21831/19891/17895/6
962/6
APPEARANCES [1] 763/24
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 322 of 359
A
appeared [4] 811/4812/25815/2895/3
appears [3] 921/211054/81056/6
apples [3] 1068/11068/11068/1
applicant [1] 772/6
applicant's [5] 796/14839/14847/5
847/241064/19
application [44] 777/17779/3779/22
779/25780/1780/2780/4780/5780/8
780/12782/6782/25783/8788/8808/21
809/13809/16826/12834/9834/17835/7
838/11838/21838/25890/21958/25959/2
992/141007/111007/231051/31056/18
1061/201061/251062/41062/71062/8
1063/201064/81064/91064/111064/12
1064/141064/25
applied [11] 778/20806/18993/1998/5
1008/11008/31009/221060/251064/21
1065/71065/7
apply [9] 991/201006/251007/10
1019/131019/171027/171051/151062/3
1064/1
applying [5] 796/23992/121007/3
1007/41035/8
appointment [2] 990/16991/1
appreciate [6] 767/6786/24857/19
882/2912/14979/7
approach [1] 1019/24
approached [1] 833/2
appropriate [2] 819/3874/22
approve [2] 1011/41011/4
approved [1] 1011/8
approximate [1] 935/2
approximately [17] 808/10829/17834/8
844/14851/6903/17915/24917/1917/8
936/9936/24949/13973/19978/19978/23
1002/221027/19
April [32] 800/2800/6809/2816/20
835/13897/11899/6900/4900/15900/21
902/16902/17902/18902/18903/7903/16
904/5904/7905/14906/20907/11908/13
923/11923/14923/16924/22925/19
928/20935/4935/71030/151061/3
April 15th [1] 809/2
April 19th [1] 900/15
April 20th [2] 800/2800/6
April 21st [1] 925/19
April 22nd [1] 924/22
April 26 [3] 902/16902/17902/18
April 29th [1] 928/20
April 30th [1] 906/20
April 5th [1] 816/20
AR15s [2] 880/141032/7
AR16s [1] 878/20
Arab [1] 999/5
are [180] 1/8768/2768/6768/25771/3
771/14773/23774/8774/10774/12774/17
775/1775/2775/9777/9777/18777/19
777/23778/2779/12780/9780/14785/6
785/14785/16786/13786/21787/5792/17
792/17794/8794/17797/1801/1803/18
805/16808/16810/25815/23821/4821/23
823/15823/21825/14825/16827/21
830/16832/9833/17840/25841/23846/19
850/15850/15851/23857/24858/19
865/17874/22876/1879/16883/14884/19
886/10886/12886/14887/1887/13889/14
889/16889/20889/21891/8892/12892/12
900/1900/22902/16904/1904/4908/2
910/2912/16915/2916/4927/3928/16
935/22936/12938/5938/14938/15939/3
939/5942/14944/9947/14948/20949/12
951/25960/4960/8961/9961/14962/6
962/9962/12964/11964/19965/6965/10
967/7967/7968/19970/8970/10971/14
971/22972/13972/24972/25973/1973/1
973/14973/15974/3974/3974/19974/19
974/24974/25975/17978/5984/7986/6
986/18989/5990/3993/23998/8999/14
1001/81002/221004/251014/181016/23
1016/231020/41020/81020/91020/9
1033/181034/221037/101038/41040/7
1042/191042/191042/251043/11043/6
1043/201048/101053/91055/151056/7
1057/181058/181058/191058/221059/3
1061/81063/121070/41072/161072/22
1073/91075/11075/181075/18
area [10] 769/17770/17771/4784/3
785/15785/15814/19829/21973/22974/5
aren't [1] 947/15
arena [1] 852/16
argue [1] 959/15
arguing [1] 965/25
argument [5] 959/8959/10962/51017/7
1070/6
arguments [3] 822/12824/51072/5
Army [3] 997/15997/17997/25
around [18] 766/10769/13793/3819/16
827/13930/6995/241000/161003/22
1004/171004/181012/251013/11023/7
1023/101030/71030/151032/4
arrest [17] 814/14827/22829/16830/21
850/1850/7850/25851/1858/19859/8
860/14874/5874/8879/211031/10
1032/251033/10
arrested [23] 827/3827/5827/6827/10
827/11827/14827/23828/24829/2841/4
849/15851/21858/13881/101020/22
1020/241030/71030/81031/151031/24
1057/181057/201057/22
arrow [3] 933/10934/4934/23
arrows [3] 935/21935/21935/22
art [1] 966/24
article [2] 977/141014/18
as [182] 763/6767/16768/23769/1771/1
772/25774/25775/4775/13775/18775/21
776/17779/5780/1780/21782/24782/24
786/3789/22790/5791/2794/20797/9
799/3799/4800/13800/14800/22801/18
801/21804/17805/3807/23809/10811/4
812/17812/25813/3813/24814/16815/1
815/23818/10820/23823/16823/16824/4
825/12825/23827/1827/3829/20830/22
830/22831/17831/22833/1833/5835/6
843/23846/16852/16853/17858/23
858/24859/7860/8860/14860/14870/21
871/15871/18873/17875/18876/15
876/15877/11882/11883/10883/14
883/16883/22883/25886/20887/2887/2
887/8887/8890/22890/22891/14895/19
895/19895/22897/8897/15897/15904/24
907/11907/20907/20908/3915/5917/2
917/2919/19923/14925/9927/5929/2
929/2930/11930/22930/22934/8948/1
957/20957/21957/22958/4958/6959/22
960/14962/2962/13962/13963/7963/15
963/16965/4965/10965/22966/9967/2
967/14968/10969/7971/3973/2982/16
983/24986/4989/7990/12994/4995/14
995/15998/11008/191010/101010/12
1012/251012/251013/111015/41015/6
1015/91021/211021/241023/231023/23
1023/241023/241033/251033/251034/7
1038/41039/51042/221044/171047/2
1047/21047/21049/31054/81072/17
1072/171074/11074/11074/141075/11
1077/10
Ashanti [4] 1000/91000/111003/15
1005/22
aside [1] 936/19
ask [40] 793/22793/23793/23795/4
817/17818/2818/16819/7833/11838/4
838/6841/2847/11849/14851/5851/11
854/14854/25862/11865/23876/11
877/18904/4939/18940/6958/12969/9
969/11979/24984/9986/5999/171009/2
1026/41058/201059/61059/191063/13
1071/81073/7
asked [43] 792/23841/23849/14851/10
852/5866/2866/4866/19867/6867/23
871/7874/4874/12876/8876/20876/23
877/8877/8877/15877/15939/21949/6
955/14980/2992/181008/201009/4
1012/161012/161026/51026/51026/8
1027/161027/201027/201028/20
1040/221040/251041/141051/18
1059/111060/221071/3
asking [9] 826/18833/3843/11851/18
866/9866/17870/22956/20976/3
assault [1] 850/14
assessment [5] 1003/21003/101003/16
1003/191035/19
asset [3] 1038/41039/11039/2
assets [3] 808/6864/61039/5
assist [1] 831/20
assistant [6] 1004/11004/21005/10
1005/111021/151045/17
assisted [1] 776/7
associated [10] 776/24777/13777/16
782/21944/24946/8949/211049/24
1051/81051/22
associating [1] 843/15
assume [1] 860/13
assumed [1] 1026/6
Astondoa [1] 816/1
ATLANTA [17] 763/2763/22766/3768/5
784/3785/9785/12793/2810/11812/6
812/18913/15913/19923/14923/17925/1
1077/6
ATM [1] 891/25
attached [7] 1/5780/2780/3992/1992/17
992/201039/19
attaching [1] 1/8
attempt [1] 951/7
attempted [2] 953/2991/3
attended [1] 988/8
attention [1] 1076/2
attesting [2] 1063/21063/3
attorney [3] 764/2881/9881/9
Attorney's [6] 882/23882/24883/4
883/17938/211074/20
attorneys [2] 883/19940/4
audibly [1] 831/7
audio [10] 823/8823/9831/7831/8
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 323 of 359
A
audio... [6] 831/10831/22833/5850/25
851/7981/24
auditing [1] 883/6
auditor [6] 883/1883/7883/10883/14
883/16939/3
August [11] 806/16836/3890/4916/1
916/3919/17922/7922/101020/16
1020/181020/19
August 17th [1] 806/16
authenticity [4] 774/13775/3786/14
805/4
authoritatively [1] 932/23
authorization [1] 993/12
auto [6] 884/3886/1886/2886/13894/3
903/17
automatic [2] 850/12850/15
automatically [3] 1034/171049/7
1051/15
Autos [1] 810/11
available [6] 801/1894/18895/13937/10
1013/81013/12
Aventador [2] 808/25809/9
aviation [5] 988/19988/20988/23995/13
997/13
avoid [1] 885/21
aware [3] 904/4920/211021/22
awareness [1] 953/25
away [3] 860/1910/141000/16
awhile [2] 1035/161059/19
B
bachelor's [1] 972/9
back [104] 767/4769/11780/25784/22
788/18788/20794/13802/24810/9819/5
821/8821/18824/9828/18830/24830/24
830/25832/5833/12841/3841/3841/24
842/18842/22843/18846/22847/20
849/15849/18854/11857/16858/3860/16
861/20865/20866/2867/4867/12871/10
875/3891/23892/2892/17898/14900/6
900/22901/3905/5911/16912/21914/23
916/1918/19926/9933/16934/5935/15
947/3952/24960/11970/1970/6978/13
979/20980/11980/19981/16982/19985/9
991/14998/1999/251001/41010/11011/2
1011/91011/131012/21012/191014/7
1014/141018/211019/71019/201023/10
1024/71025/131029/31030/151037/24
1041/31041/71043/81045/71059/18
1063/111063/241063/251069/81069/13
1074/71074/71074/231075/2
background [5] 972/3973/10987/14
993/171038/9
backtrack [4] 913/7954/141019/9
1058/8
bad [1] 857/6
bait [2] 852/12856/2
bakery [1] 1068/8
balance [26] 801/4801/4875/25876/1
876/3876/3894/14894/22896/7896/11
898/17898/20900/11900/13900/15
900/18900/24902/8902/13902/14903/24
905/11905/13906/2924/231020/13
balances [2] 895/21896/2
ballpark [6] 863/14863/15866/14866/17
877/9877/11
bank [169] 768/15772/9773/7773/9
773/18774/10774/20775/1775/17775/17
775/17780/12783/17783/25788/17
788/19792/24796/10796/17796/19
797/23798/1798/4806/23807/3807/13
807/15807/17807/18808/2816/7825/6
825/7825/21840/8840/17840/18844/10
844/11844/24844/25845/6845/9845/10
845/12845/18861/18865/4865/11873/17
880/22883/17884/3884/5884/9884/9
884/10884/19885/2887/11888/3889/5
889/6890/2891/1891/3891/18891/20
891/21892/7892/8892/25894/1894/1
895/20896/6896/9896/10896/19896/24
897/5899/20903/11903/12903/19903/20
904/22904/25905/2909/10914/16914/18
915/13915/14915/17915/21916/2916/5
917/22917/22917/23917/24918/1918/15
919/20919/23919/24920/1920/3922/22
923/12923/13923/19924/1924/2925/3
925/4928/7930/3934/6936/13936/16
936/21940/9940/10940/11940/13940/15
940/23940/25941/5941/10941/14941/16
941/17941/21941/24944/5945/17945/23
946/15948/1948/12948/13949/7949/21
950/8950/9950/12952/2953/15953/17
956/23958/19958/211011/41019/6
1019/121019/201020/61020/101020/14
1027/221028/71028/101030/191050/20
1052/31060/24
bank's [1] 924/13
bankers [1] 873/19
banking [5] 773/6876/9876/10891/25
899/24
banks [3] 884/6944/2945/19
base [4] 994/16994/211024/31047/1
based [36] 770/1770/5770/9770/9780/7
783/11783/14783/24788/6789/2791/19
798/25801/20838/10838/14838/16
838/19838/23839/1840/2840/7848/10
865/11873/15958/12969/21999/4
1004/101007/81007/81009/51042/25
1044/131044/141044/211063/1
basically [8] 827/7889/5894/3926/17
1002/191015/91017/111027/25
basing [1] 942/6
Basis [1] 790/17
BBC [1] 977/14
be [209] 1/21/3766/5766/16767/9
768/19770/3770/25771/11771/21772/13
772/22772/23773/21778/4781/21784/15
786/5789/21790/23792/18795/6796/14
796/15796/16796/18796/18800/25
803/24805/7805/12806/17809/2810/19
814/3814/8816/4817/16817/24818/1
818/18818/23818/23819/1819/2819/17
820/5820/11820/21820/24821/8821/17
822/6822/19823/2823/3823/17823/21
824/10824/17824/24827/18828/4831/24
834/1841/16846/7846/9846/9846/10
846/10846/15848/10849/4849/5850/3
850/4850/4850/18851/9853/14856/11
856/16858/7861/2867/14869/5872/7
873/11873/17874/16876/12879/25880/2
881/24882/18885/19888/5888/24890/16
891/24892/7894/3894/6895/4895/9
895/21901/6901/8901/23901/24901/25
907/15907/16911/8911/9911/14912/1
912/7913/1913/12914/19921/21921/23
924/12928/19931/1931/5931/13936/1
937/2938/6951/4961/14962/7962/8
962/10965/3965/9965/11965/18966/20
967/12967/14967/25970/2970/22974/22
975/13975/15975/16975/17975/22
976/18977/22978/1978/7978/7981/22
982/16982/19983/17984/1989/20993/16
1001/151007/131009/51010/181012/13
1013/81013/121013/141013/151014/6
1014/171018/161018/161024/20
1025/251033/11033/251035/61037/22
1042/111042/191043/191050/91053/23
1058/181060/131060/191061/91061/10
1061/131063/11064/101064/111064/17
1064/201067/11069/181070/221071/16
1071/161072/121073/151074/14
1076/11
beat [1] 857/3
became [7] 844/5844/8987/24987/24
988/1989/41015/13
became -- it [1] 1015/13
because [138] 770/4774/4776/16
778/18789/20791/20792/3792/9793/19
796/12805/18808/18814/5816/12818/10
819/1843/17845/20846/14851/18852/1
852/18852/21853/10854/21855/7856/8
857/4858/18859/3859/11860/21863/24
864/3864/12865/14871/9885/22887/13
891/5892/17910/18910/23911/15912/11
931/5931/7940/18941/15952/22958/3
960/24961/10963/5963/20964/4965/9
965/18977/24980/9982/1985/9985/18
991/3991/8991/15992/4993/231001/10
1001/111001/131001/151005/10
1007/141008/211010/221012/20
1012/241013/11015/71016/231017/17
1019/71020/221021/191022/121023/12
1024/31024/91024/131024/181024/18
1025/111025/201025/231026/20
1027/161031/71032/11033/151034/19
1035/71035/141036/11038/161041/10
1041/131041/221042/71042/81042/10
1042/191045/211046/231047/111048/4
1048/251049/21049/41049/61049/19
1053/71053/121053/251055/201056/5
1058/41061/21061/131061/241062/10
1064/41064/71066/101068/21069/2
1070/161070/24
become [3] 768/24793/18989/3
becomes [5] 793/161019/141065/8
1068/121074/16
been [82] 767/15768/10770/19771/20
786/3789/25791/1799/3800/21801/18
805/2805/19820/19826/11839/18844/13
845/22850/3865/2871/3879/10882/10
883/2883/7883/24884/15885/5885/15
887/7890/18894/8894/14903/24909/20
913/16916/9917/9923/22927/15929/1
929/3929/4929/4935/12939/1944/11
947/24949/17950/11953/3953/6953/15
957/23958/1958/2961/6961/17962/16
962/18965/16968/9968/21971/2973/5
973/11976/5976/8976/15977/5980/11
980/20983/231024/171027/11056/15
1057/71058/11059/191066/41074/10
1074/151076/7
before [51] 763/11770/8771/22786/2
806/1810/13812/14814/11819/18821/18
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 324 of 359
B
before... [41] 822/12823/14823/16
825/2833/12857/13859/18864/12879/13
894/25898/18900/18902/8903/23913/5
914/8921/9934/7934/11934/18936/14
941/8946/22947/9949/16968/23976/18
980/19986/11003/61024/31037/16
1037/161047/61048/81050/241052/12
1062/11074/101075/191075/22
beforehand [1] 773/24
began [1] 1002/20
begin [3] 989/91072/51072/20
beginning [16] 822/10837/24837/24
857/4857/4857/7875/25879/21894/13
894/21894/22895/24935/15954/3
1032/101045/7
behalf [1] 946/14
behind [4] 778/8860/16912/11039/15
being [22] 778/6842/5851/21889/4
896/4902/4902/9903/6904/5905/13
909/13913/8918/22919/9923/20925/12
950/23998/31009/51011/131049/7
1055/13
belief [2] 1006/201013/21
believe [49] 777/21777/22780/10
781/13784/11786/1788/19789/25803/9
807/16807/18807/18808/9808/13816/6
816/24816/25822/21826/14844/2859/10
865/4871/15876/13876/14881/1881/1
881/8881/8885/13885/14916/1926/18
931/1942/1963/6981/10981/13982/5
984/22989/141005/51007/91011/15
1014/181020/161023/141034/41067/1
believed [1] 1031/7
bell [1] 873/10
belonging [1] 950/13
below [8] 798/6799/22814/2828/4
829/25830/14831/25874/23
beneficiary [2] 925/3926/2
besides [3] 847/10951/81070/7
best [13] 793/4855/21858/20981/25
1033/131033/161037/131039/41041/22
1056/241064/71064/211072/23
bet [1] 939/17
better [6] 818/12819/2850/18862/11
910/7940/8
between [12] 766/12778/14875/23
892/14893/20906/1907/20916/10952/6
1023/71048/231069/9
big [7] 818/13820/5821/6972/19974/12
974/121042/23
bigger [1] 998/25
biggest [2] 957/24989/22
bill [1] 1042/23
binder [21] 773/21774/2786/1786/5
801/17805/3805/7805/12805/14805/15
810/19810/20812/21814/21827/17
827/18829/11885/17886/7886/10887/17
binders [1] 885/18
birth [16] 828/17828/22872/1969/14
984/14984/15990/5990/23991/8991/14
992/1992/17992/201024/121045/22
1058/10
birthdate [1] 990/11
birthday [1] 1025/12
bit [39] 768/11770/7784/15788/21791/1
791/3795/13796/22797/16806/11814/5
822/10837/15859/16874/25891/23
894/23898/24900/19924/19931/16
937/17949/10949/17954/1972/15979/11
987/14989/24994/11998/241013/23
1015/71019/91021/11023/91027/23
1033/11069/22
Black [1] 998/2
blank [1] 1043/21
blanket [2] 974/11974/11
blankets [1] 974/9
blasts [1] 790/11
blatantly [1] 957/24
blow [2] 783/3835/24
BMW [16] 812/3812/22841/24919/11
921/5921/13921/20926/14936/6943/2
943/13943/18945/24948/18950/5950/14
bodies [1] 975/1
body [1] 869/14
Boeing [4] 989/231022/71022/15
1022/15
bond [4] 1045/251058/121058/12
1058/13
bookkeeper [1] 1055/21
bookkeeping [3] 1044/121045/13
1055/24
books [1] 964/19
borrowed [1] 1014/3
both [35] 777/8777/10777/18778/2
783/9797/24827/23857/23857/24865/6
876/5884/13905/12907/4911/15917/2
927/18927/25930/21930/25931/5938/4
944/21957/17959/14961/13973/17986/8
986/9993/231016/241037/231048/24
1065/191076/3
bottom [16] 771/11779/21784/24
787/18800/4801/3801/3812/11826/5
830/10898/6898/7927/8952/1983/12
1052/24
bought [16] 842/15862/12862/14
865/16943/2943/4943/6943/13943/17
1015/211015/231030/231031/71031/8
1067/81067/10
boundaries [2] 779/121061/15
Bourne [2] 780/19780/19
box [1] 839/16
boxed [1] 1032/6
brand [1] 911/24
brand-new [1] 911/24
Braves [1] 910/13
break [17] 819/16819/18819/24820/4
820/25821/5821/8888/15910/12913/5
967/16967/17979/10979/12979/20
1027/231068/20
bridged [1] 958/1
briefly [3] 874/1878/81034/10
bright [1] 1048/20
bring [16] 766/19794/12795/1819/4
819/15821/18824/21857/16858/3888/19
912/15955/12967/21983/141036/3
1039/25
brings [1] 939/17
broadly [2] 771/17795/21
Broadway [1] 782/1
broker [7] 1036/241037/41037/10
1037/221038/71038/81038/16
brokerage [18] 1015/41015/61015/9
1015/121015/181019/191036/18
1036/191036/201036/221036/22
1036/231037/151037/211038/41067/6
1067/121067/13
brother [1] 1004/5
brought [9] 776/16776/18776/20880/8
880/9979/211032/191032/201045/24
BROWN [9] 763/11780/22780/23780/24
780/25873/21009/101009/111009/13
Bruce [2] 780/17873/6
bucket [1] 974/12
bucks [1] 801/12
budget [1] 975/19
build [3] 859/221004/211016/6
building [4] 969/1997/7997/101017/13
bulk [1] 801/9
bunch [3] 940/41032/51045/22
burden [1] 956/22
bureau [1] 830/22
BURTON [2] 764/4764/5
business [55] 770/14771/20771/21
778/11779/5779/6779/7787/21787/23
787/24787/25796/15796/15796/16
841/12880/22884/12889/14889/20
889/21889/22895/7895/10899/11904/25
921/11925/12954/23955/3999/231001/8
1001/131007/51012/91014/91014/9
1014/111014/111014/121014/14
1014/151014/181015/191017/41021/21
1021/231021/241036/251065/51065/6
1065/71067/231068/71068/91068/12
button [4] 983/10983/101006/17
1006/18
buttons [1] 983/12
buy [11] 875/17921/5961/51010/19
1010/201015/161015/201015/22
1029/181031/21067/7
buyer [5] 799/13809/10813/24814/9
877/2
buyer's [1] 800/5
buying [3] 872/12872/14942/13
buys [1] 945/24
C
C-A-R-U-A-N-A [1] 767/22
Cabaret [2] 785/9785/12
Cadence [1] 914/18
cadets [1] 994/18
calculated [2] 838/18838/19
calculation [3] 839/14847/6847/24
calculator [2] 977/19978/13
calendar [2] 891/11893/2
call [61] 767/11815/22819/18819/18
956/5963/6966/22968/1970/24974/15
983/18983/19985/16995/8997/23998/9
999/121000/141001/101003/111004/23
1007/131008/171010/111010/23
1011/201011/221011/241012/91013/2
1013/141016/51017/91017/111017/18
1023/211024/11024/81025/141025/17
1025/221029/51034/211035/41036/2
1037/121044/151044/191045/21
1047/211048/41050/201051/131051/18
1056/101060/251061/81064/31064/15
1069/71073/10
called [20] 799/10818/17845/20967/7
976/9976/12978/61001/141003/11003/2
1003/91004/61011/111013/51013/5
1025/141025/191034/91039/31056/7
calling [6] 968/2985/171011/181023/5
1025/201048/3
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 325 of 359
C
calls [4] 767/12882/51011/131047/21
calm [1] 875/11
came [54] 772/1772/17789/5798/14
799/2808/1844/25859/11864/15864/16
871/10871/11871/14894/20897/9902/9
903/23913/12919/25934/19936/1941/14
941/21946/13950/7950/9950/14958/9
958/10969/23970/1970/6971/25980/1
980/10980/19981/12991/5991/6991/6
1002/21016/251017/51019/21023/11
1023/141024/71024/181025/131029/22
1031/101046/111060/211074/1
can [188] 766/5766/19767/9771/10
783/3784/9785/3785/4785/18786/6
788/18790/23794/10794/12795/6796/21
796/21797/21798/6800/5803/10805/7
807/17809/4815/8817/11817/12819/5
819/6819/9820/11821/17822/6823/17
824/17824/24825/25832/19833/11
833/12835/9837/2837/7846/22847/20
854/7854/8854/14854/15855/15855/20
856/7857/15857/17863/23863/24864/25
865/16865/23866/20867/12867/14
867/23869/7869/10869/17869/18875/6
876/3881/2882/21885/11885/21888/19
889/9890/9891/16891/18893/7893/22
894/24895/14896/21897/2897/4897/20
898/4898/14898/21899/13900/10901/3
902/2902/24904/10905/5905/21905/24
906/16907/25908/8908/25909/7909/23
912/7912/10912/10912/15913/1913/7
913/8913/22914/13914/23915/8916/1
917/14918/19919/7920/7921/8921/17
921/24922/2923/2924/4924/18926/9
926/21929/9932/12932/16932/18933/1
933/4933/13933/16934/3938/18951/20
955/11956/2958/23959/15963/16965/5
966/6967/3967/9967/17971/12972/7
972/15972/20973/24973/24976/4979/21
983/17984/11984/17987/121000/8
1004/71022/11022/221027/11029/4
1035/11035/21035/21037/221040/13
1050/111050/131052/71054/171057/3
1058/131059/191059/241069/18
1072/121073/71073/151073/161073/21
1074/11
can't [16] 795/21796/16816/7817/10
817/16819/12853/14855/10863/22
864/25875/24880/16933/14948/6957/13
1055/14
cancel [2] 1026/201027/2
cannot [7] 795/18869/131024/20
1047/131047/131047/131054/2
capacity [1] 1022/1
capture [1] 831/16
captured [1] 879/4
car [13] 792/23811/16813/12813/16
831/1842/4859/17859/18887/7935/17
1017/61032/71038/12
Carauna [3] 767/12767/14767/21
card [27] 783/20807/23825/21825/22
828/16884/3885/9893/24902/21903/12
903/15904/1919/17919/19919/19919/20
920/4920/5922/9922/10944/25991/25
992/12992/13993/1993/14993/15
cards [6] 884/24885/8885/23935/17
991/20993/23
care [6] 817/23818/16956/131057/15
1058/21058/18
career [1] 994/13
careers [1] 994/11
careful [1] 853/14
carefully [1] 1009/7
CARL [59] 763/5769/1779/10782/24
785/1797/12797/24798/5798/18799/14
803/3807/23809/20809/20810/8812/1
813/24815/25816/18825/8825/10826/7
828/21835/5835/22836/14837/5838/2
843/2843/3843/23883/22899/10904/19
914/6920/13921/3921/6927/1943/4
943/16943/18943/20943/23943/24
944/14944/19944/24945/24945/25
961/11976/16976/19984/151031/5
1050/71051/111054/61077/9
Carl Torjagbo [29] 779/10782/24785/1
797/12798/5798/18799/14803/3807/23
809/20810/8815/25816/18825/8825/10
826/7835/5835/22836/14837/5838/2
843/2843/3883/22899/10904/19921/6
943/16943/20
Carl Torjagbo's [1] 797/24
carrier [10] 1015/181019/191019/20
1036/251037/131037/221037/221038/7
1038/101038/18
carrier's [3] 1015/131015/131038/9
carriers [1] 1015/10
carry [3] 1015/101015/151038/7
cars [9] 839/19841/24923/14923/17
925/11029/181030/231031/21031/11
Cartersville [2] 802/17841/7
cartoon [1] 780/25
Caruana [3] 768/2858/101043/14
case [40] 768/19768/25769/9769/10
769/12772/16775/13791/6791/12794/15
794/16795/22799/13844/24857/21872/8
872/10876/12883/21883/25884/15
886/21891/9910/13911/4939/14939/16
940/19956/22963/17965/19969/9990/7
996/151038/71039/61039/201057/6
1073/11077/10
case Number [1] 1077/10
cases [8] 791/2791/7792/6844/16
883/19945/1966/31076/1
cash [12] 812/13840/12840/16892/3
892/3892/4930/4930/13946/13946/15
946/16948/1
cashier's [14] 915/11916/10917/18
917/19917/21918/1918/3919/25921/19
921/22923/10924/6924/12949/22
catch [2] 1021/171061/24
catch-up [1] 1021/17
categories [1] 891/16
categorized [1] 893/23
cattle [1] 1037/8
caught [4] 859/21872/22961/21014/9
cause [3] 769/24789/231003/13
caused [1] 958/1
caution [1] 803/24
caveat [1] 888/14
CD [1] 831/3
cedis [5] 977/11977/12977/17978/1
978/7
center [1] 1056/16
central [3] 988/1988/2988/3
certain [15] 772/21802/25826/23840/9
883/24941/4941/8941/9942/9942/10
942/101011/161021/201038/81049/7
certainly [6] 767/1792/4961/5964/25
1060/121072/20
certificate [4] 992/18992/201045/22
1077/1
certificates [1] 1058/10
certification [1] 1056/22
certifications [1] 883/9
certified [6] 1/14768/20847/14883/11
883/11883/12
certify [1] 1077/6
Cessna [2] 989/21995/8
cetera [1] 988/25
chad [1] 818/13
chance [4] 773/23786/2787/2985/19
change [25] 766/15769/20803/2803/14
803/17824/10840/3865/5920/24920/25
929/21933/13943/14958/3985/5985/8
985/9985/17985/20985/22985/24991/2
993/251031/81054/1
changed [22] 802/25803/3822/10844/5
920/21921/1943/6943/8943/11943/12
985/3985/6986/2992/23992/241031/8
1049/121052/171054/101054/121074/5
1074/7
changes [2] 766/131048/23
changing [3] 1031/91051/251054/2
chapter [1] 997/22
chaptering [1] 997/23
character [2] 780/25781/6
charge [6] 891/22975/201005/11
1037/141060/181075/19
charged [5] 823/20891/25892/1922/10
976/1
charges [5] 785/14937/6962/201034/14
1034/18
Charles [2] 781/6781/23
Charlie [8] 780/22780/23780/24780/25
873/21009/101009/111009/13
Charlie Brown [3] 780/22780/23780/24
chart [2] 883/191073/23
Chase [53] 773/4773/6775/17780/12
787/13789/7789/9789/24790/2800/19
844/24844/25845/6845/9861/18884/9
885/10885/11889/17889/25893/25
893/25894/1895/20896/6896/9896/19
897/5897/10897/12903/11903/12934/1
940/11944/7947/1947/1947/5947/6
947/13947/13950/13951/16952/9952/15
960/22960/251011/41013/21020/10
1020/141050/201060/24
Chase Bank [19] 844/24844/25845/6
845/9861/18884/9894/1895/20896/6
896/9896/19897/5903/11903/121011/4
1020/101020/141050/201060/24
cheapest [1] 1037/13
check [90] 789/6789/15789/19789/22
839/16840/14846/9864/10885/14892/5
892/6892/9892/9897/11897/13897/15
897/23898/1898/9898/25903/16903/18
904/7904/12904/16904/17904/18904/20
904/24904/24905/3906/8914/11915/12
916/4916/10917/18917/19917/21917/23
917/24918/1918/4918/7919/17919/20
919/25920/4921/19921/22923/11924/7
924/12930/21930/23931/11934/9934/11
934/13934/14934/16934/21934/25935/1
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 326 of 359
C
check... [26] 935/2935/5935/6937/22
938/1946/14950/25951/8951/23951/24
952/1952/3952/7952/11952/16952/24
953/2953/6953/14953/21955/9956/6
960/22960/25993/171035/2
checked [1] 847/24
checking [2] 892/15893/21
checks [3] 892/5949/22953/3
chemicals [1] 974/15
chemistry [1] 987/22
Cherokee [1] 989/21
chess [1] 1023/9
chief [1] 1000/1
childhood [1] 1001/4
China [2] 1022/121022/15
Chinese [4] 974/20974/241001/14
1036/2
choice [1] 1060/11
chuckle [2] 855/1855/17
chuckled [4] 853/8855/7874/12878/25
chuckles [1] 854/23
Chung [1] 1004/5
chunks [1] 821/6
circumstances [3] 856/20874/5874/7
cite [1] 1/5
cited [1] 1014/8
cities [2] 970/7977/10
citizen [2] 1034/111060/9
Citizen's [1] 909/10
citizens [2] 1006/41036/6
City [1] 998/10
civil [4] 1038/141038/141038/151039/6
claim [5] 834/15839/171021/211046/9
1070/9
claimed [3] 838/3838/9838/16
claiming [5] 961/131041/201042/7
1048/221060/15
claims [1] 1047/9
clarification [1] 797/21
clarify [9] 817/11832/19842/20846/23
865/14865/16955/111040/131042/15
clarifying [2] 798/2818/2
class [1] 985/16
clawback [1] 937/12
clawed [4] 861/20934/51011/91030/15
clean [1] 825/1
clear [15] 791/21797/23797/25806/17
856/11869/5872/7914/19952/16957/23
958/16958/18960/15961/6963/5
clearly [2] 859/4859/9
client [1] 963/10
clockwise [1] 935/23
close [6] 877/22907/6910/21911/11
911/19946/4
closed [2] 983/8983/9
closely [2] 1065/21065/14
closer [4] 769/25911/10971/12985/13
closing [10] 800/24822/12824/5908/23
910/22911/8913/19915/19946/191072/5
Club [1] 994/16
clubhouse [2] 1023/81023/11
CM [2] 1/21/3
CM/ECF [2] 1/21/3
Cobb [1] 810/11
code [3] 769/18775/191053/11
codes [1] 951/25
coffee [1] 821/10
collected [1] 883/25
college [6] 988/5989/15989/16990/17
994/13994/14
color [1] 933/13
Colorado [1] 972/4
COLTER [3] 763/201077/41077/18
column [2] 777/10839/16
comb [1] 1009/20
combination [2] 799/2850/14
combined [1] 931/13
Comcast [7] 777/3777/4777/21777/22
777/24778/4778/12
come [43] 771/25776/2818/8821/6
824/1827/2853/6854/23866/14877/4
878/23878/24880/14882/7894/17894/19
902/11911/16916/15916/16924/1929/6
933/9941/15956/15968/5969/22971/24
976/7976/20979/20988/5988/101019/1
1023/101029/201029/231032/21044/3
1053/81069/101069/131071/22
Comedy [1] 869/20
comes [10] 822/21900/5900/5900/22
901/10901/21906/4919/19949/171047/6
coming [28] 773/10792/23793/4833/14
844/24864/9893/15903/4907/7924/16
929/14934/18941/5941/9950/11962/13
965/21976/2976/22979/7990/15990/17
990/19990/201017/201047/51048/13
1058/2
commercial [3] 989/131027/211028/7
commingled [7] 811/14863/24863/25
863/25865/1875/24931/3
Commission [1] 972/25
commit [8] 957/2957/8957/19958/11
958/24960/2985/22991/13
committed [1] 823/17
committing [1] 794/17
common [1] 976/4
commonality [1] 778/14
communicating [2] 1002/61002/9
communication [1] 857/25
companies [7] 772/14972/21972/23
1004/251005/11034/201066/18
company [56] 770/3770/4770/6770/10
770/12770/14770/19770/22770/24771/1
777/2777/22782/15790/15804/22806/17
806/20833/24834/2836/21846/6846/18
848/10861/8861/9862/21955/6955/7
955/8955/21959/4976/8976/12999/20
999/211007/81007/81009/31012/21
1015/21039/81049/201051/21051/7
1054/31054/51055/221055/231056/13
1056/141061/141061/161064/11065/3
1065/41065/24
company's [1] 1051/19
compare [1] 876/4
comparing [1] 1068/1
compensation [3] 835/15836/8836/24
complaining [3] 853/25853/25878/20
complete [1] 923/17
complex [1] 768/11
compliance [1] 768/22
complicated [2] 960/41008/4
composure [1] 1033/16
compound [2] 1063/51063/5
comprehend [1] 1032/11
compute [1] 1045/16
computed [2] 1044/11045/14
computer [5] 763/181023/251046/12
1046/131049/15
computer-aided [1] 763/18
computers [2] 1067/81067/10
computes [1] 1044/13
conceal [6] 790/6790/7962/31030/21
1030/251039/22
concealed [2] 945/12958/3
concealing [5] 943/25945/10945/25
960/19961/25
concealment [6] 945/13945/14957/20
957/22960/15960/18
conceded [1] 959/14
concern [5] 790/25793/15881/20
1012/21012/5
concerned [2] 859/15875/11
concerns [4] 767/10881/221070/3
1070/5
concession [1] 973/22
concludes [1] 853/6
conditioned [1] 859/18
conditioner [1] 859/18
conditioning [1] 831/2
conditions [1] 1033/17
conducted [1] 830/21
confirm [7] 894/13906/6909/13925/15
934/11937/9964/3
confirmed [1] 964/6
conflict [1] 1069/4
conflicting [2] 993/16993/18
confused [2] 810/4857/9
confusion [1] 982/16
Congress [1] 1064/10
connection [2] 782/61077/11
connects [1] 1037/4
Connors [3] 764/3933/3933/7
connotation [1] 792/2
consent [1] 829/21
consider [6] 794/8795/18804/1822/16
822/24957/13
consideration [2] 821/24824/7
considered [1] 803/25
considering [2] 874/21962/16
consistent [6] 834/2834/9895/4895/6
954/6966/8
consult [1] 973/7
consulting [2] 768/21768/22
contact [7] 779/9816/19816/201026/19
1037/111045/251059/14
contacted [2] 1026/251059/16
contained [2] 884/20888/8
contains [1] 831/8
contemplating [2] 1012/201019/11
content [2] 888/71074/14
context [2] 854/9855/10
continents [1] 1060/20
continue [4] 995/91068/111068/19
1068/20
continued [1] 875/14
continuing [1] 1014/12
contract [5] 799/22799/24802/18
802/23804/18
contrary [1] 856/9
control [3] 859/12860/9960/19
controlled [1] 795/9
controlling [1] 960/17
convenient [1] 1055/3
conveniently [1] 1048/23
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 327 of 359
C
converged [1] 905/9
conversational [1] 819/1
convert [3] 977/171015/241067/22
cooling [1] 879/13
cooperative [1] 1033/25
copy [7] 766/8821/20897/23899/19
904/12917/181070/2
corner [7] 771/12784/18788/14803/13
830/11933/6933/8
corporate [8] 796/6796/7796/24797/6
797/7845/21995/15995/22
corporation [5] 775/21796/25797/1
797/1797/15
correct [130] 772/2772/3777/14777/15
777/17777/18785/21785/22786/15788/2
788/3797/5797/6797/25801/13807/7
809/23813/4814/10832/13833/25841/6
841/14843/21844/8844/23845/8846/2
847/15847/15847/17848/2848/8848/9
849/3849/6858/11861/19862/13862/15
862/18863/7864/24867/7868/19868/21
870/7871/8872/1872/2872/4872/6873/5
873/7873/8874/5874/6876/9877/10
881/1886/4886/5893/1893/17894/1
905/1909/15909/17914/9914/12916/25
921/12921/15923/21930/15930/20
931/15936/25937/25938/3939/4939/15
939/19940/7940/12940/14941/11942/4
942/8942/10942/11943/3943/5943/8
944/8944/10944/13944/15944/18946/10
947/18948/5948/17949/15949/19953/16
954/5954/16954/20954/22959/20966/16
980/16982/7982/11991/18991/22992/3
992/4992/9992/191024/111024/11
1036/131053/11053/111053/151053/20
1063/211074/22
corresponding [2] 918/6924/15
corroborate [1] 964/3
cost [5] 1035/181067/51067/61067/7
1067/12
costs [2] 814/51035/19
could [132] 771/7772/22774/22777/6
777/9778/24781/15782/17787/10787/15
788/11788/20789/11789/12797/17
798/20799/6801/17802/3802/9802/12
802/19802/24803/10805/2806/1806/9
806/12806/25807/8808/23809/1810/3
810/18811/9811/20812/20813/9813/19
814/21815/17819/25820/5825/2825/17
827/17827/25828/6828/8828/15829/11
829/22830/2834/11835/19839/8839/11
846/9846/9846/10846/10846/15849/4
849/5850/3850/3850/4850/4854/7865/1
865/1865/3865/11873/11875/13875/19
876/17878/23879/4885/17886/7901/23
903/2918/10922/20923/22929/5932/6
949/25951/4953/3953/6953/14953/17
953/20977/22980/12982/9985/10993/22
1010/181011/161013/211014/13
1014/141014/161015/241021/21
1022/221026/201027/171033/14
1033/251041/81047/171048/121052/20
1058/61059/111059/161060/191063/22
1065/21065/41065/241065/241066/8
1066/221067/21067/181067/221068/10
couldn't [5] 1012/121018/161018/16
1040/31065/21
counsel [5] 832/13876/8876/20876/23
877/8
counsel's [1] 850/24
count [6] 956/22956/24958/19958/20
958/22959/16
counting [1] 892/16
countries [1] 1013/10
country [5] 849/5941/23967/7973/16
1059/20
counts [9] 956/21956/23957/18957/20
958/6958/13960/12961/8962/7
County [1] 766/3
couple [15] 784/11803/15821/19821/23
822/1824/12825/1910/18912/10948/4
956/151032/101034/151054/141069/13
course [6] 773/17774/19978/241000/8
1036/181038/2
courses [1] 1022/11
court [23] 1/31/71/91/121/14763/1
763/21766/4841/19956/20960/14962/7
963/21984/171038/171050/211058/1
1066/111071/141077/41077/51077/8
1077/19
Court's [2] 833/6956/9
Courthouse [1] 763/21
courtroom [19] 767/8769/3790/22
795/3817/15820/10821/16824/23850/22
858/6910/16912/25956/17967/24979/15
983/161069/171072/111073/6
cover [4] 770/17894/15903/24989/24
covered [3] 784/3963/171039/24
COVID [9] 772/13772/15837/22892/10
947/15947/171007/51013/81068/16
COVID-19 [1] 837/22
CR [2] 763/41077/10
CRC [2] 763/201077/18
create [4] 791/7883/18888/21066/9
created [4] 806/15974/201039/15
1074/20
creating [1] 1056/3
credit [18] 783/19884/3885/8885/9
885/23891/18891/20891/24893/24
902/21903/12903/15903/20904/1922/9
922/9935/17993/22
credits [3] 1021/211021/231021/23
crimes [3] 768/12883/12958/11
criminal [5] 763/4776/9792/6957/19
962/9
criteria [1] 772/21
cross [14] 817/13817/23819/6840/20
840/23854/8938/8938/10970/13970/15
975/7975/91040/51040/9
cross-examination [12] 817/13840/20
840/23854/8938/8938/10970/13970/15
975/7975/91040/51040/9
CRR [2] 763/201077/18
CSO [1] 1069/14
cuffed [1] 860/16
cuffs [1] 1032/12
cumulative [1] 907/16
current [4] 821/20874/151046/13
1046/25
currently [3] 768/4882/221055/6
customer [2] 807/12807/22
cut [4] 851/8851/10851/11981/1
cutoff [1] 904/5
CV [1] 966/18
D
D-E-L-A-N-O [1] 984/4
dad [8] 987/21987/24991/151002/15
1003/31004/11013/61069/5
daily [7] 876/1876/3900/11900/13
900/15977/12978/2
Dallas [4] 814/19827/6841/8841/9
damaged [1] 1068/10
Damon [1] 780/20
dancing [1] 784/6
dare [1] 887/12
data [7] 777/24778/1778/1778/3778/3
778/8783/19
database [2] 1056/251057/3
date [56] 771/11771/13771/22771/24
776/8776/18782/13783/1783/7800/5
803/8809/3810/16816/19816/20826/8
826/10828/17828/22872/1889/7900/16
904/5916/11920/16920/17920/19920/22
920/23920/24928/24928/25929/1935/2
935/6935/22941/4941/8942/9943/11
945/20946/21947/9947/15952/11969/14
987/3990/5990/22991/7991/14991/25
1019/131024/111025/241049/7
dated [5] 798/7798/20799/12800/2
809/2
day [42] 781/1826/13858/13864/3
889/12900/4900/7901/12901/20903/18
908/15911/17911/19911/21911/22
912/19912/20920/4930/6937/2937/2
937/5937/5937/6937/6977/11977/24
977/25980/191003/251003/251024/13
1025/111025/161025/191031/15
1031/171033/101048/71048/71072/13
1077/14
days [6] 1/4816/22901/13901/14978/1
1024/15
deal [7] 820/6926/31002/151002/16
1002/201027/251067/9
dealership [5] 810/10810/17812/4
842/5942/13
dealing [1] 844/22
deals [1] 1004/22
death [1] 1038/15
debit [3] 919/18919/191035/1
debt [1] 1004/19
decant [2] 974/13974/14
deceive [1] 803/19
December [5] 836/20836/25894/10
988/13988/14
deceptive [1] 852/2
decide [5] 804/2804/3819/5958/23
1015/1
decided [5] 854/18982/9985/91001/24
1062/1
decides [1] 962/8
decision [3] 962/111015/171069/1
decisions [1] 1047/14
decreased [1] 895/23
deduct [1] 1029/4
deducted [2] 1029/11061/13
deducting [1] 1061/12
deductions [1] 899/24
defendant [32] 763/7764/4769/6780/9
789/2795/22797/15802/25804/2804/23
822/15822/18827/22829/16830/24
843/19853/25855/17856/1872/13912/9
919/12920/21922/17923/5937/9962/23
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 328 of 359
D
defendant... [5] 965/15981/3983/23
1070/161070/21
defendant's [17] 773/16796/9797/8
814/14829/21830/18830/21851/20908/2
909/16924/2928/12986/4986/14986/18
987/51020/2
defendants [1] 966/3
defense [8] 769/4824/12850/24876/8
876/20876/23877/8931/25
defined [2] 775/18848/21
definitely [1] 863/15
defrauded [1] 872/8
degrading [1] 975/1
degree [3] 1008/181021/201055/25
DELANO [88] 763/5763/6768/25769/3
773/18774/20778/22779/18783/10
789/25795/9800/7802/16803/4803/4
808/6809/12809/22812/1813/24814/9
827/2827/14828/12828/21828/24831/17
833/23834/2834/4838/3838/9838/16
839/3839/5839/17839/17841/4842/22
843/16843/23843/25844/6845/4845/12
845/16845/19846/2853/6858/13859/14
860/12866/5874/7875/15876/23877/2
878/14881/19883/21911/6921/3921/4
943/7943/14957/25958/10976/25979/17
983/19983/22984/4984/11984/15985/6
986/1986/22986/25987/2987/61031/6
1031/71039/121039/191051/111054/6
1077/91077/10
Delano's [11] 778/16778/17778/19
796/9797/13797/24816/7840/2840/17
875/10980/13
Delaware [1] 1039/15
delay [1] 1029/7
deliberate [1] 911/21
deliberations [3] 823/101072/51072/20
delivery [1] 812/11
Dell [1] 1067/9
Delta [2] 998/12998/12
demeanor [4] 879/2879/5880/3880/6
demonstrative [6] 831/24931/17932/3
1074/181074/191074/23
deny [2] 958/21962/20
department [4] 848/211003/41003/7
1032/1
depend [1] 975/24
dependent [1] 777/22
depending [2] 822/18973/22
depends [1] 846/14
depict [6] 801/21802/6802/10811/3
812/24815/1
depiction [1] 853/19
depleted [1] 949/17
deposit [33] 775/20787/21788/5789/1
789/4789/23790/3801/9816/4816/6
816/9817/6840/14845/7865/5871/13
896/13896/17896/18896/25897/8897/10
899/15901/19905/3907/14913/16916/11
926/5935/3946/3952/13955/6
deposited [26] 789/9796/5796/14
816/25845/21896/4897/16898/1898/2
898/9898/25904/8904/20904/21905/15
915/12917/4929/3929/4929/5930/22
933/24933/25937/15953/6953/15
deposits [25] 775/20787/16788/22
798/6801/7864/13890/5890/12891/14
892/11892/19892/22893/15906/10
907/11916/23928/11928/17928/19
928/21929/2929/15929/22930/25936/20
describe [1] 875/9
described [3] 913/9915/5992/17
designed [3] 808/19846/12848/24
desktop [2] 1023/191049/19
despite [2] 857/12982/8
destined [1] 846/14
destroyed [2] 1014/101068/10
detail [3] 900/11925/6925/8
detailed [1] 876/2
details [2] 926/4993/21
determine [8] 772/10772/19783/9
783/13783/22804/1848/20970/3
determined [2] 782/111008/1
develop [3] 1001/161002/161002/24
developing [1] 841/12
development [1] 1004/20
Dhabi [4] 1027/211028/61028/71028/8
diced [1] 852/20
Dickens [2] 781/6781/23
did [552]
didn't [83] 770/18770/18807/1838/6
842/7842/10851/16851/17852/10853/6
854/1854/23855/13855/18857/9859/14
859/23859/24859/25860/2860/3860/4
869/6870/10873/14875/11875/12876/2
880/13880/13881/20890/15894/4931/8
940/15940/23940/25941/4943/21944/24
959/21982/13997/71004/171008/25
1009/91009/191009/191010/141011/11
1013/111017/171018/151020/241024/7
1024/91025/101026/61026/61026/10
1027/141035/101038/91038/101038/18
1041/51041/61041/81041/181042/9
1042/121044/231044/251047/11048/1
1048/41049/21054/241062/101064/21
1066/91066/241067/12
died [1] 1000/18
difference [3] 1016/181018/161035/9
different [44] 773/13774/2777/24
780/14790/11791/17794/21794/21795/9
795/11809/3811/18832/10893/23900/3
926/25929/6930/14932/10937/3954/9
954/21958/24959/2969/21970/1970/4
970/6970/7970/101006/21016/23
1035/251036/11049/211053/41053/8
1060/201065/51065/61067/31067/23
1071/151073/23
differently [1] 1061/1
difficult [1] 790/8
dig [1] 1035/16
digging [5] 1003/211003/221003/23
1035/151051/20
digits [4] 787/14788/17825/25890/15
digress [1] 782/1
diligence [2] 770/81038/18
direct [12] 767/24794/15817/17818/3
874/4881/17882/19941/3949/11968/17
971/10984/5
directly [7] 908/10917/21923/22927/3
951/5953/3953/6
director [2] 987/24988/1
disagree [2] 863/11981/21
disbursed [1] 903/6
disbursement [1] 930/11
disbursements [12] 893/3893/5893/11
893/18893/23894/15895/1895/3895/6
906/25907/18907/19
disc [2] 831/8831/9
discharge [1] 997/20
discharged [1] 997/21
discovered [4] 776/19776/20790/13
843/12
discuss [5] 808/23811/20850/18851/5
934/3
discussed [4] 814/25815/12815/16
888/3
discussing [1] 825/15
discussion [3] 851/141056/161070/18
disguising [1] 960/18
dishonorable [1] 997/20
dismiss [3] 956/21958/131071/23
display [5] 805/10813/9828/6830/2
931/18
displayed [1] 878/21
dispute [3] 848/4872/15891/21
distancing [1] 961/9
distinction [1] 965/9
distinguish [1] 875/23
distracted [1] 1033/16
District [19] 1/14763/1763/1770/16
779/13779/15783/12783/18784/4785/16
799/17799/19804/16810/12812/7814/20
968/251077/51077/5
divert [1] 1016/8
division [3] 763/2768/5776/9
do [281] 767/2768/18768/20769/3769/4
786/20788/6788/24791/10792/19793/3
793/22794/7794/15794/17801/20801/23
805/11808/14808/18811/3812/24814/4
816/22817/12818/15819/5819/8819/9
819/9819/9819/10819/10819/18819/18
819/23820/7822/15831/9832/8833/8
833/15844/2844/17848/17848/23852/17
852/17852/24854/1854/7854/12854/15
855/6855/15855/21856/5856/22856/23
856/24857/12857/12857/17857/18
857/24857/25862/10864/15867/22868/4
868/7869/19869/22869/24870/1872/15
876/2880/5880/13883/9883/15885/13
885/17887/22894/2910/7910/22910/25
911/3911/5911/7911/9911/23912/2
916/1917/1917/24920/25925/5931/7
933/2933/3933/16935/2935/5935/13
935/21939/8939/10941/5941/12941/14
941/23941/24942/1942/12942/17944/1
945/13948/22952/13953/24956/24
957/13962/21962/21965/14966/3966/3
966/4966/7967/2967/3968/23969/8
969/9969/11969/24971/20971/20973/3
973/7974/4974/4975/21977/9978/17
979/25981/9981/19982/9983/1983/2
983/6985/1985/19986/6987/20988/23
991/3991/17992/11993/10993/13994/3
995/3995/3997/13998/9999/20999/22
1000/131001/101003/91003/111004/23
1005/31005/91007/121008/91008/17
1009/141010/101010/211010/231012/9
1012/121013/21013/141013/211014/13
1014/131015/71015/81016/51016/25
1017/91017/111017/181018/241019/5
1019/111019/121020/61022/11022/2
1023/211024/11024/71024/81025/17
1025/221026/41026/51026/71027/1
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 329 of 359
D
do... [65] 1027/61027/141027/15
1027/161029/51029/71031/171031/18
1031/201031/231034/191034/20
1034/221035/31036/11036/51036/15
1036/221037/121037/221039/41039/12
1041/231041/241044/151044/19
1045/211051/131051/181053/31054/4
1055/31056/81056/101056/121056/13
1056/211057/111060/251061/81062/20
1062/241063/81064/31064/41064/12
1064/151067/221068/191068/19
1068/211068/211069/221069/22
1069/251071/71072/11074/31074/12
1074/121074/241075/71075/81075/8
1077/6
docket [1] 1/6
dockets [1] 1058/13
Doctor [1] 996/4
doctors [1] 995/24
document [24] 1/9780/2782/19787/16
800/1800/11800/12800/21800/23801/1
805/23806/2809/10826/23836/4837/4
838/13869/7869/16913/25992/6993/13
1051/61056/17
documentation [27] 804/24811/25
813/24816/17870/2870/13876/16950/22
991/9992/6992/6992/181008/111008/12
1008/131021/181046/131049/16
1049/171051/21059/121060/231060/23
1060/241061/21061/71061/21
documentations [3] 1045/221049/4
1062/6
documented [3] 811/1844/41058/11
documents [30] 773/23780/3780/5
783/16783/16800/24805/24844/4844/7
844/9849/18883/18888/4890/22891/9
941/1946/17954/2958/17992/15993/18
1006/81008/191011/161011/171033/9
1033/111058/71061/91061/24
does [75] 777/4787/18787/23793/17
795/20802/6802/9804/5813/1815/1
815/3815/3822/20831/16831/18838/13
838/15843/10847/9848/11863/11867/23
878/4888/7888/10897/13898/2898/7
899/3908/5908/7910/4913/25917/18
920/13923/7924/6924/23925/1925/2
925/5926/4926/12927/11927/12928/2
931/21931/23933/24934/24937/17947/1
952/8960/12962/6975/2975/24986/12
986/13986/24988/221006/131020/11
1036/211049/241049/251050/41052/16
1055/231055/241058/161072/61072/6
1074/91074/12
doesn't [19] 777/24822/20848/10864/3
1048/131050/21053/81054/101054/12
1054/121056/61057/101057/111059/2
1060/11061/121061/161064/81064/15
doing [20] 792/4794/16844/13852/2
852/5853/9912/16912/18945/18965/11
966/19968/21996/81003/231017/7
1026/21037/161072/221075/241076/7
dollar [9] 769/22770/3840/16864/6
931/1931/2932/10936/201038/22
dollars [9] 840/12917/8977/16978/11
978/13978/251030/11041/101045/14
don't [163] 767/1777/4778/3781/20
781/22791/8791/21791/21792/18792/18
793/17793/20793/20796/12810/16
817/23818/9818/15818/16819/8823/1
823/4823/22826/15843/8843/10843/12
846/24848/4848/20848/24849/18849/22
850/2851/9851/15852/9852/9852/11
852/11852/11852/15852/18852/22853/3
853/13853/21853/22854/5854/19854/20
854/22855/14855/25855/25856/1856/2
856/14856/15857/3858/25861/13861/14
863/11864/2864/15865/8870/12870/14
871/3872/5872/15873/11885/14889/1
910/13910/21911/25933/2933/10933/16
939/8939/10940/1940/1941/15942/22
943/8943/11945/3945/9945/13945/13
945/14945/17945/20946/15946/15948/9
948/22955/18958/22959/15961/4963/14
963/14963/21967/3976/11976/22976/23
977/17978/6980/9981/21982/16984/25
1009/111009/131009/181014/20
1014/211017/191017/191018/17
1018/171024/231034/201034/201042/2
1042/41042/131042/131042/231043/6
1043/61044/61044/61045/251046/2
1046/21050/11052/11057/71057/11
1059/141059/141059/231060/41060/6
1060/61060/71062/41064/91066/1
1068/241069/81069/211069/251071/16
1071/221073/11076/12
done [18] 790/9795/22803/18826/20
851/8868/9899/20906/21911/15929/2
939/12957/23974/18974/19974/19980/8
1038/171073/9
Donuts [1] 937/8
door [4] 790/24892/4903/4983/13
dot [2] 965/121031/25
dotted [1] 934/4
double [3] 892/16956/6983/10
double-check [1] 956/6
doubt [1] 958/22
Douglasville [16] 770/16770/20771/3
779/8779/15782/22785/2785/11785/12
785/13785/15825/24828/22999/9
1046/191052/24
down [55] 778/24785/18788/21788/21
788/22812/12814/4816/4825/9835/19
837/2837/15838/1859/19860/13879/6
879/6880/1887/5903/9908/17908/19
911/23913/16915/16923/15925/25
926/15927/5938/18956/2961/22973/5
973/11974/2974/10974/13975/3979/6
987/18992/7997/7997/91000/171001/24
1002/21005/151010/141013/171013/18
1013/221014/221014/241027/23
1073/16
dozen [1] 1056/7
dozers [1] 974/7
Dr [3] 970/24971/14996/5
Dr. [2] 996/21035/24
Dr. Miller [1] 996/2
Dr. Owusu [1] 1035/24
dragging [1] 1022/3
drawn [2] 850/6850/8
drink [1] 894/6
drive [15] 763/22793/3802/17804/14
910/3910/5913/11913/17915/3915/16
915/20918/18919/1919/2936/6
driver's [7] 783/14827/21827/21959/18
993/14996/251023/21
driving [2] 1017/61038/12
drop [1] 1037/3
Dubai [6] 941/25942/11002/131004/12
1004/131004/14
due [7] 770/7812/111019/211020/14
1020/191038/171070/8
duly [5] 767/15882/10968/9971/2
983/23
Dunkin [1] 937/8
duplicate [2] 822/14822/17
duress [1] 879/9
during [34] 772/13772/15772/24774/8
778/6783/10783/25790/5795/16805/23
817/12830/13839/6843/13843/18857/9
866/6877/13880/4892/10892/20939/12
939/13939/14949/10955/17998/4999/6
1007/51019/101023/71045/241045/25
1058/12
dying [1] 817/24
E
E71 [1] 996/13
each [6] 775/18928/11928/14949/22
1051/141056/20
earlier [14] 776/16795/8808/16825/15
826/18827/9916/22925/21926/18955/17
1019/81047/201057/161066/14
early [1] 1048/20
earned [12] 1034/91035/51035/81042/4
1042/61042/81042/91042/101044/21
1061/131064/11064/5
earnings [8] 817/9820/17838/10838/14
1035/41042/251043/101045/9
earth [1] 1046/21
easier [3] 805/12901/8945/5
easily [2] 958/1960/25
easy [3] 843/6961/201008/4
eat [1] 937/7
ECF [2] 1/21/3
economic [1] 883/12
ecosystem [1] 1003/13
edits [1] 1070/3
education [1] 988/2
educational [2] 972/3973/10
effect [2] 850/11003/13
eight [7] 768/21768/23883/3939/2958/6
962/41005/18
EIN [30] 782/5782/11782/111004/17
1004/181005/31024/191025/81025/18
1025/241026/11026/11034/201048/24
1049/31049/61049/71049/81049/16
1049/231049/241050/81050/91051/7
1051/101051/151051/221052/161054/9
1054/20
EINs [5] 782/101024/211024/221049/4
1051/13
either [14] 778/16818/25860/5906/10
926/25933/4950/12954/10967/3982/12
1000/51037/221039/191051/19
elaborate [1] 1060/17
elected [1] 1070/16
electronic [2] 897/10899/24
elements [3] 957/10962/16962/19
eligible [2] 1009/21009/5
ELMO [2] 982/25986/19
else [26] 769/24795/18823/22832/1
856/14856/15860/5865/21897/13902/18
961/2968/2980/3980/22980/24999/14
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 330 of 359
E
else... [10] 1003/51007/251023/1
1041/201046/31059/161068/111075/3
1075/71075/15
email [6] 779/10853/20853/21856/1
939/171024/16
emailed [1] 881/9
Emirates [6] 941/22941/24941/25999/5
999/121034/16
emphasis [1] 969/6
employ [4] 973/24973/241005/61005/7
employed [8] 768/3882/22968/19
968/20971/14971/16971/17973/25
employee [10] 782/10846/11871/15
871/181056/41056/121056/141056/20
1056/251057/3
employees [36] 770/5772/14772/20
772/24780/11834/5834/15834/21835/14
836/7836/23837/17838/17838/20839/13
846/8846/20847/5847/10847/23848/8
849/11866/10868/25877/9877/15877/19
959/3959/3964/16965/71009/31016/4
1057/11059/121060/13
employer [1] 1042/21
employment [1] 993/12
empty [1] 827/7
encounter [4] 852/25853/2856/20
858/19
end [22] 816/10824/3837/24864/3898/7
902/9902/9905/13911/17911/18911/22
912/18912/20935/13963/11989/14
990/111032/191042/221042/231052/17
1076/13
endangered [2] 1003/111003/11
ended [2] 766/25782/16
ending [33] 784/21798/5798/9800/19
801/4890/14890/16896/10897/1898/19
902/14914/6914/7915/13915/15915/17
915/21920/3923/13923/13927/7928/8
928/18929/12929/20930/3935/11005/5
1021/71021/81024/21024/101043/17
ends [5] 825/11898/24901/14902/12
919/23
energy [1] 1070/1
enforcement [6] 858/17858/18859/3
939/5939/7966/1
engine [1] 969/25
engineer [1] 971/21
engineering [2] 972/4972/9
enlargement [1] 818/21
enlisted [4] 994/25995/1997/15998/3
enough [2] 819/231015/14
enrolled [2] 1022/91022/11
entail [1] 772/4
entered [9] 767/8795/3820/10824/23
858/6912/25967/24983/161072/11
enthusiasm [2] 1040/81068/24
entire [7] 801/10831/13890/15894/9
988/21038/131047/9
entirely [1] 1067/23
entirety [1] 768/12
entitled [2] 851/21960/5
entity [1] 796/23
entries [1] 970/6
entry [3] 1/6798/7798/20
environmental [4] 1003/21003/10
1003/161003/18
equating [1] 781/23
equipment [7] 925/9974/7974/8974/12
974/19974/211036/3
erase [2] 933/1933/14
eraser [1] 933/2
especially [1] 910/24
essentially [5] 888/4906/13924/7
924/13949/13
establish [2] 862/211050/24
established [1] 846/18
establishment [1] 784/7
estate [17] 799/11800/15800/22804/11
820/18840/12861/11887/3903/9918/23
919/4930/7946/8946/19949/24950/16
1036/23
estimate [3] 834/41072/41072/22
estimates [5] 1033/131061/41061/7
1061/221062/7
et [1] 988/25
et cetera [1] 988/25
ethnicity [1] 792/3
even [34] 785/14804/3817/18820/6
848/17855/7900/21904/24930/13931/24
951/7953/2958/7959/8963/10963/21
965/1976/23986/21003/61008/20
1009/111013/131030/181051/11053/10
1053/191058/11058/31060/151061/16
1062/51062/181066/3
evening [3] 1025/111068/201071/17
eventually [6] 846/4846/131011/15
1011/171025/101038/16
ever [13] 816/10840/16865/7877/21
976/5976/8976/12976/15976/18976/25
989/221005/141039/22
Evert [1] 764/3
every [12] 792/19841/17849/23907/16
917/7977/11977/24977/25992/7992/7
1056/201058/10
everybody [14] 766/6767/10793/1793/7
795/20853/14857/11857/21964/4984/11
985/161007/251072/61073/2
everybody's [2] 817/221062/2
everyone [3] 804/5887/181072/23
everything [11] 875/12929/2929/4
957/23982/13992/13992/171039/19
1049/191055/31062/9
evidence [47] 771/8777/9778/25782/18
789/13797/18802/13803/11804/3804/10
808/24811/21813/20815/18823/24
834/12849/7849/11861/14861/15864/18
865/12866/24867/1869/22870/14873/15
911/20934/18957/1957/8957/19957/21
957/22957/22958/2958/7958/8958/23
960/2962/18966/12986/151019/22
1074/141074/161074/17
Ex [1] 1070/10
exact [6] 803/8803/8854/22858/25
943/111054/8
exactly [8] 795/15848/22849/19850/2
853/4853/13961/3970/2
examination [23] 767/24817/13840/20
840/23854/8874/2874/4878/10881/17
882/19938/8938/10941/3949/4968/17
970/13970/15971/10975/7975/9984/5
1040/51040/9
EXAMINATIONS [1] 765/1
examined [5] 767/15882/10968/9971/2
983/23
examiner [2] 883/11883/12
example [9] 794/23950/51014/8
1065/101066/111067/201067/241068/3
1068/6
examples [9] 887/1954/171013/24
1014/21066/91066/101067/241068/5
1068/5
excavator [2] 977/23978/3
excavators [2] 974/7977/10
Excel [1] 777/7
excessive [1] 1033/1
exchange [1] 1002/17
excited [1] 911/25
excluding [1] 893/18
excuse [3] 781/12887/18899/22
excused [2] 881/24970/22
executed [2] 859/8860/14
executing [2] 832/25858/24
execution [1] 850/1
exempt [1] 1034/13
exhibit [111] 771/7777/7777/8778/25
781/16782/18784/10786/4788/12789/12
797/18798/10798/15799/7800/10801/18
801/24802/4802/13803/11804/9805/3
805/14806/6807/9808/23810/19811/6
811/21812/20813/6813/10813/20814/22
815/5815/18816/14823/2825/3827/17
828/2828/7829/11830/3831/4831/11
831/23834/12839/9846/23874/14874/15
874/15874/17876/18876/21885/1885/12
886/7886/12886/16887/16887/22888/2
888/5888/7888/12888/19888/21893/8
897/20898/14898/22899/13901/3904/10
909/1909/8913/9913/22914/23915/8
916/2917/15918/10918/19920/7921/24
922/13923/2924/4924/18925/17926/9
931/17931/21932/3935/14936/23947/10
951/21955/121048/111050/121052/8
1052/121073/201074/61074/141075/9
1075/11
Exhibit 1 [1] 771/7
Exhibit 101 [4] 778/25781/16834/12
839/9
Exhibit 101B [1] 777/8
Exhibit 106 [1] 1050/12
Exhibit 13 [1] 803/11
Exhibit 14 [2] 805/3805/14
Exhibit 201 [1] 782/18
Exhibit 220 [1] 777/7
Exhibit 300A [1] 825/3
Exhibit 300B [1] 798/10
Exhibit 301 [1] 788/12
Exhibit 301B [2] 789/12897/20
Exhibit 302A [4] 909/1913/22920/7
922/13
Exhibit 302B [2] 797/18899/13
Exhibit 302C [1] 798/15
Exhibit 305 [3] 807/9885/1924/18
Exhibit 305G [1] 924/4
Exhibit 310 [1] 885/12
Exhibit 314 [3] 886/7886/12886/16
Exhibit 401 [2] 786/4799/7
Exhibit 402 [1] 813/20
Exhibit 403 [1] 802/13
Exhibit 404 [1] 811/21
Exhibit 405 [1] 804/9
Exhibit 406 [2] 808/23876/18
Exhibit 407 [1] 815/18
Exhibit 408 [1] 816/14
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 331 of 359
E
Exhibit 41 [2] 831/4831/23
Exhibit 42 [1] 874/15
Exhibit 43 [1] 830/3
Exhibit 44 [2] 827/17828/2
Exhibit 451 [3] 801/18801/24802/4
Exhibit 452 [2] 810/19811/6
Exhibit 453 [3] 812/20813/6813/10
Exhibit 454 [2] 814/22815/5
Exhibit 501 [13] 887/16888/12888/19
898/14901/3913/9914/23918/19921/24
923/2926/9936/23955/12
Exhibit 502 [1] 932/3
Exhibit 503 [2] 1052/81052/12
exhibits [13] 766/24773/20774/22
808/14884/14884/16884/20884/21
885/19956/7956/101073/251075/25
exist [4] 806/17806/201058/161066/24
existed [2] 959/4963/21
existence [2] 782/16964/4
exists [1] 865/9
exit [1] 997/19
exited [9] 790/22817/15821/16850/22
910/16956/17979/151069/171073/6
exotic [1] 784/6
expand [2] 1015/181019/19
expanded [1] 776/13
expat [2] 1007/141034/7
Expats [1] 999/13
expect [1] 1064/10
expecting [1] 1031/25
expenditures [5] 820/23903/21937/1
937/2949/13
expenses [6] 895/10895/11895/12
1006/141016/31016/4
expensive [1] 1067/6
experience [11] 768/19770/2789/20
791/19800/25874/10883/5945/14966/10
966/11973/9
expert [14] 793/16793/18963/7963/11
963/12963/15963/18965/1965/3965/4
965/6965/10966/9967/2
expertise [2] 1056/11056/3
explain [17] 791/15791/19792/10
795/12796/22854/9855/10859/21859/22
891/16897/4903/2905/24908/8913/8
922/21037/6
explained [1] 794/23
explaining [3] 792/5794/20992/16
explanatory [1] 891/17
exploration [3] 1004/191021/22
1035/19
extract [2] 974/151035/17
eye [1] 872/22
F
F-1 [1] 987/17
face [9] 860/13869/5870/10870/15
879/6880/1954/61008/81018/7
faced [2] 1012/131013/15
facial [2] 870/10870/12
facilitate [1] 782/8
fact [17] 775/12775/14775/14775/22
806/22878/4880/3959/3959/4963/16
963/17964/5982/8991/20994/41036/12
1057/14
facto [1] 1070/10
facts [1] 958/4
factual [2] 957/22958/4
failed [1] 957/9
fair [12] 852/6856/25858/15858/16
888/16940/5941/1941/2942/14945/2
945/6945/15
fairly [6] 801/20811/3812/24815/1
931/21986/12
fairness [1] 781/9
faith [2] 824/11071/7
fake [3] 1051/61051/121056/3
false [2] 838/6959/6
falseness [1] 959/7
familiar [12] 768/25771/3771/14779/12
787/6908/2910/2915/2951/25963/19
972/131054/23
families [1] 853/15
family [8] 963/19964/8964/191000/25
1038/131038/131059/161059/17
famous [1] 1038/7
Fannie's [2] 785/9785/12
Fannie's Cabaret [2] 785/9785/12
FAPR [2] 763/201077/18
far [7] 917/2929/2932/12932/14942/25
1018/161072/17
Fargo [3] 886/2894/3903/17
farm [1] 1037/8
farmer [1] 1037/11
faster [1] 1036/4
father [1] 1002/2
FBI [14] 768/4768/8768/18768/24
770/22790/5811/1812/17812/18814/15
830/12859/5859/71032/6
FDIC [1] 775/21
fear [1] 892/16
feasible [1] 1013/16
February [19] 771/22779/22779/24
782/13783/7783/8783/9784/1784/2
785/8785/9785/10785/10834/25915/11
915/14916/13917/201050/25
February 13th [3] 783/9784/1785/9
February 13th of [1] 783/7
February 14th [2] 785/10785/10
February 15 [1] 1050/25
February 15th [2] 771/22782/13
February 16th [4] 779/22779/24783/8
784/2
February 7th [1] 916/13
federal [10] 775/20837/12840/1859/22
1042/211060/71060/141060/151062/12
1064/4
fee [4] 891/25891/251037/141039/8
feel [2] 1064/121074/4
feeling [1] 1069/3
feelings [1] 856/7
feels [1] 793/9
fees [2] 862/19862/20
feet [1] 1022/3
felt [1] 855/11
few [10] 768/17785/4841/2932/10
938/16954/17984/91001/231009/8
1040/13
Fiber [6] 802/17910/3910/5913/11
913/16919/2
field [1] 1043/19
fight [5] 859/14859/15859/231033/19
1033/23
figure [7] 894/10939/20954/11954/15
983/51007/221061/9
figures [1] 1053/11
file [27] 763/4980/22981/61021/3
1021/51021/51021/101022/171023/19
1024/191026/81040/151040/191041/4
1041/51041/61043/141046/161048/22
1049/151049/171052/231061/41061/16
1061/181061/221064/2
filed [41] 1/21/71/9776/20778/15783/16
789/3803/14809/25835/13836/6836/19
837/11837/13837/13959/14959/15
959/18959/21981/61021/71021/12
1021/251023/141024/41024/81024/9
1025/211025/221026/121026/20
1028/241034/81034/151038/151041/17
1043/171048/21054/211061/31061/22
filing [7] 776/25776/25777/12777/17
1046/61048/181067/7
filings [3] 776/14776/15776/22
fill [3] 1007/221043/191043/23
filled [3] 780/81055/11055/1
filling [1] 1007/12
final [5] 766/13824/171071/131071/13
1072/19
finalize [1] 824/19
finally [2] 890/2929/24
finance [1] 814/5
financial [13] 768/11773/3773/5775/18
783/14817/8820/16840/7863/13883/18
887/25888/4939/21
financials [1] 876/2
find [9] 774/1871/1895/3962/19970/17
1011/121056/111059/251075/4
fine [13] 820/5823/11850/4851/16
851/17854/1854/3860/11887/191009/20
1068/221068/221075/10
fine-tooth [1] 1009/20
finish [2] 1061/61062/22
finished [1] 989/10
FINLAYSON [5] 764/4764/5869/14
963/5982/6
fire [2] 1014/101068/9
firm [2] 768/21911/18
first [53] 767/15767/20773/2773/13
776/5788/17795/4806/2806/14816/19
816/20827/18830/9830/10843/22845/1
845/2845/6849/14851/13882/10882/15
889/9909/10911/19927/6928/16935/15
959/13963/13964/4968/3968/9968/14
971/2971/7971/8979/24983/23984/2
985/6990/19990/20991/25994/151002/4
1003/31009/81020/141020/191031/24
1076/41076/5
fish [1] 933/17
five [7] 821/22895/22929/15961/8978/1
978/21024/15
fix [1] 991/2
fixed [1] 993/3
flag [4] 796/25797/2804/7873/17
flags [3] 789/23873/16960/23
flee [1] 1033/21
Fletcher [1] 995/13
flew [1] 989/22
flight [6] 988/19988/20988/21988/24
989/181033/19
flip [3] 822/8887/12947/3
flipflop [1] 965/1
flood [1] 1068/14
floor [1] 938/22
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 332 of 359
F
Florida [4] 988/8988/9988/181068/8
flow [6] 875/25875/25883/19901/9
931/18931/22
flush [1] 856/21
fly [10] 988/25989/1994/20994/23995/1
995/24998/2998/251055/211060/19
Flydubai [6] 998/16998/23999/1999/4
1034/71044/18
flying [7] 797/14985/18989/19995/22
1003/241004/101024/14
FlyingJack [66] 797/14804/15804/21
804/25805/24806/15806/23807/2807/5
807/6807/13808/6808/8808/20816/8
841/10842/16842/16842/21842/21
842/25843/3843/15861/7862/8862/12
862/14862/23863/22863/23870/19
876/15877/6881/4915/23915/24916/6
921/11921/12921/13923/20927/1927/4
928/7930/2944/23955/5961/13961/15
1012/211012/231015/41015/61016/3
1016/61017/231017/241018/221029/25
1036/121037/171037/191039/10
1039/151066/241067/2
FlyingJack's [4] 864/6924/1925/12
927/22
focus [1] 1066/11
focused [1] 865/15
focusing [3] 857/6890/20891/13
folder [5] 1023/191023/201046/12
1049/51049/21
folders [1] 1049/21
folks [1] 1071/5
follow [9] 766/23772/7772/10772/16
773/2787/7843/4931/18945/5
followed [2] 785/21792/25
following [6] 1/1772/7773/11836/11
1024/131025/16
follows [5] 767/16882/11968/10971/3
983/24
food [1] 894/6
foot [1] 926/15
footage [1] 942/18
footer [1] 816/1
force [7] 859/12860/10860/11994/16
994/19994/211033/1
foregoing [1] 1077/12
foreign [30] 880/21880/22936/13
936/16940/15940/25941/5941/10941/21
949/6949/7949/20950/8950/9950/23
953/101000/31034/91034/191035/8
1042/41042/61042/81042/91042/10
1044/211059/201061/131064/11064/5
foreman [1] 1059/9
foremen [1] 1005/11
forensic [4] 883/1883/12883/12939/3
forgetting [1] 950/18
forgiveness [12] 838/4838/7870/22
1013/251014/11014/51014/61014/16
1019/131019/181066/11066/3
form [13] 829/8829/20834/19834/19
836/19837/11837/11847/13897/10
1052/21063/221064/171077/12
formal [4] 770/8770/23772/1772/4
format [1] 888/1
formation [1] 1064/16
formed [3] 770/12770/211003/7
formerly [3] 769/1827/3883/21
forms [6] 868/18868/22868/251055/19
1062/171064/16
formula [1] 838/19
forth [3] 892/171011/131015/25
forward [3] 856/191065/211068/15
found [7] 790/12849/7869/2875/21
970/81046/121051/20
four [14] 787/14788/16825/25890/15
957/20960/121016/191018/21024/15
1054/201054/211060/201067/81073/25
frame [1] 1064/13
Frankly [1] 818/17
fraud [25] 768/14768/15768/15768/16
768/16769/14776/14790/14794/17864/7
883/11938/4956/23956/23957/2957/8
958/16958/19958/21958/24959/6960/2
969/6985/22991/13
frauds [1] 957/19
fraudulent [10] 776/14776/15776/19
776/22864/4865/6959/9959/10993/6
994/3
fraudulently [1] 877/25
free [1] 1035/1
Freight [8] 804/15804/21804/25805/24
807/3807/6808/20877/6
Freight's [1] 797/14
freshman [2] 989/10989/11
friend [4] 973/251001/41024/14
1041/15
friend's [1] 1025/12
friends [6] 977/251016/241017/12
1057/131057/251058/1
front [6] 802/7813/12831/1831/3841/3
869/23
frustrated [2] 1011/241011/25
full [9] 1/8816/10900/5913/8918/25
925/24984/14984/151038/12
Fulton [1] 766/3
fun [2] 1033/41033/6
fund [3] 918/7950/231001/13
funded [2] 949/131030/13
funding [1] 908/23
funds [56] 790/6790/8797/3801/1
801/10808/1808/4811/13811/13811/14
815/14816/13816/13817/4817/5844/10
861/10861/15861/16862/21863/25864/9
864/15864/16876/1909/21917/6917/25
918/16921/22922/25923/16925/15
927/14927/21927/23931/18931/22936/1
936/3936/16949/17949/20950/3950/14
954/9958/9960/17960/20961/16962/1
1001/131012/121012/181030/61034/2
funneled [1] 961/19
funneling [2] 961/18961/22
further [11] 806/11840/19873/24878/7
881/17881/23970/21979/4979/5993/20
1040/4
Furthermore [1] 958/9
G
G-A-L-A-M-S-E-Y [1] 973/4
gain [1] 1012/6
Galamsey [14] 966/20966/22966/23
973/2973/3973/3973/4973/5976/5976/8
976/10976/15977/9977/15
gallery [1] 1004/22
gander [1] 966/5
Ganek [3] 915/15915/19918/17
gap [1] 957/25
gated [1] 827/8
gather [3] 871/9940/1940/2
gave [15] 770/25941/20947/10947/13
1008/121008/131022/241023/11023/1
1038/31038/61065/91066/101067/9
1072/22
Gene [3] 780/18873/8964/23
General [1] 776/6
generally [2] 894/171074/6
generate [1] 1012/11
generated [2] 1051/151055/1
generating [1] 1051/13
generic [1] 969/25
geographic [1] 1061/15
geographically [1] 814/17
geological [1] 972/9
GEORGIA [52] 763/1763/22766/3
770/11770/13770/16770/17770/21771/2
779/8779/13779/15779/16782/22782/23
783/12783/18784/4785/9785/11785/12
785/13785/13785/15785/15785/16
799/16799/17799/19799/19802/17
804/15804/16807/14810/11810/12812/6
812/7813/25814/19814/20827/6827/21
828/14828/22841/8841/9968/251025/12
1047/61052/241077/6
get [106] 770/4770/20794/23810/4
817/21819/19819/24823/14824/9846/4
846/17851/3851/11852/7852/19854/10
855/21855/25856/16856/19857/23
858/21863/13865/11869/6869/22874/19
878/3878/4878/4885/20891/18898/2
911/7911/15911/20913/8931/8931/8
931/11931/13933/24937/12937/14
952/25956/15956/22958/4966/1967/22
974/16974/17977/23981/2983/11989/12
993/8993/22993/22997/201006/15
1008/221014/161017/111017/12
1017/221017/241020/241022/11
1023/171024/161025/31025/101027/2
1027/31027/41027/161032/81032/8
1032/111032/121035/31035/131035/17
1036/191036/251037/121038/25
1040/191041/31041/71042/131042/13
1042/131043/61044/181044/191046/4
1052/171055/121055/131056/251062/4
1062/51068/251073/21
gets [11] 863/8898/1898/25900/16
905/15906/18921/13954/18961/21
974/101062/8
getting [6] 877/13900/2913/61012/21
1040/141068/3
Ghana [54] 963/18963/19964/4964/12
967/7970/18971/15971/16971/23972/10
972/11972/13972/16972/17973/14976/4
977/10977/11977/12977/17978/1978/7
978/9978/10987/16987/20987/25988/3
990/24990/251001/41001/241002/2
1002/211003/211004/151005/71013/5
1013/51014/241016/121016/131016/14
1016/151016/161055/51055/61058/22
1058/251059/171059/231060/61060/7
1060/8
Ghanaian [1] 1007/8
Ghanaian-based [1] 1007/8
Ghanaians [1] 974/23
gist [2] 939/25957/4
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 333 of 359
G
give [33] 795/5821/19822/11824/3
824/4854/8856/21857/14866/14866/17
893/22911/21932/19939/22950/5966/2
977/11977/25979/121008/161009/2
1009/41012/161014/131028/181028/19
1037/131047/181048/141058/24
1071/231072/31075/24
given [9] 769/19770/9832/16940/18
962/101014/21025/231041/221060/19
gives [2] 892/7919/2
giving [5] 866/12897/7998/41013/24
1033/13
gladiator [6] 818/18827/1869/11869/12
870/1870/9
glasses [1] 885/20
global [4] 768/21919/21920/2920/5
gmail.com [1] 779/11
go [160] 766/13767/4772/8772/9775/15
775/25786/20788/18788/21791/8796/3
796/23796/24802/24804/6818/19820/12
824/24825/9826/5832/10832/18833/12
835/2835/19835/24836/16837/2837/15
839/8842/2842/18845/24846/13846/22
849/18851/22853/21853/22854/5854/8
856/2858/7858/8865/20866/2867/12
875/3875/5875/6877/1877/3883/16
885/22888/19890/9894/24895/15896/21
897/2898/14898/15898/21899/3899/14
899/14901/3901/3901/6902/2902/24
904/14905/5905/6905/21906/16907/25
909/7909/10911/25913/2913/22914/13
914/23914/24915/8916/1916/9917/14
917/15917/24918/19919/7919/19920/8
921/8921/9921/17921/24922/12922/20
923/2923/3924/9924/19925/18926/9
926/9926/10926/21926/24927/5928/3
928/9929/9934/3938/12939/8939/23
940/1940/1940/20942/22951/4951/20
952/24955/12967/22974/2978/13984/25
988/5988/7990/10993/17997/24998/1
998/13998/23999/251005/141011/2
1016/141017/31023/81025/101025/11
1044/11045/71048/151054/181056/19
1061/101061/111062/11063/111065/21
1073/81074/231075/2
goal [3] 824/16998/11004/20
goes [29] 845/7845/9862/6863/22
864/21864/23898/3899/8900/1900/8
901/10901/11901/12901/13904/25
905/15915/10923/12930/13930/19
935/20936/4945/24951/1954/18974/10
1044/161048/191074/7
going [184] 766/9766/10766/25768/7
769/18771/6781/25789/23792/9793/6
793/22793/23794/5795/4795/12796/12
797/2803/22810/9817/18818/8818/19
819/4819/4819/16819/17821/4821/7
821/18821/19821/19821/22822/7822/11
822/25823/2823/3824/10824/18832/3
833/11841/2843/6846/8846/11846/13
851/9852/21852/22852/23853/15853/18
854/8854/10856/20857/11857/14858/19
872/12874/24879/10892/17893/16
900/22901/9901/15901/21902/22902/22
904/1910/12910/18910/21911/9911/11
911/23912/8912/9920/16921/11922/12
922/23925/1930/7931/5933/17934/15
934/21934/23935/1936/24937/7937/22
953/11954/9955/18958/21962/17962/20
964/3964/3964/7964/11965/5965/6
965/8965/9965/13965/15965/18966/10
966/20967/5967/16967/18973/17975/17
975/25978/6979/10979/11979/12979/19
980/6980/10981/22982/24983/2983/4
984/9990/10990/21993/20993/22994/19
996/12999/171001/21003/131004/15
1010/11011/131012/41012/81012/9
1012/101013/141013/151015/231016/8
1017/51018/211019/171019/181019/22
1022/81026/61032/21032/111035/9
1037/131037/241040/131041/61042/22
1043/11048/111049/231060/21060/15
1063/71068/151069/11070/251071/13
1071/231072/31072/41072/41072/13
1073/21074/61076/111076/12
gold [19] 964/14972/15974/9974/10
974/13974/15974/16974/171002/17
1002/171004/211005/11006/141017/21
1027/181028/11035/151035/171036/4
goldmine [2] 972/17972/18
goldmines [4] 771/3972/13972/16
972/19
goldmining [3] 771/1972/21972/23
gone [3] 908/10931/16953/20
good [32] 767/10768/2768/4819/12
819/23820/21820/24823/11824/1841/1
867/21891/23910/6910/10912/22938/13
938/15949/17966/4967/20975/11975/12
979/23983/14984/81022/101040/8
1057/111068/251069/111071/71072/17
goods [5] 1015/101037/11037/14
1038/81038/12
Google [1] 1056/9
goose [2] 966/51059/20
got [98] 773/5773/9786/7786/22792/10
792/10792/11792/13792/14812/6819/2
819/2821/2821/12825/13828/17845/18
846/4846/7856/7856/18856/19857/11
857/22859/16864/23868/4870/7892/10
902/7910/20911/15914/8915/11917/4
933/19938/16943/17944/2944/3945/1
945/15946/21955/6957/15962/22965/11
977/19982/6982/17986/2988/23989/11
989/12989/13989/17990/16991/5991/13
991/15991/25992/8994/1994/4994/14
997/25998/3998/251000/181004/17
1005/31008/111011/181012/251020/24
1025/161026/211028/181028/24
1030/121030/121035/141041/13
1041/201048/251051/31052/181057/3
1057/151057/181057/201057/221058/3
1059/171066/201066/241069/21070/1
gotten [4] 861/10921/11041/101047/24
government [28] 767/12773/20777/8
793/13796/1802/12808/14827/17830/21
841/17844/25852/2854/10857/14884/17
885/12956/10956/21958/14958/16
960/13962/3980/5982/9982/91030/6
1034/141071/9
government's [60] 771/7774/22777/7
778/25781/16782/18784/9786/4788/12
789/11789/12797/17798/10798/15799/6
801/18801/24802/4803/11804/9805/3
805/14807/8808/23810/19811/6811/20
812/20813/5813/9813/19814/22815/4
815/18816/14825/3828/1828/7830/2
831/4831/23834/11839/8851/24851/25
852/3874/14876/17884/20885/1886/16
887/16888/12917/15932/31011/22
1050/111052/71052/121075/11
government-issued [1] 830/21
Governments [1] 885/23
grab [1] 962/25
grace [1] 1012/12
grade [2] 1016/161016/23
graduate [1] 988/12
graduated [1] 988/16
grand [1] 939/23
grandpa [1] 1000/1
grant [1] 818/8
granted [1] 991/6
graphic [1] 931/19
great [3] 955/201000/11076/7
green [4] 933/10992/12992/12993/1
Greythorne [14] 799/15799/21801/21
802/8807/13807/20809/12813/25828/14
908/3908/11918/24936/81058/15
Greythorne Lane [11] 799/15799/21
801/21802/8807/20809/12813/25828/14
918/24936/81058/15
ground [9] 857/11860/13860/18879/7
880/11032/81032/81032/111032/12
Grounds [1] 850/17
Group [2] 913/15913/19
grouping [1] 792/2
grow [2] 972/11987/15
guess [17] 781/5781/23842/10843/23
844/21844/25854/7856/4862/19871/10
874/16878/15910/23991/231063/22
1063/231064/10
guessing [1] 910/24
guide [1] 973/9
guidelines [1] 969/5
gun [2] 850/12860/3
guns [10] 850/6850/8851/1853/7855/8
855/12878/20879/25880/16880/18
guy [9] 792/24945/16959/22966/10
1001/141004/61010/171017/251032/22
guys [16] 849/15849/17853/6858/13
867/22880/8910/17938/21939/16974/20
974/24974/25977/22993/231034/16
1040/7
GX [1] 787/10
gym [1] 1023/9
H
Hackman [3] 780/18873/8964/23
had [189] 770/13771/20771/21773/6
773/23780/11782/16783/15783/16786/2
787/2790/3807/3827/23832/24834/5
834/22838/17839/18840/9841/20844/24
845/24849/12849/19849/25849/25
849/25850/14851/13856/8859/1859/5
859/5859/6859/6859/19860/9860/10
860/21861/6861/17862/10862/16862/22
865/4868/23870/14870/18871/9873/15
876/12877/9877/16877/19880/8880/24
881/22883/24884/3890/18894/17894/19
900/21905/2914/7917/7921/1921/1
924/1925/21929/4930/21936/23943/6
943/12943/15943/19944/23945/4949/17
951/3954/9954/21959/22961/5963/25
965/20965/20966/13970/6970/7980/5
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 334 of 359
H
had... [96] 980/18981/6982/13985/17
985/19986/1989/7989/18990/15990/22
991/9991/16992/2992/7992/13993/12
995/12999/251000/91000/131001/4
1001/101001/111001/131002/17
1011/181013/81013/101014/31014/9
1014/111014/121014/131014/141016/2
1016/41021/191021/201022/121022/24
1023/131023/211023/241024/81024/17
1024/221024/231025/11025/21025/11
1025/211025/221026/201027/18
1027/211028/251029/11030/181032/3
1036/61036/181038/171041/41041/14
1042/11043/41043/101043/191045/2
1045/31045/91045/111047/241049/15
1049/171057/141057/231057/251058/1
1058/81058/111058/141058/151059/9
1059/131061/231062/81062/171063/1
1066/61067/91067/141067/151068/9
1070/201075/5
hadn't [3] 1015/31061/211061/21
half [10] 769/21770/2806/10806/10
862/2883/3939/2998/251002/191030/16
halfway [1] 927/5
hall [1] 962/25
hand [6] 771/11803/13830/11974/18
986/41019/22
handful [1] 780/15
handguns [1] 859/5
handled [1] 776/16
handling [1] 1058/4
hands [2] 940/4974/19
handwriting [1] 942/23
hang [3] 817/19818/6886/9
hanging [3] 818/7818/11818/13
happen [8] 857/22897/14902/18
1002/121021/161038/11076/111076/12
happened [28] 851/4853/11859/9897/4
906/18919/14919/16934/7935/18939/20
941/20981/20982/13990/141002/13
1002/141002/241003/31011/71011/11
1011/171014/101025/91028/231034/6
1038/81040/201041/9
happening [2] 1001/31072/7
happens [11] 791/20859/11898/25
905/16905/17906/3908/18908/21931/4
935/81039/6
happy [3] 851/7879/11069/6
hard [5] 843/4843/4843/6960/81076/1
has [47] 1/7792/2796/15805/11807/23
822/14846/4848/10891/21895/21895/23
905/10905/12930/4944/21944/23954/3
956/21957/23957/25958/16963/9963/9
964/9965/16966/19967/10973/25988/23
992/2993/16993/241008/181012/13
1027/11050/41050/71054/171055/25
1064/201070/161070/241071/31073/23
1074/71074/91074/12
hasn't [2] 805/18958/1
have [387]
haven't [9] 823/21958/1959/13959/14
959/16959/161026/211039/241060/25
having [16] 767/15818/13855/8866/12
882/10960/10968/9971/2977/6977/7
983/23993/191007/161018/41025/8
1037/21
Hawks [1] 998/2
Hazel [1] 1074/1
he [326]
he'll [2] 967/141001/15
he's [49] 769/4781/9787/4791/7792/3
792/5792/9793/10793/19794/8795/12
818/7819/10851/2851/3851/3852/5
853/1853/9853/9853/24854/21854/23
856/9856/17867/12870/14875/18875/18
912/12953/9960/5961/12961/13963/16
963/18964/3964/3964/7964/11965/5
965/6965/10965/11966/9967/18975/22
975/25976/3
head [6] 816/22846/25853/4853/13
854/221033/18
headquartered [1] 770/20
headquarters [1] 998/9
health [1] 1013/6
hear [15] 822/12823/22832/9832/10
832/22833/4833/12874/24959/21972/7
984/121024/91025/141072/41072/19
heard [41] 790/24791/3823/21866/3
878/12878/17941/4959/7960/22961/18
964/1965/24965/24975/16976/12976/18
976/23976/25977/1977/5977/6977/6
977/10977/24990/7996/141006/23
1009/141009/161010/31011/201016/10
1018/41027/101031/211035/241036/10
1044/31050/211056/151071/4
hearing [5] 855/171045/251058/12
1058/131077/11
heavy [2] 974/7974/9
held [4] 926/251015/71038/161077/8
helicopters [1] 998/2
help [17] 782/8786/6787/7832/9872/11
872/14931/171001/161002/161008/9
1008/111008/131008/201010/19
1010/201022/201022/22
helped [2] 1010/241010/25
helpful [1] 888/24
her [54] 871/10871/11871/11872/5
911/25912/1933/14943/1946/13946/14
946/191001/41008/201009/41010/7
1010/81010/91010/91010/191010/19
1010/201010/201010/221010/22
1010/241010/251022/31022/241023/1
1023/51023/121023/151023/181024/9
1026/41026/51026/51026/81046/4
1046/51046/61047/141047/231048/5
1048/61055/71056/11056/21056/3
1060/221063/131063/131069/51076/4
here [63] 786/7786/22792/12796/12
801/3806/11810/10817/17853/6854/4
854/23856/2856/19882/23883/16893/10
896/23901/7904/5912/11913/8915/5
918/22921/19925/8933/14935/9936/13
937/22939/20940/9940/11940/13957/23
958/15960/21962/17965/1965/17967/18
971/25975/13975/15975/22975/24
976/18977/18990/191004/211004/22
1016/81044/41055/41055/101055/11
1055/171056/101056/151057/13
1066/111069/131069/251070/4
hereby [2] 775/211077/6
herein [5] 767/15882/10968/9971/2
983/23
hide [8] 842/7842/10844/21844/22
985/201039/141039/141039/22
high [1] 985/10
highlighted [7] 821/23822/14822/19
822/20823/181070/161070/23
highlighter [2] 932/21932/22
highlighting [4] 981/71070/211075/25
1076/3
him [92] 785/20785/23791/13791/18
792/23792/25793/23795/4819/6827/15
829/2829/15834/4841/23843/23843/23
849/10849/14849/15851/9852/19853/18
854/12854/14854/25855/2855/8856/19
857/16859/16859/19859/20859/20
859/22860/12860/16866/2866/9866/17
866/19867/6867/23870/17871/7874/9
875/13875/15877/8877/15877/18878/21
879/6879/6879/14879/14937/10960/25
963/15966/19967/2967/5967/18975/23
976/3976/23976/25977/6977/6977/7
978/17979/201002/171013/71016/12
1016/131016/141016/151016/19
1017/161017/171018/151018/17
1018/171027/161027/201027/20
1027/251033/131038/111038/19
1040/251059/19
himself [1] 961/9
hired [6] 976/18977/41038/71038/11
1038/191056/2
hiring [1] 998/5
his [91] 783/14783/14783/19791/19
794/20795/4795/16795/19802/25803/3
803/6816/8817/5817/16818/2827/22
829/2829/16834/9838/3838/9838/16
839/3839/6839/17839/20839/22840/12
842/10842/13842/17843/25844/5844/8
847/10851/8855/16856/8860/16865/7
869/5869/14870/10870/10870/15871/1
875/18875/20875/21876/24879/2879/2
879/5879/14880/6880/6880/6881/8
881/9907/5907/6920/21920/25921/1
921/3943/7943/8943/11943/23943/25
945/4945/11945/24945/25946/2959/18
962/5963/10964/6964/23965/16966/10
966/10966/11966/14966/141001/8
1004/51017/121017/251038/17
hit [3] 933/16949/101006/17
hits [1] 970/1
hitting [2] 933/11048/21
hmm [137] 833/13833/16883/23886/22
887/6887/9888/22889/11889/19890/25
892/23893/1894/16895/2895/25897/25
899/2900/14900/20901/17901/20901/22
902/15903/22909/5916/12916/14917/11
918/5918/8920/12921/21923/24925/7
925/11926/6926/20926/20930/5930/18
933/23934/10934/12934/22937/5937/11
937/13939/13941/7946/5946/12947/16
948/3949/9950/4950/6950/19950/21
950/24952/4952/17953/23954/13955/16
955/24989/25990/2991/24994/10
1009/231010/21011/31011/211013/4
1013/201014/231018/231019/231020/3
1020/51025/71027/241029/191030/24
1031/161033/31033/81034/31036/11
1037/251039/181040/121042/16
1042/181042/241043/21043/111043/16
1044/51045/61045/191046/81046/10
1050/31050/171050/191050/221051/5
1052/111052/151053/221053/24
1054/161057/191057/211058/211059/5
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 335 of 359
H
hmm... [20] 1059/71059/101060/3
1060/51062/161062/251063/191065/11
1065/161065/181065/201065/23
1066/151066/171066/191066/21
1066/231067/171067/191067/21
hold [13] 794/14817/12849/10867/19
867/19879/20933/16957/11972/4978/17
983/11011/131072/1
holding [4] 892/81012/21012/51012/11
hole [1] 974/2
Hollywood [3] 780/17780/18780/18
Holt [7] 804/14915/3915/16915/20
918/18919/1936/6
Holt Drive [6] 915/3915/16915/20
918/18919/1936/6
home [10] 853/15908/17908/20908/23
1023/101024/71025/111025/131025/16
1073/3
honest [1] 1033/1
honestly [2] 980/71009/11
Honor [73] 767/6775/6790/16796/2
803/21817/10819/17823/1823/5824/15
828/3829/24832/14850/24873/22873/24
885/4886/15887/18888/11888/18912/4
913/3932/2949/3953/9956/6956/9
956/11956/19958/12958/15958/20959/1
959/24960/14962/5962/22963/2964/21
964/25966/17968/1970/14970/23970/24
975/8979/5979/18980/16981/18981/21
982/7982/11982/18983/5983/7983/11
983/19986/14986/171019/241040/4
1040/61063/91070/51070/201071/2
1071/111072/81073/201074/131074/22
honorable [2] 763/11997/20
honorably [1] 997/21
hopefully [1] 889/1
hour [6] 821/24910/21911/10911/16
1011/141035/23
hours [2] 976/11056/16
house [40] 770/21807/21810/20839/18
841/24842/10842/11864/14864/15
864/25872/12872/14875/17878/23908/3
909/4949/23950/16961/6999/91010/19
1010/201017/11017/51022/251023/12
1023/141029/181029/211046/11
1046/161046/191047/51047/61057/14
1057/231057/231057/241058/21058/18
housekeeping [1] 956/12
Houston [6] 995/13996/131024/4
1046/211046/241047/1
how [129] 766/10769/9769/9781/2
783/13788/4790/6791/12791/15791/20
792/10792/11792/15808/12816/22821/1
822/3831/9834/7834/15834/21838/16
838/17839/18840/25849/19852/8853/4
854/14856/7866/9867/22875/9875/22
875/22877/9877/15883/2893/22896/3
901/9904/16911/7917/1935/13937/14
938/14938/15939/1954/15961/19961/21
966/21967/9968/19968/21969/21969/24
970/3970/4970/4973/3973/11973/14
973/19974/4975/17975/17975/24976/25
977/9978/11983/6984/7989/1990/3
990/14991/13991/22992/11992/16
992/25994/20994/23994/23995/1997/16
998/19999/151005/91005/171005/21
1006/121006/121006/151007/21
1007/221007/221007/221007/241010/9
1015/201017/31021/51021/161022/8
1022/221022/221023/171024/211027/6
1028/81028/121029/71032/151034/19
1034/251035/131035/221036/191038/1
1044/131047/141053/231056/81056/12
1056/131069/91072/1
however [4] 1/81007/191063/12
1063/24
huh [12] 903/25907/9916/7924/17
931/10931/12934/20936/18936/22951/6
953/51040/18
huh-uh [9] 903/25907/9916/7931/10
931/12934/20936/18936/22951/6
hundreds [1] 840/11
hunt [1] 1059/20
hurricane [1] 1068/13
husband [2] 1046/51055/7
I
I'd [3] 775/10784/71040/21
I'll [20] 766/16769/14774/3774/4795/5
803/23839/4939/17960/14961/10975/16
999/251021/231023/81027/21034/10
1037/61056/91075/71075/22
I'm [139] 766/9766/21768/4771/6
781/22782/1784/15786/9791/23793/22
793/23794/5795/4795/14796/11797/23
797/25799/5801/17803/22805/9808/4
809/4810/18817/17818/10819/4819/4
819/12819/14821/18821/19821/19
821/22822/3822/11823/10824/17825/13
830/16833/11841/2843/6843/9843/11
848/19848/19848/19851/18851/18
851/21852/12854/1854/6854/8854/10
856/20857/6857/11857/14858/7858/8
866/5869/22880/16881/1883/11896/14
905/21910/24916/9916/18916/18921/3
921/8921/20922/12933/17936/14939/7
943/17947/7948/22949/25950/17953/11
958/21959/8962/20964/1966/4966/23
967/1967/5967/16968/20971/21976/2
976/22982/24984/9987/5990/4999/17
1004/121004/141007/141012/241016/8
1019/221022/61022/71032/91040/13
1042/31042/31042/101044/131048/11
1050/11050/11055/201055/231060/2
1060/91060/181063/41063/71068/18
1068/221068/241069/11069/31069/18
1071/231072/31072/41073/21074/4
I've [35] 768/10786/7786/22790/13
793/7821/2821/21822/10822/22823/18
823/24824/6832/15856/19883/7895/20
933/17933/19938/16962/16962/17
962/22963/16976/10977/1977/19986/4
994/51009/161026/221026/231057/7
1074/101076/11076/7
ID [3] 828/8828/15993/14
idea [6] 860/9893/22965/131004/18
1013/81046/2
Ideally [1] 976/1
identical [1] 1054/4
identification [6] 782/10786/3801/18
805/3826/1827/15
identified [14] 769/6777/1815/22
816/12859/4859/7860/14860/24861/1
884/14900/15925/9936/12955/8
identify [7] 773/9773/17774/20778/5
778/13865/8876/10
identity [9] 943/25945/10946/1959/13
959/17960/16985/201030/251039/14
II [1] 922/8
illegal [2] 973/2973/18
illegally [1] 861/10
illuminate [1] 857/15
image [2] 856/9896/24
immediately [3] 830/20900/23901/10
impact [5] 1003/21003/101003/16
1003/191035/18
impermissible [1] 961/17
implies [1] 1074/17
implore [1] 1056/9
import [1] 1004/21
important [3] 796/11796/13990/1
Imports [4] 919/21920/2920/6922/8
impossible [2] 1051/91052/20
Inc [1] 926/3
incident [1] 859/10
include [9] 892/17893/20980/12980/15
980/17981/14982/91015/181019/20
included [9] 768/14800/22800/25
822/19839/13847/5847/23895/20
1074/20
includes [2] 814/5874/25
including [3] 854/11884/21900/4
income [21] 820/17838/23839/1929/5
960/10963/251012/111034/91035/5
1035/81041/111042/41042/61042/8
1042/91042/101044/141044/201044/21
1061/131064/4
income's [1] 1064/5
incoming [5] 877/6928/11928/16
936/12936/16
incorporated [4] 797/15806/22842/24
1036/12
incorporation [6] 771/11771/13771/23
804/24805/24843/1
indeed [1] 887/13
INDEX [1] 764/6
India [1] 1024/15
indicate [4] 822/11838/22843/1925/1
indicated [7] 847/9861/2898/1900/21
924/1936/23963/9
indicates [3] 778/1789/19869/16
indicating [4] 806/11924/15925/8953/9
indicative [1] 840/13
indictment [1] 775/17
individual [6] 796/9796/9796/25797/2
945/21966/19
individual's [1] 917/22
individually [1] 928/14
individuals [2] 954/4963/6
Industries [56] 770/10770/23770/25
771/23778/21778/21779/7780/11782/24
787/14788/9788/16789/7789/8789/8
789/10798/12798/14798/24800/19
809/17825/23826/1833/24835/13835/16
836/6836/8836/19836/22837/14845/1
845/4845/10871/16876/11876/15877/9
881/4889/23891/2898/12904/22944/16
944/19976/6976/9976/13999/181050/24
1051/81051/111051/231054/61059/4
1068/15
Industries' [5] 778/17787/22790/2
796/6896/8
industry [2] 779/91036/21
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 336 of 359
I
influxes [1] 840/16
informal [1] 818/24
information [70] 773/6778/9778/12
782/9790/19791/2807/12838/6851/6
878/3888/1888/8889/3890/6897/7908/5
913/7913/21916/22921/1922/14925/5
941/19962/10966/21993/16993/25
1023/151023/171023/181023/20
1023/231023/241023/251024/51024/5
1024/101024/111026/161026/211027/1
1043/251044/151046/11046/251047/11
1047/121049/201049/201049/22
1050/231055/131055/141055/15
1056/231057/11057/21057/41057/6
1057/111058/91058/111058/161058/24
1059/31059/141063/21063/211063/23
1071/24
informed [1] 875/13
inherently [1] 857/5
initial [7] 852/25853/2890/5904/2
932/14954/101067/5
initialed [2] 831/11831/11
Initially [2] 876/71001/20
initials [2] 800/5831/12
input [3] 1043/251044/141044/20
inputting [1] 1035/20
inquire [1] 1003/4
INS [1] 992/16
inside [1] 827/10
insinuating [1] 1043/7
inspect [1] 1032/2
Inspector [1] 776/6
Instagram [3] 986/7986/22987/3
instead [4] 893/25900/24924/21052/21
Institute [4] 972/5972/8988/8988/18
instituted [1] 772/12
institution [2] 773/3775/18
instruct [2] 794/7988/25
instructed [1] 980/21
instructing [1] 994/15
instruction [13] 795/5795/20795/24
804/5822/14822/18822/22823/14823/24
824/3824/5832/151073/3
instructions [18] 766/9766/14821/21
822/11822/24823/15824/11824/19
910/19910/25912/17914/3960/15962/17
1060/241069/231072/191075/6
instructor [2] 995/14996/20
instructors [3] 989/181038/31038/3
instrument [2] 989/12989/12
insufficient [7] 957/7957/18957/21
957/22958/4958/8960/2
insurance [8] 775/20862/161016/1
1016/21030/21038/101038/191067/11
insured [1] 775/20
intend [3] 963/151061/41061/22
intended [6] 870/21958/10962/3
1064/111064/131064/17
intent [13] 957/1957/8957/19957/21
958/15958/24960/2962/3962/121007/2
1007/41019/51019/7
intention [2] 857/3997/25
interaction [1] 874/12
interest [6] 769/23892/6892/8907/15
917/6917/7
interested [1] 994/19
interesting [1] 780/21
internal [2] 776/9899/7
international [2] 876/9876/10
Internet [7] 769/16769/17770/11770/14
903/10903/131067/11
interrupted [3] 833/121063/101063/11
interrupting [1] 821/7
interview [21] 830/13830/19831/7831/8
831/16838/3839/3839/6839/18847/9
853/5857/10866/6872/17877/14879/9
879/15880/4991/4991/51031/21
interviewed [7] 834/4853/1870/17874/9
875/151033/71033/10
interviewing [2] 879/14881/19
interviews [1] 1022/4
intimidated [3] 855/11855/19857/9
introduce [1] 1001/15
Intuit [4] 1044/31044/121044/161048/9
invasion [1] 974/24
invent [3] 1041/61041/181044/6
invest [1] 1014/15
invested [1] 1002/18
investigate [2] 843/14939/8
investigated [2] 790/6793/7
investigating [2] 769/12790/14
investigation [36] 769/11770/8770/23
772/1772/4772/25773/17774/9774/19
776/3776/4776/7776/12776/13776/14
776/24778/7782/9783/11787/6788/6
790/12795/16799/1801/16801/20804/21
805/23815/13815/22843/13843/18861/7
883/25969/11969/21
investigations [1] 803/18
investigative [2] 776/3776/9
investigator [3] 883/13968/20969/7
investment [1] 768/16
investments [7] 995/15995/16995/18
995/21996/3996/21997/14
Investors [1] 972/10
invite [1] 776/11
invited [3] 776/2776/5776/8
invoices [1] 1020/9
involve [1] 954/23
involved [5] 769/9843/7884/15891/9
1003/24
involves [1] 838/20
involving [2] 768/25883/21
IP [16] 776/23776/24777/1777/2777/10
777/13777/16777/19777/24778/1778/5
778/7778/8778/14778/19959/22
IRS [65] 776/18782/12783/2783/17
789/2799/4808/5811/15815/14834/20
836/6837/12840/14848/23861/10862/5
864/9878/3878/4904/7904/12905/8
905/15906/7907/2907/7914/11916/4
916/15916/20916/24917/5927/18927/25
929/2931/2931/11934/25936/19938/1
950/25953/6953/19955/91027/21028/19
1028/241034/231035/11040/251041/3
1041/71041/151042/191044/161050/2
1051/91051/141052/201053/161053/19
1061/91061/111061/141074/1
is [726]
Isaac [1] 781/3
ish [1] 819/16
isn't [4] 853/3932/19960/61000/4
issue [22] 767/3773/2792/20804/4
823/18826/14826/18850/23854/2856/16
881/3918/1960/16965/17965/19980/1
990/81045/241060/211066/31070/10
1073/20
issued [26] 782/12789/2830/21845/22
846/9846/10846/10859/5859/5880/24
881/8904/18935/5953/3990/221003/6
1024/191024/201025/181025/241026/1
1049/71049/81049/101050/81051/9
issues [2] 824/12917/24
issuing [1] 917/23
it [842]
it's [189] 772/7772/16772/16775/19
778/8778/9778/10779/24787/21788/19
789/21789/23790/9790/9790/19791/2
791/2791/7791/8791/14791/18791/18
791/21792/12793/8795/22796/14796/16
796/24799/10799/10803/24805/24806/6
809/2812/6813/8816/1816/1817/13
817/19817/23818/1818/3818/3818/4
818/5818/7818/8818/11818/21819/21
820/5820/6820/8821/2823/3823/19
825/6825/6825/10825/21828/5828/17
830/1832/2833/14834/19835/12835/12
836/5837/11837/13842/13845/14846/7
846/7846/9846/11846/13847/24848/21
849/1851/9851/15851/17851/25852/5
852/6852/8852/16852/22852/22853/3
853/5853/9853/18854/3856/12856/25
859/3859/11863/12863/14863/15863/25
863/25864/3864/7864/7864/9868/3
869/5869/23871/3872/19874/22875/24
877/2886/18897/15900/25908/18911/9
914/4920/13921/5925/9930/9931/3
932/5932/25945/4945/11945/12945/15
945/20947/1951/14953/11955/8960/15
961/22964/7966/4967/4968/15978/6
983/8983/9993/15995/7995/7995/7
998/17999/211004/81005/51007/16
1007/191018/201023/181036/23
1036/241039/191040/21042/251044/17
1044/171048/131048/181049/21052/4
1052/61055/31056/51056/71056/15
1058/121059/191060/111063/51066/3
1066/91067/251074/171076/21076/4
1076/5
it's -- it [1] 842/13
Item [1] 865/15
items [7] 839/23840/9884/21886/24
950/151029/211045/23
its [4] 806/23807/3954/6961/25
itself [5] 774/25880/15897/15952/19
1034/16
J
jail [1] 881/10
JANA [3] 763/201077/41077/18
January [18] 769/11769/13771/13826/9
826/13834/25889/25890/1891/5891/7
894/10919/22920/1920/18921/51040/20
1041/241061/3
January 2022 [1] 921/5
January 25th [1] 889/25
January 28th [1] 826/13
January 4th [1] 771/13
Jared [1] 1004/24
Jason [2] 780/19780/19
Jewelers [1] 785/11
jewelries [1] 1004/23
jewelry [4] 1004/221004/251005/1
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 337 of 359
J
jewelry... [1] 1005/2
job [12] 819/7911/24945/5969/4982/2
993/17994/15995/10995/12997/12999/1
1076/7
jobs [2] 994/131022/12
John [5] 873/10873/11943/211009/14
1009/16
John Snow [4] 873/10873/111009/14
1009/16
join [2] 776/3776/11
JPMorgan [2] 775/17934/1
judge [8] 766/21861/2912/10949/1
970/12975/61038/171076/4
JULY [7] 763/12766/3803/14836/3
1020/111020/121077/8
July 29th [1] 803/14
jumbled [1] 1033/18
jump [2] 788/20957/25
jumped [3] 873/12873/13927/2
juncture [1] 963/15
June [4] 799/12835/13889/131052/25
June 1st [1] 889/13
June 2nd of [1] 799/12
junior [1] 989/14
juror [1] 1069/5
jurors [19] 767/8790/22795/3817/15
820/10821/16824/23850/22858/6882/21
910/16912/25956/17967/24979/15
983/161069/171072/111073/6
jury [42] 766/8767/4794/7805/10806/10
815/9818/5818/11819/5821/18821/20
823/7823/9823/20824/18824/21831/20
832/12850/19854/17857/8866/23869/22
893/22898/17912/11912/17931/19
939/23956/22958/5958/23960/15962/8
962/8962/17962/19967/19990/14
1068/221069/221075/6
just [204] 767/1767/3767/4768/17
769/23770/18772/7772/10774/3782/19
783/3785/4787/3787/24787/25789/4
789/15790/9790/20791/7791/8796/12
799/22801/12802/24805/10806/1806/9
806/10806/11806/17807/21812/23814/2
814/5814/6814/25815/12815/15816/21
818/3818/4818/4818/15819/19820/4
822/8822/13823/1823/3823/7823/19
823/20823/22823/23825/1831/24833/18
835/2837/15839/22847/18851/16852/5
853/11853/17853/18855/24856/18857/2
857/22860/22866/3866/14866/15866/17
869/19869/21871/20874/16878/12
878/17878/23879/19880/24885/4888/3
890/24891/16892/3893/14894/1894/3
894/4894/13897/24901/6906/6911/14
912/10913/5913/7914/19917/6925/25
926/15932/9933/8933/16934/11938/16
942/14943/12944/9945/23946/16947/7
947/13947/14953/2954/1955/11956/14
960/15961/18961/20962/25963/17
963/21965/6965/21967/4969/25976/2
978/16980/3980/7980/22980/25982/1
982/15983/4992/7992/171000/23
1000/241003/41007/241007/241007/24
1007/251007/251008/11008/61009/8
1010/241010/251011/191013/131015/6
1019/181020/231025/81027/21031/25
1032/41032/61032/61034/101034/23
1035/51036/231036/241037/41040/14
1041/31041/81042/21044/11044/23
1048/141051/71051/221051/241053/12
1055/171056/51056/151059/241062/2
1062/61063/51063/111063/221064/25
1065/51066/201067/241068/21069/14
1072/41074/51075/61075/18
K
K-A-R-L [1] 984/4
K-O-N-G [1] 1004/9
K-U-F-O-U-R [1] 1001/7
K-W-D-Z-O [1] 984/22
KARL [33] 763/6768/25797/13797/24
802/16803/3803/4809/12809/22814/9
828/12842/22844/5845/12845/16845/19
846/2877/2883/21921/3943/7943/14
976/25983/19983/22984/4985/6986/1
986/25987/2987/61031/61077/10
Karl Delano [1] 943/14
Kartessa [1] 816/1
Kay [3] 785/111004/221004/24
Keanu [9] 780/16873/4964/221056/4
1056/51056/61056/71056/121056/13
Keanu Reeves [4] 1056/41056/7
1056/121056/13
keep [19] 794/14824/16832/3852/1
981/1982/17990/21996/121001/21007/5
1012/91012/101013/141033/161070/15
1070/251071/71071/151072/23
keeping [2] 977/12978/2
Kelley [8] 805/11903/8908/19983/20
986/201047/171048/121050/13
Kelly [1] 764/3
kept [5] 908/111001/91006/81011/18
1023/5
key [2] 960/91022/25
keys [2] 833/3833/3
killed [1] 1038/13
kilo [1] 1002/18
kilos [2] 1027/191035/20
kind [41] 769/22772/22780/16780/21
781/23784/5790/10818/4819/13862/20
862/20866/14869/23872/7876/1883/5
884/2893/3893/22904/5916/23919/18
924/19931/18931/19939/9945/4949/6
949/20951/25962/18964/9966/4989/7
1008/91019/151022/31025/31036/15
1064/101074/5
kinds [3] 937/2990/71023/22
kits [1] 859/6
knew [16] 770/2843/23871/6908/12
958/101001/101001/111001/141010/7
1010/81010/91010/221010/221026/20
1049/51049/6
know [212] 766/15766/16766/18770/7
772/5772/7772/8772/17772/21773/8
774/4778/6781/20787/3788/6788/24
791/5791/14791/21793/1801/21807/5
818/1818/9818/11818/22819/20823/19
826/15832/11843/9843/10843/12843/12
846/24848/17848/23848/24849/18850/2
852/18852/22853/12854/17854/19
854/22855/14855/17858/18859/9861/13
864/15865/8867/22872/5876/2877/8
880/6881/20892/10894/4895/12899/21
910/20910/21912/3920/23920/25932/12
937/12941/15941/24942/15943/8943/11
944/1945/17946/2946/15948/9954/1
957/11963/20963/21964/5965/15966/2
966/7967/3970/4970/4973/14974/6
974/9974/12974/23976/1976/3976/4
976/11976/22976/23978/6980/8980/19
991/16993/21993/23999/7999/20
1001/121001/201001/231002/16
1002/251003/251005/91006/181008/1
1008/21008/61009/81009/111009/13
1009/141009/181010/91010/171010/17
1010/231012/81012/131012/181013/7
1013/91013/101015/31016/121016/13
1017/121019/71019/81019/101019/10
1019/141019/181021/181022/11023/6
1023/101023/221024/71025/121026/2
1032/61032/71032/91032/241032/24
1033/151033/161033/181033/191035/3
1036/231038/91038/221039/41042/3
1042/31043/71044/151044/191044/19
1046/21046/231049/211052/11052/1
1053/91054/241055/211055/241056/8
1056/91056/121056/131056/151059/25
1060/181060/191060/221062/11062/5
1062/81063/111064/81064/91064/13
1064/151065/61065/61067/91068/6
1068/71069/51069/211071/151072/16
1072/221073/21076/1
knowing [2] 772/51051/6
knowledge [15] 793/20942/12942/13
944/20944/21947/25948/15965/13
965/18976/41006/201051/121056/24
1064/71064/21
known [8] 763/6769/1775/21827/3
883/22973/21038/181077/9
knows [1] 1047/6
Kong [1] 1004/6
Kousisis [2] 1070/61070/12
Kremkov [113] 770/10770/23770/25
771/1771/23772/9773/7773/8773/14
778/17778/21778/21779/7780/11782/12
782/24787/14787/22788/9788/16789/7
789/7789/8789/8789/10790/2796/6
796/7797/4798/12798/14798/24799/2
799/4800/19808/2809/17825/23826/1
833/24834/5835/13835/16836/6836/8
836/19836/22837/14845/1845/4845/10
845/16845/16845/19845/19861/22
866/10871/16876/11876/13876/15877/9
880/25881/4889/23891/2891/3895/20
895/21896/8896/10897/1898/12898/19
904/22944/16944/19946/23947/5976/6
976/9976/13999/17999/22999/23999/24
999/251001/31005/61009/101009/24
1010/51010/141014/221017/131017/14
1028/171033/111035/41035/51035/22
1049/51049/221049/241050/241051/8
1051/101051/231054/61058/91059/4
1059/121068/15
Kremkov Industries [37] 779/7780/11
782/24787/14788/9788/16789/7789/8
789/8789/10798/12798/14800/19809/17
825/23826/1833/24835/13835/16836/6
836/8836/19836/22837/14845/1845/4
845/10871/16876/11876/15877/9881/4
889/23891/2898/12904/22976/13
Kremkov Industries' [4] 787/22790/2
796/6896/8
Kremkov's [5] 797/6797/7928/22
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 338 of 359
K
Kremkov's... [2] 1049/251050/4
Kufour [3] 1001/51001/61001/7
Kwdzo [2] 984/15984/21
L
labeling [1] 875/18
labor [2] 1035/181035/19
lack [2] 1068/161068/16
lady [4] 911/24946/111075/241076/13
Lake [1] 998/10
Lamborghini [19] 808/25809/9810/17
810/25811/12811/13842/4876/22876/24
923/5923/9923/15923/18924/24925/10
926/15936/7948/14950/17
land [17] 814/1862/14863/3922/4
926/14935/25936/4961/141001/16
1002/161002/251003/11003/71003/12
1003/151015/221015/23
Lane [13] 799/15799/21801/21802/8
807/14807/20809/12813/25828/14
918/24936/8996/111058/15
language [1] 848/24
laptop [6] 1023/181045/221058/8
1058/91058/151059/2
large [10] 770/1770/4770/19770/19
794/16827/6972/17972/18972/21
1027/25
large-scale [2] 972/17972/21
last [18] 767/20787/14788/16819/24
825/25844/8882/15890/15911/1962/4
968/14971/7971/9984/21024/31027/18
1046/231056/16
later [16] 776/8776/18817/1817/2
857/16901/13987/24987/24991/2992/9
1025/111025/191025/241029/41030/18
1040/7
laughing [2] 985/111033/4
launder [1] 985/24
launderers [2] 844/17966/7
laundering [6] 768/15791/15844/16
957/21958/7966/8
law [12] 764/4818/3858/17858/18859/3
913/15913/19939/5939/7966/11034/10
1064/5
lawful [2] 1034/41034/6
laws [1] 1061/13
lawsuit [4] 1038/141038/141038/15
1038/22
lawsuits [1] 1039/6
lawyer [3] 830/17976/201008/9
lawyers [3] 1038/51039/11039/3
lay [3] 964/21965/11965/12
layering [2] 791/16845/20
layperson [3] 1008/31064/81064/14
leads [1] 852/25
lean [1] 1056/1
learn [4] 802/24989/11007/221036/19
learned [2] 870/241062/1
leases [1] 1000/13
leasing [1] 840/9
least [10] 782/11854/17863/1901/23
901/24910/24911/10969/23970/81071/4
Leatherleaf [17] 779/8782/22783/15
783/17785/1798/13798/19799/14825/23
828/21999/91045/241052/221052/23
1053/61053/121058/14
Leatherly [2] 1052/161053/6
leave [3] 933/171071/181071/20
leaves [1] 935/19
leaving [2] 766/251023/12
led [3] 769/12789/24842/21
Lee [12] 1001/141001/171001/21
1002/101004/51004/51006/131006/19
1027/141040/221041/231059/8
leeway [3] 854/9856/21857/14
left [14] 768/23777/12784/18818/7
828/8830/11830/24932/12932/14980/20
998/211023/131024/131030/5
left-hand [1] 830/11
legal [5] 779/6973/17992/6993/13
1039/3
legally [4] 782/15985/2993/221031/9
legitimate [3] 861/8861/13964/6
Leigh [1] 976/20
lender [1] 838/6
lengthy [2] 774/5780/4
less [5] 821/3862/23863/5863/15
1068/24
let [53] 766/15766/16766/18769/5787/3
795/4817/10819/4819/20847/11849/10
852/19856/19857/12862/11869/21
885/14885/20887/12904/4911/25912/3
916/9931/8932/12951/11967/5967/22
975/21976/3978/13978/15978/16978/17
979/24986/4991/231010/11016/81019/9
1027/231038/241040/11058/201060/17
1061/11061/61062/221063/131067/3
1069/51071/151072/16
let's [63] 788/10794/13794/14795/1
816/14818/15834/12835/1835/2835/24
836/10836/16841/2843/22845/1846/19
849/14856/18858/3858/15861/16866/2
866/19867/18868/11869/5869/19869/19
869/21872/21894/24894/24895/14
913/21928/3928/9929/17929/24950/5
951/14987/14994/91011/21012/81014/3
1014/91021/11028/171031/151037/4
1037/51037/71042/151043/81045/5
1045/171046/61053/91053/211054/14
1064/231066/111068/6
letter [18] 992/161028/241028/24
1029/91051/141051/151052/31052/4
1052/61052/211053/81053/161053/23
1053/251054/21054/41054/91054/15
letterhead [1] 1051/14
letters [2] 1019/111019/12
Lewis [4] 1004/31006/101006/11
1021/15
liabilities [1] 1035/6
liability [6] 1042/211044/131044/22
1044/231045/31045/15
liable [1] 1038/16
license [12] 783/15827/21862/19
959/19989/9989/11989/13989/18993/14
996/251023/211036/20
licensed [4] 972/25973/1989/3989/4
licenses [2] 871/1989/5
liens [1] 948/20
lies [2] 958/25959/2
lifestyle [1] 840/3
light [1] 1060/21
lightly [1] 796/12
like [155] 766/14768/19772/22775/10
780/10784/1784/5790/10791/15792/3
793/3793/4793/9801/15817/16818/1
818/3818/4819/13823/21827/12833/14
844/15844/20845/1845/14846/15849/17
850/12852/1852/2853/9853/10853/14
853/15853/17854/23854/24855/11
856/15858/22863/8866/15870/15874/14
875/1885/22887/7891/20891/22891/24
892/15893/24894/6895/10898/6900/7
902/8911/14919/18925/5932/21933/13
933/16934/15935/5937/5937/7937/7
941/22941/22945/16946/13947/2948/4
948/14950/16954/18957/12974/7975/2
976/2977/20977/25978/1978/2978/11
983/11989/20991/1993/3995/171001/9
1001/201002/191004/211004/22
1005/251007/111007/161007/24
1007/251008/181009/61010/171011/14
1012/101016/41018/161019/71019/8
1022/51023/211029/71031/231032/2
1032/91032/151033/51033/171034/6
1034/71035/71036/21036/211036/23
1036/241037/31037/41037/81037/17
1038/211038/211039/61040/81040/21
1048/131055/171056/11056/101059/23
1060/11060/171061/241062/211067/10
1068/71068/81068/81068/91068/14
1069/31072/21074/41076/2
likely [1] 887/17
limited [5] 794/9795/16803/25824/4
967/6
line [23] 1/6789/18789/19819/21830/8
830/9830/10903/20925/5925/6927/8
934/13981/11981/14981/14981/16
1056/201056/201056/201061/251062/6
1064/181075/6
lined [1] 1022/12
link [1] 1036/25
list [12] 774/5780/10780/13780/15
871/18872/21872/221008/171008/24
1008/251009/21009/7
listed [15] 779/4779/5807/23809/10
812/22825/7827/1868/25871/15894/5
907/11930/10930/11990/111056/21
listen [4] 832/4853/101067/161069/11
listing [7] 825/22889/6893/25921/5
926/24928/6947/11
literally [1] 894/9
Lithia [1] 785/15
little [48] 768/11769/25770/7784/15
788/21792/19795/13796/22797/16
806/11814/5817/4818/24822/10837/15
859/16863/5874/24894/23898/24900/19
903/14903/19914/1924/19929/14932/21
937/17940/6949/10954/1972/15979/11
985/13987/14989/24994/11998/24
1013/231015/71021/11023/91027/23
1033/11035/251036/11040/71069/22
live [5] 996/17996/19997/7999/13
1047/2
lived [1] 997/9
lives [2] 1038/201046/3
living [3] 783/10783/11783/12
LLC [3] 779/7889/231039/5
loads [2] 1015/141015/15
loan [85] 769/22769/24770/3770/4
770/5770/9770/20772/5773/4776/21
776/25778/20780/6788/8789/21790/15
796/24796/24806/18817/7820/15835/6
838/9838/10838/13838/16838/18838/19
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 339 of 359
L
loan... [57] 838/22840/3840/15845/21
861/17863/18870/21886/1886/2886/13
893/24897/5897/9902/21934/191006/23
1006/251007/31007/41007/101007/23
1008/141009/221011/21011/81012/14
1014/41014/161019/21019/131019/14
1019/181020/91020/151027/171027/21
1028/61028/81028/141029/231030/13
1040/151040/191040/241051/31051/3
1054/211056/231061/191063/11064/6
1064/111066/201066/241067/151068/3
1068/18
loans [4] 769/15769/18769/19993/22
locate [1] 880/21
located [11] 785/16799/15799/16802/7
802/17804/14804/16910/3998/81061/15
1064/2
locating [1] 1059/21
location [9] 770/15778/5778/10812/4
814/14822/23822/24960/191017/19
locked [2] 1057/71057/15
logistics [10] 804/15804/21804/25
805/25807/3807/6808/20877/71037/21
1039/10
logos [1] 861/3
long [19] 777/5777/25821/1822/3
844/13883/2911/7939/1968/21985/18
997/16998/19999/151004/201038/11
1049/121061/251069/91072/1
long-term [1] 1004/20
longer [4] 910/91068/191069/61072/2
look [73] 769/24773/20774/22779/21
782/19783/19784/7784/12784/18784/24
786/1787/2792/6794/21797/17800/4
801/4801/7801/14801/17801/22802/9
803/13804/9805/2805/12810/18812/20
818/23826/19828/15834/12842/18
846/22852/1853/12853/14857/4865/7
865/10866/20873/20875/24880/7885/9
885/17886/7886/7887/4887/16889/9
893/2913/21914/16929/17929/24939/11
939/18946/13949/21952/5986/81001/24
1009/81017/211018/91032/151048/13
1054/31058/131074/81074/111075/22
looked [16] 783/25808/16865/4871/6
872/22876/8885/24902/6934/15944/12
946/61046/121049/51056/171056/19
1063/25
looking [42] 771/10772/19785/8787/4
788/14793/24794/1794/8795/8795/10
795/11795/11798/15801/3804/1806/14
806/14809/5812/8828/8843/22884/6
895/9895/10896/3903/3903/5918/13
919/15928/16929/5938/5942/5942/5
942/14955/18981/41015/101029/15
1037/111049/211059/20
looks [3] 801/14885/22945/16
loss [5] 1035/101035/101035/12
1035/131035/14
losses [2] 1041/111045/11
lost [1] 1045/25
lot [40] 780/15790/9790/9790/14790/14
792/14811/1812/18812/19827/7827/7
827/9827/10832/24833/1841/9841/13
860/8860/23861/2870/2892/10894/4
907/20932/9932/10935/12935/21935/22
945/2970/1973/15974/20974/24976/10
984/231006/231043/201070/11076/1
lots [1] 1027/10
love [1] 1001/15
LUCIUS [12] 763/6797/13797/24802/16
803/3803/4809/12809/22828/12844/6
877/21077/10
lumped [1] 894/1
lunch [10] 766/11766/12821/24824/10
824/17910/6910/11910/12910/21912/6
lunchtime [1] 912/21
M
M16 [1] 1032/7
M16s [1] 880/14
M850XI [2] 812/3919/11
ma'am [32] 887/23889/2889/13892/4
894/16895/8896/16896/24897/15897/25
898/8898/10898/13899/19899/25900/4
900/17900/20901/1902/17909/5909/15
914/2920/12922/16922/24923/6925/11
925/23929/15929/22948/8
machine [2] 853/71077/7
mad [1] 1058/3
made [32] 784/3818/4820/17824/12
838/17896/25903/11903/17903/19
906/21919/12932/21932/22932/22943/1
947/8958/8958/16958/18963/5991/23
1002/151002/161002/201015/31015/17
1019/171027/251031/81047/141050/9
1064/12
mail [3] 768/141029/61053/9
mailed [1] 1051/16
main [1] 998/9
maintain [2] 777/41006/12
maintained [2] 777/3777/3
maintains [1] 1055/25
major [1] 780/17
majority [2] 807/25846/17
make [38] 766/12767/2770/18797/21
809/8812/2814/6815/25857/15870/6
891/17901/8913/7925/12944/2956/20
957/12962/10977/9980/8982/1982/2
982/151003/101004/211004/221018/9
1020/211034/171034/251035/21035/9
1037/11053/141053/231063/81069/1
1069/6
makes [8] 790/8818/12819/1852/1
945/5964/5977/15979/1
making [11] 783/22785/20785/23
824/18851/20869/23916/18962/18
977/14978/121035/20
mal [1] 1025/4
malicious [1] 1025/3
management [4] 988/19988/20988/23
988/24
manager [1] 768/23
manner [1] 1032/25
many [29] 771/3816/22834/7834/15
834/21849/19858/25859/1866/9877/9
877/15902/7958/24959/2967/9969/21
973/11973/14973/191005/171005/21
1015/141015/201021/51024/211028/12
1032/151063/51067/24
March [22] 787/19788/1816/24834/25
895/19895/22896/1896/7896/11896/14
896/15897/9915/18916/10917/4936/10
936/15946/23947/14947/17949/16
1030/13
March 28 [2] 896/1896/11
March 28th [3] 896/7896/14946/23
March 29 [1] 896/15
March 29th [6] 788/1816/24916/10
917/4936/10936/15
March 29th of [1] 787/19
Marietta [6] 799/16807/14810/11813/25
828/14908/3
marijuana [2] 792/22793/2
Marines [1] 994/19
Marissa [1] 830/23
mark [3] 932/17932/20933/14
marked [2] 884/16986/4
market [2] 1015/131015/14
marriage [1] 993/20
married [1] 993/24
marshals [2] 912/8912/14
Mary [1] 928/24
master's [1] 972/5
matched [1] 813/2
material [2] 775/16957/9
math [2] 985/12985/15
Matt [1] 780/20
matter [6] 769/15772/7864/3994/4
1059/21077/8
matters [1] 965/9
MAX [2] 989/23999/1
maximum [4] 834/5877/18901/18
975/23
may [55] 1/21/5798/21798/22809/2
827/12827/12827/12829/16831/17
835/13841/4858/7858/11879/10881/7
881/24882/18888/5891/17906/1906/2
906/3906/20907/10908/21908/24913/13
915/9919/16922/5928/12928/20937/20
947/3947/4949/10952/12956/6964/5
967/21967/25970/22979/6984/1986/19
1018/41019/241019/251020/221030/10
1030/111031/191050/181074/14
May 10th [1] 906/1
May 11th [5] 798/21798/22827/12906/2
922/5
May 12th [6] 829/16831/17858/11
928/12928/201020/22
May 7th [1] 1050/18
maybe [20] 793/4818/8821/3848/23
857/5863/3863/5867/1873/14910/9
933/3937/15940/5954/10963/24965/25
1009/151020/231069/31075/21
McDonald [2] 1014/41014/5
McDonald's [7] 1014/31065/101065/15
1066/51066/131067/201068/3
me [124] 766/15766/16766/18780/16
780/21781/12786/20787/3787/7790/25
794/7796/4796/11804/7808/18819/20
820/4829/7829/20830/13830/25833/14
847/11849/12862/11866/14872/13
874/12875/14885/14885/20887/18
896/25897/21899/22904/4912/3912/8
912/14916/9931/8939/21941/8951/11
957/13957/15967/2967/18967/22969/9
975/21976/20978/13978/15978/16
979/24985/11985/16985/17986/4986/11
987/8991/15991/23998/41000/17
1001/121001/151001/161001/211008/2
1008/31008/121008/201009/41010/1
1011/161011/231012/161012/191016/8
1017/111019/91021/191022/21022/22
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 340 of 359
M
me... [38] 1025/141025/191025/20
1025/231027/31027/231028/151029/5
1029/51029/91032/61032/101032/12
1038/241039/41039/81040/11041/23
1044/201044/201047/181048/31048/3
1053/181058/201060/171061/11061/6
1062/221064/211067/31067/91067/12
1069/111071/31071/151075/161077/12
mean [65] 778/13791/5791/11791/23
792/21793/2793/13794/22818/21842/18
842/24843/6843/12844/3852/18852/24
853/12853/17853/20853/24854/18
854/20854/21855/14855/16855/17
855/22856/4857/3863/12863/14869/7
869/11872/11874/21875/13878/4879/9
881/8910/23911/14942/23945/1945/3
945/17958/24965/24966/9980/24983/6
988/22991/121008/61010/171013/13
1033/41033/171036/211036/221038/21
1053/81054/101054/121056/61070/9
means [4] 848/18850/8910/20982/5
meant [2] 795/16875/19
mechanical [1] 763/18
med [1] 859/6
media [1] 1062/2
medical [2] 816/17870/6
Medicare [3] 1060/71060/141062/13
medium [1] 1001/19
meet [5] 1001/171002/101024/14
1034/111034/12
meeting [2] 1002/41017/10
meetings [2] 1001/231002/23
Melbourne [1] 988/8
melt [1] 974/16
member [2] 1051/111054/7
members [2] 1038/131059/16
memo [3] 789/18934/13934/14
memory [10] 778/16781/14809/24
867/23868/1868/8869/10869/14872/17
881/2
mentally [1] 1033/15
mention [3] 808/201039/121057/16
mentioned [20] 771/25776/21777/20
785/17785/20814/9844/20885/8886/1
896/13913/6925/21926/18941/3943/6
946/3946/21946/22949/71059/8
Mercer [3] 998/21998/241010/11
mercury [2] 974/14974/16
mess [1] 982/14
message [3] 1048/251049/11049/2
met [4] 780/9956/211002/21002/15
methods [1] 1034/22
Mexico [4] 972/5972/6972/8972/9
Miami [5] 1023/131023/131024/13
1024/151024/16
mic [3] 971/12972/7985/13
MICHAEL [2] 763/111059/8
mid [1] 821/5
mid-morning [1] 821/5
middle [17] 809/5812/8817/16818/2
834/13843/25844/8871/22871/24945/2
945/3969/19984/17985/61007/181022/4
1035/14
midmorning [1] 821/8
might [20] 778/4781/21786/5794/20
794/22804/3818/18844/17850/18875/2
875/2876/12894/8895/11911/7956/15
975/21046/241062/51075/5
migrated [1] 987/17
military [3] 853/18995/7995/7
milk [3] 1037/81037/81037/9
Mill [6] 995/15995/17995/21996/2
996/21997/14
Miller [4] 996/2996/5996/6996/7
million [99] 769/22770/2789/4794/24
798/22798/25840/16861/18861/20
861/22861/25861/25862/2862/24863/8
863/15863/18863/20864/21896/18897/5
897/12897/23898/25905/3906/5906/7
906/11906/18908/22909/3909/19909/20
909/21913/12914/8914/10915/10916/8
919/15921/23922/5923/1923/9925/16
926/8927/17927/18927/24927/25930/17
930/19930/21930/22931/4931/8931/9
931/11931/14933/22934/9934/21935/10
935/12935/13935/18935/19936/11
936/24937/16937/22938/2938/5948/4
951/8952/24953/21960/5960/61011/5
1011/81012/31012/31013/21027/8
1027/91027/201028/11030/11030/1
1030/51030/81030/161030/181035/21
1040/251044/101045/91045/11
mind [15] 832/3851/15851/18851/20
852/11852/15869/24879/16880/6965/21
985/171015/41019/171064/131071/15
mine [36] 849/6963/21965/16965/20
966/13966/20966/23970/18974/7976/5
976/8976/15977/5977/7977/15997/6
1000/211001/111002/161004/11005/15
1005/211006/21007/51010/141013/17
1013/181013/221014/221014/22
1035/161036/61055/51055/61055/14
1056/4
Minerals [1] 972/24
mines [26] 963/19964/4964/8964/10
964/11964/19965/6965/22966/21967/7
967/8967/10972/5972/10973/6973/12
973/21974/4975/1975/4976/10977/9
977/14978/12978/251058/22
minimal [1] 840/8
mining [32] 833/24834/2963/18963/19
964/2965/1965/15971/21972/4972/5
972/8973/15973/17974/25999/23999/23
1000/141000/251001/11001/81001/13
1002/211002/251003/41003/71003/12
1012/91013/141017/181021/221035/5
1035/19
minister [1] 1013/6
ministry [1] 1013/6
minors [2] 972/25973/2
minute [3] 979/201008/221063/11
minutes [20] 821/2821/3821/8821/19
821/22822/1822/4851/7853/5910/8
910/18910/18910/24911/10912/10
956/15979/12982/201011/141069/13
Miranda [1] 829/3
miscommunication [1] 857/25
mislead [1] 852/12
misleading [2] 817/19818/5
misrepresents [2] 877/24878/2
miss [2] 912/11047/21
missed [2] 788/17991/4
missing [1] 956/24
mistake [1] 991/22
mistaken [1] 881/1
MLB [2] 763/41077/10
mode [1] 1033/20
model [3] 809/8812/2815/25
modest [2] 770/15770/21
mom [2] 987/21988/1
moment [3] 873/22956/14982/24
Monday [1] 911/25
money [250] 768/15772/6772/8772/8
772/10772/13772/16772/17772/18
772/20772/22772/23773/2773/10773/11
773/12773/12773/15785/21787/7788/4
788/7790/3790/8791/15796/5798/17
800/8803/7806/20808/2817/7817/8
820/14820/15839/20839/21839/22
839/24839/25840/1840/10840/14840/15
844/16844/17844/20844/24845/9845/21
846/4846/14846/15862/5862/9862/23
862/25863/22863/23863/24864/4864/12
864/19864/23864/25870/18870/18
871/13872/8875/16875/17875/18875/19
875/20875/20875/20875/21875/21
875/22875/23875/23876/5877/24877/25
878/4878/5878/5883/19891/23891/23
892/1892/2892/7892/8892/15892/18
892/24893/15894/17894/21896/3896/4
898/18899/5899/6900/2901/9901/21
903/23904/2904/14905/8905/15905/15
906/6906/7907/2907/2907/3907/6907/7
907/7909/10909/13914/5914/10914/11
914/17914/19916/4916/4916/5916/15
916/20916/24916/24917/5920/14920/16
921/11922/17922/23924/1924/7926/7
927/16927/18927/19927/25928/1929/2
929/3929/14930/16931/1931/2931/7
931/9931/13932/15933/22933/25934/1
934/5934/19935/20936/11936/19936/19
937/12937/24945/11945/13945/14946/6
946/23947/8949/17950/7950/9950/23
950/25951/1951/17952/25953/18953/19
953/19954/12954/15954/17957/20958/6
960/25961/10961/17961/18961/19
961/21962/13966/7966/8975/16975/20
978/2985/241002/181006/141006/18
1011/71011/191012/51012/61012/7
1012/221013/11013/211014/31014/4
1014/71014/121014/141015/11015/7
1015/181018/211019/11019/21019/6
1019/201028/191029/181029/20
1029/251030/121030/211052/181062/5
1065/31065/41065/51065/251066/5
1066/221067/21067/31067/51067/14
1067/231068/11
Monica [18] 871/7871/20871/23871/25
872/18946/11946/18955/15969/12
969/14969/17969/19969/21970/2970/9
970/171010/31010/5
Monica Sweeten [2] 871/25955/15
monies [1] 772/10
month [7] 907/16917/7977/11978/19
978/22991/11035/21
months [3] 803/15834/241015/12
more [26] 770/7794/25795/21796/22
797/16817/17838/24851/7855/18857/3
874/25932/23937/17945/2964/5973/13
976/1977/241015/131034/171036/4
1036/81043/41067/121069/221071/23
morning [11] 768/2768/4821/5911/19
980/11980/12980/201025/161048/20
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 341 of 359
M
morning... [2] 1069/11071/16
most [9] 769/19772/23794/23827/9
879/25895/10911/211036/41061/3
mostly [3] 1003/241031/51036/1
motion [6] 956/11956/20957/12957/12
962/201074/21
motivations [2] 792/16792/17
motor [1] 926/13
move [26] 766/9766/10774/12774/13
775/2775/3801/24806/2811/6813/5
815/4828/1829/22831/22835/1841/3
856/18886/15888/11893/7894/25912/11
932/2960/25967/18986/14
moved [7] 766/24870/18997/3997/4
1046/51057/231058/14
movement [1] 844/10
movies [1] 780/21
moving [8] 822/17824/16825/2880/21
934/8956/161045/231057/16
Mr [5] 869/14963/5970/171001/14
1002/10
Mr. [83] 769/3773/18774/20778/16
778/17778/19778/22779/18783/10
789/25795/9796/9799/20800/7808/6
816/7827/2827/3827/14828/24830/20
831/17833/23834/2834/4838/3838/9
838/16839/3839/5839/17839/17840/2
840/17841/4843/16845/4847/9849/12
853/6858/13859/14860/12860/12861/9
866/5874/7875/10875/15876/23878/14
881/19911/6950/13957/24958/10965/20
968/19979/17980/13982/6984/11986/22
1001/171001/211004/51006/131006/19
1016/101027/141040/111040/22
1041/231047/201050/161052/10
1054/201057/171058/201062/22
1063/161064/231067/16
Mr. Delano [42] 769/3773/18774/20
778/22779/18783/10789/25795/9800/7
808/6827/2827/14828/24831/17833/23
834/2834/4838/3838/9838/16839/3
839/5839/17839/17841/4843/16845/4
853/6858/13859/14860/12866/5874/7
875/15876/23878/14881/19911/6958/10
979/17984/11986/22
Mr. Delano's [9] 778/16778/17778/19
796/9816/7840/2840/17875/10980/13
Mr. Finlayson [1] 982/6
Mr. Lee [8] 1001/171001/211004/5
1006/131006/191027/141040/22
1041/23
Mr. Oppong [1] 1016/10
Mr. Thurmond [1] 968/19
Mr. Torjagbo [20] 799/20827/3847/9
849/12860/12861/9950/13957/24965/20
1040/111047/201050/161052/10
1054/201057/171058/201062/22
1063/161064/231067/16
Mr. Torjagbo's [1] 830/20
Ms [1] 938/12
Ms. [25] 805/11882/21886/12887/10
887/22888/21897/4897/23902/4905/24
908/2913/5913/25922/2930/16932/9
933/3933/7949/6961/19983/20986/20
1047/171048/121050/13
Ms. Connors [2] 933/3933/7
Ms. Kelley [6] 805/11983/20986/20
1047/171048/121050/13
Ms. Richardson [17] 882/21886/12
887/10887/22888/21897/4897/23902/4
905/24908/2913/5913/25922/2930/16
932/9949/6961/19
much [31] 788/4808/12838/16853/4
855/18857/3887/17896/3904/16917/1
937/14946/23947/8956/3961/19975/17
975/17975/24977/9978/6978/11995/2
1001/121002/201025/151027/61028/8
1029/71035/221044/131073/4
multiengine [1] 989/17
multimillion [2] 936/201038/22
multiple [12] 784/2790/7790/11808/9
844/21845/24860/8892/5894/8954/19
954/211044/9
must [1] 795/22
my [184] 767/21768/12768/13769/23
770/1773/2774/8778/16781/13789/20
793/15800/25801/16804/5804/20809/24
815/13819/7824/10824/16828/3829/18
830/11830/15830/15830/21830/24
831/12833/15836/11839/25843/14
846/24849/9849/24851/12852/9852/9
853/13853/20854/22857/2859/23859/25
861/21862/11868/8869/10872/17878/23
881/2885/20887/25890/23891/22927/2
943/9943/21944/21947/25948/15948/25
966/10967/22970/12971/8971/9972/5
972/9973/9975/6976/1977/17977/25
984/15985/6985/9985/12985/15985/17
986/6987/21987/21987/24988/1989/10
989/12989/13989/14989/17989/18
990/16990/20990/25991/1991/4991/15
992/12993/12993/13993/19994/14
996/20997/25998/1999/8999/8999/9
999/211000/11002/21002/151003/3
1004/11004/11004/201005/101005/10
1007/151008/201012/41013/51015/4
1017/51017/61017/61019/171021/15
1021/251022/241022/241023/71023/15
1023/181023/191024/11024/11024/3
1024/101024/111024/161024/17
1026/211027/161027/201029/11029/22
1032/21033/161033/161035/31035/3
1035/31035/61036/11037/241041/4
1041/171041/171044/181044/19
1045/211045/251046/231047/11
1049/191053/181056/241056/25
1057/171057/241058/101058/10
1058/181058/181058/191061/201062/5
1064/71064/211067/161070/21072/19
1073/12
myriad [1] 858/21
myself [1] 1022/11
N
name [172] 767/20767/21768/17770/10
778/16778/17778/17778/21779/6780/22
781/2784/24797/4797/7797/7797/8
797/9797/11797/13797/14797/20797/24
797/25798/3798/4798/5798/10798/12
798/15798/18798/23799/13802/24
802/25803/3803/4803/14803/17809/13
809/15809/15809/18809/21809/22810/1
810/4810/8810/10825/7825/22828/11
828/20830/23842/13842/16842/17843/8
843/22843/25844/3844/3844/5844/8
844/8845/12845/14871/19871/22871/24
872/5876/24877/1882/15889/6889/6
889/22898/11899/9915/22915/22920/22
920/24920/25921/2921/3921/4921/12
924/2926/5927/1941/24942/10942/20
943/4943/7943/9943/12943/12943/13
943/15943/18943/19943/21943/23
943/24944/14944/16944/23945/4945/7
945/9945/12945/13945/14945/15945/24
945/25946/2957/25958/3961/11961/13
968/14969/19970/1970/9971/7971/8
971/9972/20977/1984/3984/14984/15
985/2985/7985/8985/9985/11985/17
985/20985/22985/24986/1986/2986/22
986/241001/41004/231009/141009/16
1010/181022/241023/11031/21031/8
1031/81039/91039/111039/171049/25
1050/41050/41051/21051/201053/3
1053/71053/191054/31054/51054/8
1056/6
named [4] 969/12976/161056/12
1056/13
names [17] 780/13780/14780/15780/15
791/17843/12872/21872/22944/21945/2
976/11980/3981/2981/14984/23993/23
1010/1
nature [7] 872/9948/21960/18960/20
961/25962/1963/23
Naval [2] 987/21987/25
Navy [2] 987/25994/19
necessarily [2] 866/24945/17
necessary [1] 1017/21
need [27] 786/6823/4832/4853/6853/21
853/22854/11856/2856/15857/18865/14
870/5912/9942/22962/25965/12965/13
977/191017/171024/231039/251049/2
1061/131061/161067/121070/22
1073/18
needed [14] 816/4872/11872/131003/5
1012/61012/101017/141017/151023/15
1050/231051/21059/61061/91061/10
needs [5] 796/24822/191069/51069/6
1069/6
neither [1] 854/18
Nevada [1] 971/19
never [27] 838/3845/22858/17858/18
966/19976/23977/5977/5977/6977/6
985/19994/5994/7994/81001/121001/13
1021/251026/221026/231056/171062/5
1062/111062/121062/131062/14
1062/181065/4
new [17] 911/24921/3972/5972/6972/8
972/8993/5993/8994/41023/231023/24
1026/211026/221041/251065/31065/4
1070/5
newly [2] 770/12770/21
Newmont's [1] 972/19
news [1] 1062/2
Newton [1] 781/3
next [44] 767/11785/3788/21790/10
790/10800/4813/14825/2830/25835/1
835/2835/24836/10836/16837/7859/25
861/22877/1877/3882/4889/17900/7
900/18901/12910/8917/15922/20927/2
928/9934/7935/8956/5962/21979/16
980/11983/18995/10997/12997/13
997/241048/71048/71048/201073/10
Nicholas [1] 764/3
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 342 of 359
N
Niello [1] 922/8
Niello Imports II [1] 922/8
nine [4] 769/21841/15841/16962/4
no [239] 1/13763/4771/5774/16775/8
786/17786/22790/3793/17795/25802/1
806/3808/22810/1810/7811/7813/7
815/6817/4818/10820/20824/8832/17
834/3834/10838/8838/15839/2840/19
842/9842/12843/17846/6846/22848/5
848/13849/11849/23850/14853/2853/24
855/5855/13859/24860/2860/4860/6
860/9864/12864/18865/18865/19868/22
870/16871/22871/24872/1872/3874/21
876/15877/13877/23878/1878/6879/17
881/6881/22881/22881/23886/17888/13
891/3892/6895/5895/8899/12903/25
903/25906/12907/9909/22912/1912/18
916/7916/21916/21916/21916/21916/21
924/3924/3925/25925/25927/5927/5
927/5931/3931/10931/12932/4933/15
933/15934/17934/17934/20936/18
936/22939/7939/10939/10940/3940/17
942/17942/25943/8948/9950/9950/22
951/6951/6951/9952/21952/23953/20
955/7955/10956/1958/2963/7964/1
965/5965/22968/4969/16969/18969/20
975/16975/20976/10976/20977/1977/8
979/4980/18981/24985/1985/21985/23
985/25986/17991/2991/15993/7994/4
997/8997/11998/171000/221002/5
1002/51003/81003/101003/111004/12
1004/121009/11009/81009/211010/6
1010/151012/241013/81013/91014/6
1014/111014/171016/171017/171018/1
1018/81018/101018/201018/201019/4
1020/221020/251021/111025/51026/3
1028/211029/31029/141029/241030/22
1031/11033/61033/61033/121033/22
1033/221033/241034/211037/41037/19
1039/161039/231040/41042/31042/7
1043/31043/231045/161045/211046/3
1047/41051/121051/131052/231054/2
1054/21054/21056/211057/171059/21
1060/121064/71066/251067/11067/18
1068/131068/131068/131069/201070/5
1070/81071/31073/111073/131075/14
no, [2] 796/21071/11
no, Your Honor [2] 796/21071/11
nobody [3] 860/5985/101057/24
noise [1] 1025/15
none [5] 840/18862/10895/13940/18
950/9
Nope [3] 933/2976/14976/17
normal [1] 975/2
North [2] 913/15913/19
NORTHERN [16] 763/1770/16779/12
779/15783/12783/18784/3785/16799/17
799/19804/16810/12812/7814/19968/24
1077/5
not [318]
note [5] 1/12885/4892/12961/10966/17
notes [1] 962/18
nothing [16] 831/25840/13856/14
873/24878/7970/21979/5991/171011/17
1027/11057/81063/211064/251068/14
1070/61070/14
notice [3] 777/181009/101051/9
noticed [3] 778/14963/17979/25
notified [1] 963/7
notion [2] 853/9966/1
novel [1] 781/6
November [4] 836/20836/24987/4
1077/14
November 2nd [1] 987/4
now [112] 766/12800/12808/23813/19
818/12820/7821/5821/8821/10838/3
838/9851/2852/5852/21854/4862/8
867/23867/25868/7868/16869/5869/23
870/17872/7872/11872/21874/25880/21
883/14884/11884/14885/8885/14886/1
886/3886/10887/10888/21889/17890/5
891/16892/22893/18894/24895/20
895/22898/11898/21899/23900/18904/4
905/8905/15911/23915/24923/22924/19
925/17925/24928/24930/4930/16930/19
930/25931/16934/7934/15935/12936/10
937/1937/9937/17949/7949/20950/25
951/20951/25952/15953/6965/21969/7
971/16974/20974/24979/10983/8983/9
983/10985/16990/3993/12993/15993/15
1007/71012/121012/131018/41052/10
1061/71061/81062/41063/101063/10
1069/91069/251070/151070/241071/4
1071/71071/191071/201073/23
number [60] 1/61/6782/5784/21785/23
823/2825/11826/1829/11829/12830/6
834/5834/21835/14836/7836/23838/17
839/11839/12846/24847/4847/18848/12
848/13848/16861/24865/15866/12872/3
877/18877/21888/24889/7890/16952/1
952/2952/3952/7959/3964/8975/2993/5
993/8994/1994/5994/6996/141004/17
1005/31021/81023/221024/21026/22
1026/231034/241045/201047/12
1049/131059/211077/10
Number 43 [1] 829/12
Number 7 [6] 847/4847/18848/12
848/13848/16865/15
numbers [10] 782/10825/12862/4898/7
932/10947/22947/23952/6959/19
1062/17
O
O-W-U-S-U [1] 971/9
object [6] 817/18963/12981/31029/13
1029/141074/6
objected [1] 982/6
objecting [1] 818/10
objection [40] 774/15774/16775/7
775/8786/16786/17790/16790/16795/24
801/25802/1803/20803/20803/21803/23
806/3811/7813/7815/6817/10817/18
828/3829/25831/25832/15850/16874/20
874/22886/17888/13932/4951/12953/8
953/12986/161029/41063/41063/4
1063/71075/13
objections [6] 819/12824/11824/11
1028/251029/21029/2
observation [1] 966/11
obstacle [1] 958/2
obtain [3] 776/23804/24993/14
obtained [13] 787/6788/9805/23816/12
827/22840/3840/7840/10840/18841/19
843/17865/121004/18
obtains [1] 877/24
obvious [1] 1020/23
obviously [7] 851/17854/2879/9997/3
1009/201049/221070/6
occur [1] 927/15
occurred [2] 831/17961/7
occurring [1] 960/21
ocean [1] 1007/18
October [5] 836/20836/24913/18975/16
975/18
off [14] 774/3776/5816/22846/24853/4
853/13854/22879/13935/17964/19
964/19987/121037/11037/1
offenders [1] 969/6
offense [4] 823/17962/9962/161075/20
offenses [1] 957/10
offer [1] 966/21
office [18] 764/2764/4776/7814/16
882/23882/25883/4883/17938/20938/21
939/16940/41017/41017/61052/17
1053/111053/151074/20
officer [6] 939/6939/7966/6968/24
987/21998/1
officer's [1] 792/16
officers [3] 851/21966/11032/6
offices [1] 1077/6
official [8] 1/11/21/31/71/14763/21
1077/41077/19
offset [1] 1041/11
often [1] 966/1
oh [46] 783/21783/24796/2810/2810/7
810/21819/25823/4824/1825/13826/17
858/7865/20886/22887/6887/20895/5
903/25912/16912/20932/18932/25
933/10933/11934/12934/20937/8937/20
939/10940/3942/25949/15950/9951/6
952/19952/21971/13971/17984/19
985/141022/71038/21039/131047/23
1048/131068/18
oil [3] 849/61007/161007/18
okay [513]
old [12] 818/13990/3992/25994/5997/5
997/61000/161023/231023/241046/12
1049/151049/17
oldest [2] 1025/11025/2
Oliver [7] 781/2781/3781/4781/5872/25
1009/171009/18
once [10] 776/18787/2840/10845/18
859/16860/24902/11930/25931/31021/9
one [144] 766/23777/12777/16780/16
782/8788/18790/10794/14794/24797/21
813/3816/7817/17818/2822/23834/21
835/1838/24841/17844/20846/1860/21
863/3863/24865/15873/22881/16885/18
885/19886/3888/21889/17889/18889/25
890/1892/6893/24896/14897/18898/7
898/11900/8904/15906/10907/14925/18
926/16927/6927/9927/12928/11933/4
933/5933/11935/15947/7947/13948/4
948/6949/22950/12953/7953/15956/23
956/25957/18958/20959/15959/16
959/18961/12961/20962/4962/7963/6
963/14967/3975/3975/3978/12978/25
979/24980/18980/23981/6981/9982/24
983/2983/4983/12985/11985/15990/11
991/18993/12993/17998/15998/17
1000/91000/121002/101004/71005/5
1005/221005/221005/231006/211014/2
1014/41017/121019/121020/111020/12
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 343 of 359
O
one... [31] 1021/71021/101021/12
1024/221025/11025/21025/81026/20
1031/71032/251033/151038/21054/25
1058/31058/61059/181065/211065/25
1066/201066/221067/241068/31068/4
1071/31071/231073/221073/241075/6
1075/171075/201075/21
ones [6] 786/20808/16941/20984/18
1009/81025/3
ongoing [1] 895/4
online [7] 798/8899/21899/241007/25
1017/191036/181062/2
only [29] 1/21/7780/2794/8823/9828/3
829/24832/6833/14849/12860/21861/22
875/20901/23906/13941/15946/20
952/25962/5963/9980/23991/8992/6
1008/111041/131048/231049/81050/8
1075/4
onwards [1] 996/24
op [1] 853/18
open [9] 766/3890/13891/5895/19983/6
983/131065/21065/41077/8
opened [22] 769/10770/8770/22770/22
771/1772/1826/11826/13889/8889/12
889/24889/25890/1890/3890/4890/18
891/2891/3891/7915/24916/31061/3
opening [1] 983/5
operate [2] 966/21977/10
operated [2] 804/22974/3
operating [3] 834/2895/71015/9
operation [13] 771/20771/22850/7
858/16858/17858/19858/23858/24859/4
861/131003/251046/231050/24
operational [1] 1007/5
operations [7] 839/3839/6843/2973/15
973/17987/25988/24
operators [2] 977/23978/3
opinion [3] 912/11065/21065/14
Oppong [3] 1016/101018/21018/13
opportunity [1] 884/16
option [3] 988/19988/20988/21
options [1] 1014/13
oranges [1] 1068/2
order [9] 766/16766/17795/14821/21
857/15857/17878/3935/23935/23
ordered [1] 940/18
organizational [1] 969/6
organized [2] 824/61049/19
original [4] 769/10798/11007/21007/4
originally [12] 797/12861/17954/15
971/22974/21980/5980/51011/41026/8
1030/121030/121065/7
orpailleurs [2] 978/5978/6
other [85] 772/21773/13773/16776/2
776/3776/11780/3790/13791/2791/7
793/7793/15793/20795/18798/6801/12
813/3815/15824/11825/12828/15828/15
828/20833/15835/15836/8836/24841/23
844/16844/17844/17845/14855/9856/16
860/18863/5883/5888/3891/8891/24
892/12892/16897/18898/11899/15903/5
910/13926/19927/21929/5932/4948/6
949/24950/15950/16951/7953/10961/12
961/14966/2966/2966/3966/7974/14
992/71000/121003/81013/101016/3
1016/41021/101021/121021/231025/3
1036/51045/231054/141065/61066/22
1068/41068/51068/51068/61071/5
1075/4
others [1] 959/23
otherwise [2] 791/20793/20
ought [2] 857/21858/1
our [35] 814/15821/4821/7855/21
858/20859/4859/5859/6859/9910/12
912/21913/12915/9916/1916/2916/2
917/6917/6919/15922/5923/9935/4
947/10947/10956/10960/15966/19
967/17979/10979/12982/21023/8
1035/181057/11072/22
ourselves [1] 860/15
out [154] 766/16779/25780/8780/13
780/21781/2782/6784/22788/18789/18
789/20790/15790/20792/23796/4802/19
808/18817/13817/19818/6818/7818/11
818/13820/6822/9822/21823/12824/17
826/22826/24832/24833/14841/16846/7
846/7846/17850/25851/8851/11852/1
856/9856/21857/17860/11860/22861/1
861/6871/10873/12873/13878/24888/24
893/16898/4900/2900/6900/10900/22
901/21902/22903/8904/1908/18909/13
913/14913/18914/4915/18919/25920/17
921/13923/14923/16923/22924/1924/16
925/18927/22930/7930/11930/14930/19
934/16934/18936/2936/24937/7939/8
939/20940/1940/1946/14948/1948/4
950/7950/12951/7954/10954/11954/15
955/18956/14960/25962/13967/19970/2
972/20973/16974/16980/6980/21981/1
981/12982/6982/17982/17983/5983/11
993/2996/8996/10997/22997/23997/25
998/3999/41007/121007/221007/23
1011/121011/191012/71015/81020/24
1025/61028/221030/51030/81032/7
1043/191053/121053/211055/21061/9
1061/91061/101062/181068/21069/10
1070/181070/231071/31075/51075/24
outset [1] 892/24
outside [13] 833/3849/5850/18850/20
912/11951/12953/8999/13999/14
1034/111034/121061/151064/2
over [48] 768/11786/20821/24833/15
861/22894/23897/16897/17898/3899/21
900/6900/8900/19901/11901/15903/14
903/19906/11910/20914/1915/10915/12
915/15918/16919/23921/23922/8922/17
923/10923/12929/14932/11932/11
933/25935/16938/1973/15973/25978/24
985/18993/41016/251030/181035/21
1043/11045/111057/81058/7
Overlapping [1] 1044/9
overrule [3] 803/23953/111063/7
Overruled [1] 951/13
overseas [3] 865/7865/8865/9
overwhelming [1] 807/25
owe [3] 1020/121028/81034/24
owed [3] 1019/61020/111028/25
own [13] 806/23807/3839/20839/22
876/24924/13945/24966/11966/19
1021/251037/41037/71043/15
owned [8] 804/22976/5976/8976/15
1065/101065/151066/181068/6
owner [8] 799/21844/21996/21014/11
1021/211021/241055/221055/23
ownership [1] 960/19
owning [1] 1068/3
owns [2] 960/171037/7
Owusu [5] 970/24971/1971/9971/14
1035/24
P
p.m [3] 1023/81048/191076/16
pacing [1] 1032/4
package [1] 800/16
page [119] 1/6765/2771/10779/4779/18
781/15783/1784/14785/3787/10788/11
788/17788/18797/18798/6798/20799/25
800/4800/10802/9809/1809/4809/4
809/5810/9811/16812/8813/14816/19
822/11822/22823/13823/18824/4824/4
824/14834/12834/13834/17835/2835/9
835/24836/10836/11836/16837/7839/8
839/11877/1877/3877/3888/24889/3
889/5890/9890/11890/24893/7895/15
895/17896/21897/2898/15898/21899/14
901/4902/2902/24905/6905/21905/22
905/24906/16907/25908/5909/7910/4
912/13913/6913/9913/23914/13914/24
915/8916/2917/15917/16918/13918/20
919/7919/9920/8921/25922/2922/13
922/20923/3923/7924/9924/19926/10
926/21927/6928/3928/9928/16929/9
929/17929/24947/10951/20955/12
955/19980/2981/141070/151070/18
1070/201070/25
Page 1 [11] 771/10779/4797/18816/19
822/11834/12839/8889/3889/5890/24
916/2
Page 10 [2] 787/10823/13
Page 11 [2] 905/6905/21
Page 12 [3] 800/10905/22914/13
Page 13 [1] 906/16
Page 14 [1] 907/25
Page 141 [1] 834/17
Page 143 [1] 835/9
Page 15 [2] 910/4913/9
Page 16 [1] 914/24
Page 17 [3] 783/1918/20951/20
Page 18 [1] 919/7
Page 19 [1] 921/25
Page 2 [11] 779/18798/6798/20802/9
809/4810/9811/16890/9899/14909/7
1070/20
Page 20 [2] 920/8923/3
Page 21 [1] 926/10
Page 22 [4] 809/4823/18926/211070/25
Page 23 [1] 928/3
Page 24 [1] 928/16
Page 25 [1] 929/9
Page 26 [1] 929/17
Page 27 [2] 824/4929/24
Page 3 [3] 877/3893/7922/13
Page 4 [5] 799/25895/15898/15918/13
947/10
Page 43 [2] 980/2981/14
Page 45 [1] 784/14
Page 6 [2] 897/2898/21
Page 7 [2] 788/11901/4
Page 77 [1] 924/19
Page 8 [3] 822/22902/21070/18
Page 81 [1] 781/15
Page 9 [1] 902/24
pages [10] 769/18769/18780/10822/13
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 344 of 359
P
pages... [6] 822/17835/19837/2838/1
888/21888/23
Pages 2 [1] 822/13
Pages 6 [1] 822/17
paid [29] 846/7846/7846/17877/4877/4
918/25921/20921/20935/17975/13
975/15975/16975/171004/201006/12
1006/151006/171035/231039/81041/17
1041/191042/11045/41056/251061/21
1062/111062/121062/131062/18
paint [1] 856/10
painters [1] 861/3
pairing [1] 1015/9
pandemic [3] 837/221007/61015/8
panel [9] 995/15995/17995/17995/17
995/20995/21996/2996/21997/14
paper [5] 772/16843/5939/11939/17
942/14
paperwork [10] 846/21942/15942/17
943/15943/19991/16992/81027/17
1032/31035/4
paragraph [2] 806/14823/16
paralegal [1] 1050/14
parcels [1] 961/14
parents [2] 987/201001/8
park [1] 1015/25
parked [1] 811/1
parking [1] 811/1
Parkway [1] 810/11
part [40] 772/23772/25775/13780/1
800/11800/13800/14800/15800/22
801/16835/6846/16851/18852/11853/2
854/15855/7856/6856/8856/11857/17
862/11869/14883/25886/20901/23
901/24901/25916/18923/15939/12
948/22960/9980/21982/11003/25
1054/171070/31070/161070/23
partial [1] 1/9
particular [5] 886/23889/14908/9
985/11985/15
particularly [2] 984/181043/4
parties [1] 775/21
partners [1] 1010/10
party [8] 845/141025/121025/13
1025/151025/201047/211048/41048/6
passed [3] 1000/161000/171012/13
passenger [1] 831/1
passive [4] 1035/101035/121035/14
1041/11
passport [8] 990/16990/22990/24
990/25991/3991/7991/15991/16
password [2] 1022/241023/2
past [1] 986/1
Patrick [3] 994/16994/21995/12
pause [2] 770/25833/11
pay [43] 772/14772/20772/24789/21
789/25835/15836/24862/16862/22864/6
895/12975/25977/22978/7981/21006/14
1012/101016/11016/21017/121019/7
1019/141019/201027/111027/20
1027/211028/31034/191036/81040/22
1040/251041/81041/201042/21042/11
1043/31060/61060/71060/71060/9
1060/111060/151066/2
paycheck [3] 953/24954/31044/18
paying [11] 816/10840/11954/4960/10
975/221014/71035/221042/191044/10
1057/251076/2
payment [27] 812/12887/5892/6903/9
903/10903/14903/16903/19908/17
908/19913/16914/3915/16923/15925/6
925/8925/25926/4926/161002/18
1006/131020/141020/191020/21
1034/231034/251035/2
payments [12] 837/17869/2893/25
895/4895/5902/21902/21903/5904/1
905/121003/81019/21
payroll [48] 768/16769/13770/5772/20
780/6780/7781/12782/3789/19789/21
789/22789/25808/19815/16820/22
834/20836/5837/13838/20839/14846/10
846/15847/6847/24862/10890/22895/4
895/5895/11905/3930/22934/14934/15
934/18953/22954/4954/6960/22960/24
980/4980/22980/251006/81008/17
1008/181055/161055/241056/3
payrolls [1] 846/17
pays [1] 927/7
PC [2] 915/15915/19
PDF [1] 1/1
peers [1] 912/1
penis [1] 818/21
people [59] 769/15773/7790/6792/2
793/7793/20794/16794/23849/17849/19
850/12860/8860/18879/25892/10895/11
966/3967/8967/9970/8970/10973/19
973/24973/25974/1975/2977/9977/13
994/18994/23994/23995/1999/13
1005/251006/121007/131007/20
1008/241009/41010/181013/111015/10
1032/61032/151036/21036/41036/5
1056/71058/61058/171058/171058/24
1059/111059/201060/131061/25
1062/111062/121063/13
per [2] 977/161035/21
perceived [1] 852/9
perfect [4] 806/11823/6924/201050/9
period [22] 1/4772/15772/24777/5
783/10784/1784/13784/19784/20784/21
835/15836/2836/24859/17879/13879/13
907/10929/13929/22999/71012/12
1019/13
permanent [3] 999/131007/201009/6
permissible [1] 1066/4
permission [1] 833/7
permit [1] 1003/5
permits [4] 1000/141000/231000/24
1003/6
person [20] 809/15809/18809/19
842/24845/14848/25849/23945/11963/7
970/5970/7976/22977/151002/10
1007/241037/71041/231047/51060/1
1071/4
personal [40] 796/17797/4797/22
797/23816/8840/12842/17845/22845/24
846/4846/8846/13875/18875/20877/25
878/5884/11889/15889/16889/20890/6
899/12903/11903/15904/24906/23
906/24954/24955/1955/1955/3965/13
965/18966/21993/241029/211029/21
1031/31039/51049/20
personally [4] 964/91027/131027/14
1039/11
perusing [2] 769/17780/14
Ph.D [1] 972/4
phone [9] 977/181011/131012/15
1025/151045/201045/211050/20
1059/211069/7
phones [3] 1058/101067/71067/8
photographs [5] 801/20810/25811/3
812/24813/2
phrase [2] 1061/11067/3
physically [4] 783/24784/31061/14
1064/1
physics [1] 781/3
pick [2] 1048/41068/25
pickaxe [1] 974/5
picked [2] 981/161038/11
picture [3] 807/21810/20913/8
pictures [4] 986/6998/15998/17
1049/20
piece [5] 863/3863/5910/21003/16
1003/19
pieces [7] 842/151000/91001/11
1015/221015/231030/31030/3
piles [1] 939/17
pilot [10] 870/24871/1871/6989/3989/4
989/7995/15995/221055/201060/18
pilot's [2] 989/9989/11
pilots [2] 1010/121034/16
Pinnacle [1] 925/4
Piper [1] 989/21
pistols [1] 850/14
pivot [1] 965/5
place [28] 770/13785/6799/18839/13
847/4847/14847/23848/6848/14848/17
848/20848/25849/2849/4894/12913/11
913/20942/10985/181009/61017/8
1046/231047/21057/131062/91062/10
1064/191064/20
places [1] 982/12
plainly [2] 859/61064/18
Plaintiff [2] 763/4764/2
plan [5] 824/3838/6858/201012/1
1069/21
plane [2] 989/19989/22
planes [1] 995/5
planned [1] 838/4
plans [2] 963/61073/14
plastic [9] 816/18817/11817/21820/18
826/19869/3869/6870/131018/5
play [13] 781/5781/17781/19833/7
833/9851/7851/15854/3854/18857/16
875/61023/91061/24
played [5] 780/19780/20833/10833/21
875/7
playing [6] 819/17851/15852/11852/15
979/251021/17
please [72] 767/11767/19769/5771/8
774/22777/6778/24781/16782/17783/4
784/22785/4786/1787/10787/15798/7
798/20799/6799/25802/3802/12803/11
805/2806/12806/25807/9808/23809/1
810/3810/9811/9811/20811/22812/20
813/9813/19814/21815/8815/17824/25
825/3825/18827/18828/6828/9829/23
830/2832/18833/8833/9834/11835/9
836/16837/8839/11875/5875/6876/18
882/14897/21898/15905/21907/25
914/24968/13971/6976/7978/14984/2
1047/171050/121050/14
plenty [5] 821/12856/21958/22962/2
962/18
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 345 of 359
P
plus [2] 900/25938/5
PNC [55] 773/18774/10775/17784/20
788/19788/19789/9798/4798/11825/6
825/7825/14825/21845/10845/12884/10
885/10885/23889/18890/1892/19894/2
895/21896/10897/16897/17898/3898/18
903/19903/20907/6909/13909/16913/12
914/20915/11919/22920/15922/8922/9
927/6928/18929/12929/20934/5935/1
935/11940/9940/10940/11941/16944/3
947/13950/121013/3
PNC Bank [3] 884/10903/19903/20
point [46] 776/13802/25819/19822/9
851/24851/25852/3852/4864/1873/15
880/3888/24890/23895/18899/6902/6
903/7905/8905/11916/10941/9943/1
947/8957/5967/17990/11991/18994/25
995/6996/17998/231002/101004/12
1004/141006/211012/201015/11017/20
1019/161026/191030/11037/91042/14
1053/211063/81068/25
pointed [1] 843/18
pointing [1] 869/14
policies [1] 777/23
polluting [1] 974/25
Ponzi [1] 768/16
popped [1] 769/22
portal [1] 1061/2
portion [18] 1/5783/3822/14822/19
822/21852/24854/13854/16865/1874/18
874/25875/3899/5899/6899/17982/6
982/17988/24
portray [1] 1064/17
position [3] 882/24883/2883/10
possibility [3] 953/3963/121067/18
possible [3] 820/19872/5953/18
Possibly [1] 781/7
post [6] 987/31017/191017/191053/11
1053/151070/10
potential [3] 776/19893/19916/23
potentially [4] 776/22911/10953/10
963/11
powerful [1] 855/18
PowerPoints [1] 1075/25
PPP [169] 768/15768/15769/14769/15
769/18769/22770/3770/5771/14772/5
772/12776/13776/16776/21776/25
777/17778/20779/3780/6782/13782/16
782/25783/8787/8787/22788/8789/21
790/3790/14790/14796/5796/13797/1
799/3800/8801/9803/7803/15806/18
808/5808/19808/21809/13809/16811/14
815/14816/21817/5817/7820/15834/9
835/6838/5839/21839/24839/25840/3
840/10840/14840/15845/21846/4846/14
861/9861/17861/25862/21863/18863/23
864/9864/23864/25875/16875/20875/23
890/21896/4896/18897/5898/18903/23
904/2905/8906/6906/7907/2907/7
914/10916/4916/11916/15916/20916/24
917/5927/18927/25929/3931/1931/7
931/9932/14933/22934/19936/11936/19
937/12937/24938/4949/16950/25950/25
951/17953/19955/6958/16960/24961/16
1006/231006/251007/41007/231009/5
1009/221011/21013/211014/41014/12
1015/181019/21020/91020/151021/18
1027/171029/231029/251030/61030/13
1033/111040/151040/191040/241051/3
1052/181054/211054/241056/18
1056/231061/21061/191061/251063/1
1063/201064/61064/111064/111065/3
1065/41065/81065/251066/51066/20
1066/241067/21067/31067/51067/14
1067/151067/221068/18
PPP loan [34] 769/22770/3770/5772/5
776/21776/25780/6789/21820/15897/5
1006/231006/251007/41007/231011/2
1014/41019/21020/91020/151027/17
1029/231030/131040/151040/19
1040/241051/31054/211056/231061/19
1063/11064/61064/111066/201066/24
PPP loans [1] 769/15
precisely [1] 960/20
predating [1] 1046/13
prefer [2] 967/1967/3
prejudicial [2] 818/18818/20
premarked [3] 786/3801/18805/2
prep [1] 858/1
preparation [3] 1/131040/141040/23
prepare [5] 887/10931/171008/25
1060/221071/13
prepared [3] 773/8831/191008/17
preparing [5] 1022/41022/51036/17
1040/191060/22
presence [3] 850/19859/9912/11
present [6] 827/9829/19830/13830/17
830/19830/22
presented [4] 769/16868/14962/8
966/18
presenting [1] 853/17
press [1] 983/9
Pressley [2] 830/23831/1
Presumably [1] 948/22
pretty [7] 819/12845/17861/20995/2
997/171002/201008/6
prevalence [1] 972/15
prevent [1] 858/1
prevented [1] 1068/14
previously [3] 885/5885/151021/25
price [18] 799/23799/24802/18802/23
804/18804/20809/6809/7812/9812/9
812/13814/2814/4814/7814/8816/2
816/31002/19
primarily [1] 772/14
primary [5] 779/9985/10999/6999/8
999/8
principal [20] 770/13839/12846/20
847/4847/14847/22848/6848/14848/17
848/20848/25849/1849/2849/41007/13
1007/151009/61064/191064/191064/19
printed [1] 919/25
printing [1] 824/17
prior [17] 768/18790/3817/5831/10
840/13859/21865/5883/4884/15893/1
896/4898/19901/18906/10907/7916/10
917/2
private [3] 968/20969/7989/11
probable [1] 964/5
probably [15] 805/12821/3827/18
867/11867/20868/9879/19879/23883/7
927/2938/23957/41053/251056/11
1072/2
probation [1] 968/24
probation officer [1] 968/24
problem [6] 766/17810/7843/15845/20
852/20854/4
problems [4] 767/10993/191013/15
1070/3
procedure [3] 816/17818/171051/25
procedures [3] 826/20826/23826/25
proceedings [7] 763/12763/18831/10
1076/151077/81077/111077/13
proceeds [23] 787/8787/22788/8790/4
796/5796/13796/17796/23797/1799/3
801/9803/9803/16808/5811/14815/14
816/21816/25861/9865/6938/4962/6
962/9
process [8] 768/7843/7851/13983/5
992/141002/241054/251070/9
processed [1] 1062/8
produced [1] 763/18
productive [1] 1012/7
profile [7] 790/18791/2791/8807/12
807/23813/15965/25
profiling [3] 790/18791/24792/1
profit [2] 1037/11037/1
program [15] 768/15768/16769/14
771/15772/12782/16808/19838/5846/11
846/16953/24953/25954/1960/24
1011/18
progress [1] 989/8
prohibited [1] 1/8
project [1] 1037/17
pronounce [1] 985/10
proper [5] 791/8791/14791/18818/1
851/9
properly [2] 973/21058/5
properties [3] 948/20961/121000/14
property [33] 799/15799/16799/20
799/21800/17801/2802/16802/16804/14
804/16804/20842/15908/3908/10910/2
910/5913/11913/17913/20915/2915/16
915/19918/24936/8946/14961/121000/9
1001/111001/251003/171003/191030/3
1030/4
prosecutor [2] 943/11014/19
protection [7] 768/16769/14780/6
953/241038/51039/11039/2
protects [1] 1039/5
prove [3] 957/91054/121074/14
proved [1] 959/16
proven [1] 959/14
provide [9] 838/5945/18945/19976/4
1045/201050/231057/61057/121059/11
provided [11] 769/15772/6773/3778/6
816/7816/8900/19939/23940/23941/19
1058/7
provider [1] 777/23
providing [1] 793/19
provision [2] 823/201071/1
psychic [1] 1064/10
public [3] 768/20769/16770/9
publish [5] 806/10806/12811/9815/8
986/19
publishing [3] 805/16805/17805/18
pull [51] 777/6778/25781/15784/9
784/13785/4787/10787/15789/11789/12
794/20799/6802/3802/19803/10803/10
805/7806/25807/8810/3811/22813/19
825/2834/11847/20860/3876/17897/20
899/13904/10905/5908/25909/23913/22
917/14918/10920/7922/12924/4924/18
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 346 of 359
P
pull... [11] 925/18932/6951/11951/14
971/12985/131048/111050/111052/7
1057/31059/24
pulled [5] 770/10770/14853/201053/15
1057/6
purchase [56] 799/20800/2800/15
800/16801/1802/16804/14804/19808/6
808/8808/15808/25811/25812/9812/22
813/1813/23813/23815/15815/21815/24
816/2816/3839/18861/10863/1876/22
886/20887/2888/4908/3908/6908/10
908/23910/2915/2915/5918/17919/12
919/18919/20920/4922/5923/5923/8
923/18923/19925/9925/13926/1930/8
936/3946/8946/14946/20954/14
purchased [17] 799/15808/9811/13
812/1815/13816/18839/24839/25864/14
876/23921/13925/24926/19927/3927/22
928/7942/9
purchases [23] 783/22785/24820/17
862/8864/14876/4886/23887/3887/8
887/8894/8906/21907/20907/22918/23
919/4923/10926/16942/2947/19949/24
950/17950/23
purchasing [1] 813/25
purple [1] 932/25
purported [1] 770/25
purpose [9] 795/17803/25804/2888/13
961/171007/21007/21007/41066/4
purposes [2] 831/13932/3
put [44] 771/7782/17816/4817/25
821/21822/22823/13823/24828/18852/1
858/15860/12860/12860/18864/13879/6
879/25889/6890/15932/17932/20935/22
935/23946/15966/6974/8974/9978/16
983/41006/171015/11028/171029/2
1032/121046/211047/11049/21052/8
1053/101053/161064/141075/61075/9
1075/19
puts [2] 817/24934/1
putting [5] 861/3870/18911/31012/22
1018/21
Q
QT [2] 784/6785/13
qualified [3] 965/4966/91013/25
qualify [9] 963/15967/21013/251014/5
1014/61021/241064/61064/71066/1
quantification [1] 862/25
quantify [1] 863/14
quantity [1] 1027/25
quarter [2] 835/12836/20
quarterly [2] 834/20836/5
question [47] 795/5803/24817/17818/2
819/7824/10834/21839/11839/12839/15
843/14847/11847/13847/16847/18849/9
849/10849/24859/23859/25862/11
865/17866/20866/25868/15874/13880/3
881/16927/2950/7964/2967/4979/24
980/1980/6980/7980/14980/17990/1
1037/241057/171063/51063/131067/16
1073/71073/81073/12
questioning [1] 819/22
questions [18] 820/7821/3824/6824/8
830/16840/19841/2854/14881/23938/16
948/25970/12975/6979/4984/9999/17
1027/31040/4
quick [4] 979/91010/11016/81069/11
quickly [7] 822/7822/8835/2859/10
859/13861/201011/7
quite [6] 797/23797/25931/161011/11
1012/41012/24
quote [1] 960/17
quote/unquote [1] 960/17
R
R-I-C-H-A-R-D-S-O-N [1] 882/17
race [1] 792/3
rage [1] 769/20
raised [4] 824/13828/4960/23987/16
rampant [1] 769/14
ran [1] 1038/12
range [8] 814/1814/25833/1841/21
922/4948/16950/181034/13
rapport [1] 859/22
rate [3] 857/101036/41037/13
rather [6] 770/1794/14794/16818/12
821/7851/2
rating [3] 989/12989/13989/17
ratings [3] 989/6989/6989/7
RDR [2] 763/201077/18
re [1] 881/15
re-redirect [1] 881/15
reach [1] 1076/12
reaction [1] 1011/10
read [22] 774/3774/4775/10798/7
798/20824/18825/25830/15839/11
847/18868/11007/251008/21008/7
1009/71009/191019/151062/21064/9
1064/181065/11065/14
reader [1] 879/16
reading [4] 879/14954/1966/181007/11
ready [12] 766/6820/1854/5910/11
1012/221022/111027/171032/31035/4
1040/151040/191071/18
real [25] 799/11800/15800/22804/11
820/18822/8840/12861/11873/14887/3
903/8918/23919/4930/7942/12942/12
946/8946/19949/24950/16974/171010/1
1016/81036/231069/11
real-time [1] 942/12
realized [2] 1015/121061/12
really [16] 790/3794/19842/10852/13
854/2854/21856/6856/15869/22911/24
942/13957/12985/191000/51001/12
1033/20
Realtime [1] 763/20
rear [1] 802/11
reason [20] 794/9794/24796/11844/2
853/13855/9872/15891/13904/6953/17
994/31012/171025/41025/231036/15
1038/61043/31060/121065/211067/1
reasonable [3] 860/10863/121014/11
reasonably [1] 1068/10
reasons [4] 865/15993/6993/111017/18
recall [15] 810/16816/8816/22859/1
869/18870/12871/3881/3917/1935/2
935/5941/121018/151018/171018/17
receipt [5] 803/6803/15816/21817/5
936/11
receive [3] 783/7876/141053/25
received [21] 783/1799/4800/7800/14
803/9806/21835/14836/7836/23838/18
881/6898/18905/3905/12914/16916/5
941/16951/161034/21052/61053/19
receiving [1] 1019/11
recess [3] 822/5912/6982/22
recipient [1] 941/16
reclip [1] 852/23
recognize [5] 831/9887/22986/5986/6
1020/6
recognizing [1] 962/7
recollection [4] 851/12852/9852/10
867/14
recommended [1] 1003/9
reconstructed [2] 870/11870/15
reconstruction [1] 870/12
record [22] 767/19769/5769/16770/9
774/3851/4882/14885/5891/18909/3
920/10956/19957/9966/12968/13971/6
980/10981/5981/25982/2984/31077/13
recorded [4] 763/18831/7853/3966/15
recording [38] 831/13832/4832/7
832/22833/7833/9833/10833/21833/23
838/9851/3852/21852/24853/11854/16
854/18856/12859/21861/3866/3867/3
874/11874/16874/18874/25875/7878/12
878/15878/17879/5880/9880/11880/15
880/15981/241017/71031/211032/19
records [74] 773/5773/5773/6773/9
774/8774/10775/1777/2777/4781/12
783/14783/25785/20785/23787/5797/23
815/23815/24817/8820/16834/1840/2
840/7840/18842/18843/17845/18846/3
863/13865/4865/11870/6876/9876/10
876/12876/13880/22881/6883/24884/2
884/3884/5884/6884/19884/20886/8
886/13886/20887/4887/11887/14888/3
888/3888/4888/9925/22930/6939/11
939/17940/2940/5940/9940/11940/13
940/16942/6949/21953/181034/21
1048/91048/101050/21074/151074/15
RECROSS [1] 878/10
RECROSS-EXAMINATION [1] 878/10
rectify [1] 991/2
red [8] 789/23796/25797/2804/7873/16
873/17934/4960/23
redirect [9] 854/11856/21857/15865/23
873/25874/2881/15949/2949/4
redone [1] 1018/7
reduced [1] 1077/11
Reel [1] 926/3
Reeves [9] 780/16873/4964/221056/4
1056/51056/61056/71056/121056/13
reference [1] 1034/24
referenced [2] 949/12955/17
referencing [2] 1/6897/24
referred [1] 934/8
referring [6] 807/5807/6888/231048/10
1055/151058/17
refinery [1] 1004/21
reflect [7] 769/5787/18802/15808/14
888/8926/4931/21
reflected [9] 826/23892/13893/10
896/23899/17901/7902/4926/23934/4
reflecting [5] 800/16829/8890/11898/9
905/25
reflects [2] 799/11799/20
refrain [1] 980/7
refresh [9] 778/15781/13809/24867/14
867/23869/10869/13872/17881/2
refreshed [1] 867/15
refreshes [1] 868/8
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 347 of 359
R
refund [32] 789/1799/4803/7808/5
811/15815/14840/1840/4840/11840/14
840/14840/15862/5864/9892/1905/9
906/7907/3927/18928/1930/23931/2
931/11936/19938/1960/5960/91027/4
1029/11029/61029/221041/13
refuse [2] 875/13875/14
regard [2] 982/171012/2
regarding [2] 897/81012/2
regardless [1] 1018/19
regards [11] 883/21884/5885/11886/12
919/14922/12923/19953/21955/5960/19
961/8
region [14] 988/2988/31000/21000/6
1000/81000/81000/91000/101000/12
1000/131003/151003/201005/22
1005/23
regional [1] 988/1
regions [2] 973/16973/16
registered [1] 972/24
registration [4] 825/6825/21862/20
1030/3
regulated [1] 973/1
regulations [2] 1065/21065/14
reinforced [1] 1019/15
rejected [8] 796/18796/181021/8
1024/171025/231047/251048/21049/6
relate [4] 913/25924/6924/231007/14
related [23] 773/7773/7773/8773/18
774/20804/24815/16850/25885/1886/13
887/4908/5916/5917/19920/10922/14
925/22930/7954/3955/14956/101059/12
1070/12
relating [1] 1064/16
relation [4] 803/6903/21918/3958/15
relatively [1] 770/12
relevance [4] 794/19963/7963/11
965/22
Relevancy [1] 803/21
relevant [9] 768/19792/7792/17792/20
851/16876/12883/9959/5965/19
rely [3] 1055/181055/201058/24
remaining [4] 924/23927/21928/19
1065/24
remember [31] 784/6790/2849/22853/4
853/13866/22866/23867/2867/6868/7
869/24873/11880/16889/1935/15941/5
941/14941/23947/7961/4980/11005/3
1005/191016/251017/21027/61031/2
1031/171039/121074/41074/5
remind [3] 898/17960/141075/18
reminded [1] 912/8
reminding [1] 912/14
remove [1] 974/11
removed [5] 934/6952/18952/19952/25
1070/22
renew [4] 829/24831/25874/221070/6
renewal [1] 828/4
rent [3] 772/22846/16895/12
renting [2] 840/91052/17
repaired [1] 842/5
repairs [1] 810/17
repay [2] 1012/141028/6
repeat [1] 786/9
repeated [1] 932/11
report [4] 834/19837/121042/91042/10
reported [1] 1077/7
reporter [7] 1/31/71/12763/21984/17
1077/41077/19
REPORTERS [1] 1076/17
reporting [3] 836/5879/41042/6
represent [5] 813/2934/24935/21952/6
986/12
represented [1] 815/24
represents [4] 804/11903/2927/25
932/13
request [6] 850/24851/8856/8918/2
931/24993/5
requested [2] 777/11061/20
requests [1] 766/13
required [9] 771/24958/171003/8
1007/91021/181023/191042/101042/11
1075/19
requirement [3] 782/131007/71043/23
requirements [5] 771/14771/19780/9
846/191008/1
research [3] 966/191013/231038/9
researched [2] 1039/21039/2
reshuffling [1] 766/17
reside [1] 849/1
resided [2] 783/24970/7
residence [24] 770/15778/10801/14
802/7802/11839/13840/13846/20847/5
847/14847/23848/6848/14848/17848/20
848/25849/2849/4999/141007/13
1007/151007/201009/61064/20
residency [2] 999/6999/8
resident [1] 1047/9
resolve [3] 766/25767/1963/4
resolved [1] 1073/21
respect [2] 839/5913/10
respliced [1] 855/22
respond [1] 1026/6
response [2] 839/15868/11
responsibility [3] 1014/171065/8
1068/12
responsible [1] 1014/7
rest [4] 854/3854/5964/231030/5
restarted [1] 1013/13
restaurants [2] 784/9784/11
restock [1] 1012/8
restraint [1] 819/9
restricted [1] 1/3
rests [1] 956/10
resubmit [1] 1048/21
resubmitted [4] 1021/91025/171025/25
1047/25
resubmitting [1] 1048/3
retain [5] 772/14777/24778/3778/4
778/12
retention [1] 777/23
retirement [1] 768/7
return [47] 776/22782/21789/3806/21
809/21809/25810/1810/8817/8820/15
862/1863/20864/19878/3881/61021/1
1021/31023/151023/161024/91024/10
1024/161024/171024/191025/14
1025/171025/211025/221027/10
1028/181028/201029/161034/21043/5
1043/171044/71046/171046/221047/2
1047/81047/91047/241048/21048/19
1048/211049/181051/19
returned [1] 876/16
returns [19] 776/15776/19776/25
777/13778/15778/16959/7959/71008/20
1021/51021/201022/181028/241034/15
1043/151043/201044/11046/61048/24
revealed [2] 783/11804/21
Revenue [1] 776/9
review [16] 773/24786/2883/17884/16
884/24885/1886/20890/6891/1894/25
928/11939/11939/21940/151033/9
1033/11
reviewed [14] 780/1831/10838/10884/9
884/22886/13887/2918/24919/10923/25
925/21943/15943/19951/3
reviewing [2] 891/8930/6
revising [1] 851/14
rewind [1] 833/18
reword [1] 950/2
reworked [1] 982/13
Richardson [23] 882/6882/9882/16
882/17882/21886/12887/10887/22
888/21897/4897/23902/4905/24908/2
913/5913/25922/2930/16932/9938/12
949/6961/191074/2
rifles [3] 850/14859/51032/7
rig [4] 849/61007/161007/181007/20
right [391]
right-hand [2] 771/11803/13
rights [8] 829/3829/5829/6829/15
830/15830/16879/141000/17
ring [2] 873/101025/15
rise [18] 767/7790/21795/2817/14820/3
821/15822/2824/22850/21858/5910/15
912/24967/23979/14982/21983/15
1072/101073/5
road [1] 911/23
Romania [3] 1046/51055/71071/4
Rome [1] 1025/12
room [2] 832/121059/19
Roughly [1] 1030/1
routed [1] 961/21
routine [1] 1023/7
routing [1] 952/1
Rover [12] 814/1814/1814/25833/1
841/21922/4922/4926/14935/25936/4
948/16950/18
rudiment [1] 974/6
rudimental [1] 974/22
rule [7] 819/8956/20962/201074/5
1074/71074/131074/16
Rule 29 [2] 956/20962/20
rules [3] 771/21857/111063/25
ruling [1] 956/10
run [8] 859/25876/1876/3919/19993/17
1011/181033/211033/22
runaround [1] 998/4
running [3] 792/24793/2831/1
runs [1] 793/1
rushed [1] 1032/6
rushing [2] 911/151062/3
S
S-O-L-O-M-O-N [1] 971/9
safe [1] 853/15
said [86] 777/21788/1807/1833/23
839/22846/22847/13853/21853/22862/2
866/14866/19868/9869/7871/23871/25
875/19878/12878/14878/17878/23879/3
880/13880/14880/18880/19934/14
937/20943/23946/16946/24951/3953/22
961/1961/1961/5963/21963/24963/25
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 348 of 359
S
said... [47] 965/1966/15967/6975/20
975/20976/2976/2980/12980/21982/8
1001/141018/131018/131018/151019/8
1020/121021/221022/11032/11038/17
1038/171038/221039/11041/81043/10
1043/141043/171044/61045/31045/9
1048/11049/121049/151052/231053/23
1059/81060/171060/241063/221064/8
1065/41065/51065/91065/121066/14
1066/161077/11
Sal [1] 1074/1
sale [3] 800/2804/20815/21
sales [11] 799/23799/24802/18802/23
804/18809/6809/7814/2814/4926/24
927/13
Salt [1] 998/10
same [79] 777/18777/19778/2778/19
782/23790/12798/19799/14803/20
811/16813/16824/14834/17862/6872/5
876/6877/11889/12892/18893/12893/12
894/2894/2894/6897/12900/4900/8
902/10903/4903/18905/2905/9908/15
908/18912/13913/20915/9915/17919/24
920/3920/4922/5922/11923/1923/9
923/16927/17927/24929/12929/22930/6
934/6934/23938/22945/15945/16945/20
952/9955/6955/7957/7959/22970/5
995/141010/181013/151016/161016/20
1016/221016/241018/131018/14
1018/181018/201025/231044/171049/1
1054/81060/4
sand [3] 974/10977/23978/5
sat [2] 859/17859/18
sausage [1] 869/23
saved [2] 1038/201046/13
savings [2] 892/15893/20
saw [49] 770/11785/20791/6791/6
791/12792/13792/24807/21811/4812/18
812/23812/25815/2840/17840/18870/16
871/13871/15890/24893/14894/19903/4
907/20908/13916/22926/13926/24
941/15942/9942/18943/22943/24946/20
946/22954/101007/121007/211023/25
1025/201025/211031/241035/241047/8
1047/111048/251049/11050/21051/24
1067/20
say [77] 769/14777/21778/3781/17
787/24791/5791/10795/21817/24834/7
834/21838/24839/5843/6845/2848/10
849/17854/15855/6855/14856/5863/5
863/22864/25866/19867/18867/23
868/11869/9875/16877/11891/25893/25
912/10931/8936/14937/15942/17943/21
945/15945/20953/18960/13960/23
963/22964/11965/5965/6965/14965/15
972/20975/24978/11978/19986/24997/9
1000/51012/81014/31014/91020/11
1023/81029/91037/41037/51037/7
1040/211046/161048/11049/21053/9
1068/61069/21071/101073/21074/3
1075/6
saying [32] 854/21855/18856/1891/22
900/24921/1960/3960/24962/3965/11
965/211008/241017/231018/151018/18
1029/31041/141042/151045/131047/5
1051/101055/121055/161055/18
1055/201056/171056/221057/31058/22
1061/181062/171063/20
says [37] 787/25831/4846/21847/8
847/22848/2848/13848/13848/16853/6
853/12854/22866/24867/1878/2885/19
893/24893/25927/6940/5952/13960/22
977/15980/6983/121007/121014/6
1020/161044/21045/21047/231052/24
1053/61054/61056/31064/181064/25
SBA [3] 1013/241014/81066/9
scale [18] 963/19972/17972/18972/18
972/21972/23972/24972/25973/2973/6
973/12973/15973/17973/20974/21
974/22974/251001/1
scare [2] 853/18859/15
scared [17] 853/9853/10875/12878/14
878/17879/3879/3879/4879/8879/10
879/11879/18879/19879/23879/25
880/18881/20
scary [1] 1032/13
scene [3] 859/12860/10939/8
scheduled [1] 817/21
scheme [1] 958/18
schemes [1] 768/17
school [7] 972/4985/10985/101016/14
1016/151016/201016/22
scope [2] 951/12953/8
Scott [3] 767/12767/14767/21
screen [10] 771/8800/12805/8814/3
823/3831/20832/6899/23932/17933/6
scroll [1] 814/4
scrutinize [1] 1056/19
search [2] 969/251056/9
seat [4] 830/24830/24830/25831/1
seated [19] 766/5767/9790/23795/6
820/11821/17822/6824/24830/23858/8
882/18912/7913/1967/25983/17984/1
1069/181072/121073/15
second [18] 767/1790/20794/14817/13
830/12846/1850/20878/12924/9948/12
948/13952/5959/16983/1994/11014/5
1048/141066/5
secondary [2] 1016/201016/22
seconds [2] 833/191032/10
Secretary [2] 770/11782/23
section [4] 768/22775/19787/16788/22
secured [1] 827/8
security [22] 872/3969/17991/20991/25
993/5993/8993/15994/1994/5994/6
1017/181021/81023/221024/11026/22
1026/231034/241047/121049/131060/6
1060/141062/11
see [80] 769/3771/10772/17773/11
778/7785/23797/22797/25800/5803/8
810/15812/16814/13817/9820/16820/22
822/1832/3832/6834/1853/21853/22
856/1856/7856/15871/12875/25876/3
893/4893/5894/24894/24895/5895/6
895/14895/20896/3901/9902/8903/5
907/19910/17918/6924/15925/5927/5
930/7930/9932/23934/15934/18936/11
936/15936/20937/5940/23941/4941/9
941/24942/17942/20950/11951/7952/13
952/15964/9975/3978/15998/15998/18
1003/51026/191037/211040/131049/23
1052/141054/41064/211071/141073/4
seeing [2] 895/241068/24
seeking [1] 839/1
seem [12] 818/12855/4855/11857/9
859/15874/10875/11875/12878/14954/6
975/21018/4
seems [7] 793/3818/12833/18852/7
852/16911/141055/3
seen [14] 810/13812/14814/11840/2
871/9934/11964/9965/16967/10973/20
1043/201046/241048/81052/12
seize [2] 842/2842/4
seized [20] 810/16811/2811/12812/17
814/15814/17816/13841/17841/20
841/21947/24948/1948/7948/11948/13
948/14948/16948/181030/61031/14
seizure [7] 816/13832/25841/19841/20
850/2858/23858/24
selected [2] 896/1928/25
self [3] 819/8891/17968/20
self-employed [1] 968/20
self-explanatory [1] 891/17
sell [1] 1002/17
selling [1] 1058/19
semitruck [1] 808/10
semitrucks [1] 808/9
send [8] 820/6909/211029/51029/5
1029/91034/231041/151053/12
sending [4] 844/20914/5920/13922/17
sends [3] 897/17930/14961/10
senior [3] 768/23989/18994/14
sense [4] 770/181029/71036/241050/9
sent [11] 909/13913/14914/19921/23
923/221006/181027/11051/211052/20
1053/181062/6
sentence [2] 980/231075/17
sentencing [1] 969/5
separate [1] 874/16
separated [2] 953/19993/21
September [8] 828/23836/3913/15
920/191051/101052/141052/211052/25
September 1st [2] 1051/101052/21
September 2018 [2] 1052/141052/25
September 20th [1] 913/15
series [2] 898/6952/5
served [2] 1057/81057/10
service [4] 776/10777/23778/61015/24
services [3] 1003/41003/71017/12
set [5] 1038/41039/41039/81067/13
1071/23
setting [2] 1036/171038/4
settle [2] 859/19974/13
settlement [4] 799/10799/18802/15
803/5
seven [5] 822/4853/5958/6962/4982/20
several [7] 885/18887/2887/3944/11
991/101010/181068/5
shackled [1] 912/12
shady [1] 1010/24
shafts [2] 1035/161035/16
shape [1] 1072/17
she [102] 871/15872/8872/10872/11
872/11872/13872/19911/2911/25961/1
961/6961/20993/22993/22993/24
1006/121008/161008/171008/18
1008/191008/191010/61010/141010/15
1010/231021/201021/221022/21022/2
1022/31022/221022/221022/241023/6
1023/111023/121023/131023/13
1023/141023/151023/171023/19
1023/251023/251024/41025/191025/20
1025/201025/201025/211025/21
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 349 of 359
S
she... [51] 1025/221025/251026/2
1026/61026/61026/101026/141026/16
1026/201046/31046/31046/51046/11
1046/161046/211046/241047/11047/4
1047/111047/121047/131047/14
1047/151047/231048/11048/11048/1
1048/11048/21048/21048/31048/25
1048/251049/51049/51049/61049/8
1049/171049/211050/101055/41055/5
1055/81055/111055/181055/231055/24
1055/241055/251069/61069/6
she's [15] 853/20872/7911/241046/19
1048/181049/231055/61055/61055/12
1055/131055/161055/201055/20
1055/211061/12
sheet [1] 777/8
shipping [1] 1037/3
short [6] 911/5967/12967/14997/18
1038/111041/22
shorter [1] 1012/13
shortly [2] 816/21900/7
shot [1] 932/19
shotgun [1] 790/11
should [19] 766/8770/19771/11773/21
784/15791/6792/18810/19814/3831/3
892/1937/15962/8965/3977/23995/9
1007/131029/21072/23
shout [1] 1075/24
shout-out [1] 1075/24
shovels [1] 974/5
show [11] 839/23844/7844/9846/3
862/4869/17910/4920/13957/81014/18
1032/1
showed [8] 783/17839/25844/1849/7
864/18941/21977/14992/20
showing [9] 799/5807/13810/18854/12
899/23918/14918/15935/9987/5
shown [2] 873/15959/13
shows [12] 782/15826/12874/12890/13
896/25897/8899/20906/19906/20908/9
916/3935/25
shut [6] 790/241013/171013/181013/22
1014/221014/24
shutdown [2] 947/15947/17
sic [3] 874/41001/41039/15
side [7] 777/8777/8813/15818/25
1037/171052/81052/8
sidebar [1] 820/5
sides [1] 1076/3
sign [1] 829/8
signaling [1] 869/21
signature [20] 807/23825/9825/10
825/21826/5829/18829/19829/20829/21
830/8830/8830/10830/11830/12830/12
830/14830/18884/24942/21944/25
signatures [1] 830/6
signed [10] 825/10835/4835/21836/13
837/4838/1942/15942/201056/22
1063/18
signer [2] 807/22807/24
significance [2] 791/13791/22
significant [3] 782/14803/17893/15
similar [1] 803/21
simple [2] 845/17961/20
simply [1] 960/16
simulator [1] 1010/10
since [5] 890/18902/7994/61003/6
1026/21
single [1] 1056/17
sir [35] 766/7766/20795/25820/12
832/17840/22840/25844/13847/11
847/15847/19847/25868/7868/18879/16
881/25882/2938/9956/1968/19971/18
971/20973/23975/12979/6979/8981/20
984/7987/11987/15988/4990/11008/8
1073/161075/14
sit [2] 817/11965/14
sites [1] 1006/2
sitting [1] 1059/18
situation [4] 858/21859/11859/22966/4
situations [1] 844/17
six [13] 929/22957/20960/12961/8
969/23970/1970/5970/81000/161005/20
1067/81067/81067/10
size [3] 770/4770/20973/22
sizeable [1] 849/25
skew [1] 851/19
skewed [2] 851/3853/19
Skype [5] 1001/201001/211001/23
1002/61002/9
SkyWest [6] 998/4998/6998/7998/19
998/20998/21
sliced [1] 850/25
slide [4] 897/7906/19908/9913/10
Slow [1] 987/18
slowly [2] 984/111000/5
small [27] 787/21787/23787/24787/25
963/19963/19964/7964/18964/18972/18
972/23972/24972/25973/2973/6973/12
973/15973/17973/20973/20974/21
974/22974/25975/3978/81000/251001/1
small-family [1] 1000/25
small-scale [11] 972/18972/23972/25
973/2973/6973/12973/15973/17973/20
974/251001/1
smaller [3] 887/17887/20888/1
smallest [1] 989/19
smelled [1] 792/22
Smith [1] 943/21
smokes [1] 793/2
snacks [1] 821/10
sneaky [1] 1036/15
snippet [1] 777/7
Snoopy [1] 780/25
Snow [4] 873/10873/111009/141009/16
so [603]
Social [21] 872/3969/17991/20991/25
993/5993/8993/15994/1994/5994/6
1021/81023/221024/11026/221026/23
1034/241047/121049/131060/61060/14
1062/11
Social Security [21] 872/3969/17
991/20991/25993/5993/8993/15994/1
994/5994/61021/81023/221024/1
1026/221026/231034/241047/12
1049/131060/61060/141062/11
software [7] 1044/11044/21044/12
1044/161044/201045/21045/3
soil [1] 1007/19
sole [3] 1014/171051/111054/7
SOLOMON [2] 971/1971/8
solves [1] 854/21
some [89] 769/20783/25795/13817/21
821/6822/9822/13826/19833/3833/4
843/9844/2845/14846/15852/23856/7
857/14862/19862/19862/20865/5872/22
883/14883/18884/5884/19885/8885/23
886/23887/1890/6891/16894/19895/11
895/12898/6901/6907/22913/6916/22
919/10926/19929/21937/1937/5941/9
941/20942/2944/14944/16945/1956/12
960/10969/9969/11970/3970/6970/7
973/5973/7973/11974/3974/3974/5
974/6974/12974/19974/19976/10977/25
995/24996/17998/23999/171006/6
1006/71012/111015/171018/51021/23
1022/111028/221028/231034/15
1057/251058/11065/211067/231071/4
somebody [18] 878/2878/2939/16
940/4965/14968/2973/24973/24978/12
978/25981/2998/111041/201053/10
1056/121056/131064/121068/3
somebody's [2] 1059/251076/3
somehow [4] 1001/171039/141055/12
1055/14
someone [14] 877/24877/24891/21
942/18965/21976/151023/11027/13
1029/151057/141057/221059/81059/16
1065/15
something [53] 766/16782/1792/3
794/22818/11832/10832/19852/2853/15
863/8865/14865/20866/2870/15872/8
897/13902/18937/7941/22948/20958/18
961/2961/6963/5963/23976/3991/13
998/251001/31003/11003/91012/17
1012/191014/101015/71018/91018/15
1019/31021/221034/91037/31037/8
1039/61040/211043/231044/181051/19
1053/101068/71068/81068/81068/11
1071/14
sometimes [6] 794/17939/12939/13
945/19954/231053/11
somewhere [3] 805/15827/13999/14
soon [4] 860/14897/15962/131012/25
sophisticated [2] 974/6974/20
Sorohan [2] 903/8908/19
sorry [42] 766/21782/1784/15786/9
805/9808/4809/4819/14822/3823/10
825/13854/6858/2858/7858/8865/24
866/5869/22880/16894/25896/14905/22
916/9921/3921/8921/20936/14943/17
949/25964/1966/23968/6975/14977/13
978/91022/61022/71022/101054/20
1063/41068/181069/18
sort [17] 792/2819/24841/3844/16845/2
851/14861/6871/1925/5938/24939/11
941/81000/31001/91002/251004/21
1007/16
sorted [2] 1061/91061/10
sought [2] 838/22838/23
soul [1] 964/24
sound [3] 863/11947/21072/6
sounds [4] 833/14863/12875/1912/22
source [20] 788/7790/6798/25807/25
808/4844/22894/18909/18921/22922/25
925/15926/7927/15927/21927/23950/3
960/18960/20961/16962/1
sourced [3] 894/21914/10954/15
sources [2] 790/7876/5
Southern [3] 927/121022/121022/15
spaces [1] 1043/21
speak [6] 828/24829/5829/7829/8
875/14984/11
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 350 of 359
S
speaker [1] 833/15
speakers [1] 833/15
speaks [1] 880/15
special [13] 768/2768/4768/10768/10
768/24776/7776/8829/19830/13830/22
832/23832/23848/19
specialist [1] 969/5
specialized [1] 793/19
specialties [1] 969/3
species [2] 1003/111003/12
specific [14] 769/17810/16823/14
853/23856/16884/5888/23896/6907/22
918/3920/24949/211013/91013/11
specifically [6] 816/17863/14875/16
884/14920/231051/1
specifics [1] 853/24
speculate [1] 1047/13
spell [11] 767/19882/14968/13971/6
972/20973/3984/2984/171000/51000/8
1004/7
spelled [4] 984/21984/211000/61001/7
spelling [1] 1053/19
spells [1] 1004/8
spend [4] 808/12821/19821/22910/18
spending [1] 962/14
spent [5] 907/2926/17936/2951/4
1030/2
spit [2] 1025/61025/6
spoke [5] 859/19859/20859/201013/5
1013/6
spoken [1] 1058/11
spot [1] 910/7
Springs [1] 785/15
squad [2] 768/12768/12
stand [5] 780/13818/1826/22826/24
979/21
standard [3] 790/7858/15858/18
standing [1] 942/18
Starbucks [1] 937/8
start [10] 769/12837/23841/2932/12
999/241001/31001/171003/211063/8
1063/12
started [21] 797/15840/11843/22879/13
880/11890/23902/13902/22969/25
999/251003/11003/141003/221013/10
1015/41015/61019/211022/31035/15
1035/201037/17
starting [5] 912/1928/24932/141002/24
1002/25
startle [1] 879/10
startled [1] 859/16
starts [3] 793/6852/25911/24
startup [2] 1067/51067/6
state [11] 767/19770/11770/12782/24
851/20880/6882/14968/13971/6984/2
1020/23
stated [5] 870/231019/81019/12
1028/251068/7
statement [16] 784/12784/18784/20
799/10799/11802/15803/5825/6830/14
830/15851/20896/25899/20918/15943/9
966/15
statements [12] 811/1883/17884/3
884/4884/9889/6891/3939/21966/14
966/14980/131020/6
STATES [38] 763/1763/3775/19839/12
846/20847/4847/15847/22848/11848/15
849/5882/5882/23882/24883/17959/4
968/24971/24988/5988/10990/15993/14
994/15999/91002/51007/141007/16
1007/191007/211055/41055/131055/17
1059/231061/161064/21064/201077/5
1077/9
stating [1] 1012/17
station [1] 1048/12
stay [9] 910/14951/4983/2983/2983/3
996/201040/71069/61069/9
staying [4] 925/171057/141057/22
1057/24
stealing [1] 1058/19
Stenograph [1] 1077/7
Stenographic [1] 1/12
stenography [1] 763/18
step [11] 773/2790/20792/23817/13
845/2850/20956/2956/14979/61069/8
1073/16
steps [1] 954/21
stick [4] 779/25781/2782/61075/17
sticker [2] 831/41075/9
still [20] 858/21864/4912/12921/5
961/11992/13993/23999/81002/51002/6
1003/241004/101004/101030/191034/8
1052/21056/221057/81059/171073/9
still -- this [1] 1052/2
stimulus [1] 892/9
stipulate [1] 775/22
stipulated [1] 775/14
stipulation [7] 774/13775/3775/10
786/13805/51075/51075/9
stipulations [1] 1075/18
stolen [5] 864/9864/161045/231058/10
1059/2
stomach [1] 1018/11
stood [2] 789/18789/20
stop [5] 869/13869/13869/131038/24
1072/13
stoping [1] 1068/25
stopped [4] 851/14853/22880/8
1069/19
stopping [1] 910/7
storage [4] 811/2812/18814/16827/7
store [1] 1004/24
story [2] 964/61038/11
straightened [1] 993/2
straightforward [1] 1008/6
street [6] 940/21053/31053/71059/21
1059/241059/25
strictly [1] 823/8
strike [2] 839/4991/23
struck [4] 769/22769/23780/16780/21
stuck [5] 796/4808/18974/11991/8
991/10
student [1] 989/9
studied [1] 988/19
study [2] 972/2988/18
studying [1] 1022/4
stuff [23] 819/13853/7854/1880/7
910/13911/15942/23965/141002/23
1003/241012/91021/191022/51022/23
1032/21033/171036/31055/251058/4
1058/191058/191061/121065/1
stunk [1] 910/14
stunned [1] 1032/9
sub [1] 884/21
subdivision [1] 1023/9
subject [9] 774/13775/3786/13805/4
828/5830/1832/2860/21956/9
submachine [1] 850/12
submachine-gun [1] 850/12
submit [12] 779/19792/8792/11957/8
957/17958/3958/8960/1966/81011/16
1061/41061/22
submitted [22] 779/22780/5780/11
782/6800/13835/6890/21992/141008/13
1011/171035/61047/241048/21051/6
1052/21052/31052/41054/201056/18
1061/21061/71061/23
submitting [1] 956/21
subpoena [7] 773/9876/13939/23
940/241057/81057/101057/10
subpoenaed [6] 773/5800/16815/23
876/14940/20940/21
subpoenas [4] 773/3880/24881/2881/3
subscriber [3] 778/8778/9778/13
subsequent [2] 827/22829/16
subsidiary [2] 998/11998/21
substantial [8] 770/3780/4780/10
801/10817/9820/16840/10958/17
substantially [1] 771/23
such [3] 818/10846/16965/22
sudden [2] 769/211032/5
suddenly [1] 1044/6
sued [1] 1058/3
sufficient [3] 909/21957/1962/10
sufficiently [2] 956/22957/9
suggest [4] 793/10793/14838/13838/25
suggested [2] 941/81021/19
suggesting [1] 793/8
suit [1] 769/4
suite [1] 1052/17
summarize [7] 887/11896/2907/22
908/5923/7926/12928/14
summarized [6] 889/4890/14894/4
895/17918/22919/9
summarizes [1] 922/3
summarizing [2] 887/25928/5
summary [23] 766/24888/2890/12
892/12893/11895/18902/5903/2906/1
907/10916/2918/23923/8926/13926/23
946/22954/17956/101008/191073/20
1073/251074/61074/13
superseding [1] 775/17
supplement [1] 874/14
supplied [1] 936/3
supply [1] 1005/1
support [2] 780/6950/22
supposed [12] 772/13772/23789/21
819/10846/17961/14974/221024/14
1025/251042/191044/131058/18
supposedly [3] 777/31041/141067/20
sure [41] 766/12767/2791/23794/11
794/18814/6824/18833/17847/12847/21
857/15861/7867/16870/6891/17893/24
903/3913/7913/10915/9916/18922/4
938/17944/2945/16950/1959/8967/1
976/5980/8982/1982/2982/15995/10
999/151003/101012/41012/241015/8
1050/11053/14
surface [1] 974/3
surgery [9] 816/18817/11817/21820/18
826/19869/3869/6870/131018/5
surprise [1] 780/16
surrounding [1] 856/20
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 351 of 359
S
surveillance [1] 939/9
suspected [1] 776/15
suspicious [2] 792/25833/18
SUVs [1] 1032/5
SW [1] 763/22
Swarovski [1] 1004/23
Sweeten [16] 871/7871/20871/23
871/25872/18946/11946/18955/15
969/12969/15969/17969/19970/2970/9
970/171010/3
Sweetens [1] 969/22
swiped [1] 920/5
switch [2] 852/13856/3
sworn [5] 767/15882/10968/9971/2
983/23
synched [1] 831/23
Synchrony [1] 903/14
system [5] 859/22983/101035/1
1036/191045/13
Systems [1] 763/20
T
T-41 [2] 995/8995/11
T-H-U-R-M-O-N-D [1] 968/16
T-O-R-J-A-G-B-O-C [1] 779/11
table [1] 769/4
tactical [1] 859/4
take [34] 778/24785/18819/16821/4
821/7823/11852/23859/12860/9870/21
879/6910/9910/24912/9938/18956/12
956/15967/16977/11979/9979/19980/6
980/21989/61001/241019/181057/15
1058/21063/111068/201070/181070/23
1071/31074/8
takedown [7] 850/10851/6857/5858/10
858/16858/18875/10
taken [5] 790/15822/5912/6982/22
1067/18
takes [2] 1035/161044/20
taking [4] 785/61017/71038/21058/18
talk [34] 766/10767/5797/16818/25
843/22846/19855/2861/16872/21873/19
874/7888/14910/13910/13911/16961/19
967/9972/7987/14994/91017/11021/1
1027/101031/151045/171046/61054/14
1064/231069/21069/81069/141070/2
1073/11073/18
talked [18] 844/10844/15857/13868/16
869/2872/25898/24930/16932/9942/2
950/15953/21961/21980/191001/12
1039/201048/51075/5
talking [30] 789/15820/5820/19821/22
823/21851/19858/10862/16875/10
878/15881/21935/12945/10954/8961/9
962/12992/5996/221002/221004/25
1035/241041/121047/231048/61057/18
1059/31066/131073/221073/241076/3
tan [1] 769/4
tape [4] 851/13856/8857/17979/25
tape's [1] 853/22
taught [1] 933/17
tax [107] 768/22768/22776/6776/15
776/19776/22776/25777/12777/13
778/15778/16789/2799/4803/7806/21
809/21809/25810/1810/8811/15815/14
817/8820/15837/12840/1840/3840/11
840/15862/1863/20864/19875/17875/18
875/21875/22875/23890/21891/8891/9
891/11905/8906/7907/3907/7917/5
927/18930/22936/19938/4959/6959/7
1008/201021/11021/31021/51021/20
1021/211021/231021/231022/17
1023/141023/151024/171024/19
1025/171025/211025/221025/241027/4
1027/111028/31034/21034/91034/13
1034/151035/61035/81041/131041/25
1042/111042/121042/171042/211043/5
1043/151043/171043/201043/251044/7
1044/101044/131045/151046/61046/16
1046/211047/11047/81047/81047/24
1048/21048/181048/211048/241049/6
1049/171051/191060/16
taxes [32] 960/4960/8960/101021/19
1021/251022/171023/191026/81027/20
1034/81034/151034/181040/231041/1
1041/31041/41041/51041/61041/17
1060/61060/71060/71060/141060/14
1060/151061/21061/31061/221062/11
1062/121062/131064/4
teacher [3] 985/12985/15987/21
teachers [1] 985/11
teaching [6] 994/18994/20994/21995/1
995/11995/13
team [1] 832/24
technical [1] 868/3
technically [1] 992/5
technology [6] 1/13972/6972/8972/10
988/8988/18
Ted [1] 763/22
telephones [2] 1067/71067/11
tell [25] 789/5790/25820/4869/9875/16
879/4882/21885/11953/17957/15967/17
972/15984/14990/141002/141011/24
1012/11017/161022/221031/101032/22
1032/221048/31069/141072/4
telling [1] 1013/7
tells [1] 1044/20
temporary [3] 811/2812/18814/16
ten [16] 821/8849/17850/2879/6879/25
936/5936/7962/4973/13973/24979/20
1003/171005/221015/211032/16
1032/18
ten-acre [1] 1005/22
ten-minute [1] 979/20
term [3] 966/24997/191004/20
terminology [1] 966/25
terms [50] 793/23794/8851/16883/14
884/11884/14884/19887/7888/3888/7
889/3889/9889/17890/5890/24891/18
892/11892/19894/17894/25894/25
895/23896/6900/13901/16904/4907/10
907/18916/8916/22920/16927/14928/24
930/16934/4935/13937/9938/4949/20
950/3950/15950/25952/1952/15953/24
954/8962/12992/51019/51055/18
terrible [1] 1014/10
testified [24] 767/16795/8797/3826/15
827/9844/14846/15862/25866/9869/11
872/19879/12879/19880/24882/11947/7
968/10971/3983/241010/171040/14
1040/221064/251070/24
testifies [3] 822/15822/19963/12
testify [25] 791/6791/12792/18822/20
822/20867/25869/7869/18912/9962/23
963/10963/16963/20964/7966/6966/10
967/5967/18976/22979/17979/211010/3
1041/191070/171070/21
testifying [7] 791/11830/5884/15
965/10966/91051/251065/1
testimony [23] 793/16793/18794/20
795/14795/19795/23867/2887/10941/6
942/6955/17965/12966/21016/10
1041/161041/171046/91047/201048/18
1053/171053/181061/191061/20
Texas [11] 995/13996/8996/10996/13
996/201024/11024/41046/241047/1
1047/91047/11
text [1] 1024/17
than [26] 794/16795/18801/12818/12
821/3821/7824/11851/2855/18856/16
862/23863/5863/15910/9937/17964/6
973/13977/241016/191018/21025/24
1034/171036/41065/71067/121072/2
thank [72] 767/18767/23769/7778/23
784/14785/18786/19786/24798/2802/20
807/20811/9824/21826/17840/19840/22
847/25857/19857/20858/3859/25870/14
872/1874/1875/9878/7881/13881/23
882/2882/13882/18886/18888/18901/4
902/2909/23912/4912/5913/3913/23
914/13918/11919/6921/17929/8932/6
938/7938/9955/23956/3956/4967/12
968/12970/20970/22970/23971/5979/6
979/8979/13984/1987/11987/121020/23
1063/131069/161070/241073/11073/4
1073/171076/91076/10
thankfully [1] 860/11
Thanks [4] 819/15833/19833/20869/2
that [1627]
That' [1] 943/25
that's [212] 767/3782/23784/20786/15
788/16792/1792/19792/20794/9794/19
795/16796/25797/2800/2801/9802/15
803/4805/15808/1814/6817/18817/23
818/3818/19818/24819/7820/5822/23
823/5826/10830/9834/19834/19837/11
837/11841/24844/1844/3844/3844/7
844/9845/2845/4845/6845/6845/12
845/17845/20846/3846/8846/21847/8
847/13847/13847/14848/2848/16848/19
849/9849/24852/4852/8853/11855/14
856/5856/11858/13861/21862/11864/5
864/8864/17864/18864/21865/15867/1
867/1867/9867/21868/3868/13870/5
870/23872/19874/15877/13879/3879/9
879/12880/14880/18885/20886/10
887/20891/22892/17892/22897/18
900/16902/16907/15908/19916/16
917/13917/13919/18921/4922/9927/6
931/4931/5934/8935/17937/24938/7
938/23939/15939/25940/5940/5942/6
943/8943/14944/10944/13944/15944/18
945/11945/25946/2948/5948/17948/25
953/1953/16954/5954/16954/20954/22
957/4957/11958/19958/25962/15963/24
964/5964/10965/8965/17965/17965/25
966/23966/24966/25970/12975/6978/9
978/9980/16981/15981/18981/20981/25
982/7982/11984/23986/11987/4987/6
987/8992/6992/23992/24996/14996/14
1002/231007/211010/221014/20
1014/211015/171017/61018/191023/14
1030/51034/131034/251037/151037/16
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 352 of 359
T
that's... [23] 1044/221045/31047/12
1047/141051/201053/11056/21061/11
1062/91065/91065/121067/111067/14
1067/151071/121071/141072/61072/13
1074/201074/221075/101075/161076/1
their [24] 775/19790/6846/18846/18
848/14848/25849/2853/15877/25878/5
892/8920/5956/22966/6976/111005/2
1007/201009/51015/101037/11037/9
1064/131069/211072/5
them [121] 766/10766/10766/11766/13
766/19774/1774/3774/14775/4777/3
786/22787/2794/12795/1795/5797/16
818/12819/15820/6821/21824/4827/9
832/16852/12852/16858/3880/1881/8
881/9891/17891/22894/1907/16911/21
912/15912/18939/17939/18940/6940/18
944/14944/16948/20959/14962/10
962/25967/21970/3970/7973/7973/9
973/9976/11977/12977/25980/15980/24
983/14986/6986/8992/18993/25994/20
998/131005/11006/51006/61006/7
1006/171006/181011/121011/241012/1
1012/21012/101012/151012/161012/16
1015/101026/121028/131028/251029/3
1031/71031/101031/121031/131031/14
1031/141032/41032/161032/181033/23
1035/21035/231036/81037/21037/13
1037/141039/31039/81055/11055/2
1056/191058/31058/31058/71058/7
1059/221060/141060/161065/19
1065/211066/201067/101071/22
1071/231071/231072/31072/41075/18
then [241] 769/21771/10773/11773/12
773/15776/8776/21782/5784/12784/22
784/24785/3785/13785/14788/14788/20
790/10792/14793/15794/1795/5796/8
797/7797/12797/14798/15798/20801/7
802/9802/19808/10810/9814/15815/17
821/2822/14823/11823/13823/18823/24
824/1824/9825/13825/17826/5826/13
826/14826/18828/13828/15828/20
829/19830/14831/23835/1835/19837/7
837/15841/3842/15844/5845/9846/1
852/1853/5853/12854/10854/14854/17
858/24861/25863/25866/19877/3880/2
890/2891/24892/5892/6892/9897/2
897/11897/17899/14900/2900/2900/7
901/12901/13901/14902/9903/13903/18
905/17906/3908/14908/17908/21911/3
911/6911/12911/19911/22913/14913/18
915/14915/17917/16919/22919/24
921/13921/19922/8923/2924/18926/5
927/8927/12927/21929/24930/14931/4
933/24934/23935/9935/18935/20938/1
939/20944/23946/4946/13949/16952/2
954/11954/18955/11960/10961/8961/21
962/8962/23964/8965/3965/10965/11
965/19967/13967/13967/16967/17970/3
973/1974/10974/10974/13974/14974/16
978/5979/21981/1981/1981/16985/16
987/17989/10989/11989/17991/6991/14
992/9992/25994/6998/20999/3999/12
1002/31002/201003/181004/51004/8
1004/91006/131011/151012/121012/13
1014/41014/171015/41017/51017/22
1019/131019/201021/91022/21022/13
1024/71024/81026/141027/211028/6
1029/41032/51032/101032/121034/24
1035/11036/251037/141038/121038/18
1039/31041/71041/91042/11043/8
1044/161045/141045/171046/12
1047/231047/251048/201056/25
1059/251061/231064/61065/81065/24
1066/11066/21066/31067/111068/11
1068/251069/101069/141071/121074/7
1074/161075/1
theoretically [1] 789/23
theory [3] 864/8864/171066/4
there [327]
there's [59] 766/14774/2786/5791/1
791/2791/16791/16818/10825/12843/7
853/3856/14858/17858/21858/23861/25
862/20869/16885/18890/2893/14893/14
898/6899/14899/23900/8922/8927/10
927/10927/10935/20942/17946/22952/2
953/10954/17954/18957/18958/2958/3
958/8962/2962/18964/25965/22975/16
975/20981/22983/10987/11027/11034/9
1043/231059/181060/121068/13
1068/131068/141075/21
thereafter [1] 900/7
therefore [1] 1045/14
these [79] 773/23774/8774/10774/12
775/1775/2777/10778/1778/24786/2
786/13787/5787/7793/7801/20803/18
811/3813/2815/23815/23824/11825/14
827/21827/23855/8855/12857/21864/12
864/13865/6880/14890/18891/7891/16
892/11892/19892/24894/15894/18895/1
896/14901/16903/4903/21904/1907/22
910/19919/14922/25927/3927/9928/16
936/16938/20939/16947/19954/10
960/20961/9961/22962/6962/9964/7
964/9964/18966/21973/19973/20974/4
975/3975/3986/5986/61002/231009/19
1034/41055/191065/141067/10
they [205] 767/4767/4773/6774/17
775/9776/16777/3777/18777/19777/23
778/2778/3781/13782/9786/20792/5
793/3794/7794/9797/6801/23808/18
821/10822/12823/21825/16839/25
842/16849/1854/2854/5857/15857/21
860/9860/24861/1861/1861/20862/8
862/9865/23868/18872/24873/13873/13
873/14873/14873/16873/20876/5876/7
876/12878/3880/1884/13884/23886/14
886/25887/13889/12890/19891/24
891/25892/1894/20894/20918/1918/16
918/17920/5934/6938/6939/17939/21
939/22940/6940/18940/20941/14941/15
941/19945/18947/25957/9957/25958/1
958/10959/11959/11959/13959/13
959/16961/2964/16964/17965/7966/6
967/1967/2967/3970/10972/25973/1
974/4974/5974/8974/8974/9974/9
974/11974/12974/13974/14974/14
974/16974/17974/21974/25977/11
977/11977/23977/25978/5987/24992/23
992/24993/17995/8997/7997/9998/3
998/8999/121002/151003/11003/5
1003/91005/81006/41006/41011/15
1011/161012/51012/111012/171013/8
1013/101013/111013/241013/241020/8
1020/91020/91026/201027/31028/18
1028/211028/221028/231029/41029/5
1029/91029/171030/81030/151030/15
1031/101031/121031/131031/13
1031/141031/141031/231031/23
1031/231032/11032/21032/121034/20
1034/211037/81039/11039/41039/8
1044/61044/61044/61051/11051/16
1051/181051/181056/251058/21058/4
1058/181060/41064/91064/131064/14
1067/91071/201072/21075/11075/18
1076/12
they'll [2] 974/21053/12
they're [23] 766/14786/18793/2854/4
857/5868/20883/19899/23959/8959/10
964/14964/18977/14980/9986/9998/11
1015/31034/61044/101057/11068/23
1071/181072/4
they've [3] 939/12945/11057/25
thick [1] 886/10
thing [27] 766/23772/23790/12790/13
792/19796/4818/10853/23862/20871/2
894/2894/2894/6911/19938/24939/9
942/14946/20961/20963/20965/22
985/171009/201039/41048/231053/21
1075/4
things [31] 766/14792/5795/13803/18
821/23822/9822/23825/1842/7844/20
855/12857/22859/9860/11883/15895/9
959/12963/14967/6969/3990/71023/22
1033/181034/71035/71040/131054/14
1056/11057/151058/31059/23
think [146] 766/9778/17781/22781/25
791/5791/8791/11791/14791/14791/18
791/18792/18792/18793/6793/10793/12
793/17794/19794/23805/11805/15818/5
820/21820/24823/1823/2823/22823/23
841/16851/9851/16851/19851/21851/23
851/23852/21853/3853/5854/2854/3
854/20854/20855/15855/16855/17
855/18855/25856/1856/2856/9856/25
857/2857/6857/6857/20857/24859/16
862/25866/23866/25869/18871/23
874/22879/1885/21886/3896/13910/22
911/8911/23911/23912/3912/11913/6
927/2932/16933/4938/7941/3946/21
948/25949/10951/14955/18956/24
957/15958/22959/15961/1962/2962/6
962/9962/15962/15962/18963/4963/15
965/8966/4975/19977/23981/9981/22
981/25982/12983/12983/13998/10
1004/81009/241011/81011/151014/19
1019/31023/111023/251024/151024/16
1024/221026/101029/121029/15
1032/251032/251033/41038/251039/24
1040/11040/31042/41050/11053/15
1057/251058/31068/71068/221071/12
1072/11072/61074/81074/91074/12
1074/121075/51075/161075/20
thinking [10] 781/19781/221012/22
1024/51033/191033/201042/41047/14
1073/131076/11
third [3] 775/16832/22845/14
third-party [1] 845/14
this [430]
THOMAS [2] 968/8968/15
those [116] 773/9776/11776/20777/2
777/4780/21781/23785/6795/11808/15
808/16810/25811/1812/24813/1816/13
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 353 of 359
T
those... [100] 829/5829/6839/23839/23
841/17842/7842/16853/7859/2860/20
860/22861/15868/25873/12876/5876/13
881/2884/8884/11884/11884/19885/5
885/22886/8886/12886/23888/8889/14
889/14889/16889/20889/21889/24890/6
891/5895/9901/6905/12906/10927/14
930/25935/21941/12944/9947/19947/22
947/23947/24949/12949/17949/23
950/14950/20950/23957/10957/18
957/19958/11959/7961/14962/1967/8
967/10972/24973/1973/5973/5973/11
977/10978/5978/12978/25980/3980/6
981/2984/17984/251000/171000/18
1003/61006/81006/121016/11019/12
1020/61033/171034/191041/111048/24
1054/251058/61059/111061/181062/11
1062/121064/41064/161066/91066/10
1074/15
though [8] 869/1904/24930/13958/7
960/91010/71038/251065/1
thought [19] 792/22792/24818/18
851/12873/14912/16947/1963/24963/25
964/1968/2980/121017/141017/15
1023/121023/131046/231046/241058/4
thoughts [1] 911/18
thousand [2] 978/1978/2
thousands [1] 840/11
threatened [1] 855/12
three [29] 800/7821/22825/14849/19
849/23871/3889/9890/13892/19893/12
894/11894/23901/14927/14944/9956/23
957/6957/7957/18959/6959/16962/7
978/1982/12995/12999/161028/13
1029/101029/12
through [57] 766/13768/7769/18774/3
774/6774/6774/7774/23774/24775/5
782/9784/1784/21786/4786/8786/10
786/12808/14821/23822/7822/8833/3
844/21883/16884/21887/12889/5893/2
901/6902/6906/20915/8926/25931/16
939/23940/20944/11947/3947/21954/2
957/20960/12961/11961/22979/11989/6
990/101000/181001/191001/201001/21
1035/111039/31042/201048/191056/19
1074/1
throughout [4] 787/6815/22843/18
996/20
Thurman [2] 967/14968/1
THURMOND [4] 968/8968/15968/19
970/17
tie [1] 794/5
tied [1] 957/24
TIGTA [4] 776/5776/16782/8865/16
tilted [1] 974/8
time [81] 769/13771/25772/1772/13
772/15772/24774/14775/11776/2777/5
777/25783/23784/1790/5806/17806/20
820/21820/24827/2830/16830/19836/2
838/24841/20844/13852/23853/1859/17
859/19872/18879/2879/8879/11879/12
882/3891/20907/10910/6910/10916/4
929/12929/22941/9942/12945/20946/4
949/16955/19959/5985/18989/10989/18
989/20990/19990/20991/2993/19995/14
995/24998/41000/211004/171005/10
1012/141012/251013/11019/101029/8
1029/91030/71033/141035/181035/20
1051/141055/41060/191062/41062/8
1076/11076/21076/8
timeframe [13] 890/14893/12902/10
903/4905/19917/9929/5929/71012/6
1013/91013/111041/221048/5
times [8] 775/16790/9970/5973/11
973/131005/171005/181005/20
timing [3] 1012/241069/111072/17
TIN [4] 826/21024/221050/81051/15
tips [2] 835/15836/23
title [5] 768/9775/19799/25825/22
955/21
titled [1] 831/3
titling [1] 961/12
today [15] 766/9769/3821/10831/14
831/20853/15910/21910/22911/12
911/20925/21926/18950/161071/14
1074/2
today's [3] 792/1792/2831/10
together [8] 781/24894/5894/22931/3
931/61010/101010/121058/10
told [26] 841/24849/12855/8870/17
870/21872/13921/4943/12976/20993/25
1003/61011/161012/151013/71017/17
1023/121023/151023/181025/19
1026/251031/121032/241043/14
1050/231051/11061/18
Tom [2] 967/14968/1
tomorrow [6] 911/211071/161072/5
1072/201073/41076/12
tone [1] 875/10
tonight [1] 1073/19
too [17] 786/6817/22818/18821/12
851/23853/14854/16865/14867/2867/4
880/2966/17995/241015/141035/12
1063/51069/1
took [19] 856/9894/12912/21913/11
913/20999/11008/71011/121028/22
1028/231030/81031/131031/141032/10
1035/101035/101035/121035/16
1036/18
tools [2] 974/6974/22
tooth [1] 1009/20
top [23] 782/19783/3784/13784/18
785/4788/14803/13806/9806/10816/22
829/18846/24853/4853/13854/22899/17
909/8914/16918/13921/19922/22924/22
930/4
topic [3] 825/2910/141056/16
tore [2] 997/7997/9
Torjabgo [1] 812/1
torjagbo [80] 763/5769/1779/10779/10
782/24785/1797/12798/5798/18799/14
799/20803/3807/23809/20810/8813/24
815/25816/18825/8825/10826/7827/3
828/21835/5835/22836/14837/5838/2
843/2843/3843/23847/9849/12860/12
861/9883/22899/10904/19914/6920/13
921/3921/6927/1943/4943/16943/18
943/20943/23943/24944/14944/19
944/24945/25950/13957/24961/11
965/20976/16976/19984/161031/5
1039/121039/131039/131039/19
1040/111047/201050/71050/161051/11
1052/101054/61054/201057/171058/20
1062/221063/161064/231067/161077/9
Torjagbo's [2] 797/24830/20
tornado [3] 1014/101068/91068/13
total [24] 808/12809/6809/7812/9
812/12814/2814/4814/8837/17892/20
892/21895/23906/25907/5919/4926/16
929/14929/14929/15929/15936/23
937/14938/5979/2
totaling [1] 928/21
totality [1] 893/13
totally [2] 851/21854/3
touch [9] 932/17932/18932/23933/6
933/151001/91027/31034/101046/4
touchable [1] 985/16
touche [1] 985/17
town [1] 1016/24
trace [2] 954/10954/21
traced [1] 815/13
tracing [2] 790/8954/23
track [4] 945/9945/91006/81072/23
tracked [2] 935/16947/19
tracking [1] 823/3
Tract [4] 802/17919/2936/1936/5
tractor [2] 808/11841/15
tractor-trailers [1] 841/15
tractors [5] 827/8832/25936/7950/17
1015/21
traded [1] 1027/19
trail [20] 779/8782/22783/15783/17
785/1798/13798/19799/14825/23828/21
843/5845/17999/101045/241052/16
1052/221052/241053/61053/61058/14
trailer [2] 808/11887/8
trailers [15] 808/10808/15827/8832/25
841/15861/4861/11863/1887/9928/6
936/5949/241015/211016/21030/2
train [1] 1022/8
training [10] 770/2789/20791/19800/25
883/5989/20995/51010/121016/41022/5
transaction [28] 783/19787/18788/21
788/24788/25799/11801/8804/12909/18
913/20918/13922/15924/15924/22
924/25925/18927/9930/4934/8946/19
949/21950/11954/24955/20955/21
955/22961/201032/1
transactional [1] 958/6
transactions [25] 783/25784/2784/8
785/4791/16892/12894/5894/12902/7
906/19908/9910/4913/10915/6919/14
923/8927/15930/10945/18949/12951/7
954/10958/7961/10962/13
transcript [25] 1/11/51/81/91/14763/12
763/18822/22823/2831/19831/23832/3
854/12854/12867/3867/13875/3980/2
980/9980/10981/4981/5981/221070/19
1077/12
transcripts [1] 1/2
transfer [43] 789/22796/18798/8798/22
892/15897/17899/7899/18899/20901/23
905/17908/21909/3909/19909/20913/12
913/21914/1914/8914/10915/9916/8
919/15920/10920/10922/5922/14923/1
923/22924/23930/17931/4935/10935/13
935/16935/18941/19952/25955/14
1006/131006/141034/231050/13
transferred [22] 773/12773/14773/14
773/15790/9796/7796/8796/15796/16
871/9900/2900/16904/2906/18908/14
923/10924/7934/16937/14954/18
1006/161013/1
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 354 of 359
T
transferring [1] 945/11
transfers [20] 790/7892/14892/17
893/19893/20900/1900/22901/7901/16
902/8902/11906/1906/21907/20931/16
932/10936/12941/16949/7954/19
transitioned [1] 880/2
transport [1] 1037/14
transportation [1] 1036/24
transported [3] 812/17814/151037/9
transporting [1] 1037/1
traumatic [1] 857/5
traumatized [1] 874/10
travel [2] 1000/11001/24
tread [1] 796/12
Treasury [2] 776/6892/9
trial [7] 792/12792/17792/20831/13
1010/31076/41076/5
trickled [1] 992/7
tricky [1] 991/13
tried [9] 858/20865/11901/8993/25
1017/11026/191059/181059/181076/1
trilogy [1] 780/20
trouble [1] 866/12
truck [9] 841/13860/22861/2887/8
926/24927/121015/241032/31038/12
trucking [6] 827/7841/9862/211012/21
1015/21036/21
trucks [24] 808/15861/10862/12863/1
887/9927/3927/9927/22947/19947/20
947/24949/23950/171015/141015/16
1015/201015/251015/251016/11016/2
1030/21032/21032/41037/12
true [6] 778/131018/191063/21063/21
1063/231077/13
Trust [1] 909/10
trusted [1] 1010/22
try [26] 794/14796/12803/19818/23
818/23819/1855/21857/21859/25880/7
883/18939/20991/18991/22992/9
1013/141025/81030/211030/251033/21
1033/211033/221033/251037/12
1039/221040/13
trying [37] 781/25791/7793/10793/13
794/15843/9851/3851/3851/19852/12
852/12856/2856/5856/10857/12857/24
947/7954/14983/5991/12994/31014/18
1017/111017/211022/171027/161035/3
1039/141042/131043/61053/91057/15
1058/21061/81061/241063/81074/4
Tuesday [1] 980/20
tunnels [1] 1035/17
TurboTax [6] 1023/51023/51024/18
1025/61026/191026/25
turn [19] 785/3788/11797/18798/10
802/12807/17809/1809/4814/21815/17
816/14825/17827/17829/11835/9836/10
837/7897/17987/12
turned [7] 831/2841/16860/11861/1
970/21057/81058/7
Turner [1] 763/22
turning [7] 779/18783/1799/25800/10
811/16813/14834/17
Twist [7] 781/2781/3781/4781/5872/25
1009/171009/18
two [60] 766/24781/23820/6825/12
827/21835/19837/2838/1863/8867/9
868/13868/14876/5885/20889/17901/13
911/5927/10927/10928/20931/6950/16
956/23957/6957/7957/18959/6959/6
959/12961/14962/7962/22963/14982/12
993/11993/18993/19995/12995/12
998/201000/91006/21011/121014/3
1014/131015/121015/231018/14
1024/221030/31034/221056/161065/10
1065/151066/131066/181067/201068/3
1074/11074/2
type [8] 770/24850/12880/16883/18
883/18926/5989/6995/5
typed [1] 969/25
types [5] 792/5803/18857/22886/23
907/19
typewritten [1] 1077/12
typically [5] 792/16859/10964/9966/3
1042/20
U
U.S [21] 1/14763/21764/2846/18883/4
938/21940/4977/16978/24987/171001/9
1004/111005/11009/51013/91034/11
1034/121034/211060/71060/91074/20
U.S. [12] 892/9978/11978/13994/19
997/15997/17997/251006/41007/8
1034/111036/61060/14
U.S. Army [3] 997/15997/17997/25
U.S. citizen [1] 1034/11
U.S. citizens [2] 1006/41036/6
U.S. dollars [2] 978/11978/13
U.S. federal [1] 1060/14
U.S. Navy [1] 994/19
U.S. Treasury [1] 892/9
U.S.-based [1] 1007/8
UAE [3] 1007/151024/31028/10
uh [13] 903/25907/9916/7924/17931/10
931/12934/20936/18936/22951/6953/5
984/191040/18
uh-huh [3] 924/17953/51040/18
Uh-oh [1] 984/19
ultimately [4] 797/3879/15925/24955/5
um [107] 833/13833/16886/22887/6
887/9888/22889/19892/23893/1894/16
895/2895/25897/25899/2900/14900/20
901/17901/20901/22903/22909/5916/12
916/14918/8921/21923/24925/7925/11
926/6926/20926/20930/5934/10934/12
934/22937/5937/11941/7946/5946/12
947/16948/3949/9950/4950/6950/21
950/24952/4952/17953/23954/13955/16
955/24989/25990/2991/241009/23
1011/31013/41013/201014/231018/23
1020/31025/71027/241029/191030/24
1031/161033/31033/81034/31036/11
1037/251039/181042/161043/21043/16
1045/191046/81050/31050/171050/19
1051/51052/111053/221053/241054/16
1057/191057/211058/211059/51059/7
1059/101060/51062/251063/191065/11
1065/161065/181065/201065/23
1066/151066/171066/191066/21
1066/231067/17
um-hmm [107] 833/13833/16886/22
887/6887/9888/22889/19892/23893/1
894/16895/2895/25897/25899/2900/14
900/20901/17901/20901/22903/22909/5
916/12916/14918/8921/21923/24925/7
925/11926/6926/20926/20930/5934/10
934/12934/22937/5937/11941/7946/5
946/12947/16948/3949/9950/4950/6
950/21950/24952/4952/17953/23954/13
955/16955/24989/25990/2991/24
1009/231011/31013/41013/201014/23
1018/231020/31025/71027/241029/19
1030/241031/161033/31033/81034/3
1036/111037/251039/181042/161043/2
1043/161045/191046/81050/31050/17
1050/191051/51052/111053/221053/24
1054/161057/191057/211058/211059/5
1059/71059/101060/51062/251063/19
1065/111065/161065/181065/20
1065/231066/151066/171066/19
1066/211066/231067/17
umm [30] 883/23889/11890/25902/15
917/11918/5920/12930/18933/23937/13
939/13950/19994/101010/21011/21
1019/231020/51040/121042/181042/24
1043/111044/51045/61046/101050/22
1052/151060/31062/161067/191067/21
umm-hmm [30] 883/23889/11890/25
902/15917/11918/5920/12930/18933/23
937/13939/13950/19994/101010/2
1011/211019/231020/51040/121042/18
1042/241043/111044/51045/61046/10
1050/221052/151060/31062/161067/19
1067/21
unable [1] 789/25
uncover [1] 776/24
under [13] 772/12829/21838/5879/9
888/21891/1956/20959/181031/2
1048/221051/41066/31066/20
underground [1] 974/3
underlying [1] 778/8
understand [23] 795/15795/20795/23
804/5830/15832/8852/14856/22857/8
938/20945/3959/81011/111041/24
1044/31053/31053/141062/201062/21
1062/241068/231072/141074/24
understanding [7] 794/9795/19861/21
916/191007/71013/191066/16
understood [4] 787/9798/2957/14
1008/7
unemployment [2] 837/121060/16
unfair [1] 851/25
unfortunately [1] 852/23
unfreeze [1] 1011/16
uniform [2] 998/15998/17
UNITED [43] 763/1763/3775/19839/12
846/20847/4847/15847/22848/11848/15
849/5882/5882/23882/24883/17941/22
941/24941/25959/4968/24988/5988/10
990/15993/14994/15998/22999/5999/9
999/121002/51007/141007/161007/19
1007/211055/41055/131055/171059/23
1061/161064/21064/201077/51077/9
United States [27] 775/19839/12847/4
847/15847/22848/11848/15849/5882/5
882/23882/24883/17968/24988/10
993/14994/15999/91002/51007/14
1007/161007/191007/211055/41055/13
1061/161064/21064/20
university [1] 991/7
unknowns [1] 858/21
unlawful [3] 958/9958/101034/4
unless [4] 797/25863/12945/18945/19
unquote [1] 960/17
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 355 of 359
U
until [10] 824/3891/5891/7928/20977/1
977/2987/161052/171054/241054/24
up [135] 766/23766/25769/22770/11
770/14770/22770/22771/1771/7772/1
777/6778/25781/15782/17783/3784/9
784/13784/15785/4786/5787/10787/15
789/11789/12799/6800/12802/3802/20
803/10803/11805/7806/10806/25807/8
810/3811/22813/19816/10818/1818/4
818/8824/3825/2825/2828/18834/11
835/24841/15847/20849/15852/20
852/25876/17880/9882/7888/19897/20
898/24899/13901/14902/9902/12904/10
905/13908/25909/23910/14912/11
913/22917/14918/10919/19920/7922/12
924/4924/18932/6933/9935/13947/22
947/23951/11951/14952/24955/12
962/17963/11965/14966/1967/18968/5
969/22969/23972/11978/7979/21979/21
980/1981/16985/13987/15990/11
1010/231012/191015/31019/171019/22
1021/171022/121032/11032/191032/20
1033/181036/171038/41038/41038/11
1039/51039/81039/251042/231043/8
1045/241048/41048/111050/111052/7
1052/171057/71057/151058/131059/24
1061/241067/131068/25
upon [14] 770/1770/5770/9775/12
775/14777/22780/7783/14783/24789/2
838/19840/7865/11873/15
upset [2] 855/4857/9
upwards [1] 996/24
us [20] 824/19859/6859/11863/8869/9
885/11932/12941/19941/20972/15981/1
984/14989/6999/131002/141002/16
1056/251064/11064/101075/9
use [35] 767/5794/10795/21861/15
861/16875/19888/2974/5974/6974/14
974/21980/2980/241012/61015/17
1017/251019/191023/91033/11035/1
1036/31038/41039/11039/91039/11
1049/81050/101065/241065/251066/5
1066/81066/221067/21067/31067/22
used [46] 1/13772/10772/13772/18
772/20772/22772/24774/8778/2778/20
782/12787/7789/21810/4834/19844/3
846/15861/9863/1864/6875/16875/17
875/20923/14923/17923/20925/1925/12
950/23985/15986/1994/51014/41024/19
1025/251026/161026/211026/22
1026/231029/181047/131049/171065/5
1066/111068/111073/23
user [2] 1022/241023/1
using [3] 974/221024/41068/4
usual [1] 1023/7
usually [2] 952/21006/13
Utah [1] 998/10
utilities [3] 772/22846/16895/13
V
V-O-L-T-A [1] 1000/6
vaccinating [1] 1013/10
vaccination [2] 1068/161068/17
vaccine [3] 1013/81013/121013/12
vaccines [1] 1068/16
vague [1] 957/12
value [1] 1008/8
variety [2] 773/13780/14
various [3] 773/15822/24961/22
vehicle [25] 809/7809/8809/11810/13
811/4812/1812/2812/5812/9812/9
812/13812/14812/17812/25814/11815/1
815/12815/15815/15830/22830/24
830/25833/2927/7942/9
vehicles [14] 813/2820/18833/4840/12
887/2887/7919/10926/13926/19942/3
948/14949/231029/221031/3
Velar [1] 814/1
vendor [1] 922/11
venture [2] 1002/211067/23
verdict [1] 1076/12
version [5] 821/20851/4887/25995/7
1071/14
versus [1] 953/19
very [40] 770/15770/19770/19770/21
777/4777/25803/25817/4817/19822/7
840/8849/14859/10869/5875/11878/8
887/15898/6899/17901/12918/13935/15
945/12946/4956/3956/16957/23957/23
958/1967/5967/20969/1979/23990/1
993/201011/71011/251040/81067/6
1073/4
vests [1] 859/4
via [5] 939/23940/24945/91000/17
1053/18
victim [1] 872/7
video [4] 942/18945/19945/20946/16
Vietnam [2] 1022/131022/16
VINs [1] 813/1
violations [1] 768/14
visa [6] 987/17990/16991/1991/4991/5
991/6
visited [4] 976/101005/101005/18
1005/20
voice [1] 832/22
Voices [1] 1044/9
Volta [3] 1000/21000/61000/8
VOLUME [1] 763/5
voluminous [5] 886/11886/11887/13
887/151074/15
voluntarily [4] 829/6829/7875/14
879/15
W
W-2 [4] 1042/201048/241049/31064/3
wages [4] 835/14836/7836/23846/18
wait [3] 983/11027/21053/14
waiting [2] 824/191032/4
waive [2] 829/5829/6
Walmart [5] 785/10785/111037/5
1037/71037/9
want [67] 766/15786/20794/7796/13
814/4814/6817/17817/25818/2818/11
819/5819/9819/18819/23820/4820/7
822/8822/23824/10851/15852/10852/17
854/2857/16857/21863/5865/20866/20
867/14891/17891/21891/22911/18912/2
944/2957/12957/13967/2967/6980/8
980/13982/15982/16982/24989/11
1017/91037/51037/91053/141063/8
1063/121068/191068/201068/211069/9
1070/21071/151071/161071/161071/20
1072/161074/31074/51075/81075/8
1075/101075/24
wanted [12] 766/23767/2825/1870/6
875/13902/8975/19982/1982/17998/25
1037/51075/4
wanting [2] 856/15960/10
wants [4] 819/6851/5851/51071/9
warrant [2] 816/13998/1
warrants [4] 832/25841/19841/20850/2
was [972]
was -- it [2] 871/191017/3
wash [6] 974/9974/10974/11974/13
977/22978/5
wasn't [35] 778/12782/15815/16818/19
843/4843/4844/2851/17852/10852/12
857/6872/8875/11879/8879/8946/23
947/8947/17953/18966/9970/4993/3
1003/251010/231012/41013/151015/8
1017/41019/171023/61026/61042/7
1044/121053/131063/23
watched [1] 1062/2
watching [1] 1076/8
water [2] 821/12975/1
way [39] 782/8793/8793/8818/15819/6
819/10824/6840/6842/7858/15859/14
868/4870/24871/19932/16955/8978/16
1000/31012/181014/111017/191028/17
1030/211030/251032/241033/231035/7
1041/131042/51042/71042/81046/4
1051/131054/21059/211062/71063/5
1067/41068/2
ways [1] 823/17
we [385]
we'd [3] 849/18874/14911/14
we'll [32] 767/5774/1787/3797/16
815/21819/10821/8822/1823/11841/3
849/15855/21888/14911/16911/19
917/15924/9956/14967/18979/20982/19
983/11989/241008/221013/141069/14
1070/181070/231073/41075/111075/17
1075/19
we're [50] 766/10792/12807/5807/5
819/16819/17819/24821/7824/18851/7
851/19852/21888/23896/6910/12910/18
910/21910/22911/11911/23912/8912/13
912/18918/13919/15945/10956/16
979/10979/11979/12979/19981/4983/4
983/14990/101016/171017/61018/18
1018/201036/31061/241069/51069/11
1069/251070/251071/131072/131073/9
1073/221073/24
we've [21] 791/3792/14820/19825/13
852/20856/18861/1931/16935/12944/2
944/2944/11959/7959/14963/51006/23
1039/201069/21070/11071/41073/23
weapons [1] 850/13
wearing [1] 859/2
web [1] 1017/20
website [15] 1013/241014/81016/5
1016/61016/71017/11017/131017/14
1017/151017/171017/221017/24
1019/151061/111066/9
week [7] 817/1817/2977/16977/22978/7
1058/11073/10
weekly [1] 784/1
weeks [4] 800/71011/121029/10
1029/12
weird [1] 1018/4
well [105] 774/25775/4776/16776/17
779/6779/24780/15782/15782/24783/14
783/16783/24785/21791/25792/9793/6
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 356 of 359
W
well... [89] 793/10797/9799/4801/3
804/17806/2809/2812/17813/3814/16
815/23820/23823/16825/12826/12
829/20830/22833/1833/5839/4840/7
843/1843/4844/24846/7846/19849/14
856/18858/23858/24860/8861/16866/9
868/9869/11869/15871/17871/18873/17
876/15887/2887/8890/22904/4907/11
907/20930/22931/8945/13948/2956/16
957/11957/17957/21958/4959/11959/12
960/1963/23965/8967/15975/16975/20
976/20978/16981/3981/22985/91008/19
1009/121010/11023/231023/241042/15
1043/81043/141051/241053/251054/11
1054/141058/201060/111061/51062/14
1065/91066/31069/251073/141074/1
Wells [3] 886/2894/3903/17
Wells Fargo [3] 886/2894/3903/17
went [54] 772/18773/12787/8792/14
797/3797/4797/6798/17842/21843/14
843/20845/16846/1854/15861/22862/23
863/23864/25871/10871/11889/5897/5
897/9902/6903/8904/15906/7917/6
919/16930/11935/10935/16946/14
947/21947/22954/12991/5998/211003/3
1005/141007/251013/121013/23
1016/151016/201016/221024/31029/25
1037/161047/251051/201063/24
1063/241063/25
were [282] 766/25767/4768/8769/9
769/15769/15769/19769/19771/19
771/19771/19772/25773/7775/18775/20
776/19776/23777/1778/2778/15780/1
780/5780/15781/12781/13781/19781/25
783/9783/13784/2784/2784/7784/11
787/7789/5789/15795/8795/10795/10
795/11796/5797/9797/13797/23801/14
808/4808/9816/25817/4823/20824/12
825/15826/20827/9827/22829/2830/5
832/24833/4838/5838/8839/4839/6
839/23839/25840/16841/15842/2842/4
842/15842/16842/16847/10849/20850/6
850/8850/12858/10858/24858/25859/2
859/4859/6859/12860/8860/9860/9
860/20860/22860/24861/1861/3862/9
862/16862/19862/19864/13866/9868/14
868/18868/22868/25873/13873/16874/4
874/19875/22876/5876/5876/7878/21
881/19884/5884/6884/8884/11884/13
884/23885/23885/25886/23886/25
889/12889/24889/24890/6890/13890/19
890/20891/2891/3891/7891/8891/9
892/14893/1893/2893/18894/19894/20
895/3895/19895/24897/24902/16902/21
903/6906/21906/21913/5916/23926/19
926/19926/25927/9927/22928/6928/19
928/20929/2930/6930/25937/1940/18
940/20940/23941/12942/2944/14944/16
949/6954/8954/14955/14955/18958/8
958/24959/4966/18968/2970/3975/13
975/15980/21982/12983/4983/10985/11
989/19991/10991/12991/12992/25994/3
994/18994/21994/25994/25995/5995/22
996/8998/3998/19999/6999/151000/18
1002/41002/41002/61003/61003/7
1003/81003/101003/131005/111005/21
1006/41006/41006/61006/121006/20
1006/201010/121011/241012/51012/11
1012/171012/201012/211013/15
1013/241013/241015/91016/161016/24
1018/131018/141019/211021/171022/8
1023/191029/171030/71030/71031/11
1031/121031/151032/21033/41033/13
1034/41034/101035/221037/161039/14
1041/51041/121042/61046/111047/9
1048/61049/51050/231054/11054/24
1057/251058/11058/21058/41060/15
1060/221061/31061/71061/111062/6
1063/21063/31063/81063/201068/5
1076/151077/11
were -- it [1] 769/15
weren't [8] 777/20862/8868/18873/14
891/5959/111015/81042/6
Westcreek [1] 996/11
Western [3] 1000/131003/191005/23
what [504]
what's [41] 786/3795/22796/13796/21
801/17805/2809/8810/18814/2826/8
828/11835/14836/4836/7836/23837/17
850/23852/22882/24889/22907/14913/8
914/3915/5926/23927/23952/1952/2
959/10972/3979/16987/3989/19990/5
1004/231016/181019/221064/171073/8
1076/111076/12
whatever [21] 773/6773/8818/13819/5
820/7857/17861/24861/24862/4865/11
875/13893/21912/2918/1945/18945/20
949/221006/141045/21053/181075/21
when [190] 768/8771/19771/19771/20
771/25772/1776/2776/20778/2778/6
779/18779/18779/25793/2793/3793/6
795/10795/10803/6803/6806/14809/25
810/15810/17811/4812/16812/25814/13
814/17815/2816/24817/25819/19820/4
824/9826/10827/2827/11827/14827/23
829/2834/4837/22837/22842/21843/14
843/22844/5849/17851/19854/23857/21
858/21859/8859/8859/20859/20863/22
863/25865/4865/14870/17874/12875/3
875/10875/15875/24876/3878/14881/19
889/24889/24890/2894/21900/5903/3
915/25919/18927/14930/6930/9935/5
936/10941/12941/19943/8943/11945/10
952/5954/8965/20971/24974/5979/20
980/20985/9988/10988/12990/15990/17
990/22991/12992/12992/23992/24993/1
993/2993/2993/2993/21994/14996/19
996/20996/22996/22997/25998/3999/24
1000/11000/161000/181001/21001/2
1001/21001/91002/21002/21002/13
1002/151002/231003/211007/111008/2
1009/221013/51013/81013/121013/22
1014/221015/171016/251017/61019/20
1020/141023/111023/141023/251025/6
1025/61025/101025/121025/131030/7
1030/231031/101031/231031/231033/7
1033/101034/71035/21035/141035/15
1036/171038/21039/151044/171045/23
1046/111049/121051/161051/18
1051/181051/241054/211056/15
1057/161057/181057/201060/211061/8
1061/231062/51063/181063/241063/24
1063/251066/131066/241073/9
whenever [2] 892/14895/10
where [94] 766/9768/2768/21772/8
772/8772/17773/9773/11778/5780/8
783/9785/6787/8789/5790/9792/10
792/13793/4798/13804/1814/17814/17
821/21827/5839/5839/6841/23841/23
841/24842/5845/6848/25849/1849/2
853/5853/18855/7871/13874/21877/3
882/21894/11898/9902/16903/4906/6
918/16920/5933/24935/9941/15954/12
954/17962/13964/22966/15970/7971/14
971/22972/18980/2980/6980/21982/12
982/16987/14988/7995/10995/13997/24
998/8999/4999/6999/61002/121013/11
1015/241015/241017/31019/11029/20
1031/101031/121036/231036/251038/7
1046/21047/21049/221049/221055/8
1059/241061/111063/11
Whereupon [25] 767/8790/22795/3
817/15820/10821/16822/5824/23833/10
833/21850/22858/6875/7910/16912/6
912/25956/17967/24979/15982/22
983/161069/171072/111073/61076/15
whether [17] 767/3767/4772/19778/10
783/22822/15822/18861/13879/18
920/21936/2965/19965/20967/18
1044/211044/211074/15
which [93] 768/14769/22770/16770/17
771/8772/12772/17773/3773/4776/5
776/14777/7777/9778/21778/25779/24
782/18783/18785/16786/20789/12
790/11792/7796/6797/14797/18798/23
799/3799/19800/10800/10801/9802/13
803/15804/9807/22808/4808/19808/24
810/11811/21812/6813/20814/19815/18
816/20816/24823/17827/7831/8834/12
838/20846/11856/9864/15887/16898/1
903/19904/14914/16916/11919/2929/11
929/19933/5941/8941/14943/21945/18
946/25957/25958/23967/3967/6967/7
970/2985/6993/13993/16994/15998/21
1020/41021/81024/21030/51035/9
1042/201048/101049/81049/231054/5
1055/151058/8
whichever [1] 917/25
while [4] 787/4901/21967/191021/17
who [75] 773/7778/9778/9780/16
780/18780/24781/4788/14794/16809/18
809/18814/9829/20830/19835/4835/14
835/21836/7836/13836/23837/4838/1
842/24848/24848/24860/9860/24861/1
866/4904/18911/24926/2942/13942/15
945/17946/15960/16960/17962/8967/8
967/13970/17972/24973/1973/25977/9
977/10977/15977/22978/5978/25994/18
996/4999/13999/131003/231003/23
1004/21006/81006/171006/171006/17
1009/111009/131009/141021/12
1021/141024/141037/131057/13
1057/141058/11064/81064/121064/15
who's [5] 809/10844/22851/20920/13
1037/11
Whoa [1] 818/23
whole [12] 851/13852/25894/4917/9
945/1966/1974/201004/181030/18
1045/221076/21076/8
whomever [1] 918/2
whose [12] 784/24797/20798/3798/10
798/15809/15826/5830/8830/8830/14
877/1914/5
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 357 of 359
W
why [49] 776/11782/14782/14791/20
792/14792/19793/17794/1794/15794/20
794/21795/13795/15796/11796/21
796/22800/21800/21803/17818/19
852/10853/25855/6865/15879/12890/20
891/13896/1900/24928/24985/8993/10
1010/211011/111012/171027/151031/6
1036/151038/11038/251043/191046/21
1049/161055/181056/21068/241069/8
1069/251071/22
wife [1] 993/19
wild [1] 1059/19
will [57] 1/3767/4767/19769/7791/12
823/9832/5832/6832/11832/22833/4
833/7833/9854/17857/8866/23866/25
867/2867/3882/14885/19889/1899/14
910/9910/17911/8911/20911/21911/22
911/25912/2931/19932/17945/19963/4
963/20964/19966/1967/2967/12968/13
971/6973/19973/20974/13978/7978/19
984/2989/201000/171000/181035/6
1068/251070/151071/231072/19
1072/19
willed [1] 1001/12
willing [1] 830/16
Willis [2] 780/17873/6
window [1] 833/3
wire [32] 768/14846/10877/4877/6
899/20903/7905/17906/3908/23909/3
909/21913/14913/21914/1914/4915/18
920/10921/20922/14923/22924/25926/2
930/14941/16941/19946/14955/18
956/23957/8959/61006/161034/23
wired [9] 908/18913/18915/15915/18
918/16919/23922/7923/13923/16
wires [5] 894/19903/4941/5941/9
949/22
wisely [1] 912/8
wishes [2] 962/23979/17
withdrawal [4] 917/25918/6946/4
954/11
withdrawn [1] 924/13
withdrew [1] 919/25
withheld [1] 837/13
withhold [1] 1064/3
withholding [2] 1012/181060/13
withholdings [22] 1027/111028/3
1035/71041/61041/91041/141041/17
1041/201041/211042/11042/21042/11
1042/121042/171043/11043/41043/5
1043/201043/241044/101060/211064/4
withholds [1] 1042/21
within [1] 926/14
without [6] 830/17859/10869/19909/20
993/201059/20
witness [28] 765/2767/5767/11767/15
769/6803/22803/23819/4830/9830/10
840/21866/24869/17872/10881/24
882/10911/1956/5960/23963/8963/16
963/17965/11965/12967/22968/9971/2
983/18
witness's [1] 795/23
witnessed [2] 829/18829/20
witnesses [2] 911/5962/22
woman [2] 969/111010/5
won't [1] 875/3
wondering [1] 817/22
wood [1] 1000/14
word [6] 791/23940/8965/25981/14
981/171000/3
words [9] 832/4832/5832/6832/9832/10
832/11832/11854/22875/2
work [28] 768/18768/18910/20938/20
938/22939/22957/13967/8969/7969/9
973/19973/20974/4977/9979/11993/13
998/131004/151007/151007/201010/5
1010/141034/161059/231060/11060/4
1068/21076/2
worked [8] 768/11768/14768/20768/22
966/20983/111009/101010/10
workers [15] 848/13848/13860/20
860/22861/2964/8965/161005/61005/7
1005/211006/81006/151006/211012/10
1035/22
working [25] 768/6768/8849/5860/22
883/4883/14883/20964/22967/10975/3
977/13978/12978/25995/14996/21
999/12999/141005/211034/71034/10
1034/111036/61044/181071/161071/17
works [7] 791/15791/20970/17977/15
1036/191042/41046/3
world [5] 792/1792/2997/131035/25
1036/1
worry [1] 1072/23
would [170] 768/19770/3773/20774/12
774/13775/2775/3778/3784/13786/1
789/25790/20792/7792/11792/21793/17
796/18796/18797/22799/3800/21800/21
800/25803/8805/7805/12806/2814/8
815/4820/17820/21820/24823/7823/20
824/1826/11827/18828/1828/3829/24
831/22831/23833/19834/1838/21842/18
845/22851/5855/14856/16872/17873/17
873/19874/16874/22875/9875/22877/11
878/23879/25880/2885/4886/15887/7
887/16888/11888/24890/16891/24892/7
894/3894/6894/14895/6895/9895/21
901/24901/25902/9903/23905/13906/10
907/15907/16908/10909/20909/22
910/23910/24913/11913/16916/9917/6
917/9921/23924/12927/15927/23928/18
929/1929/3929/3931/1936/1937/2937/5
938/6952/6953/18954/6956/14956/19
957/17958/12961/1961/2961/6961/7
961/17962/7963/9963/10963/12966/17
976/1978/1978/11980/11980/20991/3
993/161001/151006/151009/51013/8
1013/121014/51014/61014/171023/17
1027/151029/91038/181038/191040/19
1041/91041/101041/111043/191045/15
1046/31046/211049/81049/161050/9
1050/101053/231055/181056/10
1060/131061/101064/171066/41067/1
1070/61070/221071/81072/21074/6
1074/23
wouldn't [12] 873/18880/1887/12
960/231014/61038/191042/111044/23
1045/131053/81060/101068/2
writ [1] 794/16
write [2] 1035/21062/17
writing [3] 1012/171012/191029/2
written [15] 789/6789/6789/8789/22
832/6832/11897/12897/13897/15904/24
917/21920/2952/111008/71070/2
wrong [13] 819/7937/20943/17957/16
965/25990/22992/51019/31025/8
1026/161026/211064/221074/10
wrongful [2] 1038/141038/14
wrote [2] 992/161029/3
Wyoming [5] 1036/121036/161038/1
1038/251039/5
X
X-I [1] 1004/9
X-I-N-G [1] 1004/8
Xi [2] 1004/61004/9
Xing [2] 1004/61004/8
Y
y'all [31] 766/5767/9790/20790/23795/6
819/2819/2820/11821/17822/6824/24
833/12833/15866/25867/2897/20910/11
911/22912/2912/7913/1933/4967/25
983/171018/131069/81069/181072/12
1073/151073/181076/11
yacht [11] 815/22815/24815/25820/18
887/4887/6925/22925/24926/1926/5
926/15
Yachts [1] 926/3
yard [2] 1015/241032/3
yeah [177] 766/22773/25779/24781/18
784/11784/14784/20785/7787/20788/19
789/1794/4802/20803/14810/2810/7
810/8810/22821/13826/3841/16845/16
845/19847/7852/4852/22855/16855/16
855/24862/4862/10863/17866/22868/14
873/13873/14880/17887/6893/11895/25
895/25895/25896/19899/6900/20917/11
917/13927/10937/5937/25938/25942/22
942/22943/17944/23945/1946/7947/21
947/23948/5964/13964/15972/17973/22
975/23976/24977/3977/20977/21978/2
978/14978/14978/18979/2984/24986/11
989/7989/16990/20992/4992/12993/4
993/4994/18995/2995/21995/21995/22
995/25995/25996/7996/13996/23996/23
996/24997/23998/7998/17999/4999/8
1000/81000/121000/241001/11001/7
1002/51004/141004/141005/11006/7
1006/71006/111008/31008/121008/23
1009/131009/161009/161010/41010/18
1011/11011/231011/251012/41012/16
1013/181014/211014/251014/25
1015/171016/21017/51017/51022/10
1022/111022/151023/31024/251025/2
1025/101026/51026/111028/71028/7
1028/171031/91031/91031/141032/18
1035/121038/21039/101039/131040/3
1040/161040/211043/221046/201047/7
1048/71053/21053/71053/71053/18
1054/101055/11055/111055/111061/20
1062/141062/191062/211064/24
1065/131066/71068/171073/14
year [34] 781/12782/3809/8812/2
837/18837/20890/12890/22891/11
891/11891/14893/3893/12894/9947/14
947/15978/24989/10989/11989/14
997/17998/251002/221020/171021/3
1025/241027/111028/41030/181041/25
1042/221042/221047/101057/23
years [29] 768/11768/13768/21768/23
844/14849/19849/23867/9868/13868/14
871/4883/3883/8939/2968/22987/16
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 358 of 359
Y
years... [13] 990/4991/10993/3993/4
995/12996/22996/23998/20999/16
1000/131000/161016/191018/2
yelling [2] 1032/81032/8
yep [1] 921/21
yes [588]
yesterday [4] 766/24910/14980/11
980/19
yet [13] 790/24805/10805/17805/18
805/19886/3891/251015/91042/11047/8
1060/251061/11061/21
you [1583]
you'd [1] 781/13
you'll [10] 777/18778/15804/2809/24
832/6857/23888/24900/11925/18
1012/13
you're [63] 793/3817/24832/3857/12
857/24874/24882/21887/19891/13
891/22895/10920/21939/5942/5942/5
942/6942/23965/13971/16990/17992/5
995/22996/221004/101004/101004/13
1008/241017/221018/21022/101022/17
1033/181033/191033/191033/20
1034/111041/201041/251042/13
1042/151043/71045/131047/51047/21
1047/231048/81048/211048/211054/23
1055/121055/161055/221056/171057/2
1058/221061/181062/171065/11066/13
1068/11076/21076/31076/7
you've [29] 773/23786/2787/2840/2
844/13856/7864/23867/22868/4895/20
898/24910/20911/15930/16957/15967/6
976/23977/5977/6990/71009/141014/12
1027/101043/201048/81052/121057/3
1059/81059/17
you-all [9] 821/20822/23857/12912/2
956/14979/121069/131071/141075/10
young [3] 911/241075/241076/13
younger [3] 1016/191018/21018/9
your [285] 766/14767/6767/11767/19
768/9768/18772/25773/17773/21774/19
775/6776/3786/1788/6790/5790/16
790/25796/2798/25801/17801/20803/21
805/3805/7810/19812/21814/21816/22
817/10819/17821/24823/1823/5824/5
824/7824/15828/3829/11829/24831/16
832/14839/23841/23850/24853/4854/8
861/7864/8864/17866/20867/14867/23
867/25869/14869/24872/22873/22
873/24882/3882/14882/24883/10885/4
886/15886/21887/10887/18888/11
888/18892/8892/15892/15894/25904/5
910/20911/1911/8912/4913/3919/18
919/19919/20932/2932/14933/6944/19
945/1945/5949/3949/11953/9954/8
954/17955/17956/5956/6956/9956/11
956/19957/13958/12958/15958/20959/1
959/24960/14962/5962/22963/2964/21
964/25966/17968/1968/13969/21970/14
970/23970/24971/6972/3975/8979/5
979/18980/16981/18981/21982/7982/11
982/18983/5983/7983/11983/18983/19
984/2984/14985/2985/8985/20985/20
985/22985/24986/2986/14986/17986/22
987/14987/20989/5989/6989/9990/5
990/19991/25993/24994/11995/10
996/10997/12997/19999/61004/2
1006/201007/21007/71007/91011/10
1012/11012/21013/191016/251017/3
1017/41017/191018/71018/111019/5
1019/241020/191021/11022/171022/17
1022/231023/11026/81028/31029/15
1030/81030/231030/251031/21031/11
1031/211033/181034/21034/241035/22
1035/241036/61038/41039/51039/14
1039/171040/41040/61040/151040/19
1040/231040/231041/111041/14
1041/161041/191042/131042/21
1042/211042/251043/151043/201044/7
1045/131045/171046/91046/91046/11
1046/121046/131046/161046/19
1046/211047/11047/21047/51047/6
1047/201048/181048/211049/12
1049/151049/151050/41051/31052/18
1053/171054/211055/141056/41056/13
1056/141057/131057/141057/221058/2
1058/41058/61058/221059/21060/12
1060/251061/21061/181061/191062/4
1063/11063/91065/21065/81065/14
1065/241066/41066/161066/241067/11
1068/121070/51070/201071/21071/11
1072/81073/81073/201074/131074/21
1074/221076/5
Your Honor [67] 767/6775/6790/16
803/21817/10819/17823/1824/15828/3
829/24832/14850/24873/22873/24885/4
886/15887/18888/11888/18912/4932/2
949/3953/9956/6956/9956/11956/19
958/12958/15958/20959/1959/24960/14
962/5962/22963/2964/21964/25966/17
968/1970/14970/23970/24975/8979/5
979/18980/16981/18981/21982/7982/11
982/18983/5983/11983/19986/14986/17
1019/241040/41040/61063/91070/5
1070/201071/21072/81073/201074/22
yours [4] 997/51037/181070/81070/8
yourself [2] 1008/251039/22
Z
zero [5] 1020/121034/121041/10
1045/141045/15
ZIP [2] 769/181053/10
zoom [11] 777/9788/18802/19806/1
806/9828/8898/4900/10900/111039/3
1054/17
Case 1:22-cr-00171-MLB-RDC Document 267 Filed 02/10/26 Page 359 of 359File and source
- File
- gov.uscourts.gand.303267.267.0.pdf
- Size
- 1,641,621 bytes
- SHA-256
- de883b9cc62b7b47dd97c36d48971b3a3224c91538d4597ff8db637bcc5c2e91
- Original
- PACER (login required)