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TRANSCRIPT of Proceedings (Jury Trial) as to Carl Delano Torjagbo held on 07/25/2025,… — USA v. Torjagbo (Dkt. 268)
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. 268 · 2026-02-10 · Docket on CourtListener
Summary
A transcript of jury trial proceedings, Volume 5, in United States of America v. Carl Delano Torjagbo, also known as Karl Lucius Delano, Criminal Action File No. 1:22-cr-00171-MLB, in the U.S. District Court for the Northern District of Georgia, Atlanta Division, held July 25, 2025 before United States District Judge Michael L. Brown and filed February 10, 2026 as Doc. 268. The appearance page lists two attorneys from the Office of the U.S. Attorney for the plaintiff and one attorney for the defendant. The opening records the court taking up the jury instructions and the Government resuming cross-examination of the defendant, who is questioned about his mine, the COVID pandemic and an asserted payroll of over $45.8 million in 2020. The closing pages are the transcript's word index. The transcript is 185 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
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
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- - -
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA,
)
)
Plaintiff, ) CRIMINAL ACTION FILE
v. ) NO. 1:22-CR-00171-MLB
) VOLUME 5
CARL DELANO TORJAGBO
)
also known as
)
KARL LUCIUS DELANO,
)
)
Defendant.
)
_______________________________)
--------------------------------------------------------------
BEFORE THE HONORABLE MICHAEL L. BROWN
TRANSCRIPT OF PROCEEDINGS
JULY 25, 2025
--------------------------------------------------------------
Proceedings recorded by mechanical stenography
and computer-aided transcript produced by
JANA B. COLTER, FAPR, RDR, CRR, CRC
Realtime Systems Administrator
Official Court Reporter
1949 U.S. Courthouse
75 Ted Turner Drive, SW
Atlanta, Georgia 30303
(404) 215-1456
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APPEARANCES:
For the Plaintiff: OFFICE OF THE U.S. ATTORNEY
(By: Kelly K. Connors
Nicholas L. Evert)
For the Defendant: LAW OFFICE OF L. BURTON FINLAYSON
(By: L. Burton Finlayson)
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_ _ _
P R O C E E D I N G S
(Atlanta, Fulton County, Georgia, July 25, 2025, in open
court.)
THE COURT: Y'all can be seated. Sorry about the
delay. We had one juror running a little late.
Y'all ready?
Any questions, concerns about the jury instructions I
gave you yesterday?
MR. FINLAYSON: No, sir.
MS. CONNORS: No, Your Honor.
THE COURT: You look confused.
MS. CONNORS: No, I think we had thought there was
going to be another final one after the stipulation part was
added, but I think we're good.
THE COURT: Okay. Would you give them a final one?
I'll get it to you.
MS. CONNORS: Okay.
THE COURT: Okay.
MS. CONNORS: It just always helps to be able to
follow along.
THE COURT: Yes. Okay. All right.
Bring them in, please.
MR. FINLAYSON: Wait. Do we want to put Karl back on
the stand?
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THE COURT: Oh, yes. Sorry. Thank you. Come on up,
sir.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. Y'all can be seated.
Go ahead, please.
BY MS. CONNORS:
Q.
Mr. Delano, during your testimony yesterday, you said your
mine had to close due to the COVID pandemic, right?
A.
Yes.
Q.
And yet in 2020, you alleged that you had paid over
$45.8 million in payroll to your employees of that mine,
right?
A.
Yes.
Q.
And so there was nothing about the pandemic that was
affecting your mining activities, right?
A.
Actually, let me explain that. The COVID lockdown took
place in the United States around March. The rest of the
world, mainly Africa, was not affected until about six or
seven months later. So there was a good six or seven months
of operation before COVID restrictions rules came in effect in
Africa.
Q.
But yet, I mean, the whole world was going through the
COVID pandemic.
A.
Um-hmm.
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Q.
So there was nothing about not having a vaccine yet that
was preventing you from paying your alleged employees, right?
A.
There was, because the vaccines were available in more
developed countries before they were made available in
countries like Africa, especially the third-world countries
and the poor countries, so yes, it did affect us.
Q.
Okay. So, Mr. Delano, when you were interviewed by
Agent Caruana, you never once mentioned Andrea Lewis, correct?
A.
I could not give -- the circumstances of the interview
with Agent Caruana did not give me the opportunity to explain
everything into details.
Q.
So your testimony is that when you have a federal agent
who is interviewing you because you have been arrested for PPP
fraud, you are not going to tell him that somebody else was
actually the one who provided all the documentation? Is that
right?
A.
The question was straightforward. And I gave him a
straightforward answer.
Q.
The question was straightforward.
A.
Yes.
Q.
And he asked you if anyone helped you prepare your PPP
loan, right?
A.
I applied for the application on my own.
Q.
Yes, you did.
A.
The documentation -- yeah, the documentation -- Andrea
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Lewis is the accountant. The question was did you apply for
the PPP loan on your own and I said yes.
Q.
And you never once, while you're under arrest for bank
fraud related to this PPP loan, did you volunteer Andrea
Lewis's name, correct?
A.
No, I did not.
Q.
And you never once mentioned to Agent Caruana the name
Michael Lee, either, right?
A.
No, I did not.
Q.
In fact, you said you were the owner of Kremkov, right?
A.
Yes, I am the owner of Kremkov.
Q.
Now, you testified yesterday that you had been a pilot in
Dubai for awhile, but you came back to the United States in --
what was it -- 2019 or 2020?
A.
It was towards the end of 2019.
Q.
So you weren't working as a pilot in 2020, correct?
A.
No, I was not.
Q.
And you were living in the United States, right?
A.
Yes, I was.
Q.
You were living in Douglasville, Georgia, right?
A.
Yes, I was.
Q.
You weren't flying or traveling in 2020, right?
A.
No, I was not.
Q.
So there was no reason you couldn't change your name in
2020, right?
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A.
Because in 2020, the COVID lockdown was in effect, so
people were not going anywhere.
Q.
Yesterday you testified that the reason you had not
changed your name before was because you were too busy being a
pilot, right?
A.
Yes.
Q.
But you were not a pilot after the end of 2019, right?
A.
Yes, I was enrolled in -- yes, I was still a pilot. I
wasn't traveling, but I was enrolled in courses in the attempt
to switch from the Boeing 737 Max, which was crashing, to the
777 and the 787. So even though I was not flying, I was
taking all of these courses and I was busy.
Q.
But you were in the United States?
A.
Yes.
Q.
You could have very easily walked over to any local
courthouse just like you eventually did after you got your PPP
money, right?
A.
Yes.
Q.
And after you had already gotten this huge tax refund,
right?
A.
Yes.
Q.
And yesterday you testified that you have two mines in
2020, right?
A.
Yes.
Q.
You said you had 312 miners in one of them and 300 in the
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other, right?
A.
Yes.
Q.
But when you were interviewed by Agent Caruana in 2022,
you said that you had 50 or 60 employees, right?
A.
Yes. Let me explain that answer.
Q.
Well, Mr. Torjagbo, first can you answer my question? Did
you tell Agent Caruana that you had 50 or 60 employees?
A.
Yes, but let me explain the answer. From the time the
COVID lockdown happened to the time Africa felt the effects of
the COVID lockdown, we were operating with 300 employees on --
what do you call it? -- in the Ashanti region, 312 and about
300 in the Volta region.
Now, when the lockdown effects took effect in Africa,
about six or seven months later, the workers couldn't actually
go inside the mines, because they have to be in close
quarters. So what happened was all the workers were doing
what we call panning, which is the process where they separate
the gold ore from the sand, so everybody was working on the
surface, there they could be in close -- they could maintain
the 6 feet separation or whatever the restrictions were.
So in December of 2020, I had a call from my father
and Mr. Lee, and they said after the last -- because also, the
United States because of the lockdown, right, they said after
the last pile of gold is panned, what do they call it? --
they were going to keep 50 employees to -- what do you call
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it? -- seal the mines because there was no more ore to pan, so
that was going to be in 2021.
So when Agent Caruana asked me that question, I
remembered the last -- the last thing that happened -- which
was in 2021, they were going to reduce the labor force to 50
or 60 employees to -- what do you call it? -- eventually seal
the mine shaft to secure them, so that is the -- that was the
basis of my answer.
And the question was vague also, 2021, so I just
answered the last thing that happened that I remembered.
Q.
Okay. So Mr. Delano, do you remember Agent Caruana
specifically asking you what was the maximum amount of
employees that you've ever had? And your response was 50 or
60?
A.
Yes, because I was still thinking in terms of 2021. I
didn't -- he didn't ask me what was the maximum amount of
employees that Kremkov has -- what do you call it? -- had from
the beginning of the operation of the mine until, you know --
it was a vague question. So I still thought in my mindset, I
still thought we were talking about 2021. And in 2021, yes,
it was 50, 60. I just gave an answer saying 50, 60 so I just
gave him the same answer.
Q.
Okay. So Delano --
A.
Yes.
Q.
-- you're saying you could not accurately interpret the
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question, what was the maximum amount of employees that you
have ever had; is that right?
A.
I was still thinking in terms of 2021, so I gave the
answer that I thought.
Q.
Mr. Delano --
A.
Yes.
Q.
-- when you sat down yesterday --
A.
Um-hmm.
Q.
-- you rattled off kind of a laundry list of
qualifications and certifications that you have.
A.
Um-hmm.
Q.
College graduate.
A.
Umm-hmm.
Q.
Pilot.
A.
Um-hmm.
Q.
Flight instructor.
A.
Um-hmm.
Q.
And even working and learning how to fly Boeing's most
elite airplane.
A.
Yes.
Q.
And yet you cannot -- your testimony is you could not
understand the question what was the maximum amount of
employees you have ever had? Is that your testimony?
A.
My testimony is that was the answer I gave and that was
what I thought he was asking me.
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And the circumstances of that interview didn't give
me all of the clarity that I needed to think and interpret it,
what he was actually after. I still -- my mindset was still
in 2021, and I gave him 50, 60 in 2021.
I actually thought he was trying to trick me to give
a different answer, because it would be like I just -- you
just told me that the number of employees were -- was about
50, 60. And then he asked me to guess, you know, so I
actually thought he was tricking me, so I gave him the same
answer.
Q.
Okay. And again --
A.
Um-hmm.
Q.
-- your testimony is that despite the fact that you're a
pilot and you have to have split-second reaction time to be
able to safely maneuver that airplane, your testimony is that
in the split second when he's interviewing you, it's
impossible for you to come up with an accurate answer? Is
that right?
A.
My testimony is when you are flying an airplane, it's
different. You react using reflexes that you've trained over
and over and over again, so you can react in a split second
when you're in danger.
If I -- if you -- if I went to Walmart last week and
I bought a bunch of groceries, I know I went to Walmart, but
if you asked me, you know, detail in the -- in the amount, I
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might not be able to give you the right answer.
Q.
Okay. But yesterday, you testified specific answers.
A.
Umm-hmm.
Q.
You said 312 people in one mine and 300 people in another
mine. So how do you now know three years later the precise
amount of employees that you had in those mines?
A.
Like I stated earlier, the circumstances of that interview
distracted me and I couldn't think properly.
Q.
You couldn't think to come up with 312 and 300 three years
ago when you were interviewed, right?
A.
Again, the state of my mind was I thought he was referring
to 2021, so the answer I gave him was for 2021. He specified
2021, yes.
Q.
And you never told Agent Caruana that it was instead
Andrea Lewis who was creating these payroll documents, right?
A.
No, because he did not ask that specific question.
Q.
Well, he asked you about the payroll, didn't he?
A.
Yeah, he asked me about the payroll. But he didn't ask
whether I had an accountant preparing the payroll, he didn't
ask any of that questions.
Q.
Okay. Well, do you recall that when he's asking you about
that payroll, he even points out that one of those payroll
documents is 71 pages. Do you recall that?
A.
Yes.
Q.
And when he points that out, your response was not, oh,
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that payroll is accurate. Oh, this is prepared by someone
else, right?
A.
Because he did not ask that question.
Q.
But your response --
A.
Um-hmm.
Q.
-- instead, you tried to divert to now your PPP loan was
not based on payroll, it was instead based on earnings, right?
A.
Because I read somewhere that the rules were changed.
That's what I thought, yeah.
Q.
But what you submitted in terms of documentation only
related to payroll, correct?
A.
Yes.
Q.
You didn't submit a single bank statement that would say
this is how much Kremkov Industries was making, right?
A.
No.
Q.
There's nothing that was submitted that would say that the
$3.8 million that was used to then multiply by two and a half
to come up with the loan amount, you didn't provide anything
to say that was the revenue or earnings, anything like that,
right?
A.
No, I did not.
Q.
What you did was you provided payroll to establish that
number, right?
A.
Yes.
Q.
And now your testimony is that really wasn't me, right?
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A.
I didn't say it wasn't really me. I said I thought the
rules were changed and now -- which I'm correct, because the
rules did change.
You know, somewhere -- I think somewhere in between
where I put in the application and stuff the rules did change,
it did change to where they stopped using the amount of
employees for calculating how much you made versus using how
much the company made, so...
Q.
But do you understand, though, that your loan was based on
the payroll that you provided?
A.
Yes, after that, I -- after that, yeah, I know.
Q.
So it does not matter whether you read something later
saying that any rule changed. The rules that were in effect
when you got your loan are the only thing that apply, right?
A.
If you say so, yes.
Q.
Now, yesterday you testified related to your first
Social Security number, the one ending in 6010.
A.
Yes.
Q.
Your testimony is that you obtained a -- you had a
Ghanaian passport that had that date of birth on it, correct?
A.
Yes.
Q.
You testified that you knew that that date of birth and
information on that passport was incorrect, right?
A.
Yes.
Q.
But you testified that you knowingly used a passport with
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false documentation on it to get an U.S. visa to come to the
United States, right?
A.
It was not a false documentation. There was an error with
the date of birth, and I did not have the time to change it,
so it was not false.
Q.
So for your own convenience --
A.
Um-hmm.
Q.
-- of not wanting to delay getting this visa from the
United States government --
A.
Um-hmm.
Q.
-- you were willing to just go forward with inaccurate
information, right?
A.
School was starting, so I had to.
Q.
Well, you didn't have to, right? You made the choice to
go forward, correct?
A.
My parents made the choice. I was still a minor. I was
16 and a half.
Q.
Okay.
A.
So my parents made the choice.
Q.
And so then -- but your parents don't go with you into the
Social Security office in 1997 here in the United States to
ask for that first Social Security card, right?
A.
No, they did not.
Q.
That's only you, correct?
A.
Yes.
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Q.
And you didn't disclose to the Social Security
Administration that you supposedly had incorrect information
on that passport, did you?
A.
No, because the only form of identification I had was the
passport that I came to the United States with.
Q.
So repeatedly in the past, you have been willing to
provide false information to the United States government in
order to get what you wanted, right?
A.
That is incorrect. That's incorrect.
Q.
Did you get a visa from the United States?
A.
Yes, I got a visa from the United States.
Q.
Did you get a Social Security card from the United States?
A.
Yes.
Q.
And both of those were based on information that you knew
were false, right?
A.
They were not false. It was a mistake made on the
passport.
Q.
But you knew that you were presenting a passport with
false information on it, right?
A.
I wouldn't say false information, because the fault is not
mine. The fault is either my parents or the people that
provided the documentation.
Q.
But it's your fault that you were willing to present that
to the United States government in order to get what you
wanted, right?
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A.
It's not my fault because I was a minor and I was acting
under direction from my parents.
Q.
Well, you weren't a minor, though, right?
A.
I was 16 and a half years.
Q.
1975 and 1997, you'd be 22 years old. So when you came
here, that was what you were representing, right?
A.
Yes.
Q.
And you knowingly represented that you were 22 years old,
right?
A.
No, because I'm not 22, I'm 16 and a half, 17 years when I
came here.
Q.
You've seen the Social Security application. It's
Exhibit 7 in this case.
A.
Um-hmm.
Q.
That application indicates you're born in Accra, Ghana.
It says you're born on September 8th of 1975, right?
A.
Yes, it does.
Q.
And nothing on that form says that you informed
Social Security, oh, that's not my real date of birth, right?
A.
No.
Q.
And then in 2005, when you go back and you get another
Social Security number, we saw it, Exhibit 9, you had the
opportunity on that application to indicate if there -- if
your date of birth needed to be corrected, right?
A.
I honestly did not see that part.
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Q.
So again, you're a college graduate, you're a pilot, you
can read English, correct?
A.
Yes, I can.
Q.
And yet, you didn't see that in a form that only has -- it
has less than 20 questions on it, you didn't see that it
indicated, one, have you had another Social Security number
assigned before; is that right?
A.
Yes, that's right. I skipped it. I don't know.
Q.
Well, you didn't skip it. What you did was you said no.
That is marked on that form. You said no, never had a
Social Security number before, right?
A.
Yes.
Q.
So you lied to the Social Security Administration to get a
second Social Security card, right?
A.
I did not lie.
Q.
At that point, you're now wanting to change, now you want
to be a bit younger, four years younger, so you change -- the
date of birth is different, right?
A.
Yes. The date of birth is different, because I explained
earlier, I got the birth certificate from Ghana, I presented
it to immigration, wrote a letter, explained why, and
immigration rectified the error. I corrected that mistake at
the earliest possible time that I could do that.
MS. CONNORS: Let's pull up Government's Exhibit 7
and 9 side by side.
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BY MS. CONNORS:
Q.
Now, Mr. Delano --
A.
Yeah.
Q.
-- it clearly states in Question Number 10 on Exhibit 9:
Has the applicant or anyone acting on his or her
behalf ever filed for or received a Social Security card
number before, correct?
A.
Yes.
Q.
And now you also are saying you somehow are able to get
your -- a Ghanaian birth certificate --
A.
Um-hmm.
Q.
-- to present in order to establish that you're instead
born in a different city in Ghana?
A.
Umm-hmm.
Q.
That you have a different date of birth?
A.
Umm-hmm.
Q.
Correct?
A.
Yes.
Q.
Totally different than what you indicated in Exhibit 7,
right?
A.
Yes.
Q.
And you were willing to lie in order to get what you
wanted, a different Social Security number, correct?
A.
I wasn't lying.
Q.
You answered no to have you ever had a Social Security
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number before, right?
A.
People make mistakes when they are filling out forms. It
doesn't mean I lied. Yes, I answered no. It was a mistake.
Q.
And you even signed this saying you declared under penalty
of perjury that you were giving accurate information, right?
A.
Yes, I signed it.
Q.
And this form is not a lengthy form. This is not
something where it's just getting buried in the middle, right?
A.
Yes, it's not a lengthy form.
Q.
Because you were perfectly able to fill out the other
information, right?
A.
Yes, I was.
Q.
And in fact, the questions that give you an opportunity to
say if you had a different date of birth used on an earlier
application, to provide the prior Social Security number,
those are skipped but then you did fill out the date and you
did fill out your daytime phone number and you signed it,
those are all after.
A.
Yes, I did.
Q.
So it's not a matter of skipping these questions
accidently, right?
A.
I made a mistake when I was filling the form. I maybe
overlooked it, I don't know. But it was a mistake. I
wasn't -- it wasn't deliberate.
As a matter of fact, after I got the new
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Social Security number, if I was intent on committing some
fraud or something, I would have been using it. When I got
the new one, I never used the old one, never again.
Q.
Except for when you filed another tax return in that name?
A.
I didn't. Except for when Andrea filed a tax return in
that name.
Q.
And the Andrea --
A.
And that was over 20 years ago.
Q.
Yeah. The Andrea who was at your house but somehow
mistakenly thought you were a full-year resident of Texas,
right?
A.
Yes.
Q.
The Andrea who conveniently is now in Romania, right?
A.
Yes.
Q.
The Andrea who you have no idea how to contact, right?
A.
Yes.
Q.
The person who'd be able to come in here and say, yep, I'm
the one who did all of that, right?
A.
Yes.
MS. CONNORS: If you can zoom out of that.
BY MS. CONNORS:
Q.
Now, Mr. Torjagbo --
A.
Um-hmm.
Q.
-- both of these forms ask you about where you are born.
It says place of birth on both forms, right?
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A.
Yes.
Q.
What did you say in Government's Exhibit 7?
A.
Accra, Accra Ghana.
Q.
Okay. And then what did you say on Government's
Exhibit 9?
A.
Takoradi, Ghana.
Q.
And yet when you were interviewed by Agent Caruana, he
asked you if you still had family in Ghana, right?
A.
And I said yes.
Q.
And he asked you where you grew up, right?
A.
Yes.
Q.
And what did you say?
A.
Can you repeat the question one more time.
Q.
Well, let me ask it this way.
A.
Um-hmm.
Q.
He asked you where you grew up and you said Ghana, right?
A.
Yes.
Q.
Then he asked you do you still have family in Ghana.
A.
Yes.
Q.
And you said yes?
A.
Yes, yes.
Q.
And then he asked you where were you born, right?
A.
Yes.
Q.
Do you recall what your response was?
A.
Yes.
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Q.
What was it?
A.
South Africa.
Q.
So you lied, right?
A.
I did not lie.
Q.
How could you confuse South Africa with Ghana?
A.
Okay. So there's a -- let me explain. There's a --
there's a long history and confusion about my place of birth.
So I will explain, I will explain.
Q.
Well, Mr. Delano --
A.
Um-hmm.
Q.
-- you can maybe explain --
MR. FINLAYSON: Objection, Your Honor. I believe he
should be allowed to explain.
THE COURT: Okay. Do you want to let him explain?
He can explain his answer. Okay. I'll let him explain his
answer.
THE WITNESS: Let me explain the answer.
So originally I was born in Cape Town, South Africa.
When I was four months old, I was -- when I was able to
travel, my parents transport me -- transported me to Ghana.
Because my dad was in the military, I was issued a birth
certificate in Ghana. So I've a birth certificate from
South Africa and a birth certificate from Ghana. And that's
the birth certificate that was provided to me.
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BY MS. CONNORS:
Q.
And so this South African birth certificate, have you ever
submitted that to the United States government?
A.
No, I have not.
MS. CONNORS: No further questions.
THE COURT: Redirect?
MR. FINLAYSON: Yes, sir.
REDIRECT EXAMINATION
BY MR. FINLAYSON:
Q.
Mr. Delano, you gave some examples yesterday of things
that you read in the SBA literature about what you could do
with PPP money. Do you remember that testimony?
A.
Yes.
Q.
And you gave the example of two McDonald's, if you had --
if you got a PPP from one McDonald's and you used it for
another, do you remember that example?
A.
Yes.
Q.
And on direct [sic] examination, the prosecutor was asking
you about that example and she asked you what happened to you,
well, you -- did -- you know, was there a flood or a tornado
or something like that that caused you to shut down the mine
and not spend the PPP money with Kremkov. Do you remember
those questions?
A.
Yes.
Q.
And did something bad happen though in Africa that caused
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you not to spend the PPP money with Kremkov?
A.
Yes. Because the vaccines were not going to be available
for any foreseeable time in Ghana.
Q.
Did you have to shut down the mines because of that?
A.
Yes.
Q.
Walk us through that, how did that -- how did that go
down?
A.
Okay. So like I explained earlier, like the effects of
the COVID vaccine did not take effect in most parts of -- in
most part of Africa after the lockdown in the U.S. until about
six or seven months.
So what happened was most of the workers that -- when
the effects took -- when the COVID effects took effect in
Ghana, most of the workers that were supposed to go inside the
mine and be in close quarters who are digging the actual --
what do you call it? -- the gold ore --
Q.
Let me stop you there.
A.
Um-hmm.
Q.
Did you guys make a decision to seal the mine?
A.
Yes.
Q.
And when was that?
A.
That was -- first we talked about it in I think January,
January.
Q.
And was the mine sealed?
A.
Yes, the mine was sealed.
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Q.
And what happened to the workers? Once the mine was
sealed, where did the -- where did the majority of the
workers -- what happened to them?
A.
They would look for other jobs, you know.
Q.
You let them go?
A.
Yeah.
Q.
Is that how you got to the number of 50 or 60?
A.
Yeah. The number of 50 or 60 was -- those employees were
to be kept to seal the mine, seal the entrance of the mine and
the shaft.
Q.
And that was 2021?
A.
And that was 2021, yeah.
Q.
Okay. She was just asking you about your interrogation by
Agent Caruana. Do you remember those questions?
A.
Yeah.
Q.
And she said that you were asked directly what was the
maximum number of employees you ever had. Do you remember the
question she was asking you?
A.
Yes.
Q.
And she said your reply was 50 or 60, right?
A.
Yes, yes.
Q.
Do you recall exactly word for word how that interrogation
went in this -- in this topic.
A.
Vaguely, I can -- I can try.
Q.
Could I refresh your recollection with a little
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transcript?
A.
Yes.
MS. CONNORS: Objection, Your Honor. He asked and
answered the question. He did not say that he did not
remember anything about the number of employees.
THE COURT: Hold on. I don't need talking
objections. Okay?
MS. CONNORS: Yes, Your Honor.
THE COURT: Would you step out for a minute, please?
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: I don't like speaking objections. I
tried to stop you and you buffaloed right through me to make
sure that the jury heard your point. I don't like that.
MS. CONNORS: I apologize, Your Honor.
THE COURT: What's the question?
MR. FINLAYSON: Your Honor --
THE COURT: You can't show him something to refresh
his memory that he can then read it and then this is what it
says.
MR. FINLAYSON: Well, here's --
THE COURT: You know how to refresh a recollection.
A refreshing a recollection is showing something and then
saying now think about what you did. If you want to do that,
you can.
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But he did not -- he did not say I don't remember. I
don't think that's what he said when he was being asked.
MR. FINLAYSON: If I can point -- I intentionally sat
on my hands during this cross-examination because of
yesterday, she misstated the question, absolutely, that is
not --
THE COURT: Okay. The jury will have to decide that.
But you said and she said your reply was 50 or 60. And he
said, repeat it, and he said yes.
Then you said do you recall exactly word for word how
that interrogation went on this topic?
I can -- he said vaguely, I can try.
You said can I refresh your recollection with a
transcript.
There's not even a question there. If you want to
ask a question, ask a question. If he doesn't remember it,
then you can refresh his recollection.
You can't lead him into it because you want to tell
your witness something outside of the presence of the jury
that you want to make sure that he now says and claims that he
remembers. Okay?
MR. FINLAYSON: Your Honor --
THE COURT: Let's bring --
Yes?
MR. FINLAYSON: The recording is in evidence.
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THE COURT: That's fine. Make that point in your
closing argument.
MR. FINLAYSON: You told me yesterday I could do it
on cross-examination, so I didn't object then. I should have
objected then. She misstated what the transcript -- she
misstated the truth of what happened.
THE COURT: Then you can ask him questions. You
asked him a question, he answered it.
You can argue to the jury what they should hear in --
what they remember about the transcript. You can ask the jury
in closing to go listen to the transcript to confirm what you
think.
But you asked him a question, he answered it. He
didn't say I don't remember. You asked him the question, he
answered it. And then you said do you recall exactly how that
interrogation went.
And he said I can try.
And then you said can I refresh your recollection.
He didn't say he doesn't remember something, that's
just -- you can't -- just the fact that you want your client
to say something different, you can't get him to do that by
giving him something and asking him to read something that he
does not claim to lack a memory of.
Do you understand?
So there's plenty of ways for you to cross it. You
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probably did what you want to do now because you've brought
the issue up and you've talked to your client while he's on
the stand.
But let's bring the jury in. Let's do what we're
supposed to do. We've had a pretty good trial so far. Let's
not lose our minds on the last day.
No speaking objections. And let's abide the rules of
evidence, including how you refresh a recollection, and what
it means. Okay?
You don't say to the jury I want to show you a
transcript and see if it refreshes your recollection. You
don't tell the jury what you're showing him. You can show him
a Bible, you can show him a phone book. You can show him
whatever you want if he says I don't remember. But you don't
tell the jury what you're showing him. That's not in
evidence.
Anybody dispute these basic rules of evidence?
MS. CONNORS: No, Your Honor.
THE COURT: All right. Let's bring the jury in and
keep going. I do not like bending the rules to get an
advantage.
MR. FINLAYSON: I'm not trying to do that, sir.
THE COURT: I think both of you were trying to do it.
And I don't like it. I don't like it. We play by the rules.
We can be hard, we can be tough. But we're going to be fair.
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COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. Y'all can be seated.
Go ahead.
MR. FINLAYSON: Thank you, sir.
BY MR. FINLAYSON:
Q.
Now, Mr. Delano, we were talking about your interrogation
with Agent Caruana.
A.
Yes.
Q.
First of all, do you remember that day when you were
interrogated?
A.
Yes.
Q.
Okay. And the prosecutor asked you some questions about
that, right?
A.
Yes.
Q.
Now, this interrogation was May the 12th of 2022; is that
right?
A.
Yes.
Q.
Okay. So three years ago?
A.
Three years, yeah.
Q.
Okay. Agent Caruana asked you what the maximum amount of
employees that you ever had was; is that right?
A.
Yes.
Q.
And what was your answer, if you recall it?
A.
Yeah. My answer was off the top of my head, I did not
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know. And then he proceeded to say, you know, guess, guess,
I'm not going to lock you into the answer.
And I said, you know, I don't want to give you
answers that, you know, later on might be interpreted as, you
know, I'm lying or it's wrong, I couldn't -- because there was
a high turnover, you know, I was not going to be able to come
up with an answer. And he kept edging me on to guess. He was
not going to lock me into the answer. And so I said -- gave
him the same answer, 50, 60.
Q.
So but when he asked you the question --
A.
Um-hmm.
Q.
-- specific question --
A.
Um-hmm.
Q.
-- what was the maximum amount of employees you ever
had --
A.
Um-hmm.
Q.
-- you didn't say 50 or 60 at that point, did you?
A.
No.
Q.
And was that reflected on the recording of your interview
that we've heard in evidence already?
THE COURT: The jury will recall what the evidence
is. The witness is not supposed to answer what he thinks the
witness is. The witness is to answer questions. But the jury
will recall what the evidence is and might even have that --
will have that back there with them.
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Go ahead, please.
MR. FINLAYSON: Thank you, sir.
THE WITNESS: Um-hmm.
MR. FINLAYSON: Moving on.
BY MR. FINLAYSON:
Q.
And to be clear, what was -- in the good times, when the
mine was making money and getting gold, what was the maximum
number you had?
A.
It was around 612, something like that.
Q.
And why didn't you put 612 on the PPP application?
A.
Because not all of them were U.S. citizens.
Q.
What was your understanding of who could be counted as an
employee for the PPP application?
A.
It was the people whose place of -- permanent place of
residence was in the United States.
Q.
Now, she asked you just now about Michael Lee and Andrea
Lewis, right?
A.
Yes.
Q.
Were they real people?
A.
Yes.
Q.
Where was Michael Lee from?
A.
He's a Chinese national from China.
Q.
And where is he now, if you know?
A.
The last I heard from him, he said when the mines were
sealed, he was going back to China, so I assume he's in China
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now.
Q.
Do you have any way from where you are right now to
contact him in China?
A.
No, I do not.
Q.
And Andrea Lewis, is she a real person?
A.
Yes, she is.
Q.
And where is she now?
A.
She moved to Romania with her husband.
Q.
Um-hmm. And do you have any way to reach her from where
you are now?
A.
No, I do not.
Q.
Now, the government made some point about these people
that are the back of the courtroom. Do you know those guys?
A.
Yes, sir, I know two of them.
Q.
Okay. To your knowledge, are -- do they have any way to
reach out to people in China?
A.
No, they do not.
Q.
Or Romania?
A.
No, they do not.
Q.
She asked you a bunch of questions about your
Social Security number. And, yeah, you said when you came to
this country, right?
A.
Yes.
Q.
How old were you when you came to the U.S.?
A.
I was just about to turn 17.
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Q.
And who got the passport for you in Ghana?
A.
My father.
Q.
And how did it come to your house or how did you -- how
did you actually take possession of it in Ghana?
A.
Actually, my father went to the passport office and picked
it up.
Q.
And when did you see that the birthdate was wrong?
A.
When he brought it, he actually told me they made a
mistake on your -- on your -- you know, on your what -- what
do you call it? -- on the date of birth on the passport.
But, you know, the visa interview was -- was like a
month away so we did not have a way of changing it.
Q.
Were you trying to lie your way into the United States
with a false date of birth?
A.
No, I was not.
Q.
And when you got a replacement card, were you trying to
lie about your identity some way there?
A.
No, I was not.
Q.
And you gave them the same name?
A.
Yes.
Q.
And then you corrected the date of birth?
A.
Yes, I did.
Q.
And you presented a Ghanaian birth certificate when you
got that replacement Social Security card; is that right?
A.
Yes.
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Q.
Where did you get that Ghanaian birth certificate?
A.
My father mailed it to me.
Q.
And this may be a silly question --
A.
Um-hmm.
Q.
-- but when you were a baby --
A.
Um-hmm.
Q.
-- did you have any real-time memory of where you were
born?
A.
No, I do not.
Q.
You've been relying on other people your entire life to
tell you that?
A.
Yes.
Q.
And at some point somebody gave you -- your father gave
you a South African birth certificate?
A.
Yes.
Q.
Okay. Was that news to you?
A.
Yes.
Q.
How old were you when you learned -- when you heard that?
A.
How old was I?
Q.
When you heard about this -- that you were born --
actually born in South Africa?
A.
It was when my father and my mother were going through
some problems.
Q.
They split up?
A.
They split up, yeah.
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Q.
Do you have any memory of South Africa?
A.
No, I do not.
Q.
Until then, did you even know you had been to South
Africa?
A.
No, no.
Q.
And so have you ever even -- did you ever try to present
that South African birth certificate to anybody?
A.
No, I have not.
Q.
So according to Ghanaian tradition, or your understanding
of it, where -- where -- what did the records show where you
were born? What did -- you have --
A.
The record -- the record said I was born in Ghana. The
record said I was born in Takoradi, Ghana. That was what was
on the birth certificate.
Q.
And do you know whether you were born in that town or not?
A.
I did not, no. That's what the birth certificate said,
yeah.
Q.
It is a town in Ghana, right?
A.
Yes.
Q.
And Accra is a town in Ghana?
A.
Yes.
Q.
Did you change those up to try to trick anybody in the
U.S. Government?
A.
No.
MR. FINLAYSON: Those are all my questions, Judge.
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THE COURT: Any redirect?
MS. CONNORS: No, Your Honor.
THE COURT: All right. We're going to take another
quick break. Okay?
I need to go over some things and then we'll see
where we are. Okay?
Thank you.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: All right. Y'all can be seated.
You can step down, sir.
Do you have any more witnesses?
MR. FINLAYSON: No more witnesses, Your Honor. We're
going to rest. And for the record, I would -- I don't know if
we need to do that in front of the jury.
But I would renew my Rule 29 motion based on the
grounds previously stated, and also on the grounds across the
counts that the government has not sufficiently proven a lack
of good faith. Otherwise, the same -- the same motion as from
before.
THE COURT: Okay. I'm going to deny that motion. I
think, in fact the -- I think that your client has testified
means that the jury can reject his testimony and reach the
opposite conclusion as to his intent, so I think that the
Rule 29 issue becomes even weaker once a defendant testifies.
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I won't talk -- I won't suggest anything about my
feelings about his testimony, because it doesn't matter, but I
don't think the case got stronger for your Rule 29.
Okay. So that means we're going into closing
arguments, right?
I'll bring the jury out. You can rest.
Does the government have any rebuttal case?
MS. CONNORS: No, Your Honor.
THE COURT: Okay. So I'll give you an opportunity to
say that in front of the jury. And then I will tell the jury
that they're going to hear closings and I will read them the
instructions and then we will close, right?
MR. FINLAYSON: Yes, sir.
Could I get a quick bathroom break?
THE COURT: Yes. I'm going to give you a couple of
minutes, because I'm going to ask you during this couple of
minutes for any final, final changes to the jury instructions.
And I mean it because I'm going to read it in like five
minutes. Okay?
So we're down to the last part of it, so okay, we'll
be back in --
MS. CONNORS: Your Honor.
THE COURT: Yes.
MS. CONNORS: After you read the instructions, is
there a chance we could like a two-, three-minute quick break
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so then we can do computer setup?
THE COURT: Why don't you do that now.
MS. CONNORS: Okay.
THE COURT: I'm going to read -- as I said to you
before, right until the last page is all I'm going to go over
with them afterwards.
Have you-all looked at the proposed verdict form?
MR. FINLAYSON: Yeah, we have.
THE COURT: And you-all have approved the
instruction -- I'm sorry, the copies of the indictment that
goes back?
MS. CONNORS: I'm not sure if I saw the verdict form.
THE COURT: I'm sure it was filed by y'all.
MS. CONNORS: Oh, I wasn't sure if it had changed
since we submitted it.
THE COURT: No. It's pretty simple. It just says as
to Counts One and each one, do you want to take a look at it?
MS. CONNORS: No, Your Honor. If it's the same one,
then that's fine.
THE COURT: But you-all are okay with the --
MR. FINLAYSON: Yes. Yes, sir.
THE COURT: -- with the copy of the indictment, too?
I think it's got the forfeiture provision blacked out.
MS. CONNORS: Yes.
MR. FINLAYSON: Yeah, I don't know of a better way.
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The only other way to do it would be to cut and paste and move
the signatures. It's okay. I've seen it done -- I've seen it
done where we take that block out, I think, but...
THE COURT: All right. Well, I'm happy to do it any
way y'all want, just let me know. Okay?
I'll be back in about ten minutes, okay?
Would you tell them that we're going to be 10 or 15
minutes from now. And this will be their morning break.
COURTROOM SECURITY OFFICER: Yes, sir.
(Whereupon, a recess was taken.)
THE COURT: Okay. Any objections or changes to the
jury instructions, problems or errors?
MS. CONNORS: Not from the government, Your Honor.
Thank you.
THE COURT: How about for the defense?
MR. FINLAYSON: No, Your Honor.
THE COURT: All right. Let's bring them in. Thank
you.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: Y'all can be seated. We're missing two.
Yes. All right.
All right. Mr. Finlayson, do you have any other
witnesses?
MR. FINLAYSON: No, sir, Your Honor. On behalf of
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Mr. Delano, the defense rests.
THE COURT: Okay. Thank you.
How about the United States, do you have any rebuttal
case?
MS. CONNORS: No, Your Honor.
THE COURT: Okay. So you-all have heard all of the
evidence in this case. All right?
What happens next is I'm going to give you five or so
minutes of instructions on the law. And then the parties are
going to have a chance to give you their closing arguments.
And then I'm going to give you one more very short instruction
and then release you to begin your deliberations. Okay?
We should be wrapped up I would think before lunch.
And if that's the case, that means you get a free lunch today.
When you're deliberating, you get a free lunch. Okay? We buy
your lunch that day. All right?
I think that's all I wanted to tell you now. So now
I'm going to give you instructions. Listen to these
instructions. But I'm going to have copies brought back to
you. Okay?
So you don't necessarily have to take notes, okay,
you can if you want to, but you will have several written
copies of my instructions to you in the jury room. Okay?
All right. It is my duty to instruct you on the
rules of law that you must use in deciding this case. As I
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said, after I've completed these instructions, the parties
will have an opportunity to make their closing arguments and I
will then give you one or two additional instructions and
release you to the jury room to begin your discussions or what
we call your deliberations.
You must decide whether the United States has proved
the specific facts necessary to find the defendant guilty
beyond a reasonable doubt. Your decision must be based only
on the evidence presented here. You must not be influenced in
any way by either sympathy for or prejudice against the
defendant or the United States.
You must follow the law as I explain it to you, even
if you do not agree with the law, and you must follow all of
my instructions as a whole. You must not single out or
disregard any of the Court's instructions on the law.
The indictment or formal charge against the
defendant, which you will have back there with you, is not
evidence of guilt. The law presumes every defendant is
innocent. The defendant does not have to prove his innocence
or produce any evidence at all. The government must prove the
defendant guilty beyond a reasonable doubt, and if it fails to
do so, you must find the defendant not guilty.
The United States' burden of proof is heavy, but it
doesn't have to prove a defendant's guilt beyond all possible
doubt. The United States' proof only has to exclude any
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reasonable doubt concerning the defendant's guilt. A
reasonable doubt is a real doubt, based upon your reason and
common sense after you have carefully and impartially
considered all the evidence in the case.
Proof beyond a reasonable doubt is proof so
convincing that you would be willing to rely and act on it
without hesitation in the most important of your own affairs.
If you are convinced that the defendant has been
proved guilty beyond a reasonable doubt, say so. If you are
not convinced, say so.
As I've said before, you can only consider the
evidence that I have admitted. Evidence includes the
testimony of witnesses and the exhibits that were admitted.
But anything the lawyers say is not evidence and isn't binding
on you.
I'll remind you that sometimes the parties have
agreed that certain facts are true. These are the
stipulations that were read to you. You must treat those
facts as proven in this case.
You shouldn't assume from anything that I have said
that I have any opinion about any factual issue in this case.
Except for my instructions to you on the law, you should
disregard anything I may have said during the trial in
arriving at your own decision about the facts.
Your own recollection and interpretation of the
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evidence is what matters. In considering the evidence, you
may use reasoning and common sense to make deductions and to
reach conclusions. You should not be concerned about whether
the evidence is direct or circumstantial. Direct evidence, as
I told you before, is a person who asserts -- is the testimony
of a person who asserts that he or she has actual knowledge of
a fact, like an eyewitness.
Circumstantial evidence is proof of a chain of facts
and circumstances that tend to prove or disprove a fact.
Remember the example I gave you of somebody seeing your
neighbor fishing or seeing your neighbor walking with a
fishing pole, that's the difference between direct and
circumstantial evidence. There's no legal difference in the
weight you may give to either direct or circumstantial
evidence.
When I say you must consider all of the evidence, I
don't mean you must accept all of the evidence as true or
accurate. You should decide whether you believe what each
witness had to say, how important that testimony was, and in
making that decision, you may believe or disbelieve any
witness in whole or in part. The number of witnesses
testifying about a particular point doesn't necessarily
matter. You'll recall that I went over some questions you
might ask yourself in assessing a witness's credibility.
Things like:
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Did the witness impress you as one who was telling
the truth?
Did the witness have any particular reason not to
tell the truth?
Did the witness have a personal interest in the
outcome of the case?
Did the witness seem to have a good memory?
Did the witness have the opportunity and ability to
observe accurately -- to accurately observe the things he or
she testified about?
Did the witness appear to understand the questions
clearly and answer them directly?
And did the witness's testimony differ from other
testimony or other evidence in the case?
You should ask yourself whether there was evidence
that a witness testified falsely about an important fact. And
ask whether there was evidence that at some other time, a
witness said or did something or didn't say or do something
that was different from the testimony the witness gave during
the trial.
But keep in mind that a simple mistake doesn't mean a
witness wasn't telling the truth as he or she remembers it.
People naturally tend to forget some things or remember them
inaccurately. So if a witness misstated something, you must
decide it was because of an innocent lapse of memory or an
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intentional deception. The significance of the misstatement
may depend on whether the misstatement was about an important
fact or about an unimportant detail.
A defendant has a right not to testify, but since the
defendant did testify in this case, you should decide whether
you believe the defendant's testimony in the same way as any
other witness.
If the government offers evidence that a defendant
made a statement or omission to someone after being arrested
or detained, you must consider that evidence with caution and
great care. You must decide for yourself whether the
defendant made the statement and, if so, how much weight to
give it. To make these decisions, you must consider all the
evidence about the statement, including the circumstances
under which it was made.
The indictment, which again you'll have back there,
charges ten separate crimes called counts against the
defendant. Each count has a different number. You'll be
given a copy. Count One -- I'm going to go over them broadly
or generally with you.
Count One charges the defendant with bank fraud.
Count Two and Three charge the defendant with wire
fraud.
Count Four, Five and Six charge him with concealment
money laundering.
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And Count Seven through Ten charge him with
transactional money laundering.
I'm going to explain those substantive offenses to
you in just a moment. I'm going to go through each one. But
let me first tell you that where a statute specifies multiple
alternative ways in which an offense may be committed, the
indictment may allege multiple ways in the conjunctive, that
is by using the word "and." If only one of the alternatives
is proved beyond a reasonable doubt, that is sufficient for
conviction, so long as you-all agree unanimously as to that
alternative.
Okay?
They can charge it "and," but you can still convict
for one of those as long as it is, in fact, unanimous. All
right?
You'll see that the indictment charges that a crime
was committed on or about a certain date. The United States
doesn't have to prove that the offense occurred on an exact
date. The United States only has to prove beyond a reasonable
doubt that the crime was committed on a date reasonably close
to the date alleged.
Let's talk about each crime. Okay? I told you
there's ten different counts, some of them charge the same
crime, I'm going to go through each one before.
Count One, as I told you, charges the defendant with
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bank fraud. It is a federal crime to carry out or attempt to
carry out a scheme to defraud a financial institution or to
get money or property owned or controlled by a financial
institution by using false pretenses, representations or
promises.
The defendant can be found guilty of that crime only
if the following facts are proved beyond a reasonable doubt:
First, the defendant knowingly carried out or
attempted to carry out a scheme to defraud a financial
institution or get money, assets or other property from a
financial institution by using false or fraudulent pretenses,
representations or promises about a material fact.
Second, the false or fraudulent pretenses,
representations or promises were material.
Third, the defendant intended to defraud the
financial institution.
And, fourth, that the financial institution was
federally insured.
I'm going to give you some definitions of some of the
words I've just used.
A scheme to defraud includes any plan or course of
action intending to deceive or cheat someone out of money or
property by using false or fraudulent pretenses,
representations or promises about a material fact.
A statement or representation is false or fraudulent
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if it is about a material fact that the speaker knows is
untrue or makes with reckless indifference as to the truth and
makes with the intent to defraud.
A statement or representation may be false or
fraudulent when it's a half truth or effectively conceals a
material fact and is made with the intent to defraud.
A material fact is an important fact that a
reasonable person would use to decide whether to do or to not
do something. A fact is material if it has the capacity or
natural tendency to influence a person's decision. It doesn't
matter whether the decision maker actually relied on the
statement or knew or should have known that the statement was
false.
To act with the intent to defraud means to act
knowingly and with the specific intent to use false and
fraudulent pretenses, representations or promises to obtain
the victim's money or property. Proving intent to defraud
does not require proof that the defendant acted with the
intent to leave the victim economically worse off.
The government doesn't have to prove all the details
alleged in the indictment about the precise nature and purpose
of the scheme. It doesn't have to prove that the alleged
scheme actually succeeded in defrauding anyone.
What must be proved beyond a reasonable doubt is that
the defendant knowingly attempted or carried out a scheme
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substantially similar to the one alleged in the indictment.
Counts Two and Three charge the defendant with wire
fraud. It is a federal crime to use interstate wire
communications to carry out a scheme to defraud someone. The
defendant can be found guilty of this crime only if the
following facts are proved beyond a reasonable doubt:
First, that the defendant knowingly devised or
participated in a scheme to defraud someone by using false or
fraudulent pretenses.
Second, that the false and fraudulent pretenses,
representations or promises were about a material fact.
Third, that the defendant acted with the intent to
defraud.
And, fourth, that the defendant transmitted or caused
to be transmitted by wire some communication in interstate
commerce to help carry out the scheme to defraud.
How about some definitions?
I've used the word knowingly. Knowingly means that
the act was done voluntarily and intentionally and not because
of mistake or accident.
Scheme to defraud, which I think I've already defined
once, means a plan or course of action intended to deceive or
cheat somebody out of money or property by false or fraudulent
pretenses, representations or promises.
As I told you a minute ago, a statement or
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representation is false or fraudulent if it's about a material
fact that the speaker knows is untrue or makes with reckless
indifference to the truth and makes with the intent to
defraud.
A statement or representation may be false or
fraudulent when it is a half truth or effectively conceals a
material fact and is made with the intent to defraud.
A material fact is an important fact, as I said a
minute ago, that a reasonable person would use to decide
whether to do something or not to do something.
A fact is material if it has the capacity or natural
tendency to influence a person's decision. It doesn't matter
whether the decision maker actually relied upon the statement
or knew or should have known that the statement was false.
I explained what an intent to defraud means a minute
ago. I'm going to do it again. It means to act knowingly and
with the specific intent to use false or fraudulent pretenses,
representations or promises to obtain the victim's money or
property.
Proving the intent to defraud does not require proof
that the defendant acted with the intent to leave the victim
economically worse off.
The government again doesn't have to prove all of
the -- all of the details alleged in the indictment about the
precise nature and purpose of the scheme.
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It also doesn't have to prove that the material
transmitted by interstate wire was itself false or fraudulent,
or that using the wire was intended as the specific or
exclusive means of carrying out the alleged fraud or that the
defendant personally made transmissions over the wire. And it
doesn't have to prove that the alleged scheme actually
succeeded in defrauding anyone.
To use interstate wire communications is to act so
that something would normally -- let me say that again.
To use interstate wire communications is to act so
that something would normally be sent through wire
communications in the normal course of business. Each
separate use of the interstate wire communications as part of
the scheme to defraud is a separate crime. All right?
Let's talk about Counts Four through Six, those are
concealment money laundering. You see why I'm going to give
you all of these instructions. Some I'm repeating, there
might be some differences, but you'll have them.
It is a federal crime to knowingly engage in certain
kinds of financial transactions commonly known as money
laundering. The defendant can be found guilty of this crime
only if the following facts are proved beyond a reasonable
doubt:
First, the defendant knowingly conducted or tried to
conduct a financial transaction.
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Second, the defendant knew the money or property
involved in the transaction were the proceeds of some kind of
unlawful activity.
Third, the money or property did come from an
unlawful activity, specifically bank fraud or wire fraud.
And, third -- or I'm sorry, fourth, the defendant
knew the transaction was designed in whole or in part to
conceal or disguise the nature, location, source, ownership or
control of the proceeds.
To conduct a transaction means to start or finish a
transaction or to participate in a transaction at any point.
A transaction means a purchase, sale, loan, promise, gift,
transfer, delivery or other disposition of money or property.
A transaction with a final -- financial institution
also includes a deposit, withdrawal, transfer between
accounts, exchange of currency, loan, extension of credit, use
of a safety deposit box, or purchase or sale of any stock,
bonds, certificate of deposit or other monetary instrument.
A financial transaction -- this is a long definition.
Okay? A financial transaction means a transaction that in any
way or to any degree affects interstate or foreign commerce by
sending or moving money by wire or other means.
Or a transaction that in any way or to any degree
affects interstate or foreign commerce by involving one or
more monetary instruments. A monetary instrument includes a
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coin or currency of any country, traveler's or personal
checks, bank checks or money orders, investments, securities
or negotiable instruments in a form that allows ownership to
transfer on delivery.
A financial transaction can also be a transaction
that in any way or to any degree affects interstate or foreign
commerce by involving the transfer of title to any real
property, vehicle, vessel or aircraft.
It can also be a transaction involving the use of a
financial institution that is involved in interstate or
foreign commerce or whose activities affect interstate or
foreign commerce in any way or degree.
The phrase financial institution includes a bank
insured by the Federal Deposit Insurance Corporation.
Interstate or foreign commerce, let me define that
for you. It means trade or other business activity between
people or businesses in at least two states or between people
and businesses in the United States and people or businesses
outside the United States.
To know that the money or property involved in the
transaction came from some kind of unlawful activity is to
know that the money or property came from an activity that is
a felony under federal, state or foreign law.
The term proceeds means any property derived from or
obtained or retained directly or indirectly through some form
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of unlawful activity, including the gross receipts of the
unlawful activity.
The phrase specified unlawful activity means bank
fraud or wire fraud, which I've already explained to you, that
was in the earlier Counts. All right?
I'm getting close to the end. I'm on like Page 17 of
20. Okay?
No, I'm on 16 of 20.
All right. Again, let's talk about Counts Seven
through Ten, those are the ones I haven't talked to you about,
that is charging the defendant with transactional money
laundering.
It's a federal crime for anyone to engage in certain
kinds of financial transactions commonly known as money
laundering. A defendant can be found guilty of this
transactional money laundering crime only if the following
facts are proved beyond a reasonable doubt:
First, the defendant knowingly engaged or attempted
to engage in a monetary transaction.
Second, the defendant knew the transaction involved
property or funds that were the proceeds of some criminal
activity.
Third, the property had a value of more than $10,000.
Fourth, the property was, in fact, the proceeds of
bank fraud or wire fraud.
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And, fifth, the transaction took place in the United
States.
The term monetary transaction means the deposit,
withdrawal, transfer, exchange of funds or a monetary
instrument by, through or to a financial institution in a way
that affects interstate commerce.
A financial institution means a bank insured by the
FDIC.
The term proceeds means any property derived from or
obtained or retained directly or indirectly through some form
of unlawful activity, including the gross receipts of the
activity.
It doesn't matter whether the defendant knew the
precise nature of the crime or that the property came from
committing bank fraud or wire fraud. But the government must
prove that the defendant knew the property involved in the
monetary transactions was obtained or derived from committing
some crime.
Also it doesn't matter whether all the property
involved was derived from a crime. The government only has to
prove that more than $10,000 worth of the property was
obtained or derived from committing a crime. All right?
Does the aiding and abetting apply to all counts?
MS. CONNORS: Yes, Your Honor.
THE COURT: Okay. All right. I'm going to give you
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an instruction that applies to all counts. All right?
It is possible to prove the defendant guilty of a
crime without evidence that the defendant personally performed
every act charged. Ordinarily, any act a person can do may be
done by directing another person or agent or it may be done by
acting with or under the direction of another person.
A defendant aids and abets a person if the defendant
intentionally joins with the person to commit a crime.
A defendant is criminally responsible for the acts of
another person if the defendant aids and abets the other
person. A defendant is also responsible if the defendant
willfully directs or authorizes the acts of an agent, employee
or other associate.
But finding that a defendant is criminally
responsible for the acts of another person requires proof that
the defendant intentionally associated with or participated in
the crime, not just proof that the defendant was simply
present at the scene of the crime or knew about the crime.
In other words, you must find beyond a reasonable
doubt that the defendant was a willing participant in the
crime and not merely a knowing spectator.
You have heard in this case about two Social Security
numbers allegedly acquired by the defendant prior to the
offense charged in the indictment.
I read you this instruction before, I'm going to read
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it to you again. You must not consider this evidence to
decide if the defendant engaged in the activity alleged in the
indictment. But you may consider this evidence to decide
whether the defendant had the state of mind or intent
necessary to commit the crimes charged in the indictment, the
defendant had the motive or the opportunity to commit the acts
charged in the indictment, the defendant acted according to a
plan or in preparation to commit a crime, or the defendant
committed the acts charged in the indictment by accident or
mistake.
Good faith is a complete defense to a charge that
requires intent to defraud. A defendant isn't required to
prove good faith. The government, the United States, must
prove intent to defraud beyond a reasonable doubt.
An honestly held opinion or an honestly formed belief
cannot be fraudulent intent, even if the opinion or belief is
mistaken. Similarly, evidence of a mistake in judgment, an
error in management or carelessness can't establish fraudulent
intent.
But an honest belief that a business venture would
ultimately succeed doesn't constitute good faith, if the
defendant intended to deceive others by making representations
the defendant knew to be false or fraudulent.
Each count of the indictment charges a separate
crime. You must consider each crime and the evidence related
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to it separately. If you find the defendant guilty or not
guilty of one crime, that must not affect your verdict for any
other crime.
I caution you the defendant is on trial only for the
specific crimes charged in the indictment. You are here to
determine from the evidence in this case whether the defendant
is guilty or not guilty of those specific crimes.
You must never consider punishment in any way to
decide whether the defendant is guilty. If the defendant
is -- if you find the defendant guilty, the punishment will be
for the Judge alone to decide.
You've been permitted to take notes during the trial
and I think some of you have done that, maybe most of you.
But remember, you must use those as a memory aid during your
deliberations, you must not give them any more priority over
your independent recollection of the evidence and you must not
allow yourself to be unduly influenced by the notes of other
jurors.
I really want to emphasize that notes are not
entitled to any greater weight than your memories or
impressions about the testimony.
Your verdict, whether guilty or not guilty, must be
unanimous. In other words, you must all agree. Your
deliberations are secret and you'll never have to explain your
verdict to anyone. Each of you must decide the case for
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yourselves, but only after fully considering the evidence with
the other jurors. So you must discuss this case with one
another and try to reach an agreement. While you're doing
that, don't hesitate to reexamine your own opinion and change
your mind, if you become convinced you were wrong.
But don't give up your honestly held beliefs just
because others think differently or because you simply want to
get this case over with.
Remember that in a very real way, you are the judges,
the judges of the facts in this case. And your only interest
is to seek the truth from the evidence in this case.
That's all I've got to say to you right now.
Any objection to the way I've presented the -- other
than what we talked about, the instructions imparted to the
jury?
MR. FINLAYSON: No, sir, nothing additional.
THE COURT: Ms. Connors?
MS. CONNORS: No, Your Honor.
THE COURT: Okay. All right. Now is the time for
closing arguments. I've told you before what they say is not
evidence, but it's their opportunity to argue to you what they
believe the evidence was and how it might apply to the law.
It's very important for you to understand that, so please pay
attention.
The government, because they have the burden of
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proof, they go first. Then the defense. And then the
government has a chance for a short rebuttal, a rebuttal.
Okay?
All right. Go ahead, please.
MS. CONNORS: Good morning. Ladies and gentlemen,
may it please the Court, this week the United States has
proven beyond a reasonable doubt that Karl Delano, formerly
known as Carl Torjagbo, is guilty of defrauding Chase Bank and
the Internal Revenue Service.
And that beyond a reasonable doubt he then took the
proceeds of his fraud schemes and laundered that money,
purchases of multiple extremely expensive assets, a mansion,
vehicles, a yacht, and he moved money through multiple bank
accounts to try to hide where he got it in the first place.
Ladies and gentlemen, as you begin deliberations, the
one thing that I would remind you that the Court instructed
you on earlier today is that you do not have to leave your
common sense at the door. You take it with you into that
deliberation room.
So when you're thinking of the convenient story that
the defendant has told this week, that's what you should be
thinking about as well is what does your common sense tell
you.
The defendant has told this convenient story about
that it's really these other people that have never been
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mentioned before who were the ones behind the schemes that
resulted in more than $12 million going into his bank
accounts, bank accounts that he controlled, he was the sole
signer on those accounts.
And he's telling this story in a way to try to bob
and weave around the undisputed facts in this case. The
documents that you have seen and the testimony that you've
heard.
There was never any mention of Andrea Lewis during
his custodial interview. There was never any mention of a
Michael Lee during his custodial interview. And instead, the
defendant at that time admitted he didn't have any
U.S. operations for Kremkov, he only had 50 or 60 employees,
everyone was in Ghana, all of the things that made him
ineligible for any kind of PPP loan.
And he indicates that he somehow convinced
Michael Lee in early 2021, to send a tax withholding payment
of over $3.4 million to the IRS. And that it's simply the
IRS's problem that they didn't record that money. This story
is unbelievable. And you heard how this story constantly
shifted as he testified, constantly shifted when confronted
with what he said in his custodial interview three years ago.
Ladies and gentlemen, the evidence refutes all of it.
Here, as the Judge has described, we have four different
categories of charges. There's the bank fraud scheme, that's
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the scheme against Chase Bank related to the PPP money.
There's two counts of wire fraud, those relate to those two
IRS refunds that were transmitted to the
Internal Revenue Service, each requesting more than $3 million
in a tax refund when the defendant had never paid one dime to
the IRS in tax withholdings.
The concealment money laundering transactions are the
transactions involving certain property where the defendant
was trying to conceal some aspect of his criminal activity.
And then the transactional money laundering counts
relate to specific items that he purchased, such as the house
and the Lamborghini, BMW and Range Rover.
Now, at the beginning of this case, defense counsel
opened by telling you that really everything that the
defendant was doing was open and notorious, that this was not
an issue of him trying to hide anything. That all he did was
submit the paperwork to Chase Bank, and as a result of that
paperwork, they gave him the loan, that it was their problem
if there was anything incorrect.
And then with the Internal Revenue Service, again, it
was I submitted the paperwork, if they gave me the refund,
they gave me the refund.
Ladies and gentlemen, keep in mind that putting
egregious lies on a PPP loan application does not mean that
you are being open and notorious. Putting your egregious lies
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on an IRS tax refund or tax return does not mean that you were
being open and notorious. Instead, it means you have
committed fraud.
And then the defendant used the proceeds of that
fraud to make all of those financial transactions. He
committed money laundering. That's what we've established
this week.
Now, there are a few things that are not in dispute
here. One is that JPMorgan Chase is a federally insured
financial institution. You heard that term a few times over
now related to the jury instructions.
There's another thing that's not in dispute, the
transmissions of the tax returns were wire communications in
interstate commerce.
And the financial transactions involved the use of a
federally insured financial institution, that would include
the other banks, PNC Bank, Bank of America, so those elements
are not in dispute here.
What's also not in dispute is that the defendant
filed the PPP loan application. He has admitted to that. The
PPP loan was issued to Kremkov Industries. His alleged
goldmining company in Ghana.
What is not in dispute is that $9.5 million in
PPP loan proceeds were transferred from Chase Bank into a
Kremkov bank account that the defendant was then able to
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access, because, again, he was the sole signer on that
account.
And it is not in dispute that the IRS refund check
was deposited into another bank account that the defendant
controlled that was in the name of Kremkov Industries.
Now, the Judge just went over what the elements are
for bank fraud, so I'd point out the last element involves the
financial institution being federally insured. So, again,
that's something that's not in dispute. Here, we have
established the other remaining elements of the offense beyond
a reasonable doubt.
You heard how the Small Business Administration and
Chase relied on the applicant's attestations in that PPP loan
application to determine whether or not the loan would be
granted. It was a significant factor for them that the
individual applicant was signing and certifying that they were
providing true and correct information in the loan
application. Chase and SBA witnesses made clear that if that
attestation wasn't there, the certification wasn't there, if
the documents weren't provided, they never would have issued
the loan.
Now, the defendant claimed that his company,
Kremkov Industries, was in operation on December 31st of 2014,
yet, he did not register with the Georgia Secretary of State
until January 4th of 2021, but he wants you to accept that
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this is just a mere I didn't do paperwork before. But again,
you don't have to leave your common sense at the door. If he
was operating a multimillion-dollar goldmine and he truly
believed that this company was a U.S.-based company, it would
have been registered long before.
The defendant also signed that application attesting
to the truth of him answering this question, and saying, yes,
all of the employees of Kremkov Industries were U.S. -- had a
U.S. place of residence.
Now, the defendant's tried to give a good bit of
explanation about that, saying they're all of these
expatriates that work for his mine and he has alleged that
despite the fact that he doesn't do anything with payroll, he
doesn't know all of the identities of all of these
individuals, somehow, he was able to certify confidently that
this specific 493 employees that he listed all had a residence
in the United States, that it was something that he knew that
had to be the case.
But ask yourselves if that seems reasonable in light
of all of the things that he denied knowing about the payroll
and the employees, how he could possibly be confident that any
one of them had a residence in the United States.
And you heard how -- what that huge number was of how
many employees he had. 493, just under the 500 employee cap,
it's almost to the max. And you heard how PPP loans had a
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$10 million cap. So, again, he got very close, indicated his
monthly payroll, monthly payroll was over $3.8 million. And
you saw that -- examples of all of that payroll, you saw both
February 2020 purported payroll and you also saw his yearly
payroll for the entire year of 2020, claiming that in total,
he paid out more than $45.8 million to the 493 employees.
Ladies and gentlemen, you heard Dr. Owusu testify,
typical payment in a mine like the defendant describes $500,
$500 a month, far less than the average of $92,000 that the
defendant claimed in order to get that loan. Because again
remember that the SBA, this was how they were calculating that
amount, it was your monthly payroll times two and a half, so
putting in that $3.8 million meant that he got over
$9.5 million for this loan.
Now, how did he do that? By submitting all of that
payroll documentation that he now has testified that he
didn't -- he didn't know about. He couldn't -- he couldn't
say that it was accurate. He just got it from somebody else,
somebody that he has never mentioned before.
And what he says, and what he even pointed out as
well, is that payroll has those common names that y'all have
heard before: Keanu Reeves, Gene Hackman, Jason Bourne, John
Snow, Bruce Willis, Oliver Twist, Charlie Brown, Karl Delano
and Monica Sweeten.
And every single person on his payroll made the same
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amount of money, everybody's in 92 to 93,000 per year. Ask
yourselves if that seems to make sense to you. Does your
common sense tell you if you had a foreperson, like he
testified, that they may be -- since they're in charge that
they would make more money. How would it be that every single
person makes the same exact amount and every single person
works virtually the exact same hours?
There's no evidence that any of his payroll
documentation was true. And in fact, we showed that it's not.
Again, he keeps shifting his answers. He's got 50 or
60 employees when he talks to Agent Caruana, but yet his PPP
application clearly stated 493. And now you've also heard
that really he had 612 people, and that he was -- he was
discriminant, he only included the people who were -- who had
U.S. as their principal place of residence.
But again, he also said he didn't know anything about
the veracity of this payroll, so how could he attest to that.
There were no employees in the United States, not a
single one. And you heard how the purpose of the PPP program,
it was specifically to help American businesses keep American
employees with a paycheck. The whole idea of this program was
that the COVID-19 pandemic was shutting things down so
companies would not be able to bring in the same revenue that
they normally could. This was a way of saying please go ahead
and pay your employees. We will give you this loan so that
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you have the ability to do that.
And if ultimately you can't pay it back, we will
forgive it, we will guarantee it. The SBA was going to
guarantee it so that you did not to be concerned about being
out of the money, so even if your company possibly shut down
completely, you would likely be able to ask for forgiveness,
if you had actually paid the money to your employees, that was
the whole point of it.
But here, instead, the defendant took advantage of
the program to get $9.5 million based on all of his
representations and all of that documentation that he
supposedly had 493 employees who had a residence in the
United States.
And again, you clearly heard when you listened to the
custodial interview, and, again, if you need to listen to it
again, you will have access to that, but he confirmed there
are no U.S. operations for Kremkov, it was all in Africa. So
ask yourselves how likely is it that then all of his employees
actually have a principal place of residence in the
United States.
And he certified that everything in his application
was true and correct, not just what he wrote on the form, but
also all of the supporting documentation.
But what does the documentation show us?
You heard from the IRS, you heard Mr. Hazel testify.
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He searched not just under the employer identification number
that was on the actual PPP application for Kremkov Industries,
but he also searched the other ones that he could -- that we
were aware of. He searched the other EIN that was in the name
of Kremkov and he even searched by the EIN that was solely in
the defendant's name, and he could not find a record of a
single tax filing identified.
There were no 941 quarterly tax returns saying this
is the withholding amount that we are paying to our employees.
There were no 941s being filed. That's the federal
unemployment tax. And more specifically, there were no
withholdings related to Kremkov Industries or for the
defendant at all for either one of his Social Security
numbers, nothing in IRS's system. And yet all of those pages
of payroll over and over and over again claimed that the
employees had all of those tax deductions. And also that they
had the Social Security and Medicare tax deductions.
But you heard on day one from Agent Fowler, he
explained Social Security had no record of any of that, had
never received anything in Social Security or Medicare.
And when the defendant took the stand yesterday, what
he told you was that these were all guesses, that it was -- we
haven't actually filled out these paper -- this paperwork, it
wasn't actually sent to the IRS, it wasn't sent to anyone, and
we were just guessing at how much we would file for these
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individuals in withholdings.
And that he was relying on their accountant, this
Andrea Lewis to figure all of that out. And she was the one
who prepared all of those 941s and 940s that he clearly knew
were not based on accurate information.
And that he clearly knew had never been submitted to
IRS. And you heard from SBA and from Chase that that was a
requirement. The tax documents had to actually be submitted
to the IRS, so he admitted that that was not possible, they
had not done that. And that all of these forms just have
guesses on them.
But you know what they also have, they have
information that would say he paid $45.8 million in payroll
and that he was averaging 3.8 million. So the idea that this
is just Ms. Andrea Lewis somehow coming up with these figures
is just not plausible.
And what was even more surprising is that he's the
one who said I figured it out. I figured out that we didn't
need to pay these tax withholdings. So while he wants to say
I relied on Andrea Lewis for everything, for all of my
accounting activities, yet he's going behind her and
researching and finding out if they actually need to do tax
withholdings, and he realized they didn't, so they just didn't
submit the forms.
But ask yourselves is that likely what happened here?
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Or is it that because the defendant knew from the PPP
application itself that payroll documentation was required and
payroll tax documentation was required, that that's the reason
for all of that documentation. It's not somebody else, and
again, even if there is an Andrea Lewis, not one dime of this
money went to her, not one penny. And you also won't find her
on that payroll. She's his accountant. You assume he's
paying her. She's definitely nowhere even on that. He's told
a convenient story over and over and over again, trying to
weave around the facts, facts that show he is the one who was
submitting this information, that he was the one providing all
of these false statements to the bank.
Now, we talked some about Monica Sweeten. That was
one of the names on the payroll. And you heard from
Ms. Sweeten, when she came in and testified.
And then you also heard yesterday from Tom Thurmond,
who came in and said I researched the name Monica Sweeten, and
I could only find six people with the name Monica Sweeten.
And he was asked, well, do you know if the person
who's on the payroll is, you know, that particular Monica
Sweeten who came in and testified.
Ladies and gentlemen, it is simply unbelievable that
with billions of people in the world, when there are only six
Monica Sweetens, that there is no way that the name on that
payroll was not reflecting the one -- the Monica Sweeten that
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the defendant knows, that he personally knows, who had been a
pilot with him, it defies logic. Six people is not very many.
From day one, the defendant intended to defraud
Chase Bank out of $9.5 million. He got that money into his
bank account on March 29th. And after he gets that money, he
starts to spend it.
You've heard about some of the transactions that he
did immediately after getting this money. You heard how March
29th, this money goes into that bank account and by April 5th
of 2020, he's consulting with that plastic surgeon.
And you heard about how on April 21st, 2021, before
the IRS check is even issued, that check is dated April 23rd,
before it's even issued, he goes under contract for a
$1.6 million house. And you saw what is the one and only
document that he provided to establish that he could do an all
cash sale for that $1.6 million house, it was this, it was the
bank statement showing the $9.5 million PPP loan money.
Now, he's testified I didn't use any PPP money for
anything other than Kremkov Industries. Ladies and gentlemen,
that's simply unbelievable, even by his own transactions, he
is using the PPP money. If not for that money, he would not
have been able to get under a binding contract for that house
on April 21st.
And what did he do after he got this money?
Ms. Lewis came in -- or, I'm sorry, Ms. Richardson came in and
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talked to y'all about how he is transferring over money,
transfers $3 million out of this account by issuing a check,
then he's sending money to another account. And from there,
in one month's time, he's paying off all of his debt, got a
clean slate, off of the PPP money. She was clear, there was
not sufficient funds in any of his accounts that could have
covered those immediate expenditures that he had.
He paid off his auto loan, he paid off multiple
credit cards, it's PPP money, there's no doubt about it, the
records don't lie.
And after he even goes into this cash sale on the
house, you see that he is then purchasing luxury cars, going
on essentially a spending spree.
The motive here was greed. This was not I'm getting
this loan so that I can go ahead and pay my employees' payroll
when they are suffering due to the pandemic.
And ask yourselves as well why would he even need the
Payroll Protection Program loan? He testified yesterday
Michael Lee is who paid every single employee by wire
transfer. So why did he -- why would he need a loan anyway?
Michael Lee is the one who takes care of that. If
anybody was going to get a PPP loan in Kremkov's name, it
should have been Michael Lee, that's his responsibility.
But yet here, it's the defendant who files that loan
application and it's the defendant who receives and then
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starts spending the $9.5 million.
And he's not mistaken about the rules. He testified
today he clearly knew this application was based on the
payroll. That's not what he told Agent Caruana. He tried to
explain it as, no, my loan wasn't based on payroll, mine was
based on earnings. But he admitted there's not one earning
statement that was provided for that loan, it's all payroll,
and it's all payroll documentation that has no veracity.
Now, Chase issued the loan after receiving that
signed application from the defendant with all of the
supporting documentation. And also remember that he actually
had that prior application for a PPP loan, about a week
earlier. Ms. Carpenter explained that that one was denied by
the bank because they wanted more documentation.
So then on February 16th, he provided that. And
after he provided it, it meant that his Chase could go through
and verify, okay, he's got the payroll, he's got the tax
documents, it gets transmitted to the SBA. And the SBA had
already approved that loan by just a few days later, around
February 19th.
But by early May, Chase had become suspicious of this
loan, it's a very large loan, again, it's almost at the
maximum. So Ms. Carpenter said they ended up freezing the
account. He had already moved $3 million out of it, but they
froze the rest of the funds.
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And you heard the defendant calling Chase and trying
to get information about having the account unfrozen. And you
heard that representative from Chase give him specific
instructions. She told him you need to provide more
documentation to establish you were in business as of February
15, 2020, a clear sign that Chase wanted more, that they were
not -- no longer accepting strictly the information he
provided in his application.
And he mentions at the end, he says, well, I've got
multiple EINs. And the representative almost immediately cuts
him off, it has to be in the name of your company, it has to
be in the name of the company who got the loan.
So then what happens? You end up with that May 7,
2021 letter from the IRS. And ladies and gentlemen, on that
letter, it said -- it was addressed to Kremkov Industries,
Carl Delano Torjagbo, sole member. You heard from the IRS
that that -- a record of this EIN ever having that address and
that name associated with it doesn't exist, no record of it.
That EIN issued in 2018, so Mr. Torjagbo knows at
this point, by May 7th of 2021, that Chase is telling him that
if you're going to provide an EIN letter, it's got to be that
it shows that that company had been -- had that EIN issued
before February 15th of 2020. And the only two that he had in
the name of Kremkov Industries were not issued until January
of 2021.
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So what happens? You end up with the address that is
only consistent with the EIN ending in 8332. The other EINs
don't have anything else on them. And I'll remind you the
issue here, in part, was that the 1377 EIN that was issued in
September of 2018, he had misspelled the address, said
Leatherly Trail instead of Leatherleaf Trail.
And IRS was specific that the only -- the next time
there was ever a change in that address was not until June of
2021, after the PPP loan and after the IRS tax money have
already been obtained.
So the defendant testified that it had to be that
what happened was that the U.S. Post Office corrected the
address for him. For that to be possible, the U.S. Post
Office would have to open a letter issued from the IRS,
somehow retype the letter, create the name Kremkov Industries,
because again, 1377 doesn't have Kremkov Industries on it. So
somehow a postal worker is able to just come up with that
name, and change the address so that this EIN letter could be
given to Chase Bank, because by this point, that account is
frozen, and the defendant wants to be able to get access to
the money.
Ladies and gentlemen, it just simply makes no sense.
The defendant was willing to do whatever he had to do to get
his hands on that $9.5 million. But Chase Bank, after
receiving this letter -- so even though Chase Bank doesn't
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know what's in IRS's system, they don't know if this letter
has been forged in any way, they still don't give him the
money back. And instead, they clawback the remaining balance
in the account. Chase had realized that they had been
defrauded. The defendant's PPP application was entirely
false. And the bank did what it needed to do to try to get
that money back. Because remember, the way that these loans
worked is the bank would go ahead and fund the loan. SBA
guaranteed the loan, but the money would go directly from the
bank.
Ladies and gentlemen, the defendant cannot possibly
have a good-faith belief in false information. He cannot
believe that he was in operation on February 15th, 2020, that
all of his employees had a principal place of residence in the
United States. And based on his falsehoods he had no way that
the loan proceeds would be used for business operations.
There were no business operations at Kremkov Industries.
Now, in regards to the two different tax returns that
were filed, Counts Two and Three, those are both charged under
wire fraud. So again, the last element of this has already
been stipulated to, there are interstate wire communications.
Now, the defendant interestingly has said he did file
one of the tax returns, the one in Count Two, but he has
claimed that he did not file the one in Count Three.
The one in Count Three is the one that he says Andrea
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Lewis without his knowledge goes to his house, logs in on his
TurboTax account and files a tax return because she had to
have accessed a file on his computer that had old identity
information on it.
But ladies and gentlemen, remember the testimony of
TurboTax. They talked about how there were multiple rejected
tax filings. And what happened is that the Social Security
number ending in 6010 was the earliest return, the first one,
and it gets rejected after it was filed -- attempted on
February 6th.
But also on February 6th, there was this submission
attempt under the other Social Security number, 0540. And you
heard how the error message for both of those returns was that
the EIN on the W-2 was a mismatch essentially. That it was an
impossibility that you could have a W-2 from 2020 that had an
EIN on it that was not issued until 2021, so they get
rejected.
And so what happens next? Another attempt. Another
attempt using another EIN. This one also doesn't go through,
because he's still using one of the EINs for Kremkov that's
issued in 2021.
And why is he using those two EINs to try to do these
tax returns? Because he knows those two EINs actually have
Kremkov Industries associated with them.
But when those two fail, the third time is the charm.
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And he goes back and he is first able to go under that earlier
Social Security number, 6010, and he tries it with the 1377
EIN number, the one issued in 2018, that's not in the name of
Kremkov Industries, it's instead just in the name of Carl D.
Torjagbo. And when that one ends up going through, it's
ah-ha, found the right one. So the next morning, he submits
the tax return under 0540, so both of those end up going to
the IRS.
He now knows 1377, that EIN issued in 2018, is the
magic number. And that's precisely why when May 7th of 2021
rolls around, he knows that's the one he's got to use if he
wants to try to tell Chase Bank that he was actually in
operation before February 15th of 2020. Shifting information,
whatever works, whatever works to get millions of dollars.
Ladies and gentlemen, I'll remind you he never paid a
dime to Social Security, not in 2020, not under either one of
the Social Security numbers.
And yet what he wants you to believe is that he told
Michael Lee pay my tax withholdings sometime in 2021, early
2021. Ladies and gentlemen, that simply doesn't make sense.
When you go to file a tax return at the end of the year, you
put in what your earnings are, you put in any withholdings
that you have, and if you have losses from a company, you put
in your losses, that's how it works. At the end, then your
return is going to say either the IRS owes you money or you
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owe the IRS money.
So why would you need someone to pay withholdings?
What you would do is just say, okay, what I have is earnings
and what I have are losses. I don't need to invent that I
withheld -- any federal taxes were withheld from my pay during
the year. You could just put in the number of your earnings
and you could put in the number of your loss.
But if the defendant had done that, he would have
ended up with zero. Because you heard Mr. Hazel talk about
how the way that this refund got issued is because he's
claimed those withholdings.
What happened is that his earnings that he claimed
were about $9.1 million were completely offset by the losses
he claimed of $9.9 million, so essentially, he had negative
$800,000-ish. You have negative income, you wouldn't have any
tax liability. So there would be zero reason for you to say
let me have someone send $3.4 million to the IRS so that I
can, in exchange, get a $3.3 million tax refund. But that's
what the defendant did, he claims. Use your common sense, it
simply defies logic.
But you heard how the IRS treats tax returns on an
honor system. Taxpayers are supposed to fill out the form and
send it in. It's supposed to have accurate information. And
when the defendant claimed that he had this monster amount of
withholdings, they issued a refund check, giving him the
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benefit of the doubt.
His lies created that refund, that information was
material to the Internal Revenue Service, they were relying on
him providing truthful information when he filled out that tax
return, and he simply did not.
They made clear they could not find any W-2 on file
for him. And keep in mind there's really no earnings here for
Kremkov Industries. There's no losses. Nothing has been
shown to you that would suggest that that would be accurate,
to report $9.1 million in earnings from that company and
9.9 million in losses.
But it didn't stop there. Under that 6010
Social Security number, the defendant also attempted to get
another $3 million. In this tax return, it said full year
resident of Texas. He uses that earlier Social Security
number that we kept hearing so much about.
And Mr. Torjagbo -- or, I'm sorry -- Mr. Delano wants
you to believe that Andrea Lewis came into his house and filed
that return. And that he wasn't there to tell her she was
looking at the wrong information. But she is literally at his
house in Douglasville, Georgia. Why would she think that he
had been a full year resident of Texas. Even if she saw an
old driver's license, wouldn't she have listed his current
address?
There would be no reason to say that I'm going to see
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this old driver's license from 20 years ago and use that
address instead of the address that I am sitting at currently
to file that return. But he wants you to believe that that is
what she did.
It's another convenient story to explain away the
facts here. Because you heard that TurboTax recorded the IP
address login for every single one of those rejected tax
returns as well as the accepted ones. And all of those IP
addresses are the same. He explained that's going to be the
Internet Protocol address tied to where you are when those
returns are being filed. He's coming up with a story to try
to make sense of why he would be able to say somebody else
somehow was able to go into his house and file those returns.
Even if you believe that Andrea Lewis really did
that, keep in mind that Mr. Delano's testimony is that what
she did, because he was not there, she used all of the
information that he keeps on his computer related to
Kremkov Industries.
But what information would be on his computer that
would say he had millions of dollars in tax withholdings that
weren't actually paid?
What on his computer would have that he was making
$9 million a year with Kremkov Industries?
What would be on there to establish that he had
losses?
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And even if he had that information on there, how
would it be that those two tax returns reflect slightly
different numbers?
If she's using the information on his computer, then
they should have been the same. There would be no reason for
them to be different. The defendant had no withholdings under
that Social Secure number either.
After he got $9.5 million from Chase and after he got
$3.3 million in a tax refund that wasn't owed to him, he
started moving the money.
I apologize, I'll back up for a second. Actually, I
already went over that. Sorry.
Concealment money laundering, what this is really
referring to, you're talking about the financial transaction
in some way being designed to conceal an aspect of criminal
activity, specifically nature, source, ownership, location and
control of criminal proceeds.
So what did we see with Mr. Delano?
He takes the money out of the Chase Bank account from
the PPP loan. We saw, and what Count Four alleges, is that he
had that $3 million check, $3 million check that he just wrote
off of the Chase Bank account that got the $9.5 million
deposit. And he takes that check and he writes payroll on it.
Ladies and gentlemen, his story is that he doesn't
have to do the payroll. Michael Lee does it. He sends wire
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transfers to everybody. Payroll was on that check for the
purpose of having some memo line on it that would indicate it
was an expenditure consistent with the Paycheck Protection
Program. It was so that he could get those funds out of the
account and ultimately buy his house and get his plastic
surgery and buy his cars.
Because if he had done any of those or attempted to
do them directly from that Chase Bank account, Chase would
have caught on quickly, and he never would have been able to
get millions of dollars from that PPP loan.
He moves that money over to another bank account in
the name of Kremkov Industries at PNC, an account he had just
opened up the same time as the Chase account opened up. And
you heard about how he starts to spend that money, what we've
already described. He's paying off debt, he's going under
contract on his house, he knew he was hiding what the purpose
of that transaction was. There is no legitimate business
reason that he would have had to move this money from one
Kremkov bank account to another Kremkov bank account.
He was removing that money from the PPP bank so that
then the next transaction down the line didn't have to reflect
something about the Payroll Protection Program.
And after he ends up commingling all of that IRS
money into the same Kremkov account, we heard about a huge
$6 million transfer into a PNC Bank account that's solely in
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his name, just a personal account.
But again since he's distanced himself from the
PPP loan and now he's even distancing himself from the IRS
check. And as we pointed out, the IRS check was in his name
to begin with. He didn't have to put it into a Kremkov bank
account. He could have just put it in his personal account to
begin with. But instead he puts it into the Kremkov account
and then he moves that $6 million of commingled funds over to
a personal account, distancing himself from transactions,
distancing himself from the fraud proceeds.
After he does that $6 million transfer, the account
has got $6,007,300 and some change. And from there, he's
spending it.
And Ms. Richardson went through all of these
financial transactions. Count Five relates to the -- it's a
Fiber Drive Tract 4 property. Now, this property is land,
open land. And you have the money coming out of that personal
PNC account that had already had the big $6 million transfer
to ultimately send this $91,000 wire. And he titles this
property in the name Karl Delano, distancing himself from
Carl Torjagbo that he got the IRS money in the name of,
distancing himself from the name that he got the PPP loan on.
He's disguising the true nature and source of these funds.
We are very far downstream at this point, far from
that initial account that got the PPP money, far from the
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initial account that got the IRS money.
And while the defendant wants to try to parse out
that somehow he only did these transactions, certain
transactions with IRS money compared to PPP money, that's not
what happened. He commingles that money and transferred it
on. It would be impossible, Mr. Richardson talked about that,
impossible to then say this is a dollar of PPP money, this is
a dollar of IRS money. But even if you could, it doesn't
matter, because the defendant defrauded Chase Bank to get
those PPP funds and he defrauded the IRS to get that
$3.3 million refund check. It's all proceeds of criminal
activity.
Count Six relates to another piece of land. Now,
this one is even further downstream. Because now he has
opened FlyingJack Freight and Logistics, registered the
company in Wyoming, not in Georgia, where it's based. And he
has opened a Bank of America account. He has a long-standing
financial relationship with PNC, but when he decides to open
this company, he goes to a different bank. And he ends up
purchasing a property and sending over that wire of $150,000.
Again, ladies and gentlemen, this is all flowing down after
he's already got all of that fraud money.
And now he's got a property and a business that are
not the same business he got the PPP loan in and it's not the
same business that he claimed he was earning money from in
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2020 to get a tax refund. He is disguising what the true
source of this fund -- this money is, what the nature of the
funds are.
Now, transaction money laundering doesn't have that
concealment requirement, it's kind of one of the major
differences. All of the transactions have to be over $10,000.
Ladies and gentlemen, we saw transactions well over
$10,000. We heard about 5114 Greythorne Lane. And you heard
Kobina Oppong, his friend, 38 years, testify he'd been in that
house, 10,000 square feet, enormous property.
And you heard Mr. Oppong talk about how he had been
showing the defendant houses, because he was a realtor months
before PPP loan money comes in. And when he's showing him
houses, he's only looking at the range of $500,000 for the
purchase price. But now, months later, he doesn't use his
good friend, the realtor to buy this house, and he's all of a
sudden up to $1.6 million.
Mr. Oppong, you heard, questioned him when he learned
he had got a $9.5 million PPP loan. He probably would have
questioned him if he jumped from $500,000 for a purchase price
of a house to suddenly $1.6 million.
He doesn't buy this house until he gets the PPP
money. And as I've talked about before, he goes under
contract immediately. And he's using that Chase statement to
justify that he has the money, he has the liquidity to do an
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all cash sale. He doesn't show a foreign bank account with
some balance in it, he doesn't show anything else, it's
strictly that PPP money.
That was his justification for how he would be able
to afford this 10,000 square foot house. This property was
purchased with the fraud proceeds. By the time the 1.6 wire
and the actual closing happens on the house, he's already
gotten that IRS check money, he's been able to funnel that
money up to another bank account, the $6 million transfer.
It's a combination, you wouldn't be able to tell what dollar
was PPP and what dollar was IRS money, but again, even if you
could, it wouldn't matter, because that money was obtained
based on his false representations to Chase and to the IRS.
You also heard about the purchase of this
Range Rover, wire transfer, August of 2021, buying this
vehicle, coming directly out of the count that got that
$6 million transfer, using proceeds of the PPP fraud and the
IRS fraud, the wire fraud to buy this vehicle.
And it doesn't stop there. He buys another vehicle.
A 2022 BMW, paying $120,000 total for that vehicle. And in
January of 2022, when he buys that car, he has funneled the
money all the way from that $6 million down into FlyingJack's
bank account, not the company he got the PPP money in, not the
company he was trying to claim was anything to do with his IRS
check, using proceeds of the offense. But he wants to say I
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didn't use any PPP money for the cars, but all of this came
together.
And Count Ten, the final count in the indictment is
for the $332,000 Lamborghini. Again, where he has funneled
all of this money into the Bank of America account for
FlyingJack. And when he buys that vehicle, you've heard
Adrienne Richardson testify and you saw the bank statement
that showed he put equipment purchase for it. He put
equipment purchase because he's using PPP fraud money and he's
using IRS fraud money to purchase that car. There's no other
source of funds coming into those accounts that would be able
to pay for this vehicle. And Ms. Richardson made that clear
during her testimony over and over again.
Ladies and gentlemen, Karl Delano's fraud was
extraordinary. And his convenient story to explain everything
away is simply absurd. There's no Michael Lee who is
investing millions of dollars in his goldmine. There's no
Andrea Lewis who surreptitiously entered his house and filed a
tax return for him based on old information and a long expired
Texas driver's license. He doesn't have a mine in Ghana where
he's paying 493 employees who have a principal place of
residence in the United States. He never paid $3.8 million in
payroll to anyone. And he certainly never paid $45.8 million
in 2020 for payroll.
From day one, he intended to defraud Chase Bank and
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the Internal Revenue Service out of millions of dollars. His
actions immediately after getting those funds speak volumes.
Buying those luxury items, buying that huge house, getting the
plastic surgery, paying off debt, buying a Lamborghini, buying
a yacht. The evidence overwhelmingly shows that Mr. Delano is
guilty of all counts beyond a reasonable doubt.
As the Court -- or the Judge advised you, after
hearing from the defendant, I'll come back up and briefly
speak to you. Thank you.
THE COURT: Okay. Anybody need to stand up, stretch
a little bit? Okay. Let's take just a very quick five-minute
break. I'm not even getting up. All right?
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Y'all can be seated.
MR. FINLAYSON: Bathroom break?
THE COURT: Yes.
MR. FINLAYSON: Okay.
(Whereupon, a recess was taken.)
THE COURT: All right. Y'all ready?
MR. FINLAYSON: Yes, sir.
THE COURT: One thing I wanted to mention in reading
the instructions, two things, one is it repeatedly refers to
the prosecuting entity as the government, which I think is
weird, it ought to say the United States. I think there's a
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difference between the government that is the body that leads
and the entity that is prosecuting the case, which is the
United States. It's the United States Attorney who is
bringing the charges on behalf of the United States, and
that's why it says in the caption the United States.
I read it as the United States except for twice, I
think I accidentally said government, but it's weird, and I
think y'all should think about the way you do that in the
future.
It doesn't make a difference to many people, maybe
I'm just a stickler for it, but I don't think it's the, quote,
government, that is the party. I think it's the
United States.
And secondly, there seems to be in the instructions
inconsistency in referring to the defendant as a capital d and
a defendant as a capital D. I noticed that. That's
y'all's -- the way you-all gave it to me. But sometimes it
uses lower case D referring to a generic defendant and capital
defendant referring to this defendant and sometimes it uses a
capital D referring to a generic defendant. Again, maybe I'm
just being picky, but it is the way it is, it's the way
you-all gave it to me. There were no objections to it. So I
don't think it's going to confuse the jury in any way, but
that's just something you might want to think about. Maybe
you're not as --
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MR. FINLAYSON: And no ending sentences with a
preposition.
THE COURT: Well, that's just --
MR. FINLAYSON: Good grammar.
THE COURT: -- civility --
MR. FINLAYSON: Yes, sir.
THE COURT: -- being part of a civilized nation, I
think.
All right. Bring them in.
And don't get me started on passive voice. There is
so much passive voice in those instructions. That might keep
me up tonight. That's for all of you law students out there.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. You may be seated.
Mr. Finlayson, go ahead.
MR. FINLAYSON: Thank you, sir.
May it please the Court, counsel, members of the
jury, I want to thank you for your time this week. It's been
a long week, but we've gotten through it. And this is the
final closing arguments. And this is the last I get to speak
to you. They'll get to come back and speak again, but this is
it, this is all I can say to you. And I'm going to put
Mr. Delano in your hands when I'm done.
And again, you the jury are that last bastion between
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tyranny and justice. So I appreciate what you're doing here
and I appreciate the attention you have paid, I appreciate you
taking notes, I appreciate you doing your job, and holding the
government to its job.
And what is that job? What is the government's job?
The job is to prove their case beyond a reasonable
doubt. We've been here all week, we've gotten piles and piles
of documents, we've heard witnesses, but have they really
proved their case to you beyond a reasonable doubt?
And what is it they had to prove? Because a lot of
these things -- she's right, a lot of these things aren't in
dispute. Mr. Delano filed a PPP loan, Mr. Delano filed a tax
return, Mr. Delano bought things.
What they have to prove is what was his intent. Did
he intend to defraud the PPP program? Did he intend to
defraud the IRS? Did he intend to launder money? Was he
concealing anything in this case? Did he conceal anything?
And I submit they have failed miserably to show that intent to
do those things.
Judge Brown read the law to you and you're going to
have a copy of it and I ask you to look very carefully at
Page 19 when you get back there. Because Page 19 tells you
about good faith. And it will tell you that good faith is a
complete defense to a charge that requires intent to defraud.
And this is the important part, a defendant isn't
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required to prove good faith. The government has got to prove
the intent to defraud beyond a reasonable doubt, an honestly
held opinion or an honestly formed belief cannot be fraudulent
intent, even if the opinion or belief is mistaken.
Charlie Brown, Keanu Reeves, if those -- if that was -- if
that was mistaken, an honestly formed belief, even if mistaken
cannot show fraudulent intent.
Similarly evidence of a mistake in judgment, an error
in management or carelessness can't establish fraudulent
intent. And that's really what this case is about. And
that's really what our defense is about is have they proved
beyond a reasonable doubt that Mr. Delano had fraudulent
intent.
If you think about it, we've got all of these records
up here and we've heard all of these witnesses.
Do you know what we haven't heard? Anybody that
actually was there in realtime with real knowledge of what
Mr. Delano was up to. I mean, I'll caveat -- there's a couple
of people I'm going to talk about, but you think about all
these experts -- all these agents and financial analysts,
they're people that come in, they look at these records, they
tell you a story what they think those records show, but it's
just their story of what they think these records show.
They weren't there. There's no coconspirators,
there's nobody on the ground, you know, it's not one of those
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cases where somebody's -- you know, somebody comes in and says
oh, yeah, we were there, we planned it. He told me that's
what we were doing, there was a fake mine, blah, blah, blah.
I mean, we did have Mr. Oppong, the so-called good
friend comes in and says, yeah, I went to his house and he
went around my back, he bought a big fancy house without me,
he seems kind of grumpy. He bought this house and I told him
he needed a website. He had this company with all this
PPP loan, he should get a website.
Mr. Delano says I don't need a website, it's a
goldmine. I'm not buying your website. Now, somebody like
that, he's actually a little bit close, but, you know, I asked
Mr. Oppong, I said, Did he tell you, oh, yeah, I've got a fake
goldmine? Absolutely not. He didn't say anything close to
that.
And you would think if he had a fake goldmine, which
is what their theory is, if he had that ill intent, that's the
first thing you would do is -- you wouldn't say, yeah, that's
a good idea, I need to build a website. No, he absolutely
refuses. He doesn't build a website. He's not covering up
anything. He's not concealing anything. He didn't -- he
didn't -- he didn't fall for it. Mr. Oppong wanted to get a
piece of the pie, maybe. Oppong wanted his buddy to get a
gig, a job with a website. Mr. Delano says, no, I'm not doing
it. I don't need to do it. I'm not covering something up.
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So how -- how is the government trying to show ill
intent? Well, let start with the name. And, my God, how much
have we heard about he changed his name, changed the name
somehow to cover his tracks, to hide the money, to conceal the
evidence, to move it from A to B to C to D to Z, that's the
theory. That's -- that's how they want to prove bad faith,
that's how they want to prove ill intent.
Well, what's the name we're doing -- we're talking
about? Carl Delano Akpene Kwdzo Torjagbo is what he was born
with. He comes in this country already shortened, I guess
that was a scheme, a crime. My God, you're an immigrant
coming to America. This country used to welcome immigrants.
And people used to change their names, Anglicized names, it
was tradition. How many Italians, how many Eastern Europeans,
how many people even from Africa came to this country and
changed their name to fit in?
He's already changed it, he's already -- according to
the government, he's already a scammer. He's already lying.
That's what we heard on the cross-examination. You lied when
you got that Social Security card with a different date of
birth, you lied. My God, it's the Social Security
Administration, passports from Ghana. Those are -- that's the
word of the Lord, those are perfect entities that don't make
mistakes? Use your common sense, she says.
What's your common sense when you're dealing with the
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Social Security Administration?
What's your common sense when you're dealing with the
IRS?
Are those perfect institutions?
What's your common sense when you dealing with -- I'm
sorry, but, I mean, your own bank. Your common sense with all
three of those institutions tells you they all make mistakes,
every single one of those.
The IRS is so underfunded, it's ridiculous. You
think they're perfect? The government wants you to believe
that every one of those records and every one of their
interpretations of those records is the word of the Lord, it's
perfect, that it's right. That's what they want you to
believe, that they don't make mistakes. And we'll talk about
some of those mistakes.
Car Delano to -- Karl Lucius Delano, that's -- that's
one of their first pieces of ill intent. That shows he's a
scammer, he's a schemer, he stole this money. He hid this
money. He changed his name from Carl Delano Torjagbo to Karl
Lucius Delano. That's bad criminal 101. I'm sorry. If
that's your scheme to hide the money, if that's your scheme to
default and run away from the government, pick a better name.
It's the same name. He changed his name to his name. That is
not concealing anything. That is not defrauding anybody.
And this idea that the Social Security cards when he
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was 17 years old, and then again, I think he was about 23,
that he somehow did that to set this up 20 years later, that
does not fly. That's not reasonable. And that's not common
sense. Nobody does that.
And that's -- that's their theory. It's like you
lied, you lied, you lied. Social Security, IRS, banks, not
one of those institutions is without mistake, not one of them,
and we all know that from our own experience in life.
The timing of the name change, they've made a big
deal of that. Ah-ha, he gets the PPP loan, and then he
changes his name to Karl Delano, Karl with a K, I guess, yeah,
that -- Karl with a K, that's going to -- that's going to
throw them off, all right. He changes his name right after he
gets that PPP loan.
But you've got evidence, you've got photographs from
Instagram, because, you know, it doesn't -- if it's on
Instagram, it must be real. It's on Instagram from 2015
showing him using the name Karl Delano. It happened years
ago. There was no name change in this case to somehow hide
the money or conceal the assets or commit a fraud, there just
wasn't, there it's bigger.
This, as I said, is a case about intent. And what
was Mr. Delano's intent. And when we really start talking
about the notion of intent, it's very western. You have
action and you have intent, but really when you boil it down,
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it's how do we know what's in someone's heart?
How do we know what was in Karl's heart when he was
going through these things?
Well, as I mentioned, all these records, you get five
different people to argue and interpret them five different
ways. None of these people were actually there.
And you think about that, Kelli Carpenter, the lady,
only lady here from Chase Bank, Chase Bank is the victim,
right, they issue a $9.5 million loan, they pull back
$6 million of it, at least 6.5 they pulled out, at least
$3 million goes out the door.
They're the victim. Now, of course we heard that
that loan is then backed up 100 percent by the United States
government, so they really didn't lose anything. And they
actually got approximately a 1 percent fee -- they got paid,
Chase Bank got paid. You heard it. They don't do this for
free. Chase Bank got paid a percentage of $9.5 million, they
got paid.
But Kelli Carpenter, she comes in from the bank, does
she know Mr. Delano? Nope.
Did she ever meet with him? Nope.
Did she ever talk to him on the phone? Nope.
Did she approve -- you know, she talks about all
these documents. Oh, we would rely on this and we would rely
on that and we would rely on this.
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Did she rely on it? No.
She didn't approve the loan. You heard her. I said,
Ma'am, were you the person that actually approved this loan
for Chase Bank $9.5 million?
No, it wasn't me.
I said, Who was it?
And I'm going to mess up the pronunciation, I'm sure,
but she gave the me the name Louis Glauser. And I apologize
to Mr. Glauser, whoever he may be if I've said that wrong, but
some guy name Louis something, Glauser is what I -- how I got
it down. He approved the loan for Chase Bank. She didn't.
And did the government bring you one person from
Chase Bank who in realtime looked at Mr. Delano's application
and said, well, I'm going to rely on this or I'm looking at
that or I don't care about this or because he signed here and
certified, that's why I approved $9.5 million. The government
didn't bring you that person. They brought you a lady who
testified very nicely about all kinds of stuff, but it wasn't
her.
Her name, Kelli Carpenter, who testified on the -- I
guess the first day of testimony from Chase Bank, she's like a
muckety-muck vice president lady. She testifies really pretty
in court. But she is not the lady that authorized the loan.
So she can say, well, normally, we would do this or
perhaps we would do that and we like to rely on such and such.
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The person that actually relied on such and such, on anything,
he ain't here. They did not bring that man to court. They
didn't have him testify. The person that actually approved
that loan, we don't know what they considered. We don't know
why they considered it. All we know is somebody decided to
issue $9.5 million.
Now, we've been hearing about materiality. And
you're going to have the law on that. And the notion here or
the notion is that if false statements are made, the
government's got to prove, first of all, that they're false,
and they've got to prove that they were material. And we've
been hearing all about this list of 493 names and you have to
decide was that some kind of material falsehood made by
Mr. Delano to get something -- that Louis, whoever he was,
somehow relied upon to issue that loan.
And if you think about it, it sounds like the banks
weren't relying on the underlying documents at all. Because
if you think about it, the SBA lady said, well, you know,
we -- we -- the banks do have a due diligence requirement, but
then they really are just -- they're basing a lot of their due
diligence on the certification on the application that, hey,
it's all true. So if that's all that matters, is that, hey,
you signed at the bottom and it's all true, but you don't
actually go look at the paperwork to see what you're saying is
all true, the paperwork in theory, then, would be irrelevant.
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It's not material in any way or form. If they ain't going to
look at it, how is it material? And did they look at it? Did
they look at that paperwork that went in?
And it sounds like they weren't very curious, because
if they were curious, they might have asked questions. If
they were curious, they might have asked questions like does
Charlie Brown really work in the mines at Kremkov.
If they were curious, they might have asked questions
like, hey, does James Brown work there? Maybe they're young,
too, maybe they didn't pick up -- maybe Louis was too young to
know about James Brown, but he probably knew about
Keanu Reeves or Bruce Willis. Was he curious to ask about
John Snow? I'll bet Louis knew about John Snow. Was he
curious to ask about Gene Hackman? If the bank was curious,
they would have read the documents. If the documents were
material to their decision, they would have seen these names
and said, hey, wait a minute, we ain't giving you that money.
The documents were not material, obviously. You don't give
$9.5 million for Charlie Brown or James Brown or Keanu Reeves
or Bruce Willis, you just don't do it. That is not common
sense.
You know darn well that that bank did not read those
documents. You know they didn't rely on those documents,
Louis, whoever he was. They got paid. The money went out.
All right. We did have some -- we got some
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witnesses, as I mentioned, there were some witnesses that were
kind of close in time, they -- I mean, hey, if Monica Sweeten
had come in here and said, oh, yeah, I know Karl. He's
crooked as can be. And, yeah, he told me he had a mine and he
told me it was all, BS, you know, if Monica Sweeten had told
us something like that, that -- they would have overcome their
burden. We wouldn't be here. They would have overcome their
burden.
What did Monica Sweeten tell you? She said I'm a
pilot. I met Karl in pilot school. We trained together in
simulators. I was trying to buy a house, we are friends, I
reached out to him, he helped me. I'll bet you thought when
that lady hit the stand she was going to say, oh, he ripped me
off, he's a fraudster, he scammed me.
No. He didn't rip her off. That lady gets on the
stand and she says he helped me. I'm trying to buy a house,
and I have this cash that me and my mother have in Texas, and
the bank would not take the cash directly from me, they didn't
want -- the Realtor didn't want to close in cash. I called my
friend, Karl, he helped me out, he deposited that money into
his account, and then wired the money from his account to help
me at the bank.
Monica Sweeten was not a victim, she was not
defrauded. If anything, she cuts absolutely the other way.
You know if she had been ripped off in some way by Karl, they
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would have told you, and she was not.
She came in here and she said nope, he was a friend,
he helped me buy my house. It was her money, not his money,
not PPP money, not tax return money, her own money.
Her name shows up on the list of names that worked at
Kremkov. And again, I submit to you that that list is not
material in any way, because we all know the bank did not read
it or rely upon it.
But her -- there is a name, Monica Sweeten, no date
of birth, no Social Security number, no middle name. My
investigator found at least six other people by that name.
Does that prove a whole lot? It really doesn't prove anything
a whole lot either way. It doesn't prove that Karl had ill
intent or bad faith. It doesn't prove that he was, you know,
presenting false documents knowingly and intentionally to a
bank, because her name happened -- that name happens to be on
that list.
And it's -- beyond that, there's not really a whole
lot to it except that it shows Karl is not a shyster, Karl is
not defrauding this lady. If he's the person they were trying
to say he is, some lady comes from Texas with a bag of $40,000
in cash, wouldn't he take it? I mean, if he was that person
that they're trying to say that he was. But he didn't.
Who else did we actually hear about that knew
something? We talked about Mr. Oppong. A couple of things
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about Mr. Oppong. First of all, what did he tell you about
documents from Ghana? This kind of goes back to the name and
the Social Security mess-up. Mr. Oppong said, yeah, people
coming out of Ghana have messed up documents all the time.
People coming out of a third world country, it's not uncommon
to have messed up documents. And that's -- that's common
sense.
We all know people from other countries that have had
messed up documents. It happens.
And Oppong, who is no friend, I mean, the man
recorded Karl, we didn't hear it, but the man for some reason
decides to bring a recording to Karl's -- a recorder somehow
to Karl's house, and then they go to the office, he records
him just for the heck of it, a little weird. While he tries
to sell him this Internet -- this website thing. A little
weird. Not exactly your friend.
And then he gets up there and he says they're the
same age. They were not the same age. And, again, that's the
big -- that's the big, oh, he lied about the age and that
shows, you know -- that's all -- he didn't lie about his age.
There was a mistake when he left Africa. And he and Oppong
are not the same age, they were not in class together, they
were not in school together. And Mr. Oppong looks about five
years older than Karl.
And let's be clear, I asked -- I asked the question,
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you know, we had -- I asked Karl, because we heard about the
plastic surgery, Karl had abdominal plastic surgery. He did
not have his face reconstructed, so it's not like he looks,
you know, five years younger than Oppong now because he had,
you know, secretive plastic surgery. And he had plastic
surgery, that doesn't -- he didn't conceal money or help
launder money by getting plastic surgery. Oh, plastic surgery
that sounds bad, it sounds like movie stuff. You know, oh,
gets a bunch of money, goes and gets plastic surgery. That's
the suggestion, that's the implication of ill intent.
But let's be clear, let's make sure we're honest
about what that is, it's abdominal plastic surgery. We ain't
seeing that, because he didn't -- not his face, he didn't hide
his identity, he didn't -- you know, it's like -- didn't
change anything, didn't make the money hard to find, didn't
make the cars harder to get out of his garage, abdominal
plastic surgery.
Agent Caruana, now he gets close, he arrested Karl
May the 12th, 2022, over three years ago. And then we'll have
a -- you'll have a recording, you will have it back there, you
will have the recording of the interview.
And Caruana -- first of all, they show up there with
ten agents, tactical gear, I said automatic weapons, he said
they weren't. Anyway, they were -- they were these kinds of
guns that you hold in your hand and they would go like that
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(indicating). They were -- you know, they look like
tactical -- they're not Army guns, but they look like Army
guns. He's got long guns, short guns, ten cops, they're in
tactical vests, you know, you've seen the picture, you've seen
the movies, you know how that goes down. Get on the ground.
That's how it always goes. And they usually use the MF word
right after that, get on the ground. And they put his
cuffs -- they cuff him behind his back. You know that's what
happens and it's terrifying. You see it in the news all the
time. It's happening with ICE agents right now.
But to say that Karl wasn't scared, to say he wasn't
scared when he got arrested, put yourself in those shoes.
Think about it. You get arrested by ten armed FBI agents, how
well are you going to do when they start interrogating you?
We went around a little and she asked him some
questions today, and you've got the recording back there, so
you can go and check, and I'm not going to just tell you, you
can go check, all of this, you can go check. You've got the
recording. And you'll hear Agent Caruana saying what was the
maximum amount of employees that you ever had. And you will
hear Mr. Torjagbo say that's like it's high turnover so
honestly, you know -- Caruana, okay.
You will hear Mr. Torjagbo I cannot, you know, I
don't know off the top of my head. You will hear on that
recording you are going to have back there.
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Agent Caruana, I mean take a guess, a guesstimate,
was it 50, is it 100, is it 10. Mr. Torjagbo, you will hear,
honestly, I can't answer that question. I don't know.
Now, the prosecutor is a good lawyer. And she did a
fine job yesterday. She crossed him and she -- or maybe it
was today and he asked you about the maximum number and you
said 50 or 60. And Karl's like, yeah, went right along. It's
called leading the witness, it's what we do.
But you have the recording. You listen to that. And
you hear what Karl said. He said, honestly, I can't answer
that question. I don't know. And that's what happened on May
the 12th. And again, if Karl didn't fill in all the pieces on
May the 12th, 2022, you ask yourself how would you do after
getting thrown on the ground by 10 FBI agents.
You know, they of course -- their argument, well, you
didn't tell them about Andrea Lewis and you didn't tell them
about Michael Lee. You know, we don't always remember
everything when we're on the spot like that. And we don't --
is it important or not? It doesn't -- sometimes things don't
seem -- at that point in time, you don't have an indictment,
you don't have discovery, you don't have -- you don't know
what they're coming at you about.
You sit around for three years and you read all of
this stuff and you're like, oh, okay, and now I see what
they're coming at with me, and let me tell you all of it then.
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And that's what Karl did to the best of his ability.
He didn't say, ah-ha, he lied, he held back, he
didn't tell them about that. It's not like that. I mean, you
are going to have a -- you have a jury instruction on that.
In fact, you'll hear about how you evaluate statements. And
one of the ways that you are going to evaluate statements is
you must consider all the evidence about the statement,
including the circumstances under which it was made. You must
consider all the evidence about the statement, including the
circumstances under which it was made.
So if Karl didn't tell Caruana back on May 12th about
Andrea Lewis and Michael Lee, put yourself in his shoes, how
would you do after going through all of that? I wouldn't do
well and most people don't.
You heard from Karl Delano. And you heard -- you got
to hear him testify. And he's a witness just like anybody
else. He told you what he intended. He told you what he
believed. He told you what he did.
I mean, if he's going to -- he could have come in
here and say I didn't file any tax returns at all. I mean,
are there parts of his story that you're like, wow, that's --
you know, she came into your house and filed that after you
asked her to. I mean, you're like that seems pretty crazy.
But if he's going to start making stuff up, wouldn't he make
up something better than that.
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I mean, that's -- he told the story because that's
what happened. You don't just -- you don't -- there's no
reason to make up a crazy story. If you're going to start
making stuff up, make up a good one. Andrea Lewis coming into
his house and filing that second return, why would anybody
file a second tax return using a different date -- using a
date of birth and a Social Security number that they hadn't
used in 20 years? You just wouldn't. You would not do that.
So again, you heard him testify, you evaluate him and
you decide have they proven beyond a reasonable doubt that he
didn't have good faith, that he had ill intent, and that he
was trying to defraud people.
Was there a PPP loan for Kremkov, yes, there was. We
don't dispute it.
Was the company in operation before February 15th,
2020? And we've beat this horse for a while. The
government -- the government, Government Exhibit Number 1,
ha-hah, we've got him. Social Security -- sorry, Secretary of
State, starts with an S, Secretary of State record number one,
says, hey, Kremkov wasn't formed until January of 2021.
Ah-ha, we've got him.
Well, think about that for a second. Secretary -- I
don't know if y'all are familiar with the Secretary of State's
office, but anybody can go in there and type a name. We can
type in Kremkov, we can type in Karl Delano, we can type in
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Karl Delano with a K, anybody can type in a name, including a
bank. It is the easiest portal -- it's a starting -- the
realtor, the so-called friend, Oppong, he did it, he said he
did it. Looked on the Secretary of State website. Ah-ha, it
was incorporated after this magic date.
The form in the certification never required
incorporation before the magic date, it just didn't. They
wanted to squeeze that in there and make that an ah-ha moment.
All the language on the form said the company must be in
operation before February 15th, 2020. And operation, we never
got any kind of legal or concrete definition of what that is.
But clearly, Kremkov was in operation before that
date. Karl had an EIN number before that date. And there's
no evidence that it suddenly -- Kremkov suddenly started on
the day it was incorporated. I started practicing law in
1995, I don't think I -- no, that's not right, '89. I opened
my practice in '95. I don't think I incorporated until about
2002 -- just because you incorporate at a later date --
THE COURT: Excuse me. Let's stick with what the
evidence is in this case. I'm going to strike that last
statement about what he personally did. Let's stick with what
the evidence in the case actually is. Okay?
MR. FINLAYSON: Yes, sir.
And the argument is not about me, but the argument is
just because you -- just because you are not incorporated does
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not mean you are in business. And we all know plenty of
people that are in business that are not incorporated.
Did Kremkov have 493 employees? Yes, it did. Now,
you heard Karl talk about -- well, actually it had more at one
point. And the government was like, well, oh, now you're --
now you're making stuff up. You've got 600 all of a sudden.
Why don't you have 600, why didn't you put that on the form?
Well, not all of them qualified. Not all of the workers in
the mine were from the United States.
And that's -- that is the important piece of that is
are they principally domiciled in the United States. And same
kind of thing, not one witness could give us a legal
definition of what principally domiciled was, either. It was
like one guy said, oh, that's an IRS definition. Not one
person ever gave us the criteria for what really qualifies as
principally domiciled.
But, you know, at one point, there was a suggestion
in the testimony that you had to have your company entirely
U.S.-based, and that's not what the forms required. The forms
require that the workers had to be principally domiciled, and
that means that they live probably more than 51 percent of the
time in the States and 49 somewhere else. But we don't
really -- we never get that. We never heard if it was 51 or
75 percent. We don't have any definition from any witness
about what principally domiciled means.
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Did you pay wages, yes, we did. Now, let's be clear.
And the prosecutor asked Karl -- or, no, she argued that, you
know, well, why would you -- why would you have to get PPP
money if Michael Lee is paying wages. Well, Michael Lee was
his partner. And Michael Lee was taking out gold, he's a
Chinese man, he's taking out gold, he's got the cash.
And Michael Lee was the one that paid the people that
actually wired the money to the employees. It's not saying
that all of that cash just came from Michael Lee. It's not
saying that -- that Karl has got the percentage of the mine,
it's -- the value is in the gold, the gold's coming out of the
ground, Michael Lee is taking that gold at 50 cents on a
dollar, he is the one issuing -- doing the typing, issuing the
wires to the employees.
It's not that they weren't spending the money, it's
not that Kremkov wasn't spending the money, it was that Karl
was not the one actually wiring the money by hand, he was not
the one doing that part of the work.
And we've covered this. Again, the regulation is
that you were in operation on February 15th, 2020, not that
you were incorporated.
So, you know, I've complained, I've argued about the
lack of on the ground information realtime, because, again,
most of the government's case is people coming back three
years later looking at documents saying, well, this is what
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that means and this is what that says and this is what he did.
So many of these witnesses, they talked about it like
they were there in the room, but none of them were.
But we do have this one call, this Government's
Exhibit 108, that we heard, and I'm going to play a little bit
for you again, that tells you -- that shows you what Karl
intended. And what it shows you is that Karl did not intend
to ask for forgiveness for the PPP loan. And how do we know
that?
Let's see if I can make this work.
(Whereupon, the recording was played.)
MR. FINLAYSON: I'm entitled to six months of
deferred payments, that's what that call was about. And
there's not one bit of evidence in this case to ever say Karl
wanted to get loan forgiveness, not one. Not -- not an
attempt, not some rejections, not -- nothing.
In fact, he's talking to the people at the bank and
he's complaining like, well, you pulled this money back out, I
don't want to have to pay that part back. But I have to do --
and there was a deferment of six months on the payments. And
he's like saying, look, just put it in writing to me so that
when I have to start making the payments, we're on the same
page. That's clear as day.
You're also going to have in evidence -- excuse me --
you're going to have in evidence -- or you have in evidence
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these bank statements from Chase. And they're -- you've got a
bunch up there, too.
But the ones that I put in that I think are relevant,
September 29th, 2022, his payment due is zero, because the
payments -- there had been a deferment, payments weren't due
yet. The next statement, it's actually Defendant's 3, shows a
bill date of August 15th, 2022. And this is the first
payment. This is the first payment of $69,000. It's the
first payment due on the loan.
Now, Karl admittedly did default, but not because he
ran off to Tahiti with the money or fled the country or went
to Vegas. He defaulted because he was in jail. They took him
into jail on May the 12th, 2022, three years ago, but he did
default, but he never -- his plan all along and you'll hear it
in that call was to make the repayments. His plan was not to
ask for forgiveness.
If you're trying to rip off all this money, if it's a
scam, if your intent is ill, if it's all a fraud, like they
say, you don't make arrangements to make repayments, you just
don't. You pack it up, you go to Hawaii, you run, you do
things like that, you change your face, you get your face
changed, you get plastic surgery, you get your face done.
Karl didn't do any of that.
The tax returns, the government has gone on and on
about he didn't pay any money in to the IRS, he wasn't
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entitled to that return. Michael Lee didn't pay any money to
the IRS. That's just all made up. That's their theory, it's
all made up. The IRS sent him a check for $3.4 million, but
it was all made up. So on one hand, the IRS is God, they
don't make any mistakes ever, right? That's their general
approach is the IRS is perfect.
But on the other hand, on the other hand, here, they
must not have looked. I guess that -- they're -- it's just
the honor system. I had no idea. The IRS is the honor
system. Okay. The IRS is the honor system.
So he submits a tax return and they just send him the
money. Does that strike y'all with common sense? Does
that -- does that sound like common sense? Do you believe for
a second that -- with common sense that the IRS is just going
to send you $3.4 million because you put it on a form?
All right. We have defendant -- Government's
Exhibit 200A, which is the transcript that shows -- and this
is a transcript prepared -- prepared in 2025, by the way,
June -- you'll see at the very top -- 200A, you'll have it
back there -- 201A, I'm sorry, 201A, transcript prepared June
of 2025, which is just last month. It shows the balance owed
for tax year 2020 is zero.
If Karl had just scammed them out of $3.5 million or
3.4, the balance, shouldn't it be negative -- it should be
3.4, right? It's zero.
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And then you see the withholdings, the negatives we
were told are credits, we see the withholdings of $3,459,835.
Now, the government is going to say, oh, that's not real,
that's fake, Karl made that up. Well, Karl just made that
number up and they cut him a check, that's just -- honor
system, I guess that's -- that's how the IRS works.
Look at some of these dates and ask yourself these
questions. You got Government's Exhibit 201, Government's
Exhibit 201, which is the 1040 -- Form 1040, that's the tax
return that paid out. And the amount of money requested was
3,373,441. And that return you heard was filed February 13th,
2020, February 13th.
Now, did they issue a check the next day? They did
not. They issued the check April 23rd, '21. In other words,
they issued a check over two months later. And this is weird
for a lot of things -- a lot of reasons it's weird.
First of all, he requests 3,373,441 [sic], they pay
him out $7,000 less than what he requested. Now, you heard
what -- why that happened was there was some tax money owed
for prior years, 2013 and '14, there was $7,000 in taxes owed
by Karl. They took that out of the check. So it ain't like
that just didn't look at this. It wasn't the honor system.
They looked at this. And the records showed there was a
payment made to the IRS for that $3.4 million. The records
showed that. This was not honor system, this was not, oh,
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just a computer spit out the check because he asked for it.
Now, if it had been the next day, maybe you'd say,
yeah, okay, the computer just spit out the check. It wasn't
the next day. It was two months later.
And it gets even weirder, because if you look at that
return, that 201, that return asks -- filed by Karl, he admits
every bit, he filed that return, he asked for that money to be
sent by wire transfer to his bank, he put in -- we've all
probably -- well, people do that, you put in the routing
number and the account number and the IRS will send that money
directly to your account. He didn't say issue -- look at that
return, 201, he didn't say send me a check, but they took two
months, they took out $7,000 and they sent him a check.
And you believe, your common sense tells you that,
oh, the IRS was just working on the honor system and sending
out $3.4 million without verifying that their payments have
been made in before that. I mean, funding has been cut to the
IRS, but it ain't that bad. The IRS is the IRS.
I've covered that, why did it take so long.
Where did the PPP money go? 6.5 was taken by
Chase Bank. I always wondered if they had to return the bonus
on the original issuing. And the rest went to FlyingJack.
And we've heard the government admit, well, it went into this
account and we can't tell which was tax money and which was
PPP money, we can't tell which is which, there's no way to
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tell, but, yeah, a bunch of money then went on to FlyingJack,
and that's -- and he admitted that. He admitted that he spent
the PPP money on FlyingJack.
Now, was that what the program was designed to do?
Probably not. The program was not designed to start new
businesses. And that's what Karl did. But he told them.
When they interviewed him, he admitted it, yeah, I bought all
of these tractor trailers. I paid all of these -- I had to
pay these licensing fees, I paid insurance. He bought this
land. He did all of those things to start a new business in
this country. That's not intent to defraud. That is not --
that is not lack of good faith.
Is that -- was that perfect? No. Is that exactly
what the program was designed to do? No. But it's not fraud.
And again, he didn't ask for forgiveness. He didn't ask for
the loan to be forgiven. He didn't say, well, I put the money
into FlyingJack and so it's all free, give it to me. You
know, I don't -- I don't have to pay it back. He never did
that. He knew he had to pay it back.
I just covered that.
All right. The money laundering counts, let's talk
about that. And I love this chart because it's a nice chart.
First of all, the concealment counts, how much -- and
I've covered this a little bit already, but how much
concealing did Karl do? He changed his name from Torjagbo --
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Torjagbo to Delano, is that concealing? He had his abs done.
Is that concealing? No, he didn't conceal. It was plain as
day where this money went. He didn't hide it. He didn't hide
it in Wyoming. He got a BOA, a Bank of America account in
Georgia, I mean, I suppose if he had put all of his money in
Wyoming, that would have shown some intent to defraud or some
mal -- or some -- some evil shystery sort of things. He
didn't do that.
He put the money in a Bank of America here in
Georgia. And it starts out -- and look how easy this chart
is. Look how -- look how simple it is. It comes into Chase,
it goes to a PNC account in the name of Kremkov, Kremkov is
Karl, every one of these accounts is Karl, it's not -- there's
no secret. Open and notorious every step of the way.
Then it goes to the Bank of America account and then
he buys the things for FlyingJack, he buys the tractor
trailers. Yes, he did. He buys the land, yes, he did. The
tax return also goes into that account. The tax money goes in
there. And that's the money that he was intending to spend on
personal items. That's where he bought the toys. He bought a
nice house. Yes, he did. Was it crazy big? Yes, it was.
He bought a Lamborghini, there is nothing more open
and notorious in this world than a Lamborghini. If you're
trying to conceal funds, if you're trying to launder money, if
you're trying to hide what you're doing, that's the last thing
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you buy is a Lamborghini. A Lamborghini says look at me.
That's what a Lamborghini does. And look at me, they did.
Oppong says get a website. I don't need a website.
Look at me, open and notorious. There was no intent
whatsoever to conceal funds or conceal the source of those
funds. And it was -- look at the chart, it's clear as day. I
mean, if it had gone to like six other people, if it had
like -- if like $50,000 went to Oppong and then 40,000 came
back and then, you know, $100,000 went to Monica Sweeten and,
you know, another $100,000 came back or if it went to John
Smith or if there was six different companies, that's hiding
the money.
Here we have one account Karl's tied to, next
account, Karl's tied to and then a third account. It's clear
as day. It's not -- there's no concealment whatsoever. Every
one of those things, some of the -- one car he bought -- this
was interesting. One car he bought in the name Carl Torjagbo
after he had changed his name. And the government suggested
or argued, well, that shows he was having intent to conceal
because he had changed his name to Delano but he's using the
old name.
Like if you're trying to hide and conceal money, you
don't hide it very well by using the name you just changed
from. And anybody that's ever changed their name at marriage
or anybody that's ever changed their name not with marriage,
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anybody that's changed their name, it takes awhile for things
to catch up with that change. It's not -- it's not -- you
don't -- it doesn't show bad faith or surreptitious nature or
evil intent because it takes a while to change over all of
your documents or it takes awhile to change over your name on
all of your bills. The cable bill is probably the last to be
changed, if it's been changed yet. Well, probably it's cut
off now, but, anyway, the point is buying a car in the name
Carl Torjagbo after he's changed his name does not show any
kind of evil intent or any kind of intent to defraud.
And again, every one of these things was -- they
weren't hiding, they -- the cars were at the house. One car
was at the shop. All of the trucks were on the trucking lot.
They seized every one of them. The government didn't -- they
didn't have any trouble getting them. They weren't hidden.
They got every one of them.
They also seized money out of his accounts. And you
can think about that. They got over $2 million out of one
account and about $800,000 out of another one. And this is a
year after the PPP loan and a year after the tax return. So
use your common sense. If you're trying to commit some kind
of fraud, if you're trying to launder the money, if you're
trying to get away with this grand scheme and this grand
heist, wouldn't you go get that money out of your account? It
was right there, right where he left it, right where he left
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it. And the government grabbed it. Again, it's just another
piece that shows good faith, not bad faith.
Here we are again. And I'm about done. You're going
to have it on Page 19. Good faith is a complete defense to a
charge that requires intent to defraud. A defendant isn't
required to prove good faith. The government must prove
intent to defraud beyond a reasonable doubt.
And that -- you know, we hear those words on TV so
much, they kind of maybe lose some meaning or we start to take
them for granted, but what does beyond a reasonable doubt
mean? They almost -- it's beyond a reasonable doubt, it's
above and beyond a reasonable doubt. If you have reasonable
doubt, you might have suspicions, you might think maybe, you
might say, oh, that story -- that seems pretty crazy. That is
not what you can act upon in this case.
Oh, I think we've covered enough of that. And we've
covered that. I think we've covered all of that, too. I'm
sorry.
Again, that list, those documents were not material
to that loan.
All right. I'm going to back up a second. And this
is summary-type stuff, but again, the evidence showed that
Karl did not commit PPP loan fraud nor did he knowingly or
intentionally commit wire fraud on the IRS.
It showed he did not launder money to conceal its
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source. They showed he didn't conceal anything, he was open
and notorious, as I've said all along. Nothing more than open
and notorious and a Lamborghini. His purchases and
transactions did not use -- make use of funds from an unlawful
activity.
And the government has the burden of proof. Karl had
no burden of proof. We didn't have to prove a thing to you.
He didn't have to get on that witness stand. He doesn't have
to prove a thing. The government has to prove the lack of
good faith. And this should get us back to reasonable doubt.
Reasonable doubt, kind of at the lowest end of the
spectrum, it might be, well, do you believe he's not guilty?
If you believe he's not guilty, yeah, that's really easy,
yeah, that's reasonable doubt.
What if you think it's highly unlikely? Yeah,
maybe -- maybe it's highly unlikely he did it, sure,
easy-peasy. That is not proof beyond a reasonable doubt. If
you think it's less than unlikely, again, easy-peasy, that is
not reasonable doubt. If you think probably not, yeah, he
probably didn't do it, again easy-peasy, that is not beyond a
reasonable doubt. If you think unlikely, easy-peasy, yeah,
unlikely did it, yeah, that's not -- that is not proof beyond
a reasonable doubt.
Possibly not, maybe he didn't it, not -- not beyond a
reasonable doubt. May not be, easy-peasy, not beyond a
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reasonable doubt. Perhaps, this is where it starts to get a
little harder, it gets a little closer, yeah, perhaps he did
it. That's not beyond a reasonable doubt. Suspected, sure
seems fishy, I suspect he did it, that is not beyond a
reasonable doubt. Possibly guilty, yeah, maybe he's guilty,
possibly guilty, that is not beyond a reasonable doubt.
Probably guilty, harder even, but again probably guilty is not
proof beyond a reasonable doubt.
Guilt likely, he's likely guilty, that is not proof
beyond a reasonable doubt. Strong belief that he did it, that
is not proof beyond a reasonable doubt.
Guilt beyond a reasonable doubt is the highest
standard we have in this country. It's important. We don't
just deal with issues of liberty and life on low standards.
It is very important. You've got to hold the government to
its burden. You are the only ones that can do it. And if
they haven't proved it, you've got to say so. And if you have
doubt, if you're like, well, you know, have they proved he
didn't have good faith, have they proved to you, and it's sort
of complicated, they have to prove to you beyond a reasonable
doubt that he did not have good faith. And if they haven't
done that, you can have all of these other things, you can
have strong belief, you could have possibly guilty, you can
have all those things, you can't do it. You must hold them to
their burden and you must return a verdict based on what
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they've actually proved in this courtroom.
Did they bring the guy from Chase Bank to say, oh, I
relied on these documents and that that's why I issued this
loan. No, they did not.
Members of the jury, last time, do your job, make
them do their job, please. Go back there, look at all the
evidence, return a verdict of not guilty on all counts.
Thank you.
THE COURT: Okay. Rebuttal? Everybody okay to go a
couple of more minutes before our lunch break? I don't like
to break this up. Is that okay? I'm not seeing too much
consternation.
All right. Go ahead, please.
MS. CONNORS: Ladies and gentlemen, you've heard a
good bit just now about materiality. I want to remind you,
you'll have the jury instructions back with you. And what the
Court instructed you on earlier today and what you will see in
those instructions is that a fact is material if it has the
capacity or natural tendency to influence a person's decision.
It doesn't matter whether the decision maker actually relied
on the statement or knew or should have known that the
statement was false.
Chase Bank, it was not their burden to try to figure
out that the defendant submitted false paperwork to them.
They were not the ones who were supposed to be ensuring the
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accuracy of that information. And all that the defense wants
you to believe is that there is no way that Chase paid
attention to any of those documents.
But you heard repeatedly from SBA and from Chase that
they had to have supporting documents, it was a requirement.
They could not approve the loan if it was just the application
itself. And you even heard Chase say they had a system for
ensuring and checking off that they had actually received all
of that information.
And you heard a good bit from SBA and from Chase
about how the rules were that the bank could rely on that
information to issue the loan.
Now, when we talk about rely, it means that they
actually got the information, they got the supporting
documents, they got the application that was filled out and
they got the certification from the defendant saying my
application is true and correct and all of my supporting
documentation is true and correct. If they had those things,
they could push the application forward, they could push the
loan forward.
The defendant submitting false information to the
bank does not somehow absolve him of intent to defraud. He
doesn't get to say if the bank didn't realize that these
documents were bad, that they were so absurd, because they
listed Keanu Reeves and other individuals on them, that
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doesn't negate his intent, in fact, it seems to bolster it to
show that's documents he's providing that he is saying should
have seemed so ridiculous that no bank should have given him
the loan. But that's from him. And the bank made it clear
that all of that documentation was material to their decision
to issue that loan.
Ladies and gentlemen, there is no possibility that
the defendant had an honestly held belief that he could submit
fake information, that he could say he had Kremkov Industries
in operation before the February 15th, 2020 deadline, that he
could say that he had 493 employees, that he could say he had
$3.8 million a month in payroll and that he could try to
submit documentation to support all of that. There's no
possible way when nothing has been shown that he had Kremkov
in operation in any way prior to February 15th of 2020.
Oppong, Mr. Oppong testified 38-year friendship.
They met in boarding school. And he said yeah, maybe the
defendant could be a year younger or a year older than me
because of the way the schools worked there, there's no way
that he would be four years younger than me.
But even that aside, the bottom line is you're
talking about people who have kept in touch, they met when
they were Ghana in boarding school when they're young, they
are now in the United States and they have kept in touch for
decades. And yet, Mr. Oppong had never heard of Mr. Delano
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owning a mine.
Defense counsel asked what's in a name. A lot here.
Names like Kremkov Industries, names like Monica Sweeten,
Keanu Reeves and Karl Delano. Names are a lot when you're
going to list 493 on payroll. That's a lot of names.
And when you look at that payroll some more, we
showed, I mean, some of those pages don't have names like
Keanu Reeves. I mean, the names that we've pointed out that
are famous people, celebrities, we're talking about maybe ten
or some so names out of 493, they're buried in that payroll,
additional names they needed to get really, really close to
that 500-employee cap and be able to justify that there would
be a reason you would have such substantial payroll, you
needed to have a lot of employees.
Ladies and gentlemen, when we talked about the two
Social Security numbers, you know, the defense is saying, you
know, it would make no sense that 20 years ago, he got a
second Social Security number just so he could commit this
fraud.
To be clear that's never what the government has
argued. We've argued he obtained two Social Security numbers,
but the critical point is that the fact that he had those two
Social Security numbers is what allowed him to file the two
fraudulent tax returns. Because you heard from the IRS
witness that if two returns had been attempted using the same
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Social Security number, one would have been rejected, it would
have been rejected as a duplicate, because they only process
one return per person.
So the fact that he had those two Social Security
numbers available to him is what allowed him, gave him the
opportunity to commit the crime. We're not saying 20 years
ago, he planned to file a fraudulent tax return in 2020, it is
simply how he actually committed that crime.
Ladies and gentlemen, certainly if you need to listen
to the custodial interview again, that absolutely will be
available to you. Defense counsel wants to say that those
answers the defendant gave over and over again to
Agent Caruana somehow should be disregarded because he was too
scared to tell the truth.
But you heard the defendant get sworn in before his
testimony. And you heard he's under oath, supposed to tell
the truth. When he was asked about that interview and what he
was saying in terms of employees, he agreed that he -- that he
had a maximum 50 to 60 employees. But now it's that you're
supposed to disregard that answer because three years ago he
was afraid. He wasn't under -- he wasn't suddenly under
arrest today and he was actually tasked with answering
questions truthfully.
You're not required to disregard his answers under
oath. You get to make the call, you get to judge that. And I
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think when you look at everything in totality here, it's clear
that the defendant committed bank fraud and committed wire
fraud. That he did that to be able to get all those millions
of dollars from Chase Bank, did that to get millions of
dollars from the IRS that he was not entitled to receive.
And once he got it, he funneled all of that money
through multiple different bank accounts. Keep in mind the
demonstrative exhibit that the defendant just showed you again
doesn't include all of those additional transfers from 9849,
but you have -- you will have the summary exhibits from
Ms. Richardson that go through all of that that you can
review.
What the defendant did here was move all of that
fraud money through accounts and make enormous purchases of
lots of different assets. And he did that in part related to
the specific counts for concealment to disguise those
transactions.
We've already talked earlier today about the check
saying payroll and then moving money to accounts in the name
of FlyingJack in order to purchase other property. No reason
that he couldn't purchase those properties in one of the
original bank accounts.
And you may recall there was a lot of transferring
money through things like cashier's checks, withdrawing cash
from a cashier's -- with a cashier's check, then going and
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depositing it in another account. Cashier's checks issued on
the bank's account rather than the original account of the
defendant.
Ladies and gentlemen, it's not the victim's
responsibility to ensure the defendant's not lying to them.
It's his responsibility to make sure that he was providing
truthful information to both the bank and to the IRS. And
when he didn't, he committed fraud that got him millions of
dollars and he laundered that money. And you should find the
defendant guilty of all charges beyond a reasonable doubt.
Thank you.
THE COURT: Okay. You've heard everything. The next
thing you will do is go to the jury room, where you will
choose one of your members to act as the foreperson. The
foreperson will direct your deliberations and will speak for
you in court.
The parties have prepared a verdict form for your
convenience. It's pretty simple. It has a number, a list of
questions, each question is largely the same. It has one
question for each of the counts.
It says as to Count One, we the jury find the
defendant, Karl Lucius Delano, formerly known as Carl Delano
Torjagbo, and then there's a spot for you to put either guilty
or not guilty, there's a line to check either one, depending
on what you decide. And there is the same question for each
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one of the individual counts in the indictment. Okay?
So you have to select either guilty or not guilty for
each one of the counts at issue. Okay?
You will take it with you. And when you all have
agreed on the verdict, your foreperson will sign it at the end
and will date it and will keep it and let us know that you
have reached a verdict. Okay?
If you wish to talk with me at any time, I ask that
you write a note and you give it to the court security
officer, who will give it to me. I will respond as quickly as
possible, either in writing or more likely by bringing you
back in here.
But I want to caution you not to tell me how many
jurors have voted one way or the other if you write a note.
Okay? That is not for me or for anybody else to know.
Do you understand?
So if you write -- if you want to communicate with
me, write down your note but don't tell me where you-all are
in your deliberations.
Okay. Any questions about that?
A little bit more housekeeping. I believe the
downstairs lunchroom closes at 1:30 on Friday, I've been told
that. So why don't you do this, why don't when you get down
there -- when you get into the jury room, I'll have you go to
lunch immediately. And then when you come back, you can
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select your foreperson.
And at that time, after you've selected your
foreperson, you can begin your deliberations. Okay?
Wait until you've all got your food together. And if
you want to work over lunch, you can, or you can eat and you
can start your deliberations after that. Okay?
It will take us a couple of minutes to get you all of
the exhibits back there, so go ahead and get your lunch right
away. Okay?
Do y'all bring them back up here when they're
deliberating or do they eat down there?
COURTROOM SECURITY OFFICER: Either way. There's
rooms they can go in down there.
THE COURT: Okay. You can't deliberate down there,
you've got to deliberate up here, but y'all can decide what
you want to do. When you're deliberating you all have to be
together. Okay?
You can't deliberate where some people are getting
lunch or anything like that. Any questions about that?
So go in the back, go have lunch, then come back and
at that point, select your foreperson and begin your
deliberations. Okay?
Yes, one second. Hold on. Don't go yet.
One second. Dean, Ms. Dean, okay, you stay here.
Okay?
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All right. Y'all go ahead.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Y'all can be seated.
Ms. Dean, this is my least favorite part of a trial.
This is where I have to tell you that you are an alternate
juror, so despite having sat here all week, you don't get to
deliberate unless something happens with one of our jurors.
But we had two alternates, we've already lost one
juror because that gentleman didn't show up. And the other
juror here, she has to start work on Monday, the young lady in
the back row who is also a nurse. I think there's a high
likelihood you are going to be called in to deliberate. Okay?
JUROR: Okay.
THE COURT: So you still can't talk to anybody about
this case. All right?
I'm going to let him take you -- do you have stuff
back there?
JUROR: Yeah, my bag.
THE COURT: I'm going to let you go back there and
grab your stuff. Do you want her to stay? I guess she can go
home for the day. I think you can go home for the day, but
make sure that Ms. Kelley has your phone number in case we
need you to come back. I am very sorry about that.
JUROR: That's okay.
THE COURT: If I could have you deliberate, I would,
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but we can only have 12. I really appreciate it.
JUROR: No, that's okay.
THE COURT: And like I said, it's my least favorite
part.
JUROR: That's okay.
THE COURT: Okay. I want you-all -- any objections
or anything that y'all want to talk about?
MR. FINLAYSON: Your Honor, I did have one thought
about this juror situation. It's just a thought. Would it
make sense to just let the young woman from -- that's got to
go to work on Monday go on and put her on?
THE COURT: You-all tell me. What do want to do?
MR. FINLAYSON: That would be my vote.
MS. CONNORS: Your Honor, I'm not sure if there's
been additional information beyond the voir dire. I mean, I
know the Court did --
THE COURT: No. She said on Monday she starts a new
job and there is orientation with all the other new people.
That's all we know about her. And I told you that she said
something to the CSO maybe the first or second day of trial
that she was worried.
MS. CONNORS: Yes. And so I think our position is
that it wouldn't be appropriate to excuse her right now.
THE COURT: Okay. I won't do it unless both of y'all
agree. Okay.
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MS. CONNORS: And the one thing we did need to go
ahead and put on the record is whether or not the defendant is
choosing to hold the jury for forfeiture.
MR. FINLAYSON: I believe we -- at this juncture, I
would say yes.
THE COURT: Okay. If you change your mind, you'll
let me know. Have you-all looked at -- there's no problems
with the jury instruction that was provided on the forfeiture?
MR. FINLAYSON: I'm not aware of any at this point.
I'll look again just to make sure.
THE COURT: Please do. Because I'm going to keep
them rolling quickly if we get to that. Okay?
MR. FINLAYSON: Okay.
THE COURT: I thought I saw a flash up on the screen
a picture of a truck with a person in it that is not in
evidence.
MR. FINLAYSON: I apologize, yes, Your Honor.
THE COURT: I don't like that.
MR. FINLAYSON: I apologize.
THE COURT: Okay.
MR. FINLAYSON: I apologize.
THE COURT: But it was somehow put into a PowerPoint
that had to be used for closing. And if I saw it, the jury
saw it. And looked like it had the name on it. And it looked
like it had a person. Has FlyingJack ever operated?
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THE DEFENDANT: Yes.
MS. CONNORS: I mean, he bought dozens of trucks and
trailers.
THE COURT: Yes.
MS. CONNORS: And then Ms. Richardson only saw maybe
a few grand coming in during any timeframe.
THE COURT: And I don't -- I don't like the fact that
there is now something flashed, even momentarily, in front of
a jury that suggested an ongoing trucking business. I
don't -- I don't know how that happens accidentally, but I
don't like it. And had it stayed up for another half-second,
I was going to say something about it.
MR. FINLAYSON: I do apologize. I apologize, Judge.
I should have put it into evidence.
THE COURT: Well, I know. But, no, that's
irrelevant. You shouldn't have mentioned it because it -- you
shouldn't have had it on there because it wasn't in evidence.
I like aggressive trial, I think that's all
wonderful. I don't like things that push the line of an
unfair blow. I don't like it. And I don't sit back like a
potted plant when I see it. I note it. I did that to both of
y'all a couple of times. I didn't do anything in front of the
jury about that. But I almost did. Had it been up their
another half-second or had the government reacted, I would
have done it. Okay?
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MR. FINLAYSON: Thank you. I apologize, Judge.
THE COURT: All right. Thank you.
You-all can't go to lunch until you get all the
exhibits ready.
And then, Ms. Kelley, where do you want them to put
the exhibits when they're ready to go back?
COURTROOM DEPUTY: We'll reconcile everything at the
front table.
THE COURT: And how do they get the audio transcript
if they want to listen to it, or the audio if they want to
listen?
COURTROOM DEPUTY: The government will have to
provide a clean access.
MS. CONNORS: We have a trial laptop.
THE COURT: That has no access to the Internet or
anything like that? All right. So you-all get everything
together, you-all take responsibility for making sure that
everything that goes back is what's been admitted.
And then when you have all that, let Ms. Kelley know,
and then you can go to lunch. Okay?
All right. And then stay close. Because we're going
try to keep them moving throughout the day. Okay?
MS. CONNORS: Yes, Your Honor.
(Whereupon, a recess was taken.)
THE COURT: All right. Are y'all ready for the
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
jurors?
MS. CONNORS: My paralegals are trying to gather.
THE COURT: Well, we can wait. We've waited for
everything else.
MR. FINLAYSON: And just, Your Honor, a heads up,
depending on the verdict, we may be able to resolve the
secondary matter.
THE COURT: Okay.
MS. CONNORS: Your Honor, I think we're fine to go
ahead.
THE COURT: Let's give it another minute. She's been
here the whole time.
MS. CONNORS: I know. She came in and then she was
like, oh, let me go get the computer. And I think she got on
the elevator too fast before we could stop her.
THE COURT: That's all right.
Are you ready now?
MS. CONNORS: Yes, thank you.
THE COURT: All right. Let's bring them in.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. You may be seated.
I'm assuming you are the foreperson?
JURY FOREPERSON: Yes, sir.
THE COURT: I understand you-all have a verdict; is
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
that right?
JURY FOREPERSON: We do.
THE COURT: Is it as to each count of the indictment?
JURY FOREPERSON: Yes.
THE COURT: And is it unanimous as to each count?
JURY FOREPERSON: Yes.
THE COURT: Okay. Would you hand it up to me or hand
it to the CSO to hand it to me.
I'm going to ask you to go back in and examine your
verdict as to Number 9.
JURY FOREPERSON: Okay.
THE COURT: And then let me know if you still have a
verdict. Okay?
JURY FOREPERSON: Okay.
THE COURT: Thank you.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Y'all can be seated. They had -- for
Number Nine, they had both items checked. The other ones they
only checked one. But I heard the gentlemen say as he left,
oh, like I think maybe he realized they made a mistake. There
we go.
COURTROOM SECURITY OFFICER: All rise for the jurors.
(Whereupon, the jurors entered the courtroom.)
THE COURT: All right. Let me look at it again.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Okay. Thank you very much.
I'm going to now ask Ms. Kelley to publish the
verdict. That means she's going to read the verdict. I want
each of you to listen carefully to make sure that this is the
verdict that you-all agreed to. Okay?
And that you individually support it.
Okay. We might -- we might have at the end -- one of
the parties might ask that you be asked whether this is, in
fact, your verdict, so listen to it. Okay?
Okay. All right. Go ahead.
COURTROOM DEPUTY: In the United District Court for
the Northern District of Georgia, Atlant Division, Criminal
Action Number 1:22-cr-171, the jury verdict reads as follows.
As to Count One, we, the jury, find the defendant,
Karl Lucius Delano formerly known as Carl Delano Torjagbo
guilty.
As to Count Two, guilty.
As to Count Three, guilty.
As to Count Four, guilty.
As to Count Five, guilty.
As to Count Six, guilty.
As to Count Seven, guilty.
As to Count Eight, guilty.
As to Count Nine, guilty.
As to Count Ten, guilty.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Signed on 7/25 by the foreperson.
THE COURT: Okay. Thank you very much.
Does either party which to have the jury polled?
MR. FINLAYSON: Move to poll, Your Honor.
THE COURT: Okay. That means that Ms. Kelley is
going to ask each of you if this is the verdict that you
rendered and if it still is.
So one by one, she's going to call your juror number
and ask you to stand up and answer her questions. Okay?
Ms. Kelley.
COURTROOM DEPUTY: Juror Number 1, was the verdict as
published your verdict in the jury room?
JUROR: Yes.
COURTROOM DEUPTY: Is it still your verdict?
JUROR: Yes.
COURTROOM DEPUTY: Was the verdict freely and
voluntarily entered into by you?
JUROR: Yes.
COURTROOM DEPUTY: Juror Number 2, was the verdict as
published your verdict in the jury room?
JUROR: Yes.
COURTROOM DEUPTY: Is it still your verdict?
JUROR: Yes.
COURTROOM DEPUTY: Was the verdict freely and
voluntarily entered into by you?
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
JUROR: Yes.
COURTROOM DEPUTY: Juror Number 5, was the verdict as
published your verdict in the jury room?
JUROR: Yes.
COURTROOM DEUPTY: Is it still your verdict?
JUROR: Yes.
COURTROOM DEPUTY: Was the verdict freely and
voluntarily entered into by you?
JUROR: Yes.
COURTROOM DEPUTY: Juror Number 7, was the verdict as
published your verdict in the jury room?
JUROR: Yes.
COURTROOM DEUPTY: Is it still your verdict?
JUROR: Yes.
COURTROOM DEPUTY: Was the verdict freely and
voluntarily entered into by you?
JUROR: Yes.
COURTROOM DEPUTY: Juror Number 14, was the verdict
as published your verdict in the jury room?
JUROR: Yes.
COURTROOM DEUPTY: Is it still your verdict?
JUROR: Yes.
COURTROOM DEPUTY: Was the verdict freely and
voluntarily entered into by you?
JUROR: Yes.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
COURTROOM DEPUTY: Juror Number 21, was the verdict
as published your verdict in the jury room?
JUROR: Yes.
COURTROOM DEUPTY: Is it still your verdict?
JUROR: Yes.
COURTROOM DEPUTY: Was the verdict freely and
voluntarily entered into by you?
JUROR: Yes.
COURTROOM DEPUTY: Juror Number 23, was the verdict
as published your verdict in the jury room?
JUROR: Yes.
COURTROOM DEUPTY: Is it still your verdict?
JUROR: Yes.
COURTROOM DEPUTY: Was the verdict freely and
voluntarily entered into by you?
JUROR: Yes.
COURTROOM DEPUTY: Juror Number 24, was the verdict
as published your verdict in the jury room?
JUROR: Yes.
COURTROOM DEUPTY: Is it still your verdict?
JUROR: Yes.
COURTROOM DEPUTY: Was the verdict freely and
voluntarily entered into by you?
JUROR: Yes.
COURTROOM DEPUTY: Juror Number 27, was the verdict
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Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 148 of 185
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
as published your verdict in the jury room?
JUROR: Yes.
COURTROOM DEUPTY: Is it still your verdict?
JUROR: Yes.
COURTROOM DEPUTY: Was the verdict freely and
voluntarily entered into by you?
JUROR: Yes.
COURTROOM DEPUTY: Juror Number 29, was the verdict
as published your verdict in the jury room?
JUROR: Yes.
COURTROOM DEUPTY: Is it still your verdict?
JUROR: Yes.
COURTROOM DEPUTY: Was the verdict freely and
voluntarily entered into by you?
JUROR: Yes.
THE WITNESS: Yes. Juror Number 35, was the verdict
as published your verdict in the jury room?
JUROR: Yes.
COURTROOM DEUPTY: Is it still your verdict?
JUROR: Yes.
COURTROOM DEPUTY: Was the verdict freely and
voluntarily entered into by you?
JUROR: Yes.
COURTROOM DEPUTY: That concludes the polling of the
jury.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: Okay. Thank you.
All right. Is there any other business for the jury
on forfeiture?
MR. FINLAYSON: Your Honor, if we could discuss that
briefly for one moment, I'm hoping not, but --
THE COURT: Okay. You mean you and your --
Okay. Why don't you-all step out for just a minute.
We need just a minute.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors exited the courtroom.)
THE COURT: Okay. Y'all can be seated.
MR. FINLAYSON: Your Honor, I just -- if we could
clarify or if you could help me clarify for -- for the record
or Mr. Delano, I think we would like to waive this issue in
light of the verdict. And I guess my question -- or what I'd
like to clarify is if the case were set aside on appeal, would
this issue then become ripe again?
MS. CONNORS: Yes, Your Honor. Because if the
verdict for some reason got set aside, then forfeiture is tied
to the verdict when it's criminal.
THE COURT: I believe that's right.
MR. FINLAYSON: Okay. Under that -- and that's my
understanding as well. So under that arrangement or that
recognition, then I don't think we need to go forward with the
forfeiture procedure.
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Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 150 of 185
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
THE COURT: Okay. Then I'm going to bring them back
in and excuse them. Is that okay?
MR. FINLAYSON: That's fine.
THE COURT: All right.
MS. CONNORS: Yes, Your Honor.
THE COURT: And, Ms. Kelley, will you call that
alternate and tell her she's released from everything.
COURTROOM SECURITY OFFICER: All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT: Okay. That's it for you. There was one
thing we thought we might have to ask you to resolve, but we
don't. So you-all are done with your jury service. You do
not need to call again next week.
I want to thank you for being here and for being on
time and for being so attentive and easy to get along with.
Okay?
If y'all step back there, I'm going to come back and
just say one more good-bye to you in just a moment. Okay?
For the parties -- y'all can be seated. We'll have
any post-trial motions within 45 days.
Is that enough time for either side?
MR. FINLAYSON: Yes, sir.
THE COURT: All right. I will enter judgment upon
the verdict, barring that.
And what about a sentencing date, Ms. Kelley?
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
COURTROOM DEPUTY: Give me one second. I have it.
Sentencing is set for November 3rd at 10:00.
THE COURT: Okay. Anything else that y'all want to
talk about?
MR. FINLAYSON: No. No, sir.
MS. CONNORS: No, Your Honor.
THE COURT: Okay. We are then in recess.
I'm going to go talk to the jury. You-all don't want
to talk to the jury?
MS. CONNORS: I usually don't.
THE COURT: I think usually the person who prevails
does not, but...
MS. CONNORS: Well, I never want to hear something
that I don't want to hear.
MR. FINLAYSON: I guess I would ask for --
sometimes -- I've run into them in the parking lot before
after a trial. Is it okay to talk to them if they want to
talk to me?
THE COURT: Yes, totally fine.
All right. Thank you so much. I thought that this
was a pleasant trial and I appreciate you-all working on it.
And we're in recess.
MR. FINLAYSON: Thank you, sir. Thank you.
(Whereupon, the proceedings were adjourned at 2:26
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Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 152 of 185
1229
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
p.m.)
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Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 153 of 185
1230
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 25, in the matter of
United States of America v. Carl Delano Torjagbo also known as
Karl Lucius Delano, case Number 1:22-CR-00171-MLB; that said
proceedings in connection with the hearing were reduced to
typewritten form by me; and that the foregoing transcript is a
true and accurate record of the proceedings.
This the 10th day of November, 2025.
_______________________________
/s/ Jana B. Colter, FAPR, RDR, CRR, CRC
Official Court Reporter
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Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 154 of 185
BY MR. FINLAYSON: [3] 1101/91108/6
1110/5
BY MS. CONNORS: [4] 1081/71096/1
1098/211100/25
COURTROOM DEPUTY: [26] 1218/7
1218/121221/111222/111222/16
1222/191222/241223/21223/71223/10
1223/151223/181223/231224/11224/6
1224/91224/141224/171224/221224/25
1225/51225/81225/131225/211225/24
1228/1
COURTROOM DEUPTY: [11] 1222/14
1222/221223/51223/131223/211224/4
1224/121224/201225/31225/111225/19
COURTROOM SECURITY OFFICER:
[14] 1081/31104/101108/11115/81118/9
1118/191169/131171/131213/12
1219/201220/161220/231226/91227/8
JUROR: [38] 1214/131214/181214/24
1215/21215/51222/131222/151222/18
1222/211222/231223/11223/41223/6
1223/91223/121223/141223/171223/20
1223/221223/251224/31224/51224/8
1224/111224/131224/161224/19
1224/211224/241225/21225/41225/7
1225/101225/121225/151225/18
1225/201225/23
JURY FOREPERSON: [6] 1219/24
1220/21220/41220/61220/111220/14
MR. FINLAYSON: [52] 1080/101080/24
1100/121101/71104/171104/211105/3
1105/221105/251106/31107/221108/5
1110/21110/41114/251115/131116/13
1117/81117/211117/251118/161118/25
1138/161169/161169/181169/211171/1
1171/41171/61171/171190/231193/12
1215/81215/131216/41216/91216/13
1216/171216/191216/211217/131218/1
1219/51222/41226/41226/121226/22
1227/31227/221228/51228/151228/23
MS. CONNORS: [42] 1080/111080/13
1080/181080/201095/241098/201101/5
1104/31104/81104/151107/181115/2
1116/81116/221116/241117/31117/12
1117/141117/181117/241118/131119/5
1134/241138/181139/51205/141215/14
1215/221216/11217/21217/51218/14
1218/231219/21219/91219/131219/18
1226/181227/51228/61228/101228/13
THE COURT: [111] 1080/51080/12
1080/161080/191080/221081/11081/5
1100/141101/61104/61104/91104/12
1104/161104/181104/221105/71105/23
1106/11106/71107/191107/231108/3
1109/211115/11115/31115/101115/21
1116/91116/151116/231117/21117/4
1117/91117/131117/161117/201117/22
1118/41118/111118/151118/171118/21
1119/21119/61134/251138/171138/19
1169/101169/151169/171169/20
1169/221171/31171/51171/71171/15
1190/191205/91211/121213/141214/3
1214/141214/191214/251215/31215/6
1215/121215/171215/241216/61216/11
1216/141216/181216/201216/221217/4
1217/71217/151218/21218/91218/15
1218/251219/31219/81219/111219/16
1219/191219/221219/251220/31220/5
1220/71220/121220/151220/181220/25
1222/21222/51226/11226/61226/11
1226/211227/11227/41227/61227/10
1227/231228/31228/71228/111228/19
THE DEFENDANT: [1] 1217/1
THE WITNESS: [3] 1100/171110/3
1225/16
$
$1.6 [4] 1151/141151/161166/17
1166/21
$1.6 million [4] 1151/141151/16
1166/171166/21
$10 [1] 1145/1
$10 million [1] 1145/1
$10,000 [4] 1133/231134/211166/6
1166/8
$100,000 [2] 1200/91200/10
$12 [1] 1140/2
$12 million [1] 1140/2
$120,000 [1] 1167/20
$150,000 [1] 1165/20
$2 [1] 1201/18
$2 million [1] 1201/18
$3 [7] 1141/41152/21153/241160/14
1162/211162/211178/11
$3 million [7] 1141/41152/21153/24
1160/141162/211162/211178/11
$3,459,835 [1] 1196/2
$3.3 [3] 1159/181162/91165/11
$3.3 million [3] 1159/181162/91165/11
$3.4 [6] 1140/181159/171195/31195/15
1196/241197/16
$3.4 million [6] 1140/181159/171195/3
1195/151196/241197/16
$3.5 [1] 1195/23
$3.5 million [1] 1195/23
$3.8 [5] 1090/171145/21145/131168/22
1207/12
$3.8 million [5] 1090/171145/21145/13
1168/221207/12
$332,000 [1] 1168/4
$40,000 [1] 1183/21
$45.8 [4] 1081/121145/61149/13
1168/23
$45.8 million [4] 1081/121145/6
1149/131168/23
$50,000 [1] 1200/8
$500 [2] 1145/81145/9
$500,000 [2] 1166/141166/20
$6 [8] 1163/251164/81164/111164/18
1167/91167/171167/221178/10
$6 million [8] 1163/251164/81164/11
1164/181167/91167/171167/221178/10
$6,007,300 [1] 1164/12
$69,000 [1] 1194/8
$7,000 [3] 1196/181196/201197/13
$800,000 [2] 1159/151201/19
$800,000-ish [1] 1159/15
$9 [1] 1161/23
$9 million [1] 1161/23
$9.1 [2] 1159/131160/10
$9.1 million [2] 1159/131160/10
$9.5 [16] 1142/231145/141147/10
1151/41151/171153/11155/241162/8
1162/221166/191178/91178/171179/4
1179/161180/61181/19
$9.5 million [16] 1142/231145/14
1147/101151/41151/171153/11155/24
1162/81162/221166/191178/91178/17
1179/41179/161180/61181/19
$9.9 [1] 1159/14
$9.9 million [1] 1159/14
$91,000 [1] 1164/19
$92,000 [1] 1145/9
'
'14 [1] 1196/20
'21 [1] 1196/14
'89 [1] 1190/16
'95 [1] 1190/17
-
-- being [1] 1171/7
-- both [1] 1098/24
-- but [1] 1113/5
-- civility [1] 1171/5
-- did [1] 1113/7
-- it [1] 1096/4
-- of [1] 1092/8
-- specific [1] 1109/12
-- to [1] 1096/12
-- what [1] 1109/14
-- when [1] 1087/7
-- with [1] 1117/22
-- you [4] 1087/91092/111100/11
1109/17
-- you're [1] 1086/25
-- your [1] 1088/13
/
/s [1] 1230/18
0
0540 [2] 1157/121158/7
1
1 percent [1] 1178/15
1.6 [1] 1167/6
10 [4] 1096/41118/71187/21187/14
10,000 [2] 1166/101167/5
100 [1] 1187/2
100 percent [1] 1178/13
101 [1] 1176/20
1040 [2] 1196/91196/9
108 [1] 1193/5
10:00 [1] 1228/2
10th [1] 1230/14
12 [1] 1215/1
12th [6] 1108/161185/191187/12
1187/131188/111194/13
1377 [4] 1155/41155/161158/21158/9
13th [2] 1196/111196/12
14 [1] 1223/18
1456 [1] 1078/23
15 [2] 1118/71154/6
15th [9] 1154/231156/131158/13
1189/151190/101192/201194/71207/10
1207/15
16 [4] 1092/171094/41094/101133/8
16th [1] 1153/15
17 [4] 1094/101111/251133/61177/1
171 [1] 1221/13
19 [4] 1146/221172/221172/221202/4
1949 [1] 1078/21
1975 [2] 1094/51094/16
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 155 of 185
1
1995 [1] 1190/16
1997 [2] 1092/211094/5
19th [1] 1153/20
1:22-CR-00171-MLB [2] 1078/41230/10
1:22-cr-171 [1] 1221/13
1:30 [1] 1212/22
2
20 [9] 1095/51098/81133/71133/8
1161/11177/21189/81208/171209/6
2002 [1] 1190/18
2005 [1] 1094/21
200A [2] 1195/171195/19
201 [4] 1196/81196/91197/61197/12
2013 [1] 1196/20
2014 [1] 1143/23
2015 [1] 1177/17
2018 [4] 1154/191155/51158/31158/9
2019 [3] 1083/141083/151084/7
201A [2] 1195/201195/20
2020 [27] 1081/111083/141083/16
1083/221083/251084/11084/231085/21
1145/41145/51151/101154/61154/23
1156/131157/151158/131158/161166/1
1168/241189/161190/101192/20
1195/221196/121207/101207/151209/7
2021 [28] 1086/21086/51086/91086/15
1086/201086/201087/31088/41088/4
1089/121089/121089/131103/11
1103/121140/171143/251151/11
1154/141154/201154/251155/91157/16
1157/211158/101158/191158/20
1167/151189/20
2022 [9] 1085/31108/161167/201167/21
1185/191187/131194/41194/71194/13
2025 [5] 1078/121080/31195/181195/21
1230/14
21 [1] 1224/1
215-1456 [1] 1078/23
21st [2] 1151/111151/23
22 [3] 1094/51094/81094/10
23 [2] 1177/11224/9
23rd [2] 1151/121196/14
24 [1] 1224/17
25 [4] 1078/121080/31222/11230/8
27 [1] 1224/25
29 [4] 1115/161115/251116/31225/8
29th [3] 1151/51151/91194/4
2:26 [1] 1228/25
3
3,373,441 [2] 1196/111196/17
3.4 [2] 1195/241195/25
3.8 million [1] 1149/14
300 [5] 1084/251085/101085/121089/4
1089/9
30303 [1] 1078/22
312 [4] 1084/251085/111089/41089/9
31st [1] 1143/23
35 [1] 1225/16
38 [1] 1166/9
38-year [1] 1207/16
3rd [1] 1228/2
4
40,000 [1] 1200/8
404 [1] 1078/23
45 [1] 1227/20
49 [1] 1191/22
493 [11] 1144/161144/241145/61146/12
1147/121168/211180/121191/31207/11
1208/51208/10
4th [1] 1143/25
5
50 [21] 1085/41085/71085/251086/5
1086/131086/211086/211088/41088/8
1103/71103/81103/201105/81109/9
1109/171140/131146/101187/21187/7
1192/121209/19
500 [1] 1144/24
500-employee [1] 1208/12
51 [1] 1191/23
51 percent [1] 1191/21
5114 [1] 1166/8
5th [1] 1151/9
6
6.5 [2] 1178/101197/20
60 [18] 1085/41085/71086/61086/14
1086/211086/211088/41088/81103/7
1103/81103/201105/81109/91109/17
1140/131146/111187/71209/19
600 [2] 1191/61191/7
6010 [4] 1091/171157/81158/21160/12
612 [3] 1110/91110/101146/13
6th [2] 1157/101157/11
7
7/25 [1] 1222/1
71 [1] 1089/23
737 [1] 1084/10
75 [1] 1078/22
75 percent [1] 1191/24
777 [1] 1084/11
787 [1] 1084/11
7th [2] 1154/201158/10
8
8332 [1] 1155/2
8th [1] 1094/16
9
9.9 million [1] 1160/11
90 [1] 1/4
92 [1] 1146/1
93,000 [1] 1146/1
940s [1] 1149/4
941 [1] 1148/8
941s [2] 1148/101149/4
9849 [1] 1210/9
A
abdominal [3] 1185/21185/121185/16
abets [2] 1135/71135/10
abetting [1] 1134/23
abide [1] 1107/7
ability [3] 1123/81147/11188/1
able [26] 1080/201088/151089/11096/9
1097/101098/171100/191109/61142/25
1144/151146/231147/61151/221155/17
1155/201158/11161/121161/131163/9
1167/41167/81167/101168/111208/12
1210/31219/6
about [168]
above [1] 1202/12
abs [1] 1199/1
absolutely [5] 1105/51174/141174/19
1182/241209/10
absolve [1] 1206/22
absurd [2] 1168/161206/24
accept [2] 1122/171143/25
accepted [1] 1161/8
accepting [1] 1154/7
access [5] 1143/11147/161155/20
1218/131218/15
accessed [1] 1157/3
accident [2] 1128/201136/9
accidentally [2] 1170/71217/10
accidently [1] 1097/21
according [3] 1114/91136/71175/17
account [54] 1142/251143/21143/4
1151/51151/91152/21152/31153/24
1154/21155/191156/41157/21162/19
1162/221163/51163/81163/111163/12
1163/131163/191163/191163/24
1163/251164/11164/61164/61164/7
1164/91164/111164/181164/251165/1
1165/171167/11167/91167/231168/5
1182/211182/211197/101197/11
1197/241199/41199/121199/151199/18
1200/131200/141200/141201/19
1201/241211/11211/21211/2
accountant [4] 1083/11089/191149/2
1150/7
accounting [1] 1149/21
accounts [13] 1131/161139/141140/3
1140/31140/41152/61168/111199/13
1201/171210/71210/141210/191210/22
Accra [4] 1094/151099/31099/31114/20
accuracy [1] 1206/1
accurate [9] 1088/171090/11097/5
1122/181145/181149/51159/231160/9
1230/13
accurately [3] 1086/251123/91123/9
acquired [1] 1135/23
across [1] 1115/17
act [11] 1121/61127/141127/141128/19
1129/161130/81130/101135/41135/4
1202/151211/14
acted [4] 1127/181128/121129/21
1136/7
acting [3] 1094/11096/51135/6
action [5] 1078/41126/221128/22
1177/251221/13
actions [1] 1169/2
activities [3] 1081/161132/111149/21
activity [16] 1131/31131/51132/16
1132/211132/221133/11133/21133/3
1133/221134/111134/121136/21141/9
1162/161165/121203/5
acts [5] 1135/91135/121135/151136/6
1136/9
actual [4] 1102/151122/61148/21167/7
actually [45] 1081/171082/151085/14
1088/31088/51088/91112/41112/5
1112/81113/211127/111127/231129/13
1130/61147/71147/191148/231148/24
1149/81149/221153/111157/231158/12
1161/211162/111173/171174/121178/6
1178/151179/31180/11180/31180/24
1183/241190/221191/41192/81192/17
1194/61205/11205/201206/81206/14
1209/81209/22
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 156 of 185
A
added [1] 1080/15
additional [5] 1120/31138/161208/11
1210/91215/15
address [11] 1154/171155/11155/5
1155/81155/131155/181160/241161/2
1161/21161/71161/10
addressed [1] 1154/15
addresses [1] 1161/9
adjourned [1] 1228/25
Administration [5] 1093/21095/13
1143/121175/221176/1
Administrator [1] 1078/20
admit [1] 1197/23
admits [1] 1197/6
admitted [10] 1121/121121/131140/12
1142/201149/91153/61198/21198/2
1198/71218/18
admittedly [1] 1194/10
Adrienne [1] 1168/7
advantage [2] 1107/211147/9
advised [1] 1169/7
affairs [1] 1121/7
affect [3] 1082/61132/111137/2
affected [1] 1081/19
affecting [1] 1081/16
affects [4] 1131/211131/241132/6
1134/6
afford [1] 1167/5
afraid [1] 1209/21
Africa [17] 1081/191081/221082/5
1085/91085/131100/21100/51100/18
1100/231101/251102/101113/211114/1
1114/41147/171175/151184/21
African [3] 1101/21113/141114/7
after [48] 1/71080/141084/71084/16
1084/191085/221085/231088/31091/11
1091/111097/181097/251102/10
1116/241120/11121/31124/91138/1
1151/51151/81151/241152/111153/9
1153/161155/91155/91155/241157/9
1162/81162/81163/231164/111165/21
1169/21169/71177/131186/71187/13
1188/131188/221190/51200/181201/9
1201/201201/201213/21213/61228/17
afterwards [1] 1117/6
again [60] 1088/111088/211089/11
1095/11098/31124/161129/161129/23
1130/91133/91136/11141/201143/1
1143/81144/11145/11145/101146/10
1146/161147/141147/151147/16
1148/151150/51150/91153/221155/16
1156/201164/21165/211167/111168/4
1168/131170/201171/221171/251177/1
1183/61184/181187/121189/91192/19
1192/231193/61198/151201/111202/1
1202/31202/191202/221203/181203/20
1204/71209/101209/121210/81216/10
1220/251226/171227/13
against [4] 1120/101120/161124/17
1141/1
age [5] 1184/181184/181184/19
1184/201184/22
agent [22] 1082/81082/101082/12
1083/71085/31085/71086/31086/11
1089/141099/71103/141108/81108/21
1135/51135/121146/111148/181153/4
1185/181186/191187/11209/13
Agent Caruana [18] 1082/81082/10
1083/71085/31085/71086/31086/11
1089/141099/71103/141108/81108/21
1146/111153/41185/181186/191187/1
1209/13
Agent Fowler [1] 1148/18
agents [5] 1173/201185/231186/10
1186/131187/14
aggressive [1] 1217/18
ago [14] 1089/101098/81108/19
1128/251129/91129/161140/221161/1
1177/191185/191194/131208/171209/7
1209/20
agree [4] 1120/131125/101137/23
1215/25
agreed [4] 1121/171209/181212/5
1221/5
agreement [1] 1138/3
ah [6] 1158/61177/101188/21189/21
1190/41190/8
ah-ha [6] 1158/61177/101188/21189/21
1190/41190/8
ahead [14] 1081/61108/41110/11139/4
1146/241152/151156/81171/161205/13
1213/81214/11216/21219/101221/10
AI [1] 1/13
aid [1] 1137/14
aided [1] 1078/18
aiding [1] 1134/23
aids [2] 1135/71135/10
ain't [6] 1180/21181/11181/171185/12
1196/211197/18
aircraft [1] 1132/8
airplane [3] 1087/191088/151088/19
Akpene [1] 1175/9
all [242]
allege [1] 1125/7
alleged [12] 1081/111082/21125/21
1127/211127/221128/11129/241130/4
1130/61136/21142/211144/12
allegedly [1] 1135/23
alleges [1] 1162/20
allow [1] 1137/17
allowed [3] 1100/131208/231209/5
allows [1] 1132/3
almost [5] 1144/251153/221154/10
1202/111217/23
alone [1] 1137/11
along [5] 1080/211187/71194/141203/2
1227/15
already [21] 1084/191109/201128/21
1133/41153/191153/241155/101156/20
1162/121163/151164/181165/221167/7
1175/101175/171175/171175/18
1175/181198/241210/181214/8
also [32] 1078/61085/221086/91096/9
1115/171130/11131/151132/51132/9
1134/191135/111142/191144/61145/4
1146/121146/161147/231148/31148/16
1149/121150/61150/161153/111157/11
1157/191160/131167/141193/24
1199/181201/171214/111230/9
alternate [2] 1214/51227/7
alternates [1] 1214/8
alternative [2] 1125/61125/11
alternatives [1] 1125/8
always [4] 1080/201186/61187/17
1197/21
am [3] 1083/111161/21214/23
AMERICA [9] 1078/31142/171165/17
1168/51175/121199/41199/91199/15
1230/9
American [2] 1146/201146/20
amount [17] 1086/121086/161087/1
1087/221088/251089/61090/181091/6
1108/211109/141145/121146/11146/6
1148/91159/241186/201196/10
analysts [1] 1173/20
Andrea [23] 1082/81082/251083/4
1089/151098/51098/71098/91098/13
1098/151110/161111/51140/91149/3
1149/151149/201150/51156/251160/18
1161/141168/181187/161188/121189/4
Anglicized [1] 1175/13
another [32] 1080/141089/41094/21
1095/61098/41101/161115/31135/5
1135/61135/101135/151138/31142/12
1143/41152/31157/181157/181157/19
1160/141161/51163/111163/191165/13
1167/91167/191200/101201/191202/1
1211/11217/111217/241219/11
answer [30] 1082/181085/51085/6
1085/81086/81086/211086/221087/4
1087/241088/61088/101088/171089/1
1089/121100/151100/161100/17
1108/241108/251109/21109/71109/8
1109/91109/221109/231123/121187/3
1187/101209/201222/9
answered [7] 1086/101096/251097/3
1104/41106/81106/131106/15
answering [2] 1144/71209/22
answers [5] 1089/21109/41146/10
1209/121209/24
any [88] 1/91080/81084/151089/20
1091/131102/31111/21111/91111/15
1113/71114/11115/11115/121116/7
1116/171118/41118/111118/231119/3
1120/101120/151120/201120/25
1121/211121/211122/201123/31124/6
1126/211131/111131/171131/20
1131/211131/231131/231132/11132/6
1132/61132/71132/121132/241134/9
1135/41137/21137/81137/151137/20
1138/131140/91140/101140/121140/15
1144/211146/81148/191151/181152/6
1156/21158/221159/51159/151160/6
1163/71168/11170/231181/11183/7
1188/201190/111191/241191/24
1194/231194/251195/11195/51201/9
1201/101201/151206/31207/151212/8
1212/201213/191215/61216/91217/6
1226/21227/20
anybody [16] 1107/171114/71114/22
1152/221169/101173/161176/24
1188/161189/51189/241190/11200/24
1200/251201/11212/151214/14
anyone [8] 1082/211096/51127/23
1130/71133/131137/251148/241168/23
anything [33] 1090/181090/191104/5
1116/11121/141121/201121/231141/16
1141/191144/131146/161148/20
1151/191155/31167/21167/241172/17
1172/171174/141174/211174/21
1176/241178/141180/11182/241183/12
1185/151203/11213/191215/71217/22
1218/161228/3
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 157 of 185
A
anyway [3] 1152/201185/241201/8
anywhere [1] 1084/2
apologize [9] 1104/151162/111179/8
1216/171216/191216/211217/13
1217/131218/1
appeal [1] 1226/16
appear [1] 1123/11
APPEARANCES [1] 1078/24
applicant [2] 1096/51143/16
applicant's [1] 1143/13
application [29] 1082/231091/5
1094/121094/151094/231097/15
1110/101110/131141/241142/20
1143/141143/181144/61146/121147/21
1148/21150/21152/251153/31153/10
1153/121154/81156/51179/131180/21
1206/61206/151206/171206/19
applied [1] 1082/23
applies [1] 1135/1
apply [4] 1083/11091/141134/23
1138/22
appreciate [6] 1172/11172/21172/2
1172/31215/11228/21
approach [1] 1195/6
appropriate [1] 1215/23
approve [3] 1178/231179/21206/6
approved [6] 1117/91153/191179/3
1179/111179/161180/3
approximately [1] 1178/15
April [5] 1151/91151/111151/12
1151/231196/14
April 21st [2] 1151/111151/23
April 23rd [2] 1151/121196/14
are [90] 1/81082/141088/191091/14
1096/91096/91097/21097/161097/18
1098/241102/151111/21111/101111/13
1111/151114/251115/61117/201119/9
1121/81121/91121/171121/171126/7
1128/61130/151130/221133/101133/17
1137/51137/191137/241138/91141/7
1141/251142/81142/81142/181143/6
1147/171148/91150/231152/161156/19
1156/211158/221159/41159/221161/9
1161/101161/111164/241165/231166/3
1171/251175/221175/231176/41180/9
1180/201182/111184/221186/14
1186/251188/41188/61188/211189/23
1190/251191/11191/21191/21191/11
1194/31196/21202/31204/161207/24
1208/41208/91212/181213/181214/5
1214/121218/251219/21219/171219/23
1227/121228/7
aren't [1] 1172/11
argue [3] 1106/91138/211178/5
argued [5] 1192/21192/221200/19
1208/211208/21
argument [4] 1106/21187/151190/24
1190/24
arguments [5] 1116/51119/101120/2
1138/201171/21
armed [1] 1186/13
Army [2] 1186/21186/2
around [9] 1081/181110/91140/6
1150/101153/191158/111174/61186/15
1187/23
arrangement [1] 1226/23
arrangements [1] 1194/19
arrest [2] 1083/31209/22
arrested [5] 1082/131124/91185/18
1186/121186/13
arriving [1] 1121/24
as [100] 1078/61083/161097/251109/4
1110/121115/191115/241117/41117/16
1119/251120/121120/141121/11
1121/191122/41122/171123/11123/22
1124/61125/101125/101125/141125/14
1125/251127/21128/251129/81130/3
1130/131130/201133/141137/141139/8
1139/151139/221140/211140/24
1141/111141/171145/201146/15
1152/171153/51154/51161/81161/8
1163/131164/41166/231169/71169/24
1170/61170/151170/161170/251177/22
1178/41182/11182/41191/151193/23
1199/21200/61200/151203/21209/2
1211/141211/211211/221212/10
1212/101220/31220/51220/101220/20
1221/131221/141221/151221/17
1221/181221/191221/201221/21
1221/221221/231221/241221/25
1222/111222/191223/21223/101223/19
1224/21224/101224/181225/11225/9
1225/171226/231230/9
Ashanti [1] 1085/11
aside [3] 1207/211226/161226/19
ask [39] 1086/161089/161089/18
1089/201090/31092/221098/241099/14
1105/161105/161106/71106/101116/16
1122/241123/151123/171144/191146/1
1147/61147/181149/251152/171172/21
1181/121181/141187/131193/81194/16
1196/71198/151198/151212/81220/9
1221/21221/81222/61222/91227/11
1228/15
asked [40] 1082/211086/31088/8
1088/251089/171089/181099/81099/10
1099/161099/181099/221101/19
1103/161104/31105/21106/81106/13
1106/141108/131108/211109/10
1110/161111/201150/191174/121181/5
1181/61181/81184/251184/251185/1
1186/151187/61188/231192/21197/1
1197/71208/21209/171221/8
asking [7] 1086/121087/251089/21
1101/181103/131103/181106/22
asks [1] 1197/6
aspect [2] 1141/91162/15
asserts [2] 1122/51122/6
assessing [1] 1122/24
assets [4] 1126/101139/121177/20
1210/15
assigned [1] 1095/7
associate [1] 1135/13
associated [3] 1135/161154/181157/24
assume [3] 1110/251121/201150/7
assuming [1] 1219/23
Atlant [1] 1221/12
ATLANTA [4] 1078/21078/221080/3
1230/6
attached [1] 1/5
attaching [1] 1/8
attempt [6] 1084/91126/11157/12
1157/181157/191193/16
attempted [7] 1126/91127/251133/18
1157/91160/131163/71208/25
attention [3] 1138/241172/21206/3
attentive [1] 1227/15
attest [1] 1146/17
attestation [1] 1143/19
attestations [1] 1143/13
attesting [1] 1144/6
ATTORNEY [2] 1079/21170/3
audio [2] 1218/91218/10
August [2] 1167/151194/7
authorized [1] 1179/23
authorizes [1] 1135/12
auto [1] 1152/8
automatic [1] 1185/23
available [5] 1082/31082/41102/2
1209/51209/11
average [1] 1145/9
averaging [1] 1149/14
aware [2] 1148/41216/9
away [6] 1112/121161/51168/16
1176/221201/231213/9
awhile [3] 1083/131201/11201/5
B
baby [1] 1113/5
back [58] 1080/241083/131094/21
1109/251110/251111/131116/21
1117/111118/61119/191120/171124/16
1147/21156/31156/71158/11162/11
1169/81171/221172/221174/61178/9
1184/21185/201186/81186/161186/25
1188/21188/111192/241193/181193/19
1195/201198/181198/191200/91200/10
1202/211203/101205/61205/161212/12
1212/251213/81213/101213/201213/20
1214/111214/171214/191214/23
1217/201218/61218/181220/91227/1
1227/171227/17
backed [1] 1178/13
bad [9] 1101/251175/61176/201183/14
1185/81197/181201/31202/21206/24
bag [2] 1183/211214/18
balance [4] 1156/31167/21195/21
1195/24
bank [91] 1083/31090/131124/21
1126/11131/51132/21132/131133/3
1133/251134/71134/151139/81139/13
1140/21140/31140/251141/11141/17
1142/171142/171142/241142/251143/4
1143/71150/121151/41151/51151/9
1151/171153/141155/191155/24
1155/251156/61156/81156/101158/12
1162/191162/221163/81163/111163/19
1163/191163/201163/251164/51165/9
1165/171165/191167/11167/91167/23
1168/51168/71168/251176/61178/8
1178/81178/161178/171178/191179/4
1179/111179/131179/211181/14
1181/221182/181182/221183/71183/16
1190/21193/171194/11197/81197/21
1199/41199/91199/151205/21205/23
1206/111206/221206/231207/31207/4
1210/21210/41210/71210/221211/7
bank's [1] 1211/2
banks [4] 1142/171177/61180/16
1180/19
barring [1] 1227/24
based [19] 1090/71090/71091/9
1093/141115/161120/81121/21144/4
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 158 of 185
B
based... [11] 1147/101149/51153/3
1153/51153/61156/151165/161167/13
1168/191191/191204/25
basic [1] 1107/17
basing [1] 1180/20
basis [1] 1086/8
bastion [1] 1171/25
bathroom [2] 1116/141169/16
be [138] 1/21/31080/51080/141080/20
1081/51085/151085/191086/21088/6
1088/141089/11094/51094/241095/17
1098/171100/131102/21102/151103/9
1107/251107/251107/251108/31109/4
1109/61110/61110/121113/31115/10
1116/211118/11118/61118/71118/8
1118/211119/131120/81120/91121/6
1122/31124/181125/61126/61127/4
1127/241128/51128/151129/51130/11
1130/181130/211132/51132/91133/15
1135/41135/51136/161136/231137/10
1137/171137/221139/211143/14
1144/181144/211146/41146/51146/23
1147/41147/61149/81154/111154/12
1154/211155/111155/131155/18
1155/201156/161159/161160/91160/25
1161/91161/121161/191161/241162/2
1162/51162/61165/61166/61167/4
1167/101168/111169/151170/14
1171/151173/31177/171179/91180/25
1182/41182/71183/161184/251185/11
1190/91191/201192/11195/241195/24
1197/71198/161201/61203/121203/25
1205/251207/181207/201208/12
1208/131208/201209/101209/131210/3
1213/161214/31214/121215/131215/23
1216/231219/61219/221220/181221/8
1226/111227/19
beat [1] 1189/16
because [93] 1082/31082/131084/1
1084/41085/151085/221085/231086/1
1086/151088/61089/161090/31090/8
1091/21093/41093/201094/11094/10
1095/191097/101100/211102/21102/4
1105/41105/181107/11109/51110/11
1116/21116/161116/181123/251128/19
1138/71138/71138/251143/11145/10
1150/11153/141155/161155/191156/7
1157/21157/201157/231159/91159/10
1161/61161/161163/71165/91165/14
1166/121167/121168/91172/101172/22
1177/161179/151180/171181/41183/7
1183/161185/11185/41185/131189/1
1190/181190/251190/251192/231194/4
1194/101194/121195/151197/11197/5
1198/221200/201201/41206/241207/19
1208/241209/21209/131209/201214/9
1216/111217/161217/171218/21
1226/18
become [3] 1138/51153/211226/17
becomes [1] 1115/25
been [45] 1082/131083/121093/6
1098/21113/101114/31121/81137/12
1139/251144/51149/61151/11151/22
1152/231154/221155/101156/21156/4
1156/211160/81160/221162/51163/9
1166/91166/111167/81171/191172/7
1180/71180/121182/251194/51197/2
1197/171197/171201/71207/141208/25
1209/11209/21212/221215/151217/23
1218/181219/11
before [38] 1078/111081/211082/4
1084/41095/71095/111096/71097/1
1115/201117/51119/131121/111122/5
1125/241135/251138/201140/11144/1
1144/51145/191145/221151/111151/13
1154/231158/131166/131166/23
1189/151190/71190/101190/121190/13
1197/171205/101207/101209/15
1219/151228/16
begin [7] 1119/121120/41139/151164/5
1164/71213/31213/21
beginning [2] 1086/181141/13
behalf [3] 1096/61118/251170/4
behind [3] 1140/11149/211186/8
being [15] 1084/41105/21124/91141/25
1142/21143/81147/41148/101161/11
1162/151170/211171/71227/141227/14
1227/15
belief [10] 1136/151136/161136/20
1156/121173/31173/41173/61204/10
1204/231207/8
beliefs [1] 1138/6
believe [20] 1100/121122/181122/20
1124/61138/221156/131158/181160/18
1161/31161/141176/101176/141195/13
1197/141203/121203/131206/21212/21
1216/41226/21
believed [2] 1144/41188/18
bending [1] 1107/20
benefit [1] 1160/1
best [1] 1188/1
bet [2] 1181/131182/12
better [3] 1117/251176/221188/25
between [7] 1091/41122/121131/15
1132/161132/171170/11171/25
beyond [43] 1120/81120/211120/24
1121/51121/91125/91125/191126/7
1127/241128/61130/221133/171135/19
1136/141139/71139/101143/101169/6
1172/61172/91173/21173/121183/18
1189/101202/71202/101202/111202/12
1203/171203/201203/221203/24
1203/251204/31204/41204/61204/8
1204/101204/111204/121204/20
1211/101215/15
Bible [1] 1107/13
big [6] 1164/181174/61177/91184/19
1184/191199/21
bigger [1] 1177/21
bill [2] 1194/71201/6
billions [1] 1150/23
bills [1] 1201/6
binding [2] 1121/141151/22
birth [30] 1091/201091/221092/4
1094/191094/241095/181095/19
1095/201096/101096/151097/14
1098/251100/71100/211100/221100/23
1100/241101/21112/101112/141112/21
1112/231113/11113/141114/71114/14
1114/161175/211183/101189/7
birthdate [1] 1112/7
bit [11] 1095/171144/101169/11
1174/121193/51193/141197/71198/24
1205/151206/101212/21
blacked [1] 1117/23
blah [3] 1174/31174/31174/3
block [1] 1118/3
blow [1] 1217/20
BMW [2] 1141/121167/20
BOA [1] 1199/4
boarding [2] 1207/171207/23
bob [1] 1140/5
body [1] 1170/1
Boeing [1] 1084/10
Boeing's [1] 1087/18
boil [1] 1177/25
bolster [1] 1207/1
bonds [1] 1131/18
bonus [1] 1197/21
book [1] 1107/13
born [14] 1094/151094/161096/13
1098/241099/221100/181113/81113/20
1113/211114/111114/121114/13
1114/151175/9
both [12] 1093/141098/241098/25
1107/231145/31156/191157/131158/7
1211/71215/241217/211220/19
bottom [2] 1180/231207/21
bought [12] 1088/241172/131174/6
1174/71198/71198/91199/201199/20
1199/221200/161200/171217/2
Bourne [1] 1145/22
box [1] 1131/17
break [8] 1115/41116/141116/251118/8
1169/121169/161205/101205/11
briefly [2] 1169/81226/5
bring [16] 1080/231105/231107/4
1107/191116/61118/171146/231171/9
1179/121179/171180/21184/121205/2
1213/101219/191227/1
bringing [2] 1170/41212/11
broadly [1] 1124/19
brought [4] 1107/11112/81119/19
1179/17
BROWN [9] 1078/111145/231172/20
1173/51181/71181/91181/111181/19
1181/19
Bruce [3] 1145/231181/121181/20
BS [1] 1182/5
buddy [1] 1174/23
buffaloed [1] 1104/13
build [2] 1174/191174/20
bunch [5] 1088/241111/201185/9
1194/21198/1
burden [9] 1120/231138/251182/7
1182/81203/61203/71204/161204/25
1205/23
buried [2] 1097/81208/10
BURTON [2] 1079/41079/5
business [16] 1130/121132/161136/20
1143/121154/51156/161156/171163/17
1165/231165/241165/251191/11191/2
1198/101217/91226/2
businesses [5] 1132/171132/18
1132/181146/201198/6
busy [2] 1084/41084/12
buy [10] 1119/151163/51163/61166/16
1166/221167/181182/111182/161183/3
1200/1
buying [7] 1167/151169/31169/31169/4
1169/41174/111201/8
buys [6] 1167/191167/211168/6
1199/161199/161199/17
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 159 of 185
B
bye [1] 1227/18
C
cable [1] 1201/6
calculating [2] 1091/71145/11
call [17] 1085/111085/171085/21
1085/241085/251086/61086/171102/16
1112/101120/51193/41193/131194/15
1209/251222/81227/61227/13
called [6] 1124/171174/41182/19
1187/81190/31214/12
calling [1] 1154/1
came [24] 1081/211083/131093/5
1094/51094/111111/211111/241132/21
1132/221134/141150/151150/17
1150/211151/251151/251160/181168/1
1175/151183/21188/221192/91200/8
1200/101219/13
can [85] 1080/51081/51085/61088/21
1095/21095/31098/201099/131100/11
1100/151103/241103/241104/19
1104/251105/31105/121105/121105/13
1105/171106/71106/91106/101106/17
1106/181107/121107/131107/13
1107/251107/251108/31115/101115/11
1115/231116/61117/11118/211119/22
1121/111125/131125/131126/61128/5
1130/211132/51132/91133/151135/4
1152/151159/181169/151171/23
1179/241182/41186/171186/181186/18
1189/241189/241189/251189/251190/1
1193/101201/181202/151204/16
1204/221204/221204/231210/11
1212/251213/31213/51213/51213/6
1213/131213/151214/31214/201214/21
1215/11218/201219/31220/181226/11
1227/19
can't [16] 1104/181105/181106/20
1106/211136/181147/21173/91187/3
1187/101197/241197/251204/24
1213/141213/181214/141218/3
cannot [7] 1087/211136/161156/11
1156/121173/31173/71186/23
cap [3] 1144/241145/11208/12
capacity [3] 1127/91129/111205/19
Cape [1] 1100/18
capital [4] 1170/151170/161170/18
1170/20
caption [1] 1170/5
car [7] 1167/211168/101176/161200/16
1200/171201/81201/12
Car Delano [1] 1176/16
card [7] 1092/221093/121095/141096/6
1112/161112/241175/20
cards [2] 1152/91176/25
care [3] 1124/111152/211179/15
carefully [3] 1121/31172/211221/4
carelessness [2] 1136/181173/9
CARL [12] 1078/51139/81154/161158/4
1164/211175/91176/191200/171201/9
1211/221221/151230/9
Carl Delano [1] 1176/19
Carl Torjagbo [4] 1139/81164/21
1200/171201/9
Carpenter [5] 1153/131153/231178/7
1178/191179/20
carried [2] 1126/81127/25
carry [5] 1126/11126/21126/91128/4
1128/16
carrying [1] 1130/4
cars [5] 1152/121163/61168/11185/16
1201/12
Caruana [21] 1082/81082/101083/7
1085/31085/71086/31086/111089/14
1099/71103/141108/81108/211146/11
1153/41185/181185/221186/191186/22
1187/11188/111209/13
case [40] 1094/131116/31116/71119/4
1119/71119/141119/251121/41121/19
1121/211123/61123/141124/51135/22
1137/61137/251138/21138/81138/10
1138/111140/61141/131144/181170/2
1170/181172/61172/91172/171173/10
1177/191177/221190/201190/22
1192/241193/141202/151214/15
1214/221226/161230/10
case Number [1] 1230/10
cases [1] 1174/1
cash [10] 1151/161152/111167/1
1182/171182/181182/191183/221192/6
1192/91210/24
cashier's [4] 1210/241210/251210/25
1211/1
catch [1] 1201/2
categories [1] 1140/25
caught [1] 1163/9
caused [3] 1101/211101/251128/14
caution [3] 1124/101137/41212/13
caveat [1] 1173/18
celebrities [1] 1208/9
cents [1] 1192/12
certain [6] 1121/171125/171130/19
1133/131141/81165/3
certainly [2] 1168/231209/9
certificate [15] 1095/201096/101100/22
1100/221100/231100/241101/21112/23
1113/11113/141114/71114/141114/16
1131/181230/1
certification [4] 1143/191180/211190/6
1206/16
certifications [1] 1087/10
certified [3] 1/141147/211179/16
certify [2] 1144/151230/6
certifying [1] 1143/16
chain [1] 1122/8
chance [3] 1116/251119/101139/2
change [21] 1083/241091/31091/5
1091/61092/41095/161095/171114/22
1138/41155/81155/181164/121175/13
1177/91177/191185/151194/211201/2
1201/41201/51216/6
changed [22] 1084/41090/81091/2
1091/131117/141175/31175/31175/16
1175/171176/191176/231194/22
1198/251200/181200/201200/23
1200/241200/251201/11201/71201/7
1201/9
changes [4] 1116/171118/111177/11
1177/13
changing [1] 1112/12
charge [11] 1120/161124/221124/24
1125/11125/131125/231128/21136/11
1146/41172/241202/5
charged [7] 1135/41135/241136/5
1136/71136/91137/51156/19
charges [8] 1124/171124/211125/16
1125/251136/241140/251170/41211/10
charging [1] 1133/11
Charlie [4] 1145/231173/51181/7
1181/19
Charlie Brown [3] 1173/51181/7
1181/19
charm [1] 1157/25
chart [4] 1198/221198/221199/10
1200/6
Chase [49] 1139/81141/11141/17
1142/91142/241143/131143/181149/7
1151/41153/91153/161153/211154/1
1154/31154/61154/201155/191155/24
1155/251156/41158/121162/81162/19
1162/221163/81163/81163/131165/9
1166/241167/131168/251178/81178/8
1178/161178/171179/41179/111179/13
1179/211194/11197/211199/111205/2
1205/231206/21206/41206/71206/10
1210/4
Chase Bank [24] 1139/81141/11141/17
1142/241151/41155/191155/241155/25
1158/121162/191163/81168/251178/8
1178/81178/161178/171179/41179/11
1179/131179/211197/211205/21205/23
1210/4
cheat [2] 1126/221128/23
check [30] 1143/31151/121151/12
1152/21159/251162/211162/211162/23
1163/11164/41164/41165/111167/8
1167/251186/171186/181186/181195/3
1196/51196/131196/141196/151196/21
1197/11197/31197/121197/131210/18
1210/251211/24
checked [2] 1220/191220/20
checking [1] 1206/8
checks [4] 1132/21132/21210/24
1211/1
China [5] 1110/221110/251110/25
1111/31111/16
Chinese [2] 1110/221192/6
choice [3] 1092/141092/161092/19
choose [1] 1211/14
choosing [1] 1216/3
circumstances [7] 1082/91088/1
1089/71122/91124/141188/81188/10
circumstantial [4] 1122/41122/8
1122/131122/14
cite [1] 1/5
citizens [1] 1110/11
city [1] 1096/13
civility [1] 1171/5
civilized [1] 1171/7
claim [2] 1106/231167/24
claimed [9] 1143/221145/101148/15
1156/241159/111159/121159/14
1159/241165/25
claiming [1] 1145/5
claims [2] 1105/201159/19
clarify [3] 1226/131226/131226/16
clarity [1] 1088/2
class [1] 1184/22
clawback [1] 1156/3
clean [2] 1152/51218/13
clear [15] 1110/61143/181152/51154/6
1160/61168/121184/251185/111192/1
1193/231200/61200/141207/41208/20
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 160 of 185
C
clear... [1] 1210/1
clearly [8] 1096/41123/121146/12
1147/141149/41149/61153/31190/12
client [3] 1106/201107/21115/22
close [15] 1081/91085/151085/19
1102/151116/121125/201133/61145/1
1174/121174/141182/21182/191185/18
1208/111218/21
closer [1] 1204/2
closes [1] 1212/22
closing [9] 1106/21106/111116/4
1119/101120/21138/201167/71171/21
1216/23
closings [1] 1116/11
CM [2] 1/21/3
CM/ECF [2] 1/21/3
coconspirators [1] 1173/24
coin [1] 1132/1
college [2] 1087/121095/1
COLTER [3] 1078/201230/41230/18
combination [1] 1167/10
come [19] 1081/11088/171089/9
1090/181092/11098/171109/61112/3
1131/41155/171169/81171/221173/21
1182/31188/191212/251213/201214/23
1227/17
comes [7] 1166/131174/11174/5
1175/101178/191183/211199/11
coming [14] 1149/151161/111164/17
1167/161168/111175/121184/41184/5
1187/221187/251189/41192/111192/24
1217/6
commerce [9] 1128/161131/211131/24
1132/71132/111132/121132/151134/6
1142/14
commingled [1] 1164/8
commingles [1] 1165/5
commingling [1] 1163/23
commit [10] 1135/81136/51136/6
1136/81177/201201/211202/231202/24
1208/181209/6
committed [10] 1125/61125/171125/20
1136/91142/31142/61209/81210/2
1210/21211/8
committing [4] 1098/11134/151134/17
1134/22
common [21] 1121/31122/21139/18
1139/221144/21145/211146/31159/19
1175/241175/251176/21176/51176/6
1177/31181/201184/61195/121195/13
1195/141197/141201/21
commonly [2] 1130/201133/14
communicate [1] 1212/17
communication [1] 1128/15
communications [7] 1128/41130/8
1130/101130/121130/131142/13
1156/21
companies [2] 1146/231200/11
company [19] 1091/81142/221143/22
1144/41144/41147/51154/111154/12
1154/221158/231160/101165/16
1165/191167/231167/241174/81189/15
1190/91191/18
compared [1] 1165/4
complained [1] 1192/22
complaining [1] 1193/18
complete [3] 1136/111172/241202/4
completed [1] 1120/1
completely [2] 1147/61159/13
complicated [1] 1204/20
computer [10] 1078/181117/11157/3
1161/171161/191161/221162/41197/1
1197/31219/14
computer-aided [1] 1078/18
conceal [15] 1131/81141/91162/15
1172/171175/41177/201185/61199/2
1199/241200/51200/51200/191200/22
1202/251203/1
concealing [6] 1172/171174/211176/24
1198/251199/11199/2
concealment [8] 1124/241130/16
1141/71162/131166/51198/231200/15
1210/16
conceals [2] 1127/51129/6
concerned [2] 1122/31147/4
concerning [1] 1121/1
concerns [1] 1080/8
concludes [1] 1225/24
conclusion [1] 1115/24
conclusions [1] 1122/3
concrete [1] 1190/11
conduct [2] 1130/251131/10
conducted [1] 1130/24
confident [1] 1144/21
confidently [1] 1144/15
confirm [1] 1106/11
confirmed [1] 1147/16
confronted [1] 1140/21
confuse [2] 1100/51170/23
confused [1] 1080/12
confusion [1] 1100/7
conjunctive [1] 1125/7
connection [1] 1230/11
Connors [2] 1079/31138/17
consider [10] 1121/111122/161124/10
1124/131136/11136/31136/251137/8
1188/71188/9
considered [3] 1121/41180/41180/5
considering [2] 1122/11138/1
consistent [2] 1155/21163/3
constantly [2] 1140/201140/21
consternation [1] 1205/12
constitute [1] 1136/21
consulting [1] 1151/10
contact [2] 1098/151111/3
contract [4] 1151/131151/221163/16
1166/24
control [2] 1131/91162/17
controlled [3] 1126/31140/31143/5
convenience [2] 1092/61211/18
convenient [5] 1139/201139/241150/9
1161/51168/15
conveniently [1] 1098/13
convict [1] 1125/13
conviction [1] 1125/10
convinced [4] 1121/81121/101138/5
1140/16
convincing [1] 1121/6
copies [3] 1117/101119/191119/23
cops [1] 1186/3
copy [3] 1117/221124/191172/21
Corporation [1] 1132/14
correct [16] 1082/81083/51083/16
1090/111091/21091/201092/151092/24
1095/21096/71096/171096/231143/17
1147/221206/171206/18
corrected [4] 1094/241095/221112/21
1155/12
could [51] 1082/91084/151085/19
1085/191086/251087/211095/231100/5
1101/111103/251106/31110/121116/14
1116/251144/211146/171146/241148/3
1148/61150/181151/151152/61153/16
1155/181157/151159/61159/71160/6
1163/41164/61165/81167/121188/19
1191/121204/231206/61206/111206/19
1206/191207/81207/91207/111207/11
1207/121207/181208/181214/25
1219/151226/41226/121226/13
couldn't [8] 1083/241085/141089/8
1089/91109/51145/171145/171210/21
counsel [4] 1141/131171/181208/2
1209/11
count [30] 1124/181124/191124/21
1124/221124/241125/11125/251136/24
1156/231156/241156/251162/20
1164/151165/131167/161168/31168/3
1211/211220/31220/51221/141221/17
1221/181221/191221/201221/21
1221/221221/231221/241221/25
Count Five [1] 1164/15
counted [1] 1110/12
countries [5] 1082/41082/51082/5
1082/61184/8
country [9] 1111/221132/11175/10
1175/121175/151184/51194/111198/11
1204/13
counts [21] 1115/181117/171124/17
1125/231128/21130/151133/51133/9
1134/231135/11141/21141/101156/19
1169/61198/211198/231205/71210/16
1211/201212/11212/3
County [1] 1080/3
couple [7] 1116/151116/161173/18
1183/251205/101213/71217/22
course [5] 1126/211128/221130/12
1178/121187/15
courses [2] 1084/91084/12
court [23] 1/31/71/91/121/141078/1
1078/211080/41139/61139/161169/7
1171/181179/231180/21205/171211/16
1212/91215/161221/111230/41230/5
1230/81230/19
Court's [1] 1120/15
courthouse [2] 1078/211084/16
courtroom [15] 1081/41104/111108/2
1111/131115/91118/201169/141171/14
1205/11214/21219/211220/171220/24
1226/101227/9
cover [1] 1175/4
covered [8] 1152/71192/191197/19
1198/201198/241202/161202/17
1202/17
covering [2] 1174/201174/25
COVID [10] 1081/91081/171081/21
1081/241084/11085/91085/101102/9
1102/131146/22
COVID-19 [1] 1146/22
cr [3] 1078/41221/131230/10
crashing [1] 1084/10
crazy [4] 1188/231189/31199/21
1202/14
CRC [2] 1078/201230/18
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C
create [1] 1155/15
created [1] 1160/2
creating [1] 1089/15
credibility [1] 1122/24
credit [2] 1131/161152/9
credits [1] 1196/2
crime [31] 1125/161125/201125/22
1125/241126/11126/61128/31128/5
1130/141130/191130/211133/13
1133/161134/141134/181134/20
1134/221135/31135/81135/171135/18
1135/181135/211136/81136/251136/25
1137/21137/31175/111209/61209/8
crimes [4] 1124/171136/51137/51137/7
criminal [9] 1078/41133/211141/9
1162/151162/171165/111176/20
1221/121226/20
criminally [2] 1135/91135/14
criteria [1] 1191/15
critical [1] 1208/22
crooked [1] 1182/4
cross [4] 1105/41106/41106/251175/19
cross-examination [3] 1105/41106/4
1175/19
crossed [1] 1187/5
CRR [2] 1078/201230/18
CSO [2] 1215/201220/8
cuff [1] 1186/8
cuffs [1] 1186/8
curious [7] 1181/41181/51181/61181/8
1181/121181/141181/14
currency [2] 1131/161132/1
current [1] 1160/23
currently [1] 1161/2
custodial [5] 1140/101140/111140/22
1147/151209/10
cut [4] 1118/11196/51197/171201/7
cuts [2] 1154/101182/24
D
dad [1] 1100/21
danger [1] 1088/22
darn [1] 1181/22
date [29] 1091/201091/221092/4
1094/191094/241095/181095/19
1096/151097/141097/161112/10
1112/141112/211125/171125/19
1125/201125/211175/201183/91189/6
1189/71190/51190/71190/131190/13
1190/181194/71212/61227/25
dated [1] 1151/12
dates [1] 1196/7
day [20] 1107/61108/101119/16
1148/181151/31168/251179/211190/15
1193/231196/131197/21197/41199/3
1200/61200/151214/211214/211215/20
1218/221230/14
days [3] 1/41153/191227/20
daytime [1] 1097/17
deadline [1] 1207/10
deal [2] 1177/101204/14
dealing [3] 1175/251176/21176/5
Dean [3] 1213/241213/241214/4
debt [3] 1152/41163/151169/4
decades [1] 1207/25
deceive [3] 1126/221128/221136/22
December [2] 1085/211143/23
December 31st [1] 1143/23
deception [1] 1124/1
decide [17] 1105/71120/61122/18
1123/251124/51124/111127/81129/9
1136/21136/31137/91137/111137/25
1180/131189/101211/251213/15
decided [1] 1180/5
decides [2] 1165/181184/12
deciding [1] 1119/25
decision [12] 1102/191120/81121/24
1122/201127/101127/111129/12
1129/131181/161205/191205/201207/5
decisions [1] 1124/13
declared [1] 1097/4
deductions [3] 1122/21148/161148/17
default [3] 1176/221194/101194/14
defaulted [1] 1194/12
defendant [130] 1078/71079/41115/25
1120/71120/111120/171120/181120/19
1120/211120/221121/81124/41124/5
1124/81124/121124/181124/211124/22
1125/251126/61126/81126/151127/18
1127/251128/21128/51128/71128/12
1128/141129/211130/51130/211130/24
1131/11131/61133/111133/151133/18
1133/201134/131134/161135/21135/3
1135/71135/71135/91135/101135/11
1135/111135/141135/161135/17
1135/201135/231136/21136/41136/6
1136/71136/81136/121136/221136/23
1137/11137/41137/61137/91137/9
1137/101139/211139/241140/121141/5
1141/81141/151142/41142/191142/25
1143/41143/221144/61145/81145/10
1147/91148/131148/211150/11151/1
1151/31152/241152/251153/101154/1
1155/111155/201155/231156/11
1156/221159/81159/191159/241160/13
1162/61165/21165/91166/121169/8
1170/151170/161170/181170/19
1170/191170/201172/251195/161202/5
1205/241206/161206/211207/81207/18
1209/121209/151210/21210/81210/13
1211/31211/101211/221216/21221/14
defendant's [8] 1120/241121/11124/6
1144/101148/61156/51194/61211/5
defense [12] 1118/151119/11136/11
1139/11141/131172/241173/111202/4
1206/11208/21208/161209/11
deferment [2] 1193/201194/5
deferred [1] 1193/13
defies [2] 1151/21159/20
define [1] 1132/15
defined [1] 1128/21
definitely [1] 1150/8
definition [5] 1131/191190/111191/13
1191/141191/24
definitions [2] 1126/191128/17
defraud [33] 1126/21126/91126/15
1126/211127/31127/61127/141127/17
1128/41128/81128/131128/161128/21
1129/41129/71129/151129/201130/14
1136/121136/141151/31168/251172/15
1172/161172/241173/21189/121198/11
1199/61201/101202/51202/71206/22
defrauded [4] 1156/51165/91165/10
1182/24
defrauding [5] 1127/231130/71139/8
1176/241183/20
degree [4] 1131/211131/231132/6
1132/12
DELANO [50] 1078/51078/61081/8
1082/71086/111086/231087/51096/2
1100/91101/101108/71119/11139/7
1145/231154/161160/171162/18
1164/201169/51171/241172/121172/12
1172/131173/121173/181174/10
1174/241175/91176/161176/161176/19
1176/201177/111177/181178/20
1180/141188/151189/251190/11199/1
1200/201207/251208/41211/221211/22
1221/151221/151226/141230/91230/10
Delano's [4] 1161/151168/141177/23
1179/13
delay [2] 1080/61092/8
deliberate [7] 1097/241213/141213/15
1213/181214/71214/121214/25
deliberating [3] 1119/151213/11
1213/16
deliberation [1] 1139/19
deliberations [10] 1119/121120/5
1137/151137/241139/151211/15
1212/191213/31213/61213/22
delivery [2] 1131/131132/4
demonstrative [1] 1210/8
denied [2] 1144/201153/13
deny [1] 1115/21
depend [1] 1124/2
depending [2] 1211/241219/6
deposit [6] 1131/151131/171131/18
1132/141134/31162/23
deposited [2] 1143/41182/20
depositing [1] 1211/1
derived [5] 1132/241134/91134/17
1134/201134/22
described [2] 1140/241163/15
describes [1] 1145/8
designed [5] 1131/71162/151198/4
1198/51198/14
despite [3] 1088/131144/131214/6
detail [2] 1088/251124/3
details [3] 1082/111127/201129/24
detained [1] 1124/10
determine [2] 1137/61143/14
developed [1] 1082/4
devised [1] 1128/7
did [159]
didn't [94] 1086/161086/161088/1
1089/171089/181089/191090/13
1090/181091/11092/141093/11095/4
1095/51095/91098/51106/41106/14
1106/191109/171110/101123/18
1140/121140/191144/11145/171145/17
1146/161149/181149/231149/23
1151/181160/121163/211164/51168/1
1174/141174/211174/221174/22
1178/141179/21179/111179/171180/3
1181/101181/231182/151182/18
1182/191183/231184/111184/201185/6
1185/131185/131185/141185/14
1185/151185/151187/121187/16
1187/161188/21188/31188/111188/20
1189/111190/71191/71194/231194/25
1195/11196/221197/111197/121198/15
1198/151198/161199/21199/31199/3
1199/81201/141201/151203/11203/7
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 162 of 185
D
didn't... [8] 1203/81203/201203/24
1204/191206/231211/81214/91217/22
differ [1] 1123/13
difference [4] 1122/121122/131170/1
1170/10
differences [2] 1130/181166/6
different [25] 1088/61088/201095/18
1095/191096/131096/151096/19
1096/231097/141106/211123/19
1124/181125/231140/241156/181162/3
1162/61165/191175/201178/51178/5
1189/61200/111210/71210/15
differently [1] 1138/7
digging [1] 1102/15
diligence [2] 1180/191180/21
dime [3] 1141/51150/51158/16
dire [1] 1215/15
direct [6] 1101/181122/41122/41122/12
1122/141211/15
directing [1] 1135/5
direction [2] 1094/21135/6
directly [9] 1103/161123/121132/25
1134/101156/91163/81167/161182/18
1197/11
directs [1] 1135/12
disbelieve [1] 1122/20
disclose [1] 1093/1
discovery [1] 1187/21
discriminant [1] 1146/14
discuss [2] 1138/21226/4
discussions [1] 1120/4
disguise [2] 1131/81210/16
disguising [2] 1164/231166/1
disposition [1] 1131/13
disprove [1] 1122/9
dispute [10] 1107/171142/81142/12
1142/181142/191142/231143/31143/9
1172/121189/14
disregard [4] 1120/151121/231209/20
1209/24
disregarded [1] 1209/13
distanced [1] 1164/2
distancing [5] 1164/31164/91164/10
1164/201164/22
distracted [1] 1089/8
District [7] 1/141078/11078/11221/11
1221/121230/51230/5
divert [1] 1090/6
DIVISION [2] 1078/21221/12
do [139] 1080/241085/111085/24
1085/251086/61086/111086/171089/5
1089/211089/231091/91095/231099/18
1099/241100/141101/111101/12
1101/161101/221102/161103/14
1103/171103/221104/241105/101106/3
1106/151106/211106/241107/11107/4
1107/51107/201107/221107/231108/10
1111/21111/41111/91111/111111/13
1111/151111/171111/191112/101113/9
1114/11114/21114/151115/121115/15
1117/11117/21117/171118/11118/4
1118/231119/31120/131120/221123/18
1127/81127/91129/101129/101129/16
1135/41139/171144/11144/131145/15
1147/11149/221150/191151/151151/24
1155/231155/231156/61157/221159/3
1162/251163/81166/251167/241170/8
1172/191173/161174/181174/251178/1
1178/21178/161179/241179/251180/19
1181/201186/141187/81187/131188/13
1188/131189/81193/41193/81193/19
1194/201194/231195/131197/91198/4
1198/141198/251199/81203/121203/20
1204/161204/241205/51205/61211/13
1212/161212/231213/101213/11
1213/161214/161214/201215/12
1215/121215/241216/111217/13
1217/221218/51218/91220/21227/12
1230/6
docket [1] 1/6
document [2] 1/91151/15
documentation [22] 1082/151082/25
1082/251090/101092/11092/31093/22
1145/161146/91147/111147/231147/24
1150/21150/31150/41153/81153/11
1153/141154/51206/181207/51207/13
documents [28] 1089/151089/23
1140/71143/201149/81153/181172/8
1178/241180/171181/151181/15
1181/181181/231181/231183/151184/2
1184/41184/61184/91192/251201/5
1202/191205/31206/31206/51206/15
1206/241207/2
does [31] 1091/121094/171106/23
1116/71120/191127/181129/201134/23
1139/221141/241142/11146/21147/24
1162/251164/111177/31177/41178/19
1181/61181/91183/121190/251195/12
1195/121195/131200/21201/91202/10
1206/221222/31228/12
doesn't [48] 1097/31105/161106/19
1116/21120/241122/221123/211125/18
1127/101127/201127/221129/12
1129/231130/11130/61134/131134/19
1136/211144/131144/141154/18
1155/161155/251157/191158/20
1162/241165/81166/41166/151166/22
1167/11167/21167/191168/201170/10
1174/201177/161183/121183/13
1183/141185/61187/191201/31203/8
1205/201206/231207/11210/9
doing [11] 1085/161138/31141/15
1172/11172/31174/31174/241175/8
1192/131192/181199/25
dollar [6] 1144/31165/71165/81167/10
1167/111192/13
dollars [8] 1158/141161/201163/10
1168/171169/11210/41210/51211/9
domiciled [5] 1191/111191/131191/16
1191/201191/25
don't [96] 1092/201095/81097/23
1104/61104/121104/141105/11105/2
1106/141107/101107/121107/14
1107/141107/241107/241109/31115/14
1116/31117/21117/251119/211122/17
1138/41138/61144/21152/101155/3
1156/11156/21159/41170/111170/23
1171/101174/101174/251175/23
1176/141178/161179/151180/41180/4
1180/231181/181181/201186/241187/3
1187/111187/171187/181187/19
1187/201187/211187/211187/21
1188/141189/21189/21189/141189/23
1190/161190/171191/71191/221191/24
1193/191194/191194/201195/51198/18
1198/181200/31200/231201/31204/13
1205/101208/71212/181212/231212/23
1213/231214/61216/181217/71217/7
1217/101217/101217/111217/19
1217/201217/201226/71226/241227/12
1228/81228/101228/14
done [16] 1118/21118/31128/191135/5
1135/51137/131149/101159/81163/7
1171/241194/221199/11202/31204/22
1217/251227/12
door [3] 1139/181144/21178/11
doubt [52] 1120/81120/211120/25
1121/11121/21121/21121/51121/9
1125/91125/201126/71127/241128/6
1130/231133/171135/201136/141139/7
1139/101143/111152/91160/11169/6
1172/71172/91173/21173/121189/10
1202/71202/101202/111202/121202/13
1203/101203/111203/141203/17
1203/191203/211203/231203/251204/1
1204/31204/51204/61204/81204/10
1204/111204/121204/181204/21
1211/10
Douglasville [2] 1083/201160/21
down [19] 1087/71101/211102/41102/7
1115/111116/201146/221147/51163/21
1165/211167/221177/251179/111186/5
1212/181212/231213/111213/13
1213/14
downstairs [1] 1212/22
downstream [2] 1164/241165/14
dozens [1] 1217/2
Dr [1] 1145/7
Drive [2] 1078/221164/16
driver's [3] 1160/231161/11168/20
Dubai [1] 1083/13
due [7] 1081/91152/161180/191180/20
1194/41194/51194/9
duplicate [1] 1209/2
during [12] 1081/81105/41116/16
1121/231123/191137/121137/141140/9
1140/111159/51168/131217/6
duty [1] 1119/24
E
each [19] 1117/171122/181124/18
1125/41125/221125/241130/121136/24
1136/251137/251141/41211/191211/20
1211/251212/31220/31220/51221/4
1222/6
earlier [11] 1089/71095/201097/14
1102/81133/51139/171153/131158/1
1160/151205/171210/18
earliest [2] 1095/231157/8
early [3] 1140/171153/211158/19
earning [2] 1153/61165/25
earnings [9] 1090/71090/191153/6
1158/221159/31159/61159/121160/7
1160/10
easiest [1] 1190/2
easily [1] 1084/15
Eastern [1] 1175/14
easy [8] 1199/101203/131203/17
1203/181203/201203/211203/25
1227/15
easy-peasy [5] 1203/171203/18
1203/201203/211203/25
eat [2] 1213/51213/11
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 163 of 185
E
ECF [2] 1/21/3
economically [2] 1127/191129/22
edging [1] 1109/7
effect [6] 1081/211084/11085/13
1091/131102/91102/13
effectively [2] 1127/51129/6
effects [5] 1085/91085/131102/8
1102/131102/13
egregious [2] 1141/241141/25
Eight [1] 1221/23
EIN [15] 1148/41148/51154/171154/19
1154/211154/221155/21155/41155/18
1157/141157/161157/191158/31158/9
1190/13
EINs [5] 1154/101155/21157/201157/22
1157/23
either [17] 1083/81093/211120/10
1122/141148/131158/161158/251162/7
1183/131191/131211/231211/241212/2
1212/111213/121222/31227/21
element [2] 1143/71156/20
elements [3] 1142/171143/61143/10
elevator [1] 1219/15
elite [1] 1087/19
else [13] 1082/141090/21145/181150/4
1155/31161/121167/21183/241188/17
1191/221212/151219/41228/3
emphasize [1] 1137/19
employee [5] 1110/131135/121144/24
1152/191208/12
employees [44] 1081/121082/21085/4
1085/71085/101085/251086/61086/13
1086/171087/11087/231088/71089/6
1091/71103/81103/171104/51108/22
1109/141140/131144/81144/161144/21
1144/241145/61146/111146/181146/21
1146/251147/71147/121147/181148/9
1148/161156/141168/211186/201191/3
1192/81192/141207/111208/141209/18
1209/19
employees' [1] 1152/15
employer [1] 1148/1
end [12] 1083/151084/71133/61154/9
1154/131155/11158/71158/211158/24
1203/111212/51221/7
ended [2] 1153/231159/9
ending [4] 1091/171155/21157/81171/1
ends [3] 1158/51163/231165/19
engage [3] 1130/191133/131133/19
engaged [2] 1133/181136/2
English [1] 1095/2
enormous [2] 1166/101210/14
enough [2] 1202/161227/21
enrolled [2] 1084/81084/9
ensure [1] 1211/5
ensuring [2] 1205/251206/8
enter [1] 1227/23
entered [19] 1081/41108/21118/20
1168/181171/141219/211220/24
1222/171222/251223/81223/161223/24
1224/71224/151224/231225/61225/14
1225/221227/9
entire [2] 1113/101145/5
entirely [2] 1156/51191/18
entities [1] 1175/23
entitled [4] 1137/201193/121195/1
1210/5
entity [2] 1169/241170/2
entrance [1] 1103/9
entry [1] 1/6
equipment [2] 1168/81168/9
error [5] 1092/31095/221136/18
1157/131173/8
errors [1] 1118/12
especially [1] 1082/5
essentially [3] 1152/131157/141159/14
establish [7] 1090/221096/121136/18
1151/151154/51161/241173/9
established [2] 1142/61143/10
Europeans [1] 1175/14
evaluate [3] 1188/51188/61189/9
even [39] 1084/111087/181089/22
1097/41105/151109/241114/31114/6
1115/251120/121136/161145/201147/5
1148/51149/171150/51150/81151/12
1151/131151/201152/111152/17
1155/251160/221161/141162/11164/3
1165/81165/141167/111169/121173/4
1173/61175/151197/51204/71206/7
1207/211217/8
eventually [2] 1084/161086/6
ever [22] 1086/131087/21087/231096/6
1096/251101/21103/171108/221109/14
1114/61114/61154/171155/81178/21
1178/221186/201191/151193/141195/5
1200/241200/251216/25
Evert [1] 1079/3
every [17] 1120/181135/41145/25
1146/51146/61152/191161/71176/8
1176/111176/111197/71199/131199/14
1200/151201/111201/141201/16
everybody [3] 1085/181163/11205/9
everybody's [1] 1146/1
everyone [1] 1140/14
everything [13] 1082/111141/14
1147/211149/201168/151187/181210/1
1211/121218/71218/161218/181219/4
1227/7
evidence [61] 1105/251107/81107/16
1107/171109/201109/211109/241119/7
1120/91120/181120/201121/41121/12
1121/121121/141122/11122/11122/4
1122/41122/81122/131122/151122/16
1122/171123/141123/151123/171124/8
1124/101124/141135/31136/11136/3
1136/171136/251137/61137/161138/1
1138/111138/211138/221140/231146/8
1169/51173/81175/51177/151188/7
1188/91190/141190/201190/221193/14
1193/241193/251193/251202/221205/7
1216/161217/141217/17
evil [3] 1199/71201/41201/10
exact [3] 1125/181146/61146/7
exactly [5] 1103/221105/101106/15
1184/161198/13
examination [5] 1101/81101/181105/4
1106/41175/19
examine [1] 1220/9
example [4] 1101/141101/161101/19
1122/10
examples [2] 1101/101145/3
except [5] 1098/41098/51121/221170/6
1183/19
exchange [3] 1131/161134/41159/18
exclude [1] 1120/25
exclusive [1] 1130/4
excuse [4] 1190/191193/241215/23
1227/2
exhibit [13] 1094/131094/221095/24
1096/41096/191099/21099/51189/17
1193/51195/171196/81196/91210/8
Exhibit 108 [1] 1193/5
Exhibit 200A [1] 1195/17
Exhibit 201 [2] 1196/81196/9
Exhibit 7 [4] 1094/131095/241096/19
1099/2
Exhibit 9 [3] 1094/221096/41099/5
exhibits [5] 1121/131210/101213/8
1218/41218/6
exist [1] 1154/18
exited [6] 1104/111115/91169/14
1214/21220/171226/10
expatriates [1] 1144/12
expenditure [1] 1163/3
expenditures [1] 1152/7
expensive [1] 1139/12
experience [1] 1177/8
experts [1] 1173/20
expired [1] 1168/19
explain [19] 1081/171082/101085/5
1085/81100/61100/81100/81100/11
1100/131100/141100/151100/15
1100/171120/121125/31137/241153/5
1161/51168/15
explained [8] 1095/191095/211102/8
1129/151133/41148/191153/131161/9
explanation [1] 1144/11
extension [1] 1131/16
extraordinary [1] 1168/15
extremely [1] 1139/12
eyewitness [1] 1122/7
F
face [5] 1185/31185/131194/211194/21
1194/22
fact [35] 1083/101088/131097/13
1097/251106/201115/221122/71122/9
1123/161124/31125/141126/121126/24
1127/11127/61127/71127/71127/9
1128/111129/21129/71129/81129/8
1129/111133/241144/131146/91188/5
1193/171205/181207/11208/221209/4
1217/71221/9
factor [1] 1143/15
facts [14] 1120/71121/171121/19
1121/241122/81126/71128/61130/22
1133/171138/101140/61150/101150/10
1161/6
factual [1] 1121/21
fail [1] 1157/25
failed [1] 1172/18
fails [1] 1120/21
fair [1] 1107/25
faith [20] 1115/191136/111136/13
1136/211156/121172/231172/231173/1
1175/61183/141189/111198/121201/3
1202/21202/21202/41202/61203/10
1204/191204/21
fake [5] 1174/31174/131174/161196/4
1207/9
fall [1] 1174/22
false [36] 1092/11092/31092/51093/7
1093/151093/161093/191093/20
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 164 of 185
F
false... [28] 1112/141126/41126/11
1126/131126/231126/251127/41127/13
1127/151128/81128/101128/231129/1
1129/51129/141129/171130/21136/23
1150/121156/61156/121167/131180/9
1180/101183/151205/221205/24
1206/21
falsehood [1] 1180/13
falsehoods [1] 1156/15
falsely [1] 1123/16
familiar [1] 1189/23
family [2] 1099/81099/18
famous [1] 1208/9
fancy [1] 1174/6
FAPR [2] 1078/201230/18
far [5] 1107/51145/91164/241164/24
1164/25
fast [1] 1219/15
father [6] 1085/211112/21112/51113/2
1113/131113/22
fault [4] 1093/201093/211093/231094/1
favorite [2] 1214/41215/3
FBI [2] 1186/131187/14
FDIC [1] 1134/8
February [16] 1145/41153/151153/20
1154/51154/231156/131157/101157/11
1158/131189/151190/101192/20
1196/111196/121207/101207/15
February 13th [2] 1196/111196/12
February 15th [8] 1154/231156/13
1158/131189/151190/101192/20
1207/101207/15
February 16th [1] 1153/15
February 19th [1] 1153/20
February 2020 [1] 1145/4
February 6th [2] 1157/101157/11
federal [9] 1082/121126/11128/3
1130/191132/141132/231133/13
1148/101159/5
federally [4] 1126/181142/91142/16
1143/8
fee [1] 1178/15
feelings [1] 1116/2
fees [1] 1198/9
feet [2] 1085/201166/10
felony [1] 1132/23
felt [1] 1085/9
few [4] 1142/81142/101153/191217/6
Fiber [1] 1164/16
fifth [1] 1134/1
figure [2] 1149/31205/23
figured [2] 1149/181149/18
figures [1] 1149/15
file [13] 1078/41148/251156/221156/24
1157/31158/211160/61161/31161/13
1188/201189/61208/231209/7
filed [20] 1/21/71/91096/61098/41098/5
1117/131142/201148/101156/191157/9
1160/181161/111168/181172/12
1172/121188/221196/111197/61197/7
files [2] 1152/241157/2
filing [2] 1148/71189/5
filings [1] 1157/7
fill [5] 1097/101097/161097/171159/22
1187/12
filled [3] 1148/231160/41206/15
filling [2] 1097/21097/22
final [7] 1080/141080/161116/17
1116/171131/141168/31171/21
financial [26] 1126/21126/31126/9
1126/111126/161126/171130/20
1130/251131/141131/191131/201132/5
1132/101132/131133/141134/51134/7
1142/51142/101142/151142/161143/8
1162/141164/151165/181173/20
find [13] 1120/71120/221135/191137/1
1137/101148/61150/61150/181160/6
1185/151211/91211/211221/14
finding [2] 1135/141149/22
fine [6] 1106/11117/191187/51219/9
1227/31228/19
finish [1] 1131/10
FINLAYSON [4] 1079/41079/51118/23
1171/16
first [26] 1085/61091/161092/22
1102/221108/101125/51126/81128/7
1130/241133/181139/11139/141157/8
1158/11174/181176/171179/211180/10
1184/11185/221194/71194/81194/9
1196/171198/231215/20
fishing [2] 1122/111122/12
fishy [1] 1204/4
fit [1] 1175/16
five [10] 1116/181119/81124/24
1164/151169/111178/41178/51184/23
1185/41221/20
five-minute [1] 1169/11
flash [1] 1216/14
flashed [1] 1217/8
fled [1] 1194/11
Flight [1] 1087/16
flood [1] 1101/20
flowing [1] 1165/21
fly [2] 1087/181177/3
flying [3] 1083/221084/111088/19
FlyingJack [9] 1165/151168/61197/22
1198/11198/31198/171199/161210/20
1216/25
FlyingJack's [1] 1167/22
follow [3] 1080/211120/121120/13
following [5] 1/11126/71128/61130/22
1133/16
follows [1] 1221/13
food [1] 1213/4
foot [1] 1167/5
force [1] 1086/5
foregoing [1] 1230/12
foreign [8] 1131/211131/241132/6
1132/111132/121132/151132/231167/1
foreperson [9] 1146/31211/141211/15
1212/51213/11213/31213/211219/23
1222/1
foreseeable [1] 1102/3
forfeiture [6] 1117/231216/31216/8
1226/31226/191226/25
forged [1] 1156/2
forget [1] 1123/23
forgive [1] 1147/3
forgiven [1] 1198/16
forgiveness [5] 1147/61193/81193/15
1194/161198/15
form [23] 1093/41094/181095/41095/10
1097/71097/71097/91097/221117/7
1117/121132/31132/251134/101147/22
1159/221181/11190/61190/91191/7
1195/151196/91211/171230/12
formal [1] 1120/16
formed [4] 1136/151173/31173/6
1189/20
formerly [3] 1139/71211/221221/15
forms [7] 1097/21098/241098/25
1149/101149/241191/191191/19
forward [5] 1092/111092/151206/19
1206/201226/24
found [6] 1126/61128/51130/21
1133/151158/61183/11
four [8] 1095/171100/191124/24
1130/151140/241162/201207/20
1221/19
fourth [4] 1126/171128/141131/6
1133/24
Fowler [1] 1148/18
fraud [43] 1082/141083/41098/2
1124/211124/231126/11128/31130/4
1131/51131/51133/41133/41133/25
1133/251134/151134/151139/11
1140/251141/21142/31142/51143/7
1156/201164/101165/221167/61167/17
1167/181167/181168/91168/101168/14
1177/201194/181198/141201/22
1202/231202/241208/191210/21210/3
1210/141211/8
fraudster [1] 1182/14
fraudulent [22] 1126/111126/13
1126/231126/251127/51127/161128/9
1128/101128/231129/11129/61129/17
1130/21136/161136/181136/231173/3
1173/71173/91173/121208/241209/7
free [4] 1119/141119/151178/17
1198/17
freely [11] 1222/161222/241223/7
1223/151223/231224/61224/141224/22
1225/51225/131225/21
freezing [1] 1153/23
Freight [1] 1165/15
Friday [1] 1212/22
friend [8] 1166/91166/161174/5
1182/201183/21184/101184/161190/3
friends [1] 1182/11
friendship [1] 1207/16
front [5] 1115/151116/101217/8
1217/221218/8
froze [1] 1153/25
frozen [1] 1155/20
full [4] 1/81098/101160/141160/22
full-year [1] 1098/10
fully [1] 1138/1
Fulton [1] 1080/3
fund [2] 1156/81166/2
funding [1] 1197/17
funds [15] 1133/211134/41152/6
1153/251163/41164/81164/231165/10
1166/31168/111169/21199/241200/5
1200/61203/4
funnel [1] 1167/8
funneled [3] 1167/211168/41210/6
further [2] 1101/51165/14
future [1] 1170/9
G
garage [1] 1185/16
gather [1] 1219/2
gave [26] 1080/91082/171086/21
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 165 of 185
G
gave... [23] 1086/221087/31087/24
1088/41088/91089/121101/101101/14
1109/81112/191113/131113/131122/10
1123/191141/181141/211141/22
1170/171170/221179/81191/151209/5
1209/12
gear [1] 1185/23
Gene [2] 1145/221181/14
general [1] 1195/5
generally [1] 1124/20
generic [2] 1170/181170/20
gentleman [1] 1214/9
gentlemen [23] 1139/51139/151140/23
1141/231145/71150/221151/191154/14
1155/221156/111157/51158/151158/20
1162/241165/211166/71168/141205/14
1207/71208/151209/91211/41220/20
GEORGIA [11] 1078/11078/221080/3
1083/201143/241160/211165/161199/5
1199/101221/121230/6
get [80] 1080/171092/11093/81093/10
1093/121093/241094/211095/131096/9
1096/221106/211107/201113/11116/14
1119/141119/151126/31126/101138/8
1145/101147/101151/221152/221154/2
1155/201155/231156/61157/161158/14
1159/181160/131163/41163/51163/10
1165/91165/101166/11171/101171/21
1171/221172/221174/91174/221174/23
1178/41180/141185/161186/51186/7
1186/131191/231192/31193/151194/21
1194/221194/221200/31201/231201/24
1203/81203/101204/11206/231208/11
1209/151209/251209/251210/31210/4
1212/231212/241213/71213/81214/6
1216/121218/31218/91218/161219/14
1227/15
gets [13] 1151/51153/181157/91166/22
1177/101177/141182/151184/171185/9
1185/91185/181197/51204/2
getting [13] 1092/81097/81110/7
1133/61151/81152/141169/21169/3
1169/121185/71187/141201/151213/18
Ghana [27] 1094/151095/201096/13
1099/31099/61099/81099/161099/18
1100/51100/201100/221100/231102/3
1102/141112/11112/41114/121114/13
1114/181114/201140/141142/22
1168/201175/221184/21184/41207/23
Ghanaian [5] 1091/201096/101112/23
1113/11114/9
gift [1] 1131/12
gig [1] 1174/24
give [33] 1080/161082/91082/101088/1
1088/51089/11097/131109/31116/9
1116/151119/81119/101119/111119/18
1120/31122/141124/131126/191130/16
1134/251137/151138/61144/101146/25
1154/31156/21181/181191/121198/17
1212/91212/101219/111228/1
given [3] 1124/191155/191207/3
giving [4] 1097/51106/221159/25
1181/17
Glauser [3] 1179/81179/91179/10
go [67] 1081/61085/151092/111092/15
1092/201094/211102/61102/141103/5
1106/111108/41110/11115/51117/5
1124/191125/41125/241139/11139/4
1146/241152/151153/161156/81156/9
1157/191158/11158/211161/131171/16
1180/241184/131185/251186/17
1186/181186/181189/241194/20
1197/201201/241205/61205/91205/13
1210/111211/131212/241213/81213/13
1213/201213/201213/231214/11214/19
1214/201214/211215/111215/111216/1
1218/31218/61218/201219/91219/14
1220/91220/221221/101226/241228/8
God [4] 1175/21175/111175/211195/4
goes [18] 1117/111151/91151/13
1152/111157/11158/11165/191166/23
1178/111184/21185/91186/51186/6
1199/121199/151199/181199/18
1218/18
going [97] 1080/141081/231082/14
1084/21085/251086/21086/51102/2
1107/201107/251109/21109/61109/8
1110/251113/221115/31115/141115/21
1116/41116/111116/151116/161116/18
1117/41117/51118/71119/81119/10
1119/111119/181119/191124/191125/3
1125/41125/241126/191129/161130/16
1134/251135/251140/21147/31149/21
1152/121152/221154/211158/51158/7
1158/251160/251161/91163/151170/23
1171/231172/201173/191177/12
1177/121178/31179/71179/141180/8
1181/11182/131186/141186/171186/25
1188/41188/61188/131188/191188/24
1189/31190/201193/51193/241193/25
1195/141196/31202/31202/211208/5
1210/251214/121214/161214/19
1216/111217/121218/211220/91221/2
1221/31222/61222/81227/11227/17
1228/8
gold [8] 1085/181085/241102/161110/7
1192/51192/61192/111192/12
gold's [1] 1192/11
goldmine [5] 1144/31168/171174/11
1174/141174/16
goldmining [1] 1142/22
gone [2] 1194/241200/7
good [32] 1080/151081/201107/5
1110/61115/191123/71136/111136/13
1136/211139/51144/101156/121166/16
1171/41172/231172/231173/11174/4
1174/191187/41189/41189/111198/12
1202/21202/41202/61203/101204/19
1204/211205/151206/101227/18
good-bye [1] 1227/18
good-faith [1] 1156/12
got [89] 1084/161091/141093/11
1095/201097/251098/21101/151103/7
1112/11112/161112/241116/31117/23
1138/121139/141145/11145/131145/18
1146/101151/41151/241152/41153/17
1153/171154/91154/121154/211158/11
1159/101162/81162/81162/221164/12
1164/211164/221164/251165/11165/22
1165/231165/241166/191167/16
1167/231173/11173/141174/131175/20
1177/151177/151178/151178/15
1178/161178/171178/181179/10
1180/101180/111181/241181/251186/3
1186/121186/161186/181188/15
1189/181189/211190/111191/61192/6
1192/101194/11196/81199/41201/16
1201/181204/151204/171206/14
1206/141206/151206/161208/171210/6
1211/81213/41213/151215/101219/14
1226/19
gotten [4] 1084/191167/81171/20
1172/7
government [48] 1092/91093/71093/24
1101/31111/121114/231115/181116/7
1118/131120/201124/81127/201129/23
1134/151134/201136/131138/251139/2
1169/241170/11170/71170/121172/4
1173/11175/11175/181176/101176/22
1178/141179/121179/161189/17
1189/171189/171191/51194/241196/3
1197/231200/181201/141202/11202/6
1203/61203/91204/151208/201217/24
1218/12
government's [10] 1095/241099/2
1099/41172/51180/101192/241193/4
1195/161196/81196/8
grab [1] 1214/20
grabbed [1] 1202/1
graduate [2] 1087/121095/1
grammar [1] 1171/4
grand [3] 1201/231201/231217/6
granted [2] 1143/151202/10
great [1] 1124/11
greater [1] 1137/20
greed [1] 1152/14
grew [2] 1099/101099/16
Greythorne [1] 1166/8
Greythorne Lane [1] 1166/8
groceries [1] 1088/24
gross [2] 1133/11134/11
ground [6] 1173/251186/51186/7
1187/141192/121192/23
grounds [2] 1115/171115/17
grumpy [1] 1174/7
guarantee [2] 1147/31147/4
guaranteed [1] 1156/9
guess [13] 1088/81109/11109/11109/7
1175/101177/111179/211187/11195/8
1196/61214/201226/151228/15
guesses [2] 1148/221149/11
guessing [1] 1148/25
guesstimate [1] 1187/1
guilt [5] 1120/181120/241121/11204/9
1204/12
guilty [44] 1120/71120/211120/22
1121/91126/61128/51130/211133/15
1135/21137/11137/21137/71137/7
1137/91137/101137/221137/221139/8
1169/61203/121203/131204/51204/5
1204/61204/71204/71204/91204/23
1205/71211/101211/231211/241212/2
1212/21221/161221/171221/181221/19
1221/201221/211221/221221/23
1221/241221/25
guns [5] 1185/251186/21186/31186/3
1186/3
guy [3] 1179/101191/141205/2
guys [2] 1102/191111/13
H
ha [7] 1158/61177/101188/21189/18
1189/211190/41190/8
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 166 of 185
H
ha-hah [1] 1189/18
Hackman [2] 1145/221181/14
had [155]
hadn't [1] 1189/7
hah [1] 1189/18
half [9] 1090/171092/171094/41094/10
1127/51129/61145/121217/111217/24
half-second [2] 1217/111217/24
hand [8] 1185/251192/171195/41195/7
1195/71220/71220/71220/8
hands [3] 1105/41155/241171/24
happen [1] 1101/25
happened [19] 1085/91085/161086/4
1086/101101/191102/121103/11103/3
1106/61149/251155/121157/71159/12
1165/51177/181183/161187/111189/2
1196/19
happening [1] 1186/10
happens [10] 1119/81154/131155/1
1157/181167/71183/161184/91186/9
1214/71217/10
happy [1] 1118/4
hard [2] 1107/251185/15
harder [3] 1185/161204/21204/7
has [58] 1/71086/171095/41095/5
1096/51115/181115/221120/61120/25
1121/81122/61124/41124/181125/19
1127/91129/111134/201139/21139/6
1139/211139/241140/241142/20
1144/121145/161145/191145/211153/8
1154/111154/111156/21156/201156/22
1156/231160/81164/121165/141165/17
1165/171166/251166/251167/211168/4
1173/11192/101194/241197/171203/6
1203/91205/181207/141208/201211/18
1211/191214/101214/221216/25
1218/15
have [250]
haven't [5] 1133/101148/231173/16
1204/171204/21
having [6] 1082/11154/21154/171163/2
1200/191214/6
Hawaii [1] 1194/20
Hazel [2] 1147/251159/9
he [508]
he'd [1] 1166/9
he's [69] 1088/161089/211107/2
1110/221110/251140/51146/101149/17
1149/211150/71150/81151/101151/18
1152/31152/41153/21153/171153/17
1157/201158/111159/101161/11
1163/151163/151164/21164/31164/12
1164/231165/221165/231166/13
1166/141166/161166/241167/71167/8
1168/91168/91168/211174/121174/20
1174/211175/171175/171175/18
1175/181176/171176/181182/31182/14
1183/201186/31188/161188/191188/24
1192/51192/61192/61193/171193/18
1193/211200/201201/91203/121203/13
1204/51204/91207/21209/16
head [2] 1108/251186/24
heads [1] 1219/5
hear [16] 1106/91116/111183/24
1184/111186/191186/211186/23
1186/241187/21187/101188/51188/16
1194/141202/81228/131228/14
heard [70] 1104/141109/201110/24
1113/181113/201119/61135/221140/8
1140/201142/101143/121144/23
1144/251145/71145/221146/121146/19
1147/141147/251147/251148/181149/7
1150/141150/161151/71151/81151/11
1154/11154/31154/161157/131159/9
1159/211161/61163/141163/241166/8
1166/81166/111166/181167/141168/6
1172/81173/151173/161175/31175/19
1178/121178/161179/21185/11188/15
1188/151189/91191/41191/231193/5
1196/111196/181197/231205/141206/4
1206/71206/101207/251208/241209/15
1209/161211/121220/20
hearing [5] 1160/161169/81180/7
1180/121230/11
heart [2] 1178/11178/2
heavy [1] 1120/23
heck [1] 1184/14
heist [1] 1201/24
held [6] 1136/151138/61173/31188/2
1207/81230/8
help [5] 1128/161146/201182/211185/6
1226/13
helped [5] 1082/211182/121182/16
1182/201183/3
helps [1] 1080/20
her [26] 1096/51111/81111/91149/21
1150/61150/61150/81160/191168/13
1179/21179/191179/201182/151183/3
1183/41183/51183/91183/161188/23
1214/201215/111215/191215/23
1219/151222/91227/7
here [43] 1092/211094/61094/11
1098/171120/91137/51140/241142/9
1142/181143/91147/91149/251152/14
1152/241155/41160/71161/61172/1
1172/71173/151178/81179/151180/2
1180/81182/31182/71183/21188/20
1195/71199/91200/131202/31208/2
1210/11210/131212/121213/101213/15
1213/241214/61214/101219/121227/14
here's [1] 1104/21
hereby [1] 1230/6
hesitate [1] 1138/4
hesitation [1] 1121/7
hey [6] 1180/211180/221181/91181/17
1182/21189/20
hid [1] 1176/18
hidden [1] 1201/15
hide [11] 1139/141141/161175/4
1176/211177/191185/131199/31199/3
1199/251200/221200/23
hiding [3] 1163/161200/111201/12
high [3] 1109/61186/211214/11
highest [1] 1204/12
highly [2] 1203/151203/16
him [78] 1082/141082/171086/22
1088/41088/91089/121100/141100/15
1104/181105/181106/71106/81106/13
1106/141106/211106/221106/22
1107/121107/121107/131107/13
1107/151109/91110/241111/31124/24
1125/11140/141141/161141/181144/7
1151/21154/31154/41154/111154/20
1155/131156/21159/251160/41160/7
1162/91166/131166/181166/201168/19
1174/71177/181178/211178/221180/3
1182/121184/141184/151186/81186/15
1187/51188/161189/91189/91189/18
1189/211194/121195/31195/111196/5
1196/181197/131198/71206/221207/3
1207/41208/231209/51209/51209/5
1211/81214/16
himself [6] 1164/21164/31164/9
1164/101164/201164/22
his [112] 1096/51100/151100/15
1104/191105/171115/231115/241116/2
1120/191139/111140/21140/101140/11
1140/221141/91142/211143/221144/12
1145/11145/41145/251146/81146/10
1146/111147/101147/181147/21
1148/131150/71151/41151/201152/4
1152/61152/81152/231153/161154/8
1155/241156/141156/151157/11157/1
1157/11157/31159/121160/21160/18
1160/201160/231161/131161/17
1161/191161/221162/41162/241163/5
1163/51163/61163/161164/11164/4
1164/61166/91166/151167/41167/13
1167/241168/151168/171168/181169/1
1172/141174/51174/231175/31175/4
1176/191176/231176/231177/11
1177/131182/211182/211183/31184/20
1185/31185/131185/141185/161186/7
1186/81188/11188/121188/211189/5
1192/51194/41194/141194/151197/8
1198/251199/11199/51200/181200/20
1201/91201/171203/31207/11209/15
1209/241211/6
history [1] 1100/7
hit [1] 1182/13
hmm [26] 1081/251087/81087/11
1087/131087/151087/171088/121089/3
1090/51092/71092/101094/141096/11
1096/141096/161098/231099/15
1100/101102/181109/111109/13
1109/161110/31111/91113/41113/6
hold [6] 1104/61185/251204/151204/24
1213/231216/3
holding [1] 1172/3
home [2] 1214/211214/21
honest [2] 1136/201185/11
honestly [11] 1094/251136/151136/15
1138/61173/21173/31173/61186/22
1187/31187/101207/8
honor [39] 1080/111100/121104/3
1104/81104/151104/171105/221107/18
1115/21115/131116/81116/221117/18
1118/131118/161118/251119/51134/24
1138/181159/221195/91195/91195/10
1196/51196/221196/251197/151215/8
1215/141216/171218/231219/51219/9
1222/41226/41226/121226/181227/5
1228/6
HONORABLE [1] 1078/11
hoping [1] 1226/5
horse [1] 1189/16
hours [1] 1146/7
house [32] 1098/91112/31141/11
1151/141151/161151/221152/121157/1
1160/181160/211161/131163/51163/16
1166/101166/161166/211166/221167/5
1167/71168/181169/31174/51174/6
1174/71182/111182/161183/31184/13
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 167 of 185
H
house... [4] 1188/221189/51199/21
1201/12
housekeeping [1] 1212/21
houses [2] 1166/121166/14
how [82] 1087/181089/51090/141091/7
1091/71098/151100/51102/61102/6
1103/71103/221104/221105/101106/15
1107/81111/241112/31112/31112/3
1113/181113/191118/151119/31122/19
1124/121128/171138/221140/20
1143/121144/211144/231144/23
1144/251145/111145/151146/51146/17
1146/191147/181148/251151/81151/11
1152/11157/61157/131158/241159/10
1159/211162/11163/141166/111167/4
1175/11175/11175/21175/61175/7
1175/141175/141175/151178/11178/2
1179/101181/21186/51186/61186/13
1187/131188/51188/121193/81196/6
1198/231198/241199/101199/11
1199/111206/111209/81212/131217/10
1218/9
however [1] 1/8
huge [4] 1084/191144/231163/24
1169/3
husband [1] 1111/8
I
I'd [2] 1143/71226/15
I'll [15] 1080/171100/151116/61116/9
1118/61121/161155/31158/151162/11
1169/81173/181181/131182/121212/24
1216/10
I'm [77] 1091/21094/101094/101098/17
1107/221109/21109/51115/211116/15
1116/161116/181117/41117/51117/10
1117/121117/131118/41119/81119/11
1119/181119/191124/191125/31125/4
1125/241126/191129/161130/16
1130/171131/61133/61133/61133/8
1134/251135/251151/251152/14
1160/171160/251169/121170/11
1170/201171/231171/241173/19
1174/111174/241174/251176/51176/20
1179/71179/71179/141179/141182/9
1182/161186/171190/201193/51193/12
1195/201202/31202/171202/211205/11
1214/161214/191215/141216/91216/11
1219/231220/91221/21226/51227/1
1227/171228/8
I've [23] 1100/221118/21118/21120/1
1121/111126/201128/181128/211133/4
1138/121138/131138/201154/91166/23
1174/131179/91192/221192/221197/19
1198/241203/21212/221228/16
ICE [1] 1186/10
idea [6] 1098/151146/211149/14
1174/191176/251195/9
identification [2] 1093/41148/1
identified [1] 1148/7
identities [1] 1144/14
identity [3] 1112/171157/31185/14
ill [8] 1174/171175/11175/71176/17
1183/131185/101189/111194/18
immediate [1] 1152/7
immediately [5] 1151/81154/101166/24
1169/21212/25
immigrant [1] 1175/11
immigrants [1] 1175/12
immigration [2] 1095/211095/22
imparted [1] 1138/14
impartially [1] 1121/3
implication [1] 1185/10
important [12] 1121/71122/191123/16
1124/21127/71129/81138/231172/25
1187/191191/101204/131204/15
impossibility [1] 1157/15
impossible [3] 1088/171165/61165/7
impress [1] 1123/1
impressions [1] 1137/21
inaccurate [1] 1092/11
inaccurately [1] 1123/24
include [2] 1142/161210/9
included [1] 1146/14
includes [5] 1121/121126/211131/15
1131/251132/13
including [7] 1107/81124/141133/1
1134/111188/81188/91190/1
income [1] 1159/15
inconsistency [1] 1170/15
incorporate [1] 1190/18
incorporated [6] 1190/51190/15
1190/171190/251191/21192/21
incorporation [1] 1190/7
incorrect [5] 1091/231093/21093/9
1093/91141/19
independent [1] 1137/16
indicate [2] 1094/231163/2
indicated [3] 1095/61096/191145/1
indicates [2] 1094/151140/16
indicating [1] 1186/1
indictment [20] 1117/101117/22
1120/161124/161125/71125/161127/21
1128/11129/241135/241136/31136/5
1136/71136/91136/241137/51168/3
1187/201212/11220/3
indifference [2] 1127/21129/3
indirectly [2] 1132/251134/10
individual [2] 1143/161212/1
individually [1] 1221/6
individuals [3] 1144/151149/11206/25
Industries [21] 1090/141142/211143/5
1143/231144/81148/21148/121151/19
1154/151154/241155/151155/16
1156/171157/241158/41160/81161/18
1161/231163/121207/91208/3
ineligible [1] 1140/15
influence [3] 1127/101129/121205/19
influenced [2] 1120/91137/17
information [36] 1091/231092/12
1093/21093/71093/141093/191093/20
1097/51097/111143/171149/51149/13
1150/111154/21154/71156/121157/4
1158/131159/231160/21160/41160/20
1161/171161/191162/11162/41168/19
1192/231206/11206/91206/121206/14
1206/211207/91211/71215/15
informed [1] 1094/18
initial [2] 1164/251165/1
innocence [1] 1120/19
innocent [2] 1120/191123/25
inside [2] 1085/151102/14
Instagram [3] 1177/161177/171177/17
instead [12] 1089/141090/61090/7
1096/121140/111142/21147/91155/6
1156/31158/41161/21164/7
institution [14] 1126/21126/41126/10
1126/111126/161126/171131/14
1132/101132/131134/51134/71142/10
1142/161143/8
institutions [3] 1176/41176/71177/7
instruct [1] 1119/24
instructed [2] 1139/161205/17
instruction [6] 1117/101119/111135/1
1135/251188/41216/8
instructions [23] 1080/81116/12
1116/171116/241118/121119/91119/18
1119/191119/231120/11120/31120/14
1120/151121/221130/171138/14
1142/111154/41169/231170/141171/11
1205/161205/18
instructor [1] 1087/16
instrument [3] 1131/181131/251134/5
instruments [2] 1131/251132/3
insurance [2] 1132/141198/9
insured [6] 1126/181132/141134/7
1142/91142/161143/8
intend [4] 1172/151172/151172/16
1193/7
intended [8] 1126/151128/221130/3
1136/221151/31168/251188/171193/7
intending [2] 1126/221199/19
intent [51] 1098/11115/241127/31127/6
1127/141127/151127/171127/19
1128/121129/31129/71129/151129/17
1129/201129/211136/41136/121136/14
1136/161136/191172/141172/18
1172/241173/21173/41173/71173/10
1173/131174/171175/21175/71176/17
1177/221177/231177/241177/25
1183/141185/101189/111194/18
1198/111199/61200/41200/191201/4
1201/101201/101202/51202/71206/22
1207/1
intentional [1] 1124/1
intentionally [6] 1105/31128/191135/8
1135/161183/151202/24
interest [2] 1123/51138/10
interesting [1] 1200/17
interestingly [1] 1156/22
Internal [5] 1139/91141/41141/20
1160/31169/1
Internal Revenue Service [5] 1139/9
1141/41141/201160/31169/1
Internet [3] 1161/101184/151218/15
interpret [3] 1086/251088/21178/5
interpretation [1] 1121/25
interpretations [1] 1176/12
interpreted [1] 1109/4
interrogated [1] 1108/11
interrogating [1] 1186/14
interrogation [6] 1103/131103/22
1105/111106/161108/71108/16
interstate [15] 1128/31128/151130/2
1130/81130/101130/131131/211131/24
1132/61132/101132/111132/151134/6
1142/141156/21
interview [12] 1082/91088/11089/7
1109/191112/111140/101140/11
1140/221147/151185/211209/10
1209/17
interviewed [5] 1082/71085/31089/10
1099/71198/7
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 168 of 185
I
interviewing [2] 1082/131088/16
invent [1] 1159/4
investigator [1] 1183/11
investing [1] 1168/17
investments [1] 1132/2
involved [7] 1131/21132/101132/20
1133/201134/161134/201142/15
involves [1] 1143/7
involving [4] 1131/241132/71132/9
1141/8
IP [2] 1161/61161/8
irrelevant [2] 1180/251217/16
IRS [58] 1140/181141/31141/61142/1
1143/31147/251148/241149/71149/9
1151/121154/141154/161155/71155/9
1155/141158/81158/251159/11159/17
1159/211163/231164/31164/41164/21
1165/11165/41165/81165/101167/8
1167/111167/131167/181167/24
1168/101172/161176/31176/91177/6
1191/141194/251195/21195/31195/4
1195/61195/91195/101195/141196/6
1196/241197/101197/151197/18
1197/181197/181202/241208/241210/5
1211/7
IRS's [3] 1140/191148/141156/1
is [356]
ish [1] 1159/15
isn't [4] 1121/141136/121172/251202/5
issue [15] 1107/21115/251121/21
1141/161155/41178/91180/61180/15
1196/131197/111206/121207/61212/3
1226/141226/17
issued [21] 1100/211142/211143/20
1151/121151/131153/91154/191154/22
1154/241155/41155/141157/161157/21
1158/31158/91159/101159/251196/14
1196/151205/31211/1
issues [1] 1204/14
issuing [4] 1152/21192/131192/13
1197/22
it [431]
it's [119] 1088/161088/191093/23
1094/11094/121097/81097/91097/20
1109/51117/161117/181117/231118/2
1127/51129/11133/131138/211138/23
1139/251140/181144/251146/91150/4
1151/131152/91152/241152/251153/7
1153/81153/221153/221154/211158/4
1158/51159/231161/51164/151165/11
1165/161165/241166/51167/21167/10
1170/31170/71170/111170/121170/21
1170/231171/191173/221173/25
1174/101175/211176/91176/121176/13
1176/231177/51177/161177/171177/21
1177/241178/11180/221180/231181/1
1183/181184/51185/31185/121185/14
1186/91186/101186/211187/71187/8
1188/31190/21192/81192/91192/11
1192/151192/151194/61194/81194/17
1194/181195/21195/81195/251196/16
1198/141198/171198/221199/131200/6
1200/141200/151201/21201/21201/7
1201/71202/11202/111202/111203/15
1203/161203/181204/131204/19
1209/191210/11211/41211/61211/18
1215/31215/91226/20
Italians [1] 1175/14
items [4] 1141/111169/31199/20
1220/19
its [3] 1172/41202/251204/16
itself [3] 1130/21150/21206/7
J
jail [2] 1194/121194/13
James [3] 1181/91181/111181/19
JANA [3] 1078/201230/41230/18
January [6] 1102/221102/231143/25
1154/241167/211189/20
January 4th [1] 1143/25
Jason [1] 1145/22
job [10] 1172/31172/41172/51172/5
1172/61174/241187/51205/51205/6
1215/18
jobs [1] 1103/4
John [4] 1145/221181/131181/13
1200/10
joins [1] 1135/8
JPMorgan [1] 1142/9
judge [9] 1114/251137/111140/24
1143/61169/71172/201209/251217/13
1218/1
Judge Brown [1] 1172/20
judges [2] 1138/91138/10
judgment [3] 1136/171173/81227/23
JULY [3] 1078/121080/31230/8
jumped [1] 1166/20
juncture [1] 1216/4
June [3] 1155/81195/191195/20
juror [17] 1080/61214/61214/91214/10
1215/91222/81222/111222/191223/2
1223/101223/181224/11224/91224/17
1224/251225/81225/16
jurors [19] 1081/41104/111108/2
1115/91118/201137/181138/21169/14
1171/141212/141214/21214/71219/1
1219/211220/171220/231220/24
1226/101227/9
jury [57] 1080/81104/141105/71105/19
1106/91106/101107/41107/101107/12
1107/151107/191109/211109/23
1115/151115/231116/61116/101116/10
1116/171118/121119/231120/41138/15
1142/111170/231171/191171/251188/4
1205/51205/161211/131211/211212/24
1216/31216/81216/231217/91217/23
1221/131221/141222/31222/121222/20
1223/31223/111223/191224/21224/10
1224/181225/11225/91225/171225/25
1226/21227/121228/81228/9
just [91] 1080/201084/161086/9
1086/211086/211088/61088/71092/11
1097/81103/131106/201106/201110/16
1111/251117/161118/51125/41126/20
1135/171138/61143/61144/11144/24
1145/181147/221148/11148/251149/10
1149/151149/161149/231153/19
1155/171155/221158/41159/31159/6
1162/211163/121164/11164/61169/11
1170/111170/211170/241171/31173/23
1177/201180/201181/201184/14
1186/171188/161189/21189/81190/7
1190/181190/251190/251192/91193/21
1194/191195/21195/81195/111195/14
1195/211195/231196/41196/51196/22
1197/11197/31197/151198/201200/23
1202/11204/141205/151206/61208/18
1210/81215/91215/101216/101219/5
1226/71226/81226/121227/181227/18
justice [1] 1172/1
justification [1] 1167/4
justify [2] 1166/251208/12
K
KARL [57] 1078/61080/241139/7
1145/231164/201168/141176/16
1176/191177/111177/111177/12
1177/181182/31182/101182/201182/25
1183/131183/191183/191184/11
1184/241185/11185/21185/181186/11
1187/101187/121188/11188/111188/15
1189/251190/11190/131191/41192/2
1192/101192/161193/61193/71193/14
1194/101194/231195/231196/41196/4
1196/211197/61198/61198/251199/13
1199/131202/231203/61208/41211/22
1221/151230/10
Karl Delano [9] 1139/71145/231164/20
1177/111177/181188/151189/251190/1
1208/4
Karl Delano's [1] 1168/14
Karl's [6] 1178/21184/121184/131187/7
1200/131200/14
Keanu [7] 1145/221173/51181/12
1181/191206/251208/41208/8
Keanu Reeves [1] 1181/12
keep [12] 1085/251107/201123/21
1141/231146/201160/71161/151171/11
1210/71212/61216/111218/22
keeps [2] 1146/101161/17
Kelley [8] 1214/221218/51218/19
1221/21222/51222/101227/61227/25
Kelli [3] 1178/71178/191179/20
Kelli Carpenter [3] 1178/71178/19
1179/20
Kelly [1] 1079/3
kept [5] 1103/91109/71160/161207/22
1207/24
kind [16] 1087/91131/21132/211140/15
1166/51174/71180/131182/21184/2
1190/111191/121201/101201/10
1201/211202/91203/11
kinds [4] 1130/201133/141179/18
1185/24
knew [23] 1091/221093/141093/18
1127/121129/141131/11131/71133/20
1134/131134/161135/181136/23
1144/171149/41149/61150/11153/3
1163/161181/111181/131183/24
1198/191205/21
know [103] 1086/181088/81088/24
1088/251089/51091/41091/111095/8
1097/231101/201103/41104/221109/1
1109/11109/31109/41109/51109/6
1110/231111/131111/141112/91112/11
1114/31114/151115/141117/251118/5
1132/201132/221144/141145/17
1146/161149/121150/191150/201156/1
1156/11173/161173/251174/11174/12
1177/81177/161178/11178/21178/20
1178/231180/41180/41180/51180/18
1181/111181/221181/231182/31182/5
1182/251183/71183/141184/81184/20
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 169 of 185
K
know... [41] 1185/11185/41185/5
1185/81185/141186/11186/41186/5
1186/81186/221186/231186/241187/3
1187/111187/151187/171187/21
1188/221189/231191/11191/171192/3
1192/221193/81198/181200/91200/10
1202/81204/181208/161208/171212/6
1212/151215/161215/191216/71217/10
1217/151218/191219/131220/12
knowing [2] 1135/211144/20
knowingly [14] 1091/251094/81126/8
1127/151127/251128/71128/181128/18
1129/161130/191130/241133/18
1183/151202/23
knowledge [4] 1111/151122/61157/1
1173/17
known [10] 1078/61127/121129/14
1130/201133/141139/81205/211211/22
1221/151230/9
knows [8] 1127/11129/21151/11151/1
1154/191157/231158/91158/11
Kobina [1] 1166/9
Kremkov [48] 1083/101083/111086/17
1090/141101/221102/11140/131142/21
1142/251143/51143/231144/81147/17
1148/21148/51148/121151/191154/15
1154/241155/151155/161156/17
1157/201157/241158/41160/81161/18
1161/231163/121163/191163/19
1163/241164/51164/71181/71183/6
1189/131189/201189/251190/12
1190/141191/31192/161199/121199/12
1207/91207/141208/3
Kremkov Industries [21] 1090/14
1142/211143/51143/231144/81148/2
1148/121151/191154/151154/24
1155/151155/161156/171157/241158/4
1160/81161/181161/231163/121207/9
1208/3
Kremkov's [1] 1152/22
Kwdzo [1] 1175/9
L
labor [1] 1086/5
lack [5] 1106/231115/181192/23
1198/121203/9
ladies [22] 1139/51139/151140/23
1141/231145/71150/221151/191154/14
1155/221156/111157/51158/151158/20
1162/241165/211166/71168/141205/14
1207/71208/151209/91211/4
lady [11] 1178/71178/81179/171179/22
1179/231180/181182/131182/15
1183/201183/211214/10
Lamborghini [9] 1141/121168/41169/4
1199/221199/231200/11200/11200/2
1203/3
land [5] 1164/161164/171165/13
1198/101199/17
Lane [1] 1166/8
language [1] 1190/9
lapse [1] 1123/25
laptop [1] 1218/14
large [1] 1153/22
largely [1] 1211/19
last [19] 1085/221085/241086/41086/4
1086/101088/231107/61110/241116/20
1117/51143/71156/201171/211171/25
1190/201195/211199/251201/61205/5
late [1] 1080/6
later [12] 1081/201085/141089/5
1091/121109/41153/191166/151177/2
1190/181192/251196/151197/4
launder [5] 1172/161185/71199/24
1201/221202/25
laundered [2] 1139/111211/9
laundering [13] 1124/251125/21130/16
1130/211133/121133/151133/161141/7
1141/101142/61162/131166/41198/21
laundry [1] 1087/9
law [14] 1079/41119/91119/251120/12
1120/131120/151120/181121/22
1132/231138/221171/121172/201180/8
1190/15
lawyer [1] 1187/4
lawyers [1] 1121/14
lead [1] 1105/18
leading [1] 1187/8
leads [1] 1170/1
learned [2] 1113/181166/18
learning [1] 1087/18
least [6] 1132/171178/101178/10
1183/111214/41215/3
Leatherleaf [1] 1155/6
Leatherleaf Trail [1] 1155/6
Leatherly [1] 1155/6
leave [4] 1127/191129/211139/17
1144/2
Lee [21] 1083/81085/221110/16
1110/211140/111140/171152/19
1152/211152/231158/191162/25
1168/161187/171188/121192/41192/4
1192/51192/71192/91192/121195/1
left [4] 1184/211201/251201/251220/20
legal [3] 1122/131190/111191/12
legitimate [1] 1163/17
lengthy [2] 1097/71097/9
less [4] 1095/51145/91196/181203/18
let [26] 1081/171085/51085/81099/14
1100/61100/141100/151100/171102/17
1103/51118/51125/51130/91132/15
1159/171175/21187/251212/61214/16
1214/191215/101216/71218/191219/14
1220/121220/25
let's [22] 1095/241105/231107/41107/4
1107/51107/71107/191118/171125/22
1130/151133/91169/111184/251185/11
1185/111190/191190/211192/11193/10
1198/211219/111219/19
letter [9] 1095/211154/141154/15
1154/211155/141155/151155/18
1155/251156/1
Lewis [18] 1082/81083/11089/15
1110/171111/51140/91149/31149/15
1149/201150/51151/251157/11160/18
1161/141168/181187/161188/121189/4
Lewis's [1] 1083/5
liability [1] 1159/16
liberty [1] 1204/14
license [3] 1160/231161/11168/20
licensing [1] 1198/9
lie [7] 1095/151096/221100/41112/13
1112/171152/101184/20
lied [10] 1095/131097/31100/31175/19
1175/211177/61177/61177/61184/19
1188/2
lies [3] 1141/241141/251160/2
life [3] 1113/101177/81204/14
light [2] 1144/191226/15
like [80] 1082/51084/161088/61089/7
1090/191101/211102/81102/81104/12
1104/141107/201107/241107/241110/9
1112/111116/181116/251122/71122/25
1133/61145/81146/31174/111177/5
1179/211179/251180/161181/41181/6
1181/91182/61185/31185/81185/14
1185/251186/11186/21186/211187/7
1187/181187/241188/31188/161188/21
1188/231191/51191/141193/21193/18
1193/211194/181194/211195/13
1196/211200/71200/81200/81200/22
1204/181205/101208/31208/31208/7
1210/241213/191215/31216/181216/24
1216/251217/71217/111217/181217/19
1217/201217/201218/161219/14
1220/211226/141226/16
likelihood [1] 1214/12
likely [6] 1147/61147/181149/251204/9
1204/91212/11
line [6] 1/61163/21163/211207/21
1211/241217/19
liquidity [1] 1166/25
list [8] 1087/91180/121183/51183/6
1183/171202/191208/51211/18
listed [3] 1144/161160/231206/25
listen [9] 1106/111119/181147/15
1187/91209/91218/101218/111221/4
1221/9
listened [1] 1147/14
literally [1] 1160/20
literature [1] 1101/11
little [12] 1080/61103/251169/11
1174/121184/141184/151186/151193/5
1198/241204/21204/21212/21
live [1] 1191/21
living [2] 1083/181083/20
loan [74] 1082/221083/21083/41090/6
1090/181091/91091/141131/121131/16
1140/151141/181141/241142/20
1142/211142/241143/131143/14
1143/171143/211145/101145/14
1146/251151/171152/81152/151152/18
1152/201152/221152/241153/51153/7
1153/91153/121153/191153/221153/22
1154/121155/91156/81156/91156/16
1162/201163/101164/31164/221165/24
1166/131166/191172/121174/91177/10
1177/141178/91178/131179/21179/3
1179/111179/231180/41180/151189/13
1193/81193/151194/91198/161201/20
1202/201202/231205/41206/61206/12
1206/201207/41207/6
loans [2] 1144/251156/7
local [1] 1084/15
location [2] 1131/81162/16
lock [2] 1109/21109/8
lockdown [7] 1081/171084/11085/9
1085/101085/131085/231102/10
logic [2] 1151/21159/20
login [1] 1161/7
Logistics [1] 1165/15
logs [1] 1157/1
long [10] 1100/71125/101125/14
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 170 of 185
L
long... [7] 1131/191144/51165/17
1168/191171/201186/31197/19
long-standing [1] 1165/17
longer [1] 1154/7
look [28] 1080/121103/41117/17
1172/211173/211180/241181/21181/2
1181/31186/11186/21193/211196/7
1196/221197/51197/111199/101199/11
1199/111200/11200/21200/41200/6
1205/61208/61210/11216/101220/25
looked [8] 1117/71179/131190/41195/8
1196/231216/71216/241216/24
looking [4] 1160/201166/141179/14
1192/25
looks [2] 1184/231185/3
Lord [2] 1175/231176/12
lose [3] 1107/61178/141202/9
loss [1] 1159/7
losses [7] 1158/231158/241159/4
1159/131160/81160/111161/25
lost [1] 1214/8
lot [15] 1172/101172/111180/20
1183/121183/131183/191196/16
1196/161201/131208/21208/41208/5
1208/141210/231228/16
lots [1] 1210/15
Louis [6] 1179/81179/101180/14
1181/101181/131181/24
Louis Glauser [1] 1179/8
love [1] 1198/22
low [1] 1204/14
lower [1] 1170/18
lowest [1] 1203/11
LUCIUS [6] 1078/61176/161176/20
1211/221221/151230/10
lunch [12] 1119/131119/141119/15
1119/161205/101212/251213/51213/8
1213/191213/201218/31218/20
lunchroom [1] 1212/22
luxury [2] 1152/121169/3
lying [4] 1096/241109/51175/181211/5
M
Ma'am [1] 1179/3
machine [1] 1230/7
made [35] 1082/41091/71091/81092/14
1092/161092/191093/161097/22
1111/121112/81124/91124/121124/15
1127/61129/71130/51140/141143/18
1145/251160/61168/121177/91180/9
1180/131188/81188/101195/21195/3
1195/41196/41196/41196/241197/17
1207/41220/21
magic [3] 1158/101190/51190/7
mailed [1] 1113/2
mainly [1] 1081/19
maintain [1] 1085/19
major [1] 1166/5
majority [1] 1103/2
make [39] 1097/21102/191104/13
1105/201106/11120/21122/21124/13
1142/51146/21146/51158/201161/12
1170/101175/231176/71176/141185/11
1185/151185/161188/241189/31189/4
1190/81193/101194/151194/191194/19
1195/51203/41205/51208/171209/25
1210/141211/61214/221215/101216/10
1221/4
maker [3] 1127/111129/131205/20
makes [6] 1127/21127/31129/21129/3
1146/61155/22
making [10] 1090/141110/71122/20
1136/221161/221188/241189/41191/6
1193/221218/17
mal [1] 1199/7
man [4] 1180/21184/101184/111192/6
management [2] 1136/181173/9
maneuver [1] 1088/15
mansion [1] 1139/12
many [8] 1144/241151/21170/10
1175/141175/141175/151193/21212/13
March [3] 1081/181151/51151/8
March 29th [1] 1151/5
marked [1] 1095/10
marriage [2] 1200/241200/25
material [24] 1126/121126/141126/24
1127/11127/61127/71127/91128/11
1129/11129/71129/81129/111130/1
1160/31180/111180/131181/11181/2
1181/161181/181183/71202/191205/18
1207/5
materiality [2] 1180/71205/15
matter [14] 1091/121097/201097/25
1116/21122/231127/111129/121134/13
1134/191165/91167/121205/201219/7
1230/8
matters [2] 1122/11180/22
max [2] 1084/101144/25
maximum [12] 1086/121086/161087/1
1087/221103/171108/211109/141110/7
1153/231186/201187/61209/19
may [34] 1/21/51108/161113/31121/23
1122/21122/141122/201124/21125/6
1125/71127/41129/51135/41135/5
1136/31139/61146/41153/211154/13
1154/201158/101171/151171/181179/9
1185/191187/111187/131188/11
1194/131203/251210/231219/61219/22
May 12th [1] 1188/11
May 7 [1] 1154/13
May 7th [2] 1154/201158/10
maybe [23] 1097/221100/111137/13
1170/101170/201170/241174/231181/9
1181/101181/101187/51197/21202/9
1202/131203/161203/161203/241204/5
1207/171208/91215/201217/51220/21
McDonald's [2] 1101/141101/15
me [86] 1081/171082/101085/51085/8
1086/31086/161087/251088/21088/5
1088/71088/81088/91088/251089/8
1089/181090/251091/11099/141100/6
1100/171100/201100/201100/24
1102/171104/131106/31109/71109/8
1112/81113/21118/51125/51130/9
1132/151141/211141/221159/17
1170/171170/221171/101171/121174/2
1174/61179/51179/81182/41182/5
1182/121182/131182/141182/16
1182/171182/181182/201182/221183/3
1187/251187/251190/191190/24
1193/211193/241197/121198/171200/1
1200/21200/41207/181207/201212/8
1212/101212/131212/151212/18
1212/181215/121216/71219/141220/7
1220/81220/121220/251226/131228/1
1228/181230/12
me -- transported [1] 1100/20
mean [29] 1081/231097/31116/18
1122/171123/211141/241142/11173/18
1174/41176/61182/21183/221184/10
1187/11188/31188/191188/201188/23
1189/11191/11197/171199/51200/7
1202/111208/71208/81215/151217/2
1226/6
meaning [1] 1202/9
means [27] 1107/91115/231116/4
1119/141127/141128/181128/22
1129/151129/161130/41131/101131/12
1131/201131/221132/161132/241133/3
1134/31134/71134/91142/21191/21
1191/251193/11206/131221/31222/5
meant [2] 1145/131153/16
mechanical [1] 1078/18
Medicare [2] 1148/171148/20
meet [1] 1178/21
member [1] 1154/16
members [3] 1171/181205/51211/14
memo [1] 1163/2
memories [1] 1137/20
memory [7] 1104/191106/231113/7
1114/11123/71123/251137/14
mention [3] 1140/91140/101169/22
mentioned [7] 1082/81083/71140/1
1145/191178/41182/11217/16
mentions [1] 1154/9
mere [1] 1144/1
merely [1] 1135/21
mess [2] 1179/71184/3
mess-up [1] 1184/3
message [1] 1157/13
messed [3] 1184/41184/61184/9
met [3] 1182/101207/171207/22
MF [1] 1186/6
MICHAEL [21] 1078/111083/81110/16
1110/211140/111140/171152/19
1152/211152/231158/191162/25
1168/161187/171188/121192/41192/4
1192/51192/71192/91192/121195/1
Michael Lee [16] 1140/171152/19
1152/211152/231158/191162/25
1168/161187/171188/121192/41192/4
1192/51192/71192/91192/121195/1
middle [2] 1097/81183/10
might [19] 1089/11109/41109/24
1122/241130/181138/221170/24
1171/111181/51181/61181/81202/13
1202/131202/141203/121221/71221/7
1221/81227/11
military [1] 1100/21
million [63] 1081/121090/171140/2
1140/181141/41142/231145/11145/2
1145/61145/131145/141147/101149/13
1149/141151/41151/141151/161151/17
1152/21153/11153/241155/241159/13
1159/141159/171159/181160/10
1160/111160/141161/231162/81162/9
1162/211162/211162/221163/251164/8
1164/111164/181165/111166/17
1166/191166/211167/91167/171167/22
1168/221168/231178/91178/101178/11
1178/171179/41179/161180/61181/19
1195/31195/151195/231196/241197/16
1201/181207/12
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 171 of 185
M
millions [8] 1158/141161/201163/10
1168/171169/11210/31210/41211/8
mind [9] 1089/111123/211136/41138/5
1141/231160/71161/151210/71216/6
minds [1] 1107/6
mindset [2] 1086/191088/3
mine [25] 1081/91081/121086/7
1086/181089/41089/51093/211101/21
1102/151102/191102/241102/251103/1
1103/91103/91110/71144/121145/8
1153/51168/201174/31182/41191/9
1192/101208/1
miners [1] 1084/25
mines [7] 1084/221085/151086/1
1089/61102/41110/241181/7
mining [1] 1081/16
minor [3] 1092/161094/11094/3
minute [10] 1104/91116/251128/25
1129/91129/151169/111181/171219/11
1226/71226/8
minutes [8] 1116/161116/171116/19
1118/61118/81119/91205/101213/7
miserably [1] 1172/18
mismatch [1] 1157/14
missing [1] 1118/21
misspelled [1] 1155/5
misstated [4] 1105/51106/51106/6
1123/24
misstatement [2] 1124/11124/2
mistake [14] 1093/161095/221097/3
1097/221097/231112/91123/211128/20
1136/101136/171173/81177/71184/21
1220/21
mistaken [5] 1136/171153/21173/4
1173/61173/6
mistakenly [1] 1098/10
mistakes [6] 1097/21175/241176/7
1176/141176/151195/5
MLB [2] 1078/41230/10
moment [4] 1125/41190/81226/5
1227/18
momentarily [1] 1217/8
Monday [3] 1214/101215/111215/17
monetary [7] 1131/181131/251131/25
1133/191134/31134/41134/17
money [150] 1084/171101/121101/22
1102/11110/71124/251125/21126/3
1126/101126/221127/171128/23
1129/181130/161130/201131/11131/4
1131/131131/221132/21132/201132/22
1133/111133/141133/161139/11
1139/131140/191141/11141/71141/10
1142/61146/11146/51147/51147/7
1150/61151/41151/51151/81151/9
1151/171151/181151/211151/21
1151/241152/11152/31152/51152/9
1155/91155/211156/31156/71156/9
1158/251159/11162/101162/131162/19
1163/111163/141163/181163/20
1163/241164/171164/211164/251165/1
1165/41165/41165/51165/71165/8
1165/221165/251166/21166/41166/13
1166/231166/251167/31167/81167/9
1167/111167/121167/221167/231168/1
1168/51168/91168/101172/161175/4
1176/181176/191176/211177/20
1181/171181/241182/201182/211183/3
1183/31183/41183/41183/41185/6
1185/71185/91185/151192/41192/8
1192/151192/161192/171193/18
1194/111194/171194/251195/11195/12
1196/101196/191197/71197/101197/20
1197/241197/251198/11198/31198/16
1198/211199/31199/51199/91199/18
1199/191199/241200/121200/22
1201/171201/221201/241202/251210/6
1210/141210/191210/241211/9
Monica [14] 1145/241150/131150/17
1150/181150/201150/241150/251182/2
1182/51182/91182/231183/91200/9
1208/3
monster [1] 1159/24
month [4] 1112/121145/91195/21
1207/12
month's [1] 1152/4
monthly [3] 1145/21145/21145/12
months [12] 1081/201081/201085/14
1100/191102/111166/121166/15
1193/121193/201196/151197/41197/13
more [28] 1082/31086/11099/13
1115/121115/131119/111131/25
1133/231134/211137/151140/21141/4
1145/61146/51148/111149/171153/14
1154/41154/61191/41191/211199/22
1203/21205/101208/61212/111212/21
1227/18
morning [3] 1118/81139/51158/6
most [9] 1087/181102/91102/10
1102/121102/141121/71137/131188/14
1192/24
mother [2] 1113/221182/17
motion [3] 1115/161115/191115/21
motions [1] 1227/20
motive [2] 1136/61152/14
move [5] 1118/11163/181175/51210/13
1222/4
moved [3] 1111/81139/131153/24
moves [2] 1163/111164/8
movie [1] 1185/8
movies [1] 1186/5
moving [5] 1110/41131/221162/10
1210/191218/22
Mr [5] 1118/231147/251165/61171/16
1179/9
Mr. [47] 1081/81082/71085/61085/22
1086/111087/51096/21098/221100/9
1101/101108/71119/11154/191159/9
1160/171160/171161/151162/18
1166/111166/181169/51171/241172/12
1172/121172/131173/121173/181174/4
1174/101174/131174/221174/24
1177/231178/201179/131180/14
1183/251184/11184/31184/231186/21
1186/231187/21207/161207/251207/25
1226/14
Mr. Delano [24] 1081/81082/71086/11
1087/51096/21100/91101/101108/7
1119/11160/171162/181169/51171/24
1172/121172/121172/131173/12
1173/181174/101174/241178/20
1180/141207/251226/14
Mr. Delano's [3] 1161/151177/23
1179/13
Mr. Hazel [1] 1159/9
Mr. Lee [1] 1085/22
Mr. Oppong [11] 1166/111166/18
1174/41174/131174/221183/251184/1
1184/31184/231207/161207/25
Mr. Torjagbo [7] 1085/61098/22
1154/191160/171186/211186/231187/2
Ms [3] 1153/131213/241222/10
Ms. [18] 1138/171149/151150/15
1151/251151/251153/231164/14
1168/121210/111214/41214/221217/5
1218/51218/191221/21222/51227/6
1227/25
Ms. Andrea [1] 1149/15
Ms. Carpenter [1] 1153/23
Ms. Connors [1] 1138/17
Ms. Dean [1] 1214/4
Ms. Kelley [7] 1214/221218/51218/19
1221/21222/51227/61227/25
Ms. Lewis [1] 1151/25
Ms. Richardson [5] 1151/251164/14
1168/121210/111217/5
Ms. Sweeten [1] 1150/15
much [15] 1090/141091/71091/8
1124/121148/251160/161171/111175/2
1198/231198/241202/91205/111221/1
1222/21228/20
muck [1] 1179/22
muckety [1] 1179/22
muckety-muck [1] 1179/22
multimillion [1] 1144/3
multimillion-dollar [1] 1144/3
multiple [8] 1125/51125/71139/12
1139/131152/81154/101157/61210/7
multiply [1] 1090/17
must [39] 1119/251120/61120/81120/9
1120/121120/131120/141120/20
1120/221121/181122/161122/17
1123/241124/101124/111124/13
1127/241134/151135/191136/11136/13
1136/251137/21137/81137/141137/15
1137/161137/221137/231137/251138/2
1177/171188/71188/81190/91195/8
1202/61204/241204/25
my [57] 1082/231085/61085/211086/8
1086/191087/241088/31088/191089/11
1092/161092/191093/211094/11094/2
1094/191100/71100/201100/211105/4
1108/251108/251112/21112/51113/2
1113/221113/221114/251115/161116/1
1119/231119/241120/141121/22
1149/201152/151153/51158/191159/5
1174/61175/21175/111175/211182/17
1182/191183/31183/101186/241190/17
1206/161206/171214/41214/181215/3
1215/131219/21226/151226/22
N
name [71] 1083/51083/71083/241084/4
1098/41098/61112/191143/51148/4
1148/61150/171150/181150/241152/22
1154/111154/121154/181154/24
1155/151155/181158/31158/41163/12
1164/11164/41164/201164/211164/22
1175/21175/31175/31175/81175/16
1176/191176/221176/231176/23
1176/231177/91177/111177/131177/18
1177/191179/81179/101179/201183/5
1183/91183/101183/111183/161183/16
1184/21189/241190/11198/251199/12
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 172 of 185
N
name... [14] 1200/171200/181200/20
1200/211200/231200/241200/251201/1
1201/51201/81201/91208/21210/19
1216/24
names [15] 1145/211150/141175/13
1175/131180/121181/161183/51208/3
1208/31208/41208/51208/71208/8
1208/101208/11
nation [1] 1171/7
national [1] 1110/22
natural [3] 1127/101129/111205/19
naturally [1] 1123/23
nature [8] 1127/211129/251131/8
1134/141162/161164/231166/21201/3
necessarily [2] 1119/211122/22
necessary [2] 1120/71136/5
need [22] 1104/61115/51115/15
1147/151149/191149/221152/17
1152/201154/41159/21159/41169/10
1174/101174/191174/251200/31209/9
1214/231216/11226/81226/241227/13
needed [6] 1088/21094/241156/6
1174/81208/111208/14
negate [1] 1207/1
negative [3] 1159/141159/151195/24
negatives [1] 1196/1
negotiable [1] 1132/3
neighbor [2] 1122/111122/11
never [30] 1082/81083/31083/71089/14
1095/101098/31098/31137/81137/24
1139/251140/91140/101141/51143/20
1145/191148/201149/61158/151163/9
1168/221168/231190/61190/101191/23
1191/231194/141198/181207/25
1208/201228/13
new [6] 1097/251098/31198/51198/10
1215/171215/18
news [2] 1113/161186/9
next [12] 1119/81155/71157/181158/6
1163/211194/61196/131197/21197/4
1200/131211/121227/13
nice [2] 1198/221199/21
nicely [1] 1179/18
Nicholas [1] 1079/3
Nine [2] 1220/191221/24
no [112] 1/131078/41080/101080/13
1083/61083/91083/171083/231083/24
1086/11089/161090/151090/211092/23
1093/41094/101094/201095/91095/10
1096/251097/31098/151101/41101/5
1107/71109/181111/41111/111111/17
1111/191112/151112/181113/91114/2
1114/51114/51114/81114/161114/24
1115/131117/161118/161118/25
1122/131133/81138/161146/81146/18
1147/171148/81148/101148/111148/19
1150/241152/91153/51153/81154/7
1154/181155/221156/151156/171160/7
1160/81160/251162/51162/61163/17
1168/101168/161168/171170/221171/1
1173/241174/191174/241177/191179/1
1179/51182/151183/91183/101183/10
1184/101189/21190/141190/161192/2
1195/91197/251198/131198/141199/2
1199/141200/41200/151203/71205/4
1206/21207/31207/71207/131207/19
1208/171210/201215/21215/171216/7
1217/151218/151228/51228/5
No, [8] 1080/111107/181115/21116/8
1117/181119/51138/181228/6
No, Your Honor [8] 1080/111107/18
1115/21116/81117/181119/51138/18
1228/6
nobody [2] 1173/251177/4
none [2] 1178/61193/3
nope [4] 1178/201178/211178/22
1183/2
normal [1] 1130/12
normally [4] 1130/91130/111146/24
1179/24
NORTHERN [3] 1078/11221/121230/5
not [296]
note [5] 1/121212/91212/141212/18
1217/21
notes [5] 1119/211137/121137/17
1137/191172/3
nothing [11] 1081/151082/11090/16
1094/181138/161148/141160/81193/16
1199/221203/21207/14
noticed [1] 1170/16
notion [3] 1177/241180/81180/9
notorious [8] 1141/151141/251142/2
1199/141199/231200/41203/21203/3
November [2] 1228/21230/14
November 3rd [1] 1228/2
now [81] 1083/121085/131089/51090/6
1090/251091/21091/161095/161095/16
1096/21096/91098/131098/221104/24
1105/201107/11108/71108/161110/16
1110/161110/231111/11111/21111/7
1111/101111/121117/21118/81119/17
1119/171138/121138/191141/131142/8
1142/111143/61143/221144/101145/15
1145/161146/121150/131151/181153/9
1156/181156/221158/91164/31164/16
1165/131165/141165/231166/41166/15
1174/111178/121180/71185/41185/18
1186/101187/41187/241191/31191/5
1191/61192/11194/101196/31196/13
1196/181197/21198/41201/81205/15
1206/131207/241209/191215/231217/8
1219/171221/2
nowhere [1] 1150/8
number [64] 1/61/61088/71090/23
1091/171094/221095/61095/111096/4
1096/71096/231097/11097/151097/17
1098/11103/71103/81103/171104/5
1110/81111/211122/211124/181144/23
1148/11157/81157/121158/21158/3
1158/101159/61159/71160/131160/16
1162/71183/101187/61189/71189/17
1189/191190/131196/51197/101197/10
1208/181209/11211/181214/221220/10
1220/191221/131222/81222/111222/19
1223/21223/101223/181224/11224/9
1224/171224/251225/81225/161230/10
Number 1 [1] 1189/17
Number 14 [1] 1223/18
Number 2 [1] 1222/19
Number 23 [1] 1224/9
Number 24 [1] 1224/17
Number 27 [1] 1224/25
Number 29 [1] 1225/8
Number 35 [1] 1225/16
Number 9 [1] 1220/10
numbers [8] 1135/231148/141158/17
1162/31208/161208/211208/231209/5
nurse [1] 1214/11
O
oath [2] 1209/161209/25
object [1] 1106/4
objected [1] 1106/5
objection [3] 1100/121104/31138/13
objections [6] 1104/71104/121107/7
1118/111170/221215/6
observe [2] 1123/91123/9
obtain [2] 1127/161129/18
obtained [8] 1091/191132/251134/10
1134/171134/221155/101167/12
1208/21
obviously [1] 1181/18
occurred [1] 1125/18
off [21] 1087/91108/251127/191129/22
1152/41152/51152/81152/81154/11
1162/221163/151169/41177/131182/14
1182/151182/251186/241194/11
1194/171201/81206/8
offense [5] 1125/61125/181135/24
1143/101167/25
offenses [1] 1125/3
offers [1] 1124/8
office [8] 1079/21079/41092/211112/5
1155/121155/141184/131189/24
officer [1] 1212/10
offices [1] 1230/6
official [8] 1/11/21/31/71/141078/21
1230/41230/19
offset [1] 1159/13
oh [24] 1081/11089/251090/11094/19
1117/141174/21174/131178/241182/3
1182/131184/191185/71185/81187/24
1191/51191/141196/31196/251197/15
1202/141202/161205/21219/141220/21
okay [121] 1080/161080/181080/19
1080/221082/71086/111086/231088/11
1089/21089/211092/181099/41100/6
1100/141100/151102/81103/131104/7
1105/71105/211107/91108/131108/19
1108/211111/151113/161115/41115/6
1115/211116/41116/91116/191116/20
1117/31117/201118/21118/51118/6
1118/111119/21119/61119/121119/15
1119/201119/211119/231125/12
1125/221131/201133/71134/251138/19
1139/31153/171159/31169/101169/11
1169/181186/221187/241190/22
1195/101197/31205/91205/91205/11
1211/121212/11212/31212/71212/15
1212/201213/31213/61213/91213/14
1213/171213/221213/241213/25
1214/121214/131214/241215/21215/5
1215/61215/241215/251216/61216/12
1216/131216/201217/251218/20
1218/221219/81220/71220/111220/13
1220/141221/11221/51221/71221/9
1221/101222/21222/51222/91226/1
1226/61226/71226/111226/221227/1
1227/21227/101227/161227/181228/3
1228/71228/17
old [13] 1094/51094/81098/31100/19
1111/241113/181113/191157/31160/23
1161/11168/191177/11200/21
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 173 of 185
O
older [2] 1184/241207/18
Oliver [1] 1145/23
Oliver Twist [1] 1145/23
omission [1] 1124/9
once [7] 1082/81083/31083/71103/1
1115/251128/221210/6
one [132] 1080/61080/141080/16
1082/151084/251089/41089/221091/17
1095/61098/31098/31098/181099/13
1101/151117/171117/171117/18
1119/111120/31123/11124/191124/21
1125/41125/81125/141125/241125/25
1128/11131/241137/21138/21139/16
1141/51142/91144/221146/191148/13
1148/181149/31149/181150/51150/6
1150/101150/111150/141150/251151/3
1151/141152/41152/211153/61153/13
1156/231156/231156/241156/25
1156/251157/81157/191157/201158/3
1158/51158/61158/111158/161161/7
1163/181165/141166/51168/251169/22
1169/231173/251176/81176/111176/11
1176/171177/71177/71179/121188/6
1189/41189/191191/41191/121191/14
1191/141191/171192/71192/131192/17
1192/181193/41193/141193/151195/4
1199/131200/131200/161200/16
1200/171201/111201/121201/14
1201/161201/181201/191209/11209/3
1210/211211/141211/191211/21
1211/241212/11212/31212/141213/23
1213/241214/71214/81215/81216/1
1220/201221/71221/141222/81222/8
1226/51227/101227/181228/1
ones [8] 1133/101140/11148/31161/8
1194/31204/161205/251220/19
ongoing [1] 1217/9
only [37] 1/21/71090/101091/14
1092/241093/41095/41118/11120/8
1120/251121/111125/81125/191126/6
1128/51130/221133/161134/201137/4
1138/11138/101140/131146/141150/18
1150/231151/141154/231155/21155/7
1165/31166/141178/81204/161209/2
1215/11217/51220/20
open [13] 1080/31141/151141/25
1142/21155/141164/171165/181199/14
1199/221200/41203/11203/21230/8
opened [6] 1141/141163/131163/13
1165/151165/171190/16
operated [1] 1216/25
operating [2] 1085/101144/3
operation [12] 1081/211086/181143/23
1156/131158/131189/151190/10
1190/101190/121192/201207/10
1207/15
operations [4] 1140/131147/171156/16
1156/17
opinion [6] 1121/211136/151136/16
1138/41173/31173/4
Oppong [20] 1166/91166/111166/18
1174/41174/131174/221174/231183/25
1184/11184/31184/101184/211184/23
1185/41190/31200/31200/81207/16
1207/161207/25
opportunity [9] 1082/101094/23
1097/131116/91120/21123/81136/6
1138/211209/6
opposite [1] 1115/24
order [6] 1093/81093/241096/12
1096/221145/101210/20
orders [1] 1132/2
Ordinarily [1] 1135/4
ore [3] 1085/181086/11102/16
orientation [1] 1215/18
original [3] 1197/221210/221211/2
originally [1] 1100/18
other [47] 1085/11097/101103/4
1113/101118/11118/231123/131123/14
1123/171124/71126/101131/131131/18
1131/221132/161135/101135/13
1135/191137/31137/171137/231138/2
1138/131139/251142/171143/101148/3
1148/41151/191155/21157/121168/10
1182/241183/111184/81195/71195/7
1196/141200/71204/221206/251210/20
1212/141214/91215/181220/191226/2
others [2] 1136/221138/7
Otherwise [1] 1115/19
ought [1] 1169/25
our [7] 1107/61148/91173/111177/8
1205/101214/71215/22
out [75] 1089/221089/251097/21097/10
1097/161097/171098/201104/91111/16
1116/61117/231118/31120/141126/1
1126/21126/81126/91126/221127/25
1128/41128/161128/231130/41143/7
1145/61145/201147/51148/231149/3
1149/181149/181149/221151/41152/2
1153/241159/221160/41162/191163/4
1164/41164/171165/21167/161169/1
1171/121178/101178/111181/24
1182/121182/201184/41184/51185/16
1192/51192/61192/111193/181195/23
1196/101196/181196/211197/11197/3
1197/131197/161199/101201/17
1201/181201/191201/241205/24
1206/151208/81208/101226/7
outcome [1] 1123/6
outside [2] 1105/191132/19
over [41] 1081/111084/151088/20
1088/211088/211098/81115/51117/5
1122/231124/191130/51137/151138/8
1140/181142/101143/61145/21145/13
1148/151148/151148/151150/91150/9
1150/91152/11162/121163/111164/8
1165/201166/61166/71168/131168/13
1185/191196/151201/41201/51201/18
1209/121209/121213/5
overcome [2] 1182/61182/7
overlooked [1] 1097/23
overwhelmingly [1] 1169/5
owe [1] 1159/1
owed [4] 1162/91195/211196/19
1196/20
owes [1] 1158/25
own [11] 1082/231083/21092/61121/7
1121/241121/251138/41151/201176/6
1177/81183/4
owned [1] 1126/3
owner [2] 1083/101083/11
ownership [3] 1131/81132/31162/16
owning [1] 1208/1
Owusu [1] 1145/7
P
p.m [1] 1229/1
pack [1] 1194/20
page [7] 1/61117/51133/61172/22
1172/221193/231202/4
Page 17 [1] 1133/6
Page 19 [3] 1172/221172/221202/4
pages [3] 1089/231148/141208/7
paid [23] 1081/111141/51145/61147/7
1149/131152/81152/81152/191158/15
1161/211168/221168/231172/21178/15
1178/161178/171178/181181/241192/7
1196/101198/81198/91206/2
pan [1] 1086/1
pandemic [5] 1081/91081/151081/24
1146/221152/16
panned [1] 1085/24
panning [1] 1085/17
paper [1] 1148/23
paperwork [9] 1141/171141/181141/21
1144/11148/231180/241180/251181/3
1205/24
paralegals [1] 1219/2
parents [6] 1092/161092/191092/20
1093/211094/21100/20
parking [1] 1228/16
parse [1] 1165/2
part [15] 1080/141094/251102/10
1116/201122/211130/131131/71155/4
1171/71172/251192/181193/191210/15
1214/41215/4
partial [1] 1/9
participant [1] 1135/20
participate [1] 1131/11
participated [2] 1128/81135/16
particular [3] 1122/221123/31150/20
parties [6] 1119/91120/11121/16
1211/171221/81227/19
partner [1] 1192/5
parts [2] 1102/91188/21
party [2] 1170/121222/3
passive [2] 1171/101171/11
passport [10] 1091/201091/231091/25
1093/31093/51093/171093/181112/1
1112/51112/10
passports [1] 1175/22
past [1] 1093/6
paste [1] 1118/1
pay [17] 1138/231146/251147/2
1149/191152/151158/191159/21159/5
1168/121192/11193/191194/251195/1
1196/171198/91198/181198/19
paycheck [2] 1146/211163/3
paying [9] 1082/21148/91150/81152/4
1163/151167/201168/211169/41192/4
payment [7] 1140/171145/81194/4
1194/81194/81194/91196/24
payments [6] 1193/131193/201193/22
1194/51194/51197/16
payroll [52] 1081/121089/151089/17
1089/181089/191089/221089/221090/1
1090/71090/111090/221091/101144/13
1144/201145/21145/21145/31145/4
1145/51145/121145/161145/211145/25
1146/81146/171148/151149/131150/2
1150/31150/71150/141150/201150/25
1152/151152/181153/41153/51153/7
1153/81153/171162/231162/251163/1
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 174 of 185
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payroll... [9] 1163/221168/231168/24
1207/121208/51208/61208/101208/13
1210/19
PDF [1] 1/1
peasy [5] 1203/171203/181203/20
1203/211203/25
penalty [1] 1097/4
penny [1] 1150/6
people [43] 1084/21089/41089/4
1093/211097/21110/141110/191111/12
1111/161113/101123/231132/17
1132/171132/181139/251146/13
1146/141150/181150/231151/21170/10
1173/191173/211175/131175/151178/5
1178/61183/111184/31184/51184/8
1188/141189/121191/21192/71192/24
1193/171197/91200/71207/221208/9
1213/181215/18
per [2] 1146/11209/3
percent [4] 1178/131178/151191/21
1191/24
percentage [2] 1178/171192/10
perfect [6] 1175/231176/41176/10
1176/131195/61198/13
perfectly [1] 1097/10
performed [1] 1135/3
perhaps [3] 1179/251204/11204/2
period [1] 1/4
perjury [1] 1097/5
permanent [1] 1110/14
permitted [1] 1137/12
person [30] 1098/171111/51122/5
1122/61127/81129/91135/41135/5
1135/61135/71135/81135/101135/11
1135/151145/251146/61146/61150/19
1179/31179/121179/171180/11180/3
1183/201183/221191/151209/31216/15
1216/251228/11
person's [3] 1127/101129/121205/19
personal [7] 1123/51132/11164/1
1164/61164/91164/171199/20
personally [4] 1130/51135/31151/1
1190/21
phone [4] 1097/171107/131178/22
1214/22
photographs [1] 1177/15
phrase [2] 1132/131133/3
pick [2] 1176/221181/10
picked [1] 1112/5
picky [1] 1170/21
picture [2] 1186/41216/15
pie [1] 1174/23
piece [4] 1165/131174/231191/10
1202/2
pieces [2] 1176/171187/12
pile [1] 1085/24
piles [2] 1172/71172/7
pilot [11] 1083/121083/161084/51084/7
1084/81087/141088/141095/11151/2
1182/101182/10
place [12] 1081/181098/251100/7
1110/141110/141134/11139/141144/9
1146/151147/191156/141168/21
plain [1] 1199/2
Plaintiff [2] 1078/41079/2
plan [5] 1126/211128/221136/81194/14
1194/15
planned [2] 1174/21209/7
plant [1] 1217/21
plastic [13] 1151/101163/51169/4
1185/21185/21185/51185/51185/7
1185/71185/91185/121185/171194/22
plausible [1] 1149/16
play [2] 1107/241193/5
played [1] 1193/11
pleasant [1] 1228/21
please [12] 1080/231081/61104/9
1110/11138/231139/41139/61146/24
1171/181205/61205/131216/11
plenty [2] 1106/251191/1
PNC [6] 1142/171163/121163/25
1164/181165/181199/12
point [21] 1095/161104/141105/3
1106/11109/171111/121113/131122/22
1131/111143/71147/81154/201155/19
1164/241187/201191/51191/171201/8
1208/221213/211216/9
pointed [3] 1145/201164/41208/8
points [2] 1089/221089/25
pole [1] 1122/12
poll [1] 1222/4
polled [1] 1222/3
polling [1] 1225/24
poor [1] 1082/6
portal [1] 1190/2
portion [1] 1/5
position [1] 1215/22
possession [1] 1112/4
possibility [1] 1207/7
possible [7] 1095/231120/241135/2
1149/91155/131207/141212/11
possibly [7] 1144/211147/51156/11
1203/241204/51204/61204/23
post [3] 1155/121155/131227/20
post-trial [1] 1227/20
postal [1] 1155/17
potted [1] 1217/21
PowerPoint [1] 1216/22
PPP [66] 1082/131082/211083/21083/4
1084/161090/61101/121101/151101/22
1102/11110/101110/131140/151141/1
1141/241142/201142/211142/24
1143/131144/251146/111146/191148/2
1150/11151/171151/181151/211152/5
1152/91152/221153/121155/91156/5
1162/201163/101163/201164/31164/22
1164/251165/41165/71165/101165/24
1166/131166/191166/221167/31167/11
1167/171167/231168/11168/91172/12
1172/151174/91177/101177/141183/4
1189/131192/31193/81197/201197/25
1198/31201/201202/23
PPP loan [28] 1083/21083/41090/6
1140/151141/241142/201142/21
1142/241143/131151/171152/22
1153/121155/91162/201163/101164/3
1164/221165/241166/131166/19
1172/121174/91177/101177/141189/13
1193/81201/201202/23
PPP loans [1] 1144/25
practice [1] 1190/17
practicing [1] 1190/15
precise [4] 1089/51127/211129/25
1134/14
precisely [1] 1158/10
prejudice [1] 1120/10
preparation [2] 1/131136/8
prepare [1] 1082/21
prepared [6] 1090/11149/41195/18
1195/181195/201211/17
preparing [1] 1089/19
preposition [1] 1171/2
presence [1] 1105/19
present [4] 1093/231096/121114/6
1135/18
presented [4] 1095/201112/231120/9
1138/13
presenting [2] 1093/181183/15
president [1] 1179/22
presumes [1] 1120/18
pretenses [9] 1126/41126/111126/13
1126/231127/161128/91128/101128/24
1129/17
pretty [6] 1107/51117/161179/22
1188/231202/141211/18
prevails [1] 1228/11
preventing [1] 1082/2
previously [1] 1115/17
price [2] 1166/151166/20
principal [4] 1146/151147/191156/14
1168/21
principally [5] 1191/111191/131191/16
1191/201191/25
prior [5] 1097/151135/231153/12
1196/201207/15
priority [1] 1137/15
probably [12] 1107/11166/191181/11
1191/211197/91198/51201/61201/7
1203/191203/201204/71204/7
problem [2] 1140/191141/18
problems [3] 1113/231118/121216/7
procedure [1] 1226/25
proceeded [1] 1109/1
proceedings [6] 1078/121078/18
1228/251230/81230/111230/13
proceeds [16] 1131/21131/91132/24
1133/211133/241134/91139/111142/4
1142/241156/161162/171164/10
1165/111167/61167/171167/25
process [2] 1085/171209/2
produce [1] 1120/20
produced [1] 1078/18
program [10] 1146/191146/211147/10
1152/181163/41163/221172/151198/4
1198/51198/14
prohibited [1] 1/8
promise [1] 1131/12
promises [8] 1126/51126/121126/14
1126/241127/161128/111128/24
1129/18
pronunciation [1] 1179/7
proof [17] 1120/231120/251121/5
1121/51122/81127/181129/201135/15
1135/171139/11203/61203/71203/17
1203/221204/81204/91204/11
properly [1] 1089/8
properties [1] 1210/21
property [30] 1126/31126/101126/23
1127/171128/231129/191131/11131/4
1131/131132/81132/201132/221132/24
1133/211133/231133/241134/91134/14
1134/161134/191134/211141/81164/16
1164/161164/201165/201165/23
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 175 of 185
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property... [3] 1166/101167/51210/20
proposed [1] 1117/7
prosecuting [2] 1169/241170/2
prosecutor [4] 1101/181108/131187/4
1192/2
Protection [3] 1152/181163/31163/22
Protocol [1] 1161/10
prove [35] 1120/191120/201120/24
1122/91125/181125/191127/201127/22
1129/231130/11130/61134/161134/21
1135/21136/131136/141172/61172/10
1172/141173/11173/11175/61175/7
1180/101180/111183/121183/12
1183/131183/141202/61202/61203/7
1203/91203/91204/20
proved [14] 1120/61121/91125/91126/7
1127/241128/61130/221133/171172/9
1173/111204/171204/181204/191205/1
proven [4] 1115/181121/191139/7
1189/10
provide [6] 1090/181093/71097/15
1154/41154/211218/13
provided [12] 1082/151090/221091/10
1093/221100/241143/201151/151153/7
1153/151153/161154/81216/8
providing [5] 1143/171150/111160/4
1207/21211/6
Proving [2] 1127/171129/20
provision [1] 1117/23
publish [1] 1221/2
published [11] 1222/121222/201223/3
1223/111223/191224/21224/101224/18
1225/11225/91225/17
pull [2] 1095/241178/9
pulled [2] 1178/101193/18
punishment [2] 1137/81137/10
purchase [10] 1131/121131/171166/15
1166/201167/141168/81168/91168/10
1210/201210/21
purchased [2] 1141/111167/6
purchases [3] 1139/121203/31210/14
purchasing [2] 1152/121165/20
purported [1] 1145/4
purpose [5] 1127/211129/251146/19
1163/21163/16
push [3] 1206/191206/191217/19
put [31] 1080/241091/51110/101158/22
1158/221158/231159/61159/71164/5
1164/61168/81168/81171/231186/7
1186/121188/121191/71193/211194/3
1195/151197/81197/91198/161199/5
1199/91211/231215/111216/21216/22
1217/141218/5
puts [1] 1164/7
putting [3] 1141/231141/251145/13
Q
qualifications [1] 1087/10
qualified [1] 1191/8
qualifies [1] 1191/15
quarterly [1] 1148/8
quarters [2] 1085/161102/15
question [34] 1082/171082/191083/1
1085/61086/31086/91086/191087/1
1087/221089/161090/31096/41099/13
1103/181104/41104/161105/51105/15
1105/161105/161106/81106/131106/14
1109/101109/121113/31144/71184/25
1187/31187/111211/191211/201211/25
1226/15
questioned [2] 1166/181166/20
questions [25] 1080/81089/201095/5
1097/131097/201101/51101/231103/14
1106/71108/131109/231111/201114/25
1122/231123/111181/51181/61181/8
1186/161196/81209/231211/191212/20
1213/191222/9
quick [4] 1115/41116/141116/25
1169/11
quickly [3] 1163/91212/101216/12
quote [1] 1170/11
R
ran [1] 1194/11
range [3] 1141/121166/141167/15
Range Rover [1] 1167/15
rather [1] 1211/2
rattled [1] 1087/9
RDR [2] 1078/201230/18
reach [5] 1111/91111/161115/231122/3
1138/3
reached [2] 1182/121212/7
react [2] 1088/201088/21
reacted [1] 1217/24
reaction [1] 1088/14
read [20] 1090/81091/121095/21101/11
1104/191106/221116/111116/18
1116/241117/41121/181135/251135/25
1170/61172/201181/151181/221183/7
1187/231221/3
reading [1] 1169/22
reads [1] 1221/13
ready [6] 1080/71169/201218/41218/6
1218/251219/17
real [10] 1094/191110/191111/51113/7
1121/21132/71138/91173/171177/17
1196/3
real-time [1] 1113/7
realize [1] 1206/23
realized [3] 1149/231156/41220/21
really [26] 1090/251091/11137/19
1139/251141/141146/131160/71161/14
1162/131172/81173/101173/111177/23
1177/251178/141179/221180/201181/7
1183/121183/181191/151191/23
1203/131208/111208/111215/1
realtime [4] 1078/201173/171179/13
1192/23
realtor [4] 1166/121166/161182/19
1190/3
reason [14] 1083/241084/31121/2
1123/31150/31159/161160/251162/5
1163/181184/111189/31208/131210/20
1226/19
reasonable [51] 1120/81120/211121/1
1121/21121/51121/91125/91125/19
1126/71127/81127/241128/61129/9
1130/221133/171135/191136/141139/7
1139/101143/111144/191169/61172/6
1172/91173/21173/121177/31189/10
1202/71202/101202/111202/121202/12
1203/101203/111203/141203/17
1203/191203/211203/231203/251204/1
1204/31204/51204/61204/81204/10
1204/111204/121204/201211/10
reasonably [1] 1125/20
reasoning [1] 1122/2
reasons [1] 1196/16
rebuttal [5] 1116/71119/31139/21139/2
1205/9
recall [11] 1089/211089/231099/24
1103/221105/101106/151108/24
1109/211109/241122/231210/23
receipts [2] 1133/11134/11
receive [1] 1210/5
received [3] 1096/61148/201206/8
receives [1] 1152/25
receiving [2] 1153/91155/25
recess [5] 1118/101169/191218/24
1228/71228/22
reckless [2] 1127/21129/2
recognition [1] 1226/24
recollection [10] 1103/251104/22
1104/231105/131105/171106/181107/8
1107/111121/251137/16
reconcile [1] 1218/7
reconstructed [1] 1185/3
record [13] 1114/121114/121114/13
1115/141140/191148/61148/191154/17
1154/181189/191216/21226/131230/13
recorded [3] 1078/181161/61184/11
recorder [1] 1184/12
recording [10] 1105/251109/191184/12
1185/201185/211186/161186/19
1186/251187/91193/11
records [12] 1114/101152/101173/14
1173/211173/221173/231176/11
1176/121178/41184/131196/231196/24
rectified [1] 1095/22
redirect [3] 1101/61101/81115/1
reduce [1] 1086/5
reduced [1] 1230/11
Reeves [7] 1145/221173/51181/12
1181/191206/251208/41208/8
reexamine [1] 1138/4
referencing [1] 1/6
referring [6] 1089/111162/141170/15
1170/181170/191170/20
refers [1] 1169/23
reflect [2] 1162/21163/21
reflected [1] 1109/19
reflecting [1] 1150/25
reflexes [1] 1088/20
refresh [7] 1103/251104/181104/22
1105/131105/171106/181107/8
refreshes [1] 1107/11
refreshing [1] 1104/23
refund [13] 1084/191141/51141/21
1141/221142/11143/31159/101159/18
1159/251160/21162/91165/111166/1
refunds [1] 1141/3
refuses [1] 1174/20
refutes [1] 1140/23
regards [1] 1156/18
region [2] 1085/111085/12
register [1] 1143/24
registered [2] 1144/51165/15
regulation [1] 1192/19
reject [1] 1115/23
rejected [6] 1157/61157/91157/17
1161/71209/11209/2
rejections [1] 1193/16
relate [2] 1141/21141/11
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 176 of 185
R
related [9] 1083/41090/111091/16
1136/251141/11142/111148/121161/17
1210/15
relates [2] 1164/151165/13
relationship [1] 1165/18
release [2] 1119/121120/4
released [1] 1227/7
relevant [1] 1194/3
relied [8] 1127/111129/131143/13
1149/201180/11180/151205/31205/20
rely [11] 1121/61178/241178/24
1178/251179/11179/141179/251181/23
1183/81206/111206/13
relying [4] 1113/101149/21160/3
1180/17
remaining [2] 1143/101156/3
remember [23] 1086/111101/12
1101/161101/221103/141103/171104/5
1105/11105/161106/101106/141106/19
1107/141108/101122/101123/23
1137/141138/91145/111153/111156/7
1157/51187/17
remembered [2] 1086/41086/10
remembers [2] 1105/211123/22
remind [5] 1121/161139/161155/3
1158/151205/15
removing [1] 1163/20
rendered [1] 1222/7
renew [1] 1115/16
repayments [2] 1194/151194/19
repeat [2] 1099/131105/9
repeatedly [3] 1093/61169/231206/4
repeating [1] 1130/17
replacement [2] 1112/161112/24
reply [2] 1103/201105/8
report [1] 1160/10
reported [1] 1230/7
Reporter [6] 1/31/71/121078/211230/4
1230/19
REPORTERS [1] 1229/2
representation [4] 1126/251127/4
1129/11129/5
representations [11] 1126/41126/12
1126/141126/241127/161128/11
1128/241129/181136/221147/11
1167/13
representative [2] 1154/31154/10
represented [1] 1094/8
representing [1] 1094/6
requested [2] 1196/101196/18
requesting [1] 1141/4
requests [1] 1196/17
require [3] 1127/181129/201191/20
required [8] 1136/121150/21150/3
1173/11190/61191/191202/61209/24
requirement [4] 1149/81166/51180/19
1206/5
requires [4] 1135/151136/121172/24
1202/5
researched [1] 1150/17
researching [1] 1149/22
residence [9] 1110/151144/91144/16
1144/221146/151147/121147/19
1156/141168/22
resident [3] 1098/101160/151160/22
resolve [2] 1219/61227/11
respond [1] 1212/10
response [4] 1086/131089/251090/4
1099/24
responsibility [4] 1152/231211/5
1211/61218/17
responsible [3] 1135/91135/111135/15
rest [5] 1081/181115/141116/61153/25
1197/22
restricted [1] 1/3
restrictions [2] 1081/211085/20
rests [1] 1119/1
result [1] 1141/17
resulted [1] 1140/2
retained [2] 1132/251134/10
return [32] 1098/41098/51142/11157/2
1157/81158/71158/211158/251160/5
1160/141160/191161/31168/191172/13
1183/41189/51189/61195/11195/11
1196/101196/111197/61197/61197/7
1197/121197/211199/181201/20
1204/251205/71209/31209/7
returns [15] 1142/131148/81156/18
1156/231157/131157/231159/211161/8
1161/111161/131162/21188/201194/24
1208/241208/25
retype [1] 1155/15
revenue [7] 1090/191139/91141/4
1141/201146/231160/31169/1
review [1] 1210/12
Richardson [7] 1151/251164/141165/6
1168/71168/121210/111217/5
ridiculous [2] 1176/91207/3
right [148] 1080/221081/51081/9
1081/131081/161082/21082/161082/22
1083/81083/101083/181083/201083/22
1083/251084/51084/71084/171084/20
1084/231085/11085/41085/231087/2
1088/181089/11089/101089/151090/2
1090/71090/141090/201090/231090/25
1091/141091/231092/21092/121092/14
1092/221093/81093/151093/191093/25
1094/31094/61094/91094/161094/19
1094/241095/71095/81095/111095/14
1095/181096/201097/11097/51097/8
1097/111097/211098/111098/13
1098/151098/181098/251099/81099/10
1099/161099/221100/31103/201104/13
1107/191108/31108/141108/171108/22
1110/171111/21111/221112/241114/18
1115/31115/101116/51116/121117/5
1118/41118/171118/221118/231119/7
1119/161119/241124/41125/151130/14
1133/51133/91134/221134/251135/1
1138/121138/191139/41158/61169/12
1169/201171/91171/151172/111176/13
1177/131177/131178/91181/251186/7
1186/101187/71190/161195/51195/16
1195/251198/211201/251201/25
1201/251202/211205/131213/81214/1
1214/151215/231218/21218/161218/21
1218/251219/161219/191219/221220/1
1220/251221/101226/21226/211227/4
1227/231228/20
rip [2] 1182/151194/17
ripe [1] 1226/17
ripped [2] 1182/131182/25
rise [12] 1081/31104/101108/11115/8
1118/191169/131171/131219/20
1220/161220/231226/91227/8
rolling [1] 1216/12
rolls [1] 1158/11
Romania [3] 1098/131111/81111/18
room [17] 1119/231120/41139/19
1193/31211/131212/241222/121222/20
1223/31223/111223/191224/21224/10
1224/181225/11225/91225/17
rooms [1] 1213/13
routing [1] 1197/9
Rover [2] 1141/121167/15
row [1] 1214/11
rule [4] 1091/131115/161115/251116/3
Rule 29 [3] 1115/161115/251116/3
rules [13] 1081/211090/81091/21091/3
1091/51091/131107/71107/171107/20
1107/241119/251153/21206/11
run [3] 1176/221194/201228/16
running [1] 1080/6
S
safely [1] 1088/15
safety [1] 1131/17
said [77] 1081/81083/21083/101084/25
1085/41085/221085/231089/41091/1
1095/91095/101099/91099/161099/20
1103/161103/201105/21105/81105/8
1105/91105/91105/101105/121105/13
1106/151106/171106/181109/31109/8
1110/241111/211114/121114/13
1114/161117/41120/11121/111121/20
1121/231123/181129/81140/221146/16
1149/181150/171153/231154/151155/5
1156/221160/141170/71174/131177/22
1179/21179/61179/91179/141180/18
1181/171182/31182/91183/21184/3
1185/231185/231187/71187/101187/10
1190/31190/91191/141203/21207/17
1215/31215/171215/191230/10
sale [5] 1131/121131/171151/16
1152/111167/1
same [28] 1086/221088/91109/9
1112/191115/191115/191117/181124/6
1125/231145/251146/61146/71146/23
1161/91162/51163/131163/241165/24
1165/251176/231184/181184/18
1184/221191/111193/221208/25
1211/191211/25
sand [1] 1085/18
sat [3] 1087/71105/31214/6
saw [14] 1094/221117/121145/31145/3
1145/41151/141160/221162/201166/7
1168/71216/141216/231216/241217/5
say [73] 1090/131090/161090/191091/1
1091/151093/201097/141098/171099/2
1099/41099/121104/41105/11106/14
1106/191106/211107/101109/11109/17
1116/101121/91121/101121/141122/16
1122/191123/181130/91138/121138/20
1145/181149/131149/191158/251159/3
1159/161160/251161/121161/201165/7
1167/251169/251171/231174/14
1174/181179/241182/131183/21
1183/231186/111186/111186/211188/2
1188/201193/141194/191196/31197/2
1197/111197/121198/161202/14
1204/171205/21206/71206/231207/9
1207/111207/111209/111216/51217/12
1220/201227/18
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 177 of 185
S
saying [22] 1086/211086/251091/13
1096/91097/41104/241144/71144/11
1146/241148/81180/241186/191192/8
1192/101192/251193/211206/161207/2
1208/161209/61209/181210/19
says [23] 1094/161094/181098/25
1104/201105/201107/141117/16
1145/201154/91156/251170/51174/1
1174/51174/101174/241175/241182/16
1184/171189/201193/11200/11200/3
1211/21
SBA [11] 1101/111143/181145/11
1147/31149/71153/181153/181156/8
1180/181206/41206/10
scam [1] 1194/18
scammed [2] 1182/141195/23
scammer [2] 1175/181176/18
scared [3] 1186/111186/121209/14
scene [1] 1135/18
scheme [19] 1126/21126/91126/21
1127/221127/231127/251128/41128/8
1128/161128/211129/251130/61130/14
1140/251141/11175/111176/211176/21
1201/23
schemer [1] 1176/18
schemes [2] 1139/111140/1
school [5] 1092/131182/101184/23
1207/171207/23
schools [1] 1207/19
screen [1] 1216/14
seal [5] 1086/11086/61102/191103/9
1103/9
sealed [4] 1102/241102/251103/2
1110/25
searched [4] 1148/11148/31148/4
1148/5
seated [12] 1080/51081/51108/3
1115/101118/211169/151171/151214/3
1219/221220/181226/111227/19
second [21] 1088/141088/161088/21
1095/141126/131128/101131/11133/20
1162/111189/51189/61189/221195/14
1202/211208/181213/231213/24
1215/201217/111217/241228/1
secondary [1] 1219/7
secondly [1] 1170/14
secret [2] 1137/241199/14
Secretary [6] 1143/241189/181189/19
1189/221189/231190/4
secretive [1] 1185/5
secure [2] 1086/71162/7
securities [1] 1132/2
security [47] 1091/171092/211092/22
1093/11093/121094/121094/191094/22
1095/61095/111095/131095/141096/6
1096/231096/251097/151098/11111/21
1112/241135/221148/131148/17
1148/191148/201157/71157/121158/2
1158/161158/171160/131160/15
1175/201175/211176/11176/251177/6
1183/101184/31189/71189/181208/16
1208/181208/211208/231209/11209/4
1212/9
see [20] 1094/251095/41095/51107/11
1112/71115/51125/161130/161152/12
1160/251162/181180/241186/91187/24
1193/101195/191196/11196/21205/17
1217/21
seeing [4] 1122/101122/111185/13
1205/11
seek [1] 1138/11
seem [2] 1123/71187/20
seemed [1] 1207/3
seems [8] 1144/191146/21170/14
1174/71188/231202/141204/41207/1
seen [7] 1094/121118/21118/21140/7
1181/161186/41186/4
seized [2] 1201/141201/17
select [3] 1212/21213/11213/21
selected [1] 1213/2
sell [1] 1184/15
send [8] 1140/171159/171159/23
1164/191195/111195/151197/10
1197/12
sending [4] 1131/221152/31165/20
1197/15
sends [1] 1162/25
sense [26] 1121/31122/21139/18
1139/221144/21146/21146/31155/22
1158/201159/191161/121175/24
1175/251176/21176/51176/61177/4
1181/211184/71195/121195/131195/14
1197/141201/211208/171215/10
sent [6] 1130/111148/241148/241195/3
1197/81197/13
sentences [1] 1171/1
sentencing [2] 1227/251228/2
separate [5] 1085/171124/171130/13
1130/141136/24
separately [1] 1137/1
separation [1] 1085/20
September [3] 1094/161155/51194/4
September 29th [1] 1194/4
service [6] 1139/91141/41141/20
1160/31169/11227/12
set [4] 1177/21226/161226/191228/2
setup [1] 1117/1
seven [7] 1081/201081/201085/14
1102/111125/11133/91221/22
several [1] 1119/22
shaft [2] 1086/71103/10
she [69] 1101/191103/131103/16
1103/181103/201105/51105/81106/5
1106/51110/161111/51111/61111/7
1111/81111/201122/61123/101123/22
1149/31150/151152/51154/41157/2
1160/191160/201160/211160/22
1160/231161/41161/161161/161175/24
1178/191178/201178/211178/22
1178/231178/231179/11179/21179/8
1179/111179/221179/231179/241182/9
1182/131182/161182/231182/24
1182/251183/11183/21183/21186/15
1187/41187/51187/51188/221192/2
1214/101214/201215/171215/17
1215/191215/211219/131219/13
1219/14
she's [9] 1150/71150/81162/41172/11
1179/211219/111221/31222/81227/7
shifted [2] 1140/211140/21
shifting [2] 1146/101158/13
shoes [2] 1186/121188/12
shop [1] 1201/13
short [3] 1119/111139/21186/3
shortened [1] 1175/10
should [24] 1100/131106/41106/9
1119/131121/221122/31122/181123/15
1124/51127/121129/141139/211152/23
1162/51170/81174/91195/241203/10
1205/211207/21207/31209/131211/9
1217/14
shouldn't [4] 1121/201195/241217/16
1217/17
show [20] 1104/181107/101107/12
1107/131107/131114/101147/24
1150/101167/11167/21172/181173/7
1173/221173/231175/11185/221201/3
1201/91207/21214/9
showed [9] 1146/91168/81196/23
1196/251202/221202/251203/11208/7
1210/8
showing [7] 1104/231107/121107/15
1151/171166/121166/131177/18
shown [3] 1160/91199/61207/14
shows [13] 1154/221169/51176/17
1183/51183/191184/201193/61193/7
1194/61195/171195/211200/191202/2
shut [3] 1101/211102/41147/5
shutting [1] 1146/22
shyster [1] 1183/19
shystery [1] 1199/7
sic [2] 1101/181196/17
side [3] 1095/251095/251227/21
sign [2] 1154/61212/5
signatures [1] 1118/2
signed [8] 1097/41097/61097/171144/6
1153/101179/151180/231222/1
signer [2] 1140/41143/1
significance [1] 1124/1
significant [1] 1143/15
signing [1] 1143/16
silly [1] 1113/3
similar [1] 1128/1
Similarly [2] 1136/171173/8
simple [4] 1117/161123/211199/11
1211/18
simply [11] 1135/171138/71140/18
1150/221151/201155/221158/20
1159/201160/51168/161209/8
simulators [1] 1182/11
since [4] 1117/151124/41146/41164/2
single [10] 1090/131120/141145/25
1146/51146/61146/191148/71152/19
1161/71176/8
sir [21] 1080/101081/21101/71107/22
1108/51110/21111/141115/111116/13
1117/211118/91118/251138/161169/21
1171/61171/171190/231219/241227/22
1228/51228/23
sit [2] 1187/231217/20
sitting [1] 1161/2
situation [1] 1215/9
six [16] 1081/191081/201085/14
1102/111124/241130/151150/18
1150/231151/21165/131183/111193/12
1193/201200/71200/111221/21
skip [1] 1095/9
skipped [2] 1095/81097/16
skipping [1] 1097/20
slate [1] 1152/5
slightly [1] 1162/2
Small [1] 1143/12
Smith [1] 1200/11
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 178 of 185
S
Snow [3] 1145/231181/131181/13
so [166]
so-called [2] 1174/41190/3
Social [47] 1091/171092/211092/22
1093/11093/121094/121094/191094/22
1095/61095/111095/131095/141096/6
1096/231096/251097/151098/11111/21
1112/241135/221148/131148/17
1148/191148/201157/71157/121158/2
1158/161158/171160/131160/151162/7
1175/201175/211176/11176/251177/6
1183/101184/31189/71189/181208/16
1208/181208/211208/231209/11209/4
Social Security [42] 1091/171092/21
1092/221093/11094/121094/191094/22
1095/61095/111095/131096/231096/25
1097/151098/11111/211112/241148/13
1148/171148/191148/201157/71157/12
1158/21158/161158/171160/131160/15
1175/201175/211176/11176/251177/6
1183/101184/31189/71189/181208/16
1208/181208/211208/231209/11209/4
sole [3] 1140/31143/11154/16
solely [2] 1148/51163/25
some [57] 1098/11101/101108/13
1111/121112/171113/131113/231115/5
1122/231123/171123/231125/23
1126/191126/191128/151128/17
1130/171130/181131/21132/211132/25
1133/211134/101134/181137/131141/9
1150/131151/71162/151163/21164/12
1167/21176/151179/101180/131181/25
1181/251182/11182/251183/211184/11
1186/151193/161196/71196/191199/6
1199/61199/71199/71200/161201/21
1202/91208/61208/71208/101213/18
1226/19
somebody [11] 1082/141113/13
1122/101128/231145/181145/191150/4
1161/121174/11174/111180/5
somebody's [1] 1174/1
somehow [17] 1096/91098/91140/16
1144/151149/151155/151155/17
1161/131165/31175/41177/21177/19
1180/151184/121206/221209/13
1216/22
someone [7] 1090/11124/91126/22
1128/41128/81159/21159/17
someone's [1] 1178/1
something [36] 1091/121097/81098/2
1101/211101/251104/181104/23
1105/191106/191106/211106/22
1106/221110/91123/181123/181123/24
1127/91129/101129/101130/91130/11
1143/91144/171163/221170/241174/25
1179/101180/141182/61183/251188/25
1214/71215/201217/81217/121228/13
sometime [1] 1158/19
sometimes [5] 1121/161170/171170/19
1187/191228/16
somewhere [4] 1090/81091/41091/4
1191/22
sorry [13] 1080/51081/11117/101131/6
1151/251160/171162/121176/61176/20
1189/181195/201202/181214/23
sort [2] 1199/71204/19
sound [1] 1195/13
sounds [4] 1180/161181/41185/8
1185/8
source [7] 1131/81162/161164/23
1166/21168/111200/51203/1
South [10] 1100/21100/51100/18
1100/231101/21113/141113/211114/1
1114/31114/7
South Africa [4] 1100/51100/18
1100/231114/1
speak [5] 1169/21169/91171/21
1171/221211/15
speaker [2] 1127/11129/2
speaking [2] 1104/121107/7
specific [14] 1089/21089/161109/12
1120/71127/151129/171130/31137/5
1137/71141/111144/161154/31155/7
1210/16
specifically [5] 1086/121131/51146/20
1148/111162/16
specified [2] 1089/121133/3
specifies [1] 1125/5
spectator [1] 1135/21
spectrum [1] 1203/12
spend [5] 1101/221102/11151/6
1163/141199/19
spending [5] 1152/131153/11164/13
1192/151192/16
spent [1] 1198/2
spit [2] 1197/11197/3
split [5] 1088/141088/161088/21
1113/241113/25
split-second [1] 1088/14
spot [2] 1187/181211/23
spree [1] 1152/13
square [2] 1166/101167/5
squeeze [1] 1190/8
stand [8] 1080/251107/31148/21
1169/101182/131182/161203/81222/9
standard [1] 1204/13
standards [1] 1204/14
standing [1] 1165/17
start [12] 1131/101175/21177/23
1186/141188/241189/31193/221198/5
1198/101202/91213/61214/10
started [4] 1162/101171/101190/14
1190/15
starting [2] 1092/131190/2
starts [7] 1151/61153/11163/141189/19
1199/101204/11215/17
state [7] 1089/111132/231136/4
1143/241189/191189/191190/4
State's [1] 1189/23
stated [3] 1089/71115/171146/12
statement [22] 1090/131124/91124/12
1124/141126/251127/41127/121127/12
1128/251129/51129/131129/141151/17
1153/71166/241168/71188/71188/9
1190/211194/61205/211205/22
statements [5] 1150/121180/91188/5
1188/61194/1
states [52] 1078/11078/31081/18
1083/131083/181084/131085/231092/2
1092/91092/211093/51093/71093/10
1093/111093/121093/241096/41101/3
1110/151112/131119/31120/61120/11
1125/171125/191132/171132/18
1132/191134/21136/131139/61144/17
1144/221146/181147/131147/20
1156/151168/221169/251170/31170/3
1170/41170/51170/61170/131178/13
1191/91191/111191/221207/241230/5
1230/9
States' [2] 1120/231120/25
statute [1] 1125/5
stay [3] 1213/241214/201218/21
stayed [1] 1217/11
Stenograph [1] 1230/7
Stenographic [1] 1/12
stenography [1] 1078/18
step [5] 1104/91115/111199/141226/7
1227/17
stick [2] 1190/191190/21
stickler [1] 1170/11
still [27] 1084/81086/151086/19
1086/201087/31088/31088/31092/16
1099/81099/181125/131156/21157/20
1214/141220/121222/71222/141222/22
1223/51223/131223/211224/41224/12
1224/201225/31225/111225/19
stipulated [1] 1156/21
stipulation [1] 1080/14
stipulations [1] 1121/18
stock [1] 1131/17
stole [1] 1176/18
stop [5] 1102/171104/131160/12
1167/191219/15
stopped [1] 1091/6
story [16] 1139/201139/241140/5
1140/191140/201150/91161/51161/11
1162/241168/151173/221173/23
1188/211189/11189/31202/14
straightforward [3] 1082/171082/18
1082/19
stretch [1] 1169/10
strictly [2] 1154/71167/3
strike [2] 1190/201195/12
strong [2] 1204/101204/23
stronger [1] 1116/3
students [1] 1171/12
stuff [10] 1091/51179/181185/81187/24
1188/241189/41191/61202/221214/16
1214/20
submission [1] 1157/11
submit [7] 1090/131141/171149/24
1172/181183/61207/81207/13
submits [2] 1158/61195/11
submitted [8] 1090/101090/161101/3
1117/151141/211149/61149/81205/24
submitting [3] 1145/151150/111206/21
substantial [1] 1208/13
substantially [1] 1128/1
substantive [1] 1125/3
succeed [1] 1136/21
succeeded [2] 1127/231130/7
such [6] 1141/111179/251179/25
1180/11180/11208/13
sudden [2] 1166/171191/6
suddenly [4] 1166/211190/141190/14
1209/21
suffering [1] 1152/16
sufficient [2] 1125/91152/6
sufficiently [1] 1115/18
suggest [2] 1116/11160/9
suggested [2] 1200/181217/9
suggestion [2] 1185/101191/17
summary [2] 1202/221210/10
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 179 of 185
S
summary-type [1] 1202/22
support [2] 1207/131221/6
supporting [5] 1147/231153/111206/5
1206/141206/17
suppose [1] 1199/5
supposed [8] 1102/141107/51109/22
1159/221159/231205/251209/16
1209/20
supposedly [2] 1093/21147/12
sure [15] 1104/141105/201117/12
1117/131117/141179/71185/111203/16
1204/31211/61214/221215/141216/10
1218/171221/4
surface [1] 1085/19
surgeon [1] 1151/10
surgery [12] 1163/61169/41185/2
1185/21185/51185/61185/71185/7
1185/91185/121185/171194/22
surprising [1] 1149/17
surreptitious [1] 1201/3
surreptitiously [1] 1168/18
suspect [1] 1204/4
Suspected [1] 1204/3
suspicions [1] 1202/13
suspicious [1] 1153/21
SW [1] 1078/22
Sweeten [14] 1145/241150/131150/15
1150/171150/181150/211150/251182/2
1182/51182/91182/231183/91200/9
1208/3
Sweetens [1] 1150/24
switch [1] 1084/10
sworn [1] 1209/15
sympathy [1] 1120/10
system [11] 1148/141156/11159/22
1195/91195/101195/101196/61196/22
1196/251197/151206/7
Systems [1] 1078/20
T
table [1] 1218/8
tactical [3] 1185/231186/21186/4
Tahiti [1] 1194/11
take [18] 1102/91112/41115/31117/17
1118/31119/211137/121139/181169/11
1182/181183/221187/11197/191202/9
1212/41213/71214/161218/17
taken [4] 1118/101169/191197/20
1218/24
takes [6] 1152/211162/191162/23
1201/11201/41201/5
taking [5] 1084/121172/31192/51192/6
1192/12
Takoradi [2] 1099/61114/13
talk [20] 1116/11125/221130/151133/9
1159/91166/111173/191176/141178/22
1191/41198/211206/131212/81214/14
1215/71228/41228/81228/91228/17
1228/18
talked [13] 1102/221107/21133/10
1138/141150/131152/11157/61165/6
1166/231183/251193/21208/151210/18
talking [9] 1086/201104/61108/7
1162/141175/81177/231193/171207/22
1208/9
talks [2] 1146/111178/23
tasked [1] 1209/22
tax [54] 1084/191098/41098/51140/17
1141/51141/61142/11142/11142/13
1148/71148/81148/111148/161148/17
1149/81149/191149/221150/31153/17
1155/91156/181156/231157/21157/7
1157/231158/71158/191158/211159/16
1159/181159/211160/41160/141161/7
1161/201162/21162/91166/11168/19
1172/121183/41188/201189/61194/24
1195/111195/221196/91196/191197/24
1199/181199/181201/201208/241209/7
taxes [2] 1159/51196/20
Taxpayers [1] 1159/22
technology [1] 1/13
Ted [1] 1078/22
tell [37] 1082/141085/71105/181107/12
1107/151113/111116/101118/71119/17
1123/41125/51139/221146/31158/12
1160/191167/101172/231173/22
1174/131182/91184/11186/171187/16
1187/161187/251188/31188/111197/24
1197/251198/11209/141209/161212/13
1212/181214/51215/121227/7
telling [5] 1123/11123/221140/5
1141/141154/20
tells [4] 1172/221176/71193/61197/14
ten [11] 1118/61124/171125/11125/23
1133/101168/31185/231186/31186/13
1208/91221/25
tend [2] 1122/91123/23
tendency [3] 1127/101129/121205/19
term [4] 1132/241134/31134/91142/10
terms [4] 1086/151087/31090/10
1209/18
terrifying [1] 1186/9
testified [22] 1083/121084/31084/22
1089/21091/161091/221091/251115/22
1123/101123/161140/211145/161146/4
1150/151150/211151/181152/181153/2
1155/111179/181179/201207/16
testifies [2] 1115/251179/22
testify [9] 1124/41124/51145/71147/25
1166/91168/71180/31188/161189/9
testifying [1] 1122/22
testimony [28] 1081/81082/121087/21
1087/231087/241088/131088/15
1088/191090/251091/191101/12
1115/231116/21121/131122/51122/19
1123/131123/141123/191124/61137/21
1140/71157/51161/151168/131179/21
1191/181209/16
Texas [6] 1098/101160/151160/22
1168/201182/171183/21
than [22] 1095/51096/191133/23
1134/211137/201138/141140/21141/4
1145/61145/91151/191184/241185/4
1188/251191/211196/181199/231203/2
1203/181207/181207/201211/2
thank [23] 1081/11108/51110/21115/7
1118/141118/171119/21169/91171/17
1171/191205/81211/111218/11218/2
1219/181220/151221/11222/21226/1
1227/141228/201228/231228/23
that [974]
that's [128] 1090/91092/241093/9
1094/191095/81100/231105/21106/1
1106/191107/151114/161117/19
1119/141119/171122/121138/12
1139/211140/251142/61142/121143/9
1143/91148/101150/31151/201152/23
1153/41157/201158/31158/101158/11
1158/241159/181161/91163/251165/4
1170/51170/161170/241171/31171/12
1173/101173/111174/21174/171174/18
1175/51175/61175/61175/71175/19
1175/221176/131176/161176/16
1176/201176/211176/211177/31177/3
1177/51177/51177/121177/121179/16
1180/221184/61184/61184/181184/19
1184/201185/91185/101186/61186/8
1186/211187/111188/11188/211189/1
1189/11190/161191/101191/141191/19
1193/131193/231195/21195/21195/5
1196/31196/41196/51196/61196/6
1196/91198/21198/61198/111199/19
1199/201199/251200/21200/111200/24
1200/251201/11203/131203/141203/22
1204/31205/31207/21207/41208/5
1208/201214/241215/21215/51215/10
1215/191217/151217/181219/16
1226/211226/221227/31227/10
their [32] 1118/81119/101120/21138/21
1141/181146/151149/21172/61172/9
1173/231174/171175/131175/16
1176/111176/171177/51180/201181/16
1182/61182/71187/151195/21195/5
1197/161200/241200/251201/11204/25
1205/61205/231207/51217/23
them [56] 1080/161080/231084/25
1086/71103/31103/51109/251110/11
1111/141112/191116/111117/61118/7
1118/171123/121123/231124/19
1125/231130/181137/151143/15
1144/221149/111155/31157/241162/6
1163/81171/91177/71177/131178/5
1187/161187/161188/31191/81193/3
1195/231198/61201/141201/151201/16
1202/101204/241205/61205/241206/25
1211/51213/101216/121218/51218/22
1219/191227/11227/21228/161228/17
then [83] 1088/81090/171092/20
1094/211097/161099/41099/181099/22
1104/191104/191104/231105/10
1105/171106/41106/51106/71106/15
1106/181109/11112/211114/31115/5
1116/101116/121117/11117/191119/9
1119/111119/121120/31139/11139/1
1139/101141/101141/201142/41142/25
1147/181150/161152/31152/121152/25
1153/151154/131158/241162/41163/21
1164/81165/71177/11177/101178/13
1180/201180/251182/211184/13
1184/171185/191187/251196/11198/1
1199/151199/151200/81200/91200/14
1210/191210/251211/231212/25
1213/201217/51218/51218/191218/20
1218/211219/131220/121226/17
1226/191226/241227/11228/7
theory [5] 1174/171175/61177/5
1180/251195/2
there [116] 1080/131081/151081/20
1082/11082/31083/241085/191086/1
1092/31094/231101/201102/171105/15
1109/51109/251112/171116/251120/17
1123/151123/171124/161130/171140/9
1140/101141/191142/81143/191143/19
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 180 of 185
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there... [88] 1146/181147/161148/8
1148/101148/111150/51150/231150/24
1152/31152/51155/81156/171156/21
1157/61157/111159/161160/121160/19
1160/251161/161161/241162/11162/5
1163/171164/121167/191170/14
1170/221171/101171/121172/22
1173/171173/241174/21174/31177/19
1177/201177/211178/61181/91182/1
1183/91184/171184/211185/201185/22
1186/161186/251188/211189/13
1189/131189/241190/81191/171193/3
1193/201194/21194/51195/201196/19
1196/201196/231199/191199/221200/4
1200/111201/251205/61206/21207/7
1207/191208/121210/231211/25
1212/241213/81213/111213/131213/14
1214/171214/191215/181217/81217/17
1220/211226/21227/101227/17
there's [38] 1090/161100/61100/6
1100/71105/151106/251122/131125/23
1140/251141/21142/121146/81152/9
1153/61160/71160/81168/101168/16
1168/171169/251173/181173/24
1173/251183/181189/21190/131193/14
1197/251199/131200/151207/13
1207/191211/231211/241213/12
1214/111215/141216/7
these [52] 1084/121089/151097/20
1098/241107/171111/121119/181120/1
1121/171124/131130/171139/25
1144/111144/141148/221148/23
1148/251149/101149/151149/19
1150/121156/71157/221164/141164/23
1165/31172/111172/111173/141173/15
1173/201173/201173/211173/231178/3
1178/41178/61178/241181/161185/24
1193/21194/11196/71196/71198/8
1198/81198/91199/131201/111204/22
1205/31206/23
they [206]
They'll [1] 1171/22
they're [21] 1116/111144/111146/4
1173/211176/101178/121180/10
1180/201181/91183/231184/171186/2
1186/31187/221187/251194/11195/8
1207/231208/101213/101218/6
they've [3] 1177/91180/111205/1
thing [15] 1086/41086/101091/14
1139/161142/121169/221174/18
1184/151191/121199/251203/71203/9
1211/131216/11227/11
things [30] 1101/101115/51122/25
1123/91123/231140/141142/81144/20
1146/221169/231172/111172/11
1172/131172/191178/31183/251187/19
1194/211196/161198/101199/71199/16
1200/161201/11201/111204/221204/24
1206/181210/241217/19
think [67] 1080/131080/151088/2
1089/81089/91091/41102/221104/24
1105/21106/121107/231115/221115/22
1115/241116/31117/231118/31119/13
1119/171128/211137/131138/71160/21
1169/241169/251170/71170/81170/8
1170/111170/121170/231170/241171/8
1173/141173/191173/221173/23
1174/161176/101177/11178/71180/16
1180/181186/131189/221190/16
1190/171194/31201/181202/131202/16
1202/171203/151203/181203/19
1203/211210/11214/111214/211215/22
1217/181219/91219/141220/211226/14
1226/241228/11
thinking [4] 1086/151087/31139/20
1139/22
thinks [1] 1109/22
third [9] 1082/51126/151128/121131/4
1131/61133/231157/251184/51200/14
third-world [1] 1082/5
this [205]
those [80] 1089/61089/221093/14
1097/161097/181101/231103/81103/14
1111/131114/221114/251121/181125/3
1125/141130/151133/101137/71137/14
1140/41141/21141/21142/51142/17
1145/211148/141148/161149/41152/7
1156/191157/131157/221157/23
1157/251158/71159/111161/71161/8
1161/101161/131162/21163/41163/7
1165/101168/111169/21169/31171/11
1172/191173/51173/221173/251175/22
1175/231176/41176/71176/81176/11
1176/121176/151177/71181/221181/23
1186/121198/101200/51200/161202/8
1202/191204/241205/181206/31206/18
1208/71208/221209/41209/111210/3
1210/91210/161210/21
though [5] 1084/111091/91094/3
1101/251155/25
thought [17] 1080/131086/191086/20
1087/41087/251088/51088/91089/11
1090/91091/11098/101182/121215/8
1215/91216/141227/111228/20
three [18] 1089/51089/91108/19
1108/201116/251124/221128/21140/22
1156/191156/241156/251176/71185/19
1187/231192/241194/131209/20
1221/18
three-minute [1] 1116/25
through [25] 1081/231102/61104/13
1113/221125/11125/41125/241130/11
1130/151132/251133/101134/51134/10
1139/131153/161157/191158/51164/14
1171/201178/31188/131210/71210/11
1210/141210/24
throughout [1] 1218/22
throw [1] 1177/13
thrown [1] 1187/14
Thurmond [1] 1150/16
tied [4] 1161/101200/131200/14
1226/19
time [28] 1085/81085/91088/141092/4
1095/231099/131102/31113/71123/17
1138/191140/121152/41155/71157/25
1163/131167/61171/191182/21184/4
1186/101187/201191/221205/51212/8
1213/21219/121227/151227/21
timeframe [1] 1217/6
times [4] 1110/61142/101145/12
1217/22
timing [1] 1177/9
title [1] 1132/7
titles [1] 1164/19
today [8] 1119/141139/171153/3
1186/161187/61205/171209/221210/18
together [7] 1168/21182/101184/22
1184/231213/41213/171218/17
told [30] 1088/71089/141106/31112/8
1122/51125/221125/251128/251138/20
1139/211139/241148/221150/81153/4
1154/41158/181174/21174/71182/4
1182/51182/51183/11188/171188/17
1188/181189/11196/21198/61212/22
1215/19
Tom [1] 1150/16
tonight [1] 1171/12
too [9] 1084/41117/221181/101181/10
1194/21202/171205/111209/131219/15
took [12] 1081/171085/131102/13
1102/131134/11139/101147/91148/21
1194/121196/211197/121197/13
top [3] 1108/251186/241195/19
topic [2] 1103/231105/11
TORJAGBO [21] 1078/51085/61098/22
1139/81154/161154/191158/51160/17
1164/211175/91176/191186/211186/23
1187/21198/251199/11200/171201/9
1211/231221/151230/9
tornado [1] 1101/20
total [2] 1145/51167/20
totality [1] 1210/1
totally [2] 1096/191228/19
touch [2] 1207/221207/24
tough [1] 1107/25
towards [1] 1083/15
town [4] 1100/181114/151114/18
1114/20
toys [1] 1199/20
tracks [1] 1175/4
Tract [1] 1164/16
tractor [2] 1198/81199/16
trade [1] 1132/16
tradition [2] 1114/91175/14
Trail [2] 1155/61155/6
trailers [3] 1198/81199/171217/3
trained [2] 1088/201182/10
transaction [24] 1130/251131/21131/7
1131/101131/111131/111131/12
1131/141131/191131/201131/20
1131/231132/51132/51132/91132/21
1133/191133/201134/11134/31162/14
1163/171163/211166/4
transactional [4] 1125/21133/11
1133/161141/10
transactions [17] 1130/201133/14
1134/171141/71141/81142/51142/15
1151/71151/201164/91164/151165/3
1165/41166/61166/71203/41210/17
transcript [18] 1/11/51/81/91/14
1078/121078/181104/11105/141106/5
1106/101106/111107/111195/17
1195/181195/201218/91230/12
transcripts [1] 1/2
transfer [13] 1131/131131/151132/4
1132/71134/41152/201163/251164/11
1164/181167/91167/151167/171197/8
transferred [2] 1142/241165/5
transferring [2] 1152/11210/23
transfers [3] 1152/21163/11210/9
transmissions [2] 1130/51142/13
transmitted [5] 1128/141128/151130/2
1141/31153/18
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 181 of 185
T
transport [1] 1100/20
transported [1] 1100/20
travel [1] 1100/20
traveler's [1] 1132/1
traveling [2] 1083/221084/9
treat [1] 1121/18
treats [1] 1159/21
trial [12] 1107/51121/231123/201137/4
1137/121214/41215/201217/181218/14
1227/201228/171228/21
trick [2] 1088/51114/22
tricking [1] 1088/9
tried [5] 1090/61104/131130/241144/10
1153/4
tries [2] 1158/21184/14
trouble [1] 1201/15
truck [1] 1216/15
trucking [2] 1201/131217/9
trucks [2] 1201/131217/2
true [13] 1121/171122/171143/17
1146/91147/221164/231166/11180/22
1180/231180/251206/171206/18
1230/13
truly [1] 1144/3
truth [12] 1106/61123/21123/41123/22
1127/21127/51129/31129/61138/11
1144/71209/141209/17
truthful [2] 1160/41211/7
truthfully [1] 1209/23
try [16] 1103/241105/121106/171114/6
1114/221138/31139/141140/51156/6
1157/221158/121161/111165/21205/23
1207/121218/22
trying [25] 1088/51107/221107/23
1112/131112/161141/91141/161150/9
1154/11167/241175/11182/111182/16
1183/201183/231189/121194/17
1199/241199/241199/251200/22
1201/211201/221201/231219/2
TurboTax [3] 1157/21157/61161/6
turn [1] 1111/25
Turner [1] 1078/22
turnover [2] 1109/61186/21
TV [1] 1202/8
twice [1] 1170/6
Twist [1] 1145/23
two [34] 1084/221090/171101/14
1111/141116/251118/211120/31124/22
1128/21132/171135/221141/21141/2
1145/121154/231156/181156/19
1156/231157/221157/231157/251162/2
1169/231196/151197/41197/121208/15
1208/211208/221208/231208/251209/4
1214/81221/17
type [6] 1189/241189/251189/25
1189/251190/11202/22
typewritten [1] 1230/12
typical [1] 1145/8
typing [1] 1192/13
tyranny [1] 1172/1
U
U.S [7] 1/141078/211079/21111/24
1144/81146/151147/17
U.S. [10] 1092/11102/101110/11
1114/231140/131144/41144/91155/12
1155/131191/19
U.S. citizens [1] 1110/11
U.S. Government [1] 1114/23
U.S. operations [1] 1140/13
U.S. place [1] 1144/9
U.S. Post [2] 1155/121155/13
U.S. until [1] 1102/10
U.S. visa [1] 1092/1
U.S.-based [2] 1144/41191/19
ultimately [4] 1136/211147/21163/5
1164/19
Um [22] 1081/251087/81087/111087/15
1087/171088/121090/51092/71092/10
1094/141096/111098/231099/15
1100/101102/181109/111109/13
1109/161110/31111/91113/41113/6
Um-hmm [22] 1081/251087/81087/11
1087/151087/171088/121090/51092/7
1092/101094/141096/111098/23
1099/151100/101102/181109/11
1109/131109/161110/31111/91113/4
1113/6
Umm [4] 1087/131089/31096/14
1096/16
Umm-hmm [4] 1087/131089/31096/14
1096/16
unanimous [3] 1125/141137/231220/5
unanimously [1] 1125/10
unbelievable [3] 1140/201150/22
1151/20
uncommon [1] 1184/5
under [27] 1083/31094/21097/4
1124/151132/231135/61144/241148/1
1151/131151/221156/191157/121158/1
1158/71158/161160/121162/61163/15
1166/231188/81188/101209/161209/21
1209/211209/241226/221226/23
underfunded [1] 1176/9
underlying [1] 1180/17
understand [7] 1087/221091/91106/24
1123/111138/231212/161219/25
understanding [3] 1110/121114/9
1226/23
undisputed [1] 1140/6
unduly [1] 1137/17
unemployment [1] 1148/11
unfair [1] 1217/20
unfrozen [1] 1154/2
unimportant [1] 1124/3
UNITED [52] 1078/11078/31081/18
1083/131083/181084/131085/231092/2
1092/91092/211093/51093/71093/10
1093/111093/121093/241101/31110/15
1112/131119/31120/61120/111120/23
1120/251125/171125/191132/18
1132/191134/11136/131139/61144/17
1144/221146/181147/131147/20
1156/151168/221169/251170/31170/3
1170/41170/51170/61170/131178/13
1191/91191/111207/241221/111230/5
1230/9
United States [37] 1081/181083/13
1083/181084/131085/231092/21092/9
1092/211093/51093/71093/101093/24
1101/31112/131119/31120/61120/11
1125/191132/181132/191136/13
1144/221146/181147/131147/20
1156/151168/221169/251170/31170/3
1170/51170/61170/131178/131191/9
1191/111207/24
United States' [1] 1120/23
unlawful [8] 1131/31131/51132/21
1133/11133/21133/31134/111203/4
unless [2] 1214/71215/24
unlikely [5] 1203/151203/161203/18
1203/211203/22
until [14] 1081/191086/181102/10
1114/31117/51143/251154/241155/8
1157/161166/221189/201190/171213/4
1218/3
untrue [2] 1127/21129/2
up [75] 1081/11088/171089/91090/18
1095/241099/101099/161107/21109/7
1112/61113/241113/251114/221119/13
1138/61149/151153/231154/131155/1
1155/171158/51158/71159/91161/11
1162/111163/131163/131163/23
1165/191166/171167/91169/81169/10
1169/121171/121173/151173/18
1174/201174/251177/21178/131179/7
1181/101183/51184/31184/41184/6
1184/91184/171185/221188/241188/25
1189/31189/41189/41191/61194/2
1194/201195/21195/31195/41196/4
1196/51201/21202/211205/111213/10
1213/151214/91216/141217/111217/23
1219/51220/71222/9
upon [6] 1121/21129/131180/151183/8
1202/151227/23
us [9] 1082/61102/61147/241182/6
1191/121191/151203/101212/61213/7
use [25] 1119/251122/21127/81127/15
1128/31129/91129/171130/81130/10
1130/131131/161132/91137/141142/15
1151/181158/111159/191161/11166/15
1168/11175/241186/61201/211203/4
1203/4
used [15] 1/131090/171091/251097/14
1098/31101/151126/201128/181142/4
1156/161161/161175/121175/131189/8
1216/23
uses [3] 1160/151170/181170/19
using [26] 1088/201091/61091/71098/2
1125/81126/41126/111126/231128/8
1130/31151/211157/191157/201157/22
1162/41166/241167/171167/251168/9
1168/101177/181189/61189/61200/20
1200/231208/25
usually [3] 1186/61228/101228/11
V
vaccine [2] 1082/11102/9
vaccines [2] 1082/31102/2
vague [2] 1086/91086/19
vaguely [2] 1103/241105/12
value [2] 1133/231192/11
Vegas [1] 1194/12
vehicle [7] 1132/81167/161167/18
1167/191167/201168/61168/12
vehicles [1] 1139/13
venture [1] 1136/20
veracity [2] 1146/171153/8
verdict [68] 1117/71117/121137/2
1137/221137/251204/251205/71211/17
1212/51212/71219/61219/251220/10
1220/131221/31221/31221/51221/9
1221/131222/61222/111222/121222/14
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 182 of 185
V
verdict... [45] 1222/161222/191222/20
1222/221222/241223/21223/31223/5
1223/71223/101223/111223/131223/15
1223/181223/191223/211223/231224/1
1224/21224/41224/61224/91224/10
1224/121224/141224/171224/18
1224/201224/221224/251225/11225/3
1225/51225/81225/91225/111225/13
1225/161225/171225/191225/21
1226/151226/191226/201227/24
verify [1] 1153/17
verifying [1] 1197/16
versus [1] 1091/7
very [19] 1084/151119/111138/9
1138/231145/11151/21153/221164/24
1169/111172/211177/241179/181181/4
1195/191200/231204/151214/231221/1
1222/2
vessel [1] 1132/8
vests [1] 1186/4
vice [1] 1179/22
victim [5] 1127/191129/211178/8
1178/121182/23
victim's [3] 1127/171129/181211/4
virtually [1] 1146/7
visa [5] 1092/11092/81093/101093/11
1112/11
voice [2] 1171/101171/11
voir [1] 1215/15
voir dire [1] 1215/15
Volta [1] 1085/12
VOLUME [1] 1078/5
volumes [1] 1169/2
voluntarily [12] 1128/191222/17
1222/251223/81223/161223/241224/7
1224/151224/231225/61225/141225/22
volunteer [1] 1083/4
vote [1] 1215/13
voted [1] 1212/14
W
W-2 [3] 1157/141157/151160/6
wages [2] 1192/11192/4
wait [4] 1080/241181/171213/41219/3
waited [1] 1219/3
waive [1] 1226/14
Walk [1] 1102/6
walked [1] 1084/15
walking [1] 1122/11
Walmart [2] 1088/231088/24
want [44] 1080/241095/161100/14
1104/241105/151105/181105/20
1106/201107/11107/101107/141109/3
1117/171118/51119/221137/191138/7
1170/241171/191175/61175/71176/13
1182/191182/191193/191205/15
1212/131212/171213/51213/161214/20
1215/61215/71215/121218/51218/10
1218/101221/31227/141228/31228/8
1228/131228/141228/17
wanted [11] 1093/81093/251096/23
1119/171153/141154/61169/221174/22
1174/231190/81193/15
wanting [2] 1092/81095/16
wants [12] 1143/251149/191155/20
1158/121158/181160/171161/31165/2
1167/251176/101206/11209/11
was [426]
wasn't [28] 1084/91090/251091/1
1096/241097/241097/241117/14
1123/221143/191143/191148/24
1148/241153/51160/191162/91177/21
1179/51179/181186/111186/111189/20
1192/161194/251196/221197/31209/21
1209/211217/17
way [49] 1099/141111/21111/91111/15
1112/121112/131112/171117/251118/1
1118/51120/101124/61131/211131/23
1132/61132/121134/51137/81138/9
1138/131140/51146/241150/241156/2
1156/71156/151159/101162/151167/22
1170/81170/171170/211170/211170/23
1181/11182/241182/251183/71183/13
1195/181197/251199/141206/21207/14
1207/151207/191207/191212/14
1213/12
ways [5] 1106/251125/61125/71178/6
1188/6
we [142] 1080/61080/131080/24
1085/101085/171086/201094/22
1102/221107/241107/251107/251108/7
1112/121115/61115/151116/121116/25
1117/11117/81117/151118/31119/13
1119/151120/51138/141140/241143/9
1146/91146/251147/21147/31148/3
1148/91148/221148/251148/251149/18
1150/131160/161162/181162/20
1163/241164/41164/241166/71166/8
1173/161174/21174/21174/31174/4
1175/31175/191177/81177/231178/1
1178/21178/121178/241178/241178/25
1179/241179/251179/251180/41180/4
1180/51180/191180/191181/171181/25
1181/251182/71182/101182/111183/7
1183/241183/251184/81184/111185/1
1185/11185/121186/151187/81187/17
1187/181189/131189/241189/25
1189/251190/101191/11191/221191/23
1191/231191/241192/11193/41193/5
1193/81195/161196/11196/21197/24
1197/251200/131202/31202/81202/9
1203/71204/131204/131206/131208/6
1208/151211/211214/81214/221215/1
1215/191216/11216/41216/121218/14
1219/31219/61219/151220/21220/22
1221/71221/71221/141226/41226/8
1226/121226/141226/241227/11
1227/111227/111228/7
we'll [6] 1115/51116/201176/141185/19
1218/71227/19
we're [19] 1080/151107/41107/25
1115/31115/131116/41116/201118/7
1118/211175/81175/81185/111187/18
1193/221208/91209/61218/211219/9
1228/22
we've [26] 1107/51109/201142/6
1163/141171/201172/71172/71172/8
1173/141173/151180/71180/111189/16
1189/181189/211192/191197/81197/23
1202/161202/161202/171208/81208/21
1210/181214/81219/3
weaker [1] 1115/25
weapons [1] 1185/23
weave [2] 1140/61150/10
website [11] 1174/81174/91174/10
1174/111174/191174/201174/24
1184/151190/41200/31200/3
week [10] 1088/231139/61139/21
1142/71153/121171/191171/201172/7
1214/61227/13
weight [3] 1122/141124/121137/20
weird [6] 1169/251170/71184/14
1184/161196/151196/16
weirder [1] 1197/5
welcome [1] 1175/12
well [50] 1085/61089/171089/21
1092/141094/31095/91099/141100/9
1101/201104/211118/41139/221145/21
1150/191152/171154/91161/81166/7
1171/31175/21175/81178/41179/14
1179/241180/181181/221186/14
1187/151188/141189/221191/41191/5
1191/81192/31192/41192/251193/18
1196/41197/91197/231198/161200/19
1200/231201/71203/121204/181217/15
1219/31226/231228/13
went [25] 1088/231088/241103/23
1105/111106/161112/51122/231143/6
1150/61162/121164/141174/51174/6
1181/31181/241186/151187/71194/11
1197/221197/231198/11199/31200/8
1200/91200/10
were [128] 1082/31082/41082/7
1083/101083/181083/201084/21084/4
1084/71084/131085/31085/101085/16
1085/201085/251086/51086/201088/7
1089/101090/81091/21091/131092/11
1093/141093/151093/161093/18
1093/231094/61094/81096/221097/5
1097/101098/101099/71099/221102/2
1102/141103/81103/161107/231108/7
1108/101110/111110/191110/24
1111/241112/131112/161113/51113/7
1113/181113/201113/221114/11
1114/151121/131121/181126/14
1128/111131/21133/211138/51140/1
1141/31142/11142/131142/241143/16
1144/81145/111146/141146/181148/4
1148/81148/101148/111148/221148/25
1149/51154/51154/61154/241156/17
1156/191157/61159/51159/131159/13
1160/31170/221174/21174/31178/6
1179/31180/111181/51181/61181/8
1181/151181/181182/11182/11183/20
1184/181184/221184/231185/24
1185/241186/11191/91192/201192/21
1193/31193/31196/21201/121201/13
1202/191205/251205/251206/11
1206/241206/241207/231226/16
1228/251230/11
weren't [13] 1083/161083/221094/3
1143/201161/211173/241180/171181/4
1185/241192/151194/51201/121201/15
western [1] 1177/24
what [192]
what's [10] 1104/161142/191156/1
1175/81175/251176/21176/51178/1
1208/21218/18
whatever [5] 1085/201107/141155/23
1158/141158/14
whatsoever [2] 1200/51200/15
when [105] 1082/71082/121085/3
1085/131086/31087/71088/161088/19
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 183 of 185
W
when... [97] 1088/221089/101089/21
1089/251091/141094/51094/101094/21
1097/21097/221098/21098/41098/5
1099/71100/191100/191102/121102/13
1102/211105/21108/101109/101110/6
1110/241111/211111/241112/71112/8
1112/161112/231113/51113/181113/18
1113/201113/221119/151122/161127/5
1129/61139/201140/211141/51146/11
1147/141148/211150/151150/23
1152/161157/251158/51158/101158/21
1159/241160/41161/101165/181166/13
1166/181167/211168/61171/241172/22
1175/191175/251176/21176/51176/25
1177/231177/251178/21182/121184/21
1186/121186/141187/181193/221198/7
1206/131207/141207/221207/231208/4
1208/61208/151209/171210/11211/8
1212/41212/231212/241212/251213/10
1213/161217/211218/61218/191226/20
where [41] 1085/171091/51091/6
1097/81098/241099/101099/161099/22
1103/21103/21110/211110/231111/2
1111/71111/91113/11113/71114/10
1114/101114/101115/61118/31125/5
1139/141141/81161/101165/161168/4
1168/201174/11197/201199/31199/20
1201/251201/251204/11211/131212/18
1213/181214/51218/5
Whereupon [18] 1081/41104/111108/2
1115/91118/101118/201169/141169/19
1171/141193/111214/21218/241219/21
1220/171220/241226/101227/91228/25
whether [25] 1089/191091/121114/15
1120/61122/31122/181123/151123/17
1124/21124/51124/111127/81127/11
1129/101129/131134/131134/191136/4
1137/61137/91137/221143/141205/20
1216/21221/8
which [23] 1084/101085/171086/4
1091/21120/171124/151124/161125/6
1128/211133/41169/241170/21174/16
1188/81188/101195/171195/211196/9
1197/241197/241197/251197/251222/3
while [8] 1083/31107/21138/31149/19
1165/21184/141189/161201/4
who [43] 1082/131082/151089/15
1098/91098/131098/151098/181102/15
1110/121112/11122/51122/61123/1
1140/11146/141146/141147/121149/4
1149/181150/101150/171150/211151/1
1152/191152/211152/241152/25
1154/121168/161168/181168/211170/3
1179/61179/131179/171179/201183/24
1184/101205/251207/221212/10
1214/111228/11
who'd [1] 1098/17
who's [1] 1150/20
whoever [3] 1179/91180/141181/24
whole [10] 1081/231120/141122/21
1131/71146/211147/81183/121183/13
1183/181219/12
whose [2] 1110/141132/11
why [26] 1095/211110/101117/2
1130/161152/171152/201152/20
1157/221158/101159/21160/211161/12
1170/51179/161180/51189/51191/7
1191/71192/31192/31196/191197/19
1205/31212/231212/231226/7
will [45] 1/31100/81100/81105/7
1109/211109/241109/251116/10
1116/111116/121118/81119/221120/2
1120/31120/171137/101146/251147/2
1147/31147/161172/231185/201185/21
1186/201186/231186/241187/21197/10
1205/171209/101210/101211/13
1211/131211/151211/151212/41212/5
1212/61212/61212/101212/101213/7
1218/121227/61227/23
willfully [1] 1135/12
willing [7] 1092/111093/61093/23
1096/221121/61135/201155/23
Willis [3] 1145/231181/121181/20
wire [30] 1124/221128/21128/31128/15
1130/21130/31130/51130/81130/10
1130/111130/131131/51131/221133/4
1133/251134/151141/21142/131152/19
1156/201156/211162/251164/19
1165/201167/61167/151167/181197/8
1202/241210/2
wired [2] 1182/211192/8
wires [1] 1192/14
wiring [1] 1192/17
wish [1] 1212/8
withdrawal [2] 1131/151134/4
withdrawing [1] 1210/24
withheld [2] 1159/51159/5
withholding [2] 1140/171148/9
withholdings [14] 1141/61148/12
1149/11149/191149/231158/191158/22
1159/21159/111159/251161/201162/6
1196/11196/2
within [1] 1227/20
without [6] 1121/71135/31157/11174/6
1177/71197/16
witness [24] 1105/191109/221109/23
1109/231122/191122/211123/11123/3
1123/51123/71123/81123/111123/16
1123/181123/191123/221123/241124/7
1187/81188/161191/121191/241203/8
1208/25
witness's [2] 1122/241123/13
witnesses [11] 1115/121115/13
1118/241121/131122/211143/181172/8
1173/151182/11182/11193/2
woman [1] 1215/10
won't [4] 1116/11116/11150/61215/24
wondered [1] 1197/21
wonderful [1] 1217/19
word [9] 1103/221103/221105/10
1105/101125/81128/181175/231176/12
1186/6
words [5] 1126/201135/191137/23
1196/141202/8
work [8] 1144/121181/71181/91192/18
1193/101213/51214/101215/11
worked [3] 1156/81183/51207/19
worker [1] 1155/17
workers [8] 1085/141085/161102/12
1102/141103/11103/31191/81191/20
working [5] 1083/161085/181087/18
1197/151228/21
works [5] 1146/71158/141158/14
1158/241196/6
world [6] 1081/191081/231082/5
1150/231184/51199/23
worried [1] 1215/21
worse [2] 1127/191129/22
worth [1] 1134/21
would [96] 1080/161088/61090/13
1090/161098/21103/41104/91115/14
1115/161118/11118/71119/131121/6
1127/81129/91130/91130/111136/20
1139/161142/161143/141143/201144/4
1146/51146/51146/231147/61148/25
1149/131151/211152/171152/20
1155/141156/81156/91156/161159/2
1159/31159/81159/161160/91160/9
1160/211160/251161/121161/19
1161/201161/221161/241162/21162/5
1163/21163/81163/91163/181165/6
1166/191167/41168/111174/161174/18
1178/241178/241178/251179/24
1179/251180/251181/151181/161182/6
1182/71182/181183/11185/251187/13
1188/131189/51189/81192/31192/3
1199/61207/201208/121208/131208/17
1209/11209/11214/251215/91215/13
1216/51217/241220/71226/141226/16
1228/15
wouldn't [13] 1093/201159/151160/23
1167/101167/121174/181182/71183/22
1188/131188/241189/81201/241215/23
wow [1] 1188/21
wrapped [1] 1119/13
write [4] 1212/91212/141212/17
1212/18
writes [1] 1162/23
writing [2] 1193/211212/11
written [1] 1119/22
wrong [5] 1109/51112/71138/51160/20
1179/9
wrote [3] 1095/211147/221162/21
Wyoming [3] 1165/161199/41199/6
Y
y'all [28] 1080/51080/71081/51108/3
1115/101117/131118/51118/211145/21
1152/11169/151169/201170/81189/23
1195/121213/101213/151214/11214/3
1215/71215/241217/221218/251220/18
1226/111227/171227/191228/3
y'all's [1] 1170/17
yacht [2] 1139/131169/5
yeah [39] 1082/251089/181090/9
1091/111096/31098/91103/61103/8
1103/121103/151108/201108/25
1111/211113/251114/171117/81117/25
1174/21174/51174/131174/181177/11
1182/31182/41184/31187/71197/3
1198/11198/71203/131203/141203/15
1203/191203/211203/221204/21204/5
1207/171214/18
year [14] 1098/101145/51146/11158/21
1159/61160/141160/221161/231195/22
1201/201201/201207/161207/18
1207/18
yearly [1] 1145/4
years [28] 1089/51089/91094/41094/5
1094/81094/101095/171098/81108/19
1108/201140/221161/11166/91177/1
1177/21177/181184/241185/41185/19
1187/231189/81192/251194/131196/20
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 184 of 185
Y
years... [4] 1207/201208/171209/6
1209/20
yep [1] 1098/17
yes [169]
yesterday [15] 1080/91081/81083/12
1084/31084/221087/71089/21091/16
1101/101105/51106/31148/211150/16
1152/181187/5
yet [16] 1081/111081/231082/11087/21
1095/41099/71143/241146/111148/14
1149/211152/241158/181194/61201/7
1207/251213/23
you [926]
you'd [2] 1094/51197/2
you'll [14] 1122/231124/161124/18
1125/161130/181137/241185/20
1186/191188/51194/141195/191195/19
1205/161216/6
you're [49] 1083/31086/251088/13
1088/221094/151094/161095/11095/1
1095/161096/121107/121107/15
1119/151138/31139/201154/211162/14
1170/251172/11172/201175/111175/25
1176/21180/81180/241187/241188/21
1188/231189/31191/51191/61193/24
1193/251194/171199/231199/24
1199/251199/251200/221201/21
1201/221201/221202/31204/181207/21
1208/41209/191209/241213/16
you've [26] 1086/131088/201094/12
1107/11107/21113/101137/121140/7
1146/121151/71168/61177/151177/15
1186/41186/41186/161186/181191/6
1194/11204/151204/171205/141211/12
1213/21213/41213/15
you-all [20] 1117/71117/91117/20
1119/61125/101170/171170/221212/18
1215/61215/121216/71218/31218/16
1218/171219/251221/51226/71227/12
1228/81228/21
young [5] 1181/91181/101207/23
1214/101215/10
younger [5] 1095/171095/171185/4
1207/181207/20
your [202]
Your Honor [20] 1100/121104/31104/8
1104/151105/221115/131116/22
1118/251134/241215/81215/141216/17
1218/231219/51219/91222/41226/4
1226/121226/181227/5
yourself [8] 1122/241123/151124/11
1137/171186/121187/131188/121196/7
yourselves [6] 1138/11144/191146/2
1147/181149/251152/17
Z
zero [5] 1159/91159/161194/41195/22
1195/25
zoom [1] 1098/20
Case 1:22-cr-00171-MLB-RDC Document 268 Filed 02/10/26 Page 185 of 185File and source
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