Motion in Limine with Brief In Supportby USA as to Carla Jackson, John Gaines — USA v. Thomas et al. (Dkt. 796, N.D. Ga.)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 796 · 2024-01-04 · Docket on CourtListener

Full text

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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
 
v. 
 
TELDRIN FOSTER, 
JOHN GAINES A/K/A MARTY GAINES, 
JERRY BAPTISTE, AND 
CARLA JACKSON 
 
Criminal Action No. 
 
No. 1:20-cr-296-20-JPB 
United States’ Consolidated Motions in Limine 
 
The United States of America, by Ryan K. Buchanan, United States Attorney 
for the Northern District of Georgia, and Tal C. Chaiken and Samir Kaushal, 
Assistant United States Attorneys, and by Glenn S. Leon, Chief of the Fraud 
Section, and Siji Moore, Trial Attorney, respectfully files its Consolidated Motions 
in Limine.   
Background 
Defendants Teldrin Foster, John Gaines, Jerry Baptiste, and Carla Jackson 
are charged in a Second Superseding Indictment returned on August 10, 2021.  
(Doc. 290.)  Foster, Gaines, and Baptiste are each charged with conspiracy to 
commit bank fraud and/or wire fraud (18 U.S.C. § 1349), bank fraud (18 U.S.C. 
§ 1344 and § 2), wire fraud (18 U.S.C. § 1343 and § 2), false statements to a federally 
insured financial institution (18 U.S.C. § 1014 and § 2), and money laundering (18 
U.S.C. § 1956 and § 2).  Jackson is charged with money laundering (18 U.S.C. § 1956 
and § 2).  (Doc. 290.)  All charges arose out of a scheme orchestrated by Darrell 
Thomas to obtain fraudulent Paycheck Protection Program (“PPP”) loans.     
 
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1. 
Motion in Limine to Preclude Defendants’ Admission of their Own Self-
Serving Statements.   
At trial, the United States will seek to introduce portions of statements made 
by some of the Defendants – Foster, Gaines, and Jackson1 – to law enforcement.  
See Fed. R. Evid. 801(d)(2)(A) (statements made by a party and offered against that 
party are “not hearsay”).  These Defendants, however, may not introduce their 
own statements at trial.  
Where a defendant seeks to introduce his or her own prior statements, those 
statements are not “offered against an opposing party” and therefore do not 
qualify as non-hearsay under Rule 801(d)(2).  Fed. R. Evid. 801(d)(2); United States 
v. Willis, 759 F.2d 1486, 1501 (11th Cir. 1985) (affirming the district court’s ruling 
that the defendant could not elicit, through cross-examination of a government 
witness, his own exculpatory statements because placing a defendant’s remarks 
before the jury without subjecting the defendant to cross-examination is “precisely 
what is forbidden by the hearsay rule”); United States v. Santos, 947 F.3d 711, 729 
(11th Cir. 2020) (affirming district court’s admission of inculpatory portions of the 
defendant’s statements and exclusion of exculpatory portions of the defendant’s 
 
1 Baptiste did not make any statements to law enforcement.  
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statements).  The Court should therefore preclude Defendants from introducing 
their own statements at trial.2      
2. 
Motion in Limine to Exclude Bern Benoit’s Hearsay Statements. 
Defendant Baptiste is charged in connection with a fraudulent PPP loan 
obtained by Transportation Management Services Inc. (“Transportation 
Management”).  On July 28, 2020, in response to a grand jury subpoena directed 
to Transportation Management, Bern Benoit – Transportation Management’s 
owner – provided the United States with Transportation Management’s response.   
As part of its response, Transportation Management produced text messages 
between Benoit and Baptiste, with annotations by Benoit regarding the text 
messages.  An example of these annotations is attached as Ex. A.  
The Court should preclude Baptiste from introducing Benoit’s annotations 
for the truth of the matter asserted because those annotations are hearsay that does 
not fall within any exception.  Fed. R. Evid. 801(c); Fed. R. Evid. 802.   
3. 
Motion in Limine to Exclude Victim-Blaming.  
The United States anticipates that Defendants may seek to blame the 
victims of their fraudulent scheme by arguing that the lenders and/or the Small 
Business Administration were too gullible or negligent in approving the PPP 
loans at issue or should have detected the fraud before approving the loan 
applications.  The Court should preclude such evidence or arguments. 
 
2 When a portion of a recorded statement is admitted, the rule of 
completeness “‘does not automatically make the entire document admissible.’”  
Santos, 947 F.3d at 730 (citation omitted); see also United States v. Umbach, 708 F. 
App’x 533, 548–49 (11th Cir. 2017) (rejecting the defendant’s “all-or-nothing 
proposition” because an entire recording does not automatically become 
admissible when a portion is admitted).      
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“A perpetrator of fraud is no less guilty of fraud because his victim is also 
guilty of negligence.”  United States v. Svete, 556 F.3d 1157, 1165 (11th Cir. 2009); 
see also United States v. Teers, 591 F. App’x 824, 844 (11th Cir. 2014) (“[T]he 
negligence of the victim in failing to discover a fraudulent scheme cannot be a 
defense to wire or bank fraud . . . “).  Thus, the Eleventh Circuit has regularly 
precluded the introduction of evidence or argument by defendants that relate to 
the victim’s fault in not detecting the fraudulent scheme.  See, e.g., United States v. 
Roopnarine, 718 F. App’x 797, 808 (11th Cir. 2017) (holding that the district court 
“properly limited defense counsel’s cross-examination when defense counsel 
attempted to imply that the negligence of the financial institutions [that 
approved fraudulent loan applications] in some way negated her client’s intent 
or culpability”); United States v. Powell, 509 F. App’x 958, 967 (11th Cir. 2013) 
(affirming district court’s order on motion in limine precluding the defendant 
from presenting a defense theory that the victim mortgage lenders were 
negligent or complicit in the fraud); United States v. Mendez, 737 F. App’x 935, 
942-43 (11th Cir. 2018) (affirming district court’s order precluding the defendants 
from “advancing only an irrelevant defense” regarding the victims’ intentionally 
risky lending practices and negligence).   
This binding precedent is dispositive here.  Defendants are on trial, not the 
victims.  Any evidence or argument suggesting that the victims were negligent in 
approving the PPP loans at issue would be irrelevant because it could not 
provide any defense to the charged schemes.  Thus, the Court should preclude 
Defendants from eliciting evidence or arguing that the lenders should not have 
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approved the loans or should have detected the fraudulent schemes and any 
other evidence or argument that blames the victims.  
4. 
Motion in Limine to Prohibit Penalty Evidence or Argument.  
Because the penalties a criminal defendant faces are not relevant to the jury’s 
determination of guilt, the Court should bar Defendants from offering arguments 
or evidence regarding potential punishment.  See Shannon v. United States, 512 U.S. 
573, 579 (1994) (“It is well established that when a jury has no sentencing function, 
it should be admonished to ‘reach its verdict without regard to what sentence 
might be imposed.’”) (citation omitted); United States v. Thigpen, 4 F.3d 1573, 1577 
(11th Cir. 1993) (recognizing the “established canon that juries are not to be 
informed of or concerned with the consequences of their verdicts”).  Indeed, the 
Eleventh Circuit’s Pattern Jury Instructions caution the jury that it “must never 
consider punishment in any way to decide whether a Defendant is guilty.”  
Eleventh Cir. Basic Instr. B10.2 (2022).   
As the Supreme Court explained, juries should not consider penalty 
evidence because the penalties associated with a conviction are not probative of 
guilt or innocence: 
 
The principle that juries are not to consider the consequences of their 
verdicts is a reflection of the basic division of labor in our legal system 
between judge and jury.  The jury’s function is to find the facts and to 
decide whether, on those facts, the defendant is guilty of the crime 
charged.  The judge, by contrast, imposes sentence on the defendant 
after the jury has arrived at a guilty verdict.  Information regarding the 
consequences of a verdict is therefore irrelevant to the jury’s task.  
Moreover, providing jurors sentencing information invites them to 
ponder matters that are not within their province, distracts them from 
their factfinding responsibilities, and creates a strong possibility of 
confusion. 
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Shannon, 512 U.S. at 579 (emphasis supplied); See also United States v. Macrina, No. 
1:20-CR-216-SCJ, 2022 WL 4594993, at *1 (N.D. Ga. Sept. 30, 2022) (excluding “all 
arguments and evidence regarding Defendant’s potential penalties and collateral 
consequences” because those matters are irrelevant to the jury’s determination of 
guilt and innocence).   
For that reason, the Court should bar Defendants from introducing evidence 
or argument regarding the potential penalties they face upon conviction, 
including: (a) the maximum or mandatory minimum penalties associated with the 
charged offenses; (b) that, if convicted, Defendants could be sentenced to prison; 
and (c) that parole has been abolished in the federal criminal justice system.   
5. 
Motion in Limine to Preclude Evidence or Argument Regarding Charging 
Decisions. 
The United States anticipates that one or more Defendant may seek to argue 
that others who were involved in Darrell Thomas’s scheme, or others who applied 
for fraudulent PPP loans, were not charged.     
“The Attorney General and United States Attorneys retain broad discretion 
to enforce the Nation’s criminal laws.”  United States v. Cespedes, 151 F.3d 1329, 
1332 (11th Cir. 1998) (internal quotation marks and citation omitted).  As a general 
matter, “so long as the prosecutor has probable cause to believe that the accused 
committed an offense defined by statute, the decision whether or not to prosecute, 
and what charge to file or bring before a grand jury, generally rests entirely in his 
discretion.”  Bordenkircher v. Hayes, 434 U.S. 357, 364 (1978).  Claims based on the 
non-prosecution of other individuals are “not a defense on the merits to the 
criminal charge itself.”  See United States v. Armstrong, 517 U.S. 456, 463 (1996) 
(analyzing selective prosecution challenge).  Because selective prosecution “has no 
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bearing on the determination of factual guilt,” it is “an issue for the court to decide, 
not an issue for the jury.”  United States v. Jones, 52 F.3d 924, 927 (11th Cir. 1995); 
cf. United States v. Hill, 643 F.3d 807, 862-64 (11th Cir. 2011) (on a challenge to the 
sufficiency of the evidence, explaining that the government’s decision not to 
charge another alleged participant in a fraudulent scheme “does not matter for 
purposes” of assessing the defendant’s guilt).   
At trial, the jury will be required to determine whether the United States has 
proven beyond a reasonable doubt that Defendants committed each of the offenses 
charged in the indictment.  The question of whether some other individuals could 
also be charged with offenses related to the same or other conduct has no bearing 
on Defendants’ guilt or the factual determinations the jury will be asked to make.     
6. 
Motion in Limine to Preclude Evidence or Argument Regarding Fourth 
Amendment Issues. 
The United States anticipates that Baptiste and Foster may seek to introduce 
evidence or arguments related to their previously filed motions to suppress 
evidence.  The United States moves to preclude such evidence or argument as it is 
irrelevant to the jury’s factual determinations of guilt.  
It is a “well-established rule that it is for the court, not the jury, to decide 
whether evidence has been illegally obtained.”  Bretti v. Wainwright, 439 F.2d 1042, 
1047 (5th Cir. 1971).3  Thus, a district court may properly prohibit cross-
examination of witnesses and argument to the jury regarding the legality of a 
search warrant and evidence obtained as a result of its execution.  Burris v. United 
 
3 Decisions of the Fifth Circuit pre-dating September 30, 1981 are binding 
precedent in the Eleventh Circuit.  Bonner v. City of Prichard, Ala., 661 F.2d 1206, 
1207 (11th Cir. 1981).   
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States, 192 F.2d 253, 254 (5th Cir. 1951) (“The issues arising upon a motion to quash 
and suppress are not properly for determination by the jury, but rest within the 
province of the trial judge.”).  The Eleventh Circuit has held, for example, that a 
district court properly limited a defendant’s right to cross-examine law 
enforcement officers regarding their authority to enter a hotel, which was “an issue 
of law that the district court had already decided against” the defendant.  United 
States v. Mastin, 972 F.3d 1230, 1240 (11th Cir. 2020).  
Here, Baptiste previously moved to suppress email evidence obtained 
pursuant to a search warrant (Doc. 439), and Foster moved to suppress cell site 
data obtained pursuant to a search warrant (Doc. 493) and statements he gave 
during a voluntary interview with agents (Doc. 494).  The Honorable Catherine M. 
Salinas recommended that the motions to suppress email evidence and cell site 
data be denied.  (Doc. 557; Doc. 639.)  Judge Salinas deferred Foster’s motion to 
suppress statements to the District Court.  (Doc. 498.)  This Court has not yet issued 
its Orders as to these motions.  However, to the extent the Court denies any of 
these motions to suppress, it should preclude Baptiste and Foster from eliciting 
evidence or argument relating to the legality of the searches and of Foster’s 
statements.   
7. 
Motion in Limine to Exclude Evidence or Argument Regarding 
Defendants’ Ignorance of the Law. 
“The general rule that ignorance of law or a mistake of law is no defense to 
criminal prosecution is deeply rooted in the American legal system.”  Cheek v. 
United States, 498 U.S. 192, 199 (1991); see also McFadden v. United States, 576 U.S. 
186, 192 (2015) (“[I]gnorance of the law is typically no defense to criminal 
prosecution.”); United States v. Johnson, 981 F.3d 1171, 1189 (11th Cir. 2020) 
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(recognizing that “a mistake of law . . . is not a defense”).  Accordingly, any 
evidence or argument about Defendants’ potential ignorance of the statutes 
Defendants are charged with violating is irrelevant and inadmissible. 
8. 
Motion in Limine to Exclude Evidence of Defendants’ Generally Good 
Character and Specific Instances of Good Conduct. 
A defendant may not introduce evidence of possessing a generally good 
character. See, e.g., United States v. Camejo, 929 F.2d 610, 613 (11th Cir. 1991) (court 
properly excluded testimony that “attempt[ed] to portray [the defendant as 
having] a good character”); United States v. Cochran, 4:14-CR-022-HLM, 2014 WL 
12695800, at *3 (N.D. Ga. November 17, 2014) (barring the defendant “from 
presenting evidence of his general good character”); see also Fed. R. Evid 404(a)(2) 
(in a criminal case, “a defendant may offer evidence of the defendant’s pertinent 
trait”) (emphasis supplied).4  Thus, Defendants should not be permitted to 
introduce evidence that they possess a generally “good” character – e.g. that they 
are family-oriented, religious, active community participants, or otherwise moral 
and ethical people. See, e.g., United States v. Santana-Camacho, 931 F.2d 966, 967–68 
(1st Cir. 1991) (excluding evidence that defendant was a good family man and a 
kind man because it was not a trait relevant to the offense). 
Likewise, it is well-established that “[e]vidence of good conduct is not 
admissible to negate criminal intent.” Camejo, 929 F.2d at 612–13 (citation 
omitted) (in drug trafficking prosecution, holding that the defendant’s refusal to 
 
4 Under the Federal Rules of Evidence, in some circumstances a defendant 
may present character evidence via reputation or opinion testimony regarding 
lawfulness and often regarding truthfulness – and the prosecution is allowed to 
rebut the same. See Fed. R. Evid. 404(a)(2)(A); Fed. R. Evid. 405(a).   
 
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work in another narcotics business was irrelevant and inadmissible prior “good 
act”).  Thus, the Eleventh Circuit has consistently found proper the exclusion of 
defendants’ prior good conduct evidence when offered to support a defense of 
lack of criminal intent. See, e.g., United States v. Ellisor, 522 F.3d 1255, 1270–71 
(11th Cir. 2008) (concluding that purported legitimate business activities were 
inadmissible in a fraud case); United States v. Russell, 703 F.2d 1243, 1249 (11th 
Cir. 1983) (“‘Evidence of noncriminal conduct to negate the inference of criminal 
conduct is generally irrelevant.’”) (citation omitted); United States v. Ly, 543 F. 
App’x 944, 946 (11th Cir. 2013) (evidence that doctor discharged patients who 
violated his screening protocols was not probative of his intent to dispense 
controlled substances to patients covered by the indictment); see also Fed. R. Evid. 
404(b)(1) (evidence of other acts “is not admissible to prove a person’s character 
in order to show that on a particular occasion the person acted in accordance 
with the character”).  
  
So too, here.  Defendants should not be permitted introduce evidence of 
specific acts of good conduct, including (a) lack of prior bad acts, including acts 
involving drugs or contraband; (b) care of family members; (c) acts of honesty; 
(d) participation in religious, charitable, or community services; and (e) any other 
specific instances of “good” conduct.   
9. 
Motion in Limine to Preclude Evidence and Argument Designed to Elicit 
Jury Nullification. 
The Eleventh Circuit has held that “defense counsel may not argue jury 
nullification during closing argument.”  United States v. Trujillo, 714 F.2d 102, 106 
(11th Cir. 1983) (explaining that the defendant’s “jury nullification argument 
would have encouraged the jurors to ignore the court’s instruction and apply the 
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law at their caprice.  While we recognize that a jury may render a verdict at odds 
with the evidence or the law, neither the court nor counsel should encourage jurors 
to violate their oath.”); see also United States v. Muentes, 316 F. App’x 921, 926 (11th 
Cir. 2009) (“defense counsel may not raise arguments that would encourage jury 
nullification”); United States v. Hall, 188 F. App’x 922, 925 (11th Cir. 2006) (“[A] 
criminal defendant is not entitled to either an instruction or an argument for jury 
nullification”).   
Accordingly, the Court should bar Defendants from attempting to introduce 
evidence or to make arguments designed to encourage jury nullification.  By way 
of example, Defendants should not be permitted to introduce evidence or 
arguments related to (1) the statutes at issue being unfair or applied unfairly in 
this case; (2) the consequences a conviction may have upon Defendants and/or 
their families; or (3) sympathy.  See United States v. Funches, 135 F.3d 1408, 1409 
(11th Cir. 1998) (no error when court denies admission of evidence that would 
support nullification, “even if the evidence might have encouraged the jury to 
disregard the law and to acquit the defendant”).  Such evidence is not relevant to 
the issues at trial, could promote jury nullification, and should be excluded. 
10. Motion in Limine to Admit Self-Authenticating Evidence Subject to a 
Determination of Relevance.  
The United States intends to offer at trial exhibits that are certified copies of 
regularly conducted activities.  These documents are self-authenticating under 
Federal Rule of Evidence 902(11) and should be admitted without the need for trial 
testimony from a records custodian or other qualified witness.  The United States 
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previously provided these exhibits to Defendants, none of whom have identified 
any basis for challenging the authenticity of the records.5      
Federal Rule of Evidence 902(11) provides that “a copy of a domestic record 
that meets the requirements of Rule 803(6)(A)–(C), as shown by a certification of 
the custodian or another qualified person that complies with a federal statute or a 
rule prescribed by the Supreme Court” is self-authenticating.  Fed. R. Evid. 
902(11).  Rule 803(6), in turn, requires that “(A) the record was made at or near the 
time by – or from information transmitted by – someone with knowledge; (B) the 
record was kept in the course of a regularly conducted activity of a business, 
organization, occupation, or calling, whether or not for profit; [and] (c) making the 
record was a regular practice of that activity.”  Fed. R. Evid. 803(6)(A)–(C).  
As to some of its anticipated trial exhibits, the United States has obtained 
certifications that comply with Rule 902(11).  The certifications establish Rule 
803(6)(A)–(C)’s requirements and thus, the records associated with the 
certification are self-authenticating.  See United States v. Lezcano, 296 F. App’x 800, 
807–08 (11th Cir. 2008) (district court properly admitted business records 
accompanied by written declaration of records custodian as self-authenticating).   
Subject to any objections as to relevance, the United States respectfully 
requests that business records accompanied by a certification that complies with 
Rule 902(11) and Rule 803(6)(A)–(C) be admitted as self-authenticating without 
the need for testimony from a records custodian or other witness. 
 
 
 
5 Defendant Baptiste objected to the use of Rule 902(11) to authenticate 
documents provided by Transportation Management.  The United States does 
not at this time intend to rely on Rule 902(11) to authenticate these records. 
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11. Motion in Limine to Admit Summary Charts Under Rule 1006. 
At trial, the United States intends to introduce through witnesses 
summary charts6 that identify information related to the 14 loans that are the 
subject of the charged conduct and/or that relate to Defendants’ 
communications. Specifically, the summary charts will relate to the following: (i) 
information in the PPP loan applications and supporting documents for each of 
the 14 loans; (ii) financial transactions by each business that obtained a PPP loan; 
and (iii) logs of communications between Defendants and Darrell Thomas 
and/or other co-conspirators.  The United States intends to also introduce the 
records upon which the summary charts are based: the PPP loan applications 
and supporting documents, bank records, and phone logs.  These underlying 
documents have already been provided as part of discovery. 
Under Rule 1006, a party may use “a summary, chart, or calculation to 
prove the content of voluminous writings, recordings, or photographs that 
cannot be conveniently examined in court”: 
The proponent may use a summary, chart, or calculation to prove the 
content of voluminous writings, recordings, or photographs that 
cannot be conveniently examined in court. The proponent must make 
the originals or duplicates available for examination or copying, or 
both, by other parties at a reasonable time and place. And the court 
may order the proponent to produce them in court. 
 
6 Drafts of the summary charts will be provided at or before the pretrial 
conference. 
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Fed. R. Evid. 1006. “[T]he underlying evidence on which the summary or chart is 
based must be otherwise admissible.” United States v. Thomas, 631 F. App’x 847, 
849 (11th Cir. 2015). 
Here, the summary charts should be admissible as highly probative 
evidence summarizing voluminous documents related to fraudulent PPP loans. 
The summary charts will pertain to conduct charged within the indictment and 
will distill dozens of pages of loan applications, financial records, and phone 
records into a digestible package that can be conveniently examined by the jury. 
The government intends to admit the underlying records as well, so if the jury 
would like to review those records, they will be available. All of this evidence is 
relevant to the crimes alleged in the Indictment. As such, the United States 
moves for admission of the summary charts at trial. 
Conclusion 
 
For these reasons, the United States respectfully requests that the Court 
grant the above-requested relief.   
 
 
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Dated: January 4, 2024. 
 
RYAN K. BUCHANAN 
United States Attorney 
GLENN S. LEON 
Chief, Fraud Section 
 U.S. Department of Justice 
 
 
TAL C. CHAIKEN 
Assistant United States Attorney 
Georgia Bar No. 273949 
 
 
SIJI MOORE 
Trial Attorney, Fraud Section 
 U.S. Department of Justice 
 
SAMIR KAUSHAL 
Assistant United States Attorney 
Georgia Bar No. 935285 
 
 
600 U.S. Courthouse 
75 Ted Turner Drive SW 
Atlanta, GA 30303 
404-581-6000; Fax: 404-581-6181 
 
1400 New York Ave, NW 
Bond Building, 11th Floor 
Washington, DC 20005 
202-514-2000; Fax: 202-514-3708 
 
 
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