Court filing
TRANSCRIPT of Proceedings as to Carla Jackson, Teldrin Foster held on February 7,… — USA v. Thomas et al (Dkt. 1036)
Record facts
| Court | U.S. District Court for the Northern District of Georgia |
|---|---|
| Filed | 2024-06-17 |
U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 1036 · 2024-06-17 · Docket on CourtListener
Summary
A transcript of jury trial proceedings, Volume 3 (AM Session), in United States of America v. Carla Jackson and Teldrin Foster, Docket No. 1:20-cr-00296-JPB-CMS, held Wednesday, February 7, 2024 before United States District Judge J.P. Boulee in the U.S. District Court for the Northern District of Georgia, Atlanta Division, and filed June 17, 2024 as Doc. 1036. The appearance page lists three attorneys for the Government and separate counsel for each defendant. In the opening the court, called to order at 9:01 a.m., takes up opening statements, invokes the rule on witnesses at a defendant's request and asks counsel to police their own witnesses. The transcript is 138 pages and closes with an alphabetical word index keyed to page and line.
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
The following is the PDF of an official transcript.
Official transcripts may be filed in CM/ECF only by the
Official Court Reporter and will be restricted in CM/ECF for
a period of 90 days.
You may cite to a portion of the attached transcript by the
docket entry number, referencing page and line number, only
after the Court Reporter has filed the official transcript;
however, you are prohibited from attaching a full or partial
transcript to any document filed with the Court.
- - -
Stenographic Court Reporter note:
No AI technology was used in the preparation of this
Official Certified U.S. District Court transcript.
- - -
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 1 of 138
1
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA, DOCKET NO.
1:20-CR-00296-JPB-5-20
vs. VOLUME 3 (AM SESSION)
CARLA JACKSON and
TELDRIN FOSTER,
Defendants.
TRANSCRIPT OF JURY TRIAL PROCEEDINGS
BEFORE THE HONORABLE J.P. BOULEE
UNITED STATES DISTRICT COURT JUDGE
WEDNESDAY, FEBRUARY 7, 2024
Appearances:
For the Government: Tal C. Chaiken, Esq.
Samir Kaushal, Esq.
Babasijibomi Moore, Esq.
For Defendant Jackson: David D. Marshall, Esq.
For Defendant Foster: Leigh Ann Webster, Esq.
Saraliene Durrett, Esq.
Court Reporter: Judith M. Wolff, CRR
Official Court Reporter
1914 United States Courthouse
75 Ted Turner Drive, S.W.
Atlanta, Georgia 30303-3361
(404) 215-1317
judith_wolff@gand.uscourts.gov
STENOGRAPHICALLY REPORTED OFFICIAL COURT TRANSCRIPT
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 2 of 138
2
(Court was called to order at 9:01 a.m.)
THE COURT: All right. Are we ready for your
opening statements?
MS. WEBSTER: Yes, Your Honor. Mr. Moore will be
doing the opening.
THE COURT: Sorry?
MS. WEBSTER: Mr. Moore will be doing the opening
statement.
THE COURT: Okay. Great.
Let's bring in the jury.
Does anyone want to invoke the rule?
MS. WEBSTER: Yes, Your Honor.
THE COURT: Okay. I'll ask you to police your own
witnesses. I obviously don't know who is who back in the
galley, but please do so.
And Mr. Marshall, Ms. Webster, do you all intend to
give your opening statements now?
MS. WEBSTER: Yes, Your Honor.
MR. MARSHALL: Yes, Your Honor.
THE COURT: Very well.
MS. CHAIKEN: Your Honor, for the record, we do
have a case agent who is going to be testifying who will
remain in the courtroom.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 3 of 138
3
THE COURT: Okay. Very well.
(Jury enters the courtroom at 9:06 a.m.)
THE COURT: All right. You all can be seated.
Thank you.
We're off the record for a moment.
(Off-the-record discussion, and proceedings
continued:)
THE COURT: All right. Back on the record.
Again, good morning ladies and gentlemen. Thank
you for being here, and thank you for being here on time.
That's appreciated.
We are now going to hear the opening statements of
the parties.
Go ahead, Counsel.
GOVERNMENT'S OPENING STATEMENT
MR. MOORE: This case is about Teldrin Foster and
Carla Jackson's decision to participate in fraud during a
time of national crisis.
Let me take you back to 2020. The COVID pandemic
had shut down this country. People were told to stay home.
Businesses had to close their doors. And in the face of
this, the government moved quickly to give direct economic
assistance and relief to suffering people and businesses.
At the end of March, 2020, Congress passed a law
called the CARES Act. This was designed to give direct
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 4 of 138
4
economic assistance to people and businesses impacted by the
COVID-19 pandemic. Part of that assistance was a program
called the Paycheck Protection Program, or the PPP.
Under the PPP, businesses could apply for a loan
for approved expenses like rent, utilities or payroll.
The program was designed for businesses that
existed before February 15, 2020, before the pandemic
started.
And if the businesses spent the money on approved
expenses, the loan could be forgiven, meaning the businesses
did not have to pay the money back.
The PPP program was designed to get funds out
quickly. The funds were meant to be a lifeline to small
businesses and their employees. The funds were meant to keep
small businesses afloat. In sum, the funds were meant to
help small business owners and their employees survive.
In order to get that money out quickly, in order to
get it to the people who needed it the most, the PPP program
relied on people to tell the truth.
During this trial you will see that the PPP form
asked businesses to list the number of employees they had,
the average monthly payroll, and to certify that their
applications were truthful.
The loan amount was two and a half times the
business's average monthly payroll. So if a business had an
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 5 of 138
5
average monthly payroll of $100,000, then they could get a
PPP loan of $250,000.
As part of the plan to get the money out quickly,
the lenders could rely on the representations made in the PPP
applications and they didn't have to do an in-depth
investigation to verify that the small businesses actually
had the number of employees they claimed or actually had the
payroll expenses they claimed. The program was designed to
get the money out as fast as possible to the people who
desperately needed their paychecks to stay afloat.
In this trial the evidence will show how defendants
exploited the PPP program. You will see how they turned this
national crisis into an opportunity to take advantage of our
nation's generosity.
Here's how the fraud worked:
The evidence will show that starting around April
of 2020, mastermind Darrell Thomas worked with a variety of
people to submit fraudulent PPP loans for businesses that
existed only on paper, and they would move the money around
to make it harder for these transactions to be traced.
Each person had a different role. At the top, you
had Darrell Thomas who supervised the participants and
directed the submission of documents. Below him you had
people like defendant Teldrin Foster, who was involved in
creating false documents in support of 14 fraudulent loan
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 6 of 138
6
applications that resulted in millions of dollars of
payments.
In the next rung, Darrell Thomas had recruiters
whose job it was to find individuals who were willing to
pretend to be purported business owners. In exchange for
finding people who pretended to be business owners, each of
the recruiters would receive a portion of the loan funds.
Finally, the fraud relied on money launderers like
defendant Carla Jackson, who received more than $300,000 of
stolen money and moved it around to make it harder for it to
be traced.
During this trial you are going to hear about the
PPP program from a representative of the SBA, or the Small
Business Administration as it's formally known. They were in
charge of the program.
You will also hear from lenders who were involved
in the loans that are at issue in this case. And you will
hear from an IRS employee who will tell you that none of the
businesses at issue in this case submitted payroll tax forms
in 2019. So all of the tax forms you will see in this case
were fraudulent and were never submitted to the IRS.
You are going to see hundreds of emails and text
messages that these defendants exchanged while they were
committing these frauds.
You are going to hear interviews conducted with
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 7 of 138
7
these defendants while they were under investigation. You
will see with your own eyes how these loans were set up,
submitted and spent.
You will see how these defendants were involved in
the fraud and the coverup. You are going to see the long
paper trail that these defendants left.
The evidence will show that Darrell Thomas and
Teldrin Foster had a business relationship before the COVID
pandemic began.
Immediately after the PPP program was announced,
Darrell Thomas reached out to Teldrin Foster about recruiting
people for PPP fraud. The evidence is going to show that
from the day the program was announced, Teldrin Foster and
Darrell Thomas communicated nearly every single day, often
multiple times a day.
They exchanged hundreds of calls in less than four
months. Foster created and stamped tax documents so they
would look like they came from the IRS and then used those
documents in support of the fake PPP applications.
He did that for more than a dozen business
applications, and many of those forms were nearly identical,
the exact same numbers for every business with just a
different business name at the top.
You will see that Darrell Thomas submitted PPP loan
applications for more than a dozen businesses where
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 8 of 138
8
supporting documents the defendant Teldrin Foster created,
and those businesses got millions of dollars of PPP money.
And you will see that Teldrin Foster brought his
wife, Gena Pyfrom-Foster, in to help because she worked for
the IRS so she understood how all these different business
tax forms worked.
You will see that Gena Pyfrom-Foster didn't know
Darrell Thomas before the PPP program began.
In this case you will also hear Teldrin Foster in
his own words. You will hear him admit during an interview
that him and Darrell Thomas worked together to get a
fraudulent PPP loan for Darrell Thomas's company.
You will hear him admit that it was wrong and that
they were stealing from the government.
You will hear him admit that Darrell Thomas paid
him $50- or $60,000, both in checks to himself and to his
wife, Gena Pyfrom-Foster, and you will hear him say that he
was upset that he did not get even more money.
You will hear Teldrin Foster admit that to get the
PPP loan money in the way he and Darrell Thomas did was
fraud.
Finally, you have the money launderer, Carla
Jackson, who, under her ex-husband John Gaines's direction,
moved around the proceeds of the loans given to a business
called Gaines Reservation and Travel. You will see that
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 9 of 138
9
Foster, Thomas, and John Gaines worked on a PPP loan for
Gaines Reservation and Travel.
Though the business existed only on paper, it
received a loan of more than $800,000.
You will also see what Gaines Reservation and
Travel did with the loan proceeds. Gaines Reservation and
Travel did not pay payroll expenses or rent because it had no
payroll expense or rent, but they wanted to make it look like
it did so that the loan would be forgiven.
After the loan proceeds were deposited into the
Gaines Reservation and Travel account, John Gaines worked
with his ex-wife, Carla Jackson, to conceal the fraudulently
obtained PPP money. Carla Jackson used her purported
business, Management Resources, to move the Gaines PPP money
around.
In January 2020, February 2020, March 2020, April
2020, and May 2020, the bank account for Management Resources
had zero transactions, just a monthly service fee.
Then, all of a sudden, in June 2020, Management
Resources received more than $335,000 into its account in two
separate deposits from Gaines Reservation and Travel, a wire
transfer and a check.
The check said that it was for "consulting fees
business management." But the evidence will show that was a
lie. The evidence will show that Carla Jackson could not
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 10 of 138
10
have been consulting for a business that had no employees.
The evidence will show that Carla Jackson could not
have been managing a business that only existed on paper.
The evidence will show that Carla Jackson was not doing
anything for Transportation Management except laundering
stolen money.
You will hear Carla Jackson interview with FBI
agents where she told lie after lie, after lie about what the
money John Gaines sent her was for.
She told the agents it was for a project she was
doing at Gaines Reservation and Travel, but she couldn't tell
the agents anything about what the project was.
She pretended not to be familiar with who the owner
of Gaines Reservation and Travel was, even though the owner
on paper was John Gaines's relative, and her ex-husband John
Gaines was the person instructing her on what to do with the
PPP money.
She claimed to have a written proposal to Gaines
Reservation and Travel for the alleged project and that she
could provide that proposal to the FBI. But when she was
subpoenaed, she all of a sudden could not find the document.
In this trial, you will see what she actually spent
the money on. She wrote two $10,000 checks; each was used to
pay off an auto loan for John Gaines. And she wrote another
$10,000 check for a company controlled by John Gaines. After
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 11 of 138
11
that, the government seized the rest of the money.
The evidence will show this money was never for a
project. It was just to make it look like Gaines Reservation
and Travel was spending money on something it was allowed to
spend money on. And the evidence will show that Carla
Jackson knew that and that is why she lied about it.
Both of these defendants face various charges for
their role in this scheme.
For his role with 14 false PPP applications, Foster
is charged with conspiracy to commit bank and wire fraud, and
wire fraud. He's also charged with false statements to a
financial institution and money laundering.
For transferring the stolen money around through
accounts to hide it, Carla Jackson is charged with money
laundering. Those are the charges. And soon, you will hear
the evidence.
We ask you to focus on both of the defendants,
their own words and misrepresentations, their spending of the
stolen money and their attempts to cover up this fraud.
After you hear the evidence, the government will
ask that you return the only verdict that is consistent with
both the law and the facts, that both of these defendants are
guilty of each charged crime beyond a reasonable doubt.
Thank you.
THE COURT: Defense.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 12 of 138
12
DEFENDANT FOSTER'S OPENING STATEMENT
MS. WEBSTER: Thank you, Your Honor.
Good morning. When I was a teenager, I had a
summer job working with my mom. And one thing that I
remember clearly about that time is that they always had the
local radio station going. I'm from a small town in Georgia,
so it was often about things like high school football and
that sort of stuff.
But every day around lunchtime, they played Paul
Harvey's "The Rest of the Story." I'm not sure if you have
heard of him, but Paul Harvey was a radio personality and he
was famous for short stories that always had a twist at the
end. And once he explained the twist, he would say, "And now
you know the rest of the story."
And sometimes those stories were hard to believe,
but they were true. They were just stories that we had not
heard before. They were facts that defied expectations. And
we have lots of sayings that sort of reflect this idea: "The
truth is stranger than fiction." "You can't make this up."
Things like that.
And this case is like that. I want to say it's a
bit like one of the Paul Harvey stories, but it's going to
take a lot longer than two to three minutes to tell it.
From the government's perspective, this story is
simple, although even under that version, it's going to take
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 13 of 138
13
longer than two to three minutes.
From the government's perspective, they have
charged Teldrin Foster with not one, but many crimes and
their evidence supports a conviction on every single count.
They will tell you, as they just did, that Darrell
Thomas, the ringleader of this entire PPP scheme, received
many, in fact, hundreds of emails from Teldrin Foster's email
addresses. And those emails contained fraudulent documents
that were used to then apply for the PPP loans.
They will tell you that Darrell Thomas sent Teldrin
Foster money, including a check for $34,000. And they will
tell you, as they did, that Teldrin Foster gave a statement
where it sounds like he's admitting to being involved in at
least one of those loans.
And if the evidence just showed that, you might be
wondering what we are doing here, and you would be justified
in wondering that.
But as I said earlier, there is more, a lot more,
to this story. We believe that the evidence will also show
that Darrell Thomas and Teldrin Foster had a pre-existing
relationship for years, before 2020. And during that time,
Darrell Thomas cheated Teldrin out of money, a lot of money,
tens of thousands of dollars of legitimate money that he had
earned. And Teldrin wanted Darrell Thomas to pay him back
the money that he was owed.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 14 of 138
14
And Teldrin was married to a woman named Gena
Pyfrom-Foster. But Teldrin rarely stayed at home and they
kept a lot of information from each other. And Gena, Gena
just happened to work for the IRS.
Remember the fake documents that were in the
emails? Those were tax forms and payroll documents. And you
will hear and you will see that Gena and Darrell began
emailing each other in early April 2020. They were emails
about a tax return for Darrell Thomas's company, which is
called the Bellator Phront Group.
And shortly thereafter, Gena and Darrell Thomas
started working together to commit PPP loan fraud. Darrell
needed Gena's knowledge from her work with the IRS.
Even the agents zeroed in on this when they
interviewed Teldrin. They asked: Who knew how to fill out
these forms? They didn't think that it was Teldrin.
And when you hear the evidence, it's going to be
your turn to decide: Who knows how to fill out those tax
forms? Is it the IRS employee or someone who works as a
barber and a club promoter?
But you won't just hear us speculate about this.
You are going to hear facts. Two email addresses associated
with Teldrin Foster were accessed on Darrell Thomas's
computer. And I don't mean accessed once. I mean that the
computer had the email address saved and that the evidence
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 15 of 138
15
showed that it was visited repeatedly.
And maybe more importantly, you are going to hear
that Gena had access to both of those email accounts.
So while you will hear that Teldrin's email
addresses were used, you will hear significant evidence that
Teldrin Foster was not the one using those email addresses.
You will also hear that there are all sorts of
other people involved in this scheme and that Darrell Thomas
was receiving documents from other sources. He had brokers
to help him find people and those brokers also sent him false
documents.
Now, once he received the false documents, he
submitted the loans and then he receive the money. He had
the business owners who received the funds initially transfer
that money into various accounts. Those accounts were his
companies, the Bellator Phront Group, another company called
Elite Executive. And there were more. But what you will not
hear is that Teldrin Foster had access to any of those
entities or any of those accounts.
And when Darrell Thomas received the money from the
PPP fraud, over $10 million, you will be able to see how he
spent it. Cars, land, jewelry -- expensive jewelry. But you
won't see evidence that Teldrin Foster had anything like
that.
You will also hear evidence that Darrell had agreed
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 16 of 138
16
to pay Gena $10,000 per loan that she helped him with, and
you will see that Teldrin is charged with one count of money
laundering for $10,560 that was deposited into a bank account
on June 10 of 2020.
But you will see that this money was deposited into
a Bank of America account that Gena had set up for the
explicit purpose of receiving funds from Darrell Thomas and
that Teldrin Foster was not an authorized signer on that
account.
And you will hear that Darrell and Gena
communicated about that deposit, not that they were in
communication with Teldrin about that deposit.
You will hear that after the FBI agent came to
speak with Gena, Teldrin went in to meet with them and made a
statement. And we're going to ask that you listen to that
statement carefully. We want you to think about if Teldrin
was aware of what the agents were asking him. It's sort of
like one of those comedy bits.
They say: You sent these emails.
I sent these emails?
You sent these documents.
I sent these documents?
So you will be able to hear in his voice the
confusion he had when he was learning that someone was using
his email address to send these documents.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 17 of 138
17
You will hear evidence that Teldrin received money
from Darrell Thomas, but you won't hear that he knew that
that money came from a PPP loan.
Instead, we expect the evidence to show that
Teldrin believed that it was money that was owed from
Darrell, and Teldrin was insistent because it was the
retirement money that he had after he was working for the
Florida Department of Corrections for ten years.
So we're asking that you listen closely to the
government's case, but also listen for the rest of the story.
And when you hear the whole story, you will see that Teldrin
Foster is not guilty.
Thank you.
DEFENDANT JACKSON'S OPENING STATEMENT
MR. MARSHALL: Good morning.
Carla Jackson admitted no crime. She never
laundered any money. She never received any money that she
knew came from any illegal source. And she did not use her
business, Management Resource Services, to try and conceal
monies that came from any illegal activity.
I expect that the government's evidence in this
case will be voluminous, lots and lots of documents and
witnesses and the phone records and emails and text messages
and computer analysis. You will see a laptop that an
analysis has been done on. Evidence about internet IP
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 18 of 138
18
addresses, scores of witnesses, and on and on and on.
And the government will need all of these lawyers
at these two tables here to try to put all of this ocean of
evidence in front of you.
Now, I want to make an aside here. By the way, the
government won't be presenting -- they made a reference to
all of these hundreds and hundreds of emails. We expect that
there will be no evidence at this trial of email
communication between Carla Jackson and anybody else about
anything related to any kind of fraudulent loans or any text
messages. There will be no text messages where Carla Jackson
is one of the parties talking about fraudulent loans.
And the government, you are going to find out,
never did any forensic analysis, you will hear during trial,
of any computers that Carla Jackson owned.
You will hear evidence that Agent Stites from the
FBI went to Ms. Jackson's residence and interviewed her, but
there was no attempt to try to get any computers or laptops
at all from Ms. Jackson to see what they would hold.
And why didn't they do that? Because they know
that they didn't have the evidence of anything in those
devices.
But the evidence the government wants to introduce
at trial against Ms. Jackson is but a drop into that ocean of
the evidence that I just mentioned.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 19 of 138
19
The main evidence, primary evidence, is going to
consist of two separate deposits that were deposited into her
business banking account.
The name of that business, again, is Management
Resource Services. And these two deposits, the government
will argue, are meant to show that Ms. Jackson must be
involved in money laundering.
But you will hear during jury instructions that a
critical element is that you have to know that the source of
funds you are receiving and allegedly laundering come from an
illegal source. But she wasn't involved in money laundering
at all.
In addition, the government, I expect, will present
an audio recording of what I call a knock and talk. That's
where a law enforcement officer, in this case two FBI agents,
show up early in the morning at Ms. Jackson's home,
unannounced.
They do not call in advance. They do not give her
any warning. It's not a sitdown interview. They do not give
her an opportunity to maybe contact an attorney to see if
maybe she should talk to these two FBI agents showing up at
her door.
They asked her questions, voluminous questions,
about Gaines Reservation and Travel, questions about other
names of individuals that she might know or doesn't know and
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 20 of 138
20
about other parties.
Now, mind you, she had never, in her entire life,
been approached by FBI agents at her home -- or anywhere.
And not once during this encounter -- and this occurred on
July 7, 2020 -- did the agents ever kind of suggest that my
client should maybe consult an attorney.
The entire length of that recording is about 13
minutes long. And only at the very tail end of that you will
hear evidence that Ms. Jackson finally mentions, maybe I
should talk to an attorney. And that's when the conversation
basically ends. 13 minutes. That occurs at about the
12-minute mark.
Now, the government's playing of this recording
between FBI Agent Joseph Stites -- and there is a second FBI
agent who is present at the time too, his name is Mr. Cromer
(phonetic) -- it's meant to imply that she has done something
wrong.
You heard allegations or statements from the
government in their opening that she made false statements.
Well, we will explain that as the trial and the evidence goes
on and you hear from witnesses here.
You will also see documents introduced by the
government from Ms. Jackson's business. You heard that you
will get bank statements from this company. From January
2020 up to June 2020, well, there was a small amount, small
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 21 of 138
21
balances in the account. And the government will imply that
those small balances and then a huge balance, over $300,000
in June of 2020, must be evidence that someone is money
laundering.
That doesn't prove knowledge of anything. There is
a reason why her bank account had a large amount of money in
June of 2020 and the evidence will show you why that is and
who had knowledge of it and who had knowledge of the source.
And mind you, at the time that Ms. Jackson was
working -- this was not something where she had some small
business, hardly made any money, and then there is this large
amount of money that came to her.
You will hear testimony in this case that she was a
very accomplished and a successful businesswoman. She worked
over 20 years for IBM corporation as a senior project manager
and had worked at other companies holding similar positions.
This is not somebody that just is here trying to
make some fast money. She didn't know anything about the
source of these funds. And we're going to explain why that
is, and you will hear that at trial.
Let's talk a little bit about the two deposits that
the government referenced. The first deposit occurred on
June 8, 2020, for approximately $250,000. It was actually
$255,252.50.
I want to note one thing. You are going to get a
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 22 of 138
22
copy of the indictment and you will hear these counts that my
client is charged with. In all of the counts of this
indictment, she is charged in two counts, Count 46 and 47.
They are on pages 66 and 67 of the indictment.
You will note that the Count 46 references a wire
transfer. You will be given a definition of what a wire
transfer means. But there is an error in the government's
indictment because this was no wire transfer at all.
On June 8, 2020, it was an in-branch bank deposit
of a business check. That's not a wire fraud count. That's
basically someone going in and making a deposit.
I just point this out because that's an error that
has ridden along with the government's case all the way
through today when we are sitting here.
You will get a copy of what's called the second
superseding indictment. A second superseding indictment
implies that there is a first superseding indictment. And a
first superseding indictment implies that there was an
original indictment.
I will tell you that Ms. Jackson -- she has been
charged in each of those indictment, and each one gets
replaced as charges were added for certain people and that
error was never fixed by the government. They didn't notice.
It was sloppy by the government. But it's typical
of the sloppiness of their investigation related to
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 23 of 138
23
Ms. Jackson.
Now, the second deposit occurred on June 22, 2020.
And that's referenced in Count 47 of the second superseding
indictment.
Now, that is from a bank account of Gaines
Reservation and Travel to the bank account of Management
Resource Services. That is an actual or alleged wire
transfer where a wire is done from one bank to another.
Now, you will see and hear evidence about a person
named John Gaines. You have already heard his name
referenced. And there is an André Gaines; they are actually
related. They are cousins.
Mr. John Gaines is one of the codefendants in this
case, and he pled guilty on January 31 of this year to one of
the same counts that Ms. Jackson is charged with, Count 47.
So he was charged with many counts other than 47.
He was charged with counts 46 and 47, the same two counts as
Ms. Jackson is, and a score of other counts. But he pled
guilty only to one count. That was done on January 31.
Now, the judge will point out to you in jury
instructions that just because Mr. Gaines pled guilty to one
of those counts that my client is charged in, that has no
impact on the guilt or innocence of whether my client is
guilty of the same counts.
You are to treat them entirely separately and the
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 24 of 138
24
evidence separately. And you will know why that's important
when I talk to you a little bit more about John Gaines.
John Gaines is a very important codefendant for
other reasons, because he knows all of the information about
Gaines Reservation and Travel and about the work he did in
preparing fraudulent PPP loans for his cousin. And again, if
you hear "PPP," that's Paycheck Protection Program.
He helped prepare these fraudulent PPP loans for
his cousin, André Gaines, the owner of Gaines Reservation and
Travel. John Gaines also knew Darrell Thomas very well. And
you will hear from Darrell Thomas, I expect, as a government
witness, someone who pled guilty in this case.
But you know who else you are going to hear from at
trial besides defendants that the government will call to
boost their case? You are going to hear from John Gaines
himself.
John Gaines is going to come here and testify at
trial, we expect, but it won't be for the government. It's
going to be for Carla Jackson. He will testify in person.
And why? I'll tell you the government is not too
happy about that. And why is that? Well, because John
Gaines is going to contradict the story that the government
wants you to believe about Ms. Jackson.
Mr. Gaines will inject into this case more than the
reasonable doubt that's required about these two charges
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 25 of 138
25
against her. He will tell you that she is innocent, that she
had no knowledge of the illegal nature of the funds that made
their way into her bank account and that he orchestrated all
of it without her knowledge, which was very typical for John
Gaines.
Some quick back-story and what we expect you will
also hear during testimony: Mr. John Gaines and Carla
Jackson once married. You heard the government indicate that
they were divorced. It's true. They had known each other
for about 27 years, and 13 of those years they were married.
They didn't have any children together.
But that marriage officially came to an end in May
of 2020. Remember these checks that went into that bank
account occurred in about June 2020, so I'm trying to give
you a little bit of chronological context.
You will also hear during trial why that marriage
dissolved, and you will learn that it was because of secrets
that John Gaines kept from his wife, Carla Jackson.
Important things, very important things, the types of things
that would crush almost any spouse: Infidelity by Mr. Gaines
while he was married to Ms. Carla Jackson; children born out
of their marriage to another woman and fathered by
Mr. Gaines; secrets, hurtful secrets, damaging secrets.
And what Carla Jackson also learned through this
case, since July of 2020 and onward, was that John Gaines
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 26 of 138
26
kept everything he had done involving these fraudulent loans
a secret from her. Secrets upon secrets, upon secrets.
John Gaines never told Carla Jackson that these
funds that her business received in June 2020 came from
illegal PPP loans. He told her that he had funds that she
could use in her business, Management Resource Services, to
help develop a real estate project in Montgomery, Alabama.
In fact, John and Carla Jackson went out and
visited Montgomery, Alabama, to look at some property that
they were considering for this project. When you heard the
government reference that check that had consulting fees, you
will hear that's related to that. And André Gaines knows
some of that, too.
And you will also see during trial John Gaines --
we expect him to testify -- you will see some photos of that
visit and you will hear from John Gaines himself about that
trip with Ms. Jackson.
Ms. Jackson was going to basically do this project,
be the one in charge of it. You will hear some reference to
that when she is questioned by Agent Stites during that knock
and talk in that unannounced visit.
But you will hear that this was a real project that
she had expected to do with John Gaines. But as I told you
before, John Gaines will testify he kept information from
Carla Jackson. Lots of it.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 27 of 138
27
He will testify that his ex-wife never had any idea
of the fraudulent loans that he was involved with, with
Darrell Thomas, another person you will hear from at trial.
When you hear John testify, you will hear about
where he was when Agent Stites showed up at Ms. Jackson's
residence on July 7, 2020. We're going to talk to you about
that later but you will hear it through testimony.
As I mentioned before, some of Ms. Jackson's
background, she is not some desperate person that would ever
entertain a PPP loan fraud. She did not need to. She had
ongoing businesses. When the government mentioned again
those banks statements with those low balances, Ms. Jackson
was working.
At that particular time, I think she had a little
bit lower income than usual. It might have been around
$145,000 or whatever, but she made more than that on a
regular basis in her positions as program managers and
consultant.
Her Management Resource Services was a business
that she was trying to build up over time. So the idea of
these minimal balances of $200 and $300 to imply fraudulent
participation in PPP is not there.
Now, at the end of the evidence in this case, I do
want -- let me say this. The government is alleging that my
client has committed these crimes. The only -- she has
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 28 of 138
28
committed no crimes. And the only flaw that you will find in
Ms. Jackson is that she trusted a man in a relationship who
routinely lied to her and who was an expert at keeping
secrets from her.
At the end of the evidence in this case, from both
the government and both defendants, the judge is going to
instruct you on the law in what are called jury instructions.
These are very important instructions because they will tell
you how to apply the law and the evidence to the facts that
are presented to you during trial.
Please listen very carefully when the judge reads
those instructions. They can be very lengthy, maybe up to an
hour in length.
Especially listen to the definitions of what money
laundering is, what the elements of proof are for the
government. Every element of proof has to be proven by the
government beyond a reasonable doubt.
You will get an instruction about what reasonable
doubt means. Instructions on presumption of innocence, and
again, reasonable doubt.
Now during this trial, we will defend Ms. Jackson.
We will ask questions. We will make objections, if
necessary. Never forget that it is the government's
responsibility to prove Ms. Jackson guilty beyond a
reasonable doubt, that she is guilty of two counts of money
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 29 of 138
29
laundering, Counts 46 and 47.
Ms. Jackson never laundered any money. And she
never laundered any money because she never knew that the
money she received into her business was from a fraudulent
source.
At the end of the evidence in this case, we believe
that you will have no doubt that Ms. Jackson is not guilty of
either of these two charges because she committed no crime.
Thank you.
THE COURT: All right. Thank you, Counsel.
The United States wants to call its first witness.
MR. KAUSHAL: Your Honor, the government calls
Kandace Zelaya.
KANDACE ZELAYA,
Having been first duly sworn, testified as follows:
DIRECT EXAMINATION
BY MR. KAUSHAL:
Q.
Good morning, Ms. Zelaya.
A.
Good morning.
Q.
Can you please state and spell your name for the
record?
A.
Kandace. K-A-N-D-A-C-E.
Zelaya. Z-E-L-A-Y-A.
Q.
And Ms. Zelaya, where are you employed?
A.
The United States Small Business Administration.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 30 of 138
30
Q.
And what does the Small Business Administration do?
A.
It is an independent federal agency that its
mission is to help small businesses throughout the nation.
We provide different types of assistance:
Educational, business development, financial assistance,
government contracting assistance, and assistance after a
disaster.
Q.
And you just mentioned disasters. Was there a
disaster that occurred back in approximately 2020 in the
United States?
A.
Yes. The Coronavirus-19 pandemic was declared a
disaster.
Q.
And that is the COVID-19 pandemic, correct?
A.
Yes.
Q.
Did the SBA administer programs in response to the
COVID-19 pandemic?
A.
Yes, we did.
Q.
And was that done pursuant to federal statute?
A.
Yes.
Q.
What was the statute that resulted in the SBA
administering programs for COVID-19?
A.
The Coronavirus Aid Relief and Economic Security
Act, which is known as the CARES Act.
Q.
And was when the CARES Act passed, ma'am?
A.
March 27, 2020.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 31 of 138
31
Q.
What programs did the SBA administer -- let me
withdraw that.
Did the CARES Act create programs that the SBA
administered?
A.
Yes.
Q.
What were those programs?
A.
The Paycheck Protection Program and the Economic
Injury Disaster Loan Program for the COVID-19 pandemic.
Q.
Very briefly, can you describe what the Economic
Industry Disaster Loan Program was?
A.
That was a program designed to help businesses
replenish their income to put them in the position before the
disaster occurred.
Q.
And the other program was the Paycheck Protection
Program?
A.
Yes.
Q.
That is colloquially referred to as the PPP?
A.
Yes.
Q.
Did you have a personal role in implementing the
PPP?
A.
Yes. I was part of the team that worked on
drafting all of the forms, the application forms for the
borrower and the lender, the interim final rules, and
frequently asked questions and policy and procedural notices
that provided the public and the lenders with all of the
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 32 of 138
32
information about the program requirements.
Q.
And I skipped over this, so let me take a step
back.
Can you describe your role at the SBA?
A.
I have been with the agency for 32 years. And I am
an attorney in the Office of General Counsel. I have been
both in headquarters and the field and I have worked
primarily on all aspects of our business loan programs.
Q.
What is your current role at the SBA?
A.
I am a trial attorney in the Office of Litigation.
Q.
And you just explained that you were involved in
implement being the PPP for the SBA?
A.
Yes.
Q.
Can you tell the jury what the purpose of the PPP
was?
A.
The primary purpose, as the name suggests, was to
keep workers employed and keep their paychecks coming, so to
keep them paid.
Q.
So let's talk about when the PPP program rolled
out. When did that program actually start?
A.
The program started -- we began accepting
applications on April 3 of 2020.
Q.
When was the CARES Act passed?
A.
March 27 of 2020.
Q.
And when was the program, the PPP, announced to the
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 33 of 138
33
public?
A.
The first draft guidance was posted on our website
and Treasury's website on April 2, the night before we were
beginning to accept applications on April 3 of 2020.
Q.
What were -- so you mentioned -- can you tell me a
little bit more about what -- let me withdraw that.
Was there a way to get a loan via the PPP?
A.
Yes. The applicant would apply through a lender,
which typically at the time would have been online because no
one was going anywhere in person back in April of 2020.
They would submit their application and supporting
documentation to the lender. The lender would make the
decision to approve the loan, and then the lender would enter
certain information into SBA's electronic system to obtain
the guarantee on the loan.
And once we issued a loan number, the bank would
then disburse the funds to the borrower.
Q.
So this particular type of loan, were there
eligibility requirements for it?
A.
Yes.
Q.
What were those eligibility requirements?
A.
In addition to having to be a certain size, which
was generally not more than having 500 employees, the
business had to be in operation as of February 15 of 2020,
which meant it had to have employees for whom it was paying
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 34 of 138
34
salaries or payroll taxes or was paying independent
contractors.
Q.
And what was the -- this loan, were there specific
purposes that it could be used for, authorized purposes?
A.
Yes. The PPP loans could only be used for
authorized purposes, which included eligible payroll costs,
so salaries and wages of your employees; their health
benefits, et cetera; and also limited non-payroll costs,
which were mortgage interest payments if you owned your
building that your business was located in, or rent or lease
payments or utilities for your business.
Q.
Could a recipient of a PPP loan use that money for
personal expenses?
A.
No.
Q.
Ms. Zelaya, are you familiar with the term interim
final rule, or IFR?
A.
Yes.
Q.
What is that?
A.
An interim final rule is a rule that an agency
publishes to provide information about a program or changes.
And the interim final rule is effective immediately.
Normally in federal rule-making process, if you
publish a final rule, there would be a delayed effective
date, it won't be effective until 30 days. But because of
the emergency nature of the pandemic and the emergency relief
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 35 of 138
35
provided in the CARES Act, the rules regarding the PPP were
published as interim final rules so they would be effective
immediately.
Q.
And those rules, did those contain eligibility
requirements that we just discussed?
A.
Yes, they did.
Q.
Were those rules publicly available?
A.
Yes. They were published on both SBA's and the
Department of Treasury's website but also published in the
Federal Register.
Q.
Is it fair to say that over time the rules changed
in some form?
A.
Yes, they did. There were subsequent acts of
legislation that were passed after the CARES Act that made
some additional changes to the program.
Q.
Did the basic requirement that the business existed
on February 2020 and have employees, did that requirement
ever change?
A.
No.
Q.
So that was always a rule and is still is a rule?
A.
Yes.
Q.
You talked about this a little bit earlier. You
described the application process. I would like to break it
down just a little bit and walk through it slightly slower.
So when an applicant is applying, the borrower,
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 36 of 138
36
they contact a lender, correct?
A.
Correct.
Q.
And the lender, what -- who are the lenders that
we're talking about here? What are they?
A.
The lenders could be banks, credit unions, other
types of financial institutions who provided the loans.
The applicant would apply to the lender and provide
all of their information to the lender, and the lender,
according to the CARES Act, made the decision to approve the
loan and then requested a guarantee on the loan from SBA.
Q.
And there was an application that is submitted to
the lender that has to be filled out, correct?
A.
Correct.
Q.
After the lender gets the application, they conduct
some -- they either approve or disapprove the application,
correct?
A.
Correct.
Q.
And after that step, there is information that the
lender provides to the SBA; is that right?
A.
Yes. They enter certain information: The lender's
contact information, information about the business and the
terms of the loan, how much it was, the interest rate, which
for all PPP loans was a 1 percent fixed, and the term, either
two or five years, and various certifications that the
borrower made to the lender, the lender described to SBA.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 37 of 138
37
Q.
Can you tell me whether that information from the
lender to the SBA was submitted electronically?
A.
Yes. All of that information was submitted by the
lender to the SBA electronically.
Q.
And when it's submitted, at least in 2020, were the
servers for the SBA located in Virginia?
A.
Yes.
Q.
After the information goes to the SBA, what happens
at that point?
A.
If it goes through our system without any errors,
the system would issue an SBA loan number indicating that the
loan was guaranteed by SBA, and we would notify the lender of
the loan number and then they would disburse the funds to the
borrower.
Q.
And just a little -- the SBA loan number, is that
sometimes colloquially referred to as the e-tran number?
A.
Yes. Because our system that generates it is
called e-tran or electronic transmission system.
Q.
What happens after the SBA loan number is
transmitted back to the lender?
A.
The lender then has 10 days to disburse the funds
to the borrower.
Q.
In connection with an application are there
supporting documents that need to be provided by the
applicant?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 38 of 138
38
A.
Yes. The applicant has to provide supporting
documents to show that it had employees that it was paying
salaries for as of February 15 of 2020, and also to support
the calculation for its average monthly payroll and the
maximum loan amount.
Q.
Can you tell me whether bank statements are a
document that constitutes a supporting document for an
application?
A.
Yes.
Q.
And what about a Form 941? Is that something that
is a supporting document?
A.
Yes. Various tax forms could be used to support
the information in the application, including 941s.
Q.
Is a 941, does that relate to payroll taxes?
A.
I believe it's a quarterly tax form that is
submitted by businesses on a regular basis.
Q.
So once the loan is approved -- and you may have
covered this already. But once the loan is approved, where
does the loan money actually come from?
A.
It comes from the lender.
Q.
And what is the SBA's role in connection with that?
A.
SBA provides a guarantee to the lender. So if the
borrower does not pay the loan back as agreed under the note,
then SBA would pay the lender the guaranteed percentage on
the loan.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 39 of 138
39
Q.
Is there also something -- after a loan has been
disbursed, is there a forgiveness process that was in place
for the PPP?
A.
Yes. These loans were forgivable up to the full
principle amount of the loan. So if the borrower used all of
the proceeds only for authorized expenses during what's
called the forgiveness covered period, which is 8 to 24 weeks
after the loan was disbursed, the borrower can apply for
forgiveness.
And if they used everything appropriately, they
could have the full amount of loan forgiven.
Q.
And when you say "used everything appropriately,"
can you tell -- let me withdraw that.
Is using 60 percent of funds for payroll required
in order to get loan forgiveness?
A.
Yes.
Q.
Were there other requirements as well?
A.
Again, they could only use it for eligible payroll
costs or non-payroll costs, such as mortgage interest, rent
or lease payments, and utilities. But they had to use at
least 60 percent on payroll in order to have the full loan
amount forgiven.
MR. KAUSHAL: Your Honor, may I approach the
witness?
THE COURT: Sure. And I will tell you and all
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 40 of 138
40
counsel, feel free to move around the courtroom as you like,
without asking permission from the Court.
BY MR. KAUSHAL:
Q.
Ms. Zelaya, I'm showing you what's been marked as
Government's Exhibit --
THE COURT: We're off the record for one minute.
(Off-the-record discussion, and proceedings
continued:)
THE COURT: Back on the record. Go ahead.
MR. KAUSHAL: Thank you, Your Honor.
BY MR. KAUSHAL:
Q.
Ms. Zelaya, you have in your hands an exhibit
marked Exhibit 3014. Do you recognize that?
A.
Yes, I do.
Q.
What is it?
A.
It's the Paycheck Protection Program borrower
application form.
Q.
Is this the form that was in use in 2020?
A.
Yes. This is the first version that SBA created
for this PPP program.
MR. KAUSHAL: The government moves to admit
Government's Exhibit 3014 into evidence.
MS. DURRETT: No objection, Your Honor.
THE COURT: It's admitted.
MR. MARSHALL: No objection.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 41 of 138
41
(Government's Exhibit 3014 admitted into evidence.)
BY MR. KAUSHAL:
Q.
Ms. Zelaya, I'm going to publish this document on
the screen in front of you.
I am now publishing Government's Exhibit 3014 on
the screen.
Can you see this document on the screen,
Ms. Zelaya?
A.
Yes, I can.
Q.
Okay. Is this a first page of the PPP application?
A.
Yes.
Q.
I would like to direct your attention to the top
set of -- the top box. And I'm pointing to it with my pen
here. Do you see where I'm pointing?
A.
Yes.
Q.
What is that area of the application supposed to
contain? What information goes there?
A.
At the very top, there are various check boxes for
the applicant to indicate what type of business structure it
has, whether it's a sole proprietorship, partnership,
corporation, et cetera, and the business's legal name, trade
name if it has one, and the address, taxpayer identification
number, and primary contact business phone and email address.
Q.
And going to the second set of boxes, I'm going to
zoom in a little bit more. And now I'm going to point with
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 42 of 138
42
my pen to the second set of boxes. Do you see that area that
I'm pointing to on the screen?
A.
Yes.
Q.
All right. Can you tell us what those boxes are,
Ms. Zelaya?
A.
That's information about the loan, particularly how
the applicant calculated its maximum loan amount.
The first box, the average monthly payroll is the
first factor and a critical factor in determining how much
that particular business is going to get.
And then, they get that by -- they look at how much
money they paid in payroll for their employees for either
calendar year of 2019 or the 12 months prior to the
application. They divide that by 12 to get their average
monthly payroll that they paid that prior time frame.
And then they multiply that by 2.5, and that's
their maximum loan amount. And that formula was set in the
CARES Act, in the statute.
Q.
And that's the number that goes in this box to the
right of average monthly payroll?
A.
Yes.
Q.
And then to the right of that, there is number of
employees. What's the significance of that information?
A.
That serves two purposes. The first is to show
that they don't exceed the size standard which, as I
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 43 of 138
43
mentioned, was generally not more than 500 employees for each
business. And it also is a function of that average monthly
payroll average that's in that first box. The higher the
number of the employees, the higher the number of average
monthly payroll, which means a higher loan amount.
Q.
And looking at the average monthly payroll, is this
an important piece of information for a lender in determining
whether to approve a PPP loan?
A.
It is because, again, that's a critical factor in
determining how much that particular borrower is eligible to
receive under the PPP.
Q.
And to the right of that, the times 2.5 plus
EIDL -- and let me ask you, is EIDL, the Economic Injury
Disaster Loan, whatever they're entitled to under that?
A.
Yes. If they received an Economic Injury Disaster
loan between January and April 3, when we started the PPP,
they had to refinance that within this loan, and it would be
added as well.
Q.
The times 2.5 box, is that important to the lender
in determining whether to approve the loan?
A.
Yes. Because, again, that is how they get the
maximum loan amount for that particular business.
Q.
And then finally, to the right of that, the number
of employees, is that an important piece of information to
the lender in determining whether to approve a PPP loan?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 44 of 138
44
A.
Yes.
Q.
And below that, there is something that says
purpose of the loan. Can you describe that to the jury,
please?
A.
Those are the boxes that show the authorized
purposes, payroll, lease or mortgage interest, utilities and
the other -- they are just the authorized uses. And they
would check the boxes.
Q.
Is this an important piece of information to the
lender when deciding whether to approve the loan, the purpose
of the loan?
A.
Yes.
Q.
If any of this information we just covered in this
middle area was false or inaccurate, would that fact be
important to the lender?
A.
Yes.
Q.
Would that fact be important to the SBA?
A.
Yes.
Q.
In terms of the supporting documents, we talked
about bank statements and 941s, are those supporting
documents important to the lender in deciding whether to
approve a PPP loan?
A.
Yes. Because the lender had very minimal
underwriting obligations, but one of them was to review the
supporting documentation that the applicant provided,
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 45 of 138
45
particularly to show that they had employees as of February
15 of 2020, and to document that average monthly payroll and
maximum loan amount calculation.
Q.
Going down to the next section, the applicant
ownership, that seems to be self-explanatory, right? That's
just supposed to list the owners?
A.
Yes. They were supposed to list the owners of 20
percent or more of the application -- or the business.
Q.
And the next set of items, questions 1 through 4,
can you describe to the jury what those are?
A.
Those are getting to eligibility of the applicant.
The applicant self-certifies that it is eligible for the loan
under the rules in effect at the time, but they also need to
answer these questions, such as if they are presently
debarred, suspended, or in bankruptcy, or if they or any of
their owners has had a previous SBA loan or other federal
loan that is currently delinquent or defaulted on in the last
several years. If either are answered "yes," the loan could
not be approved.
The other questions are asking about if they own
any part of any other business, and if they received an
Economic Injury Disaster Loan between January 31 and April 3
of 2020.
Q.
Going down to the next set of questions, questions
5 through 8. Very briefly, can you describe what these are
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 46 of 138
46
intended to target from the applicant?
A.
Again, they are getting to the eligibility.
Questions 5 and 6 are talking about any prior criminal
history. And again, if those are answered "yes," the loan
could not be approved.
Question 7 is important for the average monthly
payroll calculation because it is asking if the United States
is the principal place of residence for all of the employees
that the applicant included in that average monthly payroll
calculation because the CARES Act states that they could only
include in the payroll costs employees whose principal place
of residence was in the U.S. If their employees were outside
the U.S. they could not include them and could not pay them
with PPP proceeds.
Q.
I'm going to turn to the second page of the exhibit
and focus in on the top of the document.
Are you able to read that first section,
Ms. Zelaya?
A.
Yes. Those are the certifications and
authorizations provided by the applicant.
Q.
And what does that mean in terms of this
application? What is a certification and authorization for
this application?
A.
Because of the way this program was designed, it
was very streamlined and it relied heavily on
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 47 of 138
47
self-certifications by the borrower, which the lender did not
have to independently verify as they normally would in a loan
transaction.
So these were very important for the borrower to
provide to the lender.
At the top they are basically saying that the
applicant is eligible under the rules in effect at the time;
that the applicant will comply with all of the information in
the form; that all proceeds will be used only for
business-related purposes as specified in the application and
the program rules; and that they are not engaged in any
illegal activity under federal, state or local law.
Q.
And what you were just looking at, I'm not going to
ask you to go through all of it, but can you read the first
sentence of the bullet point that I'm pointing to right here?
A.
I have read the statements included in this form,
including the state your names required by law and executive
orders, and I understand them.
Q.
And going down to this bullet point, can you read
this, please?
A.
All SBA loan proceeds will be used only for
business-related purposes as specified in the loan
application and consistent with the Paycheck Protection
Program rule.
Q.
And then going down to this bullet point, the
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 48 of 138
48
second-to-last bullet point, can you read that, please?
A.
The applicant is not engaged in any activity that
is illegal under federal, state, or local law.
Q.
Now, going down there's a section that says
"certifications."
A.
Yes.
Q.
We talked about certifications and authorizations.
Can you tell me what these -- what this specific chunk of
boxes is about?
A.
These are specifically related to certifications
required by the CARES Act for the PPP. They have to initial
next to each one. And for example, the first one is: The
applicant was in operation on February 15 of 2020, and had
employees for whom it paid salaries and payroll taxes or paid
independent contractors.
Q.
And that person, the applicant, is supposed to
certify in good faith that that's true?
A.
Correct.
Q.
And you have read the first one. Going down to the
third one, can you read that to the jury, at least the first
sentence, please?
A.
The funds will be used to retain workers and
maintain payroll or make mortgage interest payments, lease
payments, and utility payments as specified under the
Paycheck Protection Program rule. I understand that if the
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 49 of 138
49
funds are knowingly used for unauthorized purposes, the
federal government may hold me legally liable such as for
charges of fraud.
Q.
And going down to the second-to-the-last
certification, can you read those two sentences?
A.
I further certify that the information provided in
this application and the information provided in all
supporting documents and forms is true and accurate in all
material respects.
I understand that knowingly making a false
statement to obtain a guaranteed loan from SBA is punishable
under the law.
Q.
Thank you.
And these certifications are completed by the
applicant; they are supposed to initial them?
A.
Correct.
Q.
Are those certifications important to the lender in
determining whether to approve the loan?
A.
Yes, they are. As I said, this program was very
streamlined in order to get the money out the door as quickly
as possible. It relied extensively on certifications made by
the borrower, and the lender was permitted to rely on those
certifications and it was not required to independently
verify.
Q.
And to follow up on that, under the CARES Act and
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 50 of 138
50
the rules implemented by the SBA, were the lenders required
to undertake any additional due diligence when they received
the application?
A.
They had minimal underwriting obligations for this
particular program. All they were required to do was review
the application to make sure that it was complete; that all
certifications were obtained; to review the supporting
documentation to show specifically that the applicant had
employees for whom it paid salaries and payroll taxes as of
February 15 of 2020; and to do a good faith review of the
supporting documentation for that average monthly payroll
calculation to determine the maximum loan amount.
Q.
And whose representations were the lender and the
SBA relying on in these applications?
A.
The applicant's.
MR. KAUSHAL: Your Honor, if I could have one
moment, please.
BY MR. KAUSHAL:
Q.
Ms. Zelaya, why was the program designed to rely on
the information from the applicant?
A.
Because of the urgency involved with the
Coronavirus-19 pandemic. The CARES Act was passed because of
all the economic hardship that businesses were suffering; all
of the orders that some businesses were closed; others had to
significant alter their operations; the stay-at-home orders.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 51 of 138
51
There was significant economic hardship going on for
businesses throughout the nation. So the CARES Act was
enacted to provide emergency relief. And again, the program
was designed to get the money out the door as quickly as
possible to give immediate relief to these businesses.
So it was streamlined to rely on
self-certifications of the borrower and not make the lender
take the additional extra steps that would be very time
consuming to independently verify that information.
MR. KAUSHAL: Nothing further, Ms. Zelaya.
Thank you.
THE COURT: Any cross?
MS. DURRETT: Your Honor, we have no questions of
this witness.
CROSS-EXAMINATION
BY MR. MARSHALL:
Q.
Good morning.
A.
Good morning.
Q.
In your last response, I think you indicated there
were no extra steps that were needed by the lender to verify
requirements that are in the certification; is that correct?
A.
They were supposed to perform a good faith review
of the application to make sure the certifications were
required -- were received, and they were required to perform
a good faith review of the supporting documentation to show
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 52 of 138
52
they had employees as of February 15 of 2020, and to support
the average monthly pay payroll. But they were not required
to independently verify that information.
Q.
So that addresses the issue of when the funds were
initially distributed, right? When they're disbursed,
correct?
A.
Correct.
Q.
Are there any ongoing responsibilities by lender to
make sure the funds had been used or obtained in a proper
way?
A.
No.
Q.
Is there anything from SBA at a later stage that
tries to follow up and confirm that the loans have been
properly obtained?
A.
At the time of forgiveness, when the applicant
applies for forgiveness, they fill out another form that
contained more certifications; that they were eligible at the
time; that they used the proceeds only for authorized
expenses; and that they again provided that to the lender.
The lender is required to perform a good faith review of that
information and then make a decision on forgiveness and
submit it to SBA.
At that time, SBA may conduct a loan review. And
at that time, we would look at whether they were eligible or
had used the proceeds. But we did not review every loan.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 53 of 138
53
Q.
So as a follow-up then, do you have a percentage of
how many loans were reviewed by SBA? Just curious.
A.
I don't have a percentage. There were over
11 million loans that were made, and there were some that
were reviewed in a random sample, and some were reviewed
based on an indicia of potential fraud. But I don't know the
actual percentage.
Q.
And that's at the stage of maybe considering
forgiveness, right?
A.
Correct. That's at the forgiveness stage.
Q.
Is there some type of review by SBA earlier on, of
the lenders and what they are doing as far as processing
these?
A.
No. The CARES Act mandated that the lenders
approved these loans under delegated authority. That means
the lender approved the loan with no prior SBA review.
Q.
Okay. And I think, earlier on in your testimony --
maybe you will remember what the line of questioning was --
it says -- I think you responded, if the application goes
through the system without errors, you generate a loan
number, correct?
A.
Correct.
Q.
You do that or a lender does that?
A.
The lender enters the information into our
electronic system, and if they enter it properly in the right
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 54 of 138
54
format, et cetera, and it goes through again without errors,
then the system, SBA system generates the loan number.
Q.
But those errors are maybe like technical, like
filling something out incorrectly?
A.
Correct. Correct.
Q.
It's not like a checking, like, a quality assurance
to see if the application is correct?
A.
No. SBA does not receive any of the applications
or supporting documents that were provided by the applicant
to the lender. Before we issue that loan number, the agency
does not get any of that information.
Q.
Okay.
MR. MARSHALL: One second, Your Honor.
Nothing further. Thank you very much.
THE COURT: Any redirect?
MR. KAUSHAL: No, Your Honor.
THE COURT: All right. Thank you, ma'am.
You can step down.
Please call your next witness and let's just start
that next witness before we take our first break.
MR. KAUSHAL: Yes, Your Honor. The government
calls Candace Hunter to the stand.
THE COURT: Off the record.
(Off-the-record discussion, and proceedings
continued:)
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 55 of 138
55
THE COURT: Back on the record.
Good morning, ma'am. How are you?
THE WITNESS: I'm well. Thank you.
CANDACE HUNTER,
Having been first duly sworn, testified as follows.
Candace Hunter.
Candace Hunter,
Having been first duly sworn, testified as follows:
DIRECT EXAMINATION
BY MR. KAUSHAL:
Q.
Good morning, Agent Hunter. Can you please state
and spell your name for the record?
A.
Yes, it's Candace A. Hunter. C-A-N-D-A-C-E, A. and
then H-U-N-T-E-R.
Q.
Where are you employed, ma'am?
A.
At the FBI here in Atlanta.
Q.
What is your role at the FBI?
A.
I'm a special agent that also has a certification
as a general forensic examiner.
Q.
And what training do you have to be a forensic
examiner?
A.
The bureau has a process of -- it takes about two
years of training, both in hardware and software pertaining
to computers, as well as different forensic tools to use to
analyze those computers.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 56 of 138
56
Q.
How long have been a computer forensic examiner?
A.
Approximately 14 years.
Q.
And do you have, what were you before that? What
did you do?
A.
I was a special agent that worked cybercrimes such
as ATM theft and skimming and crimes against children.
Q.
And now you do forensic examination work?
A.
Correct. Yes.
Q.
Were you provided with evidence from this case,
specifically a Samsung Galaxy Note 9 that's identified as
item 1B7 in FBI evidence storage?
A.
Yes, I was.
Q.
Were you able to access that Samsung Galaxy Note 9?
A.
Not initially. But yes, eventually, I was.
Q.
Did you receive the item originally around
February 18, 2021?
A.
Yes. That's correct.
Q.
And once you received it, you said you couldn't
access it initially. Why not?
A.
It was password protected.
Q.
Were you able to get through the password at some
point?
A.
Eventually, in May of 2022, approximately a year
and a couple of months later.
Q.
And once you got into, when you say -- well, tell
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 57 of 138
57
me what that means. Were you able to unlock the phone?
A.
The software that I used to extract the device was
able to access the phone and break through.
Q.
And your role in terms of that phone was to obtain
data from the phone, correct?
A.
Yes. I extracted the phone using that software.
Q.
What software did you use?
A.
I used a product called Cellebrite Premium.
Q.
What is Cellebrite Premium?
A.
It's one of the tools that the company Cellebrite
offers. They have several different products. But the
premium mainly focuses on -- well, it has iOS as well, but
Android and iOS devices cracking that are either pattern
locked or password protected or PIN protected, somehow
protected.
Q.
Did you hook up item 1B7 to Cellebrite?
A.
Yes. I did.
Q.
Can Cellebrite obtain call logs from a phone?
A.
Yes.
Q.
Can Cellebrite obtain messages from the phone?
A.
Yes.
Q.
Can you walk the jury through the process of
obtaining information using Cellebrite?
A.
Once the extraction is obtained, then I use another
Cellebrite product, called Physical Analyzer, to parse the
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 58 of 138
58
extraction. And basically what it does is sort the data or
organize the data. It's a different bucket. Like here is
all the documents, here is all the pictures, here is all the
call logs. It just organizes the data for someone to easily
review it.
Q.
And what happens after that? Once it goes into
Physical Analyzer, then what?
A.
Then I generate what we term a portable case. And
it's basically so that the end user can open the product
without having a licensed dongle to open it. So it's just a
portable case of everything that was in that extraction that
it was able to parse, and then it's for the agent to conduct
the review and go through the evidence and find what's
relevant.
Q.
Did you create a portable case for the Samsung
Galaxy Note 9 that was identified as item 1B7 in FBI
evidence?
A.
Yes, I did.
Q.
Did that portable case that was prepared contain
WhatsApp communications for that device?
A.
Yes. It did.
Q.
Can you tell the jury what WhatsApp is?
A.
It's a communication app that you can utilize to
talk to one another without using text messages. It's
another way to communicate.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 59 of 138
59
Q.
It's a text messaging application?
A.
Yes.
Q.
Can you also make phone calls using it?
A.
Yes, you can.
Q.
Can you tell -- you've had an opportunity to review
exhibits in this case, correct?
A.
Yes, I have.
Q.
Can you tell me whether Government Exhibits 2300
through 2339 and their subexhibits and Exhibits 2345 through
2350 are with WhatsApp communications that came from the
portable case that you prepared for the Samsung Galaxy
Note 9?
A.
Yes, they were.
Q.
Did you also pull call log data from the Samsung
Galaxy Note 9?
A.
Yes, I did.
Q.
And that was also in the portable case?
A.
Yes.
Q.
Can you tell me whether Government's Exhibit 2957
and 2958 are call logs that came from the Samsung Galaxy
Note 9 portable case?
A.
Yes, they were.
Q.
Now aside from examining the Samsung Galaxy Note 9,
did you also examine a Lenovo Idea laptop that was identified
as 1B8 in FBI evidence storage?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 60 of 138
60
A.
Yes, I did.
Q.
Can you walk the jury through the steps you took in
order to get data off that device?
A.
So, with a laptop, we copy or -- image is what we
confirm. But it's a forensic copy of the hard drive or hard
drives within the laptop. And then we use another product to
parse the data, similarly to Cellebrite. In this case, I
used a product called Internet Evidence Finder.
Q.
And what is Internet Evidence Finder?
A.
It's a tool, a piece of software that the vendor is
Magnet. And it parses, again, the data from the computer and
puts it into different buckets again.
So there might be a bucket for website history or a
bucket for pictures or a bucket for Word documents. So it
just organizes the data.
Q.
And were you able to pull data from the Lenovo Idea
laptop identified as 1B8?
A.
Yes, I was.
Q.
Was that data also put into a portable case?
A.
It was.
Q.
And can you tell me whether Government's Exhibits
2960, 2961, 2962, and then 2980, 2981, 2983, 2984, 2985, 2986
and 2987 all came from the portable case prepared with
Internet Evidence Finder?
A.
Yes.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 61 of 138
61
Q.
And that was all from the laptop?
A.
Yes.
Q.
And these particular documents, at the top of the
document, it says what it is, like describes the data that
has been pulled?
A.
Yes.
MR. KAUSHAL: Your Honor, if I could have one
moment, please.
(Pause.)
MR. KAUSHAL: Your Honor, nothing further from this
witness.
THE COURT: Thank you.
Any cross?
MS. WEBSTER: Thank you. Yes.
CROSS-EXAMINATION
BY MS. WEBSTER:
Q.
Good morning.
A.
Good morning.
Q.
So I represent Mr. Foster in this case. And I
requested a copy of the digital devices that you downloaded;
is that correct?
A.
Yes.
Q.
And then that includes numerous items, not just the
two that have been talked about today.
A.
Correct.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 62 of 138
62
Q.
Am I correct that it was about 11 items seized from
Darrell Thomas?
A.
That sounds about right.
Q.
Five from Jesika Blakely?
A.
Yes.
Q.
There was an iPhone from is someone named Goeffrey
Hull?
A.
Correct.
Q.
And I sent you a hard drive?
A.
Yes.
Q.
Okay. And then you loaded all those devices on the
hard drive?
A.
Yes.
Q.
And then you sent it back to me, right?
A.
Yes.
Q.
Okay. First I just want to talk about just the
nature of the materials that were seized from Jesika
Blakely's residence. They were seized on April 2 of 2021.
Does that sound correct? You might not have it in front of
you.
A.
I'm sorry. I didn't review that portion of my
report.
Q.
Okay. Would a report, reviewing your report help
you?
A.
Yes.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 63 of 138
63
MS. WEBSTER: (Hands document to witness.)
BY MS. WEBSTER:
Q.
Does that refresh your recollection?
A.
Yes. Thank you.
Q.
So the materials were seized April 22 of 2021; is
that correct?
A.
Yes.
Q.
And there was a search warrant for her home?
A.
Yes.
Q.
And that address was on West Pace's Ferry of
Atlanta, Georgia?
MR. KAUSHAL: Your Honor, I'm going to object as
outside the scope of direct. This isn't the same set of
evidence that we covered on direct.
MS. WEBSTER: Your Honor, she is the one who -- she
is the witness who downloaded the devices that were provided
in discovery, and I think I'm able to cross-examine her about
other devices to show what she received and what she did not
receive.
And I have spoken to the government about
potentially introducing evidence from the devices that I
would like to discuss with her.
So this is a way of authenticating them for the
jury.
THE COURT: Well -- but wouldn't you agree with
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 64 of 138
64
Mr. Kaushal that this is outside of the scope? It seems like
it's something a little different.
MS. WEBSTER: It is a little different, Your Honor.
But I think, otherwise, I'm going to have to submit a Touhy
letter to bring her back so that I can ask her questions
about that, which I'm happy to do, but I feel like this is a
more streamlined way of addressing it.
MR. KAUSHAL: Your Honor, if the purpose is to show
that the downloads that the agent conducted were conducted
and that they have copies of those, we don't dispute that.
So I was just concerned about talking about the
search warrant being conducted and other things that are
outside of this agent's capacity in this case.
So if the purpose is simply to authenticate that a
copy of a phone was provided, there is no objection to that
question.
MS. WEBSTER: That's the line of questioning, Your
Honor.
THE COURT: Go ahead. Sounds like the objection is
withdrawn.
MS. WEBSTER: Thank you.
BY MS. WEBSTER:
Q.
So again, the search warrant was executed at a home
on West Pace's Ferry Road in Atlanta; is that correct?
A.
I'm sorry. Can I look at the report again?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 65 of 138
65
Q.
Yes.
A.
Yes.
Q.
And you were actually on scene for that, correct?
A.
Yes. I was.
Q.
And you found her iPhone at the time?
A.
Yes.
Q.
Okay. And you extracted that at the scene?
A.
Yes.
Q.
And then you were able to provide a copy of that on
the hard drive that you sent to me, correct?
A.
Yes.
Q.
At that time, other devices were seized?
A.
Yes, ma'am.
Q.
Okay. One of those devices was an HP Pavilion
all-in-one computer?
A.
May I look again?
Q.
Yes.
A.
I don't remember. It's not in that report.
MS. WEBSTER: I'm sorry.
(Hands document to witness.)
THE WITNESS: Okay. Yes.
BY MS. WEBSTER:
Q.
Okay. So you were able to extract that and provide
a copy of that?
A.
Yes.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 66 of 138
66
Q.
And there was also a thumb drive, correct?
A.
Yes.
Q.
So you also provided a copy of that -- or able to
extract a copy of that?
A.
Yes, ma'am.
Q.
Thank you.
There were, I think, two other devices seized. A
tablet?
A.
Yes.
Q.
And you couldn't get into that one; is that right?
You can look.
A.
That's correct.
Q.
Okay. Thank you.
And you never received any other devices from
Jesika Blakely other than the ones that are referred to in
that report?
A.
Those are the only ones I have examined.
Q.
Okay. Thank you.
And then I want to talk to you about the materials
that you received from Darrell Thomas.
A.
Okay.
Q.
And so all of those devices were provided to you at
the same time; is that correct?
A.
I obtained all those items on the same today from
evidence control.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 67 of 138
67
THE COURT: Ms. Webster, let me interrupt you. I
have gotten a note that someone would like to go ahead and
take a break now. So we'll do that.
Ladies and gentlemen of the jury, you are reminded
of your instructions for breaks.
Let's all take about a 10-minute break and off the
record for one moment.
(Off-the-record discussion, and proceedings
continued:)
THE COURT: All right. Thank you.
(There was a recess at 10:32 a.m., and proceedings
continued as follows at 10:44 a.m.:)
THE COURT: Thank you. You all may be seated.
Bring in the jury, please.
(Jury enters the courtroom at 10:45 a.m.)
THE COURT: You all can be seated.
Thank you.
Ms. Webster, you can continue your
cross-examination.
MS. WEBSTER: Thank you.
BY MS. WEBSTER:
Q.
So going back to the devices that were seized from
the search warrant of Darrell Thomas's residence, you, I
think received them all in February 8 of 2021; is that
correct?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 68 of 138
68
A.
That's when I checked them out of evidence control.
Q.
And they were actually seized during the execution
of the search warrant?
A.
Yes. In August.
Q.
In August of 2021?
A.
Yes, ma'am.
Q.
Okay. At no time were you provided any subsequent
phone related to this case from Mr. Thomas?
A.
Not from Mr. Thomas, no.
Q.
Nor other any other devices, not just phones. Let
me be clear. No other computers, tablets?
A.
No.
Q.
Okay. So turning first to the phone, which was, I
believe QATO1?
A.
Yes.
Q.
And that's a number that you use internally to
refer to the item; is that correct?
A.
Correct.
Q.
So that was actually extracted on May 18 of 2022, I
believe?
A.
Yes.
Q.
Okay. And you said -- I just want to clarify some
of your testimony from direct. That was not examined because
a password was provided to you?
A.
A password was not provided to me.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 69 of 138
69
Q.
Okay. So you were able to crack into the phone,
right?
A.
Correct.
Q.
Okay. And so there was another phone seized; is
that right?
A.
There was more than one, yes.
Q.
And there, I believe, was another. It was another
Galaxy Note 5; is that correct?
A.
Yes.
Q.
And you were never able to get into that phone; is
that right?
A.
Attempts are still ongoing.
Q.
Okay. But you still have not been actually able to
get into it; is that correct?
A.
Correct.
Q.
And at some point, you were actually provided a
code for a phone; is that right?
A.
Yes.
Q.
Okay. And was that in June of 2021?
A.
I don't remember the date.
Q.
Okay. Would seeing an email refresh your
recollection?
A.
Yes.
Q.
(Hands document to witness.)
A.
Okay.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 70 of 138
70
Q.
So did you receive a password that may -- could
have been for one of Darrell Thomas's phones?
A.
Possibly, yes.
Q.
And was that actually the password?
A.
No.
Q.
I believe you discussed on direct the Lenovo laptop
that was seized, correct?
A.
Yes.
Q.
And that actually contained two hard drives; is
that right?
A.
That's correct.
Q.
And you were able to download both of those?
A.
Yes.
Q.
There was several other devices that you were
unable to extract; is that right?
A.
Yes.
Q.
Okay. And was one of those a Samsung Galaxy 520?
A.
Could I look at the report?
MS. WEBSTER: (Hands document to witness.)
A.
The Samsung Galaxy S20?
Q.
Yes.
There is another ZTE phone that you could not get
into, correct?
A.
Correct.
Q.
There was a Microsoft Surface; is that correct?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 71 of 138
71
A.
Yes.
Q.
Okay. And that was encrypted; is that right?
A.
Yes.
Q.
And were you ever able to get into that?
A.
No, ma'am.
Q.
Are efforts still ongoing?
A.
No.
Q.
Is that because you have determined you will not be
able to get into it?
A.
Correct.
Q.
Okay. There was a crypto wallet; is that right?
A.
Yes.
Q.
And then there was a thumb drive. Yes?
A.
Can I look?
Q.
Yes.
A.
Oh, yeah. I remember. Yes.
Q.
Okay. And then something called a Panasonic
Toughbook?
A.
Yes.
Q.
Okay. And you determined there was nothing
pertinent on those devices?
A.
On the Panasonic Toughbook, yes.
Q.
Okay.
A.
On the thumb drive, if I remember, it was a
Tails OS. Nothing was marked as pertinent.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 72 of 138
72
Q.
And define "pertinent" for me?
A.
Relevant to the warrant of the items that we were
allowed to seize.
Q.
Okay. Thank you.
You did not receive an iPhone; is that correct?
A.
No.
Q.
Okay. So going back to the laptop, you downloaded
a copy of that, correct?
A.
Yes, ma'am.
Q.
Okay. And when you did that, you actually
generated a report. Yes?
A.
Yes.
Q.
That's the -- that's what you were discussing on
direct. Yes?
A.
The portable case.
Q.
The portable case. Okay. And that's also labeled
an IEF report?
A.
No, ma'am. That's a different item.
Q.
Okay.
An IEF report was provided to me; is that correct?
A.
Yes.
Q.
And what is the difference between those two?
A.
So the portable case is everything that the
software parsed so that the agent can conduct the review and
decide what is relevant to the warrant.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 73 of 138
73
At that time, they give it back to me and I
generate a report, which is just the items that were tagged
as pertinent.
Q.
Okay. So who chooses the items that were
pertinent, you or the agent?
A.
The agent. Although there are times when I would
as well, but in this case it was the agent.
Q.
Okay. And the IEF report is the report on the
materials that were deemed pertinent; is that correct?
A.
Correct.
Q.
Thank you. Can you just tell me about how that's
actually produced, the format that it's turned over in?
A.
So, you mean like the file type?
Q.
Yes.
A.
I produced an HTML report.
Q.
Okay. And so there is an HTML report, and you open
it; is that right?
A.
Yes.
Q.
And it opens in an internet browser?
A.
Yes.
Q.
And then there are different things that you can
click on; is that correct?
A.
Correct.
Q.
Okay. And then those rely on the other files that
are provided for you to be able to look at that?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 74 of 138
74
A.
Yes.
Q.
You can search within that report?
A.
Yes.
Q.
Okay. You can enter in various terms that you are
interested in finding?
A.
Yes.
Q.
Okay. You can look at different parts of the
device?
A.
Yes.
Q.
Okay. Some of the examples are like web history?
A.
Yes.
Q.
Saved passwords?
A.
Yes.
Q.
Credit cards that were saved?
A.
Yes.
Q.
Files that are on the computer?
A.
Yes.
Q.
And so, when you are in each of those subsections,
that's when you can search; is that right?
A.
Yes.
Q.
Okay. And to really for it to be able to function,
you need it electronically; is that right?
A.
The report? Yes.
Q.
It's not really functional in a printed form; is
that right?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 75 of 138
75
A.
Correct.
Q.
And so I believe, last night, you were able to
review what we have marked as Defendant's Exhibit F24; is
that right?
A.
Yes.
Q.
Okay. And did that have the IEF report that you
produced on it?
A.
24 was my report, yes.
Q.
Okay.
MS. WEBSTER: Your Honor, we have this on a flash
drive, which is what she reviewed last night, and we would
move to admit as F24.
MR. KAUSHAL: Your Honor, the government objects to
the admission of F24 as confusing because it is a live
document. And by that I mean it is something that a user
would interact with on an HTML page as opposed to a printout
of that actual page. It is certainly true that you cannot
type on a computer and have the printout search for you
because it's a printed piece of paper. But the contents of
the report are static data that can be admitted for the
portions that are relevant.
And it might be helpful for Your Honor to see the
report and the way that it functions, if Your Honor would
like to take a look at it. But we don't believe it should be
admissible because it requires the user to interact with it
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 76 of 138
76
in a way that, normally, juries do not interact with
evidence.
MS. WEBSTER: Your Honor, I have provided a copy on
a flash drive to your deputy. But we have some printouts
that we are going to seek to admit as exhibits but I think
they are difficult to read, and it makes a lot more sense for
someone to be able to actually look at the full report.
And I think that it's pertinent to the jury so that
they can see the files that were on the computer. And a lot
of the information is relevant to our defense.
THE COURT: All right. I'm at a loss here because
both of you have seen this and understand it, and I haven't.
So why don't we take a minute so I can do that.
Ladies and gentlemen of the jury, I don't want to
bore you with my fumbling through sticking this flash drive
in my computer and trying to figure it out, so why don't you
go grab another cup of coffee while I figure that out.
Sorry that we're taking a break two seconds after
the other break.
(Jury withdrew from the courtroom at 10:55 a.m.)
THE COURT: And we're off the record.
(Off-the-record discussion, and proceedings
continued at 10:58 a.m.)
THE COURT: Let's go on the record.
Okay. We're back on the record. I have gotten the
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 77 of 138
77
flash drive on my computer. And we had a brief
off-the-record conversation while -- with the consent of all
parties, as Ms. Webster helped me understand what I was
looking at.
I have now looked at what's on the flash drive.
And Ms. Webster has noted that it's basically easier to see
it on the screen versus the awkward printouts.
Mr. Kaushal helped me understand the confusion
issue.
I guess I'm wondering -- I think I do have an issue
with admitting the entirety of this flash drive and
everything on it, if what we're only going to be looking at
is a handful of portions that you will print out. I think
that's problematic unless everything on this flash drive you
are wanting to get into evidence.
It just seems odd to me that if we have a flash
drive with millions of lines of data, some of which might be
relevant, some might not be relevant, and you want to talk
about just a handful of items, it would seem like the most
efficient means would be -- I don't know that there is a huge
issue with using the computer to show the screens when you
are talking with the witness, but then you just go to
particular screens that you would have printouts of so that
the jury would have that as a reference, albeit not as easy
to read.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 78 of 138
78
I think it would be confusing just to have a flash
drive sent back to the jury if it's got millions of pages of
code on it or something and you are only going to refer to
various portions.
MS. WEBSTER: Well, I think it's just -- we're
referring to -- if you see, there are, on the left-hand side
of the screen there are a number of these. We are printing
out or have printed out many of them, or A through L, at
least, of them. So it is a number of different files.
And I will just note, like, we had them printed out
a little bit so that you can see more of what was on the
printouts, but the government objected that part of the
columns were cut off and it wasn't complete.
So now I feel like we have to put it in this form
which I tried to zoom it in on the ELMO, and you can't even
see. The jury won't be able to read it.
So it's just, I think it's difficult.
We might in a position where -- I don't know what
the government thinks about this -- where maybe I could show
this during the examination if they don't -- and not send it
back with them.
MR. KAUSHAL: Your Honor, first, Your Honor, the
government agrees with the analysis about this report in its
entirety because they are not seeking to talk about
everything that's in the report.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 79 of 138
79
If you look at the left-hand side of the document,
you are going to see sections that say refined results,
documents. And then there are more items further down.
And what this does is it confuses the jury because
they have got to know what this stuff means, and then they
have got to navigate through here, and then we're saying
okay, now they're going to be allowed to search. And there
are all these entries that have been marked as pertinent. It
is confusing.
So that is why we believe the documents should be
admitted for their relevant portions as defense has prepared
with their actual exhibits.
Now the issue -- the paper exhibits.
I understand that there is a printout issue with
the exhibits. I think if they use their electronic version
of the PDF, they can zoom in and it will show up on the
screen, and that should address the issue of using the ELMO
versus using this report.
I'm just concerned about them seeing this and being
confused by it.
If push comes to shove, Your Honor, and the defense
really wants to use this report for the purpose of showing
their exhibits, I think it's also going to be confusing
because their exhibits are not just every entry that has been
identified by the agent. The exhibits that they have
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 80 of 138
80
prepared, some of them are only portions. So for example,
Ms. Webster showed Your Honor when she typed in the name
Teldrin, the parsed search queries became a shorter list from
this large list we're looking at right now. It became much
smaller. And that is -- I believe one of their exhibits is
just the Teldrin searches.
So it -- they are going to be seeing multiple forms
of these documents, and then they might become confused about
whether something is missing or not missing.
So I just think it's going to be confusing and we
suggest that they use their PDFs in order to work with the
witness. And when it's admitted, they can admit the PDFs on
a disc and then the jury will be able to look at those PDFs.
THE COURT: Okay. So, Ms. Webster, I get that it's
going to be easier to read from this, what's on the flash
drive, the document, pulling it up, and to talk to your
witness.
And I get that the printout somehow is coming out
funky and hard to read. Here is an idea that maybe satisfies
everyone.
Could you just pull up whatever page you want her
to look at here on the screen, and maybe somebody has got a
higher tech way of doing it than I do, but we're all in here
with our phones and you can take a picture of the computer
screen for the 10 pages you want to show them, print that out
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 81 of 138
81
and mark it as an exhibit.
Why doesn't that work?
MR. KAUSHAL: It potentially would work, Your
Honor. And actually, just standing here, I -- actually, and
I'll propose this.
So long as -- you know, we're well outside of what
I covered on direct, and I understand they want to talk to
this witness and that they want to get clarification on
what's in the report.
If we use the actual report as a demonstrative and
then Ms. Webster can narrate what she is doing. This is the
report, okay, it has -- this is the report; here is how it
works. You type in the name Teldrin; here is what shows up.
And then she admits her paper copies or PDF of the actual
thing she wants to use.
We do not have an objection to that because I think
that will show the jury what she wants to show them without
giving them this whole set of information and making them
think that they need to go looking around in all this stuff.
And then they will know that what is being shown to
them, it's a subset of data and things of that nature.
That seems to address the issue, if Your Honor is
open to it.
MS. WEBSTER: Your Honor, our preference is to use
the whole thing. But understanding the Court's sort of
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 82 of 138
82
disinclination to do that, I think that's an acceptable
alternative to us.
THE COURT: All right. Very well.
Let's bring out the jury.
MS. WEBSTER: Is it okay for it to be on the screen
now.
THE COURT: Sure.
Is there an exhibit number range that you want to
move to admit? Can you just give me the range of what you
are moving to admit?
MS. WEBSTER: Yes. It's F24A through L, inclusive
of the F24E1.
THE COURT: Okay.
(Jury enters the courtroom at 11:08 a.m.)
THE COURT: All right. You all can be seated.
Thank you. Okay. Ladies and gentlemen, thank you
for your patience with this process.
I was, amazingly enough, able to pull the document
up and figure it out. And the parties have agreed that what
we will do is we're going to use the electronic version to go
through this examination, the questions and answers. The
electronic version is not going to be admitted into evidence.
Instead, Ms. Webster has offered for admission hard
copy documents, F24A through L, including F24E1.
The government hasn't objected to those documents
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 83 of 138
83
and I have admitted those documents, so those hard copy
documents will go back with you for deliberations at the end
of the case.
(Defendant's Exhibits F24A through L, including
F24E1 admitted into evidence.)
THE COURT: Ms. Webster, you can continue.
MS. WEBSTER: Thank you, Your Honor.
BY MS. WEBSTER:
Q.
Ms. Hunter, the report on your screen, is that your
report?
A.
Yes, ma'am.
Q.
So, previously, did you also have the chance to
review F24A through L?
A.
Yes, I did.
Q.
Okay. So on this report, if we go to Chrome
autofill profiles, can you tell me what that means?
A.
So, when you are typing on the Chrome web browser
on the internet, and you are entering in information in
different fields, you've probably noticed it asks you "do you
want to save this?" So that the next time you go to enter
your address, when you start typing, like in this case, 670,
it doesn't make you type the whole thing; it remembers.
That's what this is showing you.
Q.
And whose name is in this Chrome autofill profile?
A.
Darrell Thomas.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 84 of 138
84
Q.
Thank you. And then if we go to the Chrome
autofill; right?
A.
Yes, ma'am.
Q.
Can you tell -- what is Chrome autofill? What is
that section?
A.
The same thing I was just discussing. Basically,
when you fill in a form, the other thing that were typed into
a Chrome web form.
Q.
What's the difference between a Chrome autofill and
autofill profile?
A.
So if it's able to associate a bunch of data with a
user, that's the profile, so it put all together. And often
you will see multiple profiles that are on the computer.
Q.
Okay. And can you just tell me what is in the
value line of this first line?
A.
Teldrin_Foster@yahoo.com.
Q.
And what is the date that it was created?
A.
May 19, 2020.
Q.
Okay. And if we go -- just for the record,
that's -- those are 24A and B.
And if we go to what I have marked as 24 -- F24C,
that's the Chrome current session?
A.
Yes, ma'am.
Q.
And can you tell me -- again, if you look in the
title column, what is -- what is reflected in the title
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 85 of 138
85
column?
A.
Teldrin_Foster@yahoo.com.
Q.
And can you tell me what dates those are there?
A.
The last visited date is June 24, 2020, at
4:39:42 p.m.
Q.
And if you go down to the ninth line and the tenth
line, what are those dates?
A.
June 30th, 2020 -- sorry, the date is 0 June 30 of
2020.
Q.
Thank you. Tell me what the Chrome current session
at the top means.
A.
So that is what tabs were open in Chrome currently,
when the computer was obtained.
Q.
If we go to Chrome web visits, which I have marked
as F24E, can you tell me what Chrome web visits means?
A.
It is -- using again the Google Chrome browser, a
visit to a particular website or URL.
Q.
And tell me again what's in the title column for
this exhibit or this page.
A.
For this page, it's Teldrin_Foster@yahoo.com.
Q.
And if I go into the search column and I type in --
this is what we were referring to -- I was referring to
earlier when you can search the items; is that correct?
A.
Yes, ma'am.
Q.
Okay. So if we type in the name Teldrin there, can
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 86 of 138
86
you tell me what comes up?
A.
The items on the screen that have the word Teldrin
in them.
Q.
Okay. So I'm just going to scroll down. And so
Teldrin is in every entry that's on this page, right?
A.
Yes.
Q.
Okay. So what is the earliest date that's shown
here in row 123?
A.
May 2 of 2020.
Q.
Okay. And then in the date visited time, above
that, is that May 19 of 2020?
A.
Yes, ma'am.
Q.
Okay. And that subset is what's reflected in
F24E1, just the results that have Teldrin in the web visits.
Does that sound correct?
A.
Yes.
Q.
Thank you.
This is what we have marked as F24F, and it has
credit card. So explain what the meaning of that is, please.
A.
If the user types in a credit card to conduct a
purchase, the browser can save that credit card information
for later use.
Q.
Okay. And whose name is listed in the top column?
A.
Darrell Thomas.
Q.
And the last column?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 87 of 138
87
A.
Julius Johnson.
Q.
And Teldrin Foster is not listed at any point in
that view; is that correct?
A.
No, ma'am.
Q.
Thank you.
If we go to identifiers device, I have marked that
as Exhibit F24G.
What is referred to in this first row?
A.
An Apple iPhone.
Q.
Okay. And you never seized an Apple iPhone from --
to your knowledge, an Apple iPhone was not seized from
Mr. Thomas's residence; is that correct?
A.
Correct.
Q.
These are Chrome downloads. This is F24H.
Do you see in these columns where it says that it's
dl.mail.ymail.com?
A.
Yes, ma'am.
Q.
Are you familiar with what that means?
A.
No, ma'am.
Q.
Okay. Do you have any knowledge of whether that
could be for Yahoo Mail?
A.
It looks like that, but I don't want to speculate.
Q.
Okay. Going back for a second. Can you tell me
what Chrome downloads means? What is that section?
A.
Anything that was downloaded using the Chrome web
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 88 of 138
88
browser to this computer.
Q.
Okay. So the download source is what?
A.
Where it was downloaded from.
Q.
Okay. And the file name section is what?
A.
What was downloaded.
Q.
Okay. So for example, in column 119, or row 119,
when it says that the file name 123F941, and then it says
Richland Property Investor Group LLC(1), that file was
downloaded from this Yahoo -- potentially, this Ymail
address; is that correct?
A.
The Ymail address, yes.
Q.
I'm sorry. Repeat that one more time?
A.
Yes. The Ymail address.
Q.
The Ymail address. Okay. And that's going to be
true for everything on this section; what is in the file name
was downloaded from the address in the download source?
A.
Correct.
Q.
Okay. Now, if we go to identifiers people. Tell
me what this means.
A.
IEF goes through the computer and looks for any
information pertaining to individuals on the drive that it
can find, that it can parse.
Q.
Okay. And can you tell me the names that are
listed in identifier in that column?
A.
Yes. Casa Mero Yofo (phonetic), Darrell Thom, DJ
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 89 of 138
89
Thomas, Gena Pyfrom, Jesika Blakely, and Malik Dixon.
Q.
And Teldrin Foster is not in this list; is that
right?
A.
That's correct.
Q.
And then when it says Gena Pyfrom, and authors, and
the last author, what does the artifact I.D. mean, and the
artifact? What are those two columns?
A.
The artifact is what it's associated with. So
these are Excel documents. The artifact I.D. is a key, I
believe, in the table to be able to link the data.
Q.
Okay. Thank you.
And so when you have an identifier linked with a
document, like an Excel document, can you tell me what that
means?
A.
Yes. So this is what's termed metadata for an
Excel document. And the Microsoft Office saves information
within the documents pertaining to that computer.
Q.
Okay. And so where it says that Gena Pyfrom is
listed as the author in row 46, and the last author on 47,
that means that she was in -- the metadata for that document
shows that she was the author and the last author for that
document; is that correct?
A.
The metadata shows that, yes.
Q.
Okay. If we go to Excel documents, this is all the
Excel documents that are on this computer; is that right?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 90 of 138
90
A.
Yes.
Q.
And if I type in "Gena" in this search column,
right, there are two results that pop up. Is that right?
A.
Yes.
Q.
And that's what's marked in the F24I; is that
right?
A.
Yes.
Q.
It's not the entire list of Excel files; it's just
the subset?
A.
Correct.
Q.
Okay. So if we scroll over -- well, first, there
is a file name for record 2, and that says 2020 January to
February, payroll report by employee; is that correct?
A.
Yes.
Q.
Okay. And that was on the file on May 8 of 2020.
Is that right?
A.
That is when it was on this computer.
Q.
And is this when it was downloaded on the computer
or the last time it was modified? What do these dates in
the -- those two columns in the middle tell us?
A.
Specifically the file system dates?
Q.
Yes.
A.
You can see the date the file was downloaded was
May 8, and you can see the file was not -- had not been
accessed or modified on that computer because the dates and
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 91 of 138
91
times are still the same as the created date.
Q.
So that means what? Say it again?
A.
That file was not modified or accessed on this
computer, as those dates and times are the same as the file
system created date when it was downloaded.
Q.
So that's the time that it was downloaded?
A.
Yes. If you want to see the date that it was last
changed, if that's what you are looking for, modified --
Q.
Um-h'm.
A.
If you scroll over.
Q.
This way?
A.
Yes, ma'am. You will see the internal metadata of
the file, and there is the modified date.
Q.
Okay. It says first that the author is Gena
Pyfrom; is that right?
A.
Yes.
Q.
In the authors column, and then she is also listed
as the last author, correct?
A.
Yes, ma'am.
Q.
And then the last printed date and time actually
pre-dates when it was on this computer; is that right?
A.
That's correct.
Q.
So that says April 24 of 2020; is that right?
A.
Yes, ma'am.
Q.
And then the second file, it has more of a generic
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 92 of 138
92
name, CE1249E0?
A.
Yes, ma'am.
Q.
And that's also an Excel spreadsheet?
A.
It is.
Q.
Okay. And that was also created on April 24 of
2020; is that right?
A.
That was the time that the file was observed on
this laptop. If you can scroll over and let me confirm that
that was the created date, I would appreciate it.
Q.
This way?
A.
Yes, ma'am. There is the date. Yes. That's the
date of creation.
Q.
Okay. Thank you.
And then if we go to the parsed search queries
heading, so that -- tell me what a parsed search query is.
What does this mean?
A.
So anything that the user searched for on a
website.
So you will see on my report there's a Google
searches, that's specifically using the Google website,
google.com. But this parsed search queries has other -- it
can be websites or other search -- so like these first ones
are Bing, and it shows what the user searched for.
Q.
And this is searching for Harvest PPP loan,
correct?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 93 of 138
93
A.
The first one, yes.
Q.
Okay. It we type in Teldrin here, we get some
results, correct?
A.
Yes, ma'am.
Q.
Okay. So do you see how it starts in the row
that's labeled 821 with a T, and 820 is TE, and 819 is TELD,
and 818 is TELDR?
A.
Yes, ma'am.
Q.
Can you tell me what that means?
A.
The user started typing TELDR, and it's taking each
one of those as a search.
Q.
Okay. And what is the URL that it then goes to?
What is the result of those searches for the beginning of
Teldrin?
A.
Teldrin_Foster@yahoo.com.
Q.
Okay. Does that look like they're actually inside
a browser and logged into his email address?
A.
Yes.
Q.
And then if we go to the date and time folder or
column, can you tell me the dates of that?
A.
June 24 of 2020.
Q.
Okay. And if we scroll down to the bottom two,
what are those dates?
A.
May 28 of 2020.
Q.
Okay. Just to be clear for the record, F24K is the
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 94 of 138
94
subset of the parsed search queries document; is that right?
A.
Yes.
Q.
And it only includes the one that contained the
Teldrin results?
A.
Yes.
Q.
Okay. And then if we go to locally accessed files
and folders, what is that?
A.
Items on the laptop that were accessed.
Q.
Okay. And if we type in Teldrin here, what pops
up?
A.
A Teldrin_Foster@yahoo.com.
Q.
And I think I'm a little bit confused because it
says locally accessed files and folder. But generally, an
email address is on an internet browse; is that right?
A.
Correct.
Q.
So why is this labeled as a file or folder? Do you
know?
A.
A user downloaded that site, that -- the screenshot
that they saw there, they actually pressed download --
Q.
Okay.
A.
-- and saved it to the computer in this downloads
directory.
Q.
Okay. So someone took a screenshot of his email
address and that was saved to the computer. Is that what you
mean?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 95 of 138
95
A.
Not specifically like hitting a screenshot, but
just hitting "save."
Q.
Okay. Thank you.
So that is in F24L that we have marked. Is that
right?
A.
Yes.
Q.
Okay. And that is also just the subset of that
document. It's not the full thing, correct?
A.
Correct.
Q.
Okay. So we talked earlier about the devices that
you were provided and the people that you were provided them
from, right? The owners of those devices; is that right?
A.
Yes, ma'am.
Q.
And that you were never provided devices from
anyone else related to this case; is that right?
A.
No, ma'am.
Q.
No, ma'am, that I'm correct or no, ma'am, that
you --
A.
I'm sorry.
Q.
You are fine.
A.
You are correct, I was not provided any additional
devices.
Q.
Thank you.
So you didn't get anything from Gena Pyfrom-Foster?
A.
No.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 96 of 138
96
Q.
You didn't get anything from Teldrin Foster?
A.
No.
Q.
And to your knowledge, no one else in your office
was given other devices to download?
A.
No.
Q.
And earlier when you said that an agent determined
what files were pertinent to include in the IEF report --
A.
Yes, ma'am.
Q.
-- which agent was that?
A.
Special Agent Joe Stites.
MS. WEBSTER: Okay. Your Honor, could I have one
second?
THE COURT: Sure.
(Pause.)
MS. WEBSTER: Your Honor, no further questions.
THE COURT: Mr. Marshall.
MR. MARSHALL: Just a couple, Your Honor.
CROSS-EXAMINATION
BY MR. MARSHALL:
Q.
Hello, Agent.
A.
Hello.
Q.
So counsel for Mr. Foster just asked you about any
other devices from some certain other individuals. Did you
ever receive any devices from Carla Jackson?
A.
No, sir.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 97 of 138
97
Q.
So you did not do any analysis of any iPhones or
cellphones or Android phones at all --
A.
From Carla?
Q.
-- from Carla Jackson?
A.
No.
Q.
Any laptops?
A.
No.
Q.
Did you receive any kind of desktop computer, any
other computer-type devices from Carla Jackson?
A.
No.
MR. MARSHALL: Nothing further.
Thank you, Judge.
THE COURT: Any redirect?
MR. KAUSHAL: Yes, Your Honor.
THE COURT: Go ahead.
MR. KAUSHAL: Ms. Webster, may I use your computer?
MS. WEBSTER: Yes. I left it up there for that
purpose.
MR. KAUSHAL: Thank you.
REDIRECT EXAMINATION
BY MR. KAUSHAL:
Q.
All right, Agent Hunter. I'm not going to go
through every item that Ms. Webster covered, but I want to
point out -- I have some questions about some of the things
that she did cover.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 98 of 138
98
Going to what I think is 24 -- F24B, which would be
the Chrome autofill.
Before I even get to that, let me ask this
question. Does any of the information that's on the IEF
report, does it tell you who is sitting behind the computer?
A.
No.
Q.
So it doesn't know whether it's me or Ms. Webster,
for example?
A.
Correct.
Q.
And if I edit a document on Ms. Webster's computer
and I sent send it somewhere, it's going to have
Ms. Webster's metadata, right?
A.
Correct.
Q.
Assuming it's an Excel document or whatever, the
stuff we were just talking about.
A.
If she put her name on that computer, yes.
Q.
And it could be someone else's name, too?
A.
It could be anything you want.
Q.
So in that same vein, the metadata that we talked
about, this author metadata that you talked about on
cross-examination, it doesn't do any sort of fingerprint scan
to confirm that that's the person who actually authored the
document, correct?
A.
Correct.
Q.
Or any other authentication process, correct?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 99 of 138
99
A.
Correct.
Q.
And is it possible to modify metadata after a
document has been created?
A.
Yes.
Q.
So somebody can change the author? There is a way
to do that?
A.
Yes.
Q.
Okay. Now let's go to the Chrome autofill. And I
will apologize because this is one of those one-button pads
that always gets me. I just can't deal with it for some
reason. I need those two buttons, so I apologize if I'm a
little slow.
Looking at Chrome autofill, which is defense
exhibit F24B, Ms. Webster asked you about this first column.
It says user name, right?
A.
Yes.
Q.
User name is not the password, is it?
A.
No.
Q.
Is there anything in the IEF report that shows that
the password for Teldrin_Foster@yahoo.com is saved on the
computer?
A.
I do not know. I would have to look at the
passwords that were saved.
Q.
Okay. Is there a spot to do that on this report?
Right here, is that the --
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 100 of 138
100
A.
Password and tokens. But keep in mind these were
only the ones that were flagged.
Q.
Okay. So looking at this information in passwords
and tokens, do you see --
A.
No.
Q.
-- the name Teldrin Foster? It's not in there, is
it?
A.
No, sir.
Q.
I am now showing you Chrome web visits, which I
think is Defense Exhibit F24E. And I just want to point out
this date visited column. When you look at these dates and
times, is it fair to say that there could be instances where
there are multiple rows that are about interactions with a
website, within seconds? For example, directing your
attention to records 493 and 492, we have -- in 492, it says
web visit to that Yahoo address at 6:22:01; right?
A.
Yes. This would be around the same time. So the
first is looking at a folder, and the second is looking at a
message within the folder.
Q.
So like every click when I go to a new page it may
generate a new URL?
A.
Yes.
Q.
So if I read five mails it may generate five
entries?
A.
Yes, sir.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 101 of 138
101
Q.
So numerous entries for a particular visit to a --
let me withdraw that.
Accessing emails could result in numerous entries
within close succession to each other?
A.
Yes. That's correct.
Q.
We talked about, on cross-examination, the credit
card from column, the credit card page. I'm going to show
that to you now.
So this is the credit card page, F24F. I'll show
these names, Darrell Thomas and Julius Johnson.
A.
Yes, sir.
Q.
I'm now going to show you another section of this
report. Let me scroll down to it.
There is something called Chrome saved credit
cards.
MS. WEBSTER: Your Honor, Mr. Kaushal did not want
to admit the entirety of the report. I don't think that
these other pages that we are looking at are the entirety of
the report admitted into evidence at this point.
MR. KAUSHAL: Your Honor, I'm using it as a
demonstrative, just as defense was permitted to use it as a
demonstrative.
THE COURT: Overruled.
BY MR. KAUSHAL:
Q.
There is a section called Chrome saved credit
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 102 of 138
102
cards, right?
A.
Yes, sir.
Q.
What is that?
A.
These are credit cards that were specifically saved
in the Chrome web browser.
Q.
And have you received this before?
A.
Yes, sir.
Q.
Have you reviewed the credit cards tab as well?
A.
Yes, sir.
Q.
So this has six entries, and credit cards,
likewise, has six entries, correct?
A.
Yes, sir.
Q.
But there is an additional column in the Chrome
saved credit cards, right?
A.
A couple of different -- a couple of additional
columns.
Q.
And there is a column that says last used
date/time, correct?
A.
Yes, sir.
Q.
What is that?
A.
The last time that credit card was used on that
laptop.
Q.
Okay. And those are all in 2018?
A.
There's one in 2019 but the remaining, yes, are in
2018.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 103 of 138
103
Q.
Thank you.
I'm now going to go to the identifiers people tab.
This is Defense Exhibit F24J.
And in here, there is a section that says column
name. Do you see that?
A.
Yes, sir.
Q.
And do you see the artifact I.D. number here as
well?
A.
Yes, sir.
Q.
Looking at artifact I.D. 2, can you tell me whether
that is the same file that's listed twice for record 46 and
47?
A.
Yes, sir.
Q.
So that says the metadata says Gena Pyfrom was the
author and also the last author?
A.
Correct.
Q.
Going back to F24H, which is Chrome downloads, and
scrolling to the right, there's something called "state." Do
you know what that means?
A.
It basically tells you whether that download was
successful or not.
Q.
Okay. And are there some instances where it might
not be successful?
A.
Yes.
Q.
Okay. For example, right here is this -- where it
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 104 of 138
104
says 4 not parsed, is that where the download was not
successful?
A.
Correct.
Q.
Okay. What does the "save to" column represent?
A.
Where it was saved on the computer and what the
file name was.
Q.
And this is kind of like you just said, it's as if
somebody went to file and then hit save while they were
looking at that HTML address?
A.
Yes, sir.
Q.
Okay. And I'm going to scroll to the left. So we
have this entry, entry 93, that deals with mail.yahoo.com.
That entry was an incomplete download, correct?
A.
Correct.
Q.
So nothing was successfully downloaded at that
time?
A.
Correct.
THE WITNESS: Can I -- I'm sorry. Can I pull that
back?
MR. KAUSHAL: Sure.
THE WITNESS: 14 bytes were downloaded, so partial.
But it was canceled by the user. That's what the 4 means.
BY MR. KAUSHAL:
Q.
Okay. So it was an unsuccessful download but 14
bytes came down?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 105 of 138
105
A.
Yes.
Q.
Thank you.
I'm going to go to F24I, which is the Excel
documents.
And there were two files that I believe were pulled
up.
A.
Yes. No. 2 and 45.
Q.
I see No. 2 right here, and 45 is right underneath
it. Right?
A.
Yes, sir.
Q.
So here is item 2. Here is item 45. I wanted to
make sure I understood. For the first item, item 2, you said
it was not modified or accessed on the computer?
A.
On this laptop.
Q.
And what's that -- what does that mean? Can you
tell -- tell me what that means in a layperson language?
A.
So the user downloaded the file but then didn't
open that Excel spreadsheet and start typing and re-save it
on that particular laptop.
Q.
And finally, let's go to 24K, which is the parsed
search queries, that's F24K.
And I believe that defense went up here and
Ms. Webster used the search item to type in Teldrin.
So looking at items A21 and up, so it's A18, A19,
A20, and A21.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 106 of 138
106
Do you see those?
A.
Yes, sir.
Q.
Are those all -- based on looking at the records,
can you tell me, was this like a search for T and then hit
enter, and then they searched for the letter T, and then they
searched for TE and hit enter? Or what -- can you describe
what this means?
A.
So you can see over on the date/time column there
that you are within a second of -- well, two of them are the
same second, and two of them are the same second, and all
four are within one second of each other.
So it's just the user typing and maybe just not
hitting enter but just taking their time typing the letters.
Q.
Is it possible for -- and Mr. Holland, you can take
down the screen.
Thank you.
Is it possible for somebody to log into their email
from somebody else's laptop?
A.
Yes.
Q.
Is it possible for somebody to edit a document on
someone else's computer?
A.
Yes.
Q.
Is there anything in the IEF report that shows who
is behind the screen typing at the time that the data that's
contained in the report was identified?
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 107 of 138
107
A.
No.
MR. KAUSHAL: If I could have a moment, please.
Nothing further. Thank you.
THE COURT: Any recross?
MS. WEBSTER: Yes, Your Honor. Just a few points.
RECROSS-EXAMINATION
BY MS. WEBSTER:
Q.
Is it correct that not all documents have metadata
associated with it?
Or let me be more specific.
Have metadata identifying the author on those
documents?
A.
Specific to Microsoft Office?
Q.
For example, the Excel documents?
A.
Okay.
Q.
Is it possible to have those documents where there
is no metadata on them?
A.
Yes.
Q.
So not all documents necessarily have the author on
them?
A.
Can I explain?
Q.
Yes?
A.
So when you install Microsoft Office products on
your computer, it's going to prompt you for your name, and
then that's where it associates it. If you choose to leave
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 108 of 138
108
that blank, then yes, it would look blank. So the data is
there but you are not seeing an author listed.
Q.
Okay. Thank you.
And I believe that Mr. Kaushal was going through
and was going through where the saved passwords that were on
this report; is that correct?
A.
Yes.
Q.
Okay. If I -- for example, I'm on Chrome and I'm
looked in to the Yahoo web browser and to your Yahoo email
address, is it necessary that that account password is saved
in order to be able to access it again?
Does that question make sense?
A.
You can retype the password.
Q.
But if it's already logged in, right, and so, let's
say I'm not using it, but then I close out that page, I
reopen it and I type in Yahoo, sometimes that account's still
logged in, right, even if the password is not saved in a
separate profile. Is that right?
A.
Yes, ma'am.
Q.
Okay. And so here -- sorry. Can we see this
again?
There is a slight delay before it comes back up.
Here we go.
So in the parsed search query section, when someone
is typing and searching, it looks like Teldrin's name,
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 109 of 138
109
correct?
A.
Yes, ma'am.
Q.
Okay. If someone is already logged in to that
email address in this browser and you just type in that name,
then you up get into the email address, right?
A.
If they are already logged in and they say "keep me
logged in," then yes.
Q.
And when you see that the URL that comes up is
actually, like, logged into the email address, that's what
that suggests is happening, isn't it?
A.
Yes.
MS. WEBSTER: Could I have one second?
THE COURT: Certainly.
(Pause.)
MS. WEBSTER: No further questions. Thank you.
MR. MARSHALL: No questions for Ms. Jackson.
MR. KAUSHAL: Your Honor, I do have some follow-up.
THE COURT: Go ahead.
REDIRECT EXAMINATION
BY MR. KAUSHAL:
Q.
Since we are now talking about hypotheticals, if
someone changed their password on their email account, would
they stay logged in on the system, on systems that they may
have been logged in on before?
A.
No.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 110 of 138
110
Q.
And you answered on recross about these URLs, these
URLs that were being accessed. This is navigating within a
logged in account, based on your understanding of what you
are looking at?
A.
It looks like it's within the
Teldrin_Foster@yahoo.com.
Q.
But this doesn't tell you whether the password was
saved or not saved, does it?
A.
It does not.
Q.
And it doesn't tell you whether the password was
typed in when these pages were accessed, before they accessed
those pages, or not, does it?
A.
It does not.
Q.
So really, you don't know from the IEF report
whether -- there is nothing in the IEF report that shows that
the password was saved, right?
A.
That's correct.
MR. KAUSHAL: Thank you.
MS. WEBSTER: Nothing further, Your Honor. Thank
you.
MR. MARSHALL: Nothing further, Judge.
THE COURT: Ma'am, you can step down.
Thank you very much.
Let's go off the record to discuss lunch.
(Off-the-record discussion, and proceedings
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 111 of 138
111
continued at 11:50 a.m.)
THE COURT: All right. You all have a great lunch.
And you are reminded of your instructions.
And, Ms. Wolff, we will go back on the record to
talk with Juror 14.
(Jury withdrew from the courtroom at 11:50 a.m.)
THE COURT: All right. Juror 14. You all can be
seated.
Thank you.
If ever I forget to have you all please sit down
when the jurors are not coming in or going, just sit down,
please. Sorry.
All right, Juror 14, I know that you shared with
Ms. Lee some updates on what's going on with the IVF. Is
that the right acronym?
THE JUROR: Yes.
THE COURT: And I think it would be best, instead
of me trying to -- and read into the record your various
texts with Ms. Lee, just to kind of tell us what the current
status of everything is because it sounds like it has changed
a little bit from during voir dire when you thought maybe you
could leave for a few hours and come back, which I was able
to accommodate.
THE JUROR: Yes, Your Honor. When I came home, my
wife gave me more information that I wasn't made aware of.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 112 of 138
112
So yeah, it's more of a process than me having to
leave for a few hours to help create the embryos.
So the egg retrieval process -- she actually --
it's is a full-on surgery where she is put under, so to
retrieve the eggs. And then after that, there is a recovery
process where she has to be attended to for the next three
and a half hours after the process. And then the next few
days is recovery process to where she can't -- they say she
can't lift anything over 20 pounds, and I have a
two-year-old.
So that's going to make it difficult for her.
THE COURT: Let me ask you, and I think we can,
again, accommodate the procedure itself, even if it turns out
that's an entire day that you are gone.
We can pause things for a day. Not ideal but we
can do it. The pausing things for a day, plus three more
days after that or so, that is a problem.
So I'm curious, are there friend or family that
could be there with her to help lift -- what's the toddler's
name? There this is going to be a more fun discussion for
the rest of us if we at least know his or her name.
THE JUROR: Yes, his name is Reid.
THE COURT: All right. So are there friends or
family that could help with Reid for those post surgery days?
THE JUROR: So, my mother-in-law could help but my
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 113 of 138
113
father-in-law, he's out of the country, so I mean, we do have
one person that can help, some, like not all the time, but --
THE COURT: Okay. All right.
Counsel, do you have any questions for Juror
No. 14?
MS. CHAIKEN: Juror 14, do you have any updated
information about when you might -- when the surgery may be?
THE JUROR: Yes. She is going for another
ultrasound tomorrow, so we should know more information then.
But yeah, I mean, the surgery could be as early as Friday or
over the weekend to probably next week. But definitely going
to happen next week, at the latest.
THE COURT: Counsel, any additional questions?
MS. WEBSTER: No, Your Honor.
THE COURT: And I know, I guess there was also a
trip that you had planned.
THE JUROR: Yes. So that's another piece of the
puzzle. So I'm supposed to go skiing in Steamboat, Colorado,
Sunday, the 19th, and when I got the court order document,
you know, a few weeks ago, it said trial starts Monday,
February 5, and allow for a two-week period. So I thought
that it would end Friday, next Friday. So I thought I would
be okay.
And I'm supposed to go on a flight Sunday, the
18th.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 114 of 138
114
THE COURT: Gotcha.
Is that flight refundable? Is your hotel
refundable?
THE JUROR: So the flight can be refundable. But
I'm not sure about the lift tickets for skiing. I don't
think -- I'm not sure if that can be refundable.
THE COURT: Okay? What about your hotel.
THE JUROR: So I'm staying with -- it's a family
trip so I'm staying with my sister, so she would still stay
in the room that we were staying in.
THE COURT: Okay. All right.
Okay. I'll discuss all this with counsel and we'll
get back with you.
Let me assure you, though, at least for the
procedure and the surgery, and if a few hours has turned into
an entire day that you need to be there, I definitively can
tell you we will make sure that happens, no matter what day
it happens. Just let us know, even if that's Sunday at
6:00 p.m. you find out it's going to be Monday, just let
Ms. Lee know. She will let me know. I'll let the rest of
the jurors and the parties know, and we won't be here Monday.
What I would like you -- well, let me just speak
with counsel about it. But what I may ask you to do is see
if we can muddle through a little bit for those post surgery
days. Maybe take some, based on your mother-in-law's
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 115 of 138
115
availability, maybe take some early court days or late court
days to accommodate that.
It's my understanding, with those procedures,
alleviating stress can be important, so we do not want to put
any undue stress on your wife.
So I think we will hopefully be able to work
through that.
I'll be blunt with you on the ski trip. I hope you
get to go on that ski trip, but I'm not going to let you out
of jury duty to go on that ski trip. I'm sorry.
THE JUROR: Understood.
THE COURT: All right. Thank you.
THE JUROR: Thank you, Your Honor.
(Juror is excused.)
THE COURT: Counsel, here are my thoughts. First
off, had I gotten this larger story when we were picking the
jury, I probably would have suggested to the parties and
asked you if you were okay relieving him for the hardship
because three hours is one thing, even a day is one thing,
but a day plus a few days after that is a whole other ball of
wax.
So obviously, we will let him be there for the
surgery, and my hope is perhaps that he will be able to have
mother-in-law coverage and it won't be a big deal post
surgery. But if it is, we may have an issue with this juror.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 116 of 138
116
Does anyone have any thoughts they want to share
with the court about how we should handle this?
MS. CHAIKEN: Your Honor, I think it would be
helpful to wait until he has more information tomorrow about
the timing of the surgery. If it ends up being towards the
end of next week, it may not end up being an issue.
I'm hesitant to lose a juror on the first day of
trial. But I do think that if the surgery ends up being over
the weekend or early next week, it may make sense to just
relieve him and bring in an alternate.
Ms. Webster? Mr. Marshall?
MS. WEBSTER: I think we agree with the government
on this, Your Honor.
MR. MARSHALL: My only concern, Judge, and I'm not
sure where this all falls in with the aftercare and
everything, is that if somehow we get to the point of actual
jury deliberations and he gets to go to deliberate and he has
got something hanging over his head, it is going to compel
him to move faster with his decision in deciding guilt or
innocence. So I'm a little concerned about the extra
pressure it could add, if it got to that point.
That's all I wanted to add, Judge.
THE COURT: Okay.
All right. My sense is this isn't a decision that
we need to make right now, but it is one that we may need to
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 117 of 138
117
make if he comes back and tells us the mother-in-law is not
available or she is only available for a couple hours a day
or something.
We'll just see where we are.
So maybe it would be my intent later to -- well,
we'll just keep getting updates from him and see how this
plays out. But it's evident to me that everyone is aware of
the situation and wants to work with this juror, and so do I.
So hopefully we will reach a good outcome.
Hope everyone enjoys their lunch.
MS. WEBSTER: I'm sorry, Your Honor. We have an
issue.
Specifically, we have been asking -- so the next
witness that the government we anticipate is doing to call is
Special Agent Stites, and they are going to introduce the
clips of our client's statement through that.
We have been asking for the clips, or what portions
of the statement they intended to introduce, for a little
while now. And so I think there was some mixup because the
government thought that they had been produced, and we did
not have them, including as late as lat night.
So they were just provided to us early this morning
and we have not, obviously, had a chance to listen to them
because we have been in trial and we haven't -- using the
internet in this building, haven't even been able to download
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 118 of 138
118
them to play them.
So I asked the government if they were able to sort
of -- I think -- I think that this witness may testify for
quite some time, and potentially into tomorrow.
And so I asked the government if it would be
willing to hold playing those exhibits until tomorrow, so
that we had time to review them and determine if we had any
objections to the portions of the statements.
And the government indicated that it could not do
that because it was sort of like playing those clips was
interspersed throughout their examination, which I
understand.
But at this point we haven't had a chance to see
them at all. There are parts that we would object to coming
in on other bases that the Court has not ruled on.
THE COURT: Let me back up. You already have the
full statements. You just didn't know exactly what parts of
though statements they were going to use?
MS. WEBSTER: Yes.
THE COURT: You have already seen everything; you
just do not know of a, let's say, of an hour video, which
five minutes they are going to want to use.
MS. WEBSTER: Well, I think there are clips A
through V.
THE COURT: I understand.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 119 of 138
119
MS. WEBSTER: But I'm saying this to address the
issue, which is, so we can go during lunch and listen to
them, but it's, like I said, it's clips A through V.
So it's going to be difficult for us to listen, I
think, to that number of clips before we have to come back
from lunch, and to determine if they include any of the parts
that we were planning on objecting to.
So at this point, we haven't had the ability to
review them.
THE COURT: Okay. How long are the clips,
Ms. Chaiken, total?
MS. CHAIKEN: I don't know the total, Your Honor.
Some are as little as 20 seconds. Some are a couple of
minutes.
THE COURT: Just ballpark it for me. Is it going
to take an hour to listen to an hour's worth of clips, or is
it going to take 10 minutes to listen to 10 minutes' worth of
clips?
MS. CHAIKEN: Less than an hour. Probably less
than 30 minutes.
THE COURT: Okay. Ms. Lee, do we have a way of
group texting the jurors to tell them our lunch is going to
be longer than we thought?
COURTROOM DEPUTY: Yes. I can do it.
THE COURT: Okay. All right.
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 120 of 138
120
Why don't we let the jurors know we are going to
have a long lunch break and to be back at 1:30. And pass on
the Court's apologies and that it's all my fault.
All right. See you all at 1:30. Take care.
Actually, let's make it -- yes, oh, just stick to
1:30.
(Lunch recess taken at 12:05 p.m.)
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 121 of 138
121
CERTIFIED STENOGRAPHIC REPORTER'S CERTIFICATE
I, Judith M. Wolff, a stenographic reporter,
Certified Realtime Reporter and 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 Wednesday, February 7,
2024, in the matter of United States of America v. Carla
Jackson and Teldrin Foster, Case No. 1:20-cr-00296-JPB-5-20;
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 8th day of February, 2024.
___________________________
/s/ Judith M. Wolff, RPR, CRR
Official Court Reporter
Wednesday, February 7, 2024 Volume 3 Morning Session
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 122 of 138
BY MR. KAUSHAL: [10] 29/17 40/3
40/11 41/2 50/18 55/10 97/21 101/24
104/23 109/20
BY MR. MARSHALL: [2] 51/16 96/19
BY MS. WEBSTER: [7] 61/16 63/2
64/22 65/22 67/21 83/8 107/7
COURTROOM DEPUTY: [1] 119/24
MR. KAUSHAL: [23] 29/12 39/23 40/10
40/21 50/16 51/10 54/16 54/21 61/7
61/10 63/12 64/8 75/13 78/22 81/3
97/14 97/16 97/19 101/20 104/20
107/2 109/17 110/18
MR. MARSHALL: [8] 17/15 40/25 54/13
96/17 97/11 109/16 110/21 116/14
MR. MOORE: [1] 3/16
MS. CHAIKEN: [5] 2/23 113/6 116/3
119/12 119/19
MS. DURRETT: [2] 40/23 51/13
MS. WEBSTER: [32] 2/20 12/2 61/14
63/1 63/15 64/3 64/17 64/21 65/19
67/20 70/19 75/10 76/3 78/5 81/24
82/5 82/11 83/7 96/11 96/15 97/17
101/16 107/5 109/12 109/15 110/19
113/14 116/12 117/11 118/19 118/23
119/1
THE COURT: [65] 2/4 2/8 2/11 2/15
2/22 3/1 3/3 3/8 11/25 29/10 39/25
40/6 40/9 40/24 51/12 54/15 54/17
54/23 55/1 61/12 63/25 64/19 67/1
67/10 67/13 67/16 76/11 76/21 76/24
80/14 82/3 82/7 82/13 82/15 83/6
96/13 96/16 97/13 97/15 101/23 107/4
109/13 109/18 110/22 111/2 111/7
111/17 112/12 112/23 113/3 113/13
113/15 114/1 114/7 114/11 115/12
115/15 116/23 118/16 118/20 118/25
119/10 119/15 119/21 119/25
THE JUROR: [10] 111/16 111/24
112/22 112/25 113/8 113/17 114/4
114/8 115/11 115/13
THE WITNESS: [4] 55/3 65/21 104/18
104/21
$
$10 [1] 15/21
$10,000 [3] 10/23 10/25 16/1
$10,560 [1] 16/3
$100,000 [1] 5/1
$145,000 [1] 27/16
$200 [1] 27/21
$250,000 [2] 5/2 21/23
$255,252.50 [1] 21/24
$300 [1] 27/21
$300,000 [2] 6/9 21/2
$335,000 [1] 9/20
$34,000 [1] 13/11
$50 [1] 8/16
$60,000 [1] 8/16
$800,000 [1] 9/4
/
/s [1] 121/23
1
1 percent [1] 36/23
10 [5] 16/4 37/21 80/25 119/17
119/17
10-minute [1] 67/6
10:32 [1] 67/11
10:44 [1] 67/12
10:45 [1] 67/15
10:55 [1] 76/20
10:58 [1] 76/23
11 [1] 62/1
11 million [1] 53/4
119 [2] 88/6 88/6
11:08 [1] 82/14
11:50 [2] 111/1 111/6
12 [2] 42/13 42/14
12-minute [1] 20/12
123 [1] 86/8
123F941 [1] 88/7
12:05 [1] 120/8
13 [3] 20/7 20/11 25/10
1317 [1] 1/24
14 [10] 5/25 11/9 56/2 104/21 104/24
111/5 111/7 111/13 113/5 113/6
15 [7] 4/7 33/24 38/3 45/2 48/13
50/10 52/1
18 [2] 56/16 68/19
18th [1] 113/25
19 [9] 4/2 30/11 30/13 30/16 30/21
31/8 50/22 84/18 86/11
1914 [1] 1/23
19th [1] 113/19
1:20-CR-00296-JPB-5-20 [2] 1/5
121/12
1:30 [3] 120/2 120/4 120/6
1B7 [3] 56/11 57/16 58/16
1B8 [2] 59/25 60/17
2
2.5 [3] 42/16 43/12 43/19
20 [6] 1/5 21/15 45/7 112/9 119/13
121/12
2018 [2] 102/23 102/25
2019 [3] 6/20 42/13 102/24
2020 [54] 3/19 3/24 4/7 5/17 9/16
9/16 9/16 9/17 9/17 9/19 13/21 14/8
16/4 20/5 20/25 20/25 21/3 21/7
21/23 22/9 23/2 25/13 25/14 25/25
26/4 27/6 30/9 30/25 32/22 32/24
33/4 33/10 33/24 35/17 37/5 38/3
40/18 45/2 45/23 48/13 50/10 52/1
84/18 85/4 85/8 85/9 86/9 86/11
90/12 90/15 91/23 92/6 93/21 93/24
2021 [6] 56/16 62/18 63/5 67/24 68/5
69/19
2022 [2] 56/23 68/19
2024 [3] 1/12 121/11 121/20
215-1317 [1] 1/24
22 [2] 23/2 63/5
2300 [1] 59/8
2339 [1] 59/9
2345 [1] 59/9
2350 [1] 59/10
24 [8] 39/7 75/8 84/21 85/4 91/23
92/5 93/21 98/1
24A [1] 84/20
24K [1] 105/20
27 [3] 25/10 30/25 32/24
28 [1] 93/24
2957 [1] 59/19
2958 [1] 59/20
2960 [1] 60/22
2961 [1] 60/22
2962 [1] 60/22
2980 [1] 60/22
2981 [1] 60/22
2983 [1] 60/22
2984 [1] 60/22
2985 [1] 60/22
2986 [1] 60/22
2987 [1] 60/23
3
30 [3] 34/24 85/8 119/20
3014 [4] 40/13 40/22 41/1 41/5
30303-3361 [1] 1/24
30th [1] 85/8
31 [3] 23/14 23/19 45/22
32 [1] 32/5
3361 [1] 1/24
4
404 [1] 1/24
45 [3] 105/7 105/8 105/11
46 [6] 22/3 22/5 23/17 29/1 89/19
103/11
47 [8] 22/3 23/3 23/15 23/16 23/17
29/1 89/19 103/12
492 [2] 100/15 100/15
493 [1] 100/15
4:39:42 p.m [1] 85/5
5
500 [2] 33/23 43/1
520 [1] 70/17
6
60 [2] 39/14 39/21
66 [1] 22/4
67 [1] 22/4
670 [1] 83/21
6:00 p.m [1] 114/19
6:22:01 [1] 100/16
7
75 [1] 1/23
8
818 [1] 93/7
819 [1] 93/6
820 [1] 93/6
821 [1] 93/6
8th [1] 121/20
9
90 [1] 1/7
93 [1] 104/12
941 [2] 38/10 38/14
941s [2] 38/13 44/20
9:01 [1] 2/2
9:06 [1] 3/2
A
a.m [10] 2/2 3/2 67/11 67/12 67/15
76/20 76/23 82/14 111/1 111/6
A18 [1] 105/24
A19 [1] 105/24
A20 [1] 105/25
A21 [2] 105/24 105/25
ability [1] 119/8
able [34] 15/21 16/23 46/17 56/13
56/21 57/1 57/3 58/12 60/16 63/17
65/9 65/23 66/3 69/1 69/10 69/13
70/12 71/4 71/9 73/25 74/21 75/2
76/7 78/16 80/13 82/18 84/11 89/10
108/11 111/22 115/6 115/23 117/25
118/2
about [87] 3/16 6/12 7/11 10/8 10/12
11/6 12/5 12/7 14/9 14/21 16/11
16/12 16/16 17/25 18/9 18/12 19/24
19/24 20/1 20/7 20/11 21/18 21/21
23/9 24/2 24/4 24/5 24/21 24/23
24/25 25/10 25/14 26/16 27/4 27/6
28/18 32/1 32/19 33/6 34/20 35/22
36/4 36/21 38/10 42/6 44/20 45/20
46/3 48/7 48/9 55/22 61/24 62/1 62/3
62/16 63/17 63/20 64/6 64/11 64/11
66/19 67/6 73/11 77/19 78/19 78/23
78/24 79/19 80/8 95/10 96/22 97/24
98/15 98/20 98/20 99/14 100/13 101/6
109/21 110/1 113/7 114/5 114/7
114/23 116/2 116/4 116/20
above [1] 86/10
accept [1] 33/4
acceptable [1] 82/1
accepting [1] 32/21
access [6] 15/3 15/18 56/13 56/19
57/3 108/11
accessed [11] 14/23 14/24 90/25 91/3
94/6 94/8 94/13 105/13 110/2 110/11
110/11
Accessing [1] 101/3
accommodate [3] 111/23 112/13 115/2
accomplished [1] 21/14
according [1] 36/9
account [16] 9/11 9/17 9/20 16/3
16/6 16/9 19/3 21/1 21/6 23/5 23/6
25/3 25/14 108/10 109/22 110/3
account's [1] 108/16
accounts [5] 11/14 15/3 15/15 15/15
15/19
accurate [2] 49/8 121/18
acronym [1] 111/15
Act [16] 3/25 30/23 30/23 30/24 31/3
32/23 35/1 35/14 36/9 42/18 46/10
48/11 49/25 50/22 51/2 53/14
activity [3] 17/20 47/12 48/2
acts [1] 35/13
actual [7] 23/7 53/7 75/17 79/12
81/10 81/14 116/16
actually [26] 5/6 5/7 10/22 21/23
122
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 123 of 138
A
actually... [22] 23/11 32/20 38/19
65/3 68/2 68/19 69/13 69/16 70/4
70/9 72/10 73/12 76/7 81/4 81/4
91/20 93/16 94/19 98/22 109/9 112/3
120/5
add [2] 116/21 116/22
added [2] 22/22 43/18
addition [2] 19/13 33/22
additional [7] 35/15 50/2 51/8 95/21
102/13 102/15 113/13
address [23] 14/25 16/25 41/22 41/23
63/10 79/17 81/22 83/21 88/10 88/11
88/13 88/14 88/16 93/17 94/14 94/24
100/16 104/9 108/10 109/4 109/5
109/9 119/1
addresses [6] 13/8 14/22 15/5 15/6
18/1 52/4
addressing [1] 64/7
administer [2] 30/15 31/1
administered [1] 31/4
administering [1] 30/21
Administration [3] 6/14 29/25 30/1
admissible [1] 75/25
admission [2] 75/14 82/23
admit [11] 8/10 8/13 8/15 8/19 40/21
75/12 76/5 80/12 82/9 82/10 101/17
admits [1] 81/14
admitted [10] 17/16 40/24 41/1 75/20
79/11 80/12 82/22 83/1 83/5 101/19
admitting [2] 13/13 77/11
advance [1] 19/18
advantage [1] 5/13
afloat [2] 4/15 5/10
after [24] 1/11 7/10 9/10 10/8 10/8
10/25 11/20 16/13 17/7 30/6 35/14
36/14 36/18 37/8 37/19 39/1 39/8
58/6 76/18 99/2 112/5 112/7 112/17
115/20
aftercare [1] 116/15
again [25] 3/9 19/4 24/6 27/11 28/20
39/18 43/9 43/21 46/2 46/4 51/3
52/19 54/1 60/11 60/12 64/23 64/25
65/16 84/24 85/16 85/18 91/2 108/11
108/21 112/13
against [3] 18/24 25/1 56/6
agency [4] 30/2 32/5 34/19 54/10
agent [23] 2/24 16/13 18/16 20/14
20/15 26/20 27/5 55/11 55/18 56/5
58/12 64/9 72/24 73/5 73/6 73/7
79/25 96/6 96/9 96/10 96/20 97/22
117/15
agent's [1] 64/13
agents [9] 10/8 10/10 10/12 14/14
16/17 19/15 19/21 20/3 20/5
ago [1] 113/20
agree [2] 63/25 116/12
agreed [3] 15/25 38/23 82/19
agrees [1] 78/23
ahead [6] 3/14 40/9 64/19 67/2 97/15
109/18
AI [1] 1/18
Aid [1] 30/22
Alabama [2] 26/7 26/9
albeit [1] 77/24
all [93] 2/4 2/18 3/3 3/3 3/8 6/20
8/5 9/19 10/21 15/7 18/2 18/3 18/7
18/19 19/12 22/2 22/8 22/13 24/4
25/3 29/10 31/22 31/25 32/8 36/8
36/23 37/3 39/5 39/25 42/4 46/8 47/8
47/9 47/14 47/21 49/7 49/8 50/5 50/6
50/23 50/23 54/17 58/3 58/3 58/3
60/23 61/1 62/11 65/15 66/22 66/24
67/6 67/10 67/13 67/16 67/24 76/11
77/2 79/8 80/23 81/19 82/3 82/15
82/15 84/12 89/24 97/2 97/22 102/23
106/3 106/10 107/8 107/19 111/2
111/2 111/7 111/7 111/10 111/13
112/23 113/2 113/3 114/11 114/12
115/12 116/15 116/22 116/24 118/14
119/25 120/3 120/4 120/4
allegations [1] 20/18
alleged [2] 10/19 23/7
allegedly [1] 19/10
alleging [1] 27/24
alleviating [1] 115/4
allow [1] 113/21
allowed [3] 11/4 72/3 79/7
almost [1] 25/20
along [1] 22/13
already [7] 23/10 38/18 108/14 109/3
109/6 118/16 118/20
also [38] 6/16 8/9 9/5 11/11 13/19
15/7 15/10 15/25 17/10 20/22 24/10
25/7 25/16 25/24 26/14 34/8 35/9
38/3 39/1 43/2 45/13 55/18 59/3
59/14 59/17 59/24 60/19 66/1 66/3
72/16 79/23 83/12 91/17 92/3 92/5
95/7 103/15 113/15
alter [1] 50/25
alternate [1] 116/10
alternative [1] 82/2
although [2] 12/25 73/6
always [4] 12/5 12/12 35/20 99/10
am [6] 1/5 32/5 32/10 41/5 62/1
100/9
amazingly [1] 82/18
AMERICA [3] 1/4 16/6 121/11
amount [14] 4/24 20/25 21/6 21/12
38/5 39/5 39/11 39/22 42/7 42/17
43/5 43/22 45/3 50/12
analysis [5] 17/24 17/25 18/14 78/23
97/1
analyze [1] 55/25
Analyzer [2] 57/25 58/7
Android [2] 57/13 97/2
André [3] 23/11 24/9 26/12
Ann [1] 1/19
announced [3] 7/10 7/13 32/25
another [18] 10/24 15/16 23/8 25/22
27/3 52/16 57/24 58/24 58/25 60/6
69/4 69/7 69/7 70/22 76/17 101/12
113/8 113/17
answer [1] 45/14
answered [3] 45/18 46/4 110/1
answers [1] 82/21
anticipate [1] 117/14
any [60] 1/13 15/18 15/19 17/17
17/17 17/18 17/20 18/10 18/10 18/14
18/15 18/18 19/19 21/11 25/11 25/20
27/1 29/2 29/3 37/10 44/13 45/15
45/21 45/21 46/3 47/11 48/2 50/2
51/12 52/8 54/8 54/11 54/15 61/13
66/14 68/7 68/10 87/2 87/20 88/20
95/21 96/22 96/24 97/1 97/1 97/6
97/8 97/8 97/13 98/4 98/21 98/25
107/4 113/4 113/6 113/13 115/5 116/1
118/7 119/6
anybody [1] 18/9
anyone [3] 2/13 95/15 116/1
anything [16] 10/5 10/12 15/23 18/10
18/21 21/5 21/18 52/12 87/25 92/17
95/24 96/1 98/18 99/19 106/23 112/9
anywhere [2] 20/3 33/10
apologies [1] 120/3
apologize [2] 99/9 99/11
app [1] 58/23
Appearances [1] 1/15
Apple [3] 87/9 87/10 87/11
applicant [24] 33/8 35/25 36/7 37/25
38/1 41/19 42/7 44/25 45/4 45/11
45/12 46/1 46/9 46/20 47/7 47/8 48/2
48/13 48/16 49/15 50/8 50/20 52/15
54/9
applicant's [1] 50/15
application [25] 31/22 33/11 35/23
36/11 36/14 36/15 37/23 38/8 38/13
40/17 41/10 41/16 42/14 45/8 46/22
46/23 47/10 47/23 49/7 50/3 50/6
51/23 53/19 54/7 59/1
applications [11] 4/23 5/5 6/1 7/19
7/21 7/25 11/9 32/22 33/4 50/14 54/8
applies [1] 52/16
apply [6] 4/4 13/9 28/9 33/8 36/7
39/8
applying [1] 35/25
appreciate [1] 92/9
appreciated [1] 3/11
approach [1] 39/23
approached [1] 20/3
appropriately [2] 39/10 39/12
approve [9] 33/13 36/9 36/15 43/8
43/20 43/25 44/10 44/22 49/18
approved [8] 4/5 4/9 38/17 38/18
45/19 46/5 53/15 53/16
approximately [4] 21/23 30/9 56/2
56/23
April [13] 5/16 9/16 14/8 32/22 33/3
33/4 33/10 43/16 45/22 62/18 63/5
91/23 92/5
are [151]
area [3] 41/16 42/1 44/14
argue [1] 19/6
around [12] 5/16 5/19 6/10 8/24 9/15
11/13 12/9 27/15 40/1 56/15 81/19
100/17
artifact [6] 89/6 89/7 89/8 89/9
103/7 103/10
aside [2] 18/5 59/23
ask [11] 2/15 11/17 11/21 16/15
28/22 43/13 47/14 64/5 98/3 112/12
114/23
asked [9] 4/21 14/15 19/23 31/24
96/22 99/14 115/18 118/2 118/5
asking [7] 16/17 17/9 40/2 45/20
46/7 117/13 117/17
asks [1] 83/19
aspects [1] 32/8
assistance [7] 3/23 4/1 4/2 30/4
30/5 30/6 30/6
associate [1] 84/11
associated [3] 14/22 89/8 107/9
associates [1] 107/25
Assuming [1] 98/14
assurance [1] 54/6
assure [1] 114/14
ATLANTA [6] 1/2 1/24 55/16 63/11
64/24 121/7
ATM [1] 56/6
attached [1] 1/9
attaching [1] 1/12
attempt [1] 18/18
attempts [2] 11/19 69/12
attended [1] 112/6
attention [2] 41/12 100/15
attorney [5] 19/20 20/6 20/10 32/6
32/10
audio [1] 19/14
August [2] 68/4 68/5
authenticate [1] 64/14
authenticating [1] 63/23
authentication [1] 98/25
author [14] 89/6 89/19 89/19 89/21
89/21 91/14 91/18 98/20 99/5 103/15
103/15 107/11 107/19 108/2
authored [1] 98/22
authority [1] 53/15
authorization [1] 46/22
authorizations [2] 46/20 48/7
authorized [7] 16/8 34/4 34/6 39/6
44/5 44/7 52/18
authors [2] 89/5 91/17
auto [1] 10/24
autofill [9] 83/16 83/24 84/2 84/4
84/9 84/10 98/2 99/8 99/13
availability [1] 115/1
available [3] 35/7 117/2 117/2
average [16] 4/22 4/25 5/1 38/4 42/8
42/14 42/20 43/2 43/3 43/4 43/6 45/2
46/6 46/9 50/11 52/2
aware [3] 16/17 111/25 117/7
awkward [1] 77/7
B
Babasijibomi [1] 1/17
back [33] 2/16 3/8 3/19 4/11 13/24
25/6 30/9 32/3 33/10 37/20 38/23
40/9 55/1 62/14 64/5 67/22 72/7 73/1
76/25 78/2 78/21 83/2 87/23 103/17
104/19 108/22 111/4 111/22 114/13
117/1 118/16 119/5 120/2
back-story [1] 25/6
background [1] 27/9
balance [1] 21/2
balances [4] 21/1 21/2 27/12 27/21
ball [1] 115/20
ballpark [1] 119/15
bank [15] 9/17 11/10 16/3 16/6 20/24
21/6 22/9 23/5 23/6 23/8 25/3 25/13
123
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 124 of 138
B
bank... [3] 33/16 38/6 44/20
banking [1] 19/3
bankruptcy [1] 45/15
banks [2] 27/12 36/5
barber [1] 14/20
based [4] 53/6 106/3 110/3 114/25
bases [1] 118/15
basic [1] 35/16
basically [9] 20/11 22/11 26/18 47/6
58/1 58/9 77/6 84/6 103/20
basis [2] 27/17 38/16
be [118] 1/5 1/6 2/6 2/9 2/24 3/3
4/10 4/13 5/20 6/5 6/6 6/11 9/9
10/13 13/15 13/16 14/17 15/21 16/23
17/22 18/6 18/8 18/11 19/6 21/3 22/6
24/18 24/19 26/19 28/12 28/16 33/22
33/24 34/4 34/5 34/23 34/24 35/2
36/5 36/12 37/24 38/12 43/17 44/14
44/17 45/5 45/19 46/5 47/9 47/21
48/22 51/8 55/20 60/13 67/13 67/16
68/11 71/8 73/25 74/21 75/20 75/22
75/24 76/7 77/12 77/17 77/18 77/20
78/1 78/16 79/7 79/10 79/23 80/7
80/10 80/13 80/15 82/5 82/15 82/22
87/21 88/14 89/10 92/22 93/25 98/1
98/17 98/18 100/12 100/17 103/23
107/10 108/11 111/7 111/17 112/6
112/19 112/20 113/7 113/10 113/23
114/4 114/6 114/16 114/19 114/21
115/4 115/6 115/8 115/22 115/23
115/24 116/3 117/5 118/5 119/4
119/23 120/2
became [2] 80/3 80/4
because [42] 8/4 9/7 17/6 18/20 22/8
22/12 23/21 24/4 24/21 25/17 28/8
29/3 29/8 33/9 34/24 37/17 43/9
43/21 44/23 46/7 46/10 46/24 50/21
50/22 68/23 71/8 75/14 75/19 75/25
76/11 78/24 79/4 79/24 81/16 90/25
94/12 99/9 111/20 115/19 117/19
117/24 118/10
become [1] 80/8
been [31] 10/1 10/3 17/25 20/3 22/20
27/15 29/15 32/5 32/6 33/9 39/1 40/4
52/9 52/13 55/5 55/8 56/1 61/5 61/24
69/13 70/2 79/8 79/24 90/24 99/3
109/24 117/13 117/17 117/20 117/24
117/25
before [20] 1/11 4/7 4/7 7/8 8/8
12/17 13/21 26/24 27/8 31/12 33/3
54/10 54/20 56/3 98/3 102/6 108/22
109/24 110/11 119/5
began [4] 7/9 8/8 14/7 32/21
beginning [2] 33/4 93/13
behind [2] 98/5 106/24
being [11] 3/10 3/10 13/13 32/12
64/12 79/19 81/20 110/2 116/5 116/6
116/8
believe [17] 12/15 13/19 24/23 29/6
38/15 68/14 68/20 69/7 70/6 75/2
75/24 79/10 80/5 89/10 105/5 105/22
108/4
believed [1] 17/5
Bellator [2] 14/10 15/16
below [2] 5/23 44/2
benefits [1] 34/8
besides [1] 24/14
best [1] 111/17
between [6] 18/9 20/14 43/16 45/22
72/22 84/9
beyond [3] 11/23 28/17 28/24
big [1] 115/24
Bing [1] 92/23
bit [13] 12/22 21/21 24/2 25/15
27/15 33/6 35/22 35/24 41/25 78/11
94/12 111/21 114/24
bits [1] 16/18
Blakely [3] 62/4 66/15 89/1
Blakely's [1] 62/18
blank [2] 108/1 108/1
blunt [1] 115/8
boost [1] 24/15
bore [1] 76/15
born [1] 25/21
borrower [15] 31/23 33/17 35/25
36/25 37/14 37/22 38/23 39/5 39/8
40/16 43/10 47/1 47/4 49/22 51/7
both [13] 8/16 11/7 11/17 11/22
11/22 15/3 28/5 28/6 32/7 35/8 55/23
70/12 76/12
bottom [1] 93/22
BOULEE [1] 1/11
box [5] 41/13 42/8 42/19 43/3 43/19
boxes [7] 41/18 41/24 42/1 42/4 44/5
44/8 48/9
branch [1] 22/9
break [8] 35/23 54/20 57/3 67/3 67/6
76/18 76/19 120/2
breaks [1] 67/5
brief [1] 77/1
briefly [2] 31/9 45/25
bring [5] 2/12 64/5 67/14 82/4
116/10
brokers [2] 15/9 15/10
brought [1] 8/3
browse [1] 94/14
browser [9] 73/19 83/17 85/16 86/21
88/1 93/17 102/5 108/9 109/4
bucket [4] 58/2 60/13 60/14 60/14
buckets [1] 60/12
build [1] 27/20
building [2] 34/10 117/25
bullet [4] 47/15 47/19 47/25 48/1
bunch [1] 84/11
bureau [1] 55/22
business [45] 4/16 4/25 6/5 6/6 6/14
7/8 7/20 7/22 7/23 8/5 8/24 9/3 9/14
9/24 10/1 10/3 15/14 17/19 19/3 19/4
20/23 21/11 22/10 26/4 26/6 27/19
29/4 29/25 30/1 30/5 32/8 33/24
34/10 34/11 35/16 36/21 41/19 41/23
42/10 43/2 43/22 45/8 45/21 47/10
47/22
business's [2] 4/25 41/21
business-related [2] 47/10 47/22
businesses [23] 3/21 3/23 4/1 4/4
4/6 4/9 4/10 4/14 4/15 4/21 5/6 5/18
6/19 7/25 8/2 27/11 30/3 31/11 38/16
50/23 50/24 51/2 51/5
businesswoman [1] 21/14
button [1] 99/9
buttons [1] 99/11
bytes [2] 104/21 104/25
C
C-A-N-D-A-C-E [1] 55/13
calculated [1] 42/7
calculation [5] 38/4 45/3 46/7 46/10
50/12
calendar [1] 42/13
call [10] 19/14 19/18 24/14 29/11
54/19 57/18 58/4 59/14 59/20 117/14
called [17] 2/2 3/25 4/3 8/25 14/10
15/16 22/15 28/7 37/18 39/7 57/8
57/25 60/8 71/17 101/14 101/25
103/18
calls [4] 7/16 29/12 54/22 59/3
came [13] 7/18 16/13 17/3 17/18
17/20 21/12 25/12 26/4 59/10 59/20
60/23 104/25 111/24
can [107] 3/3 28/12 29/20 31/9 32/4
32/14 33/5 37/1 38/6 39/8 39/13 41/7
41/9 42/4 44/3 45/10 45/25 47/14
47/19 48/1 48/8 48/20 49/5 54/18
55/11 57/18 57/20 57/22 58/9 58/22
58/23 59/3 59/4 59/5 59/8 59/19 60/2
60/21 64/5 64/25 66/11 67/16 67/18
71/14 72/24 73/11 73/21 74/2 74/4
74/7 74/19 75/20 76/9 76/13 78/11
79/16 80/12 80/24 81/11 82/9 82/15
83/6 83/16 84/4 84/14 84/24 85/3
85/15 85/23 85/25 86/21 87/23 88/22
88/22 88/23 89/13 90/23 90/24 92/8
92/22 93/9 93/20 99/5 103/10 104/18
104/18 105/15 106/4 106/6 106/8
106/14 107/21 108/13 108/20 110/22
111/7 112/12 112/15 112/16 113/2
114/4 114/6 114/16 114/24 115/4
119/2 119/24
can't [5] 12/19 78/15 99/10 112/8
112/9
canceled [1] 104/22
Candace [5] 54/22 55/4 55/6 55/7
55/13
cannot [1] 75/17
capacity [1] 64/13
card [7] 86/19 86/20 86/21 101/7
101/7 101/9 102/21
cards [7] 74/14 101/15 102/1 102/4
102/8 102/10 102/14
care [1] 120/4
carefully [2] 16/16 28/11
CARES [15] 3/25 30/23 30/24 31/3
32/23 35/1 35/14 36/9 42/18 46/10
48/11 49/25 50/22 51/2 53/14
CARLA [29] 1/6 3/17 6/9 8/22 9/12
9/13 9/25 10/2 10/4 10/7 11/5 11/14
17/16 18/9 18/11 18/15 24/19 25/7
25/18 25/21 25/24 26/3 26/8 26/25
96/24 97/3 97/4 97/9 121/11
Cars [1] 15/22
Casa [1] 88/25
case [43] 2/24 3/16 6/17 6/19 6/20
8/9 12/21 17/10 17/22 19/15 21/13
22/13 23/14 24/12 24/15 24/24 25/25
27/23 28/5 29/6 56/9 58/8 58/11
58/15 58/19 59/6 59/11 59/17 59/21
60/7 60/19 60/23 61/19 64/13 68/8
72/15 72/16 72/23 73/7 83/3 83/21
95/15 121/12
CE1249E0 [1] 92/1
Cellebrite [9] 57/8 57/9 57/10 57/16
57/18 57/20 57/23 57/25 60/7
cellphones [1] 97/2
certain [5] 22/22 33/14 33/22 36/20
96/23
certainly [2] 75/17 109/13
CERTIFICATE [1] 121/2
certification [4] 46/22 49/5 51/21
55/18
certifications [14] 36/24 46/19 47/1
48/5 48/7 48/10 49/14 49/17 49/21
49/23 50/7 51/7 51/23 52/17
Certified [3] 1/19 121/2 121/5
certifies [1] 45/12
certify [4] 4/22 48/17 49/6 121/7
cetera [3] 34/8 41/21 54/1
Chaiken [2] 1/16 119/11
chance [3] 83/12 117/23 118/13
change [2] 35/18 99/5
changed [4] 35/11 91/8 109/22 111/20
changes [2] 34/20 35/15
charge [2] 6/15 26/19
charged [13] 11/10 11/11 11/14 11/23
13/3 16/2 22/2 22/3 22/21 23/15
23/16 23/17 23/22
charges [6] 11/7 11/15 22/22 24/25
29/8 49/3
cheated [1] 13/22
check [8] 9/22 9/23 10/25 13/11
22/10 26/11 41/18 44/8
checked [1] 68/1
checking [1] 54/6
checks [3] 8/16 10/23 25/13
children [3] 25/11 25/21 56/6
choose [1] 107/25
chooses [1] 73/4
Chrome [26] 83/15 83/17 83/24 84/1
84/4 84/8 84/9 84/22 85/10 85/12
85/14 85/15 85/16 87/14 87/24 87/25
98/2 99/8 99/13 100/9 101/14 101/25
102/5 102/13 103/17 108/8
chronological [1] 25/15
chunk [1] 48/8
cite [1] 1/9
claimed [3] 5/7 5/8 10/18
clarification [1] 81/8
clarify [1] 68/22
clear [2] 68/11 93/25
clearly [1] 12/5
click [2] 73/22 100/20
client [5] 20/6 22/2 23/22 23/23
27/25
client's [1] 117/16
clips [9] 117/16 117/17 118/10
118/23 119/3 119/5 119/10 119/16
119/18
close [3] 3/21 101/4 108/15
124
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 125 of 138
C
closed [1] 50/24
closely [1] 17/9
club [1] 14/20
CM [2] 1/5 1/6
CM/ECF [2] 1/5 1/6
code [2] 69/17 78/3
codefendant [1] 24/3
codefendants [1] 23/13
coffee [1] 76/17
colloquially [2] 31/17 37/16
Colorado [1] 113/18
column [19] 84/25 85/1 85/18 85/21
86/23 86/25 88/6 88/24 90/2 91/17
93/20 99/14 100/11 101/7 102/13
102/17 103/4 104/4 106/8
columns [5] 78/13 87/15 89/7 90/20
102/16
come [5] 19/10 24/17 38/19 111/22
119/5
comedy [1] 16/18
comes [6] 38/20 79/21 86/1 108/22
109/8 117/1
coming [4] 32/17 80/18 111/11 118/14
commit [2] 11/10 14/12
committed [3] 27/25 28/1 29/8
committing [1] 6/24
communicate [1] 58/25
communicated [2] 7/14 16/11
communication [3] 16/12 18/9 58/23
communications [2] 58/20 59/10
companies [2] 15/16 21/16
company [6] 8/12 10/25 14/9 15/16
20/24 57/10
compel [1] 116/18
complete [2] 50/6 78/13
completed [1] 49/14
comply [1] 47/8
computer [37] 14/24 14/25 17/24 56/1
60/11 65/15 74/16 75/18 76/9 76/16
77/1 77/21 80/24 84/13 85/13 88/1
88/20 89/17 89/25 90/17 90/18 90/25
91/4 91/21 94/21 94/24 97/8 97/9
97/16 98/5 98/10 98/16 99/21 104/5
105/13 106/21 107/24
computer-type [1] 97/9
computers [5] 18/15 18/18 55/24
55/25 68/11
conceal [2] 9/12 17/19
concern [1] 116/14
concerned [3] 64/11 79/19 116/20
conduct [5] 36/14 52/23 58/12 72/24
86/20
conducted [4] 6/25 64/9 64/9 64/12
confirm [4] 52/13 60/5 92/8 98/22
confused [3] 79/20 80/8 94/12
confuses [1] 79/4
confusing [5] 75/14 78/1 79/9 79/23
80/10
confusion [2] 16/24 77/8
Congress [1] 3/24
connection [3] 37/23 38/21 121/14
consent [1] 77/2
considering [2] 26/10 53/8
consist [1] 19/2
consistent [2] 11/21 47/23
conspiracy [1] 11/10
constitutes [1] 38/7
consult [1] 20/6
consultant [1] 27/18
consulting [3] 9/23 10/1 26/11
consuming [1] 51/9
contact [4] 19/20 36/1 36/21 41/23
contain [3] 35/4 41/17 58/19
contained [5] 13/8 52/17 70/9 94/3
106/25
contents [1] 75/19
context [1] 25/15
continue [2] 67/18 83/6
continued [7] 3/7 40/8 54/25 67/9
67/12 76/23 111/1
contracting [1] 30/6
contractors [2] 34/2 48/15
contradict [1] 24/22
control [2] 66/25 68/1
controlled [1] 10/25
conversation [2] 20/10 77/2
conviction [1] 13/4
copies [2] 64/10 81/14
copy [14] 22/1 22/15 60/4 60/5 61/20
64/15 65/9 65/24 66/3 66/4 72/8 76/3
82/24 83/1
Coronavirus [3] 30/11 30/22 50/22
Coronavirus-19 [2] 30/11 50/22
corporation [2] 21/15 41/21
correct [93] 30/13 36/1 36/2 36/12
36/13 36/16 36/17 48/18 49/16 51/21
52/6 52/7 53/10 53/21 53/22 54/5
54/5 54/7 56/8 56/17 57/5 59/6 61/21
61/25 62/1 62/8 62/19 63/6 64/24
65/3 65/10 66/1 66/12 66/23 67/25
68/17 68/18 69/3 69/8 69/14 69/15
70/7 70/11 70/23 70/24 70/25 71/10
72/5 72/8 72/20 73/9 73/10 73/22
73/23 75/1 85/23 86/15 87/3 87/12
87/13 88/10 88/17 89/4 89/22 90/10
90/13 91/18 91/22 92/25 93/3 94/15
95/8 95/9 95/17 95/21 98/9 98/13
98/23 98/24 98/25 99/1 101/5 102/11
102/18 103/16 104/3 104/13 104/14
104/17 107/8 108/6 109/1 110/17
Corrections [1] 17/8
costs [5] 34/6 34/8 39/19 39/19
46/11
could [43] 4/4 4/10 5/1 5/4 9/25
10/2 10/20 10/21 26/6 34/4 34/5
34/12 36/5 38/12 39/11 39/18 45/18
46/5 46/10 46/13 46/13 50/16 61/7
70/1 70/18 70/22 78/19 80/21 87/21
96/11 98/17 98/18 100/12 101/3 107/2
109/12 111/22 112/19 112/24 112/25
113/10 116/21 118/9
couldn't [3] 10/11 56/18 66/10
counsel [10] 3/14 29/10 32/6 40/1
96/22 113/4 113/13 114/12 114/23
115/15
count [8] 13/4 16/2 22/3 22/5 22/10
23/3 23/15 23/19
country [2] 3/20 113/1
counts [12] 22/1 22/2 22/3 23/15
23/16 23/17 23/17 23/18 23/22 23/24
28/25 29/1
couple [6] 56/24 96/17 102/15 102/15
117/2 119/13
court [20] 1/6 1/11 1/13 1/17 1/19
1/1 1/11 1/22 1/22 2/2 40/2 113/19
115/1 115/1 116/2 118/15 121/5 121/6
121/10 121/24
Court's [2] 81/25 120/3
Courthouse [1] 1/23
courtroom [7] 2/25 3/2 40/1 67/15
76/20 82/14 111/6
cousin [2] 24/6 24/9
cousins [1] 23/12
cover [2] 11/19 97/25
coverage [1] 115/24
covered [6] 38/18 39/7 44/13 63/14
81/7 97/23
coverup [1] 7/5
COVID [7] 3/19 4/2 7/8 30/13 30/16
30/21 31/8
COVID-19 [5] 4/2 30/13 30/16 30/21
31/8
cr [2] 1/5 121/12
crack [1] 69/1
cracking [1] 57/13
create [3] 31/3 58/15 112/2
created [9] 7/17 8/1 40/19 84/17
91/1 91/5 92/5 92/9 99/3
creating [1] 5/25
creation [1] 92/12
credit [15] 36/5 74/14 86/19 86/20
86/21 101/6 101/7 101/9 101/14
101/25 102/4 102/8 102/10 102/14
102/21
crime [3] 11/23 17/16 29/8
crimes [4] 13/3 27/25 28/1 56/6
criminal [1] 46/3
crisis [2] 3/18 5/13
critical [3] 19/9 42/9 43/9
Cromer [1] 20/15
cross [9] 51/12 51/15 61/13 61/15
63/17 67/19 96/18 98/21 101/6
cross-examination [6] 51/15 61/15
67/19 96/18 98/21 101/6
cross-examine [1] 63/17
CRR [2] 1/22 121/23
crush [1] 25/20
crypto [1] 71/11
cup [1] 76/17
curious [2] 53/2 112/18
current [4] 32/9 84/22 85/10 111/19
currently [2] 45/17 85/12
cut [1] 78/13
cybercrimes [1] 56/5
D
damaging [1] 25/23
Darrell [40] 5/17 5/22 6/3 7/7 7/11
7/14 7/24 8/8 8/11 8/12 8/15 8/20
13/5 13/10 13/20 13/22 13/24 14/7
14/9 14/11 14/12 14/23 15/8 15/20
15/25 16/7 16/10 17/2 17/6 24/10
24/11 27/3 62/2 66/20 67/23 70/2
83/25 86/24 88/25 101/10
data [19] 57/5 58/1 58/2 58/4 59/14
60/3 60/7 60/11 60/15 60/16 60/19
61/4 75/20 77/17 81/21 84/11 89/10
106/24 108/1
date [20] 34/24 69/20 84/17 85/4
85/8 86/7 86/10 90/23 91/1 91/5 91/7
91/13 91/20 92/9 92/11 92/12 93/19
100/11 102/18 106/8
date/time [2] 102/18 106/8
dates [10] 85/3 85/7 90/19 90/21
90/25 91/4 91/21 93/20 93/23 100/11
David [1] 1/18
day [14] 7/13 7/14 7/15 12/9 112/14
112/15 112/16 114/16 114/17 115/19
115/20 116/7 117/2 121/20
days [10] 1/7 34/24 37/21 112/8
112/17 112/24 114/25 115/1 115/2
115/20
deal [2] 99/10 115/24
deals [1] 104/12
debarred [1] 45/15
decide [2] 14/18 72/25
deciding [3] 44/10 44/21 116/19
decision [6] 3/17 33/13 36/9 52/21
116/19 116/24
declared [1] 30/11
deemed [1] 73/9
defaulted [1] 45/17
defend [1] 28/21
defendant [7] 1/18 1/19 5/24 6/9 8/1
12/1 17/14
Defendant's [2] 75/3 83/4
defendants [11] 1/8 5/11 6/23 7/1
7/4 7/6 11/7 11/17 11/22 24/14 28/6
defense [9] 11/25 76/10 79/11 79/21
99/13 100/10 101/21 103/3 105/22
defied [1] 12/17
define [1] 72/1
definitely [1] 113/11
definition [1] 22/6
definitions [1] 28/14
definitively [1] 114/16
delay [1] 108/22
delayed [1] 34/23
delegated [1] 53/15
deliberate [1] 116/17
deliberations [2] 83/2 116/17
delinquent [1] 45/17
demonstrative [3] 81/10 101/21
101/22
Department [2] 17/8 35/9
deposit [6] 16/11 16/12 21/22 22/9
22/11 23/2
deposited [4] 9/10 16/3 16/5 19/2
deposits [4] 9/21 19/2 19/5 21/21
depth [1] 5/5
deputy [1] 76/4
describe [6] 31/9 32/4 44/3 45/10
45/25 106/6
described [2] 35/23 36/25
describes [1] 61/4
designed [8] 3/25 4/6 4/12 5/8 31/11
46/24 50/19 51/4
desktop [1] 97/8
125
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 126 of 138
D
desperate [1] 27/9
desperately [1] 5/10
determine [3] 50/12 118/7 119/6
determined [3] 71/8 71/20 96/6
determining [6] 42/9 43/7 43/10
43/20 43/25 49/18
develop [1] 26/7
development [1] 30/5
device [5] 57/2 58/20 60/3 74/8 87/6
devices [24] 18/22 57/13 61/20 62/11
63/16 63/18 63/21 65/12 65/14 66/7
66/14 66/22 67/22 68/10 70/14 71/21
95/10 95/12 95/14 95/22 96/4 96/23
96/24 97/9
did [53] 4/11 7/20 8/18 8/20 9/6 9/7
9/9 13/5 13/12 17/18 18/14 20/5 24/5
27/10 30/15 30/17 31/1 31/3 31/19
32/20 35/4 35/6 35/13 35/16 35/17
47/1 52/25 56/4 56/15 57/7 57/16
57/17 58/15 58/18 58/19 58/21 59/14
59/16 59/24 60/1 63/18 70/1 72/5
72/10 75/6 83/12 83/14 96/23 97/1
97/8 97/25 101/16 117/20
didn't [13] 5/5 8/7 14/16 18/20
18/21 21/18 22/23 25/11 62/21 95/24
96/1 105/17 118/17
difference [2] 72/22 84/9
different [16] 5/21 7/23 8/5 30/4
55/24 57/11 58/2 60/12 64/2 64/3
72/18 73/21 74/7 78/9 83/19 102/15
difficult [4] 76/6 78/17 112/11
119/4
digital [1] 61/20
diligence [1] 50/2
dire [1] 111/21
direct [11] 3/22 3/25 29/16 41/12
55/9 63/13 63/14 68/23 70/6 72/14
81/7
directed [1] 5/23
directing [1] 100/14
direction [1] 8/23
directory [1] 94/22
disapprove [1] 36/15
disaster [9] 30/7 30/9 30/12 31/8
31/10 31/13 43/14 43/15 45/22
disasters [1] 30/8
disburse [3] 33/17 37/13 37/21
disbursed [3] 39/2 39/8 52/5
disc [1] 80/13
discovery [1] 63/17
discuss [3] 63/22 110/24 114/12
discussed [2] 35/5 70/6
discussing [2] 72/13 84/6
discussion [7] 3/6 40/7 54/24 67/8
76/22 110/25 112/20
disinclination [1] 82/1
dispute [1] 64/10
dissolved [1] 25/17
distributed [1] 52/5
District [6] 1/19 1/1 1/1 1/11 121/6
121/6
divide [1] 42/14
DIVISION [1] 1/2
divorced [1] 25/9
Dixon [1] 89/1
DJ [1] 88/25
dl.mail.ymail.com [1] 87/16
do [64] 2/17 2/18 2/23 5/5 10/16
18/20 19/18 19/18 19/19 26/18 26/23
27/23 30/1 40/13 40/14 41/14 42/1
50/5 50/10 53/1 53/23 55/20 56/3
56/4 56/7 64/6 67/3 76/1 76/13 77/10
80/23 81/16 82/1 82/20 83/19 87/15
87/20 90/19 93/5 94/16 97/1 98/21
99/6 99/22 99/24 100/4 103/5 103/7
103/18 106/1 109/17 112/16 113/1
113/4 113/6 114/23 115/4 116/8 117/8
118/9 118/21 119/21 119/24 121/7
docket [2] 1/10 1/4
document [31] 1/13 10/21 38/7 38/7
38/11 41/3 41/7 45/2 46/16 61/4 63/1
65/20 69/24 70/19 75/15 79/1 80/16
82/18 89/13 89/13 89/16 89/20 89/22
94/1 95/8 98/10 98/14 98/23 99/3
106/20 113/19
documentation [5] 33/12 44/25 50/8
50/11 51/25
documents [42] 5/23 5/25 7/17 7/19
8/1 13/8 14/5 14/6 15/9 15/11 15/12
16/21 16/22 16/25 17/22 20/22 37/24
38/2 44/19 44/21 49/8 54/9 58/3
60/14 61/3 79/3 79/10 80/8 82/24
82/25 83/1 83/2 89/9 89/17 89/24
89/25 105/4 107/8 107/12 107/14
107/16 107/19
does [27] 2/13 30/1 38/14 38/19
38/23 46/21 53/23 54/8 54/11 58/1
62/19 63/3 79/4 86/15 89/6 92/16
93/16 98/4 98/5 104/4 105/15 108/12
110/8 110/9 110/12 110/13 116/1
doesn't [8] 19/25 21/5 81/2 83/22
98/7 98/21 110/7 110/10
doing [9] 2/7 2/9 10/4 10/11 13/16
53/12 80/23 81/11 117/14
dollars [3] 6/1 8/2 13/23
don't [21] 2/16 14/24 42/25 53/3
53/6 64/10 65/18 69/20 75/24 76/13
76/14 76/16 77/20 78/18 78/20 87/22
101/17 110/14 114/5 119/12 120/1
done [6] 17/25 20/16 23/8 23/19 26/1
30/18
dongle [1] 58/10
door [3] 19/22 49/20 51/4
doors [1] 3/21
doubt [7] 11/23 24/25 28/17 28/19
28/20 28/25 29/7
down [20] 3/20 35/24 45/4 45/24
47/19 47/25 48/4 48/19 49/4 54/18
79/3 85/6 86/4 93/22 101/13 104/25
106/15 110/22 111/10 111/11
download [10] 70/12 88/2 88/16 94/19
96/4 103/20 104/1 104/13 104/24
117/25
downloaded [16] 61/20 63/16 72/7
87/25 88/3 88/5 88/9 88/16 90/18
90/23 91/5 91/6 94/18 104/15 104/21
105/17
downloads [5] 64/9 87/14 87/24 94/21
103/17
dozen [2] 7/20 7/25
draft [1] 33/2
drafting [1] 31/22
drive [19] 1/23 60/5 62/9 62/12
65/10 66/1 71/13 71/24 75/11 76/4
76/15 77/1 77/5 77/11 77/14 77/17
78/2 80/16 88/21
drives [2] 60/6 70/9
drop [1] 18/24
due [1] 50/2
duly [3] 29/15 55/5 55/8
during [19] 3/17 4/20 6/12 8/10
13/21 18/14 19/8 20/4 25/7 25/16
26/14 26/20 28/10 28/21 39/6 68/2
78/20 111/21 119/2
Durrett [1] 1/19
duty [1] 115/10
E
e-tran [2] 37/16 37/18
each [15] 5/21 6/6 10/23 11/23 14/3
14/8 22/21 22/21 25/9 43/1 48/12
74/18 93/10 101/4 106/11
earlier [7] 13/18 35/22 53/11 53/17
85/23 95/10 96/6
earliest [1] 86/7
early [6] 14/8 19/16 113/10 115/1
116/9 117/22
earned [1] 13/24
easier [2] 77/6 80/15
easily [1] 58/4
easy [1] 77/24
ECF [2] 1/5 1/6
economic [10] 3/22 4/1 30/22 31/7
31/9 43/13 43/15 45/22 50/23 51/1
edit [2] 98/10 106/20
Educational [1] 30/5
effect [2] 45/13 47/7
effective [4] 34/21 34/23 34/24 35/2
efficient [1] 77/20
efforts [1] 71/6
egg [1] 112/3
eggs [1] 112/5
EIDL [2] 43/13 43/13
either [6] 29/8 36/15 36/23 42/12
45/18 57/13
electronic [6] 33/14 37/18 53/25
79/15 82/20 82/22
electronically [3] 37/2 37/4 74/22
element [2] 19/9 28/16
elements [1] 28/15
eligibility [5] 33/19 33/21 35/4
45/11 46/2
eligible [7] 34/6 39/18 43/10 45/12
47/7 52/17 52/24
Elite [1] 15/17
ELMO [2] 78/15 79/17
else [4] 18/9 24/13 95/15 96/3
else's [3] 98/17 106/18 106/21
email [19] 13/7 14/22 14/25 15/3
15/4 15/6 16/25 18/8 41/23 69/21
93/17 94/14 94/23 106/17 108/9 109/4
109/5 109/9 109/22
emailing [1] 14/8
emails [10] 6/22 13/7 13/8 14/6 14/8
16/19 16/20 17/23 18/7 101/3
embryos [1] 112/2
emergency [3] 34/25 34/25 51/3
employed [3] 29/24 32/17 55/15
employee [3] 6/18 14/19 90/13
employees [22] 4/14 4/16 4/21 5/7
10/1 33/23 33/25 34/7 35/17 38/2
42/12 42/23 43/1 43/4 43/24 45/1
46/8 46/11 46/12 48/14 50/9 52/1
enacted [1] 51/3
encounter [1] 20/4
encrypted [1] 71/2
end [12] 3/24 12/13 20/8 25/12 27/23
28/5 29/6 58/9 83/2 113/22 116/6
116/6
ends [3] 20/11 116/5 116/8
enforcement [1] 19/15
engaged [2] 47/11 48/2
enjoys [1] 117/10
enough [1] 82/18
enter [8] 33/13 36/20 53/25 74/4
83/20 106/5 106/6 106/13
entering [1] 83/18
enters [4] 3/2 53/24 67/15 82/14
entertain [1] 27/10
entire [6] 13/6 20/2 20/7 90/8
112/14 114/16
entirely [1] 23/25
entirety [4] 77/11 78/24 101/17
101/18
entities [1] 15/19
entitled [1] 43/14
entries [6] 79/8 100/24 101/1 101/3
102/10 102/11
entry [6] 1/10 79/24 86/5 104/12
104/12 104/13
error [3] 22/7 22/12 22/23
errors [4] 37/10 53/20 54/1 54/3
es [1] 2/21
Especially [1] 28/14
Esq [6] 1/16 1/16 1/17 1/18 1/19
1/19
estate [1] 26/7
et [3] 34/8 41/21 54/1
et cetera [2] 41/21 54/1
even [11] 8/18 10/14 12/25 14/14
78/15 98/3 108/17 112/13 114/18
115/19 117/25
eventually [2] 56/14 56/23
ever [6] 20/5 27/9 35/18 71/4 96/24
111/10
every [10] 7/14 7/22 12/9 13/4 28/16
52/25 79/24 86/5 97/23 100/20
everyone [3] 80/20 117/7 117/10
everything [12] 26/1 39/10 39/12
58/11 72/23 77/12 77/14 78/25 88/15
111/20 116/16 118/20
evidence [61] 5/11 5/16 7/7 7/12
9/24 9/25 10/2 10/4 11/2 11/5 11/16
11/20 13/4 13/15 13/19 14/17 14/25
15/5 15/23 15/25 17/1 17/4 17/21
17/25 18/4 18/8 18/16 18/21 18/23
18/25 19/1 19/1 20/9 20/20 21/3 21/7
23/9 24/1 27/23 28/5 28/9 29/6 40/22
126
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 127 of 138
E
evidence... [18] 41/1 56/9 56/11
58/13 58/17 59/25 60/8 60/9 60/24
63/14 63/21 66/25 68/1 76/2 77/15
82/22 83/5 101/19
evident [1] 117/7
ex [4] 8/23 9/12 10/15 27/1
ex-husband [2] 8/23 10/15
ex-wife [2] 9/12 27/1
exact [1] 7/22
exactly [1] 118/17
examination [15] 29/16 51/15 55/9
56/7 61/15 67/19 78/20 82/21 96/18
97/20 98/21 101/6 107/6 109/19
118/11
examine [2] 59/24 63/17
examined [2] 66/17 68/23
examiner [3] 55/19 55/21 56/1
examining [1] 59/23
example [8] 48/12 80/1 88/6 98/8
100/14 103/25 107/14 108/8
examples [1] 74/10
exceed [1] 42/25
Excel [11] 89/9 89/13 89/16 89/24
89/25 90/8 92/3 98/14 105/3 105/18
107/14
except [1] 10/5
exchange [1] 6/5
exchanged [2] 6/23 7/16
excused [1] 115/14
executed [1] 64/23
execution [1] 68/2
executive [2] 15/17 47/17
exhibit [16] 40/5 40/12 40/13 40/22
41/1 41/5 46/15 59/19 75/3 81/1 82/8
85/19 87/7 99/14 100/10 103/3
Exhibit 3014 [1] 40/13
exhibits [14] 59/6 59/8 59/9 60/21
76/5 79/12 79/13 79/15 79/23 79/24
79/25 80/5 83/4 118/6
existed [5] 4/7 5/19 9/3 10/3 35/16
existing [1] 13/20
expect [8] 17/4 17/21 18/7 19/13
24/11 24/18 25/6 26/15
expectations [1] 12/17
expected [1] 26/23
expense [1] 9/8
expenses [7] 4/5 4/10 5/8 9/7 34/13
39/6 52/19
expensive [1] 15/22
expert [1] 28/3
explain [4] 20/20 21/19 86/19 107/21
explained [2] 12/13 32/11
explanatory [1] 45/5
explicit [1] 16/7
exploited [1] 5/12
extensively [1] 49/21
extra [3] 51/8 51/20 116/20
extract [4] 57/2 65/23 66/4 70/15
extracted [3] 57/6 65/7 68/19
extraction [3] 57/24 58/1 58/11
eyes [1] 7/2
F
F24 [3] 75/3 75/12 75/14
F24A [4] 82/11 82/24 83/4 83/13
F24B [2] 98/1 99/14
F24C [1] 84/21
F24E [2] 85/15 100/10
F24E1 [4] 82/12 82/24 83/5 86/14
F24F [2] 86/18 101/9
F24G [1] 87/7
F24H [2] 87/14 103/17
F24I [2] 90/5 105/3
F24J [1] 103/3
F24K [2] 93/25 105/21
F24L [1] 95/4
face [2] 3/21 11/7
fact [4] 13/7 26/8 44/14 44/17
factor [3] 42/9 42/9 43/9
facts [4] 11/22 12/17 14/22 28/9
fair [2] 35/11 100/12
faith [5] 48/17 50/10 51/22 51/25
52/20
fake [2] 7/19 14/5
falls [1] 116/15
false [8] 5/25 11/9 11/11 15/10
15/12 20/19 44/14 49/10
familiar [3] 10/13 34/15 87/18
family [3] 112/18 112/24 114/8
famous [1] 12/12
far [1] 53/12
fast [2] 5/9 21/18
faster [1] 116/19
father [1] 113/1
fathered [1] 25/22
fault [1] 120/3
FBI [14] 10/7 10/20 16/13 18/17
19/15 19/21 20/3 20/14 20/14 55/16
55/17 56/11 58/16 59/25
FEBRUARY [16] 1/12 4/7 9/16 33/24
35/17 38/3 45/1 48/13 50/10 52/1
56/16 67/24 90/13 113/21 121/10
121/20
February 18 [1] 56/16
federal [8] 30/2 30/18 34/22 35/10
45/16 47/12 48/3 49/2
fee [1] 9/18
feel [3] 40/1 64/6 78/14
fees [2] 9/23 26/11
Ferry [2] 63/10 64/24
few [7] 107/5 111/22 112/2 112/7
113/20 114/15 115/20
fiction [1] 12/19
field [1] 32/7
fields [1] 83/19
figure [3] 76/16 76/17 82/19
file [20] 73/13 88/4 88/7 88/8 88/15
90/12 90/15 90/21 90/23 90/24 91/3
91/4 91/13 91/25 92/7 94/16 103/11
104/6 104/8 105/17
filed [3] 1/5 1/11 1/13
files [9] 73/24 74/16 76/9 78/9 90/8
94/6 94/13 96/7 105/5
fill [4] 14/15 14/18 52/16 84/7
filled [1] 36/12
filling [1] 54/4
final [6] 31/23 34/16 34/19 34/21
34/23 35/2
finally [5] 6/8 8/22 20/9 43/23
105/20
financial [3] 11/12 30/5 36/6
find [8] 6/4 10/21 15/10 18/13 28/1
58/13 88/22 114/19
Finder [3] 60/8 60/9 60/24
finding [2] 6/6 74/5
fine [1] 95/20
fingerprint [1] 98/21
first [34] 21/22 22/17 22/18 29/11
29/15 33/2 40/19 41/10 42/8 42/9
42/24 43/3 46/17 47/14 48/12 48/19
48/20 54/20 55/5 55/8 62/16 68/13
78/22 84/15 87/8 90/11 91/14 92/22
93/1 99/14 100/18 105/12 115/15
116/7
five [5] 36/24 62/4 100/23 100/23
118/22
fixed [2] 22/23 36/23
flagged [1] 100/2
flash [10] 75/10 76/4 76/15 77/1
77/5 77/11 77/14 77/16 78/1 80/15
flaw [1] 28/1
flight [3] 113/24 114/2 114/4
Florida [1] 17/8
focus [2] 11/17 46/16
focuses [1] 57/12
folder [5] 93/19 94/13 94/16 100/18
100/19
folders [1] 94/7
follow [4] 49/25 52/13 53/1 109/17
follow-up [2] 53/1 109/17
following [1] 1/3
follows [4] 29/15 55/5 55/8 67/12
football [1] 12/7
foregoing [1] 121/17
forensic [7] 18/14 55/19 55/20 55/24
56/1 56/7 60/5
forget [2] 28/23 111/10
forgivable [1] 39/4
forgiven [4] 4/10 9/9 39/11 39/22
forgiveness [9] 39/2 39/7 39/9 39/15
52/15 52/16 52/21 53/9 53/10
form [14] 4/20 35/12 38/10 38/15
40/17 40/18 47/9 47/16 52/16 74/24
78/14 84/7 84/8 121/15
Form 941 [1] 38/10
formally [1] 6/14
format [2] 54/1 73/12
forms [12] 6/19 6/20 7/21 8/6 14/6
14/16 14/19 31/22 31/22 38/12 49/8
80/7
formula [1] 42/17
FOSTER [43] 1/7 1/19 3/16 5/24 7/8
7/11 7/13 7/17 8/1 8/3 8/4 8/7 8/9
8/17 8/19 9/1 11/9 13/3 13/11 13/12
13/20 14/2 14/23 15/6 15/18 15/23
16/8 17/12 61/19 84/16 85/2 85/20
87/2 89/2 93/15 94/11 95/24 96/1
96/22 99/20 100/6 110/6 121/12
FOSTER'S [2] 12/1 13/7
found [1] 65/5
four [2] 7/16 106/11
frame [1] 42/15
fraud [15] 3/17 5/15 6/8 7/5 7/12
8/21 11/10 11/11 11/19 14/12 15/21
22/10 27/10 49/3 53/6
frauds [1] 6/24
fraudulent [13] 5/18 5/25 6/21 8/12
13/8 18/10 18/12 24/6 24/8 26/1 27/2
27/21 29/4
fraudulently [1] 9/12
free [1] 40/1
frequently [1] 31/24
Friday [3] 113/10 113/22 113/22
friend [1] 112/18
friends [1] 112/23
front [3] 18/4 41/4 62/19
full [8] 1/12 39/4 39/11 39/21 76/7
95/8 112/4 118/17
full-on [1] 112/4
fumbling [1] 76/15
fun [1] 112/20
function [2] 43/2 74/21
functional [1] 74/24
functions [1] 75/23
funds [20] 4/12 4/13 4/14 4/15 6/7
15/14 16/7 19/10 21/19 25/2 26/4
26/5 33/17 37/13 37/21 39/14 48/22
49/1 52/4 52/9
funky [1] 80/19
further [11] 49/6 51/10 54/14 61/10
79/3 96/15 97/11 107/3 109/15 110/19
110/21
G
Gaines [45] 8/25 9/1 9/2 9/5 9/6
9/11 9/11 9/14 9/21 10/9 10/11 10/14
10/16 10/18 10/24 10/25 11/3 19/24
23/5 23/10 23/11 23/13 23/21 24/2
24/3 24/5 24/9 24/9 24/10 24/15
24/17 24/22 24/24 25/5 25/7 25/18
25/20 25/23 25/25 26/3 26/12 26/14
26/16 26/23 26/24
Gaines's [2] 8/23 10/15
Galaxy [10] 56/10 56/13 58/16 59/11
59/15 59/20 59/23 69/8 70/17 70/20
galley [1] 2/17
gand.uscourts.gov [1] 1/25
gave [2] 13/12 111/25
Gena [20] 8/4 8/7 8/17 14/1 14/3
14/3 14/7 14/11 15/3 16/1 16/6 16/10
16/14 89/1 89/5 89/18 90/2 91/14
95/24 103/14
Gena's [1] 14/13
general [2] 32/6 55/19
generally [3] 33/23 43/1 94/13
generate [5] 53/20 58/8 73/2 100/21
100/23
generated [1] 72/11
generates [2] 37/17 54/2
generic [1] 91/25
generosity [1] 5/14
gentlemen [4] 3/9 67/4 76/14 82/16
GEORGIA [5] 1/1 1/24 12/6 63/11
121/7
get [43] 4/12 4/17 4/18 5/1 5/3 5/9
8/11 8/18 8/19 18/18 20/24 21/25
22/15 28/18 33/7 39/15 42/10 42/11
42/14 43/21 49/20 51/4 54/11 56/21
127
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 128 of 138
G
get... [19] 60/3 66/10 69/10 69/14
70/22 71/4 71/9 77/15 80/14 80/18
81/8 93/2 95/24 96/1 98/3 109/5
114/13 115/9 116/16
gets [4] 22/21 36/14 99/10 116/17
getting [3] 45/11 46/2 117/6
give [9] 2/19 3/22 3/25 19/18 19/19
25/14 51/5 73/1 82/9
given [3] 8/24 22/6 96/4
giving [1] 81/18
go [43] 3/14 40/9 47/14 58/13 64/19
67/2 76/17 76/24 77/22 81/19 82/20
83/2 83/15 83/20 84/1 84/19 84/21
85/6 85/14 85/21 87/6 88/18 89/24
92/14 93/19 94/6 97/15 97/22 99/8
100/20 103/2 105/3 105/20 108/23
109/18 110/24 111/4 113/18 113/24
115/9 115/10 116/17 119/2
Goeffrey [1] 62/6
goes [10] 20/20 37/8 37/10 41/17
42/19 53/19 54/1 58/6 88/20 93/12
going [90] 2/24 3/12 6/12 6/22 6/25
7/5 7/12 12/6 12/22 12/25 14/17
14/22 15/2 16/15 18/13 19/1 21/19
21/25 22/11 24/13 24/15 24/17 24/19
24/22 26/18 27/6 28/6 33/10 41/3
41/24 41/24 41/25 42/10 45/4 45/24
46/15 47/13 47/19 47/25 48/4 48/19
49/4 51/1 63/12 64/4 67/22 72/7 76/5
77/12 78/3 79/2 79/7 79/23 80/7
80/10 80/15 82/20 82/22 86/4 87/23
88/14 97/22 98/1 98/11 101/7 101/12
103/2 103/17 104/11 105/3 107/24
108/4 108/5 111/11 111/14 112/11
112/20 113/8 113/11 114/19 115/9
116/18 117/15 118/18 118/22 119/4
119/15 119/17 119/22 120/1
gone [1] 112/14
good [17] 3/9 12/3 17/15 29/18 29/19
48/17 50/10 51/17 51/18 51/22 51/25
52/20 55/2 55/11 61/17 61/18 117/9
Google [3] 85/16 92/19 92/20
google.com [1] 92/21
got [9] 8/2 56/25 78/2 79/5 79/6
80/22 113/19 116/18 116/21
Gotcha [1] 114/1
gotten [3] 67/2 76/25 115/16
government [47] 1/16 3/22 8/14 11/1
11/20 18/2 18/6 18/13 18/23 19/5
19/13 20/19 20/23 21/1 21/22 22/23
22/24 24/11 24/14 24/18 24/20 24/22
25/8 26/11 27/11 27/24 28/6 28/16
28/17 29/12 30/6 40/21 49/2 54/21
59/8 63/20 75/13 78/12 78/19 78/23
82/25 116/12 117/14 117/20 118/2
118/5 118/9
government's [15] 3/15 12/24 13/2
17/10 17/21 20/13 22/7 22/13 28/23
40/5 40/22 41/1 41/5 59/19 60/21
grab [1] 76/17
great [2] 2/11 111/2
group [4] 14/10 15/16 88/8 119/22
guarantee [3] 33/15 36/10 38/22
guaranteed [3] 37/12 38/24 49/11
guess [2] 77/10 113/15
guidance [1] 33/2
guilt [2] 23/23 116/19
guilty [10] 11/23 17/12 23/14 23/19
23/21 23/24 24/12 28/24 28/25 29/7
H
h'm [1] 91/9
H-U-N-T-E-R [1] 55/14
had [72] 3/20 3/21 4/21 4/25 5/7 5/7
5/21 5/22 5/23 6/3 7/8 9/7 9/18 10/1
12/3 12/5 12/12 12/16 13/20 13/23
14/25 15/3 15/9 15/13 15/18 15/23
15/25 16/6 16/24 17/7 20/2 21/6 21/8
21/8 21/10 21/16 25/2 25/9 26/1 26/5
26/11 26/23 27/1 27/10 27/14 33/24
33/25 38/2 39/20 43/17 44/23 45/1
45/16 48/13 50/4 50/8 50/24 52/1
52/9 52/25 59/5 77/1 78/10 90/24
113/16 115/16 117/20 117/23 118/7
118/7 118/13 119/8
half [2] 4/24 112/7
hand [2] 78/6 79/1
handful [2] 77/13 77/19
handle [1] 116/2
hands [5] 40/12 63/1 65/20 69/24
70/19
hanging [1] 116/18
happen [1] 113/12
happened [1] 14/4
happening [1] 109/10
happens [5] 37/8 37/19 58/6 114/17
114/18
happy [2] 24/21 64/6
hard [10] 12/15 60/5 60/5 62/9 62/12
65/10 70/9 80/19 82/23 83/1
harder [2] 5/20 6/10
hardly [1] 21/11
hardship [3] 50/23 51/1 115/18
hardware [1] 55/23
Harvest [1] 92/24
Harvey [2] 12/11 12/22
Harvey's [1] 12/10
has [38] 1/11 17/25 20/16 22/13
22/20 23/22 27/25 27/25 28/16 36/12
37/21 38/1 39/1 41/20 41/22 45/16
55/18 55/22 57/12 61/5 77/6 79/11
79/24 80/22 81/12 82/23 86/18 91/25
92/21 99/3 102/10 102/11 111/20
112/6 114/15 116/4 116/17 118/15
hasn't [1] 82/25
have [122] 2/24 4/11 5/5 8/22 10/1
10/3 10/18 12/10 12/18 13/2 18/21
19/9 23/10 25/11 27/15 29/7 31/19
32/5 32/6 32/7 33/9 33/25 35/17
38/17 39/11 39/21 40/12 47/2 47/16
48/11 48/19 50/16 51/13 52/13 53/1
53/3 55/20 56/1 56/3 57/11 59/7 61/7
61/24 62/19 63/20 64/4 64/10 66/17
67/2 69/13 70/2 71/8 75/3 75/6 75/10
75/18 76/3 76/4 76/12 76/25 77/5
77/10 77/16 77/23 77/24 78/1 78/8
78/14 79/5 79/6 79/8 79/25 81/16
82/19 83/1 83/12 84/21 85/14 86/2
86/14 86/18 87/6 87/20 89/12 95/4
96/11 97/24 98/11 99/22 100/15 102/6
102/8 104/12 107/2 107/8 107/11
107/16 107/19 109/12 109/17 109/24
111/2 111/10 112/9 113/1 113/4 113/6
115/17 115/23 115/25 116/1 117/11
117/13 117/17 117/21 117/23 117/24
118/16 118/20 119/5 119/21 120/2
haven't [5] 76/12 117/24 117/25
118/13 119/8
having [7] 29/15 33/22 33/23 55/5
55/8 58/10 112/1
he [43] 7/20 8/17 8/18 8/20 12/11
12/13 12/13 13/23 13/25 15/9 15/12
15/12 15/13 15/13 15/21 16/24 16/24
17/2 17/7 17/7 23/14 23/16 23/17
23/18 24/4 24/5 24/8 24/19 25/1 25/3
25/21 26/1 26/5 26/5 26/24 27/1 27/2
27/5 115/23 116/4 116/17 116/17
117/1
he's [3] 11/11 13/13 113/1
head [1] 116/18
heading [1] 92/15
headquarters [1] 32/7
health [1] 34/7
hear [53] 3/12 6/12 6/16 6/18 6/25
8/9 8/10 8/13 8/15 8/17 8/19 10/7
11/15 11/20 14/7 14/17 14/21 14/22
15/2 15/4 15/5 15/7 15/18 15/25
16/10 16/13 16/23 17/1 17/2 17/11
18/14 18/16 19/8 20/9 20/21 21/13
21/20 22/1 23/9 24/7 24/11 24/13
24/15 25/7 25/16 26/12 26/16 26/19
26/22 27/3 27/4 27/4 27/7
heard [7] 12/11 12/17 20/18 20/23
23/10 25/8 26/10
hearing [1] 121/15
heavily [1] 46/25
held [1] 121/10
Hello [2] 96/20 96/21
help [12] 4/16 8/4 15/10 26/7 30/3
31/11 62/23 112/2 112/19 112/24
112/25 113/2
helped [4] 16/1 24/8 77/3 77/8
helpful [2] 75/22 116/4
her [41] 8/23 9/13 10/9 10/15 10/16
14/13 17/18 18/17 19/2 19/18 19/20
19/22 19/23 20/2 20/3 21/6 21/12
25/1 25/3 25/4 26/2 26/4 26/5 26/6
27/17 27/19 28/3 28/4 29/4 63/8
63/17 63/22 64/5 64/5 65/5 80/21
81/14 98/16 112/11 112/19 112/21
here [39] 3/10 3/10 13/16 18/3 18/5
20/21 21/17 22/14 24/17 36/4 41/14
47/15 55/16 58/2 58/3 58/3 76/11
79/6 80/19 80/22 80/23 81/4 81/12
81/13 86/8 93/2 94/9 99/25 103/4
103/7 103/25 105/8 105/11 105/11
105/22 108/20 108/23 114/21 115/15
Here's [1] 5/15
hereby [1] 121/7
hesitant [1] 116/7
hide [1] 11/14
high [1] 12/7
higher [4] 43/3 43/4 43/5 80/23
him [19] 5/23 8/10 8/11 8/13 8/15
8/16 8/17 12/11 13/24 15/10 15/10
16/1 16/17 26/15 115/18 115/22
116/10 116/19 117/6
himself [3] 8/16 24/16 26/16
his [20] 8/3 8/10 8/16 9/12 11/9
15/15 16/23 16/25 20/15 23/10 24/6
24/9 25/18 27/1 93/17 94/23 112/21
112/22 116/18 116/19
history [3] 46/4 60/13 74/10
hit [3] 104/8 106/4 106/6
hitting [3] 95/1 95/2 106/13
hold [3] 18/19 49/2 118/6
holding [1] 21/16
Holland [1] 106/14
home [8] 3/20 14/2 19/16 20/3 50/25
63/8 64/23 111/24
Honor [51] 2/6 2/14 2/20 2/21 2/23
12/2 29/12 39/23 40/10 40/23 50/16
51/13 54/13 54/16 54/21 61/7 61/10
63/12 63/15 64/3 64/8 64/18 75/10
75/13 75/22 75/23 76/3 78/22 78/22
79/21 80/2 81/4 81/22 81/24 83/7
96/11 96/15 96/17 97/14 101/16
101/20 107/5 109/17 110/19 111/24
113/14 115/13 116/3 116/13 117/11
119/12
HONORABLE [1] 1/11
hook [1] 57/16
hope [3] 115/8 115/23 117/10
hopefully [2] 115/6 117/9
hotel [2] 114/2 114/7
hour [4] 28/13 118/21 119/16 119/19
hour's [1] 119/16
hours [6] 111/22 112/2 112/7 114/15
115/19 117/2
how [25] 5/11 5/12 5/15 7/2 7/4 8/5
14/15 14/18 15/21 28/9 36/22 42/6
42/9 42/11 43/10 43/21 53/2 55/2
56/1 73/11 81/12 93/5 116/2 117/6
119/10
however [1] 1/12
HP [1] 65/14
HTML [4] 73/15 73/16 75/16 104/9
huge [2] 21/2 77/20
Hull [1] 62/7
hundreds [5] 6/22 7/16 13/7 18/7
18/7
Hunter [8] 54/22 55/4 55/6 55/7
55/11 55/13 83/9 97/22
hurtful [1] 25/23
husband [2] 8/23 10/15
hypotheticals [1] 109/21
I
I'll [7] 2/15 24/20 81/5 101/9
114/12 114/20 115/8
I'm [56] 12/6 12/10 25/14 40/4 41/3
41/13 41/14 41/24 41/25 42/2 46/15
47/13 47/15 55/3 55/18 62/21 63/12
63/17 64/4 64/6 64/25 65/19 76/11
77/10 79/19 86/4 88/12 94/12 95/17
95/19 97/22 99/11 101/7 101/12
101/20 103/2 104/11 104/18 105/3
108/8 108/8 108/15 112/18 113/18
128
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 129 of 138
I
I'm... [12] 113/24 114/5 114/6 114/8
114/9 115/9 115/10 116/7 116/14
116/20 117/11 119/1
I.D [4] 89/6 89/9 103/7 103/10
IBM [1] 21/15
idea [6] 12/18 27/1 27/20 59/24
60/16 80/19
ideal [1] 112/15
identical [1] 7/21
identification [1] 41/22
identified [6] 56/10 58/16 59/24
60/17 79/25 106/25
identifier [2] 88/24 89/12
identifiers [3] 87/6 88/18 103/2
identifying [1] 107/11
IEF [11] 72/17 72/20 73/8 75/6 88/20
96/7 98/4 99/19 106/23 110/14 110/15
IFR [1] 34/16
illegal [7] 17/18 17/20 19/11 25/2
26/5 47/12 48/3
image [1] 60/4
immediate [1] 51/5
immediately [3] 7/10 34/21 35/3
impact [1] 23/23
impacted [1] 4/1
implement [1] 32/12
implemented [1] 50/1
implementing [1] 31/19
implies [2] 22/17 22/18
imply [3] 20/16 21/1 27/21
important [16] 24/1 24/3 25/19 25/19
28/8 43/7 43/19 43/24 44/9 44/15
44/17 44/21 46/6 47/4 49/17 115/4
importantly [1] 15/2
inaccurate [1] 44/14
include [4] 46/11 46/13 96/7 119/6
included [3] 34/6 46/9 47/16
includes [2] 61/23 94/3
including [6] 13/11 38/13 47/17
82/24 83/4 117/21
inclusive [1] 82/11
income [2] 27/15 31/12
incomplete [1] 104/13
incorrectly [1] 54/4
independent [3] 30/2 34/1 48/15
independently [4] 47/2 49/23 51/9
52/3
indicate [2] 25/8 41/19
indicated [2] 51/19 118/9
indicating [1] 37/11
indicia [1] 53/6
indictment [11] 22/1 22/3 22/4 22/8
22/16 22/16 22/17 22/18 22/19 22/21
23/4
individuals [4] 6/4 19/25 88/21
96/23
Industry [1] 31/10
Infidelity [1] 25/20
information [44] 14/3 24/4 26/24
32/1 33/14 34/20 36/8 36/18 36/20
36/21 36/21 37/1 37/3 37/8 38/13
41/17 42/6 42/23 43/7 43/24 44/9
44/13 47/8 49/6 49/7 50/20 51/9 52/3
52/21 53/24 54/11 57/23 76/10 81/18
83/18 86/21 88/21 89/16 98/4 100/3
111/25 113/7 113/9 116/4
initial [2] 48/11 49/15
initially [4] 15/14 52/5 56/14 56/19
inject [1] 24/24
Injury [4] 31/8 43/13 43/15 45/22
innocence [3] 23/23 28/19 116/20
innocent [1] 25/1
inside [1] 93/16
insistent [1] 17/6
install [1] 107/23
instances [2] 100/12 103/22
instead [3] 17/4 82/23 111/17
institution [1] 11/12
institutions [1] 36/6
instruct [1] 28/7
instructing [1] 10/16
instruction [1] 28/18
instructions [8] 19/8 23/21 28/7
28/8 28/12 28/19 67/5 111/3
intend [1] 2/18
intended [2] 46/1 117/18
intent [1] 117/5
interact [3] 75/16 75/25 76/1
interactions [1] 100/13
interest [5] 34/9 36/22 39/19 44/6
48/23
interested [1] 74/5
interim [5] 31/23 34/15 34/19 34/21
35/2
internal [1] 91/12
internally [1] 68/16
internet [8] 17/25 60/8 60/9 60/24
73/19 83/18 94/14 117/25
interrupt [1] 67/1
interspersed [1] 118/11
interview [3] 8/10 10/7 19/19
interviewed [2] 14/15 18/17
interviews [1] 6/25
introduce [3] 18/23 117/15 117/18
introduced [1] 20/22
introducing [1] 63/21
investigation [3] 5/6 7/1 22/25
Investor [1] 88/8
invoke [1] 2/13
involved [10] 5/24 6/16 7/4 13/13
15/8 19/7 19/11 27/2 32/11 50/21
involving [1] 26/1
iOS [2] 57/12 57/13
IP [1] 17/25
iPhone [6] 62/6 65/5 72/5 87/9 87/10
87/11
iPhones [1] 97/1
IRS [7] 6/18 6/21 7/18 8/5 14/4
14/13 14/19
is [384]
isn't [3] 63/13 109/10 116/24
issue [16] 6/17 6/19 37/11 52/4
54/10 77/9 77/10 77/21 79/13 79/14
79/17 81/22 115/25 116/6 117/12
119/2
issued [1] 33/16
it [269]
it's [73] 6/14 12/21 12/22 12/25
14/17 16/17 19/19 20/16 22/24 24/18
25/9 37/5 38/15 40/16 40/24 41/20
54/6 55/13 57/10 58/2 58/9 58/10
58/12 58/23 58/24 59/1 60/5 60/10
64/2 65/18 73/12 74/24 75/19 76/8
77/6 78/2 78/5 78/17 78/17 79/23
80/10 80/12 80/14 81/21 82/11 84/11
85/20 87/15 89/8 90/8 90/8 93/10
95/8 98/7 98/11 98/14 100/6 104/7
105/24 106/12 107/24 108/14 110/5
112/1 112/4 114/8 114/19 115/3 117/7
119/3 119/3 119/4 120/3
item [12] 56/11 56/15 57/16 58/16
68/17 72/18 97/23 105/11 105/11
105/12 105/12 105/23
items [13] 45/9 61/23 62/1 66/24
72/2 73/2 73/4 77/19 79/3 85/23 86/2
94/8 105/24
its [6] 9/20 29/11 30/2 38/4 42/7
78/23
itself [1] 112/13
IVF [1] 111/14
J
J.P [1] 1/11
JACKSON [47] 1/6 1/18 6/9 8/23 9/12
9/13 9/25 10/2 10/4 10/7 11/6 11/14
17/16 18/9 18/11 18/15 18/19 18/24
19/6 20/9 21/9 22/20 23/1 23/15
23/18 24/19 24/23 25/8 25/18 25/21
25/24 26/3 26/8 26/17 26/18 26/25
27/12 28/2 28/21 28/24 29/2 29/7
96/24 97/4 97/9 109/16 121/12
Jackson's [7] 3/17 17/14 18/17 19/16
20/23 27/5 27/8
January [7] 9/16 20/24 23/14 23/19
43/16 45/22 90/12
January 31 [1] 45/22
Jesika [4] 62/4 62/17 66/15 89/1
jewelry [2] 15/22 15/22
job [2] 6/4 12/4
Joe [1] 96/10
John [27] 8/23 9/1 9/11 10/9 10/15
10/15 10/24 10/25 23/10 23/13 24/2
24/3 24/10 24/15 24/17 24/21 25/4
25/7 25/18 25/25 26/3 26/8 26/14
26/16 26/23 26/24 27/4
Johnson [2] 87/1 101/10
Joseph [1] 20/14
JPB [2] 1/5 121/12
judge [8] 1/11 23/20 28/6 28/11
97/12 110/21 116/14 116/22
judith [4] 1/22 1/25 121/4 121/23
Julius [2] 87/1 101/10
July [3] 20/5 25/25 27/6
July 7 [2] 20/5 27/6
June [15] 9/19 16/4 20/25 21/3 21/7
21/23 22/9 23/2 25/14 26/4 69/19
85/4 85/8 85/8 93/21
juries [1] 76/1
juror [9] 111/5 111/7 111/13 113/4
113/6 115/14 115/25 116/7 117/8
jurors [4] 111/11 114/21 119/22
120/1
jury [32] 1/10 2/12 3/2 19/8 23/20
28/7 32/14 44/3 45/10 48/20 57/22
58/22 60/2 63/24 67/4 67/14 67/15
76/8 76/14 76/20 77/24 78/2 78/16
79/4 80/13 81/17 82/4 82/14 111/6
115/10 115/17 116/17
just [82] 7/22 9/18 11/3 12/16 13/5
13/15 14/4 14/21 18/25 21/17 22/12
23/21 30/8 32/11 35/5 35/24 37/15
44/7 44/13 45/6 47/13 53/2 54/19
58/4 58/10 60/15 61/23 62/16 62/16
64/11 68/10 68/22 73/2 73/11 77/16
77/19 77/22 78/1 78/5 78/10 78/17
79/19 79/24 80/6 80/10 80/21 81/4
82/9 84/6 84/14 84/19 86/4 86/14
90/8 93/25 95/2 95/7 96/17 96/22
98/15 99/10 100/10 101/21 104/7
106/12 106/12 106/13 107/5 109/4
111/11 111/19 114/18 114/19 114/22
116/9 117/4 117/6 117/22 118/17
118/21 119/15 120/5
justified [1] 13/16
K
K-A-N-D-A-C-E [1] 29/22
Kandace [3] 29/13 29/14 29/22
Kaushal [5] 1/16 64/1 77/8 101/16
108/4
keep [7] 4/14 32/17 32/17 32/18
100/1 109/6 117/6
keeping [1] 28/3
kept [4] 14/3 25/18 26/1 26/24
key [1] 89/9
kind [5] 18/10 20/5 97/8 104/7
111/19
knew [6] 11/6 14/15 17/2 17/18 24/10
29/3
knock [2] 19/14 26/20
know [34] 2/16 8/7 12/14 18/20 19/9
19/25 19/25 21/18 24/1 24/13 53/6
77/20 78/18 79/5 81/6 81/20 94/17
98/7 99/22 103/19 110/14 111/13
112/21 113/9 113/15 113/20 114/18
114/20 114/20 114/21 118/17 118/21
119/12 120/1
knowingly [2] 49/1 49/10
knowledge [9] 14/13 21/5 21/8 21/8
25/2 25/4 87/11 87/20 96/3
known [3] 6/14 25/9 30/23
knows [3] 14/18 24/4 26/12
L
labeled [3] 72/16 93/6 94/16
ladies [4] 3/9 67/4 76/14 82/16
land [1] 15/22
language [1] 105/16
laptop [14] 17/24 59/24 60/4 60/6
60/17 61/1 70/6 72/7 92/8 94/8
102/22 105/14 105/19 106/18
laptops [2] 18/18 97/6
large [3] 21/6 21/11 80/4
larger [1] 115/16
last [18] 45/17 48/1 49/4 51/19 75/2
75/11 85/4 86/25 89/6 89/19 89/21
90/19 91/7 91/18 91/20 102/17 102/21
129
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 130 of 138
L
last... [1] 103/15
lat [1] 117/21
late [2] 115/1 117/21
later [5] 27/7 52/12 56/24 86/22
117/5
latest [1] 113/12
laundered [3] 17/17 29/2 29/3
launderer [1] 8/22
launderers [1] 6/8
laundering [10] 10/5 11/12 11/15
16/3 19/7 19/10 19/11 21/4 28/15
29/1
law [13] 3/24 11/22 19/15 28/7 28/9
47/12 47/17 48/3 49/12 112/25 113/1
115/24 117/1
law's [1] 114/25
lawyers [1] 18/2
layperson [1] 105/16
learn [1] 25/17
learned [1] 25/24
learning [1] 16/24
lease [4] 34/10 39/20 44/6 48/23
least [7] 13/14 37/5 39/21 48/20
78/9 112/21 114/14
leave [3] 107/25 111/22 112/2
Lee [4] 111/14 111/19 114/20 119/21
left [5] 7/6 78/6 79/1 97/17 104/11
left-hand [2] 78/6 79/1
legal [1] 41/21
legally [1] 49/2
legislation [1] 35/14
legitimate [1] 13/23
Leigh [1] 1/19
lender [44] 31/23 33/8 33/12 33/12
33/13 36/1 36/3 36/7 36/8 36/8 36/12
36/14 36/19 36/25 36/25 37/2 37/4
37/12 37/20 37/21 38/20 38/22 38/24
43/7 43/19 43/25 44/10 44/15 44/21
44/23 47/1 47/5 49/17 49/22 50/13
51/7 51/20 52/8 52/19 52/20 53/16
53/23 53/24 54/10
lender's [1] 36/20
lenders [8] 5/4 6/16 31/25 36/3 36/5
50/1 53/12 53/14
length [2] 20/7 28/13
lengthy [1] 28/12
Lenovo [3] 59/24 60/16 70/6
less [3] 7/16 119/19 119/19
let [25] 3/19 27/24 31/1 32/2 33/6
39/13 43/13 67/1 68/10 92/8 98/3
101/2 101/13 107/10 112/12 114/14
114/18 114/19 114/20 114/20 114/22
115/9 115/22 118/16 120/1
let's [13] 2/12 21/21 32/19 54/19
67/6 76/24 82/4 99/8 105/20 108/14
110/24 118/21 120/5
letter [2] 64/5 106/5
letters [1] 106/13
liable [1] 49/2
licensed [1] 58/10
lie [4] 9/25 10/8 10/8 10/8
lied [2] 11/6 28/3
life [1] 20/2
lifeline [1] 4/13
lift [3] 112/9 112/19 114/5
like [50] 4/5 5/24 6/8 7/18 9/8 11/3
12/7 12/20 12/21 12/22 13/13 15/23
16/18 35/23 40/1 41/12 54/3 54/3
54/6 54/6 58/2 61/4 63/22 64/1 64/6
64/19 67/2 73/13 74/10 75/24 77/19
78/10 78/14 83/21 87/22 89/13 92/22
93/16 95/1 100/20 104/7 106/4 108/25
109/9 110/5 111/20 113/2 114/22
118/10 119/3
likewise [1] 102/11
limited [1] 34/8
line [7] 1/10 53/18 64/17 84/15
84/15 85/6 85/7
lines [1] 77/17
link [1] 89/10
linked [1] 89/12
list [7] 4/21 45/6 45/7 80/3 80/4
89/2 90/8
listed [7] 86/23 87/2 88/24 89/19
91/17 103/11 108/2
listen [10] 16/15 17/9 17/10 28/11
28/14 117/23 119/2 119/4 119/16
119/17
Litigation [1] 32/10
little [19] 21/21 24/2 25/15 27/14
33/6 35/22 35/24 37/15 41/25 64/2
64/3 78/11 94/12 99/12 111/21 114/24
116/20 117/18 119/13
live [1] 75/14
LLC [1] 88/8
loaded [1] 62/11
loan [84] 4/4 4/10 4/24 5/2 5/25 6/7
7/24 8/12 8/20 9/1 9/4 9/6 9/9 9/10
10/24 14/12 16/1 17/3 27/10 31/8
31/10 32/8 33/7 33/13 33/15 33/16
33/18 34/3 34/12 36/10 36/10 36/22
37/11 37/12 37/13 37/15 37/19 38/5
38/17 38/18 38/19 38/23 38/25 39/1
39/5 39/8 39/11 39/15 39/21 42/6
42/7 42/17 43/5 43/8 43/14 43/16
43/17 43/20 43/22 43/25 44/3 44/10
44/11 44/22 45/3 45/12 45/16 45/17
45/18 45/22 46/4 47/2 47/21 47/22
49/11 49/18 50/12 52/23 52/25 53/16
53/20 54/2 54/10 92/24
loans [22] 5/18 6/17 7/2 8/24 13/9
13/14 15/13 18/10 18/12 24/6 24/8
26/1 26/5 27/2 34/5 36/6 36/23 39/4
52/13 53/2 53/4 53/15
local [3] 12/6 47/12 48/3
locally [2] 94/6 94/13
located [2] 34/10 37/6
locked [1] 57/14
log [2] 59/14 106/17
logged [10] 93/17 108/14 108/17
109/3 109/6 109/7 109/9 109/23
109/24 110/3
logs [3] 57/18 58/4 59/20
long [6] 7/5 20/8 56/1 81/6 119/10
120/2
longer [3] 12/23 13/1 119/23
look [23] 7/18 9/8 11/3 26/9 42/11
52/24 64/25 65/16 66/11 70/18 71/14
73/25 74/7 75/24 76/7 79/1 80/13
80/22 84/24 93/16 99/22 100/11 108/1
looked [2] 77/5 108/9
looking [17] 43/6 47/13 77/4 77/12
80/4 81/19 91/8 99/13 100/3 100/18
100/18 101/18 103/10 104/9 105/24
106/3 110/4
looks [4] 87/22 88/20 108/25 110/5
lose [1] 116/7
loss [1] 76/11
lot [6] 12/23 13/18 13/22 14/3 76/6
76/9
lots [4] 12/18 17/22 17/22 26/25
low [1] 27/12
lower [1] 27/15
lunch [8] 110/24 111/2 117/10 119/2
119/6 119/22 120/2 120/8
lunchtime [1] 12/9
M
ma'am [33] 30/24 54/17 55/2 55/15
65/13 66/5 68/6 71/5 72/9 72/18
83/11 84/3 84/23 85/24 86/12 87/4
87/17 87/19 91/12 91/19 91/24 92/2
92/11 93/4 93/8 95/13 95/16 95/17
95/17 96/8 108/19 109/2 110/22
machine [1] 121/9
made [13] 5/4 16/14 18/6 20/19 21/11
25/2 27/16 35/14 36/9 36/25 49/21
53/4 111/25
Magnet [1] 60/11
Mail [1] 87/21
mail.yahoo.com [1] 104/12
mails [1] 100/23
main [1] 19/1
mainly [1] 57/12
maintain [1] 48/23
make [25] 5/20 6/10 9/8 11/3 12/19
18/5 21/18 28/22 33/12 48/23 50/6
51/7 51/23 52/9 52/21 59/3 83/22
105/12 108/12 112/11 114/17 116/9
116/25 117/1 120/5
makes [1] 76/6
making [4] 22/11 34/22 49/10 81/18
Malik [1] 89/1
man [1] 28/2
management [10] 9/14 9/17 9/19 9/24
10/5 17/19 19/4 23/6 26/6 27/19
manager [1] 21/15
managers [1] 27/17
managing [1] 10/3
mandated [1] 53/14
many [6] 7/21 13/3 13/7 23/16 53/2
78/8
March [4] 3/24 9/16 30/25 32/24
mark [2] 20/12 81/1
marked [11] 40/4 40/13 71/25 75/3
79/8 84/21 85/14 86/18 87/6 90/5
95/4
marriage [3] 25/12 25/16 25/22
married [4] 14/1 25/8 25/10 25/21
Marshall [5] 1/18 2/18 2/21 96/16
116/11
mastermind [1] 5/17
material [1] 49/9
materials [4] 62/17 63/5 66/19 73/9
matter [2] 114/17 121/11
maximum [6] 38/5 42/7 42/17 43/22
45/3 50/12
may [30] 1/5 1/9 9/17 25/12 38/17
39/23 49/2 52/23 56/23 65/16 67/13
68/19 70/1 84/18 86/9 86/11 90/15
90/24 93/24 97/16 100/20 100/23
109/23 113/7 114/23 115/25 116/6
116/9 116/25 118/3
May 28 [1] 93/24
maybe [17] 15/2 19/20 19/21 20/6
20/9 28/12 53/8 53/18 54/3 78/19
80/19 80/22 106/12 111/21 114/25
115/1 117/5
me [66] 3/19 27/24 31/1 32/2 33/5
33/6 37/1 38/6 39/13 43/13 48/8 49/2
57/1 59/8 59/19 60/21 62/14 65/10
67/1 68/11 68/25 72/1 72/20 73/1
73/11 77/3 77/8 77/16 82/9 83/16
84/14 84/24 85/3 85/10 85/15 85/18
86/1 87/23 88/19 88/23 89/13 92/8
92/15 93/9 93/20 98/3 98/7 99/10
101/2 101/13 103/10 105/16 106/4
107/10 109/6 111/18 111/25 112/1
112/12 114/14 114/20 114/22 117/7
118/16 119/15 121/15
mean [11] 14/24 14/24 46/21 73/13
75/15 89/6 92/16 94/25 105/15 113/1
113/10
meaning [2] 4/10 86/19
means [21] 22/7 28/19 43/5 53/15
57/1 77/20 79/5 83/16 85/11 85/15
87/18 87/24 88/19 89/14 89/20 91/2
93/9 103/19 104/22 105/16 106/7
meant [6] 4/13 4/14 4/15 19/6 20/16
33/25
meet [1] 16/14
mentioned [6] 18/25 27/8 27/11 30/8
33/5 43/1
mentions [1] 20/9
Mero [1] 88/25
message [1] 100/19
messages [6] 6/23 17/23 18/11 18/11
57/20 58/24
messaging [1] 59/1
metadata [12] 89/15 89/20 89/23
91/12 98/12 98/19 98/20 99/2 103/14
107/8 107/11 107/17
Microsoft [4] 70/25 89/16 107/13
107/23
middle [2] 44/14 90/20
might [12] 13/15 19/25 27/15 60/13
62/19 75/22 77/17 77/18 78/18 80/8
103/22 113/7
million [2] 15/21 53/4
millions [4] 6/1 8/2 77/17 78/2
mind [3] 20/2 21/9 100/1
minimal [3] 27/21 44/23 50/4
minute [4] 20/12 40/6 67/6 76/13
minutes [8] 12/23 13/1 20/8 20/11
118/22 119/14 119/17 119/20
minutes' [1] 119/17
misrepresentations [1] 11/18
missing [2] 80/9 80/9
130
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 131 of 138
M
mission [1] 30/3
mixup [1] 117/19
modified [6] 90/19 90/25 91/3 91/8
91/13 105/13
modify [1] 99/2
mom [1] 12/4
moment [5] 3/5 50/17 61/8 67/7 107/2
Monday [3] 113/20 114/19 114/21
money [59] 4/9 4/11 4/17 5/3 5/9
5/19 6/8 6/10 8/2 8/18 8/20 8/22
9/13 9/14 10/6 10/9 10/17 10/23 11/1
11/2 11/4 11/5 11/12 11/13 11/14
11/19 13/11 13/22 13/22 13/23 13/25
15/13 15/15 15/20 16/2 16/5 17/1
17/3 17/5 17/7 17/17 17/17 19/7
19/11 21/3 21/6 21/11 21/12 21/18
28/14 28/25 29/2 29/3 29/4 34/12
38/19 42/12 49/20 51/4
monies [1] 17/20
Montgomery [2] 26/7 26/9
monthly [16] 4/22 4/25 5/1 9/18 38/4
42/8 42/15 42/20 43/2 43/5 43/6 45/2
46/6 46/9 50/11 52/2
months [3] 7/17 42/13 56/24
Moore [3] 1/17 2/6 2/9
more [33] 6/9 7/20 7/25 8/18 9/4
9/20 13/18 13/18 15/2 15/17 24/2
24/24 27/16 33/6 33/23 41/25 43/1
45/8 52/17 64/7 69/6 76/6 78/11 79/3
88/12 91/25 107/10 111/25 112/1
112/16 112/20 113/9 116/4
morning [13] 3/9 12/3 17/15 19/16
29/18 29/19 51/17 51/18 55/2 55/11
61/17 61/18 117/22
mortgage [4] 34/9 39/19 44/6 48/23
most [2] 4/18 77/19
mother [4] 112/25 114/25 115/24
117/1
move [6] 5/19 9/14 40/1 75/12 82/9
116/19
moved [3] 3/22 6/10 8/24
moves [1] 40/21
moving [1] 82/10
MR [2] 2/21 68/9
Mr. [21] 2/6 2/9 2/18 20/15 23/13
23/21 24/24 25/7 25/20 25/23 61/19
64/1 68/8 77/8 87/12 96/16 96/22
101/16 106/14 108/4 116/11
Mr. Cromer [1] 20/15
Mr. Foster [2] 61/19 96/22
Mr. Gaines [4] 23/21 24/24 25/20
25/23
Mr. Holland [1] 106/14
Mr. John [2] 23/13 25/7
Mr. Kaushal [4] 64/1 77/8 101/16
108/4
Mr. Marshall [3] 2/18 96/16 116/11
Mr. Moore [2] 2/6 2/9
Mr. Thomas [1] 68/8
Mr. Thomas's [1] 87/12
MS [2] 2/9 2/14
MS. [62] 2/6 2/18 18/17 18/19 18/24
19/6 19/16 20/9 20/23 21/9 22/20
23/1 23/15 23/18 24/23 25/21 26/17
26/18 27/5 27/8 27/12 28/2 28/21
28/24 29/2 29/7 29/18 29/24 34/15
40/4 40/12 41/3 41/8 42/5 46/18
50/19 51/10 67/1 67/18 77/3 77/6
80/2 80/14 81/11 82/23 83/6 83/9
97/16 97/23 98/7 98/10 98/12 99/14
105/23 109/16 111/4 111/14 111/19
114/20 116/11 119/11 119/21
Ms. Carla [1] 25/21
Ms. Chaiken [1] 119/11
Ms. Hunter [1] 83/9
Ms. Jackson [19] 18/19 18/24 19/6
20/9 21/9 22/20 23/1 23/15 23/18
24/23 26/17 26/18 27/12 28/2 28/21
28/24 29/2 29/7 109/16
Ms. Jackson's [5] 18/17 19/16 20/23
27/5 27/8
Ms. Lee [4] 111/14 111/19 114/20
119/21
MS. WEBSTER [17] 2/6 2/18 67/1 67/18
77/3 77/6 80/2 80/14 81/11 82/23
83/6 97/16 97/23 98/7 99/14 105/23
116/11
Ms. Webster's [2] 98/10 98/12
Ms. Wolff [1] 111/4
Ms. Zelaya [11] 29/18 29/24 34/15
40/4 40/12 41/3 41/8 42/5 46/18
50/19 51/10
much [7] 36/22 42/9 42/11 43/10
54/14 80/4 110/23
muddle [1] 114/24
multiple [4] 7/15 80/7 84/13 100/13
multiply [1] 42/16
must [2] 19/6 21/3
my [25] 12/4 20/5 22/1 23/22 23/23
27/24 41/13 42/1 62/21 75/8 76/15
76/16 77/1 92/19 111/24 112/25
112/25 114/9 115/3 115/15 115/23
116/14 116/24 117/5 120/3
N
name [32] 7/23 19/4 20/15 23/10
29/20 32/16 41/21 41/22 55/12 80/2
81/13 83/24 85/25 86/23 88/4 88/7
88/15 90/12 92/1 98/16 98/17 99/15
99/17 100/6 103/5 104/6 107/24
108/25 109/4 112/20 112/21 112/22
named [3] 14/1 23/10 62/6
names [4] 19/25 47/17 88/23 101/10
narrate [1] 81/11
nation [2] 30/3 51/2
nation's [1] 5/14
national [2] 3/18 5/13
nature [4] 25/2 34/25 62/17 81/21
navigate [1] 79/6
navigating [1] 110/2
nearly [2] 7/14 7/21
necessarily [1] 107/19
necessary [2] 28/23 108/10
need [10] 18/2 27/10 37/24 45/13
74/22 81/19 99/11 114/16 116/25
116/25
needed [4] 4/18 5/10 14/13 51/20
never [17] 6/21 11/2 17/16 17/17
18/14 20/2 22/23 26/3 27/1 28/23
29/2 29/3 29/3 66/14 69/10 87/10
95/14
new [2] 100/20 100/21
next [16] 6/3 45/4 45/9 45/24 48/12
54/19 54/20 83/20 112/6 112/7 113/11
113/12 113/22 116/6 116/9 117/13
night [4] 33/3 75/2 75/11 117/21
ninth [1] 85/6
no [62] 1/18 1/4 9/7 10/1 17/16 18/8
18/11 18/18 22/8 23/22 25/2 28/1
29/7 29/8 33/9 34/14 35/19 40/23
40/25 51/13 51/20 52/11 53/14 53/16
54/8 54/16 64/15 68/7 68/9 68/11
68/12 70/5 71/5 71/7 72/6 72/18 87/4
87/19 95/16 95/17 95/17 95/25 96/2
96/3 96/5 96/15 96/25 97/5 97/7
97/10 98/6 99/18 100/5 100/8 107/1
107/17 109/15 109/16 109/25 113/14
114/17 121/12
No. [3] 105/7 105/8 113/5
No. 14 [1] 113/5
No. 2 [2] 105/7 105/8
non [2] 34/8 39/19
non-payroll [2] 34/8 39/19
none [1] 6/18
normally [3] 34/22 47/2 76/1
NORTHERN [2] 1/1 121/6
not [118] 4/11 8/18 9/7 9/25 10/2
10/4 10/13 10/21 12/10 12/16 13/3
15/6 15/17 16/8 16/11 17/12 17/18
19/18 19/18 19/19 19/19 20/4 21/10
21/17 22/10 24/20 27/9 27/10 27/22
29/7 33/23 38/23 43/1 45/19 46/5
46/13 46/13 47/1 47/11 47/13 48/2
49/23 51/7 52/2 52/25 54/6 54/8
54/11 56/14 56/19 61/23 62/19 63/18
65/18 68/9 68/10 68/23 68/25 69/13
70/22 71/8 72/5 74/24 76/1 77/18
77/24 78/20 78/24 79/24 80/9 81/16
82/22 87/2 87/11 89/2 90/8 90/24
90/24 91/3 95/1 95/8 95/21 97/1
97/22 99/17 99/22 100/6 101/16
103/21 103/23 104/1 104/1 105/13
106/12 107/8 107/19 108/2 108/15
108/17 110/8 110/9 110/12 110/13
111/11 112/15 113/2 114/5 114/6
115/4 115/9 116/6 116/14 117/1
117/21 117/23 118/9 118/15 118/21
note [14] 1/17 21/25 22/5 38/23
56/10 56/13 58/16 59/12 59/15 59/21
59/23 67/2 69/8 78/10
Note 9 [3] 59/12 59/21 59/23
noted [1] 77/6
nothing [11] 51/10 54/14 61/10 71/20
71/25 97/11 104/15 107/3 110/15
110/19 110/21
notice [1] 22/23
noticed [1] 83/19
notices [1] 31/24
notify [1] 37/12
now [34] 2/19 3/12 12/13 15/12 18/5
20/2 20/13 23/2 23/5 23/9 23/20
27/23 28/21 41/5 41/25 48/4 56/7
59/23 67/3 77/5 78/14 79/7 79/13
80/4 82/6 88/18 99/8 100/9 101/8
101/12 103/2 109/21 116/25 117/19
number [25] 1/10 1/10 4/21 5/7 33/16
37/11 37/13 37/15 37/16 37/19 41/23
42/19 42/22 43/4 43/4 43/23 53/21
54/2 54/10 68/16 78/7 78/9 82/8
103/7 119/5
numbers [1] 7/22
numerous [3] 61/23 101/1 101/3
O
object [2] 63/12 118/14
objected [2] 78/12 82/25
objecting [1] 119/7
objection [5] 40/23 40/25 64/15
64/19 81/16
objections [2] 28/22 118/8
objects [1] 75/13
obligations [2] 44/24 50/4
observed [1] 92/7
obtain [5] 33/14 49/11 57/4 57/18
57/20
obtained [7] 9/13 50/7 52/9 52/14
57/24 66/24 85/13
obtaining [1] 57/23
obviously [3] 2/16 115/22 117/23
occurred [6] 20/4 21/22 23/2 25/14
30/9 31/13
occurs [1] 20/11
ocean [2] 18/3 18/24
odd [1] 77/16
off [17] 3/5 3/6 10/24 40/6 40/7
54/23 54/24 60/3 67/6 67/8 76/21
76/22 77/2 78/13 110/24 110/25
115/16
offered [1] 82/23
offers [1] 57/11
office [6] 32/6 32/10 89/16 96/3
107/13 107/23
officer [1] 19/15
offices [1] 121/7
official [8] 1/3 1/5 1/6 1/11 1/19
1/22 121/5 121/24
officially [1] 25/12
often [3] 7/14 12/7 84/12
oh [2] 71/16 120/5
okay [117] 2/11 2/15 3/1 41/10 53/17
54/12 62/11 62/16 62/23 65/7 65/14
65/21 65/23 66/13 66/18 66/21 68/7
68/13 68/22 69/1 69/4 69/13 69/19
69/21 69/25 70/17 71/2 71/11 71/17
71/20 71/23 72/4 72/7 72/10 72/16
72/19 73/4 73/8 73/16 73/24 74/4
74/7 74/10 74/21 75/6 75/9 76/25
79/7 80/14 81/12 82/5 82/13 82/16
83/15 84/14 84/19 85/25 86/4 86/7
86/10 86/13 86/23 87/10 87/20 87/23
88/2 88/4 88/6 88/14 88/18 88/23
89/11 89/18 89/24 90/11 90/15 91/14
92/5 92/13 93/2 93/5 93/12 93/16
93/22 93/25 94/6 94/9 94/20 94/23
95/3 95/7 95/10 96/11 99/8 99/24
100/3 102/23 103/22 103/25 104/4
104/11 104/24 107/15 108/3 108/8
131
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 132 of 138
O
okay... [12] 108/20 109/3 113/3
113/23 114/7 114/11 114/12 115/18
116/23 119/10 119/21 119/25
old [1] 112/10
once [12] 12/13 14/24 15/12 20/4
25/8 33/16 38/17 38/18 56/18 56/25
57/24 58/6
one [53] 12/4 12/22 13/3 13/14 15/6
16/2 16/18 18/12 21/25 22/21 23/8
23/13 23/14 23/19 23/21 26/19 33/10
40/6 41/22 44/24 48/12 48/12 48/19
48/20 50/16 54/13 57/10 58/24 61/7
63/15 65/14 65/15 66/10 67/7 69/6
70/2 70/17 80/5 88/12 93/1 93/11
94/3 96/3 96/11 99/9 99/9 102/24
106/11 109/12 113/2 115/19 115/19
116/25
one-button [1] 99/9
ones [4] 66/15 66/17 92/22 100/2
ongoing [4] 27/11 52/8 69/12 71/6
online [1] 33/9
only [25] 1/5 1/10 5/19 9/3 10/3
11/21 20/8 23/19 27/25 28/1 34/5
39/6 39/18 46/10 47/9 47/21 52/18
66/17 77/12 78/3 80/1 94/3 100/2
116/14 117/2
onward [1] 25/25
open [7] 58/9 58/10 73/16 81/23
85/12 105/18 121/10
opening [9] 2/5 2/7 2/9 2/19 3/12
3/15 12/1 17/14 20/19
opens [1] 73/19
operation [2] 33/24 48/13
operations [1] 50/25
opportunity [3] 5/13 19/20 59/5
opposed [1] 75/16
orchestrated [1] 25/3
order [10] 2/2 4/17 4/17 39/15 39/21
49/20 60/3 80/11 108/11 113/19
orders [3] 47/18 50/24 50/25
organize [1] 58/2
organizes [2] 58/4 60/15
original [1] 22/19
originally [1] 56/15
OS [1] 71/25
other [43] 14/3 14/8 15/8 15/9 19/24
20/1 21/16 23/16 23/18 24/4 25/9
31/14 36/5 39/17 44/7 45/16 45/20
45/21 63/18 64/12 65/12 66/7 66/14
66/15 68/10 68/10 68/11 70/14 73/24
76/19 84/7 92/21 92/22 96/4 96/23
96/23 97/9 98/25 101/4 101/18 106/11
115/20 118/15
others [1] 50/24
otherwise [1] 64/4
our [12] 5/13 32/8 33/2 37/10 37/17
53/24 54/20 76/10 80/24 81/24 117/16
119/22
out [38] 4/12 4/17 5/3 5/9 7/11
13/22 14/15 14/18 18/13 22/12 23/20
25/21 26/8 32/20 36/12 49/20 51/4
52/16 54/4 68/1 76/16 76/17 77/13
78/8 78/8 78/10 80/18 80/25 82/4
82/19 97/24 100/10 108/15 112/13
113/1 114/19 115/9 117/7
outcome [1] 117/9
outside [5] 46/12 63/13 64/1 64/13
81/6
Overruled [1] 101/23
owed [2] 13/25 17/5
own [5] 2/15 7/2 8/10 11/18 45/20
owned [2] 18/15 34/9
owner [3] 10/13 10/14 24/9
owners [8] 4/16 6/5 6/6 15/14 45/6
45/7 45/16 95/12
ownership [1] 45/5
P
p.m [3] 85/5 114/19 120/8
Pace's [2] 63/10 64/24
pads [1] 99/9
page [13] 1/10 41/10 46/15 75/16
75/17 80/21 85/19 85/20 86/5 100/20
101/7 101/9 108/15
pages [6] 22/4 78/2 80/25 101/18
110/11 110/12
paid [7] 8/15 32/18 42/12 42/15
48/14 48/14 50/9
Panasonic [2] 71/17 71/22
pandemic [10] 3/19 4/2 4/7 7/9 30/11
30/13 30/16 31/8 34/25 50/22
paper [8] 5/19 7/6 9/3 10/3 10/15
75/19 79/13 81/14
parse [4] 57/25 58/12 60/7 88/22
parsed [9] 72/24 80/3 92/14 92/15
92/21 94/1 104/1 105/20 108/24
parses [1] 60/11
part [5] 4/2 5/3 31/21 45/21 78/12
partial [2] 1/12 104/21
participants [1] 5/22
participate [1] 3/17
participation [1] 27/22
particular [11] 27/14 33/18 42/10
43/10 43/22 50/5 61/3 77/23 85/17
101/1 105/19
particularly [2] 42/6 45/1
parties [7] 3/13 18/12 20/1 77/3
82/19 114/21 115/17
partnership [1] 41/20
parts [4] 74/7 118/14 118/17 119/6
pass [1] 120/2
passed [5] 3/24 30/24 32/23 35/14
50/22
password [17] 56/20 56/21 57/14
68/24 68/25 70/1 70/4 99/17 99/20
100/1 108/10 108/13 108/17 109/22
110/7 110/10 110/16
passwords [4] 74/12 99/23 100/3
108/5
patience [1] 82/17
pattern [1] 57/13
Paul [3] 12/9 12/11 12/22
pause [4] 61/9 96/14 109/14 112/15
pausing [1] 112/16
Pavilion [1] 65/14
pay [9] 4/11 9/7 10/24 13/24 16/1
38/23 38/24 46/13 52/2
Paycheck [7] 4/3 24/7 31/7 31/14
40/16 47/23 48/25
paychecks [2] 5/10 32/17
paying [3] 33/25 34/1 38/2
payments [7] 6/2 34/9 34/11 39/20
48/23 48/24 48/24
payroll [36] 4/5 4/22 4/25 5/1 5/8
6/19 9/7 9/8 14/6 34/1 34/6 34/8
38/4 38/14 39/14 39/18 39/19 39/21
42/8 42/12 42/15 42/20 43/3 43/5
43/6 44/6 45/2 46/7 46/9 46/11 48/14
48/23 50/9 50/11 52/2 90/13
PDF [3] 1/3 79/16 81/14
PDFs [3] 80/11 80/12 80/13
pen [2] 41/13 42/1
people [16] 3/20 3/23 4/1 4/18 4/19
5/9 5/18 5/24 6/6 7/12 15/8 15/10
22/22 88/18 95/11 103/2
per [1] 16/1
percent [4] 36/23 39/14 39/21 45/8
percentage [4] 38/24 53/1 53/3 53/7
perform [3] 51/22 51/24 52/20
perhaps [1] 115/23
period [3] 1/7 39/7 113/21
permission [1] 40/2
permitted [2] 49/22 101/21
person [10] 5/21 10/16 23/9 24/19
27/3 27/9 33/10 48/16 98/22 113/2
personal [2] 31/19 34/13
personality [1] 12/11
perspective [2] 12/24 13/2
pertaining [3] 55/23 88/21 89/17
pertinent [9] 71/21 71/25 72/1 73/3
73/5 73/9 76/8 79/8 96/7
phone [18] 17/23 41/23 57/1 57/3
57/4 57/5 57/6 57/18 57/20 59/3
64/15 68/8 68/13 69/1 69/4 69/10
69/17 70/22
phones [4] 68/10 70/2 80/24 97/2
phonetic [2] 20/16 88/25
photos [1] 26/15
Phront [2] 14/10 15/16
Physical [2] 57/25 58/7
picking [1] 115/16
picture [1] 80/24
pictures [2] 58/3 60/14
piece [6] 43/7 43/24 44/9 60/10
75/19 113/17
PIN [1] 57/14
place [3] 39/2 46/8 46/11
plan [1] 5/3
planned [1] 113/16
planning [1] 119/7
play [1] 118/1
played [1] 12/9
playing [3] 20/13 118/6 118/10
plays [1] 117/7
please [16] 2/17 28/11 29/20 44/4
47/20 48/1 48/21 50/17 54/19 55/11
61/8 67/14 86/19 107/2 111/10 111/12
pled [4] 23/14 23/18 23/21 24/12
plus [3] 43/12 112/16 115/20
point [18] 22/12 23/20 37/9 41/25
47/15 47/19 47/25 48/1 56/22 69/16
87/2 97/24 100/10 101/19 116/16
116/21 118/13 119/8
pointing [4] 41/13 41/14 42/2 47/15
points [1] 107/5
police [1] 2/15
policy [1] 31/24
pop [1] 90/3
pops [1] 94/9
portable [12] 58/8 58/11 58/15 58/19
59/11 59/17 59/21 60/19 60/23 72/15
72/16 72/23
portion [3] 1/9 6/7 62/21
portions [7] 75/21 77/13 78/4 79/11
80/1 117/17 118/8
position [2] 31/12 78/18
positions [2] 21/16 27/17
possible [8] 5/9 49/21 51/5 99/2
106/14 106/17 106/20 107/16
Possibly [1] 70/3
post [3] 112/24 114/24 115/24
posted [1] 33/2
potential [1] 53/6
potentially [4] 63/21 81/3 88/9
118/4
pounds [1] 112/9
PPP [56] 4/3 4/4 4/12 4/18 4/20 5/2
5/4 5/12 5/18 6/13 7/10 7/12 7/19
7/24 8/2 8/8 8/12 8/20 9/1 9/13 9/14
10/17 11/9 13/6 13/9 14/12 15/21
17/3 24/6 24/7 24/8 26/5 27/10 27/22
31/17 31/20 32/12 32/14 32/19 32/25
33/7 34/5 34/12 35/1 36/23 39/3
40/20 41/10 43/8 43/11 43/16 43/25
44/22 46/14 48/11 92/24
PPP loan [13] 5/2 7/24 8/12 8/20 9/1
14/12 17/3 27/10 34/12 43/8 43/25
44/22 92/24
PPP loans [7] 5/18 13/9 24/6 24/8
26/5 34/5 36/23
pre [2] 13/20 91/21
pre-dates [1] 91/21
pre-existing [1] 13/20
preference [1] 81/24
premium [3] 57/8 57/9 57/12
preparation [1] 1/18
prepare [1] 24/8
prepared [5] 58/19 59/11 60/23 79/11
80/1
preparing [1] 24/6
present [2] 19/13 20/15
presented [1] 28/10
presenting [1] 18/6
presently [1] 45/14
pressed [1] 94/19
pressure [1] 116/21
presumption [1] 28/19
pretend [1] 6/5
pretended [2] 6/6 10/13
previous [1] 45/16
previously [1] 83/12
primarily [1] 32/8
primary [3] 19/1 32/16 41/23
principal [2] 46/8 46/11
principle [1] 39/5
print [2] 77/13 80/25
printed [5] 74/24 75/19 78/8 78/10
91/20
printing [1] 78/7
132
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 133 of 138
P
printout [4] 75/16 75/18 79/14 80/18
printouts [4] 76/4 77/7 77/23 78/12
prior [4] 42/13 42/15 46/3 53/16
probably [4] 83/19 113/11 115/17
119/19
problem [1] 112/17
problematic [1] 77/14
procedural [1] 31/24
procedure [2] 112/13 114/15
procedures [1] 115/3
proceedings [11] 1/10 3/6 40/7 54/24
67/8 67/11 76/22 110/25 121/10
121/14 121/18
proceeds [9] 8/24 9/6 9/10 39/6
46/14 47/9 47/21 52/18 52/25
process [12] 34/22 35/23 39/2 55/22
57/22 82/17 98/25 112/1 112/3 112/6
112/7 112/8
processing [1] 53/12
produced [4] 73/12 73/15 75/7 117/20
product [5] 57/8 57/25 58/9 60/6
60/8
products [2] 57/11 107/23
profile [4] 83/24 84/10 84/12 108/18
profiles [2] 83/16 84/13
program [37] 4/2 4/3 4/6 4/12 4/18
5/8 5/12 6/13 6/15 7/10 7/13 8/8
24/7 27/17 31/7 31/8 31/10 31/11
31/14 31/15 32/1 32/19 32/20 32/21
32/25 34/20 35/15 40/16 40/20 46/24
47/11 47/24 48/25 49/19 50/5 50/19
51/3
programs [6] 30/15 30/21 31/1 31/3
31/6 32/8
prohibited [1] 1/12
project [9] 10/10 10/12 10/19 11/3
21/15 26/7 26/10 26/18 26/22
promoter [1] 14/20
prompt [1] 107/24
proof [2] 28/15 28/16
proper [1] 52/9
properly [2] 52/14 53/25
property [2] 26/9 88/8
proposal [2] 10/18 10/20
propose [1] 81/5
proprietorship [1] 41/20
protected [4] 56/20 57/14 57/14
57/15
Protection [7] 4/3 24/7 31/7 31/14
40/16 47/23 48/25
prove [2] 21/5 28/24
proven [1] 28/16
provide [9] 10/20 30/4 34/20 36/7
38/1 47/5 51/3 65/9 65/23
provided [27] 31/25 35/1 36/6 37/24
44/25 46/20 49/6 49/7 52/19 54/9
56/9 63/16 64/15 66/3 66/22 68/7
68/24 68/25 69/16 72/20 73/25 76/3
95/11 95/11 95/14 95/21 117/22
provides [2] 36/19 38/22
public [2] 31/25 33/1
publicly [1] 35/7
publish [2] 34/23 41/3
published [3] 35/2 35/8 35/9
publishes [1] 34/20
publishing [1] 41/5
pull [5] 59/14 60/16 80/21 82/18
104/18
pulled [2] 61/5 105/5
pulling [1] 80/16
punishable [1] 49/11
purchase [1] 86/21
purported [2] 6/5 9/13
purpose [9] 16/7 32/14 32/16 44/3
44/10 64/8 64/14 79/22 97/18
purposes [8] 34/4 34/4 34/6 42/24
44/6 47/10 47/22 49/1
pursuant [1] 30/18
push [1] 79/21
put [8] 18/3 31/12 60/19 78/14 84/12
98/16 112/4 115/4
puts [1] 60/12
puzzle [1] 113/18
Pyfrom [10] 8/4 8/7 8/17 14/2 89/1
89/5 89/18 91/15 95/24 103/14
Pyfrom-Foster [5] 8/4 8/7 8/17 14/2
95/24
Q
QATO1 [1] 68/14
quality [1] 54/6
quarterly [1] 38/15
queries [5] 80/3 92/14 92/21 94/1
105/21
query [2] 92/15 108/24
question [4] 46/6 64/16 98/4 108/12
questioned [1] 26/20
questioning [2] 53/18 64/17
questions [20] 19/23 19/23 19/24
28/22 31/24 45/9 45/14 45/20 45/24
45/24 46/3 51/13 64/5 82/21 96/15
97/24 109/15 109/16 113/4 113/13
quick [1] 25/6
quickly [6] 3/22 4/13 4/17 5/3 49/20
51/4
quite [1] 118/4
R
radio [2] 12/6 12/11
random [1] 53/5
range [2] 82/8 82/9
rarely [1] 14/2
rate [1] 36/22
re [1] 105/18
re-save [1] 105/18
reach [1] 117/9
reached [1] 7/11
read [15] 46/17 47/14 47/16 47/19
48/1 48/19 48/20 49/5 76/6 77/25
78/16 80/15 80/19 100/23 111/18
reads [1] 28/11
ready [1] 2/4
real [2] 26/7 26/22
really [4] 74/21 74/24 79/22 110/14
Realtime [1] 121/5
reason [2] 21/6 99/11
reasonable [6] 11/23 24/25 28/17
28/18 28/20 28/25
reasons [1] 24/4
receive [10] 6/7 15/13 43/11 54/8
56/15 63/19 70/1 72/5 96/24 97/8
received [21] 6/9 9/4 9/20 13/6
15/12 15/14 15/20 17/1 17/17 26/4
29/4 43/15 45/21 50/2 51/24 56/18
63/18 66/14 66/20 67/24 102/6
receiving [3] 15/9 16/7 19/10
recess [2] 67/11 120/8
recipient [1] 34/12
recognize [1] 40/13
recollection [2] 63/3 69/22
record [28] 2/23 3/5 3/6 3/8 29/21
40/6 40/7 40/9 54/23 54/24 55/1
55/12 67/7 67/8 76/21 76/22 76/24
76/25 77/2 84/19 90/12 93/25 103/11
110/24 110/25 111/4 111/18 121/18
recording [3] 19/14 20/7 20/13
records [3] 17/23 100/15 106/3
recovery [2] 112/5 112/8
recross [3] 107/4 107/6 110/1
RECROSS-EXAMINATION [1] 107/6
recruiters [2] 6/3 6/7
recruiting [1] 7/11
redirect [4] 54/15 97/13 97/20
109/19
reduced [1] 121/15
refer [2] 68/17 78/3
reference [4] 18/6 26/11 26/19 77/24
referenced [3] 21/22 23/3 23/11
references [1] 22/5
referencing [1] 1/10
referred [4] 31/17 37/16 66/15 87/8
referring [3] 78/6 85/22 85/22
refinance [1] 43/17
refined [1] 79/2
reflect [1] 12/18
reflected [2] 84/25 86/13
refresh [2] 63/3 69/21
refundable [4] 114/2 114/3 114/4
114/6
regarding [1] 35/1
Register [1] 35/10
regular [2] 27/17 38/16
Reid [2] 112/22 112/24
relate [1] 38/14
related [9] 18/10 22/25 23/12 26/12
47/10 47/22 48/10 68/8 95/15
relationship [3] 7/8 13/21 28/2
relative [1] 10/15
relevant [8] 58/14 72/2 72/25 75/21
76/10 77/18 77/18 79/11
relied [4] 4/19 6/8 46/25 49/21
relief [5] 3/23 30/22 34/25 51/3
51/5
relieve [1] 116/10
relieving [1] 115/18
rely [5] 5/4 49/22 50/19 51/6 73/24
relying [1] 50/14
remain [1] 2/25
remaining [1] 102/24
remember [8] 12/5 14/5 25/13 53/18
65/18 69/20 71/16 71/24
remembers [1] 83/22
reminded [2] 67/4 111/3
rent [5] 4/5 9/7 9/8 34/10 39/19
reopen [1] 108/16
Repeat [1] 88/12
repeatedly [1] 15/1
replaced [1] 22/22
replenish [1] 31/12
report [47] 62/22 62/23 62/23 64/25
65/18 66/16 70/18 72/11 72/17 72/20
73/2 73/8 73/8 73/15 73/16 74/2
74/23 75/6 75/8 75/20 75/23 76/7
78/23 78/25 79/18 79/22 81/9 81/10
81/12 81/12 83/9 83/10 83/15 90/13
92/19 96/7 98/5 99/19 99/24 101/13
101/17 101/19 106/23 106/25 108/6
110/14 110/15
reported [1] 121/9
reporter [9] 1/6 1/11 1/17 1/22 1/22
121/4 121/5 121/5 121/24
REPORTER'S [1] 121/2
represent [2] 61/19 104/4
representations [2] 5/4 50/13
representative [1] 6/13
requested [2] 36/10 61/20
required [11] 24/25 39/14 47/17
48/11 49/23 50/1 50/5 51/24 51/24
52/2 52/20
requirement [2] 35/16 35/17
requirements [6] 32/1 33/19 33/21
35/5 39/17 51/21
requires [1] 75/25
Reservation [14] 8/25 9/2 9/5 9/6
9/11 9/21 10/11 10/14 10/19 11/3
19/24 23/6 24/5 24/9
residence [7] 18/17 27/6 46/8 46/12
62/18 67/23 87/12
Resource [5] 17/19 19/5 23/7 26/6
27/19
Resources [3] 9/14 9/17 9/20
respects [1] 49/9
responded [1] 53/19
response [2] 30/15 51/19
responsibilities [1] 52/8
responsibility [1] 28/24
rest [6] 11/1 12/10 12/14 17/10
112/21 114/20
restricted [1] 1/6
result [2] 93/13 101/3
resulted [2] 6/1 30/20
results [5] 79/2 86/14 90/3 93/3
94/4
retain [1] 48/22
retirement [1] 17/7
retrieval [1] 112/3
retrieve [1] 112/5
return [2] 11/21 14/9
retype [1] 108/13
review [20] 44/24 50/5 50/7 50/10
51/22 51/25 52/20 52/23 52/25 53/11
53/16 58/5 58/13 59/5 62/21 72/24
75/3 83/13 118/7 119/9
reviewed [5] 53/2 53/5 53/5 75/11
102/8
reviewing [1] 62/23
Richland [1] 88/8
ridden [1] 22/13
133
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 134 of 138
R
right [84] 2/4 3/3 3/8 29/10 36/19
42/4 42/20 42/22 43/12 43/23 45/5
47/15 52/5 53/9 53/25 54/17 62/3
62/14 66/10 67/10 69/2 69/5 69/11
69/17 70/10 70/15 71/2 71/11 73/17
74/19 74/22 74/25 75/4 76/11 80/4
82/3 82/15 84/2 86/5 89/3 89/25 90/3
90/3 90/6 90/16 91/15 91/21 91/23
92/6 94/1 94/14 95/5 95/12 95/12
95/15 97/22 98/12 99/15 99/25 100/16
102/1 102/14 103/18 103/25 105/8
105/8 105/9 108/14 108/17 108/18
109/5 110/16 111/2 111/7 111/13
111/15 112/23 113/3 114/11 115/12
116/24 116/25 119/25 120/4
ringleader [1] 13/6
Road [1] 64/24
role [9] 5/21 11/8 11/9 31/19 32/4
32/9 38/21 55/17 57/4
rolled [1] 32/19
room [1] 114/10
routinely [1] 28/3
row [5] 86/8 87/8 88/6 89/19 93/5
rows [1] 100/13
RPR [1] 121/23
rule [11] 2/13 34/16 34/19 34/19
34/21 34/22 34/23 35/20 35/20 47/24
48/25
rule-making [1] 34/22
ruled [1] 118/15
rules [10] 31/23 35/1 35/2 35/4 35/7
35/11 45/13 47/7 47/11 50/1
rung [1] 6/3
S
S.W [1] 1/23
S20 [1] 70/20
said [11] 9/23 13/18 49/19 56/18
68/22 96/6 104/7 105/12 113/20 119/3
121/14
salaries [5] 34/1 34/7 38/3 48/14
50/9
same [15] 7/22 23/15 23/17 23/24
63/13 66/23 66/24 84/6 91/1 91/4
98/19 100/17 103/11 106/10 106/10
Samir [1] 1/16
sample [1] 53/5
Samsung [9] 56/10 56/13 58/15 59/11
59/14 59/20 59/23 70/17 70/20
Saraliene [1] 1/19
satisfies [1] 80/19
save [6] 83/20 86/21 95/2 104/4
104/8 105/18
saved [18] 14/25 74/12 74/14 94/21
94/24 99/20 99/23 101/14 101/25
102/4 102/14 104/5 108/5 108/10
108/17 110/8 110/8 110/16
saves [1] 89/16
saw [1] 94/19
say [15] 8/17 12/13 12/21 16/19
27/24 35/11 39/12 56/25 79/2 91/2
100/12 108/15 109/6 112/8 118/21
saying [3] 47/6 79/6 119/1
sayings [1] 12/18
says [20] 44/2 48/4 53/19 61/4 87/15
88/7 88/7 89/5 89/18 90/12 91/14
91/23 94/13 99/15 100/15 102/17
103/4 103/14 103/14 104/1
SBA [36] 6/13 30/15 30/20 31/1 31/3
32/4 32/9 32/12 36/10 36/19 36/25
37/2 37/4 37/6 37/8 37/11 37/12
37/15 37/19 38/22 38/24 40/19 44/17
45/16 47/21 49/11 50/1 50/14 52/12
52/22 52/23 53/2 53/11 53/16 54/2
54/8
SBA's [3] 33/14 35/8 38/21
scan [1] 98/21
scene [2] 65/3 65/7
scheme [3] 11/8 13/6 15/8
school [1] 12/7
scope [2] 63/13 64/1
score [1] 23/18
scores [1] 18/1
screen [14] 41/4 41/6 41/7 42/2 77/7
78/7 79/17 80/22 80/25 82/5 83/9
86/2 106/15 106/24
screens [2] 77/21 77/23
screenshot [3] 94/18 94/23 95/1
scroll [7] 86/4 90/11 91/10 92/8
93/22 101/13 104/11
scrolling [1] 103/18
search [23] 63/8 64/12 64/23 67/23
68/3 74/2 74/19 75/18 79/7 80/3
85/21 85/23 90/2 92/14 92/15 92/21
92/22 93/11 94/1 105/21 105/23 106/4
108/24
searched [4] 92/17 92/23 106/5 106/6
searches [3] 80/6 92/20 93/13
searching [2] 92/24 108/25
seated [5] 3/3 67/13 67/16 82/15
111/8
second [20] 20/14 22/15 22/16 23/2
23/3 41/24 42/1 46/15 48/1 49/4
54/13 87/23 91/25 96/12 100/18 106/9
106/10 106/10 106/11 109/12
seconds [3] 76/18 100/14 119/13
secret [1] 26/2
secrets [8] 25/17 25/23 25/23 25/23
26/2 26/2 26/2 28/4
section [11] 45/4 46/17 48/4 84/5
87/24 88/4 88/15 101/12 101/25 103/4
108/24
sections [1] 79/2
Security [1] 30/22
see [58] 4/20 5/12 6/20 6/22 7/2 7/4
7/5 7/24 8/3 8/7 8/25 9/5 10/22 14/7
15/21 15/23 16/2 16/5 17/11 17/24
18/19 19/20 20/22 23/9 26/14 26/15
41/7 41/14 42/1 54/7 75/22 76/9 77/6
78/6 78/11 78/16 79/2 84/13 87/15
90/23 90/24 91/7 91/12 92/19 93/5
100/4 103/5 103/7 105/8 106/1 106/8
108/20 109/8 114/23 117/4 117/6
118/13 120/4
seeing [4] 69/21 79/19 80/7 108/2
seek [1] 76/5
seeking [1] 78/24
seem [1] 77/19
seems [4] 45/5 64/1 77/16 81/22
seen [2] 76/12 118/20
seize [1] 72/3
seized [13] 11/1 62/1 62/17 62/18
63/5 65/12 66/7 67/22 68/2 69/4 70/7
87/10 87/11
self [4] 45/5 45/12 47/1 51/7
self-certifications [2] 47/1 51/7
self-certifies [1] 45/12
self-explanatory [1] 45/5
send [3] 16/25 78/20 98/11
senior [1] 21/15
sense [4] 76/6 108/12 116/9 116/24
sent [12] 10/9 13/10 15/10 16/19
16/20 16/21 16/22 62/9 62/14 65/10
78/2 98/11
sentence [2] 47/15 48/21
sentences [1] 49/5
separate [3] 9/21 19/2 108/18
separately [2] 23/25 24/1
servers [1] 37/6
serves [1] 42/24
service [1] 9/18
Services [5] 17/19 19/5 23/7 26/6
27/19
session [3] 1/5 84/22 85/10
set [10] 7/2 16/6 41/13 41/24 42/1
42/17 45/9 45/24 63/13 81/18
several [3] 45/18 57/11 70/14
share [1] 116/1
shared [1] 111/13
she [74] 8/4 8/5 10/8 10/10 10/10
10/11 10/13 10/18 10/19 10/20 10/21
10/22 10/23 10/24 11/6 16/1 17/16
17/17 17/17 17/18 19/11 19/21 19/25
20/2 20/16 20/19 21/10 21/13 21/14
21/18 22/3 22/20 25/1 25/1 26/5
26/20 26/23 27/9 27/10 27/10 27/14
27/16 27/20 27/25 28/2 28/25 29/2
29/3 29/4 29/8 63/15 63/15 63/18
63/18 75/11 80/2 81/11 81/14 81/15
81/17 89/20 89/21 91/17 97/25 98/16
112/3 112/4 112/6 112/8 112/8 113/8
114/9 114/20 117/2
short [1] 12/12
shorter [1] 80/3
shortly [1] 14/11
should [8] 19/21 20/6 20/10 75/24
79/10 79/17 113/9 116/2
shove [1] 79/21
show [32] 5/11 5/16 7/7 7/12 9/24
9/25 10/2 10/4 11/2 11/5 13/19 17/4
19/6 19/16 21/7 38/2 42/24 44/5 45/1
50/8 51/25 63/18 64/8 77/21 78/19
79/16 80/25 81/17 81/17 101/7 101/9
101/12
showed [4] 13/15 15/1 27/5 80/2
showing [5] 19/21 40/4 79/22 83/23
100/9
shown [2] 81/20 86/7
shows [7] 81/13 89/21 89/23 92/23
99/19 106/23 110/15
shut [1] 3/20
side [2] 78/6 79/1
signer [1] 16/8
significance [1] 42/23
significant [3] 15/5 50/25 51/1
similar [1] 21/16
similarly [1] 60/7
simple [1] 12/25
simply [1] 64/14
since [2] 25/25 109/21
single [2] 7/14 13/4
sir [15] 96/25 100/8 100/25 101/11
102/2 102/7 102/9 102/12 102/19
103/6 103/9 103/13 104/10 105/10
106/2
sister [1] 114/9
sit [2] 111/10 111/11
sitdown [1] 19/19
site [1] 94/18
sitting [2] 22/14 98/5
situation [1] 117/8
six [2] 102/10 102/11
size [2] 33/22 42/25
ski [3] 115/8 115/9 115/10
skiing [2] 113/18 114/5
skimming [1] 56/6
skipped [1] 32/2
slight [1] 108/22
slightly [1] 35/24
sloppiness [1] 22/25
sloppy [1] 22/24
slow [1] 99/12
slower [1] 35/24
small [13] 4/13 4/15 4/16 5/6 6/13
12/6 20/25 20/25 21/2 21/10 29/25
30/1 30/3
smaller [1] 80/5
software [6] 55/23 57/2 57/6 57/7
60/10 72/24
sole [1] 41/20
some [39] 21/10 21/18 25/6 26/9
26/13 26/15 26/19 27/8 27/9 35/12
35/15 36/15 50/24 53/4 53/5 53/11
56/21 68/22 69/16 74/10 76/4 77/17
77/18 80/1 93/2 96/23 97/24 97/24
99/10 103/22 109/17 111/14 113/2
114/25 115/1 117/19 118/4 119/13
119/13
somebody [7] 21/17 80/22 99/5 104/8
106/17 106/18 106/20
somehow [3] 57/14 80/18 116/16
someone [15] 14/19 16/24 21/3 22/11
24/12 58/4 62/6 67/2 76/7 94/23
98/17 106/21 108/24 109/3 109/22
something [16] 11/4 20/16 21/10
38/10 39/1 44/2 54/4 64/2 71/17
75/15 78/3 80/9 101/14 103/18 116/18
117/3
sometimes [3] 12/15 37/16 108/16
somewhere [1] 98/11
soon [1] 11/15
sorry [13] 2/8 62/21 64/25 65/19
76/18 85/8 88/12 95/19 104/18 108/20
111/12 115/10 117/11
sort [8] 12/8 12/18 16/17 58/1 81/25
98/21 118/2 118/10
sorts [1] 15/7
sound [2] 62/19 86/15
sounds [4] 13/13 62/3 64/19 111/20
134
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 135 of 138
S
source [8] 17/18 19/9 19/11 21/8
21/19 29/5 88/2 88/16
sources [1] 15/9
speak [2] 16/14 114/22
special [4] 55/18 56/5 96/10 117/15
specific [4] 34/3 48/8 107/10 107/13
specifically [8] 48/10 50/8 56/10
90/21 92/20 95/1 102/4 117/13
specified [3] 47/10 47/22 48/24
speculate [2] 14/21 87/22
spell [2] 29/20 55/12
spend [1] 11/5
spending [2] 11/4 11/18
spent [4] 4/9 7/3 10/22 15/22
spoken [1] 63/20
spot [1] 99/24
spouse [1] 25/20
spreadsheet [2] 92/3 105/18
stage [3] 52/12 53/8 53/10
stamped [1] 7/17
stand [1] 54/22
standard [1] 42/25
standing [1] 81/4
start [4] 32/20 54/19 83/21 105/18
started [5] 4/8 14/12 32/21 43/16
93/10
starting [1] 5/16
starts [2] 93/5 113/20
state [6] 29/20 47/12 47/17 48/3
55/11 103/18
statement [10] 2/10 3/15 12/1 13/12
16/15 16/16 17/14 49/11 117/16
117/18
statements [14] 2/5 2/19 3/12 11/11
20/18 20/19 20/24 27/12 38/6 44/20
47/16 118/8 118/17 118/18
states [11] 1/1 1/4 1/11 1/23 29/11
29/25 30/10 46/7 46/10 121/6 121/11
static [1] 75/20
station [1] 12/6
status [1] 111/20
statute [3] 30/18 30/20 42/18
stay [5] 3/20 5/10 50/25 109/23
114/9
stayed [1] 14/2
staying [3] 114/8 114/9 114/10
stealing [1] 8/14
Steamboat [1] 113/18
Stenograph [1] 121/9
stenographic [3] 1/17 121/2 121/4
step [4] 32/2 36/18 54/18 110/22
steps [3] 51/8 51/20 60/2
stick [1] 120/5
sticking [1] 76/15
still [7] 35/20 69/12 69/13 71/6
91/1 108/16 114/9
Stites [6] 18/16 20/14 26/20 27/5
96/10 117/15
stolen [4] 6/10 10/6 11/13 11/19
storage [2] 56/11 59/25
stories [4] 12/12 12/15 12/16 12/22
story [9] 12/10 12/14 12/24 13/19
17/10 17/11 24/22 25/6 115/16
stranger [1] 12/19
streamlined [4] 46/25 49/20 51/6
64/7
stress [2] 115/4 115/5
structure [1] 41/19
stuff [4] 12/8 79/5 81/19 98/15
subexhibits [1] 59/9
submission [1] 5/23
submit [4] 5/18 33/11 52/22 64/4
submitted [10] 6/19 6/21 7/3 7/24
15/13 36/11 37/2 37/3 37/5 38/16
subpoenaed [1] 10/21
subsections [1] 74/18
subsequent [2] 35/13 68/7
subset [5] 81/21 86/13 90/9 94/1
95/7
successful [4] 21/14 103/21 103/23
104/2
successfully [1] 104/15
succession [1] 101/4
such [4] 39/19 45/14 49/2 56/5
sudden [2] 9/19 10/21
suffering [2] 3/23 50/23
suggest [2] 20/5 80/11
suggested [1] 115/17
suggests [2] 32/16 109/10
sum [1] 4/15
summer [1] 12/4
Sunday [3] 113/19 113/24 114/18
superseding [5] 22/16 22/16 22/17
22/18 23/3
supervised [1] 5/22
support [5] 5/25 7/19 38/3 38/12
52/1
supporting [14] 8/1 33/11 37/24 38/1
38/7 38/11 44/19 44/20 44/25 49/8
50/7 50/11 51/25 54/9
supports [1] 13/4
supposed [8] 41/16 45/6 45/7 48/16
49/15 51/22 113/18 113/24
sure [13] 12/10 39/25 50/6 51/23
52/9 82/7 96/13 104/20 105/12 114/5
114/6 114/17 116/15
Surface [1] 70/25
surgery [10] 112/4 112/24 113/7
113/10 114/15 114/24 115/23 115/25
116/5 116/8
survive [1] 4/16
suspended [1] 45/15
sworn [3] 29/15 55/5 55/8
system [12] 33/14 37/10 37/11 37/17
37/18 53/20 53/25 54/2 54/2 90/21
91/5 109/23
systems [1] 109/23
T
tab [2] 102/8 103/2
table [1] 89/10
tables [1] 18/3
tablet [1] 66/8
tablets [1] 68/11
tabs [1] 85/12
tagged [1] 73/2
tail [1] 20/8
Tails [1] 71/25
Tails OS [1] 71/25
take [18] 3/19 5/13 12/23 12/25 32/2
51/8 54/20 67/3 67/6 75/24 76/13
80/24 106/14 114/25 115/1 119/16
119/17 120/4
taken [1] 120/8
takes [1] 55/22
taking [3] 76/18 93/10 106/13
Tal [1] 1/16
talk [16] 19/14 19/21 20/10 21/21
24/2 26/21 27/6 32/19 58/24 62/16
66/19 77/18 78/24 80/16 81/7 111/5
talked [8] 35/22 44/19 48/7 61/24
95/10 98/19 98/20 101/6
talking [7] 18/12 36/4 46/3 64/11
77/22 98/15 109/21
target [1] 46/1
tax [9] 6/19 6/20 7/17 8/6 14/6 14/9
14/18 38/12 38/15
taxes [4] 34/1 38/14 48/14 50/9
taxpayer [1] 41/22
TE [2] 93/6 106/6
team [1] 31/21
tech [1] 80/23
technical [1] 54/3
technology [1] 1/18
Ted [1] 1/23
teenager [1] 12/3
TELD [1] 93/6
TELDR [2] 93/7 93/10
TELDRIN [58] 1/7 3/16 5/24 7/8 7/11
7/13 8/1 8/3 8/9 8/19 13/3 13/7
13/10 13/12 13/20 13/22 13/24 14/1
14/2 14/15 14/16 14/23 15/6 15/18
15/23 16/2 16/8 16/12 16/14 16/16
17/1 17/5 17/6 17/11 80/3 80/6 81/13
84/16 85/2 85/20 85/25 86/2 86/5
86/14 87/2 89/2 93/2 93/14 93/15
94/4 94/9 94/11 96/1 99/20 100/6
105/23 110/6 121/12
Teldrin's [2] 15/4 108/25
tell [53] 4/19 6/18 10/11 12/23 13/5
13/10 13/12 22/20 24/20 25/1 28/8
32/14 33/5 37/1 38/6 39/13 39/25
42/4 48/8 56/25 58/22 59/5 59/8
59/19 60/21 73/11 83/16 84/4 84/14
84/24 85/3 85/10 85/15 85/18 86/1
87/23 88/18 88/23 89/13 90/20 92/15
93/9 93/20 98/5 103/10 105/16 105/16
106/4 110/7 110/10 111/19 114/17
119/22
tells [2] 103/20 117/1
ten [1] 17/8
tens [1] 13/23
tenth [1] 85/6
term [3] 34/15 36/23 58/8
termed [1] 89/15
terms [5] 36/22 44/19 46/21 57/4
74/4
testified [3] 29/15 55/5 55/8
testify [7] 24/17 24/19 26/15 26/24
27/1 27/4 118/3
testifying [1] 2/24
testimony [5] 21/13 25/7 27/7 53/17
68/23
text [6] 6/22 17/23 18/10 18/11
58/24 59/1
texting [1] 119/22
texts [1] 111/19
than [22] 6/9 7/16 7/20 7/25 9/4
9/20 12/19 12/23 13/1 23/16 24/24
27/15 27/16 33/23 43/1 66/15 69/6
80/23 112/1 119/19 119/20 119/23
thank [52] 3/4 3/9 3/10 11/24 12/2
17/13 29/9 29/10 40/10 49/13 51/11
54/14 54/17 55/3 61/12 61/14 63/4
64/21 66/6 66/13 66/18 67/10 67/13
67/17 67/20 72/4 73/11 82/16 82/16
83/7 84/1 85/10 86/17 87/5 89/11
92/13 95/3 95/23 97/12 97/19 103/1
105/2 106/16 107/3 108/3 109/15
110/18 110/19 110/23 111/9 115/12
115/13
that [747]
that's [67] 3/11 19/14 20/10 22/10
22/10 22/12 23/3 24/1 24/7 24/25
26/12 42/6 42/16 42/19 43/3 43/9
45/5 48/17 53/8 53/10 56/10 56/17
64/17 66/12 68/1 68/16 70/11 72/13
72/13 72/16 72/18 73/11 74/19 77/14
78/25 82/1 83/23 84/12 84/20 84/22
86/5 86/7 88/14 89/4 90/5 91/6 91/8
91/22 92/3 92/11 92/20 93/6 98/4
98/22 101/5 103/11 104/22 105/21
106/24 107/25 109/9 110/17 112/11
112/14 113/17 114/18 116/22
theft [1] 56/6
their [40] 3/21 4/14 4/16 4/22 5/10
11/8 11/18 11/18 11/19 13/4 20/19
22/25 24/15 25/3 25/22 31/12 32/17
33/11 34/7 36/8 42/12 42/14 42/17
45/16 46/12 50/25 59/9 79/11 79/12
79/15 79/23 79/24 80/5 80/11 106/13
106/17 109/22 109/22 117/10 118/11
them [38] 16/14 23/25 31/12 32/18
44/24 46/13 46/13 47/18 49/15 63/23
67/24 68/1 78/8 78/9 78/10 78/21
79/19 80/1 80/25 81/17 81/18 81/18
81/21 86/3 95/11 106/9 106/10 107/17
107/20 117/21 117/23 118/1 118/1
118/7 118/14 119/3 119/9 119/22
then [70] 5/1 7/18 9/19 13/9 15/13
21/2 21/11 33/13 33/17 36/10 37/13
37/21 38/24 42/11 42/16 42/22 43/23
47/25 52/21 53/1 54/2 55/14 57/24
58/7 58/8 58/12 60/6 60/22 61/23
62/11 62/14 65/9 66/19 71/13 71/17
73/21 73/24 77/22 79/3 79/5 79/6
80/8 80/13 81/11 81/14 81/20 84/1
86/10 88/7 89/5 91/17 91/20 91/25
92/14 93/12 93/19 94/6 104/8 105/17
106/4 106/5 106/5 107/25 108/1
108/15 109/5 109/7 112/5 112/7 113/9
there [102] 13/18 15/7 15/17 18/8
18/11 18/18 20/14 20/25 21/5 21/11
22/7 22/17 22/18 23/11 27/22 30/8
33/7 33/18 34/3 34/23 35/13 36/11
36/18 37/23 39/1 39/2 39/17 41/17
41/18 42/22 44/2 51/1 51/19 52/8
52/12 53/3 53/4 53/11 60/13 62/6
135
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 136 of 138
T
there... [62] 63/8 64/15 66/1 66/7
67/11 69/4 69/6 69/7 70/14 70/22
70/25 71/11 71/13 71/20 73/6 73/16
73/21 77/20 78/6 78/7 79/3 79/7
79/14 82/8 85/3 85/25 90/3 90/11
91/13 92/11 94/19 97/17 99/5 99/19
99/24 100/6 100/12 100/13 101/14
101/25 102/13 102/17 103/4 103/22
105/5 106/8 106/23 107/16 108/2
108/22 110/15 112/5 112/18 112/19
112/20 112/23 113/15 114/16 115/22
117/19 118/14 118/23
there's [4] 48/4 92/19 102/24 103/18
thereafter [1] 14/11
these [60] 5/20 6/23 6/24 7/1 7/2
7/4 7/6 8/5 11/7 11/22 14/16 16/19
16/20 16/21 16/22 16/25 18/2 18/3
18/7 19/5 19/21 21/19 22/1 24/8
24/25 25/13 26/1 26/3 27/21 27/25
28/8 29/8 39/4 45/14 45/25 47/4 48/8
48/10 49/14 50/14 51/5 53/13 53/15
61/3 78/7 79/8 80/8 87/14 87/15 89/9
90/19 92/22 100/1 100/11 101/10
101/18 102/4 110/1 110/1 110/11
they [154]
they're [4] 43/14 52/5 79/7 93/16
thing [10] 12/4 21/25 81/15 81/25
83/22 84/6 84/7 95/8 115/19 115/19
things [11] 12/7 12/20 25/19 25/19
25/19 64/12 73/21 81/21 97/24 112/15
112/16
think [39] 14/16 16/16 27/14 51/19
53/17 53/19 63/17 64/4 66/7 67/24
76/5 76/8 77/10 77/13 78/1 78/5
78/17 79/15 79/23 80/10 81/16 81/19
82/1 94/12 98/1 100/10 101/17 111/17
112/12 114/6 115/6 116/3 116/8
116/12 117/19 118/3 118/3 118/23
119/5
thinks [1] 78/19
third [1] 48/20
this [200]
Thom [1] 88/25
Thomas [33] 5/17 5/22 6/3 7/7 7/11
7/14 7/24 8/8 8/11 8/15 8/20 9/1
13/6 13/10 13/20 13/22 13/24 14/11
15/8 15/20 16/7 17/2 24/10 24/11
27/3 62/2 66/20 68/8 68/9 83/25
86/24 89/1 101/10
Thomas's [6] 8/12 14/9 14/23 67/23
70/2 87/12
those [80] 7/18 7/21 8/2 11/15 12/15
13/8 13/14 14/6 14/18 15/3 15/6
15/10 15/15 15/18 15/19 16/18 18/21
21/2 22/21 23/22 25/10 27/12 27/12
28/12 31/6 33/21 35/4 35/4 35/7 42/4
44/5 44/20 45/10 45/11 46/4 46/19
49/5 49/17 49/22 54/3 55/25 62/11
64/10 65/14 66/17 66/22 66/24 70/12
70/17 71/21 72/22 73/24 74/18 80/13
82/25 83/1 83/1 84/20 85/3 85/7 89/7
90/20 91/4 93/11 93/13 93/23 95/12
99/9 99/11 102/23 106/1 106/3 107/11
107/16 110/12 112/24 114/24 115/3
118/6 118/10
though [4] 9/3 10/14 114/14 118/18
thought [5] 111/21 113/21 113/22
117/20 119/23
thoughts [2] 115/15 116/1
thousands [1] 13/23
three [5] 12/23 13/1 112/6 112/16
115/19
through [36] 11/13 22/14 25/24 27/7
33/8 35/24 37/10 45/9 45/25 47/14
53/20 54/1 56/21 57/3 57/22 58/13
59/9 59/9 60/2 76/15 78/8 79/6 82/11
82/21 82/24 83/4 83/13 88/20 97/23
108/4 108/5 114/24 115/7 117/16
118/24 119/3
throughout [3] 30/3 51/2 118/11
thumb [3] 66/1 71/13 71/24
tickets [1] 114/5
time [41] 3/10 3/18 12/5 13/21 20/15
21/9 27/14 27/20 33/9 35/11 42/15
45/13 47/7 51/8 52/15 52/18 52/23
52/24 65/5 65/12 66/23 68/7 73/1
83/20 86/10 88/12 90/19 91/6 91/20
92/7 93/19 100/17 102/18 102/21
104/16 106/8 106/13 106/24 113/2
118/4 118/7
times [8] 4/24 7/15 43/12 43/19 73/6
91/1 91/4 100/12
timing [1] 116/5
title [3] 84/25 84/25 85/18
today [3] 22/14 61/24 66/24
toddler's [1] 112/19
together [4] 8/11 14/12 25/11 84/12
tokens [2] 100/1 100/4
told [6] 3/20 10/8 10/10 26/3 26/5
26/23
tomorrow [4] 113/9 116/4 118/4 118/6
too [4] 20/15 24/20 26/13 98/17
took [2] 60/2 94/23
tool [1] 60/10
tools [2] 55/24 57/10
top [10] 5/21 7/23 41/12 41/13 41/18
46/16 47/6 61/3 85/11 86/23
total [2] 119/11 119/12
Toughbook [2] 71/18 71/22
Touhy [1] 64/4
towards [1] 116/5
town [1] 12/6
traced [2] 5/20 6/11
trade [1] 41/21
trail [1] 7/6
training [2] 55/20 55/23
tran [2] 37/16 37/18
transaction [1] 47/3
transactions [2] 5/20 9/18
transcript [7] 1/3 1/9 1/11 1/13
1/19 1/10 121/17
transcripts [1] 1/5
transfer [6] 9/22 15/14 22/6 22/7
22/8 23/8
transferring [1] 11/13
transmission [1] 37/18
transmitted [1] 37/20
Transportation [1] 10/5
Travel [14] 8/25 9/2 9/6 9/7 9/11
9/21 10/11 10/14 10/19 11/4 19/24
23/6 24/5 24/10
Treasury's [2] 33/3 35/9
treat [1] 23/25
trial [21] 1/10 4/20 5/11 6/12 10/22
18/8 18/14 18/24 20/20 21/20 24/14
24/18 25/16 26/14 27/3 28/10 28/21
32/10 113/20 116/8 117/24
tried [1] 78/15
tries [1] 52/13
trip [6] 26/17 113/16 114/9 115/8
115/9 115/10
true [7] 12/16 25/9 48/17 49/8 75/17
88/15 121/17
trusted [1] 28/2
truth [2] 4/19 12/19
truthful [1] 4/23
try [3] 17/19 18/3 18/18
trying [5] 21/17 25/14 27/20 76/16
111/18
turn [2] 14/18 46/15
turned [3] 5/12 73/12 114/15
Turner [1] 1/23
turning [1] 68/13
turns [1] 112/13
twice [1] 103/11
twist [2] 12/12 12/13
two [36] 4/24 9/20 10/23 12/23 13/1
14/22 18/3 19/2 19/5 19/15 19/21
21/21 22/3 23/17 24/25 28/25 29/8
36/24 42/24 49/5 55/22 61/24 66/7
70/9 72/22 76/18 89/7 90/3 90/20
93/22 99/11 105/5 106/9 106/10
112/10 113/21
two-week [1] 113/21
two-year-old [1] 112/10
type [16] 33/18 41/19 53/11 73/13
75/18 81/13 83/22 85/21 85/25 90/2
93/2 94/9 97/9 105/23 108/16 109/4
typed [3] 80/2 84/7 110/11
types [4] 25/19 30/4 36/6 86/20
typewritten [1] 121/15
typical [2] 22/24 25/4
typically [1] 33/9
typing [8] 83/17 83/21 93/10 105/18
106/12 106/13 106/24 108/25
U
U.S [3] 1/19 46/12 46/13
ultrasound [1] 113/9
Um [1] 91/9
Um-h'm [1] 91/9
unable [1] 70/15
unannounced [2] 19/17 26/21
unauthorized [1] 49/1
under [16] 4/4 7/1 8/23 12/25 38/23
43/11 43/14 45/13 47/7 47/12 48/3
48/24 49/12 49/25 53/15 112/4
underneath [1] 105/8
understand [10] 47/18 48/25 49/10
76/12 77/3 77/8 79/14 81/7 118/12
118/25
understanding [3] 81/25 110/3 115/3
understood [3] 8/5 105/12 115/11
undertake [1] 50/2
underwriting [2] 44/24 50/4
undue [1] 115/5
unions [1] 36/5
UNITED [10] 1/23 1/4 1/11 1/23 29/11
29/25 30/10 46/7 121/6 121/11
unless [1] 77/14
unlock [1] 57/1
unsuccessful [1] 104/24
until [3] 34/24 116/4 118/6
up [35] 7/2 11/19 12/19 16/6 19/16
19/21 20/25 27/5 27/20 28/12 39/4
49/25 52/13 53/1 57/16 79/16 80/16
80/21 81/13 82/19 86/1 90/3 94/10
97/17 105/6 105/22 105/24 108/22
109/5 109/8 109/17 116/5 116/6 116/8
118/16
updated [1] 113/6
updates [2] 111/14 117/6
upon [2] 26/2 26/2
upset [1] 8/18
urgency [1] 50/21
URL [4] 85/17 93/12 100/21 109/8
URLs [2] 110/1 110/2
us [10] 14/21 42/4 82/2 90/20 111/19
112/21 114/18 117/1 117/22 119/4
use [23] 17/18 26/6 34/12 39/18
39/20 40/18 55/24 57/7 57/24 60/6
68/16 79/15 79/22 80/11 81/10 81/15
81/24 82/20 86/22 97/16 101/21
118/18 118/22
used [25] 1/18 7/18 9/13 10/23 13/9
15/5 34/4 34/5 38/12 39/5 39/10
39/12 47/9 47/21 48/22 49/1 52/9
52/18 52/25 57/2 57/8 60/8 102/17
102/21 105/23
user [14] 58/9 75/15 75/25 84/12
86/20 92/17 92/23 93/10 94/18 99/15
99/17 104/22 105/17 106/12
uses [1] 44/7
using [16] 15/6 16/24 39/14 57/6
57/23 58/24 59/3 77/21 79/17 79/18
85/16 87/25 92/20 101/20 108/15
117/24
usual [1] 27/15
utilities [4] 4/5 34/11 39/20 44/6
utility [1] 48/24
utilize [1] 58/23
V
value [1] 84/15
variety [1] 5/17
various [8] 11/7 15/15 36/24 38/12
41/18 74/4 78/4 111/18
vein [1] 98/19
vendor [1] 60/10
verdict [1] 11/21
verify [6] 5/6 47/2 49/24 51/9 51/20
52/3
version [5] 12/25 40/19 79/15 82/20
82/22
versus [2] 77/7 79/18
very [22] 2/22 3/1 20/8 21/14 24/3
24/10 25/4 25/19 28/8 28/11 28/12
31/9 41/18 44/23 45/25 46/25 47/4
136
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 137 of 138
V
very... [5] 49/19 51/8 54/14 82/3
110/23
via [1] 33/7
video [1] 118/21
view [1] 87/3
Virginia [1] 37/6
visit [5] 26/16 26/21 85/17 100/16
101/1
visited [5] 15/1 26/9 85/4 86/10
100/11
visits [4] 85/14 85/15 86/14 100/9
voice [1] 16/23
voir [1] 111/21
VOLUME [1] 1/5
voluminous [2] 17/22 19/23
vs [1] 1/5
W
wages [1] 34/7
wait [1] 116/4
walk [3] 35/24 57/22 60/2
wallet [1] 71/11
want [26] 2/13 12/21 16/16 18/5
21/25 27/24 62/16 66/19 68/22 76/14
77/18 80/21 80/25 81/7 81/8 82/8
83/20 87/22 91/7 97/23 98/18 100/10
101/16 115/4 116/1 118/22
wanted [4] 9/8 13/24 105/11 116/22
wanting [1] 77/15
wants [7] 18/23 24/23 29/11 79/22
81/15 81/17 117/8
warning [1] 19/19
warrant [7] 63/8 64/12 64/23 67/23
68/3 72/2 72/25
was [241]
wasn't [3] 19/11 78/13 111/25
wax [1] 115/21
way [17] 8/20 18/5 22/13 25/3 33/7
46/24 52/10 58/25 63/23 64/7 75/23
76/1 80/23 91/11 92/10 99/5 119/21
we [134]
we'll [4] 67/3 114/12 117/4 117/6
we're [17] 3/5 16/15 17/9 21/19 27/6
36/4 40/6 76/18 76/21 76/25 77/12
78/5 79/6 80/4 80/23 81/6 82/20
web [11] 74/10 83/17 84/8 85/14
85/15 86/14 87/25 100/9 100/16 102/5
108/9
website [8] 33/2 33/3 35/9 60/13
85/17 92/18 92/20 100/14
websites [1] 92/22
Webster [20] 1/19 2/6 2/9 2/14 2/18
67/1 67/18 77/3 77/6 80/2 80/14
81/11 82/23 83/6 97/16 97/23 98/7
99/14 105/23 116/11
Webster's [2] 98/10 98/12
WEDNESDAY [2] 1/12 121/10
week [5] 113/11 113/12 113/21 116/6
116/9
weekend [2] 113/11 116/9
weeks [2] 39/7 113/20
well [25] 2/22 3/1 20/20 20/25 24/10
24/21 39/17 43/18 55/3 55/24 56/25
57/12 57/12 63/25 73/7 78/5 81/6
82/3 90/11 102/8 103/8 106/9 114/22
117/5 118/23
went [6] 16/14 18/17 25/13 26/8
104/8 105/22
were [144]
West [2] 63/10 64/24
what [150]
what's [16] 22/15 39/6 40/4 42/23
58/13 77/5 80/15 81/9 84/9 85/18
86/13 89/15 90/5 105/15 111/14
112/19
whatever [4] 27/16 43/14 80/21 98/14
WhatsApp [3] 58/20 58/22 59/10
when [65] 10/20 12/3 14/14 14/17
15/20 16/24 17/11 20/10 22/14 24/2
26/10 26/20 27/4 27/5 27/11 28/11
30/24 32/19 32/20 32/23 32/25 35/25
37/5 39/12 43/16 44/10 50/2 52/4
52/5 52/15 56/25 68/1 72/10 73/6
74/18 74/19 77/21 80/2 80/12 83/17
83/21 84/7 85/13 85/23 88/7 89/5
89/12 90/17 90/18 91/5 91/21 96/6
100/11 100/20 107/23 108/24 109/8
110/11 111/11 111/21 111/24 113/7
113/7 113/19 115/16
where [30] 7/25 10/8 13/13 18/11
19/15 21/10 23/8 27/5 29/24 38/18
41/14 55/15 78/18 78/19 87/15 88/3
89/18 100/12 103/22 103/25 104/1
104/5 107/16 107/25 108/5 112/4
112/6 112/8 116/15 117/4
whether [22] 23/23 37/1 38/6 41/20
43/8 43/20 43/25 44/10 44/21 49/18
52/24 59/8 59/19 60/21 80/9 87/20
98/7 103/10 103/20 110/7 110/10
110/15
which [31] 14/9 25/4 30/23 33/9
33/22 33/25 34/6 34/9 36/22 39/7
42/25 43/5 47/1 64/6 68/13 73/2
75/11 77/17 78/15 85/14 96/9 98/1
99/13 100/9 103/17 105/3 105/20
111/22 118/11 118/21 119/2
while [8] 6/23 7/1 15/4 25/21 76/17
77/2 104/8 117/19
who [34] 2/16 2/16 2/24 2/24 4/18
5/9 5/22 5/24 6/4 6/6 6/9 6/16 6/18
8/23 10/13 14/15 14/18 14/19 15/14
20/15 21/8 21/8 24/12 24/13 28/2
28/3 36/3 36/6 63/15 63/16 73/4 98/5
98/22 106/23
whole [5] 17/11 81/18 81/25 83/22
115/20
whom [3] 33/25 48/14 50/9
whose [5] 6/4 46/11 50/13 83/24
86/23
why [17] 11/6 18/20 21/6 21/7 21/19
24/1 24/20 24/21 25/16 50/19 56/19
76/13 76/16 79/10 81/2 94/16 120/1
wife [7] 8/4 8/17 9/12 25/18 27/1
111/25 115/5
will [133]
willing [2] 6/4 118/6
wire [9] 9/21 11/10 11/11 22/5 22/6
22/8 22/10 23/7 23/8
withdraw [4] 31/2 33/6 39/13 101/2
withdrawn [1] 64/20
withdrew [2] 76/20 111/6
within [11] 43/17 60/6 74/2 89/17
100/14 100/19 101/4 106/9 106/11
110/2 110/5
without [8] 25/4 37/10 40/2 53/20
54/1 58/10 58/24 81/17
witness [18] 24/12 29/11 39/24 51/14
54/19 54/20 61/11 63/1 63/16 65/20
69/24 70/19 77/22 80/12 80/17 81/8
117/14 118/3
witnesses [4] 2/16 17/23 18/1 20/21
wolff [5] 1/22 1/25 111/4 121/4
121/23
woman [2] 14/1 25/22
won't [9] 14/21 15/23 17/2 18/6
24/18 34/24 78/16 114/21 115/24
wondering [3] 13/16 13/17 77/10
word [2] 60/14 86/2
words [2] 8/10 11/18
work [9] 14/4 14/13 24/5 56/7 80/11
81/2 81/3 115/6 117/8
worked [12] 5/15 5/17 8/4 8/6 8/11
9/1 9/11 21/14 21/16 31/21 32/7 56/5
workers [2] 32/17 48/22
working [5] 12/4 14/12 17/7 21/10
27/13
works [2] 14/19 81/13
worth [2] 119/16 119/17
would [61] 5/19 6/7 7/18 9/9 12/13
13/16 18/19 25/20 27/9 33/8 33/9
33/11 33/12 33/13 33/16 34/23 35/2
35/23 36/7 37/11 37/12 37/13 38/24
41/12 43/17 44/8 44/14 44/17 47/2
51/8 52/24 62/23 63/22 67/2 69/21
73/6 75/11 75/16 75/23 77/19 77/20
77/23 77/24 78/1 81/3 92/9 98/1
99/22 100/17 108/1 109/22 111/17
113/22 113/22 114/9 114/22 115/17
116/3 117/5 118/5 118/14
wouldn't [1] 63/25
written [1] 10/18
wrong [2] 8/13 20/17
wrote [2] 10/23 10/24
Y
Yahoo [6] 87/21 88/9 100/16 108/9
108/9 108/16
yahoo.com [7] 84/16 85/2 85/20 93/15
94/11 99/20 110/6
yeah [3] 71/16 112/1 113/10
year [4] 23/14 42/13 56/23 112/10
years [10] 13/21 17/8 21/15 25/10
25/10 32/5 36/24 45/18 55/23 56/2
yes [219]
Ymail [4] 88/9 88/11 88/13 88/14
Yofo [1] 88/25
you [494]
you've [2] 59/5 83/19
your [99] 2/4 2/6 2/14 2/15 2/19
2/20 2/21 2/23 7/2 12/2 14/18 29/12
29/20 32/4 32/9 34/7 34/9 34/10
34/11 39/23 40/10 40/12 40/23 41/12
47/17 50/16 51/13 51/19 53/17 54/13
54/16 54/19 54/21 55/12 55/17 57/4
61/7 61/10 62/23 63/3 63/12 63/15
64/3 64/8 64/17 67/5 67/18 68/23
69/21 75/10 75/13 75/22 75/23 76/3
76/4 78/22 78/22 79/21 80/2 80/16
81/3 81/22 81/24 82/17 83/7 83/9
83/9 83/21 87/11 96/3 96/3 96/11
96/15 96/17 97/14 97/16 100/14
101/16 101/20 107/5 107/24 107/24
108/9 109/17 110/3 110/19 111/3
111/18 111/24 113/14 114/2 114/7
114/25 115/5 115/13 116/3 116/13
117/11 119/12
Z
Z-E-L-A-Y-A [1] 29/23
Zelaya [14] 29/13 29/14 29/18 29/23
29/24 34/15 40/4 40/12 41/3 41/8
42/5 46/18 50/19 51/10
zero [1] 9/18
zeroed [1] 14/14
zoom [3] 41/25 78/15 79/16
ZTE [1] 70/22
137
Case 1:20-cr-00296-JPB-CMS Document 1036 Filed 06/17/24 Page 138 of 138File and source
- File
- gov.uscourts.gand.279867.1036.0.pdf
- Size
- 719,058 bytes
- SHA-256
- c405a6f814aaf9b31c37e9ab36ccc5e7bed53c3c4538113a20bd3be2c206b42e
- Original
- PACER (login required)