Court filing
TRANSCRIPT of Proceedings as to Carla Jackson, Teldrin Foster held on February 12,… — USA v. Thomas et al (Dkt. 1039)
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. 1039 · 2024-06-17 · Docket on CourtListener
Summary
An official transcript of jury trial proceedings, Volume 6 (AM Session), in United States of America v. Carla Jackson and Teldrin Foster, Docket No. 1:20-CR-00296-JPB-5-20, held Monday, February 12, 2024 before Judge J.P. Boulee in the U.S. District Court for the Northern District of Georgia, Atlanta Division, and filed June 17, 2024 as Document 1039. Before the jury is brought in, the court takes argument on the government's motion to admit evidence of codefendants' guilty pleas, noting that responses and a reply had been filed. Counsel for a defendant and the court then discuss how questioning of an agent about the chain of communication among charged individuals should be treated. The court characterizes one statement made in front of the jury as more than an implication. The transcript runs 67 pages and ends with a word index.
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Case 1:20-cr-00296-JPB-CMS Document 1039 Filed 06/17/24 Page 1 of 67
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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 6 (AM SESSION)
CARLA JACKSON and
TELDRIN FOSTER,
Defendants.
TRANSCRIPT OF JURY TRIAL PROCEEDINGS
BEFORE THE HONORABLE J.P. BOULEE
UNITED STATES DISTRICT COURT JUDGE
MONDAY, FEBRUARY 12, 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
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(Court was called to order at 9:45 a.m.)
THE COURT: You all can have your seats.
Thank you.
I hope everyone is well this morning. Good to see
you all.
MR. MARSHALL: Good morning, Judge.
THE COURT: All right.
I guess first and foremost, for discussion before
we bring in the jury -- and Officer, if you'll check in, in
maybe five to ten to see if we have got all our jurors, and
let me know, I'd appreciate it.
It would be my intent to bring them out at 10:00 if
they are all here and just get rolling, whether or not we
have completed our discussion of our other issues.
COURT SECURITY OFFICER: Yes, sir.
THE COURT: Thank you.
But I think first and foremost is the government's
motion to admit evidence of codefendants's guilty pleas.
I take from the fact that I received responses and
a reply that you all weren't able to work out some type of
agreement on this.
Why don't we take just a few minutes a side just
for you to recap what you think your strongest points are.
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And again, I think the record will have many of your detailed
arguments but again, Ms. Chaiken, it's your motion so I'll
let you go first.
MS. CHAIKEN: Thank you, Your Honor.
So I want to take one step back because we have
been thinking a lot about how we got to this point where this
is the defense that the defense has introduced that has, we
think, opened the door.
I sent a case to the Court this morning, United
States v. Baptiste. It's a 2019 published Eleventh Circuit
case that addresses reverse 404(b) evidence, which is
basically when the defense tries to introduce evidence of a
wrong by another person.
And that case involved a situation where the
defendant was indicted in a fraudulent check cashing scheme,
and his defense was that his business partner had duped him
into participating in the scheme and he had thought that it
was all aboveboard. And he wanted to put in evidence that
this business partner had previously duped other people into
participating in similar check cashing schemes.
And the Eleventh Circuit said there are basically
two ways to view that evidence. One is the business partner
has done it before and therefore he has the capacity to do it
again, which would be admissible under Rule 404(b) to show
that the business partner was capable of duping someone into
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a scheme in that way.
The second way of looking at the evidence was that
it was introduced to show that the business partner had a
propensity of duping people or of deceiving people and
therefore likely deceived the defendant in this case. And
the Eleventh Circuit said that's not a permissible purpose.
And here, I think, based on what the defense has
said and based on the testimony that they have elicited, it's
entirely a propensity defense because there is no evidence
that Darrell Thomas has ever taken over someone's WhatsApp
account, taken over their email account, impersonated someone
in order to frame them in a fraud.
All there is is evidence that he is a liar and that
he has used people's names on documents without their
knowledge. And that's not what we have presented as to
Teldrin Foster.
It's not something where, if that's true, that
Darrell Thomas used Brenda Miller's name on a Secretary of
State filing, it shows that he has the capacity to have taken
over Teldrin Foster's entire internet persona in order to
commit this fraud.
So I think the entire defense based on this case
law is not permissible under Rule 404(b). I think the
Baptiste case makes that clear.
And because that's the defense that's been
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asserted, we're in this situation that's sort of uncharted
territory and that's why there aren't cases on point that
address this admission of guilty plea issue in this context,
because there really aren't cases where a defendant has been
allowed to put on this kind of propensity evidence and imply
that their codefendant or their business partner or whoever
has tricked or deceived other people in order to prove that
he has tricked or deceived him or impersonated him.
So there just aren't cases on point, Your Honor,
because this is not a defense that is permissible under Rule
404(b).
Obviously, generally, when this type of evidence
comes up, it's in the context of a cooperator who is
testifying and there is questioning that opens the door to
the suggestion that maybe they got off scot-free or that they
didn't plead guilty.
We just didn't find cases, one way or the other,
addressing this situation where a defendant puts at issue a
codefendant's deception.
THE COURT: Off the record.
(Off-the-record discussion, and proceedings
continued:)
THE COURT: Back on the record.
MS. CHAIKEN: So, Your Honor, what we have here now
is a situation where the defense has suggested to the jury --
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THE COURT: One moment.
Back on the record.
MS. CHAIKEN: So we have now a situation, Your
Honor, where the defense has very clearly said that their
defense is Darrell Thomas is a liar, Darrell Thomas is
someone who uses deception, Darrell Thomas is someone who
uses other people's names on documents when it benefits him.
And the defense has tried to slice and dice and
say, well, our questioning about the codefendants was a
separate line of questioning from our questioning about
Brenda Miller. But the jury doesn't consider each line of
questioning and what it may suggest in a vacuum. The jury is
listening to the testimony as a whole.
And what the jury has heard is that many of the
codefendants did not speak to Darrell Thomas, and then right
after that they heard that Darrell Thomas puts people's names
on things without their knowledge.
And there really was no purpose for that testimony
to come in. There was no need for the jury to know that
those people were charged, and in fact, we filed a motion in
limine to preclude any reference to charging decisions.
But all of those same questions could have been
asked as what was Kahlil Green's role? What was Ryan
Whittley's role?
There was no need to start off that line of
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questioning with how many people were charged and were all of
these people charged? Whether or not they were charged is
completely irrelevant to the question of whether they were
involved and what their involvement was.
And we see no purpose to have brought that in,
other than to make the point that all these people were
charged despite having had no communication with Darrell
Thomas, leading straight into "Darrell Thomas is a liar to
puts people's names on things."
So we think the implication has clearly been made
to the jury and the impression has clearly been left with the
jury that there are people who have been charged in this case
who did not deal with Darrell Thomas and that Darrell Thomas
uses people's names without their knowledge.
And the only -- I don't think the defense really
contradicted that. And the only thing that they really
raised is a confrontation clause issue, I think. And we are
not seeking to admit any testimonial statements by any
codefendant. We are just seeking to admit the fact of their
guilty plea.
The jury doesn't need to know that they admitted --
that they pleaded guilty to conspiracy with Teldrin Foster or
that Teldrin Foster was a part of that conspiracy. The jury
just needs to know that they admitted their own guilt in the
PPP fraud, in order to eliminate the misimpression that any
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of those people were duped, were lied to, were deceived, were
victims of identity theft.
And I think Mr. Foster's motion or response makes
clear that there really isn't a confrontation clause issue
because they say if we had a plea agreement for Brenda
Miller, we could introduce that. And Brenda Miller is not a
witness in this case. Brenda Miller is not testifying.
And they said, well, we imply that Brenda Miller
had nothing to do with it, and so if you have a plea
agreement for Brenda Miller, you can introduce it. And
that's exactly what we're trying to do with the codefendants.
THE COURT: All right. Let me hear from the
defense.
MS. WEBSTER: Yes, Your Honor. Thank you.
I have a number of responses.
I think first that the -- this entire argument is
based on sort of what I would consider a misreading of the
transcript or inaccurate description of the testimony that
was elicited.
To start out with, specifically I asked about
Darrell Thomas's role in the offense and then I clarified
that he communicated with the recruiters and then said: He
was the one communicating with all the business owners or
were they sometimes communicating with the recruiters?
And then, most of the time, through the recruiters.
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So that establishes that Darrell Thomas is not the
primary one communicating with the business owners --
THE COURT: Can you slow down just a little bit,
Ms. Webster?
MS. WEBSTER: Yes, I can. Thank you.
THE COURT: For both the court reporter and for me.
MS. WEBSTER: Yes.
THE COURT: Thank you.
MS. WEBSTER: So they, the line of -- that
questioning there, I think, addresses the government's
concern which is that there is some implication that because
Darrell Thomas was not communicating with the business owners
and their identities must have been stolen, that was never --
I think those few questions make clear that he was not always
communicating directly with people, but there was no
implication that therefore they were not involved.
And when I went through the people in the
indictment, I did what the government asked, and asked what
their role was.
And then when the questions that I -- that they
appear to be concerned about, which are did the -- did this
person communicate with Darrell Thomas? That wasn't the end
of the question, the question was -- or the questions were:
Did they communicate with Darrell Thomas or did they
communicate with someone else in the indictment?
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So it was just to sort of like lay out the chain of
communication. There wasn't any implication that the people
who have been charged were not involved.
Second of all --
THE COURT: You just said there wasn't any
implication that the people who have been charged were not
involved?
MS. WEBSTER: I don't think I implied that at all.
When I -- when I was questioning the witnesses -- I
mean, questioning the agent about the role of the other
people who were charged in the case, I asked sometimes if
they communicated with Mr. Foster, right, and sometimes I
asked if they communicated directly with Darrell Thomas or if
they communicated with someone else --
THE COURT: What about, I guess it wasn't a
question. I think it was maybe in response to an objection
when in front of the jury you noted that Thomas's modus
operandi was to do this.
That's more than an implication, isn't it? That's
a direct statement to the jury that that's what was going on.
MS. WEBSTER: But that was in response to the
Brenda Miller evidence when the government objected.
So I feel like I have to -- if the government
wanted us to approach for the jury not to hear the response,
then we could have. But there was an objection made and I
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was responding to the objection. And that wasn't about any
of the codefendants.
And going to the codefendants, which is what is the
subject of the government's motion, those codefendants are
all charged with conspiring with Mr. Foster.
So it is entirely relevant and admissible and
proper for me to question them or to question the witness if
they had evidence that those codefendants had communicated
with Mr. Foster.
And just to let the jury know who those people are
because the government had not -- the government had not
introduced evidence about other people, but they are the
people that he is supposed to have participated in a
conspiracy with. So I think it is entirely fair for the jury
to hear who they are and to understand their roles in the
offense.
I would note that as to my -- going back to my
response to the government's objection, the jury will be
instructed, and I believe has already been instructed, that
statements of counsel are not evidence. That is not in
dispute. So I think that would eliminate any potential harm
from that.
But I think that the case law is clear that you
cannot introduce the codefendant's convictions when they are
not testifying.
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THE COURT: Well, case law is very clear that
normally you don't do that. This is not a normal situation,
as Ms. Chaiken has argued.
Let me hear from Mr. Marshall.
MR. MARSHALL: Judge, the only thing I'd add, I'd
move to adopt the arguments that Foster has put forth.
But as the government's motion addressed
Ms. Jackson, it just addresses an issue or some statements I
made in our opening statement. Number one, that the
government's investigation was sloppy.
My motion to adopt -- that reference to a sloppy
investigation was solely related to the government's improper
drafting of Count 46 in three separate indictments.
They charged it -- they alleged that it was a wire,
it was wire fraud and a wire transaction when, in fact, it
was a check that was deposited at a bank, in branch.
So I just pointed that out to the jury early on.
That has nothing to do with bringing in plea agreements of
other codefendants or anything like that. It just doesn't
address any of that.
And then the second argument was I did make a
reference in opening to Mr. John Gaines pleading out. He is
on our witness list. We intend to call him as a witness and
those are questions I will put forth, so there is no
confrontation issue to be able to answer things. I mean, the
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government can cross him.
And then I also made a reference to -- I
anticipated that the government would be calling Darrell
Thomas. He was on their list of parties that were read out
to the jury. We had PSR materials turned over to us for
prospective cooperating witnesses by the government early on
that included Darrell Thomas.
So it was my belief that they would probably call
him. So there was a reference to a plea agreement by Darrell
Thomas.
And that's the extent of our statements during
opening arguments, Judge.
THE COURT: All right.
Ms. Webster, let's take a hypothetical scenario in
which I agree with Ms. Chaiken on this.
You don't want me to admit the guilty pleas. What
else would you have me do, short of that?
MS. WEBSTER: Are you anticipating introducing the
convictions of every single codefendant that was mentioned in
cross-examination?
THE COURT: I'm asking you what you would have me
do other than what Ms. Chaiken has suggested doing?
MS. WEBSTER: Can I have one second?
(Pause.)
THE COURT: Officer, do we have the jurors?
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COURT SECURITY OFFICER: Yes, Your Honor.
THE COURT: All right. We'll rejoin this issue
later.
Let's bring out the jury.
Investigator Stites, you can come up and get on the
stand.
Thank you.
(Jury enters the courtroom at 10:06 a.m.)
THE COURT: You all can be seated.
Thank you.
Good morning, ladies and gentlemen. Thank you for
being back, and thank you for being on time. It's greatly
appreciated.
Ms. Webster, you can continue your
cross-examination with Special Agent Stites.
MS. WEBSTER: Thank you, Your Honor.
CONTINUED CROSS-EXAMINATION
BY MS. WEBSTER:
Q.
Agent Stites, can you tell me when you began this
investigation?
A.
I'm not exact sure of the exact opening, but it was
sometime in April of 2020.
Q.
Okay. Thank you.
And your work on the case is still ongoing?
A.
Yes.
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Q.
And as part of your duties, you collect information
related to the targets of the investigation; is that right?
A.
Yes.
Q.
Sometimes you get that from other agents?
A.
Yes.
Q.
Okay. And sometimes you might get it from other
agencies?
A.
Correct.
Q.
In this case, you learned that Secret Service had
also conducted some investigation into a relevant party; is
that right?
A.
Yes.
Q.
And there was at least one interview. Yes?
A.
Correct.
Q.
And that was of Amanda Christian?
A.
Yes.
Q.
On -- in August of 2020?
A.
I'm not quite sure of the time frame of the
interview, but I think you showed me the document before.
That sounds about right.
Q.
Okay. And it was about the loan associated with
Advertising and Then Some?
A.
Yes.
Q.
And that's one of the loans that's charged in this
indictment?
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A.
Yes, it is.
Q.
And you got the report from her interview; is that
correct?
A.
Yes.
Q.
Okay. And you reviewed that document?
A.
I did.
Q.
Okay. Because that was relevant to your
investigation. Yes?
A.
It was part of the -- one of the loans we were
looking at, yes.
Q.
Okay. And you wanted to see what she said about
that loan?
A.
Yes.
Q.
And you wanted to see if she had provided truthful
information.
A.
Yes.
Q.
Okay. And in that statement, she suggested that --
MS. CHAIKEN: Objection, Your Honor. Hearsay.
MS. WEBSTER: Your Honor, I think I have laid the
foundation to show the effect on the investigation.
THE COURT: I think the issue I was having earlier
was the timeframe of that review. I thought that's what we
discussed. I thought it was still an open issue.
So do you want to try to develop that?
MS. WEBSTER: I'm sorry. The time frame of the
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interview versus the investigation?
MS. CHAIKEN: Your Honor, there is another issue as
well.
Could we approach?
THE COURT: Sure.
Ladies and gentlemen of the jury, if you would step
out for a moment, please.
(Jury withdrew from the courtroom at 10:10 a.m.)
THE COURT: You all can be seated.
All right. Well, didn't take long to circle back
to this knotty issue.
Yeah. I thought the whole -- I thought what I told
you was, last week, after we debated this for what seemed
like an hour, was I wasn't yet clear on when he reviewed that
transcript.
And if it was during his investigation, your
relevance might be high, versus if he reviewed it two weeks
before trial when he was getting a bunch of stuff in from
somebody else that didn't affect his investigation, the
relevance might be next to nil, which would have a pretty
heavy effect on how we came out on 403, eventually.
And you just rejoined the issue, but I still don't
have any details as to when he would have looked at this.
MS. WEBSTER: I understand, Your Honor.
THE COURT: Let me hear from Ms. Chaiken. She has
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something to say as well.
MS. CHAIKEN: Your Honor, I think everyone agrees
that Amanda Christian's statements in the interview are
hearsay.
My understanding is that the defense wants to offer
those statements to show the effects on the investigation.
And when somebody wants to show the effects on investigation,
the way they do that is to say, "Did you interview John Doe
or did you review an interview with John Doe?" or whatever.
And the person says "yes."
And then the next question would be, "Based on that
interview, what did you do next, or did you do anything?"
And then they may say, "I called so-and-so" or "I
went and interviewed so-and-so."
The implication would be John Doe told me that I
should go talk to so-and-so, and then I went and did that.
But to say Didn't Amanda Christian say Foster
called her? and then Did you do anything based on that? is
not showing any effect on the investigation or any effect on
the listener.
And as the Court, I think, explained last week when
we were discussing this issue, it's not a hearsay -- a
non-hearsay purpose to show the lack of effect on the
investigation because then Ms. Webster could put literally
anything in the entire world in front of Agent Stites and
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say, "Did you read this newspaper article? Did it have an
affect on your investigation?"
"No."
Doesn't this newspaper article say whatever?
So if she wants to show an effect on the
investigation, she can ask him: After you reviewed the
interview of Amanda Christian, did you do anything in your
investigation?
And then he'll answer that, whether he did or did
not do anything in his investigation, and that would show the
effect on the investigation without putting before the jury
the actual hearsay statement, which is just hearsay.
THE COURT: All right. And we still haven't
established -- maybe we can do it outside the presence of
jury.
Just establish when he would have reviewed this,
Ms. Webster, and then we can go from there.
Maybe you can make a proffer as to how you are
going to go about this and how far you intend to go or
whether you intend to stay within the limits that Ms. Chaiken
has explained are normal.
Go ahead. Let's just do a proffer.
PROFFER
BY MS. WEBSTER:
Q.
Agent Stites, if the interviewed happened in August
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of 2020, do you know about when you would have received that
document?
A.
I don't know the exact timing of receiving that
document. I would imagine it was somewhere between August
and December sometime.
Q.
Of 2020?
A.
I would guess.
Q.
Okay. And that's before Mr. Foster was charged in
this case; right?
A.
Yes.
Q.
And before he was interviewed? He was interviewed
in December of 2020; is that right?
A.
I don't remember when I reviewed the document, to
be honest with you.
Q.
Okay. And so it was produced to us in discovery;
that's correct? Yes?
A.
Correct.
Q.
Okay. And that discovery was provided in August of
2021; is that right?
A.
Can you repeat that?
Q.
That discovery was produced in August of 2021?
A.
Yeah, I don't remember the date of when the
discovery was produced. But if that's when you got it, then
I'll agree with that.
Q.
Okay. And it was in the discovery that we received
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at that time, so you had to have it before we received it?
A.
Yes.
Q.
And that's several years prior to this trial; is
that correct?
A.
Yes.
Q.
Did you review it once you received it, or did you
get it and let it sit for a while?
A.
I would have probably looked at it when the agent
from the Secret Service sent it to me.
Q.
Okay.
MS. WEBSTER: Your Honor, I think that addresses
the timeline issue.
Do you want me to ask the remaining questions that
I planned on asking?
THE COURT: Yes.
MS. WEBSTER: Okay.
THE WITNESS: What exhibit is that?
MS. WEBSTER: It's not marked as an exhibit.
THE WITNESS: You handed it to me the other day.
Do you have that?
MS. WEBSTER: I can show it to you.
BY MS. WEBSTER:
Q.
I have it on my laptop. (Hands document to
witness.)
A.
Did you hand it to me on a piece of paper last
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time?
Q.
I did. I just don't have it right now.
A.
Okay.
It was August. I was just confirming the dates and
times.
Q.
Okay. So, Agent Stites, when you received that
report, you reviewed it; is that correct?
A.
Yes.
Q.
Okay. And then what actions did you take after
reviewing that statement, or based on receiving that
statement?
A.
The full statement? I mean, we had already known
about this loan, so our intention was to interview
Ms. Christian. And I think we interviewed her a couple
times.
Q.
And did the fact that she had identified someone
with the last name Foster in a way that was not true give you
pause?
A.
Honestly, I don't recall. But I don't believe so
because, even reading it here, it's referencing CDC Finance
and an individual named Foster.
Q.
Okay. But there is no indication that that
statement is actually true?
A.
We -- at this point I don't know if we knew what
was true with Ms. Christian. I don't know that we had
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interviewed her yet.
THE COURT: All right. Is that about it,
Ms. Webster?
MS. WEBSTER: That's about it.
THE COURT: I'm going to overrule the objection.
Let's bring out the jury.
I'll let you lay that additional foundation as to
timing and ask those limited questions.
Officer, if we could bring out the jury.
Thank you.
(Jury enters the courtroom at 10:20 a.m.)
THE COURT: All right. You all can be seated.
The objection is overruled.
Ms. Webster, you can go ahead.
MS. WEBSTER: Thank you, Your Honor.
BY MS. WEBSTER:
Q.
Agent Stites, were you able to confirm that the
interview was in August of 2020?
A.
Yes.
Q.
Okay. And did you receive the interview
thereafter?
A.
Sometime thereafter, yes.
Q.
Okay. And would you have received it in 2020?
A.
I believe so, but I don't know exactly the
timeframe.
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Q.
Okay. And when you received it, you would have
reviewed that statement; is that right?
A.
Yes.
Q.
Okay. And you are aware that, in that statement,
Ms. Christian identified someone with the last name of Foster
as being involved; is that correct?
A.
Yes.
Q.
Okay. And she said that's when she sort of figured
out this was a scam whenever someone with the last name of
Foster called her; is that right?
A.
She purported that she felt like it was a scam when
somebody called her representing to be from the CDC Finance,
or the lender. And she said the individual's last name was
Foster, and the first name, didn't know.
Q.
Thank you. And to your knowledge, is that
accurate?
A.
I don't believe so.
Q.
Okay. And once you got that statement, did you
take any actions as a result?
A.
Not specific to that statement. This was a loan
that we had already identified. It just so happened the
Secret Service had also identified it as a loan. So when we
found out that the Secret Service had interviewed
Ms. Christian, that's when I reached out to that individual
and got the interview and the information.
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And then our next step was really just to interview
Ms. Christian.
Q.
Thank you.
I know it's been several days now, but do you
remember last week on direct you testified about a number of
clips from your interview with Mr. Foster; is that right?
A.
Can you be more specific?
Q.
On direct, you discussed Mr. Foster's statement
that he made --
A.
Yes. On direct. On direct. Sorry. I was
thinking about on cross.
Q.
Yes. So on direct.
And I just want to lay out the timeline for that
interview a bit.
So the day before you spoke with Mr. Foster, you
had interviewed Gena Pyfrom-Foster; is that correct?
A.
Yes.
Q.
Okay. And you told Ms. Pyfrom-Foster that you
wanted to speak with Mr. Foster; is that right?
A.
We told her -- we asked her if she thought
Mr. Foster would talk to us and she said she would ask him.
And I said, if he's willing to talk to us, have him give me a
call. Here's my number.
Q.
Okay. And did he call you?
A.
He did.
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Q.
So he agreed to come in for a statement?
A.
He agreed to come in and meet with us, yes.
Q.
And you don't know what sort of conversation that
Mr. Foster had with Ms. Pyfrom-Foster at that point?
A.
I don't know.
Q.
But he agreed to come down and meet with you and do
the interview?
A.
Yes.
Q.
He did not have a lawyer at that time?
A.
No.
Q.
You didn't tell him he could get one?
A.
No.
Q.
And you didn't tell him he should get one?
A.
No.
Q.
And it's often more difficult for you to interview
people once they have lawyers; is that right?
A.
If they represent that they have an attorney, then
we will generally coordinate with their attorney and try to
bring them in on an interview with U.S. Attorney's Office,
their attorney, as well as the agents investigating the case.
Q.
There is a little bit more of a process involved;
is that right?
A.
Yes.
Q.
So you never advised him that his statements would
be played at a trial like this; right?
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A.
Not at the time, no.
Q.
Okay. Was there another time when you advised him?
A.
No.
Q.
Okay. You never told him that he wasn't required
to speak to you?
A.
No.
Q.
Okay. So he came down for the interview; right?
And you spoke with him for a long time.
A.
Just a little over two hours.
Q.
Okay. So over two hours. And we have heard some
clips from that interview; right?
A.
Yes.
Q.
Okay. And specifically we had heard clips where
Mr. Foster told you that he had received 50- to $60,000 from
Darrell Thomas?
A.
Yes.
Q.
Okay. And he told you a little bit more about
those statements; is that right? Or those payments?
A.
Yes.
Q.
Okay.
MS. WEBSTER: Your Honor, I would plan to play the
portions that you had previously authorized under the rule of
completeness, which have been marked as F40A through F40E at
this time.
(Audio was played.)
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COURT SECURITY OFFICER: Your Honor, it's not
working.
THE COURT: Okay. Ms. Lee.
COURTROOM DEPUTY: Sorry. I did check it.
THE COURT: That's okay.
Thank you, Ms. Lee.
(Pause.)
BY MS. WEBSTER:
Q.
So in that statement -- I'm going to replay it for
the jury.
A.
I was struggling to hear it. It was hard to
understand, to be honest with you.
(Audio was played.)
BY MS. WEBSTER:
Q.
Were you able to understand that, Agent Stites?
A.
It was hard. I don't know how the recording was
made; it just seemed a little unclear. But I heard him say
he was hustled.
Q.
Okay. And is it fair to say that Mr. Foster said
that he had met Darrell Thomas and some other people that
were supposed to be his business partners previously and they
had hustled him?
A.
Yes.
(Audio was played.)
BY MS. WEBSTER:
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Q.
Agent Stites, I know that is difficult to hear.
A.
Yes. I don't know why, but it is hard to, it's not
real clear.
Q.
Can you just read these for us. (Hands document to
witness.) That's the one --
A.
Starting at the top?
Q.
Yes.
A.
Okay.
"Mr. Foster says: Not just the barber shop. Just
like what my record label would do with the nightclub and
stuff like that.
"Agent Stites: Okay.
"Mr. Foster: So they was saying like, well, we can
do this, we can do this. We can help build this out, build
this out, help to get like little -- like once they put the
credit on there to help you get established. So I fell for
it. It was giving me $1,000 here, $2,000 here. This, this
and the third. All the while the dude was hustling me
because, on the other end of it, he didn't even have no
money. He ain't even got no business. He don't got nothing.
"Agent Stites: Okay."
BY MS. WEBSTER:
Q.
Okay. I'm playing what is marked as F40C, which
should be the next transcript.
(Audio was played.)
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THE COURT: I can't understand that. I'm sure the
jury can't either. Why don't we just do a Q and A from the
transcript.
You can play it if you want, but I don't think
anybody's going to be able to understand that.
If you would like to play it and then have him read
it, that's fine, for completeness. But if all you are going
to do is play it, I think that's going to be problematic
because I don't understand what they are saying.
MS. WEBSTER: Sure. I understand, Your Honor. I
did not anticipate this not being understandable.
So, Your Honor, I think we would move to admit F40A
through E, which I think has been pursuant to your order, and
then we can have the agent read it. And then, that way, the
jury will have it and they can listen to it.
THE COURT: We don't need to admit it. We can just
play it like we have been doing. It wouldn't be any
different.
I mean, we haven't admitted the transcripts of all
the others, have we?
MS. CHAIKEN: No, Your Honor. And the transcript
is not evidence.
THE COURT: I don't think we are going to
piecemeal, play a hundred different snippets of tape and
admit one of them but not have admitted all the other ones.
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So what I'm suggesting is that given that we have
some audio issue this morning in the courthouse, instead of
playing that tape -- and you are welcome to play the tape as
well, if you would like. But from my impression, it's fairly
inaudible and hard to understand.
What I'm suggesting is what you can do is just do a
Q and A and read the lines with the witness or read it into
the record as to what was said.
To the extent you want the value, if any, of the
actual audio, you are welcome to play that as well.
But we're not going to admit just the transcript of
this without going back and admitting the transcript of a
hundred other things we have had transcripts of.
That wouldn't be fair.
MS. WEBSTER: I'm sorry, Your Honor. I wasn't
clear. I didn't mean that I wanted to admit the transcripts.
I just wanted to make sure that the actual audio clips are
admitted into evidence.
THE COURT: Yes.
(Defendant's Exhibit F40A through F40E admitted
into evidence.)
BY MS. WEBSTER:
Q.
Agent Stites, so I will not play this because I
agree that it is not comprehensible at this point.
But can you please read the remaining transcripts?
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They are short.
A.
Okay. So you want me to read the second one now?
Q.
Yes.
A.
Okay.
"Agent Stites: And that's how much you think you
paid him?
"Mr. Foster: I paid him -- or, I paid him?
"Agent Stites: Yeah. You said you got your money
back, so that means --
"Mr. Foster: No. All the -- how they manipulated
shit to fuck me, fuck over me all the while.
"Agent Stites: You think you paid him over 45 or
50 grand when he was fucking you over?
"Mr. Foster: Him and the dude David.
"Agent Stites: Okay.
"Mr. Foster: Yeah, the dude David.
"Agent Stites: And you think you got that money
back from him?
"Mr. Foster: Nope. They owe more amount that he
owed me.
"Agent Stites: How much did you get back from him,
do you think?"
Q.
Can you read the next one, please.
A.
"Mr. Foster: I'm thinking between 30 plus, 30
plus, altogether, probably. I would say, at the most, 60 but
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between 50 and 60.
"Agent Stites: Okay.
"Mr. Foster: But that was for something else
'cause I was telling him that we could go in on like doing
the promotion shit at the clubs and shit like that. But the
thing about it was he bullshitted so much, talking about
some, oh yeah, man, you know, they are holding this and they
are holding that and they are holding this or whatever.
"But you know, I put some money in the stock, you
know. I hit the stock market for such-and-such money.
That's when me and him fell out because that's when I knew he
had money.
"How the fuck you gonna put 30 grand in the stock
market in two or three weeks and make four hundred and some
thousand dollars, and he's talking crazy shit.
"His appearance, you know, like his appearance
changed, like, shit, he went to having shit that I know like
he didn't hit no fucking stock market."
Q.
Okay. Can you read the next one, please?
A.
"Mr. Foster: 'Cause when I met him, like 2016, when
I came into my retirement money --
"Agent Stites: Yeah, right. How much?
"Mr. Foster: They fucked me out of probably like
$90,000.
"Agent Stites: 90?
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"Mr. Foster: Not at one time. It was like through
a period of time.
"Agent Hale: What retirement money?"
Q.
Is there one more, or is that the last one?
A.
"Agent Stites: Then shed some light on this for
us.
"Mr. Foster: Okay. I met Darrell and some people
that, quote/unquote, were business partners but years ago.
"Agent Stites: Okay.
"Mr. Foster: And they hustled me."
Q.
So the payments that we, or that you discussed on
direct, Mr. Foster never said that they were for his
participation in a PPP fraud scheme; is that right?
A.
He was saying that it was payback money for when he
was hustled.
Q.
Okay. And he said that he had invested his
retirement money with Darrell Thomas and a guy named David;
is that right?
A.
Yes.
Q.
Okay. And that they had hustled him out of up to
$90,000?
A.
Yes.
Q.
Okay. And he said that Darrell Thomas had told him
that he had actually hit it big in the stock market?
A.
Yes.
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Q.
Okay. Okay.
So during the statement, it was you; correct? You
were there?
A.
Yes.
Q.
Okay. And there was another agent there; is that
right?
A.
Yes. Agent Hale, who is with the IRS.
Q.
Okay. And is it fair to say that he came in very
skeptical that Teldrin Foster knew how to do any tax forms?
A.
That's fair to say.
Q.
Okay. I think so skeptical at one point that you
sort of told Mr. Foster you were going to give him a test and
have him fill out a form?
A.
Agent Hale said he was going to go get, I believe,
a 940 and a 941 form and bring it in to see if he even knew
what it was.
Q.
And at some point you or Agent Hale asked him if he
knew what a 944 was; is that right?
A.
I think the question was Does he know what a 940 is
for?
Q.
Okay.
A.
It was miscommunicated.
Q.
Okay. And was there a point at which you or Agent
Hale asked Mr. Foster why you, what value do you add to this?
A.
We asked him that when Mr. Foster was saying that
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he was just receiving emails and forwarding them back and
wasn't -- saying he wasn't doing anything with them and he
was just looking at them.
Q.
And you knew at this time that Ms. Pyfrom-Foster
was an IRS employee; is that right?
A.
Yes, we did.
Q.
Had she been an IRS employee for quite a while at
that point, or do you know?
A.
I think she had -- I can't remember the exact
amount of time. But she had been for a few years, for sure.
Q.
Okay. So was it fair to say that you believed she
would be more familiar with the IRS processes than
Mr. Foster?
A.
Yes. That was sort of the going-in impression.
Q.
Okay. And she was more likely to know about the
stamps that were on some of the forms; is that right?
A.
I think anything related with the tax stuff we
thought she probably would have a little more experience than
someone who did not work for the IRS.
Q.
Okay. So this interview took place on December 10
of 2020; correct?
A.
Yes, that's correct.
Q.
Okay. And Darrell Thomas was arrested on August 6
of 2020; is that right?
A.
Yes.
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Q.
And he was indicted at that time, when he was
arrested?
A.
I think the indictment is on August 4. And then
the arrest was on August 6.
Q.
Okay. And there were news releases about it; is
that right?
A.
Yes. I believe there was some sort of press
release.
Q.
Okay. So there was a press release from the
Department of Justice; is that right?
A.
I believe so.
Q.
Okay. And there were resulting news articles about
it, like in the AJC and things like that?
A.
I'm sure there were.
Q.
Okay. Now, on direct, I think you testified about
the use of the rapid! PayCards in this scheme; is that
correct?
A.
Yes.
Q.
Okay. And so, specifically, you testified that
Darrell Thomas eventually began using rapid! PayCards to --
basically to launder the funds; is that right?
A.
That's correct.
Q.
So the funds would come into the business owners's
accounts; right?
A.
Correct.
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Q.
And then Darrell Thomas told them or communicated
with them through a recruiter to send the money to his
accounts; is that right?
A.
Are you referring specifically to rapid?
Q.
Well, there were a couple of different options;
right?
A.
I think, in the beginning, the payrolls were going
through Bellator and Elite Executive Services. Eventually,
down the road, when those two accounts were stopped and
seized, the money started going in through the MetaBank
rapid! PayCard program.
Q.
Okay. And then the intention behind that was to
sort of make it look like there was actual legitimate payroll
happening; is that right?
A.
Yes.
Q.
Because that's one of the authorized purposes for
the PPP loans?
A.
Yes.
Q.
Okay.
MS. WEBSTER: Ms. Holland, can we see Government's
Exhibit 2954?
BY MS. WEBSTER:
Q.
Agent Stites, we're looking at Government's
Exhibit 2954.
Is this the -- are these the records that you got
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from MetaBank or the rapid! PayCards?
A.
Yes. This looks like the records that we got from
rapid.
Q.
Okay. And so on this first column here, it says
card info; is that right?
A.
The first tab?
Q.
The first tab. I'm sorry.
A.
The first tab says card info.
Q.
Okay. Is this a list of all the people that were
issued rapid! PayCards from the Bellator Phront Group
company?
A.
Yes.
MS. WEBSTER: Ms. Holland, could we scroll down to
the bottom?
BY MS. WEBSTER:
Q.
There are approximately 199 names, or at least
entries, on this list?
A.
I think the first row is a header, so it would be
198.
Q.
Okay. So 198 entries; is that right?
A.
That looks about right.
Q.
So do each of these rows represent a separate card
that was issued from Bellator Phront Group?
A.
Yes.
Q.
Okay. And so if we go to, I believe, Row 52.
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So 51, actually, is the -- is what you referenced
on direct; right? It's the card issued in Mr. Foster's name?
A.
Yes. That's the card we referenced in direct.
Q.
Okay. And then on Row 52, whose name is listed
there?
A.
Gena Foster.
Q.
Okay. So just to be clear, not all the people on
this list actually received rapid! PayCards; is that right?
A.
That's our understanding, yes.
Q.
Okay. And instead, a lot of these cards that were
issued remained in the hands of people like Darrell Thomas
and Ricky Dixon and other participants in the conspiracy; is
that right?
A.
We believe that that's true.
Q.
Okay. And that's what you learned during the
course of your investigation; correct?
A.
Yes.
Q.
Okay. And in fact, when Darrell Thomas was
arrested on August 6, he had multiple rapid! PayCards in his
possession; is that right?
A.
He did.
Q.
I think it was nine. Does that sound right?
A.
That's probably close to right, if not exactly
right.
Q.
Okay. So they were using these cards to buy things
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with; is that right?
A.
Yeah. Using to buy, taking money out of the -- off
the card through ATM withdrawals. And I think eventually
they figured out a way to ACH the money into other bank
accounts.
Q.
Okay. So they figured out multiple ways of getting
the monies off of these cards; is that correct?
A.
Yes.
Q.
Okay. And some people -- he had people withdrawing
thousands of dollars -- thousands of dollars of cash per day
at times; right?
A.
Yes. I believe so.
Q.
Okay. And he actually employed other people to
get -- to do that; right? He had other people take the cards
and swipe them?
A.
Yes. That's our understanding.
Q.
Okay. Okay.
MS. WEBSTER: We're done with this exhibit. Thank
you, Ms. Holland.
BY MS. WEBSTER:
Q.
Agent Stites, I believe you got a search warrant
for cell site data; is that right?
A.
Yes, we did.
Q.
And that's what Agent Berni testified to last week;
is that correct?
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A.
Yes.
Q.
But that data only started on July 1 of 2020; is
that correct?
A.
I believe so. If you have the actual records, I
can confirm that for you, but I believe that's accurate.
Q.
Okay. And so let's -- you did not request any
other cell site analysis other than what you asked Agent
Berni to do; is that correct?
A.
Correct.
Q.
Okay. And in this case, sometimes you got bank
surveillance footage; is that right?
A.
Where we could get it. Bank surveillance footage
does not stay around long at the banks. So sometimes, by the
time you request it, it's not available.
Q.
And did you try to get any ATM footage for the
rapid! Pay transactions that were associated with
Mr. Foster's name?
A.
I think we were trying to find footage for all the
cards, to be honest with you.
Q.
Okay. And were you able to get footage for any of
them?
A.
I don't think we were able to get any footage. It
had been too long.
Q.
So you weren't able to get footage not just for
Mr. Foster, but for any rapid! PayCard; correct?
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A.
Correct.
Q.
You didn't get any documents associated with these
transactions; is that correct? Like receipts or things like
that?
A.
What kind of receipts? Like store receipts?
Q.
Yes.
A.
No.
Q.
Okay. You had issued a grand jury subpoena to
Bellator Phront Group; is that right?
A.
Yes.
Q.
And that was in the summer of 2020?
A.
That sounds right.
Q.
Okay. And so Mr. Thomas was supposed to provide
responses to that subpoena; is that correct?
A.
He was.
Q.
And did he provide responses to that subpoena?
A.
Limited.
Q.
And were those responses truthful?
A.
I think there were some untruthful documents that
were provided.
Q.
And do you know who created some of those
documents?
A.
Who created them for the response?
Q.
Yes, sir.
A.
I'm not sure who actually put the documents
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together for the response.
THE COURT: Ms. Webster -- sorry, go ahead. Go
ahead.
THE WITNESS: I don't know who put the documents
together for the response, whether it was Mr. Thomas or his
attorney or ...
THE COURT: Ms. Webster, hold on for one second,
please.
We're off the record.
(Discussion off the record, and proceedings
continued as follows:)
THE COURT: Sorry for the interruption,
Ms. Webster. You can go ahead.
MS. WEBSTER: Thank you, Your Honor.
BY MS. WEBSTER:
Q.
Agent Stites, are you aware that Gena Pyfrom-Foster
was assisting Darrell Thomas in preparing the fraudulent
documents to submit to the grand jury?
A.
No.
Q.
You are not aware that she participated in that
activity at all?
A.
I don't recall that.
Q.
Okay. At some point Darrell Thomas agreed to come
in for a proffer session with you; is that correct?
A.
Yes, he did.
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Q.
Okay. And so he came in for an interview in which
he agreed to be truthful; is that right?
A.
Yes.
Q.
That's one of the sort of primary concerns that you
have when someone comes in for a proffer statement; you want
them to be truthful?
A.
Yes.
Q.
Okay. And so he agreed to be truthful and provide
you with accurate and complete information?
A.
Correct.
Q.
Okay. But he didn't do that, did he?
MS. CHAIKEN: Your Honor, may we approach, please?
THE COURT: We're off the record.
(Off-the-record discussion, and proceedings
continued:)
THE COURT: Back on the record.
(Sidebar discussion on the record as follows:)
MS. CHAIKEN: Your Honor, Ms. Webster has just
asked about Darrell Thomas being untruthful in a proffer, in
a proffer interview, that's 608, 404(b).
There is no purpose other than to impeach the
credibility of somebody who is not testifying and to show
that he's a liar. There's no proper purpose for it.
MS. WEBSTER: Specifically, I anticipate that the
agent would testify that during the interview that Darrell
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Thomas repeatedly denied, over and over and over again, that
Gena Pyfrom-Foster was involved in any way, and that was
consistent with the agreement that she had with Darrell
Thomas not -- for her not to be identified.
And I think that is highly relevant to our defense,
and admissible and is not offered for impeachment.
MS. CHAIKEN: Your Honor, there is no purpose for
it. It's hearsay.
THE COURT: I want to put this on the record and
look at the transcript. So this isn't going to work.
(End of sidebar discussion, and proceedings
continued:)
THE COURT: Ladies and gentlemen of the jury,
please step out of the courtroom.
(Jury withdrew from the courtroom at 10:53 a.m.)
THE COURT: We're off the record.
(Off-the-record discussion, and proceedings
continued:)
THE COURT: All right. Let's just start over with
the objection and state the grounds.
The witness was going over Darrell Thomas's proffer
session, and there were some questions about whether or not
he had been truthful in that proffer session.
And just for clarification, Darrell Thomas is not a
witness in this case and no one is anticipating calling
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Mr. Thomas; is that correct, counsel?
MS. CHAIKEN: We're not, Your Honor.
THE COURT: Is the defense calling Mr. Thomas?
MS. WEBSTER: We're not, Your Honor.
MR. MARSHALL: No, Your Honor.
THE COURT: Okay. So nonwitness. Let's start from
there.
Go ahead, Ms. Chaiken.
MS. CHAIKEN: Your Honor, we have not relied on
Darrell Thomas in our case in any way. We have not relied on
his credibility in any way. He has not testified. He has
not identified Teldrin Foster as someone who participated in
the crime with him.
The evidence that he was untruthful in a proffer
session is hearsay that is -- or it's not hearsay; it's
impeachment that he lied, and it's impeachment that's
completely irrelevant to the case because he's not a witness.
And to the extent that defense wants to say that
it's for purposes of showing that he protected Gena
Pyfrom-Foster, again, we haven't relied on him as saying what
Ms. Pyfrom-Foster did or what Mr. Foster did.
But I think getting into this would open the door
to Mr. Thomas's later statements where he explained why he
protected her. Because he did, in a later proffer, admit
that she was involved in the conspiracy with him and that the
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reason why he protected her was because he felt bad for her
because Teldrin Foster had gotten her involved and had been
abusive towards her and he had seen Teldrin Foster hit her,
and he felt bad that -- for her and didn't want to get her in
trouble.
I also think it would open up the door to all of
Darrell Thomas's truthful statements in his proffer, that
Teldrin Foster was involved and that all of the other people
who he talked about in the proffer were involved.
I don't think the defense can slice and dice his
proffer to put before the jury that he was untruthful about
one thing that they think helps their defense and then
prevent the jury from learning everything else Darrell Thomas
said in his proffer. That's the whole point.
He's not a witness. He is not here. We have not
relied on him. His credibility is not at issue. It's just
not relevant to the jury that he was untruthful about one
thing.
THE COURT: Ms. Webster.
MS. WEBSTER: Your Honor, I have a couple of
responses to that.
I mean, first is, you have a witness who had
promised to be truthful and he comes in and he denies the --
the portion that I'm trying to get out is that he
specifically lied about --
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I'm sorry. Can the agent be excused for this part
of this?
THE COURT: Sure. Agent Stites, if you would
please step out of the courtroom.
Thank you.
(Pause.)
MS. WEBSTER: During the interview, Darrell Thomas
went to great lengths to protect Gena Pyfrom-Foster and said
that she was not involved. Those are consistent with the
WhatsApp messages where he is saying --
THE COURT: Again, if you can slow down for all of
us, Ms. Webster.
MS. WEBSTER: Yes.
Those are consistent with his WhatsApp messages
with Ms. Pyfrom-Foster where he says: Don't ever use your
own email address, that you don't exist, basically that we
don't know each other, even when he knew he was under federal
investigation.
So he comes in and he tells the government this.
And then they go back for a second interview later, and he
still doesn't tell them about Gena's involvement until the
government confronts him with it and says "We actually have
all your WhatsApp messages."
So to -- this is entirely relevant to the defense
that we're presenting, which is that Gena Pyfrom-Foster was
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heavily involved and her involvement --
THE COURT: I don't think Ms. Chaiken's argument is
relevance. Is it, Ms. Chaiken?
MS. CHAIKEN: No. It's improper impeachment.
THE COURT: So you don't need to talk to us about
relevance, Ms. Webster.
We all understand how it could be relevant. But I
don't know that that addresses Ms. Chaiken's objection.
MS. WEBSTER: Well, it's not hearsay because it's
not offered for the truth of the matter; right? His
statement saying Gena is not involved, that's not a truth.
So it's not offered for the truth of the matter.
I don't think that -- we're not trying to just
impeach a nontestifying witness, it's not just to cast doubt
on his credibility so I don't think 608 is relevant. So I
think that it's an admissible line of questioning.
And to the idea that it opens the door to all of
his statements coming in, first of all, the government would
be introducing those for the truth of the matter. Right?
So it would be impermissible hearsay and a
confrontation clause objection or a confrontation clause
issue.
And --
THE COURT: So you basically want just bits and
pieces of his interview to come in but not allow the
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government to put in bits and pieces? Is that it? That
seems questionable, Ms. Webster.
MS. WEBSTER: We're not playing the interview or
I'm not intending to elicit any direct statements, just sort
of the general nature of the fact that he denied Gena's
involvement.
THE COURT: Maybe I'll let it in and we'll see what
the government wants in as well.
I'm just having trouble with, if you want this in,
or that argument, why the government wouldn't come back
and -- I mean, we may need to let the jury know we're not
going to be wrapping up.
Maybe this opens the door pretty wide to some other
things. I don't know.
MS. WEBSTER: Your Honor, if they want to bring
Darrell Thomas in, we're happy to cross-examine him.
But the fact that we're asking about a nontruthful
statement that he made in a proffer doesn't open the door to
everything that he has ever said because that obviously
invites hearsay and confrontation clause issues. And we have
the right to cross-examine him.
THE COURT: He's not a witness. You certainly have
the right to cross-examine him if the government brought him
in, but he's not here. The government has not called him.
You could call him too, if you wanted to.
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MS. WEBSTER: I'm not sure -- well, the logistics
of that, I think, are pretty difficult.
But I think it's also relevant to show the impact
on the investigation.
But if what the government is suggesting is that
they are able to bring in any statement that he has made
because I elicit that he concealed Gena's involvement, that
they can bring in any statement that he made, including for
the truth of the matter, then that does give rise to a major
confrontation clause issue, and also for the --
THE COURT: But aren't you offering it for the
truth of the matter as well?
You keep making this, oh, it's not being offered
for the truth, but it seems like it is.
MS. WEBSTER: His statement isn't true, Your Honor.
When he says Gena was not involved, she didn't know
anything, she was not involved. That is not true.
THE COURT: Ms. Chaiken.
MS. CHAIKEN: Your Honor, I agree it's not a
hearsay issue as far as that statement goes because they are
offering it to prove that it was false.
The issue is that they are trying to cross-examine
somebody who has not testified.
And if Darrell Thomas were here as a witness and
they asked him about his prior attempts to cover up Gena
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Pyfrom-Foster's involvement, we would certainly be entitled
to get up and say "Why did you lie? Why did you cover it
up?" and to get into his reasons for that.
They're trying to use the fact that he's not here
to get in only the fact that he lied, without getting into
his later explanation for why he lied.
And they are also --
THE COURT: I think -- I mean, that's the point. I
think this is a rule of completeness issue.
Ms. Chaiken, if I understand your objection, you
are objecting because you are almost putting them on notice,
hey, if you are asking that, we're going to get up and ask
this.
Is that correct?
MS. CHAIKEN: That, too. But we also still don't
have an understanding of what the purpose is of admitting
that testimony other than to call Darrell Thomas a liar and
to essentially impeach his credibility, which is not
permissible under Rule 608 or under Rule 404(b).
He protected other people in the interview, too.
He also lied to us about his wife, Meghan Thomas, not being
involved and about Jesika Blakely, who is another person he
had a personal relationship with at the time, not being
involved. But he did not falsely inculpate anyone.
And again, I think this gets us back into the
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guilty plea issue because I think the suggestion that Darrell
Thomas -- using the fact that he protected Gena Pyfrom-Foster
to say that he falsely inculpated Teldrin Foster I think is a
leap that they are trying to draw from this.
And again, I think it would open the door to us
asking our agent, "Did he tell you in that interview that
certain people weren't involved that he wanted to protect?"
The answer to that would be "yes."
And then the next question would be, "Did he tell
you if anyone was involved who did not end up being involved
or who your evidence did not show was involved?"
And the answer to that, I think, would be "no."
The fact that someone tries to falsely exculpate
people is not in any way connected to falsely inculpating
people.
THE COURT: Let me ask, Ms. Webster, so I guess
your primary argument is improper impeachment?
MS. CHAIKEN: Yes. And 404(b).
THE COURT: All right.
So what's your response to improper impeachment,
Ms. Webster?
MS. WEBSTER: It's not about his credibility. It's
not offered to impeach him or to show that he is not a
credible person.
The purpose would only be to show that he was
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protecting Gena Pyfrom-Foster. So when the government says
that they haven't heard a proper purpose, that is the
purpose.
THE COURT: Ms. Chaiken.
MS. CHAIKEN: We haven't relied on Darrell Thomas.
If we had relied on Darrell Thomas, then it would be
important for the jury to know that he may have protected
Ms. Pyfrom-Foster. But we have not put Darrell Thomas on the
stand to say Teldrin Foster did this, Gena Foster did that.
And the defense knows very well from the recent
302s that we have produced that Darrell Thomas eventually did
explain exactly what Teldrin Foster did and what Gena
Pyfrom-Foster did, and he explained to us why he protected
Gena Pyfrom-Foster. They can't keep that from the jury.
THE COURT: Ms. Webster.
MS. CHAIKEN: And I would just note, Your Honor,
from the defense's own response in opposition to our motion
about the guilty pleas, they said Mr. Foster will argue that
Darrell Thomas is someone who used deceit.
That's exactly what they are now saying they are
not trying to do, but they continue trying to elicit evidence
that Darrell Thomas is a liar.
We all know he's a liar. He's been convicted of
fraud. But Darrell Thomas's credibility is not at issue for
this jury in this trial.
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THE COURT: Ms. Webster?
MS. WEBSTER: Your Honor, our defense is that --
THE COURT: Can you move the mic a little closer to
you, please.
MS. WEBSTER: Our defense is that Gena
Pyfrom-Foster and Darrell Thomas were working together. This
is relevant to our defense. I think it's admissible. I
don't think that it opens the door to statements or to issues
that would deprive us to our right to confront the witness
and to -- and information that was then being offered for the
truth of the matter.
I would note that I have -- like, the questions
about that are very limited. It would be that he concealed
Gena's involvement. They went back for a second interview.
He said he was going to be truthful. He also started that
interview concealing Gena's involvement and that he finally
acknowledged her involvement after the government confronted
him with the WhatsApp messages. And that's the extent of it.
THE COURT: Well, going back to the question that
was objected to, it was simply about whether or not he was
truthful.
It was: "At some point Darrell Thomas agreed to
come in for a proffer session with you; is that correct?
"Yes, he did."
And a few questions later: "So he agreed to be
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truthful and provide accurate and complete information?"
"Correct" is the answer.
Question: "But he didn't do that, did he?"
So you are simply -- the only thing I'm ruling on
right now is the objection to that question. And that seems
to clearly go to whether or not he was truthful.
How is it -- how is the objection to that question
any more than that, Ms. Webster?
MS. WEBSTER: Well, Your Honor, because the next
question was going to be --
THE COURT: I'm not ruling on the next question;
I'm ruling on this question.
MS. WEBSTER: Well, I can withdraw that question.
But then the next question is: He lied to you
about Gena Pyfrom-Foster's involvement.
THE COURT: All right. Anything else, Ms. Chaiken?
Your motion -- or your objection?
MS. CHAIKEN: No, Your Honor.
THE COURT: All right. I'm going to need to take a
break and look at this in a little bit more detail.
We're off the record.
(Off the record at 11:12 a.m.)
(Lunch recess was taken.)
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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 Monday, February 12, 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 12th day of February, 2024.
___________________________
/s/ Judith M. Wolff, RPR, CRR
Official Court Reporter
Monday, February 12, 2024 Volume 6 Morning Session
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BY MS. WEBSTER: [13] 14/18 19/24
21/22 23/16 28/8 28/14 28/25 29/22
31/22 38/22 39/15 41/20 44/15
COURT SECURITY OFFICER: [1] 28/1
COURTROOM DEPUTY: [1] 28/4
MR. MARSHALL: [3] 2/8 12/5 47/5
MS. CHAIKEN: [19] 3/4 5/24 6/3
16/18 17/2 18/2 30/21 45/12 45/18
46/7 47/2 47/9 50/4 52/19 53/15
54/18 55/5 55/16 57/18
MS. WEBSTER: [40] 8/14 9/5 9/7 9/9
10/8 10/21 13/18 13/23 14/16 16/19
16/25 17/24 21/11 21/16 21/18 21/21
23/4 23/15 27/21 30/10 31/15 38/20
39/13 41/18 44/14 45/24 47/4 48/20
49/7 49/13 50/9 51/3 51/15 52/1
52/15 54/22 56/2 56/5 57/9 57/13
THE COURT: [65]
THE WITNESS: [3] 21/17 21/19 44/4
$
$1,000 [1] 29/17
$2,000 [1] 29/17
$60,000 [1] 27/14
$90,000 [2] 33/24 34/21
'
'cause [2] 33/4 33/20
/
/s [1] 58/23
1
10 [1] 36/20
10:00 [1] 2/14
10:06 [1] 14/8
10:10 [1] 17/8
10:20 [1] 23/11
10:53 [1] 46/15
11:12 [1] 57/23
12 [2] 1/12 58/10
12th [1] 58/20
1317 [1] 1/24
1914 [1] 1/23
198 [2] 39/19 39/20
199 [1] 39/16
1:20-CR-00296-JPB-5-20 [2] 1/5 58/12
2
20 [2] 1/5 58/12
2016 [1] 33/20
2019 [1] 3/10
2020 [11] 14/22 15/17 20/1 20/6
20/12 23/18 23/23 36/21 36/24 42/2
43/11
2021 [2] 20/19 20/21
2024 [3] 1/12 58/10 58/20
215-1317 [1] 1/24
2954 [2] 38/21 38/24
3
30 [3] 32/24 32/24 33/13
302s [1] 55/11
30303-3361 [1] 1/24
3361 [1] 1/24
4
403 [1] 17/21
404 [8] 1/24 3/11 3/24 4/23 5/11
45/20 53/19 54/18
45 [1] 32/12
46 [1] 12/13
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50 [3] 27/14 32/13 33/1
51 [1] 40/1
52 [2] 39/25 40/4
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60 [2] 32/25 33/1
608 [3] 45/20 50/15 53/19
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75 [1] 1/23
9
90 [2] 1/7 33/25
940 [2] 35/15 35/19
941 [1] 35/15
944 [1] 35/18
9:45 [1] 2/2
A
a.m [6] 2/2 14/8 17/8 23/11 46/15
57/23
able [9] 2/22 12/25 23/17 28/15 30/5
42/20 42/22 42/24 52/6
about [44] 3/6 6/9 6/10 8/20 9/21
10/10 10/15 11/1 11/12 15/20 15/21
16/11 19/19 20/1 22/13 23/2 23/4
25/5 25/11 27/17 33/6 33/6 36/15
37/5 37/12 37/15 39/21 45/19 46/22
48/9 48/11 48/17 48/25 49/21 50/5
51/17 52/25 53/21 53/22 54/22 55/18
56/13 56/20 57/15
aboveboard [1] 3/18
abusive [1] 48/3
account [2] 4/11 4/11
accounts [4] 37/24 38/3 38/9 41/5
accurate [5] 24/16 42/5 45/9 57/1
58/18
ACH [1] 41/4
acknowledged [1] 56/17
actions [2] 22/9 24/19
activity [1] 44/21
actual [5] 19/12 31/10 31/17 38/13
42/4
actually [7] 22/23 34/24 40/1 40/8
41/13 43/25 49/22
add [2] 12/5 35/24
additional [1] 23/7
address [3] 5/3 12/20 49/16
addressed [1] 12/7
addresses [5] 3/11 9/10 12/8 21/11
50/8
addressing [1] 5/18
admissible [5] 3/24 11/6 46/6 50/16
56/7
admission [1] 5/3
admit [10] 2/20 7/18 7/19 13/16
30/12 30/16 30/25 31/11 31/16 47/24
admitted [6] 7/21 7/24 30/19 30/25
31/18 31/20
admitting [2] 31/12 53/16
adopt [2] 12/6 12/11
Advertising [1] 15/22
advised [2] 26/24 27/2
affect [2] 17/19 19/2
after [6] 1/11 6/16 17/13 19/6 22/9
56/17
again [8] 3/1 3/2 3/24 46/1 47/20
49/11 53/25 54/5
agencies [1] 15/7
agent [40] 10/10 14/15 14/19 18/25
19/25 21/8 22/6 23/17 28/15 29/1
29/12 29/21 30/14 31/23 32/5 32/8
32/12 32/15 32/17 32/21 33/2 33/22
33/25 34/3 34/5 34/9 35/5 35/7 35/14
35/17 35/23 38/23 41/21 41/24 42/7
44/16 45/25 49/1 49/3 54/6
Agent Stites [1] 18/25
agents [2] 15/4 26/20
ago [1] 34/8
agree [4] 13/15 20/24 31/24 52/19
agreed [8] 26/1 26/2 26/6 44/23 45/2
45/8 56/22 56/25
agreement [5] 2/23 8/5 8/10 13/9
46/3
agreements [1] 12/18
agrees [1] 18/2
ahead [6] 19/22 23/14 44/2 44/3
44/13 47/8
AI [1] 1/18
ain't [1] 29/20
AJC [1] 37/13
all [47] 2/4 2/7 2/9 2/12 2/15 2/22
3/18 4/13 6/22 7/1 7/6 8/12 8/23
10/4 10/8 11/5 13/13 14/2 14/9 17/9
17/10 19/13 23/2 23/12 23/12 29/18
30/7 30/19 30/25 32/10 32/11 39/9
40/7 42/18 44/21 46/19 48/6 48/8
49/11 49/23 50/7 50/17 50/18 54/19
55/23 57/16 57/19
alleged [1] 12/14
allow [1] 50/25
allowed [1] 5/5
almost [1] 53/11
already [3] 11/19 22/12 24/21
also [10] 13/2 15/10 24/22 48/6 52/3
52/10 53/7 53/15 53/21 56/15
altogether [1] 32/25
always [1] 9/14
AM [1] 1/5
Amanda [4] 15/15 18/3 18/17 19/7
AMERICA [2] 1/4 58/11
amount [2] 32/19 36/10
analysis [1] 42/7
Ann [1] 1/19
another [5] 3/13 17/2 27/2 35/5
53/22
answer [5] 12/25 19/9 54/8 54/12
57/2
anticipate [2] 30/11 45/24
anticipated [1] 13/3
anticipating [2] 13/18 46/25
any [31] 1/13 6/21 7/18 7/18 7/25
10/2 10/5 11/1 11/21 12/20 17/23
18/19 18/19 24/19 30/17 31/9 35/9
42/6 42/15 42/20 42/22 42/25 43/2
46/2 47/10 47/11 51/4 52/6 52/8
54/14 57/8
anybody's [1] 30/5
anyone [2] 53/24 54/10
anything [10] 12/19 18/12 18/18
18/25 19/7 19/10 36/2 36/17 52/17
57/16
appear [1] 9/21
appearance [2] 33/16 33/16
Appearances [1] 1/15
appreciate [1] 2/13
appreciated [1] 14/13
approach [3] 10/24 17/4 45/12
approximately [1] 39/16
April [1] 14/22
are [50] 1/12 2/15 2/25 3/21 7/12
7/17 7/19 9/21 11/4 11/10 11/12
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31/3 31/10 31/17 32/1 33/7 33/8 33/8
38/4 38/25 39/16 44/16 44/20 49/9
49/14 52/2 52/6 52/20 52/22 53/7
53/11 53/11 53/12 54/4 55/20 55/20
56/13 57/4
aren't [4] 5/2 5/4 5/9 52/11
argue [1] 55/18
argued [1] 12/3
argument [5] 8/16 12/21 50/2 51/10
54/17
arguments [3] 3/2 12/6 13/12
around [1] 42/13
arrest [1] 37/4
arrested [3] 36/23 37/2 40/19
article [2] 19/1 19/4
articles [1] 37/12
ask [6] 19/6 21/13 23/8 25/21 53/12
54/16
asked [13] 6/23 8/20 9/18 9/18 10/11
10/13 25/20 35/17 35/24 35/25 42/7
45/19 52/25
asking [5] 13/21 21/14 51/17 53/12
54/6
asserted [1] 5/1
assisting [1] 44/17
associated [3] 15/21 42/16 43/2
ATLANTA [3] 1/2 1/24 58/7
ATM [2] 41/3 42/15
attached [1] 1/9
attaching [1] 1/12
attempts [1] 52/25
attorney [4] 26/17 26/18 26/20 44/6
Attorney's [1] 26/19
audio [7] 27/25 28/13 28/24 29/25
31/2 31/10 31/17
August [11] 15/17 19/25 20/4 20/18
20/21 22/4 23/18 36/23 37/3 37/4
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August... [1] 40/19
authorized [2] 27/22 38/16
available [1] 42/14
aware [3] 24/4 44/16 44/20
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Babasijibomi [1] 1/17
back [17] 3/5 5/23 6/2 11/17 14/12
17/10 31/12 32/9 32/18 32/21 36/1
45/16 49/20 51/10 53/25 56/14 56/19
bad [2] 48/1 48/4
bank [4] 12/16 41/4 42/10 42/12
banks [1] 42/13
Baptiste [2] 3/10 4/24
barber [1] 29/9
based [7] 4/7 4/8 4/22 8/17 18/11
18/18 22/10
basically [5] 3/12 3/21 37/21 49/16
50/24
be [50] 1/5 1/6 2/14 3/24 9/21 11/18
12/25 13/3 14/9 17/9 17/17 17/20
18/11 18/15 20/14 23/12 24/12 25/7
26/25 28/12 28/21 29/24 30/5 30/8
30/17 31/14 36/12 39/18 40/7 42/19
45/2 45/6 45/8 46/4 48/23 49/1 50/7
50/19 50/20 51/12 53/1 54/8 54/9
54/12 54/25 55/6 56/13 56/15 56/25
57/10
because [27] 3/5 4/9 4/25 5/4 5/10
8/5 9/11 11/11 16/7 18/24 22/20
29/19 30/9 31/23 33/11 38/16 47/17
47/24 48/1 48/2 50/9 51/19 52/7
52/20 53/11 54/1 57/9
been [21] 3/6 4/25 5/4 6/22 7/10
7/11 7/12 9/13 10/3 10/6 11/19 25/4
27/23 30/13 30/17 36/7 36/10 42/23
46/23 48/2 55/23
before [11] 1/11 2/10 3/23 15/19
17/18 19/11 20/8 20/11 21/1 25/15
48/11
began [2] 14/19 37/20
beginning [1] 38/7
behind [1] 38/12
being [10] 14/12 14/12 24/6 30/11
45/19 52/13 53/21 53/23 54/10 56/10
belief [1] 13/8
believe [13] 11/19 22/19 23/24 24/17
35/14 37/7 37/11 39/25 40/14 41/12
41/21 42/4 42/5
believed [1] 36/11
Bellator [4] 38/8 39/10 39/23 43/9
benefits [1] 6/7
Berni [2] 41/24 42/8
between [3] 20/4 32/24 33/1
big [1] 34/24
bit [5] 9/3 25/14 26/21 27/17 57/20
bits [2] 50/24 51/1
Blakely [1] 53/22
both [1] 9/6
bottom [1] 39/14
BOULEE [1] 1/11
branch [1] 12/16
break [1] 57/20
Brenda [8] 4/18 6/11 8/5 8/6 8/7 8/8
8/10 10/22
bring [10] 2/11 2/14 14/4 23/6 23/9
26/19 35/15 51/15 52/6 52/8
bringing [1] 12/18
brought [2] 7/5 51/23
build [2] 29/14 29/14
bullshitted [1] 33/6
bunch [1] 17/18
business [13] 3/16 3/19 3/22 3/25
4/3 5/6 8/23 9/2 9/12 28/21 29/20
34/8 37/23
buy [2] 40/25 41/2
C
call [6] 12/23 13/8 25/23 25/24
51/25 53/17
called [6] 2/2 18/13 18/18 24/10
24/12 51/24
calling [3] 13/3 46/25 47/3
came [5] 17/21 27/7 33/21 35/8 45/1
can [41] 2/4 8/10 9/3 9/5 13/1 13/23
14/5 14/9 14/14 14/19 17/9 19/6
19/14 19/17 19/18 20/20 21/21 23/12
23/14 25/7 29/4 29/13 29/14 29/14
30/4 30/14 30/15 30/16 31/6 31/25
32/23 33/19 38/20 42/5 44/13 48/10
49/1 49/11 52/8 56/3 57/13
can't [4] 30/1 30/2 36/9 55/14
cannot [1] 11/24
capable [1] 3/25
capacity [2] 3/23 4/19
card [6] 39/5 39/8 39/22 40/2 40/3
41/3
cards [5] 40/10 40/25 41/7 41/14
42/19
CARLA [2] 1/6 58/11
case [20] 3/9 3/11 3/14 4/5 4/22
4/24 7/12 8/7 10/11 11/23 12/1 14/24
15/9 20/9 26/20 42/10 46/25 47/10
47/17 58/12
cases [4] 5/2 5/4 5/9 5/17
cash [1] 41/10
cashing [2] 3/15 3/20
cast [1] 50/14
CDC [2] 22/20 24/12
cell [2] 41/22 42/7
certain [1] 54/7
certainly [2] 51/22 53/1
CERTIFICATE [1] 58/2
Certified [3] 1/19 58/2 58/5
certify [1] 58/7
Chaiken [13] 1/16 3/2 12/3 13/15
13/22 17/25 19/20 47/8 50/3 52/18
53/10 55/4 57/16
Chaiken's [2] 50/2 50/8
chain [1] 10/1
changed [1] 33/17
charged [13] 6/20 7/1 7/2 7/2 7/7
7/12 10/3 10/6 10/11 11/5 12/14
15/24 20/8
charging [1] 6/21
check [5] 2/11 3/15 3/20 12/16 28/4
Christian [8] 15/15 18/17 19/7 22/14
22/25 24/5 24/24 25/2
Christian's [1] 18/3
circle [1] 17/10
Circuit [3] 3/10 3/21 4/6
cite [1] 1/9
clarification [1] 46/24
clarified [1] 8/21
clause [6] 7/17 8/4 50/21 50/21
51/20 52/10
clear [9] 4/24 8/4 9/14 11/23 12/1
17/14 29/3 31/16 40/7
clearly [4] 6/4 7/10 7/11 57/6
clips [4] 25/6 27/11 27/13 31/17
close [1] 40/23
closer [1] 56/3
clubs [1] 33/5
CM [2] 1/5 1/6
CM/ECF [2] 1/5 1/6
codefendant [3] 5/6 7/19 13/19
codefendant's [2] 5/19 11/24
codefendants [8] 6/9 6/15 8/11 11/2
11/3 11/4 11/8 12/19
codefendants's [1] 2/20
collect [1] 15/1
column [1] 39/4
come [10] 6/19 14/5 26/1 26/2 26/6
37/23 44/23 50/25 51/10 56/23
comes [4] 5/13 45/5 48/23 49/19
coming [1] 50/18
commit [1] 4/21
communicate [3] 9/22 9/24 9/25
communicated [6] 8/22 10/12 10/13
10/14 11/8 38/1
communicating [5] 8/23 8/24 9/2 9/12
9/15
communication [2] 7/7 10/2
company [1] 39/11
complete [2] 45/9 57/1
completed [1] 2/16
completely [2] 7/3 47/17
completeness [3] 27/23 30/7 53/9
comprehensible [1] 31/24
concealed [2] 52/7 56/13
concealing [1] 56/16
concern [1] 9/11
concerned [1] 9/21
concerns [1] 45/4
conducted [1] 15/10
confirm [2] 23/17 42/5
confirming [1] 22/4
confront [1] 56/9
confrontation [7] 7/17 8/4 12/25
50/21 50/21 51/20 52/10
confronted [1] 56/17
confronts [1] 49/22
connected [1] 54/14
connection [1] 58/14
consider [2] 6/11 8/17
consistent [3] 46/3 49/9 49/14
conspiracy [5] 7/22 7/23 11/14 40/12
47/25
conspiring [1] 11/5
context [2] 5/3 5/13
continue [2] 14/14 55/21
continued [6] 5/22 14/17 44/11 45/15
46/12 46/18
contradicted [1] 7/16
conversation [1] 26/3
convicted [1] 55/23
convictions [2] 11/24 13/19
cooperating [1] 13/6
cooperator [1] 5/13
coordinate [1] 26/18
correct [31] 15/8 15/14 16/3 20/16
20/17 21/4 22/7 24/6 25/16 35/2
36/21 36/22 37/17 37/22 37/25 40/16
41/7 41/25 42/3 42/8 42/9 42/25 43/1
43/3 43/14 44/24 45/10 47/1 53/14
56/23 57/2
could [12] 6/22 8/6 10/25 17/4 18/24
23/9 26/11 33/4 39/13 42/12 50/7
51/25
counsel [2] 11/20 47/1
Count [1] 12/13
couple [3] 22/14 38/5 48/20
course [1] 40/16
court [19] 1/6 1/11 1/13 1/17 1/19
1/1 1/11 1/22 1/22 2/2 2/17 3/9 9/6
14/1 18/21 58/5 58/6 58/10 58/24
courthouse [2] 1/23 31/2
courtroom [6] 14/8 17/8 23/11 46/14
46/15 49/4
cover [2] 52/25 53/2
cr [2] 1/5 58/12
crazy [1] 33/15
created [2] 43/21 43/23
credibility [7] 45/22 47/11 48/16
50/15 53/18 54/22 55/24
credible [1] 54/24
credit [1] 29/16
crime [1] 47/13
cross [9] 13/1 13/20 14/15 14/17
25/11 51/16 51/21 51/23 52/22
cross-examination [3] 13/20 14/15
14/17
cross-examine [4] 51/16 51/21 51/23
52/22
CRR [2] 1/22 58/23
D
Darrell [54] 4/10 4/18 6/5 6/5 6/6
6/15 6/16 7/7 7/8 7/13 7/13 8/21 9/1
9/12 9/22 9/24 10/13 13/3 13/7 13/9
27/15 28/20 34/7 34/17 34/23 36/23
37/20 38/1 40/11 40/18 44/17 44/23
45/19 45/25 46/3 46/21 46/24 47/10
48/7 48/13 49/7 51/16 52/24 53/17
54/1 55/5 55/6 55/8 55/11 55/19
55/22 55/24 56/6 56/22
data [2] 41/22 42/2
date [1] 20/22
dates [1] 22/4
David [4] 1/18 32/14 32/16 34/17
day [4] 21/19 25/15 41/10 58/20
days [2] 1/7 25/4
deal [1] 7/13
debated [1] 17/13
deceit [1] 55/19
deceived [4] 4/5 5/7 5/8 8/1
deceiving [1] 4/4
December [3] 20/5 20/12 36/20
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deception [2] 5/19 6/6
decisions [1] 6/21
defendant [6] 1/18 1/19 3/15 4/5 5/4
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Defendant's [1] 31/20
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defense [26] 3/7 3/7 3/12 3/16 4/7
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48/12 49/24 55/10 56/2 56/5 56/7
defense's [1] 55/17
denied [2] 46/1 51/5
denies [1] 48/23
Department [1] 37/10
deposited [1] 12/16
deprive [1] 56/9
description [1] 8/18
despite [1] 7/7
detail [1] 57/20
detailed [1] 3/1
details [1] 17/23
develop [1] 16/24
dice [2] 6/8 48/10
did [60]
didn't [16] 5/16 5/17 17/10 17/19
18/17 24/14 26/11 26/13 29/19 31/16
33/18 43/2 45/11 48/4 52/16 57/3
different [3] 30/18 30/24 38/5
difficult [3] 26/15 29/1 52/2
direct [11] 10/20 25/5 25/8 25/10
25/10 25/12 34/12 37/15 40/2 40/3
51/4
directly [2] 9/15 10/13
discovery [5] 20/15 20/18 20/21
20/23 20/25
discussed [3] 16/23 25/8 34/11
discussing [1] 18/22
discussion [8] 2/10 2/16 5/21 44/10
45/14 45/17 46/11 46/17
dispute [1] 11/21
District [6] 1/19 1/1 1/1 1/11 58/6
58/6
DIVISION [1] 1/2
Dixon [1] 40/12
do [42] 3/23 8/9 8/11 10/18 12/2
12/18 13/17 13/22 13/25 16/24 18/8
18/12 18/12 18/18 19/7 19/10 19/14
19/22 20/1 21/13 21/20 25/4 26/6
29/10 29/14 29/14 30/2 30/8 31/6
31/6 32/22 35/9 35/24 36/8 39/22
41/14 42/8 43/21 45/11 55/21 57/3
58/7
docket [2] 1/10 1/4
document [8] 1/13 15/19 16/5 20/2
20/4 20/13 21/23 29/4
documents [8] 4/14 6/7 43/2 43/19
43/22 43/25 44/4 44/18
Doe [3] 18/8 18/9 18/15
does [4] 35/19 40/22 42/13 52/9
doesn't [6] 6/11 7/21 12/19 19/4
49/21 51/18
doing [4] 13/22 30/17 33/4 36/2
dollars [3] 33/15 41/10 41/10
don't [41] 2/24 7/15 10/8 12/2 13/16
17/22 20/3 20/13 20/22 22/2 22/19
22/19 22/24 22/25 23/24 24/17 26/3
26/5 28/16 29/2 29/20 30/2 30/4 30/9
30/16 30/23 42/22 44/4 44/22 48/10
49/15 49/16 49/17 50/2 50/5 50/8
50/13 50/15 51/14 53/15 56/8
done [2] 3/23 41/18
door [9] 3/8 5/14 47/22 48/6 50/17
51/13 51/18 54/5 56/8
doubt [1] 50/14
down [6] 9/3 26/6 27/7 38/9 39/13
49/11
drafting [1] 12/13
draw [1] 54/4
Drive [1] 1/23
dude [3] 29/18 32/14 32/16
duped [3] 3/16 3/19 8/1
duping [2] 3/25 4/4
during [6] 13/11 17/16 35/2 40/15
45/25 49/7
Durrett [1] 1/19
duties [1] 15/1
E
each [3] 6/11 39/22 49/17
earlier [1] 16/21
early [2] 12/17 13/6
ECF [2] 1/5 1/6
effect [7] 16/20 17/21 18/19 18/19
18/23 19/5 19/11
effects [2] 18/6 18/7
either [1] 30/2
Eleventh [3] 3/10 3/21 4/6
elicit [3] 51/4 52/7 55/21
elicited [2] 4/8 8/19
eliminate [2] 7/25 11/21
Elite [1] 38/8
else [7] 9/25 10/14 13/17 17/19 33/3
48/13 57/16
email [2] 4/11 49/16
emails [1] 36/1
employed [1] 41/13
employee [2] 36/5 36/7
end [4] 9/22 29/19 46/11 54/10
enters [2] 14/8 23/11
entire [4] 4/20 4/22 8/16 18/25
entirely [4] 4/9 11/6 11/14 49/24
entitled [1] 53/1
entries [2] 39/17 39/20
entry [1] 1/10
Esq [6] 1/16 1/16 1/17 1/18 1/19
1/19
essentially [1] 53/18
establish [1] 19/16
established [2] 19/14 29/16
establishes [1] 9/1
even [5] 22/20 29/19 29/20 35/15
49/17
eventually [5] 17/21 37/20 38/8 41/3
55/11
ever [3] 4/10 49/15 51/19
every [1] 13/19
everyone [2] 2/6 18/2
everything [2] 48/13 51/19
evidence [20] 2/20 3/11 3/12 3/18
3/22 4/2 4/9 4/13 5/5 5/12 10/22
11/8 11/12 11/20 30/22 31/18 31/21
47/14 54/11 55/21
exact [4] 14/21 14/21 20/3 36/9
exactly [5] 8/11 23/24 40/23 55/12
55/20
examination [3] 13/20 14/15 14/17
examine [4] 51/16 51/21 51/23 52/22
exculpate [1] 54/13
excused [1] 49/1
Executive [1] 38/8
exhibit [6] 21/17 21/18 31/20 38/21
38/24 41/18
Exhibit 2954 [1] 38/24
exist [1] 49/16
experience [1] 36/18
explain [1] 55/12
explained [4] 18/21 19/21 47/23
55/13
explanation [1] 53/6
extent [4] 13/11 31/9 47/18 56/18
F
F40A [3] 27/23 30/12 31/20
F40C [1] 29/23
F40E [2] 27/23 31/20
fact [12] 2/21 6/20 7/19 12/15 22/16
40/18 51/5 51/17 53/4 53/5 54/2
54/13
fair [6] 11/14 28/19 31/14 35/8
35/10 36/11
fairly [1] 31/4
false [1] 52/21
falsely [4] 53/24 54/3 54/13 54/14
familiar [1] 36/12
far [2] 19/19 52/20
FEBRUARY [3] 1/12 58/10 58/20
federal [1] 49/17
feel [1] 10/23
fell [2] 29/16 33/11
felt [3] 24/11 48/1 48/4
few [4] 2/24 9/14 36/10 56/25
figured [3] 24/8 41/4 41/6
filed [4] 1/5 1/11 1/13 6/20
filing [1] 4/19
fill [1] 35/13
finally [1] 56/16
Finance [2] 22/20 24/12
find [2] 5/17 42/18
fine [1] 30/7
first [12] 2/10 2/19 3/3 8/16 24/14
39/4 39/6 39/7 39/8 39/18 48/22
50/18
five [1] 2/12
following [1] 1/3
follows [2] 44/11 45/17
footage [7] 42/11 42/12 42/15 42/18
42/20 42/22 42/24
foregoing [1] 58/17
foremost [2] 2/10 2/19
form [3] 35/13 35/15 58/15
forms [2] 35/9 36/16
forth [2] 12/6 12/24
forwarding [1] 36/1
FOSTER [73]
Foster's [7] 4/20 8/3 25/8 40/2
42/17 53/1 57/15
found [1] 24/23
foundation [2] 16/20 23/7
four [1] 33/14
frame [3] 4/12 15/18 16/25
fraud [6] 4/12 4/21 7/25 12/15 34/13
55/24
fraudulent [2] 3/15 44/17
free [1] 5/15
front [2] 10/17 18/25
fuck [3] 32/11 32/11 33/13
fucked [1] 33/23
fucking [2] 32/13 33/18
full [2] 1/12 22/12
funds [2] 37/21 37/23
G
Gaines [1] 12/22
gand.uscourts.gov [1] 1/25
Gena [17] 25/16 40/6 44/16 46/2
47/19 49/8 49/25 50/11 52/16 52/25
54/2 55/1 55/9 55/12 55/14 56/5
57/15
Gena's [5] 49/21 51/5 52/7 56/14
56/16
general [1] 51/5
generally [2] 5/12 26/18
gentlemen [3] 14/11 17/6 46/13
GEORGIA [3] 1/1 1/24 58/7
get [24] 2/15 14/5 15/4 15/6 21/7
26/11 26/13 29/15 29/16 32/21 35/14
41/14 42/12 42/15 42/20 42/22 42/24
43/2 48/4 48/24 53/2 53/3 53/5 53/12
gets [1] 53/25
getting [4] 17/18 41/6 47/22 53/5
give [4] 22/17 25/22 35/12 52/9
given [1] 31/1
giving [1] 29/17
go [16] 3/3 18/16 19/17 19/19 19/19
19/22 23/14 33/4 35/14 39/25 44/2
44/2 44/13 47/8 49/20 57/6
goes [1] 52/20
going [25] 10/20 11/3 11/17 19/19
23/5 28/9 30/5 30/7 30/8 30/23 31/11
31/12 35/12 35/14 36/14 38/7 38/10
46/10 46/21 51/12 53/12 56/15 56/19
57/10 57/19
going-in [1] 36/14
gonna [1] 33/13
Good [3] 2/6 2/8 14/11
got [15] 2/12 3/6 5/15 16/2 20/23
24/18 24/25 29/20 29/20 32/8 32/17
38/25 39/2 41/21 42/10
gotten [1] 48/2
government [20] 1/16 9/18 10/22
10/23 11/11 11/11 13/1 13/3 13/6
49/19 49/22 50/18 51/1 51/8 51/10
51/23 51/24 52/5 55/1 56/17
government's [9] 2/19 9/10 11/4
11/18 12/7 12/10 12/12 38/20 38/23
grand [4] 32/13 33/13 43/8 44/18
great [1] 49/8
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greatly [1] 14/12
Green's [1] 6/23
grounds [1] 46/20
Group [3] 39/10 39/23 43/9
guess [4] 2/10 10/15 20/7 54/16
guilt [1] 7/24
guilty [8] 2/20 5/3 5/16 7/20 7/22
13/16 54/1 55/18
guy [1] 34/17
H
had [50] 3/16 3/17 3/19 4/3 7/7 8/5
8/9 11/8 11/8 11/11 11/11 13/5 15/9
16/14 21/1 22/12 22/16 22/25 24/21
24/22 24/23 25/16 26/4 27/13 27/14
27/22 28/20 28/22 31/13 33/12 34/16
34/20 34/23 34/24 36/7 36/9 36/10
40/19 41/9 41/14 42/23 43/8 46/3
46/23 48/2 48/2 48/3 48/22 53/23
55/6
Hale [5] 34/3 35/7 35/14 35/17 35/24
hand [1] 21/25
handed [1] 21/19
hands [3] 21/23 29/4 40/11
happened [2] 19/25 24/21
happening [1] 38/14
happy [1] 51/16
hard [4] 28/11 28/16 29/2 31/5
harm [1] 11/21
has [33] 1/11 3/7 3/7 3/23 3/23 4/7
4/10 4/14 4/19 5/4 5/7 5/8 5/25 6/4
6/8 6/14 7/10 7/11 11/19 12/3 12/6
12/18 13/22 17/25 19/21 30/13 45/18
47/11 47/11 51/19 51/24 52/6 52/23
have [71]
haven't [5] 19/13 30/19 47/20 55/2
55/5
having [4] 7/7 16/21 33/17 51/9
he [136]
he'll [1] 19/9
he's [10] 25/22 33/15 45/23 47/17
48/15 51/22 51/24 53/4 55/23 55/23
header [1] 39/18
hear [7] 8/12 10/24 11/15 12/4 17/25
28/11 29/1
heard [6] 6/14 6/16 27/10 27/13
28/17 55/2
hearing [1] 58/15
hearsay [13] 16/18 18/4 18/22 18/23
19/12 19/12 46/8 47/15 47/15 50/9
50/20 51/20 52/20
heavily [1] 50/1
heavy [1] 17/21
held [1] 58/10
help [3] 29/14 29/15 29/16
helps [1] 48/12
her [19] 16/2 18/18 22/14 23/1 24/10
24/12 25/20 25/20 46/4 47/24 48/1
48/1 48/2 48/3 48/3 48/4 48/4 50/1
56/17
here [11] 2/15 4/7 5/24 22/20 29/17
29/17 39/4 48/15 51/24 52/24 53/4
Here's [1] 25/23
hereby [1] 58/7
hey [1] 53/12
high [1] 17/17
highly [1] 46/5
him [49] 3/16 5/8 5/8 6/7 12/23 13/1
13/9 19/6 25/21 25/22 26/11 26/13
26/24 27/2 27/4 27/8 28/17 28/22
30/6 32/6 32/7 32/7 32/12 32/14
32/18 32/21 33/4 33/11 33/20 34/20
34/23 35/12 35/13 35/17 35/25 47/13
47/20 47/25 48/16 49/22 51/16 51/21
51/23 51/23 51/24 51/25 52/25 54/23
56/18
his [31] 3/16 3/16 17/16 17/19 19/10
26/24 28/21 33/16 33/16 34/12 34/16
38/2 40/19 44/5 47/11 48/7 48/10
48/14 48/16 49/14 50/10 50/15 50/18
50/25 52/15 52/25 53/3 53/6 53/18
53/21 54/22
hit [4] 33/10 33/18 34/24 48/3
hold [1] 44/7
holding [3] 33/7 33/8 33/8
Holland [3] 38/20 39/13 41/19
honest [3] 20/14 28/12 42/19
Honestly [1] 22/19
Honor [36] 3/4 5/9 5/24 6/4 8/14
14/1 14/16 16/18 16/19 17/2 17/24
18/2 21/11 23/15 27/21 28/1 30/10
30/12 30/21 31/15 44/14 45/12 45/18
46/7 47/2 47/4 47/5 47/9 48/20 51/15
52/15 52/19 55/16 56/2 57/9 57/18
HONORABLE [1] 1/11
hope [1] 2/6
hour [1] 17/14
hours [2] 27/9 27/10
how [15] 3/6 7/1 17/21 19/18 19/19
28/16 32/5 32/10 32/21 33/13 33/22
35/9 50/7 57/7 57/7
however [1] 1/12
hundred [3] 30/24 31/13 33/14
hustled [5] 28/18 28/22 34/10 34/15
34/20
hustling [1] 29/18
hypothetical [1] 13/14
I
I'd [3] 2/13 12/5 12/5
I'll [4] 3/2 20/24 23/7 51/7
I'm [24] 13/21 14/21 15/18 16/25
23/5 28/9 29/23 30/1 31/1 31/6 31/15
32/24 37/14 39/7 43/25 48/24 49/1
51/4 51/9 52/1 57/4 57/11 57/12
57/19
idea [1] 50/17
identified [6] 22/16 24/5 24/21
24/22 46/4 47/12
identities [1] 9/13
identity [1] 8/2
imagine [1] 20/4
impact [1] 52/3
impeach [4] 45/21 50/14 53/18 54/23
impeachment [6] 46/6 47/16 47/16
50/4 54/17 54/20
impermissible [1] 50/20
impersonated [2] 4/11 5/8
implication [7] 7/10 9/11 9/16 10/2
10/6 10/19 18/15
implied [1] 10/8
imply [2] 5/5 8/8
important [1] 55/7
impression [3] 7/11 31/4 36/14
improper [4] 12/12 50/4 54/17 54/20
inaccurate [1] 8/18
inaudible [1] 31/5
included [1] 13/7
including [1] 52/8
inculpate [1] 53/24
inculpated [1] 54/3
inculpating [1] 54/14
indication [1] 22/22
indicted [2] 3/15 37/1
indictment [4] 9/18 9/25 15/25 37/3
indictments [1] 12/13
individual [2] 22/21 24/24
individual's [1] 24/13
info [2] 39/5 39/8
information [6] 15/1 16/15 24/25
45/9 56/10 57/1
instead [2] 31/2 40/10
instructed [2] 11/19 11/19
intend [3] 12/23 19/19 19/20
intending [1] 51/4
intent [1] 2/14
intention [2] 22/13 38/12
internet [1] 4/20
interruption [1] 44/12
interview [33] 15/13 15/19 16/2 17/1
18/3 18/8 18/9 18/12 19/7 22/13
23/18 23/20 24/25 25/1 25/6 25/14
26/7 26/15 26/19 27/7 27/11 36/20
45/1 45/20 45/25 49/7 49/20 50/25
51/3 53/20 54/6 56/14 56/16
interviewed [8] 18/14 19/25 20/11
20/11 22/14 23/1 24/23 25/16
introduce [4] 3/12 8/6 8/10 11/24
introduced [3] 3/7 4/3 11/12
introducing [2] 13/18 50/19
invested [1] 34/16
investigating [1] 26/20
investigation [22] 12/10 12/12 14/20
15/2 15/10 16/8 16/20 17/1 17/16
17/19 18/6 18/7 18/19 18/24 19/2
19/6 19/8 19/10 19/11 40/16 49/18
52/4
Investigator [1] 14/5
invites [1] 51/20
involved [23] 3/14 7/4 9/16 10/3
10/7 24/6 26/21 46/2 47/25 48/2 48/8
48/9 49/9 50/1 50/11 52/16 52/17
53/22 53/24 54/7 54/10 54/10 54/11
involvement [10] 7/4 49/21 50/1 51/6
52/7 53/1 56/14 56/16 56/17 57/15
irrelevant [2] 7/3 47/17
IRS [5] 35/7 36/5 36/7 36/12 36/19
is [175]
isn't [4] 8/4 10/19 46/10 52/15
issue [23] 5/3 5/18 7/17 8/4 12/8
12/25 14/2 16/21 16/23 17/2 17/11
17/22 18/22 21/12 31/2 48/16 50/22
52/10 52/20 52/22 53/9 54/1 55/24
issued [5] 39/10 39/23 40/2 40/11
43/8
issues [3] 2/16 51/20 56/8
it [128]
it's [34] 3/2 3/10 4/8 4/17 5/13
14/12 18/22 21/18 22/20 25/4 26/15
28/1 29/2 31/4 40/2 42/14 46/8 47/15
47/15 47/16 47/19 48/16 50/4 50/9
50/9 50/12 50/14 50/16 52/3 52/13
52/19 54/22 54/22 56/7
J
J.P [1] 1/11
JACKSON [4] 1/6 1/18 12/8 58/11
Jesika [1] 53/22
John [4] 12/22 18/8 18/9 18/15
JPB [2] 1/5 58/12
JUDGE [4] 1/11 2/8 12/5 13/12
judith [4] 1/22 1/25 58/4 58/23
July [1] 42/2
jurors [2] 2/12 13/25
jury [42] 1/10 2/11 5/25 6/11 6/12
6/14 6/19 7/11 7/12 7/21 7/23 10/17
10/20 10/24 11/10 11/14 11/18 12/17
13/5 14/4 14/8 17/6 17/8 19/11 19/15
23/6 23/9 23/11 28/10 30/2 30/15
43/8 44/18 46/13 46/15 48/11 48/13
48/17 51/11 55/7 55/14 55/25
just [47] 2/15 2/24 2/24 5/9 5/17
7/19 7/24 9/3 10/1 10/5 11/10 12/8
12/17 12/19 17/22 19/12 19/16 19/22
22/2 22/4 24/21 25/1 25/13 27/9
28/17 29/4 29/9 29/9 30/2 30/16 31/6
31/11 31/17 36/1 36/3 40/7 42/24
45/18 46/19 46/24 48/16 50/13 50/14
50/24 51/4 51/9 55/16
Justice [1] 37/10
K
Kahlil [1] 6/23
Kaushal [1] 1/16
keep [2] 52/13 55/14
kind [2] 5/5 43/5
knew [7] 22/24 33/11 35/9 35/15
35/18 36/4 49/17
knotty [1] 17/11
know [34] 2/13 6/19 7/21 7/24 11/10
20/1 20/3 22/24 22/25 23/24 24/14
25/4 26/3 26/5 28/16 29/1 29/2 33/7
33/9 33/10 33/16 33/17 35/19 36/8
36/15 43/21 44/4 49/17 50/8 51/11
51/14 52/16 55/7 55/23
knowledge [4] 4/15 6/17 7/14 24/15
known [1] 22/12
knows [1] 55/10
L
label [1] 29/10
lack [1] 18/23
ladies [3] 14/11 17/6 46/13
laid [1] 16/19
laptop [1] 21/23
last [10] 17/13 18/21 21/25 22/17
24/5 24/9 24/13 25/5 34/4 41/24
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later [6] 14/3 47/23 47/24 49/20
53/6 56/25
launder [1] 37/21
law [3] 4/23 11/23 12/1
lawyer [1] 26/9
lawyers [1] 26/16
lay [3] 10/1 23/7 25/13
leading [1] 7/8
leap [1] 54/4
learned [2] 15/9 40/15
learning [1] 48/13
least [2] 15/13 39/16
Lee [2] 28/3 28/6
left [1] 7/11
legitimate [1] 38/13
Leigh [1] 1/19
lender [1] 24/13
lengths [1] 49/8
let [11] 2/13 3/3 8/12 11/10 12/4
17/25 21/7 23/7 51/7 51/11 54/16
let's [7] 13/14 14/4 19/22 23/6 42/6
46/19 47/6
liar [7] 4/13 6/5 7/8 45/23 53/17
55/22 55/23
lie [1] 53/2
lied [7] 8/1 47/16 48/25 53/5 53/6
53/21 57/14
light [1] 34/5
like [32] 10/1 10/23 12/19 17/14
24/11 26/25 29/10 29/11 29/13 29/15
29/15 30/6 30/17 31/4 33/4 33/5
33/16 33/17 33/17 33/20 33/23 34/1
37/13 37/13 38/13 39/2 40/11 43/3
43/3 43/5 52/14 56/12
likely [2] 4/5 36/15
limine [1] 6/21
limited [3] 23/8 43/17 56/13
limits [1] 19/20
line [6] 1/10 6/10 6/11 6/25 9/9
50/16
lines [1] 31/7
list [5] 12/23 13/4 39/9 39/17 40/8
listed [1] 40/4
listen [1] 30/15
listener [1] 18/20
listening [1] 6/13
literally [1] 18/24
little [9] 9/3 26/21 27/9 27/17
28/17 29/15 36/18 56/3 57/20
loan [5] 15/21 16/12 22/13 24/20
24/22
loans [3] 15/24 16/9 38/17
logistics [1] 52/1
long [4] 17/10 27/8 42/13 42/23
look [3] 38/13 46/10 57/20
looked [2] 17/23 21/8
looking [4] 4/2 16/10 36/3 38/23
looks [2] 39/2 39/21
lot [2] 3/6 40/10
Lunch [1] 57/24
M
machine [1] 58/9
made [9] 7/10 10/25 12/9 13/2 25/9
28/17 51/18 52/6 52/8
major [1] 52/9
make [7] 7/6 9/14 12/21 19/18 31/17
33/14 38/13
makes [2] 4/24 8/3
making [1] 52/13
man [1] 33/7
manipulated [1] 32/10
many [3] 3/1 6/14 7/1
marked [3] 21/18 27/23 29/23
market [4] 33/10 33/14 33/18 34/24
Marshall [2] 1/18 12/4
materials [1] 13/5
matter [7] 50/10 50/12 50/19 52/9
52/12 56/11 58/11
may [7] 1/5 1/9 6/12 18/13 45/12
51/11 55/7
maybe [7] 2/12 5/15 10/16 19/14
19/18 51/7 51/13
me [28] 2/13 8/12 9/6 11/7 12/4
13/16 13/17 13/21 14/19 15/19 17/25
18/15 21/9 21/13 21/19 21/25 25/22
29/17 29/18 32/2 32/11 32/11 32/20
33/11 33/23 34/10 54/16 58/15
mean [8] 10/10 12/25 22/12 30/19
31/16 48/22 51/11 53/8
means [1] 32/9
meet [2] 26/2 26/6
Meghan [1] 53/21
mentioned [1] 13/19
messages [4] 49/10 49/14 49/23 56/18
met [3] 28/20 33/20 34/7
MetaBank [2] 38/10 39/1
mic [1] 56/3
might [3] 15/6 17/17 17/20
Miller [7] 6/11 8/6 8/6 8/7 8/8 8/10
10/22
Miller's [1] 4/18
minutes [1] 2/24
miscommunicated [1] 35/22
misimpression [1] 7/25
misreading [1] 8/17
modus [1] 10/17
moment [2] 6/1 17/7
MONDAY [2] 1/12 58/10
money [14] 29/20 32/8 32/17 33/9
33/10 33/12 33/21 34/3 34/14 34/17
38/2 38/10 41/2 41/4
monies [1] 41/7
Moore [1] 1/17
more [12] 10/19 25/7 26/15 26/21
27/17 32/19 34/4 36/12 36/15 36/18
57/8 57/20
morning [5] 2/6 2/8 3/9 14/11 31/2
most [2] 8/25 32/25
motion [9] 2/20 3/2 6/20 8/3 11/4
12/7 12/11 55/17 57/17
move [3] 12/6 30/12 56/3
Mr [5] 28/19 32/10 32/14 32/24 34/10
Mr. [39] 8/3 10/12 11/5 11/9 12/4
12/22 20/8 25/6 25/8 25/15 25/19
25/21 26/4 27/14 29/9 29/13 32/7
32/16 32/19 33/3 33/20 33/23 34/1
34/7 34/12 35/12 35/24 35/25 36/13
40/2 42/17 42/25 43/13 44/5 47/1
47/3 47/21 47/23 55/18
Mr. Foster [28] 10/12 11/5 11/9 20/8
25/6 25/15 25/19 25/21 26/4 27/14
29/9 29/13 32/7 32/16 32/19 33/3
33/20 33/23 34/1 34/7 34/12 35/12
35/24 35/25 36/13 42/25 47/21 55/18
Mr. Foster's [4] 8/3 25/8 40/2 42/17
Mr. John [1] 12/22
Mr. Marshall [1] 12/4
Mr. Thomas [4] 43/13 44/5 47/1 47/3
Mr. Thomas's [1] 47/23
Ms [1] 24/5
Ms. [50] 3/2 9/4 12/3 12/8 13/14
13/15 13/22 14/14 17/25 18/24 19/17
19/20 22/14 22/25 23/3 23/14 24/24
25/2 25/18 26/4 28/3 28/6 36/4 38/20
39/13 41/19 44/2 44/7 44/13 45/18
47/8 47/21 48/19 49/12 49/15 50/2
50/3 50/6 50/8 51/2 52/18 53/10
54/16 54/21 55/4 55/8 55/15 56/1
57/8 57/16
Ms. Chaiken [12] 3/2 12/3 13/15
13/22 17/25 19/20 47/8 50/3 52/18
53/10 55/4 57/16
Ms. Chaiken's [2] 50/2 50/8
Ms. Christian [4] 22/14 22/25 24/24
25/2
Ms. Holland [3] 38/20 39/13 41/19
Ms. Jackson [1] 12/8
Ms. Lee [2] 28/3 28/6
Ms. Pyfrom-Foster [6] 25/18 26/4
36/4 47/21 49/15 55/8
Ms. Webster [20] 9/4 13/14 14/14
18/24 19/17 23/3 23/14 44/2 44/7
44/13 45/18 48/19 49/12 50/6 51/2
54/16 54/21 55/15 56/1 57/8
much [4] 32/5 32/21 33/6 33/22
multiple [2] 40/19 41/6
must [1] 9/13
my [11] 2/14 11/17 11/17 12/11 13/8
18/5 21/23 25/23 29/10 31/4 33/21
N
name [9] 4/18 22/17 24/5 24/9 24/13
24/14 40/2 40/4 42/17
named [2] 22/21 34/17
names [6] 4/14 6/7 6/16 7/9 7/14
39/16
nature [1] 51/5
need [7] 6/19 6/25 7/21 30/16 50/5
51/11 57/19
needs [1] 7/24
never [4] 9/13 26/24 27/4 34/12
news [2] 37/5 37/12
newspaper [2] 19/1 19/4
next [11] 17/20 18/11 18/12 25/1
29/24 32/23 33/19 54/9 57/9 57/11
57/14
nightclub [1] 29/10
nil [1] 17/20
nine [1] 40/22
no [34] 1/18 1/4 4/9 6/18 6/19 6/25
7/5 7/7 9/15 12/24 19/3 22/22 26/10
26/12 26/14 27/1 27/3 27/6 29/19
29/20 30/21 32/10 33/18 43/7 44/19
45/21 45/23 46/7 46/25 47/5 50/4
54/12 57/18 58/12
non [1] 18/23
non-hearsay [1] 18/23
nontestifying [1] 50/14
nontruthful [1] 51/17
nonwitness [1] 47/6
Nope [1] 32/19
normal [2] 12/2 19/21
normally [1] 12/2
NORTHERN [2] 1/1 58/6
not [113]
note [4] 1/17 11/17 55/16 56/12
noted [1] 10/17
nothing [3] 8/9 12/18 29/20
notice [1] 53/11
now [8] 5/24 6/3 22/2 25/4 32/2
37/15 55/20 57/5
number [6] 1/10 1/10 8/15 12/9 25/5
25/23
O
objected [2] 10/22 56/20
objecting [1] 53/11
objection [14] 10/16 10/25 11/1
11/18 16/18 23/5 23/13 46/20 50/8
50/21 53/10 57/5 57/7 57/17
obviously [2] 5/12 51/19
off [14] 5/15 5/20 5/21 6/25 41/2
41/7 44/9 44/10 45/13 45/14 46/16
46/17 57/21 57/23
offense [2] 8/21 11/16
offer [1] 18/5
offered [6] 46/6 50/10 50/12 52/13
54/23 56/10
offering [2] 52/11 52/21
Office [1] 26/19
Officer [5] 2/11 2/17 13/25 14/1
23/9
offices [1] 58/7
official [8] 1/3 1/5 1/6 1/11 1/19
1/22 58/5 58/24
often [1] 26/15
oh [2] 33/7 52/13
okay [92]
once [4] 21/6 24/18 26/16 29/15
one [28] 3/5 3/22 5/17 6/1 8/23 9/2
12/9 13/23 15/13 15/24 16/9 26/11
26/13 29/5 30/25 32/2 32/23 33/19
34/1 34/4 34/4 35/11 38/16 44/7 45/4
46/25 48/12 48/17
ones [1] 30/25
ongoing [1] 14/24
only [9] 1/5 1/10 7/15 7/16 12/5
42/2 53/5 54/25 57/4
open [6] 16/23 47/22 48/6 51/18 54/5
58/10
opened [1] 3/8
opening [4] 12/9 12/22 13/12 14/21
opens [4] 5/14 50/17 51/13 56/8
operandi [1] 10/18
opposition [1] 55/17
options [1] 38/5
63
Case 1:20-cr-00296-JPB-CMS Document 1039 Filed 06/17/24 Page 64 of 67
O
order [6] 2/2 4/12 4/20 5/7 7/25
30/13
other [29] 2/16 3/19 5/7 5/17 6/7
7/6 10/10 11/12 12/19 13/22 15/4
15/6 21/19 28/20 29/19 30/25 31/13
40/12 41/4 41/13 41/14 42/7 42/7
45/21 48/8 49/17 51/13 53/17 53/20
others [1] 30/20
our [20] 2/12 2/16 2/16 6/9 6/10
12/9 12/23 13/11 22/13 25/1 40/9
41/16 46/5 47/10 54/6 55/17 56/2
56/5 56/7 56/9
out [28] 2/14 2/22 8/20 10/1 12/17
12/22 13/4 14/4 17/7 17/21 23/6 23/9
24/9 24/23 24/24 25/13 29/14 29/15
33/11 33/23 34/20 35/13 41/2 41/4
41/6 46/14 48/24 49/4
outside [1] 19/14
overrule [1] 23/5
overruled [1] 23/13
owe [1] 32/19
owed [1] 32/20
own [3] 7/24 49/16 55/17
owners [3] 8/23 9/2 9/12
owners's [1] 37/23
P
page [1] 1/10
paid [4] 32/6 32/7 32/7 32/12
paper [1] 21/25
part [4] 7/23 15/1 16/9 49/1
partial [1] 1/12
participants [1] 40/12
participated [3] 11/13 44/20 47/12
participating [2] 3/17 3/20
participation [1] 34/13
parties [1] 13/4
partner [6] 3/16 3/19 3/22 3/25 4/3
5/6
partners [2] 28/21 34/8
party [1] 15/10
pause [4] 13/24 22/18 28/7 49/6
Pay [1] 42/16
payback [1] 34/14
PayCard [2] 38/11 42/25
PayCards [6] 37/16 37/20 39/1 39/10
40/8 40/19
payments [2] 27/18 34/11
payroll [1] 38/13
payrolls [1] 38/7
PDF [1] 1/3
people [33] 3/19 4/4 4/4 5/7 6/20
7/1 7/2 7/6 7/12 8/1 9/15 9/17 10/2
10/6 10/11 11/10 11/12 11/13 26/16
28/20 34/7 39/9 40/7 40/11 41/9 41/9
41/13 41/14 48/8 53/20 54/7 54/14
54/15
people's [5] 4/14 6/7 6/16 7/9 7/14
per [1] 41/10
period [2] 1/7 34/2
permissible [4] 4/6 4/23 5/10 53/19
person [5] 3/13 9/22 18/10 53/22
54/24
persona [1] 4/20
personal [1] 53/23
Phront [3] 39/10 39/23 43/9
piece [1] 21/25
piecemeal [1] 30/24
pieces [2] 50/25 51/1
place [1] 36/20
plan [1] 27/21
planned [1] 21/14
play [9] 27/21 30/4 30/6 30/8 30/17
30/24 31/3 31/10 31/23
played [5] 26/25 27/25 28/13 28/24
29/25
playing [3] 29/23 31/3 51/3
plea [7] 5/3 7/20 8/5 8/9 12/18 13/9
54/1
plead [1] 5/16
pleaded [1] 7/22
pleading [1] 12/22
pleas [3] 2/20 13/16 55/18
please [9] 17/7 31/25 32/23 33/19
44/8 45/12 46/14 49/4 56/4
plus [2] 32/24 32/25
point [15] 3/6 5/2 5/9 7/6 22/24
26/4 31/24 35/11 35/17 35/23 36/8
44/23 48/14 53/8 56/22
pointed [1] 12/17
points [1] 2/25
portion [2] 1/9 48/24
portions [1] 27/22
possession [1] 40/20
potential [1] 11/21
PPP [3] 7/25 34/13 38/17
PPP loans [1] 38/17
preclude [1] 6/21
preparation [1] 1/18
preparing [1] 44/17
presence [1] 19/14
presented [1] 4/15
presenting [1] 49/25
press [2] 37/7 37/9
pretty [3] 17/20 51/13 52/2
prevent [1] 48/13
previously [3] 3/19 27/22 28/21
primary [3] 9/2 45/4 54/17
prior [2] 21/3 52/25
probably [6] 13/8 21/8 32/25 33/23
36/18 40/23
problematic [1] 30/8
proceedings [9] 1/10 5/21 44/10
45/14 46/11 46/17 58/10 58/14 58/18
process [1] 26/21
processes [1] 36/12
produced [4] 20/15 20/21 20/23 55/11
proffer [17] 19/18 19/22 19/23 44/24
45/5 45/19 45/20 46/21 46/23 47/14
47/24 48/7 48/9 48/11 48/14 51/18
56/23
program [1] 38/11
prohibited [1] 1/12
promised [1] 48/23
promotion [1] 33/5
propensity [3] 4/4 4/9 5/5
proper [3] 11/7 45/23 55/2
prospective [1] 13/6
protect [2] 49/8 54/7
protected [7] 47/19 47/24 48/1 53/20
54/2 55/7 55/13
protecting [1] 55/1
prove [2] 5/7 52/21
provide [4] 43/13 43/16 45/8 57/1
provided [3] 16/14 20/18 43/20
PSR [1] 13/5
published [1] 3/10
purported [1] 24/11
purpose [11] 4/6 6/18 7/5 18/23
45/21 45/23 46/7 53/16 54/25 55/2
55/3
purposes [2] 38/16 47/19
pursuant [1] 30/13
put [14] 3/18 5/5 12/6 12/24 18/24
29/15 33/9 33/13 43/25 44/4 46/9
48/11 51/1 55/8
puts [3] 5/18 6/16 7/9
putting [2] 19/11 53/11
Pyfrom [19] 25/16 25/18 26/4 36/4
44/16 46/2 47/20 47/21 49/8 49/15
49/25 53/1 54/2 55/1 55/8 55/13
55/14 56/6 57/15
Pyfrom-Foster [11] 25/16 44/16 46/2
47/20 49/8 49/25 54/2 55/1 55/13
55/14 56/6
Pyfrom-Foster's [2] 53/1 57/15
Q
question [18] 7/3 9/23 9/23 10/16
11/7 11/7 18/11 35/19 54/9 56/19
57/3 57/5 57/7 57/10 57/11 57/12
57/13 57/14
questionable [1] 51/2
questioning [10] 5/14 6/9 6/10 6/10
6/12 7/1 9/10 10/9 10/10 50/16
questions [10] 6/22 9/14 9/20 9/23
12/24 21/13 23/8 46/22 56/12 56/25
quite [2] 15/18 36/7
quote [1] 34/8
quote/unquote [1] 34/8
R
raised [1] 7/17
rapid [11] 37/16 37/20 38/4 38/11
39/1 39/3 39/10 40/8 40/19 42/16
42/25
reached [1] 24/24
read [11] 13/4 19/1 29/4 30/6 30/14
31/7 31/7 31/25 32/2 32/23 33/19
reading [1] 22/20
real [1] 29/3
really [6] 5/4 6/18 7/15 7/16 8/4
25/1
Realtime [1] 58/5
reason [1] 48/1
reasons [1] 53/3
recall [2] 22/19 44/22
recap [1] 2/25
receipts [3] 43/3 43/5 43/5
receive [1] 23/20
received [10] 2/21 20/1 20/25 21/1
21/6 22/6 23/23 24/1 27/14 40/8
receiving [3] 20/3 22/10 36/1
recent [1] 55/10
recess [1] 57/24
record [19] 3/1 5/20 5/21 5/23 6/2
29/10 31/8 44/9 44/10 45/13 45/14
45/16 45/17 46/9 46/16 46/17 57/21
57/23 58/18
recording [1] 28/16
records [3] 38/25 39/2 42/4
recruiter [1] 38/2
recruiters [3] 8/22 8/24 8/25
reduced [1] 58/15
reference [5] 6/21 12/11 12/22 13/2
13/9
referenced [2] 40/1 40/3
referencing [2] 1/10 22/20
referring [1] 38/4
rejoin [1] 14/2
rejoined [1] 17/22
related [3] 12/12 15/2 36/17
relationship [1] 53/23
release [2] 37/8 37/9
releases [1] 37/5
relevance [4] 17/17 17/20 50/3 50/6
relevant [10] 11/6 15/10 16/7 46/5
48/17 49/24 50/7 50/15 52/3 56/7
relied [6] 47/9 47/10 47/20 48/16
55/5 55/6
remained [1] 40/11
remaining [2] 21/13 31/25
remember [4] 20/13 20/22 25/5 36/9
repeat [1] 20/20
repeatedly [1] 46/1
replay [1] 28/9
reply [1] 2/22
report [2] 16/2 22/7
reported [1] 58/9
reporter [10] 1/6 1/11 1/17 1/22
1/22 9/6 58/4 58/5 58/5 58/24
REPORTER'S [1] 58/2
represent [2] 26/17 39/22
representing [1] 24/12
request [2] 42/6 42/14
required [1] 27/4
responding [1] 11/1
response [10] 8/3 10/16 10/21 10/24
11/18 43/23 44/1 44/5 54/20 55/17
responses [6] 2/21 8/15 43/14 43/16
43/18 48/21
restricted [1] 1/6
result [1] 24/19
resulting [1] 37/12
retirement [3] 33/21 34/3 34/17
reverse [1] 3/11
review [3] 16/22 18/9 21/6
reviewed [8] 16/5 17/14 17/17 19/6
19/16 20/13 22/7 24/2
reviewing [1] 22/10
Ricky [1] 40/12
right [70]
rise [1] 52/9
road [1] 38/9
role [5] 6/23 6/24 8/21 9/19 10/10
roles [1] 11/15
rolling [1] 2/15
64
Case 1:20-cr-00296-JPB-CMS Document 1039 Filed 06/17/24 Page 65 of 67
R
row [3] 39/18 39/25 40/4
rows [1] 39/22
RPR [1] 58/23
rule [7] 3/24 4/23 5/10 27/22 53/9
53/19 53/19
Rule 608 [1] 53/19
ruling [3] 57/4 57/11 57/12
Ryan [1] 6/23
S
S.W [1] 1/23
said [25] 3/21 4/6 4/8 6/4 8/8 8/22
10/5 16/11 24/8 24/13 25/21 25/22
28/19 31/8 32/8 34/12 34/16 34/23
35/14 48/14 49/8 51/19 55/18 56/15
58/14
same [1] 6/22
Samir [1] 1/16
Saraliene [1] 1/19
say [19] 6/9 8/5 18/1 18/8 18/13
18/17 18/17 19/1 19/4 28/17 28/19
32/25 35/8 35/10 36/11 47/18 53/2
54/3 55/9
saying [9] 29/13 30/9 34/14 35/25
36/2 47/20 49/10 50/11 55/20
says [8] 18/10 29/9 39/4 39/8 49/15
49/22 52/16 55/1
scam [2] 24/9 24/11
scenario [1] 13/14
scheme [5] 3/15 3/17 4/1 34/13 37/16
schemes [1] 3/20
scot [1] 5/15
scot-free [1] 5/15
scroll [1] 39/13
search [1] 41/21
seated [3] 14/9 17/9 23/12
seats [1] 2/4
second [8] 4/2 10/4 12/21 13/23 32/2
44/7 49/20 56/14
Secret [4] 15/9 21/9 24/22 24/23
Secretary [1] 4/18
SECURITY [2] 2/17 14/1
see [8] 2/6 2/12 7/5 16/11 16/14
35/15 38/20 51/7
seeking [2] 7/18 7/19
seemed [2] 17/13 28/17
seems [3] 51/2 52/14 57/5
seen [1] 48/3
seized [1] 38/10
send [1] 38/2
sent [2] 3/9 21/9
separate [3] 6/10 12/13 39/22
Service [4] 15/9 21/9 24/22 24/23
Services [1] 38/8
session [6] 1/5 44/24 46/22 46/23
47/15 56/23
several [2] 21/3 25/4
she [27] 16/11 16/14 16/17 17/25
19/5 19/6 22/16 24/8 24/8 24/11
24/11 24/13 25/20 25/21 25/21 36/7
36/9 36/10 36/11 36/15 36/18 44/20
46/3 47/25 49/9 52/16 52/17
shed [1] 34/5
shit [6] 32/11 33/5 33/5 33/15 33/17
33/17
shop [1] 29/9
short [2] 13/17 32/1
should [3] 18/16 26/13 29/24
show [14] 3/24 4/3 16/20 18/6 18/7
18/23 19/5 19/10 21/21 45/22 52/3
54/11 54/23 54/25
showed [1] 15/19
showing [2] 18/19 47/19
shows [1] 4/19
side [1] 2/24
sidebar [2] 45/17 46/11
similar [1] 3/20
simply [2] 56/20 57/4
single [1] 13/19
sir [2] 2/17 43/24
sit [1] 21/7
site [2] 41/22 42/7
situation [6] 3/14 5/1 5/18 5/25 6/3
12/2
skeptical [2] 35/9 35/11
slice [2] 6/8 48/10
sloppy [2] 12/10 12/11
slow [2] 9/3 49/11
snippets [1] 30/24
solely [1] 12/12
some [23] 2/22 9/11 12/8 15/10 15/22
27/10 28/20 31/2 33/7 33/9 33/14
34/5 34/7 35/17 36/16 37/7 41/9
43/19 43/21 44/23 46/22 51/13 56/22
somebody [5] 17/19 18/7 24/12 45/22
52/23
someone [14] 3/25 4/11 6/6 6/6 9/25
10/14 22/16 24/5 24/9 36/19 45/5
47/12 54/13 55/19
someone's [1] 4/10
something [3] 4/17 18/1 33/3
sometime [3] 14/22 20/5 23/22
sometimes [7] 8/24 10/11 10/12 15/4
15/6 42/10 42/13
somewhere [1] 20/4
sorry [8] 16/25 25/10 28/4 31/15
39/7 44/2 44/12 49/1
sort [11] 5/1 8/17 10/1 24/8 26/3
35/12 36/14 37/7 38/13 45/4 51/4
sound [1] 40/22
sounds [2] 15/20 43/12
speak [3] 6/15 25/19 27/5
Special [1] 14/15
specific [2] 24/20 25/7
specifically [6] 8/20 27/13 37/19
38/4 45/24 48/25
spoke [2] 25/15 27/8
stamps [1] 36/16
stand [2] 14/6 55/9
start [4] 6/25 8/20 46/19 47/6
started [3] 38/10 42/2 56/15
Starting [1] 29/6
state [2] 4/19 46/20
statement [23] 10/20 12/9 16/17
19/12 22/10 22/11 22/12 22/23 24/2
24/4 24/18 24/20 25/8 26/1 28/9 35/2
45/5 50/11 51/18 52/6 52/8 52/15
52/20
statements [13] 7/18 11/20 12/8
13/11 18/3 18/6 26/24 27/18 47/23
48/7 50/18 51/4 56/8
STATES [7] 1/1 1/4 1/11 1/23 3/10
58/6 58/11
stay [2] 19/20 42/13
Stenograph [1] 58/9
stenographic [3] 1/17 58/2 58/4
step [5] 3/5 17/6 25/1 46/14 49/4
still [6] 14/24 16/23 17/22 19/13
49/21 53/15
Stites [27] 14/5 14/15 14/19 18/25
19/25 22/6 23/17 28/15 29/1 29/12
29/21 31/23 32/5 32/8 32/12 32/15
32/17 32/21 33/2 33/22 33/25 34/5
34/9 38/23 41/21 44/16 49/3
stock [5] 33/9 33/10 33/13 33/18
34/24
stolen [1] 9/13
stopped [1] 38/9
store [1] 43/5
straight [1] 7/8
strongest [1] 2/25
struggling [1] 28/11
stuff [3] 17/18 29/11 36/17
subject [1] 11/4
submit [1] 44/18
subpoena [3] 43/8 43/14 43/16
such [2] 33/10 33/10
suggest [1] 6/12
suggested [3] 5/25 13/22 16/17
suggesting [3] 31/1 31/6 52/5
suggestion [2] 5/15 54/1
summer [1] 43/11
supposed [3] 11/13 28/21 43/13
sure [11] 14/21 15/18 17/5 30/1
30/10 31/17 36/10 37/14 43/25 49/3
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swipe [1] 41/15
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tab [3] 39/6 39/7 39/8
take [9] 2/21 2/24 3/5 13/14 17/10
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taken [4] 4/10 4/11 4/19 57/24
taking [1] 41/2
Tal [1] 1/16
talk [4] 18/16 25/21 25/22 50/5
talked [1] 48/9
talking [2] 33/6 33/15
tape [3] 30/24 31/3 31/3
targets [1] 15/2
tax [2] 35/9 36/17
technology [1] 1/18
Ted [1] 1/23
TELDRIN [14] 1/7 4/16 4/20 7/22 7/23
35/9 47/12 48/2 48/3 48/8 54/3 55/9
55/12 58/12
tell [6] 14/19 26/11 26/13 49/21
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telling [1] 33/4
tells [1] 49/19
ten [1] 2/12
territory [1] 5/2
test [1] 35/12
testified [6] 25/5 37/15 37/19 41/24
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testify [1] 45/25
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testimony [5] 4/8 6/13 6/18 8/18
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than [9] 7/6 10/19 13/22 36/12 36/18
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thank [20] 2/5 2/18 3/4 8/14 9/5 9/8
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23/10 23/15 24/15 25/3 28/6 41/18
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that [390]
that's [49] 4/6 4/15 4/17 4/25 4/25
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theft [1] 8/2
their [17] 4/11 4/14 5/6 5/6 6/4
6/17 7/4 7/14 7/19 7/24 9/13 9/19
11/15 13/4 26/18 26/20 48/12
them [16] 2/14 4/12 11/7 26/19 30/25
36/1 36/2 36/3 38/1 38/2 41/15 42/21
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then [35] 6/15 8/21 8/22 8/25 9/20
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there [46] 3/21 4/9 4/13 5/2 5/4 5/9
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There's [1] 45/23
thereafter [2] 23/21 23/22
therefore [3] 3/23 4/5 9/16
these [9] 7/2 7/6 29/4 38/25 39/22
40/10 40/25 41/7 43/2
they [69]
They're [1] 53/4
thing [6] 7/16 12/5 33/6 48/12 48/18
57/4
things [8] 6/17 7/9 12/25 31/13
37/13 40/25 43/3 51/14
think [68]
thinking [3] 3/6 25/11 32/24
third [1] 29/18
this [92]
Thomas [54] 4/10 4/18 6/5 6/5 6/6
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thousand [1] 33/15
thousands [2] 41/10 41/10
three [2] 12/13 33/14
through [10] 8/25 9/17 27/23 30/13
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timeframe [2] 16/22 23/25
timeline [2] 21/12 25/13
times [3] 22/5 22/15 41/11
timing [2] 20/3 23/8
together [3] 44/1 44/5 56/6
told [10] 17/12 18/15 25/18 25/20
27/4 27/14 27/17 34/23 35/12 38/1
too [4] 42/23 51/25 53/15 53/20
took [1] 36/20
top [1] 29/6
towards [1] 48/3
transaction [1] 12/15
transactions [2] 42/16 43/3
transcript [15] 1/3 1/9 1/11 1/13
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transcripts [5] 1/5 30/19 31/13
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trial [5] 1/10 17/18 21/3 26/25
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tricked [2] 5/7 5/8
tried [1] 6/8
tries [2] 3/12 54/13
trouble [2] 48/5 51/9
true [8] 4/17 22/17 22/23 22/25
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truth [8] 50/10 50/11 50/12 50/19
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truthful [12] 16/14 43/18 45/2 45/6
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try [3] 16/24 26/18 42/15
trying [9] 8/11 42/18 48/24 50/13
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turned [1] 13/5
Turner [1] 1/23
two [6] 3/22 17/17 27/9 27/10 33/14
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typewritten [1] 58/15
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U.S [1] 1/19
U.S. [1] 26/19
U.S. Attorney's [1] 26/19
uncharted [1] 5/1
unclear [1] 28/17
under [7] 3/24 4/23 5/10 27/22 49/17
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understand [11] 11/15 17/24 28/12
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understandable [1] 30/11
understanding [4] 18/5 40/9 41/16
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UNITED [7] 1/23 1/4 1/11 1/23 3/9
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unquote [1] 34/8
until [1] 49/21
untruthful [5] 43/19 45/19 47/14
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up [10] 5/13 14/5 34/20 48/6 51/12
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us [15] 10/24 13/5 20/15 25/21 25/22
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use [3] 37/16 49/15 53/4
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using [4] 37/20 40/25 41/2 54/2
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vacuum [1] 6/12
value [2] 31/9 35/24
versus [2] 17/1 17/17
very [5] 6/4 12/1 35/8 55/10 56/13
victims [1] 8/2
view [1] 3/22
VOLUME [1] 1/5
vs [1] 1/5
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want [14] 3/5 13/16 16/24 21/13
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wanted [9] 3/18 10/24 16/11 16/14
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wants [5] 18/5 18/7 19/5 47/18 51/8
warrant [1] 41/21
was [157]
wasn't [10] 9/22 10/2 10/5 10/15
11/1 17/14 27/4 31/15 36/2 36/2
way [11] 4/1 4/2 5/17 18/8 22/17
30/14 41/4 46/2 47/10 47/11 54/14
ways [2] 3/22 41/6
we [93]
we'll [2] 14/2 51/7
we're [18] 5/1 8/11 31/11 38/23
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49/25 50/13 51/3 51/11 51/16 51/17
53/12 57/21
Webster [21] 1/19 9/4 13/14 14/14
18/24 19/17 23/3 23/14 44/2 44/7
44/13 45/18 48/19 49/12 50/6 51/2
54/16 54/21 55/15 56/1 57/8
week [4] 17/13 18/21 25/5 41/24
weeks [2] 17/17 33/14
welcome [2] 31/3 31/10
well [20] 2/6 6/9 8/8 12/1 17/3
17/10 18/1 26/20 29/13 31/4 31/10
38/5 50/9 51/8 52/1 52/12 55/10
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went [6] 9/17 18/14 18/16 33/17 49/8
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were [48] 6/20 7/1 7/1 7/2 7/3 7/6
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weren't [3] 2/22 42/24 54/7
what [53] 2/25 4/7 4/15 5/24 6/12
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what's [1] 54/20
whatever [3] 18/9 19/4 33/8
WhatsApp [5] 4/10 49/10 49/14 49/23
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whenever [1] 24/9
where [12] 3/6 3/14 4/17 5/4 5/18
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whether [9] 2/15 7/2 7/3 19/9 19/20
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which [15] 3/11 3/24 9/11 9/21 11/3
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while [4] 21/7 29/18 32/11 36/7
Whittley's [1] 6/24
who [25] 5/13 6/6 6/6 7/12 7/13 10/3
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whoever [1] 5/6
whole [3] 6/13 17/12 48/14
whose [1] 40/4
why [12] 2/24 5/2 29/2 30/2 35/24
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wide [1] 51/13
wife [1] 53/21
will [8] 1/6 3/1 11/18 12/24 26/18
30/15 31/23 55/18
willing [1] 25/22
wire [3] 12/14 12/15 12/15
withdraw [1] 57/13
withdrawals [1] 41/3
withdrawing [1] 41/9
withdrew [2] 17/8 46/15
within [1] 19/20
without [6] 4/14 6/17 7/14 19/11
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witness [16] 8/7 11/7 12/23 12/23
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witnesses [2] 10/9 13/6
wolff [4] 1/22 1/25 58/4 58/23
work [4] 2/22 14/24 36/19 46/10
working [2] 28/2 56/6
world [1] 18/25
would [52] 2/14 3/24 8/17 11/17
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wouldn't [3] 30/17 31/14 51/10
wrapping [1] 51/12
wrong [1] 3/13
Y
yeah [7] 17/12 20/22 32/8 32/16 33/7
33/22 41/2
years [3] 21/3 34/8 36/10
yes [77]
yet [2] 17/14 23/1
you [218]
you'll [1] 2/11
your [60]
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