Court filing
TRANSCRIPT of Proceedings as to Carla Jackson, Teldrin Foster held on February 14,… — USA v. Thomas et al (Dkt. 1041)
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. 1041 · 2024-06-17 · Docket on CourtListener
Summary
A transcript of jury trial proceedings, Volume 8 (AM Session), in United States of America v. Carla Jackson and Teldrin Foster, Docket No. 1:20-cr-00296-JPB-CMS, held Wednesday, February 14, 2024 before United States District Judge J.P. Boulee in the U.S. District Court for the Northern District of Georgia, Atlanta Division, and filed June 17, 2024 as Doc. 1041. The appearance page lists three attorneys for the Government and separate counsel for each defendant. The opening records the court taking up the written jury instructions, confirming a ruling against a proposed theory-of-defense instruction and discussing the Lively and Orr decisions and an Eleventh Circuit statement from 1986. The transcript also records the court declining to reopen a line of testimony. The transcript is 140 pages and ends with an alphabetical word index.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
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Case 1:20-cr-00296-JPB-CMS Document 1041 Filed 06/17/24 Page 1 of 140
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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 8 (AM SESSION)
CARLA JACKSON and
TELDRIN FOSTER,
Defendants.
TRANSCRIPT OF JURY TRIAL PROCEEDINGS
BEFORE THE HONORABLE J.P. BOULEE
UNITED STATES DISTRICT COURT JUDGE
WEDNESDAY, FEBRUARY 14, 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 9:41 a.m.)
THE COURT: Good morning, everyone.
I hope everyone is well.
One administrative issue.
Ms. Mueller has put together the version of jury
instructions that will go back with the jury. I had her look
through all the titles to make sure those were benign. I
think they are. Sometimes those titles can apply to some
things but not everything. So look through there and make
sure there aren't any issues with the titles.
She also added the word "form" where it says
"explain the verdict." I think what is meant in those is to
explain the verdict form.
So that's that. And obviously, we have a portion
of those to still discuss this morning.
Let me move to that.
First off, I have now had a chance to read through
the Lively and Orr cases more thoroughly, and I want to
solidify and confirm my earlier preliminary ruling on that.
Having read those cases, I would just add the
clarification that I think Lively actually supports a ruling
in the government's favor as well.
There is no inconsistency in the cases. It's not a
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matter of my favoring the later case, Orr. And indeed Orr
cites Lively for the noncontroversial principle that a
defendant can be entitled to a theory of defense instruction
when there is an evidentiary foundation for it, even if the
evidentiary link is weak.
In Lively, the Eleventh Circuit in 1986 explained
that it was appropriate to give an instruction explaining the
relevant law that was applicable to the defendant's defense.
There, in sum, that once someone is arrested and becomes a
government agent, they can no longer be a co-conspirator.
But that's not what we have in Mr. Foster's
proposed instruction here. It isn't instructing the jury on
the applicable law, the theory of defense. Mr. Foster's
proposed instruction doesn't explain any applicable law.
Instead, it's just a listing of Mr. Foster's
various contentions, what he views the facts to be here. And
that, as I noted last night and as Ms. Chaiken argued, is
impermissible under Orr.
It's little more than defendant-friendly commentary
evidence, what he contends the evidence shows. It's merely a
judicial narrative of his version of facts or putting the
defendant's desired factual findings in the mouth of the
Court.
To the extent that Mr. Foster wants instructions
about the law, conspiracy, intent, knowledge, willingness, I
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believe instructions touching on those issues, in whole or in
part, are already included. And I will certainly entertain
instructions on the law that anyone desires, and I have done
so in this case.
Turning next to the issue involving the missing
witness that you briefed for me overnight and into this
morning, and thank you for those briefs, I want to first ask
Ms. Chaiken, you mentioned it last night and you mentioned it
in your brief but I just want the record to be clear.
In my experience both as a practitioner in the
Northern District and as a judge here, the matter of granting
someone immunity is not a five-minute procedure or even a
five-hour procedure. It's perhaps a five-day, or more,
procedure.
But I want the record to be clear on what exactly
that takes in a case like this where we have you; we have the
Fraud Section of main Justice here as well.
I know that when you were asked about that, you
stated -- bear with me for one moment -- that "We're not
authorized to grant Mr. Dixon immunity, nor are we going to."
So I would just like the record to be clear on what
that procedure is and how long that procedure generally
takes.
MR. KAUSHAL: Yes, Your Honor.
There are -- and this is my understanding of how
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this process works is that there are two ways where immunity
can be sought. There is one that is statutory immunity that
requires going to -- completing multiple levels of review and
paperwork that goes to main Justice, and that takes a fairly
significant amount of time.
There is also a form of immunity known as letter
immunity that an AUSA can seek in an instance, where
appropriate, after receiving supervisory approval.
And there are also additional requirements in this
case beyond our office's requirements because DOJ Fraud
Section is also involved, and there is also an approval
requirement through their process as well.
So letter immunity is an informal type of immunity
that sometimes can be done fairly quickly. However, to ask
the government to investigate and understand that, after
declining to explain this to us repeatedly over the nine
months coming to trial, the week from when we first previewed
the issue in front of Your Honor to last, now, I believe, the
night before last, at the end of the day when we again tried
to broach this issue with the defense and they just declined
to talk to us about it.
And then at the last moment possible, they come in
and ask us to pursue immunity, while we're in the middle of
the trial, that's simply not something that -- that we were
not authorized to do it at that moment because we would have
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had to have taken a break; we would need to understand the
facts; we would need to understand what specifically the
defendant was going to -- the testifying defendant would have
testified to, Mr. Dixon.
Because what if, hypothetically, Your Honor,
Mr. Dixon came up on the stand and said something we had no
idea he was going to say. For example, this is just a
hypothetical, but I'll say this:
What if Mr. Dixon were to say "Me and Darrell
Thomas robbed a bank together and I owed him for that because
he didn't snitch on me when we robbed that bank."
Or "Me and Darrell Thomas shot somebody and we
never told anybody, and that's the reason why I" -- according
to the defense, he's going to testify that he would have said
he took instruction from Darrell Thomas.
What if he said that on the stand, Your Honor?
That would be something that if we just blindly gave him
immunity without any knowledge about what actually occurred,
it would be irresponsible.
And while I don't know what would have happened if
we had gone down and sought supervisory approval, assuming we
could even get it from main Justice and we could get access
to our supervisor in the middle of the trial, I don't know
if -- you know, they're going to have questions for us.
And that is why the representation was made that we
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didn't have authorization to do it at that time, because we
didn't.
THE COURT: All right. Well, what's your best
estimate as to how long it would take to get those various
types of approvals?
And let's be clear about which ones you would have
needed here.
MR. MOORE: I'll speak for the Fraud Section
because I think that is the more stringent approval here.
I would need authority from a deputy assistant
attorney general, in writing. I would have to have submitted
that in writing, first to my assistant chief, then to the
chief of my section, who would both have to approve it, who
would then send it to a different building to the deputy
assistant attorney general.
And that, even in a rush scenario, I have never
heard of it being done in faster than a week because it would
go with all the other approvals that need written approval.
So that would have been the process from the Fraud Section.
And from the Fraud Section, even though we do offer
letter immunity for proffers, for immunity for testifying in
court, it has to be written approval from the deputy
assistant attorney general.
So we wouldn't have authorized letter immunity in
this situation.
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MR. KAUSHAL: And one other note, Your Honor, there
is no guarantee that Mr. Dixon would have accepted letter
immunity, even if we had offered it, because it's not
coextensive with the type of immunity one would receive
through the more formalized statutory process that is
available that takes much longer.
THE COURT: All right. Thank you.
I just wanted to clarify that issue.
I think our one of, if not the guiding case here,
is Rafael case, 487 Fed. Appx. 490, which states: A party
who is unavailable by virtue of claiming the Fifth Amendment
or another privilege does not support a missing witness
instruction.
And applying that clear statement of the law from
the Eleventh Circuit, the missing witness instruction would
be improper here.
Of course, Judge Martin in that case went on to
note that the court was aware of other circuits alluded to
exceptions to the general rule where the substantial showing
of an abuse of prosecutorial discretion and have also left
open the possibility an exception where circumstances suggest
the witness's testimony would have been exculpatory.
So we don't even know if the Eleventh Circuit would
do that. But assuming for the sake of argument the Eleventh
Circuit would adopt what other circuits have done with those
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two exceptions, I don't think either of those exceptions
apply here.
Certainly, there has been no showing of an abuse of
prosecutorial discretion. Quite to the contrary, the record
has laid out -- and the government's brief of this morning
shows that, back on February 5, the government was exploring
this issue and again invited the defense on the issue a
couple days ago, and the defense had declined to pursue the
issue with the government then when, perhaps, if back then it
had happened, maybe there could have been immunity. But we
will never know because the defense never pursued it at that
time.
As far as whether circumstances suggest the
witness's testimony would have been exculpatory, I don't
think we have that here, either.
What we have here, at best, as noted in the
government's footnote 7 of Docket 924, is Thomas instructing
Dixon to identify Foster. It's not exculpatory because it
doesn't show that Foster wasn't involved, as the government
notes it merely shows that Thomas, having been indicted and
while fighting these charges, wanted to deflect blame.
And indeed, as Ms. Chaiken notes, even the defense
recognized it would be, at most, favorable but not
exculpatory.
And I would add, bluntly, to give the instruction
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in this circumstance I think would be a miscarriage of
justice. And I decided to exercise my discretion not to do
so.
If the defense really wanted to have explored this,
they could have done it long before the moment of testimony.
In the Second Circuit's Myerson case -- and I don't
have the cite in front of me, I apologize -- they noted there
is the usual aura of gamesmanship. And here I think we have
that element of gamesmanship. The defense was invited
numerous times, early on, or earlier on in one occasion and a
little earlier on in a second occasion, to explore this and
they declined.
And instead, as far as what the information is
about what the witness would have said, we got the cryptic
statement from defense counsel that it was, quote, "based on
communications that have not happened in this courtroom,"
whatever that means.
This is not a situation in which the government was
presented with information that was clearly exculpatory and
then had time to get immunity and didn't do it. It's the
exact opposite of that. Neither of those things are true.
And I would also add -- and it's not important to
the decision because the decision stands, nevertheless, I
would add here that I explored two ways of going about what
Mr. Dixon would or wouldn't say, or would or wouldn't invoke
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his Fifth Amendment privilege on, one of which kept this
entirely away from the jury which, in hindsight, I think
would have been the more prudent course, and the other was to
put it all on the record in front of the jury.
And the defense wanted to ask their questions in
front of the jury; the government didn't.
And I think I probably, in hindsight again, made a
mistake by letting the jury hear all that. But I did, and
those questions and his invocation of the Fifth Amendment
were all in front of the jury.
I recognize, having seen the Feliciano-Franciso 701
Fed. Appx. 808, cite from the Eleventh Circuit 2017, that it
was probably an error even to let the jury hear that. But it
was obviously to the defense advantage and the government's
disadvantage.
So my ruling would stand even without that factor
but that factor even makes, in my opinion, it easier to
exercise my discretion and not give this instruction.
All right.
MS. DURRETT: Your Honor, can I be heard -- or make
a record?
THE COURT: Yes, Ms. Durrett.
MS. DURRETT: Thank you, Your Honor.
I just wanted to note, Your Honor, that we were not
asking for Court to force the government to grant immunity.
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We were not asking for the government to grant immunity for
Mr. Ricky Dixon. Mr. Dixon's attorney asked for that.
And the inference in the case, the inference that
we are requesting to tell the jury about is: There are two
parties in this case. One of them had the ability to call a
witness if that witness supported their case. The other
party could not call that witness. That's the inference.
It's not an inference that, hey, we asked you to
grant him immunity and you denied it.
We didn't ask for that. It's not our duty to
request immunity for that person. Mr. Berne requested it.
They denied it.
But the inference is not, hey, we asked for
immunity and you denied it. The inference is, two parties
had a witness, one of them could make that person available
to testify if they wanted to do it, and they had years to do
it, but they chose not to and the other party brought him
here and could not make him testify. That is the inference
that is involved.
It's not an inference that we requested that you go
to your supervisors and grant immunity. That is not it. We
did not make that request.
We were not able to call him. They were able to
call him if they wanted to. That is the inference that we
want to tell the jury about.
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And I understand the Court's ruling, but --
THE COURT: But that assumes that they had the
information, and they didn't, Ms. Durrett.
MS. DURRETT: Your Honor, they interviewed him.
THE COURT: You had it based on -- what was the
quote?
You had it, quote, based on "communications that
have not happened in this courtroom."
The government didn't have that.
MS. DURRETT: But, Your Honor --
THE COURT: In fact, the government only found out
that Dixon was even a witness when they got the call from the
Bureau of Prisons because the Bureau of Prisons thought that
it was their witness.
So I think that that's an ill-founded additional
argument.
It's 10:00. Do we have the jury, Officer?
All right. Let's bring them out.
Ms. Chaiken, I'm sorry I didn't give you a chance
to respond to that.
Do you have anything to add?
MR. KAUSHAL: Your Honor, nothing -- I think she's
misstating the law. It's incorrect what she said. Under the
law it's clear that it's clearly incorrect.
And the government will rest on its briefing.
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THE COURT: Very well.
So, obviously, those two instructions won't be part
of what I'm giving.
Has everybody had a chance to look at the final of
instructions and the titles and everything?
LAW CLERK: I just sent them.
THE COURT: We'll just do that before we get there.
And let me know if there are any issues.
MR. MARSHALL: Judge, are we getting hard copies of
those soon?
THE COURT: They have been sent. Check your
in-boxes.
MR. MARSHALL: Okay. Thanks, Judge.
THE COURT: Are we otherwise ready for your
closings?
MS. CHAIKEN: Yes, Your Honor.
THE COURT: Okay.
MS. WEBSTER: Your Honor, I just wanted to note
that we will need a brief break to adjust for technology
issues.
(Jury enters the courtroom at 10:01 a.m.)
THE COURT: You all can be seated.
Good morning, ladies and gentlemen of the jury.
THE JURORS: Good morning.
THE COURT: Happy Valentine's Day.
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All right. We are now going to hear closing
arguments. We will hear from the government and then we'll
hear from the defense.
Ms. Chaiken.
MS. CHAIKEN: Thank you, Your Honor.
GOVERNMENT'S CLOSING ARGUMENT
MS. CHAIKEN: Good morning.
THE JURORS: Good morning.
MS. CHAIKEN: The evidence in this case has shown
that Teldrin Foster and Carla Jackson both participated in
fraud during a time of national crisis.
You heard evidence in this case of 14 fraudulent
Paycheck Protection Program loans that were approved during
the pandemic, each for more than $700,000. A total of more
than $11 million, and you saw that each of these loans was
fraudulent.
You saw the tax forms, the Form 941s that were
submitted with each of these loan applications.
You saw that seven of the 14 businesses, half of
them, submitted identical Form 941s for every quarter of
2019.
You saw that these documents all had the same fake
stamps on them.
You heard testimony from the IRS that none of these
businesses had ever filed a Form 941 in 2019. Every document
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was fake.
You saw fake bank statements that were submitted
with some of these applications. You saw the real
statements, you saw the fake ones and you saw that some of
the businesses submitted identical bank statements to each
other.
You saw the payroll spreadsheets that were created
with identical numbers and just changing names.
And you saw the fabrication of the documents. You
saw them going back and forth in emails with numbers
changing, names changing, information changing.
And finally, you saw the bank records that show
that none of these businesses had any business at all, had
any payroll.
And you heard that after they got the money, they
didn't spend it on payroll. They sent the money to Darrell
Thomas. They spent it on personal expenses. They moved the
money around to the people that helped them get the loan.
Teldrin Foster is charged with various crimes in
connection with his involvement in these PPP loans. For each
loan, he is charged with wire fraud. If the lender that
issued the loan was federally insured, he is also charged
with bank fraud and with false statements to a federally
insured financial institution.
The judge will instruct you that those are two
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crimes that require the victim to be a federally-insured
financial institution. And as you heard, some of the lenders
in this case were and some of them were not.
He's also charged in connection with each loan to
commit conspiracy to commit bank fraud or wire fraud, which
is basically an agreement to commit those crimes of bank
fraud or wire fraud.
And finally, he's charged with money laundering.
Judge Boulee will instruct you that wire fraud has
four elements. And I will charge you with wire fraud because
Mr. Foster is charged with wire fraud as to each and every
one.
The first element is that Mr. Foster knowingly
devised or participated in a scheme to defraud someone by
using false or fraudulent pretenses, representations, or
promises.
And Judge Boulee will explain to you that a scheme
to defraud means a plan or course of action intended to
deceive or cheat someone out of money or property.
The government does not have to prove that the
alleged scheme actually succeeded in defrauding anyone.
And one important thing to remember here, because
you have heard that other people were involved in this scheme
as well, is that Mr. Foster is also charged with aiding and
abetting, which means he doesn't need to have personally
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performed every act charged.
Instead, he needs to have intentionally joined with
a person to commit a crime and he's criminally responsible
for the acts of people he criminally joined, he intentionally
joined with.
You saw evidence in this case that Teldrin Foster
joined with Darrell Thomas to commit PPP fraud as to each of
these loans. You saw that from the very beginning of the PPP
program, before applications were even being accepted, he was
communicating with Darrell Thomas, via WhatsApp, about the
Paycheck Protection Program.
You saw that Darrell Thomas found online a Paycheck
Protection Program request form and sent it to Teldrin Foster
on WhatsApp, and Teldrin Foster said, "that easy?" And
Darrell Thomas said, "hell yeah."
That was the very beginning of their plan to commit
PPP fraud. And you saw how they got started immediately with
the loan for Bellator Phront Group.
You saw that Teldrin Foster helped Darrell Thomas
create a fake bank statement for that business, and they
exchanged multiple versions back and forth.
You saw that Darrell Thomas and Teldrin Foster
figured out that they needed to get tax forms. And it was
Teldrin Foster's idea that they needed to stamp the form.
And then you saw that Teldrin Foster got those
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stamps. He told you he got it from someone who just moves
off of money, someone who made the stamps for him, and he
sent those stamps to Darrell Thomas. And then you saw how
those stamps ended up on the Form 941 that Bellator submitted
with its loan application.
You also saw how he worked together with Darrell
Thomas to create a payroll spreadsheet. We'll talk more
about this later but you saw that he got the list of employee
names, and then he got his wife who worked for the IRS to
make a template for him with the payroll information.
And you heard Teldrin Foster's own words. You
heard him say, "I knew the shit was wrong. We were
manipulating paperwork for him to get a loan."
(Audio was played.)
MS. CHAIKEN: You heard him say, again and again
and again, that they were manipulating documents. He said,
"me and him." "Me and Darrell Thomas."
(Audio was played.)
MS. CHAIKEN: And you heard him say in his own
words, "to get the money was fraud."
(Audio was played.)
MS. CHAIKEN: You saw that after they worked on the
Bellator loan, they just cookie-cutterred it and moved on to
other businesses. And you saw the same pattern where Darrell
Thomas would send Teldrin Foster, via WhatsApp, information
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for a business, and then the next day or the same day Teldrin
Foster, using his iCloud account, would send Darrell Thomas
forms for those businesses, identical forms. You saw them.
All he was doing was changing the business name.
And then, for example, with Impact Creations, when
the loan was approved, what did Darrell Thomas do? He sent
that to Teldrin Foster via WhatsApp. He was telling him,
"our scheme worked. This loan was approved."
And not only did he tell him it was approved, he
also made sure that Teldrin Foster got paid by Impact
Creations using that loan money.
You saw the same thing for Gaines Reservation and
Travel. Teldrin Foster creates documents, identical
documents, for the business. And then when there is
something that needs to be fixed in the document, Darrell
Thomas sends it to Teldrin Foster via WhatsApp.
And again, when the loan is approved, Darrell
Thomas tells Teldrin Foster, Teldrin Foster says "LOL bet."
And Darrell Thomas says, "Black Jesus."
You saw the same pattern for Transportation
Management Services. Business information goes into Teldrin
Foster's WhatsApp. Immediately after that, it comes out from
Teldrin Foster to Darrell Thomas with documents prepared for
that business.
Same thing with Lee Operations. Business
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information goes to Teldrin Foster. Teldrin Foster creates
the documents.
Same pattern for RK Painting.
D Parker Holdings, same pattern. The WhatsApp goes
to Teldrin Foster, and then Teldrin Foster creates the
documents.
And with D Parker Holdings, you started to see
something interesting. This is where you saw Gena Pyfrom
come into the picture. And you know that because you can
look at the timing on these emails.
On June 4 of 2020, the iCloud account sent Darrell
Thomas a payroll spreadsheet, and it was that identical
payroll spreadsheet that was based on that template from back
in April, the one that he used for every business because he
didn't know how to change the numbers because Teldrin Foster
didn't work for the IRS.
On June 8, four days later, all of a sudden, the
Yahoo account creates a new payroll spreadsheet where all the
numbers were different. And you know why that is; you know
that in that time period, around June 5, is when Darrell
Thomas started talking to Gena Pyfrom-Foster directly. He
needed her help to change the numbers because Teldrin Foster
wasn't cutting it, he didn't know how to change the numbers,
all the documents were identical.
That's where you start seeing this pattern where
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Gena Pyfrom comes in. She fixes the documents. But Teldrin
Foster is still the guy who is putting the finishing touches
on these documents, stamping them so that they are ready to
go to the banks to look like they are legitimate.
You saw that with Continuing Success. Teldrin
Foster prepares the documents in May. Gena Pyfrom comes in
in June and fixes the documents, creates payroll spreadsheets
with numbers that aren't identical, and then Teldrin Foster
stamps them.
And when there is a mistake on the document,
Darrell Thomas contacts Teldrin Foster via WhatsApp, at a
time when he was already talking to Gena Pyfrom.
If he wanted to reach her, he would WhatsApp her.
But he went to Teldrin because Teldrin was the one that was
finalizing the documents, stamping them, and making sure
everything was right.
You saw with All Star Room and Board how Teldrin
Foster helped Darrell Thomas fabricate a bank statement for
All Star Room and Board.
Darrell Thomas sent him the fake Gaines Reservation
and Travel bank statement. He sent him a bank statement for
All Star Room and Board. And then Teldrin created that All
Star Room and Board fake bank statement.
You saw Teldrin Foster send those identical
Form 941s -- that's on the left there. On the right, you see
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Gena Pyfrom-Foster come in and change the numbers because
Teldrin Foster doesn't know how to change the numbers. And
after she does that, we're back to the iCloud account,
stamping that document.
You saw the same pattern with Infinite Education
Services. Communications in the WhatsApp between Teldrin
Foster and Darrell Thomas about that business, and then
Teldrin Foster stamps those documents when they are ready.
ML Exotic Customs, again, Darrell Thomas asks
Teldrin Foster what's the ETA on ML Customs? And shortly
after that, Teldrin Foster sends him exactly what he asked
for, ML Customs, ML Exotic Customs.
Same thing with Bellavie. You saw the business
information going to Teldrin Foster via WhatsApp, and then
you saw him prepare those documents and stamp them.
Advertising and Then Some is another example. You
saw Teldrin Foster send the Form 941s with stamps on them.
And remember, this is the one where the stamp was wrong
because it was for a quarter that ended on December 31 of
2019, but it was stamped as being received in October of
2019, which is impossible.
And what did Darrell Thomas do? He went to Teldrin
Foster and said, You have to put the 2020 stamp on this. And
then Teldrin Foster did that.
Finally, you had Mickies Auto and Tire. This is
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the only loan that is charged in the indictment, of all the
ones you've heard, that's not referenced in the WhatsApp.
And you saw that they had lots of conversations on the phone,
you saw that they had lots of communications that are not
written down. But this is the only one that is not in
writing, and you saw that it followed the exact same pattern.
The Yahoo account, which was Gena Foster at the
time, creates the documents and then the iCloud account
stamps them.
Now you heard a lot in this trial about Gena
Pyfrom-Foster. You heard that she did not know Darrell
Thomas before the PPP loan fraud. She was married to Teldrin
Foster. And you saw how she became involved because you saw
the message where Teldrin Foster told Darrell Thomas "LOL. I
think I have got her to do everything, the payroll, taxes,
and find the loans."
And Darrell Thomas said, "Shit. That's what's up.
We all about to eat good."
Teldrin Foster brought Gena Pyfrom into this to
help with the PPP loan fraud. And you heard him say that, at
the beginning, he just asked her to give him a template
because he couldn't figure it out. It was too time
consuming, he didn't know the formula, and Excel wouldn't
give it to him. So he asked her to help.
(Audio was played.)
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MS. CHAIKEN: You saw that after Gena Pyfrom gave
Teldrin Foster the formula, gave him the template, he used it
to create identical documents for each business.
And you know that that's what he did because he
didn't know how to change the numbers, and he told you he
didn't know how to change the numbers.
You saw how he sent the same spreadsheet, over and
over and over again, with the same employees making the same
exact amount of money for different companies because all he
could do was take Gena's template and just change the name on
it.
And you know that that was not Gena doing that
because you saw what happened when Gena Pyfrom did actually
start becoming involved again in June. She started creating
different templates with numbers that changed because she
knew how to change the numbers.
The defense has asked you to believe that Gena
Pyfrom and Darrell Thomas framed Teldrin Foster. And when
you are considering that defense, you should consider Judge
Boulee's instruction that in considering the evidence you may
use reasoning and common sense to make deductions and reach
conclusions.
This is what the defense is asking you to believe:
They're asking you to believe that right when the
PPP program was announced, Gena Pyfrom hacked into Teldrin
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Foster's WhatsApp account hoping that maybe somebody he knows
wants to commit PPP fraud and is going to text him about it,
and then she can respond and they can start to work together
on PPP fraud using Teldrin Foster's account.
That makes no sense at all.
They're asking you to believe that Darrell Thomas
and Gena Pyfrom are so sophisticated that they figured out
how to hack into Teldrin Foster's WhatsApp account, his
Telegram account, his iCloud account and his Yahoo account
without his knowledge, without him having any idea what they
were doing.
And instead of using those accounts to commit the
fraud and frame him, instead of creating fake email addresses
that they could use to remove themselves from the situation,
what they chose to do is email themselves, message
themselves, refer to themselves in the messages, so that if
anybody ever looked at the messages, they would know, not
only that Teldrin Foster was involved in the PPP fraud, but
that they were, too.
That makes no sense.
If Gena Pyfrom had access to Teldrin Foster's
iCloud account and was trying to frame him, she would not
have sent this email from her own email address to Darrell
Thomas and to Teldrin Foster. She would have just created
the document and then had it, instead of putting it out there
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so that anybody looking at these emails would know that all
three of them were involved in this.
If she had access to Teldrin Foster's WhatsApp
account, she would not have sent a WhatsApp message that
said, "LOL, I think I have got her to do everything."
Because anybody reading that message would immediately be
pointed in the direction of the one person in Teldrin
Foster's life who would know how to do payroll and taxes, his
wife, who works for the IRS.
They're asking you to believe that they framed
themselves in order to frame Teldrin Foster. And that makes
no sense.
They're also asking you to believe that all of
these payments to Teldrin Foster were made as part of an
attempt to frame him. They paid him -- Darrell Thomas paid
him tens of thousands of dollars so that if anybody looked at
the financial trail they would see money going to Teldrin
Foster and assume he must have been involved.
And the idea that Darrell Thomas would pay
something that he was framing is, again, ridiculous.
Teldrin Foster told you -- I'm sorry, the defense
told you that these payments were for money that Darrell
Thomas owed to Teldrin Foster for some retirement investment
he made with Darrell Thomas.
But you saw Teldrin Foster's own words about what
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this money was for. It was for him to collect his
percentage, his percentage of the PPP money.
And finally, the defense is asking you to entirely
ignore Mr. Foster's own confession. They just are asking you
to assume that Darrell Thomas and Gena Pyfrom just got
incredibly lucky that when the FBI went to talk to Teldrin
Foster, he just started making up details that lined up
exactly with what had happened, even though he knew nothing
about anything that had happened.
Ms. Webster told you in her opening statement that
you would hear how confused he was during the interview. But
he wasn't confused. He gave detailed explanations of how he
and Darrell Thomas worked together, how they got the forms,
what they did with them, how they changed them.
The only thing that he was confused about was
trying to figure out how to talk his way out of the hundreds
of emails that he exchanged with Darrell Thomas. And you
heard him say, over and over and over again, "It was just
bullshit. I was just feeding him bullshit. It was just
bullshit."
Yeah, it was bullshit. They were fake documents,
but there was nothing he could say to explain why he was
passing those documents to Darrell Thomas. That's the only
thing he was confused about.
On the other hand, you have heard no evidence in
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this case that there was any hacking of anything. You heard
that we have Darrell Thomas's phone. There was no Teldrin
Foster WhatsApp account on there. There was no Teldrin
Foster Yahoo account on there. There was no Teldrin Foster
iCloud account. There was no Teldrin Foster Telegram
account. It was Darrell's things on Darrell's phone.
You heard that on Darrell Thomas's computer there
was no evidence of hacking, no evidence of attempts to change
passwords, no evidence that he had any of Teldrin Foster's
passwords.
The defense told you in opening that you would hear
evidence that the Teldrin23@iCloud.com account was on Darrell
Thomas's computer. And you did not hear that evidence in
this trial.
What you heard from their expert, Mr. Persinger, is
that on May 22, 2020, in the span of a few seconds, there
were three attempts to do something with the identity
Teldren23@iCloud.com on an Adobe website.
There was not a single shred of evidence on that
laptop that anybody had ever logged into an iCloud account
and done anything on that account. No shred of evidence of
that at all.
And you heard that the Yahoo was on Darrell
Thomas's computer, and you heard that Teldrin Foster knew
that because he put it there.
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(Audio was played.)
MS. CHAIKEN: Teldrin Foster knew that Darrell
Thomas had access to his Yahoo account. He put it on his
computer because they were working together, and that's how
they shared documents. He knew people had access to his
Yahoo account.
He didn't change the password. He didn't try to --
all he had to do was change the password. It would have come
off of anywhere else that it was logged in. But he knew
that's how it was being used.
The defense also had their expert testify that
Apple Continuity is a product that exists.
But you didn't hear any evidence in this trial that
anybody, anybody in the case had Apple Continuity, that it
was somehow linked to Teldrin Foster's WhatsApp account, his
Telegram account, his iCloud account, and that anybody ever
used Apple Continuity to get into any of Teldrin Foster's
accounts.
What the defense is asking you to believe is that
Gena Pyfrom and Darrell Thomas had access to all of Teldrin
Foster's accounts and they were able to use those accounts
for months without him having any idea, and that what they
decided to do with access to his accounts is to frame not
only him but themselves.
That makes no sense.
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I want to talk about a few other things that you
heard from the defense that are not defenses, and
Judge Boulee will not instruct you that they are defenses.
The first is that other people were involved. You
heard a lot in this trial about Darrell Thomas and about Gena
Pyfrom. And if Ms. Webster was prosecuting Darrell Thomas
and Gena Pyfrom, she would have a great case against them for
PPP fraud.
But this is not the trial of Darrell Thomas and
this is not the trial of Gena Pyfrom. This is the trial of
Teldrin Foster. And the only thing you need to decide is
what Teldrin Foster's involvement was.
The fact that other people were also involved does
not change his own involvement.
Another thing you heard a lot about was that there
were people involved in this that Teldrin Foster did not
communicate with. And again, that's not a defense. You
don't have to have a scheme to defraud with every single
person who was involved in the fraud.
Teldrin Foster had a scheme to defraud with Darrell
Thomas. That was his role. His role was to create the
documents and get the loans ready to be submitted.
The fact that other people are involved in that as
well that he did not communicate with is not a defense.
You also heard that Darrell Thomas got a lot of the
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money. He used it on things like cars and jewelry, and he
got cash. You saw all of that. And you heard that Teldrin
Foster was upset that he didn't get more, that he didn't get
his fair share. You saw that that's why they fell out.
They ultimately fell out because Teldrin Foster
felt like Darrell Thomas screwed him out of his share of the
percent of the PPP fraud.
But the fact that the person you committed fraud
with cheated you out of what you thought you deserved for the
fraud is not a defense to committing fraud.
And finally, even if you believe that Teldrin
Foster thought Darrell Thomas owed him money, the fact that
you think someone owed you money does not give you the right
to commit fraud with them to get that money back.
He said, "Well, I figured I might have a shot and
then I could get my money back, and so I decided to help him
with the fraud."
That's not a defense to the fraud.
The evidence shows that Teldrin Foster participated
in a scheme to defraud with Darrell Thomas as to each of
these loans, and that satisfies the first element.
The next element is that the false pretenses,
representations, or promises have to be about a material
fact. And that basically just means that it's an important
fact.
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And here, you know the fact was important because
you saw the application. You heard from the SBA how the loan
was calculated, and that the whole point of getting the loan
was that it was based on how much payroll you had, about
being an existing business, submitting real documents about
your business and your payroll, and then getting a loan based
on that information.
So all of the documents that were being created and
the information that was being put in this application was
clearly important because every lender told you, and the SBA
told you, that if anything in the application was false, the
loan would not have been approved.
That satisfies the second element.
The third element is that Mr. Foster acted with the
intent to defraud. And you heard him say himself that they
knew to get the money was fraud.
That's all you need to look to is his own words.
He said, "We were fixing to steal from the government."
You also saw Teldrin Foster and Darrell Thomas
discussing what information the banks want. He knew this was
being submitted to banks. And obviously, Darrell Thomas and
Teldrin Foster had no reason to be talking about these
businesses and creating fake documents for them unless the
purpose was to submit the documents to banks to get loans.
These were not just two guys who sit around just
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practicing how to Photoshop documents. The reason they did
this and the reason they put stamps on them were because they
wanted it to look legit so that when it went to banks the
loan would be approved.
And that proves the intent to defraud.
Finally, the last element is that there was an
interstate wire involved in the offense. And again, I'll
remind you here, Mr. Foster does not have to have personally
transmitted an interstate wire.
You heard testimony in this trial that Darrell
Thomas submitted all these applications from his home here in
the Northern District of Georgia; that those applications
then went to servers of lenders all over the country. And
then from there, the data from the loan application was
transmitted to the servers of the SBA in Virginia.
So there were interstate wires involved in the
submission of each of these loans. That satisfies the last
element. And you should find Mr. Foster guilty as to each
and every wire fraud count.
As I said, Mr. Foster is also charged with bank
fraud as to the loans that were issued by federally-insured
banks.
And the elements here are essentially the same
except that the victim is a federally-insured bank instead of
just someone.
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And so again, we have shown the evidence of the
scheme to defraud, that the false or fraudulent pretenses
were about a material fact, that there was an intent to
defraud.
And you heard the testimony from Cross River Bank,
Celtic Bank, and Customers Bank that they were federally
insured in 2020, which satisfies the last element.
Now Mr. Foster is also charged with conspiracy to
commit those crimes, and conspiracy to commit bank fraud and
wire fraud. And what that means, basically, is that there is
an agreement to commit those crimes between two or more
people.
As to the first element, that there was an
agreement to accomplish a common and unlawful plan,
Judge Boulee will instruct you that the government does not
have to prove that all the people named in the indictment
were members or the plan, or that those who were made any
kind of formal agreement.
And he will also instruct you that the heart of the
conspiracy charge is the making of the unlawful plan itself.
The government doesn't have to prove the plan succeeded.
It's having the plan to do it that's the crime.
And as far as the law is concerned, it makes no
difference whether evidence is direct or circumstantial. So
here, of course, people are never go to get together and sit
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with their lawyers and draft up a contract that says "we
hereby agree to commit bank and wire fraud." You are never
going to have direct evidence of that kind of agreement.
Instead, you have to look at circumstantial
evidence of what people do, what people say, how people act.
And here you have seen the evidence that Darrell
Thomas and Teldrin Foster were working together, talking
every day, exchanging documents. And the only reason for
them to be doing that was because they had an agreement to
commit fraud as to each and every one of these PPP loans.
The second element is that Mr. Foster knew the
unlawful purpose of the plan and willfully joined in it. And
Judge Boulee will instruct you that a person can be a
conspirator even if he doesn't know all the details of the
unlawful plan or the names and identities of all the other
alleged conspirators.
So again, it doesn't matter that he didn't talk to
these other people. He knew they were there because he knew
these businesses were coming from somewhere. But it doesn't
matter.
What matters is whether he knew and he conspired
with at least one person. And you saw that with Darrell
Thomas.
Judge Boulee will also instruct you that if
Mr. Foster played only a minor part in the plan but had a
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general understanding of the unlawful purpose of it, and if
he wilfully joined on at least one occasion, that's
sufficient to find him guilty.
And you saw in this case how he joined these plans,
over and over and over again. Every time he created a fake
document, every time he talked to Darrell Thomas about these
loans, every time he put a fake stamp on a document, he was
joining the conspiracy to get a fraudulent PPP loan.
That satisfies both of the elements of conspiracy.
And as to each of the conspiracy counts, you should find
Mr. Foster guilty.
Finally, as I mentioned with respect to the
federally-insured banks, Mr. Foster is charged with making
false statements to a federally-insured financial
institution. And these elements are covered by what we've
already discussed:
There were false statements and reports in the
documents that were submitted to these lenders, there was an
intent to defraud or an intent to influence the action of the
institution because the intent was, obviously, for the lender
to issue a PPP loan based on the fake numbers and the fake
documents that were submitted.
And again you heard that Cross River Bank, Celtic
Bank, and Customers Bank were federally-insured.
Finally, Mr. Foster is charged with money
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laundering. And I'm going to talk about the elements of
money laundering in more detail when I talk about
Ms. Jackson, but you'll hear that there are four elements:
The first is that the defendant knowingly
conducted, or tried to conduct a financial transaction.
And again, I'll remind you, he doesn't have to have
done it personally, as long as he intentionally joined with
someone to do it. And you heard him say that this payment
that went to Gena Pyfrom-Foster's account was actually a
payment to him.
(Audio was played.)
MS. CHAIKEN: And you heard him say, later in the
interview, that the reason it went into Gena's account is
because his account got locked up, so Darrell Thomas was
paying him through Gena's account. This is a financial
transaction that he conducted, or tried to conduct, by
joining with Gena to get this money.
The second element is that the defendant knew the
money or property involved in the transaction came from some
kind of unlawful activity.
And of course, he knew the money from Bellator came
from unlawful activity because he himself helped Bellator get
a fraudulent PPP loan.
The third element is that we have to prove the
money actually did come from an unlawful activity. And we
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have shown you the evidence that the Bellator Phront Group
loan was fraudulent.
And finally, we have to show that the defendant
knew the transaction was designed, in whole or in part, to
conceal something about the transaction or about the money.
And here, you saw that it was a payment to Gena
Pyfrom's account that was actually meant to be money for
Teldrin Foster.
You saw that the payment was designated as being
for payroll services and accounting, even though there were
no payroll services and accounting. And you saw that what
the money was actually for was payment for participation in
fraud.
That satisfies the four elements of money
laundering. You should find Teldrin Foster guilty as to each
and every count he is charged with.
I'll move on to Carla Jackson. She is charged only
with money laundering. She is not charged with participating
in the underlying PPP loan fraud. I'll go through each of
those elements again.
Again, the first element is that Ms. Jackson
knowingly conducted, or tried to conduct, a financial
transaction. You saw her deposit of this check. John Gaines
told you that that's her handwriting. And you know that
she's the only person who is an authorized signer on this
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account. She's the only person who can make transactions in
this account. And so you know that this check deposit was
hers.
And I will note, by the way, that Judge Boulee will
not instruct you that it matters what type of transaction the
financial transaction is. You heard that the indictment
says -- refers to this as a wire transfer. It's obviously a
check. But you just need to find that she knowingly
conducted, or tried to conduct, a financial transaction, not
any specific type of transaction. So the fact that it's a
check does not matter.
You saw that she also received a wire. These are
the two deposits she received, and these are the two counts
that she is charged with.
Now the second and third elements, I want to
explain them again because there is a very important
distinction here.
The third element is that we have to prove that the
money or property actually came from a specified unlawful
activity, which in this case is wire fraud. That means we
have to prove that the source of the money came from a wire
fraud.
In this case it's the PPP loan fraud, and we've
talked about how that was a wire fraud. We don't have to
prove, in the third element, that Ms. Jackson knew the
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specific criminal activity that the money came from, or even
that she knew it was a wire fraud. We just have to prove
that it did, in fact, as a factual matter, come from a wire
fraud.
The second element is the one that has to do with
Ms. Jackson's knowledge. And the knowledge that she needs to
have had is that the money was some kind of unlawful
activity. She just needs to know it was illegal, but she
doesn't need to know specifically what it was from or what
the exact illegality was.
As far as the third element, you saw that the
Gaines Reservation and Travel loan resulted -- or was a wire
fraud. You saw the fake loan application, you saw the fake
bank statements and the fake 941s.
You heard that Gaines Reservation and Travel has no
business, and never did. And you heard that that loan
application was submitted from here in the Northern District
of Georgia, and then went to Cross River Bank and then to the
SBA. And none of those servers were in the Northern District
of Georgia.
So we have proven beyond a reasonable doubt that
the money or property did come from a wire fraud.
So what that really leaves you to decide is the
second and the fourth elements, about what Ms. Jackson knew,
whether she knew that the money was from something illegal,
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and whether she knew the transaction was designed to conceal
or disguise the nature, location, source, ownership, or
control of the proceeds.
And when you are considering what she knew, there
is a very important instruction Judge Boulee is going to give
you about proving knowledge. We can prove that Ms. Jackson
actually knew both of these things, but Judge Boulee will
also tell you that it's enough that the defendant was aware
of a high probability the fact existed, unless she actually
believed the fact didn't exist.
Basically, what that means is if you avoid learning
something, that's the same as knowing it. And you can find
knowledge if Ms. Jackson actually knew, or if you find that
she had every reason to know but deliberately closed her eyes
to avoid finding out.
You heard in this case that Ms. Jackson knew that
John Gaines was working on PPP loans. She filled out her own
PPP loan application for a business that you heard had no
employees. John Gaines had her do that.
And he told you she knew he was working on PPP loan
applications. So when, all of a sudden, $300,000 fell out of
the sky into Mr. Gaines's account during a national pandemic
where people were laid off and businesses were shut down and
the economy was ground to a halt, she knew that that money
came from the PPP program.
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Mr. Gaines admitted to you, she's the one who
filled out this PPP application. You saw the signature on
it, you saw that it matches everything else that she has
signed that you have seen in this case.
You also know that she knew that the money came
from something illegal because you heard her tell lie after
lie after lie about what the money was for. And there is
nothing illegal about getting money from your ex-husband and
moving it into your account. There is nothing illegal about
moving money between people if that money is not from an
illegal source.
The only reason to lie about what the money was for
is if you know it's not supposed to be there.
(Audio was played.)
MS. CHAIKEN: You heard her say that she got more
than $335,000 into her account because there was going to be
some unspecified project that she had employees for, but she
didn't know who they were, and she didn't know how many,
because there actually wasn't a project that had even been
discussed.
And you heard from John Gaines and you know that
there was no project. There was a trip to Alabama where he
took a picture of a street sign and said that he had big
plans to do a construction project.
You also heard that Ms. Jackson lied about who the
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money was from and pretended it was an arm's length
transaction. And as you listen to this next clip, I just ask
you to keep in mind the testimony you heard from John Gaines
yesterday, about how he's the one who gave her the money,
he's the one who talked to her about the project. And listen
to what she said, now thinking of that testimony in mind,
about where she got this money.
(Audio was played.)
MS. CHAIKEN: That was a painfully, painfully long
two minutes where Ms. Jackson struggled to figure out what
she was supposed to say about where the money came from.
This was only weeks after she had received the transactions.
This is July of 2020.
And the only reason not to say "these were checks
my ex-husband gave me to put in my account for some project
he's doing" is because she knew that that was illegal. She
knew the money was not supposed to be there. She knew that
was not what the money was for.
Otherwise, there would have been no reason for her
to just say -- no reason for her to not just say "oh, my
ex-husband gave me these checks and asked me to put them in
the account." She knew that the money came from an illegal
source.
And speaking of painfully long, I want to talk
about John Gaines, because John Gaines was who Ms. Jackson
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wanted you to hear from. He was her star witness.
And asking him questions was like pulling teeth.
He would not admit to anything unless I showed him a document
that showed it.
He claimed he couldn't remember things that
happened two weeks ago on what was probably one of the most
important moments of his life, when he pleaded guilty to
committing a federal crime.
And although it took a long time, you eventually
heard about his long history of fraud. And his testimony
showed that he is hopelessly untrustworthy. But there are a
few things he couldn't deny. He admitted that Ms. Jackson
knew that he was doing PPP loans during that time period.
He admitted that Gaines Reservation had never had
any business, had never done business with Management
Resource Services. And Management Resource Services didn't
have any employees, either.
He told you that when $335,000 fell out of the sky
into Gaines Reservation and Travel's account, she didn't ask
him a single question about where he, all of a sudden, got
money when people were struggling to put food on the table
during a pandemic. And she didn't ask him because she knew.
She knew that it was PPP money.
John Gaines sat on this witness stand and he told
you that he and Ms. Jackson were business partners and that
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they were going in on a project together in Montgomery,
Alabama, a place he had been to with someone he can't even
remember, to scope out a business project. Where he took a
couple of pictures of street signs and numbers on a building.
But what his testimony showed is that the only
thing John Gaines and Carla Jackson were partners in was
money laundering.
Finally, you saw evidence that Ms. Jackson knew the
transaction was designed, in whole or in part, to conceal or
disguise the nature, location, source, ownership, or control
of the proceeds.
You saw the payments themselves and what they said
they were for: Consulting fees, daily business management
and payroll.
And you know that that's not what the payments were
for because you know that there was no business to consult.
There was no business to manage daily. There was no payroll.
That's just what it needed to look like.
You saw all of the transactions that Ms. Jackson
made. You saw that, on June 8, the money came into her
account. She deposited the check for $155,252.50 for
consulting fees and daily business management. And you saw
the text messages that John Gaines sent her on June 18,
telling her to make payments to pay off his auto loans.
And you saw she didn't respond, she didn't say, "I
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thought this was supposed to be for consulting fees. I
thought this was for a project we're doing."
He told you she did not say anything. She did not
ask him any questions. And that's because she knew that the
money was never for consulting and it was never for daily
business management. It was a place for John Gaines to hide
the PPP loan proceeds.
And there is one other very important thing about
the timing here. Even if you believe that, on June 8 of
2020, Ms. Jackson somehow thought this was really for a
project, if you believe everything the defense wants you to
believe, she really thought that she was going to consult and
do daily business management on some project in Montgomery,
Alabama, on June 18, 2020, she found out that was not true
because John Gaines asked her to use that money to pay off
his auto loans.
So by June 18 of 2020, she knew that money was not
for a project. It was just money John Gaines couldn't keep
in his own account, in the Gaines Reservation and Travel
account.
So on June 22, when he asked her for her bank
account information so that he could send a wire, by that
point she knew full well that this was money from an illegal
source and that John Gaines wanted to hide it in her account.
And finally, ladies and gentlemen, again, you don't
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need to look beyond Ms. Jackson's own words to know that she
knew the money was from the Paycheck Protection Program and
she knew that it was going into her account to conceal that
money because when she was asked what that money was for,
this is what she said.
(Audio was played.)
MS. CHAIKEN: Of all the things Ms. Jackson could
have said that money was for -- to purchase real estate, to
purchase equipment, to purchase construction materials, to
purchase products they needed -- of all the things the money
could have been for for this project, the one thing that she
chose to say it was for was payroll. And that's because she
knew that payroll is the one primary approved expense under
the Paycheck Protection Program.
When you get back to the jury room, I ask you to
look at the exhibits, the long paper trail that the
defendants left. I ask you to listen to their own words, the
recordings of their interviews.
And I ask you to use your common sense, and return
the only verdict that is supported by the evidence and by the
law, and that is a verdict of guilty on all counts.
Thank you.
Your Honor, I reserve the rest of my time for
rebuttal.
THE COURT: All right. Thank you.
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All right. Did you say you needed a couple minutes
to get your audio visual connected and ready?
MS. WEBSTER: Yes.
THE COURT: Why don't we take a very short break,
so not a 10-minuter, but maybe more like a 5-minuter?
Thanks everyone.
(Jury withdrew from the courtroom at 10:53 a.m.)
(Court recessed at 10:53 a.m., and proceedings
continued as follows at 11:07 a.m.:)
(Jury enters the courtroom at 11:07 a.m.)
THE COURT: You all can be seated.
Ms. Webster, go ahead.
MS. WEBSTER: Thank you, Your Honor.
DEFENDANT FOSTER'S CLOSING ARGUMENT
MS. WEBSTER: I told you in opening, that we were
going to try to bring you the rest of the story.
Now, the story from the government's perspective is
simple, but the reality is way more complicated, and that has
borne out time and time again. And I hope you have seen it
throughout this trial.
Let's start with the money laundering count,
Count 59 of the indictment.
To find Mr. Foster guilty on Count 59, you have to
find that he's guilty of concealment money laundering. And
that means that the government has to prove beyond a
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reasonable doubt that Teldrin Foster had the intent of making
this transaction for the purpose of concealing the source of
the funds.
Now, they're going to say that he did not have to
be the one that made that transaction, that he can be guilty
if he aided and abetted in making that transaction.
But to be guilty of aiding and abetting a
transaction or a crime, you have to intentionally join with
the person who commits the crime. And the Judge will tell
you that knowledge that a crime was being committed is not
enough. You must have involved yourself in it in some way.
Finding that a defendant is criminally responsible
for the acts of another person requires proof that the
defendant intentionally associated with or participated in
the crime, not just that the defendant was simply present at
the scene of the crime or knew about it.
So Mr. Foster had to have the intent to bring this
deposit about. And the government has not presented a single
shred of evidence that he knew about it before it happened.
The government established that there was a deposit
of $10,560 on June 11 of 2020, and that money went into the
Pyfrom Exclusive Consulting account. They also established
that, at some point in December of 2020, Teldrin Foster said
at some point, "I had access to that money."
But we had to show you the rest of the story. We
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had to show you that, first, Gena Pyfrom-Foster set up her
own personal Bank of America account on May 15 of 2020. And
then we had to show you that, on June 10 of 2020, Gena
Pyfrom-Foster went into Bank of America to set up this Pyfrom
Exclusive Consulting account for the purpose of obtaining
payments for Darrell Thomas.
And we had to show you that Gena Pyfrom-Foster
communicated with Darrell Thomas about that account and that
she sent Darrell Thomas the information for the account that
she had set up.
And this is that photo that she sent to Darrell
Thomas in their WhatsApp messages.
And then we had to show you that on the following
day, Darrell Thomas sent Gena the deposit slip showing that
the deposit had been made. And we had to show you where the
money went, that the money did not go to Teldrin Foster.
We had to show you that Darrell Thomas gave Gena
money on other occasions, that there was cash that was given
to Gena Pyfrom-Foster. And there are pictures of that.
If we can go to the next slide -- yes.
And then that there are also Zelle transfers that
were also sent directly to Gena Pyfrom-Foster. This shows
the $3,000 and the $7,000 deposits that went to Gena
Pyfrom-Foster.
And we had to ask the questions: Was there any
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evidence that Teldrin Foster knew that this transaction was
happening?
And what was the answer? No. There were no
communications between Teldrin Foster and Gena or Darrell
about this transaction. There were no communications between
Darrell and Gena where they said, hey, make sure that Teldrin
gets this money, or, okay, I'll make sure that I give this
money to Teldrin.
That never happened. There are no communications.
There is no evidence showing that this money was intended for
Teldrin Foster.
Now the government will say, well -- and has
said -- that he admitted to it in his statement. But the
evidence does not show that he knew about it in advance. In
fact, it clearly shows the opposite, that he was not
involved.
And you cannot intentionally join in with something
that you do not know is happening. But beyond that, they
haven't proven that anyone had the intent to conceal the
source of the funds.
So they haven't even proven that the people who
actually made the transaction had the intent to conceal the
source of the funds.
So Mr. Foster cannot be guilty of Count 59.
Now, turning to the conspiracy and fraud charges.
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The government presented evidence of a few people that were
involved in this case: Teldrin Foster, Darrell Thomas, Gena
Pyfrom-Foster, Carla Jackson. But we're the ones who had to
tell you about everyone else that was charged in the
indictment.
This is from the indictment that you will have a
copy of. And you will see all these names in the left-hand
column are people that Teldrin Foster was supposed to have
conspired with.
So we're the ones who had to tell you that these
people existed, and we're the ones who had to tell you what
roles they played in these conspiracies. These are the names
of the people that the government says that Mr. Foster
conspired with.
Does he have a separate agreement with each of
these people? The government just stood up and said that he
had one conspiracy with Darrell Thomas, but -- so why is he
charged in 14 different conspiracy counts? If the government
is saying that there is only one conspiracy with Darrell
Thomas, that is not what is charged in this indictment and
you cannot find him guilty of these charges.
The government said that they have to prove that
there was a specific action for each conspiracy. And the
Judge will tell you that you have to consider each count
separately, the evidence for each count separately, and the
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evidence for each defendant separately.
So the fact that you may think, well, he may have
made an agreement as to one count does not mean that he's
guilty as to every count.
The only alleged co-conspirators that you've heard
from in this case are people that the defendants called. You
heard briefly from Ricky Dixon, and you heard from John
Gaines because Ms. Jackson called him. And despite what the
government calls his painfully long testimony, they didn't
ask him if he knew Mr. Foster.
They could have brought you other people to
testify. They could have brought Darrell Thomas. And if
they are so confident that Darrell Thomas would have said
that he was conspiring with Teldrin Foster, where is he?
Where is he?
They could have brought Gena Pyfrom-Foster in. If
they're so confident that Teldrin Foster was the one using
his WhatsApp messages and no one else had access to his
devices, why would you not bring him in? They didn't bring
him. And you have to ask yourself why.
Why would they not bring someone in to testify
against him? Why would they not bring someone in to actually
put him behind the keyboard of those emails that were sent?
Why would you not bring someone who could actually put him
behind the phone of those WhatsApp messages? They want you
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to rely on the fact that they were sent, but we think you
should demand more.
Now turning to the rapid! PayCards, the government
told you that Darrell Thomas and Bellator issued
rapid! PayCards and that Teldrin Foster had one, therefore,
he must have had that card. But we had to tell you the rest.
We had to tell you that there are actually 198 of
these rapid! PayCards issued. And we had to tell you that
they were issued in all sorts of people's names, people that
never actually had a rapid! PayCard.
And we're the ones who had to tell you that Darrell
Thomas had at least nine in his possession at the time of his
arrest.
Now, they brought in Agent Berni to testify, but
we're the ones who had to ask him, could these call records
be associated with calls from your watch or your tablet? And
Jim Persinger had to tell you that they could.
We had to demonstrate to you that Agent Berni had
plotted points that were based on what are called
reconciliation transactions. Right? Reconciliation
transactions that do not establish the actual time when those
transactions happened.
And the government and Agent Berni did not realize
that the report incorrectly mapped those transactions until
later. But they still used that report to bring to you, to
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try to convince you that they could establish where
Mr. Foster's phone was.
They sort of tried to breeze past it, but these are
problems in their case that they put in front of you.
Now let's talk about the emails. The government
told you that Mr. Foster sent these emails, and therefore he
must be guilty. That those emails were sent, and he's the
one who had to have sent them.
But we're the ones who had to tell you about
Darrell Thomas's laptop. Darrell Thomas's laptop that was
found with a receipt with his trip to Las Vegas. Right?
Don't let them fool you into thinking that Teldrin Foster was
using that laptop.
It literally had a receipt from Darrell Thomas's
trip. There is no evidence that Teldrin Foster was in Vegas
with him.
So we had to tell you that the laptop had Teldrin
Foster's Yahoo email address logged in. And there is
actually a link, if you look in the top picture, there is an
LNK file that shows you that was a link to his account on the
laptop.
And I believe in the government's closing they
played a statement where Mr. Foster indicated that his email
address might have been logged in on the desktop. That is
not a desktop. That is a laptop computer. You can see it
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with your own eyes.
Now we had to show you at least in May of 2020,
that Mr. Foster's email address was logged in to this laptop,
and that in June 2020 this laptop was used. And it was used
to log into his Yahoo account over and over and over again.
If this email was being used on Darrell Thomas's
device, the government's entire theory that Gena was the one
accessing his Yahoo account and sending all those emails
doesn't even make sense.
We had to show you that whoever was using this
laptop was actively going into Yahoo and downloading files
from the emails. And we had to show you that whoever was in
the Yahoo account was actively working with this fake
Bellator statement. That's what Jim Persinger came in and
told you.
And we had to show you that someone was logging
into something with the Teldrin23@iCloud.com email account.
Now, the government wants to tell you, okay, fine, maybe
somebody else had access to that Yahoo account, but there is
this pattern that Gena used the Yahoo email address in order
to send the non-stamped versions of the 941s, but then the
iCloud came next and was used to send the stamped versions of
those, so Teldrin Foster must have sent the iCloud account
emails.
So let's walk through that a little bit.
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In the next slide we see an email from
Teldrin23@iCloud.com and it's referencing the Impact
Creations 941s. Here is a non-stamped version. Right? This
is not stamped.
But then on the next slide you will see that there
is a stamped one.
And on the next email, there is another stamped one
from Impact Creations. And then in the next email, you will
see another email from the iCloud account, sending documents
about Lee Operations. And you will see again there is a 941
that's not stamped, and then you will see one that is
stamped.
And then, in the next email, you see another email
from Teldrin23@iCloud.com, and then you see, what? A
not-stamped 941, and then you see some that are stamped.
And this repeats a pattern. Here's another one.
The Teldrin23@iCloud.com account, a non-stamped version, and
then a stamped version.
Now, the government is going to say, well, those
emails are from May 2020 and Gena Pyfrom-Foster wasn't
involved at that time. But their so-called pattern doesn't
even line up for the period in which they have to admit that
Gena was involved.
We had to admit the WhatsApp messages from Gena
Pyfrom-Foster that showed when these messages were sent. For
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example, on June 23, on the left, you will see that Gena
Pyfrom-Foster is saying "I just sent the Richlands 941
payroll reports and 940 for 2019." That was sent at 10:29.
And then you see the email account at 10:23, saying "here are
the documents."
And then the next slide, something similar. She
says, "Hey, I just sent Metadore and Linda's Hair," and then
you see the emails several minutes prior.
And then we have an email that says, "Okay, about
to send you Securus." And then, a little while later, we
have the email with all the documents from Securus.
But the next one is the one that the government
doesn't want you to think about because this disrupts the
pattern.
At 10:42, Gena says, "I'm about to send you the
email ones I did today." So remember that says "ones,"
plural. Okay?
Then eight minutes later, at 11:00, there is an
email from, what? The Teldrin23@iCloud account with these
documents. And then, seven minutes after that, another email
from, what? The Teldrin23@iCloud.com account.
So this pattern that the government is telling you
doesn't even hold up when you look at the emails. And we are
asking you to look past what you are being told, to see what
you can verify with your own eyes.
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Now let's talk about the pattern one more time.
The government has said this is the pattern, this is what
happened: Gena sent the emails from Yahoo, then Teldrin
sends Darrell the stamped versions and then Darrell uses
them.
But this only makes sense, this pattern only works
if there is this middle thing, this middle step where Darrell
sends the documents to Teldrin for the stamps. And where do
we have that?
We haven't seen emails, right, where Darrell is
saying, "Here is all the non-stamped versions. Please stamp
them."
We haven't seen WhatsApp messages sending all the
things that Gena made for Teldrin to stamp. That leaves a
huge missing link in the government's case. And the
government obtained the search warrant for all of Darrell's
emails accounts and we have his phone. Right? And they come
here to prove their case against Teldrin Foster, but where is
this? Why don't we have it?
So their alleged pattern is not supported by the
evidence.
Now let's talk to you about Gena and Teldrin's
relationship. From the government's perspective, they are
married. Right? They must live together, they must be
working together. But we had to tell you the rest of that
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story, too.
Teldrin and Gena may be married in form, but they
are not married in the sense that they have a marriage, a
relationship. And if not all marriages are created equal,
then this one is on the no-good/bad side of that scale. And
it especially is not great after Teldrin found out that Gena
was working with Darrell behind his back.
And I know that some of you may disapprove, you may
think if you are married, you shouldn't be in relationships
with other people, and we understand that. But despite that,
we brought Jennifer Murray in to testify, to show you two
things.
First, that Teldrin Foster and Gena Pyfrom-Foster,
they're not a team. They're not a pair. They do not work
together. This is not your typical marriage.
But the second point is to address the WhatsApp
messages. Because Jennifer Murray told you that Gena knows
how to get into Teldrin Foster's phone, especially during
this time period.
She told you that Gena would send the codes to the
phone at least twice a year, between 2020 to 2022. So that
idea that no one else has access to Teldrin' phones or his
devices is not true.
And remember that the apps that the government has
relied on, WhatsApp and Telegram, they are apps. They're not
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your text messages. So they are not the things that are
connected directly with your phone.
So again, we're asking you to look beyond what you
may have heard and listen to the evidence that we have also
presented. And while the government may not like that
Teldrin Foster is not the sole person with control over his
phone or control over his email addresses, it does not mean
that it's not true. And we proved that to you.
Now the government wants you to think that Gena and
Darrell started communicating in June of 2020. And we're the
ones who had to tell you, wait, that's not true. Because you
can see that they actually began communicating directly way
back in, when? April of 2020.
This email was sent on April 8 of 2020. And you
can see that Gena is communicating directly with Darrell
Thomas.
And let me be clear that, even if Teldrin Foster
introduced Gena to Darrell Thomas, he is not therefore
responsible for every single action that they took together.
And on that slide, that previous slide that I was
showing you, look at what they are talking about. Are they
talking about PPP fraud? They are talking about taxes. They
are talking about an 1120, which we know is a tax form. And
this is what Teldrin Foster knew about.
But then, on the next slide, you will see that
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Darrell Thomas sent Gena Pyfrom-Foster the, what? A PPP
application on April 9 of 2020. And on the next slide we can
see what it is, which is a PPP application for Bellator
Phront Group.
So the idea that Darrell and Gena did not begin
communicating until June of 2020 is just not true.
We want you to listen to Gena's own words. Okay?
When she wanted to be paid for her work, she sent this list
of her completed consulting contracts. And on this list are
9, I believe, of the 14 loans charged in the indictment. And
Agent Stites told you there is no legitimate consulting work
going on here. Right? It was all illegal.
So the government again says she wasn't involved
until June, but we know that she was involved much earlier
because the first loan on this list is the Bellator Phront
Group. Right? So we know that she was involved earlier.
And for the other ones that are not listed on this
list. Right? As the government has described them, they are
clones. They are the exact same. It does not take work to
repeat those. So anyone could have done that, and it does
not have to be Teldrin Foster.
But let's talk about Teldrin's statement. The
government wants you to think, well, he said he Googled PPP
information when the PPP loans were all over the news and
that he discussed it with Darrell, and therefore he must be
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involved.
But as we know, just because someone says something
in an interview with law enforcement does not make it true.
So let's think about the rest of the story as it relates to
his statement.
To fully understand what was going on during that
interview, you have to think about what Teldrin Foster knew
at the time, not what we all know now, but what he knew back
in December of 2020. So what did he know on that date?
He knew that the FBI had interviewed Gena
Pyfrom-Foster. He knew that Darrell Thomas had been arrested
and indicted. Agent Stites told you about how there was a
press release and news articles about Darrell Thomas's arrest
and indictment.
And he knew that, before this, he had received
money from Darrell Thomas, money that he absolutely told the
FBI about and money that was owed to him after Darrell had
cheated him out of his legitimate money.
And to be clear, Teldrin Foster said, "yes, I got
about a $30,000 check that I deposited into a Navy Federal
account." And that -- government went and got that account.
That is the only bank account that they ever even tried to
get.
Now, what did he not know on December 10 of 2020?
Well, he didn't know about his right to have a lawyer. I
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promise that.
And he did not know that Darrell and Gena had been
communicating behind his back. He didn't know about all
their messages. He didn't know what they had been doing.
And he didn't know about the emails from his
account. And again, you can tell when he was asked about
them. "I sent these emails?"
But what did the agents not know at the time of the
interview? They also did not know about Gena's
communications with Darrell. But even before that, even
before they had evidence of Gena's involvement, they were
super skeptical that it was Teldrin Foster. They were super
skeptical that he was the one who could have provided any
value to this scheme.
You heard the agents telling him, "What value do
you bring? Why would they need you?" And the answer -- no
one needed him. Right?
Who did they need? They needed Gena, the IRS
employee. Gena, the spreadsheet wizard; right? Gena, whose
metadata was on that entire stack of exhibits that I admitted
yesterday.
The sort of ironic part about the whole thing is
they had it absolutely right when they interviewed him. It
was Gena, the IRS employee, who knew about the stamps. It
was Gena, the IRS employee, who knew what an 1120 and a 941
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was.
Now, they just showed you a WhatsApp message that's
purportedly from Teldrin Foster saying, "I'm thinking they
need to be stamped." Right?
Who would know this other than the IRS employee?
Why would that be coming from Teldrin Foster?
So the sort of ironic thing about it is that they
presented evidence that the stamps aren't even necessary,
that the business owners would have never had access to the
documents that had the stamps on it.
But this whole idea, right, came from an IRS
employee because an IRS employee is the only one who would
have known this.
So they want you to think that the fact that Gena
Pyfrom-Foster was involved from the get-go was ludicrous, but
it wasn't ludicrous when they interviewed him in December
2020 and it's not ludicrous now.
Let me go back to the June 2020 deposit that's the
subject of Count 59 for a minute. When they interviewed
Teldrin Foster, they didn't know that Gena had communicated
with Darrell about it. Right? They didn't have those
WhatsApp messages at the time. And they didn't know that
Gena had sent that information to Darrell, or that Darrell
had sent that deposit slip back to her.
At the time of the statement and at the time
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Mr. Foster was indicted, no one knew about that. But even
after they obtained those messages, and even after they know
who was communicating about them, they haven't backtracked at
all. They haven't said, well, wait, we were wrong about
that, maybe we should reconsider.
So I just want you to think about their
unwillingness to change their mind and what that says about
this case when they are confronted with contradictory
evidence.
The government also wants you to look past all the
work that could have went into getting to the end of that
statement. They want you to ignore that the agents showed
him all the emails, and again he says "I sent these emails?"
And then later, when they showed him again, "Well,
I must have sent the emails because they came from my email."
Well, that doesn't mean that he admits that he was sending
them.
We knew that Bellator was Darrell's company and
there were talks about loans, but that doesn't mean that he
was admitting to the PPP fraud.
They want you to ignore that he was talking about
the forms or that they were talking to him about the forms
before he started describing them. And they said, this is
what these things are. And they want you to ignore so much
of what he actually said.
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Think about this. The saying, "Oh, you can Google
that; you can Google anything; just Google it," actually
sounds like someone who knows what's going on. Saying, "Oh,
you can Google that," or "someone who moves on money can get
me this," does it sound like someone who actually did it or
does it sound like someone who is speculating, who is trying
to cover for something?
And they want you to ignore the fact that he
provided details about this scheme that were completely
wrong. Right? There was no plan to sell these forms to
other business owners.
There was no plan to get a real warehouse or hire
employees to do real projects. There was none of that. But
that's what he told the government about.
So they want you to ignore what he said. They want
you to ignore that he said that he never knew that Darrell
had received any PPP funds, that he did not know that any of
them had been approved or submitted. And again, we had to
show you the rest of it.
They would have had you believe that Teldrin
Foster, when he was admitting to receiving money, that he was
receiving money for his participation in the PPP fraud. But
he said, the whole time, that he had been hustled by Darrell
Thomas and a guy named David out of his legitimate retirement
money and he was trying to get his money back.
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So go back and listen to the statements if you have
any questions about it. And don't forget to listen to the
clips that we were also able to add that complete the story
that the government is telling.
Speaking of money, let's talk about the flow of
money in this case. When the money came in, it went to
Bellator or Elite Executive. Right?
Teldrin Foster was not involved and had no
affiliation with these companies and no access to this money.
But more than that, the government wants you to think that
Teldrin Foster was a willing participant for every single
loan that was charged in this indictment.
And you heard the agents sort of wondering aloud,
"Did Darrell Thomas receive over $10 million? I don't think
so, I think it was less than that." But that's how much
money we're talking about in this case. Right?
And you think the person who conspired with him on
each and every single one of those loans did it for $34,000?
Even if you talked about the other much smaller payments, it
doesn't get to anything close to the amount of money that was
received in this case.
And the idea that Teldrin Foster was involved in
all of those loans and he got this much money, I think, is
more than sufficient to create reasonable doubt here.
And I want you to compare what we saw that money
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with what we see at Darrell Thomas's house. The jewelry, the
cars, the rapid! PayCards, this cash. Did you see anything
like that from Teldrin Foster? No. We have nothing like
that.
What is reasonable doubt? That's the standard that
the government has to meet. Right? They have to prove every
element of this beyond a reasonable doubt.
Now, reasonable doubt is a real doubt. It's based
on your reason and common sense after you have considered all
of the evidence in the case. But the government's proof has
to be so convincing that you would be willing to rely on it
for your most important decisions -- not the easy decisions,
the decisions that don't have consequences -- but the
important ones like what would you do for you kids. Would
you buy a house based on this level of confidence or this
level of evidence?
And this shows you, this chart shows you what proof
beyond a reasonable doubt means. This is a higher standard
than is required to take away your kids from your custody,
which only requires a level of clear and convincing evidence.
Proof beyond a reasonable doubt is the highest
level of proof we have in the legal system. If you're
thinking, well, he must be involved somehow, that's not proof
beyond a reasonable doubt. That is a hunch. If you are
thinking he must have done something, even if it's not
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exactly what the government has argued, that's not enough.
You cannot convict someone because they probably knew
something.
The judge will tell you that for the aiding and
abetting counts, you must find beyond a reasonable doubt that
Mr. Foster was a willful participant and not a knowing
spectator.
And as to the conspiracy counts, the judge will
tell you that simply being present or merely associating with
certain people and discussing common goals and interests
doesn't establish proof of a conspiracy.
A person who doesn't know about a conspiracy but
happens to act in a way that advances some purpose of it does
not automatically become a co-conspirator.
Now I know there is a lot of paper that has been
admitted in this case, and you are going to have it back in
the jury room with you. But this is not a question about who
submitted more paper, who admitted more exhibits or anything
like that.
It's not about whether we proved something more
than what the government proved. The government always has
the burden of proof in this case.
While we did admit evidence in the case, it was to
show you that there is significant doubt about their claims
against Mr. Foster.
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As Mr. Foster sits here, he is presumed innocent.
There is a cloak of innocence around him. And it's only if
the government establishes beyond a reasonable doubt every
single element of every single crime that he can be
convicted.
We don't have to do anything. I don't have to
present any case at all. But despite that, we have done our
best to show you that the government's story is a version of
the events and is incomplete. And I hope you have seen it.
The government acts as though we have the complete
universe of information, that there is no other information
out there that could be helpful. But I want you to think
about this.
Where would we be without Darrell's phone and his
laptop? Would the government still be arguing that it's
ludicrous that Gena -- or would the government be arguing
then that it was ludicrous to say that Gena Pyfrom-Foster had
access to the Yahoo email account?
We would be operating with limited information,
without critical facts in the case. But we still don't have
all of the critical information in this case.
We don't have Gena's phone. We don't have other
devices that were allegedly used. The agents saw other
devices in Gena's house and didn't get them. What would that
show us? What would that tell us?
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You saw that we tried to get information about what
the IP address for Gena Pyfrom-Foster's house was and we were
unable to get it. You saw that we tried to get the login
information or the IP information for the logins from
Teldrin_Foster@Yahoo.com and we couldn't get it. And we also
tried to do that for the iCloud account and we were unable to
do so when we came in later.
The government did not get a search warrant for any
of Gena's email addresses or Mr. Foster's email addresses.
And we are asking for you to demand more, that you should say
this is incomplete information and is not enough.
I'm almost done, but I wanted to ask you to be
careful or be wary of what happens after I sit down. I can't
get back up and talk to you more about the case. So whatever
they say, I want you to carefully consider whether there is
evidence to support it. Was there testimony, or is it just
an insinuation?
The last thing I want to talk to you about are the
false accusations that were made in this case. I know this
sounds outlandish. I know that. How can someone be framed
for a case like this?
But we aren't just presenting some theory for which
we don't have any evidence. There are things that
legitimately should cause concern. We have admitted a lot of
that. But in addition to everything that we have already
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talked about, we know that at least three separate people
tried to identify Teldrin Foster when they had no interaction
with him.
Now, there is this sort of joke format on Twitter
that says "If I had a nickel for every time something
happens, I would have three nickels, which isn't a lot, but
isn't it weird that it happened three times?"
And that's what I think about this. Isn't it weird
that it happened three times? That Ricky Dixon came in and
said it was Teldrin Foster, although he didn't actually say
Teldrin Foster; right? He called him Taldrid. So that's a
strong indication that he didn't actually know him and he was
being told to identify someone because he didn't even get his
name right.
But then we also have Charmaine Redding doing the
same thing, identifying Teldrin Foster. And then we have
Amanda Christian identifying someone with the last name of
Foster as being involved.
And Agent Stites told you there is no evidence that
any of that is true. There is no evidence that Teldrin
Foster communicated with Ricky Dixon. There is no evidence
that he communicated with Charmaine Redding. And there is no
evidence that he communicated with Amanda Christian.
So I just think that should give someone some pause
about this. But it's clear that it never did in this case.
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It never had any impact on the investigation. It never made
them think maybe there is more to this story.
So I'm asking you to do better than that. I'm
asking you to consider this fact: The use of Teldrin
Foster's devices, and to find that there is abundant
reasonable doubt here.
And when you consider the case carefully and when
you consider the rest of the story that we have told you, we
ask that you return the only verdict that's supported by the
evidence: Not guilty on all counts.
Thank you.
THE COURT: Mr. Marshall.
MR. MARSHALL: Thank you, Your Honor.
DEFENDANT JACKSON'S CLOSING ARGUMENT
MR. MARSHALL: I was thinking about something when
John Gaines was testifying yesterday. The government
prosecutor asked him a bunch of questions about Ms. Jackson's
qualifications. She's a professional. She's a successful
businesswoman, a senior project manager.
We know 20 years, maybe over decades at IBM,
working her way up. Very successful. We got all those,
those questions from -- Ms. Chaiken went over that. We went
over her background.
And I thought to myself why would someone like that
-- because I want to use my common sense about stuff. You
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heard that, too, from the prosecutor.
Why would a woman who has lived decades as a
successful woman, working her way up a career, all of a
sudden, on a whim, decide to participate in a fraudulent
PPP loan scheme with John Gaines or Darrell Thomas or André
Gaines?
I want you to think about that through my argument
and when you do deliberations.
There was no evidence presented during trial of any
personal bank accounts of Ms. Jackson. We know that she was
working. She had a successful job that she was working
separate from Management Resource Services.
Management Resource Services was a company that she
wanted to have grow. So when there is discussion about the
pandemic and everything shutting down, there is no testimony
about my client losing a job. She was working.
And use your own experiences to think, what's
somebody that has 20 to 30 years of experience as senior
project manager, what kind of money they probably make.
Right?
So we had no testimony about personal bank
statements or to show that maybe she was destitute. We saw
evidence about Management Resources with low balances. It
was a fledging business, it was a business in its infancy,
trying to be built. But no evidence about Ms. Jackson being
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desperate, destitute, she needed money, she wanted money to
get things like this.
So that's the thing I would ask you to think about
in the back of your head when you are looking at this. Why
would a woman like that just decide on a whim to do a
fraudulent loan for $339,000 and openly put it in her
business account? Why would she do that?
Do you want to know why she would do it? John
Gaines. The secret keeper.
We already know Mr. Gaines has admitted he
committed -- he cheated on his wife. He had children outside
the marriage, with another woman, never told his wife. Ended
up devastating her.
We also know, from the government's evidence and
their cross-examination of Mr. Gaines, of all the other fraud
activities that he had been involved in.
I think I asked back -- I want -- the date was back
to 2017 of doing fake documents for driver's licenses and
titles for cars. Fake documents on letterhead. I.D. fraud.
All of that. Emails communications referred to between John
Gaines and a Marie, this Marie that we never see. Over and
over again.
And I asked Mr. Gaines -- he had a difficult time
on the stand. I admit that. But I asked, you know, did you
ever tell Ms. Jackson about these activities? Did she know
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about these activities? No. She didn't know about all of
that.
And use your common sense. If you think a
successful businesswoman like that, with everything she had
earned and built up in her life, would stay with a man that
was involved in activities like that, it doesn't make sense.
It's not good common sense to think that.
John Gaines hid these activities from his wife all
through his life as part of his marriage. It was what he
was. He cheated on her, had kid outside the marriage, didn't
tell her about these activities. And he certainly didn't
tell her about a fraudulent PPP loan.
And we know John Gaines. He lies about things.
But I'll give him credit for one thing. Why did he come in
here and testify? And Ms. Chaiken -- I will give her credit,
she did what defense attorneys love to do when the government
brings these witnesses in.
Because what you saw yesterday was highly unusual.
You don't get codefendants in cases coming in to testify for
other codefendants. That's the rarity. You see codefendants
coming in as cooperating witnesses for the government to make
their case.
And when they get up on the stand, you see them
ripped apart by defense attorneys, cross-examined for
inconsistent statements, prior statements that they have had
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during interviews, during proffer meetings.
If they have prior convictions, they're impeached
with that. If they have been sentenced already, they get
impeached with that. They are cross-examined about the bias
that they have because what they are exchanging for their
testimony is a free ticket or a lesser or lower sentence.
All that you know about Mr. Gaines right now is
that he has pled guilty. There were no questions from me
about his sentencing and things of that nature. He pled
guilty.
But he got up there and testified. And if you may
remember, towards the end, I think at the very end of my
direct examination, I asked him, "Mr. Gaines, why are you
here? Why did it take you all this time, over three years,
to come here and say these words? Are you trying to fix
something? Are you trying to fix something for your wife?"
And you saw on stand, when I finished and before
Ms. Chaiken got up to ask questions, you saw a man, a big
man, a large man, break down, and he was crying.
And you could evaluate what that meant. I saw it
as real tears and a realization that he had put his wife in a
position that was threatening her life with his actions and
then she would have to suffer the consequences of that.
So let's go over a little bit, I want to go over a
little bit of what John Gaines testified to a little bit
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yesterday.
A lot of the time from the government, in the early
part, dealt with being cross-examined about his plea hearing
and his transcript. You heard that. And somehow that he was
being untruthful in responses.
But you may remember that the questions that I was
asking Mr. Gaines had to do with the funds that were coming
from the check and the wire transfer. What were they going
to be for? And they were going to be for this project in
Alabama, and they were going to be for payroll. And I asked
him several questions about would they have employees and all
of that.
So he was cross-examined about his testimony at his
plea hearing, and the government prosecutor made a big to-do
about a couple pages there, and they were read out, to make
it look like he was this big liar.
He wasn't lying about it. He was telling the
truth. At his plea hearing he admitted responsibility for
what he did.
He knew that the funds were not for payroll for
Gaines Reservation and Travel because that was all a sham.
That's all true, and he pled to that.
What he didn't say to you yesterday was that
Ms. Jackson knew about any of that.
There were some questions about André Gaines and
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about his medical history and so forth. Right? We heard
that. And, by the way, it's already been pointed out by
counsel for Mr. Foster, there are people in here that have
not been brought in to testify.
In this case, what have we heard? I'm going to put
up a chart just briefly for you, if I can. Here it is, right
here.
What connects Carla Jackson? Now, there are other
actors and parties in this overall case, but the person that
pretty much is like in direct concert, or the intermediary
with Carla Jackson and André Gaines, it's -- John Gaines is
in the center there.
He has constant dealings with Darrell Thomas. And
all those communications about creating documents and things
like that, and a fraudulent PPP loan application for Gaines
Reservation and Travel, that's Darrell Thomas, John Gaines,
other people that are involved.
And then we have Ms. Jackson, who is told and
represent -- he gets representations from Mr. Gaines about
what this money is coming for.
But let's go on to the other person, André Gaines.
The government never called André Gaines here. And this is
always a concern of mine in cases sometimes. Whenever there
is a back story that is a critical part of a case, I always
ask: Where are your witnesses for this?
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Why is it important that we hear from André Gaines
and we never did? And don't let the fact that there might be
medical issues -- we don't know that -- if it prevented him
from being here.
But André Gaines supposedly wrote the form, signed
the form for the PPP loan application. Supposedly had
interactions with Agent Stites. Supposedly had interactions
with John Gaines. Right? They're cousins. And had
interactions, maybe at some point, with Carla Jackson.
André Gaines could come in here and tell you what
he told Carla Jackson about this loan and what he knew. But
he's not here to testify.
Darrell Thomas could come in here if the government
wanted him to be here, and could get up on the stand and
testify to you about, hey, I had all these conversations with
John Gaines, I can tell you what I know about Carla Jackson.
And we still don't have any information about that.
I want to jump ahead a little bit about one thing.
Do you remember when the government started talking about
these PPP loan applications for Management Resource Services
and that Ms. Jackson had actually filled one out? And
somehow that knowledge that she did a PPP loan application
all of a sudden means that she knows about the fraudulent
nature about what John Gaines is doing, and Darrell Thomas.
I think I pointed out that Government's
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Exhibit 1228, that was that email that we put up on the
screen, it had some kind of vulgar language in there, and
it's telling -- John Gaines is telling Darrell Thomas, "now,
this application, this is my wife's shit. Don't fuck this
up."
Why would he say that? Why would he say that? And
I asked Mr. Gaines -- and you are allowed to take him -- you
can find him credible for whatever you want to find him
credible for. If you want to pick and choose which
statements you want to believe, you are allowed to do that.
The government wants you to disbelieve everything
he says and find him untrustworthy. Well, we know that's not
true. You get to pick and choose what he says is true or what
you believe is truthful.
But I asked him about Government's Exhibit 1228 in
that email, and I said was that because this was like a
legitimate PPP loan for your ex-wife?
Yes.
Well, why would that be? Why would Carla Jackson
need to do a real PPP loan application if she was in on the
gig and knew that, man, if I do fraudulent ones, I can get
$339,000 put into my account and I could make a story up
about projects in Alabama.
And I back up again. Why would a woman like Carla
Jackson ever get involved in a fraudulent loan activity?
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But remember that. Why would John Gaines have said
that? I'll tell you why. Because he knew that his wife
didn't know about the fraudulent nature of what he was doing.
Otherwise, there is no reason to set up some legitimate
PPP loan application.
And, by the way, that application was never
submitted, never submitted at all. If the government really
ever felt that bad about what happened with that and they
thought it was fraudulent activity on the part of
Ms. Jackson, they could have charged her. They didn't.
Let's go over some more things that he said. A
whole slew of documents that were put up. I have already
talked a little bit about this, the fake documents that he
did, that's all to impeach his credibility.
But you know what I think is pretty credible? He
did all those things. He was an incredible fake document
obtainer. He would get documents whenever he wanted to.
But none of that's linked to my client.
He made a statement during his interview -- or his
testimony yesterday about -- the prosecutor asked him about
André Gaines and whether Ms. Jackson knew him. And I
think -- what did he say? He vaguely knew.
I think this inference is from the government that
Carla Jackson -- and this goes back to that knock and talk
interview. That's what I refer to when agents or law
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enforcement just pop up on your front door.
And there's a point when she is asked about André
Gaines and if she knows him, and she says she knows of him.
And that is supposed to be some indicia that she is hiding
André Gaines and what she knows about him?
Well, we don't know the background, but John Gaines
said she vaguely knows André. We all know that there's some
family members that you just don't see very much. So that's
not fleshed out. I'm going to go into that a little bit when
we talk about the knock-and-talk interview.
Mr. Gaines got on the stand and testified that he
cheated on his wife. It was infidelity. Are we going to
disbelieve him for that? Do we think that's a true
statement? Yes, I think so. I think we do.
The trip to Alabama. The government wants you to
believe that this is all some made-up thing. Right? Now, we
showed you some photos, they weren't the greatest photos, but
there was one, at least, that showed a building there. And I
think you may remember that I went back up on the stand and
I, what I call refreshed his recollection and I showed him an
image from my laptop. It was something that we pulled up,
and it was a Google website. It wasn't Zillow.
And it was the property that he had gone out and
looked at. And he testified that there was a sign there, and
it said Call for more information and that's what he did. So
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we know that he did go out there.
There is testimony from John Gaines that he made a
trip out there and there was a project that they were
planning to build. Okay. We have got that in there.
Questions to John Gaines about his text messages
and whether he had everything. And we know that the
government has a ton of evidence, and I don't know if they
ever tried to obtain John Gaines's devices. We've already
talked about that.
None of my client's devices were looked at.
Computers were never obtained. Is that important in a case
like this? Yes, it's important in a case like this.
Wouldn't it be helpful to know if there was any
incriminating evidence in my client's computer at home?
Instead of this circumstantial evidence, these inferences and
suspicions and hunches about whether my client knew. Hard
evidence would be really something. Right?
And did you ever see, in any of the emails or the
WhatsApp messages or the text messages, anything, anything
from my client? Not copied on. Wouldn't you be copied on
one thing? Nothing.
Discussion -- he was asked questions about trying
to hide the source, trying to move the money to Management
Resource Services from Gaines Reservation and Travel because
Darrell Thomas let him know that the government is starting
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to clamp down on these PPP loans, we've got to move this
money.
There is no testimony that Ms. Jackson knew
anything about that, that that was the purpose for that.
Okay?
He was asked questions about the cashier's check.
We'll do that in a little bit.
There was a big hullabaloo about the $30,000. I
just don't see it. So we know money has come into this
account, Management Resource Services and there was some
money that was taken out for some auto loans. Okay. All
right.
It doesn't immediately go to payroll. But that
doesn't mean that's the type of thing where somebody is going
to go out and buy a Rolls Royce or have a supercar in their
garage. That's not that.
There were some expenses that were paid between two
people that had been in a relationship. They were
ex-spouses. And Mr. Gaines obviously requested this because
his name was handwritten on two of the checks that were
obtained.
So a big hullabaloo about the $30,000. It just
doesn't matter. It doesn't mean that Carla Jackson knows
about this fraudulent activity.
Let me go into -- if I could put up at least the
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basic government's evidence that we have. And I will take
this one down here.
So this is what I consider to be the primary
evidence that the government has. We have got this
knock-and-talk show-up meeting. Again, the low monthly
balances in Management Resource Services's bank account. The
two large deposits. That forms the basis of Counts 46 and
47. And I have already spoken a little bit about the $30,000
that were withdrawn, and then three checks.
Let's talk about a knock-and-talk.
Now,I have respect for Agent Stites. He has been
in the FBI for a long time. He's a professional. He knows
how to do his work. And you can tell he knows how to
testify, he is very calm, he has a very good demeanor on the
stand when he's answering responses.
What I don't necessarily have a high amount of
respect for is the nature of how they do these
knock-and-talks. And this is part of law enforcement's bag
of skills. It's in their wheelhouse. This is what they do.
I don't mean it's nefarious, but it's unfair.
So early in the morning -- and when I say "early,"
I'm talking about 9:38 or 9:40 in the morning. Ms. Jackson,
who is actually working, you can tell. She answers this way
in the recording, she has got a meeting. And if this is
during the pandemic, she has a phone call or maybe it's a
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Zoom meeting.
And two men show up, and they might as well be two
well-dressed salesmen coming to the house to want to sell
because who else shows up at your door. You get sales people
that do this; right?
So someone shows up, she's not prepared to talk to
them. And instead of having, like, two aggressive salesmen
wanting to sell people something -- and we know how we are
with that. You have a really good salesman, you sometimes
don't know what to say and you say the wrong thing and before
you know it, you have signed a contract or you have got goods
being delivered to your door.
But instead of salesmen, two of them showing up at
your door, what do you have? Two men standing there. They
are both armed because they are FBI agents, and they're also
coming with a federal subpoena for grand jury records.
So it's not a typical thing. And for anybody that
would have it happen to, it's probably shocking. It's
probably surprising.
Agent Stites could have, when he stopped that first
time, could have handed out his card, you know what, my name
is Agent Stites, this is Agent Cromer. I would like to give
you my card. I am very interested in talking to you. We're
investigating some PPP loan fraud we think you might be
involved in, and we will like to give you an opportunity --
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if you want, go ahead and call somebody, call an attorney if
you would like, and if they could give me a call at this
number I would really appreciate it and see if we can have a
meeting.
Wouldn't that be professional? Wouldn't that be
something to have that? Right?
So let's talk about some of Ms. Jackson's
responses. Right?
What did she respond to? What did she say?
When she was asked what the money was going to be
used for, she said, came from Gaines Reservation and Travel,
and it was going to be for payroll for a construction
project. That's what she told them.
And she mentioned they were going to hire some
subcontractors. They didn't have any employees yet, but she
was going to be responsible for handling that. Right? So
you know that and you've heard the recording several times.
Let's talk about how someone would maybe answer
these types of things, right, and why they would do this.
When someone comes to the door, all of a sudden,
remember, in the background we have this woman, a successful
businesswoman, she has been told certain things by John
Gaines about these loans. Right?
All of a sudden at her door, early in the morning,
are two FBI agents. No evidence that ever in her life she
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has ever faced this before.
And when you see that and he's asking questions
about this, you might being thinking, oh my God, did John do
something? Did he do something wrong? Did André do
something? And being concerned about it.
And a person like that can make, in that split
instant, decisions to make maybe limit what they say or try
not to say everything because they may think "am I going to
get him in trouble for something that I don't know about? Am
I going to get myself in trouble?"
And sometimes what Ms. Jackson did there was what
many people do in these situations. And as defense
attorneys, we know it.
I tell my kids -- I don't know if all of you have
children or many of you do. I have got grown kids, but when
they were growing up, I would tell them this and you probably
think, oh, well, this is a defense attorney saying this
stuff. But I meant this.
I would say, you know, if you ever are stopped,
always be polite and always be respectful to the police
officer you are talking to, or if it's a detective or
anything like that. Always do that. That's important.
But if anybody is ever asking you questions about
something serious, right, and you didn't do anything at all,
do not talk to the officer without talking to an attorney.
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And what I would is say is "Talk to your dad. Call
your dad. Tell them you need to talk to an attorney, and
call me." Right?
Now, why would I say that to a child of mine if
they were facing a serious charge, to not say anything,
knowing that they are innocent?
Because I know that you can make mistakes in how
you respond in what you say to people. And if I had a child
that was uncounseled and didn't have an attorney and was
facing a serious charge -- maybe it's robbery, mistaken
identity -- and my child decided to sit down and start giving
answers and responses about where they were and this and
that, and maybe they started to hide, like, "oh, I don't
know. I was with my friend," that recording could be used in
a trial, just like this, to make it look like my child did
what they are accusing them of.
So I always advised them to do that because people
don't respond well in those situations.
So there is a jury instruction that you will get
from the judge about how to treat statements of defendants in
situations like this. And you are to treat them with
caution.
That's the biggest thing -- if the government
didn't have this interview evidence, that's their biggest
piece of evidence is how Ms. Jackson responded to the
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questions by Agent Stites. When he knew that he wasn't going
to even mention anything, he never mentioned anything about
an attorney until the 12-minute mark of a 13-minute
recording. And I asked him that. That word "attorney" did
not even come out.
And I wouldn't want my child facing that, and I
mean a child that could be 21, 25. Face that fear of an FBI
agent, two of them, at your door.
Don't give the full credit or any credit to the
nature of these responses that Ms. Jackson gave. Look at the
context of how this was given and how it was conducted.
And so for all the professionalism that Agent
Stites has, this is not a professional move. It's a quick
move to try to get easy evidence from people that are not
trained and they're not professional and don't deal -- have
never dealt with FBI agents or detectives before.
I'm going to go over a couple of things in the
evidence here.
We talked about the PPP loans applications from
Management Resource Services. I've already addressed that.
That's been brought in again, overlaying this entire case
against my client.
It's not direct evidence. It's just suspicion on
suspicion, and it's inferences, and she must have known.
That's all what this is about.
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Let's talk about the Roadrunner records. Why is
that brought in? It's more suspicion about Ms. Jackson. She
is a cofounder, a cosigner of that company with Mr. Gaines.
We got testimony about that, I think, from Agent Stites about
when that was formed. And we showed the bank statement that
was up there.
And what was up there? A bunch of transactions.
There was a $71,000, an odd amount of deposit that came in.
Mr. Gaines said that he thought he remembered what that was
for. But there is no testimony that -- or evidence that my
client knew that that came from anybody like Darrell Thomas
for anything specific. It's not in the record.
And you may say, well, someone -- they're an
organizer, they are a co-owner of a company, they must know
about everything. You saw all the other transactions. This
was John Gaines, that was his company he was running.
All the transactions on there were from him except
a GEICO Insurance payment that came out of that company.
So no evidence that ties that. That's thrown in to
make you think that somehow that's related. Well,
Ms. Jackson isn't charged with anything related to
Roadrunner.
That same type of technique is used by the
government when they brought in a document -- actually, this
came into evidence another way, when Roadrunner was on a list
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of companies. Right? You saw that? Again there is nothing
tying that to Ms. Jackson.
John Gaines up there -- remember the chart I put
up? Everything comes through John Gaines, and it's Darrell
Thomas and other individuals in this case.
It's just suspicion. She's not charged in Counts
46 or 47 with anything related to Roadrunner. So remember
that.
I talked about the Alabama project. There is this
hullabaloo again, this question about this proposal. She
mentions a proposal. And then there are questions from the
government prosecutor to Agent Stites in this grand jury
subpoena. This is a minor, but also a big issue.
I asked Agent Stites about the subpoena, and he
recognized for the first time on the stand that the subpoena
return what he got back from Ms. Jackson was missing two
pages. That means two pages of document requests to give you
instructions about what you are supposed to get back. And we
have no idea what was even on that.
But that implies that she got an incomplete
subpoena because he never followed up and found out what that
was.
So I say this in reference to the proposal because
somehow they put like it was a burden or an obligation of
Ms. Jackson to come back to Agent Stites, weeks later or
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months later, and somehow come up with documents for a
proposal, or that she was supposed to provide that as part of
these documents for the subpoena. No.
We talked about the computers. We already have
evidence in the record that John Gaines lived at Carla
Jackson's house. He accessed bank accounts from that house.
You saw the Comcast record that showed that the IP address
tied to that residence is Carla Jackson.
But Mr. Gaines had computers there. He had a
desktop there. He had a laptop. We know he accessed that
stuff. So that does not mean that Carla Jackson was involved
in these loans or doing activities with him.
Let me show you the jury instruction on reasonable
doubt again.
We'll go back to that. Go back to the missing
evidence slide, please.
These are just some of things that I wrote down,
and this isn't even an exhaustive list.
No testimony from key witnesses of Gaines
Reservation and Travel, André Gaines. We already talked
about that. No back story. None of that is filled in for
us.
No testimony from key witness Darrell Thomas.
No emails, no WhatsApp messages, no text messages,
no phone calls. No selected digital devices to analyze.
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None of that was obtained.
No search warrants. No court orders. Nothing.
No direct knowledge of Ms. Jackson having knowledge
of the illegality of these funds coming from André Gaines and
Gaines Reservation and Travel.
No direct evidence of Ms. Jackson having knowledge
that the purpose of the two large deposits was to conceal the
funds, the money coming into her account.
No follow-up with Ms. Jackson, or her attorney,
regarding a construction project. She is not obligated, once
she's arrested and charged with things, to come out and say,
hey, you know what? I'm going to bring you documents on my
construction project. The incomplete subpoena that we have
there.
Let's go to the jury instruction on reasonable
doubt. And Mr. Foster's counsel already put this up.
This is -- all of the jury instructions are
important, and you need to pay attention, please, to all of
them when the Court reads through them.
This is the most important to me. And it's the
third one and this was pointed out by Ms. Webster. Proof
beyond a reasonable doubt is proof so convincing that you
would be willing to rely and act on it without hesitation,
without hesitation, in the most important of your own
affairs.
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Can you say that about the evidence that the
government has put forth against Ms. Jackson? Is this the
level of proof that, without hesitation, you would find
someone close to you? Yeah, that without hesitation, this is
proof beyond a reasonable doubt what I have heard.
And back on top, I keep asking of you to think of
this for me. Why would a woman like this, at this stage in
her life, with no proof that she's destitute or anything, get
involved in a fraudulent PPP loan application out of the
blue?
She didn't. Because John Gaines is a liar and he
used his wife to move funds.
I'm going to read you just a couple more.
Put the money laundering slide up, please.
Now, there are additional definitions that you will
get from the judge about what these elements of this offense
mean. But the most important prongs here -- and you have to
realize one thing, each of these elements have to be proven
by the government beyond a reasonable doubt.
So that reasonable doubt slide that I just showed
you about proof so convincing, each of these have to be
satisfied with that level of reasonable doubt. So number two
and four are the critical ones when you go back there.
She had to know -- and I'm going to go into that
deliberate ignorance instruction in just a second.
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So she had to know that the money and the funds
were the proceeds of an unlawful activity. There is no
direct evidence of that. This is just suspicion and hunches
and implications about her activities.
Number four, that she knew the transaction was
designed, in whole or in part, to conceal or disguise. This
is basically that she knew this was being moved over to her
bank account to hide it.
We know John Gaines was talking about, like -- it's
referred to as a clawback. That everything is getting shut
down and they're going to pull this money out and stuff.
Right? But there is no proof that Ms. Jackson knew that.
Let's go to show you something else.
We can take that down. That's fine.
Let's go to the deliberate ignorance instruction
that the government pointed out.
This is the instruction that you use when you don't
have enough proof of actual knowledge. This is like
someone -- they knew of something so much, but they stuck
their head in the sand because they didn't want anyone to
know that they knew about it. That's my summary of it. But
you'll read the jury instruction for yourself and see what it
is.
We wouldn't need this here if the government
thought it had actual knowledge evidence about my client
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knowing about this illegal nature of these funds. So read
through this. Look at this. You may find -- let's go
through here.
If a defendant's knowledge of a fact is an
essential part of a crime, it's enough that the defendant was
aware of a high probability that the fact existed, unless the
defendant actually believed the fact did not exist.
So they give an example in here about someone being
in possession of a controlled substance. And that's a good
example to use, so look at that when you read the
instruction.
So they give an example of -- let's say a defendant
possesses a package and they believe it contains a controlled
substance, but they deliberately avoid learning that it
contains the controlled substance so he or she can deny
knowledge of the package's contents. That's the ideal.
That's a good example of what deliberate ignorance is.
And this is for proof of knowledge when you don't
have sufficient evidence. So in this case, in that
example -- so you may find that a defendant knew about the
possession of a controlled substance if you determine beyond
a reasonable doubt -- again, the highest standard, the most
important jury instruction -- that the defendant actually
knew about the controlled substance or had every reason to
know but deliberately closed his or her eyes.
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There is no evidence of that. Again, it's
assumption and hunches that she was ignoring things. I guess
the government's theory would be that she is not on any of
these thousands of email communications and all of this
because she was so smart, she made sure she was never on any
email. No recording. That's not what this is.
Again, why would a woman at this stage and at this
level of success in her life do this? It doesn't make sense.
Ms. Jackson is charged with two counts. I'm going
to put those up on the screen again. I believe you'll get a
copy of the indictment when you get back.
She is charged -- actually, she is charged in
Counts 46 and 47, both money laundering counts. And they
have the two separate dates for the two transactions you know
about. And she is charged also with John Gaines.
Let me tell you a couple things about how this is
laid out. This is not a conspiracy count. You have heard
the government talk about jury instructions for a conspiracy.
My client is not charged with a conspiracy. She's is not
charged with a conspiracy with John Gaines.
This is what they refer to as a substantive count
where she is charged with this specific offense, and then
they'll lay out those elements of that specific offense for
money laundering. Okay?
So those are the two counts that we have here.
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Those are the two transactions. I ask you to think about
that, all that primary evidence, and we'll go back to that
primary evidence, the government's evidence again.
The knock-and-talk show-up meeting. I already
talked about that. You get to totally weigh what the weight
is and the worth of that interview.
The low balances. That doesn't mean anything. All
kind of businesses have low monthly balances. Two large
deposits, and then the withdrawals. A lot was made to do of
those.
And then I believe the government will say that
John Gaines was up here and provided additional evidence
confirming what Ms. Jackson said.
But let me point out one thing: Mr. Gaines was
brought here because he wanted to be here. He went through
everything that he went through with the government
prosecutor yesterday not because he was going to enjoy it.
He wanted to be here to try to fix something that he messed
up for for his ex-wife and he felt responsible for that.
That's why he was here.
So I want to ask you, when you go back to the jury
room, I want you to think about this, please. Think about
the reasonable doubt jury instruction and the level of proof
that you need. It's the highest proof level that we require.
Think about the testimony of John Gaines. And
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think of this, also: I'm not sure if the government wants
you to totally disbelieve everything John Gaines said
yesterday or if they want you to believe some of it. But let
me give you a twist on this.
Let's say you don't want to believe anything he
says. All right. Then take everything he said yesterday in
the testimony and shut it out of your mind. Take it away. I
don't find anything he said credible, so I'm not going to
believe it at all. And let's see what you are left with.
The interview and the other evidence that I just showed you.
So if the government doesn't want you to believe
John Gaines at all, don't. And let's look at the other
evidence that's there. If the government is saying that they
want you to believe some but not all, well, I'm going to tell
you, you need to believe some stuff, too, that he said, that
says that his wife, his ex-wife didn't know about this stuff.
You get to determine the credibility of all these
witnesses and what you think is important.
Suspicion upon suspicion upon suspicion is not
proof beyond a reasonable doubt.
I would ask you to, please, find Ms. Jackson not
guilty on Counts 46 and 47 because the government has not met
its burden of proof as to the elements of the offense.
Thank you.
THE COURT: Ms. Chaiken, how long do you think you
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will need?
MS. CHAIKEN: Probably about 20 minutes, Your
Honor.
THE COURT: We have been going about an hour and a
half, so I think what I would like to do is take a short
comfort break before lunch, so we can get all the closings in
before the lunch break.
So let's take a five-minute -- five-minute break.
So five minutes from now, Officer, bring the jury
back in.
And five minutes from now, Counsel, I'm going to
walk back up here.
Okay.
Thank you.
(Jury withdrew from the courtroom at 12:31 p.m.)
(There was a recess at 12:31 p.m., and proceedings
continued as follows at 12:36 p.m.)
THE COURT: Bring in the jury, please.
Counsel, I understand there were two minor changes
in the jury instruction.
On page 10, 48 was changed to 42. And on page 20,
the second half of that title was taken out.
Is that correct?
MS. CHAIKEN: Yes, Your Honor.
MS. WEBSTER: Yes, Your Honor.
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THE COURT: Mr. Marshall?
MR. MARSHALL: Yes, Judge. Correct.
THE COURT: All right. Thank you.
(Jury enters the courtroom at 12:37 p.m.)
THE COURT: You all can be seated.
Ms. Chaiken, go ahead.
MS. CHAIKEN: Thank you, Your Honor.
REBUTTAL CLOSING ARGUMENT
MS. CHAIKEN: Both of the defense attorneys
suggested to you that there are witnesses you didn't hear
from that we could have called, and they wanted you to hear
from them but we didn't call them.
And I want to be very clear. We have the burden of
proof in this case. We embrace that burden of proof. But
the defense has subpoena power, too. You saw the defense use
that subpoena power to bring people to this witness stand.
And if the defense wanted you to hear from Darrell
Thomas, from André Gaines, from Gena Pyfrom-Foster, they were
equally able to get them on that witness stand.
We did not rely on the word of fraudsters in
proving our case to you. We showed you the actual evidence
so that you can see it with your own eyes and hear it with
your own eyes and evaluate it, instead of needing to decide
whether to believe someone who was involved in a massive
fraud.
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Now, I want to start with some of the points that
Ms. Webster made as to Mr. Foster.
She talked about Jennifer Murray, their witness,
Mr. Foster's girlfriend, whose testimony was that twice a
year Mr. Foster's wife, Gena Pyfrom-Foster, calls his
mistress and gives her the password to Teldrin Foster's
phone.
And then Ms. Murray sends screenshots of that to
Teldrin Foster so he knows that people have the passcode to
his phone, and then that just keeps happening twice a year.
He knows people have access to his phone. That doesn't make
any sense. But that's the defense's evidence that Gena
Pyfrom-Foster had access to Teldrin Foster's phone.
Here is the thing, though. In order to log into
somebody's phone, you need to have their phone. And Jennifer
Murray herself told you Mr. Foster had his phone with him all
the time unless he left it in the car. And of course he did,
because who doesn't? We all carry our cellphones with us all
day long. That's how people get in touch with you.
The idea that, for an entire summer, he left his
phone at his wife's house while he was running around with
his girlfriend so that she could commit PPP fraud behind his
back is preposterous.
I also want to talk about the rapid! PayCards.
That's the rapid! PayCard that Teldrin Foster himself said he
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had and explained what the purpose of it was for in the
interview. He said the whole point was they were going to
make it look like it was payroll, going to make it look real.
How did he know that? If he didn't have a
rapid! PayCard or knew nothing about it, how did he know to
even say what a rapid! PayCard was? And you saw that he said
it was for him to collect his percentage.
And the defense wants you to believe that there was
someone with a tablet or a watch that was somehow tied to his
T-Mobile phone number that was running around town using his
rapid! PayCard and making phone calls on his phone.
Well, ladies and gentlemen, when you go back to the
jury room, please, please take a look at Government's
Exhibit 2956. That's the T-Mobile records of those phone
calls that were analyzed by Agent Berni. And when you look
at them, you will see that every single call on those phone
records is made from the same IMEI. That's the mobile
equipment identification number. It's the number for the
device.
There is not a tablet and a phone and a watch that
are all making calls while someone runs around town using
this card. It's Teldrin Foster's phone. And the defense
wants you to think that every time that rapid! PayCard is
used, it just happens to be that somebody with a watch is
within three to seven miles of where the transaction is done,
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but the transaction just happens to be hitting on the phone
that's immediately next to where the transaction is being
done. It doesn't make any sense.
Now, the defense talked a lot about things they
told you about that we didn't. And that's because those
things don't matter. They're not defenses.
We didn't tell you the specific names of the people
who were the business owners or what their specific roles
were because those people are not on trial. Those people
have been charged, and that is a question for another day.
The fact that Teldrin Foster is charged in the same
conspiracy with them does not mean that we need to prove that
he directly talked to them, communicated with them, or even
knew they existed. So we didn't tell you about that because
that is not something that matters to your decision about
what Teldrin Foster's role was.
Now, the defense also said that they're the ones
that needed to tell you that the laptop that was seized was
Darrell Thomas's laptop.
They did not need to tell you that. We told you
that. Agent Stites sat on that stand and told you that we
seized Darrell Thomas's laptop. We seized it from his home.
He told you that the Yahoo account was on it.
We told you in our case that we determined Gena
Pyfrom-Foster was using that Yahoo account. There was no
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attempt to hide that. That's not something you learned from
the defense for the first time. And Teldrin Foster told you
that. He knew that that Yahoo account was on the computer.
And they say, well, he said it was on the desktop.
You heard on the interview he uses desktop and laptop
interchangeably. He told Agent Stites that they worked on
the desktop together in the car, and then Agent Stites said
"On a desktop in the car?" And then he said, "No, no, the
laptop."
The point is he knew that his Yahoo account was on
Darrell Thomas's computer.
And Ms. Webster referenced that LNK file that was
downloaded from the Yahoo account. But I showed, when I
cross-examined Mr. Persinger, that that bank statement that
was supposedly accessed by whoever was using the Yahoo
account on that computer, that very same day, it was sent via
WhatsApp to Teldrin Foster.
What more evidence do you need that it was them
working together, using that account on Darrell Thomas's
computer and then sending the documents to each other so that
they would have copies of them.
Now Ms. Webster also addressed this pattern, the
pattern of texts, of WhatsApps, and emails that we showed
you. And her proof that that pattern is wrong was that there
were two instances cherrypicked from all of the hundreds and
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thousands of WhatsApp messages that you had, and the hundreds
of emails, two instances where there was an iCloud email that
came in to Darrell Thomas's account right around the same
time that Gena Pyfrom-Foster said, "I sent you documents."
She didn't say which ones. She didn't identify that those
were the ones she was sending. And we showed you that there
were other documents that the Yahoo account sent right around
that time.
Of course, there were emails coming in from the
iCloud account because you saw how many businesses were
involved in this. You saw that there were constantly emails
going back and forth. And if you go and you look at Teldrin
Foster's communications with Darrell Thomas, you will see
that Darrell Thomas and Teldrin Foster were on the phone at
the exact same time that Gena Pyfrom-Foster sent that
message.
You will see that there was every reason for those
iCloud messages to be coming in from Teldrin Foster at that
time.
Now Ms. Webster mentioned the evidence of Gena
Pyfrom-Foster emailing Darrell Thomas in April of 2020.
Again, that's not something we deny. We told you she was
involved in the beginning. She created the template.
You can see in that email that she sent to Darrell
Thomas that, initially, it seems like she thinks maybe she is
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helping him with something legitimate. Because she doesn't
know him, she doesn't know that he is trying to commit fraud.
You saw how she writes. You saw how different it
is from how Teldrin Foster writes. Full sentences, proper
punctuation. You can compare that from what you have seen
from Teldrin Foster to see that they were not controlling the
same accounts. They were not -- that she was not controlling
his accounts.
You also heard from Ms. Webster that Darrell Thomas
sent Ms. Pyfrom-Foster a PPP application for Bellator Phront
Group. First of all, you saw where he got that PPP
application. He got it from Teldrin Foster.
But second of all, again, nobody is denying that
Gena Pyfrom-Foster is involved. We all agree. We all agree
on that. That's not what this trial is about. This trial is
about Teldrin Foster.
Ms. Webster also mentioned that list of completed
consulting contracts that Gena Pyfrom-Foster sent to Darrell
Thomas. And ask yourself, if she had access to Teldrin
Foster's WhatsApp account and she was using it, and she and
Darrell Thomas had a conspiracy to frame Teldrin Foster, why
would she send that list from her own account?
Why would she make it clear that anybody looking at
those messages, that she worked on those loans? Because she
did not have access to Teldrin Foster's account.
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And Ms. Webster told you, when you are listening to
the statement, to think about the fact that Teldrin Foster
didn't know what Gena Pyfrom-Foster and Darrell Thomas had
been doing.
How did he answer all of those questions in the
interview? How did he even know that templates were created,
that documents were exchanged, that there were plans to hire
fake employees to make it look real, that there was a
rapid! PayCard account, that loans had been submitted and
approved?
How did he know any of that? How did he know what
to say if he didn't know what had been happening? It doesn't
make sense.
Going back to Gena Pyfrom-Foster, Ms. Webster
mentioned the entire stack of exhibits with the metadata that
Gena Pyfrom-Foster's name is on. I would ask you to go back
and look at those in the jury room, too, because what you
will see, and Mr. Kaushal showed you a little bit of it
yesterday, is that every single one of those hundred-plus
documents was created on the exact same day at the exact same
time.
That's what happens when you create a template.
Every person who saves it after that, it's going to list the
same metadata, that Gena Pyfrom was the author.
You're also going to see that there's none of those
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screenshots where anything happened in May because Gena
Pyfrom-Foster created the template in April. And then she
stayed out of it until Teldrin Foster kept messing it up
because he didn't know how to change the numbers. He
cookie-cuttered it, and Darrell Thomas needed better. So he
started working with Gena Pyfrom-Foster so she could make it
better in June.
Now Ms. Webster said, well, you saw the text that
said "I'm thinking these need to be stamped." And she
suggested to you that must have been Gena Pyfrom-Foster
because she worked for the IRS. But you know from the
testimony in the case it's actually the exact opposite.
Because you heard from Sal Hazel, from the IRS,
that documents don't get sent back to businesses after they
are stamped. The stamp actually makes it look fraudulent
because when you submit a document to the IRS, the IRS stamps
it and you never get it back.
You know who would know that? An IRS employee.
You know who wouldn't? Someone who is Googling documents and
trying to figure out how to make an IRS document look
legitimate.
You heard again about Darrell Thomas getting all
the money. Again, that's not relevant. You saw that this is
exactly why Teldrin Foster and Darrell Thomas ultimately had
a falling out. Because Teldrin said, "You are saying fuck my
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percentage?" And that's it. They never spoke again after
that.
You also heard that millions of dollars got seized
from those accounts, and you will see that in the bank
records as well. So Darrell Thomas didn't have all the money
that he thought he was going to have. Maybe he was going to
give Teldrin Foster more. But certainly, after it got
seized, yep, fuck Teldrin Foster's percentage.
That doesn't mean Teldrin Foster didn't participate
in the fraud. It just means that he was pissed he didn't get
out of it what he wanted to.
Ms. Webster showed you a chart. It had all kinds
of different standards about taking kids and arresting
people. You are not going to see any of that in the
instructions. None of it.
What the judge is going to tell you is that a
reasonable doubt is a real doubt based on your reason and
common sense after you have considered all the evidence in
the case. That's the standard you should apply.
You should not let the defense move the goalposts
by trying to impose other standards here.
Now the defense also started asking about evidence
they wish that there had been. IP addresses, why didn't we
subpoena IP addresses from Gena Pyfrom-Foster's house?
What would that have told us? You saw that Teldrin
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Foster, on his driver's licenses, has listed that address as
his residential address since 2015, and that that's still his
address on his current driver's license now.
So finding out that an IP address at Gena's house
was used to log into an account, what does that tell you?
That doesn't help you figure out if it was Gena Pyfrom-Foster
or if it was Teldrin Foster. You have to look to other
evidence.
And finally, you heard about the false accusations
that were made against Teldrin Foster. And you heard that
Agent Stites did not rely on any of those. But what you also
heard is that all three of those people told different
stories.
You heard that Amanda Christian said someone named
Foster from CDC Finance -- that's one of the lenders --
called her. You heard that Ricky Dixon said that he didn't
communicate with Darrell Thomas.
If this was a frame job, wouldn't everyone's
stories be the same?
Wouldn't Ricky Dixon know that he was supposed to
say Teldrin Foster instead of Taldrid?
Wouldn't Amanda Christian say that Foster was
someone who worked on the loan, not some random person, whose
name she doesn't know, at a bank?
What you heard is that by the time all of these
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people talked to law enforcement, they knew they were under
investigation. Darrell Thomas had already been arrested and
indicted, and everyone was trying to save themselves. That
does not tell you anything about whether Teldrin Foster was
involved in this PPP loan fraud.
Moving on to Carla Jackson. You heard multiple
times that John Gaines was this manipulative secret-keeper.
And he was. But Ms. Jackson knew that before any of this
happened. They got divorced in 2019. She knew she couldn't
trust him. She knew he lied. He had multiple children,
during their 30-year relationship, with other people.
There was no trust there. There was no reason for
her to believe that what he was doing was legitimate because
she knew that he was a manipulative liar.
But the one thing that he didn't hide from her is
that he was doing PPP loans. He didn't hide that from her.
You saw that because you saw the PPP loan application that he
had her do. He didn't hide from her that that's what he was
working on.
And there were arguments that were made by
Mr. Marshall about that being a legitimate PPP loan. But go
back and look at that application, Government's Exhibit 1228A
and 1228B.
It was blank for the amount of payroll and the
amount of employees. And you heard from Mr. Gaines, and you
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saw in the evidence, and you heard from Ms. Jackson herself
in her interview that Management Resource Services did not
have any employees.
And if you go down to the certifications page, you
will see that she initialed next to the certification that
said this business was in operation on February 15 of 2020
and had employees for whom it paid payroll. That was
initialed.
There were also initials next to the certification
that said all of the documents and the information in this
application is true and all of the supporting documents is
true. But there was no information and there was no
documents. There was no real information provided.
And why would Carla Jackson, this sophisticated
businesswoman, go to John Gaines, her manipulative, lying
ex-husband, to help her get a legitimate PPP loan that she
thought she was entitled to for her business? It doesn't add
up.
As far as Mr. Gaines's testimony yesterday, I'm not
sure if Mr. Marshall and I listened to the same testimony.
Mr. Gaines told you yesterday that the money
actually was for payroll. He said that's what it was for.
Gaines Reservation and Travel was doing a project that had
payroll, even though he pleaded guilty two weeks ago to money
laundering for making it look like it was payroll when it
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actually wasn't.
And pinning him down on his testimony was kind of
like trying to pin jello to the wall.
When Mr. Marshall first asked him about the
project, he said they purchased a property in Alabama. Then
later it turned into, "oh, we were going to purchase it. We
went there a few times."
He couldn't remember who he went there with, didn't
have the address, they had no plans. Sometimes he said he
talked to Ms. Jackson about it. Sometimes he said they
vaguely talked about it. Sometimes he said they didn't talk
about it at all.
It was completely unclear when the project was
going to happen, what the project was going to be. Why
Gaines Reservation and Travel, which he said was a
transportation business, was renovating an apartment building
in Montgomery, Alabama. None of it added up.
Now Mr. Marshall mentioned Ms. Jackson's interview
where she had said that she got the payments from André
Gaines and he said that was some sort of indicia that she was
trying to hide that she didn't really know André Gaines, or
something about André Gaines.
That's not what it's an indicia of. It's an
indicia of the fact that she was trying to hide the fact that
she got the money from John Gaines.
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When someone shows up at your door and asks you
questions, the easiest answer to give is the truth. And the
truth would have been that John Gaines gave her the money.
The only reason why she didn't say that is because she knew
she wasn't supposed to have that money. She knew she needed
to give an explanation that would perpetuate the concealment
of that money.
And you heard -- there were some allegations that
this interview was unprofessional and unfair. You have now
been in this courtroom with Agent Stites for over a week.
You have heard his interviews. You have seen him testify.
And you can hear on the interview that was talking
to Ms. Jackson from behind a screen door. He wasn't
aggressive. He wasn't yelling. He didn't tell her she was
required to talk to him. He didn't try to intimidate her.
He gave her time when she said she needed to go back to talk
to her boss.
When she took pauses, he just sat there and waited.
And when she said she wanted an attorney, he left because
that's what he is required to do when someone invokes and
says they want an attorney.
The idea that the reason why she lied is because
she was intimidated or she was taken off guard and that you
should just disregard everything she said because she's
someone who decided to try to lie to cover up for herself or
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for John Gaines when she realized the FBI was at the door,
that's exactly what shows you that she knew exactly what she
was doing. She knew there was something to cover up for
because if she didn't know that, there would have been no
reason for her to just say "My ex-husband sent me this
money."
Mr. Marshall tried to characterize the case against
Carla Jackson as suspicion. But again, when you think about
the type of evidence in this case, people don't email about
committing fraud together. And we don't have a brain scanner
that tells us what someone knows.
What you need to do to figure out what she knew is
to look at her circumstances, to look at her actions, to look
at her words. And all of those circumstances here show that
she knew that this money was PPP money and that it was being
hidden in her account.
Ms. Jackson is not here on trial because John
Gaines asked her to commit money laundering. She is on trial
because she said yes, and because she did it.
We ask you to return a guilty verdict against both
Teldrin Foster and Carla Jackson.
Thank you.
THE COURT: All right. Thank you, Ms. Chaiken,
Ms. Webster, and Mr. Marshall.
Ladies and gentlemen of the jury, we are now going
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to take a lunch break. Is 45 minutes enough? Okay.
If everybody can be back at 1:45. At that time I
will give you your instructions. And after your
instructions, you will be able to start deliberations.
But importantly, you are not to start deliberations
yet. You are not to discuss this case with anyone yet,
including yourselves.
I hope you enjoy your lunch break.
Thank you for being here.
(Jury withdrew from the courtroom at 1:00 p.m.)
(There was a lunch recess at 1:00 p.m.)
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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 Wednesday, February 14,
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 14th day of February, 2024.
___________________________
/s/ Judith M. Wolff, RPR, CRR
Official Court Reporter
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LAW CLERK: [1] 14/6
MR. KAUSHAL: [3] 4/24 8/1 13/22
MR. MARSHALL: [5] 14/9 14/13 75/13
75/15 105/2
MR. MOORE: [1] 7/8
MS. CHAIKEN: [17] 14/16 15/5 15/7
15/9 19/15 19/19 19/22 25/1 30/2
38/12 43/15 44/9 48/7 104/2 104/24
105/7 105/9
MS. DURRETT: [4] 11/20 11/23 13/4
13/10
MS. WEBSTER: [5] 14/18 49/3 49/13
49/15 104/25
THE COURT: [25] 2/4 7/3 8/7 11/22
13/2 13/5 13/11 14/1 14/7 14/11
14/14 14/17 14/22 14/25 48/25 49/4
49/11 75/12 103/25 104/4 104/18
105/1 105/3 105/5 120/23
THE JURORS: [2] 14/24 15/8
$
$10 [1] 69/14
$10,560 [1] 50/21
$11 [1] 15/15
$155,252.50 [1] 46/21
$3,000 [1] 51/23
$30,000 [4] 64/20 87/8 87/22 88/8
$300,000 [1] 42/21
$335,000 [2] 43/16 45/18
$339,000 [2] 77/6 83/22
$34,000 [1] 69/18
$7,000 [1] 51/23
$700,000 [1] 15/14
$71,000 [1] 94/8
/
/s [1] 122/23
1
10 [3] 51/3 64/24 104/21
10-minuter [1] 49/5
10:00 [1] 13/17
10:01 [1] 14/21
10:23 [1] 59/4
10:29 [1] 59/3
10:42 [1] 59/15
10:53 [2] 49/7 49/8
11 [1] 50/21
1120 [2] 62/23 65/25
11:00 [1] 59/18
11:07 [2] 49/9 49/10
12-minute [1] 93/3
1228 [2] 83/1 83/15
1228A [1] 116/22
1228B [1] 116/23
12:31 [2] 104/15 104/16
12:36 [1] 104/17
12:37 [1] 105/4
13-minute [1] 93/3
1317 [1] 1/24
14 [6] 1/12 15/12 15/19 53/18 63/10
122/10
14th [1] 122/20
15 [2] 51/2 117/6
18 [3] 46/23 47/14 47/17
1914 [1] 1/23
198 [1] 55/7
1986 [1] 3/6
1:00 [2] 121/10 121/12
1:20-CR-00296-JPB-5-20 [2] 1/5
122/12
1:45 [1] 121/2
2
20 [6] 1/5 75/20 76/18 104/2 104/21
122/12
2015 [1] 115/2
2017 [2] 11/12 77/18
2019 [6] 15/21 15/25 23/20 23/21
59/3 116/9
2020 [27] 21/11 23/23 29/16 35/7
44/13 47/10 47/14 47/17 50/21 50/23
51/2 51/3 57/2 57/4 58/20 61/21
62/10 62/13 62/14 63/2 63/6 64/9
64/24 66/17 66/18 110/21 117/6
2022 [1] 61/21
2024 [3] 1/12 122/11 122/20
21 [1] 93/7
215-1317 [1] 1/24
22 [2] 29/16 47/21
23 [1] 59/1
25 [1] 93/7
2956 [1] 107/14
3
30 [1] 76/18
30-year [1] 116/11
30303-3361 [1] 1/24
31 [1] 23/19
3361 [1] 1/24
4
404 [1] 1/24
42 [1] 104/21
45 [1] 121/1
46 [4] 88/7 95/7 101/13 103/22
47 [4] 88/8 95/7 101/13 103/22
48 [1] 104/21
487 [1] 8/10
490 [1] 8/10
5
5-minuter [1] 49/5
59 [4] 49/22 49/23 52/24 66/19
7
701 [1] 11/11
75 [1] 1/23
8
808 [1] 11/12
9
90 [1] 1/7
924 [1] 9/17
940 [1] 59/3
941 [6] 15/25 19/4 58/10 58/15 59/2
65/25
941s [7] 15/17 15/20 22/25 23/17
41/14 57/21 58/3
9:38 [1] 88/22
9:40 [1] 88/22
9:41 [1] 2/2
A
a.m [6] 2/2 14/21 49/7 49/8 49/9
49/10
abetted [1] 50/6
abetting [3] 17/25 50/7 71/5
ability [1] 12/5
able [6] 12/23 12/23 30/21 69/3
105/19 121/4
about [238]
absolutely [2] 64/16 65/23
abundant [1] 75/5
abuse [2] 8/20 9/3
accepted [2] 8/2 18/9
access [18] 6/22 26/21 27/3 30/3
30/5 30/20 30/23 50/24 54/18 57/19
61/22 66/9 69/9 72/18 106/11 106/13
111/19 111/25
accessed [3] 96/6 96/10 109/15
accessing [1] 57/8
accomplish [1] 35/14
according [1] 6/13
account [90] 20/2 21/11 21/18 23/3
24/7 24/8 26/1 26/4 26/8 26/9 26/9
26/9 26/22 27/4 29/3 29/4 29/5 29/6
29/12 29/20 29/21 30/3 30/6 30/15
30/16 30/16 38/9 38/13 38/14 38/15
39/7 40/1 40/2 42/22 43/9 43/16
44/15 44/22 45/19 46/21 47/19 47/20
47/22 47/24 48/3 50/22 51/2 51/5
51/8 51/9 56/20 57/5 57/8 57/13
57/17 57/19 57/23 58/9 58/17 59/4
59/19 59/21 64/21 64/21 64/22 65/6
72/18 73/6 77/7 83/22 87/10 88/6
97/8 99/8 108/23 108/25 109/3 109/10
109/13 109/16 109/19 110/3 110/7
110/10 111/20 111/22 111/25 112/9
115/5 120/16
accounting [2] 39/10 39/11
accounts [11] 26/12 30/18 30/21
30/21 30/23 60/17 76/10 96/6 111/7
111/8 114/4
accurate [1] 122/18
accusations [2] 73/19 115/9
accusing [1] 92/16
act [4] 18/1 36/5 71/13 97/23
acted [1] 33/14
action [4] 17/18 37/19 53/23 62/19
actions [2] 79/22 120/13
actively [2] 57/11 57/13
activities [8] 77/16 77/25 78/1 78/6
78/8 78/11 96/12 99/4
activity [10] 38/20 38/22 38/25
40/20 41/1 41/8 83/25 84/9 87/24
99/2
actors [1] 81/9
acts [3] 18/4 50/13 72/10
actual [4] 55/21 99/18 99/25 105/21
actually [35] 2/23 6/18 17/21 25/13
38/9 38/25 39/7 39/12 40/19 42/7
42/9 42/13 43/19 52/22 54/22 54/24
55/7 55/10 56/19 62/12 67/25 68/2
68/5 74/10 74/12 82/21 88/23 94/24
100/7 100/23 101/12 113/12 113/15
117/22 118/1
add [7] 2/22 9/25 10/22 10/24 13/21
69/3 117/17
added [2] 2/13 118/17
addition [1] 73/25
additional [4] 5/9 13/15 98/15
102/12
address [13] 26/23 56/18 56/24 57/3
57/20 61/16 73/2 96/7 115/1 115/2
115/3 115/4 118/9
addressed [2] 93/20 109/22
addresses [6] 26/13 62/7 73/9 73/9
114/23 114/24
adjust [1] 14/19
administrative [1] 2/6
admit [5] 45/3 58/22 58/24 71/23
77/24
admits [1] 67/16
admitted [10] 43/1 45/12 45/14 52/13
65/20 71/16 71/18 73/24 77/10 80/18
admitting [2] 67/20 68/21
Adobe [1] 29/18
adopt [1] 8/25
advance [1] 52/14
advances [1] 71/13
advantage [1] 11/14
Advertising [1] 23/16
advised [1] 92/17
affairs [1] 97/25
affiliation [1] 69/9
after [25] 1/11 5/8 5/15 16/15 19/22
20/22 23/3 23/11 25/1 43/6 43/7
44/12 59/20 61/6 64/17 67/2 67/2
70/9 73/13 112/23 113/14 114/1 114/7
114/18 121/3
again [50] 5/19 9/7 11/7 19/15 19/15
19/16 20/17 23/9 25/8 25/14 27/20
28/18 31/17 34/7 35/1 36/17 37/5
37/23 38/6 39/20 39/21 40/16 47/25
49/19 57/5 58/10 62/3 63/13 65/6
67/13 67/14 68/18 77/22 83/24 88/5
93/21 95/1 95/10 96/14 100/22 101/1
101/7 101/10 102/3 110/22 111/13
113/22 113/23 114/1 120/8
against [9] 31/7 54/22 60/18 71/25
93/22 98/2 115/10 120/7 120/20
agent [25] 3/10 55/14 55/18 55/23
63/11 64/12 74/19 82/7 88/11 89/20
89/22 89/22 93/1 93/8 93/12 94/4
95/12 95/14 95/25 107/15 108/21
109/6 109/7 115/11 119/10
agents [9] 65/8 65/15 67/12 69/13
72/23 84/25 89/15 90/25 93/16
aggressive [2] 89/7 119/14
ago [3] 9/8 45/6 117/24
agree [3] 36/2 111/14 111/14
agreement [8] 17/6 35/11 35/14 35/18
36/3 36/9 53/15 54/3
ahead [4] 49/12 82/18 90/1 105/6
123
Case 1:20-cr-00296-JPB-CMS Document 1041 Filed 06/17/24 Page 124 of 140
A
AI [1] 1/18
aided [1] 50/6
aiding [3] 17/24 50/7 71/4
Alabama [9] 43/22 46/2 47/14 80/10
83/23 85/15 95/9 118/5 118/17
all [129]
allegations [1] 119/8
alleged [4] 17/21 36/16 54/5 60/20
allegedly [1] 72/23
allowed [2] 83/7 83/10
alluded [1] 8/18
almost [1] 73/12
aloud [1] 69/13
already [16] 4/2 22/12 37/16 73/25
77/10 79/3 81/2 84/12 86/8 88/8
93/20 96/4 96/20 97/16 102/4 116/2
also [49] 2/13 5/6 5/9 5/11 5/11
8/20 10/22 16/22 17/4 17/24 19/6
20/10 27/13 30/11 31/13 31/25 33/19
34/20 35/8 35/19 36/24 40/12 42/8
43/5 43/25 50/22 51/21 51/22 62/4
65/9 67/10 69/3 73/5 74/15 77/14
89/15 95/13 101/15 103/1 106/24
108/17 109/22 111/9 111/17 112/25
114/3 114/22 115/11 117/9
although [2] 45/9 74/10
always [7] 71/21 81/23 81/24 91/20
91/20 91/22 92/17
am [4] 1/5 89/23 91/8 91/9
Amanda [4] 74/17 74/23 115/14 115/22
Amendment [3] 8/11 11/1 11/9
AMERICA [4] 1/4 51/2 51/4 122/11
amount [7] 5/5 25/9 69/20 88/16 94/8
116/24 116/25
analyze [1] 96/25
analyzed [1] 107/15
André [19] 76/5 80/25 81/11 81/21
81/22 82/1 82/5 82/10 84/21 85/2
85/5 85/7 91/4 96/20 97/4 105/18
118/19 118/21 118/22
Ann [1] 1/19
announced [1] 25/25
another [12] 8/12 23/16 31/15 50/13
58/7 58/9 58/13 58/16 59/20 77/12
94/25 108/10
answer [5] 52/3 65/16 90/18 112/5
119/2
answering [1] 88/15
answers [2] 88/23 92/12
any [44] 1/13 2/12 3/14 6/18 14/8
16/13 16/14 26/10 29/1 29/9 30/13
30/17 30/22 35/17 40/10 45/15 45/17
47/4 51/25 65/13 68/17 68/17 69/2
72/7 73/8 73/23 74/20 75/1 76/9
80/24 82/17 86/13 86/18 90/15 93/9
101/3 101/5 106/12 108/3 112/11
114/14 115/11 116/8 117/3
anybody [13] 6/13 26/17 27/1 27/6
27/16 29/20 30/14 30/14 30/16 89/17
91/23 94/11 111/23
anyone [6] 4/3 17/21 52/19 63/20
99/20 121/6
anything [29] 13/21 28/9 29/1 29/21
33/11 45/3 47/3 68/2 69/20 70/2
71/18 72/6 86/19 86/19 87/4 91/22
91/24 92/5 93/2 93/2 94/12 94/21
95/7 98/8 102/7 103/5 103/8 113/1
116/4
anywhere [1] 30/9
apart [1] 78/24
apartment [1] 118/16
apologize [1] 10/7
Appearances [1] 1/15
Apple [3] 30/12 30/14 30/17
applicable [3] 3/8 3/13 3/14
application [24] 19/5 33/2 33/9
33/11 34/14 41/13 41/17 42/18 43/2
63/2 63/3 81/15 82/6 82/22 83/4
83/20 84/5 84/6 98/9 111/10 111/12
116/17 116/22 117/11
applications [8] 15/18 16/3 18/9
34/11 34/12 42/21 82/20 93/19
apply [3] 2/10 9/2 114/19
applying [1] 8/14
appreciate [1] 90/3
appropriate [2] 3/7 5/8
approval [6] 5/8 5/11 6/21 7/9 7/18
7/22
approvals [2] 7/5 7/18
approve [1] 7/13
approved [10] 15/13 20/6 20/8 20/9
20/17 33/12 34/4 48/13 68/18 112/10
apps [2] 61/24 61/25
Appx [2] 8/10 11/12
April [6] 21/14 62/13 62/14 63/2
110/21 113/2
are [114] 1/12 2/10 4/2 4/20 4/25
5/1 5/9 10/21 12/4 12/4 14/8 14/9
14/14 15/1 16/25 22/3 22/4 23/8 24/4
25/19 26/7 28/4 31/2 31/3 31/23
34/23 35/25 36/2 37/15 38/3 40/12
40/13 42/4 45/11 51/19 51/21 52/9
53/8 53/12 54/6 54/13 55/7 55/19
56/3 58/15 58/20 59/4 59/23 59/24
60/23 61/3 61/4 61/9 61/25 62/1 62/1
62/21 62/21 62/22 62/23 63/9 63/17
63/18 63/19 67/8 67/24 70/24 71/16
73/10 73/18 73/23 77/4 79/4 79/5
79/13 79/15 79/16 81/3 81/8 81/17
81/25 83/7 83/10 85/12 89/8 89/15
89/15 90/25 91/19 91/21 92/6 92/16
92/21 93/14 94/14 95/11 95/18 96/17
97/17 98/15 98/23 101/25 102/1 103/9
105/10 107/21 108/9 112/1 113/15
113/25 114/14 120/25 121/5 121/6
aren't [4] 2/12 22/8 66/8 73/22
argued [2] 3/17 71/1
arguing [2] 72/15 72/16
argument [7] 8/24 13/16 15/6 49/14
75/14 76/7 105/8
arguments [2] 15/2 116/20
arm's [1] 44/1
armed [1] 89/15
around [9] 16/18 21/20 33/25 72/2
106/21 107/10 107/21 110/3 110/7
arrest [2] 55/13 64/13
arrested [4] 3/9 64/11 97/11 116/2
arresting [1] 114/13
articles [1] 64/13
ask [27] 4/7 5/14 5/23 11/5 12/10
44/2 45/19 45/22 47/4 48/15 48/17
48/19 51/25 54/10 54/20 55/15 73/12
75/9 77/3 79/18 81/25 102/1 102/21
103/21 111/19 112/16 120/20
asked [30] 4/18 12/2 12/8 12/13
23/11 24/21 24/24 25/17 44/21 47/15
47/21 48/4 65/6 75/17 77/17 77/23
77/24 79/13 80/10 83/7 83/15 84/20
85/2 86/22 87/6 90/10 93/4 95/14
118/4 120/18
asking [21] 11/25 12/1 25/23 25/24
26/6 27/10 27/13 28/3 28/4 30/19
45/2 59/24 62/3 73/10 75/3 75/4 80/7
91/2 91/23 98/6 114/22
asks [2] 23/9 119/1
assistant [4] 7/10 7/12 7/15 7/23
associated [2] 50/14 55/16
associating [1] 71/9
assume [2] 27/18 28/5
assumes [1] 13/2
assuming [2] 6/21 8/24
assumption [1] 101/2
ATLANTA [3] 1/2 1/24 122/7
attached [1] 1/9
attaching [1] 1/12
attempt [2] 27/15 109/1
attempts [2] 29/8 29/17
attention [1] 97/18
attorney [14] 7/11 7/15 7/23 12/2
90/1 91/17 91/25 92/2 92/9 93/3 93/4
97/9 119/19 119/21
attorneys [4] 78/16 78/24 91/13
105/9
audio [10] 19/14 19/18 19/21 24/25
30/1 38/11 43/14 44/8 48/6 49/2
aura [1] 10/8
AUSA [1] 5/7
author [1] 112/24
authority [1] 7/10
authorization [1] 7/1
authorized [4] 4/20 5/25 7/24 39/25
auto [4] 23/25 46/24 47/16 87/11
automatically [1] 71/14
available [2] 8/6 12/15
avoid [3] 42/11 42/15 100/14
aware [3] 8/18 42/8 100/6
away [3] 11/2 70/19 103/7
B
Babasijibomi [1] 1/17
back [50] 2/8 9/6 9/9 16/10 18/21
21/13 23/3 32/14 32/16 48/15 61/7
62/13 64/8 65/3 66/18 66/24 68/25
69/1 71/16 73/14 77/4 77/17 77/17
81/24 83/24 84/24 85/19 95/16 95/18
95/25 96/15 96/15 96/21 98/6 98/23
101/11 102/2 102/21 104/10 104/12
106/23 107/12 110/12 112/14 112/16
113/14 113/17 116/22 119/16 121/2
background [3] 75/23 85/6 90/21
backtracked [1] 67/3
bad [2] 61/5 84/8
bag [1] 88/18
balances [4] 76/23 88/6 102/7 102/8
bank [38] 6/10 6/11 16/2 16/5 16/12
16/23 17/5 17/6 18/20 22/18 22/21
22/21 22/23 34/20 34/24 35/5 35/6
35/6 35/9 36/2 37/23 37/24 37/24
41/14 41/18 47/21 51/2 51/4 64/22
76/10 76/21 88/6 94/5 96/6 99/8
109/14 114/4 115/24
banks [7] 22/4 33/20 33/21 33/24
34/3 34/22 37/13
based [11] 10/15 13/5 13/7 21/13
33/4 33/6 37/21 55/19 70/8 70/15
114/17
basic [1] 88/1
basically [5] 17/6 32/24 35/10 42/11
99/7
basis [1] 88/7
be [102] 1/5 1/6 3/3 3/10 3/16 4/9
4/15 4/21 5/2 5/14 6/17 6/19 7/6
7/22 8/16 9/23 10/1 11/20 14/2 14/22
17/1 20/15 27/6 31/22 32/23 33/22
34/4 36/9 36/13 39/7 43/13 43/16
44/17 47/1 49/11 50/5 50/5 50/7
52/24 55/16 56/7 60/24 61/2 61/9
62/17 63/8 63/21 63/25 64/19 66/4
66/6 70/11 70/11 70/23 72/4 72/12
72/14 72/15 72/16 72/19 73/12 73/13
73/20 76/25 80/9 80/9 80/10 82/2
82/14 83/19 85/4 86/13 86/17 86/20
88/3 89/2 89/24 90/5 90/5 90/10
90/12 90/16 91/20 91/20 92/14 93/7
97/23 98/18 98/21 101/3 102/15
102/18 105/5 105/13 107/24 108/1
110/18 113/9 115/19 118/14 121/2
121/4
bear [1] 4/19
became [1] 24/13
because [106] 5/10 5/25 6/5 6/10 7/1
7/9 7/17 8/3 9/11 9/18 10/23 13/13
17/10 17/22 21/9 21/14 21/15 21/22
22/14 23/1 23/19 24/13 24/22 25/4
25/9 25/13 25/15 27/6 29/25 30/4
32/5 33/1 33/10 34/2 36/9 36/18
37/20 38/14 38/22 40/16 43/6 43/16
43/19 44/16 44/25 45/22 46/16 47/4
47/15 48/4 48/12 54/8 59/13 61/17
62/11 63/15 64/2 66/12 67/15 71/2
74/13 75/25 78/18 79/5 80/21 83/16
84/2 86/24 87/19 89/4 89/15 91/8
92/7 92/17 95/21 95/23 98/11 99/20
101/5 102/15 102/17 103/22 106/18
108/5 108/9 108/14 110/10 111/1
111/24 112/17 113/1 113/4 113/11
113/13 113/16 113/25 116/13 116/17
119/4 119/19 119/22 119/24 120/4
120/17 120/19 120/19
become [1] 71/14
becomes [1] 3/9
becoming [1] 25/14
been [41] 7/19 8/22 9/3 9/10 9/14
9/20 11/3 14/11 27/18 33/12 43/19
44/19 46/2 48/11 51/15 56/24 64/11
65/2 65/4 68/18 68/23 71/15 77/16
79/3 81/2 81/4 87/18 88/11 90/22
93/21 104/4 108/10 112/4 112/9
124
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B
been... [7] 112/12 113/10 114/23
116/2 119/3 119/10 120/4
before [18] 1/11 5/19 10/5 14/7 18/9
24/12 50/19 64/15 65/10 65/11 67/23
79/17 89/10 91/1 93/16 104/6 104/7
116/8
began [1] 62/12
begin [1] 63/5
beginning [4] 18/8 18/16 24/21
110/23
behind [6] 54/23 54/25 61/7 65/3
106/22 119/13
being [28] 7/17 18/9 23/20 30/10
33/5 33/8 33/9 33/21 39/9 50/10 57/6
59/24 71/9 74/13 74/18 76/25 80/3
80/5 82/4 89/12 91/3 91/5 99/7 100/8
108/2 116/21 120/15 121/9
believe [31] 4/1 5/18 25/17 25/23
25/24 26/6 27/10 27/13 30/19 32/11
47/9 47/11 47/12 56/22 63/10 68/20
83/10 83/14 85/16 100/13 101/10
102/11 103/3 103/5 103/9 103/11
103/14 103/15 105/24 107/8 116/13
believed [2] 42/10 100/7
Bellator [13] 18/18 19/4 19/23 38/21
38/22 39/1 55/4 57/14 63/3 63/15
67/18 69/7 111/10
Bellavie [1] 23/13
benign [1] 2/9
Berne [1] 12/11
Berni [4] 55/14 55/18 55/23 107/15
best [3] 7/3 9/16 72/8
bet [1] 20/18
better [3] 75/3 113/5 113/7
between [8] 23/6 35/11 43/10 52/4
52/5 61/21 77/20 87/17
beyond [17] 5/10 41/21 48/1 49/25
52/18 62/3 70/7 70/18 70/21 70/24
71/5 72/3 97/22 98/5 98/19 100/21
103/20
bias [1] 79/4
big [7] 43/23 79/18 80/14 80/16 87/8
87/22 95/13
biggest [2] 92/23 92/24
bit [10] 57/25 79/24 79/25 79/25
82/18 84/13 85/9 87/7 88/8 112/18
Black [1] 20/19
blame [1] 9/21
blank [1] 116/24
blindly [1] 6/17
blue [1] 98/10
bluntly [1] 9/25
Board [4] 22/17 22/19 22/22 22/23
borne [1] 49/19
boss [1] 119/17
both [9] 4/10 7/13 15/10 37/9 42/7
89/15 101/13 105/9 120/20
BOULEE [10] 1/11 17/9 17/17 31/3
35/15 36/13 36/24 40/4 42/5 42/7
Boulee's [1] 25/20
boxes [1] 14/12
brain [1] 120/10
break [9] 6/1 14/19 49/4 79/19 104/6
104/7 104/8 121/1 121/8
breeze [1] 56/3
brief [3] 4/9 9/5 14/19
briefed [1] 4/6
briefing [1] 13/25
briefly [2] 54/7 81/6
briefs [1] 4/7
bring [14] 13/18 49/16 50/17 54/19
54/19 54/21 54/22 54/24 55/25 65/16
97/12 104/9 104/18 105/16
brings [1] 78/17
broach [1] 5/20
brought [12] 12/17 24/19 54/11 54/12
54/16 55/14 61/11 81/4 93/21 94/2
94/24 102/15
build [1] 86/4
building [4] 7/14 46/4 85/18 118/16
built [2] 76/25 78/5
bullshit [4] 28/19 28/19 28/20 28/21
bunch [2] 75/17 94/7
burden [5] 71/22 95/24 103/23 105/13
105/14
Bureau [2] 13/13 13/13
business [35] 16/13 18/20 20/1 20/4
20/14 20/21 20/24 20/25 21/14 23/7
23/13 25/3 33/5 33/6 41/16 42/18
45/15 45/15 45/25 46/3 46/13 46/16
46/17 46/22 47/6 47/13 66/9 68/11
76/24 76/24 77/7 108/8 117/6 117/17
118/16
businesses [12] 15/19 15/25 16/5
16/13 19/24 20/3 33/23 36/19 42/23
102/8 110/10 113/14
businesswoman [4] 75/19 78/4 90/22
117/15
buy [2] 70/15 87/15
C
calculated [1] 33/3
call [16] 12/5 12/7 12/23 12/24
13/12 55/15 85/20 85/25 88/25 90/1
90/1 90/2 92/1 92/3 105/12 107/16
called [9] 2/2 54/6 54/8 55/19 58/21
74/11 81/22 105/11 115/16
calls [7] 54/9 55/16 96/25 106/5
107/11 107/15 107/21
calm [1] 88/14
came [24] 6/6 38/19 38/21 40/19
40/21 41/1 42/25 43/5 44/11 44/22
46/20 57/14 57/22 66/11 67/15 69/6
73/7 74/9 90/11 94/8 94/11 94/18
94/25 110/3
can [49] 2/10 3/3 3/10 5/2 5/7 5/14
11/20 14/22 21/9 26/3 26/3 36/13
40/1 42/6 42/12 49/11 50/5 51/20
56/25 59/25 62/12 62/15 63/2 65/6
68/1 68/2 68/4 68/4 72/4 73/20 81/6
82/16 83/8 83/21 88/13 88/23 90/3
91/6 92/7 98/1 99/14 100/15 104/6
105/5 105/22 110/24 111/5 119/12
121/2
can't [2] 46/2 73/13
cannot [4] 52/17 52/24 53/21 71/2
car [3] 106/17 109/7 109/8
card [4] 55/6 89/21 89/23 107/22
career [1] 76/3
careful [1] 73/13
carefully [2] 73/15 75/7
CARLA [22] 1/6 15/10 39/17 46/6 53/3
81/8 81/11 82/9 82/11 82/16 83/19
83/24 84/24 87/23 96/5 96/8 96/11
116/6 117/14 120/8 120/21 122/11
carry [1] 106/18
cars [3] 32/1 70/2 77/19
case [62] 3/1 4/4 4/16 5/10 8/9 8/10
8/17 10/6 12/3 12/5 12/6 15/9 15/12
17/3 18/6 29/1 30/14 31/7 37/4 40/20
40/23 42/16 43/4 53/2 54/6 56/4
60/15 60/18 67/8 69/6 69/16 69/21
70/10 71/16 71/22 71/23 72/7 72/20
72/21 73/14 73/19 73/21 74/25 75/7
78/22 81/5 81/9 81/24 86/11 86/12
93/21 95/5 100/19 105/14 105/21
108/24 113/12 114/19 120/7 120/9
121/6 122/12
cases [5] 2/20 2/22 2/25 78/19 81/23
cash [3] 32/2 51/18 70/2
cashier's [1] 87/6
cause [1] 73/24
caution [1] 92/22
CDC [1] 115/15
cellphones [1] 106/18
Celtic [2] 35/6 37/23
center [1] 81/12
certain [2] 71/10 90/22
certainly [4] 4/2 9/3 78/11 114/7
CERTIFICATE [1] 122/2
certification [2] 117/5 117/9
certifications [1] 117/4
Certified [3] 1/19 122/2 122/5
certify [1] 122/7
Chaiken [12] 1/16 3/17 4/8 9/22
13/19 15/4 75/22 78/15 79/18 103/25
105/6 120/23
chance [3] 2/19 13/19 14/4
change [15] 21/15 21/22 21/23 23/1
23/2 25/5 25/6 25/10 25/16 29/8 30/7
30/8 31/14 67/7 113/4
changed [3] 25/15 28/14 104/21
changes [1] 104/19
changing [5] 16/8 16/11 16/11 16/11
20/4
characterize [1] 120/7
charge [4] 17/10 35/20 92/5 92/10
charged [35] 16/19 16/21 16/22 17/4
17/8 17/11 17/24 18/1 24/1 34/20
35/8 37/13 37/25 39/16 39/17 39/18
40/14 53/4 53/18 53/20 63/10 69/12
84/10 94/21 95/6 97/11 101/9 101/12
101/12 101/15 101/19 101/20 101/22
108/10 108/11
charges [3] 9/21 52/25 53/21
Charmaine [2] 74/15 74/22
chart [4] 70/17 81/6 95/3 114/12
cheat [1] 17/19
cheated [5] 32/9 64/18 77/11 78/10
85/12
check [9] 14/11 39/23 40/2 40/8
40/11 46/21 64/20 80/8 87/6
checks [4] 44/14 44/21 87/20 88/9
cherrypicked [1] 109/25
chief [2] 7/12 7/13
child [6] 92/4 92/8 92/11 92/15 93/6
93/7
children [3] 77/11 91/15 116/10
choose [2] 83/9 83/13
chose [3] 12/17 26/15 48/12
Christian [4] 74/17 74/23 115/14
115/22
Circuit [5] 3/6 8/15 8/23 8/25 11/12
Circuit's [1] 10/6
circuits [2] 8/18 8/25
circumstance [1] 10/1
circumstances [4] 8/21 9/13 120/13
120/14
circumstantial [3] 35/24 36/4 86/15
cite [3] 1/9 10/7 11/12
cites [1] 3/2
claimed [1] 45/5
claiming [1] 8/11
claims [1] 71/24
clamp [1] 87/1
clarification [1] 2/23
clarify [1] 8/8
clawback [1] 99/10
clear [12] 4/9 4/15 4/21 7/6 8/14
13/24 62/17 64/19 70/20 74/25 105/13
111/23
clearly [4] 10/19 13/24 33/10 52/15
client [8] 76/16 84/18 86/16 86/20
93/22 94/11 99/25 101/19
client's [2] 86/10 86/14
clip [1] 44/2
clips [1] 69/3
cloak [1] 72/2
clones [1] 63/19
close [2] 69/20 98/4
closed [2] 42/14 100/25
closing [6] 15/1 15/6 49/14 56/22
75/14 105/8
closings [2] 14/15 104/6
CM [2] 1/5 1/6
CM/ECF [2] 1/5 1/6
co [4] 3/10 54/5 71/14 94/14
co-conspirator [2] 3/10 71/14
co-conspirators [1] 54/5
co-owner [1] 94/14
codefendants [3] 78/19 78/20 78/20
codes [1] 61/20
coextensive [1] 8/4
cofounder [1] 94/3
collect [2] 28/1 107/7
column [1] 53/8
Comcast [1] 96/7
come [17] 5/22 21/9 23/1 30/8 38/25
41/3 41/22 60/17 78/14 79/15 82/10
82/13 87/9 93/5 95/25 96/1 97/11
comes [5] 20/22 22/1 22/6 90/20 95/4
comfort [1] 104/6
coming [13] 5/17 36/19 66/6 78/19
78/21 80/7 81/20 89/3 89/16 97/4
97/8 110/9 110/18
commentary [1] 3/19
commit [17] 17/5 17/5 17/6 18/3 18/7
18/16 26/2 26/12 32/14 35/9 35/9
125
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C
commit... [6] 35/11 36/2 36/10
106/22 111/2 120/18
commits [1] 50/9
committed [3] 32/8 50/10 77/11
committing [3] 32/10 45/8 120/10
common [9] 25/21 35/14 48/19 70/9
71/10 75/25 78/3 78/7 114/18
communicate [3] 31/17 31/24 115/17
communicated [6] 51/8 66/20 74/21
74/22 74/23 108/13
communicating [7] 18/10 62/10 62/12
62/15 63/6 65/3 67/3
communications [12] 10/16 13/7 23/6
24/4 52/4 52/5 52/9 65/10 77/20
81/14 101/4 110/13
companies [3] 25/9 69/9 95/1
company [6] 67/18 76/13 94/3 94/14
94/16 94/18
compare [2] 69/25 111/5
complete [2] 69/3 72/10
completed [2] 63/9 111/17
completely [2] 68/9 118/13
completing [1] 5/3
complicated [1] 49/18
computer [10] 29/7 29/13 29/24 30/4
56/25 86/14 109/3 109/11 109/16
109/20
computers [3] 86/11 96/4 96/9
conceal [8] 39/5 42/1 46/9 48/3
52/19 52/22 97/7 99/6
concealing [1] 50/2
concealment [2] 49/24 119/6
concern [2] 73/24 81/23
concerned [2] 35/23 91/5
concert [1] 81/10
conclusions [1] 25/22
conduct [4] 38/5 38/16 39/22 40/9
conducted [5] 38/5 38/16 39/22 40/9
93/11
confession [1] 28/4
confidence [1] 70/15
confident [2] 54/13 54/17
confirm [1] 2/21
confirming [1] 102/13
confronted [1] 67/8
confused [4] 28/11 28/12 28/15 28/24
connected [2] 49/2 62/2
connection [3] 16/20 17/4 122/14
connects [1] 81/8
consequences [2] 70/13 79/23
consider [7] 25/19 53/24 73/15 75/4
75/7 75/8 88/3
considered [2] 70/9 114/18
considering [3] 25/19 25/20 42/4
conspiracies [1] 53/12
conspiracy [22] 3/25 17/5 35/8 35/9
35/20 37/8 37/9 37/10 52/25 53/17
53/18 53/19 53/23 71/8 71/11 71/12
101/17 101/18 101/19 101/20 108/12
111/21
conspirator [3] 3/10 36/14 71/14
conspirators [2] 36/16 54/5
conspired [4] 36/21 53/9 53/14 69/17
conspiring [1] 54/14
constant [1] 81/13
constantly [1] 110/11
construction [5] 43/24 48/9 90/12
97/10 97/13
consult [2] 46/16 47/12
consulting [9] 46/13 46/22 47/1 47/5
50/22 51/5 63/9 63/11 111/18
consuming [1] 24/23
contacts [1] 22/11
contains [2] 100/13 100/15
contends [1] 3/20
contentions [1] 3/16
contents [1] 100/16
context [1] 93/11
continued [2] 49/9 104/17
Continuing [1] 22/5
Continuity [3] 30/12 30/14 30/17
contract [2] 36/1 89/11
contracts [2] 63/9 111/18
contradictory [1] 67/8
contrary [1] 9/4
control [4] 42/3 46/10 62/6 62/7
controlled [5] 100/9 100/13 100/15
100/21 100/24
controlling [2] 111/6 111/7
conversations [2] 24/3 82/15
convict [1] 71/2
convicted [1] 72/5
convictions [1] 79/2
convince [1] 56/1
convincing [4] 70/11 70/20 97/22
98/21
cookie [2] 19/23 113/5
cookie-cuttered [1] 113/5
cookie-cutterred [1] 19/23
cooperating [1] 78/21
copied [2] 86/20 86/20
copies [2] 14/9 109/21
copy [2] 53/7 101/11
correct [2] 104/23 105/2
cosigner [1] 94/3
could [40] 6/22 6/22 9/10 10/5 12/7
12/15 12/18 25/10 26/14 28/22 32/16
47/22 48/7 48/11 54/11 54/12 54/16
54/24 55/15 55/17 56/1 63/20 65/13
67/11 72/12 79/20 82/10 82/13 82/14
83/22 84/10 87/25 89/20 89/21 90/2
92/14 93/7 105/11 106/22 113/6
couldn't [7] 24/22 45/5 45/12 47/18
73/5 116/9 118/8
counsel [5] 10/15 81/3 97/16 104/11
104/19
count [13] 34/19 39/16 49/21 49/22
49/23 52/24 53/24 53/25 54/3 54/4
66/19 101/17 101/21
Count 59 [1] 49/22
country [1] 34/13
counts [14] 37/10 40/13 48/21 53/18
71/5 71/8 75/10 88/7 95/6 101/9
101/13 101/13 101/25 103/22
Counts 46 [1] 88/7
couple [7] 9/8 46/4 49/1 80/15 93/17
98/13 101/16
course [7] 8/17 11/3 17/18 35/25
38/21 106/17 110/9
court [21] 1/6 1/11 1/13 1/17 1/19
1/1 1/11 1/22 1/22 2/2 3/23 7/22
8/18 11/25 49/8 97/2 97/19 122/5
122/6 122/10 122/24
Court's [1] 13/1
Courthouse [1] 1/23
courtroom [9] 10/16 13/8 14/21 49/7
49/10 104/15 105/4 119/10 121/10
cousins [1] 82/8
cover [3] 68/7 119/25 120/3
covered [1] 37/15
cr [2] 1/5 122/12
create [6] 18/20 19/7 25/3 31/21
69/24 112/22
created [10] 16/7 22/22 26/24 33/8
37/5 61/4 110/23 112/6 112/20 113/2
creates [6] 20/13 21/1 21/5 21/18
22/7 24/8
creating [4] 25/14 26/13 33/23 81/14
Creations [4] 20/5 20/11 58/3 58/8
credibility [2] 84/14 103/17
credible [4] 83/8 83/9 84/15 103/8
credit [4] 78/14 78/15 93/9 93/9
crime [10] 18/3 35/22 45/8 50/8 50/9
50/10 50/15 50/16 72/4 100/5
crimes [5] 16/19 17/1 17/6 35/9
35/11
criminal [1] 41/1
criminally [3] 18/3 18/4 50/12
crisis [1] 15/11
critical [4] 72/20 72/21 81/24 98/23
Cromer [1] 89/22
cross [9] 35/5 37/23 41/18 77/15
78/24 79/4 80/3 80/13 109/14
cross-examination [1] 77/15
cross-examined [5] 78/24 79/4 80/3
80/13 109/14
CRR [2] 1/22 122/23
crying [1] 79/19
cryptic [1] 10/14
current [1] 115/3
custody [1] 70/19
Customers [2] 35/6 37/24
Customs [4] 23/9 23/10 23/12 23/12
cuttered [1] 113/5
cutterred [1] 19/23
cutting [1] 21/23
D
dad [2] 92/1 92/2
daily [5] 46/13 46/17 46/22 47/5
47/13
Darrell [136]
Darrell's [5] 29/6 29/6 60/16 67/18
72/14
data [1] 34/14
date [2] 64/9 77/17
dates [1] 101/14
David [2] 1/18 68/24
day [12] 4/13 5/19 14/25 20/1 20/1
36/8 51/14 106/19 108/10 109/16
112/20 122/20
days [3] 1/7 9/8 21/17
deal [1] 93/15
dealings [1] 81/13
dealt [2] 80/3 93/16
decades [2] 75/20 76/2
deceive [1] 17/19
December [5] 23/19 50/23 64/9 64/24
66/16
decide [5] 31/11 41/23 76/4 77/5
105/23
decided [5] 10/2 30/23 32/16 92/11
119/25
decision [3] 10/23 10/23 108/15
decisions [4] 70/12 70/12 70/13 91/7
declined [3] 5/20 9/8 10/12
declining [1] 5/16
deductions [1] 25/21
defendant [21] 1/18 1/19 3/3 3/19
6/3 6/3 38/4 38/18 39/3 42/8 49/14
50/12 50/14 50/15 54/1 75/14 100/5
100/7 100/12 100/20 100/23
defendant's [3] 3/8 3/22 100/4
defendant-friendly [1] 3/19
defendants [4] 1/8 48/17 54/6 92/20
defense [44] 3/3 3/8 3/13 5/20 6/14
9/7 9/8 9/11 9/22 10/4 10/9 10/15
11/5 11/14 15/3 25/17 25/19 25/23
27/21 28/3 29/11 30/11 30/19 31/2
31/17 31/24 32/10 32/18 47/11 78/16
78/24 91/12 91/17 105/9 105/15
105/15 105/17 107/8 107/22 108/4
108/17 109/2 114/20 114/22
defense's [1] 106/12
defenses [3] 31/2 31/3 108/6
definitions [1] 98/15
deflect [1] 9/21
defraud [10] 17/14 17/18 31/18 31/20
32/20 33/15 34/5 35/2 35/4 37/19
defrauding [1] 17/21
deliberate [3] 98/25 99/15 100/17
deliberately [3] 42/14 100/14 100/25
deliberations [3] 76/8 121/4 121/5
delivered [1] 89/12
demand [2] 55/2 73/10
demeanor [1] 88/14
demonstrate [1] 55/18
denied [3] 12/9 12/12 12/14
deny [3] 45/12 100/15 110/22
denying [1] 111/13
deposit [9] 39/23 40/2 50/18 50/20
51/14 51/15 66/18 66/24 94/8
deposited [2] 46/21 64/20
deposits [5] 40/13 51/23 88/7 97/7
102/9
deputy [3] 7/10 7/14 7/22
described [1] 63/18
describing [1] 67/23
deserved [1] 32/9
designated [1] 39/9
designed [4] 39/4 42/1 46/9 99/6
desired [1] 3/22
desires [1] 4/3
desktop [7] 56/24 56/25 96/10 109/4
109/5 109/7 109/8
desperate [1] 77/1
despite [3] 54/8 61/10 72/7
destitute [3] 76/22 77/1 98/8
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D
detail [1] 38/2
detailed [1] 28/12
details [3] 28/7 36/14 68/9
detective [1] 91/21
detectives [1] 93/16
determine [2] 100/21 103/17
determined [1] 108/24
devastating [1] 77/13
device [2] 57/7 107/19
devices [8] 54/19 61/23 72/23 72/24
75/5 86/8 86/10 96/25
devised [1] 17/14
did [76] 11/8 12/22 20/6 20/9 23/22
23/24 24/11 25/4 25/13 28/14 29/13
31/16 31/24 34/1 38/25 41/3 41/16
41/22 47/3 47/3 49/1 50/4 51/16
55/23 59/16 63/5 64/9 64/24 65/2
65/8 65/9 65/18 68/5 68/17 69/14
69/18 70/2 71/23 73/8 74/25 77/24
77/25 78/14 78/16 79/14 80/19 82/2
82/22 84/14 84/16 84/22 85/25 86/1
86/18 90/9 90/9 91/3 91/4 91/4 91/11
92/15 93/4 100/7 105/20 106/17 107/4
107/5 108/20 111/25 112/5 112/6
112/11 112/11 115/11 117/2 120/19
didn't [82] 6/11 7/1 7/2 10/20 11/6
12/10 13/3 13/9 13/19 16/16 21/15
21/16 21/23 24/23 25/5 25/6 30/7
30/7 30/13 32/3 32/3 36/17 42/10
43/18 43/18 45/16 45/19 45/22 46/25
46/25 54/9 54/19 64/25 65/3 65/4
65/5 66/20 66/21 66/22 72/24 74/10
74/12 74/13 78/1 78/10 78/11 80/23
84/3 84/10 90/15 91/24 92/9 92/24
98/11 99/20 103/16 105/10 105/12
107/4 108/5 108/7 108/14 110/5 110/5
112/3 112/12 113/4 114/5 114/9
114/10 114/23 115/16 116/15 116/16
116/18 118/8 118/11 118/21 119/4
119/14 119/15 120/4
difference [1] 35/24
different [8] 7/14 21/19 25/9 25/15
53/18 111/3 114/13 115/12
difficult [1] 77/23
digital [1] 96/25
direct [8] 35/24 36/3 79/13 81/10
93/23 97/3 97/6 99/3
direction [1] 27/7
directly [6] 21/21 51/22 62/2 62/12
62/15 108/13
disadvantage [1] 11/15
disapprove [1] 61/8
disbelieve [3] 83/11 85/13 103/2
discretion [4] 8/20 9/4 10/2 11/18
discuss [2] 2/17 121/6
discussed [3] 37/16 43/20 63/25
discussing [2] 33/20 71/10
discussion [2] 76/14 86/22
disguise [3] 42/2 46/10 99/6
disregard [1] 119/24
disrupts [1] 59/13
distinction [1] 40/17
District [10] 1/19 1/1 1/1 1/11 4/11
34/12 41/17 41/19 122/6 122/6
DIVISION [1] 1/2
divorced [1] 116/9
Dixon [14] 4/20 6/4 6/6 6/9 8/2 9/18
10/25 12/2 13/12 54/7 74/9 74/21
115/16 115/20
Dixon's [1] 12/2
do [78] 5/25 7/1 7/20 8/24 10/2
10/20 12/16 12/16 13/17 13/21 14/7
20/6 23/22 24/15 25/10 26/15 27/5
27/8 29/17 30/8 30/23 35/22 36/5
38/8 41/5 42/19 43/24 47/13 52/18
55/21 60/8 61/14 65/15 68/13 70/14
72/6 73/6 73/7 75/3 76/8 77/5 77/7
77/8 77/8 78/16 80/7 80/14 82/19
83/10 83/20 83/21 85/13 85/14 87/7
88/13 88/17 88/19 89/5 89/14 90/19
91/3 91/4 91/4 91/12 91/15 91/22
91/24 91/25 92/17 101/8 102/9 103/25
104/5 109/18 116/18 119/20 120/12
122/7
docket [3] 1/10 1/4 9/17
document [14] 1/13 15/25 20/15 22/10
23/4 26/25 37/6 37/7 45/3 84/16
94/24 95/17 113/16 113/20
documents [55] 15/22 16/9 19/16
20/13 20/14 20/23 21/2 21/6 21/24
22/1 22/3 22/6 22/7 22/15 23/8 23/15
24/8 25/3 28/21 28/23 30/5 31/22
33/5 33/8 33/23 33/24 34/1 36/8
37/18 37/22 58/9 59/5 59/11 59/20
60/8 66/10 77/18 77/19 81/14 84/12
84/13 84/17 96/1 96/3 97/12 109/20
110/4 110/7 112/7 112/20 113/14
113/19 117/10 117/11 117/13
does [22] 8/12 17/20 23/3 31/13
32/13 34/8 35/15 40/11 52/14 53/15
54/3 62/7 63/19 63/20 64/3 68/5 68/6
71/13 96/11 108/12 115/5 116/4
doesn't [37] 3/14 9/19 17/25 23/2
35/21 36/14 36/17 36/19 38/6 41/9
57/9 58/21 59/13 59/23 67/16 67/19
69/20 71/11 71/12 78/6 87/13 87/14
87/23 87/23 101/8 102/7 103/11
106/11 106/18 108/3 111/1 111/2
112/12 114/9 115/6 115/24 117/17
doing [18] 20/4 25/12 26/11 36/9
44/16 45/13 47/2 65/4 74/15 77/18
82/24 84/3 96/12 112/4 116/13 116/16
117/23 120/3
DOJ [1] 5/10
dollars [2] 27/16 114/3
don't [48] 6/20 6/23 8/23 9/1 9/14
10/6 31/18 40/24 47/25 49/4 56/12
60/19 69/2 69/14 70/13 72/6 72/6
72/20 72/22 72/22 73/23 78/19 82/2
82/3 82/17 83/4 85/6 85/8 86/7 87/9
88/16 88/20 89/10 91/9 91/14 92/13
92/18 93/9 93/15 99/17 100/18 103/5
103/8 103/12 108/6 113/14 120/9
120/10
done [14] 4/3 5/14 7/17 8/25 10/5
29/21 38/7 45/15 63/20 70/25 72/7
73/12 107/25 108/3
door [10] 85/1 89/4 89/12 89/14
90/20 90/24 93/8 119/1 119/13 120/1
doubt [26] 41/21 50/1 69/24 70/5
70/7 70/8 70/8 70/18 70/21 70/24
71/5 71/24 72/3 75/6 96/14 97/16
97/22 98/5 98/19 98/20 98/22 100/22
102/23 103/20 114/17 114/17
down [14] 6/21 24/5 42/23 73/13
76/15 79/19 87/1 88/2 92/11 96/17
99/11 99/14 117/4 118/2
downloaded [1] 109/13
downloading [1] 57/11
draft [1] 36/1
dressed [1] 89/3
Drive [1] 1/23
driver's [3] 77/18 115/1 115/3
during [14] 15/11 15/13 28/11 42/22
45/13 45/22 61/18 64/6 76/9 79/1
79/1 84/19 88/25 116/11
Durrett [3] 1/19 11/22 13/3
duty [1] 12/10
E
each [25] 15/14 15/15 15/18 16/5
16/20 17/4 17/11 18/7 25/3 32/20
34/17 34/18 36/10 37/10 39/15 39/19
53/15 53/23 53/24 53/25 54/1 69/18
98/18 98/21 109/20
earlier [5] 2/21 10/10 10/11 63/14
63/16
early [5] 10/10 80/2 88/21 88/21
90/24
earned [1] 78/5
easier [1] 11/17
easiest [1] 119/2
easy [3] 18/14 70/12 93/14
eat [1] 24/18
ECF [2] 1/5 1/6
economy [1] 42/24
Education [1] 23/5
eight [1] 59/18
either [3] 9/1 9/15 45/17
element [20] 10/9 17/13 32/21 32/22
33/13 33/14 34/6 34/18 35/7 35/13
36/11 38/18 38/24 39/21 40/18 40/25
41/5 41/11 70/7 72/4
elements [14] 17/10 34/23 37/9 37/15
38/1 38/3 39/14 39/20 40/15 41/24
98/16 98/18 101/23 103/23
Eleventh [5] 3/6 8/15 8/23 8/24
11/12
Elite [1] 69/7
else [8] 30/9 43/3 53/4 54/18 57/19
61/22 89/4 99/13
email [35] 26/13 26/15 26/23 26/23
56/18 56/23 57/3 57/6 57/17 57/20
58/1 58/7 58/8 58/9 58/13 58/13 59/4
59/9 59/11 59/16 59/19 59/20 62/7
62/14 67/15 72/18 73/9 73/9 83/1
83/16 101/4 101/6 110/2 110/24 120/9
emailing [1] 110/21
emails [29] 16/10 21/10 27/1 28/17
54/23 56/5 56/6 56/7 57/8 57/12
57/24 58/20 59/8 59/23 60/3 60/10
60/17 65/5 65/7 67/13 67/13 67/15
77/20 86/18 96/24 109/23 110/2 110/9
110/11
embrace [1] 105/14
employee [8] 19/8 65/19 65/24 65/25
66/5 66/12 66/12 113/18
employees [11] 25/8 42/19 43/17
45/17 68/13 80/11 90/15 112/8 116/25
117/3 117/7
end [4] 5/19 67/11 79/12 79/12
ended [3] 19/4 23/19 77/12
enforcement [3] 64/3 85/1 116/1
enforcement's [1] 88/18
enjoy [2] 102/17 121/8
enough [7] 42/8 50/11 71/1 73/11
99/18 100/5 121/1
enters [3] 14/21 49/10 105/4
entertain [1] 4/2
entire [5] 57/7 65/20 93/21 106/20
112/15
entirely [2] 11/2 28/3
entitled [2] 3/3 117/17
entry [1] 1/10
equal [1] 61/4
equally [1] 105/19
equipment [2] 48/9 107/18
error [1] 11/13
especially [2] 61/6 61/18
Esq [6] 1/16 1/16 1/17 1/18 1/19
1/19
essential [1] 100/5
essentially [1] 34/23
establish [3] 55/21 56/1 71/11
established [2] 50/20 50/22
establishes [1] 72/3
estate [1] 48/8
estimate [1] 7/4
ETA [1] 23/10
evaluate [2] 79/20 105/23
even [43] 3/4 4/12 6/22 7/16 7/20
8/3 8/23 9/22 11/13 11/16 11/17
13/12 18/9 28/8 32/11 36/14 39/10
41/1 43/19 46/2 47/9 52/21 57/9
58/22 59/23 62/17 64/22 65/10 65/10
66/8 67/1 67/2 69/19 70/25 74/13
93/2 93/5 95/19 96/18 107/6 108/13
112/6 117/24
events [1] 72/9
eventually [1] 45/9
ever [14] 15/25 26/17 29/20 30/16
64/22 77/25 83/25 84/8 86/8 86/18
90/25 91/1 91/19 91/23
every [29] 15/20 15/25 17/11 18/1
21/14 31/18 33/10 34/19 36/8 36/10
37/5 37/6 37/7 39/16 42/14 54/4
62/19 69/11 69/18 70/6 72/3 72/4
74/5 100/24 107/16 107/23 110/17
112/19 112/23
everybody [2] 14/4 121/2
everyone [5] 2/4 2/5 49/6 53/4 116/3
everyone's [1] 115/18
everything [20] 2/11 14/5 22/16
24/15 27/5 43/3 47/11 73/25 76/15
78/4 83/11 86/6 91/8 94/15 95/4
99/10 102/16 103/2 103/6 119/24
evidence [90] 3/20 3/20 15/9 15/12
18/6 25/20 28/25 29/8 29/8 29/9
127
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E
evidence... [80] 29/12 29/13 29/19
29/21 30/13 32/19 35/1 35/24 36/3
36/5 36/6 39/1 46/8 48/20 50/19 52/1
52/10 52/14 53/1 53/25 54/1 56/15
60/21 62/4 65/11 66/8 67/9 70/10
70/16 70/20 71/23 73/16 73/23 74/19
74/20 74/21 74/23 75/10 76/9 76/23
76/25 77/14 86/7 86/14 86/15 86/17
88/1 88/4 90/25 92/24 92/25 93/14
93/18 93/23 94/10 94/19 94/25 96/5
96/16 97/6 98/1 99/3 99/25 100/19
101/1 102/2 102/3 102/3 102/12
103/10 103/13 105/21 106/12 109/18
110/20 114/18 114/22 115/8 117/1
120/9
evidentiary [2] 3/4 3/5
ex [9] 43/8 44/15 44/21 83/17 87/19
102/19 103/16 117/16 120/5
ex-husband [5] 43/8 44/15 44/21
117/16 120/5
ex-spouses [1] 87/19
ex-wife [3] 83/17 102/19 103/16
exact [9] 10/21 24/6 25/9 41/10
63/19 110/15 112/20 112/20 113/12
exactly [7] 4/15 23/11 28/8 71/1
113/24 120/2 120/2
examination [2] 77/15 79/13
examined [5] 78/24 79/4 80/3 80/13
109/14
example [9] 6/7 20/5 23/16 59/1
100/8 100/10 100/12 100/17 100/20
Excel [1] 24/23
except [2] 34/24 94/17
exception [1] 8/21
exceptions [3] 8/19 9/1 9/1
exchanged [3] 18/21 28/17 112/7
exchanging [2] 36/8 79/5
Exclusive [2] 50/22 51/5
exculpatory [5] 8/22 9/14 9/18 9/24
10/19
Executive [1] 69/7
exercise [2] 10/2 11/18
exhaustive [1] 96/18
Exhibit [4] 83/1 83/15 107/14 116/22
Exhibit 1228 [1] 83/1
Exhibit 2956 [1] 107/14
exhibits [4] 48/16 65/20 71/18
112/15
exist [2] 42/10 100/7
existed [4] 42/9 53/11 100/6 108/14
existing [1] 33/5
exists [1] 30/12
Exotic [2] 23/9 23/12
expense [1] 48/13
expenses [2] 16/17 87/17
experience [2] 4/10 76/18
experiences [1] 76/17
expert [2] 29/15 30/11
explain [7] 2/14 2/15 3/14 5/16
17/17 28/22 40/16
explained [2] 3/6 107/1
explaining [1] 3/7
explanation [1] 119/6
explanations [1] 28/12
explore [1] 10/11
explored [2] 10/4 10/24
exploring [1] 9/6
extent [1] 3/24
eyes [6] 42/14 57/1 59/25 100/25
105/22 105/23
F
fabricate [1] 22/18
fabrication [1] 16/9
Face [1] 93/7
faced [1] 91/1
facing [3] 92/5 92/10 93/6
fact [27] 13/11 31/13 31/23 32/8
32/12 32/24 32/25 33/1 35/3 40/10
41/3 42/9 42/10 52/15 54/2 55/1
66/14 68/8 75/4 82/2 100/4 100/6
100/7 108/11 112/2 118/24 118/24
factor [2] 11/16 11/17
facts [4] 3/16 3/21 6/2 72/20
factual [2] 3/22 41/3
fair [1] 32/4
fairly [2] 5/4 5/14
fake [23] 15/22 16/1 16/2 16/4 18/20
22/20 22/23 26/13 28/21 33/23 37/5
37/7 37/21 37/21 41/13 41/13 41/14
57/13 77/18 77/19 84/13 84/16 112/8
falling [1] 113/25
false [9] 16/23 17/15 32/22 33/11
35/2 37/14 37/17 73/19 115/9
family [1] 85/8
far [5] 9/13 10/13 35/23 41/11
117/19
faster [1] 7/17
favor [1] 2/24
favorable [1] 9/23
favoring [1] 3/1
FBI [9] 28/6 64/10 64/17 88/12 89/15
90/25 93/7 93/16 120/1
fear [1] 93/7
FEBRUARY [5] 1/12 9/6 117/6 122/10
122/20
Fed [2] 8/10 11/12
federal [3] 45/8 64/20 89/16
federally [9] 16/22 16/23 17/1 34/21
34/24 35/6 37/13 37/14 37/24
federally-insured [6] 17/1 34/21
34/24 37/13 37/14 37/24
feeding [1] 28/19
fees [3] 46/13 46/22 47/1
Feliciano [1] 11/11
Feliciano-Franciso [1] 11/11
fell [4] 32/4 32/5 42/21 45/18
felt [3] 32/6 84/8 102/19
few [5] 29/16 31/1 45/12 53/1 118/7
Fifth [3] 8/11 11/1 11/9
fighting [1] 9/21
figure [6] 24/22 28/16 44/10 113/20
115/6 120/12
figured [3] 18/23 26/7 32/15
file [2] 56/20 109/12
filed [4] 1/5 1/11 1/13 15/25
files [1] 57/11
filled [4] 42/17 43/2 82/21 96/21
final [1] 14/4
finalizing [1] 22/15
finally [12] 16/12 17/8 23/25 28/3
32/11 34/6 37/12 37/25 39/3 46/8
47/25 115/9
Finance [1] 115/15
financial [9] 16/24 17/2 27/17 37/14
38/5 38/15 39/22 40/6 40/9
find [21] 24/16 34/18 37/3 37/10
39/15 40/8 42/12 42/13 49/23 49/24
53/21 71/5 75/5 83/8 83/8 83/12 98/3
100/2 100/20 103/8 103/21
finding [3] 42/15 50/12 115/4
findings [1] 3/22
fine [2] 57/18 99/14
finished [1] 79/17
finishing [1] 22/2
first [18] 2/19 4/7 5/17 7/12 17/13
31/4 32/21 35/13 38/4 39/21 51/1
61/13 63/15 89/20 95/15 109/2 111/11
118/4
five [7] 4/12 4/13 4/13 104/8 104/8
104/9 104/11
five-day [1] 4/13
five-hour [1] 4/13
five-minute [3] 4/12 104/8 104/8
fix [3] 79/15 79/16 102/18
fixed [1] 20/15
fixes [2] 22/1 22/7
fixing [1] 33/18
fledging [1] 76/24
fleshed [1] 85/9
flow [1] 69/5
follow [1] 97/9
follow-up [1] 97/9
followed [2] 24/6 95/21
following [2] 1/3 51/13
follows [2] 49/9 104/17
food [1] 45/21
fool [1] 56/12
footnote [1] 9/17
force [1] 11/25
foregoing [1] 122/17
forget [1] 69/2
form [16] 2/13 2/15 5/6 15/17 15/20
15/25 18/13 18/24 19/4 22/25 23/17
61/2 62/23 82/5 82/6 122/15
Form 941 [2] 15/25 19/4
Form 941s [2] 22/25 23/17
formal [1] 35/18
formalized [1] 8/5
format [1] 74/4
formed [1] 94/5
forms [9] 15/17 18/23 20/3 20/3
28/13 67/22 67/22 68/10 88/7
formula [2] 24/23 25/2
forth [5] 16/10 18/21 81/1 98/2
110/12
FOSTER [201]
Foster's [41] 3/11 3/13 3/15 18/24
19/11 20/22 26/1 26/4 26/8 26/21
27/3 27/8 27/25 28/4 29/9 30/15
30/17 30/21 31/12 38/9 49/14 56/2
56/18 57/3 61/18 73/2 73/9 75/5
97/16 106/4 106/5 106/6 106/13
107/22 108/16 110/13 111/20 111/25
112/16 114/8 114/24
found [6] 13/11 18/12 47/14 56/11
61/6 95/21
foundation [1] 3/4
founded [1] 13/15
four [6] 17/10 21/17 38/3 39/14
98/23 99/5
fourth [1] 41/24
frame [7] 26/13 26/22 27/11 27/15
30/23 111/21 115/18
framed [3] 25/18 27/10 73/20
framing [1] 27/20
Franciso [1] 11/11
fraud [64] 4/17 5/10 7/8 7/19 7/20
15/11 16/21 16/23 17/5 17/5 17/7
17/7 17/9 17/10 17/11 18/7 18/17
19/20 24/12 24/20 26/2 26/4 26/13
26/18 31/8 31/19 32/7 32/8 32/10
32/10 32/14 32/17 32/18 33/16 34/19
34/21 35/9 35/10 36/2 36/10 39/13
39/19 40/20 40/22 40/23 40/24 41/2
41/4 41/13 41/22 45/10 52/25 62/22
67/20 68/22 77/15 77/19 89/24 105/25
106/22 111/2 114/10 116/5 120/10
fraudsters [1] 105/20
fraudulent [19] 15/12 15/16 17/15
35/2 37/8 38/23 39/2 76/4 77/6 78/12
81/15 82/23 83/21 83/25 84/3 84/9
87/24 98/9 113/15
free [1] 79/6
friend [1] 92/14
friendly [1] 3/19
front [7] 5/18 10/7 11/4 11/6 11/10
56/4 85/1
fuck [3] 83/4 113/25 114/8
full [4] 1/12 47/23 93/9 111/4
fully [1] 64/6
funds [11] 50/3 52/20 52/23 68/17
80/7 80/20 97/4 97/8 98/12 99/1
100/1
G
Gaines [100] 20/12 22/20 39/23 41/12
41/15 42/17 42/19 43/1 43/21 44/3
44/25 44/25 45/14 45/19 45/24 46/6
46/23 47/6 47/15 47/18 47/19 47/24
54/8 75/16 76/5 76/6 77/9 77/10
77/15 77/21 77/23 78/8 78/13 79/7
79/13 79/25 80/7 80/21 80/25 81/11
81/11 81/15 81/16 81/19 81/21 81/22
82/1 82/5 82/8 82/10 82/16 82/24
83/3 83/7 84/1 84/21 85/3 85/5 85/6
85/11 86/2 86/5 86/24 87/19 90/11
90/23 94/3 94/9 94/16 95/3 95/4 96/5
96/9 96/19 96/20 97/4 97/5 98/11
99/9 101/15 101/20 102/12 102/14
102/25 103/2 103/12 105/18 116/7
116/25 117/15 117/21 117/23 118/15
118/20 118/21 118/22 118/25 119/3
120/1 120/18
Gaines's [3] 42/22 86/8 117/19
gamesmanship [2] 10/8 10/9
gand.uscourts.gov [1] 1/25
garage [1] 87/16
128
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G
gave [11] 6/17 25/1 25/2 28/12 44/4
44/15 44/21 51/17 93/10 119/3 119/16
GEICO [1] 94/18
Gena [87] 21/8 21/21 22/1 22/6 22/12
23/1 24/7 24/10 24/19 25/1 25/12
25/13 25/17 25/25 26/7 26/21 28/5
30/20 31/5 31/7 31/10 38/9 38/17
39/6 51/1 51/3 51/7 51/14 51/17
51/19 51/22 51/23 52/4 52/6 53/2
54/16 57/7 57/20 58/20 58/23 58/24
59/1 59/15 60/3 60/14 60/22 61/2
61/6 61/13 61/17 61/20 62/9 62/15
62/18 63/1 63/5 64/10 65/2 65/18
65/19 65/19 65/24 65/25 66/14 66/20
66/23 72/16 72/17 73/2 105/18 106/5
106/12 108/24 110/4 110/15 110/20
111/14 111/18 112/3 112/14 112/16
112/24 113/1 113/6 113/10 114/24
115/6
Gena's [10] 25/10 38/13 38/15 63/7
65/9 65/11 72/22 72/24 73/9 115/4
general [5] 7/11 7/15 7/23 8/19 37/1
generally [1] 4/22
gentlemen [4] 14/23 47/25 107/12
120/25
GEORGIA [6] 1/1 1/24 34/12 41/18
41/20 122/7
get [66] 6/22 6/22 7/4 10/20 14/7
16/18 18/23 19/13 19/20 30/17 31/22
32/3 32/3 32/14 32/16 33/16 33/24
35/25 37/8 38/17 38/22 48/15 49/2
61/18 64/23 66/15 68/4 68/12 68/25
69/20 72/24 73/1 73/3 73/3 73/5 73/8
73/14 74/13 77/2 78/19 78/23 79/3
82/14 83/13 83/21 83/25 84/17 89/4
91/9 91/10 92/19 93/14 95/18 98/8
98/16 101/10 101/11 102/5 103/17
104/6 105/19 106/19 113/14 113/17
114/10 117/16
get-go [1] 66/15
gets [2] 52/7 81/19
getting [7] 14/9 33/3 33/6 43/8
67/11 99/10 113/22
gig [1] 83/21
girlfriend [2] 106/4 106/22
give [24] 3/7 9/25 11/18 13/19 24/21
24/24 32/13 42/5 52/7 74/24 78/14
78/15 89/22 89/25 90/2 93/9 95/17
100/8 100/12 103/4 114/7 119/2 119/6
121/3
given [2] 51/18 93/11
gives [1] 106/6
giving [2] 14/3 92/11
go [41] 2/8 7/18 12/20 22/4 35/25
39/19 49/12 51/16 51/20 66/15 66/18
69/1 79/24 79/24 81/21 84/11 85/9
86/1 87/13 87/15 87/25 90/1 93/17
96/15 96/15 97/15 98/23 98/24 99/13
99/15 100/2 102/2 102/21 105/6
107/12 110/12 112/16 116/21 117/4
117/15 119/16
goalposts [1] 114/20
goals [1] 71/10
God [1] 91/3
goes [5] 5/4 20/21 21/1 21/4 84/24
going [66] 4/20 5/3 6/3 6/7 6/14
6/24 10/24 15/1 16/10 23/14 26/2
27/17 36/3 38/1 42/5 43/16 46/1
47/12 48/3 49/16 50/4 57/11 58/19
63/12 64/6 68/3 71/16 80/8 80/9
80/10 81/5 85/9 85/12 87/14 90/10
90/12 90/14 90/16 91/8 91/10 93/1
93/17 97/12 98/13 98/24 99/11 101/9
102/17 103/8 103/14 104/4 104/11
107/2 107/3 110/12 112/14 112/23
112/25 114/6 114/6 114/14 114/16
118/6 118/14 118/14 120/25
gone [2] 6/21 85/23
good [12] 2/4 14/23 14/24 15/7 15/8
24/18 61/5 78/7 88/14 89/9 100/9
100/17
goods [1] 89/11
Google [5] 68/1 68/2 68/2 68/4 85/22
Googled [1] 63/23
Googling [1] 113/19
got [42] 10/14 13/12 16/15 18/17
18/25 19/1 19/8 19/9 20/10 24/15
27/5 28/5 28/13 31/25 32/2 38/14
43/15 44/7 45/20 64/19 64/21 69/23
75/21 79/11 79/18 85/11 86/4 87/1
88/4 88/24 89/11 91/15 94/4 95/16
95/20 111/11 111/12 114/3 114/7
116/9 118/19 118/25
government [86] 1/16 3/10 5/15 9/6
9/9 9/19 10/18 11/6 11/25 12/1 13/9
13/11 13/25 15/2 17/20 33/18 35/15
35/21 49/25 50/18 50/20 52/12 53/1
53/13 53/16 53/18 53/22 54/9 55/3
55/23 56/5 57/18 58/19 59/12 59/22
60/2 60/16 61/24 62/5 62/9 63/13
63/18 63/23 64/21 67/10 68/14 69/4
69/10 70/6 71/1 71/21 71/21 72/3
72/10 72/15 72/16 73/8 75/16 78/16
78/21 80/2 80/14 81/22 82/13 82/19
83/11 84/7 84/23 85/15 86/7 86/25
88/4 92/23 94/24 95/12 98/2 98/19
99/16 99/24 101/18 102/11 102/16
103/1 103/11 103/13 103/22
government's [20] 2/24 9/5 9/17
11/14 15/6 49/17 56/22 57/7 60/15
60/23 70/10 72/8 77/14 82/25 83/15
88/1 101/3 102/3 107/13 116/22
grand [2] 89/16 95/12
grant [5] 4/20 11/25 12/1 12/9 12/21
granting [1] 4/11
great [2] 31/7 61/6
greatest [1] 85/17
ground [1] 42/24
Group [5] 18/18 39/1 63/4 63/16
111/11
grow [1] 76/14
growing [1] 91/16
grown [1] 91/15
guarantee [1] 8/2
guard [1] 119/23
guess [1] 101/2
guiding [1] 8/9
guilty [20] 34/18 37/3 37/11 39/15
45/7 48/21 49/23 49/24 50/5 50/7
52/24 53/21 54/4 56/7 75/10 79/8
79/10 103/22 117/24 120/20
guy [2] 22/2 68/24
guys [1] 33/25
H
hack [1] 26/8
hacked [1] 25/25
hacking [2] 29/1 29/8
had [167]
Hair [1] 59/7
half [3] 15/19 104/5 104/22
halt [1] 42/24
hand [2] 28/25 53/7
handed [1] 89/21
handling [1] 90/16
handwriting [1] 39/24
handwritten [1] 87/20
happen [2] 89/18 118/14
happened [17] 6/20 9/10 10/16 13/8
25/13 28/8 28/9 45/6 50/19 52/9
55/22 60/3 74/7 74/9 84/8 113/1
116/9
happening [4] 52/2 52/18 106/10
112/12
happens [6] 71/13 73/13 74/6 107/24
108/1 112/22
Happy [1] 14/25
hard [2] 14/9 86/16
has [44] 1/11 2/7 7/22 9/3 9/5 14/4
15/9 17/9 25/17 41/5 41/15 43/3
49/18 49/25 50/18 52/12 60/2 61/22
61/24 63/18 70/6 70/10 71/1 71/15
71/21 76/2 76/18 77/10 79/8 81/13
86/7 87/9 88/4 88/11 88/14 88/24
88/25 90/22 91/1 93/13 98/2 103/22
105/15 115/1
have [225]
haven't [6] 52/19 52/21 60/10 60/13
67/3 67/4
having [9] 2/22 9/20 11/11 26/10
30/22 35/22 89/7 97/3 97/6
Hazel [1] 113/13
he [345]
he's [14] 6/14 17/4 17/8 18/3 44/4
44/5 44/16 49/24 54/3 56/7 82/12
88/12 88/15 91/2
head [2] 77/4 99/20
hear [17] 11/8 11/13 15/1 15/2 15/3
28/11 29/11 29/13 30/13 38/3 45/1
82/1 105/10 105/11 105/17 105/22
119/12
heard [74] 7/17 11/20 15/12 15/24
16/15 17/2 17/23 19/11 19/12 19/15
19/19 24/2 24/10 24/11 24/20 28/18
28/25 29/1 29/7 29/15 29/23 29/24
31/2 31/5 31/15 31/25 32/2 33/2
33/15 34/10 35/5 37/23 38/8 38/12
40/6 41/15 41/16 42/16 42/18 43/6
43/15 43/21 43/25 44/3 45/10 54/5
54/7 54/7 62/4 65/15 69/13 76/1 80/4
81/1 81/5 90/17 98/5 101/17 109/5
111/9 113/13 113/22 114/3 115/9
115/10 115/12 115/14 115/16 115/25
116/6 116/25 117/1 119/8 119/11
hearing [4] 80/3 80/14 80/18 122/15
heart [1] 35/19
held [1] 122/10
hell [1] 18/15
help [6] 21/22 24/20 24/24 32/16
115/6 117/16
helped [4] 16/18 18/19 22/18 38/22
helpful [2] 72/12 86/13
helping [1] 111/1
her [80] 2/8 21/22 22/13 22/13 24/15
24/21 24/24 26/23 27/5 28/10 39/23
39/24 42/14 42/17 42/19 43/6 43/15
43/16 44/4 44/5 44/19 44/20 45/1
46/20 46/23 46/24 47/15 47/21 47/21
47/24 48/3 51/1 63/8 63/9 66/24
75/21 75/23 76/3 77/6 77/13 78/5
78/10 78/11 78/12 78/15 79/22 84/10
90/24 90/25 97/8 97/9 98/8 99/4 99/7
100/25 101/8 106/6 109/24 111/22
115/16 116/13 116/15 116/16 116/18
116/18 117/2 117/15 117/16 117/17
119/3 119/14 119/15 119/16 119/17
120/5 120/13 120/13 120/14 120/16
120/18
here [63] 3/12 3/16 4/11 4/17 7/7
7/9 8/9 8/16 9/2 9/15 9/16 10/8
10/24 12/18 17/22 33/1 34/8 34/11
34/23 35/25 36/6 39/6 40/17 41/17
47/9 58/3 59/4 60/11 60/18 63/12
69/24 72/1 75/6 78/15 79/14 79/15
81/3 81/6 81/7 81/22 82/4 82/10
82/12 82/13 82/14 88/2 93/18 98/17
99/24 100/3 100/8 101/25 102/12
102/15 102/15 102/18 102/20 104/12
106/14 114/21 120/14 120/17 121/9
Here's [1] 58/16
hereby [2] 36/2 122/7
hers [1] 40/3
herself [3] 106/16 117/1 119/25
hesitation [4] 97/23 97/24 98/3 98/4
hey [6] 12/8 12/13 52/6 59/7 82/15
97/12
hid [1] 78/8
hidden [1] 120/16
hide [11] 47/6 47/24 86/23 92/13
99/8 109/1 116/15 116/16 116/18
118/21 118/24
hiding [1] 85/4
high [3] 42/9 88/16 100/6
higher [1] 70/18
highest [3] 70/21 100/22 102/24
highly [1] 78/18
him [107] 6/10 6/17 12/9 12/17 12/18
12/23 12/24 13/4 19/2 19/10 19/12
19/13 19/15 19/17 19/19 20/7 20/9
22/20 22/21 23/11 23/15 24/20 24/21
24/24 25/2 26/2 26/10 26/13 26/22
27/15 27/15 27/16 28/1 28/18 28/19
30/22 30/24 32/6 32/12 32/16 33/15
37/3 38/8 38/10 38/12 38/15 45/2
45/3 45/20 45/22 47/4 53/21 54/8
54/10 54/19 54/20 54/22 54/23 54/24
55/15 56/16 64/17 64/18 65/15 65/17
65/23 66/16 67/13 67/14 67/22 69/17
129
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H
him... [36] 72/2 74/3 74/11 74/12
75/17 78/14 79/13 80/11 82/3 82/14
83/7 83/8 83/8 83/12 83/15 84/20
84/21 85/3 85/3 85/5 85/13 85/20
86/25 91/9 93/4 94/17 96/12 106/16
107/7 111/1 111/2 116/10 118/2 118/4
119/11 119/15
himself [3] 33/15 38/22 106/25
hindsight [2] 11/2 11/7
hire [3] 68/12 90/14 112/7
his [113] 3/21 11/1 11/9 16/20 19/9
19/19 20/2 26/8 26/9 26/9 26/10 27/8
28/1 28/2 28/16 30/3 30/3 30/5 30/15
30/16 30/23 31/14 31/21 31/21 32/4
32/6 33/17 34/11 38/14 45/7 45/10
45/10 46/5 46/24 47/16 47/19 52/13
54/9 54/18 54/18 55/12 55/12 56/11
56/20 56/23 57/5 57/8 60/17 61/7
61/22 62/6 62/7 64/5 64/18 64/25
65/3 65/5 68/22 68/24 68/25 72/14
74/13 77/11 77/12 78/8 78/9 78/9
79/9 79/21 79/22 80/3 80/4 80/13
80/13 80/18 81/1 84/2 84/14 84/19
84/19 85/12 85/20 86/5 87/20 88/13
89/21 94/16 98/12 100/25 102/19
103/16 103/16 106/5 106/10 106/11
106/16 106/20 106/21 106/22 106/22
107/7 107/9 107/10 107/11 108/22
109/10 111/8 115/1 115/2 115/2 115/3
118/2 119/11
history [2] 45/10 81/1
hitting [1] 108/1
hold [1] 59/23
Holdings [2] 21/4 21/7
home [3] 34/11 86/14 108/22
Honor [21] 4/24 5/18 6/5 6/16 8/1
11/20 11/23 11/24 13/4 13/10 13/22
14/16 14/18 15/5 48/23 49/13 75/13
104/3 104/24 104/25 105/7
HONORABLE [1] 1/11
hope [4] 2/5 49/19 72/9 121/8
hopelessly [1] 45/11
hoping [1] 26/1
hour [2] 4/13 104/4
house [10] 70/1 70/15 72/24 73/2
89/3 96/6 96/6 106/21 114/24 115/4
how [61] 4/22 4/25 7/4 18/17 19/3
19/6 21/15 21/23 22/17 23/2 24/13
25/5 25/6 25/7 25/16 26/8 27/8 28/11
28/12 28/13 28/14 28/16 30/4 30/10
33/2 33/4 34/1 36/5 37/4 40/24 43/18
44/4 61/18 64/12 69/15 73/20 88/13
88/13 88/17 89/8 90/18 92/7 92/20
92/25 93/11 93/11 101/16 103/25
106/19 107/4 107/5 110/10 111/3
111/3 111/4 112/5 112/6 112/11
112/11 113/4 113/20
however [2] 1/12 5/14
huge [1] 60/15
hullabaloo [3] 87/8 87/22 95/10
hunch [1] 70/24
hunches [3] 86/16 99/3 101/2
hundred [1] 112/19
hundred-plus [1] 112/19
hundreds [3] 28/16 109/25 110/1
husband [5] 43/8 44/15 44/21 117/16
120/5
hustled [1] 68/23
hypothetical [1] 6/8
hypothetically [1] 6/5
I
I'll [9] 6/8 7/8 34/7 38/6 39/17
39/19 52/7 78/14 84/2
I'm [23] 13/19 14/3 27/21 38/1 59/15
66/3 73/12 75/3 75/3 81/5 85/9 88/22
93/17 97/12 98/13 98/24 101/9 103/1
103/8 103/14 104/11 113/9 117/19
I've [1] 93/20
I.D [1] 77/19
IBM [1] 75/20
iCloud [17] 20/2 21/11 23/3 24/8
26/9 26/22 29/5 29/20 30/16 57/22
57/23 58/9 59/19 73/6 110/2 110/10
110/18
iCloud.com [7] 29/12 29/18 57/17
58/2 58/14 58/17 59/21
idea [12] 6/7 18/24 26/10 27/19
30/22 61/22 63/5 66/11 69/22 95/19
106/20 119/22
ideal [1] 100/16
identical [10] 15/20 16/5 16/8 20/3
20/13 21/12 21/24 22/8 22/24 25/3
identification [1] 107/18
identify [4] 9/18 74/2 74/13 110/5
identifying [2] 74/16 74/17
identities [1] 36/15
identity [2] 29/17 92/11
ignorance [3] 98/25 99/15 100/17
ignore [7] 28/4 67/12 67/21 67/24
68/8 68/15 68/16
ignoring [1] 101/2
ill [1] 13/15
ill-founded [1] 13/15
illegal [11] 41/8 41/25 43/6 43/8
43/9 43/11 44/16 44/22 47/23 63/12
100/1
illegality [2] 41/10 97/4
image [1] 85/21
IMEI [1] 107/17
immediately [5] 18/17 20/22 27/6
87/13 108/2
immunity [23] 4/12 4/20 5/1 5/2 5/6
5/7 5/13 5/13 5/23 6/18 7/21 7/21
7/24 8/3 8/4 9/10 10/20 11/25 12/1
12/9 12/11 12/14 12/21
impact [5] 20/5 20/10 58/2 58/8 75/1
impeach [1] 84/14
impeached [2] 79/2 79/4
impermissible [1] 3/18
implications [1] 99/4
implies [1] 95/20
important [21] 10/22 17/22 32/24
33/1 33/10 40/16 42/5 45/7 47/8
70/12 70/14 82/1 86/11 86/12 91/22
97/18 97/20 97/24 98/17 100/23
103/18
importantly [1] 121/5
impose [1] 114/21
impossible [1] 23/21
improper [1] 8/16
included [1] 4/2
including [1] 121/7
incomplete [4] 72/9 73/11 95/20
97/13
inconsistency [1] 2/25
inconsistent [1] 78/25
incorrect [2] 13/23 13/24
incorrectly [1] 55/24
incredible [1] 84/16
incredibly [1] 28/6
incriminating [1] 86/14
indeed [2] 3/1 9/22
indicated [1] 56/23
indication [1] 74/12
indicia [4] 85/4 118/20 118/23
118/24
indicted [4] 9/20 64/12 67/1 116/3
indictment [11] 24/1 35/16 40/6
49/22 53/5 53/6 53/20 63/10 64/14
69/12 101/11
individuals [1] 95/5
infancy [1] 76/24
inference [10] 12/3 12/3 12/7 12/8
12/13 12/14 12/18 12/20 12/24 84/23
inferences [2] 86/15 93/24
infidelity [1] 85/12
Infinite [1] 23/5
influence [1] 37/19
informal [1] 5/13
information [29] 10/13 10/19 13/3
16/11 19/10 19/25 20/21 21/1 23/14
33/7 33/9 33/20 47/22 51/9 63/24
66/23 72/11 72/11 72/19 72/21 73/1
73/4 73/4 73/11 82/17 85/25 117/10
117/12 117/13
initialed [2] 117/5 117/8
initially [1] 110/25
initials [1] 117/9
innocence [1] 72/2
innocent [2] 72/1 92/6
insinuation [1] 73/17
instance [1] 5/7
instances [2] 109/25 110/2
instant [1] 91/7
instead [13] 3/15 10/13 18/2 26/12
26/13 26/25 34/24 36/4 86/15 89/7
89/13 105/23 115/21
institution [4] 16/24 17/2 37/15
37/20
instruct [8] 16/25 17/9 31/3 35/15
35/19 36/13 36/24 40/5
instructing [2] 3/12 9/17
instruction [22] 3/3 3/7 3/12 3/14
6/15 8/13 8/15 9/25 11/18 25/20 42/5
92/19 96/13 97/15 98/25 99/15 99/17
99/22 100/11 100/23 102/23 104/20
instructions [12] 2/8 3/24 4/1 4/3
14/2 14/5 95/18 97/17 101/18 114/15
121/3 121/4
Insurance [1] 94/18
insured [9] 16/22 16/24 17/1 34/21
34/24 35/7 37/13 37/14 37/24
intended [2] 17/18 52/10
intent [11] 3/25 33/15 34/5 35/3
37/19 37/19 37/20 50/1 50/17 52/19
52/22
intentionally [6] 18/2 18/4 38/7
50/8 50/14 52/17
interaction [1] 74/2
interactions [3] 82/7 82/7 82/9
interchangeably [1] 109/6
interested [1] 89/23
interesting [1] 21/8
interests [1] 71/10
intermediary [1] 81/10
interstate [3] 34/7 34/9 34/16
interview [18] 28/11 38/13 64/3 64/7
65/9 84/19 84/25 85/10 92/24 102/6
103/10 107/2 109/5 112/6 117/2
118/18 119/9 119/12
interviewed [5] 13/4 64/10 65/23
66/16 66/19
interviews [3] 48/18 79/1 119/11
intimidate [1] 119/15
intimidated [1] 119/23
introduced [1] 62/18
investigate [1] 5/15
investigating [1] 89/24
investigation [2] 75/1 116/2
investment [1] 27/23
invited [2] 9/7 10/9
invocation [1] 11/9
invoke [1] 10/25
invokes [1] 119/20
involved [43] 5/11 9/19 12/19 17/23
24/13 25/14 26/18 27/2 27/18 31/4
31/13 31/16 31/19 31/23 34/7 34/16
38/19 50/11 52/16 53/2 58/21 58/23
63/13 63/14 63/16 64/1 66/15 69/8
69/22 70/23 74/18 77/16 78/6 81/17
83/25 89/25 96/11 98/9 105/24 110/11
110/23 111/14 116/5
involvement [4] 16/20 31/12 31/14
65/11
involving [1] 4/5
IP [6] 73/2 73/4 96/7 114/23 114/24
115/4
ironic [2] 65/22 66/7
irresponsible [1] 6/19
IRS [16] 15/24 19/9 21/16 27/9 65/18
65/24 65/25 66/5 66/11 66/12 113/11
113/13 113/16 113/16 113/18 113/20
is [351]
isn't [6] 3/12 74/6 74/7 74/8 94/21
96/18
issue [10] 2/6 4/5 5/18 5/20 8/8 9/7
9/7 9/9 37/21 95/13
issued [5] 16/22 34/21 55/4 55/8
55/9
issues [5] 2/12 4/1 14/8 14/20 82/3
it [271]
it's [65] 2/25 3/15 3/19 3/20 4/13
8/3 9/18 10/20 10/22 12/8 12/10
12/20 13/17 13/23 13/24 13/24 32/24
35/22 40/7 40/10 40/23 42/8 43/13
58/2 62/8 66/17 70/8 70/25 71/20
72/2 72/15 74/25 78/7 81/2 81/11
83/3 86/12 88/19 88/20 88/20 88/25
130
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it's... [24] 89/17 89/18 89/18 91/21
92/10 93/13 93/23 93/23 93/24 94/2
94/12 95/4 95/6 97/20 99/9 100/5
101/1 102/24 107/18 107/22 112/23
113/12 118/23 118/23
its [4] 13/25 19/5 76/24 103/23
itself [1] 35/20
J
J.P [1] 1/11
JACKSON [70] 1/6 1/18 15/10 38/3
39/17 39/21 40/25 41/24 42/6 42/13
42/16 43/25 44/10 44/25 45/12 45/25
46/6 46/8 46/19 47/10 48/7 53/3 54/8
76/10 76/25 77/25 80/24 81/8 81/11
81/18 82/9 82/11 82/16 82/21 83/19
83/25 84/10 84/21 84/24 87/3 87/23
88/22 91/11 92/25 93/10 94/2 94/21
95/2 95/16 95/25 96/8 96/11 97/3
97/6 97/9 98/2 99/12 101/9 102/13
103/21 116/6 116/8 117/1 117/14
118/10 119/13 120/8 120/17 120/21
122/12
Jackson's [7] 41/6 48/1 75/14 75/17
90/7 96/6 118/18
jello [1] 118/3
Jennifer [4] 61/11 61/17 106/3
106/15
Jesus [1] 20/19
jewelry [2] 32/1 70/1
Jim [2] 55/17 57/14
job [3] 76/11 76/16 115/18
John [53] 39/23 42/17 42/19 43/21
44/3 44/25 44/25 45/24 46/6 46/23
47/6 47/15 47/18 47/24 54/7 75/16
76/5 77/8 77/20 78/8 78/13 79/25
81/11 81/16 82/8 82/16 82/24 83/3
84/1 85/6 86/2 86/5 86/8 90/22 91/3
94/16 95/3 95/4 96/5 98/11 99/9
101/15 101/20 102/12 102/25 103/2
103/12 116/7 117/15 118/25 119/3
120/1 120/17
join [2] 50/8 52/17
joined [8] 18/2 18/4 18/5 18/7 36/12
37/2 37/4 38/7
joining [2] 37/8 38/17
joke [1] 74/4
JPB [2] 1/5 122/12
judge [24] 1/11 4/11 8/17 14/9 14/13
16/25 17/9 17/17 25/19 31/3 35/15
36/13 36/24 40/4 42/5 42/7 50/9
53/24 71/4 71/8 92/20 98/16 105/2
114/16
Judge Boulee [9] 17/9 17/17 31/3
35/15 36/13 36/24 40/4 42/5 42/7
Judge Martin [1] 8/17
judicial [1] 3/21
judith [4] 1/22 1/25 122/4 122/23
July [1] 44/13
jump [1] 82/18
June [20] 21/11 21/17 21/20 22/7
25/14 46/20 46/23 47/9 47/14 47/17
47/21 50/21 51/3 57/4 59/1 62/10
63/6 63/14 66/18 113/7
jury [39] 1/10 2/7 2/8 3/12 11/2
11/4 11/6 11/8 11/10 11/13 12/4
12/25 13/17 14/21 14/23 48/15 49/7
49/10 71/17 89/16 92/19 95/12 96/13
97/15 97/17 99/22 100/23 101/18
102/21 102/23 104/9 104/15 104/18
104/20 105/4 107/13 112/17 120/25
121/10
just [70] 2/22 3/15 4/9 4/21 5/20
6/7 6/17 8/8 11/24 14/6 14/7 14/18
16/8 19/1 19/23 24/21 25/10 26/24
28/4 28/5 28/7 28/18 28/19 28/19
32/24 33/25 33/25 34/25 40/8 41/2
41/8 44/2 44/20 44/20 46/18 47/18
50/15 53/16 59/2 59/7 63/6 64/2 66/2
67/6 68/2 73/16 73/22 74/24 77/5
81/6 85/1 85/8 87/9 87/22 92/15
93/23 95/6 96/17 98/13 98/20 98/25
99/3 103/10 106/10 107/24 108/1
114/10 119/18 119/24 120/5
justice [4] 4/17 5/4 6/22 10/2
K
Kaushal [2] 1/16 112/18
keep [3] 44/3 47/18 98/6
keeper [2] 77/9 116/7
keeps [1] 106/10
kept [2] 11/1 113/3
key [2] 96/19 96/23
keyboard [1] 54/23
kid [1] 78/10
kids [5] 70/14 70/19 91/14 91/15
114/13
kind [8] 35/18 36/3 38/20 41/7 76/19
83/2 102/8 118/2
kinds [1] 114/12
knew [92] 19/12 25/16 28/8 29/24
30/2 30/5 30/9 33/16 33/20 36/11
36/18 36/18 36/21 38/18 38/21 39/4
40/25 41/2 41/24 41/25 42/1 42/4
42/7 42/13 42/16 42/20 42/24 43/5
44/16 44/17 44/17 44/22 45/13 45/22
45/23 46/8 47/4 47/17 47/23 48/2
48/3 48/13 50/16 50/19 52/1 52/14
54/10 62/24 64/7 64/8 64/10 64/11
64/15 65/24 65/25 67/1 67/18 68/16
71/2 80/20 80/24 82/11 83/21 84/2
84/21 84/22 86/16 87/3 93/1 94/11
99/5 99/7 99/12 99/19 99/21 100/20
100/24 107/5 108/14 109/3 109/10
116/1 116/8 116/9 116/10 116/14
119/4 119/5 120/2 120/3 120/12
120/15
knock [6] 84/24 85/10 88/5 88/10
88/18 102/4
know [126]
knowing [4] 42/12 71/6 92/6 100/1
knowingly [4] 17/13 38/4 39/22 40/8
knowledge [17] 3/25 6/18 26/10 41/6
41/6 42/6 42/13 50/10 82/22 97/3
97/3 97/6 99/18 99/25 100/4 100/16
100/18
known [3] 5/6 66/13 93/24
knows [14] 26/1 61/17 68/3 82/23
85/3 85/3 85/5 85/7 87/23 88/12
88/13 106/9 106/11 120/11
L
ladies [4] 14/23 47/25 107/12 120/25
laid [3] 9/5 42/23 101/17
language [1] 83/2
laptop [18] 29/20 56/10 56/10 56/13
56/17 56/21 56/25 57/3 57/4 57/11
72/15 85/21 96/10 108/18 108/19
108/22 109/5 109/9
large [4] 79/19 88/7 97/7 102/8
Las [1] 56/11
last [10] 3/17 4/8 5/18 5/19 5/22
34/6 34/17 35/7 73/18 74/17
later [12] 3/1 19/8 21/17 38/12
55/25 59/10 59/18 67/14 73/7 95/25
96/1 118/6
laundering [13] 17/8 38/1 38/2 39/15
39/18 46/7 49/21 49/24 98/14 101/13
101/24 117/25 120/18
law [14] 3/8 3/13 3/14 3/25 4/3 8/14
13/23 13/24 35/23 48/21 64/3 84/25
88/18 116/1
lawyer [1] 64/25
lawyers [1] 36/1
lay [1] 101/23
learned [1] 109/1
learning [2] 42/11 100/14
least [8] 36/22 37/2 55/12 57/2
61/21 74/1 85/18 87/25
leaves [2] 41/23 60/14
Lee [2] 20/25 58/10
left [9] 8/20 22/25 48/17 53/7 59/1
103/9 106/17 106/20 119/19
left-hand [1] 53/7
legal [1] 70/22
legit [1] 34/3
legitimate [11] 22/4 63/11 64/18
68/24 83/17 84/4 111/1 113/21 116/13
116/21 117/16
legitimately [1] 73/24
Leigh [1] 1/19
lender [3] 16/21 33/10 37/20
lenders [4] 17/2 34/13 37/18 115/15
length [1] 44/1
less [1] 69/15
lesser [1] 79/6
let [14] 2/18 11/13 14/8 56/12 62/17
66/18 82/2 86/25 87/25 96/13 101/16
102/14 103/3 114/20
let's [26] 7/6 13/18 49/21 56/5
57/25 60/1 60/22 63/22 64/4 69/5
79/24 81/21 84/11 88/10 90/7 90/18
94/1 97/15 99/13 99/15 100/2 100/12
103/5 103/9 103/12 104/8
letter [5] 5/6 5/13 7/21 7/24 8/2
letterhead [1] 77/19
letting [1] 11/8
level [9] 70/15 70/16 70/20 70/22
98/3 98/22 101/8 102/23 102/24
levels [1] 5/3
liar [3] 80/16 98/11 116/14
license [1] 115/3
licenses [2] 77/18 115/1
lie [5] 43/6 43/7 43/7 43/12 119/25
lied [3] 43/25 116/10 119/22
lies [1] 78/13
life [8] 27/8 45/7 78/5 78/9 79/22
90/25 98/8 101/8
like [49] 4/16 4/21 22/4 32/1 32/6
45/2 46/18 49/5 62/5 68/3 68/5 68/6
70/3 70/3 70/14 71/19 73/21 75/24
77/2 77/5 78/4 78/6 80/16 81/10
81/15 83/16 83/24 86/12 86/12 89/7
89/22 89/25 90/2 91/6 91/22 92/13
92/15 92/15 92/21 94/11 95/24 98/7
99/9 99/18 104/5 107/3 110/25 117/25
118/3
limit [1] 91/7
limited [1] 72/19
Linda's [1] 59/7
line [2] 1/10 58/22
lined [1] 28/7
link [4] 3/5 56/19 56/20 60/15
linked [2] 30/15 84/18
list [10] 19/8 63/8 63/9 63/15 63/18
94/25 96/18 111/17 111/22 112/23
listed [2] 63/17 115/1
listen [7] 44/2 44/5 48/17 62/4 63/7
69/1 69/2
listened [1] 117/20
listening [1] 112/1
listing [1] 3/15
literally [1] 56/14
little [13] 3/19 10/11 57/25 59/10
79/24 79/25 79/25 82/18 84/13 85/9
87/7 88/8 112/18
live [1] 60/24
lived [2] 76/2 96/5
Lively [4] 2/20 2/23 3/2 3/6
LNK [2] 56/20 109/12
loan [55] 15/18 16/18 16/21 16/22
17/4 18/18 19/5 19/13 19/23 20/6
20/8 20/11 20/17 24/1 24/12 24/20
33/2 33/3 33/6 33/12 34/4 34/14 37/8
37/21 38/23 39/2 39/19 40/23 41/12
41/13 41/16 42/18 42/20 47/7 63/15
69/12 76/5 77/6 78/12 81/15 82/6
82/11 82/20 82/22 83/17 83/20 83/25
84/5 89/24 98/9 115/23 116/5 116/17
116/21 117/16
loans [29] 15/13 15/15 16/20 18/8
24/16 31/22 32/21 33/24 34/17 34/21
36/10 37/7 42/17 45/13 46/24 47/16
63/10 63/24 67/19 69/18 69/23 87/1
87/11 90/23 93/19 96/12 111/24 112/9
116/16
location [2] 42/2 46/10
locked [1] 38/14
log [3] 57/5 106/14 115/5
logged [5] 29/20 30/9 56/18 56/24
57/3
logging [1] 57/16
login [1] 73/3
logins [1] 73/4
LOL [3] 20/18 24/14 27/5
long [13] 4/22 7/4 10/5 38/7 44/9
44/24 45/9 45/10 48/16 54/9 88/12
103/25 106/19
longer [2] 3/10 8/6
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look [38] 2/8 2/11 14/4 21/10 22/4
33/17 34/3 36/4 46/18 48/1 48/16
56/19 59/23 59/24 62/3 62/21 67/10
80/16 92/15 93/10 100/2 100/10
103/12 107/3 107/3 107/13 107/15
110/12 112/8 112/17 113/15 113/20
115/7 116/22 117/25 120/13 120/13
120/13
looked [4] 26/17 27/16 85/24 86/10
looking [3] 27/1 77/4 111/23
losing [1] 76/16
lot [10] 24/10 31/5 31/15 31/25
71/15 73/24 74/6 80/2 102/9 108/4
lots [2] 24/3 24/4
love [1] 78/16
low [4] 76/23 88/5 102/7 102/8
lower [1] 79/6
lucky [1] 28/6
ludicrous [5] 66/15 66/16 66/17
72/16 72/17
lunch [5] 104/6 104/7 121/1 121/8
121/12
lying [2] 80/17 117/15
M
machine [1] 122/9
made [25] 6/25 11/7 19/2 20/10 27/14
27/24 35/17 46/20 50/5 51/15 52/22
54/3 60/14 73/19 75/1 80/14 84/19
85/16 86/2 101/5 102/9 106/2 107/17
115/10 116/20
made-up [1] 85/16
main [3] 4/17 5/4 6/22
make [34] 2/9 2/11 11/20 12/15 12/18
12/22 19/10 25/21 40/1 46/24 52/6
52/7 57/9 64/3 76/19 78/6 78/21
80/15 83/22 91/6 91/7 92/7 92/15
94/20 101/8 106/11 107/3 107/3 108/3
111/23 112/8 112/13 113/6 113/20
makes [8] 11/17 26/5 26/20 27/11
30/25 35/23 60/6 113/15
making [10] 22/15 25/8 28/7 35/20
37/13 50/1 50/6 107/11 107/21 117/25
man [5] 78/5 79/18 79/19 79/19 83/21
manage [1] 46/17
management [16] 20/21 45/15 45/16
46/13 46/22 47/6 47/13 76/12 76/13
76/23 82/20 86/23 87/10 88/6 93/20
117/2
manager [2] 75/19 76/19
manipulating [2] 19/13 19/16
manipulative [3] 116/7 116/14 117/15
many [4] 43/18 91/12 91/15 110/10
mapped [1] 55/24
Marie [2] 77/21 77/21
mark [1] 93/3
marriage [5] 61/3 61/15 77/12 78/9
78/10
marriages [1] 61/4
married [5] 24/12 60/24 61/2 61/3
61/9
Marshall [9] 1/18 75/12 105/1 116/21
117/20 118/4 118/18 120/7 120/24
Martin [1] 8/17
massive [1] 105/24
matches [1] 43/3
material [2] 32/23 35/3
materials [1] 48/9
matter [9] 3/1 4/11 36/17 36/20
40/11 41/3 87/23 108/6 122/11
matters [3] 36/21 40/5 108/15
may [23] 1/5 1/9 22/6 25/20 29/16
51/2 54/2 54/2 57/2 58/20 61/2 61/8
61/8 62/4 62/5 79/11 80/6 85/19 91/8
94/13 100/2 100/20 113/1
maybe [16] 9/10 26/1 49/5 57/18 67/5
75/2 75/20 76/22 82/9 88/25 90/18
91/7 92/10 92/13 110/25 114/6
me [28] 2/18 4/6 4/19 6/9 6/11 6/12
10/7 14/8 19/17 19/17 44/15 44/21
44/21 62/17 66/18 68/5 79/8 87/25
90/2 92/3 96/13 97/20 98/7 101/16
102/14 103/4 120/5 122/15
mean [13] 54/3 62/7 67/16 67/19
87/14 87/23 88/20 93/7 96/11 98/17
102/7 108/12 114/9
means [12] 10/17 17/18 17/25 32/24
35/10 40/20 42/11 49/25 70/18 82/23
95/17 114/10
meant [4] 2/14 39/7 79/20 91/18
medical [2] 81/1 82/3
meet [1] 70/6
meeting [5] 88/5 88/24 89/1 90/4
102/4
meetings [1] 79/1
members [2] 35/17 85/8
men [2] 89/2 89/14
mention [1] 93/2
mentioned [9] 4/8 4/8 37/12 90/14
93/2 110/20 111/17 112/15 118/18
mentions [1] 95/11
merely [3] 3/20 9/20 71/9
message [6] 24/14 26/15 27/4 27/6
66/2 110/16
messages [22] 26/16 26/17 46/23
51/12 54/18 54/25 58/24 58/25 60/13
61/17 62/1 65/4 66/22 67/2 86/5
86/19 86/19 96/24 96/24 110/1 110/18
111/24
messed [1] 102/18
messing [1] 113/3
met [1] 103/22
metadata [3] 65/20 112/15 112/24
Metadore [1] 59/7
Mickies [1] 23/25
middle [4] 5/23 6/23 60/7 60/7
might [6] 32/15 56/24 82/2 89/2
89/24 91/3
miles [1] 107/25
million [2] 15/15 69/14
millions [1] 114/3
mind [4] 44/3 44/6 67/7 103/7
mine [2] 81/23 92/4
minor [3] 36/25 95/13 104/19
minute [6] 4/12 66/19 93/3 93/3
104/8 104/8
minuter [2] 49/5 49/5
minutes [9] 44/10 49/1 59/8 59/18
59/20 104/2 104/9 104/11 121/1
miscarriage [1] 10/1
missing [6] 4/5 8/12 8/15 60/15
95/16 96/15
misstating [1] 13/23
mistake [2] 11/8 22/10
mistaken [1] 92/10
mistakes [1] 92/7
mistress [1] 106/6
ML [4] 23/9 23/10 23/12 23/12
mobile [3] 107/10 107/14 107/17
moment [4] 4/19 5/22 5/25 10/5
moments [1] 45/7
money [118] 16/15 16/16 16/18 17/8
17/19 19/2 19/20 20/11 25/9 27/17
27/22 28/1 28/2 32/1 32/12 32/13
32/14 32/16 33/16 37/25 38/2 38/17
38/19 38/21 38/25 39/5 39/7 39/12
39/14 39/18 40/19 40/21 41/1 41/7
41/22 41/25 42/24 43/5 43/7 43/8
43/10 43/10 43/12 44/1 44/4 44/7
44/11 44/17 44/18 44/22 45/21 45/23
46/7 46/20 47/5 47/15 47/17 47/18
47/23 48/2 48/4 48/4 48/8 48/10
49/21 49/24 50/21 50/24 51/16 51/16
51/18 52/7 52/8 52/10 64/16 64/16
64/17 64/18 68/4 68/21 68/22 68/25
68/25 69/5 69/6 69/6 69/9 69/16
69/20 69/23 69/25 76/19 77/1 77/1
81/20 86/23 87/2 87/9 87/11 90/10
97/8 98/14 99/1 99/11 101/13 101/24
113/23 114/5 117/21 117/24 118/25
119/3 119/5 119/7 120/6 120/15
120/15 120/18
Montgomery [3] 46/1 47/13 118/17
monthly [2] 88/5 102/8
months [3] 5/17 30/22 96/1
Moore [1] 1/17
more [31] 2/20 3/19 4/13 7/9 8/5
11/3 15/14 15/14 19/7 32/3 35/11
38/2 43/15 49/5 49/18 55/2 60/1
69/10 69/24 71/18 71/18 71/20 73/10
73/14 75/2 84/11 85/25 94/2 98/13
109/18 114/7
morning [11] 2/4 2/17 4/7 9/5 14/23
14/24 15/7 15/8 88/21 88/22 90/24
most [7] 9/23 45/6 70/12 97/20 97/24
98/17 100/22
mouth [1] 3/22
move [8] 2/18 39/17 86/23 87/1 93/13
93/14 98/12 114/20
moved [3] 16/17 19/23 99/7
moves [2] 19/1 68/4
moving [3] 43/9 43/10 116/6
Mr. [77] 3/11 3/13 3/15 3/24 4/20
6/4 6/6 6/9 8/2 10/25 12/2 12/2
12/11 17/11 17/13 17/24 28/4 29/15
33/14 34/8 34/18 34/20 35/8 36/11
36/25 37/11 37/13 37/25 42/22 43/1
49/23 50/17 52/24 53/13 54/10 56/2
56/6 56/23 57/3 67/1 71/6 71/25 72/1
73/9 75/12 77/10 77/15 77/23 79/7
79/13 80/7 81/3 81/19 83/7 85/11
87/19 94/3 94/9 96/9 97/16 102/14
105/1 106/2 106/4 106/5 106/16
109/14 112/18 116/21 116/25 117/19
117/20 117/21 118/4 118/18 120/7
120/24
Mr. Berne [1] 12/11
Mr. Dixon [6] 4/20 6/4 6/6 6/9 8/2
10/25
Mr. Dixon's [1] 12/2
Mr. Foster [28] 3/24 17/11 17/13
17/24 33/14 34/8 34/18 34/20 35/8
36/11 36/25 37/11 37/13 37/25 49/23
50/17 52/24 53/13 54/10 56/6 56/23
67/1 71/6 71/25 72/1 81/3 106/2
106/16
Mr. Foster's [10] 3/11 3/13 3/15
28/4 56/2 57/3 73/9 97/16 106/4
106/5
Mr. Gaines [17] 43/1 77/10 77/15
77/23 79/7 79/13 80/7 81/19 83/7
85/11 87/19 94/3 94/9 96/9 102/14
116/25 117/21
Mr. Gaines's [2] 42/22 117/19
Mr. Kaushal [1] 112/18
Mr. Marshall [8] 75/12 105/1 116/21
117/20 118/4 118/18 120/7 120/24
Mr. Persinger [2] 29/15 109/14
Mr. Ricky [1] 12/2
Ms. [84] 2/7 3/17 4/8 9/22 11/22
13/3 13/19 15/4 28/10 31/6 38/3
39/21 40/25 41/6 41/24 42/6 42/13
42/16 43/25 44/10 44/25 45/12 45/25
46/8 46/19 47/10 48/1 48/7 49/12
54/8 75/17 75/22 76/10 76/25 77/25
78/15 79/18 80/24 81/18 82/21 84/10
84/21 87/3 88/22 90/7 91/11 92/25
93/10 94/2 94/21 95/2 95/16 95/25
97/3 97/6 97/9 97/21 98/2 99/12
101/9 102/13 103/21 103/25 105/6
106/2 106/8 109/12 109/22 110/20
111/9 111/10 111/17 112/1 112/14
113/8 114/12 116/8 117/1 118/10
118/18 119/13 120/17 120/23 120/24
Ms. Chaiken [11] 3/17 4/8 9/22 13/19
15/4 75/22 78/15 79/18 103/25 105/6
120/23
Ms. Durrett [2] 11/22 13/3
Ms. Jackson [48] 38/3 39/21 40/25
41/24 42/6 42/13 42/16 43/25 44/10
44/25 45/12 45/25 46/8 46/19 47/10
48/7 54/8 76/10 76/25 77/25 80/24
81/18 82/21 84/10 84/21 87/3 88/22
91/11 92/25 93/10 94/2 94/21 95/2
95/16 95/25 97/3 97/6 97/9 98/2
99/12 101/9 102/13 103/21 116/8
117/1 118/10 119/13 120/17
Ms. Jackson's [5] 41/6 48/1 75/17
90/7 118/18
Ms. Mueller [1] 2/7
Ms. Murray [1] 106/8
Ms. Pyfrom-Foster [1] 111/10
Ms. Webster [15] 28/10 31/6 49/12
97/21 106/2 109/12 109/22 110/20
111/9 111/17 112/1 112/14 113/8
114/12 120/24
much [10] 8/6 33/4 63/14 67/24 69/15
69/19 69/23 81/10 85/8 99/19
Mueller [1] 2/7
132
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M
multiple [4] 5/3 18/21 116/6 116/10
Murray [5] 61/11 61/17 106/3 106/8
106/16
must [15] 27/18 50/11 55/6 56/7
57/23 60/24 60/24 63/25 67/15 70/23
70/25 71/5 93/24 94/14 113/10
my [44] 2/21 3/1 4/10 4/25 7/12 7/13
10/2 11/16 11/17 11/18 32/16 44/15
44/15 44/20 48/23 67/15 75/25 76/7
76/16 79/12 83/4 83/22 84/18 85/21
86/10 86/14 86/16 86/20 89/21 89/23
91/3 91/14 92/11 92/14 92/15 93/6
93/22 94/10 97/12 99/21 99/25 101/19
113/25 120/5
Myerson [1] 10/6
myself [2] 75/24 91/10
N
name [8] 20/4 25/10 74/14 74/17
87/20 89/21 112/16 115/24
named [3] 35/16 68/24 115/14
names [8] 16/8 16/11 19/9 36/15 53/7
53/12 55/9 108/7
narrative [1] 3/21
national [2] 15/11 42/22
nature [8] 42/2 46/10 79/9 82/24
84/3 88/17 93/10 100/1
Navy [1] 64/20
necessarily [1] 88/16
necessary [1] 66/8
need [27] 6/1 6/2 7/10 7/18 14/19
17/25 31/11 33/17 40/8 41/9 48/1
65/16 65/18 66/4 83/20 92/2 97/18
99/24 102/24 103/15 104/1 106/15
108/12 108/20 109/18 113/9 120/12
needed [14] 7/7 18/23 18/24 21/22
46/18 48/10 49/1 65/17 65/18 77/1
108/18 113/5 119/5 119/16
needing [1] 105/23
needs [4] 18/2 20/15 41/6 41/8
nefarious [1] 88/20
Neither [1] 10/21
never [31] 6/13 7/16 9/11 9/11 35/25
36/2 41/16 45/14 45/15 47/5 47/5
52/9 55/10 66/9 68/16 74/25 75/1
75/1 77/12 77/21 81/22 82/2 84/6
84/7 86/11 93/2 93/16 95/21 101/5
113/17 114/1
nevertheless [1] 10/23
new [1] 21/18
news [2] 63/24 64/13
next [18] 4/5 20/1 32/22 44/2 51/20
57/22 58/1 58/5 58/7 58/8 58/13 59/6
59/12 62/25 63/2 108/2 117/5 117/9
nickel [1] 74/5
nickels [1] 74/6
night [3] 3/17 4/8 5/19
nine [2] 5/16 55/12
no [96] 1/18 1/4 2/25 3/10 6/6 8/2
9/3 26/5 26/20 27/12 28/25 29/2 29/3
29/4 29/5 29/8 29/8 29/9 29/21 30/25
33/22 35/23 39/11 41/15 42/18 43/22
44/19 44/20 46/16 46/17 46/17 52/3
52/3 52/5 52/9 52/10 54/18 56/15
61/5 61/22 63/11 65/16 67/1 68/10
68/12 69/8 69/9 70/3 72/11 74/2
74/19 74/20 74/21 74/22 76/9 76/15
76/21 76/25 78/1 79/8 84/4 87/3
90/25 94/10 94/19 95/19 96/3 96/19
96/21 96/23 96/24 96/24 96/24 96/25
96/25 97/2 97/2 97/3 97/6 97/9 98/8
99/2 99/12 101/1 101/6 108/25 109/8
109/8 116/12 116/12 117/12 117/12
117/13 118/9 120/4 122/12
no-good/bad [1] 61/5
nobody [1] 111/13
non [4] 57/21 58/3 58/17 60/11
non-stamped [4] 57/21 58/3 58/17
60/11
noncontroversial [1] 3/2
none [11] 15/24 16/13 41/19 68/13
84/18 86/10 96/21 97/1 112/25 114/15
118/17
NORTHERN [6] 1/1 4/11 34/12 41/17
41/19 122/6
not [200]
not-stamped [1] 58/15
note [6] 1/17 8/1 8/18 11/24 14/18
40/4
noted [3] 3/17 9/16 10/7
notes [2] 9/20 9/22
nothing [10] 13/22 28/8 28/22 43/8
43/9 70/3 86/21 95/1 97/2 107/5
now [46] 2/19 5/18 15/1 24/10 35/8
40/15 44/6 49/17 50/4 52/12 52/25
55/3 55/14 56/5 57/2 57/18 58/19
60/1 60/22 62/9 64/8 64/24 66/2
66/17 70/8 71/15 74/4 79/7 81/8 83/3
85/16 92/4 98/15 104/9 104/11 106/1
108/4 108/17 109/22 110/20 113/8
114/22 115/3 118/18 119/9 120/25
Now,I [1] 88/11
number [8] 1/10 1/10 90/3 98/22 99/5
107/10 107/18 107/18
numbers [16] 16/8 16/10 21/15 21/19
21/22 21/23 22/8 23/1 23/2 25/5 25/6
25/15 25/16 37/21 46/4 113/4
numerous [1] 10/10
O
obligated [1] 97/10
obligation [1] 95/24
obtain [1] 86/8
obtained [5] 60/16 67/2 86/11 87/21
97/1
obtainer [1] 84/17
obtaining [1] 51/5
obviously [7] 2/16 11/14 14/2 33/21
37/20 40/7 87/19
occasion [3] 10/10 10/11 37/2
occasions [1] 51/18
occurred [1] 6/18
October [1] 23/20
odd [1] 94/8
off [7] 2/19 19/2 30/9 42/23 46/24
47/15 119/23
offense [5] 34/7 98/16 101/22 101/23
103/23
offer [1] 7/20
offered [1] 8/3
office's [1] 5/10
officer [4] 13/17 91/21 91/25 104/9
offices [1] 122/7
official [8] 1/3 1/5 1/6 1/11 1/19
1/22 122/5 122/24
oh [7] 44/20 68/1 68/3 91/3 91/17
92/13 118/6
okay [13] 14/13 14/17 52/7 57/18
59/9 59/17 63/7 86/4 87/5 87/11
101/24 104/13 121/1
once [2] 3/9 97/10
one [63] 2/6 4/19 5/2 8/1 8/4 8/9
10/10 11/1 12/5 12/15 17/12 17/22
21/14 22/14 23/18 24/5 27/7 36/10
36/22 37/2 41/5 43/1 44/4 44/5 45/6
47/8 48/11 48/13 50/5 53/17 53/19
54/3 54/17 54/18 55/5 56/8 57/7 58/6
58/7 58/11 58/16 59/12 59/12 60/1
61/5 61/22 65/13 65/17 66/12 67/1
69/18 78/14 82/18 82/21 85/18 86/21
88/2 97/21 98/18 102/14 112/19
115/15 116/15
ones [19] 7/6 16/4 24/2 53/3 53/10
53/11 55/11 55/15 56/9 59/16 59/16
62/11 63/17 70/14 83/21 98/23 108/17
110/5 110/6
online [1] 18/12
only [31] 1/5 1/10 13/11 20/9 24/1
24/5 26/18 28/15 28/23 30/24 31/11
36/8 36/25 39/17 39/25 40/1 43/12
44/12 44/14 46/5 48/20 53/19 54/5
60/6 60/6 64/22 66/12 70/20 72/2
75/9 119/4
open [2] 8/21 122/10
opening [3] 28/10 29/11 49/15
openly [1] 77/6
operating [1] 72/19
operation [1] 117/6
Operations [2] 20/25 58/10
opinion [1] 11/17
opportunity [1] 89/25
opposite [3] 10/21 52/15 113/12
order [4] 2/2 27/11 57/20 106/14
orders [1] 97/2
organizer [1] 94/14
Orr [4] 2/20 3/1 3/1 3/18
other [42] 7/18 8/1 8/18 8/25 11/3
12/6 12/17 16/6 17/23 19/24 28/25
31/1 31/4 31/13 31/23 36/15 36/18
47/8 51/18 54/11 61/10 63/17 66/5
68/11 69/19 72/11 72/22 72/23 77/15
78/20 81/8 81/17 81/21 94/15 95/5
103/10 103/12 109/20 110/7 114/21
115/7 116/11
otherwise [3] 14/14 44/19 84/4
our [9] 5/10 6/23 8/9 12/10 20/8
72/7 105/21 106/18 108/24
out [59] 9/5 13/11 13/18 17/19 18/23
20/22 24/22 26/7 26/25 28/16 28/16
32/4 32/5 32/6 32/9 42/15 42/17
42/21 43/2 44/10 45/18 46/3 47/14
49/19 61/6 64/18 68/24 72/12 80/15
81/2 82/21 82/25 85/9 85/23 86/1
86/3 87/11 87/15 89/21 93/5 94/18
95/21 97/11 97/21 98/9 99/11 99/16
101/17 101/23 102/14 103/7 104/22
113/3 113/20 113/25 114/11 115/4
115/6 120/12
outlandish [1] 73/20
outside [2] 77/11 78/10
overall [1] 81/9
overlaying [1] 93/21
overnight [1] 4/6
owed [5] 6/10 27/23 32/12 32/13
64/17
own [20] 19/11 19/19 26/23 27/25
28/4 31/14 33/17 42/17 47/19 48/1
48/17 51/2 57/1 59/25 63/7 76/17
97/24 105/22 105/23 111/22
owner [1] 94/14
owners [3] 66/9 68/11 108/8
ownership [2] 42/2 46/10
P
p.m [6] 104/15 104/16 104/17 105/4
121/10 121/12
package [1] 100/13
package's [1] 100/16
page [4] 1/10 104/21 104/21 117/4
pages [3] 80/15 95/17 95/17
paid [6] 20/10 27/15 27/15 63/8
87/17 117/7
painfully [4] 44/9 44/9 44/24 54/9
Painting [1] 21/3
pair [1] 61/14
pandemic [5] 15/14 42/22 45/22 76/15
88/25
paper [3] 48/16 71/15 71/18
paperwork [2] 5/4 19/13
Parker [2] 21/4 21/7
part [15] 4/2 14/2 27/14 36/25 39/4
46/9 65/22 78/9 80/3 81/24 84/9
88/18 96/2 99/6 100/5
partial [1] 1/12
participant [2] 69/11 71/6
participate [2] 76/4 114/9
participated [4] 15/10 17/14 32/19
50/14
participating [1] 39/18
participation [2] 39/12 68/22
parties [3] 12/5 12/14 81/9
partners [2] 45/25 46/6
party [3] 8/10 12/7 12/17
passcode [1] 106/9
passing [1] 28/23
password [3] 30/7 30/8 106/6
passwords [2] 29/9 29/10
past [3] 56/3 59/24 67/10
pattern [19] 19/24 20/20 21/3 21/4
21/25 23/5 24/6 57/20 58/16 58/21
59/14 59/22 60/1 60/2 60/6 60/20
109/22 109/23 109/24
pause [1] 74/24
pauses [1] 119/18
pay [4] 27/19 46/24 47/15 97/18
PayCard [7] 55/10 106/25 107/5 107/6
107/11 107/23 112/9
133
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P
PayCards [5] 55/3 55/5 55/8 70/2
106/24
Paycheck [5] 15/13 18/11 18/12 48/2
48/14
paying [1] 38/15
payment [6] 38/8 38/10 39/6 39/9
39/12 94/18
payments [8] 27/14 27/22 46/12 46/15
46/24 51/6 69/19 118/19
payroll [30] 16/7 16/14 16/16 19/7
19/10 21/12 21/13 21/18 22/7 24/15
27/8 33/4 33/6 39/10 39/11 46/14
46/17 48/12 48/13 59/3 80/10 80/20
87/13 90/12 107/3 116/24 117/7
117/22 117/24 117/25
PDF [1] 1/3
people [51] 16/18 17/23 18/4 30/5
31/4 31/13 31/16 31/23 35/12 35/16
35/25 36/5 36/5 36/5 36/18 42/23
43/10 45/21 52/21 53/1 53/8 53/11
53/13 53/16 54/6 54/11 55/9 61/10
71/10 74/1 81/3 81/17 87/18 89/4
89/8 91/12 92/8 92/17 93/14 105/16
106/9 106/11 106/19 108/7 108/9
108/9 114/14 115/12 116/1 116/11
120/9
people's [1] 55/9
percent [1] 32/7
percentage [5] 28/2 28/2 107/7 114/1
114/8
performed [1] 18/1
perhaps [2] 4/13 9/9
period [5] 1/7 21/20 45/13 58/22
61/19
perpetuate [1] 119/6
Persinger [4] 29/15 55/17 57/14
109/14
person [20] 12/11 12/15 18/3 27/7
31/19 32/8 36/13 36/22 39/25 40/1
50/9 50/13 62/6 69/17 71/12 81/9
81/21 91/6 112/23 115/23
personal [4] 16/17 51/2 76/10 76/21
personally [3] 17/25 34/8 38/7
perspective [2] 49/17 60/23
phone [31] 24/3 29/2 29/6 54/25 56/2
60/17 61/18 61/21 62/2 62/7 72/14
72/22 88/25 96/25 106/7 106/10
106/11 106/13 106/15 106/15 106/16
106/21 107/10 107/11 107/11 107/14
107/16 107/20 107/22 108/1 110/14
phones [1] 61/22
photo [1] 51/11
photos [2] 85/17 85/17
Photoshop [1] 34/1
Phront [5] 18/18 39/1 63/4 63/15
111/10
pick [2] 83/9 83/13
picture [3] 21/9 43/23 56/19
pictures [2] 46/4 51/19
piece [1] 92/25
pin [1] 118/3
pinning [1] 118/2
pissed [1] 114/10
place [2] 46/2 47/6
plan [12] 17/18 18/16 35/14 35/17
35/20 35/21 35/22 36/12 36/15 36/25
68/10 68/12
planning [1] 86/4
plans [4] 37/4 43/24 112/7 118/9
played [12] 19/14 19/18 19/21 24/25
30/1 36/25 38/11 43/14 44/8 48/6
53/12 56/23
plea [3] 80/3 80/14 80/18
pleaded [2] 45/7 117/24
please [9] 60/11 96/16 97/18 98/14
102/22 103/21 104/18 107/13 107/13
pled [3] 79/8 79/9 80/22
plotted [1] 55/19
plural [1] 59/17
plus [1] 112/19
point [10] 33/3 47/23 50/23 50/24
61/16 82/9 85/2 102/14 107/2 109/10
pointed [5] 27/7 81/2 82/25 97/21
99/16
points [2] 55/19 106/1
police [1] 91/20
polite [1] 91/20
pop [1] 85/1
portion [2] 1/9 2/16
position [1] 79/22
possesses [1] 100/13
possession [3] 55/12 100/9 100/21
possibility [1] 8/21
possible [1] 5/22
power [2] 105/15 105/16
PPP [57] 16/20 18/7 18/8 18/17 24/12
24/20 25/25 26/2 26/4 26/18 28/2
31/8 32/7 36/10 37/8 37/21 38/23
39/19 40/23 42/17 42/18 42/20 42/25
43/2 45/13 45/23 47/7 62/22 63/1
63/3 63/23 63/24 67/20 68/17 68/22
76/5 78/12 81/15 82/6 82/20 82/22
83/17 83/20 84/5 87/1 89/24 93/19
98/9 106/22 111/10 111/11 116/5
116/16 116/17 116/21 117/16 120/15
PPP loan [19] 24/20 37/8 37/21 38/23
39/19 42/18 42/20 47/7 76/5 78/12
81/15 82/20 83/20 84/5 89/24 98/9
116/5 116/17 116/21
PPP loans [8] 16/20 36/10 42/17
45/13 63/24 87/1 93/19 116/16
practicing [1] 34/1
practitioner [1] 4/10
preliminary [1] 2/21
preparation [1] 1/18
prepare [1] 23/15
prepared [2] 20/23 89/6
prepares [1] 22/6
preposterous [1] 106/23
present [3] 50/15 71/9 72/7
presented [6] 10/19 50/18 53/1 62/5
66/8 76/9
presenting [1] 73/22
press [1] 64/13
presumed [1] 72/1
pretended [1] 44/1
pretenses [3] 17/15 32/22 35/2
pretty [2] 81/10 84/15
prevented [1] 82/3
previewed [1] 5/17
previous [1] 62/20
primary [4] 48/13 88/3 102/2 102/3
principle [1] 3/2
prior [3] 59/8 78/25 79/2
Prisons [2] 13/13 13/13
privilege [2] 8/12 11/1
probability [2] 42/9 100/6
probably [9] 11/7 11/13 45/6 71/2
76/19 89/18 89/19 91/16 104/2
problems [1] 56/4
procedure [5] 4/12 4/13 4/14 4/22
4/22
proceedings [6] 1/10 49/8 104/16
122/10 122/14 122/18
proceeds [4] 42/3 46/11 47/7 99/2
process [4] 5/1 5/12 7/19 8/5
product [1] 30/12
products [1] 48/10
professional [5] 75/18 88/12 90/5
93/13 93/15
professionalism [1] 93/12
proffer [1] 79/1
proffers [1] 7/21
program [8] 15/13 18/9 18/11 18/13
25/25 42/25 48/2 48/14
prohibited [1] 1/12
project [25] 43/17 43/19 43/22 43/24
44/5 44/15 46/1 46/3 47/2 47/11
47/13 47/18 48/11 75/19 76/19 80/9
86/3 90/13 95/9 97/10 97/13 117/23
118/5 118/13 118/14
projects [2] 68/13 83/23
promise [1] 65/1
promises [2] 17/16 32/23
prongs [1] 98/17
proof [24] 50/13 70/10 70/17 70/21
70/22 70/23 71/11 71/22 97/21 97/22
98/3 98/5 98/8 98/21 99/12 99/18
100/18 102/23 102/24 103/20 103/23
105/14 105/14 109/24
proper [1] 111/4
property [6] 17/19 38/19 40/19 41/22
85/23 118/5
proposal [4] 95/10 95/11 95/23 96/2
proposed [2] 3/12 3/14
prosecuting [1] 31/6
prosecutor [6] 75/17 76/1 80/14
84/20 95/12 102/17
prosecutorial [2] 8/20 9/4
Protection [5] 15/13 18/11 18/13
48/2 48/14
prove [14] 17/20 35/16 35/21 38/24
40/18 40/21 40/25 41/2 42/6 49/25
53/22 60/18 70/6 108/12
proved [3] 62/8 71/20 71/21
proven [4] 41/21 52/19 52/21 98/18
proves [1] 34/5
provide [1] 96/2
provided [4] 65/13 68/9 102/12
117/13
proving [2] 42/6 105/21
prudent [1] 11/3
pull [1] 99/11
pulled [1] 85/21
pulling [1] 45/2
punctuation [1] 111/5
purchase [5] 48/8 48/9 48/9 48/10
118/6
purchased [1] 118/5
purportedly [1] 66/3
purpose [9] 33/24 36/12 37/1 50/2
51/5 71/13 87/4 97/7 107/1
pursue [2] 5/23 9/8
pursued [1] 9/11
put [27] 2/7 11/4 23/23 29/25 30/3
33/9 34/2 37/7 44/15 44/21 45/21
54/23 54/24 56/4 77/6 79/21 81/5
83/1 83/22 84/12 87/25 95/3 95/24
97/16 98/2 98/14 101/10
putting [3] 3/21 22/2 26/25
Pyfrom [58] 21/8 21/21 22/1 22/6
22/12 23/1 24/11 24/19 25/1 25/13
25/18 25/25 26/7 26/21 28/5 30/20
31/6 31/7 31/10 38/9 50/22 51/1 51/4
51/4 51/7 51/19 51/22 51/24 53/3
54/16 58/20 58/25 59/2 61/13 63/1
64/11 66/15 72/17 73/2 105/18 106/5
106/13 108/25 110/4 110/15 110/21
111/10 111/14 111/18 112/3 112/14
112/16 112/24 113/2 113/6 113/10
114/24 115/6
Pyfrom's [1] 39/7
Pyfrom-Foster [34] 21/21 23/1 24/11
51/1 51/4 51/7 51/19 51/22 51/24
53/3 54/16 58/20 58/25 59/2 61/13
63/1 64/11 66/15 72/17 105/18 106/5
106/13 108/25 110/4 110/15 110/21
111/14 111/18 112/3 112/14 113/2
113/6 113/10 115/6
Pyfrom-Foster's [4] 38/9 73/2 112/16
114/24
Q
qualifications [1] 75/18
quarter [2] 15/20 23/19
question [4] 45/20 71/17 95/10
108/10
questions [23] 6/24 11/5 11/9 45/2
47/4 51/25 69/2 75/17 75/22 79/8
79/18 80/6 80/11 80/25 86/5 86/22
87/6 91/2 91/23 93/1 95/11 112/5
119/2
quick [1] 93/13
quickly [1] 5/14
Quite [1] 9/4
quote [3] 10/15 13/6 13/7
R
Rafael [1] 8/10
random [1] 115/23
rapid [12] 55/3 55/5 55/8 55/10 70/2
106/24 106/25 107/5 107/6 107/11
107/23 112/9
rarity [1] 78/20
reach [2] 22/13 25/21
read [7] 2/19 2/22 80/15 98/13 99/22
100/1 100/10
reading [1] 27/6
134
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R
reads [1] 97/19
ready [5] 14/14 22/3 23/8 31/22 49/2
real [12] 16/3 33/5 48/8 68/12 68/13
70/8 79/21 83/20 107/3 112/8 114/17
117/13
reality [1] 49/18
realization [1] 79/21
realize [2] 55/23 98/18
realized [1] 120/1
really [9] 10/4 41/23 47/10 47/12
84/7 86/17 89/9 90/3 118/21
Realtime [1] 122/5
reason [20] 6/13 33/22 34/1 34/2
36/8 38/13 42/14 43/12 44/14 44/19
44/20 70/9 84/4 100/24 110/17 114/17
116/12 119/4 119/22 120/5
reasonable [23] 41/21 50/1 69/24
70/5 70/7 70/8 70/18 70/21 70/24
71/5 72/3 75/6 96/13 97/15 97/22
98/5 98/19 98/20 98/22 100/22 102/23
103/20 114/17
reasoning [1] 25/21
rebuttal [2] 48/24 105/8
receipt [2] 56/11 56/14
receive [2] 8/4 69/14
received [7] 23/20 40/12 40/13 44/12
64/15 68/17 69/21
receiving [3] 5/8 68/21 68/22
recess [2] 104/16 121/12
recessed [1] 49/8
recognize [1] 11/11
recognized [2] 9/23 95/15
recollection [1] 85/20
reconciliation [2] 55/20 55/20
reconsider [1] 67/5
record [10] 4/9 4/15 4/21 9/4 11/4
11/21 94/12 96/5 96/7 122/18
recording [5] 88/24 90/17 92/14 93/4
101/6
recordings [1] 48/18
records [7] 16/12 55/15 89/16 94/1
107/14 107/17 114/5
Redding [2] 74/15 74/22
reduced [1] 122/15
refer [3] 26/16 84/25 101/21
reference [1] 95/23
referenced [2] 24/2 109/12
referencing [2] 1/10 58/2
referred [2] 77/20 99/10
refers [1] 40/7
refreshed [1] 85/20
regarding [1] 97/10
related [3] 94/20 94/21 95/7
relates [1] 64/4
relationship [4] 60/23 61/4 87/18
116/11
relationships [1] 61/9
release [1] 64/13
relevant [2] 3/8 113/23
relied [1] 61/25
rely [5] 55/1 70/11 97/23 105/20
115/11
remember [15] 17/22 23/18 45/5 46/3
59/16 61/24 79/12 80/6 82/19 84/1
85/19 90/21 95/3 95/7 118/8
remembered [1] 94/9
remind [2] 34/8 38/6
remove [1] 26/14
renovating [1] 118/16
repeat [1] 63/20
repeatedly [1] 5/16
repeats [1] 58/16
report [2] 55/24 55/25
reported [1] 122/9
reporter [9] 1/6 1/11 1/17 1/22 1/22
122/4 122/5 122/5 122/24
REPORTER'S [1] 122/2
reports [2] 37/17 59/3
represent [1] 81/19
representation [1] 6/25
representations [3] 17/15 32/23
81/19
request [3] 12/11 12/22 18/13
requested [3] 12/11 12/20 87/19
requesting [1] 12/4
requests [1] 95/17
require [2] 17/1 102/24
required [3] 70/19 119/15 119/20
requirement [1] 5/12
requirements [2] 5/9 5/10
requires [3] 5/3 50/13 70/20
Reservation [15] 20/12 22/20 41/12
41/15 45/14 45/19 47/19 80/21 81/16
86/24 90/11 96/20 97/5 117/23 118/15
reserve [1] 48/23
residence [1] 96/8
residential [1] 115/2
Resource [10] 45/16 45/16 76/12
76/13 82/20 86/24 87/10 88/6 93/20
117/2
Resources [1] 76/23
respect [3] 37/12 88/11 88/17
respectful [1] 91/20
respond [6] 13/20 26/3 46/25 90/9
92/8 92/18
responded [1] 92/25
responses [5] 80/5 88/15 90/8 92/12
93/10
responsibility [1] 80/18
responsible [5] 18/3 50/12 62/19
90/16 102/19
rest [9] 13/25 48/23 49/16 50/25
55/6 60/25 64/4 68/19 75/8
restricted [1] 1/6
resulted [1] 41/12
retirement [2] 27/23 68/24
return [4] 48/19 75/9 95/16 120/20
review [1] 5/3
Richlands [1] 59/2
Ricky [6] 12/2 54/7 74/9 74/21
115/16 115/20
ridiculous [1] 27/20
right [56] 7/3 8/7 11/19 13/18 15/1
22/16 22/25 25/24 32/13 48/25 49/1
55/20 56/11 58/3 60/10 60/17 60/24
63/12 63/16 63/18 64/25 65/17 65/19
65/23 66/4 66/11 66/21 68/10 69/7
69/16 70/6 74/11 74/14 76/20 79/7
81/1 81/6 82/8 85/16 86/17 87/12
89/5 90/6 90/8 90/16 90/19 90/23
91/24 92/3 95/1 99/12 103/6 105/3
110/3 110/7 120/23
ripped [1] 78/24
River [3] 35/5 37/23 41/18
RK [1] 21/3
RK Painting [1] 21/3
Roadrunner [4] 94/1 94/22 94/25 95/7
robbed [2] 6/10 6/11
robbery [1] 92/10
role [3] 31/21 31/21 108/16
roles [2] 53/12 108/8
Rolls [1] 87/15
room [9] 22/17 22/19 22/22 22/23
48/15 71/17 102/22 107/13 112/17
Royce [1] 87/15
RPR [1] 122/23
rule [1] 8/19
ruling [4] 2/21 2/23 11/16 13/1
running [3] 94/16 106/21 107/10
runs [1] 107/21
rush [1] 7/16
S
S.W [1] 1/23
said [75] 6/6 6/14 6/16 10/14 13/23
18/14 18/15 19/16 23/23 24/17 27/5
32/15 33/18 34/20 43/23 44/6 46/12
48/5 48/8 50/23 52/6 52/13 53/16
53/22 54/13 60/2 63/23 64/19 67/4
67/23 67/25 68/15 68/16 68/23 74/10
83/16 84/1 84/11 85/7 85/25 90/11
94/9 102/13 103/2 103/6 103/8 103/15
106/25 107/2 107/6 108/17 109/4
109/7 109/8 110/4 113/8 113/9 113/25
115/14 115/16 117/6 117/10 117/22
118/5 118/9 118/10 118/11 118/15
118/19 118/20 119/16 119/19 119/24
120/19 122/14
sake [1] 8/24
Sal [1] 113/13
sales [1] 89/4
salesman [1] 89/9
salesmen [3] 89/3 89/7 89/13
same [30] 15/22 19/24 20/1 20/12
20/20 20/25 21/3 21/4 23/5 23/13
24/6 25/7 25/8 25/8 34/23 42/12
63/19 74/16 94/23 107/17 108/11
109/16 110/3 110/15 111/7 112/20
112/20 112/24 115/19 117/20
Samir [1] 1/16
sand [1] 99/20
Saraliene [1] 1/19
sat [3] 45/24 108/21 119/18
satisfied [1] 98/22
satisfies [6] 32/21 33/13 34/17 35/7
37/9 39/14
save [1] 116/3
saves [1] 112/23
saw [91] 15/15 15/17 15/19 15/22
16/2 16/3 16/4 16/4 16/7 16/9 16/10
16/12 18/6 18/8 18/12 18/17 18/19
18/22 18/25 19/3 19/6 19/8 19/22
19/24 20/3 20/12 20/20 21/8 22/5
22/17 22/24 23/5 23/13 23/15 23/17
24/3 24/4 24/6 24/13 24/13 25/1 25/7
25/13 27/25 32/2 32/4 33/2 33/19
36/22 37/4 39/6 39/9 39/11 39/23
40/12 41/11 41/13 41/13 43/2 43/3
46/8 46/12 46/19 46/20 46/22 46/25
69/25 72/23 73/1 73/3 76/22 78/18
79/17 79/18 79/20 94/15 95/1 96/7
105/15 107/6 110/10 110/11 111/3
111/3 111/11 113/8 113/23 114/25
116/17 116/17 117/1
say [61] 6/7 6/8 6/9 10/25 19/12
19/15 19/19 24/20 28/18 28/22 33/15
36/5 38/8 38/12 43/15 44/11 44/14
44/20 44/20 46/25 47/3 48/12 49/1
50/4 52/12 58/19 72/17 73/10 73/15
74/10 79/15 80/23 83/6 83/6 84/22
88/21 89/10 89/10 90/9 91/7 91/8
91/19 92/1 92/4 92/5 92/8 94/13
95/23 97/11 98/1 100/12 102/11 103/5
107/6 109/4 110/5 112/12 115/21
115/22 119/4 120/5
saying [10] 53/19 59/2 59/4 60/11
66/3 68/1 68/3 91/17 103/13 113/25
says [21] 2/13 20/18 20/19 36/1 40/7
53/13 59/7 59/9 59/15 59/16 63/13
64/2 67/7 67/13 74/5 83/12 83/13
85/3 103/6 103/16 119/21
SBA [4] 33/2 33/10 34/15 41/19
scale [1] 61/5
scanner [1] 120/10
scenario [1] 7/16
scene [1] 50/16
scheme [12] 17/14 17/17 17/21 17/23
20/8 31/18 31/20 32/20 35/2 65/14
68/9 76/5
scope [1] 46/3
screen [3] 83/2 101/10 119/13
screenshots [2] 106/8 113/1
screwed [1] 32/6
search [3] 60/16 73/8 97/2
seated [3] 14/22 49/11 105/5
second [12] 10/6 10/11 33/13 36/11
38/18 40/15 41/5 41/24 61/16 98/25
104/22 111/13
seconds [1] 29/16
secret [2] 77/9 116/7
secret-keeper [1] 116/7
section [6] 4/17 5/11 7/8 7/13 7/19
7/20
Securus [2] 59/10 59/11
see [44] 21/7 22/25 27/17 53/7 56/25
58/1 58/5 58/9 58/10 58/11 58/13
58/14 58/15 59/1 59/4 59/8 59/24
62/12 62/15 62/25 63/3 70/1 70/2
77/21 78/20 78/23 85/8 86/18 87/9
90/3 91/2 99/22 103/9 105/22 107/16
110/13 110/17 110/24 111/6 112/18
112/25 114/4 114/14 117/5
seeing [1] 21/25
seek [1] 5/7
seems [1] 110/25
seen [9] 11/11 36/6 43/4 49/19 60/10
60/13 72/9 111/5 119/11
seized [5] 108/18 108/22 108/22
135
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S
seized... [2] 114/3 114/8
selected [1] 96/25
sell [3] 68/10 89/3 89/8
send [12] 7/14 19/25 20/2 22/24
23/17 47/22 57/21 57/22 59/10 59/15
61/20 111/22
sending [6] 57/8 58/9 60/13 67/16
109/20 110/6
sends [5] 20/16 23/11 60/4 60/8
106/8
senior [2] 75/19 76/18
sense [19] 25/21 26/5 26/20 27/12
30/25 48/19 57/9 60/6 61/3 70/9
75/25 78/3 78/6 78/7 101/8 106/12
108/3 112/13 114/18
sent [45] 14/6 14/11 16/16 18/13
19/3 20/6 21/11 22/20 22/21 25/7
26/23 27/4 46/23 51/9 51/11 51/14
51/22 54/23 55/1 56/6 56/7 56/8
57/23 58/25 59/2 59/3 59/7 60/3
62/14 63/1 63/8 65/7 66/23 66/24
67/13 67/15 109/16 110/4 110/7
110/15 110/24 111/10 111/18 113/14
120/5
sentence [1] 79/6
sentenced [1] 79/3
sentences [1] 111/4
sentencing [1] 79/9
separate [4] 53/15 74/1 76/12 101/14
separately [3] 53/25 53/25 54/1
serious [3] 91/24 92/5 92/10
servers [3] 34/13 34/15 41/19
services [13] 20/21 23/6 39/10 39/11
45/16 45/16 76/12 76/13 82/20 86/24
87/10 93/20 117/2
Services's [1] 88/6
SESSION [1] 1/5
set [4] 51/1 51/4 51/10 84/4
seven [3] 15/19 59/20 107/25
several [3] 59/8 80/11 90/17
sham [1] 80/21
share [2] 32/4 32/6
shared [1] 30/5
she [200]
she's [12] 13/22 39/25 40/1 43/1
75/18 75/18 89/6 95/6 97/11 98/8
101/19 119/24
shit [3] 19/12 24/17 83/4
shocking [1] 89/18
short [2] 49/4 104/5
shortly [1] 23/10
shot [2] 6/12 32/15
should [12] 25/19 34/18 37/10 39/15
55/2 67/5 73/10 73/24 74/24 114/19
114/20 119/24
shouldn't [1] 61/9
show [27] 9/19 16/12 39/3 50/25 51/1
51/3 51/7 51/13 51/15 51/17 52/14
57/2 57/10 57/12 57/16 61/11 68/19
71/24 72/8 72/25 76/22 88/5 89/2
96/13 99/13 102/4 120/14
show-up [2] 88/5 102/4
showed [21] 45/3 45/4 45/11 46/5
58/25 66/2 67/12 67/14 85/17 85/18
85/20 94/5 96/7 98/20 103/10 105/21
109/13 109/23 110/6 112/18 114/12
showing [6] 8/19 9/3 51/14 52/10
62/21 89/13
shown [3] 15/9 35/1 39/1
shows [13] 3/20 9/6 9/20 32/19 51/22
52/15 56/20 70/17 70/17 89/4 89/6
119/1 120/2
shred [3] 29/19 29/21 50/19
shut [3] 42/23 99/10 103/7
shutting [1] 76/15
side [1] 61/5
sign [2] 43/23 85/24
signature [1] 43/2
signed [3] 43/4 82/5 89/11
signer [1] 39/25
significant [2] 5/5 71/24
signs [1] 46/4
similar [1] 59/6
simple [1] 49/18
simply [3] 5/24 50/15 71/9
since [1] 115/2
single [11] 29/19 31/18 45/20 50/18
62/19 69/11 69/18 72/4 72/4 107/16
112/19
sit [4] 33/25 35/25 73/13 92/11
sits [1] 72/1
situation [3] 7/25 10/18 26/14
situations [3] 91/12 92/18 92/21
skeptical [2] 65/12 65/13
skills [1] 88/19
sky [2] 42/22 45/18
slew [1] 84/12
slide [11] 51/20 58/1 58/5 59/6
62/20 62/20 62/25 63/2 96/16 98/14
98/20
slip [2] 51/14 66/24
smaller [1] 69/19
smart [1] 101/5
snitch [1] 6/11
sole [1] 62/6
solidify [1] 2/21
some [43] 2/10 16/3 16/4 17/2 17/3
23/16 27/23 38/19 41/7 43/17 44/15
47/13 50/11 50/23 50/24 58/15 61/8
71/13 73/22 74/24 80/25 82/9 83/2
84/4 84/11 85/4 85/7 85/16 85/17
87/10 87/11 87/17 89/24 90/7 90/14
96/17 103/3 103/14 103/15 106/1
115/23 118/20 119/8
somebody [7] 6/12 26/1 57/19 76/18
87/14 90/1 107/24
somebody's [1] 106/15
somehow [9] 30/15 47/10 70/23 80/4
82/22 94/20 95/24 96/1 107/9
someone [42] 3/9 4/12 17/14 17/19
19/1 19/2 32/13 34/25 38/8 46/2
54/21 54/22 54/24 57/16 64/2 68/3
68/4 68/5 68/6 71/2 73/20 74/13
74/17 74/24 75/24 89/6 90/18 90/20
94/13 98/4 99/19 100/8 105/24 107/9
107/21 113/19 115/14 115/23 119/1
119/20 119/25 120/11
something [41] 5/24 6/6 6/17 20/15
21/8 27/20 29/17 39/5 41/25 42/12
43/6 52/17 57/17 59/6 64/2 68/7
70/25 71/3 71/20 74/5 75/15 79/16
79/16 85/21 86/17 89/8 90/6 91/4
91/4 91/5 91/9 91/24 99/13 99/19
102/18 108/15 109/1 110/22 111/1
118/22 120/3
sometimes [8] 2/10 5/14 81/23 89/9
91/11 118/9 118/10 118/11
somewhere [1] 36/19
soon [1] 14/10
sophisticated [2] 26/7 117/14
sorry [2] 13/19 27/21
sort [6] 56/3 65/22 66/7 69/13 74/4
118/20
sorts [1] 55/9
sought [2] 5/2 6/21
sound [2] 68/5 68/6
sounds [2] 68/3 73/20
source [10] 40/21 42/2 43/11 44/23
46/10 47/24 50/2 52/20 52/23 86/23
span [1] 29/16
speak [1] 7/8
speaking [2] 44/24 69/5
specific [8] 40/10 41/1 53/23 94/12
101/22 101/23 108/7 108/8
specifically [2] 6/2 41/9
specified [1] 40/19
spectator [1] 71/7
speculating [1] 68/6
spend [1] 16/16
spent [1] 16/17
split [1] 91/6
spoke [1] 114/1
spoken [1] 88/8
spouses [1] 87/19
spreadsheet [6] 19/7 21/12 21/13
21/18 25/7 65/19
spreadsheets [2] 16/7 22/7
stack [2] 65/20 112/15
stage [2] 98/7 101/7
stamp [8] 18/24 23/15 23/18 23/23
37/7 60/11 60/14 113/15
stamped [18] 23/20 57/21 57/22 58/3
58/4 58/6 58/7 58/11 58/12 58/15
58/15 58/17 58/18 60/4 60/11 66/4
113/9 113/15
stamping [3] 22/3 22/15 23/4
stamps [15] 15/23 19/1 19/2 19/3
19/4 22/9 23/8 23/17 24/9 34/2 60/8
65/24 66/8 66/10 113/16
stand [15] 6/6 6/16 11/16 45/24
77/24 78/23 79/17 82/14 85/11 85/19
88/15 95/15 105/16 105/19 108/21
standard [4] 70/5 70/18 100/22
114/19
standards [2] 114/13 114/21
standing [1] 89/14
stands [1] 10/23
star [5] 22/17 22/19 22/22 22/23
45/1
start [8] 21/25 25/14 26/3 49/21
92/11 106/1 121/4 121/5
started [11] 18/17 21/7 21/21 25/14
28/7 62/10 67/23 82/19 92/13 113/6
114/22
starting [1] 86/25
stated [1] 4/19
statement [20] 8/14 10/15 18/20
22/18 22/21 22/21 22/23 28/10 52/13
56/23 57/14 63/22 64/5 66/25 67/12
84/19 85/14 94/5 109/14 112/2
statements [13] 16/2 16/4 16/5 16/23
37/14 37/17 41/14 69/1 76/22 78/25
78/25 83/10 92/20
states [7] 1/1 1/4 1/11 1/23 8/10
122/6 122/11
statutory [2] 5/2 8/5
stay [1] 78/5
stayed [1] 113/3
steal [1] 33/18
Stenograph [1] 122/9
stenographic [3] 1/17 122/2 122/4
step [1] 60/7
still [7] 2/17 22/2 55/25 72/15
72/20 82/17 115/2
Stites [18] 63/11 64/12 74/19 82/7
88/11 89/20 89/22 93/1 93/13 94/4
95/12 95/14 95/25 108/21 109/6 109/7
115/11 119/10
stood [1] 53/16
stopped [2] 89/20 91/19
stories [2] 115/13 115/19
story [12] 49/16 49/17 50/25 61/1
64/4 69/3 72/8 75/2 75/8 81/24 83/22
96/21
street [2] 43/23 46/4
stringent [1] 7/9
strong [1] 74/12
struggled [1] 44/10
struggling [1] 45/21
stuck [1] 99/19
stuff [6] 75/25 91/18 96/11 99/11
103/15 103/16
subcontractors [1] 90/15
subject [1] 66/19
submission [1] 34/17
submit [2] 33/24 113/16
submitted [17] 7/11 15/18 15/20 16/2
16/5 19/4 31/22 33/21 34/11 37/18
37/22 41/17 68/18 71/18 84/7 84/7
112/9
submitting [1] 33/5
subpoena [10] 89/16 95/13 95/14
95/15 95/21 96/3 97/13 105/15 105/16
114/24
substance [5] 100/9 100/14 100/15
100/21 100/24
substantial [1] 8/19
substantive [1] 101/21
succeeded [2] 17/21 35/21
success [2] 22/5 101/8
successful [6] 75/18 75/21 76/3
76/11 78/4 90/21
sudden [7] 21/17 42/21 45/20 76/4
82/23 90/20 90/24
suffer [1] 79/23
sufficient [3] 37/3 69/24 100/19
suggest [2] 8/21 9/13
suggested [2] 105/10 113/10
sum [1] 3/9
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summary [1] 99/21
summer [1] 106/20
super [2] 65/12 65/12
supercar [1] 87/15
supervisor [1] 6/23
supervisors [1] 12/21
supervisory [2] 5/8 6/21
support [2] 8/12 73/16
supported [4] 12/6 48/20 60/20 75/9
supporting [1] 117/11
supports [1] 2/23
supposed [10] 43/13 44/11 44/17 47/1
53/8 85/4 95/18 96/2 115/20 119/5
supposedly [4] 82/5 82/6 82/7 109/15
sure [9] 2/9 2/12 20/10 22/15 52/6
52/7 101/5 103/1 117/20
surprising [1] 89/19
suspicion [9] 93/23 93/24 94/2 95/6
99/3 103/19 103/19 103/19 120/8
suspicions [1] 86/16
system [1] 70/22
T
T-Mobile [2] 107/10 107/14
table [1] 45/21
tablet [3] 55/16 107/9 107/20
take [15] 7/4 25/10 49/4 63/19 70/19
79/14 83/7 88/1 99/14 103/6 103/7
104/5 104/8 107/13 121/1
taken [4] 6/1 87/11 104/22 119/23
takes [4] 4/16 4/23 5/4 8/6
taking [1] 114/13
Tal [1] 1/16
Taldrid [2] 74/11 115/21
talk [35] 5/21 19/7 28/6 28/16 31/1
36/17 38/1 38/2 44/24 56/5 60/1
60/22 63/22 69/5 73/14 73/18 84/24
85/10 85/10 88/5 88/10 88/10 89/6
90/7 90/18 91/25 92/1 92/2 94/1
101/18 102/4 106/24 118/11 119/15
119/16
talked [18] 37/6 40/24 44/5 69/19
74/1 84/13 86/9 93/19 95/9 96/4
96/20 102/5 106/3 108/4 108/13 116/1
118/10 118/11
talking [18] 21/21 22/12 33/22 36/7
62/21 62/22 62/22 62/23 67/21 67/22
69/16 82/19 88/22 89/23 91/21 91/25
99/9 119/12
talks [2] 67/19 88/18
tax [3] 15/17 18/23 62/23
taxes [3] 24/15 27/8 62/22
team [1] 61/14
tears [1] 79/21
technique [1] 94/23
technology [2] 1/18 14/19
Ted [1] 1/23
teeth [1] 45/2
Teldren23 [1] 29/18
TELDRIN [168]
Teldrin' [1] 61/22
Teldrin's [2] 60/22 63/22
Teldrin23 [7] 29/12 57/17 58/2 58/14
58/17 59/19 59/21
Telegram [4] 26/9 29/5 30/16 61/25
tell [45] 12/4 12/25 20/9 42/8 43/6
50/9 53/4 53/10 53/11 53/24 55/6
55/7 55/8 55/11 55/17 56/9 56/17
57/18 60/25 62/11 65/6 71/4 71/9
72/25 77/25 78/11 78/12 82/10 82/16
84/2 88/13 88/23 91/14 91/16 92/2
101/16 103/14 108/7 108/14 108/18
108/20 114/16 115/5 116/4 119/14
telling [8] 20/7 46/24 59/22 65/15
69/4 80/17 83/3 83/3
tells [2] 20/18 120/11
template [8] 19/10 21/13 24/21 25/2
25/10 110/23 112/22 113/2
templates [2] 25/15 112/6
tens [1] 27/16
testified [5] 6/4 79/11 79/25 85/11
85/24
testify [15] 6/14 12/16 12/18 30/11
54/12 54/21 55/14 61/11 78/15 78/19
81/4 82/12 82/15 88/14 119/11
testifying [3] 6/3 7/21 75/16
testimony [30] 8/22 9/14 10/5 15/24
34/10 35/5 44/3 44/6 45/10 46/5 54/9
73/16 76/15 76/21 79/6 80/13 84/20
86/2 87/3 94/4 94/10 96/19 96/23
102/25 103/7 106/4 113/12 117/19
117/20 118/2
text [7] 26/2 46/23 62/1 86/5 86/19
96/24 113/8
texts [1] 109/23
than [12] 3/19 7/17 15/14 15/15
43/16 66/5 69/10 69/15 69/24 70/19
71/21 75/3
thank [16] 4/7 8/7 11/23 15/5 48/22
48/25 49/13 75/11 75/13 103/24
104/14 105/3 105/7 120/22 120/23
121/9
Thanks [2] 14/13 49/6
that [1120]
that's [89] 2/16 3/11 5/24 6/13 12/7
13/15 21/25 22/25 24/2 24/17 25/4
28/23 30/4 30/10 31/17 32/4 32/18
33/17 35/22 37/2 39/24 42/12 46/15
46/18 47/4 48/12 57/14 58/11 62/11
66/2 66/18 68/14 69/15 70/5 70/23
71/1 74/8 74/11 75/9 77/3 78/20
80/22 81/16 83/12 84/14 84/18 84/25
85/8 85/13 85/25 87/14 87/16 90/13
91/22 92/23 92/24 93/21 93/25 94/19
94/20 99/14 99/21 100/9 100/16
100/17 101/6 102/20 103/13 106/12
106/19 106/25 107/14 107/17 108/2
108/5 109/1 110/22 111/15 112/22
113/23 114/1 114/19 115/2 115/15
116/18 117/22 118/23 119/20 120/2
their [30] 5/12 11/5 12/6 13/14
18/16 29/15 30/11 36/1 48/17 48/18
51/12 56/4 58/21 60/18 60/20 65/4
67/6 67/7 71/24 77/15 78/22 79/5
87/15 88/19 92/24 99/20 106/3 106/15
108/8 116/11
them [59] 12/5 12/15 13/18 14/6
15/20 15/23 16/10 16/18 17/3 20/3
22/3 22/9 22/15 23/15 23/17 24/9
27/2 28/14 28/14 31/7 32/14 33/23
34/2 36/9 40/16 44/21 56/8 56/12
60/5 60/12 63/18 65/7 67/3 67/17
67/23 68/18 72/24 75/2 78/23 89/7
89/13 90/13 91/16 92/2 92/16 92/17
92/21 93/8 97/19 97/19 105/12 105/12
105/19 107/16 108/12 108/13 108/13
109/18 109/21
themselves [8] 26/14 26/15 26/16
26/16 27/11 30/24 46/12 116/3
then [70] 5/22 7/12 7/14 9/9 9/9
10/20 15/2 18/25 19/3 19/9 20/1 20/5
20/14 21/5 22/8 22/22 23/7 23/14
23/16 23/24 24/8 26/3 26/25 32/16
33/6 34/13 34/14 41/18 41/18 51/3
51/13 51/21 57/21 58/5 58/8 58/11
58/13 58/14 58/15 58/18 59/4 59/6
59/7 59/9 59/10 59/18 59/20 60/3
60/4 61/5 62/25 67/14 72/17 74/15
74/16 79/23 81/18 88/9 95/11 101/22
102/9 102/11 103/6 106/8 106/10
109/7 109/8 109/20 113/2 118/5
theory [5] 3/3 3/13 57/7 73/22 101/3
there [183]
there's [3] 85/2 85/7 112/25
therefore [4] 55/5 56/6 62/18 63/25
these [75] 9/21 15/15 15/18 15/22
15/24 16/3 16/13 16/20 18/8 21/10
22/3 27/1 27/14 27/22 32/21 33/22
33/25 34/11 34/17 36/10 36/18 36/19
37/4 37/6 37/15 37/18 40/12 40/13
42/7 44/14 44/21 53/7 53/10 53/12
53/12 53/16 53/21 55/8 55/15 56/3
56/6 58/25 59/19 65/7 67/13 67/24
68/10 69/9 77/25 78/1 78/8 78/11
78/17 79/15 82/15 82/20 86/15 87/1
88/17 90/19 90/23 91/12 93/10 96/3
96/12 96/17 97/4 98/16 98/18 98/21
100/1 101/4 103/17 113/9 115/25
they [227]
they'll [1] 101/23
they're [18] 6/24 25/24 26/6 27/10
27/13 50/4 54/17 61/14 61/14 61/25
79/2 82/8 89/15 93/15 94/13 99/11
108/6 108/17
thing [29] 17/22 20/12 20/25 23/13
28/15 28/24 31/11 31/15 46/6 47/8
48/11 60/7 65/22 66/7 73/18 74/16
77/3 78/14 82/18 85/16 86/21 87/14
89/10 89/17 92/23 98/18 102/14
106/14 116/15
things [30] 2/11 10/21 29/6 31/1
32/1 42/7 45/5 45/12 48/7 48/10
60/14 61/12 62/1 67/24 73/23 77/2
78/13 79/9 81/14 84/11 84/16 90/19
90/22 93/17 96/17 97/11 101/2 101/16
108/4 108/6
think [68] 2/10 2/14 2/23 7/9 8/9
9/1 9/15 10/1 10/8 11/2 11/7 13/15
13/22 24/15 27/5 32/13 54/2 55/1
59/13 61/9 62/9 63/23 64/4 64/7
66/14 67/6 68/1 69/10 69/14 69/15
69/17 69/23 72/12 74/8 74/24 75/2
76/7 76/17 77/3 77/17 78/3 78/7
79/12 82/25 84/15 84/22 84/23 85/13
85/14 85/14 85/19 89/24 91/8 91/17
94/4 94/20 98/6 102/1 102/22 102/22
102/25 103/1 103/18 103/25 104/5
107/23 112/2 120/8
thinking [8] 44/6 56/12 66/3 70/23
70/25 75/15 91/3 113/9
thinks [1] 110/25
third [7] 33/14 38/24 40/15 40/18
40/25 41/11 97/21
this [279]
Thomas [106] 6/10 6/12 6/15 9/17
9/20 16/17 18/7 18/10 18/12 18/15
18/19 18/22 19/3 19/7 19/17 19/25
20/2 20/6 20/16 20/18 20/19 20/23
21/12 21/21 22/11 22/18 22/20 23/7
23/9 23/22 24/12 24/14 24/17 25/18
26/6 26/24 27/15 27/19 27/23 27/24
28/5 28/13 28/17 28/23 30/3 30/20
31/5 31/6 31/9 31/21 31/25 32/6
32/12 32/20 33/19 33/21 34/11 36/7
36/23 37/6 38/14 51/6 51/8 51/9
51/12 51/14 51/17 53/2 53/17 53/20
54/12 54/13 55/4 55/12 62/16 62/18
63/1 64/11 64/16 68/24 69/14 76/5
81/13 81/16 82/13 82/24 83/3 86/25
94/11 95/5 96/23 105/18 110/13
110/14 110/21 110/25 111/9 111/19
111/21 112/3 113/5 113/22 113/24
114/5 115/17 116/2
Thomas's [15] 29/2 29/7 29/13 29/24
56/10 56/10 56/14 57/6 64/13 70/1
108/19 108/22 109/11 109/19 110/3
thoroughly [1] 2/20
those [72] 2/9 2/10 2/14 2/17 2/22
4/1 4/7 7/4 8/25 9/1 10/21 11/9 14/2
14/10 16/25 17/6 18/25 19/3 19/4
20/3 22/24 23/8 23/15 26/12 28/23
30/21 34/12 35/9 35/11 35/17 39/20
41/19 54/23 54/25 55/21 55/24 56/7
57/8 57/23 58/19 63/20 66/21 67/2
69/18 69/23 75/21 75/22 81/14 84/16
92/18 101/10 101/23 101/25 102/1
102/10 107/14 107/16 108/5 108/9
108/9 110/5 110/17 111/24 111/24
112/5 112/17 112/19 112/25 114/4
115/11 115/12 120/14
though [6] 7/20 28/8 39/10 72/10
106/14 117/24
thought [13] 13/13 32/9 32/12 47/1
47/2 47/10 47/12 75/24 84/9 94/9
99/25 114/6 117/17
thousands [3] 27/16 101/4 110/1
threatening [1] 79/22
three [10] 27/2 29/17 74/1 74/6 74/7
74/9 79/14 88/9 107/25 115/12
through [16] 2/9 2/11 2/19 5/12 8/5
38/15 39/19 57/25 76/7 78/9 95/4
97/19 100/2 100/3 102/15 102/16
throughout [1] 49/20
thrown [1] 94/19
ticket [1] 79/6
tied [2] 96/8 107/9
ties [1] 94/19
time [46] 5/5 7/1 9/12 10/20 15/11
21/20 22/12 24/8 24/22 37/5 37/6
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time... [35] 37/7 45/9 45/13 48/23
49/19 49/19 55/12 55/21 58/21 60/1
61/19 64/8 65/8 66/22 66/25 66/25
68/23 74/5 77/23 79/14 80/2 88/12
89/21 95/15 106/17 107/23 109/2
110/4 110/8 110/15 110/19 112/21
115/25 119/16 121/2
times [6] 10/10 74/7 74/9 90/17
116/7 118/7
timing [2] 21/10 47/9
Tire [1] 23/25
title [1] 104/22
titles [5] 2/9 2/10 2/12 14/5 77/19
today [1] 59/16
together [16] 2/7 6/10 19/6 26/3
28/13 30/4 35/25 36/7 46/1 60/24
60/25 61/15 62/19 109/7 109/19
120/10
told [47] 6/13 19/1 24/14 25/5 27/21
27/22 28/10 29/11 33/10 33/11 39/24
42/20 45/18 45/24 47/3 49/15 55/4
56/6 57/15 59/24 61/17 61/20 63/11
64/12 64/16 68/14 74/13 74/19 75/8
77/12 81/18 82/11 90/13 90/22 106/16
108/5 108/20 108/21 108/23 108/24
109/2 109/6 110/22 112/1 114/25
115/12 117/21
ton [1] 86/7
too [7] 24/22 26/19 61/1 76/1 103/15
105/15 112/17
took [6] 6/15 43/23 45/9 46/3 62/19
119/18
top [2] 56/19 98/6
total [1] 15/14
totally [2] 102/5 103/2
touch [1] 106/19
touches [1] 22/2
touching [1] 4/1
towards [1] 79/12
town [2] 107/10 107/21
trail [2] 27/17 48/16
trained [1] 93/15
transaction [24] 38/5 38/16 38/19
39/4 39/5 39/23 40/5 40/6 40/9 40/10
42/1 44/2 46/9 50/2 50/5 50/6 50/8
52/1 52/5 52/22 99/5 107/25 108/1
108/2
transactions [12] 40/1 44/12 46/19
55/20 55/21 55/22 55/24 94/7 94/15
94/17 101/14 102/1
transcript [8] 1/3 1/9 1/11 1/13
1/19 1/10 80/4 122/17
transcripts [1] 1/5
transfer [2] 40/7 80/8
transfers [1] 51/21
transmitted [2] 34/9 34/15
transportation [2] 20/20 118/16
Travel [13] 20/13 22/21 41/12 41/15
47/19 80/21 81/16 86/24 90/11 96/20
97/5 117/23 118/15
Travel's [1] 45/19
treat [2] 92/20 92/21
trial [20] 1/10 5/17 5/24 6/23 24/10
29/14 30/13 31/5 31/9 31/10 31/10
34/10 49/20 76/9 92/15 108/9 111/15
111/15 120/17 120/18
tried [13] 5/19 38/5 38/16 39/22
40/9 56/3 64/22 73/1 73/3 73/6 74/2
86/8 120/7
trip [5] 43/22 56/11 56/15 85/15
86/3
trouble [2] 91/9 91/10
true [15] 10/21 47/14 61/23 62/8
62/11 63/6 64/3 74/20 80/22 83/13
83/13 85/13 117/11 117/12 122/17
trust [2] 116/10 116/12
truth [3] 80/18 119/2 119/3
truthful [1] 83/14
try [8] 30/7 49/16 56/1 91/7 93/14
102/18 119/15 119/25
trying [16] 26/22 28/16 68/6 68/25
76/25 79/15 79/16 86/22 86/23 111/2
113/20 114/21 116/3 118/3 118/21
118/24
turned [1] 118/6
Turner [1] 1/23
turning [3] 4/5 52/25 55/3
twice [3] 61/21 106/4 106/10
twist [1] 103/4
Twitter [1] 74/4
two [38] 5/1 9/1 10/24 12/4 12/14
14/2 16/25 33/25 35/11 40/13 40/13
44/10 45/6 61/11 87/17 87/20 88/7
89/2 89/2 89/7 89/13 89/14 90/25
93/8 95/16 95/17 97/7 98/22 101/9
101/14 101/14 101/25 102/1 102/8
104/19 109/25 110/2 117/24
tying [1] 95/2
type [7] 5/13 8/4 40/5 40/10 87/14
94/23 120/9
types [2] 7/5 90/19
typewritten [1] 122/15
typical [2] 61/15 89/17
U
U.S [1] 1/19
ultimately [2] 32/5 113/24
unable [2] 73/3 73/6
unavailable [1] 8/11
unclear [1] 118/13
uncounseled [1] 92/9
under [4] 3/18 13/23 48/13 116/1
underlying [1] 39/19
understand [7] 5/15 6/1 6/2 13/1
61/10 64/6 104/19
understanding [2] 4/25 37/1
unfair [2] 88/20 119/9
UNITED [6] 1/23 1/4 1/11 1/23 122/6
122/11
universe [1] 72/11
unlawful [11] 35/14 35/20 36/12
36/15 37/1 38/20 38/22 38/25 40/19
41/7 99/2
unless [5] 33/23 42/9 45/3 100/6
106/17
unprofessional [1] 119/9
unspecified [1] 43/17
until [5] 55/24 63/6 63/14 93/3
113/3
untrustworthy [2] 45/11 83/12
untruthful [1] 80/5
unusual [1] 78/18
unwillingness [1] 67/7
up [60] 6/6 19/4 24/17 28/7 28/7
36/1 38/14 51/1 51/4 51/10 53/16
58/22 59/23 73/14 75/21 76/3 77/13
78/5 78/23 79/11 79/18 81/6 82/14
83/1 83/5 83/22 83/24 84/4 84/12
85/1 85/16 85/19 85/21 87/25 88/5
89/2 89/4 89/6 89/13 91/16 94/6 94/7
95/3 95/4 95/21 96/1 97/9 97/16
98/14 101/10 102/4 102/12 102/19
104/12 113/3 117/18 118/17 119/1
119/25 120/3
upon [2] 103/19 103/19
upset [1] 32/3
us [10] 5/16 5/21 5/23 6/24 72/25
72/25 96/22 106/18 114/25 120/11
use [12] 25/21 26/14 30/21 47/15
48/19 75/4 75/25 76/17 78/3 99/17
100/10 105/15
used [19] 1/18 21/14 25/2 30/10
30/17 32/1 55/25 57/4 57/4 57/6
57/20 57/22 72/23 90/11 92/14 94/23
98/12 107/24 115/5
uses [2] 60/4 109/5
using [14] 17/15 20/2 20/11 26/4
26/12 54/17 56/13 57/10 107/10
107/21 108/25 109/15 109/19 111/20
usual [1] 10/8
V
vaguely [3] 84/22 85/7 118/11
Valentine's [1] 14/25
value [2] 65/14 65/15
various [3] 3/16 7/4 16/19
Vegas [2] 56/11 56/15
verdict [6] 2/14 2/15 48/20 48/21
75/9 120/20
verify [1] 59/25
version [6] 2/7 3/21 58/3 58/17
58/18 72/8
versions [5] 18/21 57/21 57/22 60/4
60/11
very [15] 14/1 18/8 18/16 40/16 42/5
47/8 49/4 75/21 79/12 85/8 88/14
88/14 89/23 105/13 109/16
via [7] 18/10 19/25 20/7 20/16 22/11
23/14 109/16
victim [2] 17/1 34/24
views [1] 3/16
Virginia [1] 34/15
virtue [1] 8/11
visual [1] 49/2
VOLUME [1] 1/5
vs [1] 1/5
vulgar [1] 83/2
W
wait [2] 62/11 67/4
waited [1] 119/18
walk [2] 57/25 104/12
wall [1] 118/3
want [47] 2/20 4/7 4/9 4/15 12/25
31/1 33/20 40/15 44/24 54/25 59/13
63/7 66/14 67/6 67/12 67/21 67/24
68/8 68/15 68/15 69/25 72/12 73/15
73/18 75/25 76/7 77/8 77/17 79/24
82/18 83/8 83/9 83/10 89/3 90/1 93/6
99/20 102/21 102/22 103/3 103/5
103/11 103/14 105/13 106/1 106/24
119/21
wanted [24] 8/8 9/21 10/4 11/5 11/24
12/16 12/24 14/18 22/13 34/3 45/1
47/24 63/8 73/12 76/14 77/1 82/14
84/17 102/15 102/18 105/11 105/17
114/11 119/19
wanting [1] 89/8
wants [13] 3/24 26/2 47/11 57/18
62/9 63/23 67/10 69/10 83/11 85/15
103/1 107/8 107/23
warehouse [1] 68/12
warrant [2] 60/16 73/8
warrants [1] 97/2
wary [1] 73/13
was [430]
wasn't [14] 9/19 21/23 28/12 43/19
58/20 63/13 66/16 80/17 85/22 93/1
118/1 119/5 119/13 119/14
watch [4] 55/16 107/9 107/20 107/24
way [12] 28/16 40/4 49/18 50/11
62/12 71/13 75/21 76/3 81/2 84/6
88/23 94/25
ways [2] 5/1 10/24
we [224]
we'll [6] 14/7 15/2 19/7 87/7 96/15
102/2
we're [14] 4/19 5/23 23/3 47/2 53/3
53/10 53/11 55/11 55/15 56/9 62/3
62/10 69/16 89/23
we've [4] 37/15 40/23 86/8 87/1
weak [1] 3/5
website [2] 29/18 85/22
Webster [16] 1/19 28/10 31/6 49/12
97/21 106/2 109/12 109/22 110/20
111/9 111/17 112/1 112/14 113/8
114/12 120/24
WEDNESDAY [2] 1/12 122/10
week [3] 5/17 7/17 119/10
weeks [4] 44/12 45/6 95/25 117/24
weigh [1] 102/5
weight [1] 102/5
weird [2] 74/7 74/8
well [33] 2/5 2/24 4/17 5/12 7/3
14/1 17/24 31/24 32/15 47/23 52/12
54/2 58/19 63/23 64/25 67/4 67/14
67/16 70/23 83/12 83/19 85/6 89/2
89/3 91/17 92/18 94/13 94/20 103/14
107/12 109/4 113/8 114/5
well-dressed [1] 89/3
went [23] 8/17 22/14 23/22 28/6 34/3
34/13 38/9 38/13 41/18 50/21 51/4
51/16 51/23 64/21 67/11 69/6 75/22
75/22 85/19 102/15 102/16 118/7
118/8
were [134]
weren't [1] 85/17
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W
what [197]
what's [5] 7/3 23/10 24/17 68/3
76/17
whatever [3] 10/17 73/14 83/8
WhatsApp [32] 18/10 18/14 19/25 20/7
20/16 20/22 21/4 22/11 22/13 23/6
23/14 24/2 26/1 26/8 27/3 27/4 29/3
30/15 51/12 54/18 54/25 58/24 60/13
61/16 61/25 66/2 66/22 86/19 96/24
109/17 110/1 111/20
WhatsApps [1] 109/23
wheelhouse [1] 88/19
when [91] 3/4 4/18 5/17 5/19 6/11
9/9 13/12 20/5 20/14 20/17 21/20
22/10 22/12 23/8 25/13 25/18 25/24
28/6 34/3 38/2 42/4 42/21 45/7 45/18
45/21 47/21 48/4 48/15 55/21 58/25
59/23 62/13 63/8 63/24 65/6 65/23
66/16 66/19 67/8 67/14 68/21 69/6
73/7 74/2 75/7 75/7 75/15 76/8 76/14
77/4 78/16 78/23 79/17 82/19 84/25
85/2 85/9 88/15 88/21 89/20 90/10
90/20 91/2 91/15 93/1 94/5 94/24
94/25 97/19 98/23 99/17 100/10
100/18 101/11 102/21 107/12 107/15
109/13 112/1 112/22 113/16 117/25
118/4 118/13 119/1 119/16 119/18
119/19 119/20 120/1 120/8
whenever [2] 81/23 84/17
where [41] 2/13 4/16 5/1 5/7 8/19
8/21 19/24 21/8 21/18 21/25 21/25
23/18 24/14 42/23 43/22 44/7 44/10
44/11 45/20 46/3 51/15 52/6 54/14
54/15 56/1 56/23 60/7 60/8 60/10
60/18 72/14 81/25 87/14 92/12 101/22
107/25 108/2 110/2 111/11 113/1
118/19
whether [12] 9/13 35/24 36/21 41/25
42/1 71/20 73/15 84/21 86/6 86/16
105/24 116/4
which [20] 7/6 8/10 10/18 11/1 11/2
17/5 17/25 23/21 24/7 35/7 40/20
58/22 62/23 63/3 70/20 73/22 74/6
83/9 110/5 118/15
while [8] 5/23 6/20 9/21 59/10 62/5
71/23 106/21 107/21
whim [2] 76/4 77/5
who [61] 7/13 7/13 8/11 19/1 19/2
19/9 22/2 27/8 27/9 31/19 33/25
35/17 39/25 40/1 43/1 43/18 43/25
44/4 44/5 44/25 50/9 52/21 53/3
53/10 53/11 54/24 55/11 55/15 56/8
56/9 62/11 65/13 65/18 65/24 65/25
66/5 66/12 67/3 68/3 68/4 68/5 68/6
68/6 69/17 71/12 71/17 71/18 76/2
81/18 88/23 89/4 105/24 106/18 108/8
112/23 113/18 113/19 113/19 115/23
118/8 119/25
whoever [3] 57/10 57/12 109/15
whole [10] 4/1 33/3 39/4 46/9 65/22
66/11 68/23 84/12 99/6 107/2
whom [1] 117/7
whose [3] 65/19 106/4 115/23
why [45] 6/13 6/25 21/19 28/22 32/4
49/4 53/17 54/19 54/20 54/21 54/22
54/24 60/19 65/16 66/6 75/24 76/2
77/4 77/7 77/8 78/14 79/13 79/14
82/1 83/6 83/6 83/19 83/19 83/24
84/1 84/2 90/19 92/4 94/1 98/7 101/7
102/20 111/21 111/23 113/24 114/23
117/14 118/14 119/4 119/22
wife [15] 19/9 27/9 77/11 77/12 78/8
79/16 79/21 83/17 84/2 85/12 98/12
102/19 103/16 103/16 106/5
wife's [2] 83/4 106/21
wilfully [1] 37/2
will [47] 1/6 2/8 4/2 9/11 13/25
14/19 15/2 16/25 17/9 17/10 17/17
31/3 35/15 35/19 36/13 36/24 40/4
40/4 42/7 50/9 52/12 53/6 53/7 53/24
58/5 58/8 58/10 58/11 59/1 62/25
71/4 71/8 78/15 88/1 89/25 92/19
98/15 102/11 104/1 107/16 110/13
110/17 112/18 114/4 117/5 121/3
121/4
willful [1] 71/6
willfully [1] 36/12
willing [3] 69/11 70/11 97/23
willingness [1] 3/25
wire [22] 16/21 17/5 17/7 17/9 17/10
17/11 34/7 34/9 34/19 35/10 36/2
40/7 40/12 40/20 40/21 40/24 41/2
41/3 41/12 41/22 47/22 80/8
wires [1] 34/16
wish [1] 114/23
withdrawals [1] 102/9
withdrawn [1] 88/9
withdrew [3] 49/7 104/15 121/10
within [1] 107/25
without [12] 6/18 11/16 26/10 26/10
30/22 72/14 72/20 91/25 97/23 97/24
98/3 98/4
witness [16] 4/6 8/12 8/15 10/14
12/6 12/6 12/7 12/15 13/12 13/14
45/1 45/24 96/23 105/16 105/19 106/3
witness's [2] 8/22 9/14
witnesses [6] 78/17 78/21 81/25
96/19 103/18 105/10
wizard [1] 65/19
wolff [4] 1/22 1/25 122/4 122/23
woman [8] 76/2 76/3 77/5 77/12 83/24
90/21 98/7 101/7
won't [1] 14/2
wondering [1] 69/13
word [3] 2/13 93/4 105/20
words [9] 19/11 19/20 27/25 33/17
48/1 48/17 63/7 79/15 120/14
work [8] 21/16 26/3 61/14 63/8 63/11
63/19 67/11 88/13
worked [9] 19/6 19/9 19/22 20/8
28/13 109/6 111/24 113/11 115/23
working [16] 30/4 36/7 42/17 42/20
57/13 60/25 61/7 75/21 76/3 76/11
76/11 76/16 88/23 109/19 113/6
116/19
works [3] 5/1 27/9 60/6
worth [1] 102/6
would [121] 2/22 4/21 5/25 6/1 6/2
6/3 6/14 6/17 6/19 6/20 7/4 7/6 7/10
7/11 7/13 7/14 7/17 7/19 8/2 8/4
8/15 8/22 8/23 8/25 9/14 9/23 9/25
10/1 10/14 10/22 10/24 10/25 10/25
11/3 11/16 19/25 20/2 22/13 26/17
26/22 26/24 27/1 27/4 27/6 27/8
27/17 27/19 28/11 29/11 30/8 31/7
33/12 34/4 44/19 45/3 54/13 54/19
54/21 54/22 54/24 61/20 65/16 66/5
66/6 66/9 66/12 68/20 70/11 70/14
70/14 72/14 72/15 72/16 72/19 72/24
72/25 74/6 75/24 76/2 77/3 77/5 77/7
77/8 78/5 79/23 80/11 83/6 83/6
83/19 83/19 83/24 84/1 84/17 86/17
89/18 89/22 90/2 90/3 90/18 90/19
91/16 91/19 92/1 92/4 97/23 98/3
98/7 101/3 101/7 103/21 104/5 109/21
111/22 111/23 112/16 113/18 114/25
117/14 119/3 119/6 120/4
wouldn't [14] 7/24 10/25 10/25 24/23
86/13 86/20 90/5 90/5 93/6 99/24
113/19 115/18 115/20 115/22
writes [2] 111/3 111/4
writing [3] 7/11 7/12 24/6
written [3] 7/18 7/22 24/5
wrong [7] 19/12 23/18 67/4 68/10
89/10 91/4 109/24
wrote [2] 82/5 96/17
Y
Yahoo [23] 21/18 24/7 26/9 29/4
29/23 30/3 30/6 56/18 57/5 57/8
57/11 57/13 57/19 57/20 60/3 72/18
108/23 108/25 109/3 109/10 109/13
109/15 110/7
Yahoo.com [1] 73/5
yeah [3] 18/15 28/21 98/4
year [4] 61/21 106/5 106/10 116/11
years [4] 12/16 75/20 76/18 79/14
yelling [1] 119/14
yep [1] 114/8
yes [13] 4/24 11/22 14/16 49/3 51/20
64/19 83/18 85/14 86/12 104/24
104/25 105/2 120/19
yesterday [13] 44/4 65/21 75/16
78/18 80/1 80/23 84/20 102/17 103/3
103/6 112/19 117/19 117/21
yet [3] 90/15 121/6 121/6
you [647]
you'll [3] 38/3 99/22 101/10
you're [2] 70/22 112/25
you've [3] 24/2 54/5 90/17
your [66] 4/9 4/24 5/18 6/5 6/16 7/3
8/1 11/20 11/23 11/24 12/21 13/4
13/10 13/22 14/11 14/14 14/16 14/18
15/5 33/6 33/6 43/8 43/9 48/19 48/23
49/2 49/13 55/16 55/16 57/1 59/25
61/15 62/1 62/2 70/9 70/12 70/19
70/19 75/13 76/17 77/4 78/3 79/16
81/25 83/17 85/1 89/4 89/12 89/14
92/1 92/2 93/8 97/24 103/7 104/2
104/24 104/25 105/7 105/22 105/23
108/15 114/17 119/1 121/3 121/3
121/8
yourself [4] 50/11 54/20 99/22
111/19
yourselves [1] 121/7
Z
Zelle [1] 51/21
Zillow [1] 85/22
Zoom [1] 89/1
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