Court filing

Exhibit Gov Exhibit List — USA v. Merritts (Dkt. 34-4, D.D.C.)

Filed November 26, 2025 in USA v. Merritts; one of 82 filings from this case.

Record facts

Court	U.S. District Court for the District of Columbia
Filed	2025-11-26

U.S. District Court for the District of Columbia · No. 1:25-cr-00076-JMC · Doc. 34-4 · 2025-11-26 · Docket on CourtListener

Full text

Government
Plaintiff
Defendant
Joint
Court
UNITED STATES OF AMERICA

VS.

CORTNEY MERRITTS

Criminal No. 25-cr-76 (JMC)

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
001
April 2020 EIDL App - Vetted
USAO-002776
002
EIDL 1 Intake App
USAO-009635
003
July 2020 EIDL App - Merritts
USAO-002780
004
EIDL 2 Intake App
USAO-009610
005
Intentionally Left Blank
Intentionally Left
Blank
006
Intentionally Left Blank
Intentionally Left
Blank
007
July 2022 PPP Forgiveness App
USAO-002765
008
PPP App
USAO-009565
009
PPP - SBA Confirmation of
Forgiveness
USAO-002632

Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 1 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
010
PPP - Schedule C
USAO-009554
011
Intentionally Left Blank
Intentionally Left
Blank
012
PPP Application - Blank
USAO-010738
013
Onfido - Application Check
USAO-009556
014
Onfido - Bank Statement
USAO-009549
015
Intentionally Left Blank
Intentionally Left
Blank
016
Onfido - SBA 1149
USAO-009561
017
Intentionally Left Blank
Intentionally Left
Blank
018
Onfido - SBA 2484
USAO-009571
019
Onfido Signature Package -
Prestamos_PPP_Loan_Documents
USAO-009574
020
020_Onfido Signature Package -
Prestamos_Proof_of_Funds_Letter
USAO-009585
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 2 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
021
Onfido Signature Package -
Prestamos_SBA_Form_147_Note
USAO-009577
022
Onfido Signature Package -
Prestamos_Written_Consent_for_PP
P
USAO-009583
023
Onfido Signature Package -
Summary
USAO-009586
024
Onfido Signature Package- W-9
USAO-009591
025
Onfido - Photo
USAO-009560
026
Onfido – Driver’s License - Front
USAO-009559
027
Onfido – Driver’s License - Back
USAO-009558
028
Vetted Production - Text Messages
USAO-005229
029
Vetted Production - Emails
USAO-005444
030
2019 Tax Form 1040
USAO-002774
031
IRS - Vetted Response
USAO-009711
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 3 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
032
IRS - Merritts Response
USAO-009690
033
IRS - Merritts - Response
Documents
USAO-010721
034
IRS - Vetted Form 3050
USAO-009715
035
Intentionally Left Blank
Intentionally Left
Blank
036
Summary Exhibit - NFCU 2019
Activity
USAO-002773
037
Summary Exhibit - NFCU 2020
Activity
USAO-002792
038
Summary Exhibit - Merritts Expense
Breakdown
USAO-010744
039
Summary Exhibit - Daily Balance
USAO-010745
040
Summary Exhibit - Transactions
USAO-010746
041
Vetted SBA Application
USAO-002520
042
Intentionally Left Blank
Intentionally Left
Blank
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 4 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
043
Merritts SBA Application
USAO-002508
044
DocuSign Subpoena Response and
Certification
USAO-001744
045
DocuSign Subpoena Response
USAO-001825
046
Intentionally Left Blank
Intentionally Left
Blank
047
DocuSign Subpoena Response
USAO-001811
048
DocuSign Subpoena Response
USAO-001815
049
DocuSign Subpoena Response
USAO-001829
050
DocuSign Subpoena Response
USAO-001751
051
NFCU Subpoena Response and
Declaration
USAO-000893
052
NFCU Statement
USAO-009549
053
NFCU Overdraft Notification
USAO-002476
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 5 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
054
NFCU Overdraft Notification
USAO-002479
055
NFCU Overdraft Notification
USAO-002477
056
NFCU Past Due Notification
USAO-002475
057
NFCU Overdraft Notification
USAO-002478
058
Intentionally Left Blank
Intentionally Left
Blank
059
Thumbtack Subpoena Response
USAO-002415
060
Thumbtack Certification
USAO-002416
061
Yelp Subpoena Response and
Certification
USAO-002448
062
Vetted Movers and Couriers – Yelp USAO-002532
063
Vetted Movers and Couriers – Yelp USAO-002542
064
Task Rabbit Subpoena Response
USAO-002429
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 6 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
065
Pack & Load Invoice
USAO-002681
066
Pack & Load Service Provider
Application
USAO-002679
067
Cash App Transactions
USAO-002665
068
Cash App Transactions
USAO-002666
069
Cash App Transactions
USAO-002667
070
Cash App Transactions
USAO-002668
071
Cash App Transactions
USAO-002669
072
Cash App Transactions
USAO-002670
073
Cash App Transactions
USAO-002671
074
Cash App Transactions
USAO-002672
075
Cash App Transactions
USAO-002673
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 7 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
076
Cash App Transactions
USAO-002674
077
Cash App Transactions
USAO-002675
078
Paul Brown Lofts Payment Receipt
USAO-002482
079
Paul Brown Lofts Payment Receipt
USAO-002485
080
Paul Brown Lofts Payment Receipt
USAO-002484
081
Paul Brown Lofts Payment Receipt
USAO-002492
082
Paul Brown Lofts Payment Receipt
USAO-002488
083
Paul Brown Lofts Payment Receipt
USAO-002491
084
Paul Brown Lofts Payment Receipt
USAO-002490
085
Paul Brown Lofts Payment Receipt
USAO-002486
086
Paul Brown Lofts Payment Receipt
USAO-002489
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 8 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
087
Paul Brown Lofts Payment Receipt
USAO-002483
088
Paul Brown Lofts Payment Receipt
USAO-002487
089
Paul Brown Lofts Payment Receipt
USAO-002473
090
Paul Brown Lofts Payment Receipt
USAO-002466
091
Paul Brown Lofts Payment Receipt
USAO-002461
092
Paul Brown Lofts Payment Receipt
USAO-002460
093
Paul Brown Lofts Payment Receipt
USAO-002467
094
Intentionally Left Blank
Intentionally Left
Blank
095
Text Message – Paul Brown Lofts
USAO-002480
096
Text Message – Paul Brown Lofts
USAO-002481
097
Text Message – Advance Financial
USAO-002501
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 9 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
098
Text Message – Aspen Financial
USAO-002498
099
Text Message – CashNetUSA
USAO-002499
100
Text Message – OppLoans
USAO-002496
101
Text Message – Integra Credit
USAO-002500
102
Text Message – Aspen Financial
USAO-002495
103
Text Message – CashNetUSA
USAO-002494
104
Text Message – CashNetUSA
USAO-002497
105
Text Message – OppLoans
USAO-002493
106
Text Messages
USAO-002227
107
Text Messages
USAO-002221
108
Text Messages
USAO-002223
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 10 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
109
Text Messages
USAO-002217
110
Text Messages
USAO-002226
111
Text Messages
USAO-002191
112
Text Messages
USAO-002203
113
Text Messages
USAO-002224
114
Text Messages

USAO-002210
115
Text Messages

USAO-002196
116
Text Messages

USAO-002749
117
Text Messages

USAO-002750
118
Text Messages

USAO-002218
119
Text Messages

USAO-002761
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 11 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
120
Text Messages

USAO-002748
121
Text Messages

USAO-002759
122
Text Messages

USAO-002752
123
Text Messages

USAO-002760
124
Text Messages

USAO-002757
125
Text Messages

USAO-002755
126
Text Messages

USAO-002746
127
Text Messages
USAO-002199
128
Text Messages

USAO-002219
129
Text Messages

USAO-002256
130
Text Messages

USAO-002260
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 12 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
131
Text Messages

USAO-002261
132
Text Messages

USAO-002265
133
Text Messages

USAO-002266
134
Text Messages

USAO-002204
135
Text Messages

USAO-002209
136
Text Messages

USAO-002202
137
Text Messages

USAO-002206
138
Text Messages

USAO-002197
139
Intentionally Left Blank
Intentionally Left
Blank
140
Text Messages

USAO-002230
141
Text Messages

USAO-002248
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 13 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
142
Text Messages

USAO-002253
143
Text Messages
USAO-002742
144
Text Messages
USAO-002739
145
Text Messages
USAO-002738
146
Text Messages
USAO-002736
147
Text Messages
USAO-002743
148
Text Messages
USAO-002734
149
Text Messages
USAO-002740
150
Text Messages
USAO-002733
151
Text Messages
USAO-002730
152
Text Messages
USAO-002194

Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 14 of 20

EXHIBIT
NUMBER
DESCRIPTION OF EXHIBIT
BATES
NUMBER
MARKED
FOR I.D.
RECEIVED
IN
EVIDENCE
WITNESS
153
Text Messages
USAO-002207
154
Text Messages

USAO-002258

Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 15 of 20

DEFENSE OBJECTIONS TO THE GOVERNMENT’S EXHIBITS
AND GOVERNMENT RESPONSES
Exhibits 31, 32, 34
• Defense objection: These exhibits from the Internal Revenue Service are negative record
returns and admission, without sufficient foundation, would violate the Confrontation
Clause of the Sixth Amendment.
• Government response: The Government does not intend to admit Exhibits 31 and 32 at trial
and will remove these documents from the Exhibit List. The tax-related documents that the
Government does intend to introduce are: (1) the Defendant’s Form 1040 income tax return
filed for tax year 2019, certified as a true copy by the IRS (Exhibit 30), (2) a Form 3050
certification of lack of record showing that the Defendant made no other tax filings in his
name during the relevant time period (exhibit to be provided after it is obtained), and (3) a
Form 3050 certification of lack of record showing that the Defendant made no tax filings
in the name of his moving company (Vetted) during the relevant time period (Exhibit 34).
The certified copy of the Defendant’s Form 1040 income tax return (Exhibit 30) is self-
authenticating pursuant to Federal Rule of Evidence 902(4). It does not constitute hearsay
because it is not being offered for the truth of the matter asserted. See Fed. R. Evid. 801(c).
This evidence is being offered for the purpose of establishing that the Defendant’s
statements about his business’s income on his loan applications were fabricated because
they differed from the tax return actually filed with the IRS. The tax return is “true” in the
sense that it was the return that was filed with the IRS, but there is a distinct and critical
difference between the “true returns” and the borrower’s “true income.” Non-hearsay use
of evidence as a means of demonstrating a discrepancy does not implicate the
Confrontation Clause. United States v. Jiminez, 513 F.3d 62, 79-81 (3d Cir. 2008); see also
United States v. Austin, 774 F.2d 99, 101–02 (5th Cir.1985) (false tax returns were not
hearsay because they were not admitted for the truth of what they asserted).
The certified tax return is also admissible under exceptions to the hearsay rules including
Federal Rules of Evidence 803(6) (business records) and 803(8) (public records) and is
self-authenticating pursuant to Federal Rule of Evidence 1005. Such a record is admissible
over Confrontation Clause objections, even if it is foreseeable that the document could be
used in a later criminal proceeding, because such use is not the primary purpose of the
document. See Melendez-Diaz v. Massachusetts, 557 U.S. 305, 324 (2009) (“Business and
public records are generally admissible absent confrontation not because they qualify under
an exception to the hearsay rules, but because—having been created for the administration
of an entity’s affairs and not for the purpose of establishing or proving some fact at trial—
they are not testimonial.”).
With respect to the Form 3050 certifications, in 2013, Rule 803(10) was amended in
response to Melendez-Diaz, in which the Court declared that a testimonial certificate could
be admitted if the accused is given advance notice and does not timely demand the presence
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 16 of 20

of the official who prepared the certificate. Id. at 325-327. The amendment incorporates,
with minor variations, a “notice-and-demand” procedure that was approved by the
Melendez-Diaz court. See Fed. R. Evid. 803(10) advisory committee’s note (2013).
Pursuant to the revised rule, a certification under Rule 902 that a diligent search failed to
disclose a public record, such as the Form 3050 certification described above, is admissible
under the exceptions to hearsay provided that the “prosecutor intending to offer a
certification provides written notice of that intent at least 14 days before trial,” which the
Government does by virtue of this response, and “the defendant does not object in writing
within 7 days of receiving notice – unless the court sets a different time for the notice or
the objection.” If the Defendant does not timely stipulate to the admissibility of such
records, the Government will call a witness who has performed the requisite searches.
Exhibits 38, 40
• Defense objection: These summaries include accounting and characterizations that imply
expert testimony or opinion is involved; the Government has not provided notice of an
expert witness pursuant to the court's deadline and therefore they are improper.
• Government response: For the reasons identified in the Government’s Motion In Limine
to Admit Certain Evidence (ECF No. 23), these exhibits are admissible under Federal Rule
of Evidence 1006. Moreover, for the reasons explained in the Government’s Opposition
(ECF No. 30) to Defendant’s Motion in Limine to preclude expert testimony (ECF No. 22),
these exhibits in no way implicate or require expert analysis or testimony.
Exhibits 41, 43
• Defense objection: These are unsigned documents purporting to be reports of the
previously exhibited applications. Without more foundation, we would object to
authentication and possible hearsay.
• Government response: The Government anticipates laying sufficient foundation for these
exhibits through its witnesses at the trial. This objection is therefore premature.
Exhibit 51
• Defense objection: This exhibit consists of voluminous bank records for Mr. Merritts. The
Government has specific months pulled out as other exhibits, so we are questioning the
purpose of this exhibit and do not know yet if we would object.
• Government response: To the extent the defense objects to the introduction of bank
statements from irrelevant time periods, for example from 2017 to 2018, the Government
can excise those statements from the exhibit. However, the Defendant’s bank statements
showing his account balances, expenses, and deposits during the relevant time periods are
directly relevant to show, inter alia, that the income and revenue figures reported in the
Defendant’s loan applications were false, and that the Defendant had few, if any, expenses
related to his purported moving business(es).
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 17 of 20

Exhibits 53-57
• Defense objection: These are screenshots regarding accounts of Ms. Turner and do not
mention Mr. Merritts. We would object on authentication, hearsay, and relevance/403.
• Government response: These records were obtained from Lisa Turner, one of the
Government’s anticipated witnesses. Ms. Turner and the Defendant were in a romantic
relationship and shared an apartment during the relevant time period, including when the
two charged fraudulent loan applications were filed. Ms. Turner is expected to testify
about, inter alia, how much work the Defendant did or did not do during that time in
relation to his moving business, and the Defendant’s income, general financial situation,
and financial constraints, including his ability to pay his share of rent, bills, and other living
expenses. These exhibits show that Ms. Turner’s bank accounts were regularly overdrawn
at least in part as a result of her having to pay rent for the apartment she shared with the
Defendant. They are therefore relevant.
As to the Defendant’s other objections, Ms. Turner can authenticate these records herself.
The Government does not expect to introduce these records for the truth of the matter
asserted, but they may be needed for other non-hearsay purposes, such as to either refresh
Ms. Turner’s recollection or for impeachment.
Exhibits 67-77
• Defense objection: These are screenshots regarding payments from Ms. Turner to Mr.
Merritts. We would object on authentication, hearsay, and relevance/403.
• Government response: These records were also obtained from Ms. Turner who can
authenticate them. They are relevant for the reasons stated above, to the extent they
demonstrate the Defendant’s general financial condition during the relevant time period.
The Government does not expect to introduce these records for the truth of the matter
asserted, but they may be needed for other non-hearsay purposes, such as to either refresh
Ms. Turner’s recollection or for impeachment.
Exhibits 78-93
• Defense objection: These are screenshots of Ms. Turner paying the rent for her apartment.
We would object on authentication, hearsay, and relevance/403.
• Government response: These records were also obtained from Ms. Turner who can
authenticate them. They are relevant for the reasons stated above, to the extent they
demonstrate that Ms. Turner was paying the rent for the apartment she shared with the
Defendant. The Government does not expect to introduce these records for the truth of the
matter asserted, but they may be needed for other non-hearsay purposes, such as to either
refresh Ms. Turner’s recollection or for impeachment.

Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 18 of 20

Exhibits 95-105
• Defense objection: These are screenshots regarding the financial situation and accounts of
Ms. Turner. We would object on authentication, hearsay, and relevance/403.
• Government response: These records were also obtained from Ms. Turner who can
authenticate them. They are relevant for the reasons stated above, insofar as they are
probative of Ms. Turner’s financial condition during the relevant time period, during which
she was in a romantic relationship and cohabitated with the Defendant. The Government
does not expect to introduce these records for the truth of the matter asserted, but they may
be needed for other non-hearsay purposes, such as to either refresh Ms. Turner’s
recollection or for impeachment.
Exhibits 106-154
• Defense objection: These are screenshots of text messages/app messages involving
unknown people and dates outside the time period of this case. As a blanket, we would
object on authentication, hearsay, and relevance/403, but recognize that some messages (if
authenticated) do refer to the moving business.
• Government response: These records were also obtained from Ms. Turner who can
authenticate them.
These exhibits primarily consist of communications between Ms. Turner and the
Defendant, most of which relate to his moving business and financial condition in 2019
and 2020.1 They are probative of the lack of accuracy of the information that the Defendant
reported on his EIDL and PPP loan applications. The statements by the Defendant are not
hearsay because they are statements by a party-opponent and are being offered against him
by the Government. Fed R. Evid. 801(d)(2). Ms. Turner’s (and occasionally other
individuals’) portions of those conversations do not constitute hearsay under a plethora of
exceptions. First, in many instances, they do not constitute “statements” under Federal Rule
of Evidence 801(a). See United States v. Moore, No. CR 18-198 (JEB), 2021 WL 1966570,
at *5 (D.D.C. May 17, 2021) (“A statement is an oral assertion, written assertion, or
nonverbal conduct, if the person intended it as an assertion, not a question, command,
greeting, or other nonassertive communication where any conveyed messages were merely
incidental and not intentional.” (citations omitted)). Second, many of them would be
offered not for the truth of the matter asserted but rather to provide important context to
understand the Defendant’s statements, or to show the effect of the Defendant’s statements
on Ms. Turner (i.e., effect on the listener). See United States v. Safavian, 435 F. Supp. 2d
36, 45 (D.D.C. 2006) (statements are not hearsay if they “go to the defendant’s intent,

1At the very least, the following exhibits consist of text message exchanges involving the
Defendant and Ms. Turner or another individual: 106, 107, 108, 109, 110, 111, 112, 113, 114, 115,
118, 119, 120, 121, 123, 124, 125, 126, 128, 129, 130, 131, 132, 133, 134, 135, 137, 138, 140,
141, 142, 143, 144, 145, 146, 147, 148, 149, 150, 151, 152, 153, and 154.
Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 19 of 20

motive, or state of mind, help to explain his future conduct, [or] serve to refute any
possibility of mistake or misunderstanding”).
Finally, to the extent Ms. Turner’s portions of conversations with the Defendant could be
considered hearsay, they are typically admissible under one or more exceptions to the rule
against hearsay, including, inter alia, Rule 803(1) (because they are statements she made
describing contemporaneous events) and 803(3) (because they are statements of her mental
and emotional condition).
To the extent this set of exhibits does not involve statements by the Defendant, the
Government does not expect to introduce them for the truth of the matter asserted, but they
may be needed for other non-hearsay purposes, such as to either refresh Ms. Turner’s
recollection or for impeachment.

Case 1:25-cr-00076-JMC Document 34-4 Filed 11/26/25 Page 20 of 20

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Exhibit Gov Exhibit List — USA v. Merritts (Dkt. 34-4, D.D.C.)

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