Transcript of Motions as to Dustin Sean McCabe held on 1/24/2025 — USA v. McCabe (Dkt. 106, S.D. Fla.)

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U.S. District Court for the Southern District of Florida · No. 9:24-cr-80103-AMC · Doc. 106 · 2025-05-09 · Docket on CourtListener

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION
CASE NO. 24-cr-80103-AMC-1 
UNITED STATES OF AMERICA, 
Fort Pierce, Florida 
Plaintiff,
January 24, 2025
vs.
9:40 a.m. - 11:17 a.m.
DUSTIN SEAN MCCABE,
Defendant. 
Pages 1 to 88
______________________________________________________________
TRANSCRIPT OF MOTIONS
BEFORE THE HONORABLE AILEEN M. CANNON
UNITED STATES DISTRICT JUDGE
APPEARANCES:
FOR THE GOVERNMENT: 
UNITED STATES ATTORNEY'S OFFICE 
ZACH KELLER, ESQ. 
TANNER P. STIEHL, ESQ. 
99 NE 4th Street 
Miami, Florida 33132 
FOR THE DEFENDANT: 
LAW OFFICE OF TERRENCE O'SULLIVAN 
TERRENCE O'SULLIVAN, ESQ. 
1 NE 2nd Avenue 
Suite 200 
Miami, Florida 33132 
LAW OFFICE OF CALISHA A. FRANCIS 
CALISHA A. FRANCIS, ESQ. 
7481 NW 37th Court 
Lauderhill, Florida 33319 
STENOGRAPHICALLY REPORTED BY:
LAURA E. MELTON, RMR, CRR, FPR
Official Court Reporter to the 
Honorable Aileen M. Cannon
United States District Court
Fort Pierce, Florida
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(Call to the Order of the Court.)    
THE COURT:  Good morning.  Please call the case.  You 
may be seated, unless you're addressing the Court. 
COURTROOM DEPUTY:  United States of America v. Dustin 
Sean McCabe, Case Number 24-cr-80103.  
Will the parties please make your appearance, starting 
with the United States. 
MR. KELLER:  Good morning, Your Honor.  Zachary Keller 
and Tanner Stiehl on behalf of the United States.  
THE COURT:  Good morning.  
MR. O'SULLIVAN:  Good morning, Your Honor.  May it 
please the Court.  Terrence O'Sullivan and Calisha Francis for 
the defense, along with Mr. McCabe, who is present at the 
defense counsel's table. 
THE COURT:  Good morning to all of you.  And good 
morning, Mr. McCabe.  
You may all be seated again, unless you are addressing 
the Court.  
This is a motion hearing on two pending motions.  There 
is a motion to sever filed by the defense, which, correct me if 
I'm wrong, Mr. O'Sullivan, seeks to sever Counts 1 and 2 from 3 
and 5.  Is that correct?  
MR. O'SULLIVAN:  Yes, ma'am, that's correct. 
THE COURT:  Okay.  That motion has been fully briefed.  
There is also a government motion in limine which seeks to 
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introduce various pieces of evidence under Federal Rule of 
Evidence 404(b), and then also makes a final argument related 
to irrelevant evidence.  And I think there is no dispute on 
that issue, but we will get to it.  That's, again, a motion 
filed by the government which too is fully briefed.  
I have reviewed these motions and pertinent authorities 
cited therein, so I'm prepared to hear argument.  
Let's start first with the motion to sever.  
Mr. O'Sullivan.  
MR. O'SULLIVAN:  Thank you, Your Honor.  
Again, may it please the Court.  
Judge, looking at the indictment, it's a five-count 
indictment, and we are looking to sever Counts 1 and 2 from 
Count 3 and 5. 
THE COURT:  Before you proceed -- 
MR. O'SULLIVAN:  Yes, ma'am. 
THE COURT:  As you know, our court reporter is taking 
down every word.  So let's be mindful of that and try to speak 
slowly for her.  Thank you. 
MR. O'SULLIVAN:  Sorry, Your Honor. 
Basically, the crux of our argument is that there is no 
rational relationship between the negligence that occurred, 
causing the unfortunate death of this young lady, and the 
subsequent wire fraud or PPP loan fraud.  The case law suggests 
that this must be some type of common plan or scheme, which 
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it's not.  The negligence, we would argue, was an accident.  
It's something that happened on the open water, and it had 
absolutely nothing to do with a financial transaction that 
occurred well over a year down the road.  
We would argue that the negligence could be described 
as a general intent crime, whereas, the PPP loan and the wire 
fraud would be specific intent crimes.  
Furthermore, the dates of these incidents are far apart 
in time; the elements of the crimes are completely and totally 
different; and the victims are different.  The government also 
mentioned, as far as the interpretations of Rule 8 and Rule 14, 
for a judicial economy and to not empanel extra jurors and take 
up more time, that there is going to be an overlap of 
witnesses.  
Now, I don't know who the government is going to call 
for each of the different charges, but, as far as I know, there 
is 23 witnesses listed, and I can only see one witness that 
would potentially be able to testify to both.  The only 
overlapping -- and I wouldn't even call it an element -- the 
over -- the only overlapping part of the government's case 
would be a witness with the initials of SB, who was on the boat 
the day that the death occurred and who was also kind of 
wrapped up in a conversation of getting a PPP loan.  
So as far as the judicial economy argument that I 
expect the government to make, we're only looking at one 
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witness, as far as I can tell, that would -- that would testify 
to both Counts 1 through 2, and then separately through 
Counts 3 through 5.  
THE COURT:  If we drill down on the chronology -- so 
Count 1 references an alleged offense date of March 29, 2020 -- 
that's correct?  
MR. O'SULLIVAN:  Yes, ma'am. 
THE COURT:  And then Count 2 has a March 5, 2020, date.  
So knowing that, can you walk me through just the chronology 
for the fraud charges so that I can better understand any 
temporal connection?  
MR. O'SULLIVAN:  Well, the fraud charges were more than 
a year down the road.  And they -- they involved completely 
different elements and different victims and different 
witnesses to prove up those charges.  So the negligence -- 
THE COURT:  Well, in the indictment, for example, I see 
Count 1 again, "on or about March 29, 2020."  And then when I 
shift to the wire fraud counts, I see "in and around March 2020 
the defendant caused the vessel to be modified so that its 
charters could use the vessel for paid charters," with 
additional allegations in March and then continuing forward 
into April, with the submission of alleged false PPP loan 
applications.  
So would you agree that we don't really have a very 
significant break in time?  
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MR. O'SULLIVAN:  Well, the submission of the actual 
loan came in February of 2021, which is 11 months after the 
alleged negligence.  The alleged negligence started, I would 
imagine the government's going to argue, weeks prior to 
the -- to the untimely death.  But it ended on the date of the 
death.  That's when the negligence itself ended.  
The electronic submission of the false -- alleged false 
PPP loan was submitted in February of '21, and also May of '21, 
and August of '21.  So we're talking between 11 and about 16 or 
17 months subsequent.  
So we would argue that there is a temporal difference 
as far as time goes, but, more importantly, this was not a 
common plan or scheme.  One has nothing to do with the other.  
THE COURT:  And I have heard you say that.  But, of 
course, the government responded that they do very much relate 
to one another because the unfortunate passing of the victim 
formed the impetus for the PPP fraud.  So what do you have to 
say about that?  
MR. O'SULLIVAN:  I would take issue with that, Judge.  
Obviously, the PPP loan is a unique thing that happened in our 
history; it happened because of COVID.  We don't know whether 
or not Mr. McCabe would have applied for a loan whether or not 
this death occurred or not.  Lots of businesses, I would argue, 
tens of thousands of businesses throughout the country applied 
for PPP loans, and they did not all do it just because their 
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business was failing.  A lot of people just wanted extra cash 
for their payroll.  A lot of employees were not working during 
that time, and -- and small business owners were kind of 
feeling the squeeze.  So the government has argued in their 
reply brief that the negligence caused the PPP loan, but we 
don't know that and we can never know that.  
Mr. McCabe, like other small business owners, may have 
applied for that loan anyway to meet payroll and to -- and to 
pay necessary business expenses.  
So I just think it's a stretch to say that the 
negligence -- you know, because of that untimely passing, that 
caused the PPP loan applications.  I think there could have 
been a multitude of reasons why someone would apply for a PPP 
loan; whether their business was slowing down, whether it was 
maintaining the status quo, or whether it was excelling.  
THE COURT:  Do you -- this is kind of a more broad 
question.  But do you agree that, in considering this motion to 
sever, I'm permitted to evaluate not only the indictment but 
also a government proffer about evidence?  
MR. O'SULLIVAN:  Yes, I would agree with that. 
THE COURT:  Okay.  So if that's the case, then I think 
the government relies on evidence that they believe does draw a 
connection between the alleged negligence and the PPP fraud.  
So although, as a theoretical matter, businesses around the 
country were, of course, seeking federal assistance, given the 
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pandemic in this particular case -- and I will hear from the 
government in a moment.  Is there not evidence that indicates 
following -- following the incident on the vessel the financial 
condition of the business was such that an infusion of cash was 
necessary to keep it afloat; and, therefore, that really does 
draw that connection that is necessary to avoid severance?  
MR. O'SULLIVAN:  I think that's a fair statement, 
Your Honor.  I think that's part of it.  But I think what we 
have to look at, and what, respectfully, I'm asking the Court 
to look at, is there a rational relationship beyond just that 
possibility, between the negligence and the wire fraud?  
THE COURT:  Uh-huh.  
MR. O'SULLIVAN:  But, more importantly, how is the jury 
going to interpret that?  And that's what our concern is, is 
that the jury is going to look at Counts 1 and 2, negligence, 
and while it could be the government's job to make a defendant 
look bad, that's fine in a criminal trial, it's going to unduly 
prejudice a jury to hear that the negligent and very sad death 
of this woman, and especially the inflammatory way in which she 
passed, you know, that's going to inflame the jurors.  I don't 
want a jury to then think that somehow Mr. McCabe used that 
death to profit.  
THE COURT:  Uh-huh.  
MR. O'SULLIVAN:  I think that that's -- that is my main 
concern, is that a jury is going to say, well, this lady died 
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and now you're trying to profit off of it.  And I think that's 
going to unduly prejudice them, and that's why we're asking for 
two separate juries to evaluate each set of facts and each set 
of circumstances separately.  
THE COURT:  All right.  What's your best authority to 
support severance in this context?  The government has cited, I 
think, several cases where motions to sever have been denied 
even where, perhaps, at first glance the charges seemed 
distinct.  
MR. O'SULLIVAN:  Judge, it would be on page 2 of our 
motion, United States v. Davis.  Let me get that cite just so 
the record is clear.  That's 773 F.2d 1180; it's 
Eleventh Circuit, 1985.  
Also, Rule 8 and Rule 14, I believe, give the Court 
wide discretion --
THE COURT:  Uh-huh. 
MR. O'SULLIVAN:  -- to make that determination based 
upon -- upon the case law.  
We would also rely upon United States v. Weaver, 
905 F.2d, 1466. 
THE COURT:  Can you engage a little bit more with the 
facts in Davis and Weaver?  
MR. O'SULLIVAN:  If I may have one moment, Your Honor. 
THE COURT:  Okay.  
MR. O'SULLIVAN:  In Davis there was a gun charge and a 
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cocaine charge. 
THE COURT:  Uh-huh. 
MR. O'SULLIVAN:  I would certainly agree that those 
would not have to be severed, and I wouldn't ask for those to 
be severed because in narcotics cases guns are often used as 
part of the tools of the trade; they kind of go hand in hand.  
However, that case does talk about Rule 8 and whether joinder 
was -- was proper.  In that case, you know, a co-conspirator 
gave a gun to the other co-conspirator, which was used as part 
of -- as part of their transaction.  So those were closely 
related.  However, that case just does give the outline as to 
what's not related.  
Some of the case law that the government relied upon 
are armed robberies with guns, which kind of have to go 
together.  It would be, I would say, improper to sever those 
types of cases.  The government also heavily relied on a 
federal housing fraud case where I believe it was -- eight 
different co-conspirators used the same agent.  And those are 
all intertwined pretty closely together, and I could see why a 
Court would exercise its discretion and deny a motion to sever.  
That makes perfect sense.  
But these -- again, these have different elements, 
different victims.  They're far away in time.  And I think, 
more importantly, it would just unduly prejudice the jury.  And 
that's the crux of our argument, Your Honor. 
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THE COURT:  Okay.  Thank you.  
Who will be arguing for the United States?  
MR. KELLER:  Zachary Keller, Your Honor. 
THE COURT:  Thank you. 
MR. KELLER:  So I want to begin by highlighting -- and 
this is something that we talk about in page -- on pages 8 
through 10 of our motion -- or our response, and that you 
talked about actually in engaging with Mr. O'Sullivan.  That 
the Eleventh Circuit routinely approves of cases where there 
is, on the one hand, a component of violence to a type of 
crime, and then there is fraudulent -- or that type of activity 
that then happens afterward for some reason.  You know, 
sometimes -- and for the Mentor case, for example, that we 
discussed, that's a case where someone killed someone in a 
robbery and then took a mail key, I believe it was, from the 
victim, and then used it later to commit fraud.  
And the issue on appeal was, well, should these two 
things have been treated completely separately in two 
completely separate trials?  Those facts are far more 
prejudicial, far more challenging, I think, in that sense than 
here.  And the Eleventh Circuit said no.  And that's because of 
the fact that the Eleventh Circuit, like all other circuits, 
reads Rule 8 and Rule 14 of the federal rules to favor, and 
strongly favor, keeping trials together, both for reasons of 
economy and just for reasons of making sure that we're able to 
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run our courts efficiently.  
THE COURT:  I mean, I'm aware of that general 
proposition.  Certainly, there are economies to be served and 
efficiency.  But can you just talk to me more about, really, 
the connection between -- between the Counts 1 and 2 in this 
case versus 3 and 5, and why it would -- it would factually 
make sense to present the case to the jury in one overall 
bucket?  
MR. KELLER:  Yes, Judge.  And that was going to be the 
next thing I spoke to was the chronology here.  And I want to 
clarify a couple of things from when Mr. O'Sullivan was 
speaking.  
And one thing that's worth noting right off the bat -- 
and I actually don't know that I made this clarification in our 
response -- that specifically Count 4, which is the May 14th of 
2021 count -- so what that relates to is, there were two 
separate PPP loans here.  And just to talk about the 
chronology -- so we have the March 5th purchase of the vessel 
and then the statement that was made about its recreational 
use.  There was MCGF, the victim's death on March 29th.  And 
then -- and I mentioned this in the response -- April 3rd is 
when the defendant first engaged with someone at the marina to 
say, Hey, I need you to print out this PPP loan application.  
I'm going to fill it out.  
He fills it out that day.  He emails -- he has the 
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person email it to him.  
A month later, so on -- in March of 2020 -- or May of 
2020, rather, is when the defendant filed his first PPP loan.  
I mean, I actually do think I make reference to that, now that 
I think about it, in the recitation of the facts because it's a 
month after that April application.  
Let me just -- maybe I didn't make reference to it.  
But a month later, in May of 2020, he files his first PPP loan 
with the revenue amount that is slightly higher than this 
April 3rd handwritten one that he submits.  And then the 
following year he applies for what's called loan forgiveness 
for PPP loans.  And as Your Honor is probably aware, the way it 
worked was, you got your loan and then later you were able to 
file to have it completely forgiven.  
So in these PPP prosecutions, sometimes we charge the 
initial wire, sometimes we charge the subsequent loan -- or 
loan forgiveness application.  I just want to make clear that 
here we do have conduct in May of 2020 that is going to be 
proving this wire fraud count of Count 4 directly because it's 
the actual loan application that he gets.  
And then after that, what you have is the defendant 
sells his vessel in November of 2020.  And he then has to -- 
THE COURT:  Wait.  I'm sorry.  I was in 2021, at this 
point, for Count 4 on the loan forgiveness.  Are we going back 
to 2020 now?  
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MR. KELLER:  Yes.  I'm sorry. 
THE COURT:  Okay. 
MR. KELLER:  I was at -- May 2020 was the first PPP 
loan, and then in November he sells the vessel, and then the 
following year is when he first submits a second PPP loan in 
February.  And then in May, he submits an application for a 
forgiveness application for the first loan, and then in August 
he submits a forgiveness application for the second loan.  
THE COURT:  Okay.  
MR. KELLER:  And one of the things to highlight, that I 
just didn't include in that chronology, but that you had spoken 
to Mr. O'Sullivan about, is the fact that shortly after the 
killing, shortly after the March 29th death, Mr. McCabe is 
speaking or texting two Coast Guard employees, saying, "After 
this happened, I'm now out of money."  And one thing that 
Mr. O'Sullivan talked to you about, as he was making his 
argument, is exactly the defense he is going to be using in 
this case for the PPP.  He is going to be saying this was 
legitimate activity, this was a business operating, trying to 
cover its expenses.  And exactly the things that we have been 
talking about here are what we're going to do to prove that 
that wasn't true.  
That's why it's so important that we're proving up all 
of this activity that happened before relating to MCGF's death 
because that is showing why his business went out of business, 
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and the same way that that April 9th Captain of the Port Order 
in 2020, that is discussed in the motion, does.  
So -- and, Your Honor, do you have any more questions 
about the chronology?  
THE COURT:  Would there be any other means of showing 
that the business was out of business without referencing the 
death of the female victim?  
MR. KELLER:  The only evidence that doesn't reference 
that would be the sale of the vessel in November.  Of course, 
our position and our explanation for why he sold the vessel is 
because he was no longer allowed to operate it because of the 
fact that he had done this; and that is from the Captain of the 
Port order about the vessel.  So even that one is still, like, 
part -- part of the story of that is still the fact that he had 
done this.  But that is, kind of, a little more separate.  
Beyond that -- 
THE COURT:  What do you say, though, to the sort of -- 
that general gut instinct that maybe there is this -- this 
danger that a jury hearing the facts on March 29th, followed 
quickly by requests for government money to continue operating 
what effectively was a terminated business would -- would 
perceive Mr. McCabe as someone who is effectively profiting 
from alleged negligence as to the death of an innocent 
passenger?  
MR. KELLER:  So, Judge, my response to that is that 
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there is nothing unusual about that, that we try cases like 
this all the time where there are multiple crimes.  And this 
danger that you're speaking to is always present.  And we have 
an effective and proven way that we deal with that, which the 
Eleventh Circuit talks about time and again, which is the jury 
instructions.  That's why we have instructions that say you are 
to consider evidence for one count solely to that count and 
then another count solely to that count is because -- and, 
again, with the Eleventh Circuit wanting these cases to be 
tried as one case, we do that by having instructions in the 
same way that, with 404(b) evidence, we will say we understand 
that there is some type of issue here, which is why we have 
instructions in the first place.  So that's the first thing I 
would say about that.  
The second thing is that, you know, a lot of times it's 
kind of the reverse.  They think -- and what I mean by that is 
the defense's argument is that once they see the manslaughter, 
they're going to be prejudiced as to the fraud. 
THE COURT:  Uh-huh. 
MR. KELLER:  Whereas, usually it's the other way 
around.  Like, the fraud is -- or the manslaughter is causing 
the prejudice about the -- or -- I'm sorry.  
Let me make sure I articulated that correctly.  
So I'm saying their argument is that the fraud is going 
to prejudice the manslaughter.  So, in other words, they're 
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going to see he tried to profit off of government stuff, and 
it's going to make them think he was more likely to be 
negligent, I suppose, is the argument. 
THE COURT:  I think perhaps it was more the other way 
around; that the manslaughter was going to taint the jury into 
convicting him on the fraud counts because they will think that 
he is, you know, brazenly seeking money from the government, 
despite his negligence on the manslaughter.  
MR. KELLER:  I think that's the more intuitive.  I 
think that's just from the way I was reading the defense's 
motion, that it was the opposite --
THE COURT:  Uh-huh. 
MR. KELLER:  -- that I was reading.
But to respond to your more intuitive one, first off, I 
would say that those are exactly the arguments that are 
addressed in all of those cases that I started out speaking to.  
And that they have those exact answers, which is that, 
number 1, we have the instructions and that, number 2, this is 
how trials are wanted to be done by the Eleventh Circuit, by 
the federal rules.  
Also, I would just add, though, that when it comes to 
this particular case, that -- and this is all the -- more than 
these other cases, where, for example, with the robbery, Mentor 
that I was talking about, you could very easily imagine two 
separate trials that are completely separate about that.  You 
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have the robbery, and then you have this fraud that happens 
totally separate and apart.  
Here it's different because of PPP.  Because of the 
fact that that type of fraud inherently involves the defendant 
arguing that that business, Florida Scuba Charters, was 
legitimate, was operating, was doing things in the normal 
course.  And our evidence against that is, on the one hand, 
going to be what happened to the money?  That he was buying a 
PGA Club membership, that he was cashing it out on various, 
you know, random expenses that were not payroll.  But, on the 
other hand, it's also going to be showing how that business was 
no longer operating, which is that killing, which is what 
happened after the killing, which is that he, number 1, sends 
these texts saying "I'm out of money.  The business is shut 
down after this."  
And then, number 2, the April 9th order from the 
Captain of the Port of Miami saying because of this, because 
this happened, we have found that your boat is no longer safe 
to operate, that you're not allowed to do this anymore.  
So it's really -- 
THE COURT:  Can you point to me in your memorandum the 
text messages, again, that you're talking about?  
MR. KELLER:  Yes, Judge.  This is on page 3.  I tried 
to put them front and center because they are very important 
evidence.  And just as further context, what they're discussing 
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here is that Mr. McCabe had not enrolled in a drug testing 
program before this happened.  And one of the immediate 
concerns of the Coast Guard was to get drug test results from 
him and from his crew mates or his people on the vessel.  And 
this is an exchange that happens as they're discussing this.  
THE COURT:  So, factually in this case, what's your 
strongest evidence of a connection between Counts 1 and 2 and 3 
and 5?  I take it, of course, these text messages you're 
relying on.  Is there anything else?  
MR. KELLER:  So we would point to these text messages 
as well as the Captain of the Port order, which is something we 
will discuss in the motion in limine which speaks to the 
defendant's ability to operate that vessel.  Those would be, 
kind of, the two -- 1A, 1B, most important evidence, 
after -- in the immediate aftermath of the killing.  But we 
would also submit that the fact of what happened, the fact of 
how awful it was, the fact of how traumatizing it was, as 
reflected in his -- is also evidence.  
And I just want to note, as I say that, that 
Mr. O'Sullivan said, you know, there is not -- there is not 
going to be any direct -- he is not going to say, you know, 
because of this, this happened.  But we use circumstantial 
evidence all the time.  And all of this is circumstantially 
proving that the defendant had this happen.  He stopped 
operating the business.  He needed money.  He was out of money, 
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as he said.  And then he did the PPP loans to get some money.  
And it's really that simple. 
THE COURT:  Can you speak to me about the 
inefficiencies, as you say, that would be created by a 
severance?  The defense has said there really wouldn't be a 
huge burden because the factual witnesses overlap to some 
degree, but not to a great degree. 
MR. KELLER:  So I spoke in the motion about two 
witnesses who -- whose testimony, in a very, kind of, direct 
way, overlaps.  The one in particular who is quite important is 
SB.  And the reason that she is so important is because on the 
one hand, she will testify about the defendant -- and this 
speaks to Count 2, as well as Count 1 -- that the defendant 
bought this vessel; that he had told her that the vessel -- 
you know, that it was going to be used for scuba.  She knew him 
as a scuba charter person.  So that wasn't surprising to her at 
the time.  She didn't know anything about what he was telling 
the Coast Guard.  
And then as this killing happened, she was someone who 
was talking to and seeing what happened as it happened, in the 
sense that Jennifer Hester, the day before, had had this 
injury, and she had seen the injury, that she had engaged with 
him about this.  And then afterwards Mr. McCabe had spoken to 
her about doing PPP loans.  And she is going to testify, at 
least, you know, from prior witness interviews, that the thing 
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that she found so curious about it is that she looked into it 
and she was thinking to herself:  How is it that he could 
manage to get $20,000 for a loan, given how small that business 
was?  
So this speaks directly to this issue of him making 
these representations and then doing these loans and then 
having them forgiven.  
And the thing I want to add about her that we've 
learned since we filed this response is that she lives in 
Colorado right now.  And she actually works on these, kind of, 
dredge vessels.  So getting her here is going to be a 
challenge.  We're actually kind of in the process of securing 
flight arrangements and hotel for -- I have got our trial, kind 
of, mapped out for myself because we've got several people that 
we're flying in.  
THE COURT:  Uh-huh. 
MR. KELLER:  Approximately eight, I think probably more 
than a half dozen people that we're flying in, and she's one of 
them.  And so that would -- that just kind of adds to the 
burden here.  Because we really would have to just straight 
call her back from wherever she is, if we were to try this 
twice.  
So those are the two witnesses who have [sic] directly 
overlapping.  But she's kind of a special case in the sense 
that she has these additional issues. 
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THE COURT:  So it's SB.  And then the other person?  
MR. KELLER:  Is -- I refer to him in the motion as JS.  
He is an employee of the marina.  
THE COURT:  How many total witnesses do you have 
planned at this time?  
MR. KELLER:  Judge, at this time -- and I have got, 
kind of, a little -- I have actually got a draft witness 
exhibit list, and I have got a, kind of, little chronology for 
myself.  We have about 30 witnesses.  
THE COURT:  And you're projecting how long?  I think 
you have indicated your estimate before, but remind me, please. 
MR. KELLER:  Now that I have mapped it out, I'm 
thinking that if we begin on the 24th -- and we have one 
particular witness availability issue which I filed a notice 
about -- that my estimate is that we should be able to finish 
by March 5th; although this may be a little ambitious, but I 
think that we should be able to make it last that long.  
THE COURT:  Okay.  Now, you've -- of course, you're 
leaning heavily on the general notion that we keep cases 
together that are indicted together -- counts together, rather, 
and that there is a general presumption against severance.  But 
that rule, essentially, would be that there would be no room 
for severance ever.  
And so I guess your final opportunity to explain why, 
in this particular case, severance wouldn't make sense.  
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MR. KELLER:  Well, Judge, let me just say that -- to 
respond to that about "severance would never be appropriate," I 
think there is a case -- and I cite -- I talk about it in a 
footnote because the defendant references it in his motion.  
And that's Holloway, and that's on page 13 at the footnote 4.  
That there is a great case and example where severance is 
appropriate.  Where what they had was a robbery spree, and then 
afterwards the defendant -- there was an arrest warrant for him 
because he has been charged with this.  He is arrested.  And he 
has a gun and he is a convicted felon.  And they didn't have a 
gun recovered from the scene of these robberies, so they didn't 
have, you know, felon in possession charges there.  
And the Court said these don't have anything to do with 
each other.  This is a case of crime committed, arrest happens, 
and these things are totally separate.  And there is all this 
prejudice from the fact that he is going to have to stipulate 
to being a convicted felon.  And this isn't right.  This isn't 
what should be happening.  
So I just say that to clarify that it's not that 
severance is never appropriate; it's that the Eleventh Circuit 
and the other circuits lean heavily in favor of it.  And, 
really, because of that -- so, you know, our best argument is 
that because they lean heavily in favor of it and because there 
are all these inextricably intertwined aspects of this case, 
going from the witnesses which is, you know, comparatively 
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minor compared to the other considerations, to just the fact 
that -- and this is our big picture position -- is that this is 
all one story.  This is all one scheme.  This is all one set of 
actions that one informs the other in the same way that proving 
the fact that the defendant did not intend to use the vessel 
recreationally, like he claimed at the very beginning, is 
proven false, by not just the Count 1 conduct, the 
manslaughter, but also the fact that he was referring to this 
as a business in his PPP loans.  
And by the same token, each of these counts ends up 
being inextricably intertwined as one story in that way.  So 
that's kind of the core of our argument.  
THE COURT:  Is it your position in general, I mean, to 
simplify, that the manslaughter is relevant to the wire fraud 
because he committed the wire fraud in order to keep the 
business afloat after the negligent killing rendered the 
business nonoperational?  
MR. KELLER:  So I would actually make a slightly 
different argument, which is this:  Let's say that we were 
talking about three wire fraud counts where the defendant had, 
for example, stolen someone's identity, and then had done, 
you know, wires in order to generate money so that he could 
just, like, keep himself afloat, keep his business going.  
There you would have a much stronger case for severance because 
those wires and those stealing the identities don't really have 
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any clear connection to the killing, unless we just wanted to 
argue, and which we do here on one hand, that there was an 
impetus for it; right?  Which is an acceptable form of 
severance.  But that would be a weaker claim than what we have 
here.  
The real key here is the fact that we're talking about 
Paycheck Protection Program loans.  That -- that when you're 
talking about the PPP loans, you're inherently arguing, as the 
defense did when they were speaking to you, that the defendant 
was legitimately engaging in business.  And because -- 
THE COURT:  But what does the manslaughter have to do 
with the PPP loans?  
MR. KELLER:  That the manslaughter is the evidence 
showing that the business was not actually operating in the way 
that he claims they are in the PPP loans.  So the PPP loans, he 
is saying this is a real business that is really operating and 
here is my revenues -- 
THE COURT:  But, in reality, it wasn't operating 
because of the negligent killing, therefore, the business 
stopped and he had to make money in order to keep it running?  
Is it just a motive question?  I'm really just trying to 
distill the connection between Count 1 and 3 and 5.  
MR. KELLER:  Yes, Judge.  And so it's not just a motive 
issue.  
So in the wire fraud for an identity theft, that would 
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be a pure motive issue which is really what I was getting at 
there.  Here it's substantive because part of the defense for a 
PPP loan specifically is that his representations about the 
business operating were true.  And that's different than if he 
were doing some other type of fraud.  So because of that, the 
manslaughter, the resulting order saying he is no longer 
allowed to operate, him texting the Coast Guard saying, "After 
this killing happened, I am shutting the business down," this 
becomes direct evidence of not just motive, but also a fact 
which is that this business was not operating, which is 
something that is essential to our case in proving the PPP 
loans were fraudulent. 
THE COURT:  And it wasn't operating because of the 
negligent killing?  Is that the government's case?  
MR. KELLER:  Yes, Judge. 
THE COURT:  Okay.  All right.  Let me hear any rebuttal 
argument from defense counsel, after which we will turn to the 
motion in limine.  
MR. O'SULLIVAN:  Judge, I just -- I keep coming back to 
whether this was a common plan or scheme.  That language, to 
me, and I think outlined in Davis, is you have to wake up one 
day and say, "These are the criminal acts that I'm going to 
commit and this is what -- the result I want."  For example, if 
Mr. McCabe said, "I'm going to sink my boat today," and then 
start doing insurance fraud or PPP loans, that's a common plan 
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or scheme.  
The negligence -- and the defense is going to be it was 
an accident.  That it was not a scheme or a plan, that it was 
an accident.  I think one has nothing to do with the other.  
And as far as these text messages go, where we're 
talking about his need for money, there is other reasons why.  
And that was actually in these text messages; that he is going 
through a divorce.  So there is other reasons why, you know, 
money became an issue.  
But, again, I think that the standard that the Court 
has to look at and the case law cites in our motion is:  Was 
this a common plan or scheme?  And I just don't see how you can 
tie an accident, which is the negligence, to then say that 
somehow he knew in the future he was going to commit wire fraud 
because of an accident -- 
THE COURT:  Well, I don't know if the law requires that 
intent to have been formed at the very beginning, to then 
commit, you know, numerous crimes over the course of two years.  
There can still be a common plan that builds off of itself 
based on whatever facts materialize.  And I think that's the 
government's representation, is that after the negligent 
killing, the business was in such dire straits, it clearly 
wasn't operating, and yet he represented to the federal 
government that it was.  And so that that's that factual 
substantive connection that disfavors severance.  
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What do you say about that?  
MR. O'SULLIVAN:  I think that's a fair statement, but I 
still think that the Court has, you know, wide latitude to 
determine, you know, A, is there prejudice to the jury?  But, 
again, you know, certainly one built off the other.  And as the 
government said, I would agree with it, it is all part of a 
story.  But this story needs to be told in two different places 
because he did not wake up in March of 2020 saying, "I'm going 
to commit these five -- these five crimes that are alleged in 
the indictment."  
The manslaughter was an accident.  I think that's no 
surprise that's going to be a big chunk of our defense.  And 
even though the fraud may have been built on that -- and I use 
the word "may" -- there is other reasons such as, as shown on 
page 3 of the government's response, the divorce and, you know, 
the financial cost to him.  So it wasn't just the business 
shutting down.  
THE COURT:  Okay.  
MR. O'SULLIVAN:  And also, just to clarify -- I'm not 
sure how important this is -- but he never sold the boat.  It 
was repossessed.  I'm not sure if that would sway the Court in 
any way or how much weight the Court would give it, but I just 
wanted to clarify that fact. 
THE COURT:  Okay.  Thank you.  
All right.  I will take the motion under advisement.  
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It would help, nevertheless, factually to entertain the motion 
in limine so I can delve deeper into the various facts.  
So, with that, let me hear from the government on its 
motion in limine, starting with Item Number 1, which, as 
described in the motion at docket entry 28, concerns evidence 
about three events occurring on March 28th of 2020, which was 
the day before the instant offense that's charged in Count 1, 
that gave the defendant notice of the propeller issue that 
proximately caused MCGF's death.  
MR. KELLER:  Yes, Judge.  
And as I begin, I just want to note -- and just to 
clarify something from the very beginning of this hearing.  I 
think you had mentioned that these were 404(b).  I just want to 
clarify that 1 through 5 are not 404(b); that our argument is 
that they're inextricably intertwined. 
THE COURT:  Okay.  
MR. KELLER:  And then six -- the sixth one is the one 
that we do call 404(b) evidence.  
THE COURT:  Okay.  Thank you for the clarification.  
And that is correct.  
MR. KELLER:  And I know that this charge -- you're 
probably the only judge in this circuit who has briefed this 
issue because you were one of the attorneys on Alvarez.  So -- 
I don't know if you remember that, but -- so I would think that 
you remember some of the stuff about seaman's manslaughter.  
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That what we're here for and what this case kind of comes down 
to, as far as the seaman's manslaughter is considered -- or is 
concerned, is the question of negligence.  The question of the 
things that put the defendant on notice, that there was a 
problem with this boat, that it presented a danger to the 
people that got on it on March 29th, and that the defendant 
didn't take the steps necessary to make it safe.  And that's 
really what this case, as far as the manslaughter, is about.
And what these first four things -- 
THE COURT:  In Alvarez was there ever a 404(b) 
challenge or an inextricably intertwined challenge?  Or was it 
just a threshold claim concerning the statute itself and its 
mens rea component?  
MR. KELLER:  There was nothing on appeal about whether 
the evidence, such as the defendant's prior cocaine use, his 
operating it without a license should come in.  That was not 
part of the appeal.  
The appeal was really about -- 
THE COURT:  But in the district court, do you know 
whether that issue was challenged?  It does seem like the 
evidence was admitted and then used to support the sentence.  
And so my question is, was there ever an actual dispute in the 
district court, though, as to whether that evidence should have 
come in in the first place?  
MR. KELLER:  I do not know the answer to that 
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question --
THE COURT:  Okay.  
MR. KELLER:  -- right now, Judge.  I can get that 
answer for you and file something, if you would like.  
THE COURT:  We will see if that's necessary.
Please continue. 
MR. KELLER:  Sure.  
So speaking to the first of these -- and this is really 
some of the most critical evidence in this case as to the 
manslaughter -- really, the most critical evidence -- which is 
showing that the defendant was on notice about the back of this 
vessel, the propeller specifically, having mechanical issues 
the day before that presented a danger to his passengers.  
And, Judge, one thing about this case that's really a 
key framing fact, a thing to understand about scuba as opposed 
to other types of ventures is that scuba inherently involves 
going near the propeller; that you have to get on and off the 
boat from the back because of the fact that you have all of 
this heavy equipment.  
And the reason that's important is because when you're 
a captain of a vessel that's doing scuba, you know that the 
passengers are going to be going near that propeller.  
So this is different than something like a fishing 
expedition.  Let's say someone had fallen off a fishing boat 
and the propeller malfunctions.  That would be a very different 
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type of case than this one because what the defendant and what 
the person who is the captain should be aware of is different.  
And that fact, that framework, is really what informs why this 
Court should be permitting us to present evidence from the day 
before of what happened that day that showed him that there was 
a danger on the back of this boat, and, namely, the propeller.  
Number 1, that Jennifer Hester, who is one of the 
passengers that day, was getting back on the boat as 
instructed.  She suddenly felt herself being sucked under the 
boat.  Her -- she had a spear gun with her.  The spear gun gets 
sucked into the propeller, shot back at her, strikes her in the 
leg.  And there is photographic evidence of the injury that 
resulted; that she has a large bruise on the inside part of her 
thigh.  
Then later in the day, she sees the propeller again 
engaging, and she sends the defendant a message -- or a 
Facebook Messenger that same day, saying, "Hey, your propeller 
is engaging when it's not supposed to, when it's supposed to be 
in neutral."  And this should be -- for any reasonable captain 
exercising reasonable diligence, it would send out high alerts.  
This is an extremely dangerous condition, but not for this 
defendant.  
Instead, he kept operating the vessel, and he drove it 
or steered it toward the marina.  And this is the third event 
that's described in the first -- for the first March 28th 
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event -- to put it to dock at the end of a day of scubaing.  
When he did so, he was unable to park at the very end of the 
pier.  And that was a problem for him because he couldn't 
really steer this vessel because it was broken, because it was 
malfunctioning.  
So what he did was, he ended up having to steer away 
from the dock, so as not to collide with it.  He kept going 
down the Palm Beach waterway.  He is heading towards the bridge 
which he almost collided with, but, instead, he ran his vessel 
aground to avoid it.  These are all things that are putting him 
on notice that day that he has a problem, that this vessel is 
not working properly, that his propeller is malfunctioning.  
But unlike any other reasonable person who would 
actually report it like he was supposed to, who would do 
something about it, instead, this defendant brought out another 
separate group of passengers the next day, 9:00 in the morning.  
And this is when the killing happens.  This is when MCGF is 
killed by being sucked under the boat, just like had happened 
to Jennifer Hester the day before, but Ms. -- but the victim 
did not have the benefit of a spear gun to protect -- to shield 
her by, you know, essentially getting sucked into the 
propeller; instead, she got sucked down.  And her wetsuit got 
entangled into it.  Her legs got essentially chopped off right 
in front of her husband, and she was held down until she 
drowned.  That's really what the heart of this case is about.  
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And those sets of facts from those -- in that two-day span is, 
really, about -- is really about 24 hours from the morning of 
March 28th until about 10:00 on March 29th, why -- at the heart 
of why this defendant should have known there was a problem.  
So our position is that those March 28th events are 
inextricably intertwined here.  They're a part of the story 
that's necessary for the jury to understand why the defendant 
was negligent that day when he did what he did; when he kept 
having that boat out and he had these passengers go near this 
propeller that he knew full well was dangerous.  
THE COURT:  How do you intend, if permitted, to 
introduce these three events?  If you could just clarify the 
evidentiary path.  
MR. KELLER:  Sure.  
Our very first witness we're going to call -- and this 
speaks to the notice that we filed about witness 
availability -- is going to be Ms. Hester who is going to 
testify about both the initial spear gun incident, as well 
as -- we have the text message or the Facebook Messenger 
message that we sent -- that she sent him.  She's going to 
testify about that as well.  
And then we have another witness from the harbor.  So 
he works there.  He was, I believe, in charge of the harbor.  
And he saw the defendant attempting to tie up to the pier -- 
I'm not conversant in the jargon yet; I will be by next 
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month -- and then have to keep going and ultimately run his 
vessel aground.  
So we're basically going to be getting this in through 
those two witnesses, along with a third witness who will 
testify in between them, who will testify about Ms. Hester's 
incidents; that he was there when she had this shot back at 
her; that Mr. McCabe, who had just got this vessel, did not 
appear to know exactly how to manage it, and the like.  
So it's not going to be, you know, ten witnesses for 
this.  It's going to be two to three.  
THE COURT:  Okay.  So the date of the alleged killing 
is March 29, and these three events took place on March 28; is 
that correct?  
MR. KELLER:  Yes, Judge.  And, again, it was really 
within a 24-hour period.  
THE COURT:  Are you making an alternative 404(b) 
argument for these, or are you proceeding solely on the 
inextricably intertwined path?  
MR. KELLER:  So we would argue that these are 
permissible 404(b) because they're showing knowledge of the 
fact that there is this danger, that there is no mistake here, 
et cetera.  But, really, our argument is that this is -- the 
core argument and the correct argument is that this is all part 
of the story that, to prove negligence, you have to show that 
there was some type of breach of duty.  To do that, you have to 
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be able to go back to what would be the triggering event.  And, 
really, here, for the purposes of that notice of him being -- 
knowing that there was a problem, those triggering events were, 
again, the day before.  
THE COURT:  Okay.  We're going to stay organized here.  
So we're going to hear now opposition argument on this one 
topic.  
Counsel.  
MS. FRANCIS:  Yes.  Thank you, Your Honor.  
Your Honor, if I may ask, is it possible that I may sit 
for my argument?  The heel of my shoe has broken and I am 
wobbly. 
THE COURT:  That's fine, yes. 
MS. FRANCIS:  Thank you, Judge.  
And this morning, Judge, we are arguing that the 
evidence should be excluded as irrelevant under Rule 401.  We 
believe that this is being offered to show the defendant's 
prior bad acts or his propensity to commit crime.  The evidence 
that the government is seeking to admit is not probative of any 
issue.  It is truly just being used for the sole purpose of 
demonstrating the defendant's poor character, and, therefore, 
it should be excluded.  
So, Judge, going back to the request, number 1.  The 
government is alleging here that the defendant was alerted to 
significant mechanical issues with this vessel.  Particularly, 
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Your Honor, they are harping on the propulsion system through 
three incidents.  Throughout their motion, Judge, they are 
asserting that these incidents happened because of the 
propulsion system.  And I would like to make sure that that's 
on the record.  
Judge, the first incident was where JH reported that 
she was feeling pulled towards the port side of the propeller.  
THE COURT:  You mean -- do you mean Ms. Hester?  
MS. FRANCIS:  Yes.  JH would be referring to 
Ms. Jennifer Hester, Judge. 
THE COURT:  Okay.  
MS. FRANCIS:  And this is despite the defendant 
claiming that the engine was in neutral.  I believe that JH, 
Jennifer Hester, did insist that the propeller was engaged, 
just her testimony, Judge.  The second incident is where the 
government is claiming that the vessel reportedly lost ability 
to reverse.  Again, Ms. Hester in that report observed that the 
port propeller was engaging.  She notified the defendant via 
Facebook.  They have that message, and that's what they're 
seeking to admit.  
The final instant, Your Honor, the defendant allegedly 
encountered restricted mobility.  Again, the government is 
alleging that this is because of a propulsion issue.  Although 
the defendant did manage to successfully avoid a bridge, the 
vessel did end up being grounded in the channel.  After making 
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mechanical adjustments, however, the defendant was able to 
navigate back to the dock.  
So, Judge, it would be an error to allow the government 
to admit this evidence, referring to the propulsion system 
being the causation.  And that is what they state emphatically 
on March 28th.  They will be unable to prove proximate 
causation.  
Judge, the government's theory that the jury will be 
able to easily find proximate causation based on defendant's 
negligent acts, referring to him still taking the paying 
passengers out on the 28th, although he experienced propulsion 
issues on the 28th.  
Judge, there is no evidence -- they are not seeking to 
admit anything, no mechanical report, no investigation, no 
review regarding the boat's engine or the boat's propulsion 
system.  There is nothing that conclusively identifies this 
being the cause of the vessel's mechanical failures following 
the incident on March 28th.  
THE COURT:  Counsel, a lot of what you're saying sounds 
like proper argument for cross-examination, or questioning and 
then closing.  But you would agree the government has to 
establish negligence.  They have to show that, by his 
misconduct, negligence, and inattention to his duties, this 
woman, MCGF, lost her life.  And so wouldn't it be directly 
relevant to establishing such negligence that this defendant, 
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one day before, was put on notice that his propeller had caused 
another passenger to get sucked through temporarily, and that 
the boat was unable to dock properly and then ultimately ran 
aground?  
It's just hard to see how that evidence isn't directly 
relevant to the essential elements of Count 1.  
MS. FRANCIS:  Yes, Your Honor, that is a key issue 
here.  The government failed to adequately inspect the boat, 
test the engine, or evaluate the propulsion system.  That has 
led to the conclusion that links that March 28th incident to it 
being a propulsion issue, and that is what we essentially have 
to defend against.  
The government is relying exclusively on testimony from 
Jen Hester.  Jen Hester did not inspect the boat.  Jen Hester 
did not prepare a report.  There is nothing that states that it 
was a propulsion system issue.  
And so, Judge, that is the issue here.  We would have 
to defend against a propulsion issue when we know for a fact 
that it was a battery issue.  
As well, Your Honor, the boat is no longer here.  We 
are not able to inspect it now.  So it's almost impossible for 
us to fight this charge that it's a propulsion issue.  And that 
is what the government is advancing.  
So, Your Honor, we would -- we would have to say that 
there would have to be other evidence that the government would 
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be willing to offer, not just these three incidents that 
they're claiming created a propulsion issue.  There is nothing, 
no report, nothing emphatically that states that this issue was 
a propulsion issue.  
If they do have evidence that states that it was a 
propulsion issue, we would have no objection to it being 
offered into evidence.  But the government offering into 
evidence these three incidents that happened on the 28th -- and 
it is based solely on testimony.  The government did not 
inspect the boat, did not start the boat.  And they have no 
record or no report saying that it was a propulsion issue, but 
yet, Judge, we would have to defend against that --
THE COURT:  Okay.  
MS. FRANCIS:  -- without having the boat here and able 
to be inspected. 
THE COURT:  All right.  It seems to me that these three 
events are part and parcel of Count 1 and that all of your 
arguments go to the weight to be given to the evidence.  So 
you, of course, will be permitted to challenge that evidence 
through questioning and argument and any evidence, perhaps, you 
wish to present.  But, at the end of the day, the government is 
required to prove negligence on Count 1.  And these events that 
took place within a day of the alleged manslaughter go to the 
heart of the negligence element.  And so for those reasons, I'm 
going to grant the government's motion in limine as to topic 
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number 1, although the defense certainly is entitled to object 
contemporaneously at trial.  And I can deal with any 
on-the-spot objections in the normal course.  
Any questions before we move on to topic number 2?  
MR. KELLER:  No, Your Honor.  
MS. FRANCIS:  No, Judge.  Thank you.  
THE COURT:  Okay.  Then let's hear argument from the 
government on whether to present evidence about the defendant 
violating a local ordinance preventing vessels like his from 
taking out paying passengers the day of MCGF's death.  
And, Counsel for the government, please identify 
exactly which local ordinance you're referring to.  
MR. KELLER:  So, Judge, the local ordinance, which is 
attached as Attachment A to the motion in limine, is referred 
to as -- or defined as "Palm Beach County COVID-19 Public 
Safety Order Number 1."  
THE COURT:  Okay.  I'm aware of that.  Doesn't that 
seem a little bit far afield?  I mean, we're talking here about 
negligence in the operation of this vessel.  Whether there was 
a COVID-19 ban on scuba excursions, why is that directly 
relevant to the negligence question here?  
MR. KELLER:  So, Judge, one of the things -- and we 
outlined this, I think, in the motion -- that courts look to 
when they're talking about "has someone been negligent or not" 
is the rules that govern whether they can be operating where 
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they are and what they should be doing while they are.  And 
this is something that affects a lot of the subsequent things 
we're going to be talking about.  
And the analogy I would draw would be to -- in O'Keefe, 
which is the Fifth Circuit case, there is a discussion of the 
fact that the victim in that case was not allowed to be on the 
boat.  So, like, there was a tugboat that the defendant was 
driving, and the woman who was on it was not allowed to be on 
there.  
Now, is that something that directly caused?  Perhaps, 
not.  But what it is, is it's evidence of a disregard of the 
rules on the day and as the incident was unfolding.  
So our position is that because what we're proving here 
and what the defense is contesting is whether the defendant was 
negligent that day, whether he breached a duty, whether he -- 
THE COURT:  But the duty here is a duty to operate a 
safe vessel.  What exactly -- how would you articulate it?  
MR. KELLER:  Well, I think that -- if I can take a look 
at the cases we cited, I believe that there is case law that 
says that part of the duty is also to abide by the rules, abide 
by the law when you're operating something like a vessel.  
If you would bear with me for -- 
THE COURT:  It just seems to me that trying to pull in 
a COVID-19 government order is, you know, factually somewhat of 
a stretch.  I mean, other than obviously he wouldn't have been 
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on the water had he complied with the directive -- but beyond 
that, how does it factually connect to the alleged negligence 
here?  
MR. KELLER:  We would argue that the fact that he 
wouldn't have been out there, that she never would have been 
killed had he abided by the order is, itself, pretty powerful 
evidence that shows that he is not abiding by the regulations; 
he is not someone who was doing the right thing that day.  
THE COURT:  But the regulation that is underpinning the 
COVID-19 has nothing to do with safe operation of vessels, you 
would agree?  
MR. KELLER:  Yes, Judge.  And that's why we're not 
arguing the violation.  So let's say it did.  Then we would be 
making a slightly different argument, which is that it would be 
negligence per se, which is basically to say that -- and this 
is more in the civil context -- but in negligence law, when 
someone does something that is a violation of a rule that 
proximately causes something to happen, then it's what's 
referred to as negligence per se, which basically means that's 
the end of the discussion.  
Here, the defense is free to argue that -- exactly as 
you're doing here:  Who cares about this order?  Who cares 
about this violation?  But our argument would be that -- or our 
position is that that just speaks to the weight that should be 
assigned it, not to whether it's admissible to show that the 
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defendant was disregarding rules on the day that this killing 
happened.  
THE COURT:  All right.  Defense argument.  
MS. FRANCIS:  Judge, we would have to argue again that 
it is completely irrelevant.  Again, Your Honor, the duty to 
operate a safe vessel has nothing to do with his duty to abide 
by that COVID-19 ordinance.  Judge, that evidence is not 
probative of any issue.  
THE COURT:  Well, is it probative of just, sort of, his 
general disregard for rules and regulations, kind of more 
broadly speaking?  
MS. FRANCIS:  Judge, I would have to argue that it's 
not probative of his actions towards the negligence charge, 
Judge.  So we would object to request number 2 as well.  We 
really believe that it's just being offered for the sole 
purpose of demonstrating, again, the defendant's poor 
character.  And, Judge, we would argue that it is irrelevant 
under Rule 401(b)(1). 
THE COURT:  What do you say that he wouldn't have been 
on the water had he complied with the COVID ban?  
MS. FRANCIS:  What we're arguing, Judge, is that it's 
just offered to show a bad act that has nothing to do with the 
negligence -- 
THE COURT:  But how do you say it doesn't have anything 
to do -- I mean, if he wasn't on the water, then this person 
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would still be alive, presumably. 
MS. FRANCIS:  Even though that may be correct, 
Your Honor, we would believe that that evidence being offered 
would seek to prejudice the defendant and be offered just to 
show his bad acts that has, unfortunately, nothing to do with 
what happened on that unfortunate date of March 29th.  
THE COURT:  All right.  Let's see.  Mr. Keller, what's 
your best relevance connection for this COVID-19 order?  
MR. KELLER:  It's exactly what we've talked about 
before.  That if she would not have been on the boat, this 
never would have happened, if he had abided by it.  And that 
any argument that it doesn't proximately cause the death, 
that's not what's required; to have a piece of negligence, to 
have evidence of negligence for a given day.  That, instead, 
that is a question purely about weight, just like it was in 
Alvarez with respect to his having a license that day to be 
operating the boat; and just like in O'Keefe where there was 
also evidence about the fact that the woman was not allowed to 
be on the boat.  
Neither of those had anything to do with the fact that 
in O'Keefe, for example, the defendant had been using cocaine 
and capsized his vessel.  But what it is, is it's showing 
negligence and it's showing something that, had it not 
happened, had she never been on that boat, then the whole thing 
would have never happened.  The charge wouldn't have existed.  
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And the same is true here.  So our position is that it should 
be admitted in the same way. 
THE COURT:  Okay.  On this point I agree with the 
defense.  The charge here really concerns misconduct, 
negligence, and inattention to duties on the vessel.  And a 
COVID-19 ban, although in some senses -- you know, in a pure 
sense would have meant he wouldn't have been operating at all.  
I think that that's not sufficiently relevant to the charges 
here which require the government to prove negligence related 
to his duties on the vessel.  
And so, given that dissimilarity, I'm going to deny the 
government's motion on prong 2, and turn to Item Number 3.  
Mr. Keller. 
MR. KELLER:  Yes, Judge.  
So Item Number 3 is evidence about the fact that when 
this happened, when the casualty occurred, when the vessel goes 
into port, the Coast Guard, of course, responded, and they 
wanted to conduct drug testing.  But it turned out that the 
defendant was not registered for a drug testing program, as 
required by regulation, and that, as a result, no one was 
tested at the scene.  In fact, the crew members who were on the 
boat never got tested because of the fact that they were not 
part of this regimen, they were not required to be.  And the 
defendant only tested later.  
So our position is that, as it, again, comes to proving 
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negligence in this case, showing that the defendant operated 
the vessel with total disregard to the rules, that he -- that 
we should also be able to show that we will never know for sure 
about who was using drugs or drinking alcohol on that vessel 
that was part of the crew because of the fact that the 
defendant negligently did not enroll in a program to protect 
his passengers like he was required to do.  
THE COURT:  Okay.  Walk me through just the basic 
requirements and how you would -- how you would establish this, 
if allowed.  
MR. KELLER:  Yes, Judge.  And if I -- and I have it 
here, the trial brief.  If I could make reference to it. 
THE COURT:  Sure. 
MR. KELLER:  And this is docket entry 29.  And this is 
actually on the third -- the 13th page.  And this is subpart B.  
THE COURT:  Okay.  
MR. KELLER:  And it's that marine employers shall 
establish programs for the chemical testing for dangerous drugs 
on a random basis of crew members on uninspected vessels.  
And the evidence that we will have about that is that 
Heather Spurlock, who was an employee of a company called The 
Maritime Consortium -- what they do, what that business does is 
offer services for drug testing.  
So when you're operating a vessel, you enroll in that 
program and then you're subject to the testing, you get a 
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compliance certificate.  This is something that anyone who is 
operating one of these vessels needs to do.  What happened here 
is that the defendant was not enrolled in one of those programs 
until two days after the killing.  After he had been spoken to 
about [sic] the Coast Guard about the testing, he acknowledges 
that he was not enrolled, and then he got enrolled days later, 
like he should have been, on the day that this happened.  
So it's going to be one witness along with a few 
records from the consortium.  And our position is that that is 
relevant because it's, number 1, showing that the defendant 
breached his duty to be enrolled like he was supposed to, which 
the rules and regulations -- the CFR say he needed to be.  
And then, number 2, that when it comes to what exactly 
happened here, that there're going to be gaps in our 
information because we will never be able to know whether there 
were crew members who were under the influence or anything like 
that, as this killing happened, because of the fact that the 
defendant was not enrolled in a program.  
THE COURT:  How does this program work?  You -- before 
you -- you open a scuba business, you then personally get drug 
tested or each time you take out a crew of -- of customers, 
they each have to be drug tested?  
MR. STIEHL:  Your Honor, so the way it typically works 
is, when you start a business, a maritime business, you enroll 
in this drug testing program, and you enroll whoever is on your 
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staff to be enrolled in this random drug testing program.  And 
they would then offer services that, after the marine casualty, 
they would also come and test your employees.  Because the 
requirement is on the marine employer, which in this case was 
Mr. McCabe -- is to ensure the drug testing of everyone that is 
determined to be directly involved.  So -- 
THE COURT:  But this is a drug testing requirement on 
the captain and any staff members operating or working on the 
vessel?  
MR. STIEHL:  Yes, Your Honor. 
THE COURT:  Okay.  Is there any suggestion by the 
government that Mr. McCabe was under the influence during the 
date in question?  
MR. KELLER:  So, our position is that we won't ever 
know for sure because of the fact that we don't have that 
evidence.  Mr. McCabe did testing afterwards, but -- 
THE COURT:  Do you know what the results of those tests 
were after?  
MR. KELLER:  That he did not test positive for anything 
afterwards.  But that -- and then I should say that his crew 
members were never tested because their attorneys -- according 
to Mr. McCabe's text messages with the Coast Guard, their 
attorneys instructed them not to.  
THE COURT:  And so -- and then just backtracking on the 
actual date of the incident, when the Coast Guard questioned 
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Mr. McCabe about his enrollment in this program, can you walk 
me through factually what your evidence indicates. 
MR. KELLER:  We have text messages between a 
Coast Guard officer and Mr. McCabe in which the Coast Guard 
officer asks him about the drug testing:  You know, is testing 
being done?  Mr. McCabe tells him that he conferred with his 
crew members, that his crew members were told -- well, first 
off, his crew members were back at what he refers to as "the 
bar," by which maybe he just means, you know, the marina, but 
that could be drinking alcohol already; I'm not sure.  I'm not 
sure what that means.  But he says that they -- he has 
conferred with them and that they are not going to comply with 
any testing, but that he himself will go get testing done.  And 
then he basically sends the Coast Guard documentation for a 
test that was done, I believe for alcohol.  
THE COURT:  Okay.  All right.  Let me hear from the 
defense on this issue.  
MS. FRANCIS:  Thank you, Your Honor.  
And we would like to point out, first of all, that the 
crew members that were on the vessel that night -- one was an 
EMT, one was a firefighter.  They're already enrolled, in their 
own programs through their employers, to be tested.  And, 
again, they are not on trial here; Mr. McCabe is.  The crew 
being tested, we believe, is irrelevant to whether or not he 
was negligent that day.  They are not -- he is not charged with 
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a crime or any type of failure to comply with the code of 
regulations 406-5, which does outline the drug testing 
requirements.  
Judge, any individual engaged or employed on that 
vessel who was determined to be directly involved in a serious 
marine incident has to provide blood, breath, saliva or urine 
"when directed to do so" is the keyword here, Your Honor.  
Mr. McCabe was not directed to do so.  He did not refuse a drug 
test.  In this instance, Judge, he was not detained.  He was 
instructed to return his vessel to his original slip.  He was 
able to drive the boat back to where it belonged.  At no point 
was he found to be directly involved in a significant marine 
incident or was he required nor refused to provide that.  
However, what he did do, Judge, is he did engage his 
own drug testing, a mobile drug testing company, that same day, 
Your Honor, of the incident.  And that drug test was, of 
course, submitted to the USCG and, of course, it came back 
negative.  So we do believe that it is irrelevant here.  
Although he did not comply specifically, he did substantially 
comply by providing his drug samples.  
Again, the crew -- we believe that is irrelevant here; 
they are not on trial, but he is.  And we do feel that entering 
this type of evidence that he failed to comply is irrelevant 
because essentially he did, Your Honor, as the government just 
stated, and the tests came back negative.  
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THE COURT:  So you agree he failed to enroll in this 
program prior to the date in question?  Prior to March 29th?  
MS. FRANCIS:  Yes, Judge, we do agree that he failed to 
enroll.  
THE COURT:  Okay.  Because you are making these 
relevance arguments and you're saying it's not relevant because 
we can disprove it.  And I'm not quite sure that that actually 
makes it irrelevant.  Whether you can counteract the evidence 
in some fashion doesn't negate its threshold relevance under 
401.  And so -- 
MS. FRANCIS:  Your Honor, we believe it's irrelevant in 
the fact that it's not really probative of any issue of whether 
or not he was negligent on March 29th.  That he failed to 
enroll in a drug testing program, we don't feel that that's 
probative of the negligence issue or any issue that took place 
on that day, especially when he actually did comply, 
Your Honor, which the government has admitted that he did 
submit his drug test.  
MR. O'SULLIVAN:  Your Honor, may I just add to that?  
THE COURT:  Yes. 
MR. O'SULLIVAN:  I don't mean to interrupt.  I 
understand that -- the Court's concerns about whether or not 
it's relevant.  The concern that we have is that it's unduly 
prejudicial because the government's going to say and kind of 
make the inference that Mr. McCabe was supposed to, by these 
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rules, enter the drug consortium and he didn't.  And that's 
going to infer to the jury that somehow he failed a drug test 
or something like that.  
Now, of course, we can disprove that, but what's the 
point of telling a jury, from the government's side, he never 
had the proper drug test, and then us getting up there and 
saying, well, he got his own drug test that day, and he -- and 
he passed?  
THE COURT:  Okay.  
MR. O'SULLIVAN:  And that we can -- 
THE COURT:  All right.  Final argument.  Are you -- 
from the government.  This is my question:  Are you at all 
concerned that we are going to turn this trial into a civil 
regulatory compliance rather than a criminal case about whether 
he had the intent to commit manslaughter and wire fraud?  
MR. KELLER:  No, Judge.  Because for each of these 
we're doing it in a very limited fashion.  So I mentioned, with 
respect to this issue, that we're doing one witness, who is 
going to be brief, and who will be introducing one document, 
maybe two.  
And as far as the issue of whether it's turning into a 
civil regulatory -- 
THE COURT:  Uh-huh.  
MR. KELLER:  The thing is that this case is, in some 
ways, about some civil issues in the sense that it's a 
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negligence trial.  It's different than a lot of other criminal 
trials because the rules of operating a vessel matter.  Because 
what we're doing here is showing that he breached his 
obligations to his passengers, which we prove in part by the 
fact that he was violating these regulations that he should 
have been abiding.  And those regulations have reasons for 
them.  And this is reflected in the case law that I believe I 
cited in the motion in limine as to -- and that's why they're 
also admitted in these other trials for seaman's manslaughter 
because it is about that.  
THE COURT:  Have you considered a limiting instruction 
directing the jury that violations of municipal ordinances 
alone perhaps wouldn't amount -- or wouldn't establish criminal 
liability in a criminal case?  
MR. KELLER:  So my answer to that is that in this 
specific instance, I actually think that -- if we were talking 
about it -- and not to go back to number 2, but here we have 
the same thing where I'm not arguing proximate causation for 
this specific negligent act, like, that this negligent act 
caused the death.  But we are still talking about simple 
negligence for this particular crime, which is a little unusual 
in the criminal context.  But what it does is it informs how 
probative something like this is in this type of case versus a 
case where there was some type of other mens rea element or 
mens rea standard. 
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THE COURT:  Do you have any evidence to indicate that 
the crew members were under the influence?  
MR. KELLER:  We will never have any evidence --
THE COURT:  Okay.  
MR. KELLER:  -- because of the fact -- 
THE COURT:  All right.  I will take this issue under 
advisement.
Ms. Cassisi, can you advise me what time the next 
hearing is.  
COURTROOM DEPUTY:  1:00, Your Honor. 
THE COURT:  Okay.  Thank you.
All right.  Let's turn to Item 4. 
MR. KELLER:  Yes, Judge.  
So Item 4 kind of relates back to Item 1 in the sense 
that when these things happened the first -- on March 28th -- 
and by "these things," I mean the mechanical issues that led to 
Ms. Hester being injured by a propulsion issue, and then 
ultimately Mr. McCabe running the vessel aground in order to 
avoid a bridge -- that those issues were reportable to the 
Coast Guard under their regulations, and that he did not report 
them.  
And our position is that that is further evidence of 
his negligent conduct.  And again, here, as far as the direct 
proximate causation, that had he reported them, like he was 
supposed to -- we will have testimony -- that the Coast Guard 
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would do something about it; that they would require some type 
of remedial action; and that as -- or they at least very likely 
would -- that they would do some type of an intervention.  And 
then, as a result, Mr. McCabe would likely have not been going 
out the next day to bring the victim out on this boat, this 
dangerous boat, and have her near this propeller that had not 
been remediated under supervision.  
So our position is that those violations of those 
regulations are direct proof, direct evidence of negligent 
conduct that the defendant engaged in that led to the -- 
THE COURT:  Okay.  This reporting requirement, where is 
it coming from?  Is it Title 46, Section 4.06, as listed in 
your trial brief?  
MR. KELLER:  Yes, Judge, it's on page 11.  And it's 
actually 4.05, "Notice of Marine Casualty."  And the two that 
we're really highlighting here are the unintended grounding --
THE COURT:  Uh-huh. 
MR. KELLER: --  or intended grounding.  And then also 
the, number 3, loss of main propulsion, primary steering, or 
any associated component or control system.  
THE COURT:  Okay.  All right.  Brief argument on this, 
please.  
MS. FRANCIS:  Judge, we would argue that the 
occurrence -- an occurrence involving significant harm or 
something to trigger the reporting requirement as defined by 
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that statute did not exist.  None of these issues were present 
on March 28th.  And the defendant's vessel was not involved in 
any kind of marine casualty that would trigger that reporting 
to the U.S. Coast Guard. 
THE COURT:  But there was an unintended grounding; 
correct?  
MS. FRANCIS:  It was a directed grounding, Your Honor.  
THE COURT:  Okay.  Well, then there was an intended 
grounding, potentially.  
MS. FRANCIS:  Well, it -- that would be -- Judge, it 
wasn't an accidental grounding, it was not a deliberate 
grounding that posed a risk, as per the statute says.  The 
statute says that it has to pose a risk.  He was entirely out 
of the channel.  He did not obstruct any marine traffic.  He 
was directed to this certain slip because the floating dock 
wasn't available. 
THE COURT:  Okay.  All right.  Thank you.  
I think, on this issue there is a clear, probative 
component here that ties closely to topic number 1 in the 
government's motion.  Because the grounding took place the day 
before the manslaughter, there was a reporting requirement that 
wasn't complied with.  Certainly you can dispute that at trial, 
Counsel, but at the end of the day, on a relevance challenge I 
disagree and I do agree with the government on this one that it 
is inextricably intertwined with the alleged conduct in 
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Count 1.  
So the motion as to topic 4 will be granted in favor of 
the government.  
Let's discuss Item 5, please.  
MR. KELLER:  Yes, Your Honor.  
So Item Number 5 concerns the April 9th Captain of the 
Port order.  In my -- and by the Captain of the Port of Miami.  
And what that basically is, is the person who is in charge of 
maintaining the safety of the marinas and the waterways in this 
district.  And what he did on April 9th is that he issued an 
order saying that the defendant, in operating his vessel, had 
been found to be a danger, that he was no longer allowed to 
operate the vessel with any paying passengers.  And our 
position is that this evidence is relevant in two ways as 
direct evidence.  
Number 1, it's evidence of remediation that happened -- 
or action that was taken as a response to the defendant's 
negligent conduct on March 29th.  And then, more importantly, 
or at least as importantly, it's evidence to the PPP fraud that 
I spoke to during the motion to sever.  That this is showing 
that the defendant had been ordered not to operate that vessel 
for the purposes of using it for scuba or any other paid 
passenger services, so that he wasn't allowed to operate this 
business that he then later claimed that he was, in fact, 
operating.  
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So our position is that it's relevant in those two 
ways.  Just to get into the how we would be proving this, we 
have one witness who is already going to be testifying about 
other things in this case who will also testify about the 
process for these orders being issued.  Because in this case he 
was someone who reports to the Captain of the Port.  And then 
we're going to have the captain -- the current Captain of the 
Port testify in a not-long presentation, just about what these 
orders are.  
He is going to explain the Captain of the Port order, 
just because the Captain of the Port order is a one-and-a-half 
page document in Coast Guard jargon that no jury -- that most 
lawyers would not be able to understand.  So that's going to 
be, kind of, brief testimony about what it is.  So that's the 
evidence and that's its purpose.  
THE COURT:  Okay.  All right.  Let me hear from the 
defense counsel.  
MS. FRANCIS:  Yes, Judge.  
We feel that there is other evidence -- other evidence 
does exist that would go to show whether or not the defendant's 
boat or vessel was shut down.  Showing the jury evidence that 
he, again, failed to comply with another order, we feel, would 
be prejudicial.  
Judge, the defendant did continue to work as a dive 
instructor.  He had -- and was offering other services to 
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individuals that hired him for guidance and instruction.  So 
that port order did not effectively shut down the defendant's 
business; it shut down his operation of the vessel.  So while 
that port order did shut down the operation of the boat, it 
didn't terminate the business itself.  He still continued to 
work, albeit in a modified way.  
So we do believe presenting evidence that he failed to 
comply with the court order -- a court order which he has not 
been charged with any crime for failing to abide by, would be 
prejudicial to the jury.  There is other evidence that does 
exist that can show that he was no longer supposed to be 
operating the boat.  
THE COURT:  Okay.  Just to be clear, you don't dispute 
that there is an order that barred him from operating the 
vessel on April -- and it was issued on April 9th of 2020?  
MS. FRANCIS:  That's correct, Judge. 
THE COURT:  So what is so highly prejudicial about that 
fact?  
MS. FRANCIS:  Just the fact that it is showing again a 
propensity for the defendant to commit another crime, another 
bad act, although he wasn't charged with any crime or failure 
to abide by this ordinance.  What we're saying is that the 
government is offering this to show that he lied on his PPP 
applications because his boat was no longer supposed to be 
operating. 
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THE COURT:  Okay.  
MS. FRANCIS:  There is other evidence that is less 
prejudicial that can show what the government is trying to 
offer, Judge. 
THE COURT:  Such as what?  
MS. FRANCIS:  Maybe the Sunbiz applications, the Sunbiz 
showing that his business was no longer operating, but 
certainly not a court order that prevented him from operating.  
We don't believe that that would go to show that he lied on his 
PPP applications.  We feel that that would be prejudicial 
because it would show that he has a propensity to not abide by 
orders.  
THE COURT:  All right.  Well, because this issue, I 
think, is connected to the severance question, I'm going to 
reserve on this too and hear argument on the final contested 
issue in the motion in limine which is Item Number 6.  
Mr. Keller. 
MR. KELLER:  Yes, Judge.  So Item Number 6 is the one 
thing that we are moving in specifically under Rule 404(b).  
And what this is, is an inspection that occurred the year 
before the March 29th killing where the defendant was found to 
have failed the inspection.  And we're -- and, just to be 
clear, the witness we're going to have testifying to this is 
someone we're calling anyway.  It's someone who works at the 
port, who does these inspections, and was later working and 
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involved in the March 29th -- so we're not calling additional 
witnesses for this.  
But what it's showing is that the defendant was someone 
who knew about the rules, that knew that he needed to keep a 
vessel that was maintained, that was properly operating, and 
that he didn't.  And that he can't later claim, "Oh, this was 
just some kind of accident.  This was a mistake.  I didn't know 
about the rules."  
THE COURT:  Is this -- is there documentation to 
support this failed safety inspection, or is it just the 
testimony of that one witness with other -- 
MR. KELLER:  So, Judge, Attachment C to the motion in 
limine is the one record that we would be submitting.  
THE COURT:  Okay.  
MR. KELLER:  And if you see under -- on the top of 
page 1, under the team lead, in the first -- so it says Sean T. 
Goodman, that's the person who we would already be calling 
anyway.  So he would be testifying about this as well.  
THE COURT:  Where can I see the failed inspection on 
this exhibit?  
MR. KELLER:  At the bottom of the first page, you will 
see where it says under "inspection results," "inspected with 
deficiencies noted."  
THE COURT:  So you're seeking to introduce the one from 
which month and year?  
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MR. KELLER:  So these "inspections with deficiencies 
noted" happened on -- April 24th of 2019 is when they were 
reported.  And then in the reports -- so the report goes on a 
couple more pages.  And by the end -- so on page 4 of the 
report, it notes that there are these deficiencies noted going 
through July of -- that's of 2019, just to be clear.  
THE COURT:  Do any of these deficiencies, in the 
government's view, have a factual connection to the failures of 
the vessel on March 29 of 2020?  
MR. KELLER:  So how they relate to them is that -- so 
one of the things that's going to come out during trial is that 
the defendant purchased this vessel and it was a fishing 
vessel, and he ended up refitting it for scuba, and he did that 
in a couple of different ways.  One of them that's really 
important is that he removed engine controls from one part of 
the vessel.  
So this vessel had a bridge which is kind of the high 
part of the vessel, and then it had the area in the back which 
is where the scuba divers do their thing.  And in that area, 
because it was a fishing vessel, there was a set of controls 
there, that he then manipulated by removing.  
So we're going to be introducing that as circumstantial 
evidence of what happened here; the fact that he bought this 
boat, he modified the boat, and then it's no longer functioning 
properly.  
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And I bring that up because some of the deficiencies 
involve not the same type of thing in the sense of, like, 
modifying controls, but they involve the same areas of the 
vessel; so, like, the bridge and that sort of thing.  That's 
the connection.  And I think that I speak to that -- a moment, 
Your Honor.  
So, I speak to that at the -- at the end part of the 
motion in limine on page 17.  
THE COURT:  I guess I'm just trying to understand.  The 
deficiencies that were found a year before, do they have 
anything to do with the deficiencies on the boat that the 
government believes led to the death of the victim?  I see here 
references to temporary repairs on a flybridge.  Is there 
anything more?  
MR. KELLER:  The only other things that -- the only 
thing besides the flybridge that would be connected would just 
be the fact that there was no railing in the back, which, 
again, we're talking about the back of the boat.  So it's kind 
of -- the locations are similar.  But, Judge, the thing I would 
just highlight as to this similarity issue is the fact that 
here we're really talking about the defendant's knowledge and 
his absence of mistake.  Instead of saying, like, well, because 
he messed up the specific part of the boat that time, he must 
have done it this time -- we're, instead, saying that he is 
going to argue that he wasn't negligent, that he was doing 
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everything like he should have.  And that we should be able to 
show, hey, he has had this prior vessel inspection.  He knew 
the rules.  He knew that you couldn't do these types of things, 
and this wasn't just some kind of accident.  
THE COURT:  Okay.  Thank you.  
Defense argument. 
MS. FRANCIS:  Yes.  Thank you, Judge.  
What we would argue here, and we want to make very 
clear for the Court, is, number 1, different boat, different 
mechanical issue.  The boat that the government is seeking to 
issue -- to enter into evidence is a completely different 
vessel from the one in controversy.  Two unrelated annual 
inspections, Your Honor.  They were not safety inspections.  
Again, this occurred a year before the March 29th incident.  
And the government is seeking to introduce this evidence to 
show the defendant's knowledge of rules.  
THE COURT:  Right.  But that's what they want to do 
under 404(b) --
MS. FRANCIS:  Yes.
THE COURT:  -- which is permit an avenue for this, if 
appropriate and balanced, under 403. 
MS. FRANCIS:  Yes. 
THE COURT:  So understanding that it's not the same 
boat and that it's not the same mechanical issue, why would it 
not still be relevant to show the defendant's overall knowledge 
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and lack of mistake concerning safety regulations on vessels?  
MS. FRANCIS:  Judge, we would have to say that these 
issues regarding the inspections were two totally separate 
issues.  The issue that he failed in that inspection was 
refitting his boat, changing issues on the boat.  
The government is arguing that there was a propulsion 
issue with this vessel, the one that is subject to this 
proceeding.  
So we have one boat with one issue here.  The boat had 
a propulsion issue, as far as the government is stating.  A 
year prior, we have a completely different vessel with a 
completely different reason why he failed the inspections.  It 
was failed, not because of safety; it was because he refitted 
the boat himself.  
We do not believe this evidence concerns -- concerning 
the inspection is relevant as to the defendant's knowledge of 
maritime rules and his absence of mistake.  
In this case there was no issue with refitting the 
vessel.  That is the reason why he failed the safety -- the 
annual inspection.  
Judge, a more appropriate way to show that the 
defendant has knowledge of rules and regulations would be to 
present his credentials.  That would be a more appropriate 
vessel.  
But, Judge, in this case we would have to argue this 
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would just be to show prior bad acts, which is not included 
under Rule 404(b).  It cannot be considered relevant when the 
issues are completely different and it was a completely 
different vessel.  
THE COURT:  Okay.  Okay.  I understand your argument.  
MS. FRANCIS:  Thank you. 
THE COURT:  Would the government have any objection to 
introducing the various inspections he did pass?  
MR. KELLER:  If the defense wants to offer those, we 
wouldn't object.  That would be how they would -- 
THE COURT:  All right.  I will consider --
MR. KELLER:  Judge, let me -- 
THE COURT:  -- these matters holistically. 
MR. KELLER:  I'm sorry.
Let me actually rethink that because I think that would 
be improper bolstering.  But I hear what you are saying that 
you think that -- 
THE COURT:  Well, if you want to show that he failed 
one inspection, it would seem appropriate not to object to the 
fact that he passed others, but --
MR. KELLER:  Yes, Judge. 
THE COURT:  -- that remains to be seen.  
I will consider the remaining arguments that I haven't 
ruled on today and also consider a potential limiting 
instruction, given the significant emphasis the government 
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wants to place on regulatory violations in a criminal case.  
I do want to then cover the final item in the motion in 
limine, as to which there appears to be no dispute.  
Am I correct about that, Mr. Keller?  
MR. KELLER:  Yes, Your Honor.  There is no dispute 
about Item 7.  
THE COURT:  So this concerns not referring to a 
non-prosecution by the state of Florida for the March 29 
incident.  Am I correct that all parties are on board with this 
decision not to make reference?  
MR. O'SULLIVAN:  Yes, Your Honor, I think that's 
appropriate. 
THE COURT:  Okay.  Then I will deny this aspect of the 
motion as moot in light of the absence of any objection.  
So I think that covers the two motions we had today on 
the agenda.  We remain scheduled for trial on the 24th.  I know 
there is the notice of witness unavailability beyond the 24th.  
Mr. Keller, is there any chance that you can ensure 
this witness available for one additional day?  I can't 
anticipate at this point the length of her direct or the extent 
to which the defense wishes to cross.  And what you're 
essentially presenting is a very truncated timetable on day 1 
of trial. 
MR. KELLER:  Judge, the problem is that she -- so, just 
to be clear, Ms. Hester had booked a trip to Colorado for a 
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week in September.  And what she did is that -- she originally 
was scheduled to fly out the 24th -- she moved the flight to 
the very morning of the 25th.  The reason she can't postpone it 
further is because the way that this trip works is that this 
group is going out to a remote area that you can't just, like, 
get to.  You have to be part of the lift up, I guess.  I'm not 
conversing -- 
THE COURT:  Is this like a vacation or a part of her 
work?  What is it?  
MR. KELLER:  It's a large group vacation of people who 
in this area go on, like, an annual trip with each other. 
THE COURT:  Okay.  How long do you think your direct of 
Ms. Hester will take?  
MR. KELLER:  Probably 45 minutes to an hour.  
THE COURT:  Do you have any sense, Mr. O'Sullivan, as 
far as your cross of this witness?  
MR. O'SULLIVAN:  I guess it really depends on the 
direct.  
THE COURT:  Uh-huh.  
MR. O'SULLIVAN:  Generally speaking, I have tried a lot 
of cases, and I am fairly brief in my crosses.  Obviously, I 
need to get out what I need to get out, but it kind of depends 
on the direct.  
THE COURT:  Okay.  
MR. O'SULLIVAN:  I can't see it being more than an 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 69 of 88

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hour.  If this -- if the government's going to do 45 to an 
hour, just, generally speaking, I cannot see me, you know, 
bloviating and going past that.  I just need to get what I get 
to and -- 
THE COURT:  Okay.  All right.  Well, this is helpful in 
planning.  Thank you.  
We will have our calendar call scheduled for the 18th.  
Anything further before we adjourn, Mr. Keller?  
MR. KELLER:  No.  Thank you, Your Honor.  
THE COURT:  All right.  Thank you.  
Mr. O'Sullivan or Ms. Francis?  
MS. FRANCIS:  Yes, Judge.  
I just wanted to put on the record, Your Honor, we do 
plan on filing a motion to dismiss.  Should we cross notice 
that for the calendar call upcoming?  
THE COURT:  Well, that's surprising because the 
pretrial motion's deadline long expired.  
MS. FRANCIS:  My apologies, Your Honor. 
THE COURT:  So I don't see a basis at this late 
juncture, approximately a month before trial, to open up the 
pretrial briefing again.  If you want to file a motion for 
leave to file something out of time, explaining exactly why you 
couldn't have anticipated this particular argument, I will 
consider it, but as far as I'm concerned, we have deadlines and 
a trial scheduled for the end of February.  
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 70 of 88

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23
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Thank you. 
MS. FRANCIS:  Yes, Judge. 
THE COURT:  That concludes our hearing.  
(These proceedings concluded at 11:17 a.m.) 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 71 of 88

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C E R T I F I C A T E
I hereby certify that the foregoing is an accurate 
transcription of the proceedings in the above-entitled matter.
DATE:  04-25-2025
/s/Laura Melton 
LAURA E. MELTON, RMR, CRR, FPR
Official Court Reporter 
United States District Court
Southern District of Florida 
Fort Pierce, Florida 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 72 of 88

$
$20,000 [1] <10:08> - 21:3
'
'21 [3] <09:46> - 6:8 <09:46>, 6:9
1
1 [31] <09:41> - 2:21 <09:42>, 3:13 <09:44>, 5:2 <09:45>, 
5:5 <09:45>, 5:17 <09:50>, 8:15 <09:55>, 12:5 <10:03>, 
17:18 <10:04>, 18:13 <10:06>, 19:7 <10:07>, 
20:13 <10:12>, 24:7 <10:15>, 25:22 <10:19>, 
29:4 <10:19>, 29:7 <10:19>, 29:14 <10:22>, 32:7 
<10:29>, 36:23 <10:33>, 39:6 <10:35>, 40:17 <10:35>, 
40:22 <10:35>, 41:1 <10:36>, 41:16 <10:46>, 
48:10 <10:56>, 55:14 <10:59>, 57:19 <10:59>, 
58:1 <11:00>, 58:16 <11:06>, 62:16 <11:10>, 
65:9 <11:14>, 68:22
10 [1] <09:54> - 11:7
10:00 [1] <10:25> - 34:3
11 [3] <09:46> - 6:2 <09:46>, 6:9 <10:57>, 56:14
1180 [1] <09:51> - 9:12
11:17 [1] <11:17> - 71:4
13 [1] <10:11> - 23:5
13th [1] <10:44> - 47:15
14 [3] <09:43> - 4:11 <09:51>, 9:14 <09:55>, 
11:23
1466 [1] <09:52> - 9:20
14th [1] <09:56> - 12:15
16 [1] <09:46> - 6:9
17 [2] <09:47> - 6:10 <11:08>, 64:8
18th [1] <11:16> - 70:7
1985 [1] <09:51> - 9:13
1:00 [1] <10:55> - 55:10
1A [1] <10:06> - 19:14
1B [1] <10:06> - 19:14
2
2 [16] <09:41> - 2:21 <09:42>, 3:13 <09:44>, 5:2 <09:45>, 
5:8 <09:50>, 8:15 <09:51>, 9:10 <09:55>, 12:5 <10:03>, 
17:18 <10:04>, 18:16 <10:06>, 19:7 <10:07>, 
20:13 <10:36>, 41:4 <10:40>, 44:14 <10:43>, 
46:12 <10:46>, 48:13 <10:55>, 54:17
2019 [2] <11:06> - 63:2 <11:07>, 63:6
2020 [16] <09:45> - 5:5 <09:45>, 5:8 <09:45>, 
5:17 <09:45>, 5:18 <09:56>, 13:2 <09:56>, 13:3 
<09:57>, 13:8 <09:57>, 13:18 <09:58>, 13:22 <09:58>, 
13:25 <09:58>, 14:3 <09:59>, 15:2 <10:18>, 28:8 
<10:19>, 29:6 <11:03>, 60:15 <11:07>, 63:9
2021 [3] <09:46> - 6:2 <09:56>, 12:16 <09:58>, 
13:23
23 [1] <09:44> - 4:17
24 [1] <10:25> - 34:2
24-cr-80103 [1] <09:41> - 2:5
24-hour [1] <10:27> - 35:15
24th [5] <10:10> - 22:13 <11:06>, 63:2 <11:14>, 
68:16 <11:14>, 68:17 <11:14>, 69:2
25th [1] <11:15> - 69:3
28 [2] <10:19> - 29:5 <10:27>, 35:12
28th [12] <10:19> - 29:6 <10:24>, 32:25 <10:25>, 
34:3 <10:25>, 34:5 <10:31>, 38:6 <10:31>, 38:11 
<10:31>, 38:12 <10:32>, 38:18 <10:33>, 39:10 <10:34>, 
40:8 <10:56>, 55:15 <10:58>, 57:2
29 [6] <09:45> - 5:5 <09:45>, 5:17 <10:27>, 35:12 
<10:44>, 47:14 <11:07>, 63:9 <11:13>, 68:8
29th [12] <09:56> - 12:20 <09:58>, 14:13 <10:00>, 
15:19 <10:20>, 30:6 <10:25>, 34:3 <10:41>, 45:6 
<10:51>, 52:2 <10:52>, 52:13 <11:00>, 58:18 <11:04>, 
61:21 <11:05>, 62:1 <11:10>, 65:14
3
3 [11] <09:41> - 2:21 <09:42>, 3:14 <09:44>, 5:3 <09:55>, 
12:6 <10:05>, 18:23 <10:06>, 19:7 <10:15>, 
25:22 <10:18>, 28:15 <10:43>, 46:12 <10:43>, 
46:15 <10:57>, 56:19
30 [1] <10:10> - 22:9
3rd [2] <09:56> - 12:21 <09:57>, 13:10
4
4 [8] <09:56> - 12:15 <09:57>, 13:19 <09:58>, 
13:24 <10:11>, 23:5 <10:55>, 55:12 <10:56>, 
55:14 <10:59>, 58:2 <11:06>, 63:4
4.05 [1] <10:57> - 56:15
4.06 [1] <10:57> - 56:12
401 [2] <10:29> - 36:16 <10:52>, 52:10
401(b)(1) [1] <10:40> - 44:18
403 [1] <11:10> - 65:21
404(b [8] <09:41> - 3:2 <10:02>, 16:11 <10:19>, 
29:14 <10:19>, 29:18 <10:20>, 30:10 <10:28>, 
35:16 <10:28>, 35:20 <11:10>, 65:18
404(b) [3] <10:19> - 29:13 <11:04>, 61:19 
<11:12>, 67:2
406-5 [1] <10:50> - 51:2
45 [2] <11:15> - 69:14 <11:16>, 70:1
46 [1] <10:57> - 56:12
5
5 [10] <09:41> - 2:22 <09:42>, 3:14 <09:44>, 5:3 <09:45>, 
5:8 <09:55>, 12:6 <10:06>, 19:8 <10:15>, 25:22 
<10:19>, 29:14 <10:59>, 58:4 <10:59>, 58:6
5th [2] <09:56> - 12:18 <10:10>, 22:16
6
6 [2] <11:04> - 61:16 <11:04>, 61:18
7
7 [1] <11:13> - 68:6
773 [1] <09:51> - 9:12
8
8 [5] <09:43> - 4:11 <09:51>, 9:14 <09:52>, 10:7 <09:54>, 
11:6 <09:55>, 11:23
9
905 [1] <09:52> - 9:20
9:00 [1] <10:24> - 33:16
9th [5] <09:59> - 15:1 <10:04>, 18:16 <10:59>, 
58:6 <11:00>, 58:10 <11:03>, 60:15
A
a.m [1] <11:17> - 71:4
abide [6] <10:38> - 42:20 <10:40>, 44:6 <11:02>, 
60:9 <11:03>, 60:22 <11:04>, 61:11
abided [2] <10:38> - 43:6 <10:41>, 45:11
abiding [2] <10:39> - 43:7 <10:54>, 54:6
ability [2] <10:06> - 19:13 <10:30>, 37:16
able [15] <09:44> - 4:18 <09:55>, 11:25 <09:57>, 
13:13 <10:10>, 22:15 <10:10>, 22:17 <10:28>, 
36:1 <10:31>, 38:1 <10:31>, 38:9 <10:34>, 39:21 
<10:35>, 40:14 <10:44>, 47:3 <10:46>, 48:15 <10:50>, 
51:11 <11:01>, 59:13 <11:09>, 65:1
absence [3] <11:09> - 64:22 <11:12>, 
66:17 <11:14>, 68:14
absolutely [1] <09:43> - 4:3
acceptable [1] <10:14> - 25:3
accident [8] <09:43> - 4:1 <10:16>, 27:3 
<10:16>, 27:4 <10:17>, 27:13 <10:17>, 27:15 <10:18>, 
28:11 <11:05>, 62:7 <11:10>, 65:4
accidental [1] <10:58> - 57:11
according [1] <10:48> - 49:21
73
acknowledges [1] <10:45> - 
48:5
act [4] <10:41> - 44:22 <10:55>, 54:19 <11:03>, 
60:21
action [2] <10:56> - 56:2 <11:00>, 58:17
actions [2] <10:12> - 24:4 <10:40>, 
44:13
activity [3] <09:54> - 11:11 <09:59>, 
14:19 <09:59>, 14:24
acts [5] <10:16> - 26:22 <10:29>, 36:18 <10:31>, 
38:10 <10:41>, 45:5 <11:12>, 67:1
actual [4] <09:46> - 6:1 <09:58>, 13:20 <10:21>, 
30:22 <10:48>, 49:25
add [3] <10:03> - 17:21 <10:08>, 21:8 <10:52>, 
52:19
additional [4] <09:46> - 5:21 <10:09>, 
21:25 <11:05>, 62:1 <11:14>, 68:19
addressed [1] <10:03> - 17:16
addressing [2] <09:40> - 2:3 <09:41>, 
2:17
adds [1] <10:09> - 21:19
adequately [1] <10:33> - 39:8
adjourn [1] <11:16> - 70:8
adjustments [1] <10:31> - 38:1
admissible [1] <10:39> - 43:25
admit [4] <10:29> - 36:19 <10:30>, 37:20 
<10:31>, 38:4 <10:32>, 38:14
admitted [4] <10:21> - 30:21 <10:42>, 
46:2 <10:52>, 52:17 <10:54>, 54:9
advancing [1] <10:34> - 39:23
advise [1] <10:55> - 55:8
advisement [2] <10:18> - 28:25 
<10:55>, 55:7
affects [1] <10:37> - 42:2
afield [1] <10:36> - 41:18
afloat [3] <09:49> - 8:5 <10:13>, 24:16 <10:13>, 
24:23
aftermath [1] <10:06> - 19:15
afterwards [4] <10:08> - 20:23 <10:11>, 
23:8 <10:47>, 49:16 <10:48>, 49:20
agenda [1] <11:14> - 68:16
agent [1] <09:53> - 10:18
agree [11] <09:46> - 5:24 <09:49>, 7:17 <09:49>, 
7:20 <09:52>, 10:3 <10:18>, 28:6 <10:32>, 38:21 
<10:39>, 43:11 <10:42>, 46:3 <10:51>, 52:1 <10:51>, 
52:3 <10:59>, 57:24
aground [4] <10:24> - 33:10 <10:27>, 
35:2 <10:33>, 39:4 <10:56>, 55:18
albeit [1] <11:02> - 60:6
alcohol [3] <10:44> - 47:4 <10:48>, 
50:10 <10:49>, 50:15
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 73 of 88

alerted [1] <10:29> - 36:24
alerts [1] <10:23> - 32:20
alive [1] <10:41> - 45:1
allegations [1] <09:46> - 5:21
alleged [12] <09:45> - 5:5 <09:46>, 5:22 
<09:46>, 6:3 <09:46>, 6:7 <09:49>, 7:23 <10:01>, 15:23 
<10:18>, 28:9 <10:27>, 35:11 <10:35>, 40:23 <10:38>, 
43:2 <10:59>, 57:25
allegedly [1] <10:30> - 37:21
alleging [2] <10:29> - 36:24 <10:31>, 
37:23
allow [1] <10:31> - 38:3
allowed [9] <10:00> - 15:11 <10:04>, 
18:19 <10:15>, 26:7 <10:37>, 42:6 <10:37>, 42:8 
<10:42>, 45:18 <10:44>, 47:10 <11:00>, 58:12 <11:00>, 
58:23
almost [2] <10:24> - 33:9 <10:34>, 39:21
alone [1] <10:54> - 54:13
alternative [1] <10:28> - 35:16
Alvarez [3] <10:20> - 29:23 <10:20>, 
30:10 <10:42>, 45:16
ambitious [1] <10:10> - 22:16
America [1] <09:40> - 2:4
amount [2] <09:57> - 13:9 <10:54>, 
54:13
analogy [1] <10:37> - 42:4
annual [3] <11:10> - 65:12 <11:12>, 
66:20 <11:15>, 69:11
answer [3] <10:21> - 30:25 <10:21>, 31:4 
<10:55>, 54:15
answers [1] <10:03> - 17:17
anticipate [1] <11:14> - 68:20
anticipated [1] <11:17> - 70:23
anyway [3] <09:48> - 7:8 <11:05>, 61:24 
<11:06>, 62:18
apart [2] <09:43> - 4:8 <10:04>, 18:2
apologies [1] <11:16> - 70:18
appeal [4] <09:54> - 11:17 <10:20>, 
30:14 <10:21>, 30:17 <10:21>, 30:18
appear [1] <10:27> - 35:8
appearance [1] <09:41> - 2:6
application [7] <09:56> - 12:23 
<09:57>, 13:6 <09:57>, 13:17 <09:58>, 13:20 <09:58>, 
14:6 <09:58>, 14:7 <09:58>, 14:8
applications [5] <09:46> - 5:23 
<09:48>, 7:12 <11:03>, 60:24 <11:04>, 61:6 <11:04>, 
61:10
applied [3] <09:47> - 6:22 <09:47>, 6:24 
<09:48>, 7:8
applies [1] <09:57> - 13:11
apply [1] <09:48> - 7:13
appropriate [8] <10:11> - 23:2 <10:11>, 
23:7 <10:12>, 23:20 <11:10>, 65:21 <11:12>, 
66:21 <11:12>, 66:23 <11:13>, 67:19 <11:13>, 
68:12
approves [1] <09:54> - 11:9
April [11] <09:46> - 5:22 <09:56>, 12:21 <09:57>, 
13:6 <09:57>, 13:10 <09:59>, 15:1 <10:04>, 
18:16 <10:59>, 58:6 <11:00>, 58:10 <11:03>, 
60:15 <11:06>, 63:2
area [4] <11:07> - 63:18 <11:07>, 63:19 <11:15>, 
69:5 <11:15>, 69:11
areas [1] <11:08> - 64:3
argue [16] <09:43> - 4:1 <09:43>, 4:5 <09:46>, 
6:4 <09:47>, 6:11 <09:47>, 6:23 <10:14>, 25:2 <10:28>, 
35:19 <10:38>, 43:4 <10:39>, 43:21 <10:40>, 
44:4 <10:40>, 44:12 <10:40>, 44:17 <10:58>, 
56:23 <11:09>, 64:25 <11:10>, 65:8 <11:12>, 
66:25
argued [1] <09:48> - 7:4
arguing [8] <09:54> - 11:2 <10:04>, 18:5 
<10:14>, 25:8 <10:29>, 36:15 <10:39>, 43:13 <10:40>, 
44:21 <10:55>, 54:18 <11:11>, 66:6
argument [33] <09:41> - 3:2 <09:42>, 
3:7 <09:42>, 3:21 <09:44>, 4:24 <09:53>, 10:25 
<09:59>, 14:17 <10:02>, 16:17 <10:02>, 16:24 <10:02>, 
17:3 <10:12>, 23:22 <10:13>, 24:12 <10:13>, 
24:19 <10:16>, 26:17 <10:19>, 29:14 <10:28>, 
35:17 <10:28>, 35:22 <10:28>, 35:23 <10:28>, 
36:6 <10:28>, 36:11 <10:32>, 38:20 <10:35>, 
40:20 <10:36>, 41:7 <10:39>, 43:14 <10:39>, 
43:23 <10:40>, 44:3 <10:41>, 45:12 <10:53>, 
53:11 <10:57>, 56:21 <11:04>, 61:15 <11:10>, 
65:6 <11:12>, 67:5 <11:17>, 70:23
arguments [4] <10:03> - 17:15 <10:35>, 
40:18 <10:52>, 52:6 <11:13>, 67:23
armed [1] <09:53> - 10:14
arrangements [1] <10:09> - 
21:13
arrest [2] <10:11> - 23:8 <10:11>, 23:14
arrested [1] <10:11> - 23:9
articulate [1] <10:38> - 42:17
articulated [1] <10:02> - 16:23
aspect [1] <11:13> - 68:13
aspects [1] <10:12> - 23:24
asserting [1] <10:29> - 37:3
assigned [1] <10:39> - 43:25
assistance [1] <09:49> - 7:25
associated [1] <10:57> - 56:20
attached [1] <10:36> - 41:14
Attachment [2] <10:36> - 41:14 
<11:05>, 62:12
attempting [1] <10:26> - 34:24
attorneys [3] <10:20> - 29:23 <10:48>, 
49:21 <10:48>, 49:23
August [2] <09:46> - 6:9 <09:58>, 14:7
authorities [1] <09:42> - 3:6
authority [1] <09:51> - 9:5
availability [2] <10:10> - 22:14 <10:26>, 
34:17
available [2] <10:58> - 57:16 <11:14>, 
68:19
avenue [1] <11:10> - 65:20
avoid [4] <09:49> - 8:6 <10:24>, 33:10 <10:31>, 
37:24 <10:56>, 55:19
aware [4] <09:55> - 12:2 <09:57>, 13:12 <10:22>, 
32:2 <10:36>, 41:17
awful [1] <10:06> - 19:17
B
backtracking [1] <10:48> - 
49:24
bad [6] <09:50> - 8:17 <10:29>, 36:18 <10:41>, 
44:22 <10:41>, 45:5 <11:03>, 60:21 <11:12>, 
67:1
balanced [1] <11:10> - 65:21
ban [3] <10:37> - 41:20 <10:40>, 44:20 <10:42>, 
46:6
bar [1] <10:48> - 50:9
barred [1] <11:03> - 60:14
based [4] <09:51> - 9:17 <10:17>, 27:20 
<10:31>, 38:9 <10:34>, 40:9
basic [1] <10:44> - 47:8
basis [2] <10:45> - 47:19 <11:16>, 70:19
bat [1] <09:55> - 12:13
battery [1] <10:34> - 39:19
Beach [2] <10:24> - 33:8 <10:36>, 41:15
bear [1] <10:38> - 42:22
became [1] <10:16> - 27:9
becomes [1] <10:15> - 26:9
begin [3] <09:54> - 11:5 <10:10>, 22:13 <10:19>, 
29:11
beginning [3] <10:12> - 24:6 <10:17>, 
27:17 <10:19>, 29:12
behalf [1] <09:41> - 2:9
believes [1] <11:09> - 64:12
belonged [1] <10:50> - 51:11
benefit [1] <10:25> - 33:20
best [3] <09:51> - 9:5 <10:12>, 23:22 <10:41>, 
45:8
better [1] <09:45> - 5:10
between [10] <09:42> - 3:22 <09:46>, 6:9 
<09:49>, 7:23 <09:50>, 8:11 <09:55>, 12:5 <10:06>, 
19:7 <10:15>, 25:22 <10:27>, 35:5 <10:48>, 50:3
74
beyond [4] <09:50> - 8:10 <10:00>, 
15:16 <10:38>, 43:1 <11:14>, 68:17
big [2] <10:12> - 24:2 <10:18>, 28:12
bit [2] <09:52> - 9:21 <10:36>, 41:18
blood [1] <10:50> - 51:6
bloviating [1] <11:16> - 70:3
board [1] <11:13> - 68:9
boat [45] <09:44> - 4:21 <10:04>, 18:18 <10:16>, 
26:24 <10:18>, 28:20 <10:20>, 30:5 <10:22>, 
31:18 <10:22>, 31:24 <10:22>, 32:6 <10:23>, 
32:8 <10:23>, 32:10 <10:25>, 33:18 <10:26>, 
34:9 <10:33>, 39:3 <10:33>, 39:8 <10:33>, 39:14 
<10:34>, 39:20 <10:34>, 40:10 <10:35>, 40:14 <10:37>, 
42:7 <10:41>, 45:10 <10:42>, 45:17 <10:42>, 
45:19 <10:42>, 45:24 <10:43>, 46:22 <10:50>, 
51:11 <10:56>, 56:5 <10:57>, 56:6 <11:02>, 
59:21 <11:02>, 60:4 <11:03>, 60:12 <11:03>, 
60:24 <11:08>, 63:24 <11:09>, 64:11 <11:09>, 
64:18 <11:09>, 64:23 <11:10>, 65:9 <11:10>, 
65:10 <11:10>, 65:24 <11:11>, 66:5 <11:11>, 
66:9 <11:11>, 66:14
boat's [2] <10:32> - 38:15
bolstering [1] <11:13> - 67:16
booked [1] <11:14> - 68:25
bottom [1] <11:06> - 62:21
bought [2] <10:07> - 20:14 <11:08>, 
63:23
brazenly [1] <10:03> - 17:7
breach [1] <10:28> - 35:25
breached [3] <10:38> - 42:15 <10:46>, 
48:11 <10:54>, 54:3
break [1] <09:46> - 5:25
breath [1] <10:50> - 51:6
bridge [5] <10:24> - 33:8 <10:31>, 37:24 
<10:56>, 55:19 <11:07>, 63:17 <11:08>, 64:4
brief [7] <09:48> - 7:5 <10:44>, 47:12 <10:53>, 
53:19 <10:57>, 56:13 <10:57>, 56:21 <11:01>, 
59:14 <11:15>, 69:21
briefed [3] <09:41> - 2:24 <09:42>, 3:5 <10:20>, 
29:22
briefing [1] <11:16> - 70:21
bring [2] <10:56> - 56:5 <11:08>, 64:1
broad [1] <09:48> - 7:16
broadly [1] <10:40> - 44:11
broken [2] <10:24> - 33:4 <10:28>, 36:11
brought [1] <10:24> - 33:15
bruise [1] <10:23> - 32:13
bucket [1] <09:55> - 12:8
builds [1] <10:17> - 27:19
built [2] <10:17> - 28:5 <10:18>, 28:13
burden [2] <10:07> - 20:6 <10:09>, 21:20
business [38] <09:47> - 7:1 <09:48>, 7:3 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 74 of 88

<09:48>, 7:7 <09:48>, 7:9 <09:48>, 7:14 <09:49>, 8:4 <09:59>, 
14:19 <09:59>, 14:25 <10:00>, 15:6 <10:01>, 
15:21 <10:04>, 18:5 <10:04>, 18:11 <10:04>, 
18:14 <10:07>, 19:25 <10:08>, 21:3 <10:12>, 
24:9 <10:13>, 24:16 <10:13>, 24:17 <10:13>, 
24:23 <10:14>, 25:10 <10:14>, 25:14 <10:14>, 
25:16 <10:14>, 25:19 <10:15>, 26:4 <10:15>, 
26:8 <10:15>, 26:10 <10:17>, 27:22 <10:18>, 
28:16 <10:45>, 47:22 <10:46>, 48:20 <10:46>, 
48:24 <11:00>, 58:24 <11:02>, 60:3 <11:02>, 
60:5 <11:04>, 61:7
businesses [3] <09:47> - 6:23 <09:47>, 
6:24 <09:49>, 7:24
buying [1] <10:04> - 18:8
C
calendar [2] <11:16> - 70:7 <11:16>, 
70:15
Calisha [1] <09:41> - 2:12
cannot [2] <11:12> - 67:2 <11:16>, 70:2
capsized [1] <10:42> - 45:22
captain [5] <10:22> - 31:21 <10:22>, 
32:2 <10:23>, 32:19 <10:47>, 49:8 <11:01>, 59:7
Captain [10] <09:59> - 15:1 <10:00>, 
15:12 <10:04>, 18:17 <10:06>, 19:11 <10:59>, 
58:6 <10:59>, 58:7 <11:01>, 59:6 <11:01>, 59:7 
<11:01>, 59:10 <11:01>, 59:11
cares [2] <10:39> - 43:22
case [51] <09:30> - 2:2 <09:42>, 3:24 <09:44>, 
4:20 <09:49>, 7:21 <09:49>, 8:1 <09:51>, 9:18 <09:52>, 
10:7 <09:52>, 10:8 <09:53>, 10:11 <09:53>, 
10:13 <09:53>, 10:17 <09:54>, 11:13 <09:54>, 
11:14 <09:55>, 12:6 <09:55>, 12:7 <09:59>, 
14:18 <10:01>, 16:10 <10:03>, 17:22 <10:05>, 
19:6 <10:09>, 21:24 <10:11>, 22:25 <10:11>, 
23:3 <10:11>, 23:6 <10:11>, 23:14 <10:12>, 
23:24 <10:13>, 24:24 <10:15>, 26:11 <10:15>, 
26:14 <10:16>, 27:11 <10:20>, 30:1 <10:20>, 
30:8 <10:21>, 31:9 <10:21>, 31:14 <10:22>, 32:1 
<10:25>, 33:25 <10:37>, 42:5 <10:37>, 42:6 <10:38>, 
42:19 <10:43>, 47:1 <10:47>, 49:4 <10:53>, 
53:14 <10:53>, 53:24 <10:54>, 54:7 <10:54>, 
54:14 <10:55>, 54:23 <10:55>, 54:24 <11:01>, 
59:4 <11:01>, 59:5 <11:12>, 66:18 <11:12>, 
66:25 <11:13>, 68:1
Case [1] <09:41> - 2:5
cases [11] <09:51> - 9:7 <09:52>, 10:5 <09:53>, 
10:16 <09:54>, 11:9 <10:01>, 16:1 <10:01>, 16:9 
<10:03>, 17:16 <10:03>, 17:23 <10:10>, 22:19 <10:38>, 
42:19 <11:15>, 69:21
cash [2] <09:47> - 7:1 <09:49>, 8:4
cashing [1] <10:04> - 18:9
Cassisi [1] <10:55> - 55:8
Casualty [1] <10:57> - 56:15
casualty [3] <10:43> - 46:16 <10:47>, 
49:2 <10:58>, 57:3
causation [5] <10:31> - 38:5 <10:31>, 
38:7 <10:31>, 38:9 <10:55>, 54:18 <10:56>, 
55:24
caused [7] <09:45> - 5:19 <09:48>, 7:5 <09:48>, 
7:12 <10:19>, 29:9 <10:32>, 39:1 <10:37>, 42:10 
<10:55>, 54:20
causes [1] <10:39> - 43:18
causing [2] <09:42> - 3:23 <10:02>, 
16:21
center [1] <10:05> - 18:24
certain [1] <10:58> - 57:15
certainly [6] <09:52> - 10:3 <09:55>, 
12:3 <10:17>, 28:5 <10:35>, 41:1 <10:59>, 57:22 
<11:04>, 61:8
certificate [1] <10:45> - 48:1
cetera [1] <10:28> - 35:22
CFR [1] <10:46> - 48:12
challenge [5] <10:09> - 21:12 <10:20>, 
30:11 <10:35>, 40:19 <10:59>, 57:23
challenged [1] <10:21> - 30:20
challenging [1] <09:55> - 11:20
chance [1] <11:14> - 68:18
changing [1] <11:11> - 66:5
channel [2] <10:31> - 37:25 <10:58>, 
57:14
character [2] <10:29> - 36:21 <10:40>, 
44:17
charge [11] <09:52> - 9:25 <09:52>, 10:1 
<09:57>, 13:15 <09:57>, 13:16 <10:19>, 29:21 <10:26>, 
34:23 <10:34>, 39:22 <10:40>, 44:13 <10:42>, 
45:25 <10:42>, 46:4 <10:59>, 58:8
charged [5] <10:11> - 23:9 <10:19>, 29:7 
<10:49>, 50:25 <11:02>, 60:9 <11:03>, 60:21
charges [7] <09:44> - 4:16 <09:45>, 5:10 
<09:45>, 5:12 <09:45>, 5:15 <09:51>, 9:8 <10:11>, 
23:12 <10:42>, 46:8
charter [1] <10:08> - 20:16
Charters [1] <10:04> - 18:5
charters [2] <09:46> - 5:20
chemical [1] <10:45> - 47:18
chopped [1] <10:25> - 33:23
chronology [7] <09:44> - 5:4 <09:45>, 
5:9 <09:55>, 12:10 <09:56>, 12:18 <09:58>, 
14:11 <09:59>, 15:4 <10:10>, 22:8
chunk [1] <10:18> - 28:12
Circuit [9] <09:51> - 9:13 <09:54>, 11:9 <09:55>, 
11:21 <09:55>, 11:22 <10:01>, 16:5 <10:01>, 
16:9 <10:03>, 17:19 <10:12>, 23:20 <10:37>, 
42:5
circuit [1] <10:20> - 29:22
circuits [2] <09:55> - 11:22 <10:12>, 
23:21
circumstances [1] <09:51> - 
9:4
circumstantial [2] <10:06> - 
19:22 <11:07>, 63:22
circumstantially [1] <10:06> - 
19:23
cite [2] <09:51> - 9:11 <10:11>, 23:3
cited [4] <09:42> - 3:7 <09:51>, 9:6 <10:38>, 
42:19 <10:54>, 54:8
cites [1] <10:16> - 27:11
civil [4] <10:39> - 43:16 <10:53>, 53:13 <10:53>, 
53:22 <10:54>, 53:25
claim [3] <10:14> - 25:4 <10:20>, 30:12 <11:05>, 
62:6
claimed [2] <10:12> - 24:6 <11:00>, 
58:24
claiming [3] <10:30> - 37:13 <10:30>, 
37:16 <10:34>, 40:2
claims [1] <10:14> - 25:15
clarification [2] <09:56> - 12:14 
<10:19>, 29:19
clarify [7] <09:55> - 12:11 <10:12>, 23:19 
<10:18>, 28:19 <10:18>, 28:23 <10:19>, 29:12 <10:19>, 
29:14 <10:26>, 34:12
clear [9] <09:51> - 9:12 <09:57>, 13:17 <10:13>, 
25:1 <10:59>, 57:18 <11:03>, 60:13 <11:05>, 
61:23 <11:07>, 63:6 <11:10>, 65:9 <11:14>, 
68:25
clearly [1] <10:17> - 27:22
closely [3] <09:53> - 10:10 <09:53>, 
10:19 <10:59>, 57:19
closing [1] <10:32> - 38:21
Club [1] <10:04> - 18:9
co [3] <09:52> - 10:8 <09:52>, 10:9 <09:53>, 
10:18
co-conspirator [2] <09:52> - 
10:8 <09:52>, 10:9
co-conspirators [1] <09:53> - 
10:18
Coast [15] <09:59> - 14:14 <10:05>, 19:3 
<10:08>, 20:18 <10:15>, 26:7 <10:43>, 46:17 <10:45>, 
48:5 <10:48>, 49:22 <10:48>, 49:25 <10:48>, 
50:4 <10:49>, 50:14 <10:56>, 55:20 <10:56>, 
55:25 <10:58>, 57:4 <11:01>, 59:12
cocaine [3] <09:52> - 10:1 <10:21>, 
30:15 <10:42>, 45:21
code [1] <10:49> - 51:1
collide [1] <10:24> - 33:7
collided [1] <10:24> - 33:9
Colorado [2] <10:08> - 21:10 <11:14>, 
68:25
75
coming [2] <10:16> - 26:19 <10:57>, 
56:12
commit [8] <09:54> - 11:16 <10:16>, 
26:23 <10:17>, 27:14 <10:17>, 27:18 <10:18>, 
28:9 <10:29>, 36:18 <10:53>, 53:15 <11:03>, 
60:20
committed [2] <10:11> - 23:14 <10:13>, 
24:15
common [6] <09:42> - 3:25 <09:47>, 
6:13 <10:16>, 26:20 <10:16>, 26:25 <10:17>, 
27:12 <10:17>, 27:19
company [2] <10:45> - 47:21 <10:51>, 
51:15
comparatively [1] <10:12> - 
23:25
compared [1] <10:12> - 24:1
completely [12] <09:43> - 4:9 <09:45>, 
5:13 <09:54>, 11:18 <09:54>, 11:19 <09:57>, 
13:14 <10:03>, 17:25 <10:40>, 44:5 <11:10>, 
65:11 <11:11>, 66:11 <11:11>, 66:12 <11:12>, 
67:3
compliance [2] <10:45> - 48:1 <10:53>, 
53:14
complied [3] <10:38> - 43:1 <10:40>, 
44:20 <10:59>, 57:22
comply [8] <10:49> - 50:12 <10:49>, 
51:1 <10:51>, 51:19 <10:51>, 51:20 <10:51>, 
51:23 <10:52>, 52:16 <11:02>, 59:22 <11:02>, 
60:8
component [4] <09:54> - 11:10 
<10:20>, 30:13 <10:57>, 56:20 <10:59>, 57:19
concern [3] <09:50> - 8:14 <09:50>, 8:25 
<10:52>, 52:23
concerned [3] <10:20> - 30:3 <10:53>, 
53:13 <11:17>, 70:24
concerning [3] <10:20> - 30:12 
<11:11>, 66:1 <11:11>, 66:15
concerns [7] <10:05> - 19:3 <10:19>, 
29:5 <10:42>, 46:4 <10:52>, 52:22 <10:59>, 58:6 
<11:11>, 66:15 <11:13>, 68:7
concluded [1] <11:17> - 71:4
concludes [1] <11:17> - 71:3
conclusion [1] <10:33> - 39:10
conclusively [1] <10:32> - 
38:16
condition [2] <09:49> - 8:4 <10:23>, 
32:21
conduct [7] <09:57> - 13:18 <10:12>, 
24:7 <10:43>, 46:18 <10:56>, 55:23 <10:57>, 
56:10 <10:59>, 57:25 <11:00>, 58:18
conferred [2] <10:48> - 50:6 <10:49>, 
50:12
connect [1] <10:38> - 43:2
connected [2] <11:04> - 61:14 <11:09>, 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 75 of 88

64:16
connection [11] <09:45> - 5:11 <09:49>, 
7:23 <09:49>, 8:6 <09:55>, 12:5 <10:06>, 19:7 <10:13>, 
25:1 <10:15>, 25:22 <10:17>, 27:25 <10:41>, 
45:8 <11:07>, 63:8 <11:08>, 64:5
consider [5] <10:01> - 16:7 <11:12>, 
67:11 <11:13>, 67:23 <11:13>, 67:24 <11:17>, 
70:24
considerations [1] <10:12> - 
24:1
considered [3] <10:20> - 30:2 <10:54>, 
54:11 <11:12>, 67:2
considering [1] <09:49> - 7:17
Consortium [1] <10:45> - 47:22
consortium [2] <10:45> - 48:9 <10:53>, 
53:1
conspirator [2] <09:52> - 10:8 <09:52>, 
10:9
conspirators [1] <09:53> - 
10:18
contemporaneously 
[1] <10:36> - 41:2
contested [1] <11:04> - 61:15
contesting [1] <10:38> - 42:14
context [4] <09:51> - 9:6 <10:05>, 18:25 
<10:39>, 43:16 <10:55>, 54:22
continue [3] <10:01> - 15:20 <10:21>, 
31:6 <11:02>, 59:24
continued [1] <11:02> - 60:5
continuing [1] <09:46> - 5:21
control [1] <10:57> - 56:20
controls [3] <11:07> - 63:15 <11:07>, 
63:20 <11:08>, 64:3
controversy [1] <11:10> - 65:12
conversant [1] <10:27> - 34:25
conversation [1] <09:44> - 4:23
conversing [1] <11:15> - 69:7
convicted [2] <10:11> - 23:10 <10:11>, 
23:17
convicting [1] <10:02> - 17:6
core [2] <10:13> - 24:12 <10:28>, 35:23
correct [12] <09:41> - 2:20 <09:41>, 2:22 
<09:41>, 2:23 <09:45>, 5:6 <10:19>, 29:20 <10:27>, 
35:13 <10:28>, 35:23 <10:41>, 45:2 <10:58>, 
57:6 <11:03>, 60:16 <11:13>, 68:4 <11:13>, 68:9
correctly [1] <10:02> - 16:23
cost [1] <10:18> - 28:16
Counsel [2] <10:36> - 41:11 <10:59>, 
57:23
counsel [4] <10:16> - 26:17 <10:28>, 
36:8 <10:32>, 38:19 <11:01>, 59:17
counsel's [1] <09:41> - 2:14
count [7] <09:42> - 3:12 <09:56>, 12:16 <09:57>, 
13:19 <10:01>, 16:7 <10:01>, 16:8
Count [16] <09:42> - 3:14 <09:45>, 5:5 <09:45>, 
5:8 <09:45>, 5:17 <09:56>, 12:15 <09:57>, 13:19 
<09:58>, 13:24 <10:07>, 20:13 <10:12>, 24:7 <10:15>, 
25:22 <10:19>, 29:7 <10:33>, 39:6 <10:35>, 
40:17 <10:35>, 40:22 <10:59>, 58:1
counteract [1] <10:52> - 52:8
country [2] <09:47> - 6:24 <09:49>, 7:25
Counts [7] <09:41> - 2:21 <09:42>, 3:13 
<09:44>, 5:2 <09:44>, 5:3 <09:50>, 8:15 <09:55>, 12:5 <10:06>, 
19:7
counts [5] <09:45> - 5:18 <10:02>, 17:6 <10:10>, 
22:20 <10:12>, 24:10 <10:13>, 24:20
County [1] <10:36> - 41:15
couple [3] <09:55> - 12:11 <11:06>, 63:4 
<11:07>, 63:14
course [13] <09:47> - 6:15 <09:49>, 7:25 
<10:00>, 15:9 <10:04>, 18:7 <10:06>, 19:8 <10:10>, 
22:18 <10:17>, 27:18 <10:35>, 40:19 <10:36>, 
41:3 <10:43>, 46:17 <10:51>, 51:17 <10:53>, 
53:4
court [6] <09:42> - 3:17 <10:21>, 30:19 <10:21>, 
30:23 <11:02>, 60:8 <11:04>, 61:8
Court [15] <09:29> - 2:1 <09:40>, 2:3 <09:41>, 
2:12 <09:41>, 2:18 <09:42>, 3:11 <09:50>, 8:9 <09:51>, 
9:14 <09:53>, 10:20 <10:11>, 23:13 <10:16>, 
27:10 <10:17>, 28:3 <10:18>, 28:21 <10:18>, 
28:22 <10:22>, 32:4 <11:10>, 65:9
COURT [133] <09:30> - 2:2 <09:41>, 2:10 
<09:41>, 2:15 <09:41>, 2:24 <09:42>, 3:15 <09:42>, 
3:17 <09:44>, 5:4 <09:45>, 5:8 <09:45>, 5:16 <09:47>, 
6:14 <09:48>, 7:16 <09:49>, 7:21 <09:50>, 8:12 
<09:50>, 8:23 <09:51>, 9:5 <09:51>, 9:16 <09:52>, 9:21 
<09:52>, 9:24 <09:52>, 10:2 <09:53>, 11:1 <09:54>, 
11:4 <09:55>, 12:2 <09:58>, 13:23 <09:58>, 14:2 
<09:58>, 14:9 <09:59>, 15:5 <10:00>, 15:17 <10:02>, 
16:19 <10:02>, 17:4 <10:03>, 17:12 <10:04>, 
18:21 <10:05>, 19:6 <10:07>, 20:3 <10:09>, 
21:16 <10:09>, 22:1 <10:09>, 22:4 <10:10>, 
22:10 <10:10>, 22:18 <10:13>, 24:13 <10:14>, 
25:11 <10:14>, 25:18 <10:15>, 26:13 <10:16>, 
26:16 <10:17>, 27:16 <10:18>, 28:18 <10:18>, 
28:24 <10:19>, 29:16 <10:19>, 29:19 <10:20>, 
30:10 <10:21>, 30:19 <10:21>, 31:2 <10:21>, 
31:5 <10:26>, 34:11 <10:27>, 35:11 <10:28>, 
35:16 <10:28>, 36:5 <10:28>, 36:13 <10:30>, 
37:8 <10:30>, 37:11 <10:32>, 38:19 <10:35>, 
40:13 <10:35>, 40:16 <10:36>, 41:7 <10:36>, 
41:17 <10:38>, 42:16 <10:38>, 42:23 <10:39>, 
43:9 <10:40>, 44:3 <10:40>, 44:9 <10:40>, 44:19 
<10:41>, 44:24 <10:41>, 45:7 <10:42>, 46:3 <10:44>, 
47:8 <10:44>, 47:13 <10:44>, 47:16 <10:46>, 
48:19 <10:47>, 49:7 <10:47>, 49:11 <10:47>, 
49:17 <10:48>, 49:24 <10:49>, 50:16 <10:51>, 
52:1 <10:51>, 52:5 <10:52>, 52:20 <10:53>, 53:9 
<10:53>, 53:11, 53:23 <10:54>, 54:11 <10:55>, 
55:1 <10:55>, 55:4 <10:55>, 55:6 <10:55>, 55:11 
<10:57>, 56:11 <10:57>, 56:17 <10:57>, 56:21 <10:58>, 
57:5 <10:58>, 57:8 <10:59>, 57:17 <11:01>, 
59:16 <11:03>, 60:13 <11:03>, 60:17 <11:03>, 
61:1 <11:03>, 61:5 <11:04>, 61:13 <11:05>, 62:9 
<11:05>, 62:14 <11:06>, 62:19 <11:06>, 62:24 <11:07>, 
63:7 <11:08>, 64:9 <11:10>, 65:5 <11:10>, 65:17 
<11:10>, 65:20 <11:10>, 65:23 <11:12>, 67:5 <11:12>, 
67:7 <11:12>, 67:11 <11:13>, 67:13 <11:13>, 
67:18 <11:13>, 67:22 <11:13>, 68:7 <11:13>, 
68:13 <11:15>, 69:8 <11:15>, 69:12 <11:15>, 
69:15 <11:15>, 69:19 <11:16>, 69:24 <11:16>, 
70:5 <11:16>, 70:10 <11:16>, 70:16 <11:16>, 
70:19 <11:17>, 71:3
Court's [1] <10:52> - 52:22
COURTROOM [2] <09:40> - 2:4 
<10:55>, 55:10
courts [2] <09:55> - 12:1 <10:37>, 41:23
cover [2] <09:59> - 14:20 <11:13>, 68:2
covers [1] <11:14> - 68:15
COVID [2] <09:47> - 6:21 <10:40>, 44:20
COVID-19 [7] <10:36> - 41:15 <10:37>, 
41:20 <10:38>, 42:24 <10:39>, 43:10 <10:40>, 
44:7 <10:41>, 45:8 <10:42>, 46:6
created [2] <10:07> - 20:4 <10:34>, 40:2
credentials [1] <11:12> - 66:23
crew [14] <10:05> - 19:4 <10:43>, 46:21 <10:44>, 
47:5 <10:45>, 47:19 <10:46>, 48:16 <10:46>, 
48:21 <10:48>, 49:20 <10:48>, 50:7 <10:48>, 
50:8 <10:49>, 50:20 <10:49>, 50:23 <10:51>, 
51:21 <10:55>, 55:2
crime [9] <09:43> - 4:6 <09:54>, 11:11 <10:11>, 
23:14 <10:29>, 36:18 <10:49>, 51:1 <10:55>, 
54:21 <11:02>, 60:9 <11:03>, 60:20 <11:03>, 
60:21
crimes [5] <09:43> - 4:7 <09:43>, 4:9 <10:01>, 
16:2 <10:17>, 27:18 <10:18>, 28:9
criminal [8] <09:50> - 8:17 <10:16>, 
26:22 <10:53>, 53:14 <10:54>, 54:1 <10:54>, 
54:13 <10:54>, 54:14 <10:55>, 54:22 <11:13>, 
68:1
critical [2] <10:21> - 31:9 <10:21>, 31:10
cross [4] <10:32> - 38:20 <11:14>, 68:21 
<11:15>, 69:16 <11:16>, 70:14
cross-examination [1] 
<10:32> - 38:20
crosses [1] <11:15> - 69:21
crux [2] <09:42> - 3:21 <09:53>, 10:25
curious [1] <10:08> - 21:1
current [1] <11:01> - 59:7
customers [1] <10:46> - 48:21
76
D
danger [7] <10:00> - 15:19 <10:01>, 16:3 
<10:20>, 30:5 <10:21>, 31:13 <10:22>, 32:6 <10:28>, 
35:21 <11:00>, 58:12
dangerous [4] <10:23> - 32:21 <10:26>, 
34:10 <10:45>, 47:18 <10:57>, 56:6
date [8] <09:45> - 5:5 <09:45>, 5:8 <09:46>, 6:5 <10:27>, 
35:11 <10:41>, 45:6 <10:47>, 49:13 <10:48>, 
49:25 <10:51>, 52:2
dates [1] <09:43> - 4:8
Davis [4] <09:51> - 9:11 <09:52>, 9:22 <09:52>, 
9:25 <10:16>, 26:21
days [2] <10:45> - 48:4 <10:45>, 48:6
deadline [1] <11:16> - 70:17
deadlines [1] <11:17> - 70:24
deal [2] <10:01> - 16:4 <10:36>, 41:2
death [17] <09:42> - 3:23 <09:44>, 4:22 <09:46>, 
6:5 <09:46>, 6:6 <09:47>, 6:23 <09:50>, 8:18 <09:50>, 
8:22 <09:56>, 12:20 <09:58>, 14:13 <09:59>, 
14:24 <10:00>, 15:7 <10:01>, 15:23 <10:19>, 
29:9 <10:36>, 41:10 <10:41>, 45:12 <10:55>, 
54:20 <11:09>, 64:12
decision [1] <11:13> - 68:10
deeper [1] <10:19> - 29:2
defend [3] <10:33> - 39:12 <10:34>, 
39:18 <10:35>, 40:12
defendant [54] <09:45> - 5:19 <09:50>, 
8:16 <09:56>, 12:22 <09:56>, 13:3 <09:58>, 
13:21 <10:04>, 18:4 <10:07>, 19:24 <10:07>, 
20:12 <10:07>, 20:13 <10:11>, 23:4 <10:11>, 
23:8 <10:12>, 24:5 <10:13>, 24:20 <10:14>, 25:9 
<10:19>, 29:8 <10:20>, 30:4 <10:20>, 30:6 <10:21>, 
31:11 <10:22>, 32:1 <10:23>, 32:16 <10:23>, 
32:22 <10:24>, 33:15 <10:25>, 34:4 <10:25>, 
34:7 <10:26>, 34:24 <10:29>, 36:24 <10:30>, 
37:12 <10:30>, 37:18 <10:30>, 37:21 <10:31>, 
37:24 <10:31>, 38:1 <10:32>, 38:25 <10:36>, 
41:8 <10:37>, 42:7 <10:38>, 42:14 <10:39>, 44:1 
<10:41>, 45:4 <10:42>, 45:21 <10:43>, 46:19 <10:43>, 
46:24 <10:43>, 47:1 <10:44>, 47:6 <10:45>, 48:3 
<10:46>, 48:10 <10:46>, 48:18 <10:57>, 56:10 <11:00>, 
58:11 <11:00>, 58:21 <11:02>, 59:24 <11:03>, 
60:20 <11:04>, 61:21 <11:05>, 62:3 <11:07>, 
63:12 <11:12>, 66:22
defendant's [14] <10:06> - 
19:13 <10:21>, 30:15 <10:29>, 36:17 <10:29>, 
36:21 <10:31>, 38:9 <10:40>, 44:16 <10:58>, 
57:2 <11:00>, 58:17 <11:02>, 59:20 <11:02>, 
60:2 <11:09>, 64:21 <11:10>, 65:16 <11:11>, 
65:25 <11:11>, 66:16
defense [20] <09:41> - 2:13 <09:41>, 
2:14 <09:41>, 2:20 <09:59>, 14:17 <10:07>, 20:5 
<10:14>, 25:9 <10:15>, 26:2 <10:16>, 26:17 <10:16>, 
27:2 <10:18>, 28:12 <10:35>, 41:1 <10:38>, 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 76 of 88

42:14 <10:39>, 43:21 <10:40>, 44:3 <10:42>, 
46:4 <10:49>, 50:17 <11:01>, 59:17 <11:10>, 
65:6 <11:12>, 67:9 <11:14>, 68:21
defense's [2] <10:02> - 16:17 <10:03>, 
17:10
deficiencies [7] <11:06> - 62:23 
<11:06>, 63:1 <11:06>, 63:5 <11:07>, 63:7 <11:08>, 
64:1 <11:09>, 64:10 <11:09>, 64:11
defined [2] <10:36> - 41:15 <10:58>, 
56:25
degree [2] <10:07> - 20:7
deliberate [1] <10:58> - 57:11
delve [1] <10:19> - 29:2
demonstrating [2] <10:29> - 
36:21 <10:40>, 44:16
denied [1] <09:51> - 9:7
deny [3] <09:53> - 10:20 <10:43>, 46:11 <11:13>, 
68:13
DEPUTY [2] <09:40> - 2:4 <10:55>, 
55:10
described [3] <09:43> - 4:5 <10:19>, 
29:5 <10:24>, 32:25
despite [2] <10:03> - 17:8 <10:30>, 
37:12
detained [1] <10:50> - 51:9
determination [1] <09:51> - 
9:17
determine [1] <10:17> - 28:4
determined [2] <10:47> - 49:6 <10:50>, 
51:5
died [1] <09:50> - 8:25
difference [1] <09:47> - 6:11
different [26] <09:43> - 4:10 <09:44>, 
4:16 <09:45>, 5:14 <09:53>, 10:18 <09:53>, 
10:22 <09:53>, 10:23 <10:04>, 18:3 <10:13>, 
24:19 <10:15>, 26:4 <10:18>, 28:7 <10:22>, 
31:23 <10:22>, 31:25 <10:22>, 32:2 <10:39>, 
43:14 <10:54>, 54:1 <11:07>, 63:14 <11:10>, 
65:9 <11:10>, 65:11 <11:11>, 66:11 <11:11>, 
66:12 <11:12>, 67:3 <11:12>, 67:4
diligence [1] <10:23> - 32:20
dire [1] <10:17> - 27:22
direct [11] <10:06> - 19:21 <10:07>, 20:9 
<10:15>, 26:9 <10:56>, 55:23 <10:57>, 56:9 <11:00>, 
58:15 <11:14>, 68:20 <11:15>, 69:12 <11:15>, 
69:18 <11:15>, 69:23
directed [4] <10:50> - 51:7 <10:50>, 51:8 
<10:58>, 57:7 <10:58>, 57:15
directing [1] <10:54> - 54:12
directive [1] <10:38> - 43:1
directly [10] <09:57> - 13:19 <10:08>, 
21:5 <10:09>, 21:23 <10:32>, 38:24 <10:33>, 
39:5 <10:37>, 41:20 <10:37>, 42:10 <10:47>, 
49:6 <10:50>, 51:5 <10:50>, 51:12
disagree [1] <10:59> - 57:24
discretion [2] <09:51> - 9:15 <09:53>, 
10:20
discuss [2] <10:06> - 19:12 <10:59>, 
58:4
discussed [2] <09:54> - 11:14 <09:59>, 
15:2
discussing [2] <10:05> - 18:25 <10:05>, 
19:5
discussion [2] <10:37> - 42:5 <10:39>, 
43:20
disfavors [1] <10:17> - 27:25
dismiss [1] <11:16> - 70:14
disprove [2] <10:52> - 52:7 <10:53>, 
53:4
dispute [6] <09:42> - 3:3 <10:21>, 30:22 
<10:59>, 57:22 <11:03>, 60:13 <11:13>, 68:3 <11:13>, 
68:5
disregard [3] <10:37> - 42:11 <10:40>, 
44:10 <10:44>, 47:2
disregarding [1] <10:39> - 44:1
dissimilarity [1] <10:43> - 46:11
distill [1] <10:15> - 25:22
distinct [1] <09:51> - 9:9
district [3] <10:21> - 30:19 <10:21>, 
30:23 <11:00>, 58:10
dive [1] <11:02> - 59:24
divers [1] <11:07> - 63:19
divorce [2] <10:16> - 27:8 <10:18>, 
28:15
dock [5] <10:24> - 33:1 <10:24>, 33:7 <10:31>, 
38:2 <10:33>, 39:3 <10:58>, 57:15
docket [2] <10:19> - 29:5 <10:44>, 47:14
document [2] <10:53> - 53:19 <11:01>, 
59:12
documentation [2] <10:49> - 
50:14 <11:05>, 62:9
done [8] <10:00> - 15:12 <10:00>, 15:15 <10:03>, 
17:19 <10:13>, 24:21 <10:48>, 50:6 <10:49>, 
50:13 <10:49>, 50:15 <11:09>, 64:24
down [16] <09:42> - 3:18 <09:43>, 4:4 <09:44>, 
5:4 <09:45>, 5:13 <09:48>, 7:14 <10:04>, 18:15 
<10:15>, 26:8 <10:18>, 28:17 <10:20>, 30:1 <10:24>, 
33:8 <10:25>, 33:22 <10:25>, 33:24 <11:02>, 
59:21 <11:02>, 60:2 <11:02>, 60:3 <11:02>, 60:4
dozen [1] <10:09> - 21:18
draft [1] <10:09> - 22:7
draw [3] <09:49> - 7:22 <09:49>, 8:6 <10:37>, 
42:4
dredge [1] <10:09> - 21:11
drill [1] <09:44> - 5:4
drinking [2] <10:44> - 47:4 <10:48>, 
50:10
drive [1] <10:50> - 51:11
driving [1] <10:37> - 42:8
drove [1] <10:23> - 32:23
drowned [1] <10:25> - 33:25
drug [24] <10:05> - 19:1 <10:05>, 19:3 <10:43>, 
46:18 <10:43>, 46:19 <10:45>, 47:23 <10:46>, 
48:20 <10:46>, 48:22 <10:47>, 48:25 <10:47>, 
49:1 <10:47>, 49:5 <10:47>, 49:7 <10:48>, 50:5 
<10:50>, 51:2 <10:50>, 51:8 <10:51>, 51:15 <10:51>, 
51:16 <10:51>, 51:20 <10:52>, 52:14 <10:52>, 
52:18 <10:53>, 53:1 <10:53>, 53:2 <10:53>, 53:6 
<10:53>, 53:7
drugs [2] <10:44> - 47:4 <10:45>, 47:18
during [4] <09:48> - 7:2 <10:47>, 49:12 <11:00>, 
58:20 <11:07>, 63:11
Dustin [1] <09:40> - 2:4
duties [3] <10:32> - 38:23 <10:42>, 46:5 
<10:43>, 46:10
duty [8] <10:28> - 35:25 <10:38>, 42:15 <10:38>, 
42:16 <10:38>, 42:20 <10:40>, 44:5 <10:40>, 
44:6 <10:46>, 48:11
E
easily [2] <10:03> - 17:24 <10:31>, 38:9
economies [1] <09:55> - 12:3
economy [3] <09:43> - 4:12 <09:44>, 
4:24 <09:55>, 11:25
effective [1] <10:01> - 16:4
effectively [3] <10:01> - 15:21 <10:01>, 
15:22 <11:02>, 60:2
efficiency [1] <09:55> - 12:4
efficiently [1] <09:55> - 12:1
eight [2] <09:53> - 10:17 <10:09>, 21:17
electronic [1] <09:46> - 6:7
element [3] <09:44> - 4:19 <10:35>, 
40:24 <10:55>, 54:24
elements [4] <09:43> - 4:9 <09:45>, 5:14 
<09:53>, 10:22 <10:33>, 39:6
Eleventh [8] <09:51> - 9:13 <09:54>, 
11:9 <09:55>, 11:21 <09:55>, 11:22 <10:01>, 
16:5 <10:01>, 16:9 <10:03>, 17:19 <10:12>, 
23:20
email [1] <09:56> - 13:1
emails [1] <09:56> - 12:25
empanel [1] <09:43> - 4:12
emphasis [1] <11:13> - 67:25
emphatically [2] <10:31> - 38:5 
<10:34>, 40:3
employed [1] <10:50> - 51:4
77
employee [2] <10:09> - 22:3 <10:45>, 
47:21
employees [3] <09:48> - 7:2 <09:59>, 
14:14 <10:47>, 49:3
employer [1] <10:47> - 49:4
employers [2] <10:45> - 47:17 <10:49>, 
50:22
EMT [1] <10:49> - 50:21
encountered [1] <10:30> - 
37:22
end [9] <10:24> - 33:1 <10:24>, 33:2 <10:31>, 
37:25 <10:35>, 40:21 <10:39>, 43:20 <10:59>, 
57:23 <11:06>, 63:4 <11:08>, 64:7 <11:17>, 
70:25
ended [4] <09:46> - 6:5 <09:46>, 6:6 <10:24>, 
33:6 <11:07>, 63:13
ends [1] <10:12> - 24:10
engage [2] <09:52> - 9:21 <10:50>, 
51:14
engaged [5] <09:56> - 12:22 <10:08>, 
20:22 <10:30>, 37:14 <10:50>, 51:4 <10:57>, 
56:10
engaging [5] <09:54> - 11:8 <10:14>, 
25:10 <10:23>, 32:16 <10:23>, 32:18 <10:30>, 
37:18
engine [4] <10:30> - 37:13 <10:32>, 
38:15 <10:33>, 39:9 <11:07>, 63:15
enroll [7] <10:44> - 47:6 <10:45>, 47:24 <10:46>, 
48:24 <10:47>, 48:25 <10:51>, 52:1 <10:51>, 
52:4 <10:52>, 52:14
enrolled [8] <10:05> - 19:1 <10:45>, 48:3 
<10:45>, 48:6 <10:46>, 48:11 <10:46>, 48:18 <10:47>, 
49:1 <10:49>, 50:21
enrollment [1] <10:48> - 50:1
ensure [2] <10:47> - 49:5 <11:14>, 68:18
entangled [1] <10:25> - 33:23
enter [2] <10:53> - 53:1 <11:10>, 65:11
entering [1] <10:51> - 51:22
entertain [1] <10:18> - 29:1
entirely [1] <10:58> - 57:13
entitled [1] <10:35> - 41:1
entry [2] <10:19> - 29:5 <10:44>, 47:14
equipment [1] <10:22> - 31:19
error [1] <10:31> - 38:3
especially [2] <09:50> - 8:19 <10:52>, 
52:16
essential [2] <10:15> - 26:11 <10:33>, 
39:6
essentially [6] <10:10> - 22:22 <10:25>, 
33:21 <10:25>, 33:23 <10:33>, 39:11 <10:51>, 
51:24 <11:14>, 68:22
establish [4] <10:32> - 38:22 <10:44>, 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 77 of 88

47:9 <10:45>, 47:18 <10:54>, 54:13
establishing [1] <10:32> - 38:25
estimate [2] <10:10> - 22:11 <10:10>, 
22:15
et [1] <10:28> - 35:22
evaluate [3] <09:49> - 7:18 <09:51>, 9:3 
<10:33>, 39:9
event [3] <10:23> - 32:24 <10:24>, 33:1 <10:28>, 
36:1
events [7] <10:19> - 29:6 <10:25>, 34:5 <10:26>, 
34:12 <10:27>, 35:12 <10:28>, 36:3 <10:35>, 
40:17 <10:35>, 40:22
Evidence [1] <09:41> - 3:2
evidence [69] <09:41> - 3:1 <09:42>, 3:3 
<09:49>, 7:19 <09:49>, 7:22 <09:49>, 8:2 <10:00>, 15:8 
<10:01>, 16:7 <10:02>, 16:11 <10:04>, 18:7 <10:05>, 
18:25 <10:06>, 19:7 <10:06>, 19:14 <10:06>, 
19:18 <10:06>, 19:23 <10:14>, 25:13 <10:15>, 
26:9 <10:19>, 29:5 <10:19>, 29:18 <10:21>, 
30:15 <10:21>, 30:21 <10:21>, 30:23 <10:21>, 
31:9 <10:21>, 31:10 <10:22>, 32:4 <10:23>, 
32:12 <10:29>, 36:16 <10:29>, 36:18 <10:31>, 
38:4 <10:32>, 38:13 <10:33>, 39:5 <10:34>, 
39:25 <10:34>, 40:5 <10:34>, 40:7 <10:34>, 40:8 
<10:35>, 40:18 <10:35>, 40:19 <10:35>, 40:20 <10:36>, 
41:8 <10:37>, 42:11 <10:39>, 43:7 <10:40>, 44:7 
<10:41>, 45:3 <10:41>, 45:14 <10:42>, 45:18 <10:43>, 
46:15 <10:45>, 47:20 <10:47>, 49:16 <10:48>, 
50:2 <10:51>, 51:23 <10:52>, 52:8 <10:55>, 55:1 
<10:55>, 55:3 <10:56>, 55:22 <10:57>, 56:9 <11:00>, 
58:14 <11:00>, 58:15 <11:00>, 58:16 <11:00>, 
58:19 <11:01>, 59:15 <11:01>, 59:19 <11:02>, 
59:21 <11:02>, 60:7 <11:03>, 60:10 <11:03>, 
61:2 <11:08>, 63:23 <11:10>, 65:11 <11:10>, 
65:15 <11:11>, 66:15
evidentiary [1] <10:26> - 34:13
exact [1] <10:03> - 17:17
exactly [10] <09:59> - 14:17 <09:59>, 
14:20 <10:03>, 17:15 <10:27>, 35:8 <10:36>, 
41:12 <10:38>, 42:17 <10:39>, 43:21 <10:41>, 
45:9 <10:46>, 48:13 <11:17>, 70:22
examination [1] <10:32> - 38:20
example [7] <09:45> - 5:16 <09:54>, 
11:13 <10:03>, 17:23 <10:11>, 23:6 <10:13>, 
24:21 <10:16>, 26:23 <10:42>, 45:21
excelling [1] <09:48> - 7:15
exchange [1] <10:05> - 19:5
excluded [2] <10:29> - 36:16 <10:29>, 
36:22
exclusively [1] <10:33> - 39:13
excursions [1] <10:37> - 41:20
exercise [1] <09:53> - 10:20
exercising [1] <10:23> - 32:20
exhibit [2] <10:10> - 22:8 <11:06>, 62:20
exist [3] <10:58> - 57:1 <11:02>, 59:20 <11:03>, 
60:11
existed [1] <10:42> - 45:25
expect [1] <09:44> - 4:25
expedition [1] <10:22> - 31:24
expenses [3] <09:48> - 7:9 <09:59>, 
14:20 <10:04>, 18:10
experienced [1] <10:31> - 38:11
expired [1] <11:16> - 70:17
explain [2] <10:10> - 22:24 <11:01>, 
59:10
explaining [1] <11:17> - 70:22
explanation [1] <10:00> - 15:10
extent [1] <11:14> - 68:20
extra [2] <09:43> - 4:12 <09:47>, 7:1
extremely [1] <10:23> - 32:21
F
F.2d [2] <09:51> - 9:12 <09:52>, 9:20
Facebook [3] <10:23> - 32:17 <10:26>, 
34:19 <10:30>, 37:19
fact [40] <09:55> - 11:22 <09:58>, 14:12 <10:00>, 
15:12 <10:00>, 15:14 <10:04>, 18:4 <10:06>, 
19:16 <10:06>, 19:17 <10:11>, 23:16 <10:12>, 
24:1 <10:12>, 24:5 <10:12>, 24:8 <10:14>, 25:6 
<10:15>, 26:9 <10:18>, 28:23 <10:22>, 31:15 <10:22>, 
31:18 <10:22>, 32:3 <10:28>, 35:21 <10:34>, 
39:18 <10:37>, 42:6 <10:38>, 43:4 <10:42>, 
45:18 <10:42>, 45:20 <10:43>, 46:15 <10:43>, 
46:21 <10:43>, 46:22 <10:44>, 47:5 <10:46>, 
48:17 <10:47>, 49:15 <10:52>, 52:12 <10:54>, 
54:5 <10:55>, 55:5 <11:00>, 58:24 <11:03>, 
60:18 <11:03>, 60:19 <11:08>, 63:23 <11:09>, 
64:17 <11:09>, 64:20 <11:13>, 67:20
facts [8] <09:51> - 9:3 <09:52>, 9:22 <09:54>, 
11:19 <09:57>, 13:5 <10:00>, 15:19 <10:17>, 
27:20 <10:19>, 29:2 <10:25>, 34:1
factual [3] <10:07> - 20:6 <10:17>, 27:24 
<11:07>, 63:8
factually [6] <09:55> - 12:6 <10:05>, 
19:6 <10:18>, 29:1 <10:38>, 42:24 <10:38>, 43:2 
<10:48>, 50:2
failed [16] <10:33> - 39:8 <10:51>, 51:23 
<10:51>, 52:1 <10:51>, 52:3 <10:52>, 52:13 <10:53>, 
53:2 <11:02>, 59:22 <11:02>, 60:7 <11:04>, 
61:22 <11:05>, 62:10 <11:06>, 62:19 <11:11>, 
66:4 <11:11>, 66:12 <11:11>, 66:13 <11:12>, 
66:19 <11:13>, 67:18
failing [2] <09:47> - 7:1 <11:02>, 60:9
failure [2] <10:49> - 51:1 <11:03>, 60:21
failures [2] <10:32> - 38:17 <11:07>, 
63:8
fair [2] <09:50> - 8:7 <10:17>, 28:2
fairly [1] <11:15> - 69:21
fallen [1] <10:22> - 31:24
false [4] <09:46> - 5:22 <09:46>, 6:7 <10:12>, 
24:7
far [18] <09:43> - 4:8 <09:43>, 4:11 <09:44>, 4:16 
<09:44>, 4:24 <09:44>, 5:1 <09:47>, 6:12 <09:53>, 
10:23 <09:54>, 11:19 <09:55>, 11:20 <10:16>, 
27:5 <10:20>, 30:2 <10:20>, 30:8 <10:36>, 41:18 
<10:53>, 53:21 <10:56>, 55:23 <11:11>, 66:10 <11:15>, 
69:16 <11:17>, 70:24
fashion [2] <10:52> - 52:9 <10:53>, 
53:17
favor [5] <09:55> - 11:23 <09:55>, 11:24 
<10:12>, 23:21 <10:12>, 23:23 <10:59>, 58:2
February [4] <09:46> - 6:2 <09:46>, 6:8 
<09:58>, 14:6 <11:17>, 70:25
federal [5] <09:49> - 7:25 <09:53>, 10:17 
<09:55>, 11:23 <10:03>, 17:20 <10:17>, 27:23
Federal [1] <09:41> - 3:1
felon [3] <10:11> - 23:10 <10:11>, 23:12 <10:11>, 
23:17
felt [1] <10:23> - 32:9
female [1] <10:00> - 15:7
few [1] <10:45> - 48:8
Fifth [1] <10:37> - 42:5
fight [1] <10:34> - 39:22
file [4] <09:57> - 13:14 <10:21>, 31:4 <11:16>, 
70:21 <11:17>, 70:22
filed [6] <09:41> - 2:20 <09:42>, 3:5 <09:56>, 
13:3 <10:08>, 21:9 <10:10>, 22:14 <10:26>, 
34:16
files [1] <09:57> - 13:8
filing [1] <11:16> - 70:14
fill [1] <09:56> - 12:24
fills [1] <09:56> - 12:25
final [6] <09:41> - 3:2 <10:10>, 22:24 <10:30>, 
37:21 <10:53>, 53:11 <11:04>, 61:15 <11:13>, 
68:2
financial [3] <09:43> - 4:3 <09:49>, 8:3 <10:18>, 
28:16
fine [2] <09:50> - 8:17 <10:28>, 36:13
finish [1] <10:10> - 22:15
firefighter [1] <10:49> - 50:21
first [23] <09:42> - 3:8 <09:51>, 9:8 <09:56>, 
12:22 <09:56>, 13:3 <09:57>, 13:8 <09:58>, 14:3 
<09:58>, 14:5 <09:58>, 14:7 <10:02>, 16:13 <10:03>, 
17:14 <10:20>, 30:9 <10:21>, 30:24 <10:21>, 
31:8 <10:24>, 32:25 <10:26>, 34:15 <10:30>, 
37:6 <10:48>, 50:7 <10:49>, 50:19 <10:56>, 
55:15 <11:06>, 62:16 <11:06>, 62:21
fishing [4] <10:22> - 31:23 <10:22>, 
78
31:24 <11:07>, 63:12 <11:07>, 63:20
five [3] <09:42> - 3:12 <10:18>, 28:9
five-count [1] <09:42> - 3:12
flight [2] <10:09> - 21:13 <11:14>, 69:2
floating [1] <10:58> - 57:15
Florida [2] <10:04> - 18:5 <11:13>, 68:8
fly [1] <11:14> - 69:2
flybridge [2] <11:09> - 64:13 <11:09>, 
64:16
flying [2] <10:09> - 21:15 <10:09>, 21:18
followed [1] <10:00> - 15:19
following [5] <09:49> - 8:3 <09:57>, 
13:11 <09:58>, 14:5 <10:32>, 38:17
footnote [2] <10:11> - 23:4 <10:11>, 
23:5
forgiven [2] <09:57> - 13:14 <10:08>, 
21:7
forgiveness [5] <09:57> - 13:11 
<09:57>, 13:17 <09:58>, 13:24 <09:58>, 14:7 <09:58>, 
14:8
form [1] <10:14> - 25:3
formed [2] <09:47> - 6:17 <10:17>, 27:17
forward [1] <09:46> - 5:21
four [1] <10:20> - 30:9
framework [1] <10:22> - 32:3
framing [1] <10:22> - 31:15
FRANCIS [30] <10:28> - 36:9 <10:29>, 
36:14 <10:30>, 37:9 <10:30>, 37:12 <10:33>, 
39:7 <10:35>, 40:14 <10:36>, 41:6 <10:40>, 44:4 
<10:40>, 44:12 <10:40>, 44:21 <10:41>, 45:2 <10:49>, 
50:18 <10:51>, 52:3 <10:52>, 52:11 <10:58>, 
56:23 <10:58>, 57:7 <10:58>, 57:10 <11:01>, 
59:18 <11:03>, 60:16 <11:03>, 60:19 <11:03>, 
61:2 <11:04>, 61:6 <11:10>, 65:7, 65:19 
<11:10>, 65:22 <11:11>, 66:2 <11:12>, 67:6 <11:16>, 
70:12 <11:16>, 70:18 <11:17>, 71:2
Francis [2] <09:41> - 2:12 <11:16>, 
70:11
fraud [28] <09:42> - 3:24 <09:43>, 4:7 <09:45>, 
5:10 <09:45>, 5:12 <09:45>, 5:18 <09:47>, 6:17 
<09:49>, 7:23 <09:50>, 8:11 <09:53>, 10:17 <09:54>, 
11:16 <09:57>, 13:19 <10:02>, 16:18 <10:02>, 
16:21 <10:02>, 16:24 <10:02>, 17:6 <10:03>, 
18:1 <10:04>, 18:4 <10:13>, 24:14 <10:13>, 
24:15 <10:13>, 24:20 <10:15>, 25:25 <10:15>, 
26:5 <10:16>, 26:25 <10:17>, 27:14 <10:18>, 
28:13 <10:53>, 53:15 <11:00>, 58:19
fraudulent [2] <09:54> - 11:11 <10:15>, 
26:12
free [1] <10:39> - 43:21
front [2] <10:05> - 18:24 <10:25>, 33:24
full [1] <10:26> - 34:10
fully [2] <09:41> - 2:24 <09:42>, 3:5
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 78 of 88

functioning [1] <11:08> - 63:24
furthermore [1] <09:43> - 4:8
future [1] <10:17> - 27:14
G
gaps [1] <10:46> - 48:14
general [7] <09:43> - 4:6 <09:55>, 12:2 <10:00>, 
15:18 <10:10>, 22:19 <10:10>, 22:21 <10:13>, 
24:13 <10:40>, 44:10
generally [2] <11:15> - 69:20 <11:16>, 
70:2
generate [1] <10:13> - 24:22
given [6] <09:49> - 7:25 <10:08>, 21:3 <10:35>, 
40:18 <10:41>, 45:14 <10:43>, 46:11 <11:13>, 
67:25
glance [1] <09:51> - 9:8
goodman [1] <11:06> - 62:17
govern [1] <10:37> - 41:25
government [51] <09:41> - 2:25 
<09:42>, 3:5 <09:43>, 4:10 <09:44>, 4:15 <09:44>, 4:25 
<09:47>, 6:15 <09:48>, 7:4 <09:49>, 7:19 <09:49>, 7:22 
<09:49>, 8:2 <09:51>, 9:6 <09:53>, 10:13 <09:53>, 
10:16 <10:01>, 15:20 <10:02>, 17:1 <10:03>, 
17:7 <10:17>, 27:24 <10:18>, 28:6 <10:19>, 29:3 
<10:29>, 36:19 <10:29>, 36:24 <10:30>, 37:16 <10:30>, 
37:22 <10:31>, 38:3 <10:32>, 38:21 <10:33>, 
39:8 <10:33>, 39:13 <10:34>, 39:23 <10:34>, 
39:25 <10:34>, 40:7 <10:34>, 40:9 <10:35>, 
40:21 <10:36>, 41:8 <10:36>, 41:11 <10:38>, 
42:24 <10:43>, 46:9 <10:47>, 49:12 <10:51>, 
51:24 <10:52>, 52:17 <10:53>, 53:12 <10:59>, 
57:24 <10:59>, 58:3 <11:03>, 60:23 <11:03>, 
61:3 <11:09>, 64:12 <11:10>, 65:10 <11:10>, 
65:15 <11:11>, 66:6 <11:11>, 66:10 <11:12>, 
67:7 <11:13>, 67:25
government's [14] <09:44> - 
4:20 <09:46>, 6:4 <09:50>, 8:16 <10:15>, 26:14 
<10:17>, 27:21 <10:18>, 28:15 <10:31>, 38:8 <10:35>, 
40:25 <10:43>, 46:12 <10:52>, 52:24 <10:53>, 
53:5 <10:59>, 57:20 <11:07>, 63:8 <11:16>, 70:1
grant [1] <10:35> - 40:25
granted [1] <10:59> - 58:2
great [2] <10:07> - 20:7 <10:11>, 23:6
grounded [1] <10:31> - 37:25
grounding [8] <10:57> - 56:16 <10:57>, 
56:18 <10:58>, 57:5 <10:58>, 57:7 <10:58>, 57:9 
<10:58>, 57:11 <10:58>, 57:12 <10:59>, 57:20
group [3] <10:24> - 33:16 <11:15>, 69:5 <11:15>, 
69:10
Guard [15] <09:59> - 14:14 <10:05>, 19:3 
<10:08>, 20:18 <10:15>, 26:7 <10:43>, 46:17 <10:45>, 
48:5 <10:48>, 49:22 <10:48>, 49:25 <10:48>, 
50:4 <10:49>, 50:14 <10:56>, 55:20 <10:56>, 
55:25 <10:58>, 57:4 <11:01>, 59:12
guess [4] <10:10> - 22:24 <11:08>, 64:9 
<11:15>, 69:6 <11:15>, 69:17
guidance [1] <11:02> - 60:1
gun [8] <09:52> - 9:25 <09:52>, 10:9 <10:11>, 
23:10 <10:11>, 23:11 <10:23>, 32:10 <10:25>, 
33:20 <10:26>, 34:18
guns [2] <09:52> - 10:5 <09:53>, 10:14
gut [1] <10:00> - 15:18
H
half [2] <10:09> - 21:18 <11:01>, 59:11
hand [7] <09:52> - 10:6 <09:54>, 11:10 <10:04>, 
18:7 <10:04>, 18:11 <10:07>, 20:12 <10:14>, 
25:2
handwritten [1] <09:57> - 13:10
harbor [2] <10:26> - 34:22 <10:26>, 
34:23
hard [1] <10:33> - 39:5
harm [1] <10:58> - 56:24
harping [1] <10:29> - 37:1
heading [1] <10:24> - 33:8
hear [11] <09:42> - 3:7 <09:49>, 8:1 <09:50>, 
8:18 <10:16>, 26:16 <10:19>, 29:3 <10:28>, 36:6 
<10:36>, 41:7 <10:49>, 50:16 <11:01>, 59:16 <11:04>, 
61:15 <11:13>, 67:16
heard [1] <09:47> - 6:14
hearing [5] <09:41> - 2:19 <10:00>, 
15:19 <10:19>, 29:12 <10:55>, 55:9 <11:17>, 
71:3
heart [3] <10:25> - 33:25 <10:25>, 34:3 <10:35>, 
40:24
Heather [1] <10:45> - 47:21
heavily [4] <09:53> - 10:16 <10:10>, 
22:19 <10:12>, 23:21 <10:12>, 23:23
heavy [1] <10:22> - 31:19
heel [1] <10:28> - 36:11
held [1] <10:25> - 33:24
help [1] <10:18> - 29:1
helpful [1] <11:16> - 70:5
herself [2] <10:08> - 21:2 <10:23>, 32:9
Hester [14] <10:08> - 20:21 <10:22>, 32:7 
<10:25>, 33:19 <10:26>, 34:17 <10:30>, 37:8 <10:30>, 
37:10 <10:30>, 37:14 <10:30>, 37:17 <10:33>, 
39:14 <10:56>, 55:17 <11:14>, 68:25 <11:15>, 
69:13
Hester's [1] <10:27> - 35:5
high [2] <10:23> - 32:20 <11:07>, 63:17
higher [1] <09:57> - 13:9
highlight [2] <09:58> - 14:10 <11:09>, 
64:20
highlighting [2] <09:54> - 11:5 
<10:57>, 56:16
highly [1] <11:03> - 60:17
himself [3] <10:13> - 24:23 <10:49>, 
50:13 <11:11>, 66:14
hired [1] <11:02> - 60:1
history [1] <09:47> - 6:21
holistically [1] <11:13> - 67:13
Holloway [1] <10:11> - 23:5
Honor [39] <09:41> - 2:8 <09:41>, 2:11 <09:42>, 
3:10 <09:42>, 3:20 <09:50>, 8:8 <09:52>, 9:23 <09:53>, 
10:25 <09:54>, 11:3 <09:57>, 13:12 <09:59>, 
15:3 <10:28>, 36:9 <10:28>, 36:10 <10:29>, 37:1 
<10:30>, 37:21 <10:33>, 39:7 <10:34>, 39:20 <10:34>, 
39:24 <10:36>, 41:5 <10:40>, 44:5 <10:41>, 45:3 
<10:46>, 48:23 <10:47>, 49:10 <10:49>, 50:18 <10:50>, 
51:7 <10:51>, 51:16 <10:51>, 51:24 <10:52>, 
52:11 <10:52>, 52:17 <10:52>, 52:19 <10:55>, 
55:10 <10:58>, 57:7 <10:59>, 58:5 <11:08>, 64:6 
<11:10>, 65:13 <11:13>, 68:5 <11:13>, 68:11 <11:16>, 
70:9 <11:16>, 70:13 <11:16>, 70:18
hotel [1] <10:09> - 21:13
hour [3] <11:15> - 69:14 <11:16>, 70:1 <11:16>, 
70:2
hours [1] <10:25> - 34:2
housing [1] <09:53> - 10:17
huge [1] <10:07> - 20:6
husband [1] <10:25> - 33:24
I
identifies [1] <10:32> - 38:16
identify [1] <10:36> - 41:11
identities [1] <10:13> - 24:25
identity [2] <10:13> - 24:21 <10:15>, 
25:25
imagine [2] <09:46> - 6:4 <10:03>, 17:24
immediate [2] <10:05> - 19:2 <10:06>, 
19:15
impetus [2] <09:47> - 6:17 <10:14>, 25:3
important [8] <09:59> - 14:23 <10:05>, 
18:24 <10:06>, 19:14 <10:07>, 20:10 <10:07>, 
20:11 <10:18>, 28:20 <10:22>, 31:20 <11:07>, 
63:15
importantly [5] <09:47> - 6:12 <09:50>, 
8:13 <09:53>, 10:24 <11:00>, 58:18 <11:00>, 
58:19
impossible [1] <10:34> - 39:21
improper [2] <09:53> - 10:15 <11:13>, 
67:16
inattention [2] <10:32> - 38:23 <10:42>, 
46:5
79
incident [13] <09:49> - 8:3 <10:26>, 
34:18 <10:30>, 37:6 <10:30>, 37:15 <10:32>, 
38:18 <10:33>, 39:10 <10:37>, 42:12 <10:48>, 
49:25 <10:50>, 51:6 <10:50>, 51:13 <10:51>, 
51:16 <11:10>, 65:14 <11:13>, 68:9
incidents [6] <09:43> - 4:8 <10:27>, 
35:6 <10:29>, 37:2 <10:29>, 37:3 <10:34>, 40:1 
<10:34>, 40:8
include [1] <09:58> - 14:11
included [1] <11:12> - 67:1
indicate [1] <10:55> - 55:1
indicated [1] <10:10> - 22:11
indicates [2] <09:49> - 8:2 <10:48>, 50:2
indicted [1] <10:10> - 22:20
indictment [5] <09:42> - 3:12 <09:42>, 
3:13 <09:45>, 5:16 <09:49>, 7:18 <10:18>, 28:10
individual [1] <10:50> - 51:4
individuals [1] <11:02> - 60:1
inefficiencies [1] <10:07> - 
20:4
inextricably [7] <10:12> - 23:24 
<10:13>, 24:11 <10:19>, 29:15 <10:20>, 30:11 <10:25>, 
34:6 <10:28>, 35:18 <10:59>, 57:25
infer [1] <10:53> - 53:2
inference [1] <10:53> - 52:25
inflame [1] <09:50> - 8:20
inflammatory [1] <09:50> - 8:19
influence [3] <10:46> - 48:16 <10:47>, 
49:12 <10:55>, 55:2
information [1] <10:46> - 48:15
informs [3] <10:12> - 24:4 <10:22>, 32:3 
<10:55>, 54:22
infusion [1] <09:49> - 8:4
inherently [3] <10:04> - 18:4 <10:14>, 
25:8 <10:22>, 31:16
initial [2] <09:57> - 13:16 <10:26>, 34:18
initials [1] <09:44> - 4:21
injured [1] <10:56> - 55:17
injury [3] <10:08> - 20:22 <10:23>, 32:12
innocent [1] <10:01> - 15:23
inside [1] <10:23> - 32:13
insist [1] <10:30> - 37:14
inspect [4] <10:33> - 39:8 <10:33>, 
39:14 <10:34>, 39:21 <10:34>, 40:10
inspected [2] <10:35> - 40:15 <11:06>, 
62:22
inspection [10] <11:04> - 61:20 
<11:04>, 61:22 <11:05>, 62:10 <11:06>, 62:19 <11:06>, 
62:22 <11:09>, 65:2 <11:11>, 66:4 <11:11>, 
66:16 <11:12>, 66:20 <11:13>, 67:19
inspections [7] <11:05> - 61:25 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 79 of 88

<11:06>, 63:1 <11:10>, 65:13 <11:11>, 66:3 <11:11>, 
66:12 <11:12>, 67:8
instance [2] <10:50> - 51:9 <10:55>, 
54:16
instant [2] <10:19> - 29:7 <10:30>, 37:21
instead [7] <10:23> - 32:23 <10:24>, 
33:9 <10:24>, 33:15 <10:25>, 33:22 <10:41>, 
45:14 <11:09>, 64:22 <11:09>, 64:24
instinct [1] <10:00> - 15:18
instructed [3] <10:23> - 32:9 <10:48>, 
49:23 <10:50>, 51:10
instruction [3] <10:54> - 54:11 <11:02>, 
60:1 <11:13>, 67:25
instructions [5] <10:01> - 16:6 
<10:01>, 16:10 <10:02>, 16:13 <10:03>, 17:18
instructor [1] <11:02> - 59:25
insurance [1] <10:16> - 26:25
intend [2] <10:12> - 24:5 <10:26>, 34:11
intended [2] <10:57> - 56:18 <10:58>, 
57:8
intent [4] <09:43> - 4:6 <09:43>, 4:7 <10:17>, 
27:17 <10:53>, 53:15
interpret [1] <09:50> - 8:14
interpretations [1] <09:43> - 
4:11
interrupt [1] <10:52> - 52:21
intertwined [8] <09:53> - 10:19 
<10:12>, 23:24 <10:13>, 24:11 <10:19>, 29:15 <10:20>, 
30:11 <10:25>, 34:6 <10:28>, 35:18 <10:59>, 
57:25
intervention [1] <10:56> - 56:3
interviews [1] <10:08> - 20:25
introduce [4] <09:41> - 3:1 <10:26>, 
34:12 <11:06>, 62:24 <11:10>, 65:15
introducing [3] <10:53> - 53:19 
<11:07>, 63:22 <11:12>, 67:8
intuitive [2] <10:03> - 17:9 <10:03>, 
17:14
investigation [1] <10:32> - 
38:14
involve [2] <11:08> - 64:2 <11:08>, 64:3
involved [6] <09:45> - 5:13 <10:47>, 
49:6 <10:50>, 51:5 <10:50>, 51:12 <10:58>, 57:2 
<11:05>, 62:1
involves [2] <10:04> - 18:4 <10:22>, 
31:16
involving [1] <10:58> - 56:24
irrelevant [10] <09:42> - 3:3 <10:29>, 
36:16 <10:40>, 44:5 <10:40>, 44:17 <10:49>, 
50:24 <10:51>, 51:18 <10:51>, 51:21 <10:51>, 
51:23 <10:52>, 52:8 <10:52>, 52:11
issue [47] <09:42> - 3:4 <09:47>, 6:19 <09:54>, 
11:17 <10:02>, 16:12 <10:08>, 21:5 <10:10>, 
22:14 <10:15>, 25:24 <10:15>, 26:1 <10:16>, 
27:9 <10:19>, 29:8 <10:20>, 29:23 <10:21>, 
30:20 <10:29>, 36:20 <10:31>, 37:23 <10:33>, 
39:7 <10:33>, 39:11 <10:33>, 39:16 <10:33>, 
39:17 <10:34>, 39:18 <10:34>, 39:19 <10:34>, 
39:22 <10:34>, 40:2 <10:34>, 40:3 <10:34>, 40:4 
<10:34>, 40:6 <10:35>, 40:11 <10:40>, 44:8 <10:49>, 
50:17 <10:52>, 52:12 <10:52>, 52:15 <10:53>, 
53:18 <10:53>, 53:21 <10:55>, 55:6 <10:56>, 
55:17 <10:59>, 57:18 <11:04>, 61:13 <11:04>, 
61:16 <11:09>, 64:20 <11:10>, 65:10 <11:10>, 
65:11 <11:10>, 65:24 <11:11>, 66:4 <11:11>, 
66:7 <11:11>, 66:9 <11:11>, 66:10 <11:12>, 
66:18
issued [3] <11:00> - 58:10 <11:01>, 59:5 
<11:03>, 60:15
issues [12] <10:09> - 21:25 <10:21>, 
31:12 <10:29>, 36:25 <10:31>, 38:12 <10:54>, 
53:25 <10:56>, 55:16 <10:56>, 55:19 <10:58>, 
57:1 <11:11>, 66:3 <11:11>, 66:4 <11:11>, 66:5 
<11:12>, 67:3
Item [11] <10:19> - 29:4 <10:43>, 46:12 <10:43>, 
46:15 <10:55>, 55:12 <10:56>, 55:14 <10:59>, 
58:4 <10:59>, 58:6 <11:04>, 61:16 <11:04>, 
61:18 <11:13>, 68:6
item [1] <11:13> - 68:2
itself [5] <09:46> - 6:6 <10:17>, 27:19 <10:20>, 
30:12 <10:38>, 43:6 <11:02>, 60:5
J
jargon [2] <10:27> - 34:25 <11:01>, 
59:12
Jen [3] <10:33> - 39:14
Jennifer [5] <10:08> - 20:21 <10:22>, 
32:7 <10:25>, 33:19 <10:30>, 37:10 <10:30>, 
37:14
JH [3] <10:30> - 37:6 <10:30>, 37:9 <10:30>, 
37:13
job [1] <09:50> - 8:16
joinder [1] <09:52> - 10:7
JS [1] <10:09> - 22:2
Judge [64] <09:42> - 3:12 <09:47>, 6:19 <09:51>, 
9:10 <09:55>, 12:9 <10:01>, 15:25 <10:05>, 
18:23 <10:09>, 22:6 <10:11>, 23:1 <10:15>, 
25:23 <10:15>, 26:15 <10:16>, 26:19 <10:19>, 
29:10 <10:21>, 31:3 <10:21>, 31:14 <10:27>, 
35:14 <10:29>, 36:14 <10:29>, 36:15 <10:29>, 
36:23 <10:29>, 37:2 <10:30>, 37:6 <10:30>, 
37:10 <10:30>, 37:15 <10:31>, 38:3 <10:31>, 
38:8 <10:32>, 38:13 <10:33>, 39:17 <10:35>, 
40:12 <10:36>, 41:6 <10:36>, 41:13 <10:37>, 
41:22 <10:39>, 43:12 <10:40>, 44:4 <10:40>, 
44:7 <10:40>, 44:12 <10:40>, 44:14 <10:40>, 
44:17 <10:40>, 44:21 <10:43>, 46:14 <10:44>, 
47:11 <10:50>, 51:4 <10:50>, 51:9 <10:50>, 
51:14 <10:51>, 52:3 <10:53>, 53:16 <10:55>, 
55:13 <10:57>, 56:14 <10:58>, 56:23 <10:58>, 
57:10 <11:01>, 59:18 <11:02>, 59:24 <11:03>, 
60:16 <11:03>, 61:4 <11:04>, 61:18 <11:05>, 
62:12 <11:09>, 64:19 <11:10>, 65:7 <11:11>, 
66:2 <11:12>, 66:21 <11:12>, 66:25 <11:12>, 
67:12 <11:13>, 67:21 <11:14>, 68:24 <11:16>, 
70:12 <11:17>, 71:2
judge [1] <10:20> - 29:22
judicial [2] <09:43> - 4:12 <09:44>, 4:24
July [1] <11:07> - 63:6
juncture [1] <11:16> - 70:20
juries [1] <09:51> - 9:3
jurors [2] <09:43> - 4:12 <09:50>, 8:20
jury [19] <09:50> - 8:13 <09:50>, 8:15 <09:50>, 
8:18 <09:50>, 8:21 <09:50>, 8:25 <09:53>, 10:24 
<09:55>, 12:7 <10:00>, 15:19 <10:01>, 16:5 <10:02>, 
17:5 <10:17>, 28:4 <10:25>, 34:7 <10:31>, 38:8 
<10:53>, 53:2 <10:53>, 53:5 <10:54>, 54:12 <11:01>, 
59:12 <11:02>, 59:21 <11:03>, 60:10
K
keep [9] <09:49> - 8:5 <10:10>, 22:19 <10:13>, 
24:15 <10:13>, 24:23 <10:14>, 25:20 <10:16>, 
26:19 <10:27>, 35:1 <11:05>, 62:4
keeping [1] <09:55> - 11:24
KELLER [73] <09:41> - 2:8 <09:54>, 11:3 
<09:54>, 11:5 <09:55>, 12:9 <09:58>, 14:1 <09:58>, 
14:3 <09:58>, 14:10 <10:00>, 15:8 <10:01>, 
15:25 <10:02>, 16:20 <10:03>, 17:9 <10:03>, 
17:13 <10:05>, 18:23 <10:06>, 19:10 <10:07>, 
20:8 <10:09>, 21:17 <10:09>, 22:2 <10:09>, 22:6 
<10:10>, 22:12 <10:11>, 23:1 <10:13>, 24:18 <10:14>, 
25:13 <10:15>, 25:23 <10:15>, 26:15 <10:19>, 
29:10 <10:19>, 29:17 <10:19>, 29:21 <10:20>, 
30:14 <10:21>, 30:25 <10:21>, 31:3 <10:21>, 
31:7 <10:26>, 34:14 <10:27>, 35:14 <10:28>, 
35:19 <10:36>, 41:5 <10:36>, 41:13 <10:37>, 
41:22 <10:38>, 42:18 <10:38>, 43:4 <10:39>, 
43:12 <10:41>, 45:9 <10:43>, 46:14 <10:44>, 
47:11 <10:44>, 47:14 <10:45>, 47:17 <10:47>, 
49:14 <10:47>, 49:19 <10:48>, 50:3 <10:53>, 
53:16 <10:53>, 53:24 <10:55>, 54:15 <10:55>, 
55:3 <10:55>, 55:5 <10:55>, 55:13 <10:57>, 
56:14 <10:57>, 56:18 <10:59>, 58:5 <11:04>, 
61:18 <11:05>, 62:12 <11:06>, 62:15 <11:06>, 
62:21 <11:06>, 63:1 <11:07>, 63:10 <11:09>, 
64:15 <11:12>, 67:9 <11:12>, 67:12 <11:13>, 
67:14 <11:13>, 67:21 <11:13>, 68:5 <11:14>, 
68:24 <11:15>, 69:10 <11:15>, 69:14 <11:16>, 
70:9
Keller [8] <09:41> - 2:8 <09:54>, 11:3 <10:41>, 
45:7 <10:43>, 46:13 <11:04>, 61:17 <11:13>, 
68:4 <11:14>, 68:18 <11:16>, 70:8
kept [3] <10:23> - 32:23 <10:24>, 33:7 <10:26>, 
34:8
80
key [4] <09:54> - 11:15 <10:14>, 25:6 <10:22>, 
31:15 <10:33>, 39:7
keyword [1] <10:50> - 51:7
killed [3] <09:54> - 11:14 <10:25>, 33:18 
<10:38>, 43:6
killing [17] <09:58> - 14:13 <10:04>, 
18:12 <10:04>, 18:13 <10:06>, 19:15 <10:08>, 
20:19 <10:13>, 24:16 <10:13>, 25:1 <10:14>, 
25:19 <10:15>, 26:8 <10:15>, 26:14 <10:17>, 
27:22 <10:25>, 33:17 <10:27>, 35:11 <10:39>, 
44:1 <10:45>, 48:4 <10:46>, 48:17 <11:04>, 
61:21
kind [28] <09:44> - 4:22 <09:48>, 7:3 <09:48>, 
7:16 <09:52>, 10:6 <09:53>, 10:14 <10:00>, 
15:15 <10:02>, 16:16 <10:06>, 19:14 <10:07>, 
20:9 <10:08>, 21:10 <10:09>, 21:12 <10:09>, 
21:13 <10:09>, 21:19 <10:09>, 21:24 <10:09>, 
22:7 <10:10>, 22:8 <10:13>, 24:12 <10:20>, 30:1 
<10:40>, 44:10 <10:52>, 52:24 <10:56>, 55:14 <10:58>, 
57:3 <11:01>, 59:14 <11:05>, 62:7 <11:07>, 
63:17 <11:09>, 64:18 <11:10>, 65:4 <11:15>, 
69:22
knowing [2] <09:45> - 5:9 <10:28>, 36:3
knowledge [6] <10:28> - 35:20 <11:09>, 
64:21 <11:10>, 65:16 <11:11>, 65:25 <11:11>, 
66:16 <11:12>, 66:22
known [1] <10:25> - 34:4
L
lack [1] <11:11> - 66:1
lady [2] <09:42> - 3:23 <09:50>, 8:25
language [1] <10:16> - 26:20
large [2] <10:23> - 32:13 <11:15>, 69:10
last [1] <10:10> - 22:17
late [1] <11:16> - 70:19
latitude [1] <10:17> - 28:3
law [9] <09:42> - 3:24 <09:51>, 9:18 <09:53>, 
10:13 <10:16>, 27:11 <10:17>, 27:16 <10:38>, 
42:19 <10:38>, 42:21 <10:39>, 43:16 <10:54>, 
54:7
lawyers [1] <11:01> - 59:13
lead [1] <11:06> - 62:16
lean [2] <10:12> - 23:21 <10:12>, 23:23
leaning [1] <10:10> - 22:19
learned [1] <10:08> - 21:9
least [3] <10:08> - 20:25 <10:56>, 56:2 <11:00>, 
58:19
leave [1] <11:17> - 70:22
led [4] <10:33> - 39:10 <10:56>, 55:16 <10:57>, 
56:10 <11:09>, 64:12
leg [1] <10:23> - 32:12
legitimate [2] <09:59> - 14:19 <10:04>, 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 80 of 88

18:6
legitimately [1] <10:14> - 25:10
legs [1] <10:25> - 33:23
length [1] <11:14> - 68:20
less [1] <11:03> - 61:2
liability [1] <10:54> - 54:14
license [2] <10:21> - 30:16 <10:42>, 
45:16
lied [2] <11:03> - 60:23 <11:04>, 61:9
life [1] <10:32> - 38:24
lift [1] <11:15> - 69:6
light [1] <11:14> - 68:14
likely [3] <10:02> - 17:2 <10:56>, 56:2 <10:56>, 
56:4
limine [12] <09:41> - 2:25 <10:06>, 19:12 
<10:16>, 26:18 <10:19>, 29:2 <10:19>, 29:4 <10:35>, 
40:25 <10:36>, 41:14 <10:54>, 54:8 <11:04>, 
61:16 <11:05>, 62:13 <11:08>, 64:8 <11:13>, 
68:3
limited [1] <10:53> - 53:17
limiting [2] <10:54> - 54:11 <11:13>, 
67:24
links [1] <10:33> - 39:10
list [1] <10:10> - 22:8
listed [2] <09:44> - 4:17 <10:57>, 56:12
lives [1] <10:08> - 21:9
loan [27] <09:42> - 3:24 <09:43>, 4:6 <09:44>, 
4:23 <09:46>, 5:22 <09:46>, 6:2 <09:46>, 6:8 <09:47>, 
6:20 <09:47>, 6:22 <09:48>, 7:5 <09:48>, 7:8 <09:48>, 
7:12 <09:48>, 7:14 <09:56>, 12:23 <09:56>, 13:3 
<09:57>, 13:8 <09:57>, 13:11 <09:57>, 13:13 <09:57>, 
13:16 <09:57>, 13:17 <09:58>, 13:20 <09:58>, 
13:24 <09:58>, 14:4 <09:58>, 14:5 <09:58>, 14:7 
<09:58>, 14:8 <10:08>, 21:3 <10:15>, 26:3
loans [14] <09:47> - 6:25 <09:56>, 12:17 
<09:57>, 13:12 <10:07>, 20:1 <10:08>, 20:24 <10:08>, 
21:6 <10:12>, 24:9 <10:14>, 25:7 <10:14>, 25:8 
<10:14>, 25:12 <10:14>, 25:15 <10:15>, 26:12 <10:16>, 
26:25
local [3] <10:36> - 41:9 <10:36>, 41:12 <10:36>, 
41:13
locations [1] <11:09> - 64:19
look [7] <09:50> - 8:9 <09:50>, 8:10 <09:50>, 
8:15 <09:50>, 8:17 <10:16>, 27:11 <10:37>, 
41:23 <10:38>, 42:18
looked [1] <10:08> - 21:1
looking [3] <09:42> - 3:12 <09:42>, 3:13 
<09:44>, 4:25
loss [1] <10:57> - 56:19
lost [2] <10:30> - 37:16 <10:32>, 38:24
M
ma'am [3] <09:41> - 2:23 <09:42>, 3:16 <09:45>, 
5:7
mail [1] <09:54> - 11:15
main [2] <09:50> - 8:24 <10:57>, 56:19
maintained [1] <11:05> - 62:5
maintaining [2] <09:48> - 7:15 <10:59>, 
58:9
malfunctioning [2] <10:24> - 
33:5 <10:24>, 33:12
malfunctions [1] <10:22> - 
31:25
manage [3] <10:08> - 21:3 <10:27>, 35:8 
<10:31>, 37:24
manipulated [1] <11:07> - 
63:21
manslaughter [19] <10:02> - 
16:17 <10:02>, 16:21 <10:02>, 16:25 <10:02>, 
17:5 <10:03>, 17:8 <10:12>, 24:8 <10:13>, 24:14 
<10:14>, 25:11 <10:14>, 25:13 <10:15>, 26:6 <10:18>, 
28:11 <10:20>, 29:25 <10:20>, 30:2 <10:20>, 
30:8 <10:21>, 31:10 <10:35>, 40:23 <10:53>, 
53:15 <10:54>, 54:9 <10:59>, 57:21
mapped [2] <10:09> - 21:14 <10:10>, 
22:12
March [34] <09:45> - 5:5 <09:45>, 5:8 <09:45>, 
5:17 <09:45>, 5:18 <09:46>, 5:21 <09:56>, 12:18 
<09:56>, 12:20 <09:56>, 13:2 <09:58>, 14:13 <10:00>, 
15:19 <10:10>, 22:16 <10:18>, 28:8 <10:19>, 
29:6 <10:20>, 30:6 <10:24>, 32:25 <10:25>, 34:3 
<10:25>, 34:5 <10:27>, 35:12 <10:31>, 38:6 <10:32>, 
38:18 <10:33>, 39:10 <10:41>, 45:6 <10:51>, 
52:2 <10:52>, 52:13 <10:56>, 55:15 <10:58>, 
57:2 <11:00>, 58:18 <11:04>, 61:21 <11:05>, 
62:1 <11:07>, 63:9 <11:10>, 65:14 <11:13>, 68:8
marina [4] <09:56> - 12:22 <10:09>, 22:3 
<10:23>, 32:24 <10:48>, 50:9
marinas [1] <10:59> - 58:9
marine [7] <10:45> - 47:17 <10:47>, 49:2 
<10:47>, 49:4 <10:50>, 51:6 <10:50>, 51:12 <10:58>, 
57:3 <10:58>, 57:14
Marine [1] <10:57> - 56:15
Maritime [1] <10:45> - 47:22
maritime [2] <10:46> - 48:24 <11:12>, 
66:17
materialize [1] <10:17> - 27:20
mates [1] <10:05> - 19:4
matter [2] <09:49> - 7:24 <10:54>, 54:2
matters [1] <11:13> - 67:13
McCabe [23] <09:41> - 2:5 <09:41>, 2:13 
<09:41>, 2:16 <09:47>, 6:22 <09:48>, 7:7 <09:50>, 8:21 
<09:58>, 14:13 <10:01>, 15:22 <10:05>, 19:1 <10:08>, 
20:23 <10:16>, 26:24 <10:27>, 35:7 <10:47>, 
49:5 <10:47>, 49:12 <10:47>, 49:16 <10:48>, 
50:1 <10:48>, 50:4 <10:48>, 50:6 <10:49>, 50:23 
<10:50>, 51:8 <10:53>, 52:25 <10:56>, 55:18 <10:56>, 
56:4
McCabe's [1] <10:48> - 49:22
MCGF [3] <09:56> - 12:20 <10:25>, 33:17 
<10:32>, 38:24
MCGF's [3] <09:59> - 14:24 <10:19>, 
29:9 <10:36>, 41:10
mean [11] <09:55> - 12:2 <09:57>, 13:4 <10:02>, 
16:16 <10:13>, 24:13 <10:30>, 37:8 <10:36>, 
41:18 <10:38>, 42:25 <10:41>, 44:25 <10:52>, 
52:21 <10:56>, 55:16
means [4] <09:59> - 15:5 <10:39>, 43:19 
<10:48>, 50:9 <10:48>, 50:11
meant [1] <10:42> - 46:7
mechanical [8] <10:21> - 31:12 
<10:29>, 36:25 <10:31>, 38:1 <10:32>, 38:14 <10:32>, 
38:17 <10:56>, 55:16 <11:10>, 65:10 <11:10>, 
65:24
meet [1] <09:48> - 7:8
members [10] <10:43> - 46:21 <10:45>, 
47:19 <10:46>, 48:16 <10:47>, 49:8 <10:48>, 
49:21 <10:48>, 50:7 <10:48>, 50:8 <10:49>, 
50:20 <10:55>, 55:2
membership [1] <10:04> - 18:9
memorandum [1] <10:04> - 
18:21
mens [3] <10:20> - 30:13 <10:55>, 54:24 
<10:55>, 54:25
mentioned [4] <09:43> - 4:11 <09:56>, 
12:21 <10:19>, 29:13 <10:53>, 53:17
Mentor [2] <09:54> - 11:13 <10:03>, 
17:23
message [4] <10:23> - 32:16 <10:26>, 
34:19 <10:26>, 34:20 <10:30>, 37:19
messages [7] <10:05> - 18:22 <10:06>, 
19:8 <10:06>, 19:10 <10:16>, 27:5 <10:16>, 27:7 
<10:48>, 49:22 <10:48>, 50:3
messed [1] <11:09> - 64:23
Messenger [2] <10:23> - 32:17 <10:26>, 
34:19
Miami [2] <10:04> - 18:17 <10:59>, 58:7
mindful [1] <09:42> - 3:18
minor [1] <10:12> - 24:1
minutes [1] <11:15> - 69:14
misconduct [2] <10:32> - 38:23 
<10:42>, 46:4
mistake [5] <10:28> - 35:21 <11:05>, 
62:7 <11:09>, 64:22 <11:11>, 66:1 <11:12>, 
66:17
mobile [1] <10:51> - 51:15
81
mobility [1] <10:30> - 37:22
modified [3] <09:45> - 5:19 <11:02>, 
60:6 <11:08>, 63:24
modifying [1] <11:08> - 64:3
moment [3] <09:49> - 8:2 <09:52>, 9:23 
<11:08>, 64:5
money [12] <09:59> - 14:15 <10:01>, 
15:20 <10:03>, 17:7 <10:04>, 18:8 <10:04>, 
18:14 <10:07>, 19:25 <10:07>, 20:1 <10:13>, 
24:22 <10:14>, 25:20 <10:16>, 27:6 <10:16>, 
27:9
month [6] <09:56> - 13:2 <09:57>, 13:6 <09:57>, 
13:8 <10:27>, 35:1 <11:06>, 62:25 <11:16>, 
70:20
months [2] <09:46> - 6:2 <09:47>, 6:10
moot [1] <11:14> - 68:14
morning [10] <09:30> - 2:2 <09:41>, 2:8 
<09:41>, 2:10 <09:41>, 2:11 <09:41>, 2:15 <09:41>, 
2:16 <10:24>, 33:16 <10:25>, 34:2 <10:29>, 
36:15 <11:15>, 69:3
most [4] <10:06> - 19:14 <10:21>, 31:9 <10:21>, 
31:10 <11:01>, 59:12
motion [38] <09:41> - 2:19 <09:41>, 2:20 
<09:41>, 2:24 <09:41>, 2:25 <09:42>, 3:4 <09:42>, 3:8 <09:49>, 
7:17 <09:51>, 9:11 <09:53>, 10:20 <09:54>, 11:7 
<09:59>, 15:2 <10:03>, 17:11 <10:06>, 19:12 <10:07>, 
20:8 <10:09>, 22:2 <10:11>, 23:4 <10:16>, 26:18 
<10:16>, 27:11 <10:18>, 28:25 <10:18>, 29:1 <10:19>, 
29:4 <10:19>, 29:5 <10:29>, 37:2 <10:35>, 40:25 
<10:36>, 41:14 <10:37>, 41:23 <10:43>, 46:12 <10:54>, 
54:8 <10:59>, 57:20 <10:59>, 58:2 <11:00>, 
58:20 <11:04>, 61:16 <11:05>, 62:12 <11:08>, 
64:8 <11:13>, 68:2 <11:14>, 68:14 <11:16>, 
70:14 <11:16>, 70:21
motion's [1] <11:16> - 70:17
motions [4] <09:41> - 2:19 <09:42>, 3:6 
<09:51>, 9:7 <11:14>, 68:15
motive [4] <10:14> - 25:21 <10:15>, 
25:23 <10:15>, 26:1 <10:15>, 26:9
move [1] <10:36> - 41:4
moved [1] <11:14> - 69:2
moving [1] <11:04> - 61:19
MR [103] <09:41> - 2:8 <09:41>, 2:11 <09:41>, 
2:23 <09:42>, 3:10 <09:42>, 3:16 <09:42>, 3:20 
<09:45>, 5:7 <09:45>, 5:12 <09:46>, 6:1 <09:47>, 6:19 <09:49>, 
7:20 <09:50>, 8:7 <09:50>, 8:13 <09:50>, 8:24 <09:51>, 
9:10 <09:51>, 9:17 <09:52>, 9:23 <09:52>, 9:25 
<09:52>, 10:3 <09:54>, 11:3 <09:54>, 11:5 <09:55>, 
12:9 <09:58>, 14:1 <09:58>, 14:3 <09:58>, 14:10 
<10:00>, 15:8 <10:01>, 15:25 <10:02>, 16:20 <10:03>, 
17:9 <10:03>, 17:13 <10:05>, 18:23 <10:06>, 
19:10 <10:07>, 20:8 <10:09>, 21:17 <10:09>, 
22:2 <10:09>, 22:6 <10:10>, 22:12 <10:11>, 23:1 
<10:13>, 24:18 <10:14>, 25:13 <10:15>, 25:23 <10:15>, 
26:15 <10:16>, 26:19 <10:17>, 28:2 <10:18>, 
28:19 <10:19>, 29:10 <10:19>, 29:17 <10:19>, 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 81 of 88

29:21 <10:20>, 30:14 <10:21>, 30:25 <10:21>, 
31:3 <10:21>, 31:7 <10:26>, 34:14 <10:27>, 
35:14 <10:28>, 35:19 <10:36>, 41:5 <10:36>, 
41:13 <10:37>, 41:22 <10:38>, 42:18 <10:38>, 
43:4 <10:39>, 43:12 <10:41>, 45:9 <10:43>, 
46:14 <10:44>, 47:11 <10:44>, 47:14 <10:45>, 
47:17 <10:46>, 48:23 <10:47>, 49:10 <10:47>, 
49:14 <10:47>, 49:19 <10:48>, 50:3 <10:52>, 
52:19 <10:52>, 52:21 <10:53>, 53:10 <10:53>, 
53:16 <10:53>, 53:24 <10:55>, 54:15 <10:55>, 
55:3 <10:55>, 55:5 <10:55>, 55:13 <10:57>, 
56:14 <10:57>, 56:18 <10:59>, 58:5 <11:04>, 
61:18 <11:05>, 62:12 <11:06>, 62:15 <11:06>, 
62:21 <11:06>, 63:1 <11:07>, 63:10 <11:09>, 
64:15 <11:12>, 67:9 <11:12>, 67:12 <11:13>, 
67:14 <11:13>, 67:21 <11:13>, 68:5 <11:13>, 
68:11 <11:14>, 68:24 <11:15>, 69:10 <11:15>, 
69:14 <11:15>, 69:17 <11:15>, 69:20 <11:16>, 
69:25 <11:16>, 70:9
MS [30] <10:28> - 36:9 <10:29>, 36:14 <10:30>, 
37:9 <10:30>, 37:12 <10:33>, 39:7 <10:35>, 
40:14 <10:36>, 41:6 <10:40>, 44:4 <10:40>, 
44:12 <10:40>, 44:21 <10:41>, 45:2 <10:49>, 
50:18 <10:51>, 52:3 <10:52>, 52:11 <10:58>, 
56:23 <10:58>, 57:7 <10:58>, 57:10 <11:01>, 
59:18 <11:03>, 60:16 <11:03>, 60:19 <11:03>, 
61:2 <11:04>, 61:6 <11:10>, 65:7, 65:19 
<11:10>, 65:22 <11:11>, 66:2 <11:12>, 67:6 <11:16>, 
70:12 <11:16>, 70:18 <11:17>, 71:2
multiple [1] <10:01> - 16:2
multitude [1] <09:48> - 7:13
municipal [1] <10:54> - 54:12
must [2] <09:42> - 3:25 <11:09>, 64:23
N
namely [1] <10:22> - 32:6
narcotics [1] <09:52> - 10:5
navigate [1] <10:31> - 38:2
near [4] <10:22> - 31:17 <10:22>, 31:22 <10:26>, 
34:9 <10:57>, 56:6
necessary [6] <09:48> - 7:9 <09:49>, 
8:5 <09:49>, 8:6 <10:20>, 30:7 <10:21>, 31:5 <10:25>, 
34:7
need [5] <09:56> - 12:23 <10:16>, 27:6 <11:15>, 
69:22 <11:16>, 70:3
needed [3] <10:07> - 19:25 <10:46>, 
48:12 <11:05>, 62:4
needs [2] <10:18> - 28:7 <10:45>, 48:2
negate [1] <10:52> - 52:9
negative [2] <10:51> - 51:18 <10:51>, 
51:25
negligence [40] <09:42> - 3:22 <09:43>, 
4:1 <09:43>, 4:5 <09:45>, 5:15 <09:46>, 6:3 <09:46>, 
6:6 <09:48>, 7:5 <09:48>, 7:11 <09:49>, 7:23 <09:50>, 
8:11 <09:50>, 8:15 <10:01>, 15:23 <10:03>, 17:8 
<10:16>, 27:2 <10:17>, 27:13 <10:20>, 30:3 <10:28>, 
35:24 <10:32>, 38:22 <10:32>, 38:23 <10:32>, 
38:25 <10:35>, 40:22 <10:35>, 40:24 <10:37>, 
41:19 <10:37>, 41:21 <10:38>, 43:2 <10:39>, 
43:15 <10:39>, 43:16 <10:39>, 43:19 <10:40>, 
44:13 <10:41>, 44:23 <10:41>, 45:13 <10:41>, 
45:14 <10:42>, 45:23 <10:42>, 46:5 <10:43>, 
46:9 <10:43>, 47:1 <10:52>, 52:15 <10:54>, 54:1 
<10:55>, 54:21
negligent [18] <09:50> - 8:18 <10:02>, 
17:3 <10:13>, 24:16 <10:14>, 25:19 <10:15>, 
26:14 <10:17>, 27:21 <10:26>, 34:8 <10:31>, 
38:10 <10:37>, 41:24 <10:38>, 42:15 <10:49>, 
50:25 <10:52>, 52:13 <10:55>, 54:19 <10:56>, 
55:23 <10:57>, 56:9 <11:00>, 58:18 <11:09>, 
64:25
negligently [1] <10:44> - 47:6
neutral [2] <10:23> - 32:19 <10:30>, 
37:13
never [14] <09:48> - 7:6 <10:11>, 23:2 <10:12>, 
23:20 <10:18>, 28:20 <10:38>, 43:5 <10:41>, 
45:11 <10:42>, 45:24 <10:42>, 45:25 <10:43>, 
46:22 <10:44>, 47:3 <10:46>, 48:15 <10:48>, 
49:21 <10:53>, 53:5 <10:55>, 55:3
nevertheless [1] <10:18> - 29:1
next [5] <09:55> - 12:10 <10:24>, 33:16 <10:27>, 
34:25 <10:55>, 55:8 <10:56>, 56:5
night [1] <10:49> - 50:20
non [1] <11:13> - 68:8
non-prosecution [1] <11:13> - 
68:8
none [1] <10:58> - 57:1
nonoperational [1] <10:13> - 
24:17
normal [2] <10:04> - 18:6 <10:36>, 41:3
not-long [1] <11:01> - 59:8
note [2] <10:06> - 19:19 <10:19>, 29:11
noted [3] <11:06> - 62:23 <11:06>, 63:2 <11:06>, 
63:5
notes [1] <11:06> - 63:5
nothing [13] <09:43> - 4:3 <09:47>, 6:13 
<10:01>, 16:1 <10:16>, 27:4 <10:20>, 30:14 <10:32>, 
38:16 <10:33>, 39:15 <10:34>, 40:2 <10:34>, 
40:3 <10:39>, 43:10 <10:40>, 44:6 <10:41>, 
44:22 <10:41>, 45:5
notice [10] <10:10> - 22:14 <10:19>, 29:8 
<10:20>, 30:4 <10:21>, 31:11 <10:24>, 33:11 <10:26>, 
34:16 <10:28>, 36:2 <10:32>, 39:1 <11:14>, 
68:17 <11:16>, 70:14
Notice [1] <10:57> - 56:15
notified [1] <10:30> - 37:18
noting [1] <09:55> - 12:13
notion [1] <10:10> - 22:19
November [3] <09:58> - 13:22 <09:58>, 
14:4 <10:00>, 15:9
number [16] <10:03> - 17:18 <10:04>, 
18:13 <10:04>, 18:16 <10:22>, 32:7 <10:29>, 
36:23 <10:35>, 41:1 <10:36>, 41:4 <10:40>, 
44:14 <10:46>, 48:10 <10:46>, 48:13 <10:55>, 
54:17 <10:57>, 56:19 <10:59>, 57:19 <11:00>, 
58:16 <11:10>, 65:9
Number [8] <09:41> - 2:5 <10:19>, 29:4 
<10:36>, 41:16 <10:43>, 46:12 <10:43>, 46:15 <10:59>, 
58:6 <11:04>, 61:16 <11:04>, 61:18
numerous [1] <10:17> - 27:18
O
O'Keefe [3] <10:37> - 42:4 <10:42>, 
45:17 <10:42>, 45:21
O'SULLIVAN [28] <09:41> - 
2:11 <09:41>, 2:23 <09:42>, 3:10 <09:42>, 3:16 
<09:42>, 3:20 <09:45>, 5:7 <09:45>, 5:12 <09:46>, 6:1 <09:47>, 
6:19 <09:49>, 7:20 <09:50>, 8:7 <09:50>, 8:13 <09:50>, 
8:24 <09:51>, 9:10 <09:51>, 9:17 <09:52>, 9:23 
<09:52>, 9:25 <09:52>, 10:3 <10:16>, 26:19 <10:17>, 
28:2 <10:18>, 28:19 <10:52>, 52:19 <10:52>, 
52:21 <10:53>, 53:10 <11:13>, 68:11 <11:15>, 
69:17 <11:15>, 69:20 <11:16>, 69:25
O'Sullivan [10] <09:41> - 2:12 <09:41>, 
2:21 <09:42>, 3:9 <09:54>, 11:8 <09:55>, 12:11 
<09:58>, 14:12 <09:59>, 14:16 <10:06>, 19:20 <11:15>, 
69:15 <11:16>, 70:11
object [4] <10:35> - 41:1 <10:40>, 44:14 
<11:12>, 67:10 <11:13>, 67:19
objection [3] <10:34> - 40:6 <11:12>, 
67:7 <11:14>, 68:14
objections [1] <10:36> - 41:3
obligations [1] <10:54> - 54:4
observed [1] <10:30> - 37:17
obstruct [1] <10:58> - 57:14
obviously [3] <09:47> - 6:20 <10:38>, 
42:25 <11:15>, 69:21
occurred [7] <09:42> - 3:22 <09:43>, 4:4 
<09:44>, 4:22 <09:47>, 6:23 <10:43>, 46:16 <11:04>, 
61:20 <11:10>, 65:14
occurrence [2] <10:58> - 56:24
occurring [1] <10:19> - 29:6
offense [2] <09:45> - 5:5 <10:19>, 29:7
offer [5] <10:34> - 40:1 <10:45>, 47:23 <10:47>, 
49:2 <11:03>, 61:4 <11:12>, 67:9
offered [6] <10:29> - 36:17 <10:34>, 40:7 
<10:40>, 44:15 <10:41>, 44:22 <10:41>, 45:3 <10:41>, 
45:4
offering [3] <10:34> - 40:7 <11:02>, 
59:25 <11:03>, 60:23
officer [2] <10:48> - 50:4 <10:48>, 50:5
82
often [1] <09:52> - 10:5
on-the-spot [1] <10:36> - 41:3
once [1] <10:02> - 16:17
one [63] <09:44> - 4:17 <09:44>, 4:25 <09:47>, 
6:13 <09:47>, 6:16 <09:52>, 9:23 <09:54>, 11:10 
<09:55>, 12:7 <09:55>, 12:13 <09:57>, 13:10 <09:58>, 
14:10 <09:59>, 14:15 <10:00>, 15:13 <10:01>, 
16:7 <10:01>, 16:10 <10:03>, 17:14 <10:04>, 
18:7 <10:05>, 19:2 <10:07>, 20:10 <10:07>, 
20:12 <10:09>, 21:18 <10:10>, 22:13 <10:12>, 
24:3 <10:12>, 24:4 <10:13>, 24:11 <10:14>, 25:2 
<10:16>, 26:21 <10:16>, 27:4 <10:17>, 28:5 <10:19>, 
29:17 <10:20>, 29:23 <10:21>, 31:14 <10:22>, 
32:1 <10:22>, 32:7 <10:28>, 36:6 <10:32>, 39:1 
<10:37>, 41:22 <10:43>, 46:20 <10:45>, 48:2 <10:45>, 
48:3 <10:45>, 48:8 <10:49>, 50:20 <10:49>, 
50:21 <10:53>, 53:18 <10:53>, 53:19 <10:59>, 
57:24 <11:01>, 59:3 <11:01>, 59:11 <11:04>, 
61:18 <11:05>, 62:11 <11:05>, 62:13 <11:06>, 
62:24 <11:07>, 63:11 <11:07>, 63:14 <11:07>, 
63:15 <11:10>, 65:12 <11:11>, 66:7 <11:11>, 
66:9 <11:13>, 67:19 <11:14>, 68:19
one-and-a-half [1] <11:01> - 
59:11
open [3] <09:43> - 4:2 <10:46>, 48:20 <11:16>, 
70:20
operate [9] <10:00> - 15:11 <10:04>, 
18:19 <10:06>, 19:13 <10:15>, 26:7 <10:38>, 
42:16 <10:40>, 44:6 <11:00>, 58:13 <11:00>, 
58:21 <11:00>, 58:23
operated [1] <10:43> - 47:1
operating [30] <09:59> - 14:19 <10:01>, 
15:20 <10:04>, 18:6 <10:04>, 18:12 <10:07>, 
19:25 <10:14>, 25:14 <10:14>, 25:16 <10:14>, 
25:18 <10:15>, 26:4 <10:15>, 26:10 <10:15>, 
26:13 <10:17>, 27:23 <10:21>, 30:16 <10:23>, 
32:23 <10:37>, 41:25 <10:38>, 42:21 <10:42>, 
45:17 <10:42>, 46:7 <10:45>, 47:24 <10:45>, 
48:2 <10:47>, 49:8 <10:54>, 54:2 <11:00>, 58:11 
<11:00>, 58:25 <11:03>, 60:12 <11:03>, 60:14 <11:03>, 
60:25 <11:04>, 61:7 <11:04>, 61:8 <11:05>, 62:5
operation [4] <10:37> - 41:19 <10:39>, 
43:10 <11:02>, 60:3 <11:02>, 60:4
opportunity [1] <10:10> - 22:24
opposed [1] <10:22> - 31:15
opposite [1] <10:03> - 17:11
opposition [1] <10:28> - 36:6
order [23] <10:00> - 15:13 <10:04>, 18:16 
<10:06>, 19:11 <10:13>, 24:15 <10:13>, 24:22 <10:14>, 
25:20 <10:15>, 26:6 <10:38>, 42:24 <10:38>, 
43:6 <10:39>, 43:22 <10:41>, 45:8 <10:56>, 
55:18 <10:59>, 58:7 <11:00>, 58:11 <11:01>, 
59:10 <11:01>, 59:11 <11:02>, 59:22 <11:02>, 
60:2 <11:02>, 60:4 <11:02>, 60:8 <11:03>, 60:14 
<11:04>, 61:8
Order [3] <09:29> - 2:1 <09:59>, 15:1 <10:36>, 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 82 of 88

41:16
ordered [1] <11:00> - 58:21
orders [3] <11:01> - 59:5 <11:01>, 59:9 <11:04>, 
61:12
ordinance [5] <10:36> - 41:9 <10:36>, 
41:12 <10:36>, 41:13 <10:40>, 44:7 <11:03>, 
60:22
ordinances [1] <10:54> - 54:12
organized [1] <10:28> - 36:5
original [1] <10:50> - 51:10
originally [1] <11:14> - 69:1
outline [2] <09:53> - 10:11 <10:50>, 51:2
outlined [2] <10:16> - 26:21 <10:37>, 
41:23
overall [2] <09:55> - 12:7 <11:11>, 65:25
overlap [2] <09:43> - 4:13 <10:07>, 20:6
overlapping [3] <09:44> - 4:19 <09:44>, 
4:20 <10:09>, 21:24
overlaps [1] <10:07> - 20:10
own [3] <10:49> - 50:22 <10:51>, 51:15 <10:53>, 
53:7
owners [2] <09:48> - 7:3 <09:48>, 7:7
P
page [12] <09:51> - 9:10 <09:54>, 11:6 <10:05>, 
18:23 <10:11>, 23:5 <10:18>, 28:15 <10:44>, 
47:15 <10:57>, 56:14 <11:01>, 59:12 <11:06>, 
62:16 <11:06>, 62:21 <11:06>, 63:4 <11:08>, 
64:8
pages [2] <09:54> - 11:6 <11:06>, 63:4
paid [2] <09:46> - 5:20 <11:00>, 58:22
Palm [2] <10:24> - 33:8 <10:36>, 41:15
pandemic [1] <09:49> - 8:1
parcel [1] <10:35> - 40:17
park [1] <10:24> - 33:2
part [24] <09:44> - 4:20 <09:50>, 8:8 <09:52>, 
10:6 <09:52>, 10:9 <09:53>, 10:10 <10:00>, 
15:14 <10:15>, 26:2 <10:18>, 28:6 <10:21>, 
30:17 <10:23>, 32:13 <10:25>, 34:6 <10:28>, 
35:23 <10:35>, 40:17 <10:38>, 42:20 <10:43>, 
46:23 <10:44>, 47:5 <10:54>, 54:4 <11:07>, 
63:15 <11:07>, 63:18 <11:08>, 64:7 <11:09>, 
64:23 <11:15>, 69:6 <11:15>, 69:8
particular [7] <09:49> - 8:1 <10:03>, 
17:22 <10:07>, 20:10 <10:10>, 22:14 <10:11>, 
22:25 <10:55>, 54:21 <11:17>, 70:23
particularly [1] <10:29> - 36:25
parties [2] <09:41> - 2:6 <11:13>, 68:9
pass [1] <11:12> - 67:8
passed [3] <09:50> - 8:20 <10:53>, 53:8 
<11:13>, 67:20
passenger [3] <10:01> - 15:24 <10:33>, 
39:2 <11:00>, 58:23
passengers [10] <10:21> - 
31:13 <10:22>, 31:22 <10:23>, 32:8 <10:24>, 
33:16 <10:26>, 34:9 <10:31>, 38:11 <10:36>, 
41:10 <10:44>, 47:7 <10:54>, 54:4 <11:00>, 
58:13
passing [2] <09:47> - 6:16 <09:48>, 7:11
past [1] <11:16> - 70:3
path [2] <10:26> - 34:13 <10:28>, 35:18
pay [1] <09:48> - 7:9
Paycheck [1] <10:14> - 25:7
paying [3] <10:31> - 38:10 <10:36>, 
41:10 <11:00>, 58:13
payroll [3] <09:48> - 7:2 <09:48>, 7:8 <10:04>, 
18:10
pending [1] <09:41> - 2:19
people [6] <09:47> - 7:1 <10:05>, 19:4 <10:09>, 
21:14 <10:09>, 21:18 <10:20>, 30:6 <11:15>, 
69:10
per [3] <10:39> - 43:15 <10:39>, 43:19 <10:58>, 
57:12
perceive [1] <10:01> - 15:22
perfect [1] <09:53> - 10:21
perhaps [5] <09:51> - 9:8 <10:02>, 17:4 
<10:35>, 40:20 <10:37>, 42:10 <10:54>, 54:13
period [1] <10:27> - 35:15
permissible [1] <10:28> - 35:20
permit [1] <11:10> - 65:20
permitted [3] <09:49> - 7:18 <10:26>, 
34:11 <10:35>, 40:19
permitting [1] <10:22> - 32:4
person [8] <09:56> - 13:1 <10:08>, 20:16 
<10:09>, 22:1 <10:22>, 32:2 <10:24>, 33:13 <10:41>, 
44:25 <10:59>, 58:8 <11:06>, 62:17
personally [1] <10:46> - 48:20
pertinent [1] <09:42> - 3:6
PGA [1] <10:04> - 18:9
photographic [1] <10:23> - 
32:12
picture [1] <10:12> - 24:2
piece [1] <10:41> - 45:13
pieces [1] <09:41> - 3:1
pier [2] <10:24> - 33:3 <10:26>, 34:24
place [7] <10:02> - 16:13 <10:21>, 30:24 
<10:27>, 35:12 <10:35>, 40:23 <10:52>, 52:15 <10:59>, 
57:20 <11:13>, 68:1
places [1] <10:18> - 28:7
plan [8] <09:42> - 3:25 <09:47>, 6:13 <10:16>, 
26:20 <10:16>, 26:25 <10:16>, 27:3 <10:17>, 
27:12 <10:17>, 27:19 <11:16>, 70:14
planned [1] <10:09> - 22:5
planning [1] <11:16> - 70:6
point [8] <09:58> - 13:24 <10:04>, 18:21 
<10:06>, 19:10 <10:42>, 46:3 <10:49>, 50:19 <10:50>, 
51:11 <10:53>, 53:5 <11:14>, 68:20
poor [2] <10:29> - 36:21 <10:40>, 44:16
Port [10] <09:59> - 15:1 <10:00>, 15:13 <10:04>, 
18:17 <10:06>, 19:11 <10:59>, 58:7 <11:01>, 
59:6 <11:01>, 59:8 <11:01>, 59:10 <11:01>, 
59:11
port [6] <10:30> - 37:7 <10:30>, 37:18 <10:43>, 
46:17 <11:02>, 60:2 <11:02>, 60:4 <11:05>, 
61:25
pose [1] <10:58> - 57:13
posed [1] <10:58> - 57:12
position [14] <10:00> - 15:10 <10:12>, 
24:2 <10:13>, 24:13 <10:25>, 34:5 <10:38>, 
42:13 <10:39>, 43:24 <10:42>, 46:1 <10:43>, 
46:25 <10:45>, 48:9 <10:47>, 49:14 <10:56>, 
55:22 <10:57>, 56:8 <11:00>, 58:14 <11:00>, 
59:1
positive [1] <10:47> - 49:19
possession [1] <10:11> - 23:12
possibility [1] <09:50> - 8:11
possible [1] <10:28> - 36:10
postpone [1] <11:15> - 69:3
potential [1] <11:13> - 67:24
potentially [2] <09:44> - 4:18 <10:58>, 
57:9
powerful [1] <10:38> - 43:6
PPP [35] <09:42> - 3:24 <09:43>, 4:6 <09:44>, 
4:23 <09:46>, 5:22 <09:46>, 6:8 <09:47>, 6:17 <09:47>, 
6:20 <09:47>, 6:25 <09:48>, 7:5 <09:48>, 7:12 <09:48>, 
7:13 <09:49>, 7:23 <09:56>, 12:17 <09:56>, 
12:23 <09:56>, 13:3 <09:57>, 13:8 <09:57>, 
13:12 <09:57>, 13:15 <09:58>, 14:3 <09:58>, 
14:5 <09:59>, 14:18 <10:04>, 18:3 <10:07>, 20:1 
<10:08>, 20:24 <10:12>, 24:9 <10:14>, 25:8 <10:14>, 
25:12 <10:14>, 25:15 <10:15>, 26:3 <10:15>, 
26:11 <10:16>, 26:25 <11:00>, 58:19 <11:03>, 
60:23 <11:04>, 61:10
prejudice [8] <09:50> - 8:18 <09:51>, 
9:2 <09:53>, 10:24 <10:02>, 16:22 <10:02>, 
16:25 <10:11>, 23:16 <10:17>, 28:4 <10:41>, 
45:4
prejudiced [1] <10:02> - 16:18
prejudicial [7] <09:55> - 11:20 <10:52>, 
52:24 <11:02>, 59:23 <11:03>, 60:10 <11:03>, 
60:17 <11:03>, 61:3 <11:04>, 61:10
prepare [1] <10:33> - 39:15
prepared [1] <09:42> - 3:7
present [8] <09:41> - 2:13 <09:55>, 12:7 
<10:01>, 16:3 <10:22>, 32:4 <10:35>, 40:21 <10:36>, 
41:8 <10:58>, 57:1 <11:12>, 66:23
83
presentation [1] <11:01> - 59:8
presented [2] <10:20> - 30:5 <10:21>, 
31:13
presenting [2] <11:02> - 60:7 <11:14>, 
68:22
presumably [1] <10:41> - 45:1
presumption [1] <10:10> - 
22:21
pretrial [2] <11:16> - 70:17 <11:16>, 
70:21
pretty [2] <09:53> - 10:19 <10:38>, 43:6
prevented [1] <11:04> - 61:8
preventing [1] <10:36> - 41:9
primary [1] <10:57> - 56:19
print [1] <09:56> - 12:23
probative [8] <10:29> - 36:19 <10:40>, 
44:8 <10:40>, 44:9 <10:40>, 44:13 <10:52>, 
52:12 <10:52>, 52:15 <10:55>, 54:23 <10:59>, 
57:18
problem [6] <10:20> - 30:5 <10:24>, 
33:3 <10:24>, 33:11 <10:25>, 34:4 <10:28>, 36:3 
<11:14>, 68:24
proceed [1] <09:42> - 3:15
proceeding [2] <10:28> - 35:17 
<11:11>, 66:8
proceedings [1] <11:17> - 71:4
process [2] <10:09> - 21:12 <11:01>, 
59:5
proffer [1] <09:49> - 7:19
profit [3] <09:50> - 8:22 <09:50>, 9:1 <10:02>, 
17:1
profiting [1] <10:01> - 15:22
Program [1] <10:14> - 25:7
program [11] <10:05> - 19:2 <10:43>, 
46:19 <10:44>, 47:6 <10:45>, 47:25 <10:46>, 
48:18 <10:46>, 48:19 <10:47>, 48:25 <10:47>, 
49:1 <10:48>, 50:1 <10:51>, 52:2 <10:52>, 52:14
programs [3] <10:45> - 47:18 <10:45>, 
48:3 <10:49>, 50:22
projecting [1] <10:10> - 22:10
prong [1] <10:43> - 46:12
proof [1] <10:57> - 56:9
propeller [17] <10:19> - 29:8 <10:21>, 
31:12 <10:22>, 31:17 <10:22>, 31:22 <10:22>, 
31:25 <10:22>, 32:6 <10:23>, 32:11 <10:23>, 
32:15 <10:23>, 32:17 <10:24>, 33:12 <10:25>, 
33:22 <10:26>, 34:10 <10:30>, 37:7 <10:30>, 
37:14 <10:30>, 37:18 <10:32>, 39:1 <10:57>, 
56:6
propensity [3] <10:29> - 36:18 <11:03>, 
60:20 <11:04>, 61:11
proper [3] <09:52> - 10:8 <10:32>, 38:20 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 83 of 88

<10:53>, 53:6
properly [4] <10:24> - 33:12 <10:33>, 
39:3 <11:05>, 62:5 <11:08>, 63:25
proposition [1] <09:55> - 12:3
propulsion [19] <10:29> - 37:1 <10:30>, 
37:4 <10:31>, 37:23 <10:31>, 38:4 <10:31>, 
38:11 <10:32>, 38:15 <10:33>, 39:9 <10:33>, 
39:11 <10:33>, 39:16 <10:34>, 39:18 <10:34>, 
39:22 <10:34>, 40:2 <10:34>, 40:4 <10:34>, 40:6 
<10:35>, 40:11 <10:56>, 55:17 <10:57>, 56:19 <11:11>, 
66:6 <11:11>, 66:10
prosecution [1] <11:13> - 68:8
prosecutions [1] <09:57> - 
13:15
protect [2] <10:25> - 33:20 <10:44>, 47:6
Protection [1] <10:14> - 25:7
prove [7] <09:45> - 5:15 <09:59>, 14:21 <10:28>, 
35:24 <10:31>, 38:6 <10:35>, 40:22 <10:43>, 
46:9 <10:54>, 54:4
proven [2] <10:01> - 16:4 <10:12>, 24:7
provide [2] <10:50> - 51:6 <10:50>, 
51:13
providing [1] <10:51> - 51:20
proving [8] <09:57> - 13:19 <09:59>, 
14:23 <10:07>, 19:24 <10:12>, 24:4 <10:15>, 
26:11 <10:38>, 42:13 <10:43>, 46:25 <11:01>, 
59:2
proximate [4] <10:31> - 38:6 <10:31>, 
38:9 <10:55>, 54:18 <10:56>, 55:24
proximately [3] <10:19> - 29:9 <10:39>, 
43:18 <10:41>, 45:12
Public [1] <10:36> - 41:15
pull [1] <10:38> - 42:23
pulled [1] <10:30> - 37:7
purchase [1] <09:56> - 12:18
purchased [1] <11:07> - 63:12
pure [2] <10:15> - 26:1 <10:42>, 46:6
purely [1] <10:41> - 45:15
purpose [3] <10:29> - 36:20 <10:40>, 
44:16 <11:01>, 59:15
purposes [2] <10:28> - 36:2 <11:00>, 
58:22
put [5] <10:05> - 18:24 <10:20>, 30:4 <10:24>, 
33:1 <10:32>, 39:1 <11:16>, 70:13
putting [1] <10:24> - 33:10
Q
questioned [1] <10:48> - 49:25
questioning [2] <10:32> - 38:20 
<10:35>, 40:20
questions [2] <09:59> - 15:3 <10:36>, 
41:4
quickly [1] <10:01> - 15:20
quite [2] <10:07> - 20:10 <10:52>, 52:7
quo [1] <09:48> - 7:15
R
railing [1] <11:09> - 64:17
ran [2] <10:24> - 33:9 <10:33>, 39:3
random [3] <10:04> - 18:10 <10:45>, 
47:19 <10:47>, 49:1
rather [3] <09:56> - 13:3 <10:10>, 22:20 <10:53>, 
53:14
rational [2] <09:42> - 3:22 <09:50>, 8:10
rea [3] <10:20> - 30:13 <10:55>, 54:24 <10:55>, 
54:25
reading [2] <10:03> - 17:10 <10:03>, 
17:13
reads [1] <09:55> - 11:23
real [2] <10:14> - 25:6 <10:14>, 25:16
reality [1] <10:14> - 25:18
really [32] <09:46> - 5:24 <09:49>, 8:5 <09:55>, 
12:4 <10:04>, 18:20 <10:07>, 20:2 <10:07>, 20:5 
<10:09>, 21:20 <10:12>, 23:22 <10:13>, 24:25 <10:14>, 
25:16 <10:14>, 25:21 <10:15>, 26:1 <10:20>, 
30:8 <10:21>, 30:18 <10:21>, 31:8 <10:21>, 
31:10 <10:21>, 31:14 <10:22>, 32:3 <10:24>, 
33:4 <10:25>, 33:25 <10:25>, 34:2 <10:27>, 
35:14 <10:28>, 35:22 <10:28>, 36:2 <10:40>, 
44:15 <10:42>, 46:4 <10:52>, 52:12 <10:57>, 
56:16 <11:07>, 63:14 <11:09>, 64:21 <11:15>, 
69:17
reason [6] <09:54> - 11:12 <10:07>, 
20:11 <10:22>, 31:20 <11:11>, 66:12 <11:12>, 
66:19 <11:15>, 69:3
reasonable [3] <10:23> - 32:19 
<10:23>, 32:20 <10:24>, 33:13
reasons [8] <09:48> - 7:13 <09:55>, 
11:24 <09:55>, 11:25 <10:16>, 27:6 <10:16>, 
27:8 <10:18>, 28:14 <10:35>, 40:24 <10:54>, 
54:6
rebuttal [1] <10:16> - 26:16
recitation [1] <09:57> - 13:5
record [5] <09:51> - 9:12 <10:30>, 37:5 <10:35>, 
40:11 <11:05>, 62:13 <11:16>, 70:13
records [1] <10:45> - 48:9
recovered [1] <10:11> - 23:11
recreational [1] <09:56> - 12:19
recreationally [1] <10:12> - 
24:6
refer [1] <10:09> - 22:2
reference [5] <09:57> - 13:4 <09:57>, 
13:7 <10:00>, 15:8 <10:44>, 47:12 <11:13>, 
68:10
references [3] <09:45> - 5:5 <10:11>, 
23:4 <11:09>, 64:13
referencing [1] <10:00> - 15:6
referred [2] <10:36> - 41:14 <10:39>, 
43:19
referring [6] <10:12> - 24:8 <10:30>, 
37:9 <10:31>, 38:4 <10:31>, 38:10 <10:36>, 
41:12 <11:13>, 68:7
refers [1] <10:48> - 50:8
refitted [1] <11:11> - 66:13
refitting [3] <11:07> - 63:13 <11:11>, 
66:5 <11:12>, 66:18
reflected [2] <10:06> - 19:18 <10:54>, 
54:7
refuse [1] <10:50> - 51:8
refused [1] <10:50> - 51:13
regarding [2] <10:32> - 38:15 <11:11>, 
66:3
regimen [1] <10:43> - 46:23
registered [1] <10:43> - 46:19
regulation [2] <10:39> - 43:9 <10:43>, 
46:20
regulations [10] <10:39> - 43:7 
<10:40>, 44:10 <10:46>, 48:12 <10:50>, 51:2 <10:54>, 
54:5 <10:54>, 54:6 <10:56>, 55:20 <10:57>, 56:9 
<11:11>, 66:1 <11:12>, 66:22
regulatory [3] <10:53> - 53:14 <10:53>, 
53:22 <11:13>, 68:1
relate [2] <09:47> - 6:15 <11:07>, 63:10
related [4] <09:41> - 3:2 <09:53>, 10:11 <09:53>, 
10:12 <10:43>, 46:9
relates [2] <09:56> - 12:16 <10:56>, 
55:14
relating [1] <09:59> - 14:24
relationship [2] <09:42> - 3:22 <09:50>, 
8:10
relevance [4] <10:41> - 45:8 <10:52>, 
52:6 <10:52>, 52:9 <10:59>, 57:23
relevant [13] <10:13> - 24:14 <10:32>, 
38:25 <10:33>, 39:6 <10:37>, 41:21 <10:42>, 
46:8 <10:46>, 48:10 <10:52>, 52:6 <10:52>, 
52:23 <11:00>, 58:14 <11:00>, 59:1 <11:11>, 
65:25 <11:11>, 66:16 <11:12>, 67:2
relied [2] <09:53> - 10:13 <09:53>, 10:16
relies [1] <09:49> - 7:22
rely [1] <09:51> - 9:19
relying [2] <10:06> - 19:9 <10:33>, 39:13
remain [1] <11:14> - 68:16
remaining [1] <11:13> - 67:23
remains [1] <11:13> - 67:22
remedial [1] <10:56> - 56:2
84
remediated [1] <10:57> - 56:7
remediation [1] <11:00> - 58:16
remember [2] <10:20> - 29:24 <10:20>, 
29:25
remind [1] <10:10> - 22:11
remote [1] <11:15> - 69:5
removed [1] <11:07> - 63:15
removing [1] <11:07> - 63:21
rendered [1] <10:13> - 24:16
repairs [1] <11:09> - 64:13
reply [1] <09:48> - 7:5
report [9] <10:24> - 33:14 <10:30>, 37:17 
<10:32>, 38:14 <10:33>, 39:15 <10:34>, 40:3 <10:35>, 
40:11 <10:56>, 55:20 <11:06>, 63:3 <11:06>, 
63:5
reportable [1] <10:56> - 55:19
reported [3] <10:30> - 37:6 <10:56>, 
55:24 <11:06>, 63:3
reportedly [1] <10:30> - 37:16
reporter [1] <09:42> - 3:17
reporting [4] <10:57> - 56:11 <10:58>, 
56:25 <10:58>, 57:3 <10:59>, 57:21
reports [2] <11:01> - 59:6 <11:06>, 63:3
repossessed [1] <10:18> - 
28:21
representation [1] <10:17> - 
27:21
representations [2] <10:08> - 
21:6 <10:15>, 26:3
represented [1] <10:17> - 27:23
request [2] <10:29> - 36:23 <10:40>, 
44:14
requests [1] <10:01> - 15:20
require [2] <10:43> - 46:9 <10:56>, 56:1
required [6] <10:35> - 40:22 <10:41>, 
45:13 <10:43>, 46:20 <10:43>, 46:23 <10:44>, 
47:7 <10:50>, 51:13
requirement [5] <10:47> - 49:4 
<10:47>, 49:7 <10:57>, 56:11 <10:58>, 56:25 <10:59>, 
57:21
requirements [2] <10:44> - 
47:9 <10:50>, 51:3
requires [1] <10:17> - 27:16
reserve [1] <11:04> - 61:15
respect [2] <10:42> - 45:16 <10:53>, 
53:18
respectfully [1] <09:50> - 8:9
respond [2] <10:03> - 17:14 <10:11>, 
23:2
responded [2] <09:47> - 6:15 <10:43>, 
46:17
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 84 of 88

response [7] <09:54> - 11:7 <09:56>, 
12:15 <09:56>, 12:21 <10:01>, 15:25 <10:08>, 
21:9 <10:18>, 28:15 <11:00>, 58:17
restricted [1] <10:30> - 37:22
result [3] <10:16> - 26:23 <10:43>, 46:20 
<10:56>, 56:4
resulted [1] <10:23> - 32:13
resulting [1] <10:15> - 26:6
results [3] <10:05> - 19:3 <10:47>, 49:17 
<11:06>, 62:22
rethink [1] <11:13> - 67:15
return [1] <10:50> - 51:10
revenue [1] <09:57> - 13:9
revenues [1] <10:14> - 25:17
reverse [2] <10:02> - 16:16 <10:30>, 
37:17
review [1] <10:32> - 38:15
reviewed [1] <09:42> - 3:6
risk [2] <10:58> - 57:12 <10:58>, 57:13
road [2] <09:43> - 4:4 <09:45>, 5:13
robberies [2] <09:53> - 10:14 <10:11>, 
23:11
robbery [4] <09:54> - 11:15 <10:03>, 
17:23 <10:03>, 18:1 <10:11>, 23:7
room [1] <10:10> - 22:22
routinely [1] <09:54> - 11:9
Rule [12] <09:41> - 3:1 <09:43>, 4:11 <09:51>, 
9:14 <09:52>, 10:7 <09:55>, 11:23 <10:29>, 
36:16 <10:40>, 44:18 <11:04>, 61:19 <11:12>, 
67:2
rule [2] <10:10> - 22:22 <10:39>, 43:17
ruled [1] <11:13> - 67:24
rules [17] <09:55> - 11:23 <10:03>, 17:20 
<10:37>, 41:25 <10:37>, 42:12 <10:38>, 42:20 <10:39>, 
44:1 <10:40>, 44:10 <10:44>, 47:2 <10:46>, 
48:12 <10:53>, 53:1 <10:54>, 54:2 <11:05>, 62:4 
<11:05>, 62:8 <11:09>, 65:3 <11:10>, 65:16 <11:12>, 
66:17 <11:12>, 66:22
run [2] <09:55> - 12:1 <10:27>, 35:1
running [2] <10:14> - 25:20 <10:56>, 
55:18
S
sad [1] <09:50> - 8:18
safe [5] <10:04> - 18:18 <10:20>, 30:7 <10:38>, 
42:17 <10:39>, 43:10 <10:40>, 44:6
Safety [1] <10:36> - 41:16
safety [6] <10:59> - 58:9 <11:05>, 62:10 <11:10>, 
65:13 <11:11>, 66:1 <11:11>, 66:13 <11:12>, 
66:19
sale [1] <10:00> - 15:9
saliva [1] <10:50> - 51:6
samples [1] <10:51> - 51:20
saw [1] <10:26> - 34:24
SB [3] <09:44> - 4:21 <10:07>, 20:11 <10:09>, 
22:1
scene [2] <10:11> - 23:11 <10:43>, 46:21
scheduled [4] <11:14> - 68:16 <11:14>, 
69:2 <11:16>, 70:7 <11:17>, 70:25
scheme [7] <09:42> - 3:25 <09:47>, 6:13 
<10:12>, 24:3 <10:16>, 26:20 <10:16>, 27:1 <10:16>, 
27:3 <10:17>, 27:12
Scuba [1] <10:04> - 18:5
scuba [10] <10:07> - 20:15 <10:08>, 
20:16 <10:22>, 31:15 <10:22>, 31:16 <10:22>, 
31:21 <10:37>, 41:20 <10:46>, 48:20 <11:00>, 
58:22 <11:07>, 63:13 <11:07>, 63:19
scubaing [1] <10:24> - 33:1
se [2] <10:39> - 43:15 <10:39>, 43:19
seaman's [3] <10:20> - 29:25 <10:20>, 
30:2 <10:54>, 54:9
Sean [2] <09:41> - 2:5 <11:06>, 62:16
seated [2] <09:40> - 2:3 <09:41>, 2:17
second [4] <09:58> - 14:5 <09:58>, 14:8 
<10:02>, 16:15 <10:30>, 37:15
Section [1] <10:57> - 56:12
securing [1] <10:09> - 21:12
see [17] <09:44> - 4:17 <09:45>, 5:16 <09:45>, 
5:18 <09:53>, 10:19 <10:02>, 16:17 <10:02>, 
17:1 <10:17>, 27:12 <10:21>, 31:5 <10:33>, 39:5 
<10:41>, 45:7 <11:06>, 62:15 <11:06>, 62:19 <11:06>, 
62:22 <11:09>, 64:12 <11:16>, 69:25 <11:16>, 
70:2 <11:16>, 70:19
seeing [1] <10:08> - 20:20
seek [1] <10:41> - 45:4
seeking [8] <09:49> - 7:25 <10:03>, 17:7 
<10:29>, 36:19 <10:30>, 37:20 <10:32>, 38:13 <11:06>, 
62:24 <11:10>, 65:10 <11:10>, 65:15
seeks [2] <09:41> - 2:21 <09:41>, 2:25
seem [3] <10:21> - 30:20 <10:36>, 41:18 
<11:13>, 67:19
sees [1] <10:23> - 32:15
sells [2] <09:58> - 13:22 <09:58>, 14:4
send [1] <10:23> - 32:20
sends [3] <10:04> - 18:13 <10:23>, 32:16 
<10:49>, 50:14
sense [11] <09:53> - 10:21 <09:55>, 
11:20 <09:55>, 12:7 <10:08>, 20:21 <10:09>, 
21:24 <10:11>, 22:25 <10:42>, 46:7 <10:54>, 
53:25 <10:56>, 55:14 <11:08>, 64:2 <11:15>, 
69:15
senses [1] <10:42> - 46:6
sent [2] <10:26> - 34:20
sentence [1] <10:21> - 30:21
separate [10] <09:51> - 9:3 <09:54>, 
11:19 <09:56>, 12:17 <10:00>, 15:15 <10:03>, 
17:25 <10:04>, 18:2 <10:11>, 23:15 <10:24>, 
33:16 <11:11>, 66:3
separately [3] <09:44> - 5:2 <09:51>, 
9:4 <09:54>, 11:18
September [1] <11:14> - 69:1
serious [1] <10:50> - 51:5
served [1] <09:55> - 12:3
services [4] <10:45> - 47:23 <10:47>, 
49:2 <11:00>, 58:23 <11:02>, 59:25
set [4] <09:51> - 9:3 <10:12>, 24:3 <11:07>, 63:20
sets [1] <10:25> - 34:1
sever [9] <09:41> - 2:20 <09:41>, 2:21 <09:42>, 
3:8 <09:42>, 3:13 <09:49>, 7:18 <09:51>, 9:7 <09:53>, 
10:15 <09:53>, 10:20 <11:00>, 58:20
several [2] <09:51> - 9:7 <10:09>, 21:14
severance [13] <09:49> - 8:6 <09:51>, 
9:6 <10:07>, 20:5 <10:10>, 22:21 <10:10>, 22:23 
<10:11>, 22:25 <10:11>, 23:2 <10:11>, 23:6 <10:12>, 
23:20 <10:13>, 24:24 <10:14>, 25:4 <10:17>, 
27:25 <11:04>, 61:14
severed [2] <09:52> - 10:4 <09:52>, 10:5
shall [1] <10:45> - 47:17
shield [1] <10:25> - 33:20
shift [1] <09:45> - 5:18
shoe [1] <10:28> - 36:11
shortly [2] <09:58> - 14:12 <09:58>, 
14:13
shot [2] <10:23> - 32:11 <10:27>, 35:6
show [19] <10:28> - 35:24 <10:29>, 36:17 
<10:32>, 38:22 <10:39>, 43:25 <10:41>, 44:22 <10:41>, 
45:5 <10:44>, 47:3 <11:02>, 59:20 <11:03>, 
60:11 <11:03>, 60:23 <11:03>, 61:3 <11:04>, 
61:9 <11:04>, 61:11 <11:09>, 65:2 <11:10>, 
65:16 <11:11>, 65:25 <11:12>, 66:21 <11:12>, 
67:1 <11:13>, 67:18
showed [1] <10:22> - 32:5
showing [16] <09:59> - 14:25 <09:59>, 
15:5 <10:04>, 18:11 <10:14>, 25:14 <10:21>, 
31:11 <10:28>, 35:20 <10:42>, 45:22 <10:42>, 
45:23 <10:43>, 47:1 <10:46>, 48:10 <10:54>, 
54:3 <11:00>, 58:20 <11:02>, 59:21 <11:03>, 
60:19 <11:04>, 61:7 <11:05>, 62:3
shown [1] <10:18> - 28:14
shows [1] <10:39> - 43:7
shut [5] <10:04> - 18:14 <11:02>, 59:21 <11:02>, 
60:2 <11:02>, 60:3 <11:02>, 60:4
shutting [2] <10:15> - 26:8 <10:18>, 
28:17
sic [2] <10:09> - 21:23 <10:45>, 48:5
85
side [2] <10:30> - 37:7 <10:53>, 53:5
significant [5] <09:46> - 5:25 <10:29>, 
36:25 <10:50>, 51:12 <10:58>, 56:24 <11:13>, 
67:25
similar [1] <11:09> - 64:19
similarity [1] <11:09> - 64:20
simple [2] <10:07> - 20:2 <10:55>, 54:20
simplify [1] <10:13> - 24:14
sink [1] <10:16> - 26:24
sit [1] <10:28> - 36:10
six [1] <10:19> - 29:17
sixth [1] <10:19> - 29:17
slightly [3] <09:57> - 13:9 <10:13>, 
24:18 <10:39>, 43:14
slip [2] <10:50> - 51:10 <10:58>, 57:15
slowing [1] <09:48> - 7:14
slowly [1] <09:42> - 3:19
small [3] <09:48> - 7:3 <09:48>, 7:7 <10:08>, 
21:3
sold [2] <10:00> - 15:10 <10:18>, 28:20
sole [2] <10:29> - 36:20 <10:40>, 44:15
solely [4] <10:01> - 16:7 <10:01>, 16:8 <10:28>, 
35:17 <10:34>, 40:9
someone [14] <09:48> - 7:13 <09:54>, 
11:14 <09:56>, 12:22 <10:01>, 15:22 <10:08>, 
20:19 <10:22>, 31:24 <10:37>, 41:24 <10:39>, 
43:8 <10:39>, 43:17 <11:01>, 59:6 <11:05>, 
61:24 <11:05>, 62:3
sometimes [3] <09:54> - 11:13 <09:57>, 
13:15 <09:57>, 13:16
somewhat [1] <10:38> - 42:24
sorry [5] <09:42> - 3:20 <09:58>, 13:23 <09:58>, 
14:1 <10:02>, 16:22 <11:13>, 67:14
sort [3] <10:00> - 15:17 <10:40>, 44:9 <11:08>, 
64:4
sounds [1] <10:32> - 38:19
span [1] <10:25> - 34:1
speaking [9] <09:55> - 12:12 <09:59>, 
14:14 <10:01>, 16:3 <10:03>, 17:16 <10:14>, 
25:9 <10:21>, 31:8 <10:40>, 44:11 <11:15>, 
69:20 <11:16>, 70:2
speaks [5] <10:06> - 19:12 <10:07>, 
20:13 <10:08>, 21:5 <10:26>, 34:16 <10:39>, 
43:24
spear [4] <10:23> - 32:10 <10:25>, 33:20 
<10:26>, 34:18
special [1] <10:09> - 21:24
specific [4] <09:43> - 4:7 <10:55>, 54:16 
<10:55>, 54:19 <11:09>, 64:23
specifically [5] <09:56> - 12:15 
<10:15>, 26:3 <10:21>, 31:12 <10:51>, 51:19 <11:04>, 
61:19
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 85 of 88

spoken [3] <09:58> - 14:11 <10:08>, 
20:23 <10:45>, 48:4
spot [1] <10:36> - 41:3
spree [1] <10:11> - 23:7
Spurlock [1] <10:45> - 47:21
squeeze [1] <09:48> - 7:4
staff [2] <10:47> - 49:1 <10:47>, 49:8
standard [2] <10:16> - 27:10 <10:55>, 
54:25
start [4] <09:42> - 3:8 <10:16>, 26:25 <10:34>, 
40:10 <10:46>, 48:24
started [2] <09:46> - 6:3 <10:03>, 17:16
starting [2] <09:41> - 2:6 <10:19>, 29:4
state [2] <10:31> - 38:5 <11:13>, 68:8
statement [3] <09:50> - 8:7 <09:56>, 
12:19 <10:17>, 28:2
States [6] <09:40> - 2:4 <09:41>, 2:7 <09:41>, 
2:9 <09:51>, 9:11 <09:51>, 9:19 <09:54>, 11:2
states [3] <10:33> - 39:15 <10:34>, 40:3 
<10:34>, 40:5
stating [1] <11:11> - 66:10
status [1] <09:48> - 7:15
statute [4] <10:20> - 30:12 <10:58>, 57:1 
<10:58>, 57:12 <10:58>, 57:13
stay [1] <10:28> - 36:5
stealing [1] <10:13> - 24:25
steer [2] <10:24> - 33:4 <10:24>, 33:6
steered [1] <10:23> - 32:24
steering [1] <10:57> - 56:19
steps [1] <10:20> - 30:7
STIEHL [2] <10:46> - 48:23 <10:47>, 
49:10
Stiehl [1] <09:41> - 2:9
still [9] <10:00> - 15:13 <10:00>, 15:14 <10:17>, 
27:19 <10:17>, 28:3 <10:31>, 38:10 <10:41>, 
45:1 <10:55>, 54:20 <11:02>, 60:5 <11:11>, 
65:25
stipulate [1] <10:11> - 23:16
stolen [1] <10:13> - 24:21
stopped [2] <10:07> - 19:24 <10:14>, 
25:20
story [7] <10:00> - 15:14 <10:12>, 24:3 <10:13>, 
24:11 <10:18>, 28:7 <10:25>, 34:6 <10:28>, 
35:24
straight [1] <10:09> - 21:20
straits [1] <10:17> - 27:22
stretch [2] <09:48> - 7:10 <10:38>, 42:25
strikes [1] <10:23> - 32:11
stronger [1] <10:13> - 24:24
strongest [1] <10:06> - 19:7
strongly [1] <09:55> - 11:24
stuff [2] <10:02> - 17:1 <10:20>, 29:25
subject [2] <10:45> - 47:25 <11:11>, 
66:7
submission [3] <09:46> - 5:22 <09:46>, 
6:1 <09:46>, 6:7
submit [2] <10:06> - 19:16 <10:52>, 
52:18
submits [4] <09:57> - 13:10 <09:58>, 
14:5 <09:58>, 14:6 <09:58>, 14:8
submitted [2] <09:46> - 6:8 <10:51>, 
51:17
submitting [1] <11:05> - 62:13
subpart [1] <10:44> - 47:15
subsequent [4] <09:42> - 3:24 <09:47>, 
6:10 <09:57>, 13:16 <10:37>, 42:2
substantially [1] <10:51> - 
51:19
substantive [2] <10:15> - 26:2 <10:17>, 
27:25
successfully [1] <10:31> - 
37:24
sucked [6] <10:23> - 32:9 <10:23>, 32:11 
<10:25>, 33:18 <10:25>, 33:21 <10:25>, 33:22 <10:33>, 
39:2
suddenly [1] <10:23> - 32:9
sufficiently [1] <10:42> - 46:8
suggestion [1] <10:47> - 49:11
suggests [1] <09:42> - 3:24
Sunbiz [2] <11:04> - 61:6
supervision [1] <10:57> - 56:7
support [3] <09:51> - 9:6 <10:21>, 30:21 
<11:05>, 62:10
suppose [1] <10:02> - 17:3
supposed [8] <10:23> - 32:18 <10:24>, 
33:14 <10:46>, 48:11 <10:53>, 52:25 <10:56>, 
55:25 <11:03>, 60:11 <11:03>, 60:24
surprise [1] <10:18> - 28:12
surprising [2] <10:08> - 20:16 <11:16>, 
70:16
sway [1] <10:18> - 28:21
system [7] <10:29> - 37:1 <10:30>, 37:4 
<10:31>, 38:4 <10:32>, 38:16 <10:33>, 39:9 <10:33>, 
39:16 <10:57>, 56:20
T
table [1] <09:41> - 2:14
taint [1] <10:02> - 17:5
talks [1] <10:01> - 16:5
Tanner [1] <09:41> - 2:9
team [1] <11:06> - 62:16
temporal [2] <09:45> - 5:11 <09:47>, 
6:11
temporarily [1] <10:33> - 39:2
temporary [1] <11:09> - 64:13
ten [1] <10:27> - 35:9
tens [1] <09:47> - 6:24
terminate [1] <11:02> - 60:5
terminated [1] <10:01> - 15:21
Terrence [1] <09:41> - 2:12
test [11] <10:05> - 19:3 <10:33>, 39:9 <10:47>, 
49:3 <10:47>, 49:19 <10:49>, 50:15 <10:50>, 
51:9 <10:51>, 51:16 <10:52>, 52:18 <10:53>, 
53:2 <10:53>, 53:6 <10:53>, 53:7
tested [8] <10:43> - 46:21 <10:43>, 46:22 
<10:43>, 46:24 <10:46>, 48:21 <10:46>, 48:22 <10:48>, 
49:21 <10:49>, 50:22 <10:49>, 50:24
testify [10] <09:44> - 4:18 <09:44>, 5:1 <10:07>, 
20:12 <10:08>, 20:24 <10:26>, 34:18 <10:26>, 
34:21 <10:27>, 35:5 <11:01>, 59:4 <11:01>, 59:8
testifying [3] <11:01> - 59:3 <11:05>, 
61:23 <11:06>, 62:18
testimony [7] <10:07> - 20:9 <10:30>, 
37:15 <10:33>, 39:13 <10:34>, 40:9 <10:56>, 
55:25 <11:01>, 59:14 <11:05>, 62:11
testing [20] <10:05> - 19:1 <10:43>, 
46:18 <10:43>, 46:19 <10:45>, 47:18 <10:45>, 
47:23 <10:45>, 47:25 <10:45>, 48:5 <10:47>, 
48:25 <10:47>, 49:1 <10:47>, 49:5 <10:47>, 49:7 
<10:47>, 49:16 <10:48>, 50:5 <10:49>, 50:13 <10:50>, 
51:2 <10:51>, 51:15 <10:52>, 52:14
tests [2] <10:47> - 49:17 <10:51>, 51:25
text [8] <10:05> - 18:22 <10:06>, 19:8 <10:06>, 
19:10 <10:16>, 27:5 <10:16>, 27:7 <10:26>, 
34:19 <10:48>, 49:22 <10:48>, 50:3
texting [2] <09:59> - 14:14 <10:15>, 26:7
texts [1] <10:04> - 18:14
THE [133] <09:30> - 2:2 <09:41>, 2:10 <09:41>, 
2:15 <09:41>, 2:24 <09:42>, 3:15 <09:42>, 3:17 
<09:44>, 5:4 <09:45>, 5:8 <09:45>, 5:16 <09:47>, 6:14 <09:48>, 
7:16 <09:49>, 7:21 <09:50>, 8:12 <09:50>, 8:23 
<09:51>, 9:5 <09:51>, 9:16 <09:52>, 9:21 <09:52>, 9:24 
<09:52>, 10:2 <09:53>, 11:1 <09:54>, 11:4 <09:55>, 
12:2 <09:58>, 13:23 <09:58>, 14:2 <09:58>, 14:9 
<09:59>, 15:5 <10:00>, 15:17 <10:02>, 16:19 <10:02>, 
17:4 <10:03>, 17:12 <10:04>, 18:21 <10:05>, 
19:6 <10:07>, 20:3 <10:09>, 21:16 <10:09>, 22:1 
<10:09>, 22:4 <10:10>, 22:10 <10:10>, 22:18 <10:13>, 
24:13 <10:14>, 25:11 <10:14>, 25:18 <10:15>, 
26:13 <10:16>, 26:16 <10:17>, 27:16 <10:18>, 
28:18 <10:18>, 28:24 <10:19>, 29:16 <10:19>, 
29:19 <10:20>, 30:10 <10:21>, 30:19 <10:21>, 
31:2 <10:21>, 31:5 <10:26>, 34:11 <10:27>, 
35:11 <10:28>, 35:16 <10:28>, 36:5 <10:28>, 
36:13 <10:30>, 37:8 <10:30>, 37:11 <10:32>, 
86
38:19 <10:35>, 40:13 <10:35>, 40:16 <10:36>, 
41:7 <10:36>, 41:17 <10:38>, 42:16 <10:38>, 
42:23 <10:39>, 43:9 <10:40>, 44:3 <10:40>, 44:9 
<10:40>, 44:19 <10:41>, 44:24 <10:41>, 45:7 <10:42>, 
46:3 <10:44>, 47:8 <10:44>, 47:13 <10:44>, 
47:16 <10:46>, 48:19 <10:47>, 49:7 <10:47>, 
49:11 <10:47>, 49:17 <10:48>, 49:24 <10:49>, 
50:16 <10:51>, 52:1 <10:51>, 52:5 <10:52>, 
52:20 <10:53>, 53:9 <10:53>, 53:11, 
53:23 <10:54>, 54:11 <10:55>, 55:1 <10:55>, 
55:4 <10:55>, 55:6 <10:55>, 55:11 <10:57>, 
56:11 <10:57>, 56:17 <10:57>, 56:21 <10:58>, 
57:5 <10:58>, 57:8 <10:59>, 57:17 <11:01>, 
59:16 <11:03>, 60:13 <11:03>, 60:17 <11:03>, 
61:1 <11:03>, 61:5 <11:04>, 61:13 <11:05>, 62:9 
<11:05>, 62:14 <11:06>, 62:19 <11:06>, 62:24 <11:07>, 
63:7 <11:08>, 64:9 <11:10>, 65:5 <11:10>, 65:17 
<11:10>, 65:20 <11:10>, 65:23 <11:12>, 67:5 <11:12>, 
67:7 <11:12>, 67:11 <11:13>, 67:13 <11:13>, 
67:18 <11:13>, 67:22 <11:13>, 68:7 <11:13>, 
68:13 <11:15>, 69:8 <11:15>, 69:12 <11:15>, 
69:15 <11:15>, 69:19 <11:16>, 69:24 <11:16>, 
70:5 <11:16>, 70:10 <11:16>, 70:16 <11:16>, 
70:19 <11:17>, 71:3
theft [1] <10:15> - 25:25
theoretical [1] <09:49> - 7:24
theory [1] <10:31> - 38:8
there're [1] <10:46> - 48:14
therefore [3] <09:49> - 8:5 <10:14>, 
25:19 <10:29>, 36:21
therein [1] <09:42> - 3:7
thigh [1] <10:23> - 32:14
thinking [2] <10:08> - 21:2 <10:10>, 
22:13
third [3] <10:23> - 32:24 <10:27>, 35:4 <10:44>, 
47:15
thousands [1] <09:47> - 6:24
three [9] <10:13> - 24:20 <10:19>, 29:6 <10:26>, 
34:12 <10:27>, 35:10 <10:27>, 35:12 <10:29>, 
37:2 <10:34>, 40:1 <10:34>, 40:8 <10:35>, 40:16
threshold [2] <10:20> - 30:12 <10:52>, 
52:9
throughout [2] <09:47> - 6:24 <10:29>, 
37:2
tie [2] <10:17> - 27:13 <10:26>, 34:24
ties [1] <10:59> - 57:19
timetable [1] <11:14> - 68:22
Title [1] <10:57> - 56:12
today [3] <10:16> - 26:24 <11:13>, 67:24 
<11:14>, 68:15
together [6] <09:53> - 10:15 <09:53>, 
10:19 <09:55>, 11:24 <10:10>, 22:20
token [1] <10:12> - 24:10
took [5] <09:54> - 11:15 <10:27>, 35:12 <10:35>, 
40:23 <10:52>, 52:15 <10:59>, 57:20
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 86 of 88

tools [1] <09:52> - 10:6
top [1] <11:06> - 62:15
topic [5] <10:28> - 36:7 <10:35>, 40:25 <10:36>, 
41:4 <10:59>, 57:19 <10:59>, 58:2
total [2] <10:09> - 22:4 <10:44>, 47:2
totally [4] <09:43> - 4:9 <10:04>, 18:2 <10:11>, 
23:15 <11:11>, 66:3
toward [1] <10:23> - 32:24
towards [3] <10:24> - 33:8 <10:30>, 37:7 
<10:40>, 44:13
trade [1] <09:52> - 10:6
traffic [1] <10:58> - 57:14
transaction [2] <09:43> - 4:3 <09:53>, 
10:10
traumatizing [1] <10:06> - 
19:17
treated [1] <09:54> - 11:18
trial [15] <09:50> - 8:17 <10:09>, 21:13 <10:36>, 
41:2 <10:44>, 47:12 <10:49>, 50:23 <10:51>, 
51:22 <10:53>, 53:13 <10:54>, 54:1 <10:57>, 
56:13 <10:59>, 57:22 <11:07>, 63:11 <11:14>, 
68:16 <11:14>, 68:23 <11:16>, 70:20 <11:17>, 
70:25
trials [6] <09:54> - 11:19 <09:55>, 11:24 <10:03>, 
17:19 <10:03>, 17:25 <10:54>, 54:2 <10:54>, 
54:9
tried [4] <10:01> - 16:10 <10:02>, 17:1 <10:05>, 
18:23 <11:15>, 69:20
trigger [2] <10:58> - 56:25 <10:58>, 57:3
triggering [2] <10:28> - 36:1 <10:28>, 
36:3
trip [3] <11:14> - 68:25 <11:15>, 69:4 <11:15>, 
69:11
true [3] <09:59> - 14:22 <10:15>, 26:4 <10:42>, 
46:1
truly [1] <10:29> - 36:20
truncated [1] <11:14> - 68:22
try [3] <09:42> - 3:18 <10:01>, 16:1 <10:09>, 
21:21
trying [6] <09:50> - 9:1 <09:59>, 14:19 <10:14>, 
25:21 <10:38>, 42:23 <11:03>, 61:3 <11:08>, 
64:9
tugboat [1] <10:37> - 42:7
turn [4] <10:16> - 26:17 <10:43>, 46:12 <10:53>, 
53:13 <10:55>, 55:12
turned [1] <10:43> - 46:18
turning [1] <10:53> - 53:21
twice [1] <10:09> - 21:22
two [23] <09:41> - 2:19 <09:51>, 9:3 <09:54>, 
11:17 <09:54>, 11:18 <09:56>, 12:16 <09:59>, 
14:14 <10:03>, 17:24 <10:06>, 19:14 <10:07>, 
20:8 <10:09>, 21:23 <10:17>, 27:18 <10:18>, 
28:7 <10:25>, 34:1 <10:27>, 35:4 <10:27>, 35:10 
<10:45>, 48:4 <10:53>, 53:20 <10:57>, 56:15 <11:00>, 
58:14 <11:00>, 59:1 <11:10>, 65:12 <11:11>, 
66:3 <11:14>, 68:15
two-day [1] <10:25> - 34:1
type [15] <09:42> - 3:25 <09:54>, 11:10 <09:54>, 
11:11 <10:02>, 16:12 <10:04>, 18:4 <10:15>, 
26:5 <10:22>, 32:1 <10:28>, 35:25 <10:49>, 51:1 
<10:51>, 51:23 <10:55>, 54:23 <10:55>, 54:24 <10:56>, 
56:1 <10:56>, 56:3 <11:08>, 64:2
types [3] <09:53> - 10:16 <10:22>, 31:16 
<11:09>, 65:3
typically [1] <10:46> - 48:23
U
U.S [1] <10:58> - 57:4
ultimately [3] <10:27> - 35:1 <10:33>, 
39:3 <10:56>, 55:18
unable [3] <10:24> - 33:2 <10:31>, 38:6 <10:33>, 
39:3
unavailability [1] <11:14> - 
68:17
under [20] <09:41> - 3:1 <10:18>, 28:25 <10:23>, 
32:9 <10:25>, 33:18 <10:29>, 36:16 <10:40>, 
44:18 <10:46>, 48:16 <10:47>, 49:12 <10:52>, 
52:9 <10:55>, 55:2 <10:55>, 55:6 <10:56>, 55:20 
<10:57>, 56:7 <11:04>, 61:19 <11:06>, 62:15 <11:06>, 
62:16 <11:06>, 62:22 <11:10>, 65:18 <11:10>, 
65:21 <11:12>, 67:2
underpinning [1] <10:39> - 
43:9
unduly [4] <09:50> - 8:17 <09:51>, 9:2 <09:53>, 
10:24 <10:52>, 52:23
unfolding [1] <10:37> - 42:12
unfortunate [3] <09:42> - 3:23 <09:47>, 
6:16 <10:41>, 45:6
unfortunately [1] <10:41> - 
45:5
uninspected [1] <10:45> - 
47:19
unintended [2] <10:57> - 56:16 
<10:58>, 57:5
unique [1] <09:47> - 6:20
United [6] <09:40> - 2:4 <09:41>, 2:7 <09:41>, 
2:9 <09:51>, 9:11 <09:51>, 9:19 <09:54>, 11:2
unless [3] <09:40> - 2:3 <09:41>, 2:17 <10:13>, 
25:1
unlike [1] <10:24> - 33:13
unrelated [1] <11:10> - 65:12
untimely [2] <09:46> - 6:5 <09:48>, 7:11
unusual [2] <10:01> - 16:1 <10:55>, 
54:21
up [16] <09:43> - 4:13 <09:44>, 4:23 <09:45>, 
5:15 <09:59>, 14:23 <10:12>, 24:10 <10:16>, 
26:21 <10:18>, 28:8 <10:24>, 33:6 <10:26>, 
34:24 <10:31>, 37:25 <10:53>, 53:6 <11:07>, 
63:13 <11:08>, 64:1 <11:09>, 64:23 <11:15>, 
69:6 <11:16>, 70:20
upcoming [1] <11:16> - 70:15
urine [1] <10:50> - 51:6
USCG [1] <10:51> - 51:17
V
vacation [2] <11:15> - 69:8 <11:15>, 
69:10
various [4] <09:41> - 3:1 <10:04>, 18:9 <10:19>, 
29:2 <11:12>, 67:8
ventures [1] <10:22> - 31:16
versus [2] <09:55> - 12:6 <10:55>, 54:23
vessel [65] <09:45> - 5:19 <09:46>, 5:20 
<09:49>, 8:3 <09:56>, 12:18 <09:58>, 13:22 <09:58>, 
14:4 <10:00>, 15:9 <10:00>, 15:10 <10:00>, 
15:13 <10:05>, 19:4 <10:06>, 19:13 <10:07>, 
20:14 <10:12>, 24:5 <10:21>, 31:12 <10:22>, 
31:21 <10:23>, 32:23 <10:24>, 33:4 <10:24>, 
33:9 <10:24>, 33:11 <10:27>, 35:2 <10:27>, 35:7 
<10:29>, 36:25 <10:30>, 37:16 <10:31>, 37:25 <10:37>, 
41:19 <10:38>, 42:17 <10:38>, 42:21 <10:40>, 
44:6 <10:42>, 45:22 <10:42>, 46:5 <10:43>, 
46:10 <10:43>, 46:16 <10:44>, 47:2 <10:44>, 
47:4 <10:45>, 47:24 <10:47>, 49:9 <10:49>, 
50:20 <10:50>, 51:5 <10:50>, 51:10 <10:54>, 
54:2 <10:56>, 55:18 <10:58>, 57:2 <11:00>, 
58:11 <11:00>, 58:13 <11:00>, 58:21 <11:02>, 
59:21 <11:02>, 60:3 <11:03>, 60:15 <11:05>, 
62:5 <11:07>, 63:9 <11:07>, 63:12 <11:07>, 
63:13 <11:07>, 63:16 <11:07>, 63:17 <11:07>, 
63:18 <11:07>, 63:20 <11:08>, 64:4 <11:09>, 
65:2 <11:10>, 65:12 <11:11>, 66:7 <11:11>, 
66:11 <11:12>, 66:19 <11:12>, 66:24 <11:12>, 
67:4
vessel's [1] <10:32> - 38:17
vessels [6] <10:09> - 21:11 <10:36>, 
41:9 <10:39>, 43:10 <10:45>, 47:19 <10:45>, 
48:2 <11:11>, 66:1
via [1] <10:30> - 37:18
victim [7] <09:47> - 6:16 <09:54>, 11:16 
<10:00>, 15:7 <10:25>, 33:19 <10:37>, 42:6 <10:56>, 
56:5 <11:09>, 64:12
victim's [1] <09:56> - 12:20
victims [3] <09:43> - 4:10 <09:45>, 5:14 
<09:53>, 10:23
view [1] <11:07> - 63:8
violating [2] <10:36> - 41:9 <10:54>, 
54:5
violation [3] <10:39> - 43:13 <10:39>, 
87
43:17 <10:39>, 43:23
violations [3] <10:54> - 54:12 <10:57>, 
56:8 <11:13>, 68:1
violence [1] <09:54> - 11:10
W
wait [1] <09:58> - 13:23
wake [2] <10:16> - 26:21 <10:18>, 28:8
walk [3] <09:45> - 5:9 <10:44>, 47:8 <10:48>, 
50:1
wants [2] <11:12> - 67:9 <11:13>, 68:1
warrant [1] <10:11> - 23:8
water [4] <09:43> - 4:2 <10:38>, 43:1 <10:40>, 
44:20 <10:41>, 44:25
waterway [1] <10:24> - 33:8
waterways [1] <10:59> - 58:9
ways [4] <10:54> - 53:25 <11:00>, 58:14 
<11:01>, 59:2 <11:07>, 63:14
weaker [1] <10:14> - 25:4
Weaver [2] <09:51> - 9:19 <09:52>, 9:22
week [1] <11:14> - 69:1
weeks [1] <09:46> - 6:4
weight [4] <10:18> - 28:22 <10:35>, 
40:18 <10:39>, 43:24 <10:41>, 45:15
wetsuit [1] <10:25> - 33:22
whereas [2] <09:43> - 4:6 <10:02>, 
16:20
whole [1] <10:42> - 45:24
wide [2] <09:51> - 9:15 <10:17>, 28:3
willing [1] <10:34> - 40:1
wire [12] <09:42> - 3:24 <09:43>, 4:6 <09:45>, 
5:18 <09:50>, 8:11 <09:57>, 13:16 <09:57>, 
13:19 <10:13>, 24:14 <10:13>, 24:15 <10:13>, 
24:20 <10:15>, 25:25 <10:17>, 27:14 <10:53>, 
53:15
wires [2] <10:13> - 24:22 <10:13>, 24:25
wish [1] <10:35> - 40:21
wishes [1] <11:14> - 68:21
witness [18] <09:44> - 4:17 <09:44>, 
4:21 <09:44>, 5:1 <10:08>, 20:25 <10:09>, 22:7 
<10:10>, 22:14 <10:26>, 34:15 <10:26>, 34:16 <10:26>, 
34:22 <10:27>, 35:4 <10:45>, 48:8 <10:53>, 
53:18 <11:01>, 59:3 <11:05>, 61:23 <11:05>, 
62:11 <11:14>, 68:17 <11:14>, 68:19 <11:15>, 
69:16
witnesses [12] <09:44> - 4:14 <09:44>, 
4:17 <09:45>, 5:15 <10:07>, 20:6 <10:07>, 20:9 
<10:09>, 21:23 <10:09>, 22:4 <10:10>, 22:9 <10:12>, 
23:25 <10:27>, 35:4 <10:27>, 35:9 <11:05>, 62:2
wobbly [1] <10:28> - 36:12
woman [4] <09:50> - 8:19 <10:32>, 38:24 
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 87 of 88

88
<10:37>, 42:8 <10:42>, 45:18
word [2] <09:42> - 3:18 <10:18>, 28:14
words [1] <10:02> - 16:25
works [5] <10:08> - 21:10 <10:26>, 34:23 
<10:46>, 48:23 <11:05>, 61:24 <11:15>, 69:4
worth [1] <09:55> - 12:13
wrapped [1] <09:44> - 4:23
Y
year [9] <09:43> - 4:4 <09:45>, 5:13 <09:57>, 
13:11 <09:58>, 14:5 <11:04>, 61:20 <11:06>, 
62:25 <11:09>, 64:10 <11:10>, 65:14 <11:11>, 
66:11
years [1] <10:17> - 27:18
young [1] <09:42> - 3:23
Z
Zachary [2] <09:41> - 2:8 <09:54>, 11:3
Case 9:24-cr-80103-AMC   Document 106   Entered on FLSD Docket 05/09/2025   Page 88 of 88

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