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Home Court filings RESPONSE to Motion re 32 First MOTION in Limine — USA v. Okeke (Dkt. 37) Response to Motion re 32 First Motion — Response to Motion re 32 First Motion in Limine — USA v. Okeke (Dkt. 37) (Dkt. 37, E.D.N.Y.)

Court filing

Response to Motion re 32 First Motion — Response to Motion re 32 First Motion in Limine — USA v. Okeke (Dkt. 37) (Dkt. 37, E.D.N.Y.)

Filed May 24, 2024 in Docket NYED 474435, the only filing from this case in the archive.

Record facts

CourtU.S. District Court for the Eastern District of New York
Filed2024-05-24

U.S. District Court for the Eastern District of New York · No. 1:22-cr-00020-FB · Doc. 37 · 2024-05-24 · Docket on CourtListener

Full text

Hon. Frederic Block 
Page 1 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
May 24, 2024 
BY ECF 
 
Honorable Frederic Block 
United States District Judge 
Eastern District of New York 
225 Cadman Plaza East 
Brooklyn, New York 11201 
 
 
Re: 
United States v. Anuli Okeke 
22 Cr. 20 (FB) 
Dear Judge Block: 
 
We write on behalf of the defendant Anuli Okeke (“Okeke”) in response to the 
government’s motions in limine (“Mot.”, Dkt. 78).  For the reasons stated below, the Court should 
deny motions 1, 2, 3, and 7.  Defendant does not object to motions 4 and 5 and does not object to 
motion 6 on the understanding that the parties are in agreement, as described below, on the proper 
use of law enforcement reports of witness interviews. 
1. Loan Documents and Business Emails 
 
The government states that “it intends to offer various loan contracts and related PPP and 
EIDL loan documents and accompanying correspondence” as verbal acts or business records.  
Mot. at 6.  While the defense disputes that the documents are verbal acts,1 they might nevertheless 
be admissible as either business records or as non-hearsay.  However, the government, which does 
not appear to request any ruling on the motion from the Court, has not identified the documents to 
which it is referring with sufficient specificity for the defense to respond. 
 
 
The vagueness of the government’s request is compounded by the fact that the 
government’s current exhibit list is so lacking in specificity as to be nearly illusory.  The 
 
1 Verbal acts are verbal or written statements that “give rise to legal consequences” like 
contracts.  See United States v. Cardascia, 951 /f.2d 474, 486-87 (2d Cir. 1991).  The 
government’s motion papers do not refer to any allegation that Okeke or any alleged co-
conspirator entered into any contract or legal agreement with any other party. 
Case 1:22-cr-00020-FB     Document 37     Filed 05/24/24     Page 1 of 4 PageID #: 183

Hon. Frederic Block 
Page 2 
 
government and the defendant have had multiple discussions regarding the defense’s issues with 
the exhibit list—including the fact that exhibits are missing, nearly 80 percent of the exhibits are 
in a single series and described simply as “Popular Bank Records,” exhibits are compilations of 
multiple documents or videos that are hours long, and hundreds of exhibits are listed with little or 
no explanation of what they are or their source, many of which appear unlikely to actually be used 
at trial.  Given the current state of the government’s exhibit list, it is impossible for the defendant 
to determine to which exhibits or portions thereof the government’s current motion refers. The 
government has informed the defense that it is currently endeavoring to amend the exhibit list. 
 
In addition to these discussions regarding the government’s amending its exhibits list, the 
defense has also solicited from the government potential stipulations regarding the admissibility 
of bank records that will hopefully moot this issue.  At present, however, the government’s motion 
is vague and unripe and should be denied. 
2. Other Acts Evidence 
 
The government “moves in limine to admit testimony and limited documents as to certain 
other acts evidence.”  Mot. at 7.  While the government offers a general description of categories 
of other acts evidence it wishes to admit, it provides no specific description of the documents or 
testimony it seeks to introduce, let alone exhibit or Bates numbers identifying the documents.  For 
this reason and the problems discussed above regarding the government’s exhibit list, this 
application, too, is premature and should be denied.   
 
First, the government asserts that it “anticipates introducing evidence that the defendant in 
some instances knowingly violated Bank 1 policies, practices, and procedures.”  Mot. at 8.  The 
government further states—vaguely—that the evidence it seeks to introduce relates to “ethics, 
including conflicts of interests, abusive sales practices, falsifying or manipulating applications, 
anti-money laundering practices, and know-your-customer requirements.”  Mot. at 9. 
 
While evidence regarding Bank policies allegedly violated and relating to the conduct at 
issue in this case would be relevant and likely admissible, the government has simply not provided 
sufficient information to conduct such an analysis.  General ethics policies and trainings, for 
example, would appear to be irrelevant and inadmissible under Federal Rules of Evidence 402 and 
403.  Because the government has failed to identify any specific policy or practice in its motion 
or on its exhibit list, this branch of the motion is premature and should be denied. 
 
The second branch of this motion relates to the government’s intention to “introduc[e] 
evidence that the defendant did not report her earnings from the fraudulent scheme on her taxes.”  
Mot. at 8.  Once again, the government has not identified what sorts of documents it intends to 
introduce and/or who it would call to testify regarding this issue.  Neither the government’s 
motion papers nor the exhibit list identify any relevant tax filings or documents relating to the 
defendants income and taxes for the relevant time period.  This branch of the motion should thus 
also be denied. 
 
In the event that the government were able to identify evidence probative of whether 
defendant declared income connected to the charged conduct—which, to date the government has 
Case 1:22-cr-00020-FB     Document 37     Filed 05/24/24     Page 2 of 4 PageID #: 184

Hon. Frederic Block 
Page 3 
 
not done—the defense would agree that such evidence could be admitted pursuant to Rule 404(b) 
and the jury be given a limiting instruction.  The government is incorrect, however, that this 
evidence could be admitted as direct evidence of the charges.  In a recent opinion, Judge Nicholas 
Garaufis considered this very issue and held that “the court declines to find that the tax returns are 
admissible as direct evidence,” noting that “the Government has not pointed the Court to any cases 
in which courts have admitted tax return evidence solely under the standard for direct evidence.”  
United States v. Kurland, No. 20 Cr. 206 (NGG), 2022 WL 2669897, 2022 U.S. Dist. LEXIS 
121821, at * 22-23 (E.D.N.Y. July 11, 2022).  Indeed, in Kurland, Judge Garaufis noted that in 
the case on which the government seeks here to rely, United States v. Black, No. 13 Cr. 316 (DLI), 
2014 WL 5783067, U.S. Dist. LEXIS 156884 (E.D.N.Y. Nov. 5, 2014), while the Court 
acknowledged that it was persuaded by out of circuit authority that tax returns could constitute 
direct evidence, the returns ultimately came in only after a Rule 404(b) analysis.  Kurland, 2022 
U.S. Dist. LEXIS 121821, at * 22-23; accord United States v. Hurt, No. 14 Cr. 250 (JBA), 2016 
U.S. Dist. LEXIS 446 (D. Conn. Jan. 4, 2016) (noting Rule 404(b) analysis in Black and admitting 
tax returns with limiting instruction under same rationale).  
 
The government’s motion should thus be denied as premature because the Court and the 
defense lack notice of which document/s or document types the government intends to offer.  In 
the event that the government in the future does present relevant and admissible tax documentation, 
those documents should be admitted only with an appropriate limiting instruction. 
3. Statements of Co-Conspirators 
 
The government writes that it “does not ask the Court to rule on the admissibility of any 
particular emails or other out-of-court statements by co-conspirators that the government intends 
to offer at this time, but merely provides notice of the types of co-conspirator statements the 
government will seek to introduce at trial.”  Mot. at 12.  Because the government seeks no relief 
and the defense is confident that the Rules of Evidence will be adhered to, no response is necessary. 
4. Evidence Regarding Punishment, and Prior Good Acts 
 
The government moves “to preclude evidence and argument” regarding “potential 
punishment or consequences” faced by defendant and “prior commission of any alleged ‘good 
acts.’”  Mot. 13-14.  Defendant has never stated any intention to offer such evidence or make 
such an argument and has no such intention. 
5. Evidence Regarding Alleged Negligence by Popular Bank and the SBA 
 
The government moves to preclude evidence that “because [Popular Bank] or the [Small 
Business Administration] SBA . . . were [] negligent,” defendant should be exonerated.  Mot. at 
15.  Defendant has never stated any intention to offer such evidence or assert such an argument 
and has no such intention. 
6. Use of Agent Reports 
 
The government moves to preclude the defense from publishing Form 302s or similar law 
enforcement reports summarizing witness interviews to the jury as prior inconsistent statements of 
Case 1:22-cr-00020-FB     Document 37     Filed 05/24/24     Page 3 of 4 PageID #: 185

Hon. Frederic Block 
Page 4 
 
witnesses.  The defense and government have discussed this motion and appear to be in agreement 
regarding the appropriate process for using such agent reports.  Defendant intends to question the 
government’s cooperating witnesses regarding their meetings with law enforcement and various 
false and inconsistent statements the cooperators made during those meetings.  During that 
examination, the defense may show the cooperators the reports to refresh their recollection, where 
appropriate, but will not display the reports to the jury. 
 
If the witnesses deny making the statements, the defense will thereafter attempt to enter 
into any necessary stipulations with the government reflecting the prior statements of the 
witnesses.  Should the parties fail to reach stipulations, the defense intends to call the law 
enforcement officer notetakers to the stand and to examine them.  During that testimony, the 
defense might seek to introduce the reports or portions thereof should the officers testify 
inconsistently with prior statements they made in their own reports.  Defendant has submitted a 
list of notetakers to the government, and the government has indicated that it will attempt to make 
those individuals available to testify (if needed) during the trial. 
7. Defense Exhibits and Trial Statements 
 
The government “requests that the Court order the defendant to disclose defense exhibits, 
including exhibits they intend to introduce through cross-examination of government witnesses, 
and Rule 26.2 defense witness material.”  Mot. at 18.  Initially, the government’s request is 
overbroad, as it improperly includes cross-examination exhibits used to impeach witnesses.  Rule 
16 makes clear that its disclosure requirement includes only documents and records the defendant 
intends to use “in the defendant’s case-in-chief at trial.”  Fed. R. Crim. P. 16(b)(1)(A).  
 
The defense is aware of its obligations under the Rules and has complied with them.  
Defendant does not at this time have any exhibits or Rule 26.2 materials in her possession relating 
to evidence she intends to use in her case-in-chief.  If, in the future, this position were to change, 
Defendant would produce the relevant materials promptly.  The government’s motion, which fails 
to identify any exhibit or statement the government believes has been withheld, should therefore 
be denied. 
CONCLUSION 
 
For the reasons stated above, the Court should deny motions 1, 2, 3, and 7.  Defendant 
does not object to motions 4 and 5 and does not object to motion 6 on the understanding that the 
parties are in agreement on the proper use of law enforcement reports of witness interviews. 
 
 
 
 
 
 
Very truly yours, 
 
 
 
 
 
 
Sanford Talkin 
 
 
 
 
 
Sanford Talkin 
 
 
 
 
 
Noam Greenspan 
 
cc: all counsel of record (via EFC) 
Case 1:22-cr-00020-FB     Document 37     Filed 05/24/24     Page 4 of 4 PageID #: 186

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