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Home Court filings United States v. Carolyn and Tracy Wade — U.S. District Court, S.D. Fla. Transcript, Hearing Within Trial (May 17, 2024) — United States v. Carolyn D. Wade (Document 139)

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Transcript, Hearing Within Trial (May 17, 2024) — United States v. Carolyn D. Wade (Document 139)

Summary

This 35-page transcript of a hearing within trial on May 17, 2024, filed as Document 139 in United States v. Carolyn D. Wade (Case No. 23-CR-60173, Southern District of Florida), opens with Judge Donald L. Graham denying a defense motion after viewing the evidence in the light most favorable to the government and finding questions of fact for the jury. The court then takes up the defense assertion that witnesses were precluded from testifying by government threats. Prosecutor David A. Snider says he asked the defense for the name of the attorney for Haydee Granados and Eduardo Rivero, Lindsay Chase, to learn whether they would assert their Fifth Amendment rights, and describes the two as de facto targets of a grand jury investigation.

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Record facts

CourtU.S. District Court for the Southern District of Florida
Filed2024-08-28

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“Transcript, Hearing Within Trial (May 17, 2024) — United States v. Carolyn D. Wade (Document 139).” U.S. District Court for the Southern District of Florida, No. 0:23-cr-60173-KMW, Doc. 139, filed 2024-08-28. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-wade-flsd-654266/2024-08-28-motion-doc-139/, SHA-256 553127403a809dc76a20da69215f6f5213f9a204afd7425e9c2b076a558bba7c.

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CRIMINAL DIVISION
CASE NO. 23-CR-60173 WILLIAMS (GRAHAM) 
UNITED STATES OF AMERICA, 
Miami, Florida 
Plaintiff,
May 17, 2024
vs.
 
9:49 AM - 4:01 PM
CAROLYN D. WADE,
(HEARING WITHIN TRIAL) 
Defendant. 
Pages 1 to 35
____________________________________________________________
TRANSCRIPT (EXCERPT) OF TRIAL
HELD BEFORE THE HONORABLE DONALD L. GRAHAM
UNITED STATES DISTRICT JUDGE
LANCE W. STEINBEISSER, FCRR, RPR, FPR-C
Official Court Reporter
United States District Court
400 North Miami Avenue 
Miami, Florida 33128
305.523.5633
Proceedings recorded by mechanical stenography; transcript 
produced by computer-aided transcription. 
Case 0:23-cr-60173-KMW   Document 139   Entered on FLSD Docket 08/28/2024   Page 1 of 35

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APPEARANCES:
 
FOR THE GOVERNMENT:
 
DAVID A. SNIDER, AUSA
United States Attorney's Office 
500 East Broward Boulevard, Floor 7
Fort Lauderdale, Florida 33394
954-660-5696
david.snider@usdoj.gov 
DERIC ZACCA, AUSA 
United States Attorney's Office                         
500 East Broward Boulevard, Floor 7
Fort Lauderdale, Florida 33394
954-660-5789
deric.zacca@usdoj.gov 
ON BEHALF OF THE DEFENDANT: 
JOHNNY L MCCRAY, JR., ESQ. 
Law Office of Johnny L. McCray, Jr, P.A.
400 East Atlantic Boulevard
Pompano Beach, Florida 33060
954-781-3662 
mccrayjlaw@gmail.com 
DARYL E. WILCOX, ESQ.
5201 Southwest 18th Street
Plantation, Florida 33317
954-303-1457 
darylewilcox06@gmail.com 
ALSO PRESENT:  Carolyn Wade 
               Hendrith V.A. Smith, paralegal 
               Agent Kelly DiPietrantonio 
Case 0:23-cr-60173-KMW   Document 139   Entered on FLSD Docket 08/28/2024   Page 2 of 35

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(Call to the Order of the Court.) 
* * * * * 
THE COURT:  Thank you very much.  
Once again, as the parties are well aware, the Court 
has to look at the evidence in the light most favorable to the 
Government.  That being the standard, the Court believes that 
there are questions of fact for the jury to decide and 
therefore the case will go to the jury for a resolution.  The 
motion is denied.  
Now, let's consider this issue which relates to 
witnesses who the defense asserts were precluded from 
testifying as a result of government threats and, of course, 
the issue that has to be decided is whether the Government's 
actions constituted substantial Government interference with 
the defense witnesses. 
And so as I understand it, there is no contact with 
the defendants directly.  There was contact with the witness's 
attorney.  Is that correct?  
MR. SNIDER:  That is correct.  The United States 
Government has had no contact with either one of these 
witnesses directly, not before this trial, not during this 
trial, not at any point.  I know the Court doesn't want to 
hear argument, but I think as a matter of law, I don't believe 
that the defense is even entitled to a hearing on this because 
I don't think as matter of law the Court could find that the 
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Government has done -- that there's been some intentional or 
malfeasant intrusion here.  Quite the contrary.  The 
Government believes it had an ethical obligation to make 
contact to these witnesses's attorney knowing that they were 
represented and knowing what the Government knows about their 
criminal exposure by virtue of, A, what had just been 
stipulated to and, B -- 
THE COURT:  What -- 
MR. SNIDER:  -- what had been stipulated to between 
the parties and what the Government had known through its 
investigation that these two witnesses have -- are de facto 
targets of a grand jury investigation.  They have not been 
formally notified as such, but the facts rise to that level. 
THE COURT:  Independent of this case?  
MR. SNIDER:  Well, I think what has come out during 
this case and what has now been stipulated to -- 
THE COURT:  I'm just saying -- 
MR. SNIDER:  Yes, it's both. 
THE COURT:  There was reference to 20 items and 
trying to turn -- 
MR. SNIDER:  Yes.  That's outside this case -- 
THE COURT:  -- relates to other matters as well; is 
that correct?  
MR. SNIDER:  Correct. 
THE COURT:  All right.  Who is the attorney for the 
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witnesses?  
MR. SNIDER:  The attorney's name is Lindsay Chase.  
And just so the record is crystal clear, okay, the -- I, as 
the lead prosecutor for this case, requested Ms. Chase -- I 
didn't have her name or contact information.  I requested the 
name and contact information for the attorney representing 
Haydee Granados and Eduardo Rivero last Friday before trial 
began. 
THE COURT:  Requested of whom?  
MR. SNIDER:  Of the defense.  I asked for the lawyers 
because I believed -- first of all, I wanted to know whether 
they were going to assert or not.  The Government has 
absolutely every right to know whether these witnesses 
intend on asserting their Fifth Amendment -- 
THE COURT:  What was the term -- you wanted to know 
whether they were going to what?  
MR. SNIDER:  Assert their Fifth Amendment.
THE COURT:  Assert.
MR. SNIDER:  -- assert their Fifth Amendment right 
not to incriminate themselves. 
THE COURT:  And you learned who the attorney -- 
MR. SNIDER:  And as I said, I believe under the 
justice manual that if the Government -- 
THE COURT:  All right.  I understand.  You learned 
that Ms. Chase was the attorney and you contacted Ms. Chase; 
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correct?  
MR. SNIDER:  Yesterday -- because I didn't get the 
contact information until yesterday. 
THE COURT:  Is Ms. Chase in the building?  In the 
courtroom?  Or -- 
MR. MCCRAY:  Yes.  She's out in the hallway. 
THE COURT:  All right.  Let's have Ms. Chase come in.  
Ms. Chase, would you come forward, please?  
MS. CHASE:  The witness stand?  
THE COURT:  Come forward to the podium. 
Good afternoon. 
MS. CHASE:  Good afternoon.
THE COURT:  Your name, please. 
MS. CHASE:  Lindsay Chase.
THE COURT:  And you are an attorney. 
MS. CHASE:  Yes, Your Honor. 
THE COURT:  And you are practicing in the South 
Florida area?  
MS. CHASE:  Yes, Your Honor. 
THE COURT:  In what specific area?  
MS. CHASE:  I practice in the tri-county area. 
THE COURT:  All right.  Now, it is my understanding 
that you represent some clients who were subpoenaed in this 
case; is that correct?  
MS. CHASE:  That is correct. 
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THE COURT:  And their names are?  
MS. CHASE:  Haydee Rivero and Eduardo Rivero.  I know 
that Haydee -- I think you have her maiden name. 
THE COURT:  Granados.  
MS. CHASE:  Yes. 
THE COURT:  Correct.  Very well.  
Now, it's my understanding that they were subpoenaed 
to testify in this case.  Is that accurate?  
MS. CHASE:  That's my understanding as well. 
THE COURT:  And -- 
MS. CHASE:  Well, I know that because I accepted 
their subpoena on their behalf, so yes. 
THE COURT:  All right.  And you obviously represent 
them in this action.  And it's my understanding that you 
received a phone call or -- I'm not sure what the method of 
communication was, but you were in touch with the Assistant US 
Attorney in this case; is that correct?  
MS. CHASE:  That is correct.  I received an email and 
then I followed up with a phone call. 
THE COURT:  And when did this occur?  
MS. CHASE:  I received the email yesterday. 
THE COURT:  And who did you speak with as a result of 
receiving the email?  
MS. CHASE:  I spoke to both of the assigned AUSAs in 
this case. 
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THE COURT:  Do you see them in the courtroom?  
MS. CHASE:  Well, I've never met them.
THE COURT:  All right.  Do you recall the names?  
MS. CHASE:  You're putting me on the spot, Your 
Honor, and I don't have an independent recollection of their 
names. 
THE COURT:  All right.  So -- 
MS. CHASE:  I think Mr. Snider was one of the last 
names and maybe something with a Z. 
THE COURT:  Something with a?  
MS. CHASE:  Z was the other last name. 
THE COURT:  V?  
MS. CHASE:  Z as in "zebra." 
THE COURT:  All right.  That's pretty close.  
So you spoke with both of these individuals via 
phone. 
MS. CHASE:  Yes.  We were on a three-way call.  
THE COURT:  And can you tell me -- 
MS. CHASE:  But -- sorry -- for clarification, 
sometimes it was just speaking to one state attorney and then 
other times it was -- sorry, not state -- AUSA and the other 
time it was both. 
THE COURT:  Can you give us the substance of the 
communication from the Assistant US Attorneys?  
MS. CHASE:  I can, Your Honor, but I'm in a little 
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bit of a bind because, as you know, I represent the two 
witnesses, and I don't think my conversations with the AUSA 
would be considered privileged information.  So I can go into 
that, but I do want to make the Court aware that I am a little 
concerned about other things later on. 
THE COURT:  And I am not -- and I will be very 
careful.  I am not intending to ask you about the substance of 
your communications with your clients.  I'm simply asking you 
now what the government attorneys related to you with 
reference to your clients.
MS. CHASE:  So, for clarification, you want me to 
discuss what the Government told me?  
THE COURT:  Yes.
MS. CHASE:  Okay.  The Government shared with me that 
they were in trial, that they asked me what was -- if my 
clients were planning on invoking their Fifth Amendment 
privilege and I said, "No, they were not planning on it."  
They proceeded to provide me some more -- and when I 
say they because I don't know these individuals, so I can't 
specify which individual told me what specifically -- and 
they're both males.  But they proceeded to give me some 
background information on the allegations in this matter.  
They told me about some of the evidence that had 
already been established in the court.  They had specifically 
told me about the stipulation that was made by both parties.  
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We discussed the IP address that was associated with my client 
Haydee Rivero.  They talked about Womply and how that program 
or -- whatever you want to call it -- would gather information 
and how that was sent out to other potential lenders.  
They told me about a subpoena that they had -- had 
done where they gathered some applications -- some PPP 
applications and told me that there was about 20 applications 
that came back and that these applications have ties to my 
client Haydee, how they -- how these individuals are either 
related by family or friends to my client Haydee.  
I proceeded to find out more about whether my clients 
were a target.  They told me that my client had moved from a 
witness to a subject but they are not a target of an 
investigation at this time.  They had shared with me -- sorry.  
I'm just thinking, Your Honor. 
THE COURT:  Yes.  
MS. CHASE:  They had told me about some transactions 
that my clients had -- like, they had received some Zelle 
payments and that the timing was very suspicious of the Zelle 
payments and that -- it was suspicious -- and that they also 
received a total of $10,000 from the Wades in general and that 
they believed that this was payment for -- they didn't call it 
like PPP document preparation but, like, that's kind of what I 
gathered from what they were concluding, but they didn't say 
they made that conclusion per se. 
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Pretty much that was it and just that my client, 
like, definitely had more connections to, like, preparing of 
PPP applications. 
THE COURT:  PP applications that included Ms. Wade as 
well as other individuals?  
MS. CHASE:  Correct.  The 20 that I had referenced 
earlier. 
THE COURT:  Now, as a result of that information, did 
you provide some advice to your clients?  
MS. CHASE:  I did, Your Honor. 
THE COURT:  And as a result of you having spoken to 
your clients, did your clients -- 
MS. CHASE:  And if I could just backtrack, Your 
Honor. 
THE COURT:  All right.
MS. CHASE:  I'm divulging everything, but I do want 
to preface this that there are certain things that I'm maybe 
not giving more detail on because I am concerned I may be 
breaching client-attorney privilege. 
THE COURT:  Well, I'm only asking you about what the 
Government communicated to you, not what you communicated to 
your clients -- so what your clients communicated to you.
MS. CHASE:  I understand but because it was a 
conversation and I shared certain things with them, they 
responded with certain things.  So that's why I'm saying that 
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I have divulged almost everything but I have not divulged 
everything because I'm concerned about -- sharing it would 
breach my confidentiality, but what I have shared -- because 
if I said something to the government about a conversation I 
had with my client and then they responded -- 
THE COURT:  Well, that, I don't want to inquire 
about.
MS. CHASE:  Okay. 
THE COURT:  I'm really only concentrating on what 
they said to you.
MS. CHASE:  Okay. 
THE COURT:  Now, you mentioned earlier that your 
clients had not intended to assert a Fifth Amendment 
privilege.  But after conversing with the Government, did that 
position change?  
MS. CHASE:  It did, Your Honor. 
THE COURT:  All right.  And did you participate in 
giving advice with regard to that change?  
MS. CHASE:  I did, Your Honor. 
THE COURT:  All right.  Counsel, any questions?
MR. SNIDER:  We've never met.  I'm David Snider.
MS. CHASE:  Hello. 
MR. SNIDER:  Nice to meet you.  
There were two phone calls yesterday, I believe, 
between myself and Ms. Chase, and I believe that Mr. Zacca was 
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on for both of them, although we did have some issues trying 
to do a three-way, but I think Mr. Zacca was on for both.  My 
outreach with Ms. Chase began with a voicemail and then an 
email and she responded to my email almost immediately saying, 
"I'm in a meeting and I'll call you back when I am free," 
which was -- and about an hour or so later, she did call back.  
I said, "Hello."  And at that point, I brought Mr. Zacca into 
the conversation.  
My first question after introducing myself as counsel 
of record for the United States in this case and stating that 
I understood from defense counsel that she was representing 
Haydee Granados and Mr. Rivero, I said, "I understand from 
defense counsel that they are under subpoena to appear in this 
case as defense witnesses."  
She confirmed that that was true.  And I said, "I 
have two questions for you.  Number one, are they going to 
appear?" -- because I wanted to prepare -- and "number two, if 
they do appear, are they going to invoke?"  That was my first 
two questions.  
And the responses were "Yes, they're going to appear 
and yes -- and yes, they plan to testify.  No, they do not 
plan to invoke their Fifth Amendment right."  And I said, 
"Okay."  And I said -- and then Ms. Chase volunteered.  She 
said -- I think I can share this -- "because they did nothing 
wrong."  And she said, "In fact, I think their testimony is 
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going to help the prosecution."  She said something to the 
effect of "I'm not sure why the defense is calling them 
because I think they're going to help the prosecution," which 
gave me pause, Judge, because testimony from these two, if 
they were to help the prosecution, I think -- to me, knowing 
what I know, I wasn't sure that Ms. Chase had truthful 
information upon which she was providing advice to her 
clients.  
So I said, "Let me confer with Mr. Zacca because I 
don't believe that you may have -- you know, you may not -- 
your clients may not be essentially giving you the full 
picture and you may be providing them ineffective advice 
because you don't have the full picture."  
I conferred with Zacca.  We hung up.  I said, "We 
will call you back."  I conferred with Mr. Zacca.  And then 
Mr. Zacca and I, upon discussing among ourselves and our 
office, concluded that we believed we had an obligation to 
advise Ms. Chase of some of at least the stipulated facts that 
had come out in this case, which was that this IP address 
belonging to her client and this money was directly 
attributable to her client.  
And the reason I felt that was necessary is because 
on the first conversation, Ms. Chase said to me that they were 
prepared to testify because, quote, Ms. Granados was not 
involved.  And when I heard that, I said, "Well, that -- 
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that's just inconsistent with what we know now to have even 
stipulated to."  So I felt an obligation to provide the 
additional facts that Ms. Chase had just described to the 
Court so that Ms. Chase was armed with information that she 
could then use to provide legal advice to her clients.  
Not once did I say you should do this, you should do 
that.  I said as crystal clear -- and I think she will 
corroborate this.  "You do with this as you see fit.  I just 
feel an obligation to provide this information because what 
you told me is inconsistent with what I know from, A, this 
trial and, B, our own investigation."  I felt ethically 
obligated to do that because she had two clients that were 
about to walk into this court and either provide testimony 
that wasn't true, which I have an obligation not to allow 
happen, or to incriminate themselves.  Because if they walked 
into this courtroom, Judge, and testified -- 
THE COURT:  I don't need to hear all of your -- 
MR. SNIDER:  That's the only thing I have to add 
about what happened, and Ms. Chase can either corroborate that 
or not. 
THE COURT:  Is that essentially -- 
MS. CHASE:  That is true, Your Honor, yes. 
THE COURT:  All right.  And your advice to your 
clients is that they assert their Fifth Amendment privilege?  
MS. CHASE:  That is correct, Your Honor.  And that is 
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their choice. 
THE COURT:  Yes.  
Anything further?  
MS. CHASE:  From me, Your Honor?  
THE COURT:  No, no.  I'm sorry.  I'm referring to -- 
MR. WILCOX:  Hello, Ms. Chase.  
I don't have anything for her, Your Honor. 
THE COURT:  All right. 
MR. WILCOX:  Wait a minute.  I do. 
Ms. Chase, prior to the phone call yesterday, did 
your clients receive a subpoena duces tecum?  
MS. CHASE:  Yes. 
MR. WILCOX:  And as a result of them receiving that 
subpoena duces tecum, what occurred?  
MS. CHASE:  As a result of receiving it, they 
contacted me and they -- sorry -- I'm, like, in an awkward 
position here.  They contacted me and we went to your 
office -- 
MR. WILCOX:  Not my office. 
MS. CHASE:  I apologize.  I went to your office. 
MR. WILCOX:  Would you say whose office?  The name. 
MS. CHASE:  Yes.  Mr. McCray's office.  And I told 
Mr. McCray that my clients have no items to provide.  Like, 
they cannot come -- we were -- we came -- 
MR. WILCOX:  Do you remember what your clients were 
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asked to bring?  
MS. CHASE:  I don't remember what the subpoena duces 
tecum said.  I can refresh my recollection, though.  According 
to the subpoena duces tecum -- I can pull it up on my phone, 
if necessary.  But I'm imagining it said something along the 
lines of documents related to PPP. 
MR. WILCOX:  May I lead, Your Honor?  
THE COURT:  Go right ahead, sir. 
MR. WILCOX:  Did the subpoena duces tecum ask them to 
bring documents related to PPP loan applications?  
MS. CHASE:  Yes, to the best of my recollection. 
MR. WILCOX:  And did the subpoena duces tecum ask 
them to bring documents related to PPP applications that they 
had filed for themselves as well as PPP loan applications that 
she had -- that they had assisted other people on?  
MS. CHASE:  I don't want to speak because I don't 
remember.  But I can refresh my recollection because I have a 
copy -- if I may, Your Honor, get my phone. 
Okay.  So the subpoena duces tecum required my client 
to bring all documents related to PPP loan applications for 
Carolyn Wade and yourself and/or Rivero Funeral Home and/or 
Rivero & Rivero Holdings, Inc.  That was for Edward -- Edward 
Rivero.  And for Haydee, it stated that she needed to provide 
all documents related to the PPP loan applications for Carolyn 
Wade and yourself and all documents related to the PPP loan 
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applications for Rivero & Rivero Holdings, Inc., or other.  
And all documents related to pay for services to Carolyn Wade. 
MR. WILCOX:  And did they have any -- and did they 
bring any of those documents to Mr. McCray's office?  
MS. CHASE:  No. 
MR. WILCOX:  And Mr. McCray had questioned them about 
their involvement in preparing an application for Ms. Wade?  
Did he question them about that?  
MS. CHASE:  Yes. 
MR. WILCOX:  And did they say that the only thing 
they did was give some advice but they didn't really prepare 
any applications?  
MS. CHASE:  I don't think that I can tell you what 
they said. 
MR. SNIDER:  Judge, I think this is outside the scope 
of the reason why they requested this hearing. 
THE COURT:  Have a seat, sir. 
She declined to answer that question. 
MR. WILCOX:  Excuse me?  
THE COURT:  She declined to respond to your question. 
MR. WILCOX:  I heard that, and she said it was a 
privilege because of attorney-client privilege, but the answer 
was given in the presence of people -- other people, Your 
Honor. 
MS. CHASE:  On my advice, though.  I don't feel 
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comfortable responding to it. 
MR. WILCOX:  Understood. 
Would it be fair to say that after you spoke with the 
Government that you had concerns about the accuracy of the 
information they provided to Mr. McCray when they were at 
Mr. McCray's office? 
MS. CHASE:  That is a fair assessment. 
MR. WILCOX:  Okay.  One moment.  And I'll ask it and 
you'll decide whether to answer it. 
Now, did your clients express to you any concerns 
after you relayed to them what you found out from the 
Government? 
THE COURT:  No, sir. 
MS. CHASE:  I can't. 
THE COURT:  I'm not going to allow that question. 
MR. WILCOX:  I knew that, Judge. 
THE COURT:  All right.  That's fine.  All right.  
MR. WILCOX:  Did you -- no, it's still -- did you 
ever represent to us that the clients were fearful?  Did you 
ever represent to Mr. McCray that your clients were fearful of 
testifying?  
MS. CHASE:  I don't think that I used that word that 
they were fearful.  I think the language that I said is that 
they're going to be invoking their Fifth Amendment right, and 
I put that in an email as well. 
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MR. WILCOX:  Did you suggest that -- did you suggest 
that the -- sorry.  Did you represent to Mr. McCray in the 
phone call yesterday that -- 
MS. CHASE:  I actually, like -- I mean, I did not 
suggest that they were fearful.  I just said that they were 
going to invoke their Fifth Amendment. 
MR. WILCOX:  Do you recall Mr. McCray asked you "Did 
the Government scare you?" or something like that and you 
said, "Pretty much"?  
MS. CHASE:  I recall him asking me if the Government 
scared -- I remember this conversation actually quite vividly 
because I didn't want to leave the impression that the 
Government scared me.  That's why I remember it vividly 
because I don't think that that -- I didn't want to leave you 
with that impression.  Yeah. 
MR. WILCOX:  But you remember answering that inquiry 
with "pretty much"?  
MS. CHASE:  I don't recall that, but I'm not saying 
that it couldn't be true.  I just don't recall it.  
MR. WILCOX:  All right. 
THE COURT:  All right.  Thank you. 
Anything further?  
MR. WILCOX:  Your Honor, I just want to make a couple 
of points -- 
THE COURT:  Well, now, I don't want to hear any 
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argument right now.  I'm going to excuse her and make some 
findings. 
MR. SNIDER:  I want to clarify.  
It is your memory of the conversation that I wasn't 
trying to do anything to you or your clients by way of 
intimidation.  Is that fair?  
MS. CHASE:  That's fair. 
MR. SNIDER:  That I was strictly -- did I say to 
you -- I believe I did -- but did I say that I believed I had 
an ethical obligation to make this disclosure?  
MS. CHASE:  You did. 
THE COURT:  All right.  Thank you. 
MS. CHASE:  And if I may, Your Honor.  Because I'm 
just a little concerned because I'm in a weird predicament 
right now because, as you know, I represent the victims but 
I'm also a witness in this case.  So I -- or I've been 
subpoenaed rather.  So I just don't know -- 
THE COURT:  Wait a minute.  You've been subpoenaed as 
a witness in this case?  
MS. CHASE:  Well, I was subpoenaed right now to be 
here. 
MR. SNIDER:  Not by the United States. 
MR. MCCRAY:  The defense had a subpoena served on her 
this morning.  Yes, the defense had a subpoena served on her 
this morning for purposes of testifying, if an evidentiary 
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hearing was granted, yes. 
THE COURT:  All right.  And so that's been 
accomplished.  
So you can step outside, and I'm going to have a 
conversation, and then I suspect you will be excused. 
MS. CHASE:  Okay.  Thank you, Your Honor. 
THE COURT:  All right.  Thank you.  
All right.  Based on the evidence, I don't see any 
improper governmental interference.  Frankly, based on what I 
have heard in the case, if the witnesses had taken the stand 
and questions had begun, I likely would have stopped the 
proceeding and advised them exactly as their counsel did, that 
you understand that you potentially have some liability and 
are you taking advantage of your Fifth Amendment privilege.  
And based upon what I have heard, there was certainly cause 
for these individuals to be concerned.  
In fact, that's the government's theory and, in fact, 
it's the defense's theory that they did it and not their 
clients.  So if there is a request to dismiss the case on that 
basis, that request is denied.  
Now, let's go further.  I want you to take a look at 
the instructions that you were given.  This is a draft.  So 
let's go through them seriatim and decide which ones should be 
given and which ones should not.  So on page 2, we have the 
duty to follow instructions and the presumption of innocence.  
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One instruction is applicable when the defendant testifies and 
when the defendant does not.  
So we have to give the instruction, the Eleventh 
Circuit pattern, where the defendant elects not to testify.  
Four, definition of reasonable doubt.  Five, consideration of 
direct and circumstantial evidence and argument of counsel.  
And by the way, if there are objections as we go through them, 
announce them.  These are, for the most part, Eleventh Circuit 
pattern instructions.  
Page 6, credibility of witnesses.  Page 7, 
impeachment of witnesses.  Page 8, note-taking.  I don't think 
that page 9, persons not on trial, is an appropriate 
instruction based on the status of the record at this time. 
MR. SNIDER:  I'm sorry.  You do not believe?  
THE COURT:  Do not.  
MR. SNIDER:  The Government believes that the 
testimony and the documents showing that others were involved 
and have not yet been charged -- for example, Granados -- 
would trigger the applicability of this instruction because I 
think what the evidence has shown -- and, in fact, I think 
both sides agree that Haydee Granados uploaded a fraudulent 
Schedule C. 
THE COURT:  And that's their position as well, by the 
way. 
MR. SNIDER:  Right.  And so the fact that she hasn't 
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been charged yet -- 
THE COURT:  Well, there's no evidence one way or the 
other.  This doesn't really relate to whether someone has been 
charged or not.  
What is the defense's position?  
MR. WILCOX:  We would object to that instruction, 
Your Honor. 
THE COURT:  All right.  I am not going to give the 
instruction on page 9, over objection. 
Page 10, introduction to offense instruction -- that 
should be offense instruction.  Page 11, the elements of wire 
fraud.  And 12.  Page 13, good faith defense.  I don't think 
there's any evidence that that instruction has been raised.  
I'll entertain some argument on that. 
MR. SNIDER:  The Government agrees that there's no 
foundation for this instruction. 
MR. WILCOX:  Your Honor, I believe the foundation was 
set by Ms. Wade's husband that he relayed to her -- so it was 
his testimony, as I recall it -- he relayed to her that he 
trusted -- 
THE COURT:  Government, have a seat, please.  Thank 
you. 
MR. WILCOX:  That he trusted -- 
THE COURT:  I'm going to ask you to move the 
microphone a little closer to you. 
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MR. WILCOX:  That he trusted Haydee -- I guess that's 
her -- correct pronunciation of her name -- Haydee Granados 
and Edward Rivero or Eduardo Rivero, they were longtime 
friends and that he trusted them to put the correct 
information in the PPP application and not put any fraudulent 
or false information in the PPP application.  And I think -- 
THE COURT:  But the problem is that -- this is an 
instruction that the defendant asserts, and there's no 
evidence that she held an opinion and honestly formed a belief 
in this case.  You're trying to do it by inference from 
Mr. Wade's testimony, and the Court holds that that's not 
sufficient to raise the good faith defense. 
MR. WILCOX:  Your Honor, I don't think we have to -- 
THE COURT:  I understand.  I understand your 
position.  I understand your position well, Mr. Wilcox.  
All right.  Summaries and summary testimony, page 14.  
There was some summary testimony presented.  Page 15, alibi.  
That doesn't seem to have been raised in this case. 
MR. MCCRAY:  It has been, Judge.  In fact, we asked 
this.  We submitted it back in April.  Judge, Exhibit 1 that's 
introduced without objection or through stipulation will show 
that on the dates in question -- the 28th and there were 
several other dates that were brought out that Ms. Wade was 
actually at work, eight hours, from 4:00 -- I mean, from 7:00 
in the morning until 4:00 in the evening.  
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She could not have been in some of the places that 
the Government was suggesting that she may have been -- at her 
house or at the funeral home.  She was at work.  And, Judge, 
we believe that if there's just a scintilla of evidence that 
supports our theory of the defense, we believe that the Court 
should allow us to have that alibi defense. 
THE COURT:  Well, the crime charged has a number of 
acts in it, and there are a number of acts that the evidence 
in the light most favorable to the government establishes that 
maybe something was done that was improper.  So you're picking 
one item out of a whole series of items.  
And so that wouldn't be sufficient on alibi.  Of 
course, you can argue that on this specific occasion that you 
just referenced that she could not have done what is alleged 
because she was at work, that's a perfectly fine argument, but 
not with regard to the defense of alibi. 
MR. MCCRAY:  Well, Judge, I just want the record to 
be clear and the Court to understand that we're not limiting 
it to just one date.  There was more than one date where it 
was alleged that Ms. -- alleged or suggested that Ms. Wade was 
somewhere other than at work.  And she was at work and those 
documents will support that. 
THE COURT:  And you may argue that point, of course. 
MR. MCCRAY:  Over our objection, Judge. 
THE COURT:  Of course. 
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Page 17, definition of knowingly.  Page 18, on or 
about a particular date.  Page 19, caution punishment.  
Page 20, duty to deliberate.  Page 21, an explanation of the 
verdict form. 
Did the parties submit a verdict form?  This verdict 
form would be rather simple.  Does the jury find beyond a 
reasonable doubt that the defendant committed the offense 
alleged in Count 1 of the indictment?  Is there anything other 
than that that you have submitted or will request?  
MR. SNIDER:  The Government submitted a proposed 
verdict form.  It was -- you know, this case was originally 
assigned to Judge Williams.  It was filed before the very 
first calendar call with Judge Williams either before or on 
that date. 
THE COURT:  All right.  We're going to pull the 
docket. 
MR. SNIDER:  And, in fact, I have it, if you would 
like. 
THE COURT:  If you have it, maybe that will be a 
little faster. 
MR. SNIDER:  May I hand it up?  
THE COURT:  Yes, sir. 
MR. SNIDER:  It's Docket Entry 32, page 27 of 27. 
THE COURT:  Any objection?  
MR. MCCRAY:  No, Judge.  I've reviewed it.  No 
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objection. 
THE COURT:  I'm sorry?  
MR. MCCRAY:  No objection from the defense.  We've 
reviewed it. 
THE COURT:  All right.  
Are there requests for additional instructions?  
MR. MCCRAY:  Not from the defense, Judge. 
MR. SNIDER:  Not from the Government.  
THE COURT:  How much time are you requesting for 
closing arguments?  
MR. SNIDER:  May I have an hour?  
THE COURT:  What does the defense request?  
MR. MCCRAY:  An hour would be good, Judge. 
THE COURT:  All right.  Is there a request for a 
notice at any time during the arguments as to time?  Because 
of course the procedure is Government, Defense, Government for 
any time remaining after having given the initial arguments.  
Sometimes lawyers ask for a notice.  Sometimes they do it with 
their phones, with themselves. 
MR. SNIDER:  Your Honor, I appreciate the offer.  I 
will take the Court up on it.  I would like to be notified 
when I have 20 minutes remaining of my hour, so I can reserve 
20 minutes for my rebuttal.  So maybe a notice at 40 minutes 
into my closing.  Thank you. 
THE COURT:  Defense?  
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MR. MCCRAY:  15 minutes, Judge. 
THE COURT:  All right.  Are there any additional 
matters we should address?  
MR. MCCRAY:  Not from the defense, Judge.  
MR. SNIDER:  I can't think of any at this time, 
Judge. 
THE COURT:  Very well.  I will see everyone Monday 
morning at 9:30.  Thank you all very much.  Have a nice 
weekend. 
(Proceedings concluded at 4:50 PM.) 
CERTIFICATE OF REPORTER 
I certify that the foregoing is a correct 
transcription of the record of proceedings in the 
above-entitled matter prepared from my stenotype notes.
DATE:  25th of August, 2024
/s/Lance W. Steinbeisser 
Lance W. Steinbeisser, 
FCRR, RPR, FPR-C
Official Court Reporter 
United States District Court
Southern District of Florida 
Miami, Florida 
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$
$10,000 [1] - 10:21
/
/s/Lance [1] - 29:15
1
1 [3] - 1:8, 25:20, 
27:8
10 [1] - 24:10
11 [1] - 24:11
12 [1] - 24:12
13 [1] - 24:12
14 [1] - 25:16
15 [2] - 25:17, 29:1
17 [2] - 1:5, 27:1
18 [1] - 27:1
18th [1] - 2:17
19 [1] - 27:2
2
2 [1] - 22:24
20 [6] - 4:19, 10:7, 
11:6, 27:3, 28:22, 
28:23
2024 [2] - 1:5, 29:15
21 [1] - 27:3
23-CR-60173 [1] - 1:2
25th [1] - 29:15
27 [2] - 27:23
28th [1] - 25:22
29 [1] - 1:8
3
305.523.5633 [1] - 
1:21
32 [1] - 27:23
33060 [1] - 2:14
33128 [1] - 1:20
33317 [1] - 2:17
33394 [2] - 2:5, 2:9
4
40 [1] - 28:23
400 [2] - 1:20, 2:13
4:00 [2] - 25:24, 
25:25
4:01 [1] - 1:6
4:50 [1] - 29:10
5
500 [2] - 2:4, 2:8
5201 [1] - 2:17
6
6 [1] - 23:10
7
7 [3] - 2:4, 2:8, 23:10
7:00 [1] - 25:24
8
8 [1] - 23:11
9
9 [2] - 23:12, 24:9
954-303-1457 [1] - 
2:18
954-660-5696 [1] - 
2:5
954-660-5789 [1] - 
2:9
954-781-3662 [1] - 
2:14
9:30 [1] - 29:8
9:49 [1] - 1:6
A
above-entitled [1] - 
29:14
absolutely [1] - 5:13
accepted [1] - 7:11
accomplished [1] - 
22:3
according [1] - 17:3
accuracy [1] - 19:4
accurate [1] - 7:8
action [1] - 7:14
actions [1] - 3:14
acts [2] - 26:8
add [1] - 15:18
additional [3] - 15:3, 
28:6, 29:2
address [3] - 10:1, 
14:19, 29:3
advantage [1] - 22:14
advice [8] - 11:9, 
12:18, 14:7, 14:12, 
15:5, 15:23, 18:11, 
18:25
advise [1] - 14:18
advised [1] - 22:12
afternoon [2] - 6:11, 
6:12
Agent [1] - 2:21
agree [1] - 23:21
agrees [1] - 24:15
ahead [1] - 17:8
aided [1] - 1:23
alibi [4] - 25:17, 26:6, 
26:12, 26:16
allegations [1] - 9:22
alleged [4] - 26:14, 
26:20, 27:8
allow [3] - 15:14, 
19:15, 26:6
almost [2] - 12:1, 
13:4
ALSO [1] - 2:20
AM [1] - 1:6
Amendment [10] - 
5:14, 5:17, 5:19, 
9:16, 12:13, 13:22, 
15:24, 19:24, 20:6, 
22:14
AMERICA [1] - 1:4
announce [1] - 23:8
answer [3] - 18:18, 
18:22, 19:9
answering [1] - 20:16
apologize [1] - 16:20
appear [4] - 13:13, 
13:17, 13:18, 13:20
APPEARANCES [1] - 
2:1
applicability [1] - 
23:19
applicable [1] - 23:1
application [3] - 
18:7, 25:5, 25:6
applications [13] - 
10:6, 10:7, 10:8, 
11:3, 11:4, 17:10, 
17:13, 17:14, 
17:20, 17:24, 18:1, 
18:12
appreciate [1] - 
28:20
appropriate [1] - 
23:12
April [1] - 25:20
area [3] - 6:18, 6:20, 
6:21
argue [2] - 26:13, 
26:23
argument [5] - 3:23, 
21:1, 23:6, 24:14, 
26:15
arguments [3] - 
28:10, 28:15, 28:17
armed [1] - 15:4
assert [6] - 5:12, 
5:17, 5:18, 5:19, 
12:13, 15:24
asserting [1] - 5:14
asserts [2] - 3:11, 
25:8
assessment [1] - 
19:7
assigned [2] - 7:24, 
27:12
Assistant [2] - 7:16, 
8:24
assisted [1] - 17:15
associated [1] - 10:1
Atlantic [1] - 2:13
attorney [10] - 3:18, 
4:4, 4:25, 5:6, 5:21, 
5:25, 6:15, 8:20, 
11:19, 18:22
Attorney [1] - 7:17
Attorney's [2] - 2:4, 
2:8
attorney's [1] - 5:2
attorney-client [1] - 
18:22
Attorneys [1] - 8:24
attorneys [1] - 9:9
attributable [1] - 
14:21
August [1] - 29:15
AUSA [4] - 2:3, 2:7, 
8:21, 9:2
AUSAs [1] - 7:24
Avenue [1] - 1:20
aware [2] - 3:4, 9:4
awkward [1] - 16:16
B
background [1] - 
9:22
backtrack [1] - 11:13
based [4] - 22:8, 
22:9, 22:15, 23:13
basis [1] - 22:20
Beach [1] - 2:14
BEFORE [1] - 1:12
began [2] - 5:8, 13:3
begun [1] - 22:11
behalf [1] - 7:12
BEHALF [1] - 2:11
belief [1] - 25:9
believes [3] - 3:6, 
4:3, 23:16
belonging [1] - 14:20
best [1] - 17:11
between [2] - 4:9, 
12:25
30
beyond [1] - 27:6
bind [1] - 9:1
bit [1] - 9:1
Boulevard [3] - 2:4, 
2:8, 2:13
breach [1] - 12:3
breaching [1] - 11:19
bring [5] - 17:1, 
17:10, 17:13, 
17:20, 18:4
brought [2] - 13:7, 
25:23
Broward [2] - 2:4, 2:8
building [1] - 6:4
C
calendar [1] - 27:13
cannot [1] - 16:24
careful [1] - 9:7
CAROLYN [1] - 1:7
Carolyn [4] - 2:20, 
17:21, 17:24, 18:2
case [19] - 3:8, 4:14, 
4:16, 4:21, 5:4, 
6:24, 7:8, 7:17, 
7:25, 13:10, 13:14, 
14:19, 21:16, 
21:19, 22:10, 
22:19, 25:10, 
25:18, 27:11
CASE [1] - 1:2
caution [1] - 27:2
certain [3] - 11:17, 
11:24, 11:25
certainly [1] - 22:15
CERTIFICATE [1] - 
29:11
certify [1] - 29:13
change [2] - 12:15, 
12:18
charged [4] - 23:18, 
24:1, 24:4, 26:7
Chase [3] - 5:2, 6:7, 
6:14
CHASE [60] - 6:9, 
6:12, 6:14, 6:16, 
6:19, 6:21, 6:25, 
7:2, 7:5, 7:9, 7:11, 
7:18, 7:21, 7:24, 
8:2, 8:4, 8:8, 8:11, 
8:13, 8:17, 8:19, 
8:25, 9:11, 9:14, 
10:17, 11:6, 11:10, 
11:13, 11:16, 
11:23, 12:8, 12:11, 
12:16, 12:19, 
12:22, 15:22, 
15:25, 16:4, 16:12, 
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16:15, 16:20, 
16:22, 17:2, 17:11, 
17:16, 18:5, 18:9, 
18:13, 18:25, 19:7, 
19:14, 19:22, 20:4, 
20:10, 20:18, 21:7, 
21:11, 21:13, 
21:20, 22:6
chase [16] - 5:4, 5:25, 
6:4, 6:8, 12:25, 
13:3, 13:23, 14:6, 
14:18, 14:23, 15:3, 
15:4, 15:19, 16:6, 
16:10
choice [1] - 16:1
Circuit [2] - 23:4, 
23:8
circumstantial [1] - 
23:6
clarification [2] - 
8:19, 9:11
clarify [1] - 21:3
clear [3] - 5:3, 15:7, 
26:18
client [11] - 10:1, 
10:9, 10:10, 10:12, 
11:1, 11:19, 12:5, 
14:20, 14:21, 
17:19, 18:22
client-attorney [1] - 
11:19
clients [25] - 6:23, 
9:8, 9:10, 9:16, 
10:11, 10:18, 11:9, 
11:12, 11:22, 
12:13, 14:8, 14:11, 
15:5, 15:12, 15:24, 
16:11, 16:23, 
16:25, 19:10, 
19:19, 19:20, 21:5, 
22:19
close [1] - 8:14
closer [1] - 24:25
closing [2] - 28:10, 
28:24
comfortable [1] - 
19:1
committed [1] - 27:7
communicated [3] - 
11:21, 11:22
communication [2] - 
7:16, 8:24
communications [1] 
- 9:8
computer [1] - 1:23
computer-aided [1] - 
1:23
concentrating [1] - 
12:9
concerned [5] - 9:5, 
11:18, 12:2, 21:14, 
22:16
concerns [2] - 19:4, 
19:10
concluded [2] - 
14:17, 29:10
concluding [1] - 
10:24
conclusion [1] - 
10:25
confer [1] - 14:9
conferred [2] - 14:14, 
14:15
confidentiality [1] - 
12:3
confirmed [1] - 13:15
connections [1] - 
11:2
consider [1] - 3:10
consideration [1] - 
23:5
considered [1] - 9:3
constituted [1] - 3:14
contact [7] - 3:16, 
3:17, 3:20, 4:4, 5:5, 
5:6, 6:3
contacted [3] - 5:25, 
16:16, 16:17
contrary [1] - 4:2
conversation [7] - 
11:24, 12:4, 13:8, 
14:23, 20:11, 21:4, 
22:5
conversations [1] - 
9:2
conversing [1] - 
12:14
copy [1] - 17:18
correct [15] - 3:18, 
3:19, 4:23, 4:24, 
6:1, 6:24, 6:25, 7:6, 
7:17, 7:18, 11:6, 
15:25, 25:2, 25:4, 
29:13
corroborate [2] - 
15:8, 15:19
counsel [6] - 12:20, 
13:9, 13:11, 13:13, 
22:12, 23:6
Count [1] - 27:8
county [1] - 6:21
couple [1] - 20:23
course [5] - 3:12, 
26:13, 26:23, 
26:25, 28:16
COURT [90] - 1:1, 
3:3, 4:8, 4:14, 4:17, 
4:19, 4:22, 4:25, 
5:9, 5:15, 5:18, 
5:21, 5:24, 6:4, 6:7, 
6:10, 6:13, 6:15, 
6:17, 6:20, 6:22, 
7:1, 7:4, 7:6, 7:10, 
7:13, 7:20, 7:22, 
8:1, 8:3, 8:7, 8:10, 
8:12, 8:14, 8:18, 
8:23, 9:6, 9:13, 
10:16, 11:4, 11:8, 
11:11, 11:15, 
11:20, 12:6, 12:9, 
12:12, 12:17, 
12:20, 15:17, 
15:21, 15:23, 16:2, 
16:5, 16:8, 17:8, 
18:17, 18:20, 
19:13, 19:15, 
19:17, 20:21, 
20:25, 21:12, 
21:18, 22:2, 22:7, 
23:15, 23:23, 24:2, 
24:8, 24:21, 24:24, 
25:7, 25:14, 26:7, 
26:23, 26:25, 
27:15, 27:19, 
27:22, 27:24, 28:2, 
28:5, 28:9, 28:12, 
28:14, 28:25, 29:2, 
29:7
court [2] - 9:24, 
15:13
Court [15] - 1:19, 
1:19, 3:1, 3:4, 3:6, 
3:22, 3:25, 9:4, 
15:4, 25:11, 26:5, 
26:18, 28:21, 
29:17, 29:17
courtroom [3] - 6:5, 
8:1, 15:16
credibility [1] - 23:10
crime [1] - 26:7
CRIMINAL [1] - 1:2
criminal [1] - 4:6
crystal [2] - 5:3, 15:7
D
DARYL [1] - 2:16
darylewilcox06@
gmail.com [1] - 
2:18
DATE [1] - 29:15
date [4] - 26:19, 27:2, 
27:14
dates [2] - 25:22, 
25:23
DAVID [1] - 2:3
David [1] - 12:21
david.snider@
usdoj.gov [1] - 2:6
de [1] - 4:11
decide [3] - 3:7, 19:9, 
22:23
decided [1] - 3:13
declined [2] - 18:18, 
18:20
DEFENDANT [1] - 
2:11
defendant [5] - 23:1, 
23:2, 23:4, 25:8, 
27:7
Defendant [1] - 1:8
defendants [1] - 3:17
Defense [1] - 28:16
defense [20] - 3:11, 
3:15, 3:24, 5:10, 
13:11, 13:13, 
13:14, 14:2, 21:23, 
21:24, 24:12, 
25:12, 26:5, 26:6, 
26:16, 28:3, 28:7, 
28:12, 28:25, 29:4
defense's [2] - 22:18, 
24:5
definitely [1] - 11:2
definition [2] - 23:5, 
27:1
deliberate [1] - 27:3
denied [2] - 3:9, 
22:20
DERIC [1] - 2:7
deric.zacca@usdoj.
gov [1] - 2:10
described [1] - 15:3
detail [1] - 11:18
DiPietrantonio [1] - 
2:21
direct [1] - 23:6
directly [3] - 3:17, 
3:21, 14:20
disclosure [1] - 
21:10
discuss [1] - 9:12
discussed [1] - 10:1
discussing [1] - 
14:16
dismiss [1] - 22:19
DISTRICT [3] - 1:1, 
1:1, 1:13
District [3] - 1:19, 
29:17, 29:18
DIVISION [1] - 1:2
divulged [2] - 12:1
divulging [1] - 11:16
docket [1] - 27:16
Docket [1] - 27:23
document [1] - 10:23
documents [10] - 
17:6, 17:10, 17:13, 
17:20, 17:24, 
31
17:25, 18:2, 18:4, 
23:17, 26:22
DONALD [1] - 1:12
done [4] - 4:1, 10:6, 
26:10, 26:14
doubt [2] - 23:5, 27:7
draft [1] - 22:22
duces [7] - 16:11, 
16:14, 17:2, 17:4, 
17:9, 17:12, 17:19
during [3] - 3:21, 
4:15, 28:15
duty [2] - 22:25, 27:3
E
East [3] - 2:4, 2:8, 
2:13
Eduardo [3] - 5:7, 
7:2, 25:3
Edward [3] - 17:22, 
25:3
effect [1] - 14:2
eight [1] - 25:24
either [5] - 3:20, 10:9, 
15:13, 15:19, 27:13
elects [1] - 23:4
elements [1] - 24:11
Eleventh [2] - 23:3, 
23:8
email [6] - 7:18, 7:21, 
7:23, 13:4, 19:25
entertain [1] - 24:14
entitled [2] - 3:24, 
29:14
Entry [1] - 27:23
ESQ [2] - 2:12, 2:16
essentially [2] - 
14:11, 15:21
established [1] - 9:24
establishes [1] - 26:9
ethical [2] - 4:3, 
21:10
ethically [1] - 15:11
evening [1] - 25:25
evidence [10] - 3:5, 
9:23, 22:8, 23:6, 
23:20, 24:2, 24:13, 
25:9, 26:4, 26:8
evidentiary [1] - 
21:25
exactly [1] - 22:12
example [1] - 23:18
EXCERPT [1] - 1:11
excuse [2] - 18:19, 
21:1
excused [1] - 22:5
Exhibit [1] - 25:20
explanation [1] - 
Case 0:23-cr-60173-KMW   Document 139   Entered on FLSD Docket 08/28/2024   Page 31 of 35

27:3
exposure [1] - 4:6
express [1] - 19:10
F
fact [8] - 3:7, 13:25, 
22:17, 23:20, 
23:25, 25:19, 27:17
facto [1] - 4:11
facts [3] - 4:13, 
14:18, 15:3
fair [4] - 19:3, 19:7, 
21:6, 21:7
faith [2] - 24:12, 
25:12
false [1] - 25:6
family [1] - 10:10
faster [1] - 27:20
favorable [2] - 3:5, 
26:9
FCRR [2] - 1:18, 
29:16
fearful [4] - 19:19, 
19:20, 19:23, 20:5
felt [3] - 14:22, 15:2, 
15:11
Fifth [10] - 5:14, 5:17, 
5:19, 9:16, 12:13, 
13:22, 15:24, 
19:24, 20:6, 22:14
filed [2] - 17:14, 
27:12
findings [1] - 21:2
fine [2] - 19:17, 26:15
first [5] - 5:11, 13:9, 
13:18, 14:23, 27:13
fit [1] - 15:8
five [1] - 23:5
Floor [2] - 2:4, 2:8
FLORIDA [1] - 1:1
Florida [9] - 1:4, 
1:20, 2:5, 2:9, 2:14, 
2:17, 6:18, 29:18, 
29:18
follow [1] - 22:25
followed [1] - 7:19
FOR [1] - 2:2
foregoing [1] - 29:13
form [4] - 27:4, 27:5, 
27:6, 27:11
formally [1] - 4:13
formed [1] - 25:9
Fort [2] - 2:5, 2:9
forward [2] - 6:8, 
6:10
foundation [2] - 
24:16, 24:17
four [1] - 23:5
FPR [2] - 1:18, 29:16
FPR-C [2] - 1:18, 
29:16
frankly [1] - 22:9
fraud [1] - 24:12
fraudulent [2] - 
23:21, 25:5
free [1] - 13:5
Friday [1] - 5:7
friends [2] - 10:10, 
25:4
full [2] - 14:11, 14:13
funeral [1] - 26:3
Funeral [1] - 17:21
G
gather [1] - 10:3
gathered [2] - 10:6, 
10:24
general [1] - 10:21
given [4] - 18:23, 
22:22, 22:24, 28:17
Government [25] - 
3:6, 3:14, 3:20, 4:1, 
4:3, 4:5, 4:10, 5:12, 
5:23, 9:12, 9:14, 
11:21, 12:14, 19:4, 
19:12, 20:8, 20:10, 
20:13, 23:16, 
24:15, 26:2, 27:10, 
28:8, 28:16
GOVERNMENT [1] - 
2:2
government [5] - 
3:12, 9:9, 12:4, 
24:21, 26:9
government's [1] - 
22:17
Government's [1] - 
3:13
governmental [1] - 
22:9
GRAHAM [2] - 1:2, 
1:12
Granados [7] - 5:7, 
7:4, 13:12, 14:24, 
23:18, 23:21, 25:2
grand [1] - 4:12
granted [1] - 22:1
guess [1] - 25:1
H
hallway [1] - 6:6
hand [1] - 27:21
Haydee [11] - 5:7, 
7:2, 7:3, 10:2, 10:9, 
10:10, 13:12, 
17:23, 23:21, 25:1, 
25:2
hear [3] - 3:23, 15:17, 
20:25
heard [4] - 14:25, 
18:21, 22:10, 22:15
HEARING [1] - 1:7
hearing [3] - 3:24, 
18:16, 22:1
HELD [1] - 1:12
held [1] - 25:9
hello [2] - 12:22, 16:6
Hello [1] - 13:7
help [3] - 14:1, 14:3, 
14:5
Hendrith [1] - 2:20
Holdings [2] - 17:22, 
18:1
holds [1] - 25:11
Home [1] - 17:21
home [1] - 26:3
honestly [1] - 25:9
Honor [23] - 6:16, 
6:19, 8:5, 8:25, 
10:15, 11:10, 
11:14, 12:16, 
12:19, 15:22, 
15:25, 16:4, 16:7, 
17:7, 17:18, 18:24, 
20:23, 21:13, 22:6, 
24:7, 24:17, 25:13, 
28:20
HONORABLE [1] - 
1:12
hour [4] - 13:6, 
28:11, 28:13, 28:22
hours [1] - 25:24
house [1] - 26:3
hung [1] - 14:14
husband [1] - 24:18
I
imagining [1] - 17:5
immediately [1] - 
13:4
impeachment [1] - 
23:11
impression [2] - 
20:12, 20:15
improper [2] - 22:9, 
26:10
Inc [2] - 17:22, 18:1
included [1] - 11:4
inconsistent [2] - 
15:1, 15:10
incriminate [2] - 
5:20, 15:15
independent [2] - 
4:14, 8:5
indictment [1] - 27:8
individual [1] - 9:20
individuals [5] - 8:15, 
9:19, 10:9, 11:5, 
22:16
ineffective [1] - 14:12
inference [1] - 25:10
information [13] - 
5:5, 5:6, 6:3, 9:3, 
9:22, 10:3, 11:8, 
14:7, 15:4, 15:9, 
19:5, 25:5, 25:6
initial [1] - 28:17
innocence [1] - 22:25
inquire [1] - 12:6
inquiry [1] - 20:16
instruction [11] - 
23:1, 23:3, 23:13, 
23:19, 24:6, 24:9, 
24:10, 24:11, 
24:13, 24:16, 25:8
instructions [4] - 
22:22, 22:25, 23:9, 
28:6
intend [1] - 5:14
intended [1] - 12:13
intending [1] - 9:7
intentional [1] - 4:1
interference [2] - 
3:14, 22:9
intimidation [1] - 
21:6
introduced [1] - 
25:21
introducing [1] - 13:9
introduction [1] - 
24:10
intrusion [1] - 4:2
investigation [4] - 
4:11, 4:12, 10:14, 
15:11
invoke [3] - 13:18, 
13:22, 20:6
invoking [2] - 9:16, 
19:24
involved [2] - 14:25, 
23:17
involvement [1] - 
18:7
IP [2] - 10:1, 14:19
issue [2] - 3:10, 3:13
issues [1] - 13:1
item [1] - 26:11
items [3] - 4:19, 
16:23, 26:11
32
J
JOHNNY [1] - 2:12
Johnny [1] - 2:13
JR [1] - 2:12
Jr [1] - 2:13
judge [2] - 18:15, 
25:20
JUDGE [1] - 1:13
Judge [15] - 14:4, 
15:16, 19:16, 
25:19, 26:3, 26:17, 
26:24, 27:12, 
27:13, 27:25, 28:7, 
28:13, 29:1, 29:4, 
29:6
jury [4] - 3:7, 3:8, 
4:12, 27:6
justice [1] - 5:23
K
Kelly [1] - 2:21
kind [1] - 10:23
knowing [3] - 4:4, 
4:5, 14:5
knowingly [1] - 27:1
known [1] - 4:10
knows [1] - 4:5
L
Lance [1] - 29:16
LANCE [1] - 1:18
language [1] - 19:23
last [3] - 5:7, 8:8, 
8:11
Lauderdale [2] - 2:5, 
2:9
law [2] - 3:23, 3:25
Law [1] - 2:13
lawyers [2] - 5:10, 
28:18
lead [2] - 5:4, 17:7
learned [2] - 5:21, 
5:24
least [1] - 14:18
leave [2] - 20:12, 
20:14
legal [1] - 15:5
lenders [1] - 10:4
level [1] - 4:13
liability [1] - 22:13
light [2] - 3:5, 26:9
likely [1] - 22:11
limiting [1] - 26:18
Lindsay [2] - 5:2, 
Case 0:23-cr-60173-KMW   Document 139   Entered on FLSD Docket 08/28/2024   Page 32 of 35

6:14
lines [1] - 17:6
loan [5] - 17:10, 
17:14, 17:20, 
17:24, 17:25
longtime [1] - 25:3
look [2] - 3:5, 22:21
M
maiden [1] - 7:3
males [1] - 9:21
malfeasant [1] - 4:2
manual [1] - 5:23
matter [4] - 3:23, 
3:25, 9:22, 29:14
matters [2] - 4:22, 
29:3
MCCRAY [12] - 2:12, 
6:6, 21:23, 25:19, 
26:17, 26:24, 
27:25, 28:3, 28:7, 
28:13, 29:1, 29:4
McCray [7] - 2:13, 
16:23, 18:6, 19:5, 
19:20, 20:2, 20:7
McCray's [3] - 16:22, 
18:4, 19:6
mccrayjlaw@gmail.
com [1] - 2:15
mean [2] - 20:4, 
25:24
mechanical [1] - 1:23
meet [1] - 12:23
meeting [1] - 13:5
memory [1] - 21:4
mentioned [1] - 
12:12
met [2] - 8:2, 12:21
method [1] - 7:15
Miami [4] - 1:4, 1:20, 
1:20, 29:18
microphone [1] - 
24:25
minute [2] - 16:9, 
21:18
minutes [4] - 28:22, 
28:23, 29:1
moment [1] - 19:8
Monday [1] - 29:7
money [1] - 14:20
morning [4] - 21:24, 
21:25, 25:25, 29:8
most [3] - 3:5, 23:8, 
26:9
motion [1] - 3:9
move [1] - 24:24
moved [1] - 10:12
MR [70] - 3:19, 4:9, 
4:15, 4:18, 4:21, 
4:24, 5:2, 5:10, 
5:17, 5:19, 5:22, 
6:2, 6:6, 12:21, 
12:23, 15:18, 16:6, 
16:9, 16:13, 16:19, 
16:21, 16:25, 17:7, 
17:9, 17:12, 18:3, 
18:6, 18:10, 18:15, 
18:19, 18:21, 19:2, 
19:8, 19:16, 19:18, 
20:1, 20:7, 20:16, 
20:20, 20:23, 21:3, 
21:8, 21:22, 21:23, 
23:14, 23:16, 
23:25, 24:6, 24:15, 
24:17, 24:23, 25:1, 
25:13, 25:19, 
26:17, 26:24, 
27:10, 27:17, 
27:21, 27:23, 
27:25, 28:3, 28:7, 
28:8, 28:11, 28:13, 
28:20, 29:1, 29:4, 
29:5
MS [60] - 6:9, 6:12, 
6:14, 6:16, 6:19, 
6:21, 6:25, 7:2, 7:5, 
7:9, 7:11, 7:18, 
7:21, 7:24, 8:2, 8:4, 
8:8, 8:11, 8:13, 
8:17, 8:19, 8:25, 
9:11, 9:14, 10:17, 
11:6, 11:10, 11:13, 
11:16, 11:23, 12:8, 
12:11, 12:16, 
12:19, 12:22, 
15:22, 15:25, 16:4, 
16:12, 16:15, 
16:20, 16:22, 17:2, 
17:11, 17:16, 18:5, 
18:9, 18:13, 18:25, 
19:7, 19:14, 19:22, 
20:4, 20:10, 20:18, 
21:7, 21:11, 21:13, 
21:20, 22:6
N
name [8] - 5:2, 5:5, 
5:6, 6:13, 7:3, 8:11, 
16:21, 25:2
names [4] - 7:1, 8:3, 
8:6, 8:9
necessary [2] - 
14:22, 17:5
need [1] - 15:17
needed [1] - 17:23
never [2] - 8:2, 12:21
nice [2] - 12:23, 29:8
NO [1] - 1:2
North [1] - 1:20
note [1] - 23:11
note-taking [1] - 
23:11
notes [1] - 29:14
nothing [1] - 13:24
notice [3] - 28:15, 
28:18, 28:23
notified [2] - 4:13, 
28:21
number [4] - 13:16, 
13:17, 26:7, 26:8
O
object [1] - 24:6
objection [6] - 24:9, 
25:21, 26:24, 
27:24, 28:1, 28:3
objections [1] - 23:7
obligated [1] - 15:12
obligation [6] - 4:3, 
14:17, 15:2, 15:9, 
15:14, 21:10
obviously [1] - 7:13
occasion [1] - 26:13
occur [1] - 7:20
occurred [1] - 16:14
OF [5] - 1:1, 1:4, 
1:11, 2:11, 29:11
offense [3] - 24:10, 
24:11, 27:7
offer [1] - 28:20
office [8] - 14:17, 
16:18, 16:19, 
16:20, 16:21, 
16:22, 18:4, 19:6
Office [3] - 2:4, 2:8, 
2:13
Official [2] - 1:19, 
29:17
ON [1] - 2:11
once [2] - 3:4, 15:6
one [10] - 3:20, 8:8, 
8:20, 13:16, 19:8, 
23:1, 24:2, 26:11, 
26:19
ones [2] - 22:23, 
22:24
opinion [1] - 25:9
Order [1] - 3:1
originally [1] - 27:11
ourselves [1] - 14:16
outreach [1] - 13:3
outside [3] - 4:21, 
18:15, 22:4
own [1] - 15:11
P
P.A [1] - 2:13
page [17] - 22:24, 
23:10, 23:11, 
23:12, 24:9, 24:10, 
24:11, 24:12, 
25:16, 25:17, 27:1, 
27:2, 27:3, 27:23
Pages [1] - 1:8
paralegal [1] - 2:20
part [1] - 23:8
participate [1] - 
12:17
particular [1] - 27:2
parties [4] - 3:4, 4:10, 
9:25, 27:5
pattern [2] - 23:4, 
23:9
pause [1] - 14:4
pay [1] - 18:2
payment [1] - 10:22
payments [2] - 10:19, 
10:20
people [3] - 17:15, 
18:23
per [1] - 10:25
perfectly [1] - 26:15
persons [1] - 23:12
phone [8] - 7:15, 
7:19, 8:16, 12:24, 
16:10, 17:4, 17:18, 
20:3
phones [1] - 28:19
picking [1] - 26:10
picture [2] - 14:12, 
14:13
places [1] - 26:1
Plaintiff [1] - 1:5
plan [2] - 13:21, 
13:22
planning [2] - 9:16, 
9:17
Plantation [1] - 2:17
PM [2] - 1:6, 29:10
podium [1] - 6:10
point [3] - 3:22, 13:7, 
26:23
points [1] - 20:24
Pompano [1] - 2:14
position [6] - 12:15, 
16:17, 23:23, 24:5, 
25:15
potential [1] - 10:4
potentially [1] - 
22:13
PP [1] - 11:4
PPP [12] - 10:6, 
10:23, 11:3, 17:6, 
33
17:10, 17:13, 
17:14, 17:20, 
17:24, 17:25, 25:5, 
25:6
practice [1] - 6:21
practicing [1] - 6:17
precluded [1] - 3:11
predicament [1] - 
21:14
preface [1] - 11:17
preparation [1] - 
10:23
prepare [2] - 13:17, 
18:11
prepared [2] - 14:24, 
29:14
preparing [2] - 11:2, 
18:7
presence [1] - 18:23
PRESENT [1] - 2:20
presented [1] - 25:17
presumption [1] - 
22:25
pretty [3] - 8:14, 11:1, 
20:17
Pretty [1] - 20:9
privilege [7] - 9:17, 
11:19, 12:14, 
15:24, 18:22, 22:14
privileged [1] - 9:3
problem [1] - 25:7
procedure [1] - 28:16
proceeded [3] - 9:18, 
9:21, 10:11
proceeding [1] - 
22:12
proceedings [1] - 
29:13
Proceedings [2] - 
1:23, 29:10
produced [1] - 1:23
program [1] - 10:2
pronunciation [1] - 
25:2
proposed [1] - 27:10
prosecution [3] - 
14:1, 14:3, 14:5
prosecutor [1] - 5:4
provide [8] - 9:18, 
11:9, 15:2, 15:5, 
15:9, 15:13, 16:23, 
17:23
provided [1] - 19:5
providing [2] - 14:7, 
14:12
pull [2] - 17:4, 27:15
punishment [1] - 
27:2
purposes [1] - 21:25
put [3] - 19:25, 25:4, 
Case 0:23-cr-60173-KMW   Document 139   Entered on FLSD Docket 08/28/2024   Page 33 of 35

25:5
putting [1] - 8:4
Q
questioned [1] - 18:6
questions [5] - 3:7, 
12:20, 13:16, 
13:19, 22:11
quite [2] - 4:2, 20:11
quote [1] - 14:24
R
raise [1] - 25:12
raised [2] - 24:13, 
25:18
rather [2] - 21:17, 
27:6
really [3] - 12:9, 
18:11, 24:3
reason [2] - 14:22, 
18:16
reasonable [2] - 
23:5, 27:7
rebuttal [1] - 28:23
receive [1] - 16:11
received [5] - 7:15, 
7:18, 7:21, 10:18, 
10:21
receiving [3] - 7:23, 
16:13, 16:15
recollection [4] - 8:5, 
17:3, 17:11, 17:17
record [5] - 5:3, 
13:10, 23:13, 
26:17, 29:13
recorded [1] - 1:23
reference [2] - 4:19, 
9:10
referenced [2] - 11:6, 
26:14
referring [1] - 16:5
refresh [2] - 17:3, 
17:17
regard [2] - 12:18, 
26:16
relate [1] - 24:3
related [9] - 9:9, 
10:10, 17:6, 17:10, 
17:13, 17:20, 
17:24, 17:25, 18:2
relates [2] - 3:10, 
4:22
relayed [3] - 19:11, 
24:18, 24:19
remaining [2] - 
28:17, 28:22
remember [6] - 
16:25, 17:2, 17:17, 
20:11, 20:13, 20:16
Reporter [2] - 1:19, 
29:17
REPORTER [1] - 
29:11
represent [7] - 6:23, 
7:13, 9:1, 19:19, 
19:20, 20:2, 21:15
represented [1] - 4:5
representing [2] - 
5:6, 13:11
request [5] - 22:19, 
22:20, 27:9, 28:12, 
28:14
requested [4] - 5:4, 
5:5, 5:9, 18:16
requesting [1] - 28:9
requests [1] - 28:6
required [1] - 17:19
reserve [1] - 28:22
resolution [1] - 3:8
respond [1] - 18:20
responded [3] - 
11:25, 12:5, 13:4
responding [1] - 19:1
responses [1] - 
13:20
result [6] - 3:12, 7:22, 
11:8, 11:11, 16:13, 
16:15
reviewed [2] - 27:25, 
28:4
rise [1] - 4:13
Rivero [13] - 5:7, 7:2, 
10:2, 13:12, 17:21, 
17:22, 17:23, 18:1, 
25:3
RPR [2] - 1:18, 29:16
S
scare [1] - 20:8
scared [2] - 20:11, 
20:13
Schedule [1] - 23:22
scintilla [1] - 26:4
scope [1] - 18:15
se [1] - 10:25
seat [2] - 18:17, 
24:21
see [4] - 8:1, 15:8, 
22:8, 29:7
seem [1] - 25:18
sent [1] - 10:4
seriatim [1] - 22:23
series [1] - 26:11
served [2] - 21:23, 
21:24
services [1] - 18:2
set [1] - 24:18
several [1] - 25:23
share [1] - 13:24
shared [4] - 9:14, 
10:14, 11:24, 12:3
sharing [1] - 12:2
show [1] - 25:21
showing [1] - 23:17
shown [1] - 23:20
sides [1] - 23:21
simple [1] - 27:6
simply [1] - 9:8
Smith [1] - 2:20
Snider [2] - 8:8, 
12:21
SNIDER [32] - 2:3, 
3:19, 4:9, 4:15, 
4:18, 4:21, 4:24, 
5:2, 5:10, 5:17, 
5:19, 5:22, 6:2, 
12:21, 12:23, 
15:18, 18:15, 21:3, 
21:8, 21:22, 23:14, 
23:16, 23:25, 
24:15, 27:10, 
27:17, 27:21, 
27:23, 28:8, 28:11, 
28:20, 29:5
someone [1] - 24:3
sometimes [3] - 8:20, 
28:18
somewhere [1] - 
26:21
sorry [8] - 8:19, 8:21, 
10:14, 16:5, 16:16, 
20:2, 23:14, 28:2
South [1] - 6:17
SOUTHERN [1] - 1:1
Southern [1] - 29:18
Southwest [1] - 2:17
speaking [1] - 8:20
specific [2] - 6:20, 
26:13
specifically [2] - 
9:20, 9:24
specify [1] - 9:20
spoken [1] - 11:11
spot [1] - 8:4
stand [2] - 6:9, 22:10
standard [1] - 3:6
state [2] - 8:20, 8:21
STATES [3] - 1:1, 
1:4, 1:13
States [7] - 1:19, 2:4, 
2:8, 3:19, 13:10, 
21:22, 29:17
stating [1] - 13:10
status [1] - 23:13
STEINBEISSER [1] - 
1:18
Steinbeisser [2] - 
29:15, 29:16
stenography [1] - 
1:23
stenotype [1] - 29:14
step [1] - 22:4
still [1] - 19:18
stipulated [5] - 4:7, 
4:9, 4:16, 14:18, 
15:2
stipulation [2] - 9:25, 
25:21
stopped [1] - 22:11
Street [1] - 2:17
strictly [1] - 21:8
subject [1] - 10:13
submit [1] - 27:5
submitted [3] - 
25:20, 27:9, 27:10
subpoena [12] - 7:12, 
10:5, 13:13, 16:11, 
16:14, 17:2, 17:4, 
17:9, 17:12, 17:19, 
21:23, 21:24
subpoenaed [5] - 
6:23, 7:7, 21:17, 
21:18, 21:20
substance [2] - 8:23, 
9:7
substantial [1] - 3:14
sufficient [2] - 25:12, 
26:12
suggest [3] - 20:1, 
20:5
suggested [1] - 
26:20
suggesting [1] - 26:2
summaries [1] - 
25:16
summary [2] - 25:16, 
25:17
support [1] - 26:22
supports [1] - 26:5
suspect [1] - 22:5
suspicious [2] - 
10:19, 10:20
T
target [2] - 10:12, 
10:13
targets [1] - 4:12
tecum [7] - 16:11, 
16:14, 17:3, 17:4, 
17:9, 17:12, 17:19
term [1] - 5:15
testified [1] - 15:16
34
testifies [1] - 23:1
testify [4] - 7:8, 
13:21, 14:24, 23:4
testifying [3] - 3:12, 
19:21, 21:25
testimony [8] - 13:25, 
14:4, 15:13, 23:17, 
24:19, 25:11, 
25:16, 25:17
THE [92] - 1:12, 2:2, 
2:11, 3:3, 4:8, 4:14, 
4:17, 4:19, 4:22, 
4:25, 5:9, 5:15, 
5:18, 5:21, 5:24, 
6:4, 6:7, 6:10, 6:13, 
6:15, 6:17, 6:20, 
6:22, 7:1, 7:4, 7:6, 
7:10, 7:13, 7:20, 
7:22, 8:1, 8:3, 8:7, 
8:10, 8:12, 8:14, 
8:18, 8:23, 9:6, 
9:13, 10:16, 11:4, 
11:8, 11:11, 11:15, 
11:20, 12:6, 12:9, 
12:12, 12:17, 
12:20, 15:17, 
15:21, 15:23, 16:2, 
16:5, 16:8, 17:8, 
18:17, 18:20, 
19:13, 19:15, 
19:17, 20:21, 
20:25, 21:12, 
21:18, 22:2, 22:7, 
23:15, 23:23, 24:2, 
24:8, 24:21, 24:24, 
25:7, 25:14, 26:7, 
26:23, 26:25, 
27:15, 27:19, 
27:22, 27:24, 28:2, 
28:5, 28:9, 28:12, 
28:14, 28:25, 29:2, 
29:7
themselves [4] - 
5:20, 15:15, 17:14, 
28:19
theory [3] - 22:17, 
22:18, 26:5
therefore [1] - 3:8
thinking [1] - 10:15
threats [1] - 3:12
three [2] - 8:17, 13:2
three-way [2] - 8:17, 
13:2
ties [1] - 10:8
timing [1] - 10:19
total [1] - 10:21
touch [1] - 7:16
transactions [1] - 
10:17
TRANSCRIPT [1] - 
Case 0:23-cr-60173-KMW   Document 139   Entered on FLSD Docket 08/28/2024   Page 34 of 35

1:11
transcript [1] - 1:23
transcription [2] - 
1:23, 29:13
tri [1] - 6:21
tri-county [1] - 6:21
trial [6] - 3:21, 3:22, 
5:7, 9:15, 15:11, 
23:12
TRIAL [2] - 1:7, 1:11
trigger [1] - 23:19
true [4] - 13:15, 
15:14, 15:22, 20:19
trusted [4] - 24:20, 
24:23, 25:1, 25:4
truthful [1] - 14:6
trying [4] - 4:20, 
13:1, 21:5, 25:10
turn [1] - 4:20
two [8] - 4:11, 9:1, 
12:24, 13:16, 
13:17, 13:19, 14:4, 
15:12
U
under [2] - 5:22, 
13:13
understood [2] - 
13:11, 19:2
UNITED [3] - 1:1, 1:4, 
1:13
United [7] - 1:19, 2:4, 
2:8, 3:19, 13:10, 
21:22, 29:17
up [5] - 7:19, 14:14, 
17:4, 27:21, 28:21
uploaded [1] - 23:21
US [2] - 7:16, 8:24
V
V.A [1] - 2:20
verdict [4] - 27:4, 
27:5, 27:11
via [1] - 8:15
victims [1] - 21:15
virtue [1] - 4:6
vividly [2] - 20:11, 
20:13
voicemail [1] - 13:3
volunteered [1] - 
13:23
vs [1] - 1:6
W
Wade [8] - 2:20, 11:4, 
35
17:21, 17:25, 18:2, 
18:7, 25:23, 26:20
WADE [1] - 1:7
Wade's [2] - 24:18, 
25:11
Wades [1] - 10:21
wait [2] - 16:9, 21:18
walk [1] - 15:13
walked [1] - 15:15
weekend [1] - 29:9
weird [1] - 21:14
whole [1] - 26:11
WILCOX [29] - 2:16, 
16:6, 16:9, 16:13, 
16:19, 16:21, 
16:25, 17:7, 17:9, 
17:12, 18:3, 18:6, 
18:10, 18:19, 
18:21, 19:2, 19:8, 
19:16, 19:18, 20:1, 
20:7, 20:16, 20:20, 
20:23, 24:6, 24:17, 
24:23, 25:1, 25:13
Wilcox [1] - 25:15
WILLIAMS [1] - 1:2
Williams [2] - 27:12, 
27:13
wire [1] - 24:11
WITHIN [1] - 1:7
witness [4] - 6:9, 
10:13, 21:16, 21:19
witness's [1] - 3:17
witnesses [11] - 3:11, 
3:15, 3:21, 4:11, 
5:1, 5:13, 9:2, 
13:14, 22:10, 
23:10, 23:11
witnesses's [1] - 4:4
Womply [1] - 10:2
word [1] - 19:22
Y
yesterday [6] - 6:2, 
6:3, 7:21, 12:24, 
16:10, 20:3
yourself [2] - 17:21, 
17:25
Z
Zacca [7] - 12:25, 
13:2, 13:7, 14:9, 
14:14, 14:15, 14:16
ZACCA [1] - 2:7
zebra [1] - 8:13
Zelle [2] - 10:18, 
10:19
Case 0:23-cr-60173-KMW   Document 139   Entered on FLSD Docket 08/28/2024   Page 35 of 35

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