Court filing
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.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Record facts
| Court | U.S. District Court for the Southern District of Florida |
|---|---|
| Filed | 2024-08-28 |
Cite this document
“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.Full text
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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
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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.
Case 0:23-cr-60173-KMW Document 139 Entered on FLSD Docket 08/28/2024 Page 26 of 35
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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
Case 0:23-cr-60173-KMW Document 139 Entered on FLSD Docket 08/28/2024 Page 29 of 35
$
$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
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7:00 [1] - 25:24
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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,
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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 35File and source
- File
- gov.uscourts.flsd.654266.139.0.pdf
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- 365,458 bytes
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- 553127403a809dc76a20da69215f6f5213f9a204afd7425e9c2b076a558bba7c
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