Transcript of Trial (May 21, 2024) — United States v. Carolyn D. Wade (Document 140)

Summary

Transcript of the May 21, 2024 trial day in United States v. Carolyn D. Wade, Case No. 23-CR-60173 in the U.S. District Court for the Southern District of Florida, before Donald L. Graham, United States District Judge, entered on the docket on 08/28/2024 as Document 140 (32 pages). The jury asked, "Does signing an application -- in parentheses -- PPP loan forgiveness, constitute knowingly agreeing to all of its contents?" The court said it cannot answer questions of fact and reread the Count 1 wire fraud instruction and the definition of knowingly. When the jury reported a deadlock, the court reread the duty to deliberate instruction; the Government asked for an Allen charge and the defense objected to it as a form of coercion. After a second deadlock note the court asked for one last attempt instead of the Allen charge, and on a third note it declared a mistrial.

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

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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 21, 2024
vs.
 
10:48 AM - 3:22 PM
CAROLYN D. WADE,
 
Defendant. 
Pages 1 to 32
____________________________________________________________
TRANSCRIPT 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 140   Entered on FLSD Docket 08/28/2024   Page 1 of 32

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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 
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 
ALSO PRESENT:  Carolyn Wade
Case 0:23-cr-60173-KMW   Document 140   Entered on FLSD Docket 08/28/2024   Page 2 of 32

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(Call to the Order of the Court.) 
THE COURT:  Good morning, everyone. 
MR. SNIDER:  Good morning. 
THE COURT:  I think you have before you a question 
that was submitted by the members of the jury, and it reads, 
"Does signing an application -- in parentheses -- PPP loan 
forgiveness, constitute knowingly agreeing to all of its 
contents?" 
That is an interesting question, but it is a question 
of fact.  And as you-all are aware, I cannot answer questions 
of fact.  It would appear that I will simply advise them of 
that and perhaps reread the wire fraud instruction, along with 
the definition of knowingly, and have them continue 
deliberating and, of course, to advise them that the 
instructions are to be read in conjunction with all of the 
other instructions that were given.  
So I'm interested in your comments.
MR. SNIDER:  Your Honor, I think that's an 
appropriate response to this question.  It does seem factual 
in nature.  And I think that it would help the jury to be 
reminded of both the instruction on wire fraud and knowingly 
because I think that that instruction explains what has to be 
done knowingly in this first scheme to defraud, which is to 
knowingly devise and participate in the scheme, not with 
respect to any particular piece of information.  
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The knowing element is to act knowingly, as far as 
the way I read it, devising and participating in this scheme.  
The only element in which knowingly is included is the first 
element.  And of course, there's a knowing element in the 
definition of intent to defraud. 
THE COURT:  Yes.  
Defense. 
MR. MCCRAY:  Judge, I agree that the jury needs to be 
told that it's the Government's burden to prove that Ms. Wade 
knowingly agreed to this document.  So I think that the 
instructions that the Court has proposed to read -- I think 
that would suffice. 
THE COURT:  All right.  I think I will have the jury 
come in and have them bring their copy of the instructions and 
to follow along with me as I reread the instructions.  
(Jury entered at 10:53 AM.) 
THE COURT:  Good morning. 
THE JURY:  Good morning. 
THE COURT:  We have received your communication.  
As you will recall, there are two judges in the 
courtroom at this time: a judge of the facts and a judge of 
the law.  I can tell you what the law is, but I cannot answer 
a question with respect to what the facts are.  So this is 
seemingly circular, right?  But we each have our role.  And as 
I advised, you have to follow the law whether you agree with 
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it or not.  And you as the judge of the facts have to decide 
what those facts are. 
What I can do is to attempt to assist you by 
rereading the wire fraud instruction and the definition of 
knowingly in conjunction with all of the other instructions 
which you have previously been given. 
I would request that you turn to page 9, and I want 
you to read along with me.  Our experience is that if you read 
and listen at the same time that the instructions are clearer.  
So let's see if we can do that. 
Count 1, as you know, charges a wire fraud in 
violation of Title 18, United States Code, Section 1343.  It 
is a federal crime to use interstate wire communications to 
carry out a scheme to defraud someone.  The defendant can be 
found guilty of this crime only if all the following facts are 
proved beyond a reasonable doubt:  One, the defendant 
knowingly devised or participated in a scheme to defraud 
someone by using false or fraudulent pretenses, 
representations, or promises. 
Two, the false pretenses, representations, or 
promises were about a material fact.  The defendant acted with 
the intent to defraud, number three, and four, the defendant 
transmitted or caused to be transmitted by wire some 
communication in interstate commerce to help carry out the 
scheme to defraud. 
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A scheme to defraud means any plan or course of 
action intended to deceive or cheat someone out of money or 
property by using false or fraudulent pretenses, 
representations, or promises.  A statement or representation 
is false or fraudulent if it is about a material fact that the 
speaker knows is untrue or makes with reckless indifference to 
the truth and makes with the intent to defraud.  A statement 
or representation may be false or fraudulent when it is a half 
truth or effectively conceals a material fact and is made with 
the intent to defraud. 
A material fact is an important fact that a 
reasonable person would use to decide whether to do or not do 
something.  A fact is material if it has the capacity or 
natural tendency to influence a person's decision.  It does 
not matter whether the decision-maker actually relied on the 
statement or knew or should have known that the statement was 
false.  To act with intent to defraud means to act knowingly 
and with the specific intent to use false or fraudulent 
pretenses, representations, or promises to cause loss or 
injury. 
Proving intent to deceive alone without the intent to 
cause loss or injury is not sufficient to prove intent to 
defraud.  The Government does not have to prove all the 
details alleged in the indictment about the precise nature and 
purpose of the scheme.  It also does not have to prove that 
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the material transmitted by interstate wire was itself false 
or fraudulent or that using the wire was intended as a 
specific or exclusive means of carrying out the alleged fraud 
or that the defendant personally made the transmissions over 
the wire.  And it does not have to prove that the alleged 
scheme actually succeeded in defrauding anyone. 
To use interstate wire communications is to act so 
that something would normally be sent through wire, radio, or 
television communications in the normal course of business.  
Each separate use of the interstate wire commissions as part 
of the scheme to defraud is a separate crime. 
Now, on page 12, the term knowingly is defined.  So 
when that term is used in the wire fraud instruction, the word 
knowingly means that an act was done voluntarily and 
intentionally and not because of mistake or by accident.  Now, 
these two instructions must be read in conjunction with all of 
the other instructions that you were given.  You shouldn't 
dwell on one particular instruction.  
Hopefully, this assists.  We understand how you would 
like me to really tell you what the facts are, which I am by 
law not allowed to do.  So thank you very much.  You may 
continue your deliberations. 
(Jury exited at 11:01 AM.) 
THE COURT:  Counsel, anything further at this time?  
MR. MCCRAY:  Not from the defense, Judge. 
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MR. SNIDER:  Not from the Government. 
THE COURT:  All right.  Thank you very much.  
(Recess from 11:02 AM to 11:49 AM.) 
THE COURT:  So the last communication reads, "The 
jury is at a deadlock," signed by Lenworth Dyer, which means 
that Mr. Dyer is the foreperson.  And he is in seat 
number three, the third seat from the left. 
So what I propose to do is to read the duty to 
deliberate instruction on page 15 and direct them to continue 
with their deliberations.  
Comment from counsel?  
MR. SNIDER:  That seems appropriate, Your Honor. 
MR. MCCRAY:  Judge, I would just object.  I -- I 
would just object.  I think the jury has made it clear to the 
Court that it's deadlocked.  To force them to go back, Judge, 
I think that that creates problems.  So I would respectfully 
object. 
THE COURT:  Well, they have not been deliberating an 
inordinate amount of time.  They started deliberating, I would 
say, after lunch yesterday, ending about 4:40, and they have 
been deliberating this morning since 9:30. 
So I am going to give the duty to deliberate 
instruction once again.  Now we need to consider what we do 
after that point in time and the question is whether I give 
the Allen charge or not.  I will make sure you receive a copy 
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of this Court's Instruction.  The Eleventh Circuit pattern is 
slightly different.  It talks about cost to the parties.  And 
frankly, it's this Court's opinion that cost to the parties is 
not an issue that ought to be considered in determining 
whether they should continue to deliberate or not.  We'll get 
you a copy of that.  This is in the eventuality that we get to 
this point. 
So you can take a look at it and you can give me your 
thoughts in the event we get to this stage.  
All right.  Bring the jury in, please.  
(Jury entered at 11:52 AM.) 
THE COURT:  Be seated, ladies and gentlemen.  We have 
to await the arrival of two more jurors, so we will do just 
that.  
Ladies and gentlemen, we have received your recent 
communication, so I have more law for you, and I want you to 
listen carefully.  It won't be necessary to read along with me 
since it is very short.  
Your verdict, whether guilty or not guilty, must be 
unanimous.  In other words, you must all agree.  Your 
deliberations are secret and you will never have to explain 
your verdict to anyone.  Each of you must decide the case for 
yourself but only after fully considering the evidence with 
the other jurors.  So you must discuss the case with one 
another and try to reach an agreement.  
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While you are discussing the case, do not hesitate to 
re-examine your own opinion and change your mind if you become 
convinced that you were wrong, but do not give up your honest 
beliefs just because others think differently or merely 
because you simply want to get the case over with. 
Remember that in a very real way you are judges, 
judges of the facts.  Your only interest is to seek the truth 
from the evidence in the case.  
Thank you very much.  You may be excused to continue 
with your deliberations.  
(Jury exited at 11:55 AM.) 
THE COURT:  I don't know if you've had an opportunity 
to take a look at the Allen charge.  Why don't you take a 
minute or so to review it and then we can discuss 
preliminarily what your thoughts are.  
All right.  Counsel, your preliminary thoughts. 
MR. SNIDER:  Your Honor, on behalf of the United 
States, the Government has no objection to the Court's 
supplemental instruction to the jury, which was just provided 
to the parties.  And if we get to the point where the deadlock 
continues, the Government would ask the Court to read this 
instruction.  
MR. MCCRAY:  Judge, as I indicated before, if we have 
to get to this point, I would be objecting to this Allen 
charge.  I think it's a form of coercion.  The jury has 
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already indicated that they are deadlocked.  If they come back 
saying it again, that they're deadlocked, you know, I think 
that in a sense this is basically forcing them to reach a 
verdict, so I would be opposed to it. 
THE COURT:  All right.  I understand.  As you, 
Counsel, are aware, this is an approved Eleventh Circuit 
instruction. 
MR. MCCRAY:  I'm keenly aware of it, Judge.  
THE COURT:  And so your argument, basically, is that 
it is an improper form of coercion. 
MR. MCCRAY:  That's correct, Judge.  That's my 
argument.  
THE COURT:  All right.  I have your positions.  Let's 
wait and see what happens. 
MR. SNIDER:  If the Court wants -- if we reach a 
point where this is -- where the Court needs to make a 
decision, the Government can supplement the Court with 
additional authority on the appropriateness of this charge 
from the Eleventh Circuit, if necessary. 
THE COURT:  Well, I'm always interested in your law.  
So if you have a case or two that you want me to review, I'm 
happy to consider it.  I've been doing this for quite a long 
time and it's the first time someone has told me about some 
laws.  Is there something new you have in mind or -- 
MR. SNIDER:  No.  I raise this issue sort of 
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contemporaneously with my office and I'm getting information 
that there may be cases supporting reading this.  That's all.  
And if the Court doesn't need to hear any argument, that's 
fine.  I just wanted to -- 
THE COURT:  If you can find something that's recent 
or instructive, I'm happy to take a look at it. 
MR. SNIDER:  Okay. 
THE COURT:  But generally, as I stated, the law is, 
this is a proper instruction. 
MR. SNIDER:  Yes. 
THE COURT:  The question is should I give the 
instruction.  And a lot of that, frankly, in my opinion, is 
dictated based on how long they've been deliberating.  At this 
stage, it has not been an inordinate amount of time.  But 
let's assume that at 5 o'clock today they tell us they're 
hopelessly deadlocked, then I have to make a decision.  That's 
a more difficult decision than at this stage of the 
proceeding. 
MR. SNIDER:  I would agree, Your Honor. 
THE COURT:  So let's wait and see what happens.  
MR. SNIDER:  Thank you, Judge.  
THE COURT:  Let me see what is happening with regard 
to ordering lunch and then I can tell you when you should be 
on call.  Should it be an hour from now or maybe you should 
just go downstairs to the cafeteria and be on call in 
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15 minutes. 
All right.  I understand that they are placing an 
order, which frankly means that their lunch is not going to 
arrive until 1 o'clock, approximately. 
MR. SNIDER:  Does the Court have a sentencing hearing 
at 1:00 PM today?  
THE COURT:  I do. 
MR. SNIDER:  Okay. 
THE COURT:  But the good news is that I have 
entertained all issues for that sentencing except for the 
pronouncement of a sentence.  So it won't take that long.  
And I actually haven't heard from the parties.  They 
wanted the actual pronouncement continued in order to 
determine if they could resolve the case that I tried with 
another case that is pending, and I don't know what the 
resolution of that is, but I'm proceeding today whether they 
have resolved the other case or not. 
So we haven't been informed as to the decision of 
counsel.  So that shouldn't interfere with any of our 
proceedings. 
MR. SNIDER:  Thank you, Judge. 
THE COURT:  All right.  Thank you all very much.  
Let's be on call at about 1:10.  
MR. MCCRAY:  I'll be on the 7th floor, Judge. 
THE COURT:  All right.  I think I mentioned there is 
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a conference room up on 14 as well.  I don't know if you've 
seen it.  It's a nice facility.  I don't think it's used very 
much, but that is an alternative.  Thank you. 
(Recess from 12:04 PM to 1:51 PM.) 
THE COURT:  We have received another communication 
which indicates the jury is still deadlocked.  So the question 
is whether the Court should present the Allen charge.  Did the 
Government find any recent cases?  Anything current, in this 
decade?  
MR. SNIDER:  The cases that the Government would rely 
on -- I don't think it's anything new -- one is from 2008 and 
one is from 2013 -- United States versus Woodard, 531 F.3d 
1352, upholding the Allen charge after the jury said it was 
deadlocked, and United States versus Bush, which was 727 F 
third 1308, which -- 
THE COURT:  You're throwing out cases.  Are you 
telling me you want me to read them?  
MR. SNIDER:  No, I was just telling the Court -- 
citing for the record. 
THE COURT:  All right. 
MR. SNIDER:  In that case, the jury hadn't even said 
they were deadlocked yet and the Court gave the charge and the 
Eleventh Circuit upheld it.  
THE COURT:  I am not a mind reader, but I have noted 
the anguish on the faces of the jury as I read the 
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instruction.  I'm not sure exactly what that means.  
Let me hear your positions regarding this one 
paragraph, keeping in mind that we have reread the duty to 
deliberate instruction.  And then on page 1, the last 
paragraph, "If a substantial majority of you are in favor of a 
conviction, those of you who disagree should reconsider.  If, 
on the other hand, a majority of an even smaller number of you 
are in favor of acquittal, the rest of you should ask 
yourselves whether you should accept that verdict."  
Then there's the paragraph -- you must also remember 
if the evidence fails to establish guilt beyond a reasonable 
doubt, the defendant must have your unanimous verdict of not 
guilty.  Again, I'll ask Mr. McCray to analyze those 
provisions for me as you would argue them. 
MR. MCCRAY:  Judge, it would be the defense's 
position that this language basically imposes undue coercion 
on the jury where it says if a substantial majority of your 
number are in favor, those of you who disagree should 
reconsider whether your doubt is a reasonable one. 
Judge, I think that language alone places an undue 
burden on those who may be in the substantial minority, and I 
believe it impinges upon the oath of the jury.  They have a 
duty to deliberate, and they've deliberated.  And they've 
indicated it twice that they are deadlocked.  One of the 
things the Court just pointed out -- and I noticed it when you 
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indicated the -- I guess the body language of some of the 
jurors.  
There is a case -- I believe it may have been the Ray 
case, which was cited in the Woodard case, which is the 
preeminent case out of the Eleventh Circuit.  The Eleventh 
Circuit said that the trial court is in a better position to 
observe the body language of sort of the jurors -- 
THE COURT:  Do you have that case with you?  Does it 
say the body language?  Can you pass it up if you have it?  If 
not, I can get it. 
MR. MCCRAY:  I have it in my computer, Judge, and I 
left it down at the seventh floor cafeteria. 
THE COURT:  Give us the cite. 
MR. MCCRAY:  Rey, Judge, is 811 F.2d 1453, which is 
an Eleventh Circuit 1987 case.  I believe it was that case. 
THE COURT:  All right.  I'm going to get a copy of 
it.  I would like to take a look at it.  
MR. MCCRAY:  Judge, do you mind if Ms. Wade goes down 
to get my computer real fast?  
THE COURT:  I can get a copy of the case in just a 
minute. 
MR. MCCRAY:  But there was another case, Judge, that 
was cited.  I didn't write that cite down.  It won't take but 
a second. 
THE COURT:  All right.  
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MR. MCCRAY:  Go ahead.  
(The Defendant exited the courtroom.)  
THE COURT:  I don't recall a case addressing body 
language.  That's why I'm kind of curious.  I want to take a 
look at the case to see what it states. 
MR. MCCRAY:  The functional equivalent of it was body 
language.  I'll get the case to you in a second.  
MR. SNIDER:  Your Honor, if the Court wants a copy of 
the case that I cited, I have it.  I provided a copy to 
defense counsel too.  
THE COURT:  Does the case just simply say it's the 
judge's call to make the decision or is it something more than 
that?  
MR. SNIDER:  I would -- yeah, that's essentially what 
it's saying.  And it was a similar case in that the jury had 
already told the Court that they were deadlocked, and then the 
Court gave the Allen charge after the second time they said 
they were deadlocked. 
(The Defendant re-entered the courtroom.)
MR. MCCRAY:  Yes, Judge, I have it.  It's a 2022 
case.  The cite, Judge, is -- 
THE COURT:  All right.  Hold on one second.  When 
lawyers come in, they just throw out cases and, like, I'm 
supposed to have considered it, so I'm going to have to take a 
look at it if there's something in particular you want me to 
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consider. 
MR. MCCRAY:  Sure, Judge.  I was giving you the cite 
of the case that talks about the jury's conduct -- the Court 
having observed the jury's conduct.  And that case is 
Rubinstein versus Yehuda, Y-E-H-U-D-A.  It's an Eleventh 
Circuit case found at 38 F.4th 982, and the relevant key 
number, Judge, is 20.  And I'm just citing the key number.  
What it says, it says, "When considering on appeal 
whether an Allen charge was impermissibly coercive, Court of 
Appeals is mindful that district judge watching the jury's 
file -- jurors" -- I just lost it.  Just a second, Judge. 
MR. SNIDER:  Is this a criminal or a civil case?  
MR. MCCRAY:  It's a RICO case. 
Here it is, Judge.  It says, "When considering on 
appeal whether an Allen charge was impermissibly coercive, 
Court of Appeals is mindful that the district judge watching 
the jurors file back into the courtroom and looking them in 
the eye can make a better judgment than an appellate court 
reading the cold record."  
In this case, the judge observed the jury's, I guess, 
behavior or conduct, specifically. 
MR. MCCRAY:  Judge, and this was a civil RICO case.  
THE COURT:  One moment, please.  
What's interesting is that the Rubinstein case cited 
by the defense is a relatively new case -- 2022.  And in this 
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case, the Eleventh Circuit states, "Whether an Allen charge is 
coercive depends on two things: the language of the charge and 
the totality of the circumstances under which it was 
delivered.  
"When considering whether an Allen charge was 
coercive, we're mindful that a district judge watching the 
jurors file back into the courtroom and looking them in the 
eye can make a better judgment than an appellate court reading 
the cold record." 
And then the court cites five circumstances that are 
relevant to the analysis: the total length of deliberations, 
the number of times the jury reported being deadlocked and was 
instructed to resume deliberations, whether the judge knew of 
the jury's numerical split -- and that, this Court is not 
aware of, and they didn't have an -- haven't indicated in a 
question and followed the Court's instruction in that regard 
not to reveal any numerical division -- "whether any of the 
instructions implied that the jurors were violating their oath 
or acting improperly by failing to reach a verdict and the 
time between the final supplemental instruction and the jury's 
verdict." 
What's interesting is that one of the factors is 
whether the Court knows what the split is.  Yes, our 
instructions tell them don't ever tell us your split.  So how 
would the Court consider that as a factor?  
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MR. SNIDER:  I think -- I think the guidance from 
these cases is not to inquire what the split is so we don't 
put any undue pressure or coercion on any one particular 
juror, if it is one person.  We don't know how many people it 
is.  So I think what the Eleventh Circuit is saying is don't 
ask -- don't inquire as to what any split might be.  
MR. MCCRAY:  Judge, and I agree with that.  In fact, 
in -- I believe it's the Woodard case and the Rey case, it 
talked about the Court not having polled the jury.  So that 
was not a factor to consider in determining whether or not the 
case should be reversed because it implied that holding the 
jury would not be proper. 
THE COURT:  Also interesting is that in United States 
versus Rey, the 1987 case, the panel held that they wouldn't 
follow the precedent and that they think the instruction is 
coercive, but they felt bound by the precedent of that panel.  
And now we have a 2022 case telling us to look at the body 
language, which is very unusual because body language doesn't 
mean anything.  Some people laugh when they're nervous.  Some 
people don't.  So what does body language mean?  
I'm going to make a suggestion and see what you-all 
think about this.  I am considering bringing them in and 
simply advising them to make one last attempt to reach a 
verdict, and if you can't do so, let us know.  And if you can 
reach some resolution considering the duty to deliberate, let 
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us know -- and leave it at that.  
Your thoughts?  
MR. SNIDER:  Well, Judge, my reaction to that is I 
think that that is pretty similar to the previously read -- 
THE COURT:  It is. 
MR. SNIDER:  -- duty to deliberate. 
THE COURT:  It is.  And, in fact, in some of the 
cases, they came back four times without an Allen charge. 
MR. SNIDER:  I'm sorry?  
THE COURT:  In the cases that you-all have submitted, 
the jury notified the judge on four occasions that they 
couldn't reach a verdict.  
MR. SNIDER:  Is the Court's suggestion that it 
provide that instruction that it just read to us instead of -- 
THE COURT:  I'm sorry.  I'm not -- the Court's 
suggestion is that it provide that instruction -- I mean, I'm 
just simply going to say make one last attempt. 
MR. SNIDER:  So is that the equivalent of the Allen 
charge?  
THE COURT:  No, it's not the Allen charge.  It's make 
one last attempt in consideration of your duty to deliberate 
that was previously read. 
MR. SNIDER:  Okay. 
THE COURT:  If you can reach a verdict, let us know.  
If you cannot reach a verdict, let us know.  There's no time 
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limit on when you make this decision. 
MR. SNIDER:  Okay.  The Court would not give an Allen 
charge past that point?  
THE COURT:  After that, I would not give an Allen 
charge. 
MR. SNIDER:  So the Government's position is that the 
Court give the Allen charge now that -- 
THE COURT:  I understand. 
MR. SNIDER:  -- it proposed.  That follows the model 
and a pattern Allen charge -- almost exactly -- it takes out 
language that I think is helpful to the defense which is -- I 
mean, it's helpful to take out that language about the cost to 
both sides.  I think that was some of the language that the 
Rey court had an issue with, and the Court has removed that 
from this proposed Allen charge.  
And in the Woodard case, the Eleventh Circuit 
commended the district court for doing that, for giving an 
Allen charge with consideration of some of the issues that had 
caused the Eleventh Circuit in Rey to have concerns and the -- 
and in Woodard, the Court affirmed the propriety of the Allen 
charge. 
THE COURT:  All right.  Mr. McCray. 
MR. MCCRAY:  Judge, on behalf of the defense, I would 
not be opposed to the procedure that the Court has suggested 
just moments ago in lieu of the Allen charge at this point. 
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THE COURT:  All right.  Let's bring the jury in.  
(Jury entered at 2:27 PM.) 
THE COURT:  Good afternoon again, ladies and 
gentlemen.  
We're going to ask that you take one last opportunity 
to see if you can reach a verdict.  I am not going to reread 
the duty to deliberate.  You may desire to do that.  But we're 
going to request that you take one last opportunity.  If you 
can reach a verdict, fine.  If you cannot reach a verdict, 
fine.  Just let us know.  There is no time limit.  We leave 
that decision up to you as the judge of the facts. 
Thank you.  
(Jury exited at 2:28 PM.) 
THE COURT:  I'll ask that you stay in around the 
area.  I suspect we're going to get a decision relatively 
quickly, but we don't know for sure.  So let's await our next 
message from the jury and we will proceed accordingly.  Thank 
you.  
(Recess at 2:29 PM.) 
(Proceedings resumed at 3:17 PM.)
THE COURT:  All right.  Ladies and gentlemen, we have 
received a communication indicating that the jury continues to 
be deadlocked.  So I am simply going to have them enter the 
courtroom and declare this case a mistrial and excuse them for 
the afternoon.  
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Any comment, Counsel?  
MR. MCCRAY:  Not from the defense, Judge. 
MR. SNIDER:  I think that the Government -- we asked 
for the Allen charge.  I think the Court overruled us.  I just 
wanted the record to be clear. 
THE COURT:  Of course.  I decided that it wasn't 
appropriate.  This is our third attempt.  And as I stated 
previously, I'm going to declare a mistrial. 
MR. SNIDER:  Very well.  
THE COURT:  Bring the jury in, please.
(Jury entered at 3:18 PM.) 
THE COURT:  We have received your last communication.  
Accordingly, I am deeming this case a mistrial, which means 
that the Government will have to decide how it wants to 
proceed hereafter. 
But I want to thank you for your service.  I know 
this was a very difficult decision, obviously, from your 
communications.  That's the beauty of our jury system.  The 
people decide.  And we appreciate you being here, carrying out 
your responsibility as a citizen.  I'm going to ask that you 
go into the jury room and I will excuse you permanently in a 
few moments.  Thank you.  
(Jury exited at 3:19 PM.) 
THE COURT:  The case of the United States of America 
versus Carolyn Denise Wade, Case Number 23-CR-60173-Williams 
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is deemed a mistrial.  
Thank you all very much for participating in this 
case.  You both represented your clients well.  If the agent 
was here, I would tell her to thank Government counsel, and 
I'm going to tell Ms. Wade to thank her counsel because they 
did a fabulous job.  Unfortunately, the jury was not able to 
decide the facts in this case. 
So I wish you all well.  I look forward to seeing you 
in our next case, counsel -- maybe not this case but another 
case, but we'll see how that develops.  
Anything further by the parties?  
MR. MCCRAY:  No, Judge. 
THE COURT:  Thank you all very much.  You are 
excused. 
MR. MCCRAY:  Judge, I'm sorry.  Ms. Wade just 
indicated to me that she's on pretrial.  So do I need an order 
or something having her -- 
THE COURT:  Well, we will be deeming the case a 
mistrial.  An order will be issued to that effect.  And so the 
same bond conditions that were in effect previously would 
remain in effect.  Were there any restrictions or...  
MR. MCCRAY:  No -- yes, but there's no problem.  We 
need to file -- 
THE COURT:  All right.  If there's some issue, you 
can file a motion. 
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MR. MCCRAY:  Thank you, Judge. 
THE COURT:  Thank you all.
(The proceedings concluded at 3:22 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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/
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24:8
deemed [1] - 25:1
deeming [2] - 24:13, 
25:18
DEFENDANT [1] - 
2:7
defendant [6] - 5:14, 
5:16, 5:21, 5:22, 
7:4, 15:12
Defendant [3] - 1:8, 
17:2, 17:19
defense [7] - 4:7, 
7:25, 17:10, 18:25, 
22:11, 22:23, 24:2
defense's [1] - 15:15
defined [1] - 7:12
definition [3] - 3:13, 
4:5, 5:4
defraud [12] - 3:23, 
4:5, 5:14, 5:17, 
5:22, 5:25, 6:1, 6:7, 
6:10, 6:17, 6:23, 
7:11
defrauding [1] - 7:6
deliberate [9] - 8:9, 
8:22, 9:5, 15:4, 
15:23, 20:25, 21:6, 
21:21, 23:7
deliberated [1] - 
15:23
deliberating [5] - 
3:14, 8:18, 8:19, 
8:21, 12:13
deliberations [6] - 
7:22, 8:10, 9:21, 
10:10, 19:11, 19:13
delivered [1] - 19:4
Denise [1] - 24:25
desire [1] - 23:7
details [1] - 6:24
determine [1] - 13:14
determining [2] - 9:4, 
20:10
develops [1] - 25:10
devise [1] - 3:24
devised [1] - 5:17
devising [1] - 4:2
dictated [1] - 12:13
different [1] - 9:2
differently [1] - 10:4
difficult [2] - 12:17, 
24:17
direct [1] - 8:9
disagree [2] - 15:6, 
15:18
discuss [2] - 9:24, 
10:14
discussing [1] - 10:1
DISTRICT [3] - 1:1, 
1:1, 1:13
district [4] - 18:10, 
18:16, 19:6, 22:17
District [3] - 1:19, 
26:10, 26:11
division [1] - 19:17
DIVISION [1] - 1:2
document [1] - 4:10
DONALD [1] - 1:12
done [2] - 3:23, 7:14
doubt [3] - 5:16, 
15:12, 15:19
down [3] - 16:12, 
28
16:18, 16:23
downstairs [1] - 
12:25
duty [8] - 8:8, 8:22, 
15:3, 15:23, 20:25, 
21:6, 21:21, 23:7
dwell [1] - 7:18
Dyer [2] - 8:5, 8:6
E
East [2] - 2:4, 2:9
effect [3] - 25:19, 
25:20, 25:21
effectively [1] - 6:9
element [4] - 4:1, 4:3, 
4:4
Eleventh [12] - 9:1, 
11:6, 11:19, 14:23, 
16:5, 16:15, 18:5, 
19:1, 20:5, 22:16, 
22:19
ending [1] - 8:20
enter [1] - 23:23
entered [5] - 4:16, 
9:11, 17:19, 23:2, 
24:11
entertained [1] - 
13:10
entitled [1] - 26:7
equivalent [2] - 17:6, 
21:18
ESQ [1] - 2:8
essentially [1] - 
17:14
establish [1] - 15:11
event [1] - 9:9
eventuality [1] - 9:6
evidence [3] - 9:23, 
10:8, 15:11
exactly [2] - 15:1, 
22:10
examine [1] - 10:2
except [1] - 13:10
exclusive [1] - 7:3
excuse [2] - 23:24, 
24:21
excused [2] - 10:9, 
25:14
exited [5] - 7:23, 
10:11, 17:2, 23:13, 
24:23
experience [1] - 5:8
explain [1] - 9:21
explains [1] - 3:22
eye [2] - 18:18, 19:8
Case 0:23-cr-60173-KMW   Document 140   Entered on FLSD Docket 08/28/2024   Page 28 of 32

F
F.2d [1] - 16:14
F.3d [1] - 14:12
F.4th [1] - 18:6
fabulous [1] - 25:6
faces [1] - 14:25
facility [1] - 14:2
fact [10] - 3:10, 3:11, 
5:21, 6:5, 6:9, 6:11, 
6:13, 20:7, 21:7
factor [2] - 19:25, 
20:10
factors [1] - 19:22
facts [9] - 4:21, 4:23, 
5:1, 5:2, 5:15, 7:20, 
10:7, 23:11, 25:7
factual [1] - 3:19
failing [1] - 19:19
fails [1] - 15:11
false [8] - 5:18, 5:20, 
6:3, 6:5, 6:8, 6:17, 
6:18, 7:1
far [1] - 4:1
fast [1] - 16:19
favor [3] - 15:5, 15:8, 
15:18
FCRR [2] - 1:18, 26:9
federal [1] - 5:13
felt [1] - 20:16
few [1] - 24:22
file [5] - 18:11, 18:17, 
19:7, 25:23, 25:25
final [1] - 19:20
fine [3] - 12:4, 23:9, 
23:10
first [3] - 3:23, 4:3, 
11:23
five [1] - 19:10
Floor [1] - 2:4
floor [2] - 13:24, 
16:12
FLORIDA [1] - 1:1
Florida [6] - 1:4, 
1:20, 2:5, 2:10, 
26:11, 26:11
follow [3] - 4:15, 
4:25, 20:15
followed [1] - 19:16
following [1] - 5:15
follows [1] - 22:9
FOR [1] - 2:2
force [1] - 8:15
forcing [1] - 11:3
foregoing [1] - 26:6
foreperson [1] - 8:6
forgiveness [1] - 3:7
form [2] - 10:25, 
11:10
Fort [1] - 2:5
forward [1] - 25:8
four [3] - 5:22, 21:8, 
21:11
FPR [2] - 1:18, 26:9
FPR-C [2] - 1:18, 
26:9
frankly [3] - 9:3, 
12:12, 13:3
fraud [6] - 3:12, 3:21, 
5:4, 5:11, 7:3, 7:13
fraudulent [6] - 5:18, 
6:3, 6:5, 6:8, 6:18, 
7:2
fully [1] - 9:23
functional [1] - 17:6
G
generally [1] - 12:8
gentlemen [4] - 9:12, 
9:15, 23:4, 23:21
given [3] - 3:16, 5:6, 
7:17
GOVERNMENT [1] - 
2:2
Government [10] - 
6:23, 8:1, 10:18, 
10:21, 11:17, 14:8, 
14:10, 24:3, 24:14, 
25:4
Government's [2] - 
4:9, 22:6
GRAHAM [2] - 1:2, 
1:12
guess [2] - 16:1, 
18:20
guidance [1] - 20:1
guilt [1] - 15:11
guilty [4] - 5:15, 9:19, 
15:13
H
half [1] - 6:8
hand [1] - 15:7
happy [2] - 11:22, 
12:6
hear [2] - 12:3, 15:2
heard [1] - 13:12
hearing [1] - 13:5
held [1] - 20:14
HELD [1] - 1:12
help [2] - 3:20, 5:24
helpful [2] - 22:11, 
22:12
hereafter [1] - 24:15
hesitate [1] - 10:1
hold [1] - 17:22
holding [1] - 20:11
honest [1] - 10:3
Honor [5] - 3:18, 
8:12, 10:17, 12:19, 
17:8
HONORABLE [1] - 
1:12
hopefully [1] - 7:19
hopelessly [1] - 
12:16
hour [1] - 12:24
I
impermissibly [2] - 
18:9, 18:15
impinges [1] - 15:22
implied [2] - 19:18, 
20:11
important [1] - 6:11
imposes [1] - 15:16
improper [1] - 11:10
improperly [1] - 
19:19
included [1] - 4:3
indicated [6] - 10:23, 
11:1, 15:24, 16:1, 
19:15, 25:16
indicates [1] - 14:6
indicating [1] - 23:22
indictment [1] - 6:24
indifference [1] - 6:6
influence [1] - 6:14
information [2] - 
3:25, 12:1
informed [1] - 13:18
injury [2] - 6:20, 6:22
inordinate [2] - 8:19, 
12:14
inquire [2] - 20:2, 
20:6
instead [1] - 21:14
instructed [1] - 19:13
instruction [20] - 
3:12, 3:21, 3:22, 
5:4, 7:13, 7:18, 8:9, 
8:23, 10:19, 10:22, 
11:7, 12:9, 12:12, 
15:1, 15:4, 19:16, 
19:20, 20:15, 
21:14, 21:16
Instruction [1] - 9:1
instructions [11] - 
3:15, 3:16, 4:11, 
4:14, 4:15, 5:5, 5:9, 
7:16, 7:17, 19:18, 
19:24
instructive [1] - 12:6
intended [2] - 6:2, 
7:2
intent [9] - 4:5, 5:22, 
6:7, 6:10, 6:17, 
6:18, 6:21, 6:22
intentionally [1] - 
7:15
interest [1] - 10:7
interested [2] - 3:17, 
11:20
interesting [4] - 3:9, 
18:24, 19:22, 20:13
interfere [1] - 13:19
interstate [5] - 5:13, 
5:24, 7:1, 7:7, 7:10
issue [4] - 9:4, 11:25, 
22:14, 25:24
issued [1] - 25:19
issues [2] - 13:10, 
22:18
itself [1] - 7:1
J
job [1] - 25:6
JOHNNY [1] - 2:8
Johnny [1] - 2:9
JR [1] - 2:8
Jr [1] - 2:9
JUDGE [1] - 1:13
judge [20] - 4:8, 4:21, 
5:1, 8:13, 10:23, 
15:15, 15:20, 
16:18, 18:10, 
18:16, 18:20, 
18:22, 19:6, 19:13, 
20:7, 21:11, 22:23, 
23:11, 25:15
Judge [20] - 7:25, 
8:15, 11:8, 11:11, 
12:21, 13:21, 
13:24, 16:11, 
16:14, 16:22, 
17:20, 17:21, 18:2, 
18:7, 18:11, 18:14, 
21:3, 24:2, 25:12, 
26:1
judge's [1] - 17:12
judges [3] - 4:20, 
10:6, 10:7
judgment [2] - 18:18, 
19:8
juror [1] - 20:4
jurors [8] - 9:13, 
9:24, 16:2, 16:7, 
18:11, 18:17, 19:7, 
19:18
JURY [1] - 4:18
jury [27] - 3:5, 3:20, 
29
4:8, 4:13, 8:5, 8:14, 
9:10, 10:19, 10:25, 
14:6, 14:13, 14:21, 
14:25, 15:17, 
15:22, 17:15, 
19:12, 20:9, 20:12, 
21:11, 23:1, 23:17, 
23:22, 24:10, 
24:18, 24:21, 25:6
Jury [8] - 4:16, 7:23, 
9:11, 10:11, 23:2, 
23:13, 24:11, 24:23
jury's [6] - 18:3, 18:4, 
18:10, 18:20, 
19:14, 19:20
K
keenly [1] - 11:8
keeping [1] - 15:3
key [2] - 18:6, 18:7
kind [1] - 17:4
knowing [2] - 4:1, 4:4
knowingly [13] - 3:7, 
3:13, 3:21, 3:23, 
3:24, 4:1, 4:3, 4:10, 
5:5, 5:17, 6:17, 
7:12, 7:14
known [1] - 6:16
knows [2] - 6:6, 
19:23
L
ladies [4] - 9:12, 
9:15, 23:3, 23:21
LANCE [1] - 1:18
Lance [1] - 26:9
language [14] - 
15:16, 15:20, 16:1, 
16:7, 16:9, 17:4, 
17:7, 19:2, 20:18, 
20:20, 22:11, 
22:12, 22:13
last [8] - 8:4, 15:4, 
20:23, 21:17, 
21:21, 23:5, 23:8, 
24:12
Lauderdale [1] - 2:5
laugh [1] - 20:19
law [7] - 4:22, 4:25, 
7:21, 9:16, 11:20, 
12:8
Law [1] - 2:9
laws [1] - 11:24
lawyers [1] - 17:23
leave [2] - 21:1, 23:10
left [2] - 8:7, 16:12
length [1] - 19:11
Case 0:23-cr-60173-KMW   Document 140   Entered on FLSD Docket 08/28/2024   Page 29 of 32

Lenworth [1] - 8:5
lieu [1] - 22:25
limit [2] - 22:1, 23:10
listen [2] - 5:9, 9:17
loan [1] - 3:6
look [8] - 9:8, 10:13, 
12:6, 16:17, 17:5, 
17:25, 20:17, 25:8
looking [2] - 18:17, 
19:7
loss [2] - 6:19, 6:22
lost [1] - 18:11
lunch [3] - 8:20, 
12:23, 13:3
M
majority [3] - 15:5, 
15:7, 15:17
maker [1] - 6:15
material [6] - 5:21, 
6:5, 6:9, 6:11, 6:13, 
7:1
matter [2] - 6:15, 
26:7
MCCRAY [26] - 2:8, 
4:8, 7:25, 8:13, 
10:23, 11:8, 11:11, 
13:24, 15:15, 
16:11, 16:14, 
16:18, 16:22, 17:1, 
17:6, 17:20, 18:2, 
18:13, 18:22, 20:7, 
22:23, 24:2, 25:12, 
25:15, 25:22, 26:1
McCray [3] - 2:9, 
15:13, 22:22
mccrayjlaw@gmail.
com [1] - 2:11
mean [4] - 20:19, 
20:20, 21:16, 22:12
means [8] - 6:1, 6:17, 
7:3, 7:14, 8:5, 13:3, 
15:1, 24:13
mechanical [1] - 1:23
members [1] - 3:5
mentioned [1] - 
13:25
merely [1] - 10:4
message [1] - 23:17
Miami [4] - 1:4, 1:20, 
1:20, 26:11
might [1] - 20:6
mind [5] - 10:2, 
11:24, 14:24, 15:3, 
16:18
mindful [3] - 18:10, 
18:16, 19:6
minority [1] - 15:21
minute [2] - 10:14, 
16:21
minutes [1] - 13:1
mistake [1] - 7:15
mistrial [5] - 23:24, 
24:8, 24:13, 25:1, 
25:19
model [1] - 22:9
moment [1] - 18:23
moments [2] - 22:25, 
24:22
money [1] - 6:2
morning [5] - 3:2, 
3:3, 4:17, 4:18, 
8:21
motion [1] - 25:25
MR [57] - 3:3, 3:18, 
4:8, 7:25, 8:1, 8:12, 
8:13, 10:17, 10:23, 
11:8, 11:11, 11:15, 
11:25, 12:7, 12:10, 
12:19, 12:21, 13:5, 
13:8, 13:21, 13:24, 
14:10, 14:18, 
14:21, 15:15, 
16:11, 16:14, 
16:18, 16:22, 17:1, 
17:6, 17:8, 17:14, 
17:20, 18:2, 18:12, 
18:13, 18:22, 20:1, 
20:7, 21:3, 21:6, 
21:9, 21:13, 21:18, 
21:23, 22:2, 22:6, 
22:9, 22:23, 24:2, 
24:3, 24:9, 25:12, 
25:15, 25:22, 26:1
must [7] - 7:16, 9:19, 
9:20, 9:22, 9:24, 
15:10, 15:12
N
natural [1] - 6:14
nature [2] - 3:20, 
6:24
necessary [2] - 9:17, 
11:19
need [4] - 8:23, 12:3, 
25:16, 25:23
needs [2] - 4:8, 11:16
nervous [1] - 20:19
never [1] - 9:21
new [3] - 11:24, 
14:11, 18:25
news [1] - 13:9
next [2] - 23:16, 25:9
nice [1] - 14:2
NO [1] - 1:2
normal [1] - 7:9
normally [1] - 7:8
North [1] - 1:20
noted [1] - 14:24
notes [1] - 26:7
noticed [1] - 15:25
notified [1] - 21:11
number [7] - 5:22, 
8:7, 15:7, 15:18, 
18:7, 19:12
Number [1] - 24:25
numerical [2] - 
19:14, 19:17
O
o'clock [2] - 12:15, 
13:4
oath [2] - 15:22, 
19:18
object [3] - 8:13, 
8:14, 8:17
objecting [1] - 10:24
objection [1] - 10:18
observe [1] - 16:7
observed [2] - 18:4, 
18:20
obviously [1] - 24:17
occasions [1] - 21:11
OF [5] - 1:1, 1:4, 
1:11, 2:7, 26:4
Office [2] - 2:4, 2:9
office [1] - 12:1
Official [2] - 1:19, 
26:10
ON [1] - 2:7
once [1] - 8:23
one [18] - 5:16, 7:18, 
9:24, 14:11, 14:12, 
15:2, 15:19, 15:24, 
17:22, 18:23, 
19:22, 20:3, 20:4, 
20:23, 21:17, 
21:21, 23:5, 23:8
opinion [3] - 9:3, 
10:2, 12:12
opportunity [3] - 
10:12, 23:5, 23:8
opposed [2] - 11:4, 
22:24
or.. [1] - 25:21
Order [1] - 3:1
order [4] - 13:3, 
13:13, 25:16, 25:19
ordering [1] - 12:23
ought [1] - 9:4
overruled [1] - 24:4
own [1] - 10:2
P
P.A [1] - 2:9
page [4] - 5:7, 7:12, 
8:9, 15:4
Pages [1] - 1:8
panel [2] - 20:14, 
20:16
paragraph [3] - 15:3, 
15:5, 15:10
parentheses [1] - 3:6
part [1] - 7:10
participate [1] - 3:24
participated [1] - 
5:17
participating [2] - 
4:2, 25:2
particular [4] - 3:25, 
7:18, 17:25, 20:3
parties [5] - 9:2, 9:3, 
10:20, 13:12, 25:11
pass [1] - 16:9
past [1] - 22:3
pattern [2] - 9:1, 
22:10
pending [1] - 13:15
people [4] - 20:4, 
20:19, 20:20, 24:19
perhaps [1] - 3:12
permanently [1] - 
24:21
person [2] - 6:12, 
20:4
person's [1] - 6:14
personally [1] - 7:4
piece [1] - 3:25
places [1] - 15:20
placing [1] - 13:2
Plaintiff [1] - 1:5
plan [1] - 6:1
PM [11] - 1:6, 13:6, 
14:4, 23:2, 23:13, 
23:19, 23:20, 
24:11, 24:23, 26:3
point [7] - 8:24, 9:7, 
10:20, 10:24, 
11:16, 22:3, 22:25
pointed [1] - 15:25
polled [1] - 20:9
Pompano [1] - 2:10
position [3] - 15:16, 
16:6, 22:6
positions [2] - 11:13, 
15:2
PPP [1] - 3:6
precedent [2] - 
20:15, 20:16
precise [1] - 6:24
preeminent [1] - 16:5
30
preliminarily [1] - 
10:15
preliminary [1] - 
10:16
prepared [1] - 26:7
present [1] - 14:7
PRESENT [1] - 2:12
pressure [1] - 20:3
pretenses [4] - 5:18, 
5:20, 6:3, 6:19
pretrial [1] - 25:16
pretty [1] - 21:4
previously [5] - 5:6, 
21:4, 21:22, 24:8, 
25:20
problem [1] - 25:22
problems [1] - 8:16
procedure [1] - 22:24
proceed [2] - 23:17, 
24:15
proceeding [2] - 
12:18, 13:16
Proceedings [2] - 
1:23, 23:20
proceedings [3] - 
13:20, 26:3, 26:6
produced [1] - 1:23
promises [4] - 5:19, 
5:21, 6:4, 6:19
pronouncement [2] - 
13:11, 13:13
proper [2] - 12:9, 
20:12
property [1] - 6:3
propose [1] - 8:8
proposed [3] - 4:11, 
22:9, 22:15
propriety [1] - 22:20
prove [5] - 4:9, 6:22, 
6:23, 6:25, 7:5
proved [1] - 5:16
provide [2] - 21:14, 
21:16
provided [2] - 10:19, 
17:9
proving [1] - 6:21
provisions [1] - 
15:14
purpose [1] - 6:25
put [1] - 20:3
Q
questions [1] - 3:10
quickly [1] - 23:16
quite [1] - 11:22
Case 0:23-cr-60173-KMW   Document 140   Entered on FLSD Docket 08/28/2024   Page 30 of 32

R
radio [1] - 7:8
raise [1] - 11:25
Ray [1] - 16:3
re [2] - 10:2, 17:19
re-entered [1] - 17:19
re-examine [1] - 10:2
reach [12] - 9:25, 
11:3, 11:15, 19:19, 
20:23, 20:25, 
21:12, 21:24, 
21:25, 23:6, 23:9
reaction [1] - 21:3
read [14] - 3:15, 4:2, 
4:11, 5:8, 7:16, 8:8, 
9:17, 10:21, 14:17, 
14:25, 21:4, 21:14, 
21:22
reader [1] - 14:24
reading [3] - 12:2, 
18:19, 19:8
reads [2] - 3:5, 8:4
real [2] - 10:6, 16:19
really [1] - 7:20
reasonable [4] - 
5:16, 6:12, 15:11, 
15:19
receive [1] - 8:25
received [5] - 4:19, 
9:15, 14:5, 23:22, 
24:12
recent [3] - 9:15, 
12:5, 14:8
Recess [3] - 8:3, 
14:4, 23:19
reckless [1] - 6:6
reconsider [2] - 15:6, 
15:19
record [5] - 14:19, 
18:19, 19:9, 24:5, 
26:6
recorded [1] - 1:23
regard [2] - 12:22, 
19:16
regarding [1] - 15:2
relatively [2] - 18:25, 
23:15
relevant [2] - 18:6, 
19:11
relied [1] - 6:15
rely [1] - 14:10
remain [1] - 25:21
remember [2] - 10:6, 
15:10
reminded [1] - 3:21
removed [1] - 22:14
reported [1] - 19:12
Reporter [2] - 1:19, 
26:10
REPORTER [1] - 
26:4
representation [2] - 
6:4, 6:8
representations [4] - 
5:19, 5:20, 6:4, 
6:19
represented [1] - 
25:3
request [2] - 5:7, 
23:8
reread [4] - 3:12, 
4:15, 15:3, 23:6
rereading [1] - 5:4
resolution [2] - 
13:16, 20:25
resolve [1] - 13:14
resolved [1] - 13:17
respect [2] - 3:25, 
4:23
respectfully [1] - 
8:16
response [1] - 3:19
responsibility [1] - 
24:20
rest [1] - 15:8
restrictions [1] - 
25:21
resume [1] - 19:13
resumed [1] - 23:20
reveal [1] - 19:17
reversed [1] - 20:11
review [2] - 10:14, 
11:21
Rey [5] - 16:14, 20:8, 
20:14, 22:14, 22:19
RICO [2] - 18:13, 
18:22
role [1] - 4:24
room [2] - 14:1, 
24:21
RPR [2] - 1:18, 26:9
Rubinstein [2] - 18:5, 
18:24
S
scheme [10] - 3:23, 
3:24, 4:2, 5:14, 
5:17, 5:25, 6:1, 
6:25, 7:6, 7:11
seat [2] - 8:6, 8:7
seated [1] - 9:12
second [5] - 16:24, 
17:7, 17:17, 17:22, 
18:11
secret [1] - 9:21
Section [1] - 5:12
see [8] - 5:10, 11:14, 
12:20, 12:22, 17:5, 
20:21, 23:6, 25:10
seeing [1] - 25:8
seek [1] - 10:7
seem [1] - 3:19
seemingly [1] - 4:24
sense [1] - 11:3
sent [1] - 7:8
sentence [1] - 13:11
sentencing [2] - 
13:5, 13:10
separate [2] - 7:10, 
7:11
service [1] - 24:16
seventh [1] - 16:12
short [1] - 9:18
sides [1] - 22:13
signed [1] - 8:5
signing [1] - 3:6
similar [2] - 17:15, 
21:4
simply [6] - 3:11, 
10:5, 17:11, 20:23, 
21:17, 23:23
slightly [1] - 9:2
smaller [1] - 15:7
SNIDER [33] - 2:3, 
3:3, 3:18, 8:1, 8:12, 
10:17, 11:15, 
11:25, 12:7, 12:10, 
12:19, 12:21, 13:5, 
13:8, 13:21, 14:10, 
14:18, 14:21, 17:8, 
17:14, 18:12, 20:1, 
21:3, 21:6, 21:9, 
21:13, 21:18, 
21:23, 22:2, 22:6, 
22:9, 24:3, 24:9
someone [4] - 5:14, 
5:18, 6:2, 11:23
sorry [3] - 21:9, 
21:15, 25:15
sort [2] - 11:25, 16:7
SOUTHERN [1] - 1:1
Southern [1] - 26:11
speaker [1] - 6:6
specific [2] - 6:18, 
7:3
specifically [1] - 
18:21
split [5] - 19:14, 
19:23, 19:24, 20:2, 
20:6
stage [3] - 9:9, 12:14, 
12:17
started [1] - 8:19
statement [4] - 6:4, 
6:7, 6:16
states [2] - 17:5, 19:1
STATES [3] - 1:1, 
1:4, 1:13
States [9] - 1:19, 2:4, 
5:12, 10:18, 14:12, 
14:14, 20:13, 
24:24, 26:10
stay [1] - 23:14
Steinbeisser [2] - 
26:8, 26:9
STEINBEISSER [1] - 
1:18
stenography [1] - 
1:23
stenotype [1] - 26:7
still [1] - 14:6
submitted [2] - 3:5, 
21:10
substantial [3] - 
15:5, 15:17, 15:21
succeeded [1] - 7:6
suffice [1] - 4:12
sufficient [1] - 6:22
suggested [1] - 
22:24
suggestion [3] - 
20:21, 21:13, 21:16
supplement [1] - 
11:17
supplemental [2] - 
10:19, 19:20
supporting [1] - 12:2
supposed [1] - 17:24
suspect [1] - 23:15
system [1] - 24:18
T
talks [2] - 9:2, 18:3
television [1] - 7:9
tendency [1] - 6:14
term [2] - 7:12, 7:13
THE [64] - 1:12, 2:2, 
2:7, 3:2, 3:4, 4:6, 
4:13, 4:17, 4:18, 
4:19, 7:24, 8:2, 8:4, 
8:18, 9:12, 10:12, 
11:5, 11:9, 11:13, 
11:20, 12:5, 12:8, 
12:11, 12:20, 
12:22, 13:7, 13:9, 
13:22, 13:25, 14:5, 
14:16, 14:20, 
14:24, 16:8, 16:13, 
16:16, 16:20, 
16:25, 17:3, 17:11, 
17:22, 18:23, 
20:13, 21:5, 21:7, 
21:10, 21:15, 
21:20, 21:24, 22:4, 
31
22:8, 22:22, 23:1, 
23:3, 23:14, 23:21, 
24:6, 24:10, 24:12, 
24:24, 25:13, 
25:18, 25:24, 26:2
they've [3] - 12:13, 
15:23
third [3] - 8:7, 14:15, 
24:7
thoughts [4] - 9:9, 
10:15, 10:16, 21:2
three [2] - 5:22, 8:7
throw [1] - 17:23
throwing [1] - 14:16
Title [1] - 5:12
today [3] - 12:15, 
13:6, 13:16
total [1] - 19:11
totality [1] - 19:3
TRANSCRIPT [1] - 
1:11
transcript [1] - 1:23
transcription [2] - 
1:23, 26:6
transmissions [1] - 
7:4
transmitted [3] - 
5:23, 7:1
TRIAL [1] - 1:11
trial [1] - 16:6
tried [1] - 13:14
truth [3] - 6:7, 6:9, 
10:7
try [1] - 9:25
turn [1] - 5:7
twice [1] - 15:24
two [6] - 4:20, 5:20, 
7:16, 9:13, 11:21, 
19:2
U
unanimous [2] - 
9:20, 15:12
under [1] - 19:3
undue [3] - 15:16, 
15:20, 20:3
unfortunately [1] - 
25:6
UNITED [3] - 1:1, 1:4, 
1:13
United [9] - 1:19, 2:4, 
5:12, 10:17, 14:12, 
14:14, 20:13, 
24:24, 26:10
untrue [1] - 6:6
unusual [1] - 20:18
up [4] - 10:3, 14:1, 
16:9, 23:11
Case 0:23-cr-60173-KMW   Document 140   Entered on FLSD Docket 08/28/2024   Page 31 of 32

32
upheld [1] - 14:23
upholding [1] - 14:13
V
verdict [14] - 9:19, 
9:22, 11:4, 15:9, 
15:12, 19:19, 
19:21, 20:24, 
21:12, 21:24, 
21:25, 23:6, 23:9
versus [5] - 14:12, 
14:14, 18:5, 20:14, 
24:25
violating [1] - 19:18
violation [1] - 5:12
voluntarily [1] - 7:14
vs [1] - 1:6
W
Wade [6] - 2:12, 4:9, 
16:18, 24:25, 25:5, 
25:15
WADE [1] - 1:7
wait [2] - 11:14, 
12:20
wants [3] - 11:15, 
17:8, 24:14
watching [3] - 18:10, 
18:16, 19:6
WILLIAMS [1] - 1:2
wire [13] - 3:12, 3:21, 
5:4, 5:11, 5:13, 
5:23, 7:1, 7:2, 7:5, 
7:7, 7:8, 7:10, 7:13
wish [1] - 25:8
Woodard [5] - 14:12, 
16:4, 20:8, 22:16, 
22:20
word [1] - 7:13
words [1] - 9:20
write [1] - 16:23
Y
Y-E-H-U-D-A [1] - 
18:5
Yehuda [1] - 18:5
yesterday [1] - 8:20
you-all [3] - 3:10, 
20:21, 21:10
yourself [1] - 9:23
yourselves [1] - 15:9
Case 0:23-cr-60173-KMW   Document 140   Entered on FLSD Docket 08/28/2024   Page 32 of 32

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