Court filing
Transcript, Testimony of Kelly DiPietrantonio (May 17, 2024) — United States v. Carolyn D. Wade (Document 111)
Summary
A trial transcript excerpt in United States v. Carolyn D. Wade, Case No. 23-CR-60173, in the U.S. District Court for the Southern District of Florida, recording the May 17, 2024 testimony of Kelly DiPietrantonio before Judge Donald L. Graham; it runs Pages 1 to 48 and was entered on the docket 07/25/2024 as Document 111. The judge notes that a defense pleading filed at 2 o'clock in the morning is unreviewed. On continued cross-examination, defense counsel Daryl E. Wilcox takes her through her summary of the evidence: transactions from an IP address ending in 166, a Womply communication asking Ms. Wade to complete her application, and login attempts to the Womply portal tied to Wade's PPP loan application. The witness agrees that Wade paid Haydee Granados about $5,000 around the time the PPP loan was funded, but believes it was for the Schedule C, not the full application.
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 | 2024-07-25 |
Cite this document
“Transcript, Testimony of Kelly DiPietrantonio (May 17, 2024) — United States v. Carolyn D. Wade (Document 111).”
U.S. District Court for the Southern District of Florida, No. 0:23-cr-60173-KMW, Doc. 111, filed 2024-07-25. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-wade-flsd-654267/2024-07-25-order-doc-111/
, SHA-256 d33535c9d7d8111131ca07bc785f2feb54a46a2f43bdd28d07c86565e16ffb1d.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.
TESTIMONY OF
KELLY DIPIETRANTONIO
CAROLYN D. WADE,
Defendant.
Pages 1 to 48
____________________________________________________________
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 111 Entered on FLSD Docket 07/25/2024 Page 1 of 48
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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
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 2 of 48
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(Call to the Order of the Court.)
THE COURT: Good morning. We are ready to proceed.
I mentioned to you yesterday if there were any issues
you had for the Court to let us know by 5 o'clock yesterday.
We did not receive anything by 5 o'clock.
I understand that a pleading was filed at 4 o'clock
this morning -- 2 o'clock this morning. I know it's a
surprise for you-all to understand that we don't wait around
looking for pleadings at 2 o'clock in the morning. So I
haven't reviewed the pleading, and we'll have to discuss it
during our next break.
MR. MCCRAY: Judge, there was a development yesterday
just before 4 o'clock PM, and we sent an email to your
chambers yesterday almost right after we found this situation
out.
THE COURT: What time was that?
MR. MCCRAY: It was about 4:20.
MR. WILCOX: Yes.
THE COURT: We didn't leave until 4:30.
MR. MCCRAY: What's that?
THE COURT: I said I left the bench yesterday. It
was about 4:35 or so.
MR. MCCRAY: We sent it before 5 o'clock. If the
Court would indulge me just for a minute.
THE COURT: Well, quickly, because I want to get the
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 3 of 48
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jury in. We can talk about this later. I can't resolve it
now anyway. It would be a good idea for me to read what you
have submitted.
MR. MCCRAY: That's fine.
THE COURT: Bring the jury in, please.
(Jury entered at 9:32 AM.)
THE COURT: Good morning. We are ready to continue
with the trial. I think I'm going to make you all my
permanent jurors. You're all on time the last few days and
that's very good. So you can call your employers and tell
them you will see them soon. We're going to pay you a big
salary.
All right. Are we ready?
MR. WILCOX: Yes, Your Honor.
THE COURT: All right. Please proceed.
I'd like to remind the witness that she is still
under oath.
THE WITNESS: Yes, Judge.
MR. WILCOX: Can we turn on the ELMO and have it
publish for everyone, please?
THE COURT: You'll note that the clock in the rear of
the courtroom is inaccurate. We think there's a battery
problem, so we won't be using that as the guide.
CROSS-EXAMINATION (CONTINUED)
BY MR. WILCOX:
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Q.
Good morning, Ms. DiPietrantonio.
A.
Good morning.
Q.
I want to direct your attention -- let me just fool with
the ELMO here a little bit. Turn your attention to page 2 of
the demonstrative aid, the summary of the evidence that you
prepared -- is that correct?
A.
Correct.
Q.
Okay. And on this particular page, you have the IP
address ending in 166. Okay. You show all the logins. You
show several logins from that IP address number; is that
correct?
A.
No, these are not logins. These are transactions.
Q.
Transactions. Okay. It says it right there up top.
Several transactions from IP address 166. And on page 4,
there is a communication from Womply asking Ms. Wade to hurry
up and complete her application; correct?
A.
Correct.
Q.
Now, on page 5, they have login attempts; is that right?
A.
Correct.
Q.
To the PPP application of Ms. Wade; correct?
A.
This is to the Womply portal.
Q.
To the Womply portal, but this still is associated with
the PPP loan application of Carolyn Wade. Am I wrong?
A.
No, that's correct.
Q.
Okay, okay.
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And two of these logins are from an IP address ending
in 125; is that right?
A.
That's correct.
Q.
Now, the IP address ending in 125 is not associated with
Carolyn Wade; correct?
A.
I don't believe so, no.
Q.
Okay. Well, have you investigated to whom that IP address
belongs to?
A.
I have an idea of who that IP address is associated to.
However, I never subpoenaed the Internet service provider for
the paid subscriber for that IP address.
Q.
Okay. Is there a reason why you did not subpoena the
subscriber for this -- for the location of this IP address?
A.
Because with other documents that I received, I was able
to determine who that IP address was associated to.
Q.
And who was that?
A.
Haydee Granados.
Q.
Okay. So the IP address ending in 125 is associated with
Haydee Granados. All right.
Now, I believe there has been evidence introduced in
the case where Ms. Wade paid Ms. Haydee Granados about $5,000
right around the time the PPP loan was funded; correct?
A.
Correct.
Q.
Okay. And the implication is that Ms. Wade paid
Ms. Granados to prepare the PPP loan application; correct?
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 6 of 48
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A.
I don't believe that she assisted in preparing the
application --
Q.
That's not what I asked you.
A.
So then my answer is no.
Q.
No. Okay. You don't believe -- you don't believe that
the $5,000 that were paid to Ms. Granados had anything to do
with the preparation of the PPP loan application?
A.
I believe it was just with the Schedule C, not the full
application.
Q.
Oh, the Schedule C -- the fake Schedule C.
A.
The Schedule C that was submitted with the PPP application
for Carolyn Wade.
Q.
Let me just see if I understand.
Are you saying that the payment to Ms. Granados was
associated with the inaccurate Schedule C that was filed with
this PPP loan application?
A.
Can you say that question again, please?
Q.
Are you testifying that the $5,000 that was paid to Haydee
Granados is associated with the fraudulent Schedule C that was
filed with this loan application?
A.
I believe so, yes.
Q.
Okay. I want to go to page 8 of your demonstrative aid.
In the first line -- can you see the first line?
A.
I can, yes.
Q.
Okay. Let me just zoom in on that a little bit. All
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 7 of 48
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right. So the date of this -- this page is entitled Womply
Events May 13, 2021; correct?
A.
Correct.
Q.
And one of the events was the uploading of a tax document;
correct?
A.
That's correct.
Q.
And that tax document was the fraudulent Schedule C; is
that correct?
A.
The Schedule C that was uploaded with the application,
correct.
Q.
The Government is saying that that is the lie that was
involved with this PPP loan application; correct?
A.
That Schedule C was never filed with the IRS, correct.
Q.
Okay. But the Government is saying that is the lie. I
mean, I heard him say it in opening statement --
THE COURT: One moment. Ask her questions, not
testify.
BY MR. WILCOX:
Q.
This Schedule C is the same Schedule C that the Government
in opening statement referred to as the lie that accompanied
the application for the PPP loan; is that right?
A.
That's correct.
Q.
Okay. And that application was uploaded by the IP address
ending in 125? Excuse me? I didn't hear you.
A.
Did you ask a question?
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 8 of 48
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Q.
Yes.
A.
What was the question?
Q.
This Schedule C -- the fraudulent one, the lie -- was
uploaded to Womply from the IP address ending in 125; correct?
A.
That's correct. It was.
Q.
And that IP address, you've testified, is associated with
Haydee Granados; correct?
A.
That's correct.
Q.
Okay. That Schedule C shows that the gross income for
Carolyn Wade's business was $113,000; correct?
A.
Correct.
Q.
Okay. Now, there was an IRS records custodian that
testified that Ms. Wade had filed two Schedule Cs with the
IRS; is that right?
A.
No, I think she only filed one Schedule C with the IRS.
Q.
Maybe we ought to -- what tax year would this Schedule C
reference? Do you remember?
A.
That was associated with the application?
Q.
Yes.
A.
2019.
Q.
2019, okay.
But she filed a Schedule C in 2019; is that right?
A.
Correct.
Q.
That the IRS is in possession of; right?
A.
Correct.
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 9 of 48
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Q.
Okay. And then there's another Schedule C for 133 that
shows that her business grossed $113,000 that was submitted
with this PPP loan application -- with her PPP loan
application; right?
A.
Correct.
Q.
From an IP address that ended in 125?
A.
Yes.
Q.
That you have testified belongs to Haydee Granados; right?
A.
Correct.
Q.
Okay. Now, before this indictment was filed, you
testified before the grand jury; correct?
A.
Correct.
Q.
And you testified as to the IP addresses that were
associated with the filing of the PPP loan application; is
that right? And when I say PPP loan application, I mean the
application that was filed on behalf of Ms. Wade.
A.
I don't remember if the IP addresses -- if I testified to
the IP addresses in the grand jury.
Q.
Well, let me see if I can refresh your recollection.
May I approach the witness, Your Honor?
THE COURT: Yes, sir.
MR. SNIDER: Go ahead.
THE WITNESS: Thank you.
THE COURT: Do you want to mark it for
identification?
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MR. WILCOX: I hadn't planned to introduce it into
evidence.
THE COURT: Well, if you're going to use it, you have
to mark it for identification. It's not received, but we have
to keep a record of what's happening in the trial.
MR. WILCOX: I'll have to figure out what number I
need to mark it as, Judge.
THE COURT: Well, you have a 1. It could be 2. We
have a 1 for identification only. It could be 2.
MR. WILCOX: All right, Your Honor.
I have a 3 that's already marked, Judge. Can I mark
it as 4?
THE COURT: Any mark you want. 4?
MR. WILCOX: Yes.
(Defense Exhibit 4 marked for identification.)
BY MR. WILCOX:
Q.
Agent DiPietrantonio, you're reviewing what's going to
be -- you have in your possession what's going to be marked as
defense exhibit for identification 4.
Would you please turn to page 19?
A.
Okay.
Q.
Just looked at it -- just look at page 19, toward the
bottom. And look at page 19 towards the top as well.
Okay. Did you make references to IP addresses in
your testimony before the grand jury?
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A.
I did, yes.
Q.
You did, okay.
And you made reference to IP address 107 -- sorry.
An IP address ending in 84; correct?
A.
Correct.
Q.
And there is no reference in your grand jury testimony to
the IP address ending in 125; correct?
A.
Correct.
Q.
Okay. Thank you.
MR. WILCOX: Your Honor, may I confer just a minute
with counsel?
BY MR. WILCOX:
Q.
Now, I believe yesterday we talked a little bit about the
DocuSign process, for lack of a better word. Now, I believe
that we were able to establish that just because the initials
CW appeared on a document that was DocuSigned does not
necessarily mean that CW is the person that DocuSigned -- that
actually executed the DocuSign; correct?
A.
That's correct.
Q.
Okay. So when we see these DocuSigned documents with the
initials CW, it doesn't necessarily mean that Carolyn Wade is
the person that executed the DocuSign document; is that
correct?
A.
That's correct.
Q.
And if one person has the DocuSign login information of
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 12 of 48
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another person, then that first person can DocuSign on behalf
of that other person; correct?
A.
No, that's not correct.
Q.
So if I had the DocuSign login information of an
individual and I had their login credentials, I could not
DocuSign on behalf of that individual?
A.
No.
Q.
Why not?
A.
Because when DocuSigns are sent to somebody, they're sent
to their email address on file. So even if you have their
DocuSign account, you have to have the email in order to be
able to sign the document in question.
Q.
I apologize.
If I had the DocuSign account and their email
address, then I could do it; correct?
A.
Correct.
Q.
I want to turn to the summary of your demonstrative aid.
This page 36 is titled Summary of Activity for Wade's PPP Loan
Application -- well, before I -- okay. I'll continue. Okay.
Now, you have -- in line 2 -- the second line here --
do you see where my finger is pointing?
A.
The third line?
Q.
Yes, the third line. That's right. Okay. I'm going to
go back to the first line, but right now I just want to focus
on the third line. You show that there were five logins from
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Verizon IP addresses 184, 224, 171 -- I'm sorry. Excuse me.
I need to start over -- IP addresses ending in 184, 224, 127,
200 while Ms. Wade was a Verizon customer; correct?
A.
Correct.
Q.
There's no reference in this summary as to how many events
or logins came from the IP address ending in 125; is that
correct?
A.
That's correct.
Q.
And going to the number of transactions, I just want to
make sure. We have a number of Womply transactions from IP
address ending in 184, IP address ending in 224, IP address
ending in 127, and IP address ending in 200.
You don't have any reference to Womply events coming
from IP address ending in 125, which is Haydee Granados's IP
address; right?
A.
Not in that line, that's correct.
Q.
Okay. Now, I'm going to go back and ask you a question
about DocuSign.
When you DocuSign a document or when you execute a
DocuSign on a document or -- I don't know if I'm phrasing that
correctly, but I think you understand what I'm saying -- it
prompts you; right?
A.
For where to sign?
Q.
Yes.
A.
Correct.
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Q.
Okay. It prompts you for where to sign. And when it
prompts you for where to sign, the entire document is not
visible; correct?
A.
No, I don't believe that's correct.
Q.
You don't?
A.
No. I think you see exactly what you're signing.
Q.
I know you see exactly what you're signing, but I'm saying
the prompt, okay -- there's words after the prompt, okay, and
there's a prompt showing you where to sign; right?
A.
Correct.
Q.
And then there's a paragraph or something next to the
place where you're supposed to sign; right?
A.
It's what you're attesting to with that signature or
initial, yes.
Q.
Okay. But it doesn't show the entirety of the document?
A.
You do have the option to see the entire document.
Q.
You have the option. But when you're signing, the
entirety of the document is not visible?
A.
No, I believe it is.
Q.
You believe it is. You're not sure, though?
A.
I'm not a hundred percent sure. I am a hundred percent
sure --
Q.
That's enough.
A.
-- that DocuSign sends you the entire application upon
signing.
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Q.
Maybe you don't understand the point I'm trying to make.
Let me see if I can be a little clearer. Okay.
When the DocuSign program prompts you to put your
initials next to whatever wording is next to it, the entire
document is not visible at that instant?
A.
No, I believe that it is.
Q.
You believe that it is, okay.
Now, as part of the investigation, you issued a
subpoena to Womply -- one moment, Your Honor. I'm going to
have to mark it.
MR. SNIDER: Are you seeking to enter this into
evidence?
MR. WILCOX: No.
MR. SNIDER: I think there's nothing -- there's no
foundation to refresh her recollection.
MR. WILCOX: May I approach the witness, Your Honor?
THE COURT: Yes, sir.
MR. SNIDER: You can show it to her.
MR. WILCOX: Okay.
(Defense Exhibit 5 marked for identification.)
BY MR. WILCOX:
Q.
I'm showing you what's been marked as Defense Exhibit 5
for identification. Do you recognize that?
A.
I do, yes.
Q.
What is it?
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A.
This is the subpoena I served --
MR. SNIDER: Objection.
THE COURT: Bring the document sidebar, please.
(The following proceedings were held sidebar:)
THE COURT: May I see the exhibit?
MR. WILCOX: I thought you had it.
MR. SNIDER: You gave it to the witness.
MR. WILCOX: Oh, I'm sorry.
THE COURT: All right.
MR. SNIDER: My objection is she's reading a document
that is not in evidence --
THE COURT: Well, she hasn't read it yet.
MR. SNIDER: She was about to; that's why I objected.
THE COURT: I'm sorry?
MR. SNIDER: I think the question was for her to read
it, which is why I objected.
THE COURT: Did you ask her to read it?
MR. WILCOX: No, I asked her did she recognize it.
THE COURT: She said yes. Okay. And then there's an
objection.
MR. ZACCA: I think the next --
THE COURT: Listen, only one at a time.
MR. SNIDER: Sorry. My objection is -- I am
objecting before she reads it in evidence. It's not in
evidence and if -- I'm not -- I wouldn't object to it being
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entered --
THE COURT: One moment. Did she serve this subpoena?
MR. WILCOX: She wrote it.
THE COURT: Did she serve this subpoena?
MR. WILCOX: Her name is on it.
THE COURT: Did she serve it on Oto Analytics?
MR. WILCOX: It was served on Oto Analytics. I don't
know who served it.
THE COURT: You don't know if she served it on -- and
you said her name is on it. When you say her name --
MR. WILCOX: She signed it.
MR. SNIDER: Directed it. I signed it.
THE COURT: All right. I'm confused. There's a
subpoena with the Clerk of Court and Mr. Snider's name on it.
Okay? So that's not her.
Now, what is it that you want to ask this witness?
Apparently, this subpoena, at least from the face of it, has
nothing to do with her, but I don't know.
MR. WILCOX: I'm sorry. I may be mistaken. On the
bottom of it, Judge.
THE COURT: All right, sir. You have to show it to
me. I haven't seen it.
So on the bottom it has, "Please provide the
materials, if possible," and it has the agent's name at the
bottom of it.
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MR. WILCOX: Yes.
THE COURT: All right. So you want to ask her if
she -- what, if she --
MR. WILCOX: Received the items that are listed in
the subpoena.
THE COURT: In the subpoena. All right. And then
from there you will do what? Let's say she says -- I mean,
you probably know the answer; right? Did she get these items?
MR. WILCOX: Yes.
THE COURT: Okay. So she's going to say, "I
retrieved these items," and I don't know. You may say, "Do
you have the statements" -- I don't know what you're going to
say, but what's the objection?
MR. SNIDER: I wanted to preemptively object to her
reading documents that are not in evidence. If he wants to
ask her if she received the records, that's fine.
THE COURT: We haven't had that question yet.
MR. SNIDER: Okay. To me, I thought that's where it
was going and I don't want to have a second sidebar, so
perhaps we can address the limit of this scope.
THE COURT: Ask her, "Did you serve the subpoena?
Are you aware of the subpoena? Did you receive some
documents? What were the documents? Where are the
documents?"
MR. SNIDER: That's fine.
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THE COURT: All right? Let's --
MR. MCCRAY: I do have the letter that I sent to you
at 4:22 yesterday. It's very short.
THE COURT: When you say sent to me --
MR. MCCRAY: Well, sent to --
THE COURT: Okay. Here's -- I don't know why lawyers
are getting into this habit now, but we don't take emails
because nobody's there to receive emails. In other words, I
don't get emails. You have to file a motion with the clerk
and then we can take some action. And that created a little
problem with the issue we discussed at the status hearing.
You were going to have some subpoenas and I said, "Do both
parties agree?" And I said, "Yes, I will."
And then there was an email sent. And then my clerk
was out and the email came in and it sat there for six days
and I didn't know about it. I found out later because there
was an email -- if it's a motion filed. Then it goes through
our docketing and then I see it, but the email is like a
casual little thing. So just so you know.
MR. MCCRAY: Okay.
THE COURT: Because if I had known your pleading came
in on that day, as you told me it was, I would have signed it
that day.
MR. MCCRAY: Yeah.
THE COURT: But my JA was out for five days and it
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sat there and I wasn't happy about it, but that's not your
problem. But anyway... okay. I didn't get this. I'll make
inquiry because it was sent at 4:22. So that's an issue I'll
have to take up with my staff.
MR. MCCRAY: Do you want to keep that, Judge?
THE COURT: Yes.
(The following proceedings were held in open court:)
THE COURT: The objection is overruled.
MR. WILCOX: One moment.
May I approach the witness, Your Honor?
THE COURT: Yes, sir.
BY MR. WILCOX:
Q.
Now I kind of lost my train of thought here.
You have in your possession a document that's marked
for identification as Defense Exhibit 5; correct?
A.
That's correct.
Q.
Do you recognize that document?
A.
I do.
Q.
What is it?
A.
This is the subpoena that I served to Womply.
Q.
You served it?
A.
Yes.
Q.
And the second page of it, it requests that Womply
provides you with certain items; is that correct? Records;
right?
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A.
That's correct.
Q.
Did you receive those records?
A.
I did.
Q.
And you asked Womply to provide all records in the custody
or control of Oto Analytics, doing business as Womply;
correct?
A.
Correct.
Q.
Related to paycheck --
MR. SNIDER: This is the objection I raised at
sidebar.
THE COURT: I'm sorry?
MR. SNIDER: This is the objection that I raised at
sidebar, reading from a document not in evidence.
THE COURT: Well, he's asking her a question. It
just so happens to be on a form, but he's asking her a
question, so she may respond to the question.
Overruled.
BY MR. WILCOX:
Q.
You asked Womply to provide all records related to
Paycheck Protection Program loan number 6697269001 and, in
parentheses, business legal name Carolyn Wade; correct?
A.
That's correct.
Q.
Including the entire content of any electronic or physical
file related to PPP loan number 6697269001, which includes but
is not limited to the following records. And then you list
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ten different items; correct?
A.
Correct.
Q.
Audit files, bank statements, all signed documents, PPP
application and accompanying documents, approved Persona
verification documents, denied Persona verification documents,
tax documents to include upload Schedule Cs, Internet protocol
report for the user related to PPP loan number 6697269001,
other applications with the same IP addresses as PPP loan
number 6697269001, and all applications between Womply and the
applicant/borrower to include communications from customer IO
database, the drift, D-R-I-F-T, platform and all sales force
communications; right?
A.
Correct.
Q.
So number eight is Internet protocol report for the IP
related to PPP loan number 6692699001 [sic]. Now, did Womply
provide you files or documents or records pursuant to this
subpoena?
A.
They did.
Q.
Do you remember approximately how many files?
A.
I don't remember how many files on this, no.
Q.
Were any of those files associated with Haydee Granados?
A.
Are you talking about number nine, not number eight?
Q.
I'm talking about the documents that were provided
pursuant to this subpoena. Did any of them involve Haydee
Granados?
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///
24
A.
Yes, they did.
Q.
How many?
A.
How many documents? I would have to --
Q.
How many files?
A.
I don't remember.
Q.
Hmm?
A.
I don't remember.
Q.
But there were files?
A.
Yes, there were.
Q.
There were files associated with Haydee Granados that
weren't connected to Carolyn Wade. Am I correct?
A.
They were connected via similar IP addresses.
Q.
No. What I'm asking you is the files that you received --
MR. SNIDER: Your Honor, at this point, I'm going to
renew my objection -- I'm sorry. I'm going to renew my
objection to the extent that the witness is providing
testimony about documents that are not in evidence.
THE COURT: Well, but he's asking her if she
retrieved certain documents; correct?
MR. WILCOX: Yes.
THE COURT: All right. So she can answer that
question.
MR. SNIDER: Okay.
THE COURT: So overruled.
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BY MR. WILCOX:
Q.
Did you receive documents or files relating to Haydee
Granados that were not related to Carolyn Wade?
A.
They had similar IPs listed on them.
Q.
Did that mean --
A.
They're related in the fact that they have similar IPs --
or not similar, the same IP.
Q.
Let me ask it another way.
Were there any documents that were related to Carolyn
Wade -- sorry. Excuse me. Let me step back.
Were there any documents or files that were related
to Haydee Granados that had nothing to do with Carolyn Wade?
A.
I received the PPP loan applications for Haydee Granados.
In the documents --
Q.
Ma'am -- I'm sorry. That's kind of like a yes-or-no
question.
A.
Well, the subpoena asks for information specifically
related to Carolyn Wade's loan.
Q.
Just allow me to ask the question again, please. Please.
Did you receive files relating to Haydee Granados
that had nothing to do with Carolyn Wade?
A.
Your Honor, this is not a yes-or-no question.
The subpoena specifically states with the same IP
addresses --
MR. WILCOX: Objection, Your Honor. It's
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nonresponsive.
THE COURT: Can you respond to his question? You can
explain your answer. But did you receive files relating to
Haydee Granados that had nothing to do with Carolyn Wade? I
think that's the question.
THE WITNESS: Then I think the answer is no because I
received those files because she had a similar -- the same IP
address as Carolyn Wade's.
BY MR. WILCOX:
Q.
So every file that you received relating to Haydee
Granados -- okay.
The files that you received relating to Haydee
Granados, did they relate to Carolyn Wade's PPP application --
all the files that you received concerning -- hmm?
A.
Outside of the fact that they had the same IP listed in
both applications, I received applications for both
individuals.
Q.
What IP address are you saying --
A.
The one ending in 125.
Q.
Okay. And we've established that that IP address belonged
to Haydee Granados, okay.
Were there files relating to Haydee Granados --
MR. MCCRAY: Judge, did she answer? I don't think
she answered.
MR. WILCOX: May I just confer with my co-counsel?
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BY MR. WILCOX:
Q.
You received files that had the same IP address ending in
125; is that right?
A.
Correct.
Q.
And we know that in some instances an IP address ending in
125 was part of Ms. Wade's PPP application process; is that
right?
A.
That's correct.
Q.
Now, were there other files that you received ending in
125 that were unrelated to Ms. Wade's PPP application?
A.
Yes.
Q.
Yes. Thank you.
How many?
A.
How many files exactly? I don't remember.
Q.
How many applications?
A.
Approximate --
Q.
Excuse me. Let me finish the question. Okay.
How many PPP applications ending in 125 did you
receive pursuant to this subpoena?
A.
I'm sorry. I don't understand the question.
Q.
How many PPP applications associated with the IP address
ending in 125 did you receive pursuant to this subpoena?
A.
Approximately 20.
Q.
20, okay.
And some were saying Haydee Granados were involved in
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20 separate PPP loan applications?
A.
Is there a question?
Q.
Yes.
A.
What was the question?
Q.
So pursuant to this subpoena, you received 20 PPP
applications that were associated with the IP address ending
in 125, which we have established is associated with Haydee
Granados; correct?
A.
Approximately 20, that's correct.
Q.
Okay. And Ms. Wade certainly wasn't involved in all 20 of
those files, was she?
A.
Not to my knowledge.
Q.
So is it fair for me to conclude that Haydee Granados
filed 20 PPP loan applications?
A.
I think it's fair to say that she assisted with those
applications. I don't know if she submitted them.
Q.
All right. So she was involved with 20 PPP loan
applications; correct?
A.
Yes.
MR. WILCOX: One moment, Your Honor. Can I just
confer with counsel? One moment, Your Honor.
I apologize, Your Honor. We have misplaced a
document. I don't seem to have it.
THE COURT: Which document? The subpoena or --
MR. WILCOX: It's in evidence. Exhibit 102.1 is what
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we're trying to find. You did not give it to me.
MR. MCCRAY: We didn't leave it up there, did we?
MR. WILCOX: Your Honor, may I approach the bench?
THE COURT: Yes, sir.
MR. WILCOX: One moment, Your Honor.
BY MR. WILCOX:
Q.
As part of your investigation, you requested IRS documents
or documents from the IRS which included her W-2 Form; is that
correct?
A.
Yes, it is.
Q.
And if I'm not mistaken, she earned about $90,000 per year
as a BSO deputy?
A.
I think it was approximately 80 to 90,000, yes.
Q.
Excuse me?
A.
I think it was approximately 80 to 90,000, yes.
Q.
80 to 90,000?
A.
Yes.
Q.
Okay. I won't quibble about that.
And the loan amount in this case is $20,833, and she
paid Ms. Granados $5,000; correct?
A.
That's correct.
MR. WILCOX: Your Honor, I think I'm just about done.
I just want to confer with counsel.
Your Honor, I don't have any other questions.
THE COURT: All right. Redirect?
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MR. SNIDER: Yes, Your Honor. Thank you.
REDIRECT EXAMINATION
BY MR. SNIDER:
Q.
Agent DiPietrantonio, during cross-examination you were
asked some questions about an IP address ending in 125;
correct?
A.
That's correct.
Q.
Okay --
MR. WILCOX: Objection to the leading, Your Honor.
THE COURT: Overruled.
BY MR. SNIDER:
Q.
Let's talk about that IP address for a little bit. You
were shown a copy of your grand jury transcript in this case;
correct?
A.
That's correct.
Q.
How many times did you testify in front of the grand jury
with respect to this case against Carolyn Wade?
A.
Just once.
Q.
And what was the purpose of that testimony?
A.
To receive an indictment.
Q.
Did you testify about all the facts that you knew at the
time?
A.
No, I did not.
Q.
What facts did you provide to the grand jury through your
testimony?
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A.
Only enough facts to receive the indictment.
Q.
To establish something?
A.
To establish probable cause to receive the indictment.
Q.
Do you remember in the grand jury being asked about a
particular IP address?
A.
Yes.
Q.
Was that the one ending in 84?
A.
Yes, it was.
Q.
And do you remember being asked about the context of that
IP address as it related to the indictment?
A.
Yes.
Q.
And what was that?
A.
That it was the IP address that was used to sign the
DocuSign.
Q.
When you were in front of the grand jury testifying, at
that time -- and by the way, when was that, if you recall?
A.
I believe that was October.
Q.
Sometime last fall?
A.
Yes.
Q.
When you were testifying in front of the grand jury last
fall, were you aware then that an IP address ending in 125 was
involved in an application for a PPP loan for Carolyn Wade?
A.
No, I was not.
Q.
Did you know then who the IP address ending in 125 was
attributable to or associated with?
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A.
No, I did not.
Q.
Had you ever even seen that IP address ending in 125
before?
A.
No, I did not.
Q.
When did you learn about the identity -- let me rephrase
that.
When did you become aware of this 125 IP address?
A.
In a trial preparation call we had with somebody who was
contracted by Womply.
Q.
Did they identify the IP address or did they -- well, let
me go back for a second.
You were involved in drafting a subpoena to Womply?
A.
That's correct.
Q.
That was a trial subpoena, not a grand jury subpoena?
A.
Correct.
Q.
And there was a request in there to provide any records
that had a similar IP that was used in Carolyn Wade's
application; is that right?
MR. WILCOX: Objection to the leading, Your Honor.
BY MR. SNIDER:
Q.
I can rephrase.
Why did you include in the trial subpoena request to
include any -- let me rephrase.
Do you know what IP crossover is, if I use that term?
A.
Yes.
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Q.
What is that?
A.
It's when an IP -- the same IP is used on more than one,
in this case, application.
Q.
Okay. Did you ask Womply for any crossover IP?
A.
Yes.
Q.
Why did you do that?
A.
Because on that trial preparation call, we were made aware
that there were other applications that made similar -- not
similar -- had the same IP addresses that were used in Carolyn
Wade's PPP application.
Q.
Did you learn the actual identity of the 125 then or did
you learn it only when you got the records?
A.
Only when I got the records.
Q.
Okay. So you didn't learn on that call that there was --
MR. WILCOX: Objection to the leading, Your Honor.
THE COURT: I'm sorry. I didn't hear.
MR. WILCOX: Objection to the leading.
THE COURT: Sustained.
BY MR. SNIDER:
Q.
Did you learn on that call --
THE COURT: What did she learn on that call?
BY MR. SNIDER:
Q.
What did you learn on that call about this 125? Was that
identified?
A.
It was not identified. I just learned that that IP
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address was also used in the submission of other PPP
applications.
Q.
Okay. When you got the records back from Womply, did it
include records of IP addresses that were involved in Carolyn
Wade's PPP loan application?
A.
It did, yes.
Q.
And was one of those IP addresses ending in 125?
A.
Yes, it was.
Q.
And let's take a look at your -- did you do an analysis
when you got the Womply records of what that IP address ending
in 125 did in relation to Carolyn Wade's application?
A.
Yes.
Q.
And was that based on the information and data that had
been supplied by Womply?
A.
Yes.
Q.
I'm going to publish for you the demonstrative that we
were using during your direct examination two days ago, and
I'm going to go to slide eight. It's marked for
identification as Government 1000.
What is in slide eight?
A.
These are Womply events on May 13, 2021, related to
Carolyn Wade's PPP loan application.
Q.
And was there an event that occurred from an IP address
ending in 125?
A.
Yes, there was.
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Q.
What was that event?
A.
It was the uploading of the Schedule C.
MR. WILCOX: Your Honor, I'm going to object. This
is exceeding the scope of my cross-examination. It's --
THE COURT: Beyond the scope of the cross is the --
MR. WILCOX: Yeah, beyond the scope of the cross.
THE COURT: Overruled.
BY MR. SNIDER:
Q.
In looking at the Womply records, did this IP address
ending in 125, as far as activity or events in Carolyn Wade's
application, do anything else other than upload this
Schedule C?
A.
No, it did not.
Q.
Did you see logins into Carolyn Wade's account from the IP
address ending in 125?
A.
No, it did not let me.
Q.
I'm sorry. I don't mean event. I just mean actual
logins. Let's take a look at login attempts on slide five. A
lot of terms I'm throwing around here, so I don't want to
confuse you.
Do you see on slide five login attempts from a 125
address?
A.
Yes.
Q.
Okay. But if there was an event from a 125 meaning
something was actually done --
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MR. WILCOX: Objection, Your Honor. It calls for
speculation.
THE COURT: Ask the question and if she's
knowledgeable, she may respond.
BY MR. SNIDER:
Q.
Do you know whether it is possible to log in and not do
anything to an application on Womply's website?
A.
It is possible, yes.
Q.
And if something is done, is it tracked in the events
spreadsheet?
A.
Yes, it is.
Q.
So there were additional logins from the 125; correct?
A.
Correct.
Q.
But there was no other activity?
A.
Correct.
Q.
You were shown slide 36 during your cross-examination. Do
you remember that?
A.
Yes.
Q.
And on the third line here, it reflects that there were
five logins from those IP addresses belonging to Verizon?
A.
Correct.
Q.
Why did you select those five to put into your summary?
A.
Because those IP addresses were included in Carolyn Wade's
application while Carolyn Wade was a Verizon customer.
Q.
And did you see logins into the Womply portal from those
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IP addresses?
A.
Yes, I did.
Q.
Did you see activity in the Womply portal from those IP
addresses?
A.
Yes, I did.
Q.
Did you see activity in the Womply portal -- logins and/or
activity in the Womply portal after -- later in time from the
logins ending in 125?
A.
Yes, I did.
Q.
You've testified that you saw this 125 IP address in other
PPP loan applications that were for borrowers that were not
Carolyn Wade; correct?
A.
That's correct.
Q.
And that information came from Womply?
A.
Correct.
Q.
But based on that alone, do you know what activity, if
any, was being done in those applications from the 125 IP
address?
A.
No, I don't.
Q.
And you've testified that, to your knowledge, this 125 IP
address is associated with who?
A.
Haydee Granados.
Q.
And the bank records in this case that are in evidence,
how much money did Haydee Granados receive from Carolyn Wade
on the day that Carolyn Wade received her PPP loan
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 37 of 48
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application?
A.
$1,000.
Q.
How that was made?
A.
Via Zelle.
Q.
Did you see any other money going from Carolyn Wade's
account to any other entity or person associated with Haydee
Granados?
A.
Yes.
Q.
What was that?
A.
A $4,000 check to the Jersey City Group a few days after
she received the proceeds of her PPP loan application.
Q.
I've published Government Exhibit 305 in evidence. Is
this the check you just referred to?
A.
Yes.
Q.
What is in the memo?
A.
Equipment restoration.
Q.
Do you know what that is?
A.
No, I do not.
Q.
I'm going to pull your demonstrative back up. I'm
publishing page 13.
Tell us again what is on page 13.
A.
This is the DocuSign for Carolyn Wade's PPP application
that was funded.
Q.
And the IP address that was used for this DocuSign?
A.
174.228.6.224.
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 38 of 48
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23
24
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39
Q.
Is there an attribution between that IP address and
Carolyn Wade?
A.
Yes. That's a Verizon-owned IP address while Carolyn Wade
was a Verizon customer.
Q.
What other --
MR. WILCOX: Objection, Your Honor. That calls for
speculation.
THE COURT: Have her testify from law enforcement
knowledge.
MR. SNIDER: I'm asking her what were the records
that are in evidence.
BY MR. SNIDER:
Q.
Based on the records in evidence, what is the attribution
between the 224 IP address and Carolyn Wade?
A.
It's a Verizon IP address while Carolyn Wade was a Verizon
customer.
Q.
What other attribution is shown on slide 13 between the IP
address ending in 224 and Carolyn Wade?
A.
The same day Carolyn Wade's PPP application is signed with
the IP address ending in 224, there's also a login to Carolyn
Wade's USAA bank account also from the IP address ending in
224.
Q.
And how many DocuSigns for PPP applications were signed in
this case?
A.
Two.
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 39 of 48
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40
Q.
This is the first?
A.
Yes.
Q.
Let's go to page 20. What are we looking at on page 20?
A.
This is the second DocuSign that was signed for Carolyn
Wade's PPP application.
Q.
And that IP ends in what?
A.
84.
Q.
And what is the attribution based on the evidence in this
case between Carolyn Wade and the IP address ending in 84?
A.
Carolyn Wade was the billing party and the name of the
service information for this IP address, her AT&T.
Q.
Where was the service provided to?
A.
To Carolyn Wade's residence.
Q.
What other attribution is shown on slide 20?
A.
On the days before and after this DocuSign was signed, an
IP address ending in 84 also logged into Carolyn Wade's USAA
bank account.
Q.
And what type of device did that, based on the evidence in
this case that's in evidence?
A.
It was an Android app.
Q.
What kind of phone did Carolyn Wade have based on the
evidence in this case during this time frame?
A.
A Note20 Ultra 5G, 128 gigabytes, copper in color.
Q.
What kind of operating system does that run, if you know?
A.
Android.
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 40 of 48
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Q.
You were asked some questions about how the DocuSign
process works on cross-examination. Do you remember that?
A.
Yes.
Q.
To your knowledge, can you sign a document by DocuSign by
logging into a website?
A.
No, you cannot.
Q.
How is it that one would begin the process of DocuSigning
a document?
A.
One has to receive the document in their email from a
company via DocuSign. They then open the link in that email
address, sign the document, and they're then provided with a
copy of everything that they signed to the same email address
on file.
Q.
So you need that original email, is that your testimony?
A.
Correct.
MR. SNIDER: I have no further questions.
THE COURT: You may step down.
MR. WILCOX: Your Honor, just for purposes of the
record, the defense may want to recall Agent DiPietrantonio.
THE COURT: She's not -- she is excused subject to
recall.
MR. WILCOX: Thank you.
* * * * *
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 41 of 48
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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: 18th of July, 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 111 Entered on FLSD Docket 07/25/2024 Page 42 of 48
$
$1,000 [1] - 38:2
$113,000 [2] - 9:10,
10:2
$20,833 [1] - 29:19
$4,000 [1] - 38:10
$5,000 [4] - 6:21, 7:6,
7:18, 29:20
$90,000 [1] - 29:11
/
/s/Lance [1] - 42:5
1
1 [3] - 1:9, 11:8, 11:9
1000 [1] - 34:19
102.1 [1] - 28:25
107 [1] - 12:3
125 [35] - 6:2, 6:4,
6:18, 8:24, 9:4,
10:6, 12:7, 14:6,
14:14, 26:19, 27:3,
27:6, 27:10, 27:18,
27:22, 28:7, 30:5,
31:21, 31:24, 32:2,
32:7, 33:11, 33:23,
34:7, 34:11, 34:24,
35:10, 35:15,
35:21, 35:24,
36:12, 37:8, 37:10,
37:17, 37:20
127 [2] - 14:2, 14:12
128 [1] - 40:23
13 [5] - 8:2, 34:21,
38:20, 38:21, 39:17
133 [1] - 10:1
166 [2] - 5:9, 5:14
17 [1] - 1:5
171 [1] - 14:1
174.228.6.224 [1] -
38:25
184 [3] - 14:1, 14:2,
14:11
18th [2] - 2:17, 42:5
19 [3] - 11:20, 11:22,
11:23
2
2 [6] - 3:7, 3:9, 5:4,
11:8, 11:9, 13:20
20 [11] - 27:23, 27:24,
28:1, 28:5, 28:9,
28:10, 28:14,
28:17, 40:3, 40:14
200 [2] - 14:3, 14:12
2019 [3] - 9:20, 9:21,
9:22
2021 [2] - 8:2, 34:21
2024 [2] - 1:5, 42:5
224 [7] - 14:1, 14:2,
14:11, 39:14,
39:18, 39:20, 39:22
23-CR-60173 [1] - 1:2
3
3 [1] - 11:11
305 [1] - 38:12
305.523.5633 [1] -
1:21
33060 [1] - 2:14
33128 [1] - 1:21
33317 [1] - 2:17
33394 [2] - 2:5, 2:9
36 [2] - 13:18, 36:16
4
4 [7] - 3:6, 3:13, 5:14,
11:12, 11:13,
11:15, 11:19
400 [2] - 1:20, 2:13
42 [1] - 1:9
4:20 [1] - 3:17
4:22 [2] - 20:3, 21:3
4:30 [1] - 3:19
4:35 [1] - 3:22
5
5 [7] - 3:4, 3:5, 3:23,
5:18, 16:20, 16:22,
21:15
500 [2] - 2:4, 2:8
5201 [1] - 2:17
5G [1] - 40:23
6
6692699001 [1] -
23:15
6697269001 [4] -
22:20, 22:24, 23:7,
23:9
7
7 [2] - 2:4, 2:8
8
8 [1] - 7:22
80 [3] - 29:13, 29:15,
29:16
84 [5] - 12:4, 31:7,
40:7, 40:9, 40:16
9
90,000 [3] - 29:13,
29:15, 29:16
954-303-1457 [1] -
2:18
954-660-5696 [1] -
2:5
954-660-5789 [1] -
2:9
954-781-3662 [1] -
2:14
9:32 [1] - 4:6
A
able [3] - 6:14, 12:15,
13:12
above-entitled [1] -
42:3
accompanied [1] -
8:20
accompanying [1] -
23:4
account [6] - 13:11,
13:14, 35:14, 38:6,
39:21, 40:17
action [1] - 20:10
Activity [1] - 13:18
activity [6] - 35:10,
36:14, 37:3, 37:6,
37:7, 37:16
actual [2] - 33:11,
35:17
additional [1] - 36:12
address [67] - 5:9,
5:10, 5:14, 6:1, 6:4,
6:7, 6:9, 6:11, 6:13,
6:15, 6:18, 8:23,
9:4, 9:6, 10:6, 12:3,
12:4, 12:7, 13:10,
13:15, 14:6, 14:11,
14:12, 14:14,
14:15, 19:20, 26:8,
26:18, 26:20, 27:2,
27:5, 27:21, 28:6,
30:5, 30:12, 31:5,
31:10, 31:13,
31:21, 31:24, 32:2,
32:7, 32:10, 34:1,
34:10, 34:23, 35:9,
35:15, 35:22,
37:10, 37:18,
37:21, 38:24, 39:1,
39:3, 39:14, 39:15,
39:18, 39:20,
39:21, 40:9, 40:11,
40:16, 41:11, 41:12
addresses [16] -
10:13, 10:17,
10:18, 11:24, 14:1,
14:2, 23:8, 24:12,
25:24, 33:9, 34:4,
34:7, 36:20, 36:23,
37:1, 37:4
Agent [3] - 11:17,
30:4, 41:19
agent's [1] - 18:24
ago [1] - 34:17
agree [1] - 20:13
ahead [1] - 10:22
aid [3] - 5:5, 7:22,
13:17
aided [1] - 1:24
allow [1] - 25:19
almost [1] - 3:14
alone [1] - 37:16
ALSO [1] - 2:20
AM [1] - 4:6
AMERICA [1] - 1:4
amount [1] - 29:19
analysis [1] - 34:9
Analytics [3] - 18:6,
18:7, 22:5
Android [2] - 40:20,
40:25
answer [6] - 7:4,
19:8, 24:21, 26:3,
26:6, 26:23
answered [1] - 26:24
anyway [1] - 4:2
anyway.. [1] - 21:2
apologize [2] - 13:13,
28:22
app [1] - 40:20
APPEARANCES [1] -
2:1
appeared [1] - 12:16
applicant/borrower
[1] - 23:10
Application [1] -
13:19
application [40] -
5:16, 5:20, 5:23,
6:25, 7:2, 7:7, 7:9,
7:11, 7:16, 7:20,
8:9, 8:12, 8:21,
8:23, 9:18, 10:3,
10:4, 10:14, 10:15,
10:16, 15:24, 23:4,
43
26:13, 27:6, 27:10,
31:22, 32:18, 33:3,
33:10, 34:5, 34:11,
34:22, 35:11, 36:7,
36:24, 38:1, 38:11,
38:22, 39:19, 40:5
applications [18] -
23:8, 23:9, 25:13,
26:16, 27:15,
27:18, 27:21, 28:1,
28:6, 28:14, 28:16,
28:18, 33:8, 34:2,
37:11, 37:17, 39:23
approach [4] - 10:20,
16:16, 21:10, 29:3
approved [1] - 23:4
approximate [1] -
27:16
assisted [2] - 7:1,
28:15
associated [18] -
5:22, 6:4, 6:9, 6:15,
6:18, 7:15, 7:19,
9:6, 9:18, 10:14,
23:21, 24:10,
27:21, 28:6, 28:7,
31:25, 37:21, 38:6
AT&T [1] - 40:11
Atlantic [1] - 2:13
attempts [3] - 5:18,
35:18, 35:21
attention [2] - 5:3,
5:4
attesting [1] - 15:13
Attorney's [2] - 2:4,
2:8
attributable [1] -
31:25
attribution [5] - 39:1,
39:13, 39:17, 40:8,
40:14
audit [1] - 23:3
AUSA [2] - 2:3, 2:7
Avenue [1] - 1:20
aware [4] - 19:22,
31:21, 32:7, 33:7
B
bank [4] - 23:3,
37:23, 39:21, 40:17
based [6] - 34:13,
37:16, 39:13, 40:8,
40:18, 40:21
battery [1] - 4:22
Beach [1] - 2:14
become [1] - 32:7
BEFORE [1] - 1:13
begin [1] - 41:7
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 43 of 48
behalf [3] - 10:16,
13:1, 13:6
BEHALF [1] - 2:11
belonged [1] - 26:20
belonging [1] - 36:20
belongs [2] - 6:8,
10:8
bench [2] - 3:21, 29:3
better [1] - 12:14
between [5] - 23:9,
39:1, 39:14, 39:17,
40:9
beyond [2] - 35:5,
35:6
big [1] - 4:11
billing [1] - 40:10
bit [4] - 5:4, 7:25,
12:13, 30:12
borrowers [1] - 37:11
bottom [4] - 11:23,
18:20, 18:23, 18:25
Boulevard [3] - 2:4,
2:8, 2:13
break [1] - 3:11
bring [2] - 4:5, 17:3
Broward [2] - 2:4, 2:8
BSO [1] - 29:12
business [4] - 9:10,
10:2, 22:5, 22:21
BY [19] - 4:25, 8:18,
11:16, 12:12,
16:21, 21:12,
22:18, 25:1, 26:9,
27:1, 29:6, 30:3,
30:11, 32:20,
33:19, 33:22, 35:8,
36:5, 39:12
C
cannot [1] - 41:6
Carolyn [45] - 2:20,
5:23, 6:5, 7:12,
9:10, 12:21, 22:21,
24:11, 25:3, 25:9,
25:12, 25:18,
25:21, 26:4, 26:8,
26:13, 30:17,
31:22, 32:17, 33:9,
34:4, 34:11, 34:22,
35:10, 35:14,
36:23, 36:24,
37:12, 37:24,
37:25, 38:5, 38:22,
39:2, 39:3, 39:14,
39:15, 39:18,
39:19, 39:20, 40:4,
40:9, 40:10, 40:13,
40:16, 40:21
CAROLYN [1] - 1:8
case [10] - 6:21,
29:19, 30:13,
30:17, 33:3, 37:23,
39:24, 40:9, 40:19,
40:22
CASE [1] - 1:2
casual [1] - 20:19
certain [2] - 21:24,
24:19
certainly [1] - 28:10
CERTIFICATE [1] -
42:1
certify [1] - 42:2
chambers [1] - 3:14
check [2] - 38:10,
38:13
City [1] - 38:10
clearer [1] - 16:2
Clerk [1] - 18:14
clerk [2] - 20:9, 20:14
clock [1] - 4:21
co [1] - 26:25
co-counsel [1] -
26:25
color [1] - 40:23
coming [1] - 14:13
communication [1] -
5:15
communications [2]
- 23:10, 23:12
company [1] - 41:10
complete [1] - 5:16
computer [1] - 1:24
computer-aided [1] -
1:24
concerning [1] -
26:14
conclude [1] - 28:13
confer [4] - 12:10,
26:25, 28:21, 29:23
confuse [1] - 35:20
confused [1] - 18:13
connected [2] -
24:11, 24:12
content [1] - 22:23
context [1] - 31:9
continue [2] - 4:7,
13:19
CONTINUED [1] -
4:24
contracted [1] - 32:9
control [1] - 22:5
copper [1] - 40:23
copy [2] - 30:13,
41:12
correct [91] - 5:6, 5:7,
5:11, 5:16, 5:17,
5:19, 5:20, 5:24,
6:3, 6:5, 6:22, 6:23,
6:25, 8:2, 8:3, 8:5,
8:6, 8:8, 8:10, 8:12,
8:13, 8:22, 9:4, 9:5,
9:7, 9:8, 9:10, 9:11,
9:23, 9:25, 10:5,
10:9, 10:11, 10:12,
12:4, 12:5, 12:7,
12:8, 12:18, 12:19,
12:23, 12:24, 13:2,
13:3, 13:15, 13:16,
14:3, 14:4, 14:7,
14:8, 14:16, 14:25,
15:3, 15:4, 15:10,
21:15, 21:16,
21:24, 22:1, 22:6,
22:7, 22:21, 22:22,
23:1, 23:2, 23:13,
24:11, 24:19, 27:4,
27:8, 28:8, 28:9,
28:18, 29:9, 29:20,
29:21, 30:6, 30:7,
30:14, 30:15,
32:13, 32:15,
36:12, 36:13,
36:15, 36:21,
37:12, 37:13,
37:15, 41:15, 42:2
correctly [1] - 14:21
counsel [4] - 12:11,
26:25, 28:21, 29:23
COURT [63] - 1:1,
3:2, 3:16, 3:19,
3:21, 3:25, 4:5, 4:7,
4:15, 4:21, 8:16,
10:21, 10:24, 11:3,
11:8, 11:13, 16:17,
17:3, 17:5, 17:9,
17:12, 17:14,
17:17, 17:19,
17:22, 18:2, 18:4,
18:6, 18:9, 18:13,
18:21, 19:2, 19:6,
19:10, 19:17,
19:21, 20:1, 20:4,
20:6, 20:21, 20:25,
21:6, 21:8, 21:11,
22:11, 22:14,
24:18, 24:21,
24:24, 26:2, 28:24,
29:4, 29:25, 30:10,
33:16, 33:18,
33:21, 35:5, 35:7,
36:3, 39:8, 41:17,
41:20
court [1] - 21:7
Court [8] - 1:19, 1:20,
3:1, 3:4, 3:24,
18:14, 42:6, 42:7
courtroom [1] - 4:22
created [1] - 20:10
credentials [1] - 13:5
CRIMINAL [1] - 1:2
CROSS [1] - 4:24
cross [6] - 30:4, 35:4,
35:5, 35:6, 36:16,
41:2
CROSS-
EXAMINATION [1] -
4:24
cross-examination
[4] - 30:4, 35:4,
36:16, 41:2
crossover [2] -
32:24, 33:4
Cs [2] - 9:13, 23:6
custodian [1] - 9:12
custody [1] - 22:4
customer [5] - 14:3,
23:10, 36:24, 39:4,
39:16
CW [3] - 12:16,
12:17, 12:21
D
DARYL [1] - 2:16
darylewilcox06@
gmail.com [1] -
2:18
data [1] - 34:13
database [1] - 23:11
date [1] - 8:1
DATE [1] - 42:5
DAVID [1] - 2:3
david.snider@
usdoj.gov [1] - 2:6
days [6] - 4:9, 20:15,
20:25, 34:17,
38:10, 40:15
DEFENDANT [1] -
2:11
Defendant [1] - 1:9
Defense [4] - 11:15,
16:20, 16:22, 21:15
defense [2] - 11:19,
41:19
demonstrative [5] -
5:5, 7:22, 13:17,
34:16, 38:19
denied [1] - 23:5
deputy [1] - 29:12
DERIC [1] - 2:7
deric.zacca@usdoj.
gov [1] - 2:10
determine [1] - 6:15
development [1] -
3:12
device [1] - 40:18
different [1] - 23:1
44
DiPietrantonio [4] -
5:1, 11:17, 30:4,
41:19
DIPIETRANTONIO
[1] - 1:7
direct [2] - 5:3, 34:17
directed [1] - 18:12
discuss [1] - 3:10
discussed [1] - 20:11
DISTRICT [3] - 1:1,
1:1, 1:14
District [3] - 1:20,
42:7, 42:7
DIVISION [1] - 1:2
docketing [1] - 20:18
document [23] - 8:4,
8:7, 12:16, 12:22,
13:12, 14:19,
14:20, 15:2, 15:15,
15:16, 15:18, 16:5,
17:3, 17:10, 21:14,
21:17, 22:13,
28:23, 28:24, 41:4,
41:8, 41:9, 41:11
documents [22] -
6:14, 12:20, 19:15,
19:23, 19:24, 23:3,
23:4, 23:5, 23:6,
23:16, 23:23, 24:3,
24:17, 24:19, 25:2,
25:9, 25:11, 25:14,
29:7, 29:8
DocuSign [22] -
12:14, 12:18,
12:22, 12:25, 13:1,
13:4, 13:6, 13:11,
13:14, 14:18,
14:19, 14:20,
15:24, 16:3, 31:14,
38:22, 38:24, 40:4,
40:15, 41:1, 41:4,
41:10
DocuSigned [3] -
12:16, 12:17, 12:20
DocuSigning [1] -
41:7
DocuSigns [2] - 13:9,
39:23
DONALD [1] - 1:13
done [4] - 29:22,
35:25, 36:9, 37:17
down [1] - 41:17
drafting [1] - 32:12
drift [1] - 23:11
DRIFT [1] - 23:11
during [5] - 3:11,
30:4, 34:17, 36:16,
40:22
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 44 of 48
E
earned [1] - 29:11
East [3] - 2:4, 2:8,
2:13
eight [4] - 23:14,
23:22, 34:18, 34:20
electronic [1] - 22:23
ELMO [2] - 4:19, 5:4
email [12] - 3:13,
13:10, 13:11,
13:14, 20:14,
20:15, 20:17,
20:18, 41:9, 41:10,
41:12, 41:14
emails [3] - 20:7,
20:8, 20:9
employers [1] - 4:10
ended [1] - 10:6
ending [38] - 5:9, 6:1,
6:4, 6:18, 8:24, 9:4,
12:4, 12:7, 14:2,
14:6, 14:11, 14:12,
14:14, 26:19, 27:2,
27:5, 27:9, 27:18,
27:22, 28:6, 30:5,
31:7, 31:21, 31:24,
32:2, 34:7, 34:10,
34:24, 35:10,
35:15, 37:8, 39:18,
39:20, 39:21, 40:9,
40:16
ends [1] - 40:6
enforcement [1] -
39:8
enter [1] - 16:11
entered [2] - 4:6,
18:1
entire [5] - 15:2,
15:16, 15:24, 16:4,
22:23
entirety [2] - 15:15,
15:18
entitled [2] - 8:1, 42:3
entity [1] - 38:6
equipment [1] -
38:16
ESQ [2] - 2:12, 2:16
establish [3] - 12:15,
31:2, 31:3
established [2] -
26:20, 28:7
event [4] - 34:23,
35:1, 35:17, 35:24
Events [1] - 8:2
events [6] - 8:4, 14:5,
14:13, 34:21,
35:10, 36:9
evidence [19] - 5:5,
6:20, 11:2, 16:12,
17:11, 17:24,
17:25, 19:15,
22:13, 24:17,
28:25, 37:23,
38:12, 39:11,
39:13, 40:8, 40:18,
40:19, 40:22
exactly [3] - 15:6,
15:7, 27:14
examination [5] -
30:4, 34:17, 35:4,
36:16, 41:2
EXAMINATION [2] -
4:24, 30:2
exceeding [1] - 35:4
EXCERPT [1] - 1:12
excuse [5] - 8:24,
14:1, 25:10, 27:17,
29:14
excused [1] - 41:20
execute [1] - 14:19
executed [2] - 12:18,
12:22
Exhibit [6] - 11:15,
16:20, 16:22,
21:15, 28:25, 38:12
exhibit [2] - 11:19,
17:5
explain [1] - 26:3
extent [1] - 24:16
F
face [1] - 18:17
fact [2] - 25:6, 26:15
facts [3] - 30:21,
30:24, 31:1
fair [2] - 28:13, 28:15
fake [1] - 7:10
fall [2] - 31:18, 31:21
far [1] - 35:10
FCRR [2] - 1:19, 42:6
few [2] - 4:9, 38:10
figure [1] - 11:6
file [5] - 13:10, 20:9,
22:24, 26:10, 41:13
filed [11] - 3:6, 7:15,
7:20, 8:13, 9:13,
9:15, 9:22, 10:10,
10:16, 20:17, 28:14
files [21] - 23:3,
23:16, 23:19,
23:20, 23:21, 24:4,
24:8, 24:10, 24:13,
25:2, 25:11, 25:20,
26:3, 26:7, 26:12,
26:14, 26:22, 27:2,
27:9, 27:14, 28:11
filing [1] - 10:14
fine [3] - 4:4, 19:16,
19:25
finger [1] - 13:21
finish [1] - 27:17
first [5] - 7:23, 13:1,
13:24, 40:1
five [6] - 13:25,
20:25, 35:18,
35:21, 36:20, 36:22
Floor [2] - 2:4, 2:8
FLORIDA [1] - 1:1
Florida [8] - 1:4,
1:21, 2:5, 2:9, 2:14,
2:17, 42:7, 42:8
focus [1] - 13:24
following [3] - 17:4,
21:7, 22:25
fool [1] - 5:3
FOR [1] - 2:2
force [1] - 23:11
foregoing [1] - 42:2
form [1] - 22:15
Form [1] - 29:8
Fort [2] - 2:5, 2:9
foundation [1] -
16:15
FPR [2] - 1:19, 42:6
FPR-C [2] - 1:19,
42:6
frame [1] - 40:22
fraudulent [3] - 7:19,
8:7, 9:3
front [3] - 30:16,
31:15, 31:20
full [1] - 7:8
funded [2] - 6:22,
38:23
G
gigabytes [1] - 40:23
GOVERNMENT [1] -
2:2
Government [5] -
8:11, 8:14, 8:19,
34:19, 38:12
GRAHAM [2] - 1:2,
1:13
Granados [28] - 6:17,
6:19, 6:21, 6:25,
7:6, 7:14, 7:19, 9:7,
10:8, 23:21, 23:25,
24:10, 25:3, 25:12,
25:13, 25:20, 26:4,
26:11, 26:13,
26:21, 26:22,
27:25, 28:8, 28:13,
29:20, 37:22,
37:24, 38:7
Granados's [1] -
14:14
grand [11] - 10:11,
10:18, 11:25, 12:6,
30:13, 30:16,
30:24, 31:4, 31:15,
31:20, 32:14
gross [1] - 9:9
grossed [1] - 10:2
Group [1] - 38:10
guide [1] - 4:23
H
habit [1] - 20:7
happy [1] - 21:1
Haydee [25] - 6:17,
6:19, 6:21, 7:18,
9:7, 10:8, 14:14,
23:21, 23:24,
24:10, 25:2, 25:12,
25:13, 25:20, 26:4,
26:10, 26:12,
26:21, 26:22,
27:25, 28:7, 28:13,
37:22, 37:24, 38:6
hear [2] - 8:24, 33:16
heard [1] - 8:15
hearing [1] - 20:11
HELD [1] - 1:13
held [2] - 17:4, 21:7
Hendrith [1] - 2:20
hmm [2] - 24:6, 26:14
Honor [25] - 4:14,
10:20, 11:10,
12:10, 16:9, 16:16,
21:10, 24:14,
25:22, 25:25,
28:20, 28:21,
28:22, 29:3, 29:5,
29:22, 29:24, 30:1,
30:9, 32:19, 33:15,
35:3, 36:1, 39:6,
41:18
HONORABLE [1] -
1:13
hundred [2] - 15:21
hurry [1] - 5:15
I
idea [2] - 4:2, 6:9
identification [9] -
10:25, 11:4, 11:9,
11:15, 11:19,
16:20, 16:23,
21:15, 34:19
identified [2] - 33:24,
45
33:25
identify [1] - 32:10
identity [2] - 32:5,
33:11
implication [1] - 6:24
inaccurate [2] - 4:22,
7:15
include [5] - 23:6,
23:10, 32:22,
32:23, 34:4
included [2] - 29:8,
36:23
includes [1] - 22:24
including [1] - 22:23
income [1] - 9:9
indictment [5] -
10:10, 30:20, 31:1,
31:3, 31:10
individual [2] - 13:5,
13:6
individuals [1] -
26:17
indulge [1] - 3:24
information [6] -
12:25, 13:4, 25:17,
34:13, 37:14, 40:11
initial [1] - 15:14
initials [3] - 12:15,
12:21, 16:4
inquiry [1] - 21:3
instances [1] - 27:5
instant [1] - 16:5
Internet [3] - 6:10,
23:6, 23:14
introduce [1] - 11:1
introduced [1] - 6:20
investigated [1] - 6:7
investigation [2] -
16:8, 29:7
involve [1] - 23:24
involved [7] - 8:12,
27:25, 28:10,
28:17, 31:22,
32:12, 34:4
IO [1] - 23:10
IP [86] - 5:8, 5:10,
5:14, 6:1, 6:4, 6:7,
6:9, 6:11, 6:13,
6:15, 6:18, 8:23,
9:4, 9:6, 10:6,
10:13, 10:17,
10:18, 11:24, 12:3,
12:4, 12:7, 14:1,
14:2, 14:6, 14:10,
14:11, 14:12,
14:14, 23:8, 23:14,
24:12, 25:7, 25:23,
26:7, 26:15, 26:18,
26:20, 27:2, 27:5,
27:21, 28:6, 30:5,
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 45 of 48
30:12, 31:5, 31:10,
31:13, 31:21,
31:24, 32:2, 32:7,
32:10, 32:17,
32:24, 33:2, 33:4,
33:9, 33:25, 34:4,
34:7, 34:10, 34:23,
35:9, 35:14, 36:20,
36:23, 37:1, 37:3,
37:10, 37:17,
37:20, 38:24, 39:1,
39:3, 39:14, 39:15,
39:17, 39:20,
39:21, 40:6, 40:9,
40:11, 40:16
IPs [2] - 25:4, 25:6
IRS [7] - 8:13, 9:12,
9:14, 9:15, 9:24,
29:7, 29:8
issue [2] - 20:11,
21:3
issued [1] - 16:8
issues [1] - 3:3
items [5] - 19:4, 19:8,
19:11, 21:24, 23:1
J
JA [1] - 20:25
Jersey [1] - 38:10
JOHNNY [1] - 2:12
Johnny [1] - 2:13
JR [1] - 2:12
Jr [1] - 2:13
judge [2] - 3:12,
26:23
Judge [5] - 4:18,
11:7, 11:11, 18:20,
21:5
JUDGE [1] - 1:14
July [1] - 42:5
jurors [1] - 4:9
jury [13] - 4:1, 4:5,
10:11, 10:18,
11:25, 12:6, 30:13,
30:16, 30:24, 31:4,
31:15, 31:20, 32:14
Jury [1] - 4:6
K
keep [2] - 11:5, 21:5
KELLY [1] - 1:7
kind [4] - 21:13,
25:15, 40:21, 40:24
knowledge [4] -
28:12, 37:20, 39:9,
41:4
knowledgeable [1] -
36:4
known [1] - 20:21
L
lack [1] - 12:14
Lance [1] - 42:5
LANCE [1] - 1:19
last [3] - 4:9, 31:18,
31:20
Lauderdale [2] - 2:5,
2:9
law [1] - 39:8
Law [1] - 2:13
lawyers [1] - 20:6
leading [4] - 30:9,
32:19, 33:15, 33:17
learn [7] - 32:5,
33:11, 33:12,
33:14, 33:20,
33:21, 33:23
learned [1] - 33:25
least [1] - 18:17
leave [2] - 3:19, 29:2
left [1] - 3:21
legal [1] - 22:21
letter [1] - 20:2
lie [4] - 8:11, 8:14,
8:20, 9:3
limit [1] - 19:20
limited [1] - 22:25
line [10] - 7:23, 13:20,
13:22, 13:23,
13:24, 13:25,
14:16, 36:19
link [1] - 41:10
list [1] - 22:25
listed [3] - 19:4, 25:4,
26:15
listen [1] - 17:22
Loan [1] - 13:18
loan [29] - 5:23, 6:22,
6:25, 7:7, 7:16,
7:20, 8:12, 8:21,
10:3, 10:14, 10:15,
22:20, 22:24, 23:7,
23:8, 23:15, 25:13,
25:18, 28:1, 28:14,
28:17, 29:19,
31:22, 34:5, 34:22,
37:11, 37:25, 38:11
location [1] - 6:13
log [1] - 36:6
logged [1] - 40:16
logging [1] - 41:5
login [7] - 5:18,
12:25, 13:4, 13:5,
35:18, 35:21, 39:20
logins [13] - 5:9,
5:10, 5:12, 6:1,
13:25, 14:6, 35:14,
35:18, 36:12,
36:20, 36:25, 37:6,
37:8
look [4] - 11:22,
11:23, 34:9, 35:18
looked [1] - 11:22
looking [3] - 3:9,
35:9, 40:3
lost [1] - 21:13
M
ma'am [1] - 25:15
mark [6] - 10:24,
11:4, 11:7, 11:11,
11:13, 16:10
marked [7] - 11:11,
11:15, 11:18,
16:20, 16:22,
21:14, 34:18
materials [1] - 18:24
matter [1] - 42:3
MCCRAY [13] - 2:12,
3:12, 3:17, 3:20,
3:23, 4:4, 20:2,
20:5, 20:20, 20:24,
21:5, 26:23, 29:2
McCray [1] - 2:13
mccrayjlaw@gmail.
com [1] - 2:15
mean [8] - 8:15,
10:15, 12:17,
12:21, 19:7, 25:5,
35:17
meaning [1] - 35:24
mechanical [1] - 1:23
memo [1] - 38:15
mentioned [1] - 3:3
Miami [4] - 1:4, 1:20,
1:21, 42:8
minute [2] - 3:24,
12:10
misplaced [1] - 28:22
mistaken [2] - 18:19,
29:11
moment [7] - 8:16,
16:9, 18:2, 21:9,
28:20, 28:21, 29:5
money [2] - 37:24,
38:5
morning [7] - 3:2,
3:7, 3:9, 4:7, 5:1,
5:2
motion [2] - 20:9,
20:17
MR [94] - 3:12, 3:17,
3:18, 3:20, 3:23,
4:4, 4:14, 4:19,
4:25, 8:18, 10:22,
11:1, 11:6, 11:10,
11:14, 11:16,
12:10, 12:12,
16:11, 16:13,
16:14, 16:16,
16:18, 16:19,
16:21, 17:2, 17:6,
17:7, 17:8, 17:10,
17:13, 17:15,
17:18, 17:21,
17:23, 18:3, 18:5,
18:7, 18:11, 18:12,
18:19, 19:1, 19:4,
19:9, 19:14, 19:18,
19:25, 20:2, 20:5,
20:20, 20:24, 21:5,
21:9, 21:12, 22:9,
22:12, 22:18,
24:14, 24:20,
24:23, 25:1, 25:25,
26:9, 26:23, 26:25,
27:1, 28:20, 28:25,
29:2, 29:3, 29:5,
29:6, 29:22, 30:1,
30:3, 30:9, 30:11,
32:19, 32:20,
33:15, 33:17,
33:19, 33:22, 35:3,
35:6, 35:8, 36:1,
36:5, 39:6, 39:10,
39:12, 41:16,
41:18, 41:22
N
name [7] - 18:5,
18:10, 18:14,
18:24, 22:21, 40:10
necessarily [2] -
12:17, 12:21
need [3] - 11:7, 14:2,
41:14
never [2] - 6:10, 8:13
next [5] - 3:11, 15:11,
16:4, 17:21
nine [1] - 23:22
NO [1] - 1:2
nobody's [1] - 20:8
nonresponsive [1] -
26:1
North [1] - 1:20
note [1] - 4:21
Note20 [1] - 40:23
notes [1] - 42:3
nothing [5] - 16:14,
18:18, 25:12,
25:21, 26:4
number [12] - 5:10,
46
11:6, 14:9, 14:10,
22:20, 22:24, 23:7,
23:9, 23:14, 23:15,
23:22
O
o'clock [7] - 3:4, 3:5,
3:6, 3:7, 3:9, 3:13,
3:23
oath [1] - 4:17
object [3] - 17:25,
19:14, 35:3
objected [2] - 17:13,
17:16
objecting [1] - 17:24
objection [17] - 17:2,
17:10, 17:20,
17:23, 19:13, 21:8,
22:9, 22:12, 24:15,
24:16, 25:25, 30:9,
32:19, 33:15,
33:17, 36:1, 39:6
occurred [1] - 34:23
October [1] - 31:17
OF [6] - 1:1, 1:4, 1:6,
1:12, 2:11, 42:1
Office [3] - 2:4, 2:8,
2:13
Official [2] - 1:19,
42:6
ON [1] - 2:11
once [1] - 30:18
one [18] - 8:4, 8:16,
9:3, 9:15, 12:25,
16:9, 17:22, 18:2,
21:9, 26:19, 28:20,
28:21, 29:5, 31:7,
33:2, 34:7, 41:7,
41:9
open [2] - 21:7, 41:10
opening [2] - 8:15,
8:20
operating [1] - 40:24
option [2] - 15:16,
15:17
Order [1] - 3:1
order [1] - 13:11
original [1] - 41:14
Oto [3] - 18:6, 18:7,
22:5
ought [1] - 9:16
outside [1] - 26:15
overruled [5] - 21:8,
22:17, 24:24,
30:10, 35:7
owned [1] - 39:3
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 46 of 48
P
P.A [1] - 2:13
page [15] - 5:4, 5:8,
5:14, 5:18, 7:22,
8:1, 11:20, 11:22,
11:23, 13:18,
21:23, 38:20,
38:21, 40:3
Pages [1] - 1:9
paid [6] - 6:11, 6:21,
6:24, 7:6, 7:18,
29:20
paragraph [1] - 15:11
paralegal [1] - 2:20
parentheses [1] -
22:21
part [3] - 16:8, 27:6,
29:7
particular [2] - 5:8,
31:5
parties [1] - 20:13
party [1] - 40:10
pay [1] - 4:11
paycheck [1] - 22:8
Paycheck [1] - 22:20
payment [1] - 7:14
per [1] - 29:11
percent [2] - 15:21
perhaps [1] - 19:20
permanent [1] - 4:9
person [7] - 12:17,
12:22, 12:25, 13:1,
13:2, 38:6
Persona [2] - 23:4,
23:5
phone [1] - 40:21
phrasing [1] - 14:20
physical [1] - 22:23
place [1] - 15:12
Plaintiff [1] - 1:5
planned [1] - 11:1
Plantation [1] - 2:17
platform [1] - 23:11
pleading [3] - 3:6,
3:10, 20:21
pleadings [1] - 3:9
PM [1] - 3:13
point [2] - 16:1, 24:14
pointing [1] - 13:21
Pompano [1] - 2:14
portal [6] - 5:21,
5:22, 36:25, 37:3,
37:6, 37:7
possession [3] -
9:24, 11:18, 21:14
possible [3] - 18:24,
36:6, 36:8
PPP [41] - 5:20, 5:23,
6:22, 6:25, 7:7,
7:11, 7:16, 8:12,
8:21, 10:3, 10:14,
10:15, 13:18,
22:24, 23:3, 23:7,
23:8, 23:15, 25:13,
26:13, 27:6, 27:10,
27:18, 27:21, 28:1,
28:5, 28:14, 28:17,
31:22, 33:10, 34:1,
34:5, 34:22, 37:11,
37:25, 38:11,
38:22, 39:19,
39:23, 40:5
preemptively [1] -
19:14
preparation [3] - 7:7,
32:8, 33:7
prepare [1] - 6:25
prepared [2] - 5:6,
42:3
preparing [1] - 7:1
PRESENT [1] - 2:20
probable [1] - 31:3
problem [3] - 4:23,
20:11, 21:2
proceed [2] - 3:2,
4:15
proceedings [3] -
17:4, 21:7, 42:3
Proceedings [1] -
1:23
proceeds [1] - 38:11
process [4] - 12:14,
27:6, 41:2, 41:7
produced [1] - 1:24
program [1] - 16:3
Program [1] - 22:20
prompt [3] - 15:8,
15:9
prompts [4] - 14:22,
15:1, 15:2, 16:3
Protection [1] - 22:20
protocol [2] - 23:6,
23:14
provide [6] - 18:23,
22:4, 22:19, 23:16,
30:24, 32:16
provided [3] - 23:23,
40:12, 41:11
provider [1] - 6:10
provides [1] - 21:24
providing [1] - 24:16
publish [2] - 4:20,
34:16
published [1] - 38:12
publishing [1] -
38:20
pull [1] - 38:19
purpose [1] - 30:19
purposes [1] - 41:18
pursuant [5] - 23:16,
23:24, 27:19,
27:22, 28:5
put [2] - 16:3, 36:22
Q
questions [5] - 8:16,
29:24, 30:5, 41:1,
41:16
quibble [1] - 29:18
quickly [1] - 3:25
R
raised [2] - 22:9,
22:12
read [4] - 4:2, 17:12,
17:15, 17:17
reading [3] - 17:10,
19:15, 22:13
reads [1] - 17:24
ready [3] - 3:2, 4:7,
4:13
rear [1] - 4:21
reason [1] - 6:12
receive [14] - 3:5,
19:22, 20:8, 22:2,
25:2, 25:20, 26:3,
27:19, 27:22,
30:20, 31:1, 31:3,
37:24, 41:9
received [16] - 6:14,
11:4, 19:4, 19:16,
24:13, 25:13, 26:7,
26:10, 26:12,
26:14, 26:16, 27:2,
27:9, 28:5, 37:25,
38:11
recognize [3] - 16:23,
17:18, 21:17
recollection [2] -
10:19, 16:15
record [3] - 11:5,
41:19, 42:3
recorded [1] - 1:23
records [18] - 9:12,
19:16, 21:24, 22:2,
22:4, 22:19, 22:25,
23:16, 32:16,
33:12, 33:13, 34:3,
34:4, 34:10, 35:9,
37:23, 39:10, 39:13
REDIRECT [1] - 30:2
redirect [1] - 29:25
reference [5] - 9:17,
12:3, 12:6, 14:5,
14:13
references [1] -
11:24
referred [2] - 8:20,
38:13
reflects [1] - 36:19
refresh [2] - 10:19,
16:15
relate [1] - 26:13
related [12] - 22:8,
22:19, 22:24, 23:7,
23:15, 25:3, 25:6,
25:9, 25:11, 25:18,
31:10, 34:21
relating [6] - 25:2,
25:20, 26:3, 26:10,
26:12, 26:22
relation [1] - 34:11
remember [11] - 9:17,
10:17, 23:19,
23:20, 24:5, 24:7,
27:14, 31:4, 31:9,
36:17, 41:2
remind [1] - 4:16
renew [2] - 24:15
rephrase [3] - 32:5,
32:21, 32:23
report [2] - 23:7,
23:14
Reporter [2] - 1:19,
42:6
REPORTER [1] -
42:1
request [2] - 32:16,
32:22
requested [1] - 29:7
requests [1] - 21:23
residence [1] - 40:13
resolve [1] - 4:1
respect [1] - 30:17
respond [3] - 22:16,
26:2, 36:4
restoration [1] -
38:16
retrieved [2] - 19:11,
24:19
reviewed [1] - 3:10
reviewing [1] - 11:17
RPR [2] - 1:19, 42:6
run [1] - 40:24
S
salary [1] - 4:12
sales [1] - 23:11
sat [2] - 20:15, 21:1
saw [1] - 37:10
Schedule [21] - 7:8,
7:10, 7:11, 7:15,
7:19, 8:7, 8:9, 8:13,
47
8:19, 9:3, 9:9, 9:13,
9:15, 9:16, 9:22,
10:1, 23:6, 35:2,
35:12
scope [4] - 19:20,
35:4, 35:5, 35:6
second [5] - 13:20,
19:19, 21:23,
32:11, 40:4
see [18] - 4:11, 7:13,
7:23, 10:19, 12:20,
13:21, 15:6, 15:7,
15:16, 16:2, 17:5,
20:18, 35:14,
35:21, 36:25, 37:3,
37:6, 38:5
seeking [1] - 16:11
seem [1] - 28:23
select [1] - 36:22
sends [1] - 15:24
sent [9] - 3:13, 3:23,
13:9, 20:2, 20:4,
20:5, 20:14, 21:3
separate [1] - 28:1
serve [4] - 18:2, 18:4,
18:6, 19:21
served [6] - 17:1,
18:7, 18:8, 18:9,
21:20, 21:21
service [3] - 6:10,
40:11, 40:12
several [2] - 5:10,
5:14
short [1] - 20:3
show [6] - 5:9, 5:10,
13:25, 15:15,
16:18, 18:21
showing [2] - 15:9,
16:22
shown [4] - 30:13,
36:16, 39:17, 40:14
shows [2] - 9:9, 10:2
sic] [1] - 23:15
sidebar [5] - 17:3,
17:4, 19:19, 22:10,
22:13
sign [9] - 13:12,
14:23, 15:1, 15:2,
15:9, 15:12, 31:13,
41:4, 41:11
signature [1] - 15:13
signed [9] - 18:11,
18:12, 20:22, 23:3,
39:19, 39:23, 40:4,
40:15, 41:12
signing [4] - 15:6,
15:7, 15:17, 15:25
similar [8] - 24:12,
25:4, 25:6, 25:7,
26:7, 32:17, 33:8,
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 47 of 48
33:9
situation [1] - 3:14
six [1] - 20:15
slide [7] - 34:18,
34:20, 35:18,
35:21, 36:16,
39:17, 40:14
Smith [1] - 2:20
SNIDER [30] - 2:3,
10:22, 16:11,
16:14, 16:18, 17:2,
17:7, 17:10, 17:13,
17:15, 17:23,
18:12, 19:14,
19:18, 19:25, 22:9,
22:12, 24:14,
24:23, 30:1, 30:3,
30:11, 32:20,
33:19, 33:22, 35:8,
36:5, 39:10, 39:12,
41:16
Snider's [1] - 18:14
sometime [1] - 31:18
soon [1] - 4:11
sorry [13] - 12:3,
14:1, 17:8, 17:14,
17:23, 18:19,
22:11, 24:15,
25:10, 25:15,
27:20, 33:16, 35:17
SOUTHERN [1] - 1:1
Southern [1] - 42:7
Southwest [1] - 2:17
specifically [2] -
25:17, 25:23
speculation [2] -
36:2, 39:7
spreadsheet [1] -
36:10
staff [1] - 21:4
start [1] - 14:2
statement [2] - 8:15,
8:20
statements [2] -
19:12, 23:3
states [1] - 25:23
STATES [3] - 1:1,
1:4, 1:14
States [4] - 1:20, 2:4,
2:8, 42:7
status [1] - 20:11
Steinbeisser [2] -
42:5, 42:5
STEINBEISSER [1] -
1:19
stenography [1] -
1:23
stenotype [1] - 42:3
step [2] - 25:10,
41:17
still [2] - 4:16, 5:22
Street [1] - 2:17
subject [1] - 41:20
submission [1] -
34:1
submitted [4] - 4:3,
7:11, 10:2, 28:16
subpoena [24] - 6:12,
16:9, 17:1, 18:2,
18:4, 18:14, 18:17,
19:5, 19:6, 19:21,
19:22, 21:20,
23:17, 23:24,
25:17, 25:23,
27:19, 27:22, 28:5,
28:24, 32:12,
32:14, 32:22
subpoenaed [1] -
6:10
subpoenas [1] -
20:12
subscriber [2] - 6:11,
6:13
Summary [1] - 13:18
summary [4] - 5:5,
13:17, 14:5, 36:22
supplied [1] - 34:14
supposed [1] - 15:12
surprise [1] - 3:8
sustained [1] - 33:18
system [1] - 40:24
T
tax [4] - 8:4, 8:7,
9:16, 23:6
ten [1] - 23:1
term [1] - 32:24
terms [1] - 35:19
testified [8] - 9:6,
9:13, 10:8, 10:11,
10:13, 10:17,
37:10, 37:20
testify [4] - 8:17,
30:16, 30:21, 39:8
testifying [3] - 7:18,
31:15, 31:20
TESTIMONY [1] - 1:6
testimony [6] - 11:25,
12:6, 24:17, 30:19,
30:25, 41:14
THE [68] - 1:13, 2:2,
2:11, 3:2, 3:16,
3:19, 3:21, 3:25,
4:5, 4:7, 4:15, 4:18,
4:21, 8:16, 10:21,
10:23, 10:24, 11:3,
11:8, 11:13, 16:17,
17:3, 17:5, 17:9,
17:12, 17:14,
17:17, 17:19,
17:22, 18:2, 18:4,
18:6, 18:9, 18:13,
18:21, 19:2, 19:6,
19:10, 19:17,
19:21, 20:1, 20:4,
20:6, 20:21, 20:25,
21:6, 21:8, 21:11,
22:11, 22:14,
24:18, 24:21,
24:24, 26:2, 26:6,
28:24, 29:4, 29:25,
30:10, 33:16,
33:18, 33:21, 35:5,
35:7, 36:3, 39:8,
41:17, 41:20
third [4] - 13:22,
13:23, 13:25, 36:19
throwing [1] - 35:19
titled [1] - 13:18
top [2] - 5:13, 11:23
toward [1] - 11:22
towards [1] - 11:23
tracked [1] - 36:9
train [1] - 21:13
transactions [5] -
5:12, 5:13, 5:14,
14:9, 14:10
TRANSCRIPT [1] -
1:12
transcript [2] - 1:23,
30:13
transcription [2] -
1:24, 42:3
TRIAL [1] - 1:12
trial [6] - 4:8, 11:5,
32:8, 32:14, 32:22,
33:7
trying [2] - 16:1, 29:1
turn [4] - 4:19, 5:4,
11:20, 13:17
two [4] - 6:1, 9:13,
34:17, 39:25
type [1] - 40:18
U
Ultra [1] - 40:23
under [1] - 4:17
UNITED [3] - 1:1, 1:4,
1:14
United [4] - 1:20, 2:4,
2:8, 42:7
unrelated [1] - 27:10
up [5] - 5:13, 5:16,
21:4, 29:2, 38:19
upload [2] - 23:6,
35:11
uploaded [3] - 8:9,
8:23, 9:4
uploading [2] - 8:4,
35:2
USAA [2] - 39:21,
40:16
user [1] - 23:7
V
V.A [1] - 2:20
verification [2] - 23:5
Verizon [8] - 14:1,
14:3, 36:20, 36:24,
39:3, 39:4, 39:15
Verizon-owned [1] -
39:3
via [3] - 24:12, 38:4,
41:10
visible [3] - 15:3,
15:18, 16:5
vs [1] - 1:6
W
W-2 [1] - 29:8
Wade [34] - 2:20,
5:15, 5:20, 5:23,
6:5, 6:21, 6:24,
7:12, 9:13, 10:16,
12:21, 14:3, 22:21,
24:11, 25:3, 25:10,
25:12, 25:21, 26:4,
28:10, 30:17,
31:22, 36:24,
37:12, 37:24,
37:25, 39:2, 39:3,
39:14, 39:15,
39:18, 40:9, 40:10,
40:21
WADE [1] - 1:8
Wade's [22] - 9:10,
13:18, 25:18, 26:8,
26:13, 27:6, 27:10,
32:17, 33:10, 34:5,
34:11, 34:22,
35:10, 35:14,
36:23, 38:5, 38:22,
39:19, 39:21, 40:5,
40:13, 40:16
wait [1] - 3:8
wants [1] - 19:15
website [2] - 36:7,
41:5
WILCOX [53] - 2:16,
3:18, 4:14, 4:19,
4:25, 8:18, 11:1,
11:6, 11:10, 11:14,
11:16, 12:10,
48
12:12, 16:13,
16:16, 16:19,
16:21, 17:6, 17:8,
17:18, 18:3, 18:5,
18:7, 18:11, 18:19,
19:1, 19:4, 19:9,
21:9, 21:12, 22:18,
24:20, 25:1, 25:25,
26:9, 26:25, 27:1,
28:20, 28:25, 29:3,
29:5, 29:6, 29:22,
30:9, 32:19, 33:15,
33:17, 35:3, 35:6,
36:1, 39:6, 41:18,
41:22
WILLIAMS [1] - 1:2
witness [7] - 4:16,
10:20, 16:16, 17:7,
18:16, 21:10, 24:16
WITNESS [3] - 4:18,
10:23, 26:6
Womply [28] - 5:15,
5:21, 5:22, 8:1, 9:4,
14:10, 14:13, 16:9,
21:20, 21:23, 22:4,
22:5, 22:19, 23:9,
23:15, 32:9, 32:12,
33:4, 34:3, 34:10,
34:14, 34:21, 35:9,
36:25, 37:3, 37:6,
37:7, 37:14
Womply's [1] - 36:7
word [1] - 12:14
wording [1] - 16:4
words [2] - 15:8, 20:8
works [1] - 41:2
wrote [1] - 18:3
Y
year [2] - 9:16, 29:11
yes-or-no [2] - 25:15,
25:22
yesterday [7] - 3:3,
3:4, 3:12, 3:14,
3:21, 12:13, 20:3
you-all [1] - 3:8
Z
ZACCA [2] - 2:7,
17:21
Zelle [1] - 38:4
zoom [1] - 7:25
Case 0:23-cr-60173-KMW Document 111 Entered on FLSD Docket 07/25/2024 Page 48 of 48File and source
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- SHA-256
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