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Transcript (Excerpt) of Trial, Government's Closing (May 20, 2024) — United States v. Carolyn D. Wade
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: the government's closing argument of May 20, 2024 before U.S. District Judge Donald L. Graham, Pages 1 to 38, entered on the docket 07/25/2024 as Document 112. The judge first agrees to drop a good-faith instruction from the jury instructions. AUSA David A. Snider tells the jury that Wade took part in a scheme to get a Paycheck Protection Program loan based on lies, which he calls a $113,000 lie: 2019 gross income for a business named Carolyn Wade that did not exist. He argues that she logged into the Womply portal at least nine times, uploaded three bank statements and linked her bank account three times, and that every login was an opportunity for her to see the fake Schedule C, Government Exhibit 113, that Haydee Granados uploaded.
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Record facts
| Court | U.S. District Court for the Southern District of Florida |
|---|---|
| Filed | 2024-07-25 |
Cite this document
“Transcript (Excerpt) of Trial, Government's Closing (May 20, 2024) — United States v. Carolyn D. Wade.”
U.S. District Court for the Southern District of Florida, No. 0:23-cr-60173-KMW, Doc. 112, filed 2024-07-25. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-wade-flsd-654267/2024-07-25-order-doc-112/
, SHA-256 5e351de28ce818cebfa5f81d8a8dd801dcc5e54ab358924aa0b8aa9273f3b004.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 20, 2024
vs.
GOVERNMENT'S CLOSING
CAROLYN D. WADE,
Defendant.
Pages 1 to 38
____________________________________________________________
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 112 Entered on FLSD Docket 07/25/2024 Page 1 of 38
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APPEARANCES:
FOR THE GOVERNMENT:
DAVID A. SNIDER, AUSA
United States Attorney's Office
500 East Broward Boulevard, Floor 7
Fort Lauderdale, Florida 33394
954-660-5696
david.snider@usdoj.gov
DERIC ZACCA, AUSA
United States Attorney's Office
500 East Broward Boulevard, Floor 7
Fort Lauderdale, Florida 33394
954-660-5789
deric.zacca@usdoj.gov
ON BEHALF OF THE DEFENDANT:
JOHNNY L MCCRAY, JR., ESQ.
Law Office of Johnny L. McCray, Jr, P.A.
400 East Atlantic Boulevard
Pompano Beach, Florida 33060
954-781-3662
mccrayjlaw@gmail.com
DARYL E. WILCOX, ESQ.
5201 Southwest 18th Street
Plantation, Florida 33317
954-303-1457
darylewilcox06@gmail.com
ALSO PRESENT: Carolyn Wade
Hendrith V.A. Smith, paralegal
Agent Kelly DiPietrantonio
Case 0:23-cr-60173-KMW Document 112 Entered on FLSD Docket 07/25/2024 Page 2 of 38
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(Call to the Order of the Court.)
THE COURT: Are we now ready for our closing
arguments?
MR. MCCRAY: Yes, Judge.
THE COURT: I think that you have the updated version
of the instructions. Other than the prior rulings, are there
any other comments?
MR. MCCRAY: No, Judge, not from the defense.
MR. SNIDER: Your Honor, I just noticed that on
page 11, the good-faith defense.
THE COURT: I'm sorry? Page 11?
MR. SNIDER: On page 11, Judge, I just noticed that
good-faith instruction is included, and I believe the Court's
ruling --
THE COURT: Oh, that should not be there, so we're
going to have to alter that. Thank you for bringing that to
my attention.
Any other comments?
MR. MCCRAY: No, Judge.
THE COURT: All right. So we will make that
correction. You can disregard good faith.
So we're going to have to decide when to break.
We'll see how it goes, but at some point in time we'll
probably have to take a break before all of the arguments are
concluded, and we'll see how it goes. And it also may depend
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on our reaction from the jurors.
Bring the jury in, please.
(Jury enters at 9:40 AM.)
THE COURT: Good morning, ladies and gentlemen. I
understand you were greeted with a lot of traffic this
morning -- we're missing one? All right. Fortunately,
everyone made it in okay.
So the evidence has been completed, and now we are at
the closing arguments stage. Each side has a maximum of one
hour to present the closing argument. The Government will go
first. They have the burden of proof. Any time that the
Government does not use that one hour, they may present what
we call a rebuttal argument. So it would be Government and
its presentation -- let's assume, hypothetically, they use
40 minutes. The defense would then have its closing argument.
They have up to one hour. The Government would then have
20 minutes remaining, the time they did not use in the initial
argument. So that is the process.
And as you know, afterwards, I will present to you
your instructions on the law and thereafter you will be able
to deliberate.
Government, are you ready to proceed?
MR. SNIDER: Yes, Your Honor.
THE COURT: You may proceed.
MR. SNIDER: Could we have the HDMI connection to
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this portion for the computer? Great. Thank you.
COURTROOM DEPUTY: Sure.
MR. SNIDER: Members of the jury, Carolyn Denise Wade
participated in a scheme, a scheme to get a loan from the
Paycheck Protection Program that was based on lies. A scheme
is a plan. It is a plan, you will hear from the Court's
instructions, essentially to get money or property based on
false statements -- lies. That is exactly what the scheme was
in this case, and Carolyn Denise Wade, the defendant,
participated in that scheme knowingly and with intent to
defraud.
Over the course of this trial, you have seen
overwhelming evidence, evidence that proves beyond a
reasonable doubt that the defendant directly participated in
the application process for her fraudulent PPP loan. She knew
exactly what she was doing. She was directly involved. She
intended to get a PPP loan based on lies.
Now, let's talk about those lies. At the beginning
of this case, I told you that this whole case was about a
$113,000 lie. Remember? And you've seen that lie over and
over and over and over again. And that lie, that $113,000
lie, that was about 2019 gross income for a business that did
not exist.
There was no business named Carolyn Wade. It was
made up. It was pulled out of thin air. Why? To get a
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fraudulent PPP loan. Even the defendant's husband, Tracy
Wade, confirmed on Friday there was no business Carolyn Wade.
It was one of the few things he testified to that was
accurate. We'll talk about that in a minute.
Everything about the business, quote, Carolyn Wade
was a lie. It had no employees. It had no payroll. It
certainly didn't have any income. And Carolyn Wade knew this.
She knew that this was a loan for a company that didn't exist
because that lie was so obvious, so apparent, and so repeated,
over and over and over again. Throughout the process, it was
impossible for her to have not seen it. It was impossible for
her not to have known.
I want you to remember when you look at the evidence
in this case. Every time you see the business legal name
Carolyn Wade, that is a lie. And every time the defendant saw
it when she was applying, she knew it was a lie. Now, let's
talk about some of those instances, the ones where this lie
just literally jumps off the page or jumps off a computer
screen.
The first time that the defendant may have seen this
lie was when she logged into the Womply portal, which the
evidence shows -- and we're going to go through this in great
detail -- the defendant did at least nine times from her cell
phone, a Samsung Note20 Ultra 5G in copper. You can look at
Government's Exhibit 802. It even has the color of her phone,
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the device.
Remember what Aman Thakral told you. He was the
witness from Womply. He testified last Tuesday and he
explained to you that every time there's a login into the
Womply portal, all of the evidence that had been previously
entered is visible. And Mr. Thakral should know. He wrote
the program for the whole website. You heard it from the
source. The person who designed the website that captured all
this information was sitting in this courtroom and told you
exactly how it worked.
So every login was an opportunity for the defendant
to see the lie. The lie was there when the defendant uploaded
three bank statements into the Womply portal because she was
logged in to do that. The lie was there when the defendant
linked her bank account three times through Womply's website
because she was logged in to do that. The lie was there when
the defendant verified her identity through Persona because
she was logged in to do that.
Took six selfies of herself. Remember the testimony
from the representative from Persona, Ms. Bergh? She walked
through all those sessions, the failures -- not because it was
the defendant who was applying, just because the barcode
couldn't be read. So she had to do it over and over and over
again. She's logged into Womply's portal every time she's
doing that.
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And then there are the documents. I'm going to focus
on a few. There's the fake Schedule C. That's Government
Exhibit 113.
This was uploaded into the Womply portal by Haydee
Granados. There's no dispute about that. We've stipulated to
that. But the point is that Haydee Granados uploads it and
then the defendant's logging in afterwards. You're going to
see that again in a few minutes. But look at this first line.
The lie literally jumps off the page. There's no business
Carolyn Wade before you even get to the fake income
information. There's no principal business Carolyn Wade. And
then you get down to these numbers. The lie literally jumps
off the page. It's impossible not to know that.
Then there's Government Exhibit 116, the first
fraudulent PPP application that was signed on May 18th from
the defendant's Verizon network that she was on. The lie
jumps off this page too. There's no business Carolyn Wade.
There's no trade name Carolyn Wade. Business phone? Sure,
that's the defendant's phone number. That's not the business
phone for a business called Carolyn Wade. Carolyn Wade isn't
the primary contact for a business named Carolyn Wade.
Certainly there's no $113,560 in 2019 gross income
for a business called Carolyn Wade. It literally jumps off
the page. And she didn't see this once. She saw it twice.
This is Government 117. This is an identical application that
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she just had to sign again because of that issue between the
lenders and Harvest being told, "Sorry, you're too big. You
can't issue any more." Had to get routed to Lendistry.
That's why she had to sign it twice. It's the exact same
document. It's the exact same lies jumping off the page.
And then there's the forgiveness application, which
the evidence shows the defendant signed from her home. Look
at the lies jumping off this page. There's no business name
Carolyn Wade. There's no trade name Carolyn Wade. There's no
employees. Three employees? It's painfully obvious how fake
this is. And here's the defendant's signature. Sole
proprietor title.
Had the SBA or its private lenders that were trying
to get money to small business owners in the midst of a
pandemic known about any of this false information,
specifically the fake income information, her business that
didn't exist, they wouldn't have funded the loan, but the SBA
didn't know that because it relied on the borrower to certify
that it was all true. The SBA and the lenders didn't know
this was false. The defendant knew it was false.
She certified it was all true knowing that it wasn't.
Look at these documents. It would have been impossible for
the defendant to have missed this. I just showed you four: a
fake Schedule C, two fake applications for a loan, and a fake
forgiveness application.
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Now let's talk about the business that the defendant
did report to the IRS as having. That was called 1 Step
A-Head. You don't see 1 Step A-Head anywhere in these
application documents. This was not a loan for 1 Step A-Head
for a business that the defendant told the IRS she had. She
didn't tell BSO she had that business, by the way. You heard
from Joanna Hely. If an employee of BSO has outside
employment under the BSO policy, you're supposed to report it
in advance. Even her husband knew that. On some years he did
that for the Wade Funeral Home.
But 1 Step A-Head isn't mentioned anywhere in these
applications because this was not an application -- a PPP loan
application for 1 Step A-Head. And Defendant did have a
Schedule C for the year 2018, 2019, and actually two for 2020
because one of the 2020s was amended. She had a Schedule C
filed with the IRS for 1 Step A-Head, but that's not what she
used. That wasn't included. And not only was it not
included, you learned this on Friday from Mr. Wade's
testimony.
The Wades never provided the real tax information --
or the tax information filed with the IRS to Haydee Granados
or Eduardo Rivero. Now think about that for a second.
The person whose only role in this, according to the
data, was to upload the tax information, the Wades didn't give
them that information. How is Haydee Granados supposed to
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know how much money 1 Step A-Head or a fake business, Carolyn
Wade, is supposed to make? How is she supposed to know that
if she didn't have the information? And their theory is that
they had no idea? You pay somebody $5,000 to upload fake tax
information and now you're surprised that it was fake when
they didn't even have the real information.
This wasn't trust. This wasn't trust in the Granados
or the Riveros. This was paying for somebody else to lie for
you, paying someone 25 percent to create and upload fake tax
information. She could have supplied the real one. That's
not what she did.
Now, when you take a look at these tax returns,
Government Exhibit 200, 201, 202, 203 -- that's from the years
2018 to 2020 -- you'll see what Carolyn Wade actually reported
to the IRS for 1 Step A-Head. And in the 2019 -- which is the
year that matters for this application because the 2019 box
was checked -- she reported $6,800, not 113,560. That's a
made-up number.
And the other thing to look at in those tax returns
are these extraordinary expenses for a hairstyling business
that's run out of a garage. That's what her husband
testified. It was in the garage. It was like a chair in the
garage.
Between those three years, '18, '19, '20, it cost
Carolyn Wade $67,770 to run 1 Step A-Head. That's what she
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reported to the IRS in expenses for those three years. And
she reported only earning $10,600. That means that it cost
Carolyn Wade out of her own pocket $57,000 to run 1 Step
A-Head for three years? That's like 27 percent of all of her
BSO wages.
And I want to make something clear here. Carolyn
Wade is not on trial for anything related to her taxes. Okay?
You can't consider those taxes as -- she's not on trial for
taxes. That's not part of this case. I don't want you to
look at that and say, well, she did something wrong here;
therefore, she did something. No, you can't do that. Okay?
But what you can do is just look at the
discrepancies. Look at the discrepancy between the -- on the
fake Schedule C, she's claiming this enormous profit, and on
the one she filed with the IRS, she's claiming these enormous
losses. $5,000 for travel? $8,400 for utilities? She's
working in the garage. Does that make sense? If it's costing
you this much money to run this hairstyling business, why
would you keep doing it? 24,000 miles driven in one year for
a hairstyling business? They weren't living in Port St. Lucie
at the time. Look at the tax returns. They were living in
Coral Springs. That's what her husband testified to. She's
working in Broward County at the sheriff's office, not living
in Port St. Lucie.
Now, let's talk about Mr. Wade's testimony -- the
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defendant's husband, Tracy Wade. He testified on Friday from
that seat right there and he was clearly trying to shift the
blame -- all of the blame on Haydee Granados and Eduardo
Rivero. Of course he was. He was trying to protect his wife.
He loves his wife. Apparently, he loves everyone. That's
what he said. He even loves Mr. Zacca, which is hard to
believe considering the interaction with Mr. Zacca and
Mr. Wade that went on for at least two hours, but that's what
he said -- "I love you, Mr. Zacca" -- something to that
effect. Mr. Wade could not answer some very simple questions
about his own affairs.
He couldn't tell you how much money his funeral home
business made as recently as 2023. He couldn't tell you the
timing of his EIDL loan. He couldn't tell you the timing of
his PPP loans. He testified that he did not have a business
named, quote, "Tracy Wade" but he couldn't explain why he got
a PPP loan for a business called Tracy Wade.
And then Mr. Wade was asked about Carolyn Wade's PPP
loan application process, and he gave you a version of events
that is just not true. And how do you know that Mr. Wade's
version is not true? Because the data doesn't lie.
The truth in this case is in the data, not in
Mr. Wade's testimony. The data, the precise digital record of
everything that happened on the Womply portal, you have it
all. Womply had extraordinary records. Literally, every time
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there was a key stroke, a piece of information put in, there's
a record. There's a unique transaction ID. You see it's the
who, the what, the where, the when. You have it all.
Let me give you a few examples. I'm going to go
through the data one more time, but let me just first give you
a couple of examples. For example, Mr. Wade testified his
wife doesn't have access -- the defendant, Mrs. Wade, doesn't
have access to her cell phone during working hours at BSO.
That's not true. How do you know that's not true? You have
the photographs of Mrs. Wade, the defendant, taking six
selfies of herself in her BSO uniform during working hours,
holding her cell phone, her Samsung Note20. You know it's a
Samsung Note20 because Persona captured the model number.
Here's another example. Mr. Wade testified that,
quote, "Haydee did 90 percent of everything for Carolyn Wade's
loan." That's not true. That's not what the data shows. The
data shows the opposite. Haydee Granados did one thing as far
as actual changes in this application. She put in fake tax
information. That's what the data shows. She didn't do
90 percent. She did one thing. That was her job and she got
paid handsomely for it.
Mr. Wade also denied his own involvement in Carolyn
Wade's application. He said, "Oh, no, that was Granados. She
was doing it all," until the data was put in front of him.
Now, what's that IP address for the Wade Funeral Home, that
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.166 that was in front of him. At that point there was no
fighting it because the data doesn't lie.
He said, well, you know, maybe it was started before
May 4. No, it wasn't. Look at the data. There's no data
before May 4. That's when this application was started.
Finally, Mr. Wade said that he DocuSigned the second PPP loan
application, the one on May 28, 2021. Remember he said that?
He said, "That's the one that I signed." And he said he
signed it from the Wade Funeral Home and he said it was at
about 2 o'clock in the afternoon. Do you remember that? He
said, "Oh, that's the one around 2 o'clock I signed." For a
person who apparently couldn't remember or said he has trouble
remembering what happened yesterday, he said he had a pretty
clear memory of signing it around 2 o'clock in the afternoon
from the Wade Funeral Home. Well, guess what? That PPP loan
application was not signed at 2 o'clock in the afternoon from
the Wade Funeral Home.
Number one, it was signed from the IP address from
the Wades' residence -- the home they live in, not the funeral
home. And number two, it wasn't signed at 2:15 in the
afternoon East Coast time. You're going to look at that
record. Mr. Wade may have memorized the DocuSign certificate
showing 2:15. Guess what? That was Pacific time. It says it
right on there, 2:15 Pacific. That's 5:15 East Coast time.
He didn't sign it at 2 o'clock. He wasn't in California. He
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was in Florida, East Coast, Eastern time, 5:15.
The data in this case puts Carolyn Wade, the
defendant, directly involved in this PPP loan application,
directly involved in this scheme. And you're going to have,
as I said, all the data. So let's walk through it one more
time because this is the record of what happened.
This application is started on May 4, 2021, from the
Wade Funeral Home. Mr. Wade said that was him at the
computer, .166. That's the IP address that AT&T assigned to
the Wade Funeral Home. And there it is. Do you see operation
type 0? That means it started. This is the first thing that
happened.
You're going to have these spreadsheets too. It's
Government Exhibit 102E, 102.1E and 102.2E. And they show
different things. The information here, taken from 102E, it's
kind of an overview of the transactions. But if you look at
the more detail, which is 102.2E, you can see every time it
goes from, like, blank to a piece of information. Mr. Wade
typed in Carolyn Wade as the business, not Haydee. It's right
there on the spreadsheet. This is what Mr. Wade did on
May 4th. He uploaded a bank document and he linked a bank
account. That's from the Wade Funeral Home. That's what the
data shows.
And then there was nothing between May 4th and
May 13th. He started it as -- I'm sorry -- this is as
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Mr. Thakral testified. You can start it, go in and out of the
application. It doesn't have to all be done at once. So
nothing happens after May 4th until May 13th when an email
gets sent to Carolyn Wade saying, "It may have gotten stuck.
It happens to the best of us. We get busy. Can you please go
in and finish?" Well, that's exactly what happens on
May 13th. There's a bunch of logins.
This spreadsheet just shows every time there was a
login to the Womply portal on May 13th. We don't know whose
IP address ended in 34. We know that the .166 was Mr. Wade
logging in. We know the .125 was Haydee Granados logging in
after that. Then Mr. Wade logs back in. And then we have the
defendant, Carolyn Wade. This is just May 13th. One, two
three, four, five logins to the Womply portal, and then
another login by Haydee Granados.
This slide, slide six, shows specifically Mr. Wade's
login attempts: one at 8:23 AM and one at 9:21 AM. This slide
shows Carolyn Wade, all of her logins, each one true, meaning
she successfully logged in. Five times on May 13. And
there's her phone, right there in front of you, the Samsung
Model SM-986U, and she's using it on Verizon's network, which
you can only use if you're a Verizon customer.
And there are the logins, the same type of app,
Android app, the same IP address to Carolyn Wade's bank
account. And you heard, in addition to this matching up with
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the device that was captured during the Persona, Agent
DiPietrantonio testified that this SM-986U is a Note20 Ultra
5G. That is the defendant using her phone to log into Womply
five times on May 13th.
And this slide, slide eight, shows specific activity
as a result of that login. It shows Haydee Granados uploading
the fake tax document. That's the only thing that she did
here. And then it shows, once again, the defendant logging
in, uploading a bank document three times, linking her bank
account three times. That 125 IP address did no other
activity except upload this fake Schedule C. Logged in --
there's other logins. But as far as activity, this is all it
did.
More transactions. These are the detailed
transactions for Mr. Wade on May 13th. Six transactions.
Look at the time, Eastern. Mr. Wade is doing these between
9:21 and 9:23 AM -- right? -- from his funeral home. And then
in goes the defendant, Carolyn Wade, after him. Between 10:08
and 10:51, all these transactions in the Womply portal.
Fifteen transactions. And that corresponds with her using
that same IP to log into her bank account on the same day.
Then we have the defendant, Carolyn Wade, doing her
Persona identity verification at work clearly in her BSO
uniform. And, by the way, this too, the time here,
10:09 AM -- it says 12:09. That's UTC. This says 10:09
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Eastern -- I'm sorry. It says 2:09 PM. The difference
between UTC, Universal Coordinated Time, and Eastern is four
hours. So this is 10:00 AM. And she is holding the Samsung
Note20 in her hands in front of her face to take these three
selfies. You can see on the device type SM-986U. That's the
Samsung Note20 Ultra 5G. It says tablet. That's a generic
term. A tablet is a device. This is her cell phone. That is
what Ms. Bergh said. Ms. Bergh explained to you that it was
just capturing generically. Look at the model number. That's
what matters.
And here's the defendant again because the first time
we know failed. Seven sessions? Right? Over and over and
over. The fail, fail, fail. Because it couldn't read the
barcode she was uploading from her Florida Driver's License,
so she does it again. It's the same IP. It's the same
device. It's the same person, the same uniform, May 13, 10:20
AM -- 10:30.
And then we come to May 18. This is the first 2483
form that's DocuSigned. This is part of Government
Exhibit 116. There is the IP address ending in 224. That is
an Verizon IP address. It is the same Verizon IP address that
is used that day, also from an Android app, to access
Mrs. Wade, the defendant's, bank account. Look at the time
zone. Pacific. Minus eight. This was at 7:56 AM Pacific.
That's 10:56 AM East.
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So she signs this one. Mr. Wade testified he didn't
do this one. He said he didn't know who did this one. You
know who did this one. This is Carolyn Wade. The next day,
Mrs. Wade gets an email from Womply explaining this transition
between lenders. Again, tried to go to Harvest initially.
Harvest was told by the SBA no more loans right now. You're
too big. We want to focus on smaller community lenders. This
is what is being told to Carolyn Wade. It's why she has to do
it again. But in between the 18th, when she signs the first
time, and the 28th, when she signs the exact same document --
the fraudulent application -- the second time, she's logging
into Womply.
Here it is on May 19, 2021. She's at work. How do
you know she's at work? That's the BSO IP address. The --
Mr. Rodriguez from the Broward Sheriff's Office came in here
and explained to you he was the network guy and said this was
BSO's IP address. It has been for a very long time.
May 20th, another login from the defendant's cell
phone. The Note20 Ultra 5G. This is from her home. She's
logging in from home. She's also logging into her USAA bank
from home.
May 22, another login. She's now back on Verizon's
network. An IP address ending in 127. That is owned by
Verizon. She's using her phone, that same Samsung, May 22.
This is all between the signing of the first one and the
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second one. Look at how many times she's logging in.
And she hasn't signed the second one yet until she
gets a reminder. And by the way, you're going to have all of
the exhibits. I showed you one reminder. There were multiple
reminders for her to sign. She thought she already signed the
first time -- why do I need to sign again? -- but she keeps
getting this reminder: Sign again, sign again, sign again.
Another login, May 27. This one, again, from the Broward
Sheriff's Office network. You've got to be an employee to log
into that network.
And now we come to the second signing, May 28th,
2021, and here it is. See? This is what Mr. Wade -- he
memorized this. He said it was around 2 o'clock in the
afternoon. I was in the Wade Funeral Home. Yeah, that
specific time. This was signed at 5:15 in the afternoon in
Florida, not California. Because it was signed from the 84 IP
address from the Wade's home -- not Wade Funeral Home, the
home where they lived, right here, 6110 Reese Road, Unit 207,
Davie, Florida, 5:15 PM. And after that, another login from
home, June 5th, 2021 -- continuing to log in, continuing to
participate in this scheme.
Members of the jury, when you finish going through
all the data that shows unquestionably beyond a reasonable
doubt that Carolyn Wade was directly involved in this, there's
one more thing I want to you to do, one more thing I want you
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to look at. Follow the money. Look at the money because the
money trail is even more evidence of the defendant's knowing
participation and intent to defraud.
This, slide 22, is the receipt of the fraudulent PPP
loan, $20,833, on June 7th that was received from Harvest, who
ultimately purchased the loan from Lendistry. That was the
testimony that you heard from Harvest's witness, Ms. Musil.
And that same day, a Zelle payment to Haydee Granados, $1,000.
The balance before that, as you heard from testimony
from Agent DiPietrantonio who looked at all of the bank
records -- it was like $45. All but $45 of this $1,000
payment came from the proceeds of the PPP loan to the person
who uploaded the fake Schedule C. That is evidence of intent
to defraud.
And that's not all they received for this loan, the
Granados and the Riveros. Look at Government 305. That is
the $4,000 check to Jersey City Group, which the parties have
stipulated is associated with Eduardo Rivero. That's a total
of $5,000. All they did was upload a fake Schedule C. Look
at that check. I'll just pull it up so you can see it real
quick.
Do you remember this check, equipment restoration?
That's a phony memo. That's intent. That's trying to hide
the purpose of this. Jersey City Group, $4,000 two days after
receipt of the PPP loan proceeds.
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The money trail doesn't stop at the Granados and the
Riveros. That's not the only instances of sham checks that we
saw here. It continues. And it continues with all the checks
that Carolyn Wade wrote to herself and to her husband for,
quote, salary. That is evidence of intent to defraud. Every
single one of these checks. Mr. Wade wasn't a salaried
employee of Carolyn Wade. He testified to that. When
Mr. Zacca asked him do you do anything for this hairstyling
business, he looked at Mr. Zacca like he had two heads.
Of course he didn't do anything for the hairstyling
business. She's writing checks to herself and her husband
over and over again for salary. And Mr. Wade stumbled to come
up with some explanation for this. Oh, I was giving her cash
and then she was writing me a check. Does that make any
sense? Why would he give her cash and then write her a check?
They had the same bank account. Their money is pooled. It
doesn't make any sense.
And he couldn't explain why she had written salary.
We know why she wrote salary. Look at this again and again
and again and again. Over, over. Never did it before receipt
of the PPP loan when you look at the bank records that we have
going back to 2019. Didn't do it again once it was forgiven.
The checks, members of the jury, are evidence that
Carolyn Wade knew this was a program to protect payroll -- to
protect payroll of small businesses, but she didn't have
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payroll from a small business, so she made it up to make it
look legitimate, to make it look like she was protecting a
small business that had payroll to herself. And when you add
up all of these checks, it's like $13,000 in salary checks.
That's twice as much money as she reported to the IRS of her
business making in 2019. Remember, she reported $6,800?
She's writing $13,000, twice as much in salary checks.
This was a lie about payroll. This was a lie to make
payroll look legitimate under the Paycheck Protection Program.
So she knew the purpose of the program. And she knew that in
order to get the loan forgiven, which she wanted to do, she
had to show payroll. That's exactly what she did.
Another login July 26, a reminder about forgiveness
on August 7th, and then there it is. She applies for
forgiveness. And when you look at Government Exhibit 118,
which I showed you at the beginning of this argument, you saw
she had written how much she had spent on payroll, 20,833.
Another lie.
This is the last slide of the presentation. You're
not going to have this one in the jury room because this is
something -- this is a summary slide. But take a look at it
now. Look at every instance of Carolyn Wade participating in
her own fraudulent PPP loan application.
This is everything you need to know. This is her
knowledge. This is her intent to defraud the Paycheck
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Protection Program. This proves beyond a reasonable doubt
that Carolyn Wade is guilty of wire fraud.
THE COURT: Excuse me. 40 minutes has elapsed.
MR. SNIDER: And that is exactly the verdict we are
going to ask you to return, a verdict of guilty. Thank you.
* * * * *
MR. SNIDER: Data doesn't lie. There is no
credibility finding in data. It is a historical record
captured of electronic information transmitted, and it gives
you everything you need in this case to see the Defendant
acting -- knowingly acting with intent to defraud in this
scheme.
This case is really about data. There's a lot of it.
And it may be hard to parse through, but you can do it. You
have it and you have the summaries explaining what the data
is. Mr. McCray makes a point about reasonable doubt. The
Government does have the sole burden in this case, and its
burden is heavy. But the doubt that he is trying to raise in
this data is not reasonable. It's not reasonable. The
numbers are what they are. The IP addresses are what they
are, the model numbers of the phone of the defendant. It is
what it is.
You're going to hear a definition of reasonable
doubt. It's proof so convincing that you would rely on it --
you rely and act on it without hesitation in your most
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important of affairs. So look at this data. Would you rely
on it? Would you look at that IP address and know that's
Mr. Wade, coupled with his testimony, that he was at the Wade
Funeral Home that day? Would you rely on this data? This
data is the truth of this case of what really happened. It is
a digital record of the defendant's own participation in this
scheme.
You heard the defense's theory in this case that the
Wades trusted Haydee Granados. They trusted her. They
trusted Mr. Rivero. Apparently, this is what they did. I'll
ask you again. How do you trust somebody to put in accurate
tax information about a business when you never gave them the
information in the first place? This isn't about trust. This
is a scheme. This is intentional. Paying them to put in a
fake tax document, that in itself was the first red flag.
The Paycheck Protection Program for Schedule C filers
was based on gross income. And they didn't give the one piece
of information showing what the gross income was. And it also
wasn't for 1 Step A-Head. Mr. McCray argues that the
defendant didn't know all the intricacies of this program,
didn't know the regulations. Did she know that she didn't
have a business named Carolyn Wade? Did she know that in
every single one of these documents that you've seen the word
1 Step A-Head doesn't appear anywhere? It is painfully
obvious that this was not a loan for any company that the
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defendant had.
But that was seen over and over and over and over
again. Data doesn't lie. It shows you the defendant
uploading her bank statements. That's what's there. Look at
the events tab on that exhibit on that spreadsheet. You also
heard Mr. McCray argue that why would she do this? Why would
the defendant do this if she knew that she had real tax
returns filed with the IRS and the IRS could just check and
see that this was all fake? It wasn't easily detectable.
You heard from the SBA witness. There were millions
and millions and millions of these loans. Impossible to check
them all, which is exactly why that application contains a
self-certification by the borrower that all of the information
is true. That was the testimony from the SBA. They rely on
the borrower to be truthful. This was a trust-based system.
There was a breach of trust in this case. There
wasn't a breach of trust by Haydee Granados. It was a breach
of trust with the SBA and the lenders that were trying to move
money out to small businesses as quickly as possible during
the pandemic. That's the breach of trust. It was a
trust-based system that depended entirely upon
self-certification because there were so many of these loans
because this was a pandemic. And as the SBA testified, small
businesses are the heartbeat of the economy. That is why this
program was focused on small businesses.
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You heard Mr. McCray argue something to the effect
that Haydee Granados was logged into the defendant's email
address or email account. No. No. Go back to the data.
What the data shows is that there was two ways to log into
Womply. One was to supply Carolyn Wade's email address,
ckidd, and the other was to supply her phone number. And if
you supplied the email, then the one-time code got to her
email address, the defendant's. And if you logged in using
the cell phone -- her cell phone, the code got sent by SMS
text to her cell phone, which means that every time there was
a login, the defendant knew about it because she's getting the
code.
So there was a login into her Gmail. They want you
to believe that she would give her email password to the
Granados? She doesn't know Haydee Granados. She's going to
give her her email password? Does that make sense?
I want you to take your common sense into the jury
room. Mr. McCray does too. Take your common sense. Because
the common sense that you have with this data -- looking at
this data with common sense shows there is no reasonable doubt
in this case that the defendant knowingly and intentionally
participated in this scheme to defraud.
Mr. McCray talked about the defendant's work
schedule. There was no testimony about that, but there was a
document, and there was no testimony because, again, just to
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be clear, she has no burden. So the defendant has no burden.
She doesn't have to call any witnesses at all. But he did
introduce this record of her work schedule, and we're in
agreement about this; yeah, the defendant was at work. You
saw the picture of her in her BSO uniform taking selfies of
herself to verify her identity. And the reason that she's on
Verizon's network is because she's not at home. She's on a
cell network. She's on her cell phone. That's not reasonable
doubt. You have it right in front of you.
The data in this case shows the defendant's
participation. It shows it wasn't an accident. She wasn't
tricked into doing this. These were intentional acts. And if
you want the context that Mr. McCray is asking for, you want
the circumstances of this, follow the money. Look at those
checks and look at the bank accounts. Do you see anywhere in
the range of these, quote, salary checks being written other
than when the defendant gets the PPP loan?
Do you want context? Look at the sham memo -- the
sham memo to the Granados, to Jersey City, equipment
restoration. Sure. Maybe they did tell her that, but she
wrote it. It doesn't make sense. Take your common sense.
Why would you write equipment restoration to the person who
just uploaded a fake Schedule C into your account? Use your
common sense.
That gives you the context. That gives you the
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circumstances. $13,000 worth of checks. Twice as much money
as 1 Step A-Head made in 2019. 1 Step A-Head not mentioned
anywhere. Use your common sense. That is the circumstances.
That is the context that you need. You have that. Take that
context and look at the evidence through that lens.
This was a scheme. This was a plan. This was
intentional. This was the defendant participating in this
scheme. And what Haydee Granados did and what her husband did
in this does not undo what the defendant knew and what the
defendant did. It's not a defense. They were involved as
well, but ultimately, this is Carolyn Wade's Paycheck
Protection Program loan. This is Carolyn Wade pretending that
she is protecting paychecks. She's not.
This is a scheme. And Carolyn Denise Wade is guilty
of participating in this scheme knowingly and with the intent
to defraud. Carolyn Wade is guilty of wire fraud, and that is
the verdict we are asking you to return based on the evidence
in this case and your common sense looking at all of that
evidence. The data doesn't lie. Thank you.
* * * * *
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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 112 Entered on FLSD Docket 07/25/2024 Page 31 of 38
$
$1,000 [2] - 22:8,
22:11
$10,600 [1] - 12:2
$113,000 [2] - 5:20,
5:21
$113,560 [1] - 8:22
$13,000 [3] - 24:4,
24:7, 29:25
$20,833 [1] - 22:5
$4,000 [2] - 22:17,
22:24
$45 [2] - 22:11
$5,000 [3] - 11:4,
12:16, 22:19
$57,000 [1] - 12:3
$6,800 [2] - 11:17,
24:6
$67,770 [1] - 11:25
$8,400 [1] - 12:16
'
'18 [1] - 11:24
'19 [1] - 11:24
'20 [1] - 11:24
/
/s/Lance [1] - 31:5
0
0 [1] - 16:11
1
1 [15] - 1:8, 10:2,
10:3, 10:4, 10:11,
10:13, 10:16, 11:1,
11:15, 11:25, 12:3,
26:19, 26:24, 30:1
102.1E [1] - 16:14
102.2E [2] - 16:14,
16:17
102E [2] - 16:14,
16:15
10:00 [1] - 19:3
10:08 [1] - 18:18
10:09 [2] - 18:24,
18:25
10:20 [1] - 19:16
10:30 [1] - 19:17
10:51 [1] - 18:19
10:56 [1] - 19:25
11 [3] - 3:10, 3:11,
3:12
113 [1] - 8:3
113,560 [1] - 11:17
116 [2] - 8:14, 19:20
117 [1] - 8:25
118 [1] - 24:15
125 [2] - 17:11, 18:10
127 [1] - 20:23
12:09 [1] - 18:25
13 [2] - 17:19, 19:16
13th [7] - 16:25, 17:3,
17:7, 17:9, 17:13,
18:4, 18:15
166 [3] - 15:1, 16:9,
17:10
18 [1] - 19:18
18th [4] - 2:17, 8:15,
20:9, 31:5
19 [1] - 20:13
2
2 [6] - 15:10, 15:11,
15:14, 15:16,
15:25, 21:13
20 [2] - 1:5, 4:17
20,833 [1] - 24:17
200 [1] - 11:13
201 [1] - 11:13
2018 [2] - 10:14,
11:14
2019 [8] - 5:22, 8:22,
10:14, 11:15,
11:16, 23:22, 24:6,
30:1
202 [1] - 11:13
2020 [2] - 10:14,
11:14
2020s [1] - 10:15
2021 [5] - 15:7, 16:7,
20:13, 21:12, 21:20
2023 [1] - 13:13
2024 [2] - 1:5, 31:5
203 [1] - 11:13
207 [1] - 21:18
20th [1] - 20:18
22 [3] - 20:22, 20:24,
22:4
224 [1] - 19:20
23-CR-60173 [1] - 1:2
24,000 [1] - 12:19
2483 [1] - 19:18
25 [1] - 11:9
26 [1] - 24:13
27 [2] - 12:4, 21:8
28 [1] - 15:7
28th [2] - 20:10,
21:11
2:09 [1] - 19:1
2:15 [3] - 15:20,
15:23, 15:24
3
305 [1] - 22:16
305.523.5633 [1] -
1:21
31 [1] - 1:8
33060 [1] - 2:14
33128 [1] - 1:20
33317 [1] - 2:17
33394 [2] - 2:5, 2:9
34 [1] - 17:10
4
4 [3] - 15:4, 15:5,
16:7
40 [2] - 4:15, 25:3
400 [2] - 1:20, 2:13
4th [3] - 16:21, 16:24,
17:3
5
500 [2] - 2:4, 2:8
5201 [1] - 2:17
5:15 [4] - 15:24, 16:1,
21:15, 21:19
5G [4] - 6:24, 18:3,
19:6, 20:19
5th [1] - 21:20
6
6110 [1] - 21:18
7
7 [2] - 2:4, 2:8
7:56 [1] - 19:24
7th [2] - 22:5, 24:14
8
8 [1] - 18:5
802 [1] - 6:25
84 [1] - 21:16
8:23 [1] - 17:17
9
90 [2] - 14:15, 14:20
954-303-1457 [1] -
2:18
954-660-5696 [1] -
2:5
954-660-5789 [1] -
2:9
954-781-3662 [1] -
2:14
9:21 [2] - 17:17,
18:17
9:23 [1] - 18:17
9:40 [1] - 4:3
A
A-Head [13] - 10:3,
10:4, 10:11, 10:13,
10:16, 11:1, 11:15,
11:25, 12:4, 26:19,
26:24, 30:1
able [1] - 4:20
above-entitled [1] -
31:3
access [3] - 14:7,
14:8, 19:22
accident [1] - 29:10
according [1] - 10:23
account [9] - 7:15,
16:22, 17:25,
18:10, 18:21,
19:23, 23:16, 28:3,
29:22
accounts [1] - 29:14
accurate [2] - 6:4,
26:11
act [1] - 25:25
acting [2] - 25:11
activity [3] - 18:5,
18:11, 18:12
acts [1] - 29:11
actual [1] - 14:18
add [1] - 24:3
addition [1] - 17:25
address [17] - 14:25,
15:18, 16:9, 17:10,
17:24, 18:10,
19:20, 19:21,
20:14, 20:17,
20:23, 21:17, 26:2,
28:3, 28:5, 28:8
addresses [1] - 25:20
advance [1] - 10:9
affairs [2] - 13:11,
26:1
afternoon [6] - 15:10,
15:14, 15:16,
15:21, 21:14, 21:15
afterwards [2] - 4:19,
8:7
32
Agent [2] - 18:1,
22:10
agreement [1] - 29:3
Ahead [1] - 10:3
aided [1] - 1:23
air [1] - 5:25
ALSO [1] - 2:20
alter [1] - 3:16
AM [9] - 4:3, 17:17,
18:17, 18:24, 19:3,
19:16, 19:24, 19:25
Aman [1] - 7:2
amended [1] - 10:15
AMERICA [1] - 1:4
Android [2] - 17:24,
19:22
answer [1] - 13:10
app [3] - 17:23,
17:24, 19:22
apparent [1] - 6:9
appear [1] - 26:24
APPEARANCES [1] -
2:1
application [21] -
5:15, 8:15, 8:25,
9:6, 9:25, 10:4,
10:12, 10:13,
11:16, 13:19,
14:18, 14:23, 15:5,
15:7, 15:16, 16:3,
16:7, 17:2, 20:11,
24:23, 27:12
applications [2] -
9:24, 10:12
applies [1] - 24:14
applying [2] - 6:16,
7:22
argue [2] - 27:6, 28:1
argues [1] - 26:19
argument [5] - 4:10,
4:13, 4:15, 4:18,
24:16
arguments [3] - 3:3,
3:24, 4:9
assigned [1] - 16:9
associated [1] -
22:18
assume [1] - 4:14
AT&T [1] - 16:9
Atlantic [1] - 2:13
attempts [1] - 17:17
attention [1] - 3:17
Attorney's [2] - 2:4,
2:8
August [1] - 24:14
AUSA [2] - 2:3, 2:7
Avenue [1] - 1:20
Case 0:23-cr-60173-KMW Document 112 Entered on FLSD Docket 07/25/2024 Page 32 of 38
B
balance [1] - 22:9
bank [15] - 7:13, 7:15,
16:21, 17:24, 18:9,
18:21, 19:23,
20:20, 22:10,
23:16, 23:21, 27:4,
29:14
barcode [2] - 7:22,
19:14
based [7] - 5:5, 5:7,
5:17, 26:17, 27:15,
27:21, 30:16
Beach [1] - 2:14
BEFORE [1] - 1:12
beginning [2] - 5:18,
24:16
BEHALF [1] - 2:11
bergh [1] - 19:8
Bergh [2] - 7:20, 19:8
best [1] - 17:5
between [10] - 9:1,
11:24, 12:13,
16:24, 18:16,
18:18, 19:1, 20:5,
20:9, 20:25
beyond [3] - 5:13,
21:23, 25:1
big [2] - 9:2, 20:7
blame [2] - 13:3
blank [1] - 16:18
borrower [3] - 9:18,
27:13, 27:15
Boulevard [3] - 2:4,
2:8, 2:13
box [1] - 11:16
breach [4] - 27:16,
27:17, 27:20
break [2] - 3:22, 3:24
bring [1] - 4:2
bringing [1] - 3:16
Broward [5] - 2:4,
2:8, 12:23, 20:15,
21:8
BSO [9] - 10:6, 10:7,
10:8, 12:5, 14:8,
14:11, 18:23,
20:14, 29:4
BSO's [1] - 20:17
bunch [1] - 17:7
burden [5] - 4:11,
25:17, 25:18, 28:25
business [34] - 5:22,
5:24, 6:2, 6:5, 6:14,
8:9, 8:11, 8:17,
8:18, 8:19, 8:20,
8:21, 8:23, 9:8,
9:14, 9:16, 10:1,
10:5, 10:6, 11:1,
11:20, 12:18,
12:20, 13:13,
13:16, 13:17,
16:19, 23:9, 23:11,
24:1, 24:3, 24:6,
26:12, 26:22
businesses [4] -
23:25, 27:19,
27:24, 27:25
busy [1] - 17:5
C
California [2] - 15:25,
21:16
captured [4] - 7:8,
14:13, 18:1, 25:9
capturing [1] - 19:9
CAROLYN [1] - 1:7
Carolyn [48] - 2:20,
5:3, 5:9, 5:24, 6:2,
6:5, 6:7, 6:15, 8:10,
8:11, 8:17, 8:18,
8:20, 8:21, 8:23,
9:9, 11:1, 11:14,
11:25, 12:3, 12:6,
13:18, 14:15,
14:22, 16:2, 16:19,
17:4, 17:13, 17:18,
17:24, 18:18,
18:22, 20:3, 20:8,
21:24, 23:4, 23:7,
23:24, 24:22, 25:2,
26:22, 28:5, 30:10,
30:11, 30:13, 30:15
case [16] - 5:9, 5:19,
6:14, 12:9, 13:22,
16:2, 25:10, 25:13,
25:17, 26:5, 26:8,
27:16, 28:20, 29:9,
30:17
CASE [1] - 1:2
cash [2] - 23:13,
23:15
cell [10] - 6:23, 14:8,
14:12, 19:7, 20:18,
28:8, 28:9, 28:10,
29:7
certainly [2] - 6:7,
8:22
certificate [1] - 15:22
CERTIFICATE [1] -
31:1
certification [2] -
27:13, 27:22
certified [1] - 9:21
certify [2] - 9:18, 31:2
chair [1] - 11:22
changes [1] - 14:18
check [7] - 22:17,
22:20, 22:22,
23:14, 23:15, 27:8,
27:11
checked [1] - 11:17
checks [11] - 23:2,
23:3, 23:6, 23:11,
23:23, 24:4, 24:7,
29:14, 29:15, 29:25
circumstances [3] -
29:13, 29:25, 30:2
City [3] - 22:17,
22:24, 29:18
ckidd [1] - 28:5
claiming [2] - 12:14,
12:15
clear [3] - 12:6,
15:14, 28:25
clearly [2] - 13:2,
18:23
CLOSING [1] - 1:6
closing [4] - 3:2, 4:9,
4:10, 4:15
Coast [3] - 15:21,
15:24, 16:1
code [3] - 28:7, 28:9,
28:11
color [1] - 6:25
comments [2] - 3:7,
3:18
common [8] - 28:16,
28:17, 28:18,
28:19, 29:20,
29:23, 30:2, 30:17
community [1] - 20:7
company [2] - 6:8,
26:25
completed [1] - 4:8
computer [4] - 1:23,
5:1, 6:18, 16:9
computer-aided [1] -
1:23
concluded [1] - 3:25
confirmed [1] - 6:2
connection [1] - 4:25
consider [1] - 12:8
considering [1] -
13:7
contact [1] - 8:21
contains [1] - 27:12
context [5] - 29:12,
29:17, 29:24, 30:3,
30:4
continues [2] - 23:3
continuing [2] -
21:20
convincing [1] -
25:24
Coordinated [1] -
19:2
copper [1] - 6:24
Coral [1] - 12:22
correct [1] - 31:2
correction [1] - 3:21
corresponds [1] -
18:20
cost [2] - 11:24, 12:2
costing [1] - 12:17
County [1] - 12:23
couple [1] - 14:6
coupled [1] - 26:3
course [3] - 5:12,
13:4, 23:10
COURT [9] - 1:1, 3:2,
3:5, 3:11, 3:15,
3:20, 4:4, 4:24,
25:3
Court [5] - 1:19, 1:19,
3:1, 31:6, 31:7
Court's [2] - 3:13, 5:6
COURTROOM [1] -
5:2
courtroom [1] - 7:9
create [1] - 11:9
credibility [1] - 25:8
CRIMINAL [1] - 1:2
customer [1] - 17:22
D
DARYL [1] - 2:16
darylewilcox06@
gmail.com [1] -
2:18
data [31] - 10:24,
13:21, 13:22,
13:23, 14:5, 14:16,
14:17, 14:19,
14:24, 15:2, 15:4,
16:2, 16:5, 16:23,
21:23, 25:7, 25:8,
25:13, 25:15,
25:19, 26:1, 26:4,
26:5, 27:3, 28:3,
28:4, 28:18, 28:19,
29:9, 30:18
DATE [1] - 31:5
DAVID [1] - 2:3
david.snider@
usdoj.gov [1] - 2:6
Davie [1] - 21:19
days [1] - 22:24
decide [1] - 3:22
Defendant [3] - 1:8,
10:13, 25:10
DEFENDANT [1] -
2:11
defendant [36] - 5:9,
33
5:14, 6:15, 6:20,
6:23, 7:11, 7:12,
7:14, 7:17, 7:22,
9:7, 9:20, 9:23,
10:1, 10:5, 14:7,
14:10, 16:3, 17:13,
18:3, 18:8, 18:18,
18:22, 19:11,
26:20, 27:1, 27:3,
27:7, 28:11, 28:20,
28:25, 29:3, 29:16,
30:6, 30:8, 30:9
defendant's [14] -
6:1, 8:7, 8:16, 8:19,
9:11, 13:1, 19:23,
20:18, 22:2, 26:6,
28:2, 28:8, 28:22,
29:9
defendants [1] -
25:21
defense [4] - 3:8,
3:10, 4:15, 30:9
defense's [1] - 26:8
definition [1] - 25:23
defraud [8] - 5:11,
22:3, 22:14, 23:5,
24:25, 25:11,
28:21, 30:15
deliberate [1] - 4:21
denied [1] - 14:22
Denise [3] - 5:3, 5:9,
30:13
depended [1] - 27:21
DEPUTY [1] - 5:2
DERIC [1] - 2:7
deric.zacca@usdoj.
gov [1] - 2:10
designed [1] - 7:8
detail [1] - 6:23
detailed [2] - 16:17,
18:14
detectable [1] - 27:9
device [5] - 7:1, 18:1,
19:5, 19:7, 19:15
difference [1] - 19:1
different [1] - 16:15
digital [2] - 13:23,
26:6
DiPietrantonio [2] -
18:2, 22:10
directly [5] - 5:14,
5:16, 16:3, 16:4,
21:24
discrepancies [1] -
12:13
discrepancy [1] -
12:13
dispute [1] - 8:5
disregard [1] - 3:21
DISTRICT [3] - 1:1,
Case 0:23-cr-60173-KMW Document 112 Entered on FLSD Docket 07/25/2024 Page 33 of 38
1:1, 1:13
District [3] - 1:19,
31:7, 31:7
DIVISION [1] - 1:2
document [7] - 9:5,
16:21, 18:7, 18:9,
20:10, 26:15, 28:24
documents [4] - 8:1,
9:22, 10:4, 26:23
DocuSign [1] - 15:22
DocuSigned [2] -
15:6, 19:19
DONALD [1] - 1:12
done [1] - 17:2
doubt [8] - 5:14,
21:24, 25:1, 25:16,
25:18, 25:24,
28:19, 29:8
down [1] - 8:12
driven [1] - 12:19
Driver's [1] - 19:14
during [4] - 14:8,
14:11, 18:1, 27:19
E
earning [1] - 12:2
easily [1] - 27:9
East [7] - 2:4, 2:8,
2:13, 15:21, 15:24,
16:1, 19:25
Eastern [4] - 16:1,
18:16, 18:25, 19:2
economy [1] - 27:24
Eduardo [3] - 10:22,
13:3, 22:18
effect [2] - 13:10,
28:1
EIDL [1] - 13:14
eight [1] - 19:24
elapsed [1] - 25:3
electronic [1] - 25:9
email [9] - 17:3, 20:4,
28:2, 28:3, 28:5,
28:7, 28:13, 28:15
employee [3] - 10:7,
21:9, 23:7
employees [3] - 6:6,
9:10
employment [1] -
10:8
ended [1] - 17:10
ending [2] - 19:20,
20:23
enormous [2] -
12:14, 12:15
entered [1] - 7:6
enters [1] - 4:3
entirely [1] - 27:21
entitled [1] - 31:3
equipment [3] -
22:22, 29:18, 29:21
ESQ [2] - 2:12, 2:16
essentially [1] - 5:7
events [2] - 13:19,
27:5
evidence [14] - 4:8,
5:13, 6:13, 6:22,
7:5, 9:7, 22:2,
22:13, 23:5, 23:23,
30:4, 30:16, 30:18
exact [3] - 9:4, 9:5,
20:10
exactly [7] - 5:8,
5:16, 7:10, 17:6,
24:12, 25:4, 27:12
example [2] - 14:6,
14:14
examples [2] - 14:4,
14:6
except [1] - 18:11
EXCERPT [1] - 1:11
excuse [1] - 25:3
Exhibit [7] - 6:25,
8:3, 8:14, 11:13,
16:14, 19:20, 24:15
exhibit [1] - 27:5
exhibits [1] - 21:4
exist [3] - 5:23, 6:8,
9:17
expenses [2] - 11:20,
12:1
explain [2] - 13:16,
23:18
explained [3] - 7:4,
19:8, 20:16
explaining [2] - 20:4,
25:15
explanation [1] -
23:13
extraordinary [2] -
11:20, 13:25
F
face [1] - 19:4
fail [3] - 19:13
failed [1] - 19:12
failures [1] - 7:21
faith [3] - 3:10, 3:13,
3:21
fake [20] - 8:2, 8:10,
9:10, 9:16, 9:24,
11:1, 11:4, 11:5,
11:9, 12:14, 14:18,
18:7, 18:11, 22:13,
22:19, 26:15, 27:9,
29:22
false [4] - 5:8, 9:15,
9:20
far [2] - 14:17, 18:12
FCRR [2] - 1:18, 31:6
few [4] - 6:3, 8:2, 8:8,
14:4
fifteen [1] - 18:20
fighting [1] - 15:2
filed [4] - 10:16,
10:21, 12:15, 27:8
filers [1] - 26:16
finally [1] - 15:6
finish [2] - 17:6,
21:22
first [13] - 4:11, 6:20,
8:8, 8:14, 14:5,
16:11, 19:11,
19:18, 20:9, 20:25,
21:6, 26:13, 26:15
five [3] - 17:14,
17:19, 18:4
flag [1] - 26:15
Floor [2] - 2:4, 2:8
FLORIDA [1] - 1:1
Florida [12] - 1:4,
1:20, 2:5, 2:9, 2:14,
2:17, 16:1, 19:14,
21:16, 21:19, 31:7,
31:8
focus [2] - 8:1, 20:7
focused [1] - 27:25
follow [2] - 22:1,
29:13
FOR [1] - 2:2
foregoing [1] - 31:2
forgiven [2] - 23:22,
24:11
forgiveness [4] - 9:6,
9:25, 24:13, 24:15
form [1] - 19:19
Fort [2] - 2:5, 2:9
fortunately [1] - 4:6
four [3] - 9:23, 17:14,
19:2
FPR [2] - 1:18, 31:6
FPR-C [2] - 1:18,
31:6
fraud [2] - 25:2,
30:15
fraudulent [6] - 5:15,
6:1, 8:15, 20:11,
22:4, 24:23
Friday [3] - 6:2,
10:18, 13:1
front [5] - 14:24,
15:1, 17:20, 19:4,
29:8
funded [1] - 9:17
funeral [3] - 13:12,
15:19, 18:17
Funeral [11] - 10:10,
14:25, 15:9, 15:15,
15:17, 16:8, 16:10,
16:22, 21:14,
21:17, 26:4
G
garage [4] - 11:21,
11:22, 11:23, 12:17
generic [1] - 19:6
generically [1] - 19:9
gentlemen [1] - 4:4
Gmail [1] - 28:12
good-faith [2] - 3:10,
3:13
GOVERNMENT [1] -
2:2
Government [14] -
4:10, 4:12, 4:13,
4:16, 4:22, 8:2,
8:14, 8:25, 11:13,
16:14, 19:19,
22:16, 24:15, 25:17
Government's [1] -
6:25
GOVERNMENT'S [1]
- 1:6
GRAHAM [2] - 1:2,
1:12
Granados [21] - 8:5,
8:6, 10:21, 10:25,
11:7, 13:3, 14:17,
14:23, 17:11,
17:15, 18:6, 22:8,
22:16, 23:1, 26:9,
27:17, 28:2, 28:14,
29:18, 30:7
great [2] - 5:1, 6:22
greeted [1] - 4:5
gross [4] - 5:22, 8:22,
26:17, 26:18
Group [2] - 22:17,
22:24
guess [2] - 15:15,
15:23
guilty [4] - 25:2, 25:5,
30:13, 30:15
guy [1] - 20:16
H
hairstyling [5] -
11:20, 12:18,
12:20, 23:8, 23:10
hands [1] - 19:4
handsomely [1] -
14:21
hard [2] - 13:6, 25:14
34
Harvest [4] - 9:2,
20:5, 20:6, 22:5
Harvest's [1] - 22:7
Haydee [17] - 8:4,
8:6, 10:21, 10:25,
13:3, 14:15, 14:17,
16:19, 17:11,
17:15, 18:6, 22:8,
26:9, 27:17, 28:2,
28:14, 30:7
HDMI [1] - 4:25
Head [13] - 10:3,
10:4, 10:11, 10:13,
10:16, 11:1, 11:15,
11:25, 12:4, 26:19,
26:24, 30:1
heads [1] - 23:9
hear [2] - 5:6, 25:23
heard [9] - 7:7, 10:6,
17:25, 22:7, 22:9,
26:8, 27:6, 27:10,
28:1
heartbeat [1] - 27:24
heavy [1] - 25:18
HELD [1] - 1:12
Hely [1] - 10:7
Hendrith [1] - 2:20
herself [6] - 7:19,
14:11, 23:4, 23:11,
24:3, 29:5
hesitation [1] - 25:25
hide [1] - 22:23
historical [1] - 25:8
holding [2] - 14:12,
19:3
home [12] - 9:7,
13:12, 15:19,
15:20, 18:17,
20:19, 20:20,
20:21, 21:17,
21:18, 21:20, 29:6
Home [11] - 10:10,
14:25, 15:9, 15:15,
15:17, 16:8, 16:10,
16:22, 21:14,
21:17, 26:4
Honor [2] - 3:9, 4:23
HONORABLE [1] -
1:12
hour [3] - 4:10, 4:12,
4:16
hours [4] - 13:8,
14:8, 14:11, 19:2
husband [8] - 6:1,
10:9, 11:21, 12:22,
13:1, 23:4, 23:11,
30:7
hypothetically [1] -
4:14
Case 0:23-cr-60173-KMW Document 112 Entered on FLSD Docket 07/25/2024 Page 34 of 38
I
ID [1] - 14:2
idea [1] - 11:4
identical [1] - 8:25
identity [3] - 7:17,
18:23, 29:5
important [1] - 26:1
impossible [5] - 6:11,
8:13, 9:22, 27:11
included [3] - 3:13,
10:17, 10:18
income [7] - 5:22,
6:7, 8:10, 8:22,
9:16, 26:17, 26:18
information [21] -
7:9, 8:11, 9:15,
9:16, 10:20, 10:21,
10:24, 10:25, 11:3,
11:5, 11:6, 11:10,
14:1, 14:19, 16:15,
16:18, 25:9, 26:12,
26:13, 26:18, 27:13
initial [1] - 4:17
instance [1] - 24:22
instances [2] - 6:17,
23:2
instruction [1] - 3:13
instructions [3] - 3:6,
4:20, 5:7
intended [1] - 5:17
intent [8] - 5:10, 22:3,
22:13, 22:23, 23:5,
24:25, 25:11, 30:14
intentional [3] -
26:14, 29:11, 30:6
intentionally [1] -
28:20
interaction [1] - 13:7
intricacies [1] - 26:20
introduce [1] - 29:2
involved [5] - 5:16,
16:3, 16:4, 21:24,
30:9
involvement [1] -
14:22
IP [17] - 14:25, 15:18,
16:9, 17:10, 17:24,
18:10, 18:21,
19:15, 19:20,
19:21, 20:14,
20:17, 20:23,
21:16, 25:20, 26:2
IRS [10] - 10:2, 10:5,
10:16, 10:21,
11:15, 12:1, 12:15,
24:5, 27:8
issue [2] - 9:1, 9:3
itself [1] - 26:15
J
Jersey [3] - 22:17,
22:24, 29:18
Joanna [1] - 10:7
job [1] - 14:20
JOHNNY [1] - 2:12
Johnny [1] - 2:13
JR [1] - 2:12
Jr [1] - 2:13
JUDGE [1] - 1:13
Judge [4] - 3:4, 3:8,
3:12, 3:19
July [2] - 24:13, 31:5
jumping [2] - 9:5, 9:8
jumps [6] - 6:18, 8:9,
8:12, 8:17, 8:23
June [2] - 21:20, 22:5
jurors [1] - 4:1
jury [6] - 4:2, 5:3,
21:22, 23:23,
24:20, 28:16
Jury [1] - 4:3
K
keep [1] - 12:19
keeps [1] - 21:6
key [1] - 14:1
kind [1] - 16:16
knowing [2] - 9:21,
22:2
knowingly [4] - 5:10,
25:11, 28:20, 30:14
knowledge [1] -
24:25
known [2] - 6:12,
9:15
L
ladies [1] - 4:4
Lance [1] - 31:5
LANCE [1] - 1:18
last [2] - 7:3, 24:19
Lauderdale [2] - 2:5,
2:9
law [1] - 4:20
Law [1] - 2:13
learned [1] - 10:18
least [2] - 6:23, 13:8
legal [1] - 6:14
legitimate [2] - 24:2,
24:9
lenders [6] - 9:2,
9:13, 9:19, 20:5,
20:7, 27:18
Lendistry [2] - 9:3,
22:6
lens [1] - 30:4
License [1] - 19:14
lie [26] - 5:20, 5:21,
5:22, 6:6, 6:9, 6:15,
6:16, 6:17, 6:21,
7:12, 7:14, 7:16,
8:9, 8:12, 8:16,
11:8, 13:21, 15:2,
24:8, 24:18, 25:7,
27:3, 30:18
lies [6] - 5:5, 5:8,
5:17, 5:18, 9:5, 9:8
line [1] - 8:8
linked [2] - 7:15,
16:21
linking [1] - 18:9
literally [5] - 6:18,
8:9, 8:12, 8:23,
13:25
live [1] - 15:19
lived [1] - 21:18
living [3] - 12:20,
12:21, 12:23
loan [27] - 5:4, 5:15,
5:17, 6:1, 6:8, 9:17,
9:24, 10:4, 10:12,
13:14, 13:17,
13:19, 14:16, 15:6,
15:15, 16:3, 22:5,
22:6, 22:12, 22:15,
22:25, 23:21,
24:11, 24:23,
26:25, 29:16, 30:11
loans [4] - 13:15,
20:6, 27:11, 27:22
log [5] - 18:3, 18:21,
21:9, 21:20, 28:4
logged [9] - 6:21,
7:14, 7:16, 7:18,
7:24, 17:19, 18:11,
28:2, 28:8
logging [8] - 8:7,
17:11, 18:8, 20:11,
20:20, 21:1
login [13] - 7:4, 7:11,
17:9, 17:15, 17:17,
18:6, 20:18, 20:22,
21:8, 21:19, 24:13,
28:10, 28:12
logins [5] - 17:7,
17:14, 17:18,
17:23, 18:12
logs [1] - 17:12
look [37] - 6:13, 6:24,
8:8, 9:7, 9:22,
11:12, 11:19,
12:10, 12:12,
12:13, 12:21, 15:4,
15:21, 16:16,
18:16, 19:9, 19:23,
21:1, 22:1, 22:16,
22:19, 23:19,
23:21, 24:2, 24:9,
24:15, 24:21,
24:22, 26:1, 26:2,
27:4, 29:13, 29:14,
29:17, 30:4
looked [2] - 22:10,
23:9
looking [2] - 28:18,
30:17
losses [1] - 12:16
love [1] - 13:9
loves [3] - 13:5, 13:6
Lucie [2] - 12:20,
12:24
M
made-up [1] - 11:18
matching [1] - 17:25
matter [1] - 31:3
matters [2] - 11:16,
19:10
maximum [1] - 4:9
MCCRAY [4] - 2:12,
3:4, 3:8, 3:19
McCray [8] - 2:13,
25:16, 26:19, 27:6,
28:1, 28:17, 28:22,
29:12
mccrayjlaw@gmail.
com [1] - 2:15
meaning [1] - 17:19
means [3] - 12:2,
16:11, 28:10
mechanical [1] - 1:23
members [3] - 5:3,
21:22, 23:23
memo [3] - 22:23,
29:17, 29:18
memorized [2] -
15:22, 21:13
memory [1] - 15:14
mentioned [2] -
10:11, 30:1
Miami [4] - 1:4, 1:20,
1:20, 31:8
midst [1] - 9:14
miles [1] - 12:19
millions [3] - 27:10,
27:11
minus [1] - 19:24
minute [1] - 6:4
minutes [4] - 4:15,
4:17, 8:8, 25:3
missed [1] - 9:23
35
missing [1] - 4:6
Model [1] - 17:21
model [3] - 14:13,
19:9, 25:21
money [14] - 5:7,
9:14, 11:1, 12:18,
13:12, 22:1, 22:2,
23:1, 23:16, 24:5,
27:19, 29:13, 29:25
morning [2] - 4:4, 4:6
most [1] - 25:25
move [1] - 27:18
MR [10] - 3:4, 3:8,
3:9, 3:12, 3:19,
4:23, 4:25, 5:3,
25:4, 25:7
multiple [1] - 21:4
Musil [1] - 22:7
N
name [2] - 6:14, 9:8
named [4] - 5:24,
8:21, 13:16, 26:22
need [4] - 21:6,
24:24, 25:10, 30:3
network [8] - 8:16,
17:22, 20:16,
20:23, 21:9, 21:10,
29:6, 29:7
never [3] - 10:20,
23:20, 26:12
next [1] - 20:3
nine [1] - 6:23
NO [1] - 1:2
North [1] - 1:20
Note20 [7] - 6:24,
14:12, 14:13, 18:2,
19:3, 19:6, 20:19
notes [1] - 31:3
nothing [2] - 16:24,
17:3
noticed [2] - 3:9, 3:12
number [7] - 8:19,
11:18, 14:13,
15:18, 15:20, 19:9,
28:6
numbers [3] - 8:12,
25:20, 25:21
O
o'clock [6] - 15:10,
15:11, 15:14,
15:16, 15:25, 21:13
obvious [3] - 6:9,
9:10, 26:25
OF [5] - 1:1, 1:4,
1:11, 2:11, 31:1
Case 0:23-cr-60173-KMW Document 112 Entered on FLSD Docket 07/25/2024 Page 35 of 38
office [1] - 12:23
Office [5] - 2:4, 2:8,
2:13, 20:15, 21:9
Official [2] - 1:19,
31:6
ON [1] - 2:11
once [4] - 8:24, 17:2,
18:8, 23:22
one [38] - 4:6, 4:9,
4:12, 4:16, 6:3,
10:15, 11:10,
12:15, 12:19, 14:5,
14:17, 14:20, 15:7,
15:8, 15:11, 15:18,
16:5, 17:13, 17:17,
17:18, 20:1, 20:2,
20:3, 20:25, 21:1,
21:2, 21:4, 21:8,
21:25, 23:6, 24:20,
26:17, 26:23, 28:5,
28:7
one-time [1] - 28:7
ones [1] - 6:17
operation [1] - 16:10
opportunity [1] -
7:11
opposite [1] - 14:17
order [1] - 24:11
Order [1] - 3:1
outside [1] - 10:7
overview [1] - 16:16
overwhelming [1] -
5:13
own [5] - 12:3, 13:11,
14:22, 24:23, 26:6
owned [1] - 20:23
owners [1] - 9:14
P
P.A [1] - 2:13
Pacific [4] - 15:23,
15:24, 19:24
page [10] - 3:10, 3:11,
3:12, 6:18, 8:9,
8:13, 8:17, 8:24,
9:5, 9:8
Pages [1] - 1:8
paid [1] - 14:21
painfully [2] - 9:10,
26:24
pandemic [3] - 9:15,
27:20, 27:23
paralegal [1] - 2:20
parse [1] - 25:14
part [2] - 12:9, 19:19
participate [1] -
21:21
participated [4] - 5:4,
5:10, 5:14, 28:21
participating [3] -
24:22, 30:6, 30:14
participation [3] -
22:3, 26:6, 29:10
parties [1] - 22:17
password [2] - 28:13,
28:15
pay [1] - 11:4
Paycheck [5] - 5:5,
24:9, 24:25, 26:16,
30:10
paychecks [1] -
30:12
paying [3] - 11:8,
11:9, 26:14
payment [2] - 22:8,
22:12
payroll [9] - 6:6,
23:24, 23:25, 24:1,
24:3, 24:8, 24:9,
24:12, 24:17
percent [4] - 11:9,
12:4, 14:15, 14:20
person [6] - 7:8,
10:23, 15:12,
19:16, 22:12, 29:21
Persona [5] - 7:17,
7:20, 14:13, 18:1,
18:23
phone [18] - 6:24,
6:25, 8:18, 8:19,
8:20, 14:8, 14:12,
17:20, 18:3, 19:7,
20:19, 20:24,
25:21, 28:6, 28:9,
28:10, 29:7
phony [1] - 22:23
photographs [1] -
14:10
picture [1] - 29:4
piece [3] - 14:1,
16:18, 26:17
place [1] - 26:13
Plaintiff [1] - 1:5
plan [3] - 5:6, 30:5
Plantation [1] - 2:17
PM [2] - 19:1, 21:19
pocket [1] - 12:3
point [4] - 3:23, 8:6,
15:1, 25:16
policy [1] - 10:8
Pompano [1] - 2:14
pooled [1] - 23:16
Port [2] - 12:20,
12:24
portal [9] - 6:21, 7:5,
7:13, 7:24, 8:4,
13:24, 17:9, 17:14,
18:19
portion [1] - 5:1
possible [1] - 27:19
PPP [17] - 5:15, 5:17,
6:1, 8:15, 10:12,
13:15, 13:17,
13:18, 15:6, 15:15,
16:3, 22:4, 22:12,
22:25, 23:21,
24:23, 29:16
precise [1] - 13:23
prepared [1] - 31:3
present [3] - 4:10,
4:12, 4:19
PRESENT [1] - 2:20
presentation [2] -
4:14, 24:19
pretending [1] -
30:11
pretty [1] - 15:13
previously [1] - 7:5
primary [1] - 8:21
principal [1] - 8:11
private [1] - 9:13
proceed [2] - 4:22,
4:24
Proceedings [1] -
1:23
proceedings [1] -
31:3
proceeds [2] - 22:12,
22:25
process [4] - 4:18,
5:15, 6:10, 13:19
produced [1] - 1:23
profit [1] - 12:14
program [5] - 7:7,
23:24, 24:10,
26:20, 27:25
Program [5] - 5:5,
24:9, 25:1, 26:16,
30:11
proof [2] - 4:11,
25:24
property [1] - 5:7
proprietor [1] - 9:12
protect [3] - 13:4,
23:24, 23:25
protecting [2] - 24:2,
30:12
Protection [5] - 5:5,
24:9, 25:1, 26:16,
30:11
proves [2] - 5:13,
25:1
provided [1] - 10:20
pull [1] - 22:20
pulled [1] - 5:25
purchased [1] - 22:6
purpose [2] - 22:24,
24:10
put [5] - 14:1, 14:18,
14:24, 26:11, 26:14
puts [1] - 16:2
Q
questions [1] - 13:10
quick [1] - 22:21
quickly [1] - 27:19
quote [5] - 6:5, 13:16,
14:15, 23:5, 29:15
R
raise [1] - 25:18
range [1] - 29:15
reaction [1] - 4:1
read [2] - 7:23, 19:13
ready [2] - 3:2, 4:22
real [5] - 10:20, 11:6,
11:10, 22:20, 27:7
really [2] - 25:13,
26:5
reason [1] - 29:5
reasonable [9] -
5:14, 21:23, 25:1,
25:16, 25:19,
25:23, 28:19, 29:7
rebuttal [1] - 4:13
receipt [3] - 22:4,
22:25, 23:20
received [2] - 22:5,
22:15
recently [1] - 13:13
record [8] - 13:23,
14:2, 15:22, 16:6,
25:8, 26:6, 29:2,
31:3
recorded [1] - 1:23
records [3] - 13:25,
22:11, 23:21
red [1] - 26:15
Reese [1] - 21:18
regulations [1] -
26:21
related [1] - 12:7
relied [1] - 9:18
rely [5] - 25:24,
25:25, 26:1, 26:4,
27:14
remaining [1] - 4:17
remember [9] - 5:20,
6:13, 7:2, 7:19,
15:7, 15:10, 15:12,
22:22, 24:6
remembering [1] -
15:13
reminder [4] - 21:3,
36
21:4, 21:7, 24:13
reminders [1] - 21:5
repeated [1] - 6:9
report [2] - 10:2, 10:8
reported [6] - 11:14,
11:17, 12:1, 12:2,
24:5, 24:6
REPORTER [1] -
31:1
Reporter [2] - 1:19,
31:6
representative [1] -
7:20
residence [1] - 15:19
restoration [3] -
22:22, 29:19, 29:21
result [1] - 18:6
return [2] - 25:5,
30:16
returns [4] - 11:12,
11:19, 12:21, 27:8
Rivero [4] - 10:22,
13:4, 22:18, 26:10
Riveros [3] - 11:8,
22:16, 23:2
Road [1] - 21:18
Rodriguez [1] - 20:15
role [1] - 10:23
room [2] - 24:20,
28:17
routed [1] - 9:3
RPR [2] - 1:18, 31:6
ruling [1] - 3:14
rulings [1] - 3:6
run [4] - 11:21, 11:25,
12:3, 12:18
S
salaried [1] - 23:6
salary [7] - 23:5,
23:12, 23:18,
23:19, 24:4, 24:7,
29:15
Samsung [7] - 6:24,
14:12, 14:13,
17:21, 19:3, 19:5,
20:24
saw [5] - 6:15, 8:24,
23:3, 24:16, 29:4
SBA [8] - 9:13, 9:17,
9:19, 20:6, 27:10,
27:14, 27:18, 27:23
schedule [2] - 28:23,
29:2
Schedule [10] - 8:2,
9:24, 10:14, 10:15,
12:14, 18:11,
22:13, 22:19,
Case 0:23-cr-60173-KMW Document 112 Entered on FLSD Docket 07/25/2024 Page 36 of 38
26:16, 29:22
scheme [15] - 5:4,
5:5, 5:8, 5:10, 16:4,
21:21, 25:12, 26:7,
26:14, 28:21, 30:5,
30:7, 30:13, 30:14
screen [1] - 6:19
seat [1] - 13:2
second [6] - 10:22,
15:6, 20:11, 21:1,
21:2, 21:11
see [17] - 3:23, 3:25,
6:14, 7:12, 8:8,
8:24, 10:3, 11:14,
14:2, 16:10, 16:17,
19:5, 21:12, 22:20,
25:10, 27:9, 29:14
self [2] - 27:13, 27:22
self-certification [2] -
27:13, 27:22
selfies [4] - 7:19,
14:11, 19:4, 29:4
sense [13] - 12:17,
23:15, 23:17,
28:15, 28:16,
28:17, 28:18,
28:19, 29:20,
29:23, 30:2, 30:17
sent [2] - 17:4, 28:9
sessions [2] - 7:21,
19:12
seven [1] - 19:12
sham [3] - 23:2,
29:17, 29:18
sheriff's [1] - 12:23
Sheriff's [2] - 20:15,
21:9
shift [1] - 13:2
show [2] - 16:14,
24:12
showed [3] - 9:23,
21:4, 24:16
showing [2] - 15:23,
26:18
shows [18] - 6:22,
9:7, 14:16, 14:17,
14:19, 16:23, 17:8,
17:16, 17:18, 18:5,
18:6, 18:8, 21:23,
27:3, 28:4, 28:19,
29:9, 29:10
side [1] - 4:9
sign [8] - 9:1, 9:4,
15:25, 21:5, 21:6,
21:7
signature [1] - 9:11
signed [12] - 8:15,
9:7, 15:8, 15:9,
15:11, 15:16,
15:18, 15:20, 21:2,
21:5, 21:15, 21:16
signing [3] - 15:14,
20:25, 21:11
signs [3] - 20:1, 20:9,
20:10
simple [1] - 13:10
single [2] - 23:6,
26:23
sitting [1] - 7:9
six [4] - 7:19, 14:10,
17:16, 18:15
slide [8] - 17:16,
17:18, 18:5, 22:4,
24:19, 24:21
SM-986U [3] - 17:21,
18:2, 19:5
small [7] - 9:14,
23:25, 24:1, 24:3,
27:19, 27:23, 27:25
smaller [1] - 20:7
Smith [1] - 2:20
SMS [1] - 28:9
SNIDER [8] - 2:3, 3:9,
3:12, 4:23, 4:25,
5:3, 25:4, 25:7
sole [2] - 9:11, 25:17
someone [1] - 11:9
Sorry [1] - 9:2
sorry [3] - 3:11,
16:25, 19:1
source [1] - 7:8
Southern [1] - 31:7
SOUTHERN [1] - 1:1
Southwest [1] - 2:17
specific [2] - 18:5,
21:15
specifically [2] -
9:16, 17:16
spent [1] - 24:17
spreadsheet [3] -
16:20, 17:8, 27:5
spreadsheets [1] -
16:13
Springs [1] - 12:22
St [2] - 12:20, 12:24
stage [1] - 4:9
start [1] - 17:1
started [5] - 15:3,
15:5, 16:7, 16:11,
16:25
statements [3] - 5:8,
7:13, 27:4
STATES [3] - 1:1,
1:4, 1:13
States [4] - 1:19, 2:4,
2:8, 31:7
Steinbeisser [2] -
31:5, 31:5
STEINBEISSER [1] -
1:18
stenography [1] -
1:23
stenotype [1] - 31:3
Step [14] - 10:2, 10:3,
10:4, 10:11, 10:13,
10:16, 11:1, 11:15,
11:25, 12:3, 26:19,
26:24, 30:1
stipulated [2] - 8:5,
22:18
stop [1] - 23:1
Street [1] - 2:17
stroke [1] - 14:1
stuck [1] - 17:4
stumbled [1] - 23:12
successfully [1] -
17:19
summaries [1] -
25:15
summary [1] - 24:21
supplied [2] - 11:10,
28:7
supply [2] - 28:5,
28:6
supposed [4] - 10:8,
10:25, 11:2
surprised [1] - 11:5
system [2] - 27:15,
27:21
T
tab [1] - 27:5
tablet [2] - 19:6, 19:7
tax [13] - 10:20,
10:21, 10:24, 11:5,
11:9, 11:12, 11:19,
12:21, 14:18, 18:7,
26:12, 26:15, 27:7
taxes [3] - 12:7, 12:8,
12:9
term [1] - 19:6
testified [13] - 6:3,
7:3, 11:22, 12:22,
13:1, 13:15, 14:6,
14:14, 17:1, 18:2,
20:1, 23:7, 27:23
testimony [10] - 7:19,
10:19, 12:25,
13:23, 22:7, 22:9,
26:3, 27:14, 28:23,
28:24
text [1] - 28:9
Thakral [3] - 7:2, 7:6,
17:1
THE [11] - 1:12, 2:2,
2:11, 3:2, 3:5, 3:11,
3:15, 3:20, 4:4,
4:24, 25:3
theory [2] - 11:3, 26:8
thereafter [1] - 4:20
therefore [1] - 12:11
thin [1] - 5:25
three [10] - 7:13,
7:15, 9:10, 11:24,
12:1, 12:4, 17:14,
18:9, 18:10, 19:4
throughout [1] - 6:10
timing [2] - 13:14
title [1] - 9:12
took [1] - 7:19
total [1] - 22:18
Tracy [4] - 6:1, 13:1,
13:16, 13:17
trade name [2] -
8:18, 9:9
traffic [1] - 4:5
trail [2] - 22:2, 23:1
transaction [1] - 14:2
transactions [6] -
16:16, 18:14,
18:15, 18:19, 18:20
TRANSCRIPT [1] -
1:11
transcript [1] - 1:23
transcription [2] -
1:23, 31:3
transition [1] - 20:4
transmitted [1] - 25:9
travel [1] - 12:16
trial [3] - 5:12, 12:7,
12:8
TRIAL [1] - 1:11
tricked [1] - 29:11
tried [1] - 20:5
trouble [1] - 15:12
true [9] - 9:19, 9:21,
13:20, 13:21, 14:9,
14:16, 17:18, 27:14
trust [10] - 11:7,
26:11, 26:13,
27:15, 27:16,
27:17, 27:18,
27:20, 27:21
trust-based [2] -
27:15, 27:21
trusted [3] - 26:9,
26:10
truth [2] - 13:22, 26:5
truthful [1] - 27:15
trying [6] - 9:13,
13:2, 13:4, 22:23,
25:18, 27:18
Tuesday [1] - 7:3
twice [5] - 8:24, 9:4,
24:5, 24:7, 29:25
two [8] - 9:24, 10:14,
13:8, 15:20, 17:13,
22:24, 23:9, 28:4
37
type [3] - 16:11,
17:23, 19:5
typed [1] - 16:19
U
ultimately [2] - 22:6,
30:10
Ultra [4] - 6:24, 18:2,
19:6, 20:19
under [2] - 10:8, 24:9
undo [1] - 30:8
uniform [4] - 14:11,
18:24, 19:16, 29:4
unique [1] - 14:2
Unit [1] - 21:18
UNITED [3] - 1:1, 1:4,
1:13
United [4] - 1:19, 2:4,
2:8, 31:7
Universal [1] - 19:2
unquestionably [1] -
21:23
up [8] - 4:16, 5:25,
11:18, 17:25,
22:20, 23:13, 24:1,
24:4
updated [1] - 3:5
upload [5] - 10:24,
11:4, 11:9, 18:11,
22:19
uploaded [5] - 7:12,
8:4, 16:21, 22:13,
29:22
uploading [4] - 18:6,
18:9, 19:14, 27:4
uploads [1] - 8:6
USAA [1] - 20:20
UTC [2] - 18:25, 19:1
utilities [1] - 12:16
V
V.A [1] - 2:20
verdict [3] - 25:4,
25:5, 30:16
verification [1] -
18:23
verified [1] - 7:17
verify [1] - 29:5
Verizon [5] - 8:16,
17:22, 19:21, 20:24
Verizon's [3] - 17:21,
20:22, 29:6
version [3] - 3:5,
13:19, 13:21
visible [1] - 7:6
vs [1] - 1:6
Case 0:23-cr-60173-KMW Document 112 Entered on FLSD Docket 07/25/2024 Page 37 of 38
W
Wade [81] - 2:20, 5:3,
5:9, 5:24, 6:2, 6:5,
6:7, 6:15, 8:10,
8:11, 8:17, 8:18,
8:20, 8:21, 8:23,
9:9, 10:10, 11:2,
11:14, 11:25, 12:3,
12:7, 13:1, 13:8,
13:10, 13:16,
13:17, 13:18, 14:6,
14:7, 14:10, 14:14,
14:22, 14:25, 15:6,
15:9, 15:15, 15:17,
15:22, 16:2, 16:8,
16:10, 16:18,
16:19, 16:20,
16:22, 17:4, 17:10,
17:12, 17:13,
17:18, 18:15,
18:16, 18:18,
18:22, 19:22, 20:1,
20:3, 20:4, 20:8,
21:12, 21:14,
21:17, 21:24, 23:4,
23:6, 23:7, 23:12,
23:24, 24:22, 25:2,
26:3, 26:22, 30:11,
30:13, 30:15
WADE [1] - 1:7
Wade's [13] - 10:18,
12:25, 13:18,
13:20, 13:23,
14:15, 14:23,
15:19, 17:16,
17:24, 21:17, 28:5,
30:10
Wades [3] - 10:20,
10:24, 26:9
wages [1] - 12:5
walk [1] - 16:5
walked [1] - 7:20
ways [1] - 28:4
website [3] - 7:7, 7:8,
7:15
whole [2] - 5:19, 7:7
wife [3] - 13:4, 13:5,
14:7
WILCOX [1] - 2:16
WILLIAMS [1] - 1:2
wire [2] - 25:2, 30:15
witness [3] - 7:3,
22:7, 27:10
witnesses [1] - 29:1
Womply [14] - 6:21,
7:3, 7:5, 7:13, 8:4,
13:24, 13:25, 17:9,
17:14, 18:3, 18:19,
38
20:4, 20:12, 28:5
Womply's [2] - 7:15,
7:24
word [1] - 26:23
worth [1] - 29:25
write [2] - 23:15,
29:21
writing [3] - 23:11,
23:14, 24:7
written [3] - 23:18,
24:17, 29:15
wrote [4] - 7:6, 23:4,
23:19, 29:20
Y
year [3] - 10:14,
11:16, 12:19
years [5] - 10:9,
11:13, 11:24, 12:1,
12:4
yesterday [1] - 15:13
Z
Zacca [5] - 13:6,
13:7, 13:9, 23:8,
23:9
ZACCA [1] - 2:7
Zelle [1] - 22:8
zone [1] - 19:23
Case 0:23-cr-60173-KMW Document 112 Entered on FLSD Docket 07/25/2024 Page 38 of 38File and source
- File
- gov.uscourts.flsd.654267.112.0.pdf
- Size
- 410,629 bytes
- SHA-256
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