Court filing
Judgment — United States v. Tracy D. Wade (Dkt. 265, S.D. Fla. No. 0:23-cr-60173)
Filed May 15, 2025 in United States v. Tracy D. Wade; one of 133 filings from this case.
Record facts
| Court | U.S. District Court for the Southern District of Florida |
|---|---|
| Filed | 2025-05-15 |
U.S. District Court for the Southern District of Florida · No. 0:23-cr-60173-KMW · Doc. 265 · 2025-05-15 · Docket on CourtListener
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 23-CR-60173-KMW
UNITED STATES OF AMERICA,
Miami, Florida
Plaintiff,
October 16, 2024
vs.
9:37 AM - 3:04 PM
CAROLYN DENISE WADE and
TRACY D. WADE,
DAY 4
Defendants.
Pages 1 to 176
____________________________________________________________
TRANSCRIPT OF JURY TRIAL
HELD BEFORE THE HONORABLE DONALD L. GRAHAM
UNITED STATES DISTRICT JUDGE
FOR THE GOVERNMENT:
DAVID A. SNIDER, AUSA
ADAM LOVE, AUSA
United States Attorney's Office
ON BEHALF OF THE DEFENDANTS:
JOHNNY L MCCRAY, JR., ESQ.
Law Office of Johnny L. McCray, Jr, P.A.
and
DARYL E. WILCOX, ESQ.
ALSO PRESENT: Carolyn Wade
Tracy Wade
Hendrith V.A. Smith, paralegal
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.
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2
T A B L E O F C O N T E N T S
PAGE
GOVERNMENT'S WITNESSES:
HAYDEE RIVERO
Cross-Examination (Continued) by Mr. Wilcox.......
11
Redirect Examination by Mr. Snider................
39
Redirect Examination by Mr. Snider................
62
Recross-Examination by Mr. Wilcox.................
70
KELLY DIPIETRANTONIO
Direct Examination by Mr. Snider..................
79
Certificate of Reporter...........................
155
GOVERNMENT EXHIBITS
MARKED
ADMITTED
2002
56
DEFENSE EXHIBITS
MARKED
ADMITTED
16
29
7
37
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(Call to the Order of the Court.)
THE COURT: As we wrapped up yesterday, I was advised
by the courtroom deputy that one of the jurors mentioned that
she recognized someone in the courtroom during the lunch hour,
that they did not communicate. The court reporter had shut
down his equipment, so I made this reference to you all and
that we would address the issue again first thing this
morning.
MR. SNIDER: Your Honor, I just wanted the Court to
be aware, Ms. Rivero is at the witness stand. I don't know if
you want her there now or --
THE COURT: No, I don't want her here now.
MR. SNIDER: Okay. Ms. Rivero, you can wait outside
until we're ready to proceed. Thank you.
THE COURT: Thank you. I did not notice you. I
apologize.
MR. SNIDER: We wanted her ready to go if the Court
was ready to proceed.
THE COURT: And I like that.
MR. SNIDER: Okay.
Just wait outside.
(Ms. Rivero exited the courtroom.)
THE COURT: So I'm not exactly sure what this could
have been about, if it's an accident or otherwise, but perhaps
we should have the juror come in and find out what the facts
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are.
MR. SNIDER: That's fine for the Government. I also
have -- the Government has no idea what transpired or -- this
was the first time it was brought to our attention.
THE COURT: Defense? Do you agree we should bring in
the juror?
MR. MCCRAY: Yes, sir.
THE COURT: All right. Which juror is it? Olga
Bustamante. Have her come in, please. That's Juror Number 6,
Olga Lidia Bustamante.
(Juror entered the courtroom.)
THE COURT: You may be seated. Good morning.
A JUROR: Good morning.
THE COURT: Ms. Bustamante, we understand that you
communicated to our courtroom deputy yesterday that you may
have observed someone in the courtroom that you knew. Would
you expound on that issue, please?
A JUROR: Yes. Yesterday, in the morning, I noticed
a person, and I wasn't sure if it was the same person that I
thought I knew from work. And then during lunch, when I went
to the seventh floor, I had a closer look and I noticed that I
think it is the person that I had worked with before, and they
were very close to the defendants.
And I just wanted to bring it up to the Court. I
don't have an issue with it, but I didn't want it to be an
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issue later on and say, oh, you knew someone from one of the
areas and this is going to be a problem. I don't have a
problem with it at all. I have been retired for ten years,
so -- I have not even been back to my job or seen anybody from
my job since I've been retired. So I have had no
communications with that person for ten years or ever seen
them again or spoken to them.
I don't know that person's family either. All I knew
was from -- I'm in IT. So I just knew as far as training and
from what I did, but nothing personal with that person that I
was close to, but I just felt the need to disclose it. I
don't know if it was a problem or not. Just since I had my
doubt, I wanted to make sure.
THE COURT: All right. First, you did exactly what
you're supposed to do, so we appreciate that. And you have
stated that you worked with this person -- first, are you sure
it's the person --
A JUROR: I am not even a hundred percent sure it is
the person. I had a closer look at lunchtime and then when I
left the building yesterday as well. And it looks like the
person, very close to the person, but I'm not a hundred
percent sure that it could be the person that I worked with.
THE COURT: And this person, you had no close working
relationship?
A JUROR: No. This person worked in a different
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department, and I'm in IT, and I go to different areas
whenever is needed for any issues with the programs. And if
there's a training, I train the staff and just -- that's the
only connection that I had with the person, if it is the
person.
THE COURT: All right.
Any questions, counsel?
MR. MCCRAY: If I could just ask a few.
Good morning.
A JUROR: Good morning.
MR. MCCRAY: What job are we talking about? What's
the name of the job?
A JUROR: I'm a database administrator.
MR. MCCRAY: That was your position?
A JUROR: First programmer and then database
administrator.
MR. MCCRAY: What was the name of the company?
A JUROR: City of North Miami.
MR. MCCRAY: How long did you work there?
A JUROR: 18 years.
MR. MCCRAY: And the person you believe that you may
have known, how long did that person work there, if you know?
A JUROR: Not -- maybe not more than five. They were
not there from when I started.
MR. MCCRAY: They were not there when you started?
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A JUROR: No.
MR. MCCRAY: Did you work in a supervisory/advisory
capacity with respect to this person?
A JUROR: No. Like I said, I was in IT, and she was
in a different department. And whenever there was training or
program issues, I remember having some type of connection with
that department.
MR. MCCRAY: Did you have any interaction with this
person while you were actually working at the City of Miami?
A JUROR: Interactions as far as her explaining any
issues that she had that I would have to fix, because we were
going through a whole conversion -- system conversion, and I
had to be very involved with different departments because of
the conversion and initial issues that we had due to the
conversion.
So I do remember going to -- working with many
staff -- like, every department staff because I did the
training. And any issues that would come up, they would call
me and I would have to go and explain it or fix it.
MR. MCCRAY: Okay. Were there any disciplinary
issues with respect to this person while you were there?
A JUROR: No.
THE COURT: Do you recall the person's name?
A JUROR: I actually spent the whole time after I
thought it was the person trying to remember, and then I
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couldn't remember. But -- I kind of had an idea what the name
was and then I overheard the name when I was leaving the
building, and her name was Mary.
THE COURT: You overheard someone refer to this
person as Mary?
A JUROR: As I was passing by and I was like, oh,
that was the name. It's been ten years since I've had any
type of connection with that person.
THE COURT: All right.
A JUROR: But I do recall that the name was Mary.
MR. MCCRAY: And when you heard Mary, did that cause
you to remember the name that you remembered back then?
A JUROR: When I heard "Mary," I was like, oh, I
think that's the name of the person.
MR. MCCRAY: And did you ever interact with this
person outside of work?
A JUROR: Never.
MR. MCCRAY: I don't have any questions, Judge.
THE COURT: All right. All right. Thank you very
much. You may return with the members of the jury.
(Juror exited the courtroom.)
THE COURT: Question one, is anyone aware of a person
being in the courtroom and in the courthouse named Mary who
may be affiliated with one side or the other?
MR. SNIDER: The Government has no person named Mary
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affiliated with this case at all.
MR. MCCRAY: Judge, I just spoke with Mrs. Wade, and
she indicates that her aunt, who has been present, her name is
Mary Johnson.
THE COURT: And did she work for North Miami, to your
knowledge?
MR. MCCRAY: Yes, according to Ms. Wade.
THE COURT: All right. So likely the same person.
We don't know for sure, but it sounds like it. But based on
what I've heard, I don't know that that creates any issues.
Do the parties have any comment regarding there being
any issues that we should address surrounding this matter?
MR. SNIDER: The Government sees no issue whatsoever
with that juror continuing to serve.
THE COURT: All right.
MR. MCCRAY: The defense sees no issue, Judge.
THE COURT: All right. Let's bring the jury in.
MR. SNIDER: Judge, may we bring the witness in?
THE COURT: Yes, please.
(Jury entered at 9:47 AM.)
THE COURT: Good morning. I think we're missing a
person, aren't we?
A JUROR: They went to go get her.
MR. WILCOX: Your Honor, before I forget -- Your
Honor, I would like to invoke the rule.
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THE COURT: All right. The rule is invoked.
(Juror entered the courtroom.)
THE COURT: So when lawyers request that the rule be
invoked, this is a rule called the rule of sequestration. And
very simply, it means that if there are any witnesses to the
proceeding in the courtroom, they must exit. There is an
exception, and that would be perhaps someone who's serving in
the role as an assistant to the lawyers. That's a special
exception, but generally speaking, witnesses are not allowed
to be in the courtroom to hear the testimony of other
witnesses because there's some thought that maybe their
testimony could be influenced by what they hear.
So when you hear the rule being invoked, it just
simply means that each side is responsible for looking to see
if any of their witnesses are in the courtroom. And if they
are, then they must be asked to leave. So the rule was just
invoked. So when you see that on TV and they say something
else, you'll know they got that wrong too.
MR. SNIDER: And, Judge, we're missing a juror.
THE COURTROOM DEPUTY: She's right here.
(Juror entered the courtroom.)
THE COURT: All right.
MR. SNIDER: Judge, with respect to that exception to
the rule, just for the Court's awareness, Special Agent
DiPietrantonio is assisting the Government as the case agent.
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THE COURT: I did say that there are some exceptions.
MR. SNIDER: I wanted to point out she's one of them.
THE COURT: A person who is assisting one side or the
other who could be a witness, they are exempted from the rule.
All right. Yes, sir.
MR. WILCOX: Thank you, Your Honor.
CROSS-EXAMINATION (CONTINUED)
BY MR. WILCOX:
Q.
Ms. Rivero, good morning.
A.
Good morning.
Q.
I think when I left off the last time, we were trying to
total the number of people that you had received successful
loans for.
Ms. Barbara Abreu, she's a friend of yours, and you
attempted to receive a PPP loan for her; is that correct?
A.
Yes.
Q.
Hmm?
A.
Yes.
Q.
But you did not get one for her?
A.
No.
Q.
How far along did you get in the process?
A.
She didn't get past confirming her identity.
Q.
Excuse me?
A.
She doesn't get past confirming her identity with Womply.
Q.
And Ms. Katelin Acevedo?
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A.
I don't recall her.
Q.
You don't recall her?
A.
No.
Q.
You don't remember how -- one moment, Your Honor.
Your Honor, may I approach the witness?
THE COURT: Yes, sir.
BY MR. WILCOX:
Q.
Ma'am, I'm showing what's going to be marked as defense
for identification 9. Do you recognize that?
A.
I don't remember anything about her application.
Q.
That's not what I asked you, ma'am. I asked you, do you
recognize it?
A.
No, I don't.
Q.
You don't recognize it?
A.
No.
Q.
Do you recognize the type of document?
A.
No, I don't recognize anything regarding this person.
Q.
I didn't ask you did you recognize.
Do you recognize that type of document?
A.
No, I don't.
Q.
You've never seen a Fast Lane application before?
A.
No.
Q.
Thank you.
Steve Alison, I believe you said you had no
recollection?
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A.
Correct.
Q.
No recollection about him as well?
A.
Correct.
Q.
You don't remember starting the process?
A.
I don't remember anything about that person.
Q.
And Nichole Almanzar?
A.
Yes, I remember her.
Q.
You remember her?
A.
Yes.
Q.
What happened with her application -- PPP loan
application?
A.
I could never get the one-time passcode on time, so the
application was never completed.
Q.
Now, if I'm not mistaken, you did testify that Angela de
la Cruz's loan was successfully funded?
A.
Yes. Correct.
Q.
Did she get a Second Draw as well?
A.
Yes. Correct.
Q.
So that's $40,000 for her?
A.
Correct.
Q.
Mohamed Faitrouni?
A.
I don't remember anything about that person.
Q.
One second.
MR. WILCOX: May I approach the witness?
THE COURT: Yes, sir.
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BY MR. WILCOX:
Q.
I'm showing what's going to be marked defense for
identification 10.
Does that refresh your recollection?
A.
No.
Q.
Are you saying that you never prepared the Schedule C for
Mr. Faitrouni?
A.
No, I said I don't remember anything regarding his
application.
Q.
And now that I've shown you his Schedule C, do you
remember it now?
A.
No, I don't.
Q.
So are you saying you didn't prepare a Schedule C for
Mr. Faitrouni?
A.
I don't remember.
Q.
So you may have but you just don't remember?
A.
Exactly. Probably.
Q.
How about Carlos Fandino?
A.
Yes, his application was done.
Q.
Successful?
A.
Correct.
Q.
Did he get a Second Draw?
A.
I don't remember.
Q.
One moment.
MR. WILCOX: May I approach the witness, Your Honor?
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BY MR. WILCOX:
Q.
Showing you what's going to be marked for defense
identification Number 11.
Do you recognize the document -- the top document?
A.
No, I don't remember.
Q.
You don't remember what?
A.
I don't remember the document.
Q.
Okay. Do you recognize what the document is?
A.
No.
Q.
Well, the title is on the top of the document, ma'am.
A.
Yeah, it's the Paycheck Protection Program.
Q.
Continue.
A.
Lender application, Second Draw.
Q.
Second Draw --
A.
Yes.
Q.
-- right?
A.
Yes. Correct.
Q.
Whose name?
A.
Carlos Fandino.
Q.
All right. Did that refresh your recollection as to
whether Mr. Carlos Fandino received a Second Draw?
A.
I don't remember -- here it says that he got one, but I
don't remember that he had got the second one.
Q.
Okay. But you know that he got the first one; right?
A.
Correct.
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Q.
I'm just going to put 40,000 for that one, okay?
A.
Okay.
THE COURT: You have to ask questions.
MR. WILCOX: Okay. Sorry.
BY MR. WILCOX:
Q.
But if he did get a Second Draw, that would be $40,000
that you got for him?
A.
Correct.
Q.
Now, Yaosca Granados?
A.
She didn't get one.
Q.
She did not get one.
Now, she's your sister; right?
A.
Correct.
Q.
Do you remember preparing a Schedule C for her?
A.
No, I never did one for her.
MR. WILCOX: May I approach the witness, Your Honor?
THE COURT: Yes, sir.
BY MR. WILCOX:
Q.
I'm showing you what is going to be marked as defense
exhibit for identification 12. In that folder there's a Fast
Lane application from Womply; is that right?
A.
Correct.
Q.
And it bears the name of Yaosca Granados?
A.
Correct.
Q.
Your sister; correct?
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A.
Yes.
Q.
And if you look at maybe the third document in that
folder, there's a Schedule C, is there not?
A.
Yes.
Q.
And who is the Schedule C made out to?
A.
Yaosca Granados.
Q.
Yaosca Granados?
A.
Correct.
Q.
Does that refresh your recollection as to whether you
prepared a fake Schedule C for her?
A.
I did not prepare a Schedule C for her.
Q.
Well, who did?
A.
I have no idea.
Q.
Okay.
A.
I didn't do it.
Q.
Are you saying she may have done it herself?
A.
I have no idea. I never did one for her.
Q.
You recall the Government asking you about her, though;
right?
A.
Correct.
Q.
And the Government asked you about PPP loan applications
for all the people I've named so far; right?
A.
Yes.
Q.
Okay. How about Onimer Lazaro Garcia Chapotten? I
believe we discussed him yesterday.
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A.
Yes.
Q.
And you indicated that you had not prepared a Schedule C
for him?
A.
Correct.
Q.
But there was a Schedule C in the exhibit that I showed
you?
A.
Yes.
Q.
Okay. And Michael Jimenez, do you remember him?
A.
Yes.
Q.
What happened with his loan application?
A.
His application didn't get completed. He couldn't confirm
his identity.
Q.
Okay. Nilda Rivera?
A.
Yes, her application was completed.
Q.
One moment, Your Honor.
I want to go back to Michael Jimenez. I'm going to
go back to Mr. Jimenez. I'm showing you what is going to be
marked as a defense exhibit for identification 13.
A.
Yes.
Q.
Is the Fast Lane application from Womply in there?
A.
Yes.
Q.
Whose name is on it?
A.
Michael Jimenez.
Q.
Okay. Look at the second document.
A.
It's a Schedule C form.
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Q.
In whose name?
A.
Michael Jimenez.
Q.
And you're saying you didn't do that?
A.
I didn't do that one because his identity couldn't be
confirmed --
Q.
Okay.
A.
-- and he did not get a loan either.
Q.
If Womply had that application in a file, can you possibly
explain why that Schedule C would be in a Womply file?
A.
I don't know.
MR. SNIDER: Objection. Foundation.
THE COURT: Sustained.
BY MR. WILCOX:
Q.
When you started the application, you went on the Womply
website; is that correct?
A.
When I uploaded the Schedule C, it was on the Womply
website.
Q.
Okay. But for you to process any loan, you had to go
through Womply; right?
A.
That's the only website I used.
Q.
That's the only website you used --
A.
Yes --
Q.
-- was Womply?
A.
-- correct.
Q.
And you admit that you tried to get a loan for
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Mr. Jimenez; is that correct?
A.
Yes.
Q.
And the loan did not go through for what reason again?
A.
His identity couldn't be confirmed.
Q.
Okay. But you're saying that you did not prepare that
Schedule C?
A.
No, I did not.
Q.
Okay. Thank you.
Jorge Rivero -- excuse me -- before I get there on
Jorge Rivero -- I apologize.
Nilda Rivera?
A.
Yes, her application was completed.
Q.
Did she get a loan?
A.
Yes.
Q.
Did she get a Second Draw?
A.
Yes.
Q.
Okay. So if the de la Cruz loan went through and
Mr. Fandino got -- sorry. I want -- Ms. De la Cruz got the
initial 20,000 -- and -- it's $20,833. I'm just rounding it
off. Ms. De la Cruz got the loan and a Second Draw. That
would be a little over 40,000; right?
A.
Correct.
Q.
And if Mr. Fandino got a loan and a Second Draw, that
would be up to a little more than 80,000; is that correct?
A.
Yes.
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Q.
And if Ms. Nilda Rivero got a loan and a Second Draw, that
would be up to about 120,000; right?
A.
Yep.
Q.
Okay. Now we're at Jorge Rivero. That's your
brother-in-law?
A.
Yes.
Q.
Did he get his loan?
A.
Yes, he did.
Q.
Did he get a Second Draw?
A.
Yes, he did.
Q.
So now we're up to $160,000 that has been stolen from the
Government with your help?
A.
Yes.
Q.
And Jose Rivero, is that a different person?
A.
Yes.
Q.
So you have a Jorge Rivero and a Jose Rivero. They're
both your brother-in-laws; is that correct?
A.
No. He's cousins with --
Q.
Pardon me?
A.
He's the cousin of my brother-in-law. They're not
brothers. They're cousins.
Q.
Okay. I'm sorry. He's the cousin of your brother-in-law,
but he received the loan?
A.
Yes.
Q.
Did he get a Second Draw?
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A.
I don't remember.
Q.
Okay. But he got a loan for the 20,833; right?
A.
Yes.
Q.
We're back up to $140,000 and some change; is that right?
A.
Yes.
Q.
Do you remember a person by the name of Victor Rivero?
A.
That's my brother-in-law's brother. That's my
brother-in-law's brother. He's my brother-in-law as well.
Q.
Did he get a loan?
A.
I don't remember.
Q.
You don't remember?
A.
No.
Q.
You do recall attempting to get a loan for him; is that
right?
A.
I don't remember anything about his application.
Q.
You know that he had an application?
A.
I guess. I just don't remember.
Q.
Well --
A.
I don't remember --
Q.
You don't remember what?
A.
-- anything regarding his application.
Q.
I'm showing you what is going to be marked as defense
exhibit for identification 14.
The first document in that folder is a Womply Fast
Lane application; is that right?
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A.
Yes.
Q.
Whose name is on it?
A.
Victor Rivero.
Q.
And there's a PPP loan application in there; is that
right?
A.
Yes.
Q.
Whose name is on that?
A.
Victor Rivero.
Q.
Okay. And what's the amount of the loan? 20,833?
A.
-- -33, yes.
Q.
I've lost track. In fact, we're up to 180. Do you know
if he got a Second Draw?
A.
I don't remember.
Q.
Edison Rogers?
A.
I don't remember.
Q.
Do you remember the Government asking you about Edison
Rogers?
A.
Yes.
Q.
And you don't remember anything about that loan?
A.
No.
Q.
Julio Arena?
A.
Yes, his application was completed.
Q.
Did he get a loan?
A.
Yes, he did.
Q.
Did he get a Second Draw?
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A.
I don't remember.
Q.
But he did get one loan approved; is that right?
A.
Yes.
Q.
So I believe that would make it about $200,000 that you
have helped people steal from the government -- a little over
$200,000; is that right?
A.
If that's the amount that you have, yes.
Q.
I didn't quite get that.
A.
I'm not keeping up with the amount that you're adding --
yes.
Q.
That's all right.
And Aliec Vale?
A.
She couldn't confirm her identity with Womply.
Q.
Aliec Vale didn't get a loan?
A.
She couldn't confirm her identity with Womply, so no.
Q.
Are you saying that Aliec Vale did not get a loan?
A.
No, her loan did not go through.
Q.
Showing you what is going to be marked as Defense
Exhibit 15. Is the first document you see a Fast Lane
application for Aliec Vale?
A.
Yes.
Q.
The next document, do you see a PPP loan application for
Aliec Vale?
A.
Yes.
Q.
How much is it? 20,833?
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A.
Correct.
Q.
Does that refresh your recollection as to whether that
loan went through?
A.
It didn't go through with me because with me her identity
couldn't go through. I didn't do the Schedule C for her or
completed the application for her.
Q.
Let me ask you this. On these folders that you're saying
someone else prepared the Schedule C and that a Schedule C was
prepared, it must have been prepared by someone else?
MR. SNIDER: Objection. It misstates the testimony.
THE COURT: Rephrase the question, please.
BY MR. WILCOX:
Q.
Okay. Let's just take Aliec Vale.
Now, are you saying that you did not process his
loan?
A.
Correct.
Q.
Okay. Do you know your IP address number?
A.
No, I don't know it by memory.
Q.
Well, if your IP address was linked to this Fast Lane
application in the uploading of a Schedule C, does that mean
that you did, in fact, process the loan?
A.
I would have to see that because with me she tried to
confirm her identity and it wouldn't go through, so I didn't
complete her application. It will show that, you know, I
tried to -- she tried to confirm her identity and it didn't go
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through. So I didn't complete her application.
Q.
I want you to listen to the question carefully, okay?
If your IP is connected to your -- do you know what
an IP address is?
A.
Correct. I do.
Q.
If your IP address is connected to the uploading of any of
these documents in Mr. Vale's Womply file, would that change
your mind as to whether or not you processed this loan?
MR. SNIDER: Objection. Foundation.
THE COURT: Well, I think you need to rephrase the
question. "Connected with," I'm not sure what that means.
BY MR. WILCOX:
Q.
If Womply's records show that your IP address uploaded the
Schedule C that was filed with this PPP loan application,
would that change your mind?
A.
I would have to see it, but I know that I didn't complete
it.
Q.
Okay. All right.
Now, with respect to Carolyn Wade's loan, would it be
fair to say that Mr. Wade was the person that you had most of
the contact with?
A.
I only had contact with him.
Q.
Right.
You didn't have any contact with Carolyn Wade?
A.
I don't remember having any contact with her.
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Q.
You don't remember speaking to her on the phone?
A.
I don't remember. Most of my conversation was with Tracy
Wade.
Q.
Okay. You don't remember --
A.
I don't remember.
Q.
Okay. You don't remember having email contact with
Ms. Wade about processing her PPP loan application?
A.
No. I remember Tracy Wade wrote for me the emails from
her.
Q.
And would it be fair to say that Tracy Wade was more
involved in the processing of Carolyn Wade than Carolyn Wade?
A.
Yes.
Q.
Okay. So he was the lead person for that loan?
A.
Yes.
Q.
Okay. And as far as you know, the only thing Carolyn Wade
did with respect to that loan was sign the DocuSign?
A.
I don't remember if that's the only thing she did. I only
uploaded the Schedule C, and Tracy Wade, with her, did their
part. I don't know.
Q.
Okay. One moment.
Now, we touched on it earlier. You pled guilty to
conspiracy to commit offenses against the United States in
violation of 18, United States Code, 371; is that right?
A.
Yes.
MR. WILCOX: May I approach?
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THE COURT: Yes, sir.
BY MR. WILCOX:
Q.
I'm showing you what is going to be marked as defense
exhibit for identification 16.
Can you identify what that is?
A.
Yes.
Q.
What is that?
A.
Information.
Q.
An information.
And an information, basically that's the document
that you pled guilty to?
A.
Correct.
Q.
You admitted to all the allegations in that -- you admit
to all the allegations in that document?
A.
Yes.
Q.
Now, you're charged by information but you waived your
right to be charged by indictment. Do you understand what
that is?
A.
Yes.
Q.
Do you understand that you had a right to be charged by an
indictment?
A.
Yes.
Q.
And do you know that an indictment is returned when a
grand jury hears evidence from the Government and the grand
jury decides that you should be charged?
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A.
Yes.
Q.
And you waived that?
A.
Yes.
Q.
And that was part of your plea agreement?
A.
Yes.
Q.
And you're only charged with one count?
A.
Yes.
Q.
I'm sorry. I'll show you the document. I'll show you the
information again, if I need to.
But in that one count of conspiracy, they allege that
you conspired to do two crimes; is that right?
A.
I was -- I pled guilty to conspiracy and false
information.
Q.
But the allegation in the information alleges that you --
Judge, can I just introduce -- I move to introduce
Defense Exhibit 16.
THE COURT: Any objection?
MR. SNIDER: No.
THE COURT: Received.
(Defense Exhibit 16 was received in evidence.)
BY MR. WILCOX:
Q.
You only were charged with one count; is that right?
A.
Yes.
Q.
And here it says that -- starting with your name, "Haydee
Rivero, formerly known as Haydee Granados, did willfully, that
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is, with intent to further the objects of the conspiracy, and
knowingly combine, conspire, confederate, and agree with
Carolyn Wade, Tracy Wade, and with others, known and unknown
to the United States Attorney, to commit certain offenses
against the United States."
Do you see that there's an "S" after offenses? Do
you see that?
A.
Yes.
Q.
One is that you, (a), to knowingly, and with intent to
defraud, devise and intend to devise a scheme or artifice to
defraud, and to obtain money by means of materially false and
fraudulent pretenses, representation, and promises, knowing
that the pretenses, representations, and promises were false
when fraudulently made --
THE COURT: Counsel, is all of that on the screen?
THE JURY: No.
THE COURT: So if you want --
MR. WILCOX: Thank you, Your Honor.
BY MR. WILCOX:
Q.
But it's basically charged in violation of Title 18,
United States Code, 1343; is that right?
A.
Yes.
Q.
And that's a conspiracy to commit wire fraud they're
alleging you're doing; is that correct?
A.
Yes.
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Q.
And if we go to (b), it says "To make any" -- that is --
"to make any statement knowing it to be false for the purpose
of obtaining for herself or for any applicant any loan, or
extension thereof by renewal, deferment of action, or for the
purpose of influencing in any way the action of the United
States Small Business Administration for the purpose of
obtaining money, property, or anything of value, under
Title 15, United States Code, Section 645(a)."
So that's a separate crime of making false statements
to the SBA; right?
A.
Correct.
Q.
Okay. So they combined two crimes and one conspiracy;
right?
A.
Yes.
Q.
Okay. And that's the only thing you're charged with?
A.
Yes.
Q.
You're not charged individually with helping all of those
people that you helped to give loans to?
A.
Correct.
Q.
Okay. And you tried to help at least 18 other people
other than the Wades and yourself; right?
A.
Correct.
Q.
You're not charged with 18 counts. You're only charged
with one count; correct?
A.
Yes.
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Q.
And you're not charged with separate conspiracies. You're
not charged with the conspiracy to commit wire fraud and a
conspiracy to lie to the SBA. You're not charged with that;
right?
A.
No.
Q.
You're only charged with one general conspiracy; correct?
A.
Correct.
Q.
Okay. Do you know how much that is punishable by?
A.
Up to five years.
Q.
Up to five years.
Do you know how much wire fraud is punishable by?
A.
No.
Q.
It's up to 20 years. We ask the Court to take judicial
notice that wire fraud is punishable by 20 years.
THE COURT: One moment. Any objection?
MR. SNIDER: No.
THE COURT: The Court judicially notes that the
maximum punishment is 20 years, as stated for the offense
stated.
BY MR. WILCOX:
Q.
And you could have been charged with wire fraud for each
of the 18 people that you helped get a loan?
MR. SNIDER: Objection.
THE COURT: Overruled.
BY MR. WILCOX:
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Q.
Right?
A.
That's not up to me.
Q.
I know it's not up to you, but it's up to them --
A.
Correct.
Q.
-- you know.
And they decided that even though you committed 18
acts of wire fraud, they were going to charge you with one
count of conspiracy; right?
A.
Yes.
Q.
The Government decided that; right?
A.
Correct.
Q.
A pretty good deal, uh?
A.
That's what they charged me with. I don't control that or
have anything -- that's not up to me.
Q.
Would you say that was a good deal for you?
A.
That's what they decided to charge me with. I have no
control over that.
Q.
I heard that. I understand you're not in control of that.
What I'm asking you -- and I want you to listen to my
question. Would you say that was a good deal for you?
A.
Yes.
Q.
I'm sorry, Your Honor. I seem to have misplaced my
questions.
Now, part of your agreement with the Government is
that if they determine that you had provided substantial
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assistance to them, they can move or request from your judge,
the judge that's going to sentence you, for a reduction in
sentence; is that right?
A.
Yes.
Q.
Okay. And you want them to do that?
A.
I would take -- I hope they take in consideration that I
am here today saying the truth -- that they take in
consideration that, but it's up to the judge.
Q.
I know, but you hope that the Government asks the judge to
give you a sentence below what you would normally get based on
your cooperation with the Government?
A.
Correct.
Q.
You understand that you are facing prison time for the
crime you've already admitted to?
A.
Yes.
Q.
And you do not wish to go to prison?
A.
Of course not.
Q.
In fact, the Government made it clear to you that just
because you testify here today that they're under no
obligation to recommend a reduction of sentence?
A.
Correct.
Q.
But you're hoping that they will?
A.
Yes.
Q.
So you're hoping that your testimony is pleasing to them?
A.
Yes.
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Q.
Now, you met with the Government to prepare for your
testimony? That's correct?
A.
Yes.
Q.
About how many times?
A.
We met four times.
Q.
Four times?
A.
Yes.
Q.
Thank you, Mr. McCray.
I want to -- Your Honor, I'm not sure. Have we
admitted Defendants' Exhibit 7?
THE COURT: Admitted?
MR. WILCOX: Yes.
THE COURT: No, sir.
MR. WILCOX: Your Honor, I would like to admit
Defendants' Exhibit 7.
MR. SNIDER: I think you need to lay a foundation for
it.
THE COURT: I don't have 7 as a foundation. So what
is 7? I don't have 7 on my list for identification, that is.
I do not have 7 for identification listed.
MR. WILCOX: I'm sorry, Your Honor. Okay. Let's do
that.
BY MR. WILCOX:
Q.
Ms. Granados, is your email address hgranados29@gmail.com?
A.
Yes.
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Q.
And I'm sorry. I should have said Ms. Rivero. I
apologize.
And did you send email communications to Tracy Wade
with respect to Carolyn Wade's PPP loan application?
A.
I don't remember.
MR. WILCOX: May I approach?
THE COURT: Yes, sir.
BY MR. WILCOX:
Q.
Do you remember receiving that email?
A.
No.
Q.
It is your --
A.
Yes, that's my email.
Q.
It is --
A.
That is my email.
Q.
That is your email address; is that right?
A.
Yes. Mm-hmm.
Q.
And do you recognize Tracy Wade's email address?
A.
Yes.
Q.
So and the document appears to have been sent to you, from
Tracy Wade to you -- from Tracy Wade on March 26, 2021?
A.
Yes.
Q.
And it has some attachments; is that correct?
A.
Yes.
Q.
And do you see the first one on the left -- do you see
that I -- that large ID?
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A.
What do you mean? I don't understand.
Q.
Do you see the document to the left of the email?
A.
Yes. It doesn't -- yes, I see it.
Q.
Okay. If you turn to the second page.
A.
Mm-hmm.
Q.
Now that's a voided check from 1 Step A-Head hair salon?
A.
Yes, I see it.
Q.
Would you agree that this voided check was sent to you
from Tracy Wade?
A.
Yes.
MR. WILCOX: Okay. I would like to admit Exhibit 7.
THE COURT: For identification.
Government?
MR. SNIDER: No objection.
THE COURT: Received as marked.
(Defense Exhibit 7 was received in evidence.)
MR. WILCOX: May I publish to the jury?
THE COURT: Yes, sir. That's 7; correct?
MR. WILCOX: That is correct.
BY MR. WILCOX:
Q.
This is the email that Tracy Wade sent to you; is that
correct?
A.
Yes.
Q.
Do you see the number here? Do you know what that number
is?
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A.
That's an EIN number.
Q.
What do you need that for?
A.
That comes with her corporation.
Q.
Whose corporation?
A.
Carolyn Wade's.
Q.
Okay. So that's the number associated with her
corporation or her business; correct?
A.
Correct.
Q.
Tracy sent you a voided check from 1 Step A-Head hair
salon?
A.
Yes.
Q.
And you requested that; right?
A.
I didn't request that.
Q.
You did not?
A.
No.
Q.
But it was sent to you --
A.
Yes.
Q.
-- by Tracy Wade on behalf of Carolyn Wade --
A.
Yes.
Q.
-- for a business called 1 Step A-Head?
A.
Yes.
MR. WILCOX: Your Honor, I just want to check.
I'm almost done, Ms. Rivero.
BY MR. WILCOX:
Q.
Do you remember completing a PPP application for Walter
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Wright?
A.
No.
Q.
Walter Wright?
A.
No.
Q.
One moment, Your Honor.
MR. WILCOX: Your Honor, I don't have any -- well,
let me check with my co-counsel and assistant first.
I don't have any more questions for Ms. Rivero.
Thank you, Ms. Rivero.
THE COURT: Redirect?
MR. SNIDER: Yes, Your Honor. I'm going to take the
podium, if that's okay. I'm going to need a moment to set up,
please.
REDIRECT EXAMINATION
BY MR. SNIDER:
Q.
Good morning, Ms. Rivero.
A.
Good morning.
Q.
So yesterday when you were on cross-examination, the
defense showed you an exhibit that was marked for
identification as Defense Exhibit 8 and then the defense moved
that exhibit into evidence and the Court received it. And I'm
going to publish that for everyone now, which I have put into
my program to publish.
Do you recognize Defendants' Exhibit 8?
A.
Yes.
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Q.
Do you remember seeing it yesterday?
A.
Yes.
Q.
We're going to go to the last page. We're on the last
page of Defense 8, which is page 4. Do you see that?
A.
Yes.
Q.
Do you remember seeing that yesterday?
A.
Yes.
Q.
And do you remember Mr. Wilcox asking you questions about
this?
A.
Yes.
Q.
What are we looking at on page 4?
A.
A voided check from Wade Funeral Home.
Q.
Did this voided check relate to the Paycheck Protection
Program loan that you were involved with for Tracy Wade?
A.
No.
Q.
I believe that you testified yesterday that this -- well,
let me ask you this.
What did you testify yesterday that this document
we're looking at here, this check, related to?
A.
That information that was shown to me yesterday and was
sent to me by email had nothing to do with the application I
completed.
Q.
Do you know which application, if any, it did relate to?
A.
Yes, for a business loan Tracy Wade was applying for.
Q.
Are you familiar with that loan?
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A.
Yes.
MR. WILCOX: Objection, Your Honor. This relates to
the matter that we may have to --
THE COURT: Come sidebar.
MR. WILCOX: Come sidebar.
(The following proceedings were held sidebar:)
THE COURT: There's an understanding so far the
document --
MR. SNIDER: Defense 8.
THE COURT: Defense 8 is in evidence. There have
been questions asked about various loans and whether the
witness is familiar with them or not. So now she's being
asked, one, did you receive it, yes, and what does 8 relate
to; correct?
MR. SNIDER: Yes.
THE COURT: All right. And now, what is the
objection?
MR. WILCOX: I believe that the witness is going to
testify that the exhibit -- void check --
THE COURT: I'm sorry. That?
MR. WILCOX: That the void check -- the void check
related to either an IPI loan or the PPP loan, which is the
subject of the Government's 404(b) motion.
THE COURT: This is not really 404(b). The thing
that makes it evidentiary is that the check is in evidence,
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and he's asking her about this check and why did you receive
this check or what was the reason for it, the same as you
asking her about various checks that she didn't recall. So I
don't see that as the same issue. What is the witness going
to say?
MR. SNIDER: Your Honor, it is the Government's
position that the defense has now --
THE COURT: Wait a minute. What is she going to say?
MR. SNIDER: She is going to say that this relates to
a business -- a separate PPP loan for the business Wade
Funeral Home. She is aware of that loan and she -- I'm going
to ask her how much that loan was seeking, and she knows the
amount and she --
THE COURT: Was this loan processed by her?
MR. SNIDER: No, but she's aware of it. She received
documents about it.
THE COURT: One moment.
MR. SNIDER: Go ahead.
THE COURT: So she received documents that related to
a different program.
MR. SNIDER: The same program. It's a PPP loan.
THE COURT: It's a -- this is a PPP loan -- thank
you. And she received the documents, but what, she didn't
process it or --
MR. SNIDER: We're going to ask her.
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THE COURT: Well, what is she going to say, is the
question. Do you know?
MR. SNIDER: She did not process it, correct. She
was not -- and this goes to the heart of something that's
important.
THE COURT: I don't need to know about the heart.
Just tell me what the facts are.
MR. SNIDER: The facts are that Mr. Wade applied for
a separate PPP loan for his business. So what that shows --
THE COURT: I'm trying to keep the facts --
MR. SNIDER: The defense --
THE COURT: One moment. He receives a check -- a
voided -- I mean, she receives -- Ms. Rivero receives a voided
check for what purpose? To process a different loan?
MR. SNIDER: Well, in connection with a -- yes, a
loan for the Wade Funeral Home, which is why that check was
sent to her. The extent of her involvement I'm going to ask
her, but I know, because I've asked her before, did you
process a loan -- did you apply for a loan for a business Wade
Funeral Home, and the answer is no. In fact, she testified on
direct she didn't know how to do -- the only loans she knew
how to do were for sole proprietors. This is a separate --
THE COURT: All right. All right. I think she can
be asked did you receive this voided check and what was the
purpose? The purpose was to process a PPP loan which was not,
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in fact, processed -- is that correct? -- which is not --
MR. SNIDER: By her. It was applied for -- yes, it
was applied for.
THE COURT: Now, when you say applied for, she did
something?
MR. SNIDER: She didn't do it. Someone else did,
someone else that she's aware of. And this is the evidence
that I wanted to -- there is a separate PPP loan application
for Wade Funeral Home. It represents that Wade Funeral Home
had 45 employees and $3 million in payroll in 2020. Attached
to that --
THE COURT: Is there a document with all of this?
MR. SNIDER: I've been asking to move that into
evidence.
THE COURT: No, no, no. I'm asking did she --
MR. SNIDER: She did receive -- yes, she received an
email attached, which it was in evidence.
THE COURT: It was in evidence?
MR. SNIDER: Yes. Yesterday morning, I asked the
Court to withdraw from evidence a document that had been
admitted, and the reason that I did that was because attached
to that email was a reference to this loan. And at that
point, because of the Court's ruling on deferring -- I didn't
want -- I didn't want to -- even the appearances I was trying
to get something through the back door.
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We are in a different posture now because she has
testified -- because the defense has put into evidence an
exhibit that relates to this other loan. She has testified
during cross-examination that this check related to another
PPP loan for Wade Funeral Home. I am now going to ask her
about that. And when we're finished, I'm going to try to move
into evidence that actual --
THE COURT: No, I'm not going that far. Here's what
you can do -- one moment. You may ask her what this reference
is and she may respond it references another loan. And you
can ask her did she process the loan as she has for other
cases, and apparently she's going to say, "No, I didn't
process the loan."
MR. SNIDER: Can I ask her if she knows anything else
about it?
THE COURT: Well, no, because what else if she didn't
process it --
MR. SNIDER: Because she knows that that loan saw a
$700,000 -- she knows that because she got an email. I can
show her the email. She got an email from the person who did
it.
THE COURT: Who is the person?
MR. SNIDER: Her name is Odalys Concepcion.
THE COURT: I mean, these are a lot of facts I
haven't heard anything about, and so --
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MR. SNIDER: I think it's fair to go down -- at least
ask her about, "Do you know anything about this application?"
And she can answer if she knows.
THE COURT: I am going to ask for an out-of-court
hearing to hear the testimony about this other issue so that I
can figure out where we are because I'm not quite sure.
MR. SNIDER: Okay.
THE COURT: Okay.
(The following proceedings were held in open court:)
THE COURT: Perfect timing because an issue has
arisen that I want to address that's going to take a little
more time than usual, so we're going to do that consistent
with your break at this time, and we'll get back to you as
soon as possible. And once we finish, I'm going to give them
a little time for a break too. So we'll be back with you as
quickly as we can. Thank you.
(Jury exited at 10:54 AM.)
THE COURT: All right. Be seated, please.
MR. SNIDER: May I take the podium, please?
THE COURT: Yes, sir.
You may proceed.
BY MR. SNIDER:
Q.
Okay. Ms. Rivero, you received the check that is on
display here, page 4 of Defendants' 8?
MR. WILCOX: Objection to the leading, Your Honor.
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MR. SNIDER: I think we're laying --
THE COURT: Based on what we've already heard,
overruled.
BY MR. SNIDER:
Q.
Did you receive this check that is on page 4 of
Defendants' 8?
A.
Yes, I received that email.
Q.
You received the email, and attached to the email was --
one of the attachments was the check that's on page 4?
A.
Yes.
Q.
Okay. And what is your understanding of what this --
THE COURT: First, did you request this check, ma'am?
THE WITNESS: No, I did not.
THE COURT: Why did you receive the check, if you
know?
THE WITNESS: My husband told Tracy Wade to forward
me all that information via email so that I can send it to my
husband's accountant because she was going to apply for a
business loan through my husband's accountant.
BY MR. SNIDER:
Q.
Who's your husband's accountant?
A.
Odalys Concepcion.
THE COURT: Is this because someone told you this?
In other words, your husband told you about this check?
THE WITNESS: My husband told me that Tracy was going
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to email me all that information and to forward it to his
accountant.
THE COURT: All right. So you received the check and
then you -- the voided check -- and you forwarded that check
to your husband; correct?
THE WITNESS: No, to my husband's accountant, Odalys
Concepcion.
THE COURT: You forwarded the check to your husband's
accountant?
THE WITNESS: Correct.
THE COURT: So that's the non-hearsay testimony.
MR. SNIDER: Yes. She received the check.
THE COURT: She received the check and she forwarded
the check to her husband's accountant, period. That's all
nonhearsay.
BY MR. SNIDER:
Q.
Did you testify on cross-examination why it is that you
received this check?
THE COURT: Because of hearsay.
MR. SNIDER: Sorry?
THE COURT: Because of hearsay. Someone told her
something.
MR. SNIDER: But it's in the record now.
THE COURT: Sir, what's in the record is the check.
Why did you receive the check? What did you do --
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you received the check. What did you do with the check?
I forwarded the check to my husband's accountant.
BY MR. SNIDER:
Q.
And why did you do that?
A.
Because he was -- she was going to apply for a business
loan for Tracy Wade.
THE COURT: See? That's hearsay.
BY MR. SNIDER:
Q.
Did you ever receive a document from that accountant?
A.
Yes.
Q.
Was it an email?
A.
Yes.
Q.
Was something attached to it?
A.
Yes.
MR. SNIDER: May I approach? Well, actually, the
jury is not here. May I publish it for her?
THE COURT: Yes, sir. You can mark it for
identification.
BY MR. SNIDER:
Q.
I'm marking for identification Government Exhibit 2002,
and I'm just going to show it to you because the jury is not
presently in the courtroom.
Do you recognize Government Exhibit 2002?
A.
Yes.
Q.
And what is this?
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A.
It's an email from Odalys Concepcion.
Q.
And what is the date of the email?
A.
May 6 of 2021.
Q.
Who is it sent to?
A.
Me.
Q.
Did you receive it?
A.
Yes.
Q.
We're going to page 2 of what's been identified for the
record as Government Exhibit 2002. Do you see that?
A.
Yes.
Q.
And do you remember receiving the attachment to it?
A.
Yes.
Q.
What does it say?
A.
It's an estimate loan application.
Q.
Okay. And what is the estimated loan amount?
A.
701 -- 701,873.
Q.
And when was the application started, according to this?
A.
May 6, 2021.
THE COURT: So what application started? Tell me
more.
BY MR. SNIDER:
Q.
Do you have an understanding of what that --
THE COURT: Not your understanding. Her personal
knowledge. Okay?
BY MR. SNIDER:
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Q.
Do you have personal knowledge that an application was
submitted apart -- a PPP loan apart from the one you did that
related to Tracy Wade's business?
A.
Yes.
THE COURT: And how do you know that?
THE WITNESS: Because Odalys Concepcion, the
accountant, forwarded me that email with that attachment
stating she started an application for Wade Funeral Home.
THE COURT: How do you know what this is for? Did
someone tell you or you're looking at the document or what?
THE WITNESS: Yes, I was told by my husband --
THE COURT: See?
THE WITNESS: Yes.
THE COURT: That's what the problem is. So I'm just
explaining to you what the problems are. So you work around
those problems in the way --
BY MR. SNIDER:
Q.
This is an email that you received?
A.
Yes.
Q.
And it's for an estimated loan amount for $701,873?
A.
Yes.
MR. SNIDER: The fact that she received this is not
hearsay. I'm going to move this into evidence, the fact that
she got it.
THE COURT: She received it from the defendant;
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correct?
MR. SNIDER: Not from the defendant.
THE COURT: She received this -- now I'm confused.
MR. SNIDER: I'm going to go to the first page. This
is from Odalys Concepcion. That is her husband's accountant
who sent it to her.
THE COURT: And why did he send it to you, ma'am?
THE WITNESS: So that I can print it out and give it
to my husband.
BY MR. SNIDER:
Q.
Let me ask you a question. Is your husband good with
computers?
A.
No.
Q.
Do you sometimes print things out for him?
A.
Yes.
Q.
Does he use email frequently?
A.
No.
Q.
Is he good at using email and receiving and printing
things?
A.
No.
Q.
Are you?
A.
Yes.
THE COURT: All right. You received it?
THE WITNESS: And I printed it out.
THE COURT: And you printed it?
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THE WITNESS: Yes.
THE COURT: And gave it to your husband?
THE WITNESS: Correct.
THE COURT: All right.
MR. SNIDER: The Government moves to admit
Government 2002.
MR. WILCOX: Your Honor, and I'm going to --
THE COURT: All right. I'm listening.
MR. WILCOX: Your Honor, one, I would object to
relevancy because if you look at this loan overview, there's
not one reference to Tracy Wade in here.
MR. SNIDER: Actually, there is. If you look at the
first page, the subject of this is Wade Funeral Home.
THE COURT: May I see the first page again?
MR. SNIDER: It's on the screen, if you can see it,
Judge. I'll make it larger so you can...
THE COURT: All right. And the attachment, bring
that up again.
All right. So what's the additional testimony, if
any?
MR. SNIDER: The Government is trying to separate
this loan for Wade Funeral Home from the one she did. The
defense -- yes. Because -- the defense is trying -- what the
defense is now -- it's clear that their theory is that, you
know, he thought that he was applying for a PPP loan through
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Ms. Rivero for Wade Funeral Home --
THE COURT: Wait a minute. I lost you.
MR. SNIDER: The defense is trying to conflate these
two loans to show that Mr. Wade was trying to apply for a
loan -- that the loan that he got for $20,000 was for his
business. And what this shows is that it was an entirely
separate loan --
THE COURT: I don't know that it shows that.
MR. SNIDER: Well, she's testified on direct she
doesn't know how to do loans for a business like Wade Funeral
Home, and I'm going to establish on redirect that she -- the
one that she did was for Tracy Wade in his own name, not for
Wade Funeral Home.
THE COURT: We have that testimony; right?
MR. SNIDER: They have opened the door to this
argument that Mr. Wade was sending her information for Wade
Funeral Home for her to do a loan for Wade Funeral Home, and
this rebuts that.
THE COURT: It does rebut it with regard to your
argument. Do you follow me? In other words, your argument is
that this was not for a particular loan. This was not for a
$20,800 loan.
MR. SNIDER: Exactly. It was a separate one.
THE COURT: Your argument is to the jury that this
shows it was a separate loan.
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MR. SNIDER: I'm just admitting, for the record --
THE COURT: My point is you're not arguing it through
her. Your oral argument to the jury at the conclusion of the
case is that this rebuts that concept.
MR. SNIDER: But I need the document in evidence to
make that argument.
THE COURT: I understand. I understand.
Defense.
MR. MCCRAY: Judge, I just want to interject. I
think that this could be accomplished by the witness simply
saying this was for an unrelated SBA loan or business loan.
We don't have to get into the details of the loan as counsel
has projected up at the sidebar.
THE COURT: I'm not following, Counsel.
MR. MCCRAY: You're not following me?
THE COURT: No.
MR. MCCRAY: All I'm saying is if we look at the
reason why --
THE COURT: All right. Let's just assume she
receives an email -- right? -- and attached to that -- that's
addressed or subject matter Wade Funeral Home. She receives
it and it has an attachment. That's really the testimony.
All right?
Now, he's going to argue something during closing and
you're going to argue something during closing.
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MR. MCCRAY: Oh, I agree with that.
THE COURT: And that's where we are. And that ends
the scenario.
MR. SNIDER: Is the Court receiving this into
evidence? And I'll ask the questions you just went over.
THE COURT: Yes, sir.
MR. SNIDER: It's received?
THE COURT: Received.
(Government Exhibit 2002 was received in evidence.)
MR. SNIDER: Thank you.
MR. WILCOX: With respect to the --
THE COURT: And we aren't going to go beyond what
we've --
MR. SNIDER: Exactly.
THE COURT: All right.
MR. SNIDER: Correct. I'm going to ask her, was she
involved in a PPP loan --
THE COURT: Not involved in anything. You received
an email. The document has Wade Funeral Home and it has an
attachment; right?
MR. SNIDER: And I'm going to establish -- yeah. And
then I'm going to move on.
THE COURT: Exactly. Exactly.
MR. SNIDER: Do you want me to ask her or just move
on?
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THE COURT: Yes, you're going to move on. That's the
operative word.
All right. Yes, sir.
MR. WILCOX: Clarification, Your Honor. Are the
email and the attachments going to be admitted into evidence?
MR. SNIDER: It's one exhibit.
THE COURT: I'm sorry? You'll have to say that
again.
MR. WILCOX: It's Exhibit 2002, the email 2002.
THE COURT: And it says email and attachment thereto.
MR. WILCOX: So you're admitting the email and the
attachment?
THE COURT: That's correct.
MR. WILCOX: Well, Your Honor, we have a concern with
that -- the amount.
THE COURT: I understand your objection.
MR. WILCOX: Hmm?
THE COURT: You're objecting to that?
MR. WILCOX: Yes.
THE COURT: I understand.
MR. WILCOX: And you're overruling.
THE COURT: Yes, sir. You all opened the doors, so
here we are. Let's take a break. We'll take about what? 10,
15 minutes.
By the way, we have to end today -- gentlemen?
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MR. SNIDER: I'm listening.
THE COURT: Mr. Wilcox?
MR. WILCOX: Excuse me? I'm sorry.
THE COURT: We have to end today at 3:00 PM. I have
several hearings starting at 3:00, and so today's session will
end at 3:00. And just -- I'm not sure where we're going to
be. But on Friday, there's an investiture that starts at
3:00 PM, which I have to attend. It's next door. So I'm
going to have to be away. I'm not sure where we will be at
that time, but just be mindful, today 3:00 PM and Friday --
well, they say be there at 2:30, but 15 till at least. If
it's a convenient time at 2:30, we will. If it makes any
difference, I may stay a few minutes longer.
Now, having said that, where do you think we might be
over the next couple of days if we end today at 3:00 PM?
MR. SNIDER: Judge, so if we resume -- I mean, my
redirect is going to take maybe 10 to 15 minutes. Then I
think the Court was going to take up some matters relating to
the 404(b) that we have noticed before the agent testifies --
THE COURT: I thought you told me --
MR. SNIDER: What?
THE COURT: I thought you told me that the 404(b)
witnesses were not being presented.
MR. SNIDER: Correct. We were going to move the
records into evidence as business records pursuant to a
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902.11.
THE COURT: And I asked you to confer with your
counsel.
MR. SNIDER: I did. And I believe their position was
with respect to the IDLE records, they did not object to the
authenticity or that they were business records for purposes
of the hearsay exception.
THE COURT: All right.
MR. SNIDER: So now it's up to the Court
substantively to determine whether they come in under 404(b).
THE COURT: Oh, without the witnesses, I'm not going
to receive them as 404(b). So now the next step is are they
relevant.
MR. SNIDER: Yes.
THE COURT: And if they're relevant, then the
self-authenticating exception to the hearsay rule would allow
its admissibility, but that's something I'm going to have to
determine when you explain to me why it's relevant. Okay?
MR. SNIDER: So can I tee up part of it? Let's talk
about the loan application. I'm more concerned about the loan
application for the $700,000 PPP loan.
THE COURT: All right.
MR. SNIDER: What is now in evidence as Government
Exhibit 2002 on page 2 is a reference to that. The records
that I wanted to move in are business records just like the
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hundred plus documents that are already in evidence. They're
just computer-generated --
THE COURT: Hundred plus are relevant. Now, you're
going to tell me why they are relevant. I'm going to listen
to your argument --
MR. SNIDER: Okay.
THE COURT: -- and then I'm going to make a decision.
MR. SNIDER: All right.
THE COURT: So let's take a --
MR. SNIDER: As far as the rest of the schedule, so
then I would call Agent DiPietrantonio.
THE COURT: The next witness?
MR. SNIDER: Yes.
THE COURT: How long do you expect her testimony to
be?
MR. SNIDER: Two hours.
THE COURT: All right. And how long do you expect
your case in chief will be?
MR. SNIDER: After that, the Government expects to
rest -- oh, I'm sorry. I thought you were talking --
THE COURT: I'm just trying to plan ahead. No one's
obligated.
MR. MCCRAY: Judge, we would anticipate about
maybe -- I can't -- I don't know how long they're going to
take, but we think about three hours for our witnesses.
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THE COURT: All right. So we are likely going to be
have closings either Friday or Monday. I'm not sure when that
will be. We'll handle it accordingly. So we're pretty much
still on schedule, which is good news.
All right. We are in recess. Let's take 15 minutes.
(Recess at 11:14 AM to 11:29 AM.)
MR. WILCOX: Your Honor, I know that the Court
generally frowns upon recross, but I think this opens up a new
area, and I'd like to --
THE COURT: What opens up a new area? The exhibit?
MR. WILCOX: Yes, this exhibit -- and I apologize. I
think it's 2001.
MR. SNIDER: 2002.
THE COURT: 2002.
MR. WILCOX: Okay. Exhibit 2002 opens up a new area,
and I think I should be allowed to recross on that --
THE COURT: The Government's position? This is a new
item. I don't usually have it surface this way. And I don't
usually allow recross, but this is a new exhibit, and my
inclination is to allow it.
MR. SNIDER: Would the Government be allowed a
redirect after that recross?
THE COURT: Wait. Now we're getting into the
California review and re, re and re, re, re, re. No, you ask
the questions that we've discussed. If he opens up a new
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area, then I'll consider it, but frowned upon. All right?
MR. SNIDER: All right. Our position is --
THE COURT: I understand your position. Let me see
where we are after he finishes, and then I'll have to take a
position.
All right. Bring the jury in, please.
(Jury entered at 11:31 AM.)
THE COURT: Defense, can I have you all come sidebar
quickly?
(The following proceedings were held sidebar:)
THE COURT: So as you all know, I don't usually allow
this recross. This is a little different.
Be seated, please.
This scenario is a little different because an
exhibit is being introduced subsequent to your cross, but
there are risks with that, so I'm going to listen to your
questions and then I'll decide what, to any extent, he can
ask.
MR. WILCOX: Yes, Your Honor.
THE COURT: I'm just putting you on notice.
MR. SNIDER: Thank you. Thank you.
(The following proceedings were held in open court:)
MR. SNIDER: May I proceed?
THE COURT: Yes, sir.
BY MR. SNIDER:
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Q.
Ms. Rivero, I'm going to publish for you and the jury an
exhibit that was received into evidence during the break
called Government 2002.
Do you see Government 2002 on your screen?
A.
Yes.
Q.
Do you recognize this document?
A.
Yes.
Q.
What is the type of document that we're looking at on the
first page?
A.
It's an email.
Q.
And I'm going to enlarge part of the email.
Is this an email that you received?
A.
Yes, I received that email from Odalys Concepcion.
Q.
Who is Odalys Concepcion?
A.
She's my husband's accountant.
Q.
What is the date that you received this email?
A.
May 6, 2021.
Q.
And what is the subject of the email?
A.
Wade Funeral Home.
Q.
Did this email have an attachment to it?
A.
Yes.
Q.
I've now moved to page 2 of Government's 2002. Do you see
that on your screen?
A.
Yes.
Q.
Is this attachment that was attached to the email that you
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received from Odalys Concepcion on page 1 of Government 2002?
A.
Yes.
Q.
I'm going to enlarge a section.
What do you read in the section I just enlarged?
A.
A loan overview.
Q.
Do you see a section that says "estimated loan amount"?
A.
Yes.
Q.
What is the amount that you see there?
A.
701,873.
Q.
Do you see a section on this that says "application
started"?
A.
Yes.
Q.
What is the date that you see there?
A.
May 6 of 2021.
Q.
Do you see a section that says "application number"?
A.
Yes.
Q.
What is the number, for the record?
A.
6781674.
Q.
Ms. Rivero, did you start this application?
A.
No.
Q.
Ms. Rivero, what did you do, if anything, when you
received this email?
A.
I printed it out and gave it to my husband.
Q.
Is your husband good with computers?
A.
No.
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Q.
Does he use email frequently?
A.
No.
Q.
Do you ever assist him in receiving information because
he's not good at computers?
A.
Yes.
Q.
I'm enlarging the top portion of this document. What does
it say there?
A.
SmartBiz.
Q.
Do you know what SmartBiz is?
A.
It's SBA.
Q.
Have you ever gone to SmartBiz's website?
A.
No.
Q.
You testified that you did loans on what website?
A.
Womply.
Q.
Have you ever done a PPP loan through SmartBiz?
A.
No.
Q.
Ms. Rivero, did Mr. Wade ever ask you to do a Paycheck
Protection Program loan for Wade Funeral Home?
A.
No.
Q.
Did Mr. Wade ever ask you to do a Paycheck Protection
Program loan for a business called 1 Step A-Head?
A.
No.
Q.
Ms. Rivero, do you know how to do a Paycheck Protection
Program loan for a business like Wade Funeral Home?
A.
No.
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Q.
Do you know how to do Paycheck Protection Program loans
for any other business other than the ones that you were
involved with that you've testified about in this trial?
A.
No.
Q.
Now, during cross-examination, Mr. Wilcox asked you about
a number of other PPP loans that you were involved with;
right?
A.
Yes.
Q.
And were those the loans and individuals that I had asked
you about when I was asking you questions first on direct
examination?
A.
Yes.
Q.
Did Mr. Wilcox ask you about every person that I had asked
you about?
A.
Yes -- most of them, yes.
Q.
I believe there may have been one person that Mr. Wilcox
asked you about that I didn't and that was Victor Rivero; is
that right?
A.
Yes.
Q.
And did you do a loan for Mr. Rivero?
A.
I don't remember.
Q.
Have you told this jury about every Paycheck Protection
Program application that you were involved with?
A.
Yes.
Q.
Have you told this jury about every Schedule C that you
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created?
A.
Yes.
Q.
And is it true that some names that I asked you about you
didn't remember?
A.
Correct.
Q.
Have you told the jury about every loan that you remember
preparing?
A.
Yes.
Q.
And your role in preparing the Schedule Cs for those
Paycheck Protection Program loans, is that part of the
conspiracy that you pled guilty to?
A.
Yes.
Q.
So have you accepted responsibility for your conduct as it
relates to the other individuals that you were involved with
in the PPP program?
A.
Yes.
Q.
You were asked some questions during direct examination
about a Second Draw. Do you remember that?
A.
Yes.
Q.
And when I was asking you questions on direct examination,
I asked you how many PPP loans you got?
A.
Yes.
Q.
And what was your answer?
A.
Two.
Q.
The second loan that you received, was that a Second Draw?
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A.
Yes.
Q.
And I believe you testified that the process for the
Second Draw was not the same as the first; is that right?
A.
Correct.
Q.
And you testified on cross-examination that you were aware
that some of the individuals for whom you prepared Schedule Cs
for a First Draw also got a Second Draw?
A.
Yes.
Q.
Was your involvement with respect to those second draws
the same as it was with the first?
A.
Yes.
Q.
Did you have to create Schedule Cs again?
A.
No. No, it was not the same.
Q.
It was not the same?
A.
No, it was not.
Q.
I believe you testified on direct examination that you
were invited. Is that the word that you used to get a Second
Draw?
A.
Yeah, Womply sends you an email stating if you want to go
ahead and do a second loan.
Q.
And with respect to your Second Draw, you didn't have to
do the whole thing over again?
A.
No.
MR. WILCOX: Objection to the leading, Your Honor.
THE COURT: Sustained.
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BY MR. SNIDER:
Q.
Ms. Rivero, have you told this jury everything that you
did with respect to the PPP loan application for Tracy Wade?
A.
Yes.
Q.
And that was a PPP loan application for how much?
A.
20,000.
Q.
Have you told the jury everything that you did with
respect to the PPP loan application for Carolyn Wade?
A.
Yes.
Q.
And that was a PPP loan application for a loan for how
much?
A.
20,000.
Q.
And with respect to your role, what was the two things
that you did on the Womply website?
A.
I created the Schedule C, I filled it in, uploaded it, and
one of the numbers on the Schedule C I inputted in the website
of Womply.
Q.
And did you get paid for doing that?
A.
Yes.
Q.
By Carolyn Wade?
A.
Yes.
Q.
And by Tracy Wade?
A.
Yes.
MR. SNIDER: No further questions.
MR. WILCOX: Can I borrow your Exhibit 2002?
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RECROSS-EXAMINATION
BY MR. WILCOX:
Q.
Good morning, Ms. Rivero. I just want to ask you a couple
of questions relating to the Government's Exhibit 2002, but
before I do that, I just want to refresh your recollection.
Now, you said that you did not -- I'm showing you
part of Defense Exhibit 8.
I don't have a screen. Are the screens on?
Now, you indicated you did not request this from
Mr. Wade?
A.
Yes.
Q.
And that somehow -- but this was sent to you on March 22,
2021?
A.
Yes, 2021.
Q.
Right.
And that's the date of the email?
A.
Yes.
Q.
You also testified that that check was sent for some other
purpose; is that right?
A.
Yes.
Q.
That your husband asked Mr. Wade to send that check to you
for some other purpose?
A.
Yes.
Q.
Well, Ms. Carolyn Wade also sent you a voided check?
A.
Yes.
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Q.
Your husband didn't ask her to send you this check for
some other purpose?
A.
I don't know what my husband spoke about with Tracy Wade.
I know that I received that email.
Q.
I understand you received that email, but what I'm saying
is that your husband didn't ask you for this check, did he?
A.
No.
Q.
He didn't request this from Carolyn Wade?
A.
No.
Q.
As far as you know, that is not for some other purpose?
A.
The email was sent to me. I didn't request it.
Q.
Ma'am, I'm asking you, as far as you know, this check was
not for some other purpose?
A.
Yes, it was. It was sent around the same time that Tracy
Wade sent me his email with his information in March of 2021.
Q.
So you're saying this check was sent --
A.
It was sent for a business loan under her business.
Q.
And -- one moment, Your Honor.
Ma'am, you testified yesterday you didn't even know
whether she had a business; isn't that correct?
A.
I'm going with what is in front of me right now -- what
you're showing me on the screen.
Q.
You testified yesterday you didn't even know whether
Ms. Wade had a business?
A.
Correct.
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Q.
Okay. But you received this check. You didn't look at
it. Is that what you're saying?
A.
I received it and I don't remember looking at it.
Q.
When did they send you this check?
A.
I don't know. It was sent by Tracy Wade.
Q.
Right.
On behalf of Carolyn Wade; right?
A.
Correct.
Q.
Okay. And now you're saying this check was for some other
purpose too?
A.
It was for a business loan.
MR. WILCOX: One moment, Your Honor.
BY MR. WILCOX:
Q.
This email that you received from the accountant that's
reflected in Government Exhibit 2002 was sent two months
later?
A.
Correct.
Q.
And you're saying that somehow this email in Defense
Exhibit 8 that was sent in March is related to this email that
was sent in May?
A.
Yes.
MR. WILCOX: One moment, Your Honor.
Nothing further, Your Honor.
MR. SNIDER: The Government has no further questions,
Your Honor.
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THE COURT: May the witness be permanently excused?
MR. SNIDER: From the Government's side.
THE COURT: May the witness be permanently excused?
MR. WILCOX: Yes, Your Honor.
THE COURT: All right. You may step down. You are
excused.
MR. WILCOX: Your Honor, we have her under subpoena,
so we would ask that she be available and she not be
permanently excused.
THE COURT: You are excused unless notified by
counsel to return.
THE WITNESS: Thank you, Your Honor.
THE COURT: Government?
MR. SNIDER: The Government is prepared at this time
to call Kelly DiPietrantonio. I understand that the Court was
going to entertain some argument before that with respect to
some other issues. Do you want to hear that now or how should
we proceed?
THE COURT: I'm not sure I'm following you.
MR. SNIDER: Maybe we should come sidebar.
THE COURT: All right, come sidebar.
(The following proceedings were held sidebar:)
MR. SNIDER: So I believe what the Court had
previously advised was that prior to the case agent testifying
it would make a ruling on the admissibility of two areas --
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THE COURT: I'm with you.
MR. SNIDER: So the first, Judge, is the loan
application that is from SmartBiz. It's the loan application
that was referenced in Government Exhibit 2002, that email
that I just showed Ms. Rivero. That is an application for
Wade Funeral Home. It states on it that Mr. Wade is the
primary contact, that he's the owner of Wade Funeral Home,
that it seems a PPP loan application based on payroll -- it
represents that Wade Funeral Home had over $3 million in
payroll in 2020. It represents that it had 45 employees.
Attached to the application were several documents that are
entirely false and fictitious. Three relate to that payroll
of purportedly $3 million showing --
THE COURT: How is that relevant to this case?
MR. SNIDER: It's relevant --
THE COURT: What is it going to show? When you say
it's false, what's the evidence that it's false?
MR. SNIDER: The evidence -- so there is evidence in
the record, tax returns, that there was no Form 941 filed with
the IRS. And the IRS agent --
THE COURT: The 941, why does it have --
MR. SNIDER: Because there was a 941 attached to the
application, and they represented that it had 45 employees and
$3 million in payroll.
THE COURT: Okay.
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MR. SNIDER: The relevance, Judge -- it's relevant in
several ways. The application was submitted on May 6, 2021,
the same day that Mr. Wade, the evidence shows, was involved
in the PPP loan application that we've been talking about in
this trial, the $20,000. It is a separate -- it shows it's
relevant because what it shows is Mr. Wade's knowledge that
what he was applying for with Haydee Granados was not for Wade
Funeral Home. It is for a business that didn't exist, which
was Tracy Wade, and he knows that because he separately
applied for a PPP loan for Wade Funeral Home for which there's
evidence we can show it was false.
THE COURT: Okay.
MR. SNIDER: My original argument was that because
this is literally the same day that he's applying for the
other one and it is a PPP loan, and the indictment alleges
that the purpose of the conspiracy was to get PPP loans based
on false information, this is the evidence of the conspiracy.
The Court at the time did not accept that and was treating
this as a 404(b).
And 404(b) -- what this goes to, Judge, is Mr. Wade's
knowledge, intent, absence of mistake with respect to the
charged PPP loan. In other words, he didn't make a mistake
and think he was getting a loan for Wade Funeral Home with
Ms. Granados. He knew he wasn't because he had separately
applied for one through a different person that claimed --
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THE COURT: A lot of the testimony you're telling me
about is not a part of this record.
MR. SNIDER: No, I'm explaining the relevance.
THE COURT: I know, but there has to be evidence of
record to support it, and you're giving me the inferences that
aren't in evidence. You might want to argue -- I understand
your point. Is there an objection?
MR. WILCOX: Yes, Your Honor, there's an objection.
And let me preface the objection with the defense's position
with respect to the $700,000 PPP loan. Mr. Wade had no
knowledge of that loan being filed on his behalf. There's no
IP address that connects that application --
THE COURT: Your objection really is there's no
evidence that this is relevant to this case is what you're
arguing, and the objection is sustained.
MR. SNIDER: Just so we're clear, the Government is
going -- if you're not letting it in in the case in chief,
then we're going to just reserve our right to cross-examine if
the defendant testifies.
THE COURT: That's a whole different issue. All
right.
(The following proceedings were held in open court:)
MR. SNIDER: Your Honor, we're ready to proceed with
the testimony of Special Agent Kelly DiPietrantonio of the
FBI. We just need a moment to set up.
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Your Honor, before I proceed with my direct
examination of Agent DiPietrantonio. I would like to read
into the record and publish a stipulation between the United
States and the defendants.
THE COURT: All right. So, ladies and gentlemen, a
stipulation is going to be published. Sometimes lawyers agree
as to certain facts or testimony, et cetera, and they
stipulate, meaning they agree to it so you can consider this
stipulation as you would any other evidence in the case.
You may publish.
MR. SNIDER: Thank you.
For the record, I have published what is a
stipulation marked as Government Exhibit 001, which reads as
follows:
"In the United States District Court for the Southern
District of Florida, Case Number 23-60173-CR-KMW (S) (Graham).
United States of America versus Carolyn Denise Wade and Tracy
D. Wade, Defendants. This is a trial stipulation regarding
communications transmitted by wire in interstate commerce.
"The United States of America and Defendants Carolyn
Denise Wade and Tracy D. Wade, through their respective
undersigned counsel, hereby stipulate and agree to the
following facts:
"As alleged in Count 2 of the superseding indictment
the disbursement of SBA Loan Number 6261949003, hereinafter
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referred to as PPP Loan 1, from Harvest Small Business
Finance LLC, identified in the superseding indictment as
Lender 1, in the approximate amount of $20,833 by automated
clearinghouse, that is, ACH transfer to USAA Federal Savings
Bank, account ending number 7309, was a communication
transmitted by wire in interstate commerce on or about June 3,
2021.
"Among other things, the funds for PPP Loan 1
originated from Lender 1's bank, which was a bank located in
the state of California, and the funds were transmitted
electronically via ACH transfer to a classic checking account
ending in 7309 at USAA bank, which was a bank located in the
state of Texas.
"As alleged in Count 3 of the superseding indictment,
the disbursement of SBA Loan Number 6697269001, hereinafter
referred to as PPP Loan 2 from Lender 1, in the approximate
amount of $20,833 by ACH transfer to USAA bank account number
ending in 3926, was a communication transmitted by wire in
interstate commerce on or about June 7, 2021.
"Among other things, the funds for PPP Loan 2
originated from Lender 1's bank, which was a bank located in
the state of California, and the funds were transmitted
electronically via ACH transfer to a checking account ending
in 3926 at USAA bank, which was a bank located in the state of
Texas.
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"The United States and defendants further stipulate
and agree the United States would prove the above-stated facts
beyond a reasonable doubt with evidence admissible at trial
under the Federal Rules of Evidence, including but not limited
to testimony and records from Lender 1, and that these facts
are deemed proven beyond a reasonable doubt."
The stipulation is dated September 23, 2024. It is
signed by David A. Snider, Assistant United States Attorney
for the United States Attorney Markenzy Lapointe, and is
signed for the defendants by Johnny L. McCray.
THE COURT: Received.
MR. SNIDER: Thank you.
(Government witness, KELLY DIPIETRANTONIO, duly
sworn.)
THE COURTROOM DEPUTY: Please state and spell your
full name for the record.
THE WITNESS: Kelly DiPietrantonio, K-E-L-L-Y. The
last name is D-I-P-I-E-T-R-A-N-T-O-N-I-O.
DIRECT EXAMINATION
BY MR. SNIDER:
Q.
It's now five minutes past 12:00, so I'll say good
afternoon.
A.
Good afternoon.
Q.
Special Agent DiPietrantonio, can you remind the jury
where you work?
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A.
I'm a special agent with the Federal Bureau of
Investigation.
Q.
I'm going to refer to the Federal Bureau of Investigation
as FBI. Is that okay?
A.
Okay.
Q.
How long have you worked for the FBI?
A.
Since 2014.
Q.
And how long have you been a special agent with the FBI?
A.
Since 2018.
Q.
Are you assigned to a particular squad?
A.
Yes, I am.
Q.
What squad is that?
A.
I'm assigned to the Broward County Public Corruption
Squad.
Q.
What do you do as a special agent for the public
corruption squad?
A.
I investigate federal criminal violations as they relate
to a public official. That could be a politician or a law
enforcement officer, somebody like that.
Q.
Does it have to be conduct that you're investigating of a
public official in the public official's capacity?
A.
No. Just while they maintain their capacity as a public
official.
Q.
Okay. Are you part or were you part of the team that
participated in an investigation that resulted in an
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indictment of Carolyn Wade and Tracy Wade?
A.
Yes, I was.
Q.
And during your participation in that investigation, did
you collect evidence?
A.
I did.
Q.
Did you collect evidence through the issuance of subpoenas
by a federal grand jury?
A.
I did.
Q.
And as a result of those grand jury subpoenas, did you, as
an agent with the FBI, receive records back?
A.
I did, yes.
Q.
Did you receive a lot of records?
A.
Yes.
Q.
And did you and other members of your team review those
records?
A.
We did.
Q.
Are you familiar with the records that you collected?
A.
I am, yes.
Q.
Did the records that you subpoenaed include records from
financial institutions or banks?
A.
They did, yes.
Q.
Did you subpoena particular accounts?
A.
I did.
Q.
With respect to Carolyn and Tracy Wade, what accounts were
you interested in?
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A.
I was interested in the accounts where they received the
proceeds of their PPP loans.
Q.
And did Carolyn and Tracy Wade receive the proceeds of
their PPP loans in the same account?
A.
No. It was two different accounts.
Q.
Did you subpoena both of those accounts?
A.
I did.
Q.
Did the records that you got back from the bank for those
accounts -- was that for just one year or more than one year?
A.
More than one year.
Q.
Approximately how many years of bank records did you
receive for the two accounts?
A.
I believe it was approximately four years.
Q.
So four years of records for two different accounts, each
of which received the proceeds of the PPP loans, one for
Carolyn Wade and one for Tracy Wade?
A.
That's correct.
Q.
Was that a lot of records?
A.
It was a very large amount of records, yes.
Q.
Did you and the FBI do something to ease or facilitate
your review of those voluminous records?
A.
We did, yes.
Q.
What did you do?
A.
We converted the files to Microsoft Excel to be better
able to analyze what went in and out of the account.
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Q.
So were you able to see using those Excels what went into
and out of the accounts?
A.
We were, yes.
Q.
When you put it into Excel, are you able to search more
easily?
A.
Yes, we were.
Q.
I'm publishing for you what is in evidence as Government
Exhibit 306. Do you see Government 306 on your screen?
A.
I do.
Q.
I'll make it a little bigger so it's easier to read.
What's Government Exhibit 306?
A.
This is a USAA checking account belonging to Tracy and
Carolyn Wade.
Q.
What's the account number? Just give us the last four
digits.
A.
7309.
Q.
Okay. And is there a particular period of the statement
that we're looking at here?
A.
Yes. This one begins on December 6, 2018, and runs
through January 7, 2019.
Q.
Was that the first statement period that you received for
this account?
A.
It was.
Q.
I'll represent to you that this statement is over
200 pages. Does that sound right?
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A.
Yes, it does.
Q.
We're going to go now to the last page. Actually, what
we're going to do is go to 237. Do you see page 237 on your
screen?
A.
I do.
Q.
And what period is the statement for that we're looking at
on page 237?
A.
October 7, 2022, through November 4, 2022.
Q.
So does this capture all the entire period of the
statements that you received for this account?
A.
It does, yes.
Q.
And that's from approximately December of 2018 through
November of 2022?
A.
That's correct.
Q.
So about four years?
A.
Yes.
MR. WILCOX: Can you repeat that? I'm sorry.
MR. SNIDER: She said it's about four years of bank
statements.
MR. WILCOX: December '18 until?
MR. SNIDER: November of 2022.
BY MR. SNIDER:
Q.
In those four years of bank statements, did you see any
evidence of deposits or inflows in the amount of $112,430 for
a business named Tracy Wade?
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A.
No, I did not.
Q.
Did you see in these four years of bank statements any
inflows or deposits totaling $113,560 for a business named
Carolyn Wade?
A.
No, I did not.
THE COURT: And, Counsel, all of the exhibits
referenced are those that have been received in evidence;
correct?
MR. SNIDER: Yes, Your Honor.
THE COURT: All right. So let me just explain,
ladies and gentlemen. There is a rule of evidence that allows
summary witnesses to testify when there are voluminous
documents -- hundreds, thousands, in some cases millions. The
documents have been received by me in evidence, and we have an
exhibit list that you will have during your deliberations.
Summary witnesses are allowed to sort of summarize these
voluminous documents to make it easier for you to understand.
So as I mentioned, many documents have been received in
evidence.
Counsel, you can refer to those numbers generally, if
you like. But this process of having a summary witness is to
make it easier for you to understand all of these voluminous
documents. You can probably spend months if you wanted to
look at each one of the documents. So this process makes it
much simpler and, of course, it's up to the lawyers to explain
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what it is they are presenting.
Yes, sir.
MR. SNIDER: Thank you, Your Honor.
BY MR. SNIDER:
Q.
I'm publishing for you, Agent DiPietrantonio, what is in
evidence as Government Exhibit 306.1.
Do you see Government Exhibit 306.1 on your screen?
A.
I do.
Q.
Is this an account statement for a particular period?
A.
It is.
Q.
And is this the statement that came from the collection of
records that we just looked at in Government Exhibit 306?
A.
It is, yes.
Q.
What is the statement period for the statement that is in
306.1?
A.
May 7, 2021, through June 7, 2021.
Q.
And can you tell from looking at this account statement
what the beginning balance was at the start of the period that
you just said?
A.
Yes.
Q.
What was the beginning balance?
A.
$50.20.
Q.
I'm now going to move to page 3 of Government
Exhibit 306.1. Do you see page 3 on your screen?
A.
I do.
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Q.
And I'm going to enlarge certain transactions that are on
this page. Do you see the transactions that I've enlarged?
A.
Yes.
Q.
Do you see a transaction on June 3?
A.
I do.
Q.
What is the first transaction on June 3 that you see?
A.
An ACH deposit from Harvest Small Business PPP L2.
Q.
Okay. Do you know what that is?
A.
That's the proceeds of the PPP loan for Tracy Wade.
Q.
And how much was received into this account?
A.
$20,833.
Q.
Can you tell from looking at this statement what the
balance was in the account prior to the receipt of the $20,833
from the PPP loan?
A.
Yes.
Q.
What was the balance?
A.
$587.82.
Q.
Now, I have enlarged for you some additional transactions
from June 3rd, 2021. Do you see that?
A.
Yes.
Q.
What is the next transaction that you see from June 3?
A.
A USAA funds transfer debit to Carolyn Wade's savings
account of $100.
Q.
Okay. And what was the balance, then, after that debit of
$100 to Carolyn Wade?
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A.
$21,320.82.
Q.
What is the next transaction that you see on June 3, 2021,
in this statement?
A.
A Zelle transfer to Haydee Granados for $1,000.
Q.
Without asking you to do math because I know you don't
have a calculator with you, are you able to say,
approximately, by looking at this statement how much of the
Zelle payment of the thousand dollars was from PPP proceeds?
A.
More than half.
Q.
To your knowledge, can PPP proceeds be used to pay for
third-party assistance with a PPP loan?
MR. WILCOX: Objection. Foundation.
THE COURT: Sustained.
BY MR. SNIDER:
Q.
We're going to move on.
I'm publishing for you Government Exhibit 303 in
evidence. Do you see Government 303 in evidence?
A.
I do.
Q.
And what are we looking at here?
A.
This is a USAA account statement for a checking account
belonging to Carolyn Wade and Tracy Wade for the account
number ending in 3926.
Q.
Is that a different account than the one that we just
looked at in Government Exhibit 306?
A.
It is.
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Q.
What is the statement period that you see on page 1?
A.
December 27 of 2018 through January 29 of 2019.
Q.
This was a multi-hundred-page record?
A.
Yes, it was.
Q.
So all the statements you received for this account were
in one record?
A.
That's correct.
Q.
I'm going to go to page 467 of Government Exhibit 303.
Do you see page 467?
A.
I do.
Q.
Is this for the same account that we looked at on page 1?
A.
It is.
Q.
And what is the statement period that you see here?
A.
October 25, 2022, through November 23, 2022.
Q.
So from page 1 to page 467, does that represent the period
of account statements that you received for this account
ending in 3926?
A.
It does, yes.
Q.
And that is approximately how many years?
A.
Approximately four years.
Q.
With respect to this account ending in 3926 and the four
years of bank statements that you got for that account, did
you see any evidence in this account of deposits or inflows to
a business for Carolyn Wade in the amount of $113,560?
A.
No, I did not.
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Q.
Did you see in these four years of bank statements any
deposits or inflows for a business in the name of Tracy Wade
in the amount of $112,430?
A.
No, I did not.
Q.
I'm publishing for you Government Exhibit 303.1. Do you
see 303.1 on the screen?
A.
I do.
Q.
Is this one of the statements for the account we just
looked at in Government 303?
A.
It is.
Q.
And what is the period of this statement?
A.
May 27, 2021, through June 28, 2021.
Q.
And can you tell from this first page where it says
activity summary what the beginning balance of this account
was for that period?
A.
Yes.
Q.
What is it?
A.
$49.54.
Q.
We're going to go to page 3 of Government Exhibit 303.1
and I'm going to enlarge for you the first transaction from
June 7, 2021. Do you see that transaction on your screen?
A.
I do.
Q.
What is this transaction from June 7, 2021?
A.
That is the proceeds of the PPP loan belonging to Carolyn
Wade being deposited into her account.
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Q.
And how much was the deposit?
A.
$20,833.
Q.
Can you tell from looking at the immediate preceding
transaction what the balance was in this account before
receipt of the $20,833?
A.
Yes.
Q.
What was the balance?
A.
1,200 -- I'm sorry. $127.79.
Q.
Is it a little difficult to read, this PDF?
A.
A little bit, yes.
Q.
If I just enlarge that, are you able to see, then, where
the period is?
A.
Yes.
Q.
So you said it was $127.79?
A.
That's correct.
Q.
After the receipt of the PPP loan on June 7 for $20,833,
do you see some additional transactions on June 7?
A.
I do.
Q.
What type of transaction is that?
A.
A debit.
Q.
Do you see five debits?
A.
Yes, I do.
Q.
We're now going to move to page 4. Do you see the top two
transactions on page 4 from June 7th?
A.
I do.
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Q.
Can you look at the second one?
A.
Yes.
Q.
What is the second transaction on June 7th on page 4 of
Government 303.1?
A.
It's a Zelle transfer to Haydee Granados for $1,000.
Q.
Can you tell from looking at this what the balance was in
this account before the transfer of a thousand dollars via
Zelle to Haydee Granados?
A.
Yes.
Q.
Okay. What was that balance?
A.
$20,878.81.
Q.
And you testified a moment ago that the PPP loan was
$20,833?
A.
Yes.
Q.
Can you give us an approximate amount of how much of the
$1,000 Zelle included PPP loan money?
A.
Approximately $955.
Q.
Do you know what a Zelle payment is?
A.
Yes.
Q.
What is it?
A.
It's a transfer between two different bank accounts.
Q.
Is it electronic?
A.
Yes, it is.
Q.
And, to your knowledge, do you have to be online to
initiate a Zelle?
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A.
You do, yes.
Q.
Did USAA bank, the bank whose records we're looking at
now -- did they keep track of logins to its website or online
platforms?
A.
They did.
Q.
Did you receive in response to your subpoena any records
from USAA bank that reflected online logins to a particular
account?
A.
We did, yes.
Q.
And in that record with the logins, did USAA bank keep
track of IP addresses that were used to perform those logins?
A.
They did, yes.
Q.
Publishing for you Government Exhibit 300 in evidence. Do
you see 300 on your screen?
A.
I do.
Q.
What is this?
A.
It's a member authentication history for the USAA bank
account ending in 6578.
Q.
Okay. Do you see where it says member number?
A.
Yes.
Q.
What are the last four digits of that?
A.
6578.
Q.
Do you know who that member is?
A.
Carolyn Wade.
Q.
And what is the date range of the member authentication
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history in this record?
A.
January 1, 2019, through October 26, 2022.
Q.
Okay. And did you review this record?
A.
I did, yes.
Q.
Did you look at the IP addresses?
A.
I did.
Q.
And did you also look at IP addresses from logins to the
Womply portal that we talked about earlier in this case?
A.
I did, yes.
Q.
Did you do any kind of comparison between the logins with
respect to the IP addresses that were in this document and the
logins to Womply?
A.
I did, yes.
Q.
And what, if anything, did you see when you compared
logins to Womply with some of the logins here?
A.
There were many similarities between the two of them.
Q.
Similarities between what?
A.
Between the IP addresses that were used to log on to the
Womply account and to log into Carolyn Wade's USAA bank
account.
Q.
Have you summarized those similarities in another aid?
A.
Yes, I have.
Q.
Okay. We'll take a look at that in a moment.
When I say aid, I mean a demonstrative to aid the
jury's understanding of these records, as the Court previously
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explained?
A.
Yes.
Q.
Okay. Now, if in its response to your subpoenas, did USAA
bank also provide images of checks that were written for the
two accounts that we have been looking at?
A.
They did, yes.
Q.
Are you familiar with those checks?
A.
I am.
Q.
Okay. We're going to start with Government Exhibit 304.
Do you see 304 on your screen?
A.
I do.
Q.
I'm going to enlarge -- is it a check image?
A.
It is.
Q.
I'm going to enlarge it. Tell the jury what this check
is.
A.
This is a check written by Carolyn Wade to Carolyn Wade on
June 8, 2021, with a memo listed as salary.
Q.
And I'm sorry, how much was the check for?
A.
$500.
Q.
And can you see an endorsement on the check?
A.
I do.
Q.
Who endorsed it?
A.
Carolyn Wade.
Q.
I'm going to move to page 2. What is the check that's on
page 2?
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A.
This is a check written by Carolyn Wade to Carolyn Wade
for $2,000 on June 16, 2021, with a memo of salary.
Q.
Is it endorsed?
A.
It is.
Q.
Who endorsed it?
A.
By Carolyn Wade.
Q.
I'm now on page 3 of Government Exhibit 304. What is this
check?
A.
This is a check written by Carolyn Wade to Carolyn Wade
for $1,000 on June 11, 2021, with a memo of salary.
Q.
Is it endorsed?
A.
It is.
Q.
Who endorsed it?
A.
Carolyn Wade.
Q.
We're now on page 4. What is the check image on page 4?
A.
This is a check written by Carolyn Wade to Tracy Wade for
$1,000 on June 10, 2021, with a memo of salary.
Q.
Is it endorsed?
A.
It is.
Q.
Who's the endorsement?
A.
The Wade Funeral Home.
Q.
We're on page 5 of Government Exhibit 304. What is this?
A.
This is a check written by Carolyn Wade to Tracy Wade for
$1,000 on June 17, 2021, with a memo of salary.
Q.
Is it endorsed?
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A.
It is.
Q.
Who's the endorser?
A.
The Wade Funeral Home.
Q.
We're now on page 6 of Government 304. I'm enlarging the
check images. What do you see?
A.
This is a check written by Carolyn Wade to Carolyn Wade
for $2,000 on June 25, 2021, with a memo of salary.
Q.
Is it endorsed?
A.
It is.
Q.
Who endorsed it?
A.
Carolyn Wade.
Q.
We're now on page 7 of Government Exhibit 304. What is
this check?
A.
This is a check written by Carolyn Wade to Carolyn Wade
for $2,000 on July 2, 2021, with the memo of salary.
Q.
And is this check endorsed?
A.
It is.
Q.
By whom?
A.
Carolyn Wade.
Q.
We're now on page 8 of Government 304. What is this
check?
A.
This is a check written by Carolyn Wade to Tracy Wade for
$1,000 on June 24, 2021, with the memo of salary.
Q.
We're now on page 9 of Government 304. What is this
check?
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A.
This is a check written by Carolyn Wade to Tracy Wade for
$1,000 on July 1, 2021, with the memo of salary.
Q.
And we're on page 4 of Government Exhibit 304. What check
image do you see here?
A.
This is a check written by Carolyn Wade to Carolyn Wade
for $2,400 written on July 15, 2021, with the memo of salary.
Q.
Is it endorsed?
A.
It is.
Q.
Who endorsed it?
A.
Carolyn Wade.
Q.
This is a ten-page exhibit. Did we just go through 10
checks?
A.
I believe we did, yes.
Q.
When the bank, USAA bank, produced records pursuant to the
subpoena, were there other check images besides the ten that
we just looked at?
A.
Yes, there were.
Q.
Did you see any other checks like this with a memo of
salary written by Carolyn Wade either to herself or to her
husband other than the ten that we just looked at?
A.
No, I did not.
Q.
Did you see checks like this prior to the receipt of the
PPP loan proceeds for Carolyn Wade on June 7, 2021?
A.
No, I did not.
Q.
Did you see any checks like this after the last check that
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we looked at on page 10, which is dated June 15th, 2021?
A.
I think the date is actually July 15, 2021.
Q.
It is. Sorry.
A.
No, I did not.
Q.
So that was the last one you saw?
A.
Yes.
THE COURT: All right. Counsel, I'm going to stop
you there. It is 12:30. We're going to break for our lunch
at this time. We're going to resume at 1:35 PM.
And just for your information, ladies and gentlemen,
today's session is going to end at 3:00 PM. I know you're not
happy about leaving early, but 3:00 PM. I have a 3:00 PM and
a 4:00 PM hearing. The hurricane schedule has caused havoc,
so we're going to break an hour early. And I'm pleased to
tell you that despite losing the two days, we're pretty much
on schedule as far as our prediction. Maybe one day over, I'm
not sure, but I'll keep you advised. Thank you. Enjoy lunch.
(Jury exited at 12:31 PM.)
THE COURT: Any additional issues?
MR. SNIDER: The Government is going to use at some
point during the continued direct a demonstrative aid very
similar --
THE COURT: Just make sure --
MR. SNIDER: They have no objection.
THE COURT: You've reviewed it with your opposing
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counsel?
MR. WILCOX: No objection.
THE COURT: Thank you. Enjoy lunch.
(Lunch recess from 12:32 PM to 1:41 PM.)
THE COURT: Counsel, you will recall that we had one
juror who told us about a doctor's appointment on Thursday
morning in Kendall, and we've just been advised that she
thinks that she may be able to have her appointment earlier
and be here by 10:30, which means we would have to start at
10:30, but I think I'm going to have her come in and confirm
because I don't want to have people here at 10:30 and she's
here at 11:00. So let's have her come in the courtroom,
Number 9, Ms. Gomez.
(Juror Number 9 entered.)
THE COURT: Have a seat, Ms. Gomez. Thank you for
reminding us you have your doctor's appointment tomorrow
morning.
A JUROR: I do.
THE COURT: And so we just want to verify what time
you think you can be here because that's the time I'm going to
tell the jurors to be here.
A JUROR: 10:30 at the latest, but if it causes the
case to go longer, I'm okay with canceling it. It's okay.
THE COURT: In the scheme of things, I don't think an
hour is going to make a difference.
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A JUROR: Okay.
THE COURT: So I will simply tell the jurors we will
start tomorrow morning at 10:30 AM. And don't get a speeding
ticket if you get here at 10:35 or -40, what have you.
A JUROR: Thank you, Your Honor.
THE COURT: Okay. Thank you.
(Juror Number 9 exited.)
THE COURT: We can have the jurors come in.
MR. SNIDER: Your Honor, the Government's going to
move into evidence, I believe without objection,
Government 1000.1.
THE COURT: One moment. I think that's one I have to
add -- 1000- --
MR. SNIDER: .1.
THE COURT: All right.
MR. SNIDER: This is the demonstrative aid that we're
going to go through with the agent. There's just two
versions. I'm going go through right now 1000, and 1000.1 I'm
going to ask to be received into evidence. The only
difference is two slides that we have taken out of the one
that's going to go back to the jury.
THE COURT: All right. I'm not sure I followed you.
Are you offering the demonstrative exhibit as a
demonstrative exhibit or as an exhibit? If it's a
demonstrative exhibit, it doesn't go into the jury room. So
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how is it being offered?
MR. SNIDER: As an exhibit, Number 1000.1.
THE COURT: All right. Any objection?
MR. WILCOX: One moment, Your Honor.
THE COURT: Yes, sir.
Now, just so we're clear, a demonstrative exhibit can
be shown to the jury during the jury process, and it can be
used during the closing arguments. The only issue is is it
being received as a demonstrative exhibit, which demonstrates,
or is it being received as an exhibit?
MR. WILCOX: Yes, Your Honor. And we'd like to --
THE COURT: Yes what?
MR. WILCOX: The yes will just say that I understood
what you were asking.
Now, Your Honor, what we would like to do is -- we
don't have any objection to it being used as a demonstrative
exhibit, but we want to reserve -- we haven't had a chance to
look at it all before we object to it being admitted as an
exhibit. But for right now, we're objecting to it being
admitted as an exhibit, and we may withdraw that objection
after we've had a chance to review the exhibit after hearing
testimony. Is that all right?
THE COURT: I mean, I hear you, but it seems if you
have an objection to it, why is it going to be used as a
demonstrative exhibit? In other words, why would you not know
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now if you -- you either have an objection or you don't;
right?
MR. WILCOX: Your Honor, we don't know until after
she testifies and after we've had a chance to look at this
exhibit whether or not we're going to --
THE COURT: You haven't seen it? This is the
demonstrative exhibit; right? Is it a chart or what is it? A
chart or paper or what?
MR. SNIDER: It is just copies of the exhibits that
are in a table -- or in PowerPoint. And I gave a copy to
defense, I believe, two days ago. But I mean, if they need
more time to review it --
THE COURT: I'll accept it as a demonstrative exhibit
now.
MR. SNIDER: That's fine. And then afterwards we'll
see if they have an objection.
THE COURT: Very well. Bring the jury in, please.
(Jury entered at 1:47 PM.)
THE COURT: You may continue.
MR. SNIDER: Your Honor.
BY MR. SNIDER:
Q.
Good afternoon, Agent DiPietrantonio.
A.
Good afternoon.
Q.
Prior to the lunch break we were looking at some images of
checks that came from the USAA bank account that received the
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proceeds of the PPP loan that went to Carolyn Wade; correct?
A.
That's correct.
Q.
I'm going to look at some additional checks, and I'm going
to publish for you what's in evidence as Government Exhibit
307. And we're going to start on page 2. Do you see a check
image on page 2 of Government Exhibit 307?
A.
I do.
Q.
I'm going to enlarge it. What is this check that we're
looking at?
A.
This is a check from Tracy Wade to the Wade Funeral Home
in the amount of $1,920 written on June 4th, 2021, with the
memo payroll week.
Q.
And the account that this is being written from, if you
can tell from here, is this the same account or a different
account than the ones we were looking at with respect to the
Carolyn Wade checks?
A.
I believe this is a different account -- still a USAA bank
but a different account.
Q.
We're now on page 3 of Government 307, and I'm enlarging
the check image. What do you see here?
A.
This is a check written by Tracy Wade to the Wade Funeral
Home in the amount of $3,709 on June 5, 2021, with the memo
that looks like "the reimbursement."
Q.
Okay. And does it appear to be endorsed?
A.
Yes.
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Q.
Can you tell who appears to have endorsed it?
A.
Tracy Wade.
Q.
It was an endorsement going back to page 2. Do you see
the endorsement on the check that was on page 2 of
Government 307?
A.
Yes, I do.
Q.
Who is that endorser?
A.
The Wade Funeral Home.
Q.
Now, we're going to go to page 4 of Government 307 and I'm
going to enlarge the check image.
What is the check you see here?
A.
This is a check written by Tracy Wade to the Wade Funeral
Home on June 11, 2021, in the amount of $3,889.50 with the
memo payroll number 2/6/11.
Q.
Was it endorsed?
A.
Yes.
Q.
Who endorsed this one?
A.
Tracy Wade.
Q.
Now we're on page 5 of Government 307 and I'm enlarging
the check image on this page. What do you see here?
A.
This is a check written by Tracy Wade to the Wade Funeral
Home on June 11, 2021, in the amount of $3,889.50 with the
memo of payroll week of 6/11.
Q.
Page 5 is the last page of this exhibit, Government 307.
The checks that we just looked at on pages 2 through 5 of 307,
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were those checks written before or after Mr. Wade received
the proceeds of his PPP loan?
A.
Those checks were written after he received the proceeds
of his PPP loan.
Q.
Did you review all of the check images that you received
for this account ending in 7309 from the USAA bank?
A.
I did.
Q.
And with the exception of the checks that we just looked
at, did you see any other checks coming from this account
before receipt of the PPP loans, like this, with a memo
payroll or something to that effect?
A.
No, I did not.
Q.
And the last check that we are looking at is dated
June 11, 2021?
A.
That's correct.
Q.
Did you see any other checks after this one dated 6/11/21,
signed by Mr. Wade, payable to the Wade Funeral Home with the
memo of payroll or something to that effect?
A.
No, I did not.
Q.
Now, this account -- you can tell from the check -- is
drawn from an account ending in 7309; is that right?
A.
That's correct.
Q.
And this is drawn from a USAA bank account?
A.
That's correct.
Q.
And putting back up the checks we looked at a moment ago
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in Government Exhibit 304, this check is drawn from an account
ending in 3926?
A.
Yes, it is.
Q.
From USAA bank?
A.
That's correct.
Q.
I'm going to publish for you what is in evidence as
Defense 8. Do you see Defense 8 on your screen?
A.
I do.
Q.
I'm moving to the last page. Do you see a check on that
page?
A.
I do.
Q.
Can you tell from the check the institution that this
check was written from?
A.
SunTrust.
Q.
Is this check, the voided check, from the account that
received the proceeds of Tracy Wade's $20,833 loan?
A.
No, it is not.
Q.
And the checks that we were just looking at that Mr. Wade
wrote to his funeral home, were those drawn from this SunTrust
account?
A.
No, they were not.
Q.
May I have the ELMO for a moment, please.
I'm going to publish for you on the ELMO what is in
evidence as Defense Exhibit 7. Do you see Defense Exhibit 7
on your screen?
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A.
I do.
Q.
What is it?
A.
This is a SunTrust check for the account named 1 Step
A-Head hair salon.
Q.
Is this check from the account that received the proceeds
of the PPP loan that went to Carolyn Wade?
A.
No, it is not.
Q.
And the checks that we looked at in Government Exhibit 304
written by Carolyn Wade to herself or Tracy Wade with the memo
salary, were those checks drawn from this SunTrust account?
A.
No, they were not.
Q.
May I please have the HDMI back on the podium? Thank you.
Where was Carolyn Wade employed in 2019?
A.
She was employed with the Broward Sheriff's Office or BSO.
Q.
How about 2020?
A.
Also BSO.
Q.
How about 2021?
A.
Still BSO.
Q.
Where was Mr. Wade, Tracy Wade, employed in 2019?
A.
Also BSO.
Q.
And 2020?
A.
Also BSO.
Q.
And 2021?
A.
Still BSO.
Q.
Do you know what department within BSO they were assigned
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to?
A.
Detentions.
Q.
What does the detention department do, if you know?
A.
They handle the jail facilities and the courthouses.
Q.
The jails and the courthouses.
Do you know where Tracy Wade was assigned in 2021,
generally, within the department of detention?
A.
I believe the jails.
Q.
Okay. And with respect to Carolyn Wade, do you know where
she was assigned in 2021?
A.
I believe the courthouse.
Q.
I am going to publish two exhibits in evidence side by
side. The first is Government Exhibit 400, which you should
see on the left side of your screen and -- thank you --
Government Exhibit 401, which you should see on the right side
of your screen. Do you see those exhibits side by side?
A.
I do.
Q.
Do you recognize them?
A.
I do.
Q.
And what are these?
A.
These are returns from the Florida Department of Revenue
that I received.
Q.
Did you ask for information from the Florida Department of
Revenue?
A.
I did.
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Q.
What were you asking for or what did you ask for?
A.
Information related to businesses owned by Tracy Wade or
Carolyn Wade or businesses where Carolyn Wade or Tracy Wade
were a principal of.
Q.
Was there something that you were looking for in that
request --
A.
Yes.
Q.
-- information you were trying to gather?
A.
Yes, there was.
Q.
What were you looking for?
A.
I was looking to identify whether or not Carolyn Wade and
Tracy Wade pay into the Florida Reemployment Assistance Tax.
Q.
What is the Florida Reemployment Assistant Tax?
A.
It's the pot of money that employers pay into should an
employee have to go under unemployment.
Q.
So it appears on the left side is a letter dated March 28,
2024; is that right?
A.
That's correct.
Q.
And it's addressed to you?
A.
Yes, it is.
Q.
And there's three companies there?
A.
Yes.
Q.
What's the first one?
A.
Wade Funeral Home South LLC.
Q.
Why did you ask for information from that company?
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A.
Because Carolyn Wade was a principal of that company.
Q.
And what's the next company you asked about?
A.
Just Us Two Foundation Incorporated.
Q.
Why did you ask about information for that one?
A.
Again, because Carolyn Wade was a principal to that
company.
Q.
And the last request was for who?
A.
Carolyn Wade.
Q.
And what did you provide in that request for Carolyn Wade?
A.
Her social security number.
Q.
With respect to the first company you asked about, Wade
Funeral Home South LLC, did the Florida Department of Revenue
have any records?
A.
No, they did not.
Q.
With respect to the second company you asked about, Just
Us 2 Foundation Inc., what was the response from the Florida
Department of Revenue?
A.
They were unable to locate Reemployment Assistance Tax
reports.
Q.
And with respect to Carolyn Wade, did they provide
information?
A.
They did.
Q.
Was that information on the second page of this document?
A.
It is.
Q.
What did the Florida Department of Revenue report to you
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when you requested information relating to Carolyn Wade?
A.
Wages and earnings statements related to Carolyn Wade and
her employment with the Broward Sheriff's Office.
Q.
Any other records?
A.
No.
Q.
Now, we're on the right side looking at Government Exhibit
401 and there's two companies listed there. What are those
two companies?
A.
Tracy Wade, and Wade Funeral Home LLC.
Q.
And to assist the Florida Department of Revenue in their
search, what did you provide for Tracy Wade?
A.
His social security number.
Q.
And what did you provide to the Florida Department of
Revenue to assist their search for Wade Funeral Home?
A.
The EIN.
Q.
Did the Florida Department of Revenue find any
Reemployment Assistance Tax reports for the Wade Funeral
Home LLC?
A.
No, they did not.
Q.
Did they find any information for Tracy Wade?
A.
They did.
Q.
Is that information on page 2 of this document?
A.
It is.
Q.
What was the extent of the information that the Florida
Department of Revenue had when it looked up Tracy Wade?
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A.
Wages and earnings for Tracy Wade as it relates to his
employment with the Broward Sheriff's Office.
Q.
And no other filings came back?
A.
That's correct.
Q.
I want to look at two other exhibits right now side by
side. The first one is Government Exhibit 159, which you
should see on the left side of your screen. And the other is
Government Exhibit 160, which you should see on the right side
of your screen. Do you have that?
A.
Yes.
Q.
Okay. What is Government Exhibit 159?
A.
It's the PPP loan application for Tracy Wade.
Q.
Okay. And what is on the right side in 160?
A.
The PPP loan forgiveness application for Tracy Wade.
Q.
And is there a section in the PPP application in
Government 159 that asks for the number of employees?
A.
There is, yes.
Q.
What is listed there?
A.
One.
Q.
Is there a section in Government 160, which is the
forgiveness application, that asks for the employees at the
time of the loan application?
A.
There is.
Q.
And what is represented there?
A.
Ten.
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Q.
Is there a section in Government 160, the PPP forgiveness
application, that asks for the employees at the time of
forgiveness?
A.
Yes.
Q.
And what is represented there?
A.
Also ten.
Q.
I'm publishing 117 on the left-hand side of your screen
and publishing 118, both in evidence, on the right side of
your screen. Do you see that?
A.
I do.
Q.
What is Government 117?
A.
The PPP loan application for Carolyn Wade.
Q.
Is there a section asking for the number of employees in
that application?
A.
There is.
Q.
What is represented?
A.
One.
Q.
And in Government 118, the forgiveness application, is
there a section that asks for the employees at the time of the
application?
A.
Yes.
Q.
What is listed?
A.
Three.
Q.
Is there a section that asks for the number of employees
at the time of forgiveness?
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A.
Yes.
Q.
What is represented here?
A.
Three.
Q.
Publishing on the left side of your screen Government
Exhibit 700 in evidence and, on the right side, Government
Exhibit 701. Do you see those?
A.
I do.
Q.
What are these records?
A.
This is Google subscriber information for two different
Gmail accounts.
Q.
Okay. Let's start with the one on the left side,
Government 700. This is a Google account for who?
A.
For Carolyn Wade.
Q.
And for the record, what are the last four digits of the
Google account ID?
A.
6506.
Q.
The name on the account?
A.
Carolyn Wade.
Q.
What is the email address for this Google account of
Carolyn Wade?
A.
Ckidd1226@gmail.com.
Q.
Do you see a section that says account recovery?
A.
I do.
Q.
Do you know what that is?
A.
Yes.
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Q.
What is it?
A.
That's any time a user loses or misplaces their password
where Google would send an alternate password or a temporary
password for them to create a new one.
Q.
Is there a phone number listed for one of those places
where the temporary password could be sent?
A.
Yes.
Q.
And do you know whose phone number that is?
A.
Yes.
Q.
Whose?
A.
Carolyn Wade's.
Q.
What is the last four digits ending in?
A.
6800.
Q.
On the right side of your screen is Government's 701. Who
is this a Google account for?
A.
Tracy Wade.
Q.
What are the last four digits of the Google ID?
A.
9890.
Q.
And what is the email address associated with this Google
account?
A.
Tracyw764@gmail.com.
Q.
Is there an account recovery information provided on this
record?
A.
There is, yes.
Q.
Is there a phone number?
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A.
Yes.
Q.
Do you know whose phone number that is?
A.
Yes.
Q.
Whose?
A.
Tracy Wade's.
Q.
What are the last four numbers of that phone number?
A.
1512.
Q.
Now, in this case, did you receive by subpoena records
from DocuSign?
A.
I did.
Q.
Did some of those DocuSign records come from Womply?
A.
Some of them did, yes.
Q.
Did you also obtain records directly from DocuSign?
A.
I did.
Q.
Did some of those overlap?
A.
They did, yes.
Q.
But did you also receive from DocuSign additional records
from DocuSign that you didn't have from Womply?
A.
Yes, I did.
Q.
And did those additional records -- well, let's just look
at them because they're in evidence.
Publishing, on the left side of your screen,
Government Exhibit 116, and I'm publishing, on the right side
of your screen, Government Exhibit 116.1.
Do you see that?
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A.
Yes.
Q.
Okay. So, just quickly, what is Government Exhibit 116?
A.
The PPP loan application for Carolyn Wade.
Q.
You said, "the." Is it the or one of them?
A.
One of them.
Q.
We're going to go to page 9 of Government 116. Are you
with me there?
A.
Yes.
Q.
What is on page 9?
A.
This is the DocuSign, the certificate of completion for
that application.
Q.
Okay. And there's an envelope ID?
A.
There is.
Q.
The last four characters?
A.
BF27.
Q.
What is the document on the right side of your screen,
116.1?
A.
The document on the right is the envelope history for that
same envelope on the left side of the screen ending in BF27.
Q.
Does the envelope history report in 116.1 give you
additional information with respect to the certificate of
completion?
A.
It does.
Q.
So looking at 116.1, can you tell when this application --
when this signing event -- let me ask you this.
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Can you tell from looking at this when the envelope
was opened?
A.
Yes.
Q.
When was that?
A.
May 18, 2021, at 2:53 PM.
Q.
Okay. And that time, is that universal time coordinated?
A.
It is, yes.
Q.
And what is the difference in terms of the time zone
between eastern, where we are here in Florida, and UTC, if you
know?
A.
During the month of May, four hours.
Q.
And UTC is ahead or behind where we are in Florida?
A.
It's behind.
Q.
I'm sorry?
A.
Behind.
Q.
Florida is behind?
A.
UTC is behind.
Q.
So can you tell from this when it was first viewed?
A.
It was viewed May 18, 2021, at 2:54 PM.
Q.
Okay. And when was it signed?
A.
May 18, 2021, at 2:56 PM.
Q.
Based on this record, does it appear that after this
application was signed it was viewed additional times?
A.
Yes.
Q.
How many times was it viewed --
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A.
In total?
Q.
-- after the signing?
A.
Four times after the signing.
Q.
And who was the user, according to this record, who viewed
it?
A.
Carolyn Wade.
Q.
When was the first time it was viewed after the signing?
A.
May 18, 2021, at 5:31 PM.
Q.
When was the second time it was viewed after the signing?
A.
May 18, 2021, at 5:31 PM.
Q.
When was the third time it was viewed after the signing?
A.
May 19, 2021, at 9:59 PM.
Q.
When was the fourth time it was viewed after the signing?
A.
May 20, 2021, at 9:58 PM -- I apologize -- AM.
Q.
Publishing Government 117, on the left side of your
screen, and Government Exhibit 117.1, on the right side of
your screen. Do you see that?
A.
Yes, I do.
Q.
What is 117?
A.
This is a second PPP loan application for Carolyn Wade.
Q.
Okay. And this one has a DocuSign envelope ID ending in
the last four characters what?
A.
6F00.
Q.
And on the right side of your screen, 117.1, what do you
see there?
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A.
The envelope history for that same DocuSign envelope
ending in 6F00.
Q.
When we go to page 20 of 117, is that the certificate of
completion?
A.
Yes, it is.
Q.
And does 117.1 provide additional information about this
signing event?
A.
It does.
Q.
When, looking at 117.1, was the envelope opened?
A.
May 28, 2021, at 9:14 PM.
Q.
And the user that opened it?
A.
Carolyn Wade.
Q.
When was it first viewed?
A.
May 28, 2021, at 9:15 PM.
Q.
And the user that viewed it?
A.
Carolyn Wade.
Q.
When was it signed?
A.
May 28, 2021, at 9:15 PM.
Q.
And who was the user that signed it?
A.
Carolyn Wade.
Q.
Was this PPP loan application, Government 117, viewed
after the signing by user Carolyn Wade?
A.
Yes, it was.
Q.
How many times?
A.
Three times.
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Q.
When was the first viewing after the signing?
A.
May 28 at 10:05 PM.
Q.
When was the second viewing after the signing?
A.
May 28, 2021, at 10:05 PM.
Q.
And when was the third viewing after the signing?
A.
May 28, 2021, also at 10:05 PM.
Q.
Looking at the signer events, do you see that on
Government 117?
A.
I do.
Q.
Do you see the email address to which this envelope was
sent?
A.
Yes.
Q.
Is that the same Google address that we just looked at in
Government Exhibit 700?
A.
It is.
Q.
What about the last entry on 117.1 -- what does that say?
A.
It says that Tracy Wade was delivered a printable copy of
the envelope ID ending in 6F00 on October 16, 2023, at
5:06 PM.
Q.
Go back to 116.1 for a second. This was the history for
116, which was a different PPP application; right?
A.
Mm-hmm.
Q.
What's the last entry that you see here?
A.
Again, Tracy Wade was delivered a printable copy of the
envelope ID ending in BF27 on October 16, 2023, at 5:05 PM.
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Q.
Publishing for you on the left side of your screen
Government Exhibit 157.1 and on the right side of your screen
Government 157.2. Are you with me?
A.
Yes.
Q.
Now, what is in 157.1?
A.
This is a certificate of completion for the first PPP loan
application for Tracy Wade.
Q.
Okay. And where was this one sent to?
A.
Tracyw764@gmail.com.
Q.
Is that the same email address that we saw in the
subscriber record for Tracy Wade in Government Exhibit 701?
A.
It is.
Q.
And what are we looking at in 157.2, on the right side of
your screen?
A.
This is the DocuSign history for the envelope ID ending in
D98B.
Q.
And that's this envelope that's on the left side in 157.1?
A.
That's correct.
Q.
And 157.2, does that have more than one page to it?
A.
It does.
Q.
Okay. I'm scrolling to the second page of 157.2. Does
this page show when this envelope was opened?
A.
It does.
Q.
Who was the user that opened it?
A.
Tracy Wade.
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Q.
When was that?
A.
May 18, 2021, at 2:30 PM.
Q.
When was it signed?
A.
May 18 at 2:31 PM.
Q.
Was it viewed before it was signed?
A.
It was.
Q.
What time was that?
A.
May 18, 2021, at 2:30 PM.
Q.
Now, after it was signed, what happened in the line I just
highlighted for you?
A.
Tracy Wade received a copy of the full envelope ID ending
in D98B.
Q.
When was that?
A.
May 18, 2021, at 2:31 PM.
Q.
What happened in the last row here that I've highlighted
on 157.2?
A.
Tracy Wade received another copy of the full envelope ID
ending in D98B on May 19, 2021, at 4:49 PM.
Q.
Now, did you also subpoena records from Verizon in this
case?
A.
I did.
Q.
And the records that you subpoenaed, did those include
call records?
A.
They did.
Q.
Did the call records indicate the cell phone that Tracy
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Wade had in April, May, June, July of 2021?
A.
They do.
Q.
Do the Verizon records indicate the cell phone that
Carolyn Wade had and was using in April, May, June, July of
2021?
A.
They do.
Q.
Are you familiar with those devices?
A.
Yes.
Q.
Publishing for you Government Exhibit 800 and going to
page 250 of that exhibit, on the left side of your screen. On
the right side of your screen, we're putting up Government
Exhibit 806 and going to page 3.
Are you familiar with these records?
A.
Yes, I am.
Q.
What are they?
A.
They're Verizon records for both Carolyn Wade and Tracy
Wade.
MR. WILCOX: I'm sorry. Can you tell me which
exhibit this is again?
MR. SNIDER: Sure. On the left side, we're looking
at 800, on page 250, and on the right side, we're looking at
Government 806 on page 3.
BY MR. SNIDER:
Q.
What is the period we're looking at for these records on
the left side?
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A.
April 16, 2021, through May 15, 2021.
Q.
Is that the same period that is in page 3 of
Government 806?
A.
Yes, it is.
Q.
What kind of cell phone did Carolyn Wade have during that
period?
A.
A Note20 Ultra 5G.
Q.
Do you see (954) 274-6800?
A.
Yes.
Q.
What is that?
A.
That is Carolyn Wade's phone number.
Q.
Is that the phone number that this device, Note20 Ultra
5G, was assigned to?
A.
Yes.
Q.
On the right side of your screen, what kind of phone did
Tracy Wade have during this period?
A.
A Galaxy S21 U 5G.
Q.
Do you see (786) 488-1512?
A.
Yes.
Q.
What's that?
A.
That's Tracy Wade's phone number.
Q.
Is that the phone number to which this Galaxy S21 U 5G was
assigned during this period?
A.
Yes.
Q.
Publishing for you, on the left side of your screen,
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Government Exhibit -- it's the same exhibit, 800. We're going
to go to page 266. Okay? And on the right side, 806, we're
going to go to page 72. Are you with me?
A.
Yes.
Q.
Okay. What period is this we're looking at?
A.
May 16, 2021, through June 15, 2021.
Q.
Is that for both pages that we're looking at?
A.
Yes, it is.
Q.
The cell phone that Carolyn Wade had in this period, May
through June of 2021, is it the same cell phone that we just
looked at?
A.
Yes, it is.
Q.
And with respect to Tracy Wade, the same cell phone?
A.
Yes.
Q.
In this period, May through June of 2021?
A.
Yes.
Q.
In Government 800, on the left side of your screen, we're
going to jump to page 283, and on the right side of your
screen, we're going to jump to page 131, and that's
Government 806. Are you with me?
A.
Yes.
Q.
What is the period we're looking at here?
A.
June 16, 2021, through July 15, 2021.
Q.
And is that for both pages that we're looking at in 800
and 806?
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A.
Yes.
Q.
Did Carolyn Wade have the same cell phone that we just
looked at?
A.
She did.
Q.
And what about Tracy Wade?
A.
Also the same cell phone.
Q.
Not with each other but --
A.
As the month prior.
Q.
Last, we're going to go to page 301 of Government
Exhibit 800 and page 204, Government Exhibit 806. Do you see
those side by side?
A.
I do.
Q.
What is the period that we're looking at for both
exhibits?
A.
June 16, 2021 --
Q.
Make it a little bigger so you can read it.
A.
-- through August 15, 2021.
Q.
Sorry. The first date?
A.
July 16th, 2021, through August 15th, 2021.
Q.
In that period, Carolyn Wade had what cell phone?
A.
A Note20 Ultra 5G.
Q.
The same phone that we looked at for the previous months?
A.
Yes, that's correct.
Q.
And Tracy Wade had what cell phone?
A.
A Galaxy S21 U 5G.
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Q.
The same phone that we looked at for the last couple of
months?
A.
Yes.
Q.
And the phone numbers respectively for Carolyn Wade and
Tracy Wade that were assigned those respective devices, did
that change?
A.
No, they did not.
Q.
Agent DiPietrantonio, all these records that you received
from these various subpoenas, were you able to extract that
information and put it into a form that would allow the jury
or aid the jury in its review of that evidence?
A.
Yes.
Q.
Did you extract information from records from Womply?
A.
I did.
Q.
Did you extract information from records from Persona?
A.
I did.
Q.
Did you extract information and records from the Small
Business Administration?
A.
I did.
Q.
Did you extract information from DocuSign?
A.
I did.
Q.
Did you extract information from Verizon?
A.
I did.
Q.
Did you extract information from AT&T?
A.
I did.
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Q.
Did you extract information from USAA bank?
A.
I did.
Q.
Okay. And you put all of that in a demonstrative aid?
A.
That with the addition of information from BSO, yes.
Q.
Okay. And BSO.
MR. SNIDER: Permission to publish the demonstrative
aid that's marked for identification as 1000.
THE COURT: You may publish.
BY MR. SNIDER:
Q.
Okay. We're now looking at slide one of the demonstrative
identified as 1000. Do you see that on the screen?
A.
I do.
Q.
Let's walk through this.
What are we looking at here on slide one?
A.
The first chart refers to the Womply records that maintain
the login attempts by Tracy Wade when he accessed his Womply
portal. If you look at the third column, I translated the
time from universal time coordinated to Eastern Daylight Time
just for ease of reading throughout the demonstrative. And if
you see in a couple columns over, the column heading IP
address, I've highlighted five different instances of logins
by Tracy Wade to his Womply portal via an IP address ending in
.166. If you look to the bottom of that page, we have the
record from AT&T that Philip Fanara spoke about -- showing
that that IP address ending in 166 was maintained by the Wade
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Funeral Home at that time on May 4, 2021.
Q.
And do you see where it says source?
A.
Yes.
Q.
Is that the government exhibit that you took this
information from?
A.
It is.
Q.
So the first source for this table is Government 163E?
A.
Yes.
Q.
And the source for the AT&T record is Government 601?
A.
Yes.
Q.
How many login attempts does the record show were made
from the IP address assigned to the Wade Funeral Home on
May 4, 2021?
A.
Five.
Q.
And were they successful?
A.
They were.
Q.
Moving to slide two of the demonstrative. What do you see
here on slide two?
A.
These are Womply transactions that Aman Thakral spoke
about as they relate to Tracy Wade's PPP application on May 4,
2021. If you look at the first two instances of transactions
in the top chart, both of those were conducted using an IP
address ending in .166. And if we look on the bottom of that
page at the AT&T record, we can see that that IP address
ending in 166 was maintained by the Wade Funeral Home, at this
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time, on May 4, 2021.
Q.
And what is the time range in Eastern Daylight Time of
these two transactions?
A.
12:37 PM through 12:41 PM.
Q.
Do you see where it says operation type?
A.
Yes.
Q.
Do you know what the zero indicates?
A.
The zero means that something was created within the
portal, the ones that refer to any modification or update to
that application, again within the portal for Tracy Wade.
Q.
So this shows one creation and one modification using the
IP address assigned to Wade Funeral Home on May 4, 2021?
A.
It does.
Q.
Moving to slide three, what do we see here on slide three?
A.
These are different Womply transactions that occurred on
Carolyn Wade's Womply portal on May 4, 2021, all of which were
done from an IP address ending in 166, as we know from the
AT&T record on the bottom of the page, was maintained by the
Wade Funeral Home at this time on May 4, 2021.
Q.
How many transactions were entered in Carolyn Wade's PPP
loan application from the Wade Funeral Home IP address on
May 4, 2021?
A.
Approximately ten.
Q.
You can count them.
A.
11.
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Q.
We're now moving to slide four. What is on slide four?
A.
These are Womply events that occurred on May 4 for Tracy
Wade's application. Womply events are any time a user
uploaded a document to their portal or linked a bank account.
In this case, we're looking at two file uploads for Tracy
Wade's PPP application that occurred on May 4, 2021, from an
IP address ending in .166. As we know, again, from the AT&T
record, .166 -- the IP address ending in .166 was maintained
by the Wade Funeral Home.
Q.
And you read the last three digits, but the entire IP
address is a match?
A.
Yes, it does.
Q.
Now we're on slide five. What happened on slide five on
May 4, 2021?
A.
These are Womply events that occurred for Carolyn Wade's
PPP loan application on May 4, 2021. We're looking at a file
upload of a bank document and a bank account that was linked
to her Womply portal, both done from an IP address ending in
.166, which as we know from the AT&T record below was
maintained by the Wade Funeral Home.
Q.
Moving to slide six, what is the information that you've
displayed from the Government Exhibits on slide six?
A.
These are Womply events that occurred on Tracy Wade's PPP
loan application via the Womply portal on May 5, 2021, two of
which were done from an IP address ending in .36. If you look
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at the user agent column, I've highlighted the device that was
used to make those -- or to conduct those events. We can see
here that it was an Android 11, Model Number SM-G998U. If you
Google that number, you can tell --
Q.
Let me ask you this: Do you know what model number is
SM-G998U?
A.
Yes.
Q.
What is it?
A.
It's a Galaxy S21 U 5G.
Q.
Okay. Keep going.
A.
So at this time, Tracy Wade was a Verizon customer, as we
can tell from the Verizon records that Dion Morrow spoke
about. And if you look to the right of the screen, I've
highlighted the same IP address that was used in the Womply
events ending in .36 where Verizon says this IP address was
maintained by Verizon and can only be used by Verizon
customers that are on their network at that time.
And if you look to the bottom left of the screen, we
have a record from Persona that Lindsey Bergh spoke about.
That's a snippet from the selfie verification check that Tracy
Wade conducted for his own application in which he used a
phone, Model Number SM-G998U, which is an Android 11 device,
on a Chrome mobile browser. Again, that device SM-G998U is a
Galaxy S21 U 5G phone, similar or the same as Tracy Wade
maintained at that time on May 5, 2021.
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Q.
Moving to slide seven, what do we see here?
A.
These are Womply transactions that occurred on Tracy
Wade's Womply portal in relation to his PPP application. So,
again, transactions are any kind of modifications or creations
within his account.
Here, we can see I've highlighted five different
occurrences where he modified or created something in his
application via an IP address ending in .36. If you look to
the bottom of that screen, that Verizon letter says that that
IP address was owned by Verizon at that time, which is the
same time that Tracy Wade was a Verizon customer.
Q.
And how many transactions occurred from that IP address on
May 5, 2021, ending in .36 that belonged to Verizon?
A.
Five.
Q.
Moving to slide eight, what information is on slide eight
of the demonstrative?
A.
Here, we have Womply login attempts that occurred on
May 5, 2021. So if you look at that first column, the
identifier column, that notes which device or which identifier
that short-lived code that Womply sent out so their users
could access their application was sent. In this case, it's a
phone number ending in 1512, which is the same phone number
that Tracy Wade maintained at this time, as you can see from
that box there in the middle of the screen.
If you look at the third login on that Womply table
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at the top of the screen, we can tell that that login was
conducted via an IP address ending in .36 from an Android 11
device, Model SM-G998U. That model number, SM-G998U,
signifies it was a Galaxy S21 U 5G phone, the same phone that
Tracy Wade had at this time. The IP address that was used to
conduct that last login on the chart is an IP address that was
maintained or owned by Verizon, again, at this time only
accessible via Verizon Wireless customers. If you look at the
chart on the bottom from Persona, again, we're just seeing
that the same device that made that login is the same device
that Tracy Wade used to conduct his selfie verification check.
Q.
The same device that he used to actually take the photos
of himself?
A.
That's correct.
Q.
Moving to slide nine, now we're on May 6, 2021. What do
we have on this slide?
A.
These are, again, different logins from Tracy Wade to his
Womply portal. There are four different logins, if you look
at the last four logins that occurred from that Womply chart.
And as we can see, those logins occurred via an IP address
ending in .36, also done from an Android 11 device, Model
Number SM-G998U, as we know from the Persona records. On the
bottom of the screen is the phone that Tracy Wade used to
conduct his selfie verification and take pictures of himself.
As we can see from the middle of the screen, that's
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the phone that Tracy Wade maintained at this time on the
Verizon Wireless network, which he was a customer of. And if
you look to the right, we can see the letter from Verizon
stating that they owned and maintained that IP address ending
in .36 where the last four logins on this chart occurred from.
Q.
And what was the time range of these four logins on May 6,
2021, using this IP address ending in 36 with the cell phone
model of Galaxy S21?
A.
3:29 PM through 3:48 PM.
Q.
And you converted that to eastern?
A.
I did.
Q.
Moving to slide ten, what happened here on May 6, 2021?
A.
Here, we can see that Tracy Wade received an email from
Womply saying that he applied for a loan recently and it's
time for him to conduct his identity verification check.
Q.
Now we're on slide 11, still on May 6, 2021. What is
displayed here on slide 11?
A.
These are Womply transactions that occurred on Tracy
Wade's PPP loan application portal. As we can see, all of the
transactions occurred from an IP address ending in .36. As we
know from looking at the Verizon letter, at the bottom of the
screen is an IP address that was maintained and owned by
Verizon at that time in which Tracy Wade was also a customer.
Q.
How many transactions occurred on May 6 from this IP
address ending in 36?
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A.
Six.
Q.
And do you see where it says "operation type"?
A.
I do.
Q.
Are those all number ones?
A.
They are.
Q.
Do those mean that they're modifications to his
application?
A.
That's correct.
Q.
We're now on slide 12 of the demonstrative. What happened
on May 6, 2021, at 3:35 PM?
A.
If you remember two slides back, Tracy Wade received an
email about four hours prior on the same day saying it was
time to take his selfie photos for his identity verification.
This slide is showing that, again, approximately four hours
later he made his first attempt at taking those selfies via
phone Android 11 on a Chrome mobile browser with Model Number
SM-G998U, which we know is a Galaxy S21 U 5G device, which
Tracy Wade maintained at this time.
Q.
And that's the same device that was being used to log in
and conduct the transactions that you just spoke about?
A.
That's correct.
Q.
I notice the time on the header is 3:35 PM EDT and then
the time from the Persona record is 7:35 PM. Can you just
explain the difference there?
A.
Sure.
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Persona maintained their records in UTC time. So all
the times that I have listed in my title slides are Eastern
Daylight Time, again, just for ease of following.
Q.
And that's the four-hour difference?
A.
That's correct.
Q.
Moving to slide 13. What happened here?
A.
This is the second attempt that Tracy Wade made at taking
selfie photos of himself in order to verify his identity via
Persona. This time was successful and the photos were
approved. These photographs, like the last ones, were also
taken on an Android 11 Chrome mobile browser via Model number
SM-G998U, which is a Galaxy S21 U 5G phone, which Tracy Wade
maintained at this time.
Q.
Now on slide 14.
A.
This is an email that Carolyn Wade received from Womply
letting her know that her Paycheck Protection Program
application was currently incomplete and she had to continue
it if she were to get the loan.
Q.
And when was this email sent to the email address
ckidd1226@gmail.com?
A.
May 13, 2021, at 6:23 AM.
Q.
Now we're on slide 15. What information is displayed here
on slide 15?
A.
These are Womply login attempts conducted by Carolyn Wade.
If you look in that first column, under identifier, you can
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see that half of them were done through her email and half of
the codes were sent to her phone number.
The first two IP addresses that I have highlighted
here end in 166, which as we know from Verizon was an IP
address maintained at the Wade Funeral Home. And the last
five IP addresses that I've highlighted ending in .184 were
owned and maintained by Verizon at a time where Carolyn Wade
was a Verizon customer.
Q.
So May 13, 2021, how many logins were done from the IP
address ending in 166 assigned to the Wade Funeral Home?
A.
Two.
Q.
And how many logins were done using an IP address ending
in 184 that was assigned to Verizon wireless?
A.
Five.
Q.
Moving now to slide 16 -- and we're still on May 13,
2021 -- what happened on this slide?
A.
So this is highlighting the same Womply login attempts
that we looked at on the last page; however, we're only
looking at the IP addresses ending in .18 or the logins that
occurred from IP address ending in .184.
If we look to the right of the screen, we can tell
again that the IP address ending in .184 was maintained by
Verizon at a time where Carolyn Wade was a Verizon customer.
If you look at the user agent, all the way to the right on the
Womply table on top of the screen, you can tell that these
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login attempts were conducted via an Android 11, Model Number
SM-N986U.
Q.
Do you know what kind of phone this is, the SM-N986U?
A.
Yes.
Q.
What is that kind of phone?
A.
It's a Note20 Ultra 5G.
Q.
Okay. Which is different than Tracy Wade's phone?
A.
That's correct.
Q.
What else can you tell from this slide?
A.
We can tell that there are logins via the 184 IP address
to Carolyn Wade's USAA account on the same day that there are
logins from that 184 IP address to her Womply portal. And if
you look at the very bottom right of that screen, we can see
that Carolyn Wade took her selfie verification photos through
Persona with a device that was an Android 11 on a Chrome
mobile browser, Model Number SM-N986U, which is that Note20
Ultra 5G phone that she maintained on the Verizon Wireless
network on May 13, 2021.
Q.
So these are the same five logins that we looked at as 515
but with a little more detail about the device that was used
to perform those logins?
A.
That's correct.
Q.
Now we're moving to slide 17. What do we have here?
A.
These are Womply transactions that occurred on Carolyn
Wade's Womply portal. So, again, these are going to be
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modifications or creations within her portal to her
application, all of which on this page were done via the IP
address ending in .166, which as we know from the AT&T record,
on the bottom of the screen, was maintained by the Wade
Funeral Home on this day, May 13, 2021.
Q.
Moving to slide 18, still on May 13, 2021, what is the
information we're looking at on slide 18?
A.
We're looking at different transactions that occurred
within Carolyn Wade's Womply portal from an IP address ending
in .18. That IP address, as we can tell --
Q.
Can you say the last three again?
A.
184. Sorry.
Q.
That's okay. Keep going.
A.
As we can tell from the bottom left of the screen on that
Verizon letter, that IP address ending in .184 was owned and
maintained by Verizon at this time of which Carolyn Wade was a
customer of. And then if we look to the right of the screen,
on the bottom, we see Carolyn Wade's USAA account had three
logins that same day via an IP address ending in .184 from an
Android app.
Q.
And how many transactions occurred on May 13, 2021, in
Carolyn Wade's PPP loan application from this IP address
ending in 184?
A.
I think it's 15 transactions.
Q.
You can count them.
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A.
Yeah, 15 transactions.
Q.
Okay. Moving to slide 19, what do we have here?
A.
This is the first attempt that Carolyn Wade made, which
was unsuccessful, at taking her selfie verification photos for
Persona. As you can see, the pictures were taken on May 13,
2021, from an Android device, Model Number SM-N986U, which we
know is the Note Ultra 5G phone, which Carolyn Wade had on the
Verizon Wireless network at this time.
She took these pictures via an IP address ending in
.184. Again, that's an IP address that was owned by Verizon,
at this time only accessible to by Verizon Wireless customers.
Q.
And is that the same IP address that we looked at in slide
18 that was doing those transactions ending in 184?
A.
Yes.
Q.
Now let's move to slide 20. What's the information
displayed here?
A.
This is Carolyn Wade's second and successful attempt at
taking her selfie photos in order to verify her identity
through Persona. She did so via an IP address ending in 184.
You can see that on the right-hand side of the screen in the
Persona record.
Those pictures were taken on an SM-N986U model phone,
which we know is a Note20 Ultra 5G per the Verizon record on
the bottom of the screen. And again, these pictures were
taken via an IP address ending in .184. If you look to the
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bottom left of the screen, that Verizon letter states that
that same IP address ending in .184 was owned and maintained
by Verizon at this time in which Carolyn Wade was a Verizon
Wireless customer.
Q.
And that's the same IP address that she used and the same
phone that she used with respect to her first attempt to take
selfies and identify her identity?
A.
That's correct.
Q.
Now we're on slide 21. What happened here on May 13,
2021?
A.
These are multiple events that occurred on Carolyn Wade's
Womply portal for her PPP loan application. Again, events are
anytime somebody uploads a document to their application or
links a bank account to their application.
Here, she did multiple of those, three of each. She
linked three bank accounts and uploaded three bank documents,
all from an IP address ending in .184, which as we know by the
Verizon letter on the bottom left of the screen was a Verizon
IP owned by Verizon at that time.
And then if you look in the user agent on the Womply
column, we can see that all of those events occurred via an
Android 11 SM-N986U, which we know is a Note20 Ultra 5G phone,
which is the same model number of the phone that was used to
take the selfie verification photos from Persona, as we can
see in the bottom right side of the screen.
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Q.
Moving down to slide 22, what happened here on slide 22?
A.
This is a DocuSign certificate of completion for Tracy
Wade on the left-hand side of the screen. This is for an
envelope ID ending in D98B. So this is his first time signing
a DocuSign for his PPP loan application. He signed this
application via an IP address ending in 190, which as we can
tell from the right side of the screen, that Verizon letter
states that they owned and maintained that IP address, and it
was only accessible to Verizon Wireless customers during this
time.
Q.
Okay. And in the header, have you converted the time in
which this was signed to Eastern Daylight from Pacific?
A.
Yes, I did.
Q.
We're now on slide 23. Is this a record that we looked at
a little bit earlier in your testimony?
A.
Yes.
Q.
Okay. Let's walk through it again.
A.
This is the envelope history ID for envelope ID D98B.
Again, it shows when Tracy Wade opened the application, viewed
his application, signed his application, and on multiple
occasions received copies of that full envelope ID, which
included the application, the certificate of completion for
his PPP loan application.
Q.
Slide 24, what occurred here on May 18, 2021, at 10:56 AM?
A.
Carolyn Wade signed her first DocuSign for her PPP loan
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application on May 18, 2021, via an IP address ending in .224,
which as we know from the right side of the screen, that
Verizon letter that we've been looking at, we can tell is a
Verizon IP, and the same day that she signs her PPP loan
application there's a login to her bank account -- to her USAA
bank account, also from an IP address ending in 224.
Q.
And on slide 25, what information is there with respect to
that signing event?
A.
This is the envelope history for the certificate of
completion that we just looked at on the previous slide ending
in BF27. We can see when Carolyn Wade opened -- opened the
application, viewed the application, signed the application,
and the four instances in which she viewed the application
after signing.
Q.
And the last event on that sheet shows?
A.
Shows that her husband, Tracy Wade, received a copy of
that full envelope ID, again, which includes the full
application and the certificate of completion.
Q.
Moving to slide 26, we're now on May 19, 2021, at 1:06 PM.
What are we looking at here?
A.
The left-hand side of the screen is the certificate of
completion for Tracy Wade's PPP loan application. This is now
the second certificate of completion.
Q.
And did he sign this using a Verizon Wireless IP address?
A.
He did. That IP address ended in 223, which, as we can
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tell from the right side of the screen, that Verizon letter
says that was an IP address owned and maintained by Verizon
Wireless at the time when Tracy Wade was a customer.
Q.
Moving to slide 27, is this the envelope history ID for
that signing event?
A.
It is.
Q.
Does that show that Tracy Wade opened and viewed and
signed his PPP loan application?
A.
It does.
Q.
Moving to slide 28, what do we have here?
A.
This is a Womply email that was sent to both Carolyn and
Tracy Wade on May 19, 2021, at different times to their
respective email. To summarize, the email says that there are
multiple updates that Womply has regarding their PPP
applications, the first being that they're still processing
all of these applications to the SBA; the second, that they
may notice some changes within their application status; and
the third is asking them to contact Congress to request
additional funding for PPP loans, as they ran out.
Q.
And what does it tell them or advise them in the last
sentence of paragraph 2?
A.
"We anticipate that all application statuses will be
updated at the next 48 hours. If we email you asking you to
take action on your application, please do so."
Q.
And both Carolyn and Tracy Wade separately received a copy
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of that email?
A.
They did.
Q.
We're now on slide 29. What is this email here?
A.
This is an email that was sent to both Carolyn and Tracy
Wade reminding them that their PPP loan applications were
incomplete.
Q.
What is it asking them, if anything, to do?
A.
To go in and continue their application if they want to
receive those funds.
Q.
We're now on slide 30, which is another Womply login
attempt. Tell us about this one.
A.
The top chart shows a login attempt by Carolyn Wade to her
Womply portal via an IP address ending in .130. If you look
at the bottom left-hand side of the screen and remember Alex
Rodriguez's testimony, he said that that IP address ending in
130 was maintained and owned by the Broward Sheriff's Office
and can only be accessed by those who have a Broward Sheriff's
account. And if you look to the right of the screen, the USAA
account belonging to Carolyn Wade, we see different logins
that occurred the same day in which her Womply portal was
logged on to, again, via the IP address ending in 130.
Q.
The date of the login of her Womply was May 19, 2021?
A.
Yeah.
Q.
At what time?
A.
8:06 AM.
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Q.
And in the USAA, are you showing that that same address
was used at different times?
A.
Yes, on different days.
Q.
Okay. Slide 31 now, we're up to May 19, 2021. What
happened here?
A.
Here, we can see that there were two logins to Tracy
Wade's Womply portal via an IP address ending in .84 and an IP
address ending in .82.
Q.
And the one ending in 84, what is that IP address? Where
is that assigned to?
A.
That's assigned to the Wade residence.
Q.
And the IP address ending in 82, who owns that one?
A.
Verizon Wireless.
Q.
And what phone did Tracy Wade use to do these logins?
A.
The Galaxy S21 U 5G.
Q.
And what can you tell about that with respect to the
Persona record you have on the bottom left?
A.
That was the same model number phone that was used to take
his selfie verification photos.
Q.
We're now on slide 32. This is an email. Who received
this, when, and what is this about?
A.
This is an email that was sent to Carolyn Wade from Womply
on May 19, 2021, letting her know the same things that we
looked at earlier; one, that they're still processing
applications; two, that they may see changes to the status in
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their application; and three, that they should request from
Congress additional funds be added to the PPP money.
Q.
Now, on slide 33, we're up to May 20, 2021. What happened
here?
A.
Here, we see two login attempts into Tracy Wade's Womply
portal, one from an IP address ending in .4, which is an IP
address owned by Verizon at a time where Tracy Wade was a
Verizon Wireless customer. We can see that both of those
Womply logins occurred via a device, Model Number SM-G998U,
which we know from Verizon is the Galaxy S21 U 5G phone, the
same phone that Tracy Wade had at this time and the same phone
that if you look to the left of the screen we can see was used
to take his Persona verification photos.
Q.
Moving to slide 34, still May 20, 2021, this is 4:57 PM.
What happened here?
A.
This was an attempt to log into Carolyn Wade's Womply
portal. The one-time code was sent to her cellular phone
ending in 6800. The login occurred from an IP address ending
in .84 via an Android 11, SM-N986U model phone, which we know
is the Note20 Ultra 5G, on the bottom left of the screen.
The IP address that was used to conduct that login,
ending in .84, is an IP address that was owned by AT&T, which
Carolyn Wade was a customer of. The service provided for that
IP address was at her residence. If we look at the Persona
record in the middle of the screen to the right, we can tell
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that that same device that was used to conduct that login was
the same device that Carolyn Wade took his selfie verification
photos for through Persona.
And if you look to the middle left of the screen, you
can see that on Carolyn Wade's USAA checking account there was
an Android app that logged into her account via an IP address
ending in .184, which, again, if you look at the bottom of the
right of the screen is an IP address that was assigned to her
house from AT&T.
Q.
Now we're on slide 35, May 22, 2021. Is this another
login attempt?
A.
Yes.
Q.
And what was the IP address that was used for this login
attempt?
A.
174.211.171.127.
Q.
And that's a Verizon Wireless IP address?
A.
It is.
Q.
And the model phone that was used for this login, is that
Carolyn Wade's cell phone model?
A.
It is.
Q.
Is it the same phone that she used to conduct her selfie
photographs for identity verification?
A.
It is.
Q.
And on May 22, 2021, were there additional logins to her
USAA account using that same IP address owned by Verizon?
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Lance W. Steinbeisser - Federal Certified Realtime Reporter
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A.
There was.
Q.
Now we're on slide 36, which is another email. Who are
the two people that received this email?
A.
Both Carolyn and Tracy Wade.
Q.
What is the nature of this email?
A.
This is an email from Womply, again, to Carolyn and Tracy
Wade letting them know they need to go in and DocuSign their
applications.
Q.
We're now on slide 37. We're up to May 25, 2021,
11:10 AM. What happened here?
A.
This was a login attempt to Tracy Wade's Womply portal
that occurred from an IP address ending in 194. As we can
tell from the Verizon letter, on the bottom right of the
screen, that IP address ending in 194 was owned and maintained
by Verizon at a time where Tracy Wade was a Verizon Wireless
customer. And the login was conducted via a mobile device
Model Number SM-G998U, which we know is the same device that
took the Persona verification photos for Tracy Wade.
THE COURT: All right, sir. I'm going to stop you
there. We are recessing for today.
And tomorrow, many of you will recall that one of the
jurors had a doctor's appointment in Kendall during voir dire.
So we're going to start tomorrow morning at 10:30 AM.
10:30 AM.
Remember not to discuss the case in any way. Have a
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good evening.
(Jury exited at 3:00 PM.)
THE COURT: You may step down.
Any additional matters?
MR. SNIDER: Not from the Government.
THE COURT: Do you know now how long you anticipate
your case is going to take from this point forward,
approximately?
MR. SNIDER: No more than an hour.
THE COURT: All right. So that means tomorrow, late
morning, hopefully, we will conclude the Government's case in
chief; correct?
MR. SNIDER: Yes, that's correct.
THE COURT: And then there are motions that I will
have to entertain, and then we should be ready for the defense
case in chief.
Earlier, Defense, you predicted about three hours for
your case, which means we should conclude all of the evidence
tomorrow.
If you give us your email addresses, we can send you
a draft of the instructions, so you will have those a little
later. Now, there's one instruction -- so, Government, you
proposed a deliberate ignorance instruction. Are you
persisting with that or do you want to wait to see what
happens with the defense case in chief?
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MR. SNIDER: We'll wait to see what happens with the
defense --
THE COURT: All right.
MR. SNIDER: -- case in chief.
Judge, with respect to the schedule and the
allocation of time -- maybe I missed this -- I'm not sure we
took into account the defense's cross-examination of the
agent. I have about no more than an hour left of my direct --
THE COURT: Good point.
Any idea?
MR. WILCOX: No more than an hour and a half.
THE COURT: All right. So we'll have to see where we
are tomorrow afternoon, and then that will tell us what
happens on Friday, knowing that we have to end at least any
portion of the trial by 2:30. If for some reason we've gotten
beyond that point and the jury is deliberating, they can stay
as late as they like. I'm not sure we're going to get there.
And I'm going to ask the defense counsel to come
sidebar for one quick moment regarding scheduling. All right?
Have a good evening.
You're going to get a draft of the instructions, but
we'll get a chance to go through them in detail. So it's just
simply a draft this afternoon.
(Proceedings adjourned at 3:04 PM.)
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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: 14th of May, 2025
/s/Lance W. Steinbeisser
Lance W. Steinbeisser,
FCRR, RPR, FPR-C
Official Court Reporter
United States District Court
Southern District of Florida
Miami, Florida
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$
$1,000 [8] - 88:4,
92:5, 92:16, 96:10,
96:17, 96:24,
97:23, 98:2
$1,920 [1] - 104:11
$100 [2] - 87:23,
87:25
$112,430 [2] - 84:24,
90:3
$113,560 [2] - 85:3,
89:24
$127.79 [2] - 91:8,
91:14
$140,000 [1] - 22:4
$160,000 [1] - 21:11
$2,000 [3] - 96:2,
97:7, 97:15
$2,400 [1] - 98:6
$20,000 [2] - 54:5,
75:5
$20,800 [1] - 54:22
$20,833 [10] - 20:19,
78:3, 78:17, 87:11,
87:13, 91:2, 91:5,
91:16, 92:13,
107:16
$20,878.81 [1] - 92:11
$200,000 [2] - 24:4,
24:6
$21,320.82 [1] - 88:1
$3,709 [1] - 104:22
$3,889.50 [2] -
105:13, 105:22
$40,000 [2] - 13:19,
16:6
$49.54 [1] - 90:18
$50.20 [1] - 86:22
$500 [1] - 95:19
$587.82 [1] - 87:17
$700,000 [3] - 45:19,
59:21, 76:10
$701,873 [1] - 51:20
$955 [1] - 92:17
'
'18 [1] - 84:20
/
/s/Lance [1] - 155:5
0
001 [1] - 77:13
1
1 [18] - 1:8, 37:6,
38:9, 38:20, 64:1,
65:21, 78:1, 78:3,
78:8, 78:16, 79:5,
89:1, 89:11, 89:15,
94:2, 98:2, 101:14,
108:3
1's [2] - 78:9, 78:21
1,200 [1] - 91:8
10 [6] - 14:3, 57:23,
58:17, 96:17,
98:11, 99:1
1000 [4] - 101:13,
101:18, 130:7,
130:11
1000.1 [3] - 101:11,
101:18, 102:2
10:05 [3] - 122:2,
122:4, 122:6
10:30 [7] - 100:9,
100:10, 100:11,
100:22, 101:3,
152:23, 152:24
10:35 [1] - 101:4
10:54 [1] - 46:17
10:56 [1] - 145:24
11 [19] - 2:4, 15:3,
96:10, 105:13,
105:22, 106:14,
132:25, 134:3,
134:22, 136:2,
136:21, 137:16,
137:17, 138:16,
139:11, 141:1,
141:15, 144:22,
150:19
116 [4] - 117:23,
118:2, 118:6,
122:21
116.1 [5] - 117:24,
118:17, 118:20,
118:24, 122:20
117 [7] - 114:7,
114:11, 120:15,
120:19, 121:3,
121:21, 122:8
117.1 [5] - 120:16,
120:24, 121:6,
121:9, 122:16
118 [2] - 114:8,
114:18
11:00 [1] - 100:12
11:10 [1] - 152:10
11:14 [1] - 61:6
11:29 [1] - 61:6
11:31 [1] - 62:7
12 [2] - 16:20, 138:9
120,000 [1] - 21:2
12:00 [1] - 79:21
12:30 [1] - 99:8
12:31 [1] - 99:18
12:32 [1] - 100:4
12:37 [1] - 132:4
12:41 [1] - 132:4
13 [11] - 18:18, 139:6,
139:21, 140:9,
140:15, 141:18,
142:5, 142:6,
142:21, 143:5,
144:9
130 [3] - 148:13,
148:16, 148:21
131 [1] - 127:19
1343 [1] - 30:21
14 [2] - 22:23, 139:14
15 [16] - 24:19, 31:8,
57:24, 58:11,
58:17, 61:5, 98:6,
99:2, 126:1, 127:6,
127:23, 128:17,
139:22, 139:23,
142:24, 143:1
1512 [2] - 117:7,
135:22
155 [2] - 1:8, 2:8
157.1 [3] - 123:2,
123:5, 123:17
157.2 [5] - 123:3,
123:13, 123:19,
123:21, 124:16
159 [3] - 113:6,
113:11, 113:16
15th [2] - 99:1,
128:19
16 [13] - 1:4, 2:15,
28:4, 29:16, 29:20,
96:2, 122:18,
122:25, 126:1,
127:6, 127:23,
128:15, 140:15
160 [4] - 113:8,
113:13, 113:20,
114:1
163E [1] - 131:7
166 [12] - 130:23,
130:25, 131:23,
131:25, 132:17,
133:7, 133:8,
133:19, 140:4,
140:10, 142:3
16th [1] - 128:19
17 [2] - 96:24, 141:23
174.211.171.127 [1] -
151:15
18 [23] - 6:20, 27:23,
30:20, 31:20,
31:23, 32:22, 33:6,
119:5, 119:19,
119:21, 120:8,
120:10, 124:2,
124:4, 124:8,
124:14, 140:19,
142:6, 142:7,
142:10, 143:13,
145:24, 146:1
180 [1] - 23:11
184 [17] - 140:6,
140:13, 140:20,
140:22, 141:10,
141:12, 142:12,
142:15, 142:19,
142:23, 143:10,
143:13, 143:19,
143:25, 144:2,
144:17, 151:7
19 [8] - 120:12,
124:18, 143:2,
146:19, 147:12,
148:22, 149:4,
149:23
190 [1] - 145:6
194 [2] - 152:12,
152:14
1:06 [1] - 146:19
1:35 [1] - 99:9
1:41 [1] - 100:4
1:47 [1] - 103:18
2
2 [17] - 50:8, 59:24,
63:22, 77:24,
78:16, 78:20,
95:24, 95:25,
97:15, 104:5,
104:6, 105:3,
105:4, 105:25,
111:16, 112:22,
147:21
2/6/11 [1] - 105:14
20 [8] - 32:13, 32:14,
32:18, 120:14,
121:3, 143:15,
150:3, 150:14
20,000 [3] - 20:19,
69:6, 69:12
20,833 [3] - 22:2,
23:9, 24:25
200 [1] - 83:25
2001 [1] - 61:12
2002 [20] - 2:11,
49:20, 49:23, 50:9,
53:6, 56:9, 57:9,
59:24, 61:13,
61:14, 61:15, 63:3,
63:4, 63:22, 64:1,
Lance W. Steinbeisser - Federal Certified Realtime Reporter
156
69:25, 70:4, 72:15,
74:4
2014 [1] - 80:7
2018 [4] - 80:9,
83:19, 84:12, 89:2
2019 [5] - 83:20,
89:2, 94:2, 108:13,
108:19
2020 [4] - 44:10,
74:10, 108:15,
108:21
2021 [112] - 36:20,
50:3, 50:18, 63:17,
64:14, 70:13,
70:14, 71:15, 75:2,
78:7, 78:19, 86:16,
87:19, 88:2, 90:12,
90:21, 90:23,
95:17, 96:2, 96:10,
96:17, 96:24, 97:7,
97:15, 97:23, 98:2,
98:6, 98:23, 99:1,
99:2, 104:11,
104:22, 105:13,
105:22, 106:14,
108:17, 108:23,
109:6, 109:10,
119:5, 119:19,
119:21, 120:8,
120:10, 120:12,
120:14, 121:10,
121:14, 121:18,
122:4, 122:6,
124:2, 124:8,
124:14, 124:18,
125:1, 125:5,
126:1, 127:6,
127:10, 127:15,
127:23, 128:15,
128:17, 128:19,
131:1, 131:13,
131:21, 132:1,
132:12, 132:16,
132:19, 132:22,
133:6, 133:14,
133:16, 133:24,
134:25, 135:13,
135:18, 136:15,
137:7, 137:12,
137:16, 138:10,
139:21, 140:9,
140:16, 141:18,
142:5, 142:6,
142:21, 143:6,
144:10, 145:24,
146:1, 146:19,
147:12, 148:22,
149:4, 149:23,
150:3, 150:14,
151:10, 151:24,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 156 of
176
152:9
2022 [7] - 84:8,
84:13, 84:21,
89:14, 94:2
2023 [2] - 122:18,
122:25
2024 [3] - 1:4, 79:7,
110:17
2025 [1] - 155:5
204 [1] - 128:10
21 [1] - 144:9
22 [5] - 70:12, 145:1,
151:10, 151:24
223 [1] - 146:25
224 [2] - 146:1, 146:6
23 [3] - 79:7, 89:14,
145:14
23-60173-CR-KMW
[1] - 77:16
23-CR-60173-KMW
[1] - 1:2
237 [3] - 84:3, 84:7
24 [2] - 97:23, 145:24
25 [4] - 89:14, 97:7,
146:7, 152:9
250 [2] - 125:10,
125:21
26 [3] - 36:20, 94:2,
146:19
266 [1] - 127:2
27 [3] - 89:2, 90:12,
147:4
274-6800 [1] - 126:8
27th [1] - 155:5
28 [9] - 90:12,
110:16, 121:10,
121:14, 121:18,
122:2, 122:4,
122:6, 147:10
283 [1] - 127:18
29 [3] - 2:15, 89:2,
148:3
2:30 [5] - 58:11,
58:12, 124:2,
124:8, 154:15
2:31 [2] - 124:4,
124:14
2:53 [1] - 119:5
2:54 [1] - 119:19
2:56 [1] - 119:21
3
3 [18] - 44:10, 74:9,
74:13, 74:24, 78:6,
78:14, 86:23,
86:24, 87:4, 87:6,
87:21, 88:2, 90:19,
96:7, 104:19,
125:12, 125:22,
126:2
30 [1] - 148:10
300 [2] - 93:13, 93:14
301 [1] - 128:9
303 [4] - 88:16,
88:17, 89:8, 90:9
303.1 [4] - 90:5, 90:6,
90:19, 92:4
304 [11] - 95:9, 95:10,
96:7, 96:22, 97:4,
97:12, 97:20,
97:24, 98:3, 107:1,
108:8
305.523.5633 [1] -
1:23
306 [5] - 83:8, 83:11,
86:12, 88:24
306.1 [4] - 86:6, 86:7,
86:15, 86:24
307 [8] - 104:5,
104:6, 104:19,
105:5, 105:9,
105:19, 105:24,
105:25
31 [1] - 149:4
32 [1] - 149:20
33 [2] - 23:10, 150:3
33128 [1] - 1:23
34 [1] - 150:14
35 [1] - 151:10
36 [11] - 133:25,
134:15, 135:8,
135:13, 136:2,
136:21, 137:5,
137:7, 137:20,
137:25, 152:2
37 [2] - 2:15, 152:9
371 [1] - 27:23
39 [1] - 2:4
3926 [6] - 78:18,
78:24, 88:22,
89:17, 89:21, 107:2
3:00 [10] - 58:4, 58:5,
58:6, 58:8, 58:10,
58:15, 99:11,
99:12, 153:2
3:04 [2] - 1:6, 154:24
3:29 [1] - 137:9
3:35 [2] - 138:10,
138:22
3:48 [1] - 137:9
3rd [1] - 87:19
4
4 [27] - 1:7, 40:4,
40:11, 46:24, 47:5,
47:9, 84:8, 91:23,
91:24, 92:3, 96:15,
98:3, 105:9, 131:1,
131:13, 131:20,
132:1, 132:12,
132:16, 132:19,
132:22, 133:2,
133:6, 133:14,
133:16, 150:6
40 [1] - 101:4
40,000 [2] - 16:1,
20:21
400 [2] - 1:22, 109:13
401 [2] - 109:15,
112:7
404(b [4] - 41:23,
58:19, 58:22, 75:20
404(b) [4] - 41:24,
59:10, 59:12, 75:19
45 [3] - 44:10, 74:10,
74:23
467 [3] - 89:8, 89:9,
89:15
48 [1] - 147:23
488-1512 [1] - 126:18
4:00 [1] - 99:13
4:49 [1] - 124:18
4:57 [1] - 150:14
4th [1] - 104:11
5
5 [9] - 96:22, 104:22,
105:19, 105:24,
105:25, 133:24,
134:25, 135:13,
135:18
515 [1] - 141:19
56 [1] - 2:11
5:05 [1] - 122:25
5:06 [1] - 122:19
5:31 [2] - 120:8,
120:10
5G [19] - 126:7,
126:13, 126:17,
126:22, 128:21,
128:25, 134:9,
134:24, 136:4,
138:17, 139:12,
141:6, 141:17,
143:7, 143:23,
144:22, 149:15,
150:10, 150:20
6
6 [14] - 4:9, 50:3,
50:18, 63:17,
64:14, 75:2, 83:19,
97:4, 136:15,
137:6, 137:12,
137:16, 137:24,
138:10
6/11 [1] - 105:23
6/11/21 [1] - 106:16
601 [1] - 131:9
62 [1] - 2:5
6261949003 [1] -
77:25
645(a) [1] - 31:8
6506 [1] - 115:16
6578 [2] - 93:18,
93:22
6697269001 [1] -
78:15
6781674 [1] - 64:18
6800 [2] - 116:13,
150:18
6:23 [1] - 139:21
6F00 [3] - 120:23,
121:2, 122:18
7
7 [23] - 2:15, 35:10,
35:15, 35:18,
35:19, 35:20,
37:11, 37:16,
37:18, 78:19,
83:20, 84:8, 86:16,
90:21, 90:23,
91:16, 91:17,
97:12, 98:23,
107:24
70 [1] - 2:5
700 [3] - 115:5,
115:12, 122:14
701 [4] - 50:16,
115:6, 116:14,
123:11
701,873 [2] - 50:16,
64:9
72 [1] - 127:3
7309 [5] - 78:5,
78:12, 83:16,
106:6, 106:21
786 [1] - 126:18
79 [1] - 2:7
7:35 [1] - 138:23
7th [2] - 91:24, 92:3
8
8 [14] - 39:20, 39:24,
40:4, 41:9, 41:10,
41:13, 46:24, 47:6,
70:7, 72:19, 95:17,
97:20, 107:7
80,000 [1] - 20:24
Lance W. Steinbeisser - Federal Certified Realtime Reporter
157
800 [6] - 125:9,
125:21, 127:1,
127:17, 127:24,
128:10
806 [7] - 125:12,
125:22, 126:3,
127:2, 127:20,
127:25, 128:10
82 [2] - 149:8, 149:12
84 [4] - 149:7, 149:9,
150:19, 150:22
8:06 [1] - 148:25
9
9 [7] - 12:9, 97:24,
100:13, 100:14,
101:7, 118:6, 118:9
902.11 [1] - 59:1
941 [3] - 74:19,
74:21, 74:22
954 [1] - 126:8
9890 [1] - 116:18
9:14 [1] - 121:10
9:15 [2] - 121:14,
121:18
9:37 [1] - 1:6
9:47 [1] - 9:20
9:58 [1] - 120:14
9:59 [1] - 120:12
A
A-Head [5] - 37:6,
38:9, 38:20, 65:21,
108:4
able [7] - 82:25, 83:1,
83:4, 88:6, 91:11,
100:8, 129:9
above-entitled [1] -
155:3
above-stated [1] -
79:2
Abreu [1] - 11:14
absence [1] - 75:21
accept [2] - 75:18,
103:13
accepted [1] - 67:13
access [1] - 135:21
accessed [2] -
130:16, 148:17
accessible [3] -
136:8, 143:11,
145:9
accident [1] - 3:24
accomplished [1] -
55:10
according [3] - 9:7,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 157 of
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50:17, 120:4
accordingly [1] -
61:3
account [74] - 78:5,
78:11, 78:17,
78:23, 82:4, 82:25,
83:12, 83:14,
83:22, 84:10, 86:9,
86:17, 87:10,
87:13, 87:23,
88:20, 88:21,
88:23, 89:5, 89:11,
89:16, 89:21,
89:22, 89:23, 90:8,
90:14, 90:25, 91:4,
92:7, 93:8, 93:18,
94:19, 94:20,
103:25, 104:13,
104:14, 104:15,
104:17, 104:18,
106:6, 106:9,
106:20, 106:21,
106:23, 107:1,
107:15, 107:20,
108:3, 108:5,
108:10, 115:12,
115:15, 115:17,
115:19, 115:22,
116:15, 116:20,
116:22, 133:4,
133:17, 135:5,
141:11, 142:18,
144:14, 146:5,
146:6, 148:18,
148:19, 151:5,
151:6, 151:25,
154:7
accountant [13] -
47:18, 47:19,
47:21, 48:2, 48:6,
48:9, 48:14, 49:2,
49:9, 51:7, 52:5,
63:15, 72:14
accounts [13] -
81:22, 81:24, 82:1,
82:5, 82:6, 82:9,
82:12, 82:14, 83:2,
92:21, 95:5,
115:10, 144:16
Acevedo [1] - 11:25
ACH [5] - 78:4, 78:11,
78:17, 78:23, 87:7
action [3] - 31:4,
31:5, 147:24
activity [1] - 90:14
acts [1] - 33:7
actual [1] - 45:7
ADAM [1] - 1:13
add [1] - 101:13
added [1] - 150:2
adding [1] - 24:9
addition [1] - 130:4
additional [14] -
53:19, 87:18,
91:17, 99:19,
104:3, 117:17,
117:20, 118:21,
119:23, 121:6,
147:19, 150:2,
151:24, 153:4
address [95] - 3:7,
9:12, 25:17, 25:19,
26:4, 26:6, 26:13,
35:24, 36:15,
36:17, 46:11,
76:12, 115:19,
116:19, 122:10,
122:13, 123:10,
130:21, 130:22,
130:25, 131:12,
131:23, 131:24,
132:12, 132:17,
132:21, 133:7,
133:8, 133:11,
133:18, 133:25,
134:14, 134:15,
135:8, 135:10,
135:12, 136:2,
136:5, 136:6,
136:20, 137:4,
137:7, 137:20,
137:22, 137:25,
139:19, 140:5,
140:10, 140:12,
140:20, 140:22,
141:10, 141:12,
142:3, 142:9,
142:10, 142:15,
142:19, 142:22,
143:9, 143:10,
143:12, 143:19,
143:25, 144:2,
144:5, 144:17,
145:6, 145:8,
146:1, 146:6,
146:24, 146:25,
147:2, 148:13,
148:15, 148:21,
149:1, 149:7,
149:8, 149:9,
149:12, 150:6,
150:7, 150:18,
150:21, 150:22,
150:24, 151:6,
151:8, 151:13,
151:16, 151:25,
152:12, 152:14
addressed [2] -
55:21, 110:19
addresses [9] -
93:11, 94:5, 94:7,
94:11, 94:18,
140:3, 140:6,
140:19, 153:20
adjourned [1] -
154:24
Administration [2] -
31:6, 129:18
administrator [2] -
6:13, 6:16
admissibility [2] -
59:17, 73:25
admissible [1] - 79:3
admit [5] - 19:25,
28:13, 35:14,
37:11, 53:5
admitted [8] - 28:13,
34:14, 35:10,
35:11, 44:21, 57:5,
102:18, 102:20
ADMITTED [2] - 2:10,
2:14
admitting [2] - 55:1,
57:11
advise [1] - 147:20
advised [4] - 3:2,
73:24, 99:17, 100:7
affiliated [2] - 8:24,
9:1
afternoon [6] - 79:22,
79:23, 103:22,
103:23, 154:13,
154:23
afterwards [1] -
103:15
Agent [8] - 10:24,
60:11, 76:24, 77:2,
79:24, 86:5,
103:22, 129:8
agent [13] - 10:25,
58:19, 73:24,
74:20, 80:1, 80:8,
80:15, 81:10,
101:17, 134:1,
140:24, 144:20,
154:8
ago [3] - 92:12,
103:11, 106:25
agree [8] - 4:5, 30:2,
37:8, 56:1, 77:6,
77:8, 77:22, 79:2
agreement [2] - 29:4,
33:24
ahead [4] - 42:18,
60:21, 68:20,
119:12
aid [8] - 94:21, 94:24,
99:21, 101:16,
129:11, 130:3,
130:7
aided [1] - 1:25
Alex [1] - 148:14
Aliec [6] - 24:12,
24:14, 24:16,
24:20, 24:23, 25:13
Alison [1] - 12:24
allegation [1] - 29:14
allegations [2] -
28:13, 28:14
allege [1] - 29:10
alleged [2] - 77:24,
78:14
alleges [2] - 29:14,
75:15
alleging [1] - 30:24
allocation [1] - 154:6
allow [5] - 59:16,
61:19, 61:20,
62:11, 129:10
allowed [4] - 10:9,
61:16, 61:21, 85:16
allows [1] - 85:11
Almanzar [1] - 13:6
almost [1] - 38:23
ALSO [1] - 1:18
alternate [1] - 116:3
AM [14] - 1:6, 9:20,
46:17, 61:6, 62:7,
101:3, 120:14,
139:21, 145:24,
148:25, 152:10,
152:23, 152:24
Aman [1] - 131:19
America [2] - 77:17,
77:20
AMERICA [1] - 1:3
amount [20] - 23:9,
24:7, 24:9, 42:13,
50:15, 51:20,
57:15, 64:6, 64:8,
78:3, 78:17, 82:19,
84:24, 89:24, 90:3,
92:15, 104:11,
104:22, 105:13,
105:22
analyze [1] - 82:25
Android [13] - 134:3,
134:22, 136:2,
136:21, 138:16,
139:11, 141:1,
141:15, 142:20,
143:6, 144:22,
150:19, 151:6
Angela [1] - 13:14
answer [3] - 43:20,
46:3, 67:23
anticipate [3] - 60:23,
147:22, 153:6
anytime [1] - 144:13
apart [2] - 51:2
Lance W. Steinbeisser - Federal Certified Realtime Reporter
158
apologize [5] - 3:16,
20:10, 36:2, 61:11,
120:14
app [2] - 142:20,
151:6
appear [2] - 104:24,
119:22
appearances [1] -
44:24
applicant [1] - 31:3
application [118] -
12:10, 12:21,
13:10, 13:11,
13:13, 14:9, 14:19,
15:13, 16:21,
18:10, 18:11,
18:14, 18:20, 19:8,
19:14, 20:12,
22:15, 22:16,
22:21, 22:25, 23:4,
23:22, 24:20,
24:22, 25:6, 25:20,
25:24, 26:1, 26:14,
27:7, 36:4, 38:25,
40:21, 40:23, 44:8,
46:2, 50:14, 50:17,
50:19, 51:1, 51:8,
59:20, 59:21,
64:10, 64:15,
64:19, 66:23, 69:3,
69:5, 69:8, 69:10,
74:3, 74:5, 74:8,
74:11, 74:23, 75:2,
75:4, 76:12,
113:12, 113:14,
113:15, 113:21,
113:22, 114:2,
114:12, 114:14,
114:18, 114:20,
118:3, 118:11,
118:24, 119:23,
120:20, 121:21,
122:21, 123:7,
131:20, 132:10,
132:21, 133:3,
133:6, 133:16,
133:24, 134:21,
135:3, 135:8,
135:21, 137:19,
138:7, 139:17,
142:2, 142:22,
144:12, 144:13,
144:14, 145:5,
145:6, 145:19,
145:20, 145:22,
145:23, 146:1,
146:5, 146:12,
146:13, 146:18,
146:22, 147:8,
147:17, 147:22,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 158 of
176
147:24, 148:8,
150:1
applications [6] -
17:21, 147:15,
147:16, 148:5,
149:25, 152:8
applied [7] - 43:8,
44:2, 44:3, 44:4,
75:10, 75:25,
137:14
apply [4] - 43:19,
47:18, 49:5, 54:4
applying [4] - 40:24,
53:25, 75:7, 75:14
appointment [4] -
100:6, 100:8,
100:16, 152:22
appreciate [1] - 5:15
approach [7] - 12:5,
13:24, 14:25,
16:16, 27:25, 36:6,
49:15
approved [2] - 24:2,
139:10
approximate [3] -
78:3, 78:16, 92:15
April [4] - 125:1,
125:4, 126:1, 155:5
area [4] - 61:9, 61:10,
61:15, 62:1
areas [3] - 5:2, 6:1,
73:25
Arena [1] - 23:21
argue [3] - 55:24,
55:25, 76:6
arguing [2] - 55:2,
76:15
argument [9] - 54:16,
54:20, 54:24, 55:3,
55:6, 60:5, 73:16,
75:13
arguments [1] -
102:8
arisen [1] - 46:11
artifice [1] - 30:10
assigned [15] -
80:10, 80:13,
108:25, 109:6,
109:10, 126:13,
126:23, 129:5,
131:12, 132:12,
140:10, 140:13,
149:10, 149:11,
151:8
assist [3] - 65:3,
112:10, 112:14
Assistance [3] -
110:12, 111:18,
112:17
assistance [2] - 34:1,
88:11
assistant [2] - 10:8,
39:7
Assistant [2] - 79:8,
110:13
assisting [2] - 10:25,
11:3
associated [2] - 38:6,
116:19
assume [1] - 55:19
AT&T [10] - 129:24,
130:24, 131:9,
131:24, 132:18,
133:7, 133:19,
142:3, 150:22,
151:9
attached [9] - 44:10,
44:17, 44:21, 47:8,
49:13, 55:20,
63:25, 74:11, 74:22
attachment [9] -
50:11, 51:7, 53:17,
55:22, 56:20,
57:10, 57:12,
63:20, 63:25
attachments [3] -
36:22, 47:9, 57:5
attempt [11] - 138:15,
139:7, 143:3,
143:17, 144:6,
148:11, 148:12,
150:16, 151:11,
151:14, 152:11
attempted [1] - 11:15
attempting [1] -
22:13
attempts [7] -
130:16, 131:11,
135:17, 139:24,
140:17, 141:1,
150:5
attend [1] - 58:8
attention [1] - 4:4
Attorney [3] - 30:4,
79:8, 79:9
Attorney's [1] - 1:14
August [2] - 128:17,
128:19
aunt [1] - 9:3
AUSA [2] - 1:13, 1:13
authenticating [1] -
59:16
authentication [2] -
93:17, 93:25
authenticity [1] -
59:6
automated [1] - 78:3
available [1] - 73:8
Avenue [1] - 1:22
aware [6] - 3:10,
8:22, 42:11, 42:15,
44:7, 68:5
awareness [1] -
10:24
B
balance [10] - 86:18,
86:21, 87:13,
87:16, 87:24,
90:14, 91:4, 91:7,
92:6, 92:10
Bank [1] - 78:5
bank [40] - 78:9,
78:12, 78:17,
78:21, 78:24, 82:8,
82:11, 84:18,
84:23, 85:2, 89:22,
90:1, 92:21, 93:2,
93:7, 93:10, 93:17,
94:19, 95:4, 98:14,
103:25, 104:17,
106:6, 106:23,
107:4, 130:1,
133:4, 133:17,
144:14, 144:16,
146:5, 146:6
banks [1] - 81:20
Barbara [1] - 11:14
based [6] - 9:9,
34:10, 47:2, 74:8,
75:16, 119:22
bears [1] - 16:23
BEFORE [1] - 1:10
beginning [3] -
86:18, 86:21, 90:14
begins [1] - 83:19
BEHALF [1] - 1:15
behalf [3] - 38:18,
72:7, 76:11
behind [5] - 119:12,
119:13, 119:15,
119:16, 119:17
belonged [1] -
135:13
belonging [4] -
83:12, 88:21,
90:24, 148:19
below [2] - 34:10,
133:19
Bergh [1] - 134:19
better [1] - 82:24
between [7] - 77:3,
92:21, 94:10,
94:16, 94:17,
94:18, 119:9
beyond [4] - 56:12,
79:3, 79:6, 154:16
BF27 [4] - 118:15,
118:19, 122:25,
146:11
bigger [2] - 83:10,
128:16
bit [2] - 91:10, 145:15
borrow [1] - 69:25
bottom [21] - 130:23,
131:23, 132:18,
134:18, 135:9,
136:9, 136:23,
137:21, 141:13,
142:4, 142:14,
142:18, 143:24,
144:1, 144:18,
144:25, 148:14,
149:17, 150:20,
151:7, 152:13
box [1] - 135:24
break [7] - 46:13,
46:15, 57:23, 63:2,
99:8, 99:14, 103:24
bring [7] - 4:5, 4:24,
9:17, 9:18, 53:17,
62:6, 103:17
brother [9] - 21:5,
21:17, 21:20,
21:22, 22:7, 22:8
brother-in-law [4] -
21:5, 21:20, 21:22,
22:8
brother-in-law's [2] -
22:7, 22:8
brother-in-laws [1] -
21:17
brothers [1] - 21:21
brought [1] - 4:4
Broward [6] - 80:13,
108:14, 112:3,
113:2, 148:16,
148:17
browser [4] - 134:23,
138:16, 139:11,
141:16
BSO [9] - 108:14,
108:16, 108:18,
108:20, 108:22,
108:24, 108:25,
130:4, 130:5
building [2] - 5:20,
8:3
Bureau [2] - 80:1,
80:3
Business [4] - 31:6,
78:1, 87:7, 129:18
business [29] - 38:7,
38:20, 40:24,
42:10, 43:9, 43:19,
47:19, 49:5, 51:3,
54:6, 54:10, 55:11,
58:25, 59:6, 59:25,
Lance W. Steinbeisser - Federal Certified Realtime Reporter
159
65:21, 65:24, 66:2,
71:17, 71:20,
71:24, 72:11, 75:8,
84:25, 85:3, 89:24,
90:2
businesses [2] -
110:2, 110:3
Bustamante [3] - 4:9,
4:10, 4:14
BY [41] - 11:8, 12:7,
14:1, 15:1, 16:5,
16:18, 19:13,
25:12, 26:12, 28:2,
29:21, 30:19,
32:20, 32:25,
35:23, 36:8, 37:20,
38:24, 39:15,
46:22, 47:4, 47:20,
48:16, 49:3, 49:8,
49:19, 50:21,
50:25, 51:17,
52:10, 62:25, 69:1,
70:2, 72:13, 79:20,
84:22, 86:4, 88:14,
103:21, 125:23,
130:9
C
calculator [1] - 88:6
California [3] - 61:24,
78:10, 78:22
can.. [1] - 53:16
canceling [1] -
100:23
capacity [3] - 7:3,
80:21, 80:22
capture [1] - 84:9
carefully [1] - 26:2
Carlos [3] - 14:18,
15:19, 15:21
Carolyn [124] - 1:18,
26:19, 26:24,
27:11, 27:15, 30:3,
36:4, 38:5, 38:18,
69:8, 69:20, 70:24,
71:8, 72:7, 77:17,
77:20, 81:1, 81:24,
82:3, 82:16, 83:13,
85:4, 87:22, 87:25,
88:21, 89:24,
90:24, 93:24,
94:19, 95:16,
95:23, 96:1, 96:6,
96:9, 96:14, 96:16,
96:23, 97:6, 97:11,
97:14, 97:19,
97:22, 98:1, 98:5,
98:10, 98:19,
98:23, 104:1,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 159 of
176
104:16, 108:6,
108:9, 108:13,
109:9, 110:3,
110:11, 111:1,
111:5, 111:8,
111:9, 111:20,
112:1, 112:2,
114:12, 115:13,
115:18, 115:20,
116:11, 118:3,
120:6, 120:20,
121:12, 121:16,
121:20, 121:22,
125:4, 125:16,
126:5, 126:11,
127:9, 128:2,
128:20, 129:4,
132:16, 132:20,
133:15, 139:15,
139:24, 140:7,
140:23, 141:11,
141:14, 141:24,
142:9, 142:16,
142:18, 142:22,
143:3, 143:7,
143:17, 144:3,
144:11, 145:25,
146:11, 147:11,
147:25, 148:4,
148:12, 148:19,
149:22, 150:16,
150:23, 151:2,
151:5, 151:19,
152:4, 152:6
CAROLYN [1] - 1:7
case [22] - 9:1, 10:25,
55:4, 60:18, 73:24,
74:14, 76:14,
76:17, 77:9, 94:8,
100:23, 117:8,
124:20, 133:5,
135:21, 152:25,
153:7, 153:11,
153:16, 153:18,
153:25, 154:4
CASE [1] - 1:2
Case [1] - 77:16
cases [2] - 45:12,
85:13
caused [1] - 99:13
causes [1] - 100:22
cell [12] - 124:25,
125:3, 126:5,
127:9, 127:10,
127:13, 128:2,
128:6, 128:20,
128:24, 137:7,
151:19
cellular [1] - 150:17
certain [3] - 30:4,
77:7, 87:1
CERTIFICATE [1] -
155:1
Certificate [1] - 2:8
certificate [10] -
118:10, 118:21,
121:3, 123:6,
145:2, 145:22,
146:9, 146:18,
146:21, 146:23
certify [1] - 155:2
cetera [1] - 77:7
chance [4] - 102:17,
102:21, 103:4,
154:22
change [4] - 22:4,
26:7, 26:15, 129:6
changes [2] - 147:17,
149:25
Chapotten [1] - 17:24
characters [2] -
118:14, 120:22
charge [2] - 33:7,
33:16
charged [18] - 28:16,
28:17, 28:20,
28:25, 29:6, 29:22,
30:20, 31:15,
31:17, 31:23, 32:1,
32:2, 32:3, 32:6,
32:21, 33:13, 75:22
chart [9] - 103:7,
103:8, 130:15,
131:22, 136:6,
136:9, 136:19,
137:5, 148:12
check [98] - 37:6,
37:8, 38:9, 38:22,
39:7, 40:12, 40:13,
40:19, 41:19,
41:21, 41:25, 42:1,
42:2, 43:12, 43:14,
43:16, 43:24, 45:4,
46:23, 47:5, 47:9,
47:12, 47:14,
47:24, 48:3, 48:4,
48:8, 48:12, 48:13,
48:14, 48:18,
48:24, 48:25, 49:1,
49:2, 70:18, 70:21,
70:24, 71:1, 71:6,
71:12, 71:16, 72:1,
72:4, 72:9, 95:12,
95:14, 95:16,
95:18, 95:20,
95:24, 96:1, 96:8,
96:9, 96:15, 96:16,
96:23, 97:5, 97:6,
97:13, 97:14,
97:16, 97:21,
97:22, 97:25, 98:1,
98:3, 98:5, 98:15,
98:25, 104:5,
104:8, 104:10,
104:20, 104:21,
105:4, 105:10,
105:11, 105:12,
105:20, 105:21,
106:5, 106:13,
106:20, 107:1,
107:9, 107:12,
107:13, 107:15,
108:3, 108:5,
134:20, 136:11,
137:15
checking [5] - 78:11,
78:23, 83:12,
88:20, 151:5
checks [20] - 42:3,
95:4, 95:7, 98:12,
98:18, 98:22,
98:25, 103:25,
104:3, 104:16,
105:25, 106:1,
106:3, 106:8,
106:9, 106:16,
106:25, 107:18,
108:8, 108:10
chief [6] - 60:18,
76:17, 153:12,
153:16, 153:25,
154:4
Chrome [4] - 134:23,
138:16, 139:11,
141:15
city [1] - 6:18
City [1] - 7:9
ckidd1226@gmail.
com [2] - 115:21,
139:20
claimed [1] - 75:25
clarification [1] -
57:4
classic [1] - 78:11
clear [4] - 34:18,
53:24, 76:16, 102:6
clearinghouse [1] -
78:4
close [4] - 4:23, 5:11,
5:21, 5:23
closer [2] - 4:21, 5:19
closing [3] - 55:24,
55:25, 102:8
closings [1] - 61:2
co [1] - 39:7
co-counsel [1] - 39:7
Code [3] - 27:23,
30:21, 31:8
code [2] - 135:20,
150:17
codes [1] - 140:2
collect [2] - 81:4,
81:6
collected [1] - 81:17
collection [1] - 86:11
column [7] - 130:17,
130:20, 134:1,
135:18, 135:19,
139:25, 144:21
columns [1] - 130:20
combine [1] - 30:2
combined [1] - 31:12
coming [1] - 106:9
comment [1] - 9:11
commerce [3] -
77:19, 78:6, 78:19
commit [4] - 27:22,
30:4, 30:23, 32:2
committed [1] - 33:6
communicate [1] -
3:5
communicated [1] -
4:15
communication [2] -
78:5, 78:18
communications [3]
- 5:6, 36:3, 77:19
companies [3] -
110:21, 112:7,
112:8
company [7] - 6:17,
110:25, 111:1,
111:2, 111:6,
111:11, 111:15
compared [1] - 94:14
comparison [1] -
94:10
complete [3] - 25:24,
26:1, 26:16
completed [7] -
13:13, 18:11,
18:14, 20:12,
23:22, 25:6, 40:22
completing [1] -
38:25
completion [10] -
118:10, 118:22,
121:4, 123:6,
145:2, 145:22,
146:10, 146:18,
146:22, 146:23
computer [2] - 1:25,
60:2
computer-aided [1] -
1:25
computer-
generated [1] - 60:2
computers [3] -
52:12, 64:24, 65:4
Concepcion [9] -
Lance W. Steinbeisser - Federal Certified Realtime Reporter
160
45:23, 47:22, 48:7,
50:1, 51:6, 52:5,
63:13, 63:14, 64:1
concept [1] - 55:4
concern [1] - 57:14
concerned [1] -
59:20
conclude [2] -
153:11, 153:18
conclusion [1] - 55:3
conduct [11] - 67:13,
80:20, 134:2,
136:6, 136:11,
136:24, 137:15,
138:20, 150:21,
151:1, 151:21
conducted [6] -
131:22, 134:21,
136:2, 139:24,
141:1, 152:16
confederate [1] -
30:2
confer [1] - 59:2
confirm [6] - 18:11,
24:13, 24:15,
25:23, 25:25,
100:10
confirmed [2] - 19:5,
20:4
confirming [2] -
11:22, 11:24
conflate [1] - 54:3
confused [1] - 52:3
Congress [2] -
147:18, 150:2
connected [3] - 26:3,
26:6, 26:11
connection [4] - 6:4,
7:6, 8:8, 43:15
connects [1] - 76:12
consider [2] - 62:1,
77:8
consideration [2] -
34:6, 34:8
consistent [1] -
46:12
conspiracies [1] -
32:1
conspiracy [13] -
27:22, 29:10,
29:12, 30:1, 30:23,
31:12, 32:2, 32:3,
32:6, 33:8, 67:11,
75:16, 75:17
conspire [1] - 30:2
conspired [1] - 29:11
contact [7] - 26:21,
26:22, 26:24,
26:25, 27:6, 74:7,
147:18
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 160 of
176
continue [4] - 15:12,
103:19, 139:17,
148:8
Continued [1] - 2:4
continued [1] - 99:21
CONTINUED [1] -
11:7
continuing [1] - 9:14
control [3] - 33:13,
33:17, 33:18
convenient [1] -
58:12
conversation [1] -
27:2
conversion [4] -
7:12, 7:14, 7:15
converted [3] -
82:24, 137:10,
145:11
cooperation [1] -
34:11
coordinated [2] -
119:6, 130:18
copies [2] - 103:9,
145:21
copy [7] - 103:10,
122:17, 122:24,
124:11, 124:17,
146:16, 147:25
corporation [3] -
38:3, 38:4, 38:7
correct [86] - 11:15,
13:1, 13:3, 13:16,
13:18, 13:20,
14:21, 15:17,
15:25, 16:8, 16:13,
16:22, 16:24,
16:25, 17:8, 17:20,
18:4, 19:15, 19:24,
20:1, 20:22, 20:24,
21:17, 25:1, 25:16,
26:5, 28:12, 30:24,
31:11, 31:19,
31:22, 31:24, 32:6,
32:7, 33:4, 33:11,
34:12, 34:21, 35:2,
36:22, 37:18,
37:19, 37:22, 38:7,
38:8, 41:14, 43:3,
44:1, 48:5, 48:10,
52:1, 53:3, 56:16,
57:13, 58:24, 67:5,
68:4, 71:20, 71:25,
72:8, 72:17, 82:17,
84:14, 85:8, 89:7,
91:15, 104:1,
104:2, 106:15,
106:22, 106:24,
107:5, 110:18,
113:4, 123:18,
128:23, 136:14,
138:8, 138:21,
139:5, 141:8,
141:22, 144:8,
153:12, 153:13,
155:2
Corruption [1] -
80:13
corruption [1] -
80:16
counsel [10] - 6:7,
30:15, 39:7, 55:12,
59:3, 73:11, 77:22,
100:1, 100:5,
154:18
Counsel [4] - 55:14,
85:6, 85:20, 99:7
count [7] - 29:6,
29:10, 29:22,
31:24, 33:8,
132:24, 142:25
Count [2] - 77:24,
78:14
counts [1] - 31:23
County [1] - 80:13
couple [4] - 58:15,
70:3, 129:1, 130:20
course [2] - 34:17,
85:25
court [5] - 3:5, 46:4,
46:9, 62:22, 76:22
COURT [216] - 1:1,
3:2, 3:12, 3:15,
3:19, 3:23, 4:5, 4:8,
4:12, 4:14, 5:14,
5:23, 6:6, 7:23, 8:4,
8:9, 8:19, 8:22, 9:5,
9:8, 9:15, 9:17,
9:19, 9:21, 10:1,
10:3, 10:22, 11:1,
11:3, 12:6, 13:25,
16:3, 16:17, 19:12,
25:11, 26:10, 28:1,
29:17, 29:19,
30:15, 30:17,
32:15, 32:17,
32:24, 35:11,
35:13, 35:18, 36:7,
37:12, 37:15,
37:18, 39:10, 41:4,
41:7, 41:10, 41:16,
41:20, 41:24, 42:8,
42:14, 42:17,
42:19, 42:22, 43:1,
43:6, 43:10, 43:12,
43:23, 44:4, 44:12,
44:15, 44:18, 45:8,
45:16, 45:22,
45:24, 46:4, 46:8,
46:10, 46:18,
46:20, 47:2, 47:12,
47:14, 47:23, 48:3,
48:8, 48:11, 48:13,
48:19, 48:21,
48:24, 49:7, 49:17,
50:19, 50:23, 51:5,
51:9, 51:12, 51:14,
51:25, 52:3, 52:7,
52:23, 52:25, 53:2,
53:4, 53:8, 53:14,
53:17, 54:2, 54:8,
54:14, 54:19,
54:24, 55:2, 55:7,
55:14, 55:16,
55:19, 56:2, 56:6,
56:8, 56:12, 56:15,
56:18, 56:23, 57:1,
57:7, 57:10, 57:13,
57:16, 57:18,
57:20, 57:22, 58:2,
58:4, 58:20, 58:22,
59:2, 59:8, 59:11,
59:15, 59:22, 60:3,
60:7, 60:9, 60:12,
60:14, 60:17,
60:21, 61:1, 61:10,
61:14, 61:17,
61:23, 62:3, 62:8,
62:11, 62:20,
62:24, 68:25, 73:1,
73:3, 73:5, 73:10,
73:13, 73:19,
73:21, 74:1, 74:14,
74:16, 74:21,
74:25, 75:12, 76:1,
76:4, 76:13, 76:20,
77:5, 79:11, 85:6,
85:10, 88:13, 99:7,
99:19, 99:23,
99:25, 100:3,
100:5, 100:15,
100:19, 100:24,
101:2, 101:6,
101:8, 101:12,
101:15, 101:22,
102:3, 102:5,
102:12, 102:23,
103:6, 103:13,
103:17, 103:19,
130:8, 152:19,
153:3, 153:6,
153:10, 153:14,
154:3, 154:9,
154:12
Court [21] - 1:21,
1:22, 3:1, 3:9, 3:17,
4:24, 32:13, 32:17,
39:21, 44:20, 56:4,
58:18, 59:9, 61:7,
73:15, 73:23,
75:18, 77:15,
94:25, 155:6, 155:7
Court's [2] - 10:24,
44:23
courthouse [2] -
8:23, 109:11
courthouses [2] -
109:4, 109:5
COURTROOM [2] -
10:20, 79:15
courtroom [15] - 3:3,
3:4, 3:22, 4:11,
4:15, 4:16, 8:21,
8:23, 10:2, 10:6,
10:10, 10:15,
10:21, 49:22,
100:12
cousin [2] - 21:20,
21:22
cousins [2] - 21:18,
21:21
create [2] - 68:12,
116:4
created [4] - 67:1,
69:15, 132:8, 135:7
creates [1] - 9:10
creation [1] - 132:11
creations [2] - 135:4,
142:1
crime [2] - 31:9,
34:14
crimes [2] - 29:11,
31:12
criminal [1] - 80:17
cross [8] - 39:18,
45:4, 48:17, 62:15,
66:5, 68:5, 76:18,
154:7
Cross [1] - 2:4
CROSS [1] - 11:7
cross-examination
[6] - 39:18, 45:4,
48:17, 66:5, 68:5,
154:7
CROSS-
EXAMINATION [1] -
11:7
Cross-Examination
[1] - 2:4
cross-examine [1] -
76:18
Cruz [3] - 20:17,
20:18, 20:20
Cruz's [1] - 13:15
Cs [3] - 67:9, 68:6,
68:12
customer [12] -
134:11, 135:11,
137:2, 137:23,
140:8, 140:23,
142:17, 144:4,
Lance W. Steinbeisser - Federal Certified Realtime Reporter
161
147:3, 150:8,
150:23, 152:16
customers [4] -
134:17, 136:8,
143:11, 145:9
D
D-I-P-I-E-T-R-A-N-T-
O-N-I-O [1] - 79:18
D98B [5] - 123:16,
124:12, 124:18,
145:4, 145:18
DARYL [1] - 1:17
database [2] - 6:13,
6:15
DATE [1] - 155:5
date [8] - 50:2, 63:16,
64:13, 70:16,
93:25, 99:2,
128:18, 148:22
dated [5] - 79:7, 99:1,
106:13, 106:16,
110:16
DAVID [1] - 1:13
David [1] - 79:8
DAY [1] - 1:7
Daylight [2] - 130:18,
132:2
daylight [2] - 139:3,
145:12
days [4] - 58:15,
99:15, 103:11,
149:3
de [4] - 13:14, 20:17,
20:18, 20:20
deal [3] - 33:12,
33:15, 33:20
debit [3] - 87:22,
87:24, 91:20
debits [1] - 91:21
December [4] -
83:19, 84:12,
84:20, 89:2
decide [1] - 62:17
decided [3] - 33:6,
33:10, 33:16
decides [1] - 28:25
decision [1] - 60:7
deemed [1] - 79:6
defendant [3] -
51:25, 52:2, 76:19
Defendants [3] - 1:8,
77:18, 77:20
defendants [4] -
4:23, 77:4, 79:1,
79:10
DEFENDANTS [1] -
1:15
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 161 of
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Defendants' [5] -
35:10, 35:15,
39:24, 46:24, 47:6
DEFENSE [1] - 2:13
Defense [13] - 24:18,
29:16, 29:20,
37:16, 39:20, 40:4,
70:7, 72:18, 107:7,
107:24, 153:17
defense [27] - 4:5,
9:16, 12:8, 14:2,
15:2, 16:19, 18:18,
22:22, 28:3, 39:19,
39:20, 41:9, 41:10,
42:7, 43:11, 45:2,
53:23, 53:24, 54:3,
55:8, 62:8, 103:11,
153:15, 153:25,
154:2, 154:18
defense's [2] - 76:9,
154:7
deferment [1] - 31:4
deferring [1] - 44:23
defraud [2] - 30:10,
30:11
deliberate [1] -
153:23
deliberating [1] -
154:16
deliberations [1] -
85:15
delivered [2] -
122:17, 122:24
demonstrates [1] -
102:9
demonstrative [19] -
94:24, 99:21,
101:16, 101:23,
101:24, 101:25,
102:6, 102:9,
102:16, 102:25,
103:7, 103:13,
130:3, 130:6,
130:10, 130:19,
131:17, 135:16,
138:9
DENISE [1] - 1:7
Denise [2] - 77:17,
77:21
Department [9] -
109:21, 109:23,
111:12, 111:17,
111:25, 112:10,
112:13, 112:16,
112:25
department [7] - 6:1,
7:5, 7:7, 7:17,
108:25, 109:3,
109:7
departments [1] -
7:13
deposit [2] - 87:7,
91:1
deposited [1] - 90:25
deposits [4] - 84:24,
85:3, 89:23, 90:2
deputy [2] - 3:3, 4:15
DEPUTY [2] - 10:20,
79:15
despite [1] - 99:15
detail [2] - 141:20,
154:22
details [1] - 55:12
detention [2] - 109:3,
109:7
detentions [1] -
109:2
determine [3] -
33:25, 59:10, 59:18
device [20] - 126:12,
134:1, 134:22,
134:23, 135:19,
136:3, 136:10,
136:12, 136:21,
138:17, 138:19,
141:15, 141:20,
143:6, 150:9,
151:1, 151:2,
152:16, 152:17
devices [2] - 125:7,
129:5
devise [2] - 30:10
difference [6] -
58:13, 100:25,
101:20, 119:8,
138:24, 139:4
different [32] - 5:25,
6:1, 7:5, 7:13,
21:14, 42:20,
43:14, 45:1, 62:12,
62:14, 75:25,
76:20, 82:5, 82:14,
88:23, 92:21,
104:14, 104:17,
104:18, 115:9,
122:21, 130:21,
132:15, 135:6,
136:17, 136:18,
141:7, 142:8,
147:12, 148:19,
149:2, 149:3
difficult [1] - 91:9
digits [6] - 83:15,
93:21, 115:14,
116:12, 116:17,
133:10
Dion [1] - 134:12
DiPietrantonio [10] -
10:25, 60:11,
73:15, 76:24, 77:2,
79:17, 79:24, 86:5,
103:22, 129:8
DIPIETRANTONIO
[2] - 2:7, 79:13
dire [1] - 152:22
direct [9] - 43:21,
54:9, 66:10, 67:17,
67:20, 68:16, 77:1,
99:21, 154:8
DIRECT [1] - 79:19
Direct [1] - 2:7
directly [1] - 117:13
disbursement [2] -
77:25, 78:15
disciplinary [1] -
7:20
disclose [1] - 5:11
discuss [1] - 152:25
discussed [2] -
17:25, 61:25
display [1] - 46:24
displayed [4] -
133:22, 137:17,
139:22, 143:16
DISTRICT [3] - 1:1,
1:1, 1:11
District [5] - 1:22,
77:15, 77:16,
155:7, 155:7
doctor's [3] - 100:6,
100:16, 152:22
document [36] -
12:16, 12:19, 15:4,
15:7, 15:8, 15:10,
17:2, 18:24, 22:24,
24:19, 24:22,
28:10, 28:14, 29:8,
36:19, 37:2, 40:18,
41:8, 44:12, 44:20,
49:9, 51:10, 55:5,
56:19, 63:6, 63:8,
65:6, 94:11,
111:23, 112:22,
118:16, 118:18,
133:4, 133:17,
144:13
documents [13] -
26:7, 42:16, 42:19,
42:23, 60:1, 74:11,
85:13, 85:14,
85:17, 85:18,
85:23, 85:24,
144:16
DocuSign [15] -
27:16, 117:9,
117:11, 117:13,
117:17, 117:18,
118:10, 120:21,
121:1, 123:15,
129:20, 145:2,
145:5, 145:25,
152:7
dollars [2] - 88:8,
92:7
DONALD [1] - 1:10
done [12] - 14:19,
17:16, 38:23,
65:15, 132:17,
133:18, 133:25,
136:21, 140:1,
140:9, 140:12,
142:2
door [3] - 44:25,
54:15, 58:8
doors [1] - 57:22
doubt [3] - 5:13,
79:3, 79:6
down [5] - 3:6, 46:1,
73:5, 145:1, 153:3
draft [3] - 153:21,
154:21, 154:23
Draw [21] - 13:17,
14:22, 15:13,
15:14, 15:21, 16:6,
20:15, 20:20,
20:23, 21:1, 21:9,
21:25, 23:12,
23:25, 67:18,
67:25, 68:3, 68:7,
68:18, 68:21
drawn [5] - 106:21,
106:23, 107:1,
107:19, 108:10
draws [1] - 68:9
due [1] - 7:14
duly [1] - 79:13
during [19] - 3:4,
4:20, 45:4, 55:24,
55:25, 63:2, 66:5,
67:17, 81:3, 85:15,
99:21, 102:7,
102:8, 119:11,
126:5, 126:16,
126:23, 145:9,
152:22
E
early [2] - 99:12,
99:14
earnings [2] - 112:2,
113:1
ease [3] - 82:20,
130:19, 139:3
easier [3] - 83:10,
85:17, 85:22
easily [1] - 83:5
eastern [4] - 119:9,
137:10, 139:2,
Lance W. Steinbeisser - Federal Certified Realtime Reporter
162
145:12
Eastern [2] - 130:18,
132:2
Edison [2] - 23:14,
23:16
EDT [1] - 138:22
effect [2] - 106:11,
106:18
eight [2] - 135:15
EIN [2] - 38:1, 112:15
either [6] - 5:8, 19:7,
41:22, 61:2, 98:19,
103:1
electronic [1] - 92:22
electronically [2] -
78:11, 78:23
ELMO [2] - 107:22,
107:23
email [78] - 27:6,
35:24, 36:3, 36:9,
36:12, 36:14,
36:15, 36:17, 37:2,
37:21, 40:21,
44:17, 44:22,
45:19, 45:20, 47:7,
47:8, 47:17, 48:1,
49:11, 50:1, 50:2,
51:7, 51:18, 52:16,
52:18, 55:20,
56:19, 57:5, 57:9,
57:10, 57:11,
63:10, 63:11,
63:12, 63:13,
63:16, 63:18,
63:20, 63:25,
64:22, 65:1, 68:19,
70:16, 71:4, 71:5,
71:11, 71:15,
72:14, 72:18,
72:19, 74:4,
115:19, 116:19,
122:10, 123:10,
137:13, 138:12,
139:15, 139:19,
140:1, 147:11,
147:13, 147:23,
148:1, 148:3,
148:4, 149:20,
149:22, 152:2,
152:3, 152:5,
152:6, 153:20
emails [1] - 27:8
employed [3] -
108:13, 108:14,
108:19
employee [1] -
110:15
employees [9] -
44:10, 74:10,
74:23, 113:16,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 162 of
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113:21, 114:2,
114:13, 114:19,
114:24
employers [1] -
110:14
employment [2] -
112:3, 113:2
end [7] - 57:25, 58:4,
58:6, 58:15, 99:11,
140:4, 154:14
ended [1] - 146:25
ending [75] - 78:5,
78:12, 78:18,
78:23, 88:22,
89:17, 89:21,
93:18, 106:6,
106:21, 107:2,
116:12, 118:19,
120:21, 121:2,
122:18, 122:25,
123:15, 124:11,
124:18, 130:22,
130:25, 131:23,
131:25, 132:17,
133:7, 133:8,
133:18, 133:25,
134:15, 135:8,
135:13, 135:22,
136:2, 136:21,
137:4, 137:7,
137:20, 137:25,
140:6, 140:10,
140:12, 140:19,
140:20, 140:22,
142:3, 142:9,
142:15, 142:19,
142:23, 143:9,
143:13, 143:19,
143:25, 144:2,
144:17, 145:4,
145:6, 146:1,
146:6, 146:10,
148:13, 148:15,
148:21, 149:7,
149:8, 149:9,
149:12, 150:6,
150:18, 150:22,
151:7, 152:12,
152:14
endorsed [16] -
95:22, 96:3, 96:5,
96:11, 96:13,
96:18, 96:25, 97:8,
97:10, 97:16, 98:7,
98:9, 104:24,
105:1, 105:15,
105:17
endorsement [4] -
95:20, 96:20,
105:3, 105:4
endorser [2] - 97:2,
105:7
ends [1] - 56:2
enforcement [1] -
80:19
enjoy [2] - 99:17,
100:3
enlarge [9] - 63:11,
64:3, 87:1, 90:20,
91:11, 95:12,
95:14, 104:8,
105:10
enlarged [3] - 64:4,
87:2, 87:18
enlarging [4] - 65:6,
97:4, 104:19,
105:19
entered [8] - 4:11,
9:20, 10:2, 10:21,
62:7, 100:14,
103:18, 132:20
entertain [2] - 73:16,
153:15
entire [2] - 84:9,
133:10
entirely [2] - 54:6,
74:12
entitled [1] - 155:3
entry [2] - 122:16,
122:23
envelope [24] -
118:12, 118:18,
118:19, 118:20,
119:1, 120:21,
121:1, 121:9,
122:10, 122:18,
122:25, 123:15,
123:17, 123:22,
124:11, 124:17,
145:4, 145:18,
145:21, 146:9,
146:17, 147:4
equipment [1] - 3:6
ESQ [2] - 1:16, 1:17
establish [2] - 54:11,
56:21
estimate [1] - 50:14
estimated [3] - 50:15,
51:20, 64:6
et [1] - 77:7
evening [2] - 153:1,
154:20
event [5] - 118:25,
121:7, 146:8,
146:15, 147:5
events [10] - 122:7,
133:2, 133:3,
133:15, 133:23,
134:2, 134:15,
144:11, 144:12,
144:21
evidence [57] - 28:24,
29:20, 37:16,
39:21, 41:10,
41:25, 44:7, 44:14,
44:17, 44:18,
44:20, 45:2, 45:7,
51:23, 55:5, 56:5,
56:9, 57:5, 58:25,
59:23, 60:1, 63:2,
74:17, 74:18, 75:3,
75:11, 75:17, 76:4,
76:6, 76:14, 77:9,
79:3, 81:4, 81:6,
83:7, 84:24, 85:7,
85:11, 85:14,
85:19, 86:6, 88:17,
89:23, 93:13,
101:10, 101:19,
104:4, 107:6,
107:24, 109:12,
114:8, 115:5,
117:21, 129:11,
153:18
Evidence [1] - 79:4
evidentiary [1] -
41:25
exactly [7] - 3:23,
5:14, 14:17, 54:23,
56:14, 56:23
Examination [5] -
2:4, 2:4, 2:5, 2:5,
2:7
EXAMINATION [4] -
11:7, 39:14, 70:1,
79:19
examination [11] -
39:18, 45:4, 48:17,
66:5, 66:11, 67:17,
67:20, 68:5, 68:16,
77:2, 154:7
examine [1] - 76:18
Excel [2] - 82:24,
83:4
Excels [1] - 83:1
exception [6] - 10:7,
10:9, 10:23, 59:7,
59:16, 106:8
exceptions [1] - 11:1
excuse [3] - 11:23,
20:9, 58:3
excused [5] - 73:1,
73:3, 73:6, 73:9,
73:10
exempted [1] - 11:4
Exhibit [66] - 24:19,
29:16, 29:20,
35:10, 35:15,
37:11, 37:16,
39:20, 39:24,
49:20, 49:23, 50:9,
56:9, 57:9, 59:24,
61:15, 69:25, 70:4,
70:7, 72:15, 72:19,
74:4, 77:13, 83:8,
83:11, 86:6, 86:7,
86:12, 86:24,
88:16, 88:24, 89:8,
90:5, 90:19, 93:13,
95:9, 96:7, 96:22,
97:12, 98:3, 104:4,
104:6, 107:1,
107:24, 108:8,
109:13, 109:15,
112:6, 113:6,
113:8, 113:11,
115:5, 115:6,
117:23, 117:24,
118:2, 120:16,
122:14, 123:2,
123:11, 125:9,
125:12, 127:1,
128:10
exhibit [38] - 16:20,
18:5, 18:18, 22:23,
28:4, 39:19, 39:21,
41:19, 45:3, 57:6,
61:10, 61:11,
61:19, 62:15, 63:2,
85:15, 98:11,
101:23, 101:24,
101:25, 102:2,
102:6, 102:9,
102:10, 102:17,
102:19, 102:20,
102:21, 102:25,
103:5, 103:7,
103:13, 105:24,
125:10, 125:19,
127:1, 131:4
Exhibits [1] - 133:22
exhibits [6] - 85:6,
103:9, 109:12,
109:16, 113:5,
128:14
EXHIBITS [2] - 2:10,
2:13
exist [1] - 75:8
exit [1] - 10:6
exited [6] - 3:22,
8:21, 46:17, 99:18,
101:7, 153:2
expect [2] - 60:14,
60:17
expects [1] - 60:19
explain [6] - 7:19,
19:9, 59:18, 85:10,
85:25, 138:24
explained [1] - 95:1
explaining [3] - 7:10,
Lance W. Steinbeisser - Federal Certified Realtime Reporter
163
51:15, 76:3
expound [1] - 4:17
extension [1] - 31:4
extent [3] - 43:17,
62:17, 112:24
extract [8] - 129:9,
129:13, 129:15,
129:17, 129:20,
129:22, 129:24,
130:1
F
facilitate [1] - 82:20
facilities [1] - 109:4
facing [1] - 34:13
fact [7] - 23:11,
25:21, 34:18,
43:20, 44:1, 51:22,
51:23
facts [9] - 3:25, 43:7,
43:8, 43:10, 45:24,
77:7, 77:23, 79:2,
79:5
fair [3] - 26:20, 27:10,
46:1
Faitrouni [3] - 13:21,
14:7, 14:14
fake [1] - 17:10
false [10] - 29:12,
30:11, 30:13, 31:2,
31:9, 74:12, 74:17,
75:11, 75:17
familiar [6] - 40:25,
41:12, 81:17, 95:7,
125:7, 125:13
family [1] - 5:8
Fanara [1] - 130:24
Fandino [5] - 14:18,
15:19, 15:21,
20:18, 20:23
far [11] - 5:9, 7:10,
11:21, 17:22,
27:15, 41:7, 45:8,
60:10, 71:10,
71:12, 99:16
Fast [6] - 12:21,
16:20, 18:20,
22:24, 24:19, 25:19
FBI [6] - 76:25, 80:4,
80:6, 80:8, 81:10,
82:20
FCRR [2] - 1:21,
155:6
federal [2] - 80:17,
81:7
Federal [4] - 78:4,
79:4, 80:1, 80:3
felt [1] - 5:11
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 163 of
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few [2] - 6:8, 58:13
fictitious [1] - 74:12
figure [1] - 46:6
file [5] - 19:8, 19:9,
26:7, 133:5, 133:16
filed [3] - 26:14,
74:19, 76:11
files [1] - 82:24
filings [1] - 113:3
filled [1] - 69:15
Finance [1] - 78:2
financial [1] - 81:20
fine [2] - 4:2, 103:15
finish [1] - 46:14
finished [1] - 45:6
finishes [1] - 62:4
First [1] - 68:7
first [45] - 3:7, 4:4,
5:14, 5:16, 6:15,
15:24, 22:24,
24:19, 36:24, 39:7,
47:12, 52:4, 53:13,
53:14, 63:9, 66:10,
68:3, 68:10, 74:2,
83:21, 87:6, 90:13,
90:20, 109:13,
110:23, 111:11,
113:6, 119:18,
120:7, 121:13,
122:1, 123:6,
128:18, 130:15,
131:7, 131:21,
135:18, 138:15,
139:25, 140:3,
143:3, 144:6,
145:4, 145:25,
147:15
five [14] - 6:23, 32:9,
32:10, 79:21,
91:21, 130:21,
131:14, 133:13,
135:6, 135:14,
140:6, 140:14,
141:19
fix [2] - 7:11, 7:19
floor [1] - 4:21
FLORIDA [1] - 1:1
Florida [19] - 1:3,
1:23, 77:16,
109:21, 109:23,
110:12, 110:13,
111:12, 111:16,
111:25, 112:10,
112:13, 112:16,
112:24, 119:9,
119:12, 119:16,
155:7, 155:8
folder [3] - 16:20,
17:3, 22:24
folders [1] - 25:7
follow [1] - 54:20
followed [1] - 101:22
following [11] - 41:6,
46:9, 55:14, 55:15,
62:10, 62:22,
73:19, 73:22,
76:22, 77:23, 139:3
follows [1] - 77:14
FOR [1] - 1:12
foregoing [1] - 155:2
forget [1] - 9:24
forgiveness [6] -
113:14, 113:21,
114:1, 114:3,
114:18, 114:25
form [2] - 18:25,
129:10
Form [1] - 74:19
formerly [1] - 29:25
forward [3] - 47:16,
48:1, 153:7
forwarded [5] - 48:4,
48:8, 48:13, 49:2,
51:7
Foundation [2] -
111:3, 111:16
foundation [5] -
19:11, 26:9, 35:16,
35:18, 88:12
four [31] - 35:5, 35:6,
82:13, 82:14,
83:14, 84:15,
84:18, 84:23, 85:2,
89:20, 89:21, 90:1,
93:21, 115:14,
116:12, 116:17,
117:6, 118:14,
119:11, 120:3,
120:22, 133:1,
136:18, 136:19,
137:5, 137:6,
138:12, 138:14,
139:4, 146:13
four-hour [1] - 139:4
fourth [1] - 120:13
FPR [2] - 1:21, 155:6
FPR-C [2] - 1:21,
155:6
fraud [6] - 30:23,
32:2, 32:11, 32:14,
32:21, 33:7
fraudulent [1] - 30:12
fraudulently [1] -
30:14
frequently [2] -
52:16, 65:1
Friday [4] - 58:7,
58:10, 61:2, 154:14
friend [1] - 11:14
front [1] - 71:21
frowned [1] - 62:1
frowns [1] - 61:8
full [6] - 79:16,
124:11, 124:17,
145:21, 146:17
funded [1] - 13:15
funding [1] - 147:19
funds [7] - 78:8,
78:10, 78:20,
78:22, 87:22,
148:9, 150:2
Funeral [50] - 40:12,
42:11, 43:16,
43:20, 44:9, 45:5,
51:8, 53:13, 53:22,
54:1, 54:10, 54:13,
54:17, 55:21,
56:19, 63:19,
65:18, 65:24, 74:6,
74:7, 74:9, 75:8,
75:10, 75:23,
96:21, 97:3,
104:10, 104:21,
105:8, 105:12,
105:21, 106:17,
110:24, 111:12,
112:9, 112:14,
112:17, 131:1,
131:12, 131:25,
132:12, 132:19,
132:21, 133:9,
133:20, 140:5,
140:10, 142:5
funeral [1] - 107:19
G
G998U [11] - 134:3,
134:6, 134:22,
134:23, 136:3,
136:22, 138:17,
139:12, 150:9,
152:17
Galaxy [11] - 126:17,
126:22, 128:25,
134:9, 134:24,
136:4, 137:8,
138:17, 139:12,
149:15, 150:10
Garcia [1] - 17:24
gather [1] - 110:8
general [1] - 32:6
generally [4] - 10:9,
61:8, 85:20, 109:7
generated [1] - 60:2
gentlemen [4] -
57:25, 77:5, 85:11,
99:10
Gmail [1] - 115:10
Gomez [2] - 100:13,
100:15
Google [10] - 115:9,
115:12, 115:15,
115:19, 116:3,
116:15, 116:17,
116:19, 122:13,
134:4
government [3] -
24:5, 37:13, 131:4
GOVERNMENT [2] -
1:12, 2:10
Government [112] -
4:2, 4:3, 8:25, 9:13,
10:25, 17:18,
17:21, 21:12,
23:16, 28:24,
33:10, 33:24, 34:9,
34:11, 34:18, 35:1,
49:20, 49:23, 50:9,
53:5, 53:6, 53:21,
56:9, 59:23, 60:19,
61:21, 63:3, 63:4,
64:1, 72:15, 72:24,
73:13, 73:14, 74:4,
76:16, 77:13,
79:13, 83:7, 83:8,
83:11, 86:6, 86:7,
86:12, 86:23,
88:16, 88:17,
88:24, 89:8, 90:5,
90:9, 90:19, 92:4,
93:13, 95:9, 96:7,
96:22, 97:4, 97:12,
97:20, 97:24, 98:3,
99:20, 101:11,
104:4, 104:6,
104:19, 105:5,
105:9, 105:19,
105:24, 107:1,
108:8, 109:13,
109:15, 112:6,
113:6, 113:8,
113:11, 113:16,
113:20, 114:1,
114:11, 114:18,
115:4, 115:5,
115:12, 117:23,
117:24, 118:2,
118:6, 120:15,
120:16, 121:21,
122:8, 122:14,
123:2, 123:3,
123:11, 125:9,
125:11, 125:22,
126:3, 127:1,
127:17, 127:20,
128:9, 128:10,
131:7, 131:9,
133:22, 153:5,
Lance W. Steinbeisser - Federal Certified Realtime Reporter
164
153:22
Government's [9] -
41:23, 42:6, 61:17,
63:22, 70:4, 73:2,
101:9, 116:14,
153:11
GOVERNMENT'S [1]
- 2:2
GRAHAM [1] - 1:10
Graham) [1] - 77:16
Granados [11] - 16:9,
16:23, 17:6, 17:7,
29:25, 35:24, 75:7,
75:24, 88:4, 92:5,
92:8
grand [4] - 28:24,
81:7, 81:9
guess [1] - 22:17
guilty [4] - 27:21,
28:11, 29:12, 67:11
H
hair [3] - 37:6, 38:9,
108:4
half [4] - 88:9, 140:1,
154:11
hand [5] - 114:7,
143:20, 145:3,
146:21, 148:14
handle [2] - 61:3,
109:4
happy [1] - 99:12
Harvest [2] - 78:1,
87:7
havoc [1] - 99:13
Haydee [6] - 29:24,
29:25, 75:7, 88:4,
92:5, 92:8
HAYDEE [1] - 2:3
HDMI [1] - 108:12
Head [5] - 37:6, 38:9,
38:20, 65:21, 108:4
header [2] - 138:22,
145:11
heading [1] - 130:20
hear [6] - 10:10,
10:12, 10:13, 46:5,
73:17, 102:23
heard [6] - 8:11, 8:13,
9:10, 33:18, 45:25,
47:2
hearing [3] - 46:5,
99:13, 102:21
hearings [1] - 58:5
hears [1] - 28:24
hearsay [7] - 48:11,
48:19, 48:21, 49:7,
51:23, 59:7, 59:16
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 164 of
176
heart [2] - 43:4, 43:6
HELD [1] - 1:10
held [6] - 41:6, 46:9,
62:10, 62:22,
73:22, 76:22
help [2] - 21:12,
31:20
helped [3] - 24:5,
31:18, 32:22
helping [1] - 31:17
Hendrith [1] - 1:19
hereby [1] - 77:22
hereinafter [2] -
77:25, 78:15
herself [4] - 17:16,
31:3, 98:19, 108:9
hgranados29@
gmail.com [1] -
35:24
highlighted [8] -
124:10, 124:15,
130:21, 134:1,
134:14, 135:6,
140:3, 140:6
highlighting [1] -
140:17
himself [3] - 136:13,
136:24, 139:8
history [10] - 93:17,
94:1, 118:18,
118:20, 121:1,
122:20, 123:15,
145:18, 146:9,
147:4
hmm [5] - 11:17,
36:16, 37:5, 57:17,
122:22
Home [50] - 40:12,
42:11, 43:16,
43:20, 44:9, 45:5,
51:8, 53:13, 53:22,
54:1, 54:11, 54:13,
54:17, 55:21,
56:19, 63:19,
65:18, 65:24, 74:6,
74:7, 74:9, 75:8,
75:10, 75:23,
96:21, 97:3,
104:10, 104:22,
105:8, 105:13,
105:22, 106:17,
110:24, 111:12,
112:9, 112:14,
112:18, 131:1,
131:12, 131:25,
132:12, 132:19,
132:21, 133:9,
133:20, 140:5,
140:10, 142:5
home [1] - 107:19
Honor [48] - 3:9,
9:24, 9:25, 11:6,
12:4, 12:5, 14:25,
16:16, 18:15,
30:18, 33:22, 35:9,
35:14, 35:21,
38:22, 39:5, 39:6,
39:11, 41:2, 42:6,
46:25, 53:7, 53:9,
57:4, 57:14, 61:7,
62:19, 68:24,
71:18, 72:12,
72:22, 72:23,
72:25, 73:4, 73:7,
73:12, 76:8, 76:23,
77:1, 85:9, 86:3,
101:5, 101:9,
102:4, 102:11,
102:15, 103:3,
103:20
HONORABLE [1] -
1:10
hope [2] - 34:6, 34:9
hopefully [1] -
153:11
hoping [2] - 34:22,
34:24
hour [7] - 3:4, 99:14,
100:25, 139:4,
153:9, 154:8,
154:11
hours [7] - 60:16,
60:25, 119:11,
138:12, 138:14,
147:23, 153:17
house [1] - 151:9
hundred [5] - 5:18,
5:21, 60:1, 60:3,
89:3
hundreds [1] - 85:13
hurricane [1] - 99:13
husband [16] - 47:16,
47:24, 47:25, 48:5,
51:11, 52:9, 52:11,
53:2, 64:23, 64:24,
70:21, 71:1, 71:3,
71:6, 98:20, 146:16
husband's [9] -
47:18, 47:19,
47:21, 48:6, 48:8,
48:14, 49:2, 52:5,
63:15
I
ID [16] - 36:25,
115:15, 116:17,
118:12, 120:21,
122:18, 122:25,
123:15, 124:11,
124:17, 145:4,
145:18, 145:21,
146:17, 147:4
idea [5] - 4:3, 8:1,
17:13, 17:17,
154:10
identification [14] -
12:9, 14:3, 15:3,
16:20, 18:18,
22:23, 28:4, 35:19,
35:20, 37:12,
39:20, 49:18,
49:20, 130:7
identified [3] - 50:8,
78:2, 130:11
identifier [3] -
135:19, 139:25
identify [3] - 28:5,
110:11, 144:7
identity [16] - 11:22,
11:24, 18:12, 19:4,
20:4, 24:13, 24:15,
25:4, 25:23, 25:25,
137:15, 138:13,
139:8, 143:18,
144:7, 151:22
IDLE [1] - 59:5
ignorance [1] -
153:23
image [7] - 95:12,
96:15, 98:4, 104:6,
104:20, 105:10,
105:20
images [5] - 95:4,
97:5, 98:15,
103:24, 106:5
immediate [1] - 91:3
important [1] - 43:5
Inc [1] - 111:16
inclination [1] -
61:20
include [2] - 81:19,
124:22
included [2] - 92:16,
145:22
includes [1] - 146:17
including [1] - 79:4
incomplete [2] -
139:17, 148:6
Incorporated [1] -
111:3
indicate [2] - 124:25,
125:3
indicated [2] - 18:2,
70:9
indicates [2] - 9:3,
132:7
indictment [8] -
28:17, 28:21,
28:23, 75:15,
77:24, 78:2, 78:14,
81:1
individually [1] -
31:17
individuals [3] - 66:9,
67:14, 68:6
inferences [1] - 76:5
inflows [4] - 84:24,
85:3, 89:23, 90:2
influenced [1] -
10:12
influencing [1] - 31:5
information [46] -
28:8, 28:9, 28:10,
28:16, 29:9, 29:13,
29:14, 40:20,
47:17, 48:1, 54:16,
65:3, 71:15, 75:17,
99:10, 109:23,
110:2, 110:8,
110:25, 111:4,
111:21, 111:23,
112:1, 112:20,
112:22, 112:24,
115:9, 116:22,
118:21, 121:6,
129:10, 129:13,
129:15, 129:17,
129:20, 129:22,
129:24, 130:1,
130:4, 131:5,
133:21, 135:15,
139:22, 142:7,
143:15, 146:7
initial [2] - 7:14,
20:19
initiate [1] - 92:25
inputted [1] - 69:16
instances [3] -
130:21, 131:21,
146:13
institution [1] -
107:12
institutions [1] -
81:20
instruction [2] -
153:22, 153:23
instructions [2] -
153:21, 154:21
intend [1] - 30:10
intent [3] - 30:1, 30:9,
75:21
interact [1] - 8:15
interaction [1] - 7:8
interactions [1] -
7:10
interested [2] -
81:25, 82:1
interject [1] - 55:9
interstate [3] - 77:19,
Lance W. Steinbeisser - Federal Certified Realtime Reporter
165
78:6, 78:19
introduce [2] - 29:15
introduced [1] -
62:15
investigate [1] -
80:17
investigating [1] -
80:20
Investigation [2] -
80:2, 80:3
investigation [2] -
80:25, 81:3
investiture [1] - 58:7
invited [1] - 68:17
invoke [1] - 9:25
invoked [4] - 10:1,
10:4, 10:13, 10:17
involved [10] - 7:13,
27:11, 40:14,
56:17, 56:18, 66:3,
66:6, 66:23, 67:14,
75:3
involvement [2] -
43:17, 68:9
IP [93] - 25:17, 25:19,
26:3, 26:4, 26:6,
26:13, 76:12,
93:11, 94:5, 94:7,
94:11, 94:18,
130:20, 130:22,
130:25, 131:12,
131:22, 131:24,
132:12, 132:17,
132:21, 133:7,
133:8, 133:10,
133:18, 133:25,
134:14, 134:15,
135:8, 135:10,
135:12, 136:2,
136:5, 136:6,
136:20, 137:4,
137:7, 137:20,
137:22, 137:24,
140:3, 140:4,
140:6, 140:9,
140:12, 140:19,
140:20, 140:22,
141:10, 141:12,
142:2, 142:9,
142:10, 142:15,
142:19, 142:22,
143:9, 143:10,
143:12, 143:19,
143:25, 144:2,
144:5, 144:17,
144:19, 145:6,
145:8, 146:1,
146:4, 146:6,
146:24, 146:25,
147:2, 148:13,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 165 of
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148:15, 148:21,
149:7, 149:9,
149:12, 150:6,
150:18, 150:21,
150:22, 150:24,
151:6, 151:8,
151:13, 151:16,
151:25, 152:12,
152:14
IPI [1] - 41:22
IRS [2] - 74:20
issuance [1] - 81:6
issue [11] - 3:7, 4:17,
4:25, 5:1, 9:13,
9:16, 42:4, 46:5,
46:10, 76:20, 102:8
issues [10] - 6:2, 7:6,
7:11, 7:14, 7:18,
7:21, 9:10, 9:12,
73:17, 99:19
IT [3] - 5:9, 6:1, 7:4
item [1] - 61:18
J
jail [1] - 109:4
jails [2] - 109:5,
109:8
January [3] - 83:20,
89:2, 94:2
Jimenez [6] - 18:8,
18:16, 18:17,
18:23, 19:2, 20:1
job [4] - 5:4, 5:5,
6:11, 6:12
JOHNNY [1] - 1:16
Johnny [2] - 1:16,
79:10
Johnson [1] - 9:4
Jorge [4] - 20:9,
20:10, 21:4, 21:16
Jose [2] - 21:14,
21:16
JR [1] - 1:16
Jr [1] - 1:16
Judge [9] - 8:18,
9:16, 10:19, 29:15,
53:16, 74:2, 75:1,
75:20, 154:5
JUDGE [1] - 1:11
judge [10] - 9:2, 9:18,
10:23, 34:1, 34:2,
34:8, 34:9, 55:9,
58:16, 60:23
judicial [1] - 32:13
judicially [1] - 32:17
Julio [1] - 23:21
July [8] - 97:15, 98:2,
98:6, 99:2, 125:1,
125:4, 127:23,
128:19
jump [2] - 127:18,
127:19
June [36] - 78:6,
78:19, 86:16, 87:4,
87:6, 87:19, 87:21,
88:2, 90:12, 90:21,
90:23, 91:16,
91:17, 91:24, 92:3,
95:17, 96:2, 96:10,
96:17, 96:24, 97:7,
97:23, 98:23, 99:1,
104:11, 104:22,
105:13, 105:22,
106:14, 125:1,
125:4, 127:6,
127:10, 127:15,
127:23, 128:15
juror [9] - 3:25, 4:6,
4:8, 8:21, 9:14,
10:2, 10:19, 10:21,
100:6
Juror [4] - 4:9, 4:11,
100:14, 101:7
JUROR [24] - 4:13,
4:18, 5:18, 5:25,
6:10, 6:13, 6:15,
6:18, 6:20, 6:23,
7:1, 7:4, 7:10, 7:22,
7:24, 8:6, 8:10,
8:13, 8:17, 9:23,
100:18, 100:22,
101:1, 101:5
jurors [5] - 3:3,
100:21, 101:2,
101:8, 152:22
Jury [6] - 9:20, 46:17,
62:7, 99:18,
103:18, 153:2
jury [28] - 8:20, 9:17,
28:24, 28:25,
37:17, 49:16,
49:21, 54:24, 55:3,
62:6, 63:1, 66:22,
66:25, 67:6, 69:2,
69:7, 79:24, 81:7,
81:9, 95:14,
101:21, 101:25,
102:7, 103:17,
129:10, 129:11,
154:16
JURY [2] - 1:10,
30:16
jury's [1] - 94:25
K
K-E-L-L-Y [1] - 79:17
Katelin [1] - 11:25
keep [6] - 43:10,
93:3, 93:10, 99:17,
134:10, 142:13
keeping [1] - 24:9
Kelly [3] - 73:15,
76:24, 79:17
KELLY [2] - 2:7,
79:13
Kendall [2] - 100:7,
152:22
kind [7] - 8:1, 94:10,
126:5, 126:15,
135:4, 141:3, 141:5
knowing [3] - 30:12,
31:2, 154:14
knowingly [2] - 30:2,
30:9
knowledge [8] - 9:6,
50:24, 51:1, 75:6,
75:21, 76:11,
88:10, 92:24
known [3] - 6:22,
29:25, 30:3
knows [6] - 42:12,
45:14, 45:18,
45:19, 46:3, 75:9
L
L2 [1] - 87:7
ladies [3] - 77:5,
85:11, 99:10
Lance [1] - 155:5
LANCE [1] - 1:21
Lane [6] - 12:21,
16:21, 18:20,
22:25, 24:19, 25:19
Lapointe [1] - 79:9
large [2] - 36:25,
82:19
larger [1] - 53:16
last [34] - 11:11, 40:3,
79:18, 83:14, 84:2,
93:21, 98:25, 99:5,
105:24, 106:13,
107:9, 111:7,
115:14, 116:12,
116:17, 117:6,
118:14, 120:22,
122:16, 122:23,
124:15, 128:9,
129:1, 133:10,
136:6, 136:19,
137:5, 139:10,
140:5, 140:18,
142:11, 146:15,
147:20
late [2] - 153:10,
154:17
latest [1] - 100:22
law [5] - 21:5, 21:20,
21:22, 22:8, 80:18
Law [1] - 1:16
law's [2] - 22:7, 22:8
laws [1] - 21:17
lawyers [4] - 10:3,
10:8, 77:6, 85:25
lay [1] - 35:16
laying [1] - 47:1
Lazaro [1] - 17:24
lead [1] - 27:13
leading [2] - 46:25,
68:24
least [4] - 31:20,
46:1, 58:11, 154:14
leave [1] - 10:16
leaving [2] - 8:2,
99:12
left [32] - 5:20, 11:11,
36:24, 37:2,
109:14, 110:16,
113:7, 114:7,
115:4, 115:11,
117:22, 118:19,
120:15, 123:1,
123:17, 125:10,
125:20, 125:25,
126:25, 127:17,
134:18, 142:14,
144:1, 144:18,
145:3, 146:21,
148:14, 149:17,
150:12, 150:20,
151:4, 154:8
left-hand [4] - 114:7,
145:3, 146:21,
148:14
Lender [5] - 78:3,
78:9, 78:16, 78:21,
79:5
lender [1] - 15:13
letter [11] - 110:16,
135:9, 137:3,
137:21, 142:15,
144:1, 144:18,
145:7, 146:3,
147:1, 152:13
letting [4] - 76:17,
139:16, 149:23,
152:7
Lidia [1] - 4:10
lie [1] - 32:3
likely [2] - 9:8, 61:1
limited [1] - 79:4
Lindsey [1] - 134:19
line [1] - 124:9
linked [4] - 25:19,
133:4, 133:17,
144:16
Lance W. Steinbeisser - Federal Certified Realtime Reporter
166
links [1] - 144:14
list [2] - 35:19, 85:15
listed [7] - 35:20,
95:17, 112:7,
113:18, 114:22,
116:5, 139:2
listen [4] - 26:2,
33:19, 60:4, 62:16
listening [2] - 53:8,
58:1
literally [1] - 75:14
lived [1] - 135:20
LLC [5] - 78:2,
110:24, 111:12,
112:9, 112:18
loan [151] - 11:15,
13:10, 13:15,
17:21, 18:10, 19:7,
19:18, 19:25, 20:3,
20:13, 20:17,
20:20, 20:23, 21:1,
21:7, 21:23, 22:2,
22:9, 22:13, 23:4,
23:9, 23:19, 23:23,
24:2, 24:14, 24:16,
24:17, 24:22, 25:3,
25:15, 25:21, 26:8,
26:14, 26:19, 27:7,
27:13, 27:16, 31:3,
32:22, 36:4, 40:14,
40:24, 40:25,
41:22, 42:10,
42:11, 42:12,
42:14, 42:21,
42:22, 43:9, 43:14,
43:16, 43:19,
43:25, 44:8, 44:22,
45:3, 45:5, 45:10,
45:11, 45:13,
45:18, 47:19, 49:6,
50:14, 50:15, 51:2,
51:20, 53:10,
53:22, 53:25, 54:5,
54:7, 54:17, 54:21,
54:22, 54:25,
55:11, 55:12,
56:17, 59:20,
59:21, 64:5, 64:6,
65:15, 65:18,
65:21, 65:24,
66:20, 67:6, 67:25,
68:20, 69:3, 69:5,
69:8, 69:10, 71:17,
72:11, 74:2, 74:3,
74:8, 75:4, 75:10,
75:15, 75:22,
75:23, 76:10,
76:11, 87:9, 87:14,
88:11, 90:24,
91:16, 92:12,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 166 of
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92:16, 98:23,
104:1, 106:2,
106:4, 107:16,
108:6, 113:12,
113:14, 113:22,
114:12, 118:3,
120:20, 121:21,
123:6, 132:21,
133:16, 133:24,
137:14, 137:19,
139:18, 142:22,
144:12, 145:5,
145:23, 145:25,
146:4, 146:22,
147:8, 148:5
Loan [6] - 77:25,
78:1, 78:8, 78:15,
78:16, 78:20
loans [18] - 11:13,
31:18, 41:11,
43:21, 54:4, 54:10,
65:13, 66:1, 66:6,
66:9, 67:10, 67:21,
75:16, 82:2, 82:4,
82:15, 106:10,
147:19
locate [1] - 111:18
located [4] - 78:9,
78:12, 78:21, 78:24
log [4] - 94:18, 94:19,
138:19, 150:16
logged [2] - 148:21,
151:6
login [23] - 130:16,
131:11, 135:17,
135:25, 136:1,
136:6, 136:10,
139:24, 140:17,
141:1, 146:5,
148:10, 148:12,
148:22, 150:5,
150:18, 150:21,
151:1, 151:11,
151:13, 151:18,
152:11, 152:16
logins [29] - 93:3,
93:7, 93:10, 93:11,
94:7, 94:10, 94:12,
94:15, 130:21,
136:17, 136:18,
136:19, 136:20,
137:5, 137:6,
140:9, 140:12,
140:19, 141:10,
141:12, 141:19,
141:21, 142:19,
148:19, 149:6,
149:14, 150:9,
151:24
look [44] - 4:21, 5:19,
17:2, 18:24, 53:10,
53:12, 55:17, 72:1,
85:24, 92:1, 94:5,
94:7, 94:23,
102:18, 103:4,
104:3, 113:5,
117:20, 130:17,
130:23, 131:21,
131:23, 133:25,
134:13, 134:18,
135:8, 135:18,
135:25, 136:8,
136:18, 137:3,
139:25, 140:21,
140:24, 141:13,
142:17, 143:25,
144:20, 148:13,
148:18, 150:12,
150:24, 151:4,
151:7
looked [23] - 86:12,
88:24, 89:11, 90:9,
98:16, 98:20, 99:1,
105:25, 106:8,
106:25, 108:8,
112:25, 122:13,
127:11, 128:3,
128:22, 129:1,
140:18, 141:19,
143:12, 145:14,
146:10, 149:24
looking [48] - 10:14,
40:11, 40:19,
51:10, 63:8, 72:3,
83:18, 84:6, 86:17,
87:12, 88:7, 88:19,
91:3, 92:6, 93:2,
95:5, 103:24,
104:9, 104:15,
106:13, 107:18,
110:5, 110:10,
110:11, 112:6,
118:24, 119:1,
121:9, 122:7,
123:13, 125:20,
125:21, 125:24,
127:5, 127:7,
127:22, 127:24,
128:13, 130:10,
130:14, 133:5,
133:16, 137:21,
140:19, 142:7,
142:8, 146:3,
146:20
looks [2] - 5:20,
104:23
loses [1] - 116:2
losing [1] - 99:15
lost [2] - 23:11, 54:2
LOVE [1] - 1:13
lunch [6] - 3:4, 4:20,
99:8, 99:17, 100:3,
103:24
Lunch [1] - 100:4
lunchtime [1] - 5:19
M
ma'am [7] - 12:8,
12:11, 15:10,
47:12, 52:7, 71:12,
71:19
maintain [2] - 80:22,
130:15
maintained [26] -
130:25, 131:25,
132:18, 133:8,
133:20, 134:16,
134:25, 135:23,
136:7, 137:1,
137:4, 137:22,
138:18, 139:1,
139:13, 140:5,
140:7, 140:22,
141:17, 142:4,
142:16, 144:2,
145:8, 147:2,
148:16, 152:14
March [5] - 36:20,
70:12, 71:15,
72:19, 110:16
mark [1] - 49:17
MARKED [2] - 2:10,
2:14
marked [12] - 12:8,
14:2, 15:2, 16:19,
18:18, 22:22,
24:18, 28:3, 37:15,
39:19, 77:13, 130:7
Markenzy [1] - 79:9
marking [1] - 49:20
Mary [8] - 8:3, 8:5,
8:10, 8:11, 8:13,
8:23, 8:25, 9:4
match [1] - 133:11
materially [1] - 30:11
math [1] - 88:5
matter [4] - 9:12,
41:3, 55:21, 155:3
matters [2] - 58:18,
153:4
maximum [1] - 32:18
MCCRAY [23] - 1:16,
4:7, 6:8, 6:11, 6:14,
6:17, 6:19, 6:21,
6:25, 7:2, 7:8, 7:20,
8:11, 8:15, 8:18,
9:2, 9:7, 9:16, 55:9,
55:15, 55:17, 56:1,
60:23
McCray [3] - 1:16,
35:8, 79:10
mean [9] - 25:20,
37:1, 43:13, 45:24,
58:16, 94:24,
102:23, 103:11,
138:6
meaning [1] - 77:8
means [8] - 10:5,
10:14, 26:11,
30:11, 100:9,
132:8, 153:10,
153:18
mechanical [1] - 1:24
member [4] - 93:17,
93:19, 93:23, 93:25
members [2] - 8:20,
81:14
memo [18] - 95:17,
96:2, 96:10, 96:17,
96:24, 97:7, 97:15,
97:23, 98:2, 98:6,
98:18, 104:12,
104:22, 105:14,
105:23, 106:10,
106:18, 108:9
memory [1] - 25:18
mentioned [2] - 3:3,
85:18
met [2] - 35:1, 35:5
Miami [7] - 1:3, 1:22,
1:23, 6:18, 7:9, 9:5,
155:8
Michael [4] - 18:8,
18:16, 18:23, 19:2
Microsoft [1] - 82:24
middle [4] - 135:24,
136:25, 150:25,
151:4
might [2] - 58:14,
76:6
million [4] - 44:10,
74:9, 74:13, 74:24
millions [1] - 85:13
mind [2] - 26:8, 26:15
mindful [1] - 58:10
minute [2] - 42:8,
54:2
minutes [5] - 57:24,
58:13, 58:17, 61:5,
79:21
misplaced [1] - 33:22
misplaces [1] - 116:2
missed [1] - 154:6
missing [2] - 9:21,
10:19
misstates [1] - 25:10
mistake [2] - 75:21,
75:22
Lance W. Steinbeisser - Federal Certified Realtime Reporter
167
mistaken [1] - 13:14
mobile [5] - 134:23,
138:16, 139:11,
141:16, 152:16
Model [11] - 134:3,
134:22, 136:3,
136:21, 138:16,
139:11, 141:1,
141:16, 143:6,
150:9, 152:17
model [9] - 134:5,
136:3, 137:8,
143:22, 144:23,
149:18, 150:19,
151:18, 151:19
modification [2] -
132:9, 132:11
modifications [3] -
135:4, 138:6, 142:1
modified [1] - 135:7
Mohamed [1] - 13:21
moment [21] - 12:4,
14:24, 18:15,
27:20, 32:15, 39:5,
39:12, 42:17,
43:12, 45:9, 71:18,
72:12, 72:22,
76:25, 92:12,
94:23, 101:12,
102:4, 106:25,
107:22, 154:19
Monday [1] - 61:2
money [5] - 30:11,
31:7, 92:16,
110:14, 150:2
month [2] - 119:11,
128:8
months [4] - 72:15,
85:23, 128:22,
129:2
morning [18] - 3:8,
4:12, 4:13, 4:18,
6:9, 6:10, 9:21,
11:9, 11:10, 39:16,
39:17, 44:19, 70:3,
100:7, 100:17,
101:3, 152:23,
153:11
Morrow [1] - 134:12
most [3] - 26:20,
27:2, 66:15
motion [1] - 41:23
motions [1] - 153:14
move [16] - 29:15,
34:1, 44:13, 45:6,
51:23, 56:22,
56:24, 57:1, 58:24,
59:25, 86:23,
88:15, 91:23,
95:24, 101:10,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 167 of
176
143:15
moved [2] - 39:20,
63:22
moves [1] - 53:5
moving [19] - 107:9,
131:17, 132:14,
133:1, 133:21,
135:1, 135:15,
136:15, 137:12,
139:6, 140:15,
141:23, 142:6,
143:2, 145:1,
146:19, 147:4,
147:10, 150:14
MR [243] - 3:9, 3:13,
3:17, 3:20, 4:2, 4:7,
6:8, 6:11, 6:14,
6:17, 6:19, 6:21,
6:25, 7:2, 7:8, 7:20,
8:11, 8:15, 8:18,
8:25, 9:2, 9:7, 9:13,
9:16, 9:18, 9:24,
10:19, 10:23, 11:2,
11:6, 11:8, 12:7,
13:24, 14:1, 14:25,
15:1, 16:4, 16:5,
16:16, 16:18,
19:11, 19:13,
25:10, 25:12, 26:9,
26:12, 27:25, 28:2,
29:18, 29:21,
30:18, 30:19,
32:16, 32:20,
32:23, 32:25,
35:12, 35:14,
35:16, 35:21,
35:23, 36:6, 36:8,
37:11, 37:14,
37:17, 37:19,
37:20, 38:22,
38:24, 39:6, 39:11,
39:15, 41:2, 41:5,
41:9, 41:15, 41:18,
41:21, 42:6, 42:9,
42:15, 42:18,
42:21, 42:25, 43:3,
43:8, 43:11, 43:15,
44:2, 44:6, 44:13,
44:16, 44:19,
45:14, 45:18,
45:23, 46:1, 46:7,
46:19, 46:22,
46:25, 47:1, 47:4,
47:20, 48:12,
48:16, 48:20,
48:23, 49:3, 49:8,
49:15, 49:19,
50:21, 50:25,
51:17, 51:22, 52:2,
52:4, 52:10, 53:5,
53:7, 53:9, 53:12,
53:15, 53:21, 54:3,
54:9, 54:15, 54:23,
55:1, 55:5, 55:9,
55:15, 55:17, 56:1,
56:4, 56:7, 56:10,
56:11, 56:14,
56:16, 56:21,
56:24, 57:4, 57:6,
57:9, 57:11, 57:14,
57:17, 57:19,
57:21, 58:1, 58:3,
58:16, 58:21,
58:24, 59:4, 59:9,
59:14, 59:19,
59:23, 60:6, 60:8,
60:10, 60:13,
60:16, 60:19,
60:23, 61:7, 61:11,
61:13, 61:15,
61:21, 62:2, 62:19,
62:21, 62:23,
62:25, 68:24, 69:1,
69:24, 69:25, 70:2,
72:12, 72:13,
72:22, 72:24, 73:2,
73:4, 73:7, 73:14,
73:20, 73:23, 74:2,
74:15, 74:18,
74:22, 75:1, 75:13,
76:3, 76:8, 76:16,
76:23, 77:11,
79:12, 79:20,
84:17, 84:18,
84:20, 84:21,
84:22, 85:9, 86:3,
86:4, 88:12, 88:14,
99:20, 99:24,
100:2, 101:9,
101:14, 101:16,
102:2, 102:4,
102:11, 102:13,
103:3, 103:9,
103:15, 103:20,
103:21, 125:18,
125:20, 125:23,
130:6, 130:9,
153:5, 153:9,
153:13, 154:1,
154:4, 154:11
multi [1] - 89:3
multi-hundred-page
[1] - 89:3
multiple [4] - 144:11,
144:15, 145:20,
147:14
must [3] - 10:6,
10:16, 25:9
N
N986U [7] - 141:2,
141:3, 141:16,
143:6, 143:22,
144:22, 150:19
name [25] - 6:12,
6:17, 7:23, 8:1, 8:2,
8:3, 8:7, 8:10, 8:12,
8:14, 9:3, 15:18,
16:23, 18:22, 19:1,
22:6, 23:2, 23:7,
29:24, 45:23,
54:12, 79:16,
79:18, 90:2, 115:17
named [6] - 8:23,
8:25, 17:22, 84:25,
85:3, 108:3
names [1] - 67:3
nature [1] - 152:5
need [11] - 5:11,
26:10, 29:9, 35:16,
38:2, 39:12, 43:6,
55:5, 76:25,
103:11, 152:7
needed [1] - 6:2
network [4] - 134:17,
137:2, 141:18,
143:8
never [7] - 8:17,
12:21, 13:12,
13:13, 14:6, 16:15,
17:17
new [7] - 61:8, 61:10,
61:15, 61:17,
61:19, 61:25, 116:4
news [1] - 61:4
next [9] - 24:22, 58:8,
58:15, 59:12,
60:12, 87:21, 88:2,
111:2, 147:23
Nichole [1] - 13:6
Nilda [3] - 18:13,
20:11, 21:1
nine [1] - 136:15
NO [1] - 1:2
non [1] - 48:11
non-hearsay [1] -
48:11
nonhearsay [1] -
48:15
normally [1] - 34:10
North [3] - 1:22, 6:18,
9:5
Note [1] - 143:7
Note20 [8] - 126:7,
126:12, 128:21,
141:6, 141:16,
143:23, 144:22,
150:20
notes [3] - 32:17,
135:19, 155:3
nothing [3] - 5:10,
40:21, 72:23
notice [5] - 3:15,
32:14, 62:20,
138:22, 147:17
noticed [3] - 4:18,
4:21, 58:19
notified [1] - 73:10
November [4] - 84:8,
84:13, 84:21, 89:14
Number [18] - 4:9,
15:3, 77:16, 77:25,
78:15, 100:13,
100:14, 101:7,
102:2, 134:3,
134:22, 136:22,
138:16, 141:1,
141:16, 143:6,
150:9, 152:17
number [39] - 11:12,
25:17, 37:24, 38:1,
38:6, 64:15, 64:17,
66:6, 78:5, 78:17,
83:14, 88:22,
93:19, 105:14,
111:10, 112:12,
113:16, 114:13,
114:24, 116:5,
116:8, 116:25,
117:2, 117:6,
126:11, 126:12,
126:21, 126:22,
134:4, 134:5,
135:22, 136:3,
138:4, 139:11,
140:2, 144:23,
149:18
numbers [4] - 69:16,
85:20, 117:6, 129:4
O
object [3] - 53:9,
59:5, 102:18
objecting [2] - 57:18,
102:19
objection [27] -
19:11, 25:10, 26:9,
29:17, 32:15,
32:23, 37:14, 41:2,
41:17, 46:25,
57:16, 68:24, 76:7,
76:8, 76:9, 76:13,
76:15, 88:12,
99:24, 100:2,
101:10, 102:3,
102:16, 102:20,
Lance W. Steinbeisser - Federal Certified Realtime Reporter
168
102:24, 103:1,
103:16
objects [1] - 30:1
obligated [1] - 60:22
obligation [1] - 34:20
observed [1] - 4:16
obtain [2] - 30:11,
117:13
obtaining [2] - 31:3,
31:7
occasions [1] -
145:21
occurred [25] -
132:15, 133:2,
133:6, 133:15,
133:23, 135:2,
135:12, 135:17,
136:19, 136:20,
137:5, 137:18,
137:20, 137:24,
140:20, 141:24,
142:8, 142:21,
144:11, 144:21,
145:24, 148:20,
150:9, 150:18,
152:12
occurrences [1] -
135:7
October [6] - 1:4,
84:8, 89:14, 94:2,
122:18, 122:25
Odalys [9] - 45:23,
47:22, 48:6, 50:1,
51:6, 52:5, 63:13,
63:14, 64:1
OF [5] - 1:1, 1:3,
1:10, 1:15, 155:1
offense [1] - 32:18
offenses [3] - 27:22,
30:4, 30:6
offered [1] - 102:1
offering [1] - 101:23
Office [6] - 1:14,
1:16, 108:14,
112:3, 113:2,
148:16
officer [1] - 80:19
Official [2] - 1:21,
155:6
official [3] - 80:18,
80:21, 80:23
official's [1] - 80:21
Olga [2] - 4:8, 4:10
ON [1] - 1:15
once [1] - 46:14
one [99] - 3:3, 5:1,
8:22, 8:24, 11:2,
11:3, 11:19, 12:4,
13:12, 13:23,
14:24, 15:22,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 168 of
176
15:23, 15:24, 16:1,
16:10, 16:11,
16:15, 17:17,
18:15, 19:4, 24:2,
27:20, 29:6, 29:10,
29:22, 30:9, 31:12,
31:24, 32:6, 32:15,
33:7, 36:24, 39:5,
41:13, 42:17,
43:12, 45:9, 47:9,
51:2, 53:9, 53:11,
53:22, 54:12,
54:23, 57:6, 66:16,
69:16, 71:18,
72:12, 72:22,
75:15, 75:25, 82:9,
82:10, 82:15,
82:16, 83:19,
85:24, 88:23, 89:6,
90:8, 92:1, 99:5,
99:16, 100:5,
101:12, 101:20,
102:4, 105:17,
106:16, 110:23,
111:4, 113:6,
113:19, 114:17,
115:11, 116:4,
116:5, 118:4,
118:5, 120:21,
123:8, 123:19,
130:10, 130:14,
132:11, 148:11,
149:9, 149:12,
149:24, 150:6,
150:17, 152:21,
153:22, 154:19
one's [1] - 60:21
one-time [2] - 13:12,
150:17
ones [5] - 66:2,
104:15, 132:9,
138:4, 139:10
Onimer [1] - 17:24
online [3] - 92:24,
93:3, 93:7
open [3] - 46:9,
62:22, 76:22
opened [11] - 54:15,
57:22, 119:2,
121:9, 121:11,
123:22, 123:24,
145:19, 146:11,
147:7
opens [4] - 61:8,
61:10, 61:15, 61:25
operation [2] - 132:5,
138:2
operative [1] - 57:2
opposing [1] - 99:25
oral [1] - 55:3
order [2] - 139:8,
143:18
Order [1] - 3:1
original [1] - 75:13
originated [2] - 78:9,
78:21
otherwise [1] - 3:24
out-of-court [1] -
46:4
outside [3] - 3:13,
3:21, 8:16
overheard [2] - 8:2,
8:4
overlap [1] - 117:15
overruled [2] - 32:24,
47:3
overruling [1] - 57:21
overview [2] - 53:10,
64:5
own [2] - 54:12,
134:21
owned [17] - 110:2,
135:10, 136:7,
137:4, 137:22,
140:7, 142:15,
143:10, 144:2,
144:19, 145:8,
147:2, 148:16,
150:7, 150:22,
151:25, 152:14
owner [1] - 74:7
owns [1] - 149:12
P
P.A [1] - 1:16
Pacific [1] - 145:12
page [83] - 37:4, 40:3,
40:4, 40:11, 46:24,
47:5, 47:9, 50:8,
52:4, 53:13, 53:14,
59:24, 63:9, 63:22,
64:1, 84:2, 84:3,
84:7, 86:23, 86:24,
87:2, 89:1, 89:3,
89:8, 89:9, 89:11,
89:15, 90:13,
90:19, 91:23,
91:24, 92:3, 95:24,
95:25, 96:7, 96:15,
96:22, 97:4, 97:12,
97:20, 97:24, 98:3,
98:11, 99:1, 104:5,
104:6, 104:19,
105:3, 105:4,
105:9, 105:19,
105:20, 105:24,
107:9, 107:10,
111:23, 112:22,
118:6, 118:9,
121:3, 123:19,
123:21, 123:22,
125:10, 125:12,
125:21, 125:22,
126:2, 127:2,
127:3, 127:18,
127:19, 128:9,
128:10, 130:23,
131:24, 132:18,
140:18, 142:2
PAGE [1] - 2:2
Pages [1] - 1:8
pages [4] - 83:25,
105:25, 127:7,
127:24
paid [1] - 69:18
paper [1] - 103:8
paragraph [1] -
147:21
paralegal [1] - 1:19
pardon [1] - 21:19
part [10] - 27:19,
29:4, 33:24, 59:19,
63:11, 67:10, 70:7,
76:2, 80:24
participated [1] -
80:25
participation [1] -
81:3
particular [6] - 54:21,
80:10, 81:22,
83:17, 86:9, 93:7
parties [1] - 9:11
party [1] - 88:11
passcode [1] - 13:12
passing [1] - 8:6
password [4] - 116:2,
116:3, 116:4, 116:6
past [3] - 11:22,
11:24, 79:21
pay [3] - 88:10,
110:12, 110:14
payable [1] - 106:17
Paycheck [9] - 15:11,
40:13, 65:17,
65:20, 65:23, 66:1,
66:22, 67:10,
139:16
payment [2] - 88:8,
92:18
payroll [10] - 44:10,
74:8, 74:10, 74:12,
74:24, 104:12,
105:14, 105:23,
106:11, 106:18
PDF [1] - 91:9
people [8] - 11:12,
17:22, 24:5, 31:18,
31:20, 32:22,
100:11, 152:3
per [1] - 143:23
percent [2] - 5:18,
5:22
perfect [1] - 46:10
perform [2] - 93:11,
141:21
perhaps [2] - 3:24,
10:7
period [25] - 48:14,
83:17, 83:21, 84:6,
84:9, 86:9, 86:14,
86:18, 89:1, 89:13,
89:15, 90:11,
90:15, 91:12,
125:24, 126:2,
126:6, 126:16,
126:23, 127:5,
127:9, 127:15,
127:22, 128:13,
128:20
permanently [3] -
73:1, 73:3, 73:9
permission [1] -
130:6
persisting [1] -
153:24
person [42] - 4:19,
4:22, 5:6, 5:10,
5:16, 5:17, 5:19,
5:21, 5:22, 5:23,
5:25, 6:4, 6:5, 6:21,
6:22, 7:3, 7:9, 7:21,
7:25, 8:5, 8:8, 8:14,
8:16, 8:22, 8:25,
9:8, 9:22, 11:3,
12:17, 13:5, 13:22,
21:14, 22:6, 26:20,
27:13, 45:20,
45:22, 66:13,
66:16, 75:25
person's [2] - 5:8,
7:23
Persona [17] -
129:15, 134:19,
136:9, 136:22,
138:23, 139:1,
139:9, 141:15,
143:5, 143:19,
143:21, 144:24,
149:17, 150:13,
150:24, 151:3,
152:18
personal [3] - 5:10,
50:23, 51:1
Philip [1] - 130:24
phone [55] - 27:1,
116:5, 116:8,
116:25, 117:2,
117:6, 124:25,
Lance W. Steinbeisser - Federal Certified Realtime Reporter
169
125:3, 126:5,
126:11, 126:12,
126:15, 126:21,
126:22, 127:9,
127:10, 127:13,
128:2, 128:6,
128:20, 128:22,
128:24, 129:1,
129:4, 134:22,
134:24, 135:22,
136:4, 136:23,
137:1, 137:7,
138:16, 139:12,
140:2, 141:3,
141:5, 141:7,
141:17, 143:7,
143:22, 144:6,
144:22, 144:23,
149:14, 149:18,
150:10, 150:11,
150:17, 150:19,
151:18, 151:19,
151:21
photographs [2] -
139:10, 151:22
photos [12] - 136:12,
138:13, 139:8,
139:9, 141:14,
143:4, 143:18,
144:24, 149:19,
150:13, 151:3,
152:18
pictures [5] - 136:24,
143:5, 143:9,
143:22, 143:24
places [1] - 116:5
Plaintiff [1] - 1:4
plan [1] - 60:21
platforms [1] - 93:4
plea [1] - 29:4
pleased [1] - 99:14
pleasing [1] - 34:24
pled [4] - 27:21,
28:11, 29:12, 67:11
plus [2] - 60:1, 60:3
PM [45] - 1:6, 58:4,
58:8, 58:10, 58:15,
99:9, 99:11, 99:12,
99:13, 99:18,
100:4, 103:18,
119:5, 119:19,
119:21, 120:8,
120:10, 120:12,
120:14, 121:10,
121:14, 121:18,
122:2, 122:4,
122:6, 122:19,
122:25, 124:2,
124:4, 124:8,
124:14, 124:18,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 169 of
176
132:4, 137:9,
138:10, 138:22,
138:23, 146:19,
150:14, 153:2,
154:24
podium [3] - 39:12,
46:19, 108:12
point [8] - 11:2,
44:23, 55:2, 76:7,
99:21, 153:7,
154:9, 154:16
politician [1] - 80:18
portal [23] - 94:8,
130:17, 130:22,
132:9, 132:10,
132:16, 133:4,
133:18, 133:24,
135:3, 136:18,
137:19, 141:12,
141:25, 142:1,
142:9, 144:12,
148:13, 148:20,
149:7, 150:6,
150:17, 152:11
portion [2] - 65:6,
154:15
position [8] - 6:14,
42:7, 59:4, 61:17,
62:2, 62:3, 62:5,
76:9
possible [1] - 46:14
possibly [1] - 19:8
posture [1] - 45:1
pot [1] - 110:14
PowerPoint [1] -
103:10
PPP [88] - 11:15,
13:10, 17:21, 23:4,
24:22, 26:14, 27:7,
36:4, 38:25, 41:22,
42:10, 42:21,
42:22, 43:9, 43:25,
44:8, 45:5, 51:2,
53:25, 56:17,
59:21, 65:15, 66:6,
67:15, 67:21, 69:3,
69:5, 69:8, 69:10,
74:8, 75:4, 75:10,
75:15, 75:16,
75:22, 76:10, 78:1,
78:8, 78:16, 78:20,
82:2, 82:4, 82:15,
87:7, 87:9, 87:14,
88:8, 88:10, 88:11,
90:24, 91:16,
92:12, 92:16,
98:23, 104:1,
106:2, 106:4,
106:10, 108:6,
113:12, 113:14,
113:15, 114:1,
114:12, 118:3,
120:20, 121:21,
122:21, 123:6,
131:20, 132:20,
133:6, 133:16,
133:23, 135:3,
137:19, 142:22,
144:12, 145:5,
145:23, 145:25,
146:4, 146:22,
147:8, 147:14,
147:19, 148:5,
150:2
preceding [1] - 91:3
predicted [1] -
153:17
prediction [1] - 99:16
preface [1] - 76:9
prepare [4] - 14:13,
17:11, 20:5, 35:1
prepared [9] - 14:6,
17:10, 18:2, 25:8,
25:9, 68:6, 73:14,
155:3
preparing [3] - 16:14,
67:7, 67:9
present [1] - 9:3
PRESENT [1] - 1:18
presented [1] - 58:23
presenting [1] - 86:1
presently [1] - 49:22
pretenses [2] -
30:12, 30:13
pretty [3] - 33:12,
61:3, 99:15
previous [2] -
128:22, 146:10
previously [2] -
73:24, 94:25
primary [1] - 74:7
principal [3] - 110:4,
111:1, 111:5
print [2] - 52:8, 52:14
printable [2] -
122:17, 122:24
printed [3] - 52:24,
52:25, 64:23
printing [1] - 52:18
prison [2] - 34:13,
34:16
problem [4] - 5:2,
5:3, 5:12, 51:14
problems [2] - 51:15,
51:16
proceed [7] - 3:14,
3:18, 46:21, 62:23,
73:18, 76:23, 77:1
proceeding [1] - 10:6
Proceedings [2] -
1:24, 154:24
proceedings [7] -
41:6, 46:9, 62:10,
62:22, 73:22,
76:22, 155:3
proceeds [13] - 82:2,
82:3, 82:15, 87:9,
88:8, 88:10, 90:24,
98:23, 104:1,
106:2, 106:3,
107:16, 108:5
process [17] - 11:21,
13:4, 19:18, 25:14,
25:21, 42:24, 43:3,
43:14, 43:19,
43:25, 45:11,
45:13, 45:17, 68:2,
85:21, 85:24, 102:7
processed [3] - 26:8,
42:14, 44:1
processing [4] -
27:7, 27:11,
147:15, 149:24
produced [2] - 1:25,
98:14
program [5] - 7:6,
39:23, 42:20,
42:21, 67:15
Program [9] - 15:11,
40:14, 65:18,
65:21, 65:24, 66:1,
66:23, 67:10,
139:16
programmer [1] -
6:15
programs [1] - 6:2
projected [1] - 55:13
promises [2] - 30:12,
30:13
property [1] - 31:7
proposed [1] -
153:23
proprietors [1] -
43:22
Protection [9] -
15:11, 40:13,
65:18, 65:20,
65:23, 66:1, 66:22,
67:10, 139:16
prove [1] - 79:2
proven [1] - 79:6
provide [6] - 95:4,
111:9, 111:20,
112:11, 112:13,
121:6
provided [3] - 33:25,
116:22, 150:23
Public [1] - 80:13
public [5] - 80:15,
80:18, 80:21, 80:22
publish [13] - 37:17,
39:22, 39:23,
49:16, 63:1, 77:3,
77:10, 104:4,
107:6, 107:23,
109:12, 130:6,
130:8
published [2] - 77:6,
77:12
publishing [14] -
83:7, 86:5, 88:16,
90:5, 93:13, 114:7,
114:8, 115:4,
117:22, 117:23,
120:15, 123:1,
125:9, 126:25
punishable [3] -
32:8, 32:11, 32:14
punishment [1] -
32:18
purportedly [1] -
74:13
purpose [13] - 31:2,
31:5, 31:6, 43:14,
43:25, 70:19,
70:22, 71:2, 71:10,
71:13, 72:10, 75:16
purposes [1] - 59:6
pursuant [2] - 58:25,
98:14
put [6] - 16:1, 39:22,
45:2, 83:4, 129:10,
130:3
putting [3] - 62:20,
106:25, 125:11
Q
questions [16] - 6:7,
8:18, 16:3, 33:23,
39:8, 40:8, 41:11,
56:5, 61:25, 62:17,
66:10, 67:17,
67:20, 69:24, 70:4,
72:24
quick [1] - 154:19
quickly [3] - 46:16,
62:9, 118:2
quite [2] - 24:8, 46:6
R
ran [1] - 147:19
range [3] - 93:25,
132:2, 137:6
re [6] - 61:24
read [6] - 64:4, 77:2,
83:10, 91:9,
128:16, 133:10
Lance W. Steinbeisser - Federal Certified Realtime Reporter
170
reading [1] - 130:19
reads [1] - 77:13
ready [5] - 3:14, 3:17,
3:18, 76:23, 153:15
really [3] - 41:24,
55:22, 76:13
reason [5] - 20:3,
42:2, 44:21, 55:18,
154:15
reasonable [2] -
79:3, 79:6
rebut [1] - 54:19
rebuts [2] - 54:18,
55:4
receipt [5] - 87:13,
91:5, 91:16, 98:22,
106:10
receive [19] - 11:15,
41:13, 42:1, 43:24,
44:16, 47:5, 47:14,
48:25, 49:9, 50:6,
59:12, 81:10,
81:12, 82:3, 82:12,
93:6, 117:8,
117:17, 148:9
received [73] - 11:12,
15:21, 21:23,
29:19, 29:20,
37:15, 37:16,
39:21, 42:15,
42:19, 42:23,
44:16, 46:23, 47:7,
47:8, 48:3, 48:12,
48:13, 48:18, 49:1,
51:18, 51:22,
51:25, 52:3, 52:23,
56:7, 56:8, 56:9,
56:18, 63:2, 63:12,
63:13, 63:16, 64:1,
64:22, 67:25, 71:4,
71:5, 72:1, 72:3,
72:14, 79:11, 82:1,
82:15, 83:21,
84:10, 85:7, 85:14,
85:18, 87:10, 89:5,
89:16, 101:19,
102:9, 102:10,
103:25, 106:1,
106:3, 106:5,
107:16, 108:5,
109:22, 124:11,
124:17, 129:8,
137:13, 138:11,
139:15, 145:21,
146:16, 147:25,
149:20, 152:3
receives [5] - 43:12,
43:13, 55:20, 55:21
receiving [5] - 36:9,
50:11, 52:18, 56:4,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 170 of
176
65:3
recently [1] - 137:14
recess [2] - 61:5,
100:4
Recess [1] - 61:6
recessing [1] -
152:20
recognize [14] - 12:9,
12:12, 12:14,
12:16, 12:17,
12:18, 12:19, 15:4,
15:8, 36:17, 39:24,
49:23, 63:6, 109:18
recognized [1] - 3:4
recollection [7] -
12:25, 13:2, 14:4,
15:20, 17:9, 25:2,
70:5
recommend [1] -
34:20
record [37] - 48:23,
48:24, 50:9, 55:1,
64:17, 74:19, 76:2,
76:5, 77:3, 77:12,
79:16, 89:3, 89:6,
93:10, 94:1, 94:3,
115:14, 116:23,
119:22, 120:4,
123:11, 130:24,
131:9, 131:11,
131:24, 132:18,
133:8, 133:19,
134:19, 138:23,
142:3, 143:21,
143:23, 145:14,
149:17, 150:25,
155:3
recorded [1] - 1:24
records [49] - 26:13,
58:25, 59:5, 59:6,
59:24, 59:25, 79:5,
81:10, 81:12,
81:15, 81:17,
81:19, 82:8, 82:11,
82:14, 82:18,
82:19, 82:21,
86:12, 93:2, 93:6,
94:25, 98:14,
111:13, 112:4,
115:8, 117:8,
117:11, 117:13,
117:17, 117:20,
124:19, 124:22,
124:23, 124:25,
125:3, 125:13,
125:16, 125:24,
129:8, 129:13,
129:15, 129:17,
130:15, 134:12,
136:22, 139:1
recovery [2] - 115:22,
116:22
recross [5] - 61:8,
61:16, 61:19,
61:22, 62:12
Recross [1] - 2:5
RECROSS [1] - 70:1
Recross-
Examination [1] -
2:5
RECROSS-
EXAMINATION [1] -
70:1
redirect [4] - 39:10,
54:11, 58:17, 61:22
Redirect [2] - 2:4, 2:5
REDIRECT [1] -
39:14
reduction [2] - 34:2,
34:20
Reemployment [4] -
110:12, 110:13,
111:18, 112:17
refer [4] - 8:4, 80:3,
85:20, 132:9
reference [5] - 3:6,
44:22, 45:9, 53:11,
59:24
referenced [2] - 74:4,
85:7
references [1] -
45:10
referred [2] - 78:1,
78:16
refers [1] - 130:15
reflected [2] - 72:15,
93:7
refresh [5] - 14:4,
15:20, 17:9, 25:2,
70:5
regard [1] - 54:19
regarding [7] - 9:11,
12:17, 14:8, 22:21,
77:18, 147:14,
154:19
reimbursement [1] -
104:23
relate [6] - 40:13,
40:23, 41:13,
74:12, 80:17,
131:20
related [8] - 40:19,
41:22, 42:19, 45:4,
51:3, 72:19, 110:2,
112:2
relates [5] - 41:2,
42:9, 45:3, 67:14,
113:1
relating [3] - 58:18,
70:4, 112:1
relation [1] - 135:3
relationship [1] -
5:24
relevance [2] - 75:1,
76:3
relevancy [1] - 53:10
relevant [10] - 59:13,
59:15, 59:18, 60:3,
60:4, 74:14, 74:15,
75:1, 75:6, 76:14
remember [60] - 7:6,
7:16, 7:25, 8:1,
8:12, 12:4, 12:10,
13:4, 13:5, 13:7,
13:8, 13:22, 14:8,
14:11, 14:15,
14:16, 14:23, 15:5,
15:6, 15:7, 15:22,
15:23, 16:14, 18:8,
22:1, 22:6, 22:10,
22:11, 22:15,
22:17, 22:19,
22:20, 23:13,
23:15, 23:16,
23:19, 24:1, 26:25,
27:1, 27:2, 27:4,
27:5, 27:6, 27:8,
27:17, 36:5, 36:9,
38:25, 40:1, 40:6,
40:8, 50:11, 66:21,
67:4, 67:6, 67:18,
72:3, 138:11,
148:14, 152:25
remembered [1] -
8:12
remind [1] - 79:24
reminding [2] -
100:16, 148:5
renewal [1] - 31:4
repeat [1] - 84:17
rephrase [2] - 25:11,
26:10
report [2] - 111:25,
118:20
REPORTER [1] -
155:1
Reporter [2] - 1:21,
155:6
reporter [1] - 3:5
Reporter..................
........ [1] - 2:8
reports [2] - 111:19,
112:17
represent [2] - 83:24,
89:15
representation [1] -
30:12
representations [1] -
30:13
represented [5] -
74:23, 113:24,
114:5, 114:16,
115:2
represents [3] - 44:9,
74:9, 74:10
request [12] - 10:3,
34:1, 38:13, 47:12,
70:9, 71:8, 71:11,
110:6, 111:7,
111:9, 147:18,
150:1
requested [2] -
38:12, 112:1
reserve [2] - 76:18,
102:17
residence [2] -
149:11, 150:24
respect [30] - 7:3,
7:21, 10:23, 26:19,
27:16, 36:4, 56:11,
59:5, 68:9, 68:21,
69:3, 69:8, 69:13,
73:16, 75:21,
76:10, 81:24,
89:21, 94:11,
104:15, 109:9,
111:11, 111:15,
111:20, 118:21,
127:13, 144:6,
146:7, 149:16,
154:5
respective [3] -
77:21, 129:5,
147:13
respectively [1] -
129:4
respond [1] - 45:10
response [3] - 93:6,
95:3, 111:16
responsibility [1] -
67:13
responsible [1] -
10:14
rest [2] - 60:10, 60:20
result [1] - 81:9
resulted [1] - 80:25
resume [2] - 58:16,
99:9
retired [2] - 5:3, 5:5
return [2] - 8:20,
73:11
returned [1] - 28:23
returns [2] - 74:19,
109:21
Revenue [9] - 109:21,
109:24, 111:12,
111:17, 111:25,
112:10, 112:14,
112:16, 112:25
review [8] - 61:24,
Lance W. Steinbeisser - Federal Certified Realtime Reporter
171
81:14, 82:21, 94:3,
102:21, 103:12,
106:5, 129:11
reviewed [1] - 99:25
right-hand [1] -
143:20
risks [1] - 62:16
Rivera [2] - 18:13,
20:11
RIVERO [1] - 2:3
Rivero [33] - 3:10,
3:13, 3:22, 11:9,
20:9, 20:10, 21:1,
21:4, 21:14, 21:16,
22:6, 23:3, 23:8,
29:25, 36:1, 38:23,
39:8, 39:9, 39:16,
43:13, 46:23, 54:1,
63:1, 64:19, 64:21,
65:17, 65:23,
66:17, 66:20, 69:2,
70:3, 74:5
Rodriguez's [1] -
148:15
Rogers [2] - 23:14,
23:17
role [3] - 10:8, 67:9,
69:13
room [1] - 101:25
rounding [1] - 20:19
row [1] - 124:15
RPR [2] - 1:21, 155:6
rule [11] - 9:25, 10:1,
10:3, 10:4, 10:13,
10:16, 10:24, 11:4,
59:16, 85:11
Rules [1] - 79:4
ruling [2] - 44:23,
73:25
runs [1] - 83:19
S
S21 [11] - 126:17,
126:22, 128:25,
134:9, 134:24,
136:4, 137:8,
138:17, 139:12,
149:15, 150:10
salary [12] - 95:17,
96:2, 96:10, 96:17,
96:24, 97:7, 97:15,
97:23, 98:2, 98:6,
98:19, 108:10
salon [3] - 37:6,
38:10, 108:4
savings [1] - 87:22
Savings [1] - 78:4
saw [3] - 45:18, 99:5,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 171 of
176
123:10
SBA [7] - 31:10, 32:3,
55:11, 65:10,
77:25, 78:15,
147:16
scenario [2] - 56:3,
62:14
Schedule [26] - 14:6,
14:10, 14:13,
16:14, 17:3, 17:5,
17:10, 17:11, 18:2,
18:5, 18:25, 19:9,
19:16, 20:6, 25:5,
25:8, 25:20, 26:14,
27:18, 66:25, 67:9,
68:6, 68:12, 69:15,
69:16
schedule [5] - 60:10,
61:4, 99:13, 99:16,
154:5
scheduling [1] -
154:19
scheme [2] - 30:10,
100:24
screen [73] - 30:15,
53:15, 63:4, 63:23,
70:8, 71:22, 83:8,
84:4, 86:7, 86:24,
90:6, 90:21, 93:14,
95:10, 107:7,
107:25, 109:14,
109:16, 113:7,
113:9, 114:7,
114:9, 115:4,
116:14, 117:22,
117:24, 118:16,
118:19, 120:16,
120:17, 120:24,
123:1, 123:2,
123:14, 125:10,
125:11, 126:15,
126:25, 127:17,
127:19, 130:11,
134:13, 134:18,
135:9, 135:24,
136:1, 136:23,
136:25, 137:22,
140:21, 140:25,
141:13, 142:4,
142:14, 142:17,
143:20, 143:24,
144:1, 144:18,
144:25, 145:3,
145:7, 146:2,
146:21, 147:1,
148:14, 148:18,
150:12, 150:20,
150:25, 151:4,
151:8, 152:14
screens [1] - 70:8
scrolling [1] - 123:21
search [3] - 83:4,
112:11, 112:14
seat [1] - 100:15
seated [3] - 4:12,
46:18, 62:13
Second [20] - 13:17,
14:22, 15:13,
15:14, 15:21, 16:6,
20:15, 20:20,
20:23, 21:1, 21:9,
21:25, 23:12,
23:25, 67:18,
67:25, 68:3, 68:7,
68:17, 68:21
second [20] - 13:23,
15:23, 18:24, 37:4,
67:25, 68:9, 68:20,
92:1, 92:3, 111:15,
111:23, 120:9,
120:20, 122:3,
122:20, 123:21,
139:7, 143:17,
146:23, 147:16
Section [1] - 31:8
section [12] - 64:3,
64:4, 64:6, 64:10,
64:15, 113:15,
113:20, 114:1,
114:13, 114:19,
114:24, 115:22
security [2] - 111:10,
112:12
see [127] - 10:14,
10:17, 24:19,
24:22, 25:22,
26:16, 30:6, 30:7,
36:24, 37:2, 37:3,
37:7, 37:24, 40:4,
42:4, 49:7, 50:9,
51:12, 53:14,
53:15, 62:3, 63:4,
63:22, 64:6, 64:8,
64:10, 64:13,
64:15, 83:1, 83:8,
84:3, 84:23, 85:2,
86:7, 86:24, 87:2,
87:4, 87:6, 87:19,
87:21, 88:2, 88:17,
89:1, 89:9, 89:13,
89:23, 90:1, 90:6,
90:21, 91:11,
91:17, 91:21,
91:23, 93:14,
93:19, 94:14,
95:10, 95:20, 97:5,
98:4, 98:18, 98:22,
98:25, 103:16,
104:5, 104:20,
105:3, 105:11,
105:20, 106:9,
106:16, 107:7,
107:9, 107:24,
109:14, 109:15,
109:16, 113:7,
113:8, 114:9,
115:6, 115:22,
117:25, 120:17,
120:25, 122:7,
122:10, 122:23,
126:8, 126:18,
128:10, 130:11,
130:20, 131:2,
131:17, 131:24,
132:5, 132:14,
134:2, 135:1,
135:6, 135:23,
136:20, 136:25,
137:3, 137:13,
137:19, 138:2,
140:1, 141:13,
142:18, 143:5,
143:20, 144:21,
144:25, 146:11,
148:19, 149:6,
149:25, 150:5,
150:8, 150:12,
151:5, 153:24,
154:1, 154:12
seeing [3] - 40:1,
40:6, 136:9
seeking [1] - 42:12
seem [1] - 33:22
sees [2] - 9:13, 9:16
self [1] - 59:16
self-authenticating
[1] - 59:16
selfie [12] - 134:20,
136:11, 136:24,
138:13, 139:8,
141:14, 143:4,
143:18, 144:24,
149:19, 151:2,
151:21
selfies [2] - 138:15,
144:7
send [8] - 36:3,
47:17, 52:7, 70:21,
71:1, 72:4, 116:3,
153:20
sending [1] - 54:16
sends [1] - 68:19
sent [32] - 36:19,
37:8, 37:21, 38:9,
38:16, 40:21,
43:17, 50:4, 52:6,
70:12, 70:18,
70:24, 71:11,
71:14, 71:15,
71:16, 71:17, 72:5,
72:15, 72:19,
72:20, 116:6,
122:11, 123:8,
135:20, 135:21,
139:19, 140:2,
147:11, 148:4,
149:22, 150:17
sentence [5] - 34:2,
34:3, 34:10, 34:20,
147:21
separate [11] - 31:9,
32:1, 42:10, 43:9,
43:22, 44:8, 53:21,
54:7, 54:23, 54:25,
75:5
separately [3] - 75:9,
75:24, 147:25
September [1] - 79:7
sequestration [1] -
10:4
serve [1] - 9:14
service [1] - 150:23
serving [1] - 10:7
session [2] - 58:5,
99:11
set [2] - 39:12, 76:25
seven [1] - 135:1
seventh [1] - 4:21
several [3] - 58:5,
74:11, 75:2
sheet [1] - 146:15
Sheriff's [5] - 108:14,
112:3, 113:2,
148:16, 148:17
short [1] - 135:20
short-lived [1] -
135:20
show [12] - 25:24,
26:13, 29:8, 45:20,
49:21, 54:4, 74:16,
75:11, 123:22,
131:11, 147:7
showed [3] - 18:5,
39:19, 74:5
showing [14] - 12:8,
14:2, 15:2, 16:19,
18:17, 22:22,
24:18, 28:3, 70:6,
71:22, 74:13,
130:24, 138:14,
149:1
shown [3] - 14:10,
40:20, 102:7
shows [12] - 43:9,
54:6, 54:8, 54:25,
75:3, 75:5, 75:6,
132:11, 145:19,
146:15, 146:16,
148:12
shut [1] - 3:5
Lance W. Steinbeisser - Federal Certified Realtime Reporter
172
side [54] - 8:24,
10:14, 11:3, 73:2,
109:12, 109:13,
109:14, 109:15,
109:16, 110:16,
112:6, 113:5,
113:6, 113:7,
113:8, 113:13,
114:7, 114:8,
115:4, 115:5,
115:11, 116:14,
117:22, 117:23,
118:16, 118:19,
120:15, 120:16,
120:24, 123:1,
123:2, 123:13,
123:17, 125:10,
125:11, 125:20,
125:21, 125:25,
126:15, 126:25,
127:2, 127:17,
127:18, 128:11,
143:20, 144:25,
145:3, 145:7,
146:2, 146:21,
147:1, 148:14
sidebar [10] - 41:4,
41:5, 41:6, 55:13,
62:8, 62:10, 73:20,
73:21, 73:22,
154:19
sign [2] - 27:16,
146:24
signed [16] - 79:8,
79:10, 106:17,
119:20, 119:23,
121:17, 121:19,
124:3, 124:5,
124:9, 145:5,
145:12, 145:20,
145:25, 146:12,
147:8
signer [1] - 122:7
signifies [1] - 136:4
signing [16] - 118:25,
120:2, 120:3,
120:7, 120:9,
120:11, 120:13,
121:7, 121:22,
122:1, 122:3,
122:5, 145:4,
146:8, 146:14,
147:5
signs [1] - 146:4
similar [2] - 99:22,
134:24
similarities [3] -
94:16, 94:17, 94:21
simpler [1] - 85:25
simply [5] - 10:5,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 172 of
176
10:14, 55:10,
101:2, 154:23
sister [2] - 16:12,
16:25
six [3] - 133:21,
133:22, 138:1
slide [54] - 130:10,
130:14, 131:17,
131:18, 132:14,
133:1, 133:13,
133:21, 133:22,
135:1, 135:15,
136:15, 136:16,
137:12, 137:16,
137:17, 138:9,
138:14, 139:6,
139:14, 139:22,
139:23, 140:15,
140:16, 141:9,
141:23, 142:6,
142:7, 143:2,
143:12, 143:15,
144:9, 145:1,
145:14, 145:24,
146:7, 146:10,
146:19, 147:4,
147:10, 148:3,
148:10, 149:4,
149:20, 150:3,
150:14, 151:10,
152:2, 152:9
slides [3] - 101:20,
138:11, 139:2
SM [18] - 134:3,
134:6, 134:22,
134:23, 136:3,
136:22, 138:17,
139:12, 141:2,
141:3, 141:16,
143:6, 143:22,
144:22, 150:9,
150:19, 152:17
SM-G998U [11] -
134:3, 134:6,
134:22, 134:23,
136:3, 136:22,
138:17, 139:12,
150:9, 152:17
SM-N986U [7] -
141:2, 141:3,
141:16, 143:6,
143:22, 144:22,
150:19
Small [4] - 31:6, 78:1,
87:7, 129:17
SmartBiz [4] - 65:8,
65:9, 65:15, 74:3
SmartBiz's [1] -
65:11
Smith [1] - 1:19
SNIDER [148] - 1:13,
3:9, 3:13, 3:17,
3:20, 4:2, 8:25,
9:13, 9:18, 10:19,
10:23, 11:2, 19:11,
25:10, 26:9, 29:18,
32:16, 32:23,
35:16, 37:14,
39:11, 39:15, 41:9,
41:15, 42:6, 42:9,
42:15, 42:18,
42:21, 42:25, 43:3,
43:8, 43:11, 43:15,
44:2, 44:6, 44:13,
44:16, 44:19,
45:14, 45:18,
45:23, 46:1, 46:7,
46:19, 46:22, 47:1,
47:4, 47:20, 48:12,
48:16, 48:20,
48:23, 49:3, 49:8,
49:15, 49:19,
50:21, 50:25,
51:17, 51:22, 52:2,
52:4, 52:10, 53:5,
53:12, 53:15,
53:21, 54:3, 54:9,
54:15, 54:23, 55:1,
55:5, 56:4, 56:7,
56:10, 56:14,
56:16, 56:21,
56:24, 57:6, 58:1,
58:16, 58:21,
58:24, 59:4, 59:9,
59:14, 59:19,
59:23, 60:6, 60:8,
60:10, 60:13,
60:16, 60:19,
61:13, 61:21, 62:2,
62:21, 62:23,
62:25, 69:1, 69:24,
72:24, 73:2, 73:14,
73:20, 73:23, 74:2,
74:15, 74:18,
74:22, 75:1, 75:13,
76:3, 76:16, 76:23,
77:11, 79:12,
79:20, 84:18,
84:21, 84:22, 85:9,
86:3, 86:4, 88:14,
99:20, 99:24,
101:9, 101:14,
101:16, 102:2,
103:9, 103:15,
103:20, 103:21,
125:20, 125:23,
130:6, 130:9,
153:5, 153:9,
153:13, 154:1,
154:4
Snider [1] - 79:8
Snider............... [2] -
2:4, 2:5
Snider................. [1]
- 2:7
snippet [1] - 134:20
social [2] - 111:10,
112:12
sole [1] - 43:22
someone [12] - 3:4,
4:16, 5:1, 8:4, 10:7,
25:8, 25:9, 44:6,
44:7, 47:23, 48:21,
51:10
sometimes [2] -
52:14, 77:6
soon [1] - 46:14
sorry [19] - 16:4,
20:18, 21:22, 29:8,
33:22, 35:21, 36:1,
41:20, 48:20, 57:7,
58:3, 60:20, 84:17,
91:8, 95:18,
119:14, 125:18,
128:18, 142:12
Sorry [1] - 99:3
sort [1] - 85:16
sound [1] - 83:25
sounds [1] - 9:9
source [3] - 131:2,
131:7, 131:9
South [2] - 110:24,
111:12
Southern [2] - 77:15,
155:7
SOUTHERN [1] - 1:1
speaking [2] - 10:9,
27:1
special [5] - 10:8,
79:24, 80:1, 80:8,
80:15
Special [2] - 10:24,
76:24
speeding [1] - 101:3
spell [1] - 79:15
spend [1] - 85:23
spent [1] - 7:24
spoken [1] - 5:7
squad [3] - 80:10,
80:12, 80:16
Squad [1] - 80:14
staff [3] - 6:3, 7:17
stand [1] - 3:10
start [8] - 64:19,
86:18, 95:9, 100:9,
101:3, 104:5,
115:11, 152:23
started [7] - 6:24,
6:25, 19:14, 50:17,
50:19, 51:8, 64:11
starting [3] - 13:4,
29:24, 58:5
starts [1] - 58:7
state [5] - 78:10,
78:13, 78:22,
78:24, 79:15
statement [17] - 31:2,
83:17, 83:21,
83:24, 84:6, 86:9,
86:11, 86:14,
86:17, 87:12, 88:3,
88:7, 88:20, 89:1,
89:13, 90:11
statements [11] -
31:9, 84:10, 84:19,
84:23, 85:2, 89:5,
89:16, 89:22, 90:1,
90:8, 112:2
STATES [3] - 1:1,
1:3, 1:11
states [3] - 74:6,
144:1, 145:8
States [18] - 1:14,
1:22, 27:22, 27:23,
30:4, 30:5, 30:21,
31:6, 31:8, 77:4,
77:15, 77:17,
77:20, 79:1, 79:2,
79:8, 79:9, 155:7
stating [3] - 51:8,
68:19, 137:4
status [2] - 147:17,
149:25
statuses [1] - 147:22
stay [2] - 58:13,
154:16
steal [1] - 24:5
STEINBEISSER [1] -
1:21
Steinbeisser [2] -
155:5, 155:5
stenography [1] -
1:24
stenotype [1] - 155:3
step [3] - 59:12, 73:5,
153:3
Step [5] - 37:6, 38:9,
38:20, 65:21, 108:3
Steve [1] - 12:24
still [10] - 61:4,
104:17, 108:18,
108:24, 137:16,
140:15, 142:6,
147:15, 149:24,
150:14
stipulate [3] - 77:8,
77:22, 79:1
stipulation [6] - 77:3,
77:6, 77:9, 77:13,
77:18, 79:7
stolen [1] - 21:11
Lance W. Steinbeisser - Federal Certified Realtime Reporter
173
stop [2] - 99:7,
152:19
subject [4] - 41:23,
53:13, 55:21, 63:18
submitted [2] - 51:2,
75:2
subpoena [7] - 73:7,
81:22, 82:6, 93:6,
98:15, 117:8,
124:19
subpoenaed [2] -
81:19, 124:22
subpoenas [4] -
81:6, 81:9, 95:3,
129:9
subscriber [2] -
115:9, 123:11
subsequent [1] -
62:15
substantial [1] -
33:25
substantively [1] -
59:10
successful [5] -
11:12, 14:20,
131:15, 139:9,
143:17
successfully [1] -
13:15
summarize [2] -
85:16, 147:13
summarized [1] -
94:21
summary [4] - 85:12,
85:16, 85:21, 90:14
SunTrust [4] -
107:14, 107:19,
108:3, 108:10
superseding [3] -
77:24, 78:2, 78:14
supervisory/
advisory [1] - 7:2
support [1] - 76:5
supposed [1] - 5:15
surface [1] - 61:18
surrounding [1] -
9:12
sustained [4] - 19:12,
68:25, 76:15, 88:13
sworn [1] - 79:14
system [1] - 7:12
T
table [4] - 103:10,
131:7, 135:25,
140:25
Tax [4] - 110:12,
110:13, 111:18,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 173 of
176
112:17
tax [1] - 74:19
team [2] - 80:24,
81:14
tee [1] - 59:19
temporary [2] -
116:3, 116:6
ten [10] - 5:3, 5:6,
8:7, 98:11, 98:15,
98:20, 113:25,
114:6, 132:23,
137:12
ten-page [1] - 98:11
terms [1] - 119:8
testified [14] - 40:16,
43:20, 45:2, 45:3,
54:9, 65:13, 66:3,
68:2, 68:5, 68:16,
70:18, 71:19,
71:23, 92:12
testifies [3] - 58:19,
76:19, 103:4
testify [6] - 13:14,
34:19, 40:18,
41:19, 48:17, 85:12
testifying [1] - 73:24
testimony [18] -
10:10, 10:12,
25:10, 34:24, 35:2,
46:5, 48:11, 53:19,
54:14, 55:22,
60:14, 76:1, 76:24,
77:7, 79:5, 102:22,
145:15, 148:15
Texas [2] - 78:13,
78:25
Thakral [1] - 131:19
THE [235] - 1:10,
1:12, 1:15, 3:2,
3:12, 3:15, 3:19,
3:23, 4:5, 4:8, 4:12,
4:14, 5:14, 5:23,
6:6, 7:23, 8:4, 8:9,
8:19, 8:22, 9:5, 9:8,
9:15, 9:17, 9:19,
9:21, 10:1, 10:3,
10:20, 10:22, 11:1,
11:3, 12:6, 13:25,
16:3, 16:17, 19:12,
25:11, 26:10, 28:1,
29:17, 29:19,
30:15, 30:16,
30:17, 32:15,
32:17, 32:24,
35:11, 35:13,
35:18, 36:7, 37:12,
37:15, 37:18,
39:10, 41:4, 41:7,
41:10, 41:16,
41:20, 41:24, 42:8,
42:14, 42:17,
42:19, 42:22, 43:1,
43:6, 43:10, 43:12,
43:23, 44:4, 44:12,
44:15, 44:18, 45:8,
45:16, 45:22,
45:24, 46:4, 46:8,
46:10, 46:18,
46:20, 47:2, 47:12,
47:13, 47:14,
47:16, 47:23,
47:25, 48:3, 48:6,
48:8, 48:10, 48:11,
48:13, 48:19,
48:21, 48:24, 49:7,
49:17, 50:19,
50:23, 51:5, 51:6,
51:9, 51:11, 51:12,
51:13, 51:14,
51:25, 52:3, 52:7,
52:8, 52:23, 52:24,
52:25, 53:1, 53:2,
53:3, 53:4, 53:8,
53:14, 53:17, 54:2,
54:8, 54:14, 54:19,
54:24, 55:2, 55:7,
55:14, 55:16,
55:19, 56:2, 56:6,
56:8, 56:12, 56:15,
56:18, 56:23, 57:1,
57:7, 57:10, 57:13,
57:16, 57:18,
57:20, 57:22, 58:2,
58:4, 58:20, 58:22,
59:2, 59:8, 59:11,
59:15, 59:22, 60:3,
60:7, 60:9, 60:12,
60:14, 60:17,
60:21, 61:1, 61:10,
61:14, 61:17,
61:23, 62:3, 62:8,
62:11, 62:20,
62:24, 68:25, 73:1,
73:3, 73:5, 73:10,
73:12, 73:13,
73:19, 73:21, 74:1,
74:14, 74:16,
74:21, 74:25,
75:12, 76:1, 76:4,
76:13, 76:20, 77:5,
79:11, 79:15,
79:17, 85:6, 85:10,
88:13, 99:7, 99:19,
99:23, 99:25,
100:3, 100:5,
100:15, 100:19,
100:24, 101:2,
101:6, 101:8,
101:12, 101:15,
101:22, 102:3,
102:5, 102:12,
102:23, 103:6,
103:13, 103:17,
103:19, 130:8,
152:19, 153:3,
153:6, 153:10,
153:14, 154:3,
154:9, 154:12
theory [1] - 53:24
thereof [1] - 31:4
thereto [1] - 57:10
thinks [1] - 100:8
third [7] - 17:2,
88:11, 120:11,
122:5, 130:17,
135:25, 147:18
third-party [1] - 88:11
thousand [2] - 88:8,
92:7
thousands [1] -
85:13
three [16] - 60:25,
74:12, 110:21,
114:23, 115:3,
121:25, 132:14,
133:10, 142:11,
142:18, 144:15,
144:16, 150:1,
153:17
throughout [1] -
130:19
Thursday [1] - 100:6
ticket [1] - 101:4
timing [1] - 46:10
Title [2] - 30:20, 31:8
title [2] - 15:10, 139:2
today [7] - 34:7,
34:19, 57:25, 58:4,
58:10, 58:15,
152:20
today's [2] - 58:5,
99:11
tomorrow [7] -
100:16, 101:3,
152:21, 152:23,
153:10, 153:19,
154:13
took [6] - 131:4,
141:14, 143:9,
151:2, 152:18,
154:7
top [8] - 15:4, 15:10,
65:6, 91:23,
131:22, 136:1,
140:25, 148:12
total [2] - 11:12,
120:1
totaling [1] - 85:3
touched [1] - 27:21
track [3] - 23:11,
93:3, 93:11
Tracy [125] - 1:19,
27:2, 27:8, 27:10,
27:18, 30:3, 36:3,
36:17, 36:20, 37:9,
37:21, 38:9, 38:18,
40:14, 40:24,
47:16, 47:25, 49:6,
51:3, 53:11, 54:12,
69:3, 69:22, 71:3,
71:14, 72:5, 75:9,
77:17, 77:21, 81:1,
81:24, 82:3, 82:16,
83:12, 84:25, 87:9,
88:21, 90:2, 96:16,
96:23, 97:22, 98:1,
104:10, 104:21,
105:2, 105:12,
105:18, 105:21,
107:16, 108:9,
108:19, 109:6,
110:2, 110:3,
110:12, 112:9,
112:11, 112:20,
112:25, 113:1,
113:12, 113:14,
116:16, 117:5,
122:17, 122:24,
123:7, 123:11,
123:25, 124:11,
124:17, 124:25,
125:16, 126:16,
126:21, 127:13,
128:5, 128:24,
129:5, 130:16,
130:22, 131:20,
132:10, 133:2,
133:5, 133:23,
134:11, 134:20,
134:24, 135:2,
135:11, 135:23,
136:5, 136:11,
136:17, 136:23,
137:1, 137:13,
137:18, 137:23,
138:11, 138:18,
139:7, 139:12,
141:7, 145:2,
145:19, 146:16,
146:22, 147:3,
147:7, 147:12,
147:25, 148:4,
149:6, 149:14,
150:5, 150:7,
150:11, 152:4,
152:6, 152:11,
152:15, 152:18
TRACY [1] - 1:7
tracyw764@gmail.
com [2] - 116:21,
123:9
Lance W. Steinbeisser - Federal Certified Realtime Reporter
174
train [1] - 6:3
training [4] - 5:9, 6:3,
7:5, 7:18
transaction [10] -
87:4, 87:6, 87:21,
88:2, 90:20, 90:21,
90:23, 91:4, 91:19,
92:3
transactions [23] -
87:1, 87:2, 87:18,
91:17, 91:24,
131:19, 131:21,
132:3, 132:15,
132:20, 135:2,
135:4, 135:12,
137:18, 137:20,
137:24, 138:20,
141:24, 142:8,
142:21, 142:24,
143:1, 143:13
TRANSCRIPT [1] -
1:10
transcript [1] - 1:24
transcription [2] -
1:25, 155:3
transfer [9] - 78:4,
78:11, 78:17,
78:23, 87:22, 88:4,
92:5, 92:7, 92:21
translated [1] -
130:17
transmitted [5] -
77:19, 78:6, 78:10,
78:18, 78:22
transpired [1] - 4:3
treating [1] - 75:18
TRIAL [1] - 1:10
trial [5] - 66:3, 75:5,
77:18, 79:3, 154:15
tried [5] - 19:25,
25:22, 25:25, 31:20
true [1] - 67:3
truth [1] - 34:7
try [1] - 45:6
trying [10] - 7:25,
11:11, 43:10,
44:24, 53:21,
53:23, 54:3, 54:4,
60:21, 110:8
turn [1] - 37:4
TV [1] - 10:17
two [37] - 29:11,
31:12, 54:4, 60:16,
67:24, 69:13,
72:15, 73:25, 82:5,
82:12, 82:14,
91:23, 92:21,
94:16, 95:5, 99:15,
101:17, 101:20,
103:11, 109:12,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 174 of
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112:7, 112:8,
113:5, 115:9,
131:17, 131:18,
131:21, 132:3,
133:5, 133:24,
138:11, 140:3,
140:11, 149:6,
149:25, 150:5,
152:3
Two [1] - 111:3
type [8] - 7:6, 8:8,
12:16, 12:19, 63:8,
91:19, 132:5, 138:2
U
Ultra [9] - 126:7,
126:12, 128:21,
141:6, 141:17,
143:7, 143:23,
144:22, 150:20
unable [1] - 111:18
under [8] - 31:7,
34:19, 59:10,
71:17, 73:7, 79:4,
110:15, 139:25
undersigned [1] -
77:22
understood [1] -
102:13
unemployment [1] -
110:15
UNITED [3] - 1:1, 1:3,
1:11
United [18] - 1:14,
1:22, 27:22, 27:23,
30:4, 30:5, 30:21,
31:5, 31:8, 77:3,
77:15, 77:17,
77:20, 79:1, 79:2,
79:8, 79:9, 155:7
universal [2] - 119:6,
130:18
unknown [1] - 30:3
unless [1] - 73:10
unrelated [1] - 55:11
unsuccessful [1] -
143:4
Up [1] - 32:10
up [34] - 3:2, 4:24,
7:18, 20:24, 21:2,
21:11, 22:4, 23:11,
24:9, 32:9, 32:13,
33:2, 33:3, 33:14,
34:8, 39:12, 53:18,
55:13, 58:18, 59:9,
59:19, 61:8, 61:10,
61:15, 61:25,
76:25, 85:25,
106:25, 112:25,
125:11, 149:4,
150:3, 152:9
update [1] - 132:9
updated [1] - 147:23
updates [1] - 147:14
upload [1] - 133:17
uploaded [6] - 19:16,
26:13, 27:18,
69:15, 133:4,
144:16
uploading [2] -
25:20, 26:6
uploads [2] - 133:5,
144:13
USAA [27] - 78:4,
78:12, 78:17,
78:24, 83:12,
87:22, 88:20, 93:2,
93:7, 93:10, 93:17,
94:19, 95:3, 98:14,
103:25, 104:17,
106:6, 106:23,
107:4, 130:1,
141:11, 142:18,
146:5, 148:18,
149:1, 151:5,
151:25
user [11] - 116:2,
120:4, 121:11,
121:15, 121:19,
121:22, 123:24,
133:3, 134:1,
140:24, 144:20
users [1] - 135:20
usual [1] - 46:12
UTC [4] - 119:9,
119:12, 119:17,
139:1
V
V.A [1] - 1:19
Vale [6] - 24:12,
24:14, 24:16,
24:20, 24:23, 25:13
Vale's [1] - 26:7
value [1] - 31:7
various [3] - 41:11,
42:3, 129:9
verification [13] -
134:20, 136:11,
136:24, 137:15,
138:13, 141:14,
143:4, 144:24,
149:19, 150:13,
151:2, 151:22,
152:18
verify [3] - 100:19,
139:8, 143:18
Verizon [54] - 124:19,
125:3, 125:16,
129:22, 134:11,
134:12, 134:15,
134:16, 135:9,
135:10, 135:11,
135:13, 136:7,
136:8, 137:2,
137:3, 137:21,
137:23, 140:4,
140:7, 140:8,
140:13, 140:23,
141:17, 142:15,
142:16, 143:8,
143:10, 143:11,
143:23, 144:1,
144:3, 144:18,
144:19, 145:7,
145:9, 146:3,
146:4, 146:24,
147:1, 147:2,
149:13, 150:7,
150:8, 150:10,
151:16, 151:25,
152:13, 152:15
versions [1] - 101:18
versus [1] - 77:17
via [30] - 47:17,
78:11, 78:23, 92:7,
130:22, 133:24,
135:8, 136:2,
136:8, 136:20,
138:15, 139:8,
139:11, 141:1,
141:10, 142:2,
142:19, 143:9,
143:19, 143:25,
144:21, 145:6,
146:1, 148:13,
148:21, 149:7,
150:9, 150:19,
151:6, 152:16
Victor [4] - 22:6,
23:3, 23:8, 66:17
viewed [17] - 119:18,
119:19, 119:23,
119:25, 120:4,
120:7, 120:9,
120:11, 120:13,
121:13, 121:15,
121:21, 124:5,
145:19, 146:12,
146:13, 147:7
viewing [3] - 122:1,
122:3, 122:5
violation [2] - 27:23,
30:20
violations [1] - 80:17
void [3] - 41:19,
41:21
voided [11] - 37:6,
37:8, 38:9, 40:12,
40:13, 43:13,
43:24, 48:4, 70:24,
107:15
voir [1] - 152:22
voluminous [4] -
82:21, 85:12,
85:17, 85:22
vs [1] - 1:5
W
Wade [273] - 1:18,
1:19, 9:2, 9:7,
26:20, 26:24, 27:3,
27:7, 27:8, 27:10,
27:11, 27:15,
27:18, 30:3, 36:3,
36:20, 37:9, 37:21,
38:18, 40:12,
40:14, 40:24,
42:10, 43:8, 43:16,
43:19, 44:9, 45:5,
47:16, 49:6, 51:8,
53:11, 53:13,
53:22, 54:1, 54:4,
54:10, 54:12,
54:13, 54:16,
54:17, 55:21,
56:19, 63:19,
65:17, 65:18,
65:20, 65:24, 69:3,
69:8, 69:20, 69:22,
70:10, 70:21,
70:24, 71:3, 71:8,
71:15, 71:24, 72:5,
72:7, 74:6, 74:7,
74:9, 75:3, 75:7,
75:9, 75:10, 75:23,
76:10, 77:17,
77:18, 77:21, 81:1,
81:24, 82:3, 82:16,
83:13, 84:25, 85:4,
87:9, 87:25, 88:21,
89:24, 90:2, 90:25,
93:24, 95:16,
95:23, 96:1, 96:6,
96:9, 96:14, 96:16,
96:21, 96:23, 97:3,
97:6, 97:11, 97:14,
97:19, 97:22, 98:1,
98:5, 98:10, 98:19,
98:23, 104:1,
104:10, 104:16,
104:21, 105:2,
105:8, 105:12,
105:18, 105:21,
106:1, 106:17,
Lance W. Steinbeisser - Federal Certified Realtime Reporter
175
107:18, 108:6,
108:9, 108:13,
108:19, 109:6,
109:9, 110:2,
110:3, 110:11,
110:12, 110:24,
111:1, 111:5,
111:8, 111:9,
111:11, 111:20,
112:1, 112:2,
112:9, 112:11,
112:14, 112:17,
112:20, 112:25,
113:1, 113:12,
113:14, 114:12,
115:13, 115:18,
115:20, 116:16,
118:3, 120:6,
120:20, 121:12,
121:16, 121:20,
121:22, 122:17,
122:24, 123:7,
123:11, 123:25,
124:11, 124:17,
125:1, 125:4,
125:16, 125:17,
126:5, 126:16,
127:9, 127:13,
128:2, 128:5,
128:20, 128:24,
129:4, 129:5,
130:16, 130:22,
130:25, 131:12,
131:25, 132:10,
132:12, 132:19,
132:21, 133:9,
133:20, 134:11,
134:21, 134:24,
135:11, 135:23,
136:5, 136:11,
136:17, 136:23,
137:1, 137:13,
137:23, 138:11,
138:18, 139:7,
139:12, 139:15,
139:24, 140:5,
140:7, 140:10,
140:23, 141:14,
142:4, 142:16,
143:3, 143:7,
144:3, 145:3,
145:19, 145:25,
146:11, 146:16,
147:3, 147:7,
147:12, 147:25,
148:5, 148:12,
148:19, 149:11,
149:14, 149:22,
150:7, 150:11,
150:23, 151:2,
152:4, 152:7,
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 175 of
176
152:15, 152:18
WADE [2] - 1:7, 1:7
Wade's [38] - 26:19,
36:4, 36:17, 38:5,
51:3, 75:6, 75:20,
87:22, 94:19,
107:16, 116:11,
117:5, 126:11,
126:21, 131:20,
132:16, 132:20,
133:3, 133:6,
133:15, 133:23,
135:3, 137:19,
141:7, 141:11,
141:25, 142:9,
142:18, 142:22,
143:17, 144:11,
146:22, 149:7,
150:5, 150:16,
151:5, 151:19,
152:11
Wades [1] - 31:21
wages [2] - 112:2,
113:1
wait [7] - 3:13, 3:21,
42:8, 54:2, 61:23,
153:24, 154:1
waived [2] - 28:16,
29:2
walk [2] - 130:13,
145:17
Walter [2] - 38:25,
39:3
ways [1] - 75:2
website [9] - 19:15,
19:17, 19:20,
19:21, 65:11,
65:13, 69:14,
69:16, 93:3
week [2] - 104:12,
105:23
whatsoever [1] - 9:13
whole [4] - 7:12,
7:24, 68:22, 76:20
WILCOX [75] - 1:17,
9:24, 11:6, 11:8,
12:7, 13:24, 14:1,
14:25, 15:1, 16:4,
16:5, 16:16, 16:18,
19:13, 25:12,
26:12, 27:25, 28:2,
29:21, 30:18,
30:19, 32:20,
32:25, 35:12,
35:14, 35:21,
35:23, 36:6, 36:8,
37:11, 37:17,
37:19, 37:20,
38:22, 38:24, 39:6,
41:2, 41:5, 41:18,
41:21, 46:25, 53:7,
53:9, 56:11, 57:4,
57:9, 57:11, 57:14,
57:17, 57:19,
57:21, 58:3, 61:7,
61:11, 61:15,
62:19, 68:24,
69:25, 70:2, 72:12,
72:13, 72:22, 73:4,
73:7, 76:8, 84:17,
84:20, 88:12,
100:2, 102:4,
102:11, 102:13,
103:3, 125:18,
154:11
Wilcox [5] - 40:8,
58:2, 66:5, 66:13,
66:16
Wilcox...... [1] - 2:4
Wilcox................ [1] -
2:5
willfully [1] - 29:25
wire [9] - 30:23, 32:2,
32:11, 32:14,
32:21, 33:7, 77:19,
78:6, 78:18
Wireless [13] - 136:8,
137:2, 141:17,
143:8, 143:11,
144:4, 145:9,
146:24, 147:3,
149:13, 150:8,
151:16, 152:15
wireless [1] - 140:13
wish [1] - 34:16
withdraw [2] - 44:20,
102:20
witness [16] - 3:10,
9:18, 11:4, 12:5,
13:24, 14:25,
16:16, 41:12,
41:18, 42:4, 55:10,
60:12, 73:1, 73:3,
79:13, 85:21
WITNESS [14] -
47:13, 47:16,
47:25, 48:6, 48:10,
51:6, 51:11, 51:13,
52:8, 52:24, 53:1,
53:3, 73:12, 79:17
WITNESSES [1] - 2:2
witnesses [9] - 10:5,
10:9, 10:11, 10:15,
58:23, 59:11,
60:25, 85:12, 85:16
Womply [69] - 11:24,
16:21, 18:20, 19:8,
19:9, 19:14, 19:16,
19:19, 19:23,
22:24, 24:13,
24:15, 26:7, 65:14,
68:19, 69:14,
69:17, 94:8, 94:12,
94:15, 94:19,
117:11, 117:18,
129:13, 130:15,
130:16, 130:22,
131:19, 132:15,
132:16, 133:2,
133:3, 133:15,
133:18, 133:23,
133:24, 134:14,
135:2, 135:3,
135:17, 135:20,
135:25, 136:18,
136:19, 137:14,
137:18, 139:15,
139:24, 140:17,
140:25, 141:12,
141:24, 141:25,
142:9, 144:12,
144:20, 147:11,
147:14, 148:10,
148:13, 148:20,
148:22, 149:7,
149:22, 150:5,
150:9, 150:16,
152:6, 152:11
Womply's [1] - 26:13
word [2] - 57:2, 68:17
words [4] - 47:24,
54:20, 75:22,
102:25
wrapped [1] - 3:2
Wright [2] - 39:1,
39:3
written [22] - 95:4,
95:16, 96:1, 96:9,
96:16, 96:23, 97:6,
97:14, 97:22, 98:1,
98:5, 98:6, 98:19,
104:11, 104:13,
104:21, 105:12,
105:21, 106:1,
106:3, 107:13,
108:9
wrote [2] - 27:8,
107:19
Y
Yaosca [4] - 16:9,
16:23, 17:6, 17:7
year [3] - 82:9, 82:10
years [20] - 5:3, 5:6,
6:20, 8:7, 32:9,
32:10, 32:13,
32:14, 32:18,
82:11, 82:13,
82:14, 84:15,
Lance W. Steinbeisser - Federal Certified Realtime Reporter
176
84:18, 84:23, 85:2,
89:19, 89:20,
89:22, 90:1
yesterday [14] - 3:2,
4:15, 4:18, 5:20,
17:25, 39:18, 40:1,
40:6, 40:16, 40:18,
40:20, 44:19,
71:19, 71:23
yourself [1] - 31:21
Z
Zelle [7] - 88:4, 88:8,
92:5, 92:8, 92:16,
92:18, 92:25
zero [2] - 132:7,
132:8
zone [1] - 119:8
Case 0:23-cr-60173-KMW Document 265 Entered on FLSD Docket 05/15/2025 Page 176 of
176File and source
- File
- gov.uscourts.flsd.670191.265.0.pdf
- Size
- 1,248,240 bytes
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- bc229adc87f2b36000cb24bdd22a6bf6666b575658fe3639b4b33cc06bdbf58b
- Original
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