Court filing
Judgment — United States v. Tracy D. Wade (Dkt. 279, S.D. Fla. No. 0:23-cr-60173)
Filed May 27, 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 | 2025-05-27 |
U.S. District Court for the Southern District of Florida · No. 0:23-cr-60173-KMW · Doc. 279 · 2025-05-27 · Docket on CourtListener
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
CASE NOs. 23-cr-60173-KMW
UNITED STATES OF AMERICA,
Miami, Florida
October 1, 2024
vs.
1:02 PM - 2:20 PM
CAROLYN DENISE WADE
TRACY D. WADE,
Defendants.
Pages 1 to 52
______________________________________________________________
TRANSCRIPT OF CALENDAR CALL
BEFORE THE HONORABLE JUDGE DONALD L. GRAHAM
UNITED STATES SENIOR JUDGE
APPEARANCES:
FOR THE GOVERNMENT:
David A. Snider, Esquire
DOJ-USAO
US Attorney's Office-Southern
District of Florida
500 E. Broward Boulevard
7th Floor
Fort Lauderdale, Florida 33394
-and-
Adam Love, Esquire
US Attorney's Office
Miami, Florida 33130
FOR THE DEFENDANT:
Daryl Wilcox, Esquire
Daryl E. Wilcox
5201 Southwest 18th Street
Plantation, Florida 33317
Case 0:23-cr-60173-KMW Document 279 Entered on FLSD Docket 05/27/2025 Page 1 of 52
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STENOGRAPHICALLY REPORTED BY:
GLENDA POWERS, CRR
Official Court Reporter before:
Senior Judge Donald L. Graham
United States District Court
James L. King Federal Justice Building
99 NE 4th Street
13th Floor
Miami, Florida 33132
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(Call to the Order of the Court.)
THE COURT: Calling Case Number 23-cr-60173, United
States versus Karen Dennis Wade; 23-cr-60173, United States
versus Tracey D. Wade.
Counsel, please state your appearances, beginning with
the Government.
MR. SNIDER: Good afternoon, Your Honor. Assistant
U.S. Attorney David Snyder on behalf of the United States. I'm
joined by my cocounsel, Assistant U.S. Attorney Adam Love.
THE COURT: Good afternoon.
MR. WILCOX: Good afternoon, Your Honor. Daryl Wilcox
on behalf of Carolyn Wade and Tracy Wade, and I'm joined with
my legal assistant, Hendrith Smith.
THE COURT: Good afternoon. You may be seated,
counsel. Thank you for coming in this afternoon so that we can
discuss the case that will commence in this matter on Monday.
First, let me state again we will not be in session on
the 11th and the 14th. The 11th is the first Friday of the
trial period, next Friday, and the 14th is a federal holiday;
so those two days we will not be in session.
We will select the jurors on Monday morning, starting
at 9:30 AM. There are a few issues pending. I don't want to
belabor this point, but I'm going to start with an issue I
raised at our last conference, telephonic conference. I raise
it because I noted that the magistrate judge states in his
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order an allusion to the Allen charge. You will recall it's in
a footnote. And I'm continually confused by this issue because
all of the pleadings filed by the defense assert that the Court
gave an Allen charge, and the magistrate also refers to this as
having been an argument of the defense, and so I'm quite
confused by it because the Court never gave an Allen charge.
It's as if someone who prepared the motion either
wasn't present at the trial or doesn't understand the Allen
case, and so perhaps the defense can clarify that issue, just
for my own personal illumination.
MR. WILCOX: Unfortunately, Judge, I cannot clarify it
for you because on the day that the jury was selected, I did
not -- well, I was here for the first day that the jury went
out; but that second day, when the Court declared a mistrial,
that entire day, I was not present in court, unfortunately. So
I apologize, Your Honor, I cannot clarify it. I cannot say
exactly what went on that day because I was not here.
THE COURT: Well, I'm going to tell you what went on.
Your cocounsel made the argument that the Court should not give
the Allen charge, commonly referred to, and as Magistrate Hunt
pointed out, the "dynamite charge," based on your cocounsel's
argument and presentation of some cases, frankly, that I had
not seen, where the Eleventh Circuit expressed extreme
reluctance about giving the Allen charge. And so I agreed with
your cocounsel and purposely did not give the Allen charge as
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requested by the Government. And the magistrate pointed out
the Court indicated that if it gave an Allen charge, it would
not refer to the cost as a factor for the jury to consider;
that is, the cost of the litigation.
And I simply directed the jury to go back and continue
deliberating on two occasions. And after the second
instruction, the jury continued and persisted with its
inability to reach a verdict, and so I simply declared a
mistrial without giving an Allen charge. So that's what
occurred, to the best of my recollection.
Does the Government recall the facts differently?
MR. SNIDER: No, not at all. In fact, to clarify or
make certain what the record was, in its response to that
motion, the Government attached as an exhibit -- and filed it
on ECF -- the entire transcript from the entire day of those
proceedings, leaving no mistake whatsoever that there was no
Allen charge given.
And I think what was perplexing to the Government was
that after it had done so, in the defendant's reply, they
continued to refer to the Allen charge having been given up to,
I believe, three times.
THE COURT: Yes.
MR. SNIDER: And that they were objecting to the third
reading, none of which is anywhere remotely consistent with the
record. So that is what it is.
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The Government read the report and recommendation,
recommending denial of that motion to dismiss certain counts
based on the alleged vindictiveness, and the Government agreed
that that motion should be denied.
The one inaccuracy I saw was that, I think, Judge Hunt
may have said that the Court read the duty to deliberate
instruction twice, and it's my recollection -- and I think the
record clearly reflects -- that the Court only gave that
instruction, the duty to deliberate, once. And that was after
the jury came back with the first note saying they were
deadlocked. The Court read the duty to deliberate.
After the second note, the Court, after hearing some
argument from the parties and reading the new cases, decided it
was not going to give an Allen charge and gave essentially an
instruction to the jury to go back and give it one last shot.
They did. They came back with a third note saying they were
deadlocked, and at that point, the Court declared a mistrial
and denoted -- it's a written order declaring a mistrial. It
was the parties' consent. There was no objection by either
side to the declaration.
THE COURT: That is as I recall the incident. So
perhaps, Mr. Wilcox, if you discuss that issue with Mr. McCray,
the only reason I raise it is because it keeps coming up; and,
once again, it was in the magistrate judge's report and
recommendation.
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MR. WILCOX: Your Honor, I will discuss this with
Mr. McCray. Now that I've heard the full explanation, it is
possible that Mr. McCray may have confused a duty to deliberate
with the Allen charge.
THE COURT: That's possible. That's certainly
possible.
All right. Enough of that. Let's proceed with some of
the other issues.
One has to do with the 404(b) evidence that the
Government has submitted. And I have, of course, read the
response, citing the 403 issues. I'm not exactly sure how the
facts are going to play out in this case, and so it may be that
I should just simply wait until the Government concludes its
case in chief to decide the extent of which there should be
404(b) evidence.
404(b) evidence is allowed. There's no question about
it. One concern on the 403 consideration is as to confusion of
the issues and waste of time. Now, this incident referred to
in the 404(b) statement, that could be a five-day trial.
That's, basically, the same general scenario as Ms. Wade's
trial.
So I'm not sure what the Government -- have a seat.
I'll be with you. I'm not sure what the Government intends to
present, but I'm not going to listen to a day or what have you
of presenting this other case involving Mr. Wade. So to the
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extent that the Court would allow some 404(b) evidence, it has
to be limited and concise so that we're not trying a different
case within the confines of what is charged. And so I don't
know if the Government wants to give me a short synopsis of
what you would intend to present and how long you expect that
it would take to present or not.
MR. SNIDER: Thank you, Your Honor. And forgive me for
being a little slow on my feet. I've injured myself. I don't
know if the Court's aware.
THE COURT: I am aware.
MR. SNIDER: I'm in a cast.
THE COURT: I'm pleased to see you here. I think
you're going to do just fine. You're moving around just as
well as a lot of my colleagues and former lawyer friends.
MR. SNIDER: So let me address what the Government
intends to do with the evidence that it has noticed in its
404(b).
The Government intends to call a witness from the SBA
that is part of the EIDL program. The EIDL is the economic
disaster loan program. That was a program that existed before
COVID but allowed loans to small businesses to be made during
COVID, basically, considered -- it allowed COVID to be a
disaster, for someone to apply for one of these economic injury
disaster loans.
That witness, the Court should just note, is intending
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to fly here from, I believe, Denver, Colorado. Her direct
testimony, at most, I would say would be an hour, and that is
probably overstating it by -- I think it's more like 30 to 40
minutes. What that witness will testify -- there's a handful
of records, not very many -- I think maybe nine or so records
that the Government has included on its witness list, and
that's in the 900 series, like, 900, 901, 902 through, I think,
nine -- just so I'm clear here -- it's 900 through 907.
THE COURT: 900 to 907?
MR. SNIDER: Correct.
THE COURT: All right.
MR. SNIDER: And those records show an application --
two applications, two applications that were submitted by the
defendant Tracy Wade to the SBA requesting an EIDL loan. And
what the SBA will testify they received these applications;
that the information in there stated that the Wade Funeral
Home --
THE COURT: In other words, you would have exhibits
that indicate what --
MR. SNIDER: The applications says, absolutely.
THE COURT: Okay.
MR. SNIDER: The information is in the application.
It's very simple. It's actually line by -- you know, there's
just a bunch of lines. And one of the pieces in the
information in there says: "How much did your business make in
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2020?"
And the answer that was put in there was, in one
application, was over $400 million, and in another application,
it was over $300 dollars.
THE COURT: Is that the same application?
MR. SNIDER: He submitted two different applications
for the same company, Wade Funeral Home.
THE COURT: Is this a correction of one or two separate
independent --
MR. SNIDER: Two separate.
THE COURT: -- applications?
MR. SNIDER: We believe the witness will testify that
these were two separate applications. The SBI assigned an
application number to reach one -- two different numbers, two
applications, two different dates. One was submitted somewhere
around, I think, April of 2020, and the other one was about a
month later while the first one was still pending.
These are applications that had to be like a PPP
application, certified as true under penalty of perjury. And
so the 404(b) evidence that we believe is admissible here is
these records to show absence of mistake that when it came to
the PPP process. And by the way, I should note by putting in
over 400 million in revenue and approximately 300 million in
expenses, the effect of that was to seek the maximum amount of
available EIDL loan, which under the program for COVID was
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150,000.
Similarly, when it came to PPP, the allegation --
THE COURT: One question.
MR. SNIDER: Yes.
THE COURT: So in order to get 150,000, is there a
gradation?
MR. SNIDER: There is a gradation. And that -- you
actually didn't have to put in 400 million. What you had to do
was put in a number that if you -- it's like if you divide it
by 12, right, and then you multiply it by a certain X factor,
if you're above the threshold, you get 150.
THE COURT: So do we know what that is?
MR. SNIDER: Yes.
THE COURT: That number is?
MR. SNIDER: The witness will testify. Absolutely.
THE COURT: What is it? I'm just curious. In other
words, to get 150,000, you would have to say you had a gross of
what number?
MR. SNIDER: It's actually -- I believe it's -- I think
it says this on the application, but you take the difference
between the gross revenue and the expenses, and I think if that
number is over 150, then what you're saying is, you know, this
is how much my business was making before the pandemic and as a
result of my injury from the pandemic, that I couldn't operate,
I'm entitled to that amount. That's the purpose of the loan.
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So you didn't have to put a delta of 400 million and
300 million on the first one, and you didn't have to do the
same on the second one. As long as you were showing that you
had net revenue of $150,000 before the pandemic, that's
essentially what you could apply up to get. That's testimony
that will come in through the SBA.
So that's really it. We are going to put in these
records. The SBA will testify what the EIDL program was, what
these applications show, that the SBA was relying on them to be
truthful. There was a certification to make sure it was true.
And then what happened was -- and this comes out in one
of the exhibits -- the SBA, as its business record, puts in
notes of every time there was an interaction between the SBA
and the applicant. So the applicant calls up and says, "What's
the status of my loan?" that gets logged. The SBA tells the
applicant, "You need to update your email address," that gets
logged. The applicant calls back and says, "Hey, what's the
status? I'm still waiting on my money," that gets logged.
What also gets logged is the SBA's review and any notes
that it puts in from its review. And in this, what the
application shows, is when the SBA was reviewing this, there a
notation to te effect of -- and I'm not quoting because I don't
have it in front of me, to the effect of I googled this
business. It seems fairly small. We need to ask the applicant
to verify this income because this seems -- like $400 million
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for a little funeral home in Hallandale Beach, Florida --
something didn't seem right. The SBA flagged it.
What happened was when the SBA flagged it, they
contacted Mr. Wade. This is all again according to the
business record notes. They contacted Mr. Wade and said, "You
have 24 hours to substantiate this, and you can substantiate it
with a copy of your tax return for this year," which he
promptly -- and I say "promptly," the records show he went in
within like an hour. He submitted the same tax return he had
filed with the IRS.
THE COURT: Now --
MR. SNIDER: Yes.
THE COURT: -- 900 through 907 shows the two
applications?
MR. SNIDER: Yes.
THE COURT: Now, is this for the same year?
MR. SNIDER: Yes.
THE COURT: It just seems a little improbable that you
would have two applications with different amounts for the same
year. So I guess that's the point.
MR. SNIDER: Yes. It's up to us then to argue to the
jury what they can infer from that. So our argument is
that what this shows -- because when it comes time -- and by
the way, so the record just flushes out, there's no
allegation -- and the Government is not going to argue that he
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submitted a bogus tax return to substantiate this 400 million.
He gave a tax return that appeared to be the exact same one
that was filed with the IRS for that year, and as a result of
that, the SBA said, "Okay. You don't qualify now for 150,000.
All you get is 80,000." And he got an 80,000 EIDL loan.
THE COURT: And the SBA paid it?
MR. SNIDER: Yes. That's on the SBA.
The point is what we're arguing is, absent of mistake,
is that in two instances before -- we're looking at this as
pandemic relief. The Court knows there were multiple forms of
pandemic relief. There was a Paycheck Protection Program.
There was the Economic Injury Disaster Loan program. There
were other programs to aid the U.S. taxpayers who were
struggling as a result of the pandemic.
And our argument, if the evidence is admitted, is that
it -- well, the argument that it's admissible is that under
404(b), it shows that this was the motive and intent of this
defendant to get PPP money, to get SBA relief that he wasn't
entitled to.
And not only that --
THE COURT: Wait a minute. Can one be eligible for
both loans?
MR. SNIDER: Yes. But what he's doing is seeking the
maximum amount. What he's charged in the indictment with is
getting a loan based on a completely made up application.
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THE COURT: That's a different -- that's a little
different than what these documents are showing.
MR. SNIDER: Well, the nature of the false statement is
almost a dunk, right, where you are grossly inflating income.
That's true in the EIDL. That's true --
THE COURT: What's the evidence of grossly inflating?
MR. SNIDER: Well, because his real tax returns, when
he was asked to show it, show that he didn't make 400 million.
He had 300,000.
THE COURT: The tax returns show 300,000?
MR. SNIDER: Yes.
THE COURT: Which was the second application amount?
MR. SNIDER: No. The second application was 300 --
THE COURT: Million.
MR. SNIDER: -- million, yes.
So, Judge, I reference this in, I think, my notice and
in my reply. This exact issue was presented to Judge Cohn.
THE COURT: That's fine.
MR. SNIDER: I'm just saying that the way that the
Court looked -- the way that the Court looked at it there was
that it was highly probative of intent and motive and other
acceptable bases under 404(b) and that it was not outweighed.
THE COURT: So wait a minute. Now you're confusing it.
I know Judge Cohn tried a case. Did it involve the parties in
this case? Are you saying there was a similar factual
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scenario?
MR. SNIDER: It was about as close of a factual
scenario as possible because --
THE COURT: Someone submitted two loans? One for 400
million and one for 300 million in another case in a different
fact pattern?
MR. SNIDER: So let me just -- the other case -- the
Government last year charged 17 Broward sheriff office deputies
with PPP fraud. One of those defendants was, coincidentally or
not, represented also by Mr. McCray and went to trial -- and I
think Mr. Wilcox -- went to trial in March.
The allegation in her indictment was that she got --
THE COURT: "Her" meaning the --
MR. SNIDER: The defendant. Her name was Stephanie
Smith. United States versus Stephanie Smith. Stephanie Smith
was alleged in her indictment to have fraudulently obtained two
PPP loans. And the allegation and what was proven at trial was
that those were fraudulent because each one had inflated
income.
Stephanie Smith, like Mr. Wade, months before her PPP
application had also submitted an EIDL application. In that
EIDL application, it contained similar false statements.
THE COURT: And these --
MR. SNIDER: It wasn't 400 million.
THE COURT: -- these false states --
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MR. SNIDER: Yeah.
THE COURT: -- in each of the loan packages are
inconsistent with one another. Is that the point? The
amount -- let's say hypothetically the gross income in one
document is different than the gross income in another document
for the same item. Is that the point, or not?
MR. SNIDER: So different lies but the same -- the
nature of the lies are the same. So different -- yes,
different amounts of income, but in both, there's an inflation
or a misrepresentation.
Trying to get pandemic relief by making false
statements months before the conduct charged in the indictment
Judge Cohn thought was admissible to show motive, intent,
absence of mistake, identity, and any other grounds that I had
put in my motion.
And in that case, you know, that loan didn't even -- it
was actually denied. It was denied. And one of the things --
THE COURT: Oh, you mean the loan itself from the SBA
was denied?
MR. SNIDER: Yes, the EIDL.
In this case, Mr. Wade did get the EIDL, but it was
half of what he was seeking. He was seeking 150,000, and when
the SBA challenged him, they said, "According to your tax
return, you only made 300 grand, not 400 million; so you're not
entitled to all 150, the maximum amount, you're entitled to
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80,000."
And when it came time for PPP, again, the allegation is
that Mr. Wade sought a maximum amount, which for a sole
proprietorship -- again, a different program, but for a sole
proprietorship, we know that the maximum amount, if you have
your own business -- no other employees -- was $20,000. And
the only way you could get that is if you could show income,
gross income of 100,000. That's the allegation in the
indictment -- that they put in false information about the
gross income to get the maximum amount of the PPP loan. I
think it's relevant that he tried to get the maximum EIDL loan
just a few months before.
THE COURT: And am I to assume that this 404(b)
evidence is to be received only as against the allegations
involving Mr. Wade?
MR. SNIDER: That's true.
THE COURT: All right.
MR. SNIDER: He is charged in the conspiracy; so I
think it goes to his -- again, what's relevant for the
substantive charge is relevant to the conspiracy; and,
obviously, under the law, Mrs. Wade -- maybe she knowingly
joined the conspiracy, she's liable for the acts of her
coconspirators. But the 404(b) is not part of -- it's not
evidence in the conspiracy. It's evidence of his intent, so
yes. But an instruction --
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THE COURT: I've been following you carefully right up
to this point about the admissibility as to the intent of each
person. It seems to me that if allowed, it's admissible as
against Mr. Wade?
MR. SNIDER: Yes, that's true.
THE COURT: One of --
MR. SNIDER: I'll stop there. I'll stop there. It's
admissible. I'll stop there. The only thing I wanted to
clarify was he's charged in the conspiracy with her --
THE COURT: I understand.
MR. SNIDER: -- but it's admissible against Mr. Wade.
And the Government has no problem with a limiting instruction.
You know, first of all, there's a model instruction.
THE COURT: Does a limiting instruction resolve any
problems with respect to prejudices against Ms. Wade? Is it in
any way confusing for jurors? Is it an instruction they can
readily follow?
What are your comments in that regard? And then, I
will allow Mr. Wilcox to respond.
MR. SNIDER: Sure. So I believe that it is a -- the
model 404(b) instruction is given routinely when 404(b)
evidence is admitted. So I think there's no question to
follow.
Adding to that, I also think it's -- I haven't seen
anything proposed yet about limiting it to Mr. or Mrs. Wade,
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but that shouldn't be -- I don't see why that would be
confusing. It's Mr. Wade that submitted it. The testimony
will concern Mr. Wade. The testimony will concern Wade Funeral
Home, which is his business.
Thank you.
THE COURT: All right. Mr. Wilcox, any comment?
MR. WILCOX: Yes, Your Honor. That's just at the
outset, Your Honor, that the loan was approved and he's paying
the loan, the EIDL loan that he received.
THE COURT: That's the $80,000 loan?
MR. WILCOX: Yes. The loan was approved.
THE COURT: And your point is there's no suggestion
that there was anything improper about it.
MR. WILCOX: There's no suggestion that there's
anything improper about the loan. It's not charged in the
indictment. That's the primary reason why I think it may be
confusing to the jury. What's charged and not charged in the
indictment, it's kind of -- what's more confusing, Judge, is
that when the Small Business Administration says, "Wait a
minute; this doesn't seem to be right," he immediately provided
them with his inaccurate tax return. So this is what the
funeral home made would suggest to me that it was probably more
of an error than some type of intent to defraud the SBA with
respect to this.
THE COURT: You would have two errors?
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MR. WILCOX: Yes, Your Honor.
THE COURT: It was 400 million, 300 million, and then
300,000?
MR. WILCOX: No. The 300,000 is not an error, Judge.
THE COURT: Yes. But the allegations are that the
documents showed 400 million and 300 million. I thought I
understood that.
MR. SNIDER: Yes.
MR. WILCOX: The EIDL application for 400 million, then
later, he filed an EIDL application where he alleged that he --
you know, he wrote on the application that the funeral home
made 300 million.
With respect to the second application, the SBA did
nothing with that. It was just -- it just -- they did nothing
at all with that.
With respect to the first application, they said,
"Listen, this doesn't look right." He immediately said, "Oh,"
and gave them what he really made. And, Your Honor, I don't --
you know, I guess he could argue that he was trying to cheat
the SBA, but I think it's confusing, one, in that he
immediately provided the SBA with his direct gross income
amount by way of a tax return, and that these aren't charged in
the indictment.
Also, Your Honor, the SBA asked him to provide a form
to sign. It's called a 4506-T form, where they requested him
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to provide them with authorization of reviewing his tax
records, and he signed that willingly, Lord -- or he signed
that willingly, Your Honor. So I don't see how the Government
can infer any intent to defraud. Even, I think, the likelihood
of confusing the jury with a charge that's not in the
indictment, Your Honor, should cause the Court to exclude this
evidence. It's not needed, and they're really trying to argue
propensity.
THE COURT: All right. Just listening to the
arguments, I think you both have assured me that I really
should wait until the conclusion of the Government's case in
chief. When I say "conclusion," I mean up to the point of the
admissibility of 404(b) evidence.
In other words, your last witness will be the 404(b)
evidence if I'm allowed -- or if I agree to allow its
admissibility.
When you're talking about the Judge Cohn case, I'm not
seeing the total similarities.
And in the Judge Cohn case, do you have two defendants
in a second case?
MR. SNIDER: No, it was one defendant.
THE COURT: It was one. All right.
And then Number 2, if you read the similar act
evidence, it refers to a defendant. And as you know, when you
have two defendants on trial, the jury really looks at two
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separate cases. So I don't see anything in the instruction
that says, "Oh, the intent of the conspiracy should be allowed
as to both and not just as to one."
So that's -- you know, I think that's pretty clear, but
I would like to see and listen to the evidence and then make a
decision.
Now, frankly, it would appear that it's probative. And
if I'm convinced that an instruction will resolve the issue as
to any unnecessary prejudices as to the codefendant, Carolyn
Wade, then it would be admissible, but I would first like to
hear the totality of the evidence.
You know, I tried this case once. This case is totally
different, with different charges, and let's see what the
evidence is, and then I will rule accordingly. So there we
are.
So now, how long do you think it will take us to try
this case, now that you've refined your cases and sort of know
what evidence you're presenting? We have two defendants this
time, rather than one, and more charges; so what is the
Government's best estimate at this time?
MR. SNIDER: My estimate, Judge, is that the Government
will rest its case in chief sometime on Thursday of the first
week. I do not anticipate going into the second week, as far
as the Government's case in chief. That's my prediction.
THE COURT: All right.
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MR. SNIDER: You know, just so I understand the Court's
ruling on the 404(b), it sounds like it's reserving until the
Government has completed its case in chief but not yet rested?
THE COURT: No, you're not going to rest.
MR. SNIDER: No. I said, "Not yet rested."
THE COURT: I'm sorry?
MR. SNIDER: You're reserving ruling until the
Government has presented its case in chief but not yet rested?
THE COURT: Correct.
MR. SNIDER: Okay. So I --
THE COURT: In other words, it's not -- sometimes I
might say, "Let's see what happens for rebuttal." It's not
that scenario. It's at the end of your case in chief. Do you
go further in your case in chief and present the 404(b)
evidence?
Am I clear?
MR. SNIDER: Yes, you're crystal clear.
THE COURT: All right.
MR. SNIDER: The only thing, the Government's last
witness, as it was in the first trial, would be a summary
witness because I think that as far as presenting --
THE COURT: All right. If you have a summary witness
that you want to present last --
MR. SNIDER: Yes.
THE COURT: -- it would be the witness before the
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summary witness.
MR. SNIDER: That would be the Government's
preference --
THE COURT: All right.
MR. SNIDER: -- if the Court could rule before we put
on summary witnesses.
THE COURT: Yes, sir.
MR. SNIDER: Thank you.
THE COURT: Not an issue.
MR. SNIDER: Thank you.
THE COURT: All right. With the conspiracy counts, as
I understand the facts, there is not an 801 (d)(2)(e) issue;
that is the admissibility of coconspirator statements.
As I read the indictments, I'm not sure that that's an
issue, but I want to raise it so I can hear your comments.
MR. SNIDER: I'm glad the Court raised that because it
was actually something I did want to address.
The Government, in its case in chief, intends to call
Haydee Rivero, formally known as Haydee Granados. Haydee
Rivero is named in the superseding indictment as a
coconspirator.
She has also been charged in a separate case by way of
information with conspiracy, and that information charges her
with conspiring with Carolyn Wade, Tracy Wade, and others as it
relates to the Paycheck Protection Program. She has since
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entered a guilty plea in her case and is going to be testifying
for the Government as a cooperating defendant.
Through her testimony, the Government anticipates that
she will testify that there were, as it sort of says openly in
her information, other coconspirators. And we'll establish --
I will just put a name on the record now -- Jamil Hunter as one
of those coconspirators.
If the Government establishes foundationally through
her testimony that Mr. Hunter was a coconspirator in this, then
the Government would seek to have any statements by Mr. Hunter
in furtherance of the conspiracy admitted under that rule.
THE COURT: By Mr. Hunter or by a coconspirator?
MR. SNIDER: For example, what Mr. Hunter may have said
to Ms. Rivero, who will be the declarant, testifying about what
he told her in furtherance of the conspiracy.
THE COURT: Can you give an example?
MR. SNIDER: Sure.
That he may have instructed her -- maybe this isn't
even a statement but how to complete a fake schedule.
THE COURT: "He?" Who is "he?"
MR. SNIDER: The unindicted coconspirator, Jamil
Hunter.
THE COURT: Told?
MR. SNIDER: This testifying coconspirator how to
complete a Schedule C fraudulently.
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THE COURT: And what makes him a part of this
conspiracy involving the Wades? Are they all together or --
MR. SNIDER: In a few respects. I expect the testimony
of Ms. Rivero will establish a couple of things. First,
Mr. Hunter assisted Ms. Rivero in getting a fraudulent PPP loan
and after he had done that, Mr. Rivero was offered -- I'm
sorry, Mr. Hunter was offered to the Wades as a person who
could do a fraudulent PPP loan for them.
Ultimately -- I think this is what the testimony will
show -- Mr. Hunter was not available to do a fraudulent loan
for Mr. or Mrs. Wade. So what happened? He taught Ms. Rivero
how to do it, and Ms. Rivero ended up doing it for the Wades
and a whole lot of other people.
THE COURT: So Mr. Hunter never had any contact with
the Wades? Is that --
MR. SNIDER: Direct contact? I don't think --
Ms. Rivero's testimony will be -- and every time I say
"Ms. Rivero," I'm referring to Ms. -- it's the same as
Ms. Granados. Granados is her maiden name. You may have heard
that name many times.
Ms. Haydee Granados Rivero will testify that at least
Mr. Wade was attempting to contact Mr. Hunter, and the way she
knows that is because Mr. Wade then called Ms. Rivero and said,
"Hey, I can't get in touch with this guy; he's not answering my
phones," and that was the transition to having Ms. Rivero be
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the one to do the -- and her part was to create fraudulent
Schedule Cs. That's how she led to being involved.
So there aren't many statements, but to the extent
that, you know, Mr. Hunter is teaching Ms. Rivero how to create
a fake document, that comes in.
THE COURT: What will Ms. Rivero say about Mr. Hunter's
statement? You say "teaching." Do you mean they got together
and discussed and conferred?
MR. SNIDER: Yes. What I expect she's going to say is
that there were some instructions over the phone telling her
which website to go to to download a blank IRS form, giving
her -- and then actually giving her in person a sample with
fake numbers that she used as an example to create others.
This has all been disclosed. This was all memorialized
in a 302 report from an interview that the Government conducted
in June of this year, and it was disclosed in our first
discovery production for the superseding indictment.
THE COURT: I assume and infer that there have been no
additional charges as against this gentleman; correct?
MR. SNIDER: Mr. Hunter is not presently charged.
THE COURT: All right.
MR. SNIDER: My basis for admitting his statements
would be to establish the foundation through Ms. Rivero that
he's an unindicted coconspirator because she will testify that
she conspired with him in the conspiracy that she's charged
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with.
THE COURT: Mr. Wilcox, you may comment.
MR. WILCOX: Let me try to see if I can understand, if
I can summarize the Government's position.
The Government is seeking to introduce a hearsay
statement of an unindicted coconspirator --
THE COURT: Well, they're saying it's not -- they're
saying it's an 801(d)(2)(e) statement.
MR. WILCOX: Like the statement of --
THE COURT: That's the allegation.
MR. WILCOX: Okay. And under that --
THE COURT: Which is an exception to the hearsay rule.
MR. WILCOX: Right. Okay. And our client doesn't --
and we don't get to confront this witness?
THE COURT: Well, if it's an 801(d)(2)(e) --
MR. WILCOX: Right.
THE COURT: -- there's an exception to the hearsay
rule.
MR. WILCOX: Let me say on this -- and this is --
THE COURT: I guess you could call the witness. When
you say "confront"...
MR. WILCOX: Excuse me.
(Pause in the proceedings.)
MR. WILCOX: Yes, we could call the witness,
Your Honor, but the thing is we haven't met with this witness
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yet. I think we put him on our witness list because we thought
about calling him at one point; but, Your Honor, he's,
obviously, the -- he's in the position of being a hostile
witness because the Government could charge him eventually, or
he could take the Fifth Amendment, just like what happened in
the first trial that we had; so that's not really feasible,
Judge.
THE COURT: You're speculating about what might happen;
so I don't want to go that far.
MR. WILCOX: Okay. We've seen the movie before, Judge.
I mean, am I wrong? I mean, we've seen it before.
THE COURT: No.
MR. WILCOX: Okay.
So I just want to -- my first confusion, Judge, is that
I understand we have these 801 problems where you have two
defendants and one statement is going to be introduced, and the
defendant doesn't testify. I understand the context of the
Bruton situation.
THE COURT: Before you go on, one question popped into
my mind. Does Ms. Rivero confer with both defendants in this
case?
MR. SNIDER: So we believe the evidence will show that
Ms. Rivero had direct contact with Mr. Wade and that any
contact with Carolyn Wade was indirectly through Mr. Wade.
We believe the evidence will show that in some
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instances you have Ms. Rivero over here on the phone with
Mr. Wade, who is in touch with Carolyn, so information is going
between Carolyn and Mr. Wade and being transmitted through
Mr. Wade to --
THE COURT: Is that because of some computer
communications that you ascribe to Ms. Carolyn Wade?
MR. SNIDER: It's two parts. Here's the first: We
know from the first trial, and we'll establish in the second
trial, that the only way to log in to the Womply website -- and
that's the website for the PPP applications that are in the
indictment -- is to receive a one-time short-lived code that is
either sent to the email address on the application or the
phone number.
With respect to Carolyn Wade, that means when there was
a log-in to Carolyn Wade's application on the Womply website,
the code, which expired after 10 minutes, was sent either to
Carolyn Wade's cell phone or Carolyn Wade's email address.
To the extent it was sent to her cell phone, her cell
phone had to be -- we will show that -- I think it came out in
the first trial that that phone, her phone is with her pretty
much at all times, like most people's phones are.
THE COURT: Does --
MR. SNIDER: And -- oh, but, but, but, but not only
that, Judge, what the evidence shows definitively is that in
connection with applying for this PPP loan, Mrs. Wade held her
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cell phone to her face, in her hands, and took six pictures.
Okay. That's not disputed. We know we can establish her --
THE COURT: Isn't that the testimony in the last case?
MR. SNIDER: What's that?
THE COURT: Isn't that the testimony in the last case?
MR. SNIDER: That came out through the testimony and
the documents.
THE COURT: Yes.
MR. SNIDER: And around that time that she's holding
that phone in her hand to take these selfies, there are log-ins
to her application by Ms. Rivero using a code sent to her cell
phone. And the only way that happens is if Ms. Wade gets the
code and transmits it, in this case, through Mr. Wade to Haydee
Rivero.
And Haydee Rivero will testify, I believe, that in some
instances, the code expired and she had to go back to Tracy
Wade, and Tracy Wade will say something to the effect of "Hold
on; I've got to get it back from Carolyn." This is all
happening in real-time. So it's a long-winded way of saying,
"Is there some communication?" It is in the way I just laid
out. Are there conversations that we have evidence of? No.
THE COURT: In other words --
MR. SNIDER: There are text messages --
(Simultaneous speakers.)
THE COURT: -- never directly was in touch with Ms. Car
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-- well, not saying in touch. Was never in the presence and
speaking to Ms. Carolyn Wade; is that correct?
MR. SNIDER: As it relates to the PPP loans charged in
the indictment, correct.
THE COURT: All right. Mr. Wilcox, sorry for
interrupting.
MR. WILCOX: Your Honor, let me make sure that I
understand the issue.
I understand the issue to be whether or not the
statements of this Hunter person are going to be admitted as a
coconspirator as a statement in furtherance of the conspiracy.
Do I have -- is that the issue?
THE COURT: I'm not sure.
Does it establish that? Does the statement of
Ms. Rivero establish the conspiracy? I guess I'm waiting to
hear from you. I'm waiting for you to answer that question.
MR. WILCOX: Your Honor, it does not appear to. It
does not appear that any statement or any conversation that
Mr. Hunter had with Ms. Granados, now known as Ms. Rivero, has
anything to do with the crimes that Mr. Wade and Mrs. Wade are
charged with.
So I would say that the statements should be
inadmissible for that reason -- and Your Honor has to do a
little more research, but also, intuitively, I have a problem
with me not being able to confront these statements. It just
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seems to be a violation of Crawford or the confrontation rule.
THE COURT: I'm always available for any case law and
legal arguments you want to make, but no one's raised that
issue; so I don't know the answer.
MR. SNIDER: As far as relating to the Wades -- I'm
proffering here, and I'm summarizing, but, essentially, if
Mr. Hunter says to Ms. Rivero, "I don't have time to do those
Wades; you do it; I'll show you how" -- that's almost the sum
of the statements.
We're not going to have her testify what Hunter told
the Wades. We don't even have evidence that Hunter ever talked
to the Wades. That's the whole reason that Rivero got involved
was because Hunter was like, "I'm too busy. I don't have time
to do PPP for Tracy Wade. You do it, and here, I will show you
how to do it."
MR. WILCOX: So is the Government proffering that the
testimony that's coming from Ms. Rivero, formally known as
Ms. Granados, is going to be that the reason she did the Wades'
PPP application is because Mr. Hunter didn't have time to do
it? If that --
THE COURT: That's what he said.
MR. SNIDER: That's what I'm saying.
We're not seeking to enter any statement --
MR. WILCOX: Your Honor --
MR. SNIDER: -- through this witness about what Hunter
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said to the defendants. Again, I don't think they ever spoke,
which is the reason why Mr. Wade said to Haydee Rivero, "I
can't get in touch with this guy; you know, you do it for me."
MR. WILCOX: Well, it --
MR. SNIDER: So it's not a major point here and
that's --
THE COURT: No, it is a major point, frankly.
MR. WILCOX: I have a problem with -- well --
THE COURT: All right. We can all have problems,
right, but I need some case law.
MR. WILCOX: I understand, Judge.
THE COURT: That solves the problem.
MR. WILCOX: Again --
THE COURT: And this scenario is that 801(d)(2)
exception to the hearsay rule, and as you raised the issue, is
it a Crawford issue? I don't know if that's a Crawford issue.
If it's a coconspirator's statement, then that's what
it is. It would be admissible because that person is a part of
the conspiracy, but is this gentleman a part of the conspiracy
based on what Ms. Granados states?
MR. SNIDER: I think she has to lay the foundation for
it. If she does, then I think the rule is available.
MR. WILCOX: But, Judge, it's hard to argue this in the
abstract.
THE COURT: I want you all to do some research, and I
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will -- and I really don't like doing this in the middle of
trial or before trial because everybody's preparing for trial.
And I understand the rigors and demands, but you're raising
some issues here for the first time, and I really want to be
clear on your positions from the standpoint of the law.
So I'm going to ask you all -- maybe I'll have you
return on -- I don't know -- Friday afternoon, and I can listen
to you, and you can give me any cases you have.
MR. SNIDER: I have --
MR. WILCOX: I thought we were on recess. You mean
like this Friday?
THE COURT: Trial is next Monday.
MR. WILCOX: I understand, Judge, yes.
MR. SNIDER: If the Court sets that -- maybe I can
speak to Mr. Wilcox, but if the Court were to set that, is
there any way that we can do that telephonically? Just because
it is not easy. I have physical therapy that day, and it's
just not -- I can't drive myself. It's really a challenge, so
if we can do it telephonically.
Maybe I can speak to Mr. Wilcox as to whether we can
make some agreement here.
(Pause in proceedings.)
THE COURT: Here's one of the issues that I am thinking
about: Does the fact that Ms. Granados confers with Mr. Hunter
and Mr. Hunter doesn't have anything to do with this but tells
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Ms. Granados how to do something, does that make him a
coconspirator such that his statements are admissible?
MR. SNIDER: Your Honor, he's instructing her to commit
fraud.
THE COURT: Well, does that make him a part of the
conspiracy between Ms. Granados and the Wades? Is he a knowing
participant in this conspiracy? That's the issue that pops
out.
MR. SNIDER: I mean, obviously, a conspiracy can exist
without every coconspirator knowing each other, certainly.
THE COURT: Of course. But at least one conspirator
has to know that they're participating in this.
MR. SNIDER: So Mr. Hunter did two things. He did two
things to conspire with Haydee Rivero -- and she's effectively
admitted to this when she pled guilty -- Number 1, he assisted
her in getting a fraudulent loan.
THE COURT: Yes, okay.
MR. SNIDER: Then he taught her how to apply
fraudulently.
THE COURT: Okay. Now, those teachings --
MR. SNIDER: What's that?
THE COURT: That person takes those teachings and then
goes out and commits offenses, does that make Mr. Hunter a part
of the conspiracy?
MR. SNIDER: I think it's reasonably foreseeable that
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he's -- actually, what he said -- because it's not only that.
He knows that Ms. Rivero had tried to put him in touch with the
Wades, and when Mr. Wade was not successful in getting in touch
with Mr. Hunter, Ms. Rivero called him a couple of times, and
then she finally got in touch with him and said, you know,
"Mr. Wade wants you to do his -- he wants one of these PPP
loans." He said, "I don't have time for that but" --
THE COURT: Yes. Does that "I don't have time for
that" --
MR. SNIDER: That doesn't -- that's not --
THE COURT: -- does that mean, "I don't have time for
this conspiracy"?
MR. SNIDER: No.
THE COURT: I'm not a part of this --
MR. SNIDER: That is not what --
THE COURT: -- but this is the way you can do it?
No, I'm just saying is that a difference?
MR. SNIDER: I understand, but I think the testimony of
Ms. Rivero will establish that that is not at all what he meant
by that.
THE COURT: How is she going to --
MR. SNIDER: I think what she would say is that he was
perhaps saying, "I don't have time to do theirs" doesn't mean
"I don't want to continue to commit fraud." What's established
is that he's in a conspiracy with her to get fraudulent PPP
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loans and teaches her how to do that because he doesn't have
time to do Tracy Wade's loan. And so then, having learned how
to create a fake Schedule C, Ms. Rivero does it for Tracy Wade
and for Carolyn Wade and for many others, which she will
testify.
THE COURT: All right. So we've established that
Friday is not a good day. Do you all want to submit something
in writing? Is that better or not?
MR. SNIDER: We could do that.
MR. WILCOX: We may -- I mean, depending on the exact
testimony, it may be a moot point, Judge, but I would not be
opposed to submitting something in writing.
But I do want to say that what he --
THE COURT: I'm not sure what you mean by what he said
could be a moot point.
MR. WILCOX: I mean -- exactly. I mean, he has kind of
summarized what Ms. Rivero, formerly known as Ms. Granados,
would say about Mr. Hunter's involvement and teaching her how
to do these PPP applications -- these fraudulent PPP
applications. That might be something we don't have a problem
with. I need to talk to Mr. McCray about it, though. That's
what I meant by it might be moot.
MR. SNIDER: So you're saying you wouldn't object to
that coming in? That fact?
MR. WILCOX: I need to talk to Mr. McCray about it and
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the clients also.
The other thing is, is that it sounds to me -- it
sounds to me that when this guy said that "I don't have time to
do the Wades PPP application" -- and when I say "this guy," I
mean Mr. Hunter -- that he's withdrawing from the conspiracy.
MR. SNIDER: Okay. I --
MR. WILCOX: Or this particular conspiracy.
MR. SNIDER: So I'm paraphrasing.
THE COURT: I'm sorry?
MR. SNIDER: I'm paraphrasing, "I don't have time."
I'm speaking here without notes and without the transcript. So
it is the effect --
THE COURT: Let me make an alternative suggestion.
MR. SNIDER: Sure.
THE COURT: So here's what I'm contemplating: I have
another trial starting the 21st. So that's why I'm a little
nervous, which means I have eight days for this case without
having to create issues for the other case.
And you think your case will take four days, and I
don't think your case will take four days, at least based on
the last one. So I'm considering picking the jury Monday
afternoon and having you all here Monday morning, and you have
Ms. Granados here Monday morning so I can figure out exactly
what she's going to say so that I understand fully that this
would be an 801(d)(2)(e) conversation, such that she should be
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able to testify as to what Mr. Hunter said to her, which is in
furtherance of a conspiracy.
That means you have your Friday. That means you can
prepare, and we can have our argument and evidence Monday
morning and pick the jury starting at 1:00 Monday and still be
able to finish the case timely.
I thought you all would just jump at this, but I see
some hesitation.
MR. WILCOX: I have no problem with it, Judge. I'm
jumping.
MR. SNIDER: I'm a little concerned about -- I'm not
sure that that -- I'm not quite sure of the hearing the Court
is envisioning.
THE COURT: No, you're not sure what she's going to
say, and I want to be sure I understand what's going to be
said. That's why I'm proposing that. You can't tell me with
any specificity. You continue to say, "Well, I'm just kind of
thinking about it." I need to do better than that.
MR. SNIDER: We have prepared -- we've met with her to
prepare for her trial --
THE COURT: All right.
MR. SNIDER: -- twice.
THE COURT: Okay, but that's not what you just said.
MR. SNIDER: I said I was paraphrasing what she said.
THE COURT: Yes, paraphrasing, well --
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MR. SNIDER: Adam has been in all these -- Mr. Love has
been in all these trial preparations.
THE COURT: I'm putting it on you now. What do you
have to say?
MR. SNIDER: No, I think it's fair to say that
Ms. Rivero will testify that A, Mr. Wade could not get in touch
with Mr. Hunter and that she herself had trouble reaching him
and then when she finally did reach him, he said, "I'm too busy
or -- I'm too busy."
THE COURT: And what? And this is --
MR. SNIDER: "But I will teach you how to do it. You
can do it for Mr. Wade."
THE COURT: And then he meets with her? They talk on
the phone?
MR. SNIDER: Both.
THE COURT: What happened?
MR. SNIDER: She said both. She said that they talked
on the phone and that he also came to her house and gave her a
sample of a fraudulent Schedule C.
Now, I don't even know that that's hearsay -- the fact
that he's making statements. She can testify he came to my
house and what he did. I don't even know that it's necessary.
I think that this is more just to explain how she became
involved. I don't know that honestly it's necessary to put in
his statements.
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THE COURT: All right. Fine. See you Monday morning
at 9:00.
MR. SNIDER: Or 9:30?
THE COURT: 9:30. I'm sorry.
Anything else, gentlemen? Anything else I need to be
aware of that you can think of at this time?
Well, if you can't think of it now, let me know Monday
morning before we start the jury selection. All right.
MR. SNIDER: Judge, this is just my own -- I don't
know. It may not be easy for me to stand up and object to
these --
THE COURT: I will work with you --
MR. SNIDER: I appreciate it.
THE COURT: -- whatever you propose. I want you to be
as comfortable as you possibly can.
MR. SNIDER: I'm on one leg right now.
THE COURT: If that's a problem, have a seat, and we
can move on with this case. Not a problem.
If you start suffering during the trial or something,
you just need to speak up.
MR. SNIDER: Okay. Thank you.
THE COURT: All right. Thank you all. Have a great
afternoon and weekend.
(The proceedings concluded at 2:20 p.m. )
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C E R T I F I C A T E
I PATRICIA BAILEY-ENTIN hereby certify that the
foregoing transcription is an accurate transcription from the
notes and audio backup of the proceedings in the
above-entitled matter, which was originally reported by Glenda
Powers.
DATE: 5/2/2025
/s/Patricia Bailey-Entin
PATRICIA BAILEY-ENTIN, RPR, FRP
Official Court Reporter
United States District Court
Southern District of Florida
Case 0:23-cr-60173-KMW Document 279 Entered on FLSD Docket 05/27/2025 Page 44 of 52
$
$150,000 [1] - 12:4
$20,000 [1] - 18:6
$300 [1] - 10:4
$400 [2] - 10:3, 12:25
$80,000 [1] - 20:10
/
/s/Patricia [1] - 44:11
1
1 [3] - 1:5, 1:8, 37:15
10 [1] - 31:16
100,000 [1] - 18:8
11th [2] - 3:18
12 [1] - 11:10
13th [1] - 2:5
14th [2] - 3:18, 3:19
150 [3] - 11:11, 11:22,
17:25
150,000 [5] - 11:1,
11:5, 11:17, 14:4,
17:22
17 [1] - 16:8
18th [1] - 1:21
1:00 [1] - 41:5
1:02 [1] - 1:6
2
2 [1] - 22:23
2020 [2] - 10:1, 10:16
2024 [1] - 1:5
21st [1] - 40:16
23-cr-60173 [2] - 3:2,
3:3
23-cr-60173-KMW-1
[1] - 1:2
23-cr-60173-KMW-2
[1] - 1:3
24 [1] - 13:6
2:20 [2] - 1:6, 43:24
3
30 [1] - 9:3
300 [8] - 10:23, 12:2,
15:13, 16:5, 17:24,
21:2, 21:6, 21:12
300,000 [4] - 15:9,
15:10, 21:3, 21:4
302 [1] - 28:15
33130 [1] - 1:18
33132 [1] - 2:6
33317 [1] - 1:21
33394 [1] - 1:16
4
40 [1] - 9:3
400 [11] - 10:23, 11:8,
12:1, 14:1, 15:8,
16:4, 16:24, 17:24,
21:2, 21:6, 21:9
403 [2] - 7:11, 7:17
404(b [16] - 7:9, 7:15,
7:16, 7:19, 8:1,
10:20, 14:17, 15:22,
18:13, 18:23, 19:21,
22:13, 22:14, 24:2,
24:14
404(b) [1] - 8:17
4506-T [1] - 21:25
4th [1] - 2:5
5
5/2/2025 [1] - 44:11
500 [1] - 1:15
5201 [1] - 1:21
7
7th [1] - 1:16
8
80,000 [3] - 14:5, 18:1
801 [2] - 25:12, 30:15
801(d)(2 [1] - 35:14
801(d)(2)(e [3] - 29:8,
29:15, 40:25
9
900 [5] - 9:7, 9:8, 9:9,
13:13
901 [1] - 9:7
902 [1] - 9:7
907 [3] - 9:8, 9:9,
13:13
99 [1] - 2:5
9:00 [1] - 43:2
9:30 [3] - 3:22, 43:3,
43:4
A
able [3] - 33:25, 41:1,
41:6
above-entitled [1] -
44:7
absence [2] - 10:21,
17:14
absent [1] - 14:8
absolutely [2] - 9:20,
11:15
abstract [1] - 35:24
acceptable [1] - 15:22
According [1] - 17:23
according [1] - 13:4
accordingly [1] -
23:14
accurate [1] - 44:5
act [1] - 22:23
acts [1] - 18:22
Adam [3] - 1:17, 3:9,
42:1
adding [1] - 19:24
additional [1] - 28:19
address [5] - 8:15,
12:16, 25:17, 31:12,
31:17
Administration [1] -
20:19
admissibility [4] -
19:2, 22:13, 22:16,
25:13
admissible [9] -
10:20, 14:16, 17:13,
19:3, 19:8, 19:11,
23:10, 35:18, 37:2
admitted [5] - 14:15,
19:22, 26:11, 33:10,
37:15
admitting [1] - 28:22
afternoon [8] - 3:7,
3:10, 3:11, 3:14,
3:15, 36:7, 40:22,
43:23
agree [1] - 22:15
agreed [2] - 4:24, 6:3
agreement [1] - 36:21
aid [1] - 14:13
allegation [7] - 11:2,
13:25, 16:12, 16:17,
18:2, 18:8, 29:10
allegations [2] -
18:14, 21:5
alleged [3] - 6:3,
16:16, 21:10
Allen [13] - 4:1, 4:4,
4:6, 4:8, 4:20, 4:24,
4:25, 5:2, 5:9, 5:17,
5:20, 6:14, 7:4
allow [3] - 8:1, 19:19,
22:15
allowed [6] - 7:16,
8:21, 8:22, 19:3,
22:15, 23:2
allusion [1] - 4:1
almost [2] - 15:4, 34:8
alternative [1] - 40:13
AM [1] - 3:22
Amendment [1] - 30:5
AMERICA [1] - 1:4
amount [10] - 10:24,
11:25, 14:24, 15:12,
17:4, 17:25, 18:3,
18:5, 18:10, 21:22
amounts [2] - 13:19,
17:9
answer [3] - 10:2,
33:16, 34:4
answering [1] - 27:24
anticipate [1] - 23:23
anticipates [1] - 26:3
apologize [1] - 4:16
appear [3] - 23:7,
33:17, 33:18
appearances [1] - 3:5
APPEARANCES [1] -
1:12
appeared [1] - 14:2
applicant [5] - 12:14,
12:16, 12:17, 12:24
application [25] -
9:12, 9:22, 10:3,
10:5, 10:14, 10:19,
11:20, 12:21, 14:25,
15:12, 15:13, 16:21,
16:22, 21:9, 21:10,
21:11, 21:13, 21:16,
31:12, 31:15, 32:11,
34:19, 40:4
applications [15] -
9:13, 9:15, 9:20,
10:6, 10:11, 10:13,
10:15, 10:18, 12:9,
13:14, 13:19, 31:10,
39:19, 39:20
apply [3] - 8:23, 12:5,
37:18
applying [1] - 31:25
appreciate [1] - 43:13
approved [2] - 20:8,
20:11
April [1] - 10:16
argue [5] - 13:21,
13:25, 21:19, 22:7,
35:23
arguing [1] - 14:8
argument [8] - 4:5,
4:19, 4:22, 6:13,
13:22, 14:15, 14:16,
41:4
arguments [2] - 22:10,
34:3
ascribe [1] - 31:6
assert [1] - 4:3
assigned [1] - 10:13
assistant [2] - 3:7,
3:13
Assistant [1] - 3:9
assisted [2] - 27:5,
37:15
assume [2] - 18:13,
45
28:18
assured [1] - 22:10
attached [1] - 5:14
attempting [1] - 27:22
Attorney [2] - 3:8, 3:9
Attorney's [2] - 1:14,
1:18
audio [1] - 44:6
authorization [1] -
22:1
available [4] - 10:25,
27:10, 34:2, 35:22
aware [3] - 8:9, 8:10,
43:6
B
backup [1] - 44:6
BAILEY [2] - 44:4,
44:11
Bailey [1] - 44:11
BAILEY-ENTIN [2] -
44:4, 44:11
Bailey-Entin [1] -
44:11
based [5] - 4:21, 6:3,
14:25, 35:20, 40:20
bases [1] - 15:22
basis [1] - 28:22
Beach [1] - 13:1
became [1] - 42:23
BEFORE [1] - 1:10
beginning [1] - 3:5
behalf [2] - 3:8, 3:12
belabor [1] - 3:23
best [2] - 5:10, 23:20
better [2] - 39:8, 41:18
between [4] - 11:21,
12:13, 31:3, 37:6
blank [1] - 28:11
bogus [1] - 14:1
Boulevard [1] - 1:15
Broward [2] - 1:15,
16:8
Bruton [1] - 30:18
Building [1] - 2:4
bunch [1] - 9:24
Business [1] - 20:19
business [7] - 9:25,
11:23, 12:12, 12:24,
13:5, 18:6, 20:4
businesses [1] - 8:21
busy [3] - 34:13, 42:8,
42:9
BY [1] - 2:1
C
CALENDAR [1] - 1:10
CALL [1] - 1:10
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cannot [3] - 4:11, 4:16
Car [1] - 32:25
carefully [1] - 19:1
Carolyn [14] - 3:12,
23:9, 25:24, 30:24,
31:2, 31:3, 31:6,
31:14, 31:15, 31:17,
32:18, 33:2, 39:4
CAROLYN [1] - 1:7
case [40] - 3:16, 4:9,
7:12, 7:14, 7:25, 8:3,
15:24, 15:25, 16:5,
16:7, 17:16, 17:21,
22:11, 22:17, 22:19,
22:20, 23:12, 23:17,
23:22, 23:24, 24:3,
24:8, 24:13, 24:14,
25:18, 25:22, 26:1,
30:21, 32:3, 32:5,
32:13, 34:2, 35:10,
40:17, 40:18, 40:19,
40:20, 41:6, 43:18
Case [1] - 3:2
CASE [1] - 1:2
cases [5] - 4:22, 6:13,
23:1, 23:17, 36:8
cast [1] - 8:11
cell [5] - 31:17, 31:18,
32:1, 32:11
certain [3] - 5:13, 6:2,
11:10
certainly [2] - 7:5,
37:10
certification [1] -
12:10
certified [1] - 10:19
certify [1] - 44:4
challenge [1] - 36:18
challenged [1] - 17:23
charge [16] - 4:1, 4:4,
4:6, 4:20, 4:21, 4:24,
4:25, 5:2, 5:9, 5:17,
5:20, 6:14, 7:4,
18:20, 22:5, 30:4
charged [15] - 8:3,
14:24, 16:8, 17:12,
18:18, 19:9, 20:15,
20:17, 21:22, 25:22,
28:20, 28:25, 33:3,
33:21
charges [4] - 23:13,
23:19, 25:23, 28:19
cheat [1] - 21:19
chief [9] - 7:14, 22:12,
23:22, 23:24, 24:3,
24:8, 24:13, 24:14,
25:18
Circuit [1] - 4:23
citing [1] - 7:11
clarify [5] - 4:9, 4:11,
4:16, 5:12, 19:9
clear [5] - 9:8, 23:4,
24:16, 24:17, 36:5
clearly [1] - 6:8
client [1] - 29:13
clients [1] - 40:1
close [1] - 16:2
coconspirator [11] -
25:13, 25:21, 26:9,
26:12, 26:21, 26:24,
28:24, 29:6, 33:11,
37:2, 37:10
coconspirator's [1] -
35:17
coconspirators [3] -
18:23, 26:5, 26:7
cocounsel [3] - 3:9,
4:19, 4:25
cocounsel's [1] - 4:21
code [5] - 31:11,
31:16, 32:11, 32:13,
32:16
codefendant [1] - 23:9
Cohn [5] - 15:17,
15:24, 17:13, 22:17,
22:19
coincidentally [1] -
16:9
colleagues [1] - 8:14
Colorado [1] - 9:1
comfortable [1] -
43:15
coming [4] - 3:15,
6:23, 34:17, 39:24
commence [1] - 3:16
comment [2] - 20:6,
29:2
comments [2] - 19:18,
25:15
commit [2] - 37:3,
38:24
commits [1] - 37:23
commonly [1] - 4:20
communication [1] -
32:20
communications [1] -
31:6
company [1] - 10:7
complete [2] - 26:19,
26:25
completed [1] - 24:3
completely [1] - 14:25
computer [1] - 31:5
concern [3] - 7:17,
20:3
concerned [1] - 41:11
concise [1] - 8:2
concluded [1] - 43:24
concludes [1] - 7:13
conclusion [2] -
22:11, 22:12
conduct [1] - 17:12
conducted [1] - 28:15
confer [1] - 30:20
conference [2] - 3:24
conferred [1] - 28:8
confers [1] - 36:24
confines [1] - 8:3
confront [2] - 29:14,
33:25
confront".. [1] - 29:21
confrontation [1] -
34:1
confused [3] - 4:2,
4:6, 7:3
confusing [7] - 15:23,
19:16, 20:2, 20:17,
20:18, 21:20, 22:5
confusion [2] - 7:17,
30:14
connection [1] - 31:25
consent [1] - 6:19
consider [1] - 5:3
consideration [1] -
7:17
considered [1] - 8:22
considering [1] -
40:21
consistent [1] - 5:24
conspiracy [25] -
18:18, 18:20, 18:22,
18:24, 19:9, 23:2,
25:11, 25:23, 26:11,
26:15, 27:2, 28:25,
33:11, 33:15, 35:19,
37:6, 37:7, 37:9,
37:24, 38:12, 38:25,
40:5, 40:7, 41:2
conspirator [1] -
37:11
conspire [1] - 37:14
conspired [1] - 28:25
conspiring [1] - 25:24
contact [5] - 27:14,
27:16, 27:22, 30:23,
30:24
contacted [2] - 13:4,
13:5
contained [1] - 16:22
contemplating [1] -
40:15
context [1] - 30:17
continually [1] - 4:2
continue [3] - 5:5,
38:24, 41:17
continued [2] - 5:7,
5:20
conversation [2] -
33:18, 40:25
conversations [1] -
32:21
convinced [1] - 23:8
cooperating [1] - 26:2
copy [1] - 13:7
correct [5] - 9:10,
24:9, 28:19, 33:2,
33:4
correction [1] - 10:8
cost [2] - 5:3, 5:4
counsel [2] - 3:5, 3:15
counts [2] - 6:2, 25:11
couple [2] - 27:4, 38:4
course [2] - 7:10,
37:11
Court [26] - 2:3, 2:4,
3:1, 4:3, 4:6, 4:14,
4:19, 5:2, 6:6, 6:8,
6:11, 6:12, 6:17, 8:1,
8:25, 14:10, 15:20,
22:6, 25:5, 25:16,
36:14, 36:15, 41:12,
44:12, 44:12
COURT [133] - 1:1,
3:2, 3:10, 3:14, 4:18,
5:22, 6:21, 7:5, 8:10,
8:12, 9:9, 9:11, 9:18,
9:21, 10:5, 10:8,
10:11, 11:3, 11:5,
11:12, 11:14, 11:16,
13:11, 13:13, 13:16,
13:18, 14:6, 14:21,
15:1, 15:6, 15:10,
15:12, 15:14, 15:18,
15:23, 16:4, 16:13,
16:23, 16:25, 17:2,
17:18, 18:13, 18:17,
19:1, 19:6, 19:10,
19:14, 20:6, 20:10,
20:12, 20:25, 21:2,
21:5, 22:9, 22:22,
23:25, 24:4, 24:6,
24:9, 24:11, 24:18,
24:22, 24:25, 25:4,
25:7, 25:9, 25:11,
26:12, 26:16, 26:20,
26:23, 27:1, 27:14,
28:6, 28:18, 28:21,
29:2, 29:7, 29:10,
29:12, 29:15, 29:17,
29:20, 30:8, 30:12,
30:19, 31:5, 31:22,
32:3, 32:5, 32:8,
32:22, 32:25, 33:5,
33:13, 34:2, 34:21,
35:7, 35:9, 35:12,
35:14, 35:25, 36:12,
36:23, 37:5, 37:11,
37:17, 37:20, 37:22,
38:8, 38:11, 38:14,
38:16, 38:21, 39:6,
46
39:14, 40:9, 40:13,
40:15, 41:14, 41:21,
41:23, 41:25, 42:3,
42:10, 42:13, 42:16,
43:1, 43:4, 43:12,
43:14, 43:17, 43:22
court [1] - 4:15
Court's [2] - 8:9, 24:1
COVID [4] - 8:21, 8:22,
10:25
Crawford [3] - 34:1,
35:16
create [5] - 28:1, 28:4,
28:13, 39:3, 40:18
crimes [1] - 33:20
CRR [1] - 2:2
crystal [1] - 24:17
Cs [1] - 28:2
curious [1] - 11:16
D
d)(2)(e [1] - 25:12
Daryl [3] - 1:20, 1:20,
3:11
DATE [1] - 44:11
dates [1] - 10:15
David [2] - 1:13, 3:8
days [4] - 3:20, 40:17,
40:19, 40:20
deadlocked [2] - 6:11,
6:17
decide [1] - 7:14
decided [1] - 6:13
decision [1] - 23:6
declarant [1] - 26:14
declaration [1] - 6:20
declared [3] - 4:14,
5:8, 6:17
declaring [1] - 6:18
DEFENDANT [1] -
1:20
defendant [7] - 9:14,
14:18, 16:14, 22:21,
22:24, 26:2, 30:17
defendant's [1] - 5:19
defendants [7] - 16:9,
22:19, 22:25, 23:18,
30:16, 30:20, 35:1
Defendants [1] - 1:8
defense [3] - 4:3, 4:5,
4:9
definitively [1] - 31:24
defraud [2] - 20:23,
22:4
deliberate [4] - 6:6,
6:9, 6:11, 7:3
deliberating [1] - 5:6
delta [1] - 12:1
demands [1] - 36:3
Case 0:23-cr-60173-KMW Document 279 Entered on FLSD Docket 05/27/2025 Page 46 of 52
denial [1] - 6:2
denied [4] - 6:4,
17:17, 17:19
DENISE [1] - 1:7
Dennis [1] - 3:3
denoted [1] - 6:18
Denver [1] - 9:1
deputies [1] - 16:8
difference [2] - 11:20,
38:17
different [15] - 8:2,
10:6, 10:14, 10:15,
13:19, 15:1, 15:2,
16:5, 17:5, 17:7,
17:8, 17:9, 18:4,
23:13
differently [1] - 5:11
direct [4] - 9:1, 21:21,
27:16, 30:23
directed [1] - 5:5
directly [1] - 32:25
Disaster [1] - 14:12
disaster [3] - 8:20,
8:23, 8:24
disclosed [2] - 28:14,
28:16
discovery [1] - 28:17
discuss [3] - 3:16,
6:22, 7:1
discussed [1] - 28:8
dismiss [1] - 6:2
disputed [1] - 32:2
DISTRICT [2] - 1:1, 1:1
District [4] - 1:15, 2:4,
44:12, 44:13
divide [1] - 11:9
DIVISION [1] - 1:2
document [3] - 17:5,
28:5
documents [3] - 15:2,
21:6, 32:7
DOJ [1] - 1:14
DOJ-USAO [1] - 1:14
dollars [1] - 10:4
DONALD [1] - 1:10
Donald [1] - 2:3
done [2] - 5:19, 27:6
download [1] - 28:11
drive [1] - 36:18
dunk [1] - 15:4
during [2] - 8:21,
43:19
duty [4] - 6:6, 6:9,
6:11, 7:3
dynamite [1] - 4:21
E
easy [2] - 36:17, 43:10
ECF [1] - 5:15
economic [2] - 8:19,
8:23
Economic [1] - 14:12
effect [5] - 10:24,
12:22, 12:23, 32:17,
40:12
effectively [1] - 37:14
EIDL [15] - 8:19, 9:14,
10:25, 12:8, 14:5,
15:5, 16:21, 16:22,
17:20, 17:21, 18:11,
20:9, 21:9, 21:10
eight [1] - 40:17
either [4] - 4:7, 6:19,
31:12, 31:16
Eleventh [1] - 4:23
eligible [1] - 14:21
email [3] - 12:16,
31:12, 31:17
employees [1] - 18:6
end [1] - 24:13
ended [1] - 27:12
enter [1] - 34:23
entered [1] - 26:1
ENTIN [2] - 44:4,
44:11
Entin [1] - 44:11
entire [3] - 4:15, 5:15
entitled [5] - 11:25,
14:19, 17:25, 44:7
envisioning [1] -
41:13
error [2] - 20:23, 21:4
errors [1] - 20:25
Esquire [3] - 1:13,
1:17, 1:20
essentially [3] - 6:14,
12:5, 34:6
establish [8] - 26:5,
27:4, 28:23, 31:8,
32:2, 33:14, 33:15,
38:19
established [2] -
38:24, 39:6
establishes [1] - 26:8
estimate [2] - 23:20,
23:21
eventually [1] - 30:4
evidence [27] - 7:9,
7:15, 7:16, 8:1, 8:16,
10:20, 14:15, 15:6,
18:14, 18:24, 19:22,
22:7, 22:13, 22:15,
22:24, 23:5, 23:11,
23:14, 23:18, 24:15,
30:22, 30:25, 31:24,
32:21, 34:11, 41:4
exact [3] - 14:2, 15:17,
39:10
exactly [4] - 4:17,
7:11, 39:16, 40:23
example [3] - 26:13,
26:16, 28:13
exception [3] - 29:12,
29:17, 35:15
exclude [1] - 22:6
excuse [1] - 29:22
exhibit [1] - 5:14
exhibits [2] - 9:18,
12:12
exist [1] - 37:9
existed [1] - 8:20
expect [3] - 8:5, 27:3,
28:9
expenses [2] - 10:24,
11:21
expired [2] - 31:16,
32:16
explain [1] - 42:23
explanation [1] - 7:2
expressed [1] - 4:23
extent [4] - 7:14, 8:1,
28:3, 31:18
extreme [1] - 4:23
F
face [1] - 32:1
fact [5] - 5:12, 16:6,
36:24, 39:24, 42:20
factor [2] - 5:3, 11:10
facts [3] - 5:11, 7:12,
25:12
factual [2] - 15:25,
16:2
fair [1] - 42:5
fairly [1] - 12:24
fake [4] - 26:19, 28:5,
28:13, 39:3
false [5] - 15:3, 16:22,
16:25, 17:11, 18:9
far [4] - 23:23, 24:21,
30:9, 34:5
feasible [1] - 30:6
Federal [1] - 2:4
federal [1] - 3:19
feet [1] - 8:8
few [3] - 3:22, 18:12,
27:3
Fifth [1] - 30:5
figure [1] - 40:23
filed [5] - 4:3, 5:14,
13:10, 14:3, 21:10
finally [2] - 38:5, 42:8
fine [3] - 8:13, 15:18,
43:1
finish [1] - 41:6
first [19] - 3:17, 3:18,
4:13, 6:10, 10:17,
12:2, 19:13, 21:16,
23:10, 23:22, 24:20,
27:4, 28:16, 30:6,
30:14, 31:7, 31:8,
31:20, 36:4
five [1] - 7:19
five-day [1] - 7:19
flagged [2] - 13:2,
13:3
Floor [2] - 1:16, 2:5
FLORIDA [1] - 1:1
Florida [8] - 1:4, 1:15,
1:16, 1:18, 1:21, 2:6,
13:1, 44:13
flushes [1] - 13:24
fly [1] - 9:1
follow [2] - 19:17,
19:23
following [1] - 19:1
footnote [1] - 4:2
FOR [2] - 1:13, 1:20
foregoing [1] - 44:5
foreseeable [1] -
37:25
forgive [1] - 8:7
form [3] - 21:24,
21:25, 28:11
formally [2] - 25:19,
34:17
former [1] - 8:14
formerly [1] - 39:17
forms [1] - 14:10
Fort [1] - 1:16
foundation [2] -
28:23, 35:21
foundationally [1] -
26:8
four [2] - 40:19, 40:20
frankly [3] - 4:22,
23:7, 35:7
fraud [3] - 16:9, 37:4,
38:24
fraudulent [9] - 16:18,
27:5, 27:8, 27:10,
28:1, 37:16, 38:25,
39:19, 42:19
fraudulently [3] -
16:16, 26:25, 37:19
Friday [6] - 3:18, 3:19,
36:7, 36:11, 39:7,
41:3
friends [1] - 8:14
front [1] - 12:23
FRP [1] - 44:11
full [1] - 7:2
fully [1] - 40:24
funeral [3] - 13:1,
20:22, 21:11
Funeral [3] - 9:16,
10:7, 20:3
furtherance [4] -
47
26:11, 26:15, 33:11,
41:2
G
general [1] - 7:20
gentleman [2] - 28:19,
35:19
gentlemen [1] - 43:5
given [3] - 5:17, 5:20,
19:21
glad [1] - 25:16
Glenda [1] - 44:7
GLENDA [1] - 2:2
googled [1] - 12:23
GOVERNMENT [1] -
1:13
Government [31] -
3:6, 5:1, 5:11, 5:14,
5:18, 6:1, 6:3, 7:10,
7:13, 7:22, 7:23, 8:4,
8:15, 8:18, 9:6,
13:25, 16:8, 19:12,
22:3, 23:21, 24:3,
24:8, 25:18, 26:2,
26:3, 26:8, 26:10,
28:15, 29:5, 30:4,
34:16
Government's [6] -
22:11, 23:20, 23:24,
24:19, 25:2, 29:4
gradation [2] - 11:6,
11:7
Graham [1] - 2:3
GRAHAM [1] - 1:10
Granados [12] - 25:19,
27:19, 27:21, 33:19,
34:18, 35:20, 36:24,
37:1, 37:6, 39:17,
40:23
grand [1] - 17:24
great [1] - 43:22
gross [7] - 11:17,
11:21, 17:4, 17:5,
18:8, 18:10, 21:21
grossly [2] - 15:4,
15:6
grounds [1] - 17:14
guess [4] - 13:20,
21:19, 29:20, 33:15
guilty [2] - 26:1, 37:15
guy [4] - 27:24, 35:3,
40:3, 40:4
H
half [1] - 17:22
Hallandale [1] - 13:1
hand [1] - 32:10
handful [1] - 9:4
Case 0:23-cr-60173-KMW Document 279 Entered on FLSD Docket 05/27/2025 Page 47 of 52
hands [1] - 32:1
hard [1] - 35:23
Haydee [8] - 25:19,
27:21, 32:13, 32:15,
35:2, 37:14
hear [3] - 23:11,
25:15, 33:16
heard [2] - 7:2, 27:19
hearing [2] - 6:12,
41:12
hearsay [5] - 29:5,
29:12, 29:17, 35:15,
42:20
held [1] - 31:25
Hendrith [1] - 3:13
hereby [1] - 44:4
herself [1] - 42:7
hesitation [1] - 41:8
highly [1] - 15:21
Hold [1] - 32:17
holding [1] - 32:9
holiday [1] - 3:19
Home [3] - 9:17, 10:7,
20:4
home [3] - 13:1,
20:22, 21:11
honestly [1] - 42:24
Honor [19] - 3:7, 3:11,
4:16, 7:1, 8:7, 20:7,
20:8, 21:1, 21:18,
21:24, 22:3, 22:6,
29:25, 30:2, 33:7,
33:17, 33:23, 34:24,
37:3
HONORABLE [1] -
1:10
hostile [1] - 30:3
hour [2] - 9:2, 13:9
hours [1] - 13:6
house [2] - 42:18,
42:22
Hunt [2] - 4:20, 6:5
Hunter [29] - 26:6,
26:9, 26:10, 26:12,
26:13, 26:22, 27:5,
27:7, 27:10, 27:14,
27:22, 28:4, 28:20,
33:10, 33:19, 34:7,
34:10, 34:11, 34:13,
34:19, 34:25, 36:24,
36:25, 37:13, 37:23,
38:4, 40:5, 41:1,
42:7
Hunter's [2] - 28:6,
39:18
hypothetically [1] -
17:4
I
identity [1] - 17:14
illumination [1] - 4:10
immediately [3] -
20:20, 21:17, 21:21
improbable [1] - 13:18
improper [2] - 20:13,
20:15
inability [1] - 5:8
inaccuracy [1] - 6:5
inaccurate [1] - 20:21
inadmissible [1] -
33:23
incident [2] - 6:21,
7:18
included [1] - 9:6
income [10] - 12:25,
15:4, 16:19, 17:4,
17:5, 17:9, 18:7,
18:8, 18:10, 21:21
inconsistent [1] - 17:3
independent [1] - 10:9
indicate [1] - 9:19
indicated [1] - 5:2
indictment [13] -
14:24, 16:12, 16:16,
17:12, 18:9, 20:16,
20:18, 21:23, 22:6,
25:20, 28:17, 31:11,
33:4
indictments [1] -
25:14
indirectly [1] - 30:24
infer [3] - 13:22, 22:4,
28:18
inflated [1] - 16:18
inflating [2] - 15:4,
15:6
inflation [1] - 17:9
information [8] - 9:16,
9:22, 9:25, 18:9,
25:23, 26:5, 31:2
injured [1] - 8:8
Injury [1] - 14:12
injury [2] - 8:23, 11:24
instances [3] - 14:9,
31:1, 32:16
instructed [1] - 26:18
instructing [1] - 37:3
instruction [12] - 5:7,
6:7, 6:9, 6:15, 18:25,
19:12, 19:13, 19:14,
19:16, 19:21, 23:1,
23:8
instructions [1] -
28:10
intend [1] - 8:5
intending [1] - 8:25
intends [4] - 7:23,
8:16, 8:18, 25:18
intent [8] - 14:17,
15:21, 17:13, 18:24,
19:2, 20:23, 22:4,
23:2
interaction [1] - 12:13
interrupting [1] - 33:6
interview [1] - 28:15
introduce [1] - 29:5
introduced [1] - 30:16
intuitively [1] - 33:24
involve [1] - 15:24
involved [3] - 28:2,
34:12, 42:24
involvement [1] -
39:18
involving [3] - 7:25,
18:15, 27:2
IRS [3] - 13:10, 14:3,
28:11
issue [17] - 3:23, 4:2,
4:9, 6:22, 15:17,
23:8, 25:9, 25:12,
25:15, 33:8, 33:9,
33:12, 34:4, 35:15,
35:16, 37:7
issues [7] - 3:22, 7:8,
7:11, 7:18, 36:4,
36:23, 40:18
item [1] - 17:6
itself [1] - 17:18
J
James [1] - 2:4
Jamil [2] - 26:6, 26:21
joined [3] - 3:9, 3:12,
18:22
judge [2] - 3:25, 43:9
Judge [21] - 2:3, 4:11,
6:5, 15:16, 15:17,
15:24, 17:13, 20:18,
21:4, 22:17, 22:19,
23:21, 30:7, 30:10,
30:14, 31:24, 35:11,
35:23, 36:13, 39:11,
41:9
JUDGE [2] - 1:10, 1:11
judge's [1] - 6:24
jump [1] - 41:7
jumping [1] - 41:10
June [1] - 28:16
jurors [2] - 3:21, 19:16
jury [14] - 4:12, 4:13,
5:3, 5:5, 5:7, 6:10,
6:15, 13:22, 20:17,
22:5, 22:25, 40:21,
41:5, 43:8
Justice [1] - 2:4
K
Karen [1] - 3:3
keeps [1] - 6:23
kind [3] - 20:18, 39:16,
41:17
King [1] - 2:4
knowing [2] - 37:6,
37:10
knowingly [1] - 18:21
known [4] - 25:19,
33:19, 34:17, 39:17
knows [3] - 14:10,
27:23, 38:2
L
laid [1] - 32:20
last [9] - 3:24, 6:15,
16:8, 22:14, 24:19,
24:23, 32:3, 32:5,
40:21
Lauderdale [1] - 1:16
law [4] - 18:21, 34:2,
35:10, 36:5
lawyer [1] - 8:14
lay [1] - 35:21
learned [1] - 39:2
least [3] - 27:21,
37:11, 40:20
leaving [1] - 5:16
led [1] - 28:2
leg [1] - 43:16
legal [2] - 3:13, 34:3
liable [1] - 18:22
lies [2] - 17:7, 17:8
likelihood [1] - 22:4
limited [1] - 8:2
limiting [3] - 19:12,
19:14, 19:25
line [1] - 9:23
lines [1] - 9:24
list [2] - 9:6, 30:1
Listen [1] - 21:17
listen [3] - 7:24, 23:5,
36:7
listening [1] - 22:9
litigation [1] - 5:4
lived [1] - 31:11
loan [24] - 8:20, 9:14,
10:25, 11:25, 12:15,
14:5, 14:25, 17:2,
17:16, 17:18, 18:10,
18:11, 20:8, 20:9,
20:10, 20:11, 20:15,
27:5, 27:8, 27:10,
31:25, 37:16, 39:2
Loan [1] - 14:12
loans [8] - 8:21, 8:24,
14:22, 16:4, 16:17,
48
33:3, 38:7, 39:1
log [3] - 31:9, 31:15,
32:10
log-in [1] - 31:15
log-ins [1] - 32:10
logged [4] - 12:15,
12:17, 12:18, 12:19
long-winded [1] -
32:19
look [1] - 21:17
looked [2] - 15:20
looking [1] - 14:9
looks [1] - 22:25
Lord [1] - 22:2
Love [3] - 1:17, 3:9,
42:1
M
Magistrate [1] - 4:20
magistrate [4] - 3:25,
4:4, 5:1, 6:24
maiden [1] - 27:19
major [2] - 35:5, 35:7
March [1] - 16:11
matter [2] - 3:16, 44:7
maximum [7] - 10:24,
14:24, 17:25, 18:3,
18:5, 18:10, 18:11
McCray [6] - 6:22, 7:2,
7:3, 16:10, 39:21,
39:25
mean [14] - 17:18,
22:12, 28:7, 30:11,
36:10, 37:9, 38:11,
38:23, 39:10, 39:14,
39:16, 40:5
meaning [1] - 16:13
means [4] - 31:14,
40:17, 41:3
meant [2] - 38:19,
39:22
meets [1] - 42:13
memorialized [1] -
28:14
messages [1] - 32:23
met [2] - 29:25, 41:19
MIAMI [1] - 1:2
Miami [3] - 1:4, 1:18,
2:6
middle [1] - 36:1
might [4] - 24:12,
30:8, 39:20, 39:22
million [21] - 10:3,
10:23, 11:8, 12:1,
12:2, 12:25, 14:1,
15:8, 15:14, 15:15,
16:5, 16:24, 17:24,
21:2, 21:6, 21:9,
21:12
Case 0:23-cr-60173-KMW Document 279 Entered on FLSD Docket 05/27/2025 Page 48 of 52
mind [1] - 30:20
minute [3] - 14:21,
15:23, 20:20
minutes [2] - 9:4,
31:16
misrepresentation [1]
- 17:10
mistake [4] - 5:16,
10:21, 14:8, 17:14
mistrial [4] - 4:14, 5:9,
6:17, 6:18
model [2] - 19:13,
19:21
Monday [10] - 3:16,
3:21, 36:12, 40:21,
40:22, 40:23, 41:4,
41:5, 43:1, 43:7
money [2] - 12:18,
14:18
month [1] - 10:17
months [3] - 16:20,
17:12, 18:12
moot [3] - 39:11,
39:15, 39:22
morning [6] - 3:21,
40:22, 40:23, 41:5,
43:1, 43:8
most [2] - 9:2, 31:21
motion [5] - 4:7, 5:14,
6:2, 6:4, 17:15
motive [3] - 14:17,
15:21, 17:13
move [1] - 43:18
movie [1] - 30:10
moving [1] - 8:13
MR [148] - 3:7, 3:11,
4:11, 5:12, 5:23, 7:1,
8:7, 8:11, 8:15, 9:10,
9:12, 9:20, 9:22,
10:6, 10:10, 10:12,
11:4, 11:7, 11:13,
11:15, 11:19, 13:12,
13:15, 13:17, 13:21,
14:7, 14:23, 15:3,
15:7, 15:11, 15:13,
15:15, 15:19, 16:2,
16:7, 16:14, 16:24,
17:1, 17:7, 17:20,
18:16, 18:18, 19:5,
19:7, 19:11, 19:20,
20:7, 20:11, 20:14,
21:1, 21:4, 21:8,
21:9, 22:21, 23:21,
24:1, 24:5, 24:7,
24:10, 24:17, 24:19,
24:24, 25:2, 25:5,
25:8, 25:10, 25:16,
26:13, 26:17, 26:21,
26:24, 27:3, 27:16,
28:9, 28:20, 28:22,
29:3, 29:9, 29:11,
29:13, 29:16, 29:19,
29:22, 29:24, 30:10,
30:13, 30:22, 31:7,
31:23, 32:4, 32:6,
32:9, 32:23, 33:3,
33:7, 33:17, 34:5,
34:16, 34:22, 34:24,
34:25, 35:4, 35:5,
35:8, 35:11, 35:13,
35:21, 35:23, 36:9,
36:10, 36:13, 36:14,
37:3, 37:9, 37:13,
37:18, 37:21, 37:25,
38:10, 38:13, 38:15,
38:18, 38:22, 39:9,
39:10, 39:16, 39:23,
39:25, 40:6, 40:7,
40:8, 40:10, 40:14,
41:9, 41:11, 41:19,
41:22, 41:24, 42:1,
42:5, 42:11, 42:15,
42:17, 43:3, 43:9,
43:13, 43:16, 43:21
multiple [1] - 14:10
multiply [1] - 11:10
N
name [4] - 16:14, 26:6,
27:19, 27:20
named [1] - 25:20
nature [2] - 15:3, 17:8
NE [1] - 2:5
necessary [2] - 42:22,
42:24
need [8] - 12:16,
12:24, 35:10, 39:21,
39:25, 41:18, 43:5,
43:20
needed [1] - 22:7
nervous [1] - 40:17
net [1] - 12:4
never [4] - 4:6, 27:14,
32:25, 33:1
new [1] - 6:13
next [2] - 3:19, 36:12
nine [2] - 9:5, 9:8
none [1] - 5:24
NOs [1] - 1:2
notation [1] - 12:22
note [5] - 6:10, 6:12,
6:16, 8:25, 10:22
noted [1] - 3:25
notes [5] - 12:13,
12:19, 13:5, 40:11,
44:6
nothing [2] - 21:14
notice [1] - 15:16
noticed [1] - 8:16
Number [3] - 3:2,
22:23, 37:15
number [6] - 10:14,
11:9, 11:14, 11:18,
11:22, 31:13
numbers [2] - 10:14,
28:13
O
object [2] - 39:23,
43:10
objecting [1] - 5:23
objection [1] - 6:19
obtained [1] - 16:16
obviously [3] - 18:21,
30:3, 37:9
occasions [1] - 5:6
occurred [1] - 5:10
October [1] - 1:5
OF [3] - 1:1, 1:4, 1:10
offenses [1] - 37:23
offered [2] - 27:6, 27:7
office [1] - 16:8
Office [2] - 1:14, 1:18
Office-Southern [1] -
1:14
Official [2] - 2:3, 44:12
once [3] - 6:9, 6:24,
23:12
one [42] - 6:5, 6:15,
7:9, 7:17, 8:23, 9:24,
10:2, 10:8, 10:14,
10:15, 10:16, 10:17,
11:3, 12:2, 12:3,
12:11, 14:2, 14:21,
16:4, 16:5, 16:9,
16:18, 17:3, 17:4,
17:17, 19:6, 21:20,
22:21, 22:22, 23:3,
23:19, 26:6, 28:1,
30:2, 30:16, 30:19,
31:11, 36:23, 37:11,
38:6, 40:21, 43:16
one's [1] - 34:3
one-time [1] - 31:11
openly [1] - 26:4
operate [1] - 11:24
opposed [1] - 39:12
Order [1] - 3:1
order [3] - 4:1, 6:18,
11:5
originally [1] - 44:7
outset [1] - 20:8
outweighed [1] -
15:22
overstating [1] - 9:3
own [3] - 4:10, 18:6,
43:9
P
p.m [1] - 43:24
packages [1] - 17:2
Pages [1] - 1:8
paid [1] - 14:6
pandemic [7] - 11:23,
11:24, 12:4, 14:10,
14:11, 14:14, 17:11
paraphrasing [4] -
40:8, 40:10, 41:24,
41:25
part [9] - 8:19, 18:23,
27:1, 28:1, 35:18,
35:19, 37:5, 37:23,
38:14
participant [1] - 37:7
participating [1] -
37:12
particular [1] - 40:7
parties [2] - 6:13,
15:24
parties' [1] - 6:19
parts [1] - 31:7
PATRICIA [2] - 44:4,
44:11
pattern [1] - 16:6
Pause [1] - 36:22
pause [1] - 29:23
Paycheck [2] - 14:11,
25:25
paying [1] - 20:8
penalty [1] - 10:19
pending [2] - 3:22,
10:17
people [1] - 27:13
people's [1] - 31:21
perhaps [3] - 4:9,
6:22, 38:23
period [1] - 3:19
perjury [1] - 10:19
perplexing [1] - 5:18
persisted [1] - 5:7
person [6] - 19:3,
27:7, 28:12, 33:10,
35:18, 37:22
personal [1] - 4:10
phone [13] - 28:10,
31:1, 31:13, 31:17,
31:18, 31:19, 31:20,
32:1, 32:10, 32:12,
42:14, 42:18
phones [2] - 27:25,
31:21
physical [1] - 36:17
pick [1] - 41:5
picking [1] - 40:21
pictures [1] - 32:1
pieces [1] - 9:24
49
Plantation [1] - 1:21
play [1] - 7:12
plea [1] - 26:1
pleadings [1] - 4:3
pleased [1] - 8:12
pled [1] - 37:15
PM [2] - 1:6
point [14] - 3:23, 6:17,
13:20, 14:8, 17:3,
17:6, 19:2, 20:12,
22:12, 30:2, 35:5,
35:7, 39:11, 39:15
pointed [2] - 4:21, 5:1
popped [1] - 30:19
pops [1] - 37:7
position [2] - 29:4,
30:3
positions [1] - 36:5
possible [4] - 7:3, 7:5,
7:6, 16:3
possibly [1] - 43:15
POWERS [1] - 2:2
Powers [1] - 44:8
PPP [21] - 10:18,
10:22, 11:2, 14:18,
16:9, 16:17, 16:20,
18:2, 18:10, 27:5,
27:8, 31:10, 31:25,
33:3, 34:14, 34:19,
38:6, 38:25, 39:19,
40:4
prediction [1] - 23:24
preference [1] - 25:3
prejudices [2] - 19:15,
23:9
preparations [1] -
42:2
prepare [2] - 41:4,
41:20
prepared [2] - 4:7,
41:19
preparing [1] - 36:2
presence [1] - 33:1
present [7] - 4:8, 4:15,
7:24, 8:5, 8:6, 24:14,
24:23
presentation [1] -
4:22
presented [2] - 15:17,
24:8
presenting [3] - 7:25,
23:18, 24:21
presently [1] - 28:20
pretty [2] - 23:4, 31:20
primary [1] - 20:16
probative [2] - 15:21,
23:7
problem [8] - 19:12,
33:24, 35:8, 35:12,
39:20, 41:9, 43:17,
Case 0:23-cr-60173-KMW Document 279 Entered on FLSD Docket 05/27/2025 Page 49 of 52
43:18
problems [3] - 19:15,
30:15, 35:9
proceed [1] - 7:7
proceedings [5] -
5:16, 29:23, 36:22,
43:24, 44:6
process [1] - 10:22
production [1] - 28:17
proffering [2] - 34:6,
34:16
program [7] - 8:19,
8:20, 10:25, 12:8,
14:12, 18:4
Program [2] - 14:11,
25:25
programs [1] - 14:13
promptly [2] - 13:8
propensity [1] - 22:8
propose [1] - 43:14
proposed [1] - 19:25
proposing [1] - 41:16
proprietorship [2] -
18:4, 18:5
Protection [2] - 14:11,
25:25
proven [1] - 16:17
provide [2] - 21:24,
22:1
provided [2] - 20:20,
21:21
purpose [1] - 11:25
purposely [1] - 4:25
put [12] - 10:2, 11:8,
11:9, 12:1, 12:7,
17:15, 18:9, 25:5,
26:6, 30:1, 38:2,
42:24
puts [2] - 12:12, 12:20
putting [2] - 10:22,
42:3
Q
qualify [1] - 14:4
quite [2] - 4:5, 41:12
quoting [1] - 12:22
R
raise [3] - 3:24, 6:23,
25:15
raised [4] - 3:24,
25:16, 34:3, 35:15
raising [1] - 36:3
rather [1] - 23:19
reach [3] - 5:8, 10:14,
42:8
reaching [1] - 42:7
read [6] - 6:1, 6:6,
6:11, 7:10, 22:23,
25:14
readily [1] - 19:17
reading [2] - 5:24,
6:13
real [2] - 15:7, 32:19
real-time [1] - 32:19
really [9] - 12:7, 21:18,
22:7, 22:10, 22:25,
30:6, 36:1, 36:4,
36:18
reason [6] - 6:23,
20:16, 33:23, 34:12,
34:18, 35:2
reasonably [1] - 37:25
rebuttal [1] - 24:12
receive [1] - 31:11
received [3] - 9:15,
18:14, 20:9
recess [1] - 36:10
recollection [2] - 5:10,
6:7
recommendation [2] -
6:1, 6:25
recommending [1] -
6:2
record [7] - 5:13, 5:25,
6:8, 12:12, 13:5,
13:24, 26:6
records [7] - 9:5, 9:12,
10:21, 12:8, 13:8,
22:2
refer [2] - 5:3, 5:20
reference [1] - 15:16
referred [2] - 4:20,
7:18
referring [1] - 27:18
refers [2] - 4:4, 22:24
refined [1] - 23:17
reflects [1] - 6:8
regard [1] - 19:18
relates [2] - 25:25,
33:3
relating [1] - 34:5
relevant [3] - 18:11,
18:19, 18:20
relief [4] - 14:10,
14:11, 14:18, 17:11
reluctance [1] - 4:24
relying [1] - 12:9
remotely [1] - 5:24
reply [2] - 5:19, 15:17
report [3] - 6:1, 6:24,
28:15
reported [1] - 44:7
REPORTED [1] - 2:1
Reporter [2] - 2:3,
44:12
represented [1] -
16:10
requested [2] - 5:1,
21:25
requesting [1] - 9:14
research [2] - 33:24,
35:25
reserving [2] - 24:2,
24:7
resolve [2] - 19:14,
23:8
respect [5] - 19:15,
20:24, 21:13, 21:16,
31:14
respects [1] - 27:3
respond [1] - 19:19
response [2] - 5:13,
7:11
rest [2] - 23:22, 24:4
rested [3] - 24:3, 24:5,
24:8
result [3] - 11:24,
14:3, 14:14
return [8] - 13:7, 13:9,
14:1, 14:2, 17:24,
20:21, 21:22, 36:7
returns [2] - 15:7,
15:10
revenue [3] - 10:23,
11:21, 12:4
review [2] - 12:19,
12:20
reviewing [2] - 12:21,
22:1
rigors [1] - 36:3
Rivero [34] - 25:19,
25:20, 26:14, 27:4,
27:5, 27:6, 27:11,
27:12, 27:18, 27:21,
27:23, 27:25, 28:4,
28:6, 28:23, 30:20,
30:23, 31:1, 32:11,
32:14, 32:15, 33:15,
33:19, 34:7, 34:12,
34:17, 35:2, 37:14,
38:2, 38:4, 38:19,
39:3, 39:17, 42:6
Rivero's [1] - 27:17
routinely [1] - 19:21
RPR [1] - 44:11
rule [8] - 23:14, 25:5,
26:11, 29:12, 29:18,
34:1, 35:15, 35:22
ruling [2] - 24:2, 24:7
S
sample [2] - 28:12,
42:19
saw [1] - 6:5
SBA [23] - 8:18, 9:14,
9:15, 12:6, 12:8,
12:9, 12:12, 12:13,
12:15, 12:21, 13:2,
13:3, 14:4, 14:6,
14:7, 14:18, 17:18,
17:23, 20:23, 21:13,
21:20, 21:21, 21:24
SBA's [1] - 12:19
SBI [1] - 10:13
scenario [5] - 7:20,
16:1, 16:3, 24:13,
35:14
schedule [1] - 26:19
Schedule [4] - 26:25,
28:2, 39:3, 42:19
seat [2] - 7:22, 43:17
seated [1] - 3:14
second [10] - 4:14,
5:6, 6:12, 12:3,
15:12, 15:13, 21:13,
22:20, 23:23, 31:8
see [10] - 8:12, 20:1,
22:3, 23:1, 23:5,
23:13, 24:12, 29:3,
41:7, 43:1
seeing [1] - 22:18
seek [2] - 10:24, 26:10
seeking [5] - 14:23,
17:22, 29:5, 34:23
seem [2] - 13:2, 20:20
select [1] - 3:21
selected [1] - 4:12
selection [1] - 43:8
selfies [1] - 32:10
Senior [1] - 2:3
SENIOR [1] - 1:11
sent [4] - 31:12, 31:16,
31:18, 32:11
separate [5] - 10:8,
10:10, 10:13, 23:1,
25:22
series [1] - 9:7
session [2] - 3:17,
3:20
set [1] - 36:15
sets [1] - 36:14
sheriff [1] - 16:8
short [2] - 8:4, 31:11
short-lived [1] - 31:11
shot [1] - 6:15
show [15] - 9:12,
10:21, 12:9, 13:8,
15:8, 15:10, 17:13,
18:7, 27:10, 30:22,
30:25, 31:19, 34:8,
34:14
showed [1] - 21:6
showing [2] - 12:3,
15:2
shows [5] - 12:21,
13:13, 13:23, 14:17,
50
31:24
side [1] - 6:20
sign [1] - 21:25
signed [2] - 22:2
similar [3] - 15:25,
16:22, 22:23
similarities [1] - 22:18
similarly [1] - 11:2
simple [1] - 9:23
simply [3] - 5:5, 5:8,
7:13
Simultaneous [1] -
32:24
situation [1] - 30:18
six [1] - 32:1
slow [1] - 8:8
Small [1] - 20:19
small [2] - 8:21, 12:24
Smith [5] - 3:13,
16:15, 16:20
Snider [1] - 1:13
SNIDER [113] - 3:7,
5:12, 5:23, 8:7, 8:11,
8:15, 9:10, 9:12,
9:20, 9:22, 10:6,
10:10, 10:12, 11:4,
11:7, 11:13, 11:15,
11:19, 13:12, 13:15,
13:17, 13:21, 14:7,
14:23, 15:3, 15:7,
15:11, 15:13, 15:15,
15:19, 16:2, 16:7,
16:14, 16:24, 17:1,
17:7, 17:20, 18:16,
18:18, 19:5, 19:7,
19:11, 19:20, 21:8,
22:21, 23:21, 24:1,
24:5, 24:7, 24:10,
24:17, 24:19, 24:24,
25:2, 25:5, 25:8,
25:10, 25:16, 26:13,
26:17, 26:21, 26:24,
27:3, 27:16, 28:9,
28:20, 28:22, 30:22,
31:7, 31:23, 32:4,
32:6, 32:9, 32:23,
33:3, 34:5, 34:22,
34:25, 35:5, 35:21,
36:9, 36:14, 37:3,
37:9, 37:13, 37:18,
37:21, 37:25, 38:10,
38:13, 38:15, 38:18,
38:22, 39:9, 39:23,
40:6, 40:8, 40:10,
40:14, 41:11, 41:19,
41:22, 41:24, 42:1,
42:5, 42:11, 42:15,
42:17, 43:3, 43:9,
43:13, 43:16, 43:21
Snyder [1] - 3:8
Case 0:23-cr-60173-KMW Document 279 Entered on FLSD Docket 05/27/2025 Page 50 of 52
sole [2] - 18:3, 18:4
solves [1] - 35:12
someone [3] - 4:7,
8:23, 16:4
sometime [1] - 23:22
sometimes [1] - 24:11
somewhere [1] -
10:15
sorry [5] - 24:6, 27:7,
33:5, 40:9, 43:4
sort [2] - 23:17, 26:4
sought [1] - 18:3
sounds [3] - 24:2,
40:2, 40:3
SOUTHERN [1] - 1:1
Southern [2] - 1:14,
44:13
Southwest [1] - 1:21
speakers [1] - 32:24
speaking [2] - 33:2,
40:11
specificity [1] - 41:17
speculating [1] - 30:8
stand [1] - 43:10
standpoint [1] - 36:5
start [3] - 3:23, 43:8,
43:19
starting [3] - 3:21,
40:16, 41:5
state [2] - 3:5, 3:17
statement [13] - 7:19,
15:3, 26:19, 28:7,
29:6, 29:8, 29:9,
30:16, 33:11, 33:14,
33:18, 34:23, 35:17
statements [13] -
16:22, 17:12, 25:13,
26:10, 28:3, 28:22,
33:10, 33:22, 33:25,
34:9, 37:2, 42:21,
42:25
states [3] - 3:25,
16:25, 35:20
STATES [3] - 1:1, 1:4,
1:11
States [6] - 2:4, 3:3,
3:8, 16:15, 44:12
status [2] - 12:15,
12:18
STENOGRAPHICAL
LY [1] - 2:1
Stephanie [4] - 16:14,
16:15, 16:20
still [3] - 10:17, 12:18,
41:5
stop [3] - 19:7, 19:8
Street [2] - 1:21, 2:5
struggling [1] - 14:14
submit [1] - 39:7
submitted [9] - 7:10,
9:13, 10:6, 10:15,
13:9, 14:1, 16:4,
16:21, 20:2
submitting [1] - 39:12
substantiate [3] -
13:6, 14:1
substantive [1] -
18:20
successful [1] - 38:3
suffering [1] - 43:19
suggest [1] - 20:22
suggestion [3] -
20:12, 20:14, 40:13
sum [1] - 34:8
summarize [1] - 29:4
summarized [1] -
39:17
summarizing [1] -
34:6
summary [4] - 24:20,
24:22, 25:1, 25:6
superseding [2] -
25:20, 28:17
synopsis [1] - 8:4
T
taught [2] - 27:11,
37:18
tax [10] - 13:7, 13:9,
14:1, 14:2, 15:7,
15:10, 17:23, 20:21,
21:22, 22:1
taxpayers [1] - 14:13
teach [1] - 42:11
teaches [1] - 39:1
teaching [3] - 28:4,
28:7, 39:18
teachings [2] - 37:20,
37:22
telephonic [1] - 3:24
telephonically [2] -
36:16, 36:19
testify [15] - 9:4, 9:15,
10:12, 11:15, 12:8,
26:4, 27:21, 28:24,
30:17, 32:15, 34:10,
39:5, 41:1, 42:6,
42:21
testifying [3] - 26:1,
26:14, 26:24
testimony [15] - 9:2,
12:5, 20:2, 20:3,
26:3, 26:9, 27:3,
27:9, 27:17, 32:3,
32:5, 32:6, 34:17,
38:18, 39:11
text [1] - 32:23
THE [135] - 1:10, 1:13,
1:20, 3:2, 3:10, 3:14,
4:18, 5:22, 6:21, 7:5,
8:10, 8:12, 9:9, 9:11,
9:18, 9:21, 10:5,
10:8, 10:11, 11:3,
11:5, 11:12, 11:14,
11:16, 13:11, 13:13,
13:16, 13:18, 14:6,
14:21, 15:1, 15:6,
15:10, 15:12, 15:14,
15:18, 15:23, 16:4,
16:13, 16:23, 16:25,
17:2, 17:18, 18:13,
18:17, 19:1, 19:6,
19:10, 19:14, 20:6,
20:10, 20:12, 20:25,
21:2, 21:5, 22:9,
22:22, 23:25, 24:4,
24:6, 24:9, 24:11,
24:18, 24:22, 24:25,
25:4, 25:7, 25:9,
25:11, 26:12, 26:16,
26:20, 26:23, 27:1,
27:14, 28:6, 28:18,
28:21, 29:2, 29:7,
29:10, 29:12, 29:15,
29:17, 29:20, 30:8,
30:12, 30:19, 31:5,
31:22, 32:3, 32:5,
32:8, 32:22, 32:25,
33:5, 33:13, 34:2,
34:21, 35:7, 35:9,
35:12, 35:14, 35:25,
36:12, 36:23, 37:5,
37:11, 37:17, 37:20,
37:22, 38:8, 38:11,
38:14, 38:16, 38:21,
39:6, 39:14, 40:9,
40:13, 40:15, 41:14,
41:21, 41:23, 41:25,
42:3, 42:10, 42:13,
42:16, 43:1, 43:4,
43:12, 43:14, 43:17,
43:22
theirs [1] - 38:23
therapy [1] - 36:17
thinking [2] - 36:23,
41:18
third [2] - 5:23, 6:16
three [1] - 5:21
threshold [1] - 11:11
Thursday [1] - 23:22
timely [1] - 41:6
together [2] - 27:2,
28:7
took [1] - 32:1
total [1] - 22:18
totality [1] - 23:11
totally [1] - 23:12
touch [9] - 27:24,
31:2, 32:25, 33:1,
35:3, 38:2, 38:3,
38:5, 42:6
Tracey [1] - 3:4
TRACY [1] - 1:7
Tracy [8] - 3:12, 9:14,
25:24, 32:16, 32:17,
34:14, 39:2, 39:3
transcript [2] - 5:15,
40:11
TRANSCRIPT [1] -
1:10
transcription [2] -
44:5
transition [1] - 27:25
transmits [1] - 32:13
transmitted [1] - 31:3
trial [21] - 3:19, 4:8,
7:19, 7:21, 16:10,
16:11, 16:17, 22:25,
24:20, 30:6, 31:8,
31:9, 31:20, 36:2,
36:12, 40:16, 41:20,
42:2, 43:19
tried [4] - 15:24,
18:11, 23:12, 38:2
trouble [1] - 42:7
true [6] - 10:19, 12:10,
15:5, 18:16, 19:5
truthful [1] - 12:10
try [2] - 23:16, 29:3
trying [4] - 8:2, 17:11,
21:19, 22:7
twice [2] - 6:7, 41:22
two [25] - 3:20, 5:6,
9:13, 10:6, 10:8,
10:10, 10:13, 10:14,
10:15, 13:13, 13:19,
14:9, 16:4, 16:16,
20:25, 22:19, 22:25,
23:18, 30:15, 31:7,
37:13
type [1] - 20:23
U
U.S [3] - 3:8, 3:9,
14:13
ultimately [1] - 27:9
under [7] - 10:19,
10:25, 14:16, 15:22,
18:21, 26:11, 29:11
understood [1] - 21:7
unfortunately [2] -
4:11, 4:15
unindicted [3] - 26:21,
28:24, 29:6
UNITED [3] - 1:1, 1:4,
1:11
United [6] - 2:4, 3:2,
3:3, 3:8, 16:15,
51
44:12
unnecessary [1] -
23:9
up [11] - 5:20, 6:23,
12:5, 12:14, 13:21,
14:25, 19:1, 22:12,
27:12, 43:10, 43:20
update [1] - 12:16
US [2] - 1:14, 1:18
USAO [1] - 1:14
V
verdict [1] - 5:8
verify [1] - 12:25
versus [3] - 3:3, 3:4,
16:15
vindictiveness [1] -
6:3
violation [1] - 34:1
vs [1] - 1:5
W
Wade [52] - 3:3, 3:4,
3:12, 7:25, 9:14,
9:16, 10:7, 13:4,
13:5, 16:20, 17:21,
18:3, 18:15, 18:21,
19:4, 19:11, 19:15,
19:25, 20:2, 20:3,
23:10, 25:24, 27:11,
27:22, 27:23, 30:23,
30:24, 31:2, 31:3,
31:4, 31:6, 31:14,
31:25, 32:12, 32:13,
32:17, 33:2, 33:20,
34:14, 35:2, 38:3,
38:6, 39:3, 39:4,
42:6, 42:12
WADE [2] - 1:7, 1:7
Wade's [5] - 7:20,
31:15, 31:17, 39:2
Wades [11] - 27:2,
27:7, 27:12, 27:15,
34:5, 34:8, 34:11,
34:12, 37:6, 38:3,
40:4
Wades' [1] - 34:18
Wait [1] - 20:19
wait [4] - 7:13, 14:21,
15:23, 22:11
waiting [3] - 12:18,
33:15, 33:16
wants [3] - 8:4, 38:6
waste [1] - 7:18
website [4] - 28:11,
31:9, 31:10, 31:15
week [2] - 23:23
weekend [1] - 43:23
Case 0:23-cr-60173-KMW Document 279 Entered on FLSD Docket 05/27/2025 Page 51 of 52
52
whatsoever [1] - 5:16
whole [2] - 27:13,
34:12
Wilcox [11] - 1:20,
1:20, 3:11, 6:22,
16:11, 19:19, 20:6,
29:2, 33:5, 36:15,
36:20
WILCOX [35] - 3:11,
4:11, 7:1, 20:7,
20:11, 20:14, 21:1,
21:4, 21:9, 29:3,
29:9, 29:11, 29:13,
29:16, 29:19, 29:22,
29:24, 30:10, 30:13,
33:7, 33:17, 34:16,
34:24, 35:4, 35:8,
35:11, 35:13, 35:23,
36:10, 36:13, 39:10,
39:16, 39:25, 40:7,
41:9
willingly [2] - 22:2,
22:3
winded [1] - 32:19
withdrawing [1] - 40:5
witness [19] - 8:18,
8:25, 9:4, 9:6, 10:12,
11:15, 22:14, 24:20,
24:21, 24:22, 24:25,
25:1, 29:14, 29:20,
29:24, 29:25, 30:1,
30:4, 34:25
witnesses [1] - 25:6
Womply [2] - 31:9,
31:15
words [5] - 9:18,
11:17, 22:14, 24:11,
32:22
writing [2] - 39:8,
39:12
written [1] - 6:18
wrote [1] - 21:11
Y
year [6] - 13:7, 13:16,
13:20, 14:3, 16:8,
28:16
Case 0:23-cr-60173-KMW Document 279 Entered on FLSD Docket 05/27/2025 Page 52 of 52File and source
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- gov.uscourts.flsd.670191.279.0.pdf
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- 754,597 bytes
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- 0fcdac0d973afb452dc425ad32d559ebc0a2592ec1e0352a80ea0bbbac97029b
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